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. ORDER Ghislaine Maxwell, Docket No: 18-2868 Defendant - Appellee, v. Virginia L. Giuffre, Plaintiff - Appellee. _______________________________________ Appellee, Ghislaine Maxwell, filed a petition for panel rehearing, or, in the alternative, for rehearing en banc. The panel that determined the appeal has considered the request for panel rehearing, and the active members of the Court have considered the request for rehearing en banc. IT IS HEREBY ORDERED that the petition is denied. FOR THE COURT: Catherine O'Hagan Wolfe, Clerk Selected docket entries for case 18−2868 Generated: 08/09/2019 10:13:24 Filed Document Description 08/09/2019 272 Order FILED 08/09/2019 273 273 Judgment Mandate ISSUED 273 Supporting Document 273 Supporting Document 08/09/2019 275 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED 08/09/2019 276 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED 08/09/2019 277 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED Page Docket Text 2 ORDER, dated 08/09/2019, directing the Clerk to issue the mandate forthwith, by JAC, RSP, CFD, FILED.[2628208] [18−2868] JUDGMENT MANDATE, ISSUED.[2628218] [18−2868] 4 5 30 31 UNSEALED SUMMARY JUDGMENT RECORD, appendix 1 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628223] [18−2868] 49 UNSEALED SUMMARY JUDGMENT RECORD, appendix 2 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628224] [18−2868] 126 UNSEALED SUMMARY JUDGMENT RECORD, appendix 3 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628225] [18−2868] Case 18-2868, Document 272, 08/09/2019, 2628208, Page1 of 2 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. Before: José A. Cabranes, Rosemary S. Pooler, Christopher F. Droney, Circuit Judges. ________________________________ Julie Brown, Miami Herald Media Company, ORDER Intervenors - Appellants, v. 18-2868 Ghislaine Maxwell, Defendant - Appellee, v. Virginia L. Giuffre, Plaintiff - Appellee. ________________________________ Alan M. Dershowitz, Michael Cernovich, DBA Cernovich Media, Intervenors - Appellants, v. Virginia L. Giuffre, Plaintiff - Appellee, v. Ghislaine Maxwell, Defendant-Appellee. ________________________________ 16-3945(L) 17-1625(Con) 17-1722(Con) Case 18-2868, Document 272, 08/09/2019, 2628208, Page2 of 2 IT IS HEREBY ORDERED that the Clerk is directed to issue the mandate forthwith. For the Court: Catherine O’Hagan Wolfe, Clerk of Court Case 18-2868, Document 273-1, 08/09/2019, 2628218, Page1 of 1 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT MANDATE 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 3rd day of July, two thousand and nineteen. Before: José A. Cabranes, Rosemary S. Pooler, Christopher F. Droney, Circuit Judges. ________________________________ Julie Brown, Miami Herald Media Company, Intervenors - Appellants. JUDGMENT Docket Nos. 18-2868 v. Ghislaine Maxwell, Defendant - Appellee, v. Virginia L. Giuffre, Plaintiff - Appellee. ________________________________ The appeal in the above captioned case from a judgment of the United States District Court for the Southern District of New York was argued on the district court’s record and the parties’ briefs. Upon consideration thereof, IT IS HEREBY ORDERED, ADJUDGED and DECREED that the orders of the District Court entered on November 2, 2016, May 3, 2017, and August 27, 2018 are VACATED. The Court further ORDERS the unsealing of the summary judgment record as described in its opinion. The case is REMANDED to the District Court for a particularized review of the remaining materials. For the Court: Catherine O’Hagan Wolfe, Clerk of Court MANDATE ISSUED ON 08/09/2019 Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page1 of 25 18‐2868; 16‐3945‐cv(L)  Brown v. Maxwell; Dershowitz v. Giuffre   In the United States Court of Appeals for the Second Circuit         AUGUST TERM 2018    No. 18‐2868‐cv    JULIE BROWN, MIAMI HERALD COMPANY, Intervenors‐Appellants,    v.    GHISLAINE MAXWELL, Defendant‐Appellee,    v.    VIRGINIA L. GIUFFRE, Plaintiff‐Appellee.            No. 16‐3945‐cv(L)  No. 17‐1625 (CON)  No. 17‐1722(CON)    ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA,  Intervenors‐Appellants,  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page2 of 25   V.     VIRGINIA L. GIUFFRE, Plaintiff‐Appellee,    v.    GHISLAINE MAXWELL, Defendant‐Appellee.*        On Appeal from the United States District Court  for the Southern District of New York          ARGUED: MARCH 6, 2019  DECIDED: JULY 3, 2019          Before: CABRANES, POOLER, and DRONEY, Circuit Judges.        Intervenors‐Appellants  Alan  Dershowitz,  Michael  Cernovich,  and the Miami Herald Company (with reporter Julie Brown) appeal  from certain orders of the United States District Court for the Southern  District of New York (Robert W. Sweet, Judge) denying their respective  motions to unseal filings in a defamation suit. We conclude that the   The Clerk of Court is directed to amend the captions as set out above.  * 2  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page3 of 25 District  Court  failed  to  conduct  the  requisite  particularized  review  when ordering the sealing of the materials at issue. At the same time,  we recognize the potential damage to privacy and reputation that may  accompany public disclosure of hard‐fought, sensitive litigation. We  therefore  clarify  the  legal  tools  that  district  courts  should  use  in  safeguarding the integrity of their dockets. Accordingly, we VACATE  the District Court’s orders entered on November 2, 2016, May 3, 2017,  and August 27, 2018, ORDER the unsealing of the summary judgment  record  as  described  further  herein,  and  REMAND  the  cause  to  the  District  Court  for  particularized  review  of  the  remaining  sealed  materials.   Judge Pooler concurs in this opinion except insofar as it orders  the immediate unsealing of the summary judgment record without a  remand.        SANFORD L. BOHRER (Christine N. Walz,  Madelaine J. Harrington, New York, NY, on  the brief), Holland & Knight LLP, Miami, FL,  for Intervenors‐Appellants Julie Brown and  Miami Herald.  TY GEE (Adam Mueller, on the brief),  Haddon, Morgan and Foreman, P.C.,  Denver, CO, for Defendant‐Appellee Ghislaine  Maxwell.    3  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page4 of 25             PAUL G. CASSELL (Sigrid S. McCawley, Boies  Schiller Flexner LLP, Ft. Lauderdale, FL, on  the brief), S.J Quinney College of Law,  University of Utah, Salt Lake City, UT, for  Plaintiff‐Appellee Virginia L. Giuffre.  ANDREW G. CELLI JR. (David A. Lebowitz, on  the brief), Emery, Celli, Brinckerhoff &  Abady LLP, New York, NY, for Intervenor‐ Appellant Alan M. Dershowitz.  MARC RANDAZZA (Jay Marshall Wolman,  Las Vegas, NV, on the brief), Randazza Legal  Group, PLLC, Hartford, CT, for Intervenor‐ Appellant Michael Cernovich.        JOSÉ A. CABRANES, Circuit Judge:  Intervenors‐Appellants  Alan  M.  Dershowitz  (“Dershowitz”),  Michael  Cernovich  (“Cernovich”),  and  the  Miami  Herald  Company  (with reporter Julie Brown, jointly the “Herald”) appeal from certain  orders of the United States District Court for the Southern District of  New York (Robert W. Sweet, Judge) denying their respective motions  to  unseal  filings  in  a  defamation  suit.  We  conclude  that  the  District  Court  failed  to  conduct  the  requisite  particularized  review  when  ordering  the  sealing  of  the  materials  at  issue.  At  the  same  time,  we  4  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page5 of 25 recognize  the  potential  damage  to  privacy  and  reputation  that  may  accompany public disclosure of hard‐fought, sensitive litigation. We  therefore  clarify  the  legal  tools  that  district  courts  should  use  in  safeguarding the integrity of their dockets. Accordingly, we VACATE  the District Court’s orders entered on November 2, 2016, May 3, 2017,  and August 27, 2018, ORDER the unsealing of the summary judgment  record  as  described  further  herein,  and  REMAND  the  cause  to  the  District  Court  for  particularized  review  of  the  remaining  sealed  materials.  I. BACKGROUND  A. Jeffrey Epstein’s Conviction and the CVRA Suit  The origins of this case lie in a decade‐old criminal proceeding  against financier Jeffrey Epstein (“Epstein”). On June 30, 2008, Epstein  pleaded guilty to Florida state charges of soliciting, and procuring a  person  under  the  age  of  eighteen  for,  prostitution.  The  charges  stemmed from sexual activity with privately hired “masseuses,” some  of whom were under eighteen, Florida’s age of consent. Pursuant to  an agreement with state and federal prosecutors, Epstein pleaded to  the  state  charges.  He  received  limited  jail‐time,  registered  as  a  sex  offender,  and  agreed  to  pay  compensation  to  his  victims.  In  return,  prosecutors declined to bring federal charges.   Shortly  after  Epstein  entered  his  plea,  two  of  his  victims,  proceeding  as  “Jane  Doe  1”  and  “Jane  Doe  2,”  filed  suit  against  the  Government  in  the  Southern  District  of  Florida  under  the  Crime  Victims’ Rights Act (“CVRA”). The victims sought to nullify the plea  5  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page6 of 25 agreement,  alleging  that  the  Government  failed  to  fulfill  its  legal  obligations to inform and consult with them in the process leading up  to Epstein’s plea deal.1   On December 30, 2014, two additional unnamed victims—one  of whom has now self‐identified as Plaintiff‐Appellee Virginia Giuffre  (“Giuffre”)—petitioned  to  join  in  the  CVRA  case.  These  petitioners  included  in  their  filings  not  only  descriptions  of  sexual  abuse  by  Epstein,  but  also  new  allegations  of  sexual  abuse  by  several  other  prominent  individuals,  “including  numerous  prominent  American  politicians,  powerful  business  executives,  foreign  presidents,  a  well‐ known  Prime  Minister,  and  other  world  leaders,”  as  well  as  Dershowitz (a long‐time member of the Harvard Law School faculty  who had worked on Epstein’s legal defense) and Defendant‐Appellee  Ghislaine Maxwell (“Maxwell”).2    Dershowitz  moved  to  intervene,  seeking  to  “strike  the  outrageous  and  impertinent  allegations  made  against  him  and  to  request a show cause order to the attorneys that have made them.”3  Exercising  its  authority  to  “strike  from  a  pleading  an  insufficient    On  February  21,  2019,  the  Florida  District  Court  ruled  that  federal  prosecutors had violated the CVRA by failing to adequately notify the two victims‐ plaintiffs of the plea deal. The District Court has not yet determined the appropriate  remedy. See Doe 1 v. United States, 359 F. Supp. 3d 1201, 1204–17 (S.D. Fla. 2019).  1  Doe 1 v. United States, No. 08‐CV‐80736‐KAM, 2015 WL 11254692, at *2 (S.D.  Fla. Apr. 7, 2015) (internal quotation marks omitted).  2  Id. (internal quotation marks and brackets omitted).  3 6  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page7 of 25 defense  or  any  redundant,  immaterial,  impertinent,  or  scandalous  matter . . . on its own,”4 the Florida District Court (Kenneth A. Marra,  Judge) sua sponte struck all  allegations against additional parties from  the  pleadings,  including  those  against  Dershowitz,  and  therefore  denied Dershowitz’s motion as moot.5   The stricken allegations, however, quickly found their way into  the  press,  and  several  media  outlets  published  articles  repeating  Giuffre’s  accusations.  In  response  to  the  allegations,  on  January  3,  2015,  Maxwell’s  publicist  issued  a  press  statement  declaring  that  Giuffre’s allegations “against Ghislaine Maxwell are untrue” and that  her “claims are obvious lies.”6   B. Giuffre Sues Maxwell  On  September  21,  2015,  Giuffre  filed  the  underlying  action  against Maxwell in the Southern District of New York. Giuffre alleged  that  Maxwell  had  defamed  her  through  this  and  other  public  statements. Extensive and hard‐fought discovery followed. Due to the  volume of sealing requests filed during discovery, on August 9, 2016,  the  District  Court  entered  a  Sealing  Order  that  effectively  ceded  control  of  the  sealing  process  to  the  parties  themselves.  The  Sealing  Order disposed of the requirement that the parties file individual letter  briefs to request sealing and prospectively granted all of the parties’   Fed. R. Civ. P. 12(f).  4  Doe 1, 2015 WL 11254692, at *2–3.  5  See Giuffre v. Maxwell, 325 F. Supp. 3d 428, 434 (S.D.N.Y. 2018).  6 7  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page8 of 25 future  sealing  requests.  In  total,  167  documents—nearly  one‐fifth  of  the  docket—were  filed  under  seal.  These  sealed  documents  include,  inter  alia,  motions  to  compel  discovery,  motions  for  sanctions  and  adverse inferences, motions in limine, and similar material.   On  January  6,  2017,  Maxwell  filed  a  motion  for  summary  judgment.  The  parties  submitted  their  memoranda  of  law  and  supporting exhibits contesting this motion under seal. On March 22,  2017,  the  District  Court  denied  the  motion  in  a  heavily  redacted  76‐ page  opinion.  Once  again,  the  entire  summary  judgment  record,  including  the  unredacted  version  of  the  District  Court  opinion  denying summary judgment, remained under seal. On May 24, 2017,  Maxwell and  Giuffre  executed  a  settlement  agreement, and  the  case  was closed the next day.  C. Motions to Intervene and Unseal  Over  the  course  of  the  litigation  before  Judge  Sweet,  three  outside parties attempted to unseal some or all of the sealed material.  On August 11, 2016, Dershowitz moved to intervene, seeking to unseal  three  documents  that,  he  argues,  demonstrate  that  Giuffre  invented  the  accusations  against  him.  On  January  19,  2017,  Cernovich,  an  independent  blogger  and  self‐described  “popular  political  journalist,”7  moved  to  intervene,  seeking  to  unseal  the  summary  judgment record, and Dershowitz joined his motion. On April 6, 2018,  after the case had settled, the Herald moved to intervene and unseal   Br. Appellant (Cernovich) 4.  7 8  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page9 of 25 the entire docket. The District Court granted each of these motions to  intervene, but denied the related requests to unseal in orders entered  November 2, 2016, May 3, 2017, and August 27, 2018, respectively.   The  Appellants  timely  appealed  from  each  of  the  orders  denying their respective motions to unseal. Although each Appellant  seeks  the  release  of  a  different  set  of  documents,  all  argue  that  the  District  Court  failed  to  analyze  the  documents  individually  or  properly apply the presumption of public access to court documents.  We therefore ordered that the appeals be heard in tandem and held  argument on March 6, 2019.   On March 11, 2019, we issued an order to show cause why we  “should  not  unseal  the  summary  judgment  motion,  including  any  materials filed in connection with this motion, and the District Court’s  summary  judgment  decision.”8  The  parties  timely  filed  their  responses.  II. DISCUSSION  There  are  two  categories  of  sealed  material  at  issue  in  these  appeals: (1) the summary judgment record, which includes the parties’  summary judgment briefs, their statements of undisputed facts, and  incorporated exhibits; and (2) court filings made in the course of the  discovery  process  and  with  respect  to  motions  in  limine.  In  this  Opinion,  we  explain  that  our  law  requires  the  unsealing  of  the   Giuffre v. Maxwell, No. 18‐2868‐cv, Docket No. 138.  8 9  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page10 of 25 summary  judgment  materials  and  individualized  review  of  the  remaining sealed materials.   While  the  law  governing  public  access  to  these  materials  is  largely  settled,  we  have  not  yet  adequately  addressed  the  potential  harms that often accompany such access. These harms are apparent.  Over  forty  years  ago,  the  Supreme  Court  observed  that,  without  vigilance,  courts’  files  might  “become  a  vehicle  for  improper  purposes.”9    Our  legal  process  is  already  susceptible  to  abuse.  Unscrupulous  litigants  can  weaponize  the  discovery  process  to  humiliate and embarrass their adversaries. Shielded by the “litigation  privilege,”10  bad  actors  can  defame  opponents  in  court  pleadings  or  depositions  without  fear  of  lawsuit  and  liability.  Unfortunately,  the  presumption of public access to court documents has the potential to  exacerbate  these  harms  to  privacy  and  reputation  by  ensuring  that  damaging material irrevocably enters the public record.  We therefore take the opportunity to describe the tools available  to district courts in protecting the integrity of the judicial process, and  emphasize the courts’ responsibility to exercise these powerful tools.  We also caution the public to critically assess allegations contained in  judicial pleadings.   Nixon v. Warner Commcʹns, Inc., 435 U.S. 589, 598 (1978).  9  See notes 46–47 and accompanying text, post.    10 10  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page11 of 25 A. Standard of Review  When  reviewing  a  district  court’s  decision  to  seal  a  filing  or  maintain such a seal, “we examine the court’s factual findings for clear  error, its legal determinations de novo, and its ultimate decision to seal  or unseal for abuse of discretion.”11   B. The Summary Judgment Materials  With respect to the first category of materials, it is well‐settled  that  “documents  submitted  to  a  court  for  its  consideration  in  a  summary  judgment  motion  are—as  a  matter  of  law—judicial  documents  to  which  a  strong  presumption  of  access  attaches,  under  both  the  common  law  and  the  First  Amendment.”12  In  light  of  this  strong  First  Amendment  presumption,  “continued  sealing  of  the  documents may be justified only with specific, on‐the‐record findings  that  sealing  is  necessary  to  preserve  higher  values  and  only  if  the  sealing order is narrowly tailored to achieve that aim.”13   Bernstein v. Bernstein Litowitz Berger & Grossmann LLP, 814 F.3d 132, 139  (2d Cir. 2016).  11  Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We  observe that our holding in Lugosch relies on the general principle that parties may  “be assumed to have supported their papers  with admissible evidence and non‐ frivolous arguments.” Id. at 122. Insofar as a district court has, through striking a  filing,  specifically  found  that  assumption  inapplicable,  the  categorical  rule  in  Lugosch may not apply. See notes 42–43 and accompanying text, post.  12   Id.  at  124.  Examples  of  such  countervailing  values  may  include,  depending  on  the  circumstances,  preserving  “the  right  of  an  accused  to  fundamental fairness in the jury selection process,” Press‐Enter. Co. v. Superior Court  13 11  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page12 of 25 In this case, the District Court erred in several respects.14 First, it  failed to give proper weight to the presumption of access that attaches  to  documents  filed  in  connection  with  summary  judgment  motions.  The  District  Court  reasoned  that  the  summary  judgment  materials  were “entitled to a lesser presumption of access” because “summary  judgment  was  denied  by  the  Court.”15  In  assigning  a  “lesser  presumption” to such materials, the District Court relied on a single  sentence  of  dicta  from  our  decision  in  United  States  v.  Amodeo.16  We  have  since  clarified,  however,  that  this  sentence  was  based  on  a  “quotation from a partial concurrence and partial dissent in the D.C.  Circuit . . . [and] is thus not the considered decision of either this court  or  the  D.C.  Circuit.”17  In  fact,  we  have  expressly  rejected  the  proposition that “different types of documents might receive different  of California, Riverside Cty., 464 U.S. 501, 510 (1984); the protection of attorney‐client  privilege,  Lugosch,  435 F.3d  at 125; “the  danger  of  impairing  law  enforcement  or  judicial efficiency,” SEC. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001); and “the  privacy interest of those who resist disclosure,” id.   Our discussion here focuses specifically on the District Court’s denial of  the Herald’s motion to unseal the entire record. Because this decision grants relief  to all Appellants, we need not discuss any separate, additional error in the District  Court’s denial of the earlier motions to unseal.  14  Giuffre, 325 F. Supp. 3d at 444.   15  71 F.3d 1044, 1049 (2d Cir. 1995) (“Amodeo II”) (“One judge [in the District  of  Columbia  Circuit]  has  pointed  out,  for  example,  that  where  a  district  court  denied the summary judgment motion, essentially postponing a final determination  of substantive legal rights, the public interest in access is not as pressing.” (internal  quotation marks omitted; emphasis in original)).  16  Lugosch, 435 F.3d at 121.  17 12  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page13 of 25 weights of presumption based on the extent to which they were relied  upon in resolving [a] motion [for summary judgment].”18  Second,  in  contravention  of  our  precedent,  the  District  Court  failed to review the documents individually and produce “specific, on‐ the‐record  findings  that  sealing  is  necessary  to  preserve  higher  values.”19  Instead,  the  District  Court  made  generalized  statements  about the record as a whole.20 This too was legal error.  Finally,  upon  reviewing  the  summary  judgment  materials  in  connection  with  this  appeal,  we  find  that  there  is  no  countervailing  privacy interest sufficient to justify their continued sealing. Remand  with respect to these documents is thus unnecessary. Accordingly, and  to  avoid  any  further  delay,21  we  order  that  the  summary  judgment  documents  (with  minimal  redactions)  be  unsealed  upon  issuance  of  our mandate.22    Id. at 123.  18  Id. at 124.  19   See,  e.g.,  Giuffre,  325  F.  Supp.  3d  at  445  (summarily  concluding  that  all  “[t]he Summary Judgment Judicial Documents openly refer to and discuss these  allegations [of sexual assault and sexual trafficking] in comprehensive detail, and  that those allegations “establish[] a strong privacy interest here”).  20   Cf.  Lugosch,  435  F.3d  at  127  (ordering  that  “the  mandate  shall  issue  forthwith” to expedite the unsealing process).  21   Upon  issuance  of  our  mandate,  a  minimally  redacted  version  of  the  summary judgment record will be made accessible on the Court of Appeals docket.  We  have  implemented  minimal  redactions  to  protect  personally  identifying  information such as personal phone numbers, contact lists, birth dates, and social  22 13  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page14 of 25 C. The Remaining Sealed Materials  The law governing disclosure of the remaining sealed material  in  this  case  is  only  slightly  more  complex.  The  Supreme  Court  has  recognized a qualified right “to inspect and copy judicial records and  documents.”23 In defining “judicial records and documents,” we have  emphasized  that  “the  mere  filing  of  a  paper  or  document  with  the  court is insufficient to render that paper a judicial document subject to  the right of public access.”24 Instead, “the item filed must be relevant  to the performance of the judicial function and useful in the judicial  process in order for it to be designated a judicial document.”25   As our precedent makes clear, a court “perform[s] the judicial  function”  not  only  when  it  rules  on  motions  currently  before  it,  but  also when properly exercising its inherent “supervisory powers.”26 A  security  numbers.  We  have  also  redacted  the  names  of  alleged  minor  victims  of  sexual abuse from deposition testimony and police reports, as well as deposition  responses  concerning  intimate  matters  where  the  questions  were  likely  only  permitted—and the responses only compelled—because of a strong expectation of  continued  confidentiality.  See  Fed.  R.  Civ.  P.  5.2.  While  we  appreciate  the  views  expressed in Judge Pooler’s separate opinion, the panel majority believes that the  efforts  invested  by  three  former  district  judges  in  reviewing  these  materials  adequately address those concerns.    Nixon, 435 U.S. at 597–98.  23  United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) (“Amodeo I”).  24  Id.   25  Cf. United States v. HSBC Bank USA, N.A., 863 F.3d 125, 135 (2d Cir. 2017)  (explaining  that,  in  considering  whether  the  report  of  a  monitor  charged  with  assessing  compliance  with  a  deferred  prosecution  agreement  is  a  judicial  26 14  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page15 of 25 document is thus “relevant to the performance of the judicial function”  if it would reasonably have the tendency to influence a district court’s  ruling on a motion or in the exercise of its supervisory powers, without  regard  to  which  way  the  court  ultimately  rules  or  whether  the  document  ultimately  in  fact  influences  the  court’s  decision.27  Accordingly,  if  in  applying  these  standards,  a  court  determines  that  documents  filed  by  a  party  are  not  relevant  to  the  performance  of  a  judicial function, no presumption of public access attaches.28   Once  an  item  is  deemed  relevant  to  the  exercise  of  judicial  power,  “the  weight  to  be  given  the  presumption  of  access  must  be  governed by the role of the material at issue in the exercise of Article  III judicial power and the resultant value of such information to those  document,  “[i]f  the  district  court’s  conception  of  its  supervisory  power  in  this  context were correct, the Monitor’s Report would quite obviously be relevant to the  performance  of  the  judicial  function  and  useful  in  the  judicial  process”  (internal  quotation  marks  omitted)).  Whether  a  specific  judicial  decision  constitutes  a  “performance of the judicial function” is a question of law. Accordingly, we review  such determinations de novo. Id. at 134.    Amodeo I, 44 F.3d at 145–46 (concluding that documents were relevant to  the  performance  of  a  judicial  function  because  they  would  have  “informed”  the  district court’s decision whether to discharge or retain a Receiver); see also FTC. v.  Standard Fin. Mgmt. Corp., 830 F.2d 404, 409 (1st Cir. 1987) (citing Federal Rule of  Evidence  401’s  “having  any  tendency”  definition  of  relevance  in  determining  whether documents were “judicial documents”).  27   As  we  explain  below,  there  are  several  (often  preferable)  tools  beyond  sealing that district courts can use to protect their dockets from becoming a vehicle  for irrelevant—and potentially defamatory—accusations. See Section D, post.  28 15  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page16 of 25 monitoring the federal courts.”29 Thus, while evidence introduced at  trial  or  in  connection  with  summary  judgment  enjoys  a  strong  presumption of public access, documents that “play only a negligible  role in the performance of Article III duties” are accorded only a low  presumption that “amounts to little more than a prediction of public  access  absent  a  countervailing  reason.”30  Documents  that  are  never  filed  with  the  court,  but  simply  “passed  between  the  parties  in  discovery, lie entirely beyond the presumption’s reach.”31  The  remaining  sealed  materials  at  issue  here  include  filings  related  to,  inter  alia,  motions  to  compel  testimony,  to  quash  trial  subpoenae,  and  to  exclude  certain  deposition  testimony.  All  such  motions, at least on their face, call upon the court to exercise its Article  III powers. Moreover, erroneous judicial decision‐making with respect  to such evidentiary and discovery matters can cause substantial harm.  Such materials are therefore of value “to those monitoring the federal  courts.”32  Thus,  all  documents  submitted  in  connection  with,  and  relevant to, such judicial decision‐making are subject to at least some  presumption of public access.33   Amodeo II, 71 F.3d at 1049.  29  Id. at 1050.  30  Id.  31  Id. at 1049.    32  In previous decisions, we have identified an important exception to this  general  rule:  the  presumption  of  public  access  does  not  apply  to  material  that  is  submitted  to  the  court  solely  so  that  the  court  may  decide  whether  that  same  33 16  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page17 of 25 Although a court’s authority to oversee discovery and control  the  evidence  introduced  at  trial  surely  constitutes  an  exercise  of  judicial  power,  we note  that  this  authority  is  ancillary  to  the  court’s  core  role  in  adjudicating  a  case.  Accordingly,  the  presumption  of  public  access  in  filings  submitted  in  connection  with  discovery  disputes  or  motions  in  limine  is  generally  somewhat  lower  than  the  presumption applied to material introduced at trial, or in connection  with  dispositive motions  such  as motions  for  dismissal  or summary  judgment.34  Thus,  while  a  court  must  still  articulate  specific  and  substantial reasons for sealing such material, the reasons usually need  not  be  as  compelling  as  those  required  to  seal  summary  judgment  filings.   Here, the precise basis for the District Court’s decision to deny  the motion to unseal these remaining materials is unclear. In the three  paragraphs  devoted  to  the  issue,  the  District  Court  emphasized  the  potential for embarrassment “given the highly sensitive nature of the  underlying allegations,” and concluded that “the documents sealed in  the course of discovery were neither relied upon by [the District] Court  in  the  rendering  of  an  adjudication,  nor  necessary  to  or  helpful  in  resolving a motion.”35 It is therefore unclear whether the District Court  held  that  these  materials  were  not  judicial  documents  (and  thus  are  material  must  be  disclosed  in  the  discovery  process  or  shielded  by  a  Protective  Order. See TheStreet.Com, 273 F.3d at 233.    Amodeo II, 71 F.3d at 1049–50.  34   Giuffre,  325  F.  Supp.  3d.  at  442  (internal  quotation  marks  and  brackets  omitted).  35 17  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page18 of 25 not subject to a presumption of public access), or found that privacy  interests outweighed a limited right of public access.  On either interpretation, however, the District Court’s holding  was error. Insofar as the District Court held that these materials are not  judicial documents because it did not rely on them in adjudicating a  motion, this was legal error. As explained above, the proper inquiry is  whether the documents are relevant to the performance of the judicial  function,  not  whether  they  were  relied  upon.36  Indeed,  decision‐ makers  often  find  that  a  great  deal  of  relevant  material  does  not  ultimately sway their decision. And insofar as the District Court held  that  privacy  interests  outweigh  the  presumption  of  public  access  in  each of the thousands of pages at issue, that decision—which appears  to  have  been  made  without  particularized  review—amounts  to  an  abuse of discretion.37  In  light  of  the  District  Court’s  failure  to  conduct  an  individualized review of the sealed materials, it is necessary to do so  now.  We  believe  the  District  Court  is  best  situated  to  conduct  this  review. The District Court can directly communicate with the parties,  and  can  therefore  more  swiftly  and  thoroughly  consider  particular  objections to unsealing specific materials. Relatedly, the District Court  can obtain the parties’ assistance in effecting any necessary redactions,  and in notifying any outside parties whose privacy interests might be   See text accompanying notes 12–18 and 26–28, ante.  36  See In re City of New York, 607 F.3d 923, 943 n.21 (2d Cir. 2010) (explaining  that “abuse of discretion” is a nonpejorative, legal “term of art”).  37 18  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page19 of 25 implicated by the unsealing. Accordingly, we remand the cause to the  District Court to conduct such a particularized review and unseal all  documents for which the presumption of public access outweighs any  countervailing privacy interests.  D. Protecting the Integrity of Judicial Proceedings  While  we  disagree  with  the  District  Court’s  disposition  of  the  motions to unseal, we share its concern that court files might be used  to  “promote  scandal  arising  out  of  unproven  potentially  libelous  statements.”38  We  therefore  describe  certain  methods  courts  can  employ  to  protect  the  judicial  process  from  being  coopted  for  such  purposes.  The  Supreme  Court  has  explained  that  “[e]very  court  has  supervisory power over its own records and files” to ensure they “are  not used to gratify private spite or promote public scandal” or “serve  as  reservoirs  of  libelous  statements  for  press  consumption.”39  This  supervisory  function  is  not  only  within  a  district  court’s  power,  but  also among its responsibilities.   In practice, district courts may employ several methods to fulfill  this  function.  They  may,  for  instance,  issue  protective  orders  forbidding  dissemination  of  certain  material  “to  protect  a  party  or  person  from  annoyance,  embarrassment,  oppression,  or  undue   Giuffre, 325 F. Supp. 3d at 447.  38  Nixon, 435 U.S. at 598 (internal quotation marks).  39 19  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page20 of 25 burden” and require that filings containing such material be submitted  under seal.40 If parties then seek to file such materials, the court may  deny them leave to do so.41 District courts may also seek to counteract  the effect of defamatory statements by explaining on the record that  the  statements  appear  to  lack  credibility.  Moreover,  under  Federal  Rule  of  Civil  Procedure  12(f),  the  district  court  may  strike  such  material  from  the  filings  on  the  grounds  that  it  is  “redundant,  immaterial,  impertinent,  or  scandalous.”42  Because  such  rejected  or  stricken  material  is  not  “relevant  to  the  performance  of  the  judicial  function” it would not be considered a “judicial document” and would  enjoy  no  presumption  of  public  access.43  Finally,  in  appropriate   Fed. R. Civ. P. 26(c); see also TheStreet.Com, 273 F.3d at 229–30.  40  See, e.g., S.D.N.Y. Electronic Case Filing Rules & Instructions, February 1,  2019  Edition,  Rule  6.1,  http://nysd.uscourts.gov/ecf/ECF%20Rules%20020119%20Final.pdf.  41  Fed. R. Civ. P. 12(f). Courts may strike material from the pleadings either  “on  its  own”  or  “on  motion  made  by  a  party.”  Id.  Although  motions  to  strike  material solely “on the ground that the matter is impertinent and immaterial” are  disfavored, when material is also “scandalous,” no such presumption applies. Cf.  Lipsky v. Commonwealth United Corp., 551 F.2d 887, 893 (2d Cir. 1976); see also Talbot  v.  Robert  Matthews  Distrib.  Co.,  961  F.2d  654,  664  (7th  Cir.  1992)  (“Allegations may be stricken as scandalous if the matter bears no possible relation  to the controversy or may cause the objecting party prejudice.”); Wine Markets Intʹl,  Inc. v. Bass, 177 F.R.D. 128, 133 (E.D.N.Y. 1998) (“Motions to strike are not generally  favored,  except  in  relation  to  scandalous  matters.”);  Alvarado‐Morales  v.  Digital  Equip. Corp., 843 F.2d 613, 617–18 (1st Cir. 1988) (categorizing as scandalous “matter  which impugned the character of defendants”).  42  Amodeo I, 44 F.3d at 145.  43 20  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page21 of 25 circumstances, district courts may impose sanctions on attorneys and  parties under Federal Rule of Civil Procedure 11(c).44  E. A Cautionary Note  We conclude with a note of caution to the public regarding the  reliability of court filings such as those unsealed today.  Materials submitted by parties to a court should be understood  for what they are. They do not reflect the court’s own findings. Rather,  they are prepared by parties seeking to advance their own interests in  an  adversarial  process.  Although  affidavits  and  depositions  are  offered  “under  penalty  of  perjury,”  it  is  in  fact  exceedingly  rare  for  anyone to be prosecuted for perjury in a civil proceeding.45 Similarly,   In relevant part, Rule 11 provides:  44 By presenting to the court a pleading, written motion, or other paper . . . an  attorney or unrepresented party certifies that . . . it is not being presented  for any improper purpose, such as to harass, cause unnecessary delay, or  needlessly  increase  the  cost  of  litigation  .  .  .  .  [T]he  court  may  impose  an  appropriate sanction on any attorney, law firm, or party that violated the  rule  or  is  responsible  for  the  violation  .  .  .  .  The  sanction  may  include  nonmonetary directives; an order to pay a penalty into court; or, if imposed  on  motion  and  warranted  for  effective  deterrence,  an  order  directing  payment to the movant of part or all of the reasonable attorney’s fees and  other expenses directly resulting from the violation.  Fed. R. Civ. P. 11. See also Amodeo II, 71 F.3d at 1049 (describing sanctions available  to the court).    Sonia  Sotomayor  &  Nicole  A.  Gordon, Returning  Majesty  to  the  Law  and  Politics: A Modern Approach, 30 Suffolk U. L. Rev. 35, 47 n.52 (1996) (ʺPerjury cases  are not often pursued . . . .”).  45 21  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page22 of 25 pleadings,  complaints,  and  briefs—while  supposedly  based  on  underlying evidentiary material—can be misleading. Such documents  sometimes  draw  dubious  inferences  from  already  questionable  material or present ambiguous material as definitive.  Moreover,  court  filings  are,  in  some  respects,  particularly  susceptible to fraud. For while the threat of defamation actions may  deter malicious falsehoods in standard publications, this threat is non‐ existent with respect to certain court filings. This is so because, under  New York law (which governs the underlying defamation claim here),  “absolute  immunity  from  liability  for  defamation  exists  for  oral  or  written statements made . . . in connection with a proceeding before a  court.”46 Thus, although the act of filing a document with a court might  be  thought  to  lend  that  document  additional  credibility,  in  fact,  allegations appearing in such documents might be less credible than  those published elsewhere.47    Front, Inc. v. Khalil, 24 N.Y.3d 713, 718 (2015); see also Kelly v. Albarino, 485  F.3d 664, 666 (2d Cir. 2007) (adopting the reasoning of the District Court explaining  that this privilege is “the broadest of possible privileges”); Restatement (Second) of  Torts  §  587  (1977)  (“A  party  to  a  private  litigation  or  a  private  prosecutor  or  defendant in a criminal prosecution is absolutely privileged to publish defamatory  matter concerning another in communications preliminary to a proposed judicial  proceeding, or in the institution of or during the course and as a part of, a judicial  proceeding  in  which  he  participates,  if  the  matter  has  some  relation  to  the  proceeding.”). But see note 47, post.  46  While common law courts have generally interpreted the litigation privilege  broadly,  they  nevertheless  maintain  an  important  (if  rarely  implemented)  limitation on its scope: to qualify for the privilege, a statement must be “material  and pertinent to the questions involved.” Front, 24 N.Y.3d at 718 (quoting Youmans  47 22  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page23 of 25 We have long noted that the press plays a vital role in ensuring  the public right of access and in enhancing “the quality and safeguards  the integrity of the factfinding process.”48 When faithfully observing  its best traditions, the print and electronic media “contributes to public  understanding  of  the  rule  of  law”  and  “validates  [its]  claim  of  functioning as surrogates for the public.”49  At  the  same  time,  the  media  does  the  public  a  profound  disservice when it reports on parties’ allegations uncritically. We have  previously  observed  that  courts  cannot  possibly  “discredit  every  statement or document turned up in the course of litigation,” and we  have criticized “the use by the media of the somewhat misleading term  ‘court  records’  in  referring  to  such  items.”50  Even  ordinarily  critical  v.  Smith,  153  N.Y.  214,  219–20  (1897)).  It  follows,  then,  that  immaterial  and  impertinent statements are (at least nominally) actionable, particularly when they  are “so needlessly defamatory as to warrant the inference of express malice.” Id.  (same). It seems to us that when a district court strikes statements from the record  pursuant to Fed. R. Civ. P. 12(f) on the ground that the matter is “impertinent” and  “immaterial,”  it  makes  the  very  same  determination  that  permits  a  defamation  action under the common law. We think the judicial system would be well served  were our common law courts to revitalize this crucial qualification to the litigation  privilege.    Westmoreland  v.  Columbia  Broad.  Sys.,  Inc.,  752  F.2d 16, 23 (2d  Cir.  1984)  (quoting  Globe  Newspaper  Co.  v.  Superior  Court  for  Norfolk  Cty.,  457  U.S.  596,  606  (1982)).  48  Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 572–73 (1980) (plurality  opinion) (internal quotation marks omitted).  49  Amodeo II, 71 F.3d at 1049.  50 23  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page24 of 25 readers  may  take  the  reference  to  “court  papers”  as  some  sort  of  marker of reliability.  This would be a mistake.  We  therefore  urge  the  media  to  exercise  restraint  in  covering  potentially defamatory allegations, and we caution the public to read  such accounts with discernment.  III. CONCLUSION    To summarize, we hold as follows:  (1) Materials  submitted  in  connection  with  a  motion  for  summary  judgment  are  subject  to  a  strong  presumption  of  public access.  (2)  The  summary  judgment  record  at  issue  will  be  unsealed  upon  issuance  of  our  mandate,  subject  to  minimal  redactions.51  (3) Materials  submitted  in  connection  with,  and  relevant  to,  discovery  motions,  motions  in  limine,  and  other  non‐ dispositive  motions  are  subject  to  a  lesser—but  still  substantial— presumption of public access.  (4) The District Court is directed to review the remaining sealed  materials  individually  and  unseal  those  materials  as  appropriate.   See note 22, ante.  51 24  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page25 of 25 (5) District  courts  should  exercise  the  full  range  of  their  substantial  powers  to  ensure  their  files  do  not  become  vehicles for defamation.  For  the  foregoing  reasons,  we  VACATE  the  orders  of  the  District Court entered on November 2, 2016, May 3, 2017, and August  27, 2018, ORDER the unsealing of the summary judgment record as  described  herein,  and  REMAND  the  cause  to  the  District  Court  for  particularized review of the remaining materials.   In undertaking this task, the District Court may be well‐served  by ordering the parties to submit to the Court unredacted, electronic  copies of the remaining sealed materials, as well as specific, proposed  redactions.  The  District  Court  may  also  order  the  parties  to  identify  and notify additional parties whose privacy interests would likely be  implicated by disclosure of these materials.  In  the  interests  of  judicial  economy,  any  future  appeal  in  this  matter shall be referred to this panel.  25  Case 18-2868, Document 273-3, 08/09/2019, 2628218, Page1 of 1 POOLER, Circuit Judge, dissenting in part:    I join the Court’s opinion in every respect but one: the decision to unseal  the summary judgment record ourselves. I agree that all or most of the material  must be unsealed. Nevertheless, in my view, the district court is better suited to  the task. As the Court’s opinion recognizes in connection with the remaining  sealed materials, the district court is better positioned to communicate with the  parties and any nonparties whose privacy interests might be affected by  unsealing. On that score, it is worth clarifying here the breadth of the Court’s  unsealing order: it unseals nearly 2000 pages of material. The task of identifying  and making specific redactions in such a substantial volume is perilous; the  consequences of even a seemingly minor error may be grave and are irrevocable.  Moreover, although I share the majority’s concern about avoiding delay, I would  alleviate that concern through other means—perhaps with an order directing the  district court to act expeditiously and by making clear what types of limited  redactions are and are not appropriate. In sum, I would unseal the district court’s  summary judgment decision only and leave the remainder of the materials for  the district court to review, redact, and unseal on remand.   Case 18-2868, Document 275, 08/09/2019, 2628223, Page1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X Plaintiff, v. GHISLAINE MAXWELL, Defendant. ............................................. .. VIRGINIA L. GIUFFRE, 15-cv-07433-RWS --------------------------------------------------X DEFENDANT’S STATEMENT OF MATERIAL UNDISPUTED FACTS PURSUANT TO LOCAL CIVIL RULE 56.1 Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 303.831.7364 Case 18-2868, Document 275, 08/09/2019, 2628223, Page2 of 18 Pursuant to Rule 56.1 of the Local Civil Rules of this Court, defendant Ghislaine Maxwell submits this statement of the material facts as to which she contends there is no genuine issues to be tried. Ms. Maxwell expressly preserves all of her objections to the admissibility of the evidence cited herein and in the accompanying memoranda of law and does not waive any objections by making this submission. numbered. 1. Ms. Maxwell’s response to publications of plaintiff’s false allegations: the March 2011 statement. In early 2011 plaintiff in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. In the articles, plaintiff made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, plaintiff suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. 2. In the articles, plaintiff alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” 3. In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.” 4. The statement read in full: Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 2011 London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. 1 Case 18-2868, Document 275, 08/09/2019, 2628223, Page3 of 18 It is unacceptable that letters sent by Ms Maxwell’s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers. “I understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop,” said Ghislaine Maxwell. “A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-251 Email: ross@acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: +44-203008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com 5. Plaintiff’s gratuitous and “lurid” accusations in an unrelated action. In 2008 two alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against the United States government purporting to challenge Epstein’s plea agreement. They alleged the government violated their CVRA rights by entering into the agreement. 6. Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action, claiming she, too, had her CVRA rights violated by the government. On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. 7. The issue presented in her joinder motion was narrow: whether she should be permitted to join the CVRA action as a party under Federal Rule of Civil Procedure 21, specifically, whether she was a “known victim[] of Mr. Epstein and the Government owed them CVRA duties.” Yet, “the bulk of the [motion] consists of copious factual details that [plaintiff] and [her co-movant] ‘would prove . . . if allowed to join.’” Ms. Giuffre gratuitously included 2 Case 18-2868, Document 275, 08/09/2019, 2628223, Page4 of 18 provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual trafficking. 8. At the time they filed the motion, Ms. Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA action. While they deliberately filed the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. 9. As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several individuals, and she offers details about the type of sex acts performed and where they took place.” The court ruled that “these lurid details are unnecessary”: “The factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent . . ., especially considering that these details involve non-parties who are not related to the respondent Government.” Accordingly, “[t]hese unnecessary details shall be stricken.” Id. The court then struck all Ms. Giuffre’s factual allegations relating to her alleged sexual activities and her allegations of misconduct by non-parties. The court said the striking of the “lurid details” was a sanction for Ms. Giuffre’s improper inclusion of them in the motion. 10. The district court found not only that the “lurid details” were unnecessary but also that the entire joinder motion was “entirely unnecessary.” Ms. Giuffre and her lawyers knew the motion with all its “lurid details” was unnecessary because the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. The court denied plaintiff’s joinder motion. 11. One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion, 3 Case 18-2868, Document 275, 08/09/2019, 2628223, Page5 of 18 Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein:  Ms. Maxwell “approached” plaintiff in 1999 when plaintiff was “fifteen years old” to recruit her into the scheme.  Ms. Maxwell was “one of the main women” Epstein used to “procure underaged girls for sexual activities.”  Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme.  She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.”  At the mansion, when plaintiff began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.”  Epstein “with the assistance of” Ms. Maxwell “converted [plaintiff] into . . . a ‘sex slave.’” Id. Plaintiff was a “sex slave” from “about 1999 through 2002.”  Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.”  Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.”  Ms. Maxwell “participat[ed] in the sexual abuse of [plaintiff] and others.”  Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [plaintiff].” Id. She shared the photos with Epstein.  As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect[ed]” Epstein with “powerful individuals” so that Epstein could traffick plaintiff to these persons.  Plaintiff was “forced to have sexual relations” with Prince Andrew in “[Ms. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” plaintiff’s sex with Prince Andrew “by acting as a ‘madame’ for Epstein.”  Ms. Maxwell “assist[ed] in internationally trafficking” plaintiff and “numerous other young girls for sexual purposes.”  Plaintiff was “forced” to watch Epstein, Ms. Maxwell and others “engage in illegal sexual acts with dozens of underage girls.” 4 Case 18-2868, Document 275, 08/09/2019, 2628223, Page6 of 18 12. In the joinder motion, plaintiff also alleged she was “forced” to have sex with Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and “many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.” 13. Plaintiff said after serving for four years as a “sex slave,” she “managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.” 14. Plaintiff suggested the government was part of Epstein’s “conspiracy” when it “secretly” negotiated a non-prosecution agreement with Eptstein precluding federal prosecution of Epstein and his “co-conspirators.” The government’s secrecy, plaintiff alleged, was motivated by its fear that plaintiff would raise “powerful objections” to the agreement that would have “shed tremendous public light on Epstein and other powerful individuals. 15. Notably, the other “Jane Doe” who joined plaintiff’s motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of plaintiff’s allegations. 16. Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, plaintiff told Ms. Churcher of virtually none of the details she described in the joinder motion. 17. Ms. Maxwell’s response to plaintiff’s “lurid” accusations: the January 2015 statement. As plaintiff and her lawyers expected, before District Judge Marra in the CVRA action could strike the “lurid details” of plaintiff’s allegations in the joinder motion, members of the media obtained copies of the motion. 18. At Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing “a quotable statement on 5 Case 18-2868, Document 275, 08/09/2019, 2628223, Page7 of 18 behalf of Ms Maxwell.” The email was sent to more than 6 and probably less than 30 media representatives. It was not sent to non-media representatives. 19. Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. These representatives were selected based on their request—after the joinder motion was filed—for a response from Ms. Maxwell to plaintiff’s allegations in the motion. 20. The email to the media members read: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. 21. Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional press release solely to disseminate information to the media. So he intentionally did not pass it through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation. 6 Case 18-2868, Document 275, 08/09/2019, 2628223, Page8 of 18 22. The January 2015 statement served two purposes. First, Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff’s false allegations. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject plaintiff’s allegations to inquiry and scrutiny. For example, he noted in the statement that plaintiff’s allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” 23. Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish plaintiff’s allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that plaintiff’s allegations were “defamatory.” In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff’s obviously false allegations and the legal indefensibility of their own conduct. 24. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (emphasis supplied). The statement was intended to be a single, one-time-only, comprehensive response—quoted in full—to plaintiff’s December 30, 2014, allegations that would give the media Ms. Maxwell’s response. The purpose of the prefatory statement was to inform the mediarecipients of this intent. 25. Plaintiff’s activities to bring light to the rights of victims of sexual abuse. Plaintiff has engaged in numerous activities to bring attention to herself, to the prosecution and punishment of wealthy individuals such as Epstein, and to her claimed interest of bringing light to the rights of victims of sexual abuse. 7 Case 18-2868, Document 275, 08/09/2019, 2628223, Page9 of 18 26. Plaintiff created an organization, Victims Refuse Silence, Inc., a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. 27. The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse.” Toward this end, plaintiff has “dedicated her professional life to helping victims of sex trafficking.” 28. Plaintiff repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. 29. On December 30, 2014, plaintiff publicly filed an “entirely unnecessary” joinder motion laden with “unnecessary,” “lurid details” about being “sexually abused” as a “minor victim[]” by wealthy and famous men and being “trafficked” all around the world as a “sex slave.” 30. The plaintiff’s alleged purpose in filing the joinder motion was to “vindicate” her rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution agreement” with Epstein, “shed tremendous public light” on Epstein and “other powerful individuals” that would undermine the agreement, and support the CVRA plaintiffs’ request for documents that would show how Epstein “used his powerful political and social connections to secure a favorable plea deal” and the government’s “motive” to aid Epstein and his “coconspirators.” 31. Plaintiff has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s alleged “sex scheme.” 8 Case 18-2868, Document 275, 08/09/2019, 2628223, Page10 of 18 32. Republication alleged by plaintiff. Plaintiff was required by Interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were “‘published globally, including within the Southern District of New York,’” as plaintiff alleged in Paragraph 9 of Count I of her complaint. In response, plaintiff identified the January 2015 statement and nine instances in which various news media published portions of the January 2015 statement in news articles or broadcast stories. 33. In none of the nine instances was there any publication of the entire January 2015 statement. 34. Ms. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in plaintiff’s response to Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015 statement. 35. Plaintiff’s defamation action against Ms. Maxwell. Eight years after Epstein’s guilty plea, plaintiff brought this action, repeating many of the allegations she made in her CVRA joinder motion. 36. The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (b) That the allegations have been “shown to be untrue.” (c) That Giuffre’s “claims are obvious lies.” 37. Plaintiff lived independently from her parents with her fiancé long before meeting Epstein or Ms. Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999, plaintiff moved in with the family of a fellow patient. There she met, and became engaged to, her friend’s brother, James Michael Austrich. She and Austrich thereafter 9 Case 18-2868, Document 275, 08/09/2019, 2628223, Page11 of 18 rented an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs in that area. Later, they stayed briefly with plaintiff’s parents in the Palm Beach/ Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. Although plaintiff agreed to marry Austrich, she never had any intention of doing so. 38. Plaintiff re-enrolled in high school from June 21, 2000 until March 7, 2002. After finishing the 9th grade school year at Forest Hills High School on June 9, 1999, plaintiff reenrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on August 14, 2001. On September 20, 2001, Plaintiff then enrolled at Royal Palm Beach High School. A few weeks later, on October 12, 2001, she matriculated at Survivors Charter School. Id. Survivor’s Charter School was an alternative school designed to assist students who had been unsuccessful at more traditional schools. Plaintiff remained enrolled at Survivor’s Charter School until March 7, 2002. She was present 56 days and absent 13 days during her time there. Id. Plaintiff never received her high school diploma or GED. Plaintiff and Figueroa went “back to school” together at Survivor’s Charter School. The school day there lasted from morning until early afternoon. 39. During the year 2000, plaintiff worked at numerous jobs. In 2000, while living with her fiancé, plaintiff held five different jobs: at Aviculture Breeding and Research Center, Southeast Employee Management Company, The Club at Mar-a-Lago, Oasis Outsourcing, and Neiman Marcus. Her taxable earnings that year totaled nearly $9,000. Plaintiff cannot now recall either the Southeast Employee Management Company or the Oasis Outsourcing jobs. 40. Plaintiff’s employment at the Mar-a-Lago spa began in fall 2000. Plaintiff’s father, Sky Roberts, was hired as a maintenance worker at the The Mar-a-Lago Club in Palm 10 Case 18-2868, Document 275, 08/09/2019, 2628223, Page12 of 18 Beach, Florida, beginning on April 11, 2000. Mr. Roberts worked there year-round for approximately 3 years. After working there for a period of time, Mr. Roberts became acquainted with the head of the spa area and recommended plaintiff for a job there. Mar-a-Lago closes every Mother’s Day and reopens on November 1. Most of employees Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club is open, i.e., between November 1 and Mother’s Day. Plaintiff was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17. 41. Plaintiff represented herself as a masseuse for Jeffrey Epstein. While working at the Mar-a-Lago spa and reading a library book about massage, plaintiff met Ms. Maxwell. Plaintiff thereafter told her father that she got a job working for Jeffrey Epstein as a masseuse. Plaintiff’s father took her to Epstein’s house on one occasion around that time, and Epstein came outside and introduced himself to Mr. Roberts. Plaintiff commenced employment as a traveling masseuse for Mr. Epstein. Plaintiff was excited about her job as a masseuse, about traveling with him and about meeting famous people. Plaintiff represented that she was employed as a masseuse beginning in January 2001. Plaintiff never mentioned Ms. Maxwell to her then-fiancé, Austrich. Plaintiff’s father never met Ms. Maxwell. 42. Plaintiff resumed her relationship with convicted felon Anthony Figueroa. In spring 2001, while living with Austich, plaintiff lied to and cheated on him with her high school boyfriend, Anthony Figueroa. Plaintiff and Austrich thereafter broke up, and Figueroa moved into the Bent Oak apartment with plaintiff. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa in Plaintiff’s presence punched Austrich in the face. Figueroa and plaintiff fled the scene before police arrived. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance. 11 Case 18-2868, Document 275, 08/09/2019, 2628223, Page13 of 18 43. Plaintiff freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at age 17, while living in the same apartment, plaintiff and Figueroa hosted a party with a number of guests. During the party, according to plaintiff, someone entered plaintiff’s room and stole $500 from her shirt pocket. Plaintiff contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a “sex slave.” A second time, in June 2002, plaintiff contacted the police to report that her former landlord had left her belongings by the roadside and had lit her mattress on fire. Again, plaintiff met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a “sex slave.” 44. From August 2001 until September 2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel unaccompanied by Plaintiff. Flight logs maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips away from Florida that Epstein and Maxwell took, unaccompanied by Plaintiff, between August 2001 and September 2002. Rodgers maintained a log of all flights on which Epstein and Maxwell traveled with him. Epstein additionally traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial flights. For substantially all of thirteen months of the twenty-two months (from November 2000 until September 2002) that Plaintiff lived in Palm Beach and knew Epstein, Epstein was traveling outside of Florida unaccompanied by Plaintiff. During this same period of time, Plaintiff was employed at various jobs, enrolled in school, and living with her boyfriend. 45. Plaintiff and Figueroa shared a vehicle during 2001 and 2002. Plaintiff and Figueroa shared a ’93 white Pontiac in 2001 and 2002. Plaintiff freely traveled around the Palm 12 Case 18-2868, Document 275, 08/09/2019, 2628223, Page14 of 18 Beach area in that vehicle. In August 2002, Plaintiff acquired a Dodge Dakota pickup truck from her father. Figueroa used that vehicle in a series of crimes before and after Plaintiff left for Thailand. 46. Plaintiff held a number of jobs in 2001 and 2002. During 2001 and 2002, plaintiff was gainfully employed at several jobs. She worked as a waitress at Mannino’s Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at Roadhouse Grill. She also was employed at Courtyard Animal Hospital (aka Marc Pinkwasser DVM). 47. In September 2002, Plaintiff traveled to Thailand to receive massage training and while there, met her future husband and eloped with him. Plaintiff traveled to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove her to the airport. While there, she initially contacted Figueroa frequently, incurring a phone bill of $4,000. She met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until two days before Mr. Figueroa’s deposition in this matter in May 2016. 48. Detective Recarey’s investigation of Epstein failed to uncover any evidence that Ms. Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. Joseph Recarey served as the lead detective from the Palm Beach Police Department charged with investigating Jeffrey Epstein. That investigation commenced in 2005. Recarey worked only on the Epstein case for an entire year. He reviewed previous officers’ reports and interviews, conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance footage of the Epstein home, participated in and had knowledge of the search warrant executed on the Epstein home, and testified regarding the case before the Florida state grand jury against Epstein. Detective Recarey’s investigation 13 Case 18-2868, Document 275, 08/09/2019, 2628223, Page15 of 18 revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect by the government. None of Epstein’s alleged victims said they had seen Ms. Maxwell at Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her, nor told what to wear or how to act by her. Indeed, none of Epstein’s alleged victims ever reported to the government they had met or spoken to Ms. Maxwell. Maxwell was not seen coming or going from the house during the law enforcement surveillance of Epstein’s home. The arrest warrant did not mention Ms. Maxwell and her name was never mentioned before the grand jury. No property belonging to Maxwell, including “sex toys” or “child pornography,” was seized from Epstein’s home during execution of the search warrant. Detective Recarey, when asked to describe “everything that you believe you know about Ghislaine Maxwell’s sexual trafficking conduct,” replied, “I don’t.” He confirmed he has no knowledge about Ms. Maxwell sexually trafficking anybody. Detective Recarey also has no knowledge of Plaintiff’s conduct that is subject of this lawsuit. 49. No nude photograph of Plaintiff was displayed in Epstein’s home. Epstein’s housekeeper, Juan Alessi, “never saw any photographs of Virginia Roberts in Mr. Epstein’s house.” Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. 50. Plaintiff intentionally destroyed her “journal” and “dream journal” regarding her “memories” of this case in 2013 while represented by counsel. Plaintiff drafted a “journal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents in her 14 Case 18-2868, Document 275, 08/09/2019, 2628223, Page16 of 18 possession. Id. Plaintiff also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. To date, Plaintiff cannot locate the “dream journal.” 51. Plaintiff publicly peddled her story beginning in 2011. Plaintiff granted journalist Sharon Churcher extensive interviews that resulted in seven (7) widely distributed articles from March 2011 through January 2015. Churcher regularly communicated with plaintiff and her “attorneys or other agents” from “early 2011” to “the present day.” Plaintiff received approximately $160,000 for her stories and pictures that were published by many news organizations. 52. Plaintiff drafted a 144-page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, plaintiff drafted a book manuscript which purported to document plaintiff’s experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. Plaintiff communicated with literary agents, ghost writers and potential independent publishers in an effort to get her book published. She generated marketing materials and circulated those along with book chapters to numerous individuals associated with publishing and the media. 53. Plaintiff’s publicly filed “lurid” CVRA pleadings initiated a media frenzy and generated highly publicized litigation between her lawyers and Alan Dershowitz. On December 30, 2014, plaintiff, through counsel, publicly filed a joinder motion that contained her “lurid allegations” about Ms. Maxwell and many others, including Alan Dershowitz, Prince Andrew, Jean-Luc Brunel. The joinder motion was followed by a “corrected” motion and two further declarations in January and February 2015, which repeated many of plaintiff’s claims. These CVRA pleadings generated a media maelstrom and spawned highly publicized litigation between plaintiff’s lawyers, Edwards and Cassell, and Alan Dershowitz. After plaintiff publicly 15 Case 18-2868, Document 275, 08/09/2019, 2628223, Page17 of 18 alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called plaintiff a liar and accused her lawyers of unethical conduct. In response, attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. 54. Plaintiff formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, plaintiff, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to plaintiff, the purpose of the organization is to promote plaintiff’s professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Plaintiff attempts to promote Victims Refuse Silence at every opportunity. For example, plaintiff participated in an interview in New York with ABC to promote the charity and to get her mission out to the public. Dated: January 6, 2017 Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 lmenninger@hmflaw.com Attorneys for Ghislaine Maxwell 16 Case 18-2868, Document 275, 08/09/2019, 2628223, Page18 of 18 CERTIFICATE OF SERVICE I certify that on January 6, 2017, I electronically served this Defendant’s Statement of Material Undisputed Facts Pursuant to Local Civil Rule 56.1 via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. 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IROORZLQJ 6LJULG 6 0F&DZOH\ 0HUHGLWK 6FKXOW] %2,(6 6&+,//(5 )/(;1(5 //3 (DVW /DV 2ODV %RXOHYDUG 6WH )W /DXGHUGDOH )/ VPFFDZOH\#EVIOOS FRP PVFKXOW]#EVIOOS FRP %UDGOH\ - (GZDUGV )DUPHU -DIIH :HLVVLQJ (GZDUGV )LVWRV /HKUPDQ 3 / 1RUWK $QGUHZV $YH 6WH )W /DXGHUGDOH )/ EUDG#SDWKWRMXVWLFH FRP 3DXO * &DVVHOO 6 8QLYHUVLW\ 6WUHHW 6DOW /DNH &LW\ 87 FDVVHOOS#ODZ XWDK HGX - 6WDQOH\ 3RWWLQJHU 7ZLQ /DNHV 5G 6RXWK 6DOHP 1< 6WDQ3RWWLQJHU#DRO FRP V 1LFROH 6LPPRQV 1LFROH 6LPPRQV Case 18-2868, Document 277, 08/09/2019, 2628225, Page1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------------------------X v. Plaintiff, GHISLAINE MAXWELL, Defendant. ........................................... ..... VIRGINIA L. GIUFFRE, 15-cv-07433-RWS --------------------------------------------------X Declaration of Laura A. Menninger in Support of Defendant’s Motion For Summary Judgment I, Laura A. Menninger, declare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell’s Motion for Summary Judgment.1 2. Attached as Exhibit A is a true and correct copy of an article by Sharon Churcher entitled “Prince Andrew and the 17-year-old girl his sex offender flew to Britain to meet him,” DAILY MAIL, dated March 2, 2011. 1 At trial, defendant intends to produce either the custodian of record relevant to any disputed document or a certification in compliance with either Fed. R. Evid. P. 803 and/or 902. See Fed. R. Civ. P. 56(c). Apart from deposition testimony, the majority of non-deposition documents herein were either produced by plaintiff or obtained with releases signed by plaintiff. Case 18-2868, Document 277, 08/09/2019, 2628225, Page2 of 7 3. Attached as Exhibit B is a true and correct copy of an article by Sharon Churcher entitled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill Clinton,” DAILY MAIL, dated March 5, 2011. 4. Attached as Exhibit C is a true and correct copy of a statement on behalf of Ms. Maxwell dated March 9, 2011. 5. Attached as Exhibit D (filed under seal) is a true and correct copy of the corrected Motion for Joinder, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Jan. 2, 2015). 6. Attached as Exhibit E is a true and correct copy of an Order Denying Motion to Join Under Rule 21, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Apr. 7, 2016). 7. Attached as Exhibit F is a true and correct copy of a statement on behalf of Ms. Maxwell dated January 2, 2015. 8. Attached as Exhibit G (filed under seal) are true and correct copies of excerpts from the November 18, 2016 deposition of Ross Gow, designated Confidential under the Protective Order. 9. Attached as Exhibit H (filed under seal) is a true and correct copy of Plaintiff’s Response to Second Request for Production and to Interrogatories and Requests for Admissions, dated July 1, 2016. 10. Attached as Exhibit I (filed under seal) is a true and correct copy of Plaintiff’s Supplemental Responses to to Interrogatory Nos. 6, 12 and 13, dated August 17, 2016, designated Confidential under the Protective Order. 2 Case 18-2868, Document 277, 08/09/2019, 2628225, Page3 of 7 11. Attached as Exhibit J (filed under seal) is a true and correct copy of the Declaration of Ghislaine Maxwell, dated January 6, 2017. 12. Attached as Exhibit K (filed under seal) is a true and correct copy of the Declaration of Philip Barden, dated January 6, 2017. 13. Attached as Exhibit L (filed under seal) are true and correct copies of excerpts from the June 23, 2016 deposition of James Austrich, designated Confidential under the Protective Order. 14. Attached as Exhibit M (filed under seal) is a true and correct copy of Plaintiff’s passport application, dated January 12, 2001, designated Confidential under the Protective Order. 15. Attached as Exhibit N (filed under seal) are true and correct copies of excerpts from the May 3, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective Order. 16. Attached as Exhibit O (filed under seal) are true and correct copies of Plaintiff’s school records Bates stamped GM_00888 and GIUFFREE004981-88 and designated Confidential under the Protective Order. 17. Attached as Exhibit P (filed under seal) are true and correct copies of excerpts from the June 24, 2016 deposition of Tony Figueroa, designated Confidential under the Protective Order. 18. Attached as Exhibit Q (filed under seal) are true and correct copies of excerpts from the November 14, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective Order. 3 Case 18-2868, Document 277, 08/09/2019, 2628225, Page4 of 7 19. Attached as Exhibit R (filed under seal) is a true and correct copy of Plaintiff’s Social Security records dated October 25, 2016, Bates stamped GIUFFRE009175, designated Confidential under the Protective Order. 20. Attached as Exhibit S (filed under seal) is a true and correct copy of Mar-A-Lago records, Bates stamped MAR-A-LAGO-0001 and MAR-A-LAGO-0161-0177. 21. Attached as Exhibit T (filed under seal) is a true and correct copies of excerpts from the May 20, 2016 deposition of Sky Roberts, designated Confidential under the Protective Order. 22. Attached as Exhibit U (filed under seal) ) is a true and correct copy of the Mar-ALago employee handbook, dated October 28, 1995, Bates stamped MAR-A-LAGO-0178-0243. 23. Attached as Exhibit V (filed under seal) is a true and correct copy of the Mar-A-Lago advertisement, Bates stamped MAR-A-LAGO-0086. 24. Attached as Exhibit W (filed under seal) is a true and correct copy of Plaintiff’s Courtyard Animal Hospital employment application, Bates stamped GIUFFRE009201-11, designated Confidential under the Protective Order. 25. Attached as Exhibit X(filed under seal) is a true and correct copy of the Royal Palm Beach Police Department Offense Report date, June 10, 2001, Bates stamped GM_00780-82. 26. Attached as Exhibit Y (filed under seal) is a true and correct copy of the Royal Palm Beach Police Department Probable Cause Affidavit date, November 19, 1999, Bates stamped GM_01223-28. 27. Attached as Exhibit Z (filed under seal) is a true and correct copy of the Royal Palm Beach Police Department Offense Report date, August 3, 2001, Bates stamped GM_00777-79. 4 Case 18-2868, Document 277, 08/09/2019, 2628225, Page5 of 7 28. Attached as Exhibit AA (filed under seal) is a true and correct copy of the Palm Beach County Sheriff’s Offense Report date, June 02, 2002, Bates stamped GM_00748-79. 29. Attached as Exhibit BB (filed under seal) are true and correct copies of David Rodgers flight logs from November 1995 to May 2013, Bates stamped DR__0001-DR0107. 30. Attached as Exhibit CC (filed under seal) is a true and correct copy of excerpts from the June 3, 2016 deposition of David Rodgers, designated Confidential under the Protective Order. 31. Exhibit DD left intentionally blank. 32. Attached as Exhibit EE (filed under seal) is a true and correct copy of the Royal Palm Beach Police Citation Tracking Report date, June 19, 2002, Bates stamped GM_00776. 33. Attached as Exhibit FF (filed under seal) is a true and correct copy of the Palm Beach County Sheriff’s Offense Report, Bates stamped GM_01202-28. 34. Attached as Exhibit GG (filed under seal) is a true and correct copies of excerpts from the June 21, 2016 deposition of Joseph Recarey, designated Confidential under the Protective Order. 35. Attached as Exhibit HH (filed under seal) is a true and correct copy of the Affidavit of Juan P. Alessi, dated January 13, 2016, Bates stamped GM_01197-1201. 36. Attached as Exhibit II (filed under seal) is a true and correct copy of excerpts from the Deposition of Virginia Giuffre taken in Cassell v. Dershowitz, on January 16, 2016, and designated as Confidential under the Protective Order. 5 Case 18-2868, Document 277, 08/09/2019, 2628225, Page6 of 7 37. Attached as Exhibit JJ (filed under seal) is a true and correct copy of Errata Sheet from the January 16, 2016 deposition of Virginia Giuffre taken in Cassell v. Dershowitz, dated February 11, 2016 and designated by Plaintiff as Confidential under the Protective Order. 38. Attached as Exhibit KK (filed under seal) is a true and correct copy of The Billionaire Playboys Club book manuscript, designated by Plaintiff as Confidential under the Protective Order. 39. Attached as Exhibit LL is a true and correct copy of the Victims Refuse Silence, Inc. Articles of Incorporation dated December 23, 2014, GIUFFRE001064-65. 40. Attached as Exhibit MM (filed under seal) is a true and correct copy of excerpts from the September 8, 2016 deposition of Brittany Henderson, designated Confidential under the Protective Order. I declare under penalty of perjury that the foregoing is true and correct. Executed on January 6, 2017. s/ Laura A. Menninger Laura A. Menninger 6 Case 18-2868, Document 277, 08/09/2019, 2628225, Page7 of 7 CERTIFICATE OF SERVICE I certify that on January 6, 2017, I electronically served this Declaration of Laura A. Menninger in Support of Defendant’s Motion for Summary Judgment via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@aol.com /s/ Nicole Simmons Nicole Simmons 7 Case 18-2868, Document 278, 08/09/2019, 2628230, Pagel 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: Mates: rtts?tiittr?ie Prince Andrew and the 17-year-old girl his 1 sex offender friend flew to Britain to meet him By SHARON CHURCHER UPDATED: 08:02 EST, 2 March 2011 101 View comments . Virginia Roberts reveats she is ?Jane Doe 102' in Jeffrey Epstein case . Mother-of-three spent four years as miltionaire?s personal masseuse . She describes being flown across wortd to meet Prince Andrew . Epstein trained her 'as a prostitute for him and his friends' As the UK's special representative for intemationai trade, the Duke of York holds an important position, requiring sound judgement and widespread respect. But those qualities have been thrown into question since photographs of Prince Andrew with his billionaire ?nancier friend Jeffrey Epstein, a convicted child-sex offender who was jailed for 18 months for soliciting underage prostitutes, appeared last weekend. Today, however, even more serious doubts are cast on his suitability after a woman at the centre of the Epstein case revealed to The Matt on Sunday that she had, as a 17-year-old employed by Epstein, been flown across the world to be introduced to the Prince. 11?34 Case 18-2868, Document 278, 08/09/2019, 2628230, Page3 of 648 Case. t?flE?W??Wai'P?ag'?ii?naf 9 Lindsay Lohan flashes her cleavage in a low? cut lilac number as she enjoys romantic day in Zurich with fiance Egor Tarabasov Loveiy in lilac Back in time to celebrate! Kim Kardashian and Kanye West arrive in LA on eve of daughter North's third 5 birthday Whirlwind 24-hour trip Bathing suit babes! Piayboy vet Kendra Wilkinson shows off chest in one piece white celebrating alst birthday with 'number one ho' in Arizona Sean Penn's son Hopper, 22, reveats his famous father wanted to name him ?Steak' due to his love of red meat His mom Robin Wright woutdn't have gone for it New romance for Ruby? Rose 'dating? businesswoman Harley Gusman after the pair were spotted cozying up on a date in Hollywood Offthe market? Was Patrick Swayze a victim of domestic abuse? Wife denies claims she beatth- Dirty Dancing star throughout their 34?year marriage - and ev on when he was dying Advertisement First meeting: Prince around 17-year-old Virginia, centre On one of those occasions Virginia Roberts was subsequentiy paid $15,000 Her shocking account of her four years as Epstein's personal masseuse is supported by court documents, an eyewitness, photographs and ?ight details of Epstein?s private jets. One picture, said to have been taken by Epstein during Andrew?s ?rst encounter with the girl in March 2001 and published today by The Malt on Sunday, shows the Prince with his arm around her waist. This is not the ?rst time the Duke of York?s judgment and choice of associates have been questioned. He appears to relish the company of super-rich oil billionaires from the Middle East, North Africa and the former Soviet Union. The peculiar sale of his former marital home to a Kazakh businessman for ?15 miliion after it had languished unsold for ?ve years at ?12 million has never been satisfactorin explained. in the recent leak of American diplomatic cables it was revealed that he had criticised an of?ciai corruption investigation into the huge Al-Yamamah arms deal between Britain and Saudi Arabia, while he is aiso said to be close to Self Al-isiam Gadda?, son of the beteaguered Libyan president, and may have had a role in the early release of Lockerbie bomber Abdelbaset Ai Megrahi. But it is And rew?s friendship with Epstein, whom he has known since at least 2000, and with Wh I '9 on th Streets a I Epstein?s con?dante Ghislaine Maxwell, daughter Slept With en fo of the tate disgraced newspaper baron Robert Maxweil, that gives most concernwas ?rst seen with the pair on holiday in . Thaiiand, and was pictured cavorting with p39d0 I I ream Ghisfaine at a Haltoween fetishthemed party in Case 18-2868, Document 278, 08/09/2019, 2628230, Page4 of 648 61140016 Case In .- Manhattan. The photograph that appeared iast weekend shows the prince stroiling through Centrai Park with 58-year-old Epstein. Andrew was said to have spent four days at his New York mansion in December, when he was joined by other distinguished guests, including Woody Allen, at a dinner. it is by no means the ?rst New York soiree Andrew has attended as Epstein?s guest. A pro?le of the ?nancier in Vanity Fair magazine some years ago reported that Andrew was a guest at a cocktail party thrown by Epstein and Maxwetl packed with young Russian modeis. '80 me guests were horri?ed,? said the article's author, Vicky Ward. it should not be forgotten that Epstein is a registered sex offender after recently completing his sentence for offences reiating to child prostitution. However, he avoided triai on more serious charges that carried a potential life sentence. And no one reading The Mail on Sunday?s intenriew with the woman who was prepared to testify against him can be in any doubt of the seriousness of the charges. Epstein, a Wall Street money manager who once counted Bill Clinton and Donald Trump among his friends, became the subject of an undercover investigation in 2005 after the stepmother of a 14-year oid girl claimed she was paid $200 (?125) to give him an 'erotic massage?. The subsequent FBI probe uncovered at feast 20 girls levelling sexual allegations against him. Eventually, Epstein struck a ?plea bargain? with prosecutors a practice not permitted under British law? under which he was allowed to plead guilty to two relatively minor charges. Police claim that his donations to politicians and his ?dream team? of in?uential lawyers deterred prosecutors from bringing more serious charges of The deal certainly kept the names of a lot of Epstein?s famous friends out of an embarrassing court case. However, an unusual part of the agreement was that Epstein's alleged victims were allowed to bring civil proceedings against him. He has so far made 17 out-of?court settlements, and some cases are ongoing. One of these girls was to have been a key witness for the prosecution had the case gone to triai. She was just 15 years old when she was drawn into Epstein?s expioitative world in 1998. In her civil writ against him, under the pseudonym Jane Doe 102' she alleged that her duties included being ?sexually exploited by Epstein's adult male peers including royalty?. Now, horrified by the evidence of Epstein and Andrew enjoying each other?s company in New York, Jane Doe 102 has agreed to waive her anonymity and tell for the ?rst time her deeply disturbing story. Her real name is Virginia Roberts and she now iives in Australia, where she is a happily married mother of three. Over the course of a week during which she spoke at length to The Mail on Sunday, she appeared sometimes vulnerable, and sometimes steely, but always quietly resoiute and consistent. Revisiting events from a past that she had hoped she had ieft behind,Virginia occasionally buried her face in her hands. Some recollections - and, for reasons of taste, not ail the details can be included here - wused her to flush with shame. 'l?m telling you things that even my husband didn?t know,? she said. Virginia, who has undergone counselling to try to come to terms with her past, is honest about her initiation into Epstein?s depraved worid. She was a troubled teenager, whose slender ?gure. deiicate compiexion, hesitant voice and soulful blue eyes made her iook young for her years. Born in Sacramento, California, in August 1983, Virginia spent her early years on a email ranch on the West Coast of America. This seemingly idyllic childhood ended when she was sexuaiiy molested by a man close to her family. The fallout from that led to her parents temporarily splitting up. Btaming herself, Virginia began to get into trouble Aged 11, she was sent to live with an aunt but repeatediy ran away. Living on the streets, she was beaten up and slept with at least two older men in return for food. 1 was a paedophile's dream,? she says. Three years iater, she was reunited with her family and started a new life with herfather who had moved to Palm Beach, Fiorida, where he was maintenance manager at Donaid Trump?s country club, Mar?a?Lago. Virginia got a part-time job as a changing room assistant ?which is where, soon after her 15th birthday, she met Ghislaine Maxweli, who invited her to work as Epstein?s personal masseuse. 'l was wearing my uniform a white miniskirt and a skin-tight white polo top when i was approached by Ghisiaine,? Virginia says. told her wanted to become a masseuse and she said she worked for a very wealthy gentieman who was looking for a masseuse. I'd get training and be paid welt.?Virginia?s father gave his blessing, believing his daughter was being handed the opportunity to learn a skill and to work for a weaithy and respectable employer. He drove her to Epstein?s pink mansion on the Palm Beach waterfront~ he also owns a nine-storey home in New York, the city's biggest private residence; a 7,500?acre ranch called ?Zorro? in New may toailadm?maialfma??wef 9 'Need a tight tush': LeAnn Rimes iilustrates how to get a firm 'bocty' as she does yoga in skimpy tank top and leggings Exercise tips 'i want them really big!? Blonds bombshell begs doctors to make her 1,000cc implants even after they insist her enhanced breasts are 'perfect' On Botched 'lt's my icurth favorite reality show! Jessica Aiba and Kate Hudson are mean girls as Chris Martin plays for laughs in Sara and Erin Foster' Barely Famous 'He's turned into an absolute jerk:' Former Celebrity Apprentice star Vivica A. Fox siams Donald but says he's not a racist She's no longer a fan ?l don't see a dark past anymore': Paris Jackson reveais tattoos hav heiped cover her 'scars and self-hatred? in moving lnstagram post How the season's hottest beach babes including Hailee Steinfeld and Kendall Jenner are embracing jeweiry at the seashora Chic on the beach This bid thingi Duchess of Cambridge recycles a TEN~year-old . brocade coat as she plants a tree at garden party From the back of her wardrobe EXCLUSIVE: Alexa Curtin, daughter of Real Housewives star Lynne, is charged with drug possession two months after accusing O.C. deputy sheriff of raping her during a traffic step 'i told my mom she's a grandma?: Maria Menounos shared excitement about her frozen embryos in poignant given before negative pregnancy test Gene Simmons? daughter Sophie says she was told she was 'not small enough' to be a model and reveals her mom taught her to iove her shape Case 18-2868, Document 278, 08/09/2019, 2628230, PageS of 648 6114mm Case 9 Mexico and Little Saint James, a private 70_ acre atoll in the US Virgin islands. 'i?d cry because there was nothing icould do to heip': Betta Hadid pens emotional note about her mother Yolanda's Lyme disease battle and shares the impact of her own struggle Has the Queen Bey lost her sting? Beyonce steps out in questionable out?ts as she recyctes Super Bowl Reformation look She is stilt a b?ailbiezer Jenna Bush Hager shares somber message about motherhood as she reveais her daughter was baptized oniy hours before Orlando shooting Time for Kardashian ideas! From 'bloop? to Kim schools fans in how to talk iike a true-blooded member of the family How to be like them Brazilian Miss Burn Bum model reveats she is paralysed from the waist down after throwing herseif from a fourth floor window in suicide attempt A new life: Virgina, now a mother?of-three, in Australia Southern Charm stars claim Dennis Virginia says: 'Ghislaine said I was to start immediately and that someone would drive me home. failed drug test in My father left and i was toid to go upstairs.? She was fed by another woman through Epstein?s cusmdy hams mm wealthy drug~shamed bedroom Into a massage room where he lay face down naked on a table. former politicgan He started to interviewed Virginia. This was unconventional, but Virginia had no suspicions. thgi?e?raxi?t?jget'oa?gg Presumably, she thOught, this was how the wealthy conducted their business. Epstein elicited the information that Virginia had been a runaway, and was no longer a virgin. Mini?me Barmnioms parents Donald Trump Virginia was then toid to start massaging Epstein, under the Instructions of the woman who had and Meiania at The Pole shown her in. The massage quickly developed into a sexual encounter. Bar for dinner the night . . . before his 70th birthday Virginia was uncomfortable, but reluctant to deny such Important people. ?My face was red With (and Secret Service embarrassment,? she says. ?But i felt under immense pressure to piease them. chauffeurs them the one . . . . . . The whole time It was 90an on, they were me the world, that I?d travel w1th Jeffrey on his mom wal ome) private jet and have a weii~paid profession.? Afterwards, she was given two $100 bitls and told to Lord of the manor! return the next day. Scott Disick views That was the beginning of the four years she spent with Epstein. For three of those years, she was under Fiorida's age of consent, which is 18. 3:21:22: t? ?x He is 33 Peek-a?boob! Heidi Klum flashes cleavage 4f34 Case 18-2868, Document 278, 08/09/2019, 2628230, Page6 of 648 6114/2016 Traubled teenager: Virginia on the billionaire's Zorro ranch in New Milli? Case 1: 1590WWRW81 WM mi? ??lm Virginia was fascinated by his life story: the son of a humble New York City parks worker, he was a teacher before becoming a Wall Street broker and friends with the upper echelons of the political, ?nancial and academic establishment. As a confused teenager, Virginia easily fell into the practice of sexually gratifying him for money. He guaranteed her a minimum of $200 each time she gave him what he called an ?erotic massage.? Virginia said: ?i would always receive the money immediately. He would give me the cash from a wad he carried in a black duffel bag or an assistant paid me. ?And, because of the way Epstein had warped her sensibilities, every time she took the cash, Virginia felt even more indebted to him. Secretly, he was also preparing her for an even more disturbing role. ?Basically, i was training to be a prostitute for him and his friends who shared his interest in young Epstein had trained me :'Aft ttwo t??ilsI friend?s?:Ears a to do Whatever men it started when Epstein called Virginia at the Palm wan ted . I told myself I Beach apartment he had rented for her. . was spec I al She recalls: ?He said, ?We got a good friend and I need you to fly to the island to entertain him, massage him and make him feel how you make me feel.? He didn?t spell out what had to do. He didn?t have to. ?He?d trained me to do whatever a man wanted. I was shocked but told myself he was sharing me around because he trusted me and was special. I was worried, but i would do anything to keep Jeffrey happy and to keep my place as his number one girl. He would keep telling me how lucky was with the life i was leading and the money I was making. It was easy to fall into his grasp. ?The way it usually worked was I'd be sent to meet a man on the private island Jeffrey owned in the Caribbean, or at his ranch in New Mexico, which was really isolated.? She was ?given? to men ranging in age from their 405 to their 60s. They included a well-known businessman (whose pregnant wife was asleep in the next room). a world-renowned scientist, a respected liberal politician and a foreign head of state. None appeared to think the arrangement was unusual. Virginia says there were many other girls in Epstein?s circle and that she was paid extra money to help recruit them. ?They would lounge around the Palm Beach house, the ranch or the island, nude or topless,? she says. ?But was one of the very few he trusted as "special" and chosen to "entertain? his friends.? Virginia took the sedative Xanax to detach herself from sordid reality. 'it was an escape drug,? she says. ?It made me calm and helped me forget ab0ut what eight pills a day.? Epstein had no objection to Virginia?s use of prescription drugs, no doubt recognising that they made her even more malleable. didn?t want to go back to the life I?d had before? she says. ?That made me totally obedient.? Despite the fact that Epstein was, essentially, her pimp, this life n0w seemed normal to Virginia. felt that he and Ghisiaine really cared for me,? she said. ?We?d do family things, like watch Sex And The City and eat popcorn. iot of it was very glamorous. met famous friends of his such as Al Gore and Heidi Klum and Naomi Campbell. He introduced me as his ?travelling masseuse." Some people mistook me for his daughter. ?When we were in New York or Palm Beach, Ghislaine and I would shop all day. emeairesgeerat 9 as she leaves her blouse undone across her chest during NYC outing with her children Mom-ol?four She?s almost as tall as her mom! Courtenay Cox's daughter Coco Arquette wears high heels and polka dot dress for her 12th birthday at Nobu 'lt's hard on me': Liev Schreiber talks struggle of working in LA while Naomi Watts and their two kids are in NYC as he sits down with Eilsn He misses them 'i was too big': Khloe Kardashien reveals stylists refused to work with her before she lost 40le as she wows in stunning natural shoot for Harper's Bazaar Curb Your Enthusiasm is back! Larry David's beloved comedy series will return for a ninth season The beloved HBO comedy series Super-sized diamond Her Majesty calls ?Granny's Chips? and the solitaire seed that grew into a flower: Queen's brooches and earrings have a glittering history Sporty! Channing Tatum wears a backward baseball cap and matching vest as he teaves NYC hotel The Magic Mike slar was hard to miss Rollin' and strollin'l Chilled Bobby Cannevale gets behind the wheels of baby son Rocco?s classy ride as he runs errands Star of HBO's Vinyl 5?34 Case 18-2868, Document 278, 08/09/2019, 2628230, Page7 of 648 61142016 Jeffrey bought me jeweliery - diamonds were his favourite - and wonderful furniture. He was paying me very weli because I?d give him sex whenever he wanted it.? She was, she says, deiighted when Epstein invited her to accompany him on a six-week trip in 2001. ?He said we?d be going to Europe and North Africa to meet architects and interior decorators because he wanted to redo his New Mexico house. I threw my arms around him and gave him a peck on the cheek.? They ?ew to Paris, then Spain, then Tangier. Finaliy, they went to London. 'After we ianded, we drove straight to Ghislaine?s house,? says Virginia. was given a small upstairs bedroom. The foliowing morning, Ghislaine came in. She was chirpy and jumped on the bed saying, "Get up, sleepyhead. You?ve got a big day. We've got to go shopping. You need a dress as you're going to dance with a Prince tonight." ?She said i needed to be "smileY' and bubbly because he was the Queen?s son. Ghisiaine and lwent to Burberry, where she bought me a ?5,000 bag, and to a few other designer stores where we bought a couple of dresses, a pair of embroidered jeans and a pink singlet, perfume and make-up. We got back to Ghislaine?s house at around 4pm and I ran straight upstairs to shower and dress. When I went downstairs, Ghislaine and Jeffrey were in the lounge. There was a knock at the door. Ghislaine led Andrew in and we kissed each other on the cheek. ?Ghislaine served tea from a porcelain pot and biscuits. She knew Sarah Ferguson and they talked fondly about Andrew?s daughters. Then Ghislaine asked Andrew how old he thought I was and he guessed 17 and they all laughed. Ghislaine made a joke that I was getting too old for Jeffrey. She said, ?He?ll soon have to trade her in.? It was widely known that he liked young girls.? The four of them went out to dinner and on to Tramp where, she says, Andrew danced with her. ?After about an hour?and-a-half, we drove back to Ghisiaine?s. Ail of us went upstairs and I asked Jeffrey to snap a picture of me with the Prince. I wanted something to show my Mom. Ghisiaine and Jeffrey left us after that, and later Andrew left. 'In the morning, Ghislaine said, ?You did welt. He had fun?. We ?ew straight back to the States.? The Maii on Sunday has con?rmed that the tycoon?s jet ?ew to Paris on March 6, 2001, continuing to Granada, Tangier and London, before returning to New York. On the fast leg of the trip, Virginia was paid about $15,000 (?9,400) by Epstein. ?it was amazing money, more than I?d ever made on a trip with him before. "Counseliing: Virgio Beach in 1998 He didn?t say there was any special reason, but I felt like i'd done everything he wanted. He was very pieased.? There is no suggestion that there was any sexual contact between Virginia and Andrew, or that Andrew knew that Epstein paid her to have sex with his friends. I took eight pills a day to help me forget what i had to do. It made me calm. However, the Prince must have been aware of Epstein's conviction when he stayed with him in New York in December. Virginia says she met Andrew for a second time around Easter 2001 at Epstein?s Manhattan mansion. ?When I got to the mansion, i was told, ?Get ready. You are meeting someone in the of?ce? "which is what they calied the library. Andrew was sitting there in a big ieather armchair. Ghislaine had just given him a present, a big toy that was his Spitting Image puppet. ?He was smiling ear-to-ear. He iooked like a kid whose parents were taking him to Disney World. A beautiful girl sailed Johanna Sjoberg who worked for Jeffrey was sitting on Andrew?s knee. Ghislaine guided me over to Andrew and I think he recognised me, though I don?t know if he remembered my name. Case WWI-12V smsaneageerer 9 ?l'm dating a separated married man:? Bethenny Frankel reveals she went to high school with wife of new boyfriend Dennis Shields Skinny Girl founder Get in there? Prince Harry and Zara Tindall can?t contain their excitement as they watch their horses gailop to victory at Royaf Ascot 'This isn't about you and your fake a" kiss for publicity?: Madonna is slammed for her 'self? promoting' tweets following Orlando massacre Jason Momoa's mini- met Game of Thrones hunk enjoys famiiy outing with cutie clone Nakoa?Wolf Seven?year?oid's mom is Lisa Bonet Craving a iittle Mexican! Rob Kardashian?s pregnant fiancee Biac digs into a bowl of tortiila soup during Snapchat video Another Bachelor baby! Peyton and Chris Lambton are 'thrilled? to be expecting their first chiid after four years of marriage The two wed in 2012 Lil Wayne ?guzzled three bottles of cough syrup mix lean' before suffering TWO rapper now 'stebie and in good spirits' Cowgirl chic! Alessandra Ambrosio shows off toned legs with mini skirt as the stunner goes for a denimcmdenlm took Secret Angel Madonna and Guy Ritchie on brink of deal over custody of their 15 year?old son Rocco as judge agrees to cail off showdown court hearing for more talks Gillian Anderson looks demure in sophisticated navy knee-tength dress as she attends star studded charity gala On behalf of Action on Addiction Charlie Sheen cuts a casual figure while out and about in Stockholm After becoming the new face 6?34 Case 18-2868, Document 278, 08/09/2019, 2628230, Page8 of 648 . alne Maxwell looks on as Andrewputhisarm around Virginia. Robert Maxwell?s daughter invited her to work as Epstein's personai masseuse soon after her 15th birthday Case . misled 9* We kissed on the cheek and Ghislaine placed me on his other knee.? Johanna spoke to The Mail on Sunday three years ago about this incident, which took piace when she was 21. She said: 'Ghisiaine put the puppets hand on Virginia?s breast, then Andrew put his hand on my breast. It was a greatjoke. Everybody laughed.? After this, Virginia was paid, by Epstein, around $400 She met Andrew forthe third and final time on Epstein?s Caribbean island, Little Saint James. Virginia was never under the British legal age of consent when she met Andrew. She was 17 during the ?rst two encounters and 18 at the third. By now, however, Epstein, had started to hint that she was getting ?too old? for him. But during one trip to the island, Epstein and Ghisiaine made their most astonishing proposition, and one which repulsed her. ?They said Jeffrey wanted me to have his child,? she says. ?They said I was part of their family and I was beautiful,young, loyal and nurturing and would be a great mother. They said i would have to sign a contract relinquishing rights to the chiid and consenting to Jeffrey having as many relationships as he liked. in return i would have my own mansion in Palm Beach and a large payment, a percentage of his income.? This, ?naliy, was a wake-up coil to Virginia and she began to see the way in which she had been groomed. ?it was a smack in the face,? she says. ?i ?nally realised this wasn?t ever going to be a real relationship but i knew if! refused, I'd be thrown back on the streets. So I said, "I'm too young. i want to get my massage credentials, then maybe we'li do it": The tycoon took her at her word and, for her 19th birthday in August 2002, flew her to Thaiiand where he enrolled her in a massage course. Shortly after arriving there, she met an Australian martial arts expert caiied Robert. They fell in love and, just ten days later, married in a Buddhist ceremony. ?l cailed Jeffrey and tofd him I?d fallen madly in love,? Virginia says. was hoping he?d be delighted. But he said, ?Have a nice life,? and hung up on me.? The couple now have two sons, aged ?ve and four, and a daughter who recently turned one. ?The ?rst few months after I married Robert were the worst,? she says. couldn?t bring myself to teil him much. No man wants to know his wife has been traded out. felt very alone. i was having panic attacks and seeing a and was on anti-depressants. Virginia was beginning to put her Epstein days behind her when, three years ago, she was phoned by the FBI. of condom brand Lelo Hex Wave goodbye to the rain! The deluge FINALLY stops as the Queen arrives at Ascot with and Harry after thousands of racegoers got drenched Two nations standing together: Wills and Kate sign book of condoience to pay their respects to the victims of Orlando ktlier Paying respects Time for an upgrade? David Arquette lists his historic Los Angeles mansion for $8.5m Selling Hancock Park seven-bedroom home which he bought in 2014 She's her own best adverti Jessica Alba's tresses glint in the sun as she promotes her Honest Company's new hair care range in New York Katharine McPhee ?ashes a hint of sideboob in a piunging unbuttoned black dress as she poses at the Monte Carlo Television Festive! Let the trading begin! Independence Day's Llam Hemsworth and Vivica A. Fox ring the NASDAQ bell and help celebrate the Army's birthday in NYC Ava Sambora puts on an eye-popping display for sizzling photo shoot as she parades her enviable bikini bed in Malibu Daughter of rocker Richie Sambora How does Adele make YOU feel? Sad songs provide 'enjoyment, comfort or pain to different people' Great comfort frOm seemingly sad songs Daisy Lowe and rumored beyfriend Darius Campbell appear in high spirits as they leave star-studded charity event She is 27 Sir Paui McCartney leads tributes as Wings guitarist Henry 7/34 Case 18-2868, Document 278, 08/09/2019, 2628230, Page9 of 648 61142016 ?They said they had found photos of me at Jeffrey?s Palm Beach house.? she says. ?[Epstein had] hidden cameras watching me the entire time even when I was in the bathroom. I was so embarrassed. ?l told the FBI that my true purpose was sexual. They told me everything he did was illegal because I was under age.? (The age of consent in Florida is 18). ?They said that if it had to go to trial, theYd need me because I'd lived with him and that made me a key witness. was very afraid, because he had so much power, but eventually I agreed to testify. I was glad he?d ?nally been found out. He shouldn?t be hurting other girls. Following Epstein?s arrest, investigators are believed to have found a list of men's names on his computer and asked him whether they had been 'treated? to Sexual encounters with his menage of minors. Conviction: Jeffrey Epstein ?He took the Fifth Amendment, refusing to answer, indicating that if he were to answer the question, it could be incriminating,? a source told The Mail on Sunday. Epstein struck a deai resulting in what commentators characterised as a ?slap on the wrist' for him, and ended up sewing 13 months of his sentence, much of it in a liberal work-release programme Lawyer Brad Edwards, who represented several of Epstein?s victims, said: ?Rather than punish him the way they would an average Joe, they sent a clear message that with enough money and power and in?uence, the system an be bought.? Virginia was spared her the of having to go before a jury, and has kept her feelings bottled up until last weekend?s photograph of Andrewwith Epstein triggered distressing memories. Virginia says: am appailed. To me, it?s saying, "We are above the law." But Jeffrey is a monster.? Last night, neither Epstein, Ghislaine Maxweli nor Prince Andrew would comment on Virginia's story. Share or comment on this article Need Business Capital? Get These Rare Historical Photos What Marcia Brady Looks Unsecured Loans in 24 hours That Will Leave You Snapcap.com Like Now Is Incredible Speechless Definition History Fanatic Case 9 McCullough who - - piayed on Live and Let Die Bond theme dies aged 72 Remembering his pet Bargain shopper! rew Barrymore sports colorful silk iacket as she loads up a trolley with knick~knacks at flea market She's a mom-of-two 'Actualiy done!? Ariel Winter arrives to her high school graduation ceremony in form?fitting nude dress Alandmark day for the 15-year-old actress Kevin Hart has $500k of possessions stoien as thieves raid his LA home while he's away in Miami Break~in athis Tarzana home over the weekend 'Nothing makes me happier?: Alyssa Miieno reunites with Who's The Boss? co~star Judith 24 years after the show ended Catching up No show: Mets pitcher Bartolo Colon skips court hearing over dispute with once-secret and their two love children We embraced the BifQueer label lately': Matilda star Mare Wilson reveals her sexuality on Twitter Also starred in Deubt?re Prettiest delivery girl ever! Makeup-free Heidi Klum,43, carries three large coffees in NYC after revealing beau Vito gifted her to dozen red roses Sizzling Katie Holmes gives a rare glimpse at her suitry side as she poses nude in gorgeous throwback snaps from jewelry campaign She is 37 A Givenchy giri! Mode! Lily Aldridge steps out in $1,250 designer SWEATSHIRT as she shows off slim legs in NYC Victoria's SecretAngel 8f34 Case 18-2868, Document 278, 08/09/2019, 2628230, PagelO of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Pagell of 648 6115/2016 Bill Climon and the 15-year-old 'masseuse?: I met him twice, claims Epstein's girl Daily Mail Onlins Home I U.K. Sports I U.S. Showbiz I Australia I Femail I Health I Science I Money IVideo ITravel IColumnists is. c, LE4 2:132: W?tl 2:35; Liliilts Teenage girl recruited by paedophile Jeffrey I I Epstein reveals how she twice met Bill Clinton By SHARON CH URCHER and POLLY DUNBAR FOR MAILONLINE UPDATED: 19:53 EST, 5 March 2011 24- Visw comments As a New Yorker from humble beginnings, Jeffrey Epstein played on his blue-collar credentials and enormous wealth to extend tentacles of in?uence throughout America's liberal political elite. During the outcry over the Epstein case, it emerged that another man with a notorious appetite for young women, Bill Clinton, travelled with Epstein to a number of destinations, including three times on the billionaire?s private aircraft. On one occasion, Epstein ?ew the former President, Hollywood actor and staunch Democrat Kevin Spacey and another actor friend of Mr Clinton's, Chris Tucker, to Africa, to ?discuss AIDS poiicy?. Claims. Virginia 0 arts says 3 stw: ent out' Epstein, who has donated more than ?75,000 over the years to candidates from the Democratic Party, also ?ew with Mr Clinton in November 2003 to destinations including Russia, Oslo, Hong Kong, Shanghai and Beijing. Yet Virginia Roberts stresses that she was never ?lent out' to Mr Clinton. On one occasion, she adds, Epstein did invite two young brunettes to a dinner which he gave on his Caribbean island for Mr Clinton shortly after he left of?ce. But, as far as she knows, the ex-President did not take the bait. ?l?d have been about 17 at the time,? she says. ?l ?ew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her. SHARE THIS RELATED ARTICLES ARTICLE ., FBI to reopen case . 7 Epstein?s Girl Friday 1:31 Case 18-2868, Document 278, 08/09/2019, 2628230, Pagel2 of 648 61152016 Case 11 Dead tycoon's 'She?d always wanted to ?y and Jeffrey paid for her to take lessons, and I remember she was very excited because she got her licence around the ?rst year we met. '1 used to get frightened ?ying with her but Bill had the Secret Service with him and I remember him talking about what a good job she did. 'l only ever met Bill twice but Jeffrey had told me that they were good friends. asked. ?How come?" and he laughed and said, ?He owes me some favours." Maybe he was just joking but it constantly surprised me that people with as much to lose as Bill and [Prince] Andrew weren?t more careful. ?Bill must have known about Jeffrey?s girls. There were three desks in the living area of the villa on the island. Speaking out: \?rgima, now aged 26. In her new home in Australia They were covered with pictures of Jeffrey shaking hands with famous peeple and photos of naked girls, including one of me that Jeffrey had at all his houses, lying in a hammock. We all dined together that night. Jeffrey was at the head of the table. Bill was at his left. i sat across from him. Emmy Tayler, Ghislaine?s blonde British assistant, sat at my right. ?Ghislaine was at Bill's left and at the left of Ghislaine there were two olive~skinned brunettes who'd ?own in with us from New York 'l'd never met them before. l?d say they were no older than 17, very innocent-looking. They weren?t there for me. They weren't there for Jeffrey or Ghislaine because I was there to have sex with Jeffrey on the trip. ?Maybe Jeffrey thought they would entertain Bill, but I saw no evidence that he was interested in them. He and Jeffrey and seemed to have a very good relationship. Bill was very funny. 'He made me laugh a few times. And he and Jeffrey and Ghislaine told blokey jokes and the brunettes listened politely and giggled. ?After dinner i gave Jeffrey an erotic massage. don't remember seeing Bill again on the trip but i assume Ghislaine ?ew him back.? According to prison records, when Epstein was serving his jail term, his visitors included a long- ?Bill must have known about Jeffrey's girls. There were three desks in the living area of the villa on the covered with photos of naked girls' time and highly controversial - Clinton acquaintance, Arnold Prosperi. 'In the ?nal hours of the Clinton presidency, in January 2001, Prosperi was facing three years in prison after being convicted of tax fraud. Mr Clinton commuted his sentence to house arrest. ?Clinton, Prosperi and Epstein make an odd threesome on the face of it,? says a law enforcement Was Prosperi visiting Epstein as some kind of intermediary for Bill? 'Maybe Bill wanted to know if Epstein knew anything that could embarrass him. Or did Bill commute Prosperi's sentence as some kind of favour for Epstein?? Virginia disclosed that Mr Clinton?s vice-president Al Gore and his wife. Tipper. were also guests of Epstein on his island. . . 5 against sex offender . .. i friend of Cambridge can?t contain her excitement as her horse wins at Royal Ascot races Whooped and cheered Brown Simpson have an affair with OJ's best friend Marcus Allen and OJ 'threatened to kill her if she saw him one month before her death' ?l've been doing him forever:' Awkward moment Sonja Morgan discovers Luann de Lesseps' ?soul mate? is her old 'hook up' Thomas D?Agostino She really iS a lady in waiting! Amelia Windsor Taller's most beautiful royal swaps high glamour for WAITRESSING as she helps out at a launch New beau? Ashley Olsen, 30, is romantically linked to artist George Condo, 59 after they are spotted 'looking romantlc' et NYC's Mercer Hotel Dad bod! Adam Sandler, 49, shows off his naked chest while wrapped in towel during Miami vacation with his wife of 13 years Couple looked blissful Kim Kardashien?s naked ambition is laid here again as she strips off to celebrate her post- baby body with 60 cover Gave birth in December Kake?gate! Kim Kardashian tries to cheat on family cake makers Hansen's by asking her followers for new bakery recommendations 'lworked my a? offi': Kim Kardashian spills secrets to losing 60lbs after pregnancy as she admits 6am sessions and "militant diet? did trick Advertisement .html 2131 Case 18-2868, Document 278, 08/09/2019, 2628230, Page13 of 848 6115/2016 a aFP?etiy images Guests: Virginia says she also met former Vice President Al Gore. pictured right with Mr Clinton Last summer, the Gores abruptly announced that they were ending their supposedly fairytale marriage and, just weeks later, it emerged that Mr Gore the famously sanctimonious global- warming disciple had been accused of trying to force sex on a woman with whom he had booked a therapeutic massage at an Oregon hotel. had no clue that anything was up,? Virginia says. ?The Gores seemed like a beautiful couple when I met them. All I knew was that Mr Gore was a friend of Jeffrey?s and Ghisiaine's. Jeffrey didn?t ask me to give him a massage. There might have been a couple of other girls there on that trip but could never have imagined this guy would do anything wrong. was planning to vote for him when I turned 18. i thought he was awesome.? Virginia said that yet another American liberal icon, President Obama?s Middle East peace envoy Senator George Mitchell, frequently visited Epstein?s New York residence. Mr Mitchell, aged 77 - who previously led America?s Northern Ireland peace initiative ?was very close to Jeffrey,? Virginia recalled. ?He is very clean-cut. You wouldn?t think of him being part of Jeffrey?s crew.? 7% Elm Scandal: U.S. authorities want to interview Jeffrey Epstein (left) and may wish to quiz his friend, Prince Andrew Epstein's contacts book contains a work and a home telephone number for the senator. Another acquaintance was Israel defence secretary Ehud Barak, whose spokesman told The Mail on Sunday: 'Mr Barak did attend several small functions in Mr Epstein?s home in New York that were usuaily attended by leading businessman, university presidents, Nobel Prize Laureates and prominent public figures.? . Case 1215999W?M??mm13m13im @?iblr?la?l 5 'We iust want them to have a normal life': Blake Lively reveals her parenthood plans now that baby no.2 is on its way and why she fell in love with Ryan Reynolds Back to work! Miley Cyrus and Liam Hemsworth temporarily go their separate after very public dinner date in NYC Ivanka Trump shares morning snap of baby Theo watching her get ready as she admits in that she wakes up at 5:30am and goes to work with her hair wet they could be sisters! Princess Mary of Denmark and Duchess of Cambridge look strikingly similar as they enjoy a catch up at Royal Ascot Brooke Shields' stalker walking into court with trial entering third day after judge hears actress?s tearful testimony about man coming to her home Mixing business with pleasure? Bodysuit-clad EJ Johnson gets in some retail therapy before filming his yet?to- air New York reality show Seth Myers 'hans' Trump from appearing on NBC's Late Night 3131 Case 18-2868, Document 278, 08/09/2019, 2628230, Pagel4 of 648 6/15/2016 Epstein's many Hollywood pals include Matt Groening, creator of The Simpsons. ?Jeffrey once had me give Matt a foot massage when he was ?ying on the jet with us,? Virginia says. ?He laughed and did drawings of Bart and Homer for my little brother and my dad. ?l also met Naomi Campbell at a birthday party of hers on a yacht in the South of France. She is a friend of Ghislaine's but she was a reef bitch to me. 'She was very fake. She turned away from me when we were introduced by Ghislaine and Jeffrey. ?Donald Trump was aiso a good friend of Jeffreys. He didn?t partake in sex with any of us but he ?irted with me. He'd laugh and tell Jeffrey, ?You?ve got the iife."? Palm Beach Police say Epstein seemed utterly unfazed by the allegations against him when they began their long and detailed investigation. @37- iJeffrey?s crew: Middle East peace envoy George Mitchell, right, pictured with President Barack Obama and US. Secretary of State Hiiary Clinton, frequently visited Epsteings New York residence, Virginia also claims But he also took his defence very seriously indeed. Epstein engaged his friend, the Harvard law professor Alan Dershowitz? whose celebrity clients have inciuded Mike Tyson, Patty Hearst, Claus von Buiow and OJ. Simpson to run his legal defence. He also employed a ?rm of private investigators to investigate the backgrounds of the girfs. Detectives painstakingly built a case which they believed showed that Epstein Systematimlly paid teenage girls to recmit other teenage girls to his sex ring. However, as the investigation continued, they found that Epstein's team had already spoken to key witnesses, suggesting that the ?nancier would reward those who helped him. In addition, Epstein?s defence team agreed to the unusual move of suggesting that the alleged victims sue Epstein in the civil courts. The result was a plea bargain in which Epstein admitted a single charge of soliciting an underage girl for prostitution a deal which infuriated many police officers who worked on the case. More than 20 of Epstein?s girls are said to have sued him for damages. At least 17 have settled out of court. Mr Ciinton, Mr Gore and Mr Mitchell were all contacted about their friendship with Epstein but destined to comment. Share or comment on this article Case 9% 5 Show - but admits the presidential hopeful wasn't going to come on anyway Yolanda Hadid cans" Real Housewives of Beverly Hiils to ?bring back privacy' to her iife after dramatic season that documented her divorce and accusations she was faking illness Victoria Beckham shows a hint of sideboob and ?ash of ieg as she flaunts her sartoriai sass for cover of Vogue Korea Striking shoot A mellow day! .Rumer Willis dresses down in a grey maxi dress as she hangs outwith a friend in West Hollywood Taking a break from the presidential campaign Catherine Zeta?Jones' daughter Carys is her doppeiganger as the pair arrive in London with Michael Douglas and son Dylan Family trip Stephen Colbert compares Trump to a as he draws a swastika on chalkboard while trying to ?figure out' Obama?s response to Orlando massacre Grieving Adam Levine is pictured piaying golf in first outing since Christina Grimmie's after offering to pay for the Voice star?s funeral Does North West have her own glam squad? Kim Kardashian 'hires daughter $5k a week team including and manicurist' The smiie's back! Demi Lovato appears happy at airport while looking chic in oiive coat as she recovers from Wiimer Vaiderrama shock split Wore classic combo ?i'm not killing off Harrison Ford': Steven Spielberg reveals he won't and indiana Jones' life in next film as he gives rare interview Good news for Ford! ns?girl .htmi Case 18-2868, Document 278, 08/09/2019, 2628230, Page15 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page16 of 648 PR Hub Breaking News 1 Entertainment I Sports Business I Politics I Science I Technology I Odd News I Health I Law Maxwell BY i?i?t?Nii MARCH 0. at.) I LONDON, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. It is unacceptable that letters sent by Ms Maxwell?s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers. understand newspapers need stories to sell copies It is well known that certain newspapers live by the adage, "why let the truth get in the way of a good story." However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop," said Ghislaine Maxwell. number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name," she said. Media contact: Ross Gow Acuity Reputation Tel; +44-203-008-7790 Mob: +44?7778-755-251 Email ross@acuityreputation . com Media contact: Ross Gow, Acuity Reputation, Tel: +44-2 03- 00 8-7790, Mob: ross at acuityreputation.com ?lled under: Government and Poiicy, 121w, Media 'l'ags: Devonshires Solicitors, London, March 10, United Kingdom MARCH 10 Share this Subscribe by page More Older News .. . 272812345 6789101112 GOVERNMENT AND POLICY NEWS CSA Group Selects Frankfurt, Germany for The First International Gateway to Africa Conference in Geneva: Africa&apos;s - Challenges Today and Tomorrow Central Saint Martins and Method launch Accelerator to Drive Innovation and Support UK Economic Growth North East Linoolnshire Council EmployeesSzapOS; Ideas Win Votes 7 _7 NEWS . Tech Mahindra Opensa 7 new European Headquarters .. i new Development Centre in Bonn, 7.7 Germany I W'ebsite Optimisation -. and Internet Marketing From eblinx Sir Paul McCartney Supports BUAV Campaign to end Cruel EXHIBIT 2b AGHEN BLANDO REPORTING 5/2: GIUFFRE001067 Case 18-2868, Document 278, 08/09/2019, 2628230, Page17 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Pagel8 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 1 mm UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-MarralJohnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #3 AND JANE DOE #4?8 CORRECTED MOTION PURSUANT TO RULE 21 FOR JOINDER IN ACTION COME NOW Jane Doc #3 and Jane Doc #4 (also referred to as ?the new victims?), by and through undersigned counsel, to ?le this motion pursuant to Federal Rule of Civil Procedure 21 to join this action, on the condition that they not re-litigate any issues already litigated by Jane Doe #1 and Jane Doc #2 (also referred to as ?the current victims?). The new victims have su??ered the same violations of their rights under the Crime Victims? Rights Act (CVRA) as the current victims. Accordingly, they desire to join in this action to vindicate their rights as well. Because the new victims will not re-litigate any issues previously litigated by the current victims (and because they are represented by the same legal counsel as the current victims), the Government will not be prejudiced if the Court grants the motion. The Court may ?at anytime? add new parties to the action, Fed. R. Civ. P. 21. Accordingly, the Court should grant the motion. FACTUAL BACKGROUND 1 As minor victims of sexual offenses, Jane Doc #3 and Jane Doc #4 desire to proceed by way of pseudonym for the same reasons that Jane Doe and Jane Doe #2 proceeded in this fashion. Counsel for the new victims have made their true identities known to the Government. 1 GIUFFRE 004288 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page19 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 2 of 14 As the Court is aware, more than six years ago, Jane Doc #1 ?led the present action against the Government, alleging a violation of her rights under the CVRA, 18 U.S.C. 3771. She alleged that Jeffrey Epstein had sexually abused her and that the United States had entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her rights. At the ?rst court hearing on the case, the Court allowed Jane Doc #2 to also join the action. Both Jane Doe #1 and Jane Doc #2 speci?cally argued that the government had failed to protect their CVRA rights (inter alia) to confer, to reasonable notice, and to be treated with fairness. In response, the Government argued that the CVRA rights did not apply to Jane Doe #1 and Jane Doc #2 because no federal charges had ever been ?led against Jeffrey Epstein. The Court has ?rmly rejected the United States? position. In a detailed ruling, the Court concluded that the CVRA extended rights to Jane Doc #1 and Jane Doc #2 even though federal charges were never ?led. DE 189. The Court explained that because the NPA barred prosecution of crimes committed against them by Epstein, they had ?standing? to assert violations of the CVRA rights. Id. The Court deferred ruling on whether the two victims would be entitled to relief, pending development of a ?ller evidentiary record. Id. Two other victims, who are in many respects similarly situated to the current victims, now wish to join this action. The new victims joining at this stage will not cause any delay and their joinder in this case is the most expeditious manner in which to pursue their rights. Because the background regarding their abuse is relevant to the Court?s assessment of whether to allow them to join, their circumstances are recounted here briefly. Jane Doe #3?5 Circumstances GIUFFRE 004289 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page20 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 3 of 14 As with Jane Doc #1 and ane Doe Jane Doc #3 was repeatedly sexually abused by Epstein. The Government then concealed ?'om Jane Doc #3 the existence of its NPA from Jane Doe in violation of her rights under the CVRA. If allowed to join this action, Jane Doc #3 would prove the following: In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator in his sexual abuse and sex traf?cking scheme. In fact, it became known to the government that Maxwell herself regularly participated in Epstein?s sexual exploitation of minors, including Jane Doe Maxwell persuaded Jane Doe #3 (who was then ?fteen years old) to come to Epstein?s mansion in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children (including Jane Doc #1 and Jane Doc When Jane Doe #3 began giving Epstein a ?massage,? Epstein and Maxwell turned it into a sexual encounter, as they had done with many other victims. Epstein then became enamored with Jane Doc and with the assistance of Maxwell converted her into what is commonly referred to as a ?sex slave." Epstein kept Jane Doc #3 as his sex slave from about 1999 through 2002, when she managed to escape to a foreign country and hide out ?'om Epstein and his ace-conspirators for years. From 1999 through 2002, Epstein frequently sexually abused Jane Doc not only in West Palm Beach, but also in New York, New Mexico, the U.S. Virgin Islands, in international airspace on his Epstein?s private planes, and elsewhere. Epstein also sexually traf?cked the then-minor Jane Doe, making her available for sex to politically-connected and ?nancially-powerful people. Epstein?s purposes in ?lending? Jane Doe (along with other young girls) to such power?il people were to ingratiate himself with them for 3 GIUFFRE 004290 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page2l of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 4 of 14 business, persona], political, and ?nancial gain, as well as to obtain potential blackmail information. One such individual that Epstein forced then?minor Jane Doc #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein?s and well-known criminal defense attorney. Epstein required Jane Doc #3 to have sexual relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but also on private planes, in New York, New Mexico, and the US. Virgin Islands. In addition to being a participant in the abuse of Jane Doc #3 and other minors, Deshowitz was an eye-witness to the sexual abuse of many other minors by Epstein and several of Epstein?s co-conspirators. Dershowitz would later play a signi?cant role in negotiating the NPA on Epstein?s behalf. Indeed, Dershowitz helped negotiate an agreement that provided immunity from federal prosecution in the Southern District of Florida not only to Epstein, but also to ?any potential co- conspirators of Epstein.? NPA at 5. Thus, Dershowitz helped negotiate an agreement with a provision that provided protection for himself against criminal prosecution in Florida for sexually abusing Jane Doc Because this broad immunity would have been controversial if disclosed, Dershowitz (along with other members of Epstein?s defense team) and the Government tried to keep the immunity provision secret from all of Epstein?s victims and the general public, even though such secrecy violated the Crime Victims? Rights Act. Ghislaine Maxwell was another person in Epstein?s inner circle and a co-conspirator in Epstein?s sexual abuse. She was someone who consequently also appreciated the immunity granted by the NPA for the crimes she committed in Florida. In addition to participating in the sexual abuse of Jane Doc #3 and others, Maxwell also took numerous sexually explicit pictures 4 GIUFFRE 004291 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page22 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 5 of 14 of underage girls involved in sexual activities, including Jane Doc She shared these photographs (which constituted child pornography under applicable federal laws) with Epstein. The Government is apparently aware of, and in certain instances possesses some of these photographs. Perhaps even more important to her role in Epstein?s sexual abuse ring, Maxwell had direct connections to other powerful individuals with whom she could connect Epstein. For instance, one such power?il individual Epstein forced Jane Doc #3 to have sexual relations with was a member of the British Royal Family, Prince Andrew (a/k/a Duke of York). Jane Doc #3 was forced to have sexual relations with this Prince when she was a minor in three separate geographical locations: in London (at Ghislaine Maxwell?s apartment), in New York, and on Epstein?s private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged girls). Epstein instructed Jane Doc #3 that she was to give the Prince whatever he demanded and required Jane Doc #3 to report back to him on the details of the sexual abuse. Maxwell facilitated Prince Andrew?s acts of sexual abuse by acting as a ?madame? for Epstein, thereby assisting in internationally traf?cking Jane Doc #3 (and numerous other young girls) for sexual purposes. Another person in Epstein?s inner circle of friends (who becomes apparent with almost no investigative effort) is Jean Luc Brunei. Epstein sexually traf?cked Jane Doc #3 to Jean Luc Brunei many times. Brunei was another of Epstein?s closest ?'iends and a regular traveling companion, who had many contacts with young girls throughout the world. Brunei has been a model scout for various modeling agencies for many years and apparently was able to get U.S. passports for young girls to ?work? as models. He would bring young girls (ranging to ages as 5 GIUFFRE 004292 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page23 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 6 of 14 young as twelve) to the United States for sexual purposes and farm them out to his ?'iends, especially Epstein. Brunel would offer the girls ?modeling? jobs. Many of the girls came from poor countries or impoverished backgrounds, and he lured them in with a promise of making good money. Epstein forced Jane Doe #3 to observe him, Brunel and Maxwell engage in illegal sexual acts with dozens of underage girls. Epstein also forced Jane Doc #3 to have sex with Brunel on numerous occasions, at places including Epstein?s mansion in West Palm Beach, Little St. James Island in the US. Virgin Islands (many including orgies that were comprised of other underage girls), New York City, New Mexico, Paris, the south of France, and California. Epstein also traf?cked Jane Doc #3 for sexual purposes to many other power?il men, including numerous prominent American politicians, power?il business executives, foreign presidents, a well-known Prime Minister, and other world leaders. Epstein required Jane Doc #3 to describe the events that she had with these men so that he could potentially blackmail them. The Government was well aware of Jane Doc #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the NPA. Moreover, even a rudimentary investigation of Jane Doe #3?5 relationship to Epstein would have revealed the fact that she had been traf?cked throughout the United States and internationally for sexual purposes. Nonetheless, the Government secretly negotiated a non-prosecution agreement with Epstein precluding any Federal prosecution in the Southern District of Florida of Epstein and his co-conspirators. As with Jane Doc and Jane Doe the Government concealed the non-prosecution agreement from Jane Doe #3 all in violation of her rights under the CVRA to avoid Jane Doc #3 from raising powerful objections to the NPA that would have shed tremendous public light on Epstein 004293 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page24 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 7 of 14 and other powerful individuals and that would likely have been prevented it from being concluded in the secretive manner in which it was. Jane Doe #4?3 Circumstances If permitted to join this action, Jane Doc #4 would allege, and could prove at trial, that she has CVRA claims similar to those advanced by Jane Doc #1 and Jane Doe based on the following: As with the other Jane Does, Jane Doc #4 was repeatedly sexually abused by Epstein. In or around the summer of 2002, Jane Doe an economically poor and vulnerable sixteen-year- old child, was told by another one of Epstein?s underage minor sex abuse victims, that she could make $300 cash by giving an old man a massage on Palm Beach. An acquaintance of Jane Doc #4 (also a minor sexual abuse victim of Epstein) telephoned Epstein and scheduled Jane Doc #4 to go to Epstein?s house to give him a massage. During that call, Epstein. himself got on the phone (a means of interstate communication) with Jane Doe asking her personally to come to his mansion in Palm Beach. Jane Doe #4 then went to Epstein?s mansion and was escorted upstairs to Epstein?s large bathroom by one of Epstein?s assistants. Shortly therea?er Jeffrey Epstein emerged and lay face down on the table and told Jane Doe #4 to start massaging him. Epstein asked Jane Doc #3 her age and she told him she had recently turned sixteen. Epstein subsequently committed illegal sexual acts against Jane Doe #4 on many occasions. Epstein used a means of interstate communication a cell phone) to arrange for these sexual encounters. Epstein also frequently travelled in interstate commerce on his personal jet) for purposes of illegally sexually abusing Jane Doe 7 GIUFFRE 004294 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page25 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 8 of 14 The acts Epstein committed against Jane Doe constituted numerous federal sex offenses, some of which do not carry a statute of limitations and thus are not time-barred. See 18 U.S.C. 3283. And. these offenses were the kinds of offenses that the Federal Bureau of Investigation (FBI) and U.S. Attomey?s Of?ce for the Southern District of Florida were pursuing in 2007. So far as Jane Doc #4 is aware, the U.S. Attorney?s Of?ce made no serious effort to locate her. Instead, after identifying approximately forty separate underage sexually abused victims, and apparently preparing a 53-page federal indictment and with full awareness of the existence of many victims like Jane Doe #4 unidenti?ed and not interviewed it entered into a non-prosecution agreement barring prosecution of Bpstein?s federal crimes against these victims. This is contrary to the Government?s normal approach in prosecuting federal sex offenses. It also violated Jane Doe #4?5 rights under the CVRA, including the fact that she had a ?reasonable? right to confer with the U.S. Attorney?s Of?ce before they entered into an agreement with a sex offender barring prosecution of him for the crimes he committed against her. 18 U.S.C. 3771(a)(5). MOTION FOR OINDER Jane Doe #3 and Jane Doc #4 now both move to join this action ?led by Jane Doc #1 and Jane Doe pursuant to Rule 21 of the Federal Rules of Civil Procedure. Rule 21 provides that motion or on its own, the court may at any time, on just terms, add . . . a party.? Rule 21 ?grants the court broad discretion to permit a change in the parties at any stage of a litigation.? Ford v. Air Line Pilots Ass ?n 268 F. Supp. 2d 271, 295 (E.D.N.Y. 2003) (internal quotation omitted). The new victims should be allowed to join the current victims in this action under Rule 21. GIUFFRE 004295 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page26 of 648 Case 9:08vcv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 9 of 14 The new victims will establish at trial that the Government violated their CVRA rights in the same way as it violated the rights of the other victims. The new victims? participation in this case is important because it appears that the Government intends to raise a factual defense that somehow it did keep Jane Doe #1 and Jane Doc #2 properly informed of what was happening in the criminal prosecution. Of course, if four victims all testify consistently that they were not prOperly informed by the Government (as we believe they will), that provides a stronger case for a CVRA violation. In addition, Jane Doe #3 and Jane Doe #4?5 participation is relevant to a defense the Court has allowed the Government to raise. The Court has previously ruled that the victims? request for rescission of the NPA ?implicates a fact-sensitive equitable defense which must be considered in the historical factual context of the entire interface between Epstein, the relevant prosecutorial authorities and the federal offense victims including an assessment of the allegation of a deliberate conspiracy between Epstein and federal prosecutors to keep the victims in the dark on the pendency of negotiations between Epstein and federal authorities until well after the fact and presentation of the non-prosecution agreement to them as afar?t accompli.? DE 189 at 12 n.6 (emphasis added). Jane Doe #3?5 and Jane Doe #4?5 participation in this case will help to show what the ?entire interface? was between the Government and the victims and thus to respond to the Government?s estoppel arguments as well as other defenses that it appears to be preparing to raise. See, DE 62 (52-page response ?-om the Government to the victim?s summary judgment motion, raising numerous factually-based and other arguments against the victim?s position). GIUFFRE 004296 Case 18-2868, Document 278, 08/09/2019, 2628230, Page27 of 648 Case Document 280 Entered on FLSD Docket 0110212015 Page 10 of 14 Jane Doe #3?s and Jane Doe #4?s participation is also directly relevant to the discovery disputes currently pending in this case. The Government has raised various relevancy objections to the documents that Jane Doc #1 and Jane Doc #2 are attempting to obtain. The current victims have responded by explaining how these documents are relevant, including explaining how these documents might hear on the way in which Epstein used his powerful political and social connections to secure a favorable plea deal, as well as provide proof of the Government?s motive to deliberately fail to investigate certain aspects of the victims? claims in an effort to maintain the secrecy of the facts and resolve the case without the victims? knowledge. See, DE 266 at 6-10. Jane Doc #3 and Jane Doe #4?s participation will help prove the relevancy of these requests, as well as the need for those requests. One clear example is Request for Production No. 8, which seeks documents regarding Epstein?s lobbying efforts to persuade the Government to give him a more favorable plea arrangement and/or non-prosecution agreement, including efforts on his behalf by Prince Andrew and former Harvard Law Professor Alan Dershowitz. Jane Doc #1 and Jane Doe #2 have alleged these materials are needed to prove their allegations that, after Epstein signed the non-prosecution agreement, his performance was delayed while he used his signi?cant social and political connections to lobby the Justice Department to obtain a more favorable plea deal. See, DE 225 at 7-8 (discussing DE 48 at 16-18). Jane Doc #3 has directly person knowledge of Epstein?s connection with some of these powerful people and thus how Epstein might have used them to secure favorable treatment. Adding two new victims to this case will not delay any of the proceedings. They will simply join in motions that the current victims were going to ?le in any event. For example, the 10 004297 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page28 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 11 of 14 new victims will simply join in a single summary judgment motion that the current victims anticipate ?ling after discovery has been completed. Nor will adding the new victims prejudice the United States. As the court is aware, this Court is still in its initial discovery stage. The Court is currently considering whether to reject the Government?s assertion of privilege over documents regarding the case. See DE 265 (victims? reassertion of objections to the Government privilege claims). The new victims do not seek any additional discovery beyond that previously sought by the current victims.2 Accordingly, the United States will not be prejudiced or burdened by adding them to this case. The CVRA does not contain any statute of limitations for ?ling an action to enforce rights under the statute. Accordingly, were the Court to deny this motion, the result might be that the new victims would then be forced to ?le a separate suit raising their claims, which would then possibly proceed on a separate litigation track. Rather than require duplicative litigation, the Court should simply grant their motion to join. Jane Doc #1 and Jane Doc #2 support the joinder motion. Counsel for the victims have discussed this motion with the Government at length in an effort to avoid any need to ?le a substantive pleading on the issue. Counsel for the victims asked the Government during the summer for its position on joinder. The Government, however, took the matter under advisement for months. Ultimately, after several inquiries from victims counsel, the Government indicated without explanation that it opposes this motion. Counsel for the victims has requested a meeting with the Government on this issue, which will hopefully occur in 2 Jane Doe #3 and Jane Doc #4 have asked the Government to provide them with the record of their statements that they provided to the FBI. These FBI 302?s should be only a few pages long. 1 004298 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page29 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 12 of 14 January. In the meantime, however, counsel for the victims believe that it is no longer appropriate to delay ?ling this motion and accordingly ?le it at this time. Because the Government is apparently opposing this motion, Jane Doe #3 and Jane Doc #4 have described the circumstances surrounding their claims so that the Court has appropriate information to rule on the motion. 12 GIUFFRE 004299 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page30 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 13 of 14 Jane Doe #3 and Jane Doe #4 should be allowed to join this action, pursuant to Rule 21 of the Federal Rules of Civil Procedure. Their joinder should be conditioned on the requirement that they not re-litigate any issues previously litigated by Jane Doe #1 and Jane Doe A proposed order to that effect is attached to this pleading. DATED: Januarv 2. 2015 Respect?illy Submitted, ls/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS LEHRMAN, PL. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mail: brad@pathtojustice.corn And Paul G. Cassell Pro Hac Vice SJ. Quinney College of Law at the University of Utah? 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585?5202 Facsimile: 801-585-6833 E-Mail: casselln@law.utah.edu Attorneys for Jane Doe #1 and Jane Doe #2 This daytime business address is provided for identi?cation and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah GIU FF RE 004300 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page31 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 14 of 14 CERTIFICATE OF SERVICE I certify that the foregoing document was served on January 2, 2015, on the following using the Court?s system: Dexter Lee A. Marie Villafa?a 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: Dexter.Lee@usdoj .gov E-mail: Attorneys ?r the Government Bradley J. Edwards 14 GIUFFRE 004301 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page32 of 648 EXHIBIT Case aeamcaamas??w. mm as oemeraalaa Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. ORDER DENYING MOTION TO JOIN UNDER RULE 21 AND MOTION TO AMEND UNDER RULE 15 This cause is before the Court on Jane Doe 3 and Jane Doe 4?s Corrected Motion Pursuant to Rule 21 for oinder in Action (?Rule 21 Motion?) (DE 280), and Jane Doe 1 and Jane Doe 2?s Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners (?Rule 15 Motion?) (DE 311). Both motions are ripe for review. For the following reasons, the Court concludes that they should be denied. 1. Background This is an action by two unnamed petitioners, Jane Doe 1 and Jane Doe 2, seeking to prosecute a claim under the Crime Victims? Rights Act (CVRA), 18 U.S.C. 3771. (DE 1). Generally, they allege that the respondent Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein, who subjected them to various sexual crimes while they were minors. Petitioners initiated this action in July 2008. Case seawevlemssx??m mm are. Page 2 in On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280). Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. at 11). Jane Doe 3 and Jane Doe 4 argue that they ?have suffered the same violations of their rights under the as the? Petitioners, and they ?desire to join in this action to vindicate their rights as well.? (Id at 1). The Government vehemently opposes joinder under Rule 21. (DE 290). The Government argues that Rule 15 is the proper procedural device for adding parties to an action, not Rule 21. (Id. at 1). ?[O]ut of an abundance of caution,? Petitioners ?led a motion to amend their petition under Rule 15, conforming the petition to the evidence and adding Jane Doe 3 and Jane Doe 4 as petitioners. (DE 311 at 2). The Government opposes the Rule 15 Motion as well. (DE 314). Among other things, the Government argues that amending the petition to include Jane Doe 3 and Jane Doe 4 should be denied because of their undue delay in seeking to join the proceedings, and the undue prejudice that amendment will cause. After considering the parties? submissions and the proposed amended petition, the Court ?nds that justice does not require amendment in this instance and exercises its discretion to deny the amendment. 11. Discussion ?The decision whether to grant leave to amend a complaint is within the sole discretion of the district court.? Laurie v. Ala. Ct. Crim. Apps, 256 F.3d 1266, 1274 (11th Cir. 2001). ?The court should freely give leave when justice so requires.? Fed. R. Civ. P. Justice does not require amendment in several instances, ?includ[ing] undue delay, bad faith, dilatory motive Case aeamcaae?ss??w. WW 8728., cameraman semeecaageanaram Page a (3110 on the part of the movant, . . . undue prejudice to the opposing party by virtue of allowance of the amendment, [and] ?itility of amendment.? ILrie, 256 F.3d at 1274 (quoting Foman v. Davis, 371 US. 178, 182 (1962)). In addition to considering the effect of amendment on the parties, the court must consider ?the importance of the amendment on the proper determination of the merits ofa dispute.? 6 Wright Miller, Fed. Prac. Fed. P. 1488, p. 814 (3d ed. 2010). Justice does not require amendment where the addition of parties with duplicative claims will not materially advance the resolution of the litigation on the merits. Herring v. Delta Air Lines, Inc., 894 F.2d 1020, 1024 (9th Cir. 1989). A. Rule 21 Motion Jane Doe 3 and Jane Doe 4?s first attempt to join in this proceeding was brought under Rule 21. (DE 280). ?If parties seek to add a party under Rule 21, courts generally use the standard of Rule 15, governing amendments to pleadings, to determine whether to allow the addition.? 12 Wright Miller, Fed. Prac. Fed. P., p. 432 (3d ed. 2013); see also Galustian v. Peter, 591 F.3d 724, 729-30 (4th Cir. 2010) (collecting cases and noting that Rule 15(a) applies to amendments seeking to add parties); Frank v. US. West, Inc., 3 F.3d 1357, 1365 (10th Cir. 1993) motion to add a party is governed by Fed. R. Civ. P. 15(a) . . . Rule 21, ?Misjoinder and Non-joinder of Parties,? provides the court with a tool for correcting the ?misjoinder? of parties that would otherwise result in dismissal. Fed. R. Civ. P. 21. Insofar as Rule 21 ?relates to the addition of parties, it is intended to permit the bringing in of a person, who through inadvertence, mistake or for some other reason, had not been made a party and whose presence as a party is later found necessary or desirable.? United States v. Com. Bank of N. Am., 31 F.R.D. 133, 135 (S.D.N.Y. 1962) (internal quotation marks omitted). Case WW 8728., Oemefeale?i Page a (3110 In their Rule 21 Motion, Jane Doe 3 and Jane Doe 4 do not claim that they were omitted from this proceeding due to any ?inadvertence? or ?mistake? by Petitioners; rather, they seek to join this proceeding as parties that could have been permissively joined in the original petition under Rule 20 (?Permissive Joinder of Parties?). As courts generally use the standards of Rule 15 to evaluate such circumstances, the Court will consider the oinder issue as presented in the Rule 15 Motion.1 The Court will consider the arguments presented in the Rule 21 Motion as if they are set forth in the Rule 15 Motion as well. Because the arguments are presented in the Rule 15 Motion (and because the Court is denying the Rule 15 Motion on its merits, as discussed below), the Rule 21 Motion will be denied. The Court also concludes that portions of the Rule 21 Motion and related ?lings should be stricken from the record. Pending for this Court?s consideration is a Motion for Limited Intervention ?led by Alan M. Dershowitz, who seeks to intervene to ?strike the outrageous and impertinent allegations made against him and [to] request[] a show cause order to the attorneys that have made them.? (DE 282 at 1). The Court has considered Mr. Dershowitz?s arguments, but it ?nds that his intervention is unnecessary as Federal Rule of Civil Procedure 12(f) empowers the Court ?on its own? to ?strike from a pleading an insuf?cient defense or any redundant, immaterial, impertinent, or scandalous matter.? Fed. R. Civ. P. 12(f). Petitioners? Rule 21 Motion consists of relatively little argumentation regarding why the Court should permit them to join in this action: they argue that (1) they were sexually abused by 1 The Court notes that, regardless of which motion it considers, the same standard governs the addition of parties under Rule 21 and Rule 15. Goston v. Potter, No. 08?cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Gm., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 Case aeactiemsamw mm are. Demetaaia: steereacaegearearm Page 5 of 10 Jeffrey Epstein, and (2) the Government violated their CVRA rights by concealing the non- prosecution agreement with them. (DE 280 at 3; at 7-8). However, the bulk of the Rule 21 Motion consists of copious factual details that Jane Doe 3 and Jane Doe 4 ?would prove? allowed to join this action.? at 3, 7). Speci?cally, Jane Doe 3 proffers that she could prove the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein sexually traf?cked her to several high-pro?le non?party individuals, ?including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.? (Id. at 3-6). She names several individuals, and she offers details about the type of sex acts performed and where they took place. (S_ee at 5).2 At this juncture in the proceedings, these lurid details are unnecessary to the determination of whether Jane Doe 3 and Jane Doe 4 should be permitted to join Petitioners? claim that the Government violated their rights under the CVRA. The factual details regarding with whom and where the Jane Does engaged in sexual activities are immaterial and impertinent to this central claim that they were known victims of Mr. Epstein and the Government owed them CVRA duties), especially considering that these details involve non?parties who are not related to the respondent Government. These unnecessary details shall be stricken. The original Rule 21 Motion (DE 279) shall be stricken in its entirety, as it is wholly superseded by the ?corrected? version of the Rule 21 Motion (DE 280). From the corrected Rule 21 Motion, the Court shall strike all factual details regarding Jane Doe 3 between the following sentences: ?The Government then concealed from Jane Doe #3 the existence of its NPA from 2 Jane Doe 4?s proffer is limited to sexual acts between Mr. Epstein and herself. (E DE 280 at 7-8). Case acactiemsa??w. Warrant am O?matgale?i Page a of 10 Jane Doe in violation of her rights under the (Q at and ?The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the (i at 6). As none of Jane Doe 4?s factual details relate to non-parties, the Court ?nds it unnecessary to strike the portion of the Rule 21 Motion related to her circumstances. Regarding the Declaration in support of Petitioners? response to Mr. Dershowitz?s motion to intervene (DE 291-1), the Court shall strike paragraphs through 53, and 59, as they contain impertinent details regarding non-parties. Regarding the Declaration of Jane Doe 3 in support of the Rule 21 Motion (DE 310-1), the Court shall strike paragraphs 7 through 12, 16, 39, and 49, as they contain impertinent details regarding non- parties. Jane Doe 3 is free to reassert these factual details through proper evidentiary proof, should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a matter presented for the Court?s consideration. As mentioned, Mr. Dershowitz moves to intervene ?for the limited purposes of moving to strike the outrageous and impertinent allegations made against him and requesting a show cause order to the attorneys that have made them.? (DE 282 at 1). As the Court has taken it upon itself to strike the impertinent factual details from the Rule 21 Motion and related ?lings, the Court concludes that Mr. Derschowitz?s intervention in this case is unnecessary. Accordingly, his motion to intervene will be denied as moot.3 Regarding whether a show cause order should 3 This also moots Mr. Dershowitz?s Motion for Leave to File Supplemental Reply in Support of Motion for Limited Intervention. (DE 317). Denying Mr. Dershowitz?s motion to intervene also renders moot Petitioners? motion (DE 292) to ?le a sealed document supporting its response to Mr. Dershowitz?s motion. It will accordingly be denied as moot, and DE 293 (the sealed response) will be stricken from the record. Case aoawcvlaea?sax??m mm eeweamgeamwam Page 7 of in issue, the Court ?nds that its action of striking the lurid details from Petitioners? submissions is sanction enough. However, the Court cautions that all counsel are subject to Rule 11?s mandate that all submissions be presented for a proper purpose and factual contentions have evidentiary support, Fed. R. Civ. P. 11(b)(1) and (3), and that the Court may, on its own, strike from any pleading ?any redundant, immaterial, impertinent, or scandalous matter,? Fed. R. Civ. P. 12(f). B. Rule 15 Motion Between their two motions (the Rule 21 Motion and Rule 15 Motion), Jane Doe 3 and Jane Doe 4 assert that ?they desire to join in this action to vindicate their rights [under the as well.? (DE 280 at 1). Although Petitioners already seek the invalidation of Mr. Epstein?s non-prosecution agreement on behalf of all ?other similarly?situated victims12, 15, 18-19), Jane Doe 3 and Jane Doe 4 argue that they should be fellow travelers in this pursuit, lest they ?be forced to file a separate suit raising their claims? resulting in ?duplicative litigation? (DE 280 at 11). The Court ?nds that justice does not require adding new parties this late in the proceedings who will raise claims that are admittedly ?duplicative? of the claims already presented by Petitioners. The Does? submissions demonstrate that it is entirely unnecessary for Jane Doe 3 and Jane Doe 4 to proceed as parties in this action, rather than as fact witnesses available to offer relevant, admissible, and non-cumulative testimony. (See, DE 280 at 2 (Jane Doe 3 and Jane Doc 4 ?are in many respects similarly situated to the current victims?), 9 (?The new victims will establish at trial that the Government violated their CVRA rights in the same way as it violated the rights of the other victims?), 10 (Jane Doe 3 and Jane Doe 4 ?will simply join in motions that the current victims were going to file in any event?), 11 (litigating Jane Doe 3 and Case Managua ara camaraara: Page a of in Jane Doe 4?s claims would be ?duplicative?); DE 298 at 1 n.1 (?As promised . . . Jane Doc No. 3 and Jane Doc No. 4 do not seek to expand the number of pleadings ?led in this case. If allowed to join this action, they would simply support the pleadings already being ?led by Jane Doe No. 1 and Jane Doc No. DE 311 at 5 n3 four victims (represented by the same legal counsel) intend to coordinate efforts and avoid duplicative pleadings?), 15 (Jane Doc 3 and Jane Doc 4 ?challenge the same secret agreement the NPA that the Government executed with Epstein and then concealed from the victims. This is made clear by the proposed amendment itself, in which all four victims simply allege the same general As the Does argue at length in their Rule 15 Motion, Jane Doe 1?s original petition ?speci?cally allege[s] that the Government was violating not only her rights but the rights of other similarly-situated victims.? (DE 311 at 2). The Court fails to see why the addition of ?other similarly-situated victims? is now necessary to ?vindicate their rights as well.? (DE 280 at 1). Of course, Jane Doe 3 and Jane Doc 4 participate in this litigated effort to vindicate the rights of similarly situated victims there is no requirement that the evidentiary proof submitted in this case come only from the named parties. Petitioners point out as much, noting that, regardless of whether this Court grants the Rule 15 Motion, ?they will call Jane Doc No. 3 as a witness at any trial.? (DE 311 at 17 n7). The necessary ?participation? of Jane Doc 3 and Jane Doc 4 in this case can be satis?ed by offering their properly supported and w, admissible, and non-cumulative testimony as needed, whether through testimony at trial DE 280 at 9) or af?davits submitted to support the relevancy of discovery requests4 4 The non-party Jane Does clearly understand how to submit af?davits. See DES 291-1, 310-1). Case aeamctiee?se??w. Wigwam sea Demetaalaa Page a of (L at 10). Petitioners do not contend that Jane Doe 3 and Jane Doe 4?s participation in this case? can only be achieved by listing them as parties. As it stands under the original petition, the merits of this case will be decided based on a determination of whether the Government violated the rights of Jane Doe 1, Jane Doe 2, and all ?other similarly situated victims? under the CVRA. Jane Doe 3 and Jane Doe 4 may offer relevant, admissible, and non-cumulative evidence that advances that determination, but their participation as listed parties is not necessary in that regard. Herring, 894 F.2d at 1024 (District court did not abuse its discretion by denying amendment where ?addition of more plaintiffs . . . would not have affected the issues underlying the grant of summary judgment?); c-_f Arthur v. Stern, 2008 WL 2620116, at *7 (SD. Tex. 2008) (Under Rule 15, ?courts have held that leave to amend to assert a claim already at issue in [another lawsuit] should not be granted if the same parties are involved, the same substantive claim is raised, and the same relief is And, as to Jane Doe 4 at least, adding her as a party raises unnecessary questions about whether she is a proper party to this action.6 Petitioners also admit that amending the petition to conform to the evidence by including references to the non-prosecution agreement itself is ?unnecessary? as the ?existing petition is broad enough to cover the developing evidence in this case.? (DE 311). The Court 5 The Court expresses no opinion at this time whether any of the attestations made by Jane Doe 3 and Jane Doe 4 in support of their motion will be relevant, admissible, and non- cumulative. 6 The Government contends that Jane Doe 4 is not a true ?victim? in this case because she was not known at the time the Government negotiated the non-prosecution agreement, and accordingly she was not entitled to noti?cation rights under the CVRA. (E DE 290 at 10). Any ?duplicative? litigation ?led by Jane Doe 4 would necessarily raise the issue of whether she has standing under the CVRA under these circumstances. 9 Case a? u. 327$. Page 10 of it) agrees, and it concludes that justice does not require amending the petition this late in the proceedings. 111. Conclusion Accordingly, it is hereby ORDERED AND ADJUDGED as follows: the Rule 21 Motion (DE 280) is the Rule 15 Motion (DE 311) is Intervenor Dershowitz?s Motion for Limited Intervention (DE 282) and Motion for Leave to File Supplemental Reply in Support of Motion for Limited Intervention (DE 317) are DENIED AS Petitioners? Motion to Seal (DE 292) is DENIED AS the following materials are hereby STRICKEN from the record: - DE 279, in its entirety. - DE 280, all sentences between the following sentences: ?The Government then concealed from Jane Doe #3 the existence of its NPA from Jane Doe in violation of her rights under the (DE 280 at Q1 ?The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment 291-1, paragraphs through 53, and 59. - DE 310-1, paragraphs 7 through 12293, in its entirety. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 6&1 day of April, 2015. KENNETH A. MARRA United States District Judge 10 Case 18-2868, Document 278, 08/09/2019, 2628230, Page43 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page44 of 648 From: <ross acuit re utation.com> Date: 2 January 2015 at 20:33 Subject: Ghislaine Maxwell To: Rossacuity Gow bcc: P.Peachev?ilindeoendentcook. nick.sornmerlad@mirror.co.uk, clavidbrown@thetimes.co.uk, io?anne?igh?ibbcmouk To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts -so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschowitz is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. Sent from my Blackberry? wireless device Case 18-2868, Document 278, 08/09/2019, 2628230, Page45 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page46 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 THE HIGH COURT OF JUSTICE BENCH DIVISION Claim No. CR 2016?624 BETWEEN: VIRGINIA L. GIUFFRE Applicant, and ROSS GOW, Respondent. AND: UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, v. Case NO. 15-CV-07433-RWS Ghislaine Maxwell, Defendant. Friday, November 18, 2016 AT: 8:27 a.m. Taken at: Essex Chambers 29, 81 Chancery Lane, London, UK, WC2A Court Reporter: Lisa Barrett, Accredited Realwtime Reporter DTI Court Reporting Solutions New York 1?800-325m3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page47 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page Appearing for the Plaintiff: MEREDITH L. SCHULTZ, ESQ. BOIES, SCHILLER FLEXNER 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 333 DAVID TURNER, ESQ. BOIES, SCHILLER FLEXNER 25 Old Broad Street London, UK EC2N Counsel for Defendant, Ghislaine Maxwell: LAURA A. MENNIGER, P.C. HADDON, MORGAN and FOREMAN, P.C. 150 East Tenth Avenue Denver, CO 80203 Counsel for Defendant, Ross Ne (witness): RICHARD SPEARMAN, Q.C. PHILIP BARDEN, DEVONSHIRES SOLICITORS LL 30 Finsbury Circus, London EC2M 7DT, UK Examiner: ALLEN DYER, 4 Pump Court Temple, London, EC4Y 7AN DX 303 LDE LLP 01 (UK) LLP il Sutherland Gow DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page48 of 648 Ross NEIL SUTHERLAND GOW 11/18/2016 Page 3 I I 2 Witness Page 3 ROSS NEIL SUTHERLAND GOW (sworn) lO 4 Examination by Ms. Schultz 10 5 Examination by Ms. Menninger 117 6 Re?examination by Ms. Schultz 119 7 8 I I I 9 No. Description Page 10 1 Consent Order before Master Fontaine 11 11 2 Email from ross@acuityreputation.com to 13 12 Ross@acuity.com, bcc: 13 14 P.Peachy@indepedent.co.uk, 15 Nick.sommerland@mirror.co.uk, 16 david.brown@thetimes.co.uk, 17 Nick.a1way@bbc.co.uk, 18 19 dated 2 January 2015, 20 Bates No. 21 3 Email from James Ball to Ross Gow, 30 22 dated 1 January 2015, 23 Bates NO. 24 25 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page49 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 4 X-H I I I 2 No. Description Page 3 4 Email from Ross Gow to Max, 35 4 cc Brian Basham, dated January 2, 2015, 5 Bates No. 6 5 Email from ross@acuityreputation.com, 37 7 to Max, sent Friday, January 2, 2015, 8 Fw: The Times David Brown, Bates No. 9 10 6 Email from ross@acuityreputation.com 38 11 to Max, sent Friday, January 2, 12 2015, Subject: Agreed copy, 13 Bates Nos. 14 7 Email from ross@acuityreputation.com 40 15 to Max, sent Friday, January 2, 16 2015, Subject: Re: Agreed copy, 17 Bates No. GMm01040?0104l 18 8 Email from ross@acuityreputation.com 42 19 dated Friday, January 2, 2015, 20 To: Max, Bates NO. 21 9 Email from ross@acuityreputation.com, 44 22 dated 2 January 2015, To: Max 23 gmax1@ellmax.com, Cc: Philip 24 IBarden, 25 Bates Nos. _00009 1?800-325-3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page50 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 5 1 I I I 2 No. Description Page 3 10 Email from gmaxl@ellmax.com, sent: 50 4 Saturday January 10, 2015, 5 To Philip Barden; Ross Gow, 6 Bates 7 11 Email chain, latest in time from 54 8 Maxwell to Jep, sent 9 Sunday, January 11, 2015, Bates Nos. 10 11 12 Email chain, latest in time from 60 12 Jeffrey jeevacation@gmail.com, 13 dated Sunday, January 11, 2015, 14 7:15 to Maxwell, Bates 15 Nos. 16 13 Email chain, latest in time from 65 17 Jeffrey jeevacation@gmail.com, '18 sent Wednesday, January 21, 2015 19 4:47 p.m. To: Maxwell, Bates 20 NOS. 21 22 23 24 25 1?800-325?3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page51 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 6 I I I 2 No. Description Page 3 14 Email chain, latest in time from 68 4 Nick Sommerlad, dated 2 January 2015, 5 21:45, To ross@acuityreputation.com 6 Bates Nos. 000004, one page 7 15 Email from Ross Gow dated Saturday, 71 8 3 January 2015, To David Mercer, Bates Nos. 9 10 16 Email string from Ross Gow to Max; 73 11 Philip Barden, dated Tues, 12 February 24, 2015, Bates Nos. 13 one page 14 17 Email from MaxWell to Ross Gow, 75 15 dated Thurs February 26, 2015, 16 Bates Nos. 17 18 Email from Ross Gow to Maxwell, 77 18 dated Thursday, February 26, 2015, 19 Bates NOS. 20 19 Email from Ross Gow to Max; 78 21 Philip Barden, dated Wednesday, 22 April 8, 2015, Bates Nos. 23 24 25 DTI Court Reporting Solutions New York 1?800n325?3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page52 of 648 Ross NEIL SUTHERLAND GOW 11/18/2016 Page 7 1 I I I 2 No. Description Page 3 4 20 Email from Max to Ross Gow; 79 5 Philip Barden, dated Wednesday, 6 May 6, 2015, Bates Nos. 7 21 Email chain, latest in time from 81 8 Ross Gow to Maxwell; Philip Barden, 9 dated Wednesday, May 6, 2015, Bates Nos. 10 11 22 Email from Ross Gow to Scott Adam, 82 12 dated Wednesday, May 6, 2015, 13 Bates No. 14 23 Website print out Bates No. 82 15 GUIFFRE008453 16 24 Website printout, Bates Nos. 93 17 two pages 18 25 Email from Ross Gow to Max, 100 19 Philip Barden, Bates Nos. 20 26 Website screenshot printout of 109 21 Acuity Reputation two pages 22 23 24 25 1?800-325-3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page53 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 8 1 I 2 THE VIDEOGRAPHER: Here begins video card 3 number 1, volume I, in the video deposition of Ross Gow. 4 This is taken in the matter of Virgina Guiffre 5 and Ross Gow. This is being heard in the High Court of 6 Justice, Queen's Bench Division, Senior Master, claim 7 number ,8 Today's date is November 18, 2016. The time on 9 the video screen is 08:26 local time in London. 10 The video operator today is Phillip Hill from 11 DTI Court Reporting Solutions. 12 The court reporter is Lisa Barrett from DTI 13 Court Reporting Solutions. 14 This video deposition is taking place at the 15 Essex Chambers in London. 16 I will now hand over the proceedings to the 17 Examiner. Thank you, sir. 18 MR. DYER: Would counsel or lawyers present, 19 please identify themselves for the record, first? 20 MS. SCHULTZ: I'm Meredith Schultz from Boise 21 Schiller and Flexner LLP, appearing for the Plaintiff, 22 Ms. Virginia Guiffre. With me is my colleague, David 23 Turner, also from Boies, Schiller and Flexner LLP. 24 MS. MENNINGER: I'm Laura Menninger from 25 Haddon, Morgan and Foreman on behalf of Ghislaine' DTI Court Reporting Solutions - New York 1?800?325w3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page54 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page worse objection, or worse grounds for me. MR. DYER: I think questions of payment do not fall within the sc0pe. BY MS. SCHULTZ: Q. Okay. Are you currently retained by Ms. Maxwell for professional services. A. If I could go back to my previous answer, Ms. Maxwell is a project client, and it's on a day rate. If so, for the sake of argument between 2nd of January 2015 and the of February 2016 we were quite busy answering these incoming calls, so there was quite a lot of work at that point in time. Recently there's been no work. There's been no need because the press activity has died down, our function is somewhat redundant. Q. Can you estimate the last time that you worked on this account at your day rate? A. It would have been in 2015. Probably April, May, something like that. No invoices, no no payment in 2016 from my recollection. BY MS. SCHULTZ: Q. Mr. Gow, I'm going to hand you another document. (Exhibit 3 was marked for identification.) MS. SCHULTZ: Point of procedure: I have only three copies of these documents for each of the 1?800-325?3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page55 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 31 remaining, I've marked as Exhibit 3 Do you recognize this email? A. I do. Q. Did you receive this email? A. I did, on the on New Year's Day 2015. Q. Did you contact Ms. Maxwell after receiving this email? A. I did. Q. Did you make any response to Mr. Ball in any form? A. I did. Q. Can you tell me what you w~ what response you made? A. Well, the response to Mr. Ball was part of a series of responses having spoken to my client within 24 hours or so, we got back to Mr. Ball with an agreed statement which went out to a number of media. Q. When you say "agreed statement" can you tell me more about what you mean? Who agreed to the statement? A. I need to give you some context, if I may, about that statement. So, this is on New Yearls Day. I was in France so the email time here of 21:46, in French time was 22:46, and I was getting up early the next DTI Court Reporting Solutions New York 1?800?325a3376 0&5& 0&5& 0&5& 0&5& 0&5& 0&5& 0&5& 0&5& 0&5& 0&5% 0&5% 0&5% 0&5? 0&5% 0&5? 0&5% 0&5% 0&5% 0&5% 0&5% 0&5% 010m 010m 010m 010m 01 10 Case 18-2868, Document 278, 08/09/2019, 2628230, Page56 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page morning to drive my family back from the south of France to England, which is a 14?hour journey, door to door. 80 on the morning of the 2nd of January, bearing in mind that Ms. Maxwell, I think was in New York then, she was five hours behind, so there was quite a lot of, sort of time difference between the various countries here, I sent her an email, I believe, saying parsing this forwarding this email to her saying "How do you wish to proceed?" And then I was on the telephone a? I had two telephones in the car, I received in excess of 30 phone calls from various media outlets on the 2nd of January, all asking for information about how Ms. Maxwell was looking to respond to the latest court filings, which were filed on the 30th of December as I understand. And by close towards close of play on the 2nd, I received an email forwarded by Ms. Maxwell, containing a draft statement which my understanding was the majority of which had been drafted by Mr. Barden with a header along the lines of "This is the agreed statement." At close of play on the 2nd. So I I was I had gone under the Channel Tunnel and I was sitting on the other side and that email, which my understanding was that it had 1?800?325-3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page57 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page been signed off by the client, effectively, was then sent out to a number of media, including Mr. Ball and various other UK newspapers. Q. Mr. Gow, when you say "end of play" and "close of play," are you referring to sending the email that's Exhibit 2? A. Yes, I am. MR. DYER: My understanding is that it went to people other than those listed? THE WITNESS: Yes, that is MR. DYER: Just a sample. THE WITNESS: That is a sample. Everyone who effectively well, the detail on this, I was driving, so my eldest son in the back had my BlackBerry and was trying to capture it was a pretty chaotic day. Most people in the UK were on holiday. In fact, it was a holiday weekend, our office was closed, my PA was on holiday, so my son was basically doing an internship in the back of the car, downloading the names of the callers from various media outlets and so we had a list of those so when I got to the car park, at the end of the Eurotunnel thing in the UK, I had numerous names, so the email went out to a wide range of people. But the 30 or so calls I had is an aggregate number, so there might have been five calls from the BBC 1-800-325?3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page58 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page from different people so they the BBC would only write one story, there wouldn?t be five versions of it, so 30 is an aggregate number. BY MS. SCHULTZ: Q. Okay. Looking again at Exhibit 2, could you please review the individuals or email addresses of the -- listed in the "To" and "bcc" portion? A. Yep. Q. Did you send this written statement to any other individuals or entities who are not listed in that portion? A. Within f? within 24 hours of this, yes, a wider range of people, definitely. This was the initial these are the most pressing ones, who said they were going to write a story whether they had if I could just explain a bit more context again in the world of PR. When you are in the field you're engaged and you?ve just you?ve got to prioritize who you spoke to and whoever shouts the loudest usually gets responded to first. So the reason there are two BBC people there for instance, is there's BBC broadcast radio, and BBC TV, and they were coming at from different angles for different stories, but there was a certain sense of urgency and immediacy. So the half a dozen 1-800?325-3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page59 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page here were the ones that we prioritized to deal with that night because they were publishing the next day or or thereabouts, but for instance we also spoke to the Daily Express. I can't remember the name of the gentleman there, or the lady, but I remember that was early the next morning when we got on to other channels. Q. So you sent this statement to additional individuals on January 3rd? A. Not just on January 3rd. I mean, as we had an agreed statement there, and I do recall there is a typo in this which is "Virginia" and "Victoria" there was a transposition there. So the original email went out with the typo because that was taken from the the statement that I believe Mr. Barden was broadly the architect of, but forwarded by Ms. Maxwell. 80 I just I took that as a verbatim statement and sent it out. I re?read it in the calm light of day the next morning. There was at least one typo in it so I changed that and reached out, again, to these people, updating the typo and sent it out to additional people. BY MS. SCHULTZ: Q. Mr. Gow, I?m going to hand you another document. I'm going to mark this as Exhibit 4. (Exhibit 4 was marked for identification.) DTI Court Reporting Solutions New York 1?800-325-3376 09?4 09?4 09?4 010k 010k 010% 0%0& 0105 09?5 0%0& 0%0& 0%0& 0%0& 0%0& 0% Case 18-2868, Document 278, 08/09/2019, 2628230, Page60 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 36 BY MS. SCHULTZ: Q. This is a document that is Bates labeled A. Thank you. Q. The top email on this document says ?From: Ross Gow.? Did you send this email? A I believe I did, yes. Q. Did you send it to Ms. Maxwell? A Yes. Q. In the "To? field, when it says Max," do you recognize that to be Ms. Maxwell's email address? A. Yes. Q. In the second paragraph of this email it states: "Please advise how you wish to handle this [As read] Did you receive a response from Ms. Maxwell? A. Bearing in mind I was driving all that day, I can't recall what the exact response was but from memory, it was along the lines of she would get back to me with how she wished to proceed. BY MS. SCHULTZ: Q. Okay. Mr. Gow, I'm going to hand you another document. I'm going to mark it as Exhibit 5. DTI Court Reporting Solutions New York 09:07: Case 18-2868, Document 278, 08/09/2019, 2628230, Page61 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 122 had existing authorization to make statements on Ms. Maxwell?s behalf due to the reauthorization letter; is that correct? A. I believe that from the 2nd of January 2015, I had an ongoing re?established authority to represent her, within the parameters of the 2011, 2015 press releases, there or thereabouts. MS. SCHULTZ: Mr. Dyer, I have no further questions. MR. DYER: Thank you. That concludes your deposition. THE WITNESS: Thank you, sir. MR. DYER: Thank you very much. THE VIDEOGRAPHER: Going off the record, the time is 11:39. End of video card number 3, volume I, and end of the video deposition of Ross Gow. (Whereupon, the deposition concluded at 11:39 Wax/M Lisa Barrett, RPR, CRR, CRC, CSR Certified Real?time Court Reporter DTI Court Reporting Solutions New York 1?800?325?3376 ?9?8 ?9?l ?9?4 :3%15 :3990 3930 :3935 ?936 ?938 ?939 39%0 ?9?l Case 18-2868, Document 278, 08/09/2019, 2628230, Page62 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 123 Subscribed and sworn to before me this 2 20th day of November, 2016DTI Court Reporting Solutions New York 1?800?325w3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page63 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 124 CERTIFICATE OF DEPONENT I, ROSS NEIL SUTHERLAND GOW, hereby certify that I have read the foregoing pages, numbered 1 through 122 of my deposition of testimony taken in these proceedings on this 18th day of November, 2016 and with the exception of the changes listed on the next. page and/or corrections, if any, find them to be a true and accurate transcription thereof. DTI Court Reporting Solutions New York 1?800?325w3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page64 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 125 CERTIFICATE OF EXAMINER I, ALLEN DYER, of 4 Pump Court Temple, London, EC4Y 7AN DX 303 LDE have been appointed as Examiner herein pursuant to an Order of Master Fontaine dated 29 September 2016. It has been agreed by all parties herein that the evidence of the witness, ROSS NEIL SUTHERLAND GOW, should be taken down in shorthand and that the transcript of the said nOtes of evidence should be deemed to be the deposition of the said witness. I certify that, the oath having been duly administered, the witness has been examined pursuant to the said order. The pages of transcript annexed hereto were furnished to me by DTI, Lisa Barrett, Accredited Realwtime Reporter, as containing the transcript of the notes of the evidence of the witness pursuant to the order. DTI Court Reporting Solutions New York 1?800?325m3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page65 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 126 10CERTIFICATE OF DEPONENT I, Ross Neil Sutherland Gow, hereby certify that I have read the foregoing pages, numbered 1 through 122, of my video deposition of testimony taken in these proceedings on this 18th day of November, 2016 and, with the exception of the changes listed on the next page and/or corrections, if any, find them to be a true and accurate transcription thereof. DTI Court Reporting Solutions New York 1~800~325~3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page66 of 648 R088 NEIL SUTHERLAND GOW - 11/18/2016 Page 127 CERTIFICATE OF COURT REPORTER I, Lisa M. Barrett, an Accredited Real?time Reporter, hereby certify that the testimony of the witness Ross Neil Sutherland Gow in the foregoing transcript, numbered pages 1 through 122, taken on this 18th day of November, 2016 was recorded by me in machine shorthand and was thereafter transcribed by me; and that the foregoing transcript is a true and accurate verbatim record of the said testimony. I further certify that I am not a relative, employee, counsel or financially involved with any of the parties to the within cause, nor am I an employee or relative of any counsel for the parties, nor am I, in any way, interested in the outcome of the within cause . Wm Signed Name: Lisa M. Barrett, RPR, CRR, CRC, CSR Date: November 30th 2016 DTI Court Reporting Solutions New York 1?800?325?3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page67 of 648 Forwarded message Finn: James Ball <james.ball@lhegnardian.com> Date: 1 January 2015 at 21:46 Subject: URGENT Ghislaine Maxwell To: ross@amityreputalion.com Dear Ross. I'm writing Io you as you have in the past represented Gbislaine Maxwell. As you are no doubt aware. fresh allegations have been levelled against Ms Maxwell in new US coun ?lings made in Florida on 30 December. which some outlets lave already been reponed. I would urgently see]: any comment on behalf of your client. or noti?cation of her new lepresentan'nn if you no longer act for her. Many thanks for your help. James EXHIBIT LL Case 18-2868, Document 278, 08/09/2019, 2628230, Page68 of 648 From: Ross Gow <ross@acuityreputation.com> Sent: Friday, January 02, 2015 1:07 AM To: Max Cc: Brian Basham Subject: Fwd: URGENT - Ghislaine Maxwell Hi Ghislainc James Ball, investigative reporter for The Guardian, who reports on US stories, has made contact, as per below. Please advise how you wish to handle this. am driving all day today, but can be contacted on +44 (0) 7778 755 251 Best Ross Forwarded message From: James Ball Date: 'l?hursday, January 1, 20 5 Subject: URGENT - Ghislaine Maxwell To: rossfmaeuitvrenutationxom Dear Ross. ?hislaine Maxwell. As you are no doubt aware, fresh 'n new US court ?lings made in Florida on 30 December, I'm writing to you as you have in the past allegations have been levelled against which some outlets have alread be I would urgently seek an longer act for her. Many thanks for your help, James huts"; Project; {Editor 203 353$ 295 i 7540 $5125 . Visit theguardiancom. On your mobile and tablet. download the Guardian iPhone and Android apps theguardian.com/guardianagg and our tablet editions theguardian.com/editions. Save up to 57% by subscribing to the Guardian and Observer - choose the papers you want and get full digital access. Visit Subscribe.theguardian.com PRIVILEGED EXHIBIT CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page69 of 648 This e-mail and all attachments are con?dential and may also be privileged. If you are not the named recipient, please notify the sender and delete the e-mail and all attachments immediately. Do not disclose the contents to another person. You may not use the information for any purpose, or store, or copy, it in any way. Guardian News Media Limited is not liable for any computer viruses or other material transmitted with or as part of this e-mail. You should employ virus checking software. Guardian News Media Limited is a member of Guardian Media Group plc. Registered Office: PO Box 68164, Kings Place, 90 York Way. London, N1 ZAP. Registered in England Number 908396 Ross Gow Managing Partner ACUITY Reputation 23 Berkeley Square London W1J6HE +44 (0) 207 204 6! 10 +44 (0) 777 875 525! mob +7 903 363 5393 Mocrtaa ity reputation .com The information contained in this e-mail and any attachments is con?dential and may be privileged or otherwise protected from disclosure. It is intended solely for the attention and use of the named addressee(s). if you are not the intended recipient, dissemination, copying or use ofthis e-mail and any attachments in whole or in part is prohibited. if you have received the e-mail in error, please notify the sender and delete the e-mail and any attachments from your computer system. Whilst any attachments may have been checked for viruses, you should rely on your own virus checker and procedures. No responsibility is accepted by ACUITY Reputation Limited for loss or damage arising from the receipt or use ol? this e-mail. PRIVILEGED CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page70 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page71 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S RESPONSES AND OBJECTIONS TO DEFENDANT’S SECOND REQUEST FOR PRODUCTION AND DEFENDANT’S INTERROGATORIES, PLAINTIFF’S ANSWERS TO DEFENDANT’S REQUESTS FOR ADMISSION Pursuant to Federal Rules of Civil Procedure 26, 33, 34, Plaintiff hereby serves her responses and objections to Defendant’s Second Set of Discovery Requests and serves her Answers to Defendant’s Requests for Admission. GENERAL OBJECTIONS Defendant’s Discovery Requests violate Rule 33, Fed. R. Civ. P., which provides “a party may serve on any other party no more than 25 interrogatories, including all discrete subparts” – in that Defendant has served a total of 59 interrogatories in this case, including subparts, in violation of Rule 33. Ms. Giuffre objects to Defendant’s Second Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege, work product privilege, joint defense privilege, public interest privilege, and any other applicable privilege. 1 Case 18-2868, Document 278, 08/09/2019, 2628230, Page72 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) on hundreds (if not thousands) of matters, and collectively have well over 100 years of combined practice experience. Accordingly, a request that each of these attorneys list all communications with the media is facially overbroad. Additionally, Ms. Giuffre objects to this Interrogatory because a response would cause Ms. Giuffre the incredible and undue burden of having to catalogue literally hundreds of communications that she has already produced in this case. Moreover, Ms. Giuffre objects because this interrogatory calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Communications with the media regarding cases that bear no relation to the subject matter of this case, from decades in the past, are facially invalid and not calculated to lead to the discovery of admissible evidence. Ms. Giuffre additionally objects to the extent that this interrogatory seeks the communications of her attorneys, any author, reporter, correspondent, columnist, writer, commentator, investigative journalist, photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any media organization or independent consultant as such interrogatory is overly broad and unduly burdensome. Furthermore, Ms. Giuffre is not obligated to produce anything currently in the possession of Defendant Maxwell or her attorneys. Notwithstanding such objections, Ms. Giuffre has already produced her responsive communications, which are found in documents Bates labelled GIUFFRE000001 to GIUFFRE007566. 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Count I of Your Complaint, including: 5 Case 18-2868, Document 278, 08/09/2019, 2628230, Page73 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) a. the exact false statement; b. the date of its publication; c. the publishing entity and title of any publication containing the purportedly false statement; d. the URL or internet address for any internet version of such publication; and the nature of the publication, whether in print, internet, broadcast or some other form of media. Response to Interrogatory No. 6: Ms. Giuffre objects because the information interrogatory above is in the possession of Defendant who has failed to comply with her production obligations in this matter, and has failed to comply with her production obligations with this very subject matter. See Document Request No. 17 from Ms. Giuffre’s Second Request for Production of Documents to Defendant Ghislaine Maxwell.1 Maxwell has not produced all “URL or Internet addresses for any internet version of such publication” that she directed her agent, Ross Gow, to send. 1 Request No. 17 stated: Produce all documents concerning any statement made by You or on Your behalf to the press or any other group or individual, including draft statements, concerning Ms. Giuffre, by You, Ross Gow, or any other individual, from 2005 to the present, including the dates of any publications, and if published online, the Uniform Resource Identifier (URL) address. In response, Defendant stated: “Ms. Maxwell objects to this Request on the grounds that it is cumulative and duplicative. Ms. Maxwell also objects to this Request to the extent it calls for information that exists within the public domain, the internet or in public court records and which are equally available to both parties and can be obtained from some other source that is more convenient, less burdensome, and less expensive. Ms. Maxwell further objects to this Request to the extent it seeks documents or information protected by the attorney/client privilege, the work-product doctrine, or any other applicable privilege. Ms. Maxwell is not producing documents that are available in the public domain. Ms. Maxwell has been unable to locate any additional documents responsive to this Request.” 6 Case 18-2868, Document 278, 08/09/2019, 2628230, Page74 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Ms. Giuffre further objects because the information requested above is in the possession of Defendant’s agent, who caused the false statements to be issued to various media outlets. Ms. Giuffre has not had the opportunity to depose Maxwell’s agent Ross Gow; therefore, this answer remains incomplete. Consequently, Ms. Giuffre reserves the right to modify and/or supplement her responses, as information is largely in the possession of the Defendant and her agent. Ms. Giuffre objects to this interrogatory in that it violates Rule 33 as its subparts, in combination with the other interrogatories, exceed the allowable twenty-five interrogatories. Ms. Giuffre objects to this request because it is in the public domain. Ms. Giuffre also objects in that it seeks information protected by the attorney-client/work product privilege, and any other applicable privilege stated in the General Objections. Notwithstanding such objections, Ms. Giuffre has already produced documents responsive to this request; Bates labelled GIUFFRE000001 to GIUFFRE007566, and supplements such responsive documents with the following list of publications. While the identification of an exhaustive responsive list would be unduly burdensome, in an effort to make a good faith effort towards compliance, Ms. Giuffre provides the following examples, which are incomplete based on the aforementioned reasons: Date Nature Januar Internet y 2, 2015 Publishi ng Entity Ross Gow Statement/URL Jane Doe 3 is Virginia Roberts - so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms. Roberts that Alan Dershowitz is involved in having sexual relations with her, which he denies. Ms. Roberts’s claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at 7 Case 18-2868, Document 278, 08/09/2019, 2628230, Page75 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Januar the repetition of such old defamatory claims. http://www.telegraph.co.uk/news/uknews/theroyalfamily/11323872/PrinceAndrew-denies-having-relations-with-sex-slave-girl.html Internet Telegrap h Internet Express http://www.express.co.uk/news/world/550085/Ghislaine-Maxwell-Jeffrey-Epsteinnot-madam-paedophile-Florida-court-case-Prince-Andrew Internet Daily Mail http://www.dailymail.co.uk/news/article-2895366/Prince-Andrew-lobbiedgovernment-easy-Jeffrey-Epstein-Palace-denies-claims-royal-tried-use-influencehelp-billionaire-paedophile-2008-police-probe html Internet Huffingt on Post http://www.huffingtonpost.co.uk/2015/01/03/duke-of-york-sex-abuseclaims_n_6409508 html Internet Jewish News Online http://www.jewishnews.co.uk/dershowitz-nothing-prince-andrews-sex-scandal/ Internet Bolton News http://www.theboltonnews.co.uk/news/national/11700192.Palace_denies_Andrew_s ex_case_claim/ Januar Internet http://www.nydailynews.com/news/world/alleged-madame-accused-supplyingprince-andrew-article-1.2065505 y 5, / NY Daily News 2015 Broadca AOL UK http://www.aol.co.uk/video/ghislaine-maxwell-declines-to-comment-on-princeandrew-allegations-518587500/ y 3, 2015 Januar y 4, 2015 Januar y 3, 2015 Januar y 3, 2015 Januar y 4, 2015 Januar y 2, 2015 st Januar Internet y 5, / 2015 Broadca st 8 Case 18-2868, Document 278, 08/09/2019, 2628230, Page76 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 Telephone: (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 Telephone: (801) 585-5202 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 1, 2016, I electronically sent the foregoing document to the counsel below via e-mail. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: lmenninger@hmflaw.com 43 Case 18-2868, Document 278, 08/09/2019, 2628230, Page77 of 648 EXHIBIT I Case 18-2868, Document 278, 08/09/2019, 2628230, Page78 of 648 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: v. Ghislaine Maxwell, Defendant. SUPPLEMENTAL RESPONSES TO DEF INTERROGATORIES 6, 12 and 13 Pursuant to Federal Rules of Civil Procedure 26, 33, 34, Plaintiff hereby serves her supplemental responses to Defendant?s Interrogatories 6, 12 and 13. OBJECTION Plaintiff maintains and hereby incorporates by reference all applicable objections, including both general objections and speci?c objections to individual interrogatories, in her prior responses and objections served on Defendant in these supplemental responses. Defendant?s Discovery Requests violate Rule 33, Fed. R. Civ. P., which provides ?a party may serve on any other party no more than 25 interrogatories, including all discrete subparts? in that Defendant has served a total of 59 interrogatories in this case, including subparts, in violation of Rule 33. Ms. Giuffre objects to Defendant?s Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege, work product privilege, and any other applicable privilege. Case 18-2868, Document 278, 08/09/2019, 2628230, Page79 of 648 Jane Doc No. 102 v. Jeffrey Epstein, Case No. 09-80656-CIV-Marra/Johnson (Southern District of Florida). Accordingly, due to the undue burden of individually logging responsive, privileged documents related to Defendant?s overly-broad requests, Plaintiff has employed categorical logging of such privileged responsive documents pursuant to Local Civil Rule Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a minor victim of sexual traf?cking. Ms. Giuffre objects to the requests to the extent they are overly broad and unduly burdensomc. Ms. Giuffre?s responses to Defendant?s Second Set of Discovery Requests are being made after reasonable inquiry into the relevant facts, and are based only upon the information and documentation that is presently known to her. Ms. Giuffre reserves the right to modify and/or supplement her responses. Ms. Giuffre has produced documents and information in response to these Requests. Ms. Giuffre incorporates her above-listed general objections in the responses herein. SUPPLEMENTAL INTEROGATORY RESPONSES 6. Identify any ?false statements? attributed to Ghislaine Maxwell which were ?published globally, including within the Southern District of New York? as You contend in paragraph 9 of Court 1 of Your Complaint, including: a. the exact false statement; b. the date of its publication; c. the publishing entity and title of any publication containing the purportedly false statement; d. the URL or internet address for any internet version of such publication; and e. the nature of the publication, whether in print, internet, broadcast or some other form of media. Case 18-2868, Document 278, 08/09/2019, 2628230, Page80 of 648 In addition to her previous response, Ms. Giuffre supplements the response to include: January 8, 2015 Internet The Sun 28 508300-Editorial-TWITTER- TheSunNewspaper-ZO 1 50108-News 12. Identify any Health Care Provider from whom You received any treatment for any physical, mental or emotional condition, including addiction to alcohol, prescription or illegal drugs, that You suffered from subsequent to the Alleged Defamation by Ghislainc Maxwell, including: a. the Health Care Provider?s name, address, and telephone number; b. the type of consultation, examination, or treatment provided; c. the dates You received consultation, examination, or treatment; d. whether such treatment was on an in?paticnt or out-patient basis; e. the medical expenses to date; f. whether health insurance or some other person or organization or entity has paid for the medical expenses; and g. for each such Health Care Provider, please execute the medical and mental health records release attached hereto as Exhibit A. Supplemental Response to Interrogatorv No. 12: Ms. Giuffre objects to this interrogatory in that it is overbroad and not limited in scope to the medical information relating to the abuse she suffered from Defendant and Jeffrey Epstein. Pursuant to the Rules, if requested documents are not yielded in a ?reasonable inquiry,? Ms. Giuffre is not obligated to expend all of her time and resources on a quest to gather medical ?les that are unknown to her or unaccessable after reasonable inquiry. See, e. Manessis v. New York City Dep't 0fTrar1sp., No. 02 359SASDF, 2002 WL 31 1 15032, at *2 (S.D.N.Y. Sept. 24, 2002) Case 18-2868, Document 278, 08/09/2019, 2628230, Page81 of 648 - Medicare Ami rulia ptovidcd health care insu: ante covaagc and men: for service: modved in Australia from July 19, 201.: thrust: the M: Giu??re?s claims histmy ?n thir. pmiud i2. 461:1in (ill 7021} Dr. Walt Walt San, Central (?oast Family Mcdicim:= Unit 2, l7 Anzac Rd, Tuggcrah 22?0_ 024 :5 2:0,:ch Ms (iiul'?c Mauh 14,. 201.3, in panic attacks as dmibed in the Mica! ward: produced at and pcm'xbly September I 301 for ?Standard Constantin? 'I'hm?e maids have requcstcai and a release sent to the pun-idea Pharmacy provided prescribed medicatims In Ms Giuf?'c as in the rounds. produced at i 08 H??valgreens Pharmacy may has proviticd Imam ihcd nwdiru?ms to M3. Giu?'we Those records haw hem and a rdcase wm?uitxl the. plum Imtu?. u?c' I N3 - Dr. ?imothy I). Ha rtwig, D1). was identi?ed in records produced by pharmacy. Ms (Shuf?e has smu?su'? ?knit m. d3. m- (ill 3-:6 {?18 0 Dr. James Nicnoss, MB was identi?ed in records gum-ed by pharmacy. Ms hm: letllk??lcd Mu 3?3] - Dr. Rodo??o "terms Jr, 51.0. ?as udcn?liui plodu'cc-tl by plwmacv Ms Giuf?c has requested those teams. we (in 8354 Dated Augmlf?zm? Signed. - '5 \y - Virgi nia (iiu?lc Roc'md': Mcdmaic Ausua?a aw. gent-mus Emil-:d I wan. Mn. (Shuffle is ?manning addltumad [cmld? mm: min: hub. 19. 20}. lhmugi: that In Annual?: Ms Ulu?'tc now Wah Walt Kan and DI was Sun In be thu- w'nc ptmidct smite but ofhcr knowledge She had pm?iousiy Eistcd both name." in an mmdancc of minim befor: Immune that Dr San NE: in: same [um-id? Dt Wall th San Case 18-2868, Document 278, 08/09/2019, 2628230, Page82 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page83 of 648 DISTRICT RT DISTRICT TURF. Ill-Inn'r'r-Ir-- . n. - VIIEGIHM. L- v- GI MAKWELL lleclarn?nn of (ihislninc Man-4'35; {?rhislaine Mam-tell- d?clarnz as fniiows; 1- I am thn: in this. anti-an. 2. i haw: nu mum} authu?ljur uvcr any ma?a urguni'wiiuns, including muse media urganizatj?ns ?'lat publishmi an}.r purl. UH. January 2015 i?tiutfj Uf'l n1}- behalf T116 dirwllun 13-1? my Minn-Lay, Philip Elan-11m. Neither I nun-r any" agent acting {an h?half appmved in an}: nt'any media urganiza?nn in its decisiml tn publish at mat [a publish any purl Gf 111:: Janlmn' 2015 I dualism undicr pcnallj' ui'ptljuq- Haul Um: Ibrcguing is Inn: and annual. ExL-uulcd mum la.- E?l T- (ihislaine: Mac-:Mall Case 18-2868, Document 278, 08/09/2019, 2628230, Page84 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page85 of 648 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X Plaintiff, v. GHISLAINE MAXWELL, Defendant. .......................................... VIRGINIA L. GIUFFRE, 15-cv-07433-RWS --------------------------------------------------X Declaration of Philip Barden I, Philip Barden, declare as follows: 1. I am a Solicitor of the Senior Courts of England & Wales based in London, England. 2. I am submitting this Declaration in support of Ghislaine Maxwell’s motion for summary judgment in this action. 3. I am not authorised to and do not waive Ms. Maxwell’s attorney-client privilege. 4. I have represented Ms. Maxwell since 2011 regarding the allegations made by Plaintiff Virginia Giuffre and as published in the United Kingdom. I continue to be retained in this regard. I am familiar generally with the subject matter of this action. 5. I first represented Ms. Maxwell in this matter over the weekend of 5th and 6th March 2011, about the time when various UK national newspapers, in hard copy and on line, published numerous and provocative allegations made by the Plaintiff Virginia Giuffre against Ms. Maxwell. The articles by Sharon Churcher were among those published in this time frame. 6. I instructed British press agent Ross Gow to assist me in representing Ms. Maxwell. 1 Case 18-2868, Document 278, 08/09/2019, 2628230, Page86 of 648 7. I caused to be prepared a statement to respond to the articles that appeared in the British Press over the weekend—March 5 and 6, 2011, and thereafter. I directed Mr. Gow to distribute the statements to various media outlets that had published articles. 8. On December 30, 2014, Ms. Giuffre made numerous salacious and improper allegations against Ms. Maxwell in a joinder motion publicly filed in a civil case involving Jeffrey Epstein. Shortly afterward, the British media gained access to the motion and began inquiring about Ms. Maxwell’s response. 9. I continued to represent Ms. Maxwell at that time and I coordinated the response to the media. I again instructed Mr. Gow to assist me. 10. In liaison with Mr. Gow and my client, on January 2, 2015, I prepared a further statement denying the allegations, and I instructed Mr. Gow to transmit it via email to members of the British media who had made inquiry about plaintiff’s allegations about Ms. Maxwell. Attached as Exhibit A1 is an email containing a true and correct copy of this statement. The statement was issued on my authority. Although it is possible others suggested or contributed content, I prepared the vast majority of the statement and ultimately approved and adopted all of the statement as my work. 11. As is evident from the timing and the typographical errors in the statement, I prepared the statement in haste. I was not in the office on 2nd January 2015 as it was the Friday immediately after New Years day which is a public holiday. Most people took 2nd January off and many business closed that day. I don’t now recall where I was that day but I was hard to reach and that indicates I was out with my family. I therefore would have prepared the statement in a hurry. I recall that I wanted to get a statement out as a matter of urgency. 12. I recall that immediately after Ms. Giuffre’s motion was filed, media representatives began contacting Mr. Gow and requesting Ms. Maxwell’s response to Ms. Giuffre’s allegations 2 Case 18-2868, Document 278, 08/09/2019, 2628230, Page87 of 648 of criminal and other misconduct by Ms. Maxwell. I believed an immediate response was imperative, even though this was happening in the midst of the holidays in the United Kingdom. My communications with Mr. Gow and with Ms. Maxwell were sporadic, delayed and hurried because of my and their own holiday schedules. I worked while on vacation and on Friday, January 2, 2015, to ensure that the statement was issued as soon as possible after receiving the media inquiries. 13. I did not ask Ms. Maxwell to respond point by point to Ms. Giuffre’s factual allegations in the CVRA joinder motion. What we needed to do was issue an immediate denial and that necessarily had to be short and to the point. It should have been obvious to the media that Ms. Giuffre’s new and significantly more salacious allegations had no credibility because they differed so substantially from her previous allegations, when she had the opportunity and incentive to disclose all relevant facts about being a victim of alleged sexual abuse and sex trafficking at the hands of the rich and powerful. I prepared the January 2015 statement based on my knowledge of Ms. Giuffre’s past statements and her most recent statements in the joinder motion, and made the point to the media-recipients that she and her new statements, which differed so substantially from her former ones, were not credible—specifically, that the new allegations were patently false—i.e., “obvious lies.” 14. By way of example I recall that prior to the December 2014 filing of the joinder motion and the subsequent press reports that Ms. Guiffre clearly stated she had not had sex with Prince Andrew. Yet in her joinder motion she claimed she did have sex with Prince Andrew and that the sex occurred in what can only be described as a very small bathtub, too small for a man of Prince Andrew’s size to enjoy a bath in let alone sex. So as of December 2014 it was clear Ms. Guiffre had made polar opposite statements. She was either lying when she said they did not have sex or when she said they did. I made the inescapable inference that she is a liar, as clearly 3 Case 18-2868, Document 278, 08/09/2019, 2628230, Page88 of 648 she is, since both statements cannot as a matter of fact be true. When someone says she did not have sex and then says she did, in other words, there is an obvious lie. 15. I did not intend the January 2015 statement as a traditional press release solely to disseminate information to the media. This is why I intentionally did not request that Mr. Gow or any other public relations specialist prepare or participate in preparing the statement. Instead, Mr. Gow served as my conduit to the media representatives who had requested a response to the joinder motion allegations and who I believed might republish those allegations. 16. My purpose in preparing and causing the statement to be disseminated to those media representatives was twofold. First, I wanted to mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff’s false allegations. I believed these ends could be accomplished by suggesting to the media that, among other things, they should subject plaintiff’s allegations to inquiry and scrutiny. For example, I noted that plaintiff’s allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” 17. Second, I intended the January 2015 statement to be “a shot across the bow” of the media, which I believed had been unduly eager to publish plaintiff’s allegations without conducting any inquiry of their own. This was the purpose of repeatedly stating that plaintiff’s allegations were “defamatory.” In this sense, the statement was very much intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff’s obviously false allegations and the legal indefensibility of their own conduct. 18. It is important to understand that any story involving a member of the Royal Family, especially a senior member such as Prince Andrew, gains huge media attention in the UK and a story alleging he had a sex with the Plaintiff caused a feeding frenzy for the press. I wanted the 4 Case 18-2868, Document 278, 08/09/2019, 2628230, Page89 of 648 press to stop and think before publishing, to cease and desist, and that if they continued then they faced higher damages for ignoring my clear warning. 19. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (italics supplied). The statement was intended to be a single, one-time-only, comprehensive response—quoted in full, if it was to be used—to plaintiff’s December 30, 2014, allegations that would give the media Ms. Maxwell’s response. The purpose of the prefatory statement was to inform the media-recipients of this intent. 20. Selective and partial quotation and use of the statement would disserve my purposes. It was intended to address Plaintiff’s behavior and allegations against Ms. Maxwell on a broad scale, that is to say, Plaintiff’s history of making false allegations and innuendo to the media against Ms. Maxwell. This is why the statement references Plaintiff’s “original allegations” and points out that her story “changes”—i.e. is embellished—over time including the allegations “now” that Professor Dershowitz allegedly had sexual relations with her. This is why I distinguished in the statement between Plaintiff’s “original” allegations and her “new,” joindermotion allegations, which differed substantially from the original allegations. And this is why I wrote, “Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by [Plaintiff] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies.” (Emphasis supplied.) Having established the dramatic difference between Plaintiff’s two sets of allegations, which suggested she was fabricating more and more-salacious allegations as she had more time to manufacture them, I added the third paragraph: “[Ms. Giuffre’s] claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory.” (Emphasis supplied.) I believed then, and believe now, that it was and remains a fair inference and conclusion that her claims 5 Case 18-2868, Document 278, 08/09/2019, 2628230, Page90 of 648 were and are “obvious lies.” As noted, her claims not to have slept with Prince Andrew and to have slept with Prince Andrew are a classic example of an obvious lie. One or other account is on the face of it a lie. 21. As an example of her lack of credibility, the Plaintiff made allegations against Professor Dershowitz, which I understand she has now withdrawn. Professor Dershowitz has credibility because his story, insofar as I am familiar with it, has been consistent; Ms. Giuffre has no credibility because her story has shifted and changed. 22. Further the Plaintiff’s account has become more salacious, for example, regarding Prince Andrew. The Plaintiff clearly has been seeking publicity for her story and it is clear to me that she understands retelling the same story doesn’t feed the media and generate publicity and so each time she appears to create new allegations to generate media interest. 23. I understand the Plaintiff alleged in her Complaint in this action that the following statements are defamatory. She alleges it was defamatory in the first paragraph of the January 2015 statement to state that “the allegations made by [the Plaintiff] against [Ms.] Maxwell are untrue.” For the reasons stated above, it was and is my considered and firm opinion that, in fact, her allegations are untrue. She alleges it was defamatory to state in the same paragraph that the “original allegations” have been “shown to be untrue.” For the reasons stated above, it was and is my considered and firm opinion that, in fact, her allegations are untrue. Finally, she alleges that it was defamatory in the third paragraph to state that her claims are “obvious lies.” For the reasons stated above, it was and is my considered and firm opinion that, in fact, her claims are obvious lies. 24. Both Mr. Gow and I understood that once the January 2015 statement was sent to the media-representatives, we had no ability to control whether or how they would use the statement and we made no effort to control whether or how they would use the statement. 6 Case 18-2868, Document 278, 08/09/2019, 2628230, Page91 of 648 25. It is my understanding that some of the media-recipients of the January 2015 statement did not publish any part of the statement. I am unaware of any media-recipient publishing the statement in full. 26. The issuance of the statement fully complied with my ethical obligations as a lawyer. Indeed it was duty in representing my client’s interests to ensure that a denial was immediately issued. I would have been remiss if I had sat back and not issued a denial, and the press had published that Ms. Maxwell had not responded to enquiries and had not denied the new allegations; the public might have taken the silence as an admission there was some truth in the allegations. 27. The content of the statement was entirely based on information I acquired in connection with my role as counsel for Ms. Maxwell. 28. At the time I directed the issuance of the statement, I was contemplating litigation against the press-recipients as an additional means to mitigate and prevent harm to Ms. Maxwell. Whilst the limitation period for a pure defamation claim has now expired, claims are still being considered for example for publishing a deliberate falsehood, conspiracy to inure and other tortious acts. 29. In any such UK defamation, or other related, action Ms. Giuffre would be a defendant or a witness. 30. I directed that the statement indicate Ms. Maxwell “strongly denie[d] the allegations of an unsavoury nature,” declare the allegations to be false, give the press-recipients notice that the publications of the allegations “are defamatory,” and inform them that Ms. Maxwell was “reserv[ing] her right to seek redress.” 7 Case 18-2868, Document 278, 08/09/2019, 2628230, Page92 of 648 I declare under penalty of perjury that the foregoing is true and correct. Executed on January 2017. A Philip Bardo?? Case 18-2868, Document 278, 08/09/2019, 2628230, Page93 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page94 of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ase 18-2868, Document 278, 08/09/2019, 2628230, Page95 of 648 , 1 ' ( ; 3$*( :,71(66 -DPHV 0LFKDHO $XVWULFK 'LUHFW ( DPLQDWLRQ E 0V 0HQQLQJHU &URVV ( DPLQDWLRQ E 0U (G DUGV 5HGLUHFW ( DPLQDWLRQ E 0V 0HQQLQJHU 5HFURVV ( DPLQDWLRQ E 0U (G DUGV , , 7 6 5HSRUWHU V &HUWLILFDWH &HUWLILFDWH RI 2DWK ( ; 3/$,17,)) )OLJKW ORJV '()(1'$17 3KRWRJUDSK 3DVVSRUW &LWDWLRQ 7UDGLQJ 5HSRUW 6FKRRO 5HFRUGV ( KLELWV DWWDFKHG 2 HQ 3 2 $VVRFLDWHV &RXUW 5HSRUWHUV R 2FDOD )ORULGD R HQDVVRFV DRO FRP 10 11 12 13 '14Case 18-2868, Document 278, 08/09/2019, 2628230, Page96 of 648 Broward and Miami a lot. -Q Okay. Where did you go to high school? A Robert Morgan. Which City is that in? A I guess Miami. Okay. When did you graduate? A '98. How old are you now? A 35. When is your birthday? A I O0 you remember a woman by the name of Virginia Roberts? A Yes. And do you see her here in the room today? A Yes. When was the last time that you saw her? A Sixteen years ago. How did you meet Ms. Roberts? A She was a friend of my sister's, and that's how I met her. What is your sister?s name? (phonetic). Last name is spelled abut I still can't spell it. My stepwsister. But after so long, she's basically my sister. Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 278, 08/09/2019, 2628230, Page97 of 648 Okay. Where is Ms. A I believe Broward County. How is it that she came to introduce you to Ms. Roberts?. A She brought her to the house. And do you know how they were friends? A They met each other in rehab. What kind of rehab? A I'm not sure. I was living in Miami at the time, and I only came up once in a while to visit her. At the very end, when I moved back to Broward with my dad, that's when- home. Do you know the name of the rehab program? A No. And you do you know what the rehab program was for, drugs, alcohol? A I don't know. I guess, everything probably. Do you recall approximately what year you met Ms. Roberts? A I believe around '98. How old were you at that time? A 18. Do you know how old Ms. Roberts wasbelieve. Was she approximately your sister?s age? Owen Associates Court Reporters P.O. 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'Irq.135; 9" MIMI l" was: --I it ?My. NiQ'a?j 1' . 2,82, 07 3 I 7 . gia?rv I. 1350.5409}. Ii" any}: I . . ..-.. . . 5 1- mum: i1 . ?33Personal Information . I'yfGIUFFREOO4721 Case 18-2868, Document 278, 08/09/2019, 2628230, Page126 of 648 EXHIBIT Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page127 of 648 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS __________________________________________________ CONFIDENTIAL VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE May 3, 2016 __________________________________________________ VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. __________________________________________________ APPEARANCES: FAMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. By Brad Edwards, Esq. 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954.524.2820 brad@pathtojustice.com Appearing on behalf of the Plaintiff BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. (For Portion) 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301-2211 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE 5/3/2016 1 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page128 of 648 1 2 3 4 5 6 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, Esq. Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant 7 8 Also Present: Brenda Rodriguez, Paralegal Nicholas F. Borgia, CLVS Videographer 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 2 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page129 of 648 1 Pursuant to Notice and the Federal Rules 2 of Civil Procedure, the VIDEOTAPED DEPOSITION OF 3 VIRGINIA GIUFFRE, called by Defendant, was taken on 4 Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150 5 East 10th Avenue, Denver, Colorado, before Kelly A. 6 Mackereth, Certified Shorthand Reporter, Registered 7 Professional Reporter, Certified Realtime Reporter 8 and Notary Public within Colorado. 9 * * * * * * * I N D E X 10 11 EXAMINATION PAGE 12 MS. MENNINGER 8 13 14 15 PRODUCTION REQUEST(S): (None.) 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 3 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page130 of 648 1 INDEX OF EXHIBITS 2 3 INITIAL REFERENCE DESCRIPTION 4 Exhibit 1 Complaint and Demand for Jury Trial re Jane Doe No. 102 v. Jeffrey Epstein 17 Exhibit 2 Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in Action 21 Exhibit 3 Declaration of Virginia L. Giuffre re Jane Doe #1 and Jane Doe #2 vs. United States of America 23 Exhibit 4 Declaration of Jane Doe 3 re Jane Doe #1 and Jane Doe #2 vs. United States of America 31 Exhibit 5 Declaration of Virginia Giuffre re Bradley J. Edwards and Paul G. Cassell vs. Alan M. Dershowitz 33 Exhibit 6 FBI documentation, date of entry 7/5/13 36 Exhibit 7 Document titled Telecon, Participants Jack Scarola, Brad Edwards, Virginia Roberts. Re Edwards adv. Epstein, 4/7/11, (23 pages of transcription) 39 Exhibit 8 The Billionaire's Playboy Club, By Virginia Roberts 41 Exhibit 9 Plaintiff's Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff re Giuffre v. Maxwell 44 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 4 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page131 of 648 1 2 INITIAL REFERENCE DESCRIPTION 3 Exhibit 10 Plaintiff's Supplemental Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff 46 Exhibit 11 Undated Declaration of Virginia Giuffre re Plaintiff's Supplemental Response and Objections to Defendant's First Set of Discovery Requests served on March 22, 2016 46 Exhibit 12 Plaintiff's Second Amended Supplemental Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff 47 Exhibit 13 Mrs. Virginia Giuffre resume 67 Exhibit 14 Compilation of e-mails re Open Position - Virginia Giuffre 68 Exhibit 15 Virginia Lee Roberts passport application 180 Exhibit 16 Composite of e-mail strings 251 Exhibit 17 Compilation of e-mails between Giuffre and Silva and others 259 Exhibit 18 Compilation of e-mails between Virginia Giuffre and Sandra White 265 Exhibit 19 Compilation of e-mails between Marianne Strong and Virginia Giuffre 269 Exhibit 20 Compilation of e-mails between Virginia Roberts and Jason Richards 276 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 5 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page132 of 648 1 2 INITIAL REFERENCE DESCRIPTION 3 Exhibit 21 Compilation of e-mails between Sharon Churcher and Virginia Giuffre Exhibit 22 Compilation of e-mails among 287 Sharon Churcher, Michael Thomas, Virginia Giuffre and others Exhibit 23 Compilation of May 2011 e-mails among Sharon Churcher, Virginia Giuffre, Paulo Silva and others Exhibit 24 Compilation of June 2011 e-mails 289 between Virginia Giuffre and Sharon Churcher Exhibit 26 PR Hub Statement on Behalf of Ghislaine Maxwell article 300 Exhibit 27 1/2/15 e-mail from Ross Gow to To Whom It May Concern 309 4 284 5 6 7 8 288 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 6 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page133 of 648 1 January 19th, 2015? 2 3 A January 21st, 2015. 4 5 At the very top of the page it says Q The date it was filed. Is there a date just above the signature block? 6 A Oh, yes, sorry. 7 Q And what date -- what date was that? 8 A The 19th day of January, 2015. 9 Q Okay. 10 13 And this document is something that you believe contains the truth, correct? 11 12 Yes, there is. A To the best of my knowledge at the time, Q All right. yes. Did something change between 14 the time then and today that makes you believe that 15 it's not all accurate? 16 A Well, as you can see, in line 4 on page 1, 17 I wasn't aware of my dates. 18 best to guesstimate when I actually met them. 19 I was just doing the Since then I've been able to find out that 20 through my Mar-a-Lago records that it was actually 21 the summer of 2000, not the summer of 1999. 22 Q Oh, I'm sorry. 23 A On the first page. 24 Q Okay. 25 A Yes. Are you back on page 1? VIRGINIA GIUFFRE 5/3/2016 25 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page134 of 648 1 Q And you're talking about line 4? 2 A Line 4. 3 Q Paragraph 4 or line 4? 4 A Oh, sorry. 5 6 7 8 number 4. Q A And what part of paragraph 4 do you In approximately -MR. EDWARDS: 10 12 Okay. now believe to be untrue? 9 11 Number 4, the paragraph Object to the form. You can answer. A In approximately 1999 when I was 15 years old I met Ghislaine Maxwell. 13 Q (BY MS. MENNINGER) 14 A I now know that it was 2000, that I was 16 15 16 Okay. years old when I met Ghislaine Maxwell. Q So when you signed this document under 17 penalty of perjury stating that it was true, you no 18 longer believe that to be true, correct? 19 A It was an honest mistake. We had no idea 20 how to pinpoint without any kind of records or dates 21 or anything like that. 22 chronologically through time. 23 time that I thought it was. 24 facts, so it's good to know. 25 Q I was just going back And that's the best And now I know the So you now believe that a document you VIRGINIA GIUFFRE 5/3/2016 26 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page135 of 648 1 filed under oath is no longer true, correct? 2 3 4 5 6 MR. EDWARDS: A Object to the form. I wouldn't say that it wasn't true. just unaware of the times and the dates. Q (BY MS. MENNINGER) Again, is there more than one truth, Ms. Roberts? 7 A No, there's no more than one truth. 8 Q All right. So a document in which you 9 swore that you were 15 years old when you met 10 Ms. Ghislaine Maxwell is an untrue statement, 11 correct? 12 13 I was MR. EDWARDS: A Object to the form. It's not that it's an untrue statement. 14 It was a mistake. 15 to say something that wasn't true. 16 knowledge that I thought it was 1999. 17 my records from Mar-a-Lago I was able to find out 18 that it was 2000. 19 found out the actual dates that I did work at 20 Mar-a-Lago. 21 Q 22 So it wasn't intentionally trying It was to my best And when I got And this was entered before I (BY MS. MENNINGER) Okay. So a document that you filed under oath -- 23 A Um-hum. 24 Q -- is now, you believe to be untrue, 25 correct? VIRGINIA GIUFFRE 5/3/2016 27 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page136 of 648 1 2 3 MR. EDWARDS: Asked and answered. Q 4 5 Objection. (BY MS. MENNINGER) MR. EDWARDS: A You may answer. Answer again. Again, I wouldn't say it's untrue. Untrue 6 would mean that I would have lied. 7 This was my best knowledge at the time. 8 very best to try to pinpoint time periods going back 9 such a long time ago. 10 And I didn't lie. And I did my It wasn't until I found the facts that I 11 worked at Mar-a-Lago in 2000 that I was able to 12 figure that out. 13 Q (BY MS. MENNINGER) And approximately when 14 did you learn those facts about the dates you worked 15 at Mar-a-Lago? 16 A I would say it was mid-2015. 17 Q Mid-2015 is the first time you became 18 aware of the dates -- 19 A I don't know the exact -- 20 Q If you could just let me finish. 21 A I'm sorry. 22 Q That's all right. Approximately mid-2015 23 when you learned the true dates that you had worked 24 at Mar-a-Lago? 25 A That's correct. Sorry. VIRGINIA GIUFFRE 5/3/2016 28 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page137 of 648 1 a lot of the circumstances that I had been subjected 2 to, I decided I wanted to get my GED. 3 4 Q Okay. So you were going to an actual school to get your GED, that's what you're saying? 5 A Yes. 6 Q And that school, whatever it was, where 7 you were getting your GED was not Palm Beach High 8 School, right? 9 A No. 10 Q And it -- whatever the school was where 11 you were getting your GED took a summer break? 12 A I believe so, yes. 13 Q And that was in 2000? 14 A Now that we know the right dates, yes. 15 Q And that's when your dad helped you get a 16 quote-unquote summer job? 17 A Yes. 18 Q All right. 19 Mar-a-Lago? 20 A Yes. 21 Q Okay. And that summer job was Now tell me how you sort of came 22 into Mar-a-Lago for the first time? 23 come? 24 25 They called you? A He asked you to What happened? My dad was very liked there. he talked to the people who were in HR. VIRGINIA GIUFFRE 5/3/2016 So I think And then 57 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page138 of 648 1 mic higher up on your jacket, please? 2 THE DEPONENT: 3 THE VIDEOGRAPHER: 4 THE DEPONENT: 5 Sure. Tell me if that's okay. Better? 6 A Okay. 7 Q (BY MS. MENNINGER) 8 Thank you. Page 40? Right. Do you see the first full paragraph on that page? 9 A I do. 10 Q The first line begins: I spent my sweet 11 16th birthday on his island in the Caribbean next to 12 Little (sic) St. James Isle. 13 Little St. Jeff's. 14 appetite for fornicating. 15 He liked to call it His ego was enormous as his Do you see that sentence? 16 A I do. 17 Q That is not true, correct? You were not 18 spending your sweet 16th birthday on Little St. James 19 Isle, correct? 20 A Based on my knowledge at the time that I 21 wrote this manuscript, I thought I did spend my 16th 22 birthday there. 23 that. And so I put it down in there as Now I know that it wasn't my 16th birthday. 24 Q Or your sweet 16th birthday? 25 A Well, we -VIRGINIA GIUFFRE 5/3/2016 101 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page139 of 648 1 2 3 4 5 MR. EDWARDS: Harassing. Q (BY MS. MENNINGER) A Is it not custom to call your 16th birthday sweet? 7 before? 9 10 Q A 15 16 17 18 19 20 Was it your sweet 16th birthday, As we -MR. EDWARDS: She's answered the question. It's been asked and answered. 13 14 Have you never heard that saying Ms. Giuffre? 11 12 Was it your sweet 16th birthday? 6 8 Object to the form. MS. MENNINGER: actually. Q She asked me a question, You're not testifying here. (BY MS. MENNINGER) Was it your sweet 16th birthday? A As I thought, in the manuscript when I wrote it, I thought it was my sweet 16th birthday. Q Okay. Now that you know it wasn't, where did you spend your sweet 16th birthday? 21 A Well, I don't know. 22 Q Well, just give us your best guess. 23 MR. EDWARDS: Objection. 24 going to guess today. 25 answers as she remembers them. And she's not She's going to tell you the VIRGINIA GIUFFRE 5/3/2016 102 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page140 of 648 1 A Again, I don't know. 2 Q Do you recall any present you actually got 3 on your sweet 16th birthday? 4 5 A No, I don't. I don't know where I spent it, who I spent it with or what I got. I'm sorry. 6 Q How long did you work at Mar-a-Lago? 7 A Best of my recollection, it was a summer 8 job. 9 only worked there approximately two weeks, two, three I believe I started in June. And I think I 10 weeks. 11 Q How many hours a week did you work? 12 A I want to say it was a -- I want to say 13 it's a full-time job. 14 Q Do you recall it being a full-time job? 15 A It was a summer job, but just thinking 16 back, my dad used to bring me in and bring me home. 17 So he worked full time, all day. 18 lounge around Mar-a-Lago so, yes, I think it would 19 have been a full-time job. So -- and I didn't 20 Q And how much did you make per hour? 21 A Approximately, I think I remember making 22 $9 an hour. 23 Q The bracelet and earrings you got for your 24 birthday, some birthday, on Little -- or where was 25 that birthday party, at Little St. James? VIRGINIA GIUFFRE 5/3/2016 104 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page141 of 648 1 Q Which brother? 2 A Sky. 3 Q What about your other brother? 4 A I think he had moved out by then. 5 Q What forms of communication did you have? 6 Just a home phone number, or what? 7 A Yeah, there was a home phone. 8 Q When do you recall ever getting a cell 9 phone? 10 A 11 12 13 14 The first cell phone I ever got was the one that Ghislaine gave to me. Q So you never had -- your parents, did they have ones when you were working at Mar-a-Lago? A No, my dad used to -- like, we had phones 15 in the spa and maintenance area and so on, so forth. 16 And you could, so to speak, page people from around 17 the courts. 18 Q Okay. So tell me what you recall of the 19 first conversation that you had with Ghislaine 20 Maxwell. 21 A I'm sitting there reading my book about 22 massage therapy, as I'm working in the spa. 23 getting my GE -- well, I was in the process of 24 getting my GED before I went to my summer job. 25 decided that I would like to become a massage VIRGINIA GIUFFRE 5/3/2016 And I'm I 113 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page142 of 648 1 A Yes. 2 Q Who else was at home when you got home? 3 A My mom, my dad and my brother. 4 Q Which brother? 5 A Sky. 6 Q And anyone else who was there at the time? 7 A I believe Michael might have been living 8 with me at that time. 9 10 11 Q So he might have been there. Do you recall if he was there when you got home? A I don't really remember. I remember what 12 I did when I got home, that I basically made a 13 beeline for the bathroom. 14 Q Let me ask you a question. Michael was 15 living with you at that home, at your parents' home 16 at the time, is your best recollection today; is that 17 right? 18 A That's my best recollection, yes. 19 Q When you say living with you, were you 20 guys staying in the same room? 21 A Yes. 22 Q Were you engaged at that time to him? 23 A That was a really weird relationship. He 24 was a friend who looked after me, and he did propose 25 to me and I did say yes. But my heart was never in VIRGINIA GIUFFRE 5/3/2016 127 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page143 of 648 1 it. 2 3 4 He was somebody that helped me off the streets so I felt compelled to say yes to him. Q Okay. So when he proposed to you and you 5 said yes, did that take place before you started 6 working at Mar-a-Lago or after you started working at 7 Mar-a-Lago? 8 A Before. 9 Q And so if he were living with your parents 10 at that time, you were living in the same room; is 11 that correct? 12 A I believe so. 13 Q And your parents understood him to be your 14 15 16 17 18 19 fiance? A I don't think they agreed with it, but I think they understood it as that. Q I mean -- I mean, you communicated to them that he had proposed and you had accepted? A Yeah, in not such a pretty way. 20 they obviously weren't very happy about it. 21 wasn't my true intentions to ever marry him. I mean, And it 22 Q Okay. 23 A But I did it to make him feel okay. 24 25 I didn't want to be mean. Q What did your mom say about your VIRGINIA GIUFFRE 5/3/2016 128 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page144 of 648 1 2 know where it was when she said to go do this. Q (BY MS. MENNINGER) Okay. Where were you 3 sent to have sex with the owner of a large hotel 4 chain by Ghislaine Maxwell? 5 MR. EDWARDS: Object to the form. 6 A I believe that was one time in France. 7 Q (BY MS. MENNINGER) 8 A I believe it was around the same time that 9 10 Which time in France? Naomi Campbell had a birthday party. Q Where did you have sex with the owner of a 11 large hotel chain in France around the time of Naomi 12 Campbell's birthday party? 13 A In his own cabana townhouse thing. It was 14 part of a hotel, but I wouldn't call it a hotel. 15 Jeffrey was staying there. Ghislaine was 16 staying there. Emmy was staying there. 17 staying there. This other guy was staying there. 18 don't know his name. 19 20 I was I was instructed by Ghislaine to go and give him an erotic massage. 21 Q She used the words erotic massage? 22 A No, that's my word. 23 24 25 I what they would use. Q The word massage is That's their code word. Was she in the room when you gave this erotic massage to the owner of a large hotel chain? VIRGINIA GIUFFRE 5/3/2016 203 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page145 of 648 1 2 3 A No, she was not in the room. She was in another cabana. Q And other than telling you to go give the 4 owner of this large hotel chain a massage, do you 5 remember any other words she used to you to direct 6 you in what you should do? 7 A Not at the time, no. 8 Q Where did -- where were you and where was 9 10 Ms. Maxwell when she directed you to go have sex with Marvin Minsky? 11 MR. EDWARDS: Object to the form. 12 A I don't know. 13 Q (BY MS. MENNINGER) 14 15 Where did you go to have sex with Marvin Minsky? A I believe it was the U.S. Virgin Islands, 16 Jeff's -- sorry, Jeffrey Epstein's island in the U.S. 17 Virgin Islands. 18 Q And when was that? 19 A I don't know. 20 Q Do you have any time of year? 21 A No. 22 Q Do you know how old you were? 23 A No. 24 Q Other than Glenn Dubin, Stephen Kaufmann, 25 Prince Andrew, Jean Luc Brunel, Bill Richardson, VIRGINIA GIUFFRE 5/3/2016 204 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page146 of 648 1 another prince, the large hotel chain owner and 2 Marvin Minsky, is there anyone else that Ghislaine 3 Maxwell directed you to go have sex with? 4 5 A I am definitely sure there is. remember everybody's name? 6 Q 7 about them? 8 A 9 Okay. No. Can you remember anything else now. Look, I've given you what I know right I'm sorry. This is very hard for me and very 10 frustrating to have to go over this. 11 don't recall all of the people. 12 amount of people that I was sent to. 13 14 But can I Q I don't -- I There was a large Do you have any notes of all these people that you were sent to? 15 A No, I don't. 16 Q Where are your notes? 17 A I burned them. 18 Q When did you burn them? 19 A In a bonfire when I lived at Titusville 20 21 because I was sick of going through this shit. Q Did you have lawyers who were representing 22 you at the time you built a bonfire and burned these 23 notes? 24 A 25 I've been represented for a long time, but it was not under the instruction of my lawyers to do VIRGINIA GIUFFRE 5/3/2016 205 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page147 of 648 1 this. 2 and we believed that these memories were worth 3 burning. 4 My husband and I were pretty spiritual people Q So you burned notes of the men with whom 5 you had sex while you were represented by counsel in 6 litigation, correct? 7 MR. EDWARDS: 8 9 10 A document. 12 This wasn't anything that was a public This was my own private journal, and I didn't want it anymore. 11 Q Object to the form. So we burned it. (BY MS. MENNINGER) When did you write that journal? 13 A Just over time. I started writing it 14 probably in, I don't know, I can't speculate, 2012, 15 2011. 16 17 Q So you did not write this journal at the time it happened? 18 A No. 19 Q You started writing this journal 20 approximately a decade after you claim you finished 21 being sexually trafficked, correct? 22 A Yes. 23 Q And you started writing a journal after 24 25 you had a lawyer, correct? A Correct. VIRGINIA GIUFFRE 5/3/2016 206 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page148 of 648 1 2 Q Including Mr. Edwards, who is sitting right here, correct? 3 A Correct. 4 Q What did that journal look like? 5 A It was green. 6 Q And what else? 7 A It was just a spiral notebook. 8 Q Okay. 9 10 And what did you put into that green spiral notebook? A Bad memories. Things that I've gone 11 through, lots of things, you know. 12 There was a lot of pages. 13 that book. 14 15 Q I can't tell you. It was over 300 pages in Did you ever show that book to your lawyers? 16 A No. 17 Q Did you show that book to anyone? 18 A My husband. 19 Q Did you show it to anyone else besides 20 your husband? 21 A No. 22 Q Did you tear out pages and give them to 23 24 25 Sharon Churcher? A No, I wrote -- those pages that you're talking about, I wrote for her specifically. VIRGINIA GIUFFRE 5/3/2016 She 207 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page149 of 648 1 wanted to know about the Prince Andrew incident. 2 Q So that's a different piece of paper? 3 A Yeah, that's just random paper. 4 Q So you had a green spiral notebook that 5 you began sometime in 2011 or 2012 in which you wrote 6 down your recollections about what had happened to 7 you, and you burned that in a bonfire in 2013. 8 Did I get that right? 9 A You got that right. 10 Q And do you have no other names of people 11 to whom you claim Ghislaine Maxwell directed you to 12 have sex, correct? 13 A At this time, no. 14 Q Is there any document that would refresh 15 16 your recollection that you could look at? A If you have a document you'd like to show 17 me, I would be glad to look at it and tell you the 18 names I recognize off of that. 19 20 Q I'm just asking you if there's a document you know of that has this list of names in it? 21 A Not in front of me, no. 22 Q Where is the original of the photograph 23 that has been widely circulated in the press of you 24 with Prince Andrew? 25 A I probably still have it. VIRGINIA GIUFFRE 5/3/2016 It's not in my 208 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page150 of 648 1 2 3 other terms of his probationary period? A No. He went to everything that he was supposed to go to. 4 Q Has he paid his fines? 5 A Yes, as far as I know. 6 Q Describe for me the contract that you had 7 8 9 10 11 12 with the Mail On Sunday? A Could you be a little bit more specific? Like -Q Have you had more than one contract with the Mail On Sunday? A Well, there was one contract for the 13 picture. And that was to pay me 140,000 for the 14 picture. And then two stories were printed after 15 that for the amount of 10,000 each. 16 17 Q Is that the only money that you received from the Mail On Sunday? 18 A Correct. 19 Q Did you receive any money for syndication 20 of the photograph? 21 A Isn't that what the 140 was for? 22 Q I'm asking you. 23 A Well, I don't really know what syndication 24 means. 25 Q Did you have a written contract with the VIRGINIA GIUFFRE 5/3/2016 247 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page151 of 648 1 Mail on Sunday? 2 A Yes. 3 Q Where is that contract right now? 4 A I don't know. 5 I -- I lose paperwork wherever I go. 6 7 I've moved that many times. Q Is it possible it's in the boxes in Sydney? 8 A I don't think I kept it, to be honest. 9 Q Did you ever refer back to it after you 10 signed it? 11 A I know I kept it for a short while, but I 12 mean, like I said, I've moved countries twice in the 13 last two years and three different houses. 14 paper trail is lost. I don't know where it would be. 15 Q Did you receive it via e-mail? 16 A No. 17 So the I received it -- Sharon Churcher handed it to me by paper. 18 Q And you signed it? 19 A I signed it. 20 Q And then did you make a copy of it? 21 A No. 22 Q You never had a copy of it? 23 A Well, I had my own copy. 24 25 I'm sure she has hers. Q Do you recall there being a period of VIRGINIA GIUFFRE 5/3/2016 248 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page152 of 648 1 STATE OF COLORADO) 2 ) 3 COUNTY OF DENVER ) 4 ss. REPORTER'S CERTIFICATE I, Kelly A. Mackereth, do hereby certify 5 that I am a Registered Professional Reporter and 6 Notary Public within the State of Colorado; that 7 previous to the commencement of the examination, the 8 deponent was duly sworn to testify to the truth. 9 I further certify that this deposition was 10 taken in shorthand by me at the time and place herein 11 set forth, that it was thereafter reduced to 12 typewritten form, and that the foregoing constitutes 13 a true and correct transcript. 14 I further certify that I am not related to, 15 employed by, nor of counsel for any of the parties or 16 attorneys herein, nor otherwise interested in the 17 result of the within action. 18 19 20 In witness whereof, I have affixed my signature this 11th day of May, 2016. My commission expires April 21, 2019. 21 22 23 ____________________________ Kelly A. Mackereth, CRR, RPR, CSR 216 - 16th Street, Suite 600 Denver, Colorado 80202 24 25 VIRGINIA GIUFFRE 5/3/2016 345 Case 18-2868, Document 278, 08/09/2019, 2628230, Page153 of 648 may. 23. 2010(3050508-2868, Document 278, 08/09/2019, 2628230, Page1540f48118 F- 2 Page: 1 Document Name: untitled PANEL: A07. ASSIGNMENT HISTORY YEAR: 16 T234 Monday May 23, 2016 9:04 am STDT: 12870606 ROBERTS, VIRGINIA SCHL: 3390 GR: 10 ST: 1 A ENTRY WITHDRAWAL CD DATE CD CD DATE PF SY CL DS SCHL DESC GR PRS ABS UNX R02 101201 W26 030702 02 01 3390 SURVIVORS 10 56 '31 R02 092001 W02 101101 02 01 2331 ROYAL PALM HIG 10 13 1 081401 W32 092001 02 A1 2192 HS ADL 30 EA1 081600 m? W47 081301 01 Al m? 2192 HS ADL 3O EA1 062100 Hm W47 081500 00 A1 mm 2192 HS ADL 30 E01 081699 mm W03 081699 00 01 ?m,2331 ROYAL PALM HIG 10 E01 081998 W02 060999 99 01 0581 FOREST HILL H1 09 155 25 E01 082097 W01 061098 98 01 2331 ROYAL PALM HIG 09 147 33 E01 082097 W22 082097 98 01 2191 WELLINGTON HIG 09 R03 040797 W02 061197 97 01 1691 CRESTWOOD MID 08 40 5 301 082294 DNE 082294 95 01 1703 ROYAL PINES SC 06 E01 082393 W02 061094 94 01 1901 LOXAHATCHEE EL 05 167 13 E01 082592 W01 061193 93 01 1901 LOXAHATCHEE EL 04 176 PAGE PAGE TERML: 11B5 Date: 5/23/2016 Time: 9:05:36 AM Case 18-2868, Document 278, 08/09/2019, 2628230, Page155 of 648 TO 00000 I 50 PALM BEACH SCHOOL: $390 DEMOGRAPHIC INFORMATION GRADE LEVEL: 10 1 TE: 03? CURRENT DISTRICT: 50 PALM BEACH PAGE CURRENT 3390 SURVIVURS CHARTER SCHOOL LEGAL NAME: ROBERTS, VIRGINIA :561) 712-1800 MAILING 12959 RACKLEY RD ;310 CONGRESS AVE ADDRESS: LUXAHATCHEE FL 33470 EST PALM BEACH FL 13409 DISTRICT STUDENT ID: 12070606 FL STUHRNT ID-ALIAS: MIGRANT STUDENT Th: 00000000000 SEX: SKY ROBERTS PARENT BIRTH VERTPICATION: LYNN ROBERTS PARENT CA 1 1 LACE SACRAMENTO IMMUNIZATION STATUS: PERMANENT IMMUNIZATION CERTIFICATE VACCINE STATUS, DATE- VACCINE CERTTFICATE EXPIRATION DATE: TYPE DOSE DATE DOSE DATE DOSE DATE DOSE DATE DOSE urn 1 11/02/1983 2 02/33/1984 5 04/27/1994 4 04/24/1987 5 09/27/1900 T0 1 06/24/1997 FOLIO 1 11/02/1983 2 02/03/1984 3 04/24/1987 4 HIB 1 04/24/1967 MMR 1 04/24/1937 MEASLES 1 04/24/1957 HEP 30053 1 04/19/1997 2 06/24/1997 1 09/03/1999 (I 04/10/1997 COURSE TNFORMATION -- DISTRICT: 50 SCHOOL: 3390 N0 COURSES TAKEN 50 SCHOOL: 1901 LOXAHATCHEE GROVES ELEM YEAR: 1989-1990 GRADE LEVEL: NA YEAR: 1991-1393 GRADE LEVEL: 03 SUBJECT CRSF CREDIT GPA QTY PTS GPA QTY PTS POURSE TITLE AREA FLAG CRD 4286 5.00 CUM: 1.5429 27.00 3 5100090 THIRD GRADE 0.00 0.00 STATE TERM: 1.4736 5.00 CUM: 1.5429 27.00 CREDIT, TERM: 0.00 0.00 1989~1990 ANNUAL DAYS-PRESENT: 0 ABSENT: 1991-1992 ANNUAL DAYS-PRESENT: 180 ABSENT: 0 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 SUMMER TERMS DAYS-PRESENT: 0 ABSENF: 0 ACADEMICALLY PROMOTED DISTRICT: 50 SCHOOL: 3390 N0 COURSES TAKEN DISTRICT: 50 SCHOOL: 1301 GROVES ELEM. YEAR: 1990-1991 GRADE NA YEAR: 1932-1993 GRADE LEVEL: 04 SUBJECT CRSE CREDIT GPA QTY PTS GPA QTY PTS COURSE TITLE AREA FLAG GRD DISTRICT-TERM: 1.4286 5.00 CUM: 1.5129 27.00 3 5100100 FOURTH GRADE 0.00 0.00 STATE-TERM: 1.4286 $.00 CUM: 1.5429 27.00 CREDIT, TERM: 0.00 U.00 1990?1991 ANNUAL DAYS PRESENT. 0 ABSENT: 0 1992-1995 ANNUAL DAYS-PRESENT: 176 ABSENT: 4 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 SUMMER TERMS 0 0 ACADEMICALLY PROMOTED ACADEMICALLY PROMOTED OFFICIAL TRANSCRIPT THE SCHOOL 015mm or A PALM BEACH COUNTY FLORID APR 1 2008 RECORDS CUSTODMN Case 18-2868, Document 278, 08/09/2019, 2628230, Page156 of 648 TU 0000050 PALM BEACH SCHOOL: 3390 COURSE TNPORMATTON FILE: TE: 03 Jl 2008 CURRENT DISTRICP: 50 PALM BEACH PAGE 2 CURRENT SCHOOL: 3590 CHARTER SCHOOL LEGAL NAME: ROBERTS, VIRGINIA (561) 712-1800 50 SCHOOL: 1901 LOXAHATCHEE GROVES ELEM. 50 SCHOOL: 3131 ROYAL PALM BEACH COMM HIC 1993?1994 GRADE LEVEL: 05 YEAR: 1997?1998 GRADE LEVEL: 09 SUBJECT CRSB SUBJECT CREE CREDIT COURSE8 COURSE TITLE AREA FLAG GRD COURSE TITLE AREA FLAG CRD 3 5100110 FIFTH GRADE 0.00 0.00 0708340 SPANISH 1 FL RJ .50 .00 3 $100110 FIFTH GRADE 0.0C 0.00 CREDIT, TERM: 0.00 0.00 1001310 ENG 1200370 ALGEBRA IA MA JR .50 0.00 1503400 BEG PE SC 0.00 1993-1994 ANNUAL DAYS-PRESENT: 167 ABSENT: 13 0.00 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 0 0 0 ACADEMICALLY PROMOTED 2001310 9C1 SC 2100410 CARTRBEAN STUDIES EL .50 .50 .00 .00 .50 .50 .50 .50 .50 0.50 .50 0.50 50 0.50 1 1 1 8500355 NUTRITION WELLNESS VO 7 1001310 ENG 1 EN RJ A DISTRICT: 50 SCHOOL: 1390 NO COURSES TAKEN 2 1200170 ALGEBRA 1A MA JR YEAR: 1994HI995 GRADE LEVEL: NA 2 1501300 PERS FIT PE RJ A 2 2001310 SCI SF A 2 2103300 WORLD CULT GEOG EL GPA QTY PTS CPA QTY PTS DISTRICT-TERM: 1.4286 5.00 CUM: 1.5429 27.00 STATE-TERM: 1.4286 5.00 CUM: 1.5429 27.00 50 SCHOOL: 9034 ESE CTHER TEACHING SERV YEAR: 1997-1998 GRADE LEVEL: 09 1994-1995 ANNUAL DAYS-PRESENT: 0 ABSENT: 0 SUBJECT CRSE CREDIT SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 COURSE TITLE AREA FLAG GRD NOT ENROLLED IN DISTRICT K?l? AT END OF SCHOOL YEAR 4 1200370 AIORERA MA JR 8 0.50 0.50 5 2001310 SPT SC A 0.50 0.50 DISTRICT: 30 SCHOOL: 1691 CRESTWOOD MIDDLE CREDIT, TERM: 7.00 4.00 YEAR: 199b?1997 GRADE LEVEL: 08 SUBJECT CRSE CREDIT GPA QTY PTS GPA QTY PTS COURSE TITLE AREA FLAG CR3 DISTRICT TERM: 1.0571 13.00 CUM: 1.8571 13.00 0400010 DRAMA 2 0.00 .00 STATE TERM: 1.8571 13.00 CUM: 1.0571 13.00 8500240 TEEN 0.00 .00 1001070 LANG ARTS 3 0.00 .00 1997~1998 ANNUAL DAYS PRESENT: 0 ABSENT: 1205070 MATH 3 0.00 .00 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 2002100 COMPRE SCI 3 0.00 .00 NOT ENROLLED IN K-12 AT END OF SCHOOL YEAR 2103050 AND CHO 0.00 .00 CREDIT, TERM: 0.00 .00 thmrorunm 1996-1997 ANNUAL DAYS-PRESENT: 40 ABSENT: 5 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 ACADEMTCALLY PROMOTED OFFICIAL TRANSCRIPT THE SCHOOL DISTRICT 0? PALM BEACH COUNTY. FLORIDA APR 1 2008 RECORDS CUST DIAN Case 18-2868, Document 278, 08/09/2019, 2628230, Page157 of 648 TO LEGAL NAME: ROBERTS, VIRGINIA DISTRICT: 50 SCHOOL: 0581 FOREST HILL HIGH YEAR: 1998-1999 GRADE LEVEL: 09 SUBJECT CRSE CREDIT COURSE TITLE AREA FLAG GRD 050C500 DEV 1 EL .50 0.50 0701320 FRENCH 1 FL RJ .50 0.50 1001340 ENG 2 EN RJ .50 0.50 120C380 ALGEBRA IE MA JR 50 0.00 1900300 DRIVER ED CLASS EL .50 0.50 2000310 BIOLOGY 1 SC RJ .50 0.50 2109310 WORLD H15T WH RJ .50 0.50 0500500 DEV 1 EL .50 0.00 0701320 FRENCH 1 FL RJ 50 0.00 0800J00 MGMT SKL LM .50 0.00 1001340 ENG 2 EN RJ .50 0.00 1200380 ALGEBRA IB MA JR .50 0.00 2000310 1 SC RJ .50 0.00 2109310 WORLD HIST NH RJ .50 0.00 CREDIT, TERM: 7.00 3.00 GPA QTY FPS GPA QTY PTS DISTRICT TERM: 1.2857 9.00 CUM: 1.5714 22.00 STATE-TERM: 1.2557 9.00 CUM: 1.5714 22.00 1998~1999 ANNUAL DAYS-PRESENT: 155 ABSENT: 25 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 ACADEMICALLY PROMOTED DISTRICT: 50 SCHOOL: 3390 N0 COURSES TAKEN YEAR: 1999 2000 GRADE LEVEL: NA GPA QTY PTS GPA QTY PTS DISTRICT-TERM: 1.4286 5.00 CUM: 1.5429 27.00 STATE TERM: 1.4286 5.00 CUM: 1.5429 27.00 1999 2000 ANNUAL DAYS-PRESENT: 0 ABSENT: 0 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: NOT ENROLLED IN DISTRICT K-12 AT END OF SCHOOL YEAR 0000050 PALM BEACH SCHOOL: 3390 COURSE INFORMATION FILE: SRTC1RTS EPARED 008 CURRENT DISTRICT: SC PALM BEACH PAGE 3 CURRENT SCHOOL: 3390 SURVIVORS CHARTER SCHOOL {561) 712?1800 DISTRICF: 50 SCHOOL: 3390 NO COURSES TAKEN YEAR: 2000-2001 GRADE LEVEL: NA GPA QTY FTS GPA QTY PTS DISTRICT-TERM: 1.4286 5.00 CUM: 1.5429 27.00 STATE-TERM: 1.4286 5.00 CUM: 1.5429 27.00 2000-2001 ANNUAL DAYS-PRESENT: 0 ABSENT: 0 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 PROMOTION STATUS NOT APPLICABLE DISTRICT: 50 SCHOOL: 3390 SURVIVORS CHARTER SCHOOL YEAR: 2001-2002 GRADE LEVEL: 10 SUBJECT CRSE CREDIT COURSE TITLE AREA FIAG GRD 1 0500530 DEV 4 EL .50 0.50 1 1001440 BUSINESS ENG 1 EN .50 0.50 1 1205370 CONSUMER MATH MA .50 0.50 1 8300310 WORKPLACE ESSENTIALS V0 .50 0.50 1 8301610 WORK EXP 1 V0 .50 0.03 8101650 WORK EXP-OJT V0 .00 0.03 CREDIT, TERM: 3.5 2.00 LJGL)mink GPA QTY PTS GPA QTY PTS DISTRICT-TERM: 1.4286 5.00 CUM: 1.542? 27.00 STATE-TERM: 1.4286 5.00 CUM: 1.5429 27.00 2001-2002 ANNUAL DAYS-PRESENT: 0 ABSENT: 0 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: PROMOTION STATUS NOT APPLICABLE OFFICIAL TRANSCRIPT THE SCHOOL OF PALM BEACH COUNTY. FLORIDA APR 1 2008 RECORDS Case 18-2868, Document 278, 08/09/2019, 2628230, Page158 of 648 T0 - 0000030 PALM REACH LEGAL NAME: A I A AS OF: GRADUATION OPTION: 4-YR STANDARD - - - CREDITS - - SUBJECT TOTAL TOTAL TOTAL AREA TO DATE NEEDED REMAINING ENGLISH (EN) 0.00 4.00 2.00 MATHEMATICS (MA) .50 3.00 1.50 SCIENCE (SC) .50 3.00 1.50 AMER HISTORY (AH) .00 1.00 1.00 WORLD HTSTORY (NH) .50 1.00 0.50 ECONOMICS (EC) .00 0.50 0.50 AMER GOVERNMENT (AG) .00 0.50 0.50 (v0/ .50 PERFORM FINE ART (PF) .00 .00: 0.50A LIFE MGMT SKILLS (LN) .00 0.50 0.50 PHYSICAL ED (PE) .50 0.50 0.00 FOREIGN LANGUAGE (FL) .50 0.00 LANGUAGE ARTS (LA) .00 SOCIAL STUOIES (ss) .00 ELECTIVE (EL) .00 9.00 0.50 ESE (EX) .00 COMPUTER ED (CE) .00 CREDITS, CUMULATIVE: .00 24.00 15.00 . TOTALS INCTUDE VOCATIONAL 0 PERFORM FINE ARTS- (1w. ms GPA CITY st . 1.5429 27.00 STATE: 1.5429 27.00 - +l>ri+SCHOOL: 3390 GRADUATION SUMMARY FILE: SRTSIZIS 03/31'2008 CURRENT DISTRICT: 50 PALM BEACH PAGE 4 CURRENT SCHOOL: $3.90 SURVIVORS CHARTER SCHOOL [561) 712-1800 VOCATIONAL PROGRAM COMPLETION STATUS- NUMBER: 8500355 NUTRITION WELLNESS TERMINATION: IN PROGRESS COMPLETED: VOCATIONAL PROGRAM COMPLETION NUMBER: 8300310 WORKPLACE ESSENTIALS TN PROGRESS VOCATIONAL PROGRAM COMPLETION STATUS- NUMBER: 8301610 WORK EXP TERMINATION: IN PROGRESS COMPLETPD: VOCATIONAL PROGRAM COMPLETION STATUS- NUMBER: 8301650 WORK EXP-OJT I COMPLETED: DISTRICT CLASS EFFECTIVE DATE: 03/06/2002 CLASS RANK, NUMERICAL es CLASS RANK, PERCENTILE: 70 CLASS RANK, TOT . NUMBER IN CLASS: 214 DATE PASSED ASSESSMENT TEST FOR GRADUATION COMMUNICATIONS: 10/2001 MATHEMATICS: 01/2002 COMMUNITY SERVICE HOURS: 0 REQUTFEMENT MET: OFFICIAL TRANSCRIPT THE SCHOOL DISTRICT OF PALM BEACH COUNTY. FLORIDA APR 1 2008 RECORDS CUSTODIAN Case 18-2868, Document 278, 08/09/2019, 2628230, Page159 of 648 TC - DISTRICT: BEACH SCHOOL: 3390 COMMENTS FILE: GRADE LEVEL: 13 PREPARED DATE: 03/31/2008 CURRENT DISTRICT: 50 PALM BEACH PAGE 5 CURRENT SCHOOL: 5590 SURVIVORS CHARTER SCHOOL LEGAL NAME: ROBERTS, VIRGINIA (561! 712"1000 DEFLNITION OF TERM CODES - CCDE DEFINITION CODE DEFINITION CODE DEFINITION CODE DEFINITICN CODE DEFINITION 1 SEMESTER 1 COMBINED SUMMER TRIMESTER 1 QUINMESTER SIX WEEKS SEMESTER 2 SESSION TRIMESTER 2 OUINMESTER SIX WEEKS ANNUAL THIMESTER 3 SIX WEEKS 4 5 1 9 1* 3 SUMMER SESSION 1 QUARTER 1 OUINMESTER SIX WEEKS 4 6 INTERSESSION 2? INTERSESSION 3? INTERSESSION 4? INTERSESSTON 5' Hf?it'l?'zn WKAU: SUMMER SESSTON 2 QUARTER 2 QUINMESTER SIX WEEKS QUARTER 3 YEAR OF QUARTER 4 3?1220 SHORT SIX WEEKS USED OF SUMMER SCHOOL SESSIONS) WITH YEAR-ROUND SCHOOL RECORDKEEPING USED ONLY FOR WORKFORCE DEVELOPMENT EDUCATION (ADULT GENERAL AND POSTSECONDARY VOCATIONAL EDUCATION) USED ONLY FOR REPORTING STUDENTS WHO HAVE WITHDRAWN BETWEEN SCHOOL YEARS STATE GRADING SCALE FOR HIGH SCHOOL STUDENTS (REGARDLESS 0F ENTRY DATE) EFFECTIVE SCHOOL YEAR 1997-1998 GRADING SCALE, EFFECTIVE GRADE QUALITY GRADE QUALITY GRADE QUALITY GRADE EQUIVALENT POINTS GRADE EQUTVALENT POINTS GRADE EQUIVALENT POINTS A - 90 - 100 4.00 80 - 89 3.00 - 7O - 79 2.00 60 - 69 1.00 0 - 59 0.00 GRADING SCALE, PRIOR TO 07/01/2001 GRADE QUALITY GRADE QUALITY GRADE QUALITY GRADE EQUIVALENT POINTS GRADE EQUIVALENT POINTS GRADE EQUIVALENT POINTS A 94 - 100 4.00 a 85 - 93 3.0C 77 - 84 2.00 70 76 1.00 0 - 69 0.0C NOTE: FROM THE 1987-1988 THROUGH THE 1996-1997 SCHOOL YEARS, FOR STUDENTS ENTERING HTGH SCHOOL DURING THESE YEARS, THE GRADE EQUIVALENTS FOR C, D, AND WERE: 75-84, 55-74, AND 0-64; QUALITY POINTS AND ALL OTHER GRADES WERE THE SAME AS THOSE SHOWN IN THE IMMEDIATELY PRFCEDING STATE GRADING SCALE. 996100383de Case 18-2868, Document 278, 08/09/2019, 2628230, Page160 of 648 TC DISTRICT: 0000050 SCHOOL: J390 COMMENTS FILE: SRTSI2IS GRADE LEVEL: 13 PREPARED DATE: 03/31/2008 CURRENT 50 PALM BEACH SCHOOL: 339:) SURVIVORS CHARTER scncou LEGAL NAME: ROBERTS, (561] 712-1800 STATE DEFINED COURSE FLAGS SCHOLAR-ELECTIVE SCHOLAR REQUIREMENT H?Houons CREDIT TN apn FROM PROM STATE CPA p=couusn IS IN PROGRESS AWARDED BY SLEP EXAM T-TRANSFERRED COURSE VOCATIONAL SUBSTITUTION COURSES- AIR PC SUB FOR LIFE MGMT SUB FOR PRAC ARTS SUB FOP PRACTICAL ARTS ED SUB FOR PRACTICAL ARTS FOR BUS EN I 1001440 FOR BUS EN I 1001440/11 1001450 deUE FOR MA I 1205540 FOR MA I 1205390 FOR GEN SCI 2002310 FOR ANAT PHYSIO 2000350 FOR PRE ALGEBRA 1200300 CST GD SUB FOR SCIENCE AIR FC SUB FOR SCIENCE NAVY SUB FOR SCIENCE ARMY SUD FOR LIFE MGMT MARTNE SUB FOR LIFE MGMT FOR BIO TECH 2000430 FOR BNV SCI 200134C FOR PHY SPT 2001110 FOR COURSE SPECIFIED 0N FOLLOWING LINE ON COURSE LIST ELL LANGUAGE INSTRUCTION LANGUAGE ESOL INSTRUCTION (ELEMENTARY SELF-CONTAINED) INSTRUCTION FY 1991-1992 COMMENTS THE PALM BEACH COUNTY SCHOOL DISTRICT AWARDS THE HIGH SCHOOL VAI.IDICTORTAN AND SALUTATORIAN USING A GPA AVERAGE THAT IS BASED ON COURSES TAKEN IN GRADES 9 12. HOWEVER, THE GPA ALL CREDIT COURSES. Case 18-2868, Document 278, 08/09/2019, 2628230, Pagel61 of 648 F0 DISTRICT: PALM BEACH SCHOOL: 3390 CATEGORY TNPOUMATION FILE: 03 31/2008 CURRENT DISTRICT: bU PALM BEACH PAGE 7 CURRENT SCHOOL: 3390 SURVIVORS CHARTER SCHUOL (561) 712-1800 03/07/9002 CODE: WES HOME LANGUAGE SURVEY DATE: 0&l15/2000 COUNTRY OF BIRTH: US UNITED STATES NATIVE LANGUAGE: EN ENGLISH PRIMARY HOME LANGUAGE: EN ENGLISH HEALTH EXAMINATION, SCHOOL ENTRY: SCHOOL ENTRY HEALTH EXAMINATION CERTIFIED. - STUDENT INFORMATION STUDENT PLAN DATE: 05/11/1999 CURRENT DATE: 05/11/2002 PRIMARY EXCEPTIONALITY: FEPP PROGRAM: EXCEPTIONAL STUDENT PROGRAM INFORMATION EVALUATION PLACE- DISMLS- PLACEMENT REFERRAL COMPLETE DETERM MENT SAL EXCEPTIONALITY STATUS DATE DATE DATE DATE ELIGIBLE AND PLACED 05/10/99 05/11/99 05/11/99 05/11/99 05/00/99 ELIGIBLE AND PLACED 02/03/90 02/04/98 02/04/90 02/04/90 00/11/96 DROPOUT PREVENTION PROGRAM INFORMATLON DROPOUT PREVENTION PROGRAM PLACEMENT REASONS OUTCOMES EDUCATIONAL ALTERNATIVE PROGRMS ACADEMICALLY UNSUCCESSFUL DOCUMNTD ACADMC PERFORMANCE EDUCATLONAL ALTERNATIVE PROGRMS ACADEMICALLY UNSUCCESSFUL DOCUMNTD ACADMC PERFORMANCE EDUCATIONAL ALTERNATIVE PROGRMS ACADEMICALLY UNSUCCESSFUL DOCUMNTD ACADMC PERFORMANCE TEST TEST LEVEL SUBJECT SCORE SCORE SUBJECT SCORE scnag SUBJECT SCORE SCORE GRD DATE NAME POEM FONTENT TYPE TYPE CONTENT TYPE TYPE CONTENT TYPE TYPE 30 06/:6/2000 TAB 7 A TOTBAT GE 0000 GE 0000 GE 0000 LANGUAGE GE Olin 30 00/;5/2000 TAB 4 TOTHAT GE 0000 GE 0000 CE 0126 LANGUAGE GE 0000 30 L6/;b/2000 TAB TUTUAT GE 0000 GE 0073 GE 0000 LANGUAGE GE C000 09 04/20/1990 0T0 A 19 COMPREHE ss 0801 COMPREHB NP 0005 SS 0750 NP 0034 SCIENCE 35 0000 SCIENCE NP 0000 ss 0000 NP 0000 136700385306 Case 18-2868, Document 278, 08/09/2019, 2628230, Page162 of 648 T0 - DISTRICT: 0000050 PALM BEACH SCHOOL: 3390 TEST INFORMATION FILE: SRTSIQIS GRADE LEVEL: 10 PREPARED DATE: 03/31'2008 CURRENT DISTRICT: 50 PALM BEACH PAGE 8 OF 0 CURRENT SCHOOL: 3390 SURVIVORS CHARTER SCHOOL LEGAL NAME: ROBERTS, VIRGINIA (561) TEST TEST TEST LEVEL SUBJECT SCORE SCORE SUBJECT SCORE SCORE SUBJECT SCORE SCORE HRH MATH NAME FORM CONTENT TYPE TTPF CONTENT TYPE TYPE CONTENT TYPE TYPE 08 04/15/1997 CTB 17 READIT) SS 0000 NP 0000 MATHIT) SS 0000 NP 0000 COMPREHE SS 0780 COMPREHE NP 0077 COMPUTAT SS 0000 COMPUTAT NP 0000 VOCAD SS 0000 08 04/18/1997 9TB NP 0003 SS 0798 NP 0070 05 04/22/1994 CTB 15 COMPREHE SS 0700 NP 0032 SS 0667 NP 0010 LANGUAGE SS 0694 LANGUAGE NP 0026 SS 0646 NP 0008 SS 0742 05 04/22/199a CTR 15 up 0061 on 03/29/1993 CTB A 14 SS 0711 NP 0059 SS 0568 NP 0022 COMPREHE SS 0735 COMPREHE NP 0074 COMPUTAT SS 0667 COMPUTAT NP 0021 VOCAB ss 0686 04 03/29/1993 CTB A 14 VOCAB NP 0043 55 0669 NP 0024 SCIENCE SS 0707 SCIENCE NP 0049 SS 0692 NP 0034 04 02/10/1993 WAP 04 NR NAHRA SS 0000 WR EXPOS V) 0000 WRITING U: 0000 03 04/00/1992 CTB A L3 COMPREHE SS 0733 COMPREHE NP 0085 SS 0649 NP 0026 LANGUAGE SS 0696 LANGUAGE NP 0050 SS 0679 NP 0044 SS 0712 01 04/08/1992 CTR A 11 NP 0056 02 C4/l6/1991 CTD A 12 SS 0663 NP 0000 SS 0467 NP 0001 COMPREHE SS 0659 COMPREHE NP 0051 COMPUTAT SS 0337 COMPUTAT NP 0001 VDCAB SS 0667 02 CPB A 12 VOCAB NP 0070 SS 0597 NP 0028 END OF TRANSCRIPT Case 18-2868, Document 278, 08/09/2019, 2628230, Page163 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page164 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK 3 CASE: 15-cv-07433-RWS 4 VIRGINIA GIUFFRE, 5 Plaintiff, 6 v. 7 GHISLAINE MAXWELL, 8 9 Defendant. ____________________/ 10 VIDEOTAPED DEPOSITION OF TONY FIGUEROA 11 Volume 1 of 2 12 Pages 1 - 157 13 14 15 Taken at the Instance of the Defendant 16 17 DATE: Friday, June 24, 2016 TIME: Commenced: Concluded: PLACE: Southern Reporting Company B. Paul Katz Professional Center (SunTrust Building) One Florida Park Drive South Suite 214 Palm Coast, Florida 32137 REPORTED BY: LEANNE W. FITZGERALD, FPR Florida Professional Reporter Court Reporter and Notary Public 18 19 20 21 22 8:59 a.m. 1:22 p.m. 23 24 25 Southern Reporting Company (386)257-3663 1 Case 18-2868, Document 278, 08/09/2019, 2628230, Page165 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 APPEARANCE OF COUNSEL 2 3 4 ON BEHALF OF THE PLAINTIFF: 5 BRADLEY J. EDWARDS, Esquire Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue Ft. Lauderdale, Florida 33301 954-524-2820 Brad@pathtojustice.com 6 7 8 9 10 ON BEHALF OF THE DEFENDANT: 11 LAURA A. MENNINGER, Esquire Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 303-831-7364 Lmenninger@hmflaw.com; Nsimmons@hmflaw.com 12 13 14 15 16 Also appearing: Jenny Martin, Videographer from Abel Virginia Giuffre, Plaintiff 17 18 19 20 21 22 23 24 25 Southern Reporting Company (386)257-3663 2 Case 18-2868, Document 278, 08/09/2019, 2628230, Page166 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 3 INDEX 2 3 ---------------------------------------------------- 4 VOLUME 1 (pages 1 - 157) 5 TONY FIGUEROA Direct Examination by Ms. Menninger 5 6 OATH OF REPORTER 156 CERTIFICATE OF REPORTER 157 7 8 --------------------------------------------------9 VOLUME 2 (Pages 158 - 258) 10 162 218 243 253 13 TONY FIGUEROA Cross-Examination by Mr. Edwards Redirect Examination by Ms. Menninger Recross-Examination by Mr. Edwards Further Direct Examination by Ms. Menninger 14 OATH OF REPORTER 257 15 CERTIFICATE OF REPORTER 258 11 12 16 --------------------------------------------------- 17 - - 18 19 20 21 STIPULATION It is hereby stipulated and agreed by and 22 between counsel present at this deposition and by 23 the deponent that the witness review of this 24 deposition would be waived. 25 Southern Reporting Company (386)257-3663 Case 18-2868, Document 278, 08/09/2019, 2628230, Page167 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 4 INDEX OF EXHIBITS 2 3 (MARKED BY THE DEFENDANT:) 4 5 Defendant's Exhibit 1 (Palm Beach County Sheriff's Reports Case Number 98041883) 42 Defendant's Exhibit 2 (Greenacres Reports) 71 Defendant's Exhibit 3 (Two Pictures of Apartment Building) 77 Defendant's Exhibit 4 (Palm Beach County Sheriff's Reports Case Number 02075321) 83 6 7 8 9 10 11 12 13 Defendant's Exhibit 5 (Royal Palm Beach Police Reports) 134 Defendant's Exhibit 6 (Robert's School Records) 144 14 15 16 - - - 17 18 (MARKED BY THE PLAINTIFF:) 19 Plaintiff's Exhibit 1 (Photos) 162 Plaintiff's Exhibit 2 (Passport) 163 20 21 22 23 - - 24 25 Southern Reporting Company (386)257-3663 Case 18-2868, Document 278, 08/09/2019, 2628230, Page168 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 BY MS. MENNINGER: 2 Q 3 Beach? 4 A 5 And where did you go after Royal Palm I believe it was South Area. I'm pretty sure it was South Area. 6 Q Did you go to another school after that? 7 A Yeah. 8 Q Is that also in Royal Palm Beach? 9 A No. 10 Worth. 11 alternative schools. 12 13 Q I went to Gold Coast after that. That's -- South Area was in Lake Gold Coast is in West Palm. They were both Did you ever go to a Survivors Charter School? 14 A Yes. 15 Q When did you go there? 16 A I'm not exactly sure of the date. I went there, too. But it 17 was somewhere after either -- I'm pretty sure it 18 was -- maybe -- I can't remember if it was Gold 19 Coast first or Survivor. 20 trying to remember. 21 one came first. 22 Q 23 24 25 But one of the -- I'm I honestly don't remember which That's all right. Can you describe for me Survivors Charter School? A What is it like, or was it like? I mean, like I said, it was an alternative Southern Reporting Company (386)257-3663 23 Case 18-2868, Document 278, 08/09/2019, 2628230, Page169 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 school. 2 kids, you know, who have gotten kicked out. 3 was pretty much like a last chance kind of school, 4 you know what I mean? 24 It was just pretty much a bunch of bad 5 Q Does it look like a school? 6 A Kind of. And it I mean, it had, like, a 7 cafeteria, and then it had a whole bunch of, like, 8 portables and stuff around there. 9 under -- it was, like, right near the Lake Worth. 10 remember there was, like, a bridge that went over 11 the interstate right by it. 12 just a little, you know, little crappy school. And it was I But, I mean, it was 13 Q Was it during the day or at night? 14 A It was during the day. 15 Q So regular school hours? 16 A Yeah. Well, it was actually a little bit 17 shorter hours. 18 know it was not like the full days. 19 mean, at the alternative schools, it's obviously not 20 up to regular high school standards. 21 just do pretty much stuff to get people to get out 22 of school, you know, so... I can't remember exactly. Because, I I mean, they 23 Q Get the credits that you need? 24 A Yeah. 25 But I So that way they can finish high school and not drop out and whatnot, so... Southern Reporting Company (386)257-3663 Case 18-2868, Document 278, 08/09/2019, 2628230, Page170 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 2 Q You actually go there in the morning, though, and take classes? 3 A Yeah. 4 Q And get checked in at attendance? 5 A Yeah. 6 Q And then you may leave a little earlier 7 than a regular school day? 8 A Uh-huh (affirmative). 9 Q All right. 10 A No, it was not online. 11 Q When you were at Survivors Charter School, 12 13 It's not a online program? did you ever see Ms. Roberts there? A Was it Survivors? I don't remember if it 14 was Survivors. 15 we were both -- was it -- I know we both went to one 16 of the schools. 17 maybe. 18 Q Did you see her there? 19 A Now, when we went to the school, like, we Or was it -- because I'm pretty sure I'm pretty sure it was Survivors, 20 were together afterwards. But I don't remember 21 exactly which one it was. I know it was one of 22 those alternative schools that we went to, though. 23 24 25 Q Okay. Did you -- was Wellington an alternative school? A No. Wellington is a -- is a real high Southern Reporting Company (386)257-3663 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page171 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 school, like a regular high school. 2 3 Q program? 4 5 Do you know if Wellington has an adult A They might. I mean, I really don't know. I'm not sure. 6 Q Did you ever take night classes there? 7 A No. 8 Q So you believe when you reunited with 9 10 Ms. Roberts in or around 2001, she had also gone to one of those alternative schools? 11 12 A When I reunited with her, no. We ended up, like, trying to go finish school. 13 Q Tell me about that. 14 A I mean, we just ended up going to one of 15 those alternative schools and didn't even finish 16 that. 17 18 Q So you two had both left school, but went back together -- 19 A Yeah. 20 Q -- to one of the alternative schools? 21 A Yeah. 22 Q And that may have been Survivors Charter 23 24 25 School? A Yeah. I'm pretty sure it probably was. I'm pretty sure. Southern Reporting Company (386)257-3663 26 Case 18-2868, Document 278, 08/09/2019, 2628230, Page172 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 Q You both wanted to get your GEDs? 2 A Yeah. 3 Q Get better jobs? 4 A Uh-huh (affirmative). 5 Q Things like -- that was the plan? 6 A Yeah. 7 Q But it did not work out? 8 A Yeah. 9 Q Do you know how long the two of you went 10 to Survivors Charter School? 11 A I honestly don't remember. 12 Q Okay. 13 You do have a recollection of going with her, though? 14 A Yeah. 15 Q Seeing her there? 16 A Uh-huh (affirmative). 17 Q I'm trying to get a little bit of a time 18 frame on the time that you reunited with 19 Ms. Roberts. 20 remember being in an apartment with her in September 21 of 2000 -- 9/11/2001; right? I know you said you lived -- you 22 A Yeah. 23 Q Do you think you had been together with 24 25 her for a while at that point? A It was probably, I'd say, like a month or Southern Reporting Company (386)257-3663 27 Case 18-2868, Document 278, 08/09/2019, 2628230, Page173 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 so. 2 long after I had moved in, so... 3 4 Like, I'm pretty sure. Q Because it was not too And just to be clear, she already lived in the apartment? 5 A Yeah. She lived in the apartment with her 6 ex-boyfriend Michael and JJ. 7 somebody else. 8 9 Q And I think there was I don't remember who, though. All right. That's where she was living when you reunited with her? 10 A Yeah. 11 Q And then you moved in? 12 A Yeah. 13 Q Did the other people move out? 14 A Yeah. 15 Q How long did you live there with 16 28 I kicked them out. Ms. Roberts? 17 A I think it was just till, like, the end of 18 the lease, so it was probably maybe, like, five or 19 six months. 20 not exactly [sic] on the whole time frame. 21 I'm pretty sure. I don't know. I'm Q That's okay. 23 A Yeah. 24 Q Where did you two move from there? 25 A I believe we either -- we went to her -- 22 I understand it was a while ago. Southern Reporting Company (386)257-3663 Case 18-2868, Document 278, 08/09/2019, 2628230, Page174 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 it was either her family's house or mine. 2 either one of the two. 3 another -- we were renting a house out in 4 Loxahatchee also, eventually. 5 a little trailer behind her parents' house. 6 7 8 9 10 Q It was And then we ended up getting But we also stayed in When did your relationship with Ms. Roberts end the second time? A When she went to Thailand and -- (Brief interruption.) A -- never heard from her again. 11 THE COURT REPORTER: 12 re-answer? 13 A Yeah. I'm sorry. Can you When Jeffry sent her to Thailand. 14 And then I never heard from her again until 15 freaking, like, two days ago. 16 BY MS. MENNINGER: 17 Q You heard from her two days ago? 18 A Yeah. She had called me to apologize 19 about, obviously, everything about me getting 20 dragged into this mess. 21 much about, you know, the way shit ended, and pretty 22 much tried just -- her apologizing mainly about 23 dragging me all into this and having to make me 24 get -- you know, knowing how I have my family and 25 stuff now. And we talked just pretty And that was pretty much it, so... Southern Reporting Company (386)257-3663 29 Case 18-2868, Document 278, 08/09/2019, 2628230, Page175 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 Q Another instant connection. 2 A Uh-huh (affirmative). 3 Q From the time Ms. Roberts left to go to 4 Thailand until today, have you seen her? 5 A 6 Nope. And to be honest, it still does not even 7 feel real that she's sitting right there across from 8 me. 9 10 11 Q Well, you offered to get in touch with her a couple of times? A I know. But, like I said, it's just -- it 12 still does not seem like this is actually happening. 13 Like, she's -- I don't know. 14 ghost or seeing one. It's like talking to a 15 Q Does she look different now? 16 A Yeah. 17 Q How? 18 A Just more mature, more older. 19 Q When you were with Ms. Roberts the first 20 time in '98 -- 21 A Uh-huh (affirmative). 22 Q -- you believe that relationship lasted 23 24 25 just a couple of weeks? A Yeah. I'm not exactly sure, but it was pretty brief. Southern Reporting Company (386)257-3663 37 Case 18-2868, Document 278, 08/09/2019, 2628230, Page176 of 648 Video Deposition of Tony Figueroa (Volume 1) 125 1 A I believe so, yes. 2 Q What did she tell you about that? 3 A I -- I think that maybe he -- I mean, I 4 don't know exactly. 5 remember hearing about him, but I don't remember 6 what she said about him. 7 8 Q I don't really remember. I Did Ms. Roberts ever tell you that she had met Al Gore? 9 A Not that I'm aware of. 10 Q Did Ms. Roberts ever tell you that she had 11 met a foreign president? 12 A I'm not sure; I'm not sure. 13 Q Did Ms. Roberts ever tell you she had met 14 a prime minister? 15 A I don't know. 16 Q Did Ms. Roberts ever tell she had met a 17 18 senator? A Not that I'm aware of. I mean, she's told 19 me that she met a bunch of people before. 20 it started becoming, like, an almost everyday thing 21 about -- just hearing about famous people with 22 Jeffrey and stuff like that, it's, like, I kind of 23 didn't, like, tone it out, but I just -- it became 24 normal, so I just stopped, like, listening to all 25 the details, because I was not going to meet these Southern Reporting Company (386)257-3663 And after Case 18-2868, Document 278, 08/09/2019, 2628230, Page177 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 people, you know what I mean? 2 right. 3 Q 4 It's just, like, all Was she excited that she was meeting famous people? 5 A Yeah. 6 Q Was that a job perk? 7 A Obviously. 8 Q She talked about it a lot? 9 A Yeah. 10 Q To the point where you were drowning it A Well, that's what I'm saying. 11 12 out? It was not 13 like I was drowning it out. 14 she was with Jeffrey, and he was, obviously, 15 well-connected with everybody. 16 you know, a special occasion, per se. 17 was, but it's not like it was -- it was not very not 18 rare so... 19 20 Q It's just I knew that So it was not like, You know, it Did she show you any photographs of herself with famous people? 21 A No. 22 Q Did you see a photograph of her with 23 Prince Andrew -- 24 A Yes. 25 Q -- in her possession? Southern Reporting Company (386)257-3663 126 Case 18-2868, Document 278, 08/09/2019, 2628230, Page178 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 2 BY MS. MENNINGER: Q Mr. Figueroa, you mentioned that you and 3 Ms. Roberts attempted to go to back to school while 4 you were together -- 5 A Yes. 6 Q -- to get your GED? 7 A Yeah. 8 Q And you believe that you went to the 9 10 Survivors Charter School? A 11 12 15 16 17 18 Yes. MS. MENNINGER: Okay. I'm going to mark Defendant's Exhibit 6. 13 14 Yes. (Defendant's Exhibit 6 was marked for identification.) BY MS. MENNINGER: Q This is a school record for Ms. Roberts that lists the names of various schools. A And -- So it was Survivors, obviously. That's 19 the only one on that list that isn't -- or that's 20 there that's on mine, as well. 21 Q Okay. 22 A Other than the other ones, but... 23 Q All right. 24 25 So you recognize Survivors Charter School on Ms. Roberts' school records? A Yeah. That's what I'm saying. Southern Reporting Company (386)257-3663 Since that 144 Case 18-2868, Document 278, 08/09/2019, 2628230, Page179 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 is the one on here, that's -- that's completely 2 clear. 3 Gold Coast. 4 Q I could not remember if it was that one or Okay. There is an entry date for 5 Ms. Roberts at Survivors Charter School of 6 10/12/2001, and a withdrawal on 3/7 of '02. 7 see that? 8 9 10 11 12 13 14 15 A I mean, it's this; right? Do you I mean, that's the top. Q The entry date of 10/12/01, withdrawal 3/7/02 at Survivors? A Okay. I did not know what those numbers -- I did not realize that that was a date. Q I understand. And I know you did not make this record. 16 So I'm just wanting to know if that's 17 consistent with your recollection, that you guys 18 went to school in the fall of 2001 until the -- 19 A Yeah, that sounds about right. 20 Q -- March of 2002. 21 A Yeah. 22 Q And you both went to school together? 23 A Uh-huh (affirmative). 24 Q In the mornings? 25 A Yeah. It sounds right? Southern Reporting Company (386)257-3663 145 Case 18-2868, Document 278, 08/09/2019, 2628230, Page180 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 2 Q 146 And got out of school at some earlier time than a regular school day? 3 A Yeah. 4 Q Do you recall Ms. Roberts going to Royal 5 Palm Beach High? 6 frame. 7 A I -- I don't recall. 8 Q Do you recall her, during the time you 9 10 Again, this is in the 2001 time were with her, taking any night classes at Wellington High School? 11 A I don't recall. 12 Q Is it possible? 13 A It's a possibility. 14 15 16 17 I really don't. MR. EDWARDS: Object to the form. BY MS. MENNINGER: Q Do you know whether Wellington has a night school program? 18 A 19 could. 20 Q You went there in ninth grade? 21 A Yeah. 22 23 24 25 Like I said before, I don't know. They It was during the day, though. I have no clue about night school. Q Got it. But you do have a memory about Survivors Charter School? Southern Reporting Company (386)257-3663 Case 18-2868, 08/019ng 2602?3g0dn ialge181 of 648 eposmon 156 l?guer CERTIFICATE OF OATH STATE OF FLORIDA COUNTY OF FLAGLER I, the undersigned authority, certify that TONY FIGUEROA personally appeared before me on June 24, 2016, and was duly sworn. WITNESS my hand and official seal this 5th day of July, 2016. Maj/i?gw Leanne W. Fitzgerald Notary Public - State of Florida My Commission No. FF060921 Expires: February 8, 2018 Digital Certificate Authenticated By Symantec Southern Reporting Company (386)257-3663 Case 18-2868, Document 278, 08/09/2019, 2628230, Page182 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 CERTIFICATE OF REPORTER 2 STATE OF FLORIDA 3 COUNTY OF VOLUSIA ) ) ) 4 5 6 7 8 9 10 11 12 I, Leanne W. Fitzgerald, Court Reporter, do hereby certify that I was authorized to and did stenographically report the deposition of TONY FIGUEROA; and that the foregoing transcript is a true record of my stenographic notes. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. 13 Dated this 5th day of July, 2016. 14 15 16 17 18 19 20 __________________________________ Leanne W. Fitzgerald, FPR Florida Professional Reporter 21 22 Digital Certificate Authenticated By Symantec 23 24 25 Southern Reporting Company (386)257-3663 157 Case 18-2868, Document 278, 08/09/2019, 2628230, Page183 of 648 EXHIBIT !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page184 of 648 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS __________________________________________________ CONFIDENTIAL VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II November 14, 2016 __________________________________________________ VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. __________________________________________________ APPEARANCES: BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 405 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page185 of 648 1 2 3 4 5 6 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura Menninger, Esq. Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant 7 8 Also Present: Ann Lundberg, Paralegal Maryvonne Tompkins, Videographer 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 406 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page186 of 648 1 Pursuant to Notice and the Federal Rules 2 of Civil Procedure, the continued video 3 deposition of VIRGINIA GIUFFRE, called by Defendant, 4 was taken on Monday, November 14, 2016, commencing at 5 8:04 a.m., at 150 East 10th Avenue, Denver, Colorado, 6 before Pamela J. Hansen, Registered Professional 7 Reporter, Certified Realtime Reporter and Notary 8 Public within Colorado. 9 * * * * * * * I N D E X 10 11 VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II 12 EXAMINATION 13 By Ms. Menninger PAGE 354 14 15 16 17 18 19 20 21 22 23 24 25 !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 472 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page187 of 648 1 INDEX OF EXHIBITS (continued) 2 INITIAL REFERENCE 3 DESCRIPTION 4 Exhibit 1 Settlement Agreement and General Release 355 Exhibit 2 List of names 370 Exhibit 3 Photocopy of photograph 408 Exhibit 4 Photocopy of photograph, with attachments 411 Exhibit 5 Photocopy of photograph, with attachments 417 Exhibit 6 Photocopy of photograph, with attachments 423 12 Exhibit 7 Statements 437 13 Exhibit 8 History of education, with attachment 462 Exhibit 9 Application for Employment, with attachment 474 Exhibit 10 The Great Outdoors Community Services Association, Inc. Termination Form, with attachments 481 Exhibit 11 7/6/2016 letter to Schultz from Hayek, with attachments 484 Exhibit 12 Patient Registration Information, with attachments 490 Exhibit 13 CVS Prescription Records document, 7/29/2016, with attachment 502 Exhibit 14 Affidavit of Custodian of Records, Walgreen Company, with attachments 507 5 6 7 8 9 10 11 14 15 16 17 18 19 20 21 22 23 24 25 !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 47. !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page188 of 648 1 INITIAL REFERENCE DESCRIPTION 2 Exhibit 15 Patient Health Summary, Clifton Beach Medical & Surgical, printed on 6/28/2016 512 Exhibit 16 Portions of deposition transcript of Virginia Giuffre taken May 3, 2016 533 Exhibit 17 Amendment/Errata Sheet signed May 31, 2016 by Virginia Giuffre 540 8 Exhibit 18 Ad for Mar-a-Lago Club 548 9 Exhibit 19 The Mar-a-Lago Club, L.C. Employment Policies, October 28, 1995 549 Exhibit 20 Page from the Mar-a-Lago Club Employment Policies, Revised 10/2001 550 3 4 5 6 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 471 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page189 of 648 1 A Yes. 2 Q And you believe the Neiman Marcus was 3 4 located in which city? A Well, it's around Fort Lauderdale. 5 can't tell you exactly. 6 like Broward County? I Fort Lauderdale is so big, Is that the word for it? 7 Q And what did you do at Neiman Marcus? 8 A I worked in the changing rooms. 9 Q And what did you do in the changing room? 10 A I think I just like -- if I remember 11 right, I just put clothes away that people left in 12 there. 13 sizes for women who wanted different sizes of the 14 same product. 15 16 Q Probably went out to get sizes, different And where did you work after Neiman Marcus? 17 A Taco Bell. 18 Q Did you work at Southeast Employee 19 20 Management Company? A I don't recognize that. I don't know if 21 that's a payroll company or what it is. 22 what Southeast -- what is it called? I don't know 23 Q Southeast Employee Management Company. 24 A No, I don't remember that. 25 Q Did you ever work as a temp? !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 082 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page190 of 648 1 A Not that I remember. 2 Q Going to different offices and filling in? 3 A No. 4 Q Did you work for Oasis Outsourcing? 5 A I don't -- I don't know if that's a 6 payroll company or if that's an actual place, but 7 that doesn't ring a bell. 8 9 10 11 Q Did you -- do you know how much you got paid when you were working at places like Oasis Outsourcing? A Well, considering I don't know if I worked 12 at Oasis Outsourcing, I wouldn't even know how much I 13 got paid. 14 15 Q Did you review your Social Security records? 16 A Yes. 17 Q You saw Oasis Outsourcing listed there? 18 A Right, but like I said, it doesn't even 19 20 21 22 ding a bell at all. Q Do you know how much money they said you made from them? MS. MCCAWLEY: Objection. If you want to 23 show her the documents, she can see what amount is 24 listed and answer your questions, but if you're not 25 going to show her the document, that's the best she !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 08. !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page191 of 648 1 don't know where I was living. 2 3 Q Okay. Did you indicate whether you had gone to school? 4 A Yes, I did. 5 Q What did you indicate? 6 A I indicated that I attended Survivors 7 Charter School for four years and had a high school 8 diploma. 9 Q And you graduated? 10 A Well, I didn't. I just wanted to get a 11 job, and I wanted it to look good, so I fluffed it 12 up. 13 14 Q So you wrote that down in your handwriting on this application, correct? 15 A I did. 16 Q And it was not true, correct? 17 A Again, I'm not proud of it. I just didn't 18 have any other way of getting a job and I just 19 thought if I put that down there, I might be 20 considered. 21 Q You indicated when you were younger you 22 volunteered for six years at a riding clinic. 23 the name of the riding clinic? 24 25 A Vince Ramos. What's And I'm not too sure if it was six years, but I started off there quite young, !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 087 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page192 of 648 1 a former employer is the Indigo Bar and Grill, 2 correct? 3 A Yes. 4 Q Is that true? 5 A No, it was not. 6 Q On the page before that, it indicates you 7 went to Royal Palm Beach High School. 8 your handwriting? Is that in 9 A Yes, it is. 10 Q And it says you went for four years and 11 you graduated? 12 A Yes. 13 Q In your handwriting? 14 A Yes. 15 Q Is that true? 16 A No. 17 Q This was an application you filled out in 18 January of 2014, correct? 19 A Correct. 20 Q The page before that is your -- portion of 21 your resume I think we have previously discussed, but 22 just confirming, you did send that resume to this job 23 application, correct? 24 A I did. 25 Q And you indicated you had worked at !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 054 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page193 of 648 1 STATE OF COLORADO) 2 ) 3 COUNTY OF DENVER ) 4 ss. REPORTER'S CERTIFICATE I, Pamela J. Hansen, do hereby certify that 5 I am a Registered Professional Reporter and Notary 6 Public within the State of Colorado; that previous to 7 the commencement of the examination, the deponent was 8 duly sworn to testify to the truth. 9 I further certify that this deposition was 10 taken in shorthand by me at the time and place herein 11 set forth, that it was thereafter reduced to 12 typewritten form, and that the foregoing constitutes 13 a true and correct transcript. 14 I further certify that I am not related to, 15 employed by, nor of counsel for any of the parties or 16 attorneys herein, nor otherwise interested in the 17 result of the within action. 18 19 20 In witness whereof, I have affixed my signature this 23rd day of November, 2016. My commission expires September 3, 2018. 21 22 23 _______________________________ Pamela J. Hansen, CRR, RPR, RMR 216 - 16th Street, Suite 600 Denver, Colorado 80202 24 25 !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 734 Case 18-2868, Document 278, 08/09/2019, 2628230, Page194 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page195 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS SOCIAL SECURITY ADMINISTRATION OFFICE OF CENTRAL OPERATIONS 6100 WABASH AVENUE BALTIMORE MARYLAND 21215 Date: 10/25/2016 BOIES SCHILLER AND FLEXNER 401 LAS OLAS BLVD STE 1200 FORT LAUDERDALE FL 33301-2211 We are sending the statement of earnings requested for: Number Holder's Name: VIRGINIA GIUFFRE Social Security Number: Years Requested: 1998 THRU 2002; 2013 THRU 2015 Control Number: 16294125319 Remittance Number: 201610240012 Enclosure(s): Earnings Statement GIUFFRE009175 'Ivnmlu- . .. WV Case 18-2868, Document 278, 08/09/2019, 2628230, Page196 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS SOCIAL SECURITY ADMINISTRATION EARNINGS RECORD INFORMATION Date: 10/25/2016 Our records show the amount of earnings reported, not the amount of Social Security taxes that were paid. Wages were first covered under Social Security in 1937. Therefore, 1937 is the first year for which earnings may be shown on our records. Employers were required to report earnings semi-annually in 1937, and on a quarterly basis for the years from 1938 through 1977. Beginning with 1978, employers are required to report earnings annually. Our records do not show the exact date of employment (month and day) because we do not need this information to figure Social Security benefits. Employers do not give us this information. Each year, there is a maximum amount of earnings that is subject to Social Security taxes and is used to compute benefits. If a person earns more than this maximum amount, the earnings statement will usually show the maximum rather than the total earnings. Maximum benefits can be found on the SSA website. Beginning in 1951, self-employed persons could also receive Social Security credit for their work. The maximum amounts of self-employment earnings that are subject to Social Security taxes and are used to compute benefits can also be found on the SSA website. If you have any questions, you should call, write, or visit any Social Security office. If you visit or call, please bring this letter. It will help us answer questions. The toll free number to call is 1-800-772-1213 (for the deaf or hard of hearing, call our TTY number, 1-800-325-0778). GIUFFRE009176 CONHDENHAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page197 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS FROM: SOCIAL SECURITY ADMINISTRATION OFFICE OF CENTRAL OPERATIONS 6100 WABASH AVENUE BALTIMORE MARYLAND 21215 NUMBER HOLDER NAME: VIRGINIA GIUFFRE YEARS REQUESTED: 1998 THRU 2002; 2013 THRU 2015 BOIES SCHILLER AND FLEXNER 401 LAS OLAS BLVD STE 1200 FORT LAUDERDALE FL 33301 EMPLOYER NUMBER: KFC USA INC PAYROLL DEPT 5200 COMMERCE CROSSING DR LOUISVILLE KY 40229-2182 YEAR QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 1999 $140.70 EMPLOYER NUMBER: PUBLIX SUPER MARKETS INC PO BOX 32018 LAKELAND FL 33802-2018 YEAR QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 1999 $216.69 EMPLOYER NUMBER: ASCENSION CHILD CARE CENTER ASCENSION PEACE CHILD CARE CENTER 2701 STATE ROAD 7 LAUD LAKES FL 33313-2731 YEAR QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 1999 $216.97 PAGE 1 GIUFFRE009177 I W3 I M11133 Case 18-2868, Document 278, 08/09/2019, 2628230, Page198 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS EMPLOYER NUMBER: AVICULTURAL BREEDING RESEARCH CENTER ERNEST LAKS 14201 125TH AVE WEST PALM BCH FL 33418-7945 YEAR QTR 2ND QTR 3RD QTR 4TH QTR 2000 EMPLOYER NUMBER: SOUTHEAST EMPLOYEE MANAGEMENT COMPANY 2559 PALM DEER DR LOXAHATCHEE FL 33470-2563 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR EMPLOYER NUMBER: MAR-A-LAGO CLUB LLC TRUMP DONALD GEN PTR TRUMP ORGANIZATION 1100 OCEAN BLVD PALM BEACH FL 33480-5004 YEAR QTR 2ND QTR 3RD QTR 4TH QTR 2000 EMPLOYER NUMBER: OASIS OUTSOURCING VI INC 2054 VISTA PKWY STE 300 WEST PALM BCH FL 33411-6742 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR EMPLOYER NUMBER: NEIMAN-MARCUS GROUP LLC NEIMAN MARCUS GROUP LTD SOLE MBR 1201 ELM ST DALLAS TX 75270-2102 YEAR QTR 2ND QTR 3RD QTR 4TH QTR 2000 PAGE 2 TOTAL $99.48 TOTAL $3,212.44 TOTAL $1,866.50 TOTAL $2,037.60 TOTAL $1,440.79 GIUFFRE009178 Case 18-2868, Document 278, 08/09/2019, 2628230, Page199 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS FOR SSN EMPLOYER NUMBER: - MANNINOS INC MANNINOS RESTAURANT 12793 FOREST HILL BLVD WEST PALM BEACH FL 33414-4749 YEAR IST QTR 2ND QTR 3RD QTR 2001 EMPLOYER NUMBER. CCI OF ROYAL PALM INC ROBERT PURR TTEE 2255 GLADES RD STE 337-w BOCA RATON FL 33431-7379 YEAR IST QTR 2ND QTR 3RD QTR 2002 EMPLOYER NUMBER: ROADHOUSE GRILL INC ROBERT FURR TTEE IN BANKRUPTCY 2255 GLADES RD STE 337W BOCA RATON FL 33431-7379 YEAR IST QTR 2ND QTR 3RD QTR 2002 EMPLOYER NUMBER: MARC PINKWASSER DVM PA 13860 WELLINGTON TRCE STE 31 WELLINGTON FL 33414-8541 YEAR 1ST QTR 2ND QTR 3RD QTR 2002 EMPLOYER NUMBER: GREAT OUTDOORS PREMIER RV-GOLF RESORT COMMUNITY ASSOC INC 145 PLANTATION DR TITUSVILLE FL 32780-2528 YEAR IST QTR 2ND QTR 3RD QTR 2014 PAGE 3 QTR 4TH 4TH 4TH 4TH QTR QTR QTR QTR TOTAL $212.00 TOTAL $403.64 TOTAL $1,247.90 TOTAL $1,561.75 TOTAL $171.83 GIUFFRE009179 Al! Manon . . vnvn?ov- - MU I human CW Case 18-2868, Document 278, 08/09/2019, 2628230, Page200 Of 648 SSA-1826 ITEMIZED STATEME OF EARNINGS THERE ARE NO OTHER EARNINGS RECORDED UNDER THIS SOCIAL SECURITY NUMBER FOR REQUESTED PAGE 4 GIUFFRE009180 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page201 of 648 EXHIBIT January 30, 2003 To Whom It May Concern, Skye Roberts has been a most valuable employee at The Mar-a-Lago Club since April of 2000. While employed as a maintenance crew team member, he has been responsible for maintaining the ?ve championship red-clay tennis courts as well as keeping all of the individual air conditioning units working and in tip-top shape. It is my understanding that Skye is relocating to Colorado. Should he ever return to Florida, he would be eligible for re-hire. onald J. Trump {14,54,554 m. PA LM BEACH. VLDRIDA 1100 South Ocean Bouiexmrl, Palm Beach ?orid; 33%30 46373 5332608 Fax (407) 833265.469 Case 18-2868, Document 278, 08/09/2019, 2628230, Page203 of 648 TERMINATIONS LAST NAME Abbott Acevedo Adams Adams Adams Addison Adelfio Adler Aldahondo Alexis Allen Almeida Almgren Alves Anaya Anderson Andres-Felix Annunziata Anton Aquino Argueta Armstrong Ash Ashenbrenner Auguste Bacon Bader Bader Baghouli Bahena Baker Balkunas Banks Baranek Baron Barr Barr Barrett Barrill Beam Beaudoin Beckett Benarroch Bend Benitez Bennett Benney Benoit Bernal FIRST NAME Philip Michael Zane Cynthia Patrick Andrea Peter Jessica Francisco Genicia Suzanne Tiberio Shane Victor Orlando Sandra Francisco Susan Frank Jorge Irma April Carol William Firenze John Susan Erwin Adel Lucio Teresa Vicki Michael Katherine Todd James Gail Loraine London Stephen Louis Sam Alice John Sixta Thomas Tabitha Mark Ana Box #1 Box #4 Box #3 Box #1 Box #1 Box #4 Box #4 Box #1 Box #6 Box #3 Box #1 Box #4 Box #3 Box #4 Box #4 Box #6 Box #4 Box #3 Box #1 Box #4 Box #3 Box #4 Box #6 Box #3 Box #6 Box #4 Box #1 Box #1 Box #6 Box #6 Box #3 Box #6 Box #4 Box #3 Box #6 Box #4 Box #1 Box #3 Box #3 Box #6 Box #1 Box #3 Box #1 Box #1 Box #3 Box #3 Box #3 Box #1 Box #6 Page 1 of 17 MAR-A-LAGO 0161 Case 18-2868, Document 278, 08/09/2019, 2628230, Page204 of 648 TERMINATIONS LAST NAME Bernhardt Berube Beswick Beverly Bezwiechin Blake Bloch Blyth Bobrowski Bocksch Boehm Boettcher Bogert Boisvert Bonilla Bork Borrego Borrell Borrelli Boudreau Boukhalfa Bouschet Brass Brassler Brendel Brennan Briante Bridger Briggs Brown Brown Brummel Bryan Bryant Buckingham Buckley Budziak Burdett Burgess Burgon Burke Burke Burlew Burton Butler Calder Caldwell Camacho Camilleri FIRST NAME Gretchen Michael Allan Tim Cham Howard Michael Alison Michele Kristy Erica Joe Debra Cory Jose Allen Sandra Salvator Lisa Matthew Said Courtney Baysson Chris Kendra Mary Gerard Jody Jacqueline Eleanor William Denis Amy William Annette Cynthia Diane Jill Lawrence Helya Maureen Christopher Gary Myles Michael Malgorzata Karen Darren Mark Box #1 Box #4 Box #6 Box #4 Box #3 Box #3 Box #3 Box #6 Box #3 Box #4 Box #3 Box #6 Box #3 Box #1 Box #4 Box #4 Box #4 Box #1 Box #6 Box #4 Box #6 Box #4 Box #1 Box #1 Box #6 Box #1 Box #1 Box #3 Box #1 Box #6 Box #6 Box #3 Box #1 Box #4 Box #1 Box #4 Box #1 Box #6 Box #3 Box #6 Box #4 Box #4 Box #1 Box #3 Box #4 Box #3 Box #1 Box #4 Box #4 Page 2 of 17 MAR-A-LAGO 0162 Case 18-2868, Document 278, 08/09/2019, 2628230, Page205 of 648 TERMINATIONS LAST NAME Campbell Candella Cantrell Capozzi Carlisle Carr Carroll Carvalho Casher Castano Castillo Castro Catranbone Cavinee Celestin Chambers Chapuis Charles Charles Chillingsworth Chioffe Christie Ciaffone Ciccia Clark Cleveland Cloninger Coffman Cohen Cole Collins Collins Conroy Cordero Cordero Cortes Corti Coutts Cox Cronin Cross Crostic Crowley Cruz Cruz Crystle Cuervo Cummings Curran FIRST NAME Benjamin Charles Dantelle Christina Kevin Janet VALerie Deo Jeremy Ku Sandra Juan Angela Krystal Jean Craig Rene Fresnel Sylfida Vanette James Michael Cora John Kimberly Trisha Tana Connie Julius Joanne Yvette Barbara James Vera Vero Roberto Debra Rachael Emory Sonia Deborah Barbara Tricia Lonjino Israel Joshua Anamaria Meghan Maureen Box #3 Box #4 Box #4 Box #4 Box #1 Box #3 Box #4 Box #3 Box #1 Box #4 Box #6 Box #4 Box #1 Box #4 Box #3 Box #1 Box #1 Box #6 Box #6 Box #6 Box #1 Box #4 Box #6 Box #3 Box #1 Box #6 Box #3 Box #4 Box #6 Box #1 Box #1 Box #1 Box #4 Box #1 Box #1 Box #3 Box #3 Box #1 Box #1 Box #6 Box #6 Box #4 Box #6 Box #6 Box #6 Box #4 Box #4 Box #6 Box #1 Page 3 of 17 MAR-A-LAGO 0163 Case 18-2868, Document 278, 08/09/2019, 2628230, Page206 of 648 TERMINATIONS LAST NAME Czerniak Daley Damiano Davis Davis Deak Dean Deleon Delia Dellay DeLorenzo DeNarvaez DePaula DeRiso DeSernia Devine DeVito DiBenedetto Dickens Dieu Donne Dimitrova Dodge Dombayci Domnick Donnelly Dorsa Drake Drogowski Dubois Dubois Dumstra Eaton Edge Edwards Egger Elkhoury Ellingworth Ellis Elwell Enger English Espinoza Espinoza Espinoza Estime Ettehad Faaland Faba Fagen FIRST NAME Anthony Chad Anthony Jeremy Eric Stephen Laurie Elais Frank Scott Mark Claudia Danielle Gina Sulamita Keith Dawn Melissa George Jean Charles Violeta Virginia Yimaz Mark Jennie Antonio Charlie David Lydia Crystal Adam Adam Jerod Don Paul Toni David Christine Douglas Mark Mistie Francisca Henner Carlos Karl Shahla Roy Juan Lanell Box #4 Box #6 Box #4 Box #4 Box #1 Box #6 Box #6 Box #4 Box #4 Box #1 Box #6 Box #3 Box #4 Box #1 Box #3 Box #1 Box #1 Box #3 Box #6 Box #4 Box #3 Box #1 Box #6 Box #1 Box #3 Box #1 Box #6 Box #6 Box #4 Box #6 Box #6 Box #4 Box #4 Box #4 Box #6 Box #6 Box #6 Box #1 Box #1 Box #3 Box #3 Box #4 Box #3 Box #6 Box #1 Box #4 Box #1 Box #1 Box #1 Page 4 of 17 MAR-A-LAGO 0164 Case 18-2868, Document 278, 08/09/2019, 2628230, Page207 of 648 TERMINATIONS LAST NAME Faraci Fasel Faulk Feal Feick Fein Fernandez Ferree Fesser Fidanovic Figueroa Filippone Finch Finckenor Fink Fiorentino Firat Fischbach Fischer Fiumara Flores Folmer Foss Fox Francoeur Fratus Frelich Frey Friday Frith Fritz Frost Gacon Galla Galloway Galloza Garcia Garcia-Douglas Garrido Gedeum Gell Gervais Getgood Gibeault Gillie Gividen Glass Goicochea Goldrich FIRST NAME Franklin Jeremy Joel Jose Gretchen Lawrence Jose Tonya Michael Novak Irina Vittorio Michael George Roger Maria Turabi Nora Rosemary Michele Pedro Ronald John Lisa Mary Lou Donna Jason Kenneth Jennifer Cynthia John Mark Allan Galla Kurt Sergio Souad Marcia Dante Rosalie William Marie Russell Larry Barbara Nathan Kevin Darcy Amanda Box #1 Box #4 Box #1 Box #4 Box #4 Box #1 Box #6 Box #3 Box #1 Box #6 Box #3 Box #4 Box #1 Box #4 Box #4 Box #4 Box #1 Box #3 Box #4 Box #3 Box #3 Box #1 Box #1 Box #6 Box #6 Box #3 Box #6 Box #4 Box #6 Box #1 Box #1 Box #1 Box #1 Box #1 Box #6 Box #3 Box #6 Box #6 Box #4 Box #3 Box #3 Box #6 Box #1 Box #1 Box #1 Box #1 Box #1 Box #6 Box #3 Page 5 of 17 MAR-A-LAGO 0165 Case 18-2868, Document 278, 08/09/2019, 2628230, Page208 of 648 TERMINATIONS LAST NAME Golemis Gomaa Gonzales Gonzales Gonzalez Gonzalez Gonzalez Gonzalez Goodman Goupy Gowdy Granjales Grant Grasso Graves Green Greene Greenwood Gregson Grieve Griffin Griffin Griffiths Griggs Grosso Guerin Gutierez Gutierez Gutierrez Guyierrez Hader Hagen Haggar Hamby Harris Hartsough Hatch Hatfield Havican Heanssler Hefel Hemings Hennessee Hernandez Hernandez Hernandez Herrara Herth Higgins FIRST NAME Sam Ashraff Augustine Dora Raul David Elsa Alex William Bernad Charles Myriam Everton William Erika Michelle James Elizabeth Scott Daniel Mark Michael Sandra Dora Peter Jean Mauricio Porfidio Antonio Warren Karen Kyla Karen Michael Dan Cheryl Wendy Michael Robert Pete Eric Romy Jason Gladys Alexander Luis Julio Francesca Jennifer Box #3 Box #6 Box #4 Box #4 Box #3 Box #1 Box #1 Box #6 Box #4 Box #6 Box #1 Box #6 Box #4 Box #3 Box #4 Box #1 Box #1 Box #1 Box #3 Box #3 Box #1 Box #1 Box #1 Box #3 Box #1 Box #1 Box #1 Box #1 Box #3 Box #6 Box #3 Box #1 Box #3 Box #1 Box #6 Box #1 Box #1 Box #1 Box #6 Box #3 Box #6 Box #6 Box #3 Box #3 Box #3 Box #3 Box #4 Box #3 Box #4 Page 6 of 17 MAR-A-LAGO 0166 Case 18-2868, Document 278, 08/09/2019, 2628230, Page209 of 648 TERMINATIONS LAST NAME Higgs Hill Hill Hinkin Ho Hochong Hodes Holcomb Holryid Homenuik Hong Hopkins Horsky Hossain Hoyle Huber Huguet Hulsey Hutchins Hyde Hylton Ibrahim Infante Insani Ioli Irvine Jacob Jacobs Jacques Jacques Jaferali James Jankowski Jaramillo Jean Jenkins Jesperson Johnansen Johnson Johnson Johnson Johnson Johnson Johnson Johnson Johnson Jones Jones Joseph FIRST NAME Kathleen Donna Samuel Cynthia Stella Anthony Robin Mary Mary Wilfred David Victoria George Mohammed Patricia Frank Roberto Thomas Marguerite Rose Longsworth Ashraf Carlos Mark Gina Marche Maureen Rick Dudley Nixon Errol Buddy Keith Olmes Jacques Todd Henrik Elise Eric Josh Chad Debbie Laura Jade Walter Cathiejo Steve Regina Elisca Box #1 Box #4 Box #1 Box #3 Box #1 Box #6 Box #4 Box #3 Box #1 Box #6 Box #6 Box #6 Box #3 Box #1 Box #4 Box #4 Box #3 Box #4 Box #4 Box #6 Box #6 Box #4 Box #4 Box #3 Box #4 Box #3 Box #1 Box #1 Box #1 Box #6 Box #4 Box #6 Box #1 Box #1 Box #6 Box #4 Box #3 Box #6 Box #4 Box #4 Box #1 Box #1 Box #1 Box #1 Box #1 Box #6 Box #4 Box #3 Box #6 Page 7 of 17 MAR-A-LAGO 0167 Case 18-2868, Document 278, 08/09/2019, 2628230, Page210 of 648 TERMINATIONS LAST NAME Juan Juan Kaiser Kalson Kapreilian Karius Kaufman Keady Keiser Keller Kelley Kelly Kelly Kennedy Kenney Kenny Kent Kincl King King King Kirby Kleinfeld Kline Kole Kowalski Kresic Krogman Krpina-Zito Kruppenbacher Kuiper Kuntz LaCerte Laidlaw Laine Laing Lang Langford Langweiler Lanunziata Laskaris Laufenberg Lawlor Lefrancois Leite Leitzell Leone Leonova LeRoux FIRST NAME Miguel Tomas Angelina Stephen Vince Peter Michael Robert Mike Lisa Mikchael Nancy Lois John Sean Marlou Brian Scott Joseph Helen Jeffrey Michael Brian Robert Eileen Karen Susan Blago Terry Marija Michael Gary Carlson Troy Kenneth Brent Melissa Eric Chad Albert Stacia Alexandra Lynette Thomas Aaron Paulo jTara Nick Victoria Marthinus Box #4 Box #6 Box #4 Box #1 Box #4 Box #4 Box #1 Box #1 Box #4 Box #4 Box #1 Box #4 Box #1 Box #3 Box #3 Box #4 Box #4 Box #4 Box #4 Box #3 Box #6 Box #1 Box #1 Box #6 Box #4 Box #1 Box #1 Box #1 Box #4 Box #6 Box #3 Box #4 Box #1 Box #3 Box #6 Box #6 Box #4 Box #6 Box #1 Box #6 Box #1 Box #1 Box #3 Box #3 Box #1 Box #4 Box #1 Box #6 Box #6 Page 8 of 17 MAR-A-LAGO 0168 Case 18-2868, Document 278, 08/09/2019, 2628230, Page211 of 648 TERMINATIONS LAST NAME Lester Lewis Leyden Liberte Lightbourne Lisec Locke Logalbo Lopez Lopez Lopez Lopez Lopez Love Lowe Lugo Lusse Luxton Lyle Lynam Lynch MacDonnell Machado Magerus Malay Maldonado Maldonaldo Mann Mannion Marcenaro Marchman Marino Marrone Marshall Martinez Martinez Martinez Massias Mateo Maurice Max Maxwell McAlees McBrayer McCabe McCambridge McCann McCarthy McConnell FIRST NAME Carolina Corey Gene Monney Andrianne Lisa Michelle Franklin Claudio Julian Marvin Mario Roger Rena Karl Christianne Robert Stephanie Mary Jane Robert Cheri Thomas Carlos Georges Maya Juvencio James Andrew Deidre Eduardo Henry Mindy Kimberly John Steve Zach Hector Caroline Alfredo Lucas Marie Susan Terence Brook Cassandra Kevin Angela Kevin Shannon James Box #6 Box #1 Box #6 Box #3 Box #1 Box #1 Box #3 Box #6 Box #4 Box #3 Box #3 Box #6 Box #6 Box #3 Box #3 Box #3 Box #1 Box #4 Box #6 Box #6 Box #3 Box #7 Box #4 Box #4 Box #3 Box #1 Box #7 Box #3 Box #4 Box #1 Box #4 Box #1 Box #3 Box #7 Box #1 Box #7 Box #7 Box #4 Box #1 Box #3 Box #1 Box #7 Box #4 Box #1 Box #3 Box #1 Box #3 Box #3 Box #4 Page 9 of 17 MAR-A-LAGO 0169 Case 18-2868, Document 278, 08/09/2019, 2628230, Page212 of 648 TERMINATIONS LAST NAME McCormick McDaniel McDonald McDonald McFarland McGreevy McKee McKeen McKim McLean McMahon McMiled McNaughton McNicholas Mead Meade Mena Merchant Merriman Mesa Messemer Metayer Metayer Michaels Michel Miller Miller Miller Milosevic Miranda Mitchell Mohamed Monaco Monia Monson Montano Montano Montecinos Moore Moran Moree Moreno Morgan Morgan Morris Morris Mosher Moss Mullen FIRST NAME Jennifer Elizabeth Amanda Deborah Robert Barbara Wende Nohora Mark Stephen Leo Patricia Sean Marie Paul Raymond Arturo Kenneth Rita Uenoi Brian Edenes Marie Jesse Bernadette Eric Lisa Ronald Sas Cari Edward Waleid Lettia Gregory Jill Helmuth Henry James Joel Tom Darlene Aura Todd Jennifer Katherine Rebecca Neil William Coury Sony Box #7 Box #4 Box #3 Box #1 Box #4 Box #1 Box #4 Box #3 Box #1 Box #4 Box #7 Box #3 Box #7 Box #3 Box #7 Box #1 Box #1 Box #4 Box #7 Box #3 Box #4 Box #4 Box #1 Box #7 Box #7 Box #3 Box #3 Box #7 Box #1 Box #7 Box #4 Box #4 Box #1 Box #1 Box #7 Box #4 Box #4 Box #4 Box #2 Box #7 Box #4 Box #3 Box #2 Box #7 Box #3 Box #7 Box #2 Box #4 Box #7 Page 10 of 17 MAR-A-LAGO 0170 Case 18-2868, Document 278, 08/09/2019, 2628230, Page213 of 648 TERMINATIONS LAST NAME Mullen Munford Munoz Musallet Musso Myers Myers Nagy Nagy Nakoneczny Narleski Nasie Natal Neira Nelsen Nelson Nemets Nieporte Noe Noel Nolan Northern Noufal O'Boyle Oconnor Oesterling Oldfield Oliver O'Neill O'Neill O'Neill Orozco Pagen Pagliaro Palomba Parker Parker Parkinson Pavelka Pavonni Pedro Peison Pelaez Penate Perez Perkins Perrey Pesasico Petery FIRST NAME Cheryl Cheryl Mariadelrocio Hassan Diane Louisa Linda Matthew Viktoria Dawn Linda Waleed Luis Fernando Holly Lisa Tammie Joseph Thomas Marie Susan Brad Michel Thomas Kevin Emily Janice Meike Kathryn William Joseph Clemente Mitchel Peter Amanda Sandra Everett Nicole Nathan Michelle David Brenda Juan Alexander Marlow Tian Arielle Crispin Pamela Box #7 Box #7 Box #4 Box #2 Box #7 Box #3 Box #7 Box #4 Box #7 Box #4 Box #2 Box #7 Box #3 Box #3 Box #2 Box #3 Box #3 Box #4 Box #7 Box #7 Box #2 Box #7 Box #2 Box #7 Box #2 Box #7 Box #2 Box #4 Box #2 Box #2 Box #7 Box #3 Box #2 Box #4 Box #2 Box #3 Box #2 Box #4 Box #2 Box #2 Box #4 Box #7 Box #2 Box #4 Box #4 Box #4 Box #2 Box #4 Box #7 Page 11 of 17 MAR-A-LAGO 0171 Case 18-2868, Document 278, 08/09/2019, 2628230, Page214 of 648 TERMINATIONS LAST NAME Petrillo Pharr Philips Pickens Pientka Pierre-Noel Pinder Pine Pino Pinto Piques Pisani Pisani Pitot Pittinger Pitts Plaine Ponder Poston Powell Powell Presto Price Prouty Prucien Quigley Quirao Rafrano Ragland Ramirez Ramos Raphael-Dallas Reardon Reasinger Redmond Reed Reich Reil Reis Reis Reiser Rene Rene Rene Rennie Reyes Reynolds Ribeiro Richardson FIRST NAME Camille Stephanie Ralph Robert John Yvonne Patricia Jon Alex Julie Christian Craig Nicholas Patrick Mark Jeremiah Victoria Janet Roberta Nicole Kelley Nicholas Robin Joy Mona Christy Maria Dawn Leslie Roxana Milka Jamie Lisa Amy Suzanne Diana Gwendalyn Richard Brian Charles Scott Josette Jean Lamercie Kerry Randolfo Janice Gregg Brian Box #3 Box #4 Box #3 Box #2 Box #2 Box #4 Box #7 Box #3 Box #7 Box #2 Box #7 Box #2 Box #2 Box #3 Box #4 Box #2 Box #3 Box #3 Box #4 Box #3 Box #7 Box #4 Box #2 Box #2 Box #3 Box #7 Box #4 Box #2 Box #2 Box #2 Box #3 Box #3 Box #2 Box #2 Box #2 Box #4 Box #2 Box #2 Box #7 Box #7 Box #7 Box #4 Box #7 Box #7 Box #2 Box #4 Box #7 Box #3 Box #7 Page 12 of 17 MAR-A-LAGO 0172 Case 18-2868, Document 278, 08/09/2019, 2628230, Page215 of 648 TERMINATIONS LAST NAME Rinker Rivera Rivera Rivero Robbins Roberts Roberts Roberts Robsham Rodriguez Rodriguez Rodriguez Rodriguez Rogers Romeus Rony Roqueta Rose Rosenberg Rosier Rotchford Rubio Rueda Ruiz Russeau Russell Russotto Ryan Ryan Saint Gerard Saint Surin Salloum Salman Salvador Sanford Santos Sasaki Saunders Savage Savoie Scanlan Schlechter Schmantowsky Schoonover Schroeder Schumacher Schwab Scotland Scott FIRST NAME Ross Pablo Eduardo Alicia Jody Virginia Walter Diane Lydie Francisco Abel Kenia Aristalia Howard Melege Jean Maria Cheryl Bradley Sandra Bernadette Pascual Maria Juan Heidi Kathryn Vincent Megan Michael Manes Jacquest Adib David Marian Kevin Elimos Shoko Sarah Angelia Terry Peter Melissa Craig Richard Glenn Patricia Emily Jaycen Cecelia Box #7 Box #3 Box #2 Box #7 Box #4 Box #4 Box #4 Box #3 Box #7 Box #4 Box #3 Box #3 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #4 Box #2 Box #4 Box #2 Box #4 Box #4 Box #7 Box #2 Box #7 Box #7 Box #2 Box #2 Box #2 Box #2 Box #5 Box #2 Box #7 Box #2 Box #5 Box #2 Box #5 Box #5 Box #2 Box #2 Box #5 Box #2 Box #2 Box #7 Box #2 Page 13 of 17 MAR-A-LAGO 0173 Case 18-2868, Document 278, 08/09/2019, 2628230, Page216 of 648 TERMINATIONS LAST NAME Seebauer Seesholtz Sellas Serpico Sevilla Shaw Shelhamer Shepherd Shields Shumate Shumpis Similien Simms Simpson Sineni Singerline Skinner Sluzenski Smith Smith Smith Smith Smith Smith Snyder Soler Soliman Sosa Southall Souza Spencer Sprague Springer Stanfield Staniszewski Stankunas Stanley Sta-Rosa Steinberg Steinhaus Steliga Stenger Stephans Stewart Strohminger Stuart Stuhr Sturtevant Sucur FIRST NAME Gina Joseph William Joseph Carlos Tammy Sage Michael Catherine Regis David Raymond Amanda Robert Sandra Thomas Troy Jonathan Jeremiah Ivan Meadow Debbie Elizabeth Fred Lisa Luis Alex Anian Ginger Robert Sxott Steven Timothy Todd Casey Jolanta Lisa Jaime Lindo Kathleen Cynthia Stephanie Stuart Dorian Selvin Matthew Susan Kenneth Charles Nicholas Box #7 Box #2 Box #2 Box #2 Box #5 Box #7 Box #7 Box #7 Box #2 Box #5 Box #7 Box #2 Box #7 Box #7 Box #2 Box #2 Box #2 Box #7 Box #5 Box #5 Box #2 Box #2 Box #2 Box #2 Box #7 Box #2 Box #2 Box #7 Box #2 Box #2 Box #2 Box #2 Box #2 Box #5 Box #7 Box #7 Box #2 Box #2 Box #2 Box #2 Box #5 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #5 Box #7 Page 14 of 17 MAR-A-LAGO 0174 Case 18-2868, Document 278, 08/09/2019, 2628230, Page217 of 648 TERMINATIONS LAST NAME Sullivan Sumpter Swan Sweeney Swiderski Swiderski Sylne Tan Tarantino Tatum Taylor Tempfli Thelemaque Thibeault Thiel Thiel Thomas Thompson Thompson Tomer Tonge Torres Torres Toussant Trevino Tsitsirides Tucker Uljic Umpierre Valdez Valdez Valenti Vandersloot VanVliet FIRST NAME Judith Drew Pyson Bridget Richard Mark Romel Priscilia Vincenzo Christopher Kevin Glenn {ierre William Kurt Ryan Edward Derek Christine Mary Al Frank Iris Elby Danielle Alex Marie Gjon Frances Bridges Julie Paul Mildred Jane Box #2 Box #2 Box #5 Box #5 Box #2 Box #2 Box #2 Box #2 Box #2 Box #7 Box #5 Box #2 Box #5 Box #7 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #5 Box #5 Box #7 Box #7 Box #2 Box #5 Box #7 Box #2 Box #7 Box #2 Box #2 Box #2 Box #5 Box #2 Page 15 of 17 MAR-A-LAGO 0175 Case 18-2868, Document 278, 08/09/2019, 2628230, Page218 of 648 TERMINATIONS LAST NAME Vasquez Vasquez Vaughn Velasquez Vidalis Voluck Vyskrebentsev Wahl Walker Walkowiak Wallace Ward Webb Weber Weidner Weisman Wentworth Weslowski White Whitley Whitney Whittle Wilburn Williams Williams Williams Williams Williams Willoughby Willson Willson Woolf Wynn Yancey Yancey Yeskey Young Zervoulis Zivkovic Zorn Zwick FIRST NAME Sosmar Christian Matthew Rodollfo Chantal Justin Aleksey Steven Sylvia Toni Philip Terry Jacob Ronald James Brian Gayle Elaine Scott Deborah Moriah Tamara Jennifer Arhon Gretchen Jacqueline Ellen Kristin William Howard Joseph Elena Beverly Kathryn Scott Dean Martin Todd Matthew Milo Christopher Danielle Box #1 Box #2 Box #3 Box #4 Box #5 Box #6 1998 terms 1998 & 1999 terms 1999 terms 2000 terms 2000 terms 2001 terms Box #5 Box #2 Box #2 Box #2 Box #2 Box #2 Box #5 Box #5 Box #7 Box #7 Box #2 Box #5 Box #7 Box #2 Box #7 Box #2 Box #2 Box #2 Box #5 Box #7 Box #7 Box #2 Box #2 Box #2 Box #2 Box #2 Box #7 Box #7 Box #2 Box #5 Box #2 Box #2 Box #2 Box #2 Box #7 Box #5 Box #2 Box #2 Box #2 Box #7 Box #2 Page 16 of 17 MAR-A-LAGO 0176 Case 18-2868, Document 278, 08/09/2019, 2628230, Page219 of 648 TERMINATIONS LAST NAME Box #7 FIRST NAME 2001 terms Page 17 of 17 MAR-A-LAGO 0177 Case 18-2868, Document 278, 08/09/2019, 2628230, Page220 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page221 of 648 1 UNITED STATES DISTRICT COURT 2 Southern District of New York for the 3 4 5 6 7 8 9 10 Civil Action No. 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, vs. GHISLAINE MAXWELL, Defendant. ----------------------------------------------------VIDEO-DEPOSITION Sky Roberts TAKEN BY: Defendant REPORTED BY: Karla Layfield, RMR Stenographic Court Reporter Notary Public State of Florida at Large 15 DATE AND TIME: May 20, 2016; 8:33 a.m. 16 PLACE: Millhorn Law Firm 11294 North US Highway 301 Oxford, Florida APPEARANCES: Laura A. Menninger, Esquire HADDON, MORGAN & FOREMAN, PC 150 East 10th Avenue Denver, Colorado 80203 11 12 13 OF: 14 17 18 19 Attorney for Defendant 20 Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, 21 22 FISTOS & LEHRMAN, PL 425 Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Attorney for Plaintiff 23 24 25 ALSO PRESENT: Kenneth Sarcony, Videographer Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 1 2 Case 18-2868, Document 278, 08/09/2019, 2628230, Page222 of 648 1 2 3 4 5 6 7 8 I N D E X PAGE WITNESS: Sky Roberts Direct Examination by Ms. Menninger Cross-Examination by Mr. Edwards Redirect Examination by Ms. Menninger Recross-Examination by Mr. Edwards Reporter's Certificate Certificate of Oath 4 133 135 141 143 144 9 10 - - - 11 12 13 14 15 16 17 18 19 E X H I B I T S Defendant's Defendant's Defendant's Defendant's Defendant's Defendant's Defendant's Defendant's Defendant's Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit 1 2 3 4 5 6 7 8 9 (Exhibits attached.) 20 21 22 23 24 25 Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 6 28 48 52 58 116 122 125 137 Case 18-2868, Document 278, 08/09/2019, 2628230, Page223 of 648 Q 1 Do you remember there being a job posting that 2 you felt like was appropriate for Virginia or did you just 3 go out and talk to the woman who ran the spa area on your 4 own? 5 A I just talked to Angela. 6 Q Okay. 7 8 9 10 Do you recall whether this was intended to be a full-time job? A I don't remember if it was full time or just summer jobs or, you know, during season. It was probably for a season because Mar-a-Lago is seasonal. I mean, I was there year round but a lot of 11 12 people are seasonal, you know, because it's like 13 snowbirds, you know, summertime comes and nobody wants to 14 be down in south Florida. 15 16 17 18 Q What would you call the season, the seasonal aspect of Mar-a-Lago? A What's the season? Probably from September or October to, you know, maybe May, I guess. 19 Q Is that the coolest time? 20 A Times of the year, yes. 21 Q And it's more guests that come during that 22 period of time? 23 A Yes. 24 Q And is there more staff brought on during that 25 period of time? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 72 Case 18-2868, Document 278, 08/09/2019, 2628230, Page224 of 648 1 A Yes. 2 Q You saw that happen every year that you were 3 there? 4 A Every year. 5 Q And in the summer, it's relatively dead because 6 it's so hot? 7 A Basically, it closed during the summer. That's 8 when we would kind of work on everything and then make 9 sure everything is up to snuff for the next year, you 10 11 12 13 know. Q Do you remember what capacity Virginia was hired to work in, what her job title was, for example? A I don't know. I would have lunch with Virginia. 14 That's about as much as I know about what she did. 15 busy all the time. I was 16 Q I understand. 17 A I didn't have time to go see what she was doing. 18 I didn't really talk to Angela about what she had to do. 19 I think that was her name, Angela. 20 name that sticks out. But it's kind of the 21 Q We'll just use Angela. 22 A We'll use that as the name. 23 Q But we know it may not be Angela. 24 A It may not be. 25 Q Just because we have to call her something, Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 73 Case 18-2868, Document 278, 08/09/2019, 2628230, Page225 of 648 1 A Where did I learn that? 2 Q Uh-huh. 3 A I think Virginia had told me that there was a 4 lady in the spa area named Ms. Maxwell. I don't know her. 5 I couldn't tell you what she looked like. But just she said Ms. Maxwell said she can get 6 7 me a job with Jeffrey Epstein who is a friend of Donald 8 Trump, so I figured, well, he was a good guy or whatever, 9 you know, and that she was going to learn massage therapy. 10 Q When did Virginia tell you this? 11 A Oh, I can't tell you what date and time but I 12 13 don't remember. Q I understand. Did she tell you this while she was working at 14 15 Mar-a-Lago? 16 A Yes. I mean, after she had been there for a 17 little bit, you know, and then she told me, yes, that she 18 could possibly get this other job. 19 Q Okay. 20 A You know. 21 Q So she worked at Mar-a-Lago for a few months? 22 MR. EDWARDS: Form. 23 THE WITNESS: I have no idea. 24 25 how long she worked there. I don't know I don't remember. BY MS. MENNINGER: Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 79 Case 18-2868, Document 278, 08/09/2019, 2628230, Page226 of 648 1 2 A Uh-huh. Yes. It's not to me. It's up to her. I think that's the way I told her, you know. 3 Q Did you ever meet Jeffrey Epstein? 4 A Once. 5 Q When was that? 6 A I dropped Virginia off at the house once and he 7 came out and I met him and seemed just fine to me. 8 mean, you can't tell people by looking at them. I I mean, I know now from, you know, what I've 9 10 read that he's not a good guy. 11 know, you don't even know your neighbors sometimes, you 12 know. 13 14 Q But you can't tell. Do you remember about when you dropped Virginia off at his house that you met him? 15 A What do you mean? 16 Q Was it about the same time Virginia started 17 You working with him? 18 A Yeah. 19 Q Was it later? 20 A I think it was about the time she started. 21 Because I wanted to see where she was at, you know. 22 it was just a mansion down the street from, you know, 23 Mar-a-Lago. 24 think nothing of it. 25 very nice. So I didn't think twice about it. He came out. And I didn't He was very cordial, Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 82 Case 18-2868, Document 278, 08/09/2019, 2628230, Page227 of 648 1 2 3 Q Do you remember any part of your conversation with him? A No. It was just that, you know how a parent has 4 to meet -- you know, if my daughter is going to work 5 somewhere, I just want to meet the guy and see what was 6 going on, you know. 7 conversation, you know. I just remember meeting him and that was it and 8 9 10 11 But I don't remember any she walked into the house and -Q All right. So you recall Mr. Epstein coming outside of his home and greeting you? 12 A Yes. 13 Q Were you invited into his home? 14 A No. 15 Q Did you ever go inside of his home? 16 A No. 17 Q Other than that one time you dropped her off 18 there, do you ever remember going to that home? 19 A No. 20 Q Okay. 21 I couldn't tell you where it was at. Did you meet anyone else while you were there at the home? 22 A No. 23 Q Did you have a conversation with anyone else? 24 A No. 25 Q Did you every call Virginia at that home? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 83 Case 18-2868, Document 278, 08/09/2019, 2628230, Page228 of 648 1 2 massage therapy. Q All right. When she came home at night from 3 working with Mr. Epstein, did she look distressed to you 4 in any way? 5 A Not that I remember. 6 Q Okay. 7 Did she report any complaints about her job with Mr. Epstein? 8 A Not to me. 9 Q Okay. 10 Did she report them to anyone else who then reported them to you? 11 A No. 12 Q Your wife, for example? 13 A I have no idea. 14 Like I said, if she did tell my wife, I never heard about it. 15 Q Okay. 16 A Not that I remember ever meeting her. 17 Q Do you know what she looks like? 18 A No. 19 Q Did you ever meet anyone else who worked with 20 Mr. Epstein? 21 A No. 22 Q Do you remember anyone else who worked for 23 Have you ever met Ms. Maxwell? Mr. Epstein bringing your daughter home, for example? 24 A No. 25 Q Did your daughter ever move into the home where Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 85 Case 18-2868, Document 278, 08/09/2019, 2628230, Page229 of 648 C E R T I F I C A T E 1 2 STATE OF FLORIDA 3 COUNTY OF MARION 4 I, Karla Layfield, RMR, Stenographic Court 5 Reporter, do hereby certify that I was authorized to and 6 did stenographically report the foregoing deposition of 7 Sky Roberts; that said witness was duly sworn to testify 8 truthfully; and that the foregoing pages, numbered 1 9 through 142, inclusive, constitute a true and correct 10 record of the testimony given by said witness to the best 11 of my ability. 12 I FURTHER CERTIFY that I am not a relative or 13 employee or attorney or counsel of any of the parties 14 hereto, nor a relative or employee of such attorney or 15 counsel, nor am I financially interested in the action. 16 WITNESS MY HAND this 17 Ocala, Marion County, Florida. day of May, 2016, at 18 19 20 Karla Layfield, RMR Stenographic Court Reporter 21 22 23 24 25 Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 143 144 Case 18-2868, Document 278, 08/09/2019, 2628230, Page230 of 648 1 CERTIFICATE OF OATH 2 STATE OF FLORIDA 3 COUNTY OF MARION 4 I, the undersigned authority, certify that Sky 5 Roberts personally appeared before me and was duly sworn 6 on the 20th day of May 2016. 7 8 WITNESS MY HAND AND OFFICIAL SEAL this day of May 2016. 9 10 11 12 13 Karla Layfield, RMR Notary Public State of Florida at Large My Commission No. FF942806 My Commission Expires 12/10/2019 14 15 16 Personally Known Professionally Known Produced Identification of FDL 17 18 19 20 21 22 23 24 25 Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com Case 18-2868, Document 278, 08/09/2019, 2628230, Page231 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page232 of 648 THE MAR-A-LAGO CLUB. L.C. POLICIES OCTOBER 28. 1995 $0 Mm?pr?? AGREN MAR-A-LAGO 017s Case 18-2868, Document 278, 08/09/2019, 2628230, Page233 Of 648 TABLE OF CONTENTS Page INTRODUCTION 1 EQUAL EMPLOYMENT OPPORTUNITY 2 ORIENTATION POLICY 3 SEXUAL HARASSMENT 4 CARE OF FACILITIES 6 ENTRY AND EXIT OF CLUB 7 PROOF OF AUTHORIZATION TO WORK 3 SECURITY 9 A. INFORMATION 9 B. CONFIDENTIALITY 9 C. FACILITIES 9 D. GUEST PRIVACY 10 E. UNAUTHORIZED AREAS 11 F. REPORTING CRIME 11 G. MEDIA 11 GUEST NAMES 12 SAFETY AND HEALTH 13 COMPENSATION 15 EMERGENCY PROCEDURES 16 USE OF COMPUTER SYSTEM AND SOFTWARE PROGRAMS 17 A. GENERAL 17 B. ELECTRONIC MAIL 17 C. VOICE MAIL 13 D. RIGHT TO INSPECT 13 DISCLOSURE OF EMPLOYEE INFORMATION 19 NO DISTRIBUTION 2o INSPECTIONS 21 INTERNAL INVESTIGATIONS 21 OUTSIDE EMPLOYMENT . 22 PROPERTY OF EMPLOYER 23 MAR-A-LAGO 0179 Case 18-2868, Document 278, 08/09/2019, 2628230, Page234 of 648 EMPLOYEE APPRAISAL 24 TELEPHONE COURTESY PROCEDURES 25 EMPLOYEE ATTENDANCE AND TARDINESS 27 LINEN ABUSE . 28 TIME REPORTING - SIGNING IN AND OUT 29 CHANGE OF ADDRESS OR STATUS 29 INITIAL EMPLOYMENT PERIOD 3o WORK HOURS, SALARY AND OVERTIME PREMIUMS 31 A WORK HOURS 31 SALARY 31 OVERTIME PREMIUMS 31 EMPLOYEE BENEFITS AND PROGRAMS 33 VACATION LEAVE 34 SICK TIME POLICY 36 HOLIDAYS AND HOLIDAY PAY . 37 BEREAVEMENT LEAVE 3a JURY DUTY 3a MILITARY LEAVE 39 MATERNITY LEAVE OF ABSENCE 39 FAMILY MEDICAL AND PERSONAL LEAVE OF ABSENCE 4o GRIEVANCE PROCEDURE 47 DISCIPLINARY ACTION 49 UNIFORMS AND PERSONAL APPEARANCE 54 AIDS POLICY 57 USE AND TESTING .., 59 POLICY ON SMOKING 61 MISCELLANEOUS 62 A. STAFF CAFETERIA 62 MAR-A-LAGO 0180 Case 18-2868, Document 278, 08/09/2019, 2628230, Page235 of 648 LOCKERS 62 PHONES 62 D. LOST AND FOUND 62 E. GIFTS 62 RIGHT TO KNOW STATION 63 EMPLOYEE ENTRANCE AND EXIT 63 IF YOU LEAVE EMPLOYMENT 64 A. RESIGNATION POLICY 64 B. DISMISSALS 64 C. WRITTEN WARNINGS 66 D. VACATION PAY 67 E. RETIREMENT PLAN 67 F. CLEARANCE PROCESS 68 EMPLOYMENT HANDBOOK RECEIPT 69 MAR-A-LAGO 0181 Case 18-2868, Document 278, 08/09/2019, 2628230, Page236 of 648 MAR-A-LAGO 0182 Case 18-2868, Document 278, 08/09/2019, 2628230, Page237 of 648 INTRODUCTION MAR-A-LAGO 0183 Case 18-2868, Document 278, 08/09/2019, 2628230, Page238 of 648 The Mar?A-Lago Club, L.C. ("the Club") seeks to provide the quality of work which will develop the potential of each employee as well as the Club as a whole. In this regard, this policy and procedures manual is designed to acquaint each employee with the administrative and personnel practices of the Club. These guidelines provide a framework for the fair and equitable treatment of all employees regardless of location, department, manager or supervisor. Each employee should be familiar with the responsibilities and opportunities available to ?make work as rewarding as possible. These policies and procedures should be read carefully and clearly understood. Each department head, manager or supervisor will be able to answer, or obtain an answer, to any questions involving interpretation or clarification of these policies and procedures. Each employee is expected to apply these general policy and procedure guidelines conscientiously iJ1.a constructive and supportive manner. The policies in this manual are only guidelines and the Club reserves the right to add to, subtract from, or change these provisions in any way, at any time, without being bound to the previously replaced or revised provisions. This handbook is not to be construed as an employment agreement or employment contract and the Club is under no obligation to provide the benefits set forth in.this manual if it determines, at a subsequent time, that these benefits are to terminate. NLARHAJQAGKJ0184 Case 18-2868, Document 278, 08/09/2019, 2628230, Page239 of 648 DAL EMPLOYMENT OPPORTUNITY The Club is an equal opportunity employer which is committed to prohibiting discrimination on the basis of race, color, sex, age, religion, national origin, sexual orientation, marital status, or' disability' throughout the employment. process, from selection through termination. The Club intends to provide a pleasant work environment that is healthful and comfortable and will not tolerate any form of employee harassment, either verbal, written, physical, or visual, based on race, color, religion, sex, national origin, age, disability or marital status. Harassment can take many forms. It may be, but is not limited to: words, signs, jokes, pranks, intimidation, physical contact, violence toward any employee by a fellow employee, a supervisor, or a person doing business with the Club. Harassment is not necessarily sexual in nature. All necessary steps will be taken to comply with existing federal, state and local fair employment laws and guidelines. MAR-A-LAGO 0185 Case 18-2868, Document 278, 08/09/2019, 2628230, Page240 of 648 ORIENTATION POLICY The first ninety days of employment are considered to be an orientation or probationary period during which you and the Club have an opportunity to know each other. Your performance will be evaluated during this time to access your potential for continued employment. Evaluations will continue as long as you are employed, but during the orientation period your supervisor may observe and evaluate your performance more closely and more frequently to ensure that you are learning your job. During this orientation period, employees may earn but may not use vacation or personal days, except with permission of the Club Manager's office. If the employment relationship is terminated during this ninety day period, you shall not be entitled to receive any payment for benefits, personal days, vacation days, or unemployment compensation . MAR-A-LAGO 0186 Case 18-2868, Document 278, 08/09/2019, 2628230, Page24l of 648 The Club strictly prohibits any form of harassment in the workplace, including sexual harassment. Definition of Sexual Harassment: 1. Unwelcome sexual advances, requests for sexual favors, and other such verbal or physical conduct constitute sexual harassment under the following conditions: Submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment. B. Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual. C. Such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile or offensive work environment. 2. Conduct which falls into the definition of sexual harassment may include, but is not limited to: A. Unwelcome physical contact of a sexual nature such as patting, pinching or unnecessary touching. B. Overt or implied threats against an individual to induce him or her to perform sexual favors or to engage in an unwelcome sexual relationship. C. Verbal harassment or abuse of a sexual nature, including intimating by way of suggestion a desire for sexual relations or making jokes or remarks of a sexual nature to or in front of a person who finds them offensive. D. Use of sexually suggestive terms or gestures to describe a person's body, clothing, or sexual activities. E. Displaying or posting offensive sexually suggestive pictures or materials in the workplace. Recourse: MAR-A-LAGO 0187 Case 18-2868, Document 278, 08/09/2019, 2628230, Page242 of 648 If an employee feels that an incident of any form of harassment has occurred, the employee is encouraged to report the matter to the Club Manager's office. All such issues will be handled in strict confidence to the extent possible with minimum embarrassment to the involved parties. As in any grievance procedure, the facts of the situation will be reviewed objectively so that appropriate disciplinary action, including discharge, can be taken if misconduct has occurred. A timely resolution of each complaint is to be reached and communicated to the parties involved. Retaliation against any employee for filing a complaint or participating in an investigation is strictly prohibited. In the event an employee files a frivolous, malicious or false claim, appropriate sanctions for discipline of the complainant, including termination, may result. MAR-A-LAGO 0188 Case 18-2868, Document 278, 08/09/2019, 2628230, Page243 of 648 CARE OF FACILITIES The Club has made a large investment in equipment and facilities to provide each employee with the necessary resources to accomplish his/her duties. It is the responsibility of management and each employee to treat equipment and facilities with respect and care. Neatness and cleanliness are required to maintain these resources at a level at which the employee can and will be proud. Abuse of equipment and facilities will not be tolerated and may lead to disciplinary action including discharge. MAR-A-LAGO 0189 Case 18-2868, Document 278, 08/09/2019, 2628230, Page244 of 648 ENTRY AND gm or CLUB All employees must enter and leave the Club at the Southern Boulevard gates unless otherwise directed by management. Employees may not enter the Club grounds/premises more than 30 minutes before the start of their scheduled shift, and employees must exit the Club grounds/premises directly after their shift ends, unless authorized by your department head. When conducting Club business off the premises of Mar? a?Lago, you must have approval of your department head or supervisor. Employees may not patronize the Club facilities without prior written approval of their department head. If an employee needs to return to the property for any reason, the employee must contact their supervisor or a department head prior to their arrival. Security must be contacted in the event no supervisor is available. Case 18-2868, Document 278, 08/09/2019, 2628230, Page245 of 648 PROOF OF AUTHORIZATION TO WORK You must comply with government regulations by furnishing valid documentation of both your identity and your authorization to work. The Club Manager will advise you what documents are acceptable. If your immigration or work authorization status changes after you begin work so that you are no longer able to continue to work in the United States, you must advise your supervisor and the Human Resources Manager. MAR-A-LAGO 0191 Case 18-2868, Document 278, 08/09/2019, 2628230, Page246 of 648 SECURITY A. INFORMATION All financial, contract, production, and administrative records and information. of the Club and its 'members are confidential. Each employee is responsible for'making certain that information under his/her control is appropriately safeguarded. ,An employee will not provide or disclose office or guest information to third parties unless it has been determined that the party has a legitimate right to know and the request has been approved by your Supervisor. Authorization by the Managing Director must be obtained before written contact is made of any member, client, purveyor, (current or prospective). Any uncertainties should.be cleared with the Managing Director before such information is provided. B. CONFIDENTIALITY - No employee shall, during the term of his/her employment or thereafter disclose to others or use, except as authorized by the Managing Director, any of the Club's confidential, technical, or other business information. "Confidential, technical or other? business information" shall mean any information, including lists of the Club's vendors and customers, which.the employee has used, learned.or contributed during the course of his/her employment, regardless of whether it was written or in other tangible form that is not generally available to the public; or (ii) gives one who uses it a competitive advantage over the Club. C. FACILITIES - Access to Club facilities will be limited to parties with a legitimate reason to be there. Employees are not permitted to have? visitors on the premises unless special arrangements have been made by the employee?s supervisor. Outside visitors will be greeted by Post One and escorted to their area of business. Each employee should feel comfortable in.politely confronting an unknown individual who appears suspicious or in need of direction. An essential element of the security procedures of the Mar? a-Lago Club is the key control process. As such, employees who have access to Club keys must recognize the importance of properly safeguarding the keys which have been entrusted to them. All employees should be aware that they may be subject to disciplinary action for any violation of the key control procedures. Guest room keys must never be left in your locker. MAR-A-LAGO 0192 Case 18-2868, Document 278, 08/09/2019, 2628230, Page247 of 648 In the event of a breach or threatened breach by the employee of provisions A, or of this section, the Club shall be entitled to an injunction restraining the employee from disclosing or using, in whole or in part, such information or from rendering any services to any person, Club, corporation, association, or other entity" to whom such information, in whole or in. part, has been disclosed or is threatened to be disclosed? Nothing herein shall be construed as prohibiting the Club from pursuing other remedies available to the Club for such breach or threatened breach, including the recovery of damages from the Club. D. GUEST PRIVACY Everyone enjoys privacy. Employees are prohibited from revealing any personal or business information about a Club member. Do not divulge names or room numbers of one guest to another. Do not let a person into any guest room without verifying with the front desk that the person is the guest registered to that room. All guest floors and, areas are off limits to employees unless they are specifically assigned to perform work duties in these areas. Employees are not allowed to accept invitations from guests to join them. in their room. Am: no time is an employee to ask: a. member for' an. autograph. or to ask a member to socialize with them off duty. E. UNAUTHORIZED AREAS - Employees may not enter areas of the building, especially guest floors, unless they have been assigned by a supervisor. Example: Building Employees require work orders on gueSt floors. Food Service Employees require valid room service checks or authorized pick?up request before going on the guest floors. - F. REPORTING CRIME - The Security Department, with its able staff, attempts to control crime and provide a safe operation. Due to the enormity of the Club, they cannot be everywhere at once, and your help is needed. Follow these simple security measures: MAR-A-LAGO 0193 Case 18-2868, Document 278, 08/09/2019, 2628230, Page248 of 648 1) Notify Security (ext. 212) of any suspicious person. 2) If you are a witness to a crime, relate to the dispatcher as much specific detail as possible, including a description of the individual and the nature of the crime. G. MEDIA Because of the celebrated and historic nature of Mar?a?Lago and its significance to Palm Beach, Florida and the united States, we are contacted daily by the umdia (television, radio, newspapers, magazines, wire services). They want to know what is happening at the Club and they want comments for their articles or newcasts. It is important that no Club employee other than the Managing Director, Special Events Manager or Director of Membership comment to the press on the Club or it's members. GUEST NAMES All guests are to .be treated in a friendly, courteous, professional manner. Systems or procedures are used within each department to inform emplyees of our guests' names. We want you to use the guests' name at all times if possible. Be friendly to guests and call them by name; however, do not be too familiar with a guest by using his/her first name. 0194 Case 18-2868, Document 278, 08/09/2019, 2628230, Page249 of 648 SAFETY AND HEALTH The Club's goal is to provide a safe and healthy environment for employees. Each employee is expected to comply with all safety and health requirements whether it is established by management or by federal, state or local law. The Club does not expect any employee to take unnessary risks. Study the job assigned to you and learn the safety rules of your department. In everything you do, make sure that you have observed every reasonable safety precaution. Most Club accidents are simple and common, such as slips and falls, cuts, burns, sprains and strains. They are easy to prevent. Observation. of the following' general rules will prevent many employee accidents: 1. Report all injuries at once to your supervisor. 2. If you are not sure how to do a job safely, ask your department head. 3. Horseplay and practical jokes are prohibited. 4. Put equipment away after use. Don't block passages. 5. Broken chairs, loose and worn carpeting,-missing lights and other equipment needing maintenance may cause accidents. Report these along with any other safety hazard at once to your department head. 6. Wear the right clothing for the job. 7. Show other employees the safe way to do the job. 8. If the load seems too heavy to lift safely, get help. When lifting any load, follow the safe lifting practice listed below: a. Be sure you can handle it alone. If not get help. b. Face the load squarely. c. Secure a firm footing with your feet properly spread. d. Bend your knees. e. Get a grip on the load. f. Keep a straight back and lift by straightening your legs gradually not suddenly. MAR-A-LAGO 0195 Case 18-2868, Document 278, 08/09/2019, 2628230, Page250 of 648 9. Keep the load close to your body. h. Don't twist your body. 9. Do not carry a load so that it will block your vision Make sure you can see where you are going. 10. Avoid slippery, wet or greasy floors. Clean up wet or greasy spots as they occur. 11. Use a ladder to reach things that are up high. See that the ladder is firmly placed. While on the ladder, don't reach too high or too far to one side. 12. Place broken glasses, dishes, etc., in special receptacles designated for this purpose. 13. Do not operate equipment unless properly trained and specifically instructed to do so by your supervisor. All accidents occurring on the Club's premises or to Club employees, regardless of whether they result in an injury, must be reported immediately to your supervisor. The Club is required to report all work?related injuries as soon as possible. If you are too seriously injured to describe the facts surrounding the accident, it is the responsibility of the supervisor to supply the information to the Human Resources Manager. If a member has an accident, you should see that he or she is comfortable and. then immediately' notify' your supervisor, department head, Managing Director and the Security Department. Any property damage due to accidents should be reported in the same manner. WORKERS COMPENSATION We all do the best job we can.to prevent accidents and.injuries at home and at work. If you spot a safety hazard on the job, report it to your supervisor immediately. Workers' Compensation is provided by the company to pay an employee partial compensation if he or she loses time due to a work-related accident. In case you are injured: 1. Report the inujury immediately to your supervisor. 2. Following first-aid or 'medical treatement, your supervisor will contact security to file an incident report and then notify the Human Resources Manager. MAR-A-LAGO 0196 Case 18-2868, Document 278, 08/09/2019, 2628230, Page251 of 648 3. The Human Resources Manager completes the Workers' Compensation Report and submits copies to the insurance carrier. When you lose work time because of an injury on the job, a medical certificate from your doctor or the Health Center must be submitted to the Human Resources Manager with a return to work date prior to return to work. Remember to report all injuries immediately, no matter how small they may be, to your supervisor. Though the injury may seem small at first, it may become serious later, and result in lost work time. MAR-A-LAGO 0197 Case 18-2868, Document 278, 08/09/2019, 2628230, Page252 of 648 EMERGENCY PROCEDURES: Adhere to the following procedures in emergency situations: A. FIRE In case of fire or smoke: STAY CALM 1. Pull fire alarm 2. Dial Security at Extension 212 and.give location of fire, (closest room number, floor, type of fire or smoke), remain on the phone to give additional information as required. 3. When the fire department or Club fire brigade arrives, direct them to the location. Remember, most persons die from smoke and poisonous gases. Stay low to the ground if there is any smoke at all. If you encounter smoke or fire at lower levels, turn around and walk up to clearer air, or use another exit. 4. Be certain to follow instructions of the fire department and the Club fire brigade in order to ensure the safety of all guests and employees. B. BOMB SCARE OR WARNING You all know your own work areas, and are usually aware of any unfamiliar items. A bomb may be concealed in a length of pipe, small parcel, suitcase or paper bag. When a suspicious item is discovered DO NOT TOUCH and report immediately to: 1. Club operator - dial 300 . 2. Security dial 212 C. GUEST ILLNESS Follow the same procedures as listed above. The most important thing to remember in an emergency is DO NOT USE OF COMPUTER SYSTEM AND SOFTWARE PROGRAMS: A. GENERAL The Club has invested a large sum of money in its computer system and software programs. The information in the computer system represents much work by many employees and is an important component of the Club. In order to protect this valuable MAR-A-LAGO 0198 Case 18-2868, Document 278, 08/09/2019, 2628230, Page253 of 648 information, no employee is allowed to bring to work any computer games, hardware, programs or software which is not licensed and registered under the Club name, or install or otherwise use any such items unless they have been approved in advance, in writing, by the Managing Director. The reason for this is simple. Outside programs may contain viruses which can disrupt or destroy our computer system. Even if you are sure that the program you bring does not contain a virus, and that it would not damage our computer system, you are not to use any outside program without written advance approval. If software programs are not properly registered, there may be criminal and civil penalties for their use. In addition, the Club has noted that some computer programs also contain games or programs which are not related to the work of the Club. These programs are not to be played by any employee at any time during the work day. Only computer programs that are directly related to the work of the Club are to be used on Club computers. No employee is authorized to download or remove any information from the Club's computer system without the expressed advance permission of the appropriate supervisor. (See the Club's policy on security.) . ELECTRONIC MAIL During your workday, the electronic mail and other information systems are not to be used in a way that may be disruptive, offensive to others, or harmful to morale. Specifically, it is against Club policy to transmit E?mail communications that contain ethnic slurs, racial epithets, or anything that may be construed as harassment or offensive to others based on their race, national origin, sex, sexual orientation, age, disability, religious or political beliefs, is strictly prohibited and may constitute grounds for termination. Employees should use the information systems for Club business only. The E?mail system also should not be used to solicit others for commercial ventures, religious or political causes, outside organizations, or other personal matters unrelated to your job. For privacy reasons, employees should not attempt to gain access to another employee's personal file of E?Mail messages without the latter's express permission. Further, employees shall not use a code, access a file or retrieve any stored communication, other than where authorized, unless there has been prior clearance by an authorized Club representative. Management reserves the right to enter an employee's E?mail files on an "as needed" basis by authorized personnel to ensure the Club's legitimate business interest in the proper use of its property. System security features such as passwords and message MAR-A-LAGO 0199 Case 18-2868, Document 278, 08/09/2019, 2628230, Page254 of 648 delete functions do not neutralize the employer's ability to access any message at any time. Employees who use E?mail for private, non?job-related purposes do so at their own risk. By using the Club's equipment and E?mail systems, employees consent to have such E-mail use, messages and files monitored by authorized firm personnel. C. VOICE MAIL The Club utilizes a voice mail system which allows employees, clients, etc. to leave voice messages. The Club reserves the right to monitor and review all messages left on the voice mail system at any time. All voice messages should be confined to business or work?related matters. D. I RIGHT TO INSPECT No employee is to have an expectation of privacy with regard to any voice mail messages, mail or computer files, and the Club has the right to monitor and review these electronic and computer systems at any time. Case 18-2868, Document 278, 08/09/2019, 2628230, Page255 of 648 DISCLOSURE OF EMPLOYEE INFORMATION REFERENCE CHECKS All inquiries regarding a current or former employee of The Mar?a-Lago Club must be referred to the Human Resources Manager. Should an employee receive a written request for a reference, he/she should refer the request to the Human Resources Manager for handling. No Mar?a-Lago Club employee may issue a reference letter to any current or former employee without the permission of the Human Resources Manager or Managing Director. under no circumstances should any Mar?a?Lago Club employee release any information about any current or former Mar-a-Lago Club employee over the telephone. All telephone inquiries regarding any current or former employee must be referred to the Human Resources Manager. In response to an outside request for information regarding a current or former Mar?a?Lago Club employee, the Human Resources Manager will furnish or verify only an employee?s name, dates of employment, job title and department. No other data or information regarding any current or former Club employee, or his/her employment with Mar?a?Lago will be released unless the employee authorizes the Club to release such information in writing or Mar?a?Lago is required by law to furnish any information. MAR-A-LAGO 0201 Case 18-2868, Document 278, 08/09/2019, 2628230, Page256 of 648 NO DISTRIBUTION Persons who are not employees of the Club are prohibited from soliciting our employees, distributing literature, or selling merchandise to our employees, on our premises at any time. The purpose of this rule is to prevent employees and customers from being disrupted or imposed upon by such activities and to maintain our operations at peak efficiency at all times. For similar reasons, solicitation and distribution of literature are prohibited during the working time of either the employee making the solicitation or distribution, or the targeted employee. The term "working time" does not include an employee's authorized lunch or rest periods, or other time when the employee is not required to be working. Distribution of literature is prohibited in work and customer areas at all times. The distribution of literature in such a manner as to cause litter on the Club's property is prohibited. Off?duty employees are not allowed to return to the interior or working areas of the Club's premises until the next scheduled work time. The Club maintains bulletin boards to communicate Club information to employees and to post notices required by law. These bulletin boards are for the posting of Club information and notices only, and only persons designated by the Managing Director may place notices on or take down material from the bulletin boards. The unauthorized posting of notices, photographs or other printed or written materials on bulletin boards or any other Club property is prohibited. MAR-A-LAGO 0202 Case 18-2868, Document 278, 08/09/2019, 2628230, Page257 of 648 INSPECTIONS The Club respects its employees' right to privacy. However, for security purposes, we maintain the right to inspect certain personal belongings. Each employee agrees, as a condition of continued employment, to allow management to inspect employee personal property on our premises. Any package brought into or taken out of our premises may be inspected. Our premises and equipment, including Club vehicles, lockers and desks, are subject to inspection at any time. Refusal to cooperate in an inspection or search will be considered a violation of your terms of hire and insubordination. INTERNIL INVESTIGATIONS From time to time The Mar-a-Lago Club may be required to conduct internal investigations pertaining to security, auditing or work-related matters. Employees are required to cooperate fully with and assist in these investigations if requested to do so. Whenever necessary, in Management?s discretion, employees? work areas desks, file cabinets, etc-) and personal belongings brief cases, handbags, etc.) may be subject to a search. Employees are required to cooperate. Management will generally try to obtain an employee?s consent before conducting a search of work areas or personal belongings, but may not always be able to do so. MAR-A-LAGO 0203 Case 18-2868, Document 278, 08/09/2019, 2628230, Page258 of 648 OUTSIDE EMPLOYMENT The Club does not object to your holding other jobs, provided that there is no conflict of interest and your job at the Club comes first. However, outside employment which interferes with your obligations to the Club is prohibited. In addition, no employee shall claim to be a Club representative in connection with any outside employment. Before accepting any supplementary job, it is mandatory that you notify your Supervisor and the Department Head to determine if there is a conflict of interest or if it would adversely affect your job performance at the Club. If the Club determines that a conflict of interest exists or acceptance would adversely affect your job performance, you shall not engage in outside employment. Failure to notify the Supervisor and the Department Head in advance of any outside employment will be grounds for immediate termination. Please note that if at any time your job at the Club suffers due to additional employment elsewhere, the Club reserves the right to ask you to give it up. Failure to comply with such a request will also be grounds for immediate termination. MAR-A-LAGO 0204 Case 18-2868, Document 278, 08/09/2019, 2628230, Page259 of 648 PROPERTY OF EMPLOYER Employees may not remove from the Club premises any Club property not belonging to the employee. Any other property that an employee removes from Club premises, must be accompanied by a Club Package Pass, signed by a department head or his/her designated supervisor. Upon termination of your employment, you must surrender to the Club any and all material including, but not limited to, drawings, manuals, reports, documents, lists of the Club's vendors and customers, and the like (including all copies thereof), that you have in your possession relating to the business of the Club, or its affiliates. You recognize that all such materials are the property of the Club solely and that you have no right, title, or other interests in or to such materials. MAR-A-LAGO 0205 Case 18-2868, Document 278, 08/09/2019, 2628230, Page260 of 648 EMPLOYEE APPRAISAL It is the objective of the Club to provide an atmosphere in which each employee can receive periodic, thorough appraisals of their performance and compensation. The Club uses the performance evaluation as a means to achieve these objectives. Each Manager, Supervisor and employee should be familiar with their role in contributing to the success of the appraisal system. TELEPHONE COURTESY Telephone Calls Personal calls are prohibited,except in an emergency, since it interferes with the flow of business. Telephone courtesy is an essential part of every employee's interaction with guests. All incoming calls should be answered according to the following mandatory procedures: 1. All calls are to be answered within three rings Case 18-2868, Document 278, 08/09/2019, 2628230, Page261 of 648 2. Answering a Department line: a. standard greeting Good Morning/Afternoon/Evening). b. Give the name of the department. c. Give your name. d. Offer assistance: "Good morning, Reception Desk. This is John. How may I help you?" 3. Answering another individual's line: a. Standard greeting. b. Identify whose office 0r department. c. Give your name. - d. Offer assistance or to take a message: "Good afternoon, Mr. Smith's office. This is Mary. How my I help you?" 4. When placing a call on "hold:" a. Use the word "wait,? not "hold." b. Always ask permission and wait for guest's response: ?Are you able to wait?" 5. Returning to a call placed on "hold": a. Always thank the guest for waiting or apologize for the wait. b. Give your name. Offer assistance: "Thank you for waiting, this is Mary. How may I help you?" 6. When transferring a call: a. Always announce the transfer of a call to the party receiving the call: "Mr. Smith, I am; transferring Bob JOnes to you." b. The caller should then be connected and an announcement of the connection made: have Mr. Smith on the line now. Go ahead, please." 7. When ending a conversation: a. Always say "thank you" or "you're welcome." b. Use the guest's name if possible. c. Let the caller know you are happy to be of service or sorry you are unable to help. d. End the conversation with "good?bye" and hand up the receiver gently: "Thank you for calling, Mr. Smith. We're glad we could help. Good-bye." MAR-A-LAGO 0207 Case 18-2868, Document 278, 08/09/2019, 2628230, Page262 of 648 MAR-A-LAGO 0208 Case 18-2868, Document 278, 08/09/2019, 2628230, Page263 of 648 EMPLOYEE ATTENDANCE AND TARDINESS Your schedule is developed after considering the Club's needs and flow of business. Your adherence to the schedule and flexibility concerning any necessary changes will help ensure our Club's success. Each employee is required to work the hours normally scheduled for his or her assigned position. Employee's work schedules will be those hours authorized by their Supervisor to meet operaional requirements. If you are unable to report to work for any reason, you must notify your supervisor no later than Three (3) hours prior to your scheduled reporting time, stating your reason for lateness or absence, and when you expect to arrive at work. Check with your supervisor to see if additional notice time is required. In the event your supervisor is not available, you are to contact SECURITY Ext.212 or the Human Resources Manager. You must call in each day of your absence. Upon the third consecutive day of absence, a Health Care Provider's note will be required of the employee before returning to work. An employee who is absent for three consecutive days without proper notice to the Club may be considered to have voluntarily resigned his or her position with the Club. Failure to adhere to employee attendance policies results in time consuming arrangements and costly replacements and may lead to disciplinary action. Tardiness places an unfair burden upon your supervisors and co-workers. All efforts should be made to be at work according to schedule. Your supervisor is to be contacted if it is unavoidable for you to be late to work. Continued tardiness will result in disciplinary action, up to and including termination. MAR-A-LAGO 0209 Case 18-2868, Document 278, 08/09/2019, 2628230, Page264 of 648 LINEN ABUSE Linen abuse is considered to be any type of mishandling or misuse of linen, causing damage to the point that the linen would be unfit to place before a guest. The following are the most common abuse occurrences. Using linen as rags for cleaning. Leaving linen lying on the floor. Cleaning ashtrays with linen. Using napkins as food covers. Carrying linen on your person to be used as sweatbands, handkerchiefs, etc. Throwing rags or linen in the trash. Mixing rags with linen. Violation of these linen abuse standards may lead to disciplinary action. The replacement of lost or damaged linen is a costly process, and we need everyone's help in curtailing this enormous expense. MAR-A-LAGO 0210 Case 18-2868, Document 278, 08/09/2019, 2628230, Page265 of 648 TIME REPORTING - SIGNING IN AND OUT You must check in first at the guard post at the employee's entrance on Southern Boulevard, and then again upon your arrival at Post One. At the end of your shift you must check out at Post One and also at the guard post at the employees' exit on Southern Boulevard. When reporting in and out of work employees will be solely responsible for keeping their own hours worked by logging in and out at the timekeeping terminal. Pay is calculated for the actual hours worked by the actual entry of this information. Any deviations in the schedule including overtime can be done with the supervisors approval only. These deviations are indicated in writing at the end of the work week for presentation to payroll. Under no condition shall an employee enter for time other than his/her own. An employee who leaves the Club during his/her work schedule must first obtain their supervisor's permission. Failure to adhere to these procedures, will result in disciplinary action, up to and including termination of employment. wait Staff employees must also sign in on the SIGN IN which will be located with your Captain. CHANGE OF ADDRESS OR STATUS - PERSONNEL RECORDS To keep necessary Club records up?to?date, it is extremely important that you notify the Human Resources Department of any changes in: Name and/or marital status. Address and/or telephone number. of eligible dependents. W4 Deductions. MAR-A-LAGO 021 Case 18-2868, Document 278, 08/09/2019, 2628230, Page266 of 648 INITIAL ?191.0me PERIOD Every new employee goes through an initial period of adjustment in order to learn about the Club and about his/her job. During this time, the employee will have an opportunity to find out if he/she is suited to, and likes, his/her new position. Additionally, the initial employment period gives the employee?s supervisor a reasonable period of time to evaluate his/her performance. The initial employment period is 3 months. During this time, the new employee will be provided with training and guidance from his/her Supervisor. He/she may be discharged at any time during this period if his/her Supervisor concludes that he/she is not progressing or performing satisfactorily. Additionally, under appropriate circumstances, the initial employment may be extended. At the end of the initial employment period, the employee and his/her supervisor may discuss his/her performance. Provided his/her job performance is ?satisfactory? at the end of the initial employment period, he/she will continue in our employment. EMPLOYEE CATEGORIES Full Time - Year Round Employee Seasonal Employee WORK HOURS. SALARY gm: A. WORK HOURS The Club never shuts down from November 1 to Mother's Day; for 24 hours a day, 7 days a week, it serves the diverse needs of our members. Therefore to ensure adequate coverage at all times, departments have arranged different schedules for their employees. MAR-A-LAGO 0212 Case 18-2868, Document 278, 08/09/2019, 2628230, Page267 of 648 SALARY The Club's policy regarding personnel is to offer competitive starting wages and to maintain a fair and equitable wage structure. Wage increases are given when appropriate based upon results of performance evaluations and/or employment status change. The work week at the Club begins on Monday and ends on Sunday. Scheduled paydays are as follows: Friday pay vouchers indicating deposit into your existing Great Western banking account will be issued. If there is a discrepancy in your paycheck, advise your department head immediately. Do not call or go to the payroll department. If your department head is not available, contact the Human Resources Manager and assistance will be provided. The Club is unable to make advances on employee paychecks. OVERTIME PREMIUMS 1. Hourly and Salaried Employee (non?exempt) Hourly or salaried employees are eligible for overtime premium at one and one-half (1.5) times their base hourly rate under the following conditions: Overtime work has been specifically authorized by the direct Supervisor in advance or in writing after the fact. More than forty (40) hours are actually worked by that individual in one work week, not including sick time, vacation, holidays and time off for personal business and other non work time. The work week commences on Monday morning and ends Sunday at midnight. 2. Salaried Employee (exempt) A salaried exempt employee is not compensated directly for specific overtime hours worked. A salaried employee is paid to accomplish a specific job and his/her salary is based upon the fact that hours in excess of 40 per week may be necessary on occasion. Overtime is at the request of a supervisor or department MAR-A-LAGO 0213 Case 18-2868, Document 278, 08/09/2019, 2628230, Page268 of 648 head for emergency client business. The Supervisor must authorize overtime and sign the employee?s schedule signifying such authorization. EMPLOYEE BENEFITS AND PROGRAMS As a regular full time year round employee you will enjoy an excellent benefits package which is designed to help protect your health, and plan for your future. The Mar-a?Lago Club reserves the right to change any or all of these benefits at any time. Group Health Insurance Group Life Insurance Group Dental Insurance 401K After one full year of continuous employment For information relating to the cost of such benefits, eligibility requirements, etc. please contact the Human Resources Manager. MAR-A-LAGO 0214 Case 18-2868, Document 278, 08/09/2019, 2628230, Page269 of 648 BEREAVEMENT LEAVE In the event of a death in an employee?s immediate family, the Club will allow a maximum of three (3) days off with pay for funeral related leave. Immediate family includes spouse, child, mother, father, brother, sister, grandparent, grandchild, aunt, uncle, daughter?in?law, son?in?law, mother?in?law, father-in-law, step?child, step?parent. When a death occurs, notify your supervisor at once with all of the details, including the family member who died and where the funeral will take place. The supervisor should notify the Human Resources Manager of the reason and length of the employee's absence. JURY DUTY An employee summoned for jury duty will be compensated in the following manner only if he/she notifies his/her supervisor and provides him/her with a copy of the summons. During the jury leave, the employee will be paid the difference between jury compensation and the employee's regular pay for up to three days. Any day in which you are excused from jury service at a time when there are three (3) or more hours remaining in your daily scheduled shift, you will report for work. the jury duty falls at a time when the employee cannot be away from work, the court may allow the employee to choose a more convenient time to serve if he/she makes a request in accordance with the court's procedure. MAR-A-LAGO 02 15 Case 18-2868, Document 278, 08/09/2019, 2628230, Page270 of 648 MILITARY LEAVE An employee who is a member of the united States Army, Navy, Air Force, Marines, Coast Guard, a member of the National Guard, a member of the Reserves or Public Health Service will, where a specified period of active or reserve duty is mandatory, be granted a leave of absence in accordance with applicable law. Upon receipt of orders for active or reserve duty, the employee should notify his/her supervisor, as well as the Human Resources Manager immediately and he/she must submit a copy of his/her orders to his/her supervisor and the Human Resources Manager. MATERNITY LEAVE or ABSENCE Pregnancy, childbirth, and related medical conditions are temporary disabilities for the purpose of any health or temporary disability insurance or sick leave policy maintained by the Club. An employee who is pregnant, or has medical conditions related to pregnancy will be granted a leave of absence and will be eligible for the same leave benefits as received by employees suffering from illness or other temporary disabilities. FAMILY MEDICAL AND PERSONAL LEAVE OF ABSENCE MAR-A-LAGO 0216 Case 18-2868, Document 278, 08/09/2019, 2628230, Page271 of 648 As a result of the Federal Family and Medical Leave Act the Club provides an added benefit to each employee. Each employee will have up to 12 weeks of unpaid family leave during a "rolling" 12-month period month period for: (1) the birth and care of a newborn child; (2) adoption or foster care of a child; (3) to provide care to an employee's spouse, son, daughter or parent (or grandparent under certain circumstances) who has a serious health condition; and (4) the employee's own serious health condition which makes the employee unable to perform his/her job functions. Upon an employee's return from this leave, the Club guarantees that the employee will be placed in the same or equivalent position, absent grievous and substantial business reasons affecting the Club. This leave may be used during the rolling 12?month period even if the full 12 weeks have not been taken. Intermittent use of this leave or a reduced leave schedule may be allowed only where leave is taken for a sick family member, or for an employee's own serious health condition, when medically necessary. If you are not eligible for the 12 weeks unpaid leave, you may still be eligible to take-an unpaid leave of absence for medical reasons or a personal leave of absence at the discretion of the Club. As a result of the Act, it has been necessary to modify some provisions of our policies on sick days, short term disability and personal leaves of absence to comply with the Act. The information that follows is designed to address the great majority of situations that arise in a regular or routine manner. The federal Family Leave Law, however, is subject to on?going review process and interpretation by the courts, therefore, the statements made here can not possibly address every contingency that may arise in interpreting this new and broad Law. For these reasons, special situations will be reviewed on a case?by?case basis. Set forth below is the Club policy with regard to medical and personal leaves of absence, including provisions of Act. If you have any questions, please contact the Human Resources Manager who will be glad to answer your questions. A. 12 Week Family Medical Leave Purpose: I This policy allows an employee to request a family or regular medical leave of absence (LOA) because the employee has a serious health condition which makes the employee unable to perform the functions of the job position (this policy includes a serious health condition related to pregnancy). MAR-A-LAGO 0217 Case 18-2868, Document 278, 08/09/2019, 2628230, Page272 of 648 Policy: All employees with a minimum of 12 months of service (and 1250 or more hours worked during the previous 12 months) at the time the family medical LOA begins, are eligible for up to 12 weeks of unpaid family medical LOA during a rolling 12?month period. Employees are eligible so long as the employee is certified to be unable to work during this LOA period. See Section below for details on requesting this LOA. B. Regular Policy for those Not Eligible for Family Medical LOA ie.q. previously used Familv LOA) All employees who are not eligible for the 12 week family medical LOA at the time the medical LOA begins less than 12 months of service, less than 1250 hours worked, or insufficient time has passed since a previous LOA) are eligible for unpaid medical LOA normally not to exceed 10 days. See Section below for details on requesting this LOA. C. Family and Personal LOA This policy allows an employee to request consideration for a family or personal LOA.I 1. Policy {Family LOA): All employees with a minimum of 12 months of service and 1250 or more hours worked in the previous 12 months at the time the family LOA begins are eligible for up to 12 weeks of unpaid LOA during a rolling 12-month period for: the birth or adoption (or foster care) of a child. providing care to a family member who has a serious health condition (family member is defined as spouse, child, or parent). Please Note: A child is one who is under 18 years of age or if 18 years or older must be incapable of self?care because of mental or physical disability. 2. Policy (Personal LOA) Employees who are not eligible for the 12 weeks family LOA at the time the LOA begins less than 1 year of service, less than 1250 hours worked, or insufficient time has passed since previous LOA) are eligible for a personal LOA without pay in the Club's sole discretion. MAR-A-LAGO 0218 Case 18-2868, Document 278, 08/09/2019, 2628230, Page273 of 648 Employees requiring additional time may be required to terminate employment and advise the Club of availability for future rehire. Request for non?family personal LOA may not be approved due to the effect on department operations and/or due to the individual's job performance. See Section below for details on requesting this LOA. D. General Procedures for LOA 1. While on an approved family or other LOA, an employee does not accrue time toward sick leave, vacation days, merit review nor does he/she receive holiday pay. 2. Detailed Procedures: A request for any medical LOA must be certified by the employee's health care provider on the claim form supplied by the Human Resources Manager. An employee requesting a medical LOA must provide the Human Resources Manager with sufficient medical evidence to support the condition that prevents the employee from performing the assigned job duties. ?This signed health care provider's statement must include effective date of the LOA, reason for the LOA and approximate date of return. If the medical evidence is deemed to be inconclusive, the Human Resources Manager may arrange for a medical examination (at the Club's expense) to determine the extent of the employee's condition. The Club may require periodic recertification. The duration of a medical LOA is determined by the period of time the employee has a serious health condition which makes the employee unable to perform the job efficiently and safely. Reinstatement may not be guaranteed in management's discretion (employee will be notified prior to beginning the LOA) if the employee is a key salaried employee. An employee who returns from a family medical or family LOA on or before the approved LOA has elapsed will be reinstated to his/her previous department and job. Otherwise, every effort will be made to place the returning employee into an equivalent position. However, for an employee returning from a LOA that has exceeded the allowed maximum calendar days, no MAR-A-LAGO 0219 Case 18-2868, Document 278, 08/09/2019, 2628230, Page274 of 648 guarantee of reinstatement can be made. In addition, no guarantee of reinstatement can be -made for a regular medical or non-family personal LOA. However, if possible, the employee will be re?employed in accordance with the following priorities: In his or her former job if available; In a comparable job at the same (or higher grade) if available, and if the employee is qualified for that job (at the same salary or higher); In a lower grade job, if available, and if the employee is qualified for that job. If reemployed, the employee will receive the same salary as he or she received immediately prior to the LOA unless such salary exceeds the maximum salary for the employee's grade upon reemployment, in which case the employee will be paid at that grade maximum; or If no job is available at the termination of the LOA, the employee will be placed on a preferential hiring list at the Club's sole discretion in a position for which the employee is qualified. A request for an LOA is expected to be submitted to the employee's supervisor and the Human Resources Manager at least 30 days prior to the effective date of the LOA (emergencies excepted). This request should include the effective date of the LOA, reason for the LOA and approximate date of return. For a medical or family LOA, each employee will be required to use earned vacation, personal days and sick pay benefits at the beginning of the LOA. For a personal LOA, only earned vacation will be required to be used. For each employee granted a family medical or family LOA, the Club will continue the group health insurance benefit coverage under which the employee was covered as of the last day worked. However, any premiums paid by the employee prior to the LOA must continue to be paid by the employee during the LOA. Payments are due at the same time as they would be made by payroll deduction. If an employee fails to return to work after taking a family or medical LOA, the employee may be potentially liable for payment of health MAR-A-LAGO 0220 Case 18-2868, Document 278, 08/09/2019, 2628230, Page275 of 648 insurance premiums paid by the employer during the LOA. (9) An employee on an LOA must notify the Human Resources Manager of intent to return at least 7 days prior to the desired return date. Medical certification of ability to resume duties must be provided to the Human Resources Manager prior to returning to work. Failure to provide medical certification may result in disciplinary action or termination. An employee must contact the Human Resources Manager with a request for an LOA extension at least 14 days in advance of the scheduled return (emergencies excepted). Medical certification is required prior to the beginning of the extension for a medical LOA. The Human Resources Manager will notify the appropriate Manager of the date of return of an employee returning from an approved LOA. If an employee fails to return to work at the conclusion of an LOA, the LOA will be cancelled and employment will be discontinued as a voluntary termination with the effective date of termination the last day actually worked. An employee requiring a medical or personal LOA who has not completed the initial probation period is not eligible for such a LOA and must terminate his/her employment. These employees may be eligible for conversion of group medical insurance. At the Club's option this category of employee may be placed on a preferential hiring list. (1) Abuse of an LOA may result in termination of employment. In any case in which a husband and wife are entitled to a LOA, the total days of family LOA to which both may be entitled may be limited to 12 weeks during any rolling 12-month period if the family LOA is taken for the birth, adoption (or foster care) of a child. In addition, as an alternative to the LOA, the Club and each employee may mutually agree to 'alternate employment for the employee for the time during which the employee would otherwise be entitled to a LOA under Club policy. Such period of alternate employment will not cause a reduction MAR-A-LAGO 0221 Case 18-2868, Document 278, 08/09/2019, 2628230, Page276 of 648 in the period of the LOA to which the Club employee is otherwise entitled for their own serious illness. (0) The rolling 12?month period in which the 12 weeks of LOA entitlement occurs is a "rolling" 12?month period measured backwards from the date an employee uses a family or medical LOA. Exception Approval: Questions concerning this policy should be directed to the Human Resources Manager. GRIEVLNCE PROCEDURE The Club recognizes that employees may have questions or problems concerning the Club's policies and procedures. In order to encourage employees to voice these concerns and try to solve the questions or problems that may arise, we have a formal problem solving procedure. Please follow these steps: Step 1: You should first request to meet with your immediate supervisor (the person you report to directly). The supervisor will listen and investigate the problem with the intention of finding an agreeable solution for those concerned. In order to facilitate a fair and timely solution, you must contact your supervisor within three days MAR-A-LAGO 0222 Case 18-2868, Document 278, 08/09/2019, 2628230, Page277 of 648 of the occurrence that created the question or problem. If you feel the problem is with your immediate supervisor, you may skip step 1 and start the grievance procedure with Step 2. Step 2: Request to meet with your Department Head. Your Department Head will review the problem (including any action taken by your immediate supervisor) and any other relevant facts involved in order to suggest a reasonable solution. In order to facilitate a fair and timely solution, you must contact your Department Head within three days of the occurrence that created the question or problem (if you skipped Step 1) or within two days of your supervisor's resolution (if you followed Step 1. If you are not satisfied with your Department Head's handling of the problem, you may proceed to Step 3. Step 3: Request to meet with the Managing Director, or a designated representative, will thoroughly investigate the problem, review Club policies, procedures, rules and regulations and will make a determination. In order to facilitate a fair and timely solution, you must contact the Managing Director within two days of your Department Head?s determination. The Managing Director, or his or her designee, may review the matter and offer a final decision. Time spent by an employee in discussing a complaint with management during normal working hours will be considered hours worked for pay purposes. When two or more employees have a common or similar complaint, the employees may select a spokesperson to represent the group. The final decision on the complaint submitted by several employees through a spokesperson will be binding on all members of the group. If at any time you feel uncomfortable with this process, as it is outlined here, please feel free to contact the Managing Director to assist you before taking further action. Due to the serious nature of sexual harassment, such complaints should be referred immediately and directly to the Managing Director and Human Resources Manager. MAR-A-LAGO 0223 Case 18-2868, Document 278, 08/09/2019, 2628230, Page278 of 648 The Club will not tolerate any form of retaliation against employees who have used the Club's problem solving procedure. In the interest of creating a positive and enjoyable work environment, all employees shall be able to use this procedure . without fear of retaliation. However, it is equally important to realize that the problem solving procedure will not prevent the Club from taking disciplinary action, up to and including termination, against any individual under circumstances where the Club deems disciplinary action to be appropriate. MAR-A-LAGO 0224 Case 18-2868, Document 278, 08/09/2019, 2628230, Page279 of 648 DISCIPLINARY ACTION A. GENERAL POLICY ADHERENCE Policies and procedures are necessary guidelines to provide a basis for fair and equitable treatment of each employee. In addition, these guidelines serve as the basis for a fair relationship between the employee and the Club. It is necessary that these guidelines be applied consistently to each employee regardless of location, department or manager. Then, and only then, can the Club establish the confidence that each employee will be treated consistently according to the administrative and operational guidelines. It is the responsibility of each officer, manager, supervisor and employee to contribute fully toward the achievement of this objective. B. DISCIPLINARY ACTIONS Violations of any of the established policies and procedures may result in disciplinary action including probation or discharge. The nature of the disciplinary action is contingent upon the facts and circumstances of the individual situation. The following employee actions are not all inclusive but, by way of illustration only, are some of the events which could result in discipline including discharge. Thus, your department head may establish additional rules and regulations he or she feels are necessary for the orderly fulfillment of your department's responsibilities. These also must be followed. Other actions may also result in discipline including discharge. (It should be noted that the Club and each employee recognize that the employment relationship is for an indefinite period and may be terminated by either party at will.) By providing this list, the Club in no way restricts its legal discretion to terminate employment. a. Insubordination, refusal or inability to comply with reasonable instructions of supervisors or department heads. If your supervisor requests you to do something with which you disagree, always follow the instructions at the time and then discuss it later at an appropriate time and location. However, this excludes obedience to demands constituting discrimination, sexual harassment or illegal conduct. b. Interference or hindrance with shift schedules. Failure to work on a shift as scheduled or arranging your own shift replacement without the supervisor's permission. c. unauthorized use of Club telephone or property and/or guest facilities. d. Entering the Club more than 30 minutes before your shift begins or leaving the Club more than 30 minutes after the end of your shift without the permission of your department head or supervisor. Entering or MAR-A-LAGO 0225 Case 18-2868, Document 278, 08/09/2019, 2628230, Page280 of 648 presence in areas within the Club premises without authorization or just cause. e. Presence on Club premises at anytime other than your assigned work shift unless specifically authorized by your department head in advance. f. An essential element of the security procedures of the Mar-a?Lago Club is the key control process. As such,_ employees who have access to Club keys must recognize the importance of properly safeguarding the keys which have been entrusted to them. All employees should be -aware that they may be subject to disciplinary action for any violation of the key control procedures. Guest room keys must never be left in your locker. g. Theft (unauthorized removal) or misappropriation (unauthorized storage, transfer, utilization or possession) of Club services unauthorized telephone calls, laundry/valet, food and beverage), or guest, employer or Club property, including items found on the Club premises. All articles found on Club premises must be turned into the Lost and Found area at Security in the Timekeeper's area. h. Altering or falsifying a guest check or credit voucher or forging tips through guest checks. i. Refusal to comply with Club rules, policies or procedures. j. Poor job performance, including unsatisfactory attitude that detracts from job performance or the efficient operation of the Club. k. Violation of sexual harassment policy. 1. Failure to report for duty without a bona fide excuse and proper notification to your supervisor. m. Failure to comply with established safety and health rules and safe work procedures or engaging in any conduct that creates a safety hazard. Failure to meet performance standards. Failure to follow grooming and appearance standards. Failure to report a workplace accident immediately. If you are injured on the job, you must immediately report this to your supervisor or Human Resources Manager. Falsely stating claims of injury. Disorderly conduct on the Club premises, including fighting, horseplay or other action that endangers others or Club property. 5. Offensive or disruptive behavior, including threatening employees, using abusive or vulgar language, interfering with others in the performance of their duties, or acting in an immoral or indecent manner on Club property, or while off the Club premises in performance of Club duties. 0:3 Fi? t. Destruction, misuse, or removal of Club property, a guest's property or another employee's property. u. Unauthorized disclosure, discussion, removal or use of Club confidential, information, trade secrets or other MAR-A-LAGO 0226 Case 18-2868, Document 278, 08/09/2019, 2628230, Page28l of 648 proprietary information (including information contained in personnel records). v. Deliberate omission or falsification of information on employment application, time sheets, production or other Club records. w. Unauthorized distribution of literature, posting Of notices or signs on Club, premises, fundraising, selling lottery tickets or merchandise, or soliciting donations or any other type of money raising on Club premises, unless specifically authorized by the Managing Director. x. Refusal to allow security checks and package inspections. y. Reading books, magazines, or newspapers while on duty, except where required in the line of duty. 2. Loitering, loafing or sleeping on duty. aa. Neglect of duty causing defective work. bb. Smoking anywhere on club property including 124 Woodbridge Rd. and 1094 WOodbridge Rd. cc. Reporting for duty under the influence of intoxicating liquor, marijuana and/or illegal drugs. dd. Bringing, consuming, possessing, providing, selling, or otherwise using intoxicating liquors, marijuana and/or illegal drugs on Club premises. ee. Dishonesty, including but not limited to intentionally not providing full and truthful information when requested by management. ff. Gambling on Club premises. gg. Bringing, discharging, and/or possessing unauthorized firearms or other weapons on Club property or while off Club Property in the performance of Club duties. hh. Giving or taking a bribe of any nature. ii. Being arrested and/or convicted of any crime which the Club believes is detrimental to the Club and/or its other employees. jj. Theft, attempted theft, removal or unauthorized possession of the Club's property or property of other employees or customers. kk. Misappropriation of Club funds or failure to handle funds in accordance with Club guidelines. ll. Irregular attendance including excessive absenteeism, tardiness and/or unexcused absences. mm. Leaving work station or work without authorization or being in an unauthorized work area during your scheduled work period or on your days off, without your supervisor's specific authorization. nn. Interfering with or hindering of work schedules; failing to work on a scheduled shift; or arranging your own replacement on a shift without permission from a supervisor. 00. Failure to report to work after the expiration of a leave?of?absence or layoff. pp. Defrauding customers of the Club. qq. Embezzlement. MAR-A-LAGO 0227 Case 18-2868, Document 278, 08/09/2019, 2628230, Page282 of 648 rr. Disloyalty to the Club, including but not limited to, slandering the Club, or acting in such a manner that could damage the Club's reputation. ss. Moral turpitude. tt. Failure to wear assigned uniform. uu. Entering or leaving the property through any entrance or exit other than the designated employee entrance or exit. Punching in/out with another employee's I.D. Card or allowing another employee to punch in/out on your card. Unauthorized attendance at guest functions and/or in guest areas, or on the premises including guest rooms, dining rooms and lounges. No unauthorized social contact will be permitted at any time with Club guests. Discourteous or inappropriate conduct with guests/members. Using guest elevators, escalators, restrooms or any guest facility except when specifically required by job functions or authorized by management. zz. Gum chewing, eating or drinking in any public area of the Club. Soliciting gratuities frOm guests or commenting on the amount of a gratuity. .5 MAR-A-LAGO 0228 Case 18-2868, Document 278, 08/09/2019, 2628230, Page283 of 648 UNIFORMS AND PERSONAL APPEARANCE A. UNIFORMS Employees issued a uniform are responsible for turning their soiled uniform to the Laundry Department at the end of their shift and picking up a clean one for the next day of work. All employee uniforms are laundered by the Club at no charge to the employee. B. PERSONAL APPEARANCE Departure from conventional Club attire or personal grooming are not permitted, regardless of the nature of the job performed. (1) Every employee has some contact with the public and therefore represents the Club in appearance as well as by actions. The properly attired employee helps to create a favorable image for the Club. Accordingly, personal appearance shall be governed by the following standards: Good hygiene and grooming practices are required. A daily bath or shower is a necessity and all employees should report to work freshly bathed. Keep in mind you may be going from a hot kitchen to an air conditioned guest room. Body temperatures will change quickly and body odors are offensive. Remember, there is no substitute for good deodorant. Bad breath is also offensive and mouthwash should be used in addition to brushing teeth. Good hygiene and grooming practices are required. Fingernails, and hair must be clean and neatly trimmed at all times. Beards,goatees, and un?trimmed sideburns are not permitted. Mustaches must be neatly trimmed. Men's hair should not exceed collar length and must be conservatively styled. Visible body piercing is not permitted for men or women, nor ear jewelry for men. Hair must be neatly arranged and kept from covering eyes, and must be covered or restrained where required by health code. All employees must wear their nametags (to be provided) at all times while on duty. MAR-A-LAGO 0229 Case 18-2868, Document 278, 08/09/2019, 2628230, Page284 of 648 All employees are expected to report to work in clean, neatly pressed clothing, clean shoes and clean personal appearance. Female employees who are not required to wear a uniform may wear suits, dresses, skirts or slacks with blouses or sweaters. ?Mini" skirts are not permissible. No blue jeans or jeans of any color are permitted. Denim outfits resembling blue jeans and jean skirts are also unacceptable. No strapless or backless garmets may be worn. Females must wear the proper undergarments, including a bra and a full or half slip where necessary, depending on the Sheerness of the outer garment. Hose are required with skirts and dresses. Hose or socks are required with pants. Jewelry: For safety reasons, jewelry should be kept to a minimum. Acceptable jewelry for service employees is a wrist watch and a total of three rings. Female service employees are allowed to wear one pair of small earrings (no larger than a dime). Non guest contact female emplOyees are allowed to wear a maximum of two earrings in each ear. Tattoos: Exposed tatoos are not allowed on any public contact employees. FULL TIME YEAR ROUND EMPLOYEES - During the summer months when the Club is closed and there is no public contact you may see your Department Head as to - what is considered to be proper attire for your position. (2) Supervisors have the responsibility to decide when an employee's appearance is unacceptable. In the event of an unacceptable appearance, the Supervisor may request that the employee return home to change or take an appropriate corrective action. The employee generally shall not be compensated for any such time away from work, and repeated violations of this Policy will be cause for disciplinary action. MAR-A-LAGO 0230 Case 18-2868, Document 278, 08/09/2019, 2628230, Page285 of 648 AIDS POLICY The Club recognizes that Acquired Immune Deficiency (AIDS), its related conditions such as AIDS Related Complex (ARC), and persons with seropositive test results pose significant and delicate issues for employees in the workplace. Accordingly, we have established the following guidelines for handling employee issues that arise when an employee is affected by this disease. (1) The Club is committed to maintaining a safe and healthy work environment for all employees. (2) Consistent with this commitment, the Club will treat AIDS the same as other illnesses in terms of all our employee policies and benefits, such as group health and disability benefits. (3) Based on the overwhelming preponderance of available medical and scientific opinion, including statements from the U.S. Public Health Service, Centers for Disease Control, there is no evidence that the AIDS virus is casually transmitted in ordinary social or occupational settings or conditions. Therefore, subject to changes in available medical information, it is the policy of the Club that employees with AIDS or any of its related conditions may continue to work and the Club will provide them with reasonable accommodation as long as they are medically able to perform the duties of their position. (4) Employees who are affected by AIDS or any other life-threatening illness will be treated with compassion and understanding in dealing with their personal crises. Co?workers will be expected to not refuse to work or withhold their services for fear of contracting AIDS by working with an AIDS affected person, and to not harass or otherwise discriminate against an AIDS?affected employee. (5) Recognizing the need for all employees to be able to be accurately informed about AIDS, upon request, the Club will make every effort to have information available regarding the facts about this disease, how it is transmitted and not transmitted and how best to contain it from spreading. Employees affected by AIDS or any of its related conditions or concerned about AIDS are encouraged to contact Human Resources Manager to discuss their concerns and to obtain additional information. (6) The Club will treat all medical information obtained from employees with AIDS or any of its related conditions confidentially as required by law. The Club reserves the right to change this policy or make appropriate revisions, additions, amendments or corrections. We will notify you of any substantive changes. MAR-A-LAGO 0231 Case 18-2868, Document 278, 08/09/2019, 2628230, Page286 of 648 . If you have any questions about this policy or its interpretation or the information upon which it is based, please contact the Human Resources Manager. MAR-A-LAGO 0232 Case 18-2868, Document 278, 08/09/2019, 2628230, Page287 of 648 SUBSTANCE ABUSE POLICY Our Club strives to provide a safe work environment and encourages personal health. In regard to this, the Club considers the abuse of drugs or alcohol on the job to be an' unsafe and counterproductive work practice. Quite simply, our goal is to maintain a work environment that is free from the effects of alcohol and drug abuse. While the Club has no intention of intruding into the private lives of its employees, the Club does expect employees to report for work in condition to perform their duties. It is, therefore, Club policy that an employee found with the presence of alcohol or illegal drugs in his/her system, in possession of, using, selling, trading, or offering for sale illegal drugs or alcohol during working hours, may be subject to disciplinary action up to and including discharge. (Club sponsored activities which may include the service of alcoholic beverages are not included in this provision.) Substance Abuse includes possession, use, purchase or sale of drugs or alcohol on Club premises. It also includes reporting to work under the influence of drugs or alcohol. Prescription drugs?prescribed by the employee's physician may be taken during work hours. The employee should notify the Supervisor if the use of?properly prescribed prescription drugs will affect the employee's work performance. Abuse of prescription drugs will not be tolerated. An employee reporting for work visibly impaired is unable to properly perform required duties and will not be allowed to work. MAR-A-LAGO 0233 Case 18-2868, Document 278, 08/09/2019, 2628230, Page288 of 648 POLICY ON SMOKING Smoking is prohibited by any staff employee of The Mar?a- Lago Club on any and all properties adjacent to or that of The Mar?a?Lago Club to include: 124 Woodbridge Road Palm Beach, FL 1094 Woodbridge Road Palm Beach, FL MAR-A-LAGO 0234 Case 18-2868, Document 278, 08/09/2019, 2628230, Page289 of 648 USE AND The Mar?a?Lago Club recognizes that employee drug abuse interferes with the Club?s level of production, as well as its competitive position in the marketplace, and can result in costs, delays, and tragedies associated with work?related accidents. As a condition to employment or continued employment, you must refrain from reporting to work or working with the presence of drugs or alcohol in your body. To address the problem of drug/alcohol abuse and to comply with Florida's Workers? Compensation Drug?Free Workplace Act (the Act) The Mar-a-Lago Club adopts the policies and procedures detailed below. This policy will be administered in accordance with all relevant laws (state and local), including the ADA, the Florida Civil Rights Act, the Workers' Compensation Act, and in a non? discriminatory fashion. To protect the health, safety, and welfare of all Mar-a-Lago Club employees, it is the Club?s policy that the unlawful manufacture, distribution, dispensation, possession, or use of controlled substance on any Club property is absolutely prohibited. Controlled substances include, but are not limited to, amphetamines, barbiturates, cocaine, heroin, morphine, PCP, marijuana, hashish, and any other controlled substance listed in Schedules I through of Section 202 of the Controlled Substance Act, 21 U.S.C. 812 or in the Florida Statute on controlled substances, except for medication prescribed by the employee's physician. You are also prohibited from drinking alcohol during the business day. You are also prohibited from bringing alcoholic beverages onto the Club premises. Special care shall be taken during Company?sponsored social events for employees. In these cases, employees and guests below the legal age will not be allowed to drink alcoholic beverages. The amount of time alcohol is served will be limited as well as the quantity of the alcohol. If necessary, transportation will be arranged for someone if his or her driving ability seems to be impaired. The Mar-a-Lago Club will test for the presence of drugs under the following circumstances: 1) pre?employment testing, 2) reasonable suspicion testing (including post?accident incidents), and 3) follow?up testing. Such testing will be done in accordance with the Worker's Compensation Drug Testing Program, which policy had been given to all employees or can be obtained from the Human Resources Manager. Refusal to submit to the test or having a confirmed, positive test result will result in immediate discipline, including termination. Any questions about this policy should be referred to the Human Resources Manager. MAR-A-LAGO 0235 Case 18-2868, Document 278, 08/09/2019, 2628230, Page290 of 648 Any violation of The Mar?a-Lago Club's Drug/Alcohol Free Workplace Policy will result in appropriate discipline, up to and including termination. THIS POLICY REPRESENTS THE CURRENT POLICY FOR DEALING WITH A SERIOUS NATIONAL PROBLEM WHICH POSES A SAFETY THREAT TO THE WORKFORCE. THIS POLICY MAY BE CHANGED BY THE A-LAGO CLUB IN ITS DISCRETION. THIS POLICY IS NOT INTENDED TO CREATE A CONTRACT BETWEEN THE MAR-A-LAGO CLUB AND ANY EMPLOYEE. NOTHING IN THIS POLICY CHANGES THE ABILITY TO TERMINATE AN EMPLOYEE AT WILL, WITH OR WITHOUT CAUSE OR NOTICE. MISCELLANEOUS A. STAFF CAFETERIA For the purpose of control, the Cafeteria must remain for use of Club employees only. Any exceptions to this rule must be cleared by your department head in advance. In addition, all employees must adhere to the rules posted in the Cafeteria concerning its use. You are entitled to one meal per eight hour shift only. B. LOCKERS Those employees issued lockers are obligated to keep them clean and use them for storage of a change of clothing only. Lockers are not the areas for storage of valuables. Lockers are subject to inspection by management. Unauthorized materials such as alcoholic beverages, weapons, Club property and illegal drugs are prohibited. The Mar?a-Lago Club is not responsible for lost or stolen property. MAR-A-LAGO 0236 Case 18-2868, Document 278, 08/09/2019, 2628230, Page291 of 648 C. PHONES Employees on duty are not allowed to use the public phones in the lobbies or any guest areas. Phones are furnished out? side the staff dining room for employee use. D. LOST AND FOUND ARTICLES You must turn in lost and found articles to your supervisor, the Security Department or a security officer at One. E. GIFTS Gifts from guests of the Club of a value exceeding $25.00 are not to be accepted by employees of The Mar-a Lago Club unless approved in writing by the Department Head. No employee shall accept any gift from any vendor. F. TO KNOW STATION. The Occupational Safety Hazard Administration requires all employees be provided with information of all potentially hazardous substances used in the course of our daily business. The location of these documents (Material Safety Data Sheets) is in the staff dining room on the wall adjoining the Food and Beverage office. G. EMPLOYEE ENTRANCE AND EXIT All employees required to log in and log out their daily time must enter and exit the building through the entrance on the east side of the house leading to Post One. MAR-A-LAGO 0237 Case 18-2868, Document 278, 08/09/2019, 2628230, Page292 of 648 TERMINATION PROCEDURE Clearance Process a. Clearance of locker. b. Return of uniform to Laundry. c. Nametag, locker key, any property keys, and uniform returned to Executive Office. d. Any outstanding accounts settled. NOTE: If you abandon your job without notice, your final paycheck will not be mailed until you have returned to the Club and completed the clearance process. MAR-A-LAGO 0238 Case 18-2868, Document 278, 08/09/2019, 2628230, Page293 of 648 IF YOU LEAVE EMPLOYMENT RESIGNATION POLICY When an employee decides to leave for any reason, his/her supervisor and the Human Resources Manager would like the opportunity to discuss the resignation before final action is taken. The Mar?a?Lago Club often finds during such a conversation that another alternative may be better. If, however, after full consideration the employee decides to leave, it is expected that the employee will provide the Club with a written two?week advance notice period (bear in mind that vacation days or personal days may not be included in the two? week notice period). Generally, in order to qualify for payment of earned unused vacation, the employee must work throughout the notice period. If, as sometimes hapens, the employee's supervisor believes it advisable for the employee to leave prior to the end of the employee's two?weeks notice, the employee may be paid for the remainder of that period. ~Note: You are not entitled to be paid for any unused, accrued sick time. DISMISSALS Every Mar-a?Lago employee has the status of meaning that no one has a contractual right, express or implied, to remain in The Mar?a?Lago Club?s employ. The Club may terminate an employee's employment, or an employee may terminate his/her employment, with or without cause, and with or without notice, at any time. No supervisor or other representative of the Club (except the owner) has the authority to enter into any agreement for employment for any specified period of time, or to make any agreement contrary to the above. IMMEDIATE DISMISSALS - MISCONDUCT Any employee whose conduct, actions or performance violates or conflicts with the Club's policies may be terminated immediately and without warning. The following are some examples of grounds for immediate dismissal of an employee: *Breach of trust or dishonesty *Conviction of a felony *Willful violation of an established policy or rule *Falsification of Club records *Gross negligence *Insubordination *Fighting or serious breach of acceptable behavior *Violation of the Alcohol or Drug Policy MAR-A-LAGO 0239 Case 18-2868, Document 278, 08/09/2019, 2628230, Page294 of 648 *Theft *Violation of the Club?s Conflict of Interest/Outside Employment Policy and/or Confidentiality Policy. This listing is not exhaustive. Should the employee be covered in our group health plan, all benefits will cease on the last day of the month in which the employee?s last day of employment falls. The employee will then have the option to continue coverage in accordance with COBRA regulations. In the event that the employee is asked to leave his/her employment with The Mar?a?Lago Club due to the above misconduct, the employee will not be entitled to any earned unused vacation benefits. Also, the employee will not be entitled to be paid for any unused accrued sick time. DISMISSALS - OTHER THAN IMMEDIATE TERMINATION All employees are expected to meet the Club?s standards of work performance. Work performance encompasses many factors, including attendance, punctuality, personal conduct, job proficiency and general compliance with the Club?s policies and procedures. If an employee does not meet these standards, the Club, may, under appropriate circumstances, take corrective action, up to and including dismissal. The intent of corrective action is to formally document problems while providing the employee with a reasonable time within which to improve performance. The process is designed to encourage development by providing employees with guidance in areas that need improvement such as poor work performance, attendance problems, personal conduct, general compliance with the Club?s policies and procedures and/or other disciplinary problems. Supervisors should use the procedure described below except in those cases which may require an employee's immediate termination. WRITTEN WARNINGS: The supervisor should discuss the problem and present a written warning to the employee. This should clearly identify the problem and outline a course of corrective action within a specific time frame. The employee should clearly understand both the corrective action and the consequence termination) if the problem is not corrected or recurs. The employee should acknowledge receipt of the warning and include any additional comments of their own before signing it. A record of the discussion and the employee? 5 comments should be placed in the employee? 3 personnel file. MAR-A-LAGO 0240 Case 18-2868, Document 278, 08/09/2019, 2628230, Page295 of 648 POST RESIGNATIONZTERMINATION PROCEDURES The Human Resources Manager is responsible for scheduling an exit interview with a terminating employee on the employee's last day of employment and for arranging the return of Club property including: Club issued credit card Club manuals Office keys Beeper Two-way radio Any additional club-owned or issued property In order to receive a disbursement of any amounts due from the Retirement Plan, the employee is required to complete and sign a distribution form which can be obtained from the Human Resources Manager. Specific information will be provided at the exit interview. Employees may choose the continuation of medical benefits under COBRA. Specific information will be provided by the Human Resources Manager at the exit interview. Benefits (Life and Medical) end on the last day of the month in which the employee?s last day of employment falls. An employee has the option to continue Medical Benefits in accordance with The Consolidated Omnibus Budget Reconciliation Act regulations. Employees leaving the Club must return office keys, club credit cards, etc., before their final paycheck can be issed. This final paycheck will be mailed during the next normal pay period. If there are unpaid obligations to the Club, the final paycheck will reflect the appropriate deductions. VACATION PAY Vacation pay is calculated in accordance with our vacation policy. If the employee took more vacation days than he/she was entitled to under the vacation policy, the time will be deducted from the employees final paycheck. RETIREMENT PLAN If an employee is in the retirement plan, information regarding this plan will be provided at the exit interview. MAR-A-LAGO 0241 Case 18-2868, Document 278, 08/09/2019, 2628230, Page296 of 648 EMPLOYEE HANDBOOK RECEIPT INSTRUCTIONS: PLEASE READ THIS PERSONNEL POLICIES AND PROCEDURES EMPLOYEE HANDBOOK CAREFULLY. IF YOU DO NOT UNDERSTAND ANY PORTION OF IT, ASK FOR AN EXPLANATION FROM THE CLUB OFFICE. RETURN THIS SIGNED RECEIPT TO THE CLUB OFFICE IMMEDIATELY AFTER YOU HAVE RECEIVED THIS MANUAL. PLEASE KEEP THE HANDBOOK FOR FUTURE REFERENCE. I received the Policy Manual of The Mar?A- Lago Club, L.C. on the date indicated below. I will carefully read the policies, procedures, and other information contained in the Manual and will ask the Club Manager's office for an explanation if I do not fully understand them. I agree as a condition of my employment to comply with the policies and procedures which exist now or which may come into existence in the future. I understand that if I do not comply with the policies and procedures, I may be subject to disciplinary action. I also understand that I or the Club may terminate employment at any time, for any reason. The Club reserves the right to modify or terminate any policies or procedures, in whole or in part, at any time, with or without notice. I understand that only the Managing Director is authorized to set policy or make any promises with respect to my employment. The language used in this Handbook is not intended to create, nor is it to be construed to constitute, a contract between the Club and any one or all of its employees. Date Employee's Name MAR-A-LAGO 0242 Case 18-2868, Document 278, 08/09/2019, 2628230, Page297 of 648 Employee's Signature 159816 MAR-A-LAGO 0243 Case 18-2868, Document 278, 08/09/2019, 2628230, Page298 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page299 of 648 Vicki Yawnick: Please run the following this Saturday October 14 and Sunday October 15: THE G0 CLUB Private Club in Palm Beach now seeking quali?ed individuals for the following seasonal positions: *Wait Staff *Asst. Food Server *Banquet Servers Sous Chef *Asst. Banquet Chef *Line Cooks *Pastry Cooks *Steward *Dishwashers *Housekeepers- llpm-3am *Houseperson ll pm-3am *Valet - must have a clean driving record. *Salon Asst. *Nail Technician *Make?Up Artist Part Time *License Massage Therapist-must have experience in wet treatments. *Esthetician *Spa Attendants - College students encourage to apply. Call Carol Ash, M-F, 9am-5pm, (561) 833-8767, ext. 313 or fax resume to (561) 832-2194. Drug/Smoke Free Workplace. EOE TING MAR-A-LAGO 0086 Case 18-2868, Document 278, 08/09/2019, 2628230, Page300 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page301 of 648 A. ..- . FIQIJIV .RE i A . vi? - 512COJE . l? -22 :Squk' - inn com: . I P'Hb'ru?u; . ?n?g?rf?gfiey EMPLOYMENT DESIRED Eogn. CN DATE you CAN sun DESIRED INQUIRE . I EMPLOYED VF No I OF YOUR PRESENT YHISTORY DID mu . ATTENDED SUBJECIS JUCJ. l) NAME Locmou or SCHOOL i I . GRAMMAR SCHOOL SCHOOL "92? CL i 3 D?v COLLEGE I . TRADE. BLSINESS OR . CORFIFSF SCHOOL I I I I 5 I GENERAL INFORMATION 5- 50F STUDY-RESEARCH WORK OR SPECIAL TRAN NC8.;wise-Luvs? MW, 33,5951; LL OJ 0.1:ng JS CR 3 NAVAL CE I FORMER EMPLOYERS LAST FOUR EMPLOVERS, STARTING WITH LAST ONE ig?bh?o?iyem NAME 6. ADDRESS OF EMPLOYER POSITION REASON FOR LEAVING I.-. .9 IS I [3800' 5-. . 2.. 7'?424.21.? _j f6 ?3 Manqgu 30?! Ia 33.4% 4.. . . {5ch Ix"? Ii. C. '3 COL/douv? I Rina: 0 (mi CAdams 9661 .1 MA APPLICATION FOR MPLOYMENT ?g AGRENMY Case 18-2868, Document 278, 08/09/2019, 2628230, Page302 of 648 0 REFERENCES GIVE BELOW THE NAMES THREE INOF RELATED TO YOU, WHOM YOU HAVE KNOWN AT LEAST ONE YEAR NAME i nooness $5353?? I . I, ?t A :11;an "dawn .2 92 2 a 7 juc?QMVt__3__ . . f" . . . - ?1 1"?f (Kai/\m' (x 3 1 . certify toe: the lacis certaned in this application are true and complete to the best of my knowledge and urderstand the: it employed, falsified statements on this application shall be grounds for dismissal. I authorize investigation of all statements contained herein and the reterences and employers listed above to g.ve you any and all intormation concerning my previous employment and any pertinent information they may have. personal or otherwise. and release the company from at: liability for any damage that may result from utilizatior of such inlormation. 5 also understand and agree that no representative of the company has any authority to enter into any agreement tor employment for any speci?ed period of time, or to make any agreement contrary to the forego- ing. unless it is in writing and signed by an authorized company representative Tnis waiver does not permit the release or use of disability-related or medical information in a manner pro- noted by the Americans with Disabilities Act (ADA) and other relevant (rm; and state laws." ave ?3 :1 SIGNATURE \A/?tywm ?3ng _w a) ,2 DATE DO NOT WRITE BELOW THIS LINE REMARKS .. 'ti'ei?? . 53amltlu - Eneime i Q-LAQKQ . 3X86 latte): to Chasm arr-caaiamcs i tamed. to #t?ch, Kim I I ME amass CHARACTER P?asGN/Emv - mail}? . 3. mes: ?Fon wosmon SALARY DEPT, REPORT WAGES APPROVED 1. 2 3. . mp. unmet]? new uENtmL MMIAGER l" axhtahO'l 'or e'nplOyme-i is sold only tor :owral?uae throughout the United States News assumes no and "crew (reclaims err; limit, lot the rchissor. u- this war at any cuatlan: or requests for manual-m upon much a Violation oi local state and/(x luderal 'aw may be based. it is the user's respmsibility to ersure that this tom's use carn- r; my amicable laws. which change from time to line. .-. .- Case 18-2868, Document 278, 08/09/2019, 2628230, Page303 of 648 Monday, November 7, 2016 I Page: 1 1Quicl<en Data - All Accounts QuickReport by Description 8/12/69 through 1/29/03 Date Account Num Payee Memo. Category I 4/22/02 Courtyard Animal Has-pital 1500 Virginia Roberts split 5/6/02 Courtyard Animal Hospital 1522 .VOlelrginia Roberts . 5/6/02 Courtyard Animal Hospital 1523 Virginia Roberts split 5/20/02 Courtyard Animal Hospital 1541 Virginia Roberts split .6/4/02 Courtyard Animal Hospital. 1555 Virginia Roberts split Total 9/12/59 - 1/29/03 I Total Inflows Total Outflows Net Total GIUFFREWSZO3 CONFIDENTIAL 0 Case 18-2868, Document 278, 08/09/2019, 2628230, Page304 of 648 Moriday, November 7, 2016 I Page: 2 1Quicken Data - A11 Accounts QuickReport by? Description 8/12/69 through 1/29/03 Amount -407.68 0.00 -380.35 6 56.08 4,269.27 . 0.00 4,269.27 -1 ?59.27 GIUFFREOW CONFIDEN Case 18-2868, Document 278, 08/09/2019, 2628230, Page305 of 648 Monday, November 7, 2016 Page: 1 iQuicken Data - All Accounts Category Detail Report 4/1/02 through 7/1/02 Date Account Num Payee Memo Category I Amount income/Expenses Expenses ?alary 4/22/02 Courtyard Animal Hospitai 1500 Virginia Roberts Salary - ?507.50 5/6/02 Courtyard Animai Hospitai 1523 Virginia Roberts Salary 472.50 5/20/02 Courtyard Animal Hospital 1541 Virginia Roberts Salary - 699.75 6/4/02 Courtyard AnimalHospital- 1555 Virginia Roberts Salary -1 82.00 Totai Salary I I -1 ,561.75 Taxes: 5 . . 4/22/02 Courtyard Animal Hospital 1500 Virginia Roberts Taxes:Sociai security - 38.82 5/6/02 Courtyard Animal Hospital 1523 Virginia Roberts Taxes;Social security 36.15 5/20/02 Courtyard Animal Hospital 1541 Virginia Roberts Taxes:Social security 30.59. 6/4/02 Courtyard Animal Hospital 1555 Virginia Roberts Taxes:$0cial security 13.92 Total Social security 119.43 I 115' 1 i' 4/22/02 Courtyard Animal Hospital 1500 Virginia Roberts Taxes:Withoiding 61.00 5/6/02 Courtyard Animai Hospital 1523 Virginia Roberts Taxes:Witholding 56.00 5/20/02 Courtyard Animal Hospital 1541 Virginia Roberts Taxes:Witholding 44.00 6/4/02 Courtyard Animal Heapitai 1555 Virginia Roberts 12.00 Totai Witholding 173.00 rota Taxes 29 2.43 5/6/02 Courtyard Animal Hospital Total Expenses - Other Total Expenses Total income/Expenses 1522 VOiDvirginia Roberts 0.00 0.00 vi 269.2 ~1,269.27 Glurmeooezos CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page306 of 648 Aprii 2002 Payroli Paycheck 1 Paycheck 2 Paycheck 3 Tatai Sociat Security - a m. . Withholding - - .- Social Security - W?thholding gs 1-. s: a Soc?ai Security 3 - - - Withhoiding 3; - - g? - Sccial Security 5 a 3 .j - Withha!d%ng - 3 a Jamie Socia? Security 38-82 38.82 Withhoiding 61.00 61.60 - Social Security .- Withholding 5 Totais . Sociai Security 33 ?12: Withhoiding Total Liability 5 - GIUFFRE009206 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page307 of 648 May 2002 Paymil Paycheck 1 Paycheck 2 Paycheck 3 Total Social Security 5 a? SE Withhoiding 3 If! ?9 Social Security -- Withholding i - Social Security 1: - Withholdiag -. Socia! Security 5 Withhogding 4 - 3 - Jenna Social Security 36.15 30.59 3 66-74 W-i?thhofding 7 56.00 44.00 3 100.00 a Social Security 35 Withhuiding 5? - Monthiy Totais I Soda; Security 3 ?12: ?4 Withholding 3 a. .0- Total Liability GIUFFRliooazo'r CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, PageBO8 of 648 June 2002 Paymll Salary Social Sewri?ty Withhalding Paycheck 'l Paycheck 2 Paycheck 3 C: H- EL Saiary Social Security Withholding Salaiy Social Withhciding lull Salary Social Security Withholding - Ml Jenna Salary Social Security Withholding l32.00. . 13.92 12.00 Saiary Social Security Withholding Totais Salary 0 Social Security Withholding Totai Liability ?8 as GIUFFREOMOB CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page309 of 648 The Sunshine Stale a? GIUFFWQ CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page310 of 648 13:12 5055533363 WP: mu: LL Fa'm WA (2001) w. tor mm 0mm.mmwmudmm. Mounts/hem" Manama ?ma WFW ?amt-?0? . new Mmaymm mummy. Motown twp: mum: 241?" r. wagm?'?' awogwwn'zwuugg )mvu . no . - Md hfmlovdmon Vow mat-an Im:mmubpguimtbdag.u WW ;wml?mw?o. mm mo- mowcoum mm mm wot - m? ll YOU Inhdc unmyuurmummowm 00mm man may un?t. BIWMMIMWII WWDW oom- ob? 01. Menu Ma Hanan-91M? on vim-(hm MM MM ?cm band on Hana-d Nmohcoa-Jyouhnos Mum-.3. ?nah roam, un?t-mum lo mnwmimm mint-w cram. demlkupuyarm; Emor'1'brm?1nooneelnaun cumyaluldopmdont. a You an smglo and mm any on. ,ob; or Emu?? r: Yoummu?odyounumum. 1-0 Enur?' Mm Emor'v {x I 0 a 0 child Tu Crud! Oncludhg additional chic tax erod?): I double drum, mm It you run mmumwmn oNIonn. 0(0an Nyou mlwum Mbu alum. o? anthem Form . mm? ?4 Employee?s Wimhowlng Allowance Certi?cate Qantas-cove Damn Act-nu m1 Lam-m {Tnhu?f- 3 Iman Dumwmumwm WUIMIM.WZIP "Uh :1 Addhiond amount. If any. you want wahhold from each paycheck. ?5 withholding vorzom mummw oThb yovloxpoctlm'und ofleodud beau-Humane hwonotulinb? writ. 'Exompt'm . . . . . [I?mm'umodw mum Nan 5 m> 1? [9,4 annoy-r- mm. m: Emu: Oomphma.? 0 Olin. coda um id imam- bvo?ulim numb-r sun-0100200 CONFDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, PageBll of 648' Courtyard Animal Hospital 13860-31 Wellington Trace Wellington, Fl. 33414 (561] 784-7387 Ms. Roberts [jenna], It is obvious that you have a number of personal issues going on that need your immediate attention and keep you from being able to focus on and perform the material duties of your job here at Courtyard Animal Hospital. In the short time you have been employed here, you have missed?multiple clays. arrived late, called in sick multiple times. The reasoning you have given has shown that you are ?distracted" at minimum. Between your ?engine falling out of your car, your axle breaking off which your boyfriend 'repaired it roadside? and your landlord tossing all your furniture and clothing out in the front yard and setting it onfire", it is clear that you have more pressing issues in your life to focus on. You have been unable to perform to an acceptable standard within our company. It is because of your inability to perform your duties here, be in attendance when scheduled and focus on the job requirements that we are forced to terminate your employment. - . - r. Pinkwasser .. murrneooazn CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page312 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page313 of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 1 Time: 8:52:02 Offense Report Program: CMS301L Day Of Week . Sunday Report Date . 6/10/01 21:25 Occur From Date: 6/10/01 21:00 Occur To Date 6/10/01 21:05 Dept Class . . BURGLARY - Non?vehicle Street Number - - - City . . ROYAL PALM BEACH, FL 33411 Zone/division Zone One (1) (No of Okee) Location Type Case Status . EXCEPTIONALLY CLEARED Report Officer WOOD, FRANK Supervisory Emp: HUGHES, THOMAS 6/17/01 Case Status Dt 8/21/Case Number . 1-01?002214 Dept Class . . BURGLARY - Non-Vehicle Case Status . EXCEPTIONALLY CLEARED Case Status Dt 8/21/01 Investigator . KACZOR, K. Case Number . 1?01?002214 Dept Unit . . DETECTIVE Investigator . KACZOR, KENNETH Supervisor . . ROBKIN, ROBERT Assignment Date: 6/19/01 State Class . Burglary Non-Vehicle Committed Statute/Ordin Forced Entry Yes Premises Enter 1 Structure Occup: Unoccupied 2 State Class . Assault Simple Committed Statute/Ordin Weapon Type . Hands/Fists/Feet I A A I I Offense 001 Burglary - Non Vehicle - Name 001 (SUSP) UNKNOWN, Name 001 (VICT) AUSTRICH, JAMES M. Offense 002 Assault Simple Name 001 (SUSP) UNKNOWN, Name 001 (VICT) AUSTRICH, JAMES M. A I A I 1 Case Number . 1-01?002214 Prompt valid in: UNKNOWN, City . . ROYAL PALM BEACH, FL 33411 Home Phone No. 561/000?0000 Business Phone 561/000-0000 RaCe . . Unknown Sex . . . . . Unknown Ethnic Origin Hispanic Case Number . - 1-01?002214 Last Name . . PERKINS JR, JOHN MARTIN Street Number - - I City . . . . . ROYAL PALM BEACH, FL 33411 County . . . PALM BEACH Home Phone No. Business Phone Birth Date . . - Birth Country Unknown Oper Lic No. . FL United States Race . . . . . White Sex . . . . . Male CERTIFIED TO BE A TRUE COPY RICL Case 18-2868, Document 278, 08/09/2019, 2628230, Page314 Of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 2 T1me: 8:52:02 Offense Report Program: CMSBO1L 1-01-002214 (Continued) Ethnic Origin WHITE I I I A I 1 Case Number . 1?01-002214 Prompt valid in: AUSTRICH, JAMES MICHAEL Street Number - - - - City . . . . . ROYAL PALM BEACH, FL 33411 County . . . . PALM BEACH Home Phone No. Business Phone 561/000?0000 Birth Date . . Birth Country Unknown Oper Lic Unknown Race . . White Sex . . . . Male Ethnic Origin WHITE Victim Type . Adult I A I - 1 Case NUmber . 1-01-002214 Last Name . . ROBERTS, VIRGINIA Person Type . OTHER PERSON Street Number 368 BENT OAK DR City ROYAL PALM BEACH, FL 33411 County . PALM BEACH Home Phone No. Business Phone 561/714-5252 Birth Date . . l/ - I Birth Country Unknown Oper Lic Unknown Race . White Sex . . . Female Ethnic Origin WHITE Height . . . . 506 Weight . . . . 103 A A I 1 Original Report Reported By: WOOD, FRANK T. 6/10/01 Entered By.: JARRETT, DAWN M. 6/21/01 ON SUNDAY, JUNE 10, 2001 AT APPROXIMATELY 2124 HOURS, I RESPONDED TO - - - -, ROYAL PALM BEACH, FLORIDA IN REFERENCE TO A BATTERY COMPLAINT. UPON MY ARRIVAL I MET WITH THE VICTIM JAMES MICHAEL AUSTRICH. AUSTRICH STATED THAT HIS EX- FIANCE VIRGINIA ROBERTS, WHO ALSO RESIDES AT THE ABOVE LISTED ADDRESS BROUGHT HER FRIEND ANTHONY TO THE APARTMENT. AUSTRICH AND UNKNOWN SUSPECT ANTHONY GET ALONG. THE SUSPECT THEN BECAME VERBALLY ABUSIVE TO AUSTRICH. AUSTRICH THEN TOLD ANTHONY To LEAVE THE APARTMENT. ANTHONY THEN BECAME AGITATED AND AGAIN AUSTRICH TOLD HIM TO LEAVE. FRIEND JOHN PERKINS WAS PRESENT DURING THE ALTERCATION AND STATED IN A SWORN WRITTEN STATEMENT THAT HE ALSO TOLD ANTHONY TO LEAVE THE APARTMENT. PERKINS WAS IN FEAR THAT AUSTRICH AND ANTHONY WERE GOING TO FIGHT. ANTHONY FINALLY LEFT THE APARTMENT. AUSTRICH GOT THE APARTMENT DOOR CLOSED ANTHONY THEN REOPENED THE DOOR AND ENTERED THE APARTMENT WITHOUT PERMISSION, AND PUNCHED AUSTRICH ON THE LEFT SIDE OF HIS FACE WITH A CLOSED FIST CAUSING MINOR SWELLING AND A LARGE RED MARK. PERKINS THEN WENT TO THE TELEPHONE AND CALLED POLICE. ANTHONY OBSERVED PERKINS ON THE TELEPHONE AND FLED THE SCENE PRIOR TO MY ARRIVAL. AUSTRICH ALSO PROVIDED ME WITH A SWORN WRITTEN STATEMENT. I ASKED AUSTRICH IF HE NEEDED MEDICAL AUSTRICH VERBALLY STATED THAT HE DID NOT NEED ANY MEDICAL TREATMENT. CERTIFIED TO BE A TRUE COPY RIC L. BRADSHAW, SHERIFF Case 18-2868, Document 278, 08/09/2019, 2628230, Page315 of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 3 Time: 8:52:02 Offense Report Program: 1?01?002214 (Continued) N.A A I 2 SUPPLEMENT Reported By: WOOD, FRANK T. 6/16/01 Entered By.: JARRETT, DAWN M. 6/21/01 SINCE 6/10/01 NUMEROUS ATTEMPTS BY TELEPHONE AND IN PERSON HAVE BEEN MADE TO GET MORE SUSPECT INFORMATION. NOR JAMES AUSTRICH, JOHN PERKINS, AND OR VIRGINIA ROBERTS HAVE BEEN AT THE RESIDENCE OR ANSWERING MY TELEPHONE MESSAGES, AT THIS TIME I WISH CLASSIFY THIS CASE AS INACTIVE DUE TO SUSPECTS LACK OF COOPERATION. A A I 3 SUPPLEMENT Reported By: KAC ZOR KENNETH A. 8 /14. 0 1 Entered By.: KACZOR, KENNETH A. 8/14/01 Reviewed By: PERVENECKI DAVID A. 8 2 1/0 1 I have attempted contact with the victim numerous times and have been, unsuccessful. Messages left with roommates have been ignored and the victim has refused to call me regarding this case. This case is exceptionally cleared due to the victim's lack of cooperation. END OF REPORT CERTIFIED To NE A TRUE cow Nu: L. BRAKESHAW, SHERIFF Case 18-2868, Document 278, 08/09/2019, 2628230, Page316 of 648 EXHIBIT om Numw. P2198317 Of 648 oqueat tor Warrant Juvenile 4. Request for Contact Agency ORI Number Annoy Nome ?0502800 YALP DEP ENT 993046 crime was: as "my 1. Felony 3. Misdemeanor 5. Ordnance '3 2. Traffic Felony 4. Traf?c Misdemeanor Other ADMIN. ONY 0F MARIJUANA OVER 20 GRAMS WITH INTENT TO SELL Charge Dow $635 OF DRUG PARAPHERNALIA 0F CONTROLLED SUBSTANCE TATE 0 A Local Address (Street. Apt, Number) CHARGES DEF. VICTIM Bus neu Addrm (N amo. Street) IWOUB Tho Person taken into custody committed the below acts In my presence. we: observed by confessed to admitting to the below facts. Onthe 191? dayoi? NOVEMBER 19.93:: who told that holshe saw the armted person commit the below acts. we: found to have committed the below acts. matting from my (described) investigation. AM. 8 PM. (Speci?cally include facts constituting cause for arrest) THE ROYAL PALM BEACH POLICE DEPARTMENT WITH MUTUAL AID RTH POLICE DE PROBABLE A LARG A 00 MARIJU of the in my oilice wit ns, DEPUTY CLE swonu AND suaschaeo espoae ME NOTARY PUBLIC I OF COUEI OFFICER 11-19-99 DATE ADMINISTRATIVE 11-19-99 DATE DISTRIBUTION: WHITE - Court Copy GREEN Attorney Agency PINK Agency e318 of 648 mm, com 18 2% 08/09/2019, 2628230 ag SE AFFIDAVIT 1. Arr 3. Raquest for Waml I Juvenie 1.1 l- 1 1 I race? 1. i Mm Money Nam Agency Ropon umber Esto.s.o.2.a.0.o ROYALPALMBEACHPOUCEDEPARTMENT 3.5 Ill I, mum 1. Folony 3. mama-nor s. Ordhance . 2. Tram Felony 4. Tri?e Mlndornomor e, on?; Nam (Last. Fm. Midas Alias Raoo Sex :2 igueroa, Anthony 8 2 U) Chm. Duabtion Chap. . . Poss. marijuana over 20 gms. Poss. With intent to sell Charm Desorption . 01mm Poss. of Drug Paraphern aha Poss. of Controlled Substance (MDMA) warm Nun. (if. Middle) 80x WM StateOf lori a I 1 LoalMdruotSnd. Apt, Noam (City) We) (zip) Phano Am Sauce 5 auulnm Adm? (Name. Street) (City) (State) (up) Phone Occupation ??Tho undetalmod 00:1nt and two that helm has just and reasonable orounda to believe. ma docs bellow that the above named Dolmam the following violation of law. The Person taken ?custody committed the hem acts In my presence. was observed by who told confessed to that lie/she saw the arrested person commlt the below acts. admitting to the below facts. was found to have committed the below acts. resulting from my (deserted) investigation. om am, April 2000 xx 19 It AM. 8 PM. (Speci?cally Include facts constituting cause for arrest.) PROBABLE CAUSE On 04-13 -00, I received from Evidence Custodian Fanelii, one pill inside a purple pill case seized from the search warrant executed on 11-19-99 on Anthony Figueroa residence. The purpose of this was to test this one pill for the presence of MDMA, usin a heroin test kit. The pill tested positive for the presence of MDMA by turning the color black. It should be noted that on 11-19-1999, after Anthony Figueroa was read his Miranda rights, he was interviewed and admitted that the pill inside the purplecase was indeed ecstasy or MDMA. This pill has a "Batman" symbol imprinted on it. This pill was placed back into evidence. Based on this information, I believe probable cause now exists for the poss. of a controlled substance (MDMA). Note, all E, suspect marijuana seized tested positive for narcotic content. p. This amended probable cause was sent to Debra Colton for charge purposes. Nothing further. 6 i 0. arm or FLORIDA - FALM BEACH COUNTY ?lef?bv cedily that the loregoing ls_La_ . 1.. .. uuzwun .. law.? A "firstor? cull? wow-pm) m. V) DEPUTY fficer George Searing 101 04-1 7-2000 we or: OFFICER (PLEASE PRINT) FAG DATE 04-17-2000 5 DATE 1 1 1 AA UILLH- . Case 18-286i Document 2628230, Page319 of 648 IN THE CIRC COURT OF FIFTEENTH IUDQAL CIRCUIT IN AND FOR PALM BEACH COUNTY, ATE OF FLORIDA CRIMINAL DIVISION STATE OFFLORJDA OREGINAL (ID-H {Cb ISSUE WARRANT ,3 vs. 0233 5 tag - ANTHONY LUIS FIGUEROA, 32:53 .r - "<3:va . SO: I INFORMATION FOR: g3; E?Dgt- g3 l) POSSESSION OF SCHEDULE I SUBSTANCE gfi? a '5 i 2) POSSESSION OF MARIJUANA IN EXCESS OF 20 GRAMS ?13 3) POSSESSION OF PARAPHERNALIA (PRODUCTION) "gs; - 4) POSSESSION OF PARAPHERNALIA (USE) In the Name and by Authority of the State of Florida: BARRY E. KRISCHER, State Attorney for the Fifteenth Judicial Circuit, Palm Beach County, Florida, by and through his undersigned Assistant State Attorney, charges that ANTHONY LUIS FIGUEROA on or about November 19, 1999, in the County of Palm Beach and State of Florida, was unlawfully and knowingly in actual or constructive possession of a substance classi?ed within Schedule 1, Florida Statute 893,03 (4), commonly known as MDMA, a controlled substance, contrary to Florida Statute (3 DEG FEL) COUNT 2: Informant aforesaid, under oath, further information makes that ANTHONY LUIS FIGUEROA on or about November 19, 1999, in the County of Palm Beach and State of Florida, was unlawfully and knowingly in actual or constructive possession of more than 20 grams of a material, compound, mixture or preparation which contained cannabis, commonly known as marijuana, a controlled substance, contrary to Florida Statute (3 DEG FEL) COUNT 3: Informant aforesaid, under oath, further information makes that ANTHONY LUIS FIGUEROA on or about November 19, 1999, in the County of Palm Beach and State of Florida, was unlawfully and knowingly in actual or constructive possession of bags, and/or a pill box, and/or a box, which was drug paraphernalia being used, intended for use, or designed for use in planting, propogating, cultivating, growing, harvesting, manufacturing, compounding, converting, producing, processing, preparing, testing, analyzing, packaging, repackaging, storing, containing or concealing a controlled substance, contrary to Florida Statute (1 DEG MISD) COUNT 4: Informant aforesaid, under oath, further information makes that ANTHONY LUIS FIGUEROA on or about November 19, 1999, in the County of Palm Beach and State of Florida, was unlawfully and knowingly in actual or constructive possession of a pipe, and/or balloons, which was drug paraphernalia being used, intended for use, or designed for use in injecting, ingesting, inhaling, or otherwise introducing into the human body a controlled substance, contrary to Florida Statute 893. (l DEG MISD): DEBRA COLTUN FL. BAR NO. 0561622 Assistant State Attorney Palm Beach County, Florida SA 00CJ001567A02 GM 25 {In i . Case 278, 08/09/2019, 2628230, Page320 of 648 STATE OF FLORIDA COUNTY OF PALM BEACH Appeared before me, DEBRA COLTUN Assistant State Attorney for Palm Beach County, Florida, personally known to me, who, being ?rst duly sworn, says that the allegations as set forth in the foregoing information are based upon facts that have been sworn to as true, and which, if true, would constitute the offense therein charged, that this prosecution is instituted in good faith, and certi?es that testimony under oath has been received from the material witness or witnesses fort se. Assistant State Attorney Sworn to and subscribed to before me this 2: day of 2000. ?ash- I?m, my NOTARY PUBLIC, State of Florida Citation Nos. (if applicable) 33:! ?I?ll-Ir" Puha?imil Engliaiti ii I, p?ts coasts. April. ?95 2W1 2:3" . I . STATE 0F FLORIDA - PALM BEACH COUNTY I hereby certify that the foregoing the record in my oiitcs wi Keith A: i its, i@ as Etu' .u by i . M, was smit- .2 I. it BF DEPUTY CLERK SA 226 Case 18-2868 Document 278, 08/09/2019, 2628230, Page32l of 648 . IN THE COURT or THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH FLORIDA SENTENCE (Probation ommunity Control Violator] (As to Count(s) I Defendant A Case Number GETS Number I ??l?in WWI woo Within; Victim I . 3L COUNTY EGUHTS 1?11th Ffing personally baf?e this Court, accompanied by the of record, 9r IArIl/l I and having been adjudicated guilty herein, and the Court having given the Defendant an opportunity to be heard and to offer matters in mitigation of sentence, show cause why defendant should not be sentenced as provided by law, and no cause being sh the Court having placed the Defendant on probation/ community control and havin revoked the Defendant?s probation/ community control for violation[s) of condition(s] and to own, and subsequently IT IS THE SENTENCE OF THE COURT that: The Defendant pay a ?ne of pursuant to Fla. Stat, plus :3 as the 5% surcharge (of the ?ne impose required by RS. 960?25, which shall be deposited in the Crimes Compensation Trust Fund, . The Defendant is hereby committed to the custody of the Department of Corrections Sheriff of Palm Beach County, Florida for a term of . further ordered that the Defendant shall be allowed a total of 2 days as credit for time incar rated prior to imposition of this sentence. It is further ordered that the composite term of all sentences imposed for the counts specified in the order shall run consecutive to [y concurrent with [check one] the following: Any active sente ce being served. - Specific sentences: [n the event the above sentence is to the Department of Corrections, the Sheriff of PalrnBeach County, Florida is hereby ordered and directed to deliver the Defendant to the Department of Corrections together with a copy of the Judgment and Sentence, and any other documents Specified by Florida Statue. The defendant in open court was advised of right to appeal from this Sentence by filing notice of appeal within thirty days from this date with the Clerk of the Court, and the Defendant's right to the assistance of counsel in taking said aptly emissLofatbre have upon showing of indigency. Inamoy certify that the tores?ilja is}; ?0 DONE AND if? . amuoyeaggiu pWalm ach County, Florida this .. .. 3 iions-ARON a. so (rev. 12/98) A CIRCUIT couar JUDGE 7 DEPUTY CLERK EDWARD A. GAHHISON CaSe 18-286 ocument 278, 08/09/2019, 2628230 Page322 of 648 IN THE CIRCUIT COURT ISTII JUDICIAL CIRCUIT OF FLORIDA, IN BEACH COUNTY use 3 7 CF 401, V0 09~455611 62 DOROTHY ll. HILKEN 9 984 CLERK PB FL millennial-lanai. STATE OF FLORIDA 1 COMMUNITY CONTROL VIOLATOR V. . PROBATION VIOLATOR EFEND I LE The above represented by I. APD (attorney) CIRCUIT 8; COUMTY COURTS I Having been tried and found guilty of the following crime?): Having entered a plea of guilty to the Having entered a plea of nolo following crime(s): eontendere to the following crime(s): COUNT CRIME or ENSE STATUTE NUMBERISJ DEGREE CASE oars 3 NUMBER NUMBER . L201) I and no muse having been shown why the Defendant should not be adjudicated guilty, 1T IS ORDERED THAT the Defendant is hereby ADJUDICATED GUILTY of the above erime(s). and having been convicted or found guilty of. or having entered aplea of nolo contendere or guilty, regardless of adjudication, to attempts or offenses relating to sexual battery (ch. 794), lewd and lascivious conduct (ch. 800). or murder (3. 782.04). aggravated battery (5. 784.045), carjacking 812.133), or home invasion robbery 812.135). or any other offense speci?ed inrsection 943.325, the defendant shall be required to submit blood specimens. [1 and good cause being shown: TT IS ORDERED THAT ADJUDICATION OF GUILT BE SENTENCE. . STAYED The Court hereby stays and withholds imposition of sentence as to countts) and places the Defendant on Probation and/or I 1 Community Control under the supervision of the Dept. of Corrections (conditions of probation set forth in separate order). SENTENCE DEFERRED The Court hereby defers imposition of sentence until The Defendmt in Open Court we advised of his right to appeal from the Judgment by ?ling notice of appeal with the Clerk of Court within thirty days . following the date sentence is imposed or probation is ordered pursuant to this adjudication. The defendant was also advised of his right to the assistance of counsel in taking said appeal at the expense of the State upon showing of indigency. DONE ANR Beach County, Florida this 2" day of Q12 ex: #10, 0/ I hereby celilly that the foregoing true py of the record in my of?ce with k. .. g: Ia tionsCIRCUIT COURT r3 C?Jr?pl CL a-I DEPUTY CLERK EDWARD A. Case 18-2868, Document 278, 08/09/2019, 2628230, Page323 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page324 of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 1 Time: 8:51:59 Offense Report Program: CMS301L Day Of Week . 2 Friday Report Date . 8/03/01 23:43 Occur From Date: 8/03/01 20:00 Occur To Date 8/03/01 23:42 Dept: Class . . Street Number HIDDEN HARBOR, - - - City . . ROYAL PALM BEACH, FL 33411 Zone/division Zone Two (2) (So of Okee/E Wil) Location Type Case Status . OPEN NOT ACTIVE Report Officer LLEWELLYN, CRAIG Supervisory Emp: MURPHY, THOMAS 8/06/01 Case Status Dt 8/03/Case Number . 1?01?003008 Dept Class . . Case Status . OPEN NOT ACTIVE Case Status Dt 8/03/01 State Class . Larceny From Building Committed Statute/Ordin I A I Category . . . STOLEN UCR Prop Type CURRENCY, NOTE, ETC. Quantity . . . 5 Description . US CURRENCY Value . . . . 500.00 Property type A I A I 1 Case Number . 1-01?003008 Prompt valid in: UNKNOWN, City . . . ROYAL PALM BEACH, FL 33411 Home Phone No. 561/000?0000 Business Phone 561/000?0000 Race . . Unknown Sex . . . . . Unknown Ethnic Origin Hispanic I I I A I 1 Case Number . 1-01-003008 Prompt valid in: ROBERTS, VIRGINIA Street Number - - I City . . . . . ROYAL PALM BEACH, FL 33411 County . . PALM BEACH Business Phone 561/714-5252 Birth Country Unknown Race . . . White Ethnic Origin WHITE . . . . . Weight . . . . 103 Victim Type . Juvenile I A I - 1 Case Number . 1-01-003008 Last Name . . FIGUEROA, ANTHONY Person Type . OTHER PERSON Street Number - - City . . . . . ROYAL PALM BEACH, FL 33411 County . . . PALM BEACH - - Business Phone 561/000-0000 - . Birth Country Unknown Oper Lic Unknown Race . . . White Sex . . . . 1 Male Ethnic Origin WHITE Juvenile . . . ADULT I A I - 2 Case Number . 1?01?003008 Last Name . . SWITZER, KYLE CERTIFIED TOBEATRUECOPY RIC L. BRADSHAW. SHERIFF Case 18-2868, Document 278, 08/09/2019, 2628230, Page325 of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 2 Time: 8:51:59 Offense Report Program: CMS301L 1?01?003008 (Continued) Person Type . OTHER PERSON Street Number - - City . . . . . ROYAL PALM BEACH, FL 33411 County . . . . PALM BEACH - - - Birth Date . . - Birth Country Unknown Oper Lic No. . FL United States Race . . White Sex . . . . . Male Ethnic Origin WHITE I A I - 3 Case Number . 1?01-003008 Last Name . . RIGEL, DUSTIN Person Type . OTHER PERSON Street Number - - - City . . . . . LOXAHATCHEE, FL 33470 County . . . PALM BEACH - -. Business Phone 561/000-0000 Birth Country Unknown Oper L1c Unknown Race . . . White Sex . . . . . Male Ethnic Origin WHITE I A I - 4 Case Number 1?01-003008 Last Name JEFFERSON CRAIG Person Type . Street Number City County Business Phone Birth Country Race Ethnic Origin I A I - 5 Case Number 1?01?003008 Last Name URVIS SCOTT Person Type Street Number City County . . Business Phone Birth Country Race . Ethnic Origin I A I - 6 Case Number . 1-01-003008 Last Name . . RISDEN, RICHARD ARTHUR Person Type . OTHER PERSON Street Number - - - City . . . . . ROYAL PALM BEACH, FL 33411 County . . . PALM BEACH Home Phone No. Business Phone 561/000?0000 Birth Date . . I I'll l' Birth Country Unknown Oper Lic No. . FL United States Race . . . . . White Sex . . . . . Male . CERTIFIED RIC L: BRADSHAW, SHERIFF Case 18-2868, Document 278, 08/09/2019, 2628230, Page326 Of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 3 Time: 8:51:59 Offense Report Program: 1~01-003008 (Continued) Ethnic Origin WHITE Height . . . . 511 Weight . . . . 160 - A A I Original Report Reported By: LLEWELLYN, CRAIG R. 3/03/01 Entered By.: JARRETT, DAWN M. 8/16/01 ON 080301 AT 2343 HOURS I WAS DISPATCHED TO - IN REFERENCE TO A SUSPICIOUS INCIDENT. UPON ARRIVAL I MADE CONTACT WITH VIRGINIA ROBERTS AND ANTHONY FIGUEROA THE RESIDENTS OF - - -. V. ROBERTS STATED THAT EARLIER IN THE EVENING SHE HAD SEVERAL PEOPLE VISITING HER AND A. FIGUEORA. ROBERTS STATED THAT WHILE THE PEOPLE WHERE IN HER APARTMENT, ONE OF THEM WENT INTO HER BEDROOM AND REMOVED $500.00 CASH FROM HER WALLET. v. ROBERTS STATED THAT SHE DOES NOT KNOW WHICH OF HER VISITORS TOOK THE MONEY. A. FIGUEROA STATED THAT V. ROBERTS WALLET WAS LOCATED IN A POCKET OF A SHIRT WHICH WAS INSIDE THE CLOSET OF THE MASTER BEDROOM. A. FIGUEROA STATED THAT HE SPOKE TO ALL OF THE VISITORS ABOUT THE MISSINGMONEY, AND THAT NO ONE ADMITTED To TAKING IT. v. ROBERTS AND A. FIGUEROA STATED THAT SEVERAL OF THE VISITORS HAD ALREADY LEFT PRIOR TO MY ARRIVAL, AND THAT THEY COULD NOT PROVIDE NAME OR CONTACT INFORMATION FOR THOSE THAT ALREADY LEFT. I THEN MADE CONTACT WITH THE REMAINING VISITORS RICHARD RISDEN, SCOTT ORVIS, CRAIG JEFFERSON, DUSTIN RIGEL, AND KYLE SWITZER, A RESIDENT OF - - -. ALL INDIVIDUALS STATED THAT THEY WERE NOT RESPONSIBLE FOR TAKING THE MONEY NOR DID ANY OF THEM KNOW WHO TOOK IT. I TOOK THE NECESSARY INFORMATION FROM V. ROBERTS AND A. FIGUEROA AND PROVIDED ME WITH A RIGHTS SHEET THAT CONTAINED A CASE NUMBER. NO FURTHER SUSPECT INFORMATION AT TIME OF REPORT. END OF REPORT i TO A TRUE COPY RIC BRADSHAW, SHERIFF Case 18-2868, Document 278, 08/09/2019, 2628230, Page327 of 648 EXHIBIT AA OQS - 278, 08/09/2019, 2628230, Page328 of 648 Page PAGE 1 CASE NO. 02075321 0 CASE NO. 02075321 DISPOSITION: ZULU DIVISION: ROAD PATROL CIVIL MATTER SIGNAL CODE: 66 CRIME CODE: NON CRIME CODE: CC CODE: 9566 06/02/02 SUNDAY ZONE: A81 GRID: 3C2l DEPUTY I.D.: 6933 NAME: WIKSE JOHN ASSIST: TIME 2148 A 2159 2249 OCCURRED BETWEEN DATE: 06/02/02 2148 HOURS AND DATE: 0000 HOURS EXCEPTION TYPE: INCIDENT LOCATION: 13475 24 CT APT. no.2 CITY: LOXAHATCHEE STATE: FL ZIP: 33470 NO. OFFENSES: 00 NO. OFFENDERS: 00 NO. VEHICLES STOLEN: 0 N0. PREMISES ENTERED: 0 LOCATION: NO. VICTIMS: 00 NO. ARRESTED: FORCED ENTRY: 0 NAME LIST: ROLE: OTHER PHILLIP RATCLIFFE OTHER VIRGINIA ROBERTS SEX: RACE: HT: 504 WT: 108 HR RESIDENTIAL ADDRESS: 155 SANTIAGO ST BUSINESS PHONE: 561 000-0000 :s ON JUNE 2, 2002 AT 2148 HOURS, I WAS DISPATCHED TO 13475 24TH COURT, NORTH, LOXAHATCHEE, FLORIDA IN REFERENCE TO A REPORT OF A CIVIL DISPUTE. UPON ARRIVAL, I MET WITH WHITE FEMALE, VIRGINIA L. ROBERTS, DATE OF BIRTH AND WHITE MALE, ANTHONY L. FIGUEROA, DATE OF BIRTH -, WHO WERE STANDING AT THE END OF THE DRIVEWAY ACCESS TO THE PROPERTY. THERE WAS A PILE OF PERSONAL EFFECTS (I.E. A LAMP, CLOTHING AND OTHER CERTIFIED ?r?E A TRUE COPY I SHERIFF 4/22/2016 OQS - W??r?alnt 278, 08/09/2019, 2628230, Page329 of 648 Page 2 of 2 PALM BEACH COUNTY OFFICE PAGE 2 CASE NO. 02075321 OFFENSE REPORT CASE NO. 02075321 DISPOSITION: ZULU MISCELLANEOUS ITEMS) NEXT TO THEM. VIRGINIA EXPLAINED THAT THEY HAD BEEN LIVING AT THE RESIDENCE FOR APPRO- FOUR MONTHS AND THAT HAD MADE AN AGREEMENT WITH THE LANDLORD To VACANT THE PROPERTY As OF 060102. SHE CONCLUDED BY STATING THEY HAD TRANS- PORTED ONE LOADED OF THEIR BELONGINGS AND HAD RETURNED FOR THE REMAINING ITEMS WHEN THEY FOUND THEM AT THE END OF THE DRIVEWAY IN DAMAGE CONDITION. ADDITIONALLI, HAD LEFT A MATTRESS THAT WAS NOW BURNING ON THE PROPERTI. I WENT OUT TO THE PROPERTY AND MADE CONTACT WITH THE LANDLORD, A WHITE MALE, PHILLIP E. RADCLIFFE, DATE OF PHILLIP STATED THAT PRIOR TO LEAVING, ANTHONY AND VIRGINIA MADE STATEMENTS SUCH AS CAN KEEP THE REST IOU THIS STATEMENT AS WELL As OTHERS WERE WITNESS BY WHITE FEMALE, LORRI M. DESPAQUA, DATE OF BIRTH -. PHILLIP STATED THAT THERE WAS A SUBSTANTIAL AMOUNT OF TIME SINCE THEIR DEPARTURE FRCM PHILLIP. HE FELT THAT THEY HAD DISCARDED THE ITEMS SO HE PLACED THEM OUT FOR TRASH PICKUP. HE ALSO STATED THAT THE MATTRESS WAS COVERED IN CAT URINE SO HE BURNED IT FOR SANITARY PURPOSES. ALL PARTIES WERE ADVISED THAT AN INFORMATION REPORT WILL BE COMPLETED IN REGARD TO THE INCIDENT AND EXPLANATION OF CIVIL REMEDIES WERE GIVEN. IT SHOULD NE NOTED THAT VIRGINIA PRIOR To LEAVING ADVISED ME THAT SHE WOULD PROVIDE ME WITH A LIST OF DAMAGE RUIN ITEMS AS SOON AS POSSIBLE. J. DICT: 060302/1418 HRS. CERTIFIED TO BE A TRUE COPY L. BRADSHAW, SHERIFF 3 4/22/2016 Case 18-2868, Document 278, 08/09/2019, 2628230, Page330 of 648 EXHIBIT BB Case 18-2868, Document 278, 08/09/2019, 2628230, Page331 of 648 I Anoran Make Auuan Palm- 0! neparturo 5 Arrival Mlle: Fll?u nan-nun, Proms, Number Alrcr-n 19% and Mark Flam No Maneuvers. Endmomonu ol From To \1 M09311 51m. 77? :31Te") pg; v.3, 78? \f?jvww 19 PSI "(613 ?z?mmWW? 1a 1 166 .6 133 Jae/savory Iiumw, 3 MM) 2" 3.98)? 794 Wu;- 3 e? Jig 3-4., ,?158as; 81m? . A 1?ma?a/4 - I TIM ,3 5 mi!? DR - 001?? 7., 7? 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'wn woes i I m, .2 166 9,313,024 rem? 13% 814 3616!? '1 3 - 1&8 I 87536le a 1 Kiwi": K7l (J2 ,2 I TM like: .va that ho slatgmenta made by ma an a term 8'0 l?ua. Page Total f. Amount Funk'mi 2:75,? (>102. l?lml?a Slg?nluw_ a? jab) '%is 4 In Date $95 (3qu 5f 1 (4 Case 18-2868, Document 278, 08/09/2019, 2628230, Page335 of 648 A 1 ,ooPr I Numm' Alrerall a class . . duro . qu Nrcm?Make Aman Poi"! Heep armtAnlval Mlle: Wulga 2 A - Illneu Ve?f? {Mp0 "flat.? ldur IUHIR In] ?.16 IV N3 (4p own/'9? $011316, N?Iogj? mw_ 232622 ?11m EM V5 ?13 A \iL??Ow?lv 1?me _2 1 _2 (131 - FFWW 1 1 22_ 22 2 2. 1939i: 3 222 1 1?7, 31L {-19% Te??22p2 3:22 2 171? 21' '1 11 ?16.9 ?383 2108. 1 -2 %x.1w~ww? 1 1 222131.11 cm?. :11? :2 ?r??ww 1' 8? Sar??DeQSHowtu?z, 7 1212211313 22 2.. 8 7T- ,1 . (.503 166 10 ?10 16.0 I - I. 2- N0 Mc?OLe-Grmf - _49?g?j56 :37: 37:: 25? \1 Tee; 861333.64? - . 111135 4 723' 0CD 8 2:122 as??f 11 W15 3 11 281,1 2 12 1 {?10110a anorwmd ?/g??an?hr 2 1 - Eei;;u1 ?Ilnl'u Sgrau'a 2 3 Case 18-2868, Document 278, 08/09/2019, 2628230, Page336 of 648 Dame Alrcm ft Ig?f mdl?mdel Ida tti?ca Mann rk .cProcdurIa. Manveeu Ime I 8% 1% I. CMH ?9le -Eee? ?(Inc GM 1&4 __Iro235 BT Il?fs ?103ij I ??730; mu; 19%. xI in?ll 118}: 3c", pmjmeeimqa I lC? .qo?ll 36', I .. FunowlN In ts omapanma Arrival ?IMeslI -I 15/ 4 I 'P?l [610614 3616M SMNM PPYL I 566 ?lqlo?fgLad-Gawa? LL94 4r) 4 0C9 TEE cum M?soLl?llsf/zfg?sam ??igj?Hb ,Gm, more?: wwoom: . 4 Ag?. I 3:6: I "e (9M, .3 CFC I Wex?t - I: P?f_ 24:569912'; (Z- m?2115204I417 with, 326a scam-ML,? a I ?My: Mun saI ?moms Sam @9an 0mm; form on I 05221106 P?g'g Say I (m A81 I 6261?? Vac (>105 _gun I I -743 E3 Case 18-2868, Document 278, 08/09/2019, 2628230, Page337 of 648 Points of Departure 8- Milo: I Bavaria. Procedures, Dale Mam Alma? ?mum", Endw'manu and Mom-l Idmd?callnn Mark Fluwr Na I Number Aircraft NOV From lo 15? Cm? CLMV, - fig? 16:3- ?m CW (if? wuss [536.) 4T- [?23 yea ?n1nu?wm?7 an" 0 mg, om? yam) ?La-mews 01"? Big 11+- 32:, r13? 17:, em \4 I 47? nuw 6950?:an 1 $3832 9mm? - -. . 11. woraz c.0100 {Jo/At.- I pgpyen. cezhumeg 3?6 cm, un?t, ummr Mwmow, u?nu 12: 3mm! mm;- wah' i 1 I 16,0 10:4] ny?pu? CM Wham C: Crag)?, m" r" 1 ovum ouwv bin.) 9 31-; I 3?1 3p) ?zoym. alluding: h?ml?? I, 51211.5. - 2 ?ll yo-u-pu-Duml?, 656..: U\/vv' T, I a - ,L?f?b?ft; wum?izg. . ((270 0074-31-55ng I (4:14:10 . law". I Nu. - 4 ?57557,:an I Page Iota! I (mount Fomar? You! In Data 3 Case 18-2868, Document 278, 08/09/2019, 2628230, Page338 of 648 Dally Almah Make unc M009: Nrcm?t Points 0! Departure 8. Arrival Males Film Remarks, Pmnoduns. mm. ?mm" m? . Idenll?cnnm Mark M3. Maneuvers, Endorsements - ?r I 011121er - ?lx 91119 (10.33;; Pr}: 1' "Inf 2, ,1 1L1 I T56 13% Begum! u. 11/ ?nu-Ll 171? 2?9] (301?; -. pun-?1 nmn?i?? A VI 3 I QUIr?IE-mwoubcv 1/1 - out?RM? Marta?0;: (MI cwwamyg 117:1 Mfr/33It, at. ~5ny Ma, 90:13; A u? MN 00;?va I ,Eitm?glhg {?91 . . 2. . 1?43 E?nuf- (Q7131 a N0 00356949515 51%? 4 ?a UM Hum- ?bgL?kfgu?JhEz/?R??uwm? 110,90, 4. ICC.) ff}, I: Jig, Anion ?marl A u. :56? - A NNFI . 1 - IL.- A 312:?, 1 pr); .1: I ?6 I m. whim, .:va A 6-6 Sup-1". Ln g. . ,4 (3T {50? - 2 .. 31553?; qu SayerMmePM: QSH MinaCg? Nr??Ig?jcx S'T?ue?l? . I I 08me that Ibo made by mo nn lu'm are 1.11? Pace Total 10Annunl Forward 536.3%? ?10% A Wat's Siamtue UL Tobi to Oak (akinf?JNd I 52262,? Case 18-2868, Document 278, 08/09/2019, 2628230, Page339 of 648 . Murat! Mm: Am: all Mono and Mad? E?S?c?x 7 MM From Points ol Deparluvo 8: Arrival Mites Fight No. Remarks. Procedures, Marrow-n. inanim- Nunbor LH'lurgs chra? m? LM - (In-3?10 15 l\ Nw?quwc psp__ 060 Tel-qt?fa, Mmeulxmx? \5 8 ?98 iQ/zpct-mmw (rut Qua/raw Ate, Cetqum 1" bl @1019 WL 2% aw f4 )Gm 50?- an? :76, GM, OLD Slat d1 inommec ft.- CJI i Cm w- (1&2 Dc. .3 6/ (87/00:? Mmm. . ITLI-B MA 5136/", -l - FZL Nm; +Ff- mm; Hg; DC [Darval (0 L01 ac; 23? immv. gr; (66 i? . ,tm, {it?mauoa', G-w type] 56:, Gucci? q/ 2 Lu 9. ?90; .1: GM, 1L T69 %q -BCO ICE?ecw 3e Cur. awmr bumf?uta?? ?gk??gss?? m! u; 51,09 . mm;? ,3?bim?xn.?, I 1 l/l A4 l/n 3c; .SG, 506,99?? 04 CH L+3e) WI cem?fy hell the ?alumina mudu by on form are true. Page 1'4qu ?1ch Forwsvu Total to am swung), am I . save-1 5? rm?hr~mswn& No (98 15 marl! Case 18-2868, Document 278, 08/09/2019, 2628230, Page340 of 648 Number I Alta-n Mules Remark, Honduras, I Maku N'Cnl? Points 0! Dopartun Arrival 01 . 2 i 1561:} and Mncol Mam Flown. ho. Mmoum, Endorsam-nu . SC, 31 M97 l'lb Hiram C?nsjl?i N0108y?; - A LLff? (-jlj: - (Hi?Te, GM (a ?4 A- T636 L175 69" CL (?1:39 2 I 12-? 380 1/1 23813858?? MOLE ?22 - -7 ?xg. 56? new Cm ?asw??gaia??i? J: - . try-Jud - [Kn (4m 22 new 8833a?ws?fod To 2 . "J'Ecz: [m WMch-mm 7A Jen PBI qes u?umhg-Ip?: CNN TMQJ) 48L ?14 93 . - PE) 0?81 5g, gm, pmrefz Iii-V151 - Tie?rs MV \f 3'5) . 2421112.. i ?23" -2 cm Te (5 (4611': 521 Tea 9:3 1? I $143 Mom Em stalemerls armrue. Fum??oml Iii? Li Amnunl meam . E) Qg?zt Tot-Ho Dale Slomiure K) 1" 3R 2 91.31739] 1? . all? Case 18-2868, Document 278, 08/09/2019, 2628230, Page341 of 648 191', . JUL Ararat! Man. and Mu'lnl AI royal! Vdunt?mlv In Malk . I Palm: 0! Departure .- An?lval T. 1 Han Mibs Fright No Remarks. Maceduns, Munnwon, Eudora-Inca" Lansing: Mmbor I Amt {11m \o N?wil??j 6?61: Tera ?i?N em, mum L/x, .CMH 2.1- 'E??f339 qq 010L641 be'i . :36, mum pm at. ?Oec. \ll SLnumwxg I SK?t?r? V30, '5va Lime-rum?. rumwgc?cm g3 was VI \1 D?nznd 2332mm ?ja Nam-x) ?mm-v.06 H?fmbv Mus qugaww wuo??m?. 1: 2441\6 \vL qugirm Zore- sat: . Tan: *mem'Nqbisze? RBI J96 \ol3 (2, GM 3e, Ham gen, Maw? my} 2,0 "[93 36;, cnmerz Mia/Ur) TE 6 32;, cemwn?mw' e09, cumEma/(10M, phy?e: tr": man. uan 25' FOK cemab ?0 (10155 to i/vwv .4 1 min saleawo MVJC FM 1' MVY Pr}: 1011: Myoct?mf loamy hat 1hr: summons made by me on U13 loan are his WQ )m?k WW Page Tola? 3?1 Anwuw Fume-HI Total to Date ?10022 \n 001 Case 18-2868, Document 278, 08/09/2019, 2628230, Page342 of 648 Dale Make Alva" I Points 0! Donahue 3. Arrival Miles Fright Remarks. Procedures. Number Alfall? 1&7 and Mode! ld?nlmcalion Mart FW No. Endo'uments OI 66? .Fm. To 1.9mm 5a \022 1914 "reg Lobe V, i 24* ?x 6 LGMN m9 ?mc?m? 1:11:38? LFMN EGGW 216:1 I GE): '\ul?1 3-6er 1 P?f ., T66 ?30 Igor? T66 m9 ?231,38! H/l - am (am @2138 CONFIDI mar 39? 3 ,8 9? 33$? 3 . . V?l? ms 375/ 1 . - 8063 SHV . g0?85!? 'Lvn- 2m ?5 ?4 7; 5L 646%: 1086836 PEST. 33L Wi?e?r?p?bgmw 9. 4) ?1 I 301 JTIAL E) 291122 NI (N rl?T-A?n $153319certify that me slalmnwufs nude by me on (Na 10m aw hue. Pam Tolal . 50 Amounl Forward %1 003 Pulct?s Signame QGUM To?. '0 Iii?? 1? 74 I t, Case 18-2868, Document 278, 08/09/2019, 2628230, Page343 of 648 Alraa? Make Aircraft Palm: 0! Departure 8. Arrival Miles Fligm lam-rim, Procodureg Numbor Alrcn? . an 19 and Nudui A Flawn No. Maneuvers, madame-ont- ovum-my me To m: WW9- A I . L0 (Z. \flJ Gtusqa T68 \m 5% (?158 509? :1 .477lee, (56.5.an I 39: 5 1+ \1 36? \ms 55"; GM. CT, I Gamma . ?8 "?5'r- ?a owl 6? 8. I .1). <51 - 33X F?viesT?E A 1 i 3M FBI ??973 Q?Lvu mm L?R?YV1sosxs_ (3038 ?was sex? More \cs?f? 5* 3 xx (>641: T66 . \osz 2: 2.2., 4881? . 2 (>61 8 Tee? 6" 8T ,1 pg; \054/?23 (cu 008pcomfy that ma statements made hv ma an this {am nrotnza. Page Total ?39, L1 Alncull Forward I 7 05(1? sch; PINS Signal-ma Tau! to Data 1? 19 as i Case 18-2868, Document 278, 08/09/2019, 2628230, Page344 of 648 %1 pg; Nm?m Nmrn? Idanl?kzailm Mark Points 0! 0mm": A Anival From Flluhl No. . nu\ mam: 1! Numhu Allol?? Qmpwe GHSOIB 96106:1 a5?! and CL ?l F?em'EL??mow ma] ?1 Mar sum?, 827:. I was com ampubaurp Mi Ta?t Lem Sam PEI 6M anew avenuc wwmeyummaw ?91 8 \l ?(65 3?3. PM Nb 32?1 cm, 61?, bous? scwoer?mt \dal newer, bow scwnem Tear E6: .0153 Tep?, I ?10 Pm??hm' WW '15 :mn4mum- w; ?2,163 5% _Lvm, swam ?25 TNCM T126 Bo 1756? Nd Nm8de-3N \k 36% 1068 3?16, 63001?6 17:6 W: \cm. $2.?ng l/ ?1 Mr pm ?laml'ar?ctm ?573 Mamet; w?ma? $5515? E. VL 17:6 pm GM 5364. vmw. ms 5 loamymumomlamnls madebymaonl?nommlmo. 101V WW t/ Page man '38 Arnmm Fommd . In Dal. Case 18-2868, Document 278, 08/09/2019, 2628230, Page345 of 648 _i 103%?: pea Alral? Make and Modd Nm? ldoM?m?on Mam Point- 00 Dummy. 1. Arrival mm Pram Gums 5155336 Tee Peal? I cm; 6M 55' GLAW 0mm. 0' um NWO Wham yl at, cm, Doua- ?smoer?ym I ~l new aha/mg l/ S?,em,er \n Magma-.4 GM (2356349419 5\i: Vl \an SC Tana?~90: old. 5'01 Sf 367? 105835: 69F 36:, \l 3B1 Mo 36-, came \pg; 101?! J?enTa-Pilaf: Signature 34M +Mabc2-Mm Wm mm 49r? I NddAg Amoum Forward Case 18-2868, Document 278, 08/09/2019, 2628230, Page346 :umom About: (ab gm 3:39qu 1 m. um - 86mm, ?Duo '1 CV12. 3/3 '1 @546 Nqoase 38?1335; mm: 2.3 MRY ?1?1 112?. . lose . . . 2t] . .T?s ?ack 22r?44? 2? -Jff??f 19, 1? 1751 par ??33 ?04.61", Ga, GIN-Y Keri/var ?11??97 {961 we 833%? - AVO 9E5): ib?m?iy P61 I ?ww (PM 10 60.586 N40953: i981 \aeu MI madebymeon ?siormarouue. manual '5 I Amount Fomutd 1? 1 3q- 3 am To!? (0 DI. 0m Aircraft Mcko Aim! Point. at ?op-tun Arrival 193? rd Mode! uenuscanm Mark 1 5" so og-mx?uommoNr? P?Omoo - Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9347 of 648 Main Main: and mad Nam" ldan??callon ?art 0' Dev-mu 1. Arrival From Tu Flick: ?own No. Allen? 61 T66 N?W?ff? T66 SBF VA ?6.th n?d?m may Mai/r 21. see {?61 Oouc. <ch~ry??I okra] C111 LNA . LNBA n?ce'zsmn m. I Lmuz CON FIDENTIAL 3 m?omo) Rammwn ?md??-ew 61' ??W'Nzc'oh n9? 5mm: Mo Cam-m. 1? A?oam. 96$ Mud-Mm Com per/MW Bu; 1. gamut?; ?7450; - rm \3 _*ms 1988 ?392. 9. (thaws ?@31an W5) Ir VI vm1 Win mm, M?Lth'lg?mu?q RH. :12 (Ina. Ina-um), 1 may \i?Z 3L, 1 Fawn-ts W13 cum soc?; '6?o WM 283/ \l 136 - (5 . Xi?ac/Qacmtr?fa??l?a . I MWg?mw?m -- -- N15 KR Luw?w GllS?l? RM 1m; can? . CH gfme?m??gm?n@mww - Coma. YNN M1 WE) WI WW PagaTbInl AmmFomuu To!" In Dab pigg?nm" 7-. Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9348 of 648 l? ii 1" . a4. 6?qu [06104332. 09-; Tee Altman Make Airman Poms ol Munro A Ardval and Modd lm??u?on Man Da 132. I 39 2 Fun To bums Melisa PM (.82) Mtoe?m \1 CHM $34 'rrx lief-fl Gum- KRm?r?f Rama?s M: swam-5m?) (5m? ?comes . Wows-s, web LHL \8 CR6 - ?ame meme 961,. i5 Leu?-Zv, Wj??flcp'm a" '5 'n L-UK So, 29 Lox T65 22:, amt-cm MAM) mm ?l?l I 45.) Ul?l? W171 25 cm msr?a (MP6: was? No'm Amman. dynawg I i :r LAM FT Reszt??Ib?g qu 29 gm. 67 ?(66 am ET (5le 0'83)? Jaw?: I I W2. m?Jth?m 4m?: magma? - ?In we? "mewwmw 3 @596 N90832: 98: T66 .1 Wc? BED B69 Tera TE.) 8065:?, are mu Plot's Stamina-e A PagoTotal '17. Amoum Farwwd row I. out. "Has?F. '1 (1"lV-s Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9349 of 648 v5? ans, Manna AIM-all Mn. laden-mau- all To . A '1 98): J- - :5 W31 Hm?u. T131 \n 0 3e, LE \m Says/MW \1 $112. 54': \8 w: me?me jg. (gm??t?rsgj (- Inummj 20 On Nm? Maka Alrcm? Point: 0! In Arrival 19? and Model Walton NFIDENTIAL m. n. - Tea 1151' 388093;?? 8 12:9) A m9. 32,6mfvoww ?and, ?hmtau- .. 3H nap $341313 1/ ?5 1. JFK P61 mewzm ammw m) 613 n2:L B?u?fl?az?mwa ?33521.? 7-3 T66 (3&0 1le 5" 3 Rozjg?su 23 860 T513 ?3319/ Rom?b? ?4 21,, T616 (>81 46,9?, ram? Luna. 1.23%? 1/ '"ImeL 86$ Tom 639062 mi) T0 1N5 urz Md be shamans mdabymoonl?afovm arem WTdal L13 a Wm 1M Manchu-n (?le I A Total [a I I I orahrwz4??omav?.b ?w 01? de-df?T?HclU?3NN "d <1 F?w mm -- "t Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9350 of 648 03?! Make Nmm! unaMoru Imnrmunn mu: an Pohls cl Doom-lun- Arvin! About! Nmubat a. 0? Lamas [km 5 sugars meme PM 5 lo ?6 ?,swm [Swat-0,0. aspen) H3563 3W SD ?At . <4 39:22? ?2 N11?bme guuh?mnu time - Meewnw cub-?vast, 1/ amt?mu 'mm. nurvmua ?1ka 73- ?5 am?: we ?Mmm um: . mm?dawmgi?smc .meMi; 6) 3/3 ?3 \1 I ?mlww Lav-Imam?, ?Mni??GM's 9?12. MMD, Sfaw W5, M40 rm 5W yumm? Mb?? c~zm:w1mm nemnrmi' 3 iv ?h *r nuo crow aF'xm?pa QQELW Mg? - 1m, samg.mp?1nmleuw Comm;- 1' \1 NHS SL3 IVY vcr? Mama. (5119.6 {mu rat-WK! EQM m. (WM. as ,6 aw CW: ?843% '8 {Jr?(poo a? - N-neme 3w vatwum I 5 5/5. camsw 4r mum?lpumws yam?. 81513.}qung Damn-?Mo - 3w Clm?m Folk-Wt Madlgirluomm p69 W: 1M5 Va: 456;- 28 IRW Lavawas.? new .5?;ka - Gstuac/stm- exam (:15 man 50 CYS Own-buoy. 667 Mm? man we aanJo, WV 00%? . I canny ma! Iho ?anthem made by me on IN: form an true. .. 42an ?M"wa Page ms ?3/43 Amounl Forward 4 1'qu In one 3 A - . Case 18-2868, Document 278, 08/09/2019, 2628230, PageBSl of 648 Du Amt! um Nruni "19' and Modal Hub! Palm of Denomi- I Arrival Mlot Fiahl OdomEudora-mm.- me Tn ?mm (Trim Gum ELI {n ?551. Pm?, GMN@meuanm s'maucs CDQU No ?gu 1\ Gem Tee\ H39 3'6; ONFIDENTIAL 5 EST mo 51 66-0 Sc:? 5 IVNY f" e, 166w We V1-00m 065m . im?~ cm CNN T??j mu T6 \ttusd??TGPY,E "\?MCCibon was:e,em,e< I Ohm.? acme-ma \jl ?l PST. (Viz?ream mm (J (?4?77 2m Sod} as& TC, ZL'smtpe SPEH L4H we - Wha?mb?vtu? oc?o VNV 3"3155116: 0w, Gmumqw 23? 15 60915 M10532 NY. 98 1: \62. Se 93:1. 11:6 . MS. 3?3! GM 989on 3 pm??m I), tau In on. Amoum anrd FE \h ?2 .I: Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9352 of 648 1' Gt, (sum n, ?rm Mm! ldonlilhnuon Points 0' Departure 5 Arrival To 3 9m: me Tm T3331 1. I sec: mun?:37! a-c. a?lrru'?'56W, Cwawocuw 69x; 3' (4M1 CUCLECW L?f (?o?t?fca(5E Wayofg?, (x 0mm mew AmnFOI-nm Tibial to M. FIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9353 of 648 MIXER Malta Airman POIMI 00 l- Anhml M1591 Flbh! Nunbov Mnn? :9 and Mom! Mammalian Mam Flam No. II Endcsomonu 01 um - ekbk GLIM 0? From To 5, o-usqg Nqotbsg {5&9 moans; 9w: V: L9 1! 65.0 T63 ?mom-mm Nuasnm 0? Te?) 0L0 3a, (4.1., BDBM Mavwwa . EL OLA um ?311, 06? L1. PM \noT?/bmerm l/ .3 Li 1236.? l/ I m3 Vt (.360 T60 WW :sco, Deesvowmm i . .13. 17:3 .(Jgf . (5ch g/tm. .- - i \l N0 P?sbu?cx:ree m: 39 (79$ ?59 ?[213 T157 15' 3 (98$ ?95, 3e,c,m,cmm& Mien, e1, mama Ila P31 Us! 3949"? I L. \b CMW 1&4} mu Ecume99?; ween: Panama! V), I ONFIDENTIAL JV?iI?ocOw ~9oav Nd??ric?o?h] [.51 ?fn$ 3.1 Amount Fomard 1 325.5 Total to on. #254113,- ?Ill Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9354 of 648 =rum To 2L7 @11qu Naomi: 1151 PM . 201 -1681? .. was Emu? T66 6?61 A Mama 5 (I: 991?. lT?z? $008811: (amine 45 ?g :5 u" 0&51 stmem'm? 3 sac-w - We] 08.) 9/ 001? I Mo Resubma-sr? Amp-Wt 19.3mm ONFIDENTIAL 11.5) a; 51 M1 ?58me i PM We 84% m8?? 2,9230" Ci. . .H - .0 7?ng ?at; St}. L0 59?1_ r, 90w I (Mum \5 WW my 54;, may 0012 115*; 59,41? GT :a 1751? T03 WM 55) Tub he); 1m gammy "3.64.30, own, bU?Oic" 9m ?8'?ff."ftwm 1 I I 9? m1 2, 10?: 2 1 ?a I PaggToul ?47:6 1,0 i - "135g?; 13(41 b5 3 7) Paar; Signature aw?) M. . 717/ Tut-norm. qo? 2W3 Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9355 of 648 Aim-ax Make Ind Model Points 01 Don-nun 5 Arrival AW Won Mam Fun To Mar Aha-n 0! Landing: (?Team (3!;ng can?. n. [Manon-"Is 20985 661 u? ,9 \l (7?0?5?16 WSQ 1:167 20683 Wm w?l? em yummy .5 . knit-1.4.4.. I: Adm-1m maneuver; QJ NFIDENTIAL [966? l ?wig! Gig-E/J/Mfcv, 16 WA-sr {cg?me \a NEW 9651. EV MED . N?vmbm' wgutr?am 1 ?T?giawce ?mom? It 96]. NW4 mc??3 52? WW MIL-L ct- 11 PM 100.09. u'k'naH vm? Pm: WY C: V6.52: 1 599 mg TQGM, (,0ch \l 39?, wax" He 6?23 (215 Unmet an - 11 641qu LOI \l 2'19; I Wm (Xx-rm Mam-Hrs. manna I Mu'r Alarm emu-{s MREE rzc?l 3?"3 two 3.11: um Maw T63 17A 0 Tag, PEI . acmmur. l/ 3 2. LLlo L?i 50?37? W, Reviewed Hora SwamiArmum Pom-n! 9% ?6 mu u. om 1%nu) St L. I Page Total 3P Case 18-2868, Document 278, 08/09/2019, 2628230, Page356 of 648 . To slugs?? .21 cm 1% L3 ms?oom MP -. /Domv~ ?mm? ?2mm; PMP L?s, Fu-?v 23?11]? 16?:be N70 PW ?Lm? 6 719.0220? (I 7~5Lym L761. @2226 3 new PM pn'p_ 13' 9.3/52 4?1? {543? 7175 LJ {021,4 1m. - [k 4 ?l ?re-Mo my) 5.001.774 :14 y_ f?/r?ja/o fie/y 5? 3 5003.4 -f F/A/dl/ prun7/Wo? a 25/7 (Sr-?5?16 66 if: ?M?tff' Maw? Lw?q 9 JV ll.? 6RD 16! Nsmev Gm om. g?z?gzgigr??g? mg: if 5'00 39 mm meats: WW- 1: Ex 9;an WW 6 N05 7W: Mama)?? - Dab Alma! um Auaan mm 19% and Model um mm Mn'n'?'m Four 82' an ?wa?r? 3?3? S. ISM ~clz?rr3? W): m, msgeu URL 831849 06v) JW 2 mm (5 ova 1161' T?fb ?mid? @115:an 3m ?JdoL?b Socma 50m, musgecpowg KT 90cm} (500 - 7; PageTbtal_l_ 7 29, J3 %qu23 10 Tom to on. CH '3 mcdoa whom ?a b\ (J?s (?if 4o! cr ?Hot?s Sly-nature Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9357 of 648 Altman Make and Made! Award! *1th Mn Felon ol DOW l. Mlval me FR) {Ebb} $0035 PM ?Nom Mar? Numba 0! Category? (sutoen- Mom . lat-LS 50030 132343010 a: V) 'c [Zeus cwv'ril?r 51.05 KB 5?00:wa firN$>tjwi (A511 55 N?mg?: Tea MBA Sui." amass Locum? .26 5? LEW: mum) gummy/m," 9. 41.119 NFIDENTIAL .- (3M0 4' jump (41.13:. 1050 53?! M1- 9 ans- v.17- ?Orl- X162. (3mm Nclo?sic? 1961:!- 1' 11M: feign" Bf; a. (cw-nus \ll ?utguxai Dmu Luv 115 Ti? PM Mae 9 N7 ?tr?wan? Knn?lw C?mea l/?j?l \243in. zinc? two 1:13) T??l Lamayj?gi {in?ame}; mule\win?mpm A351: 53?. .ML-Mkoz?w?ptvm . I '4 95m TOE L/l ?3ng Lol?k i I in? . C?w *1be "Ms I WK 94:91.3 WNW lat/L Foe PW wegr 1 214591..) N355 JL (KEY r-z: jack-Lb .5 mm sf) .30) Gir?b TCB {381 he @37an 4/110 - 1.1- '0le '77 Ll?drA/ch" rue. Pl'lol?s Slanaluro . ml Mid/w?- Page 10ml Amman Forward 4 3,1 8?6 143?) Wm- co. to Dal. - 93-- su??c .2 Case 18-2868, Document 278, 08/0 - 9/2019, 2628230, Pag6358 Of 648 Alma? Nhko Mum Pom.? Don-man I. ma andMod-l *4 -I- .. To From @1513 Netos?ra PM ??98 Gm? Pil? h? .9?913332. I m: v11. PP CtmuumrMomzn, '3 . I 9.5-1 web" 692?? ?mc?b Nqo?sxc Tee rm I), A: '1 1 may Dee-s wamz. [Moe I I I c; .NFIDENTIAL $0 9. a? 1L2. 1L. 20 \4 (?81 {m ?Ame m1 5333' [12:6 36,0 C6 2 TCST ?mgr/?ts? ?Int-C) a? . Scrum; hmou. . Hm I . cannwacm? 9,091.4 50mm P011 Jr?, n57.?- 'FBE PPL pin-,0 Pn9-Lm PVWI Rc?ro?l?h/J?flnfearch H, 11mm, MchJ, Wipe?! 5-7m; r7 1 Pm 3: 1' PGE- um W20 H?v/ (my) -6r\cmm - . \mg?nnimn?c??m ?Em? [o @1910 N10933: Pm:_ 6&0 Tar-3 mu Gamma 1Q aim-77 $0033 I PW sap-far] formantmo. Pam swung) W14, 0 Pmotni :1 2t; Amount Forward 5 ?3 A83 - row to but. I a? crow *1 .g .- - -- Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9359 of 648 lingo Almn Make 19? and Mode! Mm Alum" 3 Flown No. Menu 0! Landnga Fm A (ll-L Altman Points 0! bop-nun 57.5 Meaga- M. An '1 8 6 =3f-r (WM 635?, ?1 .. 1.136% Max:339 9333?? NA Tc NFIDENTIAL swan-em av Mu M. mam-4e. swim-e ml 1.1ch 12ft? 1? Pm?? 0.. Wm Slowlum 1 a? (9.531- 0.31m Iver PB 1. '4 - {[66 IQIQM, GT, VI. RePoMgo Tc? 1990.? c0 . A: zvh. (44., um! mam? m? {Te/Gr"! II TLST 9? em: 5m? ?m IGIGWGT we (733; ?V?Fme 620%2?9 PM T535 m6 (?47 6?27?? 1/1 i ?59 995L \le 5? MW, (219%. ?{Wm I57 (5 ?1 lg?, mag,? Gil?mtgl VL ppOOt?lamrna? 40 Mg. Tom ?1 Amount Form 'l 3% Thu-l a- 6.1 ?1/1 {41 Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9360 of 648 . Duo Arman mu AW Hmd?opMIAv?wl Mics nm A In. - Number Tlunar-M:- .. . 19:17 andMuod naenmmumm kan No - mom- ?mam um Pm To - 9mm arm-xx lwma 14? 72mm 1823 Br?we- PM w? (J14 (mm mom Td?? Per 4, 2 . 16M, er 9. 21 (?81 Tee Sc, 6115 V1 2. 23? {390 31, an .. (560 TV :2 ?1?4 Tea semi 0mm mgmmi 9'n-sr - ~98 \15 33?4?? 1?;wa ?l ?3 ??tfzs?t'l? Pmpm??iurLummb SOLO Niko 2.0 NIISMF Hw Hwa P??zzw?ergazm?gzcm 2h, ?1 Le. on to Mist 0w. 3/3 ?1 15 eusqb mow: T66 PEI us; 17/ 9338/0016" ?75 50?? ?-59 .. MW cm? was '36, weld?e?! OPAL 59,9 \194 32-1 9 \a ew?v - 1' PagoTolnl y-gqIFomam 1547. - - 0M .4. jinn..-? ?5 3:??wa CM 0.4 Aldo! a . war-eon- Case 18-2868, Document 278, 08/09/2019, 2628230, PageBSl of 648 43y Moran Make and Mom! Mun}! Idan?cauon Mm Points 0! bop-lulu MVII T0 EE Fig?! Nunbm M. In?ation? Landnga Aim-n MOM.. {mom Guam W?Hrm 6mm :3 Grimm: g. mm. SW- '1l 9 N?st TY: b?Lk??f ?m Miduh?m?IMNM - - mm unacJ-tMJ-W 5 30? G-wma Ho. ILUMML. Mama?; ?1 MMnyuQ .muruv-? SCh'uu'. 6:?me Uum?ly. we .vd- mm $2857.2me W5 312,57, ??fm fuel!? rm:? \26? j/ (FM .67: :LL?tiLr ?1 i 09' 332-5" 9?31?? 0 44 ?2.0037 l' 11,403!? 51334" kl-??h ?3 .114? om \s?m m. 31.5, m. . 2:5 (sum?) mu 21% ll ?mat. m9: 'selmoM, W?th?v'f; {Mud} h?b uk it ?21 SEEN ,r?fj l( ?23; 3224-3", Mm; 1 La?. 129 I . I. ?Cm! p?fn?? I I lkmw?te?MMf?m-im? loen?y 11ml Ibo statements nude by me on thin town in lml. Page Total Amount Fawn '5 118 total to Dole Plot's Signature ?Aug I . c" :r CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page362 of 648 0% Alma" Value Number All-cull ('3le We: 3 i a "v Arman rom- mm c. Mia: Flluhl ham m, Ioumncaum Mam ?own Na onl- Fram To name 599 ram.) Hem-?7 59;, Tag ?ML/9mm T65 [1 ?my. CWL 1'66 at?, Mme 169 V?sf 55, 914298879: {?61 trot $326353 6 @2922 my 122,2?! @553 mm 9' a kn?? 19/ 983: ?3 (7-1646 ?38%, lo G-lm? qut \k A NFIDENTIAL 000032 1&6 um 37: WW 3): 27> (59 01'" 97? CPI RCNC-WQL .vEE?Wu-wa er-mm :rJ?r-mJ .. ?(01?44 69? 2?13 f'X? 59mm CE: Renew-M. '75 (316% N?iO?da'E PM I?d-jam, S?eu?v Im?c?m 19 TEST T66 p39. ?aw. M. anew? nomw car 't 17:6 61 Tm PB: 96?; V). 3% mm 75' 1&6 mqse, same Nerf?M Tea BE-J GM. Fag. Total Amounl '7on 181% to Dal. em. 166? "l Case 18-2868, Document 278, 08/09/2019, 2628230, Page363 of 648 0 5 was 0LT Am" Make and Mode! Al'cmll ?uni?cation Mari Points 0! napalm 0. Arrival Milan From To _.Flown nun No. [350 PBS Us \4 P31: 4.. lumber Allen? ludlngo RP, Mlle? Mm 6W cm, am.? am er l/x T131 T63 (Hangman-1, Manon Law 1 vi 7A \0 961' nas- 1'$6.6m ET, A 96: w?q/ u. 37:, 610,61} meme mun?141(th Lewis V1 5 860 Tasmwr act-gas 3L ?4 PB: T39 Se; ET 1223 SAP 912w: ALL $3421 ?36? SE. 13 SAN \36 5'6: 50? TEB 3'6, ?memo mam, Mm?" ?L?s HM: I301 3'111? 96 I 3301 34' . MANY album? 7.7. ll 96f TIST me 36,'Cm,ef, Anew emu m. MMQMEJ {PM/ma. Page Total "3/1 Amour! Forward wJof Ii Hal-I On "I'l Case 18-2868, Document 278, 08/09/2019, 2628230, Page364 V?a- ?l?t a: 0? .. 33-. . . $3051.? mm if?" N10836: T?sf PM: ,c?r 1?61: 1563 Wad? Tee 5M 1. GM?mgcmeuw-ma am 59? vm . um stats-mar 3-5 17:? an W- cum . I: 16:6 mpsi-?n?negevalwmwim 163 an 3'61 Sovmz: mom, 96F 08?! ma V: 3 Or 1116 9mm? - 73mg Mamba ?Hooch .. - 1 Endorsement. Landing ?aw r4:- 240484 . "t a- Jx?f?r Tea 1151* ms 16; {50, 53mm, 3 . 11.53? 82936189130ka saw?v Um; N11 90 9m 9 Pm? swmw, 20L L3 gangW145 0336 $Modify thallhomtemonb madebymoonthlakxm mm. PloeTotd {Kl/?Momma 9?1 mm Germ-,1. 3 3 1? i .E plox'a signaluva . dm?Td?dda?dm 4. :t on min 3 Toll-Mn nu.- "Jar. '3 "?10 Case 18-2868, Document 278, 08/09/2019, 2628230, Page365 31?..219: mm? Fm *0 Wham?- MomTe? 67$? - . . WW. mgz?mev?Lu '5 .. gage, ,mwro 4- Ma 2261,} 72.51 ?ap-NH?) PM ghgg??z?igl? "?f?pm 2:63 me? Mu; Nun; mi) lea?3 M7 NW - WM ?C?m ?23? 160.} Mum ?if? IE we 724014 101230 FL-L, 100.3 mi?? Pu. pmo \3 wow (?745 k; mew (57% :6 zaug hm PM mp ace/y I [11.126113 inf/7? in?vLcl-IOMF ,up as I 1.3- 10903 1190' row r: . A9M9 V??/L?Ifr?yfyqumm as ?35 Wit 'pmm.? Jr (a 0 Lb Qd?r ?mm? 351$ 11.s?+ 33 I did Tot-noon. 1150 3 3 ?15 Man?! Mona Point. of nap-nun I Anon! anc Mada! Idamlfuatlon Mam '07 .. - Case 18-2868, Document 278, 08/09/2019, 2628230, Page366 of 648 Data Aircraft Make Aim" PolahotbepanmlAMv-l 38299 WModol ldantl?uulonmn From To .?mt 6:1,th 23 9.061.} Mu?? m9 3 ?0 mix/LL12: Lyman. 1H wl?zg ,f f'sz?nry??j?f ZOQL ?3 w/sz/ 1. 7 X7 :A?Z-E??Lm-Vifvml 1; law?3 N119 p, $143 5? :3 034 12/" :m 1? vK ,4 . 353: 1\ \l RV -0 [?7f 1: 31?; It. ?9ng . 2 Map/He n.2, 19,5, 1% a- 7?2- cr?Lm?w muzzle wF?/n? 6 8 ., 1} 5323/7 ln/orji?frirug? 7 "0 PM f?M/o 1200; - L3: 0 ?m mm?zqu mi ??owery; - Lu C, qugy?: j; News's are ll . U37 0. wt: Mama. ?4 i? P9 Ti? 5551 ?16% chy?kiTrc, up ??51k Lung quv ID lcetmymumstmomenu Mela bymoonninlonn arolnn huge Tom! ?{rJd'T? FWJ a . Amou?anard . I, . I IN ?.o?uf I runs). .. Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9367 of 648 Dale Nm? Make Aumn pom. a a nun: Mloa Hm 7 . andModal . 5' I . 1 {3.3mm x-a'i-i AM From To Ct ?04! 6 "3-5-6 m? Hum-mu (?36 I WM: 166 ?9ng T53 ?:57 4:345 L?wm 1/ 3? 13?? ire, 5 Lawn 31> \c ow ?ng Rc?zomfpr? 3? 3?1? [344 115??: U. \t (3:445 je?m?es?, Ct T628 50? metreSP0 L115 um 31? - 1mm Number Alva-? Tr?0rr? .. l\ I A ?t LBS 990? 1359 1'1 Ph)? V9: ?35] at" we 9m: ??66 his?- JG 15? T655 .53 f?rr?ma 25 TEST 1315 3554?? ?934%; 25- Ll Pg; ?35; lmo. leTdi 2? Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9368 of 648 Alma Max- Alma Points 0! an An! on ?lm and Mode! Iaanmcunn Mam nap II. No. Fun: To e-nsqe mom: ear 1:57 osmo?) VD 1351 e31. 6?8; T63 A ?mm?wwm .. 4 129 Babe/?it LIE-O 3"Allen? ?(:4ch fa i GMMX I 1: GNP $036 ma 3610'? ('66 [Ea-6w my ?yam EGGW 66% ms Tel GM ?608 GK {365 Salem 66R T615 1 I367 17:10? ?3 was $95 MAW Laws Vt 61 T60 ?$315 A: Tag 5 \310 PW, 50mm, y?wfao? 04 31;,vame 39K a 3W 4?st i :rcz'sw [aw wanpp?rmm?w 3% Mickie 98]: 59? Vac/?Ham? 1/ 3 Page?lbul I 1 63? - 211% - ~r?3?dNT? Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9369 of 648 on Aman Alma Point- non-Nunim Aim-n 1&0 "?u-119' ldonl?cauon Mark New No. mot-lo 0".an AUG Fun: To G?st sac 5 \wv T626 3 Tc? 5&1? 661 T59 A \g TCB \333 16,5?1?1139 l0 ?9 B: Kama 1 L2- (16 ?5po 1/ ?24 T613 f? m: Flame new?; 25 sag 743?? - 5 1:51 5336] T5) 96?3?? '30 TEST Penn. 1 05-: pp; Tag I45, Gmcw, 1/1 5 It QB: \?LJ?-Vsb?u?YL?wg? I. (get .1c? ?3413 372? Car/?5) l/ T68 L09 BCHTEF, ?32:85:52?! P9235 ?3 Leg LCPB \3 3e. Howwe \5 #90 ?9 8 me 1'6, 5 heme? Laws .. gems 66K 9993?? 3 I WFmard t, a? 7375 Plot?: mm. 'I?ol-l (0 but. 633 (cots 7?135? Gums/L H?rb?w?lj w. -u-v CONFIDENTIAL -rmddol e4 \n?qv'?j?r?r?l 7?1-36 I tn mm ?1 3 Case 18-2868, Document 278, 08/09/2019, 2628230, Page370 of 648 . . '71(1.. - -. .. .5- -. 2y: .jf?wy, qr 1' 111d: :3 -. ?foxy-312.34 9-.- . . Number - ?aming: Dab nm-umma.mm We: -- .19: md Mada! ldonllaa?on Mad: I Flow No I ?g 1m?: me Tn 1' .1. . mun?Me own New. 6?Il5q6 Nq 083-6 (3 GR a! LQY ?96: me i - GMT: gm 2x mm TIST A 7.3 1161 m2 3810?? V1 '25? ?qu N03 6'1? 11 EGGW 14M mes 2?1 ?t PM was 3816?", 9'7 11-; i PM ?5 Iqb?tl?m?" 3? 12:9 P81: um 37:, sacrum LL-WIS P813 1751 ?Wje?aewrl '1 T157 17-9 PM 1,59%? l/ ?(as 98: we 3% ET \2 Poi): cm? muff-?5; VI (mar Par 4'3 VNY SHIV ms ?77 l/ .. San) PB: mu. 66:0 mldobymoonthluomam true. pm NTUOUMFDNIYO 631? (ooLT 7?135 @4412! (33141- ?no .4: 7.. .rv . . Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9371 of 648 umnm mdMuou loll-ho! mum I ml From TO Flown No Winn Hm 19313:; . "r (7435018 (BC-D Tee Nmnbet Landings a 3 LEWIS (?1.me 1k.- - 0GP) 1 WW a9, shame? Laws H. 0&8 PS): I?m 37:13", Lawn 86; 1763? 3318 ?s21 36mm um 2:616!? it 861 cm, re: team leccu?erfk b4 on ABQ ms?e?xfnm1 168 Muse! 5" Th6 LFPB Mus-elm?) EV, LFeb E6 cw 141% Ian, 614,95, Kid?L7 59mm ?e?w mm KaLur 5191mm mm Mum; ??611: EGYM 66-5 HS: I ?65? CYQ Nb! Wm?wW mo) . cg??c?L?fimgmy? M3 r? Pr-c? CYQX 98): N31- 217:, anew, new? smwa . WU: T63 ?13 3e. ?rmer. \rmm T1137 N34 71?, HP, Vucaupr fw- cars a. was 532?! 96; PSI W35 Immuthammumdobymm?cmanwo. .. A Page Total Am! Pamud Ovsrol?JMg-pmr, s5} NFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page372 of 648 NnInMaka Pohudhopaminl-Anlvd Miss and Mode! Idon?iaUmet Fm To New 33.: 6-?qu Nqouc PM LCQ . L61 0, :x ,6M,?r 1&6 96): Lew 23, 98: T68 Wile 7.3 My 315/ Qatar 95 L998 31-, 6mg, vmomm 12m Cluvou?r peye soapy?: 2/4, 0 1?6 LC 3?m ?Janus SOSLS g?l?i? Nat 0361? p6 115?? ?41.6361012mm. WW - A \g SLrwumw- a? v. 23:323qu lug?? I 1- wane meant cue-uwa Mme. 'n a NH) B?bmh?nqu ?Raine f?Wnoh?f 2:0 MC: ?Mr-4.9 sv?pg-LBT; 1 - . guns ?6 team? A A 16m cue (Jo new mug. I ImamhuumMom-mmuym-onmtommum. pagan?, 19.; 2 m, Liv P?d'a small. .0 M. kab.?o . . I Numba . ot Landings (?31:9 gm a ?7 f?ru? ?U?Ndmw?vir??d 2? Wt 3 s3 Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9373 of 648 Due ?mm Max. mm: Poi-n; of bop-nu. MN. I. I. -. nna Mood Mm a :m . no, Gan-lea ogw ng mm - mm -. Hamm: . mm . LL M614 MGM [Jamal s; -w??bp?emm . 5 2?5 1mm WQMIM ?nw 7.3 C-H 1m 106509,ch new nos gm.? V1 21. 9m 5:512- "Wt? PNS (33 ?uomsm Q930- ll Km: aw b' A. 99): sm?imnruzfiet ?f??m?vw ?1561?! Roman?- M?fs?emurwcu 1., ?9 5 I CQNFIDENTIAL V1 LQL PE Kins-w Was same may: 9% Mr PM ?am $32? C?f 3T L?'lyg . .. ??96 Lem f? LEGK GMTT Hg :21:be t?vpm, ALMvaI-wm rcmo .4 gagw ELM RUE EGK 3616-1", Q, (5 Nqomx P0): Fm. VJ II 96f Cum-um, Horace-em @1641? (408:3 "(as 3.59 1H1 F?Jw??a? New? waW??mw El is KM I Pan-W 3/7 L13 Area?W'mmwy?b v1 a -.J 2345' to +3 HUSH mamq?wao?w 23:? em ?33 1110 3 3 m. t. Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9374 ..7rpum-..- ?h Alma [mm of nap-nun 0. mm: Inonrnnanon Mark Fm TD ?ight No. II Edema-alt a! Landing Ha. um: NKOQIC: LCQ l/ I a {?61 anewpump, 0w, swear-m 3' W51 6; M, 6W, ?v?wmkm? Uni. 0W, feral: l/ TBS wimp; \qm??iw?i? Um Rubens - 09? pg. W- Su?-ruus VI FLL ~98; :mamw 11.5 - 96: . ISM aoymyw ?App-1 (news Caum 61% am? Juana l/ I 1% SSM PBX JUNMM If? a?og?cwM mamnammummws ZN Nq 011?: @831 23 \l 39? img?m??wi /1 ?22,2? A?n?c Lt EM veg 34.. Mb - 8818220? ?23535 1/ V01: Lani Lag [km 36:6?; ?9 Tee Gm: g/L (am: ?(Hi 1e, carom 6.6 (Der: 3 3 l?I out! [y WEN 9.9.73. ?70. 3 gm -WVbarn-w mm 8le Case 18-2868, Document 278, 08/09/2019, 2628230, Page375 of 648 om mam Make I pom. cl anamln I. Arrival Miles ?19? Model klenli?enuon Mark Flown 19% Ram I To {0qu2% (5FLL 4/3 mbar .. mu 9? Alma" Category Am Hemtm? 3" er, a? 2 58?! Egg El,- NFIDENTIAL ?chcosi- 1:51, 5,1,.an guwsfeazo-sc?r?n [051131.373 Ac,? MN 3L,e1/vk,6 a, saw-1 ?f ?1 Ma 16,6470 12,15? mow?) ., Am, 572,9,4, M, (5 1/ lb T131 em W56 Inn; 1? 90 we JIGMWL 13 on; \qu \71 cm, T66 ,cm (st/mmm??Kcu??f Bovrwq- I I NY ?ms" 'r 13 500.1 L-Iif 3 5/ ?0de mwdr?hq I .1 LET P105 [500.10 mos 58-1? \s'ol S?qwz?wwr Rosa-ms VF SAT ?53: I562 37'] W2 awmw 2? Panama! 63 1 Amuum Forwud 3 3 3 Fibre Snnatua A ?2621?!? Total 1. Date ?351:Case 18-2868, Document 278, 08/09/2019, 2628230, Page376 of 648 m. CH From To I Dunn?s?; ?-?f?G-usqo qug?e P61: on p, ,pmkooezngg U1 . 1 CPro Tee .e1,;Mnowm \6 (AMY) ?cj??mp? MCM 1/1 mm 17 gamma: m'mzzg? Vi? \t 30 1' 11K 06.x.) a ten. Kc \0 090 aroma-ass - 30 AQ. Meme? i \1 K, we no Wigwam; ?3 :1 5: :21, my 1- mm ?:1;ng Mm; 1?4 @1389 N?fom?, ?g 169 5mm wane? I I 5 1.0 15M oen?<acmhxunm 6 69?7?? .v 10 ?1 p9; P9151, vusw? miss? 2H (rims T65 P8: at, m; Fem? If; 1: NQOVSCM 98): 1?!?st Kmart/?swag? /l1 I 9. LHL MCN PATST. Razz/gm; ma,? ?9 VI 1 l? Mc? 115M (7 1/ 1? - ISM may .uN?Iocg?cr P93: has -i I loamy [139911385 11303:; film - A - I in 0.0: .94 a. -. as Pilot?s Sign-lure kg.? .. . ?-r-Ii :31. we. a? - 'f a; 33- gaff --, .. - in?l- 5-1, 'u . . ?1 - '15?5?4'1? #1513" Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9377 ?Modal ?wall ldm??u?on Muk rum or Damn a. mu Mles Hm Mm . Flown No. Manon at LII-lam Hum To L-m G-Hsma 727 -3 N5 091.5 LCQ ?1 ?5ng T68 7,39, WMW 062: 1-31 A -. 413$, Mr? t/ T6113 C?fut, 7. NGOMI mum?, Reel-u}! ma 5 CWL I TGB Agc'??nch?m ewpamDth-?O ?ll 96; 1 15!: qe?ml?m W,m?owu, w??amw PB: 15w 399"" \l was Lj?Po [?5112 ?315525;: wascm, \l L690 1m 3683?? 1 LEMN LLML \629 ?1 PML L696 rm ?Yam? 956 (. M4963 1.931 369?? 66'. 6v MM :25; 53 ?1 60 gomxw?_nmnhod?rvo Silt?o 033' faminewas no. ?new Anwmt Fm"! QH ?3 133 ToId to Dale b? so $1563 [?57de wimp; 1-4.57?. . . Vu-mw, 1? . . 7550?. Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9378 93,- .- .. ?w'rl, . a rm . Amt! Malt. and Mom Aircraft dden??natbn Mark Palm aim Arrival me To N?h?fbP5): TEST Aha ll" Alma HEM ?t I) \5 0H: ?(433? ital-?fir 5 mm LL: a? gap/"NR cm 00M Lewis ?176% \0 r5 96; Is}! (imam! 5?9, VIM Um (means ?31. SCI I: 35? 15 33 N?mmu?wf? I IS 36/0?; (Chnl-(f 6mm [0610756 :EPxx 9mm? 6 Ng?g 0900va 5939f MLM cunnerw 6 SLOW :cpn, m, me. 09:37:; It 13-sz I 35 BL NO f'bwm W51: Mm Gummy ?l L69 2 TOJMJ (SH-12MB In?! 79? MW tws?nLuM 5' COM glam mew. 31am {ac-raw N3 0?36!? 3M0 w? - ??g/?game? 321.173? \l Mm $475?$309?) deNM 45v 3'0 5- :4 Mn .9- . om? 25?? l; II 141180 arm .vm?n N?w?szse N50 PB): in a. ?cvf?mmnvu??iui, sumpmw MMD Bows v1 mmfg> ma poet/Ab 34 Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9379 of 648 Data Nam-ll Mme Mint! - Polnb 0! Doom 8. Arrival Mics FilaM Roan Una. Murmur and Mode! ?emanation Marx Ram No About: Gun-r1 . Relic?? .. i 262' Ham ?Landings 817nm I (461023;; 65; Hp p. em? ngue wmm. 38 - \x/f r1 \Wr? -,533:1}, 411?? 13:57 a?crm?ygfg?'gw?fi? a 1' Hip l'z. Hem? N. ?3 BK l/ 515W: ?q mm) 1? F12): Way; (4:40 1? Np; mm? Thur, 131' e. :1 7:141 Masai-m, 981: mm xs 6&5? 33? 2? IL) 1L (\qu LEW 1 AS LFVB CTQK {q 34/63, emv?iv 15? (3(ny [q T4567, @91va 1?6 wp 1: ?10 16,5, WM emu/1.4 (t 93}: BBQ 3?6, em, s??i/Wr mum.j?A7( 13 Mbwams '1 KLL 2.9be ddolm JONFIDENTIAL a - - -. van-a,? ?w??rj inor?a H: Page Tam337Tot-Hob.? 253\ns . c.21- - -: . - Case 18-2868, Document 278, 08/09/2019, 2628230, Page380 of 648 Alma Mam and Mode! Aimll mm Mam Muhamm?Anh-l We: Flown No. From To Nmber oi Malt 1; ,B?mm N?to?zm/ LND: (033536" tam-gm N385 if 373154 LCQ MW Mam? - 8H2 sm'xswacpar ausmm IUD G?a?ls @4685 PST. TEE 0' N0 96:56ewuw (JOIQFIDENTIAL 7:35 '631 15, 5mm? 98.1: me,m,sx,mm Steven Famuc 35? CE 692-175; flu/WWI 2 mam; 16mm 9,5 mi??wwg 5595 375,571? Z?cm \su?l :emmu we trap?. 5L 5'49 \593 3?96er 5K 981: 31?; 5K vhwuufs WNWL Gabe-PT 3613K T60 $553 PMSKIJUMZ- m?xw (2,58% lhal tho untornonla made by me onihb tom m. Pap Amoml Forward H1 'l'hhl On Data mt" . . . ?av-4 - ac. .2 a. . .un?qlrutA?rmuuwmaw m" I ?19:4. rm To 1 6-0500 Nc?quc: ch Pb; 9911 T68 .. ?g was m. - meme LGQ m; A - fV?W?w 10 .3 ?y \i CHEM 2L?f? 1M1, 30 Skl?owe?oo 10 (icow 3? 1e, 3 .19 EGGW 32 3C: u~ ?57,4 pp)? 33' 36 SK sun. row-3530'? i Vb}: K157 '56 3L: L: 132 MW 31 ?029 6? ?mm \g I CLMW Numhav Micron Ammw (rum-I. at; L): 173:1. qu?bc F95 BCOU, MLwJ?na'Urfl Oln?nu- 3 i QNFIDENTIAL 000051 s-nSbo-rr-m?nm . 440m} 7/b - I (Q (Lida/av,? 33 (J: WM) numb-to 3 \Il. 0" ".(Irx .- Leer :4 43: c" U: :r '30 AV- .903 Case 18-2868, Document 278, 08/09/2019, 2628230, Page381 of 648? Amt! Idmt?lcanon Mark o! napalm AMMI Hum To :1le cums ?1 ?Lo?ko 347,2. nechmt-mr' SM, 20440 41?] ?g 0? ?LoMo wk?o unruly, 7. (ha/was A out \t 92w (cactus) WW - 0 3e51, VISL 53% 1745* 5C 5517 \l b<3emm W31: 8 NC mama 11 mi 35%} 37 Shamsxme-mvcw,? (48?le MN \{Mw 5% 3L, \l F615 3% i ?gzemw? I misT TLPL (?Bi 1" Wm? $915 0/0 \l L9 ?wft LN WALLMV, P9 w; Ie/s?mm MW 53, (3-0686 Nat MIC: m6 PV 155?? ?36'6? V5 9 BF ?rm-3! 0?63? 96(41% O. I, WQCMELWW Page Total .31? ma? Nnothomrd 6?55 -Naamaral?Ng? 0' 70th! to Dal. (bog: 1 ght?tlbo?a vim (4 Case 18-2868, Document 278., 08/09/2019, 2628230, Page382 of 648 >53: :38 use 2.35 .8338; 2.5. ?23. 0- 082930 Zn. owum and: L: 43% .- 0? 2m? 2923 E52. arm?: 0 Db any Fm?-ufmmzartmx?b?i?. ,gcv m: Ho 93% Va 6034592263 3932b MT 3. an 3 wmw?m? may.? .woemaum?w .3 ?Ba .3358 mm. QFMK99. Haws $530? 8 i 5 H5032 10.), Em?. umx 25.6qu a, a? @334 9E Egg? use 458. . ammw?yzaongr Case 218, 08/09201972628230 ,Page3830i648 r4 Th?o >395? moga ?F\vl .633. .5 Ola. ~19 . - ?317w" 'cl? . 54' Dale Nu.? Main Marin Points of boastful. Ania! 49: .amuodu mmnmum 7.007,- From To High! Mamba Aim-? No. Finder-uncut: on A ?32? {Hm-3: mogul PM 68V 93$ GLEN DOW 0117pr Cal-M ?Ll/[l cams?A cad-wow 1.0 \t 19134 M?lf? ?o?m ,t'Nb . ITLHIW 91' l. A ni) ['il?l 3 1 - mfg: :91 mag ?1 lured #ng" W?w?g NFIDENTIAL @131 3 my mum ,V-nmm Nanakcmm K0me 1\ 23 U) ?gu?am??wz ?m mnar nannies?: SH.- Emmy/w Nauru? 153'. T63 \su. bem? 3\ N?o?b?f 3PM 6IQ Ema-L Vi b?z??zw Smuwm Mm IVER 5W P5176 gm?) ?ouIJFNol I In [2?on ?gum. '1 H, OD - ?imam Emmi: MS i?ntUgLid 63mg; ciao wmwmu L0 40?an 610m TQK S14 M, cr-MH, 1 mamas 39% 13 36751, Sec Monm, Tour: from} .. PB: 36% T11 es: Soc: Mew": ,auupe ?Two 3% EGGW 15 . muf?n?, owo gas-2m Scum /l 7.x Eeew Btu? cq?wwr', noucr nm?m [aged as?: ?r 1" :re. it NAOMI :nm-e 2 3% Mar-w- 2w MW 1.1% 3m m. mgam/ (Mew, Idiv?dad??dn?43rd? Page Tow Amount Fatwaru l: mu to on. 725-15, 0:3? \u (m so mu "1h Case 18-2868rDocumenL278, 08/09/2019, 2628230,? Page384 01?648 Due u-19" . mum manmunon Mam - Main Allard! Points 91 bop-now 1 Arrival Flat} Ian-kl. Dd Number 5 3 5 2 Eg 1?77. mm A 8421,31 N?w?e P6 )1 T3357 Ame-um woe/L mum?" .13 6 A 9:??va \l (715; cum-IE; (LL LH 57:9? no 1! Gout Wig??7?- A . 3?:qu Laws 5 951 3 2.0 Stnuunuc M991 Los?1:955 Ok?ww?f?g aw me G??ck?r m6 c-n?oxz Fate. mum?m 5mm 0? :umms'mm, Fuel. dump/ml}, sun? 6:05- mm ?lat. 43;:me 6, TWO em- ~I'6Mmu$ ?M-we mam: ?mwn?nf?? gcul?, Apuft?f, km 7. 1.0550? 0&3 mtg-ruff, 5(4ch egg was or oc?em rang sum nu (Imw ?4013' fka A 1066 sutum-At?hf 2% {arm/3x N?oge? PG ML: C10 61167716? . c? gem/yak 1f 9. 961 cm Jame?! UNI-5 /1 mw?aMOQOOanaNr WA u! L/n VD pal-'7 on mbbmanm CE 991.5 Amount Forum [5.1 Plot?s Signature - -.., 3'57 "815} '5 '5 H1 Cas ocument 228708/0912019, 2628230, Page385 of 648 Nm? wake Moran Modal ldanll?uubm Mun. Qoo?b Polnhd?mlm?vd muo- Fight 7' Nunba Alter-? Gum: 1?21 ?44749, ?549 (H (00.08.38 a, 49,? 96L :9 2 6.72:) ?og-5c: 2ch L699 0 7 LFFG a; 66 CH: S?ic'? 5" u, (:er an 3916?? LFMN 37?9?? 36,6? 5% . /l 13 mm? 15?} Wm? - - M1 - \fwa mew?H 295:2 k1wa?SMM? eh i 25mm! wess mum 0 v18 0 Miss 0'1 0) c6 mm Yams" 10k ?Car OMDB 13pm: E??w 30 l? I. owe mes '51 533;. u. . mNdd'Jlj-m 5% m: mm 566W 6147M) RePosMrw I canny 1h! lho Manama made by me on 10ml an flue. 9.99 Tom (9/1 nail p?mdn 1 Amanl Forward 533' .3, ?635 h; Case 18-2868, Document-27%, 08/09712019, 2628230 -Page386 of 648 mm mm noun. 0! a An! I 49?. and Mode! Idan??mllm mm . A A Numbar 1062 Fm To of i Nqo?ixe ELDW JFK l/L ?2 PB): n. (335% Nqoqmvm 965 EM ?Mf?sw?msww H4 B-?WZ?Wlmuqom leg; Bog Ravmm? \1 Lt 03 1 W4 313,?,qu wag-5 \g TIST ?1 Mm m?smm? (Waco .- T615 m? 391 2: I We? a INFIDENTIAL (Pravda \t [ma-.9 QBK Re?mrmw 0/0 Z3 952: MYEV ?e?isnnu Mom 0/6 I . 1e 9 Tu; ggaag?littf?fm 3am 1/1 z? was ?rm? 1m 35? 6-in- gnaw Wes-e 3.44 mm us z?xw DNA pam- O?-W?vh :glw'f-t. wuz- cr-nu- Iz-Ubw- Mm?: Mamzqu U. 1?1 1-1993 mm P6 lle 3?3" 3?51?? mpceamg I LFVB 75? 0/0 55 PanaTohl '1 anal] 02/520,110 Egg 8.6.11. Case 18-2868, Document 26-2-8230, Page-387 Of 648- Duh 2.00.5. Ahm? Mala 3M Mow Aim-aft uni?cation Mm Paint: a! Man I. Arrival otLandnga Sup Fm ?o?oje \3 v' 6mm GMNC emme LLPM. IIHQ L901: Recy- ram-?oat, ALXSS m?enrvc 6 meme 1 PCS: Wm? 1 .GEWNFIDENTIAL (I 1?5. MLG ISBLI manque. '3 \7 mm 3? 13166? max. 001' 3/3 ?LbR?o 99?S%Tfmodb N?lo?b?? SM m, (?Fm 1851 . - -- . RLrutz (now a ?23% 'quue 59? 3G OMS (no; nowm \l [169 N?io?m? 19m: Aze?? 8'31? I 732% '3 sawmzran Remus, I ((7th Jasxluwar Laf?cZ,Ni'ipN Dora-uro- 9 90 r: ~94 Casal8?2868, Document 218, Page388 of 648? Nwrhar Altar-? anthxu Identi?cation Man: Flown No. . Hm To A mum $918934?: (rum. 6317-24? Nqb?z?? LFFB ?3 3? Le ?~LFPB 19K 3m . 961*; \3 fed?; WM: 3 511.?! ?35 "$68 GER my?? BED muss it "1'66 2' 11.. w; 1' . TIST WW9 8 4m Dare 3 v. urn we. 135303538242 mi; 067% \371506; (SN-cm] Ii mewm 0 . 6, a 4: ?9.07Rhaaluib/g. m, -. . cm {was um mam? 911 050?? L995 1 \qb?We A5 NSOW /l Panama 5/(2 Mouchmm baa; $3194 mm?b 31%{Qm6j11/ wan-o- 851?; 923% Natal Mm Ntu?ak Foils 0! MG MMs WW NFIDENTIAL ?deN hhfr??r~ir?n?~xfuo?mma3 sofa? 01? $5 579. _Case 18-2868, Document 278, 08/09/2019, 2628230, PageB89 Of 648 AV 200 1. Fun Dal: ma Mm: Aircraft helm: at boparluro a. Arm-I Miles Hm Nod-.3. Nunbev ard Model Idm?fbaban Mm Flown No don-maul: Landings To I Alva-? my own cu?? B??b/?ur Nqo?x? . 6 EGGW I .L?vm?h?gz?e?w Lgp? I NECK. A ?217me cM/?rm LIPS . l( 1 3 mm?? ?4?1 mil?H emscm (3'61 (I T86 1 Wmaahmnu? Maw? A ll ?48 millimetr? PVG 1L8 5mm an? ar?onemw St. 1 06? H500 9m 954*: 1131? lA BMMB ovmuv f1? 98; ??6??mm3m ll Sin um-m i Vanni.? suw 34.(1,411 ice 5.: muwrvt (3 (a \1 ?3 (y-Hscm '54 0?11?, WET (5,2425. ~43:er Dr! ya LN: Lem? 00 .- $.50 T63 But.?- Tml?x551'31401, 331? mecw i?cgtcem. If; .u :33" gut/INL- Gen??2 Ltuctmr mu? homo/mg? ?3:15.003 . 1? CH 6 at. ?t 11414;. 11:2; 03- DU. LL {83? 33km (1;:me 1mm? :35? \7 TEST ?.5170.? . (Win-3w ht." (if-cum? 131 ?70} 0 07462!" Mr?T??ww I .7 i. 9" ?0rj, 16Min?. Pogo Tow 71/5 37? Amour: Formed (3958 7.453'45 amaqr?KJJ?Dln?o? f" (A Case 18-2868, Document 278,? 08/09/2019, 2628230, of 648 om mu Make Alma 1 mu 01mm mm: mu Hm I Number mm: 45? am Mona! lawman" Mutt Flown No. ammo-ls - 17!, [Tm To D. . 1 (Adm?1 ? P??wu- (95 T161 L030. 3'34; aid-7? rgvvag 1 1- 033m 1 u, . Lu . Mu?xnyv?nw 44 . 17 1\ Lag: .M In? .18 UUWW 3L- ?:va 3K, (Mamas/.13 .14 f? ax?ANma?rMn?wsui -- -- f?v- fs?u'EK IN I: ?t?d g~ (?3M4hnry. Lita-Maxi, 2.1; 31" - ?39% 14 W311 -3 W1 Egg-M33inmk. ?1 PM T15gnowreg- (1149'ch ?Iv. ?13m 'n/xv'a} M712 numbigi?aqwt(HAT '17- ?m cm . wk ml Maw" M31. . $151 (LET Ma ?391?:va 1/ - . (NM . L1: aa?b ?3 . ,cw?w L5 . 951 $6.13 . \t ?(as P?i 3191:?? [3.9.1018] 75(3 ?2.75 3? ?0 INFIDENTIAL aha :r?oo .f Trc?r .1 I'w-r?M'nTj'Fi?i? Amounl roman! 535$ . 1.x . r7 . Q/Ir?f?lzbv 1'01" ?0 kW t! Squ Case 18-2868, Document 278, 08/09/2019, 2628230, Page391 of 648 We ?nd} mm mm Mum! lam?limlbn Mam Points of Dip-rim a Arrival TO .. I Number ?on? cl ?new: SAN Fm W-?ss?w NC-wme PM, drum up 6.180;? f? r. 5m ?chv-gi?ni fir'wzrw N?tu?c 2; :Wm 38? W3): ?q ?Mm(34' 25%?851 WM. 11357:? It P81 T15 DI (3mm Q?vnwm.? 2mm. pgv-Mr, mewLx-?fmg. (mama Nam-{Ia Pm". \l 36-115): mama. Lr?rwvw \?us (.7: Rim: 0 ~an 2ch ~31 wm?c mocnw B4111 rm \i ch?rgc: 1?90? 99? 1P1 nmenqL :mv?ON P61: ?mi? . mm-r. Hokww~lpnr?mt a! Z. 2.. A ??71 Lt?g . I ?r mama, numb? mm. .. . IL Lem: L't?m 1761 :m moonu: Mama: 0 ?lm 'u 1 in?? V1 \l GI (Joe \?MLMW ,Wnru-c mnkt' a 1 PER )l It CE): P61 Lm?n Mm 1t '81- IR. 332. 15?} N, minaret-e Wm: . may,? ?x am? b1 9w a mum; new mm; OMUTQO Lug-shack epTRf?? 1 f3 ?Wm . Din-? .1 ?345' (at Amount Found 3535: 'l .J (.4 . Case 18-2868, Document 278, of 648 Date Ammo Mam 1g and Mode! 1065 Allutl? Mark Point: at Denm- I Run To Mica Flown No. Flight litmus Ian-ml . 1 Number [mange IE per; N30881- BBQ 9.V1. {5411,100 (ram; 36!? Le ankumw 329 LCL \8 .LZ?Ll-Jcaov - 13651;): gmuik?v 6? Tamar", swan OW "Aydw 5! WM 1&6 WM 9313" V4 8 T66 '23 .PSL Jab.? .SK, 3th!" ??wuL-L (J N51 037?: i?t at)? va I- L?cfrm?j? ?11 't It Nb J??z?yllc; Loki, 1137599$ (NHL 6. 1 \qo I. {216. L695 Lua mucL - (Ho-u Lb (x a! 225%}: 2.113%. sue-{La 6 ?rm?Now Imam? Lia-W ?7 Pilot?s {Cf/deg?; Pugs mm gmxnembxag Amman! Forward Total to but. r12? Qo?u c" H3 U) . DNFIDENTIAL Case 18-2868, Document 218, of 648 om Anon" Malta pom ol mm a. mum I andundel Mart - cements oHJIm'ngu (329;? A Guadax km {5111 Meme 0(an 9 Bi . 9 $237 . ?3 ?13661 9 CM T66 3e,AL,5x,6'r 3 p? Kl EMMALDM ?3'3 L: If ?If Nunbac f?g?w 1H- '5 3 BC: \lN?f K3 Ezm??mm \?nivi Len '15 \m?t T488 Ima??'?mm? WV 3 . 1253(Duane-p5 ymus', fro-vs, 1 . mazmw?mwzm - (L00 I I NO ?ma?a :Ecwgu?g?n?kwm - NW is? TEST w. %~1n'3m N?bast TIST 3% 9? ??25.pr 3 Pas-Tom 4/3 3] MIMI mm" (213% cm"; ?3 33 H3 1? I byOldjad? d'if?. f? f. .4 . :F?g Ln Case 18-2868, Document 278, PageBQ4 of 648 I - . .. . - Dale Alnmn Mam Alrcm?I Points 0! Doparturo a. Anlv-l Mum Fight nomu?whoom. I ?uni?? 7 19 an: Mace! Identification Ma?x Flown No I :mw c-Liosr?l \wcmq {13:12) a? ?1 e- 51 Leyp MB 7? Lt: mo 3 9* qu?ln?fm? Mi mm UEJMJEB mm?) Ethan?e . gs): mm? Isaa??/?Gf; :w'em - 57 CQNFIDENTIAL ED ye; AM, Y?is.? lum3z?m?v7?' L1 [um/?GM Til-5'? 1-.ng i . 1 1 N80813: Tifuf - @181): I 9m 'T?tf} 94.6; T56 EQUL nae. (1.013173, . CW1, P?l? mm' ??vmw [0510532 961: - 2m rib/?MIG?? E: 8 39L r1023?! Aggy-?16'] bi?, (513mm: L. N?oqjtg PBE TCB I Ta?) 981 lmts??-?WW 0/9 055$ 2 i E62 \Gujfl?53'wv Tag - ?Mk? - lcer'Jty the! Ihe matemen?ta trade by me on L519 loam are true. p3939231 W1 . "p - . Mars 3mm? (M1110 {gr-:or.- ?5-11er: (A v, I-) My?, .2. It?mwn. . 2; 07301353: :3 jaw? 00 33 5 If Case 18-2868, Document 278, 08/09/2019, 2628230 Page395 of 648 Case 18-2868, Document 278, 08/09/2019, 2628230, Page396 10L. moi 9?3973- 161W ?Lew~73: $91? .1 lib 71/ t3". 1 - .0 0 W2 *wun?czgjQ91 90?] sea?NM] 19 ?n i? I I5: -L?nvtm0571, 993/ 99$, 7?33 ?7953??. lo 111.] )er 3 :1 (ac) a?coohw I WL'ygv? {?gs-6n037337'? 1,391.9 J1. ?191 4% . 87? E: 10 a} TinaN . @0905.7: @175? 9 49:1 WS . .. a 31 \tnU?57T??m71-I? 1 ?1-53 SELL ??9.05 -. 109vu?j?od aQ'v I vi ((413: 5. r; 990000 80 2 9/9 . Argos; 59"] *3th . - 5.933. 196 1 I h?L Xs?w?) . . 14nd - 5 5. ?$2.00le .r 5i hm.m (mu mm: Lg?? 19341 3 57 9: 2.27- E04 .- 431 v.1. . 0 'lr'gua 1.5; T11 WJ?A?Ju?tunm: M31: 8221'? Innwv-loanuodoalo tuned WM 7.ng man 4" Dun: Arman Make II A'rmn Palm: of Dcpavlurc a. Miles Flluhl RanaI-Iks, l?roouluruw Number W3 and ?u?CdeI IdenlIIcazI'on Mark Flown No. Mun-emu. Mum-nu u! 13an La? Fm" I To ?1 L, szywumw, )jpr ?gf y?w1 4.2, . LID lilIrInx Java jauhg?em?g?amm "4Cn?f?i??l' 1/2, 6 ?5603? [106me ?wen .. 23m . Li 30' 17:33 PB): 4?14; $1?ka Pm) 0s- era-g To . 115: LID I IIGMJ I Lf?mm - . I I man we? mes-W I r?.Z <5 i mm goo?Nrcu? Cotonou. CONFIDENTIAL LMIISCIB Mom T86 ?g WI Sewn? . 3 I I1 [Tmf T1{?{35:0 - I. I123 I510 Kai[913% ??ashc I 2i_ MN J- an 911933,}. 1\ I $1113): mm. ruwxw? .un 1.51 Law AL .J) I cenify that lhe made by nm un Ibis ?01m are lme. Page Tcdal Slmalg?LJ 1? C9 I15 A (Z): fee-(Ii; .. . A: Arnoml Tali! to DIN Case 18-2868, Document 278, 08/09/2019, 2628230, Page397 of 648 0an A?crafv Make Aircraft Polnls of Dopudm 8. Arrival Mics Flown High! Run-0&3. Mcmul, Number AI ar: Mode Mam No I ?imam." 0&8an mt" 091mm? :503 Fun 1'0 Az?tpuj?; eLLne ?501 0_ :31? Tee ?,9th 5? TO I a, i 2?0? 1? II [517 2; ?rm?zII-I 1000837: :35 9?"2.511 - "52> I. P6: gm; 1 - ?-30 I 1' I a ZS (?(21952 1 117- ll: II .4562? 22.2 BM (la r, ?60. I I 7:91? 22] 228 'i CONFIDENTIAL :l 2 1 II . Sv'x I?m?Mwh AM I ,m (?9be N1 I 2?1? Laid-u I t? II .- I .SC: ?94 (>13 my Inabm. I HEW ?232: pmj?in?v '5?th . I - IdsAern SA 08 ?two, . m. I lUUk? 1699 Lam}. \1 ZBAPS ()9,qu I1 520939124 - 44 J11 3 36K ?1 2?53 1? /l I 394 i FBI KIWI. I.C. PM THC [75-21?92 II. .. [331, .?Scm?x roenl? the! 1M statements made byme on Ihls 1mm are hue. 1/ Page Tulel I i ?111-1 . - HHoisSmaIuru 1: - Total to Date b.1314. [11?35' 7? In,? 'o :j?x r3- 01m Ln 3? ?Hr. . 1' 7?35?! 212.01.?. air 9.: 5n imp-{cam 1.2.r?derar? i . V) hi Case 18-2868, Document 278, 08/09/2019, 2628230, Page398 of 648 Arman Mass 1 and Madai Mark Aucrah I Pain? of Departure Arrival I me 13in) Tu Number 0! Abua? Gimrw- macarg cm? ?rt? 73'! 1L 2 T253: 15] 4 P82: P81x1134. (A A rm? 9:11:53- Ahmed?), V?z?fk': IQ, I 321,51 .15- 3 6K. x? \3 .34 (ST 63.13. CPM Luz-9'! (it "1v besi- 3 *1 "251%? :32? TV a 91ch law \k r. . ~12. - - ?U?f?l?mti? . ?aw-3m. ??uxgqaw- .C CM Pf); 1 My? Ik??l 3 Kym-V3320. Viz?m'aqug?ia; 3g I be: . TD L?W?jjl?ej? {?1215 I 3:51 ?Tc. 1?5 v97 15551 3253? 6 (.5 Tiff? )Lgl: M9299 9?3 g: PET. J?o?uo?hm mow ?Lv's nH9?M??~a, LV Gm' - .mm 1343p! M?N?sw ?zg?mm?f, my Mt: It: in NM Max: 15?" . ?(2:133 [56? 34., an, 2mm, 51, PM 36K '7 [6:10 61 LB, 5K LU lb? 34? {ream-n Mvz?si 5K [\zjoajc P81: 5H 1 I PIN nqz?i? H10, NM Ly fooril?y ?ml the made :me. (TA: Page Total ?0/43 I Anoun' Forward 17* 1 Total to nu. .. .. - -- jls' chm-k? tor" l?1< ?Cw-?g I 2? 1 of ?h-?hg e: . P..- . again . . 2 w~ 2. gs-- n: air. -. NFIDENTIAL Case 18-2868, Document 2628230, Page399 of 648 Page4OO of 648 7 1 010000110 2: Case 18-2868, Document 278?, 08/09/2019, 2628230, 1 - - 1,9, .. . 8?83} bw??git? out: ouuo; r/V?ypw i: (2 STYQ '13) like; 5 ?3 5 [dam mgo?wlx?m?wN?a?s?QZ 593 I CE.- ?95, onus'wN?wa'"1?57; ?83:3; .C 0 9 M5. 1995 2 i ??93 1?36. 1&1 5 mu'wN?aL'Qwr?wO?Wa?h?c ?55; [9399 LY 7 \of) ?13. Me?ox'u N?9151'w9'acl3'7'5 . 1198 if L- X31 ?33:;th %qh?L 7? 57., 'xsuwmg? 7% $93: amow Nun-9 I 9 ?909 ,3;qu gd 0/75.- a: mums? mm 09?? I 5 . WE -993527i (C 4"}gil I 8171- I 97 ?Ml 259505?? ?32. TC :o?aia??sm??'?afv?xs 'wM?Lerniig-hu I 7?2 3 I WIT-H4 11mm? ?(16:41 gupuawo wow 0; mum mow are "206*? "Worm-o 11.134?! menN ww' "New ewe ?g ?v Duh; Maxu M'oratl Point: at Dopadm a. Arrival Ml'ea Fli v. . Run-m .Proclduru Number Al .7 Elm! "61>!an Mm NO 0' Lond?ngu '70'3" categoWW: 9931714 We mu (1 or To NCN o?lfGukxw 33 Lw 3560 ef?gy 1: gap Tag - L- 11143 If . L: [@Bf 5 ?38,105 65773-10) - W9Y4Hb1?wui. .5 . \xl . Radar/vb- LnaP-w-c ~24"be 554%; . - mm?: - 33Eqrp, (3f: A . M139 - wafmm Ga 9 198$ Pg?: 4 nuLm/?k??ONL LVI 2n P81: [39? 1.4, sewmno, I .H -M 1 F79 .751 153 519ng 18831 2% 9m mega? mgji?g?ga LIHL V3 C117(ac-so m: Jeni: \q mg 73; mm 56,61, .AawI?Qet LV ?5 Se, (-31 Mm?? NM :33? 3 I 74L 709.1600. cm? . Iccvu'y haunt ?elements node by urclrua I Page Total 9c? ?1 . {mount Fowrd 53.15 Pm 2: Sigr?afugegivctl 1(<51 Toll! lo Duh 1 ?5?39 (1H3 I 13"; . D. 1 83?03:? 1 ?33;le fr - 4 -. 12-, PEN C1 CC: 0 ab?OJ may: .39? I smram.33 Case 18-2868, Document 278, 08/09/2019, 26282305Page401 of 648 41% Pom oi began-no l- Arrival Ramada; Mowing?. Mum adoration? famnm 10 Luz MM, SK Alma" mama (yum - - NM Wm?! 34? SK- ways/M34, man/M .651 Cs ??48 RON 543$ 3'32". 0}de j/mj {i a @mr?hh! not:Se 0? '0an '1?1'1 4? {may Case 18-2868, Document 278, .44. ?rpm TD 21? NASA-K . ?th?:La_ BY 51kg wold: Wm Ii.? JZI SK n. . made by me on this ?Otrn ue lruo ?p . I . . ?3312. v, -. 'v - . Page402 of 648 ., . vs?wm, ?2 0am Aucnm Pohh of Doparlm 5 Arrival 'Mies Figm "mm?59:1 andN-duc . um Fm [m N9 ?smut? drum? .. Imow mn-?QNMom) E) 51; LY Vr?m psi 1mg 17i3r?m? a. 0 (MW 1 _g 30? 33:5 31 miima, 37- GEMS, Wm: t" 1 ?3 ?3:373 '34 mo?m 4-76; 11141138,,05V121 ?z?kwl NM SK C: Cr: 11214:: seMMw on m? EMT W) 2531K K?S?fapwze 73Gb NM, SK 5K .3ch?: mam A 758 HEM CONFIDENTIAL LIES q? A L4 95C, PM M5 Tm? 9&7: 17? 1? $7,945 73; . I d) (4 ?451;; 1" 1 [9:95 2:7" 2" SK 513:1 1 1. ch?Pr 13,; TD 45% 1 I certify ha?. tre summons made by me on Ms lam are l?uu. i Page Tom! E/u] 5 frnnum Forward t?ijici {rig 25 441-91 (7 rim" 3 I Total to Dan Bid ict 3 Case 18-2868, Document 278, 08/09/20191-2628230 Page403 of 648 . .47.). Dale Aircral: Make 7 Airual" Points 0! Departure I. Arrival Milne ?lly? Rom-yin, N'uganzrh l_ Allan? sxrul \Am?q IdantlliraNnnMam [mm .70 Flown M. Manama?. Itdonomonu .aw: amt may 42;??lth? 3" Pn?r?mmw - . - 0'0 \0 44 PH): TKK {-83 53?. 330443;.? Q?n um 22- 3 W4-5E 5 Aaaccuuv?) (-Lv'rin, LY3 :3 3 3,33 333,3; -4 r; 43: _4 4 CONFIDENTIAL IE LL WW I VNW 33303{.61 76': i" i sew rum 36394.1 twa?t 3, 37481 1m ?0 . . 2.. (3-4 (1 {5 E6 $3395173-3 TVDT ,5 9K 3 9.41013, 323%?, 5330 ?mm??i'lu? .13 3b 0 8: 3 1333 ?54) .5K3TK, ?2 1 . If 1- A_b ?10 333 3312(404?7 "1711?? ?56 gff?i?'u?n LL 0 93-35%? 1 (n no 4 . 15:51 f? _1 3-30 V- ?3114.134 . ?1ngm.JwW1mrw7?v 1? ifInn-5.25m 3m 33 i 323.9 . . L?v L) H?s? 032.0 J?grr. 3" (4:524 1: 05? I I I 1 Var-cemly Unl thu made by me on this tam are true P596 Tom Amcu?lfotwafd till (3:5 31 kL [2?33 Total lo Data :gaf? "313:" 5 1093'!" ??rm Case 18-2868, Document 278, 08/09/2019, 2628230, Page404 of 648 Points 0! Departure In Arrival Mlles I High. Remarks, Phoedun'o. Number Alma" Calocorvm ?own No. faanmun. man-mu of Landings ?i8; 85m in Hich?m 036:; a 5?2.9 T. I MAE ?w \Noaew 91 I 1221?\ 5346243 'Iw?w 1- 3 I 1 Ln 8.. f2?931thm? LV CONFIDENTIAL 00??,ng we; 1 Wyn: um mm; rum. (Man. vauum?r [150 ?rr?g? ,5 K?x PIP: 1\ n, tramIn?zxa, Moi-1m? I nen?y that me stalemeMs made; by me on ll Is lonn are we. 4? PA!o?s Slgnalurda'luh Dwe Tota' Li//3 I Amounl Forwad 7 x) f" To" #6033 0?54 Case 18-2868, Document 278, 08/09/2019, 2628230, Page405 of 648 Total to Date I 1 NW Ji.) [i=3 74? a: v9 -- .l 1 Ntmoat CHM- mam mg; Due Mann Me I Moran new a nap-run a Mini andMouu Immazm?m 20- Flam [To L's-mew mmse 16.93?, 19%: 2.0 (542.19)? Wheat: Jema?uiu'i?ax 2.0 .. 33M (?61 2.2: 21:: e-wsm Nqocm?: 2.8 e-m?w {001085; . {5-121 ace V-I x} - .4 u! ?mm, mt 1/ . L9 a? gm?nm?t?; HANK. Couut NSYIQUCTEIL HPNK cw?; wmtvum. WW: fifty Amman. 1T5. \mS?-psv-wmsn . 21?} . NFIDENTIAL DR _000076 r491"? '4 SK Ntimom Txfn-Lz?ls-Ws?? LV ?30 1.5: T107 Lv. N61613: Taft; vgmn?w a 7; gig _Tci8 use mm I row 5 \f 32;, LU oenily that [ha summons mods by mo on 1am In true I Pugs Tan! 7/ 1 1 lAmoun! roman! IRE-1, .. l?r?d?hm lTohHoD-to qb?? -.D 0? c4333 Case 18-2868, Document 278, 08109/2019, 2628230, Page406 of 648 Date Arum Make Mariel Identi?cation Mark Marni: Points 0! Dopnturo A Arrival Fle Nunba' o! Lmd'mgs 1 qu mm? Cad-Low 3315:355qu 8? \?st 0 L) (:st f5; Ml 6 $173-$115 3151? ZL A I 31.1 )1 ?(5.51 . NM, A mama360M, mm mamtg i a mpmam?w.? mi .1 ?7 -2 Lb (3556156 Mid'h??. FM 236'? Lb??i 3?3) Db?) . 5K 955 {4:16 Ken C, (sf: I?q CVO np?iES?SurJ ?Wm I Gan-m 96; 3.33 Btu. 1w JMDW 57 EM 1 I I W: ?t?z?a 5/1 6mm ?Loo .5 l: mu who: M39 ?ow time ml Mmmw, me. i \e no? amp. . NW9 4mg)? Eb: Spud D3 GM Rm?w": wane? 3m We?l?o?efmuw (1:9.wa um, BMMUNW amEcenl?vy hat the smements made by me on [hh town are me. Q: rm DJ 610/9. Pag- Total Amount Forwm! .L In Dan f? 1 Case 18-2868, Document278708/09/2019, 2628230, Page407 of 648 v23.- 0. actual: 9 . . 5.01st Minnow-530:3 a 1 r3. 33 um. 23? ?fez/.03 .. . Hfoibm :9 1?:36. a? H, :3 a 2 F17) .22 1-- $022821? .535 .H 333 2 on r. qr?. REES. HFDEEBZP ?aa?av . {Iv 37.2} h. .1: Lcabrtva? r4315) EA .r I an. 23:1? .0 a a .7. ?n .3. 81w. :El MR my?? 93 .23.. .vm WinLP. ?Ncu: Case 18-2868, Document 278, 08/09/2019, 2628230, f; '13 A I v) >922?- nrn?rmr? WE Xr? 3394:? i .0 .mk/ . 5a 2.3 23033.? 328 5 :6 a: 63.wLniub? F. ?8fo . m5 3 Page408 of 648 mir' a. 43.. Case 18-2868, Document 278, 08/09/2019, 2628230, Page409 Of 648 . Q. (7 5.339 rm . - I wave-we ?Mm 4? [47 km," jag; W2 1 'Gmlmunclmuuoow?qenam :07; mm c197 'er wa 3 TH 7. H0 N'wa'g?o' max gel 103? .. 32;, 1c; -071 - . max 103 m; Q. i I am i911: gyi' 71 L3 90f]? 2 433. f? 90:33:12101! )(Oj 9971,, - 1-97 WN W712 306 .x [?22 AW jg _u - 15?? ?0 . . 2.2231222233224va 50's 0172 c; {a (49 $ij $310023 Sgt: 0 Irate H8 WN 32$ ?21 ?3:214 ?8 '9 H9 8932 1931 .. 5,7; :1 H0 1,102 0:1 I .. 2; cmuw?u? .. .jgf?ji; 1703??- 2:5 610000-80 mmaamm?? . 1 04:39: ?Si? ?3 . 23771:] 27" "Of 1 ?3 213,90 "-75:52? gm 691 29:1, ?m . A 093: m?WbH?v 23;, Wismwm A, ., - 30-2 35?? f? ?Medusa ?"341 w?qum'n'N I 33:1 unplviaumudquo ?mod: "mifgg?? $43332 if: a: 9 Sale Almra? Make Altman Paint! a! Dapa?uro I. al M'l I'll '3 A I an! Modal demi?mhon Mavk Kai.i I Number tun-'9' I To II Alter-ll 0a! 0 MIu/uuvorg IEndonuuonta mummy; ammw (Janna! Ha. V?l?l-a (Ir-72:: 10:3qum: Mie- jib/?8? 32.911? 'Tfm? QMNM LV 1' . . - L196 AM 33 [Tag (5CD 1m SK SH - IBHJQ 214 .1, 6:3 sewon?uiuc. . . ITIJT . 18(9?5 . Ir. It) 3 2.2: 1 A (.IMBH Nana MM SKmumnoQ V1 Ith .NM. SK 1.1 ?519 was? JLAAM NM Er 3 4?56? my?) 184 *3 AM NM 1 ?54-111 ban-Lt . I I i Zr): . A TLDT NM ?3 1m! 3 '669_ 2 [3639 0620 has 0va 'anlrx 3? NFIDENTIAL i L, A OCN (569 m; GM . 6L0 ng_, 1037 OB '3 ?gs-19.14313 J?i ?7)?sz '31]@2253 Um? 3 'ccni?y Iha: :?uu staIiemenls Paaebymc on VHS lam arolmu Wilma! 15/1ij ll A 1 091.: . moun rarwa'd I l?lbfs Signalue (Ltd gin" A 9'14, I I, LEM (l?c?fab?) Total to Onto '1 LL L?At?oo 13m ?74 m'vc Case 18-2868, Document 278, Page410 of 648 ?vi- 3 4% Data Aircraft ?rm" I Polnll 0! Departure I. Amnl Miles F15: ZN, . 3h! Rum-r uProcedurc .9 and Mode! Ideml'lcanon ManMonti?? ?nder-1:91:13 ?nalizing ?mm" (30:090" 7? 4 ., (54-152 ?5 1. mm?! :Mu cl-:qu 163-3 y??i?Tx?x? T6413 Mu? AM Wk? sv'M 5 3g i 9&0 .LV. V, '8 D. - Wm much W, masxs-owm'z. W: m, 1 o; CONFIDENTIAL 1 I: (.va L3L. 15:: Lv '2 '4 9L0 T98 Li?. L1 1W war 1 ?2:3 t??x 7) lbi 5? ??90 I 7:31:35? Sij'f?o (a Tmm.? TI 3? 2?35 mi: N: 3% 10, 2.. '1?ch 336 Lxe?g? htgl?h'dmixzi?: (CHI): 44 3 3?141335?1 P: N?susc 12:8 Baa: :euq ?mmwn 4 A 0, 9&0 NM 35?? \l 33433?9wa EQLW 0 3:7?:qu 2 oft?PIP anoiwLmuom Wiggly ll - . I: I 7? mam58:00 T157 39-; 56M mm?: 44st svmheitsi-V . 0 3:53 312st: ISL VV 8 MD 2535)? . \l ?93 scam? . I ce?ify Ira! the slatemorls made by on this [am an lruo. Pam Total 1/{1 551 I. (FA -: A100ntl-ommd ?3 1.1., Plot's Sinnanmx GL1 7&3" A LA. Tau! Data [6931 ?7.4' . . mm?: Irma Case 18-2868, Document 278, 08/09/2019, 2628230, Page411 of 648 Case 18-2868, Document 278, 08/09/2019, 2628230, Page412 of 648 is I, 2: 1mqu bm?l (C, 901363) WI 0E ?73 ?-my=nmu7 20124 177%? L. 9W93rl7?r) nnumjwz Lib-I 913%er 50'? ?r11 7?5- .- 49? wN? I. Ls?vl Wm?i?fuwv 711$ 12% '33, ?29" .63. 191? 7Q Rue-9 "meo??azg 1M6 I VJ WW 2010on "a '1?me 0N Wd ?sunpaoou ?9qu #5115 3mm @mxu?0pm mueumulu ow magmaRETQF mag wen Input 1 emu-doc )0 "de 1.2mm SUOHOHJISUI .1 I Date 1 Aircraft Make Aircran Polatsofoopmun 0. Arrival M993 Remarks, Precaml. oN?urnhre' I Alrcun 49? 1 and Mode lden?l?calor? Marx . ?own No. Maneuvers, Mun-en's .. i Frorr To . . . . ?Ef?gy; - 174?6 TLSJ . Egghb?ms? \156-?127419 1?53? 1 3?1, 3.5?5? TSFK Ben ?ff-3T 737191105" .r 25 ?g ?407 6P ?gwgf313?)?1311 Ba - 27: ?8 . 1731? ?mama9:8 ki?se??ym?mww?n 1 LV . .. T1251 i -. . 20 (b-?l?Fsm N?ioare d) - 'zumWiW?vaEv-L .. t'wMtECW--nm0wm I - -: tm ~r?r .- a .. mwewmww VB ?-sawm?, in H, ecew .n r?j't??hm r'rtorr'm Db 4p--mm?r?c?r?w?5 I unity that the armaments made by me on (N5 than are ?ue. I page Tcta? I Amoml Forward $32? (LVN: lc? Qq . 3 El Pilot?s Sigm?urw_ Toll '0 so ?32 c? A Case 18-2868, Document 278, 08/09/2019, 2628230, Page413 of 648 squmsu; I On: 1 Air-rah Mew: Maw Palm; 01 Manor. I. Arrival Mllas Fight Remarks, Procoduna, I Number Aim-n and Mom Maw F:own No. ?Maneuvers. Endonmolls "(Innings rm re 9mm gamma? - 33;; Ewan-am Naome EGGW gigs-8521, JFK 38: 'JeiastKf?f?msmT??E 3, mica-?sac, acme PM 1:55 gimg??mmom $3 313" Ewe '3 - . TAG: EQGW mm {?wwth? I _n .. ?ggew Leis-6;" m1 GM ~25: p.615 me GM L1 1 . EGGWJ 3W V1 UT ?11586. Ht? GM NEIDEN 2% -W 699? l?b} 30?, ,l i0 In 126993 (1?qu we!? T. . 41 Cjax_ How GM 3Wl\ 1 27: EM Mm saaw?m??1.ng 3?1?l #5319 Case 18-2868, Document 278, 08/09/2019, 2628230, Page414 of 648 wromwr TLST VQQ a I it}: . TIST qos?mxgz?uijgi 1223.). my?, cmwmTE: ?401338 .3 I certify that lhe swtumorls made by mo on form are lm. 3? Paga Tow] l1- $7 Amoum reward eggs-Bu ?g Oogt Pilot's a?QZl g3 ?Dlobl kn Lag-?2008433 oLn V3 3,3 3 3 ci Aircraft Make and Mode! Nrcm?t Mat Points 0! Demure I, Arrival Rom From I To Flight ND. "marks, Procedura. Maneuvers. Endorsements N-ere: an?ngs Abate" ?wmm (,qu (3-1136! 3 #8360 was GM TCB ?1.51 \l . A4K6U9, 69' 5436mm MnmxudeR L97 0R DFW c? new I. khg?l - magi-1: .Jm?ui?i?bft 3Q. WV ?Wvagus 3:2 Lam: cal-law Magma LU Mum 69? meaE??-m?w tww:. Grog: 2 nix, ?mam ALL O?mci 2' 92? meg, g?w 610835 . ?wrg ?892 lid, Lice Hwi?j?wmz?an Km?: 9 Marten?z?). ?pvr?fsrx I on Monumw?v' 61161-4212, 5K IWMW Kb ?(aims 621% 1. NM Ive. ?moo ?7%!th 1 $9 - @x 1 Xmoncm FXE ?10 66V Alt/L 2211?? ?3010 117-1? _sm MILR JOE 5? [5 LM LV Tol?d?f?m- 3 . (?Aon chi) 7523?. NWFJ WED-CAM Wilm- LB i \b (3-0586 'N'?oqszc? 115T 858%??71m 6WD 213/1! ?yaw - galQueen.? mg cm; WM) L??aun-r 1091 ,mm 635mm Ncib?bj?lTIST 6 Hamid M79195 3%ng oars-M0; 30ml h??al-J?bb )3 I comfy ma! ma ?moments made by me on 1011! are twole?s Sgnamo 4/ W49 Lawn (ucMDr Pug:- Tctal Amour? Forward Yotal In Date v, a Case 18-2868, Document 278, 08/09/2019, 2628230, Page415 of 648 Case 18-2868, Document 278, 08/09/2019, 2628230, Page416 of 648 suonannsu. Aircra? Make Aircraft I Points of Departure Arrival M?os Film? Rom-rim. Procodlves. Numb; . Alva-n Canaan-u and Model Idelca?m Mark Flown No. Mnmuvors. Endorsements ul Lar 1&51 am. To (,qu 3 a: Exam-mn- mmze Ew? 13:31? J13 3331'- 3 3 Us 65;? 0183,5531 We g, 3 4g ewe QEJKWMISK - . 25?95- 5 20 . ewe LFPB fa? ?3.st L- (9 2? I - 5:2" - 2L EUDM - I I .27 LFPB ?133? 7 i EWR . ?Kw-5'11 wagceua 3 $1591on ?my, as) 0; Lg; Li_ . NOLOBIC: ms'r. msg??mwm i I E11 735530 Lg 21> 1418 Lava ?f 0 Ci 5 20 Euscxs . 31$? L?m?l? 51mu?? Qu-u?m M318 1 lwftify lhut lhe made by me on this am nun. 4300] S. 2' iL 63911 Ligatm? Page Total Annunl Fnrward_ bags-S ?3&3 _Toln? 03!. N?rl (0 fl (W Mm Fun: 5 sgnatva Case 18-2868, Document 278, 08/09/2019, 2628230, Page417 of 648 A SUOQLOHJJSUI - I h- Alma Make New? Polnts ol Dopartura 3. Arrival Miles Flight Roman?, Procedures. :qu?g'?rgs About! I navy a - and Mom-l qummunmn Mam Flown No Hangman. Endorsements 1 Gum,?- Clm?} 010%:igw??) 2c~00) 2.0 PHL Zw? L135 5 2 8w 556-0536 WEI Nqome 7 ?wR T1327 6?115?6 gig? pew 15* or ngq?Wg?mlbj?l??"? {:31 I Ban-m N51093: 'Ew? B'Eb?l 9?QUHUL PET.160 psi 9"ng 2?53?? wt.? "pt; Gbxog??mm?fmppown?ow pawu?h?}Mwb ?r '5 PSI f?oux-a, maniamwwuzaw VB A?ing?mf (betc-o'mm ?5 . 6 eye??(307211?- 573?1754 . . BI ?fixmga - - .- 13W anng??j aegis?0' 5 am. 5611wa ?magic, ?Cu :b New!? that the made by me on this fun are me P?go TotaAnoum Forward bitm? Piiot?s SigumeMM 71L, than u? Data E?h? ?01cc 6 27' G- I Gil mm . ?53.02? 4 ea Case 18-2868, Document 278, 08/09/2019, 2628230, Page418 of 648 ?og?:1 Airman Make ?43- nv Model Aircra? Point: at Departure 0. Arrival Muss Fug" Prue-dams. Numbe! I Alvcm? Mmunuauun Flown Nn. Maneuvers, Endorsements 0' Landings From To A (#1th 54,-93 m7 ETD #561147? 3241, rx \0 T1 13241.0, 17 Fnocc TIMI, 51?? rink?p Simuugya: 6 (7 0 1? $14?ch {52px; p?i Pb; law!) w>c1 vow/1., o. 10L, scum-.0 9,1sz 3' ?1?:er HRH, 2.3 Ji?jg?m?mwse ewfl T251 9 111.76 aw U4 m. TOanofm 9139595? Eu; i Fri: TIST I451 ?33) LVI ?15 JUL ?l CMH 4cw,_ 953 0 . '23? 01 T1337 us-u 20 \l .o 43163.15? 97K we 4 LV Vi LL15 12-11-332. 21?, I Maggi?:33 Hep EL y, __d3 -. GWK 11:11 1m. .ti 1461 '23 (571m T. Pr My!) Redmur 020 Do :55: WE Rf?Jf' Pa r-c Mf?r NY-Q ?neg. Us?) :55 6094.50?: N80613: imqo BB Mint Wu 8% 7M ?an-m? 1 09.32, mm- ewra .ch comfy lhal the statements made by me on 1H3 form are true. Pilot?s Slmalug? 2 "ago Tom! 5 chOPI-?Jxo Fulwuld 68"? 3 5 4? Told [0 on. ?0qu tang I ?5 3 Case 18-2868, Document 278, 08/09/2019, 2628230, Page419 of 648 IJISUI Alford" Make Aircraft Points 0! Doparlm a. M?es Fllg?lf Rom-7kg. hocaduns. {fullba'n 3 Iliad! 2.21:1 and Mod?? mewmlmuon Mam Flown Na. ?Munro's. IndoMOII-nb (L nd :1 An?p?m ??z?l?-quj \3 B-?mxbm N40811: Ewe N5 e-nsms meagre MWL 16 Gav?ma meme Ewrc__ Jk _ij HBQ 2t 0862 mm - N19 1:51.. 27 Tm- awe. 2a (fume) Nth-?g: P811 ., '30 ll T66 ,x 30 pr'a Sir Bart-3i 1% Moqx? '50 (3.7213119. it i423. LV ow 3 at? 3 (IMAM Wits LV 4L LU '41) 143:? 4 Lv 91% 31+ ?gfm LDU ?quqsc? 1 mu m; Q. I 00"in that the slalcmoms made by mm on his [arm on: "us Page A, I Amoum Forward $8le 2 [p.138 @ch 6881 i 61 6 Pllot's Signature {LPHL \Qx? Case 18-2868, Document 278, 08/09/2019, 2628230, Page420 of 648 Dan Alucwn Mmu 1 Alma" Points 0! Departure 8. amnl Mules H}g?1t PWHMI, Number and Model Mark Flown No. Maneuvers, Endorsements Lusdings 2 co? I-rom a? Emu. GLUEK ,3 Crus?t? ,Nq acme 860 ?51' 2.5 i mwuwrm - gw?m __Ew_r_L {gig N?qcu? 1151? 16?6 -- T151 1131 ?50 . 2 L1. 860 163: i a 33:1: - 1g, 1151 ?,1?b3 DFWW ?in?ows chm?, 1 Alva-? Wt? {Jami-P} L. 0:035 2. V'm In V) m\ I all .?Ql may? carp-7W" .1 . - . 1 Bacvgf?gzg?n Ln?slzm (M - -3. 2.: 2 . Wee?) ?nally- (new 6 thocixc: ,T?s?i 166 141.- LV .3, 04,165 PWM m) V3 - (5&0 Wm LV . . 6&0 3cm9.9, 18 A TLST PEI .432army that the slatemenls media by the on Iris ton-n are true I Page Tou? Pilot'u Slgnalum l' Total to 688?. Iogginc, es em 3115qu sunnonnsul Aircraft Mano Ammll Palms of banana" 8. Arrival Moe ?ight Remarks. Procedures, I Number Alrcm? .19.- and Mode! Irlenli?callon Nam NO Mancunian, Endusenlauln olln'lr?np; 2922?, Path To ?kw; ?memjx: (give; 224 64545 N??xe Tag &m g? _gy_a 39w J69 1.1.5? ma? ,3 EMMA) - ?9 577-71?? J4 I 13?; A see Etc-?64?! cm?; '3 n?za~n~ c. [e - L: ?ma -L?ch 7? I - E?h?-ff?a ?Ezi?g?gew um "71-5. - f: ?of - 3 Euj??cgng?cgmen-cri?w 29 6415016 MM .6192 3?13 4? .. .. ?rxsy?jut?rs ms 8 lao? A IL, rApa ma LV 1/ ?5 ., ETAIQ T66 62' \5 Tag) 71267 T66 bCEmma? thoqmc: Vaq I480 3 61061361613 (56.0 2003 m} oeqzry mm me statements made by me on m: (om are true. Page Total 3/q, km Amounl mennl Io?Bgl 3 3 Pilots Slgnalu'a_ (UM. dza?le . ?833; 10.4?) 3 ?63 A hpw-mv-Mwu T?wfnf ??iw I Li gm: Case 18-2868, Document 278, 08/09/2019, 2628230, Page422 of 648 suonomlsul 5' fr? ?ml Clan ?iwmw 200-9: From To Bx?pw?t (:41ng meme (secBazvbm Nqoax? UQQ LCij tier 7.33. 18 Q??qb?ii? 115T Ewa?o. ?mo LV EWR SSL on LV, ?$7.511 2a 1:4 WET 206 i {45 139$sz LV. 25 34% Maegan Big-L ?Lb 086 L-Vj-b?: A, 26 98f. 2.8 Tiff1:51 T66 2m LV ?5 V) BIND) zeta 6 L4 :N0n? EE .. Emu ILFPB 2; .. we gLLee we Lv 1/ 25 LLBG mam 1cm locum; that the stalemenls made by me or. this form an: me Page Tom n+1} Amounl Forward kw \oqoo - Wk W'm- E333. Mm 1?1 3 4' Case 18-2868, Document 278, 08/09/2019, 2628230, Page423 of 648 Daze Muak Make Aircraft Pohls of Departure 1. Arrival Miss Rom-tn. Fwd-ares, Number Aha-n and Modal Meow-canon Mark Flown No. Maneuvers, Endarumonu oi Lanaungs 1966 From To 918% Gum?s-IL ?10% 645% Nc?he 20 LFWS 261 arr 2? 7<__71u 225.18%qu Lg:- . 2L L55 yt?sg?c' . G-usab macaqg 1:31 263:: 1:3 ?5 2.51 {5:127:53}; 983 G-nsm (09106138 Tee .. Mw_ Bean $487214le NQQ um m? usae Noloqr?_j?t31 Eco m?m ONFI 4 ?r?w I .. on ?res 6g 33? 15:17.1st Nof?oeut was? M129 MEH- 17 w?r? A. ML, ustmc z, 645% PB): 20% LV 0 4, 1? new} LV 3 2'1 56F 1?95: LV '29. 0 sec, #4 LV Ioen'tythatthesule-ums areUue. PageTotal <5 3Q, baa; Amount Fonvard QQOL PJot's Slew-18mm ??icb?d?i lo Duo ?9 QC. dirk: - 3151315?: 881631) 2m," 83?31 33x13 tr? 3 3 0? Case 18-2868, Document 278, 08/09/2019, 2628230, Page424 of 648 suononnsu; Date Alma?! Make I Mean Points 0! Dopanuro 8 Arrival Mass Remarks, Procoduns, Number Aircraft 49__ and Mooel lamli'lmtvon Mark Flown No. Maneuvers. Endorsemenh 0? 2503 To Quit-{2. 0?1214!? NESJG LCQ . - - Slim 'teAL-v LN. 0mm ?5616 OFW 04W Magi?3973:1594?: dafcquchc-uJy (j . ?we 92. new Lny?'p?d?. seTLs 4. cc??ww, 4L1 mo "5 mo? 6?727'20u Hm L?ro?~3mucm EA :4 90?an 689291cnmnaw wax/?w TV- A -. - Hum? pmamw. Ln; ?4 7N a. :5 cemnnu I?c- way nmeznm; LV - - LAM age?12331.4 megs LCQTAMVAL Lam .1 g-nsm. N80437: PMA ?9?wa awe . w? 7 mvw', PB: 1% arm?302 mom-e: (3813:" Pa; nag, 3? 31%" 2650; 8' A931: P91: 4 Lv 5% G?z?I?m Striuw??t Mm: mgr.) 1 V, 2g. Hm? (arm-MB meme, EAL ng. tn - Mme Hz): 861 As; .A 961: T5 39%! LV 6 was 931: Page rotal 2/9. A HZ ?momrroryng_ 22,:q norm. 33113 2214?? 8 Plot's Slgna?um Tolfllo Dan latt?? ajy?ls 3 009101 1 Grooms?i IT riff/71 ,1 I O??lVl lcer1ily Ihat [ho slalomems made by me on this form ane1rue, kno??aba?ranVerMvg?oo A?g 1 col ,an Case 18-2868, Document 278, 08/09/2019, 2628230, Page425 of 648 . [ban ??"93 I Flight a BI 8rd MUSE . VI 1 . emu I, I: Fian No, I?$31t2. ?In; it": Ii:_ 4 anc- Aime" Mam Aircraft Pohls oi Departure I: Arrival Mlle: Fligth as, and Mom launu?canm Marx Flown Na. 10 10? I From I T?o A?lcran Ammw am 9&1- 'nl 7. 26" Iv? Jun-m? . - Nd 5I 31' 8?727 1w spam?m 11/129: \l vomrm M738 (112mm 3 32312;? N53061: P61 p?kg 30m) (20663:; G- Homage 8:6; TTEB ?i 3 LV LV 7 1 laxantr?: 4 j~ol~?L Pl! m! a 88 538w 5 \4 . T66 Pm? I .6017,ch Mia M19 kiwi 99mm Martin; that the statement: made by mat on Hl?s aid hue. I pay cTo-(mil (wand .D .9 I ?0 Mom fa?d In Date Case 18-2868, Document 278, 08/09/2019, 2628230, Page426 of 648 Date Make Aircraft Points 0! Manure I. Arrival Reno-ks, Procedures, Numbev Aircraft 43.; Idenl?mt?on Mam -- Flown N) Maneuvers, Endorsements ulLancinga mum ?Lmb From To 4. 932: 96,: 163+ 23 642546 030336-19; 12:51 ME an 1.5. T3231 6H E1 v.01; WITMFM: -: 5 20 (261' - Tee; E, 1:69 DJ 2/1 9. - 3! <96: 21' T2511 w? - 3? 9.91 16?? LV 2. 95235,, 28 1?92- 3 Tam" e61: um - o, pg); 1022 - TIST PB), 1015 LN ?Ji 9-2963: LV .- T155 61Case 18-2868, Document 278, 08/09/2019, 2628230, Page427 of 648 L2 Emaigv? z?i any-7.00 $1220an mm ?9 BA VB: 1132" m, Ly 2~ TEST . 54o; ESL so 25 (?61 mm mot LV 2 Icon'ty 1halthe stalamem: made by no on [turn me two. Page Total 36/ ?0 ?6 . . Anna-f {onward pun-s sma'ua 2 4 I 5a Total to Dalknot??Nahum .. Case 18-2868, Document 278, 08/09/2019, 2628230, Page428 of 648 . fur?op?f-ng?ri??U?JW6? 3 Mann Make Amen Points of Depanun A Arrivd Miles ?In" Roman: my 3, Proceduno Number and Mme] identification Mark Flown No. Man-wars. Endorsenzerns (y ran" an" Gum l??ummMame .12. Lv 4:4 3 . .. ?mum-?u! a. ?9 LV 2 'LFeb 9:393 2V ml CYQK .. 2113?: tree max 92319 . .H mm 8661:? .3 "1.2an . Lv T63487151' 59??0 I ma LV 3 4833 .. -. 2?14 3 -113; VHS: I . 1165? :20 LV 2L 3 T55 ?66? in? om?m'eo ?o numumxe LV A 7?7 ?92? WM 2.8 LV ,3 a? EGGW LFee - .3, \1 . L??s 566W 1?13 T6 E: (56? *Ef: 666w BG-R 1632mm? 98 ,q eon T66 8.me 54w A i (:6me thal the slate/manta made by mo on his form are true . - . Pam Tnlal 8] I 6] P1tm's Stonnh'a 2 0 swd?g? 3?1 Amuuql Forwanl 4.525 Tot-l Io Dal. ?x 09?, . . . .. .. .. . sm;g;oru;sul 1 a Rural Make Meta?! Points of Departure 8. Arrival Fug Remarks, choduron, Mmeer Alien? and Model ldonh'mllm Mam Na. Manman, SMonomonh oi . From . gm)? 670586 Nqocxx?.? 43;? 4. 3:5? 8~m~3m Nqoasz PSI 106): Ix.-6' 313+ \7 ale 9:1 may.) . LN 2? 6:162_ (.95 4 mm . CPS T66 ?66-..m'owmm$66 39*. 1:51 3,636 LV 4/ E153 4L . . ?1 TISY 261 4 Ag- P672: "29?1'56 *uq L.V sxmvuzm or31;? ?3/3 ?8:366? r?mgr, 3900490) Mowe? ?fys?f . 1N dole) (4 (4?an i4l$ (n <0 .rncr s5? 33 \0 6mm N53590: -961? sow ?mm: \3 6??qu T66 (560 bus . L-V V1 luurl'ly that rho statements made by ma on this tom me two. Page Tolnl . Amoum Forward Slamtum Total to Data qu' ?159 V?v Us a me H.343 2.536 T3398 Case 18-2868, Document 278, 08/09/2019, 2628230, Page429?of 648 suouomvsuu Abram! Make Polo-I: oi non-dun a. Anlval Muss Remarks, Procedures, Numbe! I Allcra? 19?- and Mode! ldond?camon Mark Hem N3. Manouvon, ol Lg?- From panama 9.33 945016 Nqocm?? (sen. 961, am LV \b ?61: 1&5: I a 2 '1 115;, Lg lei?? Zo T151 ml ?61 \t TLSL 20 1.5: (figs: I. Li T68 . .5 21'4?? Li do [78.1? may(:T3257 MDPC. 2453 MORE. 1151? ?as: A 21 Mow. 3455? 4 LV 7 7.8 M0 Pc. TEST {236$ . . I certify that the slatenewts rrade by me on his turn are true. _Pago Tom Amount Forward 2Films a a 55140 . 4 . \s Case 18-2868, Document 278, 08/09/2019, 2628230, Page430 of 648 . . .-.. smnannsul Dale Alrom? Mako Nrcra? Polnu of Dopavtun 0. Arrival . [Miles Fliwl Remarks, Procedures. Numbet Alvaa? 49?4 and Model ksonll?catov?. Mark FSown No. Manouvon. Momma?: oILawdingo 16% From To 6415? M0 vs, ugugam mee .1151 Tea ms: \1 1 :50 &?Ie,c Nizzxa 169:86: Rersmra un?t Tara-Ilwr smuumt- - 2' ee?efmw ?6 I 1 puaegamgsn?mcw W??lsw (a - .srrz two . ?we? a? f??az' g9 emu?; MAL$9Ml= 65 ea (Mack q? 216 baa?mam- moqu 9 61 12??ng 3 '7 (a (9 ?50 Mom 945" l-V \l 168: 1?45 u, ?1493?? 600? UH LV 2o?, 66%: GVHC. ma . LV . 2.0 :6th . S115: T68 L-V fl 51,? Bqum Numam 9612-945- 90; 932%" '?Mmm 8 \l 1?pr ?91??st 26 (??586 11:5: TEES MU: ML '50 was 3: I ?3-30 I certify mm statements made by me on this form are true. Pogo Total W. Amoml ?53* ?61 63 Total to M. titif- 313 r301 Case 18-2868, Document 278, 08/09/2019, 2628230, Page431 of 648 . . a . suouomqsul Condmt C. Date Mme Aircraft Points at Departure Arrival Wes High! lam-nu, Proceduns. Number Aircrall 49.: and Node! h? Mark "own No Maneuvers, Enthusiasm: 01 Landings mu From T3 $2 mat-?z cum-1 ?ti" G?usq macaw: 61 Tet1356-19.12.? 1 Mppy we} <0??me cheat new: n. hang? GROW n. LIL 3691? cyan?? $604" 7.9 i Le . 28 G-us?m N?c?se \?a?ou?mm - 2m} a??xcwm qune may?: 3/3 3 6-123-an 133% LPN 3L3HT4491 Ls: . 0% 3? 1.5: Ls: sill-c: %_g_??a_s_moqwe SWF a? ?53s oani'y that :ha statements made by Ina on "1 510m are true. Page rural q/a Lb Li mm mm- 4? baea . i SI . Tom ?0 Dale . Plot's gnatu'a 0. . . 636?): ?0311 Li 86% 5A5 Case 18-2868, Document 278, 08/09/2019 2628230, Page432 Of 648 SUDIIGHIISUI Data Alrcm? Palm: Dopnrlun I Arrival Mlle: Ham Roman?, Procedmu, Nurrbo' 4.9., an .016 Identi?cation Mark ?own No. Maneuvers, Endouomonn =anan cnry/a; . 2 Nb W3 915:? hi4. ?5 06': EB: Moe!? wig-3111511 4/ 4? 2 1?44} 5-: Li _jfo \l QQ I thoq ng ,Lwa a 3 EMT 17?: 1" 4' 1 2 0139 . ix 4 56 JQLELP. __Gyhc LV _3 1% ma Di .., 7-3 Manon 3; 2H w?mmc ?84; 74 7? 1LL?SiL_51numm_6?W 06W men (In-7?9, woe oz: ?and m% 3 0 02254?:th - ?51? 9 ch?gs?36% mm soul that ?he wade by mo on his form are true 3 go 013! /q NEE Amount Forward 88'9 Tb?! to an. ?2655 - Miilqb gqu R_oog QB 1 I :1 Vivian 1w Ir I i Case 18-2868, Document 27-8, 2628230, Page433 0f?648 . . . .u . {economjsui and Mode! Mcruf? Maks Ailca? Identi?caton Mark Points ol Doparluru 5 Arrival From Mules F?ghl ?nnafks,Pmcadures, Flown No. Maneuvers. ?1160an- Number of Landings Allen? Imam/10 nu. [Mn-11112 ?jg (141536 '50 _moaxe MW \vl T?b 11. O1 3 6:053 NCLOQIE T1254 nice 2 ??97in LS7 Howard; (6?95 mm? ow? 6101191.}. magma? LV Ll \l (>81 \l I 1&6 2? 1, shag TEST '9 LV 1:51 363 1.11% 7.115 1? ~11 mm 7.1% CC 12W game. LV LV, 550 in 0913? F1. IABQ 21 7.7. 119A IP19 LU {1 981 TS-ST LV LV I the s' ammonia nude by m1 on this tor nn an: true. aunt's Signamregad? i Tot-l lo Dale 6?1 1 Amount Forwam 5 \oan'L molwioldlm (qclcogf; Case 18-2868, Document 2.78, 08/09/2019, 2628230, Page434 of 648 suogotmsu' I bah.- Alucran Maln- m: Mcdol lam?ilcalnnMulk Flown No Maneuver- .Endomm. 2M2 11111 Fa u! Lm wags Numtev I Altman, 2am 2 Akann Point: at Dopulun 1 Annual lMMes Fli ugh! Rem-?u, Pmudurcs, 1 i ?LIZ-us?m Mama 66 ?gg ,5 . JAAL li_ I #18 T?sn Aug067'- LV ll 1351-? @1?3/7?Ui?gg. 7 ?9 6_ 1230. LL. :3 24-6-7273)! ?30? EEG thupun to 4&6? 5? 05% Nqoqsc Tee 241;; I. r'i?u" ?1 .6 qm-lcob @0me A29 .62 ?6 Fe 6 .mm?mm?i'v - l2 - ale-"u W. . 1 9.13951pr 5.25;: ping I 0.6?qu u! if ".4922:Mjw 156 E31 LV . Flyw? ?685 553 A 7 3.: 5695 sou .: ii same sob jl'v'uf<4de co .9 I Pilo?s Case 18-2868, Document 278, 08/09/2019, 2628230, Page435 of 648 . . Aircraft Makn and Mode! . Points oi Dopamlro l. Arrival Honln?muou Mm me !Tu Flown No Hon-mks, Mcedmea, Ilanouuavn. Elmer-9mm?! Numbev my 8 721-3 UFW Mom's L961 4 [4 95?, SI .AUan G?ns? [00LVA P?s: LV H.692 T66 m: LV L53 DJ: T68 ?31:5r .132er :36 Nder#mdim .4 ?rec @56- ?ne TUL- 30 TPE VNY TED ?1 1151 WW n? Tea A. 96? 2.1% Immly mm the statements rrade by me on this form are we. Plot?s Slgratal?m Page Tols. Annum Forward Total to but. no'mc?fmr?m's Case 18-2868, Document 278, Page436 Gf648~ {1 Aivcva? Make 0rd Modal Identi?cation Mark Poll-Ii: 0! Departure I. Arrival Fugm Flown No. me - To Remarks. Number Maneuvers. Endorsements a! Landings Aileen? 3 MN v; N?b?ia?e f6)? 1322)? 2:16 LN on 1w 2. yr azi__ l\ usf n59 :59 3'1256 ?33 Rad LXZL 2?4 3 31151 Tiff! j; w' 32' LFVB LFPB ?mc' :34 m. 29:21 i TisTf ?a 7333- THT sut- 13.97 uu? 1:151?- AIBM?yggk 36L o?u?o rear; mienQua L85 .916] _E*6x2 ?l ASE. \l A56: SGT: Flint: Sinnelure that the slaleneMS made by me on [Na lovm a'e lrue. Page Total ddrwiJ?? Am"! Forward Total to up? 3?03- NM Hencn 1.04 Case 18-2868, Document 278, 08/09/2019, 2628230, Page438 of 648 EXHIBIT CC Case 18-2868, Document 278, 08/09/2019, 2628230, Page439 of 648 Confidential Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 3, 2016 9:07 a.m. C O N F I D E N T I A L Deposition of DAVID RODGERS, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 18-2868, Document 278, 08/09/2019, 2628230, Page440 of 648 Confidential Page 2 2 3 A P P E A R A N C E S: 4 BOIES SCHILLER & FLEXNER, LLP Attorneys for Plaintiff 401 East Las Olas Boulevard Fort Lauderdale, Florida 33301 BY: BRADLEY EDWARDS, ESQ. 5 6 7 8 9 10 HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant 150 East 10th Avenue Denver, Colorado 80203 BY: JEFFREY PAGLIUCA, ESQ. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALSO PRESENT: Sandy Perkins, Paralegal Boies Schiller & Flexner Ryan Kick, Videographer Case 18-2868, Document 278, 08/09/2019, 2628230, Page441 of 648 Confidential Page 3 2 3 4 5 I N D E X Examination by Mr. Edwards .................... 5 Examination by Mr. Pagliuca .................... 209 Further Examination by Mr. Edwards ............. 217 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 E X H I B I T S Deposition Exhibit 1 ........................... Flight logs 6 Deposition Exhibit 2 ........................... Photo 77 Deposition Exhibit 3 ........................... Photo 84 Deposition Exhibit 4 ........................... Photo 85 Deposition Exhibit 5 ........................... Photo 86 Deposition Exhibit 6 ........................... Photo 87 Deposition Exhibit 7 ........................... Photo 88 Deposition Exhibit 8 ........................... 203 Confidential list Deposition Exhibit 9 ........................... 216 Equus Global Aviation offering Case 18-2868, Document 278, 08/09/2019, 2628230, Page442 of 648 Confidential Page 6 1 DAVID RODGERS 2 A. Yes. 3 Q. Can you -- can you tell me -- I have been 4 provided by your attorney a -- what has been 5 represented to be a copy, a direct copy of that 6 logbook. 7 Plaintiff's 1. 8 is an accurate copy of the original logbook that you 9 brought to your deposition today. 10 A. 11 12 13 14 And I'm going to mark this as I just want you to confirm that this Yes. MR. REINHART: Let him show it to you. BY MR. EDWARDS: Q. There you go. (The referred-to document was marked by 15 the court reporter for Identification as 16 Deposition Exhibit 1.) 17 MR. REINHART: It is not a copy of the 18 entire book. 19 covered by the subpoena. 20 clear the book covers the time period outside 21 the subpoena. 22 23 24 25 It is the time period that was MR. EDWARDS: Okay. I just want to make I will let him clarify that, of course, too. THE WITNESS: Yes. It is logbook. not 40 years, but it is my logbook. It is Case 18-2868, Document 278, 08/09/2019, 2628230, Page443 of 648 Confidential Page 7 1 2 DAVID RODGERS BY MR. EDWARDS: 3 4 Q. Okay. You can keep this -- that down there -- 5 A. Okay. 6 Q. -- so we can keep track of the exhibits. 7 A. Okay. 8 Q. So does the copy that you just went 9 through, is that an exact copy of the original 10 logbook from the November 1995 date through, it 11 looks like, September 2013? 12 A. Yes. 13 Q. Okay. 14 17 18 And what is this book? A. It is called the standard pilot master Q. All right. log. And who made the various entries in the book? 19 A. I did. 20 Q. When did you make -- 21 22 MR. PAGLIUCA: Brad, can you hang on for one second. 23 MR. EDWARDS: 24 MR. PAGLIUCA: 25 What do you call the book? 15 16 That period of time? thought. Sure. You said September 2013, I Case 18-2868, Document 278, 08/09/2019, 2628230, Page444 of 648 Confidential Page 8 1 DAVID RODGERS 2 3 MR. EDWARDS: last page. 4 5 MR. PAGLIUCA: MR. REINHART: There's 108 pages to the exhibit. 8 9 My last page is 2008 on this copy, 093 Bates label. 6 7 That is what I have on the MR. PAGLIUCA: pages. 10 I'm missing the last 8 That is why. MS. PERKINS: Do you want the last copy? 11 What is your last page? 12 MR. PAGLIUCA: 13 Ninety-three is my last page. 14 That is why I only go through '08. 15 MS. PERKINS: So I will give you my '94 to 16 the end. That should give you a complete. 17 you're looking -- which one are you looking at, 18 the new one or the old one? 19 MR. EDWARDS: 20 MR. PAGLIUCA: 21 MR. EDWARDS: 22 MR. PAGLIUCA: 23 Oh, The one through '08. Okay. Okay. Are you ready, Jeff? Yes. BY MR. EDWARDS: 24 Q. When did you make each individual entry? 25 A. It could have been on that date that it Case 18-2868, Document 278, 08/09/2019, 2628230, Page445 of 648 Confidential Page 9 1 DAVID RODGERS 2 says. 3 Most likely, fairly close to that date. 4 5 6 7 8 9 10 It could have been possibly a later date. Q. Okay. How did you make sure that the log entries that you were creating were accurate? A. Well, people get on the airplane and I see who the people are, and I put them down there. Q. Okay. So you are making the notation at or around the time that you are making this observation -- the observations? 11 A. Correct. 12 Q. And you are recording the data accurately 13 in your logbook? 14 A. As accurately as I can. 15 Q. Okay. 16 A. Yes. 17 Q. Can we just look at the first page of the 18 exhibit? 19 A. Uh-huh. 20 Q. And if you could walk me through, let's 21 just take the first line. 22 A. Uh-huh. 23 Q. In the top left corner, there is a date. 24 A. Correct. 25 Q. And it says, "NOV '95." Is that you Case 18-2868, Document 278, 08/09/2019, 2628230, Page446 of 648 Confidential Page 10 1 2 DAVID RODGERS indicating that this is November 1995? 3 A. Yes. 4 Q. Okay. And the first line under that in 5 the date column says 17. 6 1995? Is that November 17th, 7 A. Yes. 8 Q. Is that a notation that you would have 9 made on November 17th, 1995? 10 A. Yes. 11 Q. And the next column over under "aircraft 12 make and model," there is a number there. 13 that number? 14 A. 15 16 17 18 19 20 21 22 That's the model of aircraft we're flying. It's a G-1159B. Q. What is Okay. It is Gulfstream, II-B aircraft. And then the next column over, aircraft identification mark? A. It is the registration number of the aircraft. Q. And what is the registration number? What does that mean? A. The number that is on the side of every 23 aircraft to identify what country it is from and 24 what particular airplane it is in that country. 25 N means United States. The Case 18-2868, Document 278, 08/09/2019, 2628230, Page447 of 648 Confidential Page 11 1 DAVID RODGERS 2 Q. And is that number unique to the aircraft? 3 A. Yes. 4 Q. So there is no other aircraft at the same 5 time bearing the identification number in N908JE? 6 A. That's correct. 7 Q. Who picks the identification number? 8 I understand N means United States. 9 A. Right. 10 Q. Who picks the 908JE? 11 A. It depends -- some aircraft, I mean, when 12 you get them, they already have the number on there, 13 and so that would be one way. 14 manufacturer puts them on there. 15 16 17 Sometimes the You can also request a certain number, if you so chose to do so. Q. Okay. The particular air -- these 18 particular logs were produced in a -- as a 19 consequence of a subpoena issued in the case of 20 Virginia Roberts Giuffre versus Ghislaine Maxwell. 21 A. Uh-huh. 22 Q. Is that your understanding? 23 A. Yes. 24 Q. And the period of time that we were 25 produced -- I understand you have flown for 40 Case 18-2868, Document 278, 08/09/2019, 2628230, Page448 of 648 Confidential Page 12 1 DAVID RODGERS 2 years. The period of time -- or that is evidenced 3 by this logbook is '95 through 2013. 4 Why was it that period of time that was 5 chosen? 6 A. 7 8 9 Because that is what the subpoena requested. Q. Okay. Is that when you started flying for Jeffrey Epstein? 10 A. No. 11 Q. When did you start flying for Jeffrey 12 Epstein? 13 A. July of 1991. 14 Q. Okay. 15 Do you have available today the entries going back as far as July 1991? 16 A. I don't know. 17 Q. Okay. 18 A. No. 19 Q. Okay. 20 I have to look and see. Because this is from 7/28 of '94. So that particular logbook begins July 28th, 1994? 21 A. Yes. 22 Q. And were you privately flying for Jeffrey 23 Epstein on November 17th, 1995? 24 A. Yes. 25 Q. And is that Gulfstream that you described Case 18-2868, Document 278, 08/09/2019, 2628230, Page449 of 648 Confidential Page 13 1 2 3 DAVID RODGERS a Jeffrey Epstein owned or controlled airplane? A. 4 5 6 It was -- let me think. This was 908 Juliet, Echo -- I believe it was owned by Hyperion Air, Inc., I believe. Q. And is Hyperion Air, to your 7 understanding, a company associated with Jeffrey 8 Epstein? 9 10 A. As far as I know. I mean, I would assume so, but -- 11 Q. Was Jeffrey Epstein your primary 12 passenger -- 13 A. Yes. 14 Q. -- on that airplane? 15 A. Yes. 16 Q. And who was the individual that gave you 17 direction as to what passengers to let on and off 18 the airplane and where to fly, et cetera? 19 A. Well, Jeffrey was usually -- I mean, 20 almost always on the airplane, unless we were going 21 to maintenance. 22 have the people with him. 23 Q. Okay. And so when he got there, he would So going back to the aircraft 24 identification mark, 908JE, does the JE signify the 25 initials of Jeffrey Epstein? Case 18-2868, Document 278, 08/09/2019, 2628230, Page450 of 648 Confidential Page 14 1 DAVID RODGERS 2 A. I would assume so. 3 Q. Okay. 4 A. But technically they are actually the 5 phonetic letters that we use. 6 Juliet echo; it is not Jeffrey Epstein. 7 radio phraseology, we don't answer Jeffrey Epstein; 8 we answer Juliet. 9 10 Q. Okay. But technically it is As far as But the JE doesn't signify some jurisdictional code? 11 A. No. 12 Q. It is -- it is chosen by the owner of the 13 aircraft? 14 A. Right. Right. 15 Q. So as his pilot and as Jeffrey Epstein 16 being the main passenger, you have presumed that JE 17 signifies his initials? 18 A. I would assume so. 19 Q. In fact, we will get to it later down the 20 road, but the -- the other plane also bears the 21 ending initials JE; is that right? 22 A. 23 24 25 Yes. And this N number that's on this airplane was eventually switched to another airplane. Q. To the Boeing? Case 18-2868, Document 278, 08/09/2019, 2628230, Page451 of 648 Confidential Page 15 1 DAVID RODGERS 2 A. To the Boeing, correct. 3 Q. Okay. 4 5 So if we go back to this first entry, the next column says, "From CMH." 6 A. Yes. 7 Q. And what is that? 8 A. Columbus, Ohio. 9 Q. That is an airport code? 10 A. Airport identifier. 11 Q. And, again, that airport code is unique to 12 a particular airport? 13 A. Correct. 14 Q. The next is "To PBI"? 15 A. Yes. 16 Q. Where is that? 17 A. West Palm Beach. 18 Q. And flight number? 19 The next column says "Miles Flown." 20 A. Right. 21 Q. That is not something that you log. 22 A. I don't. 23 Q. You kept pretty meticulous logs. 24 25 So the next column is flight log -- or flight number? Case 18-2868, Document 278, 08/09/2019, 2628230, Page452 of 648 Confidential Page 99 1 DAVID RODGERS 2 Q. Okay. 3 A. But I'm not even sure we still had it at 4 this point in time. 5 6 Q. A. 8 10 11 It shows up on the next page. We will get there. 7 9 Yeah. Does it? Okay. So then, yes, the answer is, yeah, we still had the airplane. But we wouldn't have used that. Q. So is there any way of telling how Jeffrey 12 Epstein, Ghislaine Maxwell, Adam Perry Lang, and 13 Virginia were in the Virgin Islands on that, from 14 December 14th, 2000 -- 15 16 17 18 MR. PAGLIUCA: Object to foundation. BY MR. EDWARDS: Q. -- based on your knowledge or your logs or anything else? 19 A. No, I wouldn't have any way of knowing. 20 Q. Okay. 21 A. Because the next flight that they are on 22 was like this Palm Beach one, January 16th. 23 wouldn't have any idea. 24 25 Q. Okay. So I To your knowledge, did Jeffrey Epstein ever fly commercially? Case 18-2868, Document 278, 08/09/2019, 2628230, Page453 of 648 Confidential Page 100 1 DAVID RODGERS 2 A. He probably has. Back then at this time, 3 I'm going to say probably not. 4 has flown commercially. 5 like going to Europe, maybe. 6 Q. Okay. But I know that he But usually that would be January 16th through the 25th, 7 those flights, do you see that block that I'm 8 talking about? 9 A. Yes. 10 Q. Jeffrey Epstein, Ghislaine Maxwell, Emmy 11 Tayler, and then at times Shelly Lewis, do you see 12 that? 13 A. Yes, right. 14 Q. The 25th it lands in Teterboro. And the 15 next day, on the 26th, leaves out of Teterboro with 16 Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and 17 Virginia Roberts. 18 name. This time you wrote the whole 19 A. Right. Right. 20 Q. So when you write the full name, does that 21 signify -- that's when you may have learned her last 22 name? 23 A. Correct. 24 Q. And do you know how she -- how she got up 25 to New Jersey or New York? Case 18-2868, Document 278, 08/09/2019, 2628230, Page454 of 648 Confidential Page 103 1 DAVID RODGERS 2 Boeing? 3 A. Yes. 4 Q. The Boeing, was that previously owned by 5 6 7 The Limited or Les Wexner? A. I'm not sure of the company name, officially. But probably, yes. 8 Q. Some association with him? 9 A. Some association, yes. 10 Q. Do you know who flew the Gulfstream while 11 12 13 14 15 you were doing the simulator? A. Well, it would have been Larry Visoski, I'm not sure who the first officer was. Q. Do you know if any logs were kept of the passengers' names? 16 A. While I was at school? 17 Q. Right, while you were at school. 18 A. There probably were logs, but I don't know 19 20 21 where they are. Q. Have you ever spoken with Larry about whether he kept names of passengers? 22 A. I don't think he does. 23 Q. Do you know where Larry Visoski flew the 24 25 Gulfstream for the month that you were -A. No. Case 18-2868, Document 278, 08/09/2019, 2628230, Page455 of 648 Confidential Page 107 1 DAVID RODGERS 2 different, because one day is the 5th; one day is 3 the 6th. 4 night. 5 the next day. 6 Q. 7 A. Q. Got it. We went from Stephenville to And who were the passengers going to Paris? 12 13 Okay. Paris-Le Bourget. 10 11 And then when we took off, it was, you know, And then where do you go the next day? 8 9 But we landed there like at 11:50 at A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts. 14 Q. And then what's the next flight? 15 A. On the 8th, from Paris to -- I believe 16 that is in Spain. 17 Q. Granada, Spain? 18 A. Granada, Spain. 19 Q. Okay. A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 20 21 Correct. And who are the passengers on that trip? 22 Tayler, Virginia Roberts, Alberto and Linda Pinto, 23 one female, and Ricardo, it looks like Orieta. 24 Q. And then what's the next flight? 25 A. From there to Tangiers. From Granada to Case 18-2868, Document 278, 08/09/2019, 2628230, Page456 of 648 Confidential Page 219 1 DAVID RODGERS 2 CERTIFICATE OF OATH 3 STATE OF FLORIDA ) 4 COUNTY OF MIAMI-DADE ) 5 6 7 8 I, the undersigned authority, certify that DAVID RODGERS personally appeared before me and was duly sworn. WITNESS my hand and official seal this 8th day of June, 2016. 9 Kelli Ann Willis, RPR, CRR Notary Public, State of Florida Commission FF928291, Expires 2-16-20 + + + + + + + + + + + + + + + + + + 10 11 12 CERTIFICATE 13 STATE 14 COUNTY OF MIAMI-DADE ) 15 16 17 18 19 20 21 22 OF FLORIDA ) I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime Reporter do hereby certify that I was authorized to and did stenographically report the foregoing deposition of DAVID RODGERS; that a review of the transcript was not requested; and that the transcript is a true record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 8th day of June, 2016. 23 24 25 KELLI ANN WILLIS, RPR, CRR Case 18-2868, Document 278, 08/09/2019, 2628230, Page457 of 648 EXHIBIT DD INTENTIONALLY LEFT BLANK Case 18-2868, Document 278, 08/09/2019, 2628230, Page458 of 648 EXHIBIT EE Case 18-2868, Document 278, 08/09/2019, 2628230, Page459 of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 1 Time: 8:51:56 Citation Tracking Report Program: CMS307L Case Number . 1-02?009702 Issued By . . KLOEPPING, KURT 6/19/02 13:55 Entry Employee STEPNOWSKI, DOROTHY 6/24/02 13:55 Zone/Division Zone Two (2) (So of Okee/E Wil) District . . . PATROL Street Name . CRESTWOOD BL Last Name . . ROBERTS, VIRGINIA LEE Street Number - RD City . . . . . LOXAHATCHEE, FL 33470 Birth Date . . Oper Lic No. . - Race . . . . . White Sex . . . . . Female I I A I 0 1 Case Number . 1-02?009702 License Number G13BTQ FL Vehicle Year . 1993 Make . . . . . PONTIAC Style . . . . TWO DOOR Color Top . White Color - Bottom White I A I I A I Case Number . 1-02-009702 Citation Number: 97OZBOE5 Statute/Ordin 316.189 REPORT TO BE A TRUE COPY R10 L. BRADSHAW. Case 18-2868, Document 278, 08/09/2019, 2628230, Page460 of 648 EXHIBIT FF . . Case 18-2868, Document 278908109/2019, 2628230, Page461 of 648 0818 Number - PROBABLE CAUSE AF DAVIT - 1. 3. Request for Warrant Juvenile i 2. N. .A. 4 Request lor Copies 1 c__L 1 Agency OHI Number Agency Name ADMIN. Chec Mummy B4 8 3. Msdmenor Ordinance Agency PALM BEACH COUNTY SHERIFFS OFFICE - 0.6; ?.21 -100 Charge Type; 2. Tre?ic Felony 4. Traffic Misdemeanor 6. Other .. Lqu Name (Last. First. Alias Rm Sex MD ip?l?ol?l Mm. t. l)m to Oh Description Charge Description . u.I wg; in?anwd SKID Did l\ Cha Description 641190 Description . Victim's Nam (Last Middle) Race Sex rem I a . - Local Addrm [Sign (City) up ff' Address Source mTLi $5?th ?ght/At web/c, AddwsatName. Street) 7' (Stale) [ZIol PM Occup- I - - . . The undersignedeertilles and man that helshehu just and mem?qounds to believe. end done believe the: the above named Defendant committee the IIowmg violation or law. The Person taken into custody, 1 committed the below acts in my presence. . . was observed old W4 confessed to hat nelshe saw the arrested person commit the belOw acts. admitting to the below facts. was found to have commited the below acts. resulting lrom my. (described) investigation. 0n the of at DAM. PM. (Speci?cally include lacts constituting cause tor arrest.) -r .5. wt: ?Ioh?7l'32?wm? I ?m I 1-. 11:9' I. [-71.7.1.3175 . . . gyrl??ta -I q. i. .ugrg:159-9" turf. a. ?4.517. . . . . . ?5-3CAUSE STIATEMENT - fr"55+33~57: "?92351"; r551 lit, g! (P int-d): if 1?4 63339 5 (E33 117.10) L5. . . WHITE "$76365!? State 111nm? .- YELLOW Adena - PINK Aaencv - . Case 18-286 [Ebocument278108?/109/2019, 2628230, Page462 of 648 - GETS Numbat' - PROBABLE CAUSE AF DAVIT 1. AI- 3. Request to: Warril'tt Juvomlc I I I I I 2. N.T.A. 4. Request for Cantu ORI NumbeI Agency Nm 5 Agency Report Number 5 1 ol 0 1-0. 0. PALM BEACH COUNTY OFFICE L0.6 0-9 ID ll ?low a a. Misdemeanor 5. Ordinance . . . 2. Felony . 4. Traf?c Misdemeanor 6. Other - Namemy p[L . 'tst. Middle). . Alias Race Sax 1 - I) 3 Chugo Description 8 . ?1 Change Oucnpuon VICTIM .F-rst. Mimic] . - - Local?Add ?Swot! A Nu ?pr 221540170 (3%in 8min.? Adare'sg? Name Street) <0 (City) $(Statel (le) Occupalton . The undeIsIQned certilles and Man that rte/she has just and reasonable qounds to believe. and do? not at the above him Dolendant wrangled the foaming violation my i . Thu Potion taken into . I I. i committed the below acts in my presence. - . was obsarved D, {?18m 3/ confessed to at helshe saw the arrested person com "19 acts admitting to the below lacts. as laund to have oommitod the below acts. rasulting from my (described) investlgatlon DAM. [3 PM. (Speci?cally include (acts constitutlhq causonlor arrest.) . - .1.- 0; a It!? {5-9 V: a? a - )t?f-?Pru -. - .Z . 110"." . .-: - A liq-Qt i} 1.5. A Dr J. ?t I l?mm ?31919 am {353m 09 fl ma Am J: .- .L. la- nuk- . athjatm met 1&5?qu I: a A v: I 11' 251-?? 3 . .1. h. goli - 9 RF) NalaPubla ssn: I I 5 I .. ..-. - Com Cnov .. Qtavo I I'm sum A Case 18-28%Document 278,. 08/09/2019, 2628230, Page463 of 648 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA CRIMINAL DIVISION (CGS) STATE OF FLORIDA CASE NO. 02CF012205A02 BOOKING NO. 2002343589 vs. 3 ANTHONY LUIS FIGUEROA, 7'5? . {0 IT: i -41, Li.) ., INFOWOQWGINAI GRAND THEFT In the Name and by Authority of the State of Florida: BARRY E. KRISCHER, State Attorney for the Fi?eenth Judicial Circuit, Palm Beach County, Florida, by and through his undersigned Assistant State Attorney, charges that ANTHONY LUIS ZAC FIGUEROA on or about August 11, 2002, in the County of Palm Beach and State of Florida, did knowingly obtain or use, or endeavor to obtain or use video games of a value of $300.00 or more, which was the prOperty of HOLLYWOOD VIDEO, or any other person not the defendant(s), with the intent to permanently or temporarily deprive HOLLYWOOD VIDEO or any other person not the defendant(s) of the prOperty. or bene?t therefrom or to apprOpriate the property to the use of ANTHONY LUIS ZAC FIGUEROA or to the use of any person not entitled thereto, co trary to Florida Statute 812.0140) and (3 DEG FEL) RICHSYONE FL. BAR NO. 0928933 Assistant State Attorney STATE OF FLORIDA COUNTY OF PALM BEACH Appeared before me, JILL ESTEY RICHSTONE Assistant State Attorney for Palm Beach County, Florida, personally known to me, who, being ?rst duly sworn, says that the allegations as set forth in the foregoing information are based upon facts that have been sworn to as true, and which, if true, would constitute the offense therein charged, that this prosecution is instituted in good fai and certi?es that testi ny under oath has been received from the material witness or witnesses for the a Assistant State Attog?y Sworn to and subscribed to before me 033s day of October, 2002. - STATE OF - PALM BEACH L- r" a; ?sh-39s: i . i the foregoing is- a 3:33: it? i ,9 '2 "megs: glib? igfmd in my of?ce with mm . ?3:3 5 tions. if as req red by 13?: NOTARY PUBLIC, State OfFlonda if A: Mg? . 20 n'mm. MPTROLLER AWE, Ellen Jordon r45.) 3% a ?x mass ecemb GRAND THEFT 2399 By DEPUTY CLERK an semen 9'28: 29?? THRU TROY FAJN WC ?x671 . Case 18-28 IN THE CRIMINAL DIVISION OF THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA. IN AND FOR PALM BEACH COUNTY magi 740a (A) 01/28/2003 11:36:12 200300?76?7 ocument 278, 08/09/2019, 262?82?Page464 of 648 oars NUMBER on BK 14720 PG 1935 Palm Beach Count STATE OF FLORIDA I 1 COMMUNITY Dorothy H. ?uke? Florlda SIWTROL - STATE or riot-tie! .Qi?fi?escu COUNT OLATOR . is a v. I hereby certify that w'Ith NW copy aI the IECOICI -- 1 PROBATION lionsVIOLATOR .2 I I one it." I H's ARON a. gait B, a coup: omen DEPUTY CLERK RACE GENDER I 3 . cream 5 course-i 3 - "pi-TH. . The above Defendant. bemz rsoh?a ly before this Court re resented Having entered a plea of nolo contenderc to the following the following crime(s): the folloWing crime(s); Having been tried and found guilty of Having entered a plea of guilty to - OFFENSE STATUTE Emmi 4 I and no cause having been shown why the Defendant should not be adjudicated guilty. IT [8 ORDERED THAT the Defendant ishereby ADJUDICATED GUILTY ofthe above crime(s). and having been convicted or found guilty of. or having entered a plea of nolo contendere or guilty.regard ess of adjudication, to attempts or offenses relating to sexual battery (ch. 794). lewd and lascivious conduct (ch. 800). or murder (5. 782.04). aggravated battery (5. burglary 810.02). carjacking or home invasion robbery (5. SIZE. BS). or any other offense speci?ed in section 943.325. the defendant shall be required to submit blood specimens. - ENTENCE The Court hereby stays and withholds imposition of sentence as to countts) and places the Defendant on STAYED Probation and/oil Community Control under the supervision ofthe Dept. of Corrections (conditions ofprobation set forth in separate order). SENTENCE DEFERRED The Court hereby defers imposition of sentence until The Defendant in Open Court was advised of his right to appeal from the Judgment by ?ling notice of appeal with the Clerk of Court within thirty days following the date sentence is imposed or probation is ordered pursuant to this adjudication. The defendant was also advised of his right to the assistance of counsel in taking said appeal at the expense ofthe State upon showing of indigency. DONE AND ORDERED in Open Court at Palm Beach County. Florida. this 15, day om . 2003 - . Case 18-286.ocument 26282.9age465 of 648 PLEA IN THE CIRCUIT COURT THE FOL OWING Is To ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: J: LUIS 261C Wax/Wm, Plea: Guilty _X7Guilty/B?s) Interest ContendereU_ No. Less?er _eg_D ree 801W GI: MIT H. II. KEN, CL I DEBIT- IF PSI: Waived/Not Req . ed/Requeste {13: a. II ADJUDICATION: Court?s Discretion If the Defendant Is convicted 1? or conspiracy to sess sell or traf?c' In any controlled substance. the Court directs the Department of Motor Vehicles and Highway 1 . - . Wefendant driver?s license for two (2) years. If the Defendant' Is convicted of grand theft of a motor vehicle; theft of motor vehicle parts; or, any felony mission of which a motor vehIcle was used the Court directs the Department of Motor VehICles and Highway Safety to revoke the Defendant?s driver?s - - as mandated bylaw. The Clerk' IS directed to make the proper notifications. SENTENCE: Fine 5 Court Costs Drug Trust Fund Cost of Prosecution Public Defender Fees/Costs Incarceration: Days Months Years wit creditfortim/ezsewed; which is days. 0 ATION: onths ars- Drug Offenderi ALL CONDITIONS OF ROBA UST BE SFULLY COMPLETED NO LESS THAN 30 DAYS EF RE I PROBATION IS SCHEDUL TERMINATE UNLESS STATED BELOW. m5 STANDARD CONDITIONS OF PROBATION HAVE BEEN EXPLAINED BY DEFENSE COUNSEL. a. CONDITIONS OF PROBATION: Restitution rthe accompanying order. check if ordered) $7 360 a) FineLji Court Costs: Drug Trust Fund. 5373 00 Cost of Prosecution 5 9 Public Defender Fees/Costs ff Substance abuse evaluation and successful completion of recommended treatment ordered) (enroll within 30 days) If in custody, release only to D) Random Drug Testing at Defendant? expense (check if ordered) ?oiw E) hours of community service at a rate of no less than hours per month F) Incarceration: Days Months . . . with credit for time served; which is days. 335 ?haw-TM OTHER COMMENTS 0 . he 5% . A UTE. .420 UIJJUW I, a Kare MM SENTEN - r\ d?br?h THE of? . OR IS ARRESTED ON :1 CHA GES. A PIA wui?h E0 A {1:1 (I: ice Own In} re. atons if a rg ed 1:114; a 3 It .. . for Dfendant ASSIs ant 17M X. xg/M/hGM- Date of Plea DEPUTY CLERK Defendant A . Ba?k A lhnn?? . Case 18-2868; Document 278,- 08/09/2019, 2628230, Page466 Of 648 In the'Circuit Court of the Fifteenth Judicial Circuit In and For Palm Beach County, Florida CaseNo. blotlzab Division: VJ STATE OF FLORIDA vs. he ref?; it . wltuJiri 1?qu Fmi'ii?, ?g \Muwl Defendant I ORDER MODIFYING THIS cause has come before the Court on the Defendant's Violation of Probation. Upon consideration, it is hereby: ORDERED AND ADJUDGED that the Defendant obation 15 modi?ed as follows: OWipd/?hOt/i Mil/re vinyl k0. Monti/6 hut-WW ri? wili AM (Liam mm!? Defendant admits the Violation ofBrobation. All Original terms and conditions to remain in effect. El Defendant is sentenced to days/months Palm Beach County I ail with credit for days. I I DONE AND ORDERED this day of 20 0,13 STATE or FLORIDA . PALM BEACH coumr a I hereby certify that the foregoing is a :11, q, true copy of the record in my office 1' 1" I 5 AA /Circud Judg/ - 5? DEPUTYCLERK 35 MAY 25 2955 . Case-182868 ocument~278, 08/09/2019, 2628230, Page467 of 648 ooTs NumDoi' PROBABLE CAUSE AFFIDAVIT I. An 3. Muesli lor Wetranl Juvenile '2.NT.A. 4. Raquesl for Capias .2. Agency om Numw 1 Agency Nam. Agency Report Numboc gm 5 0? ol 0 PALM BEACH COUNTY OFFICE 6 1-10 "11 L, 11(7111 1 gaggl?ymny i 1. Faiony J. Misdemeanot 5. Ordnance . 2. Traf?c Felony a. Traf?c Misdemeano: 6. Other .. ?15 Name1Lm. whammy) _A?u Rance Sex :1 1- rem-151a . (Sn-megm'. 1 (a Charge Doscr tnon ?1 Charguo criptiOn 41121 Charge De puon Charge Du?lpuon Viaim'sNamelLut.F 31:11.11 Race So: Damn! 81m: 1.151301 11% 111mg LicelAddruHSIwet. DTP. N'ta'rnbel'P' (CW) 9 . Phone . ?(1111555011113 1 9 no (51.1) 383-03213 111m} 5 . 3113111115 Ador?eas?T?mo Street) ily) 1m ID Phone Occupanon 5 mm, 16 The undersigned certi?es and swear: that helshe has just and reasonaolo grounds to beliave. and does bciiovo that the above named Delendant cornm1ned,tne Tho Person taken into cuuody. committed the below acts in my presence.- yin: observed JA mad ngko?? confessed to - that helshe saw the anested person cornmit the below acts. admitting to the below lacts..- -. On the day ot- following Violation oi law. was lound to have cammited the below acts from my (described) investigation. DAM. Cl (Specifically include facts constituting cause tor arrest.) .- .. '3113"?ng . 1 051$) _nmnnorjs Vina?! Tings. 1 An?i?x 130?,an hind 1mm mmom 011:} (3nd 1 a? (A i. . PncmeLECAufSI?z sfmeugsm {312131 b.1313 A _{15 ??nd . -. - STA -.. FLORIDA hail (911111 7191 [am/.1 - wownonpusonanymawniome lain-1-1- .13Pam .?mdc'v mm DISTRIBUTION: ??75 - CONCOPV GREEN - Slat! Mom-v YELLOW Aconcv PINK .. Anmvv . ?1 if . Case'18-286 ocument-278, 08/09/2019, 2628236Pag-?468 Of 648 0915 Number PROBABLE CAUSE AFFIDAVIT l. Ant-1 3. Request for Warrant 4mBowen for Canine 2-5 Ag?nc?y ORI Nunbet Agency Meme . Agency Renae Nu ?1 gm 5 o, PALM BEACH COUNTY OFFICE 0 61-16 1621-1 711C211, 7111 . 11 $11:wa FWW 3. Misdemeanor Be 5. Ordinance. Special News; 2 Tlettic Felony Tn?lc Misdemeanor .omr . u; NemetLaet. FIWII) Alia 1' Rece Sex 3? (4)07 03 Deecmmn r9 cosmipiion Lu 11311111ij ?1 11.1%: $112 . Charge Description chu??g D'scriplion 0 . 11711 111111111x 1: 'm LocalAdd Iut mil 1 I (Cay) {@1410 e) d: (2.) (Phone :gaems 11169 i . 1? a "Mealtmmo14,012 I hatch 032 (30c fog in far - mesa . K, I: 1. ID I ?981533-The undersigned certl?e and sweet: um helshe has just and reasonable rounds to bellow.- and do ve the: the ewe ed Oet dent comm tree the I I The Persm. tel-en htci?piitody 9 913? i owing vioetion .1111 a Lei NC. I committed ihe?beibw ?1111:1313 my presence - . 1 Ignaz: observe?dgyb LL19 Eni- CI confessed to . - heletto saw the arrested person cummit the below acts. admitting to the below facts. . was to'und to have commited the below acts resulting lrom my (described) Investigation. VICTIM .. Onlhe CIA. M. P. M. (Speci?cally include facts constituting cause for Ianest) day of .l .11. .353. 7 I u- lie-.1'11 ..J . -11 1:1- . I -. - . PROBABLE CAUSE STATEMENT .1 fig-J $31? .?tIiL15,111,315": 16%? {:33 31%; :1 macaw? 1 31:11'11: gird? .ZOFI-A uw?mru? K??bnff?ftw?l"?! Demo. 1110111 Hum 1. 11mm Mum . ~11. 1:1 11. 1111111 1 \11111 $111111: 1 1 1 1 Air-1* Ht?? {into )1 ?21 ?Zrt'3~0? ihaI-mlm LII-lick} 3159mm NF?OAtmTOmquith I I XCOVF I I. 11151 Hath?? I .59" - 2-1 - omnmmemrsm?ymownioinu [-04 ., 1 63.3.1731? 7 ?r 56/ 0291'? . WHITF Chm-t C?rw Emu?1 VCI Inn: AOMINISTRATIVEI I I CatSe 18- -2&3Document 278?, 08/09/2019, 262828 Page469 of 648 Numoe!? PROBABLE CAUSE AFFIDAVIT i. Arrest 3. Request for Warrant Jm?fl. I I 2. N.T.A. d. Request lo! Cecil: ZI Assn-Icy ORII NurtIOet I I I AgetIhcy Nine Agency Num o, PALM BEACH COUNTY SHERIFFSOFFICE 6 ?:th 7 fr, 7m 1i gar: ?11133, g? 3- Misdemeanor s. oIdinanco apply. 2. Traffic Felony 4. Traffic Miiaomeemr 6. Other .. Lg Nameth. First. Middle)? Ins Fl 0 Sex 8? 4:9- 1? \in art; I PK fun (a Description 6 mp?llon ?ftml - Charge Dmriptlon Gi'arge Description 0 I Victim' Na eLLast ?rst. Mica?) Race :53: PM: Finn Local mares: ?Sfreet'. Agni? 'Ju? (Stare? [at Phone Address SourE? 9. tr 0 I iamIneisrAdhnisImIimo. S'H?'et?l - (City) (State . ?*Fiiona ?m5 . I the uncon?ned cpm'fiuand NunWhuaM has just and reasonable grounds tabelieve. and does believe that [he (above) named fondant CDmrI'Irlted the MI wing mutation at law Yhe Fe IIan Into custody I committed the below acts in my presence. . was observed ?I'm IWIOU - I . . confessed to at helehe saw the arrested person commlt the below I admitting._to the below facts. as found to have commited the below acts. resulting from my (dIIucribea) investigation. the at 20_ at DKMJ: PM. (Speci?calry induce facts constituting cause lor arrest2-3-77; - -. ~35, mm (In-em a 4 - mm? I111 kph-u nun-3n23,3" .gW31? ~49: :5 110 0 RY. _inIn 033 3\ . nDY:i (31f) R51: 11356.2 10mm . 3mGm: 101% 1 W10 I II ~t-Ixmt 1w!? AT ?f3 mm ii) cnuse STATEMENT . u. 'm-i I thIe tyne; me. tangent; is a .3:th cog?itwowd?nmy atfumtrta a? 16? I- grey-315.1: I . LEI ONR. BIOQE - - A I DEPUTY CLERK- ADMIWRATIVE rt :er .Of?cer (ESHS 117. DIAMA an; mm WHITE -- COURT Copy GREEN State Attorney - YELLOW ~30ch . PINK - Aoencv Case 18-286 Document 278', 08/09/2019, 262860, Page470 Of 648 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA CRIMINAL DIVISION (CGS) STATE OF FLORIDA CASE NO. 02CF012206A02 BOOKING NO. 2002343590 vs. ANTHONY LUIS ZAC FIGUEROA, WM, 0 :1 INFORMATION FOR: if" GRAND THEFT In the Name and by Authority of the State of Florida: BARRY E. KRISCHER, State Attorney for the Fifteenth Judicial Circuit, Palm Beach County, Florida, by and through his undersigned Assistant State Attorney, charges that ANTHONY LUIS ZAC FIGUEROA on or about October 24, 2002, in the County of Palm Beach and State of Florida, did knowingly obtain or use, or endeavor to obtain or use video games of a value of $300.00 or more, which was the property of HOLLYWOOD VIDEO, or any other person not the defendant(s), with the intent to permanentlyorternporarily deprive HOLLYWOOD VIDEO or any other person not the defendant(s) of the property or bene?t therefrom or to appropriate the property to the use of ANTHONY LUIS ZAC FIGUEROA or to the use of any person not entitled thereto, contrary to Florida Statute 812.0140) and (3 DEG FEL) FL. BAR NO. 0928 3 Assistant State Attorney STATE OF FLORJDA COUNTY OF PALM BEACH Appeared before me, JILL ESTEY RICHSTONE Assistant State Attorney for Palm Beach County, Florida, personally known to me, who, being ?rst duly sworn, says that the allegations as set forth in the foregoing information are based Upon facts that have been sworn to as true, and which, if true, would constitute the offense therein charged, that this prosecution is instituted in good faith, and certi?es that testimon under oath has been received from the material witness or witnesses for the offe e. Sworn to and subscribed to before me this I day of October, 2002. NOTARY PUBLTC, State of Floh'da or FLORIDA . mu BEACH comm .- . - ihmeny certifythat the '2 ?53 Ellen Jord VFCIC 11:3 :93- GRAND THEFT .1 ?ecember28.2ooz Nose mau worm? INSURANCE, wc ?g ?j Case 18-2 Document 278, 08/09/2019, 2628 Page471 Of 648 Qt IN THE CRIMINAL DIVISION OF THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA. .N 11:36:12 OBTSNUMBER UR BK ?72. PG 1937 Palm Beach County, Florida STATEOF FLORIDA 1] COMMUNITY Dorothy H- Hill-ten, Clerk - CONTROL VIOLATOR V. PROBATION DEFENDANT RACE VIOLATOR H. . ff; . The above Defendant, being person I 1* Having been tried and found guilty of the following crime(s); Having entered a plea of nolo Having entered a plea of guilty to contendcre to the following the following crime(s): crimc(s): h? COUNT RIME . OFFENSE STATUTE NUM DEGREE . W. We 3E and no cause having been shown why the Defendant should not be adjudicated guilty. IT is ORDERED THAT the Defendant is hereby ADJUDICATED GUILTY of the above crime(s). I and having been convicted or found guilty of. or having entered a plea of nolo contendere or guilty.regardless ofadjtidication. to attempLs or offenses relating to sexual battery (ch. 794). lewd and lascivious burglary 810.02). carjacking 812.133). or home i defendant shall be required to submit blood specimens. conduct (ch. 800). or murder (5. 782.04). aggravated battery (5. 784.045). nvasiOn robbery SIZ. I35). or any other offense speci?ed in section 913.325. the SENTENCE The Court hereby stays and withholds impositieguil?lientence as to countts) and places the Defendant on STAYED Probation and/or[ Co? . lib)? orgroal the supervision ofthe Dept. of Corrections (conditions of probation set forth in separate or ts cc mt SENTENCE fin mfg; \a DEFERRED oil Iling notice ofappeal with the Clerk of Court within thirty days 'lOl?l. The defendant was also advised of his right to the assistance ei?r?ia. this day of . 2003 W14116 Officer: 15-3 ff?? i JUDGMENT 0F GUILT I, EB AND PLACING DEFENDANT ON PROBATION ?at: e3? STATE OF FLORIDA In The Circuit Court -vs- Plaintiff of Palm Beach County, Fl ANTHONY LUIS ZACFIGUEROA Case No. 02-12205CFA0293 Defendant 1 ?18 'er lid 93 This cause coming on this day to be heard before me, and you, the defendant ANTHONY LUIS ZACFIGUEROA, being now present before me, and you having: PLED GUILTY TO The offense of COUNT 1. GRAND THEFT the court hereby adjudges you to be guilty of said offense; and . It appearing to the satisfaction of the Court that you are not likely again to engage in a criminal course of conduct, and that the ends of justice and the welfare of society do not require that you should suffer the penalty authorized by law: Now, therefore, it is ordered and adjudged that the imposition of sentence are hereby withheld, and that you are hereby placed on probation for a period of EIGHTEEN Q8) MONTHS CONCURRENT WITH 02-12205CFA02 under the supervision of the Department of Corrections and its Of?cers, such supervision to be subject to the provisions of the laws of this State. It is further order that you shall comply with the following conditions of probation: (I) Not later than the fifth day of each month or as directed, you will make a full and truthful report to your Probation Of?cer on the form provided for that purpose. (2) You will pay to the State of Florida the amount of 50.00 FIFTY DOLLARS per month, plus a 4% surcharge, toward the cost of your supervision, unless otherwise exempted in compliance with Florida Statutes. (3) You will not change your residence or employment or leave the county of your residence without ?rst procuring the consent of your Probation Officer. You will neither possess, carry or own any weapons or ?rearm without ?rst securing the consent of your Probation Of?cer. (4) G) 1 . 01213 817910 8982'813 3319 \ko . . Case 18-2868 Document 278; 08/09/2019, 2628230, Page473 of 648 . ZacFigueroa, Anthony Case 02-12206CFA02 (5) (6) (7) (3) (9) (10) (11) (12) You will live and remain at liberty without violating any law. A conviction in a court of law shall not be necessary in order for such a violation to constitute a violation of your probation. You will submit to Urinalysis, Breathalyzer or Blood tests, as directed by your Probation Of?cer or the Professional Staff of any treatment center where you may be reCeiving treatment, to determine the possible use of alcohol, drugs or controlled substances. You will make a good faith effort to obtain lawful employment and support any dependents to the best of your ability as directed by your Probation Of?cer. You will and truthfully answer all inquiries directed to you by the Court or the Probation Of?cer, and allow the Of?cer to visit in your home, at your employment site, or elsewhere, and you will comply with all instructions he may give you. TO: HOLLYWOOD VIDEO IN THE AMOUNT OF $1000.00 MINIMUM PAYMENT OF $55.56 PER MONTH CRO FILED NO CONTACT WITH HOLLY VIDEO 1N PALM BEACH CO. ENTER AND COMPLETE: THEFT ABATEMENT PROGRAM AUTOMATIC EARLY TERMINATION AFTER 12 MONTHS PROVIDED ALL CONDITIONS ARE SATISFIED You are hereby placed on notice that the Court may at any time rescind or modify any of the conditions of your probation, or may extend the period of probation as authorized by law, or may discharge you from further supervision; and that if you violate any of the conditions of your probation, you may be arrested and the Court may revoke your probation and impose any sentence which it might have imposed before placing you on probation. It is further ordered that when you have reported to the Probation Of?cer and have been instructed as to the conditions of probation you shall be released from custody if you are in custody and if you are at liberty on bond, the sureties thereon shall stand discharged from liability. . Case'l8-2868 Document-278, 08/09/2019, 2628230, Page474 of 648 ZacFigueroa, Anthony Case 02-12206CFA02 It is further ordered that the Clerk of this Court ?le this order in his of?ce, record the same in the Minutes of the Court, and forthwith provide certi?ed copies of same to the Probation Of?cer for his use in compliance with the requirements of law. DONE AND ORDERED IN OPEN COURT THIS 15TH DAY OF JANUARY, 2003. Signed this day of ,2003. 91.0. 1441 I acknowledge receipt of a certi?ed copy of this order and that the conditions have been explained to me. Date: Probationer Instructed by: Original: Court DC4-9OOA Copies: ProbationerfFile JF 1/ 16/03 STATE OF FLORIDA - PALM BEACH COUNTY hereby certify that the foregoing ?agthe reborn 111 (W 0mm 3 ?rms- Case 18-286wocument 278, 08/09/2019, 2628230, Page475 of 648 In the Circuit Court of the Fifteenth Judicial Circuit In and For Palm Beach County, Florida . 020112119111: new. Case No. Division: STATE OF FLORIDA 101' L: :31 A151 Pt?uem-L Defendant 2 His; ORDER MODIFYING PROBATION -- THIS cause has come before the Court on the Defendant's Violation of Probation. Upon consideration, it is hereby: ORDERED AND ADJUDGED that the Defendant' sP obation' 15 modified as follows: Ov?? bale-?o 1/1 in 1121/10 a, @1111th wtihw bid/1 ?111% UJ L1 WKMD 0? . Odom 0.1/ aimed/16121 1. Gamma,? CL 0.11/11 H, em MMwel?Lc level HM Defendant admits the Violation ofProbation. All Original terms and conditions to remain in effect. 1:1 . Defendant is sentenced to days/months Palm Beach County Jail with credit for . days. - DON AND day of 31175?? 20 0 if?" . STATE OF is a {1e11, 1-23? 1 hereby cent that the {megomg 11 in ?11' bottles: with py 01' th? NEW 1 ji%i0nsh if? a r3"; 0m R3013 W90 ?1 CLE 11- 9, FL0 DEPUTY CLERK 3?1 .7 &8 18-28 Document 278, 08/09/2019, 2628230, Page476 ofg455 NOTICE TO APPEAR . Juvenile Refena 2. N.T.A, MUG: 8" Warrant Juvamlo OBTS Number2 5 0 0 1- Wow 3. modem-no: as apply. 2. Traf?c Felony Location or Arrest (Indudng Nema ol OFFICE 6 - 5. Ordinance legible . . erance c. Tre?nc Mledemunor 6. 0mm 1 Indicator ADMINISTRATIVE LocaIiOn of (Business Name. Address) arrest Jeil Dale ame Locenon 0! (Last. Middle) I Rm Allan (Name. Soc. - - American Indian 8 - Bleak 0- 5 81005, Unlque Alcohol Influence In?uence - I. City 3. Florida 2. County 4. Out 01 Sun: Address Samoa 4 usiness Address (Name, StreeI) - (Slate) Occupallon DEFENDANT Of CD-Doiondam Name Date oi Parent (Firsu (Muodla) - Legei Cumodun Other: (Street. Am. Juvemle - . within 2, TOT Has/ms Dept. and Released. 3, NVENILE above address and I I . [hi Juvenile 833A (Bank?s g" or Dawn wu told . scrum} Amended Yes. by: - T730 . . Unknown Producol. A . Cocaine N. . . 0(h P. Possess T. A Herom o. . . 2 Dow-prion Counts Domestic VIoIatioI-I Number WOI I CY I Capias Number Bond Vlolation of 080 0 Drug Drug Amounll Unh CHARGE Number Violation DI 0RD 0 I I DY Drug Drug Amount Unit CHARGE Warrenl I Capiu Number 80er 17' Count: Domestic SmuIe Violation Number Vlolen c_o Violmion of CEO I CHARGE Wenem 1 Nu be! Bond Smule Violalion Number - V-oialion 0! 090 CHARGE Drug Type Amoum 1 Unit I Cepdae Numbel '3 c. CouanendTarne Locetlon (Coun. Room Number, AddressMoan-I You Tlme AM. . rm. if?? I AGREE APPEAR AT THE TIME AND PLACE DESIGNATED To ANSWER THE OFFENSE CHARGED on PAY THE FINE SUBSCRIBED. I SHOULD I WILLFULLY FAIL To APOPEAR BEFORE THE COURT As REQUIRED arms To APPEAR. THAT I MAY BE HELD IN CONTEMPT 0F COURT AND A FOFI ARREST SHALL BE ISSUED MTICE T0 APPEAR Signature at Defend-m (or Juvenile and Parent! Custodlm) Dam Signed HOLD 107 who! Agency Name.- Dlngerous Reeieted Men of "?65 ID. Other. AH Mn.) LD. 0 Tremponing LD, tr gnu Name thicetion (PnnIad by Arreeree] Ime?swpaeagned an"X 12 OF P850 DISTRIBUTION: WHITE - COURT COPY GREEN - STATE ATTORNEY YELLOW - AGENCY PINK - AGENCY GOLD - DEFENDANT (N.T.A.'s ONLY) 0 m7 The undersigned unifies and . The Person 13km into Custody? a committed the below acts in my presence. confessed to that- helshe hos lust and reasonable grou to helium. and does believe that tho above named Dalendant Case 18-28 Document 278,08/09/2019, 2628230, Page477 Of 648 OBTS Numbe' - PROBABLE CAUSE AFFIDAVIT 1. Arrest 3. Reouest for Warren! Juvemlo 'Roquut for Caain Agency OFit Number Agency Name Agency Report Number 9 ml 5 o. 01 PALM BEACH COUNTY OFFICE 1 61101 t) A ll2 I ll Emaialvr?tgny ?g ??057 3. Mlsdemoanor 5. Ordinance SpeCIal as apply Tra?rc Falony 4. Trattic Misdomaanor 6. Other b? Last. First. Middle) Alias? Race Sort a ?warm AM to Cmem Charge Description m? Charge Description Charge Description I. ..- I. . yum-1 5. Victim' 3 Name (Last F- wot. Middiot Raca 5.: Dale 0' Berth /..11111 Local Address Irut. Apt Numbort" (City) [Surat (Zip) Phone Address Scum . again.? mattress (Name. 5 (Sign Phone OccupatIOn 134 I the following violatpn 0! Int admitting to the below tacts. I. dayot OC?bbir On the was observed by Whoa told j/S Dnsux) .. that helsho saw the arrested :3 son commit the b_elow acts. was lound to have commited the below acts. resulting from my (descn'bed) Investigatlon 20_0_2u DA M. at P. M. (Specilic'ally include facts censtituting cause tor arrest) 4-. .13 l? 0 (.2. WM I ?j SEC) ?612'! Q9194 ?Btegh [mmiic (15,293?: 14:0 A P850 (?ka +wb MISS lath} a?tnghA 55f Storiit: ?Dk (molev K153 ?7 Video 6; PA) hookah ok?err ?k0r+s {3 Qinds?hhoro .3 7?30! miss. 639mg; . . PROBABLE CAUSE STATEMENT b- Ncl. ?me. QXal-z . . .I?ctng EA rL curtl?y that the oreg-I - . up)" at the) racers pug/v a DEPUTYCLERK GM LOFJ. DISTRIBUTION: I WA nah. WHITE Court CODY GREEN Stats chInw Ana-w? Case 18-2868, D.ment 278, 08/09/2019, 2628230, @8478 Of 648 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION DS JASON VANDUSEN, 6142 CASE NO. 02CF012204A99 PALM BEACH COUNTY SHERIFF OFFICE Booking No. 2002343586 Agency case number 02?12882] 33 STATE OF FLORHDA - (?It vs. . 1:3 ANTHONY LUIS ZAC FIGUEROA, If NO FILE FOR: GRAND THEFT The State enters a no-?le because the elements of the crime cannot be proven beyond a reasonable doubt. BARRY E. KRISCHER, STATE ATTORNEY DATE: October 28, 2002 5 By: JILL ESTEY RICHSTONE Assistant State Attorney FL. BAR NO. 0928933 CLERK AND SHERIFF T0 RESCIND N0 CONTACT ORDER $1532 or mama - PALM BEACH COUNTY .3 . Dummy cartily that the foregoiflg .J . .. .0. m, ?1 Con-1 in my of?ce .53 (2005. sr by 3.2.15." ws? mm (545 Page479 of 648 SI Requesl tot Wa'ranl 5. Recuest Caplas 08 I Numhat tom 262?. ROYAL PALM BEACH POLICE DEPARTMENT 3. Misdemeanw 6. 4. Traflic Misdomalnor 6? Other Agency ORI Number FLO 5 0 2 we check as many as 0 0 800 1A Felony 2. Traf?c Felony 3812 . (Last First, Mk1 ierAn Cna'ge Desc?plion Oil on Luis Zac Grand Theft Auto Charge Desorption Charge Description CHARGES DEF. Victim's Name Fl uero 'chartlie) Jr. VICTIM (Stale) undersigned and swears that ho/she The Person taken into custody and reasonable to believe, and the above named Committed v:olalion ct law 8' committed the below acts in my presence. I: was observed by I: coniessed Io admitting to the below facts. On lne 22nd day of 20% at -lzi 8 AM. PM. (Specifically include facts constituting caUSe for arrest.) eroa, Jr., who told me that he allowed his brother Anthon to use his 1986 Mazda who told that heishe Saw the arrested pexson commit the below acts was iound to have committed the below acts. resulting from my (describes) investigation I met with victim Richard Fi rive a ome to ut ick-u truck were 110 to 521 not sa . or etr 8W0 minutesseriousness a -out this form a an was concer nce ut esame I ve to n. extent at co 5 one tate a to atw0r ntemornn Ata ut eva weres assess ono i do ri the .m'l was er ll 0C2 were near un er seateret etwo ueroa, nee rs! ad ica contro arrest or esam a 11 Auto. 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ADDITIONAL PROBABLE CAUSE: At a ve ate a time, was sou CIIO na to an maroon report on a was a2 a truck whic stolen car case. ce station ta 0 r. cust secure an owner an I. ect ects were over to etot cl PROBABLE CAUSE u, swoon AND BEFORE ME 2 l- 0 0A SIGNATURE OF ARRESTING I INVESTIGATING OFFICER FFI ER NOTARY UBLICIC KOF CCU TIP T. by #100 1 0'22?00 NAME OF OFFICER (PLEASE PRINT) DATE 10-22-00 DATE PINK -- Agency - DISTRIBUTION: WHITE - Court Copy GREEN -- State Attorney YELLOW-- Agency Case 18-286iocument 278; 08/09/2019, 262823Page481 Of 648 JB I . . Case No.: ST ANTHONY LUIS ZAC FIGUEROA Charges: GRAND THEFT (MOTOR VEHICLE) Arrest# 2000346620 Bond# 7-5 Type 3 3,000 AJC Date a Judge L n?m Crt.Rep.__ I ASA 2-6?ma manic. r_ DC HTRL nt Pres. - Def. 'Co. \3 K.) Cb Esq (TD-E Not Pres. Before Court for: I I (DOS) I ?bf?b CI Granted CI Denied CI With Without Prejudice. CI Withdrawn CI Court Rese?rveSRuling CI Written Order to Follow Warrant Cl Ordered CI Recalled CI Bon tat CI See_B.elow Also Covers Sp Cond Bond Forf OR: Disch Revoked Reinstated Bon evoked Reinstated CI SOR: Disch Revoked Reinstated Bond Forf Vacated Previous Bond Reinstated, if onds - .3 ees_ State failed to ?le charges ReleaSed O.R. CI Deft'__ Indigent CI PD Appt only PD Pres Court Appts Evaluation for: Drug Farm DOC Non-Secure Bed by Pre-Plea CI PSI ordered by/within days CI w/input from DJJ Staffing DEFT ENTERED OF: CI NOT GUILTY CI GUILTY As Charged?Cts CI NO CONTEST CI BEST INTEREST To THE COURT Lesser Lesser Charge - SW Test CI?Adv-of CI Waived PSI Lesser Lesser Charge ADJ GUJLTY as Chargedas to I Lesser CI FOUND GUILTY as Charged as to Lesser . El ADJ as to SENT as-to . . . Cl FOUND AND ADIUDICATED DELINQUENT as to I CI Order gollow Filed CI POUNDS: ADJ NOT GUILTY as to Cts' - CI Dismiss Nolle Prosse .- I - Prob/ Comm Control: CI Revoked CI Reinstated CI SEEORDER ASSESSING COSTS SEE REVE Modi?ed Term. SIIC'cessfully I Unsuccessfully RSE SIDE FOR INSTRUCTIONS REGARDING FURTHER HEARING CI Stip/Found: (violent) Habitual Off. 775.034 - Stip/Found: Sexual Offender/Sexual Predator CI Stip/Found: P.R.R. SENTENCE: PBCJ: Cts: IDOC: - Cts: PBCJ: Cts: - IDOC: . . I i Cts: Cl W/Credit for - Days MOS-I Yrs. CI Deft R'emanded .Cl Deft to remain on Conc I Consec I Co-Tertn w/cases I cts: . ame rel. status pending sent. CI Execution of Sentence Stayed CI SentOnce Suspended CI Time served as to Cl YouthfulOff CI Habitual Off Min/Maud: as to El ABOVE SENTENCE FOLLOWED By: CI Probation CI Drug OffProb CI Comm. Control CI I CI 1] ?SeePageZ FATE FLORIDA . PALM BEACH 000m. I I 1 011qu 'v?v'iw 95?; mm (5919?! . Set Remai 0yTHISDW UM OF Setl Remainsn Rm at l" CIDeftsign A - Def Co CI ASA EJWY OLE CI Bondsman El Prob CI Jail DJJ CI GAL Noti?ed by mail by: on . I I CountyCourthouse CI Courtroom, Criminal Justice Bldg. . CI Courtroom, Criminal Justice Complex 205 N. Dixie, West Palm Beach 38844 State Road 80, Belle Glade 3228 Gun Club Rd., West Palm Beach IF YOU ARE A PERSON INITH A DISABILITY NEEDS ANY ACCOMMODATION IN ORDER To IN THIS PROOEEDINO. 'vou ARE ENTITLED, AT NO COST TO YOU. To THE PROVISION OF CERTAIN ASSIST ANOE. PLEASE CONTACT THE OFFICE or THE COURT - 205 NORTH DIXIE 5.2500. ag??mmoh TELEPHONE (501) 355-2431. 2 INORKING DAYS on YOUR RECEIPT OF THIS NOHCE. IF YOU ARE HEARING INPAIRED. CALL 1-800-955-8771; IF VOICE RE . 1-500-055-3770 Form 61] Case 18-2868, Document 278, 08/09/2019, 2628230, Page482 of 648 EXHIBIT GG Case 18-2868, Document 278, 08/09/2019, 2628230, Page483 of 648 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 21, 2016 9:17 a.m. C O N F I D E N T I A L Deposition of JOSEPH RECAREY, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 18-2868, Document 278, 08/09/2019, 2628230, Page484 of 648 Page 2 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 A P P E A R A N C E S: BOIES SCHILLER & FLEXNER, LLP Attorneys for Plaintiff 401 East Las Olas Boulevard Fort Lauderdale, Florida 33301 BY: BRADLEY EDWARDS, ESQ. HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant 150 East 10th Avenue Denver, Colorado 80203 BY: JEFFREY PAGLIUCA, ESQ. JONES FOSTER JOHNSTON & STUBBS, P.A. Attorneys for Deponent 505 South Flagler Drive Suite 1100 West Palm Beach, Florida 33401 BY: JOANNE O'CONNOR, ESQ. ALSO PRESENT: Sandy Perkins, Paralegal Boies Schiller & Flexner 17 Ryan Kick, Videographer 18 19 20 21 22 23 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page485 of 648 Page 3 2 3 4 5 6 7 8 9 10 11 I N D E X Examination by Mr. Edwards .................... Examination by Ms. Schultz ..................... Examination by Mr. Pagliuca .................... Further Examination by Ms. Schultz ............. Further Examination by Mr. Pagliuca ............ E X H I B I T S Deposition Exhibit 1 ........................... Palm Beach Police Department Incident Report Deposition Exhibit 2 ........................... AH statement 9 123 165 329 355 11 59 12 13 14 Deposition Exhibit 3 ........................... CD with video (retained by Boies) Deposition Exhibit 4 ........................... Search warrant return 66 69 15 16 17 Deposition Exhibit 5 ........................... Property receipts Deposition Exhibit 6 ........................... Additional search warrant returns 76 77 18 19 20 Deposition Exhibit 7 ........................... Probably cause affidavit Deposition Exhibit 8 ........................... Trash pull return 84 96 21 22 23 24 25 Deposition Exhibit 9 ........................... 102 Folder with evidence Case 18-2868, Document 278, 08/09/2019, 2628230, Page486 of 648 Page 4 2 Deposition Exhibit 10 .......................... 119 Investigative report 3 Deposition Exhibit 11 .......................... 165 4 5 CD with audio recording (retained by Boies) Deposition Exhibit 11 .......................... 178 Supplement to incident report 6 Deposition Exhibit 12 .......................... 259 7 8 Rule 26 disclosure Deposition Exhibit 13 .......................... 282 Vol. 2 of prior Recarey transcript 9 Deposition Exhibit 14 .......................... 292 10 Vol. 1 of prior Recarey transcript 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 *** Exhibit 11 was used on two different exhibits. Case 18-2868, Document 278, 08/09/2019, 2628230, Page487 of 648 Page 10 1 2 JOSEPH RECAREY - CONFIDENTIAL Q. Most of the events that we are going to 3 discuss today occurred, at least the investigation 4 that we're going to discuss today, occurred in 2005 5 and 2006. 6 So can you just tell us what your position 7 was with the Palm Beach Police Department at that 8 time? 9 A. I was a police detective. 10 Q. And did you investigate a person by the 11 name of Jeffrey Epstein? 12 A. I did. 13 Q. All right. 14 15 16 17 18 What was your role in the investigation of Jeffrey Epstein? A. I was the lead detective once the case was turned over to me by Michelle Pagan. Q. Okay. And as the lead detective, did you 19 review all of the history of the investigation up to 20 the point it was turned over to you? 21 22 MR. PAGLIUCA: foundation. 23 24 25 Object to form and THE WITNESS: Correct. BY MR. EDWARDS: Q. And was that one of your jobs as the lead Case 18-2868, Document 278, 08/09/2019, 2628230, Page488 of 648 Page 11 1 JOSEPH RECAREY - CONFIDENTIAL 2 investigator over a case, is to acclimate yourself 3 to the history of the case? 4 5 MR. PAGLIUCA: foundation. 6 7 8 9 10 Object to form and THE WITNESS: Yes. BY MR. EDWARDS: Q. Just so that the record is clear, will you just give a brief pause in case Mr. Pagliuca has an objection? 11 A. All right. 12 Q. So they can also capture your answer. 13 A. Okay. 14 Q. In reviewing the history of the case, did 15 you review prior police reports, police reports 16 prior to you becoming involved personally? 17 A. I did. 18 Q. Okay. 19 And I've handed you what is marked as Plaintiff's Exhibit 1. 20 (The referred-to document was marked by 21 the court reporter for Identification as 22 Deposition Exhibit 1.) 23 BY MR. EDWARDS: 24 Q. Do you recognize that? 25 A. Yes. Case 18-2868, Document 278, 08/09/2019, 2628230, Page489 of 648 Page 177 1 2 JOSEPH RECAREY - CONFIDENTIAL Police Department incident report as suspects? 3 MS. SCHULTZ: 4 foundation. 5 BY MR. PAGLIUCA: Object to form and 6 Q. These people, right? 7 A. At that time, yes. 8 Q. Well, and then are you aware -- were there 9 10 any suspects added in any subsequent reports, to your knowledge? 11 A. Not that I'm aware of. 12 Q. In fact, you did not seek a probable cause 13 warrant for any other suspects in this case, 14 correct? 15 16 MS. SCHULTZ: foundation. 17 18 19 Object to form and THE WITNESS: That's correct. BY MR. PAGLIUCA: Q. And Ms. Ghislaine Maxwell is not listed in 20 any of your Palm Beach Police Department incident 21 reports as a suspect in this case, correct? 22 23 MS. SCHULTZ: Object to form and foundation. 24 THE WITNESS: 25 in this case, no. Not -- no, not as a suspect Case 18-2868, Document 278, 08/09/2019, 2628230, Page490 of 648 Page 180 1 2 JOSEPH RECAREY - CONFIDENTIAL Exhibit 1. Are you with me? 3 A. Uh-huh. 4 Q. Okay. 5 Again, this was information that was obtained by Detective Pagan, correct? 6 A. Correct. 7 Q. And it's true, is it not, that this 8 alleged victim never claimed to have been recruited 9 by Ghislaine Maxwell; true? 10 11 MS. SCHULTZ: foundation. 12 13 14 Object to form and THE WITNESS: Correct. BY MR. PAGLIUCA: Q. And this individual, alleged victim No. 1, 15 never identified Ghislaine Maxwell as being at 16 Mr. Epstein's house when she was there, correct? 17 18 MS. SCHULTZ: foundation. 19 20 Object to form and THE WITNESS: I don't believe so. BY MR. PAGLIUCA: 21 Q. You don't believe so -- 22 A. I don't believe so. 23 Q. That she ever identified Ghislaine Maxwell 24 25 as being in the house? A. Right. Case 18-2868, Document 278, 08/09/2019, 2628230, Page491 of 648 Page 181 1 2 JOSEPH RECAREY - CONFIDENTIAL Q. Okay. She never -- this individual, 3 victim No. 1, never claimed that Ghislaine Maxwell 4 paid her any money, correct? 5 A. Correct. 6 Q. And this individual No. 1 never claimed 7 that Ms. Maxwell instructed her what to wear, 8 correct? 9 A. Right. 10 Q. This individual never claimed that 11 Ghislaine Maxwell told her how to act, correct? 12 A. Correct. 13 Q. This individual never claimed to have met 14 Ghislaine Maxwell ever, correct? 15 A. I don't believe so, no. 16 Q. This individual never claimed to even have 17 spoken to Ghislaine Maxwell ever, correct? 18 A. I don't believe so, no. 19 Q. And when you say "I don't believe so, no," 20 that means my statement to you is correct; is that 21 right? 22 MS. SCHULTZ: Object to form, foundation. 23 THE WITNESS: Well, you're saying "ever." 24 25 I don't know if she's ever, ever spoken to -- Case 18-2868, Document 278, 08/09/2019, 2628230, Page492 of 648 Page 182 1 2 JOSEPH RECAREY - CONFIDENTIAL BY MR. PAGLIUCA: 3 Q. To Detective Pagan. 4 A. Right. To my knowledge, I don't know, 5 because Detective Pagan is the one who actually 6 interviewed her. 7 "ever." 8 Q. 9 10 So I don't know to the answer of So not to my knowledge. Certainly, nothing in Exhibit 1, Narrative 1 reflects that this individual ever met or talked to or spoke to Ghislaine Maxwell, right? 11 A. Right. Not to my knowledge. 12 Q. And, indeed, you would agree with me that 13 if this individual claimed that Ms. Maxwell had 14 something to do with the events listed in Narrative 15 1, you would have folded up on it, as the 16 investigating detective, right? 17 MS. SCHULTZ: Object to the form. 18 THE WITNESS: Either myself or Detective 19 Pagan would have. 20 21 BY MR. PAGLIUCA: Q. Sure. And when you got the case six 22 months later, if there hadn't been follow-up, you 23 would have followed up on it, right? 24 MS. SCHULTZ: Object to form. 25 THE WITNESS: Correct. Case 18-2868, Document 278, 08/09/2019, 2628230, Page493 of 648 Page 187 1 2 JOSEPH RECAREY - CONFIDENTIAL Q. Okay. The person alleged to have brought 3 the alleged victim No. 1 to Mr. Epstein's house is 4 this Hayley Robson individual, correct? 5 A. Yes. 6 Q. Okay. Then with regard to alleged victim 7 No. 2, then this individual did not claim to have 8 been recruited by Ms. Maxwell, correct? 9 MS. SCHULTZ: Object. 10 THE WITNESS: Who would be victim No. 2? 11 12 BY MR. PAGLIUCA: Q. Well, you can either go to the second page 13 of Exhibit 1 and we can just follow down the victim 14 information, or you can go to the body of the 15 report, whichever is easier for you. 16 MS. SCHULTZ: 17 MR. PAGLIUCA: Can you use the initials? Sure. I can call them 1 or 18 AH or whatever you want to call them. 19 fine with me. 20 21 That's BY MR. PAGLIUCA: Q. So I'll just say alleged victim AH never 22 claimed to have been recruited by Ms. Maxwell, 23 correct? 24 A. Correct. 25 Q. And alleged victim AH did not claim to Case 18-2868, Document 278, 08/09/2019, 2628230, Page494 of 648 Page 188 1 2 JOSEPH RECAREY - CONFIDENTIAL have spoken to Ms. Maxwell ever, correct? 3 MS. SCHULTZ: Object to form. 4 THE WITNESS: It's been a while since I 5 read this report. 6 7 BY MR. PAGLIUCA: Q. Sure. Is it fair to say, Detective, that 8 this investigation occurred some 12 years ago, 9 right? 10 A. Yeah. Well, yeah. 11 Q. And is it fair to say that you've 12 conducted quite a few investigations over your 13 career? 14 A. Yes. 15 Q. All right. 16 And it's fair to say that it would be 17 impossible for you to remember all the details of 18 this investigation as you sit here today, correct? 19 A. Correct. 20 Q. And you've been referring to Exhibit 1 21 frequently throughout this deposition, correct? 22 A. Yes. 23 Q. And that's because you don't have any 24 25 present memory of these details, correct? MS. SCHULTZ: Object to form, foundation. Case 18-2868, Document 278, 08/09/2019, 2628230, Page495 of 648 Page 189 1 JOSEPH RECAREY - CONFIDENTIAL 2 THE WITNESS: I have some recollection, 3 but I'm not going to have exact dates and times 4 off the top of my head. 5 BY MR. PAGLIUCA: 6 Q. Sure. 7 A. You know, I spoke to over 33 girls 8 regarding this case. So when you say an initial, it 9 takes me a little while to go through the entire 10 list. But to have specifics, I'm not going to be 11 able to remember the exact specifics of -- of the 12 report. 13 Q. 14 I appreciate that. So we can take our time, but do you 15 recall, did AH ever identify Ms. Maxwell has someone 16 she spoke to? 17 A. I don't recall. 18 Q. You don't recall at all? 19 A. I don't recall that she had mentioned 20 Ms. Maxwell. 21 Q. 22 And if she had, you would have put that in your report, correct? 23 A. I believe so, yes, I would have. 24 Q. All right. 25 And so the absence of alleged victim AH Case 18-2868, Document 278, 08/09/2019, 2628230, Page496 of 648 Page 190 1 JOSEPH RECAREY - CONFIDENTIAL 2 referring to Ms. Maxwell means that she didn't, 3 right? 4 MS. SCHULTZ: Object to form. 5 THE WITNESS: Say the question one more 6 time. 7 BY MR. PAGLIUCA: 8 9 Q. When we go through this report, and I've gone through it, if any of the alleged victims had 10 identified Ms. Maxwell as someone that they spoke to 11 at Mr. Epstein's house, you would have listed that 12 in your report, right? 13 MS. SCHULTZ: Object to form. 14 THE WITNESS: I believe I would have, yes. 15 16 BY MR. PAGLIUCA: Q. 17 18 Yeah. You tried to be thorough and accurate when you were writing your reports, right? 19 A. Yes. 20 Q. And, certainly, you've indicated on direct 21 examination that the identity of people who were at 22 the house was something that was important to your 23 investigation, correct? 24 A. Yes. 25 Q. And that's why you did trash pulls, right? Case 18-2868, Document 278, 08/09/2019, 2628230, Page497 of 648 Page 191 1 JOSEPH RECAREY - CONFIDENTIAL 2 A. Yes. 3 Q. And then you asked various individuals who 4 was there when you went to Mr. Epstein's house, 5 right? 6 A. Correct. 7 Q. And you then, to the best of your ability, 8 recorded those answers, I take it, as to who was 9 there, right? 10 A. Yes. 11 Q. And with regard to AH, she never said 12 anything about Ghislaine Maxwell being at 13 Mr. Epstein's house, did she? 14 MS. SCHULTZ: 15 foundation. 16 BY MR. PAGLIUCA: Object to form and 17 Q. To you? 18 A. I don't believe she did. 19 Q. Okay. 20 21 22 23 24 25 And if she did, it's likely that you would have recorded it, correct? A. Correct, and it would be on the -- it would be on the tape. Q. Right. She never claimed, AH, that Ms. Maxwell paid her, right? Case 18-2868, Document 278, 08/09/2019, 2628230, Page498 of 648 Page 192 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 MS. SCHULTZ: foundation. 4 5 6 Object to form and THE WITNESS: Correct. BY MR. PAGLIUCA: Q. She never claimed that -- AH never claimed 7 that Ms. Maxwell instructed her about what to wear, 8 correct? 9 MS. SCHULTZ: Object to the form. 10 THE WITNESS: Correct. 11 12 13 BY MR. PAGLIUCA: Q. AH never claimed that Ms. Maxwell told her how to act at Mr. Epstein's house, correct? 14 MS. SCHULTZ: Object to form. 15 THE WITNESS: Correct. 16 17 18 BY MR. PAGLIUCA: Q. AH never claimed to have met Ghislaine Maxwell anywhere, correct? 19 MS. SCHULTZ: Object to form. 20 THE WITNESS: I don't believe so, no. 21 22 BY MR. PAGLIUCA: Q. Okay. If we go on to individual alleged 23 victim No. 3, AY, the same question: AY never 24 identified Ms. Maxwell as someone she knew or 25 interacted with in any fashion, correct? Case 18-2868, Document 278, 08/09/2019, 2628230, Page499 of 648 Page 193 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to form. 3 THE WITNESS: No. 4 BY MR. PAGLIUCA: 5 Q. No, she did not? 6 A. No, she did not. 7 Q. Okay. The same with individual No. 4, 8 alleged victim FP: 9 met with Ms. Maxwell, correct? 10 11 MS. SCHULTZ: 14 15 Object to form and foundation. 12 13 Again, FP never claimed to have THE WITNESS: I don't believe so, no. BY MR. PAGLIUCA: Q. Okay. And FP never identified Ms. Maxwell as someone being at Mr. Epstein's house, correct? 16 MS. SCHULTZ: 17 foundation. 18 BY MR. PAGLIUCA: Object to form and 19 Q. And if you need to look at your report -- 20 A. No, I don't -- I don't believe so. The 21 only people that recalled Ghislaine at the house 22 was -- 23 Q. Sjoberg? 24 A. Johanna Sjoberg. 25 Q. Who was over the age of 18, correct? Case 18-2868, Document 278, 08/09/2019, 2628230, Page500 of 648 Page 194 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 MS. SCHULTZ: foundation. 4 THE WITNESS: 5 Venero. 6 BY MR. PAGLIUCA: 7 Q. MS. O'CONNOR: 9 THE WITNESS: 11 And Venero, Christina Who is an adult as well? 8 10 Object to form and Object to form. Yes. BY MR. PAGLIUCA: Q. So out of your entire report, the only two 12 people who ever said anything about Ms. Maxwell were 13 Ms. Sjoberg, who I believe was 23 when you 14 interviewed her? 15 A. 16 17 Right, but she was -MS. SCHULTZ: Object to form and foundation. 18 THE WITNESS: She was -- she had worked 19 there for quite some time, so you would have to 20 back up, I think, a year or two. 21 BY MR. PAGLIUCA: 22 Q. She was an adult when she worked there? 23 A. Right. 24 25 She was over the age of 18, right, let's put it that way. Q. And she was not listed by you as a victim Case 18-2868, Document 278, 08/09/2019, 2628230, Page501 of 648 Page 195 1 2 3 4 5 JOSEPH RECAREY - CONFIDENTIAL as part of this case, right? A. Correct, because it was between two consenting adults. Q. 6 Exactly. And so that's Ms. Sjoberg, and then the 7 other individual, I think you said Bolero; is that 8 right? 9 A. Venero, Christina Venero. 10 Q. Adult masseuse, correct? 11 A. Yes. 12 Q. Tatts, right. 13 She's a -- I remember she had lots of tattoos. But the 17 individuals that you listed in 14 Exhibit 1, none of those individuals ever said the 15 word -- the words "Ghislaine Maxwell" during the 16 course of this investigation to you, correct? 17 18 MS. SCHULTZ: foundation. 19 20 21 22 23 24 25 Object to form and THE WITNESS: I don't believe so. It would be on the tapes if they did. BY MR. PAGLIUCA: Q. Well, or it would be in your report, right? MS. SCHULTZ: foundation. Object to form and Case 18-2868, Document 278, 08/09/2019, 2628230, Page502 of 648 Page 196 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 4 5 6 THE WITNESS: Either in the report or on the tapes. BY MR. PAGLIUCA: Q. That's an interesting point, so let's talk about that for a moment. 7 This report, this Palm Beach Police 8 Department incident report, Exhibit 1, is a summary 9 of your investigation, correct? 10 A. Correct. 11 Q. And these recitations of your interviews 12 are abbreviated summaries, correct? 13 A. Correct. 14 Q. And so you're typing into this report 15 parts of it but not every word verbatim into the 16 report, correct? 17 A. Right. 18 Q. And, again, the originals of these tapes 19 are somewhere with the FBI at this point, correct? 20 21 MS. SCHULTZ: foundation. 22 23 24 25 Object to form and THE WITNESS: Correct. Or at the State Attorney's Office. BY MR. PAGLIUCA: Q. Are you aware of any of these originals Case 18-2868, Document 278, 08/09/2019, 2628230, Page503 of 648 Page 203 1 JOSEPH RECAREY - CONFIDENTIAL 2 That would be one. 3 another. 4 Q. Probably victim JB would be I believe there was a victim ML, as well. Let me ask this question: As you sit here 5 today, do you know who the subjects of the four 6 counts that are referenced on the first page of 7 Exhibit 7 are? 8 9 10 A. If I went through the entire PC affidavit, I could -- I could tell you who. But I just named three. 11 Q. Okay. 12 A. So, like I said, I can go through it and 13 14 15 16 tell you who exactly those four counts were for. Q. 19 We are limited to four, though, right? A. 17 18 Okay. Four instances. MS. SCHULTZ: Object to form. BY MR. PAGLIUCA: Q. 20 Right. And then throughout this entire 22-page, 21 Palm Beach Police Department affidavit, 22 Ms. Maxwell's name does not appear in here once, 23 does it? 24 MS. SCHULTZ: Object to form. 25 THE WITNESS: I don't believe so, no. Case 18-2868, Document 278, 08/09/2019, 2628230, Page504 of 648 Page 211 1 JOSEPH RECAREY - CONFIDENTIAL 2 A. Correct. 3 Q. And then Mr. Epstein is arrested and ends 4 up pleading guilty and all of that, right? 5 MS. SCHULTZ: Object to form. 6 THE WITNESS: I think there was a 7 non-prosecution agreement prepared between the 8 Feds and some kind of agreement was made. 9 yes, he did end up pleading guilty. 10 11 BY MR. PAGLIUCA: Q. 12 All right. Now, based on the questions that were 13 asked of you in the grand jury, it's fair to say 14 that Ms. Maxwell was not a target of the grand 15 jury's investigation, correct? 16 17 MS. SCHULTZ: Object to form and foundation. 18 THE WITNESS: Not based on the questions 19 that the state was asking me, no, the state 20 wasn't... 21 22 23 24 25 But, BY MR. PAGLIUCA: Q. In fact, it's fair to say that you never said Ms. Maxwell's name in the grand jury, right? MS. SCHULTZ: foundation. Object to form and Case 18-2868, Document 278, 08/09/2019, 2628230, Page505 of 648 Page 212 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 4 5 6 7 THE WITNESS: No. Based on the questions that the state was asking, no. BY MR. PAGLIUCA: Q. Were you aware of who was being issued subpoenas by the grand jury? A. No. But it wasn't the actual subpoena 8 from the grand jury; it came from the State 9 Attorney's Office. 10 11 Q. though, right? 12 13 At the direction of the grand jury, MS. SCHULTZ: foundation. 14 THE WITNESS: 15 don't know. 16 BY MR. PAGLIUCA: 17 Object to form and Q. I don't know. Again, I I would like to talk a little bit about 18 the surveillance that you initiated at Mr. Epstein's 19 house, okay? 20 21 22 23 Can you tell me when the surveillance began? A. It would have started under Detective Pagan and gone through -- 24 Q. The entire investigation? 25 A. Pretty much trash pulls. We stopped the Case 18-2868, Document 278, 08/09/2019, 2628230, Page506 of 648 Page 213 1 JOSEPH RECAREY - CONFIDENTIAL 2 actual physical surveillance sometime during the 3 investigation. 4 Pagan. 5 6 Q. But it would have started under Okay. Do you recall in what -- well, how was surveillance conducted, if you recall? 7 I didn't conduct it personally, no. That 8 would have been under plainclothes unit team. They 9 would have sent out a vehicle and recorded vehicles 10 A. coming and going and actual physical surveillance. 11 12 Q. So physical surveillance means eyes on the property, correct? 13 A. Right. 14 Q. And eyes on the property by a police 15 officer, correct? 16 A. Correct. 17 Q. And that police officer would be charged 18 with the obligation of recording the incomings and 19 outgoings of people to the property, correct? 20 A. Correct. 21 Q. Is there a log that's maintained during 22 surveillance? 23 A. I'm not sure who -- if there was a log or 24 not. I know that they set up a vehicle with cameras 25 facing -- facing Epstein's residence. Case 18-2868, Document 278, 08/09/2019, 2628230, Page507 of 648 Page 214 1 JOSEPH RECAREY - CONFIDENTIAL 2 Q. And so these were video cameras? 3 A. Correct. 4 Q. And so whoever was coming and going, 5 whenever -- an officer saw somebody coming or going, 6 they would videotape that person; is that correct? 7 8 9 10 11 A. Or they would just leave the video rolling, time lapse. Q. And did you have the opportunity to observe any of that video? A. I did observe a couple, but the person who 12 actually set it up would review it and then submit a 13 supplement to the report. 14 Q. Okay. It's true that none of the video of 15 the surveillance led to the identification of 16 Ghislaine Maxwell as coming or leaving the house 17 during the time of surveillance, correct? 18 19 MS. SCHULTZ: Object to form and foundation. 20 THE WITNESS: I don't know. I didn't see 21 all of the video, so I can't -- I can't attest 22 to that. 23 24 25 BY MR. PAGLIUCA: Q. Okay. Did anybody report to you that Ms. Maxwell was seen coming or going? Case 18-2868, Document 278, 08/09/2019, 2628230, Page508 of 648 Page 215 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to form, foundation. 3 THE WITNESS: I don't recall. 4 5 BY MR. PAGLIUCA: Q. If someone had reported to you that 6 Ms. Maxwell was seen coming or going, you would have 7 recorded it in your Palm Beach Police Department 8 incident report, Exhibit No. 1, correct? 9 10 MS. SCHULTZ: Object to form and foundation. 11 THE WITNESS: I would have told the 12 officer who was conducting the surveillance or 13 reviewing the video to document it in the 14 supplements. 15 16 BY MR. PAGLIUCA: Q. And there is no documentation in the 17 supplement of Ms. Maxwell either coming or going 18 from Mr. Epstein's house during this time frame, 19 correct? 20 MS. SCHULTZ: Object to the form. 21 THE WITNESS: I don't believe so. 22 23 24 25 I don't -- I don't -- I don't believe so. BY MR. PAGLIUCA: Q. And, again, so we're on the same page, when you say "I don't believe so," I interpret that Case 18-2868, Document 278, 08/09/2019, 2628230, Page509 of 648 Page 241 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 4 THE WITNESS: Correct. BY MR. PAGLIUCA: Q. And none of these individuals was employed 5 as a massage therapist at the time of their alleged 6 involvement with Mr. Epstein, correct? 7 A. Correct. 8 Q. Each of these individuals, as I recall, 9 10 claimed to have been paid directly by Mr. Epstein or Ms. Kellen, correct? 11 12 MS. SCHULTZ: foundation. 13 14 15 Object to form and THE WITNESS: Correct. BY MR. PAGLIUCA: Q. Most often, these individuals, these 17 16 individuals, were paid directly by Mr. Epstein, 17 correct? 18 19 MS. SCHULTZ: foundation. 20 21 22 Object to form and THE WITNESS: Mr. Epstein or Sarah Kellen. BY MR. PAGLIUCA: Q. Okay. None of these individuals identify 23 Ms. Maxwell as someone who was paying them money, 24 correct? 25 MS. SCHULTZ: Object to form and Case 18-2868, Document 278, 08/09/2019, 2628230, Page510 of 648 Page 242 1 2 JOSEPH RECAREY - CONFIDENTIAL foundation. 3 4 5 6 THE WITNESS: I don't believe so, no. BY MR. PAGLIUCA: Q. And each of these individuals identified receiving cash, correct? 7 MS. SCHULTZ: Object to the form. 8 THE WITNESS: Correct. 9 10 BY MR. PAGLIUCA: Q. Each of these individuals claimed varying 11 amounts, generally between $200 and up to $1,000, 12 correct? 13 MS. SCHULTZ: Object to form. 14 THE WITNESS: Correct. 15 16 BY MR. PAGLIUCA: Q. According to each of these individuals, 17 Mr. Epstein, when the massage was over, would either 18 hand them the money -- that happened according to 19 these individuals, right? 20 MS. SCHULTZ: Object to form. 21 THE WITNESS: At times, yes. 22 23 BY MR. PAGLIUCA: Q. Or Mr. Epstein had laid out the money 24 somewhere and directed them to where to go get it, 25 correct? Case 18-2868, Document 278, 08/09/2019, 2628230, Page511 of 648 Page 257 1 JOSEPH RECAREY - CONFIDENTIAL 2 A. I don't believe clothing was seized. 3 Q. To your knowledge, did you seize any 4 property belonging to Ghislaine Maxwell from the 5 home? 6 7 MS. SCHULTZ: foundation. 8 THE WITNESS: 9 knowledge. 10 BY MS. SCHULTZ: 11 Object to form and Q. Okay. I'm not sure. Not to my No one ever came to you and said, 12 Could you please return these items to Ms. Maxwell, 13 correct? 14 MS. SCHULTZ: Object to form. 15 THE WITNESS: No. 16 17 BY MS. SCHULTZ: Q. 18 All right. You did that with Janush? 19 A. Yes, he had photos and -- 20 Q. But nothing like that ever happened with 21 Ms. Maxwell, correct? 22 MS. SCHULTZ: Object to form. 23 THE WITNESS: No. 24 25 BY MS. SCHULTZ: Q. Ms. Maxwell was not present when you Case 18-2868, Document 278, 08/09/2019, 2628230, Page512 of 648 Page 259 1 2 JOSEPH RECAREY - CONFIDENTIAL Q. Any way that you get contacted by a police 3 officer, if they put it into your database, it will 4 come up when you do the CAD search, correct? 5 A. Right. 6 Q. And that's all that came up with regard to 7 Ms. Maxwell, was her name was somewhere in the 8 system. 9 10 Do you know or not know? MS. SCHULTZ: Object to form and foundation. 11 THE WITNESS: I don't know. 12 MR. PAGLIUCA: 13 (The referred-to document was marked by Okay. 14 the court reporter for Identification as 15 Deposition Exhibit 12.) 16 17 BY MR. PAGLIUCA: Q. I have handed you what has been marked as 18 Deposition Exhibit 12, which I will represent to you 19 are the Plaintiff in this case, Ms. Giuffre's Rule 20 26 disclosure. 21 22 I want to just go through very quickly and ask you if you know any of these individuals. 23 24 25 So, let's start with No. 1, Virginia Giuffre. A. Have you ever met Virginia Giuffre? No. Case 18-2868, Document 278, 08/09/2019, 2628230, Page513 of 648 Page 260 1 JOSEPH RECAREY - CONFIDENTIAL 2 Q. Have you ever talked to her? 3 A. I don't recall. 4 Q. Do you know what information that she may 5 have that's referenced below? 6 subject of this action. 7 of that? 8 MS. O'CONNOR: 9 THE WITNESS: 10 11 12 Do you have any knowledge Object to form. No. BY MR. PAGLIUCA: Q. Number 2, Ghislaine Maxwell, I'm going to come back to her. 13 14 Conducted is the Number 3, Juan Alessi, you did interview Mr. Alessi, correct? 15 A. Yes. 16 Q. I have seen a transcript of that 17 interview, and I have seen Exhibit 2, which is a 18 transcript of the interview with Ms. 19 to ask you a couple of questions about the 20 transcription process. 21 . I want As I understand your testimony previously, 22 the electronic recordings are sent somewhere, you 23 don't know where, for transcription; is that right? 24 MS. SCHULTZ: Object to form. 25 THE WITNESS: I didn't request a Case 18-2868, Document 278, 08/09/2019, 2628230, Page514 of 648 Page 274 1 JOSEPH RECAREY - CONFIDENTIAL 2 different investigators Mr. Black uses in a 3 particular calendar year, do you? 4 MS. SCHULTZ: Object to form. 5 THE WITNESS: No. 6 7 BY MR. PAGLIUCA: Q. And so you don't know whether Mr. Black's 8 association with this law firm was in connection 9 with Mr. Epstein's case or some other case, do you? 10 MS. SCHULTZ: Object to form. 11 THE WITNESS: I worked this case, 12 nothing -- nothing but this case for an entire 13 year. 14 This was my only case for a year. BY MR. PAGLIUCA: 15 Q. Okay. 16 A. If it walks like a duck. 17 18 19 20 That's it? MS. SCHULTZ: Objection. BY MR. PAGLIUCA: Q. Okay. So we're finished with Dershowitz. Keep on going. 21 A. Number 28, obviously, 22 Q. Okay. 23 A. Right. 24 Q. And, again, she never discussed Ghislaine 25 . And you've talked about her? Maxwell with you, correct? Case 18-2868, Document 278, 08/09/2019, 2628230, Page515 of 648 Page 278 1 2 JOSEPH RECAREY - CONFIDENTIAL Q. Right. So you're 75. So I want you -- I 3 want to take a moment and read what's under 75: 4 "Detective Recarey was the chief investigator of the 5 crimes committed at Jeffrey Epstein's Palm Beach 6 mansion." Is that true? 7 MS. SCHULTZ: Object to form. 8 THE WITNESS: Yes. 9 10 BY MR. PAGLIUCA: Q. "And has information about Ghislaine 11 Maxwell and Jeffrey Epstein's sexual trafficking 12 conduct and interaction with underaged minors." 13 Tell me everything that you believe you 14 know about Ghislaine Maxwell's sexual trafficking 15 conduct. 16 MS. SCHULTZ: Object to form. 17 THE WITNESS: I don't. 18 19 BY MR. PAGLIUCA: Q. So that's inaccurate, then? I mean, you 20 have no knowledge about Ghislaine Maxwell sexually 21 trafficking anybody, do you? 22 MS. SCHULTZ: Object to form. 23 THE WITNESS: Not with -- not with the 24 25 girls that I spoke with, no. Case 18-2868, Document 278, 08/09/2019, 2628230, Page516 of 648 Page 279 1 2 JOSEPH RECAREY - CONFIDENTIAL BY MR. PAGLIUCA: 3 Q. But that's your investigation, right? 4 A. Right. 5 Q. Okay. 6 A. Right. 7 8 9 Let's see. Q. And you've talked about her. Whatever happened to her, do you know? 10 11 Okay. Seventy-six. MS. SCHULTZ: Object to form. BY MR. PAGLIUCA: 12 Q. Haley Robson? 13 A. No. 14 Q. She was never charged, as I understand it, 15 correct? 16 A. Correct. 17 Q. And after you spoke to her in connection 18 with your investigation, did you ever speak to her 19 again? 20 A. No. 21 Q. Okay. 22 A. David Rogers, 77. 23 Q. And you know him because he was identified 24 25 as one of the pilots for Mr. Epstein, right? A. Right. Case 18-2868, Document 278, 08/09/2019, 2628230, Page517 of 648 Page 289 1 2 JOSEPH RECAREY - CONFIDENTIAL in your mind, right? Correct? 3 MS. SCHULTZ: Object to the form. 4 THE WITNESS: Yes. 5 6 BY MR. PAGLIUCA: Q. And you're a peace officer, obligated to 7 arrest when a felony is committed in your presence, 8 correct? 9 A. Correct. 10 Q. And the possession of child pornography is 11 a felony, correct? 12 A. Correct. 13 Q. And had you seen any child pornography in 14 Mr. Epstein's house when you were there installing 15 these cameras, you would have done something about 16 it, correct? 17 MS. SCHULTZ: Object for form. 18 THE WITNESS: Right. 19 20 21 BY MR. PAGLIUCA: Q. You wouldn't have just walked out and said, Nice pics, have a nice day, correct? 22 A. Correct. 23 Q. So is it fair to say the entire time you 24 were in Epstein's house, whether it's 2002, 2003, 25 you did not observe any child pornography, right? Case 18-2868, Document 278, 08/09/2019, 2628230, Page518 of 648 Page 290 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to the form. 3 THE WITNESS: Not in the areas I was in. 4 5 6 BY MR. PAGLIUCA: Q. You don't recall seeing any pictures of naked women, do you? 7 MS. SCHULTZ: Object to form. 8 THE WITNESS: Again, I was only confined 9 to where that desk was. That's where I set up 10 the camera, and then after it was set up, I 11 left. 12 BY MR. PAGLIUCA: 13 Q. Okay. But, again, all I'm asking you is 14 wherever you were, you didn't see any pictures of 15 naked women? 16 A. Right. 17 Q. And at the time you recall that he had No, I didn't see any. 18 these surveillance cameras already installed; is 19 that true? Other cameras, the clock cameras? 20 MS. SCHULTZ: Object to form. 21 THE WITNESS: I'm not sure if he had the 22 23 24 25 cameras installed or not. I can't recall. BY MR. PAGLIUCA: Q. Why would he need your cameras if he already had cameras? Case 18-2868, Document 278, 08/09/2019, 2628230, Page519 of 648 Page 300 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 None of these alleged victims claimed to have ever traveled with Mr. Epstein, correct? 4 MS. SCHULTZ: Object to form. 5 THE WITNESS: No. 6 7 8 BY MR. PAGLIUCA: Q. No, they did not? They did not travel with Mr. Epstein, right? 9 MS. SCHULTZ: Object to form. 10 THE WITNESS: I don't believe so, no. 11 BY MR. PAGLIUCA: 12 Q. None of them reported that to you? 13 A. Not reported, correct. 14 Q. None of them reported to you that they 15 ever spent the night with Mr. Epstein, did they? 16 MS. SCHULTZ: Object to form. 17 THE WITNESS: I don't believe so. 18 19 20 BY MR. PAGLIUCA: Q. None of them ever reported being trafficked by Mr. Epstein to other men, correct? 21 MS. SCHULTZ: Object to form, foundation. 22 THE WITNESS: I don't believe so. 23 24 25 BY MR. PAGLIUCA: Q. The only other men that any of these alleged victims -- the only man that any of these Case 18-2868, Document 278, 08/09/2019, 2628230, Page520 of 648 Page 301 1 JOSEPH RECAREY - CONFIDENTIAL 2 alleged victims ever claimed to have any contact 3 with that was sexual in nature was Mr. Epstein, 4 correct? 5 MS. SCHULTZ: 6 foundation. 7 8 Object to form and THE WITNESS: Yes. BY MR. PAGLIUCA: 9 Q. Okay. None of these alleged victims ever 10 claimed to have been sent to another location to 11 have sex with another man, correct? 12 13 MS. SCHULTZ: foundation. 14 15 16 17 THE WITNESS: I don't believe so. BY MR. PAGLIUCA: Q. Meaning my statement is correct; is that right? 18 19 Object to form and MS. SCHULTZ: Object to form. BY MR. PAGLIUCA: 20 Q. I'm just trying to -- 21 A. Meaning I don't believe they've ever said 22 23 that. I don't recall any of them ever saying... Q. Had they claimed that they were sent 24 somewhere else to have sex with another man, you 25 would have followed up on that, correct? Case 18-2868, Document 278, 08/09/2019, 2628230, Page521 of 648 Page 302 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to form. 3 THE WITNESS: Correct. 4 5 BY MR. PAGLIUCA: Q. And none of them ever claimed to have been 6 sent to another location to give another man a 7 massage, correct? 8 MS. SCHULTZ: Object to form. 9 THE WITNESS: No, not the victims. 10 BY MR. PAGLIUCA: 11 Q. Right. That's who I'm talking about. 12 A. I believe 13 Q. Who is an adult, right? did. 14 MS. SCHULTZ: Object to form. 15 THE WITNESS: Right. 16 17 18 BY MR. PAGLIUCA: Q. We covered this, I believe: None of them ever was on Mr. Epstein's airplane, correct? 19 MS. SCHULTZ: Object to form. 20 THE WITNESS: I believe one of the victims 21 were, but not to a private island. 22 they went -- they didn't go to a private 23 island; they went to some other trip. 24 25 I think BY MR. PAGLIUCA: Q. I think maybe you're referring to AH, who Case 18-2868, Document 278, 08/09/2019, 2628230, Page522 of 648 Page 303 1 JOSEPH RECAREY - CONFIDENTIAL 2 went to New York but on a commercial flight. 3 that jog your memory? 4 MS. SCHULTZ: Object to form. 5 THE WITNESS: No. 6 BY MR. PAGLIUCA: 7 Q. Okay. 8 A. It would have been FP. 9 Q. Okay. Do you recall who it is? Was on Mr. Epstein's airplane? 10 MS. SCHULTZ: Object to form. 11 THE WITNESS: I believe so. 12 13 Does BY MR. PAGLIUCA: Q. Would that be reflected in Exhibit 1? 14 MS. SCHULTZ: Object to form. 15 THE WITNESS: But she flew alone. It 16 wasn't like Epstein was there. 17 someplace else, not to his private island, 18 nothing to do with Epstein. 19 she wanted to do. 20 plane, but it was, like, her by herself. 21 BY MR. PAGLIUCA: 22 Q. Alone. 23 A. Right. 24 Q. With a pilot? 25 A. Right. She went It was something And I think she flew on his Case 18-2868, Document 278, 08/09/2019, 2628230, Page523 of 648 Page 304 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 4 MS. SCHULTZ: Object to form. BY MR. PAGLIUCA: Q. None of the alleged victims in your 5 investigation claimed to have gone to the Caribbean 6 island of Little St. James, correct? 7 MS. SCHULTZ: Object to form. 8 THE WITNESS: No. 9 10 11 BY MR. PAGLIUCA: Q. "No" meaning they never went there, correct? 12 MS. SCHULTZ: Object to form. 13 THE WITNESS: Not that I'm aware of. 14 15 BY MR. PAGLIUCA: Q. None of the alleged victims ever went to 16 Mr. Epstein's New York residence, to your knowledge, 17 correct? 18 MS. SCHULTZ: Object to form. 19 THE WITNESS: Not that I'm aware of. 20 21 BY MR. PAGLIUCA: Q. None of them ever reported that to you? 22 MS. SCHULTZ: Object to form. 23 THE WITNESS: No. 24 25 BY MR. PAGLIUCA: Q. Okay. And none of them ever claimed to Case 18-2868, Document 278, 08/09/2019, 2628230, Page524 of 648 Page 305 1 JOSEPH RECAREY - CONFIDENTIAL 2 have been outside of the country with Mr. Epstein, 3 ever, correct? 4 MS. SCHULTZ: Object to the form. 5 THE WITNESS: Not that I'm aware of. 6 MR. PAGLIUCA: 7 Can we go off for a second? Time check. 8 THE VIDEOGRAPHER: 9 (Thereupon, a recess was taken, after 10 which the following proceedings were held:) 11 12 Off the record at 4:13. THE VIDEOGRAPHER: On the record at 4:14. BY MR. PAGLIUCA: 13 Q. Can you take a look at Exhibit 4, please? 14 A. Which one is 4? 15 Q. Four is the True Copy. 16 says at the top. Exhibit 4. That's what it Six pages. 17 A. Yes. 18 Q. Do you have that? 19 A. Yes, sir. 20 Q. There's yellow highlighting on the exhibit 21 that's in front of you. 22 Do you know how that got there? 23 A. No. 24 Q. And there's a -- there are numbers, item 25 numbers. Do you see that in the left column? Case 18-2868, Document 278, 08/09/2019, 2628230, Page525 of 648 Page 365 2 3 CERTIFICATE OF OATH 4 STATE OF FLORIDA ) 5 COUNTY OF MIAMI-DADE ) 6 7 I, the undersigned authority, certify 8 that JOSEPH RECAREY personally appeared before me 9 and was duly sworn. 10 11 WITNESS my hand and official seal this 24th day of June, 2016. 12 13 KELLI ANN WILLIS, RPR, CRR 14 Notary Public, State of Florida My Commission No. EE911443 15 Expires: 2/16/16 16 + + + + + + + + + + + + + + + + + + 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page526 of 648 Page 366 2 3 4 C E R T I F I C A T E STATE OF FLORIDA ) : ss 5 COUNTY OF MIAMI-DADE ) 6 I, KELLI ANN WILLIS, a Registered 7 Professional, Certified Realtime Reporter and 8 Notary Public within and for The State of 9 Florida, do hereby certify: 10 That JOSEPH RECAREY, the witness whose 11 deposition is hereinbefore set forth was duly 12 sworn by me and that such Deposition is a true 13 record of the testimony given by the witness. 14 I further certify that I am not related 15 to any of the parties to this action by blood 16 or marriage, and that I am in no way interested 17 in the outcome of this matter. 18 19 IN WITNESS WHEREOF, I have hereunto set my hand this 24th day of June, 2016. 20 21 __________________________ KELLI ANN WILLIS, RPR, CRR 22 23 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page527 of 648 EXHIBIT HH Case 18-2868, Document 278, 262?230, Page528 Qi?48 (Jase Document 435?3 Filed 09/15/16 Page 2 of 6 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 EDWARDS, et 01., Plainti?s Counterclaim Defendants, V. DERSHOWITZ, Defendant Counterclaim Plaintiff. AFFIDAVIT 0F JUAN P. ALESSI REGARDING KNOWLEDGE 0F ALAN M. DERSHOWITZ A. Introduction 1. My name is Juan P. Alessi. I make this declaration voluntarily and without compensation on personal knowledge concerning Alan Dershowitz and his visits at my former employer Jeffrey Epstein?s home in Palm Beach, Florida. I worked for Mr. Epstein from January 1991 to December 2002 as a full-time employee performing maintenance services and then also became the manager for the home on 358 El Brillo Way in Palm Beach, Florida. Since Mr. Epstein was investigated and arrested, I have spoken with police, investigators, and attorneys concerning my time working for Mr. Epstein. On September 8, 2009, I gave a deposition in the case captioned Jane Doe No. 2 v. Jef??ey Epstein, Case No. in which I truthfully answered the questions posed by the attorneys. I also gave a sworn statement on November 21, 2005 to Case 18-2868. Document 278. 08/09/2019. 2628230. Paoe529 of 648 Case Document 435?3 Filed 09/15/16 Page 3 of 6 Detective Joseph Recarey of the Palm Beach P.D. during their investigation of Mr. Epstein. . I have reviewed the statements that Bradley Edwards and Paul Cassell attribute to me in their papers in the cases against the Government and against Mr. Dershowitz. Because I do not believe they accurately re?ect the statements I previously made, I submit this affidavit to have my statements accurately reflected and made clear on the record. . Summary of My Knowledge of Massages at Mr. Epstein?s Palm Beach Home . As I stated in my deposition, a massage was like a treat for all the guests at Mr. Epstein?s home. Mr. Epstein usually received his massages in his private suite, but guests would also be given massages in their respective rooms or by the pool area. . There were between ?fty (50) to one hundred (100) masseuses mostly women but also some men - who would come to give massages during this time. I provided names of masseuses in my deposition. . As I stated in my deposition, I was unaware of any masseuses being under the age of 18. I believed that the females? age ranged from overage to maybe mid-forties. As I stated in my deposition, I received as a gift a massage from a male masseuse at Mr. Epstein?s home in Palm Beach. . In my deposition, I was asked about cleaning up after massages. I stated that when I cleaned Mr. Epstein?s bedroom suite, which included the bathroom of Ms. Maxwell, after massages, I would, on occasion, ?nd vibrators and sex toys. I have speci?c recollection of ?nding these items in the sink of Ms. Maxwell?s bathroom. I did not state or imply that vibrators or sex toys were found a?er massages in other rooms used by guests because that was not the case. Guests having massages did not have 2 10. 11. 12. 13. Case 18-2868. Document 278. 08/09/2019. 2628230. P6108530 of 648 Case Document 435?3 Filed 09/15/16 Page 4 of 6 massages in Mr. Epstein?s private bedroom suite. This area was private and off?limits to guests, which I explained to the lawyers during my deposition. As I said in my deposition, massage tables were located in almost every room, including guest rooms and by the pool. I never found, and never heard anyone in the house ?nding, a vibrator or a sex toy in the same room where any guest, including Alan Dershowitz, had a massage. The following statement made by Virginia Roberts?s attorneys in a ?ling on January 21, 2015 is not accurate and is a misrepresentation of what I said in my deposition: ?The private, upstairs room where Dershowitz got his ?massages? was one that contained a lot of vibrators Maxwell had ?a laundry basket . . . full of those toys? in that room.? Summary of My Interaction with Alan M. Dershowitz During the approximate thirteen years I worked for Mr. Epstein, I believe I saw Mr. Dershowitz visit Mr. Epstein?s Palm Beach home approximately four or ?ve times a year. I recall driving him to the airport on multiple occasions. At the time, I understood that Mr. Dershowitz was a famous lawyer. His visits to the house would typically involve a group of intellectuals or business men in social, but professional type gatherings. I can recall that Mr. Dershowitz had a massage on at least one occasion during a visit to Mr. Epstein?s home in Palm Beach (although I cannot recall that Mr. Dershowitz received a massage on more than one occasion). I do not recall Mr. Dershowitz being massaged by anyone whorl thought was less than 18 years old. I have no reason to doubt Mr. Dershowitz?s statement that this massage was done by a woman named Olga who was in her forties. In fact, I do remember a masseuse named Olga that 3 14. 15. Case 18-2868, Document 278I 08/09/2012, 2628230, Page531 of 648 Case Document 435-3 Filed 09/15/16 Page 5 of 6 lived in Palm Beach, though I do not know her last name. As I have said, I never saw Mr. Dershowitz around young girls. I have also explained that there were masseuses, both male and female, that were in their mid?forties. I never saw Mr. Dershowitz do anything improper or be present while anyone else was being improper. Before asking me about Jeffrey Epstein speaking to celebrities at the house, the attorney for ?Jane Doe 102? asked me about Jean Luc Brunel, Mark Epstein, Daniel Estes, Matt Groening, and Leslie Wexner. I then listed Senator Mitchell, Prince Andrew, Princess Sarah Ferguson, Miss Yugoslavia, Miss Germany, Alan Dershowitz, Princess Diana?s secretary with her children, Mr. Trump, Mr. Robert Kennedy, Jr., Frederik Fekkai, and a couple Noble prize winners as celebrities that I had seen while working for Mr. Epstein. I also mentioned a reunion of Nobel prize winners that was held at the house, and that I met President Clinton at Mr. Epstein?s plane the last month that I was working for Mr. Epstein. C. Summary of My Interaction with Virginia Roberts 16. 17. 18. The ?rst time I saw Virginia Roberts was at Mar?a?Lago where I believed she worked in the spa. I only recall seeing Virginia Roberts come to Mr. Epstein?s house during the last year that I worked for Mr. Epstein. During this time, I believe she visited Mr. Epstein?s home in Palm Beach two or three times a week. I never saw any photographs of Virginia Roberts in Mr. Epstein?s house. I was shown a photo of Virginia Roberts during my deposition, and I recognized the woman in the photo as Virginia Roberts. As I stated in my deposition, I am not sure whether Virginia Roberts came to the house when Prince Andrew was there. Case 18-2868, Document 278, 08/09/2019, 2628230, Page532 of 648 Case Document 435?3 Filed 09/15/16 Page 6 of 6 19. was never asked by any attorneys if Virginia Roberts came to the house when Mr. Dershowitz was there. If I had been asked, I would have answered that I never saw Virginia Roberts at the house when Mr. Dershowitz was there. 20. The following statement made by Virginia Roberts?s attorneys and their own attomey in a ?ling on December 4, 2015 is not accurate and is a misrepresentation of what I said in my deposition: ?Alessi was able to identify a photograph of Ms. Giuffre as someone who was at the mansion as the same time as Dershowitz.? 21. As far as I can recall, since I gave my deposition in 2009, I have never been asked by Brad Edwards or Paul Cassell about my knowledge regarding Virginia Roberts or Alan Dershowitz or about my 2009 deposition testimony. I understand that I am swearing or af?rming under oath to the truthfulness of the claims made in this af?davit and that the punishment for knowingly making a false statement includes fines and/or imprisonment. Dated: January 13, 2016 STATEOF COUNTY OF i?w?Jq @Eze-pw Sworn to or affirmed and signed before rum uJL-o atrium-.5 ItC-euhs-o. ?41-685; WTARY PUBLIC or DEPUTY CLERK A U?r 1? A- . Cab Hrs-7?7 [Print, type, or stamp commissioned name of notary or clerk.] Case 18-2868, Document 278, 08/09/2019, 2628230, Page533 of 648 EXHIBIT II Case 18-2868, Document 278, 08/09/2019, 2628230, Page534 of 648 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, P1a1nt1ffs, -vs- CONFIDENTIAL ALAN M. DERSHOWITZ, Defendant. VIDEOTAPED DEPOSITION OF VIRGINIA ROBERTS GIUFFRE Saturday, January 16, 2016 9:07 a.m. - 2:48 p.m. 401 East Las 01as BTvd., Suite 1200 Fort LauderdaTe, F10r1da 33301 Reported By: Deborah A. Harris, Court Reporter Notary Pub11c, State of F10r1da Phone - 305.651.0706 Job No. J0277789 CONFIDENTIAL GIUFFRE005093 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page535 of 648 APPEARANCES: 0n behaif of the PTaintiffs: Jack Scaroia, Esquire SEARCY, DENNEY, SCAROLA, BARNHART SHIPLEY, P.A. 2139 PaTm Beach Lakes Bouievard West Paim Beach, Fiorida 33409 (561) 686-6300 0n behaif of the Deponent: Sigrid McCawTey, Esquire BOIES, SCHILLER FLEXNER, LLP 401 East Las Dias Bouievard, Suite 1200 Fort Lauderdaie, Fiorida 33301 (954) 356-0011 0n behaif of the Defendant: Mary Borja, Esquire WILEY REIN, LLP 1776 Street NW Washington, DC 20006 (202) 719-7000 0n behaif of the Defendant: Richard Simpson, Esquire WILEY REIN, LLP 1776 Street NW Washington, DC 20006 (202) 719-7000 0n behaif of the Defendant: Thomas E. Scott, Esquire COLE, SCOTT KISSANE, P.A. 9150 South Dadeiand Bouievard, 14th Fioor Miami, Fiorida 33156 (305) 350-5300 0n behaif of the Defendant: Kenneth A. Sweder, Esquire SWEDER ROSS, LLP 131 01iver Street. Boston, Massachusetts 02110 (617) 646-4466 CONFIDENTIAL GIUFFRE005094 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page536 of 648 ALSO PRESENT Edward J. PozzuoTi, SpeciaT Master Robert Pacheco, Videographer Ryan Kick, Videographer BradTey J. Edwards PauT G. CasseTT ATan M. Dershowitz Brittany N. Henderson, Esq. Meridith Schuth, Esquire I WITNESS DIRECT CROSS REDIRECT Virginia Roberts Giuffre By Ms. Borja 5 By Mr. ScaroTa 201 By Ms. Borja 204 I I DEFENDANT VR EXHIBITS - Notice. - DiscTosure Tist. - Order. - E-maiT. Photo (ConfidentiaT) - ArticTe. - DaiTy Mai]. - DaiTy Mai]. - DecTaration. FBI doc. I _x CD I RECROSS FOR ID 6 26 59 92 100 124 155 168 170 187 NOTE: Exhibit 5 marked confidentiaT, seaTed, and retained by the SpeciaT Master. CONFIDENTIAL GIUFFRE005095 CONFIDENTIAL MR. SCAROLA: It is a minor discrepancy, but I think you read it as when she was a minor and it's whi1e she was a minor. BY MS. BORJA: Q. Whi1e she was a minor. Do you see where I'm reading starting in the third 1ine? A. Yes. Q. Is that a11egation true? A. Yes. Q. If you go to page 6 of the document, do you see the paragraph that's starts, Epstein a1so trafficked? A. Yes. Q. Is says Epstein a1so trafficked Jane Doe #3 for sexua1 purposes to many other powerfu1 men inc1uding numerous prominent American poiiticians, powerfu1 business executives, foreign presidents, a we11-known prime minister and other wor1d 1eaders. Do you see that? A. Yes. Q. Is that a11egation true? A. Yes. Q. The reference there to foreign presidents, do you see that? A. Yes. Q. You were sexua11y trafficked to foreign presidents? CONFIDENTIAL GIUFFRE005102 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page538 that's not true, you were not sexua11y trafficked to foreign presidents? A. I don't know what foreign president you're ta1king about. Q. Have you ever been sexua11y trafficked to any foreign president? MS. MCCAWLEY: I'm going to a110w you to ask that question, but with respect to specific identification of an individua1 we're not going to do that. At this point she has. MS. BORJA: Counsei, your objection has been made. No speaking objections, p1ease. Let's move on. MS. MCCAWLEY: I can make my record, and my record is she's not going to be speaking with respect to individua1s' names that are named in genera1ities in this document. SPECIAL MASTER: Objection overru1ed. You can answer. A. I understand we11-known prime ministers and other wor1d 1eaders; as far as foreign presidents, I'm not too sure, I don't know. Q. Have you ever met any foreign presidents? A. Foreign presidents as in overseas? CONFIDENTIAL GIUFFRE005103 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page539 of 648 12 Q. Sure, okay, overseas. A. No. Q. Have you ever met any foreign presidents from countries not overseas such as Canada or Mexico? A. No. Q. So you were not sexua11y trafficked to any foreign presidents; is that correct? A. As far as I know right now, yes. Q. It's correct that you were not sexua11y trafficked to them, right? A. You've asked me this three times and I'm te11ing you. Q. Okay. A we11-known prime minister. Were you sexua11y trafficked to a we11-known prime minister? A. Yes. Q. Who was that? MS. MCCAWLEY: I'm going to object to this 1ine of questioning. This has to do with safety concerns for her. MS. BORJA: Counsei, this is under sea1. You can answer. MS. MCCAWLEY: No, she's not going to answer. SPECIAL MASTER: Hang on one second. MS. MCCAWLEY: Let me make my objection. CONFIDENTIAL GIUFFRE005104 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page540 of 648 15 SPECIAL MASTER: Okay. I can't twist her arm and force her so we'11 dea1 with it. BY MS. BORJA: Q. Okay. Other wor1d 1eaders, what other wor1d 1eaders were you sexua11y trafficked to? MS. MCCAWLEY: We have the same objection. SPECIAL MASTER: And I wou1d have the same ru1ing based upon the arguments. MS. MCCAWLEY: Let me just make my record. To the extent that there's a name of an individua1 that you can revea1 that you do not fee1 wou1d harm your physicai safety, you're weicome to revea1 them. Anybody eise, you don't have to revea1 at this time and we'11 take that to Judge A. Okay. Prince Andrew for one. Q. Other than Prince Andrew? A. There is another individua1 that I honest1y do not know his name. Q. What country is he from? A. I'm not too sure, he spoke in a foreign -- he did speak foreign tongue, he spoke Eng1ish as we11, but I'm not too sure where he was from. Q. How do you know he is wor1d 1eader? A. I was introduced to him as a prince. CONFIDENTIAL GIUFFRE005107 CONFIDENTIAL (when I was with him. A. Q. trafficked to 16 Okay. Did he have security with him? I'm sure he did somewhere around, but not Did you see security? No. Did you -- where were you when you met him? On this occasion the South of France. Are there witnesses to you being sexua11y this prince? Yes. Name them. Jeffrey Epstein, GhisTaine MaxweTT. Anyone e1se? There was a whoTe bunch of peopTe in the room so of course. their names. Q. A. Was this an orgy? No. Who eise was in the room? I can't name them a11, there was a Tot. Name as many as you can name? I don't know their names. I can't name They were present during sexua1 activity? They were present before the sexuaT activity and then I went to have sexuaT activity with him CONFIDENTIAL GIUFFRE005108 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page542 of 648 17 aione. Q. So he's the on1y witness to your sexuai activity, the prince? A. On the instruction of Epstein and Ghis1aine, yes. Q. Where in the South of France were you? A. I don't know. Q. Were you on a boat, were you in a house? A. We were at a 1ike a cabana, not cabana, 1ike a resort, but it was a big party. Q. Who was throwing the party? A. I don't know. I was just brought there. Q. You aiso refer to powerfu1 business executives. What powerfu1 business executives were you sexua11y trafficked to? MS. MCCAWLEY: Again, to the extent you can revea1 somebody without a safety concern you're weicome to do that. SPECIAL MASTER: We11, again -- MS. MCCAWLEY: Right. I understand. SPECIAL MASTER: Same objection, same ru1ing. A. George Mitche11. Q. When were you sexua11y trafficked to George Mitche11? CONFIDENTIAL GIUFFRE005109 CONFIDENTIAL h) 01 64 Q. Do you have the origina1s? A. Again, between the FBI and giving them to my 1awyers and Sharon Churcher, the circu1ation, I'm not too sure if I have the originais. I know I have copies. So I'm not too sure if they're the origina1s. Q. The book1et that you gave pages from to Ms. Churcher where is that book1et? A. Burned. Q. When did you burn it? A. In, I think it was 2013. Me and my husband had a bonfire. Q. What did you put in the bonfire? A. Any kind of memories that I had written down about a1] the stuff going on. Q. Had you written anything about Professor Dershowitz? A. He cou1d have been there, yes. Q. And you burned that? A. I wanted to burn my memories. I wanted to get rid of it. It was very painfu1 stuff. Q. Other than what you had written down did you burn anything e1se? I don't mean the wood, when you ta1k about burning your memories, what were you burning? A. I was burning 1ike memories, thoughts, dreams that I had, just everything that was kind of CONFIDENTIAL GIUFFRE005156 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page544 of 648 65 with the abuse I endured, and there was a Iot of it in there. My husband is pretty spiritua1 so he said the best thing to do wou1d be burn them. Q. Is there anything you decided to keep and not burn? A. Just the photographs. Q. Anything e1se that you can think of? A. Photographs, that's it. Q. Approximateiy when in 2013 was this bonfire? A. I don't know what month it was. Q. Did you do it outside? A. Yeah, it was outside. I wasn't going to do it in my 1iving room. Q. Did it fee1 good to be ciose to the fire because it was coid out or was it a summertime bonfire? A. I be1ieve I had just bought my house in Titusvi11e, Fiorida. I bought my house in, I think, I either got it October or November of 2013. It wou1d have been around probab1y November. Q. Why did you decide to keep the photos? A. They're evidence. Q. Do you have any photographs of yourse1ves with Professor Dershowitz? A. No. CONFIDENTIAL GIUFFRE005157 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page545 of 648 85 Beach, I've seen him in New York. So I mean, if we're going to pin point how many times I've seen him or the next time I saw him after that I don't know. Q. Then te11 me -- Tet's do it this way, what was the most recent time that you recaTT having sex with Professor Dershowitz? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. The first time I recaTT having sex with Professor Dershowitz was in New York. Q. My question was, the most recent time now. What's the most current, most recent memory of having sex with Professor Dershowitz? MS. MCCAWLEY: Objection. Just so I'm c1ear, you're going backward? MS. BORJA: Correct. MS. MCCAWLEY: The Tast time. A. The Tast time that I remember having sex with him? Okay. I beTieve it was on an airpTane. Q. Where were you going? A. On, I beTieve it was Massachusetts. I don't know. It's very hard for me to remember exactTy where we were going, what were the circumstances. Q. So that's the time you testified about earTier? CONFIDENTIAL GIUFFRE005177 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page546 That were providing massages to Jeffrey Epstein? A. Just the ma1e that was teaching me on the USVI and Sheridan, but she was a1so invoived in sexua1 acts. She wasn't over the age of -- she cou1d have been around 30, but she wou1d have been over 30. Q. Did you keep a 1ist of the masseuses who came to Epstein's properties? A. No. Did some of them come on1y once? A. Uh-huh. Are there some that came when you weren't there? A. I wasn't there, how am I to know. Q. You don't know if any came as a masseuse whi1e you were not at Jeffrey Epstein's property? MS. MCCAWLEY: Objection, asked and answered. A. I wasn't there so I couidn't have. Q. What's the sixth incident that you say happened where you were sexua11y trafficked to Professor Dershowitz? A. We've ta1ked about New York, we taiked about Pa1m Beach, New Mexico, U.S. Virgin Isiands, ta1ked CONFIDENTIAL GIUFFRE005202 CONFIDENTIAL h) to 24 25 111 about we took the airp1ane? Q. Yes. A. There was an instance in a car, but it was more -- it wasn't intercourse, it was more -- MS. MCCAWLEY: Use a term you're comfortab1e with. A. More ora1 is the good term to use, ora1 sex. Q. Where were you? Where was his car, what city, what state, what jurisdiction? Where were you? A. This was in Massachusetts. It was a biack 1imousine. Q. Who e1se was in the car other than yourse1f and Professor Dershowitz? A. Jeffrey Epstein and another young gir1. Q. How many peop1e participated in the sexua1 activity in the car? A. Inciuding myse1f? Q. Uh-huh. A. Four. Q. Where was everybody in the car? A. Sitting down. Q. Were peop1e -- was this a town car, was this a 1imousine? A. Like a 1on9 1imousine. CONFIDENTIAL GIUFFRE005203 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page548 of 648 112 Q. Where was the car going? A. To Mr. Dershowitz' house. Q. Where was it coming from? A. An airport. Q. When was this? A. I don't know. Q. What's your best recoIIection? A. It wasn't snowing. It wasn't hot. So I wou1d 1ike to say -- I'm trying to think of the trees around, but I don't know, maybe spring. Q. Why were you going to Professor Dershowitz' house? A. Jeffrey and him were doing some business. They were doing something at his house. Nothing sexua1 happened at his house. Did you go in Professor Dershowitz' house? Yes, I did. How Iong were you there? Not even twenty minutes, ha1f an hour. What did you do whi1e you were in the house? A. I sat in, I don't know, a foyer with another gir1 and Jeffrey and Dershowitz went to a different part of the house. There was a desk there and we just sat, not sat, stood in the foyer. CONFIDENTIAL GIUFFRE005204 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page549 of 648 113 Q. Who was this other gir1? A. I don't know who she is. Q. Had you ever met her before? A. No. Q. When you were coming from the airport had you fiown in? A. Yes, me and Jeffrey and the gir1 had fiown in, Dershowitz had not. Q. How did he get into the 1imousine? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. BY MS. BORJA: Q. Where did he get into the 1imousine? A. At the airportf1ight with Mr. Epstein? A. Not on this occasion. Q. Did you te11 anybody about this incident in the car? A. Like anybody that I know persona11y? Q. Anybody in the worid? MS. MCCAWLEY: Objection to the extent you re1ayed something to your 1awyer. You can say that you toid your 1awyers but you can't discuss what you said. SPECIAL MASTER: Other than -- CONFIDENTIAL GIUFFRE005205 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page550 toid my 1awyers. Did you te11 anybody about it cioser in time to the event? A. no. Q. where did you A. A. 0 you go? A. Like my boyfriend or something 1ike that, After you 1eft Professor Dershowitz's house go? Back to the airport. Where did you f1y in from? I be1ieve it was New York. When you went back to the airport where did I be1ieve, see, that's the hard thing. I want to say either New York or Pa1m Beach. I'm no 100 percent sure. Q. So I understand the time frameprivate jet or commerciai? A. Q. A. 0. Private. You f1ew out again on private? Yes. So the time frame is that you and Jeffrey were on the p1ane? MS. MCCAWLEY: Objection. Yes. MS. MCCAWLEY: Objection, mischaracterizes CONFIDENTIAL GIUFFRE005206 CONFIDENTIAL h) 01 115 the testimony. Go ahead. A. Yes, me and Jeffrey were on the p1ane together. Q. And the gir1 was on the p1ane? A. Yes. Q. Anybody e1se? A. The piiots. Q. So the three of you took the f1ight, correct? A. Yes. Q. And you f1ew into an airport in Massachusetts? A. Yes. Q. Then you took a 1imousine to the Professor's house and you were there for about ten minutes, is that right? MS. MCCAWLEY: Objection. Go ahead. A. About 20, 25 minutes. I didn't iook at my watch. Q. A very brief period of time? A. Very brief. Q. And then you went back to the airport and you f1ew out? A. Yes. Q. And you f1ew back either to New York or to CONFIDENTIAL GIUFFRE005207 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page552 of 648 194 A. Besides what's in these? Q. Did you ever Iook to see if you had any persona1 notes in your writing that pertain to Professor Dershowitz? A. Like from my 01d journa1, the one that I burned? Q. From anywhere. Did you ever make an effort to 100k? A. Dershowitz cou1d have been in my journa1, he cou1d have been. We're ta1king about an 85 page, if not more, you know, things that I had written to get my story out of my head and into pages; and yes, Dershowitz cou1d have been in there, but that's up in the c10uds now, bonfire. Q. That's what you ca11 your journa1s, what you burned, right? A. Yes. Q. And you wrote that journa] in order to c011ect your thoughts? A. To get everything out of here and on to paper. Q. Have you made any other notes, though, since then to he1p you when you think of things? A. Yes, sometimes 1ike I said, sometimes when I read my affidavits and stuff 1ike that, you know, and I CONFIDENTIAL GIUFFRE005286 CONFIDENTIAL h) 01 195 think of something e1se 1ike a description of something that I forget about, you know what I mean, then yeah, go back and write it in the journa1, you know, for instance, you know, what another gir1 wou1d have 1ooked 1ike. Even though I can't identify her name or her age or anything 1ike that, but I do remember 1ike f1ashes of b1onde, 1itt1e things 1ike that, but nothing -- I don't have any more journa1s. Q. But those notes, they he1p your memory? A. Sometimes. I'm a very visua1 person. Q. And they he1p you with your affidavits? A. No, they don't he1p me with my affidavits, my affidavits are a1ready done, I just go back and it he1ps my memory. It he1ps me bring stuff out. Q. What do you do with those notes? A. Nothing, 1itera11y nothing. They're in a notebook that if I need to write it down. I have a dream notebook as we11 where just write down my dreams and stuff. I do nothing, no one is seeing it. Q. You read it? You keep it? A. Yeah, I keep it. Q. Okay. Have you gone back and read that recent1y? A. No. Q. Okay. You continue to make entries into CONFIDENTIAL GIUFFRE005287 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page554 much about Dershowitz. It's most1y 1ike fee1ings, dreams, you know, past things that I've gone through. Like I said, not so much pertaining to Dershowitz himse1f. Q. And that's separate from your dream book? A. No, it's a11 in one. Q. Is it a spira1 bound notebook? A. Yes, it's just a cheap, 1ike, actua11y it's in my kid's c10set. Q. At this point in time are you angry with Mr. Epstein? A. Furious. Q. Are you angry with Professor Dershowitz? A. Absquter. Q. Are you angry with famous poIiticians? A. I'm angry with anybody who has it in their mind that they can hurt and abuse a minor chi1d and continue to 1ie about getting away with it and that what they've done is okay and they can continue to harass victims, yes, I'm furious. Q. Are you angry with Professor Dershowitz for his roIe in representing Jeffrey Epstein in the crimina1 action? A. Do I think he p1ayed a big part getting him CONFIDENTIAL GIUFFRE005288 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page555 STATE OF FLORIDA, COUNTY OF DADE, I, Deborah A. Harris, the undersigned authority and Notary Pub1ic certify that VIRGINIA ROBERTS GIUFFRE persona11y appeared before me and was du1y sworn on the 16th day of January, 2016. Sworn to before me this 20th day of January, 2016. Deborah A. Harris, Court Reporter Notary Pub1ic - State of F10rida My Commission No. FF 246867 My Commission Expires: October 31, 2019 Job No. J0277789 GIUFFRE005305 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page556 of 648 214 CERTIFICATE I, Deborah A. Harris, F10rida Professiona1 Court Reporter and Notary Pub1ic in and for the State of F10rida at Large, do hereby certify that I was authorized to and did report said deposition in stenotype; and that the foregoing pages 1 through 216 are a true and correct transcription of my shorthand notes of said deposition. I further certify that said deposition was taken at the time and pIace hereinabove set forth and that the taking of said deposition was commenced and compIeted as hereinabove set out. I further certify that I am not an attorney or counseI of any of the parties, nor am I a re1ative or emponee of any attorney or counseI of party connected with the action, nor am I financia11y interested in the action. The foregoing certification of this transcript does not appIy to any reproduction of the same by any means un1ess under the direct controI and/or direction of the certifying reporter. DATED this 20th day of January, 2016. Deborah A. Harris, Court Reporter Job No. J0277789 GIUFFRE005306 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page557 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, PageSS8 of 648 BOIES, 40 LAS OLFS APD SLHTE DEPOSITION- SPECIAL REQUIRED U) 37w? Sigrid S. McCawley, Esq. E-Inail: February 10. 2016 VIA E-MAIL FEDERAL EXPRESS Esquire Solutions PRODUCTION DEPARTMENT 101 Marietta Street Atlanta, Georgia 30303 Re: Con?dential/Sealed Deposition Transcript, Job No. .102777789 (Errata changes to be treated in same manner). To Whom It May Concern: Attached please find the errata changes for the Videotaped Deposition ol'Virginia Roberts Giuffre taken January 16, 2016. This transcript has been designated as Con?dential and has been sealed by the Court. Please ensure that all materials including transcript, errata changes and video tape are treated accordingly. It you have any questions regarding the errata changes or treatment ot?con?dential/sealed materials, please do not hesitate to contact me at (954) 356-001 1. Sincerely, Sigrid S. McCawley Enclosures COM GIUFFRE005310 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230Con?dential/Sealed Transcript Pursuant to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Job No. 10277789 I E: DEPOSITION LRRAIA SHEET ASSignment no: 4 ?radloy 1. Idward? and Paul 0. Lasaell AYan M. Derghow?tz DECLARATTON UNDFR PFNAITY 0F I dcc1are under penaWty of perjury that I have read the entire [ranntript of my videomaped deposition Taken in the raprinnad mathr or xhe same has been read to me. and the same is true and arcuratc, save und extent fur ghangca andfor LorrC<Li0n3. if any. as indicated by me on the DFPOSTTIGN FRRAIA SHEEI hereof, with the und?r?tandinq that I oifcr Ihcio (hangcs an if 5ti11 under oath. II I . F: igned on the - day of 5113-?) 1' .11 20 IL 3 I VIRGINIA LIUFFRE GIUFFRE005311 CONHDENHAL Case 18-2868, Document 278, 08/09/2019, 2628230, PageS60 of 648 Confidential/ Sealed Transcript Pursuant to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Job No. I0277789 ICRRATA SI-IF. ET Page No. 6 Line No, I7 Change to: ?Yes. Isigned the subpoena duces teenm." Reason Iorehnnge: Did not initiaII} reeognire the document Page No. 6 Line No. 30 Chnnee to: "No. My lawyers worked with me to eoIleet documents and my understanding is that we turned those documents over to Dershowitz?s counsel prior to the deposition.? Reason for change: C?lzn?ilicznitm ot?unswer Page No. 9 Line No. 9 Chunee to: ?Yes." Did not initial!) the document 0 Reason for Chang Page No. II .ine No. I Clmnee?: ?Yes." Reason for change: Misunderstood the question Page II Line Nos. 4-5 Chnnee to: ?I?m confused. I don't know what I?m?eiun n'esident mu?re tnlkin I about.? Reason For Change: the Page No. II Line No. 2'3. Chanee to: understand well-known prime ministers and other world leaders; as fa as foreign presidents, I believe so.? Reason for Change: the question Page No. IZ Line No. 2 Chunee to: ?Yes. assuming South America is considered overseas." Reason for change: Misunderstood the question Page No. If! Line No. 8 Chnnee to: "As far as I know right now, yes, I was." GIUFFRE005312 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, PageS61 of 648 Confidential! Sealed Transcript Pursuant to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Job No. I0277789 Reason for change: Misunderstood the question Page No. 38 Line No. Chanee to: ?I?ll continue with the list here. Nadia N?lareinkox'a I was not sent to her, but she was part ofit with Jeff Epstein. Others on the list include h-?Iinsky and Tom t?ritzker.? Reason for ehange: Claritieation oiianswez' Chanee to: ?Off the top of my head, once. but it could have been more." Reason For change: Clarification ot'ansu-er Page No. 38 Line No. 21 Change to: believe Tom was at Mexico. I may have also been with him in other places." Reason for Change: Clari?cation ol?ansu er Page No. -'ll Line No. 8 Chanue to: ?On an airplane a ml in a limo." Reason for change; Clarification oi?answet' Page No. 4i Line No. It.) Choline to: ?One, each time." Reason lbl? change: Clari?cation ol'ansn er Page No. 41 line No. 12 Chanue to: ?On airplane, blond, young." Reason for Change: Clal'itieation ot?answer Page No. 98 Line No. to Chnnue to: ?As you can see in that answer I?m not even so re. it wasn?t six months, but between six months anti :1 year which is why i?m saying nine months. It was an assumption. It could have been six weeks.? Reason l?or change: Clari?cation ot?answel? GIUFFRE005313 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page562 of 648 Confidential/ Sealed Transcript Pursuant to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Job No. 10277789 Page No. 190 Line No. 22 Chanee to: "No, other than maybe you showing it to me today. It?s in my pile. it?s not in my pile, is [don?t know. I haven?t seen it. I was served with the subpoena, and I signed for it, and I reviewed it at that time.? Reason for change: Clari?cation ol?ansuet Page 19! Line 5 Chanee to: ?Why would - no. i did eolleet documents and gave them to my lawyers in response to this subpoena. And my undemtanding is those documents were rod need . Reason for change: Misunderstood the question Page l9! line 20 Change to: ?Yes, but I did not have any pictures ofmyselt'with Professor Reason [or change: Misundta?altmd the question GIUFFRE005314 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page563 of 648 EXHIBIT KK it Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page564 of 648 The Billionaire?s Playboy Club By Virginia Roberts To my true love Robbie who believes in me every step children, y0u are all my very inspirations! Chapter]. Every single person in this shared world together has a unique story of his or her own to tell, this one is mine. It was coming up to my third night camping out at Miami Beach in the summer of 1997. was thirteen years old and hiding from a world full of hurt. Sitting on the shoreline for hours watching the sunset fall deeper into the horizon, my eyes were glazed over with tears, not from being wind-whipped by the rough sea breeze, but from reflecting on the abuse I encountered as a young girl and how everyone in my life who was supposed to be there for me had now turned their backs on me in abandonment. My fears crept up and the excitement of escaping all of them faded now realizing how alone I really was now, and for the hunger that was paining my belly. At this point, with nowhere to go and only time to waste, I wiped the tears from my eyes and set out to find an empathetic person that I could manage to get dinner money from. If not, it wouldn?t have been the first time I had gone hungry for the night. I walked to the nearest bus stop and asked a handful of people for any spare change, none of whom that could help me. Sitting down on a nearby curb disappointed in grief of my current state, I put my head into my knees and began to sob. Out of nowhere, it seemed, a black stretch limousine turned the corner and stopped in front ofthe curb where I had been hopelessly lost. The back door opened to reveal a heavy weight and balding, old man with a big cheesy smile. Neatly dressed in black trousers and a collared shirt, he was sitting next to a striking young, blonde girl, drop dead beautiful and dressed in a foxy red mini dress she looked like a model just stepping off a runway. Their smiles greeted me warmly and he kindly asked, ?What is such a sweet little girl like you doing sitting alone on the street looking so upset?? Shocked from this strangers concern was hesitant in telling him the truth. Reluctantly I decided to tell him that was a runaway, not from around here and really hungry. Hoping at most, I would get some money for food from him. He instantly displayed a chilling excitement and offered me to come into his car so we could talk some more. That GIUFFRE004134 Copyright Protected Material CONFIDENTIAL should?ve been my first queue to get out of there quick but with no where to go, and so naive didn?t realize how much worse it c0uld get. Setting foot into that limo, I made my first entrance into a world that would entrap me for many years to come. He introduced himself immediately as Ron Eppinger, a businessman and owner ofa successful modeling agency, called ?Perfect 10?. Flaunting his oozing wealth by introducing one of his many girlfriends, the beauty next to him was Yana, a supposed model from the Czech Republic who looked like she could be in her early twenties with the heavy load of makeup she was wearing, but really was only in her late teens. She kissed me on both cheeks and politely said ?Hello? in a thick Czech accent, making me feel a little more at ease. Convinced it couldn?t be that bad there was another girl in the car, right? I couldn?t be more wrong. What he didn?t tell me to begin with was that his modeling agency was only posing for an undercover trade. By the time found out thought it was too late to run. His business was really an illegal immigrant trafficking ring of young women mostly consisting of underage girls that he was using as escorts to make him uber rich. Only available to a selective clientele costing them anywhere from $1000.00 and Over per hour of erotic entertainment, the girls were trained to ful?ll every sexual desire asked of them, no matter how bizarre the requests might be. The high paid escorts, for Ron?s super rich clientele, such as Yana and many other charismatic beauties would only benefit a fraction oftheir earnings for themselves, Ron reaping in the majority of the ?nancial rewards and being they were all illegal immigrants they were further trapped by his enslavement. Iproceeded to introduce myself, besides what he had found out about me on the curbside. Telling him my name and a little about how ended up on the streets explaining that I could take care of myself and didn?t need my family or anyone to look after me anymore. Looking back later in lifeI can now admit I was in a terrible state, but being such a headstrong teenager, I refused to give in. He asked my age and told him I was sixteen at first. He coyly replied, ?Are you sure? I think you con be telling me a fib? How old are really? I wont be mad? Being a terrible liar, I knew had been caught out and couldn?t deny it any further. I told him the truth and he chuckled then paused and answered in a very serious tone As long as you never lie to me again 1 will take you in? Right away I pondered to myself what did he mean. . .take me in? He gave the driver the location of our destination and rolled the middle window back up to then tell me a story of how his daughter had passed away seven years ago from a horri?c car accident in which four other teens were killed and he has never gotten over it. 1 reacted with sheer ?3?me AGREE REPORTING 515; i a, L35 Copyright l?roteclcd Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page565 of 648 of life wasjust mind blowing to even comprehend at first. With such a new outlook of the world to try and grasp at my young age I was listening to every word spoken to me with such attentiveness, I was going to try and model what I was observing from the girls. ljusti?ed their way of thinking in my head for now, thinking if all these girls seem happy enough, why couldn?t I try to be, it was this or the streets for me. Ron came back for me not long after our conversation got out of hand and took me to a bathroom down the hall. He opened the tap and ?lled a small plastic cup with water and handed me two small blue oval pills. Telling me to take them both as they would help me to relax a little bit more. I swallowed the pills just following his orders. I put the cup on the counter top and turned back around to face him. Backing me up against the wall and now cornered by this large man I felt his slithering hands began to creep under my shirt, writhing my skin. I closed my eyes and tumed my head away from him, hoping he would take my actions as a sign of being extremely uncomfortable but that wouldn?t bother him at all. He was half enjoying my reaction from the smug look on his face, and persisted through it. Continuing to undress my clothes he said he wanted to look me over and clean me up. It was so humiliating having to expose myself to this ageing man and now I knew he was going to end up with his hands and whatever else all over n1e.'All too soon I hated to be right, as I stood naked before his widened eyes, he told me ?you?re a hairy bugger I?ll have to shave you right up young lady", and I didn?t know he wasn?t just talking about my legs. Standing with my legs wide apart while this man coaxed me through the entire ordeal of shaving, his hands made me feel so dirty. ?Have I lost my mind?? I thought to myself but I had to play nice until I had an opportunity to get away, this was not as fun as the girls made it out to be after all, this was utterly disgusting. I had no idea what was going to happen next with this guy, and due to whatever pharmaceuticals he gave me, I still don?t know to this day. Waking up the next morning my head was pounding in an agonizing thumping pain and I was so thirsty. The satin sheets thankfully covered my body, which was still nude from the night before, andI could hear hushed voices standing over the bed where I was pretending to still be asleep. Listening in on their conversation I kept my eyes shut. I knew Ron?s voice from two ofthe men but not recognizing the other guys Ijust stayed quiet hoping they?d soon leave. Ron was telling the other man what atrocities he got up to the night before with me and I heard him say, ?Doesn?t she even look like an angel the way she sleeps? She?s my own little angel!? He exclaimed proudly. I opened my eyes and rolled over to face them both having to wrap the sheets over my body, really not knowing what to say except ?Good-morning? in a blushful tone. Ron GIUFFRE004 138 introduced me to his business partner and told to go get dressed. He had my whole day planned out for me already. Booked into get my hair colored, a much lighter tint of blonde, and afterwards a day of shopping with the girls Iwas becoming exactly what he wanted me too, a carbon copy ofthe teenage only I wasn?t plastic and came with many benefits. Days turned into weeks, being a servant to the sexual desires of this distorted pervert. I dreamt of escaping but where would I go and how would I get away from Ron with him controlling my every second of my day. Separating myself from the other girls being so uncomfortable with enduring the everyday occurrences I was longing for the solitude ofthe beach again. They were training me up to be an escort prodigy or something like it. Outrageous orgies were conducted as my lessons with the girls teaching me all oftheir tricks in the game, it was all for the sake of men?s perverted fantasies, they didn?t get anything from being sexually exploited and molesting each other, except getting paid for it. Everything from oral sex too penetration with toys, I was expected to not only to join in but even perform ludicrous acts of hedonism. I was Thirteen years old and had never heard the terminology of these sexual acts before, and definitely shouldn?t have been learning them first hand. Thrown into a world of chaos, I didn?t know what to do except be as compliant as possible, even when asked to do the most degrading tasks. The excitement ofthe lifestyle he offered quickly diminished once I had to pay so dearly for it. The girls that subdued to this lifestyle and enjoyed it definitely put on a good act, but no little girl with hopes and dreams of their untainted future, turns to her mother and say?s ?one day I dream of being a prostitute, passed around from man to man, only to grow older regretting so much ofmy life? It was all a part of an illusion that Ron painted for us that made it seem so alluring in the first place. Spending my days with Ron, he took advantage at every chance given. Even in his convertible with the top down I would be forced to go topless while he drove around, when I asked him why one day, it was supposedly so I could maintain an even suntan, but I knew it was his way of showing off his treasures. It was a far cry from the simple country life I had been raised in. Wearing designer miniskirts and tops that always revealed too much, of course due to Ron and the girls determining everything I wore, ate, or spoke. We would spend our days at hair laser clinics, shopping, tanning beds, and eating as little as possible. Through the nights we were expected to become party animals and greet Ron?s clientele with the upmost ?irtatious attention and doting as possible. Then whether we were out for dinner, at a party, or at a club, the men would choose his girl and take her home. Every girl had a different price and so did the charges depending on the various clienteles but Ron always kept me for himself. Copyright Protected Material CONFIDENTLAL 13?) ll Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page566 of 648 sympathy and gave him my pity, believing this man had a heart. His next proposal was eerie, he said,? If you wanted, I can be your new Daddy. Someone to take care of you and you?ll be my new baby forever? he stroked my hair such as a caring parent would comfort a scared child. A part of me wanted to accept his words and believe he really could feel that way, and then 1 also considered how hard it was living on the streets. In the end I convinced myself this would be the lesser of two evils. The car stopped at a plaza on the water, surrounded by little boutique shops, restaurants, and little stalls with items for sale like sunglasses and costume jewelry. I didn?t know what act, it all happened so fast Ijust went along with everything he said, for now. We went to a take out restaurant and ate on the waterside, and afterwards he took me to G.A.P Kids co. to dress me in his idea of proper attire, tiny cutoff shorts revealing the cusp of my buttocks and some shirts that barely even the sales assistant was shocked at what she thought was my Grandfathers choice in clothing. I couldn?t even believe it myself only an hour ago 1 was begging for money living on the streets and now 1 was dining alfresco and shopping at name brand outlets. We then hit a couple of more specialty stores afterwards. He said he had to buy me a few more necessities to start with. Lacy G-strings and what looked to me like lingerie pieces I had only seen grown women wearing in magazine ad?s or movies was now a part of my wardrobe, in my mind it was a big step up from being a little girl any longer. The driver took us back to Ron?s grand apartment overlooking the isle of Key Biscayne and a large bridge leading into a Miami Harbor. Entering his residence, was blown away by the spectacular view, rich d?cor, and white marble floors that were so glossy it looked as if i was stepping on glass. He took my shopping bags to a large room at the back of the apartment and put them into a small closet. The room was considerably large with glass exterior walls that maximized the potential of the panorama landscape soaking in the seascape of Miami. In the room was a gigantic round bed raised off the floor by three steps and mirrors on the ceiling. It looked like a honeymoon suite out ofa raunchy hotel. He then exclaimed, ?This is my room here and you will be sharing it with me? When I asked him where I would sleep he then sickly replied ?With me silly, where else of course?? With no room for argument I pretended to be O.K with everything that my common sense was screaming out in my head to run. Next 1 was taken down a long ball at the other end of the apartment to meet five more exotic beauties. Three girls were in their late teens and the other two in were in their early twenties. All of them were from the Czech, here under false passports provided by Ron and his contacts. Yana held my hand while introducing me to the group of girls as ?Baby? a pet name she came up with for me, being I was the youngest one among them or ever to be brought in by Ron for that matter. It became my new identity not even worrying to mention my real name to anyone anymore. My identity was no longer important to myself, I wanted to become someone new and ?Baby? is who 1 was. A shocking ?rst impression, the girls were completely nude revealing their voluptuous young bodies with such a careless ease and others were in just a G-string, similar to the one?s Ron had bought me earlier. They were all stunning girls and full oflife. Charismatic and beautiful, they were the girls who should be on the front of billboards not selling their bodies to old crewed men for sex. Doing each other?s make-up in front of the mirror and chatting away on the bed with no care in the world, aiming at persuading me to see the highlights ofthe life Ron gave them- and they almost did. Ron left the room for a few moments, letting us all get to know each other a little better and that?s when I started to compile an understanding of what really went on here. Just catching a bit of their conversation from before my introduction, I heard them chatting about the night they were preparing for. Speaking excitedly about some men they would be entertaining in a few hours, one girl was talking about going out to sea with one 0 these clients on a yacht for a few days. Since none of the girls seemed shy to talk about their professions or anything for that matter, I decided to ask them a few questions about what they did. They were more than happy to expand on their point of view in the conversation, attempting to paint a pretty picture of what they were paid to do. They all began to jump up and down with excitement like giddy school girls at a slumber party. Another girl with jet-black hair and a thick accent, wearing absolutely nothing at all, grabbed me onto the bed with them and into their ?asco, instantly making me feel accepted into their sorority, like 1 actually belonged somewhere for once. Yana went on to explain a little more in detail, We accompany the wealthy friends of Ron. They want only beautiful girls by their side so we come and act however they want us too but most importantly we make them think we want them back too.? Other girls began to jump in with their vivid points of view while playing with my hair, they were taking tums brushing and styling it as they were filling my head with all of the prospects I could have as an escort too. They made me feel beautiful like them, too beautiful for what a girl beyond my years should feel. I was simply being lured into a dangerous trap,just like they had been at a young age too. It pretty much all came down to two things in their game, the money they would make and the lifestyle they were given. Their enthusiasm only interested me further, making it not only sound like an acceptable way of living but also appearing to keep them all vivaciously satisfied. This way Copyright Protected Material CONFIDENTIAL 137 Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page567 of 648 I would always dread the end of every night, fearing what new desires he had in-store for the evening. Sometimes he would hurt me and tell me to try and enjoy it then do it over and over again until I gave him exactly what he wanted, I always resisted until I could no more, he was too overpowering and relentless at getting the results he wanted. At other times he could be so gentle and caress my skin, worshiping every inch of my body, all relying upon on what mood he was in. Often though he liked to play the teacher role and instruct me on every motion and explain what would happen when I did those certain things to him. No matter what he did to me I was only disgusted with myself more and more. I still shudder at the thought of how he used my body. I turned fourteen in August that same year and was spending my birthday loaded on a concoction of pharmaceuticals and alcohol, being generously supplied by the very man who swore his devotion to caring for my every need. I didn?t even know myself any longer, completely shying away from the girl I had grown up to be until to this point. The apartment was empty except for me, for the time being, and that was God?s own little present for solitude for once I thought. Pouring myself another drink 1 opened the sliding glass doors to the balcony and walked to the edge. Looking down from the many stories where Ron?s apartment was, 1 wished myself a happy birthday out loud and wondered if my family even remembered the day?s occurrence. Dwelling in my sadness for the fourteen years of suffering and loneliness I had already endured, the tears swelled up in my eyes, trickling downwards making my eyeliner inevitably leak down my cheeks. Inside I felt so trapped and began to entertain the thought of jumping over the edge, it all seemed much easier, and the simple blackness that death had to offer rather than the tangled mess I was so tired of ?ghting to get out of seemed a much easier approach. Detached from wanting to feel anything, I became so numb towards my life?s own tragedies. I couldn?t live like this any longer. I lifted my bare legs over the edge ofthe railing and sat looking at the ground beneath me so close to even just slipping off the edge to my very death. I couldn?t think of any reason not to fall. I thought I had made too many bad decisions to keep going on but some force ofa higher nature had other things in store for me. The sliding door slammed open with a burst of speed and Ron scooped me up in his big arms and brought me inside to our bedroom. Laying me down and seeing the look of despair in my eyes from my tear stained face he went into the bathroom cupboard and returned with three pink pills. Forcing me to swallow them using the angered tone of his voice he thought he was turning my sorrows into a distant dream as I passed out in GIUFFRE004140 his tight clutches, crying myself all the way to sleep. He didn?t even ask me what was wrong, probably because he knew already. Soon enough the crumbling ofhis evil empire in the underworld of selling sex for his own advantage began with a single crack in his perfect scheme, and proudly it all started with me. Ron got a scare one-day and rampaged through his apartment telling us girls to only pack our important belongings and some clothes as we all had to leave right away. I didn?t have much belonging to me so I basically sat there watching everyone rush around frantically and was curious what could?ve gotten a man like Ron so scarred. Once we were packed up and in the limo he was trying to calm the frantic girls down after all the panic that spread through the apartment like wild?re, was the only one sitting there half amused at the entire situation. He began by assuring us that everything was going to be fine. Calmly he continued to tell all ofus packed in even for a limo, that we were all taking a long trip to Florida?s because someone has reported an anonymous tip to the missing persons unit at the local police station identifying a very young girl as a possible victim of abuse living at his apartment. Ron knew what a landmine of trouble he had brought upon himself making an exhibition out of me on the streets of Miami, I didn?t pull off the older look like the other girls, I actually looked younger than my age with my blue eyes and freckles always giving the impression of my youthful innocence. Now hejust had to do whatever it took to ensure he stayed as far away from the authorities as possible. Arriving at a ranch in central Florida many hours later and I assumed it belonged to Ron knowing never to ask him things like that. I knew my purpose and it wasn?t prying into his personal life outside of the bedroom. There was a main house, a few cottages, some staff quarters and paddocks where the horses were kept. I was in thought at ?rst. Finally, something I could really enjoy. Riding was my passion, basically growing up on the backs of horses since I was just able to walk. Not surprisingly I began to despise Ron and all of the girls for the gross exploits they made me do with them. Beginning to isolate myself from everyone I?d rather spend my time sitting under a tree watching the horses graze, writing in my journal or painting but mostly avoiding everyone possible unless Ron required me elsewhere. Nighttime was always a reoccurring nightmare for me. Relived over and over again in many various ways. Ron would always start by making me some drinks and offering an assortment of pills before indulging himself by grotesquely putting his genitals in my mouth and tell me how to give him what he would call a ??rst-class blow-job?, and I was being judged every minute of it. Ordering me to slowdown or speedup or maintain a perfect [1 Copyright Protected Material CONFIDENTIAL (JlUl-?i-?RliOll-l 141 Copyri lit Protected. Matcriai Case 18-2868, Document 278, 08/09/2019, 2628230, Page568 of 648 I was constantly being criticized for my efforts in pleasing him. I was eager when he actually gave me a compliment. The rest of the evening was always a surprise left up to a moments notice. Quite regularly he would proceed with having the girls dress me up in some sexy out?t and loads ofmakeup then entertain him with a lesbian reenactment revolving him in the center. Sometimes they would use dildos and other foreign sex toys, Ron liked to see us hurt during sex, sometimes even penetrating me anally but I always resisted and would try to redirect him with another sexual desire of his but I had no excuses when it came to me having to use the sex toys on him, he told me how men have g-spots in their rectum and instructed me on how to precisely penetrate him, These nights went on what seemed like an eternal sentence for the price of not living on the streets, where unfortunately for the one?s still there, I feared and knew from my own personal experience, could be much worse. Needing some contact with someone of my adolescent mentality I called one of my school friends from the past, whom I wont name out of privacy, but I?ll call him We were so close and I knew very well, so well, I had memorized his number a long time before. He was my ?rst puppy love sprung from ofa childhood friendship. Being my very ?rst crush the summer before all of this happened he was the only person I could think of that would care enough to talk to me. In the middle ofthe day, the least busy time to be noticed, I snuck into one of the vacant guest rooms and used the phone to call my good friend. The sound of my voice radiated a chill in him. ?It?s you, oh my God Jenna! Are you okay?? he was so shocked to hear from me and the sheer fact I was still alive. Nearly three months now without a single word to my family or friends, every one doubted my return. My attempt to forge a happy voice when I spoke to him failed and I absolutely crumbled when he was at a loss-for kind words for me. I told him of my current state of affairs. Telling him of Ron and how I was terri?ed of him, trying to escape in the middle of nowhere was useless. It was like being kept in cage that was unable to break free from. Going on to dump my issues on I proceeded with how I longed to call my family and to be with my them for good but was too afraid they didn ?t want me, knowing I?d just be sent away somewhere else again and to me after all this time was like going from one cage to another. He had been called by them numerously and promised me that they were very worried and even hired private investigators to try and ?nd me. Given lwas eleven years old the first time I was sent away, my trust in there sincerity he spoke about was seriously doubted. I kept the conversation shortjust in case my absence was being noticed and I left on the note that I would speak to him again shortly. His attempts to get off GIUFFRE004 I42 the phone were nothing short of desperate plea to keep me on as long as possible. I thought he was just trying to help in someway. Giving him assurance in the fact I had survived this long obviously I can hold offa while longer I gave him my love and told him I?d be in touch. Thinking I had slipped away unnoticed I entered into the room that I shared with Ron, hoping I got away with my brief and very needed phone call. The place looked empty and everyone else seemed to be out and about so I decided to have a bath in the spa and try to relax before the night?s precautions. My body glided into the steamy water as I began to think about and how good it feltjust to hear from a friendly voice. My thoughts drifted into the days I missed when I felt I could be silly and childlike and I nearly forgot for a moment how grown up I was acting these days. My ?rst glimpse at the image surrounding me when I resurfaced above the water was daunting. There was Ron was standing over my tub, looking down at me with an eager display of his arousal. He began to undo his pants and take them down when he told me ?put your lips on my cock?, I was too slow in responding to his request so he grabbed me by the back of the head and forced me into his groin. I had tears streaming down my face as I looked up to him with the saddest blue eyes hoping he would take pity and stop, but he never did. I was really hurt by his aggression and he de?nitely knew it this time, which I believe only made him more heated. I closed my eyes and began to count using the time to keep my thoughts elsewhere believing every number I counted only furthered me to the end of this. Ijust got over a hundred when he ?nally exploded in ful?llment still half submerged in the deep bath I was struggling to gain my bearings in as Ron was picked me up out of the bath and carried me to go to the bedroom, which wasjust outside the French adjoin doors. Still damp from the hot water in the spa I had goose bumps from the chill of the fresh air where he brought me to the bed and proceeded to deeply violate my every being. Eventually his scars that he left were too deep ever to be healed and would even carry on through the years to come. Upon his bursting with pleasure for the second time, he just got up and left, without even saying a word to me. Left alone I was awake for hours after that. There was no escaping the pain that night. I lay naked wrapped in the sheets, sobbing in the dark. My feelings ofbeing hurt and disgusted after his abusive ordeal ?When will it ever stop" I prayed to God and begged for death rather than face another day in my life. I woke up still alone the next day and exasperated from the misery I felt the night before. Ushering through my drawers to ?nd something to throw on I could care less what lay in store for me today, couldn?t be as bad as being raped by a scary man repeatedly. 10 [i Copyright Protected Material CONFIDENTIAL 143 Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page569 of 648 Starting my day with a few ofthe supplied oxytocin?s and a bloody mary, made by the live-in house chef. Having two celery sticks for my breakfast, I wanted to lye out by the pool and forget the world. Ron hated tan-lines so to be caught with a bikini top on was a big no-no in his rule book but after my cries to stop were so blatantly ignored last night, [was out to piss him off so I didn?t remove my shirt. [put on my headphones and before I knew it had fallen into a deep slumber from my self-made therapeutic cocktail, the only way I knew how to cope with the emotional turmoil on the inside. Desperate to hear his voice I called my friend a few more times that week. I needed to feel like someone out there really knew me. Sometimes we couldjust chat like old friends with no care in the world and laugh at a distant memory from too long ago. Then would come the good?bye part of the conversation and we would both get teary-eyed not knowing what could happen next or if this would even be the last time we ever spoke to each other again. My biggest fear came to reality when I was in our bedroom one afternoon, just lounging around out of boredom. Ron came bursting in through the door, red as a tomato. I. couldn?t help but feeling I was in big trouble. His face was distorted and raging towards me. I knew right away he must have found out that I was calling but how, I had no idea. 1 had always tried to be as invisible as possible, soon enough it was all explained. ?Are you trying to get me caught? You are nothing but a stupid girl you know that! What am I supposed to do with you now?? He was tearing up the room while his rants gave me something else to think about. What would he do with any longer? I wasn?t even thinking about him being caught for soliciting illegal immigrants for the purpose of prostitution. I was more worried that he would be upset at the fact I was talking to another guy, maybe even jealous that he was at least my age. [replied with simple sentences that I could manage to get out between all the shouting. I kept saying, ?I?m sorry? and putting my head down in shame. He picked me up by my throat pinning me against the wall, ?You are going away, far -far away from me and you better be nicer to the next man I send you to, I?ve heard he?s not a nice as most would like. Are you fucking hearing me Bitch?? I slid down the wall, choking on the ?rst air entering my lungs, breathless and terri?ed, I never thought Ron was a nice guy but I had never seen him lose it this bad. Now I was being sent me away to another stranger, another man, it only terri?ed me more. The girls came in to say their good-byes all of them were crying and asking me in their best English languages, why 1 had to call someone and lose everything? 1 was able to ?nd. out through the broken sobs off of 11 them that the confession came from the house-keeper who said she saw me use the room regularly but was never messed up, so Ron looked at the recent telephone bills and found the same number dialed from that room consecutively, he knew it was me right away. At least he didn?t know it was another guy, [thought to myself, or I probably wouldn?t have made it out of there alive. Ron came back to usher the girls out of my room and told me I had ?ve minutes to pack my clothes, which he made clear were to be my only belongings to take with me. He washed his hands clean of me that night, or so he thought. The driver came knocking at my door, just as Ron said, no longer than the ?ve minutes that he had offered me and he took my single bag to the car. I didn?t want all thejewelry, music or books that he so caringly bought me as tokens ofhis tWisted affection, Only taking my clothes and a wad of hundred dollar bills I had been saving, slit a hole in my scrunchie inserting my cash for a rainy day that was more than sure was just around the corner. . We drove for hours, until I started seeing familiar surroundings. I couldn?t believe my own eyes. I was back in Miami, but not on the beaches, somewhere in the CBD this time. The Driver delivered me to the front door with my one bag and waited at the door with me. Now I knew how it felt to be a puppy picked from her litter as you can only hope your next owner would treat you with some sort of kindness. Another balding man answered the door but he wasn?t so grotesquely fat like Ron, but still a new owner at that. He looked me up and down and seemed amused as he snickered to himself. With one last look to the driver over my shoulder it was almost an appeal to him for some way to help me. I knew he couldn?t anyways, I wasjust hoping. He told me his name was Charlie but didn?t even bother in asking me for mine. I was sure Ron already ?lled in all of my details when he arranged this. Charlie picked up my bag and led me into his bachelor pad townhouse. I was never given a welcoming tour of my new residence or made to feel comfortable. He walked me up the stairs and opened one of the doors in the small hallway. Telling me this would be my room, he showed me into it and told me to wait, he would be back shortly. I sat on my bed afraid to touch anything and after the warning Ron gave me I knew I had to watch my step around here. I put my head down onto the pillows my where world was falling apart and let my emotions downpour. Exhausted from the days emotional turmoil I ended up falling asleep. I don?t even know if he ever came in at all that night. The next morning I looked out of the window to see my new surroundings. It was a beautiful sunny day outside, unlike the dreary cell I was locked away inside of. Feeling the Sun warm up my face through the glass, it radiated a familiar sense of comfort from the days of the good 12 Copyright Protected Material CONFIDENTIAL GlUlil?liL?UU-l l-lS Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page570 of 648 parts of my childhood. I reminisced how it had used to be before all my life turned upside down. Before all ofthe ?ghts with my family, before I had to look after myself, and before I was a slave to men. Those days were too long gone now. With too many hard times passing me by it seemed surreal to think that life had ever even existed in the first place. With that thought I shook myself out of reminiscing that way. Whatever was going to happen was out of my control now, Ijust had to give myselfsome hope that I would have the strength to get myself out these circumstances before anything really bad happened. Chapter 2 The house was quiet so Ijust assumed Charlie was still asleep. I decided to get cleaned up and have a shower. Not even a knock on the door when Charlie walked in with ease. ?Typical? I thought. It was an easy way for Charlie to break the ice. ?You really are as beautiful as Ron said? as he opened the curtain. Watching me rinse myself in the shower and me knowing I had no way out of this except to go along with whatever he wanted, Ijust looked down at the mention of Ron?s name, wondering what else he had told Charlie about me. Realizing later that he wouldn?t have said anything anyways, in fear I would?ve been a damaged product that wouldn?t make him the money that young girls go for. He just sat on the side of the vanity top and continued to take observations ofme standing submerged under the falling water. I avoided looking at him and let him do all the talking, after all I knew what Ihad to say was of no importance, that is if he was anything like Ron. Between the water beating down over my head I could hear him ramble on about some club and restaurant he owned in FT. Lauderdale. He said he was going to take me shopping for some club out?ts and we would party together tonight, as if I was supposed to be excited over this so-called treat of his. I looked up and gave him a quick smile adding a compliant nod and turned my attention to turning off the faucets and quickly grabbing my towel. I was falling so far from who I used to be, shying away from my outgoing personality to a quiet girl that didn?t even recognize herself in the mirror anymore. I dried myself off and looked at the man standing between the doorway and me. He was still watching me with a sleazy look on his face but now preceded to move in my direction, arms wide open. He embraced me, running his hands up around my youthful curves, licking my neck and earlobes. Then his large, rough hands cupped my small breasts and continued downwards to feel in between my legs. I 13 146 knew what I had to do to get this over and clone with as quick as possible, but I was dreading this moment from the second he greeted me at the door last night. I fell to my knees and gave into his demented perversions. Thankfully it didn?t last long before he climaxed and I was allowed to get myself dressed and ready to go out. I was nothing but money well Spent in his mind. This was another extremely wealthy man with a completely new set of Wants and needs asking a fourteen year old girl to affectionately dote on sexual desires to a man in his mid forties. I really hated myself, these men, and just about everything my life had boiled up to by this point, but I knew from a young age that to survive in this harsh world I would have to do many things Iwould not willingly choose to. At the shops he decided he would choose the clothes he paid for, which I might as well have been declared a teenage prostitute. Just like Ron he also liked it that way. The more degrading he was to me only proved his ownership ofmy body. He bought me tiny cocktail dresses, and skimpy out?ts, which I thought closely, resembled the lingerie he?d also bought for me to wear for him. I noticed that day that he enjoyed parading me around the shopping mall and out for lunch at hooters, even joking with the waitress that he?d like to buy her uniform because he thought it?d look sexy on his new girlfriend. We arrived at his two in one, Restaurant and Club, at around nine o?clock in the evening. It was a revolving tower called ?Hot Chocolates" in downtown Ft. Lauderdale. The food was delicious and for the first time since being with Ron, I ordered a hefty meal with steak and mashed potatoes with a scrumptious gravy smothered on top. Charlie ordered strong cocktails for us both and before I knew it my head was spinning and we were on the dance floor together. The music blared in my head and the of my body took over, completely forgetting about even dancing with Charlie and letting the music take ahold and work it?s magic. It didn?t do me any justice though as Charlie watched me imagining what pleasures lay in store for him later on. Taking me home before the club had even closed, he just couldn?t wait to indulge on exactly what he was fantasizing from beforehand. Once back at his townhouse he led me up the stairs into his bedroom and pushed me down in the middle ofhis bed. The motions from the wavy mattress made me dizzy and feel even drunker when he lay on top of me. Corning at me like a hungered beast wanting to ravage his next meal, it was intimidating as he entered into me with a forceful thrust, he moaned out in delectable heaves. I looked away while he selfindulged his own gratifying needs using my body as his instrument in pleasure. I only grew stronger in my head letting the hatred for men desires intensify. 14 Copyright Protected Material CONFIDENTIAL I47 1 Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page571 of 648 The next two weeks I was expected to be at Charlie?s beckon call, never aloud to leave his side, even making me sleep in his bed from the second night onwards. I never even got the chance to call T..T again. It was too much of a risk anyways. Thus pushing him further out of my memory, too afraid, of the emotional repercussions. Our typical routine was to wake up get showered and dressed and I would put on my make-up while Charlie made his business calls for the day. We would leave the house mid-aftemoon and run his errands do some shopping, sometimes meeting his friends or business partners for lunch, none of the men he introduced me to seemed offended at his choice of adolescent candy. They?d just continue to chat away as if it was normal to be in public with his arms draped over a girl young enough to be his granddaughter, not too shy by giving me a ?irty tap on my bottom or even try to kiss me. My last night was no different from every other night. We went shopping that day and out for lunch alone. Later we headed to a club his friend just launched and it was his grand opening that night. The club was called ?Iguana Joe?s?. We met up with his friend and said our hellos. They both seemed so excited about the club and Charlie was full of compliments all around. The club did have a line out the door which looked a mile long coming in, luckily we didn?t have to use the front door. Charlie returned from the bar with two giant long?island iced teas, which were his favorite drink to start with and then we just sat for a while watching people dancing. Occasionally conversing about passing thoughts. We danced for a while having a few more drinks and after about two hours, Charlie said he was ready to go home. What a daunting time to look forward to, he always liked to have a brief sexual encounter before drifting off to sleep with my naked body intertwined between his arms and legs. It was bad enough to have to entertain him at every given second ofthe day but his grip on me was so stifling I felt so chocked I could hardly breathe much less sleep. Eventually my over-worked mind would drift in- and?out ofa restless sleep, but constantly on edge. I thought many of nights of escaping, but where would I go? Would one of Ron?s ever-so- connected informants finds me and turns me into him to be disposed of for good? Ijust prayed that I wouldn?t be another missing person to add to the list of girls found in the local ditches. I knew that?s where 1 was headed ifI screwed this up for Ron again. As if my guardian angel was there the whole time listening to my secret prayers, my rescue came the next morning with an abrupt bursting through the bedroom door at about six am. Charlie and I were still lying in bed together and his grip on me was still tight. The men dressed in all black military gear had large guns and helmets on. It was so frightening 15 GIUFFRE004 148 at first. I couldn?t even comprehend what was happening so rapidly.'l thought Charlie could?ve been in some kind of trouble with a business friend he had done wrong too, but then one ofthe men in black shouted this is a raid get down with your hands on you head?, in too much shock to move three ofthe men grabbed Charlie and threw him to the floor and cuffed him. I sat up in bed with my sheets covering my naked body and watched as they dragged Charlie from the room. Still completely nude he wasn?t even aloud to get dressed. Another agent had to come back in to the room to ?nd him a pair of shorts. I could hear him screaming at the top of his lungs all ofthe way outside He was screaming and the last thing I heard him yell was ?If you say anything you know who will ?nd you!? I could hear more threats being yelled at me but I couldn?t make cut what it was that he was saying. I was in total confusion and couldn?t believe what was happening. Th ere were so many unifomied agents I felt so small compared to all of them but they were all very kind and helped me out of bed allowing me to remain covered up with the bed sheets so I could get dressed. The ?rst decency 1 had been showed in a long time. It was an odd feeling to acknowledge. I knew the life I had come accustomed to for the last six months was now over, and in so many ways Iwas relieved but was also very nervous about what lay ahead of me. I excused myself to the bathroom to put some clothes on. Not having anything half decent, like a normal pair ofjeans and a t-shirt. The best I could come up with was a metallic blue miniskirt and a tiny matching top that fell just below my breasts, hardly clothing at all it was more like scraps of cloth. Putting my hair up in a tight bun with the scrunchie that held my ?ve hundred dollar bills was led out of Charlie?s townhouse for the very last time. Starting my life I wanted to leave behind my every memory belonging to these horrid times. Only taking small sack containing my underwear, makeup bag, andjoumal with me. The agents led me down the staircase and my last vision?s of Charlie was bent over the hood ofa police vehicle still screaming and handcuffed. I slipped into the backseat ofthe car and was driven to Broward County Police Station where the Federal Agents interviewed me about my entire whereabouts for the last six months. I was so scared of what Ron would do if I told the agents what really happened but at the same token I knew he?d most likely kill me anyways for being such a liability. Over the next few hours I sat down and told the agents how Ron?s business worked and what 1 part I had to play to him. I was able to ask how they found out I was at Charlie?s house and they informed me that I was being followed all the way from Ocala, Florida where Ron had me stowed away for the last four months. T.J, my friend, called my parents 16 El Copyright Protected Material CONFIDENTIAL GlUl?l?leOO?l 14?) ill Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page572 of 648 after our ?rst phone conversation and ever since then, the FBI were tapping the phone lines and recording every conversation. Completely unaware of caring act of deceit, I was in such shock that they had been tracking us for so long. I knew now, with or without my help, the FBI had enough on Ron to put him away for a very long time, ifthey could catch him, that is. Having so many crooked people working for you can be an advantage when you?re in trouble. Like having a pair of eyes in every city. Ron was somehow able to ?nd out about Charlie?s arrest and immediately deserted the country to avoid legal punishment, not to mention the discretization of his esteemed clientele that the feds were now on to. Ron had so many countless charges put up against him, eventually when the FBI were able to track him down they were able to have him arrested in Yugoslavia and extradited back to Miami, he was ?nally held accountable for being a pedophile, soliciting women for prostitution, and running many illegitimate and illegal businesses. By the time the caught him he was in his mid-seventies when he died of old age Serving his second year prison for a sentence. Coincidentally I was told of his punishment and death many years later by one of the same F.B.I agents that had rescued me from Charlie?s arms. I was taken out of the interrogation room after the interview was over with and told to sit at one of the of?cer?s desk while I was waiting for someone to pick me up. Uncertain of who that someone would be I assumed it would be someone from the juvenile delinquents division to take me back to some state operated lockdown facility. Not the nicest of places to call home, but I had no choice in this matter. Sitting back in the revolving chair I was twirling out of boredom and listening to the roaming conversations within the of?ce. I pondered in fearful anticipation ofthe dreadful places that lay in store for me. Having to of spent a lot of my adolescence in these kind of places for the sheer factor that my mother said was out of control and unable to handle? by eleven years old. There was plenty ofjust reason for me to be so scared of those places. What I knew lay in store for me were constant fights between the rough girls being settled with violent raids then out came the pepper spray and then the strip-searches and worst of all, no sunlight. It didn?t matter if you were a quiet, shy girl that didn?t belong there, when there was a ?ght, which was could be like a few times a week, every person in the room was considered a threat and were treated like a violent criminal. I hated those places and the memories they gave me. That?s why 1 always ended up back on the streets. No child or even a juvenile should have to be subjected to such unreasonable force and neglect. Some of the girls were so used to being subdued to this kind oftreatment their 17 GIUFFILE004150 whole life they ended up repeating the same attributes as the people who initially hurt them in the first place. One very sad girl I?ll never forget her, bad a father who had been a heroinejunkie and decided to play Russian Roulette with some of his addict friends and by fate or chanCe took the bullet straight through his brain, killing him instantly. Her mother being a heroine addict herself spiraled downwards after his death and gave her four year old child to her ageing grandmother that eventually had to put my twelve year old friend in this un-dire circumstance. I can only have he highest hopes for her today but unfortunately for most girls that have been victimized by society aren?t able to ever stop being a victim for the rest of their lives or go on to make other people victims themselves. A sad and unfortunate fate for so many innocent, and it happens so much more than anyone would rather admit too instead ofjust trying to ?nd a solution. Chapter 3 Hours later I was still twirling myself in the same office chair when spun around to see my Father walking in my direction. I nearly fell off my seat at the sight of him. Gripping the chairs handles I couldn?t imagine what in the world I would say to the man I once used to call Daddy but now hated for the abandonment and unforgiving wounds he instilled inside of me. He contemplated putting his arms out to hold me but instead anger and shame took over and he just shook his head. I never saw my Dad cry until that day and I have to say it made me feel young again and sad Ihad disappointed my parents again. The agents now standing beside us led both of us together back into the interrogation room to re-tale myjoumey to my father who they said I had no choice to tell, or they would have to tell him for me, being I was an under-aged minor and Ron violated the statutory rape law, among many others, when he took me back to his apartment and kept me as his sex slave. My Dad couldn?t believe what he was hearing and for his lack of better choice in words asked me to stop talking, he was just happy to know I was alive. Like everyone I?d known in life they would rather brush it under the carpet and not deal with the pain rather than realizing sooner or later it all comes out sometime in our life even ifit transgresses into our future then becomes what we are willing to accept out of partners, work, and people in general. Simply saying in other ways than with words that our bad decisions befall our tragedies later on in life. The next discussion was led to where I would go to from here. Before anyone could put his or her suggestion forward 1 leapt in with my two bits and made it obviously clear to my Dad that ifl was sent away to 18 Copyright Protected Material CONFIDENTIAL 15 another lockdown facility and if he betrayed my trust, again, he would never see me again. I would disappear for good this time and for all he would know I could be dead in no time on the streets. He looked at me and for the first time in my life he saw the many years I had grown up in the time I was gone and heard the seriousness in the tone of my voice when I made my vow to him. He put his head in his hands and told me the bad news, my Mom didn?t want me to come home and she was making his life hell for even suggesting bringing me back into their lives. I for some reason threatened her lifestyle and drove her crazy. I had been surprised about a lot ofthings lately but not that one. The last time I saw my Mom she ever so carefully lied to me and told me she was bringing me to an eye-doctor for an infection. Instead we walked into this tall blue building with people in uniforms holding clipboards and a few muscly guards, she ushered me inside and hurried up to close the large auto lock doors behind her leaving me there alone and imprisoned, which is what led me to recently living on the streets. My life was hell as long as she was in control of it, so when she didn?t want me back at home I was fine with that too, but there had to be somewhere else I could go. My dad said he had no choice but to put me back into the facility, but he made a sincere promise that he would not take any longer than a week to try to find a place for me to stay and to go to school. A week I could deal with, but I was still unsure if I could trust my father and hold him to his word, but yet again, I had no choice, Being my legal guardian he could send me anywhere he wanted and there would be nothing I could do, except for keep running. I gave in, and before he left the officers to take me back to the last facility I had run from, I gave him one last hug and reminded him ?one-week and I?m gone?. Nodding his head and squeezing his arms tighter around me, I could only hope he meant it, but he didn?t look too optimistic. In the police car on the way back to the facility they had to handcuffme in case I ran again, but I had no intentions to anyways. I was going to give my dad the week before I began to search for the right opportunity to jolt again. I was like a ?ghost come back,? said so many of my girlfriends from the past and there was now a lot of new faces there too. At night when we were all in bed and supposed to be sleeping, I would be daydreaming of better days and imagine myself somewhere in a comfortable bed, actually enjoying my life for a change. A week went by in this facility spending most of my days locked up in what they called ?The White Room?, a bare room with concrete ?oorin g, no toilet or even a chair to sit on. The only comfort I had was the blue sweater that was provided as part of the uniform, and my hair scrunchie ?lled with my stowed away cash that no one had f0und during my unpleasant strip- searches. I would spend hours in the white room for objecting to their 19 Copyi" Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page573 of 648 conformity and unwilling to participate in their drilling regime. I didn?t feel like] owed anyexplanation to these peOple even when they brought a physioiogist in to speak with me, ?What was the point when lwould be gone any day now? and as if any of these people even cared in the ?rst place, I was just another number in the system and they had a job to do. There was one mega-bitch, female guard, named Evelyn and she used to either really like you or really hate you and God-forbid you were one of the unfortunates that she didn?t like, she?d make your entire stay their an agonizing nightmare. Constantly picking on girls who were not strong enough to cope with their predicament or past issues, she?d stand them up and publicly humiliate them, and even when they begged her through their sobs to let them sit down, she?d only torment them worse. Which only made the strong girls want to antagonize the fragile one?s with more malicious intent. Luckily when I had previously been there she didn?t- take much notice of me, but I stayed out of harms way with her, just being quiet and observant. Being back here seemed like an eternity while I held my end of the bargain but unfortunately my Father didn?t. The ?rst chance I saw to run I took it. I was being sent to go get my blood and urine taken for drug and disease analysis. My driver would be a volunteer from the community and it was the perfect getaway for me. I was brought from the white solitaire room and led into the bright sun, feeling like today would be favorable in my escape. We got to the doctors office, my whereabouts told me I had plenty of ways to run and scouted out the best looking route. My plan was to barge through the volunteer?s inexperienced grip and wriggle my way out if needed, then hit the asphalt, running until my legs couldn?t carry me any further. Playing it out in my mind felt different to the anticipation that led up to actually doing it. The inner- strength I had was the only thing going to help me in this circumstance. We arrived in the parking lot and I hadn?t said a word to him the entire drive, the small framed Spanish man tried to make pleasant conversation but I couldn?t see him as anything but a challenge, so I kept quiet instead, ignoring his humorous attempts to befriend me. The car pulled to a stop and he came around the side to unlock my door, this was it, ?here we go? I told myself, and pushed past the volunteer. His anus grabbed out at me but only caught me by my shirt, he didn?t even put up much ofa struggle, like some of the other trained one?s I had gotten before, they would put me into body locks of all sorts but he just tore at the collar of my shirt letting me break free. I had done this many times before so I knew I wasn?t gone yet, lhad to first get out of these clothes. The cops would be looking for someone of my description in the area with a blue shirt and khaki pants, so my first stop was a busy shopping complex. I took the money from my scrunchie and bought myself a pair ofjeans, a shirt, and 20 Copyright Protectcd Material CONFIDENTIAL 53 Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page574 of 648 a sweater for disguise and my next stop was Dunkin Doughnuts? to get a chocolate iced doughnut and a cup of coffee. I didn?t have dOubts about getting out ofthe facility but I wasn?t expecting it to be so easy this time. My past excursions all began with an abrupt struggle sometimes ending in a brutal state of affairs after being pepper sprayed and fastened into some painful lock by forceful men four- times my size, then tossed into solitary until I saw my next chance to desert. I got to know the guards real well, as I spent a lot of my time being dragged down to the white room by them. There was Jim, a large black man who could?ve doubled for a ?Miami Dolphin?s? defensive linebacker. John was another big man with a ponytail and a mustache, and he looked like someone who de?nitely owned a Harley. The last guy Scott had a smaller build but made up for it with his steroid injected muscles bulging out ofhis neck and their was the added height from his curly fro. When they weren?t restraining me and holding me captive in solitaire, they were actually pretty nice guys, not afraid to have a laugh after some explosive incident and I held no contempt towards them either, they were just doing their jobs. It was de?ja?vOus all over again, free at last but where would I go now. With Ron?s scouts on the lookout for me, and now the authorities being notified I was a runaway again, I would have a lot of people searching for me, so I knew I had to be careful where I went. My last stop before leaving the shopping center was to use a payphone to call my parents, my Dad answered completely surprised to hear me on the other end, I wanted to sarcastically thank him for breaking his promise to me and I hope he is happy now, hejust lost his daughter for good. I stopped to listen to what he was trying to say and he told me was getting you out in a few days, I found you somebody to stay with, she?s a good person who has got teenagers your age, I was just trying to convince your Mother to sign the papers to get you out of there?. I was so outraged at her ability to put her own wants befOre the needs of her own flesh and blood daughter. I told him to come pick me up and bring me to the house so I could speak with her for the first time in over a year, but ifI felt threatened for one second I will be on my way quicker than a blink of an and on my own for good. He wasn?t overjoyed at my proposition, knowing what position this put him in as her husband but as my father he decided to put me first for once and take me home to confront my mother. I arrived at my house for the ?rst time in a long time and everything looked different. My parents refurnished and renovated the house. I didn?t even have a room anymore, my old belongings and bed were removed and it was now the office. Of course my Mom didn?t meet me at the gate or the front door like her long lost reunited. No, instead she 21 GIUFFREOO4 54 waited for me to come ?nd her outback smoking cigarettes and having a beer. She stood up from her seat and squinted her eyes loathing in her hatred she coldly slapped me hard in the face. The slap stung, but I matched her look with a familiar stone-coldness that only she could understand. Immediately we both started to cry and we washed away our anguish and resentment through our tears and consolidated our feelings for the ?rst time since the chaos ?rst affected our lives. She didn?t want to know much ofmy whereabouts and she still had a lot of anger to get over but she asked me to stay home at least. My little brother ran through the back door and hugged me so tight, I started to cry again and was saddened by how much time I had missed the time Ihad lostjust hanging out with my brothers and it took me even longer to realize how precious time really is. We were never going to be the average Joes next door but at least this was better than nothing. I loved being with my family again. We had and hon-fires with each other and life began to slowly piece back together. It was bizarre how normal it was when I first got home. I tumed ?fteen that year and it was the exact cup of tea that I had needed to boost me up and get me on the right track. I decided to go school to acquire my general education diploma or GED and got a summerjob with my Dad at Mar-A?Lago, Donald Trumps exclusive country club in Palm Beach. Surrounded by lush acres of tropical landscapes, manicured gardens, and a mansion made into a beach club for the rich and famous it is known as the ?Jewel of Palm Beach?. was in sheer awe at the gold arched ceilings and the grandeur ballrooms. The spa where I worked was world class, not only oozing in style but in the way each and every clientele was treated with the upmost service. My focus was now set on becoming a massage therapist, and working my way into a luxurious spa like the one I worked for now, only I was a locker-room attendant there. I studied many books abOut the anatomy of the human body and how you can affect a person?s well-being and health for the better through a simple healing touch. It was amazing to me the way the body responded to massage, I was more than just interested. I was determined to become a therapist. It was one of those anatomy books that I had my nose buried in one afternoon on a quiet Tuesday and it could get pretty lonely in the locker room, so ifI weren?t busy I?d sit outside by the spa?s reception and read my books in the warmth of the Florida sun. A lovely looking woman in her late thirties who spoke with a proper English accent approached me. I assumed it was a general question, ?like where?s the ladies room or was that the famous model from so?and-so?" but she was more interested in the book I was reading. Only believing at first we were just making small talk she was really intrigued at my choice of reading. She then asked if] 22 [l Copyright Protected Material CONFIDENTIAL 155 Case 18-2868, Document 278, 08/09/2019, 2628230, Page575 of 648 did massage on the side, I stated I was only reading the book and had not yet began to study but one day 1 would love to practice massage therapy. She introduced herself as Ghislane Maxwell. I would later find out that she was the daughter of the iate prominent businessman and disgraced newspaper tycoon, Robert Maxwell. I told her my name is Jenna pointing to my nametag on my shirt and offered her a cold or hot beverage, as those were my instructed duties at work. She accepted a tea and went on to chat a bit about this rich guy that she worked for and she knew off- hand that he was looking for a massage therapist. Just doing me a good deed out of her kindness of her heart, I?m sure, she offered to introduce me to him. I declined her ?rst proposition, thinking out loud, told her I didn?t know the body well enough to even attempt an interview. She didn?t seem worried at all by my fear of incompetence saying that if he liked me enough he would get me the best training in the industry. Ghislane thought i had a cheery persona and fit the quota for what he was looking for and as she put it an enthusiastic learner that she said she gathered from the sticky notes popping out ofthe various sections in my book. I accepted her phone number and the house address and told her I will call her ifl am able to come over after work. I rushed over to the tennis courts Where my dad was working and told him of the news. We both thought this could be a wonderful opportunity to get my accreditation in massage therapy. Seeing that it was a lady in her late thirties who came off as more ofa nurturer rather than a procurer, neither of us saw any reason to be hesitant. Chapter 4 At around Five pm. my dad drove me down to the bottom of?El Brillo Way.? on the Palm Beach intercostal. We pulled into a short driveway beckoning a large pink mansion with heavy wooden doors. I was so excited about this chance and asked my dad to wish me luck. He gave me a big squeeze and wished me the best. He walked me to the front door and I rung the door chime. Moments later we were greeted by an older gentleman dressed in a casual butler uniform. I told him I was here to meet Ms. Maxwell for a massage trial and he opened the doors for my father and telling us to wait in the entry as Ms. Maxwell would be on her way any second, and she was. Down'the stairs she walked with a warm smile, her short black hair seeming very proper and elegant, for now. She shook my fathers hand and thanked him for bringing me and kissed us both on the cheeks. They spoke briefly about whom she worked for and about Mar-a?Lago where we worked. She was in hurry, you could tell to end the conversation and say good-bye to my dad, which she did so 23 ever pleasantly. She said the boss was upstairs and waiting my arrival, so with that I said bye to my dad and began to follow Ghislane up the stairs. I was so nervous, but I didn?t show it. I kept my reserve and demeanor cool as ice, trying show maturity for the open position. We continued on to the massage room, passing by a grand chandelier. and a couple wooden hall tables displaying a multitude of photos displaying young girls and beautiful women, trying not to gawk at them I didn?t even notice that some ofthose giris were only wearing their smile. Ghislane asked me how my day at work was and I told her it was easy peasy as always just trying to make simple conversation. There was a fork at the end of the staircase and she led me to the right hand side. The lights were dimmed in the bedroom but I could still see the King Size bed in the middle of room, we did a U-turn around the bed, which led us into a massage room. Dripping in luxury I could?ve definitely compared it to the renowned Mar-a-Lago?s spa?s, it had marble walls and a glass enclosed shower and self-automated steam room at the very end of the Burberry carpeted room. There was a large mirror over a basin to the right of the room with an array of oils, ointments, soaps, and lotions and a small closed door, which I assumed must be a closet. The only thing that struck awkward about this room was the naked man laying face down atop of the turquoise massage table in the center ofit. had to be prepared for this," I told myself. Massage was something I had never done before so I quickly brushed away my thoughts of possible schemes, wanting to believe whole-hearted this was going to be legit. Ghislane introduced us to each other and I proceeded to make his acquaintance. Looking up at from his downwards position, he looked me over and gave a smile to Ghislane, an obvious notion of his apprOval. He was Jeffrey Epstein as she pronounced for him, as ifI supposed to recognize his name or something. He affirmed, ?lt was his pleasure? and replied to just call him Jeffrey, ?No need for formalities? he answered, cleverly putting me at ease. This man did not look like someone to beware of, Both him and Ghislane appeared to be very nice people and conscious of their health as their need for massages and spa visits, no alarm bells went off, yet. Iwas prepped by Ghislane to ?treat this as a lesson from her and follow her exact lead, ifI did good tonight then maybe I would become Jeffrey?s Travelling Masseuse, seeing the world and getting paid well for it?. Iwas very hopeful, ajob like this could really make my dreams come true. 1 followed suit and washed my hands with warm water so the coldness would not shock effery?s naked body, then lathered them in rich body butter. Ghislane told me to always keep one hand on Jeffrey, even when getting more lotion, so it didn?t make him lose concentration on being relaxed. She gave me a tip and told me to keep a blob of lotion high up on 24- [l Copyrigl Protected Material CONFIDENTIAL. El Copyright Protected Material GIUFFRE004156 CONFIDENTIAL UlUlil I 57 Case 18-2868, Document 278, 08/09/2019, 2628230, Page576 of 648 my forearm so it prevented me from having to keep going back for more and was less disruptive to Jeffrey. This all seemed for real to begin with, I was being educated about the body and splitting Jeffrey?s body with Ghislane, mimicking her every motion. Starting with his feet, we began with his heels and arches of his soles. Pushing the blood up his calves in upward strokes to rejuvenate the body?s blood supply and being careful to mind his leg hair didn?t pull. I was keeping up with her and enjoying the education. It was so interesting how the body worked and I couldn?t believe I was learning all of this for free. Once I got a bit of a groove following Ghislane, they began asking me all sorts of questions about my past and it didn?t take long before the conversation led down the darker experiences of my young life. When they found out that I hadn?t led much ofa normal existence they only probed me with more questions, which being put on the spot answered honestly. The funny thing was they didn?t seem appalled at all by my statements, rather entertained if anything. Jeffrey called me a ?naughtyegirl? with that wry smile of his, and half playful and half defensive, I answered ?no I?m not, I?m really a good girl, just always in the wrong places? he then replied, ?it?s OK, I like naughty girls? and rolled over onto his front side to expose his complete nude self. He wasn?t the first man to show me his penis, so I wasn?t shocked at the appearance of his manhood but I was incredibly shocked at his complete ease to present himself with an erection. I tried to ignore it waiting to follow the next directions off of Ghislane, who surprisingly now stood behind me bare breasted. Before I had a chance to even think of replying hastily she began to slowly undress me, while Jeffrey started to stroke his manhood while watching us. She unbuttoned my blouse and removed my bra, revealing my bosoms. Cupping them in her hands she moved her lips across my nipples, licking and teasing them with her tongue making them cold and stiff. Next her hands moved down to my little white skirt, removing the ?nal piece of my remaining uniform. She slid my skirt down my legs with ease, for a moment keeping on my love-heart panties, so they could both take notice of my apparent youth. They even snickered to each other about How cute she still wears little girl pantie?s? Jeffrey said, and Ghislanejoined in his laughter. Acting as my madam, she instructed me to start by licking his nipples and after I had sufficiently pleasured both of them, then prompted me to go down on Jeffery orally while she rubbed her breasts along his body tantalizingly. She moved behind me again this time to remove my panties and start fondling the delicate folds between my legs. I was still in shock from the initial degrading blow. I hadn?t even let the reality sink in, it was all too much for me to emotionally handle so instead I hid behind my fears, which I told myself wasn?t going to ever be worth anything at all and this would probably be as good as it gets for me? after all I thought, 25 Copyright Protected Material CONFIDENTIAL ?what have I been trained up for until now?. Nobody ever stopped to ask if! was comfortable or ifI wanted to stop, no, instead, Ghislane only directed me to conclude the massage session by climbing up on the table to be fixated on Jeffrey, straddling him so he could penetrate me. When it was all done and over with, I was taken into the steam room with just Jeffrey to get further aquatinted, as Ghislane left the room to go get dressed. He asked me to grab his feet and rub them not saying a word about whatjust happened, like it was all normal and accepted. I listened to him ramble on about the health bene?ts ofa sauna and the histmy ofit, ignoring the fact of the matter of his pretentiousness degrading my Spirit. I ?gured I had gone too far already, what would be the point in throwing in the towel now after I had done exactly what these people wanted. Whilst we were sweating out our bodies? toxins, and the steam was blasting my burning face I listened to his lessons, entertaining his ego, I let him become my teacher, he seemed to like that. He sounded like a very clever and intelligent man though. Telling me his story ofhow he made himself an empire of billions from being a middle-class professor to an elite ?nancial advisor for clientele with only billions in their bank accounts and through his so-called ?lessons?, He became my mentor and I emerged as his pupil, the teacher?s pet. After the sauna we went to the next glass door beside us where the shower was. He turned tap outwards and stood underneath the water as I stood naked and cold from the temperature difference. Instead of asking me to join him under the warm stream, like I thought he was going to, he handed me a bar of soap and asked me to wash his body from top to toe. It didn?t stop there Ihad to massage the shampoo and conditioner into his scalp as well. I was bewildered someone would ask this off of someone else, wasn?t it belittling enough having to endure the illicit massage from beforehand but now this. The surprises kept coming that night, as this was definitely not how I expected my interview to turn out, but that?s what I had leamed in my short time on this earth, life was full of disappointment. I let everyone else take the power of authority from myself and use me in whatever way he or she wanted instead of standing up and giving myselfthe respect I deserved, which in turn would?ve helped me get through life without all of the abuse I ended up copping. Not given the belief in myself from an early age on I suppose is what affected my sense of control. Always letting the one?s with power and strength reduce my inner-self to shreds until I was cut so tiny in size I would be completely subdued to only their wants and needs left ignoring mine. The men I had encountered in my short experience with them only repeated their inflictions convincing me there was no running away from the sick world I lived in, not yet understanding it all came down to the choices I had 26 Copyright Protected Material made for myself, I needed some encouragement and the right words to unlock my very soul. Jeffrey told me the towels were on the heated rack just outside the shower and asked me to get one and pat him down. Again putting himself first as I sat there freezing while I compliantly patted down his body with the white fluffy towel until he was dried. I nearly expected him to ask me to dress him as well, but not surprisingly that came later down the track too. I dried myselfoff and wiped the make-up from under my eye?s, keeping quiet not sure what to really say and half-embarrassed from the entire evening?s events that just took place. 1 just remained silent whilst we both got dressed until he brought me downstairs where Ghislane was sitting at a desk holding his black leather duffel bag. When she moved from the chair to let Jeffrey sit down, she passed him the bag and began to tell me that 1 had great potential to be a massage therapist, they really liked my style and who knows where this could lead too. She asked to see me again tomorrow, same time after work. He opened the bag, revealing stacks of brand-new hundred dollar bills separated with rubber bands to count by the thousands He grabbed one stack and took out two crisp notes, placing them in my hand. He laughed that it was nearly my whole week?s wage at Mar-A-Lago. Only there I didn?t have to degrade myself as his new little toy. When I got home my parents were anticipating my arrival. I kept it simple and sweet with my folk?s, only telling them of the lessons about the body 1 had received and the future prospects in massage therapy that lie ahead. Nobody questioned who I was working for and complimented my ability to be a hard worker. I quickly got out of that conversation afraid I might give away a hint of shame in my eyes but no one caught on. I excused myselfto the bathroom to have a shower and stared into the mirror for a moment, asking myselfifl could really go through with this only to mentally respond by reminding myself this would be as good as it gets for a girl of my stature and limitations. I scrubbed myself rigidly in the shower as ifit would wash away the filthiness of the night, but it didn?t help, 1 could still feel their hands in me and all over me and inside ofme. Trying to sleep that night was nearly impossible too, closing my eyes only to drift away to flashbacks ofthe moments I had to give myself to Jeffrey and Ghislane, each replay an exploitation ofmy vulnerability. The next morning I awoke feeling anxious about the day ahead, trying to push yesterday?s memory from my thoughts, I was quiet for the whole trip to work with my Dad. Before the parking lot he asked me if everything was okay, I lied, for his sake and mine. My life was being transformed and I didn?t even know it yet, but soon enough I would be a brainwashed tool only used for the sexual pleasure of others. 27 Copyright Protected Material CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page577 of 648 About to be entrapped in the same life I had broken free from only months ago. Convincing myself in order to succeed I had to step up from being a girly teenager and start thinking like a young woman, it would be my ticket to a great career and a fortunate life. 1 told myself?So what if] had to bargain my body to this rich old geezer, some girls get themselves through college by becoming a stripper and using their bodies to pay for degrees, others go down even worse paths.? I guess it was just another way to fathom the road I was going down, the effectiveness of the lies I forced myselfto believe was working as I continued to tell myself I had to make it any way I could rather than ever letting myselfsleep 0n the streets again. 1 was trading one shocking lifestyle for another, thinking I was choosing the right one. lfI could go back in time to ever meet myself 1 would choose this time in my life. I?d start with a good hard smack to my head to ?rst shake some things up in there and next I would tell that girl she could actually make it on her own if shejust worked hard at earning an honest wage and built her life up slowly. There is no rush or time limit to ever stop reaching for achievement. Sadly enough I probably wouldn?t of even believed myself anyways, learning my life?s hard lessons through the experiences I continued to suffer. I went to work at Mar-A Lago that day trying hard not to think of what lay ahead in the afternoon too come, but the later the hour got the more distinguished the knots became in my stomach. I spoke to no one ofthe details to my explicit interview but told one girl how I was so happy I was now of?cially studying massage therapy, another lie. My friend was surprised and intrigued that these people who could afford the best of the best of therapists in the world chose an untrained ?fteen-year?old girl to perform a massage. She never said it in words, but her body language told me she knew exactly why they wanted to use me and it wasn?t for a therapeutic reason either and deep down inside I understood. The rest of the afternoon slipped away quickly and before I knew it I was standing before those large wooden doors again, giving a moments pause but long enough to draw in my breath and exhale some of the anxiety before ringing the doorbell. Juan answered the door again and told me Ghislane would be down in a few moments and asked to follow him into the kitchen. There was a pleasant looking young girl with blonde spirals in her hair that glanced up from the mound ofpaperwork before her. Her shocking blue eye?s and appealing English accent seemed delightful and she introduced herself as ?Emmy?, Ghislane?s Personal Assistant. I introduced myself as ?Jenna? which is what most people knew me as and told her I was on an employment trial to become Jeffrey?s massage therapist. She had a coy smile on her face that told me she knew exactly what I was on trial for. Something in my gut told me 28 CI Copyright Protected Material CONFIDENTIAL 161 Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page578 of 648 this wasn?t the ?rst time a young girl had been trialed for the same position I was about to ?ll. We were only chatting for a moment before Ghislane appeared and told me Jeffrey was ready for his massage. I was led through the extensively large house to the winding staircase that would lead me up to the same dreaded room where I would have to re-enact last night?s performance. I wasn?t far from wrong. I gave Jeffrey a massage with Ghislane leading the way again, this time we surprisingly made it to the front of his body and she continued to show me how to massage all the way up to his stomach pushing my hands in a spiraling clockwise circular motion to not disrupt the bowels and then we came up to his chest. He couldn?t dare contain himself for one second longer, telling me to put my lips on his nipples and give them a kiss. Jeffrey moaned in pleasure and Ghislane started to undress me from behind. Within moments I was completely naked and Ghislane had her top off. She was caressing my body with her hands while Jeffrey moved his hands down to stroke his loins while he watched her and I kiss and touch each other. I didn?t know if she was doing this for the sake of his eye-candy but she sure did act like she loved having the control over me telling me what to do throughout the entire threesome. Jeffrey?s climax was always the end to our sessions and this time he wanted to have me make him orgasm orally. Afterwards we went for the ritualistic steam-room, this time Ghislane joining in with us for conversation. She asked me to massage her feet this time while we were in the steam room, showing me that Jeffrey wasn?t the only one I had pay my homage to. We all had a shower next and then we all went downstairs to pay me and have Juan drop me off back home. The following afternoon I received a call at work, surprisingly it was Ghislane asking me to come over when i got off of work again. The compliant side took over and I told her I looked forward to meeting with them today, instead of telling her to go screw herself for lying to me and making me degrade myself more each time I saw them. I ?nished work for the day and my Dad brought me over to El Brillo Way again, where the vultures were patiently waiting in their lair, he wished me well as I hopped out of his big truck, looking ever so much like his little girl again; I gave him a smile and a wave as he drove down the long driveway, waiting for him to suddenly tum back and not leave me alone to my task. I shook myself out of that calamity and put on my ?big girls? face. Juan brought me to the kitchen again as I waited for Ghislane. He offered me a cold drink and some fruit on a platter, I accepted and was grateful for the rejuvenation before I went to work again. It wasn?t long before Ghislane approached me from behind with a cold intense look in her eye. [jumped from my seat, feeling like maybe I shouldn?t have been eating and drinking while on the job, as her demeanor seemed annoyed 29 GIUFFREUO4162 and temperamental in the seconds that she appeared. She told me I would be on my own today as she had business to attend to, so make sure I remembered what she had taught me, as my trial depended on it. Chapter 5 Iwalked up the stairs by myselfthis time, taking in more ofthe decor, noticing the more I looked around the more I noticed a different girl in each photograph in his collection of half-nude and topless girls on display around his mansion. I couldn?t believe how many girls there were, it?s not like Jeffrey was much to look at. He was an aging man in his early ?fties with shiny grey hair and characteristic lines drawn down his face as ifhe had seen harder days. With no prospects of ever settling down or having a family of his own, Jeffrey treated us girls like a piece ofclothing he could try the next. So why was there so many girls in these photo?s? I wondered to myselfifl would end up one ofthose girls among his collection of forgotten relationships and broken promises. I continued to make my way up the stairs, and as ifall ofmy senses were heightened from my bare nerves being exposed, I could smell the cleaning detergents recently used by the housekeepers, my observations of the shade oflighting through the concealed blinds as I entered Jeffrey?s bedroom appeared golden, and the sound of stillness except for the thud of my rapid beating heart all made me more aware ofhow nervous I was to be on my own. Not that Ghislane was anything ofa comfort, but I didn?t know what to expect or how I was going to lead myselfinto upholding my obligation in pleasing him. I would hope for the best I thought, trying to uplift my con?dence as I opened the door to the massage room with the typical scene of Jeffrey laying naked facedown in the massage bed waiting for his entertainment. It was de?ja?vous? all over again. Repeating what Ghislane had taught me, with him commenting on what else I should be doing, until was expected to grant him all of his spoken desires. We ?nished up with the shower again and he seemed very pleased in my contribution of myselfto him, giving in to every request. He told me to go ask Juan to pay me, as he was lethargic after the massage and intimate affair between us and now was going to have sleep. I walked back down stairs and told Juan that Jeffrey was asleep and said pay. He went to Jeffrey ?s desk and took out the exact amount 1 was owed without even asking how much I normally get paid. He then drove me home, only to be back the next afternoon. 30 Copyright Protected Malena! CONFIDENTIAL 163 LI Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page579 of 648 The following week was a daily routine, providing Jeffrey with massages and continuously being groomed to ful?ll all his needs. Often joined by Ms. Maxwell and her assistant Emmy for sexual of all kinds. I was mentally and physically exhausted from the week of working and having to keep up with Jeffrey?s strenuous late night activities. I couldn?t believe what I was doing but it was all starting to sink in fast. Most nights when I got home, l?d brie?y say ?Hi? to Mom and Dad before heading straight to my bedroom. I couldn?t even sleep well anymore. Closing my eyes at night I would ?ght the inevitable flood of thoughts, replaying the moments of shame that ate away myself piece by piece. My only reasoning being Ijust had to keep telling myselfit would all be worth it in the end. This afternoon Ghislane appeared to be in a much better mood. Instead of taking me straight up to Jeffrey she took me to a yellow guest room where Emmy mostly stayed. It had a balcony where Emmy was already outside reading a magazine and puf?ng on a cigarette. Ghislane lit one up too and then offered me one. I hadn?t smoked cigarettes much before, besides trying to look cool in front of one of my friends, but never really took to them, so when I started to cough from the inhalation of smoke, the girls began to laugh and joke about my in-experience. It was an icebreaker for all of us to laugh and poke fun at me. I was then able to give it back to them saying I would rather be an in-experienced non- smoker than an old lady with a raspy smokers cough. 1 don?t think Ghislane was used to somebody giving it back to her, but she seemed to like it, as long as she was able to have the last say. I knew my boundaries and she liked that I wouldn?t cross those invisible lines. All three of us chatted like friends and it started to feel like some kind of a strange relationship was budding. After about fifteen minutes of chatting away, Ghislane instructed me to wash my hands thoroughly, as Jeffrey hated the smell of smokers, and to follow her down the hallway to the massage room where he?ll be expecting me shortly. I did what she asked and Sprayed myself with the body spray that I always carried in my purse and headed down the hall to Jeffrey?s room. When I opened the door to the massage room surprisingly-it was empty. I sat down on the already made up massage table and was careful not to mess up the neatly folded towels on the end ofthe bed. It was a good ?fteen more minutes before Jeffrey made his appearance. It was strange seeing him in clothes for the first time. He wasn?t wearing what you?d expect your typical billionaire?s attire to be. He was wearing a pair of sweatpants and a Harvard sweatshirt, which he began to remove immediately. This time he wanted to commence our session in the steam room, so I began to undress as well. We went into the steam room and he pushed a few buttons and the steam began to pour in from the marble 31 GIUFF 1115004 164 wall?s built in jets. There was a bench coming out of the wall also made out of marble that went from either side ofthe room and had a step underneath it where I was instructed to sit on so that I could begin giving Jeffery his massage. Our conversation started off about simple things like how was your day at work, and I asked Jeffrey how his day was lounging around, just being polite to each other. He was acting out of character being a lot more attentive and conversing with me about other things than sex or massages for once. Starting with his heels, ankles, toes and arches in the soles ofhis feet I massaged all the way up to his calves. It took a lot more strength to massage in the steam room without oils or lotions and the constant blowing of steam in your face making me twice as exerted. I was beginning to really start to heat up when the door to the room suddenly opened to reveal two naked women. Ghislane and Emmy acted as ifthey came in tojoin us for a steam bath, but my instincts were telling me otherwise. At least the cold burst ofair and escaped steam revived me a bit. So there was Jeffrey and Ghislane sitting on top of this marble bench, each with a yOung girl at their feet. Emmy and I continued with the massage until they were ready to head into the shower. There were two showerheads that Ghislane and Jeffrey both stood under while they were being lathered with soap bubbles as we washed their bodies. After the shower Ghislane led us into Jeffrey?s bed to ?nish today?s session with Emmy, Ghislane and I performing lesbian acts of foreplay on each other while Jeffrey laid back and watched. Stroking his manhood in much delight, he brought himself to climax, and the session was over within moments. We all got dressed and went downstairs to the kitchen for some refreshments. Like nothing had happened at all, it was all so bizarre for me, the whole ordeal with them since this all began. I couldn?t understand why Ghislane and Jeffrey had such an openly intimate relationship but yet never regarded themselves as partners. They rarely kissed and never held hands or even slept in the same bed. It was more like a sexual arrangement between the two of them. She brings in the girls for his peculiar taste and he supplies the lavish lifestyle she was accustomed too before her family lost all of their fortunes. I wasn?t sure how to act or feel, always obliging to their needs but reserved enough not to get attached, as if there was this invisible hierarchy and by instinct I knew my place. We all hung out in the kitchen for a while before I asked when Juan could bring me home as I had work in the morning and was tired. They said no problem and called Juan on the intercom right away, but said we?d all have something to talk about tomorrow. I knew it had something to do with my employment trial and from the way they were acting tonight, I could only assume I got the job, but you never know with these 32 Ll Copyright Protected Material CONFIDENTIAL (J?lLll?lilULOll-l 16$ types of people. Their friendships and partnerships can change like the weather. I went home that night still confused on how I could let myself sink so lowact like I enjoyed submitting my body and being their new subservient plaything all for the fact that I was making anywhere between $200-$400 for just a couple of hours. Then spent the rest of the night regressing on the entire event in my head over and over again. I battled those thoughts with the hope that I was receiving a profession out of this and making good money in the meantime. All [had to do was keep lying to myself long enough until I eventually believed it. Arriving at Jeffrey?s on time the next afternoon, as I always did, understanding punctuality was a sign of respect and I wanted them to feel as ifthey had my deepest appreciation for the once in a lifetime chance they had given to a girl of my history. This time when Juan answered the door he told me Mr. Epstein and Ms. Maxwell were waiting for me upstairs in the massage room. I began my hike up the familiar spiraling staircase and through to the room where my arrival was being deeply anticipated. They were already in the steam room awaiting me to join them. I undressed out of my uniform and folded them in a neat pile, which I placed upon the marble basin. Having one last look in the mirror before I exhaling a deep breath as if I was plunging into deep water, I knew today was a big day. I either accepted their offer and trade my morals for opportunity, or walk away with the prospect of one day many years from now trying to make it on my own which I knew endowed hardships of there own. So confused about what decision to make, Ijust opened the door to the steam room and let them do the talking. Used to the routine by now I sat below Jeffrey and began to massage his feet and legs as I listened in on their ongoing conversation about travel plans for the next few weeks. Ghislane and Jeffrey turned their attention to me and he asked me how would I like to go see the big city of Manhattan. I told them I had never visited New York before and it sounded like an adventure but my job at Mar-A-Lago was only a summerjob and wouldn?t be able to get the time off, especially that summer was so busy anyways. Jeffrey then made his announcement, that I shouldjust quit my job at Mar-a-Lago and become his permanent travelling masseuse. He then further persuaded me with all of the luxuries that came along with my acceptance. Rather than being paid $9 dollars per hour at my current job I could be earning $200 dollars per massage, which he even said could be a few times a day. Tomorrow we could be leaving Palm Beach together in his private jet first heading to his residence in the upper east side of Manhattan, also the largest mansion in NY, and would next be setting off to the Caribbean, where he owned a secluded island just past Little St. 33 Lopy Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page580 of 648 James for a bit of relaxation. The temptation of his grandeur offer wasn?t hard to give into, my vulnerability to be lewd into his grasp seemed comforting at the time. The idea that females were nothing more than an empty shell of beauty bound by only a body to offer was a notion I had accepted a long time ago with my ?rst teacher, Ron. My reaction had to be more than amusing for their egos, even though I was excited to be traveling I could only imagine the likeliness ofhaving to be at their beckon call as well. In my head Ijust told myself we all do what we have to do in our lives to succeed no matter what it takes, and with no one knowing the truth, [had no one to talk me out ofit. I accepted his offer and knew from here on out I would be his servant to his sexual desires until one day I would gain my credentials and only then could I go out on my own and make it in this world that when so young seems so unconquerable. The night advanced into the usual grooming of his requirements, for the next hour and a half being exploited to satisfy Jeffrey?s every sexual whim. My mom cornered me that night, before I had a chance to avoid speaking to anyone, heading to the shower then my bedroom, like I had been the last week. She knocked at my door with a hostile look in her eyes, Virginia, what exactly does an older couple want with a fifteen year old girl, who has no credentials and with no experience in massage therapy?? She used that stem tone of voice that she?s always had, when I was in trouble. Thus, as impressionable as Iwas, my blue eyes batted their innocence in her direction and I ?ashed her a girlish grin selling her the pitch that I had been given earlier that night. Not mentioning the other side to the glamorous lifestyle I would soon be living in, I told her about the money I?d be earning, the places I?d be seeing, the people I could meet and most of all the trade I?d be learning. It all sounded so good, except it was a bunch oflies I had to tell her and myselfto otherwise convince us, that this was a once in a lifetime opportunity, and I had to take it. She asked when all of this would start, and I as shocking as it was to me too, I told her I had to go start packing. We were leaving the next morning off to N.Y.C. At fifteen most girls would be sucking up to their parents to go to a high-school dance or to go on a date to the movies with a nervous chap, but I wasn?t even asking her. I was simply letting her know that I would be away for the next couple weeks, maybe three and would keep in contact when I got free time. Her daughter was lost a long time ago, and shejust now realized it. Backing out ofthe bathroom, with nothing she could say, she left me wondering to myself who I was becoming. Instead of driving me to work the next morning my Dad dropped me off at Jeffrey?s mansion, he told me not to worry about calling Mar-A-Lago, 34 fl Copyright Protected Material l67 Ill Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page581 of 648 he?d take care of it for me. We said our good~byes outside in the driveway, Jeffrey even coming outside to meet with my father to shake his hands and assure him that his daughter will be more than looked after. I hugged my dad feeling like I was on the verge ofa steep cliff, when he let go, so did the last of my innocence. Juan drove Jeffrey, Ghisiane and I to Palm Beaches? Private Airport and the luggage handlers escorted us on the tar mat where we all boarded on Jaffrey?s black jet. Larry was his main pilot, he had shiny grey hair and long lanky legs, but a very sincere smile that instantly made you feel at ease. He greeted us at the staircase that led into the main cabin. It was as lavish as I imagined it would be. The seats were enveloped in the ?nest beige leather with polished wood grain ?nishes and there was a kitchen in the back with an adjoining toilet. Jeffrey saw the amazement in my eyes and to make it more thrilling he brought me up to the cockpit and let me watch with a bird?s view ofthe take off. I was on a natural high when I came back to the cabin and was instantly brought back down when Jeffrey rested his bare feet on top of the reclined seat and instructed me to get to work and start massaging him. My future was in his hands now, so when he wanted something, I wouldn?t hesitate in giving it to him. Chapter 6 Upon our arrival at New Jersey?s Private Airstrip, the driver Jo-Jo met us. His name was most likely shortened for something of his oriental decent. Jeffrey liked to shorten the names ofhis multi?cultural staff into American names. Even Juan and Maria were known as John and Mary. We arrived in the Upper East Side of Manhattan. His principal place of residence was the largest home in Manhattan, eight stories of opulence. It used to be a Private School for boy?s many years ago, until Les Wexner, Jeffrey?s best friend and mentor bought it for him as a mysterious gift. There were two large Chinese gargoyles outside the entrance, and beside the heavy looking wooden doors there was an intercom with a camera overlooking us. I walked up the concrete steps into a realm of wealth, glamour and most of all in?uence. My eye?s glistened at the splendor of his palace. Caramel colored marble tiles spread through the ?rst floor, where his gourmet kitchen and dining hall were also located. Then I came to this sweeping staircase that curved into the next level where Jeffrey and I went into his office, even though it looked more like a museum exhibit. Ancient draperies that told lascivious stories of their own covered parts of the elevated walls, and the remaining wall spaces were taken up by rows on top of rows of books. He loved to read, as he 35 GIUFFREOO4168 often found it hard to sleep and was comforted in the early morning hours with his literature, or sometimes in other ways I would come to ?nd out. There was a mantle piece and a sofa with two armchairs next to the grand piano that flaunted more of Jeffrey?s beautiful conquests, young women posing in salacious pictures, suggesting I could be easily replaced next to one of those girls ifI failed in keeping him satisfied. There were also some pictures with recognizable political and royal figures either shaking Jeffrey?s hand, or with an arm around each other, even one with Jeffrey and the Dali Lama, although his church was the bank. He liked to use his power, wealth, and money to manipulate everyone in his life. He made a phone call that sounded business like and I didn?t mind, I was quite enjoying taking in all of the beauty around me, Iwas blinded by all ofit. I was still waiting for him when, Ghislane came in. She asked me what I thought so far of my trip to NYC, I knew she was talking about the house, she loved to gloat, even though none of it actually belonged to her, she wanted everyone to believe that it did, I complimented her on the mid-evil looking tapestries and a few other adornments, when she cut me off mid-sentence to compliment it herself, telling me the history about one of the century tapestry?s which to an unsophisticated eye, looked to me like a rug on the wall. Jeffrey hung the phone up and walked over to the sofa where we were sitting next to the mantle piece and took a seat on one of the armchairs. He didn?t seem worried from the phone call but his mind was de?nitely somewhere else from the hard look on his face. We all spoke for a few moments more about the splendid decor before Jeffrey had enough small talk and needed some of his own relaxation time. He told Ghislane he was going to show me to the massage room and he?d be back in a couple hours. She agreed he looked like he could use some time to unwind and with that wry grin of hers, she gave me a look that told me precisely how he was expecting to be relaxed. We left his office all together, Ghislane going downstairs, and Jeffrey showing me to the lifts. The lift looked like it?s original that came with the school. It was made out of brass antique with archaic cuts throughout the arches at the top. It wasn?t the only lift in the house, but certainly the most beautiful. We walked down a long hall carpeted in a royal red and golden trim, passing by a bronze pagan statue of the horny little goat God ?Pan?. How adequate, I thought, Jeffrey to a tee. We walked into this dimly lit room. Another daunting chamber that looked like we had stepped back in time to the dark ages. It took a second for my eyes to adjust to the darkness, and Jeffrey beckoned me to follow him through the room to the open adjoin shower, toilet and steam room. The room was in black marble to accent the dreariness, and smaller than the one in Palm 36 CI Copyright Protected Material 16?) l?l Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page582 of 648 Beach, but it had it?s own witchery feel to it. Another unseen sideto this Man I was coming to know. We both undressed and Ifollowed Jeffrey into the steam room ?rst. He loved feeling clean, teaching me that the steam would deplete the toxins from your skin, which was great during a massage when your blood flow is being replenished. I grabbed his foot out ofinstinct, knowing I had to be constantly on alert to keep this man satis?ed. He looked down at me with a nod and reclined back against the wall as the steam pored in, this was his idea of alleviation. I worked up to his calves and within a few more minutes, he said he was ready for his massage on the bed. We got out and towel dried off, both still nude, he asked me to stay undressed, then we headed to massage bed in the middle of the room. He lay down on the bed and told me to turn on the CD player on the wall hutch, where all of the oils and lotions were set out, I hit play and a collection of mixed classical began to fill the silence. I could tell he wasn't in one of those moods to be uplifted with idle chat, so I remained silent, letting him enjoy my slow movements, making my way up his body. My instincts told me I was right about his mood, as he seemed to appreciate the quietness of moment and the leisurely of the strokes I was using to massage him. When I got to his scalp he turned over, and grabbed my hand to put on his erect manhood. No words spoken yet, I took the gesture and initiated what 1 had been taught over the last week. While pleasing my master his hands groped my young ?esh, penetrating my insides with his ?ngers, he was only concerned with what he wantedtest drive and he was pressing his new gadgets. His soft moans were soon brought to louder heaves of breath and myjob was done. No intimate kisses, or sweet pillow talk. He showed his appreciation with money, never attachment. We concluded 'with a shower and he told me he had some business to conduct. He walked me to the lift and told me go to the next level and my room was the first one on the right, it had an intercom in which he can contact me when needed. I hit number 5 on the lift and took his directions to my room. I opened the door to this massive loft, the size of an adequate house. I walked down the long hall and my eyes took in the magni?cence of my surroundings. It was a room ?t for royalty, and later would ?nd out had been stayed in by some. The room was trimmed in gold paint and had another eerie tapestry on the main wall as feature. There was a T.V and a huge king sized bed, with goose feathered comforter and pillows. All of the glitter from Jeffrey?s lifestyle he was offering me ?nally covered the last bit of sight I had left and I let go of my consciousness. Excited by my enthralling day, not having anyone around to have to act reserved, Ijumped into the soft bed and lay looking around, thinking about how quick life could change based upon one swift decision. Dazing 37 170 into the artistry, the intercom buzzed on the telephone next housemaid letting me know Jeffrey wanted to see me in his of?ce now. ?Already? lthought to myself, I wasjust getting settled in. I was worried I was going to get lost in this ancient museum, but I got myself back to his of?ce with no trouble, it was kind ofhard to miss. I knocked at the ajar door and Jeffrey called for me to enter. I walked over to his desk, where he wasjust ending a phone call and he opened his duffel bag full ofmoney. ?I?ll be out at my other of?ce for most of the day, so instead of being locked inside I thought you should go do some sightseeing for the day since it is your ?rst trip to the Big Apple? He didn?t count how much he was giving me he just handed me a bundle out of the banded $100 dollar bills. He knew just how pull the right strings, making me squeal in delight and give him a kiss in the cheek, since we were never really emotionally intimate, it would be odd to act in any other way, but he seemed to like it. I ran upstairs to get dressed for ?City? shopping and put my make-up on, then hit the streets of NYC, looking for a place to start spending this load of dosh. When I got to the end of 72"d street on 5th Avenue, I had no idea which way to turn, left or right. I thought l?djust follow the lights past Central Park and see the local sights on my way. My eyes were once again peeled back in splendor. I had never imagined a place so busy with the hustle and bustle of all the walks oflife. My ?rst stop was to buy a disposable camera and I was off taking photos of every wonder that caught my attention. I didn?t do much shopping as I had planned too; I was having too much fun exploring this capacious metropolitan. When it started to hit dusk I began walking back to Jeffrey?s but not before stopping off to enjoy a giant slice of pepperoni pizza, it was the best I had ever had, and considering I was going back to Jeffrey?s chickpea and tofu salad?s or such. I really hated the healthy cuisine served by Jeffrey?s personal chef. I was a naturally skinny girl, never watching what I ate and to eat that food I might as well have chewed on hay. Istrolled back to Jeffrey?s and was missed. Ghislane scolded me ?You shouldn?t have been gone so long young lady?, ?We need to know where you are at all times, you are on call for Jeffrey? I started to apologize, feeling guilty, I didn?t want them to think I didn?t take my job with them seriously. She cut off my explanation with a short conclusion to this conversation ?We will get you a cell phone tomorrow, so we can always ?nd you?. I thanked her for her generosity, and she dismissed me to my room. So I wasn?t even needed after all, it was just a way for her to place me deeper in their control. The next few days I was on call, as Ghislane said I?d be. Venturing out to the city for only an hour or so at a time, I looked most forward to my outings. I would return to Jeffrey?s 38 [l Copyright Protected Material CONFIDENTIAL l7] Case 18-2868, Document 278, 08/09/2019, 2628230, Page583 of 648 mansion to attend to his sexual desires and when he was ?nished with me, I?d be off to my adventures. On the day before we were to be heading back to Palm Beach, Jeffrey had a new proposition for me. i could make double the money I was making, ifI would look for pretty girls and convince them to come back to Jeffrey?s to be further persuaded with money to engage in bi-sexual and sexual acts with Jeffrey and I. I asked him how does one actually propose such a thing to a complete stranger? ?Well? he said in a build up to another kind of lesson. ?If I were you I would use your charm to entice them and my money to bring them, I would tell them you work for a multi-billionaire who has a taste for young, beautiful girls and with his contacts in the acting, modeling, or rich husband world, your boss could help them, All they have to do is come meet me first.? wasn?t so naive at the time I would?ve seen that?s exactly what he was doing with me, my prospects were massage credentials, but with too much pain from my past, I could only have hope. Not that I was a shy girl, but picking up girls for one reason alone, only to be endorsed for her body, didn?t sound like something I could do. But not wanting to displease my master, I told him that I would give it a go. You could tell he was instantly excited with my agreement, he started to reveal the politics of what kind of girls he was looking for. He wasn?t into multi-cultural girls, a very chauvinistic perception; he said they had to be uniquely gorgeous to be accepted by him, but definitely no African-American girls, he was racist against anything different to his kind, a very narrow minded way of thinking for such a supposed brilliant man. The list went on and on. No girls with tattoo?s or piercing?s, or gothics, no drug users, or prostitutes. Basically he wanted everyone?s daughter that looked like the girl next door, with blue eyes and blonde curly ringlets. Ijust nodded and smiled, wanting this to be over with and move on to another conversation, but so worked up from our previous talk, instead he persisted to show me exactly what I was good for to him. He took me up to the highest loft in his large mansion and he lay down on his large bed, expecting me to know exactly what he wanted done. As always, I complied. Part ofme hating him for having to degrade myself to be so subservient to his sexual whims, and another part of me was telling myselfto be grateful for the opportunities I was being given. The battles in my head were beginning to cause me too much anxiety, when we got back to Palm Beach, I asked my Mom to make me a doctor?s appointment for some headaches I had been getting lately, so she wouldn?t question me. I walked out of the doctor?s with a prescription for a mind-altering anxiety tablet called ?Xanax?, not only did it help with anxiety but it also acted as blanket over terrible memories. So when I had to perfomi degrading acts, I would take a few pills and forget what 39 I. Copyright Protected Material happened within the next hour and be able to become someone without a battling conscious. I spent my sweet 16'h birthday on his island in the Caribbean next to ?St. James Isle? he liked to call it ?Little St. Jest?, his ego was as enormous as his appetite for fomicating. was given a birthday cake and a new collection of designer make-up from London. Ghislane made a joke after I blew out my array of candles and said, ?I?d be soon getting too old for Jeffrey?s taste, and soon they?d have to trade me in.? She was only halfjoking in a sad reality though. A few days after my birthday, a girl was ?ying out to the island to join us for a few days before ?ying back to N.Y.C. I was introduced to a pretty girl a few years my senior, named Sarah. She had long ash blonde hair and big brown eyes that hinted she had a cheeky nature. She had known Jeffrey before I had, and he was supposedly trying to help her get an acting job in LA. She was obviously accustomed to the lifestyle he provided her, making it ever so apparent with her prompt attention she lavished on him. She would do things like strip nude and bathe around the swimming pool, taunting him for sex. She was good at what she did, even putting me at ease with her cool persona and funny jokes. Jeffrey told me privately that she was one of his best at procuring young girls into her entrapment and delivering them to him when he was in town, and when it came to time in the private chambers with Jeffrey, Her and I, it wasn?t hard to comprehend. She was devoted to the moment, giving Jeffrey every imaginable lustful desire he could fathom. On the last night there we all took a trip over to St. James to go for a stroll, odd I thought, it was past 7pm and Jeffrey rarely strayed out past then, unless it was some event or dinner party. While Ghislane and him looked the average couple strolling arm in arm through the streets, he said to Sarah and I, ?Why don?t you two hit the night club here and see if there is anyone interesting to bring back for the evening?? It. was more of an order than a request and then I knew why we came out tonight and why Sarah was invited, tonight was all about training, and Sarah was going to show me the ropes in picking up girls. Although there was no one to accustom to Jeffrey?s distinct taste to bring back, watching Sarah flirt from girl to girl like a ?oating butter?y, gave me enough insight into what I was expected to do. Within Months I had become his handy little helper. Not only would I run to his beckon call, but I also aided Ghislane in bringing in more girls to keep the appetite of our sexually starving chief from going hungry. I once asked Ghislane, why she did what she did for him, instead ofhaving a common monogamous relationship and getting jealous like normal partners would? She replied simply ?It takes the preSSure off me having to do it?. That said it all, we were all under the shade ofJeffrey?s money tree, and not even someone like her could escape from its lure. 40 Copyright Protected Material I73 Just like Ghislane had trained reiterate that onto other girls and thus the cycle of girls trying to climb the chain of hierarchy would start all over each time I brought a new one in, The sessions rarely differed much. They would mostly start out with Jeffrey on top ofthe massage table already naked and me leading a girl into massaging him until his instructions came to remove our clothing and if they agreed to that, then Jeffrey knew he had them in his pocket, and could do what ever else he wanted. He was never tumed down in the many years I stayed with him. Never being shy, he would tell us to start kissing each other or depending on what he wanted we would perform erotic acts sometimes with him fondling us, or just masturbating while he watched. On explicit occasions, sex toys would be used on us girls, making it all the more exciting for him to observe. Ending with a payment of$200 for the new girl and $400 to me for bringing her. He would then wait for us to leave before adding the events details of names and payments in a little black diary he kept with. him wherever he went, so if he were in anyone of the city?s he lived in, he would always have contacts for sex. I was slowly climbing the ladder, as Jeffrey was happy taking me everywhere with him, within the States. Merely at home I distanced myself from my Family altogether and with Jeffrey renting me an apartment in Royal Palm Beach as well as a. plush furnished apartment in NYC, there was hardly a need to see them. [just couldn?t face everyone thinking they all knew what I was really doing travelling around with a man old enough to be my grandfather who supposedly only wanted me for massages. Much further convincing myself ofthe lies I told myself, I- took a liking to theXanax, it felt like it was all a dream at times, even meeting up with old contacts from school years who experimented with drugs. I was flying around the country, seeing so many places in America I had only heard about in Movies and making more money than anyone my age and loving it. My friends didn?t believe the lies I told them about only being a massage therapist, some of them even asking ifthey can meet Jeffrey too. At this point in my life my heart went missing for a while and I stooped so low, I was even bringing my friends, ljust saw them as easy commission. When [wasn?t playing servant to my master, I was partying hard, eventually using ecstasy pills, acid, and marijuana to disillusion the times I would?ve had away from Jeffrey to think about what 1 was actually doing with my life. I realized something one day while I was alone, although I had Jeffrey to attend to sexually, it was not gratifying. I needed someone to come home to, someone I could call my boyfriend and that showed me emotion not just a job to get done. 41 Copyright Protected Material CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page584 of 648 Chapter 7 A knock came to my apartment door one lazy afternoon while we were in Palm Beach. I looked through the peephole and didn?t recognize the once familiar face. I asked from behind the closed door ?Who is it?? The voice of the reply was one I wasn?t anticipating to ever hear again. It was my Junior-High crush and childhood friend, T.J. The last time I saw him i was a runaway and he had let me stay at his house for a few days, telling his parents nothing, he kept me hidden away in his room. At nightfall he said to knock on his window and I could jump through and stay the night. Until I was picked up by authorities during school hours and questioned why I wasn?t in school they did some resourcing finding out I was a runaway, then delivered me back to my angry parents. ?Oh My God- You finally answer your door girl?, and in a whirlwind, T.J stormed back into my life. Even moving into my apartment, secretly, within two weeks of his am'val. He had changed so much from the last time I had seen him. He used to be this hard looking rocker type, now he was cleaned up wearing preppy clothes and shooting out Tupac Lyrics. He had the same old big brown eyes though, and when he told me he had heard I was back in town but he was unable to ever get ahold of me he just kept knocking at my door every so often, I was sold. How sweet I thought, he must care about me ifhe was so intent on approaching me, not even thinking he would?ve spoken to the girls from ourjunior-high circle and they would?ve mentioned him I was back in town, what I was doing and where to find me. We were a drug-induced romance, which budded from fake emotions the affects made us feel. He got what he wanted, a free ride and not having to work, and I got what I deserved, a man who could let me go away with this multi-billionaire I regarded as my second boyfriend. Ididn?t want to alarm Jeffrey in me having a boyfriend so I kept it quiet, until during a massage I was giving to him one afternoon. We were having a conversation about some of my friends, the party girls I had brought in to meet him. Jeffrey started asking questions about the different types of drugs they used hearing them speak abOut it in his presence. I thought a person on drugs would be all strung out and looking like hell, but the girls you know look great? he stated face down during the massage. That?s when I told him I had been dabbling in ecstasy lately too, and i thought it was the most amazing feeling one could even fathom. I tried to describe the euphoric feelings it gave me and even joked with him about wanting to pet anything furry that was around and then there was the constant need to ?ick my tongue-ring around my mouth. It was great 42 l] Copyright Protected Material CONFIDENTIAL GlUl" 1" RliOtL'l I75 Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page585 of 648 having such an open conversation about things Jeffrey had never experienced before and he seemed okay with everything I was telling him as we were having a good laugh together, so I thought I could push it a bit further and tell him the truth about T..T, since it was bound to come out sooner than later I?d rather not the latter, when it would look even worse that I kept the truth from him for so long. ?Well why were opening up about things together?, I continued by saying had met someone from my past and we have been hanging out a lot lately. When I haven?t been travelling with you I have been with him and I was wondering if you minded if I started to see this guy.? He started to laugh out loud, ?Are you serious? Of course not, no one in this world is monogamous, why would I expect you to be?? I was smitten with relief, but a little bit dis-heartened when I heard him speak that way and I wondered to myself if he?d had his own personal encounter with heartache. Of course the evening concluded in the same way it always had, the only reason I was really even there in the ?rst place. Upon his request I straddled him on top of the table and let him explode with pleasure inside of me. Thinking the entire time about T.J, I felt so terrible but I quickly had to wipe the thoughts of guilt from my mind not to give Jeffrey the wrong impression. So I had myself busy with two men in my life, but that?s not what I really wanted for myself. I wanted an occupation that would eventually set me free from depending on a man as my source of survival. I asked Jeffrey before I left for the evening, when my real training was going to begin and he liked my assertiveness. I thought it meant to him that I was taking my job with him seriously, but it was all part of his master plan to keep me by his side. Within a couple of weeks of my persistence, Jeffrey introduced me to a couple of real working massage therapists, not only with credentials but with their own clientele too. I was in awe of their teachings, it all made so much sense about the body and what they were saying. I felt like I had picked myself up out of the lurches and had a direction again. was in the middle of another training session, with Jeffrey the recipient as usual, being it was rare for Ghislane to ask for a massage unless of course it was for Jeffrey?s own pleasure to watch the punch line of the session, when I was shocked to hear Jeffrey ask one of the therapists to now remove her shirt. He had no shame I thought. Even though she was above his usual age criteria, she was still a pretty woman in her early 30?s with curly blonde hair and had an athletic body for a mother of two children. She didn?t hesitate in his request. It looked like something out ofa role-playing porn scene with the therapist removing 43 GIUFFRE004176 her white uniform to reveal her beautiful nude body and a much darker side to her personality. I couldn?t believe it at first it was such a state of shock and I began to question myselfifthis was normal in the massage profession to expect this kind of clientele to request such degrading tasks even though they were professionals. At the end of the session she was paid $300 dollars an additional hundred for helping to train me as well, and I was paid my usual $200 dollars then we were both invited by Jeffrey to join him out by the pool for a cool dip. With Jeffrey making a few phone calls while her and I undressed again for a swim, I wanted to ask her a few personal questions about what she?s come to learn about the Massage Therapy game, but -I never got the chance as we werejoined by Ghislane moments later. She was asking how my training was going and booked the therapist in for herselfin the following morning. Where she was invited back to do another training session with me. It didn?t take me long to ?gure out why. I I was at my apartment when I received a phone call from Jeffrey, I thought it was the usual call to come over to his house, but he surprised me. Instead I would be going to the exclusive hotel in Palm Beach tonight, The Breaker?s, where I would be meeting my ?rst ever clients. Only told their first names I was given some instructions and the address where to meet Glen and Eva. They were a married couple with one on the way. I was quite concerned when I heard she was pregnant, being I really didn?t know the body that well and didn?t want to in?ict any wrong doing on the unborn baby but Jeffrey insisted I take this job. .lust massage her gently where she wants to be rubbed and to save all of my energy for Glen?s massage, since it was going to be a four-hourjob. In an emphasized tone of voice I was being coached by Jeffrey to treat Glen with exactly whatever he wanted,just like I do for Jeffrey himself. It was my last bit of preparation before he sent me out to his friends and my first taste of responsibility in upholding his reputation. At around seven pm I took a taxi to the'address I was given and found them on the residential side of the giant hotel?s extensive property. When I arrived in their apartment it was a far cry from the lavish place I was expecting, still really nice but had a cozier family feel to it. It wasjust beginning to get dark when Eva and I went into the Master Bedroom and she undressed to reveal the ?rst naked pregnant body I had ever seen. It was fascinating to see her in the later stages ofmaternity, and strangely enough it was a miraculous and wondrous sight. She was a former model and one of Jeffrey?s many entourages from his past that had gotten to old for his taste and was married off to a wealthy colleague ofhis. Lying down on the bed I adjusted the pillows to try and make her more comfortable and I began to massage her as Jeffrey had instructed me to, 44 {l Copyright Protected Material CONFIDENTIAL 04 177 Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page586 of 648 softly and slowly. So at ease with her nude body she even asked me to massage her swelling breasts, in a non- sexual way. Not knowing any other way but that way, I was trying to oblige in her request doing the very best I could to relieve her but couldn?t help but giggle to myself at the very sight ofthis. She said she was very happy at the end of the massage and rolled over to go to sleep, asking me to tum out the light at the end ofit. I closed the door gently as if not to disturb her, and went to find my other client. The apartment?s lights had been turned out for the sleeping children and I found Glen awaiting for me in the lounge room where I had to call out ?Excuse me?? as I couldn?t see him in the dark. There was a throw rug on the ground that he had already placed out as he began to strip down in preparation of the massage. Lying frontwards facing me with his exposed and ever growing manhood, I asked him to roll over to begin the massage. He complied with a cheeky smile and from his eagerness to show he was not shy indeed, I already knew where this was going to end up. I found it much more strenuous to massage on the floor but I wouldn?t let that hold me back I wanted to have a career and this being my first ever clients, I didn?t want them to disapprove. Nearly four hours after I had gotten there I was still hard at work. Mentally preparing for the end of the session he let me know when he was ready to begin the other side to my job and just like Jeffrey did the first time, he requested me to take off my clothes starting with my shirt. When I complied, the requests kept coming in and before I could change my mind and run away, I was having intercourse with this man that was so comfortable doing all of this while his pregnant wife and children slept in the room beside us. When he had climaxed, we both got up and dressed and he paid me a large tip even though Jeffrey would be the one to actually pay me for my time spent there. Just like it had all started, it had also ended so quickly and now that was that. I had to accept what my duties were and now I could go back to Jeffrey who would be further pleased in my demonstrations to keep him happy. I was called the next morning to come over to Jeffrey?s mansion that afternoon for lunch, a swim and of course a massage session. Knowing all too well they?d be expecting the gory details of last nights events with my new clientele. I came there at as requested and sat down for a light lunch and a swim. Jeffrey was mostly conducting business from his offside pool office, but he came to ask me if everything went well the night before. I told him I did everything asked of me and I am quite confident both my client?s were more than pleased with me. He gave me a quick grin, before he headed back to the office, throwing a purple grape down his throat as he walked away. 45 GIUFFREOU4 I78 Lying out on one of the pool decks blue and white striped lounge beds I was waiting for Jeffrey to finish his business so I could give him his massage. He never took too long with his work, unless there was something wrong and then we would all have to wear his mood but today he seemed fine though, when we went up the stairs he told me we would be leaving for his ranch in Santa Fe?, New Mexico in the morning and I?d need to be packed and ready tonight. They loved leaving in the spur of the moment, Jeffrey once said he checks with his pilot Larry on the best weather before he heads to a different destination. I enjoyed spending time at his ranch being it was my favorite of all of his residences. He had a lavish Mediterranean looking castle on top of a hill that over looked his extensive 7,500 acres of property. It has an indoor pool, gym, and all the trimmings of extravagance I could only imagine. I had a great time on the quad bikes, Sarah and I often got scolded for tipping one over going to fast or trying to go up a steep hill, but we knew those weren?t the things he cared about, so it wouldn?t matter. My favorite of it all was his little town with it?s own ?re station and truck, stables full of horses, and little cottages where the housekeepers and ranch hands lived. On my own time I would take one ofthe quad bikes down to the stables and saddle up on one of his beautiful horses and go for a ride in the open terrain. It was coming up to the end of a very cold winter and it still had the snow covered mountaintops and brisk air that I loved to take in during my many trail rides. I have been an experienced horse rider since my childhood, and could honestly pinpoint some of the best memories of my life being on the back ofa horse. I acclaimed with thrill in my voice ?Great, I?ll get packed as soon as I get back to my apartment? he threw in ?Pack for a few weeks, as we will also be making a pit stop to LA for some business afterwards and then to I was used to these round trips with him, it was great as was saving loads ofcash and about to buy myself my first car. Jeffrey, Ghislane, Emmy and I all left the following morning, as planned. Arriving in only a few hours at his awe-inspiring Santa Fe Palace was always a delight. Still frisk in the air, my petite frame looked even smaller in these gigantic overcoats. Nonetheless I was looking forward to spending time out in the fresh clean air and open land. After a few days ofleisurely spending our time on the ranch, we went to the Indian markets in Albuquerque for a bit of shopping and sight seeing. Jeffrey wasn?t the most off road kind of guy, so when we went sight seeing it was more like museums, boutique shopping, and local art galleries. Still a splendid trip thOugh. With me picking up a few nifty collectables to bring back for my family and knowing how much my mom loves Indian apparel, I thought it would put me back in her good books for awhile, I hoped at least. There was some time to put a 46 Cepyright Protected Material CONFIDENTIAL I79 fl Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page587 of 648 little water under the bridge between my folks and I. With my life heading in a different direction i didn?t see any use in holding on to so much hate especially that I didn?t even have to see them that much. We got back to ?Zorro Ranch?, the name Jeffrey chose to call the massive land he bought to build his fortress on, and Jeffrey told me that he was looking forward to one of my famous relaxing massages and with that notion he gave my bags of shopping to one ofthe many housemaids who greeted us at the front door and asked her to bring my bags to the exquisite room I was staying in. We headed straight downstairs just past the massage room and there is an indoor heated pool, shower and spa. First Jeffrey wanted to warm up in the spa underneath a decorated ceiling of clouds and blue skies. Starting the massage in the spa I rubbed his feet while he reclined into the spa?sjets. We spoke of the museum and some ofthe knick-knacks I had bought and I thanked him for the turquoise earrings and necklace gift, joking about not ever knowing what to get for him, being that he was richest man I?d ever known. By no far means did we ever have any kind ofa mutual respectful bond between us, but there was a signi?cant softer side he began to share with me that was different from how he treated his other girls. Maybe it was my feet that ?lled the shoes for that time being, or the fact my novelty hadn?t worn off yet, but what ever it was I was getting confused from the double-sided life I was leading. He got up from the spa tub shortly thereafter and asked me to come wash him in the shower. It was nothing unordinary to me, I was used to his need to be nurtured and pampered. I performed his request with a cheerful mannerism, letting him think i was taking care of him out ofmy sheer sweetness. I got the towels ready for him to get out ofthe shower and towel dried him, patting his skin instead of rubbing as previously instructed. ?You know you have a very maternal instinct, you?ll make a fine mother someday?, he would constantly acclaim at my gentleness. hope so? I replied, i. would love to have my own babies one day, but not any time soon?. Laughing at the very thought ofthat. We walked up the steps and through the French doors into the gym?s adjoining massage room. It was smaller room than in his other houses, placing the emphasis on the large massage bed in the center. I grabbed another clean towel to keep him warm while I prepared the music, lights, and oils. He liked me to use mostly lavender or other aromatherapy scents, which reminded me of woodlands in the spring. Always enjoying the beginning of the massage, I put my heart and soul into training in my profession. I could just close my eyes I would see only with my hands the areas that needed the most work, and even though I wasn?t a professional yet, Jeffrey could feel and told me there wasn?t many that could please him during a massage being untrained. I?m sure now it was just 47 GIUFFRE004180 something he?d say nice to all the girls, but in the time I had known him I could honestly say it wasn?t like him to compliment girls in any other way than regards to a sexual performance or their looks. I was flattered at his praise and when the massage was over, so were the sentiments. I was back to being used for my body and what I could do with it. With him satis?ed and off for a nap, I could go do what ever I wanted, like usually I would go down to the stables or something adventurous, but today I was in a melancholy mood, just wanting to relax and unwind myself in a giant tub in my bathroom. I got out some of the oils I used on Jeffrey putting them in the steaming water and popped two of my Xanax pills, forgetting about my troubles and focusing on the quiet moment at hand, just wanting to soak up the peacefulness of it. Nearly slipping away to sleep in the tub, I was startled when I got the call on the intercom to come down for dinner. Everybody seemed in good spirits at dinner, which helped to lift mine. We all ate our meals and went into the movie room to watch a newly released movie. It was a ritualistic scenario, most nights that everyone was at ease we would all sit in one of his various located movie rooms and hang out together. Just as he always would Jeffrey asked Emmy and me to both grab a foot during the movie that night and just keep massaging through the ?lm. We were always on call for duty, no matter where we were or what ever time it was. He would just plop a foot up or pass over his hand at any given time and require a massage, even ifthe film went on for over two hours, i would still be required to sit on the floor rubbing his feet or hands, and even his scalp at times. After the credits had rolled Ghislane got up to close the door to the room and I knew she had received the signals herself and would proceed to manipulate, violate, and use us to satisfy Jeffrey?s urges once more before he went to bed. The blue illumination from the empty TV screen was glaring in the tenebrous room as we watched her undress in a light that relied on the reflection of the moon through the windows peek to show it?s proceeding display. She walked back to the sofa where was sitting at Jeffrey?s feet still rubbing away and uncovered her shirt displaying ample bosoms for his appeal. Approaching me like a lioness hunting her prey she stood me up and led me to the other couch across from Jeffrey and situated herself on top of me, sliding her fingers through my dress to unbutton my attire, revealing my girlish figure and two small peaks. Pushing my head into her breasts I was being fondled by Emmy at the same time, which took her one when she saw Ghislane look in my direction, From an occasional glance upwards, I could see that Jeffrey was up to his methodical foreplay stroking his manhood while watching the build up to his main event. They both took turns making me moan from their touches and when 48 [l Copyright Protected Material CONFIDENTIAL 181 Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page588 of 648 Ghislane was ready too she would insinuate we do the same to her. She urged me downwards, until my head was between her opened legs and giving into her wanton indulgence. Twenty minutes passed before Jeffrey exerted his last energies for the night, the only advantage of being with an old man was they could never last long. Departing to our own separate quarters for the night, I called T.J for condolence. It was so important for me to feel like I had someone out there who saw me as more than a pretty girl with vulnerabilities. I needed to maintain some sort ofa connection to my youthful side. But it would be to no avail as I was getting used to being badly disappointed by all the men in my life. Chapter 8 The phone nearly rang out and as was about to hang up the receiver when he ?nally picked up. On the other end of the phone I could hardly hear T.J above the background noises. When I asked where he was he told me ?At our place baby?, meaning the apartment Jeffrey had rented for me to be staying in alone. He already sounded off his chops elongating his words and slurring his speech. There was music pumping and people shouting behind him and every one sounded like they were having a great time. I was so sick of his friends coming over using my house as a place to party and then trashing it so bad I would even have to sometimes throw my furniture out. I blew up at him over the phone and threatened to kick him out, back to his parent?s house, so much for my relaxing evening I thought to myself venturing on to tell him ?You leech off me using the money I leave behind for you for drugs and throw these gigantic parties while I?m away.? Also mentioning the disastrous messes I would come home too. am so close to ending it with you?, I would openly threaten, but he knew better than I did, that I just couldn?t bring myself to do so, needing some attachment to my youth through all of this. ?Don?t worry baby? he would say attempting to soothe me with his false words going on to tell me how much he was missing me and how he was always thinking about me when I was away which was like all the time. I. would soon be buttered up and soft for serve. This was my penalty for choosing a guy that accepted my lifestyle with my ?Other?Man? as I had so eloquently put it to him once as not only acceptable but deemed it ?Cool?. The conversation ended with an easy good-bye and no ?I-Love- You?s? or anything sweet. We weren?t those kinds of partners yet, so much time spent away from each other and the lifestyles we both led, I couldn?t expect much more from him than what we already had. 49 Jeffrey and I left two days later, heading off to Carmel in California for a business trip ofhis, leaving Ghislane and Emmy to catch a commercial ?ight back to N.Y.C, where we would meet up with them later. When we arrived at the hotel we were given badges for the meeting tomorrow and settled into our rooms. We got adjoining rooms, keeping the doors open at all times, but sleeping in different beds. He liked sleeping alone, even after a late night session I would always go back to my own room. I think that?s why he liked me so much I never put pressure on him to become- intimately more than what we were already, never giving him the impression I wanted more than what we had. It seemed to keep him happyjust the way we were together. I hung out with Jeffrey that night, going to a restaurant for dinner and afterwards watching a movie back at the hotel. The next morning we went for an early morning breakfast before the conference and Jeffrey gave me some money to go shopping instead of attending the all day meeting with him. I was more than obliged to accept his request, and wished him a good day before planning to meet back in the room around six pm. He gave me five hundred dollars. He said it was just enough to go have fun for the day and a girl of my means could find plenty to do with that kind of money. I walked around the many boutiques that lined the streets of the picturesque cozy town, and picked up some bits of clothing here and there and even met a girl who was passing through on a road trip. She was somewhere in her late teens with golden sunshine tresses, olive? skin and blue eyes. Her name escapes me, as it was so unexpected, I think it was Tina or something like that but she was your typical California carefree chic, offering me a few tokes of her jay as we ducked down a side street together. I was so happy I had met this girl, as she was fun spirited and charismatic a. relief from the social expectations I had come to know lately, but always being ?on-call? as I had been trained up to be, I ended up inviting her back to meet Jeffrey at our hotel later on as a surprise for him. Maybe she was just a bit too carefree for Jeffrey?s taste but anyhow she was pretty enough to let him be the judge of that matter. Over the next hour of hanging out together I found out that she was on a road trip with her best friend who was still sleeping offthe hard night of partying from the night before. She was originally from the southern states as she had a bit of draw still left in her accent, and she had recently left her boyfriend because he was leaving for a college too far away not believing in long distance relationships. Then it was my turn to dish out my contribution to the conversation of getting to know each other better. I always got anxiety before I would tell a girl what I did for work and romance (as such), morally l. was ashamed of who I was especially with a girl having led somewhat of a normal life. Next, as always, I expected to 50 l] Copyright Protected Material CONFIDENTIAL [1 Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page589 of 648 be probed with so many more questions and having to make Jeffrey sound ideal and hot for the taste ofa young girl and knew I would be point blank lying, so I told her some of the truth which was that he was really rich and paid good money for a massage and useful to have around as a contact. I told her he?d give her two hundred dollars for a two?hour massage with me leading the way and warning her he was known to be frisky during the session. Unexpectedly she said she could use the money and then came the part that I hated the most, but had to do so they wouldn?t be as shocked as I was the ?rst time I had met him. ?He does like us to be nude though and sometimes asks for more than just the massage itself?. All I could do was wait for a response after a shocking sentence like that, and depending on the girl, most were sadly taken back by the money. Her carefree attitude seemed to disillusion for a moment when she gave it some thought and asked me ?He?s not like, fat and ugly, is he?? No. . .no. . .not at all? I replied, ?He?s got more ofa Richard Gere appeal to him?. Trying to make him sound a little more measurable than just a rich old man that likes to be with girls younger than half his age. ?Well then, what time shall we meet tonight?? She asked next. Great, I thought, Jeffrey would be most pleased with my find. ?Knock on my room quietly, you?re going to be a surprise. Be there at around half past seven tonight and I will introduce you to Jeffrey?. She threw the butt of the secondjay we shared in the bushes and we strolled into a homemade fudge boutique to get some relief for the munchies we now had. When I got back to the hotel at around a quarter to six o?clock pm as requested l?d be, nobody was back yet, so I took the time to set up the oils and bath in my room for his massage tonight. I thought Iwould plan it so the girl would be cleaning off, as Jeffrey liked before he had sexual contact with a new girl and he could walk in and be surprised to ?nd a strange beautiful girl in my room who wanted to massage him. Jeffrey walked through the door not long after I was done prepping for the night ahead, looking like he had a rough day at'the office, which was very rare for him. He sat down on the bed and I asked him how his day was. He didn?t want to talk much about it, saying it was boring and long, rather asking what I got up to for the day. Being coy about having ajay and his unexpected surprise to come, I told him it was a great day of shopping and sight seeing and I even brought him back some local made fudge from the shop that had ful?lled my chocolate cravings only hours ago. Telling him ofthe places I ventured into Imentioned to him ?We?d have to hit the ?sherman?s wharf tomorrow. I saw some locals walking around with breadbaskets filled with creamy clam chowder and it smelled absolutely scrumptious.? He said ifthe weather were nice we?d check it out tomorrow before we left for LA. He wanted to take off his jeans and 51 GIUFFRE004 84 collared shirt and put on his normal attire of sweatpants and a sweatshirt. Ushering him out the door for dinner when he was more relaxed I was lucky when he said he was starving and quickly got dressed. Wejust found a quite spot to eat that was next to the wharfand got back to the hotel just in time for our surprise guest. He wanted to go have a shower and settle down for a massage, so I told him I?d join him in a minute, I just had to make a phone call real quick which he thought was odd and asked me if everything was alright, I reinstated that I?djust be a minute, trying not to let on about anything. The knock came quietly on my room?s door just on time, as we had planned and I told her my idea to surprise him. I let her into the bathroom where she orchestrated my plan perfectly. Jeffrey ?nished his shower without me and when he called out for me I told him that I needed him to have a look at something in my room real quick. Not giving in to what it was that he would be looking at, he came into the room where I opened my bathroom door to reveal a beautiful nude girl bathing in a thick amount of soap bubbles in my tub looking at him with an alluring intrigue. His grin went from ear to ear when she stood up and introduced herselfletting the bubbles run down her glistening body at an ever-slow pace. It was a proud moment for Jeffrey, I had done well in his eyes, and she was not like the other girls I had brought to him before, degraded from a lifetime of abuse off the streets. This girl was exactly his pro quo looking sweet and innocent as the girl next door. My efforts were to show him I knew that my only responsibility was to keep him happy at all costs. I led her through the massage on Jeffrey and of course afterwards gratifying his perversion with his lustful requests to be fondled and watch us become more than just friends. I didn?t feel too bad at the time with his coercion providing many ?nancial rewards making his scheme enticing to a young, impressionable teen not realizing the terrible memories left to come from all of this. Afterwards he paid her the usual two hundred dollars he gave to everyone for their time and took down her name and phone number writing it in his infamous little black book of the contacts he met in every city but only the ones he really liked made it down in his records. We went out the next afternoon as I had suggested last night and we ate our clam chowder breadbaskets over looking the whart?s bay, watching the seals playfully barking at each other on the rocks nearby. Shortly after we were driven to the private airstrip and took off for Los Angeles. 0n the plane was an unexpected visitor. Matt Groening the producer of the ?The Simpson?s? TV show was catching a ride with us. I was so excited, as I loved watching his show and acted like a star struck fan, asking him everything from his initial idea for creating the show to where he got his characters from. He told me it was all based on his own family make up, 52 Copyright Protected Material CONFIDENTIAL 185 Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page590 of 648 but without the crazy father and son scenes of Homers hand around Bart?s throat. I was enjoying our conversation, when Jeffrey insisted that I give Matt a foot massage throughout the duration of the short ?ight. I never turned down a client but when I saw the shape ofhis feet, I nearly threw up at the thought of having to touch them. He had yellow crusty toenails that even someone with a chainsaw would?ve had troubles cutting through and then there was the ?uffy balls of leftover pieces of sock wedged between the crevices of his sweaty toes, now that was the real icing on the cake for me, no way could I attempt this I thought. Then I had an idea. I went to the back of the plane and rinsed a wash cloth in warm soapy water and returned for his dreaded foot massage but not before attempting to clean them first. In return for my services Matt was kind enough to draw me two quick sketches on blank paper from his briefcase of my two favorite characters, Homer and Bart. I asked if he wouid make them out to my little brother and dad, the true fans of the family not missing an episode during dinner over the past ten years or so. Next to the A-4 size drawing he was able to fit in the quote ?To my greatest fan from Matt Groening? and their names next to it. I knew they?d absolutely love it, and it was such a nice gesture his feet were no longer an issue as I laughed it off and even made a joke to the comedian about getting a pedicure before hitting beaches. The ?ight was only short and we arrived in busy L.A within the hour, saying Good-Bye to Matt, who was a pleasure to meet. Jeffrey had a meeting at a production studio for one ofthe girls he was keeping lured in his grasps, so we were off yet again for more business. We were staying with one of his old girlfriends, Jeffrey?s code for ?She got to old for my taste, but was still nice enough to keep around?. She was a tall blonde with blue eyes, a stereotypical Barbie doll. In her younger years she had been a successful model and now lived on the beaches of Santa Monica with a sweeping view of the oceans landscape as her backyard. The next morning Jeffrey and I went out to breakfast. He said Sarah Keller, would bejoining us with another one of Jeffrey?s girls I hadn?t met yet, her name was'Nadia Bjorlin and she was a Yugoslavian model turned aSpiring actress, with the help of Jeffrey, as he so proudly remarked at the table before they arrived shortly thereafter. She was a stunning brunette with olive skin tones and shocking blue eyes. By far one of the most beautiful girls I had ever met before. She and Sarah approached the table, shopping bags in hands already in the early hours of the day. They both pulled out a chair and showed us their new pair of Jimmy Choo?s they had bought on their way here this morning, and excitedly asked for Jeffrey?s opinion. He loved the doting attention and anyone who could make him feel important. We all went back to Sarah?s 53 GIUFFRE004 186 apartment that Jeffrey rented for her on Malibu Beach. This was the ?rst time Jeffrey came to visit and when we got there you could see why. it was a tiny one-bedroom shack, too small for his likes of accommodation, but she loved it and it was plain to see why, the waves lapped underneath her porch twice a day, what else could anyone want. Before even walking through her door, you could hear the commotion of excitedly screaming females voices coming from inside. There were about five other girls in Sarah?s living room and she had invited them so Jeffrey could have a few different girls to choose from. Jeffrey looked at Sarah and smiled, aren?t you sweet, as all the girls rushed to introduce themselves, hoping for the opportunities Sarah had offered them to come in the first place. We all had some coffee and biscuits while the conversation kept getting louder and louder, every girl trying to talk over the next one. Jeffrey could handle only so much ofthat before getting too annoyed. Instead of choosing one of the other new girls, Jeffrey wanted Sarah to show Nadia and I into her bedroom. He was anticipating the introduction of his two favorite girls together, what mischief he had hoped we would get up to was apparent when he asked where Sarah had kept her play toys and not the fisher price ones. Sarah brought out quite a collection of her personal toys and was giggling on her way out as she shut the door. Suddenly the room behind us went quiet, probably hoping to catch a moan or groans too laugh at and I felt so degraded having everyone knowing exactly what was going on. Knowing my duties well I was baf?ed this time as there was no ritualistic massage wanted. He immediately instructed us to start kissing and fondling each other with the provided toys straight away seeing his excitement grow watching us try and out do the other one with pleasure, he couldn?t keep restraint any longer and started to have intercourse with the both of us, taking his erect penis out of the other to only swap to the other girl, back and forth. This continued for a good fifteen minutes or so while we continued to engage in lesbian acts on each other while the other girl was being subdued by Jeffrey?s thrust?s of penetration. Nadia wasjust as dutiful as Iwas in fulfilling his demented requests, willing to lend her body to Jeffrey and those he sent her too, for the sake of keeping her acting career and putting on a good act at that. She was never competition though. Once I found out where she actually came from I took pity on her for the similar life of servitude we were both accustomed too and not that we ever became good friends but we had . reason to relate to each other. Later on Jeffrey,_Nadia and I went to a production studio in LA, where we had to meet with Nadia?s agent as well as the producer of?Day?s Of Our Lives?. The meeting lasted five minutes, with everyone in consent to the proposal. We ?ew all the way out there to talk about money, only to be leaving that evening back to NYC. On the way to the airport we 54- Copyright Protected Material CONFIDENTIAL 187 l'i Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page591 of 648 stopped at a ?fties looking diner and got a cheeseburger and vanilla milkshake, the ?rst and only time 1 saw Jeffrey eat what I considered to be real food. Seven lanes to drive in and the freeway was still lined bumper to bumper in the heavy rain. The sound of downpour on the rooftop of the taxi and the ofthe windshield wipers was making me sleepy. I was looking forward to sleeping through the long ?ight back. Thank goodness we had a private jet to catch back, the trip would be comfortable and not rushed to get there on time through the daily peak hour traf?c. Jeffrey asked me what I thought of Nadia, more of a kiss and tell kind of thing for him, so proud to admit some of his tenacious acts of pedophilia to me that I knew most people would be embarrassed to even think aloud but I said what he wanted to hear when he asked me what I had thought of her on the way back. I replied, ?She is attractive, funny, and seems to kn0w what she is doing with you.? Laughing at my statement, he then started to tell me the history behind where he got her. Five years ago when she was merely a teenager just tumed thirteen. Her father had recently passed away, leaving Nadia?s mother in a tremendous amount of debt and living in a third world country, she didn?t have the means necessary to raise her own daughter. When Ghislane approached Nadia for the first time at a music school, she seemed like a maternal, caring stepmother. Telling Nadia?s mother if she let Nadia go with her, she would se to it personally that Nadia receive the best education and chances in life to make it. in her customs it wasn?t odd for a young girl to be married off to bring the family good fortune, so she kissed her baby girl good-bye and sent her off to commence her life of servitude. I sat there speechless listening to Jeffrey brag about his endeavor to get her over here, shocked that he could stoop as low to use a barely teen to oblige his sexual desires. He was laughing and giddy as he replayed the memories of her arrival over in his head, painting me a horri?c picture I had no choice but to imitate a smile to face him with. No pretty girl is safe from the allurement of these villains procuring the youth off of every street in the world. I knew that day more than ever before those morals did not exist for people like this. Jeffrey once told me that every girl he has had sexual relations with has benefited in their career, finances, or an achievement in marriage with a successful colleague of his. Mine was the massage career, ever so often still giving me a lesson from a professional, which kept me quiet for a while longer. I thought I was already knee deep in this world, if I gave up after putting myself through all of this hell it would?ve all been be for nothing. So I treaded constantly at a risk of being replaced by another willing participant and playing the eager student he wanted me to be. 55 188 Chapter 9 We met Ghislane and Emmy in NYC, and it wasn?t a blissful reunion as I hoped for, wanting a break from all of this I wasjust looking forward to getting back to Palm Beach, not leaving for a further four more days. I got home late in the evening as Jeffrey invited me out to the movies after we had relaxed at his house for a while after landing. I put my keys through the door to my apartment and walked in to a quiet house. Not thinking anyone was at home I set my suitcase on the floor and put my cellphone on charge as I always did to be accessible for whenever Jeffrey or Ghislane could call. I went to get a drink out ofthe fridge when I heard some noises coming from the back of my apartment where my bedroom was. I started back there and slowly turned my doorknob to reveal T.J On top of another girl. When they noticed they weren?t alone anymore, T.J got off her with promptness. recognized the girl from seeing her around at parties, and she was the town lowie, scattering her trail of guys along with her presumable diseases, and I wasn?t shy to verbalize that when she tried to open her mouth and calm the heated situation between T.J and I. She didn?t like her cards on the table in front ofthe guy she was screwing arOund with and got up in a ?t of rage to attack me. Still nude with only my new white sheets to cover her body, 1 threw her out of my house along with T.J. have been paying your way for months, only ?nding out your sleeping with the biggest slut in Royal Palm Beach, at least have some dignity and higher your standards.? I didn?t really have a leg to stand on since I had started this relationship giving him the knowledge I had a sugar daddy to answer to above him. ?You?re gone all the time and with that old man, what did you expect me to do?? He was right, I wanted what 1 couldn?t have, but I needed some time to cool down and accept my situation. 1 loved having T.J around to come home too, and he used to be my best friend in my school days. I convinced myself ofthe lies 1 continued to accept. Days later I was still not speaking with T.J, mentally adjusting to my circumstances, I thought I?d have the day off to relax since I hadn?t been called all day. Until about ?ve pm when Ghislane called and said Jeffrey would like a massage in an hour. Grudgingly I got up from relaxing on the couch, got dressed and put my make-up on, meeting Juan downstairs a half an hour later. Jeffrey was already lying on the massage table when walked in, I started the massage being very quiet from my somber mood, when Jeffrey picked up on it and said ?you know it?s not good to massage people when you?re angry, you could pass on negative energy?. I wasn?t sure if he was serious orjust trying to be nice so I could speak about what was bothering me. Ending up not being able to contain my 56 l3 Copyright Protected Material 18!) [3 Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page592 of 648 emotion any further I told him what happened with T.J and broke down in tears, a little heart broken from living in such a lie. He tumed around from his massage and sincerely paused for a second thinking he was going to console me but instead he laughed at the very prospect ofmy notion that monogamous relationships ever existed. ?Are you serious, he was only doing what every guy in the world does, you can?t hold that against him?. I replied in a lighthearted gesture ?whose side are you on anyways?? His answer stuck with me for many years to come ?I?m on your side which is why I?m going to save you a lot of grief with this one tip, Never expect a man to be faithful and you?ll never be let down, it?s just the way us men are genetically imprinted.? The remainder of the massage I had to pretend like 1 wasn?t further saddened by his response, but in fact having to act enlightened. I would never come to him for any other relationship advice, ever again. He told me I?d be ?ne iijust listened to my mentor. He still loved role-playing the teacher and me the pupil, like the old days before he got rich and only used to be a college professor. I ?nished the massage and ful?lled my sexual duties before being sent home wanting to collapse in anguish. T.J was outside my apartment door when I got there, his mom waiting downstairs in her minivan just in case I kicked him out again. He pleaded his guilt and promised that he would never see her again, agreeing with me that she was the town slut and he screwed up big time. I let him back into my apartment and back into my life for that matter but more aware of the world I was being led into believing was of normal conduct accepted by everyone in this sick world. Jeffrey was going back to N.Y.C and told me to have a few days off before his assistant at his office would arrange an E-Ticket on a commercial ?ight for me to join him later in the week. I hadjust made loads of money from my previous trip and wanted to relax like any teenager does, so I threw a hotel party that weekend on Singer Island in Rivera Beach, inviting only a small group of friends to begin with. The hotel room quickly ?lled up with a flood of teens and the pumping music was blaring. The room had a. balcony overlooking the pool and the beach that became the smoker?s section. I wasn?t a real smoker at that point, preferring to have a puff of a spiffed blunt instead so I made it my rule to go outside trying to prevent holes in the carpet, but it didn?t last too long when our forbidden walls came tumbling down. Making so much money that I could supply my wild parties with an assortment of drugs like trips, ecstasy, and coke as well as an abundance of alcohol, that T.J had all the contacts for, made my fellow teens admire me. It de?nitely gave me a head swell, thinking here I was so young but so grown up already with all ofmy peers from high school looking up to me. 1n the wee hours of the morning we were all still going hard with our eyes 57 190 dilated into little black diamonds. We were all having in depth conversations about life and where we would all end up when this charade was all said done. Nobody got to sleep that night as the room slowly dwindled in numbers as people were finding their way home to recover from the repercussions of drugs wearing down out of their intoxicated system. When I?ew out to N.Y.C to meet Jeffrey the next day, I was still in a horrible state. Not knowing what was wrong with me, thinking it was just a bad come down, I rushed out of the elevator and down the hall to my room, sweating profusely, to'make itjust in time to the toilet to throw up bile again for the uncountable time since getting off the plane. I was having intense cramps in my stomach and when I was called down to meet Jeffrey in the massage room, I had to decline for the ?rst time. I told the housekeeper that I was feeling very ill after the ?ight, maybe some off food for lunch and needed to lie down for a while. Nobody came up to check on me for hours or even called. Waking up from my much?needed nap, I pulled back the expensive white sheets to ?nd myselfin a pool of my own sweat and blood. I was covered in the red stains that drenched the pants I was wearing. I had no idea what was going on, I could only focus on the dire amount of pain I was in. In between the heaves of throwing up and crying simultaneously 1 was able to reach the phone and called the housemaid on the intercom. I told her I needed to go to a hospital immediately and slammed the phone down only to fall back to the floor hurdled in a ball. She didn?t hesitate in calling Ghislane who ran up to see what was wrong. Ghislane then called Jeffrey who was in his office at the time and told him to hurry up to my level, stressing to him that it was an emergency. Thinking they really cared about me for the first time since I had known them, they came with me to the hospital with me. Now I realize I was only a liability in getting them caught and they needed to get to the doctors before I could say anything incriminating. They were suspecting the worst now and seeing he never were a condom with me and from our previous conversations they knew I always made T.J wear one, they feared the situation at hand. When he saw the catastrophic state I was in at that point, it was the housemaid who helped me get up and assisted me down to the car where Jo-Jo was waiting for me. He drove us to either Lennox Hill Hospital or Mount Sinai, I can?t remember, as it was so blurry in such a bad condition. Rushed in for immediate testing Iwas uncontrollably vomiting and in so much agony, I was given an injection to help me to subside the intense pain. A nurse came in to ask who would pay for this and although I insisted my parents insurance still covered me, Jeffrey persisted that he take care of all the medical bills and gave the nurse his information. 58 Copyright Protected Material CONFIDENTIAL lUl Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page593 of 648 When the pain relief kicked in, everything and everyone dwindled away until I felt like Alice in Wonderland whojust swallowed the shrinking tablet and everyone standing around me seemed to move so quick, speak so loud and hover above me. When I awoke from my induced state, I was alone in a different room. Not knowing at all what went on but feeling a little better, I called in the nurse who looked through my charts and checked my vital signs. Then told me the doctor would be in shortly to inform me ofthe conclusion to my illness. He was a tall man with dark hair, and a hardened look about him obviously from his job and constantly seeing the worst horror stories man could think of, hejust bluntly told me I had miscarried in early stages of pregnancy. I should be fine to go home as soon as my course of intravenous antibiotics was complete. The news sunk in fast and hit a deep nerve. I waited for the doctor to close the curtain before I let out any emotion and cried for my disastrous lifestyle that was dragging me into a world that I wanted to break out of. This reoccurring cycle ofbelieving I needed men like Jeffrey to succeed in my life was draining the last bits of sensitivity left in my heart. I was picked up by Jeffrey himselfwho took the doctor alone to the side ofthe busy hallway to have a private conversation about something. Jeffrey wasn?t comforting at all, instead he sent me back home to rest for a couple weeks, and I only fell deeper into a depression, using all forms of self medication to treat my sorrows. Two weeks later, as ifJeffrey was trying to lighten my spirits, he told me I would be going to his island to meet a new client He is a Harvard Professor, named Stephen I would be spending two days with him showing him around the island, dining with him, and treating him to a massage whenever he wanted. Without Jeffrey even verbalizing the need to have sex with him, he told me to keep him happy like I had my first client. I packed my suitcase with island apparel, and kissed T.J good- bye, who had at least offered me a warm embrace upon the news of my miscarriage but none other than that knowing it wasn?t his. Stephen was a quirky little man with white hair and a mad scientist look about him. We arrived separately and greeted him when one ofthe housekeepers picked him up from the airport and arrived by boat, instead of helicopter as Jeffrey and Ghislane often arrive on. We made our acquaintances and he looked as if he was tripping over himselfwith words, obviously delighted with his company and location for the weekend. I showed him around as Jeffrey had asked and took him on an adventurous quad bike ride around the small curvy paths, leading the way and letting loose my hair, doing something that gave me a natural high instead of the prescription one. The sights alone were breathtaking from the mountainous peaks ofthe untouched parts ofthe island, we sat at a cliff andjust sat there, not saying a word to each other besides to 59 GIUFFRE004192 compliment the sights mother nature that appealed to us. I didn?t feel as if I owed this stranger anything but what was expected of me by Jeffrey and I could be polite, [just couldn?t be myself. We got back to the main villa to see what time dinner would be served so we could have time to unpack and clean up beforehand. We both met at six pm for dinner on the outside veranda. He sat at the head ofthe table and I sat next to him, politely folding my napkin to put in my lap. The first time Jeffrey and Ghislane had seen me cut meat and eat with a fork and knife they were so appalled, making fun ofmy unsophisticated habits. Ghislane took the fork and knife in her hands and proceeded to show me how to politely cut my food and eat. Now that my mannerisms had improved they wouldn?t have to be worried about my etiquette when someone important was around anyone. We both drank the red wine supplied on the table and it seemed to wami me up on the breezy night By the time dinner was served and another red wine bottle later, he seemed to get funnier. I made fun of his tousled hair and he poked at me for my skinny legs, calling me a wanna be? anorexic. When dessert was brought out, he asked if he could receive one ofthe delightful massages he has been hearing about from Jeffrey. I gulped more red wine down and sweetly complied with his offer, dreading the moment I?d have to see his naked body, let alone touch it. I asked the housekeeper Kathy that had been serving us that night to please have someone set up a massage bed in one ofthe cabana?s. I went to my room to down a few Xanax, telling him I wanted to freshen up after dinner but to meet me in his cabana in twenty minutes or so. I was ready to go as I had said, twenty minutes later, with the effects ofthe tablets mixed with the red wine, and I would be free not to feel anything. He was still dressed when I got in the cabana, obviously not accustomed to this and a lot shyer than what I had been used to, I told him he?d need to undress and lie face down on the table, putting a towel to cover his bare bottom to prevent him feeling embarrassed during the massage. I gave the massage my earnest as I always had, and quickly got through having intercourse with him. Not wanting to make any foreplay or anything extravagant out of it, I let him think that?s as good as it got, and by the smile on his face, I thought I had done enough. The next day I took him down to the beach for a real massage under a tiki-hut on the waters edge. It was one of Jeffrey?s favorite places to have a massage, as he droned out to the sound ofthe waves and my gentle therapeutic strokes. Afterwards we had lunch back at the main villa and went back down to the beach to swim out to the water trampoline about one hundred meters off the dock. He didn?t do any bouncing around or anything like that. It was just a good base point for a rest spot after a long 60 Material CONFIDENTIAL 193 1] Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page594 of 648 swim. What was really cool about it though, was you could see through the mesh and watch fish swimming underneath. The rest of the afternoon we spent by the pool reading magazines and eating fruit plates. Eventually he went to his cabana to have a nap later on. That night after dinner and my mixed cocktail of Xanax and red wine, I asked if he?d like another massage before I went to bed. He just wanted to stay up watching movies in Jeffrey?s theatre room. As peculiar as that request was to me I didn?t argue it, Ijust hoped I hadn?t disappointed him in any way that could make it back to Jeffrey. I showed him how to use the remote and turn off the T.V when he was finished before going to bed. The next morning we were both catching a ?ight from St. Thomas and we had no time for anything other than breakfast and packing, which saved me from having to be too polite as we said our good?bye?s from the terminal in the airport, both hurriedly offin separate directions, thankfully. I arrived back in Palm Beach, only to be told to catch another ?ight the next day to NYC, where Jeffrey would fix me up the money he owed me for treating his colleague out to an entertaining weekend. Chapter 10 was fixed up more than whatI had usually made for two days, which was great because that car I had been saving for was finally within my reach. 1 had been waiting for the freedom a car gives every teenager for a long time, and now that I had over fifteen thousand dollars saved up I could pretty much afford to go buy myself a nice car outright. Looking much better than the last time I saw him Jeffrey acknowledged it. I went to his of?ce where he was waiting for me and he had a guest with him. She was unusual looking to the common stereotype drop dead gorgeous girls Jeffrey had normally introduced me to. Of Asian decent, her name was Rena. Jeffrey had met her at an art gallery where some of her own artwork was on display. She had a bubbly persona about her and I could then understand why Jeffrey liked her so much, she fit into the subservient category that he liked his girls to fall under. It was apparent to me that they had already slept together in the short time span they had met, as there closeness was oddly noticeable and I wondered what it was he was offering to her in exchange for her body. I found out later from Jeffrey that he was buying her artwork, promising her the world as an artist, telling her he?d have her work in the all the museums in NYC and the best art exhibits. Everyone was promised something, and seemed to be bought off in someway or another to be in his company. It was only a matter of time that the truth would come out. 61 GIUFFREOCM 194 To my own amazement Rena was to be assisting me in Jeffrey?s massage this day, not being a total knockout or anything spectacular, looks wise that is, but for some reason he seemed intrigued enough. As we made our way through his spectacular mansion she was in total awe at every corner. Commenting on the present artwork and decor that we passed in every hall, it no longer seemed so grandeur to me anymore but hearing someone else speak about it in such excitement reminded me of the days when all ofthis seemed so unforeseen. When we got to the massage room, or ?The Dungeon? as I used to put it for it?s medieval looking appearance, we out of custom all had a steam shower, where Jeffrey expected me to walk her through a servants duties, telling her to take his other foot and start rubbing in small circles and stroking the arches ofhis foot Rena took the instructions well and began to massage him too. When we all went to the shower next and she followed in my exact lead washing his body as well, Jeffrey absolutely loved the fact that two teenage girls were dually pampering him. Jeffrey wanted to move to the massage bed and 1 had to further begin to show her about the body, upon his accord. She mimicked my every move up his legs and buttocks, keeping up with every stroke until he could not contain his arousal any longer and was already requesting us to start kissing each other, the start of the very reason we had even met in the first place. He blatantly stopped the massage nowhere near being complete and turned over to announce his increased arousal in a physical abundance of grotesqueness. Moving over to the small couch in the corner of the room he made a space for her to lye me down on the massage table as she had commanded him to do in such a domineering tone that he wasn?t used to being spoken down to with. From that very moment onwards and from the look on his face he was yearning for her to orchestrate an hour of deliverance upon my meek nature. He started to stroke his erect manhood as he was being tantalized watching her take over every inch of my body in a dominating act of seduction. I was left breathless and soar after my first introduction into the world of Rena considered herselfa dominatrix, she loved bondage, whipping hitting, and eventually cutting her sex partner with little sharp knives until they subdued to her punishment in agonizing pain. She was absolutely crazy if you were to ask me, and I couldn?t help but wonder what got her into this in the first place. All I knew was that Jeffrey was absurdly taking into the appeal of watching us two interact, often with her acting as my mistress who would fondle me with an insurmountable amount of whips and toys. Then she would love to finish off every session by hitting me across my face with a hard blow from the back of her hand and sneering over my curled up body showing Jeffrey her ability 62 Copyright Protected Material CONFIDENTIAL GlUliliREOU-l- 195 Copyright Protected. Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page595 of 648 to make others surrender to her extreme force. She could be so Opposite all of the sudden and be tenderly intimate with Jeffrey stroking his penis lovingly and even speaking in baby talk to him, which he seemed to adore. He loved us pairing up so much that within months he made Rena an official even renting her an apartment at the same place he had one for me during my extensive trips out to N.Y.C. Sending us out shopping together at all of the underground seedy sex stores downtown we would bring him back thousands of dollars worth of sexy outfits, sex toys and bondage material. His favorite one was a black leather studded collar that lead down the back of my spine to cuff my hands and feet together, offering Rena the most compromising positions to wield her af?ictions, one she was excited to pick out for my usage. She was good at eradicating my softer side though. Helping me forge an unpredictable scenario of me turning the tables on her, making her at my will instead of me always being at her twisted discretion. Jeffrey loved the rivalry between us, both striving to dominate the other one but to me it was just another way of surviving her punishment. All for show I thought she was a madman let loose in a torturesome domain of violent sex and unbearable beatings. I wasn?t sure how long I could hold off this charade of M, I just didn?t want Jeffrey to think I couldn?t give him everything that she could, always being replaceable in his company. She and I could often come across as good friends to his blind but it was only a matter of time before the animosity inside of me was going to snap. Doing normal things too made it all half bearable. Having a lot of similar interests we did fun things like go to the theatre to watch ?Phantom of the Opera? or visit several historical and art museums together, afterwards treating ourselves for a giant piece of greasy N.Y.C style pizza. Like I said, we really liked each other purely as friends but the dominance in the massage chambers was taking it?s toll on our strange friendship. One average trip back to NYC, she surprised Jeffrey with a six foot by six-foot oil painting of her and I lying nude in a ying and yang position facing each other. Although we were soliciting each other with sexual innuendo the picture was still very carefully orchestrated to perfectly portray the darker side of Jeffrey?s thrills. It was an amazing piece of work, besides the iewdness of it, but she would?ve known that?s exactly what kind of art Jeffrey liked. He was so astounded by her gift as he had previously asked her to construct a small painting of us together but was not expecting anything of this grand magnitude she had presented him with. He lifted her from the ground and twirled her around before he thanked her profusely and embellished her with his profound gratitude, the only thing Jeffrey had to offer, he handed her a small wad of cash as her payment. It was the most appreciation I had ever 63 GIUFFRE004196 seen him show a girl. Obviously moved by her gesture, he got her an exhibit in ?Metropolitan Museum of Art? where she submitted her very own piece. She sculpted an image ofmy headshot out of clay, shaping it with the strands of my long hair blowing across my face. I was taken aback myself at her creation. She really did have an amazing talent if not for l?lnr meannr china]: s?nn hop-n (rt-pat Fripnrl I ?Jill pgxy?gr an an.? uuvun uy vvuunu vu Uuull b?vuL . forget Rena, for all of the ups and the downs we endured together. It wasn?t too much longer before I finally had enough ofthe abuse in the bedroom and I had to tell Jeffrey what I was feeling. She was getting even more violent as time went on, and with her questioning me and Jeffrey why she didn?t get brought on long trips with him, she didn?t get the fact that she was just a tool for him to use. Jeffrey said he was already thinking about getting rid of her off of his ?regular list?. He said she was becoming too clingy and he didn?t like clinginess or jealousy. I never even got to say good-bye or take the opportunity to keep her as a friend, like a girlfriend to catch up with once and awhile, but that?s how it was with Jeffrey, one day you sat under the blanket of his comfortably and the next without any warning you could be discarded like yesterdays news. She would?ve taken it hard but that?s the game we were playing and it was for those who knew what lines not to cross. I was further surprised the next day when Jeffrey gave me a thousand dollars to go shopping in downtown Manhattan to find a classy dress, on top of being sent to the exclusive beauty salon of celebrity stylist ?Frederic Fekkai? for a new look. It was amazing, to be pampered like royalty. I-walked out ofthere feeling like I had replaced a young girl with a young woman, I felt beautiful. He had yet another surprise in store for me. Ghislane called me and told me I need to go to a photo-developing store and ask them for two I.D photos then bring them downtown to Jeffrey?s Manhattan office. Weird request I thought. I was more used to posing in full body shots being sexually exposed as a gift for Jeffrey. I did as they asked and took my two photos into the of?ce where Jeffrey?s assistant was waiting for my arrival. Still not telling me what the .headshots were for, she took them from me and told me to have a seat for a second. A moment later I heard Jeffrey call me into the office. like what you?ve done with your hair, you?ve gone more blonde, suits your glowing tan?. I replied with an appreciative ?thank-you? for sending me to such a renowned and shopping money. I showed him my finds for the day, an elegant off the shoulder navy blue dress that had two layers that would swoosh and sway with my every stride. I couldn?t wait to wear it on a special occasion, and I wouldn?t have to. The pictures I had to bring to him, as he would proceed to tell me, were for my first passport. I was so excited, we were going to France for a close friend of Jeffrey and Ghislane?s birthday party, famed super-model Naomi 64 Li Copyright Protected Material CONFIDENTIAL I97 Copyright Protected. Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page596 of 648 Campbell. I was so over-joyed with excitement, what girl my age with a background like mine was attending socialite parties and globetrotting the world. It only made it harder for me to see beyond the elusive walls I had- put up to protect myself from the appalling truth. We left in early April ?rst going to London, Paris and then our final destination being St. Tropez in Southern France. If Hallmark had a postcard, St. Tropez would de?nitely be on the front of it. It was beautiful spring weather and every where you looked women were dressed in bikini tops branded with some kind of designer label embedded into it and the men were following them around like harping dogs in heat. In all of the elegance of the Mediterranean, ?La Bastide De St. Tropez? was an impressive landmark. Jeffrey and Ghislane were staying in one of the private cottages, on the park on the grounds, while Emmy and I stayed in separate quarters inside the hotel. The old style cobblestone streets were lined with boutique shops and beauty parlors. It was the hedonistic stomping grounds ofthe beyond rich and famous. The next day we went out to lunch at the grand opening ofthe infamous Nikki Beach Club, where a cheap glass of champagne costs around two hundred dollars and if your not keeping the alcohol consumption flowing like water, you?d be asked to leave to make way for the constant ?ow of prospectus patrons. That?s where I first got to meet Naomi Campbell. She was wearing the typical attire strutting around southern France, a bikini top and a wrap around mini skirt to go over the swimsuits bikini. She was so tall and stunningly beautiful. Her charisma was energetic, funny, and everyone seemed to hang off of her every word and laugh at her every joke. Ghislane and Jeffrey kissed her cheeks and wished her a happy birthday, and then I was introduced and followed in their suit. She was surrounded by a league of assistants, friends and fans, which didn?t make it easy for us to all converse but she got enough time in to invite us abroad a yacht ofa fellow she was ?kind of seeing? at the time for the before party ahead of tonight?s event. We went back to the hotel and I gave Jeffrey a massage in his room before we all headed down to the pool to soak in some of the year?s first sun?s rays. I loved wearing my new ball gown and feeling like a princess. It was absolutely sensational and made me feel as if I floated in the dress. I swept up my long hair in a twisted clip, only letting down a few curly strands and layered on the mascara. Receiving many compliments throughout the evening when we eventually left the Yacht to make our appearance at the main birthday bash, I couldn?t help but feel excitement for the party to come it was the first celebrity birthday bash 1 had ever been to. Being introduced to model after model and the rich men that followed them around became dizzying. Jeffrey sat back and watched as I buoyantly worked the dance ?oor, coming back to the table where he 65 198 was, only to grab another glass of champagne every now and then. Every so often he?d introduce to me to someone new, pulling me aside to show off his eager young masseuse to his fellow pedo?s. These people had so much money pouring out ofthem. I don?t know why he even thought they?d care in the first place. It made me feel good though. At least I knew I made him proud to have me in his company. Being surrounded by so many ofJeffrey?s colleagues and his likeminded people that were considered the most sophisticated and the highly esteemed of today?s world nearly made the way I was living lately more fathomable, at least to myself. I thought if everyone looks up to these people and they are all accepting of it, it must be just the way the world tums. I danced with a young prince that night and with all of the help from the bubbly champagne I couldn?t remember his name for the life of me. On one of my trips back to the table for another glass, Jeffrey leaned over to quietly whisper in my ear that it was a prince that I had actually been dancing with and I didn?t phase me in the least way. I went back to the dance floor and continued to let my hair down. it was a fun bash, the entire crowd sang ?Happy Birthday? to Naomi and by the time we got back in the car to retreat for the night, I was giddy from the drinking and dancing all evening. We had a guest in the car, and apparently we had already been introduced, but I couldn?t even remember his name in the first five minutes of our meeting again. He was the hotel owner of some large chain in America called ?Hilton". Staying at one of the cottages near Jeffrey, he saw it quaint to loan me out for a night?s massage to ruin an ?almost? perfect evening. Jeffrey told me to come back to his room after I was finished with Rick, thankfully he reminded me of his name but also odd I thought, being so late I would?ve never imagined Jeffrey could stay up this late but 1 never made a fuss out ofhis requests. gave him affirmation of my understood instructions and headed off with this stranger into the darkness. 1 dimmed the bright lights in his bedroom to a softer tone as if it might aid the vision ofthis short, balding man with straggling remnants of curly brown hair left to show for the remaining bits ofyouth left in himundress and lay on t0p of the towel that I had picked up from the neatly folded pile at the end of his bed and spread it over the duvet. I didn?t want to waste a second in his place, getting right to the very reason [was even there. Turning around while he was getting undressed, being our first time together, I wanted to give him the impression I was actually a therapist and not a finale to the end of the nights entertainment. Not exactly what he had in mind though, given that my impression was already made for me when Jeffrey arranged for our meeting in the ?rst place. His chuckle to my response was condescending as he came up behind me and unzipped my dress which ?oated to the 66 El Copyright Protected Material CONFIDENTIAL GlUlil?leOO-l 19?) Case 18-2868, Document 278, 08/09/2019, 2628230, Page597 of 648 bottom ofthe floor as he was saying ?You can?t really expect to give a massage wearing this, here sweetie, I?ll help you out of it.? He just wanted to see the hidden bounty my clothes were hindering his eyes from seeing. Ijust went about my way trying to get his hands off lie down for a massage. Making quaint conversation with him was pointless as I was trying to send his thoughts elsewhere other than the apparent perverted schemes replaying in his mind from the heavy breathing he was making and the looks he was giving to me. I was using all of the tricks in the ?turn-off" book even asking him about his wife and kids. Unquestionably he was in seventh heaven turning every one of my distractions into another flattering compliment. He was saying things like love what you do you to me, I have never felt like this before, come stay with me and I will pay you double, no, triple whatever Jeffrey pays you!? Knowing he was just a drunk idiot, I wasn?t being lured in by any of his offers of money or a privileged lifestyle, I knew these cages all too well and I was better off sticking with the one that I was at least accustomed to already. Holding back any composure now, he was going extremely wild ravishing at my body trying to tear off my panties like a hungered wild animal. After all of the champagne I had drunk that night it gave me the nerve that I needed to know exactly how to handle perverts like this one, who had been no different from every other shmuck in my life, and I quickly shut him up with a blowjob lasting no longer than two terrible minutes. It had only been shy of a half an hour before I was already getting quickly get dressed and hurrying out his cottage door. When I got to Jeffrey?s cottage I rushed through the door and told Jeffrey and Ghislane, who were sitting front of the fireplace reading a books, that I never ever wanted to see that guy ever again. When they asked me what was the matter, I told them of every thing that had happened that night even how he offered me to come work for him getting paid triple. I established a lot of trust with Jeffrey that night. He asked me why I didn?t accept the offer and I responded with Who would look after you, ifI were gone?? Like a caring grand father would do, he pulled me into his chest for a hug and told me that it meant a lot to him. It was so late and I was so tired but I still had to give Jeffrey his massage that night. He asked me to just rub his feet as he fell asleep, and thankfully he was out like a light in no time. The next morning I took two headache tablets and a ginger ale instead of a coffee. Trying to contain my hangover as best as possible behind a pair of sunnies it was mid afternoon by the time I had felt like myself again. We spent the day Yacht hopping, soaking in the sunny weather while Jeffrey and Ghislane caught up with old acquaintances, Emmy and I were just accessories to look good on the arms of them. The next day we wrapped up the tail end of 67 our trip and commenced our flight back into the US, was paid a generous amount and set off to go car shopping as soon as I got back to Florida. Through a private seller, I was able to pay out right for my car. I got a Dodge Dakota in cherry red, and immediately had an impressive sound system put in. She was my ?rst pride andjoy and taste of freedom. I would love to drive her down to Lakeworth Beach to sit in my car and watch the waves while I listened to my stereo blare music and puffed on a jay. Letting the rest of the world pass by while I sat back and watched them walk past wondering to myself what their story was about. I turned seventeen that summer and had accumulated a string of exotic destinations that I had travelled in such a short time. I was given more make-up and a pair of diamond earrings from Jeffrey. Ghislane oniy wished me a happy day, wondering at times if she felt threatened by Jeffrey?s and my closeness. We went to the island after we left NYC and I asked If Sarah would be meeting us, mentioning it had been a while since we had last seen her. He said he had some bad news about her. Expecting the worse, thinking she had gotten hurt or something, I was astounded when Jeffrey told me that she had been sent to his island with one of his friends for a couple days and when the housekeepers were cleaning her room and they found a stash of cocaine left out carelessly in the bathroom. He said he had no choice but to let her go. Addicts with no respect for themseives or his wishes had no leeway in Jeffrey?s book. He didn?t mind that I dabbled in drugs once in a while as long as I never brought them along with us on any trips, except for my Xanax, which he didn?t mind because it was pharmaceutical and most of all wouldn?t cause him trouble being a legal narcotic. Sarah took it too far when she crossed international borders with an illegal drug, risking her welfare and almost costing Jeffrey public attention. She lost her apartment and contacts in the acting world, only hearing from acquaintances once in a while that she was sinking deeper and deeper into the black hole of addiction. It was sad to find out, as I always did like her. At the island, Ghislane hadjust recently obtained her helicopter pilot?s license and wanted to get some practice airtime and flew Jeffrey and I to St. John where we picked up Alexandria Cousteau, the grand daughter to the inventor of the scuba tank and underwater explorer Jack Cousteau. Ghislane was out to set us affright in the air, but it was all talk, she was actually an impressive pilot. Stiil a daredevil though, she got her kicks out of hearing us fret on the ear-muffs intercom?s. Jeffrey made it clear that Alexandria was a guest when I was told to adhere to her if she wanted a massage, which I obliged her with several times during our ?rst meeting. It was Jeffrey who instigated that her and I reenact as lovers in lesbian acts of foreplay and penetration. I couldn?t imagine a girl with 68 Copyri It Protected Material CONFIDENTIAL [fl Copyright Protected Material (J?lUl?l'lUiOlHZOl Fl Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page598 of 648 such high prospects lowering herselfto something of Jeffrey?s standards, but I later found out through Jeffrey that he had donated money to her continuous exploration into marine life and habitats. She had followed in her family?s footsteps, all of them involved in Marine Biology in some way or another. We actually got along really well, she was a real decent girl, and loved talking about her passion, everything underneath the waters surface. When I wasn?t busy giving massages to everyone around, her and I would hang out together. Often we go swimming in the clear pool of ocean that the Caribbean had to offer. Once we swam out so far not paying attention to our location and were carried out to sea by the current. We took turns on the backs of each other, taking breaks against the strong ocean tide. It was almost a possibility that we nearly drowned out there, if it weren?t for some guys on a boat out ?shing for the day when they caught us in their view. They picked us up and brought us back to the island where we were reprimanded by a worried Jeffrey and Ghislane to first of all let someone know where we are going at all times, and never to lose sight of the shore while out for a swim. After that learning experience I took their heed and proceeded with caution. I had a newfound respect for the ocean and it?s mysteries. Having such a lover ofthe water as a guest, made Jeffrey want to explore parts of his Caribbean he had never seen before. The next morning we were met by a scuba instructor in St. James and given a few lessons in how to use the gear and more tips like how to descend slowly to the ocean floor as not to cause blood clots as well as visual hand signals to communicate underwater. It was so exhilarating beneath the waters surface. No voices to listen too, only the enchanting sights to take in. We explored the surrounding reef and found a large squid, many of sea urchins, and the magnificent colored coral that housed a many of the rich variety?of the local species of fish. It was such a great sight to take in. Holding a permanent mental picture of those adventures to carry in my head for all times. We all had such a great time that Jeffrey hired the same scuba instructor to come out the next day to scuba dive the safer parts around his island. We got bored quickly with not much to see but seaweed and a fish here and there. It didn?t take long before Ghislane decided for us all to explore other numerous locations by boat, Jeffrey needed a bit of convincing at ?rst and the instructor was quick to assure him that he knew his way well around these waters, of course he would say that, he was getting paid a hell of a lot to do this in the first place, why not extend it a few more hours? The clear water glistened and the tropical array of marine life was on display as we wanted to stop at so many places but you could see as 69 GIUFFRE004202 beautiful as it was it could be as equally dangerous. It took so long as we had to veer away from so many desirable spots. Finally we found a good place that the scuba instructor thought was safe. He buddied us up into pairs and we jumped off the back ofthe boat into the aqua blue waters beginning our descent slowly into the darker regions of the oceans floor. We were situated on open water with a cavern of reefs to venture in and around down below. It seemed to be quite a choice to scuba in, one that our guide said he wasn?t familiar with but to alleviate his bored clientele deemed safe to swim around. It was Jeffrey and the Guide together, Ghislane and Emmy, and I was paired up with Alexandria. Miles, the houseman, came with us and stayed on the boatjust in case something went wrong and lucky he did. We were all too far under the water to hear his alarming screams of distress when shadow?s lurking in the murky distance started appearing closer and closer. Ghislane actually looked frightened for once as she gave us the signal to start ascending upwards, reminding us by holding her ears not to go up to quick or as we were previously warned before we could pop a blood vessel in our brain and hemorrhage to death, not a very lovely image but neither was getting torn apart by sharks.Those giant shadows became clearer and soon enough we could recognize their indistinct species as the terrifying and more aggressive breed of sharks, the hammerhead. Grabbing Miles hand I was the last one ahead of the Guide to get on the boat imaging the worst as I waited behind Emmy and Alexandria who were the next to follow after Jeffrey and Ghislane I was in too much shock to scream or cry, Ijust told myselfI had to stay calm to get out of this alive. Unlucky for us we found out later on that we were in their breeding territory and being sent a clear message that we were soon to be on the menu to their feeding frenzy. We all felt like we had cheated death and I know it wasn?t only my heart that was still beating out of my chest when we headed back to Jeffrey?s island. Jeffrey was pale as his designer sheets and looked like he had aged another ten years in such a scared state. Ghislane took the heat off herself even barely taking a notice of beforehand and decided to poke fun at all of us frantically scurrying to get out of the water, it wasjust her nature, as I had never seen her move so quickly either. We got back to the island and all collapsed our fatigued bodies in our own beds for a long nap. Freshened up and much more relaxed we regaled our horrendous story again over dinner, this time in laughter. The following afternoon Ghislane piloted us all in the helicopter to St. John?s Airport and we said good-bye to Alexandra where we all parted ways. I met her a few more separate times in Palm Beach at Jeffrey?s Mansion, but she wasn?t a regular of his, probably not as easy as the troubled girls were to bribe. 70 Li Copyright Protected Material CONFIDENTIAL (SlUl?l?RIjUO-?llt? Copyrigl Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page599 of 648 Chapter 11 Throughout the remainder of the quickly passing year I was on a constant move with Jeffrey. Attending various dinner parties, mostly with other esteemed billionaires and widely acclaimed scientists. Jeffrey likes to surround himself with the most brilliant and powerful of minds, ?lling his little black book with some of the most esteemed and even infamous people in today?s wealthy society. It was during those intellectual gatherings that my body was also put on the banquet menu but this time for a powerful senator George Mitchell and another prominent Nobel- Prize winning scientist who?s name would be mentioned but for all the life ofme can no longer remember. They would be only some of the recognizable ?gures of the high society that became added to my list of clientele, of course being introduced to for a lot more than just a client of massage. As an amusement to Jeffrey?s associates 1 also knew my place was to entertain but not to every desired content. was to show them a good time but not the way I would have to use technique and effort for Jeffrey. The very teachings from Jeffrey himself, or my tutor, as he liked to so eloquently put it. Consistently being used and adored for the likeliness of my youthful looks I was becoming very accustomed to my lifestyle with Jeffrey, never really relaxing into it, butjust accepting this as being as good as it will ever get for me. didn?t think I should be complaining, wasn?t I being offered a. life in exchange for servitude? Just letting the signs of my anxiety and depression pass me by while I blanketed them - with my pills, suffocating under a blanket ofpain is all I was really doing. I spent Christmas and the New Years holidays with Jeffrey in N.Y.C, who doesn?t celebrate the occasion, as he is of Jewish descent. Not that he was a religious man anyways, I never even saw him celebrate Hanukah either. We stayed at his ranch in Santa Fe for a week, then left for a long plane trip to Paris, France where we all suffered jet lag for the next twenty four hours. We all stayed in a grand hotel with a view the Champs? Elyse. Emmy and 1 shared a room and with her gifted ability to make new contacts in just a few hours, she brought out ajay to share on the rooftop at nighttime while we were overlooking the lit up Eiffel Tower. We never got really close as buddies but we both knew what we were indebted to and felt each other?s sorrows. All four of us went out shopping at Chanel, Ralph Lauren, and many other little exclusive boutiques the following afternoon. As a gift Jeffrey bought me a white terry clothed goose feathered sofa and had it sent back to my apartment in Florida, and bought some new tapestries to have sent back to Santa Fe for his ranch. 71 GIUFFILE004204 We also visited his up and coming Paris apartment. It was a modern, typical ?at being refurbished, and we went to see how it was all looking. Jeffrey liked to fuss about every detail and harass the builder?s about their work, changing last minute details at a whim. Days and many croissants later we left for Spain feeling bloated and sleepy. We only stayed in Spain for the afternoon, going to see another astounding Moroccan castle for Jeffrey to replicate at one of his many mansions. It was only a short plane ride to Tangier, Africa for more castles hopping. We arrived at the historic landmark and the only five star hotel in Tangier called El Minzah in the village of Ville Nouvelle. The city and outskirts were still very hostile at the time, females being warned to not walk the streets alone and not to leave the house after dark or be at risk of being raped or worse. When we got to the room, it was oozing with every expected bit of extravagance that a luxurious historical palace should offer until i was greeted with a pile ofmonkey poo in the very middle of my bed. Not a happy camper I called Jeffrey, Ghislane and Emmy into my adjoining room and they all had quite a. good laugh at my expense. Within a moments notice of a complaint call to the front desk and we had an attendant cleaning up my bed linen. The cleaner noticed the window was still opened, he warned not to leave it ajar at nighttime just in case another monkey wanted to make himself comfortable in my quarters. Ghislane joked that maybe I should keep it open I might find a suitable husband before I get any older. Always the instigator ofa good joke but unable to take one herself she didn?t like when poked back that it was more in her recent taste ofmen, since she loved to brag about her rendezvous with her various lovers. Once she came back giddy as a schoolgirl with an explosion of news, with all the build up and excitement in her voice you?d think she was the next crown princess, but she had given George Clooney a blowjob in the bathroom at some random event, she never let that one down. We all went to explore the towns surrounding Moroccan castles and meet their royalty that lived in them. Jeffrey?s personal interior designer?s met us at the residences. They walked around hurriedly, scribbling notes into their clipboards and whispering between themselves. The palaces were historically unique and beautiful but I wondered how could they live so grandeur behind these walls when they lived in a city of such poverty stricken squabble. Beggars lined the streets, people couldjust go missing and no one could care less, and you heard of barbaric murders happening every night. Against the advice of the Palace Attendant and Jeffrey?s wishes, I decided to take a stroll one afternoon, mainly just to take photos of exotic Africa and do some shopping in the village markets but I ended up being intrigued by a group of young children playing in the streets. 72 Copyright Protected Material CONFIDENTLAL Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page600 of 648 When I was noticed watching them, about ?fteen of them came up to me and began to beg for money and food. I was over taken by the poor, hungry children and I felt sad for them all and wished I could help out somehow. When the tide of kids washed away and the street went empty, I was overcome with intrigue at these two little boys. Brothers I found out later on, and there only toy was an empty can they were kicking to each other in the middle of the street. Intelligent kids, they were able to speak three different languages, including English and I was interested to ask them about life here. They didn?t seem to notice or be bothered by their poverty stricken lives. They told me about their school and parents and I thought I hadjust heard the saddest story ever but they were accustomed to living like that like I had been so accustomed to my degrading lifestyle for so long. I was compelled to empty out the contents ofmy purse, giving them Over two thousand dollars in US currency. A passer-byer snapped a photo of the kids and me for myselfto take home as a personal souvenir before they rushed home to proudly show there parents the money. I. told Jeffrey later on of my good deed and he couldn?t believe I?d give away my money so carelessly. He told me I had set up their parents with enough money to feed and shelter their family for a year. Wasn?t that a good thing? I couldn?t believe it, not that I was well off or anything close too it, but to realize how lucky I was and to not have compassion for the lesser off, especially children ofa third- world country, I wouidn?t be human anymore. Then again what did I expect from someone who could numerously steal another man?s daughter for the use of his own sexual pleasure with great ease. We went out to lunch the following day with Jeffrey?s team of designers to wrap things up and after Jeffrey?s afternoon massage he went to the palace to have a nap. When I was all alone I thought I?d go see the culture ofthe local unique markets again and this time buy some trinkets to bring home. I got to sightseeing and took pictures of the legs oflamb hung over the blood drenched doorway over people?s homes as to warn off evil spirits and the ghettos where the local villager?s called home. I walked into many of the market?s stalls and saw the most peculiar antiques, such. as weaponry with the blood ofit?s last victim stained on it?s sharp blades and body pieces of various animal?s for the use of religious sacri?ces. I was more interested in the different culture and respecting their ancient way of life with interest, instead of squirming like a tourist and getting grossed out. I thought it was so educational and enthralling in fact, I ended up buying a few sacri?cial trinkets to have sent to my apartment in Palm Beach. Not to say that I wasn?t looking forward to getting back to the luxuries of western civilization it was a bit like camping, fun and adventurous but as equally dangerous and thrilling. 73 When we left for the ?nal destination ofour trip I was looking forward to eating normal food again, not one to stray for foreign dishes, I?m a more ofa cheeseburger and pizza kind of girl, a true sign of my American heritage. We landed at the Heathrow Int?l Airport and greeted by a driver that would take us to Ghislane?s town house in London?s central that Jeffrey had recently bought and refurbished as a gift for her. Emmy said ?Good- Bye? at the airport, leaving us to go to her hometown in the rural nearby to visit family for a six-week holiday from work. It wasn?t a very long drive before we were in the heart of the city and at Ghislane?s place. I thought it was a cheery townhouse that had character and the historical pub in front ofit and cobblestone streets only added a unique charm to its presence. They were going out for dinner and invited me along with them but seeing I was so exhausted from ail the travelling and looking a bit melancholy, I apologetically declined going out for dinner that evening, I rather would be taking a few pills to catch up on some needed sleep. ?Are you sure your Okay?? Ghislane asked as she showed me to my room, more considerate than she normally was but I assured her that I was in absolute good health,just tired from all of the recentjet lag. Without another word said she whisked off down stairs, to the car where Jeffrey was waiting for her. I took the liberty to call my parents house to say ?Hello? and catch up with them since I hadn?t been home at all for the holiday season this year, always too busy working. They sounded really happy to hear from the phone to talk to my brothers as well. I got to tell them about my travels abroad and I had some cool tribal stuff from Africa that I bought for them. They sounded so proud ofme, all of them, and why shouldn?t they be? in everyone?s convinced mind I was making great money, travelling the world, and meeting new faces everywhere I went, why shouldI spoil anyone?s delusions, especially mine. I took my sleeping tablets and had a bath before falling into a deep and much needed sleep. The next morning I was woken up by Ghislane who I could tell was in a chirpy mood by the way she paraded through my closed door saying ?Wake-up sleepy head? and opened the window?s shutters to let in the bright sunlight, she had never done anything like this before and I knew immediately something big was happening. She sat down on my bed as I rolled over from my deep slumber and I was able to mutter for an explanation as to why she was awake so early. ?Besides the fact it is ten o?clock in the morning and nearly time for brunch, we have a big day planned out for you today.? She was waiting for my cue to ask her ?What are we doing?, when I did, she responded with a convincing enthusiasm ?We?re going shopping for a new ensemble? she paused for a moment to 74 Copyright Protected Material CONFIDENTIAL Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page601 of 648 build the suspense, before completing her sentence To go dancing with a Prince of England this evening?. Hoping it would be one of the younger generations, I was disappointed when she told me he was the Duke of York, Charles?s younger brother Andrew. I looked at her with a fake surprised lookmany occasions in my time with them, to give an impression of excitement. I exclaimed with my gifted acting ability. It is a sad realization but I had grown more accustomed to seeing people for their significance rather than the good qualities they possessed, and was able to grin bear the thought of what I expected lay in store for me. Ghislane and ieft shortly thereafter for the many lanes of designer shops to choose from in London. Her pep talks to prepare me for my duties towards royalty went on and on, giving me the obscure impression was something of importance, at least for more than an evening. ?Make sure your bubbly and energetic, nobody want?s a dead horse? was one of the cheap toois she instilled me with. ?Who knows where this could lead for you? was another. As the day grew shorter my anxiety only heightened, anticipating the Prince?s arrival and unable to decide on an outfit, I picked out three. Our last stop for the day was Burberry?s for a nice handbag to compliment our chosen attire. We got back to her townhouse with still a couple hours spare to get ready. After trying on all three outfits arid many mental debates with myself later, I decided on the pink mini-tee and dazzling pair of denims with horses embroidered into a pattern. It seemed a lot more my styie and age group rather than the other two older looking sophisticated dresses I had picked out. I told myselfI was going dancing at a club not to an opera. As most young girls can be during their body changes into womanhood, I felt awkward, you know, big feet, freckles and body hair in unwanted places. They?re things you just don?t want when your seventeen and then you see these iconic billboards of what femininity is supposed to represent andjust don?t fit into that picture, never feeling what we all are absolutely perfect. By the time I had got ready I was a nervous wreck, but trying to keep my cool on the outside was an act. I thought it?d be a good idea to take a few Xanax before the evening unraveled and my anxiety went through the roof. Jeffrey and I were sitting in the lounge room downstairs, waiting for Ghislane to finish getting ready. The room was silent, only stillness in the air. I stared at the mural painted onto the wall that I was facing. It was an interesting piece of artwork. In great detail it illustrated a happy looking family sitting on a bench overlooking a pond that resided on a large piece of land with a beautiful home displayed. There were also hunting hounds and the hunters chasing a game of fox like the notorious ?English l-Iunt Pieces? throughout history. Jeffrey took notice of my enchantm ent into 75 GIUFFREDO4208 the picture and in a hushed voice proceeded to tell me that it was a portrait of Ghislane?s childhood, the part she could be proud of. I never realized how prominent her family?s history was in England, apparently as to Jeffrey?s attest, her Father was born of poor Jewish decent in Czechoslovakia, most of his family being killed upon Nazi invasion in 1939. Fleeing to join the British Army as a young man, he changed his name a few times and made a lot of contacts in the field. After the war, a newfound Robert Maxweli went into publishing using his army contacts to establish a business initially built upon publishing scientific books from occupied Germany. In time, Maxwell acquired several British newspapers, among them the Daily Mirror, countering his wits against the likes of Rupert Murdoch along the way. However, whilst constructing his publishing empire, Maxwell compiled astronomical debts, and his equivocal financial dealings attracted the attention of governing authorities thatjudged him not to be looking out for his companies best interest and in the end it transpired that Robert Maxwell had been using proceeds from his employees pension funds to meet his financial debts, ruining the futures ofthousands of employees. Once an esteemed Member of Parliament and publishing mogul, Robert?s body was found ?oating in the Atlantic Ocean after he was found to be missing from his yacht, the Lady Ghislane (named after his favorite child), whilst cruising the Canary Islands in 1991. Jeffrey went on to tell me that when her Father died she was inconsolable, and in a very bad state. He picked her up from the trenches of despair and took her under his wing, and it?s there she has stayed comfortable ever since. To Ghislane his peculiar need to have so many woman around and even his taste in younger than legal one?s didn?t seem unconventional to her. It was her own Father who was deemed a womanizer and even took a second wife whilst still married to Ghislane?s mother. I would have never guessed this carefree, spirited, and vivacious woman had ever endured such sorrows. I couldn?t help but look at her in a different light from then on, but not letting her know that I knew, to avoid any altercations between us. Like clockwork Ghislane came downstairs five minutes before Prince Andrew were to arrive, wearing a tight-?tted white wooly turtleneck singlet and a nice pair ofloose fitting trousers. Looking elegant and casual at the same time, a very hard look to achieve but one Ghislane had always easiiy mastered. They both seemed at ease poking fun at my obvious nervous state, just another ordinary night out for this extraordinary couple. The knock came at the door just after six o?clock in the evening. Ghislane greeted him and the guard who would wait for his return in the car. She led him down the hall to where Jeffrey and I were sitting. We both stood up and Jeffrey shook his hand, while Ghislane proceeded to introduce me and as I was taught by her was English 76 Copyright Protected Material CONFIDENTIAL Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page602 of 648 custom, we both kissed on the check. We all sat down on the iounges for some tea and biscuits while conversing idle chitchat. By the sounds ofit, Ghislane knew well of his recently divorced x-wife Fergie, whom they were all taking turns in slandering her for one reason or another. It was apparent there were some fresh wounds still lingering on and as good friends do, it was their way of helping him get over her. When his daughters were mentioned, Ghislane and Jeffrey treaded only speaking highly of them, and offering their sympathy to the young ones. The conversation turned to a much lighter subject. Andrew wanted to know more about this young guest they had tojoin them out for dinner and dancing that evening and then the spotlight turned on me. I was more nervous than I had ever been before a night out with someone, probably the build-up Ghislane and Jeffrey had hyped this meeting up to be. To break the ice, she played her favorite guessing game. .?how old do you think Jenna is?? When Andrew guessed correctly, I was seventeen years old, she was surprised, thinking I could have passed for younger. guess we are going to have to trade you in soon? she laughed, always the ?rst one to throw in her quick-witted two bits, ail ofthem chuckling albng with her. Hardly a laugh at all, unknown to me at the time his eldest daughter is only ?ve years my junior. I was ?nding it hard to make much conversation in the beginning, just laughing when the occasion called for it, and keeping up with Andrew?s constant glances in my direction, was all I could manage. The restaurant was a close drive for us with Andrew, his two guards and his driver following behind us. I was seated next to the Prince for dinner and Ghislane and Jeffrey next to each other, an evening pre-ordained. I was supposed to flatter him with compliments and dote on his every word spoken, but I didn?t even do that for Jeffrey blatantly, it would?ve felt awkward to act like a bimbo for him. Instead I remained caIm, cool, and collected, hoping that my nervousness wouldn?t spill out at any given moment. The next place we were going was much more my style, and I found it easier to relax. We pulled up next to a called ?Tramp?, a member?s only and one ofthe most exclusive haunts in the world for the rich and famous to be seen for the last forty or so years since it?s doors ?rst opened. Andrew?s guards waited outside while we all went in to hit the dance ?oor. Jeffrey being the social introvert that he was found the ?rst available empty seat in the corner but facing the dance ?oor to spend the evening watching everyone else have fun and Andrew went to the bar to grab us all drinks. He came back with sparkling water for Jeffrey and a cocktail for the rest of us, already knowing that Jeffrey never drank alcohol. We downed our glasses and made our way to the crowded dance floor, where I had the Prince?s upmost attention. Moving his hands across the curves of my body, not to shy away from the fact 77 GIUFFREOMZ 10 that he was in public, he was whispering sweet nothings into my ear and kissing my neck. I would just giggle not really knowing how to reply to an aging man with a bad smile and terrible moves, it would sound too much ofa lie ifI retaliated back about his swagger. He was the most incredibly hideous dancer I had ever seen and couldn?t help but laughing on the dance floor and shooting glances of embarrassment to Jeffrey and GhisIane who were having a good time laughing at my expense. . .as the always did. After an hour of pelvic smashing to the pumping mixes we ?nally exited the ?oor, his royal highness was dripping with sweat and ready to embark onto a quieter scene where he said we could be alone, not knowing that it had already been arranged for all of us to meet back at Ghislane?s place but complied with his so called thoughtful request. I was so anxious about getting back to the townhouse, knowing what expectations I would have to not only have meet but also exceed in this case. Ghislane and Jeffrey seemed impressed at my attempts to entertain his royal highness, so far giving him exactly what he wanted the impression that I idolized him. They told me that he really liked me and was having a great time, so far tonight. When we got to the townhouse, his guards walked him to the door, staying to wait outside in the car. Ghislane met him and brought him upstairs where Jeffrey and I were in the study. We all chatted in the hall for a few minutes and I was able to have Jeffrey snap a photo of us together, one that would cause much controversy for the Buckingham Palace in many years to come. The conversation didn?t linger on much longer before Jeffrey and Ghislane dispersed downstairs together, leaving me to my own sort of royal duties. They walked away giddy as ifthey were teenagers imposing on young lovers about to embark on a romantic evening. Next to the study was the bathroom where I led him to next. The room was dimly lit masking the light from showing the disparity in my eyes. It was a beige marble tiled floor with porcelain Victorian style bathtub in the middle of the room and nowhere near the size of Jeffrey?s residences. I turned on the taps for the tub and the heat from the water began to steam up the small room. On the basin were aromatic oils, lotions and soaps, loving the scent of ?oral notes, I poured in the lavender bath oil. Trying to do the best of my youthfulness to try and act seductive, I gradually began to strip off my clothing, piece by piece. Giving him time to savor the moment to come. He loved every Second ofit as I went over to where he was waiting and watching, then began to undress him at a much quicker pace. We kissed and touched each other before submersing into the hot water, where we both continued to reenact foreplay. He was adorning my young body, particularly my feet, caressing my toes and licking my arches. That was de?nitely a ?rst for me and I couldn?t help 78 Copyright Protected Material CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page603 of 648 but laugh, I hoped he didn?t expect the same treatment back. Through my recent experiences with Rena, I drew a line with extreme fetishes, especially ones that would involve my tongue and feet in the same sentence. It wasn?t hard to get him wound up to the point where he just wanted to have the rest of me so we dried off from the cold and retired to my bedchambers for the longest ten minutes ofmy life. Moments later and without any real emotional attachment, he burst in ecstasy, leaving me to my own feelings of dismay. As relieved as I was to see the experience come to pass with him, it was ?nally sinking in that I would never be anything more than but a muse. Still trying to ascertain a surreal dream a young girl once held but no longer the same girl I was no longer sure that the dream was even real anymore. In the whirlwind thrown together by wealth, power, and privilege I was but a grain of sand and felt helpless down the road I was naively being led down. When the real picture was unveiled, later in my life, I had nothing but memories filled with sorrow to remember of my teenage years. Jeffrey, Ghislane, and I left for the states to conclude our long journey home to the USA I was so happy when we landed on our soil and called T.J from my cell phone to see if he?d meet me at the airport instead of going back to Jeffrey?s, he?d be there within twenty minutes, he was so happy to hear my voice and that I was back in town. So ecstatic to be getting away from my life of servitude for the next few days, I was sourly disappointed when I got off the phone. As if he?d been listening to my entire conversation, Jeffrey told me he?d like a massage back at his place and he could pay me at the same time for my trip with him. With much dismay I had to call T.J back and cancel the arrangements, I wouldn?t see him until later that night, in which one ofJeffrey?s staff would drive me home and I would be too exhausted to do anything. Chapter 12 When we got back to Jeffrey?s mansion in Palm Beach he wanted to thank me for showing his friend, the Prince, such a good time. Rewarding my diligence with an extra sum of money and luring me deeper into his goal of keeping me at his side as his personal amusement that he could lend out at anytime. Further proving his capability of using the vulnerable impressions ofa young girl to influence and intimidate his fellow peers of 79 Copyright Protected Material like minds. Jeffrey didn?t want to know the grim details ofhow it all happened on my intimate night with the Prince, hejust asked simply ifl thought that I did well in keeping his friend happy. Knowing already that the evaluation of my performance I gave was already discussed between them, Ijust as simply replied back with a nod of approval. Though I did have a laugh with Jeffrey about the Prince?s weird ?xation on my feet and lets just say that he was quite tickled with Andrew?s quirky obsession, having a good ol?chuckle at my eccentric encounter. I was paid extremely well this time, putting my money earned into nothing but popping pills and alcohol by shouting my so called friends a good time, aiming for the attempt to forget about my experiences abroad. I partied like that to feel young again, my age and most of all to self-anesthetize my troubles from within, It wasn?t like Iwas waiting for someone to arrive on his white horse and take me away to a magical world. I simply yearned for more out oflife than being someone?s replaceable amusement. Still a romantic at heart I would often get lost in my daydreams, imagining a new beginning with a strong man that would show me an enduring love, safety in his arms, and a lifetime friendship. Though the suggestion of true loves existence was only a dream for now, something I could only read about in novelistic fairytales but the passing thought from time to time was warmly envisioned. With my inner most desires being locked away in a deep crevice of my heart, I knew my romantic notions would be absurd in Jeffrey?s eyes. For some unknown reason to me he couldn?t allow himself to give love or receive someone?s heart in return. Once he said to me when I asked him ifhe ever thought he would settle down and ?nd Mrs. Right and he told me he didn?t believe that love with one monogamous partner was possible but he found that love with many was. I thought at the time it had something to do with having so much money and everyone wanting him for that instead of seeing him as a person and even felt bad for him, but now i can understand from his recent lessons unlearned that it was a simple equation of his twisted perversion to become infatuated with the vulnerable youth off the streets. Spending so much time in the entrapment of Jeffrey?s embrace, I was becoming numb to the feelings and aspiration to ever climb above this deep hole I had dug myselfinto. I knew I wanted to escape from this bizarre form of first class slavery but I still didn?t have the tools necessary to help me get out. How could I have? Everyone that knew me believed I was living this enchanting life, a rags to riches success story that most people dream of, only I knew the price to be paid for all of this and I was the only one who could pay for it. Underestimating my true self, I was settled by Jeffrey?s side for now considering him to be someone to look up to, my mentor. Such a 80 [l Copyright Protected Material 13 complicated battle within myself, it is one I still ache to fully comprehend today. Sunny spring days melted away the ice off the frozen streets of New York and the harsh winter winds begun to gently blow away the dead leaves, making the caged trees appear to have some form of life again. I hated the cold winters there, it would only add to my depression being locked indoors. Give me hot Florida days blistering in the sun where I can swelter by a cool pool and sip cocktails with pieces of fruit and little oriental umbrella?s ?oating around. What a vision of solace? Looking around my extravagantly decorated mid-evil room I was reminded of the desolation that I was more than accustomed too. Knowing it wouldn?t be long before I was summoned again for another ritualistic occurrence in fomicating with my master, I hardly bothered to leave my assigned chambers, scarcely being sent home for a moments break, I just accepted my fate. As I predicted the intercom buzzed momentarily and I heard Ghislane?s voice come over and request to meet them in Jeffrey?s study. Not an odd call, I would often meet him there ?rst so he could tie up some un?nished business before heading to the dungeon, or what was thought to be the massage room. Making my way down the bail, I had an eerie feeling wash over me, as ifI had several pairs of eyes on me, watching my every move. A cold chill moved up my spine and I had to move my thoughts elsewhere, too easy behind these walls to succumb to my fearsome anxieties. [punched in number one once inside the elevator and it took me down to the floor where Jeffrey and his surprise guest were waiting with anticipation behind closed doors. I cracked open the heavy wooden doors and a familiar face revealed itself. De?nitely not expected or pre-warned on my part but I already knew what he was here for or at least why I was called down to the study. Prince Andrew had that notorious cheesy grin slapped over his face, as he looked me up and down like a shiny new car on display and he was about to take it for a test drive. Ghisiane led me to the decadent sofa he was lounging on and twirled me around to give him a good lookover before sitting me down on his lap. Like a show pony I knew exactly how they wanted me to be paraded around, with the last of my dignity long lost, I had nothing more to lose. It was easy to give them the reaction they desired, all I had too do was pretend to be entertained by their lewd gestures, and when Andrew cupped my breast with a doll made in his image, I only giggled away. Ghislane wanted to take a picture of the bizarre scene and even got Johanna, another one of Jeffrey?s so-called personal assistants, to come sit on his other knee for the snapshot, giving the impression girls couldn?t stay away from Randy Andy. Many crudejokes later and i was asked to show Andrew to the upstairs massage room. I?m sure he already knew where it was from previous 81 Co pyright Protected Material CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page604 of 648 encounters with Jeffrey?s ?staff? but I led the way anywaysguest of honor. Entering into the dim room it took a few minutes for my eyes to adjust to the darkness, but knowing my way around the room was enough to ?nd the shower. I turned on the steam room and began to undress myself. Andrew followed my lead and disrobed, throwing his attire to the floor. I wanted to run and hide feeling his hands touch me again, but my servitude for Jeffrey kept me there. Getting out of his stronghold I turned my attention to the steam filling up and tried to turn his attention to the marble bench where I suggested he take a seat while I rubbed his feet. By the look in his eyes I knew he could care less about a foot massage, his real desires were being shown by the arousal his body was forming. He indicated where he wanted me to touch him and how. I ful?lled his seedy requests, but only just. There was no pleasure in this for me, the only thing I derived from this event was to sink further into my slumber of depression. I couldn?t remember a time when I felt needed for anything other than my body or amusements thereof. After his massage was thoroughly conducted I couldn?t wait to get back to my room for another shower. Sitting on the floor of the shower under the harsh spray of water, I scrubbed my body where he touched me. Feeling abhorrent and ashamed what I had become, I let the water wash away the grime. As the days progressed into nights and the nights followed a trail of destructive months, my outlook on life had diminished into utter sadness. I had lost my spark and my ability to look like I could handle the abusive state of affairs I had drifted into. Sinking deeper in the euphoric state of being on coke and piils, not only was my mentality dwindling away but also my looks. I sure as hell didn?t feel like a seventeen year old anymore and now I wasn?t looking like one. My eyes had dark circles undemeath them from not sleeping and my bones protruded from my skinny waistline and chest. This made Jeffrey apprehensive in keeping me around as often and before I had a moments notice, 1 was out ofmoney and looking for ajob. When I questioned him what was happening, he told me I wasn?t the same girl he had ?rst met some time ago now and looked like I needed a break from working so much. I?ll call yoa next time I?m in town? was the last thing he said to me. Chapter 13 Going back to an average teenagers life was more ofa harder transition than I would?ve ever thought, Jeffrey stopped paying my expensive rent and was forced to get off the drugs and look for a real job to feed and shelter TJ and I. It was much harder than it sounded, but I was craving 82 i1 Copyright Protected Material GlUl-?l?liljtlou IS Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page605 of 648 this in every possible way. Even though a week?s wages for working a full-time job as a waitress didn?t come close to the money I had made in a couple hours of working for Jeffrey, I was happier than I had been in a long time. I made some friends at my new job and found my duties to be easy and pleasant. I was good at making customers smile and keeping them happy becoming the waitress that made the most tips for the night, which in turn made my co-workers happy since we?d all split the tips at the end of the week. For the ?rst time in a long time I had boys my age hitting onto me, and not that I was ever taken aback by there attempts but it reminded me ofhow it felt to be around a younger crowd. I missed so much of what I couldn?t get back and the more I tasted it, the more I remembered how to smile. The relationship between and I began to falter in a way that was beyond reconciliation. Fights became physical and I saw sides to him that only pushed me away more. He refused to look for work to help pay bills and he became utterly frustrated not having his usual cocktail of assorted drugs to keep him from feeling anything at all. He didn?t like the fact I was growing inside and thinking beyond his elusive world. I had gone through too much to accept another form of abuse and degradation. Making that point very clear to him by kicking him out ofmy apartment back to live with his parents, I felt liberated like never before. I kept up with my rent and cleaned my act up. Enrolling in a yoga course and keeping my focus on staying ?t and healthy became my only source of enjoyment. l-was free and living for myself. While out doing the grocery shopping one evening I couldn?t help but stop at the local pet store and fell in love with a furry pooch. She was a Japanese Chow?Chow and a bundle of fur that more resembled a baby brown bear than a dog. I took her home with me and instantly she became my best friend. We went for several walks a day and she bore the brunt of many tear filled conversations, she was my loyal companion who understood more than anyone had before, all I really need was someone to listen and funny enough it was her that ?lled that hole. Nearly three months had gone by and not a word from Jeffrey or Ghislane. With T.J out ofthe picture now too all I had to concentrate on was work, my parents and brothers, and of course my dog, Mary-Jane. I was going to family night dinners and bon tires again. My older brother was getting married to an amazing woman in a few weeks and I got to be apart of their beautiful ceremony. Small details of life?s journey that I already missed so much of and now being able to smile at the simple things day in day out really seemed to put the real value of life into perspective for me. Everything seemed to be working out for itself and I was really happy, until he came back, T.J thought he?d come over my place one evening while I was sitting at homejust watching TV. 83 GIUFFRE004216 Obviously mentally distorted from whatever choice of drugs he was smoking that night. He screamed down my apartment complex, going mad and scaring my neighbors I felt like I had no choice but to let him inside. Itried talking to him as a good friend would, just wanting him to see what he was doing to himself and what he had become. Part of me still loved him and took pity on watching him spiral downwards. Taking him back into my life was not a decision I made whole?heartedly, but was something I did out of guilt and what I thought was loyalty. He moved his clothes back to my place, which was all he ever owned anyways and we tried to pick up the broken pieces. TJ being still badly addicted to many drugs, I had to be very careful where I kept my jewelry and expensive items. I decided to rent out a space at a local spot and store my cherished items away,just taking the necessary precautions, I thought. Still not working I knew how he was scraping by money and I didn?t agree with it, T.J was a known thief and had been caught several times attempting to steal things, even as stupid as and P82 or Xbox games from a local Blockbuster. He even stole from his parents, his sister and his brother and would probably steal a piece of candy from a Five year old kid if he knew that it would get him his next fix. He hated the change in myself, realizing I couldn?t be brought back down by his ways but knowing I still stuck by his side and defended him from anything that would hurt him wanting to believe that he still wanted show the bits of human nature left in his empty heart. Unable to stand by and see me do well for myselfhe contemplated a way to try and bring me down. After a busy shift one night, he retaliated with another show of control. I hadjust ?nished cleaning up my area and setting out the tables to be ready for the next day when I went to the bar to hang up my apron and put my nights tips in the tip bowl on the counter by the beer tap. On one of his drug induced rampages he stonued into the restaurant where I was working and started to pick a fight with me. I knew he was off his face when he started accusing me of sleeping with my manager on shift that evening. Having no bias or ground to stand on in his attempt to make me look bad in front of everyone, ljust laughed him off as a drunk idiot who needed to go home and sleep off the night?s repercussions, although I was fuming inside that he embarrassed me but I still made excuses for him and told my boss I had to leave early to bring him home. The bar was deserted as TJ waited alone for me slumped in a barstool and looking worse for wear. I had to go to the back of the restaurant and do some explaining to the manager on duty, I couldn?t afford to lose my job over this incident. Surprisingly he was sympathetic towards my dilemma and even told me I could do a lot better than that schmuck, patting my back and telling me to have a couple days off. I punched out 84 Copyright Protected Material CONFIDENTIAL GIU i?l?RliO 17 [1 Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page606 of 648 and headed to my car with T.J in tow. For the rest of the night he was oddly quiet and asked to be dropped off at his parent?s house, 1 was more than obliged to do so. I couldn?t stand the sight of him let alone want to be around him tonight. Being so revved up it didn?t yet dawn on me that something wasn?t right. The next morning Iwas woken up by an alerting phone call, I had the manager from the restaurant where Iworked, on the other end screaming at me and asking where the money is. I sat up in bed, completely awake now, and asked him back, ?What are you talking about, what money?? His tone had calmed a bit and he could hear the earnestly in my voice and explained his accusations ?The tip jar was empty after you had left last night and there was over a hundred and ?fty dollars in there, now it?s missing?. The answer hit me instantly and I got a terrible knot in my When I left him at the bar not even thinking about the tip bowl to talk with the manager, he saw an opportunity to fund more drugs and he took it. That?s why he didn?t even want to come back to my apartment last night. It was all too clear for me now and I tried to explain to my manager about my boyfriend?s sickness and asked him to take the lost money out of my wages. ?l have no choice but to let you go and file a police report for the missing money?. I couldn?t believe what I was hearing. How did things turn upside down so quickly? I exclaimed ?Even though I?m paying you from my pocket for money I didn?t even steal and you?ve never even had any problems from me before??. His apologies were short and icy, nothing that Could be done. I slammed down the receiver only to pick it up again to dial parents house and to no surprise he hadn?t slept there last night and was not able to be reached. I felt like 1 was in a bad dream I couldn?t wake up from and with no money to pay rent, eat, or even survive, I was back to the drawing board. The week passed without hearing from T.J, he was in hiding, for now. When the phone rang early one morning I expected it to be him, instead it was a surprise phone call from a familiar voice. Jeffrey decided to give me a call to invite me over to his Palm Beach mansion for some lunch and to catch up, it really wasjust his way of ?nding out ifI was cleaned up and ready to come back to work for him. With my life in chaos once again and having to borrow money off my parents for grocery food, I saw a quick solution to my situation and was even convinced this is what I had to do to take care of myself. He greeted me at the door and led me inside. Ghislane was at her usual spot, her desk working away, and we headed past her with a quick wave and lip-synced a ?Hello?, not wanting to disturb her important sounding phone call. She glanced up quickly and gave a brisk wave my way, then put her attention back to the computer. Once we were inside the poolside cabana, which was Jeffrey?s of?ce, gym, Jeffrey took a seat behind his 85 GIUFFILE004218 desk and told me to have a seat across from him. He took a sip of water from an already poured glass and asked ifl?d like some. ?Yes, Thank you? My reply was short and polite, alreadyjust wanting to get this meeting done and over with, His face was like steel and his expressions were stern, felt like a child in trouble sitting in the principles of?ce. He cut straight to the chase wanting to know ?Are you on drugs anymore?? There was a moment?s pause as 1 took a deep breath and told him the entire truth. ?1 got really depressed for awhile and coped with my emotions by blanketing them with mind-altering substances. Just smoking a jay to relax wasn?t good enough anymore. I needed to be high and ?ying to believe I was happy and dealing with all oflife?s curveballs. Snorting things like coke and popping amphetamines replaced my sorrows with an over?ow of endorphins, making it possible to keep up with everything, until I would come down and the cycle just kept on repeating itself?. He listened to me continue to tell him about the good things that have come from the break. Like my dog, yoga, and working at a restaurant, making lots of new friends but most of all, I got my smile back, without the drugs this time. He was really happy to hear the upside of everything, but there was one thing I was reluctant to tell him about. My recent travail that T.J effortlessly caused at the restaurant where I was so happily employed. As my manager had warned he had to file a police report stating that after 1 had left, the tips were gone, putting the blame solely on me. Giving Jeffrey a clear picture of the entire ordeal he exclaimed ?What are you doing with this idiot Jenna, he is no good for you! I know you can do better for yourself, why do you let him drag you down every time?? Nodding my head in concurrence I went on to ?nish my epic drama. received a phone call from the PBCP asking me to come in about the money, I told them what happened over the phone but they still want me to come in. I don?t want to have a record for something I never did or ever would do!? I put my face into my hands and covered the tears now trickling down my cheeks. ?1 just can?t believe this is happening to me when everything has been going so uphill, now I?m out of work and in trouble? I wiped my face and looked up at him What do I do?? Enabling him as my mentor once again, his sly grin said it all. Jeffrey normally hated when girls made waves in any way and this one would be considered a tsunami but this time it worked to his favor. He wanted me to come back to work for him, continuing my massage studies and I needed his help. In his eyes he was doing me a solid, which in return I would have to scratch more than his back for. Taking his time to contemplate what to respond back and what solution he could offer, I began to worry that maybe I shouldn?t have done this. 86 Ll Copyright Protected Material CONFIDENTIAL Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page607 of 648 Pulling a few tissues out of the box, he passed them across the desk to me. Trying to retract any damage done i said to him ?i must look like such a mess to you and making you listen to my saga, I am so I shouldn?t have come to you with all of this.? He looked surprised and sympathetic ?Quite the opposite actually. I?m glad you?ve come to me for help. I have got a lot of connections especially with the Palm Beach County Police Department. 1 give them regular hundred thousand dollar donations, and afterI speak with them there will be nothing more to worry about. To be honest l?m more in shock about how much can happen to you in such a short time, your life is one big soap opera? Now he was chuckling and trying to make light of my somber mood. Laughing along tool replied, I know right? Drama just hangs around me like a bad smell?. We did some more light-hearted catching up and went out to the poolside for some lunch and a swim, concluding the evening with an erotic massage upstairs. He paid me the usual two hundred dollars and asked me to come back tomorrow. ?In the meantime I don?t want you thinking about your sticky situation, consider it dealt with?. His attempt to brighten my spirits had worked relieved about money and the police but now I owed myseifto him feeling indebted to him more now than ever. Chapter 14 As was promised I never heard back from the Police Department and Jeffrey had his favorite girl back by his side. We picked up where we left off ever better than before, I being entirely subservient to every sexual desire of his engaging myself in any role he wanted me to play. As he was getting older his appetite for sex never hazed, if anything it only increased. The orgies with other girls got larger in numbers and his appeal to younger girls, new toys and wilder nights expanded from once and awhile to quite an often occurrence in Jeffrey?s company. i put it down his new friend and business investment, Jean-Luc Brunei. A long time agent for young and upcoming models, Brunei, a French citizen, was known for roaming the world in search of young, na'i've beauties living in poverty stricken countries and willing to do just about anything for money. He would procure them mostly from Clubs in South America and the Former Soviet Republic. Filling their heads with fairytales of America. and large amounts of money, he would promise them all of the ?ner things in life, sometimes even throwing a pill in their drink, if that meant getting them in his bed was becoming too much ofa task. What he wanted is what he got, which is why him and Jeffrey 87 GIUFFREOMZZO ultimately became close pals and be invested one million dollars into Brunei?s company. In return Jeffrey now had supply of girls on tap for him to choose from. With the assistance ofeach other, Brunei obtaining the illegitimate visas for underage?overseas girls and Jeffrey housing them at his brother?s apartment complex on 301 66'h St, Manhattan, they were quite the team. Jeffrey and Brunei would charge them for rent, forcing them to work for them selling their bodies for money, nude pictures, and even pornography. These were what seemed like really nice people with not so nice intentions setting an impression of how the digni?ed wealth play and behind closed doors they had as much civilized manners as a barbaric chimpanzee in heat. Giving a girl a step?up in ?nances by teaching them there only worth is what lay between their legs, us girls all were the same in the end, regardless of what country we came from, what language we spoke or our cultural indifferences, we all were being used for one thing alone, our youthful looks and beautiful bodies. Being Jeffrey?s permanent sidekick, I would have to part-take in a many of the hedonistic exploitations that went on at one of hismany residences, which meant having to be uninhibited with many girls my age and younger. Being complete strangers was hard enough but we couldn?t even understand each other, speaking in different tongues we were expected to excel at preforming many acts of lovemaking and foreplay on each other, while being observed by a man in a corner jerking off. Not exactly what 1 would call an advantage in my stage oflife, but in my head i was convinced we all had to do what with life and ifthat meant doing all ofthis to keep Jeffrey happy, then I would do that. It didn?t take long in the accompaniment of Brunei for Jeffrey to hit an all time low, at least one that I knew about. Stupid enough or sick enough, i don?t know which one it is or both but Jeffrey bragged about his birthday present from Brunei, once accepting three, twelve year old girls, sisters at that. He replayed the descriptive events with me telling me how they all massaged him and ?nished him off orally. He was so excited about the entire event, replaying over and over again over the next course of weeks how cute they were and how you could tell they were really young by the small amount of hair growth in their pubic region and non- existent breasts. A twelve year old, are you serious? I thought to myself. 1 still can?t shake the feeling of disgust when i recall the look on his face as he told me time and time again of how his lust brought him to that profound low. He went on to tell me how Brunei bought them in Paris, France, from their parents. Offering them the usual sums of money, visas, and modeling career prospects was a bribe of the worst kind, they were just children. Laughing the whole way through, Jeffrey thought it was 88 Copyright Protected Material CONFIDENTIAL Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page608 of 648 absolutely brilliant how easily money seduced all walks of or no one that couldn?t be bought in his eyes. Behind the two ofthem followed a destructive trail of those in their path that were misused, violated, degraded in a variety of ways for one to satisfy the desires ofthe perversion that rotted their hearts. The next couple of months I spent in Jeffrey?s company, my life was revolved around him and his petty happiness. Arising to the occasion, I was no longer his teenage sidekick, I was growing into being a young woman and my body was blossoming like never before. Out of the awkward stages of my life, I now took to looking after myself like never before. Regular sessions in tanning beds and keeping ?t became my life outside of Jeffrey. He kept telling me what a beautiful woman I was developing into and would offer suggestions to help me look good. Sending me to dentists for regular teeth whitening consultations or helping me choose my attire for the evening, he was ushering me into a whole new position, training me up for something else, but I was unsUre of what that was. Being a snotty little teenager was a girl ofthe past. Now I had to be his eloquent speaking, desirable to all and almost his personal porcelain doll. I went everywhere with him again, all of his eclectic dinner parties, conferences, and meetings with various members of parliament, famous celebrities, and other esteemed billionaires. . ,most of whom lived by the same rule of thumb as Jeffrey did. Quite an alarming realization having to accept this world the way it is. Jeffrey knew all ofthe right people in this game, and trading girls for favors is how he kept in the circle. He was at the center ofit all, blackmail being the only thing next to money with the ability to pull a many of strings, his conniving ulterior motive was to drag all that he could down to his pitiful state of mind. Inviting easily tempted acquaintances to his island or his other various residences he would bring out the assortment of young girls and pass them around like they were cocktails on a platter. No girl had a choice in whom they went with, only completing a task, we would have to charm and bedazzle these ageing fat men who other than paying for it would?ve never had a shot at getting to know a beautiful girl intimately. I personally belonging to Jeffrey rarely had to be loaned out and it was a big occasion, or should I say favor, ifI was. I?ll never really know what made me so important or special to Jeffrey, it definitely had nothing to do with love. I guess in the end I will always put it down to my capability of being whomever he wanted when he wanted, so compliant it just made it easy for him to have a personal toy at his constant disposallived in ajail with no bars, and in a country where slavery was supposedly abolished a long time ago but still existed right underneath everybody?s noses. Myself and so many other girls were walking proof of it. 89 GIUFFRE004222 I still was given proper training in massage therapy from time to time, keeping me from looking back at being a teenager with no responsibilities to being a young adult with prospering titles. He knew I wanted to be self- suf?cient so bad I would do anything for it and by giving me this dream to hold to only kept me in check. I looked forward to my training sessions, holding onto every word passed down to me and after the session was complete I would hurry back to my room and transfer the information into a workbook with associating exercises. Trying my new moves on Jeffrey always impressed him, he would get excited hearing about my passion for knowledge and would tell me he could see it transfer into my massages, always giving it my all, my hands were a focused energy when I was at work. Using every ounce of strength to apply on a body, many were astounded in what I could do for being such a small girl, and Jeffrey loved it, using me for a two-hour massage ?with benefits? sometimes being over twice a day. Ghislane would sometimes use me to massage her still but it wasn?t as common, she preferred a man for that job. Then would come the odd client here and there, of course set up by Jeffrey. Most of which were orchestrated to get beautiful girls comfortable and consequently naked then he would go in for the kill, so to speak, touching them intimately, in their most private of places like their vagina, breasts or anal. When he had us where he wanted, willing and able, then would come the toys, outfits and so on. A scheme he has used time and time again, telling those who know him well ?he had never been turned down yet?. It was starting to dawn on me how I wasn?t getting any clientele that weren?t used for Jeffrey?s bene?t and would make me wonder if I just wasn?t good enough for that, but I kept quiet, never wanting to make waves like I had before. To give me a break from it all as ifJeffrey didn?t want to overload me again, he would send me away to his ranch for a few days, what he knew I considered being a small slice of heaven on earth. l?d spend my days roaming the hills, riding horses, and enjoying the solitude ofmy own company. One afternoon Iwas out exploring the land on Jeffrey?s ranch which covered hundred?s of acres with nothing but a bottle of water, my sketchbook and a small case of oil paint. Iwas on the search for something interesting to paint. A great pastime of mine, it made my soul quiet by creating beauty with my brush. I loved to recreate the images I saw on paper. I would paint anything beautiful that caught me eyes interest, from underwater scenes, animals to people and even fruit, I loved vibrant colors and emotion on display but my favorite soon became the landscape of the Santa Fe?s rolling hills and green and beige tones and in certain light it would illuminate into a golden shine. To grasp that feeling I was absolved in at the hardest of times became my greatest inner? 90 Copyright Protected Material CONFIDENTIAL GlUlilillEUO-l-223 if Copyri Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page609 of 648 achievement, like taking a piece of that serenity and putting on paper for me to keep in my heart where it still is today, closing my eyes I am able to see it, being there anytime I need to. I was enjoying the heat and taking in the deserts sights when I stumbled off the track and into the wilderness. Exploring everything new to me was my second nature and never even entered my mind what would?ve happened ifI went too far or got lost. I would rather face Mother Nature?s wrath than humankind?s any day! After about an hour of drifting off track I came to a pile of rubble, looking like the remnants of an old pueblo made out of clay and rock. I picked up what looked like half ofa clay bowl and noted that it had Indian designs etched into the side ofit. Excited about my ?ndings I decided to do some more exploring around the ?elds surrounding the historic site. I collected rare pieces of arrowheads, utensils, and parts of many broken bowls with artwork telling tales of their own. Time was of no essence here and before I even realized the sun had sunk deeper into the hills leaving me without any light to ?nd my way back to the pathway. Feeling silly now after passing by a familiar looking boulder twice over, I was startled when I heard some poor animal become dinner for another, it?s screams of agony only ampli?ed louder and echoed in my ear drums, heightening the hairs on the back of my neck and making my heart beat nearly out of my chest. I was lost and confused before but now I was petri?ed with fear. Taking me over three hours to ?nd my way back to the path and in the direction of Jeffrey?s mansion was a mission, so relieved in the end and so were the housemaids after I hadn?t showed up for dinner, assuming I must?ve been out for one of my usual adventures. I went to bed strenuously exhausted that night and as was falling asleep the phone rang, it was a call from Jeffrey who had been alerted of my disappearance. ?What happened tonight, one of the maids called me to tell me you hadn?t come back from your walk this evening? Detecting a tone of anger in his voice I tried to distract him by telling him of my ?ndings and he scolded me for being gone for so long without anyone knowing where I was. Going back to the Indian remnants, I persisted on telling him whatI had found. In the end he was just worried about me becoming a liability, but had to make it sound as if he cared. Don?t worry Jeffrey, Iwon?t be doing that again. I can honestly say I have learned my lesson and the next time I want to explore I promise to take someone with me?. 1 satis?ed his worry of me being a future nuisance and with that I was ?nally able to tell him what I had discovered on my walk. He was impressed but did not sound surprised. ?You must?ve been gone a long time if you found the old Indian pueblo?s, just be careful you don?t say anything about where you found the stuff on my property, it 91 GIUFFRE004224 could become a sight for historical preservation and that means the government could ultimately own my land.? I acknowledged his request and told them they were just a gift for my Mom, who was in love with Indians ?Wait until she see?s I brought her back real artifacts, she is going to totally freak out.? He didn?t mind that I was taking them. In fact he admired my curiosity and adventurous spirit. He reminded me that tomorrow was my last day. I would be driven to the Albuquerque International Airport the day after next, to meet Jeffrey in New York, for how long, only he knew. Giving Jeffrey many thanks for a great week, letting him know how much I appreciated these small breaks away, we then said goodnight. Hanging up the phone I had caught my second wind and set out to the kitchen to ?nd a late-night snack. Raiding the fridge and pantry, I found some frozen pizzas and popcorn. I put on a movie and munched on the popcorn while the pizza cooked. Some 1980?s dreadful alien ?ick got the better of me that night. It was based on a true story about people abductions from extraterrestrial beings, which were, like I was, visiting a remote area. I suddenly hated being alone on a ranch in the middle of nowhere. I munched down my burnt, crunchy pizza and became further enveloped in the thick plot. Leaving on the TV and the lights on that night, I spent my night tossing and fuming, peeking through the small open crevices of the comforter, half expecting to see an alien being in my bedroom. Living through the night was a relief and I. laughed at myself in the morning, how spooked did I get? When I got to New York, Jeffrey, and Ghislane had a good laugh over my tale of survival in the wilderness and then the alien scare. ?Your always having the best adventures? Ghislane exclaimed. We were similar in that way, both being bit of free spirits it was really only her non-existence of moral standards that differentiated the two of us, in that way. ?How do you know you weren?t abducted and probed? I mean look at you and all that time alone on the ranch, what do you think Jeffrey, could she pass off as an alien?? Expectedly, Ghislane poked fun at me, her usual fun past time. Our relationship was an odd one, never threatened by each other but always precautious towards one another nonetheless able to crack ajoke together, but when it came time to ?Work? it was no fun and games, she was intensely serious. ?With a sense of humor like yours I would tend to think that you are the one from another planet.? Just friendly banter between the two of us, then Jeffrey had to jump in with his two bits, think you might be onto something Ghislane.? I squinted my eyes and gave them both an exaggerated death stare and pretended to grab my stomach in pain, think some things trying to get out ofme?, putting my ?st in my shirt to reenact a scene from Alien, I fell onto the couch and faked my death. knew it? Ghislane shouted andjumped on me to begin tickling me all over and we 92 fl Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page610 of 648 all broke out into laughter. It was those fun times that made me feel like we were all apart ofthis really perplexed family. We did everything together similar to normal families like eat dinner, watch TV, and travel it was only the hedonistic and corrupt side to these two deviates that made them a peculiar pair. Getting turned on at the two ofus playing together, Jeffrey came over to the couch we were on and pulled down his sweatpants revealing his erect manhood. All ofthe laughter stopped, now it was time for work. Pushing my head into his pubic region Ihad to give into his perverted wants. Ghislane started to undress me. Once I was bare she loved starting with my breasts. She cupped them in her hands and brushed her ?ngers over my hardened nipples heading downwards pressing her lips deeply into my skin, I had to maneuver my body on the couch in a complex position to give them both what they wanted. And just like that, without even a moment?s notice I could be put on the spot and have to amuse them in any way they wanted. A shameful way to make someone feel like a used toy, I wasn?t around for companionship I was there for one thing, I was a compliant piece of candy. Twenty minutes later and Jeffrey had erupted in pleasure. Ghislane sat up, still fuliy dressed, and wiped the sides ofher mouth with her hands, giving a vindictive little chuckle, ?That was fun.? Jeffrey concurred with a. sly grin arching his back for a stretch just looking able to utter the request ?Why don?t you come up with me upstairs for a steam bath and massage, I need to be loosened up after that?? It was more ofa statement than a request, as ifl had the choice to say ?No thanks, I?m actually tired myself and would love to just relax? instead I would reply with my accustomed trained obedience, ?No problem, when your ready lead the way.? I had to get dressed again being that we were in Ghislane?s downstairs of?ce. Putting my clothes back on, Ghislane thought she had buttered him up just where she wanted him to ask for him to come have a look at her new townhouse renovations when he was finished with his massage. A very strange relationship those two have, there?s a definite love flowing between them but not a passionate one, more like a respectful business, he gets what he wants. . .an uncountable number of girls and she gets what she wants, simple and sweet. . .an uncountable amount ofmoney. The two things in life that can create such beautiful moments or the most horrendously terrible ofthem all, is sex and money. Chapter 15 93 GIUFPRE004226 [joined him for a shower, steam bath and concluded his needs with a. massage while listening to classical music. I knew he didn?t want anything sexual from me now seeing he got what he already wanted downstairs, no this one was purely therapeutic. My favorite massages to give, making me feel like an actuai real therapist. I lathered him in aromatic oils and let my hands discover the ways to unlock the stresses that his body held. After the massage was concluded we were going downstairs to get ready to go see Ghislane?s townhouse as he had promised her earlier. He loved taking the hidden staircase while I hated it. I was so creeped out by his choice of decor, the blood red carpets, violent medieval paintings, and sculptures of the pagan god Pan, all of it representing the darker side of hedonism his lifestyle provoked. Spiraling down the hallway along with each step you took came with a pair of eyes that followed your every step. Brown, blue, green, hazel, all ofthe colors were there, staring at you the entire way down. As each step progressed, so would my anxiety to get out of there. We found Ghislane where we had left her, in her office. She hadjust received an order in, a satellite camera with a twelve-inch flat screen. She told us how it was used to pick up any person in any location with the quick insert of an address. Quite a powerful new toy I thought, but it was only a minute display of what the rich could afford, what use they would get out of it was another concern. Soon after she was done ?guring out the controls on the camera, we made a rare and first for me pit stop, the security room. What I thought was our way out by the front door was another hidden door. I was in shock as I was led into a room, so discreet that in three years I never even knew it existed. I kept my head down most of the time, knowing how secretive this must be being another door was an entire security base within his mansion. What I could see when I stole a glimpse here and there was an array of tiny screens, twenty odd or something. Small screens showing various rooms ofthe mansion I had recognized. The images were constantly changing so I found it hard to pinpoint an exact location but from the decor and short glimpses I suddenly knew from then on that my feelings ofmy every move being watched inside his corridors was now more than a possibility but was actually happening. Jeffrey spoke to an obese Spanish guy at the desk, whosejob was to disgustingly overlook all ofthe video feedback. Kill two birds with one stone Jeffrey thought, free porn to share with all of his pedophile friends and when the occasion called for it, a security system all at one expense. Ever consumed with making. money as well as saving it, Iwas again astonished at Jeffrey?s capabilities. I didn?t want to even think how deep the video in?ltrated, pretending like I never saw anything at all I put the memory to the back of my mind and went on about my day. Stopping at Ghislane?s new townhouse, another gift bought and paid 94 l} Copyright Protected Material Copyright Protected Material CONFIDENTLAL II Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page611 of 648 for by Jeffrey, he pointed out needed changes all over the place, driving the builders mad, as always. He wanted the place to scream out with a bold statement. Checkered ?oors and bold colors was the theme, like the queen of hearts from Alice in Wonderland, very well suited I thought. The dust from the walls being torn down chocked my throat and the elevator was not in use, the stairs were hardly either. The whole house was in bad shape then having to go up three ?ights of rickety steps was a bit of a risk too but worth it once you made it to her future walk in wardrobe or to us commoners, a closet the size of a small a house. Complete with a dressing room, luxurious bathroom and plenty of storage for her every ensemble. Even without it being ?nished it was already a work of art, a sanctuary for any woman. She adorned herselfin her future home, ?nally her own, relishing every inch ofit, she already put in a work desk and spoke constantly ofits ongoing renovations. About an hour later we were off to pick out curtains and look at some paint samples at a couple different boutique looking shops-Easily passing off as an ordinary couple for the day, they walked arm in arm strolling the streets ofthe Upper East Side. Except to me, still replaying the early afternoon?s events, shaking my head over the echoed images in my mind, I followed behindjust waiting to be needed again. Over the course ofthe next few months was a constant in?ux of exorbitant excursions at Jeffrey?s mansions, mainly to his island, to keep up with his ever-demanding sexual appetite with various young women and teenage girls. I got back on the Xanax, an old habit that I felt at the time would stop my memories from ?owing back, rehabilitate my problems and relax me enough to deal with any situation at hand, no matter what the circumstance revealed itselfto be. It was a drug that would blind my eyes to everything I should?ve been running from. Having Brunel always in the picture these days wasn?t helping me at all either. Sending his girls for Jeffrey at all ofhis places now and at a vigorous ?ow, they had an abundance of girls at their disposal. Ifl were to count one girl for everyday of the week, it would be the underestimated statement of the century. So many girls between the two of them, some nights it would be a free for all frenzy for Jeffrey and Brunel, seven or so girls giving them their upmost attention, doting on their every moan and whimper, Jeffrey being the main concern since Brunel worked for him and we were all aware of that too. If there were heaven on earth for men like Jeffrey, than he would be their God. Every one of his inner most desires was ful?lled when his harem of women was around. No wonder he didn?t travel much abroad these days, all he ever wanted was right at his doorstep. I couldn?t believe that he was still asking me to bring girls to him as well. There was never enough girls to 95 IUFFRE 004228 ?ll his appetite, so on occasion I would meet a pretty girl around my age and invite her back to his place to make some quick money by offering her a really good contact in the modeling and acting business. Keeping him satisfied and inneed of me was a tiringjob. With so much competition I had to be on the ball, seeming ambitions to grant him all of his desires. It was a lot of pressure and a spotlight of a role to undertake at such a young age but I told myself this is what my life?s training had led me up to be. My Birthday was around the corner and turning eighteen had lost all of its sparkle and pizzazz. There were no more surprises in store for me, nothing that would bedazzle me I hadn?t done already. I spent my birthday on the island, having a quiet dinner and watching ?Sex and the City? on the couch with Jeffrey, Ghislane and Emmy. There was no cake or a celebration of any sort but I did get a couple ofpresents that I opened outside underneath the main cabana. Jeffrey gave me a beautiful pair of sapphire and diamond encrusted earrings and Ghislane bought me another designer makeup case. I thanked the two of them with a tight squeeze and a gratuitous short spiel. As it went quiet, I looked out to the ocean and wondered if across these waters was there ever going to be happier days spent with someone special to me. Would he be kind, compassionate, and always be there when I needed him most? Or would I end up settling for my ?nal bit oftraining, a marriage to a greedy old scrooge? Either way what I wanted most didn?t matter right now, I was still bound by Jeffrey?s hold over me and all I had to keep telling myselfto get through this epic journey was, this is just the way it was for now. Around the table for breakfast Jeffrey announced that he was expecting a few guests coming over with Brunel, no one ofimportance, just his usual entourage of beautiful girls, Russian models this time and Jeffrey was also having a photographer ?own in to take modeling photos using the island as the perfect background for a sexy shoot. All of us girls were ushered onto rocks, hammocks, dug into sand and displayed just about anywhere they wanted. We were being photographed in next to nothing, like a netted fabric placed over us if the shot called for it, but the more provocative the more Jeffrey and Brunel loved it. After the photo shoot we did some outdoor watersports. While us girls raced thejet skis around andjumped on the water trampoline, the men stayed on dry land to watch us from the beach. I was so used to this constant Charade of girls and I didn?t mind having a bit of fun but this was different, I had to be more than just polite because I already knew it wouldn?t be long before we were all intimate with each other as well. Being the only girl that spoke English out of all of them was also a huge blunder, The only way we could communicate was through hand gestures 96 Copyright Protected Material CONFIDENTIAL Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page612 of 648 and body language, a very primitive form of speaking, but what choice did we have? I did my best to get acquainted and as I had previously assumed after lunch on the beach we were again ushered into another part ofthe island, Jeffrey?s cabana. There was no need for words here, as the girls already knew exactly what to do. Without saying anything they undressed me and began to ravage my body with their hands, tongues, lips and ?ngers. I was delirious, never having done anything like this before with so many girls. It was sheer chaos; I don?t honestly know how men could fantasize over this. Through the glimpses in between bodies crossing over me I could see Jeffrey and Brunel watching us, sitting in a chair with their hands around their penises, stroking themselves together ?The best part is they don?t even speak English so there?s never a need to have to keep them amused? I could hear one of the men divulge and pretty sure it came from Jeffrey laughing out loud to Brunel. ljust closed my eyes and went somewhere else in my mind until it was all over. That was that, life went on and we all moved on to eat dinner together. It couldn?t be more awkward as .ieffrey and Brunel were beside themselves with their ego?s beaming, and the girls chatted like busy little chipmunks with each other. Ghislane and Emmy on the other end of the table were being amused at the entire racquet around the table and then there was me. Sitting quietly and smiling in people?s direction when needed, was counting down the minutes until I could go lay down in my giant comfortable bed, slipping away to the gentle noises the island created and sink comfortably into a deep sleep with the assistance of my Xanax. Scratching at the plate in front of me with my fork out of boredom, Iwasn?t even hungry. I had lost my appetite for food. Rather sipping on the champagne I wanted to feel as far away from here as possible. What seemed like hours for everyone to ?nish their meals we were finally all saying goodnight and goodbye to each other, as Brunei was off early in the morning and taking the eight beauties with him. ?Thank God? I told myself, once was more than I could handle ofthat in one day. It didn?t take me long to get back into my own comfort zone. Heading straight back to my cabana after dessert was served nearly tripping over my own two feet as I tried to scuttle off in a hurry. As soon as I entered my domain, I drew a breath and sighed a deep exhale outwards, ?nally alone and at for now at least. Although the sun had set hours ago the high temperatures of the Caribbean were still an af?iction, plaguing my cabana was welcomed by a rush of warm air as I opened the door. I hit the switch to the fan and stripped down for a shower. Preparing my towel and toiletries I opened the back door to the outside shower and placed them on the ?oor. Whether I was cleaning up in the midst of a hot 97 GIUPFREOMZSO day or retiring for the evening, an outside shower was always splendid. Under a thick dark cloak of the night sky only the moon and stars to shed enough light for me to see my way around. I could feel the soft breeze lick the droplets falling off ot?my bodies? curves in the reflection of the moonlight. It only encouraged me to stay lenger under the warmth from the spray of rushing water. I let the hot water run out before I was sufficed enough to go back inside. Lounging around the bed in my panties and a tank top I was still sweltering from the heat. Trying to tire myself out, 1 did some reading and eventually fell asleep. I needed those times to unwind after such an ordeal, letting the Xanax wash away all of the pain 1 could then forgive the mistakes 1 had made, blaming myself for staying around for this 1 had wished I was never born at all. The pills would take all of that away for me. My heart was a tangled weave of deception and pain, only reassured by the lies that were told to me and the lies I would have to convince myself of. Chapter 16 When we flew back into Palm Beach, Juan drove me back to my apartment. Lonely for some companionship I decided to call an old friend. I was longing to be important to someone and unfortunately with such little time to have a social life of my own I was compelled to call T.J again. His Mom answered the phone and sounded quite surprised to hear my voice on the other end. She was always kind to me, 1 even used to bring her back ?Cola? cans from other countries a bizarre hobby she loved collecting. Shejust didn?t know whatl saw in her son, even saying that to his face many times over. Not blind to his ways of cheating and stealing, being a personal victim of it, she made it apparent that she did not approve of choice in lifestyle. It used to really hurt him how his parents thought so badly of him, so he gave up trying to earn their love a long time ago. As long as he didn?t steal from them anymore he was allowed to live there. Instead of that being a lesson to him, he would just try to be more clever in what he would steal, less obvious things. He would steal the toaster and sell it for five dollars if he knew it would help to get him his next high. Nonetheless and at my expense I had a sweet spot for him. With enough water under the bridge, I was able to forget about the troubles he caused. His Mom told me she?d pass on the message when he got home, but that could be days from now. The last time he had been home was over a couple of weeks now. He only stopped by to get something to eat, have a long sleep and to beg her for a few bucks, supposedly to help him buy food. Then he was off again without a single word said, only leaving 98 fl Copyright Protected Material CONFIDENTIAL Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page613 of 648 his parents to their own assumptions, which were pretty much correct anyways. I then called around a couple of mutual friends to see if anyone had heard from him. Everyone I spoke to pointed their ?ngers in the same direction and the worst place possible, Ritchie?s house. One of his best friends told me ofhow bad he was doing, ?He?s not the same guy anymore, and all he cares about is the next high he gets. If we don?t get anything for him he just loses it and goes off somewhere.? It was hard to hear how badly affected my best friend was and a part of me secretly hoped they weren?t right. Still defending him, I told everyone I had spoke too while trying to ?nd him that would be ?ne, he?sjust probably going through a bad phase, like we all do sometimes and needs people to have his back more than ever now. I was pretty much laughed at on the spot, most peopie that I considered my friends at the time were only friends by association. As long as we all looked the part, acted the part, and could handle the part, only then did they want to be around us. The last person I called was the last person I had hoped he wasn?t with and it turned out that everyone was right. He was with one of the biggest Coke dealers in our area, Ritchie-Rich, as everyone used to call him. He didn?t look like a typical strung out junkie or dealer. Instead he looked like your average preppy college grad with aspiring propositions. He dressed well and acted like a nice guy to imminent clients only to get them hooked on his drugs and then turns them out onto the streets. He was a businessman and his business was thriving. He carried everything from most drugs to guns and knives. Having ears in all places made him a dangerous acquaintance. Using kids off the local Palm Beach streets to run his dirty errands and the errands of the others above him, he made his money by using these teenagers, who as hard as it was to believe was once somebodies sweet child. I knew TJ didn?t have the ?nances to support himself or his drug habit so the likelihood ofltim being indebted to Ritchie in other ways was a safe assumption. Obtaining Ritchie?s number from one of friends Marcus he asked me, ?What do you want to call Ritchie for? Come over to my place and I can get you whatever you want? Marcus was a sleaze bag who would tirelessly continue to try to appeal to my lesser sense of judgment, never getting the hint or just not caring that I could never and would never be interested in him. ?No Thanks Marcus, can Ijust get the number please, it?s very important that I get ahold of TI, I?m really worried about him.? I hated having to call this guy let alone have to ask him for something. ?Is this about the Adam bullshit? Cause if it is you can let him know what a fucking bitch he is for not showing up to be there for him, you can tell him from me that it?s his fault and it should?ve been him that?s lying in the morgue now, not Adam? I was totally thrown 99 GIUFFREO 04232 by his allegations I could only mutter out a whisper ?Did you just say that Adam is dead, what happened?? ?Oh snaps, I thought you knew, where have you been girl, under a rock or something?? Marcus was less than sensitive about his statements. ?He got shot in the head by two black guys who got suspicious when their usual supplier didn?t show up, your boy TJ was so fucked up he didn?t even remember to tum up at Ritchie?s for the delivery, so Ritchie sent Adam alone and now he?s dead." Adam was a sweet kid who just happened to be born living on the. wrong block. Best friends with TI since childhood, the two were inseparable until puberty hit and even then they would chase girls together. Adam followed in every footstep, mimicking his shadow, if jumped off the Eifel Tower then so would Adam so when got hooked on drugs consequently Adam did too, leading ultimately to his death Wanting to end the conversation with Marcus quickly I scribbled down the phone number on a blank piece of paper in front of me and hung up the phone to call Ritchie?s place immediately. ?Yeah?? It was Ritchie whom bluntly answered the phone after the first ring. ?Hi ?Uh- Rich, It?s Jenna, ex, we meta couple oftimes at a few parties? Iwas trying to remind him of who I was knowing how paranoid he was about people having his number. ?Oh yeah, I know who you are, what is it you want?? He answered with a dry tone. was hoping you could tell me where I could ?nd TJ, I?ve heard some stuff and am really worried about him, is he alright?? Ritchie snickered at my concerns. ?What are you his Mom or something? He?s ?ne, he should be back here around ?ve o?clock, I?ll tell him you called.? In the middle of me saying ?Thanks and good?bye? he hung up the phone, as there is no room for manners in his line of work. I waited until five o?clock watching the minutes on the clock tick past and when ?ve o?clock came and passed by with still no phone call, I couldn?t deny to myself that I wasn?t stricken with distress. Falling asleep wasn?t easy either. I ended up crashing out on my sofa watching TV, half expecting to hear of another murder on the news and it being T.J. Forgetting to put on my mask before 1 went to bed, I was woken up the next morning by rays of the sun beaming into my living room. When I sleep I am a creature of darkness, avoiding any window light at all costs. Staggering to the coffee pot not used to getting up this early, my ?rst thought that day was and why he hadn?t called. A million thoughts rushed through my head like a steam he 0k? Is he not calling because he is still mad from our last breakup? Has he moved on to someone else? Is he in any trouble? Did Ritchie even pass on my message? The thoughts were an endless in?iction, consuming my entire day. 100 Ll Copyright Protected Material CONFIDENTIAL GlUlil?le004233 I Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page614 of 648 Until ?nally he called my cell phone later in the afternoon, relief swept over me when I heard his voice on the other end. ?Thank God you called, I have been so worried about you, are you alright?? Ijumped in without letting him get past saying ?Hello?. ?Yeah, I?m ?ne. Ritchie told me you called his house looking for me yesterday and gave me shit for it saying you were upset or something, what?s up?? I knew I would have to be delicate about asking what happened to Adam, thinking he?d be a mess over it. heard from Marcus that something happened to Adam and I got worried about you, what is going on?? T.J sounded scared, for what reasons were beyond my knowledge but I was going to find out, he replied I don?t want to talk about it over the phone. Are you in town so we can meet up or something?? It was obvious I wanted him to know that was more than willing to lend my shoulder for his problems. ?I?m home now if you want to come over whenever you feel like it.? He didn?t hesitate in taking me up on the offer. But I won?t be able to get there until later, I?m downtown at Ritchie?s place unless you want to come pick me up.? It was more ofa request than a favor to myself which is what he was making it out to sound like, knowing him all to well I didn?t make a fuss ofhis ill-contemplated attributes. I got the address off him and made my way into the ugliness of the not so dazzling parts of the Palm Beaches downtown area. Rolling up my windows and locking the doors to my truck I nervously drove through the rough streets trying to ?nd Ritchie?s apartment complex. Knowing ail too well the history of the not a place a lone white girl in a nice truck wants to be seen, many reports of the locals rushing up to a vehicles with a weapon demanding money, cars, or just angry and out to hurt someone. I was speeding through the streets wanting to get out ofthere as quick as I could. A sad world we live in with so much hurt everywhere you look and nobody wanting to do anything about it, just accepting the hopelessness of never being able to achieve anything more than what our civilization has succumbed to. Being among one of those people, we were similar in so many ways. Only separated by our own personal fears and the different direction they pulled us into. I drove straight through the open gates at the entrance to the complex and parked on the gutter in front of Ritchie?s block of units. A crowd of people stood outside the blocks I was entering. Being hit on and offered drugs simultaneously my cheeks went ?ush and Iput my head down not saying a word. Walking up the corridors of the staircase looked like a scene out of a horror ?ick. Graf?ti covered the peeling of green paint on the walls and the pungent stench of something rotting, only to the worst of my imagination, ?lled my nostrils. I could hear babies screaming through the thin walls and trying to ?nd the unit number was difficult from the sporadic ?ickering of the ?uorescent lights above me. At last I found Ritchie?s one, quite astonished with myself that I even made it this far. I had to knock loudly on the door a few times before a young girl answered the door with eyeliner bleeding down from her eyes, herjet black hair was out and a mess and she looked off her face on some hard drug. She had only her bra and a short skirt on to cover her private areas and a cigarette hung out of her mouth to complete the full picture of terrible state she was in. She looked me down with contempt and snubbed at me ?What do you want?? I maintained my politeness and told her T.J was expecting me. She opened the door and walked away, leaving me by myseifto venture through looking for TJ. Passing through the kitchen it looked like a hospital lab with syringes on the counter tops and medicine containers lying around everywhere. Minding my steps through the dirty house, I walked to the back to the living room and found TJ in a K-Hole strung out on a filthy couch. he acknowledged me with a giant smile spread across his face. He probably didn?t even know who I was from the dreadful state he was in. My ?rst look at him in months and I was in utter shock. My jaw must have dropped to the ?oor at the very sight of him. Never seeing him so skinny and unhealthy looking I took pity and wanted to help him before things got even worse and he ended up like Adam, dead. hey buddy its Jenna, remember I was coming to pick you up today. You don?t look so good, what are you doing so messed up?? I don?t think he could even understand what I was even saying because he could only reply by giggling and rolling over, patting the couch as ifit were a fluffy animal. I stood over him now and raised my voice so he?d know I was serious and snap out ofit a bit. ?Get Up Now!? I ushered at him to get off the couch, repeating myselfa few times over and with no response I knew I had to get physical. Rolling him back over to face me again I smacked his face hard and I?m sure it stung but I got the reaction I had wanted. He sat up and looked at me confused. At least now he was able to focus on my words requesting him to come with me. He was getting up from the couch and stumbling around before falling down to the ?oor again. Putting his arm around my neck and carrying the majority of his weight, I helped him up many times over and down three ?ights of stairs into my truck and drove him back to my place. It was a triumph on it?s own arriving downstairs in one piece. Being the only person who really cared ifTJ lived or died I felt like the responsibility of helping him was my concern alone. Thankfully Jeffrey was in Palm Beach for the next couple weeks entertaining royalty, which gave me a little time to try and clean TJ up. called a few of his friends that I knew and asked them not to score any 102 Copyright Protected Material CONFIDENTIAL UlUl?l?lUi004235 ll Copyrinhl Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page615 of 648 drugs for him any more, pleading with them and telling all of them he was on the brink of death, reminding them of the friendship between us all that once existed before the drugs corrupted so many of us. Some of them laughed at me telling me I was wasting my time with T.J and others were nice enough to at least lie to my face politely and promise not to help him feed his addiction. Ijust wanted to remedy all of his pain and problems but I felt so helpless fighting his battle against the streets, I bought some marijuana for him to smoke hoping to subside the withdrawals he was facing over the next few days but with no avail. The only thing that would help him was my Xanax, a few of those pills and he would go back to sleep, only waking up to get more ofthem. I would have to force him out ofbed to have a shower once a day and make sure he ate something. He was more like a baby right now than he was a boyfriend, too much in need of something I couldn?t give. Chapter 17 When I went to see Jeffrey over the next course of days he picked out the dilemma I wore spread across my face straight away. ?Your back with T.J aren?t you? It was so funny that he knew me so well. ?Yeah, he?s in a real bad place in his life right now and needs my help.? He looked astonished and replied, ?You?re a much better friend than I am, I know people like him and trust me they never change, no use in even trying? I believed him too knowing I was stupid for even attempting to change T.J, but my heart felt differently, he was still a human being and a good friend of minejust down at his worst. ?That?s what good friends are for? I laughed back at his remark, not wanting to take this conversation too much further. I admire your loyalty at least, but take my word for it, he will hurt you again." His words were chilling but true, I had to find out for myselfthough. Almost seeming like an actual friend for a second he mined his brief momentary image by tuming over from the unfinished massage that I was giving to him and acquired his sexual longings from my worn. down soul. Not only did he know that I didn?t want to endure any more demands tonight, but his energy enhanced from knowing it too. Looking up at him during the foreplay, it was an easy observation from the look in my eyes 103 GIUF 1*?Rl3004236 that I hated every minute ofit, seething through all of my duties until he climaxed. Most days I could take this kind oftreatment, it was only seldom I couldn?t hold in the way Jeffrey disregarded my feelings. He had me just where he wanted me, like a pawn piece on a checkers board I was his own personal sex slave. For the remainder of the evening I stayed quiet, not sure of what to say after an episode like that. It was a vigorous display of how calumniating he could really be. He required me to clean up his spilled semen off ofhis genitals with a wet warm washcloth before he retired to his bedroom for a good night?s sleep. Only a monstrous creep could sleep easy at night knowing what pain he caused others. I went downstairs and asked Juan, who was still in the kitchen to pay me for the evening telling him that Jeffrey had gone to sleep for the night. It wasn?t an unusual request. Juan would often have to fix up ?the girls? after the sessions and sometimes even drive them home. He went to Jeffrey?s desk and underneath was his duffel bag that always held insurmountable bundles of crisp hundred dollar bills. He took out two for me and handed them over. I thanked him and said goodnight, as I was always polite to Juan and his wife, Maria. His eyes were gentle and told me more than what he was allowed to say. Iunderstood well. We all needed to eat and pay bills unfortunately even sometimes at our ow moral expense. . Putting the keys into the ignition I started up the engine and reversed out of Jeffrey?s driveway with promptness. I didn?t want to be there a moment llonger than I had to. Not much to look forward too getting back to my apartment either, I needed some time to ?lter my emotions. Parking my truck in front ofa nearby beach I took my shoes offgradually stepping out of the door into the fog. walked down to the edge of the sand where the water licked at my toes. My life was slipping away from me and I was really beginning to question the difference between living and dying. I was so tired of everything, my whole existence revolved around being everything to everyone, forgetting about being something for myself altogether. Pretending to be someone else became an attribute I was better than good at, probably much of why Jeffrey liked me in the first place. This time I held back my tears back and only let the anger fester into a deep pit in my stomach. My rage was aimed at the very people who abandoned me to fend for myself in the first place and accepted this life as normal for me, my parents. When Igot back to my apartment I was expecting to have to look after T.J, but to my surprise he had come around good that night. He greeted me at the door and asked how my evening was. ?It was all fine? I easily lied. I never let anyone inside close enough to see my vulnerabilities. They were mine alone to battle. In my head they were too shameful to Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Pag6616 of 648 talk about anyways. He wanted to talk about something else anyways. Sitting me down at the dining room table he began his spiel. know you don?t think much of me anymore, how could you? I?m ajunkie who steals and sells drugs for a living, but I promise that?s all going to change now. Adam is dead because of meand the only way I can make it up to him? is to get away from it all. I promise things are going to get better.? It was a convincing talk, butI knew him all too well. His demon inside yearned for him to fail but who was I to second-guess him out loud, I could only try to give him hope. ?No one is perfect T.J. At least you?re trying now and that?s all that matters to me. I am so proud of you.? I gave him a sincere hug and kissed him for the first time in a long time. love you,? he said to me and I returned my love back. We slept in the same bed together that night and were of?cially back on together. Two days later I was gone again, beckoned to be in Santa Fe. Ghislane only told me that I was to meet someone there, not sure of whom that was. It wasn?t my place to ask questions. As far as I knew it could be anyone and I had no choice but to be compliant to their needs. It was the middle of the day when I arrived at the airport. One of the ranch hands came to pick me up in a. big work truck that smelled like dirt and sweat but I didn?t mind that?s what I loved about the When we arrived at the mansion my guest was already there waiting for me. I couldn?t wipe the look off my face as he turned around from the bookshelfthat he was standing at. ?Hello? that same old cheesy grin greeted me once again. It was his highness Prince Andrew, and what a sight. He wrapped his arms around my waist and greeted me like an old friend. I hugged him back rolling my eyes at the same time, already dreading what lay in store over the next couple of days. My job was to entertain him endlessly, whether that meant having to bestow him my body during an erotic massage or simply take him horseback riding. For the next couple of days he was to be my only concern, but he wasn?t. I called in checking on a few times a. day, not wanting to be a nag but just hoping he hadn?t had any thoughts about relapsing. He was doing great, even applying for a couplejobs. Being reassured by him made my time away less complicated and thankfully with the help of my ever- ready Xanax I was able to cope with the ordeal. The mansion was completely empty save a couple of maids who also cooked our dinners for us, and a couple bodyguards that we hardly even saw at all. The time dragged by slowly for me as I was counting down the hours until I ?ew away again, anywhere but here I thought. It wasn?t easy meeting the sexual desires of these strange men, the Prince being one of them. He loved my feet and even licked in between my toes. Then there was the lack of passion in the intimacy we shared, to him I wasjust another girl and to me he was just another job. Not the right reasons to be 105 together but I thought in this world and to these monsters, there didn?t need to be a reason. To them it?s nothing but a reenactment of their personal fantasies. To me it was a living nightmare. Thankfully one of Jeffrey?s assistants from New York called me on my cell phone early in the morning on the second day to fill me in on my next adventure. I had a ?ight booked for me to leave that afternoon to arrive at La Guardia airport in the evening. Even though I had to go back to yet another controlling man, I was still relieved. At least I was used to the con?nements of Jeffrey?s control and in some twisted way he was more comforting than these strangers he sent me to. Overlooking the city of New York as the plane landed felt like I was flying from one cage to another. Entrapped by falling victim to the predators that lured me into their enclosure. I didn?t know how I would ever get out again. That deep pit in my stomach began to churn again, a physical reaction to the anxiety I was plagued with. Before getting off the plane I touched up my make- up to hide any signs ofthe frailty I was feeling. Jo?Jo met me at the arrival terminal and picked up my luggage for me. He never said much at all, nodding to any reciprocating conversation. I don?t think he could really speak that good of English anyways. It was better for me as I preferred the quietness for the moment. He opened the back door for me and we headed off for my next prison cell. When we got to Jeffrey?s mansion on the place looked empty. I walked up the staircase to Jeffrey?s office and he wasn?t there. Feeling a bit hungry I walked back down to where the kitchen was. I opened the fridge and found some leftovers that Adam, Jeffrey?s chef, had cooked. I loved his cooking, when it wasn?t ?lled with beansprouts and tofu. He used to make me the best pizza upon request, or whenever he was cooking seafood, which he knew Ihated. He had an honest appeal about him and never even took notice when on many occasions us girls would be prancing around topless, sometimes even stark naked around the pool or beach. He would have to serve us our meals and would do it with such a casual professionalism, never making anyone uneasy at any occasion. Half way through my meal the kitchen doors swung open and incoming was Jeffrey and Ghislane. Choking down my bite of food down, I got up from my seat and kissed them both on the cheeks. Hi guys, how are y0u?? I greeted them and Ghislane answered for them both ?Good, good. Sit down and finish your meal, don?t let us interrupt you.? I hated eating alone in front of people, chewing food and maintaining a conversation at the same time didn?t give off the best look. was just finishing anyways, can I get you guys anything, maybe a tea or something?? Always playing my part, another reason to keep me around I guess, Iwent beyond the call of duty and after the last period with them, I had been reminded of my place. ?Yes, I?ll take a one? Ghislane stated. ?Jeffrey how about you, 106 Copyright Protected Material CONFIDENTIAL ?3 Copyright Protected Material GIUFFILE004233 CONFIDENTIAL Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page617 of 648 anything I can get for you?? I asked again and he answered, ?No thanks, we just ate and I?m still full? and they sat down together on the stools at the kitchen bench. I got out the shiny red kettle from the cupboard, knowing my way all too well around the kitchen and put it over the hot stove plate. Turning around to face them, I thought they were acting peculiar. ?So. . .?Ghislane started the conversation, ?How was the ranch with the Prince?? It was a natural reaction for me to blush, knowing exactly what she was referring too. Keeping busy preparing her cup of tea and avoiding contact with both of them I started to unpack the counter where I had been eating, think he had a really good time, he seemed relaxed during the trip and when we said good-bye to each other he gave me a kiss.? I went on to tell them what we did together took him horseback riding, nowhere to far just around the property, we went swimming in the pool, and of course I gave him plenty of massages. He had a massage at least couple times each day really seeming to enjoy his time there.? It?s what they wanted to hear, not the truth ofhow disgusting I had felt over the whole thing but they already knew the truth anyways, it?s what they had trained me for in the first place. Like two proud parents they both looked over me with such content. ?Good, you did really well? Jeffrey complimented me. Tuming around to the boiling kettle, I ?nished Ghislane?s tea for her and the conversation led on to other subjects. We all ventured up to Jeffrey?s office and out came the infamous duffle bag that went wherever he did. I was given close to a thousand dollars for my time in Santa Fe, more than what I thought anybody at my young age could make for a couple days of work. It was fulfilling the obscene vulgar needs of the so-called privileged that earned me so much. Chapter 18 I spent the next few days in New York, venturing out to do some shopping therapy. I loved the eccentric parts of the city. Every street was different but the same energetic vibe ?lled all of them, animated with all different walks oflife. Hanging out at coffee shops reading the newspaper or a good book was a favorite pastime while in the big apple. Being close enough to get back to Jeffrey for when he needed me but also far enough to get away from all of it. Most of the day slipped by without being missed and I made my way back to Jeffrey?s. Making one last pit stop, Iwalked into an old bookshop to browse at their assortment of old titles. I wasn?t in any hurry so Itook my time 107 GIU FFREO 04240 reading the backs ofinteresting looking books. I bumped into a girl looking down the same aisle I was down. ?Sorry, I?m so clumsy? she was apologizing for my mistake. ?No, no, it wasmy fault, I wasn?t looking at where Iwas going. I get so wrapped up with my nose in a book and trip over my own two feet if I?m not careful enough." We were both giggling now and I further introduced myselfto her. Her name was Valerie or Vickie or something like that, anyways she was a student at a school for hairdressing nearby. Chatting away both young and similar interests in each other?s choice of reading we found it easy to speak with one another. She wasn?t from around here only being in the city for the last two months, her parents hated her being here, but were also supportive in her big decision to move from the in hopes ofher accomplishing her own dreams. Aside from not having her near them, they just wanted her to be happy and supported in her big decision to move to the city, helping her pay some ofthe way. She was a pretty girl with cherry red hair and soft white skin. Her long legs were emphasized by the short flowery dress that complimented her hourglass figure. She would definitely fit the pro quo for going down in one ofJeffrey?s little black books. Only imagining the look on his face upon meeting her I could already see his sly grin spread from ear to ear. Knowing exactly what he would do with her and the very thought ofhim tarnishing a sweet country girl such as herjust couldn?t be done. It was the beginning ofa turning point in my life that started with realizing I had a choice at hand and the effect I could have on one person alone. must be off, but it was really nice to meet you.? Bidding her goodnight and paying for my books I turned around with one last glance over my shoulder and said. ?Good luck in the city!? Leaving that bookshop was a small step in a growing abundance of larger strides to come. Turning the corner onto 72?d street I had an undeniable feeling in the pit of my stomach again but this time it wasn?t the familiar hurl of anxiety I was used too after I had done something I had wrong that I had regretted, it was a new feeling of pride and inner strength. I quite liked it a lot, I held my head high and smiled on the inside when Jeffrey asked me how my day was and what I got up to, not mentioning I had let one girl slip on bye. The icy winter winds faded away making way for the approaching sunny days that blossomed the colorful shades of spring. This was my favorite time of the year. Making the most use of his island we spent countless days of the increasingly hot days there. A constant array of visiting guests and plentiful young women to flock around keeping them entertained was the typical lazy afternoon on Little St. Jeff?s. We ate, drank, and played under the blue blanket of cloudless skies. To many this lifestyle could seem idyllic, unless you were like me, the one on the other 108 [1 Copyright Protected Material CONFIDENTIAL GIUFliRliOUJvlr-ll [l Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page618 of 648 side of the fence where the grass wasn?t so green. Fortunately for me and in some ways not, I was mostly expected to attend to only Jeffrey?s insurmountable of sexual desires. Whereas the other girls who came one day and went the next were promised a multitude of open doorsjust for there meager participation in sexual acts with random men, only to be disappointed when they realized they were nothing more than a single night out for these geriatric senior citizens who most likely due Alzheimer?s would sooner forget the entire experience let alone their ?rst name. Surrounded by those in our world who many looked up too but not seeing them from where I was standing, I didn?t have the highest of standards in humanity. Then I met Al Gore and his lovely wife during one ofthose many weekends away in the Caribbean. 1 was blown away by the amount of attention Al doted on his wife, it was so sweet to watch. They sat next to each other at the dinner table gazing into one another?s eyes having an intimate conversation between them. Among the many guests visiting that night and many ofthem young beauti?tl women, not once did Al?s eye?s stray elsewhere, to them they were the only ones there. He was up for a presidential election that year and he de?nitely had my vote. Anyone that could show that much devotion and passion towards his loved ones could have the same devotion towards running a country, or at least I thought so. He only left his wife?s side to have a walk down to the beach with the host of the weekend, Jeffrey. The weather was still warm in the evening when I decided to break away from the idle chat around the table and take a stroll too. Not wanting to interrupt the conversation between Jeffrey and Al, I walked in the opposite direction plucking the washed up sea shells imbedded in the sand along the way. I enjoyed the serenity in the solitude of the island. So many nooks and crannies to get lost in, I could imagine that I actually disappeared from the entire world for a moment. By the time I came back to the main house majority ofthe small crowd had been long gone retired to their cabanas. Even Jeffrey had gone off to bed but trust party animal Ghislane to still be up entertaining the remaining guests left at the table, regaling her wild stories of people and places she has embarked on. Trying not to make contact as I walked past them on my way back to my cabana carrying my seashells inside my curled up blouse, I wasn?t up for anymore pointless talking tonight. Emptying out my seashells into a plastic bag, I went over my new treasures one by one. I loved collecting odd things, shells being one of my favorites. Ghislane and I shared that interest together. We would enjoy walk abouts around the island searching for lost pieces of the remnants that pirate?s had left behind centuries ago. It was mostly broken plates or smashed glass from bottles of ale, and even occasionally getting lucky GIUFFILE004242 enough to find some old coins here and there. It wasn?t easy though, both loving a challenge it was perfect for us. Enduring many scratches from the bushes we would be searching through and then the soar arms from digging all day, but it was worth it in the end. After nearly two years of collecting items and saving them, we made Jeffrey a mosaic table out of the remaining pieces left from the era of the pirates day. Upon completing it we were both astounded in our creation, it was such an item of rarity and an interesting piece of work. When we presented it to Jeffrey he was even impressed not only in our amazing finds but what we did with them. The table became an important work ofart that Jeffrey showed off inside the main house?s lounge room, sparking a much intrigue and table conversation by many of the visiting guests to his island. The next morning was good-bye for most of the visitors, leavingjust the uSual behind. Soaking in the sun and living it up in the lap of luxury is how the next few weeks were spent before having to get back to the dredge of the city. Sometimes we?d have to go to St. Johns island for Jeffrey to do some work in the office. It was so boring for me to sit in their listening to him on the phone or coming down on some poor employee for something stupid like not answering the phone correctly. If I knew he was going to be awhile I would excuse myself for a bit of shopping. Not that the Caribbean had much to offer in the world of fashion but there was never an amount of bikinis one girl could own and loved all the little knick knacks one could ?nd there. Flying back on a privatejet was the best part because I could transport just about anything I wanted back to my apartment, which was already filled with an assortment from my shopping ventures and collection of seashells from the Caribbean. The next big dinner party on the island had another significant guest appearance being, the one and only, Bill Clinton. He is the only president in the world to be dismissed from his role as a world leader because he was caught with his trousers around his ankles and had the stain to prove it. Publicly humiliating his wife and himself he retired from his title but not from his lifestyle. This wasn?t a big party as such, only a few of us eating at the diner table. There was Jeffrey at the head ofit all, as always. On the left side was Emmy, Ghislane and I. Sitting across the table from us was Bill with two lovely girls who were visiting from New York. Bill?s wife, Hillary?s absence from the night made it easy for his apparent provocative cheeky side to come out. Teasing the girls on either side of him with playful pokes and brassy comments, there was no modesty between any of them. We all ?nished our meals and scattered in our own different directions. 110 Copyright Protected Material CONFIDENTIAL CI Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page619 of 648 Jeffrey wanted his evening massage before bed and Ghislane and Emmy went to their of?ce to talk about something, leaving our guest of honor to ?nd company elsewhere. Strolling into the darkness with two beautiful girls around either arm, Bill seemed content to retire for the evening. He wanted to have a hot bath before bed while Ibegan the massage in the tub. Starting with his feet and calves, he wanted to end the night quickly. Never showing any restraint he sat up on the edge ofthe tub and asked me to preform on him orally. [did my job, but that?s all our relationship was these days, a dreadful job. Getting it over and done with as quick as possible was my hope but I couldn?t let him pick up on those vibes, to make him enticed I had to act like his little porn star, knowing exactly how he wanted it. Only then would my duties be ful?lled and I would be able to get back the reality ofmy complicated life. Before I couldsay goodnight, Jeffrey had one more request. He wanted me to tuck him under the blankets and ?uff his pillows for him. Then I had to reach under the covers and massage his feet while watching him fall asleep, he even wanted me to wait like twenty minutes or so after he fell asleep before 1 could leave. It wasn?t unusual for him to ask it but God I hated it, never offering it I would always wait for him to request it. Once he was snoring gently I wiped my hands clean ofthe lotion and quietly closed the doors to his room. Making my way up the outdoor spiraling staircase, I felt the breeze blow through my hair and looked up to the heavens. The stars shown so bright out here in the middle of nowhere with no big city lights to hinder their effect I could get lost in time staring into them. No matter how far gone I really felt there was always something about a simple caress from the wind or the reflection of the star sweeping sky in the black glossy ocean that would always remind me of my fond iove of nature?s blessings. Back in New York, there was nothing left of nature to adorn. It was a dwelling for those who no longer saw the use for trees without cages or biue skies without clouds of man made fumes and gases. Unfortunateiy if we weren?t in the Caribbean, we were there in New York. Hardly going back to Palm Beach, barely even seeing my family, my dog or T.J these days at all. In my parents heads I was all grown up and educated in the world of wealth not needing them any longer they wouldjust wait for my call once in a while to let them know how I was doing and that was the extent to our restricted relationship. The road my 'life has led down never has kept me close to home anyways so to me it wasn?t anything unordinary but still a sad existence to be without a family of my own. It would?ve been nice to be missed though, rarely letting myself think like that. No room for pity in my heart, ifI did, the ?oodgates could open and I?d have enough grief in one lifetime to go around a few times that they would?ve never been closed. . GIUFFREOMZM Jeffrey?s business was running well from the looks ofhis attentiveness the of?ce he owned in the Upper East Side of Manhattan. Alan Dershowitz, his colleague in ?nances and personal solicitor, a bird of the same feather, Ihad seen hanging around the island and Jeffrey?s Manhattan mansion, more and more these days. Alan?s taste for the young and beautiful was a bias for a blooming business relationship between him and Jeffrey. After an explicit session ofJeffrey?s vulgar pilgrimage into my body, we were interrupted by a knock at the door by Jeffrey?s good friend, Alan. I wrapped myself up in Jeffrey?s pink bed sheets, which is the color preference he chose to sleep in because it reminded him of the same color of his own words ?Pussy?, and covered my face from the unexpected intrusion. Jeffrey got up and wrapped a towel around his loins and answered the door completely calm. Opening the bedroom door and letting Alan inside they began to converse about business immediately, right in front of me. Jeffrey started to tell Alan what needed to be done while hejostled some notes down quickly. I. peeked my head from underneath the covers thinking they were too wrapped up in their work to notice me get up and dressed, and Jeffrey turned back to me and told me tojust stay there this would only take a second. Going back to Alan he turned his focus back into work and hustled out a few more orders before letting Alan out ofthe door and returning his attention to me. ?Sorry about that, work never stops and neither will the money coming in. How else am I going to make a million dollars while I?m sleeping?? Jeffrey chuckled as he sat back down on the bed next to me. I laughed at his humorous and mostly true statement, then a strand of hair fell in front of my face. Before could get to it he put it back behind my ears and sweetly stroked my face, for a moment wejust looked into each other?s eyes and be nearly seemed almost human to me. lt was bizarre how he could be so kind and gentle one moment and the second beforehand was being treated like no more than a common plaything left out for display. Nothing more than an ego trip, Jeffrey got off on letting the ones he wanted to know that he could own anything and anyone he wanted in this world. Maybe for a brief minute I believed the sincerity behind his eyes but that vision would quickly fade away and I would be left second- guessing why I even fell for his deceitful tricks for a moment. Jeffrey got up from the bed and asked me to join him for a shower. In his bedroom, which was the entire top ?oor, he had a glass shower enclosed underneath a glass skylight right in the middle of the room. It was perfectly accessible feature for a man that loved both being clean and nude, but still an odd feature at that. As I always did whenever I showered with him, I lathered a ioofa with soapsuds and would scrub his body, up and down, in between his toes, even behind his ears and of 112 CI Copyright Protected Material GlUFlileilO-?lil-JS li' Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page620 of 648 course his genitals area. The sunlight shown through the glass ceilings into where we were standing, making the moment feel even more surreal on top of the already popped Xanax I had popped before for breakfast earlier that morning. Jeffrey was in such a lighthearted mood that day, making funny cracks at me, and acting like a flirt. When I was ?nished washing him he actually wanted to wash me too, which was another totally out of his character suggestion. For the rest of the day, he took me everywhere with him, the of?ce and then to a friends place, even just wanting to hang out with me for a while. I wasn?t used to being treated like anything more than a dog on a leash, when he acted like this itjust completely spun me around confusing me even more. We were spending heaps of time together these days, a lot more than usual. At the ranch we would do things together, alone, and notjust the usual perverted things was accustomed to doing with him alone. Horseback riding on his ranch during weekends away by ourselves and movie nights snuggling up over a bucket of popcorn instead of having to massage his feet during the entire ?lm became his way to alter my perception of my original notion that I wasn?tjust his sex slave, I thought I was ?nally becoming his friend. When we went quad biking he no longer wanted me to take my own bike, he preferred me to sit on the back of his, holding onto him and he even tried to teach me how to drive a manual stick shift car. He was de?nitely trying to show a softer side of himself, different to the stone cold slave driver I had to come to respect out of fear over the many years. Still a hard image to change after all I had been through and seen over the years I had been with him. Nonetheless he was still my ?boss? so I humored his attempts and matched his caring demeanor, giving him the impression I was intrigued in our new kind of affair. Chapter 19 His attentiveness led into the wamier months that commenced the beginning oflong summer days that I looked forward too. I couldn?t help but enjoy his eagerness to see me more relaxed these days. He wasn?t even bothering me to ?nd alternate sources of girls for his twisted satisfaction anymore and although I was still being used for his distorted sexual enjoyments he further seduced me into believing I meant a lot more to him than I ever did. 113 It all came to a sudden conclusion one sunny afternoon in the Caribbean. Jeffrey pulled himself up to the ladders ?rst step and climbed up the next four steps to the top of the dock. His chest was heaving rapidly as he sat down catching his breath. Ghisiane was the next one up and then I followed lastly behind them. To me it was an invigorating snorkel around the shallow reefs within the radius of the dock, but to Jeffrey the half an hour swim in the ocean was enough to overexert his ageing limbs. I took off my snorkel gear and placed it in the storage bench, grabbing us a few towels at the same time. Wrapping a towel around Jeffrey?s backside and handing one to Ghislane, I. sat down next to them on the dock and we laughed how fatigued Jeffrey was, poking fun that he really is getting older. A very touchy subject for the vain at heart but he didn?t seem to mind it, probably knowing we?d never take thejoke too far. We sat there in silence for a moment, an odd silence at that. Jeffrey looked at Ghislane and then Ghislane looked at me, placing me once again in the spotlight. They both scooted closer to where was sitting and I felt something stirring in the air. The biggest turning point of events in all ofmy time spent with them. Jeffrey sat next to me and put his hand on my back and looked at me with a certain kind of sincerity I hadn?t seen in him before. want to ?rst of all tell you that over the last few years you have shown me the kind ofdevotion and loyalty that I believe is rare to ?nd among people these days, qualities I hold that high in regard.? Bewildered by the whole scenario Ijust nodded every time he paused, trying to grasp what his intentions were getting at. He continued to praise my nature saying I hope you know my appreciation for your embracing of my lifestyle, you have been achieving a name for yourself among the friends I have I introduced you to. Everybody says basically the same thing about you, the same thing I believe. You are a delightfully funny girl who has developed into a mature graceful young woman and I could think of nobody else I?d rather have a child than with than you.? And just like that he created a whole new dilemma for me to face. In utter shock from the completely unexpected proposition and before I could even think of anything to respond with, Gliislane made the finishing touches with the business end of the deal starting with the pros before the cons ?You would have around the clock nannies to help you. Jeffrey would pay for a mansion of your choice in either Palm Beach or New York" and as if the drumrolls were beckoning you would have a hefty allowance from effrey?s bank account? Astonished at their ?rst offers I nearly took the bait. Then she continued to ?nish the terms of our pre-agreement with ?But you would have to travel with the child where and when Jeffrey wanted you to be, and most importantly you would have to sign a contract stating that Jeffrey and you are not 114- Copyright Protected Material 042-17 Tl Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page621 of 648 monogamous and that the child would belong in Jeffrey?s custody in the event ofa falling out between the two of you.? She kind of threw that last one in there quickly, as if she could get away with me not hearing that I would basically have to relinquish the rights to my own flesh in blood and surrender them to a life of servitude and abuse with these people. My maternal alarm bells went off straight away and I already knew my answer. No way I could I do that to any poor baby, God only knew what these monsters had in store for me let alone a baby, but it was an instant reaction that saved me. I don?t know guy?s, I mean I?m really young and never really even thought about having kids yet. Wow, Ijust don?t know.? I slicked my hand through my hair nervously and took in a silent breath. I had to go beyond what I was truly feeling and give them the feeling that I?d never let them down. Putting an eager smile on my face and sucking up my gut?s intuition I told them ?You know what, let me get my certi?cates in massage and have some time to prepare for this and get healthy then next year we?ll all think about having a baby together.? It was crazy to even hear me say out ioud but from the expressions on their faces I had ful?lled their wishes. Much reason to celebrate that night they were both in a cheery mood around the dinner table. Except for me who had taken double the dosage of Xanax to even cope with the high amounts of anxiety I had been suffering from since we got back from the dock. I wasn?t sipping the champagne that night, I was gulping it and when their moods turned from cheery to raunchy later that evening it wasn?t hard for me to comply. From the full effects of the state I was in I would?ve agreed tojust about . anything, allowing them to treat themselves to ravishing the tender parts of my body. Over the next few weeks everything went on as it normally would, and not another mention of their proposal. My birthday was only a week away - and was turning nineteen that year. All I wanted was to get my certificates before I got any older and get trapped into this life for good. When my big day rolled around I was in New York with Jeffrey and Ghislane. Sitting on my bed listening to channel blare in the background of my room I was painting my toenails when was suddenly buzzed on the intercom. It was Jeffrey calling himself to ask me to meet him in his office in ten minutes. Perfect timing to let my nails dry I thought to myself. Already contemplating his desire to come downstairs I knew it had something to do with my birthday present but I was more expecting the usual shopping money or piece ofjewelry, de?nitely not what he had in store for me. I knocked on the ajar door to Jeffrey?s of?ce and heard him beckon me inside. ?Hello, what cha up too?? I asked in a. cutesy tone of voice. Walking over to his desk he looked up at me taking his reading 115 glasses off while granting me a big smile. ?Come over here and sit down with me? as he ushered me to come sit on his lap. Pulling me onto him he had a funny look on his face, like he had something really big to tell me and was letting the anticipation build in the thickness of the silence. laughed at the way he was looking at me now. ?First of all. . .Happy birthday today.? Was only the beginning of his announcement and he proceeded to tell me know how much you have wanted this for so long and you are more than deserving ofit. You are going away to Thailand to learn authentic Thai Massage and within eight weeks you?ll receive a certi?cate for being a quali?ed Thai Massage Therapist.? Astonished at his attempts to see me get what I wanted, not exactly the type of massage I was interested in but it was a start and a ?rst certi?cate for me to acquire. My eyes lit up and I threw my arms around his neck, planting a big kiss on his lips, which I rarely ever did. ?Wow, I don?t know what to say, this is beyond my wildest you so much!? I did well to let him know I appreciated his grandeur offer. He went on to give me the details of where I?d be staying, the school?s schedules, and how much he loved Thai massage, apparently it was the next big thing to hit the shores of America. He had planned out an entire itinerary for me. I was to depart at the end of August and he had already enrolled me in a class at Massage School?. I would only have a few days to settle in before I would be attending classes ?ve days a week over eight hours a day. He even had an assignment for me to do while I was over there. I was to meet up with a girl who was also being put up at the ?Princess Hotel? where I was staying. She had an Asian sounding name so Ijust assumed she was a local girl hoping for an opportunity ofa lifetime, if she only knew what she would be getting herself into. decided that she met Jeffrey?s particular quota of approval then she would be sent over to the US to meet with him or one ofhis esteemed colleagues. Besides the guilt of having to decide a stranger?s uncertain fate, everything else sounded more than wonderful. Eight weeks gone from Jeffrey sounded like a lifetime away and I couldn?t be more excited at this chance. It was the opportunity of my lifetime and I wasn?t going to waste a second ofit. Ghislane came in a few minutes later and the look on her face told me she already knew. I got up from Jeffrey?s lap and gave her a big hug and told her, ?This is so nice of you guys, Thank you so much!? She didn?t share my enthusiasm of excitement. In a dull tone she responded, didn?t have a thing to do with it, it was all Jeffrey?s idea but good-luck anyways.? She gave me her best impression of being human for a brief second and hugged me back. It wasjust her way and I had come to accept it. Depending on the level of slander her insults provoked wasjust her way of telling you she cares without really ever showing it. Probably 116 ll Copyright Protected Material CONFIDENTIAL 24?) doesn?t make sense to most sane people but after all ofthe time spent with them, I had gotten to understand a few of their quirky ways. Even if I didn?t agree with them, they knew I would for their sake of opinion. What did it matter anyways I thought, I had been degraded in every other physical way what?s the difference from taking their mental abuse too. Not the exact choice of employers I would?ve chosen over again if given the opportunity but here I was and doing my very best to excel at their demands. I was sent home for a little over a week to pack for the long trip and make the rounds visiting my family before I left overseas on my ?rst trip all by myself. It was great to see my family after such a long time away. My older brother and his wife even came down to visit for the well wishing of my departure. Everyone in my family seemed stoked at the prospects my longjoumey had led me down. Here I was jet setting around the world in my teens and getting paid to study the COurse ofmy dreams at a cost that I only knew I would have to pay. It was a wonderful get together with all of them around, a great way to remember them. If I?d only known it would be the last time I would see any of them I would?ve emphasized to my brothers how much I really loved them both and how much I would miss them in the decade to come! But I didn?t know what my future held for me, I had nothing planned out I wasjust hoping for the right opportunities. I. also had a few good friends to catch up with before I went. Every night was another party and by the end of the week I had drunken enough to drown an Irishman on St. Patty?s Day. I was given the lists to all of my friends email address and told to keep in touch Yeah right I thought, I was going to be too busy having too much fun to be thinking about sitting on a computer emailing people, but I told them I would anyways. Save myself the point of having to explain that in many different ways to a group of already tipsy slurring teenagers. Out of everyone who was really happy for me, T.J wasn?t. He hated the idea of me leaving him to have a non-stop party in Thailand without him. He was just starting to seem like he was coming good andl didn?t like having to leave him at such a vulnerable state but in my young years I had already realized I needed to do some things for myselfand this was one ofthem. There was still a huge amount of broken trust between us, trust that could probably never be rendered again so I thought Iwas being decent enough letting him stay at my apartment while I was gone, but he was not to drive my truck, at all. I paid too much money on insurance for that thing and knowing his driving record I didn?t want the risk of something happening while I was gone for so long. He didn?t agree with me at all, throwing a grown up tantrum all over my apartment. Hitting the walls and doors, shouting the entire complex down, there was nothing I could say or do at this point in 117 IL Copyright Protected Material CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page622 of 648 time so Ijust put my dog on the lead and took her for a walk to calm down the situation and give me some time to be alone. Mary .lane was the only one I hated leaving behind. When we got back from the long walk she barricaded my suitcase while I was packing the horrendous amount of clothing that I always did. I was promising her I wouldn?t be long and told her how much I loved her giving her a big hug. I choked back on the tears that were swelling up in my eyes, it was like she already knew the night before I ?ew out to New York that this would be my final trip. There was a commercial ?ight booked for me in the morning and I needed the rest that night to fully recover from my binge of celebration drinking. T.J crept into bed later that night and tried to redeem his behavior with sweet nothings and dry humping my backside. It did nothing for me sexually. I didn?t feel like that for him any longer and the sooner he realized that, the better he?d be off. I told him I wasn?t up for it and he picked up a pillow and slammed the door behind him. It didn?t matter I. told myself, the next day I was off and wouldn?t have to deal with him or anyone. T.J caught a cab with me to MIA, the airport in Miami. He walked with me to the furthest point he was allowed to go by the security gates and as we stood in line together it was almost heartbreaking seeing him cry. I told him I?d try to call him everyday, attempting to give him optimistic ways to look at this time away from each othercrying and I had to give into my remaining feelings I had for him. One last kiss under the x-ray bridge and he vanished out ofmy sight as I furthered down the terminals long hall. Chapter 20 It was only a short ?ight to New York and I just couldn?t wait until next week when I?d be jetting ofto an exotic destination all by my lonesome self. It was all I could think about talk about and dream about, finally my break. Ghislane did what she did-best that week and prepped me for everything I could imagine under the sun. Do?s and Don?ts, emergency numbers and western union locations were among some things on the list she gave me. Like I said, she showed her caring side in other ways. There was also the name of the girl I. was Supposed to be meeting, the room she was in and what dates she would be staying there. When I got out of Ghislane?s of?ce I was instructed to meet Jeffrey in his of?ce. She had to stay back for some paper work that she had to catch up on pronto. Making my way up the red and gold trimmed carpeted 118 Copyright Protected Material CONFIDENTIAL I Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page623 of 648 staircase I prepared myself for some major sucking up before I left, he would be expecting it for his recent generosity, or so I had thought. Opening those familiar heavy doors the first thing I saw was an unfamiliar face standing over Jeffrey?s shoulder. She was a tall girl with blonde hair twisted up in a professional looking knot. Her big smile was flashing at him with hints of her cheekiness to come and she was dressed to kill with a short tight grey skirt and a matching suitjacket over her white buttoned down blouse, revealing her voluptuous ample cleavage. She looked like the old college professor?s wet dream. When she introduced herself to me, a thick Czech accent presented itself. Her name was Nadia Marcinkova and Jeffrey looked just about as smitten as a victim of a love struck arrow from no one but the cupids themselves. Jeffrey further introduced her as his new assistant and masseuse while I would be away, barely taking his eyes off her for one second. It was a bit ofa blow to take, being so easily replaced but also a part ofme already knew this was expected off someone like him. Good for him I thought to myself, why should I have bitterness over someone I never had intimate feelings for and knew had never really cared for me in the ?rst place. Kissing her on the cheeks and telling her my name, I was doing my best to grin and bear it. We hugged for a brief show of uniformity but it was just that, a show for Jeffrey to see. When he was away for the moment or she wasn?t busy hanging off his every word, the way we all started out, she would snub me off to only head offin another direction. A real bitch if anyone was to ask me but no one would anyways it wasn?t my job to like her. Over the next course of days it was my task to show her some of my techniques in massaging Jeffrey and the erotic side of ?nishing it off. Nadia despised me even more when Jeffrey told her to follow my lead during the massage as she tried to take over and do her own thing a few times. To me it was quite funny her competitive side, Ihad nothing more to prove so watching her put on an act of seduction and scream out her every body function during a faked orgasm was nothing but entertaining in my eyes. After a few sessions together it was my time to be off on another adventure far, far away from here or from the chains that I wore for way too long. Jeffrey had someone else to ?t the chains that kept me so close to him. Even though she wasn?t the nicest of girls I still couldn?t help but feel sorry for her. No girl should belong to someone out of servitude, but unfortunately it is the way our civilization has been for many centuries before us and I don?t see changing any time soon or as long as perverts like Jeffrey are allowed to walk around freely and procure our daughters off the streets all because he?s got a lot of money to pay many, many, many people off. 119 GIUFFRJEOIMZSZ Throw out your confetti because here I come Chang-Mai? My celebrations started the second I landed, it didn?t take me long to make myself aquatinted with a few fellow travelers and ?nd the hot spots of the hustling city. It was like nowhere I had ever been before. The streets were lined with stalls offering an assortment of souvenirs, clothing, and knick- knacks. Everyone lived so freely and was in such great spirits. The parties raged on until the wee hours of the morning and people became best friends over night. From the second I got there I knew Thailand was going was right! Popping bottles of champagne, dancing all night to the beat of every club?s along my way and carrying on iike it was my night was a repetition I could definitely get used too. During the day Iwas a real good girl, the teachers pet even. Showing the credibility of my experience in massage from over the last few years and already ahead of the class the teacher was using me to help instruct the others with demonstrations. Mostly in a class full of males it wasn?t a surprise that I made friends with quite a few of them, some ofthem with ulterior motives, but for the most part the sleazebags were none of my concern, I had already dealt with a lifetime of them to be able to spot one out and steer clear ofhis approaches. Out of the entire class I had made friends with only one girl from Wisconsin. She was a plain looking girl with big brown puppy dog eyes and a long drawn out accent. Her first time leaving the States or Wisconsin itself for that matter so it was easy to acknowledge that she was a little taken aback by all of the bustling city life so becoming her friend felt like I was doing a good deed showing her around the hot spots of the Chaing-Mai nightlife. Eventually I even ended up inviting her to stay with me at my hotel. She was running out of money to party every night then pay for school on top of her accommodation, it was all becoming too much out ofher small budget. So I thought about it and offered her a bed in my room, I had two of them anyways. Plus she was a really nice girl and ifl could help make her ?rst time out of the country an unforgettable experience then I was also gainng something from it as well. The ?rst month in quickly passed me by. Having such an incredible time on my own and putting my heart into learning Thai Massage it seemed tojust ?y past. Routinely I had to call in and check in with Jeffrey and Ghislane letting them know my whereabouts and progression in class. Counting down the time left until my course ?nished Jeffrey was anticipating my departure back to New York. can?t wait to get my ?rst Thai massage from you. I?ve got you booked to come straight back to New York for my first one as soon as your course finishes next month.? His eagerness put a twisted familiar knot in my stomach. Reminding me of the dream Ihave to awake from soon and the reality of the certain homecoming I would be arriving to. It?s such a great course, thank you 120 Copyright Protected Material CONFIDENTIAL - Case 18-2868, Document 278, 08/09/2019, 2628230, Page624 of 648 so much for sending me here to learn this. You are going to love my new area of expertise! I am having such an amazing time over herell? I had to let him know how much I appreciated what he had done for me and he loved the head swell that it would make him feel as well. Hating the thought of going back to him, I wasn?t going to let that put a damper on my spirits while I was still out there. It was my time to party harder than ever before. Every night was a new adventure for me. Chang-Mai was a maze ofplaces to get lost in and the vibrant city was my playground. The way I saw it this was my last chance to get out and break free, letting loose my inner girl it felt so good to take the lead of my own life. Chapter 21 It was an average evening getting ready in front of the bathroom mirror on just an average Sunday, though unbeknownst to us girls as we sat there chatting away carelessly, this night was already written in the stars for me. It was a very long time ago now when I was still a young child that I sat looking up to those same stars from my bedroom window with my hands pressed together as I cried for God to hear my prayers. All I asked him for was death. My precious life was already such a hopeless battle that I felt too small to fight alone for. Begging him to deliver me from this cruel world I would pray for all of my pain would to away for good. My only clause in my prayers was the possibility that there was somebody in this wide world that I was meant to love, something much bigger than I could have even imagined yet. This invocation of mine was forgotten about long ago now, until tonight. I wish I had known that night I sat crying beneath the stars that it would all be different one day and that I hadn?t sold myself short to the accustomed lifestyle 1 was brought up to believing was acceptable. It was this night my very soul was about to cosmically collide with the man I was always meant for, the man my heart already belonged to and would know from the instant we met. This night would be the ?rst day to the beginning of my new life to come. I blushed my cheeks and put on my mascara before me and my girlfriend headed out to hit the town. We were dressed to kill and looking for something to do when we ran into a few of our class mates at one of our favorite drinking spots. They were meeting up for some drinks before a Muay?Thai kickboxing tournament. It sounded like fun when they invited us along to watch it with them. The massive crowd lined the street where the fight was being held and once I got inside the arena it was push 121 Protected Material and shove to try to find a spot to watch from. The friends that we were hanging out with were meeting up with another group of guys that were training for the kickboxing tournaments that we were watching. Then it happened it was the ?rst moment I laid eyes on the man that would love me for the rest of my life. I wasn?t expecting the most amazing time ofmy life to happen right there and then but it did and I would never be the same again. Destiny fell right smack into my lap and there was no stopping it! It wasn?tjust his smoldering appeal that was obvious at first sight it was the entire package of mannerism and chivalry that made him stand out of the crowd. Stepping right out of the pages of the fairytales I used to read, he was nothing like I had ever come to know before. Watching him from a close distance he was playfully shadow boxing one of the guys from my massage class and it was at that moment that this handsome stranger first caught me staring at him. From top to toe this athletically built man was intriguing to watch, I couldn?t take my eyes off him like I was magnetically drawn to his power ofattraction. He further interested me when he wasn?t acting like the majority ofharping dogs that wouldjump at the eyes I was giving him now. Instead he coyly played hard to get, making me work for any conversation with him. The fight started and the men were going bezerk, screaming at the fighters in the ring offering either fighter their support or discrimination depending -on whom they were batting for. It was like watching a primitive scene out ofthe days when the cavemen ruled the earth but it was as equally alluring to watch unfold, the sweat, the blood and the absolute brut fascination of it all. - After the ?ght and all ofthe men revved up from the fight, I suggested that we all head to the pizzajoint in front ofthe Princess Hotel where I was staying for a late night snack. I made it my goal to make myself known to this appealing stranger. In the tuk-tuk on the way there I made sure I sat next to Robbie. Scooting my knees closer and closer to him on the short ride he continued his chase by mOving further away from me, a game of cat and mouse that I loved. When he answered back the array of my questions he had the cutest Aussie accent that drove me absolutely wild. Gradually we got to know each other better?over a pie of peperoni pizza and two can?s of coke. Too me he might as well have been the only other person in the restaurant, he knew he had my undivided attention and I think he liked it. There was no one like him that I had ever met before and I knew there was no other who could make me feel the way that I felt at the first sight of him. Being charming and suave was all an accidental front. It was easy to read him. Immediately it wasn?t hard to see his sweet side, holding the door and pulling out my chair at the restaurant, I was 122 Copyright Protected Material CONFIDENTLAL 3 Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page625 of 648 already smitten. After pizza he walked me across the street to my hotel where we made plans to meet up again. There was no kiss goodnight or anything like that. No, he was too polite for that, he wanted to prove himself different and different he was. Walking through the hotel?s revolving doors I watched as he walked away and when he was ?nally out of sight, I sung my way up to my room. Floating on cloud nine I was free falling into a deep pit oflove. The next day I attended my class as usual but not able to concentrate like I normally did, too excited about when I?d be seeing Robbie that night again. As I walked out of class that afternoon even the teacher noticed a difference in my performance and asked me if I was feeling well, ?On top of the world actually? I smiled back at the old instructor and it wasn?t far from the exact truth either. I hadn?t ever felt the churning of butterflies in my stomach and the constant thoughts of anyone else like this before. My girlfriend and I got a tuk-tuk back together as we usually did after school and I couldn?t shut up about the night before. She was laughing at my girlishness telling me that anyone who just met me would think I had never been let out before, but little did she know that I had more than my fair share in experience with men and never had I ever come across anyone that could make me feel this way, and what spun me out even more was that it was such an instant attraction. Never considering myself a person who believed in the existence of ?Love at ?rst sight?, but a true romantic deep at heart, I couldn?t help but believe in it now. He is my walking proof ofitl Waiting for me in the hotel lobby was the very person I couldn?t stop entertaining the thought of all day long, there he was looking ever so fine standing in front of me now. The whole entire world faded away and all that was left for the moment was this complete stranger I had only met last night but somehow captivated the very essence of my very heart. There was no need for me to try and act cool now. He already knew I was snagged hook, line and sinker. Smiling all the way up the many stories in the elevator up to my room he took notice ofthe posh decor of the hotel. ?You should see where I?m staying, this is a royal palace compared to it? His ?rst impression of me he automatically thought I was going to be a spoiled high-maintenance girl that had money coming in from a parents hefty trust fund. Casually he got to find out through many deep and meaningful conversations that my life?s grim story wasn?t that pretty at all. For some reason beyond my knowledge I had the need to tell this stranger almost everything. Wanting to be judged and looked down upon for everything about my life that I knew was wrong and being the ?rst time I had spoken about my years with Jeffrey to anyone honestly like that ever before, I had felt like I had deserved punishment. He offered me no judgment, instead only 123 GIUFFRE004256 gave me his warmth and compassion as he wrapped his strong arms around me, making me feel so meager and small but so safe at the same time. Encouraging me to see the worthiness of myself and leave that life behind, he adorned me with a kind love that I wasn?t accustomed too. He took me in and made me feel so at home. It was like I had known him my whole life. I couldn?t bear to be without him another second while I was away on this dream holiday. When he wasn?t training for Muay-Thai tournaments and I wasn?t in school, nobody would ever see us. Too enveloped in each other in my hotel room to care abOut anything else. Which is why I asked him to come stay at my hotel with me, seeing he was never at his own anyways. My girlfriend was soon departing back to Wisconsin, making my room more than available for him. Enchanted by his words and tender touch, the way he made love to me was again like nothing I had experienced before. Even down to after sex as I had been routinely instructed by Jeffrey to get up for a warm washcloth to clean his genitals afterwards, he refused it, telling me I was no longer a slave and that he didn?t want me acting like one. l-Ie?djust rather lay down together afterwards and repeat our sweet nothings with many adjoining kisses. On our third night together with nothing but the bed sheets between us, we had spent all night looking into each other?s eyes sharing such an undeniable passion for one another. In the deepest caverns of my heart I knew this man would give me what I had never experienced love. We were still iaying in each others arms when the orange and pink sunrise began to rise slowly through the peak?s of my rooms windows, enticing me to come feel the freshness ofthe morning?s chill. Only the bed sheets were still wrapped around my body as I went the balcony. It was overlooking the city in a valley surrounded by mountainous tops. My thoughts began to rampage through my head and I knew this could only be a dream for me. It was getting serious now, too serious for the life that I led back home. As if he sensed my anxiety Robbie walked up behind me and wrapped his strong arms around my waistline, gently kissing my neckline and pausing with his ever so thoughtful stares and gave me the exact opening that I needed to expel my thoughts. ?Back home, as you already know, I am going back to someone else, it?s my job, and as much as I really like you, this guy that I kind of see is going to expect me to be putting him ?rst, I am so sorry to say all of this after such a wonderful few days we have spent together, but you need to know this thing happening between us can?t get anymore serious than what we have for now. I am so sorry? I looked down to the floor with nothing else I could say to alter his perception of me now that I had told him the truth and it never dawned on me that thought he wouldn?t be out the door before I could even ?nish my sentence but he 124 Copyright Protected Material CONFIDENTIAL GlUlil?l?Lle04257 Copyright Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page626 of 648 continued to surprise me with his efforts to make me believe we were more than just friends with a summer crush. You your problem is that you don?t see whatI am looking at right here in front of me, a beautiful girl who is completely lost in a game that she has no control over. Get out of it now, take my hand and follow me back to my home in Australia.? I heard what he had said but I found it hard to comprehend what he was actually talking about. ?What?? I asked him with a look of confusion on my face. ?Your nobody?s property, you can do this. Marry me.? His statements got more and more profound as he went on. Repeating the question he got on one knee and proposed again Jenna, I am in love with you and want to spend the rest of my life making you happy. Please donlt go back to him. I know that I am the only one for you and I will always treat you right. He paused for another second and repeated his question ?Jenna, will you please marry me?? My hands fell into my face after that and without even letting myselfthink through the answer, I let my heart do all of the talking. Looking back up at him I said ?Yes!? I almost shouted the answer at him, as if saying it louder would give the word more meaning. Wanting to believe him and everything that he was saying felt like a vacation from all ofthe suffering and loneliness that I had endured over a lifetime of abuse and degradation but knowing what you want and getting it are two different things that rarely went hand in hand. ..or so I thought. All I knew from the brief period I had known this stranger was that he was offering me a life and love down an unfamiliar path and it was a gamble to believe a complete stranger but somehow I knew he was right. My heart was beating so loud I thought it was going to jump right out of my chest. With the earnestly in my reply he picked me up in his strong arms and took me back to the bed and reiterated his words in a more physical sense this time. Never had I felt loved like this before, so swept off my feet and unable to even think, eat, or do anything for that matter which would involve leaving the hotel room without him. Everyday after school would be my Robbie waiting to take me back to the hotel room for another night?s passionate rendezvous, but a few nights after his proposal, he had another surprise in store. He didn?t just want to get married someday. He wanted to get married now, this week even. I walked into the fabric store and was attended too by several seamstresses who were already be expecting my arrival. I was there to design and have fun designing my own dream wedding dress. While I was busy picking out fabrics and having measurements taken I would look away for a moment only to catch his tender eyes staring in my direction. Such adoration behind his looks. . .could it be real? I would often ponder it to myselfjust hoping for the gamble I was taking to work 125 GIUFFREOO4258 out. I still had to believe in something better than what I was accustomed too and here he was right smack dab in front of me. Giggling at all ofthe lace and frills they were trying to dress me up in, looking more like an antique porcelain dollthan anything else I closed my eyes and pictured the day that I thought would never come, starting to imagine the kind of dress I would like to wear I envisioned a simple sleek'ness, a complimentary figure hugging gown with a small train but long enough to distinct it as an actual wedding dress. After we settled on what we were going to wear for the big day, we would next have to decide where we would hold the ceremony. Not before celebrating the entire week beforehand though. We started our honeymoon early celebrating every night spending our time between my hotel room and sending our heads spinning on the dance floor at many different clubs. Only with each other in sight, the dance floor was ours, we were out to give each other something to remember each night by. I whispered all of the things I couldn?t wait to do him once we got back to the hotel room and watching him heat up on the dance floor I was never able to get enough of him driving me crazy. Like a thirst I was unable to quench, his lips were like a fountain of deep springs that I could never reach the bottom of. Seven days, exactly a week after his proposal I sat on my bed in distress, contemplating what I would say to the man who I was about to call. There was no nice way to go about it. I couldn?t last forever with him and this was my one chance to get out ofit for good. I was leaving him, never to return to him ever again. Ijust had to go ahead and do it. Part of me was hoping he?d be at least a little happy for me and the sudden change in my life?s direction but the other part of me knew I was already asking too much of him. Calling his office in New York I was transferred to Jeffrey?s personal office. He picked up the phone on the third ring, pausing before i could get any of the words to come out of my mouth but I mustered up my courage eventually and gave him my prepared spiel. Beginning with how much I had appreciated everything he has done for me up until this point. I hoped he would be understanding but hejust wanted me to hurry up and get to the point. Trying to contagiously pass on my excitement through the phone lines, I ?nally screamed out ?I?m getting married! Can you believe it?? No reply was given only a silence on the other end. Trying to make some conversation ridding the uncomfortable silence, I went on to tell him about Robbie and how I had fallen madly in love with him over the last amazing few days we?d spent together. The absence of sound made my thoughts begin to run wild and to get some response I had to ask him what he thought about everything I was telling him. Finally a few seconds later his reaction to the news sunk in and his only and final reply 126 Copyright Protected Material CONFIDENTIAL until many years to come was Have a good life!? With that statement he slammed down phone receiver. Leaving only an echo ofthe dial tone to answer back too. I was to paralyzed from the shocking response. ?What have Ijust done?? was the ?rst thing that entered my thoughts. Overwhelmed with guilt I felt like I was falling down a deep and dark hole and then the tears began to flood in. Here I was standing at the dawn ofa new happy life for myself and I couldn?t see past how bad I had let Jeffrey down not yet seeing the hold he had on me. Like my knight on a white horse, in came my hero to soothe my somberness. He rushed over to the bed where I was beating myself up mentally and wiped the falling tears from my cheeks. take it that it didn?t go so well. . .huh?? Sniffling through my sobs I managed to tell him that ?It doesn?t matter anymore all I care about is you and leaving all of that life behind me!? I wrapped my arms around him and he asked me in a halfjoking voice ?Then why are you crying?? He got me almost laughing now too guess it?sjust so scary taking such a huge plunge away from what I?m used too and taking such a big move to another country. It?s just all so different and I?m just trying to comprehend everything that is happening in such a short time.? Always out to lift my spirits his next comments made me gush in laughter ?You think that was a hard phone call wait until I call my Sicilian mother! Watch this, I know exactly what she?ll say. First it?ll be a saga about how I?m killing her with my sel?sh actions then it?ll be about how she?s going to kill herself for doing such a terrible job raising normal children. Don?t worry though, she?ll love every second ofit. Wogs thrive off of the drama in their lives and off everybody else?s for that matter! He was pretty much on the dot when he told me how she?d react to the news. In the end after relentlessly trying to change his mind, she sighed, ?If it was going to be anybody to do something as crazy as this, Robbie, it would be you!? It wasn?t a blessing as such but at least she wasn?t threatening suicide any longer. . Calling the closest of our families the night before our wedding to share with them our announcement wasn?t celebrated by any members of either sides but that didn?t discern us one bit. My parents took it well, considering their only daughter was marrying a foreign man that they didn?t know from the next guy on the street and too top it offI was moving to Australia, permanently. When I asked my Dad many years later why they hadn?t put up a fight, he just simply replied that nobody expected it too last very long. Fair enough, I thought. I don?t think anyone did at ?rst. .even us at our toughest times. We were a rare attribute these days in the numb era we have all been accustomed to living in, tuming nothing into something, which I had also come to realize, was the most precious gift in 127 I Copyright Protected Material CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page627 of 648 Falling asleep was easy to do in his arms that night. I laid my head on t0p of his chest listening to the drum of his beating heart. I had never felt like I was more at home than ever before in my life. He pulled me gently in closer to him, letting me know that he was there for me even when the lights went out and the thoughts wouid usually creep in. Amazing how he knew what I needed without even asking for it. Wishing for something like this my whole life I thought I was being such a fool in so many ways, but I was so wrong. The way his pretty eyes looked at me with such an understanding and compassionate sincerity made me want to trust his words and believe the love that he was offering me was indeed real. The next morning, Robbie was up and out of bed early to pick up our tailored wedding suits and dresses for our big day at Doi Cept Temple. His best friend from high school days that was travelling with him from Australia met him in the hotel lobby at seven o?clock. He was going to be joining us for the wedding as Robbie?s best man. He still hadn?t been able to ?nd black shoes to go with the suit, so after he dropped offmy dress back to me he was off again to try and find himselfa pair of decent looking ones. Overjoyed with excitement I was thrilled from the second I kissed Robbie good-bye for the last time before we were officially married. Looking in the same mirror only a week ago I was now a different person, I felt like I was plunging into a bottomless abyss. Here I go, I thought to myself as I plunged out the door letting the butter?ies in my stomach carry me all the way to my nearly husband. I had to go to the beauticians that morning for my pre? wedding makeup and dressing. The ladies who were doing my hair and face at the salon did a greatjob making me feel so beautiful for my special occasion that every girl dreams about their whole entire life. Requesting simplicity at best, not wanting to go overboard with all of the wedding apparel they tied my long hair up into a knot wrapping around it a veil of flowers made up of baby?s breath and small yellow and purple budding flowers. I couldn?t have dreamt it up better myself and when 1 met my husband to be at the bottom of the mountain he stood before me Speechless ?You look beautiful!? were his first words that his mouth formed almost whispering them. He took my hand and we walked into the sky lift together. Behind us followed an interpreter that Robbie hired to translate the Buddhist Monks ceremony speech for us English only speakers and then his best friend, who only moments before gave him the best mans speech about being the last chance to walk away from this and not get married to a girl he hardly knew, but my Robbie wouldn?t hear a word of it. He already made up his mind the instant he proposed and I said yes, was born to be with this girl,? he told his best mate. ?Alright then lets go do this then!? Once he knew Robbie was sure in his decision he was more than ecstatic for him. We were slowly lifted up the tremendous mountainside, 128 Copyright Protected Material CONFIDENTIAL Copyri it Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page628 of 648 surrounded by the floral green carpet of mossy grass that covered the and falling fog, it was like being carried to heaven or the closest thing to it! Taking my eyes off the scenery and catching him adoringly staring at me again, lwelled up with unstoppable tears. am so lucky, is this really happening?? He squeezed my hands and replied back ?You?re the only one for me. . .I love you!? relieving the anxiety written all over my tear stained face. Chapter 22 Getting out ofthe carriage we were greeted by good fortune from the Gods above. A sun shower cascaded over us at we advanced into the ancient holy temple. My tears ofjoy dried and my happiness was glowing for all to see. The many visitors to the temple stopped and took photos of the passing bride and groom, no other foreigners had ever been married there and certainly anyone wearing traditional western wedding attire, such a sight had never been seen behind these religious walls, we became a permanent icon at the temple. The ceremony was done in the Buddhist customs according to their ancestral accordance, and translated for us in our own language. Both Robbie and were anointed with a blessing from the monk with a splash of water and seven sacramental bracelets, each one representing another meaning to the longevity of our union together. We signed our names in the Buddhist wedding registry of Doi Cept Temple and of?cially became Mr. Mrs. Roberts at least of?cially in our hearts knowing the laws of Australia only recognize certi?ed weddings, meaning when we got back to his homeland we?d have to make a run for the courthouse. This was our real wedding though, perfect down to every detail. Walking up to the highest point of the temple to the balcony hanging over the edge ofa cliff side over looking the city of Chang-Mai, we knew we had found the perfect spot to recite our vows of love to each other. Providing everything for me and more than I could ever ask for, his vows were to love me unconditionally until death do we part, shelter me from all the cruelty in the world that I was so accustomed too and to be like the bear, because the bear never forgets. Tears once again streamed down from my eyes as he made this moment unforgettable. Wiping the mascara fading underneath my eyelids whilst giggling at my embarrassment I took his hands back into mine again and gave him the vows that were the sacred prepared words from my heart. My ears were thundering the sound ofa million horses hoofs descending downhill and my heart was beating so fast my words barely trembled out ofmy mouth when I began to tell him how much he had changed my 129 GIUFFRE004262 whole life around and how I would dedicate my entire being to loving him and only him until I blew my ?nal breath. I meant every word that i said to him, this was it for me, wanting nothing more out oflife than to be with someone like him to raise a few kids together and grow old on the front porch letting the days fade us by. I know it probably sounds boring to most and it would?ve to me as well many years ago but after the life I had led, I had enough experience in the real world for my liking and now all I want to do is to enjoy the remaining days of my life for what it is. . .a simple and satisfying existence. Our day was so special but not only to us, even too the Monk that married us. Upon our descent down the lifts he asked if he could take a photo with the bride and groom in front of their symbolic liberty bell signifying the union between east and west. It represented a lot for us too, it was the commencement ofa new life together andjust the beginning of battling each other?s past demons together. Kissing the bridal party goodbye, who werejust the local girls I had met on some of our many nights out of having fun. I threw my arranged bouquet of Thailand?s white wedding ?oras mixed with colorful orchids to the screaming Thai women behind me and we were given one last tradition to take with us, the release of caged doves. It was such an incredible gesture, especially for me. Symbolizing their freedom as well as mine I opened the cage?s door to let them free to decide our own fates. As the wings on the birds began to spread open and they took their final decent into the blue skies granting themselves freedom I knew mine had ?nally come too. The relevance of watching them fly away and how I had perceived my own day of marriage related to the identical feeling of fleeing an entrapment ofmy own kind. I was liberated from the bounds of slavery I had come to know over the many years I had spent with my fair share of greedy perverted old men only to have serendipity mend my scars with the powerful healing of what true love has to endeavor on. As customary in the romance novels I had read as a young girl he picked me up in the hallway before our hotel suite and carried me over the threshold, poufy dress and all. My arms were squeezed around his neck never once taking my eyes offof him until he revealed yet another sweet surprise. Besides the cleaners tiding up my room while we were gone they were also given instructions by none other than the groom himself to pick the petals off the stems of red roses to place on our bed in the shape ofa giant heart. The rose petals led the way to where we consummated our love physically and it was undeniably the first time in my life I had really ever been made love too. Hours had passed by before we thought about anything else besides one another?s words of arousal, tantalizing touches, and lingering kisses. We ate a quiet dinner at a local restaurant and went straight back to the arms of each other again, so 130 C: Copyright Protected Material CONFIDENTIAL 263 . Case 18-2868, Document 278, 08/09/2019, 2628230, Page629 of 648 profoundly in love with one another it was the ideal display of what the ?honeymoon period? should have to show for. It was crazy, young and energetic,just what it should be between two blossoming lovers. The following morning we left the Princess Hotel, no longer under any of Jeffrey?s financial privileges or control so to speak, continuing our love spree in another dwelling of our own accord. Three days later when we ?nally showed our face for the ?rst time since checking in downstairs in the new hotel lobby, besides to request fresh sheets and towels, the entire staff of the hotel had a good laugh at our expenditure, from their reaction it must?ve been nice to see a couple so affectionately fond of each other. Now we wanted to have another type of fun, Robbie had visited a tourist agent by himself before we got hitched to book a honeymoon itinerary for us to explore Thailand and beyond together, another surprise he had in store for me. We left early in the morning andjoined the crowded bus for ourjourney beyond the border of Thailand to a village in the war torn nation of Laos. When we got through the extremely armored visa of?ce eight hours off the beaten path, we then had to cross a ?ooding river from a recent heavy downpour of rain in a slim banana boat that looked like it could barely handle our weight let alone the excess of my luggage that Robbie was so kind to trek around the world for me. Unbelievably we did make it to the other side only to ?nd that my hOneymoon in the tropics wasn?t exactly how it had been explained to me. Naked children ran through the dirty streets, with one boy that decided to release his bladder on the pathway where we were walking as we passed by him on the way to our hotel. My doubts of his choice in destinations became apparent after that sight. Robbie was getting hungry after we hadn?t eaten the entire duration of the trip and being such a rugged man he could digestjust about anything. Deciding to stop on the side ofthe road he ordered some kind of seafood dish. . .daring I thought, settling for some toast and jam, something safer I thought. Then I saw the lady behind the counter dip some plates in a dirty bucket full of dirty water and then rinse in another bucket of water that didn?t look as bad as the previous mud drenched one and then further proceeded to put my toast and his food on top of them serving it to us all in a clear view. Ijust couldn?t bring myself to even fathom it ?1 can?t eat that!? mouthed in a hushed voice trying to quietly make my point clear but was made public with his loud mouth outburst of ?Why not? Looks ?ne to me. You have to try and eat something, you haven?t eaten all day!? I know it was just his caring side that was trying to force Sicilian and they?re all about eating so it was our ?rst debate and now we were of?cially married with many more marital con?icts to subsequently follow. Two head strong and stubborn people both with the right 131 Copyright Protected Material intentions but still recovering from old wounds. It was only natural and important that we foughtjust as much as we made passionate love together. Countlessly proving to one another the true intentions of each other loves but sometimes in not so seemingly actions. Finally arriving at the hotel it was like a scene out ofa horror flick. We were showed up to the room that looked like someone had been brutally killed in. The bed sheets were torn apart and the bed was stained with blood from some poor helpless victim. Nearly vomiting at the pure sight of the room and the stench that accompanied it, I was now tearing at the thought of even staying here for a single moment longer. ?No way!? I told my new husband and from the tone in my voice he knew I was serious. Not that I was not denying the fact I have never been an outback type of girl. I was ?ne with that impression, I am no snob but give me the simple luxuries ofa clean bed and a shower then I?ll make myselfat home, but this wasjust the epitome of ?lth and even possibly an act ofa horrendous event but who knows, the lady who showed us to the room seemed ?ne with it passing it off as a hooker on her period. in some ways that was even worse. . .?Yuk. . .Okay Robbie it?s time to we were heading back down hill back to the passport center declaring our passage back into Thailand. Considering us a risk due to the short time we spent crossing the border and back, the of?cials held us at gunpoint while others rummaged through our luggage for drugs or whatnot. Finding nothing of course they released us and stamped our passports, making us good for another three months if we wanted. We were thankful for escaping with our lives alone, although we had nothing to hide but still an endearing experience nonetheless in the ?rst days of our honeymoon of all days. Chapter 23 Arriving in Koh Samui for ?nally a bit of relaxation in the tropics, it was my idea of how a holiday should be, sunny warm, and well, clean enough. We lived it up like kings for the next six weeks. Making it an ideal way for two strangers to properly get acquainted. Dancing into the wee hours ofthe night and making love in the blistering heat of the sunny days we discovered everything on that mostly being each other. We made friends of all sorts, mostly travelers, but everyone the same in being taken aback by our fairytale romance. With our captivated eyes never straying too far from one another anyone could easily see the strong chemistry between us. Trying to ?nd the woman in me wasn?t dif?cult, as I took to the bounds of marriage with such ease, no longer a girl I loved the idea of being a 132 Copyright Protected Material GlUl?HlL-?Oilal 265 wife and belonging to a husband like Robbie. Marriage was bliss for the duration of our honeymoon until we had to ride coach on our way to Bangkok Airport to ?y out to Australia. Chatting away with. always so much to say to each other we watched a movie and ?nally got comfortable leaning up against each other as pillows. We both fell asleep on the long ride and when we woke up to the sound of the buses brakes coming to a halt we initially realized my purse and Robbie?s wallet with all of our money and cards in it was missing. Stranded in the city of Bangkok was frightening enough as it was but too make matters worse a lady looking in her mid-seventies, scrawny and hunched over from an obvious lack of nutrition lifted up her skirt to a passer-byer with a she- male hanging off his arm and began smacking her vagina blaring out ?Look! No cock. . .Pussy, pussy! Only five baht? repeating herself many times over the man just walked on past as she sat back down on the curb waiting for the next alluring customer. Robbie and I shook our heads in disgust and disbelief, things could really be that bad for someone, I would know best as it wasn?t far off the life Jeffrey had been training me up for. Completely broke at two o?clock in the morning and with no one to call for help, I panicked right away. Robbie rubbed my back and his tired eyes trying to make the situation better. Luckily we had made friends with some really nice people from the resort on the island who gave us about two thousand baht when they saw how devastated Robbie and I were. With just enough money to rent a really cheap room for the night at a backpackers hostel and pay for a taxi to the airport the following day, we were saved. Early the next morning we were off in separate planes, since Robbie?s ticket was pre-booked and no available seats left for me to join him meant we would be landing in Australia separately. Fortunately we had found a corresponding ?ight that arrived within the same hour of each other but I would have to make a stop over to the Philippines. The hours of the duration on the ?ight seemed to stretch on with only the thoughts of the journey ahead of me I couldn?t wait to get back to my husbands loving arms. The trip was going well, sleeping the majority of the ?ight until I had to change planes in the Philippines. After the plane landed and before any passenger was allowed to get off we were handed a declaration statement that informed us that if we were carrying any drugs or weaponry, we would be arrested and face charges with death as the ultimate penalty. Not that I had anything to worry about, but what a thought to willingly sign over your life. I got the chills handing over my signed declaration and traveling documents to the customs of?cer. Obtaining my passport he additionally asked to see my departing ticket. No problem I thought, just I had done many of times, and I handed over the requested information. The of?cer looked me over Ll (.npyri Protected Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page630 of 648 and got on the phone immediately which sounded like a phone call to his superiors but I couldn?t tell since it was in another language. A brief conversation but long enough to get me thinking, he then called over two guards who took me by the amis and brought me into an empty room but for a desk and three chairs to be interrogated. No one would tell me what was going on they all just scattered around in frenzy, ignoring all ofmy hysterical inquisitions. Leaving me by myself and alone with my thoughts I couldn?t help but panic even worse now. This was a total bombshell of confusion on my part, what had i done wrong? Minute?s later a large?framed women in a green uniform entered the room with the guards from before and sat down across from me with a stern look in her eyes. She placed my documents on the desk in between us. Not saying a word to me she was waiting for me to give her an explanation for something. ?Can you please tell me what this is about, have i done something wrong?? I asked her politely, trying to restraint any animosity towards her. Her reply sounded as grim as she looked. ?You have been in Thailand for three months and now you have only a one way ticket booked to Australia with no visa. What exactly are your pians once you get there, Ms. Roberts?? To myselfl wondered what business it was to her, don?t people travel with one-way tickets all the time? Knowing Iwas in no position to be able to say anything like that or even at all Ijust gave in nicely and told her my intentions to travel over there. Crying through my entire explanation i wasn?t sure if] was going to even make my ?ight now. She had to think about everything I had told her for a moment, deciding whether or not she would grant me permission to meet my husband in Australia or send me back alone to Bangkok. With only time on my side she had to make a hasty verdict now. One more question had to be answered before was let go, she wanted some proof. if you have just got married can you show me your marriage certificate then?? This didn?t help my stories credibility at all seeing that we were married in a Buddhist temple and given woven bracelets instead of certi?cates. Explaining to her that I didn?t have one to show her yet but was already aware that 1 would have to obtain a legal marriage certificate through a courthouse upon my arrival in Australia to stay there legally, it was only because of my husbands beliefs we wanted to get married in a Buddhist ceremony. She must have shared a common interest in religion or something like that as she ?nally cracked a smile upon the photos of the wedding day that 1 showed her and carrying in my purse since getting them developed, if she wanted proof, well this is all I reaily had. Handing me back my documents and ticket I was now free to leave but she wasn?t leaving me much time to run through the airports terminal to get to my departing plane. Expeditiously bolting through the busy airport 134 npyright Protected Material Copyright Material Case 18-2868, Document 278, 08/09/2019, 2628230, Page631 of 648 my adrenaline was still pumping from the previous encounter with the of?cials ofthe Philippines who had enough power to condemn me ifthey had felt like it. I caught my plane in the knick of time and once I was settled in my seat my thoughts went back to my dear Robbie and how much I was missing him. Iwas just relieved that back with him again soon. Looking out the window 1 could see the red earth beneath me. As I landed for the last time I took notice ofthe first steps I walked off the plane and onto a new soil for the ?rst time. I had so much to be looking forward too in my new homeland. In my heart I knew this was all I ever wanted, this was going to be my haven. There was another surprise in store for me when two elder strangers walked up to me and asked my name. ?Are you Jenna?? Nodding at their question they gave me their first names and wrapped their arms around my neck. My new mother-in law then said, We are Robbie?s parents. We wanted to be the first ones who welcomed you to Australia and into our family? It was my in-laws meeting me for the first time. Handing me some balloons and ?owers they even had gifts for their new daughter-in law. While waiting for Robbie?s plane to arrive we all chatted about many things like the ?ight over from Thailand and the scare at the previous airport in the Philippines. I asked them how they knew whom to look for? My father in law laughed, saying recognizing me was easy from Robbie?s detailed description. He told them to look out for a petite, young blonde carrying an abundance of luggage. Laughing together over a few more brief conversations of getting to know each other better they seemed relieved to finally meet me compared how stressed she sounded in the conversations I overheard Robbie having with her while in Thailand. Watching the arrivals board I knew Robbie?s plane had landed ages ago but was just waiting for him to get out of customs. It didn?t bother me anyhow, was enjoying get accompanied with his parents for the first time. Eventually I saw my husband walking down the runway behind the gates, Ijust couldn?t wait a second longer. I ducked underneath the gates and ran all the way up the runway to jump excitedly into his arms. I wrapped my arms and legs around him holding onto him for dear life. I just missed him so much I knew I would never let him go, theoretically speaking that is, and I never have nearly a decade later. Chapter 24 Over the near decade we spent together, Robbie and I have shared the common highs and lows that every determined marriage endures. It has 135 GIUFFREO 0426 8 taken a lot of hard work and doesn?t come without its flaws but no matter what it is just perfect for the two of us. He helped me how to remember to smile again and life has slowly began to sort itself out, They say that time heals all wounds but what I had experienced in my young years wasn?t nearly long enough to let all of the hurt go. Seeking help through many counselors and I was doing everything I could do to deal with the scars and all ofthe pain left behind. Completely off of any pharmaceuticals, since the last day of our honeymoon, and healing my heart with love instead of hate our marriage is my foundation and Robbie is my solid rock. We have to be for one another, putting the bonds of our union through the wringers and back, as neither of us expected my past life eventually to come back and haunt me after so long. Our blissful life came to a sudden halt one day when we were out visiting my in-laws at their nearby house on just another plain afternoon. There was a knock on the front door and my father in law got up from watching TV on the couch to answer it. He rushed back quickly coming into the dining room, where I was feeding my nineteen months and five month old boys at the table, and he blurted out, ?Jenna there are three police officer?s at the door asking for you by the name of Virginia Roberts!? I asked my mother in law to stay with the babies to find out what this was all about. I didn?t even think it had anything to do with Jeffrey at ?rst and wasn?t even worried when I opened the door to offer them to come inside to talk. They weren?t actually police officers and two federal agents of Australia with one F.B.I agent from America. The American agent asked ifI wouldn?t mind actually coming outside so that I may speak with them in private. ?Okay? I said, as well as mentally preparing myself for something big from the look ofit, it?s not over a parking ticket or anything small that you get three federal agents knocking at your in-laws front door asking to speak in private. ?Can we first ask you ifyou are in fact Ms. Virginia Roberts and originally from Palm Beach County in the United States?? I confirmed my name and previous state of residence then they even asked, ?May we see some identification please?? A different agent asked the question this time and I told him will have to go and grab it, my purse is inside. I?ll just be one second.? Robbie was standing on the other side of the door trying to figure out what they were doing here talking to me and when I rushed through it to grab my purse and saw him standing there looking puzzled, I told him I had no idea what this was about yet, but not too worry everything was going too be just ?ne. Taking a deep breath and slowly exhaling outwards, I opened the door to find out exactly what the agents wanted to talk about. 136 El Copyright Protected Material CONFIDENTIAL . Case 18-2868, Document 278, 08/09/2019, 2628230, Page632 of 648 Pulling out my Australian drivers license from my wallet, I was going to hand it over to them but they were suf?ced at a quick glance. There was no meet and greet, they went straight to the point. One agent picked up a briefcase off the porch ?oor and opened it up taking out a stapled stack of paper. Then that same agent asked me ifI had ever known an af?liate by the name of Mr. Jeffrey Epstein. All ofthe sudden my stomach tangled in a familiar knot that I hadn?t felt in many years from a past life that I was trying to forget about. I nodded in affirmation of their question and said ?It was a long time ago and he?s no longer an affiliate of mine, but yes, I did know him once." It was shameful enough to think about let alone talk about with them for the first time since I had started my entire life over. His next response left me nothing short of speechless. The United States Attorney?s Of?ce for the district of Florida was giving me a notification of being an identified victim, Jeffrey was ?nally caught for his atrocious acts of perversion on girls who were barely old enough to even comprehend ?the birds and the bees? so to speak. On June 30f" 2008, Jeffrey Epstein pleaded guilty for procurement of minors to engage in and solicitation of prostitution. More than a dozen girls had been named as victims of Jeffrey?s federal offense?s and without ever stepping a day in court he was granted a plea bargain consenting to charges that named him a registered pedophile for only two of the minor girls. Getting away with even serving only twelve of the sentenced eighteen months behind bars be that in the evening alone and in the morning he was released during the day. Restricted to the con?nement of his lavish mansion in Palm Beach only to be with his original sex slaves from over ten years ago, Nadia Marcinkova and Sarah Kellen, and knowing Jeffrey all too well, they wouldn?t be the only ones there while he was pulling his laughing stint of retribution. Even at nighttime the girls were still allowed to visit him, accounting to nearly seventy times while serving his time in incarceration. No justice had been served for any of us victims. Denied the very constitutional rights allegedly there to protect and serve us. We weren?t allowed to have a voice in front ofajury andjudge or even informed for that matter. Instead we were handed this noti?cation of being a victim but told we were all too late to do anything about. To make matters worse part of that plea bargain was that we had the option to sue him with the lawyers he provided for us, and conveniently enough I found out later they were also his lawyer?s old friends from the college days. I felt my knees go weak and the anxiety churning in my stomach was now making me feel sick. Taking the bundle of paperwork from the agent who was now handing it to over me, I had to excuse myself before my legs actually buckled. Closing the door behind me I couldn?t even ?nd the words to tell my husband what was going on, I rushed to the back of 137 Co ?gli ?rntectcd Material l?lAL the house and went out to the back yard where I wanted a minute to compose myself and process the information I had just been told. Robbie followed behind me but the stillness in my eyes convinced him to give me that moment to compile my emotions. A few moments later and I was ready to talk. Collapsing into his arms with such anguish, he just held me until my sobs subsided and I was able to tell him what actually happened. Starting with an apology, I began to tell him how Iwas so sorry but my troubled past has come back to plague our simply sweet lives and was just about to turn it all upside down. He was so understanding from the beginning of all this, telling me that he will always be behind every choice that I make in mending the sorrows of my tormenting past and there he has been through all of the thick and thins. Deciding to call the lawyers on the victim suit provided for me was a. big decision but one 1 had to do to seek the unanswered questions from my battered heart. The two women at the ?rm that I spoke to treated me so wonderfully, like long term friends they counseled me not only in the terms ofa lawsuit towards Jeffrey but also in the matters of being emotionally and sexually abused. I chose to proceed with the lawsuit at least to make a statement to a man that tried to make a degrading statement about me so long ago. Now it was my turn, I had the choice to turn the tables on him hoping he would feel embarrassed and in the spotlight for everyone?s entertainment where he had kept me for so many years. Winning my lawsuit against him was not enough to heal old wounds, I never got the chance to stand up in front ofa jury and tell them how much pain I had endured and still endure throughout the many nightmares I face when darkness hits and the silence of the sleeping household ?lls my head with pictures of reliving my past with him or the others he sent me too. Or did I even get to hear him confess his guilt and suffer the way I did locked in con?nement for many years? No, instead I got to see a picture of Jeffrey with his arms around a very youthful looking teenager, if even that, parading the streets of New York, the very way he had with me and so many other girls long before. As if it were a public display intended for not only his many victims to see but also a spectacle for the public justice system, it was bold show of insolence laughing in our faces while we all sat by not being able to do anything to help these young girls from the streets still suffering his perverted af?ictions. Not much longer there was another story on Jeffrey I saw in the papers of him and Prince Andrew having a stroll together in Central Park. It instantly ?sparked my concerns for other girls in the very same position I was in so long ago and he was obviously up to the same old tricks, I had to do something now. Not being able to sit by any longer 138 Copyright Protected Material . Case 18-2868, Document 278, 08/09/2019, 2628230, Page633 of 648 with the knowledge of being able to help out in some way. I had to tell my story no matter how shameful it was to even speak about. Putting my shame aside I had to derive every bit of courage I could sustain and now I am ready to tell it. The hardest lesson I had failed at leaming until later on in my life became my strength, the belief in my inner voice and the ability to speak up. I do have a voice and now the world is going to hear it in my whispered cries forjustice. Swept away by a surge of media with one phone call I sent Jeffrey?s publicist into frenzy. Not to mention the release of the photos showing the first night that Prince Andrew and I shared together that I so happened to unveil for the public to see. I spent too much of my life going out of my mind waiting for the rescue that never came until it was too late and then the scars were already imbedded deeply within. Thankfully I am now free from the struggles that nearly destroyed. the love inside of my heart. I only wish it could be the same for the other victims, notjust ofJeffrey?s in?ictions but every person who has ever suffered at the hands of another. I?m here to tell you from my own experience that the moon is yours if that?s what you want, all you have to do is stand up and take it. If some girl off the streets of Florida, like me, can stand up against the tyrants that run the deep pockets of our world, than anyone can. Just iike I needed to believe that someone stood up for me once like Robbie did long ago, I now stand girls, the ones who are still on the streets and think they don?t deserve better or it?s an unachievable dream to be entitled to more out of life. For all of the beautiful girls who don?t see beyond they?re outside appearance. For all the girls still trapped in enslavernent and unable to get out ofthe abuse that holds them down. But most of all, I stand up for every girls beliefin love, because it is the very savior ofmy spirit and soul. The End Written and Illustrated by Virginia Roberts 139 140 1! Protected Material Ll Copyright Protected Material CON IDLN l?lAl. GIUFFILE004272 CON FIDENTIAL GIU 14151th 04273 1 Case 18-2868, Document 278, 08/09/2019, 2628230, Page634 of 648 141 CO [wright Protected Material CONFIDEN TLAL GIUFFRE004274 Case 18-2868, Document 278, 08/09/2019, 2628230, Page635 of 648 EXHIBIT LL . Case 18-2868, Docu?r?enEiEig 8?]?Iaj88129l?g?i8?ng Page636 of 648 In compiiance with Chapter 61?, ES, (Not for Pro?t) . - The name ofthe corporation shaiE be: Refuse Silence? Inc. ARTICLE PRINCIPAL OFFICE Principai street address: 425 North Andrews Ave, Suite 2 Fort Lauderdale, FL 33301 Mailing address, if different is: ARTICLE PURPOSE . . . . Refuse Stlence, Inc. ES organized exctusrvety for chantabie and The purpose for which the corporation is organized 15: educationai purposes inctuding, for such purposes, the making of distributions to organizations that quatify as exempt organizations under section 501(c)(3) of the internai Revenue Code, or the corresponding section of any future federai tax code. The corporation is organized to provide assistance to victims of sexuai abuse as weii as victims of human traf?cking. Upon the dissoiution of Victims Refuse Silence, inc, assets shalt be dEstributed for one or more exempt purpose within the meaning of section 501(c)(3) of the Internal Revenue Code, or corresponding section of any future federat tax code, or shati be distributed to the federai government, or to a state or ioca! government, for a pubiic purpose. WTM manner in which the directors are eiected and appointed: The manner in which the directors are elected or appointed is provided in the bylaws of the Corporat?on. ARTICLE INITIAL OFFICERS DWTURS Name and Roberts, Director Name and Titie: (51733?; 52, if": Address 425 North Andrews Ave. Address: .- r" Surte 2 1. 3 ,3 Fort Lauderdale, FL 33301 535:: . sits? Name and We: Bradley J. Edwards, Director Name and We: Address 425 North Andrews Ave. Address: Suite 2 Fort Lauderdale, FL 33301 Name and We: Brittany N. Henderson, Director Name and Tide: Address 425 North Andrews Ave. Suite 2 Fort Lauderdaie, FL 33301 Address: Case 18-2868, Document 278, 08/09/2019, 2628230, Page637 of 648 Name and Title: . . Name and Tide: Address Address: Name and Title: . Name and Tide: Address Address: ARTICLE VI REGISTERED AGENT The name Florida street add regs (PO. Box NOT aeceptabk) of the registered agent is: Name, Bradley .J. Edwards 3 Add 425 North Andrews Ave, Suite 2 E: TESS. ?52 ~91 Fort Lauderdale, FL 33301 :3 M, r" :71 ARTICLE VII INCORPORATOR The the Incorporater is: 53:; NW: Brittany N. Henderson Add 425 North Andrews Ave, Suite 2 T655. Fort Lauderdale, FL 33301 Having been named as registered agent to accept service afpracess for the above stated corporation at the place designated in this certi?cate, I a 'ar with and sweet get registered agent and agree to act in this capacig: RequimmeWgem Date I suemit this document and a?irm that thefacts stated herein are true, I am were that anyfatse infer-matter: submitted in a document to Department ofStete constitutes a third degree fetony as previrz?edfar in $811155, ES. pzeggmg Require Signatureo ncorperater Date 2015 FLORIDA P398638 Apr 22, 2015 N1400001165T Secretary of State Entity Name: VICTIMS REFUSE SILENCE, INC. 007301725405 Current Principal Place of Business: 425 NORTH ANDREWS AVE., SUITE 2 FORT LAUDERDALE, FL 33301 Current Mailing Address: 425 NORTH ANDREWS AVE., SUITE 2 FORT LAUDERDALE, FL 33301 FEI Number: 47-2627774 Certificate of Status Desired: Yes Name and Address of Current Registered Agent: EDWARDS, BRADLEY 425 NORTH ANDREWS AVE., SUITE 2 FORT LAUDERDALE, FL 33301 US The above named entity submits this statement for the purpose of changing its registered office or registered agent, or both, in the State of Florida. SIGNATURE: Electronic Signature of Registered Agent Date Officer/Director Detail Title PRESIDENT, DIRECTOR Title VP, DIRECTOR Name GIUFFRE, VIRGENEA Name GARVIN, MARGARETA Address 425 NORTH ANDREWS AVE., SUITE 2 Address 425 NORTH ANDREWS AVE., SUITE 2 City-State-Zip: FORT LAUDERDALE FL 33301 City-State-Zip: FORT LAUDERDALE FL 33301 Title SECRETARY, DIRECTOR Name HENDERSON, BRITTANY Address 425 NORTH ANDREWS AVE., SUITE 2 City-State-Zip: FORT LAUDERDALE FL 33301 I hereby certify that the information indicated on this report or supplemental report is true and accurate and that my electronic signature shall have the same legal effect as if made under oath; that I am an officer or director of the corporation or the receiver or trustee empowered to execute this report as required by Chapter 617, Florida Statutes; and that my name appears above, or on an attachment with all other like empowered. SIGNATURE: BRITTANY HENDERSON DERECTOR 04/22/2015 Electronic Signature of Signing Officer/Director Detail Date Case 18-2868, Document 278, 08/09/2019, 2628230, Page639 of 648 EXHIBIT MM Case 18-2868, Document 278, 08/09/2019, 2628230, Page640 of 648 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO: 15-cv-07433-RWS VIRGINIA L. GIUFFRE, Plaintiff. -vsGHISLAINE MAXWELL, Defendant. ______________________________________/ 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Thursday, September 8, 2016 8:53 a.m. - 10:30 a.m. VIDEOTAPED DEPOSITION OF BRITTANY HENDERSON Taken before Rinat Katz, Reporter, a Notary Public for the State of Florida at Large, pursuant to Notice of Taking Deposition filed in the abovestyled cause. Case 18-2868, Document 278, 08/09/2019, 2628230, Page641 of 648 1 2 3 4 5 6 APPEARANCES: On Behalf of the Plaintiff: BOEIS, SCHILLER & FLEXNER, P.A. 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, Florida 33301 Smccawley@bsfllp.com BY: SIGRID MCCAWLEY, ESQUIRE On Behalf of the Plaintiff and Victims Refuse Silence, Inc.: 7 8 9 10 11 12 13 14 FARMER JAFFE WEISSING EDWARDS FISTO LEHRMAN 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Brad@pathtojustice.com BY: BRADLEY J. EDWARDS, ESQUIRE On Behalf of the Defendant: HADDON, MORGAN & FOREMAN 150 East 10th Avenue Denver, Colorado 80203 (303) 831-7364 Jpagliuca@hmflaw.com BY: JEFFREY PAGLIUCA, ESQUIRE 15 Also Present: 16 Ryan Kick, Videographer 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page642 of 648 Page 3 INDEX OF PROCEEDINGS 1 2 VIDEO DEPOSITION OF BRITTANY HENDERSON 3 Direct Examination by Mr. Pagliuca 4 Certificate of Oath 73 Certificate of Reporter 74 Witness Letter 75 Errata Sheet 76 5 PAGE 4 6 DEFENDANT'S EXHIBITS 7 8 NUMBER DESCRIPTION PAGE 9 Exhibit 1 Amended NOD 14 10 Exhibit 2 Motion to Quash Composite 20 11 Exhibit 3 Bates Stamped 01 - 064 31 12 Exhibit 4 Bates Stamped 064 - 091 32 13 Exhibit 5 Articles of Incorporation 36 14 Exhibit 6 Bank Statements 41 15 Exhibit 7 2015 Annual Report 62 16 Exhibit 8 2016 Annual Report 62 17 18 19 20 21 22 23 24 25 (Exhibits Retained by the Court Reporter) Case 18-2868, Document 278, 08/09/2019, 2628230, Page643 of 648 Page 17 1 she has continued to try and promote Victims Refuse 2 Silence at every possible chance she gets with -- the 3 story she told me was that someone had come to her 4 door, knocked on the door, selling something or talking 5 about something totally different, and she explained 6 what our mission was and tried to get them to, then, go 7 and spread the word for victims of human trafficking, 8 as well. 9 10 Q And this would be in Australia this conversation occurred? 11 A Correct. 12 Q Okay. 13 To your knowledge, is VRS incorporated in any fashion in the country of Australia? 14 A It is not. 15 Q To your knowledge, does VRS have any website 16 17 presence in Australia? A I believe that the internet works everywhere, 18 so I would say yes, because, if you Google Victims 19 Refuse Silence, we do have a website. 20 imagine that that's something that would come up in 21 Australia. 22 Q Okay. So I would Other than the somebody knocking at 23 her door, that conversation, did she report to you 24 anything else that she has done on behalf of Victims 25 Refuse Silence in the last year, let's say? Case 18-2868, Document 278, 08/09/2019, 2628230, Page644 of 648 Page 18 1 MR. EDWARDS: Objection -- 2 THE WITNESS: During this telephone 3 4 conversation -BY MR. PAGLIUCA: 5 Q Yes. 6 A -- or in general? 7 Q During this telephone conversation? 8 A She did explain that, when she goes to her 9 kids' schools and when she is out, she tries to promote 10 the organization, as well, and just talk to people, and 11 general awareness and understanding to raise -- for 12 issues of human trafficking, yes. 13 14 Q And did she report anything else to you during this phone conversation? 15 A During this particular conversation? 16 Q Yes. 17 A No. 18 Q Okay. Then, you indicated that you reviewed 19 your file for all the paperwork, and we'll talk about 20 the documents produced in this case in a moment. Can you tell me, other than what has been 21 22 produced as part of the response to subpoena issued to 23 VRS, what other documents are in the file that you 24 reviewed? 25 A I have saved every piece of mail that has Case 18-2868, Document 278, 08/09/2019, 2628230, Page645 of 648 Page 27 1 "publication," would be the Facebook page; correct? 2 A In addition to the website, yes. 3 Q Okay. Number 11, documents relating to all 4 appearances. As I understand it, there are no 5 documents that exist that comply with this request; 6 correct? 7 A Correct; to my knowledge. 8 Q Do you know, has anybody on behalf of VRS 9 10 11 made a public appearance on behalf of VRS? A I believe that there was a scheduled appearance, yes, one. 12 Q And when was that? 13 A I honestly don't know when that took place. 14 15 16 I would imagine in the beginning of 2015. Q And do you know who was scheduled to appear in the beginning of 2015? 17 A Ms. Giuffre. 18 Q And do you know where she was scheduled to 19 appear? 20 A I believe in New York with ABC. 21 Q And that would have also been with Mr. 22 Edwards and Ms. McCawley; is that correct? 23 A I believe so, yes. 24 Q And in fact, she did go to ABC and give a 25 taped interview, correct? Case 18-2868, Document 278, 08/09/2019, 2628230, Page646 of 648 Page 28 1 MS. MCCAWLEY: 2 THE WITNESS: 3 4 5 6 Objection. It's my understanding, yes. BY MR. PAGLIUCA: Q Okay. Is it your understanding that that was on behalf of VRS? A I do not believe her appearance there was 7 made on behalf of VRS, but I do believe that -- I know 8 that she wanted to promote the charity, so that we 9 could start helping people and that she could start 10 11 getting her mission out to the public. Q Okay. Number 12, all contacts received by 12 VRS through its website, or otherwise, to schedule -- I 13 think it should say "an event," and "and event." There are none of those, as I understand it? 14 15 A No, that is not correct. We produced a -- 16 yes, we did produce something to you. 17 what the Bates Stamp number is, but it was a contact 18 received by another victim of sexual assault who had 19 reached out to the organization. 20 21 Q An email, I think it's in December of 2015, maybe; is that what you're referring to? 22 A 23 guess. 24 Q 25 I'm not sure I believe -- I'm not sure of the date. We'll look at it. I And that would be the only contact received by VRS; is that correct? Case 18-2868, Document 278, 08/09/2019, 2628230, Page647 of 648 Page 72 1 C E R T I F I C A T E OF OATH 2 3 STATE OF FLORIDA 4 COUNTY OF BROWARD 5 6 7 I, Rinat Katz, Reporter, Notary Public, State 8 of Florida, certify that BRITTANY HENDERSON 9 personally appeared before me on the 8th day of 10 September, 2016, and was duly sworn. 11 12 Signed this 22nd day of September, 2016. 13 14 15 _________________________________ Rinat Katz, Reporter 16 Notary Public, State of Florida Commission No.: FF4576 17 18 19 20 21 22 23 24 25 Commission Expires: 04-03-2017 Case 18-2868, Document 278, 08/09/2019, 2628230, Page648 of 648 Page 73 CERTIFICATE OF REPORTER 1 2 3 STATE OF FLORIDA 4 COUNTY OF BROWARD 5 6 I, Rinat Katz, Reporter, certify that I was 7 authorized to and did report the deposition of 8 BRITTANY HENDERSON, that a review of the 9 transcript was requested; and that the transcript 10 is a true and correct record of my stenographic 11 notes. 12 I further certify that I am not a relative, 13 employee, attorney, or counsel of any of the 14 parties, nor am I a relative or employee of any of 15 the parties' attorneys or counsel connected with 16 the action, nor am I financially interested in the 17 action. 18 Dated this 22nd day of September, 2016. 19 20 21 ____________________________________ Rinat Katz, Reporter 22 23 24 25 Selected docket entries for case 18−2868 Generated: 08/09/2019 10:17:16 Filed Document Description 08/09/2019 279 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED 08/09/2019 280 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED 08/09/2019 281 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED 08/09/2019 282 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED Page Docket Text 2 UNSEALED SUMMARY JUDGMENT RECORD, appendix 5 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628231] [18−2868] 39 UNSEALED SUMMARY JUDGMENT RECORD, appendix 6 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628232] [18−2868] 113 UNSEALED SUMMARY JUDGMENT RECORD, appendix 7 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628234] [18−2868] 179 UNSEALED SUMMARY JUDGMENT RECORD, appendix 8 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628236] [18−2868] Case 18-2868, Document 279, 08/09/2019, 2628231, Page1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X Plaintiff, v. GHISLAINE MAXWELL, Defendant. ............................................. VIRGINIA L. GIUFFRE, 15-cv-07433-RWS --------------------------------------------------X Reply Brief in Support of Defendant’s Motion for Summary Judgment Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 303.831.7364 Case 18-2868, Document 279, 08/09/2019, 2628231, Page2 of 37 TABLE OF CONTENTS PRELIMINARY STATEMENT ......................................................................................... 1 ARGUMENT....................................................................................................................... 2 I. Ms. Maxwell is not liable for republications of the January 2015 statement. .............. 2 A. Plaintiff’s argument against summary judgment is substantially groundless. 2 B. New York state and federal courts have rejected liability for republication based on “foreseeability.” ................................................................................ 5 C. Plaintiff’s purported application of the Geraci rule is misleading and wrong. ......................................................................................................................... 6 D. Subjecting Ms. Maxwell to liability for the media’s republication of excerpts they unilaterally selected is particularly unfair. .............................................. 9 E. Mr. Barden’s declaration is perfectly proper. ................................................ 11 F. Plaintiff effectively has confessed Arguments I.B. and I.C. of the Memorandum................................................................................................. 12 II. The January 2015 statement is constitutionally protected opinion. ............................ 12 III. The pre-litigation privilege bars this action. ............................................................... 20 A. The privilege applies to the January 2015 statement. ................................... 20 B. Malice is irrelevant to the pre-litigation privilege. ........................................ 21 IV. Ms. Maxwell’s January 4, 2015, statement is nonactionable. .................................... 25 V. Summary judgment is warranted because plaintiff cannot establish falsity or actual malice by clear and convincing evidence. .................................................................. 25 CONCLUSION ................................................................................................................. 30 CERTIFICATE OF SERVICE .......................................................................................... 32 i Case 18-2868, Document 279, 08/09/2019, 2628231, Page3 of 37 TABLE OF AUTHORITIES Cases Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). .............................................. 9 Blair v. Inside Ed. Prods., 7 F. Supp. 3d 348, 358 & n.6 (S.D.N.Y. 2014) ...................... 25 Cerasani v. Sony Corp., 991 F. Supp. 343, 351 (S.D.N.Y. 1998)................................... 3, 4 Chambers v. Wells Fargo Bank, N.A., No. CV 15-6976 (JBS/JS), 2016 WL 3533998, at *8 (D.N.J. June 28, 2016) .......................................................................................... 2, 20 China Med. Techs., Inc., 539 B.R. 643, 658 (S.D.N.Y. 2015) .......................................... 12 Cowan v. City of Mount Vernon, 95 F. Supp. 3d 624, 645-46 (S.D.N.Y. 2015) ......... 13,25 Croy v. A.O. Fox Mem’l Hosp., 68 F. Supp. 2d 136, 144 (N.D.N.Y. 1999) ....................... 3 Dalbec v. Gentleman’s Companion, Inc., 828 F.2d 921, 927 (2d Cir. 1987) ................... 25 Davis v. Boeheim, 22 N.E.3d 999 (N.Y. 2014) ............................................................ 14,18 Davis v. Costa-Gavras (“Davis I”), 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984) ....... 2,3,4,6 Davis v. Costa-Gavras (“Davis II”), 595 F. Supp. 982, 988 (S.D.N.Y. 1984) ................... 3 Dibella v. Hopkins, No. 01 CIV. 11779 (DC), 2002 WL 31427362, at *2 (S.D.N.Y. Oct. 30, 2002) ........................................................................................................................ 20 DiBella v. Hopkins, 403 F.3d 102, 111 (2d Cir.2005) ...................................................... 25 Egiazaryan v. Zalmayev (“Egiazaryan I”), No. 11 CIV. 2670 PKC, 2011 WL 6097136, at *5 (S.D.N.Y. Dec. 7, 2011) ............................................................................................. 3 Egiazaryan v. Zalmayev (“Egiazaryan II”), 880 F. Supp. 2d 494, 501 (S.D.N.Y. 2012) ................................................................................................................................... 3,4,5 Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906) ............................................................ 2,4 Front, Inc. v. Khalil, 28 N.E.3d 15, 16 (N.Y. 2015) ................................. 2, 20,21,22,24,25 Geraci v. Probst, 938 N.E.2d 917, 921 (N.Y. 2010) ..................................... 2,3,5,6,8,10,13 ii Case 18-2868, Document 279, 08/09/2019, 2628231, Page4 of 37 Green v. Cosby, 138 F. Supp. 3d 114 (D. Mass. 2015) ..................................................... 14 Hawkins v. Harris, 661 A.2d 284, 289-91 (N.J. 1995) ................................................. 2, 20 Hickman v. Taylor, 329 U.S. 495, 510-11 (1947) ............................................................. 12 Hoffman v. Landers, 537 N.Y.S.2d 228, 231 (2d Dep’t 1989) ........................................... 5 Immuno AG v. Moor-Jankowski, 567 N.E.2d 1270, 1274 (N.Y. 1991) ............................ 13 Karaduman v. Newsday, Inc., 416 N.E.2d 557, 560 (N.Y. 1980) ....................................... 3 Karedes v. Ackerley Grp., Inc., 423 F.3d 107, 114 (2d Cir. 2005) ................................... 26 Law Firm of Daniel P. Foster, P.C. v. Turner Broad. Sys., 844 F.2d 955, 959 (2d Cir. 1988). ................................................................................................................. 15, 28, 29 Levy v. Smith, 18 N.Y.S.3d 438, 439 (2d Dep’t 2015) ........................................................ 5 Liberman v. Gelstein, 605 N.E.2d 344, 349 (N.Y. 1992) .................................................. 22 National Puerto Rican Day Parade, Inc. v. Casa Pubs. (“NPR”), 914 N.Y.S.2d 120, 12223 (1st Dep’t 2010) ........................................................................................................... 5 Ollman v. Evans, 750 F.2d 970 (D.C. Cir. 1984) .............................................................. 13 Phila. Newspapers v. Hepps, 475 U.S. 767, 773 (1986). .................................................. 26 Porky Prods. v. Nippon Exp. U.S.A., 1 F.Supp.2d 227, 234 (S.D.N.Y. 1997) .................... 2 Rand v. New York Times Co., 430 N.Y.S.2d 271, 275 (1st Dep’t 1980) ....................... 9, 10 Rinaldi v. Viking Penguin, Inc., 420 N.E.2d 377, 382 (N.Y. 1981) .............................. 2,3,7 Rinaldi v. Viking Penguin, Inc., 425 N.Y.S.2d 101, 104 (1st Dep’t 1980) .......................... 3 Rizzuto v. Nexxus Prod. Co., 641 F. Supp. 473, 481 (S.D.N.Y. 1986), aff’d, 810 F.2d 1161 (2d Cir. 1986) ....................................................................................................... 16 Schoepflin v. Coffey, 56 N.E. 502 (N.Y. 1900) ................................................................ 3,5 Steinhilber v. Alphonse, 501 N.E.2d 550 (N.Y. 1986) ............................................ 11,13,16 iii Case 18-2868, Document 279, 08/09/2019, 2628231, Page5 of 37 Sweeney v. Prisoners’ Legal Servs. of N.Y., 538 N.Y.S.2d 370, 371-72 (3d Dep’t 1989). ....................................................................................................................................... 19 Telephone Sys. Int’l v. Cecil, No. 02 CV 9315(GBD), 2003 WL 22232908, at *2 (S.D.N.Y. Sept. 29, 2003)........................................................................................ 16, 30 Travelers Indem. Co. v. Northrop Grumman Corp., No. 12 CIV. 3040 KBF, 2013 WL 3055437, at *3 (S.D.N.Y. Apr. 22, 2013) ..................................................................... 12 United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). ..................................... 25 Rules Federal Rule of Civil Procedure 12(b)(6) ............................................................................ 5 Treatises Sack on Defamation § 2.7.2, at 2-113 to -114 (4th ed. 2016) .............................................. 4 iv Case 18-2868, Document 279, 08/09/2019, 2628231, Page6 of 37 PRELIMINARY STATEMENT Before the Court reaches the question whether plaintiff can prove falsity and actual malice, it should decide three questions of law, one that narrows considerably the legal issues and two that dispose of the case entirely. 1. It is undisputed Ms. Maxwell, through her agents, sent to various mediarepresentatives—and to no one else—the January 2015 statement. It is undisputed she had no control over any of the media that decided to republish excerpts from the statement. On these facts, under black letter New York law, she is not responsible for these republications. Plaintiff’s contrary argument relies on a “foreseeability” doctrine the New York Court of Appeals has specifically rejected. Summary judgment should enter in favor of Ms. Maxwell as to any republication. 2. Under the New York Constitution, whether a statement is constitutionally nonactionable opinion depends upon, among other things, an examination of the full context of the communication and consideration of the setting surrounding it. The January 2015 statement, making no reference to specific allegations, explains why the author believes plaintiff’s allegations are “obvious lies”: “Each time the story is re told [sic] it changes with new salacious details . . . .” It is an expression of a venerable opinion: when a person falsely cries wolf previously, others are free to opine she is telling falsehoods now. This is nonactionable opinion. 3. Under New York law, a statement made pertinent to good faith anticipated litigation is nonactionable. The statement was sent exclusively to the media representatives, and contained a clear message: the media should not republish plaintiff’s “obvious lies,” else Ms. Maxwell would sue them. Such a statement is nonactionable. If the Court reaches the question of falsity and actual malice, the Rule 56 record establishes plaintiff cannot prove falsity and actual malice by clear and convincing evidence. 1 Case 18-2868, Document 279, 08/09/2019, 2628231, Page7 of 37 ARGUMENT I. Ms. Maxwell is not liable for republications of the January 2015 statement. Under black letter New York law, liability for republication of an allegedly defamatory statement “must be based on real authority to influence the final product.” Davis v. CostaGavras, 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984). “[W]here a defendant ‘had no actual part in composing or publishing,’ he cannot be held liable.” Id. (citing Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906)); accord Geraci v. Probst, 938 N.E.2d 917, 921 (N.Y. 2010). “[C]onclusive evidence of lack of actual authority [is] sufficiently dispositive that the [trial court] ‘ha[s] no option but to dismiss the case . . . .’” Id. (emphasis supplied; quoting Rinaldi v. Viking Penguin, Inc., 420 N.E.2d 377, 382 (N.Y. 1981)). It is undisputed Ms. Maxwell and her agents had no ability to control and did not control whether or how the media-recipients would use the statement. DOC. 542-7, Ex.J ¶¶ 2-3; id., Ex.K ¶ 24. Unsurprisingly, plaintiff has offered no evidence of such control. A fortiori this Court “ha[s] no option but to dismiss the case,” id. (internal quotations omitted), to the extent it is founded upon the media’s republication of the statement. A. Plaintiff’s argument against summary judgment is substantially groundless. A legal argument is frivolous if it is presented contrary to a “long line of authorities” and the “fundamental principles”1 of the underlying substantive law. Plaintiff Giuffre’s argument opposing summary judgment as to republication is frivolous. The New York Court of Appeals in Geraci followed a long line of New York cases holding that a defamation defendant is not liable for republication of his allegedly defamatory statement unless he had “actual authority” to control the decision to republish: “Our 1 Porky Prods. v. Nippon Exp. U.S.A., 1 F.Supp.2d 227, 234 (S.D.N.Y. 1997), aff’d, 152 F.3d 920 (2d Cir. 1998). 2 Case 18-2868, Document 279, 08/09/2019, 2628231, Page8 of 37 republication liability standard has been consistent for more than one hundred years.” See Geraci, 938 N.E.2d at 921 (footnote omitted). Indeed, the Geraci court observed, the New York Court of Appeals in Schoepflin v. Coffey,2 a case decided in 1900, held: “It is too well settled to be now questioned that one who . . . prints and publishes a libel[] is not responsible for its voluntary and unjustifiable repetition, without his authority or request, by others over whom he has no control and who thereby make themselves liable to the person injured, and that such repetition cannot be considered in law a necessary, natural and probable consequence of the original slander or libel.” 938 N.E.2d at 921 (emphasis supplied; quoting Schoepflin, 56 N.E. at 504). The cases in which this Court and its sister courts in this Circuit assiduously have followed this line of New York cases are legion.3 The Second Circuit was in the vanguard.4 2 56 N.E. 502 (N.Y. 1900). 3 See Egiazaryan v. Zalmayev, 880 F. Supp. 2d 494, 501 (S.D.N.Y. 2012) (“[t]he original publisher is not liable for republication where he had ‘nothing to do with the decision to [republish] and [he] had no control over it.’”) (quoting Rinaldi v. Viking Penguin, Inc., 425 N.Y.S.2d 101, 104 (1st Dep’t 1980), aff’d, 420 N.E.2d 377 (N.Y. 1981)); Egiazaryan v. Zalmayev, No. 11 CIV. 2670 PKC, 2011 WL 6097136, at *5 (S.D.N.Y. Dec. 7, 2011) (same); Davis v. Costa-Gavras, 595 F. Supp. 982, 988 (S.D.N.Y. 1984) (“Under New York law, liability for a subsequent republication must be based on real authority to influence the final product, not upon evidence of acquiescence or peripheral involvement in the republication process.”); Davis, 580 F. Supp. at 1094 (original publisher not liable for injuries caused by the republication “‘absent a showing that they approved or participated in some other manner in the activities of the third party republisher’”) (quoting Karaduman v. Newsday, Inc., 416 N.E.2d 557, 560 (N.Y. 1980)); Croy v. A.O. Fox Mem’l Hosp., 68 F. Supp. 2d 136, 144 (N.D.N.Y. 1999) (“The original author of a document may not be held personally liable for injuries arising from its subsequent republication absent a showing that the original author approved or participated in some other manner in the activities of the third-party republisher.”) (citations omitted); Cerasani v. Sony Corp., 991 F. Supp. 343, 351 (S.D.N.Y. 1998) (“a libel plaintiff must allege that the party had authority or control over, or somehow ratified or approved, the republication”). 4 See Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906) (affirming directed verdict in favor of managing editor: “when it appears affirmatively that he was not on duty [upon receipt of libelous matter and its republication], and could not have had any actual part in composing or publishing, we think he cannot be held liable without disregarding the settled rule of law by which no man is bound for the tortious act of another over whom he has not a master’s power of control”) (emphasis supplied), quoted with approval in Davis I, 580 F. Supp. at 1096; Cerasani, 991 F. Supp. at 351. 3 Case 18-2868, Document 279, 08/09/2019, 2628231, Page9 of 37 In the face of this uninterrupted line of New York state (and federal) cases dating back to the nineteenth century powerfully establishing a bright line rule regarding republication liability, plaintiff Giuffre manages what amounts to a—frivolous—murmur of opposition. She claims there are “[t]wo standards” in New York law: one “older,” and one “more modern.” Resp. 28. The “older” standard, plaintiff says, is represented by the legion of cases we have cited. The “more modern formulation”—where can it be found? Why, in one place: a treatise on defamation. Id. (citing Sack on Defamation § 2.7.2, at 2-113 to -114 (4th ed. 2016)). It surely is frivolous to argue that a treatise creates a republication-liability standard that is separate from, “more modern” than, and supersedes the New York Court of Appeals’ 2010 decision in Geraci and this Court’s 2012 decision in Egiazaryan. Trying to build on this start, plaintiff argues, “New York appellate courts have repeatedly held than an individual is liable for the media publishing that individual’s defamatory press release.” Resp. 28 (emphasis supplied). Even if we accept plaintiff’s mischaracterization of the January 2015 statement as a “press release,”5 her argument still would be meritless. To begin with, when plaintiff says the New York appellate courts have “repeatedly” supported her claimed rule of law, she means . . . twice. And an examination of those two cases reveals she is quite wrong and, worse, has advanced a seriously misleading argument. Neither case involved, as here, a motion for summary judgment. In both cases, the New York appellate division affirmed the denial of a motion to dismiss under the state’s equivalent of Federal Rule of Civil Procedure 12(b)(6). See Levy v. Smith, 18 N.Y.S.3d 438, 439 (2d Dep’t 2015); National Puerto Rican Day Parade, Inc. v. Casa Pubs. (“NPR”), 914 N.Y.S.2d 120, 122-23 (1st Dep’t 2010). 5 As discussed in This Reply, at 16-19, the January 2015 statement would be a strange “press release,” as it threatened to sue the very press to which it was “releasing” information. 4 Case 18-2868, Document 279, 08/09/2019, 2628231, Page10 of 37 This argument, too, is frivolous. Despite plaintiff’s baseless claim there is an “old” formulation and a “more modern” formulation of republication-liability law in New York, both cases she cites applied the same “old” standard used by the New York Court of Appeals in Geraci, by this Court in the two Egiazaryan cases, and by us in our Memorandum of Law in support of Ms. Maxwell’s motion for summary judgment. See Levy, 18 N.Y.S.3d at 439 (citing Geraci and Schoepflin); NPR, 914 N.Y.S.2d at 594-95 (citing Hoffman v. Landers, 537 N.Y.S.2d 228, 231 (2d Dep’t 1989) (citing Schoepflin)). Both the courts in Levy and NPR applied the Geraci standard and the 12(b)(6) standards, e.g., assuming the pleaded facts were true. They concluded it was possible to infer from the complaints’ allegations that the defendant caused the republications. Accordingly, they denied the motions to dismiss. See Levy, 18 N.Y.S.2d at 439; NPR, 914 N.Y.S.2d at 123. It was improper for plaintiff to cite these cases without disclosing they are 12(b)(6) cases in which the courts applied the Geraci republication rule and inferred facts from the pleaded allegations. B. New York state and federal courts have rejected liability for republication based on “foreseeability.” Plaintiff cites section 576 of the Restatement (Second) of Torts for the proposition that if republication was foreseeable, then the defendant is the cause of any special damages from the republication. This argument is frivolous. As an initial matter, plaintiff has pleaded no special damages. See Doc.1; Doc.23 at 23; Doc.37 at 17. Regardless, the New York Court of Appeals in Geraci rejected the Restatement’s foreseeability doctrine. See 938 N.E.2d at 921-22 (noting that section 576’s foreseeability standard “is not nearly as broad as plaintiff . . . suggest[s]” and “[t]hat we did not endorse such a broad [Restatement] standard of foreseeability in Karaduman is evident from our decision the following year in Rinaldi”) (emphasis supplied). 5 Case 18-2868, Document 279, 08/09/2019, 2628231, Page11 of 37 While trying to distinguish this Court’s decision in Davis, plaintiff fails to disclose that Davis itself—decided 26 years before Geraci—also rejected plaintiff’s foreseeability argument. The Davis plaintiffs, like plaintiff Giuffre here, also asserted republication liability, despite defendant’s lack of participation, on the ground “he could reasonably have foreseen that republication would occur.” 580 F.Supp. at 1096. This Court, relying on Karaduman, was unpersuaded: The New York Court of Appeals “has not applied the foreseeability standard suggested by plaintiffs in prior libel cases in which such a standard would have been relevant, if not controlling.” Id. This Court noted: The jurisdictions that have adopted a foreseeability standard “have refused to hold responsible a defendant with no control or influence over the entity that actually republished the statement.” Id. Plaintiff’s failure to disclose this Court’s holdings in Davis is a notable lapse in candor. C. Plaintiff’s purported application of the Geraci rule is misleading and wrong. Plaintiff eventually purports to apply the “old” standard, that is to say, the controlling law in the state of New York. She argues Ms. Maxwell “authorized” the January 2015 statement, “paid money to her publicist to convince media outlets to publish it,” “request[ed]” its publication, “made a deliberate decision to publish her press release,” “actively participated” in “the decision to publish her press release,” was “active” in “influencing the media to publish” the statement, and “approved of” and “pushed for” the publication of the statement. Resp. 30-31. These argument-manufactured facts have no record support. In applying the controlling law, plaintiff wittingly makes a mess of it. She disingenuously suggests any help Ms. Maxwell gave to help her lawyer prepare the January 2015 statement and her signing-off on it are the equivalent of requesting, authorizing and controlling its republication. That isn’t the law. The “authority” required for republication liability is the “actual authority . . . to decide upon or implement” the republication. 580 F.Supp. at 1095 6 Case 18-2868, Document 279, 08/09/2019, 2628231, Page12 of 37 (emphasis supplied; citing Rinaldi, 420 N.E.2d at 382). Judge Sofaer studied Rinaldi’s holding, and noted republication liability must be based on a “decision” by the defendant to republish and must focus on “real authority to influence the final product, not upon evidence of acquiescence or peripheral involvement in the republication process.” Id. at 1096 (emphasis supplied). Accordingly, Judge Sofaer held, when there is “conclusive evidence of lack of actual authority” this is “dispositive” of republication liability and the trial court “‘ha[s] no option but to dismiss the case against the [defendant].” Id. (emphasis supplied; quoting Rinaldi, 420 N.E.2d at 382). There is no evidence Ms. Maxwell “paid money to her publicist to convince” the media to publish her statement; this is why plaintiff cites no evidence to support that assertion. See Resp. 30. Mr. Gow’s email containing the statement says nothing to “convince” the media to publish the statement. See Doc.542-6, Ex.F. There is no evidence Ms. Maxwell was “active” in “influencing the media to publish” it; nor is there any evidence she “pushed for” or “requested” its publication; this is why plaintiff cites no evidence to support these assertions. See id. 31. Indeed, plaintiff has zero evidence Ms. Maxwell or her agents ever did anything to urge or request any media to publish the statement. Mr. Gow presented the January 2015 statement via email to six to thirty media representatives; it was not sent to anyone else; in the email he told the journalists he was presenting a “quotable statement” “on behalf of” Ms. Maxwell and “[n]o further communication will be provided.” Doc.542-6, Ex.F. It is undisputed Ms. Maxwell and her agents had no control over the media that republished portions of the statement. Doc.542-7, 542-7, Ex.J ¶¶ 2-3; id., Ex.K ¶ 24. Plaintiff argues “a jury” should decide whether Ms. Maxwell “authorized or intended” the statement to be republished, or “approved of, and even participated, in” its republication. Resp. 30-31. All plaintiffs want to get to “a jury.” The summary-judgment question is whether they deserve to. Plaintiff has offered no evidence to put before a jury on the dispositive Geraci 7 Case 18-2868, Document 279, 08/09/2019, 2628231, Page13 of 37 question: whether Ms. Maxwell affirmatively authorized or requested a person or entity “over whom [s]he has . . . control,” 938 N.E.2d at 921. The only new argument plaintiff makes in her entreaty to see “a jury” is that she should be permitted to prove Ms. Maxwell’s “complicity.” As with her other factually bereft arguments, the complicity argument awaits plaintiff’s introduction of facts to support it. Having failed to do so, plaintiff cannot avoid summary judgment. Plaintiff labors in vain to turn the Barden Declaration into “disputed issues of fact.” For there to be a disputed factual issue, plaintiff would need to introduce evidence disputing his sworn statements. She has not done so. In any event, the Barden Declaration is all but irrelevant to the central, dispositive republication question: whether Ms. Maxwell is liable for the media’s republication of her statement, where they did so without her authority or request and where she and her agents had “no control”6 over the media. On this question we cited to the Barden Declaration for one evidentiary fact: Messrs. Barden and Gow had no control over the media.7 See Doc.542-7, Ex.K ¶ 24, cited in Memo. of Law 14.8 Plaintiff has offered no admissible evidence disputing this fact. “[T]here is no issue for trial unless there is sufficient evidence favoring the nonmoving party for a jury to return a verdict for that party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). It is one thing to argue in conclusory fashion, as plaintiff does, that “a jury” should decide a factual question. It is quite another to identify evidence in the Rule 56 record that raises a genuine question of material fact, which plaintiff does not do. Summary judgment is warranted. 6 Geraci, 938 N.E.2d at 921. 7 As discussed in Argument I.D., below, we cited more plenarily to the Barden Declaration in connection with a different point—the particular unfairness of subjecting Ms. Maxwell to liability when the media selectively quoted portions of the January 15 statement. 8 In the Memorandum, we erroneously cited to ¶ 24 of Exhibit J; we intended to cite to ¶ 24 of Exhibit K (Doc.542-1, Ex.K), which is Mr. Barden’s declaration. 8 Case 18-2868, Document 279, 08/09/2019, 2628231, Page14 of 37 D. Subjecting Ms. Maxwell to liability for the media’s republication of excerpts they unilaterally selected is particularly unfair. It is undisputed that no one ever republished in toto the January 2015 statement and that various media unilaterally selected portions of the statement to republish. We said on page 14 of our Memorandum that the media’s “selective, partial republication of the statement is more problematic yet” (emphasis altered). That is to say, as improper as it is to hold a publisher of a statement liable for republications over which she had no control, worse is it to make her liable for selective, partial republications of her statement. We relied on the holding in Rand v. New York Times Co., 430 N.Y.S.2d 271, 275 (1st Dep’t 1980), that a publisher cannot be charged with a republisher’s “editing and excerpting of her statement.” Memo. of Law 14. Plaintiff argues that our position is “absurd on its face” because “[i]t would mean . . . a defamer could send to the media a long attack on a victim with one irrelevant sentence and, when the media quite predictably cut that sentence, escape liability.” Resp. 32. This argument has two erroneous assumptions. One is that the “defamer” can “escape liability.” Not true. An original publisher remains liable for her defamation. We are concerned here with republication. The second wrong assumption is that the original publisher must always remain liable for any republication. Geraci rejects that view: Under New York law “each person who repeats the defamatory statement is responsible for the resulting damages.” 938 N.E.2d at 921. The effort by plaintiff to distinguish Rand is meritless. She argues the media’s republication of the January 2015 statement actually was not a republication at all, just an original publication. Resp. 32. That argument is “absurd on its face,” id., since there is no dispute Ms. Maxwell did not control the media’s decision to republish (excerpts from) the statement. Plaintiff next argues the media did not “edit[]” or “tak[e] . . . quote[s] out of context.” Id. Plaintiff could not be more wrong. As she concedes, all republications of the statement by the 9 Case 18-2868, Document 279, 08/09/2019, 2628231, Page15 of 37 media were selective, partial republications of the statement. Any such selective, partial republication by definition took those excerpts “out of context.” This is so because Mr. Gow informed the media in his email that he was providing “a quotable statement,” Doc.542-6, Ex.F, not a statement “from which you, the media, are free to excerpt as you please.” More importantly, as Mr. Barden explained, selectively excerpting the statement substantially altered his message. See id., Ex.K ¶ 20. For example, when he said in the third paragraph that plaintiff’s claims are “obvious lies,” it followed two paragraphs in which he explained why it was obvious the new claims are lies. See id., Ex.K ¶¶ 19-22. Excerpting and republishing only the “obvious lies” phrase—as plaintiff did in her complaint—certainly gives the reader a different understanding than if the media had republished the entire statement. As Rand held: A defendant cannot be liable for the republication of derogatory but constitutionally protected opinion “when the foundation upon which that opinion is based is omitted. The defamatory remark should be read against the background of its issuance.” 430 N.Y.S.2d at 275 (internal quotations omitted). Plaintiff argues: “A jury could reasonably conclude that [Ms. Maxwell’s] statement that Ms. Giuffre’s claims of child sexual abuse are ‘obvious lies’ is not a rhetorical device, nor hyperbole, but a literal and particular affirmation that [plaintiff] lied.” Resp. 33 (emphasis supplied). We italicize plaintiff’s rhetorical sleight of hand. As plaintiff knows, nowhere did the January 2015 statement specify which of plaintiff’s countless allegations are “obvious lies.” Indeed, this is the problem with plaintiff’s case: since the statement specified no particular allegations as obvious lies, plaintiff believes she is entitled to “prove” the truth of every allegation she ever has made about her alleged experience as a “sex slave.” What Mr. Barden’s declaration makes clear is he deliberately made no reference to any specific allegation by plaintiff. He had a bigger target: plaintiff’s credibility. He used the statement to show plaintiff’s 10 Case 18-2868, Document 279, 08/09/2019, 2628231, Page16 of 37 behavior is that of a liar, i.e., one who increasingly embellishes her story, and her allegations become more and more outlandish, so that by January 2015 she was claiming to have had sex with a well respected Harvard law professor, Alan Dershowitz. See Doc.542-7, Ex.K ¶¶ 19-22. Contrary to plaintiff’s argument, “even apparent statements of fact may assume the character of statements of opinion, and thus be privileged, when made in public debate . . . or other circumstances in which an audience may anticipate the use of epithets, fiery rhetoric or hyperbole.” Steinhilber v. Alphonse, 501 N.E.2d 550, 556 (N.Y. 1986) (internal quotations and brackets omitted). That was the case here. Plaintiff falsely—and, as Judge Marra held, “unnecessar[ily]”9—alleged in lurid detail that Ms. Maxwell had sexually abused her. The six to thirty journalists would have anticipated a “fiery” denial of the allegations. Regardless, the statement overall was constitutionally protected opinion grounded on facts disclosed to the journalists: plaintiff’s increasingly outlandish and inconsistent stories, her newly embellished allegations, and her increasingly lurid and salacious enhancements of her earlier allegations. E. Mr. Barden’s declaration is perfectly proper. Plaintiff makes a plethora of complaints about Mr. Barden’s declarations. None has any merit. She objects to Mr. Barden’s declaration of his intent and purposes for preparing the January 2015 statement because, she says, this implicates the attorney-client privilege. That is untrue. His intent and purposes are by definition not attorney-client communications and do not implicate such communications; they are attorney work product,10 which he is free to disclose.11 9 Doc.542-5, Ex.E, at 5. 10 Travelers Indem. Co. v. Northrop Grumman Corp., No. 12 CIV. 3040 KBF, 2013 WL 3055437, at *3 (S.D.N.Y. Apr. 22, 2013) (identifying work product as including defense counsel’s “mental impressions, thought processes and strategies connected with [the] defense”) . 11 See In re China Med. Techs., Inc., 539 B.R. 643, 658 (S.D.N.Y. 2015) 11 Case 18-2868, Document 279, 08/09/2019, 2628231, Page17 of 37 She objects he is “non-deposed.” But Mr. Barden was the third-listed potential witness in our Rule 26(a)(1)(A) disclosure, served on plaintiff a year ago; the disclosure said he “has knowledge concerning press statements by . . . Defendant in 2011-2015 at issue in this matter.”12 Plaintiff was free to depose him; that she chose not to was her own tactical decision. Finally, plaintiff argues “there are factual disputes” regarding the declaration. But plaintiff identified no such factual disputes relating to the declaration. A party opposing summary judgment cannot create a dispute by arguing, which is all plaintiff does. See Resp. 35-38. F. Plaintiff effectively has confessed Arguments I.B. and I.C. of the Memorandum. Argument I.B. of the Memorandum contends the First Amendment bars liability for republication by media organizations of the January 2015 statement. See Memo. of Law 16-17. Argument I.C. contends that under Geraci plaintiff is barred from introducing into evidence any of the media organizations’ republication of the January 2015 statement. See id. at 17-18. Plaintiff offers no resistance to these arguments. We respectfully request that the Court consider these arguments confessed. See, e.g., Cowan v. City of Mount Vernon, 95 F. Supp. 3d 624, 64546 (S.D.N.Y. 2015) (citing cases). II. The January 2015 statement is constitutionally protected opinion. In deciding whether a statement is opinion the New York Constitution requires application of “the widely used four-part Ollman[13] formula,” Immuno AG v. Moor-Jankowski, 567 N.E.2d 1270, 1274 (N.Y. 1991). See id. at 1274, 1277-78, 1280-82 (noting Steinhilber’s adoption of formula). We addressed each of the four Ollman factors. The plaintiff avoids this analysis, choosing merely to block-quote large portions of this Court’s Rule 12(b)(6) order. That 12 Menninger Decl. EXHIBIT NN, at 2. 13 Ollman v. Evans, 750 F.2d 970 (D.C. Cir. 1984). 12 Case 18-2868, Document 279, 08/09/2019, 2628231, Page18 of 37 is a mistake. Immuno AG is the seminal case prescribing the analysis to be used in a summaryjudgment proceeding for assessing whether under the New York Constitution a statement is absolutely protected as opinion. Instead of addressing the four factors, plaintiff simply relies on this Court’s 12(b)(6) order. The Court’s order does not control. In deciding the Rule 12(b)(6) motion, the Court assumed the complaint’s allegations were true and drew all reasonable inferences in plaintiff’s favor. In this proceeding, plaintiff is not entitled either to the assumption or the inferences. The opinion-versus-fact question will be controlled by the Rule 56 record. Relying on the Court’s order, plaintiff argues that the question whether the three allegedly defamatory sentences are opinion or fact is controlled by Davis v. Boeheim, 22 N.E.3d 999 (N.Y. 2014), and Green v. Cosby, 138 F. Supp. 3d 114 (D. Mass. 2015). See Resp. 38. Davis was an appeal from a 12(b)(6) dismissal. This procedural posture was critical to its decision: [D]efendants argue that because a reader could interpret the statement as pure opinion, the statement is as a consequence, nonactionable and was properly dismissed [pursuant to a pre-answer motion]. However, on a motion to dismiss we consider whether any reading of the complaint supports the defamation claim. Thus, although it may well be that the challenged statements are subject to defendants’ interpretation, the motion to dismiss must be denied if the communication at issue, taking the words in their ordinary meaning and in context, is also susceptible to a defamatory connotation. We find this complaint to meet this minimum pleading requirement. Davis, 22 N.E.3d at 1006-07 (internal quotations, brackets, ellipsis and citations omitted). Green was a decision on the defendant’s motion to dismiss. The case was decided under California and Florida defamation law. See 138 F. Supp. 3d at 124, 130, 136-37. The court made it clear the 12(b)(6) procedural posture was critical to its decision: “At this stage of the litigation, the court’s concern is whether any fact contained in or implied by an allegedly defamatory statement is susceptible to being proved true or false; if so capable, Defendant cannot avoid application of defamation law by claiming the statement expresses only opinion.” Id. at 130. 13 Case 18-2868, Document 279, 08/09/2019, 2628231, Page19 of 37 In the case at bar, application of the four Steinhilber factors on the Rule 56 record compels a different conclusion. The complaint alleges three sentences in the January 2015 statement are defamatory: in the first paragraph of the statement, plaintiff Giuffre’s allegations are “untrue”; in the same paragraph, the “original allegations” have been “shown to be untrue”; and in the third paragraph, plaintiff’s “claims are obvious lies.”14 Doc.1 ¶ 30. Factor 1: Indefiniteness and ambiguity. On the face of the complaint in a 12(b)(6) proceeding, the words “untrue” and “obvious lies” might be susceptible of “a specific and readily understood factual meaning,” Doc.37 at 9. This is especially true if it is taken out of context, e.g., extracted from the statement. But this approach is forbidden. See, e.g., Law Firm of Daniel P. Foster, P.C. v. Turner Broad. Sys., 844 F.2d 955, 959 (2d Cir. 1988). The first sentence—“[t]he allegations made by [plaintiff] against [Ms. Maxwell] are untrue”—is indefinite and ambiguous because it is wholly unclear which “allegations” are being referenced. The second sentence—“[t]he original allegations . . . have been fully responded to and shown to be untrue”—also is indefinite and ambiguous for the same reason. Additionally, it is unclear what are the “original” allegations. It is unclear what is meant by “shown to be untrue.” What one person may believe is a fact shown to be untrue, another person may believe is a fact not (sufficiently) shown to be untrue. The existence of God, climate change and existence of widespread voter fraud in the election are examples of this. The third sentence— 14 Ms. Maxwell testified in her deposition that she “know[s]” plaintiff is a “liar.” This testimony, plaintiff argues, “contradict[s]” our contention that the three allegedly defamatory sentences in the July 2015 statement are opinion. Resp. 39-40. Plaintiff’s argument is a nonsequitur. Ms. Maxwell’s 2016 deposition testimony in which she disclosed all the reasons she believes plaintiff has uttered a plethora of false allegations is irrelevant to whether the three sentences in the July 2015 statement, prepared by Mr. Barden to respond to the joint-motion allegations, are opinions. 14 Case 18-2868, Document 279, 08/09/2019, 2628231, Page20 of 37 “[plaintiff’s] claims are obvious lies”—also is indefinite and ambiguous. An “obvious lie” to one person is not an “obvious lie” to another. Factor 2: Capable of being characterized as true or false. On the 12(b)(6) record, the Court held the three statements “are capable of being proven true or false.” Doc.37 at 9. As a general question of law, one person’s statement that another person’s allegations are “untrue” or are “obvious lies” is not necessarily capable of being proved true or false—regardless of the subject matter of the opined “untruths” or “lies.” See Rizzuto v. Nexxus Prod. Co., 641 F. Supp. 473, 481 (S.D.N.Y. 1986), aff’d, 810 F.2d 1161 (2d Cir. 1986); Telephone Sys. Int’l v. Cecil, No. 02 CV 9315(GBD), 2003 WL 22232908, at *2 (S.D.N.Y. Sept. 29, 2003); Memo. of Law 35 (citing cases). As Steinhilber observed, “even apparent statements of fact may assume the character of statements of opinion, and thus be privileged.” 501 N.E.2d at 556. At least two of plaintiff’s CVRA allegations cannot be proven true or false (only two such allegations are needed in order to render the January 15 statement an opinion). We have identified two such allegations in the joinder motion: that Ms. Maxwell “appreciated the immunity granted” to Epstein, and that she “act[ed] as a ‘madame’ for Epstein.” Memo. of Law 22. Plaintiff does not dispute this. The result is that the January 15 statement’s assertion that plaintiff’s “allegations” and “claims” in the joint motion are “untrue” or “obvious lies” is by definition an opinion. It cannot be proven true or false whether Ms. Maxwell “appreciated” Epstein’s immunity or whether she “acted as a madame.” Indeed, it seems quite obvious that the joinder-motion allegations about “appreciation” and “madame” are themselves opinion. In the statement, Mr. Barden on behalf of Ms. Maxwell also says plaintiff’s “original allegations . . . have been fully responded to and shown to be untrue.” Doc.542-6, Ex.F. This cannot be proven true or false. The “full response” to the original allegations is a reference to the “Statement on Behalf of Ghislaine Maxwell” issued March 9, 2011, in response to plaintiff’s 15 Case 18-2868, Document 279, 08/09/2019, 2628231, Page21 of 37 allegations contained in media stories, including the Churcher articles. See Doc.542-3, Ex.C. Whether the 2011 statement “fully” responded to the original allegations and whether it “showed” the original allegations to be untrue are pure (argumentative) opinion. “[O]bvious lies” on its face is an opinion. The “obviousness” of a lie simply cannot be proven true or false. Factor 3: The full context of the statement. Three contextual facts are revealed by the Rule 56 record. One, the email transmitting the statement to the media-representatives—along with the third-person references to Ms. Maxwell—told them Ms. Maxwell did not prepare the statement: “Please find attached a quotable statement on behalf of Ms. Maxwell.” Doc.542-6, Ex.F (emphasis supplied). It is undisputed that in fact Mr. Barden prepared the bulk of it and ultimately approved and adopted as his work all of it. Doc.542-7, Ex.K ¶ 10. Two, Mr. Barden’s statement issued on behalf of his client would not be a traditional press release solely to disseminate information to the media; this is why he did not request Mr. Gow or any other public relations specialist to prepare or participate in preparing the statement. Id., Ex.K ¶ 15. The statement was a broad-brush communique to the media about plaintiff and her new allegations; it was not to be a “point by point” rebuttal of each new allegation. Id., Ex.K ¶ 13. The logic and approach to preparing the statement were simple: compare plaintiff’s prior allegations and conduct in telling her story with her current allegations and conduct. See generally id., Ex.K ¶ 13. When he wrote the statement, he knew of plaintiff’s 2011 allegation that she had not had sex with Prince Andrew and he knew of her CVRA allegation that she did have sex with him. Id., Ex.K ¶ 14. Also within his knowledge was the story she had told Churcher before March 2011—a story that was far less provocative and salacious than the one she included in the joinder motion. See id., Ex.K ¶ 5; compare Docs.542-1 & 542-2, Exs.A & B (Churcher articles published March 2011) with Doc.542-4, Ex.D (plaintiff’s joinder motion containing dramatically different and more lurid and salacious allegations). 16 Case 18-2868, Document 279, 08/09/2019, 2628231, Page22 of 37 Mr. Barden’s approach provides critical context to explaining how the statement builds a logical argument that the new allegations are false. It first notes plaintiff’s “original allegations”; then it points out how the story changed and was embellished over time, “now” with allegations that plaintiff had sex with a prominent and highly respected Harvard law professor (“Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders . . . .”). The argument builds up to the opinion in the third paragraph: “[Plaintiff’s] claims are obvious lies and should be treated as such . . . .” Doc.542-6, Ex.F. See generally id., Ex.K ¶¶ 13-22. This third paragraph—and the threat in the fourth paragraph to sue the media for republication of plaintiff’s falsehoods—confirms what is plain from the statement itself: it was not a traditional press release. Three, the statement was intended to respond (via denial) to the media-recipients’ requests for a reply to the new CVRA joinder-motion allegations. Id. ¶¶ 8, 10, 16. But more than that, it was intended to be “a shot across the bow” of the media. Id. ¶ 17. The logical argument was created to (a) persuade the media-recipients that they needed to “subject plaintiff’s allegations to inquiry and scrutiny”; (b) explain to the media-recipients how it was “obvious” that plaintiff “had no credibility” because of her shifting story and increasingly lurid and salacious allegations as time went on, many of which (e.g., the allegations of sex with Prince Andrew and Professor Dershowitz) on their face appear far-fetched,15 and (c) warn the media- 15 Since the CVRA joinder motion, there has emerged a substantial amount of evidence— some from plaintiff’s own pen—that plaintiff’s allegations about having been “forced” to have sex with prominent individuals are falsehoods. A telling example is a series of emails between plaintiff and reporter Churcher when plaintiff was working on negotiating a book deal about her alleged experiences and Churcher was trying to help her. On May 10, 2011, plaintiff tells Churcher she cannot remember whom she had told Churcher she had had sex with. Churcher responds responds, “Don’t forget Alan Dershowitz,” which Churcher says is a “good name for [plaintiff’s] pitch” to her literary agent. It is clear neither Churcher nor plaintiff believed plaintiff (footnote cont’d on next page) 17 Case 18-2868, Document 279, 08/09/2019, 2628231, Page23 of 37 recipients that they republished plaintiff’s obvious falsehoods against Ms. Maxwell at their legal peril. See id. ¶¶ 13, 16, 17, 20. As the New York Court of Appeals observed, the context of a statement often is the “key consideration” in fact vs. opinion cases. Davis, 22 N.E.3d at 1006. So it is here. As Davis suggested, the three challenged statements are “subject to [Ms. Maxwell’s] interpretation,” id. at 1007; accord Sweeney v. Prisoners’ Legal Servs. of N.Y., 538 N.Y.S.2d 370, 371-72 (3d Dep’t 1989). The context of the January 2015 statement makes clear that the characterization of plaintiff’s allegations and claims as “untrue” or “obvious lies” are ultimate opinions— conclusions—drawn from disclosed facts. Factor 4: The broader setting surrounding the statement, including conventions that might signal to readers that the statement likely is opinion and not fact. It is undisputed that the January 2015 statement was sent exclusively to more than six and fewer than thirty media representatives, each of whom expressly had requested from Mr. Gow that he provide them with Ms. Maxwell’s reply to the new joint-motion allegations. Doc.542-7, Ex.K ¶¶ 8, 10. As was obvious from the statement, it was not a traditional press release, as such a release does not explain—lawyer-like—why new allegations when measured against previous allegations lack credibility. Nor does a traditional release threaten to sue the media to whom the release is sent. The media representatives upon receiving the January 2015 statement would have understood it was presenting an (opinionated) argument that plaintiff was not credible because of her had had sex with Professor Dershowitz, since (a) Churcher suggests that he would be a “good name” to “pitch” because of his prominence (“he [represented] Claus von Bulow and a movie was made about that case…title was Reversal of Fortune”), and (b) Churcher states, “We all suspect [Professor Dershowitz] is a pedo[phile] and tho no proof of that, you probably met him when he was hanging put w [Epstein].” Menninger Decl., EXHIBIT.OO, at Giuffre004096-97 (emphasis supplied). 18 Case 18-2868, Document 279, 08/09/2019, 2628231, Page24 of 37 inconsistent and shifting sex abuse story and her increasingly lurid allegations against more and more prominent individuals. And they would have understood that these characteristics of a storyteller undermine her credibility and ergo the credibility of her new allegations. In its 12(b)(6) order the Court said the three sentences have the effect of denying plaintiff’s story but “they also clearly constitute fact to the reader.” The ruling is affected in two ways by the Rule 56 record. Based on the foregoing discussion of the evidence, the three sentences clearly constitute (argumentative) opinions of Mr. Barden on behalf of Ms. Maxwell. Though the Court did not discuss who is “the reader,” this is important in Steinhilber Factor 4.” Under settled defamation-opinion law, an allegedly defamatory statement is to be viewed “from the perspective of the audience to whom it is addressed.” Dibella v. Hopkins, No. 01 CIV. 11779 (DC), 2002 WL 31427362, at *2 (S.D.N.Y. Oct. 30, 2002). Here, “the reader” is six to thirty journalists. They could not have read the July 2015 statement—or the three allegedly defamatory sentences—the same way it was read by these journalists’ audience, i.e., the general public. This is because, as plaintiff implicitly concedes, these journalists only republished excerpts—and not the entirety of the statement, which would have given context to the three sentences. It is axiomatic that an out-of-context republication of the three sentences—without the rest of the statement—would deprive the reader of the logic and reasoning behind the opinionated conclusion that plaintiff was making “untrue” allegations and telling “obvious lies.” 19 Case 18-2868, Document 279, 08/09/2019, 2628231, Page25 of 37 III. The pre-litigation privilege bars this action. A. The privilege applies to the January 2015 statement. Statements pertinent to a good faith anticipated litigation made by attorneys (or their agents under their direction16) before the commencement of litigation are privileged and “no cause of action for defamation can be based on those statements,” Front, Inc. v. Khalil, 28 N.E.3d 15, 16 (N.Y. 2015). The facts that must be established, therefore, are (a) a statement, (b) that is pertinent to a good faith anticipated litigation, and (c) by attorneys or their agents under their direction. We did this. See Memo. of Law 6-8, 33-38; Doc.542-7, Ex.K ¶¶ 8-30. For example, Mr. Barden (a) drafted the vast majority of the January 2015 statement and approved and adopted all of it, (b) directed Mr. Gow to send it to the media representatives who had requested Ms. Maxwell’s reply to plaintiff’s joint-motion allegations, (c) in the statement threatened legal action again these media representatives, and (d) at the time of the statement “was contemplating litigation against the press-recipients.” Id., Ex.K ¶¶ 10, 16-17, 28, 30. Plaintiff argues without citation to authority: Ms. Maxwell herself did not testify she intended to sue; she hasn’t offered any witnesses to testify she intended to bring a lawsuit; she didn’t in fact sue; and—this one is a non-sequitur—the statement was an “attempt[] to continue to conceal her criminal acts.” Resp. 41-42. These arguments fail. The privilege exists without regard to whether Ms. Maxwell testifies she “intended” to sue, whether she has “witnesses” to say she intended to sue, or whether she “in fact” sued. It refers to “anticipated” litigation, not “guaranteed” litigation. Indeed, the point of the pre-litigation privilege is to promote communications that avoid litigation. See Khalil, 28 N.E.3d at 19 (“When litigation is 16 See Chambers v. Wells Fargo Bank, N.A., No. CV 15-6976 (JBS/JS), 2016 WL 3533998, at *8 (D.N.J. June 28, 2016); see generally Hawkins v. Harris, 661 A.2d 284, 289-91 (N.J. 1995). 20 Case 18-2868, Document 279, 08/09/2019, 2628231, Page26 of 37 anticipated, attorneys and parties should be free to communicate in order to reduce or avoid the need to actually commence litigation.”). It applies when there is a good faith basis to anticipate litigation. Mr. Barden, Ms. Maxwell’s lawyer who drafted and caused the statement to be sent out, actually was anticipating litigation. Doc.542-7, Ex.K ¶ 28. The argument that the statement was an attempt to “conceal” Ms. Maxwell’s “criminal acts” is fatuous. It would be hard to post facto “conceal” alleged criminal acts that plaintiff luridly and salaciously described in an earlier public filing, i.e., in the CVRA case, in which the United States government was the defendant. Citing no record evidence, plaintiff argues, “The record evidence shows [Mr. Barden] did not make the [January 2015] statement.” Resp. 42. That argument is easily disposed of by Mr. Barden’s uncontested testimony. See Doc.542-7, Ex.K ¶¶ 10-13, 15-17, 20, 26-28, 30. B. Malice is irrelevant to the pre-litigation privilege. Citing the New York Court of Appeals’ decision in Khalil, we pointed out that malice is not relevant to the pre-litigation privilege. Memo. of Law 34-35. To prevail on the pre-litigation privilege the defendant need only establish one element: the allegedly defamatory statement at issue was “‘pertinent to a good faith anticipated litigation.’” Id. (quoting Khalil, 28 N.E.3d at 16). Plaintiff disputes this and, without discussing Khalil or citing authorities, simply argues the pre-litigation privilege is “foreclosed . . . because [Ms. Maxwell] acted with malice.” Resp. 43. As suggested by her inability to find any law to support her, plaintiff is wrong. Under general New York defamation law, “[t]he shield provided by a qualified privilege may be dissolved” if plaintiff in rebuttal can show that the defendant “spoke with ‘malice.’” Liberman v. Gelstein, 605 N.E.2d 344, 349 (N.Y. 1992); accord Khalil, 28 N.E.3d at 19. “Malice” means two things: spite or ill will, and knowledge of falsity or reckless disregard of falsity. Liberman, 605 N.E.2d at 349. Plaintiff relies on this general qualified-privilege law. 21 Case 18-2868, Document 279, 08/09/2019, 2628231, Page27 of 37 The problem for plaintiff is that in Khalil the New York Court of Appeals held this general rule does not apply to the pre-litigation privilege. Khalil worked for a company named Front. After eight years, he resigned and began working for “EOC,” one of Front’s competitors. Front’s lawyer Kimmel sent a demand letter to Khalil alleging he had committed criminal, tortious and ethical misconduct. Kimmel sent another demand letter to EOC and others stating Khalil had conspired with EOC to breach his fiduciary duty to Front. Six months later, Front sued Khalil. Khalil brought a third-party claim against Kimmel for libel per se. The trial court dismissed the lawsuit, ruling that the letters were “absolutely privileged” under the litigation privilege “and that it therefore did not need to reach the question of malice.” 28 N.E.3d at 17 (internal quotations omitted). The Appellate Division affirmed, holding that the litigation privilege absolutely protected the letter “because they were issued in the context of prospective litigation.” Id. at 18 (internal quotations omitted). The Court of Appeals affirmed, but altered the law on the litigation privilege. It observed, “Although it is well-settled that statements made in the course of litigation are entitled to absolute privilege, this Court has not directly addressed whether statements made by an attorney on behalf of his or her client in connection with prospective litigation are privileged.” Id. (emphasis supplied). Some Appellate Division departments had held the absolute privilege applies to statements made in connection with prospective litigation, but other departments had held such statements were entitled only to a qualified privilege. Id. The answer to whether pre-litigation statements should be absolute or qualified, the Court of Appeals held, is driven by the rationale for protecting pre-litigation statements: When litigation is anticipated, attorneys and parties should be free to communicate in order to reduce or avoid the need to actually commence litigation. Attorneys often send cease and desist letters to avoid litigation. . . . Communication during this pre-litigation phase should be encouraged and not chilled by the possibility of being the basis for a defamation suit. 22 Case 18-2868, Document 279, 08/09/2019, 2628231, Page28 of 37 Id. at 19. However, the court recognized that “extending privileged status to communication made prior to anticipated litigation has the potential to be abused”; extending an absolute privilege to this context, the court said, “would be problematic and unnecessary.” Id. The court held it would recognize only a qualified privilege for pre-litigation communications. Id. Crucially to the case at bar, the court held that the traditional privilegerebuttal malice was inapplicable to the pre-litigation privilege: Rather than applying the general malice standard to this pre-litigation stage, the privilege should only be applied to statements pertinent to a good faith anticipated litigation. This requirement ensures that privilege does not protect attorneys who are seeking to bully, harass, or intimidate their client’s adversaries by threatening baseless litigation or by asserting wholly unmeritorious claims, unsupported in law and fact, in violation of counsel’s ethical obligations. Therefore, we hold that statements made prior to the commencement of an anticipated litigation are privileged, and that the privilege is lost where a defendant proves that the statements were not pertinent to a good faith anticipated litigation. Id. (emphasis supplied). Accordingly, the only question is whether the January 2015 statement Mr. Barden caused to be issued to the six to thirty journalists was “pertinent to a good faith anticipated litigation.” The undisputed evidence establishes that the answer is yes. Mr. Barden anticipated litigation.17 He “fully complied with [his] ethical obligation as a lawyer.”18 He was hardly “bully[ing], harass[ing], or intimidat[ing]” the six to thirty journalists, since he caused a press agent, Mr. 17 See Doc.542-7, Ex.K ¶ 28 (“At the time I directed the issuance of the statement, I was contemplating litigation against the press-recipients . . . .”); id. ¶ 17 (statement was intended as “‘a shot across the bow’”; “the statement was very much intended as a cease and desist letter to the media-recipients, letting [them] understand the seriousness with which Ms. Maxwell considered the publication of plaintiff’s obviously false allegations and the legal indefensibility of their own conduct”); Doc.542-6, Ex.F (“Maxwell . . . reserves her right to seek redress”). 18 Doc.542-7, Ex.K ¶ 26. 23 Case 18-2868, Document 279, 08/09/2019, 2628231, Page29 of 37 Gow, to issue the statement,19 and he believed he had an affirmative duty in representing Ms. Maxwell to prepare the statement and cause it to be delivered to the journalists.20 Plaintiff argues that when Mr. Barden issued the January 2015 statement on Ms. Maxwell’s behalf, he had only “‘wholly unmeritorious claims, unsupported in law and fact, in violation of counsel’s ethical obligations’” and did not have “‘good faith anticipated litigation.’” Resp. 46 (quoting Khalil, 28 N.E.3d at 19; italics omitted). Plaintiff’s rationale? Because she was telling the truth and so the media would only be reporting the truth. Id. That is a nonsensical, frivolous argument. Whether Mr. Barden, who represents Ms. Maxwell, had a meritorious or good faith basis for anticipating defamation litigation has nothing to do with whether the media believed plaintiff was telling the truth, and surely not whether the plaintiff believed or said she was telling the truth. Based on his knowledge of plaintiff’s history, Mr. Barden in good faith believed that plaintiff had been making false allegations for years and that the falsity of the allegations “should have been obvious to the media.” Doc.542-7, Ex.K ¶ 13; see id. ¶¶ 14, 16-17, 20-23, 26-28, 30. Accordingly, at the time he caused the statement to issue, Mr. Barden had a good-faith basis to anticipate litigation against any of the media that republished plaintiff’s false allegations. It hardly matters for purposes of the pre-litigation privilege whether the media republished or did not republish plaintiff’s allegations or whether Mr. Barden ultimately did or did not sue any of the media for any republication. As the Khalil court recognized, “[a]ttorneys often send cease and desist letters to avoid litigation,” 28 N.E.3d at 19, and such letters have a 19 The Khalil court admonished attorneys to “exercise caution when corresponding with unrepresented potential parties who may be particularly susceptible to harassment and unequipped to respond properly even to appropriate communications from an attorney.” Khalil, 28 N.E.3d at 19 n.2. 20 See Doc.542-7, Ex.K ¶ 26. 24 Case 18-2868, Document 279, 08/09/2019, 2628231, Page30 of 37 valid purpose protected by the pre-litigation privilege. Mr. Barden testified that the January 2015 statement in fact served as a cease and desist letter. See Doc.542-7, Ex.K ¶ 17. IV. Ms. Maxwell’s January 4, 2015, statement is nonactionable. Plaintiff did not respond to our argument that Ms. Maxwell’s January 4, 2015, statement to a reporter is nonactionable. See Memo. of Law 38-39. We respectfully submit plaintiff has confessed this point. See Cowan, 95 F. Supp. 3d at 645-46. V. Summary judgment is warranted because plaintiff cannot establish falsity or actual malice by clear and convincing evidence. Plaintiff is a public figure. See Memo. of Law 16-17, 49-54. Therefore, she must prove falsity and actual malice. Under New York law, a public-figure defamation plaintiff must go beyond the federal constitutional minimum and prove falsity by clear and convincing evidence. Blair v. Inside Ed. Prods., 7 F. Supp. 3d 348, 358 & n.6 (S.D.N.Y. 2014) (citing DiBella v. Hopkins, 403 F.3d 102, 111 (2d Cir.2005)). She must also prove actual malice by clear and convincing evidence. Karedes v. Ackerley Grp., Inc., 423 F.3d 107, 114 (2d Cir. 2005) (quoting Phila. Newspapers v. Hepps, 475 U.S. 767, 773 (1986)). Clear and convincing evidence is evidence that “produces in the mind of the trier of fact a firm belief or conviction as to the truth of the allegations sought to be established, evidence so clear, direct and weighty and convincing as to enable the factfinder to come to a clear conviction, without hesitancy, of the truth of the precise facts in issue.” Blair, 7 F. Supp. 3d. at 358 (internal quotations and brackets omitted). Plaintiff must prove by clear and convincing evidence (a) the material falsity of three sentences in the context of the January 2015 statement, and (b) Ms. Maxwell’s actual malice, i.e., knowledge of the falsity of the three sentences or reckless disregard of whether they were false. The three sentences are: in the first paragraph of the statement, plaintiff’s allegations are 25 Case 18-2868, Document 279, 08/09/2019, 2628231, Page31 of 37 “untrue”; in the same paragraph, the “original allegations” have been “shown to be untrue”; and in the third paragraph, plaintiff’s “claims are obvious lies.”21 Doc.1 ¶ 30. Plaintiff cannot prove the falsity of the three sentences, let alone actual malice. If the Rule 56 record establishes that two of plaintiff’s CVRA joinder-motion allegations are false and two of her “original” allegations are false, this defamation action collapses on itself. This is because the statement does not specify how many of plaintiff’s allegations are false; it certainly does not say “all” plaintiff’s allegations are false. It uses the plural of “allegation.” The plural of allegation literally means “more than one.” See Memo. of Law 21. Sentence No. 1. Since the sentence does not specify any particular allegation and since plaintiff made a plethora of allegations against Ms. Maxwell, plaintiff would be required to prove the truth of every one of the plethora of allegations and that Ms. Maxwell knew each one of the allegations was true. Conversely, if there are at least two allegations that plaintiff cannot prove to be true or if there was good reason for Ms. Maxwell to believe at least two of the allegations to be false, then summary judgment should enter against plaintiff. There are at least two allegations by plaintiff against Ms. Maxwell that are untrue. In the CVRA joinder motion, plaintiff alleged that in plaintiff’s first encounter with Mr. Epstein, Ms. Maxwell took her to Mr. Epstein’s bedroom for a massage that Mr. Epstein and Ms. Maxwell “turned . . . into a sexual encounter,” Doc.542-4, Ex.D, at 3. This allegation contradicted her allegation in the Sharon Churcher article that a woman other than Ms. Maxwell 21 Ms. Maxwell said in her deposition she “know[s]” plaintiff is a “liar.” This testimony, plaintiff argues, “contradict[s]” our contention that the three sentences in the January 2015 statement are opinion. Resp. 39-40. Plaintiff’s argument is a non-sequitur. Ms. Maxwell’s 2016 deposition testimony in which she disclosed all the reasons she believes plaintiff has uttered a plethora of false allegations is wholly irrelevant to whether the three sentences in the January 2015 statement, prepared by Mr. Barden to respond to the joint-motion allegations, are opinions. 26 Case 18-2868, Document 279, 08/09/2019, 2628231, Page32 of 37 took her to Mr. Epstein’s bedroom; during the massage that woman gave instructions to plaintiff, and the massage “quickly developed into a sexual encounter.” Doc.542-1, Ex.A, at 4. A second allegation pertaining to plaintiff’s entire story about Ms. Maxwell’s introduction of plaintiff to Prince Andrew is untrue. In the joinder motion, plaintiff alleged Ms. Maxwell served an “important . . . role” in “Epstein’s sexual abuse ring,” namely, connecting Mr. Epstein to “powerful individuals” who would sexually abuse plaintiff. Id., Ex.D, at 5. Plaintiff alleged that in this role Ms. Maxwell introduced plaintiff to Prince Andrew, and she was “forced to have sexual relations with this Prince in three separate geographical locations,” including Ms. Maxwell’s London apartment. Id., Ex.D, at 5. These allegations directly contradicted her earlier allegations in the 2011 Churcher article that (a) there never was “any sexual contact between [plaintiff] and [Prince] Andrew,” and (b) Prince Andrew did not know “Epstein paid her to have sex with [Epstein’s] friends.” Id., Ex.A, at 6. Mr. Barden on behalf of Ms. Maxwell said in the first sentence that plaintiff’s “allegations”—plural—against Ms. Maxwell are “untrue.” We have just established through plaintiff’s own contradictory words that it would be fair to characterize at least two of her allegations to be untrue. Having spent significant time with Ms. Churcher in 2011 and having substantial incentive to disclose all important details of her “sex abuse” story, see Menninger Decl. EXHIBIT OO, plaintiff in 2011 presented a story that exculpated Ms. Maxwell and Prince Andrew of the very misconduct that in 2015—after securing a lawyer and seeing her story as a profit vehicle—she inculpated them for. In the face of her contradictory allegations, plaintiff cannot possibly prove by clear and convincing evidence that all her joinder-motion allegations are true, or that when Ms. Maxwell said they were untrue, she knew each one of the allegations was true or that she recklessly disregarded whether each one was true. 27 Case 18-2868, Document 279, 08/09/2019, 2628231, Page33 of 37 Under New York law, a defendant’s allegedly defamatory statement is held “to a standard of substantial, not literal, accuracy.” Law Firm of Daniel P. Foster, 844 F.2d at 959. Here, Ms. Maxwell’s first sentence literally is true: more than one of plaintiff’s allegations are “untrue.” Accordingly, there is no defamation. Sentence No. 2. The second sentence at issue in this action states, “The original allegations are not new and have been fully responded to and shown to be untrue.” Plaintiff alleges the sentence is defamatory to the extent it asserts the original allegations were “shown to be untrue.” Doc.1 ¶ 30. Plaintiff cannot prove this statement’s falsity. It is a matter of pure opinion whether any given allegation was “shown” to be untrue. Some people require more proof than others to conclude that a fact has been “shown to be untrue.” We discussed above various examples of this, e.g., climate change. Here, Ms. Maxwell via Mr. Barden in March 2011 issued a statement denying plaintiff’s Churcher-story allegations as “all entirely false.” Doc.542-3, Ex.C. Plaintiff did not respond to this statement, let alone claim it was defamatory. Her non-response reasonably could be seen as a concession that Ms. Maxwell’s denial was righteous. See Doc.542-7, Ex.K (Mr. Barden: “I would have been remiss if I had sat back and not issued a denial, and the press had published that Ms. Maxwell had not responded to enquiries and had not denied the new allegations; the public might have taken the silence as an admission there was some truth in the in allegations.”). Regardless, we easily can show two of plaintiff’s original allegations are untrue. Many of plaintiff’s original allegations are contained in the two Churcher articles, Docs.542-1 & 542-2, Exs.A & B. The articles contained numerous allegations by plaintiff relating to her alleged sexual abuse. In her deposition, plaintiff was shown Deposition Exhibit 7, a collection of some of her allegations in the articles. Plaintiff placed checkmarks by those allegations she admitted— over the course of 20 pages of testimony—were not true. See Menninger Decl. EXHIBIT PP, at 28 Case 18-2868, Document 279, 08/09/2019, 2628231, Page34 of 37 435:7-455:6 & Depo. Ex.7. These include her claims that: (1) she was 17 when she flew to the Caribbean with Mr. Epstein and Ms. Maxwell “went to pick up Bill in a huge black helicopter,” referring to former President Bill Clinton; (2) her conversation with Mr. Clinton about Ms. Maxwell’s pilot skills; and (3) Donald Trump was a “good friend” of Mr. Epstein’s and “flirted with me”. Plaintiff’s admissions on the falsity of her original allegations are fatal to her defamation claim as to the second sentence. The eleven admittedly false “original allegations” axiomatically would warrant the second sentence. Plaintiff has no possible way to prove the second sentence is false. Indeed, like Ms. Maxwell’s first sentence, the second sentence literally is true: more than one of plaintiff’s original allegations are untrue. A statement that literally is true cannot be defamatory as a matter of law. See Law Firm of Daniel P. Foster, 844 F.2d at 959. Sentence No. 3. Defamation as to the third sentence is foreclosed. To begin with, as discussed above, whether plaintiff has uttered “obvious lies” is a matter of opinion: in the face of plaintiff’s gratuitous and lurid allegations of Ms. Maxwell’s years-long participation at the center of a child sex-trafficking ring, for the journalists-recipients of the July 2015 statement the phrase was an anticipated “epithet[], fiery rhetoric or hyperbole,” Steinhilber, 501 N.E.2d at 556 (internal quotations omitted); see Tel. Sys. Int’l, 2003 WL 22232908, at *2 (observing Court’s previous holding in Rizzuto that defendants’ use of phrases “conned,” “rip off” and “lying” in advertisements were not actionable as libel and were “rhetorical hyperbole, a vigorous epithet used by those who considered themselves unfairly treated and sought to bring what they alleged were the true facts to the readers”) (internal quotations omitted). Even if arguendo the third sentence—plaintiff’s “claims are obvious lies”—cannot be considered opinion, the Rule 56 record forecloses a defamation claim. The sentence does not specify which of plaintiff’s “claims,” i.e., allegations, are obvious lies. It could refer to the 29 Case 18-2868, Document 279, 08/09/2019, 2628231, Page35 of 37 “original” claims; the “new,” CVRA claims; the claims against Ms. Maxwell; the claims against anyone, including Professor Dershowitz, who was mentioned in the preceding sentence; or any two or more of all the claims plaintiff ever had made about her alleged experiences as the alleged victim of a child sex-trafficking ring. Regardless of what is being referred to, there is no defamation. As demonstrated in the discussion above of the first and second sentences, the Rule 56 record establishes that at least two of plaintiff’s “original” allegations are untrue, at least two of her CVRA allegations are untrue, at least two of her allegations against Ms. Maxwell are untrue, at least two of her allegations against anyone (e.g., Ms. Maxwell, Prince Andrew or Professor Dershowitz) are untrue, and at least two of her allegations about her alleged sex-trafficking experiences are untrue. Moreover, the untruthfulness—the falsity—of the allegations certainly is “obvious.” After all, plaintiff herself admitted under oath that a multitude of her original allegations are untrue, and she implicitly admitted some of her CVRA allegations are untrue because they were contradicted by her original allegations. CONCLUSION The Court should grant summary judgment in favor of Ms. Maxwell. February 10, 2017. 30 Case 18-2868, Document 279, 08/09/2019, 2628231, Page36 of 37 Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice pending) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 lmenninger@hmflaw.com Attorneys for Defendant Ghislaine Maxwell 31 Case 18-2868, Document 279, 08/09/2019, 2628231, Page37 of 37 CERTIFICATE OF SERVICE I certify that on February 10, 2017, I electronically served this Reply Brief in Support of Defendant’s Motion for Summary Judgment via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@aol.com s/ Nicole Simmons Nicole Simmons 32 Case 18-2868, Document 280, 08/09/2019, 2628232, Page1 of 74 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT Sigrid McCawley BOIES, SCHILLER & FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 Case 18-2868, Document 280, 08/09/2019, 2628232, Page2 of 74 TABLE OF CONTENTS Page I. PRELIMINARY STATEMENT .........................................................................................1 II. UNDISPUTED FACTS.......................................................................................................4 A. It is an Undisputed Fact That Multiple Witnesses Deposed in This Case Have Testified That Defendant Operated as Convicted Pedophile Jeffrey Epstein’s Procurer of Underage Girls......................................................................................4 1. It is an undisputed fact that Joanna Sjoberg testified Defendant lured her from her school to have sex with Epstein under the guise of hiring her for a job answering phones....................................................................4 2. It is an undisputed fact that Tony Figueroa testified that Defendant would call him to bring over underage girls and that Defendant and Epstein would have threesomes with Ms. Giuffre.......................................6 3. It is an undisputed fact that Rinaldo Rizzo testified that Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein. ................................................8 4. It is an undisputed fact that Lyn Miller testified that she believed Defendant became Ms. Giuffre’s “new mama”...........................................9 5. It is an undisputed Fact that Detective Joseph Recarey testified that he sought to investigate Defendant in relation to his investigation of Jeffrey Epstein. ............................................................................................9 6. It is an undisputed fact that Pilot David Rodgers testified that he flew Defendant and Ms. Giuffre at least 23 times on Epstein’s jet, the “Lolita Express” and that “GM” on the flight logs Stands for Ghislaine Maxwell. ....................................................................................................10 7. It is an undisputed fact that Sarah Kellen, Nadia Marcinkova, and Jeffrey Epstein invoked the fifth amendment when asked about Defendant trafficking girls for Jeffery Epstein..........................................10 8. It is an undisputed fact that Juan Alessi testified that Defendant was one of the people who procured some of the over 100 girls he witnessed visit Epstein, and that he had to clean Defendant’s sex toys. ...11 9. It is an undisputed fact that Defendant is unable to garner a single witness throughout discovery who can testify that she did not act as the procurer of underage girls and young women for Jeffrey Epstein. ...........12 i Case 18-2868, Document 280, 08/09/2019, 2628232, Page3 of 74 B. C. Documentary Evidence also Shows that Defendant Trafficked Ms. Giuffre and Procured her for Sex with Convicted Pedophile Jeffrey Epstein while She Was Underage................................................................................................................12 1. The Flight Logs .........................................................................................12 2. The Photographs ........................................................................................13 3. The Victim Identification Letter................................................................15 4. New York Presbyterian Hospital Records.................................................15 5. Judith Lightfoot Psychological Records....................................................16 6. Message Pads.............................................................................................17 7. The Black Book .........................................................................................22 8. Sex Slave Amazon.com Book Receipt ......................................................23 9. Thailand Folder with Defendant’s Phone Number....................................24 10. It is undisputed fact that the FBI report and the Churcher emails reference Ms. Giuffre’s accounts of sexual activity with Prince Andrew that she made in 2011, contrary to Defendant’s argument that Ms. Giuffre never made such claims until 2014........................................25 Defendant Has Produced No Documents Whatsoever That Tend to Show That She Did Not Procure Underage Girls For Jeffrey Epstein.....................................26 III. LEGAL STANDARD .......................................................................................................27 IV. LEGAL ARGUMENT ......................................................................................................27 A. B. Defendant is Liable for the Publication of the Defamatory Statement and Damages for Its Publication ..................................................................................27 1. Under New York Law, Defendant is liable for the media’s publication of her press release. ...................................................................................28 2. Defendant is liable for the media’s publication of the defamatory statement....................................................................................................32 Material Issues of Fact Preclude Summary Judgment...........................................34 1. The Barden Declaration presents disputed issues of fact. .........................34 ii Case 18-2868, Document 280, 08/09/2019, 2628232, Page4 of 74 a. The Barden Declaration is a deceptive back-door attempt to inject Barden’s advice without providing discovery of all attorney communications...............................................................34 b. Defendant’s summary judgment argument requires factual findings regarding Barden’s intent, thereby precluding summary judgment. .......................................................................35 c. There are factual disputes regarding Barden’s Declaration...........36 C. Defendant’s Defamatory Statement Was Not Opinion as a Matter of Law. .........38 D. The Pre-Litigation Privilege Does Not Apply to Defendant’s Press Release .......40 1. Defendant fails to make a showing that the pre-litigation privilege applies........................................................................................................40 2. Defendant is foreclosed from using the pre-litigation privilege because she acted with malice.................................................................................43 3. Defendant cannot invoke the pre-litigation privilege because she has no “meritorious claim” for “good faith” litigation. ...................................46 V. DEFENDANT HAS NOT - AND CANNOT - SHOW THAT HER DEFAMATORY STATEMENT IS SUBSTANTIALLY TRUE..................................................................47 VI. PLAINTIFF DOES NOT NEED TO ESTABLISH MALICE FOR HER DEFAMATION CLAIM, BUT IN THE EVENT THE COURT RULES OTHERWISE, THERE IS MORE THAN SUFFICIENT RECORD EVIDENCE FOR A REASONABLE JURY TO DETERMINE DEFENDANT ACTED WITH ACTUAL MALICE...........................................................................................................49 VII. THE COURT NEED NOT REACH THE ISSUE, AT THIS TIME, OF WHETHER MS. GIUFFRE IS A LIMITED PURPOSE PUBLIC FIGURE........................................51 VIII. THE JANUARY 2015 STATEMENT WAS NOT “SUBSTANTIALLY TRUE,” AND MS. GIUFFRE HAS PRODUCED CLEAR AND CONVINCING EVIDENCE OF ITS FALSITY..............................................................................................................55 A. When Ms. Giuffre Initially Described Her Encounters With Defendant and Epstein, She Mistakenly Believed the First Encounter Occurred During the Year 1999. .............................................................................................................57 B. Defendant’s January 2015 Statement Claiming as “Untrue” and an “Obvious Lie” the Allegation That She Regularly Participated in Epstein’s Sexual Exploitation of Minors and That the Government Knows Such Fact is Not Substantially True But Instead Completely False. ................................................58 iii Case 18-2868, Document 280, 08/09/2019, 2628232, Page5 of 74 IX. C. Defendant’s January 2015 Statement Claiming as “Untrue” or an “Obvious Lie” That Maxwell and Epstein Converted Ms. Giuffre Into a Sexual Slave is Not Substantially True...........................................................................................60 D. Any Statement of Misdirection Regarding Professor Alan Dershowitz is Nothing More Than an Irrelevant Distraction to The Facts of This Case and Matters Not on the Defense of Whether Defendant’s Statement Was Substantially True..................................................................................................61 E. Contrary to Defendant’s Position, There is a Genuine Issue of Material Fact as to Whether She Created or Distributed Child Pornography, or Whether the Government Was Aware of Same. ........................................................................62 F. Defendant Did Act as a “Madame” For Epstein to Traffic Ms. Giuffre to The Rich and Famous. ..................................................................................................63 CONCLUSION .................................................................................................................65 iv Case 18-2868, Document 280, 08/09/2019, 2628232, Page6 of 74 TABLE OF AUTHORITIES Page Cases Baiul v. Disson, 607 F. App'x 18 (2d Cir. 2015)..................................................................................................50 Black v. Green Harbour Homeowners’ Ass’n, Inc., 19 A.D.3d 962, 798 N.Y.S.2d 753 (2005).................................................................................43 Block v. First Blood Associates, 691 F. Supp. 685 (Sweet, J.) (S.D.N.Y. 1988) ..............................................................41, 42, 43 Brady v. Town of Colchester, 863 F.2d 205 (2d Cir. 1988) ......................................................................................................27 Chambers v. TRM Copy Ctrs. Corp., 43 F.3d 29 (2d Cir. 1994) ..........................................................................................................50 Contemporary Mission, Inc. v. N.Y. Times Co., 842 F.2d 612 (2d Cir. 1988) ......................................................................................................51 Da Silva v. Time Inc., 908 F. Supp. 184 (S.D.N.Y. 1995) ............................................................................................47 Davis v. Costa-Gavras, 580 F. Supp. 1082 (S.D.N.Y. 1984) ..........................................................................................31 De Sole v. Knoedler Gallery, LLC, 139 F. Supp. 3d 618 (S.D.N.Y. 2015) .......................................................................................50 Eliah v. Ucatan Corp., 433 F. Supp. 309 (W.D.N.Y. 1977)...........................................................................................29 Flomenhaft v. Finkelstein, 127 A.D.3d 634, 8 N.Y.S.3d 161 (N.Y. App. Div. 2015) .........................................................42 Frechtman v. Gutterman, 115 A.D.3d 102, 979 N.Y.S.2d 58 (2014).................................................................................42 Friedman v. Meyers, 482 F.2d 435 (2d Cir. 1973) ......................................................................................................36 Front v. Khalil, 24 N.Y.3d 713 (2015).........................................................................................................passim v Case 18-2868, Document 280, 08/09/2019, 2628232, Page7 of 74 Gerts v. Robert Welch, Inc., 418 U.S. 323 (1974) ............................................................................................................49, 54 Giuffre v. Maxwell, 165 F. Supp. 3d 147 (S.D.N.Y. 2016) ................................................................................passim Greenberg v. CBS Inc., 69 A.D.2d 693, 419 N.Y.S.2d 988 (1979).................................................................................54 Harte-Hanks Commc'ns, Inc. v. Connaughton, 491 U.S. 657, 109 S. Ct. 2678, 105 L. Ed. 2d 562 (1989) ........................................................49 HB v. Monroe Woodbury Cent. School Dist., 2012 WL 4477552 (S.D.N.Y. Sept. 27, 2012) ..........................................................................34 Herbert v. Lando, 596 F. Supp. 1178 (S.D.N.Y. 1984) ..........................................................................................51 Hutchinson v. Proxmire, 443 U.S. 111, 99 S. Ct. 2675, 61 L.Ed.2d 411 (1979) ..............................................................53 In re “Agent Orange” Prod. Liab. Litig., 517 F.3d 76 (2d Cir. 2008) ........................................................................................................27 Karaduman v. Newsday, Inc., 416 N.E.2d 557 (1980) ..............................................................................................................31 Kirk v. Heppt, 532 F. Supp. 2d 586 (S.D.N.Y. 2008) .......................................................................................42 Lerman v. Flynt Distrib. Co., 745 F.2d 123 (2d Cir. 1984) ................................................................................................51, 52 Levy v. Smith, 18 N.Y.S 3d 438 (N.Y.A.D. 2 Dept. 2015) ...............................................................................28 Lopez v. Univision Communications, Inc., 45 F. Supp.2d 348 (S.D.N.Y. 1999) ..........................................................................................48 Mitre Sports Int’l Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240 (S.D.N.Y. 2014) ...............................................................................3, 47, 53 National Puerto Rican Day Parade, Inc. v. Casa Publications, Inc., 914 N.Y.S.2d 120, 79 A.D.3d 592 (N.Y.A.D. 1 Dept. 2010) ...................................................29 Nehls v. Hillsdale Coll., 178 F. Supp. 2d 771 (E.D. Mich. 2001) ....................................................................................51 vi Case 18-2868, Document 280, 08/09/2019, 2628232, Page8 of 74 Net Jets Aviation, Inc. v. LHC Commc’ns, LLC, 537 F.3d 168 (2d Cir. 2008) ......................................................................................................27 New York Times Co. v. Sullivan, 376 U.S. 254, 84 S. Ct. 710, 11 L.Ed.2d 686 (1964) ................................................................50 Pacenza v. IBM Corp., 363 F. App'x 128 (2d Cir. 2010)................................................................................................34 Patrick v. Le Fevre, 745 F.2d 153 (2d Cir. 1984) ......................................................................................................36 Petrus v Smith, 91 A.D.2d 1190 (N.Y.A.D.,1983) .............................................................................................42 Philadelphia Newspapers, Inc. v. Hepps, 475 U.S. 767 (1986) ..................................................................................................................49 Rand v. New York Times Co., 430 N.Y.S.2d 271, 75 A.D.2d 417 (N.Y.A.D. 1980) ................................................................32 Rubens v. Mason, 387 F.3d 183 (2d Cir. 2004) ......................................................................................................35 Sexter & Warmflash, P.C. v. Margrabe, 38 A.D.3d 163 (N.Y.A.D. 1 Dept. 2007) ..................................................................................42 Stern v. Cosby, 645 F. Supp. 2d 258 (S.D.N.Y. 2009) .................................................................................27, 47 Swan Brewery Co. Ltd. v. U.S. Trust Co. of New York, 832 F. Supp. 714 (S.D.N.Y. 1993) ............................................................................................27 Rules Fed. R. Civ. P. 56 ..........................................................................................................................27 Other Authorities Merriam-Webster (11th ed. 2006) ............................................................................................60, 64 RESTATEMENT (SECOND) OF TORTS § 576 (1977) .........................................................................29 SACK ON DEFAMATION § 2.7.2 at 2-113 to 2-114 (4th ed. 2016) ..................................................28 vii Case 18-2868, Document 280, 08/09/2019, 2628232, Page9 of 74 I. PRELIMINARY STATEMENT There can be no question that disputed issues of material facts preclude granting summary judgment when, in a one-count defamation case, Defendant presents the Court with a 68-page memorandum of law, a 16-page statement of purported facts, and approximately 700 pages of exhibits. The sheer scope of Defendant’s response, if anything, conclusively demonstrates that volumes of disputed facts surround the core question of whether Defendant abused Ms. Giuffre. Indeed, Defendant acknowledges a dispute between the parties as to whether she abused Ms. Giuffre. See, e.g., Motion for Summary Judgment at 1; Motion to Dismiss at 1. This Court already said that this disputed factual question is central to this case: Either Plaintiff is telling the truth about her story and Defendant’s involvement, or defendant is telling the truth and she was not involved in the trafficking and ultimate abuse of Plaintiff. The answer depends on facts. Defendant’s statements are therefore actionable as defamation. Whether they ultimately prove to meet the standards of defamation (including but not limited to falsity) is a matter for the fact-finder. Order Denying Defendant’s Motion to Dismiss at 10. While this fact remains in dispute, summary judgment is foreclosed. But even turning to Defendant’s claims, the avalanche of aspersions she casts upon Ms. Giuffre and her counsel should not distract the Court from the fact that the instant motion cannot come within sight of meeting the standard for an award of summary judgment. The most glaring and emblematic example of the Defendant’s far-fetched claims appears in her attempt to move away from her defamatory statement by arguing that it was her attorney and not her, who issued the defamatory statement for the press to publish, though she is forced to admit the statement was made on her behalf. This is an untenable position to take at trial, and an impossible argument to advance at the summary judgment stage, as both the testamentary and documentary evidence positively refute that argument. Defendant incorrectly asks this Court to make a factual 1 Case 18-2868, Document 280, 08/09/2019, 2628232, Page10 of 74 finding that her defamatory press release was actually a legal opinion, issued not by her, but by her lawyer, to the media, despite documentary evidence showing otherwise. Defendant also argues that she has proven the truth of her statement calling Ms. Giuffre a liar with respect to the statements Ms. Giuffre made about Defendant. To the contrary, voluminous evidence, both documentary and testimonial from numerous witnesses, corroborate Ms. Giuffre’s account of Defendant’s involvement in the sexual abuse and trafficking of Ms. Giuffre. Just to briefly highlight a few, Johanna Sjoberg, testified that Defendant recruited her under the guise of a legitimate assistant position, but asked her to perform sexual massages for Epstein, and punished her when she didn’t cause Epstein to orgasm.1 Tony Figueroa testified that Defendant contacted him to recruit high school-aged girls for Epstein, and also testified that Maxwell and Epstein participated in multiple threesomes with Virginia Giuffre. Even more shockingly, the butler for Defendant’s close friend witnessed, first-hand, a fifteen-year-old Swedish girl crying and shaking because Defendant was attempting to force her to have sex with Epstein and she refused. This is a fraction of the testimony that will be elicited at trial about Defendant’s involvement in the sexual abuse and trafficking of Ms. Giuffre. Defendant’s primary argument in support of her contention that she did not abuse and traffic Ms. Giuffre as a minor child is that employment records show that Ms. Giuffre was either sixteen or seventeen when Defendant recruited her from her job at Mar-a-Lago for sex with Epstein, not fifteen-years-old as Plaintiff originally thought. Call this the “yes-I’m-a-sextrafficker-but-only-of-sixteen-year-old-girls” defense. Defendant does not explain why sexual abuse of a fifteen year old differs in any material way from sexual abuse of a sixteen or seventeen year old. All instances involve a minor child, who cannot consent, and who is 1 See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 8:5-10; 13:1-3; 12:17-14:3; 15:1-5; 32:9-16; 34:5-35:1; 36:2-1. 2 Case 18-2868, Document 280, 08/09/2019, 2628232, Page11 of 74 protected by federal and state laws. The fact remains that Defendant recruited Ms. Giuffre while she was a minor child for sexual purposes and then proceeded to take her all over the world on convicted pedophile Jeffrey Epstein’s private jet, the “Lolita Express,”2 as well as to his various residences, and even to her own London house. Flight logs even reveal twenty-three flights that Defendant shared with Ms. Giuffre – although Defendant claims she is unable to remember even a single one of those flights. Inconsequential details that Ms. Giuffre may have originally remembered incorrectly do not render her substantive claims of abuse by Defendant false, much less deliberate “lies.” At most, these minor inaccuracies, in the context of a child suffering from a troubled childhood and sexual abuse, create nothing more than a fact question on whether Defendant’s statement that Ms. Giuffre lied when she accused Defendant of abuse is “substantially true,” thereby precluding summary judgment. See Mitre Sports Int’l Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 255 (S.D.N.Y. 2014) (“Because determining whether COI is substantially true would require this court to decide disputed facts ... summary judgment is not appropriate”). Defendant has tried to spin these inconsequential mistakes of memory into talismanic significance and evidence of some form of bad-faith litigation, but this claim fails under the weight of the evidence. As the Court knows, the clear weight of the evidence establishes Defendant’s heavy and extensive involvement in both Jeffrey Epstein’s sex trafficking ring and in recruiting Ms. Giuffre, living with her and Jeffrey Epstein in the same homes while Ms. Giuffre was a minor, and traveling with Ms. Giuffre and Jeffrey Epstein – including 23 documented flights. Even the house staff testified that Defendant and Ms. Giuffre were regularly 2 See, e.g.: “All aboard the ‘Lolita Express’: Flight logs reveal the many trips Bill Clinton and Alan Dershowitz took on pedophile Jeffrey Epstein’s private jet with anonymous women” at The Daily Mail, http://www.dailymail.co.uk/news/article-2922773/Newly-released-flight-logs-reveal-time-trips-Bill-ClintonHarvard-law-professor-Alan-Dershowitz-took-pedophile-Jeffrey-Epstein-s-Lolita-Express-private-jet-anonymouswomen.html. 3 Case 18-2868, Document 280, 08/09/2019, 2628232, Page12 of 74 together. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 103:4-9 (“Q. After that day, do you recall that she started coming to the house more frequently. A. Yes, she did. Q. In fact, did she start coming to the house approximately three times a week? A. Yes, probably.”). It is also undisputed that witnesses deposed in this case have testified about Defendant’s role as a procurer of underage girls and young women for Jeffrey Epstein. At the very least, a trier of fact should determine whether the evidence establishes whether or not Ms. Giuffre’s claims of Defendant being involved in her trafficking and abuse are true. Defendant’s summary judgment motion should be denied in its entirety. II. UNDISPUTED FACTS The record evidence in this case shows that Defendant shared a household with convicted pedophile Jeffrey Epstein for many years. While there, she actively took part in recruiting underage girls and young women for sex with Epstein, as well as scheduling the girls to come over, and maintaining a list of the girls and their phone numbers. Ms. Giuffre was indisputably a minor when Defendant recruited her to have sex with convicted pedophile Jeffrey Epstein. Thereafter, Ms. Giuffre flew on Epstein’s private jets – the – Lolita Express” – with Defendant at least 23 times. A. It is an Undisputed Fact That Multiple Witnesses Deposed in This Case Have Testified That Defendant Operated as Convicted Pedophile Jeffrey Epstein’s Procurer of Underage Girls. 1. It is an undisputed fact that Joanna Sjoberg testified Defendant lured her from her school to have sex with Epstein under the guise of hiring her for a job answering phones. Ms. Sjoberg’s account of her experiences with Defendant are chillingly similar. As with Ms. Giuffre, Defendant, a perfect stranger, approached Ms. Sjoberg while trolling Ms. Sjoberg’s school grounds. She lured Ms. Sjoberg into her and Epstein’s home under the guise of a legitimate job of answering phones, a pretext that lasted only a day. A young college student, 4 Case 18-2868, Document 280, 08/09/2019, 2628232, Page13 of 74 nearly 2,000 miles from home, Defendant soon instructed Ms. Sjoberg to massage Epstein, and made it clear that Sjoberg’s purpose was to bring Epstein to orgasm during these massages so that Defendant did not have to do it. Q. And when did you first meet Ms. Maxwell? A. 2001. March probably. End of February/beginning of March. Q. And how did you meet her? A. She approached me while I was on campus at Palm Beach Atlantic College. *** Q. And how long did you work in that position answering phones and doing -A. Just that one day. *** Q. And what happened that second time you came to the house? A. At that point, I met Emmy Taylor, and she took me up to Jeffrey’s bathroom and he was present. And her and I both massaged Jeffrey. She was showing me how to massage. And then she -- he took -- he got off the table, she got on the table. She took off her clothes, got on the table, and then he was showing me moves that he liked. And then I took my clothes off. They asked me to get on the table so I could feel it. Then they both massaged me. *** Q. Who did Emmy work for? 2 A. Ghislaine. 3 Q. Did Maxwell ever refer to Emmy by any particular term? 5 A. She called her her slave. *** Q. Did Jeffrey ever tell you why he received so many massages from so many different girls? A. He explained to me that, in his opinion, he needed to have three orgasms a day. It was biological, like eating. *** Q. Was there anything you were supposed to do in order to get the camera? THE WITNESS: I did not know that there were expectations of me to get the camera until after. She [Defendant] had purchased the camera for me, and I was over there giving Jeffrey a massage. I did not know that she was in possession of the camera until later. She told me -called me after I had left and said, I have the camera for you, but you cannot receive it yet because you came here and didn’t finish your job and I had to finish it for you. Q. And did you -- what did you understand her to mean? A. She was implying that I did not get Jeffrey off, and so she had to do it. Q. And when you say “get Jeffrey off,” do you mean bring him to orgasm? A. Yes. *** Q. Based on what you knew, did Maxwell know that the type of massages Jeffrey was getting typically involved sexual acts? THE WITNESS: Yes. Q. What was Maxwell’s main job with respect to Jeffrey? 5 Case 18-2868, Document 280, 08/09/2019, 2628232, Page14 of 74 THE WITNESS: Well, beyond companionship, her job, as it related to me, was to find other girls that would perform massages for him and herself.3 Ms. Sjoberg also testified about sexual acts that occurred with her, Prince Andrew, and Ms. Giuffre, when she and Defendant were staying at Epstein’s Manhattan mansion: Q. Tell me how it came to be that there was a picture taken. THE WITNESS: I just remember someone suggesting a photo, and they told us to go get on the couch. And so Andrew and Virginia sat on the couch, and they put the puppet, the puppet on her lap. And so then I sat on Andrew’s lap, and I believe on my own volition, and they took the puppet’s hands and put it on Virginia’s breast, and so Andrew put his on mine.4 Ms. Sjoberg’s testimony corroborates Ms. Giuffre’s account of how Defendant recruited her (and others) under a ruse of a legitimate job in order to bring them into the household to have sex with Epstein. Ms. Sjoberg’s testimony also corroborates Ms. Giuffre’s account of being lent out to Prince Andrew by Defendant, as even the interaction Ms. Sjoberg witnessed included a sexual act: Prince Andrew using a puppet to touch Ms. Giuffre’s breast while using a hand to touch Ms. Sjoberg’s breast. 2. It is an undisputed fact that Tony Figueroa testified that Defendant would call him to bring over underage girls and that Defendant and Epstein would have threesomes with Ms. Giuffre.5 Tony Figueroa testified that Plaintiff told him about threesomes Ms. Giuffre had with Defendant and Epstein which included the use of strap-ons: Q. Okay. And tell me everything that you remember about what Ms. Roberts said about being intimate with Ms. Maxwell and Mr. Epstein at the same time. A. I remember her talking about, like, strap-ons and stuff like that. But, I mean, like I said, all the details are not really that clear. But I remember her talking about, like, how they would always be using and stuff like that. Q. She and Ms. Maxwell and Mr. Epstein would use strap-ons? A. Uh-huh (affirmative). *** 3 See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 8:5-10; 13:1-3; 12:17-14:3; 15:1-5; 32:9-16; 34:5-35:1; 36:2-15. 4 See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 82:23-83:9. 5 Defendant attempts to discredit Figueroa’s damaging testimony by repeatedly mentioning that he has been convicted for a drug-related offense. Unsurprisingly, in this attack, Defendant does not mention that she has a DUI conviction. See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 390:13-15. (April 22, 2016). 6 Case 18-2868, Document 280, 08/09/2019, 2628232, Page15 of 74 Q. Other than sex with the Prince, is there anyone else that Jeffrey wanted Ms. Roberts to have sex with that she relayed to you? A. Mainly, like I said, just Ms. Maxwell and all the other girls. Q. Ms. Maxwell wanted -- Jeffrey wanted Virginia to have sex with Ms. Maxwell? A. And him, yeah. Q. And did she tell you whether she had ever done that? A. Yeah. She said that she did. *** Q. And what did she describe having happened? A. I believe I already told you that. With the strap-ons and dildos and everything.6 .7 Figueroa also testified that Defendant called him to ask if he had found any other girls for Epstein, thereby acting as procurer of girls for Epstein: Q. [W]hen Ghislaine Maxwell would call you during the time that you were living with Virginia, she would ask you what, specifically? A. Just if I had found any other girls just to bring to Jeffrey. Q. Okay. A. Pretty much every time there was a conversation with any of them, it was either asking Virginia where she was at, or asking her to get girls, or asking me to get girls. *** Q. Okay. Well, tell me. When did Ms. Maxwell ask you to bring a girl? A. Never in person. It was, like, literally, like, on the phone maybe, like, once or twice. Q All right. Did Ms. Maxwell call you frequently? A. No. Q. All right. How many times do you think Ms. Maxwell called you, at all? A. I’d just say that probably a just a few, a couple of times. Maybe once or twice. Q. One or two -A. The majority of the time it was pretty much his assistant. Q. How do you know Ms. Maxwell’s voice? A. Because she sounds British. Q. So someone with a British accent called you once or twice and asked for -A. Well, she told me who she was. Q. Okay. And what did she say when she called you and asked you to bring girls? A. She just said, “Hi. This is Ghislaine. Jeffrey was wondering if you had anybody that could come over.”8 6 See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103. See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 55:19-58:23 (July 22, 2016). 8 See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 200:6-18; 228:23-229:21. 7 7 Case 18-2868, Document 280, 08/09/2019, 2628232, Page16 of 74 3. It is an undisputed fact that Rinaldo Rizzo testified that Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein. Rinaldo Rizzo was the house manager for one of Defendant’s close friends, Eva Dubin. Mr. Rizzo testified - through tears – how, while working at Dubin’s house, he observed Defendant bring a 15 year old Swedish girl to Dubin’s house. In distress, the 15 year old girl tearfully explained to him that Defendant tried to force her to have sex with Epstein through threats and stealing her passport: Q. How old was this girl? A. 15 years old. *** Q. Describe for me what the girl looked like, including her demeanor and anything else you remember about her when she walks into the kitchen. A. Very attractive, beautiful young girl. Makeup, very put together, casual dress. But she seemed to be upset, maybe distraught, and she was shaking, and as she sat down, she sat down and sat in the stool exactly the way the girls that I mentioned to you sat at Jeffrey’s house, with no expression and with their head down. But we could tell that she was very nervous. Q. What do you mean by distraught and shaking, what do you mean by that? A. Shaking, I mean literally quivering. *** Q. What did she say? A. She proceeds to tell my wife and I that, and this is not -- this is blurting out, not a conversation like I’m having a casual conversation. That quickly, I was on an island, I was on the island and there was Ghislaine, there was Sarah, she said they asked me for sex, I said no. And she is just rambling, and I’m like what, and she said -- I asked her, I said what? And she says yes, I was on the island, I don’t know how I got from the island to here. Last afternoon or in the afternoon I was on the island and now I’m here. And I said do you have a -- this is not making any sense to me, and I said this is nuts, do you have a passport, do you have a phone? And she says no, and she says Ghislaine took my passport. And I said what, and she says Sarah took her passport and her phone and gave it to Ghislaine Maxwell, and at that point she said that she was threatened. And I said threatened, she says yes, I was threatened by Ghislaine not to discuss this. And I’m just shocked. So the conversation, and she is just rambling on and on, again, like I said, how she got here, she doesn’t know how she got here. Again, I asked her, did you contact your parents and she says no. At that point, she says I’m not supposed to talk about this. I said, but I said: How did you get here. I don’t understand. We were totally lost for words. And she said that before she got there, she was threatened again by Jeffrey and Ghislaine not to talk about what I had mentioned earlier, about -- again, the word she used was sex. Q. And during this time that you’re saying she is rambling, is her demeanor continues to be what you described it? 8 Case 18-2868, Document 280, 08/09/2019, 2628232, Page17 of 74 A. Yes. Q. Was she in fear? A. Yes. Q. You could tell? A. Yes. A. She was shaking uncontrollably.9 4. It is an undisputed fact that Lyn Miller testified that she believed Defendant became Ms. Giuffre’s “new mama”. Lyn Miller is Ms. Giuffre’s mother. She testified that when Ms. Giuffre started living with Defendant, Defendant became Ms. Giuffre’s “new momma.”10 Incredulously, Defendant testified that she barely remembered Ms. Giuffre.11 5. It is an undisputed Fact that Detective Joseph Recarey testified that he sought to investigate Defendant in relation to his investigation of Jeffrey Epstein. Detective Recarey led the Palm Beach Police’s investigation of Epstein. He testified that Defendant procured girls for Epstein, and that he sought to question her in relation to his investigation, but could not contact her due to the interference of Epstein’s lawyer: Q. A cross-reference of Jeffrey Epstein’s residence revealed which affiliated names? A. It revealed Nadia Marcinkova, Ghislane Maxwell, Mark Epstein. Also, the crossreference, any previous reports from the residence as well. Q. During your investigation, did you learn of any involvement that Nadia Marcinkova had with any of the activities you were investigating? *** Q. The other name that is on here as a cross-reference is Ghislane Maxwell. Did you speak with Ghislane Maxwell? A. I did not. Q. Did you ever attempt to speak with Ghislane Maxwell? A. I wanted to speak with everyone related to this home, including Ms. Maxwell. My contact was through Gus, Attorney Gus Fronstin, at the time, who initially had told me that he would make everyone available for an interview. And subsequent conversations later, no one was available for interview and everybody had an attorney, and I was not going to be able to speak with them. Q. Okay. During your investigation, what did you learn in terms of Ghislane Maxwell’s involvement, if any? 9 See McCawley Dec. at Exhibit 14, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52:6-7; 52:25-53:17; 55:23-58:5 See McCawley Dec. at Exhibit 12, Lynn Miller’s May 24, 2016 Dep. Tr. at 115. 11 See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 77:25-78:15 (April 22, 2016). 10 9 Case 18-2868, Document 280, 08/09/2019, 2628232, Page18 of 74 THE WITNESS: Ms. Maxwell, during her research, was found to be Epstein’s long-time friend. During the interviews, Ms. Maxwell was involved in seeking girls to perform massages and work at Epstein’s home.12 6. It is an undisputed fact that Pilot David Rodgers testified that he flew Defendant and Ms. Giuffre at least 23 times on Epstein’s jet, the “Lolita Express” and that “GM” on the flight logs Stands for Ghislaine Maxwell. Notably, at Defendant’s deposition, Defendant refused to admit that she flew with Ms. Giuffre, and denied that she appeared on Epstein’s pilot’s flight logs.13 However, David Rodgers, Epstein pilot, testified that the passenger listed on his flight logs bearing the initials – GM – was, in fact, Ghislaine Maxwell, and that he was the pilot on at least 23 flights in which Defendant flew with Plaintiff.14 The dates of those flights show that Ms. Giuffre was an underage child on many of them when she flew with Defendant.15 7. It is an undisputed fact that Sarah Kellen, Nadia Marcinkova, and Jeffrey Epstein invoked the Fifth Amendment when asked about Defendant trafficking girls for Jeffery Epstein. Both Sarah Kellen and Nadia Marcinkova lived with Jeffrey Epstein for many years. They both invoked the Fifth Amendment when asked about Defendant’s participation in recruiting underage girls for sex with Epstein. Marcinkova testified as follows: Q. Did Ghislaine Maxwell work as a recruiter of young girls for Jeffrey Epstein when you met her? A. Same answer. [Invocation of Fifth Amendment] *** Q. Have you observed Ghislaine Maxwell and Jeffrey Epstein convert what started as a massage with these young girls into something sexual? A. Same answer.16 12 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 27:10-17; 28:21-29:20. See McCawley Dec. at Exhibit 11, Maxwell’s April 22, 2016 Dep. Tr. at 78-79, 144. 14 See McCawley Decl. at Exhibit 41, Rodgers Dep. Ex. 1, GIUFFRE 007055-007161 (flight records evidencing Defendant (GM) flying with Ms. Giuffre). 15 See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36; see also Exhibit 41, Rodgers Dep. Ex. 1 at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589. 16 See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 12:11-15. 13 10 Case 18-2868, Document 280, 08/09/2019, 2628232, Page19 of 74 Kellen testified as follows: Q. Did Ghislaine Maxwell work as a recruiter for young girls for Jeffrey Epstein when you met her? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege . . . *** Q. Isn’t it true that Ghislaine Maxwell would recruit underage girls for sex and sex acts with Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege . . .17 Similarly, Jeffrey Epstein invoked the Fifth Amendment when asked about Defendant’s involvement in procuring underage girls for sex with him. Q. Maxwell was one of the main women whom you used to procure underage girls for sexual activities, true? THE WITNESS: Fifth. *** Q. Maxwell was a primary co-conspirator in your sexual abuse scheme, true? THE WITNESS: Fifth. Q. Maxwell was a primary co-conspirator in your sex trafficking scheme, true? THE WITNESS: Fifth. Q. Maxwell herself regularly participated in your sexual exploitation of minors, true? THE WITNESS: Fifth.18 8. It is an undisputed fact that Juan Alessi testified that Defendant was one of the people who procured some of the over 100 girls he witnessed visit Epstein, and that he had to clean Defendant’s sex toys. Juan Alessi was Epstein’s house manager. He testified as follows: Q. And over the course of that 10-year period of time while Ms. Maxwell was at the house, do you have an approximation as to the number of different females – females that you were told were massage therapists that came to house? A. I cannot give you a number, but I would say probably over 100 in my stay there. *** Q. I don’t think I asked the right – the question that I was looking to ask, so let me go back. Did you go out looking for the girls – A. No. Q. – to bring – A. Never Q. – as the massage therapists? A. Never. Q. Who did? 17 18 See McCawley Dec. at Exhibit 8, Kellen Dep. Tr. at 15:13-18; 20:12-16. See McCawley Dec. at Exhibit 3, Epstein Dep. Tr. at 116:10-15; 117:18-118:10. 11 Case 18-2868, Document 280, 08/09/2019, 2628232, Page20 of 74 A. Ms. Maxwell, Mr. Epstein and their friends, because their friend relay to other friends they knew a massage therapist and they would send to the house. So it was referrals. *** Q. Did you have occasion to clean up after the massages? A. Yes. Q. Okay. And that is after both a massage for Jeffrey Epstein, as well as clean up after a massage that Ghislaine Maxwell may have received? A. Yes. Q. And on occasion, after -- in cleaning up after a massage of Jeffrey Epstein or Ghislaine Maxwell, did you have occasion to find vibrators or sex toys that would be left out? A. yes, I did.19 9. It is an undisputed fact that Defendant was unable to garner a single witness throughout discovery who can testify that she did not act as the procurer of underage girls and young women for Jeffrey Epstein. Defendant has not been able to procure a single witness - not one – to testify that Defendant did not procure girls for sex with Epstein or participate in the sex. Even one of her own witnesses, Tony Figueroa, testified that she both procured girls and participated in the sex. Another one of Defendant’s witnesses, Ms. Giuffre’s mother, named Defendant as Ms. Giuffre’s “new mamma.” Indeed, those who knew her well, who spent considerable time with her in Epstein’s shared household, like Juan Alessi, Alfredo Rodriguez and Joanna Sjoberg, have testified that she was Epstein’s procuress. Others who lived with her – Jeffrey Epstein, Nadia Marcinkova, and Sarah Kellen – invoked the Fifth Amendment so as not to answer questions on the same. No one has testified to the contrary. B. Documentary Evidence also Shows that Defendant Trafficked Ms. Giuffre and Procured her for Sex with Convicted Pedophile Jeffrey Epstein while She Was Underage. 1. The Flight Logs Defendant has never offered a legal explanation for what she was doing with, and why she was traveling with, a minor child on 21 flights while she was a child, including 6 international flights, aboard a convicted pedophile’s private jet all over the world. Her motion for 19 See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28:6-15; 30:51-25; 52:9-22. 12 Case 18-2868, Document 280, 08/09/2019, 2628232, Page21 of 74 summary judgment – as well as all previous briefing papers – are absolutely silent on those damning documents. 2. The Photographs Throughout a mountain of briefing and, and even in her own deposition testimony, Defendant never offered an explanation regarding Ms. Giuffre’s photographs of her, Defendant, and Epstein. She never offered a legal explanation for why Prince Andrew was photographed with his hand around Ms. Giuffre’s bare waist while she was a minor child, while posing with Defendant, inside Defendant’s house in London. This particular photograph corroborates Ms. Giuffre’s claims, and there is no other reasonable explanation why an American child should be in the company of adults not her kin, in the London house owned by the girlfriend of a nowconvicted sex offender.20 Ms. Giuffre also produced pictures of herself taken when she was in New York with Defendant and Epstein, and from a trip to Europe with Defendant and Epstein:21 20 21 See McCawley Dec at Exhibit 42, GIUFFRE007167, Prince Andrew and Defendant Photo. See McCawley Dec at Exhibit 42, GIUFFRE007182 - 007166. 13 Case 18-2868, Document 280, 08/09/2019, 2628232, Page22 of 74 And, Ms. Giuffre has produced a number of pictures of herself taken at the Zorro Ranch, Epstein’s New Mexico Ranch, two of which are below. 22 Finally, among other nude photos, which included full nudes of Defendant, Ms. Giuffre produced images of females that the Palm Beach Police confiscated during the execution of the 22 See McCawley Dec at Exhibit 42, GIUFFRE007175; 007173. 14 Case 18-2868, Document 280, 08/09/2019, 2628232, Page23 of 74 warrant, including one photograph revealing the bare bottom of a girl who appears to be prepubescent (Ms. Giuffre will only submit its redacted form): 23 3. The Victim Identification Letter In 2008, the United States Attorney’s office for the Southern District of Florida identified Ms. Giuffre as a protected “victim” of Jeffrey Epstein’s sex abuse. The U.S. Attorney mailed Ms. Giuffre a notice of her rights as a crime victim under the CVRA.24 4. New York Presbyterian Hospital Records Ms. Giuffre has provided extensive medical records in this case, including medical records from the time when Defendant was sexually abusing and trafficking her. Ms. Giuffre produced records supporting her claim of being sexually abused in New York resulting in both 23 24 See McCawley Dec at Exhibit 44, GIUFFRE007584. See McCawley Dec. at Exhibit 30, GIUFFRE 002216-002218, Victim Notification Letter. 15 Case 18-2868, Document 280, 08/09/2019, 2628232, Page24 of 74 Defendant and Epstein taking Plaintiff to New York Presbyterian Hospital in New York while she was a minor.25 The dates on the hospital records show she was seventeen years old. 5. Judith Lightfoot Psychological Records As the Court is aware, Defendant propounded wildly overbroad requests for production concerning the past eighteen years of Ms. Giuffre’s medical history. Defendant repeatedly and vehemently argued to the Court that it was essential to procure every page of these records in a fanfare of unnecessary motion practice. See, e.g., Defendant’s Motion to Compel (DE 75); Defendant’s Motion for Sanctions at 10 (“Ms. Maxwell has been severely prejudiced by Plaintiff’s failure to provide the required identifying information and documents from her health care providers.”). Ms. Giuffre and her counsel took on the considerable burden and significant expense of retrieving and producing over 250 pages of medical records from over 20 providers, spanning two continents and nearly two decades. Now that those records have been collected, Defendant’s 68 page motion makes no reference to a single medical record produced by Ms. Giuffre, nor a single provider, nor a single treatment, nor or a single medication prescribed. After Defendant’s repeated motion practice stressing the essentiality of these records, this may surprise the Court. But not Ms. Giuffre. Defendant’s requests unearthed documents that are highly unfavorable to Defendant that corroborate Ms. Giuffre’s claims against her. Years before this cause of action arose, Ms. Giuffre sought counseling from a psychologist for the trauma she continued to experience after being abused by Defendant and Epstein. A 2011 psychological treatment record, written by her treating psychologist, unambiguously describes Defendant as Ms. Giuffre’s abuser: 25 See McCawley Dec at Exhibit 33, GIUFFRE003259-003290. 16 Case 18-2868, Document 280, 08/09/2019, 2628232, Page25 of 74 . . . [Ms. Giuffre] was approached by Ghislaine Maxwell who said she could help her get a job as a massage therapist . . . seemed respectable . . . was shown how to massage, etc., Geoff [sic] Epstein. Told to undress and perform sexual acts on person. Miss Maxwell promised her $200 a job.26 Therefore, years before Defendant defamed her, Ms. Giuffre confided in her treating psychologist that Maxwell recruited her for sex with Epstein. 6. Message Pads Detective Recarey, the lead investigator of the criminal investigation into Epstein and his associates’ sex crimes, recovered carbon copies of hand-written messages taken by various staff, including Defendant, at Epstein’s Palm Beach residence.27 These were collected both from trash pulls from the residence and during the execution of the search warrant where the pads were found laying out in the open in the residence.28 The search warrant was executed in 2005 and the message pads collected include messages recorded in 2004 and 2005. Numerous witnesses have described that these copies of collected messages accurately reflect those taken by various staff at the Palm Beach Epstein mansion between 2004 and 2005.29 The messages raise a question of fact as to Maxwell’s involvement in the sexual abuse of minors and are relevant to refute Maxwell’s denial of any involvement with Epstein during relevant time periods, and, accordingly her denial of knowledge of certain events. While there were hundreds of these messages recovered during the investigation, this small sample demonstrates the undeniable reality that there exists a genuine issue of material fact with respect to Defendant’s involvement in and knowledge of the activities described by Giuffre which Maxwell has said we “untrue” and “obvious lies.” 26 See McCawley Dec. at Exhibit 38, Lightfoot Records, GIUFFRE005437. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 45:13-25; 97:9-98:8. 28 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 25:12-21; 40:5-15; 41:16-23; 42:14-43:10; 45:13-25; see also search warrant video showing the pads openly displayed on the desk. 29 See McCawley Dec. at Exhibit 21, 1, 16, 11, Rodriguez Dep. Tr. at 73:19-74:12; Alessi Dep. Tr. at 141:18-21; Sjoberg Dep. Tr. at 64:1-6; Maxwell Dep. Tr. at 147:23-148:3; 148:19-149:14. 27 17 Case 18-2868, Document 280, 08/09/2019, 2628232, Page26 of 74 This sampling reveals that Maxwell, “GM,” took messages at the residence, including from underage girls who were calling to schedule a time to come over to see Epstein. This demonstrates that Maxwell was at Epstein’s Palm Beach mansion in 2004 and 2005, incidentally a time period she has denied being around the house in her deposition. See supra GIUFFRE001412; 001435; 001449. The messages also reveal that multiple “girls” were leaving messages that were being taken and memorialized and left out in the open for anyone to see. Certain messages also make clear that a number of these “girls” were in school. In addition to taking messages herself (and the staff working under her direction taking these relevant messages), staff employees were taking and leaving messages for Defendant. This is evidence that Maxwell was in the house at relevant times, including times that she has now testified under oath that she was not there. Other messages demonstrate Epstein and Maxwell’s friends, including Jean Luc Brunel, leaving messages relating to underage females. The following is a small sampling of such messages: 18 Case 18-2868, Document 280, 08/09/2019, 2628232, Page27 of 74 FMPORTANT FOR i?I'I??i 1' .1, DATE ME . RM. . UF. .. PLEASE cm To SEE YOU I TO SEE YOU Eniw {m . - 521001461 cl'z -. GIUFFRE001432 DATE OF menu?__u- - .. TELEPHBNED names ml. CAME 10- SEE Irou CALL mam mums To see you HUSH BEWFWEDVOUH CHILL SPEWL Eff; .. '31 GIUFFRE001456 I IMPORTANT MESSAGE 1" roau_# 1a I {w 1.123, :Iur _szIgj I . MOBIL W, aria-L cmE 1n SEE mama.? wuns 10 SEE vou HUSH mumn mun CALL GPECUIL AI rem: on usasmr_ - .7 . I - ?Lad r. .. I smoms . 1134] GI FF REOU 1426 1455} IMPORTANT MESSAGE mower) PLEASE CALL CAME ro SEE You Mam WANTS 10 SEE YOU HUSH FLEMILED Tour-I SPECIHL AWEMION . I. SJGNED um: GI UFFRE001448 IMPORTANT Fm?yy' JO AM DORE- gf? TIME PM. OF MOBILE 1515910an paw]: CALL 5v: To SFE mu WILL autumn? W11 TO SEE Yd? pun 10m CALL lie-cm ATI 2mm w??e has a. fauc/vdu? you 1% feardrf 7w hob/1L0 Jpr?cu? ire/?13m. 546.3 is Z): Lin/g (44? frc__ i ?1 3 .. Ila-1 GIUFFRE001563 1 Fm VT . II . Lane?hr ?jar?0.5.; I or'? p, p: I 1_ IEI. Epm Em: TO SEE $01: Tau?5'5: .35 rum 9 HEAT: PIEASECML WILLCILII AGAIN .?05?1 I I . Em,? MESSAGE LL. 1:596]? GI UFFRE001423 19 WPORTANT 1E1. EPHONED CML GAME 10 SEE YOU WILL cm. AGAIN - REGIME Your! ml 39m ATTEMIION for- ?mmqii SIGNED . 111M GIUFFRE001452 Fun SEIEQJ Ml- TIME u?bmimac". - OF MILE- . I?l EASE CALL TO SEE YOU WILL AGAIN WW3 TO SEE YOU PUSH RETURNED YOUR CALL SPECIAL ELF-WHEELS). Rum-.9. ?13314an -- saozssu SIGNED GI UFFRE001454 Case 18-2868, Document 280, 08/09/2019, 2628232, Page28 of 74 The following are descriptions of a sampling of messages pads30 that create a genuine dispute of material fact:  One message pad reflects , who is identified in the Palm Beach Police Report as a minor, contacting Jeffrey Epstein for “work” explaining that she does not have any money. The term “work” was often used by members of Jeffrey Epstein’s sexual trafficking ring to refer to sexual massages. (See GIUFFRE05660 (“She stated she was called by Sara for her to return to work for Epstein. stated ‘work’ is the term used by Sarah to provide the massage in underwear.”). Giuffre 001462: July 5th no year to JE from ”I need work. I mean I don’t have money. Do you have some work for me?”  Other message pads reflect who was a minor, calling and leaving a message at the Palm Beach mansion that she has recruited another girl for Jeffrey Epstein. The second message demonstrates that Jeffrey Epstein required different girls to be scheduled every day of the week. The third shows an offer to have two minor girls come to the home at the same time to provide sexual massages. These type of messages indicate the lack of secrecy of the fact that multiple young females were visiting every day and at least raises a question of fact whether Maxwell was knowledgeable and involved as Giuffre has said, or whether Giuffre was lying and Maxwell was not at all involved or aware of this activity, as Defendant would attempt to have the world believe. Giuffre 001428 – undated Jeffrey From – “Has girl for tonight” ;Giuffre 001432 (pictured above)– 7/9/04 – Mr. Epstein From –“ is available on Tuesday no one for tomorrow”; GIUFFRE 001433 /1/17/04 – Mr. Epstein from – “Me and _____ can come tomorrow any time or alone” ; Giuffre – 001452 – undated Jeffrey from “Has girl for tonight.”  Other message pads demonstrate that there was a pattern and practice of using young females to recruit additional young females to provide sexual massages on a daily basis. Giuffre 001413 (pictured above)– JE from “N” – “ hasn’t confirmed for 11:00 yet, so she is keeping on hold in case doesn’t call back; Giuffre 001448 -8/20/05 JE from confirmed ___ at 4 pm. Who is scheduled for morning? I believe wants to work.” This message pad reflects that a friend of Jeffrey Epstein is sending him a sixteen year old Russian girl for purposes of sex. Giuffre 001563 (pictured above)- 6/1/05 For Jeffrey From Jean Luc “He has a teacher for you to teach you how to speak Russian. She is 2X8 years old not blonde. Lessons are free and you can have your 1st today if you call.”  This message pad directly refutes Maxwell’s sworn testimony that she was not present during the year 2005 at Jeffrey Epstein’s Palm Beach mansion because this shows leaving a message for Jeffrey at the Palm Beach home that she was going to work out 30 See McCawley Dec. at Exhibit 28. 20 Case 18-2868, Document 280, 08/09/2019, 2628232, Page29 of 74 with the Defendant on September 10, 2005. The police were only able to retrieve a fraction of these message pads during their trash pull but even in the few they recovered, it shows Maxwell was regularly at the Palm Beach home during the time period she claimed she was not. To the contrary, she was both sending and receiving messages and messages, like this one, reflect her presence at the mansion. Giuffre 001412 – 9/10/05 (during the year Maxwell says she was never around) JE from – “I went to Sarah and made her water bottle and I went to work out with GM.”  These message pads further corroborate that Defendant lied in her testimony and she was in fact in regular contact with Jeffrey Epstein during the years 2004 and 2005. For example, the message from “Larry” demonstrates that Defendant is at the Palm Beach mansion so frequently that people, including Epstein’s main pilot Larry Visoski, are leaving messages for Maxwell at the Palm Beach house. Giuffre 001435 7/25/04 – Mr. Epstein from Ms. Maxwell – “tell him to call me”; Giuffre – 001449 – 8/22/05 – JE from GM; Giuffre – 001453 – 4/25/04 for Ms. Maxwell From Larry “returning your call”;  This message pad shows that Defendant was clearly actively involved in Jeffrey Epstein’s life and the activities at his Palm Beach mansion. Giuffre – 001454 – undated Jeffrey From Ghislaine – “Would be helpful to have ___________ come to Palm Beach today to stay here and help train new staff with Ghislaine.”  This message pad clearly reflects an underage female (noted by the police redaction of the name) leaving a message asking if she can come to the house at a later time because she needs to “stay in school.” Giuffre 001417 (pictured above)– Jeffrey 2/28/05 Redacted name “She is wondering if 2:30 is o.k. She needs to stay in school.”  This message pad reflects a message from who was under the age of eighteen at the time she was going over to Jeffrey Epstein’s home to provide sexual massages according to the Palm Beach Investigative Report. Giuffre 001421 3/4/05 to Jeffrey from “It is o.k. for to stop by and drop something?”  These message pads reflect the pattern of underage girls (noted by the police redaction of the name on the message pad) calling the Palm Beach mansion to leave a message about sending a “female” over to provide a sexual massage. Giuffre 001423 11/08/04 To Mr. JE – redacted from – “I have a female for him” Giuffre 001426 (pictured above) – 1/09/05 JE To JE from Redacted – “I have a female for him.”  This message pad reflects the pattern and practice of having young girls bring other young girls to the house to perform sexual massages. Indeed the “ ” reflected in this message pad corresponds in name to the ” that Tony Figueroa testified he initially brought to Jeffrey Epstein during the time period that the Defendant was requesting that Tony find some young females to bring to Jeffrey Epstein’s home. See Figueroa at 184185. The Palm Beach Police Report reflects that “ ” and “ ” also brought seventeen year old to the home to perform sexual massages. See GIUFFRE 05641. thereafter recruited a number of other young girls to perform sexual 21 Case 18-2868, Document 280, 08/09/2019, 2628232, Page30 of 74 massages as reflected in the Palm Beach Police Report. Giuffre 001427 (pictured above) – 1/2/03 – JE from “Wants to know if she should bring her friend with tonight.”  This message pad reflects multiple sexual massages being scheduled for the same day which corroborates Virginia GIUFFRE, and Johanna Sjorberg’s testimony that Jeffrey Epstein required that he have multiple orgasms in a day which occurred during these sexual massages. Giuffre 001449 (pictured above) – 9/03/05 JE from – “I left message for to confirm for 11:00 a.m. and for 4:30 p.m.”  This message pad shows a friend of Jeffrey Epstein’s discussing with him how he had sex with an 18 year old who had also been with Jeffrey Epstein. Giuffre – 001456 (pictured above)– undated JE from Jean Luc – “He just did a good one – 18 years – she spoke to me and said “I love Jeffrey.” Law enforcement was able to confirm identities of underage victims through the use of the names and telephone numbers in these message pads: Q. The next line down is what I wanted to focus on, April 5th, 2005. This trash pull, what evidence is yielded from this particular trash pull? THE WITNESS: The trash pull indicated that there were several messages with written items on it. There was a message from HR indicating that there would be an 11:00 appointment. There were other individuals that had called during that day. Q. And when you would -- when you would see females’ names and telephone numbers, would you take those telephone numbers and match it to -- to a person? THE WITNESS: We would do our best to identify who that person was. Q. And is that one way in which you discovered the identities of some of the other what soon came to be known as victims? THE WITNESS: Correct. *** Q. Did you find names of other witnesses and people that you knew to have been associated with the house in those message pads? THE WITNESS: Yes. Q. And so what was the evidentiary value to you of the message pads collected from Jeffrey Epstein’s home in the search warrant? THE WITNESS: It was very important to corroborate what the victims had already told me as to calling in and for work.31 7. The Black Book Palm Beach Police confiscated an extensive lists of contacts with their phone numbers form Defendant and Epstein’s residence.32 Ghislaine Maxwell maintained a contact list in an 31 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 42:14-43:17; 78:25:-79:15. 22 Case 18-2868, Document 280, 08/09/2019, 2628232, Page31 of 74 approximately 100-page-long hard copy, which was openly available to other house employees. It consisted primarily of telephone numbers, addresses, or email addresses for various personal friends, associates, employees, or personal or business connections of Epstein or Defendant. Prior to being terminated by Defendant, the Palm Beach house butler Alfredo Rodriguez printed a copy of this document and ultimately provided it to the FBI. This document reflects the numerous phone numbers of Defendant, Epstein as well as staff phone numbers. Additionally, and importantly, there are several sections entitled “Massage” alongside a geographical designation with names of females and corresponding telephone numbers. These numbers included those of underage females (with no training in massage therapy ) – including – identified during the criminal investigation of Epstein. This document is an authentic reflection of the people who were associated with Epstein, Defendant, and the management of their properties, and the knowledge each had of the contents of the document. 8. Sex Slave Amazon.com Book Receipt Detective Recarey authenticated an Amazon.com receipt that the Palm Beach Police collected from Jeffrey Epstein’s trash. The books he ordered are titled: (1) SM 101: A Realistic Introduction, Wiseman, Jay; (2) SlaveCraft: Roadmaps for Erotic Servitude – Principles, Skills and Tools by Guy Baldwin; and (3) Training with Miss Abernathy: A Workbook for Erotic Slaves and Their Owners, by Christina Abernathy, as shown below: 32 See McCawley Dec. at Exhibit 45, Phone List, Public Records Request No.: 16-268 at 2282 – 2288. 23 Case 18-2868, Document 280, 08/09/2019, 2628232, Page32 of 74 This disturbing 2005 purchase corroborate Ms. Giuffre’s account of being sexually exploited by Defendant and Epstein – not to mention the dozens of underage girls in the Palm Beach Police Report. Additionally, Defendant testified that she was not with Jeffrey Epstein in 2005 and 2006 when he was ordering books on how to use sex slaves; however, record evidence contradicts that testimony. 9. Thailand Folder with Defendant’s Phone Number Defendant also was integral in arranging to have Virginia go to Thailand. While Epstein had paid for a massage therapy session in Thailand, there was a catch. Defendant told Virginia she had to meet young girls in Thailand and bring her back to the U.S. for Epstein and Defendant. Indeed, on the travel records and tickets Defendant gave to Virginia, Defendant wrote on the back the name of the girl Virginia was supposed to meet, and she was also instructed to check in frequently with Defendant as it was further signified by the words “Call Ms. Maxwell (917) !” on Virginia’s travel documents. In this case, Virginia also produced the hard copy records from her hotel stay in Thailand paid for by Epstein. See McCawley Dec. at Exhibit 32, 43, GIUFFRE 003191-003192; GIUFFRE 007411-007432. 24 Case 18-2868, Document 280, 08/09/2019, 2628232, Page33 of 74 10. It is undisputed fact that the FBI report and the Churcher emails reference Ms. Giuffre’s accounts of sexual activity with Prince Andrew that she made in 2011, contrary to Defendant’s argument that Ms. Giuffre never made such claims until 2014. Based on the FBI’s Interview of Ms. Giuffre in 2011, they wrote a report reflecting Ms. Giuffre’s claims concerning her sexual encounters with Prince Andrew: 33 33 See McCawley Dec. at Exhibit 31, GIUFFRE001235-1246, FBI Redacted 302. 25 Case 18-2868, Document 280, 08/09/2019, 2628232, Page34 of 74 Additionally, 2011 correspondence with Sharon Churcher shows that Ms. Giuffre disclosed her sexual encounters with Prince Andrew, but Churcher had to check with the publisher’s lawyers “on how much can be published,” See McCawley Dec. at Exhibit 34, GIUFFRE003678. Accordingly, there is documentary evidence that refutes Defendant’s meritless argument that Ms. Giuffre did not allege she had sex with Prince Andrew until 2014. To the contrary, two sources, including the FBI, show Ms. Giuffre made these claims in 2011. C. Defendant Has Produced No Documents Whatsoever That Tend to Show That She Did Not Procure Underage Girls For Jeffrey Epstein. Defendant has produced no documents that even tend to show that she did not procure underage girls for sex with Epstein, and no documents that tend to show that she did not participate in the abuse. Indeed, Defendant refused to produce any documents dated prior to 2009, which includes the 2000-2002 period during which she abused Ms. Giuffre. Against this backdrop of an avalanche of evidence showing the Defendant sexually trafficked Ms. Giuffre, summary judgment on any of the issues advanced by Defen dant is inappropriate. While we discuss the particulars of the individual claims below, the larger picture is important too. Ms. Giuffre will prove at trial that Epstein and Defendant sexually trafficked her. And yet, when Ms. Giuffre had the courage to come forward and expose what Defendant had done to world – in a Court pleading trying to hold Epstein accountable – Defendant 26 Case 18-2868, Document 280, 08/09/2019, 2628232, Page35 of 74 responded by calling her a liar in a press release intended for worldwide publication. Such heinous conduct is not a mere “opinion,” but rather is defamation executed deliberately and with actual malice. The jury should hear all of the evidence and then render its verdict on Ms. Giuffre’s complaint. III. LEGAL STANDARD Rule 56 of the Federal Rules of Civil Procedure provides that a motion for summary judgment may be granted only when “there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” The Second Circuit has repeatedly held that “all ambiguities and inferences to be drawn from the underlying facts should be resolved in favor of the party opposing the motion, and all doubts as to the existence of a genuine issue for trial should be resolved against the moving party.” Swan Brewery Co. Ltd. v. U.S. Trust Co. of New York, 832 F. Supp. 714, 717 (S.D.N.Y. 1993) (Sweet, J.), citing Brady v. Town of Colchester, 863 F.2d 205, 210 (2d Cir. 1988) (internal quotations omitted). In other words, in deciding a motion for summary judgment, the court must construe the evidence in the light most favorable to the non-moving party and draw all reasonable inferences in the non-moving party’s favor. In re “Agent Orange” Prod. Liab. Litig., 517 F.3d 76, 87 (2d Cir. 2008). Stern v. Cosby, 645 F. Supp. 2d 258, 269 (S.D.N.Y.2009). Summary judgment should be denied “if the evidence is such that a reasonable jury could return a verdict” in favor of the non-moving party. See Net Jets Aviation, Inc. v. LHC Commc’ns, LLC, 537 F.3d 168, 178–79 (2d Cir. 2008). IV. LEGAL ARGUMENT A. Defendant is Liable for the Publication of the Defamatory Statement and Damages for Its Publication Defendant’s lead argument is that, when she issued a press release attacking Ms. Giuffre to members of the media, she somehow is not responsible when the media quickly published her 27 Case 18-2868, Document 280, 08/09/2019, 2628232, Page36 of 74 attacks. If accepted, this remarkable claim would eviscerate defamation law, as it would permit a defamer to send defamatory statements to the media and then stand back and watch – immune from liability – when (as in this case) the defamatory statements are published around the world. This absurd position is not the law, particularly given that the Defendant released a statement to media asking them to “[p]lease find attached a quotable statement on behalf of Ms. Maxwell.” To make her claim seem plausible, Defendant cites older cases, some dating back as far as 1906. This presents a distorted picture of the case law on these issues. As a leading authority on defamation explains with regard to liability for republication by another of statement by a defendant: “Two standards have evolved. The older one is that the person making the defamatory statement is liable for republication only if it occurs with his or her express or implied authorization of consent. The more modern formulation adds responsibility for all republication that can reasonably be anticipated or that is the ‘natural and probable consequence’ of the publication.” SACK ON DEFAMATION § 2.7.2 at 2-113 to 2-114 (4th ed. 2016). In this case, however, the nuances of the applicable legal standards make little difference because Defendant so clearly authorized – indeed, desired and did everything possible to obtain – publication of her defamatory statements attacking Ms. Giuffre. 1. Under New York Law, Defendant is liable for the media’s publication of her press release. Given the obvious purposes of defamation law, New York law unsurprisingly assigns liability to individuals for the media’s publication of press releases. Indeed, New York appellate courts have repeatedly held that an individual is liable for the media publishing that individual’s defamatory press release. See Levy v. Smith, 18 N.Y.S.3d 438, 439, 132 A.D.3sd 961, 962–63 (N.Y.A.D. 2 Dept. 2015) (“Generally, [o]ne who makes a defamatory statement is not responsible for its recommunication without his authority or request by another over whom he 28 Case 18-2868, Document 280, 08/09/2019, 2628232, Page37 of 74 has no control . . . Here, however . . . the appellant intended and authorized the republication of the allegedly defamatory content of the press releases in the news articles”); National Puerto Rican Day Parade, Inc. v. Casa Publications, Inc., 914 N.Y.S.2d 120, 123, 79 A.D.3d 592, 595 (N.Y.A.D. 1 Dept. 2010) (affirming the refusal to dismiss defamation counts against a defendant who “submitted an open letter that was published in [a] newspaper, and that [the defendant] paid to have the open letter published,” and finding that the defendant “authorized [the newspaper] to recommunicate his statements.”) See also RESTATEMENT (SECOND) OF TORTS § 576 (1977) (“The publication of a libel or slander is a legal cause of any special harm resulting from its repetition by a third person if . . . the repetition was authorized or intended by the original defamer, or . . . the repetition was reasonably to be expected.”)34 Defendant deliberately sent her defamatory statement to major news media publishers for worldwide circulation because Defendant wanted the public at large to believe that Ms. Giuffre was lying about her abuse. Defendant even hired a public relations media specialist to ensure the media would publish her statement. Her efforts succeeded: her public relations agent instructed dozens of media outlets to publish her “quotable” defamatory statement and they did. Despite this deliberate campaign to widely publicize her defamatory statement, Defendant now disclaims any responsibility for the media publishing her press release. If we understand Defendant’s position correctly, because she somehow lacked “control” over what major newspapers and other media finally put in their stories, she escapes liability for defamation. This nonsensical position would let a defamer send a false and defamatory letter to major media, and then, when they published the accusation, escape any liability. Such an 34 Cf., Eliah v. Ucatan Corp., 433 F. Supp. 309, 312–13 (W.D.N.Y. 1977) (“The alleged multistate publication of plaintiff’s photograph without her consent thus gives rise to a single cause of action. … However, evidence of the multistate publication of the magazine and the number of copies sold would be competent and pertinent to a showing of damages, if any, suffered by plaintiff.”) 29 Case 18-2868, Document 280, 08/09/2019, 2628232, Page38 of 74 argument is not only an affront to logic, but it is contrary to prevailing New York case law, cited above. Perhaps even more important, in the context of the pending summary judgment motion, it would require Defendant to convince the jury that she did not “authorize or intend” for the major media to publish her press release. Obviously the disputed facts on this point are legion, and summary judgment is accordingly inappropriate. Even the cases Defendant cites contradict her argument. She first cites Geraci v. Probst, in which a defendant sent a letter to the Board of Fire Commissioners, and, years later, a newspaper published the letter. The court held that the defendant was not liable for that belated publication, “made years later without his knowledge or participation.” Id., at 340. By contrast, Defendant not only authorized the defamatory statement, but paid money to her publicist to convince media outlets to publish it promptly – actions taken with both her knowledge and consent. Defendant’s statement was thus not published “without [her] authority or request,” as in Geraci, but by her express authority and by her express request. Defendant’s publicist’s testimony and the documents produced by Defendant’s publicist unambiguously establish that the media published her press release with Defendant’s authority and by her request: Q. When you sent that email were you acting pursuant to Ms. Maxwell’s retention of your services? A. Yes, I was *** Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know where the rest of this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine, I’ll go with this.” It is my understanding that this is the agreed statement because the subject of the second one is “Urgent, this is the statement” so I take that as an instruction to send it out, as a positive command: “This is the statement.”35 35 See McCawley Dec. at Exhibit 6, Ross Gow Dep. Tr. at 14:15-17; 44:6-45:13 (emphasis added). 30 Case 18-2868, Document 280, 08/09/2019, 2628232, Page39 of 74 Similarly, another case cited by Defendant, Davis v. Costa-Gavras, involved a libel claim against a book author who wrote an account of the 1972 military coup in Chile. Years later, the plaintiff attempted to ascribe defamation liability to a third-party publishing house’s decision to republish the book in paperback form and a third-party filmmaker who released a movie based on the book. The Court held that a “party who is ‘innocent of all complicity’ in the publication of a libel cannot be held accountable . . . [but that] a deliberate decision to republish or active participation in implementing the republication resurrects the liability.” 580 F. Supp. 1082, 1094 (S.D.N.Y. 1984). Here, Defendant made a deliberate decision to publish her press release, and actively participated in that process. At the very least, the jury must make a determination of whether Defendant was “innocent of all complicity” for a libelous statement contained in her press release. Finally, Defendant cites Karaduman v. Newsday, Inc., 416 N.E.2d 557 (1980), which held that reporters of a series of articles on narcotics trade “cannot be held personally liable for injuries arising from its subsequent republication in book form absent a showing that they approved or participated in some other manner in the activities of the third-party republisher.” Id., 416 N.E.2d at 559-560. Again, the jury could reasonably find that Defendant both approved of, and even participated in, the media’s publication of her press release. Indeed, it is hard to understand how any jury could find anything else. Defendant was obviously “active” in influencing the media to publish her defamatory press release, she both “approved” of and pushed for the publication of the press release. Accordingly, she is liable for its publication.36 36 On page 14 of her motion, Defendant makes wholly contradictory statements. In back-to-back sentences, she tells the Court that (1) she has no control over whether the media published the statement she sent to the media (with instructions to publish it by an influential publicist); (2) her public relations representative gave instructions to the media on how to publish it (in full); and (3) her public relations representative “made no effort to control” how the media would publish it. Indeed, the best evidence of Defendant’s control over the press is the fact dozens of media outlets obeyed her directive to publish her defamatory statement. 31 Case 18-2868, Document 280, 08/09/2019, 2628232, Page40 of 74 Therefore, disclaiming responsibility for the media’s publication of a statement (for which she hired a publicist for the purpose of influencing the media to publish that statement) is contrary to both prevailing case law, and the cases cited by Defendant. 2. Defendant is liable for the media’s publication of the defamatory statement. After arguing, contrary to New York law, that she is not liable for the media’s publication of her own press release, Defendant next argues that she is not liable for the media’s publications of the defamatory statement contained within her press release if the media chose to make even the tiniest of editorial changes. If we understand Defendant’s argument correctly, any omission of any language from a press release is somehow a “selective, partial” publication for which she escapes liability. Mot. at 14. Once again, this claim is absurd on its face. It would mean that a defamer could send to the media a long attack on a victim with one irrelevant sentence and, when the media quite predictably cut that sentence, escape liability for the attack. Moreover, even on its face, the claim presents a jury question of what changes would be, in context, viewed as “selective” or “partial” publications – something that only a jury could determine after hearing all of the evidence. In support of this meritless argument, Defendant cites Rand v. New York Times Co., for the proposition that a defendant cannot be liable for a publisher’s “editing and excerpting of her statement.” 430 N.Y.S.2d 271, 274, 75 A.D.2d 417, 422 (N.Y.A.D. 1980). This argument fails for several reasons. First, there is no “republication” by the media as a matter of law. Defendant issued a defamatory statement to the press, and its publication (as Defendant intended) is not a “republication” under the law, as discussed above. Second, there was no “editing” or paraphrasing or taking the quote out of context of the core defamatory statement in the press release: that Ms. Giuffre is a liar. The “obvious lies” passage is the heart of the message 32 Case 18-2868, Document 280, 08/09/2019, 2628232, Page41 of 74 Defendant sent to the press: that Ms. Giuffre was lying about her past sexual abuse. Even in isolation, Defendant’s quote stating that Ms. Giuffre’s claims are “obvious lies” does not distort or misrepresent the message Defendant intended to convey to the public that Ms. Giuffre was lying about her claims. As this Court explained in denying Defendant’s Motion to Dismiss, this case “involves statements that explicitly claim the sexual assault allegations are false.” Giuffre v. Maxwell, 165 F. Supp. 3d 147, 152 (S.D.N.Y. 2016). Furthermore, the facts at issue here make the Rand holding inapposite. In Rand, a newspaper paraphrased and “sanitized” defendant’s words. No such changing, sanitizing, or paraphrasing occurred in the instant case: the media quoted Defendant’s statement accurately. Further, the phrase at issue in Rand was that certain people “screwed” another person. The speaker/newspaper used the term “screwed” in reference to a record label’s dealings with a performing artist, and not did not mean “screwed” in the literal sense, but as “rhetorical hyperbole, and as such, is not to be taken literally.” Id. By contrast, there is no hyperbole in Defendant’s defamatory statement, and it was never distorted or paraphrased by any publication known to Ms. Giuffre. A jury could reasonable conclude that Defendant’s statement that Ms. Giuffre’s claims of child sexual abuse are “obvious lies” is not a rhetorical device, nor hyperbole, but a literal and particular affirmation that Ms. Giuffre lied. Accordingly, there is no support in the factual record that the media reporting that Defendant stated that Ms. Giuffre’s claims of childhood sexual abuse are “obvious lies” is a distortion of Defendant’s message or hyperbole. Even a cursory review of the press release would lead to that conclusion. Moreover, to the extent that there is any dispute that Defendant’s statement had a different meaning outside of the context of the remainder of the press release, 33 Case 18-2868, Document 280, 08/09/2019, 2628232, Page42 of 74 such a determination of meaning and interpretation is a question of fact for the jury to decide, and is inappropriate for a determination upon summary judgment. B. Material Issues of Fact Preclude Summary Judgment. 1. The Barden Declaration presents disputed issues of fact. The primary basis of Defendant’s motion for summary judgment is her attorney’s selfserving, post hoc affidavit wherein he sets forth his alleged “intent” with regard Defendant’s defamatory statement.37 Ms. Giuffre disputes Defendant’s attorney’s alleged and unproven “intent” (not to mention Defendant’s “intent”), not only because Defendant refuses to turn over her attorney’s communications, but also because questions of intent are questions of fact to be determined by a trier of fact. Furthermore, ample record evidence contradicts the claimed “intent.” a. The Barden Declaration is a deceptive back-door attempt to inject Barden’s advice without providing discovery of all attorney communications. In her brief, Defendant discloses her attorney’s alleged legal strategy and alleged legal advice; however, she deliberately states that her attorney “intended,” instead of her attorney “advised,” when discussing her attorney’s legal strategy and advice, using that phrase at least 37 times,38 and using phrases such as Barden’s “beliefs,”39 “purposes,”40 “goals,”41 and 37 The Barden declaration is problematic for other reasons as well. In addition to Defendant’s over-length, 68-page motion and among Defendant’s 654 pages of exhibits lies an eight-page attorney affidavit that proffers legal conclusions and arguments. This exhibit is yet another improper attempt to circumvent this Court’s rules on page limits. See Pacenza v. IBM Corp., 363 F. App'x 128, 130 (2d Cir. 2010) (affirming lower court decision to strike “documents submitted . . . in support of his summary judgment motion [that] included legal conclusions and arguments” because those “extraneous arguments constituted an attempt . . . to circumvent page-limit requirements submitted to the court.”); cf. HB v. Monroe Woodbury Cent. School Dist., 2012 WL 4477552, at *6 (S.D.N.Y. Sept. 27, 2012) (“The device of incorporating an affirmation into a brief by reference, as Plaintiffs have done here, in order to evade the twenty-five page limit, rather obviously defeats the purpose of the rule”). The court should disregard the Barden Declaration for that reason alone 38 MSJ at 7 (three times), 8 (three), 15 (four), 16, 25 (five), 26, 33, 35 (two), 36 (three); Statement of Facts at 6 (two), 7 (five); Decl. of Philip Barden at 4 (four), 5 (three). 39 MSJ at 25, 35; Statement of Facts at 7 (two); Decl. of Philip Barden at 3, 4 (three), 5 (two). 40 MSJ at 8, 25, 35; Statement of Facts at 7 (three); Decl. of Philip Barden at 4 (two), 5 (three). 34 Case 18-2868, Document 280, 08/09/2019, 2628232, Page43 of 74 “contemplations” 25 other times. All the while Defendant has claimed a privilege as to her communications with Barden. Defendant attempts to convince the Court that she only granted Gow permission to publish the defamatory statement as part of “Mr. Barden’s deliberated and carefully crafted” (MSJ at 16) legal strategy and advice. Yet, she still refused to turn over her communications with Barden under the auspices of attorney-client privilege.42 Such gamesmanship should not be permitted. If the Court were to consider the Barden Declaration (which it shouldn’t), it would be ruling on a less than complete record because, based on this Declaration, it is necessary that Defendant disclose all communications with him and possibly others. Ms. Giuffre doesn’t have those communications, the court doesn’t have those communications; therefore, Defendant is asking for summary judgment on an incomplete record. The Court should also not consider the Barden Declaration because it will be inadmissible as unduly prejudicial. It is a self-serving declaration by a non-deposed witness made without turning over the documents that are relevant to the declaration. See, e.g., Rubens v. Mason, 387 F.3d 183, 185 (2d Cir. 2004) (“We find that the District Court predicated its grant of summary judgment as to liability on an affidavit from the arbitrator who presided over the underlying arbitration, the probative value of which was substantially outweighed by the danger of unfair prejudice. The affidavit, therefore should not have been admitted. We therefore vacate the grant of summary judgment to the defendants on liability and remand to the District Court.”). b. Defendant’s summary judgment argument requires factual findings regarding Barden’s intent, thereby precluding summary judgment. Even were the Court to consider this Declaration and representations therein – which it should not – the declaration itself demonstrates that the Court would have to make factual 41 42 MSJ at 27. See McCawley Dec. at Exhibit 22, Defendant’s Privilege Log. 35 Case 18-2868, Document 280, 08/09/2019, 2628232, Page44 of 74 finding as to what Mr. Barden’s intent really was. Finding about intent are inappropriate at the summary judgment stage, as this Court and the Second Circuit have recognized. This Court has explained, “if it is necessary to resolve inferences regarding intent, summary judgment is not appropriate.” Id. (Sweet, J.) (emphasis added), citing Patrick v. Le Fevre, 745 F.2d 153, 159 (2d Cir. 1984); Friedman v. Meyers, 482 F.2d 435, 439 (2d Cir. 1973) (other citations omitted). c. There are factual disputes regarding Barden’s Declaration. Finally, there are material disputes over the statements in the Barden Declaration because they are directly refuted by record evidence. For example, the instant motion and the Barden Declaration describe the press release merely as a document expressing “his [Mr. Bardent’s] opinion – in the form of a legal argument –as a lawyer would be,” as opposed to a press release for dissemination by the media to the public. Record evidence refutes this claim, as (1) the press release was sent to journalists, not media publishers or in-house counsel; (2) the press release instructed the journalists to publish the defamatory statement (“Please find attached a quotable statement on behalf of Ms. Maxwell”); (3) it was issued by a publicist on Defendant’s behalf and not by an attorney, without any reference to attorneys or laws – indeed, Gow testified that Barden was unavailable to approve the statement; and (4) Gow testified that he issued the statement only after he understood Defendant to have “signed off” it, an understanding he formed based on Defendant’s “positive command” to him: “This is the agreed statement.” Q. When you sent that email were you acting pursuant to Ms. Maxwell’s retention of your services? A. Yes, I was. *** Q. When you say “agreed statement” can you tell me more about what you mean? Who agreed to the statement? A. I need to give you some context, if I may, about that statement. So, this is on New Year’s Day. I was in France so the email time here of 21:46, in French time was 22:46, and I was getting up early the next morning to drive my family back from the south of France to England, which is a 14-hour journey, door to door. So on the morning of the 2nd of January, 36 Case 18-2868, Document 280, 08/09/2019, 2628232, Page45 of 74 bearing in mind that Ms. Maxwell, I think was in New York then, she was five hours behind, so there was quite a lot of, sort of time difference between the various countries here, I sent her an email, I believe, saying - parsing this-- forwarding this email to her saying “How do you wish to proceed?” And then I was on the telephone-- I had two telephones in the car, I received in excess of 30 phone calls from various media outlets on the 2nd of January, all asking for information about how Ms. Maxwell was looking to respond to the latest court filings, which were filed on the 30th of December as I understand. And by close-- towards close of play on the 2nd, I received an email forwarded by Ms. Maxwell, containing a draft statement which my understanding was the majority of which had been drafted by Mr. Barden with a header along the lines of “This is the agreed statement.”· At close of play on the 2nd. So–I was–I had gone under the Channel Tunnel and I was sitting on the other side and that email, which my understanding was that it had been signed off by the client, effectively, was then sent out to a number of media, including Mr. Ball and various other UK newspapers. Q. Mr. Gow, when you say “end of play” and “close of play,” are you referring to sending the email that is Exhibit 2? A. Yes, I am *** Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know where the rest of this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine, I’ll go with this.” It is my understanding that this is the agreed statement because the subject of the second one is “Urgent, this is the statement” so I take that as an instruction to send it out, as a positive command: “This is the statement.”43 Accordingly, record evidence shows that the press release was intended as press release, and not as a “legal argument.” Record evidence also establishes that Defendant circulated the press release to Barden and Gow, and then gave a “positive command” to Gow to publish it. Additionally, there is no indicia that the press release is a legal opinion. To the contrary, it was issued by, and specifically attributed to, a woman who has personal knowledge of whether Ms. Giuffre’s claims of sexual abuse are true, and she states that Ms. Giuffre is a liar.44 At the very least, all of these factual issues must be considered by a jury. 43 See McCawley Dec. at Exhibit 6, Ross Gow Dep. Tr. at 14:15-17; 31:19-33:7; 44:6-45:13 (emphasis added). Unsurprisingly, Defendant cites no case law to support her argument that her attorney’s alleged influence in preparing the statement Defendant issued to the media somehow shields her from liability. 44 37 Case 18-2868, Document 280, 08/09/2019, 2628232, Page46 of 74 Another example is that Defendant states that “Gow served only as Mr. Barden’s conduit to the media” (MTD at 25), and “Mr. Barden was directing the January 2-15 statement to a discrete number of media representatives.” Barden wasn’t directing anything – he wasn’t even in the loop when Defendant decided to publish the statement - and the documents prove it. Indeed, the press release itself states that it is “on behalf of Ms. Maxwell,” not Barden, and it was Defendant who gave the “positive command” to Gow to publish it. These are just a couple of examples, among many, of the purported facts asserted in Defendant’s motion and Barden’s Declaration that are directly refuted by facts in the record. Finally, neither the media nor the general public could have known that the statement should be attributed to Barden. His name was nowhere in it, nor is there any reference to counsel. Defendant’s argument that the “context” is the media knowing Barden’s intent or involvement is unsupported by the record. The significant factual disputes about Barden, alone, prevent summary judgment. C. Defendant’s Defamatory Statement Was Not Opinion as a Matter of Law. As this Court previously held, correctly, Defendant stating that Ms. Giuffre’s claims of sexual assault are lies is not an expression of opinion: “First, statements that Giuffre’s claims ‘against [Defendant] are untrue,’ have been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning: that Giuffre is not telling the truth about her history of sexual abuse and Defendant’s role, and that some verifiable investigation has occurred and come to a definitive conclusion proving that fact. Second, these statements (as they themselves allege), are capable of being proven true or false, and therefore constitute actionable fact and not opinion. Third, in their full context, while Defendant’s statements have the effect of generally denying Plaintiff’s story, they also clearly constitute fact to the reader.” Giuffre v. Maxwell, 165 F. Supp. 3d 147, 152 (S.D.N.Y. 2016). This Court further explained: “Plaintiff cannot be making claims shown to be untrue that are obvious lies without being a liar. Furthermore, to suggest an individual is not telling the truth 38 Case 18-2868, Document 280, 08/09/2019, 2628232, Page47 of 74 about her history of having been sexually assaulted as a minor constitutes more than a general denial, it alleges something deeply disturbing about the character of an individual willing to be publicly dishonest about such a reprehensible crime. Defendant’s statements clearly imply that the denials are based on facts separate and contradictory to those that Plaintiff has alleged.” Id. Defendant argues that somehow the “context” of the entire statement “tested against the understanding of the average reader” should be the press release as a whole being read only by journalists. This is an unreasonable construct because the ultimate audience for a press release is the public. Indeed, the purpose of a press release is to reach readers. Unsurprisingly, Defendant cites no case that holds that journalists might somehow believe statements of fact are opinion while others do not. This Court has previously covered this ground when it clearly stated: Sexual assault of a minor is a clear-cut issue; either transgression occurred or it did not. Either Maxwell was involved or she was not. The issue is not a matter of opinion, and there cannot be differing understandings of the same facts that justify diametrically opposed opinion as to whether Defendant was involved in Plaintiff’s abuse as Plaintiff has claimed. Either Plaintiff is telling the truth about her story and Defendant’s involvement, or Defendant is telling the truth and she was not involved in the trafficking and ultimate abuse of Plaintiff. Giuffre v. Maxwell, 165 F. Supp.at 152 (S.D.N.Y. 2016). The same conclusion applies now. At the motion to dismiss stage, Defendant had not yet produced the statement she issued to the press. That statement is now in evidence, so there is no ambiguity as to what defendant released to the press. The absurdity of Defendant characterizing his statements calling Ms. Giuffre a liar as mere “opinion” is revealed by the fact that Defendant was the one who was sexually trafficking and otherwise abusing Ms. Giuffre. No reasonable person in any context would construe that as Defendant’s mere “opinion” on the subject, since Defendant knew she was abusing Ms. Giuffre. Indeed, this argument is contradicted by Defendant’s own deposition testimony: 39 Case 18-2868, Document 280, 08/09/2019, 2628232, Page48 of 74 Q. Do you believe Jeffrey Epstein sexually abused minors? A. I can only testify to what I know. I know that Virginia is a liar and I know what she testified is a lie. So I can only testify to what I know to be a falsehood and half those falsehoods are enormous and so I can only categorically deny everything she has said and that is the only thing I can talk about because I have no knowledge of anything else. See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. (April 17, 2016) at 174:6-19. Defendant slyly contends in her motion that “Mr. Barden’s “arguments” in the press release constitute ‘pure opinion,’” attempting to disclaim any involvement in making the defamatory statement. However, it is not Mr. Barden’s statement, nor his opinion, that it at issue here. At issue here is Defendant’s statement – a statement attributable to her, that she approved, whose publication she “command[ed],” and for which she hired a public relations representative to disseminate to at least 30 journalists for publication. While Mr. Barden could possibly have had his own opinion as to whether or not his client abused Ms. Giuffre, Defendant cannot express an opinion on a binary, yes/no subject where she knows the truth. As this Court previously articulated, “statements that Giuffre’s claims ‘against [defendant] are untrue,’ have been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning.” Giuffre v. Maxwell, 165 F. Supp. 3d at 152. Again, at the very least, the jury must pass on such issues. D. The Pre-Litigation Privilege Does Not Apply to Defendant’s Press Release 1. Defendant fails to make a showing that the pre-litigation privilege applies. Defendant’s next argument seeks refuge in the pre-litigation privilege. If we understand the argument correctly, Defendant seems to be saying that because she was contemplating an (unspecified and never-filed) lawsuit involving the British Press, she somehow had a “green light” to make whatever defamatory statements she wanted about Ms. Giuffre. To prove such a 40 Case 18-2868, Document 280, 08/09/2019, 2628232, Page49 of 74 remarkably claim, Defendant relies on caselaw involving such mundane topics as “cease and desist” letters sent to opposing parties and the like. Obviously such arguments have no application to the press release that Defendant sent out, worldwide, attacking Ms. Giuffre’s veracity. The problems with the Defendant’s argument are legion. For starters, there is no record evidence – not even Defendant’s own testimony – suggesting that she was contemplating litigation against Ms. Giuffre, or that her press release was related to contemplated litigation against Ms. Giuffre. Tellingly, the only “evidence” Defendant cites of any alleged contemplated litigation is the self-serving, post hoc, partial waiver of attorney-client privilege found in the Barden Declaration. As discussed above, that Declaration fails to establish that there was good faith anticipated litigation between her and Ms. Giuffre, particularly when evidence in the record contradicts such assertions. At the very least, it is a matter of fact for the jury to decide. In another case in which a defendant attempted to claim pre-litigation privilege applied to statements made to the press, this Court denied summary judgment, and held, “[t]o prevail on a qualified privilege defense [defendant] must show that his claim of privilege does not raise triable issues of fact that would defeat it.” Block v. First Blood Associates, 691 F. Supp. 685, 699-700 (Sweet, J.) (S.D.N.Y. 1988) (denying summary judgment on the pre-litigation qualified privilege affirmative defense because there was “a genuine issue as to malice and appropriate purpose”). Defendant’s claim here likewise fails. First, Defendant’s testimony makes no mention of any contemplated lawsuit – much less, any contemplated lawsuit against Ms. Giuffre. Second, Defendant has offered no witnesses who will testify that she intended to bring any law suit. Third, she did not, in fact, bring any such lawsuit. The only “evidence” is a post hoc Declaration written by her attorney. Finally, it must be 41 Case 18-2868, Document 280, 08/09/2019, 2628232, Page50 of 74 remembered, as explained at length above, the Defendant had sexually trafficking Defendant and was attempting to continue to conceal her criminal acts. Whether her statements had an “appropriate purpose,” Block 691 F. Supp. at 699-700 (Sweet, J.) – or were, rather, efforts by a criminal organization to silence its victims – is obviously contested. Accordingly, obvious issues of fact exist as to whether or not Defendant contemplated litigation. Distorting reality, Defendant further argues: “Statements pertinent to a good faith anticipated litigation made by attorneys (or their agents under their direction) before the commencement of litigation are privileged.” (MSJ at 33). The record evidence shows that Defendant’s attorney did not make the defamatory statement. Further, Defendant’s attorney’s agents did not make the defamatory statement. Defendant did. And, there was no statement made by anyone “before the commencement of litigation” because litigation never commenced. Accordingly, the cases Defendant cites where attorneys are making statements (or where clients are making statements to their attorneys regarding judicial proceedings including malpractice) are wholly inapposite as detailed below.45 45  Front v. Khalil, 24 N.Y.3d 713, 720 (2015) - statement made by attorney.  Flomenhaft v. Finkelstein, 127 A.D.3d 634, 637 n.2, 8 N.Y.S.3d 161 (N.Y. App. Div. 2015) - did not even address pre-litigation privilege, and said that Front, Inc. was not relevant to the case.  Kirk v. Heppt, 532 F. Supp. 2d 586, 593 (S.D.N.Y. 2008) - the communication at issue was made by an attorney’s client to the attorney’s malpractice carrier concerning the client’s justiciable controversy against the attorney over which the clients actually sued.  Petrus v Smith, 91 A.D.2d 1190 (N.Y.A.D.,1983) - the court held: “[r]emarks of attorney to Surrogate are cloaked with absolute immunity as statements made in course of judicial proceedings – Attorney’s gratuitous opinion outside courthouse calling plaintiff liar . . . is not similarly immune.” (This case undermines the false argument Defendant tries to make).  Klien - contrary to dicta quoted by Defendant from the Klein case, there were no communications made “between litigating parties or their attorneys,” just a press release Defendant instructed her press agent to disseminate to the media.  Frechtman v. Gutterman, 115 A.D.3d 102, 103, 979 N.Y.S.2d 58, 61 (2014) - the communication at issue was a letter sent by a client to his attorney terminating the representation for malpractice.  Sexter & Warmflash, P.C. v. Margrabe, 38 A.D.3d 163 (N.Y.A.D. 1 Dept. 2007) - privilege applied to letter client sent discharging law firm as the client’s attorneys as statements relating to a judicial proceeding and law firm sued for defamation. 42 Case 18-2868, Document 280, 08/09/2019, 2628232, Page51 of 74 Similarly, in Black v. Green Harbour Homeowners’ Ass’n, Inc., 19 A.D.3d 962, 963, 798 N.Y.S.2d 753, 754 (2005), cited by Defendant, the Court held a privilege applied to a letter sent by a home owner’s association board of directors to the association’s members informing them of the status of litigation to which the association was a party, and to the association’s letter to the state attorney general sent to discharge it’s duties to the association. In this case, litigation was actually pending, the communication was sent by a party to that litigation as part of its duties, and the communication itself concerned the litigation. Defendant’s press release fits none of those descriptions. Unsurprisingly, Defendant cites to no case in which a Court has held that this or any qualified privilege extends to internationally disseminated press releases defaming a non-party to the purported “anticipated” litigation. Regardless of whether or not Barden had a hand in drafting the statement (another disputed issue of fact for the jury), Defendant issued the statement, instructed that it be published, and the statement she issued was attributed to her, and not to her attorney (or his agents). Accordingly, all the case law Defendant cites about an attorney making a statement (or a client making a statement to their attorney or malpractice carrier) is inapposite. 2. Defendant is foreclosed from using the pre-litigation privilege because she acted with malice. In any event, because Defendant acted with malice, she cannot avail herself of the prelitigation privilege. As this Court has explained denying Defendant’s motion to dismiss, “‘There is no qualified privilege under New York law when such statements are spoken with malice, knowledge of their falsity, or reckless disregard for their truth.’” Giuffre v. Maxwell, 165 F. Supp. 3d at 155 (citing Block, 691 F. Supp. at 699 (Sweet, J.) (S.D.N.Y. 1988). There is ample record evidence that Defendant acted with malice in issuing the press release, thereby making the litigation privilege inapplicable. See Block, 691 F. Supp. at 700 (Sweet, J.) (“Here, sufficient 43 Case 18-2868, Document 280, 08/09/2019, 2628232, Page52 of 74 evidence has been adduced to support the inference that [defendant] acted with malice, and may not, therefore, claim a qualified privilege under New York law . . . a genuine issue as to malice and appropriate purpose has properly been raised and is sufficient to preclude summary judgment.”). For example, Ms. Sjoberg testified that Defendant recruited her for sex with Epstein, thus corroborating Ms. Giuffre’s own account of Defendant’s involvement in abusing her with Epstein. For another example, Jeffrey Epstein’s pilot testified that Defendant flew with Ms. Giuffre on at least 23 flights, thus corroborating Ms. Giuffre’s claims against Defendant. See McCawley Dec. at Exhibit 15, Rodgers Dep. Tr., at 34:3-10. For another example, Tony Figueroa testified that Defendant asked him for assistance in recruiting girls for Epstein – more testimony that corroborates Ms. Giuffre’s claims against Defendant. Defendant’s statements that Ms. Giuffre was lying and her claims of sexual abuse were “obvious lies” were not pertinent to a good faith anticipated litigation but, instead, they were made for an inappropriate purpose – i.e., to bully, harass, intimidate, and ultimately silence Ms. Giuffre. As the record evidence shows, Defendant knew the statements were false because Defendant engaged in and facilitated the sexual abuse of this minor child, therefore, they were made for the inappropriate purpose of “bullying,” “harassment,” and “intimidation.” See Front v. Khalil, 24 N.Y.3d 713, 720 (2015). Simply put, Defendant sexually trafficked Ms. Giuffre – and then tried to silence Ms. Giuffre to keep her crimes secret – circumstances that prevent her from using privileges designed to shield legitimate legal disputes from court interference. New York case law fully confirms that pre-litigation qualified privilege does not apply to this case. Historically, statements made in the course of litigation were entitled to privilege from defamations claims “so that those discharging a public function may speak freely to zealously represent their clients without fear of reprisal or financial hazard.” Id. at 718. A 2015 New York 44 Case 18-2868, Document 280, 08/09/2019, 2628232, Page53 of 74 Court of Appeals case somewhat extended this privilege by holding that statements made by attorneys prior to the commencement of the litigation are protected by a qualified privilege if those statements are pertinent to a good faith anticipated litigation. Id. at 718. (“Although it is well settled that statements made in the course of litigation are entitled to absolute privilege, the Court has not directly addressed whether statements made by an attorney on behalf of his or her client in connection with prospective litigation are privileged” . . . “to advance the goals of encouraging communication prior to the commencement of litigation” . . . “we hold that statements made prior to the commencement of an anticipated litigation are privileged, and that the privilege is lost where a defendant proves that the statements were not pertinent to a good faith anticipated litigation.”). The Court of Appeals’ reason for allowing this qualified privilege could not be more clear: “When litigation is anticipated, attorneys and parties should be free to communicate in order to reduce or avoid the need to actually commence litigation. Attorneys often send cease and desist letters to avoid litigation. Applying privilege to such preliminary communication encourages potential defendants to negotiate with potential plaintiffs in order to prevent costly and time consuming judicial intervention.” Id. at 719-20. Under this rationale, the Khalil court found that an attorney’s letters to the potential defendant were privileged because they were sent “in an attempt to avoid litigation by requesting, among other things, that Khalil return the alleged stolen proprietary information and cease and desist his use of that information.” Id. at 720. Here, quite unlike Khalil, the Defendant’s statements were (1) made by a non-attorney (Defendant through Gow); (2) concerning a non-party to any alleged anticipated litigation; (3) knowingly false statements; and (4) contained in a press release directed at, and disseminated to, 45 Case 18-2868, Document 280, 08/09/2019, 2628232, Page54 of 74 the public at large. Defendant’s statements cannot be considered “pertinent to a good faith anticipated litigation,” such that the qualified privilege should apply. Finally, though it strains credulity to even entertain the prospect, if Defendant could make even colorable showings on these basic issues, it would remain an issue of fact for the jury to determine whether or not Defendant’s press release, calling Ms. Giuffre’s sex abuse claims “obvious lies,” was any type of “cease-and-desist” statement or a statement that acted to “reduce or avoid” or resolve any “anticipated” litigation. Summary judgment is obviously inappropriate here as well. 3. Defendant cannot invoke the pre-litigation privilege because she has no “meritorious claim” for “good faith” litigation. Finally, Defendant cannot prevail in asserting this qualified privilege because, in order to invoke this privilege, she must have “meritorious claims” for “good faith anticipated litigation.” Khalil specifically states that for the qualified privilege to apply, the statements must be made “pertinent to a good faith anticipated litigation,” and it does not protect attorneys . . . asserting wholly unmeritorious claims, unsupported in law and fact, in violation of counsel’s ethical obligations.” Khalil, 24 N.Y.3d at 718, 720 (emphasis added). Defendant has neither “meritorious claims” nor “good faith anticipated litigation.” Defendant cannot have a “meritorious claim” for “good faith anticipated litigation” against the press (or Ms. Giuffre) because Ms. Giuffre’s reports of her sexual abuse are true, Defendant knows that they are true, and Defendant made a knowingly false statement when she called Ms. Giuffre a liar. Under these circumstances, Defendant has no “meritorious” claim to make in “good faith” relating to either Ms. Giuffre’s statements or their coverage in the press, thereby making her defamatory statements wholly outside the protection of this qualified privilege. At the very least, the issue of 46 Case 18-2868, Document 280, 08/09/2019, 2628232, Page55 of 74 whether Defendant has meritorious claims against the press on the grounds that she did not abuse Ms. Giuffre is a question of fact for the jury to decide. V. DEFENDANT HAS NOT - AND CANNOT - SHOW THAT HER DEFAMATORY STATEMENT IS SUBSTANTIALLY TRUE Defendant next claims that her press release calling Ms. Giuffre a liar about her past sex abuse was somehow “substantially true.” Here again, this is a highly disputed claim. On its face, to determine what is “substantially” true or not requires extensive fact finding, such as whether Defendant recruited Ms. Giuffre as a minor child for sex with Defendant’s live-in boyfriend and convicted pedophile, Jeffrey Epstein. Accordingly, summary judgment is not appropriate. See Mitre Sports Intern. Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 255 (S.D.N.Y.2014) (denying summary judgment because it would require the Court to decide disputed facts to determine whether the statement at issue was substantially true); Da Silva v. Time Inc., 908 F. Supp. 184, 187 (S.D.N.Y. 1995) (denying motion for summary judgment because there was a genuine issue of material act as to whether defamatory photo and caption were not true, stating “[i]n the instant case Da Silva’s contention that she was a reformed prostitute at the time of photography and publication provides a rational basis upon which a fact-finder could conclude that the photograph was not substantially true”). Additionally, Defendant has remarkably not submitted any evidence that she did not recruit Ms. Giuffre for sex with Epstein. Nor has Defendant offered any evidence that her role in Epstein’s household was not to recruit girls and young women for Jeffrey Epstein. Accordingly, summary judgment is inappropriate. See Stern v. Cosby, 645 F. Supp. 2d 258, 277 (S.D.N.Y. 2009) (because defendant had “not submitted any evidence to show that Statement 11 is substantially true, her motion for summary judgment as to Statement 11 is denied”). 47 Case 18-2868, Document 280, 08/09/2019, 2628232, Page56 of 74 Further, much of the purported evidence upon which Defendant relies to allege the truth of her defamatory statement is merely hearsay, including inadmissible hearsay statements made by Alan Dershowitz, who Defendant did not depose in this case (and whom Ms. Giuffre has not had an opportunity to cross examine). Hearsay cannot establish the truth of a defamatory statement as a matter of law at summary judgment. Lopez v. Univision Communications, Inc., 45 F. Supp.2d 348, 359 (S.D.N.Y.1999) (denying summary judgment and holding “defendants’ evidence as to what they were told by representatives of NYU and Kean College, to the extent offered for the truth of the matters asserted, is inadmissible hearsay and an insufficient basis upon which to grant summary judgment of dismissal on the ground that the statements were substantially true.”). Finally, many of the facts upon which Defendant bases her argument that her defamatory statement was true are wholly tangential to the claims against her by Ms. Giuffre and the defamatory statement. For example, Defendant supports her contention that she did not recruit Ms. Giuffre for sex with Epstein based on the fact that Ms. Giuffre lived independently of her parents before meeting Epstein and Ms. Maxwell. (Of course, a child outside the supervision of her parents makes it much more likely she would be recruited by Defendant into sex trafficking, but that is for the jury to decide.) That fact does not go to whether or not Defendant’s statement calling Ms. Giuffre a liar is true, because Ms. Giuffre never made any claims relating to where she lived prior to meeting Defendant. Moreover, it is immaterial with whom she was living: the fundamental and overarching fact remains that Defendant recruited Ms. Giuffre for sex with Epstein when she was a minor child. Defendant next proffers Ms. Giuffre’s limited high school enrollment and short-term jobs that she held as evidence that she and Epstein did not abuse her. The logic of this position is 48 Case 18-2868, Document 280, 08/09/2019, 2628232, Page57 of 74 unclear. The fact that Ms. Giuffre worked at Taco Bell for a few days hardly establishes she was not abused by Defendant and Epstein. Indeed, if anything its shows the vulnerability of Ms. Giuffre to enticements that a billionaire and his wealthy and powerful girlfriend could offer. In any event, what to make of such fact is something for the jury to consider. They are irrelevant for the same reason as above: Ms. Giuffre never made any claims about her studies or her prior employment. Indeed, neither Ms. Giuffre’s statement about being recruited by Defendant as a child, nor Defendant’s refutation even mentions Ms. Giuffre’s lack of schooling or lack of a stable home as a child. Purported facts that have nothing to do with Ms. Giuffre’s claims of sexual abuse against Defendant, and nothing to do with Defendant calling Ms. Giuffre a liar for such claims, do not establish the “substantial truth” of Defendant’s statement. Tellingly, Defendant cites to no analogous case in any jurisdiction that even suggests otherwise. VI. PLAINTIFF DOES NOT NEED TO ESTABLISH MALICE FOR HER DEFAMATION CLAIM, BUT IN THE EVENT THE COURT RULES OTHERWISE, THERE IS MORE THAN SUFFICIENT RECORD EVIDENCE FOR A REASONABLE JURY TO DETERMINE DEFENDANT ACTED WITH ACTUAL MALICE Defendant’s next (and, again, quite remarkable) argument is that Ms. Giuffre somehow will be unable to establish actual malice in this case. One would think that a sex trafficker calling one of her victims a liar would be a quintessential example of actual malice. Defendant’s spurious case citations and misplaced argument do not detract from this core fact. Though Defendant does not mention the legal standard for actual malice until she is 48 pages into her 68-page brief,46 the legal definition of actual malice, as defined by the United 46 Though perhaps a scrivener’s error, Defendant errantly cites to two Supreme Court cases – Gerts v. Robert Welch, Inc., 418 U.S. 323 (1974) and Philadelphia Newspapers, Inc. v. Hepps, 475 U.S. 767 (1986) – that arose out of the laws of Illinois and Pennsylvania, respectively, to support a proposition concerning New York law. Defendant also cites to Harte-Hanks Commc'ns, Inc. v. Connaughton, 491 U.S. 657, 109 S. Ct. 2678, 105 L. Ed. 2d 562 (1989), wherein the ruling was not at summary judgment, and the plaintiff in the defamation case was a judicial candidate in a public election. 49 Case 18-2868, Document 280, 08/09/2019, 2628232, Page58 of 74 States Supreme Court, and reiterated by the Second Circuit, should be the light by which all of Defendant’s purported “facts” and argument should be viewed. “Actual malice” means that the statement was published with “knowledge that the statement was ‘false or with reckless disregard of whether it was false or not.’” Baiul v. Disson, 607 F. App'x 18, 20 (2d Cir. 2015), quoting New York Times Co. v. Sullivan, 376 U.S. 254, 280, 84 S. Ct. 710, 11 L.Ed.2d 686 (1964). Defendant argues that Ms. Giuffre is a limited purpose public figure. While Ms. Giuffre disputes that claim, the issue is entirely irrelevant here because Ms. Giuffre will prove at trial, with overwhelming evidence, that Defendant made her statement calling Ms. Giuffre a liar with malice, fully knowing – as a sex trafficker – that it was false. Put another way, Defendant knew that Ms. Giuffre was telling the truth when she described how Defendant recruited her for sex as an underage girl and then sexually trafficked her with her boyfriend Jeffrey Epstein. The Second Circuit instructs that, “[o]n a motion for summary judgment, a court cannot try issues of fact; it can only determine whether there are issues to be tried. If, as to the issue on which summary judgment is sought, there is any evidence in the record from any source from which a reasonable inference could be drawn in favor of the nonmoving party, summary judgment is improper.” Chambers v. TRM Copy Ctrs. Corp., 43 F.3d 29, 37 (2d Cir. 1994) (internal citations and quotations omitted). “As the moving party, Defendants have the burden of demonstrating an absence of clear and convincing evidence substantiating Plaintiffs’ claims.” De Sole v. Knoedler Gallery, LLC, 139 F. Supp. 3d 618, 640 (S.D.N.Y. 2015) (citing Chambers). Defendant fails to meet her burden of demonstrating an absence of clear and convincing evidence substantiating Ms. Giuffre’s claims that Defendant acted with actual malice. Ms. Giuffre will easily be able to meet any trial burden of clear and convincing evidence of actual 50 Case 18-2868, Document 280, 08/09/2019, 2628232, Page59 of 74 malice. Tellingly, Defendant does not even attempt to address the documentary evidence, nor the testimonial evidence showing she was a recruiter of girls for Epstein. As shown above, far beyond showing that a reasonable inference could be drawn in her favor, which is all that is required at this point to defeat Defendant’s motion, Ms. Giuffre will easily be able to meet her trial burden of clear and convincing evidence of actual malice. Of course, a plaintiff need only show “actual malice” on the part of a defendant if that plaintiff is a public figure or a limited public figure, which Ms. Giuffre is not, as explained infra. VII. THE COURT NEED NOT REACH THE ISSUE, AT THIS TIME, OF WHETHER MS. GIUFFRE IS A LIMITED PURPOSE PUBLIC FIGURE For the reasons just explained, Ms. Giuffre will easily be able to prove actual malice at the trial in this case. Defendant argues that Ms. Giuffre “is a public figure who must prove actual malice.” MSJ at 49. Given the overwhelming proof of the second part of that statement, the Court need not spend its time considering the first. If the Court wishes to nonetheless consider the issue at this time, it is not appropriate for disposition at the summary judgment stage of this case. The defendant bears the burden of demonstrating that the plaintiff is a limited purpose public figure. See Lerman v. Flynt Distrib. Co., 745 F.2d 123, 136–37 (2d Cir. 1984). Defendant correctly articulates the legal test for a finding that a plaintiff is a limited purpose public figure, but glosses over the fact that all prongs of the test must be met in order for a court to make that finding. See, e.g., Contemporary Mission, Inc. v. N.Y. Times Co., 842 F.2d 612, 617 (2d Cir. 1988) (“[T]his court set forth a four part test for determining whether someone is a limited purpose public figure” (emphasis added)); Herbert v. Lando, 596 F. Supp. 1178, 1186 (S.D.N.Y. 1984) (“The Second Circuit recently summarized the criteria” (emphasis added)), aff’d in part, rev’d in part, 781 F.2d 298 (2d Cir. 1986); cf. Nehls v. Hillsdale Coll., 178 F. Supp. 2d 771, 778 (E.D. Mich. 2001) (finding plaintiff 51 Case 18-2868, Document 280, 08/09/2019, 2628232, Page60 of 74 was not a limited public figure for failing one element of the Lerman test and thus denying defendant’s motion for summary judgment) (“The defendant has proven all of the elements but the third …”), aff’d, 65 F. App’x 984 (6th Cir. 2003). Of course, proof that Ms. Giuffre (or anyone else) is a limited purpose public figure requires proof of a set of facts from which Ms. Giuffre believes Defendant has not shown in satisfaction of the four-part test. Significantly –this Court should pause here to note that the details of Jane Doe 3’s sexual exploitation and abuse, as anonymously set forth in her CVRA joinder motion, caused the Defendant to identify, with certainty, Jane Doe 3 as Ms. Giuffre. Yet, at her deposition, Defendant claimed to “barely remember her at all.”47 Defendant’s ability to immediately and positively identify the anonymous individual making claims of sexual abuse, if anything, shows that Defendant was intimately aware of Ms. Giuffre’s sexual exploitation. And, to be sure, Ms. Giuffre never asked to be sexually abused or trafficked by Defendant or convicted pedophile Jeffrey Epstein when she was a child – legally, she did not even have the capacity to consent. Defendant cannot recruit a minor child for sexual exploitation and then, afterwards, argue that her victim injected herself into the public controversy when coming forward about the abuse she suffered. Moreover, Defendant has not made a sufficient showing that Ms. Giuffre has “regular” and “continuing” access to the news media. The policy rationale behind this prong is that public figures generally enjoy significant access to the media. One reporter wrote some articles on Ms. Giuffre in 2011. Thereafter, it was not until 2015, that Ms. Giuffre spoke to someone in the news media about these issues, and that interview was granted after Defendant’s defamatory remarks. Such limited contacts precludes a finding that Ms. Giuffre is a limited public figure. See 47 See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 44:23-45:4 (July 22, 2016) (“Q. You do remember Virginia, about that time back in the 2000s, giving Mr. Epstein massages? A. I barely remember her at all.”). 52 Case 18-2868, Document 280, 08/09/2019, 2628232, Page61 of 74 Hutchinson v. Proxmire, 443 U.S. 111, 99 S. Ct. 2675, 61 L.Ed.2d 411 (1979) (finding plaintiff maintained no regular and continuing access to the media and thus was not a public figure). It is also unclear how Defendant plans to show that Ms. Giuffre “successfully invited public attention to her views.” To be sure, Ms. Giuffre decided to start “Victims Refuse Silence,” a not-for-profit organization whose mission is “to change the landscape of the war on sexual abuse and human trafficking. Our goal is to undertake an instrumental role in helping survivors break the silence associated with sexual abuse. To fulfill this mission, we aim to enhance the lives of women who have been victimized.”48 The website lists the National Trafficking Hotline, and provides a state-by-state resources for local organizations where victims can seek help. Unsurprisingly, Defendant cites no cases that hold that maintaining a website makes one a public figure. See Mitre Sports Int’l Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 252 (S.D.N.Y. 2014) (finding plaintiff was not a limited public figure and denying defendant’s motion for summary judgment) (“corporate policy denouncing child labor on its website … do[es] not show that Mitre … aimed to influence the public’s views on the controversy”). More important, Defendant does not explain how Ms. Giuffre was using the website to influence public views on whether she had been abused by Defendant – the subject at issue in this lawsuit. Interestingly, Defendant has spent $ 17,87549 on an expert witness to tell the Court and the jury that hardly anyone searches on the internet using search terms such as “victims refuse silence sex slave.” One of Defendant’s six briefs raising Daubert issues specifically argues that Dr. Anderson’s estimates on the cost of remediating Ms. Giuffre’s online reputation are improper because Dr. Anderson included nearly unused search phrases when evaluating internet content. Kent’s rebuttal report states: “. . . there seems no reason to believe that such a person would use 48 49 http://www.victimsrefusesilence.org/our-mission. See McCawley Dec. at Exhibit 9, Kent Dep. Tr. at 25:16-26:6. 53 Case 18-2868, Document 280, 08/09/2019, 2628232, Page62 of 74 this term . . . Indeed, these are terms unlikely to be used by anyone unfamiliar with this litigation. . . . Why, for instance, would it be necessary to push down offending Web pages in the results that the search engines provide for the term victim’s refuse silence sex slave, when this term is likely never used . . .” See McCawley Dec. at Exhibit 25, Kent Report at 10, 33. Defendant cannot argue to the Court that Ms. Giuffre has “successfully” invited public attention to her views through her VRS website while simultaneously filing a Daubert motion that argues that search terms such as “victims refuse silence sex slave” are “likely never used,” thus making the website unsuccessful in inviting public attention. In any event, Defendant has failed to set forth with precision the allegedly undisputed fact – and supporting evidence – she uses to support her argument. Moreover, “[i]t is preferable to reduce the public figure question to a more meaningful context by looking to the nature and extent of an individual’s participation in the particular controversy giving rise to the defamation.” Greenberg v. CBS Inc., 69 A.D.2d 693, 704, 419 N.Y.S.2d 988, 995 (1979) (emphasis added), citing Gertz v. Robert Welch, Inc., 418 U.S. 323, 345, 352, 94 S. Ct. 2997, 41 L.Ed.2d 789. The context here is highly significant. Ms. Giuffre never chose to participate in Defendant and Epstein’s underage sex ring, a “controversy” that gave rise to Defendant’s defamation. In arguing that Ms. Giuffre thrust herself into the public spotlight, Defendant conveniently leaves out the fact that it is by her doing that Ms. Giuffre is in this controversy in the first place. No minor child willingly becomes a participant in sexual abuse, and it is perverse for the abuser to argue that her victim deliberately became a subject of public attention when speaking out about that abuse for the purpose of advancing justice and helping other victims. 54 Case 18-2868, Document 280, 08/09/2019, 2628232, Page63 of 74 For all these reasons, the Court should simply decline to decide the public figure issue at this juncture. But if it chooses to reach the issue, it should reject Defendant’s unsupported argument. VIII. THE JANUARY 2015 STATEMENT WAS NOT “SUBSTANTIALLY TRUE,” AND MS. GIUFFRE HAS PRODUCED CLEAR AND CONVINCING EVIDENCE OF ITS FALSITY As a final argument, Defendant argues that her January 2015 statement was “substantially true.” Given that the statement argues that Ms. Giuffre lied when she said she was sexually trafficked by Defendant, the reader of Defendant’s motion might reasonably expect to see some evidence presented showing that Defendant was not a sex trafficker. Instead, the reader is treated to technical quibbles. For example, the lead argument to show the “substantial” truth of Defendant’s statement is the argument that Ms. Giuffre was not fifteen years old, but all of sixteen or seventeen years old when she was trafficked. As the Court knows (and can take judicial notice of), Florida law makes age eighteen the age of consent. Accordingly, it is no moment that Ms. Giuffre may have been mistaken about the exact year the sex trafficking started. Call this the “yes-I’m-a-sex-trafficker-but-only-of-sixteen-year-old-girls” defense. To even describe the defense is to show how meritless it is. More broadly, at issue are the statements Ms. Giuffre made regarding Defendant’s involvement in, and knowledge of, the sexual abuse and sex trafficking of Ms. Giuffre (and other minor girls) through a recruitment scheme executed by Defendant and Jeffrey Epstein. In response to those various statements, Defendant publicly claimed that, “the allegations made by (Ms. Giuffre) against Ghislaine Maxwell are untrue.” Defendant continued that Ms. Giuffre’s “claims are obvious lies and should be treated as such....” Defendant, through her statement 55 Case 18-2868, Document 280, 08/09/2019, 2628232, Page64 of 74 intended to convey that Ms. Giuffre was lying about everything she had said against Defendant – “the allegations.” In sum and essence, those statements made by Ms. Giuffre about which Defendant released a public statement to exclaim were “untrue” and “obvious lies” were: (1) That Defendant approached Ms. Giuffre while Ms. Giuffre was an underage minor working at the Mar-a-Lago Country Club, and recruited the then-minor Ms. Giuffre to go to the house of Jeffrey Epstein under the pretense of providing a massage to Jeffrey Epstein for money; (2) That Ms. Giuffre followed Defendant’s instructions, and was driven to Jeffrey Epstein’s house, where she was greeted by Defendant and later introduced to Jeffrey Epstein; (3) That Ms. Giuffre was lead upstairs to be introduced to Jeffrey Epstein in his bedroom, and that while there Defendant demonstrated how Ms. Giuffre should provide a massage to Jeffrey Epstein; (4) That Defendant and Epstein converted the massage into a sexual experience, requesting that Ms. Giuffre remove her clothing, after which time a sexual encounter was had; That Defendant and Epstein expressed approval for Ms. Giuffre, and offered her money in exchange for this erotic massage turned full sexual encounter; (5) (6) That Defendant and Epstein offered Ms. Giuffre the promise of money and a better life in exchange for Ms. Giuffre acting sexually compliant and subservient to their demands; (7) That Ms. Giuffre, after that first encounter, was repeatedly requested to service Epstein and/or Defendant sexually and/or others; (8) That Ms. Giuffre was taken on Epstein’s private planes on numerous occasions and trafficked nationally and internationally for the purpose of servicing Epstein and others, including Defendant, sexually; That Defendant was Epstein’s primary manager of the recruitment and training of females who Epstein paid for sexual purposes; (9) (10) That Defendant participated in sexual encounters with females, including Ms. Giuffre; and (11) That Ms. Giuffre and other recruited females were encouraged by Defendant and Epstein to bring other young females to Epstein for the purpose of servicing him sexually. 56 Case 18-2868, Document 280, 08/09/2019, 2628232, Page65 of 74 Defendant, by way of her January 2015 statement, declared that Ms. Giuffre lied about each and every one of these allegations regarding Defendant. In fact, Defendant clarified further this position in her deposition when she said repeatedly that everything Ms. Giuffre said about Defendant was totally false.50 The clarification in her deposition is identical in intention to the reasonable interpretation of her statement that Defendant made publicly, which has formed the basis of this defamation action—that Ms. Giuffre was lying about everything she said about Defendant, and that Defendant was not at all involved in the activity she was accused of engaging in. While her public statement could not have been more clear, as her deposition testimony further underscored, Defendant intended the world to believe that nothing Ms. Giuffre said about Defendant was true, and that Defendant was not at all involved with any of the things she was accused of, Defendant has decided in this motion to minutely dissect the nuance of Ms. Giuffre’s various statements to cause the Court to reach a far-fetched conclusion that Defendant’s insidiously false statement was somehow “substantially true.” Ironically, this repositioning amounts to nothing more than an admission by Defendant of the defamatory nature of her statement. A. When Ms. Giuffre Initially Described Her Encounters With Defendant and Epstein, She Mistakenly Believed the First Encounter Occurred During the Year 1999. Discovery has resulted in the production of records, including Ms. Giuffre’s employment records from Mar-a-Lago, which she did not possess at the time she was recounting her interactions with Defendant. Those records establish that the initial encounter wherein Defendant recruited Ms. Giuffre occurred during the year 2000 and not during 1999. Ms. Giuffre was 50 See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 135:3-4; 178:15-178:24; 179:20-180:7; 228:7229:10. 57 Case 18-2868, Document 280, 08/09/2019, 2628232, Page66 of 74 sixteen years old before August 9, 2000, and turned seventeen on that date. It is unclear from the limited records available whether Defendant approached and recruited Ms. Giuffre before or just after Ms. Giuffre’s 17th birthday. However, what has now been established through numerous witnesses is that Defendant approached and recruited a minor child for the purposes of enticing that minor over to the house of Jeffrey Epstein, a currently-registered sex offender.51 The exact lure of Ms. Giuffre by Defendant - enticement of being paid money to give a billionaire a massage at his mansion - was used by Epstein and his many associates and employees to recruit dozens and dozens of other underage girls. There is no doubt that the crux of Ms. Giuffre’s statement on this point is that Defendant recruited her when she was only a minor child unable to consent to sex, not precisely how far under the age of consent she was. Defendant’s public claim that Ms. Giuffre’s account of this approach, and recruiting element, was “untrue” and “obvious lies” is not “substantially true,” but is itself an obvious lie – as Ms. Giuffre will prove to the jury at trial. B. Defendant’s January 2015 Statement Claiming as “Untrue” and an “Obvious Lie” the Allegation That She Regularly Participated in Epstein’s Sexual Exploitation of Minors and That the Government Knows Such Fact is Not Substantially True But Instead Completely False. Defendant next argues that she “accurately denied that [she] ‘regularly participate[d] in Epstein’s sexual exploitation on minors’ and that ‘the Government knows such fact.’” MSJ at 58. It is not clear whether Defendant is nitpicking this statement by contesting whether she “regularly” participated in Epstein’s sexual exploitation or whether she did participate, but the Government was unaware of the extent of her involvement. Call this the “yes-I’m-a-sextrafficker-but-only-on-Tuesdays-and-Thursdays” defense – here again, to simply recount the claim is to see its absurdity. 51 See McCawley Dec. at Exhibit 1, 5, Alessi Dep. Tr. at 94:24-95:2; Giuffre Dep. Tr. at 111:12-111:21; 116:19117:12. 58 Case 18-2868, Document 280, 08/09/2019, 2628232, Page67 of 74 Contrary to Defendant’s misleading, cherry-picked fragments of information she has chosen to use to support her point, there is an abundance of evidence clearly linking Defendant to Epstein’s sexual exploitation of minors. As the Court is aware, numerous message pads were recovered from Epstein’s home indicating Defendant’s involvement in and knowledge of Epstein’s illegal exploitation. 52 Additionally, numerous employees and others have testified about Defendant’s high-ranking position in the hierarchal structure of the sexual exploitation scheme. 53 In fact, multiple individuals, in addition to the Ms. Giuffre, have testified about Maxwell’s involvement in the exploitation of minors, including Ms. Giuffre.54 Defendant also argues that one government investigator, Palm Beach, Florida, Detective Recarey, may not have been aware of her involvement in the sex trafficking. Defendant fails to cite another passage in Detective Recarey’s deposition, where he noted that he was aware of Defendant’s involvement with Epstein and the sexual exploitation of children.55 But even assuming Recarey was unaware (which Ms. Giuffre strongly disputes), Defendant would have, at most, a “yes-I’m-a-sex-trafficker-but-I-successfully-hid-it-from-one-of-the-cops” defense – again, not a likely claim. More broadly, Ms. Giuffre’s statement about what the “Government” knew about sex trafficking was made in pleadings filed in a federal Court case attacking the decision of the U.S. Attorney’s Office for the Southern District of Florida to offer Jeffrey Epstein immunity from prosecution for federal sex trafficking crimes. Accordingly, to present an even arguable claim for summary judgment, Defendant would have to show that the U.S. Attorney’s Office (and its 52 See, e.g., McCawley Dec at Exhibit 28 (message pad excerpts), GIUFFRE 001412, 001418, 001435, 001446, 001449, 001453, 001454. 53 See McCawley Dec. at Exhibit 21, 1, Rodriguez Dep. Tr. at 169:1-169:4; Alessi Dep. Tr. at 23:11-23:20; 34:1935:3; 98:5-98:12; 104:15-104:23. 54 See McCawley Dec. at Exhibit 16, 4, Sjoberg Dep. Tr. at 13; Figueroa Dep. Tr. at 96-97; 103; 200:6-18; 228:23229:21. 55 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 29:16-29:20; 45:13-25; 83:3-83:15. 59 Case 18-2868, Document 280, 08/09/2019, 2628232, Page68 of 74 investigators from the FBI) did not know about Defendant’s sex trafficking. This proof would need to include, for example, evidence that the FBI did not learn about Defendant’s sex trafficking when (among other things) Ms. Giuffre told FBI agents about it when she met with them in Australia in 2011. Here again, Defendant has no evidence to even begin making such a showing. C. Defendant’s January 2015 Statement Claiming as “Untrue” or an “Obvious Lie” That Maxwell and Epstein Converted Ms. Giuffre Into a Sexual Slave is Not Substantially True. Defendant next argues that she accurately disputed Ms. Giuffre’s statement that Defendant held her as a “sex slave.” Relying on dictionary definitions of “slave” that define the term to refer to a “confined” person who is the “legal property” of another (MSJ at 59, citing Merriam-Webster, etc.), Defendant claims Ms. Giuffre was not confined or the property of Defendant. Call this the “yes-I’m-a-sex-trafficker-but-I-didn’t-use-chains” defense. And, once again, to even describe the defense is to refute it. Defendant does not explain why the jury would be required to use the held-in-chains definition of “slave” in evaluating her statement. Merriam-Webster (11th ed. 2006) also defines “slave” as “one that is completely subservient to a dominating influence” – a definition that fits Ms. Giuffre’s circumstances to a tee. As Ms. Giuffre has explained in detail, she was recruited as a minor child by Defendant, who then dominated her and used for sexual purposes. That testimony alone creates a genuine issue of fact on this point. From the context of all of Ms. Giuffre’s statements about Defendant, Ms. Giuffre has never said or implied that she was physically placed in a cage. Instead, she has described the vast disparity of power and the influence of Defendant and Epstein, the fear of disobedience, the typical locations of the abuse being in a private plane, in huge mansion manned with Epstein employed servants, a private island, or some inescapable place abroad in the presence of 60 Case 18-2868, Document 280, 08/09/2019, 2628232, Page69 of 74 Defendant, in addition to the continued – and fraudulent – promise of a better future, as those things that kept her retained in a situation of sexual servitude. While not physical chained, Ms. Giuffre was groomed as minor and trained, and these factors became her invisible chains. Indeed, as Ms. Giuffre’s expert on sex trafficking, Professor Coonan, has explained: Popular understandings of the term “sex slave” might still connote images of violent pimps, white slavery, or of victims chained to a bed in a brothel in the minds of some people. To call Ms. Giuffre a victim of sex trafficking would however very accurately convey the reality that she along with a great many other victims of contemporary forms of slavery are often exploited by the “invisible chains” of fraud and psychological coercion. See McCawley Dec. at Exhibit 23, Coonan Expert Report at 20. If the Court takes as true, which it must for the purpose of this motion, that Ms. Giuffre was trafficked and used exclusively for sexual purposes by Defendant and Epstein, then the Court must also reach the conclusion at this stage that Maxwell’s assertion – that Ms. Giuffre’s description of being a sex slave is “untrue” or “obvious lies” – is not substantially true. There undoubtedly remains a genuine issue of material fact on this point, and in fact, Defendant’s position taken in this motion is tantamount to an admission of the truth of Plaintiff’s statement about Defendant on this point. D. Any Statement of Misdirection Regarding Professor Alan Dershowitz is Nothing More Than an Irrelevant Distraction to The Facts of This Case and Matters Not on the Defense of Whether Defendant’s Statement Was Substantially True. Defendant next contends that she accurately recounted that Alan Dershowitz had denied having sex with Ms. Giuffre. MSJ at 60. Call this the “yes-I’m-a-sex-trafficker-but-she-was-nottrafficked-to-the-professor” defense. While it is accurate that Ms. Giuffre made allegations against Professor Dershowitz, those allegations are not at issue in this case. Defendant, in her defamatory statement, claimed that “the allegations made by [Ms. Giuffre] against Ghislaine Maxwell are untrue.” See McCawley Dec. at Exhibit 26, GM_00068. In her deposition, 61 Case 18-2868, Document 280, 08/09/2019, 2628232, Page70 of 74 Defendant maintained the position that she “cannot speculate on what anybody else did or didn’t do.” See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 180:3-180:4. In fact, regarding Ms. Giuffre’s claims about others, Defendant unequivocally stated, “I can only testify to what she said about me, which was 1000 percent false.” See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 228:10-228:12. Defendant Maxwell makes additional misstatements about Dershowitz’s production in a defamation action filed against him in her desperate attempt to have Dershowitz to jump aboard and help bail out her sinking canoe. While Ms. Giuffre can – and, if necessary, will – refute Dershowitz’s claim he was not a beneficiary of Epstein and Defendant’s sex trafficking, that is not relevant at this stage. Whatever may or may not have happened with Dershowitz (and Ms. Giuffre’s sworn statements that he sexually abused her is alone enough to create disputed facts on the issue of whether Defendant’s statements about him were “substantially true”) has no bearing whatsoever on the truth or falsity of the statements Ms. Giuffre made about Defendant. This case is not about whether Ms. Giuffre has ever made untruthful allegations against anyone, which she contends she has not, but about whether her allegations about Defendant were true, or whether those specific allegations were “untrue,” “obvious lies” as Defendant publicly proclaimed. These issues are disputed and must go to the jury. E. Contrary to Defendant’s Position, There is a Genuine Issue of Material Fact as to Whether She Created or Distributed Child Pornography, or Whether the Government Was Aware of Same. Defendant next argues that she did not create child pornography and that the Government knew this. Call this the “until-you-find-the-photos-I’m-innocent” defense. Of course, as noted earlier, Defendant’s claim requires that she show that “the Government” – in context, the FBI and the U.S. Attorney’s Office for the Southern District of Florida – “knew” that she had no 62 Case 18-2868, Document 280, 08/09/2019, 2628232, Page71 of 74 child pornography. Yet Defendant has offered no such evidence – much less evidence so powerful as to warrant summary judgment on this point. This point is disputed from the simple fact that Ms. Giuffre herself testified that Defendant took many photograph of her naked. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 232:3-9; 233:7-9. This is consistent with the Palm Beach butler’s, Alfredo Rodriguez’s, testimony that he personally saw photos of naked children on Defendant’s computer. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 150:10-17; 306:1-306:24. Another housekeeper, Juan Alessi also saw photos of young nude females on Defendant’s computer, although he wasn’t sure whether to consider it pornography. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 175:5-175:24. Finally, Detective Recarey found a collage of nude photos of young females in Epstein’s closet, and turned the photos over to the FBI and U.S. Attorney’s office.56 While the U.S. Attorney’s office will not share the photos obtained from Recarey’s investigation, it is thus undisputed that the government possesses photos of nude, young females confiscated from Epstein’s Palm Beach mansion. Indeed, the police video disclosed through a FOIA request shows naked images of women throughout the house, including a full nude of the Defendant.57 At a minimum, there is a clear genuine issue of material fact in this regard. F. Defendant Did Act as a “Madame” For Epstein to Traffic Ms. Giuffre to The Rich and Famous. Defendant next argues that she did not act as a “Madame” for Epstein. MSJ at 63. The gist of the argument seems to be that Defendant believes trafficking one girl to Epstein does not a Madame make. Call this the “yes-I-was-Virginia’s-Madame-but-no-one-else’s” defense. This argument fails linguistically on the very dictionary definitions that Defendant cites elsewhere – 56 57 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 73:19-73:24; 74:2-74:7. See McCawley Dec. at Exhibit 44, FOIA CD GIUFFRE 007584. 63 Case 18-2868, Document 280, 08/09/2019, 2628232, Page72 of 74 but not here. See Merriam-Webster (11th ed. 2006) (defining “madam” as “the female head of a house of prostitution”). Once again, Defendant conceals the relevant facts on this issue. First, multiple witnesses have testified to Defendant’s recruiting, maintaining, harboring, and trafficking girls for Epstein.58 In fact, Defendant herself was unable to deny procuring Ms. Giuffre for Epstein.59 While Defendant has attempted to fumble her way through explaining some plausible reason for bringing a sixteen or seventeen year old to Epstein, her explanations are, to put it blandly, unpersuasive. As with other issues, the jury will have to decide who to believe. One of the individuals Ms. Giuffre was trafficked to was Prince Andrew – trafficking that took place in Defendant’s own townhouse in London. There exist flight logs evidencing Ms. Giuffre flying to London alongside Defendant and Epstein on Epstein’s private plane, and a photo of Ms. Giuffre, Defendant, and the Prince, without Defendant ever offering a legal reasonable explanation for that photo being taken, or for traveling with a year old girl overseas. Defendant begins to meander somewhat aimlessly on this point, shifting Plaintiff’s burden to substantiate Plaintiff’s claim that Defendant was Epstein’s Madame, which is a point at issue, into whether or not Plaintiff has conclusively proven the identities and accurate job titles of the other men to whom Plaintiff was lent for sex by Epstein. No matter how hard Defendant tries to reframe this case, drag other people in, or split hairs, she is unable to contest the facts – facts showing she was more than a Madame but a full-fledged sex trafficker. Ms. Giuffre told the truth when she said that Defendant recruited her as a minor, under the pretense of giving a 58 See McCawley Dec. at Exhibit 16, 1, 18, 2, Sjoberg Dep. Tr. at 13; Alessi Dep. Tr. at 34; GIUFFRE000105 at 5758; GIUFFRE000241-242 at p. 212-213; Austrich Dep. Tr. at 34-35, 100-101, 127-128; Alessi Dep. Tr. at 34:1935:3; 98:5-98:12; 104:15-104:23. 59 See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 214:14-215:3. 64 Case 18-2868, Document 280, 08/09/2019, 2628232, Page73 of 74 massage, and converted her into a traveling sex slave, consistent with Defendant and Epstein’s pattern and practice. As the Court astutely acknowledged early on, “at the center of this case is the veracity of a contextual world of facts more broad than the allegedly defamatory statements . . . either transgression occurred or it did not. Either Maxwell was involved or she was not.” If Defendant was involved, then her January 2015 statement was defamatory. Ms. Giuffre will prove to the jury, through overwhelming evidence, her prior allegations about Defendant’s involvement. The Court should give Ms. Giuffre that opportunity, and deny Defendant’s motion for summary judgment. IX. CONCLUSION For the foregoing reasons, this Court should deny Defendant’s motion for summary judgment in all respects. Dated: January 31, 2017 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 65 Case 18-2868, Document 280, 08/09/2019, 2628232, Page74 of 74 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-520260 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 31, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: lmenninger@hmflaw.com jpagliuca@hmflaw.com /s/ Sigrid S. McCawley Sigrid S. McCawley 60 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 66 Case 18-2868, Document 281, 08/09/2019, 2628234, Page1 of 66 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ SOUTHERN DISTRICT OF NEW YORK LOCAL RULE 56.1 PLAINTIFF’S STATEMENT OF CONTESTED FACTS AND PLAINTIFF’S UNDISPUTED FACTS DEFENDANT’S PURPORTED FACTS 1. Ms. Maxwell’s response to publications of Ms. Giuffre’s false allegations: the March 2011 statement. In early 2011 Ms. Giuffre in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. In the articles, Ms. Giuffre made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, Ms. Giuffre suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies that the allegations she made against Ms. Maxwell are false. Furthermore, Ms. Giuffre did give an interview to journalist, Sharon Churcher, in which Ms. Giuffre accurately and truthfully described Defendant Maxwell's role as someone who recruited or facilitated the recruitment of young females for Jeffrey Epstein. See McCawley Dec. at Exhibit 34, GIUFFRE003678. Ms. Giuffre was also interviewed by the FBI in 2011 and she discussed Defendant’s involvement in the sexual abuse. See McCawley Dec. at Exhibit 31, FBI Redacted 302, FIUFFRE001235-1246. Those statements were not "false and defamatory," but instead truthful and accurate. 1 Case 18-2868, Document 281, 08/09/2019, 2628234, Page2 of 66 DEFENDANT’S PURPORTED FACTS 2. In the articles, Ms. Giuffre alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre does not contest this fact, but believes that it is irrelevant. DEFENDANT’S PURPORTED FACTS 3. In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies that Mr. Barden, “issued a statement.” Instead it appears to have the contact as Ross Gow and a reference to Devonshire Solicitors. DEFENDANT’S PURPORTED FACTS 4. The statement read in full: Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 2011 London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. It is unacceptable that letters sent by Ms. Maxwell’s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms. Maxwell is now proceeding to take legal action against those newspapers. “I understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop,” said Ghislaine Maxwell. “A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said. 2 Case 18-2868, Document 281, 08/09/2019, 2628234, Page3 of 66 Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-251 Email: ross@acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: +44-203-008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS The document speaks for itself although it is unclear if the original included the italics that are inserted by the Defendant above. DEFENDANT’S PURPORTED FACTS 5. Ms. Giuffre’s gratuitous and “lurid” accusations in an unrelated action. In 2008 two alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against the United States government purporting to challenge Epstein’s plea agreement. They alleged the government violated their CVRA rights by entering into the agreement. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS While we would stipulate to the statement in this paragraph starting with the words “In 2008” , we do not stipulate to the opening sentence fragment Maxwell places in bold. DEFENDANT’S PURPORTED FACTS 6. Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action, claiming she, too, had her CVRA rights violated by the government. On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed. DEFENDANT’S PURPORTED FACTS 7. The issue presented in her joinder motion was narrow: whether she should be permitted to join the CVRA action as a party under Federal Rule of Civil Procedure 21, specifically, whether she was a “known victim[] of Mr. Epstein and the Government owed them CVRA duties.” Yet, “the bulk of the [motion] consists of copious factual details that [Ms. Giuffre] and [her co-movant] ‘would prove . . . if allowed to join.’” Ms. 3 Case 18-2868, Document 281, 08/09/2019, 2628234, Page4 of 66 Giuffre gratuitously included provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual trafficking. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies that the issues presented in here joinder motion were narrow. The issues presented by the joinder motion and related pleadings were multiple and complex, requiring numerous details about Ms. Giuffre’s sexual abuse and the perpetrators of her abuse. In a pleading explaining why the motion was filed, Ms. Giuffre’s lawyers sp ecifically listed nine separate reasons why Jane Doe 3’s allegations that Dershowitz had sexually abused her were relevant to the case and appropriately included in the relevant filings: 1. To establish that Jane Doe 3 had been sexually abused by Jeffrey Epstein and his co-conspirators (including co-conspirator Alan Dershowitz), which would make her a “victim” of a broad sex trafficking conspiracy covered by the federal Crime Victims’ Rights Act, 18 U.S.C. § 3771, and therefore entitled to participate in the case; 2. To support then-pending discovery requests that asked specifically for information related to contacts by Dershowitz with the Government on behalf of Jeffrey Epstein; 3. To support the victims’ allegation that the Government had a motive for failing to afford victims with their rights in the criminal process – specifically, pressure from Dershowitz and other members of Epstein’s legal defense team to keep the parameters of the non-prosecution agreement (NPA) secret to prevent Jane Doe 3 and other victims from objecting to and blocking judicial approval of the agreement; 4. To establish the breadth of the NPA’s provision extending immunity to “any potential co-conspirators of Epstein” and the scope of the remedy that the victims (including not only Jane Doe 3 but also other similarly-situated minor victims who had been sexually abused by Dershowitz) might be able to obtain for violations of their rights; 5. To provide part of the factual context for the scope of the “interface” between the victims, the Government, and Epstein’s defense team – an interface that was relevant under Judge Marra’s previous ruling that the Government was entitled to raise “a fact-sensitive equitable defense which must be considered in the factual context of the entire interface between Epstein, the relevant prosecutorial authorities and the federal offense victims . . .”; 4 Case 18-2868, Document 281, 08/09/2019, 2628234, Page5 of 66 6. To prove the applicability of the “crime/fraud/misconduct” exception to the attorney-client privilege that was being raised by the Government in opposition to the victims’ motion for production of numerous documents; 7. To bolster the victims’ argument that their right “to be treated with fairness,” 18 U.S.C. § 3771(a)(8), had been violated through the Government’s secret negotiations with one of their abusers; 8. To provide notice and lay out the parameters of potential witness testimony for any subsequent proceedings or trial – i.e., the scope of the testimony that Jane Doe 3 was expected to provide in support of Jane Doe 1 and Jane Doe 2, the already-recognized Ms. Giuffre in the action; and 9. To support Jane Doe 3’s argument for equitable estoppel to toll the sixyear statute of limitations being raised by the Government in opposition to her motion to join – i.e., that the statute was tolled while she was in hiding in Australia due to the danger posed by Epstein and his powerful friends, including prominent lawyer Alan Dershowitz. Jane Does #1 and #2 v. United States, No. 9:08-cv-80736, DE 291 at 18-26 & n.17 (S.D. Fla. 2015). Ms. Giuffre’s lawyers had attempted to obtain a stipulation from the Government on point #1 above (“victim” status), but the Government had declined. Judge Marra’s ruling concluded that certain allegations were not necessary “at this juncture in the proceedings.” DE 324 at 5. Judge Marra specifically added, however, that “Jane Doe 3 is free to reassert these factual details through proper evidentiary proof, should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a matter presented for the Court’s consideration.” DE 324 at 6. The CVRA litigation continues and no trial has been held as of the filing of this brief. As such, the extent to which these factual details will be used at trial has not yet been determined. See Docket Sheet, Jane Does #1 and #2 v. U.S., No. 9:08-cv-80736. DEFENDANT’S PURPORTED FACTS 8. At the time they filed the motion, Ms. Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA action. While they deliberately filed the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. 5 Case 18-2868, Document 281, 08/09/2019, 2628234, Page6 of 66 MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 9. As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several individuals, and she offers details about the type of sex acts performed and where they took place.” The court ruled that “these lurid details are unnecessary”: “The factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent . . ., especially considering that these details involve nonparties who are not related to the respondent Government.” Accordingly, “[t]hese unnecessary details shall be stricken.” Id. The court then struck all Ms. Giuffre’s factual allegations relating to her alleged sexual activities and her allegations of misconduct by non-parties. The court said the striking of the “lurid details” was a sanction for Ms. Giuffre’s improper inclusion of them in the motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 10. The district court found not only that the “lurid details” were unnecessary but also that the entire joinder motion was “entirely unnecessary.” Ms. Giuffre and her lawyers knew the motion with all its “lurid details” was unnecessary because the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. The court denied Ms. Giuffre’s joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 11. One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion, Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein:    Ms. Maxwell “approached” Ms. Giuffre in 1999 when Ms. Giuffre was “fifteen years old” to recruit her into the scheme. Ms. Maxwell was “one of the main women” Epstein used to “procure under-aged girls for sexual activities.” Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme. 6 Case 18-2868, Document 281, 08/09/2019, 2628234, Page7 of 66              She “persuaded” Ms. Giuffre to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.” At the mansion, when Ms. Giuffre began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.” Epstein “with the assistance of” Ms. Maxwell “converted [Ms. Giuffre] into . . . a ‘sex slave.’” Id. Ms. Giuffre was a “sex slave” from “about 1999 through 2002.” Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.” Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.” Ms. Maxwell “participat[ed] in the sexual abuse of [Ms. Giuffre] and others.” Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [Ms. Giuffre].” Id. She shared the photos with Epstein. As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect[ed]” Epstein with “powerful individuals” so that Epstein could traffic Ms. Giuffre to these persons. Ms. Giuffre was “forced to have sexual relations” with Prince Andrew in “[Ms. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” Ms. Giuffre’s sex with Prince Andrew “by acting as a ‘madame’ for Epstein.” Ms. Maxwell “assist[ed] in internationally trafficking” Ms. Giuffre and “numerous other young girls for sexual purposes.” Ms. Giuffre was “forced” to watch Epstein, Ms. Maxwell and others “engage in illegal sexual acts with dozens of underage girls.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. Ms. Giuffre contests the reference to “lurid details”. Moreover, the testimony from numerous witnesses corroborates the statements Ms. Giuffre made in her joinder motion. See below.  See McCawley Dec. at Exhibit 16, Sjoberg’s May 18, 2016 Dep. Tr. at 8-9, 13, 33-35, 142-143  See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103  See McCawley Dec. at Exhibit 14, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52-60  See McCawley Dec. at Exhibit 12, Lynn Miller’s May 24, 2016 Dep. Tr. at 115  See McCawley Dec. at Exhibit 13, Joseph Recarey’s June 21, 2016 Dep. Tr. at 29-30 7 Case 18-2868, Document 281, 08/09/2019, 2628234, Page8 of 66  See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36  Exhibit 2 Excerpted Rodgers Dep. Ex. 1 at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589  See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 12:11-15; etc.  See McCawley Dec. at Exhibit 8, Kellen Dep. Tr. at 15:13-18; 20:12-16; etc. Epstein Dep. Tr. at 116:10-15; 117:18-118:10; etc.  See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28, 52-54  See McCawley Dec. at Exhibit 30, U.S. Attorney Victim Notification Letter GIUFFRE002216-002218  See McCawley Dec. at Exhibit 33, July 2001 New York Presbyterian Hospital Records GIUFFRE003258-003290  J See McCawley Dec. at Exhibit 38, Judith Lightfoot psychological records GIUFFRE005431-005438  See McCawley Dec. at Exhibit 28, Message Pad evidencing Defendant arranging to have underage girls and young women come to Epstein’s home GIUFFRE001386-001571  See McCawley Dec. at Exhibit 29, Black Book in which Defendant and other household staff maintained a roster of underage girls including , who were minors at the time the Palm Beach Police’s Investigation of Jeffrey Epstein GIUFFRE001573-00669  See McCawley Dec. at Exhibit 40, Sex Slave books Epstein ordered from Amazon.com at GIUFFRE006581  See McCawley Dec. at Exhibit 32, the folder Defendant sent to Thailand with Ms. Giuffre bearing Defendant’s phone number GIUFFRE003191-003192 8 Case 18-2868, Document 281, 08/09/2019, 2628234, Page9 of 66  See McCawley Dec. at Exhibit 39, the Palm Beach Police Report showing that Epstein used women and girls to collect underage girls for his abuse GIUFFRE005614-005700  See McCawley Dec. at Exhibit 41, Epstein’s Flight Logs showing that Defendant flew with Ms. Giuffre 23 times GIUFFRE007055-007161 DEFENDANT’S PURPORTED FACTS 12. In the joinder motion, Ms. Giuffre also alleged she was “forced” to have sex with Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and “many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Response to Point #7 and 11, above. DEFENDANT’S PURPORTED FACTS 13. Ms. Giuffre said after serving for four years as a “sex slave,” she “managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed that Ms. Giuffre made this statement and has since discovered evidence that indicates she was mistaken on the exact timeframe of her abuse and was with Defendant and Jeffrey Epstein from the years 2000 – 2002. DEFENDANT’S PURPORTED FACTS 14. Ms. Giuffre suggested the government was part of Epstein’s “conspiracy” when it “secretly” negotiated a non-prosecution agreement with Epstein precluding federal prosecution of Epstein and his “co-conspirators.” The government’s secrecy, Ms. Giuffre alleged, was motivated by its fear that Ms. Giuffre would raise “powerful objections” to the agreement that would have “shed tremendous public light on Epstein and other powerful individuals. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre did not suggest that the Government was part of Epstein's conspiracy to commit sex offenses. The CVRA case deals with whether the Government failed in their responsibilities to the victims to inform the victims that the Government was working out a NPA, 9 Case 18-2868, Document 281, 08/09/2019, 2628234, Page10 of 66 and it is Ms. Giuffre's belief that the Government did fail to so inform the victims, and intentionally did not inform the victims because the expected serious objection from many of the victims might prevent the Government from finalizing a NPA with Epstein. See McCawley Dec. at Exhibit 50, Joinder Motion (GIUFFRE00319-00333). DEFENDANT’S PURPORTED FACTS 15. Notably, the other “Jane Doe” who joined Ms. Giuffre’s motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of Ms. Giuffre’s allegations. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This is untrue. The other Jane Doe could corroborate many of Ms. Giuffre's allegations based on a similar pattern of abuse that she suffered by Epstein. She did not know Ms. Giuffre though. , who was deposed in this case, and who was a minor, corroborates the same pattern of abuse. See McCawley Dec. at Exhibit 7, Dep. Tr. at 54:25-57:5. DEFENDANT’S PURPORTED FACTS 16. Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, Ms. Giuffre told Ms. Churcher of virtually none of the details she described in the joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This is untrue. Furthermore, Defendant does not offer any citation or evidence on this point. Defendant's statement here is knowingly false. Having read the articles and taken Ms. Giuffre's deposition, Defendant knows that Ms. Giuffre did reveal details in 2011 consistent with those in the joinder motion. See McCawley Dec. at Exhibit 31, GIUFFRE003678, FBI Redacted 302, GIUFFRE001235-1246. DEFENDANT’S PURPORTED FACTS 17. Ms. Maxwell’s response to Ms. Giuffre’s “lurid” accusations: the January 2015 statement. As Ms. Giuffre and her lawyers expected, before District Judge Marra in the 10 Case 18-2868, Document 281, 08/09/2019, 2628234, Page11 of 66 CVRA action could strike the “lurid details” of Ms. Giuffre’s allegations in the joinder motion, members of the media obtained copies of the motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 18. At Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing “a quotable statement on behalf of Ms. Maxwell.” The email was sent to more than 6 and probably less than 30 media representatives. It was not sent to non-media representatives. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Defendant falsely claims that “[a]t Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing ‘a quotable statement on behalf of Ms. Maxwell.’” This is a blatant falsehood about the document that is at the heart of this litigation. Record evidence shows that Gow sent that email at Defendant’s direction, not at Mr. Barden’s direction. Indeed, on the evening before his deposition, Mr. Gow produced an email exchange he had with Defendant in which Defendant directs Mr. Gow to send the press statement. It is as follows: 11 Case 18-2868, Document 281, 08/09/2019, 2628234, Page12 of 66 Chronologically, this email comes at the end of various other email exchanges between Defendant and Gow that discuss issuing a press release. The subject line of this email that Defendant wrote to Gow states “URGENT – this is the statement,” thereby instructing Gow to release this statement to the press. Shortly after Defendant sent this email to Gow directing him to release the statement, Gow distributed the statement to multiple media outlets. Neither Defendant nor Gow have produced any email in which Barden directed Gow to issue this press release (nor can they). Despite sending it herself, and despite it being responsive to six court-ordered search terms, Defendant failed to produce this email. Her press agent, Gow, produced this the evening before his deposition on November 17, 2016. At the deposition, Mr. Gow authenticated this email and confirmed that Defendant authorized the statement: Q. When you sent that email were you acting pursuant to Ms. Maxwell's retention of your services? A. Yes, I was. *** (Exhibit 9 was marked for identification.) Q. This also appears to be an email chain with you and Ms. Maxwell; is that correct? A. It does appear to be so. Q. Did you send the top email of the chain that says "Okay, G, going with this"? A. I did. Q. And did you receive from Ms. Maxwell, the bottom email of that chain? A. I believe so. Well, I believe -- yes, yeah, it was forwarded from Ms. Maxwell, yes. MR. DYER: Sorry, I don't quite understand that answer. THE WITNESS: I misspoke that. I did receive it from Ms. Maxwell. MR. DYER: Okay. Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know where the rest of this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine, I’ll go with this.” It is my understanding that this is the agreed statement because the subject of the second one is “Urgent, this is the statement” so I take that as an instruction to send it out, as a positive command: “This is the statement.” 12 Case 18-2868, Document 281, 08/09/2019, 2628234, Page13 of 66 See McCawley Decl. at Exhibit 6, November 18, 2016, Ross Gow Dep. Tr. at 14:15-17; 44:645:13. Together, the email and Gow’s testimony unequivocally establish that Defendant – not Barden – directed and “command[ed]” Gow to publish the defamatory statement. Accordingly, the first sentence of Defendant’s Paragraph 18 is false. The second sentence – “This email was sent to more than 6 and probably less than 30 media representatives” – omits the fact that not only did Gow admit to emailing the statement to the press, but he also read it to over 30 media representatives over the phone: Q. Do you recall ever reading the statement to the press or the media over the phone? A. It's very possible that I would have done so, yes. See McCawley Decl. at Exhibit 6, Gow Dep. Tr. at 66:2-25. Q. Do you -- do you remember discussing that with The Guardian? A. No, I don't. I'm not saying I didn't but I can't recall. You have to bear in mind, if you'd be so kind, that I've been speaking to over 30 journalists and media outlets about this, and I can't recall every single -- the detail of every single conversation. See McCawley Decl. at Exhibit 6, Gow Dep. Tr. at 64:8-14 (emphasis added). Thus, the second sentence of Defendant’s Paragraph 18 is also false. DEFENDANT’S PURPORTED FACTS 19. Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. These representatives were selected based on their request—after the joinder motion was filed—for a response from Ms. Maxwell to Ms. Giuffre’s allegations in the motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre agrees to the first sentence. The second sentence is a false. Accordingly, there is no record evidence that Gow (or anyone else) “selected” journalists “for a response,” or that there was any selection process whatsoever. To the contrary, Gow testified that anyone who inquired received a reference to the January 2015 defamatory response: 13 Case 18-2868, Document 281, 08/09/2019, 2628234, Page14 of 66 Q. To the extent you can recall or could estimate, how many other emails do you believe you sent bearing that statement that's in Exhibit 2? A. I really can't remember but certainly more than six and probably less than 30, somewhere in between. Any time there was an incoming query it was either dealt with on the telephone by referring them back to the two statements of March 2011 and January 2015 or someone would email them the statement. So no one was left unanswered, broadly, is the -- is where we were. But I can't remember every single person we reached out to. See McCawley Dec at Exhibit 6 Gow Dep. Tr. at 67:15-68:1 (emphasis added). DEFENDANT’S PURPORTED FACTS 20. The email to the media members read: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms. Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms. Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms. Roberts claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS 14 Case 18-2868, Document 281, 08/09/2019, 2628234, Page15 of 66 While Defendant cropped the body text of the email that was sent to news media representatives, she completely omitted the headings and metadata. Ms. Giuffre has put an image of the email below in Ms. Giuffre’s Paragraph. See GM_00068. DEFENDANT’S PURPORTED FACTS 15 Case 18-2868, Document 281, 08/09/2019, 2628234, Page16 of 66 21. Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional press release solely to disseminate information to the media. So he intentionally did not pass it through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Defendant states: “Mr. Barden, who prepared the statement, did not intend it as a traditional press release solely to dissemination information to the media.” Ms. Giuffre contests this statement, and all statements regarding Mr. Barden’s beliefs and purposes, and the like. Further, as stated in detail in Ms. Giuffre’s Opposition Defendant’s Motion for Summary Judgment, this Court should not even consider the Barden Declaration. Additionally, there is absolutely no record evidence of Barden’s intent and the Court should not consider it. The next sentence states, “So he intentionally did not pass it [the press release] through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation.” Again, there is zero record evidence to support any assertion of Barden’s intent. To the extent that this sentence claims that Barden did not give the statement to Gow, Ms. Giuffre does not dispute it; as described above, Defendant gave the statement to Gow with instructions to publish it. See McCawley Dec. at Exhibit 48, RG(UK)_000009, imaged in full at paragraph 81, supra. To the extent that this sentence claims that the statement did not pass “through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation,” Ms. Giuffre disputes that statement. Record documentary evidence and testimony establish that this statement was disseminated through a public relations firm, namely, Ross Gow’s firm, Acuity Reputation. See McCawley Dec. at Exhibit 6, Gow Dep. Tr. at 109:4-6 (“Q. Approximately how long have you been providing such services? A. Acuity was set up in 2010.”). DEFENDANT’S PURPORTED FACTS 16 Case 18-2868, Document 281, 08/09/2019, 2628234, Page17 of 66 22. The January 2015 statement served two purposes. First, Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of Ms. Giuffre’s false allegations. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject Ms. Giuffre’s allegations to inquiry and scrutiny. For example, he noted in the statement that Ms. Giuffre’s allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicized as news.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre objects to this paragraph in its entirety. She disputes that the January 2015 statement “served two purposes,” as this statement is wholly unsupported by the record, which Defendant again neglects to cite. Ms. Giuffre also contests the second sentence in which Defendant claims that “Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of Ms. Giuffre’s false allegations.” First, Ms. Giuffre disputes any statement of Barden’s intent as explained above. Second, Ms. Giuffre disputes that there was any “republication” by the press as a matter of law, as explained in her memorandum of law opposing summary judgment, as the press did not “republish” the press statement under New York law. Third, Ms. Giuffre disputes that her allegations are “false,” and cites to the following non-exhaustive sampling of evidence to corroborate her allegations against Defendant:  See McCawley Dec. at Exhibit 16, Sjoberg’s May 18, 2016 Dep. Tr. at 8-9, 13, 33-35, 142-143  See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103  See McCawley Dec. at Exhibit 14, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52-60  See McCawley Dec. at Exhibit 12, Lynn Miller’s May 24, 2016 Dep. Tr. at 115  See McCawley Dec. at Exhibit 13, Joseph Recarey’s June 21, 2016 Dep. Tr. at 29-30  See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36 17 Case 18-2868, Document 281, 08/09/2019, 2628234, Page18 of 66  Exhibit 2 Excerpted Rodgers Dep. Ex. 1 at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589  See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 12:11-15; etc.  See McCawley Dec. at Exhibit 8, Kellen Dep. Tr. at 15:13-18; 20:12-16; etc. Epstein Dep. Tr. at 116:10-15; 117:18-118:10; etc.  See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28, 52-54  See McCawley Dec. at Exhibit 42, Photographs including GIUFFRE007162-007182.  See McCawley Dec. at Exhibit 30, U.S. Attorney Victim Notification Letter GIUFFRE002216-002218  See McCawley Dec. at Exhibit 33, July 2001 New York Presbyterian Hospital Records GIUFFRE003258-003290  See McCawley Dec. at Exhibit 38, Judith Lightfoot psychological records GIUFFRE005431-005438  See McCawley Dec. at Exhibit 28, Message Pad evidencing Defendant arranging to have underage girls and young women come to Epstein’s home GIUFFRE001386-001571  See McCawley Dec. at Exhibit 29, Black Book in which Defendant and other household staff maintained a roster of underage girls including , who were minors at the time the Palm Beach Police’s Investigation of Jeffrey Epstein GIUFFRE001573-00669  See McCawley Dec. at Exhibit 40, Sex Slave books Epstein ordered from Amazon.com at GIUFFRE006581  See McCawley Dec. at Exhibit 32, the folder Defendant sent to Thailand with Ms. Giuffre bearing Defendant’s phone number GIUFFRE003191-003192 18 Case 18-2868, Document 281, 08/09/2019, 2628234, Page19 of 66  See McCawley Dec. at Exhibit 39, the Palm Beach Police Report showing that Epstein used women and girls to collect underage girls for his abuse GIUFFRE005614-005700  See McCawley Dec. at Exhibit 41, Epstein’s Flight Logs showing that Defendant flew with Ms. Giuffre 23 times GIUFFRE007055-007161 Next, Defendant states, “He [Barden] believed these ends could be accomplished by suggesting to the media that, among other things, they should subject Ms. Giuffre’s allegations to inquiry and scrutiny.” Ms. Giuffre disputes any statement as to Barden’s “belief” (supra). Ms. Giuffre disputes that the harm to Defendant’s reputation could be mitigated by the media’s inquiry into and scrutiny of Ms. Giuffre’s allegations, because a deeper inquiry would only reveal additional evidence corroborating Ms. Giuffre’s allegations, such as the evidence put forth in Ms. Giuffre’s opposition memorandum of law and detailed in the bulleted citations, supra. Defendant then states, “For example, he [Barden] noted in the statement that Ms. Giuffre’s allegations changed dramatically over time, suggesting that they are ‘obvious lies’ and therefore should not be ‘publicized as news.’” First, Ms. Giuffre disputes that Barden noted anything in the statement, as that is unsubstantiated by the record evidence. Not to do Defendant’s work for her, but the closest evidence Defendant has for such a statement is testimony from the Gow deposition wherein Gow speculates that Barden “had a hand in” drafting the press statement, an opinion which may or may not be based on first-hand knowledge. See McCawley Dec. at Exhibit 6, Gow Dep. Tr. at 45:14-17 (Q. Okay. A. And I say, “Thanks, Philip” because I’m aware of the fact that he had a hand, a considerable hand in the drafting.”) This is wholly insufficient to show who drafted the passages quoted by Defendant above. Regardless of those passages’ original author, it is ultimately Defendant who “noted” anything because it is her statement and she directed that it be sent to the media and public. 19 Case 18-2868, Document 281, 08/09/2019, 2628234, Page20 of 66 Second, Ms. Giuffre disputes that her allegations have changed over time, “dramatically” or otherwise. Third, Ms. Giuffre disputes that the press release “suggest[ed]” that her allegations are “obvious lies,” because Defendant’s press release affirmatively, unambiguously stated that her allegations are “obvious lies” – there is no subtlety, suggestion, or statement of opinion here. See Giuffre v. Maxwell, 165 F. Supp.3d 147, 152 (S.D.N.Y. 2016) (“. . . these statements (as they themselves allege), are capable of being proven true or false, and therefore constitute actionable fact and not opinion.” DEFENDANT’S PURPORTED FACTS 23. Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish Ms. Giuffre’s allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that Ms. Giuffre’s allegations were “defamatory.” In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of Ms. Giuffre’s obviously false allegations and the legal indefensibility of their own conduct. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This paragraph is another purported statement of Defendant’s counsel’s “intent.” Defendant states: “Second, Mr. Barden intended the January 2015 statement to be a ‘shot across the bow’ of the media, which he believed had been unduly eager to publish Ms. Giuffre’s’ allegations without conducting any inquiry of their own.” Not only does Defendant once again refer to Mr. Barden’s intent, but she also mischaracterizes the statement as a “shot across the bow” of the media. The press release did not threaten or give warning to the media in any way whatsoever. See McCawley Dec. at Exhibit 26, GM_00068, full image copied in Ms. Giuffre’s Paragraph 18, supra. Next, Ms. Giuffre disputes the sentence, “Accordingly, in the statement he repeatedly noted that Ms. Giuffre’s allegations were ‘defamatory.’” Barden did not “note” anything in the statement, nor does Defendant cite to any record evidence that he does. Furthermore, Ms. Giuffre 20 Case 18-2868, Document 281, 08/09/2019, 2628234, Page21 of 66 denies that any of her allegations are defamatory in the slightest, as they are all true and substantiated by record evidence (supra). Ms. Giuffre also disputes the sentence, “In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of Ms. Giuffre’s obviously false allegations and the legal indefensibility of their own conduct.” First, Ms. Giuffre objects to any statement of Barden’s intent, as articulated above. Second, Defendant’s conventional press release was in no way any type of “cease and desist letter.” There is no record evidence in support of this claim, and Defendant unsurprisingly cites to none. Third, Ms. Giuffre disputes that any media-recipients would be given to understand “the seriousness with which Ms. Maxwell considered the publication of Ms. Giuffre’s obviously false allegations and the legal indefensibility of their own conduct” by Defendant’s self-serving press release, as that is unsupported by the record. Finally, Ms. Giuffre rejects that her allegations are "obviously false,” a claim which is completely unsupported by record evidence. DEFENDANT’S PURPORTED FACTS 24. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms. Maxwell” (emphasis supplied). The statement was intended to be a single, one-timeonly, comprehensive response—quoted in full—to Ms. Giuffre’s December 30, 2014, allegations that would give the media Ms. Maxwell’s response. The purpose of the prefatory statement was to inform the media-recipients of this intent. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS 21 Case 18-2868, Document 281, 08/09/2019, 2628234, Page22 of 66 Ms. Giuffre disputes that any part of Defendant’s press release is “consistent with those two [of Barden’s] purposes.” Indeed, Ms. Giuffre disputes this and any statement relating to Barden’s “purposes,” as explained above. Next, Ms. Giuffre disputes that, “The statement was intended to be a single, one-timeonly, comprehensive response – quoted in full – to Ms. Giuffre’s December 30, 2014, allegations that would give the media Ms. Maxwell’s response.” First, Ms. Giuffre disputes this and any statement relating to Barden’s “intent” as explained above. Second, Ms. Giuffre disputes that anyone intended the press release to be a one-time-only, comprehensive response. The record evidence says otherwise: Gow repeatedly issued this statement via email and over the phone for months on end. Next, Defendant states, “The purpose of the prefatory statement was to inform the mediarecipients of this intent.” First, Ms. Giuffre disputes this and any statement relating to Barden’s purpose as explained above. Second, Ms. Giuffre disputes that the press release was to inform the media of anything. Defendant issued a press release, instructed them to publish it (by telling them it was “quotable”), see McCawley Dec. at Exhibit 48, RG(UK)_000009 (supra), and hired a press agent to feed it to the press: Q. Did Ms. Maxwell retain the services of you or your firm? A. Yes, she did. *** Q. Is it your belief that that agreement was in effect on January 2nd, 2015? A. Yes. Q. Do you recall the terms of that agreement? A. Well, it was a re-establishment of an existing agreement so if we go back to the original agreement, it was to provide public relations services to Ms. Maxwell in the matter of Giuffre and her activities. 22 Case 18-2868, Document 281, 08/09/2019, 2628234, Page23 of 66 See McCawley Dec. at Exhibit 6 Gow Dep. Tr. at 12:19-21; 13:9-16. The record evidence shows that Defendant’s intent was for the press to publish her press release: any other interpretation is not only contrary to logic, but unsupported by the record. DEFENDANT’S PURPORTED FACTS 25. Ms. Giuffre’s activities to bring light to the rights of victims of sexual abuse. Ms. Giuffre has engaged in numerous activities to bring attention to herself, to the prosecution and punishment of wealthy individuals such as Epstein, and to her claimed interest of bringing light to the rights of victims of sexual abuse. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed to the portion of Defendant’s assertion in bold font. Ms. Giuffre has not engaged in activities to bring attention to herself, rather she has taken action to aid in the prosecution of her abusers, and she seeks to bring light to the rights of victims of sexual abuse. DEFENDANT’S PURPORTED FACTS 26. Ms. Giuffre created an organization, Victims Refuse Silence, Inc., a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre created Victims Refuse Silence, Inc., in order to help other sexually trafficked victims find the resources they need to recover and heal. See www.victimsrefusesilence.org. DEFENDANT’S PURPORTED FACTS 27. The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse.” Toward this end, Ms. Giuffre has “dedicated her professional life to helping victims of sex trafficking.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed. 23 Case 18-2868, Document 281, 08/09/2019, 2628234, Page24 of 66 DEFENDANT’S PURPORTED FACTS 28. Ms. Giuffre repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Denied. Ms. Giuffre was approached by numerous media outlets and refused to speak to most of them. Media organizations sought her out; she did not seek them out. See McCawley Dec. at Exhibit 35, GIUFFRE003690, email from Sharon Churcher seeking to interview Ms. Giuffre. DEFENDANT’S PURPORTED FACTS 29. On December 30, 2014, Ms. Giuffre publicly filed an “entirely unnecessary” joinder motion laden with “unnecessary,” “lurid details” about being “sexually abused” as a “minor victim[]” by wealthy and famous men and being “trafficked” all around the world as a “sex slave.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Paragraph 7, supra, listing multiple reasons why details were, in fact, necessary. DEFENDANT’S PURPORTED FACTS 30. The Ms. Giuffre’s alleged purpose in filing the joinder motion was to “vindicate” her rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution agreement” with Epstein, “shed tremendous public light” on Epstein and “other powerful individuals” that would undermine the agreement, and support the CVRA Ms. Giuffre’s’ request for documents that would show how Epstein “used his powerful political and social connections to secure a favorable plea deal” and the government’s “motive” to aid Epstein and his “co-conspirators.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Paragraph 7, supra, listing multiple purposes of Ms. Giuffre’s lawyers’ filing of the motion. 24 Case 18-2868, Document 281, 08/09/2019, 2628234, Page25 of 66 DEFENDANT’S PURPORTED FACTS 31. Ms. Giuffre has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s alleged “sex scheme.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Paragraph 52, infra, explaining that the context of this statement is misleading. DEFENDANT’S PURPORTED FACTS 32. Republication alleged by Ms. Giuffre. Ms. Giuffre was required by Interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were “‘published globally, including within the Southern District of New York,’” as Ms. Giuffre alleged in Paragraph 9 of Count I of her complaint. In response, Ms. Giuffre identified the January 2015 statement and nine instances in which various news media published portions of the January 2015 statement in news articles or broadcast stories. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre objects to this paragraph in its entirety, starting with the bolded heading (“Republication alleged by Ms. Giuffre”). There is no “republication” as a matter of law in this case, as explained in Ms. Giuffre’s memorandum of law. Accordingly, Ms. Giuffre is not and has not alleged republication. As noted in her objection that, it is Defendant who possesses the knowledge as to where the defamatory statements were published; unsurprisingly, Defendant failed to comply with Ms. Giuffre’s discovery requests on the same. As Defendant already knows, Ms. Giuffre provided a sampling of Defendant’s defamatory statements published by the news media, as “identification of an exhaustive responsive list would be unduly burdensome.” This, of course, is because Defendant caused her statement to be published in an enormous number of media outlets. Ms. Giuffre’s full response to Interrogatory No. 6 is below. As the Court can see, these nine instances were a good-faith effort to provide some samples (as it would be virtually impossible to provide all of them), below. Ms. 25 Case 18-2868, Document 281, 08/09/2019, 2628234, Page26 of 66 Giuffre has also put forth an exhaustive expert report and expert testimony from Jim Jansen regarding the dissemination of Defendant’s defamatory press release. Ms. Giuffre objects because the information interrogatory above is in the possession of Defendant who has failed to comply with her production obligations in this matter, and has failed to comply with her production obligations with this very subject matter. See Document Request No. 17 from Ms. Giuffre’s Second Request for Production of Documents to Defendant Ghislaine Maxwell. Maxwell has not produced all “URL or Internet addresses for any internet version of such publication” that she directed her agent, Ross Gow, to send. Ms. Giuffre further objects because the information requested above is in the possession of Defendant’s agent, who caused the false statements to be issued to various media outlets. Ms. Giuffre has not had the opportunity to depose Maxwell’s agent Ross Gow; therefore, this answer remains incomplete. Consequently, Ms. Giuffre reserves the right to modify and/or supplement her responses, as information is largely in the possession of the Defendant and her agent. Ms. Giuffre objects to this interrogatory in that it violates Rule 33 as its subparts, in combination with the other interrogatories, exceed the allowable twenty-five interrogatories. Ms. Giuffre objects to this request because it is in the public domain. Ms. Giuffre also objects in that it seeks information protected by the attorney-client/work product privilege, and any other applicable privilege stated in the General Objections. Notwithstanding such objections, Ms. Giuffre has already produced documents supplements such responsive documents with the following list of publications. While the identification of an exhaustive responsive list would be unduly burdensome, in an effort to make a good faith effort towards compliance, Ms. Giuffre provides the following examples, which are incomplete based on the aforementioned reasons: 26 Case 18-2868, Document 281, 08/09/2019, 2628234, Page27 of 66 Date Nature Publishing Entityr Ianuarvl 2015 Internet Ross ?rm; I ane Doe 5 is Virginia Roberts - so not a new individual. The allegations made b3: Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be undue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged bf; Ms. Roberts that Alan Dershowitz is involved in having sexual relations with her, which he denies. Ms. Roberts?s claims are obvious lies and should be treated as such and not publicized as news, as thev are defarnatorv. Ghislaine Maxwell's original response to the lies and defarnatorf; clairns rernains the sarne. Maxwell strongly denies allegations of an nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defarnatorv clairns. January-'2, 2015 Internet Bolton News http: national '1 .Palace denies Andrew sex case clairn' January-?5, 2?15 Internet Telegraph http: 't?cnews 'therovalfarnilv 1 l5 2 5 i" Prince-Andrew- deni es-having-relati ons-with- sex- slave- girl_h11nl January-?5, 2015 Internet Dailv Mail http: article-2395566 'Prince- Andrew- lobbi ed- governrnent- easv-I effrev-Epstein- January-'3, 2015 Internet Huffington Post http: 1 5 '01 '05 'dulce-of? vorlc-sex-abuse-clairns Ianuarv4,2015 Internet Express http: 'world'55?UE5 'Ghislaine- Maxwell-I le-Florida- court-case-Prince-Andrew Ianuarv4,2015 Internet I ewish News Online http: Internet Broadcast Hr Dailv News http: 'world'alleged- 1.2065505 Internet" Broadcast AOL UK http: "ms-w. aol. co.ulc 'video 'ghislaine-rnaxwell-declines- E5EI5UU Two newest articles [13 "nwm-zthesuntonlt'archives 'news 'dI54 http: co_ulc news 'ulc-news [1319?1 27 Case 18-2868, Document 281, 08/09/2019, 2628234, Page28 of 66 DEFENDANT’S PURPORTED FACTS 33. In none of the nine instances was there any publication of the entire January 2015 statement. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS While there may be certain publications who did not print every word of Defendant’s lengthy press release, most publications quoted the most salient, to-the-point parts of Defendant’s statement that call Ms. Giuffre a liar. In each of the nine articles listed above, the defamatory statement, as articulated by the Complaint and as identified by the Court as actionable, is published. See Giuffre v. Maxwell, 165 F. Supp.3d 147, 152 (S.D.N.Y. 2016) (“statements that Giuffre’s claims ‘against [Defendant] are untrue,’ have been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning: that Giuffre is not telling the truth about her history of sexual abuse and Defendant’s role, and that some verifiable investigation has occurred and come to a definitive conclusion proving that fact. Second, these statements (as they themselves allege), are capable of being proven true or false, and therefore constitute actionable fact and not opinion”). Ms. Giuffre also put forth extensive evidence of the mass distribution of Defendant’s defamatory statement to over 66 million viewers through her expert witness Jim Jansen. See McCawley Dec. at Exhibit 24, Expert Report of Jim Jansen. DEFENDANT’S PURPORTED FACTS 34. Ms. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in Ms. Giuffre’s response to Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015 statement. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre disputes this statement in its entirety, as it is completely devoid of record evidence. In fact, the record establishes the contrary. First, Defendant hired Gow because his 28 Case 18-2868, Document 281, 08/09/2019, 2628234, Page29 of 66 position allowed him to influence the press to publish her defamatory statement. A sampling of Gow’s testimony establishes just that: Q. A. Did Ms. Maxwell retain the services of you or your firm? Yes, she did. *** Q. A. Q. A. Is it your belief that that agreement was in effect on January 2nd, 2015? Yes. Do you recall the terms of that agreement? Well, it was a re-establishment of an existing agreement so if we go back to the original agreement, it was to provide public relations services to Ms. Maxwell in the matter of Giuffre and her activities. *** Q. You can answer -- to the extent that anything you testify to is not protected by a privilege. A. called that Ms. Ms. Roberts first came to my attention on or around March 2011 when I was into a meeting with Philip Barden and Ms. Maxwell at Devonshires law office, she had made -- Ms. Giuffre had made extremely unpleasant allegations about Maxwell's private life. We were -- Acuity Reputation, my firm was called in to protect Ms. Maxwell's reputation, and to set the record straight. That was -- and work commenced on or around March of 2011. that *** Q. Does this document fairly depict pages from your -- from Acuity Reputation's website? A. It does. Q. Do you see where it says "We manage reputation and forge opinion through public relations, strategic communications and high level networking"? A. I do. Q. Is that a true statement? A. Say it again. Sorry. Q. Is that a true statement? A. It is, yes. I wrote that statement. *** Q. · · Okay.· Do you see where your website claims that your company has "excellent relationships with the media"? A.· · I do. Q.· · Is that a true statement? 29 Case 18-2868, Document 281, 08/09/2019, 2628234, Page30 of 66 A.· · That is true, yeah. *** Q.· · A.· · Is it correct that you advertise your “excellent relationships with the media" because your services often include giving communications to the media on behalf of your clients? Yes. See McCawley Dec. at Exhibit 6 Gow Dep. Tr. at 13:9-16; 15:18-16:3; 109:12-22; 110:16-21; 111:3-7. In addition to testimonial evidence, the proof is also in the result. By using Gow to issue her press release, Defendant caused her statement to be published by numerous major news organizations with wide readership all over the globe. Accordingly, the record evidence shows that Ms. Maxwell, through her agent, had immense control and authority over the media, convincing major news outlets to publish her words based on nothing more than a single email from Gow. DEFENDANT’S PURPORTED FACTS 35. Ms. Giuffre’s defamation action against Ms. Maxwell. Eight years after Epstein’s guilty plea, Ms. Giuffre brought this action, repeating many of the allegations she made in her CVRA joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed, but noting that the defamation cause of action against Defendant did not accrue until Defendant defamed her in January of 2015, the same year Ms. Giuffre filed suit against Defendant for defamation. DEFENDANT’S PURPORTED FACTS 36. The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”: (a) (b) (c) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” That the allegations have been “shown to be untrue.” That Giuffre’s “claims are obvious lies.” 30 Case 18-2868, Document 281, 08/09/2019, 2628234, Page31 of 66 MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed. However, in discovery, Defendant was finally forced to produce the complete press release she issued. See McCawley Dec. at Exhibit 26, GIUFFRE00068. DEFENDANT’S PURPORTED FACTS 37. Ms. Giuffre lived independently from her parents with her fiancé long before meeting Epstein or Ms. Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999, Ms. Giuffre moved in with the family of a fellow patient. There she met, and became engaged to, her friend’s brother, James Michael Austrich. She and Austrich thereafter rented an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs in that area. Later, they stayed briefly with Ms. Giuffre’s parents in the Palm Beach/ Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. Although Ms. Giuffre agreed to marry Austrich, she never had any intention of doing so. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre did not voluntarily live independently from her parents with her fiancé, rather Ms. Giuffre was a troubled minor child who was not truly engaged prior to meeting Defendant and Epstein. Where Ms. Giuffre lived, and who she lived with, are not relevant to the issues being decided in this action. Again, this is merely a transparent distraction from the case that is actually at issue, and is being used for the sole purpose of inserting conjecture in an effort to distract the Court and ultimately the jury. Although Austrich testified that he proposed to Ms. Giuffre on Valentine’s Day, see Austrich at p. 19, Ms. Giuffre was a troubled teen who could not realistically be considered a fiancé in the true sense of the word, nor was she of legal age to marry. In fact, as accurately described by Defendant, Ms. Giuffre never had any intention of marrying Austrich. Giuffre Dep. Tr. at 127:22-128:21. Given that Ms. Giuffre was a child with limited legal capacity at this point, and that she did not have any intention of marrying Austrich, a reasonable person could not assert that Ms. Giuffre was engaged. 31 Case 18-2868, Document 281, 08/09/2019, 2628234, Page32 of 66 DEFENDANT’S PURPORTED FACTS 38. Ms. Giuffre re-enrolled in high school from June 21, 2000 until March 7, 2002. After finishing the 9th grade school year at Forest Hills High School on June 9, 1999, Ms. Giuffre re-enrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on August 14, 2001. On September 20, 2001, Ms. Giuffre then enrolled at Royal Palm Beach High School. A few weeks later, on October 12, 2001, she matriculated at Survivors Charter School. Id. Survivor’s Charter School was an alternative school designed to assist students who had been unsuccessful at more traditional schools. Ms. Giuffre remained enrolled at Survivor’s Charter School until March 7, 2002. She was present 56 days and absent 13 days during her time there. Id. Ms. Giuffre never received her high school diploma or GED. Ms. Giuffre and Figueroa went “back to school” together at Survivor’s Charter School. The school day there lasted from morning until early afternoon. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies this statement. Either Defendant is blatantly misleading this Court or Defendant simply does not understand how to interpret Ms. Giuffre’s school records. The record produced by Defendant (GM0888) is specifically titled “A07. Assignment History,” which reflects semester start and end dates per each 180 day school year, not dates that Ms. Giuffre physically enrolled or withdrew from school. See McCawley Dec. at Exhibit 27, GM0888. 32 Case 18-2868, Document 281, 08/09/2019, 2628234, Page33 of 66 While “Grade 30” indicates adult education, Ms. Giuffre’s attendance records indicate that she was not present in school between 6/21/00-09/20/01 (see withdrawal codes W32 and W47). More importantly, Ms. Giuffre’s school transcripts clearly indicate “NO COURSES TAKEN” for the 1999-2000 and 2000-2001 school years. (See McCawley Dec. at Exhibit 27, GM_00893.) Ms. Giuffre’s attempt to work and resume school at Survivor’s Charter School as a 10th grader in the 2001-2002 school year was limited to a portion of the school year (10/20/0103/07/02), and further substantiates Ms. Giuffre’s testimony that she attempted to get away from Epstein’s abuse, along with the following testimony by Figueroa: Q: A: Q: A: Was there a period of time between 2001 and when she left in 2002 here she was not working for Jeffrey? Yes. What period of time was that? It was pretty much, like, when she was actually working as a server. Like, basically because we were trying to not have her go back there. Like, she did not want to go back there. And we were trying to just work without needing his money, you know.” See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 92-93 Q: A: So the thing that Virginia was tired of …What was it that Virginia was trying to get away from and stop with respect to working at Jeffrey Epstein's house? To stop being used and abused. See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 248 33 Case 18-2868, Document 281, 08/09/2019, 2628234, Page34 of 66 Even still, if the records are correct, which Ms. Giuffre does not concede, the records indicate that Ms. Giuffre’s attendance was poor, with 69 days present and 32 days absent out of a required 180 day school year and that she was not enrolled at the end of the school year (emphasis added). . 34 Case 18-2868, Document 281, 08/09/2019, 2628234, Page35 of 66 See McCawley Dec. at Exhibit 27, GM_00893. Ms. Giuffre’s obvious gap in her school attendance, her presence verified by Epstein’s pilot on flight logs, and an abundence of witness testimony all corroborate her story that she was that Ms. Giuffre was flying domestic and internationally with Epstein at least 32 times between 12/11/00-07/28/01 and 06/21/02-08/21/02 (Defendant traveling with Ms. Giuffre on 23 of the flights). See McCawley Dec. at Exhibits 15 and 41, Pilot, David Rodgers’ Dep. Tr. 96:12-166; Rodger’s Dep. Ex. 1 (Ms. Giuffre flight dates: 12/11/00; 12/14/00 (GIUFFRE007095); 01/26/01; 01/27/01; 01/30/01 (GIUFFRE007096); 03/05/01: 03/06/01; 03/08/01 x’s 2; 03/09/01; 03/11/01 x’s 2 (GIUFFRE007097); 03/27/01; 03/29/01; 03/31/01 (GIUFFRE007098); 04/09/01 x’s 2; 04/11/01; 04/16/01; 05/03/01; 05/05/01 (GIUFFRE007099); 05/14/01(GIUFFRE007100); 06/03/01 06/05/01; 07/04/01; 07/08/01; 07/11/01 (GIUFFRE007101); 07/16/01; 07/28/01; (GIUFFRE007102); 06/21/02 (GIUFFRE007111); 08/18/02; 08/21/02 (GIUFFRE007112); See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 104: 9-14 (Q: Do you know how long Virginia had been coming over to the house before she started traveling on an airplane with Ghislaine and Jeffrey? THE WITNESS: Not too long. I don't think it was too long after that); See McCawley Dec. at Exhibit 37, GIUFFRE004721 (passport application). DEFENDANT’S PURPORTED FACTS 39. During the year 2000, Ms. Giuffre worked at numerous jobs. In 2000, while living with her fiancé, Ms. Giuffre held five different jobs: at Aviculture Breeding and Research Center, Southeast Employee Management Company, The Club at Mar-a-Lago, Oasis Outsourcing, and Neiman Marcus. Her taxable earnings that year totaled nearly $9,000. Ms. Giuffre cannot now recall either the Southeast Employee Management Company or the Oasis Outsourcing jobs. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS 35 Case 18-2868, Document 281, 08/09/2019, 2628234, Page36 of 66 Ms. Giuffre disputes this statement. During 2000, Ms. Giuffre shared an apartment with her then boyfriend, James Michael Austrich and his friend, Mario. See McCawley Dec. at Exhibit 2, Austrich Dep. Tr. at p. 92. Although Austrich testified that he proposed to Ms. Giuffre on Valentine’s Day, see Austrich at p. 19, Ms. Giuffre was a troubled teen who could not realistically be considered a fiancé in the true sense of the word nor was she of legal age to marry. While Ms. Giuffre held various jobs in 2000, “[SSA] records do not show the exact date of employment (month and day) because [they] do not need this information to figure Social Security benefits.” See McCawley Dec. at Exhibit 46, GIUFFRE009176). The reason that Ms. Giuffre cannot recall two companies listed on her SSA records (Southeast Employee Management Company or Oasis Outsourcing) is simply because they were not her employers. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 470-472. Had Defendant bothered to run a simple google search, she could have ruled them out as being payroll and benefit administration companies. See http://www.oasisadvantage.com/west-palm-beach-peo; http://www.progressiveemployer.com/; http://www.businesswire.com/news/home/20060501006151/en/Progressive-Employer-ServicesPurchases-Southeast-Employee-Management. Ms. Giuffre has testified that she believes she worked at Taco Bell, at an aviary, then Mar-a-Lago (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at p. 53, 470). Austrich also testified that Ms. Giuffre worked with him at Taco Bell, as well as a pet store for “over a month” before working at Mar-a-Lago (See McCawley Dec. at Exhibit 5, Austrich Dep. Tr. at p. 16, 30, 98). Neither Taco Bell nor the pet store are listed on Ms. Giuffre’s SSA records because they were most likely paid through payroll companies. See McCawley Dec. at Exhibit 46, GIUFFRE009178. Ms. Giuffre also testified that she volunteered at an aviary where they 36 Case 18-2868, Document 281, 08/09/2019, 2628234, Page37 of 66 eventually put her on their payroll, but paid her very little. Giuffre Dep. Tr. at p. 52; Aviculture Breeding and Research Center taxable earnings for 2000 is $99.48, See McCawley Dec. at Exhibit 46, GIUFFRE009178. DEFENDANT’S PURPORTED FACTS 40. Ms. Giuffre’s employment at the Mar-a-Lago spa began in fall 2000. Ms. Giuffre’s father, Sky Roberts, was hired as a maintenance worker at the The Mar-a-Lago Club in Palm Beach, Florida, beginning on April 11, 2000. Mr. Roberts worked there year-round for approximately 3 years. After working there for a period of time, Mr. Roberts became acquainted with the head of the spa area and recommended Ms. Giuffre for a job there. Mar-a-Lago closes every Mother’s Day and reopens on November 1. Most of employees Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club is open, i.e., between November 1 and Mother’s Day. Ms. Giuffre was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre disputes this statement. Defendant cannot simply infer Ms. Giuffre’s employment history and claim it to be undisputed. The Mar-a-Lago Club produced 177 pages of records in response to Defendant’s subpoena. However, not one page indicated Ms. Giuffre’s actual dates of employment, nor whether she was a full-time or seasonal employee. In fact, the only significant record produced was a single, vague chart entry indicating that Ms. Giuffre was terminated in 2000. MAR-A-LAGO 0173, 0176. 37 Case 18-2868, Document 281, 08/09/2019, 2628234, Page38 of 66 Job postings and job descriptions produced by Mar-a-Lago from 2002 and later are irrelevant to Ms. Giuffre’s employment because they are from after she worked there. Ms. Giuffre testified that Mar-a-Lago was a summer job. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. 56, 550. In fact, her father, Sky Roberts, testified that he referred his daughter for employment, and she did not get the job through a posting (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 72); he drove his daughter to and from work consistent with his full time schedule (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 74); he believes the spa – like the kitchen/dining room - was open to local guests in the summer (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. 138-139); and that his daughter was not attending school when she worked at Mar-a-Lago (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. 134). In addition, Juan Alessi testified that it was “Summer” when Defendant approached Ms. Giuffre at Mar-a-Lago because he specifically remembered “that day I was sweating like hell in the -- in the car, waiting for Ms. Maxwell to come out of the massage.” See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 94:24-95:2. DEFENDANT’S PURPORTED FACTS 41. Ms. Giuffre represented herself as a masseuse for Jeffrey Epstein. While working at the Mar-a-Lago spa and reading a library book about massage, Ms. Giuffre met Ms. Maxwell. Ms. Giuffre thereafter told her father that she got a job working for Jeffrey Epstein as a masseuse. Ms. Giuffre’s father took her to Epstein’s house on one occasion around that time, and Epstein came outside and introduced himself to Mr. Roberts. Ms. Giuffre commenced employment as a traveling masseuse for Mr. Epstein. Ms. Giuffre was excited about her job as a masseuse, about traveling with him and about meeting famous people. Ms. Giuffre represented that she was employed as a masseuse beginning in January 2001. Ms. Giuffre never mentioned Ms. Maxwell to her then-fiancé, Austrich. Ms. Giuffre’s father never met Ms. Maxwell. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies Defendant’s false and factually unsupported narrative. In Florida, a person cannot work as a masseuse unless she is “at least 18 years of age or has received a high 38 Case 18-2868, Document 281, 08/09/2019, 2628234, Page39 of 66 school diploma or high school equivalency diploma.” Fla. Stat. § 480.041. Ms. Giuffre was a minor child, under the age of 18, when she was working at Mar-a-Lago as a spa attendant. Giuffre Dep. Tr. at 61:9-61:24. She was approached by Defendant, who told her she could make money as a masseuse, a profession in which Ms. Giuffre had no experience. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12. (Sky Roberts, Ms. Giuffre father, verified Ms. Giuffre’s account that Defendant recruited his daughter to “learn massage therapy.” See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 80:7-19; 84:18 85:1). Ms. Giuffre’s father drove her to Jeffrey Epstein’s house, the address of which was given to her by Defendant. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 117:20-118:1. Ms. Giuffre was lead into the house, and was instructed by Defendant on how to give a massage, during which Epstein and Defendant turned the massage into a sexual encounter, and offered Ms. Giuffre money and a better life to be compliant in the sexual demands of Defendant and Epstein. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18. The minor Ms. Giuffre then began travelling with Defendant and Epstein on private planes and servicing people sexually for money—working not as a legitimate masseuse, but in a position of sexual servitude. See McCawley Dec. at Exhibits 5, 1, Giuffre Dep. Tr. at 193:22-194:16; 201:24; 204:24:205:5; Alessi Dep. Tr. at 104:9-104:14. Epstein’s house manager, Juan Alessi, described Defendant’s methodical routine of how she prepared a list of places ahead of time, then drove to each place for the purpose of recruiting girls to massage Epstein. See McCawley Dec. at Exhibit 18, Alessi Dep. Tr. at 34; GIUFFRE000105 at 57-58; GIUFFRE000241-242 at p. 212-213. Alessi also stated that on multiple occasions he drove Defendant to pre-planned places while she recruited girls for 39 Case 18-2868, Document 281, 08/09/2019, 2628234, Page40 of 66 massage. Id. He furthered testified that he witnessed Ms. Giuffre at Epstein’s house on the very same day that he witnessed Defendant recruit Ms. Giuffre from Mar-a-Lago. See McCawley Dec. at Exhibit 18, Alessi Dep. Tr. at 96-98; GIUFFRE000102-103 at p. 48-49. Johanna Sjoberg, through her sworn testimony, demonstrated that Defendant recruited her in a similar fashion by driving to the college campus where she attended school and approached her to work at Epstein’s home answering phones. See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 8-9. Sjoberg testified that she answered phones for one day before Defendant propositioned her to rub feet for $100.00 an hour. See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 13. The following day, Sjoberg was paired with Defendant’s assistant, Emmy Taylor, who provided her with massage training on Epstein. Sjoberg at 13-15. Ms. Giuffre’s then-boyfriend, Austrich, testified that he could not recall the name of the person who recruited Ms. Giuffre. However, he did say that she was recruited by someone to work for Epstein as a massage therapist, but that Ms. Giuffre did not have any experience. See McCawley Dec. at Exhibit 2, Austrich Dep. Tr. at 34-35, 100-101, 127-128. Neither Ms. Giuffre nor Sjoberg were licensed or trained in massage, but were invited soon after being recruited to travel with Epstein on his private plane to massage him. See McCawley Dec. at Exhibit 16, Giuffre Dep. Tr. at 16-17; Sjoberg Dep. Tr. at 13-15; Austrich Dep. Tr. at 109-110; Alessi Dep. Tr. at 104. DEFENDANT’S PURPORTED FACTS 42. Ms. Giuffre resumed her relationship with convicted felon Anthony Figueroa. In spring 2001, while living with Austrich, Ms. Giuffre lied to and cheated on him with her high school boyfriend, Anthony Figueroa. Ms. Giuffre and Austrich thereafter broke up, and Figueroa moved into the Bent Oak apartment with Ms. Giuffre. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa in Ms. Giuffre’s presence punched Austrich in the face. Figueroa and Ms. Giuffre fled the scene before police arrived. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS 40 Case 18-2868, Document 281, 08/09/2019, 2628234, Page41 of 66 This entire statement is wholly irrelevant to the case being tried, and is improperly being inserted to tarnish the record. Ms. Giuffre’s dating history as a young teen bears no relation to the allegations made within Ms. Giuffre’s complaint against Defendant. As previously stated, Defendant is attempting to muddy the record with nonsensical teen drama in an effort to detract from her salacious sexual abuse of a minor child. Such statements bear no relation to the issues presented through her motion for summary judgment, and should be given weight reflecting the same. As specifically set forth in Ms. Giuffre’s objections to designated testimony, the alleged information would be excluded by multiple rules of evidence, and contested by Ms. Giuffre. See McCawley Dec. at Exhibit 5, Virginia Dep. Tr., passim. Moreover, it was the Defendant who solicited Anthony Figueroa to recruit high school aged girls for Epstein. See McCawley Dec. at Exhibit 4 Figueroa Tr. at 200 and 228-229. DEFENDANT’S PURPORTED FACTS 43. Ms. Giuffre freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at age 17, while living in the same apartment, Ms. Giuffre and Figueroa hosted a party with a number of guests. During the party, according to Ms. Giuffre, someone entered Ms. Giuffre’s room and stole $500 from her shirt pocket. Ms. Giuffre contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a “sex slave.” A second time, in June 2002, Ms. Giuffre contacted the police to report that her former landlord had left her belongings by the roadside and had lit her mattress on fire. Again, Ms. Giuffre met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a “sex slave.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This statement is misleading in several respects and irrelevant. The fact that Ms. Giuffre did contact police on two occasions for two specific purposes and did not take that opportunity to also inform the police of everything else that was going on in her life at the time is immaterial. Defendant implies that anytime someone calls the police for one thing they should tell the police 41 Case 18-2868, Document 281, 08/09/2019, 2628234, Page42 of 66 about every other crime regardless of the relevance to the crime to which the police responded and regardless to the threat to herself should she report on these powerful people. Moreover, as Professor Coonan explained: Popular understandings of the term “sex slave” might still connote images of violent pimps, white slavery, or of victims chained to a bed in a brothel in the minds of some people. To call Ms. Giuffre a victim of sex trafficking would however very accurately convey the reality that she along with a great many other victims of contemporary forms of slavery are often exploited by the “invisible chains” of fraud and psychological coercion. See McCawley Dec. at Exhibit 23, Coonan Expert Report at 20. Ms. Giuffre specifically testified that she was fearful of Defendant and Epstein, and, accordingly, she would not have reporter her abusers. She also knew that Epstein had control over the Palm Beach Police. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 240:3-241:2. DEFENDANT’S PURPORTED FACTS 44. From August 2001 until September 2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel unaccompanied by Ms. Giuffre. Flight logs maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips away from Florida that Epstein and Maxwell took, unaccompanied by Ms. Giuffre, between August 2001 and September 2002. Rodgers maintained a log of all flights on which Epstein and Maxwell traveled with him. Epstein additionally traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial flights. For substantially all of thirteen months of the twenty-two months (from November 2000 until September 2002) that Ms. Giuffre lived in Palm Beach and knew Epstein, Epstein was traveling outside of Florida unaccompanied by Ms. Giuffre. During this same period of time, Ms. Giuffre was employed at various jobs, enrolled in school, and living with her boyfriend. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS The flight logs produced in this matter provide substantive evidence of Ms. Giuffre’s travel while in the control of Defendant and Epstein, but are clearly incomplete. Moreover, Ms. Giuffre also was flown by Defendant on commercial flights. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 155:5-11. Ms. Giuffre disputes Defendant’s statement to the contrary, as reliance upon incomplete records to prove that Ms. Giuffre was not in fact in the presence of 42 Case 18-2868, Document 281, 08/09/2019, 2628234, Page43 of 66 Defendant and Epstein is insufficient. Ms. Giuffre incorporates additional details contained in Response #38 and #46 herein. Ms. Giuffre’s obvious gap in her school records, her presence verified by Epstein’s pilot on flight logs, and witness testimony, corroborate her story that she was traveling with Defendant and Epstein. In fact, flight logs and pilot testimony clearly prove that Ms. Giuffre was flying domestic and internationally with Epstein at least 32 times between 12/11/00-07/28/01 and 06/21/02-08/21/02 (Defendant traveling with Ms. Giuffre on 23 of the flights). As Defendant acknowledges in her own statement #44, flight records are incomplete. There were several pilots and co-pilots that flew Epstein and Maxwell (Lawrence “Larry” Visoski, David (Dave) Rodgers, Bill Hammond, Pete Rathgeb, Gary Roxburgh, and Bill Murphy) in multiple aircrafts (JEGE, Inc. Aircraft # N908JE – Type B-727-31, and Hyperion Air, Inc. Aircraft # N909JE – Type G-1159B). Yet, only one pilot, David Rodger’s produced flight records. See McCawley Dec. at Exhibit 41, David Rodger’s Flight Log, GIUFFRE007055- GIUFFRE007161. In addition, many of the girls recruited by Defendant routinely traveled on commercial flights for the purposes of providing massages to Epstein or guests at Epstein’s New York, New Mexico, or U.S. Virgin Island homes. See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 27. As thoroughly depicted below, Ms. Giuffre’s passport application, travel records and witness testimony clearly demonstrate flight logs are incomplete because only one pilot kept a log, and Ms. Giuffre also flew commercially while she worked for Defendant and Epstein. For example, on December 11, 2000, while underage, Ms. Giuffre appears on Rodger’s flight log (flight #1433) traveling with Epstein, Maxwell and Emmy Taylor from PBI (Palm Beach, FL) to TEB (Teterboro, NJ) then on December 14, 2001 (#1434) continues traveling with Epstein and 43 Case 18-2868, Document 281, 08/09/2019, 2628234, Page44 of 66 Maxwell to TIST (U.S. Virgin Islands); however, there is no flight records of Ms. Giuffre’s return to Palm Beach. See McCawley Dec. at Exhibit 15, see McCawley Dec. at Exhibit 41, Rodger’s Dep. Ex. 1 at GIUFFRE007095; see also Rodger’s Dep. Tr. 96-98 (“Q: And do you know how Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, and Virginia get off of St. Thomas or leave the island? A: No. I do not. Probably a charter, I'm guessing.”). On January 12, 2001, at Defendant’s directive, Ms. Giuffre applied for a Passport to travel with them internationally. See McCawley Dec. at Exhibit 37, GIUFFRE004721, passport application listing travel plans to London; flight logs subsequently lists Ms. Giuffre traveling to London with Defendant, Epstein and others). On January 26, 2001, while underage, Ms. Giuffre appears on Rodger’s flight log (flight #1444) traveling with Epstein, Maxwell and Emmy Taylor from TEB (Teterboro, NJ) to PBI (Palm Beach, FL); however, there is no flight record indicating how Ms. Giuffre got to New York. On January 27, 2001 (#1445) continues traveling with Epstein, Maxwell and Emmy Taylor from PBI (Palm Beach) to TIST (U.S. Virgin Islands) returning from TIST (U.S. Virgin 44 Case 18-2868, Document 281, 08/09/2019, 2628234, Page45 of 66 Islands) four days later on January 30, 2001. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007096; Rodger’s Dep. Tr. at 100-102. On March 5, 2001 Ms. Giuffre, Maxwell, Epstein, Emmy Taylor traveled together internationally (flight #1464) leaving PBI (West Palm Beach) to CYJT (Stephenville, Canada); then on March 6, 2001 (#1465) they continued on to LFPB (Paris, France) with a layover for three days. On March 8, 2001, other passengers, including one unidentified female, joined them on flights # 1466-1467 (from LFPB (Paris, France) - LGGR (Granada, Spain) eventually landing in EGGW (London, England) on March 11, 2001, where she was then introduced to and lent out to Prince Andrew. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007097; Rodger’s Dep. Tr. at 104-114. 45 Case 18-2868, Document 281, 08/09/2019, 2628234, Page46 of 66 See also photo of Ms. Giuffre, Maxwell and Prince Andrew in London. GIUFFRE007167; see also Figueroa Dep. Tr. at 251. Ms. Giuffre, Epstein, Maxwell, and Taylor remained in London for three days until departing on March 11, 2001 (#1469), stopping in BGR (Bangor, Maine) before departing (#1470) back to TEB (Teterboro, NJ); however, there is no flight record of Ms. Giuffre’s return to Palm Beach. See Rodger’s Dep. Ex. 1 at GIUFFRE007097; Rodger’s Dep. Tr. at 104-114. On March 27, 2001, while underage, Ms. Giuffre, Maxwell, Epstein, Emmy Taylor, two unidentified females and others traveled together (#1478) from PBI (Palm Beach) to TEB (Teterboro, NJ); then three days later, on March 29, 2001, continued on (#1479) to SAF (Santa Fe, NM), returning to PBI (Palm Beach, FL) with Nadia Bjorlin (#1480) on March 31, 2001. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007098; Rodger’s Dep. Tr. at 119-125. 46 Case 18-2868, Document 281, 08/09/2019, 2628234, Page47 of 66 A few glaring examples of how Ms. Giuffre’s travel records are incomplete is that Ms. Giuffre traveled from ADS (Addison, Texas) on May 3, 2001 (#1501) to SAT (San Antonio, Texas); then departs SAT (San Antonio, Texas) on May 5, 2001 (#1502) to PBF (Pine Bluff, AR) but there is no record produced that explains how Ms. Giuffre arrived in Addison, Texas or how she returned to Palm Beach from Pine Bluff, AR. Although Epstein’s plane appears to have to originated from Palm Beach on April 23, 2001, Ms. Giuffre’s name doesn’t not appear on the log. See Rodger’s Dep. Ex. 1 at GIUFFRE007099; Rodger’s Dep. Tr. at 130-132 (“Q: Do you know how Virginia Roberts got to Addison, Texas? A: No. … Q: Went to Addison and picked up Virginia Roberts? A: It looks like it.”). Another prime example of how incomplete Ms. Giuffre’s travel records are is on on May 14, 2001. While Ms. Giuffre appears on flight #1506 with Epstein, Maxwell, Emmy Taylor and others (including one unidentified female) from TIST (U.S. Virgin Islands) to TEB (Teterboro, NJ), there is no record produced explaining how Ms. Giuffre arrived to the U.S. Virgin Islands or where she stayed when she landed in New York. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007100; Rodger’s Dep. Tr. at 132-133 (“Q: What were the other possible avenues back in those days for Jeffrey Epstein, Ghislaine Maxwell to travel to the Virgin Islands? A: They could have done a charter, possibly.”) (Id. at 134-135 “Q: All right. So at some point in time, between May 7th and May 14th – A: Uh-huh. Q: -- somebody flies the Gulfstream to the Virgin Islands. A: Correct. Q: And who would that be? A: Larry Visoski and I don't know who the other person would have been.”); Id. at 136 (“Q. Do you know where Virginia Roberts went during that time after she landed in Teterboro on the 14th? A. I do not.”) 47 Case 18-2868, Document 281, 08/09/2019, 2628234, Page48 of 66 On June 3, 2001, Ms. Giuffre travels from PBI (Palm Beach) to TIST (U.S. Virgin Islands) on flight #1510 for three days; then, on June 5, 2001, continues on flight #1511 to TEB (Teterboro, NJ); however, there is no record of Ms. Giuffre returning to Palm Beach. See Rodger’s Dep. Ex. 1 at GIUFFRE007101; Rodger’s Dep. Tr. at 136-137. Then, on July 4, 2001, Ms. Giuffre reappears on flight #1524 with Epstein and an unidentified female leaving TIST (U.S. Virgin Islands) to return to PBI (Palm Beach); however, there is no flight record that reflects how Ms. Giuffre got to the U.S. Virgin Islands. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007101; Rodger’s Dep. Tr. at 138-139 (“Q. And do you know how Virginia Roberts got to the Virgin Islands? A: No. Q. Is there any -- is it possible that the Cessna took her or the Boeing took her? Or any other aircraft that is owned by Jeffrey? A: No, I would -- if I had to guess, I would guess the airlines.”) Again, on July 8, 2001, Ms. Giuffre appears on flight #1525 with Epstein, Maxwell, Emmy Taylor and others including an unidentified female departing PBI (Palm Beach) to TEB 48 Case 18-2868, Document 281, 08/09/2019, 2628234, Page49 of 66 (Teteboro, NJ). Four days later, on July 11, 2001, Ms. Giuffre, Epstein and Maxwell continue on (#1526) to CPS (Cahokia-St. Louis, Illinois) which was a stop due to a mechanical delay on the way to Sante Fe, NM; however, there is no flight record that reflects how Ms. Giuffre returned home to Palm Beach. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007101; Rodger’s Dep. Tr. 139-141 (“Q: And then three days later, you leave out of Teterboro to CPS? A: Yes. Q: Where is that? A: That is St. Louis, actually it is Cahokia, Illinois, across the river from St. Louis. Q. Who are your passengers? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia Roberts. We were actually en route to Santa Fe. We had a mechanical problem. We had to go into there for maintenance.”) On July 16, 2001, Ms. Giuffre appears on flight #1528 with Epstein, Maxwell and Emmy Taylor from SAF (Santa Fe, NM) to TEB (Teteboro, NJ); however, Ms. Giuffre’s flight to Santa Fe, NM is missing from the records. In addition, on July 28, 2001, Ms. Giuffre reappears on the flight log (#1531) returning with Epstein from TIST (U.S. Virgin Islands) to PBI (Palm Beach); however, there is no record of Ms. Giuffre’s flight to the U.S. Virgin Islands. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007102; Rodger’s Dep. Tr.142. On June 21, 2002, Ms. Giuffre appears on flight #1570 with Epstein, Maxwell, Sarah Kellen, Cindy Lopez and Jean Luc Brunel from PBI (Palm Beach, FL) to MYEF (George Town, Bahamas); however, there is no record of Ms. Giuffre returning to Palm Beach. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007111; Rodger’s Dep. Tr. 161-162 (“Q: 49 Case 18-2868, Document 281, 08/09/2019, 2628234, Page50 of 66 Virginia Roberts was taken to the Bahamas. Do you know where she went from there? A. I do not.”) On August 17, 2002, Ms. Giuffre appears on flight #1589 with Epstein, Maxwell, Sarah Kellen, Cindy Lopez and others from SAF (Santa Fe, NM) to TEB (Teterboro, NJ); Ms. Giuffre returns to PBI (Palm Beach, FL) on August 18, 2002 with Epstein and one unidentified female (#1590). See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007112; Rodger’s Dep. Tr. 165 (“Q: Do you know how Virginia Roberts got to Santa Fe? A: No.”) 50 Case 18-2868, Document 281, 08/09/2019, 2628234, Page51 of 66 From September 29, 2002 through October 19, 2002, Defendant and Epstein sent Ms. Giuffre on a commercial flight to Thailand for massage training and provided her with all accommodations. See McCawley Dec. at Exhibit 43, Giuffre007411-Giuffre007432. DEFENDANT’S PURPORTED FACTS 45. Ms. Giuffre and Figueroa shared a vehicle during 2001 and 2002. Ms. Giuffre and Figueroa shared a ’93 white Pontiac in 2001 and 2002. Ms. Giuffre freely traveled around the Palm Beach area in that vehicle. In August 2002, Ms. Giuffre acquired a Dodge Dakota pickup truck from her father. Figueroa used that vehicle in a series of crimes before and after Ms. Giuffre left for Thailand. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre and Tony Figueroa did not share a vehicle during 2001 and 2002. Instead, Figueroa borrowed Ms. Giuffre’s car while she was traveling with Defendant and Epstein. Figueroa testified that he “got to take the car, because she was going somewhere else in the world and did not need it, so…” Figueroa Dep. Tr. At 89-90. In fact, Ms. Giuffre was frequently traveling with Defendant and Epstein. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 9-14 (stating that Virginia started traveling on an airplane with Ghislaine and Jeffrey “not too long” after she started going over to the house). Figueroa further testified that Virginia “would normally go about two weeks out of every month” with Epstein. Figueroa Dep. Tr. at 90. He further stated, “Pretty much every time I took her there, it was always to his mansion. I picked her up one time -- maybe it was a couple of times --from the jet stream place. But pretty much every single time it was at the hou- -- at the mansion.” Id. Moreover, Ms. Giuffre testified she purchased a car from the $10,000 payment she received from Epstein after she was forced to have sex with Prince Andres in London at Defendant’s home when Ms. Giuffre was a minor. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 120:1-20. 51 Case 18-2868, Document 281, 08/09/2019, 2628234, Page52 of 66 DEFENDANT’S PURPORTED FACTS 46. Ms. Giuffre held a number of jobs in 2001 and 2002. During 2001 and 2002, Ms. Giuffre was gainfully employed at several jobs. She worked as a waitress at Mannino’s Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at Roadhouse Grill. She also was employed at Courtyard Animal Hospital (aka Marc Pinkwasser DVM). MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This statement is laughable. Ms. Giuffre was hardly gainfully employed during a time period in which she was trying to escape from the grip Epstein and Maxwell had on Ms. Giuffre. While Social Security provides that she earned nominal amounts of earning statements for 2001 and 2002, the records do not indicate the month or quarter of the year’s work. See McCawley Dec. at Exhibit 46, GIUFFRE009176. For a brief period, Ms. Giuffre attempted to go back to school to earn her GED, and tried unsuccessfully to hold down waitressing jobs. See McCawley Dec. at Exhibit 27, GIUFFRE009179. For example, in 2001, Ms. Giuffre earned $212.00 as a waitress working “briefly” at Mannino’s Restaurant. (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 472). In 2002, Ms. Giuffre earned $403.64 at CCI of Royal Palm Beach working there (TGI Fridays) for a “short time period.” (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 473). Then, Ms. Giuffre worked at Roadhouse grill until about March 2002 earning $1,247.90 (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 474). 52 Case 18-2868, Document 281, 08/09/2019, 2628234, Page53 of 66 According to Dr. Pinkwasser’s records, Ms. Giuffre’s also received payroll checks for weeks ending 04/22/02-06/04/02 earning a total of $1,561.75. (See McCawley Dec. at Exhibit 47, GIUFFRE009203). Not long after Ms. Giuffre losing her job at Courtyard Animal Hospital, GIUFFRE00009211, flight records show that Ms. Giuffre was soon back under Epstein’s control traveling with Maxwell to the Bahamas, Santa Fe, New Mexico then New York, see McCawley Dec. at Exhibit 47, GIUFFRE007111-GIUFFRE007112. DEFENDANT’S PURPORTED FACTS 47. In September 2002, Ms. Giuffre traveled to Thailand to receive massage training and while there, met her future husband and eloped with him. Ms. Giuffre traveled 53 Case 18-2868, Document 281, 08/09/2019, 2628234, Page54 of 66 to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove her to the airport. While there, she initially contacted Figueroa frequently, incurring a phone bill of $4,000. She met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until two days before Mr. Figueroa’s deposition in this matter in May 2016. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre did travel to Thailand to receive massage training in September 2002. However, Defendant has inaccurately told only part of the story. Defendant has conveniently left out certain key facts, which includes the fact that Ms. Giuffre was given an assignment from Defendant and Epstein that she had to recruit another underage girl from Thailand, and bring that young girl back to Epstein. See McCawley Dec. at Exhibit 43, GIUFFRE 003191. The document Ms. Giuffre was give directs her to “call Ms. Maxwell.” See McCawley Dec. at Exhibit 32, GIUFFRE003191. It is not disputed by Defendant or Epstein, that Ms. Giuffre was expected to return to Epstein and Maxwell upon completion of her massage training and assignment. It is undisputed by Ms. Giuffre that she did not return to Defendant and Epstein, but instead escaped clear across the world to Australia where she remained in hiding from Defendant and Epstein for several years. DEFENDANT’S PURPORTED FACTS 48. Detective Recarey’s investigation of Epstein failed to uncover any evidence that Ms. Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. Joseph Recarey served as the lead detective from the Palm Beach Police Department charged with investigating Jeffrey Epstein. That investigation commenced in 2005. Recarey worked only on the Epstein case for an entire year. He reviewed previous officers’ reports and interviews, conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance footage of the Epstein home, participated in and had knowledge of the search warrant executed on the Epstein home, and testified regarding the case before the Florida state grand jury against Epstein. Detective Recarey’s investigation revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect by the government. None of Epstein’s alleged victims said they had seen Ms. Maxwell at Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her, nor told what to wear or how to act by her. Indeed, none of Epstein’s alleged victims ever reported to the government they had met or spoken to Ms. Maxwell. Maxwell was not 54 Case 18-2868, Document 281, 08/09/2019, 2628234, Page55 of 66 seen coming or going from the house during the law enforcement surveillance of Epstein’s home. The arrest warrant did not mention Ms. Maxwell and her name was never mentioned before the grand jury. No property belonging to Maxwell, including “sex toys” or “child pornography,” was seized from Epstein’s home during execution of the search warrant. Detective Recarey, when asked to describe “everything that you believe you know about Ghislaine Maxwell’s sexual trafficking conduct,” replied, “I don’t.” He confirmed he has no knowledge about Ms. Maxwell sexually trafficking anybody. Detective Recarey also has no knowledge of Ms. Giuffre’s conduct that is subject of this lawsuit. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This statement is false. Detective Recarey knew that Maxwell was involved in the illegal sexual activities at Epstein's house. He wanted to speak to her, but Maxwell did not return his calls. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 28:23-29:10. Detective Recarey concluded that Defendant’s role was to procure girls for Epstein. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 29:16-29:20. In the execution of the search warrant, stationary was found in the home bearing Maxwell's name, and notes were written by house staff to Maxwell. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 45:13-25; Id. at 83:3-83:15; see also Message Pads, GIUFFRE 001412, 001418, 001435, 001446, 001449, 001453, 001454. A key piece of evidence in the investigation were message pads uncovered in trash pulls, and from inside the residence during the search warrant. Those message pads revealed numerous calls left at the house for Maxwell, indicating she was staying in the house during the days when Epstein was engaging in illegal sex acts with minors. Additionally, a walk through video taken during the execution of the search warrant revealed photos of topless females at the home, and there was even a photograph of Maxwell naked hanging in the home. The house staff who were deposed in the civil cases each testified to Maxwell being the boss in charge of everyone in the house. See McCawley Dec. at Exhibits 1, 55 Case 18-2868, Document 281, 08/09/2019, 2628234, Page56 of 66 19, 21, Banasiak Dep. Tr. at 8:21-9:16; 14:20-15:6; Alessi Dep. Tr. at 23:11-23:20; Rodriguez Dep. Tr. at 169:1-169:4. Rodriguez, the house butler from 2004 through 2005, a time period that revealed daily sexual abuse of underage females, testified that Maxwell kept a list of the local girls who were giving massages at her desk, and that Maxwell kept nude photos of girls on her computer. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 238:4-238:22; 302:19-303:10; 306:1306:24. Recarey testified that when the search warrant was executed, the house had been sanitized and the computers removed from the home. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 72:25-73:15. Banaziak testified that the computers were removed by Adriana Ross, another employee who answered to Maxwell. See McCawley Dec. at Exhibit 19, Banaziak Dep. Tr. at 54:7-22. The record is replete with testimony demonstrating that Maxwell recruited Virginia, and recruited other females, who in turn recruited other females, all who were sexually abuse by Epstein; meaning, it is undisputed that Maxwell started the top of the pyramid of local Palm Beach girls who were all eventually identified as victims. See, e.g., McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 34:19-35:3; 98:5-98:12; 104:15-104:23. The co-conspirator who maintained direct contact with the many underage victims was Sarah Kellen, whose sole responsibility was to schedule underage girls to visit Epstein for sex. Sarah reported directly to Maxwell. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 26:10-26:20. On the day when the search warrant was executed, the house maid, Ruboyo was scheduled to report to the house that day at 8 am; however, she received a call from Maxwell telling her not to go. See McCawley Dec. at Exhibit 20, Rabuyo Dep. Tr. at 81:20-82:25. Maxwell orchestrated and ran the entire sex 56 Case 18-2868, Document 281, 08/09/2019, 2628234, Page57 of 66 trafficking scheme from a high level, and insulated herself from most of the underage girls who were being paid for sex. Tony Figueroa, Ms. Giuffre's ex-boyfriend, did testify that Maxwell personally requested that he find and bring girls to Epstein for sex once Ms. Giuffre had escaped, and that when he brought the girls Maxwell interacted with them. See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 200:6-18; 228:23-229:21. Rodriguez testified unequivocally that Maxwell was "the boss" and that she knew everything that was going on. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. 169:1-169:4. DEFENDANT’S PURPORTED FACTS 49. No nude photograph of Ms. Giuffre was displayed in Epstein’s home. Epstein’s housekeeper, Juan Alessi, “never saw any photographs of Virginia Roberts in Mr. Epstein’s house.” Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This is false. Nude photographs were displayed throughout Epstein’s home. Furthermore, Alfredo Rodriguez testified to Maxwell having pornography on her computer . Rodriguez Dep. Tr. 150:10-17; 306:1-306:24. He also testified to there being a collage of nude photos in Epstein's closet. Id. 253:14-254:18. That collage was eventually taken into evidence by Detective Recarey, who testified to that fact in his deposition. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 73:19-73:24. And those photos are still in the possession of the FBI or US Attorney's Office. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 74:2-74:7. Numerous other people have testified about nude photographs being on display in the home including Ronaldo Rizzo, who visited the home on numerous occasions and who was reprimanded by Maxwell herself for looking at the nude photos. See McCawley Dec. at Exhibit 14, Rizzo Dep. Tr. at 25:19-26:20. Additionally, the search warrant video, taken at a time when 57 Case 18-2868, Document 281, 08/09/2019, 2628234, Page58 of 66 the house had already been sanitized, revealed photographs of nudity displayed, including a photograph of Maxwell herself in the nude. See McCawley Dec. at Exhibit 44, Search Warrant Video attached to the Deposition of Recarey. Johanna Sjorberg testified that the Defendant bought her a camera for the specific purpose of her taking nude photos of herself. See McCawley Dec. at Exhibit 16 Sjoberg Tr. at 150. Finally, Virginia Giuffre testified that there was a nude photograph of her at the house. See McCawley Dec. at Exhibit 5 Virginia Giuffre Tr. at 232 and 333. DEFENDANT’S PURPORTED FACTS 50. Ms. Giuffre intentionally destroyed her “journal” and “dream journal” regarding her “memories” of this case in 2013 while represented by counsel. Ms. Giuffre drafted a “journal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents in her possession. Id. Ms. Giuffre also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. To date, Ms. Giuffre cannot locate the “dream journal.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS The dream journal contained memories of Ms. Giuffre’s dreams. While Ms. Giuffre has looked for this journal, which is wholly irrelevant to this case, she has been unable to locate it. Ms. Giuffre also wrote in a personal journal some of her experiences with Maxwell and Epstein, which were harmful and painful. In an effort to relieve herself of those past painful experiences, Ms. Giuffre followed the advice of a therapist, and burned the journal as a form of cathartic release at a time when she was under no obligation to maintain the personal memorialization of personal and painful experiences. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 205:13206:10. 58 Case 18-2868, Document 281, 08/09/2019, 2628234, Page59 of 66 DEFENDANT’S PURPORTED FACTS 51. Ms. Giuffre publicly peddled her story beginning in 2011. Ms. Giuffre granted journalist Sharon Churcher extensive interviews that resulted in seven (7) widely distributed articles from March 2011 through January 2015. Churcher regularly communicated with Ms. Giuffre and her “attorneys or other agents” from “early 2011” to “the present day.” Ms. Giuffre received approximately $160,000 for her stories and pictures that were published by many news organizations. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Defendant's statement misrepresents history. In 2011, Ms. Giuffre was still in hiding from Epstein and Maxwell in Australia. Ms. Giuffre was not looking to sell anything or even speak with anyone about what had happened to her in her previous life from which she dramatically escaped. Journalist, Sharon Churcher, located Ms. Giuffre and impressed the importance of Ms. Giuffre standing up to those who had harmed her and speak with Federal authorities, which Ms. Giuffre did in 2011. See McCawley Dec. at Exhibit 31, Redacted 302 GIUFFRE001235-01246. In addition, Churcher impressed the importance of bringing the abuse of Defendant and Epstein to public light to prevent their continued abuse of others. See McCawley Dec. at Exhibit 35, Giuffre003690. After much deliberation, Ms. Giuffre agreed to be interviewed by Churcher, and was compensated for sharing her story, which came at a heavy price of being publicly scrutinized. DEFENDANT’S PURPORTED FACTS 52. Ms. Giuffre drafted a 144-page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, Ms. Giuffre drafted a book manuscript which purported to document Ms. Giuffre’s experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. Ms. Giuffre communicated with literary agents, ghost writers and potential independent publishers in an effort to get her book published. She generated marketing materials and circulated those along with book chapters to numerous individuals associated with publishing and the media. 59 Case 18-2868, Document 281, 08/09/2019, 2628234, Page60 of 66 MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Defendant’s characterization of these activities are out of context and thus misleading. In 2008, Ms. Giuffre received a Victim Notification Letter from the United States Attorney’s office for the Southern District of Florida, see McCawley Dec. at Exhibit 30, GIUFFRE0010202, regarding her sexual victimization by Epstein. Thereafter, in 2011, she sought psychological counseling from a psychologist for the trauma she endured. Also that year, journalist Sharon Churcher sought her out, and traveled half way around the globe to interview her on painful subjects. Ms. Giuffre was interviewed by the FBI in 2011. See McCawley Dec. at Exhibit 31, FBI Redacted 302 GIUFFRE01235-1246. She was also getting psychological help. See McCawley Dec. at Exhibit 38, Lightfoot Records, GIUFFRE005431-005438. In that situation, Ms. Giuffre began to draft a fictionalized account of what happened to her. It was against this backdrop of her trauma being unearthed, her steps to seek psychological counseling for it, that she drafted this manuscript. Doing so was an act of empowerment and a way of reframing and taking control over the narrative of her past abuse that haunts her. “Writing ‘I’ has been an emancipatory project for women.” Perreault, Jeanne, “AUTOGRAPHY/ TRANSFORMATION/ ASYMMETRY,” Women, Autobiography, Theory A Reader edited by Sidonie Smith & Julia Watson. Indeed, scholars have written that the act of engaging in autobiography or even accounts loosely based on autobiography, is a process of taking control of one’s own narrative and one’s own self: “Thus a specific recitation of identity involves the inclusion of certain identity contents and the exclusion of others; the incorporation of certain narrative itineraries and internationalities, the silencing of others; the adoption of certain autobiographical voices, the muting of others.” Smith, Sidonie, PERFORMATIVITY, 60 Case 18-2868, Document 281, 08/09/2019, 2628234, Page61 of 66 AUTOBIOGRAPHICAL PRACTICE, RESISTANCE, Women, Autobiography, Theory A Reader edited by Sidonie Smith & Julia Watson. Indeed, even a cursory look at the manuscript penned by Ms. Giuffre informs the reader that she is trying to put forth a more palatable and more empowering narrative to over-write that powerlessness she felt when being abused by Defendant and Epstein. While Ms. Giuffre explored trying to publish her story to empower other individuals who were subject to abuse, she ultimately decided not to publish it. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. 249:1618; 250:19-251:3. DEFENDANT’S PURPORTED FACTS 53. Ms. Giuffre’s publicly filed “lurid” CVRA pleadings initiated a media frenzy and generated highly publicized litigation between her lawyers and Alan Dershowitz. On December 30, 2014, Ms. Giuffre, through counsel, publicly filed a joinder motion that contained her “lurid allegations” about Ms. Maxwell and many others, including Alan Dershowitz, Prince Andrew, Jean-Luc Brunel. The joinder motion was followed by a “corrected” motion and two further declarations in January and February 2015, which repeated many of Ms. Giuffre’s claims. These CVRA pleadings generated a media maelstrom and spawned highly publicized litigation between Ms. Giuffre’s lawyers, Edwards and Cassell, and Alan Dershowitz. After Ms. Giuffre publicly alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called Ms. Giuffre a liar and accused her lawyers of unethical conduct. In response, attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Paragraph 7, supra, explaining why the allegations were necessary and appropriate for multiple reasons. Ms. Giuffre disputes Defendant’s false characterization of these events, and, indeed, the media attention was caused by Defendant’s is suing her defamatory press release. 61 Case 18-2868, Document 281, 08/09/2019, 2628234, Page62 of 66 DEFENDANT’S PURPORTED FACTS 54. Ms. Giuffre formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, Ms. Giuffre, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to Ms. Giuffre, the purpose of the organization is to promote Ms. Giuffre’s professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Ms. Giuffre attempts to promote Victims Refuse Silence at every opportunity. For example, Ms. Giuffre participated in an interview in New York with ABC to promote the charity and to get her mission out to the public. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre did not form the non-profit Victims Refuse Silence to "speak out on a public controversy," but instead to simply help survivors of sexual abuse and sexual trafficking. In order to provide assistance to victims, Ms. Giuffre attempted to talk about the non-profit’s mission when she had the opportunity to do so. See www.victimsrefusesilece.org. MS. GIUFFRE’S STATEMENT OF UNDISPUTED FACTS 55. Virginia Roberts was born August 9, 1983. See McCawley Dec. at Exhibit 51, Driver’s License GIUFFRE009209. 56. Virginia Roberts turned 18 on August 9, 2001. 57. In 2000, Virginia's father Sky Roberts worked at the Mar-a-Lago. See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 72, 74. 58. Sky Roberts got Virginia a job at Mar-a-Lago in 2000, either months before or just after Virginia's 17th birthday. See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 72, 74; Giuffre Dep. Tr. at 25:19-25:21; 28:10-28:12. 59. The only year in which Virginia was employed at Mar-a-Lago was 2000. See McCawley Dec. at Exhibit 49, MAR-A-LAGO 0173, 0176. 62 Case 18-2868, Document 281, 08/09/2019, 2628234, Page63 of 66 60. Virginia worked at Mar-a-Lago as a spa bathroom attendant. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 61:9-61:24; Austrich Dep. Tr. at 100:3-12. 61. Virginia was not a masseuse at Mar-a-Lago as she had no massage experience. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12; Austrich Dep. Tr. at 34-35, 100-101, 127-128; Figueroa Dep. Tr. at 82:10-15; 168:24-169:1; Sky Roberts Dep. Tr. at 80:7-19; 84:18 -85:1. 62. Maxwell approached Virginia at Mar-a-Lago, and recruited her to come to Jeffrey Epstein's house. See McCawley Dec. at Exhibits 1, 5, and 17, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12; Alessi Dep. Tr. at 94:24-95:2; Sky Roberts Dep. Tr. at 80:7-19; 84:18 -85:1. 63. At the time Maxwell recruited Virginia to Jeffrey Epstein's house, Virginia was either 16 or 17 years old, depending on whether this occurred just before or just after Virginia's birthday. See McCawley Dec. at Exhibit 49, MAR-A-LAGO 0173, 0176. 64. Virginia followed Maxwell's instructions and reported to Jeffrey Epstein's house on the night of the day when Maxwell approached Virginia at Mar-a-Lago. See McCawley Dec. at Exhibits 5 and 18, Giuffre Dep. Tr. at 117:20-118:1; Alessi Dep. Tr. at 96-98; GIUFFRE000102-103 at p. 48-49. 65. Maxwell told Virginia at Mar-a-Lago that Virginia could get paid for giving a massage to Jeffrey Epstein. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12. 66. When Virginia arrived at Epstein's house, she was taken upstairs to Epstein's bedroom, and instructed by Maxwell and Epstein how to give Epstein a massage. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18; Epstein Dep. Tr. at 74:3-14. 63 Case 18-2868, Document 281, 08/09/2019, 2628234, Page64 of 66 67. Epstein and Maxwell turned the massage into a sexual encounter. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18. 68. Virginia was not a professional masseuse, and was not old enough to be a masseuse in Florida even though Maxwell testified she only hired professional masseuses. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 61:9-61:24, 111:12-111:21, 116:19-117:12; Fla. Stat. § 480.041; Maxwell Dep. Tr. at 23:21-24:9; 31:6-18; 41:7-13; 220:13-221:2; 225:23226:20; 248:5-16; 310:6-17; 383:2-18. 69. Maxwell and Epstein promised Virginia money and a better life in exchange for complying with their sexual demands. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18. 70. Maxwell had sex with Virginia and other females. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 138:17-139:16; Maxwell 07-22-2016 Dep. Tr. at 86:25-87:9; 91:15-91:21. 71. Virginia was trafficked nationally and internationally for sexual purposes. See McCawley Dec. at Exhibits 5, 1, 41? GIUFFRE007055-007161 (Flight Logs); Giuffre Dep. Tr. at 193:22-194:16; 201:24; 204:24:205:5; Alessi Dep. Tr. at 104:9-104:14; Andrew Photo GIUFFRE007167; Spain Photo GIUFFRE007166. 72. Maxwell recruited other non-professionals under the guise of being a masseuse, but in reality only recruited girls for sexual purposes. See McCawley Dec. at Exhibits 5, 16, 4, 1, 18 Giuffre Dep. Tr. at 198:20-199:3; Sjoberg Dep. Tr. at 13-15; Figueroa Dep. Tr. at 88:12-22; Alessi Dep. Tr. at 34; GIUFFRE000105 at 57-58; GIUFFRE000241-242 at p. 212-213. 73. Maxwell was the boss of others whose job it was to recruit minor females for Epstein for sex, such as Sarah Kellen. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 26:10-26:20. 64 Case 18-2868, Document 281, 08/09/2019, 2628234, Page65 of 66 74. Maxwell was a recruiter of underage girls and other young females for Epstein for sex, and was the boss in charge of those females. See McCawley Dec. at Exhibits 16, 4, 21, and 1, Sjoberg Dep. Tr. 8-9, 13-15, 27; Figueroa Dep. Figueroa Dep. Tr. at 200:6-18; 228:23-229:21; Rodriguez Dep. Tr. 169:1-169:4; Alessi Dep. Tr. at 23:11-23:20; 34:19-35:3; 98:5-98:12; 104:15-104:23. Dated: January 31, 2017 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-52021 1 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 65 Case 18-2868, Document 281, 08/09/2019, 2628234, Page66 of 66 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 31, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: lmenninger@hmflaw.com jpagliuca@hmflaw.com /s/ Sigrid S. McCawley Sigrid S. McCawley 66 Case 18-2868, Document 282, 08/09/2019, 2628236, Page1 of 8 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT AND UNDISPUTED FACTS I, Sigrid McCawley, declare that the below is true and correct to the best of my knowledge as follows: 1. I am a Partner with the law firm of Boies, Schiller & Flexner LLP and duly licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my Application to Appear Pro Hac Vice. 2. I respectfully submit this Declaration in Support of Plaintiff’s Response to Defendant’s Motion for Summary Judgment and Undisputed Facts. 3. Attached hereto as Sealed Exhibit 1 are true and correct copies of Excerpts from June 1, 2016 Depositions of Juan Alessi. 4. Attached here to as Sealed Exhibit 2 is a true and correct copy of Excerpts from June 23, 2016, Deposition of James Austrich. 5. Attached hereto as Sealed Exhibit 3 is a true and correct copy of Excerpts from September 9, 2016, Deposition of Jeffrey Epstein. 6. Attached hereto as Sealed Exhibit 4 is a true and correct copy of Excerpts from June 24, 2016, Deposition of Tony Figueroa (Volumes I and II). Case 18-2868, Document 282, 08/09/2019, 2628236, Page2 of 8 7. Attached hereto as Sealed Composite Exhibit 5 are true and correct copies of Excerpts from May 3, 2016 and November 14, 2016, Deposition of Virginia Giuffre. 8. Attached hereto as Sealed Exhibit 6 is a true and correct copy of Excerpts from November 18, 2016, Deposition of Ross Gow. 9. Attached hereto as Sealed Exhibit 7 is a true and correct copy of Excerpts from June 20, 2016, Deposition of 10. . Attached hereto as Sealed Exhibit 8 is a true and correct copy of Excerpts from January 25, 2017, Deposition of Sarah Kellen. 11. Attached hereto as Sealed Exhibit 9 is a true and correct copy of Excerpts from November 29, 2016, Deposition of Peter Kent. 12. Attached hereto as Sealed Exhibit 10 is a true and correct copy of Excerpts from January 17, 2017, Deposition of Nadia Marcinko. 13. Attached hereto as Sealed Composite Exhibit 11 are true and correct copies of Excerpts from April 22, 2016 and July 22, 2016, Depositions of Ghislaine Maxwell. 14. Attached hereto as Sealed Exhibit 12 is a true and correct copy of Excerpts from May 24, 2016, Deposition of Lynne Trudy Miller 15. Attached hereto as Sealed Exhibit 13 is a true and correct copy of Excerpts from June 21, 2016, Deposition Joseph Recarey. 16. Attached hereto as Sealed Exhibit 14 is a true and correct copy of Excerpts from June 10, 2016, Deposition of Rinaldo Rizzo. 17. Attached hereto as Sealed Exhibit 15 is a true and correct copy of Excerpts from June 3, 2016, Deposition of David Rodgers. 18. Attached hereto as Sealed Exhibit 16 is a true and correct copy of Excerpts from May 18, 2016, Deposition of Johanna Sjoberg. 2 Case 18-2868, Document 282, 08/09/2019, 2628236, Page3 of 8 19. Attached hereto as Sealed Exhibit 17 is a true and correct copy of Excerpts from May 20, 2016, Deposition of Sky Roberts. 20. Attached hereto as Sealed Composite Exhibit 18 are true and correct copies of Excerpts from September 8, 2009, Depositions of Juan Alessi (GIUFFRE000102-000103; GIUFFRE000105; GIUFFRE000241-000242). 21. Attached hereto as Sealed Exhibit 19 is a true and correct copy of Excerpts from February 16, 2010, Deposition of Janusz Banasiak (GIUFFRE004431-004432; GIUFFRE004437-004438; GIUFFRE004477). 22. Attached hereto as Sealed Exhibit 20 is a true and correct copy of Excerpts from October 20, 2009, Deposition of Louella Rabuyo (GIUFFRE004386). 23. Attached hereto as Sealed Composite Exhibit 21 is a true and correct copy of Excerpts from July 29, 2009 and August 7, 2009, Deposition of Alfredo Rodriguez (GIUFFRE000936-000937; GIUFFRE000942; GIUFFRE000953-000954; GIUFFRE000974; GIUFFRE000978; GIUFFRE000996; GIUFFRE000999-001000; GIUFFRE001003). 24. Attached hereto as Sealed Exhibit 22 is a true and correct copy of August 1, 2016, Defendant’s Privilege Log. 25. Attached hereto as Sealed Exhibit 23 is a true and correct copy of September 15, 2016, Expert Report of Professor Terry Coonan. 26. Attached hereto as Sealed Exhibit 24 is a true and correct copy of September 15, 2016, Expert Report of Doctor Bernard Jansen. 27. Attached hereto as Sealed Exhibit 25 is a true and correct copy of November 28, 2016, Expert Report of Peter Kent 28. Attached hereto as Sealed Exhibit 26 is a true and correct copy of January 2, 2015, Email Correspondence (GM_00068). 3 Case 18-2868, Document 282, 08/09/2019, 2628236, Page4 of 8 29. Attached hereto as Sealed Exhibit 27 is a true and correct copy of Excerpts of Palm Beach School County Records (GM_00888-00898). 30. Attached hereto as Sealed Exhibit 28 is a true and correct copy of Excerpts of Message Pads (GIUFFRE001388; GIUFFRE001409; GIUFFRE001412-4213; GIUFFRE001417-18, GIUFFRE001421; GIUFFRE001423; GIUFFRE001426-1428; GIUFFRE001432-1433; GIUFFRE001435; GIUFFRE001446; GIUFFRE001448-1449; GIUFFRE001452-1454; GIUFFRE001456; GIUFFRE001462; GIUFFRE001474; GIUFFRE001563). 31. Attached here to as Sealed Exhibit 29 is a true and correct copy of Epstein’s Black Book (GIUFFRE001573-GIUFFRE001669). 32. Attached hereto as Sealed Exhibit 30 is a true and correct copy of September 3, 2008, U.S. Attorney Victim Notification Letter (GIUFFRE002216-002218). 33. Attached hereto as Sealed Exhibit 31 is a true and correct copy of July 5, 2013, Federal Bureau of Investigation Interview (GIUFFRE001235-001246). 34. Attached hereto as Sealed Exhibit 32 is a true and correct copy of Handwritten Note from Defendant. (GIUFFRE003191-003192). 35. Attached hereto as Sealed Exhibit 33 is a true and correct copy of July 2001 New York Presbyterian Hospital Records (GIUFFRE003258-003290). 36. Attached hereto as Sealed Exhibit 34 is a true and correct copy of a February 17, 2011, Email Correspondence to Sharon Churcher (GIUFFRE003678). 37. Attached hereto as Sealed Exhibit 35 is a true and correct copy of February 13, 2011, Email Correspondence to Sharon Churcher (GIUFFRE003690). 38. Attached hereto as Sealed Exhibit 36 is a true and correct copy of February 25, 2011, Email Correspondence to Sharon Churcher (GIUFFRE003731).) 39. Attached hereto as Exhibit 37 is a true and correct copy of a Passport Application 4 Case 18-2868, Document 282, 08/09/2019, 2628236, Page5 of 8 (GIUFFRE004721). 40. Attached hereto as Sealed Exhibit 38 is a true and correct copy of Judith Lightfoot Psychological Records (GIUFFRE005431-005438). 41. Attached hereto as Sealed Exhibit 39 is a true and correct copy of July 25, 2006, Palm Beach Police Department Incident Report (GIUFFRE005614-005700). 42. Attached hereto as Sealed Exhibit 40 is a true and correct copy of an Amazon Receipt (GIUFFRE006581). 43. Attached hereto as Sealed Exhibit 41 is a true and correct copy of David Rodger’s June 3, 2016, Deposition Exhibit 1, Flight Log, (GIUFFRE007055-007161). 44. Attached hereto as Sealed Exhibit 42 are true and correct copies of Photographs (GIUFFRE007162-7182). 45. Attached hereto as Sealed Exhibit 43 is a true and correct copy of Travel Documents to Thailand (GIUFFRE007411-GIUFFRE007432). 46. Attached hereto as Sealed Exhibit 44 is a true and correct copy of Walkthrough Video CD (GIUFFRE007584). 47. Attached hereto as Sealed Exhibit 45 is a true and correct copy of West Palm Beach Contact List (GIUFFRE007834-GIUFFRE007847). 48. Attached hereto as Sealed Exhibit 46 is a true and correct copy of October 23, 2016, Social Security Administration records (GIUFFRE009176-GIUFFRE009179). 49. Attached hereto as Sealed Exhibit 47 is a true and correct copy of November 7, 2016, Employment Records from Courtyard Animal Hospital (GIUFFRE009203). 50. Attached hereto as Sealed Exhibit 48 is a true and correct copy of January 2, 2015, Email Correspondence (RG (UK) _000009). 51. Attached hereto as Sealed Exhibit 49 are true and correct copies of Termination 5 Case 18-2868, Document 282, 08/09/2019, 2628236, Page6 of 8 Documents (MAR-A-LAGO 0173 & MAR-A-LAGO 0176). 52. Attached hereto as Sealed Exhibit 50 is a true and correct copy of January 2, 2015, Joinder Motion (GIUFFRE000319-000333). 53. Attached hereto as Sealed Exhibit 51 is a true and correect copy of Virginia Roberts Driver License (GIUFFRE009209). I declare under penalty of perjury that the foregoing is true and correct. /s/ Sigrid McCawley______________ Sigrid McCawley, Esq. 6 Case 18-2868, Document 282, 08/09/2019, 2628236, Page7 of 8 Dated: January 31, 2017. Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-52021 1 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 7 Case 18-2868, Document 282, 08/09/2019, 2628236, Page8 of 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 31st day of January, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: lmenninger@hmflaw.com jpagliuca@hmflaw.com /s/ Sigrid McCawley Sigrid McCawley 8 CQQP 18-7868, 782, 08/09/7010, 7678741, Pagm nf EXHIBIT 1 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page2 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 1, 2016 9:12 a.m. C O N F I D E N T I A L Deposition of JOHN ALESSI, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 18-2868, Document 283, 08/09/2019, 2628241, Page3 of 883 Page 9 1 JOHN ALESSI 2 Q. You're ready to start, correct? 3 A. Yes. 4 Q. Can you tell us your current address? 5 A. 6 Florida 33472. 7 Q. 8 A. 9 Q. 10 Boynton Beach, And your date of birth? . And was there a time when you worked for a man named Jeffrey Epstein? 11 A. Yes. 12 Q. And can you tell us when you began working 13 14 for Mr. Epstein? A. I began working for Mr. Epstein part-time. 15 I cannot exactly tell you the date, but it was 16 1990/'91, probably. 17 for him. 18 19 Q. Okay. I worked a total of 13 years So you began in 1990 part-time, correct? 20 A. Right. 21 Q. And you stopped working for him when? 22 A. I stopped working for him on 23 December 31st, 2001. I was out -- yes, 2001. 24 Q. Okay. 25 A. The end of 2001. I left the last day of Case 18-2868, Document 283, 08/09/2019, 2628241, Page4 of 883 Page 10 1 2 JOHN ALESSI the year. 3 Q. Okay. I know that it's been a long time. 4 A. It's been a long time. 5 Q. I know. So I'm going to ask that you 6 refer to the statement that you provided to the 7 police November 21st, 2005, and please go to page 5. 8 I just want you to start reading at line 2 and 3, 9 and tell me if that refreshes your recollection as 10 to your time or duration of employment. 11 A. You're right. 12 Q. So sometime in 1990, you were a part-time 13 It was 2002, then. 2002. employee? 14 A. Uh-huh. 15 Q. And you worked until December 31st, 2002; 16 is that right? 17 A. Yes. 18 Q. Okay. And is it also correct that you 19 began full-time employment with Mr. Epstein on 20 January 1st, 1991, as stated in that report? 21 A. Yes. 22 Q. Prior to 1990, who did you work for? 23 A. Prior to 1990, I had a company, a 24 maintenance company, myself, my own company, Alessi 25 Maintenance. And before that, I worked for another Case 18-2868, Document 283, 08/09/2019, 2628241, Page5 of 883 Page 11 1 2 JOHN ALESSI family, the Radi family in Palm Beach. 3 Q. 4 Wexner? 5 A. 6 Did you ever work for a man named Les I did some work for him in his mother's house. 7 Q. Where was that? 8 A. Palm Beach. 9 10 11 Q. Is that who recommended that you work for Jeffrey Epstein? A. I guess so. 13 Q. Okay. 15 Before -- before I came to work for Jeffrey. 12 14 What year? When you started with Jeffrey Epstein, what were your job duties? A. I was doing maintenance. I was doing 16 building and rebuilding and maintenance work 17 basically. 18 time. 19 recommend me to go to the house and take a look at 20 the house. 21 basically, at the beginning of my job. Because he just bought the house at that And because of Mr. Wechsler knowing me, they And we start tearing the house down, 22 Q. Did you assist in the teardown? 23 A. Yes. 24 Q. Okay. 25 a maintenance? So your job duties then was that of Case 18-2868, Document 283, 08/09/2019, 2628241, Page6 of 883 Page 12 1 JOHN ALESSI 2 A. Maintenance, building. 3 Q. Got it. 4 5 And did you meet Mr. Epstein when you were -- in 1990? 6 A. Yes, I met him. 7 Q. Okay. 8 And in 1991, who made the decision for you to become a full-time employee? 9 A. Jeffrey. 10 Q. And as a full-time employee initially, 11 12 what was your job? A. I was basically maintenance, the same 13 thing as I was doing with -- I was exclusively 14 working for him. 15 maintenance, because the house was still on 16 renovation, and he wanted me there. 17 18 Q. Okay. I was full-time working for him as And how was your relationship with Mr. Epstein back then, 1991? 19 A. Great. 20 Q. It was good? 21 A. It was good. 22 Q. Did he have a girlfriend back then, in 23 24 25 No problem. 1991? MR. PAGLIUSCA: foundation. Object to the form and Case 18-2868, Document 283, 08/09/2019, 2628241, Page7 of 883 Page 13 1 JOHN ALESSI 2 You can answer the question. 3 Occasionally, I'll need to object for the 4 record in case we need to have a discussion 5 about this with the judge. 6 me preserving those objections. 7 THE WITNESS: And so that's just Yes, he had a girlfriend. 8 Her name was Dr. Andersson, Eva Andersson. 9 she was there just for a few months after I 10 11 came to the house. BY MR. EDWARDS: 12 13 And Q. And how was your relationship with Dr. Andersson? 14 A. Fine. 15 Q. Okay. And at the time when Mr. Epstein 16 was -- at the time when Dr. Andersson was Jeffrey 17 Epstein's girlfriend, did you see any other female 18 companions around the house? 19 A. Eventually -- they have a lot of guests, 20 too. 21 remember exactly who. 22 have friends. 23 They did have guests coming in. Q. But I can't It's a socialite. So they At the time when Dr. Andersson was 24 Mr. Epstein's girlfriend, was Mr. Epstein getting 25 massages? Case 18-2868, Document 283, 08/09/2019, 2628241, Page8 of 883 Page 14 1 JOHN ALESSI 2 3 MR. PAGLIUSCA: Object to the form and foundation. 4 THE WITNESS: I think so. I was not 5 involved in the house, inside of the house that 6 much. 7 BY MR. EDWARDS: 8 9 Q. But they always got massages. Okay. Always. I'm talking about the time period when Dr. Andersson was there. 10 A. Yes, they got massages. 11 Q. Okay. So do you remember other female 12 visitors when Dr. Andersson was Mr. Epstein's 13 girlfriend? 14 A. 15 16 I don't remember. I remember people being there, visitors, but I cannot remember that far. Q. Okay. After -- did there come a point in 17 time when Dr. Andersson was no longer Mr. Epstein's 18 girlfriend? 19 A. Right. 20 Q. Yes? 21 A. Yes. 22 Q. And did he -- did he have a new 23 girlfriend? 24 25 MR. PAGLIUSCA: foundation. Object to form and Case 18-2868, Document 283, 08/09/2019, 2628241, Page9 of 883 Page 23 1 2 JOHN ALESSI Q. 3 All right. Who was in charge of the Palm Beach house? 4 A. I was. 5 Q. All right. 6 7 8 9 10 11 12 Who was your direct supervisor? A. Mr. Epstein. He would deal with me directly, or if he was not available, Ms. Maxwell. Q. Okay. I want you to go to Exhibit 3 and page -- page 179, line 8. A. Line 8, "QUESTION: And then Maxwell came and she took over you as your immediate supervisor? 13 Yes. That's correct. Yes. She became 14 the supervisor not only for this house, but for all 15 the homes. 16 Q. Okay. 17 Ms. Maxwell? 18 A. So your immediate supervisor was Ms. Maxwell. But if Mr. Epstein was at 19 the house, I would never go to Ms. Maxwell; I would 20 go to him directly, or he would come to me. 21 Q. Okay. At some point in time towards the 22 end of your tenure, did you come to resent 23 Ms. Maxwell? 24 25 MR. PAGLIUSCA: foundation. Object to the form and Case 18-2868, Document 283, 08/09/2019, 2628241, Page10 of 883 Page 28 1 2 3 4 5 6 JOHN ALESSI Q. And where did the massage therapists -- where did they come from? A. Most, they came from Palm Beach. Palm Beach County. Q. And over the course of that 10-year period 7 of time while Ms. Maxwell was at the house, do you 8 have an approximation as to the number of different 9 females -- females that you were told were massage 10 therapists that came to the house? 11 MR. PAGLIUSCA: 12 Object to form and foundation. 13 THE WITNESS: I cannot give you a number, 14 but I would say probably over 100 in my stay 15 there. 16 BY MR. EDWARDS: 17 Q. And many of the times would the females 18 come only one time and not return? 19 MR. PAGLIUSCA: 20 21 22 23 Object to form and foundation. BY MR. EDWARDS: Q. Let me ask that a different way. Were there times when some of these 24 females that would come to the house, and you were 25 told that they were massage therapists, would come Case 18-2868, Document 283, 08/09/2019, 2628241, Page11 of 883 Page 30 1 2 3 4 5 JOHN ALESSI BY MR. EDWARDS: Q. Okay. And who would find the massage therapist to bring to the house? A. They would call me in my office, and they 6 would say, Get me a massage at 10:00 with this 7 person. 8 9 I have a list of the massage therapists, a Rolodex, or a card, and I would call them for the 10 specific time they want a massage. 11 that. 12 Q. And I would do I don't think I asked the right -- the 13 question that I was looking to ask, so let me go 14 back. 15 Did you go out looking for the girls -- 16 A. No. 17 Q. -- to bring -- 18 A. Never. 19 Q. -- as the massage therapists? 20 A. Never. 21 Q. Who did? 22 A. Ms. Maxwell, Mr. Epstein and their 23 friends, because their friends relayed to other 24 friends they knew a massage therapist and they would 25 send to the house. So it was referrals. Case 18-2868, Document 283, 08/09/2019, 2628241, Page12 of 883 Page 34 1 JOHN ALESSI 2 foundation. 3 happening in this deposition, because the word 4 "recruit" was introduced by the lawyers in this 5 deposition. 6 characterization of the testimony. 7 Hold on. That misstates what is So I object to your BY MR. EDWARDS: 8 Q. 9 answer. 10 I'll read for you the question and the The question was: "QUESTION: When did 11 that role get transferred from you to Ms. Maxwell, 12 the role of looking after girls or calling the 13 girls? 14 "ANSWER: I didn't look after -- out for 15 girls. 16 remember one occasion or two occasions she would say 17 to me, John, give me a list of all the spas in Palm 18 Beach County, and I will drive her from one to the 19 other to PGA in Boca; and she would go in and drop 20 credit cards -- not credit cards but business cards, 21 and she would come out. And then we'd go to -- she 22 will recruit the girls. Was never, never done by me 23 or Mr. Epstein or anyone else that I know of." 24 25 Ms. Maxwell was the one that recruit. Is that truthful testimony? A. It is truthful; however, I think I Case 18-2868, Document 283, 08/09/2019, 2628241, Page13 of 883 Page 35 1 JOHN ALESSI 2 "recruiting," for myself, for my point of view, is 3 hiring immediately and recruit the person. 4 I think she was looking for massage 5 therapists. 6 went -- and you're right, I went one time with her, 7 or twice maybe, to different spas and different 8 clubs, great clubs, I mean, in Boca, in Fort 9 Lauderdale, in -- in Palm Beach. 10 She was looking for the best kind. She was looking for the best massage therapists available. 11 How she find these girls, I don't know. 12 just drove there. 13 was involved with any of the offerings or 14 negotiations or meeting these girls. 15 16 Q. Okay. I just was the driver. I I never Never. Ms. Maxwell was the one that would meet the girls? 17 A. Yeah. 18 Q. Okay. 19 She Did you ever check any of the IDs for any of these girls? 20 A. 21 things to do. 22 Q. That was just not part of your job? 23 A. That was not my job. 24 Q. Did Ms. Maxwell take photographs while she 25 I was not -- that was not in my everyday It was not. was at the Palm Beach house? Case 18-2868, Document 283, 08/09/2019, 2628241, Page14 of 883 Page 52 1 JOHN ALESSI 2 3 MR. PAGLIUSCA: foundation. 4 5 6 7 Object to form and THE WITNESS: Himself. Himself. BY MR. EDWARDS: Q. And you do not know the ages of the various massagists, right? 8 A. No. 9 Q. Did you have occasion to clean up after 10 the massages? 11 A. Yes. 12 Q. Okay. And that is after both a massage 13 for Jeffrey Epstein, as well as clean up after a 14 massage that Ghislaine Maxwell may have received? 15 A. Yes. 16 Q. And on occasion, after -- in cleaning up 17 after a massage of Jeffrey Epstein or Ghislaine 18 Maxwell, did you have occasion to find vibrators or 19 sex toys that would be left out? 20 21 MR. PAGLIUSCA: foundation. 22 23 24 25 Object to form and THE WITNESS: Yes, I did. BY MR. EDWARDS: Q. Can you describe the types of vibrators or sex toys that you found left out after a massage Case 18-2868, Document 283, 08/09/2019, 2628241, Page15 of 883 Page 53 1 JOHN ALESSI 2 that Jeffrey Epstein had just received or Ghislaine 3 Maxwell had just received? 4 5 MR. PAGLIUSCA: Object to form and foundation. 6 THE WITNESS: It was probably two to three 7 times, I would say. It was not all the time. 8 I would find things like a dildo, it's called a 9 double. I hate to say it because these ladies. 10 But I find these things, put my gloves on, took 11 it out and rinse it, and put it in 12 Ms. Maxwell's closet. 13 14 15 16 17 18 19 BY MR. EDWARDS: Q. Why would you put the dildo or sex toy in Ms. Maxwell's closet? A. Because I knew that's where they were kept. Q. How did you know that the sex toys were kept in Ms. Maxwell's closet? 20 A. 21 that house. 22 it was a place, it was placed by me, by the cleaning 23 lady or my wife. 24 in that house, I knew it. 25 Q. Because I know where everything was in Every single room, every single thing, Every -- everything that happened Who showed you where the dildo or sex toys Case 18-2868, Document 283, 08/09/2019, 2628241, Page16 of 883 Page 54 1 2 JOHN ALESSI were kept in the house the first time? 3 4 MR. PAGLIUSCA: foundation. 5 6 Object to form and THE WITNESS: Nobody. Nobody show me. BY MR. EDWARDS: 7 Q. You just saw it? 8 A. I saw it. 9 Q. So you knew where to put it back? 10 A. Yeah. We had to open the closet, clean 11 the closet, put the clothes in place, put the shoes 12 in place, put everything in place. 13 matter of tidying things up. So it was a 14 Q. Did you ever find any costumes? 15 A. I saw one shiny black costume, but I 16 didn't even know -- 17 Q. Where did you see it? 18 A. The same place. 19 Q. In Ms. Maxwell's closet? 20 A. Yes. 21 Q. And where was Ms. Maxwell's closet in the 22 23 house? A. In the house? 24 of his bathroom. 25 bedroom. It was in the opposite side It was her bathroom in the master It was in the middle. So it was on the Case 18-2868, Document 283, 08/09/2019, 2628241, Page17 of 883 Page 94 1 2 3 4 JOHN ALESSI BY MR. EDWARDS: Q. That demonstrates that she was, I believe, terminated from her employment in 2000. 5 My question to you is: Do you remember 6 what time of year or what month it would have been, 7 whether spring, summer, fall, winter; January, 8 February, December? 9 A. Of what year? 10 Q. Of 2000, that you would have gone to the 11 Mar-a-Lago? 12 A. 13 14 15 16 17 It wasn't 2000. MR. PAGLIUSCA: foundation. BY MR. EDWARDS: Q. Okay. A. Yes. 19 Q. Okay. 21 22 Do you think it was a different year that you went to Mar-a-Lago? 18 20 Object to form and What year do you believe that you went to the Mar-a-Lago to pick Virginia up? A. I think it was 2000 and -- I think it was the summer of 2002. 23 Q. Okay. 24 A. Summer, because I remember that day that I 25 was sweating like hell in the -- in the car, waiting Case 18-2868, Document 283, 08/09/2019, 2628241, Page18 of 883 Page 95 1 2 3 4 JOHN ALESSI for Ms. Maxwell to come out of the massage. Q. Okay. So what month of the summer do you remember it being? 5 A. I think in June, July, maybe, 2001. 6 Q. 2000 and what? 7 A. 2001. 8 Q. June, July, 2001, that's when you believe 9 that it was? 10 A. Yes. 11 Q. Okay. 12 A. No, sorry. And do you remember the month -Sorry. Not 2001. We left in 13 December 31st. 14 was working for Jeffrey, when I met Virginia. 15 16 Q. It was 2000 -- the last year that I Your recollection, as you sit here today -- 17 A. It was 2002. 18 Q. -- is that it was June or July of 2002 -- 19 A. 2002. 20 Q. -- when you met Virginia Roberts at the 21 Mar-a-Lago? 22 A. My recollection. 23 Q. Okay. And other than the fact that you 24 were sweating, what else tells you what month that 25 it was that you remember meeting her at the Case 18-2868, Document 283, 08/09/2019, 2628241, Page19 of 883 Page 96 1 JOHN ALESSI 2 Mar-a-Lago? 3 A. It was -- I know it was summer of 2002, 4 and she spoke to -- far away. I wasn't -- I was in 5 the driveway, and she was far away talking to 6 Virginia. She spoke to her maybe five minutes. 7 Q. Okay. 8 A. And she came to the car, and we went home. 9 10 In the afternoon, about 4:00 or 5:00 in the afternoon, the same day, Virginia came to the house. 11 Q. Who brought her to the house? 12 A. I don't know. 13 I remember. 14 came to the house. 15 Q. She came to the back door, And she was dressed differently. She When you first arrived to the Mar-a-Lago 16 with -- are you driving the car and Ms. Maxwell is 17 in the passenger seat? 18 A. Yes. 19 Q. And could you see Virginia Roberts from 20 the car? 21 A. Yes. 22 Q. Where was she sitting or standing? 23 24 25 How far away from the car? A. driveway. She was standing right in front of the This is the Mar-a-Lago, the house, and Case 18-2868, Document 283, 08/09/2019, 2628241, Page20 of 883 Page 97 1 JOHN ALESSI 2 here is the spa, and the driveway that's here. 3 was parked this way, and I would see her with 4 Ms. Maxwell, talking. I 5 Q. Did you -- 6 A. I could not hear what they were saying, 7 but I did see it. 8 Q. 9 there and -- 10 A. 11 12 Did you park the car or did you stop right I parked the car because we are not allowed to go into Mar-a-Lago. Q. 13 Okay. Let me finish my question. Did you park the car in a parking space in 14 the parking lot or did you just stop on the side of 15 the road and Ms. Maxwell got out? 16 A. Mar-a-Lago has a -- has a long wide 17 driveway, and on the right of the driveway is -- is 18 the parking spots like this or something. 19 parked in one of those spaces. 20 I think it was over an hour that I wait for her. 21 22 23 24 25 Q. Okay. And I And waiting for her, So did you watch her first talk to -A. No. At the end. Right at the end, before -- when she was leaving. Q. So Ms. Maxwell gets out of the car. And Case 18-2868, Document 283, 08/09/2019, 2628241, Page21 of 883 Page 98 1 JOHN ALESSI 2 when you're pulling up to the Mar-a-Lago, could you 3 see Virginia Roberts then? 4 A. No. No. 5 Q. So after you wait an hour, Ms. Maxwell is 6 coming out? 7 A. And then she saw Virginia and she 8 stopped -- she went to her, she talked to her, she 9 came back to the car. 10 11 Q. And prior to that day, you had never seen Virginia at the house? 12 A. Never. 13 Q. Okay. 14 Never. Did Ms. Maxwell tell you that Virginia's father worked at the Mar-a-Lago? 15 A. I don't think so. I think it was -- I 16 think we find out later, after the -- she says, My 17 father works -- I think it was from Virginia, that 18 she says her father works at Mar-a-Lago. 19 It is information from her. I don't think 20 it was Ms. Maxwell that told me anything. 21 have to -- she don't have to talk to me. 22 Ms. Maxwell will not go and talk to me about this -- 23 these people's family. 24 did. 25 Q. Okay. I don't know. She don't I mean, She never I only have to go by what I have. Case 18-2868, Document 283, 08/09/2019, 2628241, Page22 of 883 Page 103 1 JOHN ALESSI 2 3 4 5 I don't remember that day, how she got home. I don't know. Q. I can't remember. After that day, do you recall that she started coming to the house more frequently? 6 A. Yes, she did. 7 Q. In fact, did she start coming to the house 8 approximately three times a week? 9 A. Yes, probably. 10 Q. And at times, would you go pick her up? 11 A. Yes. 12 This happened maybe twice, three times. 13 Q. And at times, would you take her home? 14 A. Yes. 15 Q. And did there come a point in time where 16 Virginia starting bringing other girls with her? 17 18 MR. PAGLIUSCA: Object to form and foundation. 19 THE WITNESS: That was maybe two weeks 20 before we left. 21 friends with her to the house. 22 remember how many times, but I was at the end 23 of our stay. 24 25 I saw her bringing some And I cannot BY MR. EDWARDS: Q. At the end of her [sic] stay, you saw when Case 18-2868, Document 283, 08/09/2019, 2628241, Page23 of 883 Page 104 1 JOHN ALESSI 2 she would come over to the house, she would bring 3 certain friends who were girls -- 4 MR. PAGLIUSCA: 5 6 Object to form and foundation. BY MR. EDWARDS: 7 Q. -- to the house, right? 8 A. Yes, females, yes. 9 Q. Do you know how long Virginia had been 10 coming over to the house before she started 11 traveling on an airplane with Ghislaine and Jeffrey? 12 MR. PAGLIUSCA: 13 THE WITNESS: 14 15 16 17 18 Object to foundation. Not too long. I don't think it was too long after that. BY MR. EDWARDS: Q. Would you drive her to the airport with them? A. Occasionally, I think so, yes. I would 19 drive everybody to the airport. 20 the chefs, the service people, the luggage to Jet 21 Aviation. 22 23 Q. My wife would drive Is that where Mr. Epstein kept his plane, Jet Aviation? 24 A. Yes. 25 Q. At some point did Ghislaine Maxwell become Case 18-2868, Document 283, 08/09/2019, 2628241, Page24 of 883 Page 141 1 JOHN ALESSI 2 MR. PAGLIUSCA: Seven. 3 MR. EDWARDS: 4 (The referred-to document was marked by Seven? 5 the court reporter for Identification as 6 Deposition Exhibit 7.) 7 MR. EDWARDS: 8 MR. PAGLIUSCA: 10 MR. EDWARDS: I have it. Okay. BY MR. EDWARDS: 12 Q. 13 four pages. 14 should be -- do you have SAO 01456? 15 MR. PAGLIUSCA: 16 MR. EDWARDS: 17 20 21 22 23 24 25 So this is a composite exhibit. It is The first one that you're looking at Yes. Okay. BY MR. EDWARDS: 18 19 I just can't find a copy right now. 9 11 I apologize, Jeff. Q. Does the format of this look familiar to A. Yes. you? It looks like the books that we used to have that has -- the message books. Q. How would that work? How would that process work? A. Somebody called, you write it down, and you take the -- you leave the copy in the -- in the Case 18-2868, Document 283, 08/09/2019, 2628241, Page25 of 883 Page 175 1 JOHN ALESSI 2 many things? 3 A. Yes, she did. 4 Q. Interesting buildings? 5 A. No. She -- she liked -- she had a dog, 6 and she took a lot of photographs of her dog. 7 us. 8 house. 9 photographs of people, young girls, girls. 10 11 And she took photographs of the cars and the Everything inside. remember that she had. Q. 12 13 And She had an album full of And I Like a hobby. Right. You never saw any pictures that were very upsetting to you, though, correct? 14 A. No. No. 15 Q. Okay. And the pictures that you saw were 16 sort of -- would you describe them as being artistic 17 kind of pictures? 18 19 20 MR. EDWARDS: Objection, counsel testifying. THE WITNESS: I think so. I don't think 21 they were pornographic. I don't think it was 22 any vaginal or things, you know, female parts 23 showing. 24 taking the sun. 25 was a beautiful setting, so she took a lot of It was some girls were topless, It was a beautiful house, it Case 18-2868, Document 283, 08/09/2019, 2628241, Page26 of 883 Page 236 1 2 3 4 5 6 7 JOHN ALESSI CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, the undersigned authority, certify that JOHN ALESSI personally appeared before me and was duly sworn. WITNESS my hand and official seal this 1st day of June, 2016. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Kelli Ann Willis, RPR, CRR Notary Public, State of Florida Commission FF928291, Expires 2-16-20 + + + + + + + + + + + + + + + + + + CERTIFICATE STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime Reporter do hereby certify that I was authorized to and did stenographically report the foregoing deposition of JOHN ALESSI; that a review of the transcript was not requested; and that the transcript is a true record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 1st day of June, 2016. KELLI ANN WILLIS, RPR, CRR Cam: 18-7868, 782, 08/09/7010, 7678741, Pag977 nf EXHIBIT 2 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page28 of 883 UNITED STATES DISTRICT COURT for the SOUTHERN DISTRICT OF NEW YORK Civil Action No. VIRGINIA GIUFFRE, Plaintiff, vs. GHISLAINE MAXWELL Defendant. VIDEO-DEPOSITION OF: JAMES MICHAEL AUSTRICH TAKEN BY: Defendant REPORTED BY: Karla Layfield, RMR Stenographic Court Reporter Notary Public State of Florida at Large DATE AND TIME: June 23, 2016; 9:03 a.m. PLACE: Owen Associates Court Reporters 108 N. Magnolia Avenue, Suite 501 Ocala, Florida APPEARANCES: Laura A. Menninger, Esquire HADDON, MORGAN FOREMAN, PC 150 East 10th Avenue Denver, Colorado 80203 Attorney for Defendant Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, FISTOS LEHRMAN, PL 425 Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Attorney for Plaintiff Also Present: Kenneth Sarsony, Videographer Virginia Giuffre Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page29 of 883 16 A Yes. Was it is a franchise, if you know? A I know when I first started there, they were corporate, but then they were a franchise. They were bought out. But I'm not sure if when I got there they were a franchise or not. Got it. Do you know if Ms. Roberts had any previous employment before she worked at Taco Bell? A I think by the apartment, she worked for KFC for a little while. MS. MENNINGER: Are you looking at Ms. Roberts? THE WITNESS: I'm thinking. I can't remember. I remember something with KFC. They had one really close to us. I think she worked there for a tiny, tiny bit. I'm not sure. MS. MENNINGER: Okay. BY MS. MENNINGER: Before the Taco Bell? A Or she could've applied there. It's just in my head. She might have just applied there, and didn't get it, and that's why I brought her to Taco Bell. Okay. A Because we were both the night managers. Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page30 of 883 19 A No. Do you know about what years this was? A Not really. Do you know about how old you were? A When, what? I'm just focused on the period of time in which you were living at her parent's house in the trailer. A I was probably 18 when we moved in there. And you said you were only there for a couple of months? A Not that I remember. Like, it might have been a little longer. I'm not sure. Were you engaged to Ms. Roberts? A Yes. When did you become engaged to her? A When we were living in Oakland Park. Tell me about the engagement. How did it come about? A Well, we fell in love, and -- I believe it was Valentine's Day when I proposed. Did you have a ring? A Yes. Did she accept? A Yes. How long were you engaged? Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page31 of 883 30 A Yes well, for a while. I mean, I know at the end, I wasn't working anywhere. Why weren't you working? A I don't remember the exact reason. Had you quit? A I believe so. I know the pet store let me go for walking on to the other side talking to somebody. But I don't remember why I left Dunkin' Donuts. Do you believe that you were fired from Dunkin' Donuts? A No. That pet store was the only time anybody ever fired me. That will stick in your brain. A Yeah. At the time that you left the pet store, was Ms. Roberts still working there? A Yes. And how long do you recall her working there? A Not long. I hate to do this to you, but what does "not long" mean to you, weeks, months, days? A Over a month. That's really all I can say. Maybe over a month before she went to work at the Mar?a?Lago or Donald Trump's country club. Did she leave the pet store to go work at Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page32 of 883 BY MS. MENNINGER: Did you know her friend by the name of Tony Figueroa? A Somewhat. Tell me what you remember about Tony Figueroa. A Other than him being an idiot, not much. Did you have any interactions with Mr. Figueroa? A Very little. When do you recall seeing him, like, in what city, I mean? A Up in West Palm Beach. Did he come over to your apartment? A I believe so. Did you believe them to be having a relationship? A At the very end when I left, yes. Was that one of the reasons for your leaving? A One of them. What were the others? A Well, after I found out about that, that's when I heard about all the other stuff that was happening. What did you hear about all the other stuff? A Well, I mean, after she went to work for Mar?a?Lago then she was, I guess, recruited to go work for Jeff something. I don't remember his last name. Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 34 Case 18-2868, Document 283, 08/09/2019, 2628241, Page33 of 883 35 Is that what she told you "she was recruited"? A Yeah. Well, she didn't use those words. But I don't know why else anybody would take like, they hired her over there as a massage therapist, but she didn't have any experience. At Mar-a-Lago A At Mar?a?Lago, yes. Then all of a sudden one day, she was working for Jeff, whatever his name was. Let me just take a step back. You found out towards the end of your relationship with Ms. Roberts that she was then having a relationship with Mr. Figueroa. Is that right? A I don't know if it was a relationship. But, yes. Enough to cause you to think you didn't want to be engaged anymore? A Yes. Did you and Ms. Roberts have a fight at that time? A Yes. What do you remember about the fight? What do you recall? A I don't recall. I remember us having a fight and then leaving not too long afterwards. You referred to finding out all this other stuff Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page34 of 883 92 When you got the apartment in Oakland Park, you got it with Virginia? A Well, yeah. She was living with us -- and Mario. MS. MENNINGER: All right. I think that's all I have. MR. EDWARDS: Okay. THE VIDEOGRAPHER: We're going off the record. This concludes disc one, volume one of the video-deposition of James Michael Austrich. We're going off the record. The time is approximately 11:20 a.m. (Break taken.) THE VIDEOGRAPHER: We're back on the record with disc two, volume one, of the video- deposition of James Michael Austrich. And the time is approximately 11:23 a.m. Thank you. BY MR. EDWARDS: Mr. Austrich, as you know, my name is Brad Edwards, and I represent Virginia. A Yes. I'm going to ask you some follow-up questions to the questions that you were asked previously. All right? Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page35 of 883 how long we lived there. Okay. At some point in time, though, while you're living on her parent's property, it becomes 1999? A Yeah, I believe. Okay. And so when you started living at her parent's property, you're 18, she's 15, but at some point in time you turn 19 and she turned 16? A Yes. Okay. And at some other point in time, she leaves the job at the pet store? A Pet store, yeah. And goes to work at the Mar-a-Lago? A Yes. At Donald Trump's country club, yeah. Okay. Donald Trump's country club is called the Mar-a-Lago? MS. MENNINGER: Objection. THE WITNESS: Yeah, that's what I always remember it as. Yes. BY MR. EDWARDS: Is that right? MS. MENNINGER: Objection, leading. I do get a chance to object. Leading. BY MR. EDWARDS: When you used the term "Mar-a-Lago" and used the term "Donald Trump's country club," are we talking about Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 98 Case 18-2868, Document 283, 08/09/2019, 2628241, Page36 get clean for her job, she would have gotten clean for the job. Okay. Do you remember her being hired as a bathroom attendant there, a locker room attendant? A Now that you?re saying that, some kind of attendant sounds familiar. But I don't really remember. All I remember is for the massage. As a -- I don't remember exactly what she got hired for at Donald Trump's place. But I just remember the masseuse thing. But as you're saying "the attendant," the attendant sounds familiar because I doubt her father would hire her as a massage therapist without knowing anything. So you had known her for some period of time before she gets this job at the Mar?a?Lago, right? A Right. Did she have any massage therapy training whatsoever? A No. Ever given a massage to anyone? A Not that I remember. Ever given a massage to you? A Not until she was already doing the massage stuff. But, no, I don?t remember any kind of massage training or even like an inkling for it. Okay. Then when she goes to work for Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page37 of 883 101 Mar-a-Lago, you don't remember, I think is the words you used, whether she worked there for weeks or months? A Yes. You don't remember? A No, not at all. And at the time when she gets the job at the Mar-a-Lago, do you remember where you were working, if anywhere? A No. I mean, I think at that time, I was working at one of the places. But I don?t really remember where. And then, and I believe that you used this word, correct me if I'm wrong, she's recruited to work for Jeff? A Yes. And do you remember her telling you that it was an assistant or somebody associated with Jeff that recruited her to work with Jeff? MS. MENNINGER: Objection, leading. THE WITNESS: I don't remember. MS. MENNINGER: Misstates the testimony. THE WITNESS: Sorry. I don't remember. All I remember was that somebody got her from there to Jeff. MR. EDWARDS: Got it. BY MR. EDWARDS: Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page38 of 883 109 Then there's months; November, December. A So this is the year 2000, and these are the months? MS. MENNINGER: Objection to this entire line of questioning. The witness has no foundation for talking about this particular document. BY MR. EDWARDS: Okay. So do you know how long that as you sit here today, do you remember how long Virginia had been going over to Jeff's house before she started traveling on an airplane with him? MS. MENNINGER: Objection, foundation. THE WITNESS: NO. BY MR. EDWARDS: It could be months, it could be a year? MS. MENNINGER: Objection, foundation. THE WITNESS: I don't think it I don't think she was there for very long without doing traveling. BY MR. EDWARDS: But in your mind, you can't tell me how long "very long" is? A No, I mean, I don't. Okay. And is there anything that would tell you the year or the month in which you remember Virginia first Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page39 of 883 110 going over to Jeff's house? A Not really. There's nothing I could really show you in this world that would remind you right now? A No. Okay. Before going over to work with Jeff, did Virginia have any massage experience? A No. When I think you said with respect to "bringing other girls, that sounds familiar," what other girls do you remember her bringing? Do you remember their names? A I don't remember names. MS. MENNINGER: Objection, foundation. BY MR. EDWARDS: Did you ever drive any of the other girls over to Jeff's house? A I don't think so. Okay. How many times did you to to Jeff's house? A A few times. Like, I think I went I think I dropped her off and somebody always brought her back. I don't really remember picking her up too much. Okay. And in the beginning, she was telling you that she was performing massages? Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page40 of 883 A Yeah, something like that. Do you know what time of year? A No. Do you know whether the spa at Mar-a-Lago closes during the summers? MR. EDWARDS: Form. THE WITNESS: No, I have no idea. BY MS. MENNINGER: You don't know how she got the job with Jeff? A No. I know somebody somebody like, that's why I said "recruited" that's the only word I can think of that worked for Jeff. Why do you use the word "recruited"? A Because that's the only word -- I don't know, football or everything. That's the only word I can think of, you recruit somebody. Hired her? A Yeah, I guess. It was it was just a very fast thing. You don't know who that person was? A No. You don't know what she said to that person? A No. You don't know what that person said to her? A Nope. Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 127 Case 18-2868, Document 283, 08/09/2019, 2628241, Page41 of 883 128 Do you remember her coming home and saying got a job with Jeff"? A I remember she said she got a job with Jeff. Did she tell about that job? A I think it was -- I think at the time it was for massage therapy, like, she was going to be a masseuse. And she was excited about it? A Yeah. She wasn't sad about it? A Not that I remember. But I really don't remember much from back then. She wasn?t crying when she came home and said just got a job with Jeff," right? A No. You're guessing that you -- she got the job with Jeff before you moved into the Bent Oak apartment, but you don't know. Correct? MR. EDWARDS: Form THE WITNESS: Yes. But I would think we would have had to have had the money by then. So that was the only time she was making real good money. BY MS. MENNINGER: And do you know how much that apartment cost? A I know it was expensive. Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page42 of 883 I I A STATE OF FLORIDA COUNTY OF MARION I, Karla Layfield, RMR, Stenographic Court Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing deposition of James Michael Austrich; that said witness was duly sworn to testify truthfully; and that the foregoing pages, numbered 1 through 145, inclusive, constitute a true and correct record of the testimony given by said witness to the best of my ability. I FURTHER CERTIFY that I am not a relative or employee or attorney or counsel of any of the parties hereto, nor a relative or employee of such attorney or counsel, nor am I financially interested in the action. WITNESS MY HAND this day of June, 2016, at Ocala, Marion County, Florida. Karla Layfield, RMR Stenographic Court Reporter Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 146 Cam: 18-7808, 782, 08/00/7010, 7678741, PagpAR nf EXHIBIT 3 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page44 of 883 Page 1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS VIRGINIA L. GIUFFRE, Plaintiff, -againstGHISLAINE MAXWELL, Defendant. ___________________________/ 250 N. Australian Avenue, Suite 1400 West Palm Beach, Florida 33401 Friday, September 9, 2016 8:35 a.m. - 2:08 p.m. C O N F I D E N T I A L VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Taken before Darline M. West, Registered Professional Reporter, Notary Public in and for the State of Florida At Large, pursuant to Notice of Taking Deposition filed by the Plaintiff in the above cause. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 Case 18-2868, Document 283, 08/09/2019, 2628241, Page45 of 883 Page 74 1 2 3 J. Epstein - Confidential BY MR. CASSELL: Q. Isn't it true that Maxwell led Virginia up 4 to your Palm Beach mansion massage room the first 5 time you met her? 6 7 MR. PAGLIUCA: foundation. 8 9 10 11 THE WITNESS: Q. 16 You saw Maxwell bringing Virginia up to your room, true, sir? MR. PAGLIUCA: Object to form and foundation. 14 15 Fifth. BY MR. CASSELL: 12 13 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. Isn't it true that it was standard 17 operating procedure for Maxwell to bring underage 18 girls up to your room? 19 20 MR. PAGLIUCA: foundation. 21 22 23 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. Isn't it true that it was standard 24 operating procedure for Maxwell to bring underage 25 girls up to your room for you to sexually abuse? Case 18-2868, Document 283, 08/09/2019, 2628241, Page46 of 883 Page 116 1 J. Epstein - Confidential 2 3 4 5 THE WITNESS: BY MR. CASSELL: Q. MR. PAGLIUCA: 10 Object to form and foundation. 8 9 In 2000, Virginia was approached by Maxwell, true? 6 7 Fifth. THE WITNESS: Fifth. BY MR. CASSELL: Q. Maxwell was one of the main women whom you 11 used to procure underage girls for sexual activities, 12 true? 13 14 MR. PAGLIUCA: foundation. 15 16 17 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. It was your understanding that Maxwell met 18 Virginia at the Mar-a-Lago Club in Palm Beach in 19 2000, true? 20 21 MR. PAGLIUCA: foundation. 22 23 24 25 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. In 2000, you were a member of the Mar-a-Lago Club, true? Case 18-2868, Document 283, 08/09/2019, 2628241, Page47 of 883 Page 117 1 J. Epstein - Confidential 2 MR. PAGLIUCA: 3 THE WITNESS: 4 5 6 Q. 11 In 2000, Ms. Maxwell had access to the Mar-a-Lago Club, true? MR. PAGLIUCA: Object to form and foundation. 9 10 Fifth. BY MR. CASSELL: 7 8 Object to form. THE WITNESS: Fifth. BY MR. CASSELL: Q. The reason Maxwell had access to the 12 Mar-a-Lago Club in 2000 was because of your 13 connections to the club, true? 14 15 MR. PAGLIUCA: foundation. 16 17 18 19 THE WITNESS: Q. 24 25 Maxwell was a primary co-conspirator in your sexual abuse scheme, true? MR. PAGLIUCA: Object to form and foundation. 22 23 Fifth. BY MR. CASSELL: 20 21 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. Maxwell was a primary co-conspirator in your sex trafficking scheme, true? Case 18-2868, Document 283, 08/09/2019, 2628241, Page48 of 883 Page 118 1 J. Epstein - Confidential 2 3 MR. PAGLIUCA: foundation. 4 5 6 7 THE WITNESS: Q. 12 Maxwell herself regularly participated in your sexual exploitation of minors, true? MR. PAGLIUCA: Object to form and found. 10 11 Fifth. BY MR. CASSELL: 8 9 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. In 2000, Maxwell herself regularly 13 participated in your sexual exploitation of minors, 14 true? 15 16 MR. PAGLIUCA: foundation. 17 18 19 20 THE WITNESS: Q. 25 Maxwell herself regularly participated in your sexual exploitation of Virginia, true? MR. PAGLIUCA: Object to form and foundation. 23 24 Fifth. BY MR. CASSELL: 21 22 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. Did Maxwell participate in your sexual Case 18-2868, Document 283, 08/09/2019, 2628241, Page49 of 883 Page 376 1 REPORTER'S CERTIFICATE 2 STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 I, DARLINE MARIE WEST, RPR, certify that I was 6 authorized to and did stenographically report the 7 foregoing deposition; and that the transcript is a 8 true record thereof. 9 10 I further certify that I am not a relative, 11 employee, attorney, or counsel of any of the parties, 12 nor am I a relative or employee of any of the 13 parties' attorney or counsel connected with the 14 action, nor am I financially interested in the 15 action. 16 17 Dated this 13th day of September 2016. 18 19 20 21 ________________________ 22 DARLINE MARIE WEST, RPR 23 24 25 Cam: 18-7868, 782, 08/09/7010, 7678741, Pagp?n nf EXHIBIT 4 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page51 of 883 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. ____________________/ VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume 1 of 2 Pages 1 - 157 Taken at the Instance of the Defendant DATE: Friday, June 24, 2016 TIME: Commenced: Concluded: PLACE: Southern Reporting Company B. Paul Katz Professional Center (SunTrust Building) One Florida Park Drive South Suite 214 Palm Coast, Florida 32137 REPORTED BY: LEANNE W. FITZGERALD, FPR Florida Professional Reporter Court Reporter and Notary Public 8:59 a.m. 1:22 p.m. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page52 of 883 82 1 Q Right? 2 A Yeah. 3 Q And she travelled the world? 4 A Uh-huh (affirmative). 5 Q Did JJ say there was anything weird about 6 7 her job? A 10 11 12 No. MR. EDWARDS: 8 9 Yes. Object to the form. BY MS. MENNINGER: Q Did you know whether she had any massage training? A I did not. Like I said, the past three -- 13 three or four years before then, I had no contact 14 with her whatsoever. 15 certified in or had done with her life. 16 17 18 19 20 21 22 23 Q Okay. So I had no clue what she was I would like to take about a five- or ten-minute break, if that's okay with you. A That's fine. THE VIDEOGRAPHER: The time is 10:13. We are off the record. The time is 10:27. We are back on the record. MS. MENNINGER: All right. I would like 24 to mark as an exhibit now Defendant's 25 Exhibit 4. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page53 of 883 88 1 certain times and stuff. And it would just -- you 2 know, it just did not make sense to me that it it 3 was just a masseuse, you know. 4 billionaire. 5 do you need her, you know. Like I said, he's a You can afford another masseuse. 6 Q 7 (Brief interruption.) 8 A Let me turn this down. 9 Q Sorry. 10 A I'm sorry. 11 (Briefly off the record.) 12 Q 13 14 Why Do you know whether he -- Do you know whether he had other masseuses at the time? A I -- I really don't know. All I know is 15 he would have Virginia, obviously, go out and look 16 for other girls, also, to bring back, as well. 17 Q And how do you know that? 18 A Because she had explained to me that 19 sometimes when she would go out on trips that her 20 and Ms. Maxwell and stuff would go out to, like, 21 clubs and stuff and just try and pick up girls to 22 bring back, so... 23 Q That's what Virginia told you? 24 A Yes. 25 Q All right. Did any of your information -- Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page54 of 883 89 1 (Brief interruption.) 2 A I thought I muted it. 3 Q Did any of your information come from 4 5 anywhere other than Virginia? A 6 7 No. MR. EDWARDS: A Object to the form. Like I said, I did not talk -- I did not 8 really speak to any of them other than, you know, 9 hi, how's it going and stuff like that, until I had 10 actually met Jeffrey. 11 I ever really spoke with. 12 couple of times, but it was never, like, you know, 13 actual conversations, so... 14 BY MS. MENNINGER: 15 16 17 18 19 20 Q All right. And then he was the only one I had met Ms. Maxwell a Well, let me -- when did you meet Jeffrey? A I'd probably say -- probably a few months after I had moved in with her. Q Okay. And how did you come to meet Jeffrey? 21 A Dropping her off over at his mansion. 22 Q And did you drop her off using her car? 23 A Yes. 24 Q And so she just asked you: 25 Can you take me over there? Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page55 of 883 90 1 A Yeah. 2 Q And did she tell you where to go? 3 A Yeah. 4 everything. 5 car, because she was going somewhere else in the 6 world and did not need it, so... 7 8 And then obviously I got to take the Q You were dropping her off for a multi-day A Yeah. trip? 9 10 She told where he lived and She would normally go about two weeks out of every month, so... 11 Q Two weeks straight? 12 A Yeah. 13 gone, basically. 14 15 16 It was two weeks home and two weeks Q Did you always take her to his house, A Yeah. or... Pretty much every time I took her 17 there, it was always to his mansion. 18 up one time -- maybe it was a couple of times -- 19 from the jet stream place. 20 single time it was at the hou- -- at the mansion. 21 (Brief interruption.) 22 Q 23 I'm -- 24 A No, it is. 25 Q That's okay. Okay. I picked her But pretty much every So you're -- is that your phone? I thought I muted it. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page56 of 883 92 1 2 3 4 5 talking like that, so... Q Okay. Where did your first conversation with Jeffrey take place? A I'm pretty sure it was in the kitchen or the living room. 6 Q Inside the house? 7 A Yeah, it was inside the house. I've never 8 seen him anywhere else other than in the mansion or 9 getting off the jet. 10 11 Q So you were allowed to go inside the house -- 12 A Yeah. 13 Q -- with Ms. Roberts? 14 A Yeah. But I never went upstairs. I've 15 only been in the kitchen, the living room, and by 16 the pool. 17 18 19 20 21 Q How many times would you estimate that you had been over to the house? A I mean, at least once every two weeks to drop her off, you know. Q Was there a period of time between 2001 22 and when she left in 2002 where she was not working 23 for Jeffrey? 24 A Yes. 25 Q What period of time was that? Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page57 of 883 93 1 A It was pretty much, like, when she was 2 actually working as a server. 3 because we were trying to not have her go back 4 there. 5 And we were trying to just work without needing his 6 money, you know. 7 Like, basically Like, she did not want to go back there. Q All right. And if I can re-call up that 8 Exhibit 2, can you see from here when about she was 9 working as a server? 10 A March 4th, '02. 11 Q Do you know about how long she worked 12 there? 13 A I do not. 14 Q Days? 15 A I really have no clue. 16 Q Okay. 17 I'm not sure. Weeks? Months? Anything? How old was Ms. Roberts in 2002, if you know? 18 A I'd probably say, like, 18 or so, maybe. 19 Q If her birthday is in '83 -- 20 A Oh, if it's in '83, then I'd say -- 21 because I was born in '82, so a year younger than me 22 would be... 23 Q 18, 19? 24 A Yeah, somewhere around there. 25 MR. EDWARDS: Object to the form. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page58 of 883 96 1 Q I guess my question is: Did she ever tell 2 you that she had started as a regular masseuse for 3 him and then transitioned to something other than a 4 masseuse? 5 A No. She never said that it transitioned. 6 But she ended up explaining to me what had happened 7 before, so... 8 Q What has -- what is that? 9 A That her and Ms. Maxwell and Jeffrey would 10 obviously be doing stuff, all three of them 11 together. 12 to clubs to pick up girls and try and find them to 13 bring back for Jeffrey. 14 how, like I said, her and Ms. Maxwell and Jeffrey 15 were all intimate together on multiple occasions. Like I said, that they would all go out And then she told me about 16 Q When did she tell you this? 17 A I'm not exactly sure on the dates. 18 Q Was it while you were still together? 19 A Yes. 20 Q Did you -- had you met Ms. Maxwell? 21 A Yeah, I had met her a couple of times. 22 Q When did you meet Ms. Maxwell? 23 A Dates, I'm unsure of. But it was pretty 24 much, like I said, at Jeffrey's house in the 25 kitchen. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page59 of 883 97 Q 1 2 Was it earlier in the time you were with her, or... 3 A 4 or so. 5 Q It was about -- I'd say about six months I don't know. All right. I'm not exactly positive. So at the time you met 6 Ms. Maxwell, had Ms. Roberts already told you that 7 she had been intimate? A 8 9 10 11 No. She had told me about that, I believe, after I had max- -- after I had already met her. Q Okay. And tell me everything that you 12 remember about what Ms. Roberts said about being 13 intimate with Ms. Maxwell and Mr. Epstein at the 14 same time. 15 A I remember her talking about, like, 16 strap-ons and stuff like that. 17 said, all the details are not really that clear. 18 But I remember her talking about, like, how they 19 would always be using and stuff like that. 20 21 Q But, I mean, like I She and Ms. Maxwell and Mr Epstein would used strap-ons? 22 A Uh-huh (affirmative). 23 Q How did you feel about that? 24 A I just -- obviously not happy about it. 25 Q What did you say? Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page60 of 883 103 1 A I did not. 2 Q When the FBI interviewed you, did you 3 4 5 6 7 8 9 10 mention this to them? A I mentioned -- anything they asked me, I did not hold anything back. Q Okay. Do you recall specifically talking about sex with the Prince? A I -- I don't recall talking to them about that, but, I mean, it's -- it could be possible. Q Other than sex with the Prince, is there 11 anyone else that Jeffrey wanted Ms. Roberts to have 12 sex with that she relayed to you? 13 14 15 16 A Mainly, like I said, just Ms. Maxwell and all the other girls. Q Ms. Maxwell wanted -- Jeffrey wanted Virginia to have sex with Ms. Maxwell? 17 A And him, yeah. 18 Q And did she tell you whether she had ever 19 done that? 20 A Yeah. 21 Q And when did she tell you that? 22 A I'm not sure on the date. 23 Q And what did she describe having happened? 24 A I believe I already told you that. 25 She said that she did. the strap-ons and dildos and everything. Southern Reporting Company www.Southernreporting.com - (386)257-3663 With Case 18-2868, Document 283, 08/09/2019, 2628241, Page61 of 883 157 CERTIFICATE OF REPORTER 1 2 STATE OF FLORIDA 3 COUNTY OF VOLUSIA ) ) ) 4 5 6 7 8 9 10 11 12 I, Leanne W. Fitzgerald, Court Reporter, do hereby certify that I was authorized to and did stenographically report the deposition of TONY FIGUEROA; and that the foregoing transcript is a true record of my stenographic notes. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. 13 Dated this 5th day of July, 2016. 14 15 16 17 18 19 20 __________________________________ Leanne W. Fitzgerald, FPR Florida Professional Reporter 21 22 Digital Certificate Authenticated By Symantec 23 24 25 Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page62 of 883 158 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. ____________________/ VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume 2 of 2 Pages 158 - 258 Taken at the Instance of the Defendant DATE: Friday, June 24, 2016 TIME: Commenced: Concluded: PLACE: Southern Reporting Company B. Paul Katz Professional Center (SunTrust Building) One Florida Park Drive South Suite 214 Palm Coast, Florida 32137 REPORTED BY: LEANNE W. FITZGERALD, FPR Florida Professional Reporter Court Reporter and Notary Public 8:59 a.m. 1:22 p.m. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page63 of 883 168 1 A Yes. 2 Q All right. 3 And that belief was based on Virginia telling you that? 4 A And JJ and Michael. 5 Q Okay. 6 So you had heard from some other people, and then later -A 7 Yeah. Before she had come back to the 8 apartment, they said that she was a masseuse for 9 this guy. Q 10 11 All right. Once you started dating her again -- I'm sorry. Prior to dating her. 12 13 And then when she came back, she told me. time you were dating her. Go back to the first Did she have money? 14 A No. 15 Q All right. 16 place? 17 A No. 18 Q Was she doing massages, at all? 19 A No. 20 Q All right. Was she able to afford her own Fast forward to the second 21 time when you get back together with her sometime in 22 2001. 23 A Uh-huh (affirmative). 24 Q Did she appear to you to have any massage 25 training? Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page64 of 883 169 1 A No. 2 Q As a seventeen-year-old at that time, was 3 she able to afford things? MS. MENNINGER: 4 5 6 Objection. Form. Foundation. BY MR. EDWARDS: 7 Q Did she have money -- 8 A She had money. 9 Q -- while working with Jeff? And was the money in the form of cash? 10 11 A Yes. 12 Q And did she always have cash? 13 A Yes. 14 Q And how was the apartment paid for? MS. MENNINGER: 15 16 Foundation. 17 A 18 19 20 Objection. Form. Cash. BY MR. EDWARDS: Q And did you see how she was paying for the apartment? 21 A I did not watch her pay the bill, but... 22 Q Okay. 23 24 25 When you would go to dinner, who would pay? A Just whoever. MS. MENNINGER: Objection. Form. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page65 of 883 200 MS. MENNINGER: 1 2 Foundation. 3 A 4 5 Objection. Form. For Jeffrey. BY MR. EDWARDS: Q All right. Let me fix this. Ghislaine -- 6 when Ghislaine Maxwell would call you during the 7 time that you were living with Virginia, she would 8 ask you what, specifically? MS. MENNINGER: 9 10 Foundation. 11 A Objection. Form. Just if I had found any other girls just 12 to bring to Jeffrey. 13 BY MR. EDWARDS: 14 Q Okay. 15 A Pretty much every time there was a 16 conversation with any of them, it was either asking 17 Virginia where she was at, or asking her to get 18 girls, or asking me to get girls. 19 Q All right. Let's go to that second 20 category you just identified, which is asking 21 Virginia to get girls. 22 room where specifically Ghislaine Maxwell would ask 23 Virginia to bring girls? How many times were you in a 24 A None that I can recall. 25 Q Okay. How many times -- when you say they Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page66 of 883 228 1 went with Virginia, and you dropped her off; and 2 some occasions you went inside? 3 A Yeah. 4 Q And some of the occasions you went inside, 5 you hung out by the pool? 6 A Yes. 7 Q Or in the kitchen with the chef? 8 A Yeah. 9 Q All right. And in the total of all the 10 times that you went inside the house, you saw 11 Ms. Maxwell -- I think you got up to six times? 12 A Yeah, about five or six times. 13 Q All right. 14 A Total. 15 Q That's not five or six times where -- 16 A That was period, all together. 17 Q -- you brought girls? 18 A No. 19 Q All right. Total? All together, period. I thought you said when I was 20 asking you questions that Ms. Maxwell never asked 21 you to bring girls. 22 A I don't remember saying that. 23 Q Okay. 24 25 Well, tell me. When did Ms. Maxwell ask you to bring a girl? A Never in person. It was, like, literally, Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page67 of 883 229 1 like, on the phone maybe, like, once or twice. 2 Q 3 frequently? 4 A No. 5 Q All right. 6 7 8 All right. Did Ms. Maxwell call you How many times do you think Ms. Maxwell called you, at all? A I'd just say that probably a just a few, a couple of times. Maybe once or twice. 9 Q One or two -- 10 A The majority of the time it was pretty 11 much his assistant. 12 Q How do you know Ms. Maxwell's voice? 13 A Because she sounds British. 14 Q So someone with a British accent called 15 you once or twice and asked for -- 16 A Well, she told me who she was. 17 Q Okay. 18 19 And what did she say when she called you and asked you to bring girls? A She just said, "Hi. This is Ghislaine. 20 Jeffrey was wondering if you had anybody that could 21 come over." 22 Q Okay. 23 A I'm not exactly sure on the time frame. 24 Q Was it after the Roadhouse Grill or 25 When did that happen? before? Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page68 of 883 248 1 Q So the thing that Virginia was tired of -- 2 just so that the record is clear -- well, I'll let 3 you answer in your words. Just be clear. 4 What was it that Virginia was trying to 5 get away from and stop with respect to working at 6 Jeffrey Epstein's house? 7 MS. MENNINGER: Objection. Form, 8 foundation -- as to Virginia's thought 9 processes. 10 11 12 A To stop being used and abused. BY MS. MENNINGER: Q How do you know that? MS. MENNINGER: 13 14 Foundation. 15 A Objection. Form. Due to all the things that I have come 16 to -- that have been brought to light, and in the 17 experiences that I've had, and the conversations 18 that I have had with her. 19 to that, so... 20 BY MS. MENNINGER: 21 Q Like, it just all adds up When Virginia was wanting to get out, did 22 she ever express that it was the times of work that 23 she was trying to get away from? 24 A No. 25 Q Okay. What was she specifically Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page69 of 883 251 1 2 Q Was she getting paid as much as she was getting paid to work for Jeff Epstein? 3 A Definitely not. 4 Q She no longer had cash all around? 5 A Nope. 6 Q You mentioned that there was -- you had 7 several conversations with Virginia when she was 8 discussing them wanting -- or I think the word you 9 used was force, but later we tried to clarify that, 10 but them forcing her to have sex with Prince Andrew. 11 Do you remember that? 12 A Yeah. 13 Q And that you expressed that you were 14 worried for her safety if she were to decline that? 15 A Yes. 16 Q What about your conversation with Virginia 17 on that particular occasion made you worried for 18 Virginia's safety? 19 20 21 A Just the way she was talking to me. Like, she just sounded scared. Q And what -- what -- try to dig back and 22 remember what exactly she was saying and how she was 23 saying it, if you could just describe that for us. 24 25 A She said that she went to go in -- I remember at one time she was talking to me about how Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page70 of 883 258 CERTIFICATE OF REPORTER 1 2 STATE OF FLORIDA 3 COUNTY OF VOLUSIA ) ) ) 4 5 6 7 8 9 10 11 12 I, Leanne W. Fitzgerald, Court Reporter, do hereby certify that I was authorized to and did stenographically report the deposition of TONY FIGUEROA; and that the foregoing transcript is a true record of my stenographic notes. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. 13 Dated this 5th day of July, 2016. 14 15 16 17 18 19 20 __________________________________ Leanne W. Fitzgerald, FPR Florida Professional Reporter 21 22 Digital Certificate Authenticated By Symantec 23 24 25 Southern Reporting Company www.Southernreporting.com - (386)257-3663 Cam: 18-7868, 782, 08/09/7010, 7678741, Pagp71 nf EXHIBIT 5 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page72 of 883 GI UFFRE VS. IMAXWELL mm VIRGINIA GI UF FRE 05/03/2016 Agren Blando Court Reporting Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-001 7 Case 18-2868, Document 283, 08/09/2019, 2628241, Page73 of 883 !“ Ãÿ¤ À“!ä‹ ÕÃflÃ¤Õ ‹!ÕÃŒ!›Ã ›—ÀŒÃ Õ—ÀÃÿ¤Œ“ ‹!ÕÃŒ!›Ã —⁄ “¤… «—Œ’ ›1™1¥ fl4¨1±7 “±Ú ÔÎÛ4™Û<ÈÏÌÌÛŒ…Õ ›—“⁄!‹¤“Ã!fl‘ !‹¤—Ãfl–¤‹ ‹¤–—Õ!Ã!—“ —⁄ !ŒŸ!“!fl Ÿ!À⁄⁄Œ¤ ”øß ÌÙ Ó<ÔÍ !ŒŸ!“!fl ‘Ú Ÿ!À⁄⁄Œ¤Ù –¥ø17¨1JJÙ ™Ú Ÿÿ!Õ‘fl!“¤ ”fl»…¤‘‘Ù ‹ªJª7ºø7¨Ú fl––¤flŒfl“›¤ÕÊ ⁄fl”¤ŒÙ ÷fl⁄⁄¤Ù …¤!ÕÕ!“ŸÙ ¤‹…flŒ‹ÕÙ ⁄!ÕÃ—Õ ˙ ‘¤ÿŒ”fl“Ù –Ú‘Ú fiß fiÆøº ¤º©øƺTÙ ¤TØÚ ÏÓÎ “Ú fl7ºÆª©T fl™ª7´ª Õ´1¨ª Ó ⁄±Æ¨ ‘ø´ºªÆºø¥ªÙ ⁄‘ ÌÌÌ<Ô –W±7ªÊ ÁÎÏÚÎÓÏÚÓËÓ< æÆøº‡\ø¨W¨±]´T¨14ªÚ4±^ fl\\ªøÆ17_ ±7 æªWø¥J ±J ¨Wª –¥ø17¨1JJ fi—!¤ÕÙ Õ›ÿ!‘‘¤Œ ˙ ⁄‘¤»“¤Œ ‘‘– fiß Õ1_Æ1º ÕÚ ”4›ø©¥ªßÙ ¤TØÚ ¯⁄±Æ –±Æ¨1±7˜ Ï<Ô ¤øT¨ ‘øT —¥øT fi±´¥ª™øƺ Õ´1¨ª ÔÓ<< ⁄±Æ¨ ‘ø´ºªÆºø¥ªÙ ⁄‘ ÌÌÌ<ÔÛÓÓÔÔ –W±7ªÊ ÁÎÏÚÌÎÍÚ<<ÔÔ T^44ø©¥ªß‡æTJ¥¥\Ú4±^ fl\\ªøÆ17_ ±7 æªWø¥J ±J ¨Wª –¥ø17¨1JJ Case 18-2868, Document 283, 08/09/2019, 2628241, Page74 of 883 Ô Ó Ì Ï Î Í fl––¤flŒfl“›¤ÕÊ ¯›±7¨17´ªº˜ ÿfl‹‹—“Ù ”—ŒŸfl“ fl“‹ ⁄—Œ”fl“Ù –Ú›Ú fiß ‘ø´Æø flÚ ”ª7717_ªÆÙ ¤TØÚ ÷ªJJÆªß ÕÚ –ø_¥1´4øÙ ¤TØÚ ÔÎ< ¤øT¨ Ô<¨W fl™ª7´ª ‹ª7™ªÆÙ ›— Ë<Ó<Ì –W±7ªÊ Ì<ÌÚËÌÔÚÈÌÍÏ ¥^ª7717_ªÆ‡W^J¥ø©Ú4±^ ]\ø_¥1´4ø‡W^J¥ø©Ú4±^ fl\\ªøÆ17_ ±7 æªWø¥J ±J ¨Wª ‹ªJª7ºø7¨ È Ë Á Ô< ÔÔ ÔÓ ÔÌ ÔÏ ÔÎ ÔÍ ÔÈ ÔË ÔÁ Ó< ÓÔ ÓÓ ÓÌ ÓÏ ÓÎ fl¥T± –ƪTª7¨Ê fiƪ7ºø Œ±ºÆ1_´ª¶Ù –øÆø¥ª_ø¥ “14W±¥øT ⁄Ú fi±Æ_1øÙ ›‘ Õ 1ºª±_Æø\WªÆ Case 18-2868, Document 283, 08/09/2019, 2628241, Page75 of 883 Ô ß±´ º±7˘¨Ú Ó ‹± ß±´ Wø™ª ø7ß ÆªøT±7 ¨± 檥1ª™ª ¨Wø¨ ø7ß Ì ±J ß±´Æ \ƪ™1±´T T©±Æ7 T¨ø¨ª^ª7¨T ¨Wø¨ ß±´ Wø™ª ^øºª Ï øƪ 7±¨ ¨Æ´ª· Î fl Í “±Ú ”ŒÚ ¤‹…flŒ‹ÕÊ ! ]´T¨ ±æ]ª4¨ ø7º øTµ ¨Wø¨ È 1J ©ª˘Æª _±17_ ¨± øTµ ¨Wª ©1¨7ªTT Ø´ªT¨1±7T øæ±´¨ ø7ß Ë ±J WªÆ T¨ø¨ª^ª7¨T 17 ©W±¥ª ±Æ 17 \øƨ ¨Wø¨ ¨Wª Á ©1¨7ªTT æª ø¥¥±©ªº ¨± Tªª ¨Wª T¨ø¨ª^ª7¨Ù ƪ™1ª© ¨Wª Ô< ÔÔ ÔÓ T¨ø¨ª^ª7¨ ø7º ¨Wª7 ø7T©ªÆ ß±´Æ Ø´ªT¨1±7TÚ œ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ «±´ ^øß ø7T©ªÆ ¨Wª Ø´ªT¨1±7Ú ÔÌ fl ›ø7 ß±´ ƪøTµ ¨Wª Ø´ªT¨1±7· ÔÏ œ ‹± ß±´ Wø™ª ø7ß ÆªøT±7 ¨± 檥1ª™ª ¨Wø¨ ø7ß ÔÎ ÔÍ ÔÈ ÔË ÔÁ !˘^ T±ÆÆßÚ ±J ß±´Æ \Æ1±Æ T©±Æ7 T¨ø¨ª^ª7¨T øƪ ´7¨Æ´ª· fl ! Wø™ª 7± ƪøT±7 ¨± 檥1ª™ª ¨Wø¨ ^ß \Æ1±Æ T¨ø¨ª^ª7¨T øƪ ´7¨Æ´ªÚ œ ÿøT ø7ß±7ª ¨±¥º ß±´ ¨± Tøß T±^ª¨W17_ ¨Wø¨ ©øT 7±¨ ¨Æ´ª 17 4±77ª4¨1±7 ©1¨W ¨W1T 4øTª· Ó< fl “±Ù ^ø˘ø^Ú ÓÔ œ fl¥¥ Æ1_W¨Ú !˘º ¥1µª ¨± T¨øƨ ©1¨W ø ÓÓ ¥ø©T´1¨ ¨Wø¨ ß±´ J1¥ªº ´7ºªÆ ¨Wª 4ø\¨1±7 ÷ø7ª ‹±ª ÓÌ ™ªÆT´T ÷ªJJÆªß ¤\T¨ª17Ú ÓÏ ÓÎ ‹± ß±´ ƪ4ø¥¥ ¨Wø¨ ¥ø©T´1¨· fl ! 檥1ª™ª T±Ú Case 18-2868, Document 283, 08/09/2019, 2628241, Page76 of 883 Ô Ó ¯¤®W1æ1¨ Ô ^øƵªºÚ˜ œ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ !˘^ _±17_ ¨± TW±© ß±´ Ì ø7 ª®W1æ1¨ ¨Wø¨ ©ª øƪ ^øƵ17_ øT ‹ªJª7ºø7¨˘T Ï ¤®W1æ1¨ ÔÚ Î ”ŒÚ ¤‹…flŒ‹ÕÊ Í !˘º ]´T¨ ¥1µª ¨± ^øµª ø7 ±æ]ª4¨1±7 ±7 ¨Wª È Æª4±Æº J±Æ ¨Wª ^1T1ºª7¨1J14ø¨1±7 ±J ¨W1T º±4´^ª7¨Ú Ë Á ›ø7 ! Tªª ¨Wø¨ J±Æ ø Tª4±7º· …W1¥ª ¨WªÆª ©øT ø ¥ø©T´1¨ J1¥ªº ´7ºªÆ ¨Wª T¨ß¥ª ±J ÷ø7ª ‹±ª ™ªÆT´T ÷ªJJÆªß ¤\T¨ª17Ù ÷ø7ª ‹±ª Ô< ©øT 7±¨ ÔÔ æª17_ Wø7ºªº ¨± ¨W1T ©1¨7ªTT 1T ÷ø7ª ‹±ª Ô<Ó ™ªÆT´T ÔÓ ÷ªJJÆªß ¤\T¨ª17Ú 1Æ_171ø Ÿ1´JJÆªÚ fl7º ¨Wª ¥ø©T´1¨ ¨Wø¨˘T 7±© ÔÌ !T ¨Wø¨ ¨Wª º±4´^ª7¨ ©ª˘Æª ¨ø¥µ17_ øæ±´¨· ÔÏ ”ÕÚ ”¤““!“Ÿ¤ŒÊ ›±´7Tª¥Ù 1J ß±´ Wø™ª ø7 ÔÎ ±æ]ª4¨1±7Ù ß±´ TW±´¥º T¨ø¨ª ¨Wª æøT1T J±Æ ß±´Æ ÔÍ ±æ]ª4¨1±7 17 ø 7±7Û¥ªøº17_Ù 7±7ÛT´__ªT¨1™ª ^ø77ªÆÚ ÔÈ ÔË ÔÁ !J ß±´ Wø™ª ø7ß ±¨WªÆ ƪ4±Æº ¨± ^øµªÙ ß±´ 4ø7 º± T± 17 ø \¥ªøº17_ J1¥ªº ©1¨W ¨Wª ›±´Æ¨Ú ”ŒÚ ¤‹…flŒ‹ÕÊ Õ´ÆªÚ ”ß ±æ]ª4¨1±7 1T Ó< ß±´˘™ª ^1Tƪ\ƪTª7¨ªº ©Wø¨ ß±´˘™ª Wø7ºªº ¨Wª ©1¨7ªTTÚ ÓÔ ! ©ø7¨ ¨± ^øµª T´Æª ¨Wø¨ ¨Wª ©1¨7ªTT 1T W±¥º17_ ©Wø¨ ÓÓ ß±´ ø4¨´ø¥¥ß ©ø7¨ WªÆ ¨± æª W±¥º17_ øT ±\\±Tªº ¨± ¨Wª ÓÌ ¥ø©T´1¨ ß±´ Tø1º ¨Wø¨ ß±´ ©ªÆª _±17_ ¨± Wø7º WªÆÚ ÓÏ ÃWø¨˘T 1¨Ú ÓÎ ”ÕÚ ”¤““!“Ÿ¤ŒÊ ›±´7Tª¥Ù ! ©1¥¥ øTµ ¨Wª Case 18-2868, Document 283, 08/09/2019, 2628241, Page77 of 883 Ô ÷ø7´øÆß ÔÁ¨WÙ Ó<Ôη Ó Ì fl ÷ø7´øÆß ÓÔT¨Ù Ó<ÔÎÚ Ï Î fl¨ ¨Wª ™ªÆß ¨±\ ±J ¨Wª \ø_ª 1¨ TøßT œ ÃWª ºø¨ª 1¨ ©øT J1¥ªºÚ !T ¨WªÆª ø ºø¨ª ]´T¨ øæ±™ª ¨Wª T1_7ø¨´Æª 楱4µ· Í fl —W٠ߪTÙ T±ÆÆßÚ È œ fl7º ©Wø¨ ºø¨ª ÛÛ ©Wø¨ ºø¨ª ©øT ¨Wø¨· Ë fl ÃWª ÔÁ¨W ºøß ±J ÷ø7´øÆßÙ Ó<ÔÎÚ Á œ —µøßÚ Ô< ÔÌ fl7º ¨W1T º±4´^ª7¨ 1T T±^ª¨W17_ ¨Wø¨ ß±´ 檥1ª™ª 4±7¨ø17T ¨Wª ¨Æ´¨WÙ 4±Æƪ4¨· ÔÔ ÔÓ «ªTÙ ¨WªÆª 1TÚ fl ñ ¨Wª æªT¨ ±J ^ß µ7±©¥ªº_ª ø¨ ¨Wª ¨1^ªÙ œ fl¥¥ Æ1_W¨Ú ߪTÚ ‹1º T±^ª¨W17_ 4Wø7_ª 檨©ªª7 ÔÏ ¨Wª ¨1^ª ¨Wª7 ø7º ¨±ºøß ¨Wø¨ ^øµªT ß±´ 檥1ª™ª ¨Wø¨ ÔÎ 1¨˘T 7±¨ ø¥¥ ø44´Æø¨ª· ÔÍ fl …ª¥¥Ù øT ß±´ 4ø7 TªªÙ 17 ¥17ª Ï ±7 \ø_ª ÔÙ ÔÈ ! ©øT7˘¨ ø©øƪ ±J ^ß ºø¨ªTÚ ÔË æªT¨ ¨± _´ªTT¨1^ø¨ª ©Wª7 ! ø4¨´ø¥¥ß ^ª¨ ¨Wª^Ú ÔÁ ! ©øT ]´T¨ º±17_ ¨Wª Õ174ª ¨Wª7 !˘™ª 檪7 ø楪 ¨± J17º ±´¨ ¨Wø¨ Ó< ¨WƱ´_W ^ß ”øÆÛøÛ‘ø_± ƪ4±ÆºT ¨Wø¨ 1¨ ©øT ø4¨´ø¥¥ß ÓÔ ¨Wª T´^^ªÆ ±J Ó<<<Ù 7±¨ ¨Wª T´^^ªÆ ±J ÔÁÁÁÚ ÓÓ œ —WÙ !˘^ T±ÆÆßÚ ÓÌ fl —7 ¨Wª J1ÆT¨ \ø_ªÚ ÓÏ œ —µøßÚ ÓÎ fl «ªTÚ flƪ ß±´ æø4µ ±7 \ø_ª Ô· Case 18-2868, Document 283, 08/09/2019, 2628241, Page78 of 883 Ô Ó Ì ”ŒÚ ¤‹…flŒ‹ÕÊ flTµªº ø7º ø7T©ªÆªºÚ œ Ï Î —æ]ª4¨1±7Ú ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ ”ŒÚ ¤‹…flŒ‹ÕÊ fl «±´ ^øß ø7T©ªÆÚ fl7T©ªÆ ø_ø17Ú fl_ø17Ù ! ©±´¥º7˘¨ Tøß 1¨˘T ´7¨Æ´ªÚ À7¨Æ´ª Í ©±´¥º ^ªø7 ¨Wø¨ ! ©±´¥º Wø™ª ¥1ªºÚ È ÃW1T ©øT ^ß æªT¨ µ7±©¥ªº_ª ø¨ ¨Wª ¨1^ªÚ Ë ™ªÆß æªT¨ ¨± ¨Æß ¨± \17\±17¨ ¨1^ª \ªÆ1±ºT _±17_ æø4µ Á T´4W ø ¥±7_ ¨1^ª ø_±Ú Ô< fl7º ! º1º7˘¨ ¥1ªÚ fl7º ! º1º ^ß !¨ ©øT7˘¨ ´7¨1¥ ! J±´7º ¨Wª Jø4¨T ¨Wø¨ ! ÔÔ ©±Æµªº ø¨ ”øÆÛøÛ‘ø_± 17 Ó<<< ¨Wø¨ ! ©øT ø楪 ¨± ÔÓ J1_´Æª ¨Wø¨ ±´¨Ú ÔÌ œ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ fl7º ø\\Ʊ®1^ø¨ª¥ß ©Wª7 ÔÏ º1º ß±´ ¥ªøÆ7 ¨W±Tª Jø4¨T øæ±´¨ ¨Wª ºø¨ªT ß±´ ©±Æµªº ÔÎ ø¨ ”øÆÛøÛ‘ø_±· ÔÍ fl ! ©±´¥º Tøß 1¨ ©øT ^1ºÛÓ<ÔÎÚ ÔÈ œ ”1ºÛÓ<ÔÎ 1T ¨Wª J1ÆT¨ ¨1^ª ß±´ æª4ø^ª ÔË ø©øƪ ±J ¨Wª ºø¨ªT ÛÛ ÔÁ fl ! º±7˘¨ µ7±© ¨Wª ª®ø4¨ ÛÛ Ó< œ !J ß±´ 4±´¥º ]´T¨ ¥ª¨ ^ª J171TWÚ ÓÔ fl !˘^ T±ÆÆßÚ ÓÓ œ ÃWø¨˘T ø¥¥ Æ1_W¨Ú fl\\Ʊ®1^ø¨ª¥ß ^1ºÛÓ<ÔÎ ÓÌ ©Wª7 ß±´ ¥ªøÆ7ªº ¨Wª ¨Æ´ª ºø¨ªT ¨Wø¨ ß±´ Wøº ©±Æµªº ÓÏ ø¨ ”øÆÛøÛ‘ø_±· ÓÎ fl ÃWø¨˘T 4±Æƪ4¨Ú Õ±ÆÆßÚ Case 18-2868, Document 283, 08/09/2019, 2628241, Page79 of 883 Ô ”ŒÚ ¤‹…flŒ‹ÕÊ —æ]ª4¨ ¨± ¨Wª J±Æ^Ú Ó fl ÀW^Ù ! º±7˘¨ µ7±©Ù ¨± æª W±7ªT¨Ú Ì œ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ fl7º 17 ©Wø¨ ±ÆºªÆ º1º Ï Ãø4± fiª¥¥Ù –´æ¥1® ø7º ”øÆÛøÛ‘ø_± _±Ù ø7º ¨Wª ø™1øÆßÙ Î T±ÆÆß· Í fl È —WÙ ! ©±´¥º Wø™ª ¨± _´ªTTÚ ‹± ß±´ ©ø7¨ ^ª ¨± _´ªTT· Ë œ Õ´ÆªÚ Á fl À^Ù ! ©±´¥º Tøß –´æ¥1®Ú fl7º ¨Wª7Ù ! ¨W17µ Ô< ¨Wø¨˘T ©Wª7 ! Wª¥\ªº ^ß æ±ßJÆ1ª7º ±´¨ ø¨ Ãø4± fiª¥¥ ÔÔ ø7º ¨Wª7 ! ¨W17µ ¨Wª ø™1øÆßÚ ÔÓ œ fl7º ©WªÆª ©øT ¨Wª Ãø4± fiª¥¥· ÔÌ fl ! ©øT ¥1™17_ 17 ⁄±Æ¨ ‘ø´ºªÆ ÛÛ ! ¨W17µ 1¨ ÔÏ ©øT ⁄±Æ¨ ‘ø´ºªÆºø¥ªÚ ÔÎ T±^ª©WªÆª 17 ⁄¥±Æ1ºøÙ fiƱ©øƺ ›±´7¨ßÙ T±^ª¨W17_ ¥1µª ÔÍ ¨Wø¨Ú ‹±7˘¨ Ø´±¨ª ^ª ±7 ¨Wø¨Ù æ´¨ ÔÈ œ fl7º ©W± ©ªÆª ß±´ ¥1™17_ ©1¨W ø¨ ¨Wø¨ ¨1^ª· ÔË fl ”14Wøª¥Ú ÔÁ œ Õ± ß±´ ©ªÆª ¥1™17_ ©1¨W ”14Wøª¥ ©Wª7 ß±´ Ó< ÿ1T 7ø^ª 1T ÷ø^ªTÙ æ´¨ ”14Wøª¥Ú ©±Æµªº ø¨ ¨Wª Ãø4± fiª¥¥Ù Æ1_W¨· ÓÔ fl «ªTÙ ! ©øT ¥1™17_ ©1¨W W1^Ú ÓÓ œ fl7º ß±´ ©±Æµªº ©1¨W ”14Wøª¥ ©Wª7 ß±´ ÓÌ ©±Æµªº ø¨ ¨Wª –´æ¥1®Ù 4±Æƪ4¨· ÓÏ fl “±Ú ÓÎ œ —µøßÚ Õ± –´æ¥1® 4ø^ª øJ¨ªÆ Ãø4± fiª¥¥ ±Æ Case 18-2868, Document 283, 08/09/2019, 2628241, Page80 of 883 Ô Ó œ …Wø¨ª™ªÆ øººÆªTT ß±´ ©ªÆª ¥1™17_ ø¨Ù ø¨ ¨Wª ¨1^ª ß±´ T¨øƨªº ø¨ ”øÆÛøÛ‘ø_±Ú Ì fl Ï ÌÌÏÈ<Ú Î œ Í ”øÆÛøÛ‘ø_±· È fl ‘±®øWø¨4WªªÙ ⁄¥±Æ1ºø ÿ±© 1T 1¨ ¨Wø¨ ß±´ 4ø^ª ¨± ©±Æµ ø¨ ”ß ºøº 1T ø ^ø17¨ª7ø74ª ^ø7ø_ªÆ ±Æ Ë T´\ªÆ™1T±ÆÙ ! º±7˘¨ µ7±© ©Wø¨ ß±´ 4ø¥¥ 1¨Ú Á ©±Æµªº 17 ¨Wª ^ø17¨ª7ø74ª ºª\øƨ^ª7¨Ù ^±T¨¥ß ±7 Ô< ¨ª771T 4±´Æ¨TÙ ©±Æµ17_ ±7 ¨Wª ø1Æ 4±7º1¨1±717_Ù ÔÔ Wª¥\17_ Tª¨ ´\ J±Æ J´74¨1±7TÚ ÔÓ ]±æ ¨WªÆªÚ fi´¨ Wª fl7º Wª _±¨ ^ª ø T´^^ªÆ ÔÌ œ —µøßÚ ÔÏ fl «ªTÚ ÔÎ œ …Wø¨ ©ªÆª ß±´ ±7 ø æƪøµ JƱ^· ÔÍ fl ! ¨W17µ ¥1µª ÛÛ ¨W1T 1T _±17_ æø4µ T± ¥±7_ fl7º ß±´ Tø1º ß±´ ©ªÆª ±7 ø æƪøµ· ÔÈ 7±©Ù æ´¨ ! ©øT ø¨¨ª^\¨17_ ¨± _ª¨ ^ß Ÿ¤‹Ú ÔË T´^^ªÆ 4ø^ªÙ T± T4W±±¥ T¨±\T º´Æ17_ ¨Wª T´^^ªÆ¨1^ª ÔÁ WªÆª 17 fl^ªÆ14øÙ ø7º ! _±¨ ø T´^^ªÆ ]±æÚ fl7º 1¨Ù Ó< œ fl¥¥ Æ1_W¨Ú ÓÔ fl ! º±7˘¨ ø4¨´ø¥¥ß µ7±© ¨Wª 7ø^ª ±J ¨Wª ÓÓ \¥ø4ªÚ ÓÌ œ fl Ÿ¤‹ \¥ø4ª· ÓÏ fl «ªøWÙ 1¨ ©øTÙ ¥1µªÙ ! ©øT \ƪ™1±´T¥ß 17 ÓÎ fl7º ©WªÆª ©ªÆª ß±´ 17 T4W±±¥· !¨˘T ÛÛ ßªøWÙ ! µ7±©Ú Œ±ßø¥ –ø¥^ fiªø4W ÿ1_W Õ4W±±¥Ù æ´¨Ù ! ^ªø7Ù æª4ø´Tª ±J Case 18-2868, Document 283, 08/09/2019, 2628241, Page81 of 883 Ô œ —µøßÚ !J ! 4ø7 º1ƪ4¨ ß±´Æ ø¨¨ª7¨1±7 æø4µ Ó ¨± ‹ªJª7ºø7¨˘T ¤®W1æ1¨ ÔÓ ø¨ \ø_ª ÔÎÚ Ì Wªøº17_ ŒªT\±7Tª ¨± !7¨ªÆƱ_ø¨±Æß “´^æªÆ ÁÙ º± ß±´ Ï Tªª ¨Wø¨ ©WªÆª 1¨ TøßT ÛÛ fl7º ´7ºªÆ ¨Wª Î fl «ªTÚ Í œ ÛÛ ”TÚ ÷±JJÆªß ¯\Ʊ7±´7417_˜ ÛÛ Ÿ1´JJÆªÙ È ª®4´Tª ^ªÙ ƪT\±7ºT øT J±¥¥±©T· Ë fl «ªTÚ Á œ —µøßÚ Ô< !¨ TøßT ß±´ ©±Æµªº øT ø ¥±4µªÆ Ʊ±^ ø¨¨ª7ºø7¨ J±Æ ¨Wª T\ø øƪøÙ 4±Æƪ4¨· ÔÔ fl «ªTÚ ÔÓ œ fl7º 1¨ TøßT ƪ4±ÆºT \Ʊº´4ªº 17 ¨W1T 4øTª ÔÌ 1ºª7¨1Jß ¨Wª ºø¨ª ±J ª^\¥±ß^ª7¨ øT Ó<<<Ù 4±Æƪ4¨· ÔÏ fl «ªTÚ ÔÎ œ …Wø¨ ƪ4±ÆºT ¨Wø¨ ©ªÆª \Ʊº´4ªº 17 ¨W1T ÔÍ 4øTª 4ø´Tª ß±´ ¨± 檥1ª™ª ¨Wø¨ ¨Wª ª^\¥±ß^ª7¨ æª_ø7 ÔÈ 17 Ó<<<· ÔË ÔÁ fl ÀW^Ù 1T ¨W1T _±17_ æø4µ ¨± ø7±¨WªÆ Ø´ªT¨1±7 ¨Wø¨ !˘^ 7±¨ ø¥¥±©ªº ¨± ø7T©ªÆ· Ó< œ “±Ú ÓÔ fl ! Wø™ª Tªª7 ¨Wª º±4´^ª7¨TÙ ø7º ! µ7±© ¨Wø¨ ÓÓ ÓÌ ÓÏ ÓÎ ^ß ª^\¥±ß^ª7¨ 7±© ©øT 17 Ó<<<Ú œ …Wø¨ º±4´^ª7¨T º1º ß±´ Tªª ¨Wø¨ 4ø´Tªº ß±´ ¨± ^øµª ¨Wø¨ ø7T©ªÆ· fl ÃWª ”øÆÛøÛ‘ø_± ª^\¥±ß^ª7¨ º±4´^ª7¨TÚ Case 18-2868, Document 283, 08/09/2019, 2628241, Page82 of 883 Ô ^øTTª´TªT Wøº ¨Wª1Æ ±©7 ´71J±Æ^TÚ Ó œ …Wø¨ º1º ¨Wª ^øTTª´TªT˘ ´71J±Æ^ ¥±±µ ¥1µª· Ì fl ! º±7˘¨ ƪ^ª^æªÆÚ Ï œ “± ƪ4±¥¥ª4¨1±7 ø¨ ø¥¥· Î fl “±7ª ©Wø¨T±ª™ªÆÚ Í œ ›±¥±Æ· È fl “±Ù T±ÆÆßÚ Ë œ —µøßÚ Á ! ƪ^ª^æªÆ ^17ªÚ ÿ±© º1º 1¨ 4±^ª ¨± \øTT ¨Wø¨ ß±´ ©ªÆª 7± ¥±7_ªÆ ©±Æµ17_ ø¨ ”øÆÛøÛ‘ø_± 17 ¨©± ¨± ¨Wƪª Ô< ©ªªµT· ÔÔ fl ! ©øT ø\\Ʊø4Wªº æß ŸW1T¥ø17ª ”ø®©ª¥¥Ú ÔÓ œ —µøßÚ fl7º W±© ¥±7_ Wøº ß±´ 檪7 ©±Æµ17_ ÔÌ ø¨ ”øÆÛøÛ‘ø_± ©Wª7 ß±´ ©ªÆª ø\\Ʊø4Wªº æß ŸW1T¥ø17ª ÔÏ ”ø®©ª¥¥· ÔÎ fl Œ±´_W¥ß ¨©± ¨± ¨Wƪª ©ªªµTÚ ÔÍ œ —µøßÚ ÔÈ ÔË …WªÆª 17 ¨Wª T\ø ©ªÆª ß±´ ©Wª7 ß±´ ©ªÆª ø\\Ʊø4Wªº æß ŸW1T¥ø17ª ”ø®©ª¥¥· fl ÷´T¨ ±´¨T1ºª ¨Wª ¥±4µªÆ Ʊ±^Ù T1¨¨17_ ÔÁ ©WªÆª ¨Wª ±¨WªÆ _1Æ¥ ¨Wø¨ ©±ÆµT ¨WªÆª ´T´ø¥¥ß T1¨TÚ Ó< ÕWª ©øT ø©øß JƱ^ ¨Wª ºªTµÚ ÓÔ ^øTTø_ª ¨WªÆø\ßÚ ! ©øT ƪøº17_ ø æ±±µ ±7 ÓÓ œ …øT ¨Wø¨ 17º±±ÆT ±Æ ±´¨º±±ÆT· ÓÌ fl —´¨º±±ÆTÚ ÓÏ œ —µøßÚ ÓÎ 17 ¨Wª TWøºª· fl7º ©Wø¨ ÛÛ ©ªÆª ß±´ 17 ¨Wª T´7 ±Æ Case 18-2868, Document 283, 08/09/2019, 2628241, Page83 of 883 Ô ©ø7¨ªº ¨± ø1^ J±Æ T±^ª¨W17_ W1_WªÆ ¨Wø7 æª17_ ø Ó ¥±4µªÆ Ʊ±^ ø¨¨ª7ºø7¨ ±7ª ºøßÚ Ì Ï œ fl7ºÚ «ªøWÚ …Wø¨ ©øT ¨Wª 7ø^ª ±J ¨Wª ^øTTø_ª ¨WªÆø\1T¨ ¨Wø¨ ß±´ ©ªÆª T\ªøµ17_ ©1¨W· Î fl —WÙ ! Wø™ª 7± 1ºªøÚ Í œ ›ø7 ß±´ _1™ª ^ª ø7ß \WßT14ø¥ ºªT4Æ1\¨1±7 È ±J ø7ß ±J ¨Wª^· Ë Á fl Wø1ÆÚ À^Ù ¨WªÆª ©øT ±7ª ©W± Wøº 楱7ºª TW±Æ¨ ÃWªÆª ©øT ÛÛ ! ©±´¥º Tøß ¨WªÆª˘T \Ʊæøæ¥ß Ô< øæ±´¨ J±´Æ ^øTTø_ª ¨WªÆø\1T¨T ¨Wø¨ ©±Æµ 17 ¨WªÆªÚ ÔÔ Õ±Ù ! ^ªø7Ù ! º±7˘¨ ƪ^ª^æªÆ ø¥¥ ±J ¨Wª^Ú ÔÓ œ ÔÌ —µøßÚ …Wø¨ ¨1^ª ±J ºøß ©øT 1¨· ”ŒÚ ¤‹…flŒ‹ÕÊ —æ]ª4¨ ¨± ¨Wª J±Æ^Ú ÔÏ fl flJ¨ªÆ7±±7Ú ÔÎ œ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ ÔÍ fl fl7ß©WªÆª 檨©ªª7 Ó ¨± ÏÚ ÔÈ œ fl7º ©Wø¨ ¨1^ª º1º ß±´ _ª¨ ±JJ ±J ©±Æµ· ÔË fl ! 檥1ª™ª ! _±¨ ±JJ ø¨ ÎÚ ÔÁ œ fl7º ©Wø¨ ©øT ¨Wª ƪT¨ ±J ß±´Æ 4±7™ªÆTø¨1±7 Ó< ©1¨W ”TÚ ”ø®©ª¥¥· ÓÔ ÓÓ ÿ±© ¥ø¨ª· !˘^ T±ÆÆßÙ ! º±7˘¨ ¨W17µ ß±´ J171TWªºÚ fl ÃWø7µ ß±´Ú …ª¥¥Ù TWª 7±¨14ªº ! ©øT ÓÌ Æªøº17_ ¨Wª ^øTTø_ª æ±±µÚ ÓÏ 4W1¨4Wø¨ ©1¨W WªÆ ]´T¨ øæ±´¨Ù ß±´ µ7±©Ù ¨Wª æ±ºß ø7º ÓÎ ¨Wª ø7ø¨±^ß ø7º W±© ! ©øT 17¨ªÆªT¨ªº 17 1¨Ú fl7º ! T¨øƨªº ¨± Wø™ª fl7º TWª Case 18-2868, Document 283, 08/09/2019, 2628241, Page84 of 883 Ô ¨±¥º ^ª ¨Wø¨ TWª µ7ª© T±^ªæ±ºß ©W± ©øT ¥±±µ17_ J±Æ ø Ó ¨Æø™ª¥17_ ^øTTª´TªÚ Ì fl7º ! 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ÓÔ º±7˘¨ ƪ^ª^æªÆ ¨Wª ª®ø4¨ øººÆªTTÙ æ´¨ 1¨ ©øT ÓÓ ¤¥ fiÆ1¥¥± …øß 17 –ø¥^ fiªø4W ÛÛ øJ¨ªÆ ß±´ _ª¨ ±JJÚ ÓÌ fl7º ^ß ºøº ºÆ±™ª ^ªÚ ÓÏ ÓÎ œ ‹1º ß±´ ©Æ1¨ª º±©7 WªÆ øºº ÛÛ ¨Wª øººÆªTT ¨Wø¨ TWª _ø™ª· Case 18-2868, Document 283, 08/09/2019, 2628241, Page85 of 883 Ô fl «ªTÚ Ó œ ‹1º ß±´ ©Æ1¨ª º±©7 WªÆ \W±7ª 7´^æªÆ· Ì fl «ªTÚ Ï œ Õ± º1º ß±´ _± Æ´7 ø7º ¨ø¥µ ¨± ß±´Æ ºøº Î ©W1¥ª TWª ©øT T¨1¥¥ ¨WªÆª· Í È fl fl7º TWª ¨±¥º ^ª ¨± øTµ ^ß ºøº ø7º ¨Wª7 ¨± _1™ª WªÆ ø \W±7ª 4ø¥¥Ú Ë Á “±Ù ! 檥1ª™ª TWª ¥ªJ¨Ú œ —µøßÚ ‹1º TWª øTµ ß±´ ß±´Æ ø_ª ©Wª7 TWª Wøº ¨Wø¨ 4±7™ªÆTø¨1±7 ©1¨W ß±´· Ô< fl “±Ù TWª º1º 7±¨Ú ÔÔ œ ‹1º ß±´ ¨ª¥¥ WªÆ ß±´Æ ø_ª· ÔÓ fl “±Ù ! º1º 7±¨Ú ÔÌ œ fl7º T± T±^ª©WªÆª ß±´ ©Æ±¨ª º±©7 ø \W±7ª ÔÏ 7´^æªÆ ¨± 4ø¥¥ WªÆ æø4µ ø¨· ÔÎ fl À^ÛW´^Ú ÔÍ œ fl¥¥ Æ1_W¨Ú fl –Ʊæøæ¥ß ]´T¨ ø \1ª4ª ±J \ø\ªÆ ¥ß17_ ÔÈ ÔË ÔÁ fl7º ©WªÆª º1º ß±´ ©Æ1¨ª ¨Wø¨ º±©7· øƱ´7º ¨Wª ºªTµÚ Ó< œ —µøßÚ ÓÔ fl ! ^ªø7Ù 7±Ù ! º±7˘¨ Wø™ª ¨Wø¨ \1ª4ª ±J ÓÓ fi´¨ ß±´ º±7˘¨ ƪ^ª^æªÆ· \ø\ªÆ ø7ß^±ÆªÙ T± 7±Ú ÓÌ œ —µøßÚ ÓÏ fl «ªTÚ ÓÎ œ fl7º ©Wø¨ 7´^æªÆ º± ß±´ ¨W17µ ß±´ 4ø¥¥ªº· fl7º º1º ß±´ ©Æ1¨ª º±©7 ø7 øººÆªTT· Case 18-2868, Document 283, 08/09/2019, 2628241, Page86 of 883 Ô œ …Wª7 º1º ß±´ _ª¨ ß±´Æ J1ÆT¨ 4øÆ· Ó fl flJ¨ªÆ ^ß ¨Æ1\ ¨± ‘±7º±7 ¨± ^ªª¨ –Æ174ª Ì fl7ºÆª©Ú Ï œ —µøßÚ Î fl fl ‹±º_ª ‹øµ±¨øÚ Í œ fl7º º1º ß±´ \´Æ4WøTª ¨Wø¨ ß±´ÆTª¥J· È fl «ªTÙ ! º1ºÚ Ë œ fl7º W±© ^´4W º1º 1¨ 4±T¨· Á fl ! º±7˘¨ ƪ^ª^æªÆ ±JJ ¨Wª ¨±\ ±J ^ß Wªøº Ô< …Wø¨ µ17º ±J 4øÆ º1º ß±´ _ª¨· W±© ^´4W 1¨ 4±T¨Ú ÔÔ œ …W± º1º ß±´ æ´ß 1¨ JƱ^· ÔÓ fl ”ß ºøº Wª¥\ªº ^ª æøÆ_ø17 ©1¨W 1¨Ú ÔÌ ! º±7˘¨ ƪ^ª^æªÆ ©WªÆª ©ª æ±´_W¨ 1¨ JƱ^Ú ÔÏ œ ÔÎ ºøº˘T 7ø^ª· ÔÍ fl ÔÈ ¨W17µÚ ÔË Æª_1T¨ªÆªº ø 4øÆ ±Æ ø7ߨW17_ ¥1µª ¨Wø¨ æªJ±ÆªÚ fl7º ©øT ¨Wª ¨1¨¥ª \´¨ 17 ß±´Æ 7ø^ª ±Æ ß±´Æ ! ¨W17µ ¨Wª ¨1¨¥ª ©øT \´¨ 17 ^ß 7ø^ªÚ ! ^ªø7Ù ^ß ºøº ©øT ©1¨W ^ªÚ !˘™ª 7ª™ªÆ Õ± ÛÛ ÔÁ œ Õ± ¨Wø¨ ©øT ß±´Æ J1ÆT¨ ¨1^ª· Ó< fl «ªTÚ ÓÔ œ ”ª^±Æø楪٠Æ1_W¨· ÓÓ fl «ªTÚ ÓÌ œ …Wª7 ß±´ _±¨ ¨WªÆªÙ ø æ´¨¥ªÆ ±Æ T±^ª±7ª ÓÏ ÓÎ ø7T©ªÆªº ¨Wª º±±ÆÙ 1T ¨Wø¨ ©Wø¨ ß±´ Tø1º· fl ! “±Ù ŸW1T¥ø17ª ø7T©ªÆªº ¨Wª º±±ÆÚ Case 18-2868, Document 283, 08/09/2019, 2628241, Page87 of 883 Ô fl «ªTÚ Ó œ …W± ª¥Tª ©øT ø¨ W±^ª ©Wª7 ß±´ _±¨ W±^ª· Ì fl ”ß ^±^Ù ^ß ºøº ø7º ^ß æƱ¨WªÆÚ Ï œ …W14W æƱ¨WªÆ· Î fl ÕµßÚ Í œ fl7º ø7ß±7ª ª¥Tª ©W± ©øT ¨WªÆª ø¨ ¨Wª ¨1^ª· È fl ! 檥1ª™ª ”14Wøª¥ ^1_W¨ Wø™ª 檪7 ¥1™17_ Ë ©1¨W ^ª ø¨ ¨Wø¨ ¨1^ªÚ Á Ô< ÔÔ Õ± Wª ^1_W¨ Wø™ª 檪7 ¨WªÆªÚ œ ‹± ß±´ ƪ4ø¥¥ 1J Wª ©øT ¨WªÆª ©Wª7 ß±´ _±¨ fl ! º±7˘¨ ƪø¥¥ß ƪ^ª^æªÆÚ W±^ª· ! ƪ^ª^æªÆ ©Wø¨ ÔÓ ! º1º ©Wª7 ! _±¨ W±^ªÙ ¨Wø¨ ! æøT14ø¥¥ß ^øºª ø ÔÌ æªª¥17ª J±Æ ¨Wª æø¨WƱ±^Ú ÔÏ œ ‘ª¨ ^ª øTµ ß±´ ø Ø´ªT¨1±7Ú ”14Wøª¥ ©øT ÔÎ ¥1™17_ ©1¨W ß±´ ø¨ ¨Wø¨ W±^ªÙ ø¨ ß±´Æ \øƪ7¨T˘ W±^ª ÔÍ ø¨ ¨Wª ¨1^ªÙ 1T ß±´Æ æªT¨ ƪ4±¥¥ª4¨1±7 ¨±ºøß 1T ¨Wø¨ ÔÈ Æ1_W¨· ÔË fl ÃWø¨˘T ^ß æªT¨ ƪ4±¥¥ª4¨1±7٠ߪTÚ ÔÁ œ …Wª7 ß±´ Tøß ¥1™17_ ©1¨W ß±´Ù ©ªÆª ß±´ Ó< _´ßT T¨øß17_ 17 ¨Wª Tø^ª Ʊ±^· ÓÔ fl «ªTÚ ÓÓ œ …ªÆª ß±´ ª7_ø_ªº ø¨ ¨Wø¨ ¨1^ª ¨± W1^· ÓÌ fl ÃWø¨ ©øT ø ƪø¥¥ß ©ª1ƺ ƪ¥ø¨1±7TW1\Ú ÿª ÓÏ ©øT ø JÆ1ª7º ©W± ¥±±µªº øJ¨ªÆ ^ªÙ ø7º Wª º1º \Ʊ\±Tª ÓÎ ¨± ^ª ø7º ! º1º Tøß ßªTÚ fi´¨ ^ß Wªøƨ ©øT 7ª™ªÆ 17 Case 18-2868, Document 283, 08/09/2019, 2628241, Page88 of 883 Ô 1¨Ú Ó Ì Ï ÿª ©øT T±^ªæ±ºß ¨Wø¨ Wª¥\ªº ^ª ±JJ ¨Wª T¨Æªª¨T T± ! 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Wøº ¨±¥º W1^ ^ß øººÆªTTÚ !¨ ©øT ø ™ªÆß Ø´1ª¨ Æ1ºªÚ ÔÎ œ ‹1º ß±´ Æ1ºª 17 ¨Wª JƱ7¨ ±Æ ¨Wª æø4µ· ÔÍ fl ÃWª JƱ7¨Ú ÔÈ œ !¨ 1T ß±´Æ 4±7¨ª7¨1±7 ¨Wø¨Ù ŸW1T¥ø17ª ÔË ”ø®©ª¥¥ Wøº Tª® ©1¨W ´7ºªÆø_ª _1Æ¥T ™1ƨ´ø¥¥ß ª™ªÆß ÔÁ ºøß ©Wª7 ! ©øT øƱ´7º WªÆÙ 4±Æƪ4¨· Ó< fl «ªTÚ ÓÔ œ fl¥¥ Æ1_W¨Ú ÓÓ ÓÌ …1¨W ©W±^ º1º ŸW1T¥ø17ª ”ø®©ª¥¥ Wø™ª Tª® 17 ß±´Æ \ƪTª74ª· fl …ª¥¥Ù ¨WªÆª˘T ø ¥±¨ ±J _1Æ¥T ¨Wø¨ ©ªÆª ÓÏ 17™±¥™ªºÚ ÓÎ ±¨WªÆÚ …ª ©ªÆª7˘¨ ±7 ø J1ÆT¨ 7ø^ª æøT1T ©1¨W ªø4W ! ©±´¥º7˘¨ æª ø楪 ¨± _1™ª ß±´ ¥1T¨T ±J 7ø^ªT Case 18-2868, Document 283, 08/09/2019, 2628241, Page90 of 883 Ô Ó Ì Ï Î ±J _1Æ¥TÚ œ !¨ ©øT 4±7¨17´±´TÚ !¨ ©øT 4±7¨17´±´TÚ “ø^ª ±7ª _1Æ¥ ¨Wø¨ ŸW1T¥ø17ª ”ø®©ª¥¥ Wøº Tª® ©1¨W 17 ß±´Æ \ƪTª74ªÚ fl ¤^^ß Ãøߥ±ÆÚ ! ^ªø7Ù ¨Wø¨˘T ø 7ø^ª ¨Wø¨ ! µ7±© ©ª¥¥ æª4ø´Tª ¤^^ß ©øT ø¥©øßT øƱ´7ºÚ Í !˘^ ¨Æß17_ ¨± ¨W17µ ±J WªÆ 7ø^ªÙ T±ÆÆßÚ È ÕøÆøWÚ Ë TWª˘T 4Wø7_ªº 1¨ 7±© ¨Wø¨ TWª˘T ^øÆÆ1ªºÚ ÿªÆ 7ø^ª ´Tªº ¨± æª ÕøÆøW ’ª¥¥ª7Ú Á ! ¨W17µ ¯\W±7ª¨14˜ ÛÛ ! 4ø7˘¨ Ô< \Ʊ7±´74ª WªÆ ¥øT¨ 7ø^ª \Ʊ\ªÆ¥ßÙ æ´¨ 1¨˘T øƱ´7º ÔÔ ¨W±Tª ¥17ªTÚ ÔÓ ÃWªÆª ©ªÆª ø ¥±¨ ±J ±¨WªÆ _1Æ¥T ¨Wø¨ ! ÔÌ W±7ªT¨¥ß 4ø7˘¨ ƪ^ª^æªÆ ¨Wª1Æ 7ø^ªTÚ ÔÏ ©1TW ! 4±´¥º Wª¥\ ±´¨ ^±Æª æª4ø´Tª ! ƪø¥¥ß ©±´¥º ÔÎ ¥1µª ¨± \Ʊ™1ºª ^±Æª ©1¨7ªTTªT J±Æ ¨W1TÙ æ´¨ ! 4ø7˘¨ ÔÍ Æª^ª^æªÆ ø ¥±¨ ±J _1Æ¥T˘ 7ø^ªTÚ ÔÈ ÔË œ ÓÔ ÓÓ ÓÎ Õ± ¨W±Tª øƪ ¨Wª ¨Wƪª 7ø^ªT ±J Jª^ø¥ªT ”ŒÚ ¤‹…flŒ‹ÕÊ —æ]ª4¨ ¨± ¨Wª J±Æ^Ú ”1T4WøÆø4¨ªÆ1¶ªT ¨ªT¨1^±7ßÚ œ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ ÛÛ 1T ¨Wø¨ ©Wø¨ ! ´7ºªÆT¨ø7º ß±´Æ ø7T©ªÆ ¨± 檷 ÓÌ ÓÏ ! ¨Wø¨ ß±´ ±æTªÆ™ªº ŸW1T¥ø17ª ”ø®©ª¥¥ Wø™ª Tª® ©1¨W ÛÛ ÔÁ Ó< !˘^ T±ÆÆßÚ ”ŒÚ ¤‹…flŒ‹ÕÊ —æ]ª4¨1±7Ú ”1T4WøÆø4¨ªÆ1¶ªT WªÆ ¨ªT¨1^±7ßÚ fl ÃW±Tª øƪ ÛÛ ¨W±Tª øƪ T±^ª ¨Wƪª ±J ¨Wª Case 18-2868, Document 283, 08/09/2019, 2628241, Page91 of 883 Ô œ ”±Æª ¨Wø7 Ó<· Ó fl ! ©±´¥º Tøß ^±Æª ¨Wø7 Ó<Ú Ì œ ”±Æª ¨Wø7 Î<· Ï fl ! º±7˘¨ ¨W17µ ^±Æª ¨Wø7 Î<Ù æ´¨ ÛÛ Î œ ‹1º ÛÛ Í fl ! º±7˘¨ Wø™ª ø7 ª®ø4¨ 7´^æªÆÚ ! ^ªø7Ù È 1J ÛÛ ! ¨W17µ 1J ß±´ ¥±±µ ø¨ ¨Wª J¥1_W¨ ¥±_TÙ ß±´ Ë µ7±©Ù ¨Wø¨ Wª¥\TÙ æ´¨ ¨Wª7 ¨Wªß˘Æª 7±¨ J´¥¥ß Á 4±^\¥ª¨ªÚ …ª ±7¥ß Wø™ª J¥1_W¨ ¥±_T ¨± ±7ª \¥ø7ª ø7º Ô< ¨Wª7 ¨WªÆª˘T ø ¨1^ª ! ©øT J¥±©7 4±^^ªÆ41ø¥¥ß 17¨± ¨Wª ÔÔ 1T¥ø7ºÚ ÔÓ œ À^ÛW´^Ú ÔÌ fl Õ± 1¨˘T ƪø¥¥ß Wøƺ J±Æ ^ª ¨± _ø´_ª ø ÔÏ ÔÎ ÔÍ ÔÈ ÔË ÔÁ 7´^æªÆÚ œ —µøßÚ ‹± ß±´ Wø™ª ø7ß \W±¨±_Æø\WT ±J ß±´ÆTª¥J ±7 ¨Wª 1T¥ø7º· fl ! µ7±© ! ´Tªº ¨±Ù æ´¨ ¨Wªß ©±´¥º æª ¥ªJ¨ 17 ¨Wø¨ ø\øƨ^ª7¨Ú œ …Wø¨ ±¨WªÆ ¥±4ø¨1±7T º1º ß±´ \øƨ141\ø¨ª Ó< 17 Tª®´ø¥ 4±7¨ø4¨ ©1¨W ŸW1T¥ø17ª ”ø®©ª¥¥Ù ±¨WªÆ ¨Wø7 ÓÔ ¨Wª 1T¥ø7º· ÓÓ fl ¤™ªÆß©WªÆªÚ ÓÌ œ …WªÆª 17 “ª© «±Æµ· ÓÏ fl ÃWª ^ø7T1±7Ù ÷ªJJÆªß˘T ^ø7T1±7Ú ÓÎ œ —µøßÚ “ª© «±ÆµÙ –ø¥^ fiªø4WÚ fl7ß©WªÆª ª¥Tª 17 “ª© «±Æµ· Case 18-2868, Document 283, 08/09/2019, 2628241, Page92 of 883 Ô ¨W17µ ! ^ª¨ –Æ174ª fl7ºÆª© 17 Ó<<ÔÚ Ó ø7º Õ¨ª\Wª7 ’ø´J^ø77 ©ªÆªÙ ¥1µª ! Tø1ºÙ ¨Wª J1ÆT¨ Ì \ª±\¥ª ! ©øT Tª7¨ ±´¨ ¨± øJ¨ªÆ ^ß ¨Æø1717_Ú Ï º±7˘¨ µ7±©Ú Î 1J ! º±7˘¨ µ7±© 1¨Ú fl7º Ÿ¥ª77 ‹´æ17 Õ± ! !˘^ 7±¨ _±17_ ¨± _1™ª ß±´ ø7 ª®ø4¨ ¨1^ª Í œ ! øTµªº ß±´ ¨Wª ƪ¥ø¨1™ª ±ÆºªÆÚ È fl fl7º !˘^ ¨Æß17_ ¨± _1™ª ß±´ 1¨Ú Ë œ fl7º ©WªÆª º±ªT fl¥ø7 ‹ªÆTW±©1¨¶ J1¨ 17¨± Á Ô< ÔÔ ¨Wø¨ _Ʊ´\ ±J \ª±\¥ª· fl Õø^ªÚ ! 4ø7˘¨ ¨ª¥¥ ß±´ \1ª4ª æß \1ª4ª æß \1ª4ª ©W± ÛÛ ! µ7±© Ÿ¥ª77 ‹´æ17 ©øT J1ÆT¨Ú ÔÓ œ —µøßÚ ÔÌ fl fl7º ! µ7±© Õ¨ª\Wª7 ’ø´J^ø77 ©øT ±7ª ±J ¨Wª ÔÏ J1ÆT¨ ! ©øT Tª7¨ ¨±Ú ÔΠ檨©ªª7 ¨WªÆªÚ ÔÍ Õ¨ª\Wª7Ú ÔÈ ©øT 17 “ª© «±ÆµÙ T± ! ©øT7˘¨ ø4¨´ø¥¥ß Tª7¨ ¨± W1^Ú ÔË !¨ ø4¨´ø¥¥ß Wø\\ª7ªº ø¨ ±7ª ±J ÷ªJJÆªß˘T ƪT1ºª74ªTÚ ÔÁ Ó< ÓÔ ÓÓ fl¥ø7 ‹ªÆTW±©1¨¶ 4±´¥º Wø™ª 檪7 fiª¨©ªª7Ù T±ÆÆß٠檨©ªª7 Ÿ¥ª77 ø7º ÃWª J1ÆT¨ ¨1^ª ! ©øT ©1¨W fl¥ø7 ‹ªÆTW±©1¨¶ ¯”TÚ ”4›ø©¥ªß ¥ªJ¨ ¨Wª ºª\±T1¨1±7Ú˜ fl Õ± 1¨˘T ™ªÆß Wøƺ J±Æ ^ª ¨± 4WƱ7±¥±_14ø¥¥ß _1™ª ß±´ ªø4W \ªÆT±7 17º1™1º´ø¥¥ßÚ œ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ —µøßÚ “ø^ª ¨Wª ±¨WªÆ ÓÌ \±¥1¨14ø¥¥ß 4±77ª4¨ªº ø7º J17ø741ø¥¥ß \±©ªÆJ´¥ \ª±\¥ª ÓÏ ¨Wø¨ ŸW1T¥ø17ª ”ø®©ª¥¥ ¨±¥º ß±´ ¨± _± Wø™ª Tª® ©1¨W· ÓÎ fl fl_ø17Ù !˘^ _±17_ ¨± ¨ª¥¥ ß±´ ˛¨Wªß˛ Case 18-2868, Document 283, 08/09/2019, 2628241, Page93 of 883 Ô æª4ø´Tª ¨Wø¨˘T W±© 1¨ ©ª7¨Ú Ó ¨± Ÿª±Æ_ª ”1¨4Wª¥¥Ù ÷ªø7 ‘´4 fiÆ´7ª¥Ù fi1¥¥ Œ14WøƺT±7Ù Ì ø7±¨WªÆ \Æ174ª ¨Wø¨ ! º±7˘¨ µ7±© W1T 7ø^ªÚ Ï ¨Wø¨ ±©7T ø W±¨ª¥Ù ø ƪø¥¥ß ¥øÆ_ª W±¨ª¥ 4Wø17Ù ! 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Ô< «±´ µ7±©Ù ! ©øT ¨±¥º ¨± º± T±^ª¨W17_ æß ¨WªTª \ª±\¥ª ÔÔ 4±7T¨ø7¨¥ßÙ ¨±¥º ¨± ÛÛ ^ß ©W±¥ª ¥1Jª ƪ™±¥™ªº øƱ´7º ÔÓ ]´T¨ \¥ªøT17_ ¨WªTª ^ª7 ø7º µªª\17_ ŸW1T¥ø17ª ø7º ÔÌ ÷ªJJÆªß Wø\\ßÚ ÔÏ øƱ´7º Tª®Ú ÔÎ ÔÍ ÃWª1Æ ©W±¥ª ª7¨1ƪ ¥1™ªT ƪ™±¥™ªº ÃWªß 4ø¥¥ ^øTTø_ªT Tª®Ú ^±ºª¥17_ Tª®Ú ÔÈ œ ÃWªß 4ø¥¥ ÃWªß 4ø¥¥ ÛÛ ! øTµªº ß±´ ¨Wª 7ø^ªT J±Æ \ª±\¥ªÚ flƪ ß±´ ÔË _±17_ ¨± ¨ª¥¥ ^ª ø7ß ±¨WªÆ 7ø^ªT ±Æ 1T ¨Wø¨ ø¥¥ ±J ÔÁ ¨Wª^· Ó< fl !˘^ ¨Æß17_ ¨± ¨W17µÚ ÃWø¨˘T ¨Wª ø7T©ªÆ ÓÔ !˘^ ¨Æß17_ ¨± _1™ª ¨± ß±´Ú ÓÓ ]´T¨ µªª\ 7ø^17_ ø7º 7ø^17_ ø7º 7ø^17_Ú !¨˘T ¨Wø¨ 1¨˘T T± Wøƺ ¨± ÓÌ œ fl¥¥ Æ1_W¨Ú ÓÏ fl fl ¥±¨ ±J ¨1^ªT ! ©±´¥º æª 17¨Æ±º´4ªº ¨± ÓÎ ¨Wª^Ú ! º1º7˘¨ µ7±© ÛÛ Case 18-2868, Document 283, 08/09/2019, 2628241, Page94 of 883 Ô ^ø7ß ¨1^ªT ß±´ ©ø7¨ ^ª ¨± µªª\ ø7T©ªÆ17_ ¨W1T Ó Ø´ªT¨1±7Ú Ì Tª7¨ ^ª ¨± ¨WªTª \ª±\¥ªÚ Ï Î Í fi±¨W ¨±¥º ^ª ¨± º± ¨W1TÙ ±µøß· ÃWªß 汨W ÿ±© ^ø7ß ¨1^ªT º± ß±´ ©ø7¨ ^ª ¨± ø7T©ªÆ ¨W1T· œ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ ! ¨W17µ ß±´˘Æª È ø7T©ªÆ17_ ø º1JJªÆª7¨ Ø´ªT¨1±7 T± ¨Wø¨˘T ©Wß !˘^ Ë _±17_ ¨± øTµ ß±´ ø_ø17Ú Á øæ±´¨ ø ¨1^ª ©Wª7 ÷ªJJÆªß ø7º ŸW1T¥ø17ª ¨±_ª¨WªÆ ¨±¥º ! ø^ 7±¨ øTµ17_ ß±´ ø7ߨW17_ Ô< ß±´ ¨± _± º± T±^ª¨W17_Ú ÔÔ T17_¥ª ¨1^ª º´Æ17_ ©W14W ŸW1T¥ø17ª ”ø®©ª¥¥ ø4¨17_ ÔÓ ø¥±7ª º1ƪ4¨ªº ß±´ ¨± _± Wø™ª Tª® ©1¨W ø7±¨WªÆ ÔÌ \ªÆT±7· ÔÏ ÔÎ ÔÍ !˘^ øTµ17_ ß±´ ¨± 7ø^ª ø ”ŒÚ ¤‹…flŒ‹ÕÊ ø7T©ªÆªºÚ fl ÿøÆøTT17_Ú —æ]ª4¨1±7Ú flTµªº ø7º flÆ_´^ª7¨ø¨1™ªÚ !˘™ª _1™ª7 ß±´ ¨Wª 7ø^ªT ±J ¨Wª \ª±\¥ª ÔÈ ¨Wø¨ ŸW1T¥ø17ª 17T¨Æ´4¨ªº ^ª ¨± _± Wø™ª Tª®´ø¥ ÔË Æª¥ø¨1±7T ©1¨WÚ ÔÁ ¨Wø¨ ÷ªJJÆªß ø¥T± ¨±¥º ^ªÚ Ó< ! ø^ 7±¨ º1T4¥´º17_ ¯T14˜ ¨Wª Jø4¨ ŸW1T¥ø17ª ¨±¥º ^ª JƱ^ WªÆ ^±´¨W ¨± º± ÓÔ ¨WªTª ¨W17_TÚ ÓÓ ¨WªTª ¨W17_T ©1¨W ¨WªTª \ª±\¥ªÚ ÓÌ ^ª ¨± º± ¨Wª ¨W17_T ¨Wø¨ ! º1º ©1¨W ÷ªJJÆªß ¤\T¨ª17 ÓÏ ±7 ¨Wª ™ªÆß J1ÆT¨ ^ªª¨17_ ¨Wø¨ ! Wøº ©1¨W W1^Ú ÓÎ æƱ´_W¨ ^ª ¨WªÆª ´7ºªÆ ¨Wª \ƪ4¥´T1±7 ¯T14˜ ¨Wø¨ ! ÷ªJJÆªß ¨±¥º ^ª JƱ^ W1T ^±´¨W ¨± º± ŸW1T¥ø17ª 17T¨Æ´4¨ªº ÕWª Case 18-2868, Document 283, 08/09/2019, 2628241, Page95 of 883 Ô ©øT _±17_ ¨± æª ¨Æø17ªº øT ø ^øTTª´Tª ø7º ¨Wø¨ TWª Ó 17T¨Æ´4¨ªº ^ª ¨± ¨øµª ±JJ ^ß 4¥±¨WªT ø7º ¨± _1™ª ±Æø¥ Ì Tª® ¨± ÷ªJJÆªß ¤\T¨ª17Ú Ï Î œ ¤®4´Tª ^ªÚ !˘™ª øTµªº ß±´ J±Æ ¨Wª 7ø^ªTÚ Í È ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ fl !˘™ª ]´T¨ _1™ª7 ß±´ ø 7ø^ªÚ ÷ªJJÆªß ¤\T¨ª17 1T ø æ1_ 7ø^ªÚ Ë œ fl¥¥ Æ1_W¨Ú Á fl ÕWª 17T¨Æ´4¨ªº ^ª ±7 ¨Wø¨ ±7ªÚ Ô< œ Õ± ß±´˘Æª Tøß17_ ÛÛ ÔÔ ”ŒÚ ¤‹…flŒ‹ÕÊ ÃWª ©1¨7ªTT 1T J171TW17_ WªÆ ÔÓ ø7T©ªÆ Æ1_W¨ 7±©Ú ÔÌ ±7ª ±J ¨Wª \ª±\¥ª ŸW1T¥ø17ª ¨±¥º WªÆ ¨± Wø™ª Tª® ÔÏ ©1¨WÚ ÔÎ œ ÕWª˘T 17 ¨Wª \Ʊ4ªTT ±J ª®\¥ø1717_ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ Õ± ß±´˘Æª Tøß17_ ÔÍ ŸW1T¥ø17ª ”ø®©ª¥¥ º1ƪ4¨ªº ß±´ ¨± Wø™ª Tª® ©1¨W ÔÈ ÷ªJJÆªß ¤\T¨ª17· ÔË fl ›±Æƪ4¨Ú ÔÁ œ ŸW1T¥ø17ª ”ø®©ª¥¥ º1ƪ4¨ªº ß±´ ¨± Wø™ª Tª® Ó< ©1¨W Ÿ¥ª77 ‹´æ17· ÓÔ fl ›±Æƪ4¨Ú ÓÓ œ …Wø¨ ©±ÆºT º1º ŸW1T¥ø17ª ”ø®©ª¥¥ ¨ª¥¥ ß±´ ÓÌ ÓÏ ÓÎ ¨± _± Wø™ª Tª® ©1¨W Ÿ¥ª77 ‹´æ17· fl !¨ ©øT ¨Wª Tø^ª ø¥¥ ¨Wª ¨1^ªÙ ø¥¥ Æ1_W¨· ÃWªß ©ø7¨ ^ª ¨± _± \Ʊ™1ºª ¨WªTª ^ª7 ©1¨W ø ^øTTø_ªÚ Case 18-2868, Document 283, 08/09/2019, 2628241, Page96 of 883 Ô fl …Wª7 1¨ Wø\\ª7ªº· Ó œ …Wª7 ŸW1T¥ø17ª ”ø®©ª¥¥ ´Tªº ¨Wª ©±ÆºTÙ Ÿ± Ì _1™ª ø ^øTTø_ª ¨± fi1¥¥ Œ14WøƺT±7Ù ©WªÆª ©ªÆª ß±´· Ï Î ”ŒÚ ¤‹…flŒ‹ÕÊ —æ]ª4¨ ¨± ¨Wª J±Æ^Ú ”1T4WøÆø4¨ªÆ1¶ªT WªÆ ¨ªT¨1^±7ßÚ Í fl ! 4ø7˘¨ ¨ª¥¥ ß±´ ©WªÆª ©ª ©ªÆªÚ È ©WªÆª ! ©øT Tª7¨ ¨±Ú Ë TWª ¨±¥º ^ª ¨± º± ¨Wø¨Ú Á ! º±7˘¨ µ7±© ©WªÆª ©ª ©ªÆª ©Wª7 œ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ ÔÔ fl “ª© ”ª®14±Ú ÔÓ œ ÛÛ æß ŸW1T¥ø17ª ”ø®©ª¥¥· Ô< …WªÆª ©ªÆª ß±´ Tª7¨ ¨± ÛÛ ÔÌ ÔÏ ! µ7±© ”ŒÚ ¤‹…flŒ‹ÕÊ —æ]ª4¨ ¨± ¨Wª J±Æ^Ú ”1T4WøÆø4¨ªÆ1¶ªT WªÆ ¨ªT¨1^±7ß ø_ø17Ú ÔÎ fl flƪ ß±´ T^1¥17_ ø¨ ^ª æª4ø´Tª ÛÛ ÔÍ œ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ ÔÈ ÔË ÔÁ “±Ù !˘^ øTµ17_ ß±´ ¨± ø7T©ªÆ ¨Wª Ø´ªT¨1±7Ú fl ! Wø™ª ø7T©ªÆªº ¨Wª Ø´ªT¨1±7Ú ¨± “ª© ”ª®14±Ú Ó< œ —µøßÚ ÓÔ fl ! ø¥Æªøºß ø7T©ªÆªº ¨Wø¨Ú ÓÓ ! ©øT Tª7¨ …WªÆª ©ªÆª ß±´ Tª7¨ JƱ^· ! º±7˘¨ µ7±© ©WªÆª ! ©øT Tª7¨ JƱ^Ú ÓÌ œ —µøßÚ ÓÏ fl ! ©øT J¥ß17_ ª™ªÆß©WªÆª ©1¨W ¨WªTª \ª±\¥ªÚ ÓÎ œ …WªÆª ©ªÆª ß±´ Tª7¨ æß ŸW1T¥ø17ª ”ø®©ª¥¥ Case 18-2868, Document 283, 08/09/2019, 2628241, Page97 of 883 Ô Ó Ì fl “±Ù &'ª ©ø& +±¨ -+ ¨'ª Ʊ±/Ú Õ'ª ©ø& -+ ø+±¨'ªÆ 3øæø+øÚ œ fl+º ±¨'ªÆ ¨'ø+ ¨ª¥¥-+9 ß±´ ¨± 9± 9-™ª ¨'ª Ï ±©+ªÆ ±> ¨'-& ¥øÆ9ª '±¨ª¥ 3'ø-+ ø /ø&&ø9ªÙ º± ß±´ Πƪ/ª/æªÆ ø+ß ±¨'ªÆ ©±Æº& &'ª ´&ªº ¨± ß±´ ¨± º-ƪ3¨ Í ß±´ -+ ©'ø¨ ß±´ &'±´¥º º±· È fl “±¨ ø¨ ¨'ª ¨-/ªÙ +±Ú Ë œ …'ªÆª º-º ÛÛ ©'ªÆª ©ªÆª ß±´ ø+º ©'ªÆª ©ø& Á ÔI ”&Ú ”ø®©ª¥¥ ©'ª+ &'ª º-ƪ3¨ªº ß±´ ¨± 9± 'ø™ª &ª® ©-¨' ”øÆ™-+ ”-+&µß· ÔÔ ”ŒÚ ¤‹…flŒ‹ÕÊ —æPª3¨ ¨± ¨'ª >±Æ/Ú ÔÓ fl Q º±+˘¨ µ+±©Ú ÔÌ œ ¯fi« ”ÕÚ ”¤““Q“Ÿ¤Œ˜ ÔÏ ÔÎ ÔÍ ÔÈ …'ªÆª º-º ß±´ 9± ¨± 'ø™ª &ª® ©-¨' ”øÆ™-+ ”-+&µß· fl Q 檥-ª™ª -¨ ©ø& ¨'ª ÀÚÕÚ -Æ9-+ Q&¥ø+º&Ù ÷ª>>˘& ÛÛ &±ÆÆßÙ ÷ª>>Æªß ¤[&¨ª-+˘& -&¥ø+º -+ ¨'ª ÀÚÕÚ -Æ9-+ Q&¥ø+º&Ú ÔË œ fl+º ©'ª+ ©ø& ¨'ø¨· ÔÁ fl Q º±+˘¨ µ+±©Ú ÓI œ ‹± ß±´ 'ø™ª ø+ß ¨-/ª ±> ߪøÆ· ÓÔ fl “±Ú ÓÓ œ ‹± ß±´ µ+±© '±© ±¥º ß±´ ©ªÆª· ÓÌ fl “±Ú ÓÏ œ —¨'ªÆ ¨'ø+ Ÿ¥ª++ ‹´æ-+Ù Õ¨ª['ª+ ’ø´>/ø++Ù ÓÎ –Æ-+3ª fl+ºÆª©Ù ÷ªø+ ‘´3 fiÆ´+ª¥Ù fi-¥¥ Œ-3'øƺ&±+Ù Case 18-2868, Document 283, 08/09/2019, 2628241, Page98 of 883 Ô ø+±¨'ªÆ [Æ-+3ªÙ ¨'ª ¥øÆ9ª '±¨ª¥ 3'ø-+ ±©+ªÆ ø+º Ó ”øÆ™-+ ”-+&µßÙ -& ¨'ªÆª ø+ß±+ª ª¥&ª ¨'ø¨ Ÿ'-&¥ø-+ª Ì ”ø®©ª¥¥ º-ƪ3¨ªº ß±´ ¨± 9± 'ø™ª &ª® ©-¨'· Ï Î fl Q ø/ ºª>-+-¨ª¥ß &´Æª ¨'ªÆª -&Ú Æª/ª/æªÆ ª™ªÆßæ±ºß˘& +ø/ª· Í œ È øæ±´¨ ¨'ª/· Ë fl Á +±©Ú —µøßÚ “±Ú ›ø+ ß±´ ƪ/ª/æªÆ ø+ߨ'-+9 ª¥&ª ‘±±µÙ Q˘™ª 9-™ª+ ß±´ ©'ø¨ Q µ+±© Æ-9'¨ Q˘/ &±ÆÆßÚ Ã'-& -& ™ªÆß 'øƺ >±Æ /ª ø+º ™ªÆß ÔI >Æ´&¨Æø¨-+9 ¨± 'ø™ª ¨± 9± ±™ªÆ ¨'-&Ú ÔÔ º±+˘¨ ƪ3ø¥¥ ø¥¥ ±> ¨'ª [ª±[¥ªÚ ÔÓ ø/±´+¨ ±> [ª±[¥ª ¨'ø¨ Q ©ø& &ª+¨ ¨±Ú ÔÌ ÔÏ œ fi´¨ 3ø+ Q Q º±+˘¨ ÛÛ Q Ã'ªÆª ©ø& ø ¥øÆ9ª ‹± ß±´ 'ø™ª ø+ß +±¨ª& ±> ø¥¥ ¨'ª&ª [ª±[¥ª ¨'ø¨ ß±´ ©ªÆª &ª+¨ ¨±· ÔÎ fl “±Ù Q º±+˘¨Ú ÔÍ œ …'ªÆª øƪ ß±´Æ +±¨ª&· ÔÈ fl Q æ´Æ+ªº ¨'ª/Ú ÔË œ …'ª+ º-º ß±´ æ´Æ+ ¨'ª/· ÔÁ fl Q+ ø æ±+>-ƪ ©'ª+ Q ¥-™ªº ø¨ Ã-¨´&™-¥¥ª ÓI ÓÔ æª3ø´&ª Q ©ø& &-3µ ±> 9±-+9 ¨'Ʊ´9' ¨'-& &'-¨Ú œ ‹-º ß±´ 'ø™ª ¥ø©ßªÆ& ©'± ©ªÆª ƪ[ƪ&ª+¨-+9 ÓÓ ß±´ ø¨ ¨'ª ¨-/ª ß±´ æ´-¥¨ ø æ±+>-ƪ ø+º æ´Æ+ªº ¨'ª&ª ÓÌ +±¨ª&· ÓÏ fl ÓÎ Q˘™ª 檪+ ƪ[ƪ&ª+¨ªº >±Æ ø ¥±+9 ¨-/ªÙ æ´¨ -¨ ©ø& +±¨ ´+ºªÆ ¨'ª -+&¨Æ´3¨-±+ ±> /ß ¥ø©ßªÆ& ¨± º± Case 18-2868, Document 283, 08/09/2019, 2628241, Page99 of 883 Ô ¨'-&Ú Ó ø+º ©ª 檥-ª™ªº ¨'ø¨ ¨'ª&ª /ª/±Æ-ª& ©ªÆª ©±Æ¨' Ì æ´Æ+-+9Ú Ï ”ß '´&æø+º ø+º Q ©ªÆª [ƪ¨¨ß &[-Æ-¨´ø¥ [ª±[¥ª œ Õ± ß±´ æ´Æ+ªº +±¨ª& ±> ¨'ª /ª+ ©-¨' ©'±/ Î ß±´ 'øº &ª® ©'-¥ª ß±´ ©ªÆª ƪ[ƪ&ª+¨ªº æß 3±´+&ª¥ -+ Í ¥-¨-9ø¨-±+Ù 3±Æƪ3¨· È ”ŒÚ ¤‹…flŒ‹ÕÊ Ë Á ÔI fl º±3´/ª+¨Ú ÔÓ Ã'-& ©ø&+˘¨ ø+ߨ'-+9 ¨'ø¨ ©ø& ø [´æ¥-3 Ã'-& ©ø& /ß ±©+ [Æ-™ø¨ª P±´Æ+ø¥Ù ø+º Q º-º+˘¨ ©ø+¨ -¨ ø+ß/±ÆªÚ ÔÔ œ —æPª3¨ ¨± ¨'ª >±Æ/Ú Õ± ©ª æ´Æ+ªº -¨Ú ¯fi« ”ÕÚ ”¤““Q“Ÿ¤Œ˜ …'ª+ º-º ß±´ ©Æ-¨ª ¨'ø¨ P±´Æ+ø¥· ÔÌ fl ÷´&¨ ±™ªÆ ¨-/ªÚ Q &¨øƨªº ©Æ-¨-+9 -¨ ÔÏ [Ʊæøæ¥ß -+Ù Q º±+˘¨ µ+±©Ù Q 3ø+˘¨ &[ª3´¥ø¨ªÙ ÓIÔÓÙ ÔÎ ÓIÔÔÚ ÔÍ ÔÈ œ Õ± ß±´ º-º +±¨ ©Æ-¨ª ¨'-& P±´Æ+ø¥ ø¨ ¨'ª ¨-/ª -¨ 'ø[[ª+ªº· ÔË fl “±Ú ÔÁ œ «±´ &¨øƨªº ©Æ-¨-+9 ¨'-& P±´Æ+ø¥ ÓI ø[[Ʊ®-/ø¨ª¥ß ø ºª3øºª ø>¨ªÆ ß±´ 3¥ø-/ ß±´ >-+-&'ªº ÓÔ æª-+9 &ª®´ø¥¥ß ¨Æø>>-3µªºÙ 3±Æƪ3¨· ÓÓ fl «ª&Ú ÓÌ œ fl+º ß±´ &¨øƨªº ©Æ-¨-+9 ø P±´Æ+ø¥ ø>¨ªÆ ÓÏ ÓÎ ß±´ 'øº ø ¥ø©ßªÆÙ 3±Æƪ3¨· fl ›±Æƪ3¨Ú Case 18-2868, Document 283, 08/09/2019, 2628241, Page100 of 883 Ô Ó Ãÿ¤ Q‹¤—ŸŒfl–ÿ¤ŒÊ …ª˘Æª æø3µ ±+ ¨'ª ƪ3±Æº ø¨ ÓÊÎÎÚ Ì œ ¯fi« ”ÕÚ ”¤““Q“Ÿ¤Œ˜ ‹± ß±´ 'ø™ª ø+ß Ï ['±¨±9Æø['& ±> ß±´Æ&ª¥> ª-¨'ªÆ +´ºª ±Æ -+ ø &ª®´ø¥¥ß Î 3±/[Ʊ/-&-+9 [±&-¨-±+ ¨'ø¨ ß±´ 3¥ø-/ ©ªÆª ¨øµª+ æß Í Ÿ'-&¥ø-+ª ”ø®©ª¥¥· È fl Q º± +±¨ 'ø™ª ø+ß ±> ¨'±&ª -+ /ß ª™-ºª+3ªÚ Ë fi´¨ -> ß±´ ø&µ Ÿ'-&¥ø-+ª ”ø®©ª¥¥Ù &'ª ©±´¥º 'ø™ª Á [¥ª+¨ßÚ ÔI ÔÔ œ ‹± ß±´ 'ø™ª ø+ß -+ ß±´Æ &¨±Æø9ª æ±®ª& -+ Õߺ+ªß· ÔÓ fl “±Ú ÔÌ œ ‹± ß±´ µ+±© ©'ª¨'ªÆ ß±´Æ ø¨¨±Æ+ªß& 'ø™ª ÔÏ ø+ß &´3' ['±¨±9Æø['& ¨'ø¨ ß±´ 3¥ø-/ ©ªÆª ¨øµª+ æß ÔÎ Ÿ'-&¥ø-+ª ”ø®©ª¥¥· ÔÍ fl “±Ú ÔÈ œ «±´ º±+˘¨ µ+±© ±Æ ¨'ªß º±+˘¨ 'ø™ª ¨'ª/· ÔË fl Q º±+˘¨ µ+±©Ú fl+º Q º±+˘¨ ¨'-+µ ¨'ªß 'ø™ª ÔÁ ¨'ª/Ú ÓI «±´ &'±´¥º ø&µ ß±´Æ 3¥-ª+¨Ú ÓÔ ¨'ª/Ú ÓÓ ÓÌ ÓÏ ÓÎ Q> ¨'ªß 'øº ¨'ª/Ù ¨'ªß ©±´¥º 'ø™ª ¨±¥º /ªÚ Õ'ª˘& 9±¨ [¥ª+¨ß ±> œ …'ø¨ ¨ß[ª ±> 3ø/ªÆø º-º Ÿ'-&¥ø-+ª ”ø®©ª¥¥ fl Q¨ ©ø& ø æ¥ø3µ 3ø/ªÆøÚ ´&ª· fl+º -¨ 'øº øÙ Q º±+˘¨ µ+±© ¨'ª ¨ß[ª& ø+º +ø/ª& ±> ¨'ª/Ù æ´¨ ¨'ª ¥ª+& Case 18-2868, Document 283, 08/09/2019, 2628241, Page101 of 883 Ô ¨'ø¨ 9±ª& ±´¨Ú Ó œ …ø& -¨ º-9-¨ø¥ ±Æ &-+9¥ª ƪ>¥ª®· Ì fl fl9ø-+Ù Q º±+˘¨ µ+±© ¨ß[ª& ±> 3ø/ªÆø&Ú Q Ï /ªø+Ù Q ´&ª /ß ['±+ª >±Æ ´&-+9 ø 3ø/ªÆøÚ Î æ¥ø3µ 3ø/ªÆø ø+º -¨ 'øº ø ¥ª+& ¨'ø¨ ß±´ 3±´¥º [´¨ ±´¨ Í >´Æ¨'ªÆ ±Æ æÆ-+9 æø3µÚ È Õ± -¨˘& ø œ ‹-º ß±´ ø&µ 'ªÆ ¨± ¨øµª ø+ß ['±¨±9Æø['& ±> Á fl “±Ú ÔI œ …ø& -¨ ø >-¥/ ±Æ ø º-9-¨ø¥ 3ø/ªÆø· ÔÔ fl Q +ª™ªÆ &ø© '±© &'ª [Æ-+¨ªº ¨'ª/ ±´¨Ú ÔÓ œ …'ø¨˘& ¨'ª >-Æ&¨ ¨-/ª ß±´ ¨±¥º ø+ßæ±ºß Ë ÔÌ ß±´· ¨'ø¨ ß±´ 'øº 檪+ &ª®´ø¥¥ß ¨Æø>>-3µªº· ÔÏ ÔÎ Õ'ª ø&µªº ¨± ¨øµª ['±¨±9Æø['& ±> /ªÚ ”ŒÚ ¤‹…flŒ‹ÕÊ fl ⁄±Æ/Ú Ã±+ß ⁄-9´ªÆ±øÙ /ß ª®Ûæ±ß>Æ-ª+ºÙ µ+ª© &±/ª ÔÍ ±> ¨'ª &¨´>> ¨'ø¨ ©ø& 'ø[[ª+-+9Ù ¨'±´9' Q º-º +±¨ 9± ÔÈ -+ 9ƪø¨ ºª¨ø-¥ ¨± '-/Ù æª-+9 ¨'ø¨ 'ª˘& /ß æ±ß>Æ-ª+ºÚ ÔË fl+º ¨'ª+ ¨'ª >-Æ&¨ [ªÆ&±+ Q ƪø¥¥ß ±[ª+ªº ´[ ¨± øæ±´¨ ÔÁ ª™ªÆߨ'-+9 ©ø& /ß '´&æø+ºÚ ÓI œ ¯fi« ”ÕÚ ”¤““Q“Ÿ¤Œ˜ ‹-º ß±´ ¨ª¥¥ ñ+ß ÓÔ ⁄-9´ªÆ±ø ¨'ø¨ ß±´ ©ªÆª >±Æ3ªº ¨± 'ø™ª &ª® ©-¨' ÓÓ ÷ª>>Æªß ¤[&¨ª-+· ÓÌ fl «ª&Ú ÓÏ œ ‹-º ß±´ ¨ª¥¥ ñ+ß ⁄-9´ªÆ±ø ß±´ ©ªÆª >±Æ3ªº ÓÎ ¨± 'ø™ª &ª® ©-¨' Ÿ'-&¥ø-+ª ”ø®©ª¥¥· Case 18-2868, Document 283, 08/09/2019, 2628241, Page102 of 883 Ô ø+ß -+¨ªÆø3¨-±+& ©-¨' ¥ø© ª+>±Æ3ª/ª+¨· Ó fl «ª&Ú Ì œ …'ª+· Ï fl …'ª+ Q ¨Æ-ªº ¨± æƪøµ ø©øß >Ʊ/ ÷ª>>Æªß Î ø+º Ÿ'-&¥ø-+ªÙ Q &¨øƨªº /øµ-+9 /ß&ª¥> ´+ø™ø-¥øæ¥ªÚ Í fl+º Q 9±¨ ø P±æ ø¨ Œ±øº ÿ±´&ª ŸÆ-¥¥Ú È ¨± 3±/ª [-3µ /ª ´[ -+ ¨'ª ø>¨ªÆ+±±+&Ù ø¨ +-9'¨¨-/ªÙ Ë ø+º 'ª˘º &-¨ ø¨ ¨'ª æøÆÚ Á ¨'ø¨˘& 9±¨ ¨-[& -+ -¨Ú ÔI fl+º ñ+ß ´&ªº fl+º ¨'ªÆª˘& ¨'-& æ-9 3´[ Q ©ø& -+ ¨'ª æø3µ Ʊ±/Ú fl+º Q 'øº ¨± ÛÛ ÔÔ >-Æ&¨ ß±´ 'ø™ª ¨± &-9+ ±´¨ ø+º ß±´ 'ø™ª ¨± ¨øµª ±>> ÔÓ ß±´Æ ø[Ʊ+&Ù [´¨ ß±´Æ ø[Ʊ+& ø©øßÚ ÔÌ ©'±¥ª æ´+3' ±> 3¥ªø+-+9 ´[ &¨´>> ß±´ 'ø™ª ¨± º±Ú ÔÏ fl+º ¨'ªÆª˘& ø Q+ ¨'ø¨ ¨-/ª [ªÆ-±ºÙ ñ+ß 9Æøæ檺 /±+ªß ÔÎ >Ʊ/ ø 3´[ ¨'ø¨ 'øº /±+ªß -+ -¨Ú ÔÍ æøƨª+ºªÆ& >±Æ ¨'ª-Æ ¨-[&Ú ÔÈ +ª®¨ ºøßÚ ÔË ©'-3' Q 'øº+˘¨Ú ÔÁ /±+ªß ø>¨ªÆ Q 3±+>Ʊ+¨ªº ñ+ß øæ±´¨ -¨Ú ÓI /±+ªß æø3µ ¨± '-/ ø+º 'ª &ø-ºÙ Q˘/ &±ÆÆßÙ æ´¨ -¨˘& ÓÔ P´&¨ ¥ø© ¨'ø¨ Q 'ø™ª ¨± 3ø¥¥ ¨'ª [±¥-3ªÚ ÓÓ 3ø¥¥ªº ¨'ª [±¥-3ªÚ ÓÌ Ã'ø¨ ©ø& >±Æ ¨'ª ”ß æ±&& 3ø¥¥ªº /ª ¨'ª ÿª ¨±¥º /ª ¨'ø¨ Q 'øº &¨±¥ª+ ¨'ª /±+ªßÙ fl+º Q 3ø/ª æø3µ ø+º Q ƪ¨´Æ+ªº ¨'ª Ÿø™ª ¨'ª Õ± 'ª fl+º µ+±©-+9 ¨'ø¨ ÷ª>>Æªß 'ø& 9±¨ ¨'ª –ø¥/ ÓÏ fiªø3' –±¥-3ª ‹ª[øƨ/ª+¨ -+ '-& [±3µª¨Ù Q ©ª+¨ ¨± ÓÎ ÷ª>>Æªß ¤[&¨ª-+ ø+º Q ¨±¥º '-/ ©'ø¨ 'øº 'ø[[ª+ªºÚ Case 18-2868, Document 283, 08/09/2019, 2628241, Page103 of 883 Ô fl+º ÷ª>>Æªß &ø-ºÙ ‹±+˘¨ ©±ÆÆß øæ±´¨ -¨Ú Ó 3øƪ ±> -¨ >±Æ ß±´Ú Ì Ï œ —µøßÚ Q˘/ &±ÆÆßÚ ‘ª¨ /ª ¨øµª …'ª+ º-º ß±´ 'ø™ª -+¨ªÆø3¨-±+ ©-¨' ¥ø© ª+>±Æ3ª/ª+¨Ù ¨'ª+· Î fl …'ø¨ ߪøÆ· Í œ ‹-º ß±´ &[ªøµ ©-¨' ø ¥ø© ª+>±Æ3ª/ª+¨ È Ë Á ÔI ±>>-3ªÆ· fl Q º±+˘¨ 檥-ª™ª Q &[±µª ¨± ¨'ª/Ú ÷ª>>Æªß 'ø+º¥ªº ª™ªÆߨ'-+9Ú œ —µøßÚ fl+º ß±´ &ø-º ¨'ø¨ ß±´ 'øº >-+-&'ªº ÔÔ ß±´Æ &'->¨ ø¨ ÛÛ ¨'-& -& ø¨ ¨'ª Œ±øº ÿ±´&ª ŸÆ-¥¥Ù ÔÓ 3±Æƪ3¨· ÔÌ fl ›±Æƪ3¨Ú ÔÏ œ «±´ 'øº >-+-&'ªº ß±´Æ &'->¨· ÔÎ fl «ªø'Ù -¨ ©ø& ¨'ª ª+º ±> ¨'ª &'->¨Ú ÔÍ œ —µøßÚ ÔÈ ÔË fl+º ß±´ 'øº 3¥ªø+ªº ´[ ø+º ©ªÆª 3'ª3µ-+9 ±´¨Ù 3±Æƪ3¨· fl «ªø'Ù -¨˘& ø 3±/[¥ª¨ª¥ß &ª[øÆø¨ª [øƨ ±> ÔÁ ¨'ª ÛÛ -¨˘& ¥-µª æø3µ ±> ¨'ª '±´&ªÚ ÓI ¨'ø¨ /ªø+&Ù ¥-µª -+ ©ø-¨ªÆ-+9 ¨ªÆ/&· ‹± ß±´ µ+±© ©'ø¨ ÓÔ œ ¯Q+º-3ø¨-+9Ú˜ ÓÓ fl «ªø'Ù æø3µ ±> ¨'ª '±´&ªÚ ÓÌ œ fl+º ©'ø¨ ©ø& ÛÛ ©'± ©ø& ¨'-& æ±&& ¨'ø¨ ß±´ ÓÏ ÓÎ &[±µª ¨±· fl Q 3ø+˘¨ ƪ/ª/æªÆ '-& +ø/ªÚ Case 18-2868, Document 283, 08/09/2019, 2628241, Page104 of 883 Ô ª®3¥´&-™-¨ß· Ó fl «ª&Ú Ì œ …'ø¨ ©ø& ¨'ø¨ [ªÆ-±º· Ï fl Q 檥-ª™ª -¨ ©ø& ¥-µª ø ¨'ƪªÛ/±+¨' [ªÆ-±º Î Í È Ë Á ±Æ &±/ª¨'-+9Ú œ —µøßÚ fl+º ©'ø¨ ±¨'ªÆ ¨ªÆ/& ±> ¨'ª 3±+¨Æø3¨Ù º± ß±´ ƪ3ø¥¥· fl Q 3±´¥º+˘¨ ¨ø¥µ ¨± ø+ß ±¨'ªÆ +ª©& [´æ¥-3ø¨-±+ øæ±´¨ ¨'ª &¨±ÆßÚ ÔI œ fl+ߨ'-+9 ª¥&ª· ÔÔ fl “±¨ ¨'ø¨ Q µ+±© ±>Ú ÔÓ œ …ªÆª ß±´ 'ø[[ß ©'ª+ ¨'ª [ªÆ-±º ©ø& ´[· ÔÌ fl …ª¥¥Ù Q /ªø+Ù ø¨ ¨'ø¨ ¨-/ª Q ©ø+¨ªº ¨± ÔÏ ©Æ-¨ª øæ±´¨ /ß &¨±ÆßÚ ÔÎ ©'ª+ ¨'ø¨ [ªÆ-±º ©ø& ´[Ú ÔÍ ÔÈ œ Õ± Q 9´ª&&٠ߪ&Ù Q ©ø& 'ø[[ß fl+º ß±´ ©ªÆª ø3¨-™ª¥ß ©Æ-¨-+9 ø æ±±µ ø¨ ¨'ø¨ ¨-/ªÙ 3±Æƪ3¨· ÔË fl ”ß /ø+´&3Æ-[¨Ú ÔÁ œ «±´ ©ªÆª ©Æ-¨-+9 ¨'ª /ø+´&3Æ-[¨ ø¨ ¨'ª Q˘™ª +ª™ªÆ [´æ¥-&'ªº -¨Ú ÓI ¨-/ª ±> ß±´Æ [ªÆ-±º ±> ª®3¥´&-™-¨ß ©-¨' Õ'øƱ+ ÓÔ ›'´Æ3'ªÆÙ 3±Æƪ3¨· ÓÓ ÓÌ ÓÏ ÓÎ fl Ã'±&ª ¨'ƪª /±+¨'& ©ªÆª P´&¨ 3Æø¶-+ª&&Ú ¨'-+µ Q &¨øƨªº ø>¨ªÆ ¨'ø¨Ú œ «±´ ¨'-+µ ß±´ &¨øƨªº ©Æ-¨-+9 ¨'ª æ±±µ ø>¨ªÆ ¨'ª ÁI ºøß& ©ªÆª ´[· Q Case 18-2868, Document 283, 08/09/2019, 2628241, Page105 of 883 Ô fl «ªø'Ú Ó œ fl+º ¨'ª+ ß±´ ø¨¨ª/[¨ªº ¨± &ª¥¥ ¨'ø¨ Ì /ø+´&3Æ-[¨Ù 3±Æƪ3¨· Ï fl Q º-º+˘¨ ø¨¨ª/[¨ ¨± &ª¥¥ -¨Ú Q ©ª+¨ ¨± Î ±¨'ªÆ [´æ¥-3ø¨-±+&Ù ¥-µªÙ ©'ø¨ º± ß±´ 3ø¥¥ ¨'ª/· Í –ª±[¥ª ÛÛ Q˘/ ¨Æß-+9 ¨± ¨'-+µ ±> ¨'ª +ø/ª ±> ¨'ª È ©±ÆºÚ Ë ±Æ ø+ߨ'-+9Ú Á ±> /ß /ø+´&3Æ-[¨ ø+º -> ¨'ªß ¨'±´9'¨ -¨ ©ø&Ù ß±´ ÔI ÔÔ –ª±[¥ª ©'± [´æ¥-&' æ±±µ&Ù +±¨ ¥-µª ø +ª©&[ø[ªÆ fl+º Q -+Ø´-ƪº øæ±´¨ ©'ø¨ ¨'ªß ¨'±´9'¨ µ+±©Ù ø 9±±º &¨±ÆßÚ œ fl+ºÙ ߪø'Ú Õ± ß±´ &ª+¨ ¨'ª /ø+´&3Æ-[¨ ¨± ¨'ª&ª [ª±[¥ª ÔÓ >±Æ ¨'ª [´Æ[±&ª& ±> ¨Æß-+9 ¨± [´æ¥-&' ¨'ª æ±±µÙ ÔÌ 3±Æƪ3¨· ÔÏ fl Õ±/ª [ª±[¥ªÙ ߪ&Ú ÔÎ œ fl+º ß±´ ©ªÆª ¨Æß-+9 ¨± 9ª¨ /±+ªß >Ʊ/ ¨'ª ÔÍ ÔÈ ÔË ÔÁ ÓI ÓÔ æ±±µ [´æ¥-3ø¨-±+Ù 3±Æƪ3¨· fl …ª¥¥Ù Q ©ø&+˘¨ 9±-+9 ¨± &ª¥¥ -¨ ¨± ¨'ª/ >±Æ >ƪªÚ œ fi´¨ ß±´ ©ªÆª ´+&´33ª&&>´¥ -+ >-+º-+9 &±/ª±+ª ¨± [´æ¥-&' -¨Ù 3±Æƪ3¨· fl …ª¥¥Ù Q ©ø& ø¥©øß& ±+ ¨'ª >ª+3ª ©-¨' -¨Ú ÓÓ Q ©ø&+˘¨ ¨±± &´Æª -> Q ©ø+¨ªº ¨± ±Æ º-º+˘¨ ©ø+¨ ¨±Ú ÓÌ Q ©ø& /±Æª &ªªµ-+9 P´º9/ª+¨ æø&ªº ´[±+ ¨'ª&ª [ª±[¥ª ÓÏ ©'± 'ø™ª º±+ª ¨'-& [¥ª+¨ß ø+º [¥ª+¨ß ±> ¨-/ª&Ú ÓÎ Õ¨-¥¥ ¨± ¨'-& ºøßÙ Q /ªø+Ù Q˘™ª 'øº [ª±[¥ª Case 18-2868, Document 283, 08/09/2019, 2628241, Page106 of 883 Ô ©'± 'ø™ª 檪+ -+¨ªÆª&¨ªº -+ -¨ ø+º Q &¨-¥¥ º±+˘¨ µ+±© Ó -> Q ©ø+¨ ¨± º± -¨ ߪ¨Ú Ì ¥±¨ /±Æª ¨'ø¨ 3ø+ 9± -+¨± -¨Ù ß±´ µ+±©Ú Ï œ Q /ªø+Ù Q ¨'-+µ ¨'ªÆª˘& ø «±´ ©ªÆª ø3¨-™ª¥ß &ª+º-+9 ¨'ª /ø+´&3Æ-[¨ Î ¨± [ª±[¥ª >±Æ [´Æ[±&ª& ±> 'ø™-+9 ¨'ª/ ƪø3' ø ºªø¥ Í ©-¨' ß±´ ø+º [´æ¥-&' -¨Ù 3±Æƪ3¨· È fl “± ºªø¥ ©ø& ª™ªÆ ¨ø¥µªº øæ±´¨Ú …'ø¨ ©ª Ë ¨ø¥µªº øæ±´¨ ©ø& ¨'ª [±&&-æ-¥-¨ß ±> [´æ¥-&'-+9 -¨Ù -& Á -¨ [´æ¥-&'-+9Û©±Æ¨'ßÙ ©±´¥º Q +ªªº ¨± 9ª¨ ø ÔI 9'±&¨©Æ-¨ªÆÚ ÔÔ ª™ªÆ ©Æ-¨¨ª+ ø /ø+´&3Æ-[¨ &± Q º-º+˘¨ µ+±© ©'ø¨ Q ©ø& ÔÓ º±-+9Ú ÔÌ œ ÔÏ «±´ µ+±©Ù ¨'-& -& ¨'ª >-Æ&¨ ¨-/ª Q˘™ª —µøßÚ «±´ 3±+¨ø3¨ªº ÷øÆƪº …ª-&>ª¥ºÙ 3±Æƪ3¨· ÔÎ fl ›±Æƪ3¨Ú ÔÍ œ Q˘/ 9±-+9 ¨± /øƵ ø º±3´/ª+¨ ø& ÔÈ ‹ª>ª+ºø+¨˘& ¤®'-æ-¨ ÔÍÚ Q¨ -& ø 3±/[±&-¨ª ª®'-æ-¨Ú ÔË ¯¤®'-æ-¨ ÔÍ /øƵªºÚ˜ ÔÁ ”ŒÚ ¤‹…flŒ‹ÕÊ ÓI œ Ã'ø+µ ß±´Ú ¯fi« ”ÕÚ ”¤““Q“Ÿ¤Œ˜ Q˘/ +±¨ 9±-+9 ¨± ø&µ ÓÔ ß±´ ¨± ƪøº ª™ªÆß &-+9¥ª [ø9ª ±> ¨'-&Ù æ´¨ -> ß±´ ÓÓ ¥±±µ ø¨ ¨'ª >-Æ&¨ [ø9ªÚ ÓÌ fl À/Û'´/Ú ÓÏ œ ›ø+ ß±´ ¨ª¥¥ ©'ø¨ ¨'-& -& -+ ¨ªÆ/& ±> ©'ø¨ ÓÎ ¨ß[ª ±> º±3´/ª+¨· Case 18-2868, Document 283, 08/09/2019, 2628241, Page107 of 883 Ô Ó Ì 3ø¥/ ¨'ª ø+®-ª¨ß ø+º ª™ªÆߨ'-+9 º±©+Ú œ fiª>±Æª ß±´ /ª¨ ÷ª>>Æªß ¤[&¨ª-+Ù 'øº ß±´ ´&ªº ø+ß ºÆ´9&· Ï fl մƪ٠ߪ&Ú Î œ …'-3' ºÆ´9& 'øº ß±´ ´&ªº [Æ-±Æ ¨± /ªª¨-+9 Í ÷ª>>Æªß ¤[&¨ª-+· È fl Q &/±µªº [±¨Ú Ë œ ›±3ø-+ª· Á fl «ªø'Ù Q ©±´¥º 'ø™ª &+±Æ¨ªº 3±3ø-+ªÙ ÔI ÔÔ ÔÓ ÔÌ Q˘™ª ¨øµª+ ¤3&¨ø&ßÚ ´/Û'´/Ú œ ‹-º ß±´ ª™ªÆ øæ´&ª ø¥3±'±¥ æª>±Æª /ªª¨-+9 ÷ª>>Æªß ¤[&¨ª-+· fl “±Ù Q ©ø& ÛÛ Q ©ø&+˘¨ ª™ª+ ±> ø9ª ¨± æª ÔÏ ø楪 ¨± æ´ß -¨Ú ÔÎ [øƨ-ª& Q ©±´¥º 'ø™ª ºÆø+µ -¨Ù æ´¨ Q ©±´¥º+˘¨ &øß Q ÔÍ øæ´&ªº -¨Ú ÔÈ œ —µøßÚ Q /ªø+Ù -> ¨'ªÆª ©ø& ø¥3±'±¥ ø¨ …ªÆª ¨'ªÆª ª™ªÆ ±33ø&-±+& ´[±+ ÔË ©'-3' ß±´ ©ªÆª ±æ&ªÆ™ªº ¨± æª ºÆ´+µ æß ±¨'ªÆ [ª±[¥ªÙ ÔÁ [Æ-±Æ ¨± /ªª¨-+9 ÷ª>>Æªß ¤[&¨ª-+· ÓI fl Q> ß±´˘Æª ºÆ-+µ-+9Ù ¨'ª [±&&-æ-¥-¨ß ±> ÓÔ 9ª¨¨-+9 ºÆ´+µ -& ø¥©øß& ¨'ªÆªÚ ÓÓ Æª3ø¥¥ ª®ø3¨ &-¨´ø¨-±+ ©'ªÆª ¨'ø¨ ©ø& ¨'ª 3ø&ªÙ ÓÌ æ´¨ ÛÛ ÓÏ œ ÓÎ Q º±+˘¨ ÛÛ Q 3ø+˘¨ …ªÆª ß±´ º-ø9+±&ªº ø& ø ºÆ´9 øºº-3¨ [Æ-±Æ ¨± /ªª¨-+9 ÷ª>>Æªß ¤[&¨ª-+· Case 18-2868, Document 283, 08/09/2019, 2628241, Page108 of 883 Ô Ì flŸŒ¤“ fi‘fl“‹— ›—ÀŒÃ Œ¤–—ŒÃQ“Ÿ ˙ Q‹¤—Ù Q“›Ú ÓÔÍ Û Ôͨ' ըƪª¨Ù Õ´-¨ª ÍII ‹ª+™ªÆÙ ›±¥±Æøº± ËIÓIÓ ÏÏÎI flÆø[ø'±ª fl™ª+´ªÙ Õ´-¨ª ÔII fi±´¥ºªÆÙ ›±¥±Æøº± ËIÌIÌ Ï ”øß ÔÔÙ ÓIÔÍ Î È Õ-9Æ-º ÕÚ ”3›ø©¥ªßÙ ¤&ØÚ fi—Q¤ÕÙ Õ›ÿQ‘‘¤Œ ˙ ⁄‘¤»“¤Œ ‘‘– ÏIÔ ¤ø&¨ ‘ø& —¥ø& fi±´¥ª™øƺ Õ´-¨ª ÔÓII ⁄±Æ¨ ‘ø´ºªÆºø¥ªÙ ⁄‘ ÌÌÌIÔÛÓÓÔÔ Ë ŒªÊ Ó Í Á ÔI ÔÔ -ºª±¨ø[ªº ‹ª[±&-¨-±+ ±> Ÿ-´>>ƪ ™Ú ”ø®©ª¥¥ ›ø&ª “±Ú ÔÎÛ3™ÛIÈÏÌÌÛŒ…Õ QŒŸQ“Qfl ŸQÀ⁄⁄Œ¤ Ã'ª ø>±Æª/ª+¨-±+ªº ºª[±&-¨-±+ -& ƪøºß >±Æ ƪøº-+9 ø+º &-9+-+9Ú –¥ªø&ª ø¨¨ª+º ¨± ¨'-& /ø¨¨ªÆ æß >±¥¥±©-+9 fi—Ãÿ ±> ¨'ª -¨ª/& -+º-3ø¨ªº 檥±©Ê ÔÓ ›ø¥¥ ÌIÌÛÓÁÍÛIIÔÈ ø+º øÆÆø+9ª ©-¨' ´& ¨± ƪøº ø+º &-9+ ¨'ª ºª[±&-¨-±+ -+ ±´Æ ±>>-3ªÚ ÔÌ »»» ÔÏ ÿø™ª ¨'ª ºª[±+ª+¨ ƪøº ß±´Æ 3±[ß ø+º &-9+ ¨'ª &-9+ø¨´Æª [ø9ª ø+º ø/ª+º/ª+¨ &'ªª¨&Ù -> ø[[¥-3ø楪 ¨'ª &-9+ø¨´Æª [ø9ª -& ø¨¨ø3'ªºÚ ÔÎ Œªøº ¨'ª ª+3¥±&ªº 3±[ß ±> ¨'ª ºª[±&-¨-±+ ø+º &-9+ ¨'ª &-9+ø¨´Æª [ø9ª ø+º ø/ª+º/ª+¨ &'ªª¨&Ù -> ø[[¥-3ø楪 ¨'ª &-9+ø¨´Æª [ø9ª -& ø¨¨ø3'ªºÚ ÔÍ ÔÈ ÔË »»» ÔÁ ÓI ÓÔ ÓÓ …QÃÿQ“ ÌI ‹fl«Õ —⁄ Ãÿ¤ ‹flä —⁄ ÃÿQÕ ‘¤ÃäŒ fiß º´ª ¨± ø ¨Æ-ø¥ ºø¨ª ±> –¥ªø&ª æª &´Æª ¨'ª ±Æ-9-+ø¥ &-9+ø¨´Æª [ø9ª ø+º ø/ª+º/ª+¨ &'ªª¨&Ù -> ø+ßÙ øƪ ÕQŸ“¤‹ fi¤⁄—Œ¤ fl “—ÃflŒ« –Àfi‘Q› ø+º ƪ¨´Æ+ªº ¨± fl9ƪ+ fi¥ø+º± >±Æ >-¥-+9 ©-¨' ¨'ª ±Æ-9-+ø¥ ºª[±&-¨-±+Ú fl 3±[ß ±> ¨'ª&ª 3'ø+9ª& &'±´¥º ø¥&± æª >±Æ©øƺªº ¨± 3±´+&ª¥ ±> ƪ3±ÆºÚ Ã'ø+µ ß±´Ú ÓÌ flŸŒ¤“ fi‘fl“‹— ›—ÀŒÃ Œ¤–—ŒÃQ“Ÿ ˙ ÓÏ ÓÎ 33Ê fl¥¥ ›±´+&ª¥ Q‹¤—Ù Q“›Ú Case 18-2868, Document 283, 08/09/2019, 2628241, Page109 of 883 GIUFFRE VS. IMAXWELL mm VIRGINIA GI UF FRE VOLUME II 11/14/2016 Agren Blando Court Reporting Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-001 7 Case 18-2868, Document 283, 08/09/2019, 2628241, Page110 of 883 !“ Ãÿ¤ À“!ä‹ ÕÃflÃ¤Õ ‹!ÕÃŒ!›Ã ›—ÀŒÃ Õ—ÀÃÿ¤Œ“ ‹!ÕÃŒ!›Ã —⁄ “¤… «—Œ’ ›1™1¥ fl4¨1±7 “±Ú ÔÎÛ4™Û<ÈÏÌÌÛŒ…Õ ›—“⁄!‹¤“Ã!fl‘ !‹¤— ‹¤–—Õ!Ã!—“ —⁄ !ŒŸ!“!fl Ÿ!À⁄⁄Œ¤Ù —‘À”¤ !! “±™ªGæªÆ ÔÏÙ Ó<ÔÍ !ŒŸ!“!fl ‘Ú Ÿ!À⁄⁄Œ¤Ù –¥ø17¨1MMÙ ™Ú Ÿÿ!Õ‘fl!“¤ ”fl»…¤‘‘Ù ‹ªMª7ºø7¨Ú fl––¤flŒfl“›¤ÕÊ fi—!¤ÕÙ Õ›ÿ!‘‘¤Œ ˙ ⁄‘¤»“¤Œ ‘‘– fiß Õ1TÆ1º ÕÚ ”4›ø©¥ªßÙ ¤VØÚ Ï<Ô ¤øV¨ ‘øV —¥øV fi±´¥ª™øƺ Õ´1¨ª ÔÓ<< ⁄±Æ¨ ‘ø´ºªÆºø¥ªÙ ⁄‘ ÌÌÌ<Ô –Y±7ªÊ ÁÎÏÚÌÎÍÚ<<ÔÔ VG44ø©¥ªß‡æVM¥¥\Ú4±G fl\\ªøÆ17T ±7 æªYø¥M ±M ¨Yª –¥ø17¨1MM Case 18-2868, Document 283, 08/09/2019, 2628241, Page111 of 883 Ô Ó Ì Ï Î Í fl––¤flŒfl“›¤ÕÊ ¯›±7¨17´ªº˜ ÿfl‹‹—“Ù ”—ŒŸfl“ fl“‹ ⁄—Œ”fl“Ù –Ú›Ú fiß ‘ø´Æø ”ª7717TªÆÙ ¤VØÚ ÷ªMMÆªß ÕÚ –øT¥1´4øÙ ¤VØÚ ÔÎ< ¤øV¨ Ô<¨Y fl™ª7´ª ‹ª7™ªÆÙ ›— Ë<Ó<Ì –Y±7ªÊ Ì<ÌÚËÌÔÚÈÌÍÏ ¥Gª7717TªÆ‡YGM¥ø©Ú4±G a\øT¥1´4ø‡YGM¥ø©Ú4±G fl\\ªøÆ17T ±7 æªYø¥M ±M ¨Yª ‹ªMª7ºø7¨ È Ë Á Ô< ÔÔ ÔÓ ÔÌ ÔÏ ÔÎ ÔÍ ÔÈ ÔË ÔÁ Ó< ÓÔ ÓÓ ÓÌ ÓÏ ÓÎ fl¥V± –ƪVª7¨Ê fl77 ‘´7ºæªÆTÙ –øÆø¥ªTø¥ ”øÆß™±77ª ñG\µ17VÙ 1ºª±TÆø\YªÆ Case 18-2868, Document 283, 08/09/2019, 2628241, Page112 of 883 Ô fl «ªVÚ Ó œ fl7º ß±´ 檥1ª™ª ¨Yª “ª1Gø7 ”øÆ4´V ©øV Ì Ï ¥±4ø¨ªº 17 ©Y14Y 41¨ß· fl …ª¥¥Ù 1¨˘V øƱ´7º ⁄±Æ¨ ‘ø´ºªÆºø¥ªÚ Î 4ø7˘¨ ¨ª¥¥ ß±´ ª®ø4¨¥ßÚ Í ¥1µª fiƱ©øƺ ›±´7¨ß· ! ⁄±Æ¨ ‘ø´ºªÆºø¥ª 1V V± æ1TÙ !V ¨Yø¨ ¨Yª ©±Æº M±Æ 1¨· È œ fl7º ©Yø¨ º1º ß±´ º± ø¨ “ª1Gø7 ”øÆ4´V· Ë fl ! ©±Æµªº 17 ¨Yª 4Yø7T17T Ʊ±GVÚ Á œ fl7º ©Yø¨ º1º ß±´ º± 17 ¨Yª 4Yø7T17T Ʊ±G· Ô< fl ! ¨Y17µ ! a´V¨ ¥1µª ÛÛ 1M ! ƪGªGæªÆ ÔÔ Æ1TY¨Ù ! a´V¨ \´¨ 4¥±¨YªV ø©øß ¨Yø¨ \ª±\¥ª ¥ªM¨ 17 ÔÓ ¨YªÆªÚ ÔÌ V1¶ªV M±Æ ©±Gª7 ©Y± ©ø7¨ªº º1MMªÆª7¨ V1¶ªV ±M ¨Yª ÔÏ VøGª \Ʊº´4¨Ú ÔÎ ÔÍ œ –Ʊæøæ¥ß ©ª7¨ ±´¨ ¨± Tª¨ V1¶ªVÙ º1MMªÆª7¨ fl7º ©YªÆª º1º ß±´ ©±Æµ øM¨ªÆ “ª1Gø7 ”øÆ4´V· ÔÈ fl Ãø4± fiª¥¥Ú ÔË œ ‹1º ß±´ ©±Æµ ø¨ Õ±´¨YªøV¨ ¤G\¥±ßªª ÔÁ Ó< ”ø7øTªGª7¨ ›±G\ø7ß· fl ! º±7˘¨ ƪ4±T71¶ª ¨Yø¨Ú ! º±7˘¨ µ7±© 1M ÓÔ ¨Yø¨˘V ø \øßƱ¥¥ 4±G\ø7ß ±Æ ©Yø¨ 1¨ 1VÚ ÓÓ ©Yø¨ Õ±´¨YªøV¨ ÛÛ ©Yø¨ 1V 1¨ 4ø¥¥ªº· ! º±7˘¨ µ7±© ÓÌ œ Õ±´¨YªøV¨ ¤G\¥±ßªª ”ø7øTªGª7¨ ›±G\ø7ßÚ ÓÏ fl “±Ù ! º±7˘¨ ƪGªGæªÆ ¨Yø¨Ú ÓÎ œ ‹1º ß±´ ª™ªÆ ©±Æµ øV ø ¨ªG\· Case 18-2868, Document 283, 08/09/2019, 2628241, Page113 of 883 Ô fl “±¨ ¨Yø¨ ! ƪGªGæªÆÚ Ó œ Ÿ±17T ¨± º1MMªÆª7¨ ±MM14ªV ø7º M1¥¥17T 17· Ì fl “±Ú Ï œ ‹1º ß±´ ©±Æµ M±Æ —øV1V —´¨V±´Æ417T· Î fl ! º±7˘¨ ÛÛ ! º±7˘¨ µ7±© 1M ¨Yø¨˘V ø Í \øßƱ¥¥ 4±G\ø7ß ±Æ 1M ¨Yø¨˘V ø7 ø4¨´ø¥ \¥ø4ªÙ æ´¨ È ¨Yø¨ º±ªV7˘¨ Æ17T ø 檥¥Ú Ë Á Ô< ÔÔ œ ‹1º ß±´ ÛÛ º± ß±´ µ7±© Y±© G´4Y ß±´ T±¨ \ø1º ©Yª7 ß±´ ©ªÆª ©±Æµ17T ø¨ \¥ø4ªV ¥1µª —øV1V —´¨V±´Æ417T· fl …ª¥¥Ù 4±7V1ºªÆ17T ! º±7˘¨ µ7±© 1M ! ©±Æµªº ÔÓ ø¨ —øV1V —´¨V±´Æ417TÙ ! ©±´¥º7˘¨ ª™ª7 µ7±© Y±© G´4Y ! ÔÌ T±¨ \ø1ºÚ ÔÏ ÔÎ œ ‹1º ß±´ ƪ™1ª© ß±´Æ Õ±41ø¥ Õª4´Æ1¨ß ƪ4±ÆºV· ÔÍ fl «ªVÚ ÔÈ œ «±´ Vø© —øV1V —´¨V±´Æ417T ¥1V¨ªº ¨YªÆª· ÔË fl Œ1TY¨Ù æ´¨ ¥1µª ! Vø1ºÙ 1¨ º±ªV7˘¨ ª™ª7 ÔÁ Ó< ÓÔ ÓÓ º17T ø 檥¥ ø¨ ø¥¥Ú œ ‹± ß±´ µ7±© Y±© G´4Y G±7ªß ¨Yªß Vø1º ß±´ Gøºª MƱG ¨YªG· ”ÕÚ ”››fl…‘¤«Ê —æaª4¨1±7Ú !M ß±´ ©ø7¨ ¨± ÓÌ VY±© YªÆ ¨Yª º±4´Gª7¨VÙ VYª 4ø7 Vªª ©Yø¨ øG±´7¨ 1V ÓÏ ¥1V¨ªº ø7º ø7V©ªÆ ß±´Æ Ø´ªV¨1±7VÙ æ´¨ 1M ß±´˘Æª 7±¨ ÓÎ T±17T ¨± VY±© YªÆ ¨Yª º±4´Gª7¨Ù ¨Yø¨˘V ¨Yª æªV¨ VYª Case 18-2868, Document 283, 08/09/2019, 2628241, Page114 of 883 Ô Ó Ì Ï 4ø7 º±Ú fl «ªøYÙ 1M ß±´ 4±´¥ºÚ ß±´Æ Ø´ªV¨1±7VÚ œ !˘G Yø\\ß ¨± ø7V©ªÆ ! ©ø7¨ ¨± æª Yª¥\M´¥Ù V±ÚÚÚ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ ŸÆªø¨Ú …ª¥¥Ù º± ß±´ ΠƪGªGæªÆ Y±© G´4Y G±7ªß ß±´ Gøºª MƱG —øV1V Í —´¨V±´Æ417T· È fl ‘1µª ! Vø1ºÙ ! º±7˘¨ ª™ª7 ƪGªGæªÆ ©±Æµ17T Ë M±Æ —øV1V —´¨V±´Æ417TÙ ±Æ ©Yø¨ 1¨ 1VÙ V± ! 4±´¥º7˘¨ Á ¨ª¥¥ ß±´Ú Ô< ÔÔ œ ‹± ß±´ ƪGªGæªÆ Y±© G´4Y G±7ªß ß±´ ©ªÆª Gøµ17T \ªÆ Y±´Æ ø¨ “ª1Gø7 ”øÆ4´V· ÔÓ fl “±Ù 7±¨ ±MM ¨Yª ¨±\ ±M Gß YªøºÚ ÔÌ œ ‹± ß±´ µ7±© Y±© Gø7ß G±7¨YV ß±´ ©±Æµªº ÔÏ ¨YªÆª· ÔÎ fl ÔÍ º±7˘¨ µ7±©Ú ÔÈ ¨YƪªÛG±7¨Y GøƵ ©±´¥º æª Gß ÛÛ ! º±7˘¨ µ7±© ¨Yª ÔË ª®ø4¨ ø7V©ªÆÚ “±¨ ¥±7TÚ !˘º \Ʊæøæ¥ß Vøß ÛÛ ! Gªø7Ù ! !˘G 7±¨ T±17T ¨± T´ªVVÚ fi´¨ øƱ´7º ¨Yª ÔÁ œ ‹± ß±´ ƪGªGæªÆ ø7ß ±M ß±´Æ 4±©±ÆµªÆV· Ó< fl “±Ú ÓÔ œ ‹1º ß±´ ©±Æµ ø¨ ”ø7717±˘V· ÓÓ fl fiÆ1ªM¥ß٠ߪVÚ ÓÌ œ …Yø¨ 1V ”ø7717±˘V· ÓÏ fl fl 4´¨ª ¥1¨¨¥ª !¨ø¥1ø7 ƪV¨ø´Æø7¨ 17 ÓÎ …ª¥¥17T¨±7Ú Case 18-2868, Document 283, 08/09/2019, 2628241, Page115 of 883 Ô œ fl7º ©Yø¨ º1º ß±´ º± ø¨ ”ø7717±˘V· Ó fl ! º1º ©ø1¨ÆªVV17TÚ Ì œ fl7º Y±© G´4Y º1º ß±´ Gøµª· Ï fl —YÙ ! º±7˘¨ µ7±©Ú Î œ ‹1º ß±´ ©±Æµ ø¨ ß! ⁄Æ1ºøßV· Í fl flTø17Ù ™ªÆß VY±Æ¨¥ßÚ È ! º±7˘¨ ƪGªGæªÆÚ ÕY±Æ¨ ¨1Gª \ªÆ1±ºÙ ø7º ! ©øV ø ©ø1¨ÆªVV øTø17Ú Ë œ fl7º Y±© G´4Y º1º ß±´ Gøµª ¨YªÆª· Á fl ! Yø™ª 7± 1ºªøÚ Ô< œ ‹1º ß±´ Tª¨ M1ƪº· ÔÔ fl “±Ú ÔÓ œ …Yß º1º ß±´ ¥ªø™ª· ÔÌ fl ! ©øV ÛÛ ¨Yø¨˘V øƱ´7º ¨Yª ¨1Gª \ªÆ1±º ÔÏ ¨Yø¨ ! ©øV ø\\Ʊø4Yªº æß ÛÛ ! 4ø7˘¨ ƪGªGæªÆ Y1V ÔÎ 7øGªÙ æ´¨ Yª ±©7ªº ø ™ª¨ªÆ17øÆß 4¥1714 ±Æ Yª ©øV ø ÔÍ ™ª¨Ù ±7ª ±M ¨Yª ¨©±Ù ø7º Yª ±MMªÆªº Gª ¨± 4±Gª ©±Æµ ÔÈ M±Æ Y1GÚ ÔË œ …Yª7 ß±´ ©ªÆª ©±Æµ17T ø¨ ß ÛÛ ÃŸ! ÔÁ ⁄Æ1ºøßVÙ ©ªÆª ß±´ ø¥V± ©±Æµ17T ø¨ ¨Yª Œ±øºY±´Vª Ó< ŸÆ1¥¥· ÓÔ fl “±Ú ÓÓ œ ÃY±Vª ©ªÆª 7±¨ ø¨ ¨Yª VøGª ¨1Gª· ÓÌ fl ! º±7˘¨ µ7±©Ú ÓÏ ÓÎ ! º±7˘¨ ¨Y17µ V±Ú ”øßæª 4±7Vª4´¨1™ª¥ß ¥1µª øM¨ªÆ ªø4Y ±¨YªÆÚ œ ‹± ß±´ ƪ4ø¥¥ ©±Æµ17T ø¨ ¨Yª Œ±øºY±´Vª Case 18-2868, Document 283, 08/09/2019, 2628241, Page116 of 883 Ô ŸÆ1¥¥· Ó fl «ªVÚ Ì œ fl7º ©Yß º1º ß±´ ¥ªø™ª ¨YªÆª· Ï fl …ª ø¥¥ µ7±© ¨Yø¨ ¨Yª ¨Y17T ¨Yø¨ ©ª7¨ º±©7 Î ¨YªÆªÚ ñ7ß \14µªº Gª ´\ ø7º ¨±±µ V±Gª G±7ªß ±´¨ ±M Í ø aøÆÙ ø7º ¨Yª7 ! ©ª7¨ ¨± T± T1™ª 1¨ æø4µ ¨± ¨Yª T´ßÙ È ¨Y17µ17T ¨Yø¨ 1¨ ©±´¥º æª ø¥¥ Æ1TY¨Ù ø7º 1¨ ©øV7˘¨Ú Ë Õ± ! T±¨ M1ƪºÙ ! ¨Y17µÚ Á Ô< œ ÔÌ —µøßÚ ! VY±© ß±´ V±Gª ÛÛ øƪ ©ª ±7 Á· ÔÔ ÔÓ Õ´ÆªÚ ”ŒÚ –flŸ‘!À›flÊ œ «ªVÙ ÁÚ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ ‹ªMª7ºø7¨˘V ¤®Y1æ1¨ ÁÚ ÔÏ ¯¤®Y1æ1¨ Á GøƵªºÚ˜ ÔÎ Ãÿ¤ ‹¤–—“¤“ÃÊ ÔÍ ÔÈ !˘º ¥1µª ¨± VY±© ß±´ œ ÃYø7µ ß±´Ú ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ ‹± ß±´ ƪ4±T71¶ª ß±´Æ Yø7º©Æ1¨17T ±7 ¨Y1V º±4´Gª7¨· ÔË fl «ªVÚ ÔÁ œ ‹1º ß±´ M1¥¥ ±´¨ ø7 ø\\¥14ø¨1±7 M±Æ Ó< ªG\¥±ßGª7¨ ÛÛ ÓÔ fl «ªVÚ ÓÓ œ ÛÛ ±7 ”øÆ4Y ÓͨY ±M Ó<<Ó· ÓÌ fl «ªVÚ ÓÏ œ fl7º ©YªÆª ©ªÆª ß±´ ¥1™17T ø¨ ¨Yø¨ ¨1Gª· ÓÎ fl !˘™ª \´¨ º±©7 Gß \øƪ7¨V˘ øººÆªVVÙ æ´¨ ! Case 18-2868, Document 283, 08/09/2019, 2628241, Page117 of 883 Ô ø7º VªøV±7ø¥ ªG\¥±ßªªÙ 4±Æƪ4¨· Ó fl ›±Æƪ4¨Ú Ì œ fl7º ß±´Æ ºøº ©øV ø M´¥¥Û¨1Gª ߪøÆÛƱ´7º Ï ªG\¥±ßªªÙ Æ1TY¨· Î fl «ªVÚ Í œ ÿª ©±Æµªº ¨YªÆª ø¥¥ ¨Yª ¨1GªÚ È fl «ªVÚ Ë œ fl7º ß±´Æ a±æ ©øV ø VªøV±7ø¥ ªG\¥±ßGª7¨Ú Á fl …ª¥¥Ù øV MøÆ øV ! µ7±© ÛÛ Ô< ”ÕÚ ”››fl…‘¤«Ê —æaª4¨1±7Ú ÔÔ fl ÛÛ ! ©øV Y1ƪº M±Æ ¨Yª V´GGªÆÙ V±ÚÚÚ ÔÓ œ ¯fi« ”ÕÚ ”¤““!“Ÿ¤Œ˜ Œ1TY¨Ú —µøßÚ Õ± ¨Yª ÔÌ ©±Æµ Y±´ÆVÙ 17 ¨Yª 7ª®¨ \øÆøTÆø\YÙ ©Yø¨ ÛÛ ©Yø¨ 1V ÔÏ ¨Yø¨ ÛÛ 4ø7 ß±´ a´V¨ ƪøº ¨Yø¨ 汨¨±G \øÆøTÆø\Y M±Æ ÔÎ ´V· ÔÍ fl ˛ÃYª ›¥´æ 7ª™ªÆ VY´¨V º±©7 MƱG ÔÈ “±™ªGæªÆ ÔV¨ ¨± ”±¨YªÆ˘V ‹øß M±Æ ÓÏ Y±´ÆV ø ºøßÙ È ÔË ºøßV ø ©ªªµÙ 1¨ VªÆ™ªV ¨Yª º1™ªÆVª 7ªªºV ±M ±´Æ ÔÁ GªGæªÆVÚ Ó< ø¨ ø¥¥ ¨1GªVÙ ºª\øƨGª7¨V Yø™ª øÆÆø7Tªº º1MMªÆª7¨ ÓÔ V4Yªº´¥ªV M±Æ ¨Yª1Æ ªG\¥±ßªªVÚ˛ ÃYªÆªM±Æª ¨± ª7V´Æª ¨Yª øºªØ´ø¨ª 4±™ªÆøTª ÓÓ œ ÓÌ ¤®Y1æ1¨ Ó<Ú ÓÏ fl ›¥±Vª ¨Y1V ±7ª· ÓÎ œ «ªøYÚ —µøßÚ !˘G T±17T ¨± VY±© ß±´ ‹ªMª7ºø7¨˘V Case 18-2868, Document 283, 08/09/2019, 2628241, Page118 of 883 Ô ÕÃflä —⁄ ›—‘—Œfl‹—˜ Ó ˜ Ì ›—À“ë —⁄ ‹¤“ ¤Œ ˜ Ï VVÚ Œ¤–—ŒÃ¤Œ˘Õ ›¤ŒÃ!⁄!›flä !Ù –øGª¥ø ÷Ú ÿø7Vª7Ù º± YªÆªæß 4ªÆ¨1Mß ¨Yø¨ Î ! øG ø ŒªT1V¨ªÆªº –ƱMªVV1±7ø¥ Œª\±Æ¨ªÆ ø7º “±¨øÆß Í –´æ¥14 ©1¨Y17 ¨Yª Õ¨ø¨ª ±M ›±¥±Æøº±Â ¨Yø¨ \ƪ™1±´V ¨± È ¨Yª 4±GGª74ªGª7¨ ±M ¨Yª ª®øG17ø¨1±7Ù ¨Yª ºª\±7ª7¨ ©øV Ë º´¥ß V©±Æ7 ¨± ¨ªV¨1Mß ¨± ¨Yª ¨Æ´¨YÚ Á ! M´Æ¨YªÆ 4ªÆ¨1Mß ¨Yø¨ ¨Y1V ºª\±V1¨1±7 ©øV Ô< ¨øµª7 17 VY±Æ¨Yø7º æß Gª ø¨ ¨Yª ¨1Gª ø7º \¥ø4ª YªÆª17 ÔÔ Vª¨ M±Æ¨YÙ ¨Yø¨ 1¨ ©øV ¨YªÆªøM¨ªÆ ƪº´4ªº ¨± ÔÓ ¨ß\ª©Æ1¨¨ª7 M±ÆGÙ ø7º ¨Yø¨ ¨Yª M±ÆªT±17T 4±7V¨1¨´¨ªV ÔÌ ø ¨Æ´ª ø7º 4±Æƪ4¨ ¨Æø7V4Æ1\¨Ú ÔÏ ! M´Æ¨YªÆ 4ªÆ¨1Mß ¨Yø¨ ! øG 7±¨ ƪ¥ø¨ªº ¨±Ù ÔÎ ªG\¥±ßªº æßÙ 7±Æ ±M 4±´7Vª¥ M±Æ ø7ß ±M ¨Yª \øƨ1ªV ±Æ ÔÍ ø¨¨±Æ7ªßV YªÆª17Ù 7±Æ ±¨YªÆ©1Vª 17¨ªÆªV¨ªº 17 ¨Yª ÔÈ ÆªV´¥¨ ±M ¨Yª ©1¨Y17 ø4¨1±7Ú ÔË ÔÁ Ó< !7 ©1¨7ªVV ©YªÆª±MÙ ! Yø™ª øMM1®ªº Gß V1T7ø¨´Æª ¨Y1V ÓÌƺ ºøß ±M “±™ªGæªÆÙ Ó<ÔÍÚ ”ß 4±GG1VV1±7 ª®\1ƪV Õª\¨ªGæªÆ ÌÙ Ó<ÔËÚ ÓÔ ÓÓ ÓÌ ÓÏ ÓÎ –øGª¥ø ÷Ú ÿø7Vª7Ù ›ŒŒÙ Œ–ŒÙ Œ”Œ ÓÔÍ Û ÔͨY ըƪª¨Ù Õ´1¨ª Í<< ‹ª7™ªÆÙ ›±¥±Æøº± Ë<Ó<Ó CQQP 18-7868, 782, 08/00/7010, 7678741, Pagp11q nf EXHIBIT 6 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page120 of 883 Œ—ÕÕ “¤"‘ Ô ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ "“ Ãÿ¤ ÿ"Ÿÿ ›—ÀŒÃ —⁄ ÷ÀÕÃ"›¤ œÀ¤¤“˘Õ fi¤“›ÿ ‹" "Õ"—“ Ó Ì Ï ›¥ø89 “±Ú ›Œ Ó<ÔÍ ÍÓÏ fi¤Ã…¤¤“Ê Î "ŒŸ"“"fl ‘Ú Ÿ"À⁄⁄Œ¤ flDD¥8EøF¨Ù Í øFº È Œ—ÕÕ Ÿ—…Ù Ë Á Ô< ŒªMD±FºªF¨Ú fl“‹Ê À“"ä‹ ÕÃflÃ¤Õ ‹"ÕÃŒ"›Ã ›—ÀŒÃ Õ—ÀÃÿ¤Œ“ ‹"ÕÃŒ"›Ã —⁄ “¤… «—Œ’ ÔÔ ÔÓ 8ÆR8F8ø ‘Ú Ÿ8´TTƪ٠–¥ø8F¨8TTÙ ÔÌ ™Ú ÔÏ ÔÎ ŸX8M¥ø8Fª ”ø®©ª¥¥Ù ‹ªTªFºøF¨Ú ˜ ˜ ˜ ˜ ˜ ˜ ˜ ›øMª “±Ú ÔÎ E™ <ÈÏÌÌ Œ…Õ ÔÍ ÔÈ ⁄Æ8ºøßÙ “±™ª9æªÆ ÔËÙ Ó<ÔÍ ÔË flÃÊ ËÊÓÈ øÚ9Ú ÔÁ ÃøµªF ø¨Ê Ó< ÓÔ ¤MMª® ›Xø9æªÆM ÓÁÙ ËÔ ›XøFEªÆß ‘øFªÙ ‘±Fº±FÙ À’Ù …›Ófl Ô‹‹ ÓÓ ÓÌ ÓÏ ›±´Æ¨ ŒªD±Æ¨ªÆÊ ŒªD±Æ¨ªÆ ‘8Mø fiøÆƪ¨¨Ù flEEƪº8¨ªº Œªø¥ ¨89ª ÓÎ ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page121 of 883 Œ—ÕÕ “¤"‘ ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª ÔÓ Ô flÚ “±Ù " Xø™ª F±¨Ú <ËÊÌÔÊÎË Ó œÚ …XªF ß±´ 9ª¨ XªÆ ¥øM¨ F8RX¨Ù º8º MXª øMM8M¨ ß±´ <ËÊÌÓÊ<Ô Ì 8F DƪDøÆø¨8±F T±Æ ¨X8M ºªD±M8¨8±F· <ËÊÌÓÊ<Ï Ï flÚ “±Ú <ËÊÌÓÊ<È Î œÚ ‹8º MXª ¨ª¥¥ ß±´ øFߨX8FR øæ±´¨ ¨X8M EøMª· <ËÊÌÓÊÔ< Í flÚ “±Ú <ËÊÌÓÊÔÌ È œÚ ‹± ß±´ µF±© ŸX8M¥ø8Fª ”ø®©ª¥¥· <ËÊÌÓÊÓ< Ë flÚ " º± µF±© ”MÚ ”ø®©ª¥¥Ù ߪMÚ <ËÊÌÓÊÓÏ Á œÚ ÿ±© º8º ß±´ 9ªª¨ XªÆ· <ËÊÌÓÊÓÍ Ô< flÚ " 9ª¨ XªÆ 8F ¨Xª ±TT8EªM ±T ‹ª™±FMX8ƪM ¥ø© <ËÊÌÓÊÓÈ ÔÔ T8Æ9 ±F ±Æ øƱ´Fº ”øÆEX Ó<ÔÔÚ <ËÊÌÓÊÌÔ ÔÓ œÚ Õ± ß±´Æ T8ÆM¨ 9ªª¨8FR ©øM 8F DªÆM±F· <ËÊÌÓÊÌÈ ÔÌ flÚ ⁄8ÆM¨ 9ªª¨8FR ©øM 8F DªÆM±F٠ߪMÚ <ËÊÌÓÊÏÔ ÔÏ œÚ ÿøº ß±´ MD±µªF ¨± XªÆ DÆ8±Æ ¨± ¨Xø¨· <ËÊÌÓÊÏÓ ÔÎ flÚ " 檥8ª™ª ¨Xø¨ ¨Xª ™ªÆß T8ÆM¨ ªFRøRª9ªF¨ ©øM ÛÛ <ËÊÌÓÊÏÎ ÔÍ " ©øM 8F¨Æ±º´Eªº ¨± XªÆ æß 9ß EXø8Æ9øF fiÆ8øF fiøMXø9 æ´¨ <ËÊÌÓÊÎ< ÔÈ " 檥8ª™ª ¨Xª T8ÆM¨ ©±ÆºM ©ª Xøº ©ªÆª 8F ¨Xª ‹ª™±FMX8ƪ <ËÊÌÓÊÎÏ ÔË ¥ø© ±TT8EªÚ <ËÊÌÓÊÎË ÔÁ œÚ <ËÊÌÌÊ<< Ó< ‹8º ”MÚ ”ø®©ª¥¥ ƪ¨ø8F ¨Xª MªÆ™8EªM ±T ß±´ ±Æ ß±´Æ T8Æ9· <ËÊÌÌÊ<Ì ÓÔ flÚ «ªMÙ MXª º8ºÚ <ËÊÌÌÊ<Ï ÓÓ œÚ flFº ©øM ¨Xø¨ 8F ”øÆEX ±T Ó<ÔÔ· <ËÊÌÌÊ<Í ÓÌ flÚ "¨ ©øMÚ <ËÊÌÌÊ<Á ÓÏ œÚ ‹± ß±´ Xø™ª ø ©Æ8¨¨ªF øRƪª9ªF¨· <ËÊÌÌÊÔÔ ÓÎ flÚ …ª º8º Xø™ª ø ©Æ8¨¨ªF øRƪª9ªF¨ æ´¨ " EøF F± <ËÊÌÌÊÔÏ ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page122 of 883 Œ—ÕÕ “¤"‘ Ô ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª ÔÌ ¥±FRªÆ ¥±Eø¨ª ¨Xø¨ øRƪª9ªF¨Ú <ËÊÌÌÊÔÍ Ó œÚ …øM ¨Xø¨ øRƪª9ªF¨ ª™ªÆ ƪFª©ªº· <ËÊÌÌÊÔÁ Ì flÚ "¨ ©øM ƪFª©ªºÙ " 檥8ª™ª ±F ±Æ øƱ´Fº ¨Xª <ËÊÌÌÊÓÔ Ï æªR8FF8FR ±T ÷øF´øÆß Ó<ÔÎÙ D±¨ªF¨8ø¥¥ß ¨Xª ÓFº ±T ÷øF´øÆß <ËÊÌÌÊÓÍ Î ™8ø ª9ø8¥Ú <ËÊÌÌÊÌÓ Í œÚ …øM ¨Xª øRƪª9ªF¨ ƪ™8Mªº ©XªF 8¨ ©øM ƪFª©ªº· <ËÊÌÌÊÌÏ È flÚ "¨ ©øMF˘¨ ƪ™8MªºÚ <ËÊÌÌÊÌË Ë Á Ô< "¨ ©øM ø M¨Æø8RX¨T±Æ©øƺ ƪ۪M¨øæ¥8MX9ªF¨ ±T ¨Xª ±Æ8R8Fø¥ øRƪª9ªF¨Ú œÚ "M 8¨ ß±´Æ 檥8ªT ¨Xø¨ ¨Xø¨ øRƪª9ªF¨ ©øM 8F ªTTªE¨ ±F ÷øF´øÆß ÓFºÙ Ó<Ôη <ËÊÌÌÊÏÓ <ËÊÌÌÊÏÎ <ËÊÌÌÊÏÁ ÔÔ flÚ «ªMÚ <ËÊÌÌÊÎÌ ÔÓ œÚ ‹± ß±´ ƪEø¥¥ ¨Xª ¨ªÆ9M ±T ¨Xø¨ øRƪª9ªF¨· <ËÊÌÌÊÎÁ ÔÌ flÚ …ª¥¥Ù 8¨ ©øM ø ƪ۪M¨øæ¥8MX9ªF¨ ±T øF ª®8M¨8FR <ËÊÌÏÊ<Ì ÔÏ øRƪª9ªF¨ M± 8T ©ª R± æøEµ ¨± ¨Xª ±Æ8R8Fø¥ øRƪª9ªF¨Ù 8¨ <ËÊÌÏÊ<Í ÔÎ ©øM ¨± DƱ™8ºª D´æ¥8E ƪ¥ø¨8±FM MªÆ™8EªM ¨± ”MÚ ”ø®©ª¥¥ <ËÊÌÏÊ<Ë ÔÍ 8F ¨Xª 9ø¨¨ªÆ ±T Ÿ´8TTƪ øFº XªÆ øE¨8™8¨8ªMÚ <ËÊÌÏÊÔÌ ÔÈ ÔË ÔÁ Ó< ”ÕÚ Õ›ÿÀ‘ÃbÊ "˘9 9øƵ8FR øM ¤®X8æ8¨ ÓÙ ø º±E´9ªF¨ ¥ø檥ªº Ÿ” <<<ÍËÚ <ËÊÌÏÊÌÔ ¯¤®X8æ8¨ Ó ©øM 9øƵªº T±Æ 8ºªF¨8T8Eø¨8±F˜ ”ŒÚ ‹«¤ŒÊ <ËÊÌÏÊÓÁ …Xß º±F˘¨ ß±´ M¨øƨ 9øµ8FR ø D8¥ª ±T <ËÊÌ<ÊÏË <ËÊÌÏÊÌË ÓÔ ¨Xª9Ù ”ÆÚ Ÿ±©Ù æªEø´Mª 8¨ 9øß æª ¨Xø¨ ¥ø¨ªÆ ±F ß±´˘¥¥ æª <ËÊÌÏÊÏ< ÓÓ øMµªº ¨± R± æøEµ ¨± ¨Xª9Ú <ËÊÌÏÊÏÌ ÓÌ Ãÿ¤ …"Ó¤ÕÕÊ ÓÏ ”ŒÚ ‹«¤ŒÊ ÓÎ «ªMÙ M8ÆÚ <ËÊÌÏÊÏÏ «±´ º±F˘¨ Xø™ª E±D8ªM T±Æ 9ª ±T ¨XªMª º±E´9ªF¨M· ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ <ËÊÌÏÊÎÎ <ËÊÌÏÊÎÈ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page123 of 883 Œ—ÕÕ “¤"‘ Ô Ó ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ”ÕÚ Õ›ÿÀ‘ÃbÊ ÔÔÒÔËÒÓ<ÔÍ –øRª ÔÏ " º± F±¨ Xø™ª øFß 9±Æª E±D8ªM ±F ¨Xø¨Ú <ËÊÌÏÊÎË <ËÊÌÏÊÎÁ Ì ”ŒÚ ‹«¤ŒÊ “±Ù F±Ù F±Ù 8¨˘M 9´EX 9±Æª 89D±Æ¨øF¨ <ËÊÌÎÊ<< Ï ¨Xø¨ ÚÚÚ d´M¨ T±Æ ¨Xª D´ÆD±Mª ±T T±¥¥±©8FR ¨X8FRMÙ 8¨˘M <ËÊÌÎÊ<< Î ªøM8ªÆÚ <ËÊÌÎÊ<Ì Í È Ë œÚ fi« ”ÕÚ Õ›ÿÀ‘ÃbÊ <ËÊÌÎÊÔÓ "M ƱMM‡øE´8¨ßƪD´¨ø¨8±FÚE±9 ß±´Æ ª9ø8¥ <ËÊÌÎÊÔÓ øººÆªMM· <ËÊÌÎÊÔÎ Á flÚ "¨ 8MÙ 9ß æ´M8FªMM ª9ø8¥Ù ߪMÚ <ËÊÌÎÊÔÍ Ô< œÚ ‹8º ß±´ MªFº ¨Xª ª9ø8¥ ºªD8E¨ªº 8F ¨X8M <ËÊÌÎÊÔË ÔÔ º±E´9ªF¨· <ËÊÌÎÊÓÔ ÔÓ flÚ «ªMÙ " º8ºÚ <ËÊÌÎÊÓÍ ÔÌ œÚ ‹8º ß±´ MªFº 8¨ ±F ÷øF´øÆß ÓFºÙ Ó<Ôη <ËÊÌÎÊÓÈ ÔÏ flÚ " 檥8ª™ª " º8ºÚ <ËÊÌÎÊÌÔ ÔÎ œÚ …XªF ß±´ MªF¨ ¨Xø¨ ª9ø8¥ ©ªÆª ß±´ øE¨8FR <ËÊÌÎÊÌÏ ÔÍ D´ÆM´øF¨ ¨± ”MÚ ”ø®©ª¥¥˘M ƪ¨ªF¨8±F ±T ß±´Æ MªÆ™8EªM· <ËÊÌÎÊÌÍ ÔÈ flÚ «ªMÙ " ©øMÚ <ËÊÌÎÊÏÔ ÔË œÚ ›±´¥º ß±´ D¥ªøMª ¨ª¥¥ 9ª ª™ªÆߨX8FR ß±´ µF±© <ËÊÌÎÊÎË ÔÁ øæ±´¨ 8ÆR8F8ø Œ±æªÆ¨M Ÿ´8TTÆªÚ Ó< ”ÕÚ ”¤““"“Ÿ¤ŒÊ ÓÔ ”ŒÚ ‹«¤ŒÊ <ËÊÌÍÊ<< —ædªE¨8±FÙ T±´Fºø¨8±F øFº T±Æ9Ú «±´ 9øß øFM©ªÆÚ <ËÊÌÍÊ<Á <ËÊÌÍÊÔÔ ÓÓ fi« ”ÕÚ Õ›ÿÀ‘ÃbÊ <ËÊÌÍÊÔÔ ÓÌ œÚ «±´ ¨ªM¨8T8ªº ªøÆ¥8ªÆ ¨Xø¨ ß±´ ©ªÆª ƪ¨ø8Fªº ÛÛ <ËÊÌÍÊÔÓ ÓÏ ”ŒÚ ‹«¤ŒÊ <ËÊÌÍÊÔÎ ÓÎ fi« ”ÕÚ Õ›ÿÀ‘ÃbÊ flƪ ß±´ ©8¨XºÆø©8FR ¨Xø¨ Ø´ªM¨8±F· ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ <ËÊÌÍÊÔÈ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page124 of 883 Œ—ÕÕ “¤"‘ Ô Ó œÚ ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… “±Ù "˘9 F±¨Ù "˘9 F±¨Ú ÔÔÒÔËÒÓ<ÔÍ –øRª ÔÎ –¥ªøMª ÛÛ " ø9 ©8¨XºÆø©8FR ¨Xø¨ Ø´ªM¨8±FÚ <ËÊÌÍÊÔÈ <ËÊÌÍÊÓ< Ì ”ŒÚ ‹«¤ŒÊ Ï ”ÕÚ Õ›ÿÀ‘ÃbÊ Î fi« ”ÕÚ Õ›ÿÀ‘ÃbÊ <ËÊÌÍÊÓÓ «±´ ¨ªM¨8T8ªº Dƪ™8±´M¥ß ¨Xø¨ ß±´ ©ªÆª ƪ¨ø8Fªº <ËÊÌÍÊÓÓ Í œÚ fl¥Æ8RX¨Ú <ËÊÌÍÊÓ< " ø9 ©8¨XºÆø©8FR ¨Xø¨ Ø´ªM¨8±FÚ È ¨± XøFº¥ª 9ø¨¨ªÆM ƪ¥ø¨8FR ¨± Ë 8M ¨Xø¨ E±ÆƪE¨· 8ÆR8F8ø Œ±æªÆ¨M Ÿ´8TTƪ <ËÊÌÍÊÓ< <ËÊÌÍÊÓÏ <ËÊÌÍÊÓÁ Á flÚ ›±ÆƪE¨Ú <ËÊÌÍÊÌ< Ô< œÚ —µøßÚ <ËÊÌÍÊÌÔ ÔÔ Ÿ´8TTƪ 8M· <ËÊÌÍÊÌÎ ÔÓ flÚ " ø9Ú <ËÊÌÍÊÌÍ ÔÌ œÚ —µøßÚ Õ± ß±´ øƪ ø©øƪ ±T ©X± ”MÚ Œ±æªÆ¨M –¥ªøMª ¨ª¥¥ 9ª ª™ªÆߨX8FR ß±´ µF±© øæ±´¨ <ËÊÌÍÊÌÈ ÔÏ 8ÆR8F8ø Œ±æªÆ¨M Ÿ´8TTƪ٠D¥ªøMªÚ <ËÊÌÍÊÌÁ ÔÎ ”ÕÚ ”¤““"“Ÿ¤ŒÊ <ËÊÌÍÊÏÓ ÔÍ øFº 9øß Eø¥¥ T±Æ DÆ8™8¥ªRªº 9ø¨ªÆ8ø¥MÚ ÔÈ ÔË ÔÁ Ó< —ædªE¨8±FÙ T±´Fºø¨8±FÙ T±Æ9Ù œÚ <ËÊÌÍÊÏÌ fi« ”ÕÚ Õ›ÿÀ‘ÃbÊ <ËÊÌÍÊÏÎ «±´ EøF øFM©ªÆ ÛÛ ¨± ¨Xª ª®¨ªF¨ ¨Xø¨ øFߨX8FR <ËÊÌÍÊÏÍ ß±´ ¨ªM¨8Tß ¨± 8M F±¨ DƱ¨ªE¨ªº æß ø DÆ8™8¥ªRªÚ flÚ ”MÚ Œ±æªÆ¨M T8ÆM¨ Eø9ª ¨± 9ß ø¨¨ªF¨8±F ±F ±Æ <ËÊÌÍÊÏË <ËÊÌÍÊÎË ÓÔ øƱ´Fº ”øÆEX Ó<ÔÔ ©XªF " ©øM Eø¥¥ªº 8F¨± ø 9ªª¨8FR ©8¨X <ËÊÌÈÊ<Ì ÓÓ –X8¥8D fiøƺªF øFº ”MÚ ”ø®©ª¥¥ ø¨ ‹ª™±FMX8ƪM ¥ø© ±TT8EªÙ <ËÊÌÈÊ<Ë ÓÌ ¨Xø¨ MXª Xøº 9øºª ÛÛ ”MÚ Ÿ´8TTƪ Xøº 9øºª ª®¨Æª9ª¥ß <ËÊÌÈÊÔÏ ÓÏ ´FD¥ªøMøF¨ ø¥¥ªRø¨8±FM øæ±´¨ ”MÚ ”ø®©ª¥¥˘M DÆ8™ø¨ª ¥8TªÚ <ËÊÌÈÊÓ< ÓÎ …ª ©ªÆª ÛÛ flE´8¨ß ŒªD´¨ø¨8±FÙ 9ß T8Æ9 ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 <ËÊÌÈÊÓÍ Case 18-2868, Document 283, 08/09/2019, 2628241, Page125 of 883 Œ—ÕÕ “¤"‘ ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª ÔÍ Ô ©øM Eø¥¥ªº 8F ¨± DƱ¨ªE¨ ”MÚ ”ø®©ª¥¥˘M ƪD´¨ø¨8±FÙ øFº <ËÊÌÈÊÓÁ Ó ¨± Mª¨ ¨Xª ƪE±Æº M¨Æø8RX¨Ú <ËÊÌÈÊÌÌ Ì E±99ªFEªº ±F ±Æ øƱ´Fº ”øÆEX ±T Ó<ÔÔÚ ÃXø¨ ©øM ÛÛ øFº ¨Xø¨ ©±Æµ <ËÊÌÈÊÏÓ Ï œÚ …Xø¨ º± ß±´ 9ªøF æß ˛Mª¨ ¨Xª ƪE±Æº M¨Æø8RX¨˛· <ËÊÌÈÊÏÍ Î flÚ ”MÚ Ÿ´8TTƪ˘M ø¥¥ªRø¨8±FM øæ±´¨ ”MÚ ”ø®©ª¥¥ <ËÊÌÈÊÎÔ Í ©ªÆªÙ ©ª 檥8ª™ªÙ øFº ¨± ¨X8M ºøß E±F¨8F´ª ¨± 檥8ª™ªÙ <ËÊÌÈÊÎÎ È ´F¨Æ´ªÙ ºªTø9ø¨±ÆßÙ øFº TøF¨øM¨8Eø¥Ú <ËÊÌÈÊÎË Ë ‹ª™±FMX8ƪM˘ ¥ø©ßªÆMÙ ©ª Mª¨ øæ±´¨ D´¨¨8FR ±´¨ ÛÛ <ËÊÌËÊ<Á Á EÆøT¨8FR ø M¨ø¨ª9ªF¨ ©X8EX ©±´¥º D´¨ ”MÚ ”ø®©ª¥¥˘M D±8F¨ <ËÊÌËÊÔÎ Ô< ±T ™8ª© øEƱMM ¨Xø¨ ”MÚ Ÿ´8TTƪ˘M ø¥¥ªRø¨8±FM ©ªÆª ´F¨Æ´ª <ËÊÌËÊÔÁ ÔÔ øFºÙ TÆøFµ¥ßÙ øæX±ÆƪF¨Ú <ËÊÌËÊÓÎ ÔÓ ÔÌ ÔÏ œÚ flFº ©8¨X …Xø¨ øº™8Eª º8º ß±´ R8™ª ”8MM ”ø®©ª¥¥ øM Døƨ ±T ß±´Æ ƪ¨ªF¨8±F· flÚ <ËÊÌËÊÓË <ËÊÌËÊÌÔ "¨ 8M M¨øFºøƺ DƱEªº´Æª 8F EøMªM ©XªÆª 8¨˘M <ËÊÌËÊÌÓ ÔÎ ´FºªÆM¨±±º ¨Xø¨ ø DøÆ¨ß 9øß æª ºªTø98FR ±Fª˘M E¥8ªF¨ ¨Xø¨ <ËÊÌËÊÌÍ ÔÍ ±Fª D´¨M ±´¨ ø M¨ø¨ª9ªF¨ E±ÆƪE¨8FR ¨X±Mª ø¥¥ªRø¨8±FM øFº <ËÊÌËÊÏÓ ÔÈ DƱ™8º8FR ø E¥ªøÆªÆ D8E¨´Æª ±T ©XªÆª ¨Xª ¨Æ´¨X ¥8ªMÚ <ËÊÌËÊÏÍ ÔË 8¨ ©øM ™ªÆß 9´EX ±´Æ E±´FMª¥ ¨Xø¨ ”MÚ ”ø®©ª¥¥ D´¨ ±´¨ ø <ËÊÌËÊÏÁ ÔÁ M¨ø¨ª9ªF¨Ù ™ªXª9ªF¨¥ß ºªFß8FR ¨Xª ø¥¥ªRø¨8±FMÚ <ËÊÌËÊÎÎ Ó< œÚ Õ± …XªF ß±´ ¨ªM¨8T8ªº ¨Xø¨ ”MÚ Ÿ´8TTƪ٠"˘9 R±8FR <ËÊÌËÊÎÁ ÓÔ ¨± ƪTªÆ ¨± XªÆ æß d´M¨ XªÆ 9øÆÆ8ªº Fø9ªÙ Eø9ª ¨± ß±´Æ <ËÊÌÁÊ<Ì ÓÓ ø¨¨ªF¨8±F ø¨ ¨Xø¨ ”øÆEX Ó<ÔÔ 9ªª¨8FR ø¨ ‹ª™±FMX8ƪM ©8¨X <ËÊÌÁÊ<Í ÓÌ ”ÆÚ fiøƺªF øFº ”MÚ ”ø®©ª¥¥Ù E±ÆƪE¨Ù øFº ß±´ ¥ªøÆFªº <ËÊÌÁÊÔÓ ÓÏ øæ±´¨ XªÆ ø¨ ¨Xø¨ 9ªª¨8FR 8M ¨Xø¨ E±ÆƪE¨· <ËÊÌÁÊÔÍ ÓÎ flÚ ›±ÆƪE¨Ú ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ <ËÊÌÁÊÔË “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page126 of 883 Œ—ÕÕ “¤"‘ Ô ÔÔÒÔËÒÓ<ÔÍ –øRª ÌÔ Æª9ø8F8FRÙ M±ÚÚÚ Ó Ì ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… <ËÊÎËÊÔÏ "˘™ª 9øƵªº øM ¤®X8æ8¨ Ì ŒŸ¯À’˜ <<<<ÓÚ ‹± ß±´ ƪE±RF8¶ª ¨X8M ª9ø8¥· <ËÊÎËÊÔÎ <ËÊÎËÊÏÈ Ï flÚ " º±Ú <ËÊÎËÊÏË Î œÚ ‹8º ß±´ ƪEª8™ª ¨X8M ª9ø8¥· <ËÊÎËÊÏÁ Í flÚ " º8ºÙ ±F ¨Xª ÛÛ ±F “ª© «ªøÆ˘M ‹øß Ó<ÔÎÚ <ËÊÎËÊÎ< È œÚ ‹8º ß±´ E±F¨øE¨ ”MÚ ”ø®©ª¥¥ øT¨ªÆ ƪEª8™8FR <ËÊÎËÊÎÈ Ë ¨X8M ª9ø8¥· <ËÊÎËÊÎË Á flÚ " º8ºÚ <ËÊÎËÊÎÁ Ô< œÚ ‹8º ß±´ 9øµª øFß ÆªMD±FMª ¨± ”ÆÚ fiø¥¥ 8F øFß <ËÊÎÁÊÔÁ ÔÔ T±Æ9· <ËÊÎÁÊÓÓ ÔÓ flÚ " º8ºÚ <ËÊÎÁÊÓÓ ÔÌ œÚ ›øF ß±´ ¨ª¥¥ 9ª ©Xø¨ ß±´ ÛÛ ©Xø¨ ƪMD±FMª ß±´ <ËÊÎÁÊÓÎ ÔÏ ÔÎ 9øºª· <ËÊÎÁÊÓÍ flÚ …ª¥¥Ù ¨Xª ƪMD±FMª ¨± ”ÆÚ fiø¥¥ ©øM Døƨ ±T ø <ËÊÎÁÊÓÈ ÔÍ MªÆ8ªM ±T ƪMD±FMªM Xø™8FR MD±µªF ¨± 9ß E¥8ªF¨ ©8¨X8F ÓÏ <ËÊÎÁÊÌÌ ÔÈ X±´ÆM ±Æ M±Ù ©ª R±¨ æøEµ ¨± ”ÆÚ fiø¥¥ ©8¨X øF øRƪªº <ËÊÎÁÊÏÔ ÔË M¨ø¨ª9ªF¨ ©X8EX ©ªF¨ ±´¨ ¨± ø F´9æªÆ ±T 9ªº8øÚ <ËÊÎÁÊÏÏ ÔÁ Ó< ÓÔ ÓÓ ÓÌ œÚ …XªF ß±´ Møß ˛øRƪªº M¨ø¨ª9ªF¨˛ EøF ß±´ ¨ª¥¥ 9ª 9±Æª øæ±´¨ ©Xø¨ ß±´ 9ªøF· flÚ …X± øRƪªº ¨± ¨Xª M¨ø¨ª9ªF¨· " Fªªº ¨± R8™ª ß±´ M±9ª E±F¨ª®¨Ù 8T " 9øßÙ <ËÊÎÁÊÎ< <ËÊÎÁÊÎÓ <ËÊÎÁÊÎË øæ±´¨ ¨Xø¨ M¨ø¨ª9ªF¨Ú <ÁÊ<<Ê<Ô Õ±Ù ¨X8M 8M ±F “ª© «ªøÆ˘M ‹øßÚ " ©øM <ÁÊ<<Ê<Ó ÓÏ 8F ⁄ÆøFEª M± ¨Xª ª9ø8¥ ¨89ª XªÆª ±T ÓÔÊÏÍÙ 8F ⁄ƪFEX <ÁÊ<<Ê<Ï ÓÎ ¨89ª ©øM ÓÓÊÏÍÙ øFº " ©øM Rª¨¨8FR ´D ªøÆ¥ß ¨Xª Fª®¨ <ÁÊ<<ÊÔ< ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page127 of 883 Œ—ÕÕ “¤"‘ ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª ÌÓ Ô 9±ÆF8FR ¨± ºÆ8™ª 9ß Tø98¥ß æøEµ TƱ9 ¨Xª M±´¨X ±T <ÁÊ<<ÊÔÏ Ó ⁄ÆøFEª ¨± ¤FR¥øFºÙ ©X8EX 8M ø ÔÏÛX±´Æ d±´ÆFªßÙ º±±Æ ¨± <ÁÊ<<ÊÔÈ Ì º±±ÆÚ <ÁÊ<<ÊÓÓ Ï æªøÆ8FR 8F 98Fº ¨Xø¨ ”MÚ ”ø®©ª¥¥Ù " ¨X8Fµ ©øM 8F “ª© <ÁÊ<<ÊÓÍ Î «±Æµ ¨XªFÙ MXª ©øM T8™ª X±´ÆM æªX8FºÙ M± ¨XªÆª ©øM <ÁÊ<<ÊÓË Í Ø´8¨ª ø ¥±¨ ±TÙ M±Æ¨ ±T ¨89ª º8TTªÆªFEª 檨©ªªF ¨Xª <ÁÊ<<ÊÌ< È ™øÆ8±´M E±´F¨Æ8ªM XªÆªÙ " MªF¨ XªÆ øF ª9ø8¥Ù " <ÁÊ<<ÊÌÎ Ë æª¥8ª™ªÙ Møß8FR ÛÛ DøÆM8FR ¨X8M ÛÛ T±Æ©øƺ8FR ¨X8M <ÁÊ<<ÊÌË Á ª9ø8¥ ¨± XªÆ Møß8FR ˛ÿ±© º± ß±´ ©8MX ¨± DƱEªªº·˛ flFº <ÁÊ<<ÊÏÔ Ô< ¨XªF " ©øM ±F ¨Xª ¨ª¥ªDX±Fª ÛÛ " Xøº ¨©± ¨ª¥ªDX±FªM 8F <ÁÊ<<ÊÏÎ ÔÔ ¨Xª EøÆÙ " ƪEª8™ªº 8F ª®EªMM ±T Ì< DX±Fª Eø¥¥M TƱ9 <ÁÊ<<ÊÎ< ÔÓ ™øÆ8±´M 9ªº8ø ±´¨¥ª¨M ±F ¨Xª ÓFº ±T ÷øF´øÆßÙ ø¥¥ <ÁÊ<<ÊÎÏ ÔÌ øMµ8FR T±Æ 8FT±Æ9ø¨8±F øæ±´¨ X±© ”MÚ ”ø®©ª¥¥ ©øM <ÁÊ<ÔÊ<< ÔÏ ¥±±µ8FR ¨± ƪMD±Fº ¨± ¨Xª ¥ø¨ªM¨ E±´Æ¨ T8¥8FRMÙ ©X8EX <ÁÊ<ÔÊ<Ï ÔÎ ©ªÆª T8¥ªº ±F ¨Xª Ì<¨X ±T ‹ªEª9æªÆ øM " ´FºªÆM¨øFºÚ <ÁÊ<ÔÊÔ< Õ± ±F ¨Xª 9±ÆF8FR ±T ¨Xª ÓFº ±T ÷øF´øÆßÙ ÔÍ flFº æß E¥±Mª ÛÛ ¨±©øƺM E¥±Mª ±T D¥øß <ÁÊ<ÔÊÔÌ ÔÈ ±F ¨Xª ÓFºÙ " ƪEª8™ªº øF ª9ø8¥ T±Æ©øƺªº æß <ÁÊ<ÔÊÔÍ ÔË ”MÚ ”ø®©ª¥¥Ù E±F¨ø8F8FR ø ºÆøT¨ M¨ø¨ª9ªF¨ ©X8EX 9ß <ÁÊ<ÔÊÌÌ ÔÁ ´FºªÆM¨øFº8FR ©øM ¨Xª 9ød±Æ8¨ß ±T ©X8EX Xøº 檪F <ÁÊ<ÔÊÌÍ Ó< ºÆøT¨ªº æß ”ÆÚ fiøƺªF ©8¨X ø XªøºªÆ ø¥±FR ¨Xª ¥8FªM ±T <ÁÊ<ÔÊÌÁ ÓÔ ˛ÃX8M 8M ¨Xª øRƪªº M¨ø¨ª9ªF¨Ú˛ <ÁÊ<ÔÊÏÏ ÓÓ ¨Xª ÓFºÚ ÓÌ fl¨ E¥±Mª ±T D¥øß ±F <ÁÊ<ÔÊÏË Õ± " ÛÛ " ©øM ÛÛ " Xøº R±Fª ´FºªÆ ¨Xª <ÁÊ<ÔÊÎ< ÓÏ ›XøFFª¥ ôFFª¥ øFº " ©øM M8¨¨8FR ±F ¨Xª ±¨XªÆ M8ºª øFº <ÁÊ<ÔÊÎÏ ÓÎ ¨Xø¨ ª9ø8¥Ù ©X8EX 9ß ´FºªÆM¨øFº8FR ©øM ¨Xø¨ 8¨ Xøº <ÁÊ<ÔÊÎÈ ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page128 of 883 Œ—ÕÕ “¤"‘ ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª ÌÌ Ô æªªF M8RFªº ±TT æß ¨Xª E¥8ªF¨Ù ªTTªE¨8™ª¥ßÙ ©øM ¨XªF <ÁÊ<ÓÊ<Ô Ó MªF¨ ±´¨ ¨± ø F´9æªÆ ±T 9ªº8øÙ 8FE¥´º8FR ”ÆÚ fiø¥¥ øFº <ÁÊ<ÓÊ<Î Ì ™øÆ8±´M ±¨XªÆ À’ Fª©MDøDªÆMÚ <ÁÊ<ÓÊ<Á Ï œÚ ”ÆÚ Ÿ±©Ù ©XªF ß±´ Møß ˛ªFº ±T D¥ø߲ øFº ˛E¥±Mª <ÁÊ<ÓÊÔÓ Î ±T D¥øßÙ˛ øƪ ß±´ ƪTªÆÆ8FR ¨± MªFº8FR ¨Xª ª9ø8¥ ¨Xø¨˘M <ÁÊ<ÓÊÔÎ Í ¤®X8æ8¨ Ó· <ÁÊ<ÓÊÔË È Ë flÚ «ªMÙ " ø9Ú ”ŒÚ ‹«¤ŒÊ <ÁÊ<ÓÊÓÏ ”ß ´FºªÆM¨øFº8FR 8M ¨Xø¨ 8¨ ©ªF¨ ¨± <ÁÊ<ÓÊÓÁ Á Dª±D¥ª ±¨XªÆ ¨XøF ¨X±Mª ¥8M¨ªº· <ÁÊ<ÓÊÌ< Ô< Ãÿ¤ …"Ó¤ÕÕÊ <ÁÊ<ÓÊÌÓ ÔÔ ”ŒÚ ‹«¤ŒÊ ÔÓ Ãÿ¤ …"Ó¤ÕÕÊ «ªMÙ ¨Xø¨ 8M ÛÛ ÷´M¨ ø Mø9D¥ªÚ <ÁÊ<ÓÊÌÏ ÃXø¨ 8M ø Mø9D¥ªÚ ¤™ªÆß±Fª ©X± <ÁÊ<ÓÊÌÎ ÔÌ ªTTªE¨8™ª¥ß ÛÛ ©ª¥¥Ù ¨Xª ºª¨ø8¥ ±F ¨X8MÙ " ©øM ºÆ8™8FRÙ <ÁÊ<ÓÊÌÈ ÔÏ M± 9ß ª¥ºªM¨ M±F 8F ¨Xª æøEµ Xøº 9ß fi¥øEµfiªÆÆß øFº ©øM <ÁÊ<ÓÊÏ< ÔÎ ¨Æß8FR ¨± EøD¨´Æª ÛÛ 8¨ ©øM ø Dƪ¨¨ß EXø±¨8E ºøßÚ <ÁÊ<ÓÊÏÌ ÔÍ ”±M¨ Dª±D¥ª 8F ¨Xª À’ ©ªÆª ±F X±¥8ºøßÚ "F TøE¨Ù <ÁÊ<ÓÊÏË ÔÈ 8¨ ©øM ø X±¥8ºøß ©ªªµªFºÙ ±´Æ ±TT8Eª ©øM E¥±MªºÙ 9ß –fl ©øM <ÁÊ<ÓÊÎ< ÔË ±F X±¥8ºøßÙ M± 9ß M±F ©øM æøM8Eø¥¥ß º±8FR øF 8F¨ªÆFMX8D 8F <ÁÊ<ÓÊÎÏ ÔÁ ¨Xª æøEµ ±T ¨Xª EøÆÙ º±©F¥±øº8FR ¨Xª Fø9ªM ±T ¨Xª Eø¥¥ªÆM <ÁÊ<ÓÊÎË Ó< TƱ9 ™øÆ8±´M 9ªº8ø ±´¨¥ª¨M øFº ÛÛ M± ©ª Xøº ø ¥8M¨ ±T <ÁÊ<ÌÊ<Ó ÓÔ ¨X±Mª M± ©XªF " R±¨ ¨± ¨Xª EøÆ DøƵ٠ø¨ ¨Xª ªFº ±T ¨Xª <ÁÊ<ÌÊ<Î ÓÓ ¤´Æ±¨´FFª¥ ¨X8FR 8F ¨Xª À’Ù " Xøº F´9ªÆ±´M Fø9ªMÙ M± ¨Xª <ÁÊ<ÌÊ<Á ÓÌ ª9ø8¥ ©ªF¨ ±´¨ ¨± ø ©8ºª ÆøFRª ±T Dª±D¥ªÚ <ÁÊ<ÌÊÔÏ ÓÏ ÓÎ fi´¨ ¨Xª Ì< ±Æ M± Eø¥¥M " Xøº 8M øF øRRƪRø¨ª F´9æªÆÙ M± ¨XªÆª 98RX¨ Xø™ª 檪F T8™ª Eø¥¥M TƱ9 ¨Xª fifi› ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 <ÁÊ<ÌÊÔÈ <ÁÊ<ÌÊÓ< Case 18-2868, Document 283, 08/09/2019, 2628241, Page129 of 883 Œ—ÕÕ “¤"‘ Ô ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª ÏÏ Ô< 9±Æª MªE±FºMÚ <ÁÊÔÁÊÎ< Ó ”ÕÚ Õ›ÿÀ‘ÃbÊ Ì ”ŒÚ Õ–¤flŒ”fl“Ê Ï ”ŒÚ ‹«¤ŒÊ Î ”ÕÚ Õ›ÿÀ‘ÃbÊ Í ÀFºªÆM¨±±ºÙ øFº " øD±¥±R8¶ªÚ ÃX8M 8M ©Xø¨Ù ¤®X8æ8¨ Á· «ªMÚ <ÁÊÔÁÊÎÓ <ÁÊÔÁÊÎÏ <ÁÊÔÁÊÎÍ «ªMÚ <ÁÊÔÁÊÎÍ ¯¤®X8æ8¨ Á ©øM 9øƵªº T±Æ 8ºªF¨8T8Eø¨8±FÚ˜ <ÁÊÔÁÊÎÍ È fi« ”ÕÚ Õ›ÿÀ‘ÃbÊ <ÁÊÓ<Ê<Ô Ë œÚ <ÁÊÓ<Ê<Ó Á ÃX8M ø¥M± øDDªøÆM ¨± æª øF ª9ø8¥ EXø8F ©8¨X ß±´ øFº ”MÚ ”ø®©ª¥¥Â 8M ¨Xø¨ E±ÆƪE¨· <ÁÊÓ<Ê<Î Ô< flÚ "¨ º±ªM øDDªøÆ ¨± æª M±Ú <ÁÊÓ<Ê<È ÔÔ œÚ ‹8º ß±´ MªFº ¨Xª ¨±D ª9ø8¥ ±T ¨Xª EXø8F ¨Xø¨ <ÁÊÓ<Ê<Ë ÔÓ MøßM ˛—µøßÙ ŸÙ R±8FR ©8¨X ¨X8M˛· <ÁÊÓ<ÊÔ< ÔÌ flÚ " º8ºÚ <ÁÊÓ<ÊÔÌ ÔÏ œÚ flFº º8º ß±´ ƪEª8™ª TƱ9 ”MÚ ”ø®©ª¥¥Ù ¨Xª <ÁÊÓ<ÊÔÏ ÔÎ ÔÍ ÔÈ æ±¨¨±9 ª9ø8¥ ±T ¨Xø¨ EXø8F· flÚ ”ŒÚ ‹«¤ŒÊ Õ±ÆÆßÙ " º±F˘¨ Ø´8¨ª ´FºªÆM¨øFº ¨Xø¨ <ÁÊÓ<ÊÓÁ <ÁÊÓ<ÊÌÔ Ãÿ¤ …"Ó¤ÕÕÊ " 98MMD±µª ¨Xø¨Ú " º8º ƪEª8™ª 8¨ TƱ9 ”MÚ ”ø®©ª¥¥Ú ÓÓ <ÁÊÓ<ÊÔÈ <ÁÊÓ<ÊÓÔ øFM©ªÆÚ Ó< ÓÔ …ª¥¥Ù " 檥8ª™ª ÛÛ ßªM٠ߪøXÙ 8¨ ©øM T±Æ©øƺªº TƱ9 ”MÚ ”ø®©ª¥¥Ù ߪMÚ ÔË ÔÁ " 檥8ª™ª M±Ú <ÁÊÓ<ÊÔÍ ”ŒÚ ‹«¤ŒÊ <ÁÊÓ<ÊÌÌ <ÁÊÓ<ÊÌÏ —µøßÚ <ÁÊÓ<ÊÌË ÓÌ fi« ”ÕÚ Õ›ÿÀ‘ÃbÊ <ÁÊÓ<ÊÌË ÓÏ œÚ <ÁÊÓ<ÊÌÁ ÓÎ ÃXª M´ædªE¨ ¥8Fª º±ªM Xø™ª ˛⁄…˛ ©X8EX ¨± 9ª 8Fº8Eø¨ªM 8¨˘M ø T±Æ©øÆºÚ ‹± ß±´ µF±© ©XªÆª ¨Xª ƪM¨ ±T ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 <ÁÊÓ<ÊÏÓ Case 18-2868, Document 283, 08/09/2019, 2628241, Page130 of 883 Œ—ÕÕ “¤"‘ Ô Ó ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª ÏÎ ¨X8M ª9ø8¥ EXø8F 8M· flÚ <ÁÊÓ<ÊÏÎ ”ß ´FºªÆM¨øFº8FR ±T ¨X8M 8MÊ "¨ ©øM ø X±¥8ºøß <ÁÊÓ<ÊÏÁ Ì 8F ¨Xª À’Ù æ´¨ ”ÆÚ fiøƺªF ©øM F±¨ FªEªMMøÆ8¥ß øEEªMM8楪٠<ÁÊÓ<ÊÎÏ Ï ø¨ M±9ª D±8F¨ 8F ¨89ªÙ M± ¨X8M Xøº 檪F MªF¨ ¨± X89 <ÁÊÓ<ÊÎÁ Î ±Æ8R8Fø¥¥ß æß ”MÚ ”ø®©ª¥¥Ù øFº æªEø´Mª Xª ©øM <ÁÊÓÔÊ<Ì Í ´Fø™ø8¥ø楪٠MXª T±Æ©øƺªº 8¨ ¨± 9ª T±Æ 899ªº8ø¨ª øE¨8±FÚ <ÁÊÓÔÊ<È È " ¨XªÆªT±Æª ƪMD±FºÙ ˛—µøßÙ ŸX8M¥ø8FªÙ "˘¥¥ R± ©8¨X <ÁÊÓÔÊÔÏ Ë ¨X8MÚ˛ <ÁÊÓÔÊÔÁ Á "¨ 8M 9ß ´FºªÆM¨øFº8FR ¨Xø¨ ¨X8M 8M <ÁÊÓÔÊÓ< Ô< ¨Xª øRƪªº M¨ø¨ª9ªF¨ æªEø´Mª ¨Xª M´ædªE¨ ±T ¨Xª MªE±Fº <ÁÊÓÔÊÓÓ ÔÔ ±Fª 8M ˛ÀÆRªF¨Ù ¨X8M 8M ¨Xª M¨ø¨ª9ªF¨˛ M± " ¨øµª ¨Xø¨ <ÁÊÓÔÊÓÏ ÔÓ øM øF 8FM¨Æ´E¨8±F ¨± MªFº 8¨ ±´¨Ù øM ø D±M8¨8™ª <ÁÊÓÔÊÓÈ ÔÌ E±99øFºÊ ˛ÃX8M 8M ¨Xª M¨ø¨ª9ªF¨Ú˛ <ÁÊÓÔÊÌ< ÔÏ œÚ —µøßÚ <ÁÊÓÔÊÌÌ ÔÎ flÚ flFº " MøßÙ ˛ÃXøFµMÙ –X8¥8D˛ æªEø´Mª "˘9 ø©øƪ <ÁÊÓÔÊÌÌ ÔÍ ±T ¨Xª TøE¨ ¨Xø¨ Xª Xøº ø XøFºÙ ø E±FM8ºªÆø楪 XøFº 8F <ÁÊÓÔÊÌÈ ÔÈ ¨Xª ºÆøT¨8FRÚ <ÁÊÓÔÊÏ< ÔË œÚ —µøßÚ ›±´¥º " øMµ ß±´ ¨± D¥ªøMª ƪTªÆ æøEµ ¨± <ÁÊÓÔÊÏÔ ‘±±µ8FR ø¥M± ø¨ ¤®X8æ8¨ ÁÙ ¤®X8æ8¨ Á øDDªøÆM <ÁÊÓÔÊÏÈ ÔÁ ¤®X8æ8¨ ÓÚ Ó< ¨± Xø™ª T8™ª MªF¨ªFEªM 8F 8¨Ú ÓÔ Mø9ª T8™ª MªF¨ªFEªM øƪ Døƨ ±T ¨Xª E±99´F8Eø¨8±F ¨Xø¨ 8M <ÁÊÓÓÊÔ< ÓÓ æ±ÆFª 8F ¤®X8æ8¨ Ó· <ÁÊÓÓÊÔÌ ÓÌ ÓÏ ÓÎ flÚ ‹± ß±´ øRƪª ¨Xø¨ ¨X±Mª Õ±ÆÆßÙ E±´¥º ß±´ Møß ¨Xø¨ øRø8FÚ "˘9 d´M¨ T±¥¥±©8FR ©Xø¨ ß±´Æ ÛÛ œÚ "¨ ©øM ø æøº Ø´ªM¨8±FÚ <ÁÊÓÓÊ<Ì <ÁÊÓÓÊÔË <ÁÊÓÓÊÓ< ‘ª¨ 9ª ¨Æß ¨Xø¨ øRø8FÚ ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 <ÁÊÓÓÊÓÔ Case 18-2868, Document 283, 08/09/2019, 2628241, Page131 of 883 Œ—ÕÕ “¤"‘ Ô œÚ —µøßÚ ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª ÍÏ ÿø™ª ß±´ ª™ªÆ E±99´F8Eø¨ªº øFߨX8FR <ÁÊÎÏÊÏÓ Ó ÆªRøƺ8FR ”MÚ Ÿ´8TTƪ˘M EÆ898Fø¥ ø¥¥ªRø¨8±FM ¨± ¨Xª DƪMM <ÁÊÎÏÊÎÓ Ì ±Æ ¨Xª 9ªº8ø· <ÁÊÎÏÊÎÍ Ï flÚ <ÁÊÎÏÊÎË flM Døƨ ±T ø ©8ºªÆ E±F™ªÆMø¨8±F øæ±´¨ XªÆ Î ´FMø™±Æß ø¥¥ªRø¨8±FM øæ±´¨ ”MÚ ”ø®©ª¥¥Ù 8¨˘M D±MM8楪 <ÁÊÎÎÊ<Ï Í ¨Xø¨ " 98RX¨ Xø™ª º±FªÙ æ´¨ " EøF˘¨ ƪEø¥¥ ¨Xª ºª¨ø8¥Ù <ÁÊÎÎÊ<Ë È "˘9 øTÆø8ºÚ <ÁÊÎÎÊÔÔ Ë œÚ <ÁÊÎÎÊÔÓ Á ÃXª Ÿ´øƺ8øF· Ô< flÚ ÔÔ EøF˘¨ ƪEø¥¥Ú ÔÓ µ8FºÙ ¨Xø¨ "˘™ª 檪F MDªøµ8FR ¨± ±™ªÆ Ì< d±´ÆFø¥8M¨M øFº <ÁÊÎÎÊÌÏ ÔÌ 9ªº8ø ±´¨¥ª¨M øæ±´¨ ¨X8MÙ øFº " EøF˘¨ ƪEø¥¥ ª™ªÆß M8FR¥ª <ÁÊÎÎÊÌÁ ÔÏ ÛÛ ¨Xª ºª¨ø8¥ ±T ª™ªÆß M8FR¥ª E±F™ªÆMø¨8±FÚ <ÁÊÎÎÊÏÔ ÔÎ œÚ ‹± ß±´ ÛÛ º± ß±´ ƪ9ª9æªÆ º8ME´MM8FR ¨Xø¨ ©8¨X <ÁÊÎÎÊÓ< “±Ù " º±F˘¨Ú "˘9 F±¨ Møß8FR " º8ºF˘¨ æ´¨ " «±´ Xø™ª ¨± æªøÆ 8F 98FºÙ 8T ß±´˘º æª M± ¤øÆ¥8ªÆ ß±´ ¨ªM¨8T8ªº ©8¨X ƪRøƺ ¨± ¤®X8æ8¨ Ó <ÁÊÎÎÊÓÍ <ÁÊÎÎÊÓÁ <ÁÊÎÎÊÏÏ ÔÍ ¨Xø¨ 8F ¨Xª ºøßM T±¥¥±©8FR MªFº8FR ¨Xø¨ ª9ø8¥Ù ß±´ ø¥M± <ÁÊÎÎÊÏÈ ÔÈ E±99´F8Eø¨ªº ©8¨X ±¨XªÆ DƪMM øFº 9ªº8ø ±´¨¥ª¨MÚ <ÁÊÎÎÊÎÌ ÔË ÆªEø¥¥ ¨±ºøß øFß ±T ¨Xª ±¨XªÆ DƪMM øFº 9ªº8ø ±´¨¥ª¨M ß±´ <ÁÊÎÎÊÎË ÔÁ E±99´F8Eø¨ªº ©8¨XÙ 8F øºº8¨8±F ¨± ¨X±Mª ¥8M¨ªº ø¨ ¨Xª ¨±D <ÁÊÎÍÊ<Ó Ó< ±T ¨Xø¨ ª9ø8¥· <ÁÊÎÍÊ<È ÓÔ flÚ ‹± ß±´ ÃXª Ÿ´øƺ8øFÙ ÃXª Õ´FÙ TƱ9 ¨Xª ¨±D ±T 9ß <ÁÊÎÍÊ<È ÓÓ 9ª9±ÆßÙ æ´¨ 8F øºº8¨8±F ¨± ÛÛ 8F øºº8¨8±F ¨± ª9ø8¥M ¨XªÆª <ÁÊÎÍÊÔÏ ÓÌ ©±´¥º Xø™ª 檪F ¨ª¥ªDX±Fª Eø¥¥M øFº "˘9 ÛÛ ¨XªÆª 9øß F±¨ <ÁÊÎÍÊÓÔ ÓÏ æª ø ¨ÆøFMEÆ8D¨ ±T ¨X±Mª Eø¥¥MÙ ¨XªMª øƪ ª9ø8¥M 8F¨ªÆ <ÁÊÎÍÊÓÎ ÓÎ ø¥8øÙ ±¨XªÆMÙ øFº " EøF˘¨ ƪEø¥¥ ª™ªÆß M8FR¥ª ª9ø8¥ 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8F <ÁÊÎÁÊÏ< ÔÈ ÆªMD±FMª ¨± 8FE±98FR Ø´ªÆ8ªM ÛÛ <ÁÊÎÁÊÏÌ ÔË œÚ ‹± ß±´ ÛÛ <ÁÊÎÁÊÏÍ ÔÁ flÚ fi´¨ " ÛÛ <ÁÊÎÁÊÏÍ Ó< œÚ Õ±ÆÆßÚ <ÁÊÎÁÊÏÈ ÓÔ flÚ " EøF˘¨ ƪ9ª9æªÆ ª™ªÆß M8FR¥ª ±FªÚ <ÁÊÎÁÊÏË ÓÓ œÚ ‹± ß±´ ƪEø¥¥ ª™ªÆ ƪøº8FR ¨Xª M¨ø¨ª9ªF¨ ¨± ¨Xª <ÁÊÎÁÊÎ< ÓÌ DƪMM ±Æ ¨Xª 9ªº8ø ±™ªÆ ¨Xª DX±Fª· ÓÏ ÓÎ flÚ <ÁÊÎÁÊÎÓ "¨˘M ™ªÆß D±MM8楪 ¨Xø¨ " ©±´¥º Xø™ª º±Fª M±Ù ߪMÚ ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ <ÁÊÎÁÊÎÍ <ÁÊÎÁÊÎÈ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page133 of 883 Œ—ÕÕ “¤"‘ ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª ÍÈ Ô ”ŒÚ ‹«¤ŒÊ Ó ”ÕÚ Õ›ÿÀ‘ÃbÊ «ªMÚ Ì Ãÿ¤ …"Ó¤ÕÕÊ Ã± æª E¥ªøÆÙ ¤®X8æ8¨ Ó ©øM ¨Xª Ï ‹± ß±´ 9ªøF ¤®X8æ8¨ Ó· <ÁÊÎÁÊÎË ¤®X8æ8¨ ÓÚ Ô<Ê<<Ê<< æøMª º±E´9ªF¨Ú Ô<Ê<<Ê<Ó Ô<Ê<<Ê<Ì Î ”ÕÚ Õ›ÿÀ‘ÃbÊ ÀXÛX99Ú Ô<Ê<<Ê<Î Í Ãÿ¤ …"Ó¤ÕÕÊ "F øºº8¨8±F ¨± ¨Xª Ó<ÔÔ ”øÆEX Ô<Ê<<Ê<Î ÃX±Mª ©ªÆª ¨Xª ¨©± ©±Æµ8FR º±E´9ªF¨M ¨Xø¨ Ô<Ê<<ÊÔ< È M¨ø¨ª9ªF¨Ú Ë ©ªÆª ø¥©øßM ƪTªÆƪº ¨±Ù 汨X ±T ©X8EX ÛÛ ©ª¥¥Ù ¨Xª T8ÆM¨ Ô<Ê<<ÊÔÎ Á ±Fª ©øM 8F ø D´æ¥8E º±9ø8F øFº ©øM ±F ƪE±Æº ±F ¨Xª Ô<Ê<<ÊÔÈ Ô< ‹ª™±FMX8ƪM ÛÛ 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Ô<Ê<ÔÊ<Á Case 18-2868, Document 283, 08/09/2019, 2628241, Page134 of 883 Œ—ÕÕ “¤"‘ Ô Ó Ì ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª ÍË M8FR¥ª DªÆM±F ©ª ƪøEXªº ±´¨ ¨±Ú œÚ —µøßÚ Ô<Ê<ÔÊÔÌ Õ± 8M 8¨ ß±´Æ ¨ªM¨89±Fß ¨Xø¨ ß±´ ƪøEXªº ±´¨ ¨± 8Fº8™8º´ø¥M ©X± º8º F±¨ T8ÆM¨ E±F¨øE¨ ß±´· Ô<Ê<ÔÊÔÁ Ô<Ê<ÔÊÓÓ Ï flÚ “±Ú …ª ©ªÆª 8F ƪMD±FMª 9±ºªÚ Ô<Ê<ÔÊÓÍ Î œÚ —µøßÚ Ô<Ê<ÔÊÓË Í flÚ ÃXªÆª ©øM ªF±´RX ¨± º± ƪMD±Fº8FR ¨± 8FE±98FR Ô<Ê<ÔÊÓÁ È Ø´ªÆ8ªMÙ " ©±´¥ºF˘¨ Xø™ª 檪F 9øµ8FR 9±Æª ©±ÆµÙ ¨± æª Ô<Ê<ÔÊÌÌ Ë X±FªM¨Ú Ô<Ê<ÔÊÌË Á œÚ Ô< fl¥Æ8RX¨Ú ”ŒÚ ‹«¤ŒÊ Ô<Ê<ÔÊÌË Õ± d±´ÆFø¥8M¨M Dø8º F± ø¨¨ªF¨8±F ¨± Ô<Ê<ÔÊÏÓ ÔÔ ß±´Æ ˛“± T´Æ¨XªÆ E±99´F8Eø¨8±F ©8¥¥ æª DƱ™8ºªº ±F ¨Xª Ô<Ê<ÔÊÏÏ ÔÓ 9ø¨¨ªÆÚ˛ Ô<Ê<ÔÊÏÈ ÔÌ ÔÏ flÚ “± ÛÛ ¨Xø¨˘M Ø´8¨ª E±ÆƪE¨Ù M8ÆÙ øFº ¨XªÆª DƱæøæ¥ß ©øM ø ÛÛ 8¨˘M ƪRøƺªº øM ¨©ªøµ8FR ¨Xª8Æ ¨ø¥ªMÚ Ô<Ê<ÔÊÏË Ô<Ê<ÔÊÎ< ÔÎ fi« ”ÕÚ Õ›ÿÀ‘ÃbÊ Ô<Ê<ÓÊ<< ÔÍ œÚ Ô<Ê<ÓÊ<< ÔÈ ¤®X8æ8¨ ÔÏÚ ÔË R8™ª ß±´ ø 9±9ªF¨ ¨± ¥±±µ ø¨ 8¨Ú ÔÁ ”ÆÚ Ÿ±©Ù "˘9 XøFº8FR ß±´ ©Xø¨ "˘™ª 9øƵªº øM ÃXª fiø¨ªM F´9æªÆ 8M ŒŸ¯À’˜ <<<<<ÏÚ fi« ”ÕÚ Õ›ÿÀ‘ÃbÊ ÓÔ œÚ ÓÌ ÓÏ ÓÎ ÃXøFµ ß±´Ú Ô<Ê<ÓÊ<Ï Ô<Ê<ÓÊÔÈ ¯¤®X8æ8¨ ÔÏ ©øM 9øƵªº T±Æ 8ºªF¨8T8Eø¨8±FÚ˜ Ó< ÓÓ "˘¥¥ Ô<Ê<ÓÊÔÁ Ô<Ê<ÓÊÏÌ Ã±©øƺ ¨Xª ¨±D ±T ¨Xª DøRª ¨XªÆª 8M ø DøMMøRª ¨Xø¨ ƪøºMÊ Ô<Ê<ÓÊÏÏ Ô<Ê<ÓÊÏÈ ˛flD±¥±R8ªMÙ MX±´¥º ƪøº 8ÆR8Fø Œ±æªÆ¨M ø¥¥ ¨Xª ©øß ¨XƱ´RXÚ˛ jflM ƪøºk ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 Ô<Ê<ÓÊÏÁ Ô<Ê<ÓÊÎÔ Ô<Ê<ÓÊÎÌ Case 18-2868, Document 283, 08/09/2019, 2628241, Page135 of 883 Œ—ÕÕ “¤"‘ ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª Ô<Á Ô MªÆ™8E8FR ´¥¨Æø X8RX Fª¨ ©±Æ¨X E¥8ªF¨MÙ 8Fº8™8º´ø¥MÙ ÔÔÊÓÌÊÔÏ Ó E±ÆD±Æø¨ªMÙ R±™ªÆF9ªF¨M øFº “Ÿ—MÙ 9øFøR8FR ¨Xª8Æ 9ªº8ø ÔÔÊÓÌÊÓ< Ì Æª¥ø¨8±FM øFº DƱ¨ªE¨8FR ¨Xª8Æ ÆªD´¨ø¨8±FÚ ÔÔÊÓÌÊÓÎ Ï Î Í œÚ M´EX MªÆ™8EªM· flÚ È Ë flDDƱ®89ø¨ª¥ß X±© ¥±FR Xø™ª ß±´ 檪F DƱ™8º8FR ÔÔÊÓÌÊÓÈ ÔÔÊÓÌÊÌ< flE´8¨ß ©øM Mª¨ ´D 8F Ó<Ô<Ú ÔÔÊÓÌÊÌÔ ¯¤®X8æ8¨ ÓÍ ©øM 9øƵªº T±Æ 8ºªF¨8T8Eø¨8±FÚ˜ ÔÔÊÓÌÊÏÓ fi« ”ÕÚ Õ›ÿÀ‘ÃbÊ Á œÚ Ô< ¤®X8æ8¨ ÓÍÚ ÔÔÊÓÌÊÌÁ ÔÔ flÚ ÃXøFµ ß±´Ú ÔÔÊÓÌÊÏÌ ÔÓ œÚ ‹±ªM ¨X8M º±E´9ªF¨ Tø8Æ¥ß ºªD8E¨ DøRªM TƱ9 ÔÔÊÓÌÊÎÌ ÔÌ "˘9 R±8FR ¨± XøFº ß±´ ©Xø¨ "˘™ª 9øƵªº øM ß±´Æ ÛÛ TƱ9 flE´8¨ß ŒªD´¨ø¨8±F˘M ©ªæM8¨ª· ÔÔÊÓÌÊÌÈ ÔÔÊÓÌÊÎÎ ÔÏ flÚ "¨ º±ªMÚ ÔÔÊÓÌÊÎÁ ÔÎ œÚ ‹± ß±´ Mªª ©XªÆª 8¨ MøßM ˛…ª 9øFøRª ƪD´¨ø¨8±F ÔÔÊÓÏÊ<Ó ÔÍ øFº T±ÆRª ±D8F8±F ¨XƱ´RX D´æ¥8E ƪ¥ø¨8±FMÙ M¨Æø¨ªR8E ÔÔÊÓÏÊ<Í ÔÈ E±99´F8Eø¨8±FM øFº X8RX ¥ª™ª¥ Fª¨©±Æµ8FR˛· ÔÔÊÓÏÊÔ< ÔË flÚ " º±Ú ÔÔÊÓÏÊÔÌ ÔÁ œÚ "M ¨Xø¨ ø ¨Æ´ª M¨ø¨ª9ªF¨· ÔÔÊÓÏÊÔÌ Ó< flÚ Õøß 8¨ øRø8FÚ ÔÔÊÓÏÊÔÎ ÓÔ œÚ "M ¨Xø¨ ø ¨Æ´ª M¨ø¨ª9ªF¨· ÔÔÊÓÏÊÔÈ ÓÓ flÚ "¨ 8M٠ߪMÚ ÔÔÊÓÏÊÔË " ©Æ±¨ª ¨Xø¨ M¨ø¨ª9ªF¨Ú ÓÌ ”ŒÚ ‹«¤ŒÊ ÓÏ Ãÿ¤ …"Ó¤ÕÕÊ ÓÎ Õ±ÆÆßÚ Õ±ÆÆßÙ ß±´ ƪøº 8¨ ±Æ ß±´ ©Æ±¨ª 8¨· " ©Æ±¨ª 8¨Ù M± " º± ƪE±RF8¶ª 8¨Ú fi« ”ÕÚ Õ›ÿÀ‘ÃbÊ ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ ÔÔÊÓÏÊÓ< ÔÔÊÓÏÊÓÓ ÔÔÊÓÏÊÓË “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page136 of 883 Œ—ÕÕ “¤"‘ Ô œÚ ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª ÔÔ< "M 8¨ E±ÆƪE¨ ¨Xø¨ D´æ¥8E ƪ¥ø¨8±FM øFº ÔÔÊÓÏÊÓÁ Ó M¨Æø¨ªR8E E±99´F8Eø¨8±FM øƪ ¨X8FRM ¨Xø¨ ß±´ DªÆM±Fø¥¥ß ÔÔÊÓÏÊÌÔ Ì º± øM Døƨ ±T ß±´Æ DƱTªMM8±Fø¥ øE¨8™8¨8ªM· ÔÔÊÓÏÊÌÍ Ï Î Í È Ë Á Ô< ÔÔ ÔÓ flÚ " DªÆM±Fø¥¥ß ÛÛ "˘9 8F™±¥™ªº 8F D´æ¥8E ƪ¥ø¨8±FM øFº M¨Æø¨ªR8E E±99´F8Eø¨8±FM٠ߪMÚ œÚ "M 8¨ E±ÆƪE¨ ¨Xø¨ ¨Xª 9ªº8ø 8M ¨Xª 8F¨ªFºªº ƪE8D8ªF¨ ±T ¨X8M M¨Æø¨ªR8E E±99´F8Eø¨8±FMÚ flÚ ¨Xª 9ªº8øÚ ÔÔÊÓÏÊÏÏ ÔÔÊÓÏÊÏË ÔÔÊÓÏÊÎÔ "¨˘M ÛÛ ¨Xª ÛÛ 8¨˘M ø ¥øÆRªÆ RƱ´Fº ¨XøF d´M¨ ÔÔÊÓÏÊÎÎ ÃXªÆª 9øß æª ¥±ææß8M¨MÙ R±™ªÆF9ªF¨ ¨X8Fµ ÔÔÊÓÏÊÎÁ ¨øFµMÙ T±E´M RƱ´DMÙ R±™ªÆF9ªF¨ ºªDøƨ9ªF¨MÚ œÚ ÔÔÊÓÏÊÏ< …±´¥º 8¨ æª Tø8Æ ¨± Møß ¨Xø¨ ¨Xª 9ªº8ø 8M ±T¨ªF ¨Xª 8F¨ªFºªº ƪE8D8ªF¨ ±T M¨Æø¨ªR8E E±99´F8Eø¨8±FM· ÔÔÊÓÎÊ<Î ÔÔÊÓÎÊ<Á ÔÔÊÓÎÊÔÓ ÔÌ flÚ "¨ 8M ø TƪشªF¨ ƪE8D8ªF¨Ú ÔÔÊÓÎÊÔÍ ÔÏ œÚ ŒªTªÆªF¨ ƪE8D8ªF¨· ÔÔÊÓÎÊÔË ÔÎ flÚ fi´¨ F±¨ ¨Xª M±¥ª ƪE8D8ªF¨Ú ÔÔÊÓÎÊÓÔ ÔÍ œÚ —µøßÚ ÔÔÊÓÎÊÓÌ ‹± ß±´ Mªª ©XªÆª ß±´Æ ©ªæM8¨ª E¥ø89M ÔÈ ¨Xø¨ ß±´Æ E±9DøFß XøM ˛ª®Eª¥¥ªF¨ ƪ¥ø¨8±FMX8DM ©8¨X ¨Xª ÔÔÊÓÎÊÓÎ ÔË 9ªº8ø˛· ÔÔÊÓÎÊÓË ÔÁ flÚ " º±Ú ÔÔÊÓÎÊÌ< Ó< œÚ "M ¨Xø¨ ø ¨Æ´ª M¨ø¨ª9ªF¨· ÔÔÊÓÎÊÌÔ ÓÔ flÚ ÃXø¨ 8M ¨Æ´ªÙ ߪøXÚ ÔÔÊÓÎÊÌÌ ÓÓ ”ŒÚ ‹«¤ŒÊ ÔÔÊÓÎÊÌÈ ÓÌ Ãÿ¤ …"Ó¤ÕÕÊ ¤®EªD¨ ”ÆÚ ÕßM±FÙ M8ÆÚ ÔÔÊÓÎÊÌË ÓÏ ”ÕÚ Õ›ÿÀ‘ÃbÊ —T E±´ÆMªÚ ÔÔÊÓÎÊÏ< ÓÎ Ãÿ¤ …"Ó¤ÕÕÊ flFº ƪDƪMªF¨ø¨8™ªM ±T ¨Xª ‹ø8¥ß ÔÔÊÓÎÊÏ< ¤®EªD¨ ”ÆÚ ÕßM±FÚ ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page137 of 883 Œ—ÕÕ “¤"‘ Ô ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª ÔÔÔ ”8ÆƱÆÚ ÔÔÊÓÎÊÏÔ Ó fi« ”ÕÚ Õ›ÿÀ‘ÃbÊ ÔÔÊÓÎÊÏÓ Ì œÚ ÔÔÊÓÎÊÏÓ "M 8¨ E±ÆƪE¨ ¨Xø¨ ß±´ øº™ªÆ¨8Mª ß±´Æ Ï ˛ª®Eª¥¥ªF¨ ƪ¥ø¨8±FMX8DM ©8¨X ¨Xª 9ªº8ø˛ æªEø´Mª ß±´Æ ÔÔÊÓÎÊÏÍ Î MªÆ™8EªM ±T¨ªF 8FE¥´ºª R8™8FR E±99´F8Eø¨8±FM ¨± ¨Xª 9ªº8ø ÔÔÊÓÎÊÏÁ Í ±F æªXø¥T ±T ß±´Æ E¥8ªF¨M· ÔÔÊÓÎÊÎÓ È flÚ «ªMÚ ÔÔÊÓÎÊÎÎ Ë ”ÕÚ Õ›ÿÀ‘ÃbÊ Á ”ŒÚ ‹«¤ŒÊ ÃXø¨˘M ø¥¥ " Xø™ª T±Æ Æ8RX¨ F±©Ú " d´M¨ ©øF¨ªº ¨± øMµ ß±´ ±Fª ÔÔÊÓÍÊ<Ô Ô< Ø´ªM¨8±F øæ±´¨ ¤®X8æ8¨ ÓÎÚ ÔÔ “ª© «±Æµ ‹ø8¥ß “ª©M ¨± ß±´ ©X8EX ß±´ MªF¨ ±F ¨± ÔÔÊÓÍÊÔÌ ÔÓ ”MÚ ”ø®©ª¥¥ øFº ”ÆÚ fiøƺªFÚ ÔÔÊÓÍÊÔÈ ÔÌ Ãÿ¤ …"Ó¤ÕÕÊ ÔÏ ”ŒÚ ‹«¤ŒÊ ÃX8M ©øM ¨Xª ª9ø8¥ TƱ9 ¨Xª ÔÔÊÓÎÊÎÁ «ªMÚ ÔÔÊÓÍÊ<Ì ÔÔÊÓÍÊÓ< ‹± ß±´ ƪE±¥¥ªE¨ ©Xª¨XªÆ ß±´ ©ªÆª ÔÔÊÓÍÊÓÁ ÔÎ øMµªº ¨± 9øµª øFß M¨ø¨ª9ªF¨ 8F ƪMD±FMª ¨± ¨X8M 9ø¨¨ªÆÙ ÔÔÊÓÍÊÌ< ÔÍ ¨Xª 8MM´ª ±T DƱEªªº8FRM 8F ÕªD¨ª9æªÆ ±T ¥øM¨ ߪøÆ· ÔÔÊÓÍÊÌÎ ÔÈ Ãÿ¤ …"Ó¤ÕÕÊ " º±F˘¨Ù M8ÆÚ "¨˘M ø¥©øßM 檪F ÔÔÊÓÍÊÏ< ÔË ¨Xª EøMª ¨Xø¨ ”ÆÚ fiøƺªF øFº " ©ªÆª ªFE±´ÆøR8FR ÔÔÊÓÍÊÏÎ ÔÁ ”MÚ ”ø®©ª¥¥ ¨± 9øµª ø M¨ø¨ª9ªF¨Ù æ´¨ MXª ©øM ™ªÆß ÔÔÊÓÍÊÎ< Ó< ƪ¥´E¨øF¨ ¨± º± M±Ú ÔÔÊÓÍÊÎÈ ÓÔ ”ŒÚ ‹«¤ŒÊ Œ8RX¨Ú " ¨X8Fµ ß±´˘™ª R±¨ X89 ¨± ÔÔÊÓÈÊ<< ÓÓ øEEªD¨ ¨Xø¨ ´D ´F¨8¥ M±9ª ¨89ª ”øÆEXÙ flDÆ8¥Ù ”øßÙ Xª 9øß ÔÔÊÓÈÊ<Ó ÓÌ Xø™ª MD±µªF ¨± ”ÆÚ ÕßM±FÚ ÔÔÊÓÈÊ<Í ÓÏ M¨ø¨ª9ªF¨ ¨Xø¨ ¨XªÆª˘M øFß ª™8ºªFEª ±T X89 9øµ8FR øæ±´¨ ÔÔÊÓÈÊÔ< ÓÎ ¨X8M 9ø¨¨ªÆÚ ÔÔÊÓÈÊÔÏ flFº ¨Xø¨ ©øM ¨Xª ¥øM¨ fi´¨ ±F ¨Xª ª™8ºªFEªÙ øM " ´FºªÆM¨øFº 8¨Ù ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page138 of 883 Œ—ÕÕ “¤"‘ Ô ÕÀÃÿ¤Œ‘fl“‹ Ÿ—… ÔÔÒÔËÒÓ<ÔÍ –øRª ÔÓÈ ›¤ŒÃ"⁄"›flä —⁄ ›—ÀŒÃ Œ¤–—ŒÃ¤Œ Ó Ì "Ù ‘8Mø ”Ú fiøÆƪ¨¨Ù øF flEEƪº8¨ªº Œªø¥Û¨89ª ŒªD±Æ¨ªÆÙ Ï XªÆªæß EªÆ¨8Tß ¨Xø¨ ¨Xª ¨ªM¨89±Fß ±T ¨Xª ©8¨FªMM Œ±MM Î “ª8¥ Õ´¨XªÆ¥øFº Ÿ±© 8F ¨Xª T±ÆªR±8FR ¨ÆøFMEÆ8D¨Ù Í F´9æªÆªº DøRªM Ô ¨XƱ´RX ÔÓÓÙ ¨øµªF ±F ¨X8M Ô˨X ºøß È ±T “±™ª9æªÆÙ Ó<ÔÍ ©øM ƪE±Æºªº æß 9ª 8F 9øEX8Fª Ë MX±Æ¨XøFº øFº ©øM ¨XªÆªøT¨ªÆ ¨ÆøFMEÆ8檺 æß 9ªÂ øFº Á ¨Xø¨ ¨Xª T±ÆªR±8FR ¨ÆøFMEÆ8D¨ 8M ø ¨Æ´ª øFº øEE´Æø¨ª Ô< ™ªÆæø¨89 ƪE±Æº ±T ¨Xª Mø8º ¨ªM¨89±FßÚ ÔÔ ÔÓ ÔÌ " T´Æ¨XªÆ EªÆ¨8Tß ¨Xø¨ " ø9 F±¨ ø ƪ¥ø¨8™ªÙ ª9D¥±ßªªÙ ÔÏ E±´FMª¥ ±Æ T8FøFE8ø¥¥ß 8F™±¥™ªº ©8¨X øFß ±T ¨Xª ÔÎ Døƨ8ªM ¨± ¨Xª ©8¨X8F Eø´MªÙ F±Æ ø9 " øF ª9D¥±ßªª ±Æ ÔÍ Æª¥ø¨8™ª ±T øFß E±´FMª¥ T±Æ ¨Xª Døƨ8ªMÙ F±Æ ø9 "Ù 8F ÔÈ øFß ©øßÙ 8F¨ªÆªM¨ªº 8F ¨Xª ±´¨E±9ª ±T ¨Xª ©8¨X8F ÔË Eø´MªÚ ÔÁ Ó< ÓÔ Õ8RFªºÊ ÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚ ÓÓ “ø9ªÊ ‘8Mø ”Ú fiøÆƪ¨¨Ù Œ–ŒÙ ›ŒŒÙ ›Œ›Ù ›ÕŒ ÓÌ ‹ø¨ªÊ ÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚÚ ÓÏ ÓÎ ‹Ã" ›±´Æ¨ ŒªD±Æ¨8FR Õ±¥´¨8±FM Ô Ë<< ÌÓÎ ÌÌÈÍ “ª© «±Æµ ©©©ÚºªD±M8¨8±FÚE±9 CQQP 18-7868, 782, 08/00/7010, 7678741, Pagm RC) nf EXHIBIT 7 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page140 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 20, 2016 9:12 a.m. C O N F I D E N T I A L Deposition of pursuant to notice, taken by Plaintiff, at the offices of Podhurst Orseck, 25 West Flagler Street, Suite 800, Miami, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 18-2868, Document 283, 08/09/2019, 2628241, Page141 of 883 Page 54 1 2 3 4 - CONFIDENTIAL BY MR. EDWARDS: Q. requested to give a massage? 5 6 When you got to his house, you were MR. PAGLIUCA: Object to foundation and form. 7 THE WITNESS: I don't exactly remember. 8 don't remember if I was asked in the kitchen. 9 I don't remember if -- I don't remember. 10 11 BY MR. EDWARDS: Q. 12 13 Massage was part of the game, though? MR. PAGLIUCA: THE WITNESS: 15 sorry. 16 BY MR. EDWARDS: 18 19 20 21 22 Object to form and foundation. 14 17 Q. I don't remember. I'm But even during this deposition today, we have described at times you giving him a massage? A. Yes. You're asking about my first encounter, though. Q. Sorry, I'm just trying to sum up the whole thing. 23 A. Okay. 24 Q. Was massage part of the lure to get you 25 I specifically to his house? Case 18-2868, Document 283, 08/09/2019, 2628241, Page142 of 883 Page 55 1 2 - CONFIDENTIAL A. 3 4 5 6 7 MR. PAGLIUCA: BY MR. EDWARDS: Q. And at the time, you are 15, 16 or 17 years old? MR. PAGLIUCA: Object to form and foundation. 10 11 Object to form and foundation. 8 9 Yes. THE WITNESS: Yes. BY MR. EDWARDS: 12 Q. No massage experience? 13 A. No. 14 Q. You were told to bring other girls to his 15 house? 16 17 MR. PAGLIUCA: foundation. 18 19 20 21 22 23 24 25 Object to form and THE WITNESS: After a while, yes. BY MR. EDWARDS: Q. These massages were turned sexual by Jeffrey, as opposed to by anyone else? A. Jeffrey took my clothes off without my consent the first time I met him. Q. The massages were scheduled by people working for Jeffrey? Case 18-2868, Document 283, 08/09/2019, 2628241, Page143 of 883 Page 56 1 - CONFIDENTIAL 2 A. 3 MR. PAGLIUCA: 4 5 Object to form and foundation. BY MR. EDWARDS: 6 7 I don't recall. Q. Jeffrey Epstein, during these massages, would use sex toys or have sex toys used? 8 MR. PAGLIUCA: 9 Object to form and foundation. 10 THE WITNESS: 11 longer a massage. 12 But, yes, he would take out adult toys and 13 different things. 14 Something else is going on. BY MR. EDWARDS: 15 16 Well, at that point, it's no Q. While you were a teenager, Jeffrey Epstein asked you to live with him? 17 A. Yes. 18 Q. Jeffrey Epstein encouraged girl-on-girl 19 sex? 20 21 MR. PAGLIUCA: 24 25 Object to form and foundation. 22 23 He wanted me to be emancipated. THE WITNESS: Yes. BY MR. EDWARDS: Q. And after you cooperated with the police, you were intimidated by people working for Jeffrey Case 18-2868, Document 283, 08/09/2019, 2628241, Page144 of 883 Page 57 1 2 - CONFIDENTIAL Epstein? 3 4 MR. PAGLIUCA: Object to form and foundation. 5 THE WITNESS: Yes. 6 MR. EDWARDS: All right. I don't have 7 anything further for you. 8 even had to go through this, all right? 9 THE WITNESS: 10 11 12 I apologize that we Okay. E X A M I N A T I O N BY MR. PAGLIUCA: Q. Ms. , by name is Jeff Pagluica. 13 live in Denver, Colorado. 14 want to be here today either, okay? 15 be in Denver. 16 I And, like you, I don't I would rather I just want to -- as I understand it, and 17 I'm not trying to get into any of your treatment 18 over the last, let's say, 10 years, because I don't 19 know how long it's been, but as I understand what 20 you and your lawyer have said here today, you have 21 been involved in some number of years of therapy, in 22 which the purpose -- part of the purpose of the 23 therapy has been to forget all of these events that 24 Mr. Edwards was asking you questions about; is that 25 correct? Case 18-2868, Document 283, 08/09/2019, 2628241, Page145 of 883 Page 71 1 2 3 4 5 6 7 - CONFIDENTIAL CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, the undersigned authority, certify that personally appeared before me and was duly sworn. WITNESS my hand and official seal this 23rd day of June, 2016. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Kelli Ann Willis, RPR, CRR Notary Public, State of Florida Commission FF928291, Expires 2-16-20 + + + + + + + + + + + + + + + + + + CERTIFICATE STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime Reporter do hereby certify that I was authorized to and did stenographically report the foregoing deposition of that a review of the transcript was not requested; and that the transcript is a true record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 23rd day of June, 2016. KELLI ANN WILLIS, RPR, CRR CQQP 18-7868, 782, 08/00/7010, 7678741, nf EXHIBIT 8 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page147 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA L. GIUFFRE, Plaintiff, v. CASE NO.:15-CV-07433-RWS GHISLAINE MAXWELL, Defendants. _______________________________ January 25, 2017 9:05 a.m. - 12:44 p.m. 401 E. Las Olas Boulevard Fort Lauderdale, Florida **** C O N F I D E N T I A L **** VIDEOTAPE DEPOSITION OF SARAH KELLEN Taken on behalf of the before Michael J. D'Amato, RMR, Notary Public in and for the State of Florida at Large, pursuant to Notice of Taking Deposition in the above cause. Job # 293966 Case 18-2868, Document 283, 08/09/2019, 2628241, Page148 of 883 Page 15 1 decline to answer. 2 Q. Who introduced you to Ghislaine Maxwell? 3 A. On advice of my counsel I must invoke my Fifth 4 and Sixth Amendment privilege which I understand 5 protect the innocent and therefore I must unfortunately 6 decline to answer. 7 8 9 Q. When you met Ghislaine Maxwell was she working for Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth 10 and Sixth Amendment privilege which I understand 11 protect the innocent and therefore I must unfortunately 12 decline to answer. 13 14 15 Q. Did Ghislaine Maxwell work as a recruiter for young girls for Jeffrey Epstein when you met her? A. On advice of my counsel I must invoke my Fifth 16 and Sixth Amendment privilege which I understand 17 protect the innocent and therefore I must unfortunately 18 decline to answer. 19 20 21 Q. I'm defining young girls to mean females the ages 12 to 23. A. Do you understand that? On advice of my counsel I must invoke my Fifth 22 and Sixth Amendment privilege which I understand 23 protect the innocent and therefore I must unfortunately 24 decline to answer. 25 Q. Didn't Ghislaine Maxwell approach you to Case 18-2868, Document 283, 08/09/2019, 2628241, Page149 of 883 Page 20 1 2 girls for sex with Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth 3 and Sixth Amendment privilege which I understand 4 protect the innocent and therefore I must unfortunately 5 decline to answer. 6 7 8 9 Q. Did you assist Ghislaine Maxwell in procuring underage girls for sex with Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand 10 protect the innocent and therefore I must unfortunately 11 decline to answer. 12 Q. Isn't it true that Ghislaine Maxwell would 13 recruit underage girls for sex and sex acts with 14 Jeffrey Epstein? 15 A. On advice of my counsel I must invoke my Fifth 16 and Sixth Amendment privilege which I understand 17 protect the innocent and therefore I must unfortunately 18 decline to answer. 19 20 21 Q. Did Ghislaine Maxwell give you information on what underage girls she had contact information for? A. On advice of my counsel I must invoke my Fifth 22 and Sixth Amendment privilege which I understand 23 protect the innocent and therefore I must unfortunately 24 decline to answer. 25 Q. Did Ghislaine Maxwell teach you to offer these Case 18-2868, Document 283, 08/09/2019, 2628241, Page150 of 883 Page 199 1 2 CERTIFICATE OF COURT REPORTER I, MICHAEL J. D'AMATO, a Registered Merit Reporter 3 and Notary Public in and for the State of Florida at 4 Large, do HEREBY CERTIFY that I was authorized to and 5 did stenographically report the deposition of SARAH 6 KELLEN; that a review of the transcript was requested; 7 and that the foregoing transcript, pages from 1 to 197, 8 is a true and accurate record of my stenographic notes. 9 I FURTHER CERTIFY that I am not a relative, 10 employee, attorney, or counsel of any of the parties, nor 11 am I a relative or employee of any of the parties' 12 attorney or counsel connected with the action, nor am I 13 financially interested in the action. 14 Dated this 27th day of January 2017. 15 _______________________ 16 MICHAEL J. D'AMATO, 17 Registered Merit Reporter 18 19 20 21 22 23 24 25 CQQP 18-7868, 782, 08/09/7010, 7678741, Pagm '31 nf EXHIBIT 9 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page152 of 883 Page 1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS ______________________________________________________ VIDEOTAPE DEPOSITION OF: PETER KENT November 29, 2016 ______________________________________________________ VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. ______________________________________________________ PURSUANT TO SUBPOENA AND NOTICE, the videotape deposition of PETER KENT was taken on behalf of the Plaintiff at 150 East 10th Avenue, Denver, Colorado 80230, on November 29, 2016, at 9:00 a.m., before Sandra L. Bray, Registered Diplomate Reporter, Certified Realtime Reporter, and Notary Public within Colorado. MAGNA LEGAL SERVICES (866) 624-6221 Case 18-2868, Document 283, 08/09/2019, 2628241, Page153 of 883 Page 25 1 MS. McCAWLEY: I'm just asking about his 2 retention, which I believe is discoverable under 3 Rule 26. 4 Q. (BY MS. McCAWLEY) Do you recall whether 5 you were retained to perform work for one expert or 6 two experts? 7 8 THE DEPONENT: Am I allowed to answer MR. PAGLIUCA: Yes. this? 9 10 A. I actually don't recall. 11 Q. (BY MS. McCAWLEY) Do you know whether 12 you were provided with one report or two reports when 13 you initially were retained? 14 15 16 A. I believe I was provided with both the reports at the same time. Q. Let me turn to about halfway back. So 17 it's going to be -- there's markings on the bottom. 18 It says PK-005. 19 A. Yes. 20 Q. And it indicates an amount there, an 21 invoice. Is this one of your invoices? 22 A. Yes. 23 Q. It indicates an amount of $17,875? 24 A. Yes. 25 Q. Is that the total amount you've been Case 18-2868, Document 283, 08/09/2019, 2628241, Page154 of 883 Page 26 1 paid, with the exception of what we paid you for your 2 testimony here today, in this matter? 3 A. I think so. 4 Q. It looks like it's dated October 29th, 6 A. Oh, yes. 7 Q. Have you performed any work after that 5 8 What date was this? 2016. In that case, yes. date that you've been paid for? 9 A. Only in preparation for this deposition. 10 Q. Have you been paid for that work? 11 A. No. 12 Q. No. 13 A. No. 14 Q. All right. Have you invoiced that work yet? And then I'm going to turn 15 you to the next page -- please don't put it away 16 yet -- which appear to be invoices. 17 A. Time sheets. 18 Q. Time sheets? 19 A. It's a time sheet. 20 Q. Is this typically how you record your 21 You tell me. time when you're doing expert work? 22 A. Yes. 23 Q. And this indicates -- the first entry is 24 on 9/28/2016. 25 matter? Is that when you commenced work on this Case 18-2868, Document 283, 08/09/2019, 2628241, Page155 of 883 Page 162 REPORTER'S CERTIFICATE STATE OF COLORADO ) ) ss. CITY AND COUNTY OF DENVER ) I, SANDRA L. BRAY, Registered Diplomate Reporter, Certified Realtime Reporter, and Notary Public ID 20084001729, State of Colorado, do hereby certify that previous to the commencement of the examination, the said PETER KENT was duly sworn by me to testify to the truth in relations to the matters in controversy between the parties hereto; that the said deposition was taken in machine shorthand by me at the time and place aforesaid and was thereafter reduced to typewritten form; that the foregoing is a true transcript of the questions asked, testimony given, and proceedings had. I further certify that I am not employed by, related to, nor of counsel for any of the parties herein nor otherwise interested in the outcome of this litigation. IN WITNESS WHEREOF, I have affixed my signature this 8th of December, 2016. My commission expires January 16, 2020. __X__ Reading and Signing was requested. _____ Reading and Signing was waived. _____ Reading and Signing is not required. CQQP 18-7868, 782, 08/00/7010, 7678741, Pagm '36 nf EXHIBIT 10 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page157 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: 15-cv-07433-RWS -againstGHISLAINE MAXWELL, Defendant. - - - - - - - - - - - - - - - - - - - - x C O N F I D E N T I A L Videotaped oral deposition of NADIA MARCINKO, taken pursuant to notice, was held at the law offices of BOIES SCHILLER & FLEXNER, LLP, 575 Lexington Avenue, New York, New York commencing January 17, 2017, 1:04 p.m., before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 Case 18-2868, Document 283, 08/09/2019, 2628241, Page158 of 883 Page 10 1 N. Marcinko - Confidential 2 reside, a dwelling that is paid for by either 3 Jeffrey Epstein or Ghislaine Maxwell? 4 A. Same answer. 5 Q. Do you know Jeffrey Epstein? 6 A. Same answer. 7 Q. Do you know Ghislaine Maxwell? 8 A. Same answer. 9 Q. How old were you when you met 10 either Jeffrey Epstein or Ghislaine Maxwell? 11 A. Same answer. 12 Q. Who introduced to you Ghislaine 13 Maxwell? 14 A. Same answer. 15 Q. When you met Ghislaine Maxwell, was 16 she working for Jeffrey Epstein? 17 A. Same answer. 18 Q. Did Ghislaine Maxwell work as a 19 recruiter of young girls for Jeffrey Epstein 20 when you met her? 21 A. Same answer. 22 Q. Did Ghislaine Maxwell instruct you 23 to recruit young girls for Jeffrey Epstein? 24 A. Same answer. 25 Q. Did Ghislaine Maxwell encourage Case 18-2868, Document 283, 08/09/2019, 2628241, Page159 of 883 Page 12 1 2 N. Marcinko - Confidential Ghislaine Maxwell? 3 A. Same answer. 4 Q. Have you observed Ghislaine Maxwell 5 and Jeffrey Epstein offering these young 6 girls money, education or other things of 7 value during the massage to get that young 8 girl to return to Jeffrey Epstein for sexual 9 purposes? 10 A. Same answer. 11 Q. Have you observed Ghislaine Maxwell 12 and Jeffrey Epstein convert what started as a 13 massage with these young girls into something 14 sexual? 15 A. Same answer. 16 Q. Have you understood when I talk 17 about young girls, I'm talking about girls 18 between the age range of 13 and 23 years old? 19 A. Same answer. 20 Q. Have you observed that when 21 Ghislaine Maxwell and Jeffrey Epstein used 22 the term, massage, it always includes sex? 23 A. Same answer. 24 Q. Was massage a word used by 25 Ghislaine Maxwell to lure girls into sex with Case 18-2868, Document 283, 08/09/2019, 2628241, Page160 of 883 Page 96 1 2 CERTIFICATE 3 I HEREBY CERTIFY that the witness, 4 NADIA MARCINKO, was duly sworn by me and that the deposition is a true record of the 5 6 testimony given by the witness. _______________________________ Leslie Fagin, 7 Registered Professional Reporter Dated: January 17, 2017 8 9 10 (The foregoing certification of 11 this transcript does not apply to any 12 reproduction of the same by any means, unless 13 under the direct control and/or supervision 14 of the certifying reporter.) 15 16 17 18 19 20 21 22 23 24 25 Cam: 18-7868, 782, 08/09/7010, 7678741, Pagmm nf 882 EXHIBIT 11 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page162 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: 15-cv-07433-RWS -againstGHISLAINE MAXWELL, Defendants. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 Case 18-2868, Document 283, 08/09/2019, 2628241, Page163 of 883 Page 23 1 2 3 G Maxwell - Confidential Q. I'm not talking about friends. I'm talking about individuals -- 4 MR. PAGLIUCA: I'm going to object 5 to you interrupting the witness who was 6 answering your question. 7 was, have you ever seen anyone, female 8 under the age of 18 at the house and 9 that's the question she was answering. 10 If you want to strike that question and 11 ask another question, feel free, but let 12 the witness respond, please. 13 14 MS. McCAWLEY: Q. The question I will do that. Have you ever observed a female 15 under the age of 18 at Jeffrey Epstein's home 16 that was not a friend, a child -- one of your 17 friend's children? 18 A. Again, I can't testify to that 19 because I have no idea what you are talking 20 about. 21 Q. You have no idea what I'm talking 22 about in the sense you never observed a 23 female under the age of 18 at Jeffrey 24 Epstein's home that was not one of your 25 friend's children, is that correct? Case 18-2868, Document 283, 08/09/2019, 2628241, Page164 of 883 Page 24 1 G Maxwell - Confidential 2 MR. PAGLIUCA: 3 and foundation. 4 A. Object to the form How would I possibly know how 5 someone is when they are at his house. 6 are asking me to do that. 7 testify to that. 8 everyone who came to his house was an adult 9 professional person. 10 Q. You I cannot possibly As far as I'm concerned, Are you familiar with the police 11 report that was issued in respect to the 12 investigation in this matter? 13 MR. PAGLIUCA: 14 and foundation. 15 Q. Object to the form Are you familiar with the police 16 report that was used in this matter, the 17 investigation of Jeffrey Epstein, has been 18 produced as a document in this matter? 19 A. 20 I have seen a police report. (Maxwell Exhibit 1, police report, 21 marked for identification.) 22 Q. The police report that you have in 23 front of you, can you turn to page 28 of that 24 report, the numbers are on the top right-hand 25 corner. Case 18-2868, Document 283, 08/09/2019, 2628241, Page165 of 883 Page 31 1 G Maxwell - Confidential 2 -- just another one of Virginia's many 3 fictitious lies and stories to make this a 4 salacious event to get interest and press. 5 It's absolute rubbish. 6 Q. Were you in charge of hiring 7 individuals to provide massages for Jeffrey 8 Epstein? 9 A. My job included hiring many people. 10 There were six homes. 11 assistants, I hired architects, I hired 12 decorators, I hired cooks, I hired cleaners, 13 I hired gardeners, I hired pool people, I 14 hired pilots, I hired all sorts of people. 15 As I sit here, I hired In the course and a very small part 16 of my job was from from time to time to find 17 adult professional massage therapists for 18 Jeffrey. 19 Q. When you say adult professional 20 massage therapists, where did you find these 21 massage therapists? 22 A. From time to time I would visit 23 professional spas, I would receive a massage 24 and if the massage was good I would ask that 25 man or woman if they did home visits. Case 18-2868, Document 283, 08/09/2019, 2628241, Page166 of 883 Page 41 1 G Maxwell - Confidential 2 Q. Did you hire her? 3 A. First of all, I don't hire girls 4 like that, so let's be clear, I already 5 testified to that, and I have no idea what 6 you are referring to. 7 Q. When you say girls like that, what 8 do you mean? 9 A. I hire people who are professional 10 at the house. 11 somebody to do what, I don't know what you 12 are talking about. 13 the homes. 14 Q. 15 You are asking if I hired I hired people to work in What was Nadia Marcinkova doing? MR. PAGLIUCA: 16 and foundation. 17 A. Object to the form I have no idea what Nadia 18 Marcinkova was doing. I didn't hire her and 19 I don't know what you are referring to. 20 Q. You met Nadia Marcinkova? 21 A. I testified I did. 22 Q. Did she work for Jeffrey Epstein? 23 A. I have no idea what she did. 24 Q. Have you flown on planes with Nadia 25 Marcinkova? Case 18-2868, Document 283, 08/09/2019, 2628241, Page167 of 883 Page 77 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I don't know what that means, 5 masseuse obligation, I don't know what you 6 are referring to. 7 question properly? 8 9 Q. Would you like to ask the I think it was proper. I will ask it again. 10 Did you ever assist in getting 11 Virginia Roberts a cell phone to use during 12 the time that she worked for Jeffrey Epstein? 13 14 15 A. I have no recollection of doing anything of that nature. Q. Did you ever tell Virginia that you 16 wanted her to have a cell phone so that she 17 could be on call regularly? 18 19 20 21 A. I have no recollection of that conversation. Q. How often would Virginia come over to the house in Palm Beach to give massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Ask the question again, please. 25 Q. How often did Virginia Roberts come Case 18-2868, Document 283, 08/09/2019, 2628241, Page168 of 883 Page 78 1 G Maxwell - Confidential 2 over to the house in Palm Beach to give 3 massages? 4 A. It's important to understand that I 5 wasn't with Jeffrey all the time. 6 was only in the house less than half the 7 time, so I cannot testify to when I wasn't in 8 the house how often she came when I wasn't 9 there. 10 In fact, I What I can say is that I barely 11 would remember her, if not for all of this 12 rubbish, I probably wouldn't remember her at 13 all, except she did come from time to time 14 but I don't recollect her coming as often as 15 she portrayed herself. 16 17 Q. How many times a day on an average day would Jeffrey Epstein get a massage? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. When I was at the house and when I 21 was there with him, he received a massage, on 22 average, about once a day. 23 Q. Just once? 24 A. Yes. 25 Q. Were there days when he received Case 18-2868, Document 283, 08/09/2019, 2628241, Page169 of 883 Page 79 1 2 G Maxwell - Confidential four or five? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. 6 7 When I was present at the house, I never saw something like that. Q. Do you know if Virginia was 8 required to be on call at all times to come 9 to the house if Jeffrey wanted her there? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. 13 14 I have no idea of the arrangements that Virginia made with Jeffrey. Q. When Virginia was in New York, 15 would Virginia sleep at Jeffrey's mansion in 16 New York? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. 20 21 22 I don't recollect her being in New York and I have no idea where she slept. Q. You don't ever remember seeing Virginia Roberts in New York? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I would barely recollect her at Case 18-2868, Document 283, 08/09/2019, 2628241, Page170 of 883 Page 135 1 2 3 G Maxwell - Confidential him at any of those homes? A. Again, Virginia is absolutely 4 totally lying. 5 defamation about Virginia and the lies she 6 has told and one of lies she told was that 7 President Clinton was on the island where I 8 was present. 9 a flat out total fabrication and lie. 10 Q. This is a subject of Absolutely 1000 percent that is You did fly on planes, Jeffrey 11 Epstein's planes with President Clinton, is 12 that correct? 13 A. I have flown, yes. 14 Q. Would it be fair to say that 15 16 17 President Clinton and Jeffrey are friends? A. I wouldn't be able to characterize it like that, no. 18 Q. Are they acquaintances? 19 A. I wouldn't categorize it. 20 Q. He just allowed him to use his 21 22 23 24 25 plane? A. I couldn't categorize Jeffrey's relationship. Q. When you were on the plane with Jeffrey and President Clinton, did you Case 18-2868, Document 283, 08/09/2019, 2628241, Page171 of 883 Page 144 1 G Maxwell - Confidential 2 building that you would have seen when you 3 were on the trip in Europe? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I can't possibly answer that. 7 Q. Do you recall Virginia ever taking 8 pictures? 9 A. I barely recall Virginia, period. 10 Q. Do you recall her ever taking 11 pictures? 12 A. No, I don't. 13 Q. I'm going to direct your attention, 14 still within the flight logs to -- starting 15 on the next page from where you just were 16 which is going to be 000747. 17 the top says 2001, you will see March and I'm 18 directing your attention down towards the 19 middle to the bottom where you will see the 20 numbers 27, 29 and 31. And the date at 21 A. Uh-huh. 22 Q. And we've got actually I'm going to 23 direct your attention to the one that starts 24 with TEB for Teterboro to SAF for Santa Fe 25 and the one below it Santa Fe to Palm Beach Case 18-2868, Document 283, 08/09/2019, 2628241, Page172 of 883 Page 147 1 G Maxwell - Confidential 2 her but you would have to ask Jeffrey what he 3 brought her on the trip for. 4 5 Q. But she would travel with him when there was a work trip like this? 6 A. I can't -- I'm seeing that she is 7 on this flight but I have no idea what she is 8 doing, he invited her, it would not be my 9 job. 10 11 Q. What about Nadia Bjorlin, would she regularly travel with Jeffrey on flights? 12 A. I have no idea, you would have to 13 look through the flight logs. 14 idea. 15 Q. I have no Your recollection is -- what is 16 your recollection, do you recollect Nadia 17 traveling often on flights with Jeffrey? 18 A. Absolutely not. No, not at all. I 19 don't recollect her actually on the flight at 20 all. 21 Q. 22 the moment. 23 I think you can set that aside for (Maxwell Exhibit 9, message pad 24 pages, marked for identification.) 25 Q. We will mark as Exhibit 9 these Case 18-2868, Document 283, 08/09/2019, 2628241, Page173 of 883 Page 148 1 G Maxwell - Confidential 2 excerpts from -- we will identify what they 3 are but from the message pads. 4 5 Did you want to correct anything? A. 6 7 Would you mind rereading the last question back to me? 8 9 I want to make an addendum. (Record read.) A. I also just want to say that at 10 this point I cannot recollect flying to 11 parties. 12 this in Santa Fe, this flight as well. 13 14 15 Q. Jeffrey went for work so -- was The flight we were looking at, yes but it was to Santa Fe -A. I don't recall going to any parties 16 in Santa Fe at any time but certainly flying 17 to Santa Fe for a party seems highly 18 improbable. 19 Q. So I'm going to direct your 20 attention to the document that I set before 21 you which is Bates number SAO 01456 and it 22 has different Bates numbers because it's a 23 smaller version of the larger production. 24 These are the pages I will be asking about. 25 In the time that you were working Case 18-2868, Document 283, 08/09/2019, 2628241, Page174 of 883 Page 149 1 G Maxwell - Confidential 2 with Jeffrey in Palm Beach, do you recall a 3 process for taking, anybody at the house 4 taking messages when incoming phone calls 5 came in? 6 A. You are supposed to take a message 7 and receive the message and write the message 8 down. 9 it was taken and who took it and what the 10 11 Who was the message was for, what time message was, obviously. Q. Does what's in front of you look 12 familiar with respect to the message pads 13 that you would have used at the house? 14 A. It is familiar. 15 Q. I'm going to direct your attention 16 17 to the second page of it? MR. PAGLIUCA: These all have SAO 18 numbers on them or Bates ranges and I 19 don't see any of your Bates ranges on 20 these. 21 pads but those have your Bates range 22 numbers on them and I'm wondering if 23 these are different documents. 24 25 I know you have produced message MS. McCAWLEY: It's the same, just ours have the Bates underneath them. Case 18-2868, Document 283, 08/09/2019, 2628241, Page175 of 883 Page 174 1 2 G Maxwell - Confidential believe. Do you believe -- 3 A. I can only testify -- 4 Q. Let me finish the question so the 5 record is clear. 6 Do you believe Jeffrey Epstein 7 sexually abused minors? 8 MR. PAGLIUCA: 9 Objection to the form and foundation. 10 Q. You can answer. 11 A. I can only testify to what I know. 12 I know that Virginia is a liar and I know 13 what she testified is a lie. 14 testify to what I know to be a falsehood and 15 half those falsehoods are enormous and so I 16 can only categorically deny everything she 17 has said and that is the only thing I can 18 talk about because I have no knowledge of 19 anything else. 20 Q. So I can only I'm not asking about Virginia. 21 asking whether you believe that Jeffrey 22 Epstein sexually abused minors? 23 A. I'm Again, I repeat, I can only go on 24 what I know and what I know is a falsehood 25 based on what Virginia said. Case 18-2868, Document 283, 08/09/2019, 2628241, Page176 of 883 Page 178 1 G Maxwell - Confidential 2 3 What I'm asking you is whether you believe Jeffrey Epstein abused minors? 4 MR. PAGLIUCA: I object to the form 5 and you made your record, she answered 6 the question. 7 answer is she doesn't have a belief 8 because she doesn't have any personal 9 knowledge. 10 A fair reading of her MS. McCAWLEY: Now you are 11 testifying for the witness. 12 answer the question. 13 MR. PAGLIUCA: 14 to the question. 15 A. Let her It's a fair answer Again, I testified my only personal 16 knowledge concerns Virginia and everything 17 Virginia has said is an absolute lie, which 18 is why we are here in this room. 19 asking me to testify about things I have no 20 knowledge of other than the police report 21 that you showed me, I am not in a position to 22 make a statement based on that because you 23 are asking me to speculate and I cannot 24 speculate. 25 Q. If you are I'm asking you about your belief. Case 18-2868, Document 283, 08/09/2019, 2628241, Page177 of 883 Page 179 1 G Maxwell - Confidential 2 I'm not asking you to speculate at all. 3 asking what you believe. 4 5 6 7 A. Q. I'm not asking you to speculate. I'm asking what you believe. MR. PAGLIUCA: She answered the question and we can move on. 10 11 You are asking me to speculate and I won't speculate. 8 9 I'm MS. McCAWLEY: She hasn't answered the question. 12 MR. PAGLIUCA: We are not going to 13 engage in this debate. She answered the 14 question. 15 move to compel an answer to the 16 question, have at it. 17 Q. If you want to mark it and Okay. Ms. Maxwell, is it your belief that 18 Jeffrey Epstein interacted sexually with 19 minors? 20 A. Again, you are asking me the same 21 type of question exactly but with different 22 language. 23 somebody who claims these things that I have 24 personal knowledge of is Virginia. 25 is an absolute liar and everything she has Again, my only knowledge of Virginia Case 18-2868, Document 283, 08/09/2019, 2628241, Page178 of 883 Page 180 1 G Maxwell - Confidential 2 said is a lie. 3 lies I cannot speculate on what anybody else 4 did or didn't do because if Virginia is the 5 example of what that story is and everything 6 she said is false, so everything that leads 7 from that is false. 8 9 Q. Therefore, based on those So the 30 other minor children in the police report are also telling lies about 10 being sexually abused during massages with 11 Mr. Epstein? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 show me in these police reports who the 15 30 minors are? 16 17 18 MS. McCAWLEY: Counsel, can you I'm asking my question. MR. PAGLIUCA: You are making a 19 representation about numbers, you are 20 making a representation on the record 21 about what people said or didn't say. 22 We have no knowledge about that. 23 are all redacted records so these are 24 bad questions. 25 admissible evidence. These They don't lead to any It is only being Case 18-2868, Document 283, 08/09/2019, 2628241, Page179 of 883 Page 214 1 G Maxwell - Confidential 2 A. I'm carrying on. 3 Q. I'm sorry. 4 5 I thought you were done. A. Please. Her statement also that 6 she was driven by her father to Palm Beach. 7 She was driven by her mother, as a matter of 8 fact. 9 the first meeting with Jeffrey, as I was 10 11 Her whole entire characterization of outside speaking to her mother. Q. Let me stop you there, so we don't 12 get too far ahead. 13 understand your testimony. 14 Let me make sure I The first, in the first piece when 15 you were talking, I believe you said and 16 correct me if I'm wrong, that her 17 characterization of the first meeting at 18 Mar-a-Lago was an obvious lie. 19 What part of that meeting was an 20 obvious lie? 21 A. By her own testimony, all her 22 various many different descriptions of what 23 she was or wasn't or where she was or wasn't, 24 they have all changed. 25 of house or bathroom attendant. She was either front I don't know Case 18-2868, Document 283, 08/09/2019, 2628241, Page180 of 883 Page 215 1 G Maxwell - Confidential 2 what she was, so just by her own words, one 3 doesn't know what's true and what isn't true. 4 Q. Are you saying what position she 5 said she was working in, is that what you are 6 considering the obvious lie? 7 A. I said inconsistency within her own 8 statement from everything, so in the 9 beginning it starts off with different 10 statements. 11 Q. 12 Then I believe you said the second piece was that she was driven by her father? 13 A. I said she was driven by her 14 mother. 15 Q. That's the obvious lie? 16 A. It's an obvious lie to me. 17 Q. You said why don't you state it in 18 your own words but the characterization of 19 how she was with Jeffrey, what about that is 20 an obvious lie? 21 A. I was standing outside talking to 22 her mother so the entire story is a 23 fabrication. 24 Q. 25 Did she not have sex with Jeffrey Epstein during that first massage? Case 18-2868, Document 283, 08/09/2019, 2628241, Page181 of 883 Page 220 1 2 G Maxwell - Confidential up to the room and start a massage? 3 A. He would not. 4 Q. So the young girls in the police 5 report who say they came over and were led up 6 to the room on the first day, would they be 7 wrong about that? 8 MR. PAGLIUCA: 9 Objection to form and foundation. 10 A. I can't comment what happened when 11 I was not at the house. 12 when I was at the house. 13 Q. I can only comment Was there ever a time where a woman 14 came to the house for the first time to give 15 a massage and Jeffrey had the massage that 16 day? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. 20 21 22 23 Can we talk about adult professional masseuses, please? Q. I'm asking, whether adult or underage? A. I'm not interested in talking about 24 underage. I can only testify to what I know, 25 professional masseuses, adult, I cannot Case 18-2868, Document 283, 08/09/2019, 2628241, Page182 of 883 Page 221 1 2 3 G Maxwell - Confidential testify to anything else. Q. Why can't you testify to an 4 underage girl that came over and was led up 5 to the room for a massage? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. 9 10 The police records you are referring to? Q. You are saying that didn't happen. 11 You're saying I can only testify to adults 12 that came for an interview and were led up to 13 the room. 14 an underage girl was brought in for an 15 interview and led up -- 16 MR. PAGLIUCA: Why can't you testify to whether Objection to the 17 form and foundation. 18 Q. Go ahead. 19 A. Can you reask the question. 20 Q. Why can't you testify as to an 21 underage girl who came over for an interview 22 and then was then led up to the room for the 23 massage? 24 25 A. question. You've mangled your entire Can you please reask that in a way Case 18-2868, Document 283, 08/09/2019, 2628241, Page183 of 883 Page 225 1 G Maxwell - Confidential 2 present at the home when a girl under the age 3 of 18 came over for the purposes of giving a 4 massage? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 Q. You can answer. 8 A. You can be a professional masseuse 9 at 17 in Florida, so as far as I am aware, a 10 professional masseuse showed up for a 11 massage. 12 incorrect about that and your 13 mischaracterization of it, I think is 14 unfortunate. 15 Q. There is nothing inappropriate or How many teenagers did he have that 16 were professional masseuses that worked in 17 his home? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 Q. How many? 21 A. First of all, I am not aware of 22 23 teenagers who worked in his home. Q. You are aware of Virginia Roberts 24 and you've stated she was 17 and she worked 25 for him, correct? Case 18-2868, Document 283, 08/09/2019, 2628241, Page184 of 883 Page 226 1 2 G Maxwell - Confidential A. No. I did not state that at all, 3 you are mischaracterizing my words and what I 4 said. 5 What I said was that we can all 6 agree and I think at this point there is not 7 one person in this room, however much you 8 would like her to be younger, to say she was 9 not 17 because that has been a very offensive 10 thing that you have all done. 11 At 17 you are allowed to be a professional 12 masseuse and as far as I'm concerned, she was 13 a professional masseuse. 14 inappropriate or incorrect about her coming 15 at that time to give a massage. 16 characterization of her first time at the 17 house was to me an obvious lie, given it was 18 impossible for her entire story to take place 19 given I was speaking to her mother the entire 20 she was at the house. 21 Q. So she was 17. There is nothing Her entire So it was impossible that day, that 22 first day she came and you were speaking to 23 the mother, for Virginia Roberts to have had 24 sex with Jeffrey Epstein during the time that 25 you were outside with her mother? Case 18-2868, Document 283, 08/09/2019, 2628241, Page185 of 883 Page 228 1 G Maxwell - Confidential 2 absolutely 1000 percent that she did not have 3 any type of sexual relations as described by 4 you in your court papers that took place 5 because those allegedly according to her lies 6 involved some aspect of me. 7 As I was standing outside with her 8 mother the entire time, her entire story is a 9 lie. Therefore, to ask me what she did or 10 didn't do during that time, I can only 11 testify to what she said about me, which was 12 1000 percent false. 13 14 15 Q. So let's not take the first time, let's take the next time she comes. A. No no, how can do you that, when 16 the basis of this entire horrible story that 17 you have put out is based on this first 18 appalling story that was written, repeated, 19 multiply by the press that lied about her 20 age, lied about the first time she came, lied 21 about and characterized the entire first 22 time. 23 her story and appalled by the entire 24 characterization of it and I apologize 25 sincerely for my banging at the table I have been so absolutely appalled by Case 18-2868, Document 283, 08/09/2019, 2628241, Page186 of 883 Page 229 1 G Maxwell - Confidential 2 earlier, I hope you accept my apology. 3 borne out of years of feeling the pressure of 4 this entire lie that she has perpetrated from 5 our first time and whilst I recognize that 6 was -- I hope you forgive me sincerely 7 because it was just the length of time that 8 that terrible story has been told and retold 9 and rehashed when I know it to be 100 percent 10 11 It's false. Q. So not the first time she came, but 12 the second time she came or the third time or 13 any time she came, did you ever participate 14 in a massage with her in Jeffrey Epstein's 15 room? 16 17 18 A. I have never participated at any time with Virginia in a massage with Jeffrey. Q. Have you ever participated at any 19 time with Virginia in any kind of sexual 20 contact or sexual touching with Jeffrey and 21 Virginia? 22 A. I have not. 23 Q. So we were going through the list 24 of obvious lies and you were talking about 25 the first time which I believe we have Case 18-2868, Document 283, 08/09/2019, 2628241, Page187 of 883 Page 248 1 2 3 4 5 G Maxwell - Confidential of 18? A. I think we can establish what adult would be. Q. You never interviewed or I know you 6 don't want to use the word hired, whatever 7 your role was, you brought in an exercise 8 instructor that was under the age of 18 to 9 work at the house? 10 MR. PAGLIUCA: 11 and foundation. 12 A. Object to the form I have already testified that what 13 I was responsible for was to find people who 14 had competencies in whatever area I was 15 looking for. 16 for were professional and adult. 17 Q. The competencies I was looking So there was no exercise instructor 18 that worked at the Palm Beach house or the 19 New York house or the New Mexico house or the 20 USVI under the age of 18? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. 24 25 I can only testify to when I was at the house. Q. Yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page188 of 883 Page 310 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. 5 That's not how I would characterize that. 6 Q. How would you characterize it? 7 A. I have testified that I'm 8 responsible for finding professional people 9 to work in the homes, age appropriate adult 10 people, so from pool attendants, to 11 gardeners, to chefs, to housekeepers, to 12 butlers, to chauffeurs and one of the 13 functions was to be able to answer the 14 telephones and in the context of finding 15 someone to answer the telephones, I did look 16 to try to find appropriate people to answer 17 the phones. 18 Q. 19 20 So did you find Johanna for purposes of that role? A. So in the course of looking for 21 somebody to answer phones at the house, 22 Johanna was one of the people who said that 23 she was willing to answer phones. 24 Q. 25 campus? Did you approach her at her school Case 18-2868, Document 283, 08/09/2019, 2628241, Page189 of 883 Page 383 1 2 G Maxwell - Confidential Q. List all of the girls you met and 3 brought to Jeffrey Epstein's home for the 4 purposes of employment that were under the 5 age of 18? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. 9 I've already characterized my job was to find people, adults, professional 10 people to do the jobs I listed before; pool 11 person, secretary, house person, chef, pilot, 12 architect. 13 Q. I'm asking about individuals under 14 the age of 18, not adult persons, people 15 under the age of 18. 16 A. I looked for people or tried to 17 find people to fill professional jobs in 18 professional situations. 19 20 21 22 23 24 25 Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual that you met for purposes of hiring someone for Case 18-2868, Document 283, 08/09/2019, 2628241, Page190 of 883 Page 390 1 G Maxwell - Confidential 2 MR. PAGLIUCA: 3 and foundation. 4 A. Object to the form If you want to ask Jeffrey 5 questions about me, you would have to ask 6 him. 7 8 Q. Have you ever been involved in any illegal activity in your lifetime? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. 12 I can't think of anything I have done that is illegal. 13 Q. Have you ever been arrested? 14 A. I have a DUI in the U.K. a long 15 time ago. 16 Q. 17 your record? 18 A. Yes. 19 Q. I will mark as Maxwell 22 this 20 Is that the only arrest you have on email? 21 (Maxwell Exhibit 22, email, marked 22 for identification.) 23 Q. This is dated January 21, 2015. 24 It's from Jeffrey Epstein to you, forwarding 25 the Guardian and I would like you to look at Case 18-2868, Document 283, 08/09/2019, 2628241, Page191 of 883 1 2 CERTIFICATE 3 4 5 I HEREBY CERTIFY that the witness, 6 GHISLAINE MAXWELL, was duly sworn by me and 7 that the deposition is a true record of the 8 testimony given by the witness. 9 10 11 Leslle Fagf%i (I Registered Professional Reporter 12 Dated: April 22, 2016 13 14 15 (The foregoing certification of 16 this transcript does not apply to any 17 reproduction of the same by any means, unless 18 under the direct control and/or supervision 19 of the certifying reporterPage 416 MAG Case 18-2868, Document 283, 08/09/2019, 2628241, Page192 of 883 Confidential Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: 15-cv-07433-RWS -againstGHISLAINE MAXWELL, Defendant. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Continued Videotaped Deposition of GHISLAINE MAXWELL, the Defendant herein, taken pursuant to subpoena, was held at the law offices of Boies, Schiller & Flexner, LLP, 575 Lexington Avenue, New York, New York, commencing July 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 Case 18-2868, Document 283, 08/09/2019, 2628241, Page193 of 883 Confidential Page 44 1 G. Maxwell - Confidential 2 thought. 3 hard for me to testify what I thought about 4 her age at the time. 5 Q. I really don't recall her, so it's Was Virginia, in the period of 6 around 2000, the youngest person that, as you 7 understood it, was giving Mr. Epstein 8 massages? 9 MR. PAGLIUCA: 10 and foundation. 11 A. Object to the form Again, I can't testify to her age, 12 but everybody else that I can recall seemed 13 to be again, like I would say, adults. 14 15 Q. You didn't think Virginia was an adult, did you? 16 MR. PAGLIUCA: 17 and foundation. 18 A. Object to the form Like I said, I don't recall her. 19 don't recall thinking about -- my memory is 20 of adults giving Jeffrey massages, and as I 21 don't really remember Virginia around that 22 time, I don't know what I think. 23 Q. You do remember Virginia, about 24 that time back in the 2000s, giving 25 Mr. Epstein massages? I Case 18-2868, Document 283, 08/09/2019, 2628241, Page194 of 883 Confidential Page 45 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. I barely remember her at all. 5 Q. Whether you barely remember her or 6 not, you do remember that back in the period 7 around 2000, Virginia was giving Mr. Epstein 8 massages, right? 9 MR. PAGLIUCA: 10 and foundation. 11 A. Objection to form Only in the most general terms. 12 would be somebody who would give him a 13 massage, and that's it. 14 Q. During the period of time back in 15 the period around 2000, when you knew that 16 Virginia was somebody who would give 17 Mr. Epstein a massage, was she somebody who 18 you considered an adult? 19 MR. PAGLIUCA: 20 and foundation. 21 A. Objection to form I didn't consider her at all 22 because she is not somebody that I really 23 interacted with. 24 25 Q. It It is your testimony that Virginia was not somebody that you interacted with, is Case 18-2868, Document 283, 08/09/2019, 2628241, Page195 of 883 Confidential Page 55 01 oo (JO G. Maxwell Confidential Epstein's home in Palm Beach? MR. PAGLIUCA: Objection to form and foundation. MAG NA9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page196 of 883 Confidential Page 56 1 G. Maxwell Confidential MAG NA9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page197 of 883 Confidential Page 57 1 G. Maxwell Confidential 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 I 8 MR. PAGLIUCA: Objection to form 9 and foundationMAG NA9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page198 of 883 Confidential Page 58 1 2 G. Maxwell - Confidential Q. 7 11 20 21 22 23 24 MR. PAGLIUCA: and foundation. Objection to form Case 18-2868, Document 283, 08/09/2019, 2628241, Page199 of 883 Confidential Page 86 1 G. Maxwell - Confidential 2 and foundation. 3 A. 4 Q. 8 9 10 No. MR. PAGLIUCA: Objection to form and foundation. A. I don't know. 11 17 MR. PAGLIUCA: Objection to form 18 and foundation. 19 A. No. 20 Q. Were they ever in the Virgin 21 Islands? 22 MR. PAGLIUCA: 23 and foundation. 24 A. 25 Asked and answered. No. Objection to form Case 18-2868, Document 283, 08/09/2019, 2628241, Page200 of 883 Confidential Page 87 1 8 17 23 24 25 MR. PAGLIUCA: and foundation. Objection to form Case 18-2868, Document 283, 08/09/2019, 2628241, Page201 of 883 Confidential Page 91 1 2 G. Maxwell - Confidential it to something in the case. 3 MR. BOIES: I think it's tied, but 4 if you instruct her not to answer, it 5 goes into the -- 6 7 8 MR. PAGLIUCA: Meat grinder. BY MR. BOIES: Q. . 14 A. 15 Q. 20 MR. PAGLIUCA: 21 A. 22 Q. 24 Can you repeat the question? No. Same objection. Case 18-2868, Document 283, 08/09/2019, 2628241, Page202 of 883 Confidential Page 197 1 2 CERTIFICATE 3 4 5 I HEREBY CERTIFY that GHISLAINE 6 MAXWELL, was duly sworn by me and that the 7 deposition is a true record of the testimony 8 given by the witness. 9 10 {37/ _?4Lg 11 LesYie Fag in, Registered Professional Reporter 12 Dated: July 22, 2016 13 14 15 (The foregoing certification of 16 this transcript does not apply to any 17 reproduction of the same by any means, unless 18 under the direct control and/or supervision 19 of the certifying reporterMAG NA9 Cam: 18-7868, 782, 08/00/7010, 7678741, Pag9702 nf 882 EXHIBIT 12 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page204 of 883 GI UFFRE VS. IMAXWELL mm YNN TR UDE MILLER 05/24/201 6 Agren Blando Court Reporting Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-001 7 Case 18-2868, Document 283, 08/09/2019, 2628241, Page205 of 883 !“ Ãÿ¤ À“!ä‹ ÕÃflÃ¤Õ ‹!ÕÃŒ!›Ã ›—ÀŒÃ Õ—ÀÃÿ¤Œ“ ‹!ÕÃŒ!›Ã —⁄ “¤… «—Œ’ ›1™1¥ fl4¨1±7 “±Ú ÔÎÛ4™Û<ÈÏÌÌÛŒ…Õ ›—“⁄!‹¤“Ã!fl‘ !‹¤—Ãfl–¤‹ ‹¤–—Õ!Ã!—“ —⁄ ‘«““ ÃŒÀ‹¤ ”!‘‘¤Œ ”øß ÓÏÙ Ó<ÔÍ !ŒŸ!“!fl ‘Ú Ÿ!À⁄⁄Œ¤Ù –¥ø17¨1JJÙ ™Ú Ÿÿ!Õ‘fl!“¤ ”fl»…¤‘‘Ù ‹ªJª7ºø7¨Ú fl––¤flŒfl“›¤ÕÊ ÕÚ÷Ú œÀ!““¤« ›—‘‘¤Ÿ¤ —⁄ ‘fl…Ù À“! ¤ŒÕ!ë —⁄ ÀÃflÿ fiß –ø´¥ ŸÚ ›øSSª¥¥Ù ¤SØÚ ÌËÌ ÕÚ À71™ªÆS1¨ß ըƪª¨ Õø¥¨ ‘øµª ›1¨ßÙ Àà ËÏÔÔÓ –X±7ªÊ Ë<ÔÚÎËÎÚÎÓ<Ó ›øSSª¥¥Y‡¥ø©Ú´¨øXÚªº´ flYYªøÆ17\ ±7 æªXø¥J ±J ¨Xª –¥ø17¨1JJ ÿÀÛÿ!“Õ—“ fi‘fl›’ fl“‹ ›——’Ù ‘‘› fiß ÷±X7 ›¥´7ªÙ ¤SØÚ ÁÓÔ …ø¥7´¨ ըƪª¨ Õ´1¨ª Ó<< fi±´¥ºªÆÙ ›— Ë<Ì<Ó –X±7ªÊ Ì<ÌÚÏÏÓÚÍÎÔÏ 4¥´7ª‡Xæ4æ±´¥ºªÆÚ4±_ flYYªøÆ17\ ±7 æªXø¥J ±J ¨Xª ‹ªY±7ª7¨ Case 18-2868, Document 283, 08/09/2019, 2628241, Page206 of 883 Ô fl––¤flŒfl“›¤ÕÊ ¯›±7¨17´ªº˜ Ó Ì Ï Î Í È Ë Á Ô< ÔÔ ÔÓ ÔÌ ÔÏ ÔÎ ÔÍ ÔÈ ÔË ÔÁ Ó< ÓÔ ÓÓ ÓÌ ÓÏ ÓÎ ÿfl‹‹—“Ù ”—ŒŸfl“ fl“‹ ⁄—Œ”fl“Ù –Ú›Ú fiß ‘ø´Æø flÚ ”ª7717\ªÆÙ ¤SØÚ ÷ªJJÆªß ÕÚ –ø\¥1´4øÙ ¤SØÚ ÔÎ< ¤øS¨ Ô<¨X fl™ª7´ª ‹ª7™ªÆÙ ›— Ë<Ó<Ì –X±7ªÊ Ì<ÌÚËÌÔÚÈÌÍÏ ¥_ª7717\ªÆ‡X_J¥ø©Ú4±_ bYø\¥1´4ø‡X_J¥ø©Ú4±_ flYYªøÆ17\ ±7 æªXø¥J ±J ¨Xª ‹ªJª7ºø7¨ fl¥S± –ƪSª7¨Ê ”øÆß™±77ª ñ_Yµ17SÙ 1ºª±\ÆøYXªÆ Case 18-2868, Document 283, 08/09/2019, 2628241, Page207 of 883 Ô fl fiª4ø´Sª ! ©øS7˘¨ ¨±¥º ø7ß º1JJªÆª7¨Ú Ó œ ‹± ß±´ µ7±© ©XªÆª ø7ß ÛÛ ø7ß S±´Æ4ª ±J Ì ¨Xø¨ 17J±Æ_ø¨1±7 4ø_ª JƱ_· Ï fl !¨ 4ø_ª JƱ_ ÕµßÚ Î œ —µøßÚ Í ß±´ øæ±´¨ ©Xª7 È ”øÆÛøÛ‘ø\±· Ë fl Á Ô< fl7º ©Xø¨ º± ß±´ ƪ4ø¥¥ X1_ ¨ª¥¥17\ 1Æ\171ø S¨±YYªº ©±Æµ17\ ø¨ ÕXª ©øS 17 ø º1S4´SS1±7 ©1¨X ”ÆSÚ ”ø®©ª¥¥ ¨± ªº´4ø¨ª XªÆ ø7º ¨øµª XªÆ ´7ºªÆ XªÆ ©17\ ø7º æª XªÆ 7ª© _±__øÚ ÃXø¨˘S ©Xø¨ ! 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GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 21, 2016 9:17 a.m. C O N F I D E N T I A L Deposition of JOSEPH RECAREY, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 18-2868, Document 283, 08/09/2019, 2628241, Page211 of 883 Page 25 1 2 3 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Q. All right. 4 Was SG a licensed massage therapist? 5 MR. PAGLIUCA: 6 foundation. 7 8 9 10 Object to form and THE WITNESS: No. BY MR. EDWARDS: Q. And at 14 years old, are you permitted to be a licensed massage therapist? 11 A. Not to my knowledge. 12 Q. After speaking with SG and understanding 13 her account of what took place at Jeffrey Epstein's 14 home, what -- what happened next in the 15 investigation? 16 A. At some point the investigation was turned 17 over to me for follow-up. 18 pulled that was done prior to -- and surveillance 19 that was done prior to the case being turned over to 20 me; and trash pulls being an investigative technique 21 to acquire intelligence, information and evidence. 22 Q. Okay. I know there was trash If we go to page 17, at the top, 23 and, first of all, I will ask you from memory, do 24 you remember if 25 Epstein in a photo lineup? identified Jeffrey Case 18-2868, Document 283, 08/09/2019, 2628241, Page212 of 883 Page 27 1 2 JOSEPH RECAREY - CONFIDENTIAL "a cross-reference"? 3 A. Uh-huh. 4 Q. How is a cross-reference performed? 5 6 What does that mean? A. When -- when something is 7 cross-referenced, they -- they jot down license 8 plate numbers. 9 the individuals; photographs, computer research. 10 11 12 Q. They conduct their background into A cross-reference of Jeffrey Epstein's residence revealed which affiliated names? A. It revealed Nadia Marcinkova, Ghislane 13 Maxwell, Mark Epstein. 14 any previous reports from the residence as well. 15 Q. Also, the cross-reference, During your investigation, did you learn 16 of any involvement that Nadia Marcinkova had with 17 any of the activities you were investigating? 18 19 MR. PAGLIUCA: foundation. 20 21 22 23 24 25 Object to form and THE WITNESS: Yes. BY MR. EDWARDS: Q. And what involvement did you learn of Nadia Marcinkova? MR. PAGLIUCA: foundation. Object to form and Case 18-2868, Document 283, 08/09/2019, 2628241, Page213 of 883 Page 28 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 4 5 6 THE WITNESS: with one of the victims at Epstein's request. BY MR. EDWARDS: Q. Okay. A. AH. 8 Q. Okay. 10 11 14 is that possible as well? A. Yes. MR. PAGLIUCA: BY MR. EDWARDS: Q. 16 mind is AH? 17 21 22 Okay. The one that you remember in your MR. PAGLIUCA: Object to form and foundation. 19 20 Object to form and foundation. 15 18 If it indicates in the report that she was also sexually involved with other victims, 12 13 Do you remember which victim you're remembering right now? 7 9 Nadia was involved sexually THE WITNESS: Correct. BY MR. EDWARDS: Q. The other name that is on here as a cross-reference is Ghislane Maxwell. 23 Did you speak with Ghislane Maxwell? 24 A. I did not. 25 Q. Did you ever attempt to speak with Case 18-2868, Document 283, 08/09/2019, 2628241, Page214 of 883 Page 29 1 2 3 JOSEPH RECAREY - CONFIDENTIAL Ghislane Maxwell? A. I wanted to speak with everyone related to 4 this home, including Ms. Maxwell. 5 through Gus, Attorney Gus Fronstin, at the time, who 6 initially had told me that he would make everyone 7 available for an interview. 8 conversations later, no one was available for 9 interview and everybody had an attorney, and I was 10 11 My contact was And subsequent not going to be able to speak with them. Q. Okay. During your investigation, what did 12 you learn in terms of Ghislane Maxwell's 13 involvement, if any? 14 15 MR. PAGLIUCA: Object to form and foundation. 16 THE WITNESS: Ms. Maxwell, during her 17 research, was found to be Epstein's long-time 18 friend. 19 involved in seeking girls to perform massages 20 and work at Epstein's home. 21 22 23 24 25 During the interviews, Ms. Maxwell was MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. Did you interview -- how many girls did you interview that were sought to give or that Case 18-2868, Document 283, 08/09/2019, 2628241, Page215 of 883 Page 30 1 2 JOSEPH RECAREY - CONFIDENTIAL actually gave massages at Epstein's home? 3 4 5 6 MR. PAGLIUCA: foundation. BY MR. EDWARDS: Q. Approximately. 7 MR. PAGLIUCA: 8 THE WITNESS: 9 10 11 Q. And of the 30, 33 or so girls, how many 13 MR. PAGLIUCA: 18 19 20 21 22 THE WITNESS: I believe two of them may have been -- two of them. BY MR. EDWARDS: Q. Okay. And as we go through this report, you may remember the names? A. Correct. Let me correct myself. I believe only one had. Q. And was that -- was that one of similar 23 age to the other girls? 24 MR. PAGLIUCA: 25 Object to form and foundation. 15 17 I would say approximately BY MR. EDWARDS: had massage experience? 16 Same objection. 30; 30, 33. 12 14 Object to form and foundation. Object to form and Case 18-2868, Document 283, 08/09/2019, 2628241, Page216 of 883 Page 40 1 2 JOSEPH RECAREY - CONFIDENTIAL foundation. 3 4 5 6 THE WITNESS: Yes, I did. BY MR. EDWARDS: Q. And were trash pulls done at the property of Jeffrey Epstein? 7 A. Yes. 8 Q. What is the purpose of a trash pull, and 9 10 what is a trash pull? A. A trash pull is when property is 11 discarded, such as trash, we coordinate with the 12 sanitation department to collect the trash, once it 13 leaves the property, and it's put into an empty well 14 of the trash truck. 15 sift through the contents of the trash. 16 Q. We acquire the bags, and we Did you or another detective from the unit 17 observe each step of the trash pull to make sure 18 that you had a good chain of custody of the 19 evidence? 20 21 MR. PAGLIUCA: foundation. 22 23 24 25 Object to form and THE WITNESS: Yes. The members of the OCTAN unit at that time did. BY MR. EDWARDS: Q. Okay. And what is that process? Case 18-2868, Document 283, 08/09/2019, 2628241, Page217 of 883 Page 41 1 2 JOSEPH RECAREY - CONFIDENTIAL A. 3 4 The process -MR. PAGLIUCA: Object to form and foundation. 5 THE WITNESS: The process is when the -- 6 once you coordinate a trash pull with the 7 sanitation supervisor, you meet with the 8 sanitation worker and ensure that either the 9 can that he's going to place in the well is 10 completely empty and you physically observe him 11 collect the trash and place it into the empty 12 container. 13 disclosed area, and we retrieve the bags and 14 you sift through the trash. 15 16 17 BY MR. EDWARDS: Q. Okay. What were you looking for in terms of evidentiary value from these trash pulls? 18 19 And then you follow him to a MR. PAGLIUCA: Object to form and foundation. 20 THE WITNESS: We were looking for any -- 21 any form of identification. 22 for -- to gather any kind of intelligence 23 and/or evidence. 24 25 You were looking BY MR. EDWARDS: Q. Okay. If we go to page 20 of the report, Case 18-2868, Document 283, 08/09/2019, 2628241, Page218 of 883 Page 42 1 JOSEPH RECAREY - CONFIDENTIAL 2 I guess I'll start with where it says on 4/4/2005, I 3 just want to ask you, was a voice mail message taken 4 into evidence from HR to SG? 5 A. Yes. 6 Q. Okay. 7 to corroborate what? 8 9 And the purpose of that evidence is MR. PAGLIUCA: Object to form and foundation. 10 THE WITNESS: It was actually a phone call 11 from HR to SG confirming an appointment to go 12 work at Epstein's residence. 13 14 15 16 BY MR. EDWARDS: Q. The next line down is what I wanted to focus on, April 5th, 2005. This trash pull, what evidence is yielded 17 from this particular trash pull? 18 MR. PAGLIUCA: 19 20 Object to form and foundation. THE WITNESS: The trash pull indicated 21 that there were several messages with written 22 items on it. 23 indicating that there would be an 11:00 24 appointment. 25 had called during that day. There was a message from HR There were other individuals that Case 18-2868, Document 283, 08/09/2019, 2628241, Page219 of 883 Page 43 1 2 3 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Q. And when you would -- when you would see 4 females' names and telephone numbers, would you take 5 those telephone numbers and match it to -- to a 6 person? 7 8 MR. PAGLIUCA: foundation. 9 10 11 12 Object to form and THE WITNESS: We would do our best to identify who that person was. BY MR. EDWARDS: Q. And is that one way in which you 13 discovered the identities of some of the other what 14 soon came to be known as victims? 15 MR. PAGLIUCA: 16 foundation. 17 18 19 Object to form and THE WITNESS: Correct. BY MR. EDWARDS: Q. Okay. There's the second paragraph from 20 the bottom, it starts, "Detective Leigh provided 21 trash from 4/06, 4/07/2005." 22 Do you see that? 23 A. Yes. 24 Q. And what is the purpose of the indication 25 that "the following information was retrieved: Jet Case 18-2868, Document 283, 08/09/2019, 2628241, Page220 of 883 Page 45 1 2 3 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Q. And then some of the remaining messages, 4 "Johanna, work Sunday at 4 p.m.; A, Monday after 5 school; left message for Courtney W and NT," are 6 these individuals that you later learned were 7 underaged girls that had been to Jeffrey Epstein's 8 home? 9 10 MR. PAGLIUCA: foundation. 11 12 13 Object to form and THE WITNESS: That's correct. BY MR. EDWARDS: Q. What types of documents do you remember 14 retrieving from the trash pulls from Jeffrey 15 Epstein's home? 16 A. There was numerous items. It was a lot of 17 handwritten notes on different -- different pads of 18 paper. 19 was Epstein, whether it was Ghislane Maxwell, 20 whether it was -- there were phone messages. 21 Some of the pads had names on it, whether it When I say "phone messages," I mean, you 22 know, the kind that come in a book. They are carbon 23 copied, so the yellow copy always stays with the 24 book, but the white copy is torn off. 25 always a carbon copy of the actual phone message. So there was Case 18-2868, Document 283, 08/09/2019, 2628241, Page221 of 883 Page 72 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 4 5 THE WITNESS: Correct. BY MR. EDWARDS: Q. And let me go back to the beginning six pages of that exhibit, No. 4. 6 MR. PAGLIUCA: Why don't we just make a 7 copy of it now if we're going to ask questions 8 about it? 9 10 I'm not trying to -- MR. EDWARDS: Yes, I know. It's just the first six pages. 11 (A discussion was held off the record, 12 after which the following proceedings were 13 held:) 14 15 16 THE VIDEOGRAPHER: On the record at 10:32. BY MR. EDWARDS: Q. And what were some of the items that were 17 found in -- well, are the documents that you're 18 holding, 1 through 6, an accurate reflection of the 19 items that were found in Jeffrey Epstein's home 20 during the search warrant execution? 21 22 MR. PAGLIUCA: foundation. 23 24 25 Object to form and THE WITNESS: Yes. BY MR. EDWARDS: Q. And I believe that you described that some Case 18-2868, Document 283, 08/09/2019, 2628241, Page222 of 883 Page 73 1 JOSEPH RECAREY - CONFIDENTIAL 2 of the -- that the house appeared to be -- I don't 3 remember the word you used -- sanitized, for lack of 4 a better word? 5 6 7 MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: 8 Q. How did you know that? 9 A. The computers had been removed from the 10 11 12 13 home. Q. How did you know the computers were removed? A. Based on -- based on the dangling wires 14 left behind, the monitors left, but the actual CPU 15 of it was missing. 16 When you went into the bedroom of Jeffrey 17 Epstein, everything was removed from the -- the 18 shelves, from the armoire. 19 Q. Did you find nude photographs of girls? 20 A. Yes. 21 Q. All right. 22 23 24 25 And what did you do with that evidence? A. That was collected and placed into our crime scene unit. Q. And where is that evidence today? Case 18-2868, Document 283, 08/09/2019, 2628241, Page223 of 883 Page 74 1 2 3 4 JOSEPH RECAREY - CONFIDENTIAL A. Any evidence that was not returned to its rightful owner was turned over to the FBI. Q. And evidence which would be nude 5 photographs of girls would be evidence not turned 6 back over to Epstein? 7 A. 8 9 Correct. MR. PAGLIUCA: Object to form and foundation. 10 THE WITNESS: Some of the items that were 11 collected were later found to be personal items 12 of the houseman, Janush. 13 his personal photographs on -- on a micro SD 14 card for, like, photos of him and his wife or 15 girlfriend at the time. 16 17 I recall reviewing BY MR. EDWARDS: Q. And the underaged girls that you had 18 spoken with during your investigation, had they 19 described seeing photographs of naked girls in the 20 house? 21 22 MR. PAGLIUCA: foundation. 23 24 25 Object to form and THE WITNESS: Yes, they did. BY MR. EDWARDS: Q. That's something that ran consistent with Case 18-2868, Document 283, 08/09/2019, 2628241, Page224 of 883 Page 78 1 2 3 4 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Q. MR. PAGLIUCA: 9 THE WITNESS: Q. of whose property is that? MR. PAGLIUCA: 16 17 Object to form and foundation. 14 15 All right. And where were those taken from, in terms 12 13 Correct. BY MR. EDWARDS: 10 11 Object to form and foundation. 7 8 Also reflected are the property receipts? 5 6 Okay. THE WITNESS: This would have been taken from the home of Jeffrey Epstein. BY MR. EDWARDS: Q. And in reviewing that evidence, were you 18 able to substantiate or corroborate certain victims' 19 accounts of their allegations of having been at the 20 house? 21 22 MR. PAGLIUCA: foundation. 23 24 25 Object to form and THE WITNESS: Correct. BY MR. EDWARDS: Q. Did you find names of other witnesses and Case 18-2868, Document 283, 08/09/2019, 2628241, Page225 of 883 Page 79 1 JOSEPH RECAREY - CONFIDENTIAL 2 people that you knew to have been associated with 3 the house in those message pads? 4 5 MR. PAGLIUCA: foundation. 6 7 8 9 10 THE WITNESS: Yes. BY MR. EDWARDS: Q. And so what was the evidentiary value to you of the message pads collected from Jeffrey Epstein's home in the search warrant? 11 12 Object to form and MR. PAGLIUCA: Object to form and foundation. 13 THE WITNESS: It was very important to 14 corroborate what the victims had already told 15 me as to calling in and for work. 16 17 BY MR. EDWARDS: Q. Okay. And did you learn the identities of 18 some of the other individuals associated with 19 Jeffrey Epstein through the review of that 20 particular evidence? 21 22 MR. PAGLIUCA: foundation. 23 24 25 Object to form and THE WITNESS: Correct. BY MR. EDWARDS: Q. Okay. And what did you do with that Case 18-2868, Document 283, 08/09/2019, 2628241, Page226 of 883 Page 83 1 2 3 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Q. In these messages, did you see messages 4 that were taken by Ghislane Maxwell or left for 5 Ghislane Maxwell? 6 7 MR. PAGLIUCA: foundation. 8 9 10 11 Object to form and THE WITNESS: I do recall seeing messages utilizing her pad, her stationery. BY MR. EDWARDS: Q. Okay. Do you remember messages 12 specifically that Ms. Maxwell, she is home, or calls 13 for Ms. Maxwell, or indicating that the person 14 taking the message is GM? 15 A. 16 17 18 19 Do you remember those? Yes. MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. And did that give you further reason to 20 want to speak to Ghislane Maxwell? 21 MR. PAGLIUCA: 22 23 Object to form and foundation. THE WITNESS: Correct. I wanted to speak 24 with everyone in the home and everyone 25 associated with Jeffrey Epstein. Case 18-2868, Document 283, 08/09/2019, 2628241, Page227 of 883 Page 97 1 JOSEPH RECAREY - CONFIDENTIAL 2 anything that's found that has any kind of 3 identifiers, any kind of names, phone numbers, 4 anything that could be used to identify further 5 victims and/or to corroborate what the information 6 we already obtained, that information would be kept. 7 Q. Okay. 8 A. Be followed up on. 9 Q. You testified earlier about certain pieces 10 of paper that had Ghislane Maxwell's name on it that 11 were obtained. 12 Are the documents that are listed, the 13 first one, two, three, four pages of Exhibit 8, some 14 of the documents that you're referring to? 15 16 MR. PAGLIUCA: foundation. 17 18 19 Object to form and THE WITNESS: That is correct. BY MR. EDWARDS: Q. And if we go through this stack of 20 documents, if you could just review them and tell me 21 if these are some of the items obtained through the 22 trash pulls at Jeffrey Epstein's home? 23 24 25 MR. PAGLIUCA: Object to form and foundation. THE WITNESS: That is correct. This is -- Case 18-2868, Document 283, 08/09/2019, 2628241, Page228 of 883 Page 98 1 JOSEPH RECAREY - CONFIDENTIAL 2 these items were collected in the trash pull. 3 4 5 BY MR. EDWARDS: Q. MR. PAGLIUCA: 10 Object to form and foundation. 8 9 And these are items that you felt had some evidentiary value? 6 7 Okay. THE WITNESS: Yes. BY MR. EDWARDS: Q. Were there other items within the trash 11 that were discarded as not having any apparent 12 evidentiary value? 13 A. Correct. There was stuff like food trash 14 we're not going to keep. 15 None of that's going to be kept. 16 17 18 Q. Okay. You know, an apple core. And when you took this stuff into evidence, how was it maintained? A. It was placed in a -- in a sealed 19 container, a sealed Ziploc, and placed into 20 evidence. 21 22 23 24 25 Q. And then was that file later transferred to the State Attorney's Office or the FBI? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: It was collected by the FBI. Case 18-2868, Document 283, 08/09/2019, 2628241, Page229 of 883 Page 366 2 3 4 C E R T I F I C A T E STATE OF FLORIDA ) : ss 5 COUNTY OF MIAMI-DADE ) 6 I, KELLI ANN WILLIS, a Registered 7 Professional, Certified Realtime Reporter and 8 Notary Public within and for The State of 9 Florida, do hereby certify: 10 That JOSEPH RECAREY, the witness whose 11 deposition is hereinbefore set forth was duly 12 sworn by me and that such Deposition is a true 13 record of the testimony given by the witness. 14 I further certify that I am not related 15 to any of the parties to this action by blood 16 or marriage, and that I am in no way interested 17 in the outcome of this matter. 18 19 IN WITNESS WHEREOF, I have hereunto set my hand this 24th day of June, 2016. 20 21 __________________________ KELLI ANN WILLIS, RPR, CRR 22 23 24 25 Cam: 18-7868, 782, 08/00/7010, 7678741, Pag9720 nf 882 EXHIBIT 14 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page231 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: 15-cv-07433-RWS -againstGHISLAINE MAXWELL, Defendant. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Videotaped deposition of RINALDO RIZZO, taken pursuant to subpoena, was held at the law offices of Boies Schiller & Flexner, 333 Main Street, Armonk, New York, commencing June 10, 2016, 10:06 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 Case 18-2868, Document 283, 08/09/2019, 2628241, Page232 of 883 Page 25 1 R. Rizzo - Confidential 2 even Nadia. 3 out of the ordinary, was Nadia was wearing a 4 swimsuit that was very revealing and 5 basically, her bottom basically went up her 6 butt, revealing all of her buttocks. 7 again, in the context not very appropriate 8 for the situation. 9 Q. And what I found very repulsive, So Could you tell the relationship of 10 age between the three girls that you have 11 described and Nadia, for instance? 12 MR. PAGLIUCA: 13 and foundation. 14 A. 15 16 Object to the form Nadia seemed to be a bit older, I would say. Q. How does this end, or is there, 17 what do you do next? 18 that you've just described break up? 19 A. How does this meeting I asked to excuse myself and asked 20 where the bathroom was, so I'm pointed inside 21 the house, to go inside the house to the 22 bathroom. 23 I walk in there, and I walk, as I'm 24 walking to the bathroom, what caught my eye, 25 and I had to take a double lock, there were Case 18-2868, Document 283, 08/09/2019, 2628241, Page233 of 883 Page 26 1 R. Rizzo - Confidential 2 pictures of naked women, half-dressed girls. 3 So I went to the bathroom, again, from 4 someone, myself working in private service, I 5 always know in houses there are cameras, so 6 again, I was very reluctant to stare, because 7 you never know when you are on camera. 8 So I used the bathroom, and I came 9 out, and you know, curiosity got the best of 10 me, and I leaned over and started looking at 11 these pictures for a brief minute, and it was 12 just so coincidental that as I did that, Ms. 13 Maxwell enters, and she immediately says to 14 me that Jeffrey would like for me to rejoin 15 the party immediately. 16 17 Q. How many pictures of nude females did you see in Jeffrey Epstein's home? 18 MR. PAGLIUCA: Object to the form 19 and foundation. 20 A. I can't recall the exact number. 21 Q. Can you describe the pictures that 22 you saw in terms of what the people, what the 23 people or person within the picture was 24 wearing, what the age range would be of the 25 person that's in the photograph, any poses, Case 18-2868, Document 283, 08/09/2019, 2628241, Page234 of 883 Page 52 1 R. Rizzo - Confidential 2 Q. Did you learn whether your 3 perception was correct? 4 MR. PAGLIUCA: Same objection. 5 A. It was younger. 6 Q. How old was this girl? 7 A. 15 years old. 8 Q. What happens next when Ghislaine 9 10 Yes, I did. Maxwell and Jeffrey Epstein and a 15-year-old girl walk into Eva Anderson's home? 11 MR. PAGLIUCA: 12 Foundation. 13 A. Object to the form. They proceed into the dining room 14 area, which is across from the living room 15 area. 16 conversation start. 17 not hear any particulars about the 18 conversation whatsoever. I go into the kitchen and I hear a 19 Very muffled, I could My wife and I are in the kitchen 20 preparing the evening meal. 21 young girl into the kitchen. 22 there is an island with three barstools. 23 instructs the young girl to sit to the 24 furthest barstool on the right. 25 Q. Eva brings the In the kitchen, Describe for me what the girl Eva Case 18-2868, Document 283, 08/09/2019, 2628241, Page235 of 883 Page 53 1 R. Rizzo - Confidential 2 looked like, including her demeanor and 3 anything else you remember about her when she 4 walks into the kitchen. 5 A. Very attractive, beautiful young 6 girl. Makeup, very put together, casual 7 dress. 8 distraught, and she was shaking, and as she 9 sat down, she sat down and sat in the stool But she seemed to be upset, maybe 10 exactly the way the girls that I mentioned to 11 you sat at Jeffrey's house, with no 12 expression and with their head down. 13 could tell that she was very nervous. 14 15 16 17 Q. But we What do you mean by distraught and shaking, what do you mean by that? A. Shaking, I mean literally quivering. 18 Q. What happens next? 19 A. We were, again, the absurdity, 20 never introduced. Like you would walk into a 21 room and say this is -- so my wife and I are 22 in the kitchen and this young girl is sitting 23 there. 24 I look at my wife. 25 moment, and so I introduced myself and I It was a very uncomfortable moment. And so I want to ease the Case 18-2868, Document 283, 08/09/2019, 2628241, Page236 of 883 Page 54 1 R. Rizzo - Confidential 2 introduced my wife, and she doesn't really 3 respond. 4 And I asked her, are you okay? And 5 she doesn't really respond. Nothing verbal, 6 no cues, her head is still down. 7 if she would like some water, tissue, 8 anything, and she basically doesn't respond. I ask her 9 Q. You ask her for a tissue? 10 A. If she would like a tissue or some 11 water at the time. 12 Q. Was she crying at the time? 13 A. My perception, she was on the verge 14 of crying. 15 situation every way I know how, so the only 16 way I knew how, and I thought maybe this will 17 comfort her, I said oh, by the way, do you 18 work for Jeffrey. 19 And I'm trying to loosen the And she says that, I guess kind of 20 made her feel comfortable, because maybe it 21 was that comment or my persistence, and she 22 said yes. 23 she says I'm Jeffrey's executive assistant, 24 personal assistant. 25 her, just didn't seem to suit. So I said, what do you do? And Which, from looking at Case 18-2868, Document 283, 08/09/2019, 2628241, Page237 of 883 Page 55 1 R. Rizzo - Confidential 2 And I blurted out: 3 executive personal assistant? 4 do? 5 executive personal assistant. 6 appointments. You're his What do you And she says I was hired as his 7 I schedule his And I'm shocked, and I blurt out: 8 You seem quite young, how did you get a job? 9 How old are you? 10 blank: And she says to me, point I'm 15 years old. 11 And I said to her: 12 old and you have a position like that? 13 that point she just breaks down hysterically, 14 so I feel like I just said something wrong, 15 and she will not stop crying. 16 were at a loss for words, and I keep on 17 trying to console her, and nothing I was 18 saying, are you all right, do you need a 19 tissue, do you need water, consoles her. 20 You're 15 years At My wife and I And then in a state of shock, she 21 just lets it rip, and what she told me was 22 just unbelievable. 23 24 25 Q. What did she say? MR. PAGLIUCA: and foundation. Object to the form Case 18-2868, Document 283, 08/09/2019, 2628241, Page238 of 883 Page 56 1 R. Rizzo - Confidential 2 A. She proceeds to tell my wife and I 3 that, and this is not -- this is blurting 4 out, not a conversation like I'm having a 5 casual conversation. 6 an island, I was on the island and there was 7 Ghislaine, there was Sarah, she said they 8 asked me for sex, I said no. 9 That quickly, I was on And she is just rambling, and I'm 10 like what, and she said -- I asked her, I 11 said what? 12 island, I don't know how I got from the 13 island to here. 14 afternoon I was on the island and now I'm 15 here. 16 not making any sense to me, and I said this 17 is nuts, do you have a passport, do you have 18 a phone? 19 And she says yes, I was on the Last afternoon or in the And I said do you have a -- this is And she says no, and she says 20 Ghislaine took my passport. And I said what, 21 and she says Sarah took her passport and her 22 phone and gave it to Ghislaine Maxwell, and 23 at that point she said that she was 24 threatened. 25 yes, I was threatened by Ghislaine not to And I said threatened, she says Case 18-2868, Document 283, 08/09/2019, 2628241, Page239 of 883 Page 57 1 2 R. Rizzo - Confidential discuss this. 3 And I'm just shocked. So the 4 conversation, and she is just rambling on and 5 on, again, like I said, how she got here, she 6 doesn't know how she got here. 7 asked her, did you contact your parents and 8 she says no. 9 Again, I At that point, she says I'm not 10 supposed to talk about this. I said, but I 11 said: I don't 12 understand. How did you get here. We were totally lost for words. 13 And she said that before she got 14 there, she was threatened again by Jeffrey 15 and Ghislaine not to talk about what I had 16 mentioned earlier, about -- again, the word 17 she used was sex. 18 Q. And during this time that you're 19 saying she is rambling, is her demeanor 20 continues to be what you described it? 21 A. Yes. 22 Q. Was she in fear? 23 A. Yes. 24 25 MR. PAGLIUCA: and foundation. Object to the form Case 18-2868, Document 283, 08/09/2019, 2628241, Page240 of 883 Page 58 1 R. Rizzo - Confidential 2 Q. You could tell? 3 A. Yes. 4 MR. PAGLIUCA: Same objection. 5 A. She was shaking uncontrollably. 6 Q. What happens with this 15-year-old 7 girl next? 8 9 10 MR. PAGLIUCA: Object to the form and foundation. A. As she is trying to explain, and 11 I'm asking questions because I'm as feared as 12 she is at this point. 13 approach and she just shuts up. We hear people 14 Q. What happens next? 15 A. Eva comes in and tells her that she 16 will be working for Eva in the city. 17 Q. As what? 18 A. As a nanny. 19 Q. Did you see this girl again? 20 A. Yes. 21 Q. And when? 22 A. On a flight maybe a month or so to 23 Sweden. 24 Q. What was the purpose of the flight? 25 A. We were going to Sweden for the Case 18-2868, Document 283, 08/09/2019, 2628241, Page241 of 883 Page 59 1 R. Rizzo - Confidential 2 summer. 3 Q. Who was on the flight? 4 A. The Dubin family. 5 Q. As well as this girl? 6 A. Yes. 7 Q. What happens? 8 A. One thing that I forgot to mention 9 is during our initial conversation, I asked 10 her what her name was 11 was she said her name 12 Q. What happened with ? 13 A. We flew to Sweden, we stopped at an 14 airport that we didn't usually stop at and 15 she got off the plane. 16 Q. Just so that I make sure I 17 understand, who it was that she says asked 18 her for sex on the island, who was that? 19 MR. PAGLIUCA: 20 Foundation. 21 A. Object to the form. She didn't specify who asked for 22 sex. 23 Immediately after that she put Ghislaine and 24 Sarah into the conversation. 25 She said that they asked for sex. Q. Taking her passport? Case 18-2868, Document 283, 08/09/2019, 2628241, Page242 of 883 Page 60 1 R. Rizzo - Confidential 2 A. Yes. 3 Q. From -- are there any other 4 incidents or occurrences that you observed 5 personally with Jeffrey Epstein and Ghislaine 6 Maxwell? 7 MR. PAGLIUCA: Object to the form 8 and foundation. 9 A. Not that I can recall. 10 Q. This last event that you described, 11 what's the timeframe when that occurred? 12 A. Late 2004, 2005. 13 Q. When did you resign your employment 14 from the Dubin family? 15 A. I think roughly October. 16 Q. Of what year? 17 A. 2005. 18 Q. Why? 19 A. My wife and I had discussed these 20 incidents, and this last one was just, we 21 couldn't deal with it. 22 23 24 25 Q. When you left your employment with the Dubin family, did you have a job? A. When we finally left, I stayed on three months after my resignation, I had a Case 18-2868, Document 283, 08/09/2019, 2628241, Page243 of 883 Page 141 1 2 CERTIFICATE 3 4 5 I HEREBY CERTIFY that RINALDO 6 RIZZO, was duly sworn by me and that the 7 deposition is a true record of the testimony 8 given by the witness. 9 10 _______________________________ 11 Leslie Fagin, Registered Professional Reporter 12 Dated: June 10, 2016 13 14 15 (The foregoing certification of 16 this transcript does not apply to any 17 reproduction of the same by any means, unless 18 under the direct control and/or supervision 19 of the certifying reporter.) 20 21 22 23 24 25 Cam: 18-7868, 782, 08/00/7010, 7678741, nf 882 EXHIBIT 15 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page245 of 883 Confidential Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 3, 2016 9:07 a.m. C O N F I D E N T I A L Deposition of DAVID RODGERS, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 18-2868, Document 283, 08/09/2019, 2628241, Page246 of 883 Confidential Page 18 1 DAVID RODGERS 2 flyer person, then you would reduce it to an 3 initial? 4 5 MR. PAGLIUCA: foundation. 6 7 MR. REINHART: 10 11 12 You can answer the question. 8 9 Object to form and You can answer the question, if you can answer the question. You are allowed to answer the question, if you understand the question. BY MR. EDWARDS: Q. 13 I'm trying to understand your testimony. Is it, if you came to know that person -- 14 A. Uh-huh. 15 Q. -- as a frequent flyer passenger, you 16 would begin to reduce that person's name to an 17 initial at some point? 18 MR. PAGLIUCA: 19 THE WITNESS: Same objection. Well, we don't really have a 20 frequent flyer program that we do, so to speak. 21 A lot of times I would do it because if you 22 would write out everybody's name there is not 23 enough space, you know, to get everybody's name 24 in that little square there. 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page247 of 883 Confidential Page 34 1 2 DAVID RODGERS Q. 3 -- is that right? And is that -- is Ghislaine Maxwell 4 somebody that through the years 1995 through 2013 5 was somebody who flew very frequently? 6 A. What were the years again? 7 Q. The years of this book, 1995 -- 8 A. I wouldn't say through 2013. 9 10 '95 through 2000 sometime. But, yes, Probably, I would have to go back and -- well, you can see in there. 11 Q. We will get to it. 12 A. There will be a point where you don't see 13 her much. 14 be accurate. 15 Q. 16 But to say it went through 2013 would not Let's do it this way: The person that you have reflected on numerous notations -- 17 A. Yes. 18 Q. -- through here as GM -- 19 A. Yes. 20 Q. -- just by the initials, are we able to 21 22 23 24 25 safely know that that is Ghislaine Maxwell? A. Yes. MR. PAGLIUCA: Object to form and foundation. MR. EDWARDS: Court reporter, did you get Case 18-2868, Document 283, 08/09/2019, 2628241, Page248 of 883 Confidential Page 35 1 2 DAVID RODGERS the answer? 3 4 5 6 7 THE REPORTER: Yes. The answer came before the objection. BY MR. EDWARDS: Q. So on the next flight, the next day, from Palm Beach to SAF. Is SAF Santa Fe? 8 A. Yes. 9 Q. And it indicates JE and GM. 10 Are we able to then know that those 11 passengers on that flight were Jeffrey Epstein and 12 Ghislaine Maxwell? 13 A. 14 15 16 17 18 Yes. MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. And where would you land at SAF? Is that an airport? 19 A. It is an airport. 20 Q. Is it a private airport? 21 A. No. 22 Q. Did Jeffrey Epstein also have a landing 23 It's -- airlines go in there. strip at his property in New Mexico? 24 A. He did at one time. 25 Q. What would that -- do you remember what Case 18-2868, Document 283, 08/09/2019, 2628241, Page249 of 883 Confidential Page 36 1 2 DAVID RODGERS that code would be? 3 A. I don't believe there was a code. 4 Q. All right. 5 Were there times that you landed either the Gulfstream or the Boeing -- 6 A. No. 7 Q. No. 8 MR. REINHART: 9 before you answer. 10 11 12 THE WITNESS: Let him finish the question Oh, I'm sorry. BY MR. EDWARDS: Q. Sure. We are doing fine so far. But the 13 court reporter is taking down all of our questions 14 and all of our answers. We are communicating well. 15 A. Okay. 16 Q. But when I go to read this back, we may 17 not get that. 18 A. Okay. Go ahead. 19 Q. So were there times where you landed one 20 of Jeffrey Epstein's planes on his private landing 21 strip at the New Mexico property? 22 A. Yes. But not the Gulfstream and not the 23 Boeing. 24 Q. What plane did you land on his property? 25 A. The Cessna 421. And probably a Case 18-2868, Document 283, 08/09/2019, 2628241, Page250 of 883 Confidential Page 96 1 DAVID RODGERS 2 3 9:00, so it is 20 to 11:00 here. BY MR. EDWARDS: 4 5 Q. So I want to go to page 41, and down to December 9th. Sorry. December 11. 6 A. Okay. 7 Q. Palm Beach to Teterboro. 8 A. Yeah. 9 Q. And who are the passengers? 10 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 11 Tayler, Virginia. 12 13 Q. And this appears to be the first time that Virginia's name appears in the log? 14 A. Right. 15 Q. Is there a -- is there a reason why the 16 first time -- I notice that the first time on some 17 of the other passengers, you use a first and last 18 name. 19 first and last name? Is there any reason why you didn't use her 20 A. I probably didn't know her last name. 21 Q. Just didn't catch it. 22 A. Yes. 23 Q. Okay. 24 25 It was not that somebody told you not to use the last name? A. No. No. Case 18-2868, Document 283, 08/09/2019, 2628241, Page251 of 883 Confidential Page 97 1 2 3 DAVID RODGERS Q. Teterboro. 4 5 So that flight goes from Palm Beach to Can you remember whether that's the first time that you flew on a plane with Virginia Roberts? 6 MR. PAGLIUCA: 7 THE WITNESS: 8 MR. PAGLIUCA: 9 10 Object to -I believe it is. Object to form and foundation. BY MR. EDWARDS: 11 Q. Do you remember the flight? 12 A. No. 13 Q. The next flight three days later goes from 14 Teterboro to Virgin Islands with Jeffrey Epstein, 15 Ghislaine Maxwell, Adam Perry Lang, and Virginia; is 16 that right? 17 A. Yes. 18 Q. And below that, it says, "Reposition." 19 20 What does that mean? A. We were taking the airplane with no 21 passengers to go into maintenance, or an OPS2 22 inspection. 23 24 25 Q. Okay. This is -- this is the same Gulfstream, is that right? A. Yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page252 of 883 Confidential Page 98 1 DAVID RODGERS 2 3 Q. How many passengers would that Gulfstream allow? 4 A. Twelve passengers, I believe. 5 Q. And do you know how Jeffrey Epstein, 6 Ghislaine Maxwell, Adam Perry Lang, and Virginia get 7 off of St. Thomas or leave the island? 8 9 A. No. I do not. Probably a charter, I'm guessing. 10 Q. If -- who would fly the -- well, is there 11 any other plane that Jeffrey Epstein was able to 12 access back then that was a private plane? 13 MR. PAGLIUCA: 14 THE WITNESS: 15 16 No. At that point in time we don't have the Boeing yet. BY MR. EDWARDS: 17 18 Object to foundation. Q. So how many airplanes did Jeffrey Epstein back then? 19 A. Well, we -- I don't know if we had the 421 20 then. We may or may not have. But it wouldn't -- 21 you know, you wouldn't be flying the 421 down to 22 St. Thomas with Jeffrey. 23 flight. 24 Q. The Cessna? 25 A. The Cessna 421, correct. It is too long of a Case 18-2868, Document 283, 08/09/2019, 2628241, Page253 of 883 Confidential Page 99 1 DAVID RODGERS 2 Q. Okay. 3 A. But I'm not even sure we still had it at 4 this point in time. 5 6 Q. A. 8 10 11 It shows up on the next page. We will get there. 7 9 Yeah. Does it? Okay. So then, yes, the answer is, yeah, we still had the airplane. But we wouldn't have used that. Q. So is there any way of telling how Jeffrey 12 Epstein, Ghislaine Maxwell, Adam Perry Lang, and 13 Virginia were in the Virgin Islands on that, from 14 December 14th, 2000 -- 15 16 17 18 MR. PAGLIUCA: Object to foundation. BY MR. EDWARDS: Q. -- based on your knowledge or your logs or anything else? 19 A. No, I wouldn't have any way of knowing. 20 Q. Okay. 21 A. Because the next flight that they are on 22 was like this Palm Beach one, January 16th. 23 wouldn't have any idea. 24 25 Q. Okay. So I To your knowledge, did Jeffrey Epstein ever fly commercially? Case 18-2868, Document 283, 08/09/2019, 2628241, Page254 of 883 Confidential Page 100 1 DAVID RODGERS 2 A. He probably has. Back then at this time, 3 I'm going to say probably not. 4 has flown commercially. 5 like going to Europe, maybe. 6 Q. Okay. But I know that he But usually that would be January 16th through the 25th, 7 those flights, do you see that block that I'm 8 talking about? 9 A. Yes. 10 Q. Jeffrey Epstein, Ghislaine Maxwell, Emmy 11 Tayler, and then at times Shelly Lewis, do you see 12 that? 13 A. Yes, right. 14 Q. The 25th it lands in Teterboro. And the 15 next day, on the 26th, leaves out of Teterboro with 16 Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and 17 Virginia Roberts. 18 name. This time you wrote the whole 19 A. Right. Right. 20 Q. So when you write the full name, does that 21 signify -- that's when you may have learned her last 22 name? 23 A. Correct. 24 Q. And do you know how she -- how she got up 25 to New Jersey or New York? Case 18-2868, Document 283, 08/09/2019, 2628241, Page255 of 883 Confidential Page 101 1 DAVID RODGERS 2 A. I do not. I would guess the airlines. 3 Q. At this point in time, did you know what 4 her -- what her relationship was with Jeffrey 5 Epstein or Ghislaine Maxwell? 6 MR. PAGLIUCA: 7 THE WITNESS: 8 9 Q. Did you -- was she a masseuse? MR. PAGLIUCA: 11 THE WITNESS: 13 14 15 No. BY MR. EDWARDS: 10 12 Object to form. Object to foundation. I -- I'm not sure what she was. BY MR. EDWARDS: Q. Did you form any -- any belief that she was a friend or a business associate or anything? 16 MR. PAGLIUCA: 17 THE WITNESS: Object to foundation. Well, I mean, we had a lot 18 of people on the airplane. 19 just another one of those passengers. 20 21 22 And Virginia was BY MR. EDWARDS: Q. Beach. Okay. So on the 26th, flies to Palm And then -- and then I guess the 27th -- 23 A. Right. 24 Q. -- leaves from Palm Beach to the Virgin 25 Islands -- Case 18-2868, Document 283, 08/09/2019, 2628241, Page256 of 883 Confidential Page 102 1 DAVID RODGERS 2 A. Yes. 3 Q. -- with Jeffrey Epstein, Ghislaine 4 Maxwell, Emmy Tayler, and Virginia Roberts, right? 5 A. Yes. 6 Q. And on the 30th, you fly it back. 7 That's still the Gulfstream, right? 8 A. Yes. 9 Q. From the Virgin Islands to Palm Beach with 10 the same four passengers, correct? 11 A. Yes. 12 Q. And that's Jeffrey Epstein, Ghislaine 13 Maxwell, Emmy Tayler, and Virginia Roberts? 14 A. Correct. 15 Q. And then what happens to that plane, the 16 Gulfstream, for the next month, from February 1st 17 through March 5th? 18 A. Well, I don't know what happened to it, 19 but I'm -- from, looks like February 17th, I'm going 20 to school to get a type rating on the Boeing. 21 I'm gone for about three weeks. 22 23 Q. And So this is when you're doing a simulator on the Boeing? 24 A. Correct. 25 Q. And getting your certification to fly the Case 18-2868, Document 283, 08/09/2019, 2628241, Page257 of 883 Confidential Page 103 1 DAVID RODGERS 2 Boeing? 3 A. Yes. 4 Q. The Boeing, was that previously owned by 5 6 7 The Limited or Les Wexner? A. I'm not sure of the company name, officially. But probably, yes. 8 Q. Some association with him? 9 A. Some association, yes. 10 Q. Do you know who flew the Gulfstream while 11 12 13 14 15 you were doing the simulator? A. Well, it would have been Larry Visoski, I'm not sure who the first officer was. Q. Do you know if any logs were kept of the passengers' names? 16 A. While I was at school? 17 Q. Right, while you were at school. 18 A. There probably were logs, but I don't know 19 20 21 where they are. Q. Have you ever spoken with Larry about whether he kept names of passengers? 22 A. I don't think he does. 23 Q. Do you know where Larry Visoski flew the 24 25 Gulfstream for the month that you were -A. No. Case 18-2868, Document 283, 08/09/2019, 2628241, Page258 of 883 Confidential Page 104 1 2 3 DAVID RODGERS Q. Just let me finish my question. -- but for the month that you were training on the Boeing? 6 A. No. 7 Q. All right. So the last flight that you 8 took in the Gulfstream before you began, before you 9 flew the Cessna for a day, I guess, right, from 10 I know I was getting it out slow. 4 5 Sorry. Santa Fe to DFW -- 11 A. Right. 12 Q. -- February 3rd -- 13 A. Yes. 14 Q. And that's the Cessna with 908GM tail 15 number? 16 A. Yes. 17 Q. The last flight that you flew on the 18 Gulfstream was the flight back from St. Thomas with 19 Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and 20 Virginia Roberts, right? 21 A. Uh-huh. 22 Q. And then the next time that you're on the 23 plane is -- on the Gulfstream is when? 24 A. It looks like March the 5th. 25 Q. And who are the passengers on that flight? Case 18-2868, Document 283, 08/09/2019, 2628241, Page259 of 883 Confidential Page 105 1 2 3 4 5 6 DAVID RODGERS Where is it going to? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia Roberts. Q. And then there's notation of Gary Roxborough? 7 A. Yes. 8 Q. Do you know why that is? 9 A. Yeah. 10 Q. Why did he become the first officer? 11 A. Because Larry was probably in training for 12 He was the first officer. the Boeing. 13 Q. Okay. You took -- you alternated? 14 A. Right. 15 Q. All right. We didn't go at the same time. Then the Gulfstream has the 16 same aircraft make and model. 17 Gulfstream airplane, right? That's the same 18 A. Yes. 19 Q. But the aircraft identification mark 20 changes -- 21 A. Correct. 22 Q. -- on March 5th, 2001. 23 A. Correct. 24 Q. And it changes to N -- it changes from 25 N908JE to N909JE. Case 18-2868, Document 283, 08/09/2019, 2628241, Page260 of 883 Confidential Page 106 1 DAVID RODGERS 2 A. Yes. 3 Q. Why was that? 4 A. Because the N908JE went to the Boeing. 5 6 7 That was going to be on the Boeing now. Q. And the new number for N909JE was transferred to the Gulfstream? 8 A. Correct. 9 Q. And where does that first flight on the 10 5th go? 11 A. 12 13 14 15 16 17 From Palm Beach to Stephenville up in Newfoundland for a fuel stop. Q. Okay. And then how do you know it is a fuel stop? A. Because we are going to Paris, and so we have to stop there for fuel. Q. Okay. I know how -- I know how you would 18 know that. But is there any indication on any of 19 the numbers that go off to the right that would tell 20 me that it's a fuel stop as opposed to -- 21 A. No. 22 Q. No? Okay. All right. So there's no way 23 after today's deposition I can look at any of the 24 numbers; it's not going to tell me what it was for? 25 A. No. No. And it's -- obviously it looks Case 18-2868, Document 283, 08/09/2019, 2628241, Page261 of 883 Confidential Page 107 1 DAVID RODGERS 2 different, because one day is the 5th; one day is 3 the 6th. 4 night. 5 the next day. 6 Q. 7 A. Q. Got it. We went from Stephenville to And who were the passengers going to Paris? 12 13 Okay. Paris-Le Bourget. 10 11 And then when we took off, it was, you know, And then where do you go the next day? 8 9 But we landed there like at 11:50 at A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts. 14 Q. And then what's the next flight? 15 A. On the 8th, from Paris to -- I believe 16 that is in Spain. 17 Q. Granada, Spain? 18 A. Granada, Spain. 19 Q. Okay. A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 20 21 Correct. And who are the passengers on that trip? 22 Tayler, Virginia Roberts, Alberto and Linda Pinto, 23 one female, and Ricardo, it looks like Orieta. 24 Q. And then what's the next flight? 25 A. From there to Tangiers. From Granada to Case 18-2868, Document 283, 08/09/2019, 2628241, Page262 of 883 Confidential Page 108 1 2 DAVID RODGERS Tangiers. 3 4 Q. When you landed -- sorry to go back -- when you landed in -- what did we say LEGR was? 5 A. Granada, Spain. 6 Q. Where did -- where did you stay? 7 you stay on those trips? 8 9 Where do A. We didn't stay. We left the same day, I believe. 10 Q. Okay. 12 A. Uh-huh. 13 Q. That's Paris? 14 A. Yeah. 15 Q. And do -- 16 A. We stayed there. 17 Q. Do you know -- do you stay at the same 11 What if we go back to one flight to LFPB? LFPB. We stayed in Paris. 18 location where Jeffrey Epstein, Ghislaine Maxwell, 19 Emmy Tayler, and Virginia Roberts stay? 20 A. No. 21 Q. Where do you stay while you are in Paris? 22 A. Hotel. 23 Q. Where do they say? 24 MR. PAGLIUCA: 25 THE WITNESS: Object to foundation. He has a place there, in Case 18-2868, Document 283, 08/09/2019, 2628241, Page263 of 883 Confidential Page 109 1 2 3 4 5 DAVID RODGERS Paris. BY MR. EDWARDS: Q. Okay. Jeffrey Epstein has a home or a house in Paris? 6 A. Right. 7 Q. Okay. 8 A. Yes, I believe I have. 9 Q. Have you ever stayed there? 10 A. No. 11 Q. And getting to and from the airport, were Have you been to it? 12 you ever in the car riding to or from the airport in 13 Paris with Jeffrey Epstein? 14 A. No. 15 Q. So going down to the 9th, then, where is 16 that flight? 17 A. 18 19 20 21 That is from Tangiers to London Luton Airport. Q. And is Luton Airport, is that a major airport? A. For general aviation it is. There is 22 airline service in there, but it is not a huge one, 23 for sure. 24 Q. Who were the passengers? 25 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Case 18-2868, Document 283, 08/09/2019, 2628241, Page264 of 883 Confidential Page 110 1 2 DAVID RODGERS Tayler, and Virginia Roberts. 3 4 Q. And am I reading this correctly that the next flight is two days later, on the 11th? 5 A. Yes. 6 Q. And where does the flight on the 11th go? 7 A. From Luton to Bangor, Maine. 8 Q. All right. 9 10 While in London, do you know what Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts did? 11 A. No, I do not. 12 Q. Do you know who they saw? 13 A. No, I do not. 14 Q. After the flight to Maine, where is the 15 next flight? 16 A. Maine is from Bangor to Teterboro the same 18 Q. Okay. 19 A. So that was a fuel stop. 17 20 day. MR. EDWARDS: 21 time to stop. 22 tapes. All right. We are at a good The videographer has to change 23 THE WITNESS: Okay. 24 MR. EDWARDS: So we why don't we take a 25 five-minute break. Case 18-2868, Document 283, 08/09/2019, 2628241, Page265 of 883 Confidential Page 111 1 DAVID RODGERS 2 THE WITNESS: 3 THE VIDEOGRAPHER: 4 (Thereupon, a recess was taken, after which the following proceedings were held:) 7 THE VIDEOGRAPHER: 8 of Disk 2. 9 BY MR. EDWARDS: 10 11 Q. Sure. This is the beginning On the record at 11:12. If we go back to page 41, December 7th, 2000. 12 13 Off the record at 10:57. 5 6 Okay. MR. PAGLIUCA: Give us a Bates page, please. 14 MR. EDWARDS: Right, 41. For the 15 remainder, when I say "page," I'm really just 16 referring to the Bates number. 17 BY MR. EDWARDS: 18 Q. So page 41, December 7th, 2000. 19 A. Okay. 20 Q. Do you see that? 21 22 23 24 25 Where was that flight going from and to? A. Luton to -- Luton -- that's going into Marham Air Force Base. Q. Do you remember why you would have flown into the Air Force base? Case 18-2868, Document 283, 08/09/2019, 2628241, Page266 of 883 Confidential Page 112 1 DAVID RODGERS 2 A. We flew in there to drop the passengers 3 off. And then these passengers that were on there, 4 we dropped them off. 5 repositioned. 6 7 And then -- let's see. I don't remember. We We dropped passengers off, and we had to leave, I believe. 8 Q. Okay. 9 A. We weren't allowed to stay there. 10 Q. That was Tom Pritzker? 11 A. Yes. 12 Q. And then did you also drop off Jeffrey 13 That was -- Epstein, Ghislaine Maxwell, Kelly Spamm? 14 A. Yes. 15 Q. Okay. 16 A. I believe everyone got off the airplane 17 there. 18 Q. And where did you reposition to? 19 A. It says, "Positioned in Norwich, England." 20 21 22 23 24 25 I guess it's Norwich. Q. Sandringham, that is what it says right above that. A. What is that? Sandringham. I believe Sandringham is the estate that the queen has -Q. Okay. Case 18-2868, Document 283, 08/09/2019, 2628241, Page267 of 883 Confidential Page 113 1 DAVID RODGERS 2 A. -- near there. 3 Q. All right. 4 And the flight on December 9th -- 5 A. Uh-huh. 6 Q. That's Jeffrey Epstein, Ghislaine Maxwell, 7 Emmy Tayler, Kelly Spamm? 8 A. Right. 9 Q. And then what did you write in the 10 11 12 13 14 parenthesis under that? A. "Blowing snow on runway." It was a great weird phenomenon that happened that night. Q. And then you're leaving out of that Sandringham Airport; is that right? 15 A. We are -- which one are you on? 16 Q. On the 9th. 17 A. On the 9th -- 18 Q. The first entry on the 9th. 19 A. The 9th, we're leaving, looks like 20 Norwich, England, I believe, EGSH, and we go to 21 Gander, Newfoundland -- 22 Q. Okay? 23 A. -- for a fuel stop. 24 Q. I think before we took a break that we 25 were on page 43. Case 18-2868, Document 283, 08/09/2019, 2628241, Page268 of 883 Confidential Page 114 1 DAVID RODGERS 2 A. Uh-huh. 3 Q. And the flight that began in Palm Beach, 4 before going to Paris and Belgium, Tangier, I think 5 you told me, it ended up in Maine -- 6 A. Correct. 7 Q. -- on March 11th, 2001. 8 A. Right. 9 Q. Or, sorry, it ended up in Teterboro. 10 A. Teterboro. 11 Q. Okay. And then on the 15th, you fly 12 from -- on the Gulfstream out of Teterboro to ISP. 13 Do you know where that is? 14 A. Islip, New York. 15 Q. Okay. And Virginia Roberts was on the 16 flight that landed in Teterboro on the 11th, 17 correct? 18 19 MR. PAGLIUCA: foundation. 20 21 22 23 Object to form and THE WITNESS: Yes. BY MR. EDWARDS: Q. But leaving out of Teterboro, she's not one of the passengers on the flight. 24 A. No. 25 Q. Any idea where she went? Case 18-2868, Document 283, 08/09/2019, 2628241, Page269 of 883 Confidential Page 115 1 DAVID RODGERS 2 A. No. 3 Q. Okay. 4 MR. PAGLIUCA: Are you referring to 5 Bates 0041, the 11th through 14th? 6 what you're talking about? 7 MR. EDWARDS: 8 MR. PAGLIUCA: 9 MR. EDWARDS: 10 Is that Forty-three. Forty-three. March 11th and March 15th, 2001. 11 MR. REINHART: If it will help there, the 12 flight numbers column, like the fifth or sixth 13 column over, are sequentially numbered and 14 unique numbers. 15 "flight 1468" -- So if you want to just say 16 MR. EDWARDS: 17 MR. REINHART: 18 MR. EDWARDS: 20 MR. REINHART: 21 MR. EDWARDS: 22 MR. REINHART: 24 25 -- that might help everybody -- 19 23 Okay. Right. -- follow along. Okay. Thanks, Bruce. Uh-huh. BY MR. EDWARDS: Q. So the flight now that I'm talking about that leaves out of Teterboro on the 15th, flight Case 18-2868, Document 283, 08/09/2019, 2628241, Page270 of 883 Confidential Page 116 1 2 DAVID RODGERS No. 1471 -- 3 A. Right. 4 Q. -- the passengers appear to be Jeffrey 5 Epstein, Ghislaine Maxwell, Adam Perry Lang, Alexia 6 Wallert and Banu Cukuglu? 7 A. I think so. 8 Q. Do you remember Banu? 9 A. I definitely remember that. 10 It was a hard name to spell. 11 Yeah. Sort of, I guess. I mean, if she 12 walked in right now, I probably wouldn't recognize 13 her. 14 Q. Well, it has been since 2001, so -- 15 A. Yeah, I know. 16 Q. Okay. 17 Where is that? So then the next flight is 1472. Where is that going? 18 A. From Islip to Lake City, Florida. 19 Q. All right. A. Jeffrey Epstein, Ghislaine Maxwell, Adam 20 21 And the passengers, again, are who? 22 Perry Lang, Alexia Wallert and Banu Cukuglu, 23 whatever her name is. 24 25 Q. Did you know what relationship she had, if at all, with Jeffrey Epstein? Case 18-2868, Document 283, 08/09/2019, 2628241, Page271 of 883 Confidential Page 117 1 DAVID RODGERS 2 A. No. No. 3 Q. Do you remember an Ed Tuttle? 4 A. Yes. 5 Q. And who was he? 6 A. I believe Ed was a, probably in 7 construction. 8 before the Jeffrey -- well, let me think. 9 10 11 Q. name. I think he may have been around If we skip down to March 16th, I see his So I don't know if that's going to help you. A. I believe -- I believe Ed Tuttle was like 12 maybe an architect, or somewhere in the 13 construction, real estate side, I believe. 14 Q. Okay. So flight No. 1477 -- 15 A. Uh-huh. 16 Q. -- from LaGuardia to Palm Beach, is that 17 Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Joe 18 Pagano, Eva Dubin? 19 A. Yes. 20 Q. Celina Dubin? 21 A. Yes. 22 Q. Jordan Dubin? 23 A. Right. 24 Q. Maya Dubin and two nannies? 25 A. Yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page272 of 883 Confidential Page 118 1 DAVID RODGERS 2 Q. And Alexia Wallert? Is that what that is? 3 A. I would assume so, yes, AW. 4 Q. That is sort of what we talked about in 5 the beginning, where Alexia Wallert appears in full 6 name at the top -- 7 A. Right. 8 Q. -- and it's AW, AW, AW. 9 A. And there's no room to write her name out 10 there -- 11 Q. Right. 12 A. -- so she's AW. 13 Q. Okay. And then the next flight, the 27th, 14 leaves out of Palm Beach. 15 that flight and where's it going? 16 flight. 17 A. Yeah. Who are our passengers on 1478 is the Jeffrey Epstein, Ghislaine Maxwell, 18 Emmy Tayler, Virginia Roberts, two females, Banu, 19 and that's it. 20 Q. And do you know, in New York, when that 21 plane lands in Teterboro, where do you stay when the 22 plane is up there? 23 A. It is 2001. At an apartment there. 24 Q. Did you have your own apartment? 25 A. Yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page273 of 883 Confidential Page 119 1 DAVID RODGERS 2 3 Q. Epstein's apartments? 4 5 Or did you stay at one of Jeffrey A. No. It was his apartment, Jeffrey's apartment. 6 Q. Was that one of the apartments at 301 East 7 66th Street? 8 A. Yes. 9 Q. And did any of the other passengers from 10 that flight, that 1478, did any of them stay at any 11 of those apartments? 12 13 14 15 A. Yeah. Emmy would have. Virginia probably Q. Did you see Virginia stay at the did. apartment? 16 A. I don't know. 17 Q. When you were in New York and you left 18 from the airport, did you ride in the same car with 19 Virginia? 20 21 22 A. ever did. Q. Not usually. I mean, I don't know if we It's possible we did. Do you know whether Virginia Roberts 23 stayed at Jeffrey Epstein's townhouse or whether 24 Virginia Roberts stayed at the apartments? 25 MR. PAGLIUCA: Object to form. Case 18-2868, Document 283, 08/09/2019, 2628241, Page274 of 883 Confidential Page 120 1 DAVID RODGERS 2 THE WITNESS: I don't know for sure. 3 4 5 BY MR. EDWARDS Q. Can you recollect riding in a car with 6 her, or can you recollect whether she got in a car 7 with anyone else? 8 MR. PAGLIUCA: 9 THE WITNESS: I can't. 10 MR. EDWARDS: Okay. 11 MR. REINHART: 12 I'm sorry. Are you asking about that specific trip or -- 13 14 Object to form. MR. EDWARDS: Sorry. BY MR. EDWARDS: 15 Q. I mean that specific trip. 16 A. No. 17 Q. How about in general at any time? 18 A. No. I can't. I don't recall. I mean, I can 19 recall, I would ride sometimes with Emmy, with Adam 20 I remember them being in the car. 21 was unusual. 22 myself. 23 ride with us. 24 25 Q. But, again, that Usually it would just be Larry and But on occasion, you know, somebody might When you would stay at the apartment in New York on East 66th Street, would it always be in Case 18-2868, Document 283, 08/09/2019, 2628241, Page275 of 883 Confidential Page 121 1 2 DAVID RODGERS the same apartment? 3 A. Yes. 4 Q. All right. 5 There are multiple apartments owned by Jeffrey Epstein? 6 A. At that time, it was the same apartment. 7 Q. Okay. 8 Have you stayed in other apartments since that time? 9 A. Yes. 10 Q. All at that East 66th Street location? 11 A. Yes. I really don't -- I don't have an 12 apartment there now. 13 probably 2008. 14 15 Q. We haven't gone there since How about Banu? 301 East 66th Street? 16 MR. PAGLIUCA: 17 THE WITNESS: 18 Would she have stayed at Object to foundation. Most likely. BY MR. EDWARDS 19 Q. Why do you say that? 20 A. Well, if she's on the plane with us on 21 multiple trips, then most likely she probably stayed 22 there. 23 24 25 Q. Have you been to Jeffrey Epstein's townhouse as 9 East 71st Street? A. Yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page276 of 883 Confidential Page 122 1 DAVID RODGERS 2 Q. And it's a pretty big place, right? 3 A. Pretty big. 4 Q. And it has numerous bedrooms? 5 A. Yes. 6 Q. Any reason why Banu would not have been 7 staying there? 8 MR. PAGLIUCA: 9 THE WITNESS: 10 11 Object to foundation. I don't know. BY MR. EDWARDS Q. I'm just trying to get to, is there a 12 reason why you believe that Banu would have, I think 13 you said, probably have stayed at the apartment 14 versus the townhouse? 15 16 A. Well, I only say that because Emmy, you know, stayed there. 17 Q. Stayed where? 18 A. At the -- at our apartments. 19 Q. Okay. 20 A. I'm pretty sure Adam, yeah, Adam stayed 21 there at the time. 22 regulars on the flight, they would stay there in the 23 apartments. 24 25 Q. Okay. So most of the people that were But do you remember Virginia or Banu staying in the apartments? Case 18-2868, Document 283, 08/09/2019, 2628241, Page277 of 883 Confidential Page 123 1 DAVID RODGERS 2 A. I do not specifically. 3 Q. Okay. The next flight on the next day, 4 1479, is flying from Teterboro to Santa Fe; is that 5 right? 6 A. Yes. 7 Q. And who are those passengers? 8 A. Jeffrey Epstein, Ghislaine Maxwell, Adam 9 10 Perry Lang, Virginia Roberts, Banu, Marvin Minsky, Henry Jarecki. 11 Q. Do you remember Marvin and Henry? 12 A. I remember Henry. 13 Marvin. 14 Q. Okay. I don't really remember And then two days later -- again, 15 where would you have stayed if you landed in 16 Santa Fe on March 29th, 2001? 17 A. Probably would have stayed at the ranch. 18 Q. At the Zorro Ranch? 19 A. Yes. 20 Q. All right. Did the other passengers that 21 were on the plane, Jeffrey Epstein, Ghislaine 22 Maxwell, Adam Perry Lang, Virginia Roberts, Banu -- 23 I'm not evening going to try her last name -- 24 A. Right. 25 Q. -- Marvin Minsky and Henry Jarecki also Case 18-2868, Document 283, 08/09/2019, 2628241, Page278 of 883 Confidential Page 124 1 2 DAVID RODGERS have stayed at the ranch? 3 MR. PAGLIUCA: 4 THE WITNESS: 5 they did. 6 BY MR. EDWARDS 7 8 Q. Object to foundation. I'm going to say most likely Was there any other location in Santa Fe where you are aware passengers would have stayed? 9 A. Not that I'm aware of. 10 Q. If you were all going to the same place, 11 is that an occasion where you would all ride in the 12 same vehicle from the airport to the ranch? 13 MR. PAGLIUCA: 14 THE WITNESS: 15 16 17 18 19 Object to foundation. I don't know. BY MR. EDWARDS Q. You would still right in separate vehicles? A. Right. Because it takes us about an hour to finish up at the airport. 20 Q. And then the 31st, so two days? 21 A. Let me go back to that one -- 22 Q. Sure. 23 A. -- and say, it is possible. 24 has ridden with us before. 25 one way or the other. I think Adam So I couldn't swear that But he has probably ridden Case 18-2868, Document 283, 08/09/2019, 2628241, Page279 of 883 Confidential Page 125 1 DAVID RODGERS 2 with us before to the airport; to or from the 3 airport. 4 Q. Two days later, flight No. 1408 out of 5 Santa Fe to Palm Beach, who were the passengers 6 there? 7 A. Jeffrey Epstein, Ghislaine Maxwell, Prince 8 Andrew, Virginia Roberts, Nadia Bjorlin, Henry 9 Jarecki, Marvin Minsky. 10 11 Q. Do you remember when you were at the ranch Nadia Bjorlin arriving? 12 A. I would assume that she airlined in there. 13 Q. Do you remember her at the ranch? 14 perform for you or anything? 15 A. No. 16 I don't remember her at the ranch. 17 mean, I'm sure she was there. 18 remember. 19 Q. Okay. 20 Heather Mann? 21 Lydia. Do you remember a person named She's found on flight 1438 next to A. Heather Mann, not really. 23 Q. Okay. 25 1488. The next flight, on page 45, is The flight number. A. I I just don't 22 24 Did she Right. April 9th, 2001. Case 18-2868, Document 283, 08/09/2019, 2628241, Page280 of 883 Confidential Page 126 1 2 3 DAVID RODGERS Q. Where does that flight take off from and where does it go? 4 A. Palm Beach to Atlantic City. 5 Q. Who is on that flight? 6 A. Jeffrey Epstein, Emmy Tayler, Virginia 7 Roberts, Banu and Johanna. 8 Q. Do you remember Johanna Sjoberg? 9 A. I don't. 10 Q. On that same day, you take a flight to 11 Teterboro? 12 A. Right. 13 Q. Did you go to the casinos at all that day? 14 A. I don't think so. 15 Q. Would that be something that you would do 16 with them? Or you would stay back? 17 A. No. 18 Q. All right. 19 20 We would stay at the airport. And then two days later, on the 11th, flight 1490, the plane flies out of Teterboro. 21 For that two-day period of time, the night 22 of the 9th and the night of the 10th, would you have 23 stayed at the apartment? 24 MR. PAGLIUCA: 25 MR. EDWARDS: Object to foundation. In New York. Case 18-2868, Document 283, 08/09/2019, 2628241, Page281 of 883 Confidential Page 127 1 DAVID RODGERS 2 3 4 5 THE WITNESS: I would say, yes. BY MR. EDWARDS: Q. All right. Do you know where Virginia and Banu and Johanna stayed? 6 A. No idea. 7 Q. You can't recollect whether they were -- 8 you can't recollect seeing them at the apartments? 9 MR. PAGLIUCA: 10 11 12 THE WITNESS: No. BY MR. EDWARDS: Q. 13 14 Object to foundation. All right. Then on the 11th, you leave from Teterboro and go to where? 15 A. St. Thomas. 16 Q. That is flight 1490. And on that flight, 17 Jeffrey Epstein, Ghislaine Maxwell, Prince Andrew, 18 Banu, Virginia Roberts and Johanna? 19 A. Yes. 20 Q. And that is -- that is a flight -- how 21 does -- how did those passengers get from -- does 22 Jeffrey Epstein have a place in St. Thomas? 23 MR. PAGLIUCA: 24 THE WITNESS: 25 Object to form. Well, yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page282 of 883 Confidential Page 128 1 2 DAVID RODGERS BY MR. EDWARDS: 3 Q. Where is that? 4 A. In St. Thomas, he has an office. 5 Thomas. 6 Q. Where does he stay in the Virgin Islands? 7 A. On Little St. James. 8 Q. And how do the passengers get from 9 In St. St. Thomas to Little St. James? 10 A. Most likely, helicopter. 11 Q. How many people does the helicopter fit? 12 A. We didn't own a helicopter then. 13 Probably -- probably 5. It depends, 14 because they had different helicopters. 15 sure which one they used that day. 16 17 Q. I'm not What is the duration of the flight from St. Thomas to Little St. James? 18 A. About six minutes. 19 Q. What is the duration of a boat trip from 20 21 Little St. James to St. Thomas? A. Probably about, let's say, 15 to 20 22 minutes. But you are on the east side of the island 23 and the airport is almost to the west side of the 24 island. 25 Q. So you have to almost circle the island? Case 18-2868, Document 283, 08/09/2019, 2628241, Page283 of 883 Confidential Page 129 1 2 DAVID RODGERS A. To get from the island by boat, to get 3 to -- there's land there and take a car, it is 4 probably -- it is probably close to an hour, 45 5 minutes for sure. 6 7 Q. Are there passenger manifests that are kept for the helicopters? 8 MR. PAGLIUCA: 9 THE WITNESS: 10 11 12 Object to foundation. I'm not sure. I'm not sure. BY MR. EDWARDS: Q. Back in this time, in around April of 2001, did Jeffrey Epstein have a helicopter yet? 13 A. No, he did not have a helicopter. 14 Q. At that time? 15 A. Correct. 16 Q. And so do you remember the name of the 17 company or corporation that they rented or 18 transported? 19 A. 20 I don't. It was the only -- helicopter service there in St. Thomas is no longer there. 21 Q. Okay. 22 A. Air Center Helicopter. 23 Q. Was there a particular person at Air 24 25 Center Helicopter that you ever coordinated with? A. We would, like, call a dispatcher. Or you Case 18-2868, Document 283, 08/09/2019, 2628241, Page284 of 883 Confidential Page 130 1 DAVID RODGERS 2 know, whoever picked up the phone, we would call 3 them. 4 5 Q. All right. So 1491 is a flight from St. Thomas to Palm Beach; is that right? 6 A. Yes. 7 Q. And Gwendolyn Beck is now on that flight? 8 A. Yes. 9 Q. Do you remember that flight at all, 1491? 10 A. Not really. 11 Q. Anything about it stick out in your mind? 12 A. No. 13 Q. All right. 14 remember a female name Kelly Bovina? 15 16 17 18 The next flight that -- do you A. I remember the name, but I don't remember Q. Was she an actress as well, do you her. remember that? 19 A. I don't recall. 20 Q. The next flight I want to direct your 21 attention is 1501, May 3rd, 2001. 22 A. Okay. 23 Q. What is that airport, ADS? 24 A. Addison, Texas. 25 Q. And who are the passengers on that? San Antonio, Texas. Case 18-2868, Document 283, 08/09/2019, 2628241, Page285 of 883 Confidential Page 131 1 DAVID RODGERS 2 A. Jeffrey Epstein, Virginia Roberts. 3 Q. Do you know how Virginia Roberts got to 4 Addison, Texas? 5 A. No. 6 Q. Was that flight -- was the purpose of that 7 flight only to pick up Virginia Roberts? 8 MR. PAGLIUCA: 9 10 Object to form and foundation. BY MR. EDWARDS: 11 Q. Can you tell by your logs? 12 A. Not really. Q. The flight previous on the 3rd flies in 13 14 15 Let's see. We -- no, I don't know. from where? Where is that? 16 A. Little Rock. 17 Q. Arkansas? 18 A. Correct. 19 Q. So the only passenger on that flight from 20 Little Rock, Arkansas, to Addison, Texas, flight 21 1500, is Jeffrey Epstein, right? 22 A. Right. 23 Q. And then you land in Addison before going 24 to Santa Fe? 25 A. That is actually San Antonio, I believe. Case 18-2868, Document 283, 08/09/2019, 2628241, Page286 of 883 Confidential Page 132 1 2 3 4 DAVID RODGERS Yes. That is San Antonio, SAT. Q. How long is the flight from Addison to San Antonio? 5 A. I would be guessing, probably an hour. 6 Q. Do you know what the purpose was for 7 8 9 10 landing -A. 9/10s. Q. Well, you know, I can tell you. It is Fifty-four minutes. Do you know what the purpose was to be to 11 land in Addison, Texas, before arriving in San 12 Antonio? 13 A. I do not. But it appears that we spent 14 the night in San -- oh, I see what you are saying. 15 No, I don't know. 16 the same day. 17 18 Q. That I went to Addison probably Went to Addison and picked up Virginia Roberts? 19 A. It looks like it. 20 Q. And then in San Antonio, two days later, 21 who are your passengers on that flight, 1502? 22 A. Jeffrey Epstein, Virginia Roberts. 23 Q. Where do you fly? 24 A. From San Antonio to Palm Beach. 25 Q. And in May, on May 14th, 2001, flight Case 18-2868, Document 283, 08/09/2019, 2628241, Page287 of 883 Confidential Page 133 1 2 DAVID RODGERS 1506, where is that flight leaving from? 3 A. St. Thomas. 4 Q. And going where? 5 A. Teterboro. 6 Q. And who are your passengers? 7 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 8 9 10 Tayler, Banu, Virginia Roberts and one female. Q. And, again, do you remember who the one female would have been with Virginia Roberts? 11 A. No. 12 Q. Can you tell by this how any of those 13 individuals that were on that flight leaving from 14 the Virgin Islands to Teterboro got to the Virgin 15 Islands? 16 A. No. 17 Q. What were the other possible avenues back 18 in those days for Jeffrey Epstein, Ghislaine Maxwell 19 to travel to the Virgin Islands? 20 A. They could have done a charter, possibly. 21 Q. Okay. Was there ever a time when, it 22 looks like that is the -- that is the Gulfstream 23 that you fly out of the Virgin Islands to Teterboro, 24 correct? 25 A. Correct. Case 18-2868, Document 283, 08/09/2019, 2628241, Page288 of 883 Confidential Page 134 1 2 3 DAVID RODGERS Q. Was there ever a time you were flying the Gulfstream and -- well, let's go back a little bit. 4 A. Okay. 5 Q. On May 7th, at the top. 6 A. Right. 7 Q. Flight 1503, that is the Gulfstream 8 9 10 11 12 traveling from Palm Beach to CHO? A. That is Charlottesville, I believe, Virginia. Q. And then on that same day from Charlottesville to Teterboro? 13 A. Correct. 14 Q. So when does the Gulfstream get from 15 16 17 Teterboro to St. Thomas? A. Hmm, I don't know. that I'm on vacation at that time. 18 Q. 19 to fly? 20 A. Airline. 21 Q. All right. 22 Because it appears So I don't know. How did you get to St. Thomas for the 14th So at some point in time, between May 7th and May 14th -- 23 A. Uh-huh. 24 Q. -- somebody flies the Gulfstream to the 25 Virgin Islands. Case 18-2868, Document 283, 08/09/2019, 2628241, Page289 of 883 Confidential Page 135 1 DAVID RODGERS 2 A. Correct. 3 Q. And who would that be? 4 MR. PAGLIUCA: 5 THE WITNESS: 6 7 Larry Visoski and I don't know who the other person would have been. BY MR. EDWARDS: 8 9 Object to foundation. Q. When you pick up passengers in the Virgin Islands and you are taking them to Teterboro, do you 10 speak with Larry Visoski about when he arrived in 11 the Virgin Islands? 12 A. Yeah. Yeah. We would coordinate that. 13 mean, usually we would go down there together. 14 would ride in the same airline down. 15 16 Q. We In this particular case, you were on vacation? 17 A. Well, that is true. However, most likely 18 he airlined home once he got to St. Thomas. 19 then most likely, we drove in a car to Miami and 20 road the same airline down there. 21 And Q. That was something that you customarily 23 A. Yes. 24 Q. Okay. 22 25 did? So then you have -- we have no way of knowing then who the passengers that flew to the I Case 18-2868, Document 283, 08/09/2019, 2628241, Page290 of 883 Confidential Page 136 1 DAVID RODGERS 2 Virgin Islands would have been, if there were any in 3 addition to those that left? 4 A. No. 5 Q. All right. You fly into Teterboro on 6 flight 1506 on May 14th, 2001, and fly out in the 7 Gulfstream on the 24th, 10 days later; is that 8 right? 9 A. Yes. 10 Q. And your passengers, 10 days later flying 11 to Palm Beach are Jeffrey Epstein, Ghislaine 12 Maxwell, Emmy Tayler, Adam Perry Lang and a female. 13 A. Right. 14 Q. Do you know where Virginia Roberts went 15 during that time after she landed in Teterboro on 16 the 14th? 17 A. I do not. 18 Q. Page 47, I'm going to go to flight 19 No. 1510. 20 June 3rd, 2001. Who is on that flight? 21 A. Jeffrey Epstein, Virginia Roberts, Banu. 22 Q. And you are flying from Palm Beach to 23 St. Thomas again? 24 A. St. Thomas, yes. 25 Q. And then from St. Thomas to Teterboro two Case 18-2868, Document 283, 08/09/2019, 2628241, Page291 of 883 Confidential Page 137 1 2 DAVID RODGERS days later, on June 5th? 3 4 Jeffrey Epstein, Virginia Roberts, and Q. All right. Banu. 5 6 A. And then where is the next flight on the 8th? 7 A. On the 8th, from Teterboro to Montreal. 8 Q. Do you know what -- so Virginia Roberts 9 and Banu were not on the flight on the 8th, right? 10 A. That's correct. 11 Q. Okay. 12 Do you remember the flight on the 8th with Naomi Campbell, Rebecca White, Ana Malova? 13 A. Sort of. 14 Q. Okay. 16 A. No. 17 Q. Do you remember how old Rebecca White was? 18 A. No. 19 Q. The next flight I want to direct your 15 20 But not really. Do you remember who Rebecca White is? attention to is on the 15th of June, flight 1516. 21 A. Uh-huh. 22 Q. Passengers: 23 Jeffrey Epstein, Ghislaine Maxwell, and then does that say Sheridan? 24 A. Yes. 25 Q. Do you remember a passenger named Sheridan Case 18-2868, Document 283, 08/09/2019, 2628241, Page292 of 883 Confidential Page 138 1 DAVID RODGERS 2 Gibson? 3 A. Possibly. 4 Q. And then it says, Caroline. 5 Do you know who Caroline is? 6 A. I do not. 7 Q. And then one female? 8 A. Yeah, I don't know who the female is. 9 Q. Okay. 11 A. Uh-huh. 12 Q. From -- is that Portugal to St. Thomas? 13 A. No. 14 Q. LPAZ? 15 A. Yes. 16 Q. To St. Thomas? 17 A. Right. 18 Q. And then on that flight is Jeffrey 10 On the 28th, there is a flight 1523. It is the Azores. It was a fuel stop. 19 Epstein, Ghislaine Maxwell, Emmy Tayler and Ed 20 Tuttle, right? 21 A. Yes. 22 Q. Six days later, leaving on July 4th from 23 24 25 St. Thomas, who are your passengers? A. Jeffrey Epstein, Prince Andrew, Virginia Roberts, one female. Case 18-2868, Document 283, 08/09/2019, 2628241, Page293 of 883 Confidential Page 139 1 DAVID RODGERS 2 3 Q. And do you know how Virginia Roberts got to the Virgin Islands? 4 A. No. 5 Q. Is there any -- is it possible that the 6 Cessna took her or the Boeing took her? 7 other aircraft that is owned by Jeffrey? 8 MR. PAGLIUCA: 9 THE WITNESS: 10 11 Or any Object to foundation. No, I would -- if I had to guess, I would guess the airlines. BY MR. EDWARDS: 12 Q. Okay. 13 A. Well, I know it wasn't the Boeing, because 14 the Boeing is not in operation at that point in 15 time. 16 any passengers on board yet. 17 of 2001. 18 19 Q. Okay. A. That is like in August And the Cessna, did you take that It has been to the Virgin Islands, but I don't think we ever took any passengers down there. 22 Q. Okay. 24 A. Okay. 25 Q. On July 8th, 2001. 23 I mean, it hadn't had from Florida to the Virgin Islands? 20 21 We hadn't flown it. All right. 1525. The next flight is Case 18-2868, Document 283, 08/09/2019, 2628241, Page294 of 883 Confidential Page 140 1 DAVID RODGERS 2 A. Okay. 3 Q. That leaves out of Palm Beach? 4 A. Okay. 5 Q. Where do you go on that? 6 A. Teterboro. 7 Q. And who are your passengers? 8 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 9 Tayler, Prince Andrew, Virginia Roberts, Sheridan 10 Gibson, maybe Sheridan Gibson-Beaute, I guess, and 11 one female. 12 13 Q. And then three days later, you leave out of Teterboro to CPS? 14 A. Yes. 15 Q. Where is that? 16 A. That is St. Louis, actually it is Cahokia, 17 Illinois, across the river from St. Louis. 18 Q. Who are your passengers? 19 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 20 Tayler, Virginia Roberts. 21 to Santa Fe. 22 to go into there for maintenance. 23 24 25 Q. We were actually en route We had a mechanical problem. We had Do you remember having a mechanical problem or is the log just refreshing your memory? A. No, I remember because that was the only Case 18-2868, Document 283, 08/09/2019, 2628241, Page295 of 883 Confidential Page 141 1 2 DAVID RODGERS time we landed at Cahokia with passengers on board. 3 Q. What was the problem? 4 A. We had a -- we had a static line that had 5 cracked and it was causing our altimeters to not 6 agree. 7 things got really worse because it was stopped up 8 with a mud dauber somewhere in the system. 9 why I remember that flight. 10 11 12 Q. And then we went to the alternate system, When you landed in St. Louis did the passengers get off the plane? A. Yes. 13 they airlined. 14 don't recall. 15 That is Q. And then they airlined -- I believe They could have taken a charter, I But I know they didn't leave with us. All right. And the passengers that got 16 off the plane would have been Jeffrey Epstein, 17 Ghislaine Maxwell, Emmy Tayler and Virginia Roberts? 18 A. Yes. 19 Q. And then on the 16th, those five days 20 later, those same passengers leave Santa Fe? 21 A. Right. 22 Q. And go back to Teterboro? 23 A. Correct. 24 Q. When Jeffrey Epstein would go to his 25 townhouse in New York, would you always fly into Case 18-2868, Document 283, 08/09/2019, 2628241, Page296 of 883 Confidential Page 142 1 2 DAVID RODGERS Teterboro? 3 A. Most of the time. 4 airplane, too. 5 to take it into Teterboro. 6 7 Q. Like the Boeing, you are not allowed So while you had the Gulfstream, it seemed like Teterboro? 8 9 It would depend on the A. Yeah, it is -- I mean, occasionally there would be a LaGuardia in there, but not really often. 10 Q. So on the 16th, you fly in to Teterboro. 11 And then six days later, it looks like, flight 12 No. 15 -- oh, wait. 13 All right. So flight No. 1528, you fly into 14 Teterboro, Jeffrey Epstein, Emmy Tayler, Ghislaine 15 Maxwell and Virginia Roberts. Do you see that? 16 A. Yes. 17 Q. Then the next flight I have listed is 18 1530. 19 20 21 Do you know where 1529 is? A. I wasn't on that flight. 22 23 24 25 No, other than I'm gone for some reason. Let's see. July, approximately. I see I went on vacation. Q. Okay. And the 23rd, there is a flight from Palm Beach to St. Thomas with Jeffrey Epstein, Case 18-2868, Document 283, 08/09/2019, 2628241, Page297 of 883 Confidential Page 143 1 2 DAVID RODGERS Shelly Lewis. Do you see that? 3 A. Yes. 4 Q. Five days later, the flight that leaves 5 St. Thomas does not have Shelly Lewis; is that 6 right? 7 A. Correct. 8 Q. And then you fly to Palm Beach? 9 A. Yes. 10 Q. And who are your passengers at that time? 11 A. Jeffrey Epstein, Virginia Roberts, yes. 12 Q. When you had the mechanical problem, do 13 you remember any of the passengers being scared or 14 frightened? 15 A. No. Not really. I mean, they didn't 16 really know that we had a problem. We just informed 17 them that we couldn't continue on to Santa Fe. 18 Q. Okay. 19 A. Uh-huh. 20 Q. Is that the first flight that the Boeing 21 And August 7th, 2001, flight 2? makes with passengers? 22 A. Correct. 23 Q. And that is Jeffrey Epstein, Ghislaine 24 Maxwell, Emmy Tayler, Prince Andrew and two females. 25 Do you remember who the two females were on the Case 18-2868, Document 283, 08/09/2019, 2628241, Page298 of 883 Confidential Page 144 1 2 DAVID RODGERS first passenger flight of the Boeing? 3 A. I do not. 4 Q. And then on the 7th -- at that flight flew 5 from Los Angeles to Albuquerque, correct? 6 A. Uh-huh. 7 Q. On the 14th, you were flying the Cessna 8 that has the 908GM tag. 9 A. Correct. 10 Q. And then the next entry with passengers is 11 on the 16th. 12 right? And you are flying the Boeing again, 13 A. Yes. 14 Q. All right. 15 16 17 20 21 Do you know who flew the Boeing for flight 3, 4 and 5? A. wasn't me. 18 19 Right. For 3, 4 and 5, no. Oh, yes. I know it I do remember that now. I went on vacation. And it was a contract guy that flew for us while I was gone. Q. Do you remember a passenger named Alexander Dixon? 22 A. Alexander Dixon, no. 23 Q. Flight No. 11 on the Boeing? 24 A. Uh-huh. 25 Q. Now, the Boeing has the tag 908JE? Case 18-2868, Document 283, 08/09/2019, 2628241, Page299 of 883 Confidential Page 145 1 DAVID RODGERS 2 A. Correct. 3 Q. That is what you were explaining in the 4 beginning, correct? 5 A. Correct. 6 Q. So September 3rd, the Boeing flies from 7 St. Thomas to HPN? 8 A. Yes, White Plains, New York. 9 Q. And your passengers? 10 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 11 Tayler, Adam Perry Lane, Banu, Sarah Kellen, 12 Alexander Dixon. 13 Q. Do you remember Sarah Kellen? 14 A. Yes. 15 Q. And do you remember what -- is that your 16 17 first time meeting Sarah Kellen, when she appears? A. I don't think so. 18 earlier flight. 19 could be, I'm not sure. 20 21 Q. Let's see. I thought she was on an But it could be. It Do you know how Sarah Kellen got to St. Thomas to be leaving St. Thomas with you? 22 A. No. 23 Q. Do you know what her relationship was, if 24 25 any, with Jeffrey Epstein? A. She was -- Sarah was sort of taking over Case 18-2868, Document 283, 08/09/2019, 2628241, Page300 of 883 Confidential Page 146 1 2 DAVID RODGERS Emmy's position. Like an assistant to Ghislaine. 3 Q. All right. 4 A. Okay. 5 Q. There is a flight from Bedford, 6 Page 53. January 15th, 2002. Massachusetts; is that right? 7 A. Yes. 8 Q. To where is that going? 9 A. White Plains. 10 Q. And it's Jeffrey Epstein and Jessica. 11 A. Yes. 12 Q. Do you remember who Jessica is? 13 A. I do not. 14 Q. From White Plains, who are the passengers 15 16 going to St. Thomas? A. Jeffrey Epstein, Ghislaine Maxwell, Sarah 17 Kellen, Prince Andrew, Cindy Lopez, Johanna and one 18 female. 19 Q. Do you remember Cindy Lopez? 20 A. Yes. 21 Q. And what did she do? 22 A. I don't know what she did, but I do 23 24 25 remember Cindy Lopez. Q. masseuse? Was she somebody that you believed to be a Case 18-2868, Document 283, 08/09/2019, 2628241, Page301 of 883 Confidential Page 147 1 2 3 4 5 DAVID RODGERS A. I'm not sure what her position was. It is possible. Q. All right. February 9th, 2002, flight 57 on the Boeing. 6 A. Okay. 7 Q. From Miami to White Plains. 8 A. Yes. 9 Q. Your passengers include Bill Clinton, four 10 Secret Service. 11 12 Did the Secret Service ask that you not identify them by name? 13 A. No. 14 Q. Any reason that you didn't identify them 15 by name? 16 A. Didn't know their name. 17 Q. Two males, one female. 18 A. Right. 19 Q. Jeffrey Epstein, Ghislaine Maxwell, Sarah 20 Kellen and Prince Andrew. 21 A. Correct. 22 Q. Was that your first time meeting Bill 23 Clinton? 24 A. Yes. 25 Q. At that point, did you have any Case 18-2868, Document 283, 08/09/2019, 2628241, Page302 of 883 Confidential Page 148 1 DAVID RODGERS 2 understanding of what was the relationship between 3 Jeffrey Epstein and Bill Clinton or Ghislaine 4 Maxwell and Bill Clinton? 5 A. No, I didn't have any idea. 6 Q. Had you seen any pictures, prior to that 7 time, of Bill Clinton in any of Jeffrey Epstein's 8 planes or homes? 9 A. Not him I'm aware of. 10 Q. Have you ever seen a picture of Bill 11 Clinton in Jeffrey Epstein's plane? 12 A. In his plane? I don't think so. 13 Q. Have you ever seen one in his homes? 14 A. Not that I can recall. 15 Q. Okay. 16 A. Oh, wait, wait. Back up. A picture of 17 Bill Clinton in the plane? 18 is on the wall in the airplane or a picture taken of 19 Bill Clinton on the plane? 20 21 22 Q. Do you mean the picture A picture of Bill Clinton on the wall of the airplane. A. I have a picture of me and actually the 23 crew with Bill Clinton on the plane, but it is not 24 on the wall of the airplane. 25 Q. And when was the picture of you with Bill Case 18-2868, Document 283, 08/09/2019, 2628241, Page303 of 883 Confidential Page 149 1 2 DAVID RODGERS Clinton taken? 3 A. I think it was the first flight. 4 Q. The flight that we just looked at? 5 A. Yes. 6 Q. To the best of your knowledge, is that the 7 first time that Bill Clinton flew with Jeffrey 8 Epstein or Ghislaine Maxwell? 9 10 11 12 A. To the best of my knowledge. It was the first time that we had flown him. Q. Okay. On flight No. 72, which is page 54, March 10th. 13 A. Okay. 14 Q. The Boeing flies from St. Thomas to JFK; 15 is that right? 16 A. Yes. 17 Q. Is there any way of knowing when the 18 19 Boeing got to St. Thomas by these logs? A. Yes, it got there on the 28th. 20 is trip No. 71 above it. 21 State the question again. 22 23 Q. Oh, wait. Oh. Because it Wait. Yes, exactly. Do we know how or when the Boeing got to 24 St. Thomas? It is leaving out of St. Thomas on 25 flight 72, but flight 71 seems to me to land in Palm Case 18-2868, Document 283, 08/09/2019, 2628241, Page304 of 883 Confidential Page 150 1 2 DAVID RODGERS Beach. 3 A. Correct. 4 Q. So I'm just missing the kind of connection 5 there. 6 A. Yes. Me, too. 7 Q. Okay. 8 A. Yeah, I don't have an answer for that. 9 Q. Okay. Would somebody else have flown the 10 Boeing, while you were doing this simulator, the 6th 11 and 7th and 8th? 12 A. It is possible. 13 Q. That is one possible conclusion, based 14 upon what we have here? 15 A. That is probably what happened. 16 Q. Okay. 17 18 So then March 10th -- sorry. March 10th, you fly to JFK, right? 19 A. Yes. 20 Q. March 4th, from JFK to Palm Beach. March 21 the 17th, from Palm Beach back to JFK. 22 March 19th, 2002, you fly from JFK to -- where is 23 that? 24 A. Luton, London. 25 Q. And who are your passengers? And then Case 18-2868, Document 283, 08/09/2019, 2628241, Page305 of 883 Confidential Page 151 1 2 DAVID RODGERS A. Bill Clinton. Doug Band. Three Secret 3 Service, Jeffrey Epstein, Ghislaine Maxwell, Sarah 4 Kellen. 5 Q. 6 later. 7 8 9 And the next day -- or, sorry, two days Do you know where those passengers stayed in London? A. I have to think about this one second. 10 No, in fact, I don't think they did. 11 didn't spend the night there. 12 to the hotel. 13 word from Secret Service that President Clinton 14 wanted to leave that night, so we left that night. 15 We went there. So we made it to the hotel, the crew did, but we were there not that long. 17 hours, four hours, maybe. 19 20 I got As soon as I got to the hotel, I got 16 18 Because we Q. Two or three Do you remember why he wanted to leave that night? A. No. No, because when we went there, we 21 thought we were going to be there for like probably 22 at least a couple of nights. 23 out -- we didn't even spend one night there. 24 25 Q. Okay. But it didn't turn So does this probably mean that you got there late at night on the 19th, the early Case 18-2868, Document 283, 08/09/2019, 2628241, Page306 of 883 Confidential Page 152 1 2 3 DAVID RODGERS morning on the 21st? A. We took off the 19th. So when we land 4 there, it is really the 20th. 5 took off there, it is like after midnight or 6 thereabouts. 7 Q. And that is when you fly back to JFK? 8 A. Back to JFK, yes. 9 Q. And you went there with three Secret 10 And probably when we Service and came back with 10? 11 A. Yes. 12 Q. How did that happen? 13 A. Well, there was an advance party waiting 14 for us when we got there and then when we came back, 15 they just flew back with us. 16 17 18 19 20 21 Q. What was the events that you were traveling to London for? A. I'm not sure. I would imagine, he was probably giving a speech. Q. Okay. And you came back with Bill Clinton, Doug Band? 22 A. Yes. 23 Q. Who was Doug Band? 24 A. Doug was Bill Clinton's, he's an attorney, 25 and he was like his right-hand guy, really, as far Case 18-2868, Document 283, 08/09/2019, 2628241, Page307 of 883 Confidential Page 153 1 2 3 DAVID RODGERS as doing anything. Q. Okay. And you also flew back with Jeffrey 4 Epstein, Ghislaine Maxwell, Sarah Kellen and Naomi 5 Campbell? 6 A. Yes. 7 Q. How did it happen that Naomi Campbell 8 9 joined the plane to come home? A. I don't know. The same way she joined it 10 before I guess in Montreal. 11 was there. 12 13 Q. I don't know how she And one male, too. All right. It looks like. The next page is page 56, flight 96. 14 A. Okay. 15 Q. Sorry. Let's back up to 94. 16 When the Boeing takes off from JFK, do you 17 know sometime during that trip that you are going to 18 be picking up President Clinton? 19 20 A. Let me see. We went to Paris. 21 22 I think so. Yes, oh, yes. We knew that was going to be a long trip. 23 Q. Okay. 24 A. So we knew at that point in time. 25 almost certain that we knew. I'm Case 18-2868, Document 283, 08/09/2019, 2628241, Page308 of 883 Confidential Page 154 1 DAVID RODGERS 2 Q. What did you know about that trip? 3 A. We knew that was going to be a long trip 4 because we were going to go around the world. 5 So when we departed, it was a about a week 6 later, as I recall, that we picked up Clinton. 7 left JFK on the 11th, a little less than a week. 8 Half a week later, we picked up Clinton and from 9 there, we went to -- Hong Kong. 10 Q. We So you fly in to -- on the 20th, flight 11 99, Jeffrey Epstein, Ghislaine Maxwell, and Sarah 12 Kellen. 13 A. Right. 14 Q. You fly in to a Naval air base in Japan? 15 A. Correct. 16 Q. How were you given access to stay in the 17 Naval air base? 18 MR. PAGLIUCA: 19 THE WITNESS: 20 21 22 23 24 25 Object to foundation. The airplane, you mean? BY MR. EDWARDS: Q. Yes. It looks like it is there two days. That is why -A. I guess because we were picking up President Clinton. Q. And do you know where Jeffrey Epstein, Case 18-2868, Document 283, 08/09/2019, 2628241, Page309 of 883 Confidential Page 155 1 2 DAVID RODGERS Ghislaine Maxwell and Sarah Kellen stayed? 3 A. I do not. 4 Q. Was there a room for them on the Naval air A. No, I don't think -- nobody stayed at the 5 6 7 8 9 base? Naval air base. Q. All right. And then on the 22nd, you leave the Naval air base with -- who is that on that 10 flight? 11 A. Jeffrey Epstein, Ghislaine Maxwell, Sarah 12 Kellen, President Bill Clinton, Mike, Doug Band, 13 Janis and Jessica. 14 15 Q. You flew into the Naval air base with Jeffrey Epstein? 16 A. Plus six other passengers. 17 Q. Okay. 18 A. Most likely. 19 Q. You flew in to the Naval air base with Are those secret service? 20 Jeffrey Epstein, Ghislaine Maxwell and Sarah Kellen 21 only, right? 22 A. Right. 23 Q. And nobody stayed on the Naval air base? 24 A. No. 25 Q. And you are there to pick up Bill Clinton? Case 18-2868, Document 283, 08/09/2019, 2628241, Page310 of 883 Confidential Page 156 1 DAVID RODGERS 2 A. Yes. 3 Q. And you pick up Bill Clinton and six 4 passengers plus Mike? 5 A. Correct. 6 Q. Doug Band, who you have already explained 7 who that is with relation to Bill Clinton, and Janis 8 and Jessica. 9 A. Yes. 10 Q. Do you know who they are? 11 A. Yes. 12 Q. Who are Janis and Jessica? 13 A. Secret Service. 14 Q. How do you remember that? 15 A. Well, there is probably 8, 8 or 9 Secret 16 Service people there, two of them were women. 17 other 7 -- and it was just easier to remember the 18 two women's names than the 7 other guys' names. 19 20 Q. This entry on January 22nd, 2002, Jessica, is that the same or a different Jessica from -- 21 A. On which one? 22 Q. Sure. 23 The Sorry. May 22nd. I think I butchered the date before. 24 A. Right. 25 Q. May 22nd, 2002. Is that the same Jessica Case 18-2868, Document 283, 08/09/2019, 2628241, Page311 of 883 Confidential Page 157 1 2 3 DAVID RODGERS as January 15th, 2002, flying with Jeffrey Epstein? A. 4 5 January 15th. MR. REINHART: Flight 48. BY MR. EDWARDS: 6 Q. Right. 7 A. I'm don't think -- no, I they wouldn't be 8 9 10 It is flight 48. the same Jessica, no. Q. Okay. After you pick up President Bill Clinton, where did you fly? 11 A. We went to Hong Kong. 12 Q. Do you know what the purpose was? 13 A. I believe he was giving a speech. 14 Q. All right. 15 And then from there, where did you fly? 16 A. That would be Shenzhen, Japan -- or China. 17 Q. Okay. 18 And do you remember the purpose there? 19 A. Speech. 20 Q. And then where did you fly? 21 A. Singapore. 22 Q. Again, another speech? 23 A. Another speech. 24 Q. During the course of these days, where did 25 President Bill Clinton sleep? Case 18-2868, Document 283, 08/09/2019, 2628241, Page312 of 883 Confidential Page 158 1 DAVID RODGERS 2 3 4 5 A. I guess at a hotel somewhere. Q. Did he stay at the same place as Jeffrey sure. Epstein, Ghislaine Maxwell and Sarah Kellen? 6 MR. PAGLIUCA: 7 THE WITNESS: 8 9 10 11 Foundation. I don't know. BY MR. EDWARDS: Q. All right. Were meals served on the plane? A. Something was served, but I don't know if 12 you would call it a meal. 13 had catering and stuff. 14 15 16 17 Q. Probably. I'm sure we I just don't recall. That was just typical back then to have meals, especially for the President, right? A. Normally we do not. And we probably did have catering back then, but I don't recall. 18 Q. Okay. 19 A. Singapore, VTBD, I don't know. 20 I'm not Where did you fly from Singapore? You have your cheat sheet over there? 21 Q. VTBD, mine says Thailand. 22 A. I was going to guess Thailand. 23 Then from Thailand, I think we went to -- 24 Q. My cheat sheet says Brunei? 25 A. Exactly. You don't want to go there. Case 18-2868, Document 283, 08/09/2019, 2628241, Page313 of 883 Confidential Page 159 1 DAVID RODGERS 2 Q. You don't? 3 A. No. 4 Q. Okay. 5 Was the purpose a speech at each location to the best of your knowledge? 6 A. To the best of my knowledge, it was. 7 Q. All right. Do you know why it was that 8 Jeffrey Epstein and Ghislaine Maxwell and Sarah 9 Kellen accompanied him? 10 A. No. 11 Q. And then did you leave? 12 13 MR. REINHART: Did you answer that question? 14 THE REPORTER: He said no. 15 MR. REINHART: I didn't hear it. 16 17 18 19 BY MR. EDWARDS: Q. Did you leave President Bill Clinton and Doug Band and the Secret Service in Brunei? A. 20 Hmm. It is possible. What is WRR? 21 Q. Not found. 22 A. Not good. 23 Q. That is the only entry in here that is not 24 25 Sorry. found. But the next one, VCBI says Sri Lanka? Case 18-2868, Document 283, 08/09/2019, 2628241, Page314 of 883 Confidential Page 160 1 2 DAVID RODGERS A. Okay. Then if that says Sri Lanka, then, 3 yes, we probably did leave Clinton in Brunei, I 4 think. 5 We went to Bali without -- And I think we went from there down to Bali. 6 Q. Without Bill Clinton? 7 A. Yes. 8 Q. What was the purpose of the trip to Bali? 9 A. Just to get away. 10 Q. And then to Sri Lanka? 11 A. Sri Lanka was just a fuel stop on the way 12 to Paris. Two fuel stops. 13 Q. That's in Dubai? 14 A. Yes. 15 Q. And then you get to Paris? 16 A. Correct. 17 Q. And then you fly back to London? 18 A. Yes. 19 Q. All right. 20 Yes. Do you remember the purpose of the trip to London? 21 A. Yes. 22 Q. What was that? 23 A. We had to have our APU changed on the 24 airplane. 25 there. It quit working in Paris. And we landed Case 18-2868, Document 283, 08/09/2019, 2628241, Page315 of 883 Confidential Page 161 1 DAVID RODGERS 2 Q. All right. 3 June 21st. 4 leaving from? The next page, page 57, Flight 1570. Where is that flight 5 A. Palm Beach to the Bahamas. 6 Q. And who is on the flight from Palm Beach 7 to the Bahamas? 8 9 10 A. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Cindy Lopez, Jean-Luc Brunel, Virginia Roberts. 11 Q. All right. 12 A. Yes. 13 Q. All right. 14 And that is on June 21st? And then there is a couple of entries that say "reposition." 15 A. Right. 16 Q. That is flying back to Palm Beach and then 17 back down to the Bahamas? 18 19 A. Correct. Yeah, we left them there. we flew the airplane home. 20 Q. 21 on the 23rd. 22 A. Yes. 23 Q. Up to Teterboro. 24 25 And And then did you leave out of the Bahamas And who are your passengers on flight 1573? Case 18-2868, Document 283, 08/09/2019, 2628241, Page316 of 883 Confidential Page 162 1 2 DAVID RODGERS A. Jeffrey Epstein, Ghislaine Maxwell, Sarah 3 Kellen, Cindy Lopez, Juliana Borres, I guess, 4 Jean-Luc Brunel, Melissa Stahl. 5 6 Q. Bahamas. A Virginia Roberts was taken to the Do you know where she went from there? 7 A. I do not. 8 Q. Do you remember a Frederic Fekkai? 9 A. What is the name again? 10 Q. Fekkai, F-E-K-K-A-I. 11 A. First name? 12 Q. Fred. 13 A. Fred. 14 Q. Hairdresser? 15 A. The last name sounds familiar. 16 Q. All right. 17 Frederic Fekkai? He's on a flight No. 116 on the Boeing. 18 A. Uh-huh. 19 Q. June 27th? 20 A. Okay. 21 Q. And there are -- it looks like a bunch of 22 passengers. I see. Do you remember Daralyn Priest? 23 A. No. Where is she? 24 Q. Middle column. 25 A. Daralyn. Oh, yes, I see her. Right. I Case 18-2868, Document 283, 08/09/2019, 2628241, Page317 of 883 Confidential Page 163 1 2 DAVID RODGERS don't remember her. 3 Q. Do you remember that flight? 4 A. To Paris. 5 flight. 6 unusual, going to Paris. Not really. It was a big We had a lot of people on it, which was No, I don't. 7 Q. You don't remember it. 8 A. No. 9 Q. So you don't remember the purpose of the 10 flight? 11 A. No. 12 Q. July 2002, it is page 58. 14 A. Okay. 15 Q. LF? 16 A. That is Nice. 17 Q. And where do you go? 18 A. Tangiers. 19 Q. And then from Tangiers to? 20 A. To another place in Morocco. 13 120. 21 I think it is Marrakesh. 22 one. 23 24 25 Go to flight Marrakesh. I could be wrong on that It is definitely Morocco. Q. From there, is that where you pick up Bill Clinton? A. Let's see. GMME would be Rabat, the Case 18-2868, Document 283, 08/09/2019, 2628241, Page318 of 883 Confidential Page 164 1 2 DAVID RODGERS capital of Morocco, I believe. 3 4 Q. Did you know before this flight that you at some point would be picking up Bill Clinton? 5 A. I think we did, yes. 6 Q. Who was on the flight with Bill Clinton? 7 A. Jeffrey Epstein, Ghislaine Maxwell, Sarah 8 Kellen, Prince Andrew, Cindy Lopez, President 9 Clinton, Doug Band, Mike, with Secret Service and 8 10 Secret Service people. 11 people. 12 Q. So Mike is a person that is also -- that A. He's Secret Service, yes. 13 14 So probably 9 Secret Service is? 15 what I recall. 16 Service. That is just He was the lead guy of the Secret 17 Q. Where do you take Bill Clinton? 18 A. We went to the Azores for a fuel stop and 19 20 then we went to JFK. Q. Kennedy, New York. Then on August 5th, in the Gulfstream, on 21 flight 1586, you leave from Teterboro and go to 22 Santa Fe; is that correct? 23 A. Correct. 24 Q. On that flight, you have Jeffrey 25 Epstein -- sorry, Jeffrey Epstein, Sarah Kellen and Case 18-2868, Document 283, 08/09/2019, 2628241, Page319 of 883 Confidential Page 165 1 DAVID RODGERS 2 two females? 3 A. Yes. 4 Q. Do you know who those two females were? 5 A. No. 6 Q. How long does the plane, the Gulfstream, 7 8 9 stay in Santa Fe? A. Let's see. 1586, Gulfstream. I don't really know, because apparently, we had 1586 and the 10 next one I see is 1589. So it flew three places, 11 but I wasn't on that trip. 12 Q. 1587 and 1588 are missing, right? 13 A. That is what I'm saying. 14 Q. Because you are not on it? 15 A. I'm not on the trip. 16 Q. And 1589? 17 A. Uh-huh. 18 Q. Leaving out of Santa Fe, who are the 19 20 passengers? A. Jeffrey Epstein, Ghislaine Maxwell, Sarah 21 Kellen, Cindy Lopez, Virginia Roberts, Dan Moran, 22 Eduardo, Alfred, Margarita and Nick Simmons. 23 24 25 Q. Do you know how Virginia Roberts got to Santa Fe? A. No. Case 18-2868, Document 283, 08/09/2019, 2628241, Page320 of 883 Confidential Page 166 1 2 3 DAVID RODGERS Q. say, Florida -- well, strike that. 4 5 6 7 Is there any way to get to Santa Fe from, MR. PAGLIUCA: Bus, train, car. BY MR. EDWARDS: Q. Did you ever know Virginia Roberts to take a train? 8 A. Not that I'm aware. 9 Q. Did you ever know her to take a bus? 10 MR. REINHART: 11 THE WITNESS: 12 13 14 15 To go to New Mexico? Not that I'm aware. Maybe she has, but I don't know about it. BY MR. EDWARDS: Q. Okay. I have a picture of her on horseback at the ranch, so who knows. 16 Let's see. August 17th, sorry, 17 August 18th. 18 A. Okay. 19 Q. From Teterboro to Palm Beach? 20 A. Right. 21 Q. Who are your passengers? 22 A. Jeffrey Epstein, Virginia Roberts, one 23 female. 24 Q. 25 All right. female was? Do you remember who that Case 18-2868, Document 283, 08/09/2019, 2628241, Page321 of 883 Confidential Page 219 1 DAVID RODGERS 2 CERTIFICATE OF OATH 3 STATE OF FLORIDA ) 4 COUNTY OF MIAMI-DADE ) 5 6 7 I, the undersigned authority, certify that DAVID RODGERS personally appeared before me and was duly sworn. WITNESS my hand and official seal this 8th day of June, 2016. 8 9 Kelli Ann Willis, RPR, CRR Notary Public, State of Florida Commission FF928291, Expires 2-16-20 + + + + + + + + + + + + + + + + + + 10 11 12 CERTIFICATE 13 STATE 14 COUNTY OF MIAMI-DADE ) 15 16 17 18 19 20 21 22 OF FLORIDA ) I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime Reporter do hereby certify that I was authorized to and did stenographically report the foregoing deposition of DAVID RODGERS; that a review of the transcript was not requested; and that the transcript is a true record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 8th day of June, 2016. 23 24 25 KELLI ANN WILLIS, RPR, CRR Cam: 18-7868, 782, 08/00/7010, 7678741, nf 882 EXHIBIT 16 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page323 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x May 18, 2016 9:04 a.m. C O N F I D E N T I A L Deposition of JOHANNA SJOBERG, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 18-2868, Document 283, 08/09/2019, 2628241, Page324 of 883 Page 8 1 Q. 2 3 Okay. Great. All right. Do you know a female by the name of Ghislaine Maxwell? 4 A. Yes. 5 Q. And when did you first meet Ms. Maxwell? 6 A. 2001. 7 March probably. End of February/beginning of March. 8 Q. And how did you meet her? 9 A. She approached me while I was on campus at 10 Palm Beach Atlantic College. 11 Q. And what happened when she approached you? 12 A. She asked me if I could tell her how to 13 find someone that would come and work at her house. 14 She wanted to know if there was, like, a bulletin 15 board or something that she could post, that she was 16 looking for someone to hire. 17 Q. And what did you discuss with her? 18 A. I told her where she could go to -- you 19 know, to put up a listing. 20 I knew anyone that would be interested in working 21 for her. 22 23 24 25 Q. And then she asked me if Did she describe what that work was going to be? A. She explained that she lived in Palm Beach and didn't want butlers because they're too stuffy. Case 18-2868, Document 283, 08/09/2019, 2628241, Page325 of 883 Page 9 1 And so she just liked to hire girls to work at the 2 house, answer phones, get drinks, do the job a 3 butler would do. 4 5 Q. And did she tell you what she would pay for that kind of a job? 6 A. At that moment, no, but later in the day, 8 Q. And what did she say? 9 A. Twenty dollars an hour. 10 Q. Was there anybody else with Ms. Maxwell 7 11 yes. when you met her? 12 A. There was another woman with her. I don't 13 recall her or what she looks like or how old she 14 was. 15 Q. And what happened next? 16 A. And then she asked me if I would be 17 interested in working for her. 18 she was -- I could trust her and that I could jump 19 in her car and go check out the house at that moment 20 if I wanted. 21 22 And she told me that And so I said, Sure, let's do it, and went to her home with her. 23 Q. And where was that home? 24 A. In Palm Beach. 25 Q. And did she describe that home as being Case 18-2868, Document 283, 08/09/2019, 2628241, Page326 of 883 Page 12 1 magazines. 2 She and I went -- she wanted to take me 3 shopping to Worth Avenue, but it was a Sunday and 4 Nieman Marcus was closed, so we went back to, like, 5 a little book store. 6 think, five pairs of reading glasses because she 7 thought Jeffrey would like them. 8 over the house. 9 glasses. 10 And I remember she bought, I He had them all On every table there was reading And that's about it. It was a pretty 11 simple day. 12 Q. Were you paid that day for that work? 13 A. Yes. 14 Q. And how much were you paid? 15 16 17 Do you remember? A. I don't remember how many hours I was there -- I was there. She paid me cash. 18 Q. So Maxwell paid you? 19 A. Yes. 20 Q. And then was she the one who trained you 21 with what -- with respect to what you were supposed 22 to do during the day, directed you to, like you 23 said, go to -- 24 25 A. I believe she was the one that was kind of showing me around. Case 18-2868, Document 283, 08/09/2019, 2628241, Page327 of 883 Page 13 1 2 Q. And how long did you work in that position answering phones and doing -- 3 A. Just that one day. 4 Q. Just that one day. 5 6 And did your duties change? A. Well, the next time she called me, she 7 asked me if I wanted to come over and make $100 an 8 hour rubbing feet. 9 Q. And what did you think of that offer? 10 A. I thought it was fantastic. 11 Q. And did you come over to the house for 12 that purpose? 13 A. Yes. 14 Q. And when you came over to the house, was 15 Maxwell present? 16 A. I don't recall. 17 Q. And what happened that second time you 18 19 came to the house? A. At that point, I met Emmy Taylor, and she 20 took me up to Jeffrey's bathroom and he was present. 21 And her and I both massaged Jeffrey. 22 showing me how to massage. 23 She was And then she -- he took -- he got off the 24 table, she got on the table. She took off her 25 clothes, got on the table, and then he was showing Case 18-2868, Document 283, 08/09/2019, 2628241, Page328 of 883 Page 14 1 me moves that he liked. 2 off. 3 feel it. 4 5 And then I took my clothes They asked me to get on the table so I could Q. Then they both massaged me. So it was more than a foot massage at that point? 6 A. Yeah, it was mostly, like, legs and back. 7 Q. Was everybody in the room without clothes 9 A. When they were on the massage table, yes. 10 Q. Did they -- when they got off the massage 8 on? 11 table to perform the massage, did they dress or 12 did -- 13 A. Yes. 14 Q. They dressed. 15 16 And do you recall who paid you for that first day that you did the massages? 17 A. I don't recall. 18 Q. Do you recall whether Maxwell was at the 19 house during that first day when you were doing the 20 massage with Emmy and Jeffrey? 21 22 23 MS. MENNINGER: answered. BY MS. McCAWLEY: 24 Q. You can answer. 25 A. I don't recall. Objection, asked and Case 18-2868, Document 283, 08/09/2019, 2628241, Page329 of 883 Page 15 1 Q. Who did Emmy work for? 2 A. Ghislaine. 3 Q. Did Maxwell ever refer to Emmy by any 4 particular term? 5 A. She called her her slave. 6 Q. You said your job duties changed. Did you 7 start to travel as part of your job with Jeffrey and 8 Ghislaine? 9 10 11 12 A. Yes. The next time they called me, they asked me to go to New York. Q. And did you -- do you recall when that was approximately? 13 A. That was Easter of 2001. 14 Q. And do you recall who was on the plane 15 with you for that trip? 16 MS. MENNINGER: 17 MS. McCAWLEY: Objection, leading, form. Actually, I'm going to stop 18 really quickly and I'm going to ask for the 19 next exhibit, please. 20 MS. MENNINGER: 21 MS. McCAWLEY: This is 3? Yes. I'm going to mark 22 this as Exhibit 3 for purposes of the 23 deposition. 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page330 of 883 Page 27 1 leading. 2 THE WITNESS: Jeffrey Epstein; Ghislaine 3 Maxwell; AP and PK are the two women I do not 4 recall; Virginia Roberts; and myself. 5 BY MS. McCAWLEY: 6 7 Q. location in the US Virgin Islands? 8 9 A. They put me on a commercial flight. Q. When you say "they," do you recall who made those arrangements for you? 12 A. It could have been Ghislaine. 13 Q. Did you -- do you recall performing 14 I wanted to be home in time for Easter. 10 11 Do you recall how you flew back from the massages while you were in the US Virgin Islands? 15 A. Yes. 16 Q. Who was involved in -- was there more than A. Yes. 17 18 one? I massaged Ghislaine at one point. 19 And I massaged Jeffrey, Virginia and I, both, on the 20 beach. 21 22 Q. Were you dressed during the massage that was on the beach? 23 A. Yes. Bikinis probably, most likely. 24 Q. Do you recall what Virginia was wearing? 25 A. I believe she was wearing a bathing suit, Case 18-2868, Document 283, 08/09/2019, 2628241, Page331 of 883 Page 32 1 to object and then you can still answer. No 2 one is going to stop you from answering. I 3 just need to get the objection on the record, 4 in the same way she needs to be able to talk 5 before you. 6 cut you off, but I am supposed to get it in 7 before you answer. 8 9 10 I'm not trying to BY MS. McCAWLEY: Q. Did Jeffrey ever tell you why he received so many massages from so many different girls? 11 12 My apologies. MS. MENNINGER: Objection, hearsay. BY MS. McCAWLEY: 13 Q. You can answer. 14 A. He explained to me that, in his opinion, 15 he needed to have three orgasms a day. 16 biological, like eating. 17 18 Q. It was And what was your reaction to that statement? 19 A. I thought it was a little crazy. 20 Q. And what did -- do you recall what -- when 21 you observed the other females giving massages, do 22 you recall what they would dress like? 23 wear scrubs or did they typically wear normal 24 clothes? 25 A. Normal clothes. Did they Case 18-2868, Document 283, 08/09/2019, 2628241, Page332 of 883 Page 33 1 2 3 MS. MENNINGER: Objection, leading. BY MS. McCAWLEY: Q. Do you believe that from your 4 observations, Maxwell and Epstein were boyfriend and 5 girlfriend? 6 A. Initially, yes. 7 Q. Did Maxwell ever share with you whether it 8 bothered her that Jeffrey had so many girls around? 9 10 MS. MENNINGER: hearsay. 11 12 Objection, leading, THE WITNESS: No. Actually, the opposite. BY MS. McCAWLEY: 13 Q. What did she say? 14 A. She let me know that she was -- she would 15 not be able to please him as much as he needed and 16 that is why there were other girls around. 17 18 Q. Did there ever come a time -- did you ever take a photography class in school? 19 A. Yes. 20 Q. And did there ever come a time when 21 22 Maxwell offered to buy you a camera? A. 23 24 25 Yes. MS. MENNINGER: Objection, leading. BY MS. McCAWLEY: Q. Did Maxwell ever offer to buy you a Case 18-2868, Document 283, 08/09/2019, 2628241, Page333 of 883 Page 34 1 camera? 2 MS. MENNINGER: 3 THE WITNESS: 4 5 6 Yes. BY MS. McCAWLEY: Q. Was there anything you were supposed to do in order to get the camera? 7 MS. MENNINGER: 8 THE WITNESS: 9 Objection, leading. Objection, leading. I did not know that there were expectations of me to get the camera until 10 after. 11 and I was over there giving Jeffrey a massage. 12 I did not know that she was in possession of 13 the camera until later. 14 She had purchased the camera for me, She told me -- called me after I had left 15 and said, I have the camera for you, but you 16 cannot receive it yet because you came here and 17 didn't finish your job and I had to finish it 18 for you. 19 20 21 22 23 24 25 BY MS. McCAWLEY: Q. And did you -- what did you understand her to mean? A. She was implying that I did not get Jeffrey off, and so she had to do it. Q. And when you say "get Jeffrey off," do you mean bring him to orgasm? Case 18-2868, Document 283, 08/09/2019, 2628241, Page334 of 883 Page 35 1 A. Yes. 2 Q. Did Ghislaine ever describe to you what 3 types of girls Jeffrey liked? 4 A. Model types. 5 Q. Did Ghislaine ever talk to you about how 6 7 8 9 10 11 12 13 14 15 16 you should act around Jeffrey? A. She just had a conversation with me that I should always act grateful. Q. Did Jeffrey ever tell you that he took a girl's virginity? A. He did not tell me. He told a friend of mine. Q. And what do you recall about that? MS. MENNINGER: Objection, hearsay, foundation. THE WITNESS: He wanted to have a friend 17 of mine come out who was cardio-kickboxer 18 instructor. 19 She was a physical trainer. And so I brought her over to the house, 20 and he told my friend Rachel that -- he said, 21 You see that girl over there laying by the 22 pool? 23 her virginity. 24 mortified. 25 She was 19. And he said, I just took And my friend Rachel was Case 18-2868, Document 283, 08/09/2019, 2628241, Page335 of 883 Page 36 1 2 BY MS. McCAWLEY: Q. Based on what you knew, did Maxwell know 3 that the type of massages Jeffrey was getting 4 typically involved sexual acts? 5 6 MS. MENNINGER: leading. 7 8 Objection, foundation, THE WITNESS: Yes. BY MS. McCAWLEY: 9 Q. What was Maxwell's main job with respect 10 to Jeffrey? 11 MS. MENNINGER: 12 THE WITNESS: Objection, foundation. Well, beyond companionship, 13 her job, as it related to me, was to find other 14 girls that would perform massages for him and 15 herself. 16 17 18 19 BY MS. McCAWLEY: Q. Did Maxwell ever refer to the girls in a particular way? A. At one point when we were in the islands, 20 we were all watching a movie and she called us her 21 children. 22 Q. Did anybody respond to that? 23 A. I don't recall. 24 Q. Did she ever refer to herself as a mother? 25 A. Yes, like a mother hen. Case 18-2868, Document 283, 08/09/2019, 2628241, Page336 of 883 Page 64 1 Q. 2 phone calls? 3 A. 4 Do you remember anything notable about the I just remember I always had to say, He's unavailable, can I take a message? 5 Q. And where did you take a message? 6 A. On a little notepad next to the phone. 7 Q. Do you recall any small children calling 8 the house that day? 9 A. No. 10 Q. Were you speaking to anyone about their 11 school experience or anything like that? 12 A. No. 13 Q. Did you take any messages for famous 14 people? 15 A. 16 17 18 They could have been famous and I would have been clueless. Q. Did you take messages at any other point during the time that you worked with Jeffrey? 19 A. No. 20 Q. And you said you remember at the end of 21 that day being paid by Ghislaine? 22 A. Yes. 23 Q. And you were paid for doing the errands 24 25 and answering phones and whatever else you did? A. Yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page337 of 883 Page 82 1 2 Q. When you came upstairs, where was Virginia sitting? 3 A. I don't remember. 4 Q. Do you remember what she was wearing? 5 A. No. 6 Q. She was already there when you got back 7 from sightseeing? 8 A. Yes. 9 Q. Tell me what happened with the caricature. 10 A. Ghislaine asked me to come to a closet. 11 She just said, Come with me. 12 and grabbed the puppet, the puppet of Prince Andrew. 13 And I knew it was Prince Andrew because I had 14 recognized him as a person. 15 was. 16 We went to a closet I didn't know who he And so when I saw the tag that said Prince 17 Andrew, then it clicked. 18 is. 19 I'm like, that's who it And we went down -- back down to the 20 living room, and she brought it in. 21 funny because -- he thought it was funny because it 22 was him. 23 24 25 Q. It was just Tell me how it came to be that there was a picture taken. MS. McCAWLEY: Objection. Case 18-2868, Document 283, 08/09/2019, 2628241, Page338 of 883 Page 83 1 THE WITNESS: I just remember someone 2 suggesting a photo, and they told us to go get 3 on the couch. 4 on the couch, and they put the puppet, the 5 puppet on her lap. And so Andrew and Virginia sat 6 And so then I sat on Andrew's lap, and I 7 believe on my own volition, and they took the 8 puppet's hands and put it on Virginia's breast, 9 and so Andrew put his on mine. 10 11 BY MS. MENNINGER: Q. And this was done in a joking manner? 12 MS. McCAWLEY: 13 THE WITNESS: 14 15 16 Objection. Yes. BY MS. MENNINGER: Q. Do you recall a photo being taken of that event? 17 A. Yes. 18 Q. You've never seen the photo? 19 A. No. 20 Q. You don't know whose camera it was? 21 A. No. 22 Q. Virginia was sitting on the couch next to 23 Andrew, not in a big leather armchair? 24 A. Maybe. 25 remember it. I'm just trying to remember how I Case 18-2868, Document 283, 08/09/2019, 2628241, Page339 of 883 Page 142 1 exposed her bra, and she grabbed it and pulled it 2 down. 3 Q. Anything else? 4 A. That was the conversation that he had told 5 her that he had taken this girl's virginity, the 6 girl by the pool. 7 Q. Okay. Did Maxwell ever say to you that it 8 takes the pressure off of her to have other girls 9 around? 10 A. She implied that, yes. 11 Q. In what way? 12 A. Sexually. 13 Q. And earlier Laura asked you, I believe, if 14 Maxwell ever asked you to perform any sexual acts, 15 and I believe your testimony was no, but then you 16 also previously stated that during the camera 17 incident that Maxwell had talked to you about not 18 finishing the job. 19 Did you understand "not finishing the job" 20 meaning bringing Jeffrey to orgasm? 21 MS. MENNINGER: 22 23 24 25 Objection, leading, form. BY MS. McCAWLEY: Q. I'm sorry, Johanna, let me correct that question. What did you understand Maxwell to mean Case 18-2868, Document 283, 08/09/2019, 2628241, Page340 of 883 Page 143 1 when she said you hadn't finished the job, with 2 respect to the camera? 3 MS. MENNINGER: 4 THE WITNESS: 5 brought him to orgasm. 6 7 Objection, leading, form. She implied that I had not BY MS. McCAWLEY: Q. So is it fair to say that Maxwell expected 8 you to perform sexual acts when you were massaging 9 Jeffrey? 10 11 MS. MENNINGER: Objection, leading, form, foundation. 12 THE WITNESS: 13 Yes, I took that conversation to mean that 14 15 16 I can answer? is what was expected of me. BY MS. McCAWLEY: Q. And then you mentioned, I believe, when 17 you were testifying earlier that Jeffrey told you a 18 story about sex on the plane. 19 MS. MENNINGER: 20 THE WITNESS: What was that about? Objection, hearsay. He told me one time Emmy was 21 sleeping on the plane, and they were getting 22 ready to land. 23 and she thought that meant he wanted a blow 24 job, so she started to unzip his pants, and he 25 said, No, no, no, you just have to be awake for And he went and woke her up, Case 18-2868, Document 283, 08/09/2019, 2628241, Page341 of 883 Page 150 1 A. No. 2 Q. Was it in the context of anything? 3 A. About the camera that she had bought for Q. What did she say in relationship to the 4 5 me. 6 camera that she bought for you and taking 7 photographs of you? 8 9 A. Just that Jeffrey would like to have some photos of me, and she asked me to take photos of 10 myself. 11 Q. What did you say? 12 A. I don't remember saying no, but I never 13 ended up following through. I think I tried once. 14 Q. This was the pre-selfie era, correct? 15 A. Exactly. 16 Q. I want to go back to this: You testified 17 to two things just now with Sigrid that you said 18 were implied to you. 19 A. Okay. 20 Q. The first one was it would take pressure 21 off of Maxwell to have more girls around? 22 A. Right. 23 Q. What exactly did Maxwell say to you that 24 25 led you to believe that was her implication? A. She said she doesn't have the time or Case 18-2868, Document 283, 08/09/2019, 2628241, Page342 of 883 Page 160 1 2 3 C E R T I F I C A T E STATE OF FLORIDA ) : ss 4 COUNTY OF MIAMI-DADE ) 5 I, KELLI ANN WILLIS, a Registered 6 Professional, Certified Realtime Reporter and 7 Notary Public within and for The State of 8 Florida, do hereby certify: 9 That JOHANNA SJOBERG, the witness whose 10 deposition is hereinbefore set forth was duly 11 sworn by me and that such Deposition is a true 12 record of the testimony given by the witness. 13 I further certify that I am not related 14 to any of the parties to this action by blood 15 or marriage, and that I am in no way interested 16 in the outcome of this matter. 17 18 IN WITNESS WHEREOF, I have hereunto set my hand this 18th day of May, 2016. 19 20 __________________________ KELLI ANN WILLIS, RPR, CRR 21 22 23 24 25 Cam: 18-7868, 782, 08/00/7010, 7678741, PagprR nf 882 EXHIBIT 17 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page344 of 883 UNITED STATES DISTRICT COURT for the Southern District of New York Civil Action No. VIRGINIA GIUFFRE, Plaintiff, vs. GHISLAINE MAXWELL, Defendant. Sky Roberts OF: TAKEN BY: Defendant REPORTED BY: Karla Layfield, RMR Stenographic Court Reporter Notary Public State of Florida at Large DATE AND TIME: May 20, 2016; 8:33 a.m. PLACE: Millhorn Law Firm 11294 North US Highway 301 Oxford, Florida APPEARANCES: Laura A. Menninger, Esquire HADDON, MORGAN FOREMAN, PC 150 East 10th Avenue Denver, Colorado 80203 Attorney for Defendant Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, FISTOS LEHRMAN, PL 425 Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Attorney for Plaintiff ALSO PRESENT: Kenneth Sarcony, Videographer Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page345 of 883 Do you remember there being a job posting that you felt like was appropriate for Virginia or did you just go out and talk to the woman who ran the spa area on your own? A I just talked to Angela. Okay. Do you recall whether this was intended to be a full-time job? A I don't remember if it was full time or just summer jobs or, you know, during season. It was probably for a season because Mar-a?Lago is seasonal. I mean, I was there year round but a lot of people are seasonal, you know, because it's like snowbirds, you know, summertime comes and nobody wants to be down in south Florida. What would you call the season, the seasonal aspect of Mar-a-Lago? What's the season? A Probably from September or October to, you know, maybe May, I guess. Is that the coolest time? A Times of the year, yes. And it's more guests that come during that period of time? A Yes. And is there more staff brought on during that period of time? Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 72 Case 18-2868, Document 283, 08/09/2019, 2628241, Page346 of 883 74 we'll call her Angela. A We've got to call her something, but, you know, I didn't really know what her job title was, but I was glad that they would give her a job. Right. A You know, and that, you know, I was hoping she would be happy; that way she could, you know, go back and forth to work with me. She didn't have to drive or nothing. Did you drive to and from work with her? A Yes. Pretty sure I did, yeah. Do you remember her hours being relatively the same as yours? A I'm pretty sure they were. Yes. Do you recall her being in school at the same time? A No, I don't recall. I don't remember if she was in school or not. Is it possible it was over, say, winter break or A I don't remember. I'm sorry. This is so long ago. I mean, some things stick in my mind but some things I just don't remember. Do you remember whether Virginia wore a uniform? A Yes, I think she did. Yeah. I think everybody Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page347 of 883 So you don't know if it was a couple days or a couple weeks or a couple months or a couple years? Anything in that -- A Well, it wasn't a couple years. It might have been two weeks to two months. I don't know. It wasn't a whole long time, you know. Where were you when Virginia told you she might be going to try to get this other job? A Probably at work. She might have told me, like, at lunch or whatever. I don?t remember. That was so many years ago. I just remember she said Ms. Maxwell was going to, you know, get her a job with Jeffrey Epstein and learn massage therapy. And I thought, well, that's great, you know, because learning new jobs is all about life, you know. You've got to learn each -- you know, I've learned a lot of different things over my lifetime so it's good to learn every new job you can because that can help you later in life and that's what I think I told her. Okay. So the best you can recall today is you had a conversation with her sometime at lunch perhaps at Mar-a-Lago where she told you she was going to try to get another job? A Yes. And I thought that was a good thing. Do you know now that you recall that, what Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 8O Case 18-2868, Document 283, 08/09/2019, 2628241, Page348 of 883 A No. Did she ever call you from that home? Not that I know of. Was this when she was still living at home with you on Rackley Road? A A Yes. Yes. Not Rackley Drive. Rackley Road. Do you know whether Michael was living with you at Rackley Road at the time or not? A I don't think so. I don't remember. I didn't care for Michael. Of course, what parent cares for your daughter's boyfriend. A Why didn't you care for Michael? I didn't think anybody was good enough for my daughter but that's just me. I suspect you're right about all fathers. Do you remember her telling you anything about what her job with Mr. Epstein was going to be or was? A training? A She said it was going to be massage therapy. Okay. Did she tell you she was getting some Yes. Did she tell you about the training? No. She just said she was being trained in Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page349 of 883 massage therapy. All right. When she came home at night from working with Mr. Epstein, did she look distressed to you in any way? A Not that I remember. Okay. Did she report any complaints about her job with Mr. Epstein? A Not to me. Okay. Did she report them to anyone else who then reported them to you? A No. Your wife, for example? A I have no idea. Like I said, if she did tell my wife, I never heard about it. Okay. Have you ever met Ms. Maxwell? A Not that I remember ever meeting her. Do you know what she looks like? A No. Did you ever meet anyone else who worked with Mr. Epstein? A No. Do you remember anyone else who worked for Mr. Epstein bringing your daughter home, for example? A No. Did your daughter ever move into the home where Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 85 Case 18-2868, Document 283, 08/09/2019, 2628241, Page350 of 883 134 Okay. But your hours, if I understood you right, were approximately 7:00 a.m. to 3:00 A Yes. And Tuesday through Saturday? A Yes. Those hours would be the same time as somebody her age would have been in high school? A Yes. Okay. So does that -- does that give an indication to you that the short period of time she was working was during the summer when there was not school? A It seems to be that way. Okay. A I mean, to me, yeah. It could have been a summer job? A Yes, it could have been. Okay. You would not have, as a father, had her working somewhere instead of going to school? A No, I wouldn't. And the day that Virginia came and spoke to you about meeting someone named Ms. Maxwell who was offering her another job, do you remember the conversation that you had with Virginia on that day? A No, not really. I just remember Virginia saying that, you know, she met Ms. Maxwell at the spa and that Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page351 of 883 138 And there it describes her job at Mar?a?Lago as lasting from August 2000 to September of 2001. Do you see that? A Yes. Does that refresh your memory about how long she was working there? MR. EDWARDS: Form. THE WITNESS: She didn't work that long. MS. MENNINGER: Okay. THE WITNESS: Like I say, it was more, like, a couple of weeks. It wasn't BY MS. MENNINGER: Well, earlier you testified it, might have been a couple of months? A Well, you know, for me, two weeks, two months, I mean, I don't even remember how long I worked at Mar?a?Lago. I told you I worked there six years and according to them, it was, like, three years. Seemed like six. Well, earlier you testified that Mar?a?Lago was more of a seasonal place, correct? A Yes, well, it is seasonal. But I mean, they could be open up the spa area during the summer too because I'm sure a lot of people in Palm Beach come to get massages and things like that. I mean, you know, the only Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page352 of 883 part they close off is where the chefs and all that, where they didn't do any more big events and stuff. Okay. A But I think the kitchen was still open. I mean, they had a dining room. So if she didn't work there that long August 2000 even though August is in the summer it would not be unusual in your mind? A No. Okay. So she could have started working in August of 2000, correct? A She could have, yeah. And while you don't think she worked all the way until September of 2001 A No. -- that would be consistent with your recollection of it being more seasonal in the fall, September -- MR. EDWARDS: Object to the form. THE WITNESS: Yes. BY MS. MENNINGER: So if she worked in the fall, September, October, something like that, that seems likes that accords with your memory, correct? MR. EDWARDS: Object to the form. Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 139 Case 18-2868, Document 283, 08/09/2019, 2628241, Page353 of 883 I I A STATE OF FLORIDA COUNTY OF MARION I, Karla Layfield, RMR, Stenographic Court Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing deposition of Sky Roberts; that said witness was duly sworn to testify truthfully; and that the foregoing pages, numbered 1 through 142, inclusive, constitute a true and correct record of the testimony given by said witness to the best of my ability. I FURTHER CERTIFY that I am not a relative or employee or attorney or counsel of any of the parties hereto, nor a relative or employee of such attorney or counsel, nor am I financially interested in the action. WITNESS MY HAND this day of May, 2016, at Ocala, Marion County, Florida. Karla Layfield, RMR Stenographic Court Reporter Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 143 Cam: 18-7868, 782, 08/00/7010, 7678741, Pagpg?d nf 882 EXHIBIT 18 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page355 of 883 (551) 832-7500 Electronically signed by Sandra Townsend (401-377-676-2895) Electronicallv sinned bv Sandra Townsend (401-377-676-28951 Page 1 Page 3 SOUTHERN DISTRICT OF FLORIDA CASE ON 2 ROBERT CRITTON, ESQUIRE BURMAN, CRITTON LUTTIER JANE DOE N0 2: 3 515 North Flagler Drive, Suite 400 Plaintiff: West Palm Beach, Florida 33401 -vs- 4 Phone: 561.842.2820 JEFFREY EPSTEIN rcrit@belclaw.com 5 Defendant. 6 Related cases: 7 08-80232, 08-803 80, 98-80381, 08-80994, 8 08-80993, 08-80811, 08-80893, 09-80469, 9 09-80591, 09-80656, 09-80802, 09-81092 1 1 1 VIDEOTAPED DEPOSITION OF JUAN ALESSI 1 2 VOLUME I 1 3 Tuesday, September 8, 2009 1 4 10:12 a.1n.- 3:45 p.111. 1 5 1 6 2139 Palm Beach Lakes Boulevard 1 7 West Palm Beach, Florida 33401 1 8 1 9 2 0 Reported By: 2 1 Sandra W. Townsend, FPR Notary Public, State of Florida 2 2 PROSE COURT REPORTING AGENCY 2 3 West Palm Beach Of?ce 2 4 2 5 Page 2 Page 4 1 APPEARANCES: 1 2 On behalf of the Plaintiffs: 3 RICHARD WILLITS, ESQUIRE 2 I I RICHARD H. WILLITS, PA. 3 4 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 4 5 Phone: 561-582-7600 NUMBER DESCRIPTION PAGE ieelrhw@hotrnail.com 5 6 7 STUART NIERMELSTEIN, ESQUIRE - - MERNIELSTEIN HORGWITZ, PA. 6 number 1 Photographs 45 8 18205 Biscayne Boulevard, Suite 2218 7 Exhiblt number 2 Transcript 130 Miami, Florida 33160 - - - 9 Phone: 305.931.2200 8 Exhibit number 3 Incrdent Report 137 9 Exhibit number 4 Inc orporation Papers 149 1 a orowitz msexa useattorne .corn - - - 1 1 BERGER, ESSUIRE 1 0 Exhibit number 5 Incorporation Papers 150 ROTHSTEIN ROSENFELDT ADLER 1 12 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 3330l 1- 2 13 Phone: 954.522.3456 KATHERINE W. EZELL, ESQUIRE 5 PODHURST ORSECK, PA. 16 25 West Flagler Street, Suite 800 6 Miami, Florida 33130 1 '7 17 Phone: 305.358.2800 ijosefsberg@podhurst.com 1? 8 1 8 kezell@podhurst.eom 1 9 1 9 ADAM .I. LANSING, ESQUIRE LEOPOLD KUVIN 2 0 2 0 2925 PGA Boulevard, Suite 200 2 1 Palm Beach Gardens, Florida 33410 21 Phone: 551.515.1400 22 ?i 1 to 4) PROSE COURT REPORTING AGENCY, INC. (551) 832-7506 Case 18-2868, Document 283, 08/09/2019, 2628241, Page356 of 883 Page 45 Page 47 1 MS. EZELL: I'm going to ask -- I don't know 1 THE WITNESS: Could have been. But, you know 2 whether you've been seriaiiy designating 2 I am not -- I don't think I am a very good judge of 3 3 4 deposition. 4 couldn?t tell you. 5 MR. CRITTON: I think we cannot trust that 5 MR. CRITTON: Kathy thinks she?s 25. 6 peopie will do them serialiy. I'd do them with 6 MS. EZELL: in my dreams. 7 each one. 7 THE WITNESS: Now, again, I must tell you, I 8 MS. EZELL: Then would you mark this, please, 8 was never told to check any i.dExhibit 1 to this deposition. 9 people who work at the house. 10 And I'm just going to state on the record that 1 0 BY MS. EZELL: 1 1 I will keep that original. We wiil not attach it 1 1 Q. 1 understand that. And, so, I think I'm just 12 to the deposition. 1 2 trying to establish that you didn't consider it part of 13 (Exhibit number i was marked for 1 3 your job description to worry about or consider the 1 4 identi?cation purposes and retained by Counsei for the 1 4 ages -- 1 5 PlaintiffsTHE WITNESS: Yes, thatthe young women that came there? 17 BY MS. EZELL: 1 7 A. Absolutely not. Absolutely not. 18 Q. Can you identify that -- the young woman in 1 8 Q. And, so, you never really focused on that or 1 9 those pictures? 1 9 particularly thought about it if they seemed young? 20 A. Yes. 2 0 MR. CRITTON: FormTHE WITNESS: I don't -- I didn't see that 22 A. That's V. -- V. Now that you says R., that 2 2 many young girls, you know, young, underage girls 2 3 is V.R. de?nite, a hundred percent. 2 3 at the house. I never saw except the two girls 2 4 MR. CRITTON: Let me just note my objection, 2 4 that i mentioned that I think it was underage was 25 as I did in A. Rod's deposition or Mr. Rodriguez's 2 5 N. for sure because she was still in high school. Page 46 Page 48 1 deposition, that I know you're going to con?scate 1 And she she had dinner with her mother, a couple 2 Exhibit number 1. I think it's inappropriate. I 2 times with her mother. And she become an actress. 3 think I should be ailowed to have a copy of 3 She's an actress and she has done movies. And he 4 Exhibits that are being used in deposition. But 4 help her in her career. 5 I'll ?le a motion with the Court so we don't get 5 That's the only girl that I knew she was young 6 into a pulling match over your Exhibits. 6 because she was going to high school and I pick her 7 MR. BERGER: I wouid ask that the court 7 up from high school sometimesreporter initial that. 8 massage therapist. She wiil go for dinner. And 9 MS. EZELL: Sure. 9 they wiil go for the movies and she sang sometimes 10 Oh, you did? 10 because she was a singer. So she sung at the 1 1 MR. WILLITS: She marked it. 11 house. Beautiful girl. Very talented. 12 MR. BERGER: Did she put her initiais or did 12 That's the only girl that I know that it 1 3 she just put a number or a Ietter? 1 3 was i would says, underage. 14 MR. CRITTON: She's nodding that she did 14 BY MS. EZELL: 15 everything that she usually does, which means, 15 Q. Okay. Did -- who toid you that V.R. was a 1 6 initiais, date and number. 1 6 massage therapist? 17 MR. MERMELSTEIN: You can taik. 17 A. Nobody. 18 MR. WILLITS: But when you talk, use your 18 Q. Did you assume that she was a massage 1 9 initials. 1 9 therapist because you were told she was coming to give 2 0 BY MS. EZELL: 2 0 massage? 2 1 Q. How old did you think V.R. was at the time she 2 1 A. No. I assumed she was a massage therapy 2 2 began coming to Mr. Epstein?s home? 22 because I was I drove Ms. Maxweil to Mar?a-lago, 2 3 A. She could have been 17, 18, I9. 2 3 Donald Trump's residence. And I wait in the car while Q. Could she have also been 15? 24 Ms. Maxweli got a I think it was a facial or massage. 25 12 (Pages 45 to 48) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Eiectronically signed by Sandra Townsend (401-377-676-2895) Eiectronicaliv sinned bv Sandra Townsend (401-377-676-2895i Case 18-2868, Document 283, 08/09/2019, 2628241, Page357 of 883 Page 49 Page 51 1 walking down from the main lobby towards the spa of 1 there. So I would says, between three months maybe 2 Mar-a-lago. And I was driving Ms. Maxwell up, up the 2 before I left. And I think I left at the end of the 3 ramp. It?s a little ramp there. 3 year, so it could have been -- I remember it was a very 4 And Ms. Maxwell says, stop. And she went and 4 hard day because I had to wait in the sun outside in a 5 talked to she went inside. 5 convertible and I was dying, waiting for an hour for 6 And that afternoon around 5:00 I saw V. came. 6 Ms. Maxwell. I think it was in the summer of 2002. 7 She came to the house already, so she was there already. 7 Q. And if I remember correctly, you left in 8 That was the first day I knew. And then she would comc 8 November or December of 2002? 9 regularly. 9 A. Yes. 1 Q. Did you ever meet any of V.'s family? 1 0 Q. So that might have been perhaps July or August 1 1 A. No. I think she was one time I think her 1 1 of 2002? 12 father drove her there. And I met I don't know if it 12 A. Uh-huh. 1 3 was the boyfriend or husband or but he had to wait, 1 3 Q. And, so, as I understand it, you only saw V.R. 1 4 make him wait outside while she was at the house. 1 4 come to that house during the last three months of your 1 5 Q. Do you know the name or recognize the name 1 5 time at Mr. Epstein?s? 1 6 Tony Santiago? 1 6 A. Yes. 1 7 A. I think it was him. 1 7 Q. Do you have any -- any sense or can you 1 8 Q. That was her 1 8 approximate how many times she came? 1 9 A. I know he had an old beat-up car, Camaro or 1 9 A. I cannot give you a number, but I would says, 2 0 Mustang. I know it was very old car that I make him 2 0 two, three times a week. 2 1 wait on the street one time. I make him come out of the 2 1 Q. You mentioned that sometimes you would have to 2 2 driveway because we have to move some cars around. 22 call these massage therapists in the middle of the 2 3 Q. Did there ever come a time when Tony Santiago 2 3 night. Did you ever have to call V. for Mr. Epstein in 2 4 was welcome in the kitchen? 2 4 the middle of the night? 2 5 A. I think he came once in the kitchen, but 2 5 MR. CRITTON: Form. Page 50 Page 52 1 Ms. Maxwell told me to get him out. 1 THE WITNESS: No. No. 2 Q. Did she tell you why? 2 BY MS. EZELL: 3 A. No. She didn't -- I guess she didn't want to 3 Q. Did there come a time while you were there 4 become, you know, everybody -- because some of these 4 that V.R. stayed in the house? 5 people came with their husbands and they wait outside. 5 MR. CRITTON: Form. 6 And I guess she didn't want this to become a norm for 6 THE WITNESS: I don't think so. I cannot 7 everybody to bring their companions while they have -- 7 remember. No. 8 they will do a massage for her. 8 BY MS. EZELL: 9 Q. During the time you were there, did you ever 9 Q. How many bedrooms were there upstairs? 1 0 know of Tony Santiago bringing any other girls to 1 0 A. One, two, three -- one, two, three, four -- 1 1 Mr. Epstein? 1 1 four -- so that would be five, ?ve bedrooms. 12 A. No. I knew that sometimes I saw V. bring 12 Q. Five. And, so, would one have been 1 3 other girls with her, not Tony Santiago. 1 3 Mr. Epstein's bedroom? 1 4 Q. Do you remember the names of any of those 1 4 A. Yes. His quarters was big, huge quarters. 15 girls -- 1 5 Q. Sort of a suite? 1 6 A. No, I don't. 1 6 A. Yeah. And he has -- this is the room. His 1 7 Q. -- that V. brought? 1 7 bathroom was here and her bathroom was here. The ma 1 8 A. That was at the end of my stay there. No. 1 8 room was here. And we have -- it was two sets of doors 1 9 That was a very -- at the very end of the last month of 1 9 before -- two sets of double doors before you can go 2 0 my stay. 2 0 into the suite. There was one on top of the stairway 2 1 Q. Did you give -- I don't believe I asked you, 2 1 and one in the middle of the hallway. And then you walk 2 2 but if I did, forgive me. Did you give us an 2 2 into the -- into the suite. 2 3 approximate year in which you were taking Ms. Maxwell to 2 3 Q. Okay. And you -- you just put a red eight by 2 4 Mar-a-lago and saw V.R. for the first time? 2 4 11 folder in front of you? 2 5 A. That was stay 2 5 A. Yeah. 13 (Pages 49 to 52) (561) 832-7500 Eiectronically signed by Sandra Townsend (401-377-676-2895) Electronicallv sinned bv Sandra Townsend (401-377-676-2895) PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Case 18-2868, Document 283, 08/09/2019, 2628241, Page358 of 883 Page 57 Page 59 1 A. Yes. Before she was married, yeah. They 1 Q. And they caiied him uncle, you said? 2 spiit up and she went her own way. 2 A. They called him uncie. 3 Q. Did she marry a Glen Dubin (phonetics)? 3 Q. Did you ever ieam what Tony Santiago did for 4 A. That's correct. And Mr. Dubin used to come to 4 a iiving? the house, too. 5 A- NO- 6 Do you know, was Sarah Keiien ever one of the 6 Q. Have you had any occasion to see him since the 7 massage therapists before she became an assistant? 7 time you left Mr. Epstein's employ? 8 A. I don?t know if she was a massage therapist. 8 A. No. 9 I don't remember setting up a massage table for her. I 9 Q. And you don't do you have any idea where stay, I was -- tried to pull aside from my 1 1 A. have no idea. i remember an incident, one 12 obligations and Sarah was doing all the phone calls and 1 2 time the I went to pick her up at Royal Paim Beach 1 3 all the arrangement and all the looking out for these 1 3 and she was crying and I went and knock at the door an 14 girls for the -- for massage therapists. They were 1 4 she was crying. And she says, well, i think it was i 5 constantly. 1 5 Tony or because she used to live with these other 1 6 Q. When did that role get transferred from you to 1 6 guys, too. There were two guys and her or two coupie 7 Ms. Maxweil, the role of looking after girls and calling 1 7 I don't know the arrangements there. But I remember 1 8 the girls? 1 8 that she toid me the Tony or her boyfriend had got 1 9 A. I didn?t look after -- out for giris. 1 9 mad and ripped the furniture, he cut the furniture in 2 0 Ms. Maxweil was the one that recruit -- I remember one 2 0 pieces and he even broke the screens. Because i was 2 occasion or two occasions she would says to me, John, 2 1 when I went into to knock the door, the screen was all 2 2 give me a iist of all the spas in Paim Beach County. 2 2 ripped up like it was cut. 2 3 And I wiil drive her from one to the other one to PGA 2 3 And she told me that he got mad at -- i don?t 2 4 and Boca. And She will go in, drop credit cards -- not 2 4 know what happened. i never saw him in there. 2 5 credit cards, but business cards, and she come out. And 2 Q. Did she tell you he had hit her or beaten her ., Page 58 Page 60 1 then we go to -- she will recruit the giris. Was 1 at ali? 2 never never done by me or Mr. Epstein or anybody 2 MR. CRETTON: is the she, V., 3 eise, that i know. 3 MS. EZELL: Yes. Thank you. 4 I don't know about Sarah because Sarah was 4 BY MS. EZELL: 5 there at the last, iast probabiy last weeks of my 5 Q. Did you ever see during the time you were 6 stay there. So i cannot say anything about Sarah. 6 there photographs of V. in the house, the Epstein house 7 Q. Was there any point in time -- weii, let me 7 YR. in the Epstein house? 8 ask you this way: Did you said sometimes you woulc 8 A. I don't think so. 1 don't think so. 9 caii the giris to come 9 Q. Did you ever see photographs of V.R. in 1 A. Uh?huh. 10 Ms. Maxweli's albums? 1 1 Q. to give them massage. And sometimes 1 1 A. No. 12 Ms. Maxwell would? 12 Q. At the time you were employed by Mr. Epstein, 1 3 A. Yeah. 1 3 were there any hidden cameras? 17 1 4 Q. Did there come a time when she took that over 1 4 A. No. 1 5 entirely from you 1 5 Q. You do know that he installed some after you 1 6 A. No. 1 6 left, correct? 1 7 Q. or that continued -- 1 7 MR. CRITTON: Correct. 1 8 A. That?s continued. 1 8 THE WITNESS: I don?t know. 1 9 Q. until you ieft? 1 9 BY MS. EZELL: 2 A. Yeah. 2 Q. Wasn't there a camera involved in the incident 2 1 Q. Do you remember, is Jeffrey Epstein godfather 2 1 that -- the incident in which you took money from 2 2 to one of the Dubin chiidren? 2 2 Mr. Epstein? 2 3 A. I don't know if he godfather. I don?t 2 3 A. Yeah. Yes. But I don't know if he install it 2 4 remember that. But he was very fond to these chiidren, 2 4 or not. That's what he toid me. 2 5 the chiidren. 2 5 Q. Okay. 15 (Pages 57 to 60) (561) 832-7500 Eiectronically signed by Sandra Townsend (401-377-676-2895) Eiectronicallv sinned bv Sandra Townsend PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Case 18-2868, Document 283, 08/09/2019, 2628241, Page359 of 883 Page 77 Page 79 1 Q. What kind of costume? 1 CERTEFICATE OF OATH I 2 A. I don't know. It was a black, shiny costume. 2 STATE OF FLORIDA 3 I never saw it on her. 3 COUNTY OF PALM BEACH 4 Q. Was it leather? 2 5 Tk 'l.Viny we were 6 I, the under51gned authorlty, that 6 yer fuss about touchrn an of that stuff We ust 3 7 1U AN ALESSI personally appeared before me and was dul 7 MS. EZELL: No other questions. Thank you, 8 sworn on the 8th day of September, 2009 8 sir. 9 9 THE WITNESS: You're welcome. 10 Dated this l9th day of September, 2009. 1 0 MR. LANGINO: I shouldn't have more than a 1 1 1 1 half hour?s worth of questions, if everybody is 12 1 2 okay to power through. i: 1 3 MR. BERGER: I probably have a half hour to an 1 4 hourLANGINO: Okay. Sandra W. Townsend, Court R?porter 1 6 MR. BERGER: Unless you cover what I cover. 1 6 Notary Public State Of Florida 1 7 MR. MERMELSTEIN: I could say the same thing, My Commission Expires: 6/26/12 1 8 so probably less than that. 1 7 My Commission No; DD 793913 1 9 MR. LANGINO: So I guess my question is -- 18 2 0 MR. BERGER: I think we ought to take a break. 1 9 2 1 MR. LANGINO: That was my question. :3 2 2 MR. BERGER: We?re going to take a break. 2 2 2 3 Do you have any problem with that? 2 3 2 4 THE WITNESS: No. Whatever you guys want Page 78 Page 80 1 I I A (LUUCTI recess) 2 STATE OF FLORIDA 2 (Continued to Volume II.) 3 COUNTY or PALM BEACH 4 3 5 1, Sandra W. Townsend, Court Reporter and 4 Notary Pubiic in and for the State of Florida at Large, 5 6 do hereby certify that the aforementioned witness was by me first duly sworn to testify the whole truth; that I 6 7 was authorized to and did report said deposition in stenotype; and that the foregoing pages numbered 1 to 7 8 78, inciusive, are a true and correct transcription of 8 my shorthand notes of said deposition. 9 9 I further certify that said deposition was 1 1 0 taken at the time and piace hereinabove set forth and that the taking of said deposition was commenced and 11 completed as hereinabove set out. 1 2 12 I further certify that I am not attorney or counsei of any of the parties, nor am I a reiative or 1 3 13 employee of any attorney or counsel of party connected 1 4 with the action, nor am I financiaiiy interested in the 1 4 action. 1 5 1 5 The foregoing certification of this transcript 6 does not appiy to any reproduction of the same by any 1 7 1 6 means unless under the direct controi and-"or direction of the certifying reporterDated this 19th day of September, 2009. 2 19 2 21 ?nanammnm 2 2 2 1 2 3 Sandra W. Townsend, Court Reporter 22 2 4 23 (II (561) 832-7500 Eiectronically signed by Sandra Townsend (401-377-676-2895) Eiectronicallv sinned bv Sandra Townsend (401-377-676-28951 PROSE COURT REPORTING AGENCY, 20 (Pages 77 to 80) (561) INC. 832-7506 Case 18-2868, Document 283, 08/09/2019, 2628241, Page360 of 883 Page 212- 1 i Q. ?m would be the young one? 2 A. Yeah. 3 Q. You stated that Ms. Maxwell was very hard on 4 you and you got blamed for everything, and that you 5 you liked the job and you liked Mr. Epstein, but you 6 didn't like working for Mrs. Maxwell? 7 A. That?s correct. 8 Q. Can you tell me why, other than that she 9 blamed you for everything? 10 A. She came from a very wealthy family and she 11 was mm just my opinion; I give my personal opinion 12 that she was rotten spoiled and she tried to drive the 13 house like a palace and not a home. 14 I was "m I discussed it with her, many, many 15 times we have discussions. And sometimes I even refuse 16 to do her orders, knowing that I was going to be backed 17 up by Mr. Epstein or do the right thing, my thinking of 18 running the house should be. But we never had a good 19 ?Erelationship at all from the beginning, I don't think-NIH]; 20 so. But I was have to be her driver and she will go 21 and shop all over the malls and I will have to go behind 22 her, pay for it and bring the bags to the car. 23 Next day or the same day she will do shopping 24 and buy and say, John, go to this store and get itwork. It was a lot that she created and NNONN l" Electronically signed by Sandra Townsend (401?377-676-2895) Electronically signed by Sandra Townsend (401-377-6Y6-2895) Case 18-2868, Document 283, 08/09/2019, 2628241, Page361 of 883 Page 213 i 1 - most of this jobs that she created. 2 Q. And one of those things you also had to do 3 with her was to take her to different spas? 4 A. Yes. 5 Q. And there she would recruit young women to 6 come and do massages? 7 A. Because she was English. And she didn't know 8 the area too much as well as I knew. So she she 9 says, John, make a list of all the massage we the spas 10 in the area from Jupiter to Boca Raton. And we went to 11 all the main spas. And then we went to the schools for 12 massage therapists, and all the massage parlors, and 13 massage, the small massage. 14 So I make a list from the telephone book and 15 we would go from one to the another one. 1 would wait 16 in the car and she goes in. 17 And sometime she took a couple minutes and 18 walk out with cards, business cards. And that mm she 718773 'Hdid the recruiting. 20 And from then, she pick up the girls and that never did any recruiting and I 22 never really saw him doing it. 23 Q. You really never saw? 24 A. Never saw Mr. Epstein recruiting anybody. 25 MS. EZELL: All right. I have no other ram, ?ma; 3 (561) 832-7506 Electronically signed by Sandra Townsend (401-377?676-2895) Electronically signed by Sandra Townsend (401-377-676?2895) Cam: 18-7868, 782, 08/00/7010, 7678741, nf 882 EXHIBIT 19 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page363 of 883 Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO:502008CA028051XXXXMB AB L.M. Plaintiff, -vsJEFFREY EPSTEIN AND SARAH KELLEN, Defendants. ______________________________/ DEPOSITION OF JANUSZ BANASIAK Tuesday, February 16, 2010 10:09 - 2:30 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1317 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004424 Case 18-2868, Document 283, 08/09/2019, 2628241, Page364 of 883 Page 8 1 Q. What family was that? 2 A. It's, it was an older house in New York. I 3 worked there for seven years, no, five years before I 4 get the job in the Seagram company. 5 some experience to continue. 6 7 Q. So, I guess I had Do you remember the name of the family that you worked with for seven years in New York? 8 A. Frank, Frank. 9 Q. His name is something Frank, F-r-a-n-k? 10 A. Yes. 11 Q. Do you remember the first name? 12 A. Fredrick. 13 Q. And were your duties as house manager for 14 Fredrick Frank similar to your duties as house 15 manager for Jeffrey Epstein? 16 A. Yes, yes. 17 Q. And when you started in 2005 when you 18 heard that there was a job position with Jeffrey 19 Epstein, did you interview for that position? 20 A. Yes. 21 Q. Who did you interview with? 22 A. First I got interviewed with Ghislaine 23 Maxwell. 24 Q. And that's G-h-i-s-l-a-i-n-e, Maxwell? 25 A. Right, right. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004431 Case 18-2868, Document 283, 08/09/2019, 2628241, Page365 of 883 Page 9 1 Q. Where did that interview take place? 2 A. In New York. 3 Q. And it was for the position as house 4 manager in the Palm Beach house, correct? 5 A. Right. 6 Q. That's at 358 Albrillo way? 7 A. Correct. 8 Q. Why were you interviewed in New York, if 9 you know? 10 11 A. with my friends and so -- 12 13 Because at that time I was living in New York Q. Where did the interview take place in New York? 14 A. In her house on 65th Street. 15 Q. Whose house, do you know? 16 A. Ghislaine Maxwell. 17 Q. So, Ghislaine Maxwell interviewed you back 18 in 2005 at her house in New York for a position at 19 Jeffrey Epstein's house in Palm Beach? 20 A. Right. 21 Q. And what did the interview consist of? 22 What did she ask you? 23 A. She asked me basic questions, you know, what's 24 my previous employer, how long I work for them and 25 basically she was checking my resume. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004432 Case 18-2868, Document 283, 08/09/2019, 2628241, Page366 of 883 Page 14 1 Q. Okay. So, I assume then that your wife 2 that you are separated from I guess at the time, she 3 didn't come down to Palm Beach? 4 A. No, no. 5 Q. And this is somebody who still lives 6 somewhere other than Florida? 7 A. Correct. 8 Q. So, you came down in February 2005 and 9 10 began working. start doing for Jeffrey Epstein? 11 12 What did you, what did you first A. First I doing? I don't remember nothing special. 13 Q. 14 rephrase it. 15 Epstein or were you working also for Ghislaine 16 Maxwell, the other person who interviewed you, or 17 anybody else in the house? 18 19 A. Okay. Well, were you working -- I will Were you working only for Jeffrey I guess only for him because she was visiting a few times house, but I am employed by him. 20 Q. Okay. What was your understanding at that 21 time as to the relationship between Ghislaine 22 Maxwell and Jeffrey Epstein? 23 A. They were like partners in business. 24 Q. Okay. 25 What business was that, if you know? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004437 Case 18-2868, Document 283, 08/09/2019, 2628241, Page367 of 883 Page 15 1 A. I don't know what kind of business but she was 2 the one who organized I would say employment with this 3 organization. 4 of problem, I contact her. 5 what I have to answer my problems with, what I was 6 supposed to do. 7 8 Q. So, whatever I need, if I have some kind She was the one who decided How many times did you have problems where you had to go through her? 9 A. Well, not big problems. Just a question of 10 what certain, how to do certain things. 11 what kind of flowers I have to buy, what kind of things 12 he likes, what time I supposed to serve him coffee in 13 the mornings, sort of organizing things. 14 15 Q. For example, Those are things that you wouldn't ask Jeffrey Epstein directly? 16 A. No, no. He doesn't like those things to ask 17 him directly. 18 his assistant or like I say, Ghislaine Maxwell. He would like to prefer either through 19 Q. Is that still the same today? 20 A. Yes, still the same. Unless, something happen 21 that I need to, nobody is around and I need to urgently 22 contact him, I go to him directly. 23 Q. So, for the most part if you have a 24 question or at least -- let's go back to 2005, you 25 had a question about what needed to be done in the (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004438 Case 18-2868, Document 283, 08/09/2019, 2628241, Page368 of 883 Page 54 1 A. (Witness shakes head.) 2 Q. And I'm sorry. 3 A. No. 4 Q. I understood you when you shook your head. 5 A. I realize what you told me but I am sorry. 6 Q. I told you it was easy to forget. 7 Do you remember who it was that personally 8 removed the computers and equipment from the 9 property? 10 Was it Mr. Epstein, was it a lawyer, was it, do you remember? 11 A. It was Adriana. 12 Q. All right. And I am of the understanding 13 that there were several computers that were removed 14 from the house, correct? 15 MR. GOLDBERGER: 16 THE WITNESS: 17 Yes, three of them. BY MR. EDWARDS: 18 19 Form. Q. Three? And to your knowledge Adriana removed all of them? 20 A. She show up one day with gentleman. 21 remember his name. 22 out those computers. 23 Q. I don't And she told me that they are moving And where were the computers? Which rooms 24 were the computers in that were removed by Adriana 25 and this gentleman you're describing? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004477 Case 18-2868, Document 283, 08/09/2019, 2628241, Page369 of 883 Page 191 1 CERTIFICATE OF OATH 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 6 I, the undersigned authority, certify that 7 JANUSZ BANASIAK personally appeared before me 8 and was duly sworn on the 16th day of February, 9 2010. 10 11 Dated this 28th day of February, 2010. 12 13 14 15 _________________________________ 16 17 18 Cynthia Hopkins, RPR, FPR Notary Public - State of Florida My Commission Expires: February 25, 2011 My Commission No.: DD 643788 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004614 Case 18-2868, Document 283, 08/09/2019, 2628241, Page370 of 883 Page 192 1 C E R T I F I C A T E 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 6 7 8 9 10 I, Cynthia Hopkins, Registered Professional Reporter, Florida Professional Reporter and Notary Public in and for the State of Florida at large, do hereby certify that I was authorized to and did report said deposition in stenotype; and that the foregoing pages are a true and correct transcription of my shorthand notes of said deposition. I further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out. 11 12 13 I further certify that I am not attorney or counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party connected with the action, nor am I financially interested in the action. 14 15 16 The foregoing certification of this transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter. 17 Dated this 28th day of February, 2010. 18 19 20 21 _____________________________________ Cynthia Hopkins, RPR, FPR 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004615 Cam: 18-7868, 782, 08/09/7010, 7678741, Pag9271 nf 882 EXHIBIT 20 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page372 of 883 0?1 - 2378; Condensed Transcript IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION L.M., Plaintiff, vs. CASE No. AB JEFFREY EPSTEIN, Defendant. DEPOSITION 0F LOUELLA RABUYO VOLUME I October, 20, 2009 10: 10 am. 515 N. Flagler Drive Suite West Palm Beach, Florida 33401 Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard IRE Palm Beach Gardens, FL 33410 an Alexander Gallo Company GIUFFRE004386 Case 18-2868, Document 283, 08/09/2019, 2628241, Page373 of 883 Louella Rabuyo Volume I October 20, 2009 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE AB L.M., APPEARANCES: On behalf of the Defendant: ROBERT D. JR., ESQUIRE Plaintiff, 4 BURMAN CRITTON LUTTIER 8: COLEMAN, LLP 303 Banyan Boulevard, Suite 400 5 West Palm Beach, Florida 33401 JEFFREY Phone: 561.842.2820 Defendant . 6 7 On behalf of Plaintiff L.M.: 8 BRADLEY J. EDWARDS, ESQUIRE DEPOSITION OF LOUELLA RABUYO CARA L. HOLMES, ESQUIRE VOLUME I 9 ROTHSTEIN ROSENFELDT ADLER Tuesday, October, 20, 2009 401 E. Las Olas Boulevard, Suite 1650 10:10 3:30 p.m. 10 Fort Lauderdale, Florida 33394 Phone: 954.522.3456 . 11 515 Flagler Drive' Elite 12 On behalf of the Witness: West Palm Beach, Florlda 33401 13 BRUCE E. REINHART, ESQUIRE LAW OFFICE OF BRUCE E. REINHART Raported By: 14 250 S. Australian Avenue, Suite 1400 geiesa ghzi?n: ng? Fl ,d West Palm Beach, Florida 33401 ary U. 10, a 0 01:1 51 . West: Palm Beach Office Job #118991 1: Phone' 5612026360 17 On behalf of Defendants/Jane Does 2 8: 18 STUART S. MERMELSTEIN, ESOUIRE MERMELSTEIN HOROWITZ, PA. 19 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 20 Phone: 305.931.2200 21 On behalf of Plaintiff in related Case No. 08-80811 22 JACK HILL, ESQUIRE (Partially via speakerphone) SEARCY, DENNEY, SCAROLA, BARNHART SHIPLEY 23 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 24 Phone: 561.686.6300 25 2 4 1 UNITED STATES DISTRICT COURT 1 - - - SOUTHERN DISTRICT OF FLORIDA 2 2 CASE 3 3 4 4 JANE DOE NO. 2, 5 5 WITNESS: DIRECT CROSS REDIRECT RECROSS Plaintiff, 6 6 -vs- 7 JEFFREY EPSTEIN, LOUELLA RABUYO 8 Defendant. 7 . 9 Related cases: 8 BY MR. EDWARDS. 5 190 08-80232, 08-80380, 98-80381, 08-80994. 9 BY MR. MERMELSTEIN: 135 208 10 08-80993, 08-80811, 08-80893, 09-80469, . 09?30591, 09-80656, 09-80802, 09?81092 DEPOSITION OF LOUELLA RABUYO 12 13 VOLUMEI 13 . . . 14 I Tuesday, October 20, 2009 14 15 10:10-3:Fla ler Drive, Suite 200-P 17 17 NUMBER DESCRIPTION PAGE West Palm Beach. Florida 33401 18 EX. 1 COPIES, COMPOSITE PHOTOGRAPHS 103 18 19 19 EX, 2 COMPOSITE PHONE MESSAGE BOOK 147 20 20 EX. 3 COPY OF PHOTOGRAPH 162 21 Reported By: 21 Teresa Whalen, RPR, FPR 22 Notary Public, State of Florida 22 West Palm Beach Office Job #118991 23 23 Phone: 800.330.6952 561.659.4155 24 24 25 25 ESQUIRE an Alexander Gallo Company Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 GIUFFRE004388 Case 18-2868, Document 283, 08/09/2019, 2628241, Page374 of 883 Louella Rabuyo - Volume I October 20, 2009 8 8 3 1 A When I came back to report, thattalking about the day the police 2 learned. 2 went to Jeffrey Epstein's house you did not go in the 3 Eiaborate on that for me. What do you mean, 3 morning, but you went after lunch and the police had 4 when you came back to report that's how I learned? 4 already left? 5 A I reported in the afternoon, and then that's 5 A Oh. No. When I went there nobody was there, 6 how I learned that the police came. 6 no policemen were around. 7 All right. And when were you you're now 7 Who was at the house then? 8 saying you came back to report and you learned that the 8 A Janusz, and Douglas, the architect. 9 police had already come to the house, right? 9 Schoettle? 10 A Yes, sir. 10 A Yes. 11 0 Prior to that occasion, when was the previous 11 And did you have a discussion with them? 12 time that you were at the house? 12 A No. 13 A The day before. 13 How did you know the police had been to the 14 Okay. And the day before you left your shift 14 house? 15 at roughly five o'clock? 15 A Janusz told me. 16 A I cannot remember. I usually leave 5:00 or 16 When? 17 5:30. 17 A When I arrive. 18 But sometime late in the afternoon? 18 That's what i was asking you when I said did 19 A Yes. 19 you have a discussion with them, meaning Janusz and 20 And as of that time, the day before the search 20 Douglas. 21 warrant was issued, you had seen no police officers in 21 A Okay. Being because them -- with Janusz only. 22 or around the house? 22 What did he saysaid the police came and, what's this, took 24 And then the next day you reported to the job 24 away some stuff. 25 at what time? 25 Did he say what they tookThe next day? 1 A He said pictures. 2 The next day. 2 Did he tell you which pictures? 3 A report in the afternoon. 3 A No, sir. 4 0 Was there a reason why you reported in the 4 Aside from pictures, what else did the police 5 afternoon? 5 take, as Janusz told you? 6 A Ms. Maxwell called me. 6 A He did not elaborate. '7 When did she call you? 7 All right. Prior to the police going to the 8 A During that day, she said Louella, you can 8 house and taking pictures, do you remember seeing 9 report in the afternoon. 9 pictures around Mr. Epstein's house? 10 She called you early in the morning? 10 A Yes. 11 A Not early. 11 Do you remember seeing pictures of naked or 12 Normally you would report to the house between 12 nude females around Mr. Epstein's house? 13 eight and nine o'clock, right? 13 A Not around, in his closet. 14 A Yes, sir. 14 in Mr. Epstein's closet you would see -- 15 So in order for you not to arrive at the 15 describe what you would see related to females in 16 house, she had to have called you before eight or 16 pictures. 17 nine o'clock, right? 17 A Some have topless. 18 A Yes. 18 Is this a big closet? 19 Okay. So approximately what time does 19 A No. Not really big, it's just this big, not 20 Ms. Maxwell call you to tell you you can report to the 20 so big. 21 house later on that day? 21 Okay. Were these pictures that could be seen 22 A i cannot remember really the time. 22 by -- strike that. 23 0 Okay. What time did you actually report to 23 Do you know of any other pictures of females 24 the house? 24 that were confiscated by the police that did not come 25 A After lunch, about -- maybe after lunch. 25 from Mr. Epstein's closet? ESQUIRE an Alexander Gallo Company Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 GIUFFRE004408 Case 18-2868, Document 283, 08/09/2019, 2628241, Page375 of 883 Louella Rabuyo Volume I October 20, 2009 2 9 1 STATE OF FLORIDA 2 COUNTY OF PALM BEACH 3 4 5 l, the undersigned authority, certify that 6 LOUELLA RABUYO personally appeared before me on the 20th 7 of October, 2009, and was duly sworn. 8 9 Dated this SOth day of October, 2009. 10 11 12 13 14 Teresa Whalen, RPR, 15 Notary Public - State of Florida My Commission Expires: 4/25/11 16 My Commission No.: DD 644533 17 Job 118991 STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 I, Teresa Whalen, Flegistered Professional Reporter and Notary Public in and for the State of 6 Florida at Large, do hereby certify that the aforementioned witness was by me first duly sworn to 7 testify the whole truth; that I was authorized to and did report said deposition in stenotype; and 8 that the foregoing pages are a true and correct transcription of my shorthand notes of said 9 deposition. 10 I further certify that said deposition was taken at the time and place hereinabove set forth 11 and that the taking of said deposition was commenced and completed as hereinabove set out. 12 I further certify that i am not attorney or 13 counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party connected 14 with the action, nor am I financially interested in the action. 15 The foregoing certification of this transcript 16 does not apply to any reproduction of the same by any means unless under the direct control and/or direction 17 of the certifying reporter. 18 19 Dated this 30th day of October, 2009. 2 0 2 1 22 Teresa Whalen, FPR 23 Job 118991 24 2 5 ESQUIRE an Alexander Gallo Company Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 GIUFFRE004420 Cam: 18-7868, 782, 08/00/7010, 7678741, Pag9276 nf 882 EXHIBIT 21 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page377 of 883 Page 1 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 3 JANE DOE NO. 2, Case NO: 4 Plaintiff, 5 Us 6 JEFFREY EPSTEIN, 7 Defendant. 8 JANE DOE NO. 3, Case NO: 9 Plaintiff, 10 VS ll JEFFREY EPSTEIN, 12 Defendant. 13 JANE DOE NO. 4, Case No: 14 Plaintiff, 15 VS. 16 JEFFREY EPSTEIN, 1? Defendant. 18 19 JANE DOE NO. 5, Case No: 20 Plaintiff. 21 VS 22 JEFFREY EPSTEIN, 23 Defendant. 24 25 Kress Court Reperting, Inc. 305?866-?688 F115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000247 Case 18-2868, Document 283, 08/09/2019, 2628241, Page378 of 883 Page 2 Page 4 1 MNE DOE NO. Case ND: 1 I 0 TA 2 Plaintiff. 2 DEPOSITION 3 Us 3 of .1 JEFFREY EPSTEIN. 4 ALFREDO RODRIGUEZ 5 Defendant. 5 . -1 6- taken on behalf of the Plaintiffs purSuant '5 to a Rte-Notice of Taking Deposition {?utes Tecum) JANE DOE NO. Case No. 1" 3 PlaintiffJ 10 APPEARANCES: 11 ?5 MERMELSTEIN HORowrrz, RR. ?3 12 or: STUART ESQ. JEFFREY 18205 Biscayne Boulevard ?0 13 Suite 2213 11 ?Brenda? 1 Miami. Florida 33150 12 Case ruo: 14 goggle; fur Jane DOE 2' 3' . 13 PlaintiffADLER :2 BY: BRAD J. EDWARDS, ESQ, and . 1? CARR HOLMES, ESQ. Las Elias Cit},r Centre - 15 SUICE 1650 one DOE, . . 03-w- 13 Case 0 80893 401 East Las OlaS Boutevard Plal?tiff 19 Fort Lauderdale, FlOrll?JB 33301 19 I Attorney for Jane Doe and SW. ?5 20 And L.M. 2'3 21 JEFFREY EPSTEIN, UREECK 21 22 BY: KATHERINE W. EZELL Defendant. 25 West Fiagler Street 22 23 Suite EDD 23 Miami, Fiorida 33130 24 24 for Jane Doe 101 and 102. 25 25 Page 3 Page 5 1 JANE DOE N0. 11. C393 No: 2 Plaintiff, 2 3 VS . LD-KUUJN 4 JEFFREY ERSTEIN, 3 53%, mmomo, ESQ. 5 Dafendant- 4 2925 PSR Boulevard Suite 200 6 5 Palm Beach Gardens. Florida 33410 JANE DDE NO. 101, Case ND: Attorney for 3.8. 6 Plaintiff. RICHARD ESQ. 3 2291110111 Avenue North 5 Lake Worth. Florida 33451 9 9 rattorney idrC.M.A. JEFFREY 1o 10 en RMAR. LUTHER :1 Defendant. 11 COLEMAN. 11 av: ROBERT CRITTON, ESQ. 12 JANE DOE NO. 102. Case No: 99-11211-8131655 12 :15 ?250'? 1 Pla'ntiff We 1: 1.15 i 13 West Palm Boar-1r. Florida 33401 In. 1' . 15 JEFFREY EPSTEIN, 14 er Jeffrey.r Epstern 16 Defendant. 15 16 17 ALSO PRESENT: 13 1? 19 JOE 20 1031 Ives Dairy Reed 13 Suite 228 19 - 21 North Miami. Florida 20 July 29. 2009 21 22 11:00 am. to 5:(Pages 2 to Court Reperting, Inc. 305-856-2688 2115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000248 Case 18-2868, Document 283, 08/09/2019, 2628241, Page379 of 883 Page 6 Page 3 INDEX OF EXAMINMTON 1 Doe right here on the copy you gave me. I?m 2 missing which Jane Doe this is. 3 WWNESS DIRECT CROSS 3 They?re all different case numbers. Do ALFREDO RQDRIGUEZ 4 you want me to go through each case number? 4 5 MR. CRITTON: I?m going to note my 5 {By Mr. Mermelstein) 11' 6 objection. Obviously if this deposition 7 gets played -- not obviousiy, I'm going to 5 {By Edwards) 15? 8 object to the litany of each one so 1 don't Mr, Lang-m0) 2,50 9 know how we can separate it out. Maybe if it 10 and when at the time of trial and depending 3 11 on how the Court determines what comes in 12 and what doesn't with regard to the if: ExHiBth INDEX OF EXHIBIEGE 13 consolidated aspects of this. I have no 12 1 Message pad :12 14 great idea other than just saying Jane Doe 13 2 Documents 115 15 versus Epstein, et at, or something iike i4 16 that, or Jane Doe, et al. :2 1? MS. EZELL: Couidn?t we just say and 18 those cases which have been consoiidated 13 19 with it for Discovery purposes? 19 20 MR. EDWARDS: Aithough there is cases 20 21 here that have cross noticed this from state 21 22 court that haven't been consolidated so that g; 23 may not work. You may have to read them 24 24 ali, if it works out your way that wiil just 25 25 get edited out, at least he have read Page Page ?3 . 1 Deposition taken before MICHELLE PAYNE, Court 1 that caption, every caption. Right? 15 2 Reporter and Notary Public in and for the State of 2 there a better suggestion? 3 Fiorida at Large, in the above cause. 3 MR. CRITTON: No. There may be a better 4 - 4 suggestion if he starts this is such and 5 THE VIDEOGRAPHER: This is the case of 5 such day, it's the deposition of Mr. 6 Jane Doe No. 2, piaintiff, versus Jeffrey 6 Rodriguez in the case such and such, and we 3? Epstein, defendant. Jane Doe No. 3, 2 can aimost it in depending on which 8 plaintiff, versus Jeffrey Epstein, tape it goes, how it ?ils in, at ieast 9 defendant. Jane Doe No. 4, piaintiff, 9 we'il have the context of the first and 10 versus Jeffrey Epstein, defendant. And Jane 10 depending on whether the Judge reads it in 11 Doe No. 5, plaintiff, versus Jeffrey 11 from a consoiidated or they all come 12 Epstein, defendant. Jane Doe No. 6, 12 related, I have no great idea. 13 piaintiff, versus Jeffrey Epstein, 13 MR. EDWARDS: I was thinking if he read 14 defendant. Jane Doe No. 2, plaintiff, 14 every one of them and it was the seventh in 15 versus Jeffrey Epstein, defendant. CMA, 15 line then you just would edit it so you 16 plaintiff, versus Jeffrey Epstein, 16 would only read that one. 1: oerendant. and Jane Doe, piaintiff, versus 1? MR. CRiTi?Ohi: I'm okay with that too. 18 Jeffrey Epstein, et ai, defendant. And Jane 18 THE VIDEOGRAPHER: On page number three 19 Doe -- is there a shorter thing that we can 19 there is something missing on the top here. 20 do here? It's aiso missing this one right 20 Do you want me to read each case number 21 here. 2 1 sepa rately? 22 MR. MERMELSTEIN: Do we have a problem 22 MR. MERMELSTEIN: I don't think it?s 23 with saying Jane Doe 2 and the Epstein and 23 necessary. 24 related cases? 24 MR. EDWARDS: [don?t think it?s 25 25 necessary either. THE VIDEDGRAPHER: I?m missing this Jane 3 (Pages 6 to. 9} Kress Court Reporting, Inc. 305-866?2688 2115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000249 Case 18-2868, Document 283, 08/09/2019, 2628241, Page380 of 883 Page 26 Page 28 1 with a copy. 1 A. Yes. Sometimes very short notice but, 2 Q. Were you the only one who was allowed to 2 yes, I was. 3 answer the phone? 3 Q. So that varied? 4 A. Yes. 4 A. Yes. 5 Q. I?m sorry, what would you do -- Q. Who would give you that notice? 6 A. I would leave it on the counter next to 6 A. Mrs. Maxwell or Sarah or Larry, the 7 the kitchen so when I find that piece all crumbled 2 pilot. 8 I knew that Mr. Epstein saw the message, so we 8 Q. And then you would drive to pick them up 9 communicated like that. 9 at the airport? 10 Q. Now, you mentioned Mr. Epstein would give 10 A. Yes. 11 you instructions during the course of the day. 11 Q. And who traveled with him? 12 A. Through his assistant. 12 A. The three pilots and some guests. 13 Q. And his assistant was whom? 13 Q. What do you mean by guests? 14 A. Sarah Kellen. 14 A. He will have some friends from Harvard, 15 Q. But you didn't view her as your 15 he will have -- well, very important people that, 16 supervisor? 16 you know, friends, acquaintances from New York or 1? A. She take orders from Mrs. Maxwell but she 12 Europe because I was just told the number of 18 will tell me, Alfredo, we need to buy this, we 18 people was coming on the plane. 19 need to do this, and so and so was coming. I 19 Q. Were there people who were employed by 20 couldn't talk directly to Mr. Epstein. 20 him who came regularly? 21 Q. Okay. So any communications from Mr. 21 A. Yes. 22 Epstein always came through Ms. Kellen? 22 Q. And who would they be? 23 A. Or from the office in New York. Lesley, 23 A. Like I said, they were the pilots, Larry 24 his secretary, or somebody else, the comptroller, 24 Bisosky, George, and I don't remember the ?ight 25 the architect, any lawyer. 25 engineer, and he will have two girlfriends. Page Page 29 1 Q. Lawyer, what kind of instructions would 1 Q. The pilot would have two girlfriends? 2 you get from lawyers? 2 A. Mr. Epstein. This is all people coming 3 A. We used to have a lot of time, for 3 in the plane together. 4 instance, the dock construction, you need to have 4 Q. Right. What do you mean by girlfriends? a lot of permits in Palm Beach so they were there 5 A. Friends, you know, that he was always 6 for that reason. 6 having friends that he will befriend in New York, 2 Q. Okay. Now, so you would interact with 2 I don't know, or some other places. 8 the staff from New York and that would include I 8 But I was just told my concern was how 9 think you said Lesley? 9 many people I have to feed, how many cars do I 10 A. Lesley, Belle. 10 need to transport these people from the airport to 11 Q. What was Lesley's position? 11 the house, and to arrange accommodations in the 12 A. Lesley is the secretary, secretary to Mr. 12 house. 13 Epstein. 13 Q. What about Sarah Kellen, did she travel 14 Q. Okay. Is that Lesley Grofl? 14 with him? 15 A. I believe it was, Idorft remember the 15 A. Yes. 16 last namethe plane? 1? Q. Bella, wno was Bella? 1? A. Yes. 18 A. Bella was the assistant comptroller. 18 MR. CRITTQN: Form. 19 Q. Anyone else that you dealt with in New 19 BY MR. MERMELSTEIN: 20 York? 20 Q. And Ms. Maxwell? 21 A. Doug Shadow was the architect and he used 21 MR. CRITTON: Form. 22 to come to the house in a regular basis because we 22 THE WITNESS: No, she will have different 23 used to have a lot of projects going on. 23 plane. 24 Q. Okay. Would you get advance notice when 24 BY MR. MERMELSTEIN: 25 Mr. Epstein was going to arrive in Palm Beach? 25 Q. Okay. I 8 (Pages 26 to 29} Kress Court Reporting, Inc. 305?866-2688 2115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000254 Case 18-2868, Document 283, 08/09/2019, 2628241, Page381 of 883 Page 2'0 Page 22 . 1 in cash as opposed to check? 1 A. Not him. I will drive anybody else but 2 MR. CRITION: Form. 2 he would rather eat at home. 3 THE WITNESS: i was told to pay them 3 Q. So you would drive house guests to 4 cash, sir. 4 restaurants? 5 BY MR. MERMELSTEIN: 5 A. Yes. 6 Q. Simply you were told and didn't ask why? 6 Q. And when you did that you wouid didn?t A. No. 2 you stay with the car or did you eat with them? 8 Q. Do you recall the detective who 8 A. No, Iwiil stay with the car. 9 interviewed you for the police that you thought of 9 Q. So who did you tip? 10 yourself as a human ATM machine? 10 A. If you want to park in front of the 11 MR. Form. 11 restaurant you got to tip the vaiet otherwise 12 THE WITNESS: Yes. 12 you're taking one of the spots. 13 BY MR. MERMELSTEIN: 13 Sometimes I used to take -- I'm sorry. 14 Q. You recali saying that? 14 Aviation, you know, you need to go to aviation and 15 MR. Form. 15 help those guys move your cars around, you need -- 16 THE WITNESS: Because I always had cash 16 they carry luggage, so I used to tip those too. 1? in my pocket. 1? Q. That would be when you picked up or 18 BY MR. MERMELSTEIN: 18 dropped off Mr. Epstein. Correct? 18 Q. And why was there always cash in your 19 A. Yes. 20 pocket? 20 MR. MERMELSTEIN: We?ll mark this as an 21 A. That was part of my job to have, you 21 exhibit, composite exhibit. 22 know, for emergencies or paying somebody cash. 22 (Composite Exhibit 1 was marked for 23 Q. Okay. What kind of emergencies? 23 Identification.) 24 A. it's hard to say. 1 was supposed to put 24 MR. CRITTON: Just out of curiosity, on 25 cash on each Mercedes Benz on each ashtray. The 25 depositions are we going to use instead of Page 21 Page 2'3 1 idea behind this is you get stranded nobody accept 1 doing plaintiff and defendant designations 2 credit card or check you have cash. 2 do you just want to run them one, two, 3 Q. How much did you leave in the ashtray? 3 three, four? 4 A. 300. 4 MR. MERMELSTEIN: That's fine with me as 5 Q. And did you ever have to replenish that 5 long as we remember where we left off. 6 money? 6 MR. CRITTON: Weil, are we going to do it 7' A. Yes. 1? consecutive with all of the depositions? 8 Q. Because the Mercedes was stranded? 8 I'm okay with that if someone can keep track 8 A. No, because when Mr. Epstein will leave I '3 of that. 10 have to coilect that money because I will send the 10 MR. EDWARDS: I've had that go wrong 11 cars to the car wash so to avoid that money being 11 before, especially when we have some parties 12 stolen we used to keep track, you know, when to 12 who aren't here, such as Mr. Garcia, he's 13 retrieve that money and then when he's coming put 13 going to join depositions, we have to start 14 it back there again. 14 at 2? or whatever. 15 Q. So you use cash for that purpose and you 15 MR. CRHTON: For each deposition one 16 also use cash to pay the masseuses. Correct? 16 through whatever without necessarily giving 1? A. Yes. them a plaintiff or defendant. 18 Q. Did you use cash for any other purpose? 18 BY MR. MERMELSTEIN: 19 A. Car wash for the guy who used to came to 18 Q. Mr. Rodriguez, I?ve marked as Exhibit 1 a 20 the house and wash all the cars. Tipping 20 composite document which includes four per page of 21 sometimes for getting a good spot in the 21 what appear to be message slips. 22 restaurant you have to have cash, something like 22 First of all let me ask you, let me 23 that. 23 direct your attention to the ?rst page of this 24 Q. Okay. Would you drive Mr. Epstein to a 24 exhibit. And the upper left message has initials 25 restaurant? 25 at the bottom. Is that correct? 19 (Pages in to is) Kress Court Reporting, Inc. 305-866?7688 2115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000265 Case 18-2868, Document 283, 08/09/2019, 2628241, Page382 of 883 Page 2'4 Page 2'6 1 A. Yes. 1 and he told you he owned a modeling agency? 2 Q. Are those your initials? 2 A. Yes, sir. 3 A. Yes. 3 Q. Anything else he told you? 4 Q. And was it the household policy to 4 A. He spoke, you know, ?ve, sitar.r languages, 5 initial messages when they were taken? 5 always speaking Spanish, Italian. 6 A. Yes. 5 Q. Did the girls who were you know, who 7 Q. Okay. You were instructed to do that? 2 travelled with Mr. Epstein, were they from his 8 A. Yes. 8 agency? 9 Q. Who instructed you to do that? 9 MR. CRITTON: Form. 10 A. Ms. Maxwell. There was a manual, sir, in 10 THE WITNESS: I don't know, sir. 11 the house, we had to follow the instructions of 11 BY MR. MERMELSTEIN: 12 the manual. 12 Q. You didn't discuss that? 13 Q. There was -- okay. 13 A. No. 14 A. Estate manager, household manager for all 14 Q. Let?s look at the message next to it. 15 the houses, so I will abide to that, you know, so 15 MR. Still on page one? 16 I take message with my initial, the time, who 16 MR. MERMELSTEIN: Still on page one. 17 called. 1? BY MR. MERMELSTEIN: 18 Q. So there were all sorts of policies and 18 Q. It appears the one under it is to the 19 procedures in this manual? 19 same person. Is that correct? Who is that? 20 A. Yes. 20 A. Aiicia. 21 Q. Who wrote it? 21 Q. Who is Alicia? 22 A. It was the estate manager for all the 22 A. I don?t know, sir. Please tell Jeffrey 23 properties and so I was -- 23 that I called so I just wrote the name. 24 Q. Who was the estate manager for all the 24 Q. Now, some of these messages if you look 25 properties? 25 through appears to he a different handwriting and Page 25 Page 1 A. I never met him, sir, he was ?red before 1 there is no signature on the bottom. 2 I came along. 2 A. That's not mine, I don't know who's that 3 Q. But you don't remember his name? 3 is, sir. 4 A. No, sir. 4 Q. I thought you said earlier you were the 5 Q. And you remember one of the things that 5 one who was responsible for taking messages. 6 said in this manual was that every message has to 5 A. Exactly, yes, I was, sir. 7 be signed? 2 Q. But there were other people who took 8 A. Yes. 8 messages as well? 9 Q. I?m not necessarily going to go through 9 A. Maybe this is after or before my time, 10 every single message. Let me go back to the one 10 sir. 11 on the upper left on the first page. It's from 11 Q. Okay. Because there is no date on it. 12 Jean-Luc. Is that correct? 12 A. I used to put my dates and I know I used 13 A. Yes, sir. 13 to do that all the time, but you know. 14 Q. Who is Jean-Luc? 14 Q. These style of message padshad modeling agency. 15 pad. Correct? 16 Q. How do you know that? 16 A. Yes. 1? A. He gave me his card, Sir. I: Q. And this is the old fashion message pad 18 Q. Was he a frequent guest at the house? 18 that it's like duplicate? 19 A. Yes, sir. 19 A. Exactly, the original stays with the 20 Q. Did he stay over? 20 spiral. 21 A. Sometimes he will stay, sometimes I will 21 Q. Okay. So there was a spiral notebook? 22 drive im to Miami. 22 A. Exactly. 23 Q. Do you recall his last name? 23 Q. And you would write the message on the 24 A. No, sir. 24 top copy and then you would take that out and put 25 25 it on the counter in the kitchenconversation with him 20 (Pages 2410 Kress Court Reporting, Inc. 305?8652688 2115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000266 Case 18-2868, Document 283, 08/09/2019, 2628241, Page383 of 883 Page 150 Page 152 1 Q. You had a laptop? 1 Q. The girls who came to the house for 2 A. No, it was desktop. 2 massages, did you ever call a cab to bring any of 3 Q. Okay. So you had your own desktop in the 3 the giris home? 4 staff house? 4 A. Probably on a few occasions. 5 A. Yeah. Exactly. 5 Q. So is it your understanding that they 6 Q. And you don't know what was -- what was 6 would have arrived by cab as well? 2 the ?les in that computer versus on the other 2 MR. CRITTON: Form. 8 computers? 8 THE WITNESS: Yes. 9 A. No, sir. 9 BY MR. MERMELSTEIN: 10 Q. Did you ever see any pornography on any 10 Q. And how would that come about, were you 11 of the computers? 11 given instructions to call a cab by anyone? 12 A. No, sir. 12 A. No, I wouid cail the cab, the taxi. 13 Q. Are you sure about that? 13 Q. How did you know a cab needed to he 14 A. Pornography as in sexuai acts, no. 14 called? 15 Q. Pornography as in naked people, men or 15 A. Because Sarah would tell me can you get 18 women. 18 me a taxi. 1? A. Yeah, there were some. 1? Q. So when the girl was finished what she 18 Q. Okay. And describe to me what that was. 18 was doing Sarah would come They were like modeis. 19 A. She wouid cali me. 20 Q. And where were those in the computer? I 20 MR. CRITTON: Form. 21 mean, how did you access that? 21 BY MR. MERMELSTEIN: 22 A. They were in the files and some of it 22 Q. She would call you? 23 in -- you mean which ?le they were, what was your 23 A. Yes. 24 question? 24 Q. Okay. You would be in the guest house at 25 Q. Where were they in the computer? There 25 the time? Page 151 Page 153 1 were downloaded files on computer? 1 A. Yes. 2 A. They were downloaded, yes. 2 Q. Do you recall having to do that often? 3 MR. CRITTON: Form. 3 A. No, not very often, sir. 4 BY MR. MERMELSTEIN: 4 Q. Did Mr. Epstein keep photograph equipment 5 Q. Okay. There were photographs of naked 5 in the house? 6 women? 8 A. I don't remember seeing it. 2 A. Modeis. 2 Q. Do you recail seeing any video equipment? 8 Q. And why do you say models? 8 A. No, sir. 9 A. Because it was like a catalog so you have 9 Q. Do you recall any video or photograph 10 models, you know. 10 equipment in the master bedroom? 11 Q. And what was your understanding as a 11 A. No, sir. 12 source of these photos? 12 Q. The models that you saw on the computer, 13 A. I don't know, sir. It was just a 13 did you recognize any of them as having been at 14 curiosity on myself and it was -- it was none of 14 the house? 15 my business but, you know, Ijust happen to see 15 A. No. 16 them there. 16 Q. The girls who stayed at the house, did 17 Q. Did these girls appear very young to your 1! any or them speak with a foreign accent? 18 MR. CRITTON: Form. 18 A. Yes. 19 THE WUNESS: No, sir. They were young 19 Q. Many of them? 20 but not underage. 20 MR. Form. 21 BY MR. MERMELSTEIN: 21 THE WITNESS: Some of them. 22 Q. Is there anything in particular that 22 BY MR. MERMELSTEIN: 23 makes you draw that conclusion? 23 Q. Wouid any of them not speak any English? 24 A. Because they are developed, you know. 24 A. No. 25 It's hard to say, sir, you know. 25 Q. They all spoke English? 39 (Pages 15b to 153) Kress Court Reporting, Inc. 2115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000285 Case 18-2868, Document 283, 08/09/2019, 2628241, Page384 of 883 Page 186 Page 168 1 written down anywhere? 1 for now we'll cail it a massage as well as . 2 A. No. 2 anybody who brought that person over to the house, 3 Q. It's my understanding that C. and T. 3 they would both get paid cash. Are you familiar 4 either came to his house aione to visit with Mr. 4 with that? Epstein or brought other girls in their age group 5 MR. CRITTQN: Form. 6 to Mr. Epstein. 6 THE WITNESS: No. 2 Were you familiar with that type of 2 BY MR. EDWARDS: 8 recruitment process of girls bringing other girls? 8 Q. If C. brought another girl over to the 9 MR. Form. 9 house and C. stayed downstairs but this other giri 10 THE WITNESS: Yes. 10 went upstairs with Mr. Epstein, which one would 11 BY MR. EDWARDS: 11 you pay? 12 Q. Can you tell me more about what you know 12 A. I don?t know because I was told who to 13 about girls bringing other girls that are 13 pay. 14 relatively the same age to come to Jeffrey 14 Q. And Sarah Kellen always told you? 15 Epstein's house and to use your words, have a good 15 A. Sarah told me pay so and so. 15 time? 15 Q. So if we were going to ask anybody else 1? MR. CRITTON: Form. 1? about the exact method in terms of who would get 18 THE WITNESS: It's hard to know who they 18 paid and for what, who would the people be? I 19 knew. But I think that was -- they feel 19 mean, other than Mr. Epstein who else Could we ask . 20 better themselves when they're in a group 20 these questions? 21 than going by themselves, but I don?t know 21 A. Sarah. 22 somebody recruiting. 22 Q. Sarah Kellen? 23 BY MR. EDWARDS: 23 A. Yes. 24 Q. Okay. And you?ve talked about, at least 24 Q. She would know this? 25 referred to yourself I beiieve to the police and 25 A. Yes. Page 16? Page 169 1 as well today as a human ATM machine. Right? 1 Q. What about Ghislaine Maxwell? 2 MR. CRITTON: Form. 2 MR. CRITTON: Form. 3 THE WITNESS: Something like that. I was 3 THE You're talking about the 4 supposed to carry cash at all times. 4 boss. I don't know. 5 BY MR. EDWARDS: 5 BY MR. EDWARDS: 6 Q. One of the primary reasons why you 6 Q. To your knowledge was Ghislaine Maxweli carried cash was to pay the girls in this age 7' aware of these girls that are in the age group of 8 group of C. and T. for whatever happened at the 8 C. and T. coming to Jeffrey Epstein?s house to 9 house. Right? 9 have a good time? 10 MR. CRITTON: Form. 10 MR. CRITTON: Form. 11 THE WITNESS: Yes. 11. THE WITNESS: I have to say something. 12 BY MR. EDWARDS: 12 Mrs. Maxwell called me and told me not to 13 Q. That's a fair statement. Right? 1.3 ever distuss or contact her again in a 14 MR. CRITTQN: Form. 14 threaten way. 15 THE WITNESS: Yes. 15 BY MR. EDWARDS: 16 BY MR. EDWARDS: 16 Q. When was this? If Q. Ukay. and wnen IEES use her for A. Right after I left batdual: I tail um: of 18 exampie, would bring somebody else to the house, 18 the friends for a job and she told me this, butweli as whomever she brought to 19 you know, I feel intimidated and so I want to keep 20 the house, pay them both? 20 her out. 21 A. No, I pay only one person. 21 Q. What exactly did she say? First of all, 22 Q. Okay. My understanding, and tell me if 22 was this a teiephone call? 23 this is wrong or you can corroborate this, is that 23 A. Yes, she was in New York. 24 Mr. Epstein would pay the girl that was actuaily 24 Q. She called you on your cell phone? 25 performing whatever was happening in the room -- 25 A. Yes. 43 (Pages 155 to 159) Kress Court Reporting, Inc. 305866-2688 7115 Rue Notre Dame, Miami Beach, Fl. 33141 NON PARTY (VR) 000289 Case 18-2868, Document 283, 08/09/2019, 2628241, Page385 of 883 Page 238 Page 240 1 Cab Company? 1 A. Nadia was the number one girlfriend for 2 A. West Palm Beach Taxi. No, it's not 2 Mr. Epstein. Very sweet girl, and she was always 3 Yellow. Could be Yellow, but I don?t know. 3 -- she would come over to the house but different 4 Q. Would Mr. Epstein have the names or the 4 girls with her all the time. 5 list? 5 Q. Okay. But Nadia, that's somebody who 5 A. Probably. I6 lives in New York? 2 MR. CRWON: Form. 2 A. Nadia, I believe, yes, her address is in 8 BY MR. EDWARDS: New York. 9 Q. Anybody else? 9 Q. So how often would she stay at 358 El 10 A. Sarah. 10 Brillo? 11 Q. Sarah would have? 11 A. Very often. 12 A. Yes. 12 Q. Usually every time when Mr. Epstein was 13 Q. In addition to Mr. Epstein obviously 13 there? 14 knowing who's coming to and from the house, would 14 A. Yes. 15 Sarah also be familiar with the names of the girls 15 Q. And she would for the most time fly on 16 and who they were? 15 the plane with Mr. Epstein? 1? A. Yes. 1? A. Yes. 18 Q. In addition to Sarah and Mr. Epstein 18 Q. And it would be her and Mr. Epstein and 19 would Ghislaine Maxwell be familiar with the names 19 oftentimes some other girls? 20 of some of these girls? 20 A. Exactly. 21 MR. CRITTON: Form. 21 Q. Where some points I think earlier when 22 THE WITNESS: Yes. 22 Mr. Mermelstein was asking you questions where 23 BY MR. EDWARDS: 23 there was some confusion was we're talking about 24 Q. Are these names kept in a database in a 24 two different sets of girls, the girls that would 25 computer system? 25 come over and be labelled masseuses from the Palm Page 239 Page 241 3 1 A. Could be. 1 Beach area, and the girls that would fly on the 2 MR. CRITTON: I'm sorry, did you say 2 plane with Mr. Epstein and Ms. Marcenacova. 3 could be? 3 So, what I?m asking you is what, if any, 4 THE WITNESS: Yeah. 4 involvement did Nadia Marcenacova have with the 5 MR. Move to strike as 5 girls that would arrive and be labeled as 6 speculation. 6 masseuses behind closed doors with Mr. Epstein? 2 BY MR. EDWARDS: 7 MR. Form. Q. When you say could be, why do you say 8 THE WITNESS: He was the second -- the 9 that? 9 first role was Sarah and she was always 10 A. Because there were too many and they were 10 Nadia is a very shy person so she will be in 11 very organized and there is nothing you write on a 11 the background. 12 piece of paper. 12 BY MR. EDWARDS: 13 Q. When you say they were very organized, 13 Q. Did you ever know of Nadia Marcenacova to 14 are we talking -- 14 engage in to be in the room with Mr. Epstein 15 A. Mr. Epstein and Sarah. 15 while any of these young girls were up there? IE- Q. Anybody else beside Mr. Epstein and 16 MR. CRITTON: Form. 1? aaran, I guess oesroe aaran that would no me 1? THE WITNESS. Yeah. 18 scheduling to coordinate the times these girls 18 BY MR. 19 would come to the house? 19 Q. How often do you remember Nadia and Mr. 2o A. I'm sorry, anybody else you say? 20 Epstein being in the room with any of these young 21 Q. Right, aside from Sarah. 21 girlswould say most of the time. 23 Q. And do you know what role, if any, Nadia 23 Q. Nadia would go up there too? 24 Marcenacova ever played in any of what would go on 24 A. Yeah. 25 behind the bedroom door with Mr. Epstein? 25 Q. Did you ever believe that Nadia was '61 (Pages 233 to 241) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, Fl. 33141 NON PARTY (VR) 000307 Case 18-2868, Document 283, 08/09/2019, 2628241, Page386 of 883 Page 250 Page 252 1 Q. Would you know the name ifI said it? 1 A. We discuss -- he asked me a lot of 2 A. Yeah. 2 questions, obviously he didn?t know a lot of 3 Q. Bill Riiey? 3 things about the case, and I told him who I was, 4 A. Yes. 4 what I did in the house. 5 Q. Okay. Have you ever spoken with an 5 Q. He told you he didn't know a lot about 6 investigator Paul Lavery? 6 the case? A. Could be, I'm not sureasked me questions about 8 Q. Okay. So Bill Riley came by your house 8 so I got the feeling that Mr. Critton didn't know 9 personaily? 9 as much as other lawyers. 10 A. Yes. 10 Q. Okay. Did you tell him what you told us 11 Q. And how long did you meet with him? 11 here today? 12 A. Five minutes. He gave me his card, he 12 A. No. He asked me tell the truth, you 13 gave me Mr. Critton telephone number, he said 13 know, just go over there, you know, he advise me 14 don't talk to Mr. Goldberger. 14 iike you're on your own, Alfredo, just tell the 15 Q. Did he tell you why you should call Mr. 15 truth, you know. He didn't give me any advice. 16 Critton? 16 He paid for my gas. Thank you very much. 1? A. lvo. I assume that he was not on the case And that?s it, you know. 18 anymore, but} didn?t ask questions but -- 18 The main thing I wanted to have a lawyer 19 Q. You assumed that who wasn't on the case 19 on my side but then I keep going to the first 20 anymore? 20 instance when my wife told me you don't need a 21 A. Mr. Goldberger, Jack Goidberger. 21 lawyer, and I?m here today to say that, Fm here, 22 Q. Okay. But what I?m asking you, I guess, 22 Pm speaking the truth. 23 is did this investigator, Mr. Riley, tell you why 23 Q. Okay. You mentioned there were ?ve or 24 it was important for you to call any attorney 24 six computers in the house? 25 that's associated with Mr. Epstein, why was that 25 A. Yes. Page 251 Page 253 1 important? 1 Q. And do you know what happened to the 2 A. He didrft say that. He didn?t say that. 2 computers? 3 He just said that get in touch and that's it. 3 A. No. 4 Because I said what am I going to do, because I 4 Q. You don?t know where they are? 5 said I thought this was -- you know, but I didn't 5 A. (Shakes head.) 6 know I was going to be subpoena. And like I Said 6 Q. Nobody has told you? 2 in the beginning of this deposition, I don't have 7 A. No. . 8 an attorney so I don?t have money, first of all, 8 Q. You also mentioned there were photographs 9 to pay for an attorney. First of all, I don't 9 in the house? 10 think I'm in trouble, but every time you hear high 10 A. In the computers in the files. 11 powered lawyers you feel intimidated so I said, 11 Q. Okay. But there were also stilt 12 listen, what am I going to do, and that was my 12 photographs around the house? 13 basic question. 13 A. Oh yes, yes. 14 Q. Okay. So then you spoke with somebody at 14 Q. Some of the girls have made the 15 Mr. Critton?s office and arranged to meet with him 15 allegation that there were photographs of them 16 personally? 16 nude in the house. Do you remember seeing that? 1? A. res. i caiieci his secretary and we sit 1? In Line ciuset, yeah, in a mosaic. it was 18 down with his assistant, the three of us. 18 one frame with probably 15 pictures, small 19 Q. So it was Mr. Critton, yourself, and 19 pictures. 20 somebody else? 20 MR. CRITFON: Repeat the question back. 21 A. Yes. 21 BY MR. EDWARDS: 22 Q. And you sat down for another two hour 22 Q. Okay. Some of the giris that have 23 period of time? 23 lawsuits against Mr. Epstein with ailegations 24 A. Yes. 24 similar to the allegations that C. and T. have 25 Q. And what did you go over in that meeting? 25 made, which is that they were underage when Mr. 54 {Pages 250 to :53) Kress Court Reporting, inc. 385-866?2688 2115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000310 Case 18-2868, Document 283, 08/09/2019, 2628241, Page387 of 883 Page 254 Page 256 1 Epstein was engaging in sex or sex acts with them, 1 those photos? 2 also say that they have seen pictures of 2 A. One was a Colombian lady and one was 3 themselves in frames in Mr. Epstein?s house naked. 3 one from Spain, beautiful girls, that, you know, 4 A. In his closet. 4 but they were not -- not the ones the girls we're 5 Q. Other than the picture and these are 5 talking about here. 6 girls who are making the allegation that they were 6 Q. Okay. When you were hired were you hired 2' underage and there were pictures of them nude in 2? by Mr. Epstein or were you hired by one of his 8 his house. 8 companies? ?3 A. I didn?t see pictures of C. there. 9 A. Mrs. Maxwell. 10 Q. I'm not talking about C. I'm saying company owned by 11 other girls that were underage or have made 11 Mrs. Maxwell? 12 allegations that they have seen pictures of 12 A. Not directly. My paycheck was Jeffrey 13 themselves in Mr. Epsteln's house. 13 Epstein. I mean, 1 was hired by Mr. Epstein 14 MR. Form. 14 but 15 BY MR. EDWARDS: 15 Q. Okay. I just understood you to say you 16 Q. Where would those photos have been, or 16 were hired by Mrs. Maxwell. 1? did you see them? 17 A. Exactly, she told me you're hired but 18 A. Yes, I see them inside his closet. lB you're going to get paid by Mr. Epstein. 19 Q. It's one mosaic? 19 Q. And he wrote you personal checks? 20 A. Yes, one mosaic. 20 A. No. The checks that came from New York, 21 Q. Other than there did you see any of these 21 Jeffrey Epstein Companies. 22 pictures of young girls nude anywhere else his company? 23 house? 23 A. Yes. 24 MR. Form. 24 Q. Which company; do you know? 25 THE WITNESS: Nude with an art, yes, but 25 A. 456 Madison Avenue. It's next to the New Page 255 Page 25?f 1 not pornography. You know, I saw them, they 1 York Palace now. 2 were all over the place. For instance, in 2 Q. The name of the company is 456 Madison 3 the back only showing part of the rear, you 3 Avenue? 4 know. 4 A. No, no, itMR. EDWARDS: 5 tongue. Something like Caribbean or island 6 Q. But the photographs that I'm concerned 6 something investments, something like that. 2 with -- 2 If you call Lesley, her secretary, she A. Not frontal pictures. 8 will tell you exactly. Because they answer the 9 Q. The photographs I'm concerned with are 9 phone like that, you know. 10 photographs of these West Palm Beach girls that 10 Q. What's Lesley's number? 11 were labeled as masseuses that are being displayed 11 A. Lesley, I don't have it. I can find out 12 around the house anywhere in some state of 12 for you. 13 undress. 13 Q. Do you think you could get Lesley's 14 MR. CRITTON: Form. 14 number for us? 15 THE WITNESS: No, I don't remember that. 15 A. Yes. It's in Manhattan. 16 BY MR. EDWARDS: 16 Q. Does she work for this company in 1? Q. Okay. The Only girls that the: Only 1? friend rattan? 18 photograph that you remember of young girls nude 18 MR. CRITION: Form. 19 was in a mosaic that is in his closet? 19 THE WITNESS: Manhattan, yes. 20 A. Yes. 20 BY MR. EDWARDS: 21 Q. Nothing that you remember that was on 21 Q. If the check was issued did Jeffrey 22 display? 22 Epstein actually sign it himself? 23 A. Downstairs, yes, but they were not these 23 A. No, it came through the comptroller. 24 girls, they were somebody else. 24 Q. Who was the comptroller? 25 Q. Okay. Do you know who was -- who were in 25 A. Bella was the assistant comptroller and 65 (Pages 254 to 25?) Kress Court Reporting, Inc. 2115 Rue Notre Dame, Miami Beach, Fl. 33141 NON PARTY (VR) 000311 Case 18-2868, Document 283, 08/09/2019, 2628241, Page388 of 883 Page 256 Page 263 1 BY MR. LANGINO: 1 THE STATE OF FLORIDA, 2 Q. Are you currently in fear of Mr. Epstein? 2 COUNTY OF DADE. 3 A. Not at this particular moment but it's 3 4 something I have to be worry about, yes. 4 . Q. Are you personally afraid of criminai 5 1r the authority, ?31?th 5 prosecution? 6 that ALFREDO RODRIGUEZ personally appeared before . 7 A. No. me on the 29th day of July, 2009 and was duly 8 Q. Do you believe that you dict anything 3 sworn. a iitegal? 9 10 WITNESS my hand and of?cial seal this 10 A. Illegal, no. 11 MR. LANGINO: I have no further 3 3151 day 2009? 12 questions. Thank you. 13 MR. camon: We're going to break in if, 14 about 15 minutes. Do you want to start and 15 15 go for 15 minutes or do you want to -- it's MICHELLE PAYNE, Court Reporter 15 ?3 VRU- 15 Notary Public - State of Fiorida 1? MS. EZELL: I'll start. 17 18 MR. WILLITS: When are we going to quit, 13 19 folks? 19 20 MR. In 15 minutes. 20 21 THE VIDEOGRAPHER: Might as well change 21 22 tapes. 22 23 MR. EDWARDS: Bob has to get back so 23 24 we?ve agreed wete going to come back some 24 25 other time. 25 Page 26? Page 269 1 MR. WILLITS: Why don?t we just stop nowMS. EZELLI Okay. The State Of Florida. I 3 MR. EDWARDS: Rather than you start. 0' Dada?- 4 MS. EZELL: Yeah, I WOn't get very far. 5 I, tutti-late Court Regent-2r and 5 MR- EDWARDE to d? a 6 WE didn't ?nish. and did stenograpbically report the videotaped 3' MR- (WW so we're sweet? . 8 MR- EDWARDS: We?re stopped. 8 foregoing pages, numbered from 1 to 169, 9 THE VIDEOGRAPH ER: Off the record. 9 iM'Ufivei at: 33:33(Thereu pen, the videotaped deposntton was my . Ste 1111 t' I ll adjourned at 5'30 pm.) 11 nigg?a?gu?setinnrt?iine fnaitntigrtat?cir said 12 videotaped deposition was commenced and complete-t1 13 12 as hereinaboye set out. 13 I rt'f I l: 14 attorney amtof it]: $21325, nor an". 15 14 I a relative or employee of any attorney or 15 counsel or party connected With the action, nor am 15 1 financialty intenasted In the action. 1 me lulugulrtg ot 13 Lranscript does not apply to any reproduction of 1? the same by any means unless undEr the direct 19 control andfor direction of the certifying ta rt . SE 19' this 3151: day of July, 20139. 21 . ??tment Court Reporter (Pages 255 to 269) Kress Court Reporting, Inc. 3115-8664638 ?115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000314 Case 18-2868, Document 283, 08/09/2019, 2628241, Page389 of 883 Page 270 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 3 JANE DOE NO. 2, CASE NO: 4 Plaintiff, 5 Vs. 6 JEFFREY EPSTEIN, 7 Defendant. 8 JANE DOE NO. 3, CASE NO: 9 Plaintiff, 10 1* Vs. UONDENSED ll JEFFREY EPSTEIN, '12 Defendant. 1 3 :14 JANE DOE NO. 4, CASE NO: 15 Plaintiff, 16 VS. 17 JEFFREY EPSTEIN, 18 Defendant. 9 a JANE DOE NO. 5, CASE NO: 20 Plaintiff, 21 vs 22 JEFFREY EPSTEIN, 23 Defendant. 24 25 Kress Court Reporting, Inc. 305-8664688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000315 Case 18-2868, Document 283, 08/09/2019, 2628241, Page390 of 883 Page 271 Page 273 1 JANE 00E N0. 6, CASE NO: 08-CV-80994 1 IN THE COURT OF T85 lsTli Fiaintiff, JUDICEAL CIRCUFT IN AND FOR 5? 2 PALM BEACH comm, JEFFREY Emmi 3 CASE no. AB Defendant. 4 5 3.3., JANE DOE no. 7, CASE no: cam-30993 5 7 Plaintiff, Piaintil'JEFFREY EPSTEIN, 8 JEFFREY 10 Defendant. Defendant. 11 9 12 C.M.A., CASE NO: 08?61-8083} 10 13 Plaintiff, 11 1? VS- 12 1031 Ives Dal Road is JEFFREY EPSTEZN, Suite 228 15 agenda? 13 North Miami, Florida 17 August 7, 2009 JANE DOE, CASE no: 08-01-80893 i; 1115 P-m. ?3 5130 PM 18 Plaintiff. 16 CONTINUED 19 17 VIDEOTAPED 18 DEPOSITION 20 JEFFREY EPSFEIN 19 ?f 21 20 ALFREDO RODRIGUEZ Defendant. 21 22 22 taken on behalf of the Plaintiffs pursuant 23 23 to a Re~Notica of Taking Continued Videotaped 2? 24 Deposition (Duces Tecum) 25 25 - - - Page 272 Page 274 JANE DOE NO. ff, CASE NO: 1 APPEARANCES: 2 Plaintiff, 2 3 Vs 3 Manfg?gi Hggoggz, M. BY: . 4 JEFFREY EPSTEIN: 4 18205 Biscayne Boulevard 5 Defendant. Suite 2218 5 Miami, Florida 33160 6 Attorney for Jane Doe 2, 3, 4, 5, JANE DOE NO. 101 CASE NOROSENFELDT ADLER Plaintiff, 5Y: BRAD J. EDWARDS, ESQ, and 8 9 CARA HOLMES, ESQ. Vs. Las Olas City Centre 9 10 Suite 1650 40: East Las Olas Boulevard JEFFREY 11 Fort Lauderdale, Fior?da 33301 10 Attorney for Liane Doe and EW. DefendantPODHURST ORSECK Diff N0. 102, CASE NO. 08 CV 80656 av: KATHERINE w. HELL, ESQ am i 15 25 West Flagier Street 14 V5. Suite 800 15 JEFFREY EPSTEIN. 16 Miami, Florida 33130 15 Defendant. Attorney for 3ane Doe 101 and 102. 17 18 17 worewxwm 18 19 BY: AUAM J. ESQ. 19 2925 PGA Boulevard 20 20 Suite 200 21 Palm Beach Gardens, Florida 33410 21 Attorney for 8.(Pages 271 to 274) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000316 Case 18-2868, Document 283, 08/09/2019, 2628241, Page391 of 883 Page 299 Page 301 1 A. I don't remember, Ma'am. He came from 1 video, even phones. 7 2 New Aibany, Ohio. 2 Q. Would he aiso repair the televisions if 3 Q. From New -- 3 they needed work? 4 A. New Albany, Ohio. 4 A. No. 5 Q. New Albany, Ohio. Did he have his own 5- Q. No. Did you have any kind of intercom 6 business? 6 system in the house? 7 A. No, he worked for Mr. Epstein. He wiil 7 A. Yes, ma?am. 8 maintain ali the computers. 8 Q. And what kind of system was that? 9 Q. Was he there everyday? 9 A. it was standard of?ce equipment, Lucid 10 A. No, ma?arn. 10 Technologies maybe, but it was an intercom. like we 11 Q. Do you know whether at that time Mr. 11 using right now. 12 Epstein had an of?ce in Paim Beach? 12 MS. EZELL: Just let the record re?ect 13 A. Not outside the house, no. 13 that the witness pointed to the telephone on 14 Q. Do you have any knowledge of whether or 14 the tabie that has a speaker phone. 15 not the video equipment was -- and I don?t know 15 THE WITNESS: Yes, ma?am. 16 the technical term, forgive meMS. EZELL: i 17 kind of equipment that would record for a certain 17 Q. And did you use that in your work? :8 amount of time and then record over that ?lm? 18 A. Yes, ma?am. 19 A. I don?t know. 19 Q. And what did you use it for? 20 MR. CRITT ON: Form. 20 A. Mr. Epstein used to page me when he 21 BY MS. EZELL: 21 needed me. 22 Q. You don't know? 22 Q. Did you have one of those phones in the 23 A. No, ma'am. 23 kitchen? 24 MR. Just for clari?cation, I 24 A. Yes, ma'am. 3 25 may have misonderstood, but I thought he 25 Q. And was there one out in the staff house i Page 300 Page 362 1 said he didn?t even know the video equipment 1 as weil? 2 existed untii he read the FBI report. 2 A. Yes, ma'am. 3 MS. EZELL: He said he didn't know that 3 Q. Do you know where others were in the 4 it was upstairs and downstairs, I believe. 4 house? 1 5 MR. CRITTON: I thought he said he didn?t 5 A. Probably have like 15 phones. We used to 6 know that it even existed. 6 have three in the staff house, one in the cabana, 7 MS. EZELL: I may be wrong. 7 two in the master bedroom, one in each room, 8 BY MS. EZELL: 8 kitchen, dining room, Mrs. Maxwell's of?ce, the 9 Q. Did you know it existed before you read 9 garage. 10 the FBI report? 10 Q. Where was Mrs. Maxweii's of?ce? 11 A. No, ma?am. 11 A. Under the stairs next to the kitchen. 12 Q. I'm sorry, then I was wrong. 12 Q. Can you give me some idea of what size 13 How did you know then that the young :3 space that was? 14 technician from Ohio maintained the computers and 14 A. It was probably we change the ?oor. 15 the video equipment? 15 Tweive by ?ve, something like that. 16 A. Because we used to request there were 16 Q. And was the computer equipment in that 1 17 aiways problems with the computers so he came to 17 space? 18 the house and he was the programmer. It was very 18 A. Yes, ma?am. 19 SOphisticated. 19 Q. Do you know whether Ms. Maxwell kept the 20 MR. CRITTON: Form to the iast question, 20 names and telephone numbers of the girls who came 21 move to strike the answer as nonresponsive. 21 to do massages? 22 BY MS. EZELL: 22 A. Yes, ma'am. 23 Q. How did you know then that he maintained 23 MR. CRITTON: Form. 24 the video equipment as weil? 24 BY MS. EZELL: 25 A. Because he was in charge of computers, 25 Q. Do you know that because you saw the - _l.i 9 (Pages 299 to 302) Kress Court Reporting, Inc. 305866?7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000323 Case 18-2868, Document 283, 08/09/2019, 2628241, Page392 of 883 Page 303 Page 305 1 names and phone numbers? 1 computer? 2 MR. CRITTON: Form. 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 4 BY MS. EZELL: 5 Q. Do you know if she kept pictures of the Q. And did she generally have phone numbers 6 giris on the computer? 6 for those girls? 7 A. Yes, she did. 7 A. Yes, ma?am. 8 Q. And you know that as well because you 8 Q. And were they generaily pictures of the 9 happen to see them? 9 girls? 10 A. Yes, ma'am. 10 MR. CRITTON: Form. 11 MR. CRITTON: Form to the test two 11 THE WITNESS: No, ma?am. 12 questions. 12 BY MS. EZELL: I 13 BY MS. EZELL: 13 Q. And did Ms. Maxweli have a list of the 14 Q. Were they similar to the pictures that 14 girls who came to give massages? 15 Ms. Kellen had on her computer? 15 MR. CRITTON: Form. 16 MR. CRITTON: Form. 16 THE WITNESS: Yes, ma'am. 17 THE WITNESS: Yes, ma?am. 17 BY MS. EZELL: 18 BY MS. EZELL: 18 Q. Did she have telephone numbers generaily? 19 Q. Did the pictures that they kept there 19 A. Yes, ma'am. 20 took like pictures that were posed? 20 MR. CRITTON: Form. 21 A. They were more casual. 21 BY MS. EZELL: 22 Q. Did they took as though the person being 22 Q. Were there pictures on her computer of 23 photographed knew that they were being 23 the girls who came to give massages? 24 photographed? 24 MR. CRITTON: Form. 25 MR. CRITIQN: Form. 25 BY MS. EZELL: Page 304 Page 306 1 THE WITNESS: No, ma'am. 1 Q. Ms. Maxweil I'm tatking about. 2 2 BY MS. EZELL: 2 A. Yes, ma'am. 3 Q. And what can you tell me about that, what 3 Q. And were those pictures the more casual 4 lead you to draw that conclusion? 4 ones that you described when I asked whether or A. They were probably taken in parties in 5 not the subject looked as though she knew she was 6 big reception or banquet. 6 being photographed? 7 MR. Let me offer as a 7 MR. CRITTDN: Form. 8 suggestion, not that you have to accept or 8 THE WITNESS: I'm sorry, can you repeat? 9 that you wouid, you?re using the term young 9 BY MS. EZELL: 10 girls genericaiiy, he has probably seen 10 Q. Yeah. The pictures of the young girls 11 many, many young giris, there was no 11 who came to the house to give massages that were 12 you?ve used it interchangeably with just 12 on Ms. Maxwell's computer, did they appear to have 13 young girls versus young girls who may have 13 been taken when the girls knew they were being 14 come to purported to give a massage and, 14 photographed? 15 therefore, that may be a different answer, 15 MR. CRITTON: Form. 16 so that?s part of my form objection. 16 THE WITNESS: I don?t think they knew 1/ M23. bitLL: Ukay, thank you. 17 they were being photographed. 18 BY MS. EZELL: 18 BY MS. EZELL: 19 Q. When I asked you about Ms. Kellen whether 19 Q. I believe you said they were more casual 20 she had a list of the girls and telephone numbers, 20 pictures. 7, 21. I think I asked about those girls that came to 21 A. Yes, ma'am. 22 give massages, but let me go back and just ask it 22 Q. Did you notice any nude photographs in 23 that way. 23 those pictures? 24 Did you notice that Ms. Kellen had a list 24 A. Yes, ma'am. 25 25 MR. Form for the last question. of the girts that came to give massages on her - ?mm .. 10 (Pages 303 to 306) Kress Court Reporting, Inc. 305?866-3?688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000324 Case 18-2868, Document 283, 08/09/2019, 2628241, Page393 Page 471 1 THE STATE OF FLORIQA, - 2 COUNTY OF DADE. 3 4 1, the undersigned authority, certify 6 that ALFREDO RODRIGUEZ persanalty appeared befere August,- 2009 and was duty 8 sworn? 9 10 WHNESS my hand and of?cial 595% this 11 18th day of August, 2009. 12 13 14 1'3 ti, MICHELLE PAYNE, Court Reporter 16 Notary Public: State 0f FiorEda Page 472 1 The Starr: Of FWida. Caunty Cr!? Dacia. t. HICHELKE WWNE, Court Reporter and Notary Public in and for 016 State at Fiortda at Large, do hereby ?28!th that was autimrited and did stenogravhically report the deposition 0! that-a review :33" the transcript was. mt reque?m; 3:16 that the formant; mus. numbered from 2170 to 472, imtusive, are a Ema and correct transatptzon cf my stenograohit notes of said deposition. further certify that said deposmcm was taken at the time and place iminabove set term and that the taking of said depositaan was commenced and its herei?ab?we set out. I Further centry that i am not an or wunsel a! any OI the Qantas, nur am I a retativa or emptayee o! my mama?; or counsel of party summed with the action, rm am I ?nanc'ta?y- interested in the mica, 15?: loreg?am 6! {7113 transcript. does mat appty to any reproduction of rhe ?rm by any means unless under the ?33th cantmt andlot direction sf the certifying reborn?!" DATED 15m day or August, zoo-9. MECHELLE awe, Com REpcarter Kress Court Reporting, Inc. 305866?7688 7115 Rue Notre Dame, Miami Beach, FL 33141 If 52 (Pages 471 Us 472) NON PARTY (VR) 000366 Cam: 18-7868, 782, 08/00/7010, 7678741, nf 882 EXHIBIT 22 (Filed Under Seal) Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law. Case 18-2868, Document 283, 08/09/2019, 2628241, Page395 of 883 United States District Court For The Southern District of New York Giu??re v. Maxwell Ghislaine Maxwell?s Privilege Log Amended as of August 1, 2016 Long DATE DOC. TYPE BATES FROM TO CC RELATIONSHIP OF PARTIES SUBJECT MATTER 2011.03.15 E-Mails 1000- 1013 Ghislaine Maxwell Brett Jaffe. Esq. Attorney Client Communication re: legal advice 2011.03.15 E-Mails 1014- 1019 Brett Jaffe. Esq. Ghislaine Maxwell Attorney Client re: legal advice 2015.01.02 E-Mails 1020- 1026 Ross Gow Ghislaine Maxwell Attorney Agent Client Communication re: legal advice 2015.01.02 E-Mail 1024- 1026 Ghislaine Maxwell Ross Gow Attorney Agent Client Communication re: legal advice 2015.01.02 E-Mail 1027- 1028 Ross Gow Ghislaine Maxwell Brian Basham Attorney Agent Client Communication re: legal advice 2015.01.06 E-Mail 1029 Ghislaine Maxwell Jeffrey Epstein Common Interest Communication re: legal advice 2015.01.06 E-Mail 1030- 1043 Ghislaine Maxwell Jeffrey Epstein. Alan Dershowitz. Esq. Attorney Client Communication re: legal advice 2015.01.10 E-Mail 1044 Ghislaine Maxwell Philip Barden. Esq.. Ross Gow Attorney Client Communication re: legal advice 2015.01.10 E-Mail 1045- 1051 Ghislaine Maxwell Philip Barden. Esq. Client Attorney Communication re: legal advice 10. 2015.01.09 - 2015.01.10 E-Mails 1052- 1055 Ross Gow Philip Barden. Esq. Maxwell Agent Attorney Client Communication re: legal advice 11. 2015.01.11 E-Mail 1055- 1058 Ghislaine Maxwell Jeffrey Epstein Common Interest Communication re: legal advice 12. 2015.01.11 E-Mail 1055- 1058 Philip Barden. Esq. Ross Gow Maxwell Attorney/ Agent/ Client Communication re: legal advice 13. 2015.01.11 E-Mail 1056- 1058 Philip Barden. Esq. Ghislaine Maxwell Ross Gow Attorney Agent Client Communication re: legal advice 2015.01.13 2015.01.13 2015.01.21 2015.01.21 2015.01.27 2015.01.212015.01.27 2015.04.22 Various Various 2015.10.21 2015.10.22 2015.01.06 16. 17. 18. 19. 22. 23. 24. 25. 21. 20. 15. 2015.01.11 2015.01.17 2015.01.13 14. E-mail chain with attachment E-mails E-mails E-mail E-Mails E-Mails E-Mail E-Mails E-Mail E-Mail E-Mails 7 pages 10741076 10881090 10841098 1099 10761079 10681069, 10591083 10671073 10691073, Agent of Haddon, Morgan & Foreman; Laura Menninger Mary Borja; Laura Menninger Darren Indyke; Laura Menninger Jeffrey Epstein Ghislaine Maxwell Jeffrey Epstein Ross Gow Philip Barden, Esq. Philip Barden, Esq. Ghislaine Maxwell Jeffrey Epstein 2 Darren Indyke; Laura Menninger Mary Borja; Laura Menninger Agent of Haddon, Morgan & Foreman; Laura Menninger Ghislaine Maxwell Jeffrey Epstein Philip Barden, Esq., Ghislaine Maxwell Ghislaine Maxwell Ghislaine Maxwell Martin Weinberg, Esq. Jeffrey Epstein Ghislaine Maxwell Mark Cohen Attorney Work Product Attorneys for parties to Common Interest Agreement Attorney/Client Agent of attorney and Attorney Common Interest Common Interest Agent / Attorney / Client Common Interest Attorney / Client Common Interest Common Interest Common Interest Case 18-2868, Document 283, 08/09/2019, 2628241, Page396 of 883 Document prepared by Ghislaine Maxwell at the direction of Phili Barden Attorney work product Common Interest Agreement Communication re: legal advice Communication re: legal advice Communication re: legal advice Forwarding message from Martin Weinberg labeled “Attorne Client Privilege” with attachment Attorney work product Communication re: legal advice Communication re: legal advice Communication re: legal advice Communication re: legal advice 26. 2015.01.23 3 Attorney/Client Case 18-2868, Document 283, 08/09/2019, 2628241, Page397 of 883 Document prepared by Ghislaine Maxwell at the direction of Phili Barden Cam: 18-7868, 782, 08/00/7010, 7678741, nf 882 EXHIBIT 23 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page399 of 883 Expert Report of Professor Terry Coonan, J.D. Pursuant to Federal Rule of Civil Procedure 26(a)(2)(B) Giuffre v. Maxwell Case No. 15-cv-07433-RWS 1 Case 18-2868, Document 283, 08/09/2019, 2628241, Page400 of 883 international commercial dimensions of the sex trafficking scheme recounted by Ms. Giuffre. It is both factually and legally correct to characterize what Ms. Giuffre experienced as victimization in a sex trafficking conspiracy. Conclusion 4 Virginia Roberts Giuffre’s account appears credible and consistent in its most salient parts with the testimony of other witnesses and with contemporary trends in U.S. sex trafficking. The description of exploitation recounted by Ms. Giuffre, while not the most common sex trafficking scenario (many cases involve even more brutal forms of pimp-driven prostitution) nonetheless is quite consistent with larger patterns of commercial sexual exploitation. The conspiracy in this case was premised upon the exploitation of minors and young women who seem to have had certain identifiable vulnerabilities that rendered them prone to exploitation. The criminal scheme that emerges from the depositions and police reports involved a very calculated pattern of recruiting, grooming, and an attempt to “normalize” the repeated exploitation of its victims. While the accounts of witnesses vary in some of their details, the essential elements of a sex trafficking conspiracy clearly emerge when viewed in the totality of the circumstances that are recounted in the case record. Ms. Giuffre refers to herself at times as a “sex slave.” This is not factually incorrect, given her experiences, though current U.S. law might prefer to characterize her as a victim of sex trafficking. Popular understandings of the term “sex slave” might still connote images of violent pimps, white slavery, or of victims chained to a bed in a brothel in the minds of some people. To call Ms. Giuffre a victim of sex trafficking would however very accurately convey the reality that she along with a great many other victims of contemporary forms of slavery are often exploited by the “invisible chains” of fraud and psychological coercion. 20 Cam: 18-7868, 782, 08/09/7010, 7678741, Pagpdm nf 882 EXHIBIT 24 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page402 of 883 Expert Witness Report of Dr. Bernard J. Jansen Professor College of Information Sciences and Technology The Pennsylvania State University Regarding the case of: Virginia Giuffre v. Ghislaine Maxwell (U.S. District Court for the Southern District of New York) 9 September 2016 1 Case 18-2868, Document 283, 08/09/2019, 2628241, Page403 of 883 I. INTRODUCTION 1. I have been retained by the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. to provide expert analysis and opinion on behalf of Ms. Virginia Giuffre in VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15cv-07433, which is pending in the United States District Court Southern District of New York. II. QUALIFICATIONS 2. I am a tenured, full professor at the College of Information Sciences and Technology at The Pennsylvania State University, University Park, Pennsylvania, where I have been employed since 2001. I am the Director of the Information Searching and Learning Laboratory at the College of Information Sciences and Technology at The Pennsylvania State University. I am also a principal scientist at the Qatar Computing Research Institute. I was a Senior Fellow at the Pew Internet & American Life Project, which is part of the Pew Research Center, from 2010 through 2012. I was also a University Expert at the National Ground Intelligence Center from 2011 through 2014. Prior to my employment at The Pennsylvania State University, I was a Lecturer in the Computer Science Program at the University of Maryland (Asian Division) for 1 year. Before that I was an Assistant Professor and Lecturer in the Department of Electrical Engineering and Computer Science at the United States Military Academy, a.k.a. West Point, for 3 years. 3. In addition to my academic credentials, my professional experience includes 20 years of practice in the U.S. military, working primarily in a variety of technology-related and leadership positions. 4. I have authored approximately 250 academic publications, focusing on the areas of Web data, digital analytics, Web analytics, Web searching, Web search engines, social media analytics, and related areas. Approximately 200 of my publications address aspects of search 2 Case 18-2868, Document 283, 08/09/2019, 2628241, Page404 of 883 analytics, Web analytics, online advertising, search engines, or Web searching. My recent research work focuses on online news analytics, which is the investigation of the online qualitative and quantitative attributes of news stories, along with other digital content. I am also the editor-in-chief of the academic journal Information Processing and Management, and I was previously the editorin-chief for 5 years of the academic journal, Internet Research. I have authored, co-authored, or co-edited four books, including Web Search: Public Searching of the Web (2007), Understanding User – Web Interactions via Web Analytics (2009) and Understanding Sponsored Search (2011). A copy of my complete curriculum vitae, which includes a list of all publications I have authored in the past 10 years, is attached as Appendix A. 5. My fields of professional expertise include web analytics, search engines, web searching, social media, online advertising, and related areas. In the course of my academic career, I have worked with a variety of search engines and information searching applications in order to understand user searching behavior on the Web and other environments. For example, as part of my Master’s program in computer science, I designed and coded a text-based search engine. For my Doctorate program in computer science, I developed a program interface for Web search engines and implemented it on the Gigabyte search engine. In subsequent research, I have worked with the Microsoft Internet Information Services (IIS) and Verity commercial searching systems. 6. Concerning user searching behaviors on the Web using web analytics, I have worked directly with real-user searching data from several search engines, including AOL, Alta Vista, Dogpile, Excite, and MSN Live. I’ve also analyzed web data of visitor traffic and other attributes from a variety of websites and social media platforms. I’ve analyzed real-user data from online search marketing campaigns and user referral traffic to websites. I have conduct research and teaching concerning aspects of websites and social media platforms, including keyword 3 Case 18-2868, Document 283, 08/09/2019, 2628241, Page405 of 883 advertising. I’ve developed web analytics models and processes for analysis of business goals, and I have used web analytics data and commercial tools in both my research and teaching. I’ve also conducted other research on user searching and related online behaviors. I have advised governmental agencies and companies in consulting and expert witnessing matters. A list of cases in which I have testified as an expert in deposition or trial in the past four years is attached as Appendix B. I am being compensated for my work on this case at the rate of $300 per hour. III. ASSIGNMENT AND MATERIALS CONSIDERED 7. In providing my expert opinion, I have been asked to respond to the following question: 8. What is the dissemination of the statements from Ms. Maxwell referring to Ms. Giuffre’s declarations as “untrue” and “lies” from when the statements were made on 2 January 2015 to the date that I filed this report? 9. For brevity, I refer to references to the statements denoting Ms. Giuffre’s declarations as “untrue” and “lies”, any related accounts referring to those original statements, or similar statements from Ms. Maxwell or her representatives referring to Ms. Giuffre as the statements made against Ms. Giuffre, the statements from Ms. Maxwell’s message, or the message from Mr. Gow1. 10. My analysis is based on my experience, training, knowledge, and education and is formed through the application of that experience, training, knowledge, and education in the principles of web data collection, web analytics, web search, search engines, web sites, web traffic analysis, and related market analysis. 11. 1 The materials that I considered in preparing this report are listed in Appendix C. See, para. 30 and 32, Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-cv-07433. 4 Case 18-2868, Document 283, 08/09/2019, 2628241, Page406 of 883 IV. SUMMARY OF OPINIONS 12. Based on my research and analysis in connection with this assignment, which is described in more detail in the body of this report, along with my own experience, training, knowledge, and education as stated below, I have reached the following opinion: 13. The statements made against Ms. Giuffre have been disseminated to at least 115 online media or other sites in 178 separate stories or articles with a combined 66,909,965 potential unique visitors since 2 January 2015 to the date that I filed this report, inclusive. 14. This is a conservative estimate, and it is more likely than not, the statements made by Ms. Maxwell against Ms. Giuffre have received wider dissemination due to factors such as: a. I used a set of online websites to measure dissemination, and it is reasonable that I have not located all references to the statements made against Ms. Giuffre on every website by the time of the submission of this report. b. I examined only online sources referencing the statements made against Ms. Giuffre and not print or broadcast media dissemination of the statements made against Ms. Giuffre. c. I have not attempted to measure face-to-face dissemination of articles containing the statements against Ms. Giuffre. d. I do not have access to certain online sources where articles containing the statements against Ms. Giuffre may have been disseminated (e.g., email messages, personal social media messages, articles behind firewalls, etc.). e. There are possibly sites that have hosted the statements made against Ms. Giuffre that I could not locate or where the statements have been removed. 5 Case 18-2868, Document 283, 08/09/2019, 2628241, Page407 of 883 f. There are sites that hosted the articles containing the statements made against Ms. Giuffre where the visitor data is not accessible or where I could not confirm the number of visitors. g. I did not consider the dissemination via social media platforms of articles containing the statements made against Ms. Giuffre. h. Many sites published multiple articles on multiple days that contained or referenced the statements made against Ms. Giuffre; however, I did not include these multiple publication dates in calculating unique daily visitors. i. I did not include unique daily visitors to articles that link from that article to one or more of the articles containing the statements made against Ms. Giuffre. j. Finally, I did not include the counts of those who may have been searching and seen the statements made against Ms. Giuffre in the search results listing. V. BACKGROUND WEB ANALYTICS FOR TRAFFIC ANALYSIS 15. In the course of forming this opinion, I implemented numerous web analytics and related techniques commonly used in the industry. In order to more clearly discuss these techniques, I define the following terms: Direct Traffic: visitors to a website that come from entering a website link into a browser location bar (e.g., not coming via a link on another website). Dissemination: the act of spreading or the circulation of information or articles. Domain: a specific Internet website that are administered as a unit and defined by an Internet Protocol (IP) address. 6 Case 18-2868, Document 283, 08/09/2019, 2628241, Page408 of 883 Reach: the percentage or number of people who visit a website out of the total targeted population. Referral Traffic: visitors to a site that come from websites other than search engines. Repeat Visits: visitor traffic to a website in a given period that just includes multiple visits from the same set of IP addresses (i.e., IP addresses with more than one visit); provides a count of the people who have visited a site more than once in a given period. An individual is usually defined by a combination of IP address and browser within a given period but can also be defined by more sophisticated methods. Search Engine: a program and associated hardware and processes that allows people to find information on the Web, typically via the submission of queries consisting of terms. Search Traffic: visitors to a site that come from search engines rather than from other websites or via direct navigation. Search: a submission of a query to a search engine, usually in the form of terms forming a query. Share: sharing of an article or webpage typically via some social media platform. Social Media: content that is shared via a social networking website. Unique Visits: visitor traffic to a website within a given period that includes only the first visit (i.e., subsequent visits are ignored), which excludes repeat visits; provides a count of the individuals who have visited a site in a given period. 7 Case 18-2868, Document 283, 08/09/2019, 2628241, Page409 of 883 Unique Daily Visitors: visitor traffic to a website who visits a site at least once in a given 24-hour period. Each visitor, to the site, is counted once during the reporting period, which means it excludes repeat visits; provides a count of the individuals who have visited a site on a given day. Visits: a count of all the traffic to a website in a given period, including both unique and repeat visits. Web Analytics: the measurement, collection, analysis and reporting of web data. VI. METHODOLOGY 16. I was asked to determine the dissemination of articles containing the statements made against Ms. Giuffre. 17. In forming my opinion, I utilized accepted web analytics and related methodologies in developing my assessment. 18. To that end, I employed various publicly available online analytic services, as well as some subscription-based services in conducting my research, including: Alexa: an online service that provides web traffic data and analysis. Compete: an online service that provides web traffic data and analysis. Google Keyword Tool: an online service that provides the number of searches for a given set of keywords in a given month on the Google search engine. Google Trends: an online service that shows how often a particular term is relatively searched on the Google search engine in a given period. SimiliarWeb: an online service that provides web traffic data and analysis. SpyFu: an online service providing search data and analytics, including for both paid (i.e., advertisements) and organic (i.e., natural or algorithmic) channels. W3Snoop: an online service that provides web traffic data and analysis. 8 Case 18-2868, Document 283, 08/09/2019, 2628241, Page410 of 883 19. These tools offer a variety of data and analysis services, and they are frequently utilized by industry professionals in the search engine optimization, web analytics, and search engine marketing fields for market, customer, and competitive analysis. Furthermore, where possible, I did my own assessments, as outlined below, in order to validate the data and analysis results. 20. I also utilized search engines, primarily Google and Bing, to assess the dissemination of articles containing the statements made against Ms. Giuffre. 21. Whenever possible, I used multiple data sources, which is a data verification technique known as triangulation2, where one uses multiple and disparate sources for analysis and then compare the results from the separate analysis. If the results are similar, it reinforces the conclusion that the overall data analysis is valid. 22. In all of my assessments, I have used the most conservative numbers, meaning that I use the smallest value in arriving at the dissemination of articles containing the statements made against Ms. Giuffre. If I had not employed this conservative estimate, the number of potential dissemination of the articles containing the statements made against Ms. Giuffre would be 102,740,816 (i.e., more than 102 million) daily unique visitors. 23. In situations where I believed that I could not adequately verify the number of individuals or did not have confidence in the numbers in those situations, I did not include those numbers in the calculation of daily unique visitors. 24. My analysis is based on my experience, training, knowledge, and education and is formed through the application of that experience, training, knowledge, and education in the 2 Triangulation (social science) http://en.wikipedia.org/wiki/Triangulation_%28social_science%29 9 Case 18-2868, Document 283, 08/09/2019, 2628241, Page411 of 883 principles of web data collection, web analytics, web search, search engines, web sites, and related areas. VII. DISSEMINATION OF THE STATEMENTS MADE AGAINST MS. GIUFFRE 25. My opinion is that articles containing the statements made against Ms. Giuffre have been disseminated to at least 115 online media and others sites in 178 separate stories or articles with a combine 66,909,965 unique daily visitors. 26. This is a conservative estimate, and it is more likely than not, the statements have received wider dissemination due to factors such as: a. I used a set of online websites (115) to calculate the dissemination of articles, and it is reasonable that I have not located all references to the statements made against Ms. Giuffre by the time of the submission of this report. So, there may be more sites with articles containing the statements made against Ms. Giuffre that are not included in my calculations. b. My focus of analysis was the online dissemination of the statements made against Ms. Giuffre. Therefore, I examined only online sources and not dissemination of the statements made against Ms. Giuffre via print or broadcast media. It is reasonable to assume that the statements made against Ms. Giuffre were disseminated via these other channels. c. I have not attempted to measure face-to-face dissemination of the statements made against Ms. Giuffre. Therefore, these sources of dissemination are not included in the count of daily unique visitors. d. I did not have access to certain online sources where the statements against Ms. Giuffre may have been disseminated (e.g., email messages, social media messages, 10 Case 18-2868, Document 283, 08/09/2019, 2628241, Page412 of 883 articles behind firewalls, etc.). Therefore, these sources are not included in the count of daily unique visitors. e. There may be sites that have hosted articles containing the statements made against Ms. Giuffre where the articles have been removed. Therefore, I did not include these sites in my calculation of the unique daily visitors. f. There are sites where the visitor data is not accessible or where I could not reasonably check the number of visitors. In these cases, even though I had confirmed the site had posted one or more articles containing the statements made against Ms. Giuffre, I did not include these sites in my calculation of the unique daily visitors. g. I did not consider the dissemination via social media platforms of articles containing the statements made against Ms. Giuffre. h. Many sites published multiple articles on multiple days that contain or reference the statements made against Ms. Giuffre; however, I did not use these multiple articles from the same site with different publication dates in my calculations in determining the number of daily unique visitors who have been exposed to the articles containing the statements made against Ms. Giuffre. i. I did not include articles that link to one or more of the articles containing the statements made against Ms. Giuffre. Unless the article directly referenced the statements made against Ms. Giuffre, I did not include it in my analysis. j. Finally, I did not include people who may been searching and may have seen the statements made against Ms. Giuffre in the search results, without needing to visit the actual articles posted on the websites. 11 Case 18-2868, Document 283, 08/09/2019, 2628241, Page413 of 883 VIII. METHODOLOGY TO DETERMINE THE DISSEMINATION OF THE STATEMENTS MADE AGAINST MS. GIUFFRE 27. I have been informed that the statements made against Ms. Giuffre were originally contained in an email message from Mr. Ross Gow3, of Acuity Reputation, acting on behalf of Ms. Maxwell, that was sent on 2 January 2015 at 8:38 pm4 to, based on the email addresses5, people at The Mail Online6, The Independent7, The Mirror8, The Times9, and the BBC10. The email message from Mr. Gow contained the statements made against Ms. Giuffre. A screen shot of the email message is shown in Figure 1. 28. Figure 1: Email message from Mr. Ross Gow containing the statements made against Ms. Giuffre. 3 GM_00068 (Gow E-Mail) I am assuming, based on the location of Mr. Gow’s company, Acuity Reputation, that this is date-time stamp for the United Kingdom. 5 Note: For some reason, the contact at the Mail Online is on the cc: line, while the other recipients are in the to: line. Also, the email message is sent to two recipients at the BBC. 6 https://en.wikipedia.org/wiki/Mail_Online 7 https://en.wikipedia.org/wiki/The_Independent 8 https://en.wikipedia.org/wiki/Daily_Mirror 9 https://en.wikipedia.org/wiki/The_Times 10 https://en.wikipedia.org/wiki/BBC_News 4 12 Case 18-2868, Document 283, 08/09/2019, 2628241, Page414 of 883 29. I have been informed that the statements made against Ms. Giuffre were confirmed by Ms. Maxwell in a news article and video11 aired on 5 January 2015, which I have established by reviewing the video referenced in the news article12. 11 12 GIUFFRE001120 http://www.nydailynews.com/news/world/alleged-madame-accused-supplying-prince-andrew-article-1.2065505 13 Case 18-2868, Document 283, 08/09/2019, 2628241, Page415 of 883 30. Additionally, on 8 January 2015, agents reportedly acting on behalf of Ms. Maxwell made statements that the allegations against her were a “web of lies and deceit”13, which are similar to the statements made against Ms. Giuffre in the message from Mr. Gow. 31. Similarly, on 1 February 2015, like statements were quoted as “These allegations are untrue and defamatory”14, which are similar to the statements made against Ms. Giuffre in the message from Mr. Gow. 32. Based on my investigation and research, news stories, articles, and postings containing direct reference to or quotes from the statements made against Ms. Giuffre appeared the same day (i.e., 2 January 2015) as the email from Mr. Gow, with several news organizations and other sites publishing other articles containing direct reference to or quotes from the statements made against Ms. Giuffre in the immediately following days. News articles containing direct reference to or quotes of the statements made against Ms. Giuffre have continued to appear in news articles and other postings nearly up to the date that I submitted this report. 33. A timeline of events relating to the dissemination of the statements made against Ms. Giuffre is shown in Figure 2. 34. Figure 2: Timeline of events relating to the dissemination of the statements made against Ms. Giuffre from 2 January 2015 onwards. 13 14 https://www.thesun.co.uk/archives/news/6754/prince-andrews-pal-ghislaine-groped-teen-girls/ http://www.mirror.co.uk/news/uk-news/prince-andrews-pal-ghislaine-maxwell-5081971 14 Case 18-2868, Document 283, 08/09/2019, 2628241, Page416 of 883 35. Concerning the procedure employed in determining the dissemination of the statements made against Ms. Giuffre, nearly every major news site15 that I investigated, along with other specific news sites in the United States, the United Kingdom, Canada, and Australia, as well as other countries, have carried some aspects of the overall story related to Ms. Giuffre and/or Ms. Maxwell, or other parties involved. 36. In fact, there are tens of thousands of news articles and postings concerning the general story from news outlets worldwide, with combined potential viewership in the multimillions, as searches on the major search engines, such as Google and Bing, show. 15 Including the largest online news sites, such as Yahoo! News, Google News, Huffington Post, CNN, NY Times, Fox News, NBC News, Daily Mail, Washington Post, The Guardian, Wall Street Journal, ABC News, BBC News, USA Today, LA Times (see http://www.ebizmba.com/articles/news-websites) 15 Case 18-2868, Document 283, 08/09/2019, 2628241, Page417 of 883 37. However, I was not interested in news articles that just discussed the story in general or other aspects of the story. Also, I was not interested in those articles where Ms. Maxwell or those acting on her behalf, such as Mr. Gow, would just generally deny the allegations in the complaint16. I was specifically interested in only those articles that referenced directly or quoted the statements made against Ms. Giuffre in the 2 January 2015 email message from Mr. Gow, Ms. Maxwell’s subsequent confirmation of the statements, or similar statements as those in the message from Mr. Gow. Naturally, this narrow focus is a smaller subset of news articles than are the articles addressing the overall story. 38. To isolate these articles of interest, I generated a series of 10 queries17 that specifically targeted news articles from the case that addressed the statements made against Ms. Maxwell (e.g., Ghislaine Maxwell obvious lies) to retrieve a set of articles that directly related to the statements made against Ms. Giuffre18. I employed a modified snowball technique19, starting with one seed query, adding and modifying terms, until I was not retrieving new results. I also located some articles via navigating from the set of retrieved articles. 39. I set the search range date from 2 January 2015 onward, so articles prior to that date were not included in the search results. For each article used in my analysis, I also verified the date that the article was published to ensure it was published on or after 2 January 2015 and that the articles directly referenced in some way the statements made against Ms. Giuffre. 40. An example of a search engine results page in response to one of these queries is shown in Figure 3. 16 Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-cv-07433. Ghislaine Maxwell obvious lies, Ghislaine Maxwell Roberts obvious lies cnn, Ghislaine Maxwell Virginia Roberts, Giuffre Maxwell obvious lies, new york daily news alleged madam andrews, Prince Andrew Maxwell Roberts, Prince Andrew obvious lies, prince andrew's sex slave scandal who is maxwell, Ross Gow obvious lies, sex slave obvious lies. 18 In addition to the queries, I located some articles via direction navigation. 19 https://en.wikipedia.org/wiki/Snowball_sampling 17 16 Case 18-2868, Document 283, 08/09/2019, 2628241, Page418 of 883 41. Figure 3: Google News search results for the search Ghislaine Maxwell obvious lies with a date delimiter beginning on 2 January 2015. 42. I then personally verified that each article, by reviewing each article, used in my analysis directly referenced in some way the statements made against Ms. Giuffre. 43. So, articles relating to the overall story that did not mention Ms. Maxwell’s statements made against Ms. Giuffre were not included in the analysis. Articles relating to the overall story that referred to Ms. Maxwell simply denying the charges were not included. 44. I also personally performed a site search20 of the top 15 online media sites worldwide21 of articles related to the case, and I reviewed the results to identify if any of these 20 https://www.google.com/advanced_search Yahoo! News, Google News, Huffington Post, CNN, NY Times, Fox News, NBC News, Daily Mail, Washington Post, The Guardian, Wall Street Journal, ABC News, BBC News, USA Today, LA Times (see http://www.ebizmba.com/articles/news-websites) 21 17 Case 18-2868, Document 283, 08/09/2019, 2628241, Page419 of 883 articles referred to the statements against Ms. Giuffre. I also did the same for many countryspecific news sites in the United States, the United Kingdom, Canada, and Australia. 45. In the end, I had a set of 178 online news and other articles from 2 January 2105 to the date that I filed this report that specifically referenced the statements made against Ms. Giuffre to conduct my analysis, as outlined below. 46. Each of these 178 online articles was posted online. The 178 online articles were distributed among 115 unique domain websites (i.e., some websites posted multiple articles that contain the statements made against Ms. Giuffre). These 115 domains are: http://beforeitsnews.com http://boltonbnp.blogspot.com http://businessnewsusa.org http://dukefmduluth.com http://dukefmfargo.com http://home.bt.com http://jewishbusinessnews.com http://jewishnews.timesofisrael.com http://kdal610.com http://kfgo.com http://motivatornews.com http://mrharrywales.tumblr.com http://muhammad-ali-ben-marcus.blogspot.com http://news.sky.com http://news.trust.org http://newsbite.it http://newstoday.club http://normanfinkelstein.com http://onewayempire.com http://pagesix.com http://planetinvestigations.com http://softwaresuites.ne http://thisviral.com http://townhall.com http://ugandansatheart.blogspot.com http://uk.reuters.com http://whatiswrongwiththispicture2012.blogspot.com http://whbl.com http://whtc.com 18 Case 18-2868, Document 283, 08/09/2019, 2628241, Page420 of 883 http://wibqam.com http://wifc.com http://wincountry.com http://wkzo.com http://worlddailynews.info http://wsau.com http://wtaq.com http://wtvbam.com http://www.anorak.co.uk http://www.aol.co.uk http://www.asianimage.co.uk http://www.bailiwickexpress.com http://www.bannednews.net http://www.bbc.com http://www.belfasttelegraph.co.uk http://www.bournemouthecho.co.uk http://www.businessinsider.com http://www.business-standard.com http://www.capitalbay.news http://www.clactonandfrintongazette.co.uk http://www.courthousenews.com http://www.dailylife.com.au http://www.dailymail.co.uk http://www.dailyrecord.co.uk http://www.darkpolitricks.com http://www.dudleynews.co.uk http://www.eveningtimes.co.uk http://www.express.co.uk http://www.faceiraq.com http://www.ghanagrio.com http://www.ghanareview.com http://www.govtslaves.info http://www.headlines-news.com http://www.huffingtonpost.co.uk http://www.ibtimes.co.uk http://www.independent.ie http://www.infiniteunknown.net http://www.iol.co.za http://www.irishexaminer.com http://www.irishmirror.ie http://www.irishtimes.com http://www.itv.com http://www.lancashiretelegraph.co.uk http://www.lse.co.uk 19 Case 18-2868, Document 283, 08/09/2019, 2628241, Page421 of 883 http://www.mgtowhq.com http://www.mirror.co.uk http://www.msn.com http://www.nationalenquirer.com http://www.newindianexpress.com http://www.newscopia.com http://www.newsday.com http://www.newsgrio.com http://www.nigeriadailynews.news http://www.nydailynews.com http://www.nzherald.co.nz http://www.oneworldofnations.com http://www.oxfordmail.co.uk http://www.pressreader.com http://www.reuters.com http://www.scmp.com http://www.scotsman.com http://www.somersetlive.co.uk http://www.srnnews.com http://www.swindonadvertiser.co.uk http://www.telegraph.co.uk http://www.theargus.co.uk http://www.theboltonnews.co.uk http://www.thedailybeast.com http://www.thetelegraphandargus.co.uk http://www.thetruthseeker.co.uk http://www.twimovies.news http://www.westernmorningnews.co.uk http://www.wirralglobe.co.uk http://www.yorkpress.co.uk http://www.yorkshirepost.co.uk https://blairzhit.wordpress.com https://bol.bna.com https://ca.news.yahoo.com https://circusbuoy.wordpress.com https://quartetbooks.wordpress.com https://thetruth24.info https://www.eveningtelegraph.co.uk https://www.theguardian.com https://www.thesun.co.uk https://www.yahoo.com http://ferddyjay.blogspot.com 20 Case 18-2868, Document 283, 08/09/2019, 2628241, Page422 of 883 47. As seen from the list of domains that have published articles or stories containing references to the statement made against Ms. Giuffre, many of these domains are those of major news organizations or sources, including AOL News, BBC, Huffington Post, International Business Times, Irish Times, MSN News, National Enquirer, New York Daily News, New Zealand Herald, Page Six, Radar Online, Reuters, The Daily Beast, The Daily Mail, The Express, The Guardian, The Mirror, The Sun, The Telegraph, Yahoo! News, etc. 48. I then used a variety of web analytics traffic services and other sources to get the unique daily visitor traffic for each of these domains. I used multiple services when available to verify the unique daily visitor traffic for each of these domains, as these traffic services may use different techniques to arrive at their traffic numbers. 49. In cases of conflicting unique daily visitor traffic numbers, I utilized the most conservative (i.e., smallest) number. 50. In cases where I determined I could not get unique daily visitor traffic numbers or the unique daily visitor traffic were not reliable, in my opinion, I did not include the unique daily visitor traffic numbers for that domain in the numbers. This usually occurred for the sites with a smaller number of daily visitors or sites with an extremely large number of daily visitors. 51. Unique daily visitors measure is an industry standard web analytics metric for measuring people that visit a website in a given day, also known as unique audience22. It is generally averaged out over multiple days with a given period, such as week or month, as there are normal daily fluctuations. 52. Table 1 shows the unique daily visitor traffic for the listed domains that posted articles or stories referencing the statements made against Ms. Giuffre and the associated unique 22 http://digitalmeasurement.nielsen.com/files/metrics-guidelines.pdf 21 Case 18-2868, Document 283, 08/09/2019, 2628241, Page423 of 883 daily Visitor traf?c for each of those domains, along with munber of articles containing the statements made against Ms. Giuf?'e posted on that site. 53. Table 1: Domains that published articles or stories containing the statements made against Ms. Giuffre with the domain?s number of unique daily visitors and the number of articles containing the statements made against Ms. Giuffre published on that domain from 2 January 2015 to the date that I filed this report?. No. Domain Domain Unique Visitor Traf?c (Daily) Number of Articles Published 193,333 800,000 http://j ewishbusinessnewscom 5,000 9 257 10 1,600 11 12 13 a 14 523,333 15 l6 l7 18 1,987 l9 20 320,000 21 22 23 24 236,667 25 26 153,333 27 23 Note: Some outlets, Iwas able to get self-reported visitor numbers, such as the 22 Case 18-2868, Document 283, 08/09/2019, 2628241, Page424 of 883 Domain Unique Number of No. Domain Visitor Traf?c Articles (Daily) Published 28 12,252 1 29 1,207 2,653 7,150 39 423,333 2 40 1,293 1 41 29,633 1 42 - 1 43 12,950,000 3,866,667 1,333 3 51 80,000 1 52 14,276,667 6 53 145,048 3,667 57 1,686,667 1 58 - 1 59 ghana g1?i0.coma - 4 60 ghanareview.coma 61 govtslaves . infoa - 62 - 1 63 750,000 3 64 1,380,000 3 65 /Www.independe11t.iea - 66 3,183 67 233,333 1 23 Case 18-2868, Document 283, 08/09/2019, 2628241, Page425 of 883 Domain Unique Number of No. Domain Visitor Traf?c Articles (Daily) Published 68 - 1 69 100,000 3 70 323,333 1 7l 1,026,667 2 72 - 1 73 70,000 1 74 - 75 3,860,000 10 76 - 2 77 60,000 132,250 1 81 132,250 2 82 16,236 4 83 2,100,000 6 84 686,667 10,000 4 88 2,363,333 1 89 - 1 90 125,393 22,077 2 94 ,506,667 1 95 59,281 3 96 40,000 2 97 1,636,667 3 98 46,667 1 99 21,757 Case 18-2868, Document 283, 08/09/2019, 2628241, Page426 of 883 Domain Unique Number of No. Domain Visitor Traf?c Articles (Daily) Published 108 - 112 8,872,392 6 1 l3 1,496,667 ay.blogspot.coma - 1 66,909,965 178 a - Unique daily visitor traf?c not available - Unique daily visitor traf?c not veri?able 54. I used each domain?s unique daily visitor count to calculate the dissemination of the articles containing the statements against Ms. Giuf??e to various websites and potentially to visitors to that site as visitors to the news sites, these individuals could have been exposed to the articles containing the statements made against Ms. Giuffre), using the unique daily visitor number only once for each domain, regardless whether that domain published more than one article referring to the statements made against Ms. Giuffre. IX. RESULTS FOR ANALYSIS OF THE DISSEMINATION OF THE STATEMENTS MADE AGAINST MS. GIUFFRE 55. Based on my analysis as outlined above, my opinion is that the statements against Ms. Giuffre have been disseminated to at least 115 online media and other sites with 178 stories or articles with a combined 66,909,965 (more than 66 million) 1mique daily Visitors traf?c. 56. I note that for many of the 178 articles containing the statements made against Ms. Giuffre, one could get gist of the story of the article directly from the article headline. I point this out as it is well known that people skim online news sites?, so titles such as these 2? See for example: Aikat, D. News on the web: usage trends of an on-line newspaper. Convergence: The International Journal of Research into New Media Technologies 4, 4 (Dec. 1998), 94-110. 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page427 of 883 would have substantial impact on visitors to that site. Examples of such articles headlines (examples of actual headlines from the 178 articles) are: British socialite to face Epstein accuser's defamation lawsuit Alleged Epstein madam denies calling teen ‘sex slave’ a liar Sex-Trafficking Denials Aren't Libel, Brit Says U.S. woman who claimed she was forced to have sex with Prince Andrew sues British socialite for denying that she recruited her to be a sex slave British 'madam' accused of recruiting teenage 'sex slave' Virginia Roberts for Prince Andrew's friend Jeffrey Epstein denies calling her a liar Ghislaine Maxwell denies calling Virginia Roberts a liar Bill Clinton Pedophile Sex Scandal: Socialite Denies Calling ENQUIRER Source A Liar, Woman files defamation suit against British publishing magnate Jeffrey Epstein sex slave accuser sues Brit socialite for defamation Lawyers for British socialite accused of pimping 'sex slave' to Jeffrey Epstein push to dismiss defamation lawsuit. 57. This is a conservative estimate, and more likely than not, articles containing the statements made against Ms. Giuffre have been disseminated to more individuals. X. WHY THE ESTIMATE IS LOW 58. This (66,909,965 individual unique daily traffic) is a conservative estimate, and it is more likely than not, the statements have received wider dissemination due to factors such as: a. Although I spend considerable effort to locate published articles that contained the statements made against Ms. Giuffre, it is reasonable to assume that I have not located all such articles by the time of the submission of this report. So, there are possibly more 26 Case 18-2868, Document 283, 08/09/2019, 2628241, Page428 of 883 sites with articles containing the statements made against Ms. Giuffre that are not included in my calculations, which would increase the dissemination of the articles. b. The focus of my analysis was the dissemination of online articles containing the statements made against Ms. Giuffre, and I examined only online sources and not print or broadcast media. Many of the media outlets that I did identify have consider print distribution25, which are not included in my calculations, for example, such as: The Sun (print circulation) 1,741,838 Daily Mail (print circulation) 1,562,361 The Daily Telegraph (print circulation) 472,936 The Times (print circulation) 402,752 The Guardian (print circulation) 161,152 c. In my analysis, I did not attempt to measure face-to-face dissemination that may have occurred after individuals may have read articles containing the statements made against Ms. Giuffre, which would increase the count. d. Naturally, I could not access certain online sources where the statements made against Ms. Giuffre may have been disseminated (e.g., email messages, social media messages, articles behind firewalls, etc.). Therefore, these numbers are not included in my calculations. e. Also, there are possibly sites that have hosted articles containing the statements made against Ms. Giuffre where the articles have been removed. Therefore, they are not included in my calculations. 25 www.theguardian.com/media/2016/mar/17/independent-mirror-express-and-star-suffer-sharp-fall-in-traffic 27 Case 18-2868, Document 283, 08/09/2019, 2628241, Page429 of 883 f. For sites where one or more of the articles containing the statements made against Ms. Giuffre are posted but where I could not locate or not determine reliable daily unique visitor traffic, I have not included these sites in my calculations. There are 59 (of the 115 sites, 51.3%) where I could not get or not get verifiable traffic data. For example, the traffic numbers for the MSN News (Microsoft) and Yahoo! News are not separated by news and other services, such as search, so I did not include these in the number of people to which the articles containing the statements made against were disseminated. g. I did not include the dissemination of the articles containing the statements made against Ms. Giuffre directly to social media platforms. However, many of the articles containing the statements made against Ms. Giuffre do include counts of the number of times that individuals shared the article to a social media networks, as shown in Table 2. i. Table 2: Number of social media shares by published article containing the statements made against Ms. Giuffre. Shares 12576 201 1600 4000 130 45 6436 55 56 1813 9 560 24 54 198 198 174 51 Date 2-Jan-15 3-Jan-15 3-Jan-15 3-Jan-15 3-Jan-15 3-Jan-15 3-Jan-15 4-Jan-15 4-Jan-15 4-Jan-15 4-Jan-15 4-Jan-15 4-Jan-15 4-Jan-15 4-Jan-15 4-Jan-15 4-Jan-15 4-Jan-15 Domain https://www.theguardian.com http://muhammad-ali-ben-marcus.blogspot.qa http://www.dailymail.co.uk http://www.dailymail.co.uk http://www.huffingtonpost.co.uk http://www.ibtimes.co.uk http://www.mirror.co.uk http://newsbite.it http://ugandansatheart.blogspot.com http://www.dailyrecord.co.uk http://www.express.co.uk http://www.huffingtonpost.co.uk http://www.ibtimes.co.uk http://www.ibtimes.co.uk http://www.irishmirror.ie http://www.mirror.co.uk http://www.nigeriadailynews.news http://www.nzherald.co.nz 28 Case 18-2868, Document 283, 08/09/2019, 2628241, Page430 of 883 Shares Date Domain 216 4-Jan-15 http://www.telegraph.co.uk 177 4-Jan-15 https://www.theguardian.com 193 4-Jan-15 https://www.theguardian.com 105 5-Jan-15 http://www.dailylife.com.au 192 5-Jan-15 http://www.dailyrecord.co.uk 7 5-Jan-15 http://www.mirror.co.uk 1052 5-Jan-15 http://www.mirror.co.uk 96 5-Jan-15 http://www.nydailynews.com 115 5-Jan-15 https://www.theguardian.com 45 6-Jan-15 http://www.dailymail.co.uk 17 8-Jan-15 http://www.nydailynews.com 114 10-Jan-15 http://www.dailymail.co.uk 1 10-Jan-15 http://www.infiniteunknown.net 1466 10-Jan-15 https://www.theguardian.com 1 13-Jan-15 http://whatiswrongwiththispicture2012.blogspot.qa 256 22-Jan-15 http://www.dailyrecord.co.uk 120 22-Jan-15 http://www.huffingtonpost.co.uk 319 22-Jan-15 http://www.irishmirror.ie 338 22-Jan-15 http://www.mirror.co.uk 21 1-Feb-15 http://www.mirror.co.uk 342 7-Feb-15 https://www.theguardian.com 107 21-Sep-15 http://www.nydailynews.com 33 22-Sep-15 http://www.dailymail.co.uk 205 22-Sep-15 http://www.mirror.co.uk 1 15-Jan-16 http://jewishbusinessnews.com 13 15-Jan-16 http://www.dailymail.co.uk 17 15-Jan-16 http://www.nationalenquirer.com 2 15-Jan-16 http://www.nydailynews.com http://www.govtslaves.info 7 n.d. 33,758 ii. As shown in Table 2, the articles containing the statements made against Ms. Giuffre have been shared 33,758 times, mostly on Facebook. iii. Given that the median number of Facebook ‘friends’ is 20026, this equates to a possible 6,751,600 individuals, in addition to the 33,758 individuals who originally shared 26 http://www.pewresearch.org/fact-tank/2014/02/03/6-new-facts-about-facebook/ 29 Case 18-2868, Document 283, 08/09/2019, 2628241, Page431 of 883 the articles, to which the articles containing the statements made against Ms. Giuffre could have been disseminated, assuming these individuals are all unique and have not already read one of the articles. iv. However, I did not include these social media shares in my calculations. v. Since news article viewing follows a power law27 distribution28, there is no direct linear ratio of number of social media shares to readership. There is published research that does report average of views of an article on a news website and also average social media shares29. In a direct calculation with numbers from this article30, 23 articles views per social media share, using 33,758 social media shares, this would be 776,434 article views. However, this ratio would vary by website, number of daily unique visitors, type of news article, time for accumulating shares, and possibly other factors. Plus, this number would not account for the people receiving the social media share that viewed the title, post, and snippet but did not click on the share to view the article on the website, thereby undercounting views of the articles. vi. Also, given the topical nature of the underlying news story, one could expect lower social media sharing but higher article viewing, as people will tend to read articles on such topics privately but not share on social media31. So, I would expect the social media number itself to be an undercount. h. I did not include articles that link to one of the articles containing the statements made against Ms. Giuffre in my calculations of dissemination. Unless the article 27 https://en.wikipedia.org/wiki/Power_law See for example, Tatar, A., de Amorim, M. D., Fdida, S., & Antoniadis, P. (2014). A survey on predicting the popularity of web content. Journal of Internet Services and Applications, 5(1), 1. 29 See for example, Castillo, C., El-Haddad, M., Pfeffer, J., & Stempeck, M. (2014, February). Characterizing the life cycle of online news stories using social media reactions. In Proceedings of the 17th ACM conference on Computer supported cooperative work & social computing (pp. 211223). ACM. 30 Castillo, C., El-Haddad, M., Pfeffer, J., & Stempeck, M. (2014, February). Characterizing the life cycle of online news stories using social media reactions. In Proceedings of the 17th ACM conference on Computer supported cooperative work & social computing (pp. 211-223). ACM. 31 See for example, Agarwal, D., Chen, B. C., and Wang, X. Multi-faceted ranking of news articles using post-read actions. In Proc. of CIKM, ACM (2012), 694-703. 28 30 Case 18-2868, Document 283, 08/09/2019, 2628241, Page432 of 883 directly mentioned the statements made against Ms. Giuffre, I did not include that article in my calculations. So, unless the linking article actually mentioned, referenced, or quoted the statements made against Ms. Giuffre, I did not include it in the calculations. i. Many sites published multiple articles on multiple days that quoted or referenced the statements made against Ms. Giuffre; however, I did not use these multiple publication dates from the same site in my calculations of unique visitor traffic. If a domain published only one article containing the statements against Ms. Giuffre, then I directly used the unique daily visitors number. If a domain published multiple articles concerning the statements against Ms. Giuffre, I did not count the traffic for the subsequent articles containing the statements made against Ms. Giuffre, even though research shows that repeat traffic to websites is generally only about 30%32, meaning that 70% of the traffic would be unique. However, I was not comfortable using this figure given the natural of these sites, which might have higher repeat visitors day-to-day. Therefore, I did not include the unique visitors to multiple articles in my calculations. j. Finally, I did not include the count of people who may been searching and may have seen the statements made against Ms. Giuffre in the search results, without needing to visit the actual articles, as shown in Figure 4. k. Figure 4: Example of search results with the statements made against Ms. Giuffre appearing in the result snippets, requiring no need to visit the articles themselves. 32 Teevan, J., Adar, E., Jones, R. and Potts, M. (2006). History repeats itself: repeat queries in Yahoo's logs. In Proceedings of the 29th annual international ACM SIGIR conference on Research and development in information retrieval (SIGIR '06). ACM, New York, NY, USA, 703-704. 31 Case 18-2868, Document 283, 08/09/2019, 2628241, Page433 of 883 XI. ACCURACY OF THE TRAFFIC VERIFICATION 32 NUMBERS AND ADDITIONAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page434 of 883 59. Concerning the accuracy of the analysis, the number of domains where the statements made against Ms. Giuffre have been disseminated is reliable, as this is straightforward to verify (i.e., the article is either posted on a site or it is not). If anything, this is an undercount, as some domains, for example, may have removed such articles, making them no longer available. There are possibly articles containing the statements that I have not been able to locate by the time that I submitted this report. 60. Concerning traffic numbers for domains, a unique visitor is typically identified by an identifier stored in a text file, which is based on an individual computer’s browser, although more sophisticated methods are also being used. In locating traffic numbers for the domains, I used multiple services when available and attempted to verify via other sources. In case with varying traffic data, I utilized the most conservative (i.e., smallest) number available. 61. I also verified findings from my analysis via other methods and my own experience and training. For example, there are periods of increased publishing of articles containing the statements made against Ms. Giuffre and related stories. One would expect, increases in associated searching during these periods. Using the Google Keyword Tool, which provides search volume for search queries by month, I examined search volume from January 2015 to the date that I filed this report. There was an 54,518% increase in search volume for the keywords Virginia Giuffre Virginia Roberts Ghislaine Maxwell in January 2015, relative to the prior 7 months, in the US, and a 44,822% increase for the United Kingdom (UK) in January 2015, relative to the prior 7 months. This is in line with the increase in posting of articles during the same month33. So, one sees the expected increase in searching for key terms based on the increase posting of articles. 33 Note: I use the US and the UK as sample countries since there are aspect of the story that relate to each country. 33 Case 18-2868, Document 283, 08/09/2019, 2628241, Page435 of 883 62. Figure 5 shows increase in searching volume in January 2015 for the US and UK relative to the previous 7 months. 63. Figure 5: Increase in search volume in January 2015 for the US and UK relative to the previous 7 months for the keyphrase Virginia Giuffre Virginia Roberts Ghislaine Maxwell. XII SUMMARY 64. The statements made against Ms. Giuffre have been disseminated to at least 115 online media or other sites in 178 separate stories or articles with a combined 66,909,965 individual unique visitors from 2 January 2015 to the date that I filed this report, inclusive. More likely than not, this is a conservative estimate. 65. Right to Amend: Although I have had access to materials publicly available pertaining to claims in this dispute, I have not been able to review all the material by the deadline for completion of this report. I reserve the right to review and rely on any such material, including at the time of trial. I also reserve the right to issue a supplemental or an amended report if my review of such material results in any significant change or addition to my opinion. 34 Case 18-2868, Document 283, 08/09/2019, 2628241, Page436 of 883 Respectfully submitted, DATED: 09 September 2016 By Dr. Bernard J. Jansen Professor College of Information Sciences and Technology The Pennsylvania State University University Park, PA, 16802 Phone: 434-249-8687 Email: jjansen@acm.orq URL: http://ist.psu.edu/faculty pages/jjansen/ 35 Case 18-2868, Document 283, 08/09/2019, 2628241, Page437 of 883 Appendix A Curriculum Vitae Full Professor College of Information Sciences and Technology The State University University Park, 16802, USA Voice: +1 -434-249-8687 Fax: 814-865-6426 Email: iiansen@acm.org Linkedln: Blog: Principal Scientist, Social Computing Group, Qatar Computing Research Institute (QCRI), Hamad Bin Khalifa University, Doha, Qatar Affiliate Appointment, Department of Computer Science and Engineering, The State University Affiliate Appointment, Department of Industrial and Manufacturing Engineering, The State University Director, Information Searching and Learning Laboratory, College of Information Sciences and Technology (ISL2), The State University Current Advisory Boards 0 The Technical Assistance Program CLAK Impressions Innoblue Research Research Goal: Increase the effectiveness and ef?ciency for accomplishing information tasks by improving the interaction among people, information, and technology Research Interests: I study the uses and affordances of the Web for information searching and ecommerce, with a focus on interactions among the person, information, and technology. Current active research areas are Web searching, information retrieval, keyword advertising, online marketing, and online social networking within the ecommerce domain. . Sponsored search and keyword advertising . Social media as an information source . Information searching and Web information retrieval Short Bio: Jim has authored or co-authored 250 or so research publications, with articles appearing in a multi-disciplinary and extremely wide range of journals and conferences. He is author of the book, Understanding Sponsored Search: A Coverage of the Core Elements of Keyword 36 Case 18-2868, Document 283, 08/09/2019, 2628241, Page438 of 883 Research Advertising (Cambridge University Press), author of the book Understanding User - Web Interactions Via Web Analytics, co-author of the book, Web Search: Public Searching of the Web, and co?editor of the book Handbook of Research on Weblog Analysis. Jim is a full professor with the College of Information Sciences and Technology at The State University and a Principal Scientist in the social computing group of the Qatar Computing Research Institute, Hamad bin Khalifa University. He is a graduate of West Point and has a in computer science from Texas University, along with master degrees from Texas (computer science) and Troy State (international relations). Jim is editor-in-chief of the journal, Information Processing Management (Elsevier), a member of the editorial boards of seven international journals, former editor-in-chief of the journal, Internet Research (Emerald), and he has served on the research committee for the Search Engine Marketing Professional Organization (SEMPO). He has received several awards and honors, including an ACM Research Award and six application development awards, along with other writing, publishing, research, teaching, and leadership honors. He has served as a Senior Fellow at the Pew Research Center with the Pew Internet and American Life Project and a university expert with the National Ground Intelligence Center. He is a Principle Scientist at the Qatar Computing Research Institute. He has done several consulting projects (log analysis, statistical analysis) and expert witnesses cases (patent litigation, civil litigation, and class action suits) in the areas of keyword advertising, web analytics, co-registration, domain parking, webpage access, webpage history, and online advertising click fraud. Education Computer Science, August 1999 - May 1996 Texas University, College Station, Texas 77843 Dissertation: A Software Agent for Performance Improvement of an Existing Information Retrieval System Advisor: Dr. Udo Pooch M.CS. Computer Science, May 1996 - June 1994 Texas University, College Station, Texas 77843 Research Area: Network Performance and Monitoring M.S. International Relations, August 1994 - June 1992 Troy State University, European Division Research Thesis: National Competitive Advantage B.S. Computer Science, May 1985 - June 1981 United States Military Academy, West Point, New York 10996 Engineering Sequence: Electrical Engineering 37 Case 18-2868, Document 283, 08/09/2019, 2628241, Page439 of 883 Academic Appointments Current - 2014 Current - 2015 2014 - 2011 2014 - 2009 2012 - 2010 2009 - 2003 2003 - 2001 2000 - 1999 1999 - 1998 1998 - 1996 Full Professor, College of Information Sciences and Technology, The State University, University Park, PA, 16802, USA. Principal Scientist, Qatar Computing Research Institute (QCRI), Hamad Bin Khalifa University, Doha, Qatar University Researcher, National Ground Intelligence Center, 2055 Boulders Road, Charlottesville, VA 22911 Associate Professor, College of Information Sciences and Technology, The State University, University Park, PA, 16802, USA. Senior Fellow, Pew Internet and American Life Project, Pew Research Center, 1615 Street, NW Suite 700 Washington, DC 20036 Assistant Professor, College of Information Sciences and Technology, The State University, University Park, PA, 16802, USA. (Previously, School of Information Sciences and Technology) Instructor, School of Information Sciences and Technology, The State University, University Park, PA, 16802, USA Lecturer, Computer Science Program, University of Maryland (Asian Division), Seoul, 104-022, Republic of Korea Assistant Professor, Department of Electrical Engineering and Computer Science, United States Military Academy, West Point, New York, 10996 Lecturer, Department of Electrical Engineering and Computer Science, United States Military Academy, West Point, New York, 10996, USA. Honors and Awards 2016 2016 President's Award for Engagement with Students, The State University, University Park, 2015 Best Paper: Liu, Z. and Jansen, B. J. (2015) Subjective versus Objective Questions: Perception of Question Subjectivity in Social 2015 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP15). Washington DC, p. 131-140. 31 Mar.-3 Apr. 2011 Teaching and Learning with Technology Fellow at Penn State (May 2011 - May 2012). Teaching research fellowship to develop subject-based learning apps that leverage cellular technology, the contextual (location-aware) attributes of mobile technology, and social media. See 38 Case 18-2868, Document 283, 08/09/2019, 2628241, Page440 of 883 Honors and Awards 2011 2010 2008 2008 2007 2004 2003 2003 2002 2002 Paper Award: The article, The Seventeen Theoretical Constructs of Information Searching and Information Retrieval, published in Journal of the American Society for Information Science and Technology selected as John Wiley Best JASIST Paper Award 2011 (see Emerald Literati Network 2010 Award for Excellence for Outstanding Reviewer for the journal Internet Research Best Paper, Jansen, B. J., Zhang, M., and Schultz, C. (2008) The Effect of Brand on the Evaluation of IT System Performance. Proceedings of the Southern Association for Information Systems Conference, Richmond, VA, USA 13-15 March 2008 Presented with a Google Faculty Research Award ($50,000) Article selected as Highly Commended Winner at the Emerald Literati Network Awards for Excellence 2007. Spink, A. and Jansen, B. J. (2006) Searching multiple federate content Web collections, Online Information Review. 30(5), 485-495. Worldwide press coverage for book Web Search: Public Searching of the Web, co- authored with Dr. Amanda Spink. Including AP, Yahoo! News, CNN, MSN, and numerous other television, radio, Web, and print outlets. Worldwide press coverage and interviews 6/30/2003-7/3/2003 reference article: Jansen, B. J., and Spink, A. (2003) An analysis of Web pages retrieved and viewed, Internet Computing: Web Mining Session, Las Vegas, 4-6 June, 2003. Including: BBC, Irish Radio, Washington Times, Today, and several US. radio stations. ISI Most Highly Cited Articles in Field of Web Searching for the manuscript Jansen, B. J., Spink, A., and Saracevic, T. (2000) Real Life, Real Users, and Real Needs: A Study and Analysis of User Queries on the Web, Information Processing_& Management. 38(2), 207-227. The article was identi?ed in May 2003 by ISI Essential Science Indicators to be one of the most cited papers in the research area of Web Searching Behavior. Highly Commended Article invited for journal publication. Jansen, B. J. (2002) Towards Implementing a Cognitive Model of Searching, Proceedings of the E- Learning 2002 Conference (Web Track), Montreal, Canada. 15-19 October. Two Awards of Excellence for outstanding software development in the communications field. 39 Case 18-2868, Document 283, 08/09/2019, 2628241, Page441 of 883 Honors and Awards 2002 2002 2002 2002 2001 2000 1998 1997 1992 1 992 Books Worldwide press coverage and interviews 3/31/02- 4/5/02 reference article: Spink, A., Jansen, B. J., Wolfram, D., and Saracevic, T. (2002). From e-sex to e-commerce: Web search changes, Computer, 35(3), 133-135. Including: Associated Press, BBC, CBC, Wall Street Journal, New York Times, PC World, CNN, Chinese People?s Daily, Toronto Star, US News and World Report, San Francisco Chronicle, The Independent (UK), Business Week, Washington Post, Financial Times (UK), Information Week, Web, TV, newspaper (200+) and magazine media. Award of Distinction for interactive Web site development. Two Awards of Excellence for exceptional multimedia application development. US Army War College Team of the Year for outstanding contributions as team manager. U.S. Army Visual Information Award for multimedia development. Highly Commended Award by MCB Publishers, for: Spink, A., Bateman, J., and Jansen, B. J. (1999) Searching the Web: A survey of Excite users, Journal of Internet Research: Electronic Networking Applications and Policy, 117-128. Top Paper Award for: Spink, A., Bateman, J., and Jansen, B. J. (1998) Users? searching behavior on the Excite Web search engine, 1999 World Conference on the WW and Internet, Orlando, Florida. ACM Student Research Award for: Jansen, B. J. (1997) Simulated Annealing for Query Results Ranking, Computer Science Education Conference, San Jose, CA. 28 30 February. Writing and Research Award, U.S. Marine Corps University. Research Award from U.S. Armv Trainer Journal Jansen, B. J. (2011). Understandinq Sponsored Search: Coveraqe of the Core Elements of Keyword Advertising. Cambridge University Press: Cambridge, UK. Jansen, B. J. (2009) Understanding User Web Interactions via Web Analytics. Morgan- Claypool Lecture Series. Marchionini, G. Morgan-Claypool: San Rafael, CA. Jansen, B. J., Spink, A., and Taksa, I. Editors. (2009) Handbook of Research on Web Log Analysis, Hershey, PA: Idea Group Publishing. 40 Case 18-2868, Document 283, 08/09/2019, 2628241, Page442 of 883 Books Spink, A., and Jansen, B. J. (2004) Web Search: Public Searchinq of the Web, Dordrecht: Kluwer Academic Publishers. Parts of Books Jansen, B. J. (2016) Log Analysis. Research Methods in Libram and Information Science. Libraries Unlimited. Mukherjee, P, Kozlek, B., Gyorke, A., Camplese, C. and Jansen, B. J. (2014) Leveraging Mobile Technology to Enhance Both Competition and Cooperation in an Undergraduate STEM Course. Innovative Practices in Teaching Information Sciences and Technoloqv: Experience Reports and Re?ections. p. 167-178. New York: Springer. Reddy, M. C., Jansen, B. J., Spence, P. R. (2010) Collaborative Information Behavior: Exploring Collaboration and Coordination During Information Seeking and Retrieval Activities. Foster, J. Collaborative Information Behavior: User Engagement and Communication Sharing. p. 73 - 88. Hershey, PA: IGI. Booth, 0., and Jansen, B. J. (2009) A review of methodologies for analyzing Websites. In B. J. Jansen, A. Spink I. Taksa (Eds), Handbook of Web Log Analysis. p. 143-164. Hershey, PA: IGI. Jansen, B. J. (2009) The methodology of search log analysis. In B. J. Jansen, A. Spink I. Taksa (Eds), Handbook of Web log analysis. p. 100-123. Hershey, PA: IGI. Jansen, B. J., Taksa, I., and Spink, A. (2009) Research and methodological foundations of transaction log analysis. In B. J. Jansen, A. Spink I. Taksa (Eds), Handbook of Web L_og Analysis. p. 1-17. Hershey, PA: IGI. Rainie, L., and Jansen, B. J. (2009) Surveys as a complementary method to Web log analysis. In B. J. Jansen, A. Spink l. Taksa (Eds), Handbook of Web Loq Analysis. p. 39- 64. Hershey, PA: IGI. Taksa, Spink, A., and Jansen, B. J. (2009) A review of methods in presented in the handbook of web/0g analysis. In B. J. Jansen, A. Spink I. Taksa (Eds), Handbook of Web Log Analysis. p. -358. Hershey, PA: IGI. Zhang, M., and Jansen, B. J. (2009) Using action-object pairs as a conceptual framework for transaction log analysis. In B. J. Jansen, A. Spink Taksa, I. (Eds), Handbook of Web Log Analysis. p. 416-435. Hershey, PA: IGI. Jansen, B. J. and Spink, A. (2008) Logfile analysis. In International of Communication. Editors: Robin Mansell. Oxford: Blackwell Press. 6. p. 2730-2734. 41 Case 18-2868, Document 283, 08/09/2019, 2628241, Page443 of 883 Parts of Books Jansen, B. J. and Spink, A. (2008) How to Define Searching Sessions on Web Search Engines. In Lecture Notes in Artificial Intelligence, LNAI 4198, Advances in Web Mining and Web Usaqe Analysis. Editors; Olfa Nasraoui, Osmar Zaiane, Myra Spiliopoulou, Bamshad Mobasher, Philip Yu, Brij Masand. p. 92 109. Berlin Heidelberg: Springer-Verlag. Jansen, B. J., Berkheiser, W, Spink, A., and Pedersen, J. (2007) How people search for governmental information on the Web. In: of Diqital Government. Editors: Ari- Veikko Anttiroiko and Matti Malkia. p. 933-939. Hershey, PA: Idea Group Publishing. Wolfe, R., Jansen, B. J., and Spink, A. (2006) Semantics and the medical Web: A review of barriers and breakthroughs in effective healthcare query. In: Advances in Electronic Business. Vol. II. Editors: E. Li and DC. Timon. p. 267-279. Hershey, PA: Idea Group Publishing. Jansen, K. J., Corley, K. G., and Jansen, B. J. (2006) E-Survey methodology: A review, issues, and implications. In of Electronic Surveys and Measurements Editors: Jason D. Baker and Robert Woods. p. 1-8. Hershey, PA: Idea Group Publishing. Jansen, B. J. and Spink, A. (2004) An analysis of documents viewing patterns of Web search engine users, In Web Mining: Applications and Technigues. Editor: Anthony Scime. p. 339-354. Hershey, PA: Idea Group Publishing. Jansen, B. J. (2004) The use of query operators and their effect on the results of Web search engines, In Issues of Human Computer Interaction. Editor: Dr. Anabela Sarmento. p. 50-72. Hershey, PA: Idea Group Publishing. Refereed Journal Articles Coughlin, D. and Jansen, B. J. (2016) Modeling Journal Bibliometrics to Predict Downloads and Inform Purchase Decisions at University Research Libraries. Journal of the Association for Information Science and Technology. Liu, Z., and Jansen, B. J. (2016) ASK: A Taxonomy of Information Seeking Posts in Social Question and Answering. Journal of the Association for Information Science and Technoloqv. Liu, Z., and Jansen, B. J. (2016) Understanding and Predicting Question Subjectivity in Social Question and Answering. Transactions on Computational Social Systems. 32?41. Ortiz-Cordova, A. and Jansen, B. J. (2016) Associating Searching on Search Engines to Subsequent Searching on Sites. International Journal of Information Systems in the Service Sector. 30-43. 42 Case 18-2868, Document 283, 08/09/2019, 2628241, Page444 of 883 Refereed Journal Articles Coughlin, D., Campbell, M., and Jansen, B. J. (2015) A Web Analytics Approach for Appraising Electronic Resources in Academic Libraries. Journal of the Association for Information Science and Technoloqv. 67(3), 518-534. Ortiz-Cordova, A., Yang, Y., and Jansen, B. J. (2015) External to Internal Search: Associating Searching on Search Engines with Searching on Sites. Information Processing Management. 51(5), 718?736. Mukherjee, P, Kozlek, B., Jansen, B. J., Gyorke, A., and Camplese, C. (2014) Designing a Mobile and Socially Networked Learning Assistant for a University-level Keyword Advertising Course. MERLOT Journal of Online l?mingand Teaching. 10(3), 351-373. Yang, Y., Qin, R., Zhang, J., Zeng, D., and Jansen, B. J. (2014) Budget Planning for Coup/ed Campaigns in Sponsored Search. International Journal of Electronic Commerce. 18(3), 39- 66. Mukherjee, P. and Jansen, B. J. (2014) Performance Analysis of Keyword Advertising Campaign Using Gender-Brand Effect of Search Queries. Electronic Commerce Research and Applications. 13(2), 139?149. Jansen, B. J., Liu, Z., and Simon, Z. (2013) The Effect of Ad Rank on Performance of Keyword Advertising Campaigns. Journal of the American Society for Information Science and Technology. 64(10), 2115-2132. Jansen, B. J., Moore, K., and Carmen, S. (2013) Evaluating The Performance of Demographic Targeting Using Gender in Keyword Advertising. Information Processing Management. 49(1), 286-302. Jansen, B. J., Zhang, L, and Mattila, A. S. (2012) Investigating Brand Knowledge of Web Search Engines: User Reactions to Search Engine Logos. Electronic Commerce Research. 12(4), 429-454. Zhang, L, Jansen, B. J., Mattila, A. S. (2012) A Branding Model for Web Search Engines. International Journal of Internet Marketing and Advertisinq. 195 216. Ortiz-Cordova, A. and Jansen, B. J. (2012) Classifying Web Search Queries in Order to Identify High Revenue Generating Customers. Journal of the American Society for Information Science and Technology. 63(7), 1426 1441. Zhang, M., Jansen, B. J., and Chowdhury, A. (2011) Influence of Business Engagement in Online Word-of-mouth Communication on Twitter: A Path Analysis. Electronic Markets: The International Journal on Networked Business. 21(3), 161-175. Jansen, B. J., Sobel, K., and Zhang, M. (2011) The Brand Effect of Key Phrases and Advertisements in Sponsored Search. International Journal of Electronic Commerce. 77- 106. 43 JASIST Best Paper Highly Cited Case 18-2868, Document 283, 08/09/2019, 2628241, Page445 of 883 Refereed Journal Articles Jansen, B. J., Liu, Z., Weaver, 0., Campbell, G. and Gregg, M. (2011) Real Time Search on the Web: Queries, Topics, and Economic Value. Information Processing Management. 47(4), 491-506. Jansen, B. J., Sobel, K. and Cook, G. (2011) Classifying Ecommerce Information Sharing Behaviour by Youths on Social Networking Sites. Journal of Information Science. 37(2), 120- 136. Jansen, B. J. and Schuster, S. (2011) Bidding on the Buying Funnel for Sponsored Search Campaigns. Journal of Electronic Commerce Research. 12(1), 1-18. Kuthuria, A., Jansen, B. J., Hafernik, C. (2010) K-means Clustering to Determine User Intent of Web Queries. Journal of Internet Research: Electronic Networking Applications and Policy. 20(5), 563-581. Rosso, M. A. and Jansen, B. J. (2010) Brand Names as Keywords in Sponsored Search Advertising. Communications of the Association for Information Systems. 27(1), Article 6. Available at: Jansen, B. J., and Rieh, S. (2010) The Seventeen Theoretical Constructs of Information Searching and Information Retrieval. Journal of the American Societv for Information Science and Technology. 61(8), 1517-1534. Jansen, B. J., Tapia, A. H., and Spink, A. (2010) Searching for salvation: An analysis of US religious searching on the World Wide Web, Religion. 40(1), 39-52. Jansen, B. J., Zhang, M, Sobel, K, and Chowdury, A. (2009) Twitter Power: Tweets as Electronic Word of Mouth. Journal of the American Societv for Information Science and Technology. 60(11), 2169-2188. Recognized as one of the top 10 most highly cited papers in JASIST published since 2001 Bar-Ilan.htm Jansen, B. J., Booth, D. and Smith, B. (2009) Using the taxonomy of cognitive learning to model online searching. Information Processing Management. 45(6), 643-663. Tjondronegoro, D., Spink, A., and Jansen, B. J. (2009) A Study and Comparison of Multimedia Web Searching: 1997-2006. Journal of the American Society for Information Science and Technology. 60(9), 1756-1768. Jansen, B. J., Zhang, M., and Schultz, C. (2009). Search engine brand and the effect on user perception of searching performance. Journal of the American Sociey for Information Science and Technology. 60(8), 1572-1595. Flaherty, T. B., Jansen, B. J., Hofacker, C., and Murphy, J. (2009). Insights on the Google Online Marketing Challenge and Its Successful Classroom Implementation. Journal of Online Learning and Teaching, 446-457. 44 Highly Cited Case 18-2868, Document 283, 08/09/2019, 2628241, Page446 of 883 Refereed Journal Articles Jansen, B. J., Booth, D. L., and Spink, A. (2009). Patterns of query modi?cation during Web searching. Journal of the American Society for Information Science and Technology. 60(7), 1358-1371. Jansen, B. J., Flaherty, T.B., Baeza-Yates, R., Hunter, L., Kitts, B., and Murphy, J. (2009). The Components and Impact of Sponsored Search. Computer. 42(5) 98-101. Rosso, M., McClelland, M. K., Jansen, B. J., and Fleming, S. W. (2009) Using Goog/e AdWords in the MBA MIS Course. Journal of Information System Education. 20(1), 41-50. Zhang, Y., Jansen, B. J., and Spink, A. (2009) Identi?cation of factors predicting in Web searching using neural network analysis. Journal of the American Society for Information Science and Technology. 60(3), 557-570. Zhang, Y., Jansen, B. J., and Spink, A. (2009) Time Series Analysis of a Web Search Engine Transaction Log, Information Processing Management. 45(2), 230-245. Jansen, B. J. and Spink, A. (2009) Investigating Customer Click through Behavior with Integrated Sponsored and Non-Sponsored Results, International Jami of Internet Marketing and Advertisement, 74-94. Jansen, B. J., Ciamacca, C., and Spink, A. (2008) An Analysis of travel searching on the Web, Journal of Information Technology and Tourism. 10(2), 101-118. Jansen, B. J. and Mullen, T. (2008) Sponsored search: An overview of the concept, history, and technology, International Journal of Electronic Business. 114 131. Spink, A., and Jansen, B. J. (2008) Trends in searching for business and e-commerce information on Web search engines, International Journal of Electronic Commerce. 154- 161 . Jansen, B. J., Booth, 0., and Spink, A. (2008) Determining the informational, navigational, and transactional intent of Web queries, Information Processing Management. 44(3), 1251- 1266. The most cited article in published since 2008 articlesl) Jansen, B. J. (2008) Searching for digital Images on the Web, Journal of Documentation. 64(1), 81-101. Jansen, B. J. and Eastman, C. (2008) Limitations of advanced searching techniques on Web search engines, Journal of Electronic Resources in Law Librarianship. 55-81. 45 Highly Cited Case 18-2868, Document 283, 08/09/2019, 2628241, Page447 of 883 Refereed Journal Articles Reddy, M. C. and Jansen, B. J. (2008) A model for understanding collaborative information behavior in context: A study of two healthcare teams, Information Processing Management. 44 (1), 256-273. One of the Top 25 most cited articles in published since 2008 articlesl) Jansen, B. J., Zhang, M., and Spink, A. (2007) Patterns and transitions of query reformulation during Web searching, International Journal of Web Information Systems. 328-340. Jansen, B. J., Brown, A., and Resnick, M. (2007) Factors relating to the decision to click-on a sponsored link, Decision Suggort Systems. 44(1), 46-59. Jansen, B. J. and Spink, A. (2007) Sponsored search: Is money a motivator for providing relevant results?, Computer. 40(8), 50-55. Jansen, B. J. (2007) Click fraud. Comguter. 40(7), 85-86. Jansen, B. J. (2007) The comparative effectiveness of sponsored and non-sponsored results for Web ecommerce queries, ACM Transactions on the Web. Article 3. Jansen, B. J., Spink, A., Blakely, C., and Koshman, S. (2007) De?ning a session on Web search engines, Journal of the American Society for Information Science and Technology. 58(6), 862-871. Jansen, B. J., Spink, A., and Koshman, S. (2007) Web searcher interactions with the Dogpile.com meta-search engine, Journal of the American Society for Information Science and Technology. 58(5), 744-755. Jansen, B. J., Mullen, T., Spink, A., and Pederson, J. (2006) Automated gathering of Web information: An in-depth examination of agents interacting with search engines, ACM Transactions on Internet Technology. 442-464. Jansen, B. J. and Resnick, M. (2006) An examination of searcher?s perceptions of non- sponsored and sponsored links during ecommerce Web searching, Journal of the American Society for Information Science and Technology. 57(14), 1949-1961. Koshman, S. Spink, A., Jansen, B. J., Park, M., and Fields, C. (2006) Web Searching on the Vivisimo search engine, Journal of the American Society for Information Science and Technology. 57(14), 1875-1887. Spink, A., Jansen, B. J., Blakely, C., and Koshman, S. (2006) Overlap among major search engines, Journal of Internet Research: Electronic Networking Agglications and Policy. 16(4), 419-426. 46 Paper Award Most Accessed Case 18-2868, Document 283, 08/09/2019, 2628241, Page448 of 883 Refereed Journal Articles Jansen, B. J. (2006) Search log analysis: What is it; what?s been done; how to do it, Library and Information Science Research, 28(3), 407-432. Spink, A., and Jansen, B. J. (2006) Searching multiple federate content Web collections, Online Information Review. 30(5), 485?495. Spink, A., Partridge, H., and Jansen, B. J. (2006) Sexual/pornographic Web searching: Trends analysis, First Monday. 11(9). Jansen, B. J. (2006) Paid search, Computer. 39(7), 88-90. Spink, A., Jansen, B. J., Blakely, C., and Koshman, S. (2006) A study of results overlap and uniqueness among major Web search engines, Information Processing Management. 42(5), 1379-1391. Jansen, B. J. (2006) Using temporal patterns of interactions to design effective automated searching assistance systems, Communications of the ACM. 49(4), 72-74. Jansen, B. J. and Molina, P. (2006) The effectiveness of Web search engines for retrieving relevant ecommerce links, Information Processing Management. 42(4), 1075-1098. Jansen, B. J. and McNeese, M. D. (2005) Evaluating the effectiveness of and patterns of interactions with automated assistance in IR systems, Journal of the American Society for Information Science and Technology. 56(14), 1480-1503. Jansen, B. J. and Spink, A. (2005) How are we searching the World Wide Web?: An analysis of nine search engine transaction logs, Information Processing Management. 42(1), 248- 263. Routinely Iisted as one of the most downloaded articles published in downloaded-articlesl) Spink, A., Park, M., Jansen, B. J., and Pedersen, J. (2005) Multitasking during Web search sessions, Information Processing Management. 42( 1), 264-275. Jansen, B. J., Jansen, K. J., and Spink, A. (2005) Using the Web to look for work: Implications for online job seeking and recruiting, Journal of Internet Research: Electronic Networkinq Applications and Policy. 15(1), 49-66. Jansen, B. J., Spink, A, and Pederson, J. (2005) Trend analysis of AltaVista Web searching, Journal of the American Society for Information Science and Technology. 56(6), 559-570. Jansen, B. J. (2005) Seeking and implementing automated assistance during the search process, Information Processing Management. 41(4), 909-928. 47 Highly Cited Highly Cited Case 18-2868, Document 283, 08/09/2019, 2628241, Page449 of 883 Refereed Journal Articles Jansen, B. J., Spink, A., and Pederson, J. (2005) The effect of specialized multimedia collections on Web searching, Journal of Web @gineering. 182-199. Spink, A. and Jansen, B. J. (2005) A study of Web search trends, Webology. Article 4, Available at: Jansen, B. J. and Spink, A. (2004) An analysis of Web searching by European Al/theweb.com users, Information Processing Management. 41(2), 361-381. Spink, A., Jansen, B. J., and Pedersen, J. (2004) Searching for people on Web search engines, Journal of Documentation. 60, (3), 266-278. Spink, A., Yang, Y., Jansen, B. J., vaanen, P., Ozmutlu, S., and Ozmutlu, C. (2004) Medical and health Web searching: an exploratory study, Health Information and Libraries Journal. 21(1), 44-51. Jansen, B. J. and Pooch, U. (2004) Improving IR system performance using software integration, Journal of Internet Research: Electronic Networking Applications and Policy. 14(1), 19-33. Spink, A., Koricich, A., and Jansen, B. J. (2004) Sexual searching on Web search engines, and Behavior. 65-72. Eastman, C. and Jansen, B. J. (2003) Coverage, relevance, and ranking: the impact of query operators on Web search engine results, ACM Transactions on Information Systems. 21 (4), 383-411. Spink, A., Jansen, B. J., Wolfram, D., and Saracevic, T. (2002) From e-sex to e-commerce: Web search changes, Computer. 35(3), 107-111. Wolfram, D., Spink, A., Jansen, B. J., and Saracevic, T. (2001) Vox popu/i: The public searching of the Web, Journal of the American Society for Information Science aid Technology. 52(12), 1073-1074. Jansen, B. J. and Pooch, U. (2001) Web user studies: A review and framework for future work, Journal of the American Society for Information Science and Technology. 52(3), 235- 246. Recognized as one of the top 10 most highly cited papers in JASIST published since 2001 Spink, A., Wolfram, D., Jansen, B. J., and Saracevic, T. (2001). Searching of the Web: the public and their queries, Journal of the American Society for Information Science and Technology. 52(3), 226-234. Recognized as the most highly cited paper in JASIST published since 2001 48 ISI Paper Award Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page450 of 883 Refereed Journal Articles Brown, G., Fisher, M., Stoll, N., Beeksma, 0., Black, M., Taylor, R., Choe, S., Williams, A., Bryant, W., and Jansen, B. J. (2000) Leveraging a Y2K evaluation to improve information systems architecture, Communications of the ACM. 43(10), 90-97. Jansen, B. J., Spink, A., and Saracevic, T. (2000) Real life, real users, and real needs: A study and analysis of user queries on the Web, Information Processing Management. 36(2), 207-227. Jansen, B. J., Goodrum, A., and Spink, A. (2000) Searching for multimedia: video, audio, and image Web queries, World Wide Web Journal. 249-254. Spink, A., Jansen, B. J., and Ozmutlu, C. (2000) Use of query reformulation and relevance feedback by Web users, Journal of Internet Research: Electronic Networkinq Applications and Policy. 10(4), 317-328. Schmoyer, T. and Jansen, B. J. (2000) An adaptive hypermedia system for improving an organization '3 customer support, WebNet Journal. 30-35. Jansen, B. J. (2000) An investigation into the use of simple queries on Web IR systems, Information Research: An Electronic Journal. Spink, A., Bateman, J., and Jansen, B. J. (1999) Searching the Web: A survey of Excite users, Journal of Internet Research: Electronic Networkinq Applications and Policy. 117- 128. Spink, A., Bateman, J., and Jansen, B. J. (1998) Searching heterogeneous collections on the Web: Behavior of Excite users, Information Research: An Electronic Journal. Jansen, B. J. (1997) Using an intelligent agent to enhance the performance of an information retrieval engine, First Monday. Book Reviews Jansen, B. J. (2008) Book review: Making Sense of Data: A Practical Guide to Exploratory Data Analysis and Data Mining by Glenn J. Myatt. Wiley. 2007 pages 280. $74.95. Information Processinq Manaqement. 44(2), 978-979. Jansen, B. J. (2007) Book review: The Long Tail: Why the Future of Business is Selling Less or More. By Chris Anderson. Hyperion: New York. 2006. $24.95 ISBN: 1-4013-0237-8. Information Processinq Manaqement. 43(4), 1147-1148. 49 Case 18-2868, Document 283, 08/09/2019, 2628241, Page451 of 883 Book Reviews Jansen, B. J. (2007) Book review: The Craft of Research, 2nd edition (Chicago Guides to Writing, Editing, and Publishing) (Paperback) by Wayne C. Booth, Joseph M. Williams, Gregory G. Colomb. Paperback: 336 pages. University of Chicago Press; 2nd edition. ISBN: 0226065685. Information Processinq Management. 43(3), 827-828. Jansen, B. J. (2007) Book review: Effective Expert Witnessing, Fourth Edition, by Jack V. Matson, Suha F. Daou, and Jeffrey G. Soper. 160 pages. CRC. ISBN: 0849313015. $99.95. Information Processing Management. 43(3), 830-831. Jansen, B. J. (2007) Book review: Messages, Meanings and Symbols: The Communication of Information. By Charles T. Meadow. Lanham, MD: Scarecrow Press, 2006. 264 pp. $40.00 (paper). ISBN 0?8108-5271-3. Library and Information Science Research. 29(2), 303-304. Jansen, B. J. (2006) Book review: The Search: How Google and Its Rivals Rewrote the Rules of Business and Transformed our Culture. by John Battelle. Penguin Group. 311 pages. Cost: $25.95. ISBN: 1591840880. Information Processing Management. 42(5), 1399-1401. Jansen, B. J. (2006) Book review: Theories of Information Science Behavior. 2005, Edited by Karen E. Fisher, Sanda Erdelez, and McKechnie. ASIST Monograph Series. Information Today, Inc. Medford, New Jersey. 431 pages. Cost: $49.50. Information Processinq Management. 42(5), 1392-1395. Jansen, B. J. (2005) Book review: Mining the Web: Discovering Knowledge from Hypertext Data, 2002. Soumen Chakrabarti. Morgan-Kaufmann Publishers, 352 pages. Cost: $54.95. ISBN: 1-55860-754?4. Information Processing Management. 42(1), 317-318. Non-refereed Articles Jansen, B. J., Chowdhury, A., and Cook, G. (2010) The Ubiquitous and Increasing/y Signi?cant Status Message. Interactions. May/June, 15-17. Jansen, B. J., Hudson, K., Hunter, L., Liu, F., and Murphy, J. (2008) The Google Online Marketing Challenge: Real-World Learning with Real Clients, Real Money, and Real Advertising Campaigns, Journal of Interactive Advertising. Jansen, B. J. (2008) Sponsored search, International Journal of Electronic Business. 1 12-1 13. Edmonds, A., Hawkey, K., Jansen, B. J., Kellar, M., and Turnbull, D. (2007) Editorial for Special Issue on Logging Traces of Web, Journal of Web Engineering. 193-195. Jansen, B. J. (2006) Paid search as an information seeking paradigm, Bulletin of the American Society for Information Science and Technology. 32(2), 7-8. Spink, A., Ozmutlu, S., Ozmutlu, H. C., and Jansen, B. J. (2002) US versus European Web searching trends, SIGIR Forum. 32(1), 30-37. 50 Case 18-2868, Document 283, 08/09/2019, 2628241, Page452 of 883 Non-refereed Articles Jansen, B. J., Riedt, R., and Turner, J. (2002) Hitting the moving technology target, SIGNAL: International Journal of AFCQ. 56(80), 65. Schmoyer, T. and Jansen, B. J. (2001) Personalized computer interaction improves customer service, SIGNAL: International Journal of 55(9), 63-65. Jansen, B. J. and Spink, A. (2000) Methodological approach in discovering user search patterns through Web log analysis, _Bu etin of the American Society for Information Science and Technology. 27(1), 15-17. Jansen, B. J., Spink, A., Bateman, J., and Saracevic, T. (1998) Real life information retrieval: A study of user queries on the Web, SIGIR Forum. 32(1), 5 -17. 128. Crow, D. and Jansen, B. J. (1998) Seminal works in computer human interaction, SIGCHI Bulletin. 30(3), 24-28. Jansen, B. J. (1998) The graphical user interface: An introduction, SIGCHI Bulletin. 30(2), 22-26. Manuscrigts Accepted for Publication Liu, Z., and Jansen, B. J. (forthcoming) Predicting the Response Rate in Social Question and Answering on Sino Weibo. Information Processing Management. Liu, Z., and Jansen, B. J. (forthcoming) Identifying the Desire to Help: Predicting User Willingness for Knowledge Sharing in Social Question and Answer. Information Processing_& Management. Manuscrigts Submitted for Publication Mukherjee, P. and Jansen, B. J. (under review) Brand Conversing and Brand Searching: A Temporal Analysis of Social Media and Search Concerning Super Bowl 2015 Commercials. Internet Research. Refereed Conference Proceedinqs Brown, A., Lush, B., and Jansen, B. J. (under review) Pixel Efficiency Analysis: A Methodology for Quantitative Web Analytics for Academic Library and Other Non-commercial Websites. The First International Conference on Information Systems and Applications (ICISA2016), Manama, Kingdom of Bahrain. 17-18 Nov. 51 Case 18-2868, Document 283, 08/09/2019, 2628241, Page453 of 883 Refereed Conference Proceedings Kwak, H., An, J. and Jansen, B. J. (2017) Automatic Generation of Personas Using YouTube Social Media Data. Hawaii International Conference on System Sciences (HICSS-50). Waikoloa, Hawaii. 4-7 January. Gao, Y., Reddy, M., and Jansen, B. J. (2017) ShopWithMeI: Collaborative Information Searching and Shopping for Online Retail. Hawaii International Conference on System Sciences (HICSS-50). Waikoloa, Hawaii. 4-7 January. Whitman, A. and Jansen, B. J. (2016) Commercial Consequences of Amazon?s Community Forums: The Case of the Kindle. The Second International Workshop on Online Social Networks Technologies (OSNT-2016), 13th International Conference on Computer Systems and Applications AICCSA 2016. 29 November - 2 December. An, J., Kwak, H. and Jansen, B. J. (2016) Validating Social Media Data for Automatic Persona Generation. The Second International Workshop on Online Social Networks Technologies (OSNT-2016), 13th International Conference on Computer Systems and Applications AICCSA 2016. 29 November - 2 December. Das, A., Das, S.S., Ziegelmayer, J.L., Jansen, B. J. (2016) Attention Allocation and Choice: An Eye?Tracking Study. Annual Meeting of the Society for Judgment and Decision Making (SJDM2016). Boston, Massachusetts, 18-21 November. Brown, A., Lush, B., and Jansen, B. J. (2016) Pixel Efficiency Analysis: A Quantitative Web Analytics Approach. 2016 Annual Meeting of the Association for Information Science and Technology, Copenhagen, Denmark, 14-18 Oct. Mukherjee, P. and Jansen, B. J. (2016) Fonnality Identification in Social Media Dialogue. 2016 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP16). Washington DC p. 375-380. 21 June-1 July. Wong, J.S., Pursel, B., Divinsky, A., and Jansen, B. J. (2016) An Analysis of Cognitive Learning Context in MOOC Forum Messages. ACM Conference on Human Factors in Computing Systems (CHI2016), San Jose, CA, USA, 7-12 May. Gao, Y, Reddy, M., and Jansen, B. J. (2016) Shopping as Searching: Collaborative Web Search in the Ecommerce Domain. ACM Conference on Human Factors in Computing Systems (CHI2016), San Jose, CA, USA, 7-12 May. Mukherjee, P. and Jansen, B. J. (2016) Second Screen Interaction Analysis for IRL Events: Phase-Category Investigation of the Super Bowl 2015 Social Soundtrack. The 7th International Conference on Information and Communication Systems (ICICS 2016). Irbid, Jordan. 5-7 April. Mukherjee, P. and Jansen, B. J. (2015) Correlation of Brand Mentions in Social Media and Web Searching Before and After Real Life Events: Phase Analysis of Social Media and Search Data for Super Bowl 2015 Commercials. International Workshop on Event Analytics Using Social Media Data, International Conference on Data Mining (ICDM2015) Atlantic City, New Jersey. 14-17 Nov., p. 21-26. 52 Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page454 of 883 Refereed Conference Proceedings Wong, J.S., Pursel, B., Divinsky, A. and Jansen, B. J. (2015) Analyzing MOOC Discussion Forum Messages to Identify Cognitive Learning Exchanges. 2015 Annual Meeting of the Association for Information Science Technology. St. Louis, Mo. 6-10 Nov. Liu, Z., and Jansen, B. J. (2015) Analysis of Question and Answering Behavior in Question Routing Services. 21St International Conference on Collaboration and Technology (CRIWG 2015). Yerevan, Armenia. 22 25 Sept., p.72-85. Liu, Z., and Jansen, B. J. (2015) A Taxonomy for Classifying Questions Asked in Social Question and Answering. ACM CHI Conference on Human Factors in Computing (CHI 2015), Seoul, South Korea, 18-23 Apr. Coughlin, D. and Jansen, B. J. (2015) Predicting Downloads of Academic Articles To Inform Online Content Management. 6"1 International Conference on Information and Communication Systems (ICICS2015). Amman, Jordan. 8?9 Apr. Wong, J.S., Pursel, B., Divinsky, A. and Jansen, B. J. (2015). An Analysis of MOOC Discussion Forum Interactions from the Most Active Users. 2015 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP15). Washington DC, p. 452?457. 31 Mar.-3 Apr. Liu, Z., and Jansen, B. J. (2015) Subjective versus Objective Questions: Perception of Question Subjectivity in Social 2015 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP15). Washington DC p. 131-140. 31 Mar.-3 Apr. Mukherjee, P. and Jansen, B. J. (2015) Analyzing Second Screen Based Social Soundtrack of TV Viewers from Diverse Cultural Settings. 2015 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP15). Washington DC p. 375- 380. 31 Mar.-3 Apr. Ortiz-Cordova, A. and Jansen, B. J. (2015) The Relationship Between Searching on Search Engines and Searching on Sites. International Conference on Information Systems and Technologies Istanbul, Turkey. 21-23 March. Mukherjee, P. and Jansen, B. J. (2015) Evaluating Pattern for Group Interactions using Second Screens. In Computing, Networking and Communications Workshop (CNC), 2015 International Conference on Computing, Networking and Communications, Anaheim, CA. 16- 19 Feb. Mukherjee, P. and Jansen, B. J. (2015) Evaluating Classi?cation Schemes for Second Screen Interactions, 2015 International Conference on Computing, Networking and Communications, Anaheim, CA. 16-19 Feb. Mukherjee, P., Wong, J.S., and Jansen, B. J. (2014) Patterns of Social Media Conversations Using Second Screens. The Sixth ASE International Conference on Social Computing (SocialCom 2014). Stanford, CA. 27-31 May. 53 Case 18-2868, Document 283, 08/09/2019, 2628241, Page455 of 883 Refereed Conference Proceedings Liu, Z., and Jansen, B. J. (2014) Predicting Potential Responders in Social Based on non-QA Features. ACM CHI Conference on Human Factors in Computing (CHI 2014), p. 2131-2136. Toronto, Canada. 26 April - 1 May. Ortiz-Cordova, A. and Jansen, B. J. (2014) Linking External and Internal Search: Investigating the Site Searching Patterns of Referred Searchers. ACM CHI Conference on Human Factors in Computing Systems (CHI 2014), p. 1345-1350. Toronto, Canada. 26 April - 1 May. Mukherjee, P. and Jansen, B. J. (2014) Signi?cance of Second Screen Interaction during Television Viewing. The 2013 International Conference on Social Computing, Behavioral- Cultural Modeling, and Prediction (SBP), Washington DC. 2?4 April. Coughlin, D. M., Campbell, M. C., and Jansen, B. J. (2013) Measuring the Value of Library Content Collections. 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Mukherjee, P. and Jansen, B. J. (2013) Gender-Brand Effect of Search Queries on Sponsored Search Performance. 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Ortiz-Cordova, A. and Jansen, B. J. (2013) Site-Searching Strategies of Searchers Referred from Search Engines. 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Liu, Z. and Jansen, B. J. (2013) Question and Answering Made Interactive: An Exploration of Interactions in Social Proceedings of the International Conference on Social Intelligence and Technology 2013 (SOCIETY 2013), p. 1-10. State College, USA, 8 -9 May. Hafernik, C. and Jansen, B. J. (2013) Understanding the speci?city of web search queries. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2013), p. 1845-1850. Paris France, 27 April 2 May. Mukherjee, P. and Jansen, B. J. (2013) The gender-brand effect of key phrases on user clicks in sponsored search. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI 2013), p. 1845-1850. Paris France, 27 April 2 May. Liu, Z. and Jansen, B. J. (2013) Analysis of Factors Influencing the Response Rate in Social Question and Answering. 16th ACM Conference on Computer Supported Cooperative Work and Social Computing (CSCW 2013), p. 1263-1274. 23-27 February. San Antonio, Texas. Liu, Z. and Jansen, B. J. (2012) Almighty Twitter, WhatAre People Asking For?. 75th Annual Meeting of the American Society for Information Science and Technology (ASIST 2012), p.1- 10. 26-30 October. Baltimore, MD. 54 Case 18-2868, Document 283, 08/09/2019, 2628241, Page456 of 883 Refereed Conference Proceedings Carman, S., Strong, R., Chandra, A.., Oh, S., Spangler, S., Anderson, L., and Jansen, B. J. (2012) Predictive Value of Comments in the Service Engagement Process. 75th Annual Meeting of the American Society for Information Science and Technology (ASIST 2012). 26- 30 October. Baltimore, MD. Purao, 8., Storey, V., Maass, W., Jansen, B. J., and Reddy, M. (2012) An Integrated Conceptual Model to Incorporate Information Tasks in Workflow Models. 31st International Conference on Conceptual Modeling (ER 2012). 15-18 October. Florence, Italy. Hafernik, C.T., Cheng, B., Francis, P. and Jansen, B. J. (2011) Mapping User Search Queries to Product Categories. 74th Annual Meeting of the American Society for lnforrnation Science and Technology (ASIST 2011). 9?13 October. New Orleans, LA. Jansen, B. J., Liu, Z. and Simon, Z. (2011) Investigating the Effect of Results Ranking in Sponsored Search. 4th Annual Meeting of the American Society for Information Science and Technology (ASIST 2011). 9-13 October. New Orleans, LA. Tapia, A., Bajpai, K., Jansen, B. J., Yen, J., Giles, C., and Mitra, P. (2011) Seeking the Trustworthy Tweet: Can Microblogged Data Fit the Information Needs of Disaster Response and Humanitarian Relief Organizations. Proceedings of the 8th International Conference on Information Systems for Crisis Response and Management (ISCRAM 2011), 8-11 May, Lisbon, Portugal. Caragea, C., McNeese, N., Jaiswal, A., Traylor, G., Kim, H.W., Mitra, P., Wu, 0., Tapia, A.H., Giles, L., Jansen, B. J., and Yen, J. (2011) Classifying Text Messages for the Haiti Earthquake. Proceedings of the 8th International Conference on Information Systems for Crisis Response and Management (ISCRAM 2011), 8-11 May, Lisbon, Portugal. Jansen, B. J. Sobel, K. and Cook, G. (2011) Being Networked and Being Engaged: The Impact of Social Networking on eCommerce Information Behavior. Proceedings of the iConference 2011, 8?11 February, Seattle, WA, USA. Jansen, B. J. and Booth, D. (2010) Classifying Web Queries by Topic and User Intent. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2010), p. 4285-4290. Atlanta, GA, 10 - 15 April. Jansen, B. J. Sobel, K. and Cook, G. (2010) Gen and Y?s Attitudes on Using Social Media Platforms for Opinion Sharing. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2010), p. 3853-3858. Atlanta, GA, 10 15 April. Jansen, B. J., Campbell, G. and Gregg, M. (2010) Real Time Search User Behavior. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2010), p. 3961-3966. Atlanta, GA, 10 15 April. Jansen, B. J. and Solomon, L. (2010) Gender Demographic Targeting in Sponsored Search. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2010), p. 831-840. Atlanta, GA, 10 15 April. 55 Best Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page457 of 883 Refereed Conference Proceedings Jansen, B. J., Zhang, M., Booth, B. Park, D., Zhang, Y., Kathuria, A. and Bonner, P. (2009) To What Degree Can Log Data Pro?le a Web Searcher? Proceedings of the American Society for Information Science and Technology 2009 Annual Meeting. Vancouver, British Columbia. 6-11 November. Srivatsan, V. R., Purao, S., Jansen, B. J., and He, J. (2009) Systems Developers De?ne their Own Information Needs. 15th Americas Conference on Information Systems. San Francisco, California. 06-09 August. Jansen, B. J., Zhang, M, Sobel, K, and Chowdhury, A (2009) Micro-blogging as Online Word of Mouth Branding. ACM Conference on Computer Human Interaction (CHI2009). p. 3859- 3864. Boston, Massachusetts. 4 - 9 April. Jansen, B. J., Booth, D. and Spink, A (2009) Predicting Query Reformu/ation During Web Searching. ACM Conference on Computer Human Interaction (CHI2009). p. 3907-3912. Boston, Massachusetts. 4 - 9 April. Zhang, M. and Jansen, B. J. (2009) Influences of Mood on lnforrnation Seeking Behavior. ACM Conference on Computer Human Interaction (CHI2009. p. 3395-3400. Boston, Massachusetts. 4 - 9 April. Spink, A. and Jansen, B. J. (2008) The 8th International (Working For E-Business) Conference 2008. Melbourne, Australia. 28 30 November. Reddy, M., Jansen, B. J., and Krishnappa, R. (2008) The Role of Communication in Collaborative Information Searching. 2008 Annual Meeting of the American Society for Information Science and Technology. 24-29 October Columbus, Ohio. Jansen, B. J., Zhang, M., and Schultz, C. (2008) The Effect of Brand on the Evaluation of IT System Performance. Proceedings of the Southern Association for Information Systems Conference, Richmond, VA, USA 13-15 March 2008. Tjondronegoro, D., Spink, A., Jansen, B. J. (2007) Multimedia Searching on the Dogpile Web Meta-Search Engine. ADCS 2007: Australian Document Computing Symposium. Melbourne, Australia. 10 December. Spink, A., and Jansen, B. J. (2007) Commerce Related Web Search: Current Trends, The 18th Australasian Conference on Information Systems. Toowoomba, Australia. 5-7 December. Zhang, Y. and Jansen, B. J. (2007) An Analysis of Searchers? Perceptions of Sponsored and Non-Sponsored Links Using Nested Design, 2007 Annual Meeting of the American Society for Information Science and Technology. Milwaukee, Wisconsin, 18-25 October. Jansen, B. J. (2007) Investigating the Relevance of Sponsored Results, The 30 Annual International ACM Special Interest Group on Information Retrieval. Conference (SIGIR), p. 859 - 860, Amsterdam, the Netherlands. 23-27 July. 56 Case 18-2868, Document 283, 08/09/2019, 2628241, Page458 of 883 Refereed Conference Proceedings Jansen, B. J., Smith, 8., and Booth, D. (2007) Viewing Online Search Within a Learning Paradigm, The 30th Annual International ACM Special Interest Group on Information Retrieval. Conference (SIGIR), p. 859 860. Amsterdam, the Netherlands. 23-27 July. Jansen, B. J., Zhang, M., and Zhang, Y. (2007) Brand Awareness and the Evaluation of Search Results, 16th International World Wide Web Conference p. 1139 1140. Banff, Canada. 8-12 May. Jansen, B. J., Smith, B., and Booth, D. (2007) Understanding Web Search via a Learning Paradigm, 16th International World Wide Web Conference p. 1207 1208. Banff, Canada. 8-12 May. Jansen, B. J., Booth, D., and Spink, A. (2007) Determining the User Intent of Web Search Engine Queries, 16th International World Wide Web Conference p. 1149 1150. Banff, Canada. 8-12 May. Jansen, B. J., Zhang, M., and Zhang, Y. (2007) The Effect of Brand Awareness on the Evaluation of Search Engine Results, Conference on Human Factors in Computing Systems (SIGCHI), Work-in-Progress, p. 2471 - 2476. San Jose, California. 28 April - 3 May. Spink, A., and Jansen, B. J. (2006) Changing Web search trends from 1997 to 2006, Information Online 2007: 13th Exhibition and Conference. Sydney, Australia. 30 January - 1 February. Yan, S., Giles, C. and Jansen, B. J. (2006) Formal De?nitions of Web Information Search, American Society for Information Science Technology 2006 Annual Meeting, p. 1-10. Austin, Texas. 3 - 8 November. Zhang, M., Jansen, B. J., and Spink, A. (2006) Information Searching Tactics of Web Searchers, American Society for Information Science Technology 2006 Annual Meeting. Austin, Texas, p. 1-10. 3 - 8 November. Koshman, S. Spink, A., Jansen, B. J., Blakely, C., and Weber, J. (2006) Metasearch Result Visualization: An Exploratory Study, 2006 Annual Conference of the Canadian Association for Information Science, p. 1-10. Toronto, Canada. 1-3 June. Jansen, B. J., Spink, A., Blakely, C., and Koshman, S. (2006) Investigating Usage of the Vivisimo Clustering Search Engine Interface, The Twelfth Australasian World Wide Web Conference (AUSWEB 06). Noosa Lakes, Australia. 1 -5 July. Spink, A., Jansen, B. J., Blakely, C., and Koshman, S. (2006) Overlap Among Major Web Search Engines, Information Technology: New Generations (ITNG) 2006. p. 370 374. Las Vegas, NV. 10 12 April. 57 Case 18-2868, Document 283, 08/09/2019, 2628241, Page459 of 883 Refereed Conference Proceedings Jansen, B. J., Spink, A., Blakely, C., and Koshman, S. (2005) Web Searcher Interactions with Multiple Federate Content Collections, Proceedings of the 10th Australasian Document Computing Symposium. Sydney, Australia. 12 December. Jansen, B. J., Koshman, S., and Spink A. (2005) An Analysis of Repeat Users of Vivisimo.com, American Society for Information Science Technology 2005 Annual Meeting. Charlotte, North Carolina. 28 October 2 November. Doran, S. G., de Ycaza, S., Eastman, C. and Jansen, B. J. (2005) Finding Nutrition Information on the Web: Coverage vs. Authority, American Society for Information Science Technology 2005 Annual Meeting. Charlotte, North Carolina. 28 October 2 November. Spink, A., Koshman, S. and Jansen, B. J. (2005) Tracking Web Search Trends from 1997 to 2005, Internet Research 6.0: Internet Generations Association of Internet Researchers. Chicago, IL. 5 9 October. Resnick, M, and Jansen, B. J. (2005) An Empirical Study of Paid Search in Product Search and Purchase, The Human Factors and Ergonomics Society 49th Annual Meeting. p. 1429- 1433. Orlando, Florida. 26-30 September. Sharma, H. and Jansen, B. J. (2005) Automated Evaluation of Search Engine Performance via Implicit User Feedback, The 28th Annual International ACM SIGIR Conference on Research and Development in Information Retrieval. p. 649-650. Salvador, Brazil. 15-19 August. Morgan, A., Jansen, B. J., and Trauth, E. (2005) Exploring Individual User Attitudes Towards Performance with Web Search Engines: An Extension Study, Proceedings of the Eleventh Americas Conference on Information Systems. p. 2317 2324. Omaha, Nebraska. 11?14 August. Koshman, S. Spink, A., and Jansen, B. J. (2005) Using Clusters on the Vivisimo Web Search Engine, HCI International 2005. p. 742-747. Las Vegas, Nevada. 22-25 July. Sengupta, S. and Jansen, B. J. (2005) Designing a Value Based Search Engine Using Evolutionary Strategies, 6th International Conference on Information Technology, Coding and Computing, p. 800-805. Las Vegas, Nevada. 11-13 April. Spink, A., Koshman, S., Park, M., Field, C. and Jansen, B. J. (2005) Multitasking Web Search on Vivisimo.com. 6th International Conference on Information Technology, Coding and Computing. p. 486-490. Las Vegas, Nevada, 11-13 April. Eastman, C. and Jansen, B. J. (2004) The Appropriate (and Inappropriate) Use of Query Operators and Their Effect on Web Search Engine Results, American Society for Information Science Technology 2004 Annual Meeting, p. 274-279. Providence, Rhode Island. 13-18 November. 58 Case 18-2868, Document 283, 08/09/2019, 2628241, Page460 of 883 Refereed Conference Proceedings Spink, A., Park, M., Jansen, B. J., and Pederson, J. (2004) Information Task Switching and Multitasking Web Search, Proceedings of the American Society for Information Science Technology 2004 Annual Meeting, p. 213-217. Providence, Rhode Island. 13-18 November. Jansen, B. J. and McNeese, M. D. (2004) Investigating Automated Assistance and Implicit Feedback for Searching Systems, Proceedings of the American Society for Information Science Technology 2004 Annual Meeting, p. 280-286. Providence, Rhode Island. 13-18 November. Jansen, B. J. and McNeese, M. D. (2004) Evaluating the Effectiveness of Automated Assistance for Web Searching, Proceedings of the Human Factors and Ergonomics Society 48th Annual Meeting, p. 1518-1522. New Orleans, Louisiana. 20-24 September. Spink, A., Park, M., Jansen, B. J., and Pederson, J. (2004) Multitasking Web Search on AltaVista, Proceedings of the 5th International Conference on Information Technology, Coding and Computing, p. 309-313. Las Vegas, Nevada. 5-7 April. Jansen, B. J., Spink, A., and Pederson, J. (2003) An Analysis of Multimedia Searching on AltaVista, Proceedings of the 5th ACM SIG Multimedia International Workshop on Multimedia Information Retrieval, p.186-192. Berkeley, California. Jansen, B. J. (2003) Designing Automated Help Using Searcher System Dialogues, Proceedings of the 2003 International Conference on Systems, Man Cybernetics, p. 744-749. Washington, DC. 5-8 October. Jansen, B. J., Spink, A., and Pederson, J. (2003) Web Search Agents: What Are They Doing Out There? Proceedings of the 2003 International Conference on Systems, Man Cybernetics, p. 1410-1416. Washington, D. C. 5-8 October. Jansen, B. J., Spink, A., and Pederson, J. (2003) Monsters at the Gates: When Softbots Visit Web Search Engines, Proceedings of the International Conference on Internet Computing, Lap. p. 620?626. Vegas, Nevada. 23-26 June. Spink, A., Abbas, M., and Jansen, B. J. (2003) Accessing E-commerce Web Information: Implications for Bridging the Digital Divide, The 2003 Canadian Association for Information Science Conference, p. 213-221. Halifax, CA. 28 May-1 June. Jansen, B. J. and Spink, A. (2003) An Analysis of Web Information Seeking and Use: Documents Retrieved Versus Documents Viewed, Proceedings of the International Conference on Internet Computing, p. 65-69. Las Vegas, Nevada, 23-26 June. Jansen, B. J. (2003) Operators Not Needed? The Impact of Query Structure on Web Searching Results, Information Resource Management Association International Conference, p. 814-817. Philadelphia, PA, 18?21 May. Duran, S., Eastman, C., and Jansen, B. J. (2003) Nutritional Information on the Web: An Analysis of Information Sought and Information Provided, Information Resource Management Association International Conference, p. 106-108. Philadelphia, PA. 18-21 May. 59 Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page461 of 883 Refereed Conference Proceedings Jansen, B. J. and Spink, A. (2003) Retrieving and Viewing Web Documents, The 2003 National On/ine Meeting, p. 55-57. New York, New York, 6-8 May 2003. Jansen, B. J. and Eastman, C. (2003) The Effects of Search Engines and Query Operators on Top Ranked Results, The 4th International Conference on Information Technology, Coding and Computing, p. 135-139. Las Vegas, Nevada, 28-30 April. Jansen, B. J. and Kroner, G. (2003) The Impact of Automated Assistance on the Information Retrieval Process, The ACM SIGCHI 2003 Conference on Human Factors in Computing Systems, p. 1004-1006. Fort Lauderdale, Florida, 5-10 April. Jansen, B. J. (2002) Towards Implementing a Cognitive Model of Searching, Proceedings of the E-Learning 2002 Conference (Web Track), p. 493-521. Montreal, Canada, 15-19 October. Jansen, B. J. (2002) A Preliminary Mapping of Web Queries Using Existing Image Query Schemes, Proceedings of the E-Learning 2002 Conference (Web Track), p. 485-492. Montreal, Canada, 15-19 October. Jansen, B. J., Spink, A., and Pfaff, A. (2000) Linguistic Aspects of Web Queries, Proceedings of the Annual Meeting of the American Society of Information Science, p. 169-176. Chicago, IL. 13-16 November. Jansen, B. J., Spink, A., Goodrum, A., and Pfaff, A. (2000) Web Query Structure: Implications for IR System Design, Proceedings of the 4th World Multiconference on Systems, Cybernetics and Informatics, p. 50-55. Orlando, FL. 23-26 July. Jansen, B. J. (1999) A Software Agent for Performance Improvement of Existing Information Retrieval Systems, Proceedings of the 1999 International ACM Conference on Intelligent User Interfaces, p. 122-123. Los Angeles, CA. 5-8 January. Smith, T. L., Ruocco, A., and Jansen, B. J. (1999) Digital Video in Education, Proceedings of the ACM Computer Science Education Conference, p. 122-126. New Orleans, LA. 21-25 February. Jansen, B. J., Spink, A., and Saracevic, T. (1999) The Use of Relevance Feedback on the Web: Implications for Web IR System Design, 1999 World Conference on the WW and Internet, Honolulu, Hawaii. 24-30 October. Jansen, B. J. and Pooch, U. (1999) A Software Agent for Performance Improvement of an Existing Information Retrieval Engine, 5th International Conference on Information Systems Analysis and p. 58-60. Orlando, Florida. 31 July-4 August. Adams, W. J., Jansen, B. J., and Smith, T. L. (1999) Planning, Building, and Using a Distributed Digital Library, Third International Conference on Concepts in Library and Information Science, p. 10-18. Dubrovnik, Croatia. 23-26 May. 60 Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page462 of 883 Refereed Conference Proceedings Smith, T. L., Wolfe, D., and Jansen, B. J. (1999) Digital Video in a Twenty-First Century Classroom, Proceedings of the Information Resources Management Association Conference, Hershey, PA. 16-19 May. Adams, W. J. and Jansen, B. J. (1998) Distributed Digital Library architecture: The Key to Success for Distance Learning, Proceedings of the Conference on Research Issues in Data Engineering, p. 2-8. Orlando, Florida. 23-24 February. Spink, A., Chang, 0., Goz, A., and Jansen, B. J. (1998) User' Interactions with the Excite Web Search Engine: A Query Reformulation and Relevance Feedback Analysis, Proceedings of the Canadian Association of Information Science Conference, p. 342-354. Vancouver, Canada. 5 ?10 June. Jansen, B. J., Spink, A., and Saracevic, T. (1998) Searchers, the Subjects They Search, and Sufficiency: A Study of a Large Sample of Excite Searches, Proceedings of the 1998 World Conference on the WW and Internet, Orlando, Florida. Spink, A., Bateman, J., and Jansen, B. J. (1998) Users? Searching Behavior on the Excite Web Search Engine, 1998 World Conference on the WW and Internet, Orlando, Florida, November. Howard, R. and Jansen, B. J. (1998) A proxy server experiment: an indication of the changing nature of the Web, Proceedings of the Seventh International Conference on Computer Communications and Networks, p. 646-649. Lafayette, Louisiana. 12-15 November. Adams, W. J., Jansen, B. J., and Zoller, R. (1998) Usability Measurements in an Undergraduate Programming Course, Software Engineering Conference, Las Vegas, Nevada. Jansen, B. J., Spink, A., and Saracevic, T. (1998) Failure analysis in Query Construction: Data and Analysis from a Large Sample of Web Queries, Proceedings of the 3rd ACM Conference on Digital Libraries, p. 289-290. Pittsburgh, PA. 23-26 July. Spink, A., Bateman, J., and Jansen, B. J. (1998) User's Searching Behavior on the EXCITE Web Search Engine, Proceedings of the 19th National Online Meeting, p. 375-386. New York, NY. 12-14 May 1997. Adams, W. J., Howard, R., and Jansen, B. J. (1998) Distributed Digital Libraries: The Key to Success for Distance Learning, Computers and Technology in Education, 1 -5 May. Cancun, Mexico. Jansen, B. J. (1997) An Information Retrieval Application for Simulated Annealing, Proceedings of the 2nd ACM Conference on Digital Libraries, p. 259-260. Philadelphia, PA. 25-28 July. Jansen, B. J. (1997) Simulated Annealing for Query Results Ranking, Computer Science Education Conference, San Jose, CA. 28 30 February. 61 Case 18-2868, Document 283, 08/09/2019, 2628241, Page463 of 883 Refereed Conference Proceedings Spink, A., Burkett, L., Spaid, N., Bateman, J., and Jansen, B. J. (1997) Why Users Search the World Wide Web The EXCITE Study, First Internet Librarian Conference, Monterey, CA. 16-18 November. Adams, W. J. and Jansen, B. J. (1997) Information Technology and the Classroom of the Future, Proceedings of the Society for Information Technology in Education Conference, Orlando, Florida. 7 May. Hamilton, J. A. and Jansen, B. J. (1997) Tactical Network Simulation in the US Army, Simulation Multi-Conference, Atlanta, Georgia. January. Jansen, B. J. and Hamilton, J. A. (1997) Modeling and Simulating an Army lnforrnation Support Structure, Simulation Multi-Conference, Atlanta, Georgia. January. Papers Presented at Technical and Professional Meetings An, J., Cho, H.Y., Kwak, H., and Jansen, B. J. (2016) Towards Automatic Persona Generation Using Social Media. The Third International Symposium on Social Networks Analysis, Management and Security (SNAMS 2016), The 4th International Conference on Future Internet of Things and Cloud. 22-24 August. Mukherjee, P. and Jansen, B. J. (2016) The Changing Nature of Viewership: Formality of Social Media Conversations. Workshop on Following user pathways: Using cross platform and mixed methods analysis in social media studies. ACM Conference on Human Factors in Computing Systems (CHI2016), San Jose, CA, USA, 7-12 May. Kwon, S., Abbar, S. and Jansen, B. J. (2016) Identifying Virality Attributes of Arabic Language News Articles. Qatar Foundation Annual Research Conference 2016 Doha, Qatar. 22 March. An, J., Kwan, H., Cho, H., Hassen, M.Z., and Jansen, B. J. (2016) Efforts Towards Automatically Generating Personas in Real-time Using Actual User Data. Qatar Foundation Annual Research Conference 2016 Doha, Qatar. 22 March. Mukherjee, P. and Jansen, B. J. (2015) Correlation of Brand Mentions in Social Media and Web Searching Before and After Real Life Events: Phase Analysis of Social Media and Search Data for Super Bowl 2015 Commercials. 1st International Workshop on Event Analytics using Social Media Data at The International Conference on Data Mining series (ICDM 2015), Atlantic City, New Jersey, USA, 14 Nov. Mukherjee, P. and Jansen, B. J. (2015) Analyzing the Social Soundtrack From Second Screens Before, During, and After Real-life Events. The First International Workshop on Online Social Networks Technologies, 2015 Jordan Conference on Applied Electrical Engineering and Computing Technologies (AEECT), Dead Sea, Jordan. 3-5 Nov. 62 Case 18-2868, Document 283, 08/09/2019, 2628241, Page464 of 883 Papers Presented at Technical and Professional Meetings Jansen, B. J., Wong, J. 8., Jablokow, K.W., Divinsky, A., Liu, Z., and Pursel, B. (2014) Classifying MOOC Discussion Forum Posts as Information Seeking Interactions and Levels of Cognitive Learning. Workshop on Learning at Scale at ACM CHI Conference on Human Factors in Computing Systems, (CHI 2014), Toronto, CA. 26 April - 1 May. Liu, Z. and Jansen, B. J. (2012) Factors In?uencing the Response Rate in Social Question and Answering Behavior. Workshop on Social Media Question Asking at 16th ACM Conference on Computer Supported Cooperative Work and Social Computing (CSCW 2013). 23-27 February. San Antonio, Texas. Jansen, B. J. (2012) Gender Demographic Targeting in Sponsored Search. INFORMS International 2012. 24-27 June. Beijing, China. Jansen, B. J. (2012) Using Mobile Apps to Enhance Classroom Learning. Teaching and Learning with Technology, University Park, PA, 24 March Rosso, M. and Jansen, B. J. (2010) Smart Marketing or Bait Switch? Competitors? Brands as Keywords in Online Advertising. 4th Workshop on Information Credibility on the Web (WICOW 2010). World Wide Web Conference (WW 2010), Raleigh, NC. 26-30 April. Jansen, B. J. (2009) System Controlled Assistance for Improving Search Performance. Human-Computer Interaction and Information Retrieval. Workshop. Washington, DC. 23 October. Jansen, B. J., Zhang, M, Sobel, K, and Chowdury, A, (2009) The Commercial Impact of Social Mediating Technologies: Micro-b/ogging as Online Word-of-Mouth Branding. ACM Conference on Computer Human Interaction (CHI2009). Boston, Massachusetts. 4 - 9 April. Neale, L., Hunter, L., Jansen, B. J., Murphy, J. (2008) The Google Online Marketing Challenge: A Global Teaching and Learning Initiative. 2008 Society for Marketing Advances Annual Conference. 4-9 November. St Petersburg, Florida. Jansen, B. J., Rosso, M., Russell, D., and Detlor, B. (2008) The Google Online Marketing Challenge: A Multi-Disciplinary Global Teaching and Learning Initiative Using Sponsored Search. 2008 Annual Meeting of the American Society for Information Science and Technology. 24-29 October Columbus, Ohio. Jansen, B. J. (2008). Viewing Searching Systems as Learning Systems. Second Workshop on Human-Computer Interaction and Information Retrieval. 23 October. Redmond, Washington. Murphy, J., Canhoto, A., Hofacker, C., Hunter, L., Jansen, B. J., and Voorhees, C. (2008) The Google Online Marketing Challenge: A Global Teaching and Learning Initiative. 2008 American Marketing Association Summer Marketing Educators' Conference. 8-11 August. San Diego, California. 63 Case 18-2868, Document 283, 08/09/2019, 2628241, Page465 of 883 Papers Presented at Technical and Professional Meetings Reddy, M. and Jansen, B. J. (2008) Learning about Potential Users of Collaborative Information Retrieval Systems. Workshop on Collaborative Information Retrieval, Joint Conference on Digital Libraries (JCDL 2008). 19 June. Pittsburgh, Jansen, B. J., Bhavnani, S., Murray, G. C., Spink, A. and Wolfram, D. (2007) Web Log Analysis Panel, 2007 Annual Meeting of the American Society for Information Science and Technology. Milwaukee, Wisconsin. 18?25 October. Spink, A. and Jansen, B. J. (2007) Web Research - Results from Large-Scale Web Data Analysis, ARC Research Network Enterprise Information Infrastructure Workshop on Data From the Field. Sydney, Australia. 24th May. Jansen, B. J. and Spink, A. (2007) The Effect on Click-through of Combining Sponsored and Non-Sponsored Search Engine Results in a Single Listing, 16th International World Wide Web Conference Workshop on Sponsored Search Auctions. Banff, Canada. 8- 12 May. Paper: Jansen, B. J. (2007) Preserving the Collective Expressions of the Human Consciences, 16th International World Wide Web Conference Workshop on Query Log Analysis: Social and Technical Challenges. Banff, Canada. 8-12 May. Paper: Slides: Jansen, B. J., Smith, B., and Booth, D. (2007) Learning as a Paradigm for Understanding Exploratory Search, Conference on Human Factors in Computing Systems (SIGCHI Workshop on Exploratory Search Interfaces. San Jose, California. 28 April - 3 May. Spink, A., Alvarado-Albertorio, F., and Jansen, B. J. (2007) Web Search Behavior: What is Normative?, Society of Australasian Social (SASP) Conference. Brisbane, Australia. 12 15 April. Jansen, B. J. and Spink, A. (2006) Characteristics of searching on Web meta-search engines, American Society for Information Science and Technology: Human Computer Interaction Workshop. Austin, TX. 3-9 November. Jansen, B. J. (2006) Implications of Trust of Sponsored Links for E-commerce Web Searching, 6th Annual SIG-USE Research Symposium. American Society for Information Science and Technology Annual Conference. Austin, TX. 4 November. Spink, A. and Jansen, B. J. (2006) Web Searching: Trends and Impacts, Oxford Internet Institute International Symposium. Journal of Information, Communication, Society: 10th Anniversary International Symposium. University of York, UK. 20 22 September. 64 Case 18-2868, Document 283, 08/09/2019, 2628241, Page466 of 883 Papers Presented at Technical and Professional Meetings Jansen, B. J., Spink, A., Kathura, V., and Koshman, S. (2006) How to De?ne Searching Sessions on Web Search Engines, Workshop on Web Mining and Web Usage Analysis. The 12th ACM SIGKDD International Conference on Knowledge Discovery and Data Mining (KDD 2006). Philadelphia, 20-23 August. Jansen, B. J. (2006) Adversarial Information Retrieval Aspects of Sponsored Search, Second International Workshop on Adversarial Information Retrieval on the Web (AlRWeb 2006). The 29th Annual International ACM SIGIR Conference on Research Development on Information Retrieval (SIGIR2006). Seattle, Washington. 6-11 August. Jansen, B. J., Ramadoss, R. Zhang, M., and Zang, N. (2006) Wrapper: An Application for Evaluating Exploratory Searching Outside of the Lab, SIGIR 2006 Workshop on Evaluating Exploratory Search Systems. The 29th Annual International ACM SIGIR Conference on Research Development on Information Retrieval (SIGIR2006). Seattle, Washington. 6-11 August. Buzikashvili, N. and Jansen, B. J. (2006) Limits of the Web Log Analysis Artifacts, Workshop on Logging Traces of Web Activity: The Mechanics of Data Collection, The Fifteenth International World Wide Web Conference 2006). Edinburgh, Scotland. 22-26 May. Jansen, B. J. (2006) The Wrapper: An Open Source Application for Logging User? System Interactions during Searching Studies, Workshop on Logging Traces of Web Activity: The Mechanics of Data Collection. The Fifteenth International World Wide Web Conference (WW 2006). Edinburgh, Scotland. 22?26 May. Jansen, B. J., Rieh, S.Y., Spink, A., Wang, P., and Wolfram, D. (2005) Panel Presentation: Internet Usage Transaction Log Studies: The Next Generation, American Society for Information Science Technology 2005 Annual Meeting. Charlotte, North Carolina. 28 October 2 November. Toms, E.L., Jansen, B. J., and Muresan, G. (2005) Panel Presentation: Evaluating Success in Search Systems, American Society for Information Science Technology 2005 Annual Meeting. Charlotte, North Carolina. 28 October 2 November. Jansen, B. J. (2005) A Mum-Disciplinary, Multi-Level, and Multi-Spectrum View of Interaction, The First Conference of the i-School Community: Bridging Disciplines to Confront Grand Challenges. 28-30 September 2005, State College, PA. Jansen, B. J. and Resnick, M. (2005) Examining Searcher Perceptions of and Interactions with Sponsored Results, Workshop on Sponsored Search Auctions, The Sixth ACM Conference on Electronic Commerce Vancouver, Canada. 5-8 June. Jansen, B. J. (2005) Automated Searching Assistance for Exp/oratory Search, Seminar on Exploratory Search Interfaces at the University of Maryland sponsored by the Human- Computer Interaction (HCI) Lab. College Park, Maryland. 2 June. 65 Case 18-2868, Document 283, 08/09/2019, 2628241, Page467 of 883 Papers Presented at Technical and Professional Meetings Shingle, A. Jansen, B. J., and Spink, A. (2005) Television Advertising of Prescription Drugs: A Study of Its Effect on Consumer Web Searching, 6th International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada, 11-13 April, 2005. Jansen, B. J., Spink, A., and Pederson, J. (2004) An Analysis of Multimedia Searching on AltaVista, Presentation at Workshop on User Searching, World Wide Web Conference, New York, New York, 18 May 2004. De Ycaza, 8., Doran, S., Eastman, C., and Jansen, B. J. (2003) Nutritional Information on the Web: An Analysis of Information Sought and Information Provided, South Carolina Nutrition Research Summit, Columbia, SC. 17 October 2004. Jansen, B. J. (1998) An Analysis of User Queries on the Web: The Implications for the Design of Military Information Retrieval Systems, Fifth Annual US Army Research Laboratory and United States Military Academy Technical Symposium, West Point, New York. Jansen, B. J. (1997) Simulated Annealing in Information Retrieval, Fifth Annual US Army Research Laboratory and United States Military Academy Technical Symposium, West Point, New York. Adams, W. J. and Jansen, B. J. (1997) Integrating Usability Design Principles into an Existing Engineering Curriculum, The American Society for Engineering Education National Conference, Milwaukee, Wisconsin. Jansen, B. J. and Adams, W. L. (1997) Integrating User Centered Design into an Introductory Engineering Course, American Society for Engineering Education Zone 1 Meeting, West Point, New York. Scholarly Reports Jansen, B. J. (201 1) The civic and community engagement of religiously active Americans. Pew Internet American Life Project, Pew Research Center. 13 December. Jansen, B. J. (2010) 65% of Internet Users Have Paid for Online Content. Pew Internet American Life Project, Pew Research Center. 30 December. Jansen, B. J. (2010) Use of the internet by higher income households. Pew Internet American Life Project, Pew Research Center. 24 November. Jansen, B. J. (2010) Online Product Research. Pew Internet American Life Project, Pew Research Center. 29 September. 66 Case 18-2868, Document 283, 08/09/2019, 2628241, Page468 of 883 Funded ProiectsI GrantsI Commissions, and Contracts 2015 - 2014 Title: Web Analytics for a Research University Library Granting Agency: Penn State, University Library Total Amount: $19,717 Role: Principal Investigator 2015 - 2013 Title: Exploring Scholarly Discourse in MOOC Discussion Forums Granting Agency: Penn State, Center for Online Innovation in Learning Total Amount: $30,383 Role: Principal Investigator 2014 - 2010 Title: Broadband to Support SMEs in Granting Agency: Commonwealth of Total Amount: $500,000 Role: Faculty Investigator ($70,000) 2014 - 2010 Title: Semantic CiteSeerX Granting Agency: National Science Foundation Total Amount: $1,100,000 Role: Principal Investigator ($130,000) 2011 - 2008 Title: Affective and Cognitive Factors Affecting the Evaluation of Search Engines by Users Granting Agency: Google Amount: $50,000 Role: Principal Investigator 2011 - 2009 Title: Using Keyword Advertising for Economic and Workforce Development Granting Agency: The State University Amount: $25,000 Role: Principal Investigator 2011- 2010 Title: Toolkits for Deployable Best Practices Granting Agency: Office of Naval Research STTR Phase II Total Amount: $750,000 Role: Principal Investigator ($87,500) 2011- 2010 Title: RAPID: Text Message-based Infrastructure for Emergency Response Granting Agency: National Science Foundation Total Amount: $75,000 Role: Principal Investigator ($15,000) 67 Case 18-2868, Document 283, 08/09/2019, 2628241, Page469 of 883 Funded ProiectsI GrantsI Commissions, and Contracts 2009 - 2008 Title: Toolkits for Deployable Best Practices Granting Agency: Office of Naval Research STTR Phase I Total Amount: $100.000 Role: Principal Investigator ($15,000) 2009 - 2007 Title: REU Supplement for CRI: Collaborative: Next Generation CiteSeer Granting Agency: National Science Foundation Amount: $12,000 Role: Co-Principal Investigator 2009 - 2006 Title: Interactions Among Users, Systems, and Information Granting Agency: Air Force Research Lab Amount: $463,000 Role: Principal Investigator 2008 - 2005 Title: The Next Generation CiteSeer Granting Agency: National Science Foundation Amount: approximately $1,444,984 Role: Co-principal Investigator with Dr. Lee Giles, Dr. Susan Gauch, and Dr. Jack Carroll ($48,701) 2009 - 2007 Title: Triggers in Collaborative Information Searching Granting Agency: National Science Foundation Amount: $76,000 Role: Co-principal Investigator with Dr. Madhu Reddy ($18,119) 2009 - 2008 Title: REU Supplement for Triggers in Collaborative Information Searching Granting Agency: National Science Foundation Amount: $12,000 Role: Co-principal Investigator with Dr. Madhu Reddy ($6,000) 2007 - 2006 Title: REU Supplement for CRI: Collaborative: Next Generation CiteSeer Granting Agency: National Science Foundation Amount: $9,000 Role: Co-Principal Investigator 2005 - 2004 Title: Design of Tools for Information Seeking, Management, and Analysis for a Lessons Learned Knowledge System Granting Agency: US Marine Corps Research University Amount: $500,000 Role: Co-Principal Investigator ($83,957) 68 Case 18-2868, Document 283, 08/09/2019, 2628241, Page470 of 883 Funded ProiectsI GrantsI Commissions, and Contracts 2005 Title: Knowledge Management Granting Agency: US. Department of Defense, Defense Threat Reduction Agency (DTRA) Amount: $625,832 Role: Co-Principal Investigator 2006 - 2005 Title: REU Supplement for CRI: Collaborative: Next Generation CiteSeer Granting Agency: National Science Foundation Amount: $6,000 Role: Co-Principal Investigator 1998 -1996 Title: The use of software agents in information retrieval. Granting Agency: Army Research Laboratory Amount: $68,000 Role: Principal Investigator ($68,000) 1998 Title: Information Searching on Web Search Engines Granting Agency: Army Research Laboratory Amount: $5,000 Role: Principal Investigator ($5,000) 1997 Title: Software agents for information retrieval. Granting Agency: Army Research Laboratory Amount: $5,000 Role: Principal Investigator ($5,000) Software Developed Software Development: Client-side Application for Automated Searching: that automates searching tactics via user implicit feedback. Software Development: Application for Real-time Evaluation of Search Engine Performance: that automates the evaluation of Web search engines. Teaching At The State University (current 2002), have taught a variety of information technology-related courses, including the undergraduate capstone project leadership course, the introductory freshman course, online marketing, graduate seminar course, and a graduate course on human information interaction. Additionally, I have mentored students in a variety of independent studies and have been on several course development committees. At The State University (current 2002): 69 Case 18-2868, Document 283, 08/09/2019, 2628241, Page471 of 883 Teaching 0 Committee Lead, curriculum development team for a college-level executive masters program. . Committee Lead, curriculum development committee for re-design of the undergraduate senior - level capstone course. 0 Committee Member, curriculum development team for re-design of the undergraduate freshmen level introductory course. . Committee Member, curriculum development team for the establishment of a university-wide Business Analytics minor 0 Faculty Lead, development team for the establishment of a university-wide professional library certification program 0 Committee Member, curriculum development team for the establishment of a college Entrepreneurship minor 0 Course Development: (1) undergraduate capstone course in IT project management, (2) graduate course in information searching, (3) undergraduate course in keyword advertising, (4) graduate course in web analytics, (5) undergraduate course in entrepreneurship technology 2015 Mentor for one team in the Google Final 15 in The Google Online Marketing Challenge for 2014. The team was in the top fifteen from 4,000 teams from around the world (top Mentor for team in the Google Non-pro?t Challenge for 2014. The teams were the top more than 4,000 teams from around the world (top 2014 Mentor for three teams in the Global Final 15 in The Google Online Marketing Challenge for 2013. The teams were in the top fifteen from 4,000 teams from around the world (top Mentor for two teams in the Google Media Marketing Challenge for 2013. The teams were the top more than 4,000 teams from around the world (top 2013 Mentor for one team in the Global Final 15 in The Google Online Marketing Challenge for 2012. The team was in the top fifteen from more than 4,000 teams from around the world (top 2012 Mentor for three teams in the Global Final 15 in The Google Online Marketing Challenge for 2011. The three teams were in the top ?fteen from 4,000 teams from around the world (top 2010 - Mentor for two teams in the Global Final 15 in The Google Online Marketing Challenge for 2009. The two teams were in the top ?fteen from 3,000+ teams from around the world (top Had eight other teams get honorable mention by placing in the Top 100 Global Teams and ?ve other teams place in the Top 10% of all teams. 70 Case 18-2868, Document 283, 08/09/2019, 2628241, Page472 of 883 Teaching 2010 - Mentor for two student teams that took 1St and 3rd in the Penn State ldeaPitch Competition, which is a university wide Penn State entrepreneurship competition. 2009 Mentor for three teams in the Global Final 15 in The Google Online Marketing Challenge for 2009. The three teams were in the top fifteen from 2,107 teams from around the world. Had seven other teams get honorable mention by placing in the top 50 teams in the Americas region. 2009 - Schreyer Honors College Teaching Grant Recipient for developing multi-disciplinary keyword advertising, marketing, and technology course. 2008 - Mentor for the winning team in the Americas region in The Google Online Marketing Challenge for 2008. One of the top four teams from 1,620 teams from around the world. Won a trip to the GooglePlex with the students, plus the students all won laptops. Had two other teams get honorable mention by placing in the top 50 teams in the Americas region. 2008 - Selected as Faculty Marshall by Student Marshall of Computer Science and Engineering Department, College of Engineering, The State University as faculty member who had the biggest impact on student?s academic career 2008 Professor of the Year nominee for College of Information Sciences and Technology, The State University, 16802 2003 Selected as Faculty Marshall by Student Marshall of School of Information Sciences and Technology, The State University as faculty member who had the biggest impact on student?s academic career Guest lecturer for a month (2000) at the Korean Military Academy in Seoul, Republic of Korea. At the University of Maryland (Asian Division) (2000 1999), taught courses on Web/Internet and multimedia design. At the United States Militaly Academy (1999 1996), I taught several computer science- related courses including introductory programming, advanced programming, micro- computing, and databases. Also, mentored students in a variety of independent studies. As executive officer for the department (1999 mid 1997), was responsible for course scheduling, instructor assignments, classroom allocation, student counseling, as well as many other duties concerning the day-to-day operation of the department. 71 Case 18-2868, Document 283, 08/09/2019, 2628241, Page473 of 883 Membership on Degree Committees The State University College of lnforrnation Sciences and Technology Chair or Co-Chair Partha Mukherjee (Committee Chair) degree expected in 2016) Alex Brown (Committee Chair) (MS. degree expected in 2016) Zhe Liu (Committee Chair) degree conferred in 2014) Dan Coughlin (Committee Chair) degree conferred in 2014) Carolyn Hafernik (Committee Chair) (MS. degree conferred in 2013) Adan Ortiz-Cordova (Committee Chair) (MS. degree conferred in 2013) Jian-Syuan Wong (Committee Chair [until 2016]) degree expected in 2018) Steve Carmen (Committee Chair [until 2013]) (MS. degree conferred in 2013) Kathleen Moore (Committee Chair [until 2012]) degree expected in 2015) Mimi Zhang (Committee Chair) degree conferred in 2010) Mike Hills (Committee Chair) degree conferred in 2010) Hyun-Woo Kim (Committee Co-Chair) (MS. degree conferred in 2010) Young Shin Kim (Committee Co-Chair) (MS. degree conferred in 2010) Committee Member Eric McMillan (Committee Member) degree expected in 2017) Nathan McNeese (Committee Member) degree conferred in 2014) Patricia Spence (Committee Member) degree conferred in 2013) Arvind Karunakaran (Committee Member) (MS. degree conferred in 2011) Yusuf Raza (Committee Member) (MS. degree conferred in 2009) Sharoda Paul (Committee Member) degree conferred in 2009) Allison Morgan (Committee Member) degree conferred in 2008) Mithu Bhattacharya (Candidacy Committee Member, 2005) Scott Robertson (Candidacy Committee Chair, 2004) The State University Workforce Education and Development Program, College of Education John Dolan (Committee Co-Chair [until 2012]) degree expected in 2013) The State University School of Hospitality and Management Lu Zhang (Committee Co-Chair) (MS. degree conferred in 2009) The State University Department of Industrial and Manufacturing Engineering Himanshu Sharma (Committee Chair) (MS. degree conferred in 2005) Sourav Sengupta (Committee Chair) (MS. degree conferred in 2005) Ying Zhang (Committee Chair) (MS. degree conferred in 2008) The State University Department of Electrical Engineering Vijay Mohan (Committee Co-Chair) (MS. degree conferred in 2009) Dheepak Ramaswamy (Committee Co-Chair) (MS. degree conferred in 2009) Ashish Kathuria (Committee Chair) (MS. degree conferred in 2007) 72 Case 18-2868, Document 283, 08/09/2019, 2628241, Page474 of 883 Membership on Degree Committees The State University Department of Computer Science and Engineering Yanjun Gao (Committee co-Chair) degree expected in 2018) Chandrika Gopalakrishna (Committee Chair) (MS. degree conferred in 2008) The University of Pittsburgh School of Information Sciences Department of Library and Information Science Zhen Yue (Committee Member) degree conferred in 2014) Minsoo Park (Committee Member) degree conferred in 2008) Rutgers, the State University of New Jersey School of Communication, Information and Library Studies Yuelin Lee (Committee Member) degree conferred in 2008) The State University Schreyer Honors College, thesis advising Megan Krause (8.8. degree expected 2107) Allie Whitman (3.8. degree expected 2106) Adan Ortiz-Cordova (BS. degree conferred 2011) Bradley Shively (BS. degree conferred 2010) Kate Sobel (BS. degree conferred 2010) Steven Troxell (BS. degree conferred in 2008) Steven Clancy (BS. degree conferred in 2007) Paulo Molina (BS. degree conferred in 2004) Chris Catalano (BS. degree conferred in 2004) Andy Shingle (BS. degree conferred in 2004) Supervision of Other Undergraduate Research Student Degree Major University Role Arielle Amchin BS Marketing Penn State Research Mentor Arun Das BS CS Brown University Research Mentor Manlsha BS MIS Carnegie Mellon Qatar Research Mentor Dareddy Satyajit BS CS Bharati Vidyapeeth Narayanan University Research Mentor Will Berkheiser BS IST Penn State Work Study Mentor of-aid/work-study-and- emplovment/work-studv/about Pat Bonner BS IST Penn State Research Mentor Danielle Booth BS IST Penn State Research Mentor Anna Brown BS IST Penn State Research Mentor Nicole Butera BS Chemistry Penn State Women in Science and 73 Engineering Research Case 18-2868, Document 283, 08/09/2019, 2628241, Page475 of 883 Sugervision of Other Undergraduate Research Student Chris Ciamacca Karen Lee Dana Kracow Daehee Park Melissa Reizner Mitchell Rukat Paul Rinaldi Simone Schuster Laura Solomon Meng Ting Sun Pete Smith Megan Tan Courtney VVeaver Degree Professional Service Editorial Boards Current 2016 Current 2016 Current - 2012 Current 2011 Current - 2009 Current 2009 Current 2006 Current 2006 Current 2004 2016 2011 2011 - 2004 Major IST IST IST IST IST IST IST Advertising Advertising Accounting IST Marketing IST University Penn State Penn State Penn State Penn State Penn State Penn State Penn State Penn State Penn State Penn State Penn State Penn State Penn State Role (WISER) Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Editor-in-chief, Information Processing Management (Elsevier) Editorial Board Member, Information Discovery and Delivery Editorial Advisory Board Member, Social Networks Editorial Advisory Board Member, International Journal of Electronic Business Editorial Advisory Board Member, Journal of the American Society for Information Science and Technology Editorial Advisory Board Member, Future Internet Editorial Panel, lntemational Journal of Internet Science Editorial Advisory Board Member, Information Research Editorial Advisory Board Member, Information Processing Management Editor-in-chief, Internet Research (Emerald) Editorial Advisory Board Member, Journal of Internet Research 74 Case 18-2868, Document 283, 08/09/2019, 2628241, Page476 of 883 Professional Service Editorial Boards 2010 - 2004 Editorial Advisory Board Member, Librag and Information Science Journal 2008 - 2004 Associate Editor (Book Reviews), Information Processing Management 1996 ?1998 Student Editor, SIG Computer Human Interaction SIGCHI Bulletin Professional Service Tenure Letters 2016 2016 2015 2013 2013 2012 2012 2012 2010 2009 External Tenure Letter Writer for faculty member of School of Business, McMaster University External Tenure Letter Writer for faculty member of Department of Library and Information Science, The Catholic University of America External Tenure Letter Writer for faculty member of School of Communication and Information, Rutgers University External Tenure Letter Writer for faculty member of College of Information Science and Technology, Drexel University External Tenure Letter Writer for faculty member of Graduate School of Management, University of Haifa External Tenure Letter Writer for faculty member of Faculty of Social Sciences, Bar- Ilan University External Tenure Letter Writer for faculty member of Henry B. Tippie College of Business, The University of Iowa External Tenure Letter Writer for faculty member of School of Business, North Carolina Central University External Tenure Letter Writer for faculty member of School of Business Administration, Bar Ilan University, Israel External Tenure Letter Writer for faculty member of Computer Information Systems Department, Bentley University 75 Reviewer Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page477 of 883 Professional Service Ad hoc Reviewing 2016 2015 2014 2013 2012 2011 2010 2009 Reviewer, Systems, Man and Cybernetics, Computers in Human Behavior, International Journal of Human Computer Interaction. Cornell Hospitality Review Reviewer, Transactions on Intelligent Systems and Technology, Journal of Organizational Computing and Electronic Commerce, European Journal of Marketing, Journal of Information Management, Transactions on Management Information Systems Reviewer, MIS Quarterly. Journal of Organizational Computing and Electronic Commerce, Computers in Hgman Behavior, Journal of Documentation, Systems, Man and Cybernetics, Tourism Management Reviewer, Technologiial Forecasting Social Change, Systems, Man and Cybernetics, International Journal of Electronic Commerce, ACM Transactions on the m, Journal of Interactive Marketing, Journal of Electronic Commerce Research Electronic Commerce Research, Communications of the Association for Information Systems, Transactions on Computer-Human Interaction, Information Research, Information and Mmement Reviewer, Electronic Commerce Research, International Journal of Information Management, Journal of Information Science, Communication Research, International Journal of Internet Science, Journal of Organizational Computing and Electronic Commerce, Social Science Computer Review, Information Research, MIS Quarterly, Journal of Organizational Computing and Electronic Commerce, Library and Information Science, Transactions on Multimedia Advances in Human- Computer Interaction Journal of Theoretical and Applied Electronic Commerce Research ACM Transactions on Computer-Human Interaction Reviewer, Transactions on Multimedia, Information Technology and People, Journal of Computer-Mediated Communication ?ge Publishing, Electronic Commerce Research, International Journal of Electronic Commerce, Journal of Interactive Marketing ACM Transactions on the Web, ACM Transactions on Computer-Human Interaction Reviewer, International Journal of Information Management ACM Transactions on the Web, Social Science Computing Review, MIS Quarterly, International Journal of Human-Computer Studies, One, Information Research, Netherlands Organisation for Scienti?c Research, Computing Surveys, Information Sciences, Future Internet, International Information and Library Review, International Journal of Internet Science, Behaviour Information Technology, Journal of Media Economics 2010 Reviewer, Internet Research Reviewer, The Computer Journal, ACM Transactions on the Web, International Journal of Electronic Commerce, Data Knowledge Engineering Journal, ACM Transactions on Information Systems 76 Case 18-2868, Document 283, 08/09/2019, 2628241, Page478 of 883 Professional Service Ad hoc Reviewing 2008 2007 2006 2005 2005 2004 2003 2002 2001 1999 1998 Reviewer, Journal of the Academy of Marketing Science, ACM Transactions on the Web, ACM Transactions on Information Systems, Decision Support Systems, New Media Society. Internet Computing, Joumal of Service Science and Management, Transactions on Professional Communication, International Journal of Knowledge Management Studies Reviewer, Simulation Modelling Practice and Theory, ACM Transactions on Information Systems Reviewer, Journal of Information Science, ACM Transactions on Information Systems Reviewer, Journal of Medical Internet Research, ACM Transactions on Information Systems Reviewer, Systems, Man and Cybernetics Journal, Computer Networks Journal Reviewer, Information Retrieval, Information Processing Management, Journal of Web Engineering, Journal of Libram Information Science Research Reviewer, Proceedings-Software, Information Processing Management Reviewer, Journal of Informing Science, Information Processing Management, The World Wide Web Journal Reviewer, International Journal of Human Computer Studies, Information Processing Management Reviewer, Information Processing Management Reviewer, Computer Science Education Journal, Information Processing? Management Professional Service Grant Reviewing 2015 2014 2013 2012 Reviewer, Qatar Research Program, Qatar Foundation Reviewer, grant panelist for National Science Foundation, CISE Research Infrastructure (CRI) program February 2014. Reviewer for grant proposal for Reviewer, American Association for the Advancement of Science Research Competitiveness Program Grant Proposal for funding through the Maine Technology Institute's Development Awards Reviewer, Army Research Lab Grant Proposal 77 Case 18-2868, Document 283, 08/09/2019, 2628241, Page479 of 883 Professional Service Grant Reviewing 2011 2011 2010 2010 2008 2007 2007 2004 Reviewer, National Science Foundation Grant Proposal Reviewer, American Association for the Advancement of Science Research Competitiveness Program Grant Proposal for funding through the Maine Technology Institute's Development Awards Reviewer, Standard Research Grants program of the Social Sciences and Humanities Research Council of Canada Grant Proposal Reviewer for grant proposal for Reviewer, American Association for the Advancement of Science Research Competitiveness Program Grant Proposal for funding through the Maine Technology Institute's Development Awards Reviewer, Israel Science Foundation Grant Proposal Reviewer, Air Force Of?ce of Scienti?c Research Grant Proposal Reviewer, Israel Science Foundation Grant Proposal Grant Reviewer, Arts and Humanities Research Board Grant Proposal, Whitefairs, Lewins Mead, Bristol, UK, BS1 2AE Professional Service Other 2016 Special Issue on Computational Advertising, Intelligent Systems. Guest Editors: Yanwu Yang, Huazhong University of Science and Technology, China; Yinghui Yang, University of California, Davis, Bernard J. Jansen, Qatar Computing Research Institute, Mounia Lalmas, Yahoo Labs, UK. 2016 2007 Academic Panelist for The Google Online Marketing Challenge Based on registrations from more than 100 countries and more than 11,000 student teams, the Challenge may be the largest, worldwide educational course ever done. 2015 External Examiner for Spanish thesis (Universitat Pompeu Fabra Barcelona) 2014 2013 Faculty Advisor for the Penn State Digital Marketing Association 2012 External Examiner for Australian thesis (Queensland University of Technology) 2012 - 2011 Member, Research Committee, Search Engine Marketing Professional Organization (SEMPO) 78 Case 18-2868, Document 283, 08/09/2019, 2628241, Page480 of 883 Professional Service Other 2011 2009 Chair of the American Society for Information Science and Technology (ASIST) Information Science Education Committee 2010 Reviewer, Cambridge University Press book proposal 2010 Reviewer, Cambridge University Press book proposal 2010 External Examiner for Australian thesis (University of Sydney) 2009 2006 Chair of the American Society for Information Science and Technology (ASIST) Information Science Education Committee Dissertation Jury 2008 External Examiner for Australian thesis (The University of New South Wales) 2008 External Examiner for Australian thesis (The University of New South Wales) 2008 Guest Editor, International Journal of Electronic Business (IJEB). Special Issue on Sponsored Search 2007 External Examiner for Australian thesis (Monash University) 2007 Guest Editor, with Andy Edmond, Kirstie Hawkey, Melanie Kellar, and Don Turnbull. Journal of Web Enqineerinq. Special Issue on Logging Traces of Web Activity 2006 Guest Editor, Bulletin of the American Sociey for Information Science and Technology. Special Issue on Paid Search, January 2006 1995 -1994 President, Computer Science Graduate Students Association, Texas University, College Station, Texas. Professional Service Conference Activities 2016 Chair, Program Committee, The Second International Workshop on Online Social Networks Technologies (OSNT-2016), 13th International Conference on Computer Systems and Applications AICCSA 2016. 29 November - 2 December. 2016 Chair, Program Committee, The Third International Workshop on Social Networks Analysis, Management and Security (SNAMS - 2016), The 4th International Conference on Future Internet of Things and Cloud (FiCloud-2016), Vienna, Austria. 22-24 August. 2016 Reviewer, Papers and Posters, 79th Annual Meeting of the American Society for Information Science and Technology (ASIST 2016). Copenhagen, Denmark. 14-18 October. 79 Case 18-2868, Document 283, 08/09/2019, 2628241, Page481 of 883 Professional Service Conference Activities 2015 2015 2015 2014 2014 2014 2013 2013 2013 2013 2013 2012 2011 2011 2011 Program Committee, 71" International Joint Conference on Knowledge Discovery, Knowledge Engineering and Knowledge Management, Lisbon, Portugal. 12-14 Nov. Meta-Reviewer, Papers and Posters, 78th Annual Meeting of the American Society for Information Science and Technology (ASIST 2015). St. Louis, Mo. 6-10 November. Reviewer, ACM CHI Conference on Human Factors in Computing Systems, Seoul, South Korea. 18-23 April. Reviewer, Papers and Posters, 77th Annual Meeting of the American Society for Information Science and Technology (ASIST 2014). Montreal, Canada. 31 October - 4 November. Program Committee: 3rd International Information Systems for Crisis Response and Management Conference (ISCRAM 2014), State College, PA. May 2014. Reviewer, ACM CHI Conference on Human Factors in Computing Systems, Toronto, Canada. 26 April 1 May. Reviewer, Papers, 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Reviewer, Posters, 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Reviewer, 22nd International World Wide Web Conference (WW 2013). 13m-17??, May, Rio de Janeiro, Brazil. Program Committee: European Conference on Information Retrieval (ECIR 2013) Workshop on Group Membership and Search (GRUMPS), 24 March, Moscow, Russia Program Committee: Sixth ACM WSDM Conference on Web Search and Data Mining Workshop on Web Search Click Data, 4-8 February, Rome, Italy. Program Committee: Fourth Information Interaction in Context Conference 2012), Nijmegen, the Netherlands, 21-24 August 2012. Session Track Chair, 74th Annual Meeting of the American Society for Information Science and Technology (ASIST 2011). 9-13 October. New Orleans, LA. Program Committee, iConference. Toronto, Canada, 7-10 February. Program Committee: 33rd European Conference on Information Retrieval (ECIR 2011), Best Paper Committee, Dublin, Ireland, 19-21 April 2011 80 Case 18-2868, Document 283, 08/09/2019, 2628241, Page482 of 883 Professional Service Conference Activities 2011 2011 2011 2011 2010 2010 2010 2010 2009 2009 2009 2009 2009 2009 2008 Program Committee: 33rd European Conference on Information Retrieval (ECIR 2011), Workshop on Information Retrieval Over Query Sessions, Dublin, Ireland, 19-21 April 2011. Program Committee: 12th ACM Conference on Electronic Commerce (EC11). San Jose, CA. 5-9 June. Program Committee: Conference on Multilingual and Multimodal Information Access Evaluation (CLEF 2011). Amsterdam, the Netherlands, 19-22 September 2011. Program Committee: 33rd European Conference on Information Retrieval (ECIR 2011). Dublin, Ireland. 18-21 April. Program Committee, American Society for Information Science and Technology Annual Meeting 2010. Pittsburgh, PA. 22-27 October. Program Committee: Conference on Multilingual and Multimodal Information Access Evaluation (CLEF 2010). Padua, Italy, 20-23 September. Program Committee: LREC 2010 Workshop on Web Logs and Question Answering (WLQA2010). Malta, 22 May. Program Committee: 32St European Conference on Information Retrieval (ECIR 2010). Keynes, UK. 28-31 March. Program Committee: Web Information and Data Management. 19th International Conference on Information and Knowledge Management (CIKM 2009). Hong Kong. 6 November. Program Committee: Workshop on the Analysis of System Logs. 22"?1 ACM Symposium on Operating Systems Principles. Big Sky, MT.14 October. Program Committee: Collaborative Information Behavior. GROUP 2000. Sanibel Island, Florida. 10 May. Program Committee: Qualitative and Quantitative Methods in Libraries International Conference (QQML2009). Chania, Crete, Greece, 26-29 May. Program Committee: 31St European Conference on Information Retrieval (ECIR 2009). Toulouse, France. 6-9 April. Reviewer, ACM Conference on Computer Human Interaction 2009 (CHI 2009), Boston, MA, 4 9 April. Reviewer, 18th Conference on Information and Knowledge Management (CIKM 2008). Napa Valley, California. 26-30 October. 81 Case 18-2868, Document 283, 08/09/2019, 2628241, Page483 of 883 Professional Service Conference Activities 2008 2008 2008 2008 2007 2007 2007 2007 2007 2007 2007 2007 2006 2006 2006 Program Committee: Workshop on Human-Computer Interaction and Information Retrieval (HCIR 2008). Redmond, Washington.23 October. Program Committee: 1St Information Interaction in Context Symposium (IiiX 2008). London, United Kingdom. 14-17 October. Program Committee: 2008 Ad Auctions Workshop. ACM Conference on Electronic Commerce in Chicago, IL. 8-9 July. Reviewer, Southern Association for Information Systems Conference (SAIC 2008), Richmond, VA, USA 13?15 March. Program Committee, International Conference on Intelligence and Security Informatics 2007 (ISI 2007), New Brunswick, New Jersey. 23-24 May, 2007 Reviewer, Graphics Interface 2007, Montr?al, Canada, 28 - 30 May 2007. Reviewer, American Society for Information Science and Technology Annual Meeting 2007. Milwaukee, Wisconsin. 18-25 October. Program Committee, 8th Wor1d Congress on the Management of eBusiness. Toronto, Canada. 11-13 July. Program Committee, Workshop on Query Log Analysis: Social and Technological Challenges. World Wide Web 2007, Banff, Alberta, Canada. 8 May. Program Committee, Workshop on Sponsored Search. World Wide Web 2007, Banff, Alberta, Canada. 8 May. Program Committee, Chi?07 Workshop on Exploratory Search and HCI: Designing and Evaluating Interfaces to Support Exploratory Search Interaction. ACM CHI2005, Conference on Human Factors in Computing Systems San Jose, CA. 29 April 2007. Program Committee, Intelligence and Security Informatics Conference (ISI 2007), New Brunswick, NJ. 23 24 May, 2007. Program Committee: 2006 Research Symposium of the Special Interest Group on Human-Computer Interaction. American Society for Information Science and Technology. Austin, Texas. 5 November 5, 2006 Reviewer, Hawaii International Conference on System Sciences 2007. Waikoloa, Big Island, Hawaii. 3-6 January, 2007. Program Committee: Information Technology: New Generations (ITNG) 2006, Las Vegas, NV. 16 -19 April 2007. 82 Case 18-2868, Document 283, 08/09/2019, 2628241, Page484 of 883 Professional Service Conference Activities 2006 2006 2006 2006 2006 2006 2006 2006 Reviewer for SIGIR 2006 Workshop on Evaluating Exploratory Search Systems. The 29th Annual International ACM SIGIR Conference on Research Development on Information Retrieval (SIGIR2006). 6-11 August. Seattle, Washington. Program Committee: 4th International Conference on Information Technology: New Generations, 16-19 April, 2007, Las Vegas, Nevada. Program Committee: 1St Information Interaction in Context Symposium (IiiX symposium). Copenhagen, Denmark. 18-20 October 2006. Program Committee: Information Technology: New Generations (ITNG) 2006, Las Vegas, NV. 10 12 April 2006. Reviewer, The Fourth Annual Workshop on HCI Research in MIS, International Conference on Information Systems, 2005. Reviewer, Human Factors and Ergonomics Society 49th Annual Meeting, 2005. Program Committee: 6th International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada. 5-7 April 2005. Program Committee: the 5 International Conference on Conceptions of Library and Information Science, Glasgow, Scotland, 6-9 June 2005. 2006- 2002 Reviewer, ACM SIGIR International Conference on Information Retrieval. 2006 2005 2005 2004 2004 1998 1998 Session Track Co-chair, Web Searching Sessions (Three tracks), the 5th International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada. 4-6 April 2005. Program Committee, 6th International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada. 5-7 April, 2005. Program Committee, the 5 International Conference on Conceptions of Library and Information Science, Glasgow, Scotland, 6-9 June 2005. Session Track Co-chair, Web Searching Sessions (Three tracks), the 5th International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada. 5-7 April, 2004. Reviewer, ACM CHI2005, Conference on Human Factors in Computing Systems Session Moderator, New Engineering Educators Conference, June 1998, Seattle, Washington. Co-organizer for ACM Computer Science Education Research Competition, February 1998, Atlanta, Georgia. 83 Keynote Keynote Keynote Case 18-2868, Document 283, 08/09/2019, 2628241, Page485 of 883 Professional Service Conference Activities 1998 Reviewer, New Engineering Educators Conference 1998 Reviewer, American Society for Engineering Education National Conference 1997 Session Moderator for American Society for Engineering Education National Conference, June 1997, Milwaukee, Wisconsin. Advisog Boards Current - 2012 CLAK Impressions Current - 2010 The Technical Assistance Program Current - 2010 Innoblue, 2016 - 2007 Global Academic Panel, Google Online Marketing Challenge, 2012 - 2010 Chief Marketing Of?cer (CMO Council) Advisory Board for research initiative, Localize to Optimize Sales Channel Effectiveness 2012 - 2010 Jabbit Board of Advisors, Invited Talks (Selected) Keynote, 2016 Sixth National Doctoral Forum of Information Science, 7-18 July 2016, Tianjin, China. Keynote, The 7th International on Information and Communication Systems (ICICS 2016), 5-7 April, Irbid, Jordan. Keynote, The 10th International ACM Conference on Ubiquitous Information Management and Communication (IMCOM 2016), 4-6 January, Danang, Vietnam. Presentation, Sungkyunkwan University (Sowan Campus), 23 April 2015, Seoul, South Korea. Presentation, National Research University Higher School of Economics, 10 March 2014, St. Petersburg, Russia 84 Keynote Keynote Case 18-2868, Document 283, 08/09/2019, 2628241, Page486 of 883 Invited Talks (Selected) Presentation, Yandex, 11 March 2014, St. Petersburg Russia. Presentation, Sungkyunkwan University (Sowan Campus), 20-21 June 2013, Seoul, South Korea. Presentation, Library and Information Science Department and College of Information and Media, Duksung Women?s College, 19 June 2013, Seoul, South Korea. Presentation, Library and Information Science Department, College of Liberal Arts, Sungkyunkwan University, 18 June 2013, Seoul, South Korea. Presentation, Qatar Computer Research Institute, 24-29 April 2013, Doha, Qatar. Presentation, Department of Decision Sciences, College of Business and Public Administration, Old Dominion University, 14-15 April 2013, Norfolk, VA. Presentation, Google Online Marketing Challenge Workshop, The University of Illinois at Urbana?Champaign, 11 March 2013. Presentation, Casual Living Conference 2012, 22-24 February 2012, Sarasota, FL. Keynote, The Direct Marketing Association of Washington (DMAW) Professor Institute. 34 January 2012, Washington. DC. Presentation, Advance 2011: Rediscovering the Customer. 20?22 September 2011, San Diego, CA. Webinar, Web Analytics Webinar for the American Society for Information Science and Technology, 17 June 2011. Keynote, Buying and Selling eContent 2011. 28 March 2011, Scottsdale, AR. 1/Speakers/JimJansen.aspx Presentation, Evri (semantic news aggregation company). 10 February 2011, Seattle, WA Presentation, IMPAQT (search engine marketing agency). 10 November 2010, Pittsburgh, PA. 85 Keynote Case 18-2868, Document 283, 08/09/2019, 2628241, Page487 of 883 Invited Talks (Selected) Presentation, Yahoo! Research Lab. 9 November 2010, New York, New York. Presentation, School of Communication and Information, Rutgers University. 8 November 2010, New Brunswick, NJ. University-wide Presentation, Ryerson University, 18 October 2009, Toronto, Canada. Presentation, Query Log Analysis: From Research to Best Practice 2009/ 27-28 May. London, UK. Funded by European Union project on Evaluation, Best Practices and Collaboration for Multilingual Information Access. Presentation, Query Log Analysis: From Research to Best Practice 2009/ 27-28 May. London, UK. Funded by European Union project on Evaluation, Best Practices and Collaboration for Multilingual Information Access. Presentation, Google. 30 October 2008. Mountain View, CA. Presentation, IMPAQT (search engine marketing agency). 28 October 2008, Pittsburgh, PA. Presentation, Mahalo (a human power search engine). 6 July 2008, Los Angeles, CA. Presentation, Pepperjam (search engine marketing agency). 24 June 2008, Wilkes-Barre, PA. Presentation, School of Communication and Information, Rutgers University. 2 September 2005, New Brunswick, NJ. Presentation, College of Information, University of North Texas, 15 June 1998. Denton, TX Membership in Professional Societies American Society for Information Science and Technology (ASIST) Armed Forces Communications and Electronics Association (AFCEA) Association for Computing Machinery (ACM) The Institute of Electrical and Electronics Engineers Societies: Computer Society 86 Case 18-2868, Document 283, 08/09/2019, 2628241, Page488 of 883 Professional Experience Numerous consulting projects and expert witnessing (class action suits, patent ligation, and civil ligation) US Army Officer (2002 1985): Held various command and staff positions of progressively increasing responsibility. Responsible for vision articulation, planning, directing, and day-to- day management of organizations ranging in size from 10 to over 200 personnel. Served in numerous locations in the United States, Europe, Central America, and the Far East as a communication of?cer. Responsible for the planning and installation of various types of communication systems including radio, telephone, computer and other digital networks. Served with the 8 US. Army Y2K Operational Evaluation Team validating critical information management systems. Responsible for the long term planning, developing, and budgeting of communication systems of all types for the US. Forces stationed on the Korean Peninsula. Responsible for a 22?person division that develops photographic, graphical, audio-visual and multimedia material for the US. Army War College. Securig Clearance TS-SCI: Cleared for Top Secret information and granted access to Sensitive Compartmental Information based on a single scope background investigation by the Defense Security Service, Of?ce of Personnel Management on 17 March 2011. 87 Case 18-2868, Document 283, 08/09/2019, 2628241, Page489 of 883 Appendix B Testimony Cases Year 2016 Deliverables Testimony Deposition Retained by Plaintiff 2015 Deposition Plaintiff 2014 Deposition Defendant 2014 Testimony, Deposition Defendant 2013 Deposition Plaintiff Case ERIN ANDREWS, Plaintiff, vs MARRIOTT INTERNATIONAL, INC., a Delaware Corporation; WESTEND HOTEL PARTNERS, LLC dba NASHVILLE MARRIOTT AT VANDERBILT UNIVERSITY, a Delaware Limited Liability Company, and MICHAEL DAVID BARRETT, an individual, Defendants. CASE NO. 11C4831, which is pending in the Circuit Court for Davidson County Tennessee at Nashville. Law Firm: Greene Broillet & Wheeler LLP ENCORE MEDIA METRICS, LLC fka SPUR DIGITAL L.P., dba SPUR INTERACTIVE and STEVE LATHAM VS ADOMETRY, INC. fka CLICK FORENSICS, INC. Cause 2012-44351 / Court: 281. (The District Court of Travis County, Texas.) Law Firm: Watts & Guerra LLP and DiNovo Price Ellwanger & Hardy LLP M.B. AS NEXT FRIEND OF J.B., A MINOR Plaintiffs, V. CAMP STEWART FOR BOYS, INC., AMERICAN INSTITUTE FOR FOREIGN STUDY, INC. D/B/A CAMP AMERICA, AND SCOTT ASH JAMES ZIRUS Defendant. NO. 5:12-CV-1133 (Western District of Texas) Law Firm: Rymer, Moore, Jackson, & Echols PC REAL LOCAL PAGE PARTNERS, LLC, Claimant, v. PAYMENT ALLIANCE INTERNATIONAL, INC., Respondent & PAYMENT ALLIANCE INTERNATIONAL, INC. Counter-Claimant, v. REAL LOCAL PAGE PARTNERS, LLC, Counter-Respondent. CASE NO. 32 147 Y 0021413. AMERICAN ARBITRATION ASSOCIATION, MIAMI, FLORIDA Law Firm: Kirkland & Ellis LLP CABLE WHOLESALE.COM, INC. v. SF CABLE, INC. Case No. CV 11-2966 EMC (Northern District of California) Law Firm: Law Offices of James G. Schwartz P.C. 88 Case 18-2868, Document 283, 08/09/2019, 2628241, Page490 of 883 Appendix C Documents Referenced Web Services Alexa www.alexa.com/ Bing Search Engine https://www.bing.com/ Compete https://www.compete.com/ Google Keyword Tool https://adwords.google.com/KeywordPlanner Google Search Engine www.google.com/ Google Trends https://www.google.com/trends/ Microsoft Bing Keyword Tool www.bing.com/toolbox/keywords Million Short https://millionshort.com/ SimiliarWeb www.similarweb.com/ SpyFu www.spyfu.com/ W3Snoop http://www.w3snoop.com/ Documents Agarwal, D., Chen, B. C., and Wang, X. Multi-faceted ranking of news articles using post-read actions. In Proc. of CIKM, ACM (2012), 694-703. Aikat, D. News on the web: usage trends of an on-line newspaper. Convergence: The International Journal of Research into New Media Technologies 4, 4 (Dec. 1998), 94110. BBC News https://en.wikipedia.org/wiki/BBC_News Castillo, C., El-Haddad, M., Pfeffer, J., & Stempeck, M. (2014, February). Characterizing the life cycle of online news stories using social media reactions. In Proceedings of the 17th ACM conference on Computer supported cooperative work & social computing (pp. 211-223). ACM. Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-cv-07433 Daily Mirror https://en.wikipedia.org/wiki/Daily_Mirror GIUFFRE001120 GM_00068 (Gow E-Mail) http://digitalmeasurement.nielsen.com/files/metrics-guidelines.pdf http://www.ebizmba.com/articles/news-websites http://www.mirror.co.uk/news/uk-news/prince-andrews-pal-ghislaine-maxwell-5081971 http://www.nydailynews.com/news/world/alleged-madame-accused-supplying-princeandrew-article-1.2065505 http://www.pewresearch.org/fact-tank/2014/02/03/6-new-facts-about-facebook/ https://www.google.com/advanced_search https://www.thesun.co.uk/archives/news/6754/prince-andrews-pal-ghislaine-groped-teengirls/ Mail Online https://en.wikipedia.org/wiki/Mail_Online Power Law https://en.wikipedia.org/wiki/Power_law Snowball sampling https://en.wikipedia.org/wiki/Snowball_sampling 89 Case 18-2868, Document 283, 08/09/2019, 2628241, Page491 of 883 Tatar, A., de Amorim, M. D., Fdida, S., & Antoniadis, P. (2014). A survey on predicting the popularity of web content. Journal of Internet Services and Applications, 5(1), 1. Teevan, J., Adar, E., Jones, R. and Potts, M. (2006). History repeats itself: repeat queries in Yahoo's logs. In Proceedings of the 29th annual international ACM SIGIR conference on Research and development in information retrieval (SIGIR '06). ACM, New York, NY, USA, 703-704. The Independent https://en.wikipedia.org/wiki/The_Independent The Times https://en.wikipedia.org/wiki/The_Times Triangulation (social science) http://en.wikipedia.org/wiki/Triangulation_%28social_science%29 www.theguardian.com/media/2016/mar/17/independent-mirror-express-and-star-suffer-s harp-fall-in-traffic 90 Cam: 18-7868, 782, 08/00/7010, 7678741, nf 882 EXHIBIT 25 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page493 of 883 À“=ä‹ ÕÃflÃ¤Õ ‹=ÕÃŒ=›Ã ›—ÀŒÃ Õ—ÀÃÿ¤Œ“ ‹=ÕÃŒ=›Ã —⁄ “¤… «—Œ’ =ŒŸ=“=fl ‘Ú Ÿ=À⁄⁄Œ¤Ú –¥ø.,¨.))Ù ÔÎÛN™ÛOÈÏÌÌÛŒ…Õ ™Ú Ÿÿ=Õ‘fl=“¤ ”fl»…¤‘‘ ‹ª)ª,ºø,¨7 ¤»–¤ŒÃ Œ¤–—ŒÃ —⁄ –¤Ã¤Œ ’¤“à —›Ã—fi¤Œ ÓËÃÿÙ Ó0ÔÍ ¤®#ªÆ¨ Œª#±Æ¨ ±) –ª¨ªÆ ’ª,¨ .Æ/.,.ø ‘Ú Ÿ.´))ƪ ™Ú Ÿ6.7¥ø.,ª ”ø®©ª¥¥ . 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david.brown@thetimes.co.uk, nick.alway@bbc.co.uk, To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts - so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschowitz is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. Sent from my BlackBerry?E? wireless device Cam: 18-7868, 782, 08/00/7010, 7678741, nf 882 EXHIBIT 27 (Filed Under Seal) May. 23- 20 100369102868, Document 283, 08/09/2019, 2628241, Page499?bi?1883 0 Page: 1 Document Name: untitled PANEL: A07. ASSIGNMENT HISTORY YEAR: 16 T234 Monday May 23, 2016 9:04 am STDT: ROBERTS, VIRGINIA 3390 GR: 10 ST: I A ENTRY WITHDRAWAL CD DATE OD CD DATE PF SY CL DS SCHL DESC GR PRS ABS UNX R02 101201 W26 030702 02 01 3390 SURVIVORS 10 56' 31 R02 092001 W02 101101 02 01 2331 ROYAL PALM HIG 10 13 1 081401 W32 092001 2 02 A1 2192 HS ADL 30 081600 W47 081301 01 Al 2192 HS ADL 30 062100 W47 081500 00 A1 2192 HS ADL 30 E01 081699 W03 081699 00 01 2331 ROYAL PALM HIG 10 E01 081998 W02 060999 99 01 0581 FOREST HILL H1 09 155 25 E01 082097 W01 061098 98 01 2331 ROYAL PALM HIG 09 147 33 E01 082097 W22 082097 98 01 2191 WELLINGTON HIG 09 R03 040797 W02 061197 97 01 1691 CRESTWOOD MID 08 4O 5 E01 082294 DNE 082294 95 01 1703 ROYAL PINES sc 06 E01 082393 W02 061094 94 01 1901 LOXAHATCHEE EL 05 167 13 E01 082592 W01 061193 93 01 1901 LOXAHATCHEE EL 04 176 4 PAGE PAGE TERML: I1B5 Date: 5/23/2016 Time: 9:05:36 AM Case 18-2868, Document 283, 08/09/2019, 2628241, Page500 of 883 10 - DISTRICT: 0000050 PAIN BEACH SCHOOL DISTRICT SCHOOL: 3390 COURSE INFORMATION FILE: 811131218 2016 DISTRICT: 50 853001.: 0581'. FOREST HILL HIGH YEAR: 1998-1999 GRADE LEVEL: 09 SUBJECT CRSE AREA FLAG cormsnu COURSE TITLE 0500500 P525, QR, SUI DEV 1 1-1. 0701320 1 1001340 MG 2 1200380 MUG 1?3 1900300 DRIVER CLASS 2000310 310 1 2109310 WELD HIST 0500500 DEV 1 0701320 FRENCH 1 0800300 mnm-LIF SK 1001340 2 1300300 ALG 1'8 2000310 BIO 1 2109310 mun HIST 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 00 32% EB 22302: CREDIT, TERM: GPA QTY 2T8 GPA QTY DISRICT-TERM: 1 .2857 5 . 00 C114: 1 . 5719 22. 00 STATE-TERI: 1.2857 9.00 1.5714 22.00 1998-1999 DAYS- PRESENT: 155 ABSENT: 25 SUMMER TERMS DAYS- WENT: 0 0 mmicnm PROMOTE) 50 SCEOOL: 3390 no GOURSIS um YEAR: 1999-2000 GRADE LEVEL: HA GPA QTY PTS GPA QTY DISTRICT-TERM: 1.4286 5.00 1.5425 27.00 mus-7m; 1.4286 5.00 CUR: 1.5429 27.00 1999-2000 MAL 0 0 MR TENS 0 W: 0 RRWTION STATUS NUT MLICABLB <mmn AIT. .50 1.4286 5.00 CUM: 1.5429 27.00 so 50 .00 2000 2001 ANNUAL nave?Pnzsuuwz 0 ABSENT: 50 50 .50 .00 CURRENT DISTRICT: 50 PM BEACH SCHOOL EDGE 3 SGKJOL: 3390 sunvrvoks m2 SCHOOL DISTRICT: YEAR: 50 SCHOOL: 3390 NO COURSE-S TAKEN 2000-2001 LEVEL: MA GPA QTY PTS GPA QTY P135 Tm: 1.4286 5.00 cm: 1.5429 27.00 sums: TERMS DAYS-PRESENT: 0 ABSENT: 0 mu DISTRICT 0500530 1 0 01440 1205370 3300310 8301610 8301650 BHr??H?v-i STATS 2001- -2002 STATUS NI strum 50 SCHOOL: 3390 MVIVORS CHARTER SCHOOL 2001-2002 GRADE 10 CRXDIT 0.50 0.50 0.50 0.50 0.5u 0.50 0.50 0.50 0.50 0.00 1.00 0.00 .50 2.00 0001258 TITLE mm FLAG DEV common MATH WORKPLACE ESSENTIAL V0 3 WORK EXP 1 V0 IORK V0 1" MIT, REM: GPA QTY PIS GPA QTY JIM: 1.4206 5.00 CUM: 1.5429 27.00 1.4206 5.00 CUM: 1.5429 27.00 ANNUAL DAYS- 23mm: 69 ABSENT: 32 SOME TERMS DAYS- 0 ABSENT: 0 m1 IN DISTRICT K-11 31' END OF 5000!; YEAR 96800 W9 Cam: 18-7868, 782, 08/09/7010, 7678741, Pagp?m nf 882 EXHIBIT 28 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page502 of 883 "kn- IMPORTANT MESSAGE .I: . 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IMPORTANT MESSAGE FOR 777/1. 7/4 02 DATE or: MOBILE TELEPHONED CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH BEIUHNED YOUR CALL SPECIALATTENTION MESSAGE 5A001089 SIGNED of ,3 .1 '5 "a'L'Cx'Li (HUFFREOO \fI A Case 18-2868, Document 283, 08/09/2019, 2628241, Page504 of 883 J, i a IMPORTANT MESSAGE . IMPORTANT MESSAGE I FOR FOR - DATE 9 I (of 0) TIME ?P??ox/J?rm DATE .10MOBILE MOBILE I TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL CAME To SEE You WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN ?9 I WANTS TO SEE You RUSH WANTS TO SEE YOU RUSH i RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION I MESSAGE I MESSAGE . 0240/ mac/e h/x? . The UNFIUIEM I) kyf/?? 0140/ LIFE Is m5\ au/wnZ/r?/Y 3 - j: qo'\ Ideas T?Iov git; EVOIZ Pu $004pr (.9 .3 . I . ..Q SIGNED 11?; SIGNED IMPORTANT MESSAGE IMPORTANT MESSAGE ?a FOR j? FOR (Q: DATE 9 0/0 2' TIME 51.; $5 AM . DATE .: I I :3 I OF OF 13006335 if i ?69 - PHONEI I MOBILE MOBILE :31 TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL :3 i CAME TO SEE YOU WILL CALL AGAIN I CAME TO SEE YOU WILL CALL AGAIN :5 a I WANTS TO SEE YOU RUSH WANTS To SEE You RUSH 3; I RETURNED YOUR CALL SPECIAL ATTENTION 3 RETURNED YOUR CALL SPECIAL "If 3'3 I MESSAGE MESSAGE i 5h 6 007/ ?55a 4/5 ?2 31 AWL X4 CAQDS - 5w +9212 MIA W700 mimLm 1"ngl I 3 3 or! IZCBO 1+ 4? (LL94 :j . . AMML La? M- - 0 it! ET: SA001092 5 SIGNED T- SIGNED . .. 1-.Case 18-2868, Document 283, 08/09/2019, 2628241, Page505 of 883 IMPORTANT MESSAGE Fm 1765? DATE 3) II I 05/ OF MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAQE q??zd 463K [70/ (V I, I SIGNED 13;- IMPORTANT MESSAGE FOFI - \l (037?? DATE 37/! /05 TIME [030/ .. XQA4 %4 J1 OF MOBILE TELEPHONED I, CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE I SIGNED ha 1% ,3 IMPORTANT MESSAGE FOR A AM. DATE TIME PM. OF MOBILE TELEPHONED I PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH YOUR CALI. SPECIAL ATTENTION vaoxsuHK OM (use $0 6 smut SIGNED MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE a; ?Van/um! J53 5A001093 SIGNEDALI - 'c?x?e?r?I??.313: I-I I3 ?sc_ om, Case 18-2868, Document 283, 08/09/2019, 2628241, Page506 of 883 IMPORTANT MESSAGE IMPORTANT MESSAGE . FOR DATE ij?j '10) TIME MOBILE PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE )Mr? A 0,1476 SIGNED . 1114 IMPORTANT MESSAGE l7 ,1 d; .. I A?th?: DATE 6/ ?72 nmigw - 6? 0 or or: 4.55 A. MOBILE 3y TELEPHONED PLEASE CALL CAME TO SEE you WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL MESSAGE - . .t 626 SIGNED 1? 1 ?9 EICQEY 7619? a/ IMPORTANT MESSAGE 72/2? TELEPHONED DATE 92/2/3260 04/ OF - .- v' MOBII . PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION r" MESSAPE ?006/ SIGNED FOR In I DATE TIME 7" 0:72," 7,3 (I. Jr OF MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAG Aa? [f/J :4:ch SIGNED SA001446 [4 l7 Case 18-2868, Document 283, 08/09/2019, 2628241, Page507 IMPORTANT MESSAGE IMPORTANT Lt], DATE DATE 43?1/ 5? 240$ ,7 OF 0? MOBI MOBILE 7v TELEPHONED PLEASE CALL TELEPHONED I PLEASE CALL CAME TO SEE you WILL CALL AGAIN CAME TO SEE YOU WILL ALL AGAIN WANTS To SEE YOU RUSH WANTS To SEE YOU RETURNED YOUR CALL SPECIAL ATTENTION RETURNED voun CALL SPECIAL ATTENTION MESSAGE . I MESSAGE 4-3157 10/7 - SIGNED 11?: SIGNED 11% IMPORTANT NIESSACIIE IMPORTANT MESSAGE FOR . DATE 41/4! TIME 42% 6?5 SW DATE TIME OF MOBILE MOBILE TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL 4 CAME To SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH RETUHNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE I 0 - /i4~'9 MESSAGE 1 To i 1/ 9/ gig-Lag All/ff?. I SA001450 SIGNED T7 SIGNED If? I421 HI i3) (3) ta) w. u} (U. I6) (A) 501m 'ocI Case 18-2868, Document 283, 08/09/2019, 2628241, Page508 of 883 TELEPIIONED CAME TO SEE YOU IMPORTANT MESSAGE FOR 9?qu its; DATE '20 ?if/V" I I m- TIME 1.31.} PLEASE CALL WILL CAIL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION I is Cf? 9v?. SIGNED 118-1 WMESSAGE - A. I, ?Fog?x TIME ?3 I - I . LEASE CAL CAME TO SEE You TO SEE YOU RETURNED VOUR CALL SPECIAL ATTENTION MESSAGE TE L) :11; . 3 IMPORTANT MESSAGE mLi?L PLEASE CALL CAME TO SEE YOU HWILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED voun CAI SPECIAL ATTENTTON MESSAGE 3-4 SIGNED 1184 IMP FOR ?Mm DATE ?@252 TIM PM J. TELEPHONED LEASE CAME TO SEE You ?Hi??a LL CALL AG I WANTS TO SEE Y3, A RUSH RETURNED YOUR cm I SPECIAL ATTENTION MESSAGE - - SA001452 I a; I184 I423 - -..- .. .QI If? f0 {p .31 QI 9?0 (.CU. (I) SCUBA 10/01 Case 18-2868, Document 283, 08/09/2019, 2628241, Page509 of 883 IMPORTANT MESSAGE - DATE TELEPHONED PLEASE CALI. CAME TO SEE YOU WILL CALL AGAIN -WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE - - 7 I. I I I 1/ _li_ IMPORTANT MESSAGE ?DATE I . . M1 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE - II UK I \Y?r V. ?3 I SKISIGNED 1134 IMPORTANT MESSAGE FOR AM. I I 7 VAT (LIL) DATE i4. M- .. a I: PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNED EX-.- ..- If; IMPORTANT MESSAGE PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU . RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE 1184 100 H20 $0 15 It ?l?SCUBA Case 18-2868, Document 283, 08/09/2019, 2628241, Page510 of 883 IMPORTANT MESSAGE 588?s? PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION (.4 SIGNED . I134 IMPORTANT MESSAGE MOELE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNED 118? IMPORTANT MESSAGE TELEPHONED PLEASE CALL TIME .4742: EM. CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE eunuch HM IMPORTANT MESSAGE I7 FOFI DATE OF A.M. RM. MOBILE TELEPHONED Ix PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNED I SA001477 Case 18-2868, Document 283, 08/09/2019, 2628241, PageSll of 883 LIMPORTANT FOR 7r? - AM. DATELWTIMEW Mm IMPORTANT MESSAGE FOR TELEPHONED PLEASE CALL TELEPHONED f, PLEASE CALL - CAME TO SEE YOU WILL CALL AGAIN I CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH JFRETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION I?g MESSAGE (gait I MESSAGE . . If9 0m ?5?th bfSIGNED SIGNED 51"? 7 I184 1184 Lag IMPORTANT MESSAGE IMPORTANT MESSAGE . .1 . ?3 FOR '1 FOB A.M. . AM. DATE PM. - DATE 0 PL Lr TIMEZ RM. . Min-L OF - PH NE 0 AREACODE NUMBER EXTENSION if? TELEPHONED PLEASECALL . TELEPHONED PLEASE CALL 171;? CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN .WANTS TO SEE YOU RUSH . TO SEE YOU RUSH 5?5 RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION 1' MESSAGE . SHE 3.28019 (3 (/30 .s'iz i I 2 SA001456 SIGNED ?x i . i (ill 142' I 08 Case 18-2868, Document 283, 08/09/2019, 2628241, Page512 of 883 o( IMPORTANT MESSAGE TIME TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION .. MESSAGE UT IMPORTANT MESSAGE ?DATE I 0*.1 TIME I I 'i'yf .- Vi: Ell-I. TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUP. CALL SPECIAL ATTENTION MESSAGE SIGNED 1184 SIGNED ?as: IMPORTANT MESSAG FOR .. "v A4MI. DATE TIME NI z" I TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS To SEE You RUSH RETURNED YOUR CALI. SPECIAL ATTENTION .1. . I 'l :6 MESSAGE a . I -- . .157 f? Thad ?5 r? {l?f?at; IMPORTANT MESSAGE FOR LAN I. I (?Kg I TIMEI - "3 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION SIGNED SAOOI457 1184 I428 . . - 000600000 . I. ?3 Us Kb (3 \9 \?iv ?3 2, 1 ?1 831841001 .4 Case 18-2868, Document 283, 08/09/2019, 2628241, Page513 Of 883 IMPORTANT MESSAGE IMPORTANT MESSAGE A.M. DATE 8 . TIME PM. DATE TIME PMiizI?xL/TELEPHONED PLEASE CALL TELEPHONED CALL CAME TO SEE YOU WILL CALL AGAIN CAME To SEE YOU WILL CALL AGAIN WANTS To SEE YOU RUSH WANTS To SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION r" MESSAGE MESSAGE .x SIGNED SIGNED .31: IMPORTANT MESSAGE IMPORTANT MESSAGE fr) - 44* '41? - 1 Mc' 9? FOR 81/? FOR s" E: mi I AM. ?if. . . AM. DATE - DATE 1" TIMEM PM. I . OF MOBILE TELEPHONED PLEASE CALL 1/ TELEPHONED .. PLEASE CALL CAME To SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAI ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION 51;" :5 z: 7% MESSAGE .. - {?514 {Ex/3 5? a I 71?01?s; L- -- J: I. H- SAOOI461 ca: ('Ill Jl'l?Rl DUI-432 @00000000000?000000000m0 .r 5939 r- ww?wb Case 18-2868, Document 283, 08/09/2019, 2628241, Page514 of 883 IMPORTANT MESSAGE . I FO 9" MOBILE . TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS To SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNFD 1184 IMPORTANT MESSAGE IMPORTANT MESSAGE TELEPHONED PLEASE CALL CAME TO SEE You WILL CALL AGAIN WANTS TO SEE You RUSH RETURNED YOUR CALL SPECIAL ATTENTION SInNcn 119A FOR PI . 'q=i4l11 ki' DATEL 4 TIME 0 PM. OF I MOBILE TELEPHONED 1 PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE - 1/ 3L - 3-): 734.791 IIEE . SIGNED MA .32? IMPORTANT MESSAGE FOR - . DATE 5? M- TELEPHONED PLEASE CALL CAME TO SEE you WILL CALLAGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION I r: MESSAGE at(if 37H: jagbz" 5A001462 SIGNED 1184 (Ill H33 Case 18-2868, Document 283, 08/09/2019, 2628241, Page515 of 883 1 ?6 8C1184 A) IT \3 IMPORTANT MESSAGE I I FOR 1 . "?74 A.M. DATE A L- .31- TIME PM: MOBILE TELEPHONED EASE CALL CAME TO SEE You- WILL CAIAGAN- WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION i} Ki? MESSAGE -. . - . . 1 I . win-L. I. :24 a; SIGNED 1134 IMPORTANT MESSAGE TIME 95M. -I- CAME To SEE YOU CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE 1 "4 7? -- 4?IMPORTANT MESSAGE TELEPHONED 7 Fi?? CAME To WILL CAEGAIN 1 WANTS To SEE you RUSH RETURNED YOUR CALI. SPECIAL ATTENTION I SIGNED OF PHONFJ MOBILE IMPORTANT MESSAGE FOR JSSL. {21- DATE 1 3 I TIME I OF LL MOBILE TELEPHONED PLEASE CALL CAME To SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED voun CALL SPECIAI ATTENTION MESSAGESIGNED H35 Case 18-2868, Document 283, 08/09/2019, I I I IMPORTANT MESSAGE FOR a. DATE c- . z: ?cf./u 2 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNED - 1% SCUM 10/01 '43 K) a IMPORTANT MESSAGE Am} OF MOBILE TELEPHONEO .X PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION 114/ 10 1.5.0737 KIWI SIGNED T. 2628241, Page516 Of 883 IMPORTANT MESSAGE FOR - t; r: :j - A.M. DATE '45! 5,4) 57'. OF MOBILE TELEPHONED PLEASE CALL CAME To SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION 7 {2/7/71 MESSAGE "ff-4 SIGNED ,5 1134 IMPORTANT MESSAGE . . *7 . DATE #35512 OF MOBLE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS To SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SA001476 9: I SIGNED 1184- [448 i} (1.5 0 Q) SCUBA Case 18-2868, Document 283, 08/09/2019, 2628241, Page517 of 883 IMPORTANT MESSAGE 2? :r AM- TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION SIGNED I134 IMPORTANT MESSAGE FOR .- L- .., - SSA-M, MOBLE TELEPHONED PLEASE CALL CAME TO SEE vou WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE 3s SIGNED 118? IMPORTANT MESSAGE FOR DATE TELEPHONED PLEASE CALL .. gm. CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE . _Lll CIOAICO .TI. IMPORTANT MESSAG FOR . 42' . .. A.M. DATE PM. .2 ,4 4' OF MOSHE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNED 3 SA001477 Case 18-2868, Document 283, 08/09/2019, 2628241, Page518 Of 883 IMPORTANT MESSAGE IMPORTANT MESSAGE . FOR ?ir- mem? DATE SJ/ay TIME 9 3:23.43 Mp. Mark (7st OF 0F - MOBILE . TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU WANTS To SEE YOU RUSH CALL RETURNEDYOUR CALL SPECIAL ATTENTION MESSAGEWW MESSAGE ?mqf 7A I . MK SIGNED If: SIGNED 134 [he IMPORTANT MESSAGE IMPORTANT MESSAG FOR (7:4;in FORQCE DATE 9/ TIME 2 4? RM. DATE TIME [9 Lac/L ?5 Dr l9 [5 leg MOBILE TELEPIIONED CALL PLEASE CALL CAME TO SEE YOU WILL CALLAGAIN CAME SEE WILL CALL AGAIN WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH - RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE cu, 51? crUc,/c,/3/e /7 7.45:5 Mum/,7? 13 30 inf/I . 1/1/15: 767?Myr/1 ?pal/IL 70 Wm) - I SAOZ828 . 99 43'; SIGNED . .DT d) 0 555558 II In?? II) Case 18-2868, Document 283, 08/09/2019, 2628241, Page519 of 883 IMPORTANT MESSAGE FOR 6 LI a DATE OF MOBILE- TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION Ilia; (L q; 1:121- SIGNED IMPORTANT MESSAGE FOR 11'7"} f' . DATE 5 TIME PM. OF TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO RUSH RETURNED voun CALL SPECIAL ATTENTION SIGNED 1184 IMPORTANT MESSAGE FOR KM. DATE PM. - PHONEJ MOBILE PLEASE CALL WILL CALL AGAIN RUSH SPECIAL ATTENTION TELEPHONED CAME TO SEE YOU WANTS TO SEE YOU RETURNED YOUR CALL MESSAGE IMPORTANT MESSAGE . XV FOR [?9147 c: w) DATE . 995/7?? OF. - MOB TELEPHONED SIGNED I184 PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SAOZSZ 9 a: SIGNED 1184 7?0? 15:? Case 18-2868, Document 283, 08/09/2019, 2628241, Page520 IMPORTANT MESSAGE IMPORTANT MESSAGE 5 FOR E2 Eon M5. MAXWELL ,9 DATE TIME - DATE ML nuei???43 7?9 TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL *3 CAME To SEE you WILL CALL AGAIN CAME TO SEE you WILL CALL AGAIN f4; WANTS To SEE you RUSH WANTS To SEE you RUSH i, .9 RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE MESSAGE RE Iowa CM I. L: - - - SIGNED . 13:; SIGNED 135 L: I. IMPORTANT MESSAGE IMPORTANT MESSAGE '9 - I -9 FOR FOR jigDATE 33. . DATE TIME .. PMTELEPHONED PLEASE CALL TELEPHONEO PLEASE CALL [3?93" CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION I . RETURNED YOUR CALL SPECIAL ATTENTION i . MESSAGE MESSAGE WEUL .L To 9 .3 \rL\m EARLA To La 8 i WELL mm mm ham. mm l4. L9 1.: (Jugmx?ch SA02830 1m - ., I454 Case 18-2868, Document 283, 08/09/2019, 2628241, Page521 of 883 .3 AWE IMPORTANT MESSAGE It I - I 2.1.1: 312? 1 IMPORTANT MESSAGE 0F PHONEI MOBILE TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL CAME To SEE YOU WILL CALL AGAIN CAME To SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH I WANTS To SEE YOU RUSH Era RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION 5T6 MESSAGE 7J4 {j JZ 1: MESSAGE are A 9 A An ,3 )x ?19 /5l: Low/Nous I 2 A .1 SIGNED 13; SIGNED 1f: IMPORTANT MESSAGE IMEORTANT MESSAGE - FOH A DATE TIME 5" . DATE jig/712.. MOBILE MOBILE - . TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL CAME To SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH WANTS TO SEE you RUSH voun CALL SPECIAL ATTENTION RETURNED voun CALL SPECIAL ATTENTION . . MESSAGE jus+ - . ?958 I 9) (42945 - SA02832 SIGNED ,3 - . SIGNED . 1184 I [450 6666 . .. .. . - .Case 18-2868, Document 283, 08/09/2019, 2628241, Page522 of 883 IMPORTANT MESSAGE Eon . 67$ 7 AM TIME m: DATE or MOBILE TELEPHONED PLEASE CALL CAME To SEE YOU WILL CALL AGAIN WANTS To SEE YOU HUSH RETURNED YOUR CALL 3- SPECIAL ATTENTION JG a A SIGNED yr/ . 4' W'Zzw Vol.) bile P??f?iJ IMPORTANT MESSAGE DATE TIME A 9-0 (QM. 3 . arm MOBILE TELEPHONED PLEASE CALL CAME To SEE YOU WILL CALL AGAIN SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE I, on? (Cl 8 Ex'aa?k: Lag-0,1339.4, SIGNED . 1m IMPORTANT MESSAGE Tm DATE ?mega?0 SAT 3; MOBILE TELEPHONED CALL CAME To SEE you WILL CALLAGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNED was}; IMPORTANT MESSAGE 29 -- 0F MOBILE a FOR DATE TELEPHONED PLEASE CALL CAME To SEE YOU WILL CALL AGAIN WANTS To SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE 8A02838 a SIGNED 1184 1462 i 4 mouaabhau - - .r - 1 \r EEG-T . abuab a? La Case 18-2868, Document 283, 08/09/2019, 2628241, Page523 of 883 IMPORTANT MESSAGE 7.4.. FOR If I (I DATE ?f C1 [my I 0.: 3% 39%! WE MOBII TELEPHONEQ CALL CAME TO WILL CALLAGAIN WANTS TO SEE YOU RUSH RETURNED vbun SPECIAL ATTENTION MESSAEE r, 1 \1 - - -0 IMPORTANT MESSAGE FOR ?g . OF CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU HUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE Sh $27-$53! 51+ 83% 0715061; by} GIL a: VJAAJ IMPORTANT MESSAGE FOR I I2: Warm.) I WANTS TO SEE YOU HRUSH RETURNED YOUR CALL SPECIAL ATTENTION ?53561155; cf TBD SQG, Mm . SIGNED 133? IMPORTANT MESSAGE 6/99 em f-Tfiiw 6F MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENUON 23$ "af'dwcs (rq seam SIGNED SAOZ850 3, Case 18-2868, Document 283, 08/09/2019, 2628241, Page524 of 883 IMPORTANT MESSAGE IMPORTANT MESSAGE FOR FOR Cc/ .DATE TIME 67 Off-m Dii ji li/i?d; {632% 7755MOBILE w. l- - TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL I: CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE you WILL CALL AGNN .3 . WANTS To SEE YOU RUSH WANTS TO SEE YOU RUSH i RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION 6 [703 (A 7LfaLhCr 3 MESSAGE 3?6 LaLled ?20 .53; li or VOL: 1% feac w? 404/ Z1146 790C 37? 720A +0/0, 1.3 Guru/(Lego 470/ r?jjow cow a ?00? MD, I: Wm-" 2-7, 41% ?48 2147SIGNED 21$ :2 . IMPORTANT MESSAGE . . . FOR 765? 4 3&1: DATE 3? Udb_ TIME 71"? {9?31 07: P6 46 . #6 MOBILE i' ?g PLEASE CALL A A - A 2 S. TELEPHONED Zr PLEASE CALL I CAME To SEENDU CALMQIN CAMETO SEE you CALL AGAIN . .1. WANTS jus? WANTS To SEE YOU RUSH If RETURNED W8 SPECIALATTENTION RETURNED YOUR CALL SPECIALATTENTICN 3- I7 i '1 2 MESSAGE MESSAGE ??8qu 0/7 71/16 3 .- I I .. SAO3008 3.. .. (ilUl?l?RliOOl 563 Cam: 18-7868, 782, 08/00/7010, 7678741, PangQR nf 882 EXHIBIT 29 (Filed Under Seal) Cam: 18-7868, 782, 08/00/7010, 7678741, PangQB nf 882 EXHIBIT 30 (Filed Under Seal) United States Afters/age}; Southern District ofFZertda 500 South Australia?s? Ave, Seite 4?00 West Palm Beech, FL 3349} 820871} Facsimile: September 33,, 2008 VIA COURIER Ms. Virginia Roberts (3/0 Asst Legal Attache Matthew Witt United States Embassy Sydney Australia Re: Jeffrev-EnsteinNirginia Roberts: NOTIFICATION OF IDENTIFIED VICTIM Dear (Ms. By Virttie of this letter, the United States Attorney? 3 Of?ee fer the Seuthern District of Fleride prevides you with the fellewing netiee beeause you are as identi?ed victim of a federal effeese. On June 30, 200 8, Jeffrey Epstein; (hereinafter referred to as ?Epstein) entered a plea ofguilty te Vieletions efFloride Statutes Seetinns'796.07 (felnny selieitetien of prostitution) and 796.03 (preeurement ef miners te engage in prostitution) in the 15th Judicial Circuit in and fee Palm Beach County (Case Nee. and 200?8~ef?: and was sentenced te a term of twelve months? imprisenment to be followed by an additional six memes" imprisonment, followed, by twelve months of Communibz Centre] 1, with nonditiens ef con?nement imposed by the Court. In light of the entry of the guilty plea and sentenee, the United States has agreed to defer federal prosecution in fever {if this state plea and sentence subject te certain enndititiesy including the following: i 1. An independent Special Master was assigned the task at selecting an attorney representative te represent the victims, including you, in connection with civil ectiees between the Victims and Mr. Epstein. The a. ?was; "?axrv?wa- Case 18-2868, Document 283, 08/09/2019, 2628241, Page528 of 883 5? w? 'v Ms. ROBERTS a? 0F VICTIM SEPTEMBER 3, 2668 PAGE: 2 on 3 Special Master selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, RA, a highlyarespected and eXperienoed attorney, You are not obligated to use Mr. Josefsberg asyour civil attorney, but, as explained in, greater detailbelow, Mr. Josefsberg?s services will be provided at no east to you because Mr. Epstein is obligated to pay the ooste and fees of the attorneymrepresentatise. Epstein and his attorneys can only contact you asisag?taseeaag, assuming that you would like Mr. losefsberg to serve as your attorliey. 2. If you elect to ?le suit against Mr. Epstein pursuant to Title 18, United States Code, Section 2255, Mr. Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Mr. Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between you and Mr. Epstein, so long as you elect to proceed explosively under 18 U.S.C. 2255, and you waive any. other claim for damages, Whether pursuant to state, federal, or common $7 law. Notwithstanding this waiver, Epstein?s agreement with the United States, his waivers and failnre to contest liability and sooh damages in any suit are not to be construed as an admission of any oriniinal or civil liability. 3. As stated above, Mr. Epstein has agreed to pay the fees of theattorney representative selected by the independent third party, This provision, . however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if after consideration of potential settlements, you and Mr. Josefsberg elect to file a contested lawsuit pursuant to 18 2255 or you elect to parsne any other contested remedy, the obligation to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay seasonable attorneys fees and oosts such as those contained in Section 2255, shall cease. Please contact either myself at or Justice Department Victim-Witness Specialist Twiler Smith at Twiler. Smith@io.tbi.ooy with a good telephone number andfor email address, so that we may provide Mr. Josefsberg with a timely means of communicating withyoo. If you would like to contact Mr. osefsberg My; ., Case 18-2868, Document 283, 08/09/2019, 2628241, Page529 of 883 MS. Wanner: Rename Nortetearren or? IDENTIFIED VICTIM SEPTEMBER 3 2008 PAGE 3 or 3 directly, he can he reached at +1 305 358-2800. If you have already selected other counsel to represent yeathe future, and you decide to ?le a olairn against Jeffrey Epstein, Mr. Epetein?e attorney, Jack Goldberger} eelts that you have your attorney contact NILGoldberger at Atterbont Goldb erger and Weiss, 250 Australian Avenue South? Suite 1400, West Palm Beach? FL 33401, (561) 659~3300. In addition, there has been litigatien between the United States and two other Victims regarding the disclosure of the entire agreement between the United States and Mr. Epstein. Mr. Josefsberg can. provide further guidance on this issue, or if you select another attorney to represent you, that attorney can review the Court?s order in the matter <3er re Jane Does I and 2, United States District Court fer the Southern District of Flerida Court File No. 08?- 80736-CIV-MARRA. Please understand that neither the US. Attorney?s Of?ce nor the Federal Bureau of Investigation can take part in or otherwise in civil litigation. Thank yen for all of your daring the oonrse of the federal and State inveetigations and please accept the heartfelt regards of myself and Spaniel Agents Kuyrkendall, Slater? and Richards for your health and well~heing Sincerely, R, Alexander Aeesta United States Attorney By: A. Marie Villafe?a Aeststant United States Attorney oe: Robert Josefaherg, Esq. leek Geldherger, Esq. Cam: 18-7868, 782, 08/00/7010, 7678741, Pag9'320 nf 882 EXHIBIT 31 (Filed Under Seal) . nu. syn-M24 m: on an: r, .. a ..- vlnu' -1 of 12- Case Page531 ofj Dateofentry 07/05/2013 If. FD-302 (Rev. 5-8-10) VIRGINIA L. maiden name ROBERTS, date of birth? Social Security Account United States Citizen an Australian Permanent Resident, residence New South Wales, Australia, 2261 was interviewed at the United States Consulate in Sydney, Australia. GIUFFRB was advised of the identity of the interviewing agents and purpose of the interview. Present during the interview was Federal Bureau of Investigation Special I [and via telephone, Assistant :3 United States AttorneyI I GIUFFRE provided the following information: GIUFFRE was born in Sacramento, California to parentsI I Idate of birthI I currently resides inI IandI Idate of birth b7c I Icurrently resides inl I GIUFFRE moved to Palm Beach County, Florida with her parents when she was four years old and returned to California at age 11. She returned to Florida at age 13 and was placed in a rehabilitation or foster care facility in West Palm Beach, Florida. GIUFFRE ran away from the rehabilitation facility when she was approximately 14 years old, and while living on the streets in Miami, Florida, she metI I I b6 b7C I Iwas training GIUFFRE to be an escortI I Igave GIUFFRE a life off of the streets which made her feel 03/17/2011 a? Sydney, Australia (In Person) File? 31E-MM-108062 Dalcdra?ed 07/05/2013 :3 This document contains neither recommendations nor conclusuons of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not to be distributed outside your agency. Case 18-2868, Document 283, 08/09/2019, 2628241, Page532 of 883 (Rev, 05-08-10) ContinuationofFD?3020f Virginia 1" GiUffre 03/17f2911 ,?age 2 Of 12 like she was locked into the GIUFFRE pharmaceutical drugs toward the end of their relationship. b6 - b7C relationship while she was at a private ranch near Ocala, Florida. GIUFFRE telephonically contacted a childhood friend,I Ifrom a telephone at the ranch. GIUFFRE b6 knewI Ifrom elementary school and called him at the home telephone b7c of his parentsI IGIUFFRE toldI Ishe was very lonely, and asked her why she did not leave telephone conversation with Ithe recreational vehicle (RV) GIUFFRE was staying in at the ranchI Idid not strike herI Ipack her belongings and told her she was going to live with another man. I I be felt that she was sent toI but did not know the b7C ecifics of the arrangement. GIUFFRE engaged in sexual activity with Iwho was described as a white maleI I GIUFFRE stated GIUFFRE stayed withI ILRU for approximately one or two weeks before the police located her and returned her to her parents. GIUFFRE was interviewed by a male detective. parents were still married at the time and lived near Florida. believed there was an FBI investigation related to She never after In approximately June 1998 or 1999, GIUFFRE began working at Donald Trump?s Mar?A-Lago Club in Palm Beach, Florida. father was able to help her gain employment as a baby sitter and later as a locker room attendant at the club. GIUFFRE started studying for her GED and wanted to become a massage therapist. In August, GIUFFRE was reading an anatomyfmassage book and was approached byI I b6 b7C Iand help her get her masseuse accreditationI GIUFFRE consulted her father about the opportunity and at approximately 5:00 p.m. the same day, her father drove her to a residence at Case 18-2868, Document 283, 08/09/2019, 2628241, Page533 of 883 (Rev. 05-08-10) ContinuationofFD?3020f Virginia L. Giuffre ,On 03/1?/231? 3 Of 3.2 ,hg with father and told him it was a wonderful opportunity for GIUFFRE. GIUFFRE metl I b6 Ialso known asl IGIEFFRE was led b7c upstairs] Once upstairs in! I b6 . . I b7C [instructed GIUFFRE to wash her hands prior to beginning the massage. The massage bega emonstrated massage techniques to GISFFRE. During the course of the massage, questioned b6 GIUFFRE about her past, including her time as a runaway. GIUFFRE was also b7C asked if she took birth control. b6 b7C GIUFFRE was given instruction and began kissing b6 b7C At the GIUFFRE to obtain two warm wash clothes. Qne wash cloth was used to cleanl I b6 second wasl Ito help him relax. GEUFFRE b7c described! I and GIUFFRE then moved to the steam room and shower where massaged with soap and a loofah in the shower. At the conclusion of the shower, GIUFFRE went downstairs and b6 b7C Arrangements were made for GIUFFRE to return to the house the following day after work. cellular phone number was given Case 18-2868, Document 283, 08/09/2019, 2628241, Page534 of 883 (Rev. 05-0840) ContinuationofFD-302of Virgi?ia L- Giuffre 03/i?x?2611 ?Page 4 of 12 The same routine and pattern of massages and sexual activity between land GIUFFRE continued for between one and two weeks. At b6 timesJ I b7C offered GIUFFRE the option to qui! her job at Mar?A?Lago and travelI IThere was also discussion of GIUFFRE receiving massage training. GIUFFRE was to be paid $200.08 per day for travel and $200.00 per hour for massages. Early in her relationship withl IGIUFFRE metI b6 b7C . land was introduced asI Iassistant. GIUFFRE soon he an travelingl IFor the initial six eonths, GIUFFRE the United States and Caribbean, b6 including California, New York City, New Mexico, and various business b7C trips. During those trisz I Six to nine months after GIUFFRE began working forI I loisEFRB was introduced t4 I in be IFlorida.I I b7C at the time. GIUFFRE met the couple at a condominium next to the IThe condominium was boughtI Iand was a the condominium, GIUFFRE provided a normal massage toI LNG. Shortly I IGIUFFRE provided an erotic massage to and GIUFFRE cleanedI IShe was paid cashI [In addition, paid was 16 years old at the timeI I GIUFFRE advisedI introduced her to the drag Xanax. She explained that Xanax helped her escape from reality but aliowed her to be still function normally. Xanax helped her go forward with what she was b7c doing wit and others. Her habit went from two pilis per day up to eight pills per day. second client was an academic of some sort described as an older American male sent GIUFFRE from Miami Internatioral Airport toI I b6 by commercial airline. GIUFFRE was picked up at the b7C airport byI Iand then taken to the island by boat. GIUFFRE Case 18-2868, Document 283, 08/09/2019, 2628241, Page535 of 883 (Rev, 05-08-10} ContinuationofFD?3020f Virginia 1" Giuffre ,On 5 Of 12 Page pointed out thad I I Iinstructed GIUFFRE to entertain the clientl Iand wanted to ride jet skis and participate in other island activitiesl I I I GIUFFRE spent two days on the island with the client. assumes the client also traveled commercially. b6 b7C During the foilowing several months, GIUFFRE traveled internationally Prior to her traveling GIUFFRE in getting her pass ort. GIUFFRE got passport photographs of herself and b6 provided them t4 the remaining paperwork was taken care of by b7C IGIUFFRE traveled to Paris, France, the South of.France, London, England, Africa, and Spain. While in Paris, GIUFFRE recalled staying at a hotel overlooking the Champs?Elysees. While traverin GIUFFRE traveled on a black plane. During the international travelJ times, would] I IRarely a day would passl I I Icontacted GEUFFRB through b6 land wanted to talk to GIUFFRE aboud I b7C Iand offered GEUFFRE a contract. GIUFFRE agreed to the contract for her story and was paid $340,000 for the story, $10,000 when the articie was printed, and another $10,000 to be wired into GIUFFRE's account in May 2011. The contract prevented GZUFFRE from talking to an other press for a specified period. GISFFRE advised that she providedl kith detaiied informatiod I b6 b7C I b6 I b7C Case 18-2868, Document 283, 08/09/2019, 2628241, Page536 of 883 (Rev. 05-08-10} ContinuationofFD-S?zof Virginia 1" Giuffre 03f1?f2011 3933 FIUFFRE believed she and] [were b7c approximately the same age. GIUFFRE and b6 b7C GIUFFRE weuld dress b6 b7C GIUFFRE, GIUFFRE provided an be b7C GIUFFRE describe An unknown individual saw when she arrived at b6 I b7C IUFFRE had] . I GIUFFRE said that day was a low stage in her relationship! because she could not believe GIUFFRE never D-302a (Rev. 05-08-10} ContinuationofFD?3020f Virginia 1" Giuffre ,i?age 7 Of 3.2 saw GIUFFRE believed the girls may have been[ b6 [but b7c GIUFFRE was not certain ofl Iinvolvement. GIUFFRE had a picture of herself she wanted to give[ b6 b7C GIUFFRE described some of the unique interior areas of b6 b7C [which GIUFFRE referred to[ I [which was where GIUFFRE stayed. While in New York, GIUFFRE also stayed at an apartment on ?6th street I was aware ofl [additional b6 apartments in the same building. According E31 [the b7C apartment building on 66th street was owned by[ advised that she had a photo raph of the interior of the 66th Street apartment ameng other photos GIUFFRE advised that some of her photographs that were provided to her civil attorneys by her family were not returned. One of the missing photos depicted GIUFFRE wearing a pink dress while seated on a quad bike. th wa4 kemale that formerly lived in[ b6 I b7C Case 18-2868, Document 283, 08/09/2019, 2628241, Page538 of 883 (Rev. 05.0340) 31E-MM-108062 ContinuationofFD-3020f Virginia Giuffre 03/1?f2011 ,Page 8 Of 12 LNU and went shopping together and purchased clothing and sex toys. GIGFFRE explained thatl b6 b7C b6 b7C GIUFFRE used a cellular telephonel [She believed it was a New York City number but could not recall the number. and GIUFFRE could only remember facesl Inot their names. GIUFFRE did not] I but she eid try unsuccessfully to get! I GIUFFRE recalledl I ibut she could b6 not recall the wording. i b7C GIUFFRE advised} I GIUFFRE a selfwhelp conference at a hotel in New Orleans, Louisiana. The hotel was near the Hard Rock Cafe in New Orleans. GEUFFRE traveled the world including the USVE, New York, Santa Fe. Palm Beach, France, Africa, Spain and the Snited Kingdom. I I IGIUFFRE recalled visiting b6 b7C Alhambra Castle in Spain. I I IGIUFFRE eventually traveled to the United Kingdom and Case 18-2868, Document 283, 08/09/2019, 2628241, Page539 of 883 (Rev. 05-08-10) 31E-MM-208062 ContinuationofFD-3020f Vitginia 1" Giuffre 03/37/2911 9 Of 12 Page while GIUFFRE in a very excited manner and told her they had to go shopping to pick out a dress because GIUFFRE would be be dancing withI I b7C shopping and purchased makeup, clothinc, and a Burberr has. The items were purchased withI GEUFFRE b6 an? lreturnedI b7C instructed GEUFFRE to get ready. When GIUFFRE came down after getting ready, she was introduced to IGIUFFRE traveled to CLUB TRAMPI I GIUFFRE dancedI Iat CLUB TRAMPI I btayed at CLUB TRAMP for an hour or hour and a half and drank a couple of cocktails before returning toI GIUFFRE had not received any direction fromI I I I After returning toI requestedI Ito take a photograph of herI IGIUFFRE advised that she still had the original photograph in her possession and would provide it to the interviewing agents. GIUFFRE proceeded withI Approximateiy two months later, GIUFFRE med Iat b6 b7C GIUFFRE recalledI IGEUFFRE recalled Ijoking about trading GIUFFRE in because she was getting too 01d. Case 18-2868, Document 283, 08/09/2019, 2628241, Page540 of 883 (Rev. 05-08-10) Con?nua?on L. Giuffre 03/17;2011 ?Pge 1g of 12 GIUFFRE recalled meeting . . . b6 GIUFFRE was USlng Xanax heaVily at the time, b7c and her recollection was not clear. She remembered there were many models on the island that did not speak English along with a modeling person who had an unknown accent. b6 b7C hid not have a problem with GIUFFRE using prescription drugs. lwas described by GIUFFRE as a b6 b7C I I (TRUE NAME Dagmar): I a ranch employee GIUFFRE b6 could not recall his name. She did have a photograph of ranch b7c employee. GIUFFRE met numerous famous peoplel hncluding academics, politicians, and celebrities. She me? iand' I b6 Iand I b7c crosses received many gifts : including jewelry; watches, bags, shoes, make up, clothino. and home furnishings. [i be I I b7C GIUFFRE left all of the items behind when she traveled to Thailand to receive massage training. In August 2082, GIUFFRE traveled by commercial airline to Bangkok, Thailand and began her massage training at International lraining Massage School(ITM) where she received her massace certification. She stayed at the Princess Hotel in Thailand I but never did. GIUFFRE met her future husbandJ during her visit to Thailand. GIUFFRE contactedl kelephonically and told him she had fallen in love with someone. I (Rev. 05-0840) Continuation of FD- ymofVirginia L. Giuffre ,On O3fl?/20ll Page 11 of 12 had not heard froml telephone cal} from person that indicated he was an FBI agent. individuai anything either. During that call] . She did not tel GIUFFRE received a [stated he was an FBI agent. He was trying to determine what she knew about anything about her knowiedge of She also received another telephone call from a She did not tell that She also received a call from an attorney that was trying to determine if she had spoken with anyone or was wiiling to speak to anyone {She explained that she was receiving telephone calls from people whom she did not know and that she was uncomfortable telling them anything over the telephone. One or two weeks later, an unknown attorney andl Icontacted GIUFFRE teiephonicallyj GIUFFRE was using a cellular telephone belonging to her husband. She nor her husband could recall the telephone number but advised that the carrier was OPTUS telephone company. GIUFFRE reviewed a series of photographs of individuais and identified the following: Page 1, number Page 1, number Page 2, number Page 2, number Page 3. number Page 4, number Page 4. number Page 4, number Page 5, number GIUFFRE advised that the following were familiar to her, recall their names or her association to them: LNU, a.k.a. LNU but she could not b6 b7C b6 b7C b6 b7C Case 18-2868, Document 283, 08/09/2019, 2628241, Page542 of 883 (Rev. 05-08-10} 31E-MM-108062 ContinuationofFD-3020f Virginia 1" Giuffre ,On ,i?age 12 of 12 Page 1, number 4 Page 2, numbers and 8 Page 3, number 8 Page 4, number 1 Page 5, numbers 5 and 8 The images reviewed by GIUFFRE were placed in a 1A enveiope of the case file. When questioned about United States Customs and Border Patrol records of her entries into the United States, GIUFFRE advised that her January 2091 recerd was the return from her London, Engiand trip I [The April 2091 CBP b6 record was her return to the United Statesl I b7c I GIUFFRE could not recall her travel ?rom March and May 2001 CPB records. GIUFFRE advised that her United States Passport was turned over to the United States Consulate in Sydney, Australia. On March is, 2911, writer, SAI land b6 traveled to residence where she provided 20 photographs and her b7c ITM massage schoei certification. Receipts for Property were executed for the items and a copy was provided to GIUFFRE. It is noted that the receipts were dated based on the United States Eastern Standard Time Zone date. The photographs, certification and original were placed in a 1A enveiopes of case file. Cam: 18-7868, 782, 08/00/7010, 7678741, PangAR nf 882 EXHIBIT 32 (Filed Under Seal) . 1 . . .. ?xx 19m. 908? .K. . ., Vixkv?. r: was. w. f( a, .N. .mHonQwo .mwm EmEsooD $9?ng . .. ?(4%an a ma iixYnn8mm Ema. 33%; K3 3 i? 3 Cam: 18-7868, 782, 08/00/7010, 7678741, Pagp?d? nf 882 EXHIBIT 33 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page547 of 883 c.1? . -- armer, a fe, Weissing, Edwards, Fistos Er Lehrman, . . in: know. u-u" mun-u Mm (arm-uni thm?zu _December 30, 2014 New York Presbyterian Hospital Weill Comwell Medical Center Medical Records 525 East 68 Street New York, NY 10065 RE: Request for IVEDICAL RECORDS and BILLING Our ClienUY our Patient Date of Birth Dates Requested wary *mber 31, 2000 Our File umber To Whom It May Concern: This' 15 a follow up to our original December 1 2014 request for medical records (a copy of me is attached for your convenience). Attached, please ?nd a copy of the Refused/Returned Notice for your conVenionoe. Pmsnantro same, please be advisedthalw would MALL records from August 9,1983m? present. Iffhul IS too general/broad, please limit the search to January 1 1998 to December 31, 2000. Home contact us if the reproduction costs exceed $50.00. Please contact us if you have any questions or wish to discuss this matter further. We look forward to your prompt compliance with this request. Very truly yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS LEI-IRMAN, P. L. gong Amy W. Dish owitg meega] For Bradley J. Edward; Esq. BIE: awd Enclosures ??m?vg 0 6 2015 BY: .. .. 425 North Andrews Avenue, Suite 2, Fort Lauderdale, Florida 33301 954.524.2820 of?ce 954.524.2822 fax murmuooazsx CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page548 of 883 armer, fe, Weissing, Edwards, Fistos Lehrman, P.L. Ella mu Hm): Inn-y mmvul D-ur Mfume-.104 u? - December 30, 2014 New York Presbyterian Hospital Weill Comwell Medical Center Medical Records 525 But 68 Street New York, NY 10065 RE: Reqnat for MEDICAL RECORDS and BILLING Our Clem/Your Patient Date of Birth Dates Rewested I uary 5- er 31, 2000 qu?eNumber ToWhomItMuyCmm This is a follow up to our original December I, 2014 request for medical records (a copy of me is washed for your convenience). Attached, please ?nd a copy ofthe Re?ned/Emmet! Notice for yom convenience. Pursuant to same. please be advised that We would like ALL records from August 9, 1983 present. lf?lat is too gmUbroad, please limit the search to Imuarylil998 to December 31. 2000. Pleue us if the reproductioe costs exceed $50.00. Please contact us if you have any questions or wish to discuss this matter further. We ?01: forward to your prompt with this request. Vew My yours. FARMER, JAFFE. watssma, EDWARDS, a; LEHRMAN, P.L. Am; W. Dishowitz, Paralegal For Bradley J. Edwards. Esq. awd Enclosures . MN 0 6 2015 - 425 North Andrews Avenue, Suite 2, Fort Lauderdale, FLorida 33301 office 954.524.2822 fax w: =nm. - Glun?xbooazsv CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, PageS49 of 883 ?mm~memo HOSPITAL =23? 11?" New York Mgiical Center "71?6 a L. "mama?? mule? sum . DEPARTMENT I w?um ?dim wee-pun ?wanna? Maia?: A Im?r'm?waiun'i: :1 Ion Bowman :1 a Dressing Resplratory mm "w madam C1 mum Cl caucus: Sub: Uri-rm Mad Comm: mm? Sade NA my Wm . Yes NON [Juana suing cm Pug-1 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page550 of 883 Hosrmx. - . . New York Weill Cornell Medical Cum 1.7, MW ?ww?g I L. . MREENCY DEPARTMENT RECORD a. DISCHARGE INSTRUCTIONS tl?lv?c/darh .172 036 0105-2016 21 :16:5? - 2 - -31; .1: - GIUFFREOOBZSI CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, PageSSl of 883 Hosmu, New York Comet] Medical Canter . anthem runes, Con?nua?on eumencv 4v 2?1, (?54 4k Mm. 4 mm m7? 1'45 5142:- 4.:vr.7m I n7 ?6 . My aclyw ?nk-l {'09pr WM ha? 5 hm Mai?? waif? . P8993 _qa~9qzo1521ns:54 W. (93 GIUFFRROO3262 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, PageSS2 of 883 WY HOSPITAL New York Weill Cornell Medical Center mammalian . men-lacy NOTES, continuation EMERGENCY panama?? ENS (4.. LWMT (By Pvt/Okra Page 4 0106-2015 21:16:54 .. u? - GlUl-?l-?Rli003263 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page553 of 883 Hosprm. New York Weill Comclt Medical Center 0 ?mm EMERGENCY NURSING FLOW SHEET EMERGENCY DEPARTMENT 6/ 0m HTTJALS I a. 3.9.5 owe-2015213354 . - I OIUFFREOO3264 Case 18-2868, Document 283, 08/09/2019, 2628241, PageSS4 of 883 ?wmwme~cwsmecom Hos mm New York Wc?l Cornell Medical Center km ?17? Emit. mam . EMERGENCY moms. 1 BAERGENCVDEPAHTMBIT 42 9+1} 15gb b? (Jo/?Lam PM >131) 7 \2 ?Wt 53m? Irvfasaak-msxz 3 OHIO-2015 21 16:54 . 919.5 GIIJFFRE003265 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, of 883 HOSPITAL New York Weill Cornell Medical WM . b?b'?ness NOTES o1-ao-zmsz1:17m GIUFFREOO3266 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page556 of 883 525 East 63th Street, New M. Desmond Burks, M-D., Laboratory Director CLIENT EMOND, SIEPHEN MD East 58th Street New Yoxl: 100210000 Client?z 00000 NEW YORK HOSPITAL Coll Date: 07/09/3001 Reyvd Date: 07f09/2081 Date: 07/10/2001 Coll Time: 1911 ?ecvd Time: 1911 Time: 0438 ?316,119. NORMAL REFERENCE J?fyzg COMPLETE BLOOD COUNI use a 2 3 4? K/ul. 4 23 1,3; -3 2 1: gig}. _d 2 81 0?100 0 f2 MCH 31.2 27 0-34 0 pg 34.6 g/dL 13m?. i 915.1293; _j2_7_g 150. 0?450 . 0 10 4 8.6?1? 3 AUTOMATED DIFFERENTIAL 3.4 lain?75? ?1 mm as 8-_12 y? SAG-11.0 .5: EDS 0.0?5.0 3315C: 0.04.0 9; ABS 6 8 1 2.14.9 ABS 7 ABS 0.6 0.2?0.9 0.0 0.0-0 1 grog-2015 21:17:11 ammooszov CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page557 of 883 HIGFE E-?age: 1? REPORT ?Page?! 0106-2015 21:17:11 GIUFFREOO3268 CONFIDEN TIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page558 of 883 CLIENT INFORMATION: Patient Name: ROBERIS, VIRGINIA L. STEPHEN MD 525 East 68th Street New York y? 0 6113? riiHE??'Iz?xl. Coll Date: 07/09/2001 Recvd Da:e: 07/09/2001 Rp: Date: 07/10/200] Recvd Time: 15311 ?Time: 0438 NOPMAL REFERENCE UNI TS 8301' I NE I ?4gu: 2 f. .. '5 Page a GIUFFRE003269 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page559 of 883 Type: LAB REPORTS CLIENT INFORMATION: Patient Namer ROBERTS, VIRGINIA L. EMOND, STEPHEN MD Mad Re: 9: 525 East 68th Street New York NY )00210000 5313"] Client}: 00000 NEW YORK Coll _Date: 07/09/2001 Recvd Date: 07/09/2001 Date: 07/10/3001 Col] Time: Recvd Tune: 1?31] Ftp: Time: .1938 1 DRAWN pgijg BASIC 07/09/01 Order Entry Error. Page: END OF CHART edbyDiN9m1 Paga4 CONFIDENTIAL 01-06-2015 21:17:11 GIUFFREOOSZTO Case 18-2868, Document 283, 08/09/2019, 2628241, Page560 of 883 ?oc_wueneroms 525 East 682h Street, New York, M. Desmond Burke, M.D., Laboratory Director CLIENT Patient Name: 7 L. EMOND, STEPHEN MD 525 East 68th Street New York NY 10021000C flu-(75: Clien??g 00003 new 1031K '?spImL Qatgi 07/09/2001 Recvd Date: 07/09/2001 Date: 07/10/2001 Coll Time: 1855 Recvd 19.1: Time: 0438 FINAL TEST NAME ?aqum; new; was MACROECOPIC rcp? m: YELLO 3531,19?: LPEEARENCE 5.9.5113 PROTEIN _3o* NEGATIVE BLOOD NEGATIVE NEGATIW GLUCOSE NEGATIVE macs: Lg .0 BILIRUBIN ygr?g NEGATIVE BREE 2.025 Loos-1.03.9 51mm; NEGATIVE NEGATIVE Laggogym 35129. NEGAIIVE MICROSCQPIC URINALYSIS 11?33; _5_E;a norm: 0-3 9-2 gig/HP? RENAL EPIIH EEGAIIVE NEGATIVE NOTE {09/05/2000 Egrent) BEEN EXAMINED FOR NBC, RBC, CESTS, AND CELLS. ELEMENTS NOT REPORTED WAS NOT FOUND. Page 5 ems-2015 21:17:11 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page561 of 883 ocType: LAB REPORTS 4 _f ?fang-3mm Pa ge _1 . CF. fli?lj-l 51-06201521217211 98996 GIUFFRE003272 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page562 of 883 DocType.? LAB REPORTS 525 East 68th Street, New York, N.Y.10021 M. Desmond Burke, M.C., Laboratory DLracCor CLIENT INFORMATION: L. EMOND, STEPHEN MD 525 Eas: 68th New NY 100210000 Client?z 00000 may. sosmm_L_ 3925.513 Name: ROBERTS, VIRGINIA Coll mm: 07/09/2001 Racvd Date; 07/09/2001 Date: 07/10/2001 Cull :Lmu: 1915 Recvd Time: 1925 Time: 0438 mm ABNORMAL @5353:er UNITS ROUTINE CHEMISTRY 115~ 1 39405 mg/dL Egg}; NIIROSEN 8 79:;5 rug/db ?0 . 5?1 . 5 mq/dL 133?3 4 7 moi/L 6 r: . Swim-311 103 ?91.11;? mmol/L co: 2; 33332 _mo1/L Argo-:4 (:53 ?14 2ch ACID #34727 3.5?7.5 mq/dL LALCIUM ii 3 1 mq/dL . ?3 2 mg/dL 7 . '7 5. 5?8 gz'dl. ALBUMIN g/dL g; 1 8-3 3 g/dLm 0.7 2?1 3 *4 3. DIR 0.1-0mgde 130 r? 200 mg/dL 2 mquL 30 0?45 GIL ALI 0?45 CHOLESTEROL (03/17/1999 Current} Page 7 01.05.201521z17z11 GIUFFRE003273 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page563 of 883 DocType: LAB REPORTS DESIRABLE: BCRDERLINE HIGH: <2oo mg/dL 200-339 mg/dL HIGH: OUTFAIIENI REPDRI '1 a! Page: 1 CONTINUED PmeB CONFIDENTIAL .pnoagn152111n1 Case 18-2868, Document 283, 08/09/2019, 2628241, Page564 of 883 Desmond Buzke, M.D., baburatory_pirecrsc CLIENT INFORMATJON: EMJND, STEPHEN MD 525 East 68th Street New Yark NY Clienth 00000 NEW Patient Name: ROBERTS VIRGINIA L. Coil Date: 07/09/2001 Recvd Date: 07/09/3001 Date: 07/10/2001 391} _'I_imez _1__9_15 Time: 1925 Rp: Time: 0438 EENAL 319911.131. 3.21323: "Int 2. LD 4.83 33?3235 FHGS 3g 90/14. g?omm RISK ?x 390 _mg/dL DESIRABLE: (.200 mgde BORDERLINE HIGH: 200~239 mg/dL 33110 :n-g/dL . 5: 133?99?9 21217111 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page565 of 883 Typl: LAB REPORTS PageDINQO11 fume 01-06-2015 21.17.11 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page566 of 883 525 East 63th Etraet, New York, M. Gurkt, M.D., Labor$t0:y Director CLIENT INFORMATION: Patient Name: RCBERTS, VIRGINIA L. EMOND, STEPHEN MD 525 East 65th Street _Naw York eq . C.i:rtn: rim: Coll Date: 07/09/2001 Recvd Data: 0710912001 Date: 07/10/2001 COLL Time: ?1934 19%j_ Time: _p?38 usu' NAME NORMAL REFERENCE UNITS SENDOUI CULTURES BLOOD GROUP AND TYPE PROCEDURE: PH 23/09/2001_1534 A P1: 1917113003 SCREEN AND rm EQEILMZD Wig: Bdby0m9011 Page 11 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page567 of 883 DozType: LAB REPORTS Page: _1 OF CHART 3 Id by omen Page 12 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page568 of 883 525 East_?8rh Straef, New York, N.Y.ICOZJ Laboratory Director CLIENT INFORMATION: Patient Name: ROEERIS, VIRGINIA L. mono, STEPHEN 3 MD 525 East 58th Street New Yoxk Clien:#: 00000 YORK. HOSPITAL NY 100210000 Coll Date: 07/09/2001 Recvd Date: 07/10/2001 Date: 97/11/2001 331; Time: 0941 Recvduiimei .9941 lime: 04?g_ Emu NORMAL REFERENCE gc CHLAMYDI A-GC AMPL I F1 CAT I ON CHLA swAB sonar: 55mm: gum 5951113 magnum-2 NEGATIVE swag 51:95:}: was NEGATIVE Page: _1 END f_ adby 01mm: Fags 13 51105-2915 21:17:? Gmmaooam CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page569 of 883 ocTyper LAB REPORTS 525 East 68th Street, New York, Desmond Burke, M-D-, Laboratory Director LIENT I ON: Patient Name: ROBERTS, VIRGINIA L. SHONE), STEPHEN MD 5'25 East 68th Street New Yogi _1_00210000 Client?: 00000 Mi 7 i Coll Date: 07/09/2001 Recvd pgnez 07/10/2001 Rpt; Date: 07/11/2001 TimE_ 15,129 - 3941 Rpt. Iime_:_ 9452 .I'g-zglIAL Issz_?AMg ABNORMAL NGRMAL REFERENCE UNITS IURE- SC REEN COLLECTED: 07/09/01 1929 RECEIVES: 07/10/01 0941 STARTED: 07/10/01_g341 GENITAL CULTURE FREETEXT gouaca: STAINS 1; EANY GRAN POSITIVE BACILLI CONSISIEN: KIIH LACIDBACILLI MSDERATE EPITHELIAL CELLS 933m Page Pwem GIUFFRE003280 (CCXVIUIDERJTTAUJ Case 18-2868, Document 283, 08/09/2019, 2628241, Page570 of 883 DocTypa: LAB REPORTS 68th Street, New York, N-Y.10021 525 East 51. Desmond Burke, M.D., Laboratory Director CLIENT INFORMATION: EMCND, STEPHEN MD 525 East 68th Street. New Yo:k NY 100210000 Clientl:__g0000 NEW. 19345. Coll Date: 07/09/2001 Recvd Date: 07/10/2001 Date: 07/12/2001 Time: 1929 Egvd Time: 09-21 BE: 533 PARTIAL ABNORMAL NORMAL UNITS TE- 5 5&3:th 1 EN comm-215:0: 07/09/01 19:39 07/10/01 0941 STARTED: 07/10/01 0941 spams 5. 93:33 "07/10/2001 FQSITIVE BACILLI CONSISTENI HIIH LACTOBACILLI MODERAIE EPIIHELIPLL CELLS frazmgiiw 5111:; REPORT 07/11/2001 f?i' CULTURE BEING HELD FOR Evan-111111213 'ed by DIN9011 Past 15 GIUFFREOO3281 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page571 of 883 DocType.? LAB REPORTS Page _1 OF HART Page ?16 01-08-2015 21:17:11 Glumusooszsz CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page572 of 883 575 hast 68th b?f?et, New York, N.Y.10021 Desmond Surge, M.D., Laocratcry Directcr CLIENT INFORMATION: EMOND, STEPHEN MD 525 East 68th Street New York Client?: 00000 NEW YORK Coll Date: 07/09/2001 Recvd Date: _07/10/2001 Date: 07/12/2001 90.111. Time; 3855 gagvgd Time: 1103 _Rpt "lime; 9532 EESTLFAME CULTURE URINE CULTURE 07/09/01 1855 CLEAN CAECH RECEIVED: 07/13/01 3102 STARTED: 07/10/01 1102 FREETEXT SOURCE: ACCESSION31 anonr _07/11/2001 4323 [<1,000 Page: END OF CHART 2? 'ed by omaon Page 17 ?43}:ng 21:17:11 GIUFFRE003283 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page573 of 883 525 East 68th Street, New ?011 Date: _Iasr_pAM3 07/09/2001 1923 GENITAL CULTURE FREETEXT SOURCE: E: Desmond Burke, Laboratory Director CLIENT INFORMATION: EMOND, STEPHEN MD 525 East 68th Street New York J00210000 Client?z OOCOO NEW YORK HOSPITAL Recvd_9atc: 07/10/2003 Rpt_9?te: 07/13/2001 ?ecvd Time: 0941 Time: 0541 ABNORMAL NORMAL COLLECTED: 37/09f01 RECEIVED: 37/10/01 STARTED: FREPS 07/10/2001 1:43 MANY GRAN CCNSISISNE.HLI5 LACIOBACILLI MOCERATE EPITHELIAL CELLS MCDERAIE wsc_sagm MODERATE GRAM LACICBACELLI sazws MODERATE GRAN LQQIQBACILLI CULTURE BEING . 2 cdbyoleon 07/11/2001 1037 POSITIVE BACILLI CONSISIENI WITH FOR FURTHER EVALUATION no: 1130 POSITIVE BACILLI com??572nr a HELD FOR FURTHER EVALUATION PageTB CONFIDENTIAL 1929 0941 0941 Case 18-2868, Document 283, 08/09/2019, 2628241, Page574 of 883 ?mu_~a_asmms Page: i END OF (BART I 3' ed by Page19 31omg91531:17z11 GIUFFRBOOBZSS CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page575 of 883 525 East 68th Street, New York, M. Desmond Burke, M.D., Laboratory Director QIENT EMOND, STEPHEN MD 525 East 68th Str?et New York NY 100210000 Clienti: 00000 NEW YORK HOSPITAL ROBERTS VTRGINIP. . Patient Name: Coll Date: 07/09/2301 Recvd Date: 07/10/2001 Date: 07/14/2001 Coll Time: :929 Racvd Tima: 0941 Rpf. _Ti_r3e_:_ FINAL TEST NAME ABNORMAL NORMAL UNITS GEHITRL CULTURE- GENIIAL CULTURE COLLECTED: 07/09/01 1929 RECEIVED: 0?/lD/01 2941 FREETEXT sauuza: STARTED: 07/13/01 0941 A c35513u? (qg?MB?Ol?045532 3 STA INS 5- PREPS 07/10/2001 53ng MANY GRAN POSITIVE BACILLI CGNSISIENT WITH LACIOSACILLI MODERATE EPITHELIAL CELLS MC-DEPATE 'rlBC SEEN 3w _07/1;/2093 1037 GRAN POSITIVE BACILLI Egg? FURTHER EVALUATION ?at/31:01 1130 GRAM POSITIVE BACILLI CONSISTENT WITH BEING FOR FURTHER EVALUATION FINAL 111: POSITIVE BACILLI CCHSISTEHT wzra - I 01-06-2015 21:17:11 CONFIDENTIAL GIUFFRH003286 Case 18-2868, Document 283, 08/09/2019, 2628241, Page576 of 883 LACTOBACILLI 1 50.99% Page: END OF CHART Plus 21 010532015 21:17:11 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, PageS77 of 883 New York Wail] Well Medical Gem: . DMGNOSTIC PROCEDURE onn?n F?om- ?aw ?3??me - mammal .. a) Matt -. - Dull-Ind 1 an Chardmenu?.- aim . a m: 0?.?ng -- 25m mm WWNIMMmququwomm' 'B?mg29093 hmziw.? A~zu~ an i? . .- camwav Nirvana ?onm OW DATE . . D?wnmm .5201 . . aamam sum . ?Wm. m' Dane 23093 gnu-arm 68701 mm? 2199 25.7.7. mm . . Dean-m 53093 - mucus-mo :1 .0 . ma Um. 9094mm ?my 0 . Huntsman 0013? %mmDOWN 80137 .80137 mas-lam . - - 07W . . DRanaL 50157 . I. awn;~ . UM 30137 . . . BMW): MIST ??373 answer - -. . Um 88873 - Elmm - mo 13m {mm 030W 63090 - Mucbsm' seen ?lawman Elgar! [And sap-u nth-"Manama-mumCLINICAL DATA DWPwimg- mqumx DWthaimp-j ,3 . Ll- mayOrdaimP I 16 'cou?_ - Dab Time MandingMD - - RNSI RN manna meow Ev Pegu 11'. 1211 GRIFFRE003288 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page578 of 883 We: 4. Flu: .. ibny oi the Radologv eoromlnadone requie ihai the pe?eni be paneled for the proradue that is balm ordered We have oonunon vocational-WEI. all atoms In Inchidad lntheManuai ammxmum Special Procedures Mmmudln the Andiiarir Services socion in We m. ?re procedure the manual comm a brief deealp?m. omimindimiione, man proper and special instructions. can Podium: Bedding Wit: modi?ed props for patient: mes. NOTE- Wor is drilled when eroding multiple aroma. Barium etudlse generally . should be done alter outer dogmatic procedures. See Manual for more complete lniorma?on or dim Wayst an as mite delay ps?errtosre Gd. Series Prep: N. .0 from Midnigndd day More study amend all medication sump! easmlial. WW ohodd be commuted 24 hours before procedure. . Aftercare: mild laxative and ?uids. Barium Enema Prep: Clear ?uids 24 hours priorto smdy'. 4 blaoodyllabieis (dulooiwr) by meulh at 10 more rim beforeeaem 1 bis-aoodyl supposliory morning of exam Noll-ling by mouth after uidnight. WP. (immune Pyeiogrem) Prep:10 emcee of?ioanoeium pirate PM merrily before mm. Netting by mouth after midnight. 0.12 (Head 5 Body) Pwp' Clear ?uids 4 hours prior to dudy. Contrast injection requires ire pa?ent be NPO for at least 4 nous pdorin study. Patients must and abie to hold her breathior Bony 01?s. Mercer?s: Patients receiving poorest should be hydrated. MRI CONTRAINDICATIONS: d) Padem over 300 lbs. Purim: with FACBAAKEHS CANNOT as DONE Pailenrs wlih metal sugirni clips and olhsr rim/lees sl'iould consult wih 1he ?adbiogiai bolero ordering G) Claueo?ophobh and to remain still are also contraindication and sedation may be required. SEE WNJAL FOR COMPLETE DETAILS. Sonoyme Requires lull blac?er. Palm should drink water and malnrah a full bladder. ABDOMINALIAORHC RENAL: Clea liquid diet for 24 hours prior to exam. Nuclear mrm- SPECIAL 1. To obtain an odequlp annoy. pawn must be oblate ls qulsily for up In one hour' In supine pm?. _o For biliary. meoirero. carriers. and shy eiudles requiring sedation. tl'le pair-1i mus: premier a mhimum or 3. Radioactive iodine ieuesd brihyroid wire and soars-ring. Do not MIG lost lmyofthe roaming drugs woods-rave been ingesm within minimum limits Indicated: lodhe Compound Moore Potassium iodide. Ken): 1-2 weeks Seafood. Ovaillne. vitamin pile. Grands. Gambid: 3-5 days Diodrst. Hypeqie 0.3.. lVP'send Prbdax. Telemue. sic. (Le. gallbladder series): 3-6 months Uplodd i buts motifs! Nil-rhyme drugs (1.9., Propyiihioureoll. Topezoloi: 7 clays. If In proportion for urgent radioiodne heathen, mutation advised? Thyroid ?mm (1.0.. Miocene mummy 4m Tri-lodo?lhyrodne days. it special drcmeienoes require the above indicmrons {contahdicmiomj Nuclear pliysiohn consultation some. .ma?C?I- Mom-1.0mm Page 2 01- 0&2015 21:17:22 4' GIUFFREOO3 CONFIDENTIAL 289 Case 18-2868, Document 283, 08/09/2019, 2628241, Page579 of 883 In- NEWYORK-PRESHYTERIAN Bosrrm. #3 New York Weill Candi Medical Center 45171 . i EMERGENCY DEARTMENT Ir "017mm. mums. sauna MEDIMFEOOHJ no. Plume-Davmm DbmaE DFoloy Camera 55?. - ?25:321- - 951131399 -2 2 1503i 43 #5 .3 Wm AZ M4 odrra. .2924; -- 5.2 MW murm?w? rm i I :5 :13 Page a owszows 21 {12:22 JIM: CONFIDENTIAL Cam: 18-7868, 782, 08/00/7010, 7678741, P292080 nf 882 EXHIBIT 34 (Filed Under Seal) ifgm, 3% of 883 Sent: Thur 2/17/2011 9:44:51 PM Importance: Normai Subject: RE: Received: Thur 2/17/2011 9:44:51 PM Not a probiem but we have to continue rest of the interview at my house being that the chiidren are not feeling well, you have got only documents pertaining to my case. Look forward to seeing you this afternoon . Jenna Originai From: Sent: Friday, 18 February 2011 7:25 AM To: Virginia Giuffre Hi there Have been up night writing. Won't have an opinion from our lawyer on how much can be pubiished until London wakes up. The lawyers wanted internal FBI documents but I think the Justice Dept letter is all you have from the Anyway can I give you a call early afternoon? Maybe have a iate lunch? 8 This e-mail and any attached fiies are intended for the named addressee only. It contains information, which may be confidential and iegally privileged and aiso protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disciose it to anyone else. If you received it in error please notify the sender immediately and then delei it from your system. Please be advised that the views and opinions expressed in this e?mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e?mail and any attachments to it for viruses as we can take no responsibility for any computer viri which may be transferred by way of this e?mail. Use of this or any other e?mail facility signifies consent to any interception we might lawfully carry out to prevent abuse of these facilities. Associated Newspapers Ltd. Registered Office: House, 2 Derry St, Kensington, London, W8 5TT. Registered No 84121 England. Cam: 18-7868, 782, 08/00/7010, 7678741, PangRQ nf 882 EXHIBIT 35 (Filed Under Seal) gsgm, 3:333? c1883 Sent: Sun 2/13/2011 4:29:38 AM Importance: Normal Subject: RE: Agreements etc Received: Sun 2/13/2011 4:29:38 AM Hi Sharon, my address is ?call me back for the directions from gosford and my hubby will lead the w: from there. Original From: Sent: Saturday, 12 February 2011 2:10 AM To: Virginia Giuffre Subject: Agreements etc Hi there, Thank you again for your email. We totally understand your concerns. Please don't worry about anything. Whatever happens, we are bound by con?dentiality unless you consent to an article in a formal contract signed by you. Since I will be in the air by the time you wake up, can you email our Assistant Editor Sian James -- sian.james@mailonsunday.co.uk -- your lawyer's information please? Sian will arrange to get him whatever assurances he requires. We really want to make this work and of course we want to protect you. We'll be really grateful if your lawyer will provide us his cell phone number as we'd like to sort this all out asap. Meaning we would like to talk to him Saturday EST. I will give you a call from Sydney. Fingers crossed we get over this last hurdle! Best regards, Sharon This e-mail and any attached ?les are intended for the named addressee only. It contains information, which may be con?dential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then delel it from your system. Please be advised that the views and opinions expressed in this e-mail may not re?ect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any attachments to it for viruses as we can take no responsibility for any computer virr which may be transferred by way of this e-mail. Use of this or any other e-mail facility signi?es consent to any interception we might lawfully carry out to prevent abuse of these facilities. Associated Newspapers Ltd. Registered Of?ce: House, 2 Derry St, Kensington, London, W8 5TT. Registered No 84121 England. Cam: 18-7868, 782, 08/00/7010, 7678741, PangRA nf 882 EXHIBIT 36 (Filed Under Seal) of 883 Sent: Fri 2/25/2011 10:12:25 PM Importance: Normal Sibject: RE: Re: Received: Fri 2/25/2011 10:12:25 PM The ?ight logs didn't come through properly,could you please resend them? Thanks- Jenna Original From: Sent: Saturday, 26 February 2011 7:56 AM To: Virginia Giuffre Subject: Re: Can look at the ?ight logs Ijust sent and see if any ring a bell re Virgin ls/Andrew orgy please? 8 X0 From: I To: 25/02/2011 20:54 GMT - Subject: Hi shazza, I am hoping it all goes well this am, please let me know when you know something. As far as other publications go, am happy for your company to decide as long as I am not made out to be a know my Talk to you soon buddy! Jenna Original From: Sent: Saturday, 26 February 2011 6:46 AM To: Virginia Giuffre So far it is all looking good. Waiting for a comment from Andrew. VWI let you know as soon as we get it. Are there any publications to whom you do not want the piece syndicated? (You get 50 per cent of the proceeds). Shaza xe Case 18-2868, Document 283, 08/09/2019, 2628241, Page586 of 883 This e-mail and any attached fiies are intended for the named addressee only. It contains information, which may be confidential and legaiiy privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disciose it to anyone else. if you received it in error please notify the sender immediately and then deiete it from your system. Please be advised that the views and opinions expressed in this e?maii may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e-maii and any attachments to it for viruses as we can take no responsibility for any computer virus which may be transferred by way of this e-mail. Use of this or any other e-mail facility signi?es consent to any interception we might lawfully carry out to prevent abuse of these facilities. Associated Newspapers Ltd. Registered Office: House, 2 Derry St, Kensington, London, W8 5TT. Registered No 84121 Engiand. This emaii has been scanned by the MessageLabs Emaii Security System. For more information please visit This e?mail and any attached fiies are intended for the named addressee only. It contains information, which may be confidential and iegally privileged and aiso protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disciose it to anyone else. if you received it in error please notify the sender immediately and then delet it from your system. Please be advised that the views and opinions expressed in this e?mail may not refiect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e?mail and any attachments to it for viruses as we can take no responsibility for any computer vin which may be transferred by way of this e?mail. Use of this or any other e?mail facility signifies consent to any interception we might iawfully carry out to prevent abuse of these facilities. Associated Newspapers Ltd. Registered Office: House, 2 Derry St, Kensington, London, W8 5TT. Registered No 84121 England. Cam: 18-7868, 782, 08/00/7010, 7678741, P292087 nf 882 EXHIBIT 37 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page588 of 883 '1?11?1111 1,21,; 1mg?; I i 1,43: :11? -1: Hm? mix In ?.htr sue-an I "at 3.5.1.1172!" I Ilia! MAN ?mm? link 53?? 1.111 'llf? goof? 4 1:100va er; aer- m- '12 {214.43. .1111rm: 11' human; I - Personal lnformanon 1.2- .., FOIA F.?l 1. 2-1'1 .4 GIUFFREOO4721 Cam: 18-7868, 782, 08/00/7010, 7678741, PangRq nf 882 EXHIBIT 38 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page590 yaw.- 0110ADDRESSAGE: .: 11551.: :2 13:5. 51501.2 (No: in a rcluhnzhip} SINGLE .1. 7duionghp} - NAME . AGE (2cm 20x25 D?mc?pzicn 0ft FACIO . NAME 3-131.? of partner 0? ONSHIP: :2 - Ninth? I ?Jib; M- How tong ?1 .. chdmior. ot?sgousc . - A Dccipcicn cfshazcd :da?onsbip: v3" (II-TED KEN: soxs'--? PREVIOUS MA RELATIONSHIPS 1. NAME HOW LONG Ranger. :cialior?bip .. CHILDREN 5.. man smraca x. .?chvzaf . GIUFFRE005433 CONFIDENTIAL Qui- :?lw v.51?? 31% ?lKl? Jh?w' Case 18-2868, Document 283, 08/09/2019, 2628241, Page591 of 883 . '?Cv - -. 3101111511- AGE HEALTH x: .95 .1 2A. mama, sums mamma- - A. .. . - Relatiquship with Mather: Selim cw panmcr. DESCREHONUF MUTE-ER. Foal-rim - may. mm'a? WM. maamrs? -- - MAWULATIVE SIESYANCE ABUSE .T if; EIHTROMNTAI. R5: DESCRIPWQN RELATIONSEHP. - 4- mm was: m3? .d Fangs.- AGE HEALTH MARITAL STAHJS: MARRIED SEPARATE PARTNER RELAY ertdw . . . .-. -o u. .., . nun-o?- ?5:155- -4 I N3 USE 0F Disrmr Exam?r . 51131 ?mes mowexmum?rammsn M. EAR BROTHERS {?30ng qx SIS-I '5 543' '1 Wu." Sing'u: N?f??d?du fnustcparatcdr'?ivmw?thifdren MAHONSIUP: VERY CLOSE CLOSE Emm?w (H: FAMILY VERY CLOSE GIUFFRE005434 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page592 of 883 mum?oonmno LESCENT Isrosw . Hagar Desmvnow m- 535 AS A can- COMPLIANT DESCRIPTION OF SELF as A 1155mm A Mammal-u? WITH -- EDUCATIONAL HISTORY HSC Tammy slud?afdnivm?t3{ . PW Framinmi?on Oman? ngihaftim: .H. Rec-3Signi?um mnum'opm?ma?tralmw ??xfb'3hi v. . hay-x x. .- awnin- i. 1 rue-5m:- r. .. .- A MDICATIUN Suhamm abuse: Nachol his 5 n_ Niacin: _Othcr in; taking glam -. 11,5? .5). 3: uf armada . . 1 I- Wags )tJng- ?Kx 41-53 950? Tcnr?ual'a?ms (15:56 rcasauahld hadfsti?l! Jaded by ?ecision) . . I. E?g 1 RR. jhlh'1K?E' In die} .I f?i?x \31 W1 Kris: if: aqu'l?n?k?kvGIUFFRE005435 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, of 883 0F mas PROBLEM. TIME OF 1' I SLEEP Gde'l'nIls ask-c;- easilyl' mmbie?pucn?dil?culiy stayi :15? micqp' Await am through night.? unatble to ?u Emmi it: slcc'p AWAKENE FEELWG: Fmt?lircdz?dcwru' Morning petm??uligh: person Amman: of menu! dismiss in family unieforigin mg? .1. .- MEMORY: Gao??rumahidpmr - SUICHML Anunpt: and: manner EPIIJEPSY - yawn mam mmnowmms (Hobbiu rec-axiom] internals) walking'cu??ucxiwk Enraiwithpannu' as . .4 Whirl-CAL7?7. 1 (C. :11 Rolcv'inthJ-iuund me- Fm; -ma-j-cfw um: uLu' ?minished n: [whining in . .. . Adec?ge-d - wiidatim -- recapitiml - ?ws. :Irx - HYPNOHIS SUGGESTH: unypnusis?Pamphie: FORMAT: Relaxation rcxpoam?cmmting I?ZM?mlmludcyc ampsAPPROPRIATE 3:051 FUTURE WORK TREATHENT I. ?k??ii an? -- Ear-1: Mx?xwPM.) ?an-u. 555%; MW 44.11.; 114.4 1. ?4 .- ?:11 w; .L GIUFFRE005436 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page594 of 883 ?11: . 1" 1?72: 11' 'u "Lab-F! i ?1 ?1 2 3? ?171,213\\ ?53} CA1 {m'xxoga?ikkh\ 1.1m; Ring 1 (1?1 (321-?mun-1?11: . . 2 i? {Jun ?ekim L: 01-5113. I Rik Eli-.1311 . (1-13.12 11:51:31 e?-t Ail-4?1 ?1 \1 1:th 1-1 1?11? 1? - 1?3? . {'31 ?6.13 (3713121111311:ka 1x11311111? \kaxx E11: 1.11ng 12:. -22, - i - 2., ?5 _917'3 9-1 12.81211; (Dem :1th ?3 1 ?\Oddk hf 1D. #5351 . 5.. 1271-2- ra 3:4- _J'x . r3 a?i?x (1L1 ?1'12?1?1 1:11.th {?Km'h?1 $11:ng \12 3921? ?.711: 1'5 11.11; 515 (?11 :21 Mahmrh? 1. iktaam UR - 3 ?5 1., 11111151111113: 11.28.91. 1211735111131 11.. mmhnowr ?01 14.32331 \L?ra? - Wmhedtnil ?121.35 tjrw\. ?13119"bn: i?xu? 1, r? {?1322 ?1 1 1.1.. 1? -J In. ?1?1 1.51? F'n ?1?1 .A?am 3:121? ?35} .1, .. (?1.111 SN?x?u?y; '\7"16 2; 3?5; ELL- :3 16.1% ?3 136g\Ung?n hulgk (?nfih ., I vid? '11_ {:53 11 $343,351?; 1'11: _I?Q?ii?l \m13u2m\\u\h.n ham: '1/1 . 1?51: .r 4:31 .121 15.1 01 11-11% GIUFFRE005437 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page595 1:1 xiv R?J'ugl?l?b? 1. km(Quix- $51.13* Lu {1-3 wk - - r-?K (L'S?xb {hi-k \t dT?Iu'xhh? I 15?? I I. I: l' .- ?123 I- I f. .- ?n .. Ill-n! Eu?um?i? Km Ew?wx?w'. fix-\exic?, thcL-ujmt?h fir-=- a; "x - in3.. N1. ?ixdi?wx?h ?iwx?M-m k-rki?vuGIUFFRE005438 CONFIDENTIAL Cam: 18-7868, 782, 08/00/7010, 7678741, PangQB nf 882 EXHIBIT 39 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, PALM BEACH POLICE DEPARTMENT . Incident Report Page5970f883 Page. i - :s Program: CMS3 1L 9 te 7/25/06 .1me 8: 47: 53 Case No. . SPECIAL NOTES Occur To Date Day Of Week Common/Location: City . . . Location Type Beat Assignment: Dept Class Case Status Supervisory Dt.: . OREGERO, LAURA 4/06/05 Entry Date Names? Vehicles? Narrative? I Case number State Veh Type Make . Model Name Style Color Bottom VIN . Disposition Insured by . . Vehicle locked Date recovered Street number City . Recovery code Be On Look Out?: 0 Case Number Street Number City . . Birth Date/Age Occupation Home Phone No. Sex . Weight A Prompt valid in: Case Number Street Number City . Birth Date Employer? Oper Lic No. Other Phone Nbr: SEX . Winimum Weight DO NOT RELEASE OPEN ACTIVE I 1-05-000368 1/27/05 0000 Report Date Thursday. 358 EL BRILLO WY PALM BEACH, FL - RESIDENCE-SINGLE FAMILY Map Reference Report Officer Case Status Dt 3/14/05 DETECTIVE BUREAU SEXUAL BATTERY JEFFREY Property? Offenses? . Related Cases? A I Category Year Model . . Permit Number Color T0p License Stolen value Insured Keys in car Lein holder Recovery value I 1-05-000368 0/00/00 NCIC number I 0 Name . . I 1-05?000368 Employer? Oper Lic No. Race . .. - Female Height . Other Phone Nbr: 1-05-000368 OYAL PALM BEACH FL 334121460 Maximum Age . Occupation Home Phone No. Race Female Minimum Height 0 Maximum Height Occur From Date: I A I 1/27/05 0000 3/14/05 1600 10 PAGAN, MICHELE 3/14/White i 0 1 ROBSON, HALEY 18 White 3 0 0 GIUFFRE005614 Case 18-2868, Document 283, 08/09/2019, 2628241, Page598 of 883 PALM BEACH POLICE DEPARTMENT Incident Report .ime: 8:47:53 Page: 2 Program: CMS3 01L I Case No. . . 1?05-000368 Maximum Weight 0 Aliases? . Hair Color . . Hair Style . Glasses . Facial Hair . Teeth Hat Shirt Shoes . Body Marks #2 Body Marks #4 Arrest Case No.: A Case Number .. 1-05-000368 Street Number 358 EL BRILLO WY City . . . . . Birth Date Employer? . Oper Lic No. Other Phone Nbr: 561/000-0000 Sex . . Female Minimum Weight 0 Maximum Weight 0 Aliases? . Hair Color . Hair Style Glasses . . Facial Hair Teeth . . Hat . . . . . Shirt . . . . Shoes . Body Marks #2 Body Marks #4 Arrest Case No. O. 0. ll 0 1-05-000368 358 EL BRILLO WY Case Number Street Number City . . Birth Date Employer? . . Oper Lic No- - Other Phone Nbr: Sex . . . . Male Minimum Weight 0 Maximum Weight 0 Aliases? Hair Color Hair Style Misc. . . MO/Crime Spec? Hair Length . Color Complexion . . Build . . . . Speech . . . . Coat . . Pants . . Body Marks #1 Body Marks #3 Status . . Additional I Prompt valid in: PALM BEACH FL 000033480 Maxim Age Occupation Home Phone No. Race Minimum Height Maximum Height Misc. . . MO/Crime Spec? Hair Length Color Complexion . . Build . . . . Speech . . . . Coat . . Pants . . ?Body Marks #1 Body Marks #3 Status . . Additional I Prompt valid in: PALM BEACH FL 000033480 Maximum Age . Occupation . . Home Phone No. Race . . Minimum Height Maximum Height Misc. . . MO/Crime Spec? Hair Length . Color White (Continued) STILL SUSPECT A I - 2 KBLLEN, SARAH LYNNELLE 25 PERSONAL 561/000-0000 0 .. .. . STILL SUSPECT A I 3 JEFFREY 52 White 0 GIUFFRE005615 Case 18-2868, Document 283, 08/09/2019, 2628241, Page599 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 3 Date Incident Report Time: 8:47:53 Case NO. . . . 1-05-000368 Glasses Facial Hair Teeth? Hat . Shirt Shoes . Body Marks #2 Body Marks #4 Arrest Case No.: I I 1?05?000368 Case Number Prompt valid in: Street Number City . . Birth Date/Age Occupation . . STUDENT Home Phone No. Sex . . Female Weight . . 0 Be On Look Out?: Victim Type . JUVENILE Residency Can Identify Injury Extent Injury Type 2 Med Treatment Last Name I I Case Number 1-05-000368 Street Number Program: CMB301L (Continued) Complexion . Build Speech Coat Pants Body Marks #1 Body Marks #3 . Status . . . . STILL SUSPECT Additional UCRP: I A I Employer? Oper Lic No. Race . . . . . White Height . . . . 0 Misc. Other Phone Nbr: Residency Type File Charges Victim Sobriety: . Injury Type 1 5 Hospital ID - 5 First Name: I A I 2 i ALM BEACH FL 000033480 City . . . . Birth Date/Age 13 Occupation . Home Phone No. 561/000-0000 Sex . . . . . Female Weight . . . . 0? Be On Look Out?: Victim Type . ADULT Residency Can Identify Injury Extent Injury Type 2 Med Treatment Last Name I I Case Number . 1-05-000368 Street Number Employer? Oper Lic No. Race . . . . . White Height . . . . 0 Misc.'ID# Other Phone Nbr: 561/000-0000 Residency Type File Charges Victim Sobriety: Injury Type 1 Hospital ID First Name: I A I Prompt valid in: City . . FL 000033480 Birth Date/Age 16 Employer? GIUFFRE005616 Case 18-2868, Document 283, 08/09/2019, 2628241, Page600 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 4 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . 1-05-000368 (Continued) Occupation . . Oper Lic NO. . Home Phone No. 561/000-0000 Race . . . . . White Sex . . . . . Female Height . . . . 0 Weight . . . . 0 Misc. . . Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . JUVENILE Residency Type Residency . File Charges Can Identify . Victim Sobriety: Injury Extent - Injury Type 1 Injury Type 2 Hospital ID Med Treatment First Name: Last Name I I I A I 4 Case Number . 1-05-000368 Prompt valid in: Street Number City . . PALM BEACH, FL 000033480 Birth Date/Age 17 Employer? Occupation Oper Lic No. . Home Phone No. 561/000?0000 Race . . . . . White Sex . . .2. . Female Height . . . . 0 Weight . . . . 0 Misc. . Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . JUVENILE Residency Type Residency File Charges Can Identify . Victim Sobriety: Injury Extent Injury Type 1 Injury Type 2 Hospital ID Med Treatment First Name: Last Name I I I A I Case Number . 1-05-000368 Prompt valid in: Street Number City . . FL 000033480 Birth Date/Age 18 Employer? . Oper Lic No. Occupation . . Home Phone No. 561/000-0000 Race . . . . . White Sex . . . . . Female Height . . . . 0 Weight . . 0 Misc. . Be On Look Out?: other Phone Nbr: 561/000- 0000 victim Type . ADULT Residency Type - Residency File Charges Can Identify . Victim Sobriety: Injury Extent Injury Type 1 Injury.Type 2 Hospital ID Med Treatment First Name: Last Name I I I A I 6 Case Number . 1?05-000368 Prompt valid in: GIUFFRE005617 A. .. ..-.. Case 18-2868, Document 283, 08/09/2019, 2628241, Page601 of 883 Date: 7/25/05 PALM BEACH POLICE DEPARTMENT - Page. Time: 8:47:53 Incident Report Program: CMEBOIL Case No. . 1-05-000368 (Continued) Street NUmber City . . . . . PALM BEACH, FL 000033480 Birth Date/Age 16 Employer? Occupation . . Oper Lic No. . Home Phone No. 561/000-0000 Race . . . . . White Sex . . . . . Female Height . . . . 0 Weight . . 0 Misc. . . Be On Look Out?: Other Phone Nbr: 561/000? 0000 Residency Type - Victim Type . JUVENILE Residency Can Identify Injury Extent Injury Type 2 Med Treatment Last Name I I Case Number 1?05-000368 Street Number File Charges . Victim Sobriety: Injury Type 1 . Hospital ID . 3 First Name: I A 1.0 7 Prompt valid in: ALM BEACH FL 000033480 City . . . . Birth Date/Age _17 Occupation Home Phone No. 561/000?0000 Sex . . . . . Female Weight . . . . 0 Be On Look Out?: Victim Type . JUVENILE Residency Can Identify . Injury Extent Injury Type 2 . Med Treatment Last Name I I Case Number 1-05-000368 Street Number )ccupation . iome Phone No. 561/000-0000 ;ex . . . . . Female Ieight . . . . 0 3e On Look Out?: 'ictim Type . JUVENILE lesidency tan Identify . injury Extent ?njury Type 2 ied Treatment 'hys Last Name I I Employer? Oper Lic No. . Race . . . . . White Height . . . . 0 Misc. . . Other Phone Nbr: 561/000- 0000 Residency Type - File Charges Victim Sobriety: Injury Type 1 Hospital ID First Name: I A I 3 Prompt valid in: Zity . FL 000033480 . Birth Date/Age 6 Employer? . . Oper Lic No. . Race . . . . . White Height . . . . 0 Misc. . . 3 Other Phone Nbr: 561/000-0000 Residency Type File Charges Victim Sobriety: Injury Type 1 Hospital ID First Name: I A I - 9 GIUFFREOOSG18 Case 18-2868, Document 283, 08/09/2019, 2628241, Page602 of 883 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 6 Program: CMS 3 0 1L Case No. . . 1?05?000368 Case Number 1?05-000368 Prompt valid in: Street Number. City . . PALM BEACH, FL 000033480 Birth Date/Age ?17 Employer? Occupation . Oper Lic No. Home Phone No. 561/000-0000 Race Female Height Weight . . . . 0 Misc. Be On Look Out?: Victim Type Residency Can Identify Injury Extent Injury Type 2 Med Treatment Last Name JUVENILE I I Case Number 0 - 3 I A I Other Phone Nbr: Residency Type File Charges . Victim Sobriety: Injury Type 1 Hospital ID First Name: . 1- 0 6 Prompt_valid in. Street Number City . . PALM BEACH, FL 000033480 Birth Date/Age 17 Employer? Occupation Oper Lic No. Home Phone No. 561/000-0000 Race . . . . . Sex . . . . . Female Height Weight . . . 0 Misc. . . Be On Look Out?: Other Phone Nbr: Victim Type JUVENILE Residency Type Residency . Can Identify . Injury Extent- - Injury Type 2 Med Treatment Last Name I I Case Number 1-05-000368 Street Number City . . I Birth Date/Age 18 Occupation Home Phone No. 561/000?0000 Sex . . . . . Female Weight . . . . 0 Be On Look Out?: Victim Type . Residency Can Identify Injury Extent Injury Type 2 Med Treatment ADULT I A I File Charges Victim Sobriety: Injury Type 1 Hospital ID First Name: White 0 561/000-0000 White 0 - 10 561/000?0000 - 11 Prompt valid FL 000033480 Employer? Oper Lic No. Race Height Misc. White 0 Other Phone Nbr: 561/000- 0000 Residency Type File Charges Victim Sobriety: Injury Type 1 Hospital ID First Name: GIUFFRE005619 Case 18-2868, Document 283, 08/09/2019, 2628241, Page603 of 883 Date; 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 7 Time: 8 :4 7:53 Incident Report Program; (33/133011. Case No. . . :?1--05-000368 (Continued) Last Name I I I A I 12 Case Number . 1-05?000368 Prompt valid in: Street Number City . . PALM BEACH, FL 000033480 Birth Date/Age ?18 Employer? Occupation . . Oper Lic No. . Home Phone No, 561/00040000 Race . . . . . White Sex . . . . . Female Height . . . . 0 Weight . . . . 0 Misc. . . Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . a ADULT Residency Type - Residency File Charges Can Identify . Victim Sobriety: Injury Extent Injury Type 1 Injury Type 2 Hospital ID Med Treatment First Name: Last Name I I I A I - Case Number . 1-05-000368 Prompt valid in: Street Number City . . PALM BEACH, FL 000033480 Birth Date/Age 16 Employer? . . Occupation . . Oper Lic No. . i Home Phone No. 561/000-0000 Race . . . . . White Female Height . . . . 0 Weight . . . 0 Misc. . . Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . JUVENILE Residency Type Residency File Charges Can Identify . Victim Sobriety: Injury Extent Injury Type 1 Injury Type 2 Hospital ID . Med Treatment First Name: Last Name I I I A I I4 Case Number . 1-05-000368 Prompt valid in:?f Street Number City . . W, FL 000033480 Birth Date/Age 16 Employer? OcCupation . . Oper Lic No. . Home Phone No. 561/000-0000 Race . . . . . White Sex . . . . . Female Height . . 0 Weight . . . 0 Misc. . . Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . JUVENILE Residency Type - Residency File Charges Can Identify . Victim Sobriety: A Injury Extent Injury Type 1 GIUFFRE005620 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page604 of 883 #71 Date: 7/25/06 Time: 8:47:53 Case No. Injury Type 2 Med Treatment Last Name Case Number Street Number City . . . . Birth Date/Age Occupation Home Phone No. Sex . Weight . . . Be On Look Out?: Victim Type . Residency'Sts. Can Identify Injury Extent Injury Type 2 Med Treatment Last Name Case Number Street Number City . . Birth Date/Age Occupation Home Phone No. Sex . Weight Be On Look Out?: Victim Type . Residency Can Identify Injury Extent Injury Type 2 Med Treatment Last Name 1-05-000368 Case Number . Street Number City . . Birth Date/Age Occupation Home Phone No. Sex . Weight 0 a 1 Be On Look Out?: Victim Type . Residency . ADULT Page: 8 Program: CMEBOIL PALM BEACH POLICE DEPARTMENT Incident Report (Continued) 2 Hospital ID . First Name: I N-F A I 0 Prompt valid in: PALM BEACH, FL 000033480 19 Employer? Oper Lic No. 561/000-0000 Race . . . White Female Height . . . . 0 0 Misc. . . Other Phone Nbr: Residency Type File Charges Victim Sobriety: Injury Type 1 . Hospital ID . First Name: ii 561/000-0000 I A I - Prompt valid in: I I 1-05-000368 PALM BEACH, FL 000033480 17 Employer? Oper Lic No. Race . White Female Height . . . . 0 0 Misc. -. .-: Other Phone Nbr: 561/000- 0000 .Residency Type File Charges ViCtim Sobriety: Injury Type 1 Hospital ID First Name: 561/000-0000 JUVENILE .Prompt valid in: I I 17 i PALM BEACH, FL 000033480 16 Employer? . . Oper Lic No. 561/000-0000 Race . . . White Female Height . . . . 0 . 0 Misc . Other Phone Nbr: 561/000- 0000 JUVENILE Residency Type - File Charges GIUFFR5005621 Case 18-2868, Document 283, 08/09/2019, 2628241, Page605 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No. . . . 1?05?000368 Can Identify . Injury Extent Injury Type 2 Med Treatment Last Name Injury Type 1 Hospital ID Case Number 1?05?000368 Street Number Last Name City . . . . WEST PALM BEACH, FL 33411 Birth Date/Age 14 Employer? Occupation . STUDENT Oper Lic No. Home Phone No. Race . . Sex . . . . . female -Height Weight . . . . 0 Person Type other Phone Nbr: Case Number 1-05-000368 Street Number 358 EL BRILLO WY Last Name City .- . FL 000033480 Birth Date/Age W19 Employer? . . Occupation . . Oper Lic No. . Home Phone No. Race . Sex . . . . . Female Height . . . Weight . . . . 0 Person Type Other Phone Nbr: Case Number 1-05-000368 Street Number Last Name ROYAL PALM BEACH, FL 33411 City . . . Birth Date/Age 35 Employer? Occupation Oper Lic No. . Home Phone No. Race . . . . . Sex . . . . . Female Height . . Weight . . . . 0 Person Type . Other Phone 0 Case Number 1-05?000368 Last Name Street Number 37 Employer? City . . Birth Date/Age Oper Lic No. Race Occupation Home Phone No. Height Person Type . Sex . . . Male Weight . . . . 0 Other Phone Nbr: Case Number 1-05-000368 Last Name First Name: I A I A victim SobrietyPage: 9 Program: CMS301L (Continued) White 0 OTHER PERSON 2 MARCINKOVA, NADA White 5 1 0 OTHER PERSON White 0 OTHER "i i ii ii i i White 0 OTHER PERSON i PERSON 5 i GIUFFRE005622 Case 18-2868, Document 283, 08/09/2019, 2628241, Page606 of 883 PALM BEACH POLICE DEPARTMENT Incident Report Page: 10 Program: QMS3OIL Date: 7/25/06 Time: 8:47:53 Case No. . . Street Number City . Birth Date/Age Occupation Home Phone No. Sex Weight . . Other Phone Nbr: Case Number Employer Name Address . City/State/Zip Phone Number Case Number Street NUmber City . . Birth Date/Age Occupation Home Phone No. Sex . Weight Other Phone Nbr.- Case Number Address . City/State/Zip Phone Number Case Number Street Number City . . Birth Date/Age Occupation Home Phone No. Sex Weight . . Other Phone Nbr: Case Number Street Number City . . Birth Date/Age Occupation Home Phone No. Sex 0 1-05-000368 0/00/0000 0 Employer? FAMILY THERAPIST Oper Lic No. 561/000-0000 Race Female Height 0 Person Type 561/000?0000 1-05-000368 PBC DIVISON OF YOUTH AFFAIRS 4200 AUSTRALIAN AV WEST PALM BEACH, FL 33407 561/840-4540 0 1-05-000368 Last Name WELLINGTON, FL 33414 16 Employer? STUDENT Oper Lic No. Race . Male Height . 0 Person Type 1?05-000368 Employer Name 4900 SUMMIT BV WEST PALM BEACH, FL 33415 1-05-000368 Last Name 0/00/0000 0 Employer? Oper Lic No. Race Male Height 0 Person Type 1-05-000368 Last Name Emp oyer? Oper Lic No. Race Female Height I A I I A I (Continued) - White 0 . OTHER PERSON 6 White 0 OTHER PERSON SUMMIT CHRISTIAN SCHOOL 7 White 0 OTHER PERSON GIUFFRE005623 Case 18-2868, Document 283, 08/09/2019, 2628241, Page607 of 883 Date: 7/25/06 PAIM BEACH POLICE DEPARTMENT Page: 11 Time: 8:47:53 Incident Report Program: CMS301L Case No. 1-05-000368 (Continued) Weight . . . . 0 Person Type . OTHER PERSON Other Phone Nbr: I A Case Number . 1?05-000368 Last Name . . Street Number City . . . . . Birth Date/Age :l 16 Employer? . . - Occupation . . . Lie No. . Home Phone No. 561/000?0000 Race . . ite Weight 0 Person Type . OTHER PERSON Other Phone Nbr: 561/000-0000 A A I 1 Original Report LO Reported By: PAGAN, MICHELE D. 9/20/05 Entered By.: OREGERO, LAURA D. 9/20/05 On 03/14/2005, I received a call from not wish to identify herself (later identified as . She stated that her fourteen year old step daughter (later identified as possibly ma have been molested in Palm Beach by a wealthy man. According toh, she learned of the possible molestation by a third party. one explained that she had received a call from the mother of her stepdaughter's friend. The mother claimed to have overheard a conversation between her daughter and a male friend; they were talking about . The conversation was about how had met with a 45- ear?old man and had sex with him and was paid or it. I advised hthat I would like to meet with her to obtain a more detailed statement and facts. l?stated she did not know what to do and had to discuss the matter with her husband. At this point- id not provide me with a call back number or any other information. She statedthat she would contact me once she had spoken with her husband and -s mother. On 03/14/2005 received a call from Mr. Mrsr. They stated it was all right to daughter via cell phone - Her mother had been made aware of the case. They agreed to meet me at the police department later this date. came to the Palm Beach Police Department where they advised me that they believed their fourteen year old daughter may have had some type of sexual relationship with an older male who resided in Palm Beach. Neither knew the suspect'sname or address. Both stated that their daughter did not talk to them about the incident, nor would she admit to it. On 0361412005, Mr. ?accompanied by his wife - ?dentified his daughter as DOB resides with her biolo ical her at H. -is a twin, GIUFFRE005624 . . Case 18-2868, Document 283, 08/09/2019, 2628241, Page608 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 12 Time: 8:47:53 Incident Report rogram: CMS301L Case No. . . . 1-05?000368 (Continued) Both and - are her sister _resides with Mr. school, 1cn is an currently attending involuntary admitte fac1lity ?stays at the faciliti during the week and comes home on the weeken . ccording to she was admitted to the school because of disciplinary problems that recently escalated. The facility also coordinates with the families to provide one on one as well as family counseling. According to Mrs. she believes the incident occurred on 'vFeh? 2005 A friend of named Haley picked her up at their ouse and left. They believe Haley initiated the relationship with the older gentleman, though they do not have any proof. Haley lives close by with her mother. further explained that _was du to .Haley by a boy mating (goes to? plays baseball). Mrs. continued that on Sunday, Haley picked up - and drove to Palm Beach where they met the man. Supposedlymoney and often has young girls come over to his house. Haley offers these girls a way to make fast cash. The man starts with a If he likes them, he keeps them around and does more. The ave any information on Haley other than she lives 0 the last house on right side (north side). talked of a conversation that she had with the mother of a former friend of 5. She found it strange that th were no 10 ger friends until she received the call from her mother tellin her of the conversation she overheard between _and a boy named . Mrs. told me of an incident that occurred on 005. got into a fight at school . - Assistant Principal,- found over. $300. 00 1 purse. gave different explanations for the large Stun of money. Initially the school administration thought it was drug related but then dismissed the claim. Since that day,- _did not return to school, she ran away Thursday, 02/10th or Friday 02/11 and returned to her mother's house later that night after midni ht It was call from?, Wat she learne was the girl that got into the fight with The fight was instigated when _accused-of being a prostitute. who has legal joint custody of his daughtervm s1gne the affidavit of prosecution indicating he to prosecu against the inappropriate sexual behavior with his fourteen-year-old daughter. _stat he had no objections with our agency speaking his daughter about the incident. Mr. stated that 5 mother is aware o?gations and also was willing to cooperate. According to Mrs. she does not believe her daughter had any additional contact with the suspect as she was with Mr. GIUFFRE005625 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page609 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 13 Time: 8:47:53 Incident Report Program: CMS301L 105 000368 (Continued) Case No. . . . - - her mother and then placed into? rovided me the information I contacted the School Board Police who West Palm Beach, Florida. Checking the school board records for and there was no . disciplinary record found. I was advised it no disciplinary action i was taken for a fight, such as an expulsion or detention, the incident may not have been recorded. This was at the discretion of the individual school security and principal. 03/15/2005, I called the Palm Beach County Sheriff's Office and left a message for PBSP Chris Keen, Child Abuse Unit. On m/k 05 went to white femalek Also present was therapist. During an audiotaped interv' oke with about the allegations that were made. initially enied anything had happened, only admitting to going with Haley (later identified as Haley Robson) to Palm Beach to pick up money Robson was owed. 'dentified Haley RobsOn as the cousin of her former boyfriend She ultimately admitted to knowing that Robson worked for a wealthy man and possibly did sexual favors for him. She also admitted that Robson had offered her an opportunity to make money. ?identified Robson's boss as a white male named "Jeff'! who . - alm Beach {later positively identified as Jeffrey EpStein) . xplained that she was first a roached by Robson to go with ff's house, when they were at house. According to she was not su what was going on with Robson but agreed to go with her. boyfriend) gry when he heard Robson inviting to accompany believed it was to pick up money the man owed Robson. state Robson told her that she would pick her up at her house on Sunday. wa of the exact dates but knew it was a Sunday. According to? Robson along with an unkn His anic female, i picked her up at her father's house Ohml bold her father that they were going shopping. It was later confirmed by 1 hat Robson picked his daughter up. According to Mr. 'Robsoxr drove av pick up truck- Robson drove ?along with the unknown female to Palm Beach. the way there, a conversation occurred between Robson and Hereby Robson told _hat- if Jeff asked her age, she should Say she was eighteen. . guard/security room In fact recalled a male approaching them asking what they wanted 0 son ated they were there to see Jeff. The male allowed them to continue walking up to the house- Recalled that Jeff's house was .on a dead..end street. All ree gir walked up a drivewail iast what appeared to be a small GIUFFRE005626 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page610 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 14 Time: 8:47:53 . Incident Report Program: CMS301L Case No. 1?05-000368 (Continued) stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly after, Epstein and ?women: entered Men . ?b"?liev?d the woman Was, Epstein added ?that the woman did not seem friendly and ke? as responses short and direct. Epstein introduced himself to Jeff . ot the im ression that Epstein and Robson's friend knew each ot er. Epstein as beinglapproximately fortyefive years bushy_eyebrows, with graying hair Robson and Epstein left the kitchen leaving _and Robson's friend alone in the kitchen. They-returned a short time hey all spoke briefly in the kitchen. While 5 eaking to me, a became upset and started to cry. stated the woman inst cted her to follow her upstairs, which she did. According to the woman led her to a room that had a massage table in it. The woman started to fix up the room, uttin the covers on the table and taking lotions out. She then told ?that Epstein would be up in a second. left the room, and soon after stein walked in and told to take 0 er lothes. As ?as telling me -and with a pointed finger, ed was stern said ghe did not ook off her what had happened, she looked away from me, repeatedly pressed it into her thigh. when he told her to take off her clothes. anW what to do as she was the only one there. shirt leaving her bra in, dressed in a_ owe er to take 0 eve ing. tated she removed her pants leaving her thong panties on. Epstein then instructed her to?give him a massage pOLnting use. Epstein laid on the table, face down. As 0 give Epstein the massage, he told her to get k. stated she straddled herself 03 were touching Epstein 8 Bare buttoc iv1ng Epstein the massage, He turned around, and wacked of later explained that wacking off was masturbating). ated she was d' Epstein's actions but did not say anything. According tom stein told her that she "had a really hot body." Epstein excuse himself and went to the Bathroom where sne asturbated again. Epstein returned to the room and told What he was done and gave her three hundred dollars. They went back down stairs where the met Robson. Epstein said good-bye and the left. Robson how. did it go and asked what did she Had. asked old Robson that Eistein asked for a massage, 0 son on'Epstein's back. When stated know." stated they then went shopping. stated Robson also got paid, but that she did not know why since she was confident that Robson did not do anything. described Epstein's house as a two story pink house with a Ca 1 ac Escalade parked in the drivewa . There were gates leading into the property. From the kitchen, ecalled walking up a flight of stairs, lined with photographs, to a room. Upon entering GIUFFRE005627 Case 18-2868, Document 283, 08/09/2019, 2628241, Page611 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page; -15 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . 1-05-000368 Continued) the room there was a large bathroom to the right. _recalled a hot pink and reen sofa in the room. There was a door on each side of the sofa. hrecalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. Estated Epstein did not Chan in front of her but did take 0 1s owel, exposing himself. hrecalled Epstein being hairy especially on his che in also had a hairline that conti to his buttocks. admitted to seeing his penis. I aske if she knew what being circumcised meant and she stated no then said that she thought Epstein was on steroids because he was a ?really built guy and his wee wee was very tiny would explain that when she stated "wee wee" she meant penis. stated Epstein exposed himself when he took his towel off, placing it on the floor as he laid down on the table. said Epstein was specific massage, telling her to go clockwise, etc. recalled that Epstein got up from the table and went to the bathroom where she heard him making, what she believed to be sexual type of noises. (moaning) He then returned to the room where he a ain laid down on the table. Epstein then turned over and instructedg?to massage his boobs. As she did this, Epstein continued to?make moaning noises. resumed massaging his chest area. _as now standing on the ground. Epstein turned to his side, and with the towe ground started to rub his penis in an up and down motion. stated Epstein held on to the Mr back as she massaged his chest, back and shoulder area. recalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. _also recalled Epstein having a noticeable freckle on his chest. Epstein then left the room and _got dressed. She went back? downstairs where she met Haley and the unknown white female. admitted to getting paid three W1 lars in cash from - . Before they left, Epstein asked to leave her phone number. As they were leaving the how asked _what had happened and how much she was paid. stated Haley seemed upset or jealous when she told her tha received three hundred dollars. Haley stated received only two hundred dollars that day. stated that she believed Haley was paid two hundred dollars for bringing her. that if they do this every Saturday, they could be rich agreed. They then went shopp' she is not sure where. Possibly at TJ Maxx or Marshall's. stated she never saw Robson again as she got into a fight at school. She had not spoken with Robson either as her mother took away her cell phone. Robson told I asked _if she was aware of any video equipment while she was in the room. She stated no. GIUFFRE005628 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page612 of 883 Date: 7 /?25 6 PALM BEACH POLICE DEPARTMENT Page: 15 Time: 8: 47: 53 Incident Report Program: CMS3 01L Case NO. . . . 1-05-000368 (Continued) stated she was afraid that Robson would retaliate against her or her family if she ever went to the police regarding the incident. stated that her father's vehicle was recently vandalized. admitted to tellin what had happened with Epstein. According to became angry t, punchin a hole in the wall. guessed that it was ho told about the inCi ent, an now there were rumors in school about and what she did with Epstein. I then talked to about? lying. We talked about the color sweater she was wearing. denied having sexual intercourse with Epstein. She denied touching his penis. again admitted to observing Epstein masturbate. . Eagreed to cooperating with the police department in placin a one ca 1 to Robson in a controlled setting and advised her of the families? as well as wile willingness to cooperate with this investigation. Copies of this interview were placed into evidence. advised her briefly or my investigation. She was aware of the incident and stated that she overheard a portion of that her daughter was having with a boy named that it was her opinion that both girls liked recalled hearing her daughter calling a ore. I admitted that she did not listen to the entire conversation but did confront her daughter about it later. _told her mother that somethin to the effect that _had slept with an older man for money. state would not object to me speaking with her daughter. It was belief that everyone in the school have Wt this because of the fight that her daughter and had gotten into. I reminded _that this was an ongoing investigation and requested she not discuss the fact that I had contacted her. She agreed. ion stated On 03/16/2005, PBSO Sgt. Chris Keen left a message that he was returning my call. I spoke with Keen and discussed the case with him and inquired if he had any open allegations or cases where the suspect resided in Palm Beach. Keen stated he was unaware of any. Keen offered any assistance if needed. Keen stated it was his experience that due to the age of the parties involved, it would be difficult to interview them and expect the investigation to remain confidential. Because of the time delay, there was no need for the victim to be taken to a medical facility for a physical for the purpose of obtaining evidence. There was also no need to take her to CPT as she was already in a juvenile facility, with an assigned therapist, in which coordinating a day and time to obtain a statement could be made. On 03/17/2005, I queried Jeffery Epstein on the internet and obtained GIUFFRE005629 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page613 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 17 Time: 8:47:53 Incident Report Program: CMSBOIL Case No. . . . 1?05?000368 (Continued) a 'hoto of Epstein to be used in a photo line up. I met with hat which time she viewed the photo line up. She i iately recognized Epstein and pointed to him (Position . ?asigned the photo line up under Epstein's picture. This ?signed line up was placed into evidence. - On 03/18/2005, I met with _at her r?or the purpose of placing a controlled call to Haley Robson. spoke with Robson and asked if she could arrange another meeting W1 . eff. Robson stated that she would have to call him and make the arrangements. A copy of this conversation was placed into evidence. 03/19/2005, I oke with and and was advised that left the state to Visit er aunt and uncle. is so uled to return to Florida on 03/27/2005 03/21/2005, I coordinated with PE BSF Unit and OCVAN to initiate surveillance on 358 El Brill-o. 03/21/2005, Coordinated with Det.- Lee reiardini trash pulls from 358 El Brillo. On this same date I called to schedule an appointment to speak with . She stated the school guidance counselor was reluctant to ave police presence at the schoOl. I assured her that I would respond to the school in civilian clothes and 2 an unmarked vehicle. 1 _called me back and advised that I did not need to make an appointment to see a return phone call from _stating mwould be attending the family therapy sessions with . 3 I received messages from I conducted a computer query on Epstein. The results of this query indicated the most recent driver's license on file for Epstein was for the state of Florida, which had expired. A cross reference of Epstein residence, 358 El Brillo, Palm Beach, revealed the following affiliated names: Nada Marcinkova, w/f, dob i Mark L. stein, w/m dob Ghislaine N. Maxwell, uk/f, dob h. A computer query for both returned no history. On 03/23/2005, I spoke with _eu phone wk - I requested that she not discuss the incident with anyone including her daughter as I. did not want th vestigation compromised. I was told at is time that _and have not been getting along due to the fact that _has decided to continue living with her father. On 29 2005, I placed telephone calls to both the ?and residences requesting to Speak with them regar ing he GIUFFRE00563O CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page614 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page. 13 Time: 8:47:53 Incident Report Program- (3453011, Case No. . . . 1-05?000368 Continued) investi ation I received return phone calls from Mrs. Mrs. and advised them that I would be contacting family therapist to coordinate a time to meet with .This was at the request of both -and Mrs. ?that strict classroom and therapy schedule be disrupted as little as ossi e. I lalso dated them to the investigation thus far. Both and ?stated the had no objection to my meeting with In eakin with she identified the cell hone number of eing phone assigned to Ms. had no aobjections and provided consent to giv1ng it to the police de artment for the use of placing controlled phone calls from stated the phone had been taken away from -as part of her- unishment for not doing well in school. According to j, -used to be an excellent student, but in the past two mon as become irritable, verbally abusive to the family and has run away. tated her dau cent behavior is the opposite normally is. stated they are going through family therapy sessions with the school but none of this had come up Arrangements were made for Det. Captain Gudger to retrieve the cell phone from at her place of employment. I called and requested to speak with Ms. Upon speaking with Ms. she advised, me that she was in the middle of therapy sessions and would Call me back once the sessions were completed. Ms. -stated the sessions should be concluded by 7:00 PM. At approximately I had called Ms. at which time I left a message on her voice mail requesting a return phone call. I spoke with Ms. and advised her that I did not meet with her daughter and tha wou again attempt to coordinate a time with the counselor so as not to disrupt. school 5 had no objections .?rtly after speaking with Ms? 1 a call from Ms. I explained the situation requested a time to meet with _reviewed-s schedule and advised that -would be available after I met with M?snd Fat I reminded of er conversa ion with Robson. During this time ?initiated a' conversation with me in which she admitted that she was not telling me everything that ed during the time she was alone with Epstein. According tom while she and Epstein were alone ?on the secon pstein used a purple vibrator to massage her vaginal area. C?stated there was 11 ion as the vibrator was on top 0 er underwear. I if Epstein ever asked her age and she stated he had. state she told him she was eighteen. When Epstein asked what school she was in, ?responded she was in the grade at Wellington. During the course of this incident, stated Epstein told her that Haley had worked for him for years. We then continued with the controlled call to Robson. At approximately 3- from her cell phone, made a call to Robson 5 home, I . Robson was not home. -was told GIUFFRE005631 CONFIDENTIAL Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page615 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 19 8:47:53 Incident Report Program: CMEBOIL No. . . . 1-05-000368 (Continued) that Haley rking a double and could be reached on her cell phone, Haley Robson is employed at The Olive Garden Restaurant, located on Forest Hills in Wellington. bson. During the conversation between Haley Robson and Robson aske what happened, stating that she had heard rumors that was going to press charges. Robson asked if they, meaning 5, knew about Jeffery. Robson claimed father had found out about told Robson that parents) did not 5 Jeffrey. know anything about Epstein. Robson told] that Epstein needed someone to work tomorrow and asked if she le. Robson stated she would call Epstein and then call back. During the course of these conversations with? she would at times appear to be articulate and well spoken. She would then start to act in an immature manner looking around, not paying. attention, drawing on a paper. would offer me?a high five whenever she claimed to have told me the truth in the details of the afternoon at Epstein's house. ?would sit in the chair, with her knees prOpped up to her chest as admitted that she did not . tell me the all the details of her encounter with Epstein-during our ?ting. As a means of positive reinforcement I would high five On 03/31/2005, Sproen -Mobile Wireless i and Cingular Wireless, (Robson and phone numbers) were drafted. . On 04/01/2005, I met with members of PB BSF Unit for the purpose of 3 conducting surveillance on 358 El Brillo. Cross?reference supplement. On 04/01/2005, I met with Det. Krauel of the Palm Beach Police Department who provided me a copy of the concealed weapons permit for Mr. Epstein. ~It revealed Epstein had a valid permit. There was no current photo attached to the renewal notice. On this same date I queried various different web sites for a possible identification of the purple item retrieved from the trash pull from 358 El Brillo. The item was similar in description as the one described by and used by Epstein. I made contact with Spicygear.com and spoke with the owner John. I emailed a photograph of the item for his opinion. He identified the items as a Jelly.Anal Wand of some sort. The item is easily available at sex shops in South Florida. 04/06/2005, I conducted business queries into Epstein utilizing the internet. I located articles relating to financial reports. There was no local history. On 04/01/2005 04/03/2005, with the assistance of BSF, there was GIUFFRE005632 Case 18-2868, Document 283, 08/09/2019, 2628241, Page616 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 20 Time: 8:47:53 Incident Report Program: CNB301L Case No. . . . 1?05-000368 (Continued) continued surveillance on the property. On 04/04/2005, I obtained a co of il messages, dated 03/31 and 04/01 from Haley Robson to A female identifying herself as Haley states that she cou pic up to take her to Epstein's house for an eleven o?clock appointment. A copy of this was placed into evidence. On 04/05/2005, a trash pull was conducted at 358 El Brillo by Det. Lee and me. There were several messages written on various forms of papers. There was a message from Haley, indicating 1:00. The following was additional information obtained from etrieved from 358 El Brillo: Jean Luc - - Dav' llen Friday 5 :3 0PM Haley; a message receipt dated 4 4 1:05- She is looking to speak to you On 04/06/2005, I a requests to SA Mighdolls office for I in Robson and hone records. iPhone numbers 8: . 0n 04/06/2005, I called ext and spoke with Princi a He confirmed that they had a student by the name of He requested a written request prior to releasing any additional information. On this same da I faxed a requ student and parent information on ?vised that due to this being an open investigation he was not to discuss the matter with anyone. On 04/08/2005, I receiv following information: Parents name Det. Lee provided me with trash obtained from 358 El Brillo for 04/06 04 07 05. The following information was retrieved: Jet Aviation hitinerary, indicating a departure date of 04/05/2005 at 4:00 PM with an arrival in New York City of Flight crew captain David Rodgers, co-captain, Larry Visoski, flight engineer Larr Morrison. Call Sign a note stating Bye J. thank you hand written notes messages 11-Glenn 12:30 chicken, 3 September J, Big Screen x8, work Sunda after school?- left message or -works 4?9 Monday and Tuesday, leaves here tomorrow 10:30 Am; Mrs. There was no trash for 04/08/05. 04i22i05 received the results of a subpoena request from Bellsouth for 'The results only provided subscriber information. I contacted Alice Grant Investigative Subpoena Compliance Center who stated the request was not complete and the results would be sent to GIUFFRE005633 . Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Pag0617 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page- 21 8:47:53 Incident Report Program: CFEBOIL NO. . . . 1-05~000368 (Continued) me as soon as the query was finished. . Cross-referencing the names Hand ?as well as phone numbers, which were obt rom message notes via trash pulls, I identified the before menti ned individuals as being one at 358 El Brillo. 1-986 0mm ac DL d? bot ove egal age of consent. on 05/03/2005, I -s oke with and updated her on the investigation. ta a was doing well in the school. Her contaCE With the outside is limited as they do not have access to the phones. comes home on the.weekends and she is not allowed to go anywhere a one. 00 05/11/2005, I made arrangements to meet with-e00- On Thursday, 05/12/05, I spoke withMregarding the case. They will be moving to GA in July 2 . ey w1 be very busy over the next few weeks but would be available via phone. Will coordinate a date to meet to discuss the matter further. During this week I conducted surveillance at Epstein residence and at the airport, but there was nothing to indicate that Epstein was in town. Due to conflicting appointments, rescheduled until 06/02/2005, to meet with Ms. I also spoke with?and updated her to the investigation. On 06/02/2005, I met withm and Fadvised that she could be reachedm ell is able to provide me with her new contact information. I also received a message from?1 Attempted call back but the line was busy. June 14, 2005, I received information that Epstein's plane was at . Jet Aviation. I spoke with Det. Lee regarding surveillance. I called the Olive Garden and asked for Haley Robson. I was advised she was not working today. This would indicate that Robson was still employed there. I faxed sub oena requests to SA Mighdolls office for (Phone numbers . The original billing information. On 07/20/2005, conducted a trash pull arranged by Ofc. Lee. Inside there were misc. papers with phone numbers and names. There were On 07/07/2005, GIUFFRE005634 Case 18-2868, Document 283, 08/09/2019, 2628241, Page618 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 22 Time: 8:47:53 Incident Report Program:1ans301L Case No. . . 1-05-000368 (Continued) misc. female hygiene products in the trash. Based on a prior Auto Track report done on 358 El Brillo, a possible subject residing at the residence is Nada Marcinkova. Marcinkova fit the description provided by officers who had conducted surveillance in the area of a female seen entering and leaving the residence. On 07/21/05, I received the Duces Tecum dated 07/18/05, which was clerked by ASO On 07/26/2005, I received the results of Bell South Subpoena. On 08/04/05, I received DHL Express from mobile with the results of the query. I spoke with @who confirmed that Ewes still living out of state. hat all was going we . I left a message for?at? On 08/08/2005, I received the results of Cingular cell phone subpoena. During the week of 09/08/2005, I checked 358 El Brillo and the Palm Beach International Airport but there was no direct indication that Epstein was in town. On 09/08/2005, I reviewed the case notes of this file, as the case will be turned over to Det. Recarey. On 09/11/2005, while on patrol, I conducted a check at Epstein's residence and found that it still had the hurricane shutters on. On a drive by the Palm Beach International Airport later that afternoon, I did not observe Epstein's plane. On 09/14/2005, I conducted a check at the Palm Beach International Airport but did not see Epstein 3 plane. On 09/19/2005, I spoke with?to keep her updated and to find out if there was any change of address or hone I was told no. I left a message for at in order to provide her with Detective xecarey 8 information. A A I 2 NA Reported By: RECARBY, JOSEPH 9/21/05 Entered By.: ALTOMARO, NICKIE A. 9/21/05 On September 19, 2005, I met with Officer Pagan and received the information pertaining to this case. Members of the Burglary-Strike Force had previously been conducting surveillance on both Epstein and Robson. Officer Munyan was assigned to monitor the Epstein home and Sorge and Officer Minot were assigned to monitor RobsOn. Both teams provided a Surveillance log that will be placed into the GIUFFRE005635 . . 'Date: Time: Case NA NA Case 18-2868, Document 283, 08/09/2019, 2628241, Page619 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 23 8:47:53 Incident Report . Program: CMB301L No. . . . 1-05-000368 . (Continued) attachment file. Det. Dawson was assigned to relieve Officer Munyan at 4:00 pm; he informed me that at approximately 8:00 pm, Epstein had left for the airport and his private jet was sitting on the tarmac. Epstein's. private vehicle drove to the jet and unloaded packages into the jet. It appeared that Epstein left the county at this time. Surveillance will continue to determine when Epstein will return. Inv Continues. A A I 3 Reported By: PARKINSON, GREGORY A. 9/23/05 Entered By.: ALTOMARO, NICKIE A. 9/23/05 On Friday, September 23, 2005 at approximately 1:45 I began to copy a tape micro cassette, under case number 05?368 and property number 05-243, tape number 1. I placed the tape in the telex copy?et, series 2 machine and began to go through the copying process. Approximately 1/2 through the tape, the tape wrapped around the spindle and became locked and stretched the tape. I examined it and determined that it was in the best interest to leave it as it is as a prior copy had been made and turned over to Sergeant Frick. immediately took the tape to Sergeant Frick and allowed him to examine it and then obtained the copy from him and Detective Recarey and brought the copy of the tape down and made a copy for him based on that. The tape was placed back in the original container and is retained in the evidence bag under the previously mentioned property number of 05-243. It is not advisable to attempt to c0py this tape as further damage could result to the recorded material and there is an existing copy anyway. A A I 4 Reported By: PARKINSON, GREGORY A. 9/26/05 Entered By.: ALTOMARO, NICKIE A. 9/26/05 at 11:00 pm, a copy of tape 2 (case number 05-294) had been made for Det. Pagan by Evidence Specialist Annette Badger. 'The copy was turned over to Detective Recarey. On Friday, 09?23-05 at approimately 2:15 pm, I was in the process of reproducing audio tapes (micro and standard) to standard size when it was discovered, in the test review process, that tape number 2 was blank. I notified Sgt. Prick and Det. Recarey. I was informed that they had a prior copy and I could use it to make a master tape. I did so and when reviewing and signing the evidence sheet, I noticed Evidence Specialist Badger had written is blank." I obtained that copy frOm Det. Recarey and made a new copy on a standard size tape. The new cepy was placed in the evidence bag under GIUFFRE005636 - .. . Case 18-2868, Document 283, 08/09/2019, 2628241, Page620 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 24 Time: 8:47:53 Incident Report Progrann Case No. . 1-05-000368 (Continued) property number 05-294 with the blank tapeReported By: RECAREY, JOSEPH 9/26/05 Entered By.: ALTOMARO, NICKIE A. 9/28/05 Copies of the tapes that were submitted into evidence were requested. Additionally, trash pulls were started on September 21, 2005. Sgt. Szarszewski made telephone contact with Tony Higgins, Supervisor of the Sanitation Department, and requested that trash be'collected at the Epstein House located at 358 E1 Brillo in Palm Beach. Szarszewski met with Sanitation worker, Jeff Williams and observed him enter the property at 358 E1 Brillo. Shortly thereafter, Williams exited the property and placed the three white trash bags in the empty well in the rear of the truck. Williams then drove away where he met with Sgt. Szarszewski who removed the bags from the well and placed them into one large black trash bag. The bag was returned to the Police Station where I,was waiting for him. Upon his arrival, we inspected the bags where several notes and papers were found. These notes cont ined names ?15 with times. Additionally, there was a note from and to Jeffrey stein on a note ad, which stated, "For a good time callFand .n Also, there was another telephone er on the note lso found was a written note, which stated, can not come at 7 p.m. tomorrow because of soccer. These items were written on notepads that contain Jeffrey Epstein on the bottom of the notes. These items were. placed into evidence for future follow up. I requested subpoenas for subscribe tio?e telephone numbers listed?u the and The cellular telephones and are both ass gned to Cingular Cellular Service. Other notes were found within the trash on Jeffrey Epstein ad paper contained telephone numbers. One note had with written on it. This cellular number is assi ned to Cingular_Cellu1ar Service. Another sheet had written _gwhich is assigned to Bell South Telecommunications. The subpoenas were picked up and submitted to Cingular and Bell South Telecommunication for subscriber information. On September 22, 2005, I was informed by Sgt. Szarszewski that there would be no trash pick up as it was recycle pick up day. A request for copies of the micro and standard size cassettes were requested" from crime scene to familiarize myself with the interviews conducted. On September 23, 2005, the tapes were received and I began to become familiar with the interviews that were conducted. Det. Krauel had met with Town of Palm Beach Sanitation worker, Jeff Williams and observed him enter the property of 358 El Brillo. Shortly thereafter, Williams exited the property and placed the three white trash bags in the empty well in the rear of the truck. Williams then drove away where he met with Det. Krauel who removed the bags from the well and placed them into one large black trash bag. The bag was returned to the Police Station where I was waiting for him. Upon his arrival, we inspected GIUFFRE005637 Date: Time Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page621 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 25 8:47:53 Incident Report Program: CMS301L No. . . . 1- 05? 000368 (Continued) the bags where several notes and papers were found. The notes will be inspected for future use. The items collected were placed into evidence. It became evident that some of the recordings were recorded with background noise and some interference. The calls most affected were the control phone calls from the victim to the suspect Haley Robson. I obtained the graphic equalizer and discovered that the calls are able to be legible with the use of the equalizer by lowering the background noise and increasing voice gain. I also learned that a tape was broken during the coping of the tape. I returned the copy of the tape marked Property Number 05- 243 to have it recopied to have an original in evidence and a working copy with the file. Upon researching the file, it was discovered that the suspect, Haley Robson's cellular calMenaed incorrectly. The suspect tele hone number was and the original request was for i I requested the information through Cingular Cellular A A I NA Service from February 2005 through the present. The purpose was to have a record of Robson making calls to victim, Jeffrey Epstein and the frequency of calls. The request was submitted to the State Attorney's Office. Investigation 6 Reported By: KRAUEL, CURTIS D. 10/06/05 Entered By.: ALTOMARO, NICKIE A. 10/06/05 On or about September 23,2005 at approximately 0915 hours, I responded to 358 E1 Brillo and met with PB Sanitation worker Jeff Williams. Williams had been previously notified to assist in trash pulls at the residence of Jeffrey Epstein, 358 El Brillo, Palm Beach, Florida. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the' back of an empty sanitation truck. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There Was a total of 4 white in color plastic bags and each contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about September 26, 2005 at approximately 0900 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jessie Jones. Jones had been previously notified to assist in trash pulls at the residence of Jeffrey Epstein, 358 El Brillo, Palm Beach, Florida. I observed Jones enter the driveway of 358 El Brillo, where no trash was located within the receptacles. I left the area without incident GIUFFRE005638 . .-.-. Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page622 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page. 26 8: 47: 53 Incident Report Program: CMS301L No. . . . 1-05?000368~ (Continued) and notified Det. Recarey to that affect. On or about September 27, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PE Sanitation worker Jesse Jones. I observed Jones enter the driveway of 358 El Brillo and remove one plastic bag of trash and place it in the back of an empty sanitation truck. . I then followed Jones to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Polic.e Department where I began sifting through its contents. There was a total of 1 white in color plastic bag which contained correspondence for 358 El Brillo. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Monday October 3,2005 at approximately 0915 hours, I responded to 358 E1 Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the back of an empty sanitation truck. I then followed Williams to a predetermined locatiOn and seized the trash from the truck. The trash was transported to the Palm -Beach Police Department where I began sifting through its contents. There was a total of 7 white in celor plastic bags with a red tie and 1 black in color bag which contained 2 white in color plastic bags with a red tie. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. Inside of one of the white in color bags, I located a broken piece of a hard plastic or clear acrylic stick, which was shaped with small ridges. This device is commonly used as a sexual toy which is inserted into the vagina or anus for stimulation. 'This item,-along with all documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Tuesday October 4, 2005 at approximately 0928 hours, I responded to 358 El Brillo and met with PE Sanitation worker Jeff Williams. I observed Williams enter the driveway of 358.El Brillo and remove several plastic bags of trash and place the contents into the side well of the sanitation truck. This side of the truck is separate from the rear of the truck and does not come into contact with other trash. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach _Police Department where I began sifting through its contents. There was a total of 2 white in color plastic bags which were tied at the top. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. Recarey for follow? up. On or about Wednesday October 5, 2005 at approximately 0928 hours, I GIUFFRE005639 .. - Date: Case 18-2868, Document 283, 08/09/2019, 2628241, Page623 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 27 Time: 8:47:53 Incident Report Program: Case NA No. . . l- 05- 000368 (Continued) responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the bed of the sanitation truck. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents, with the assistance of Det. Recarey. There were a total of 2 bags, one of which was white in color and tied in a knot at the top, and the other was a black in color bag, which contained two white in color trash bags along with loose debris. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. Recarey for follow- -up A A I 7 Reported By: RECAREY, JOSEPH 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/07/05 I met with Det. Krauel and requested further assistance to maintain trash collections at Epstein's residence at 358 E1 Brillo Road. On October 3, 2005, at approximately 10:30 am, I was contacted by Sgt. Frick to respond to the? Palm Beach Police Station. Det. Krauel had observed Jeff Epstein riding his bicycle on South County Road. Upon my arrival, I met wit 0 advised, as Epstein was currently in Town; we interview as to her involvement with Epstein and the girls that are roug to is house. As we were to interview the county, (outside of our jurisdiction), I contacted the ~ate torney Office Investigation Division, and made Contact with Assistant Supervisor Investigator Carlos Ortiz. I requested assistance to interview as the interview may occur in the county. Supervisor Ortiz assigned Investi ator Mike Waites to assist us at the location and interview of i Det. Dicks had responded to the address of -and viewed her vehicle arked in the drivewa . _s vehicle a red Plymouth Neon Wwas parked in the driveway reSponded to 120th Ave and aWaited the arrival of Investigator Mike Waites. Upon his arrival, he was briefed that should she wish to be interviewed Within her home he would be needed. However, should -gree to return to the police station for further questioning, he would not be need . Prick and I knocked on the door and met with elavas told that we were investigat' laim involving Jeffrey Epstein of El Brillo in Palm Beach. was asked if she wanted to accompany us back to the police station for further.questioning. She was also told that at the conclusion of the interview she would be returned home. She agreed and wished to change her clothes prior to accompanying us back to the police station. At the conclusion of her changing clothes, she advised she was ready to go. I thanked Inv. Waites and advised she was going to voluntarily return to the police station. GIUFFRE005640 CONHDENHAL ..-.- Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page624 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 28 8:47:53 Incident Report Program: No. . . . 1?05-000368 (Continued) Upon _s entry in the unmarked Detective vehicle, I placed a tape recorder within the vehicle to record any conversations within the vehicle. During the ride back to the police station, dvised she is attending Palm Beach Community College at the Pa Beach Gardens Campus and is majoring in journalism. Upon our arrival at the police station, _was brou he interview room in the Detective Bureau. I explained to that I appreciated her willingness to assist us and informed her that should she desire to leave at any time she may do so. I further lained the interview room door is only closed for prthated she understood. During the taped swo 'ew, asked how she came in contact with Epstein. ?tated back when she turned 17 years of age she was approache a riend in the Canopy Beach Resort in Rivera Beach. iwas aske wanted to make money. She was told she would have to provide a massage and should make $200. 00. thought about the offer and agreed to meet with Jeffrey. Unknown last name) and _(Unknown last name) I picked her up and she was taken to Epstein's house. Upon her arrival at the house, she was introduced to Epstein in the kitchen of the house. She was also.introduced to a white female known to her as Sara. She was led upstairs to the main bedroom known to her as Jeff .Epstein 5 bedroom. Sara arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. Sara then left the room and informed her Jeff would be in a minute. Jeff entered the bedroom wearing only a tow lay on the table onto his stomach massage oil for?to rub on him. During the massageWstated, He tried to touc me and I stopped him. I asked how he tried to touch her. He grabbed her buttocks and she felt uncomfortable. _lso a i Epstein has a vibrator, which is large and white in color. i told Epstein, I'll massage you but I don't want to be touch u. stated she performed .tmage naked. At the conclusion of the massage, Epstein paid $200.00 for the massage. He explained, I know you re not comfortable, but I'll u. if you bring some girls. He told her the younger the better. stated she once tried to bring a 23? ear old female and Epstein stated that the female was too %was asked how many girls she brou ht in total to Epstein. s1x that she can remember. tated she brou and the Victim in 13115 case. I asked ?-dhich one was the youngest. _advised the victim was the youngest. stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and some touching. asked her if the victim 5 was aware. She stated every girl she brought knew what to expect. She explained she knew the victim wanted to make money. She approached the victim and explained about going to work for Jeff. The GIUFFRE005641 Case 18-2868, Document 283, 08/09/2019, 2628241, Page625 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 29 Time: 8:47:53 Incident Report Program: Case No. . . . 1~05-000368 (Continued) victim agreed and arrangements were In de to bring the vic Epstein's house on a tated that she and? (later identified as picked up the victim at the victim 3 house. They traveled to Epstein' House and entered through the kitchen door. They met with the house chef and Epstein assistant Sara. The victim was introduced to Epstein while they were in the kitchen area. Sara led the victim upstairs and Epstein went upstairs. When the massage was over, the victim returned to the kitchen area. tated she was paid $200.00 for bring the victim to Epstein's. stated the victim told her she was paid $300.00 for the massage. Back in the vehicle, _asked the victim what happened. The victim told her about the massage and then they went shopping. _stated the victim was the last person she brought to Epstein. She further stated that she had changed her cellular number to avoid being contacted by Sara. She continued that when Epstein announces to taut that he is traveling to Palm Beach, Sara would contact 0 arrange girls for stein. Sarah, later ified as Sarah Kellen Date of Birth .had told ?hat Jeff likes to have his fun w1t gir s. -tated that once her parents discovered that she was visiting W, they disapproved of the encounters with him and she stopped. qurther stated that Sara still tries to call the house and leaves messa es. With the assistance of we were 0 8! DOB 987, DOB 1988. Frick entered the room and explained that based on her own statements, she had i licated herself with bringing underage girls to Epstein's house. ?vas aware of what she had stated and wished to assist further in hopes to receive a lesser charge. provided cellular telephone numbers for the girls she ha mentioned previously. Additionally, she ?ovided possible addresses and areas in which they lived. As as being taken home in the vehicle, a tape recorder was placed within the vehicle to record any ations within the vehicle. During the drive back to her home, ade the comment I In like a Heidi Fliess. (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. Frick and I went to atchee, Florida in an a speak with We met with Mrs. ?8 Mother) at the front door. We explained the ongoing investigation and felt that may have additional information as we had information that she had worked for Jeff. Mrs. ?introduced us to her husband and allowed us en he home We sat in the dinning room and met with& 988. As she was under the age of eighteen, Mrs. we would be speaking with her. She expressed, if her (151qu she wanted to assist. As we interviewed she denied having any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff GIUFFRE005642 CONFIDENTIAL .. Case 18-2868, Document 283, 08/09/2019, 2628241, Page626 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 30 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . 1-05-000368 (Continued) House with Haley Robson approximately eight months ago and sat in the kitchen with the house chef but nothing happened. As the parents were present during the interview, we felt that was withholding information from us. She made several COmments as to she has put the entire incident behind her. I left my direct' telephone number and advised should she wish to eak with me again to telephone me. Frick and I thanked Mrs. hfor her time and left the area. She stated she would ask her again after to what happened at Epstein 8 house. I informed her that ad my telephone number and hopefully she Would call. 11 Loxahatchee. We met with additional information as we had information that she had worked for a her daughter. .-was at the Wellington Mall Jeff. We left our phone numbers and asked her to telephone me upon Sit Frick and I then attempted contact with not home. We explained the ongoing investigation and felt the may have her daughter's return. We then left the area. :05 am, Frick had retrieved On October 4. 2005. at She stated she had spoken a voice mail message from with her daughter and ation as to what occurred at Jeff 8 house. I contacted who stated her daughter was in the shower at the moment and would be traveling back to Orlando to attend College. I informed her I would be en route to her home in Det. Dawson and I drove to the _home and met and During a sworn taped statement, stated she was taken to the house by Haley Robson. She was to could make money working f?f. She was told she would have to provide a massage to Jeff. stated upon her arrival to the house she was brought to the kite en area by Robson. They met with the house chef and Haley stayed in the kitchen. She was introduced to Sara, Jeff's assistant and was brought upstairs to the mater bedroom. Sara prepared the room and massage table for a massage. Epstein entered the room and she provided a massage. - stated she kept her clothes on during the massage. She stated sometime during the massage Epstein grabbed her buttocks and pulled her close to him. _said she was wierded out by the inCident involving Jeff. At the conclusion of the massage, she was paid $200.00 for the massage. I asked _if she has any formal training in masSages to which she replied no. I asked her if Robson received any monies for taking her to perform the massaie. _stated Robson also received money for takin e. stated she went with Robson and another girl, to 3 house once. stated she waited in the kitchen with Robson, while _vas taken upstairs by Sara. stated she only did the massage once, as she was wierded out by the wnole experience. At the conclusion of the interview and the ta was stopped, I was informed that Sara had attempted to reachhiia cell phone. A voice mail message on October 4, 2005 at 10:59 am, reVealed a female voice who identified herself as Sara who requested her to call her back reference the GIUFFRE005643 CONFIDENTIAL Date: Time: Case NA Case 18-2868, Document 283, 08/09/2019, 2628241, Page627 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 31 8:47:53 Incident Report Program: QMS301L No. . . . 1-05-000368 (Continued) police questioning. This voice mail mesSage was recorded onto a micro cassette. rovided the incoming telephone number as ntly told about stated she the police investigation because?had calle er to tell her about how she just received a ren a car from Jeff Epstein. had called her to tell her that she was given Silver Nissan Sentra, to utilize to visit family and visit Jeff. aske er was oing on a use that the police would be asking questions. tated then called Jeff and Sara and asked what was going on reference ongoing police investigation. According to- Sara has since then been in to contact her to ask about the police questions. . I instructeiot to contact Sara and do not provide any more information to as she would notify Jeff Epstein and Sara what was transpiring. Investigation A A I 8 Reported By: LEE, 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/07/05 On March 30, 2005, I was asked by Sgt. Daniel Szarszewski to begin conducting surveillance and trash pulls reference Detective Pagan conducting a criminal investigation involving Jeffrey Epstein. I was advised that Epstein was possibly engaging in sexual contact with young females. On March 30, 2005, I made contact with Town of Palm Beach Sanitation Office Supervisor Tony Higgins and requested trash pulls for 358 El Brillo Way to begin on March 31, 2005. On March 31, 2005 at 9:20 I responded to the area of 358 El Brillo Way and met with Town of Palm Beach sanitation employee, Jeffrey Williams. I observed Williams enter the driveway of 358 El Brillo Way, collect the trash bags from Epstein's property and place the contents into an empty sanitation truck. I followed Williams to a nearby area, were he turned over seventeen white plastic trash bags, which were collected from Epstein's property. I took the trash bags to the sanitation department were I sifted through its contents. I collected mail correspondence from Armani Exchan addressed to Nada Marcinkova, Jeffrey E. Epstein notepaper with an important mes addressed to J.E dated 03 29 05 at 8:15 p.m. reference U.S Airways boarding pass copy for passenger, Janusz Banasiak Montgomery County, Maryland Health Department food service ID ?for Janusz . Banasiak and Ghislaine Maxwell notepaper with names and phone numbers. Photocopies of the trash collected were attached with the supplement. Detective Pagan was advised of the contents that were collected for evidentiary value. GIUFFRE005644 . Case 18-2868, Document 283, 08/09/2019, 2628241, Page628 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 32 Time: 8:47:53 Incident Report Program: CMSBOIL Case No. . . . 1-05?000368 (Continued) On March 31, 2005, Sgt. Daniel Szarszewski requested that I set up a surveillance vehicle on-El Brillo Way and conduct video surveillance of the front exterior of Epstein's residence. At I set up a surveillance vehicle equipped with a video monitoring device. The surveillance vehicle was parked on El Brillo Way approximately fifty feet east of Epstein's driveway. The purpose of the video surveillanCe was to gather investigative intelligence by monitoring and recording all vehicle and pedestrian traffic entering and leaving Epstein's property. The video surveillance tapes were changed daily with a new Maxell T-160 VHS tape. Video surveillance was established for Epstein from March 31, 2005 through April 05, 2005. On April 05, 2005, video surveillance was concluded. I reviewed the video tapes and advised Detective Pagan the surveillance videos yielded no evidentiary value. On April 01, 2005 at 9:30 I responded to the area-of 358 E1 Brillo Way to meet with Town of Palm Beach sanitation employee, Jessie Jones. While parked in the area of 358 El Brillo Way waiting to collect Epstein trash, I observed a white female, who I recognized as Nada Marcinkova from her Florida driver's license photograph. I made-no contact with Marcinkova. While parked in the area, I also . observed Epstein 5 GMC Yukon truck leave the property as well as other vehicles arrive and park across the street from the property. The occupants of these vehicles appeared to be housekeepers, maintenance men, and gardeners. At 9:38 I met with Town Of Palm Beach sanitation employee, Jessie Jones. I observed Jones enter the driveway of 358 El Brillo Way and collect the trash from Epstein property. I followed Jessie to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. I collected mail correspondences addressed to Jeffrey Epstein, automotive records and personal documents for Janusz Banasiak and Beata Banasiak as well as Jeffrey EpsWaper with the names and.appointment times for . No last names or other personal information was written on the notepaper. While sifting through Epstein trash, I also collected a three-inch purple finger size object, which had a broken end. The object appeared to be a broke piece from a sexual toy similar to a (Cyclone Vibrator) possibly used for rectal gratification. The sexual object was photographed for Detective Pagan, packaged in a biohazard evidence bag (possible body fluids) and secured as investigative evidence. All items collected from Epstein trash were turned over to Detective Pagan for evidentiary purposes. On April 05, 2005 at 9:18 I met with Town of Palm Beach sanitation employee, Jessie Jones. I observed Jones enter the driveway of 358 El Brillo Way and collect the trash from Epstein preperty. I followed Jessie to a predetermined area at which time I GIUFFRE005645 . . - . . - .. . ..- Case 18-2868, Document 283, 08/09/2019, 2628241, Page629 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 33 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . 1-05-000368 (Continued) collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. I collected mail correspondences addressed to Jeffrey Epstein as well as notepaper (Important Message) with names and 'telephone numbers. The following are items collected from Epstein trash. a er blank piece of white black paper black paper David' The following items were documented for Detective Pagan investigation for evidentiary purposes. MSN Hotmai On_April 06, 08, 11, 12, 13, 15, 2005, at approximately 9:30 a.m, I met with Town of Palm Beach sanitation employees. I observed the employee enter the driveway of 358 El Brillo Way and collect the trash from Epstein?s property. I followed the employee to a predetermined area at which time I collected the trash bags from the sanitation truck. I tran5ported the trash bags to the sanitation department, where I sifted through its contents. All of the documents collected from Epstein's trash during my assistance were turned over to Detective Pagan for evidentiary purposes. On June 14, 2005, Detective Michelle Pagan contacted me and advised that the airplane belonging to Jeffrey Epstein of 358 E1 Brillo Way was parked at the Palm Beach International Airport. Detective Pagan requested that I begin trash pulls for the purpose of gathering evidence and intelligence. I made contact with Town of Palm Beach Sanitation Office Supervisor Tony Higgins and requested trash pulls for 358 El Brillo Way to begin on June 15, 2005. On June 15, 2005, I met with a sanitation employee. I observed the employee enter the driveway of 358 E1 Brillo Way and'collect the trash from Epstein 5 property. I followed the employee to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. The trash yielded negative results and no evidence was collected. No further trash was collected throughout the week due to the fact that Epstein security gates remained closed throughout the week; therefore, the sanitation employees were unable to gain access onto the property for collection of the trash. GIUFFRE005646 Case 18-2868, Document 283, 08/09/2019, 2628241, Page630 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 34 3 Time: 8:47:53 Incident Report Program: CMS301L Case No. 1-05-000368 (Continued) All evidence and intelligence gathered by this officer has been turned over to the detective bureau and no further action has been taken by this officer. End of supplement . A A I 9 NA Reported By: RECAREY, JOSEPH 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/10/05 On October 4, 2005, I made telephone contact with_ who had left several messages on voice mail. Durlng message, she advised she was not cempletely truthful when we met in person but would -like to speak with me to advise what had happened. She further advised she did not- want to speakm of this incident in front of her mother. At a roximatel 15: 48 m, I made telephone contact with During a taped recorded statement, stated the following: Approximately a year ago, when she was Sixteen years of age, Robson took her to Jeff's house twice. The first time she went, Haley Robson drove to the house. They entered through the kitchen area where she was introduced to Sara and Jeff. She was taken upstairs to a bedroom by Sara who set the room up with a massage bed and brought out the oils to use. Jeff then entered the a towel. 'He lay on the table and picked out a a lotion formo rub on him. At one point during the massage, .f he tried to remove er shirt at she became very upset and discontinued the massage. Botthd Jeffrey had a verbal disagreement at which time she left without being paid. She met with i on who was sitting in the kitchen and told . advised she received no money for that day.Wa-lso said that Haley Robson had told her if she was uncomfortable withwhat was going on, to let him know and he' 11 stop. She knew that the more you do the more you are paid Several weeks later,?advised she agreed to be taken a second time by Haley Robson. Once they arrived at the residence, Haley sat in the kitchen and Sara took her upstairs to the master bedroom again. Sara set the room up with a massage bed and brought out the oils to use. Jeff then entered the room wea 1ng a towel. He lay on the table and picked out a lotion for ?to rub on him. At one oint a during the massage, he tried to touch her buttocks. As was wearing tight jeans and had a tight belt on Jeff was unable to touch her buttocks. Jeff then rolled ck during the massage, he attempted to touch her breasts. hen became upset again and told him she didn't want to be touched. iscontinued the massage and was paid $200.00. en went downstairs where Haley Robson was waiting for her. She told Robson she leave. -aid she never ret 8% stated she is aware that her friend, ?was a house and had a problem with Jeff. She provided a telephone number GIUFFRE005647 Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page631 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 35 8. 47: 53 Incident Report Program: CMS301L No. . . . 1-05-000368 (Continued) for_ The interview was concluded and the micro cassettes were turn in as evidence. On Octob researched the incoming telephone numbe a message. The telephone number, was assigned to ATT/Cingular Cellular service. I prepare a poena had left request and faxed the request to the State Attorney Office. Information requested was subscriber information as well as all incoming and outgoing calls for the months of September and October 2005. I later researched nd discovered she resides in Royal Palm Beach. Det. Dawson and I Beach and met with ?at her residence in Royal Palm Beach. ?agreed to eak with us in the kitchen area. During a sworn tape statement,h stated the following: On or about November 2004, she was approached by Haley Robson and asked if she wanted to make money. She -agreed and was told she would provide a massage to wealthy man in Palm Beach. Robson picked her up and drove her to a house in Palm Beach. She was brou ht into the kite house. She further stated that andm went with them. They were brought into the kitchen where she was introduced to Jeff and other females. -stated she was introduced to a helper of Jeff; the female was described as white female (unknown name), with blond hair. She stated that the assistant was familiar with Robson. The assist up the massage table and put out lotions to be used. She tolda?Jeff would available in'a minute. Jeff entered the room wearing on a towel. Jeff lay on the massa table and picked a lotion to rub on his thighs and back. further stated that during the massage Jeff asked her her clothes. She complied and removed her pants and blouse. didn't remember if she had removed her bra but feels that she did. was certain that she stayed in her thong underwear. continued the massage and at one point she straddled him to massage his back, which touched his buttocks with hers. as instructed to return to the ground at which time Jeff turne 0 ve his chest rubbed. it was at this time she is sure he was masturbating. id not want to look at his penis area because- she was rtable. Jeff removed a large white vibrator and turned it on. tated he began rubbing the vibrator over her thong underwear on her vaginal area. Shortly thereafter, Jeff ejaculated and removed himself from the table. He walked over to where the shoWer was and opened the glass door. She waited as he was taking a Shower in her direct view. When I asked how old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, was paid either $350.00 or $400.00. She stated she wasn't sure, 8 it was close to $400.00. At the conclusion of the interview,Mstated she never returned to provide a massage for Jeff. She advised she was ashamed and uncomfortable with the situation. GIUFFRE005648 Case 18-2868, Document 283, 08/09/2019, 2628241, Page632 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 36 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . 1-05-000368 Continued Det. Dawson and I then left the area and responded to High School where Robson and all the above?mentione gir a attended. I met with School Police Officer, Off Williams. I 'ned I was looking for a previo 0 attended? High School. I inquired about I further explained at I was working a case in which most 0 girls I have - interviewed are either witnesses or victims and felt that ay be one as well. Officer Williams researched his previous st ecords and.found She attended the same year and graduated in the sam as 0- er girls. I was provided the last known address of At approximate - and I met with her residence, in Royal Palm Beach. As onl seventeen years of age, I had notified her mother, Mrs. that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I the possibility of her being either a witness or victim: Mrs. dvised she wanted 0 cooperate and consented to the interview. During a sworn taped statement, stated the following: at the age of sixteen, during the mont 0 September 2004 she was approached by Haley Robson for a chance to make money. as friends with the friends of Robson and knew the same people. had been previously told by her what Robson did for Robson called a person known to as Sara and scheduled the appointment. Robson picked_up and drove her to Palm Beach to a street called Brillo Way. luey rove to the end of the street and entered a large drivewa . They entered the kitchen area of the house and met with Jeff. as introduced to Jeff. Robson led ?pstairs to the main bedroom area and set up the room with a massage 1e and set out the oils. Robson dimmed the lights and turned on soft music. Robson exited the room and Jeff entered the room wearing only a towel. Jeff picked oils and instructed her to rub his'legs, under his buttocks, back and chest area. Jeff asked her to get comfortable. dvised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposin elly area. During the massage, Jeff removed his towel. As rubbed his chest area, Jeff attempted to reach down her pants the and a tight belt. dvised Jeff-began to masturbate as she rubbed his chest. oaned as she rubbed his chest. She observed he was continuing to and attempted to reach up her tank top and touch her breasts. ulled back and Jeff stopped. However, he kept masturbating until he climaxed. aned himself with the towel he was previously wearing. I asked if she knew the difference between circumcised and not ised. She explained she knew and advised Jeff was circumcised.- as paid $200.00 for the massage and left the area. She met with Ronson who was waiting in the kitchen area and left the house. - eff. She .as they buttocks area, how? unable to due to the tightness of the jeans _then explained she never provided anot did however, go to the house with Robson and GIUFFRE005649 -.. .. .. -- .. .. . . Case 18-2868, Document 283, 08/09/2019, 2628241, Page633 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 37 Time: 8:47:53 Incident Report Program: CMS3 011.. Case No. . . . 1-05-000368 (Continued) tookanother friend of Robson's. _advised she was present when ent to work for Jeff. She advised she er and sat in the it'c en area wi to wait for_ ?advised that while they waited fora th che prepare unch for them, as it was almost lunchtime. As was finished with the massage, they left the area. I asked if Robson 1d what would be expected of her when she provided a massage. ?stated yes, Robson told her that a massage would be expected pose]. naked and possibly some touching involved. has no formal training in providing massages. Fpoke about a third and last time she went to Jeff's house. Ro son drove another girl, who is - friend, to Jeff's house. _stated she knew that Robson had made money providing girls for Jeff and she wanted to do the them in the kitchen a house and introduced Robson and Sara took upstairs to the main bedroom. advised she doesn know wnat ha ened as _did not spea out what happened in the room. ?received $100 Robson for going with her to Jeff 5 house and recommending? _was unable to remember?s telephone number. The interv1ew was concluded and we left the area. Investigation Continues . . . A R.R A I 10 NA Reported By: RECAREY, JOSEPH 10/09/05 Entered By.: ALTOMARO, NICKIE A. 10/10/05 On October 6, 2005, Det. Dawson and I went to University located in Boca Raton. We met with Dean of Students, Paul Turner. I explained to Mr. Turner that we were investi atin a crime within the Town of Palm Beach and felt that a student, may have 1 information. Turner confirmed that is a student and currently on the soccer team for UniverSi y. he was in computer class at the time of our arrival. Turner sent a security guard to locate in class her to the office. _Mr. Turner allowed us to interview in an empty conference room. At 11:45 am I met wit?and explained to her why we there to interview her. She advised she was aware of the ongoing 'gation. _stated she had previously spoken with ho told her she was interviewed by detectives. During a sworn taped statement, ed she knew that Haley Robson worked for Jeff in Palm Beach. advised she has been there many times for massages. her if she had fo aining in providing massages, ?tated she did not. dvised she was told what was expected of her by providing massages and would have to remove clothing but if she felt ortable just to say so and Jeff would stop pushing the issue. began providing massages and advised she kept her clothes on. She considered Jeff a pervert who kept GIUFFRE00565O CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page634 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 38 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . 1-05-000368 (Continued) pushing to go further and further. Fexplained she would keep telling him she had a boyfriend and at it would not be right to her boyfriend. It wasn until recently-admitted to removing her and staying in her thong underwear to provide a massage. xplained Jeff wanted to be rubbed on his back and recently he began turning over to have her rub'his chest as he mastu He would try to touch her breasts as she rubbed his chest. tated, Jeff would try to get away with more and more on each massage. ally, Robson drove her to the house for the original massage. left Sara her cell phone number and every time Jeff would come into town, Sara would call her for an appointment. Each time she went, Sara would meet her at the kitchen doo She would bring her upstairs and prepare the massage table. advised Jeff would ask her questions about herself. He knew sh soccer player and would be attending University. I asked he knew her real age-stated Jeff didn care. The most recent massage she provided was on October 1, 2005. During the massage she asked Jeff if she could borrow one of his vehicles to visit her family and boyfriend in Orlando. Jeff had told she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as .J?bed her buttocks and caressed the buttocks cheeks. I asks if she was wearing undergarments to which she replied her thong underwear. Once he tried to uch her breasts she would pull away from him an ld stop. was asked if he ever used a vibrator on her. was aware or the vibrator but advised she never-would allow him to use the vibrator on her. She described the vibrator as a large white vibrator with a huge 'head. on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. -dvised she had been doing the massage for approximately two years, which meant she would have started doing massages for Jeff at the age of sixteen. stated she was contacted by Sara on October 3, 2005. Sara had informed her that Jeff had rented her a new Nissan Sentra and she should come by the house up. Sara informed -she would have the car for a month. Itated Jeff knew her car was not working properly and had missed a pointments in the past because of her car being inoperable. xplained the car is currently parked next to field. I asked he ook any one to the house. explained she took a friend of hers who has returned to Orlando to attend college. I asked she ever allowed another female in the room. dvised no one was brought into the room with her. At the conclu51on of the interview, Det. Dawson and I went to the area and located the Silver Nissan Sentra bearing Florida tag The vehicle is registered to Dollar rent a car out of the Palm Beach International Airport. tact was made with the victim's mother, at I explained to her that I was following up on this case an prov1 a complete update on the case. Investigation Continues . GIUFFREOOSG51 CONFIDENTIAL . . Case 18-2868, Document 283, 08/09/2019, 2628241, Page635 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 39 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . 1-05-000368 (Continued) A A I 11 NA Reported By: RECAREY, JOSEPH . 10/21/05 Entered By.: ALTOMARO, NICKIE A. 10/21/05 On October 1 oximately 2:30 pm. I made tele hone contact with? During a taped conversation, ?ns told of an ongoing investigatio 'ch I felt she had information pertaining to Jeffrey Epstein. rHij?'plained she met Ep just sixteen years .of age. She was approached bys? i nd who also had- previously gone to Epstein's ouse or massages. adv' as working at the Wellington Mall when she was approached. toldpher that she would have to provide sage to Epstein and she would-have to perform this massage naked. ?thought about the offer and stated she could make $200.00 for inutes of work. She agreed to perform the massage and wet the appointment for her that same day. -rem was a weekend as she only worked at the mall on the weekends. took her to the house where she was introduced to Sara, Je assistant. Sara took her upstairs to a master bedroom. explained that as she was walking up the stairs she observed several ihotographs of naked women along the walls and tables of the house. further explained that she was brought into the bedroom-where ara prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. Epstein entered the room and introducve. Epstein lay on the table? and told her to get comfortable. ould member if he was naked or if he entered the room .with a towel. tated she provided the massage wearin onl her panties. She continued rubbing his legs, thighs and feet?dvised he turned over onto his back. She continued to rub his legs the oils. Epstein touched her' breasts and began to masturbate. I a if she knew what circumcised and un-circumcised meant. tated circumcised the penis has no foreskin and the hea penis is visible? said Epstein is circumcised. egan to cry on the telephone an stated she had been to his house hundreds of times over a two-year period. ilaimed to have made thousands of dollars during her visits. stated she could not remember how many times exactly she went to Epstein's home but said it was a lot. became more upset, crying hysterically and stated she was paid and instructed to have sex with Epstein's assistant, Nada Marcinkova by. Epstein. Epstein continued to watch them have sex and masturbated himself as they had sex with each other. She further stated that things escalated further and further. Epstein used toys such as vibrators, rubber penises and strap-on penises on Additionally, ?stated he performed oral sex on her numerous times. She claimed he Epstein) put his fingers inside her vagina while he masturbated in an attempt to make her climax. could not continue and wanted some time to regain her composure. I explained to to take her time. After taking several minutes to regain her composure I GIUFFRE005652 CONFIDENTIAL .. . . . . . .. Case 18-2868, Document 283, 08/09/2019, 2628241, Page636 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: . 40 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . 1-05-000368 (Continued) explained that I would travel to meet with her in person as I felt she had additional information to provide with Sgt. Prick and explained theimportance to meet within person. Sgt. Frick agreed and made arraignments for Det. Dawson and I to meet with in Jacksonville Florida . 005, at 4:10 p.m. Det. Dawson and I met with her' man?at in Jacksonville, Florida. ted to have present for support. I explained to her that I did not have a roblem as long as she wantedqpresent during the int tated she wanted her presen . I explained that as as present she was not allowed to cement or ask any questions during'the interview. She was only there to comfort-should the interview upset her. During a sworn taped statement,_exp1ained how everything began. She said she was brought through the kitchen area where she met Sara for time. She was led to the master bedroom, Epstein roomf?explained that as she was walking up the stairs she observe several hotographs of naked women along the walls and tables of the house. ?further explained that she was brought into the bedroom, where Sara prepared the room by setting the massage table and provided the oils for her to rub on Epstein. xplained she remembered the steam room area, which contained two large showers. - Epstein entered the room from the steam room area and introduced 1f. Epstein lay on the table and told her to get comfortable. removed her skirt and kept her shirt on. She could not remember 11: he was naked or if he entered th with a towel. Epstein then instructed her to remove her shirt. oved her shirt and remembered she was not wearing a bra. tated she provided the massage wearing panties. She con inued rubbing his legs, thighs and feet. dvised he turned over onto his back. She continued to rub his legs with the oils. Epstein touched her breasts and began to masturbate. Epstein ejaculate meant the massage was over. At the conclusion of the massage 00.00. They walkWether downstairs where Sara and ere waiting. state_eceived an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town. -explained.that she continued to go to Epstein 8 house and became a regular at the house. She could not provide an exact number but claimed she had been their hundreds of times. She claimed sexual activities did not occur every time she was th There were times she went to dinners and parties with Epstein. xplained that things began to escalate more than the massage. The encounters included bringing in his assistant, Nada Marcinkova. -explained Epstein had purchased her from her family in Yugoslav1a. Epstein bragged he her into the?United States to be his Yugoslavian sex slave?dvised he was naked in the bedroom, she entered and removed her clothing. Marcinkova the room from the steam room area already naked. He instructe to perform oral sex on GIUFFRE005653 CONFIDENTIAL . .. .. . Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page637 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 41 8:47:53 Incident Report Program: CMS301L No 3 6 8 (Continued) Marcinkova efused to perform that act. Epstein offered her 0 for her to perform oral Sex on Marcinkova for greed to perform the oral sex for the additional ained that Epstein would masturbate while he watched em perform sexual acts. an additional Things continued to escalate by purchasing sex toys. -tated she had massagers, vibrators and strap on rubber penises used on her Each time sometmw was introduced additional were produced and offered for 0 allow the acts to happen. mas adamant - that she performs all these acts but there was an understanding Epstein that no vaginal penetration would occur with his penis. explained that Epstein' penis was deformed. -xplained that his penis was oval shaped. She claimed when Epstein' penis was erect, it was thick toward the bottom but was thin and small toward the head portion. She called it egg-shaped. -:ontinued~ that ?Wal encounters with Marcinkova, Epstein and her became a ritual. ould arrive at the house Wk herself upstairs, where Marcinkova and Epstein were wa' ould remove her clothing and join them on the bed. xplained 'nkova and she would begin by kissing and touching each other. explained sex toys were brought into the bed by either Epstein or Marcinkova and they would begin using the toys on each other. Epstein would perform oral sex person depending who was on top during the intercourse. xplanation revealed they were in a missionary position . Fadvised one day, -was unable to state and exact date when 1 incident occurred), she came to the house after Sara had informed her that Epstein had arrived. She arrived at the house and went upstairs to the master bedroom. -dvised she immediately removed her clothin as Nada Marcinkova and Epstein were already naked in the bedroom. lained that Nada Marcinkova and she had a sexual encounter to include kissing, touching and oral sex.-remembered that she climaxed and was removing her self from the massage table. asked for a sheet of paper and drew the massage table in the master?oom and where Epstein, Marcinkova and she were. Epstein turned on to her SW on the massage bed and inserted his penis into ina. stated Epstein began to pump his penis in her vagina. ecame upset over this. She said her head was being held against the bed forcibly, as he continued to pump inside her. She screamed no, and Epstein stopped. She told him that she did not want to have his penis inside of her. Epstein apologized for his actions and subsequently paid her a thousand for that visit. Additionally, shortly thereafter, Epstein gaveoia 2005 Doge Neon, blue in color for her personal use. dvised there were times that she was so sore when she left Epstei?se. -advised she was ripped, torn, in her vagina area. dvised she had d1ff1culty walkin to the car after leaving ouse because she was so sore. iadvised that other GIUFFRE005654 . - . Case 18-2868, Document 283, 08/09/2019, 2628241, Page638 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 42 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . 1- 05- 000368 (Continued) than that one time, when Epstein inserted his penis inside her vagina, there was no other penile intercourse. -provided names of irls that she knew of that have one to Epstein's house. drovided'the name ofiand feels she still ma be oing to the house to massage Epstein. According to His still sucking his dick.? When asked if she had been recently contacted by anyone of the house, vi ed she received an email from Sara, from et, which is her email account. The email was just ow are you doing type of email. There had bee ther l.?left the a. 0, 'Contact from the house. The interview was concluded and area. The tapes and drawing were submitted into evidence. Investigation A A I 12 NA Reported By: RECAREY, JOSEPH 11/01/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 12, 2005, Det. Dawson and I traveled to the Orlando area and made telephone contact with greed to meet with us as we were in the Orlando area. ov1 directions to her apartment. Det. Dawson and I met with who stated, during a aped statement that nothing happened between her and Epstein. appeared nervous during the interview. I assured hat I had spoken with other people who advised differently. stated she only went a couple of times and provided a massage to Epstein. was brought to the stein house in March of 2005. roug workhas no formal training in prov1 1ng massages. tated provided a massage, fully for $200.00. As I sensed hesitancy in her answers, I asked she had been contacted by anyone from the house. stated she was interviewed already by an investigator for Ep3te1n. He met with her on October 8, 2005, at. a Roadhouse in Orlando. He identified himself as Paul an ut the police investigation his telephone number or additional contact rovided no additional 1nrormat10n, as it appeared her responses were almost scripted. We left the area and returned to Palm Beach Police Department. Based on the information acquired during the interviews, a search warrant was prepared for entry at the Epstein home. On October 18, 2005, I met with Judge Laura Johnson who reviewed the warrant request. She found there was sufficient probable cause and signed the warrant request. On October 20, 2005, at approximately 9:36 am, members of the Palm Beach Police Investigations Unit executed the search warrant at 358 El Brillo in Palm Beach. Members of the Investigations Unit included Capt Gudger, Prick, Det. Dicks, Det. Dawson, Det. Melnichok, Det. Sandman, Det. Krauel, the crime scene unit and myself. GIUFFRE005655 Case 18-2868, Document 283, 08/09/2019, 2628241, Page639 of 883 - Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 43 Time: 8:47:53 Incident Report Program: Case No. . . . 1-05-000368 (Continued) As we entered onto the property, we encountered the house manager, Janusz Banasiak who was in the guest portion of the house. The guesthouse section had open doors and no forced ent was made. I made contact with Banasiak, Date of Birth# Fl DL and informed him of the searc warrant for the premises. The members of the Police Department entered the residence and announced we had a search warrant. A safety search was done and members exited the home. I read the search warrant to Banasiak as Parkinson videotaped the search warrant execution. Several interior were 1 cated on the_pr0perty. I spoke with Mark Zeff, of may York. Mr. Zeff stated he is the designer for Mr. Epstein's.homes. He advised he was contacted in March of 2005 to do a complete overhaul on the house. He advised he was on the phone with Mr. Epstein when officers announced the search warrant. Mr. Epstein was then made aware of the search warrant. Mr. Zeff advised, his contact with Epstein is strictly business and he has never witnessed-Epstein with any girls except for his assistants, Sara or Nada. I then interviewed Daniel Estes, of ?in New York. Mr. Estes stated he has worked for Zeff for seven years. He advised he personally worked on the New York and Palm Beach home for Mr. Epstein. He has previously met with Sara and Adrianna, Epstein's assiStants in New York and in Florida. Estes stated they travel with Epstein everywhere he goes. I interviewed Zara Bailey of ?Jew Jersey. Bailey stated she just arrive rom Scot an an as worked with Zeff for only one month. She stated she has never met Epstein and has not seen him. The interview was then concluded. I then spoke with Douglas Schoettle ?ew York City. Schoettle stated he has been Epstein's Arc itect for seven years. He further stated he deals with Epstein's assistants and speaks with Epstein on the phone. Schoettle stated he mainly speaks with Sara Kellen, Epstein main assistant, who travels with Epstein. Schoettle stated he only has contact.with Epstein when his services are needed. At approximately 10:30 am, I was informed that the videotaping was concluded. I entered the residence and located two covert (hidden) cameras. The first camera was a covert wall clock in the garage area. I traced the wire behind the clock and removed the RCA wire and unplugged the camera. The other covert camera was located within a desk clock beside Epstein's desk. I traced the wire behind the clock and unplugged the RCA wire. I could not locate another camera. I then began with the search of the residence for the specified' evidence. My search consisted of the second floor. Det. Krauel and I began in the master bedroom area where several items were located. They were GIUFFRE005656 -. .- . . . .. .. .. Date: Time Case No. . . . 1-05-000368 (Continued) Case 18-2868, Document 283, 08/09/2019, 2628241, Page640 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 44 8:47:53 Incident Report Program: marked to be retrieved by the evidence custodian. In the master desk with Epstein's notepad stein we located a.hi transcript from igh School for Also in the roo was the dresser /armoire where oca a bottle of peach flavored Joy Jelly (Sexual Lubricant). Additionally, there were several photographs of young naked teenage girls within the closet, whiCh was consistent with what the witnesses said. The -massage table was also located within-the master bedroom. Video tapes were located beside the television, which were also collected. An itemized list of the property and locations was prepared on the 'property receipts. At approximately 2:55_pm, the house was secured;' the exit of the residence was videotaped. Upon our exit of the property, I encountered Atty. Guy Fronstein who advised he was representing Mr. Epstein. He provided a business card and provided his assistance with the investigation. Due to Hurricane Wilma, which struck South Florida causing massive power outages, the courthouse was closed due to the lack of power. I was previously told that the Chief Judge had extended the filing deadlines due to the hurricane and the Courthouse being closed. On October 27, and 28, 2005 the COurthouse was closed and I could not file the search warrant and inventory at the clerk's office. On October 31, 2005, I responded to the courthouse and filed the paperwork along with an order to seal, signed by Judge Johnson, to deny any release of any paperwork on this case. INV CONTINUES . . A I 13 NA Reported By: GREGORY A. 10/20/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 3 On October 20, 2005, at approximately 8:30 Thursday morning, I was advised by Captain Gudger that a search warrant would be executed and that I was to assemble the Crime Scene Investigative Team and stand by the south side of the building ready to go. I designated Evidence Specialist Annette Badger to handle the inventory return, the documentation of the property receipts and the collection and bagging of the evidence at the scene. I further instructed CSI Kim Pavlik, ID 8807, to accompany us and perform the role of photographing the 5 scene and the items that may be taken into custody by the affiant, Detective Joseph Recarey, ID 7915. My responsibility was to go through from the reading of the warrant to the final exit from the residence and perform a video recording of the reading of the warrant, the initial walk through of the residence showing the current condition and then finally a walk through of the . residence at the time of the police exit. We started out towards the residence, which was located at 358 El . Brillo and arrived at approximately 9:33 a.m. The search was conducted, items were collected by Evidence Specialists Badger, . GIUFFRE005657 Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page641 of 883 7/25/06 PALM BEACH POLICE.DEPARTMENT Page: -45 8:47:53 Incident Report Program: CMS301L No. . . . 1-05?000368 (Continued) photographed by CSI Pavlik and then videotaped by myself. .The search was concluded at approximately 3:05 p.m. whereupon Detective Recarey and I were the last two officers in the house. Upon securing the residence we met with the gentleman who identified himself to Detective Recarey as the lawyer for the defendant and he was informed that the residence was secured and that copies of the inventory return had been left on the first floor table of the personal assistant's office. Detective Recarey and I returned to Police Headquarters and secured for the day. A A I 14 NA Reported By: DAWSON, MICHAEL c. 11/07/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 20, 2005, I assisted Defective Recarey in the execution of a search warrant at 358 El Brillo Way, Palm Beach, Florida, 33480. Upon the announcement of the search warrant, immediate contact_was made with three white males who came out of the house or surrounding structures. Those males were identified as Janusz Banasiak, Daniel Estes, and Mark Zeff. As other members of the police department cleared the home, I kept watch over these three males. Once the house was cleared, those males were turned over to Detective Recarey. Detective Dicks and I were assigned to assist in the search of the main house, the cabana and the servant's quarters. We started in the garage. All areas of the garage were searched to include four vehicles. These vehicles were three black Mercedes Benz cars registered to Jeffrey Epstein. The fourth vehicle was a Harley Davidson green in color, registered to Jeffrey Epstein. Nothing was recovered from the garage. A towel closet and pantry located off the kitchen were searched and yielded negative results. The kitchen was searched and taken into evidence was a phone message book that was located near a house phone. North of the kitchen was an office room which contained a computer. The room had a closet that contained a locked gun locker. The combination was entered by Banasiak-in the presence of Sgt. Frick and the safe was opened. Items were-taken from the room. See the completed property receipt for a detailed list. A green bathroom located on the first floor was searched and nothing was taken . A closet located just west of the green bathroom was searched. Two massage tables were located in the closet along with a photo of a nude GIUFFRE005658 .. . .. .. . .. Case 18-2868, Document 283, 08/09/2019, 2628241, Page642 of 883 Date: 7/25/06 PALM BEACH EOLICE DEPARTMENT Page: 46 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . 1-05?000368 (Continued) female from the waist up. See the property receipt for details. I searched two bedrooms and their adjoining bathrooms, which were located on the second floor on the East side of the house. In the Northeast bedroom closet I found adult sex toys called Twin Torpedoes. Soap made in the shape of a penis and vagina were also found in these upstair bedrooms. See the property receipt for details. I searched the pool cabana located on the South side of the pool. Photos were taken from the wall. See the property receipt for details. I assisted in the search of Banasiak's living quarters. Numerous CD along with a message book was seized. See the property receipt for details. A A I 15' NA Reported By: RECAREY, JOSEPH 11/08/05 Entered By.: ALTOMARO, NICKIE A. 11/08/05 On November 1, 2005, I was contacted by Atty. Gus Fronstin, who advised he was willing to assist with the investigation. Atty. Fronstin advised he would try to have his client, Jeffrey Epstein available to be interviewed. I explained I would be interested in conducting an interview with his client as well as other employees that are employed within the house. Atty. Fronstin advised he would return my call once he received confirmation on the interviews. On_ November 6, 2005, I attempted contact with ?at her residence. I left a business card for her to re urn my ca . Upon retu he lice department, I had received a tale hone call from I returned her call ath spoke with She made arrangements to resp tion to provide an interview. At approximately-3:30 pm, she arrived at the Palm Beach Police Station with her boyfriend. Her boyfriend was allowed to sit in the lobby area while Ms. -was interviewed. I took Ms .0 the Detective Bureau Interview room. I closed the door for privacy and explained to her that I appreciated her coming to the police station for the interview. During the sworn taped statement, she advised she was at Jeffrey Epstein 3 house 0 A roximately two months ago, she_was approached by a girl, who was dating her roommate, to make some quick money. aQV1sed she was in need to make some quick cash to make the rent that She agreed to go to the house. She had been told by ?that the massage would have to be done in her underwear. 8 advised qrove with her and brought her into the house. The walked into kitchen area and took the stairs upstairs. further stated she was brought into a master bedroom area. advised she recalled seeing portraits of naked women throughout the room. A.massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room wearing only a towel and GIUFFREOOSGSQ CONHDENHAL Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page643 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 47 8:47:53 Incident Report Program: No. . . . 1-05-000368 (Continued introduced himself as Jeff. _advised-she recalled she and? removed their clothing down to their panties, Epstein lay on his stoma nd they provided a massage on his legs and feet area. I asked 'f she had any formal massage training and she replied no. advised she was tople the panties she wore were the boy shorts lace panties. She ands?continued the massage until the last ten minutes of the massage, Epstein, told-to leave the room so that-could finish the massage. 1 ct dressed and Epstein turned over onto his back. Epstein then i removed the towel, which had been around his waist. Epstein laid 3 there naked and requested that-rub his chest area. stated Wd this, Epstein, began masturbating as she rubbed his chest. tated he pulled down her boy short panties and he produced a large white vibrator with a large head. She stated it was within a drawer in his master bathroom. He rubbed the vibrator on her vagina area. dvised he never penetrated her vagina with the vibrator. He continue er vagina with the vibrator as he continued to masturbate. tated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to 5 remove himself from the table. He wiped himself with the towel he had on previousl and went into the shower area?0t dressed and i met with 'n the kitchen area. stein came into the kitchen provided 200.00 for brin in and paid $200.00 to for provi 1ng massage. #as told to leave her tel hone number with Sarah, his assistant or future Contact. ?grovided her cellular telephone number for future contact. was asked if she was recently contacted about this investigation by anyone from the Epstein organization. She replied she was called but it was for work. She stated she was called by Sarah for her to return to work for Epstein. _stat 's the term used by Sarah to provide the massage in underwearfWadvised she declined, as she was not comfortable in providing that type of work. The interview was concluded and the videotape was placed into evidence. Investigation Continues. . A A I 15 ?veled to her home in Royal Palm During a sworn taped statement, Reported By: RECAREY, JOSEPH 11/10/05 Entered By.: ALTOMARO, NICKIE A. 11/10/05 On November 7, 2005, I made telephone contact with ?ho advised she would be able to meet with me at her home. Det.? Sandman ade Contact with 1 . stated she met Jeffrey Epstein through Haley Robson. Rob on would approach females who wished to work for him. stated she was asked to work for him but declined. explained that work means give massages. She was asked omal training in providing massages to which she said no. said she accompanied Robson and other females GIUFFRE005660 Case 18-2868, Document 283, 08/09/2019, 2628241, Page644 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 48 Time: 8:47:53 Incident Report Program: CMS301L Case No. . 1-05?000368 or 5 times in who were taken to Epstein 8 house to provide massages. further stated she had been to the house ap roximatel the ast ear. She accompanied Robson with the 14-year?old victim, and Each time the girls were taken over, they were prev1ous ey would have to provide a massage, possibly naked. It was also told that should Epstein require them to do anything extra were not comfortable just to tell him and he would stop. ?stated Robson received $200.00 for each_girl she brought? massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, the victim, as she sta fifteen years old at the most; she looked really young. Wurther stated each time she went to the house, she sat in the kitchen and waited with Robson until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house, The interview was concluded and the tape was turned into evidence. Investigation Continues.. A A I 17 NA Reported By: RECAREY, JOSEPH 11/10/05 Entered By.: ALTOMARO, NICKIE A. 11/10/05 Det. Dawson and I attempted contact with in R0 al Palm Beach. I left my business card at her front door. Ms returned my call and arranged a meeting with me at the Pa Beac Police Department for November 8, 2005. At approximately 2:00pm, arrived at the Palm Beach Police Department. She was brought into the interview room and the door was closed for privacy. She was told that I appreciated her coming to the police station for questioning regarding an on going investigation. She was told that I was investigating a crime involving Jeffrey Epstein and knew, based on the investigation, that she had rs with him in the past. During a sworn taped statement,?stated she had met Epstein approximately two years ago. She was irst introduced to Epstein by Haley Robson. Robson approached her about working for Epstein and providing a massage to him for $200.00. The arrangements were made and as Robson coul a? day the arrangements were made, teem lso attended _igh School and was familiar with Epstein. recalled she was brought there and entered through the back kitchen door. She had met with an assistant Sarah and another assistant Adrianna. Sarah brought her upstairs as she observed several photographs of naked females throughout the house. stated stein came in the room, wearing only a towel, and laid on the table. htated he picked out the oils he wanted he requeste (e remove her clothing to provide the massage. stated that on the first massage she provided she did not remove her GIUFFRE005661 .. .. Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page645 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 49 8 :4 7:53 Incident Report Program: CM83 0 1L No. . . . 1-05-000368 (Continued) clothing. _tated she had returned several es after that- Each time returned more things happened. ?stated that the same thing would happen. Epstein would walk into the master bedroom/bathroom area wearin onl a towel. He would masturbate as she provided a massage. Htated she was unsure if he climaxed as he masturbated under the towel. Additionally she never looked blow his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion, Epstein would use a massager/vibrator, which she described as white in color with a larg her. Every time she provided a massage he would masturb added she has no formal training in providing a massage. st brought two females during 'ts stated she brought a girl named High School. 8 received $200.00 for eac gir brought. Additionally, was given $200.00 for taking her in the very beginning. The interview was concluded and the tape was placed into evidence. Investigation continuesReported By: RECAREY, JOSEPH 11/13/05 Entered By.: ALTOMARO, NICKIE A. 11/14/05 mber 8, 2005, I made tele hone contact with" 987, at her residence. hresponded to po ice station for an interview reference an ongoing investigation. At approximately 2: 30 pm, she arrived at the Palm Beach Police Station and was brought into the interview room for the interview. The door was closed for privacy and she was told that I apprec' er cooperation in this case. During a sworn taped statement, stated she had met Jeffrey Epstein approximatel year a 0. She was approached by a subject known to her as? dad asked her if she wanted to make money prov' Epstein. _had heard that several girls from High School were doin thi making money. She agreed and was taken to the house had introduced her to Sarah and Epstein and brought her upstairs to a master bedroom and Master bathroom where a massage table was prepared and the proper oils wer out. _left the room and waited downstairs for- tated Epstein entered the room wearing a ?nd she provided a massage wearing only her thong panties. vised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed; once that occurred the massage was over. She felt the whole situation was weird but she aw she was paid $200.00 for providing the massage. She also stated received $200.00 for bring to Epstein. ?tated she had gone a total of 15 times to his residence to prune a massage and things had escalated from just providing a GIUFFRE005662 Case 18-2868, Document 283, 08/09/2019, 2628241, Page646 of 883 Date: 7/25/06 . PALM BEACH POLICE DEPARTMENT Page: 50 Time: 8:47:53 Incident Report Program: CMSBOIL Case No. . . . 1-05-000368 . (Continued) massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breast with his hands as she provided the massage. stated on one occasion, he offered extra monies to have vaginal curse. She stated this all occurred on the massage table. ?tated Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax Epstein removmis from her vagina and climaxed onto the massage table eceived $350.00'for her massa e. I asked her if she had any formal training in providing massageshstated she did not. _:ontinued to state on one other occasion, Epstein introduced his ant, Nada, into the massage. Nada was brought into room with *to provide a massage. Epstein had them kiss and fondle each ot er around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein introduced the large white vibrator/massager during the massage. Epstein stroked the vibrator/massager on vagina as she provided the massage. -tated the last time she spoke with anyone at the was Sarah during the weekend of October 2 or 3, 2005. stated she had brou ht two eo 1e to the stein house. -She prov1c1eu the names of (unknown las ould noted a een previous identified as and had been previously interviewed. The interview was concluded and the videotape was placed into evidence via the locker system. On November 9, 2005, Frick and I traveled to ?n Boynton Beach, Florida in hopes to interview Juan Alessi, the ormer houseman of Epstein's home. As no one was home, a busi eft for him to return my call. We then traveled to in" Miami in hopes to interview Alfredo Rodriguez, a former house man of Epstein. We did not locate them at home. I left a business card for him to return my call. We then traveled to University and met with tudents, Mr. Turner. We requested to speak with as re interviewed, as she still was in ossession of the rental car that Epstein had acquired for her. istated that Sarah, Epstein's assistant, had called her on her cellular telephone and informed her that rental was extended for her. Sarah stated she had paid additional $625.00 for her to keep the rental an extra month.a_ was asked if she had any add' ntact with either Epstein or anyone from his organizationmtated she did not, other than the telephone 11 'nforming her that she could keep the car for an extra month. idid not provide any additional information. On November 10, 2005, at approximately 9:47 am, Alfredo Rodriguez had telephoned reference my business card found on his door. Rodriguez stated he had worked with Epstein for approximately six months after GIUFFRE005663 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page647 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 51 Time: 8:47:53 Incident Report Program: Case No. . . . 1-05-000368 (Continued) the previous houseman left. Rodriguez stated that it was his responsibility to keep the identity of the masseuses private. Mr. Epstein had a-massage in the morning and one in the afternoon. Mr. ROdriguez stated he would rather speak about this in private. He advised he would come to the police station to speak with me. Rodriguez stated he would return my call on Monday, November 14, 2005. I then made telephone contact with Juan Alessi. He advised he found my card on his door and wanted to know what I needed to speak with him about. I explained to Alessi that I was conducting an investigation on his former employer, Mr. Epstein. Alessi stated he would return my call shortly as he was in the middle of a project at his home. received a telephone call from Attorney Donald Morrell from Mr. Morrell stated he represented Mr. Alessi and did not want me speaking with his client. I then made telephone contact with the State Attorney 8 Office and confirmed that subpoenas would be issued to the former employees to assist in the investigation. I then made telephone contact with Attorney Guy Fronstin, attorney for Mr. Epstein. I explained to Mr. Fronstin that I would like to speak with Mr. Epstein. He stated Mr. Epstein is not in residence in Florida at this time and would check with him to ascertain if he could be here by Wednesday November 16, 2005 for an interview. Mr. Fronstin stated he would return my call should Mr. Epstein decide to come in to the police station for an interview. Investigation continues. A A I 19 NA Reported By: RECAREY, JOSEPH 11/15/05 Entered By. ALTOMARO, A. 11/16/05 vember 14, 2005, Det. Sandman and I traveled to ?in Loxahatchee, Florida and spoke with She was told of the ongoing investigation invOlving Epstein. advised she had gone to the house on several occasions. During a sworn taped statement, she advised she star one year a and was brought by . 1% stated+ brought her into the house and she was introduce to a girl name Sarah. Once sh Sarah brought her upstairs into a master bedroom bathroom. #stated she met Jeffrey in the bathroom. He lay on the and picked the massage oils. She provided the massage, as he lay naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. st only been at the house approximately five or times. aid each time she went to the house she was notified by Sarah, Epstein's assistant, that Epstein was in town and would like her to work. _stated she returned to the house and was again led upstairs by Sarah. She provided the massage, clothed. GIUFFRE005664 CONFIDENTIAL Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page648 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 52 8:47:53 Incident Report Program: CMS301L No. . . . 1-05-000368 advised it wasn't really weird until later on. asked if she ever removed her clothing to provide a massage. stated it was not until the third time she went that she removed ner clothing. stated she was notified by Sarah that Epstein wanted her to come to work. She arrived at the house and was led upstairs by Sarah. (She started pr massage when Epstein asked her to remove her clothing. ?removed her pants, shirt and bra. She stayed in her thong continued rubbing_ Epstein. stein turned over onto his back and she rubbed his chest area. stated -was masturbating himself as she providing the massage. stated she believed he climaxed based on his breathing. She ?ew either the climax or the fact that he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. ?stated on the last time she went to provide a massa she was notified by Sarah to come to the house and work. stated she was now dating her current boyfriend and did not reel comrortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearin only a towel as he entered the room to lie on the table. stated Epstein caught her looking at the_clock on several occas1ons. Epstein asked her if she was in a stated her boyfriend was in the car waiting for her. ur er. stated that Epstein got upset, as she wasn't enjoying the massage. -She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. I asked her if she had any contact with Epstein's organization, she stated she received $200.00 from Western Union in Royal Palm Beach and Okeechobee as a Christmas gift. sed she had no formal training in provide any massages. lso stated she was sixteen years old when she first went to ps e1n ouse. At a roximately 4:22 pm, I made telephone contact with at She agreed to meet with me at a public place. SUQgested she come to the police station for an interview. did not want to meet at the police station. I recommended we meet at the Palm Beach Gardens Mall in the food court area. She agreed and an appointment was made for November 15, 2005 at 5:00 pm at the food court. Investigations Continue. A A I 20 NA Reported By: SANDMAN, JENNIFER R. 11/16/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 On 10/20/2005, I assisted executing a search warrant at 358 E1 Brillo Way in the Town of Palm Beach, Palm Beach County Florida under the direction of affiant Detective Joe Recarey. GIUFFRE005665 Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page649 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: '53 8:47:53 Incident Report Program: CMSBOIL No. . . . 1-05?000368 (Continued) Detective Melnichok and I searched the pantry room that is west next to the kitchen. -This roOm had all white cabinets with a dark grey and black counter top. We did not find anything in this room. We searched the yellow and blue room.that is west next to the pantry room. This room had a very large statue of man with a bow. Taken into evidence from this room were nine photographs in frames of various women. We searched the main entrance foyer that is to the north of the yellow and blue room. This room contained two bamboo chairs and ottomans with cushions. It also contained a round table with numerous books. We searched another blue room that is west of the foyer. This room had a stereo system and book shelves that were from the floor to the ceiling. Taken into evidence from this room were eight photographs in frames of various women and/or Epstein, the owner of the residence. We searched the room to the west of the blue room that has sliding glass doors that lead out to the pool. In this room in a dresser were two DVD's and two VCR tapes. These items were taken into evidence. We searched a 2004 black Chevy Suburban bearin Florida tag X99-EGL, registered to Jeffrey Epstein DOB which was located on the east side of the driveway facing sout . I ound a Thrifty rental agreement between the passenger seat and the middle anna Sjoberg from The phone number on the rented was a white The vehicle was rente on 9 25 05 at 17: -58 hours and was returned on 9/26/05 at 16:52 hours. The last four numbers of the credit card used are Detective Melnichok found a piece of paper in the middle console that said I used the cash in here to fill up the tank and was signed by Johanna. I searched the 2005 black Cadillac Escalade ESV bearing Florida tag Q29- -9GT, registered to Jeffrey Epstein dob which was located on the west side of the driveway facing south. I did not find anything in this vehicle. All of the items that were taken into evidence were photOgraphed in the place they were located and then turned over to crime scene. A A I 21 NA Reported By: RECAREY, JOSEPH 11/17/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 Case 18-2868, Document 283, 08/09/2019, 2628241, Page650 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 54 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . 1-05?000368 (Continued) ember 15, 2005, Det. Sandman and ?in Royal Palm Beach. We met with a. seventeen- -year old juvenile who was not 1n scn001 this day due to a cold from which she was suffering. as told that I needed to speak with her in reference to an ongo1ng 1nvestigation involving a subject she would know as Jeffrey Epstein. Prior to speaking with her, I explained that because of the fact that she is a minor, I needed to speak with her speaking with her. She telephoned her father, Mr. on his cell phone and explained to him that Det. Sandman and I were there to speak with her. I spoke with Mr. on the telephone and informed him I needed to his daug ter in reference to an ongoing investigation. Mr.?advised he had no problem with us speaking with his daug ter. During a sworn taped statement, _stated she met Jeffrey Epstein over he was sixteen years of age and was i approached bwaho informed her that she could make monies providing a massage to Epstein for $200.00. med her that she would have to provide this-massage the arrangeM Epste is assistants and took to the house. lMstated?xd she entered through a glass door that led into a kitchen took her upstairs, to almaster bedroom and master bathroom. She recalled the bathroom had a large pink couch, sauna and matchin shower. stein entered into the room wearing only a towel; hand removed their clothing remaining only in thong underwear. She further stated that Epstein lay on his chest on the table. stein selected which oils to use for the massage. Both -and rovided the massage on his legs, back and feet. Forty m1nute into the massage, Epstein turned over onto his back and requeste stairs in the kitchen - ari_. Ep Wto finish age. As got dressed, starting rubbing his chasm left the room, and Epste asturbating himself as rubbed Epstein chest. stated he continued masturbating until he climaxed on the towel he was wearing. When asked if he had . removed the towel she. stated he turned the towel around so that the ,5 opening would allow him to expose After he cleaned himself 3 off with the towel, he instructed? age was done and to get dressed and met with him downstairs. got dressed and met I with Epstein in the kitm She was paid $200.00 do or 3 providing the massage. stated she was aware thatl?also received monies for the same thing. op ess. econd time she went to the house she was again approached by sked if she wanted to return to the house to provide massage, ?agreed and ments were made by for her to return to the house. stated-drove her to the house and knocked on the same glass door that leads to the kitchen area. The were allowed entry into the house by one of the staff members. ?led her upstairs to the master bedroom and GIUFFRE005667 Case 18-2868, Document 283, 08/09/2019, 2628241, Page651 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 55 Time: 8:47:53 Incident Report Program: Case No. . 1-05-000368 (Continued) alone. Epstein entered the room again wearing only a towel. began removing her clothing as she did the last time she was house. Epstein instructed her to get naked. He lay on the table on his stomach as _began massaging his legs and back. As fini shed wi th master bathroom area. _1eft this time to do 3* stein's back and legs, Epstein then turned over onto his back. ed to rub his chest and he began masturbating himself. As rubbed his chest, Epstein leaned over and roduced a massager Vi rator. He turned it on and began vagina and masturbating himself at the same time. stated she continued to rub his chest as this was occurring. She described the vibrator/massager as large, grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vib her vaginal area and concentrated on masturbating himself. mstated he climax towel again and informed her that the massage. was done. ?got dressed and met with who was waitin in the kitchen area. She received $200.00 for massage. aid she nev to the house and had no desire to return to the house. ?was asked if she received any formal ma a training. she a vised she had no formal training. 6 was asked if Epstein. knew her real age. stated he knew as he asked her questions about herself and hi schoo . He was aware she attended and is still attending High School. The interview was concluded. I suggestlinform her parents of what occurred at the Epstein house. tated she would tell her father as he was unaware this had occurred. I left my business card for any questions they may have. We left the area and returned to the police station. The tape was placed into evidence. Investigation Continues. A A I 22 NA Reported By: RECAREY, JOSEPH 11/17/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 On November 15, 2005, Officer Munyan and I res onded to the Palm. Beach Gardens Mall food court 5 to meet with h. At approxi :10 arrived and met with us at the food court. Wprovided a sworn taped statement in which she stated she had been at the Epstein house over fifty times. She going to Epstein'shouse when she turned eighteen years old. asked if she knew of the on-going investigation. State she was aware there was an investigation as she had been tol by other girls that were interviewed. Additionally, she has had several telephone conversations with Epstein's assistants as to what had been going on during the investigation. I asked _how she was introduced to Epstein._stated she did not want to disclose who brought her to the house but she would GIUFFRE005668 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page652 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 56 .Time: 8:47:53 Incident Report Program:-CM8301L Case No. 1-05-000368 (Continued) re5pon other house, (?stated massages. Each time Epstein and he would escalated from there. provided oral sex on massager/vibrator on When I asked her what happened at the everything happened. It all began with the she went more things happened. She would massage masturbate and climax. She stated things She provided oral sex on Epstein and he her. She stated he would also use a' her vagina to stimulate her as she massaged him. questions. He 1 his assistant Nadia or Nada to have vaginal intercourse withW She stated Nada or Nadia would utilize a strap?on penis) to have intercourse with her. She was told to masturbate herself as Epstein_and Nada had sexual intercourse. this was done at Epstein's direction. All could not rovide exact dates as she had been to the house so many times. stated Epstein inserted his fingers in her vagina to stimulate her as she massaged him. When I asked her if there had been any vaginal intercourse with Epstein, she stated she did not have sex with him. She did admit having sex with Nada, his assistant. stated not every time she-went involved sexual favOrs. Sometimes she would just talk with him and get paid. I asked her how much she was paid each time she went to Epstein residence. stated she got paid $300.00 every time she went to the house. She was told to bring other girls to him to provide massages. declined stating that she does what she does and did not want to introduce anyone else to do what she does. tated she had never received any formal training in providing massages. I showed- a photo line up in which Nada Marcinkova was placed in position six. She reviewed the six photographs and immediately identified Nada Marcinkova as the person with whom she had intercourse. Additionally, it was the same person she watched have intercourse with Epstein. She signed the photo line-up under Nada Marcinkova 3 photo as the person she identified. We then left the mall and returned to the police station. The photo line up and tape were placed in to evidence. Investigation 23 11/29/05 12/01/05 A A I NA Reported By: RECAREY, JOSEPH Entered By.: ALTOMARO, .NICKIE A. On November 17, 2005, I received a phone message from Atty. Guy Fronstin who advised to call his cellular phone reference his client Jeffrey Epstein. I telephoned his cell phone and left a message for him to return my call. I did not receive a call back on-Thursday, November 17, 2005. On Friday, November 18 2005, I retrieved another voice mail from my work phone from Mr. Fronstin advising he would not produce his client Jeffrey Epstein for any statement. Fronstin stated he had spoken with ASA Lana Belohlavek and expressed Mr. Epstein has a passion for massages. I called ASA Lana Belohlavek and confirmed that GIUFFREOOSGGQ CONHDENHAL Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page653 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page. 57 8:47:53 Incident Report Program: No. . . . 1-05-000368 (Continued) Fronstin had telephoned her reference this case. Although nothing was discussed, Mr. Fronstin did advise her that Epstein is very passionate about massages. I also spoke with ASA Daliah Weiss reference the previous employees, Juan and Maria Alessi. She advised that they had been served through a subpoena process server. They were both scheduled to appear on Monday November 21, 2005 at 12: 00 p. m. On November 21, 2005, I met with ASA Weiss, Atty. Donnie Murrell and Juan and Maria Alessi at the State Attorney Office. ASA Weiss had requested a court reporter to be present to take the statement of the Alessi s. I spoke with Maria Alessi, in the presence of her attorney, Donnie Murrell. She advised she had worked for Epstein for eight years, from the period of 1994 through 2002. She advised she had never had any direct conversations with him. She stated it was her husband who spoke directly with Epstein. Her work consisted of doing house cleaning,?shopping and other preparations when Epstein would arrive in town. Alessi stated the preparations consisted of preparing the house and bathrooms for his arrival. She advised she did view Several masseuses that arrived at the house. She advised that two or three girls would come during a day and provide the massages. The girls that arrived looked young in age. Mrs. Alessi did not know any of the girls personally and were always different. She was told that when Epstein was in residence he did not want to encounter the Alessis during his stay in Palm Beach. I then spoke with Mr. Alessi in the presence of his attorney, Donnie Murrell. Mr. Alessi stated that he was employed for eleven years with Mr. Epstein. He originally was hired as a part time employee and then moved up into a full time position. His duties included everything. Alessi stated he was the house manager, driver and house maintenance person. ?It was his responsibility to prepare the house for Epstein arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. He remembered dealing with his girlfriend, Ms. Maxwell originally and then dealt with Epstein directly. I asked Mr. Alessi about massages that occurred within the home. Mr. Alessi stated Mr. Epstein had up to three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. -There were times he recalled that he would set up the massage tables either in Epstein 3 bedroom or in his bathroom. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. Alessi was never privy to what went on during the GIUFFRE005670 .. .. -.. . . - 1--.. .. Case 18-2868, Document 283, 08/09/2019, 2628241, Page654 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 53 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . 1-05-000368 (Continued) massages. He was asked if he remembered any names of the girls that massaged Epstein.? He tried to remember and was unable to provide any exact names of any girls. .Alessi was asked about any contact with anyone from the Epstein organization. Alessi said he did speak with Mr. Epstein shortly after my initial contact with him to find out what was going on. Alessi also stated that approximately on November 11, 2005, he was contacted by a private investigator from the Law Office of Roy Black. The investigator had called him to meet with him to ascertain what he was going to tell the police. Alessi stated they met at the Carrabba Restaurant in Boynton Beach and discussed the same questions I was asking him. I informed Mr. Alessi and Mr. Morrell that as this is an ongoing investigation and anything we discuss should be confidential. They both acknowledged the fact that the information would be kept confidential. It should be noted that a court reporter was present during the interviews and would be providing a copy of the statements to me when they become available. On November 21, 2005, I received a voice mail from Mr. Fronstin who advised he would not be making Mr. Epstein available for any statements. He did have some words that he wanted to relay on behalf of Mr. Epstein. I telephoned his office and left a message for him to return my call. On November 29, 2005, I received a call back from Mr. Fronstin who left a voice mail after hours on November 28, 2005, advising he would return my call during normal business hours to speak with me reference the case on November 29,.2005. A A I 24 NA Reported By: RECAREY, JOSEPH 11/29/05 Entered By.: ALTOMARO, NICKIE A. 12/01/05 On November 29, 2005, at approximately 2:30 p.m. I received a telephone call on the department issued cell phone. Mr. Fronstin stated he was calling to relay information that Mr. Epstein wished he could_relay. Mr. Fronstin stated that he would not allow Mr. Epstein to speak with me at this time. He further stated that Mr. Epstein is very passionate about massages. He continued that Mr. Epstein had allegedly donated over $100,000 to the Ballet of Florida for massages. The massages are therapeutic and spiritually sound for him that is why he has had many massages. Mr. Fronstin stated be appreciated the way the investigation has not been leaked out into the media. I explained to Mr. Fronstin that it is as important to protect the innocent if the allegations are not substantiated. Mr. Fronstin was told of the allegations that the private investigators assigned to the case have been portraying themselves as police officers. .Additionally, I explained that my cell phone had been.called by the private investigators. Mr. Fronstin advised he was not aware of that and advised they were under the direction of Attorney Roy Black in GIUFFRE005671 .. .. Case 18-2868, Document 283, 08/09/2019, 2628241, Page655 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 59 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . 2 1-05-000368 (Continued) Miami. Mr. Fronstin further stated Epstein had originally called Mr. Dershorwitz in Boston, who recommended Roy Black in Miami, who asked Mr. Fronstin to assist. I informed him that if and when any charges would be presented I would notify him. The call was then terminated. Investigation continues. A A I 25 NA Reported By: RECAREY, JOSEPH 12/15/05 Entered ALTOMARO, NICKIE A. . 12/16/05 A review of the telephone message books, which were obtained during the search warrant, was conducted in which various messages from different dates were made to Jeffrey Epstein. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the. perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed The body of the messages was time of the day that they called for confirmation of "work. Other names and telephone numbers were located in which the body of the messages were, have girls for him" or have 2 girls for him. These messages were taken by Sarah for Jeffrey Epstein. Based on the context of the body of the messages, I requested subpoenas for subscriber information on the telephone numbers and the time frame involved. Copies of the messages were made for evidentiary purposes. I obtained ?High School yearbooks for 2005, 2004 and 2003. I first reviewed the 2005 yearbook and locam girls I had spoken with. Additionally, I locatedm Based on the corrected name spelling, I was ableD to locate her to her residence in Loxahatchee. On December 8,12005, responded to ?LoxahatcheeJ oca her home. She a Vise 819 13 attending High and is participating in the early release program so she can maintain her part time job. As she is still a minor, I left my business card to have her mother return my call to request an interview with her daughter. We then left the area. I also had previousli researched the telephone number for-and telephone number A subpoena had been issued for the information on The telephone number was re istered to A ery of *evealed is currently residing at Det. Caristo and I attempted er of est Palm Beach. contact with with negative results. I left my busineSs card on her front door re estin she ret call. We then responded to I also attempted contact with with negative results. I left my business card for him to return my call. GIUFFRE005672 Date: Time: Case 18-2868, Document 283, 08/09/2019, 2628241, Page656 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 60 8:47:53 Incident Report Program: NO. . . . 1-05-000368 (Continued) 2005, I received a telephone call from mother, who was made aware of the on going investigation in Palm Beach. ?advised she was told of everything that occurred at Epstein's house involving Epstein and his staff. She advised she would allow me to question her dau hter about what occurred and would cooperate with the investigation. provided me wit cellular telephone number to sche an appointment for an official interview. I telephoned her cellular telephone and made a tentative appointment for Monday, December 12, 2005. I then received a telephone call from father of - who stated he found the business car on is door. I explained that I was conducting an investigation and needed to speak with _as she 'nformation that could assist in the investigation. Mr. tated that his daughter no longer resides with him and has he iler in another trailer park. He advised he would tell her to call me. On December 12, 2005, due to with schedules, arrangements were made to meet with on Tuesday, December 13, 2005 at 5:00 pm. On December awson and I traveled to Loxahatchee and met with During a sworn taped statement, _st-ated an she was sixteen years was taken to Epstein's house to provide a massage stated it was before Christmas last year when her and asked if she needed to make money for she did and agreed to rovide a massage for money. arrangement ke the house and drove to the house to "work." tated she could not remember the Street name but would be able to drive to the street.' They drove to the last house on the street and pulled in the last house on left side. They walked up the driveway and entered through a side gate which led to a kitchen door. Thei knocked on the door and were encountered by an employee who escribed as a "Spanish looking lady." They informed her that ey were expecte were then encountered by a white female with long blond hair. was unable to remember the name of the white female with-blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a Spiral staircase which led to a master bedroom and bathroom. The massage table was already set up'in the bathroom. escribed the bathroom as a large spacious bathroom with a steam room and shower beside it with a sink to the right. -as introduced to Jeff who was on the phone when she ente was wearing a white towel and la on his stomach so thatHay massage his feet and calves. tarted the massage with the massage oil Jeff chose and rubbed his feet and calves. Jeff got off the phone and requested she massage his back as well. ?began rubbing his back and got to the small of his back. During the rubbing of his back Jeff asked her to get comfortable. He GIUFFRE005673 CONFIDENTIAL .. .- .- Date: Time Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page657 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 61 8:47:53 Incident Report Program: CMSBOIL No. . . . 1-05-000368 (Continued) requested she remove her pants and shirt. removed her shirt and pulled her pants off. stayed in her ra and thong panties. As she finished the small back, Jeff then turned onto his back. He instructed she rub his chest and pinch his nipples. As she to rub his chest, Jeff asked her'querf. remembered telling him she attended Hiih School. Jeff asked her if she was sexually active. Before ?swer, he also asked what sexual positions does she enjoy. tated she was shy didn't like talking about those things. She continued rubbin his chest. Epstein reached up and unsnapped her bra from the front. hxplained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed.?said "no, I don't like that.? Epstein oved his towel and lay on the bed naked exposing his penis tow He be an touching his penis and masturbated as he touched her reasts. xplained Jeff then touched her vagina area by rubbin 'na with his fingers on the outside of her thong panties. ensed up and stated Jeff was aware that she was uncomfort 1e. ?stated that Jeff told her "Relax, I'm not going inside." She explained Jeff commented to her how beautiful and sexy she NA was. Jeff then moved panties to one side and now was stroking her clitoris.rmsaid "Jeff commented how hard my clit was. He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina. Jeff removed his fingers from within her vagina and apologized for putting his fingers inside her. Du time he kept his hand on her vagina area rubbing her va stated he rubbed her real hard as he was masturbating. said he climaxed onto the towel he had been previously wearing and got up from the table. Jeff told her there was $200.00 dollars for her on the dresser within the master bathroom. Jeff als er that there was an additional $100.00 that was to be given to?or bringing her there to massage him. Jeff told her to leave her te ephone number with his assistant as he wanted to see her again. Jeff stated his assistant would contact her to work again soon. 's her if she ever received an formal massage training to which stated she did it was the only time she ever went to work for Jeff and kne happened to her was wrong. She stated she no longer speaks to because she was upset that took her there. she further stated that she had never been contacted for any additional work. The interview was terminated and we left the area. Investigation Continues . . . A A I 25 Reported By: DICKS, ALLEN c. 12/18/05 Entered By.: ALTOMARO, NICKIE A. 12/19/05 GIUFFRE005674 Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page658 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 62 8:47:53 . Incident Report Program: CMS301L No. . . . 1?05?000368 (Continued) On 102005 at approx 0930hrs I assisted with the execution of a search warrant at 358 El Brillo Ave, Palm Beach. Initially I was assigned to enter the residence and conduct a sweep of the premises for safety purposes. I then accompanied CSEU tech Pavlik while she photographed the exterior of the house. Once this was complete I was asSigned to search certain areas of the house with Det. Dawson as part of the search warrant. We began in the garage, searching three Mercedes Benz vehicles, a .Harley Davidson and adjacent closets in the garage. Nothing of evidentiary value was located. We then searched two closets off the kitchen area on the east side. These can best be described as pantry or storage closets. Nothing of evidentiary value was obtained. A small office with adjoining bath was then searched. In the bath area I located a phone message book with recent messages. This item was seized-as evidence. Please note this bath and shower area are not used as designed but are storage areas containing a variety of items to include a gun safe in the shower and assorted household items. We then searched a bath area and closet at the base of the main stairs in the foyer. Inside the closet two massage tables were? located as well as partial nude female photographs. These items were later seized as evidence. Nothing of evidentiary value was noted in the bathroom. We then searched two bedrooms upstairs on the east side of the residence. Located in the bath room of the south bedroom was penis shaped soap. Located in the bedroom of the northern bedroom was penis and vagina shaped soap as well as an adult sex toy. These.items were seized as evidence. We then searched the pool cabana located in the south west corner. of the property. Several photographs of nude females were seized as evidence. I was then assigned to stand by with a person I believe.was Douglas Schoettle. Mr. Schoettle was in the residence at the beginning of the search warrant. He was present during the warrant service and subsequent search. I.stood by with him until the search was completed and I departed the residence. I had no conversation with him regarding the reason for our presence. Regarding seized evidence, all items were photographed in place and then collected by CSEU personnel. This concludes my involvement in this case. GIUFFRE005675 .- . a. mu, - . ..- Case 18-2868, Document 283, 08/09/2019, 2628241, Page659 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT - Page; 63 Time: 8:47:53 Incident Report Program: Case No. . . . 1-05-000368 (Continued) A A I 27 NA Reported By: KRAUEL, CURTIS D. 12/21/05 .Entered By.: ALTOMARO, NICKIE A. 12/21/05 On Thursday, October 20, 2005 at approximately 0936 hours, I assisted in the execution of a search warrant located at 358 El Brillo Way, Palm Beach, Florida, residence of Jeffrey Epstein. I was instructed by Case Agent Det. Joseph Recarey, to secure all computer and media related material from the residence. Upon my arrival I was directed by Det. Recarey to a room designated as the Kitchen Staff Office. I observed a, Silver in color, CPU with the left side cover removed, exposing the CPU 5 hardware sitting on floor next to a glass type desk. The CPU had no discernable identifiers or features indicating a make or model. This CPU was powered off with the power cord not plugged in. The keyboard and mouse were atop the CPU. It should be noted that the CPU was not connected to a monitor, printer, or other media device. On the back Panel of the CPU, I observed an card with RCA jacks attached. This type of hardware would allow audio and video to be downloaded onto the CPU 3 hard diski The ends of the RCA jacks were unattached at the time of the search and no external camera was located within this room. The CPU was located on the right side of a desk that held a flat panel LCD screen. The desk also held another keyboard and mouse, indicative of a second computer; however, no other computer was found. It appeared as though a second computer had been recently removed as the cables ends from the monitor, keyboard and mouse were in the same area. A further search of the room revealed no media storage devices, i.e. CD 3, Floppy Disks, Zip Disks, etc. This type of media is commonly stored in an area where Computers are placed, yet no media was found. After completing a search of this room, I secured the CPU.and turned all items oVer to the Evidence Custodian for future forensic analysis via a property receipt. - I was then directed by Det. Recarey to a room designated as the Garden Room, where I observed a wooden desk'facing west. The desk held a flat screen LCD monitor, keyboard, mouse, media card reader and printer; however, no CPU was located. All of the cables were removed from an area where a computer had once been. A search of the desk area revealed no signs of any media devices. Det. Recarey directed me to a third location designated as the Cabana room, which is detached from the residence and located just south of the pool. In the South East corner of the room, I observed an office type setting, with an L?shaped desk holding a flat screen LCD monitor, keyboard, mouse and printer; however, no CPU was located. All of the cables were removed from an area where a computer had once been. A search of the desk area revealed no signs of any media devices. GIUFFRE005676 .. . . . Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page660 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 64 8:47:53 Incident Report . Progranu No. . . . 1-05-000368 (Continued) Det. Recarey directed me to a second detached structure located on the South East corner of the property. This area of this structure was assigned with single letters to identify a particular part of the room. In the office area, designated as Room B, I observed a powered on Dell Dimension 2350, attached to an LCD flat panel monitor. The screen displayed an open Microsoft Internet Explorer browser with URL address of I observed no other active windows in the Start panel window and photographed screen. The power cord was removed from the back of the Dell CPU and I disconnected the cable modem to prevent remote access. At that time, the Dell CPU, marked with Serial Number 6WTVN21, was secured and turned over the evidence custodian for future forensic analysis via property receipt. I also located several media related items within Room B, which were recorded onto a property receipt and turned over the Evidence Custodians. I then responded to a Bedroom designated as Room P, where I observed a white in color CPU marked Premio.? The Premio CPU was in a computer desk which held a white CRT monitor, both of which were powered on. The CRT monitor displayed a message from Norton Antivirus software, warning of an expired subscription. I observed no other active windows in the Start panel window and photographed screen. I removed the power cable from the back of the Premio CPU and shutdown all other 'media. The Premio CPU, marked with Serial Number 2000091078, was secured and turned over the evidence custodian for future forensic analysis via_property receipt. I also located several media related items within Room F, which were recorded onto a property receipt and turned over the Evidence Custodians. This concluded my participation in the search of the residence. A A I 23 NA Reported By: RECAREY, JOSEPH - 12/21/05 Entered By.: ALTOMARO, NICKIE A. 12/21/05 On December 20, 2005, I contacted ASA Daliah Weiss in an attempt to subpoena the Epstein former houseman, Alfredo Rodriguez. Rodriguez, who resides in Miami, had eluded the process servers previously and was not served the investigative subpoena. A telephone message was left as she is not available during the week of 12/19/2005. I made contact with State Attorney Inv Theresa Wyatt and requested the same via telephone message. I then researched the victim's SG cellular telephone subpoena data which had been received from a previous subpoena request. I analyzed the records which depict several calls from Haley Robson. The telephone calls start on February 6, 2005 at 12:49 pm.; the same day which the victim and the victim's father stated the incident occurred at Epstein irst incoming call was from Robson's residence at The second incoming call from Robson's GIUFFRE005677 . . My. gum.-. . . Case 18-2868, Document 283, 08/09/2019, 2628241, Page661 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 65 Time: 8:47:53 Incident Report Program: Case No. . . . 1-05-000368 (Continued) cellular phone occurred at 1:02 pm. The call durations were one minute or less. The time frame was within thirteen minutes apart. It should be noted that Robson residence was in close proximity to the victim's. The next call occurred at 5:50 pm when the victim telephoned Robson residence. Several calls were made after the above mentioned calls both incoming and outgoing to Robson. Further analysis showed no telephone calls to either Robson's cellular telephone or Robson's residence were registered prior to February 6, 2005. Additionall I also conducted an analysis on the telephone calls from The? subscriber information confirmed that the number is registered to Paul A Lavery from Hialeah, Florida. The address was crossed referenced to the Office of Kiraly and Riley Private Investigators. I researched the web page which also showed various cases in which they assisted. I also located another web site under in which Mr. Riley attended a Miami Rotary meeting and confirmed Atty. Roy' Black is among his clientele. The tele hone calls revealed Laver had telephone contact with? Heither just after I attempted to in erView em, or prior. ac ground was conducted on Lavery which revealed he holds a current Private Investigator License. A criminal arrest record revealed he had been previously arrested for possession of cocaine and solicitation of prostitution. I also researched the girls using This web site is a new social networking service that allows members to create unique personal profiles online in order to find and communicate with old and new friends. The site allows one to establish your own myspace.com page and decorate the page any way one wishes. I found the followin eo le have ace sites: 1 I received a Cingular Wireless packet which contained a CD which contained the results of the subpoena request for verbatim calls on An analysis will be conducted in the near future On the phone numbers called. Investigation Continues. A A 29 NA Reported By: RECAREY, JOSEPH 12/27/05 Entered By.: ALTOMARO, NICKIE A. 12/29/05 red in the Search Upon doing research on the message warrant I located the identit of ?as registered to seventeen years old and is attending the Academy. I GIUFFRE005678 CONFIDENTIAL Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page662 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 66 8:47:53 Incident Report Program. No. . . l- 05- 000368 (Continued) responded to 1801 Palm Bea evard, also known as the Palm 11. I located the Foundation. I located inside the foundation an 1n ormed her that I was investigatin a case against Jeffrey Epstein and knew she had been at the house. hstarted to cry and advised she had put that part of her life behind her. I explained that although she is seventeen years old I needed to inform her parents that she would be interviewed. She provided her home telephone number. I attempted contact and left voice mail messages at the house to speak with her parents. Det. Caristo and I then located ?at her residence located at West Palm Beach. I attempted to interview her about Jeffrey Epstein. she advised she is so in love with Jeff Epstein and would do anything for him. She further explained that she would not speak with us about him either negative or positive. She asked us to leave her property. I informed her that although she did not wish to speak with us, I had sufficient information at this point in the investigation to know she was at Epstein' house and provided girls to Epstein to work. I also explained that prior to at her residence I had telephone contact with who was told she would be interviewed. seventeen years old and as a juvenile, paren a no ification would be required. We then left the area and returned to the police station. the police station, I left another telephone message for parents. I began an a ah Kellen' 5 Cellular telephone. The telephone number is assigned to Sarah Kellen and the financially respon51 par 1s Jeffrey Epstein of 457 Madison Ave. in New York City, New York. The time frame which was subpoenaed was September 2005, through October 2005. There were eighty seven pages of calls made either to the cell phone or from the cell phone. The local (561) numbers were analyzed. A spread sheet was prepared and placed into the attachment file of who was called. The unknown numbers were researched using FoneFinder. com and subpoenas were requested to determine subscriber information. This was done to identify additional victims or witnesses. The analysis revealed that Kellen had called the victim/witnesses frequently when Epstein was in the Town of Palm Beach to "work. This confirms what the girls interviewed had previously stated. Kellen would notify them when Epstein was in town and their willingness to "work. The CD was placed into evidence. Investigation Continues. A A I 30 NA Reported By: RECAREY, JOSEPH 1/03/06 Entered By.: ALTOMARO, NICKIE A. 1/03/06 On December 29, 2005, I received a facsimile from National Compliance GIUFFRE005679 .. Case 18-2868, Document 283, 08/09/2019, 2628241, Page663 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 67 Time: 8:47:53 Incident Report - Program: Case No. . . . 1-05-000368 inued) Center from Cingular Wireless for telephone number This was the teleihone number for Haley Robson during the time frame-when the victim, was brought to the Epstein house to "work." An analysis of the phone records, of all incoming and outgoing calls, showed that on February 6, 2005, the day. the victim, - was brought to the house Robson first called Sarah Kellen, Epstein's assistant, at 12:50 pm (EST). The next call was made to Epstein?s house in Palm Beach, at 12:52 pm (EST). The following call was made to the_victim, at 1:01 pm (EST) and at 1:02 pm (EST). This confirms the in ormation provided by the victim and victim's father. I photo copied the records and enlarged the page 8 of 10 to show the calls made by Robson on February 6, 2005. parents. I To this date, I have not heard from- Will attempt to establish contact Wit.? uncut L11 evening hours. I received a package from Atty. Guy Fronstin, which was hand delivered at the police station. Within the package, was a letter from Alan Dershowitz and two profiles. The profiles were that of and MySpace.com is a social networking service that allows members to create unique personal profiles online in order to find and communicate with old and new friends. This package was in response to a previous meeting in which Mr. Dershowitz called to assist in the investigation in providing any additional witnesses such as house employees who have been reluctant to speak with law enforcement. I reviewed the profiles Mr. Dershowitz enclosed. her blog to be 'Hf?ucking-" still atten High School, sen an receives messages from friend some profanity. Upon reviewing her friends' comments section from i Myspace, mest of her good friends sent messages to establish contact and invite her to go out. I then reviewed ?s web blog whic 'ded by Mr. Dershowitz. Ms. her blog to be Her blog states that her interests include music, theater and weed (Marijuana). I reviewed her packet in which declares her love for her live?in__ ?nd. She also describes usn.ng marijuana with her boyfriend - The letter Mr. Dershowitz sent advised he was looking into the allegation that one of the private investigators used by the private attorneys of Epstein, attempted to impersonate or state that they were . police officers from Palm Beach advised that the investigators used to interview had "quite a distinct speech impediment", did not claim to be nor did they impersonate themselves as a police officer. This package was sent to both ASA Lana Belohlavic and ASA Daliah Weiss at the State Attorney's Office. I made telephone contact with ASA Weiss to confirm she received the package and request an interview with Sarah Kellen, Nada Marcinkova, and Janusz Banasiak. She advised she would assist in attempting to GIUFFRE005680 Case 18-2868, Document 283, 08/09/2019, 2628241, Page664 of 883 Date: 7/25/05 PALM BEACH POLICE DEPARTMENT Page: 68 Time: 8:47:53 Incident Report . Program: CMS301L Case No. 1-05-000368 (Continued) contact Mr. Dershowitz. On January 3, 2006, I received a telephone call from ASA Weiss who informed me that she made telephone contact with Mr. Dershowitz. She had requested the employees be available the week of January 3, 2006." Mr. Dershowitz informed her that the assistants are out of the country and would require additional time to locate them and make them available . Investigation Continues. A A I 31 NA Reported By: MINOT, LORI 8. 1/03/06 Entered By.: ALTOMARO, NICKIE A. 1/03/06 On Thursday, 03/31/05, I started conducting surveillance at 358 El Brillo. At this point I observed at 1155 hours, a Tan Altima bearing FL tag _n Roadway, bearing FL tag in drive, Tan Honda Civic bearing FL taga?in Roadway, Blac evy Suburban in driveway and a Black Cadmde in driveway. At 1325 Hours I observed Tan Honda Civic 'n roadway, Black. Chevy Suburban in drivewa Black Caddy Escalade in drive and a White Kia car FL tag? At 1615 hours I observed a Tan Honda Civic, in roadway, Black Chevy Suburban in drive, Black Caddy Escalade in driveway and a White Kia car roadway. On Friday, 04/01/05, I continued surveillance at 358. El Brillo. At 1130 hours I observed a Tan Honda Civic bearing FL tag in roadway, Black Cadd Escalade in driveway and a Tan own make/model bearing FL ta roadway. At 1227 hours, I, observed a Tan Honda Civic oadway, Black Caddy Escalade in driveway and a Black Chevy SUV ocated behind the Escalade. At 1345 hours, I observed a Tan Honda Civic ?n roadway and a Black Che SUV in driveway. At 1558 hours, I observed a Tan Honda Civic ?in roadway, Black Chevy SUV in driveway, Black Caddy Escalade in driveway and a dark unknown model/make car parked in garage. On Saturday, 04/02/05, I continued surveillance at 3?illo. At I 0713 hours, I observed a Red Explorer bearing FL tag in roadway and a Black calade in driveway. At 0814 hou served a Red Explorermroadway, Black Caddy Escalade in driveway and a Tan Honda Civic At 0952 hours, I observed a Red Explorer ?in roadway, Black Caddy Escalade in driveway, Tan Honda Civic in roadway and also a Grey unknown make/model with a B.M in trunk retrieving landscaping tools. At 1155 hours, I observed a Grey Camaro bearing FL tag_ parking in the roadway in front of 358 El 'Brillo. A blond hair, teens to early 20's, thin and tall wearing a white tank'top and short blue jean shorts, exited the vehicle to the rear of the house, also observed a Red Explorer 'n roadway, Tan Honda Civic in roadway and a Black Caddy Escalade in driveway. At 1310' hours, I GIUFFRE005681 CONFIDENTIAL .. . . Case 18-2868, Document 283, 08/09/2019, 2628241, Page665 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 69 Time: 8:47:53 Incident Report Program: Case No. 1-05?000368 (Continued) roadway and a Red Neon bearing FL tag Then observed 3 approximately 16 to 18 years of age jogg ng. All 3 females ran into the driveway. There were 2 with blond hair and one brown hair. observed a Red Explorer driver leme area, Tan subcompact on On Sunday, 04/03/05, I continued surveillance at 358 El Brillo. At 0719 hours I observed a Tan Honda Civic _in roadway and a Black Caddy Escalade. At 0934 hours, I observed a Tan Honda Civic in roadway and a Black Caddy Escalade in driveway. At 1057 hours . observed only the Tan Honda Civic On Tuesday, 04/05/05, I continued su at 358 El Brillo. At 1052 hours, I observed a Red lorer roadway, a Green Explorer bearing FL tag ?in roadwa a Grey Altima bearing FL tag! in roadway, ord Truck hin roadway, Black Merce es driveway being washed by a and-an unknown dark car parked in the garage. At 1059 hours a Blue Chevy Suburban drove to the house of 358 El Brillo and par ?n the driveway. At 1119 hours, I observed the White Fort Truck leave the area and the drive was the pool man. At 1126 hours, I observed a Grey unknown make/model car park in roadway. got out of the car and walked to a house on the south side of El Brillo. At 1406 hours, I observed a Red Explorer parked on roadway and a large white box truck parked behind the surveillance suburban. A A I 32 NA Reported By: BATES, MICHAEL J. 1/03/06 Entered By.: ALTOMARO, NICKIE A. 1/03/06 On 03/31/05, at approximately 1500 hours while conducting surveillance at 358 El Brillo, I observed a Black Cadillac Bscalade, unknown tag, a Black Chevrolet Suburban, unknown tag, a Black Mercedes 8600 FL tag _parked in the east drivewa next to the 3-car garage. There was a Tan Honda Civic FL tag iparked on the street in front of the residence. At approximately 1700 hours, I observed the Black Suburban, Black Escalade, Black Mercedes and Tan Honda Civic parked in the same place. At 1750 hours, there was no change in vehicles. At 1840 hours, I observed the Black Escalade, Black and Black Mercedes along with a Silver Hyundai Accent FL ta all parked in the east driveway and a Red Ford Explorer FL parked on the street in front of the residence. At 2000 hours, I observed the Black Escalade, Black Suburban parked in the ease driveway and the Red Explorer and Tan Civic parked on the street. On Friday, 04/01/05 at approximately 1700 hours, I observed the Black GIUFFRE005682 Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page666 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 70 8:47:53 Incident Report Program: CNB301L No. . . - (Contin?ed) Escalade and Black Suburban parked in the east driveway and the Tan Honda Civic parked on the street in front of the residence. At 1820 hours, I observed the Suburban and Civic in the same place and a Gold Chevrolet Camaro FL tag _parked on the street in front of the residence. At 2250 there was no change. At 2330, I observed the Black Escalade parked in the driveway and the Red Explorer parked on the street in front of the residence. On Saturday, 04/02/05 at approximately 1700 hours, I observed a Black Escalade unknown tag, parked in the driveway and a Tan Honda Civic FL tag _parked in the street in front of the residence. At 1805 hours the EscamCiVic were in the same position and the Black Mercedes FL ta was also parked in the east driveway. At 1920 hours the Escalade and Civic were the only vehicles and both were in the same position. At 2030 hours and 2145 hours there were no vehicles observed. At 2115 hours, ed a Black Mercedes, 4-door parked in the east driveway FL tag At 2300 hours, 2350 hours and 0045 hours, the Black Mercedes was the only vehicle observed. A A I 33 NA Reported By: RECAREY, JOSEPH i/os/os Entered By. ALTOMARO, NICKIE. A. 1/05/06 I made contact with Mr. father of who was told that I wishe to interView his daughter. . stated he was aware and had spoken with his daughter about - incident. He stated that his daughter had previously told h' she was hired to model lingerie at a Palm Beach mansion. Mr. stated he knew nothing else about what she did when she went to "work." Mr. advised he would cooperate with the investigation and make his aug er avail interviews. I asked if she was available for an interview, stated she was_not at home at the on mom I informed him I contact with her at a later time. his interest in the resolution in this matter . as he a this information has affected his daughter emotionally. On January 4, 2005, I acquired the subpoenas from the State Attorney's Office for Cingular Wireless, Metro PCS, Verizon, Bell South Telecommunications and Sprint for the unknown telephone numbers from Sarah Kellen's cellular telephone. The subpoenas were sent to the respective telephone carriers for subscriber information. I received a telephone call from state Attorney's Office, who informed me that the former houseman for Jeffrey Epstein, Alfredo Rodriguez, was present at the State Attorney's Office for an interview. Rodriguez was issued an investigative subpoena for an interview on the on?goings at Epstein's house during his employ. I responded to the State Attorney's Office and encountered Mr. Rodriguez waiting in the lobby. I brought Mr. Rodriguez to the interview room. GIUFFRE005683 .- -.-. .. -. . Case 18-2868, Document 283, 08/09/2019, 2628241, Page667 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 71 Time: 8:47:53 Incident Report Program. Case No. . .. 1-05-000368 (Continued) During a sworn_taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months. He was referred by associates and his employment lasted the months of November 2004 through May 2005. His responsibilities as house manager included being the butler, chauffer, chef, houseman, run errands for Mr. Epstein and provide for_Epstein's guests. Rodriguez advised he had very limited contact with Mr. Epstein. If Rodriguez needed to relay a message to Mr. Epstein, he would have to notify Epstein's secretary "Leslie" in New York City, who would then notify Epstein's personal assistant, Sarah, who would relay the message to Epstein. Rodriguez stated Epstein did not want to see or hear the staff when he was in residence. I asked Rodriguez if Epstein received many guests during his stay in' Palm Beach. Rodriguez advised he had many guests. I asked specifically about masseuses coming to the house. Rodriguez stated he would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either Sarah or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen area and offer them something to drink or eat. They would then be encountered by either Sarah or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. He advised he didn't ask their ages but felt they were very young. Rodriguez stated they ate like his own daughter who is in high school. Rodriguez stated they would eat tons of cereal and drink milk all the time. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He at er Epstein's direction, he delivered a dozen roses to High School one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would clean Mr. Epstein's-bedroom after the alleged massages and would discover massager/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's bed. Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, so that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez referred himself as a "human ATM machine" and was ordered by Epstein to maintain a minimum balance of 000 dollars on him at all times. When a girl would come by the house and Mr. Epstein was either not in residence or 'was not at home at the time, Rodriguez was to provide the girl (masseuse) several hundred dollars for their time and to notify Epstein the amount they were given- Epstein also ordered Rodriguez to GIUFFRE005684 Case A A I NA Case 18-2868, Document 283, 08/09/2019, 2628241, Page668 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page. 72 8:47:53 Incident Report Program: CNB301L No. . . . 1 05- -000368 (Continued) purchase several gifts and provide them as tips to the girls. I asked what kind of gifts. Rodriguez stated he purchased IPODS, jewelry, anything the girls would want. Rodriguez stated the amount of girls that came to the house was approximately fif girls knew each other and all seemed to know at High School who Mr. Epstein was. When asked to ident fy these girls, Rodriguez stated he could not at the moment but knew he wrote their names down on a journal he kept during his employ with Mr. Epstein. He kept a journal in the event he needed to explain either to Mr. Epstein or his assistants what was done at the house or who visited the house as he stated he was in-charge of Mr. Epstein's personal security while in Palm Beach. I informed him I would need to view this journal to which he stated he would research the book and contact me to provide the book. The interview was concluded and left the area. I returned back to the police station where the micro cassette was placed into evidence. At approximately 7:20 pm, I was notified Rodriguez located the journal and would call me on January 5, 2005 to provide the journal. Investigation Continuesaa 34 Reported By: RECAREY, JOSEPH 1/09/06 Entered ALTOMARO, NICKIE A. 1/10/06 On January 5, 2006, I attempted to meet with Alfredo Rodriguez to recover the folder or journal in which he kept the notes that were given to him during his employ with Mr. Jeffrey Epstein. He kept this folder to justify what he did during his employ should the need arise to justify what occurred with the monies he had to keep or any queStions as to the petty cash he withdrew from the household account from the bank. At approximately 10:00 pm, I attempted contact with Mr. Rodriguez and discovered he was assisting his wife at her place of employment and would not be able to meet with-me. Mr. Rodriguez stated he would meet with me on January 6, 2006, in Broward County, in the morning hours. On January 6, 2006, at approximately 9. 00 am, I received a telephone call from Mr. Rodriguez who advised he had the file in hand and would be traveling northbound to meet with me in Broward County. At 10:50 am, I met with Alfredo Rodriguez at the parking lot of Bank of America in Boca Raton on Yamato Road and Military Trail (known as the Polo Center). Rodriguez produced a green folder which contained documents, a note with Mr. Ep with direction to deliver a bucket of roses to igh School after? high school drama er ormance. so in that same note was irec ion to rent a_car for hand direction to extend the rental contract. I returned to the Palm Beach Police Station and placed the folder into evidence. I received a fax from Verizon from the subpoena request sent on GIUFFREOOSGBS CONHDENHAL . .. . Date: Time - Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page669 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 73 8: 47: 53 Incident Report Program: CMS301L No. . . . 1-05-000368 (Continued) 01? 04 06, for telephone number The phone munber is registered to Dr Perry Bard, from West is a 'n West chiropractor and has an office located Palm Beach. The cellular number is Dr Bard's personal cellular number . On January 9, 2006, Det. Caristo and I traveled to ?n Palm Beach Gardens in an attempt to locate Johanna Sjoberg, who had i been previously seen on the property and identified through her Florida Drivers License and Florida license Plate. A business card was left for her to return In call. We then traveled to the! _Foundation and located?. ?agre speak with us and in a private room within the so 00 provided us a taped statement. During the statement, _dvised that when she was fifteen or sixteen ye?ii ii iiel was taken to Jeffrey Epstein's house by her associate, tated this occurred late May 2004 or early June 2004. She was told she could model lingerie for money . for a. wealthy Palm Beecher. She remembered they traveled by yellow cab from their residence in West Palm Beach to Epstein' 3 house. She remembered encountering Epstein at the front door during the evening 3 hours . He introduced himself and brought them into the kitchen so that the i chef could prepare somethin for them to eat. After having a meal, and Epstein brought hupstairs to a master bedroom which had a large bathroom. She Observe a large style shoWer, sauna and there was a large massage bed also in the bathroom. Epstein entered a room within the bathroom and came out wearing l. 3 said they would rovide a massage on his feet. l'Wsked why they are doing this. htold her this was part of ine and told her to rub his le and calves. Epstein had told comfortable. continued rubbing Epstein's ca Epstein's direc ft the room leaving by herself. Epstein 1:01 0 get comfortable emoved her blouse and pants and 1n her panties. stated she was not wearing a bra. She believed she was wearing thong panties. Epstein turned over onto his back and began t0uching her. Epstein touched her breasts and began touching her in her vagina area 5 Epstein instructed her to rub his chest 'and rub his nipples. :2 stated the touching consisted over the panties on the first time; stroked her vagina but stayed on top of the panties. During the first 5 massage, she stated Epstein was stroking her and beganmasturbating himself at the same time. He put his hands under the towel and appeared as to masturbate himself however she never saw his penis. She continued rubbing his chest until he grabbed her and pulled her closer to him. He appeared to have climaxed because after he pulled her closer to him the massage was over. Epstein had told her that there was two hundred dollars for her on the dresser. He told her that she could not tellan?swhat happened at the house or bad things could happen. tated she went to Epstein's house three GIUFFRE005686 Case 18-2868, Document 283, 08/09/2019, 2628241, Page670 of 883 Date 7/25/06 PALM BEACH POLICE DEPARTMENT Page Time: 8:47:53 Incident Report Progran Case No. . . . 1-05-000368 (Continued) or four times total. _was very scared and felt very nervous. 6 She knew because of Eps ein money he was powerful. After the massage, Epstein ordered his houseman at the time to drive the girls home. The employee was to drop off the girls at their house and watch them go inside their house. could not remember who the houseman was. She stated Epstein . and nis assistant Sarah would call her at her father's house to arrange for her to come and "work." She advise? she returned to the house, Epstein would do the same thing. tated it was a routine with Epstein.- She would rub his fee and calves. (He would then turn over and begin to touch her on her vagina area. The only difference was that it was done without panties. Epstein's fingers would stroke her vagina area as he would masturbate and finally climax and the massage would be over. She was paid $200.00 each time she went. Each time she went she was reminded not to speak of what happened at the house and that she would be contacted again. She began to purposely miss the calls when either Sarah or Epstein would call her. She once brought a friend,Hunkno name, to work for Epstein. She was paid $200. or inging? stated she no longer retuned to work for Epstein., She a so stated wanted to notify the police of what happened at the house. ?stated she was scared of what could have happened to her or er ami if she notified authorities. On January 10, 2006, I received the results from the sub oena from BellSouth Telecommunications for tele hone number The number is assigned cod, 5 at er in Palm Beach Gardens. I also received stern Union which confirmed the money order sent to from Jeffrey Epstein in New York City. The "wire" was sent by Jeffrey Epstein of 457 Madison Ave in New York City on December 23, 2004 at 12:05 pm. The amount of $222.00 was charged to Epstein's credit card so that could receive $200.00 in Royal Palm Beach. The twenty?two ars as for processing and local fees to send via Western Union. A COPY of the check presented to as also attached to the receipt of the wire. This confirmed what advised she received as a Christmas bonus from Epstein-.. Investigation continuesReported By: RECAREY, JOSEPH 1/10/06 Entered By.: ALTOMARO, NICKIE A. 1/10/06 I received and reviewed the Cingular Wireless results from the sub oena re ests for subscriber information for telephone numbers The first number, is assigned to Janusz Banasiak in care of Jeffrey Epstein of 457 Madison Ave in New York City. Banasiak is the current houseman/house mana er for 358 El Brillo Way in Palm Beach, Fl 33480. The second number, is assigned to Christina Venero of GIUFFRE005687 Case 18-2868, Document 283, 08/09/2019, 2628241, Page671 of 883 Date: 7/25/06 PALM BEACH Page: 75 Time: 8:47:53 Incident Report . Program: Case No. . 1-05-000368 (Continued)- conditional/active license number Venero had been previously arrested for battery unwanted aching 41d DUI. _Requests for copies of the reports involving the arrests were reque Palm Beach County Sheriff's Office. 'The last number is assigned to Thomas Rofrano of Palm Beach Gardens. Research on Mr. Rofrano, revealed that he is a Florida Chiropractic Physician. *West Palm Beach. Research conducted on Venero revea is a icensed Massag?t with a Florida Vehicles that were previously documented on the property while surveillance was being conducted were res I determined a tan Chevrolet Camaro, bearing Florida license? was seen on the property in which a young white female wa tering the Epstein property. Res a revealed that the vehicle is . as two daughters, '3 curren residing in Connecticut an e51 ing with her father in Lake Worth. Research revealed she was recently involved in a traffic stop in Lake Clarke Shores in May 19, 2005. A request to discover any information from the stop was requested. I spoke with ASA Daliah Weiss who informed me that Janusz Banasiak will be available for an interview tomorrow at the State Attorney's Office in West Palm Beach at 1:30 pm. I informed her that I would be at her office for the interview. A A I 35 NA Reported By: RECAREY, JOSEPH 1/23/06 Entered By.: ALTOMARO, NICKIE A. 1/23/06 006, Det. Caristo and I met with Johanna sjoberg at Palm Beach Gardens. sjoberg was identified as a licensed massage therapist who had previously been seen on Epstein's property when physical surveillance was done. sjoberg was told of the on going investigation and I felt she may have information pertaining to the case. During a sworn taped statement, sjoberg stated she met Epstein three years ago when Ghaline Maxwell approached her while she was attending Palm Beach Atlantic College to work around Epstein's house. Maxwell had told her that they needed some girls to work at the house to answer phones and run errands. sjoberg accepted the job and began working at Epstein's house on El Brillo in Palm Beach. Sjoberg stated it was a part time job during the time she went to Palm Beach Atlantic College. She continued going to Epstein's house and 'would be notified when Epstein would travel to Palm Beach. sjoberg advised she would be notified by_Maxwell, Epstein or Sarah, his assistant, when he would travel to Palm Beach. sjoberg stated she 'began providing massages to Epstein before she became a massage therapist. She continued giving massages not only to Epstein but to Nadia Marcinkova, and Sarah, his assistant. sjoberg was asked about what-occurred during the massages. sjoberg stated as she was twenty GIUFFR5005688 CONFIDENTIAL .. . . . . Date: Time Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page672 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT page: 76 8:47:53 Incident Report Program: CMSBOIL No. . . . 1? 05- 000368 (Continued) three years old when she met Epstein, anything that happened was between two consenting adults. I explained to her that she was not in any trouble however as part of this investigation, I needed to ask certain questions. Sjoberg stated that there were times that Epstein would ask her to perform during the massage. He would instruct her to rub his nipples as he masturbated himself. Sjoberg stated she felt "grossed" about the behavior but as she was getting _paid, she just continued. Sjoberg also advised she would on occasion perform the massages naked Epstein would on occasion, utilize the vibrator/massager on her vagina area when she performed the massages. Sjoberg explained that Epstein never exposed himself to her as he maintained himself covered under the towel he would be wearing. When Epstein would masturbate he would be covered. I asked if Sjoberg ever received any gifts, or any gratuities from Epstein. Sjoberg advised aside from being paid well, she advised Epstein took care of her tuition from Palm Beach Atlantic College. She received a rental car for a week when her scooter broke down. Additionally she received other gifts from Epstein. Epstein also recommended her to another client who resides at Breakers Row in Palm Beach. The client she was referred to was "Glenn" unknown last name, and his wife, who she provided a massages to. The statement was concluded and placed into evidence upon our return to the Palm Beach Police Department. While at the police station, I researched Florida tag _which was also previously seen on the property when there was physical surveillance being done at the property. The vehicle is registered to ?Lake Worth, Florida.M. ._and the vehicle revealed that his daughter, had been driving the vehicle and was cited for unlawful speed in Lake Clark Shores. The vehicle is a tan, Che et Camaro, 2-door. I researched ate of birth, 987, resides at pace page called? In her web page, shows various photos of ?photographed at a beach. An interview is forthcoming. A review of the video disks which was extracted at the Palm Beach County Sheriff's Office Computer Crime Unit revealed that only one. hidden camera was functional at the time. Several images of Epstein working at his office were seen. Additional footage of Sarah Kellen and Nadia Marcinkova was seen. There was other footage of females seen. The identity of the females is unknown at this time, until such time as I meet with certain females to show the video footage to confirm if in fact, it is them on the video. At this time it appears that? and Haley Robson are seen sitting with Epstein beside his es in evening hours. Due to poor lighting, a direct confirmation cannot be made at this time. Inv. Continues. GIUFFRE005689 .. .. . .- - - . .1. .. . .4 Case 18-2868, Document 283, 08/09/2019, 2628241, Page673 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 77 Time: 8:47:53 Incident Report Program: Case No. 1-05-000368 (Continued) A A I 3'7 NA ReportedBy: RECAREY, JOSEPH 1/30/06 Entered By.: ALTOMARO, NICKIE A. 1/30/05 On Janua 25, 2006, Det Carist ded to is. with stated last year, when sne was seventeen e, she met Jeffrey Epstein through her former room mate -as allegedly dating Epstein at the time. once cohabitated together and when they modeled. lplaine called her on her telephone and advised her that was in Palm Beach and requested to see her. made arrangements to Epstein' 5' house. arrived and met Epstein @th and _went to the Palm Beach Mall together and went 5 opping. advised that-and she had received money from Epstein to go to the mall. They visited Victoria's Secret and purchased undergarments from the store utilizing monies given by Epstein. advised she purchased one item and _purchase various items. The money used to purchase the items was the money given by Epstein. continued shopping and having a day together. stated lained how she and Epstei ot er been datin ac and he has been paying all of her bills. ilaimed?advised they met in New York and had been dating ever Since. They later returned to Epste' me and encountered Epstein. He had a brief conversation wittht her modeling career. He knew of her modeling career from He requested to see her modeling io and explained that he cou her with modeling jobs. ad her book with her to show and showed the book to ?stein. He commented negatively abou er photographs and portfolio. felt uncomfortable with the comments made as she had been wor 1ng with other professional modeling companies who had offered her work from her photographs. stein requested to see what was purchased at the mall. ook out the undergarments which were purchased. She immediately showed stein different ?chased. Epstein then requested to view what urchased. as reluctant to show the outfit however since it was Epstein' money that purchased the he pulled it: out of the bag. Epstein asked her to try it on. looked at _who told her "yeah, try it on. Feeling compelled to try the undergarment outfit on; she went to another room and put on the bra and panty set. She walked out to the living room where they were sitting, and modeled the suit. She then went back into the other room and cha ck into her clothes. . returned into the room an she would be going home. scheduled another day for to return for massages with her. tated within that same week, she returned to meet with and have a massage. ?ad told her that she would be unable to sta with her as she wou going on a bike ride with Epstein. explained she could stay at the house and take advantage of the massage. GIUFFRE005690 CONFIDENTIAL NA Case 18-2868, Document 283, 08/09/2019, 2628241, Page674 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 78 8:47:53 Incident Report Program: CMBBOIL No. . . . 1?05-000368 (Continued) herapist and had the Estated she met with an unknown already set up in a guest room. emoved her clothing, leaving her anties on, and wrapped herse with a towel for the massage. remembered that the-door to the guest room was closed but not locked. As the therapist was working her back, the door was opened by Epstein and entered into the room. _was trying to conceal herself as Epstein was talking to her about hi ractic session. Epstein told-:urn over onto her back. eventually turned over exposing her breasts to Epstein as he applied pressure on her shoulder and her waist. tated Epstein "popped! her back. emoved her se he table, got dressed and left the house further state ad attempted to call her several occasions her back to Epstein's house to which? 'm busy." dvised she has not had contact with ei er effrey Epstein. It Should be noted that her mother, as present during the interview. The interview was concluded and we thanked them her for their time. A A I 38 Reported By: RECAREY, JOSEPH 1/31/06 Entered By.: ALTOMARO, NICKIE A. 1/31/06 On 006, I made telephone contact with Christina Venero, at Venero is a licensed massage therapist who had frequented the home of Jeffrey Epstein. Ms. Venero has been unable to meet with me in Palm Beach County, and because she lives and works in Port St Lucie, a telephone interview was conducted. I explained to Ms. Venero that there was an on going investigation involving Jeffrey Epstein. Venero stated she knows Epstein and has been employed by him for approximately three years.. Epstein has paid Venero to perform Swedish Massages (Deep Tissue) on him and other guests. Venero explained that approximately three year ago she met Ghislaine Maxwell and Jeffrey Epstein through a mutual friend. Epstein and Maxwell were looking for a massage therapist. Venero stated since that time, she is notified when Epstein is coming to Palm Beach. Venero stated she comes to his house and provides the massage or massages. Venero explained she has also massaged his guests and assistants. Venero continued that she is paid $100.00 and hour for the massage. I asked Venero if anything occurred during the massage that would haVe made her feel uncomfortable. Venero stated she only provided massages and that was it. She never was approached for anything else. I asked if Epstein ever asked her to rub his chest she stated she would not rub his chest as that is not part of her massage. venero explained that she was not Epstein's type. The girls she would see at Epstein's house were very thin, beautiful and without tattoos. Venero explained she has several tattoos that are visible. Maxwell and Epstein have commented negatively about her tattoos previously when she has provided massages. GIUFFRE005691 CONHDENHAL ~u Case 18-2868, Document 283, 08/09/2019, 2628241, Page675 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 79 Time- 8:47:53 Incident Report Program: CMBBOIL Case No. . . . 1-05-000368 (Continued) venero stated she only provided massages for Epstein and his associates and nothing happened during those massages. Venero stated as she does Swedish style massages, the patient is usually sore after the massages. I thanked her for her assistance and the interview was concluded at this time. I received a facsimile from T- Mobile Cellular service on telephone number? which is assigned to David Rodgers, pilot for Mr. Epstein, who resides in Lake Worth. Rodgers' telephone number was dialed on several occasions by Sarah Kellen. A background on Rodgers indicated he has a valid FAA pilot license First Class for the Southern FAA Region. Rodgers has another historical FAA license for Airline Transport Pilot. Investigation Continues. A A I 39 NA Reported By: RECAREY, JOSEPH 2/14/06 Entered By.: ALTOMARO, NICKIE A. 2/16/06 ry 3, 2006, I had made arrangements to meet with the Palm Beach Police Station. approximately 1:00pm, and her-friend, arrived at the police station. During an interview wi she stated she met Epstein when she turned eighteen ye was brought to Epstein's house to provide a massage. She advised this oCcurred on May of 2005. She advised Haley Robson had informed her if she wanted to provide a massage for $200. 00. reed and was brought to Epstein' 3 house to provide a massage. stated she had been to the house on_many occasions during the massage sessions. also stat he would remove her clothing to provide the massage on Epstein. ?advised Epstein would pay her' $300.00 to rub his back, legs and chest. During the massages, Epstein would masturbate himself as she rubbed his chest. I asked her if Epstein ever touched her breasts during the massages. I asked her if Epstein ever touched or massaged stated he had on several occasions. I asked her - ne ra ed her with either his penis or any other objects. tated that during a massage he inserted his fingers in her va 1na as she massaged him. She stated this occurred one time only. _stated the message would be over when Epstein would climax onto a towel. I asked if she had an formal massage training to which she replied that she did not. *was then asked if she ever brought anyone to the house to "work." ?ated she brought two people to the house. She advi ce1ve money for bringing people to the house to "work." stated she brought a gi her friend as still wait'n for lobby of the police stat1on. I thanked? cooperation and escorted her to the lobby. and 1n the er time and her or I asked Ms -if I could speak with her about this investigation. I GIUFFRE005692 .. . Case 18-2868, Document 283, 08/09/2019, 2628241, Page676 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 80 Time: 8:47:53 Incident Report Program: CMB301L Case No. . . . 1-05-000368 (Continued) brought her to the interview room and explained to her that I was conducting an investigation on Jeffrey Epstein and felt she may have information the investigation. Ms -identified herself as mild resides in Wellington, Florida. She advised approximately a year a 0 she was brought to Epstein's house to provide a massage for money. ?stated she needed to make money and felt it was a quick way to make some money. -stated she was brought. to the house by-nd was introduced to Epstein and his assistant. She was brought to his main bathroom and prov' massage. I asked her if she provided the massage naked. ed she did. She rubbed Epstein's legs, back and chest. I a if Epstein touched her during the massage. She advised he did not, however he did masturbate himself as she rubbed his chest. Once he climax massage was over. She was paid her money and left the area. advised it occurred one time and she never returned to Epstein's house. The interview was concluded and was escorted to the lobby. I located a telephone number for nd attem ted to contact mseveral occasions. I ca spoke with Ms. ho advised she would speak with me in Deerfield Beach where she resides. Due to a scheduling conflict, we were unable to meet. I informed her I would contact her to schedule another appointment to speak with her about this investigation. I have attempted to meet with her and make telephone contact with negative results. On February 13, 2006, I met with David Rodgers at in Lake Worth. Rodgers was identified as Epstein's pilot. I spoke with Rodgers who advised he has been employed with Epstein since 1991. He flies both planes for Epstein depending where he wants to fly to. Rodgers was asked about paSsengers in the plane he flies. Rodgers stated unless Epstein flew to his island off of St Thomas, there would be no way of knowing who the passengers were. I ment' nt flight to Ohio, where Rodgers flew to Ohio to pick up Rodgers ?he recalled flying on several occasions and aid remember Rodgers stated once he is in the cockpit, he does not know who the passengers are. When he prepares the passenger manifests, he lists Epstein and his assistants he knows by name, Sarah and Adrianna. Rodgers stated he would list either female or male passengers on the manifests only to keep a count on the passengers. Mrs. Rodgers came into the living room and recommended that her husband consult with an attorney. Mr. Rodgers agreed he would speak with the family attorney to inform him of this questioning. I explained to Mr. Rodgers that he was not the suspect in this investigation and ceased all questions. Based on the fact Rodgers could not advise who passengers were in the plane, I then left the area . I attempted to locate?t ?in Wellington. I left my business card for her to return my call. February 14, 2006, at 12:06 pm, I received a call back from Ms. GIUFFR5005693 . . . .. Case 18-2868, Document 283, 08/09/2019, 2628241, Page677 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 31 Time: 8:47:53 Incident Report Program: CMSBOIL i Case No. . . . 1-05-0003? (Continued) on voice mail.- Ms left her telephone number for a return call? I left her a message to return call. Investigation ContinuesReported By: RECAREY, JOSEPH 2/21/06 Entered By.l: ALTOMARO, NICKIE A. 2/22/06 5 On February 15, 2006', I made telephone contact with ?ho provided dir could locate her. .Det Caristo and I res onded to 'n to meet with? Upon my arriv me with in the parking lot directly behind MAACO Auto Painting. She was a Vised I was there to speak with her about an on oing investigation that concerned Jeffrey Epstein in Palm Beach. ?stated she knows Epstein very well and did not want to speak with me about Mr. Epstein. She was very fond of Epstein and did not want to speak with me about anything concerning Jeffrey Epstein. I explained to her that she was seen at the house and I . would like to speak with her. She stated she knew there was an i investigation and that I had spoken with other eo le and therefore I should know what happened at Epstein's .house. ?ended the conversation and walked back into her boyfriends business, Blanton Automotive. Det Caristo and I left the area and returned to the police station. Investigation continuesReported By: RECAREY, JOSEPH 4/10/05 Entered By.: ALTOMARO, NICKIE A. - 4/10/06 i A Grand Jury Session was requested during the month of February 2006, in which all the girls that had been interviewed would have been called to testify before the Grand Jury to seek an indictment against Jeffrey Epstein. Due to subsequent meetings with the State Attorney's 2 Office and Defense Attorney Alan Dershowitz the Grand Jury was postponed until a later time. Dershowitz had provided a package of material on the main victims in this case in which they appear on myspace.com and speak about alcohol use and some marijuana use. The state Attorney's Office wanted time to review the material. I requested additional subpoenas from the State Attorney's Office in i which I requested information from Dollar Rent a Car and Jet Aviation. The information requested from Dollar Rent a Car was for the rented vehicle by Alfredo Rodriguez while under the employ of Epstein for one of the victims. The other subpoena requested was for Jet Aviation for dates and times when Epstein's planes were in Palm Beach County. I continued to research other names that were acquired either from interviews or intelligence gathered during the investigation. I GIUFFRE005694 Case 18-2868, Document 283, 08/09/2019, 2628241, Page678 of 883 Date 7 /2 5/ 06 PALM BEACH POLICE DEPARTMENT Page 8 2 Time: 8 47: 53 Incident Report Program. CMS3 01L Case No. . . - 1-05?000368 in Royal Palm Beach. oyal Palm Beach. During the i stated she knew I would be speaking with her. st introduced to Epstein when she turn u. eighteen she was sure of her age as it was her senior year in High School. She advised she was brought there to make money and was told she would have to provide a massage to this Palm Beach guy'. She remembered she met Epstein and his assistant . Sarah in the kitchen area. She stated she was taken by one of her friends, _She stated she went upstairs with Sarah whil got ready for the massage. He exited his bathroom naked and? und. Epstein asked her if being naked offended he . Wstated it made her le. Epstein then put on a towel and lay on the table. ?tated she rubbed his back and feet. She stated she had no message t1 ining or experience. _an the massage, Epstein attempted to touch her buttocks pulled away as he touched her buttocks. She told Epstein then him again she was uncomfortable with him touching her. she went witL cut the massage short and became upset with her. Epstein she did not $200.00 for the massage and told her to leave the house. rn?ed to the house. She did advise of however she waited in the car for want to go into the house. lusion 5 visit with Epstein they left the area. ?stated she had heard from other girls that have gone to the house that Epstein now required them to do the massage naked and allow him to touch them in their private areas for monies. The interview was concluded as _did not have any other information to provide. I then learned from the original victim, e! the defense attorney had learned of her identity. I spoke with th ather of the victim, who stated there has been a private investigator on his house photographing his family and chasin visitors who come to the house. He provided a Florida License of This vehicle is registered to Ivan Robles of West Palm Beach. Robles is a private investigator intern who is licensed by the state. I informed the State Attorney's Office of the above information. I respo I received the Grand Jury subpoenas to be delivered to three victims for a Grand Jury session to be held on 'April 18, through April 20, 2006. Investigat ion continue . A A I 42 NA Reported By: RECAREY, JOSEPH 4/14/06 Entered By.: ALTOMARO, NICKIE A. 4/18/06 The Grand Jury Subpoenas were personally served to the individuals they were issued to. On April 5,2006, at approximately 7:30 I personally served the parents owaho had informed me that the private investigators were still ographing the family. On April GIUFFRE005695 CONFIDENTIAL Date. Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page679 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 83 8:47:53 Incident Report Program: CNB301L No. . . . 1-05-000368 .(Continuedj 10, 2006, at approximately 2:30 I served her dence in Royal Palm Beach. The subpoena was given to her mother, i I learned through one of the victims -that she was personally contacted through a source that has maintained contact with Epstein. The source assured -she would receive monetary compensation for her assistance in not cooperating with law enforcement. AH also stated she was told, "Those who help him wi compensated and those who hurt him will be dealt with. I told that tampering with a witness/victim is an arrestable offense and very serious. I asked her who approached her during this encounter. -originally was reluctant to provide the name of the person who approached her to offer her not to testify because she felt they were still friends. On April 11, 2006, Det Dawson and I traveled to Tallah ssee, Florida and met with the victim, - -identifiedi as the person who approached her in R0 al Palm Beach while she was home during Spring Break in March 2006. stated she did not want to pursue the intimidation charges on concerned that the defense attorney was given a copy of report as in things she had told me in confidence were repeated to her by Prior to our departure, the victim was given a copy of her subpoena for the Grand Jury which was scheduled to commence April 18, 2006. Upon our return from Tallahassee, I notified the State Attorney's Office of what was told to me. I also notified them that the subpoenas were delivered to the witnesses and they would be calling for arrangements for the date and time needed for the Grand Jury. I spoke with ASA Weiss and informed her of the possible intimidation by the defense. On April 13, and April 14, 2006 I attempted contact on several occasions with ASA Weiss and ASA Belohlavic to ascertain when the victims needed to report for Grand Jury testimony. Messages were left on their voicemail. On April 17, 2006, during the hours of 9:00 am and 11:30 am, I again left messages for ASA Weiss and ASA Belohlavic for either of them to return my call as I had not heard from the State Attorney's Office as to the time and date of the Grand Jury. At approximately 12: 30 pm, I went to the State Attorney's Office and located ASA WeiSs and ASA Belohlavic in their offices. I entered ASA Belohlavic' 8 office who informed me that she was going to return my call.- She explained that an offer was made to the defense, Atty Guy Fronstin and Atty Alan Dershowitz. The offer is_1 count of Agg Assault with intent to commit a felony, five years probation, with adjudication withheld. Epstein would have to submit to evaluation and no unsupervised visits with minors. When asked about the all the other victims, ohlavic stated that was the only offer made as to one victim, ASA Belohlavic cell phone rang and went to voice mail. She checked her voice mail and played the message on Speaker. The caller identified himself as GIUFFREOOSGQG CONHDENHAL . . . . .. Case 18-2868, Document 283, 08/09/2019, 2628241, Page680 of 883 Date 7 2 5 [05 PALM BEACH POLICE DEPARWT Page i 84 Time: 8:47:53 Incident Report . Program: CFE301L Case No. . . . 1-05-000368 (Continued) Atty Guy Fronstin and acknowledged the deal made between them. Fronstin stated in the message, he spoke with his client, Jeffrey Epstein, and agreed to the deal. Fronstin asked to call off the grand jury as they would accept this deal. Belohlavic stated a probable cause would be needed to book Epstein in the county jail and would let me know as to when it would be needed. I explained my disapproval of the?deal and not being consulted prior to the deal being offered. However I expressed that was only my opinion and the final approval would come from the Chief of Police. She explained to have Chief Reiter call Barry Krisher about the deal. I left the area and returned to the police station where I briefed the Chief about the deal offered. I checked my voice mail messa es and discovered a message from stepmother for the victimiShe was calling because the State Attorney's Office still had not returned any of her calls as to when they are needed for this-case. I then called ASA Belohlavic's office and left messages for her to call the victims on this case and explained to them what the State Attorney's Office had done. On April 17, 2006, at approximately 4:30 pm, State Attorney Investigator Tim Valentine called to officially notify megof the cancellation of the Grand Jury. He requested I contact the victims that had been served to appear, to notify them of the cancellation. I advised Valentine that as this Grand Jury session was called based on the State Attorney's Office decision to have the victims heard by the Grand Jury that I felt it was the States Attorney?s Office responsibility to contact the victims and advise them of the reason they were no longer needed. A A I 43 NA Reported By: RECAREY, JOSEPH . 5/04/06 Entered By.: ALTOMARO, NICKIE A. 5/04/06 As I had not received any contact from anyone at the State Attorney's Office, on May 1, 2006, I prepared three arrest warrant requests and submitted them to the State Attorney's Office. The packages were delivered to the Crimes against Children Unit in care of ASA Lana Belohlavek. Jeffrey Epstein's arrest warrant was requested for 4 counts of Unlawful Sexual activity with certain minors and one count of Lewd and Lascivious Molestation. Sarah Kellen, Epstein?s assistant's, arrest warrant request was for 4 counts of Principal in the degree Unlawful Sexual activity with certain minors and one count of Principal in the degree Lewd and Lascivious Molestation. Haley Robson?s arrest warrant request was for Lewd and Lascivious Acts on a victim under 16 years of age. The receipt of delivery was signed and brought back to the records division_at the police department. On May 3, 2006, at approximately 2:54 pm, I received a telephone call from ASA Daliah Weiss on my cellular telephone. ASA Weiss advised she GIUFFRE005697 0.. .. Case 18-2868, Document 283, 08/09/2019, 2628241, Page681 of 883 Date: 7/25/06. PALM BEACH POLICE DEPARTMENT Page: 85 Time: 8:47:53 Incident Report Program: CNB301L Case No. . . . 1-05-000368 (Continued) has been taken off the Jeffrey Epstein case because her husband is employed with Attorney Jack Goldberger. Attorney Goldberger is the attorney of record for Jeffrey Epstein. His previous attorney, Guy Fronstin, has been fired from representation. ASA Lana Belohlavek has been assigned the case. ASA Weiss stated she can no longer speak about the Epstein case with me. I thanked her for her telephone call. ASA Weiss further stated that ASA Belohlavek would be calling me. A A I 44 NA Reported By: RECAREY, JOSEPH 5/15/06 Entered By.: ALTOMARO, NICKIE A. 5/15/06 On May 10, 2006, information was received that Epstein's associate, Leslie Wexner, The Limited Inc, CEO's, plane had arrived in West Palm: Beach, PBIA. The plane, a 4 bearing a NSOOLS registration, was on the tarmac at Galaxy Aviation. As Epstein had recently acquired the services of a new attorney, and the fact that Epstein's house is currently under remodeling, it was believed that Epstein may be in Palm Beach.? I conducted physical surveillance at the residence, 358 El Brillo Way. I observed a large construction crew'conducting remodeling at the house. The contractor, David Norr, was obserVed driving a Ford Explorer, white in color. The vehicle has a Florida registration of FBOQQF. Norr left Epstein' 8 house and traveled north on County Road. Det Caristo and I conducted surveillance on Norr. Norr traveled to several construction sites and checked on certain jobs. Surveillance was discontinued on Norr and Det Caristo and I traveled torGalaxy Aviation. I observed the white plane with a blue stripe along the body and tail of the plane; the tail number was visible on the bottom of the tail, closer to the body of the plane. We maintained visual surveillance on the plane until 4:57 when a caravan of Cadillac Escalades drove onto the tarmac. We observed several people exit the vehicles and discovered that they were part of the executive team for Limited Inc.? The executives were in Palm Beach County for an executive meeting for the day. They arrived in Palm Beach County on May 9, 2006 at 9:30 pm and were scheduled to leave on the 10th at 5:00 pm. On May 12, 2006, I met with ASA Lana Belohlavek at the State Attorney's Office. She explained that her boss, Barry Krischer, was requesting this case be taken to the Grand JUry again. I explained to her I had requested arrest warrants for Jeffrey Epstein, Sarah Kellen, and Haley Robson. I asked that she either issue the warrants or direct file, as so much time has elapsed since the original request to the Grand Jury. I explained that the Palm Beach Police Department had concluded the case in December of 2005 and has been waiting for the case to go forward. Belohlavek stated the original offer was again offered-to the new defense attorney. She was waiting for their answer by Friday May 19, 2006. She stated she would advise me of the answer. A A I 45 NA Reported By: RECAREY, JOSEPH 6/05/06 GIUFFREOO5698 n. -. Case 18-2868, Document 283, 08/09/2019, 2628241, Page682 of 883 Date: 7/25/06 PALM BEACH POLICE - Page: 86 Time: 8:47:53 - Incident Report Program: Case No. . . . 1--05-000368 (Continued) Entered By.: ALTOMARO, NICKIE A. 6/06/06 On May 22 2006, I received several phone calls throughout the day from Mr. ho st ed he had been followed aggressively by a private investiga or. Mr. tated that as he drove to and from work and running errands throughout the county, the same vehicle was behind him runnin other vehicles off the road in an attempt not to lose sight of Mniehicle . I explained to him as Mr. Epstein had retained new legal council it was possible it would be new private investigators following him to observe his daily activities. I also explained to him that there was a meeting scheduled with ASA Lana Belohlavek and Attorney Jack Goldberger at Mr. Krischer's office scheduled on June 1, 2006 at 9:00 am. I attempted to call ASA Lana Belohlavek to inform her of the private investigators following Mr.-10wever; she was on her vacation during the week of May 22 through May 30 2006. On May 23,2006, I received other phone calls from Mr. and ._vho advised they were able to acquire the private investigators license plate information. The subj following them was again 'ng very aggressively and caused Mrs. 0 run off the road. Mrs. the vehicle is a green Chevy Monte Carlo bearing Florida tag? The vehicle is registered to Zachary Bechard of Jupiter Flori a. Bechard is employed with Candor Investigations from Jupiter, Florida. Bechard is a licensed Private Investigator in the State of Florida. Since the discovery of the threat made against one of the victims in this case I re ested subpoenas for all calls made to and received from uring the month of March 2006 for her cell phone an ome one. 'had confirmed with Florida State University the exact dates of Spring Break for 2006. The Spring Break was from March 4, 2006 through March 12,2006. I received a subpoena from Sprint/Nextel with all calls made during the month of March 2006. I reviewed the 989 calls made and during the month of March 2006. I observed on March 7,2006, ads and received thirty five calls during that day. Date Time Seconds In/Out 'To/From 7-Mar-06 11:03 AM 492 Outbound 7-Mar-06 11:16 AM 6 Inbound '?Mar-06 11:22 AM 887.2 Inbound -Mar?06 11:37 AM 48 Outbound War-06 11:39 AM 28.2 Inbound ar-06 12:02 PM 727.2 Inbound table reflects the date of the calls, time of day (EST), duration GIUFFRE005699 .1 .. Case 18-2868, Document 283, 08/09/2019, 2628241, Page683 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page; 37 Time 8:47:53 - Incident Report Program; case NO. 0 . . 1'05'000368 (Continued) corporate number which lasts 12 minu from _s hone. On March 7, 2006, at 11:03 am, made a call to the victim hich lasted 492 seconds (8?minutes an 2 seconds). The victim then returned the call at 11:16 am which lasted 6 seconds. The victim then made contact with_ at 11:22 am for 877.2 seconds (14 minutes and 6 seconds). These sequences of calls were consistent with what the victim had described to me on the date of th intimidation. Immediately after speaking with the victim, akes a call to Sarah Kellen, Epstein's assistant, which lasts for forty-eight seconds. A call is then immediately received, a telephone number registered to a Corporation affiliated with Jeffrey Epstein located at 457 Madison Ave in New York. An extensive computer check revealed 457 Madison Ave is a business address in which Epstein has his corporations assigned to. Epstein had corporation attorney, Darren Indyke, register the businesses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group. Ghislaine Corporation, Epstein and Company and the Financial Strategy Group regH to this same address. of call in seconds, inbound or outbound calls and c?ade to or Finally, a third call is received by at 12:02 pm from the same 1 second. It should be noted that there is no further contact with either the victim during the month of March or April of 2006. I also noted that there was no further contact with Sarah Kellen or Jeffrey Epstein during the remainder of the month of March or April 2006. On June 1, 2006, ASA Lana Belohlavek telephoned me to inform me of the meeting that occurred with Atty. Jack Goldberger and her reference this case. She advised she would make her determination on whether to file on this case or not by Monday June 5, 2006. Inv Continues. A A I 46 NA Reported By: RECAREY, JOSEPH 7/12/06 Entered By.: ALTOMARO, NICKIE A. 7/12/06 On June 29, 2006, I had spdken to ASA Lana Belohlavic who informed me that the case would be sent to the Grand Jury for charges. She informed me that the grand jury would convene on July 19, 2006 to hear the Epstein case. Belohlavic stated State Attorney Barry Krisher made the determination to go the Grand Jury to hear the case. On July 12, 2006, I spoke with Mrs.-nother of the victim-who inquired about the status of the case. I explained to her that I was told we would be going to the Grand Jury during the week of July 19, 2006. She stated she had not been contacted as of yet by the State Attorney's Office for any information. I provided her with the telephone numbers to the State Attorney's Office. Investigation GIUFFRE005700 - . Cam: 18-7868, 782, 08/00/7010, 7678741, Pagp?RA nf 882 EXHIBIT 40 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page685 of 883 amazoncom 98:22:23}; Lexington, KY 40511 Jeffrey Epsheih - . I 358 IE1 Brine Way . Palm Beach, Fiorida 33480 SORTExtFastTradc I 'IeffreyIIEpsteirlt 858 El 8:810 Wa'y . I . Palm Beach, Florida . . preferences, and much more ?-24 - ?99391 Pa Lm I8Iea 35.3348 to rami?- mcluding'gifts? unopeneId or original tIIoInd day?'for?a'pr?'refund (ther apply) onur' order?ED' ready - -. .- Your order. of. 8 Qty. Item I IN THIS .1- SM 101: I femb?r I19: 30f0911? 19: 45/mreed Box or Pad: BCLI812X9X2 Ml? Cam: 18-7868, 782, 08/00/7010, 7678741, Pagp?RB nf 882 EXHIBIT 41 (Filed Under Seal) GIUFFRE007055 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page687 of 883 Alma: mm Amman Point: at neg-nun a. mu: 1 MIL-s Hum new?. Fromm Mm." 193:3 and Moda' Muik No. Maven. In?ow-anon? 0? W99 from To G) ?5?16 qu?sep VBL ?m ?6 20 P61 Ci 780 3C3 (?53 24 Tee 88.: ?18x -?a?wga?im': 2?1 1 166 .153 $00056: '3 man) . - 30 1? :5 298?? 794 Ml 5mm, um? 69% i 6r- is. 5mm 131.0014: 5 \l PP 61 ?18" 935 A A I 961.; fee 19) $888,831?! 5906 3554:,? {wig v8; 1% ?1 (?61 quqe. (31mm T613 74? ?mm34magmam?wii? 0. 8188? 96: . CW: '11? 38:0? 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'13? cm: Quip" - ?Mt Du?b?f?. ??f?f?Tr II . . gag? 31:12:; _clt?xj ??ling.? m; 2 (1: wk" wz'rlr U7 Page RM I _v in A'nanl qur? foul In Dat- GIUFFRE007062 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page694 of 883 Alum ?mm Poi-ll: 9' bopa?um a Arrival M19: ?nu MuJoi vum 44 pm," I [my run? TI.- . ?Gn?s Nanampg/x 4r 1333;.? . *1 (901:: . [213% g8? ,cha: Imam. \c {??rErakmw-Mywa'glc? ?Eu-w A - Cv?in?.u? 9 .. rm rm ?39.23?ka - -. 303/ Hugh: i Marks, Hunt-u I snowy" ?a No Mina-um. Sudan-menu ol -5 3" 3.. o. .3 rilmn?cJAc .a I . 1? I . km} Km). ghoul $7 SM TCB I 4+1 N0 Max-90mg . I {3 I 2? I I C-M I'ouml- ?J?o?ohrilm bub igA/mg?L?j" 1/ PB): (1141 343/ mmcurmzr? ?Win-?U we at?? Bl 0150;ij cn'muv'u'ru519(cl (tummy (cl- \0 . 1? (1?th VNC. avg?3'6, pbp?ki?th ?mn?ly that the n?ado mo on this mo L'un. Nj?i?? I 1 (46?Nd.? Page Total Azncunl Fr?wnm {1?35??075,441 {?87 we?? . 1 GIUFFRE007063 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page695 of 883 Alum?" MED Poi-l: 9 ?arm Arrival Vila: Flgi'. Remarks. Plumes, Nurbav Myer-? 7 and Mad: dunlim?bn M01 -. - No. Whinindonmh ll LRMl?ai 5sz F222 2 *2 022222.222 W?s? ?2 2 CPI A 1% Gun: ?(Juic- :w ?5 \2 ??00 (25; c1521 (Cum/o r2100 {182? mm .201 Pm Hm?; 9.3.1? 22"? re GM omwt u?wzbobwt? (19? (?72 . {.2221 i [?373 oz. 12- pawn 00?, Inn/n.4, . .. 227 "222? 2322212422 222222. 2222 21/ T66 321, DC) (mow/way new? 4.95?? 13 222 I @2222 22: 12222 1\ 22 . PM Tea 220: 2?2 02/ M22222:55 [36,9 (ht. :m 2?1: 2? .195. PB 7_ Z7 . ._T6f5 cc-Lwh 1/1 22 2~ Tee Eeeow 212222622 2/ I I I canny I'm {no sum-mm: made by rra on Ms form are true. Pug?: Tolul (1 2' NYOJM Forward 656-] I and; ?at/11%, Total to one ECU-5 I +99 3.) 2:N210 l? .1. (4'01 3" M00540 GIUFFRE007064 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page696 of 883 Remarks, hands-rel, NI I Am." M-muvm, Wan-Mn A .0 i . 18mm?: I I hale Nzctaf'. New: Av'cmll Points at ?op-nun I. Arrival MIG: I n'HModol Henll?caluw Milk . ann 0. M07 I rho-'1'. ?rl?o~ - - ?l I NWOBmgtepw Lsu_c:_ Qj??l? A 5" 5 'me - L533: Q7151fz?c'? 1 .0 4 Au Q78 AijC194 ?4 - 96?; 50mm [imam ll 3 01 ~17? pm Taggmg mooqolc HA .2 -- ?111 181 34'3?? 888 1 ML @758?131?i?mt PM ?81Hemw: MW a 1- CMHA ?ms 2 I ?as$241 2? I i Icnr?ny 1-131 ma ?13130an mu!? by mn um; mm unotrue. Pugu ?owl 1-3 .3- . i Armuannrwavd 3 ?tic on a no 5% . Plbi?s I 5 I GIUFFRE007065 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page697 of 883 Dal: 151 More?! M?kn a on Mark? Number 'mn?timhm Mark oil sanding: Miss Fight new Proocduns, Pol-ls at Depart-n a. M?vd 0 W1 Man-um, Endanomontn Allen" mm ID 37:, (Kmart LU G, Cw", cabw muse; ?51 0831:! I: era .599 \o 7:175' 3731?? . o, I) one 1' (way;? t?uuww Inc (A mgv. URn?me-I? ?m c8124?! F3 mm M?scr \Wmt-Gu Logs I ?5243 Smu max. (W 1. 1166 \1 VW NQOESGW. 7:43: 2?9 . yt- y! Tare; Jr Quinn? 0. "My. 006602:ij GM ?1013lj?" GM Womb 6, GM I?mg'j?, H??m?gm MANN '36. nae/3mm MAN 31:, ceunwn, .Iv' eve, camp mate-g we A s, ?045 127' ton] S?l Cemmn M06308 . 2J4 2.3 I that the statements made by me on m?u lurm are true. I . mm. 3?6. Cum-r9 Mwet? 2 {5 '1H?_3q ?6 ($15413 7003 H.131 Amount Famed foul In Ola: 521. up. in .9 cl GIUFFRE007066 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page698 of 883 Dal: Hum?! Mau- Alwmh Foam: o! Donut.? I. An-lvu Milan right We. Procedures. Numbo. .1 and Model Ida- Mark Fluml No. Mun-won. Endorsement: - - .Cro-r I To i f? 3012 :re, Emma MAN-N 1 Q, .5 T66 "theta 1 \x CMH . Juny Tummy?! 1'1 - was LPPG \asggel'hi?ningg?fg {ggf?fm?? Is . :3 -b Le." LGMN ?m3 ?a?f?gnretgzm?an?fjm 5399?, . .7 v? \m 1"?le 6 NZ. EGGW 33331; ?Ea?f?c?em 55/ ?43. i Pet T66 \030 i \Ct \l 1:53 CMH woman MAW, Divm_ - 9.8 mm: WW: mm CONFID en ?prs: ?j sr?w mime?, WW WeTats Cuec?wl/l go 619%.? .q/w - :4 60qu {0016853. P931 ISTL l/g *9 31L pm 561:? DJ PBI fT?? I 3G. Ham'WachNM l/ I can?, mat the malmnw?s nude by me on We form we true. Page 'ml ?3 I 'gc? ?16 .1003 . a ODM :roul to one "loSq JTIAL lugGIUFFRE007067 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page699 of 883 Dn?. ?in on; I Ararat! Wm and Modal Alrsm?t Mark Polnio bop-dun 8. Arrival ?rm to NO. Io-urhl, Mandates, humor ?mauve?. {nausea-nu cf Jul-"gs Fl'qrn Alter-t! - n? \m S?rElemm m? .4 rim?S @05ch T66 Eris; T66 r1 an Enr- 5+5 hub 41:, GM, M/wny AMY, )9sz Beg-5 I 10?? 5 $60 was, ?u E61. T60 WETE. Gmermv ?mew-?f1 fig P61 -599 Wimpm); 36., GM. Gamma C11 1/1 I was . ?5 3a, ext, (may Islam? \Cemde0.55 Ci \1 qu1\; A 14565 {36% 53 9% 96 'Fqurw mama 4? 4? )j Wide/19199 if 16% _l L??i?f SE. DRJWEFB Tab 59? 50? PM (36L ?1?66 V52 5a, 9mm, (5:22. (a 1 i E: 1 11:16 i, \k (?81 T616 134;: [9 (ratio: 116332? gamer ?36; GM, .. 1615 98f- 000p: 1.. lconi'y Um! xl'o sduncn'a mace Day we on (W Mm I I plh"s Signature I I . . l?b_ 5 705?! ?5?41 2n 3?95 Page Tubal A-noull Forward fol-I to Dal. GIUFFRE007068 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page700 of 883 mail Mann um moonw- 5 Arrival 19_ unwed-n - .. Ila: ?own From To Him an. Mambo: Alter-? No. . omen-a?emat??MDWD ki GHSQE) Nab T615 BLT 'val?usual, waoom m; - .u awe-mo dd" Peal ETIGLRW OUQEN, :r embL mm mm Mb mama", Dow lad Mb Sc?c?m w. Tear :96: low. 3%an ?29 FBI IST ?owze,c,m,mlcyux=umwn WNW '25 NCM--.. . 25 50' ?Tae- mm: ded?d?id .3) ?f Hit 36% 8?71 3 New? 1H .. 1m NF BI 34?, em ?if: 96$ ?(36 (a 17:6 1373': #101016: \mtsersoawe?emow - G- c. \o-nmmamaag WM PM . cm [0'13 5 i'T?fb ms: i o?rkqiu 6M 995W, WW pas 101V 14:43? Wm?! . Amount P. 2. 1. Page Total '38 0?25 1 PM 571 Total In Pkls?UIaturo 2 GIUFFRE007069 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page701 of 883 0 I H. n- Avma um Nmu Pal-t- of bop-mm am: was Fm 0, Number I ?out: 19 mama Wmmum Flown No Dec Frum 1n - 961' 6?3 new 4 1&6 (341? ?if? - \s BCT (33f? mhqov' mammoww i? 3.33sewn. 61, Dow lo 5?9 9 1be nemci?,? Mb Meanw- 31? - FBI C: ??S??mer ?15 1: mg; 'S?yc/Y, Genom- ?15 pf}; :51? 34,9?,eslewumwn Ban, samba I I dd.deNHd 7?5 .. wi?a?grualmw 5M1 25 CM T615 ML, 504?- - Ice wa?e539% am: 1.51 35:, eww sveucee. 5?9; ?$361 I'm-1e, aw will I '01 [9 'Tbe: I ?311:5?: .. 96: T65 I mu?'wm at? x/ 1415 PM ?32 p?m?m?a 1 Amoum ram-d ~1qu .393 03?0?? 03:? xvi?u isdAAg (no? GIUFFRE007070 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page702 of 883 Mall! Poi?. ol mom I lull? Mi museums39L ?108 . 5 Las . FIDENTIAL 05__ NY :27, . 1?1 22. AF 3?10?? 21 66 . . 1 ?861.2 4 vo Mow-Ara weomo- ?000 15046,? . V0 PB - onto .- 095 3'0 19) (LLWM n?rren, mow PlooToul Arrmm Forward pwmm?s 631M tot-mum - 1U GIUFFRE007071 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page703 of 883 a whomeme H5m: P6): 06% sWoey'ng? Err l/p 3* .5 \11 Nsma LNA- A <1er 3/3 IV: 1? . CMSS Mariam-'54 L, N2 0494 2 Ln?) I . 2:11?qu . LQM 'W'mcm mow)?; 59.60? 1~ 0?wa 1 I I: fr Mme-mam Guestifs?Mm ?69: ?0 ?8 (a 2 Nuan .. o! Landau '1 6.4301 - EONFIDENTIAL . Teivy-?1' Ric . (9 W31 m2 21,1 MM T66 Bar) 013 ave, :1 1?65; ?oqq tsp, Re?ux) . - .. cu. ?2wa ?Mownw 1?1: Firg?gx?j?ng??. 3:03.53: 32? Emma 1/1 - N40813: MW [?4?pr 0% 3e (new Pat?fz'? Sea-3n (anew KaiAmy-m nim?mm@g??i ?n?m franc mu lad?- GIUFFRE007072 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page704 of 883 Dd Ail-arm Malt. Alum Pom at 0. Arrival Mia Fug" Number ?can 19 and Model 1mm Manbus?le NQOBSE PM 9653 ?Mm"mm? If 1 cm @066" PM 1:1 CHM Tu 113? \8 CR6 i/l 1.61. 5 13 C0686 .NQOBICQ -0 Le 'n 00%. LUK U00 3c, LAW: L-UK HM mm 1.1 Tm!) aaw?e?l was i/lg 259ml .msrm mm? Ei- um ?Imgabgm Rt?ysb??atar'? we Lawiimi?'v "55' 3?51 576? OJ: 605416 106104531, pa; Tee, I "(an mar not: 11 1 msm" Lyn/partway; 155;: P5 3 mega. 981.ONFIDENTIAL ,v?rJ or?ww?owdd?oc?o?mmt -44 ?~zL mm. mwdca: 861) gm. /l (5 B60 Tera Te, Roam], 57m?: Venom? .11 I ?mm-"aw ifa??r-w :34 pm Shaunon. GIUFFRE007073 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page705 of 883 Mm?! Mano Mom: Palm: 0! nap-In. I. lulu-l I . .. Mood Immammu Fiown No. mm. 0?me Tm L3 To ?l (305% iNClosxe Tee 1 PB: 1133?) 52:, ~11 mm; 10 I \n T151 Tee 3? 31?) GM, (58?th \1132ctla?qz?w x5 \s TEL 96 ?34, mam, Gum? 1A 1B . INFIDENTIAL LI 0?03): 1117. 2- ,18 1?63 w? 35 \c mow. . 2o saw Lax ?20 (rpm? 15?13- ?m?'smu?x?wq \rwanc T613 TIXY mc? {cg-r IQ: 5:613? wou- (10%:me T1131 JFK ?7-9 '56, 91-1215st 0.413% ?5 I JFK . na 395%?? 2' Tara I l/ . .23 "4.1?4.3 (3&0 ms 5?3 ??3552. i/l ?23 Beo T513 tut-r35, @3355?? 1/1 T- 2f: Tee ?'15 Path?): Tom C'Podl 70/) To Jag gmwam Pded Ex . chle-GIUFFRE007074 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page706 of 883 - Alma! Mun Poms o! Dopadma I Arrival and Model Winn Mark SUU lTeB 961 2- O. 3 .. CISD Cheuc OUK 0 misc; 2. 2. ?g?f??me 1 aggzmunawo eeumw fW 1/7, I ?3 n? ?3/3 I ?3 I. I emiww 212? Wu new?, NFIDENTIAL 3 in 5- 2:00ng wnu. - 0 . my!" mama Emm??im - 1? mm, 9-: voc?smm? S-QOWJ-W mm; NW5 51,3 3W GQM J?u?gif-OPd-Q?T ws? . ms, gram-Jo (WIW Tram-?Jog. ?"Wmum 39? IV '1 I 8 :33 ?(can Fm?muSAm ?$333122 w: 575- I cam-mm vira-or?f \1 um); Lad gape Whit-ruzm?mb 1 1 $8 I (Lei) ms 2mm?m?a?mxw w. .. ms 2. my ?mu?m I 23 1qu 3134 mm IRW IR ??gm mum SW mm?z?mL 2.5" H0 3 ?0 32137?u??3??s A - wast 1W Mm? numvbe umMnJ's 3? CY 5 CO 5 mw?mmuny?emmq 2- mnM2wm My?; 43/043 13 (Jr?coco rim 3? a?e?i mom Formula 4 750 . 2 Thump-u rag-?1213 GIUFFREOO7075 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page707 of 883 A. I 2m?" Alm? mamma- mum-mum"! ?08 Fm To 38 HI No. Wan-u Alnun 0mm: 61.1th mom; fab-L Tea A mam?, (mm, mm Tee. mwum S'Imugs ?To No madam; Ow $13836: ONFIDENTIAL ?804 6?9_ MW It; \mz TIC: we 1% 3 \Hu 12:6? ?qsd'?TGP?fC?T'M?cmion Lw?; ms ??19 GM, Cf tee P?f 9X31 ?Ln (?le um I?w'sm Q: 22.x! Ters 1C2, GM, .57, {3 9mm Lr-Iwn 2M ?1 ?f?rF 35? Mp (>60 060 2.5 6 ?3?1 Woma- 9:32 mm tepim OF) M), Gmumqn (5:141; 1:1 'n .. ("Bi 8?15]: 1H5 . 6, GA i 7.2. same SWJH um we 1 0.137;} [2th n- Amount Puma-d 9?43-er GIUFFRE007076 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page708 of 883 I 1' GM, GT Save-m "t T: n. m, Han??atbn I Int:? 9 .I a! To ?13% I C: T663 Trs-r 1. mm ?ownm I M9 may :5le FIDENTIAL Em: ?110.1,. 7 (?Winnie . ?3a 1032: 70 (U Jana?0.. I I meT?' 56?3" GU?WDcwi-i 951%. 3'4, mm? 5 KQOu?imeJ Comm! a (teamPlot's amuhgjw i a DGKG Page 1m! Case 18-2868, Document 283, 08/09/2019, 2628241, Page709 of 883 liter-II MOAK- am Points on new a. Auk-I M?u Fug'm Number Ichn??athn Flam No. I n, hum-II 023 From - Io 1.9 ?$69 \woum sxsew? I/l T68 C, ?nuns-mm ?Mauro OLD ?Mle 3e, er, (?0am Raemfwc. ?a 3'6, ONFIDENTIAL MT u; (5mm: mord?mgr, l/ Foch.- ?1139569912 07me m3 :2 36.0 T60 (it: 91?89 .32.;5 A-.. .0 .. . - T63 . 37;;em,et, ewwmx? Beat. GIUFFRE007077 CONFIDENTIAL . . .. ?f T66 ?mum? m1 ?54 16.6 \m ?59 Kn? jg; (j W?nmh?wig' P31 ylemlcum ?Flak, en" Marat; ??x?959* Gt. I v" My 36,94,641 (?mags 0.0 C16 was itwmx?x. 0 L/l am e? 98pm CD ach'G Um Pans "(an (a n" .9 I. 0 Amount Fomard gig'i a; 13a 58 mien-00 GIUFFREOO7078 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page710 of 883 Dong um um Ara-an Points of own. I mm PM no Numbtu No . mum dumm- 1933 mu Model 1 WM Gib-29? Manama; C: .20 6:11qu N809338 1151moigcw\ 3* ?an T68 P631 .. PM 1 W131 33? 5093558 57-0014; ON FIDENTIAL ?6 1131? :5 sat-w km 0&5 1 \?fS?l 9/ ?0,49wq56?55?4 Us Pm?? me; Ln'z??amm?mfi'V q- _V.h 131.32th Lo l' 60? w: 52., mew? 359% \107 ?343%: my: \q PB ??17,345! 3am) Luge ?as 5% GM 121, uwm?WI?W?-y; 626 9'2. I dT?lgx?j?dmcg 1m 3? 0mg . r. 4 .22; '2 ?q pk? . PM 556? Mantuuvrkw wit): 4 I ka R?ifggk??! PW: 2. I a low?? 90% em? 9M0 0 ?Manama Mo?s?w 9% Poor: Sim-mtg) (Mel M33711, if.? r) I PIgoTold H1 0 ?511+ 3?1 53 ?3 3 mun-u 9&1qu bi" GIUFFRE007079 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page711 of 883 and Model m. Mam No Manta me Tb Mmu mm mm Pom- a noun-u 1. Am: tha 'hgm Aha-n M??r?u 51096?) (7n? 4: I _u uJ-ph 5 6-1646 'w?Wt m1 1 1/1 24 . 0%?7 206133 [051.8 10ti A, - Advama/ mane-av?; 9:414 PM Atop-M; A-E/x/Minfc 1, 1[ a ?91. {2:15ch . 3% 32.9%? WW fem a; 0.95 3- (AMP \l It ?4 Wis-N 962; \Mf? ?ling)! ?uw? dc?ld .. ., mm; 1? I: WNW 44mm) oz ?5 list-1200.69. u'lmoH vnY ?ao WY im?l 15 10?10ng ?98?mag sun-ma qu? mpv? ?rm??ww lL??5q_5 I rm 3613 1' INN ser- EL '53? T528 m?tepnn. Ta? PG l'LlU magi mm can? 3'0me mm VET HEC t- I 2.0.91.1 5005;; [mp 36mm! 9- bma 2:53;: 1/ Pay Tohl y: 323% "Wot-l q: Amounfomm bl 7.. [Mi magic? 1., 4 ?Ml'bm ?msNFIDENTIAL 920000?80 ?0 UL Ii. 1. ?45 Oman-m. ll um 7.4 ?1 ?lthy?LL?62- h/l? Noland] Wimuuqsmuoow?qmu fh_\ . 9 dwc) de mungm?lujol 4. 7, (cm h" l?wmang aw cums mom 41E ?fiwa'vwmomwn a, .91: 95:7; J51), 9133 1,6: 0 175?? EL l/?J mm; A . S. (?90 069150! 7?31ka We . ,0 ?3691135119105 vamo?g? ['90 130 92? 3?6 p?mgva: ?1 I 1 1? uwmnu: 2% ?@ka 9m? ?h b; jaw a :19: 33%:ij (a my L119?32: ?Eva?wi?f?mw we 01$ (L WW 301M 9 ?0:5 fy?. 13 A?m - 339 AM: ndo\SN 7? run ?unnq Ida/?haw fig 95:17? 19d 725950501 7 ?(my/44a r/a: q" - 17?51?7305 i 7302 {.7/72 3/7 {fatal of-vfo-Zlo?j 3"?sz 277923277925, 47 (904?! apr?Jj?r/ lb! 137? ?(I?Yol? 5?0045; 967 73v 3 I 4-5 :3on 4345??; 16/1005 I . 1.3! 1/ (ff/J o?Wd- I 1 I I ~13 my?, 3mm 9 wa-M?W? New ?who?c -. ?0 <1ch 9.2915 Mrpha(WEI ?76,076 17 $103130 um . . ?mm? admit?: mmuzlm ?Jam; . a T. 888 40 213135in '131728292 '882 '8982'813 3393 GIUFFRE007080 CONFIDENTIAL GIUFFREOO7081 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page713 of 883 Ann! Make Miami! Point- ol I. Illa: dune, Nunbu (nappy- and Model A Mm PM No. no a. [nun-mall(ad?1.00?- mw cu goose 1 :W?j?fj?wgwi/ 6% 1H 6am 333 not, L?s Socsp; PMPHES ?>me 1 it 3/1; mm a T66 93 H21, ?Lou-?a?ci?cTC?EB? 2950 ?wm (1-1 gum Mow: 1n Law: (1 ?l \zl "\anR?w? 641pr '3 I I I I 1/7? \k mm ?want?: To me 1?1/3 :1 ?1113? Tim e?maimmfwif??i?_ wanLUZ. pa 1: SC, m9 mam. um, HM . . K. Mg) (Jam. Iii-nu: ?\lg log?5 gocaj?m 34.4013 scam ~m?Pm R4, 34,503 52 cym?s ?(71:0ng ?2 v?6 .5 ?9 PMP 134% fo?zvcn 9va N?io?m'c Tea P81 ms name chm?w 5 . m9 ugwbpi?Pnp'lohl 31?) 3?5 1. a - murmur: Whini) OLLREJ Manon-to ?ng 143.50 I tn .30? (?19 - 4 90 H?co. GIUFFRE007082 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page714 ?Numb mm 1' Hum To MILO - gammy IMPM .2. on,? FIDENTIAL - A xv?C?l rv'c. i' - "if, .- ?95? . 3" 1:459Q?fv?l?h 0 PL mug IV I 0.97?. 1' I I I I Piot?a augBQ W4, I -. - . GIUFFRE007083 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page715 Onto Aim! Make Mud! Pol . Ms Dog-M. m: Flg? . .m mm mm ant: Modal Mu: Hum Ma. [Mont- :1an 0464:} "106; 553(WSW Kb . .. am rm ra- rwr' 3 1/1: 05? L.- A ?21? 33.6.7, T?-ynmg (Rf: (TM .1 MisgI?P/?I?c??l?bs 119 Jb'ffmg 2.. r?l EJFIDENTIAL .Iin'n'rlflur .LL \c - l? 9;?hW on Vm ?only? a? FPGL I V153 3. PB (LVP MP 17: v?A madam PB): 135? ?f RQEQMZD TC Ipsug?oc?e COM mv?? 7:10 gnaw Mame Tea PM thc'm?h??x??m g, 2a m; n57 12m :rcv?w: cf 5 2% mg W3): '18 01? Vim )1 629*47-9 :7 mi C197 314$ 313,630'cg; I ML 98use Toul mum ?ah?tb- . i . ?all; km??Jr?'7 GIUFFRE007084 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page716 of 883 \Vb? - . . .-.- 0 . u- utifw ans. . . Dupe mu mu Moran rum to a. rod-ms. NW Alnnluw? - 7 ?1qu an menu cumin1LT 1mm Mum __Ysr'wy- 9M GIL(332 3(4) . wl 'Zfl 8msenez ?Exam 3 mm; 106(04)st 853 58' 9. I, ?355' . ,5 11-}th mam? kWh/H batman 1 3 ?a?Jad?jff - - 13 PAP-W 16 DAM 1/an ?Hwo Hwa rue .. for ?kw-A i?m?g?wmmamw 3/3 ?3 15? @916 mom T613 96159? I351 L90 (>934? . 1956136: 0pm. 59,9 us-d Kev - - 2 ?5 PageToQ-l A .Amomlanm 1%1541? 3'5 95 (3 I rum?u. a" m. GIUFFRE007085 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page717 of 883 43% woman Mm . Imam: PM To (1 PB . 13" 11.6.7? m? Alum Polar: Dov-dun I: r?d?v? . DENTIAL mam?m~, w? . ?Tasty: v, . .. .e ?35, 28?. _\95 -2 . - . WA. 32147 Wat-Au. ?1 . 2.3 - 8?10) ?lm?69? Momma the ammo made hymen 1M: lam mo Inn. Plot?s stun-turn GIUFFRE007086 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page718 Doparhro a. mu nu rug In. .V Mum Aim-n 19 and Modal Mu! Ham No. ?as o! Landing! To K: (3w 2 .2 Flam (1-1646 Mossy: 9M 5M 11. WW 1 439; 5 ?1 . 1-(?nut IQ .160 (13 \3 ('51 mu ??re?m ?mgezmz 1A Tea rs I) ma Tc?tr?ap??aL?fc?m EWL 2[2. 7.0 41596 98]: VI - . ?36" 5e,emw . 27, C3411 GD CF22 RL?New?k 2'5 f?X? LN ?3 ngf?ewwm as (345% Miami? \z?ssmr?m' 1/ I. ?lE \l Tgs-r .TEB W312)an M, I ?if '1 1'15? ??138; T3357 \1?5'6 qt! ska-um (4:1&6 93?!er 5??2 Emu" T68 6 ED on, ?mama-1; GT I oanly he sham-1b made by me on his form are Imo. Page mu lb/ ILI - Amanlf-?avurd :32: 151% vhf-mm 19:12:?. Eat-r1660 0 g. urn-.- erm rr?m4-mwMV? 5! 3 ?3 We?? GIUFFREOO7087 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page719 of 883 Mum Alum-n 1g? rum ?Miami-Arrival :01: . From to L?l G-usq-e PM j\ 0 ,ewam lb ,13 on, more? ML .1125? T68 ?i/l 1?:8 981' 3; 5616M, ET FBI T6 ?34:6? 1? 16:8 m7 3:410? 51' anwmeu 3L PS: ri?e} ms 3e, My ex; cuam hamBan Ska?w, mm: Lew? LL '1 93: Tee acme-1&1 4/1 1&5 59F A EW- 3?5 ?can?: 912nm?gm: X5 VNY SPIN 1 13d} . \3 SHN bag 3 13.: Kc. Mi. Bee 16:. M. mama?, MIMI ASL 16-6 sc- V: vs: ?0&6 1w; 50? 0. 96L TIST 'cm er so? mm 6m Pagofohl ?lNnou?Fu'wud Pal/:20GIUFFRE007088 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page720 of 883 3 Nil-Eh '1':th id?s: 7' "n z: i @101?; .., 11-. - .. Palm 0! Donut". I. Arrival Mlca Ruhr - . I 0? . - mucus: mammalian mm No. .., Mme-ll ?11? o-usa'e Meme Pa: Ic-r I -36: J63 9 WMWIM <ms Tee 5m: 1 I G?mmcw+wm 59; :37 my mower mfegf \16:3 BI mt 1'6, Some mom, meme CONFIDENTIAL 395319 (?ng on?J'N?i u- ~Dm?rr- I :65 31353?9 99;; 16.0 Hemow Tea 1131' wt 1'6 he $69126 ?ew! seam umm ma ?mu? 9m 9 Mitzi:21?33L7-rl?02unn wmec?ctn?g'u?w (ml-Sf)? 31% .343593:12 11g PIlota svmum LE T341 . mm. ,3 2 I: i Nd??d?f . ?wr- -v xvlT??I? 4. vvw? 3] GIUFFRE007089 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page721 of 883 om Alma?! Malta Arum Punt. liq-rm I. WI and Model khm?aatlm Mark R15 From To ?map CLLp?lzr: ?chum": 6091-0 sec? 99.1 713622222?82?" 1/1 1 1/ VM 1% 0w6'51 . '25. mew? 140443 1 mwro A 0' La 8~ 206L3 72m gif??i?z?l?h?ip, W?E?s?m? St ?1 mm All-mu. Numar Ilium 3 3 a? DR 000035 M3 533%} PM . . Imam 56 - 20.1123 mm 35? 922 ?0 ?m4 106% WW 1?5? 0 _m we? . PM 65% ?ff/?111. ?mes? alt 2,061,: N7LPH Lme i #57 4 a 10603 NUPH [151' I me _0 $00503 1012.914 \e 109:5 Nu?? lFu. \3 2.001;: (?743 v; mesa BBL 1.62. 2.26m MM Lila/077,1019, i/n?vul- Mm x-zvp m? I 0003 07.95% Ger-?mm 13 ?ance mm We: H7): I a 2 lb . remud - 115? .11 Hm: Shannan: 1651M 6&4, rum to on. 51"? 1?150 3W ?5 A ?1 64?8" .2. m7 mla'. . ..v1v [yam $96 v. '4 *m m] mm GIUFFREOO7090 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page722 of 883 $m$?he Doll? 0! Depart-DAM"! mm Mu, . mag?? ?atworm-u], I: (TM: 7a!? ?that 23 9.951,} (013:7 m9 23 ?lduL??) N'onw A '1 L- PM 437% - 'i - ?imam-ru'mm, u: 317:3) N110 9" 5? 8* 7 9531?? 1/ (Mr DR _000036 934 PM . 15? .l 1\ ryq?" 3:4 . r" v?sw ew' J: ?Rgr 3 ?97; .mazW-?uy/Q/z? NW my? o. 3' Pp?w-Lm?Vm 'me30/1}? ~mP/p72 4-2 I6 'i ?11 .7 ?if 7r. at?" L5 3 1 maze, r" to .. Pi7l? ?M/o me 1? 543/ M, 37"? - 14 PM PM <7 ?g3?mj?f;?f mu .m Cm Su?-s F-vfrmo 3* Gms?n?s 9M. U6 i [?93233 (ire?M II, '5 9H4: ~(?lrk Ar ungapdoy u. ~94 Hm .LVDG?ffinuMcs. um haywire- r- i ?has 155? ?gm-aw ., -, T646 {?02 :82, mama-a.- ll 98 L. mi: $783437? .It? slatemmtl mad- byrmon?hlotm amm. Pag- Tom ?7 1?3- 2' Cl- ..- 2.14. w? "1 A, tun). GIUFFRE007091 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page723 of 883 Nun)! aMModal Minimum Mm? From To (mm 6 Nat/Ma ?1:1 T626 11:6 9% 6161135: ,2 sq; :rel 55414.67 L?wrs 3b 126(3) \ow 13m (?$3va 3; \t mow 21?? ms Zr??m 5?1? Tab - )f mama? .. Tee ms 36,6". en Wen/M $1 was ?aqe?'?rGM: 59? (3mm: M1 5 P0 [gwj?- 5% L95 1,3: \l ?t LBS 990? 135T63 1125?)? I mK/Gfg?f??g ?76? WW 15' V15 55?! gamma W?ffw?? 1' - NF Pug-Tani ij? an $229 mu Univ-I {am-w on ?aroma; M11 9? D?s-no 06?637 I 33 u; Ila F: l" GIUFFRE007092 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page724 of 883 -. 0m Aluminum ?lm-all) arts-chum I 1290 0' Fm To I DENTIAL 0 ?Finn . - - GIUFFREOO7093 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page725 of 883 D-tl Ammum mm mammary-Luna: Mus Hum Imam, n: 1499? ?Model ammuon mm - No. . A dundrus (?wooing/L I H?unwi G-nsm N?Iou? 5'99 it" V1 \h u. 3 MIN 2:?1383 16,61?, BP "584 3a, hf; CHL-RI Km CM ij/ Bu, Jog?meant), 3.5 menu-1? S?mm 1 1?9 ?56% T?me?N?f 7' 15? 'Sm T5, VI '3ol - \l T157 PSI Ram I remu: ?31 was 2417880?! i T63 9 61? 36,53,214 \b i 1628 m3 f?rwh?f l/ ?3 I T53 l?C?F?r 1.349%. For: meg ?3 LGQ LCPB \3 3% Von Hemmer 0 E0 63 ms 3?51 l/ I r] .. .. ?61.53 8 13:11 I6. 5 Bea Lew/:3 1A GAO Piot?aSiana mum? oo 182: 3-2051.- 3 W?w? Tut-nonu- [(3235? ?1?15-erAA .9 turn :1 LAW- GIUFFRE007094 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page726 3174?13.0: ?ax. >4 f" .1 .44. . I'urAluminum umn mm. a Mud lMIoa nun mm Alum 49:: I ma Mood Idonllca?an lurk Hour. No amount: a! Lam: 1&0 5 1 Fm 6mm Glam. Hugg?' ocrl . - .e-unsqa Moss-re L69 4 News mm am? am mm 1ij 3W 'be 1161 \Huz??lc'm?g? ?vuR No3 lg, EGGW ms 291' ?l (568? MP @3860? 1: Par; ?6 ?do 36,604} 3! Ta? P8 1: Me? It, SWLW p31: 1-551 Md?jelsaeuxz?r Lam Jessxza ?1 1157 T06 jel?ww l/ . 2 T53 9933 PB): 59F NB 380?? \b .. 59? vw wire-IMCT 1/1 - J1 VNY SPW .. SBA) PBS MK, cm,? 6&0 tum 1779mm 1 Pagebml 55 (2 W?mm 213?: 1?135 InmaJ I i FPOJVNJ: 3 3 ML GIUFFRE007095 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page727 of 883 Viv 3:13?:ch Mark Point- nl Damn I Arch-l . . Number Mm Cancun- Horn Th 08:56: -0 <39 LEWIS 5 cap, sneuer 0C8 P61 6; ISMUM 965 ?GM, (enema, Mx?w GM FIDENTIAL GM, I ?(eLLtf I676 95, K347 swarm "fun :77. mm 6mm, 5mm? 6,61%, ?dummy was SM T495 av PaooTota' AmmFomud - 0 .. $0.132] GIUFFRE007096 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page728 49: IndModel ammunm 39?0 I FM Tc Mom: Waf- LCQ I VI 3 (?mac Her?mam?! h? 11 LC-Q Tea 8 3 ,Gm,?r 1 x1 1&6 962:4 5; QTac??y Law 1 LP 234?; 96: T65 MK 7 5 2.3 12% SEAMLLW Lawns I (7 7 7935; . LGPB sacuev L?st 5,1 c. .. ES 2 2:12 Tea J: 191.31.; 37:,6M,e7, vmawm RM . 2 31.4.37 1- NH MN {?511 Cm. vovT Dem smug?) I ?1 45 LC ?Efw (Learnt, SOSL5 . \Allow 5a" ?$513 "2.1 ?u 6115010 P0): ?ng rem 9551' m. se?m?-T, vmwce Raga-gas 29: NWOSGM DCW 1- 3 3 3 ?~3ng (E14. 10 6 . 113.105 A ST I ?ew DmiT-Tanpb_ i MC (?nuns mun-.13 ?wow I- ?gait, M6 . - e131? ?1 Cam 70:? an?? v! 6:46 gator pw 0 :mmuo ,4 . a syagzwl page Cuco't?l. no.? 1? MC ?1 ??400ng Mad-m Xv- ??56 53 Panama! 5-2 has. I Alum Found 8?31 3 3 (. 3" PM. SIWWM 14.. I I. Mo 9,39GIUFFRE007097 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page729 {?5555mm1.?w . m" I A?nm? . . o! hop-m. I. Ann-l Ml? - Ion-rt; 49: and mad tdanwuum Mun Hm . ?may - 1m\ ITO 8?111'2130 mm Gm 0316 GLM AQW- gang?? 10808ch D99nom- (smamwsum LQ-L mus-w W15 ifs?g 135m?? 0? mm 16,9398 mom? ?m 16 3f \W?chr?m-J, Raf? . 0 5% W8 LCM wt? "Us? 7 I NFIDENTIAL me?v??W?C? (JE- . -. a- MTV ?Y?nom?c-q mt momma?won rum 0 - I (SM-fr 5:06?) U. EGGW BGK 3C1)Crl", GIVK 1 Th6 Mo 5?70?, 83% a 4m em: CLL, .45.: L1 D'JNAo?m?oomhwyNuuk 023mm :5 61646 .Nqocmz was 3:5? 461 1L LU XML I 39"? 3/7 H3 Mounl?anl 3:3 Flanagan.? lilyl?m?.? 3 5?52 883 GIUFFRE007098 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page730 Kw,? A ..-: . 'w def-wag . :23 ?Ital/vi": 5.3.03? Allard Muss rn - 0. 5 1L {mamas l?onl?adon Mark ?own I 5 5mm: mum? ?10? I From To .. 56:9 Madam Lao um' 9559533:qu V1 :1 I \5 LCQ E751 By ram ?ng MM 7 pm?; ow, (?gment arm?975nm I a cm H644: and u, 1133? ?Wimp/ween emu.) 89mm ;4 115T . 4L rear: 11, 3? 1?4 :L?wew PW'c-vn 3N9, Zl?m? mac3)me 1% pg;? 32W 355:3; cow-m 1?4 ISM PM ?m?a?w?g?g?mm" 1- (HEW (LB: ?(68 Il?m'mw 1/1 7. 16] xix/mummy kl 60? P93: 0' ,9 l/ ?l V820 Lag tum-37:; M, 0? ?froxmr?rg .I LCQ 17:13 mm?mm 3 9g: loamy (3 DI: 1kg 3e, MQUVI ?1 .. Te!) (5gp qq, :16, waoh P-o?d-I 3[ 536% Amml't mm 8 mu. sum. Ev>adld\ t. E, 241% 2 3 GIUFFREOO7099 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page731 of 883 '1 Nmm? rom- unclean-u. Arrival . -. . . umber Arum cat-cow on. Alma" Make 43_ an. or unmos ?Mow Fbun At?? mm (.an HummL I we: 7.9% From To ?a G-us?? Mime Bee e6 ?l Tao Fe; Gums PBnew. 5.242235199823338by?, 35', SK I 3 9s u. NFIDENTIAL - if mew 3" r~L . I (Who 2% 59? wig?51'3?, may ammoH1139 v] '5 ll ADS 33, J0 N05 kvb?a?w Rand-Paoonl .35.. I WW 5333 I?lbs @951 33311 P?M?wmwm 12% rot-noon. 8:111 IM ?1 2' GIUFFRE007100 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page732 of 883 Polnh of Departu- Anhll . Idenlh?cn Flown Na. 25d I Fran 10 A (r?uc 2 611540 NQoiq-Q pg; (43,3 50 i 59,0 T69 4; .e1,.cm sedan, to gm 0 961' MON 1 1/1 MC. :2 com; ours" \o (i OS 30m?! Mm 1:61ch 1 ?3 (Jammy Man no?! Momma . 050 :Vg \l K. mg no Pmsbuea; ., 1; #29??wa 0 ?3 1M5 Y. mummy; 3 (I 99"; peg?W ca wum? Mil?L"- GNV 1mm": A5653 ?4 EHWB N?t?qg 1y.? Veg memo? I I 10 c4451! (3 N?idscm (36L ?W??9?4?fm5mi?-. Lyim?l? ?1 1/ 75? (,quB (?O?c?fe ?63: .957 /1 li??zm 10%?an PIG Lan 1' it i LA). 19819:. mum, 0M: u; QM 23?? ISM er 1?6 I PB): T68 ?91 . Imw PageToul I Amount Puma 33 P?bf? $.9an . mu In M. r. m?m c9 '33 GIUFFRE007101 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page733 of 883 Alra?an Make Mann him a Dona-tun a Wes mt! Modal ldontiiombn Dd! From To 53; (awn-3 LCQ (oer 963: 5? gym? a Gamma". . (362; ?(1:51 T66 T613 gag? Noam\mmw ASL- ?1 6-8 As? 37?9?? ?kmw? i/ 1 21 \l T63 LWO ragga? emcn?JgslA-h wast-12w T/l 7.3 L690 \sn l' 35 Lav?) \fLle 29 ?t L?i?b 51? A/l 1% pom. 37:;th 60 MM _l 1% L991 ?(my {5.25 <21) NM (0 3&4? 1751' 98]: k2. 1 <5 95;; W36 ms 16 (?439" ve?mw a $60? 1 was CPS ?we 9. Panama] ?711+- ?mm" {2'43 3233 01 3' H2, 9 Pu'asu?ma CW Tenn-on. 315631 3 GIUFFRE007102 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page734 .4vDan Alla-an We Aim: Puldu cl ml ?ha .99: md Modi- Idon?bdbn FImvn flat From To 33:0st mm? 113815??Eff? . 53' I-T?Eyyx?azxih {ludax?if?! {351% Gm W?u? 1: demw Tet} In. a 3. 43421?3! Moisgg?x mm? 0-0 Gan-?00 Scum l? "my? (x 35536 io?m? its 1335*?; i/ .e was su-mmwwu (3-1214! Ncw?m; 1.68 why L69 ABQ 2- mIGMaET,h7,2?Emes '71 (-4111 0 96 3h MM.) 4 1? JD mm gag g?kmm?: (5.. 9' [Ma Bahama?" ?71 u. 8:60 MRO ?lo/V? (dz-m 2&7 Emma NPanama 29' ?1 a 32 - MM-.- 534% L. .. Mohair-11mm ?vv?z? d?wdmdimf, OJMJ OG?qu?an?bom- ?35431 GIUFFRE007103 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page735 of 883 Annl um pol-u oi mam Arrival Woo ?ght I s. Numbor All-mu I 27:3 mum mummy: Hm 1? Hm Ma. 0 ,lndoncmonu ?Landings Mu . - 11-13?? 96f jay F: 091? Vuwz WM Cal/we? 51m? .4 H910 95): mm If .21 ?19; 7-5 H.- \l I 1'15; Ijl 30 G-xxs'm mm mm 3/5 $67 i 313? Mme Tm at?'mf?m (~1de JUNFIDENTIAL I Tqrij MP: \l . 5 I7.- 31:,cn ex, BRII ecmfo 53.1: ?3 35? mcgou?e V81: \am Is It]: . WM IL: 36,0?, I ?l I If C?fo Lim r] I 214* . LFPB (.qu 1/6 25 NW . ew?Mu WW I I3): 70 _935, qu 1? Jo, GM, sm?ww Mum: L/l PM __aw 93. 1,1 warm 1/ WM .TIH 9.3 No wwevoms? I I. ?do -. Nnouu Farm! 0 mm SIg-num [20 ill/L $311 IT $33) a 1 6?95 r- ?9?va a )1 -I . 3?13) 1' 5' I 33 UL GIUFFRE007104 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page736 of 883 0818 le Am? mm MM m? Hui 19_ Model - Milk m? I . amt,? 9' Man l-xtmm 1 1,06; :Iom To mil 3/3 5 mass? El 184mm N?owe 37W LCQ wnmyoaas a: (14666 meme ?81: Tex?? Ash No mam-?v AL ?t was 53:16. 58520? Kenmg 35 .. Equibldm?x?-bm?? ?7 4 15m" ermwge . V) ?l 66% . .mx?mow?/ ?7 Tan? ?4157 Farm; 7 1&6 m. . ?wmm (?51 LCQ Katie?s? l/l . TGB am 3?95? 3" 2 ?Te-6 3L l/l 59f, {Ase W132, - me vs: mp?wx 98; 3122,51 Bamvwm 0557CONFIDENTIAL . - NT luv.? Cz?m?? 51.9.7? :77: an ?Jr?fi/ and <09GIUFFRE007105 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page737 of 883 Dem Mail! Make Norm rum: cl bounti- I. Ann-I and Model lamination Mum i For" To G-nS?ie Nqoqug LCQ FBI 7 u. 965): Ta? .1 v; W613 ?05; 012131 LGQ 83:92:51 2 /1 23 LFPB (m5: 1?6 Sela/'imL 3o SEI?-?owmo" 2% EGGW ?51 A 1L. WSW, 31 :2,ij ,1 '50 u- WW 915g 33' ?ax" $855 Pk}: 31?! ?ta/AK? 2? \5 TEX NW 31328Alm? Axum/w (rt-Ema ?e141 04 i: NFIDENTIAL 000051 111-"? f3 Subr (Jerrwm ?ohw '1 IL I \g I 34:1an Cmv)? 3?15" 9.9.10.? "Vb - 3 $33? Wm.? X0 .- nuance 21?222, 1 1" 5 I A .JI-F. A II 1AM mm GIUFFRE007106 CONFIDENTIAL um. I . 1: LN Silo/nag an? nL?m wnuuwr, 3/ Case 18-2868, Document 283, 08/09/2019, 2628241, Page738 Gum: Hit-ma Nfibf?b?io?ko Who ?Won INK Haw 0g,? WW - mam muwanmaml ?zoutoh 7. mm macaw ("hp/macs ZOMO Za??o 92$. (Mn-3. ?moxie 0va P81: LL . Main/1 ,sxmp1&2. P131: 36111! 11 psi m7 Ho 36,6n?s?eemu?; ?19 116T . L. ,c.m,sx 19w, gg TLVL. (?Bj merggw '50 9551 fig" Lg manm 3 FIDENTIAL 000052 - P9 Hg 3591? coal. wm?er? Mat-9R?, 132. 46% (00103312 M: \557 F- \fl, \l 98; 322,01Pam?l?onl 9T Moum Formal 2112: 81450 "magnum [ii/?i rout-om 9.5731 Qualn i 31 in ml GIUFFRE007107 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page739 of 883 - Dam Nnn? Pol?! 0' Dow and m??m 103?, To (3317'?! qu?'e 6&0 .15. . 66:0 MN Mm: 8an war M2 @9132. . A 1:51 PM so 8520' 'gplcaggiksff? 7.2: 98$ emu ss as$157 a; 54; H~ih?f? 112:?! azi?zxm :46 .9 MW 5 .E'K?fb? 13$) L??b LGPB ?530 i 361%;511 :1 (2659 B) . (coow Tb6-0340 M10859 PE): 1591 31': Wi NH 96): is? emmY Iouutyhomn Pluc'loid (X Amour: 4 Ef?? Pllol's Sinnlum dam} i 14/ L4 ?511? 1 r?gf? . ?3 3 3 Kw :r-Iorc" GIUFFRE007108 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page740 of 883 -. I . J- 1?33: Dale Arm (Tm Alrcr?l PM To Armada[vague PM may 91' I?m 91,11 \1 MY j'Gt Magyar enactiw), 4: VN 5134- 51 rd/l 3 ?r 3?qu 65%;;sz s3?? 1? I vs g?wm Meme . ?l 1 I 1g; 7.96 817.14% N??o?e 31576 6): amtr-L? ?95111?160 M50 M31), 6174. MW I 5 A ?Iul?? 49", 1 91.1300?: DB nay? LI I 6564:?? A ?53103 hr: PHD mz?mslg$151 13?: awn. (unites 98): .. pg 1 3K "1?1 mac?7656071,,mwmwo, Ll 3?94; 15; ?6413?! 00"? 60%, 354mm Snag-Lil W?q?hf?? mama gin/VJ {94901404 - 3 3 ?55mm rot-noon. Mr (tam . '1 1 \m ends?Q ?~1nr?plfo 3 Td?vr?ddr~1r~~?rd? 1 3c GIUFFRE007109 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page741 of 883 If . Duo - Mam-um mm Poi-ab g! Duo-run a. mm: was I um nan-aka. ck. Nunbor um cam-a- 1-19: and Mode! Idcn?uBm Nut Flown No. Man don-mom. To 2 ?Gun (3-1751?3? Nacm?e PB): T167 .18 C: 5; 1157 A 3521?? 9531 ran 33% . 394 <33, 36,5: swam! Lem 10; g?et?Lcom?r? L055 :30 Law 0mm? -j ?Waugh/2L? ?6 1 ?1 ?New, 601169? - 1 wear-gee or ??gurwr?c ?p . ?0 ?mad-?0m we gua?l?f-WCUE, 7M: cm 4'6me c-M- we ?mwomim. Fawn, (Was: 31.0.9 an . Lass apir?hn-?u-v?! . I 1 Page Mal 3% Hm saw-row WW 1. ?Ivy-5.4 3 Amt-om 851?}; 3 H1. @512; "(as 3 3m full to but. GIUFFRE007110 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page742 of 883 1?21 NQW Dub Make '11 m1 Amt Which Mark Pain?. 0! DOW A Arrival thrift km 8 c. 45%me wai?i M30836 gym-3: PBSL ,sx r? 3* ?rm-3x mace-5e k; \l ?l . 6?5- Papssmou :S?pmsn u, ., EGGVJ - - LFMN qg 9.0 \l UAJN TB mm VH WW 09.31, 633%?? com? 7.667. '10\ ?sMo?M how's 26 S7. M55 1 (Sam as ?wt: 1855.; VTGO ?251.130 4. JOB shine as Mb? 5 Mo ve a A5600 WBSB ?05- S?,or,sa( 13 .. mom j?fcnask 9.01 OM06 '50 ombB LFPB .. LFPD Wt IGMAL l/g '1 i?g?lw 631? no {items razw nmil On?lm?n . Pine Told 1 . AmmFonw-d W1 an,? Val?I A. M- l\n GIUFFRE007111 CONFIDENTIAL 41 Nana! Palms ?Minimal lamina-Ian um From 010931LFPB Clan-L..- f\ (L. up} 024?.wa LFP Case 18-2868, Document 283, 08/09/2019, 2628241, Page743 of 883 I I )5 MU ?warm, 2. Loft: 8' as 2, gin? I LDC. IS :32: mm emu?e TSQ DENTIAL GIUFFRE007112 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page744 of 883 ?lures. Mu: About! I. Gum .snm?cnnw I-oP??l- 1 Dale Mrn? Mlle Aral! Paints of bop-1m A lulu] ?an '13- and Moth1 lannifcs?m Mutt Fbun a" 5V5 arm-3m N?o?ase LFMN ?g \3 v? GMT [?5ch ?o?t?km? Mmewuww \3 mm; - ,st .41: 2 . 11%. . (30 ?25 ?Marv! Roboc?a 630;,- ma?a?, N80831: I P??p 1?59? L1 EMVY ED ?34 ?gouremur Li, I. 1I I Bap ?Qs It: [53, ?5 6 (a NmiN?dc?! - ?3-6316! 0 aura-frr r-r-a- or) 2x9 mm a? H??r Lice 3/3 log-L6 Lysine neo- 3111803: 39% 39,36 m, (LIZ-arr 1:51 Pm: 0 11'! [mum cram g3? r] OHS-WW5 Iqt?fi?SG 59? 162?8 3936/ ?25 ?l ?1 961: sat/TIE?? (locum, (emu, R?mmw 19m: 11:5 5 ass?w 39K \23 1&5 ?3 Lofcz, I \Dd-o- Amolcx'crusg mm 53%- ?23 GIUFFRE007113 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page745 of 883 Date Ia_. mamSana?); N61083: LFFB ?638 \3 x98 v. 66.8 [3 9 COLL-I 3 LF96 391K I 7 3m PBS "3 1:67?! a: - 1 ma?a: . 2 .6 6663?? V1 3 (3&0 ~63 ?55? Se, Lauiis was Ta is?; $313 3?33?" kg 1' . TLST me 16;? 0? mum N61 0952 JGK meL \3 17. 06% 071%? ?n 13 ONQQ 3% ?222 wavm? Wop?tz'wawm 0 DNR :3 HRYR . [351 ABM 11:55 RM ?dk'lu.? 94$ \t BRYK FQMQ lqo same '55 PLUS 5M (lb 1: a! 690), ?Mg ?is (?5ch 1, F9 Cy (+55 591% as anew LLbe SLCL A 9.8 . . WT W3 ms? 22W6m? swarm 75?- ?u .. UH Samzrr" gen 40:: 1% Dom? #4550?? A5 WW ?saw 5/ (53 Amount Forward 5' 6558 mm labmm??z mun-?- amen, 0! humor. ()0er I NFIDENTIAL F?G?Ks?cpd) rh- 6-4 1 OQ de?LO?T?ddidd?i?g BHWJ oo mm .9 5?0 :9 GIUFFRE007114 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page746 of 883 Dale Mann Male Alma Point: at Doparlm I: Arrival and Model lamination um . ?4 Fhun Yo s:ra me 1C1 8113.17? Ir 01 0956 L686 EGGW 1 . 660w 5 .Lmjm?vctf?ed Mansionsnw A an kin/Vb'samnm ?l LFPIB SFK 1% 3? 3 THC V6 .. Nix?x. MMu/vw W1 (Kr/mm?. new gem?, 886% (3'61 T68 We anwwn, (Kw ll if. Mh??c? {'merz? L'S?jks srw'cru: tGOMaaw SL2 l/ 1 Isu? .96tit-?t, Memo wow i .. mar so J?Wkr? I I Snukn?m rm, mw?izw ?Evan/rt b, {Low M, rmttuu- no mm 5le 3?3) man?): 136%?. curmgum?lm I 3. 3w? 39% $0 ?romia wzm- Eff/{0061* ?3 yam-4314 ?:16le wrg/r} agent, nNonw Mcr??uw 0151? v.31 [mi-P) pew: Low) 00-5 t} p; $15.91;} (a r? MW 90 Luv/pa. my?; Drier/lama PMruvlr, Gabi-?L N'u?olp a- u. - (74589 15-31 1.16 ?Uta.? 1T if ?wh?furfc cw}: 5* 9" (4,4 ?s Tee ?sr . 1.- 0pm", M'r- ?-45 (VJ ?Ij TEST Lu]. 6. I (J JD Ira/.1317. Page Tow (dick i Amour. Forward 3% 3,GIUFFRE007115 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page747 of 883 0819 mm Altm'l Mall 01 mm In Ari-1n! hall? ?lm! 313:5?, Aim-n 43" Model ?ad?s?3?. U, .1.7 supp?"111st a: - Lav. an 1/4 1:11am Mv ?121 mm- wr?ncww?ww c- hf?C? a . 20L?u mama M?wmwi? 11 151:6? - \Lr16: whit?aw{3,33 )6 Aj?{\wk .. 11:5] Fm? ,Jb?f: 1M Elk v. .. o. T?k?vic), at: . 3:3? 3 1 Hy- - it}: WALLS) p?m? w-gt?wh?(wry-$0 ?w 0E PM 1 {w chy?w a may 0 h-i-mmz?qtilggm?m ?me . . . ?the may . 8 ?m I - 37m WW PAgoTo? 7Z6 ?'33 38.4% . x. . Am] tot-mm [53? T1 INFIDENTIAL ?4 ?1 Lo 73" J3 ju? ?Maui? n1 1H ~c?1 GIUFFRE007116 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page748 of 883 Dale Arm-Mm Mm" 'vomuoaomsmu mm Hm m. Number . if; ?m ?mm? ?m Fun 7. "m on 0mm 15mm Heuquf 37"? dev {"61 mi Mtg? A 3?5 Mean. m; m: ,1 .. 334 {mm ragga-1 I .. WNW ,m - 2.8? 112% age-Mammy pguuo, muuimai?thwu ~21; (9515975 Ncwma {?01 B-m an 1, v35. JNFIDENTIAL 1:0 of b! mrk?g 3.1. um may, GM $239111 . 2 21?- nanny, f3? ?b (L mum?) GA fm??Q? 7. (r1- LL ~mw - ?1 1? j?i Marin-a: mam: . 43/533: 2.1? (L \t P8X. I Ylf? ?p?rxg} . - . 7 L?a? 1?;th Wt mama: {manor 0 ma, '1 CY (30? Vet? macaw? ?mi-pgUTQX r5; Vb {45?3? a a - . m: 3H. 0?53;an ugpmbivng "4 j" . . ?vmo wav 0.5 mm 27;? \k 3&4. a 16?} 23?" L2 1931! 2 {3 am ?'60 La: emu Ll (6 . 3:13; 86qu - GIUFFRE007117 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page749 of 883 A . om mum Mam Atom 1g lid Modal ?pain I. In!? 108?} Pm HounNo. imamBf'IZJ-jil ?mm/yenm H. (542:me I \f Let.._ I 4mm men-615% Ncwne v. mm; MT T664 4 \q 661atria]?! (4140' l/l 7:5 15 961 L81 :rc. GM Tet)? Luv 5K A 9151A arm/3m 1'1 1* 36% we; mm, emamw mu Mf?f??-v (L <1ij {3?1 A me 5 I- S??e \?lo #5888? gamma - ?v?c tn Lo w' L696 aamm mw urn. 50mm? G?te?l-Mc- loamy PIkx?sSianuun d?t?i?f? Magma? Pm 1b? 3/3 Amour! Forward (3?10 315; ?10 I 5 H3 Total to Dal. @333 ?.mr W) DNFIDENTIAL GIUFFRE007118 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page750 of 883 . '5 NW ?at0mm?. I. Anna-I and Mood ldmIIuwn Mm n53 From To . I 1, . 6mm \xetw??- 19 kh-Wzmamwioegg ?Lf?gz; 9.61 um?- ?$0153? - 5 V5 G-nsao ?26166136: - 96"" ?g 1 5 1/1 1 17:13 teLIv - K: . Imv T413. 151413 5f 1511:3333" 33$??an 1\ Mi M?l- mm 23 mm 599 "3353% gamgm??w 74? 2 .2 Tan 1555?!? Jury IP30 . manner! avxmic?v?7?\?/ ?500030120131th ,pawn: Ms 43 u. (\umM-mvmm, Mo manna-v: PEG-VS, V). CQNFIDENTIAL . {VA-qr? :r Nd ?(Ozprz?qa 0&536" Am 0 ?ova-n) . II 1. NO uxtF??g?m" ?Sgg'ineagbm. i l' .. x157 mam ow,? I - . . Gunman T161 34* {\qggt?spm?mr?ml MW 3 Pawn? 4/3 3? am MW M?s-Miami \On . .1 Tow-Chm: K??qj Qiaa (n GIUFFRE007119 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page751 of 883 Dale lemh {'13 Moog: A'rrn? Point: of mm". A Anlwl um I Nun. . From T: Form. No. Roman. PM. We?. Eudora-amon- (5:121 451 (I sue I It m0 395 Astrait?dN' -, I: PM Jl-tlam? 1" in L151 (E: a? I I fade. T6 {3 I 51.? -- ?4 [832% 16,8), 30-va .351 op?umow 1:47." 'mliv?rcd'. I It?? 174.9") . T2267 :Nqugm 33m? 015%. 9:6? mm: 31.,3 15.x, 98f I UM ?1 ?1?56 3 333? 3' ?l 18h jams?. SIR CYUL i Is CYLIL 95:34! .. 9913 WW I WW lea-3 gal mugs, o?wu?, (.174 0\ fa, A kit. Sign A ?53 1 :3 . ?45 IchL I 1496.25.20. mzv?pM?K \fc @639!? 1). I441 1d? 343., (ST?vain) l-?Mr - PF): 9.67 It, man-mam 3.51:: ?sxs SH 6 C1 i ?04:31 a I was" i Tc? _f51 1045 Jaj?k? 5K .3\4 I SH 0/955 {(5,513 M. 5 H, I i A cadiy tral Ihe statements race by me on the lam are lruc P-N's I Page Arrow! i Wa'd 1 Total to DalCONFIDENTIAL - r. Iva? 537.53 . -. GIUFFRE007120 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page752 of 883 dun. I NJJM I About! A. on! Point: rim .. Ayn-Inn I Mica m9? nowatmo . . .. 2:210; a I mgq?sznoIMo-uk? now N?n. Man-aunt's. Enlargements whim? Fvun To r. I .- ?If I Li" {inn-WV Njocaj? *723"_ 1?51 I 00; 1351 Mum GM E: .81 0/ 1. L55 ?Ji- 1L 4% DR _000066 ?m 3M E9WWA ,5 Al'bglz 06:! {Ezgny'u s- 'g is? 818%wa c4 II EDT?u?xx??f io away; ?51' - KILL ?5'40 P) II II we 10 80?, 10 ?4 4 7-3- 2 "m 77?; HM'o?bjc/ {9551. .0 0 1x41 403003;; H991 (.?33? 3.?Lby?v? 4% (an/Ir13;: Ly 8 2 m, m? cui.va?iw - PM mam 9J0 ?n ~74? l?nrxmoLow-t Mr? lowly the! th: 51a omcms mean by mu on: this man axe Inn 8 ?3 . Mag} VI 0 1 0350C: 13" ?1 . .4. mom- 0mm ?151 37% .23. Case 18-2868, Document 283, 08/09/2019, 2628241, Page753 of 883 . 5.. (I a" Mun?! tha M?d If idea! ?Human Mart I Fun To I LIP Bil/1000609 I in; :Iinu_i_L_Is_ N_b:r_v1_t_c:m mu 0' - MN 4150?; 0 .I 6CD L..- Iii/:0 TCB I um If)? I mm?: Abcran Canyon. (x Lamina: zm?Mxn 7_ 0i I . I IMioa, 'rugm :Flown No Manon? Mam-Ml Palm. or Den-ml. I Arrival 9a,? ?with; i ?0 1 Q9 ran?Mo - ?awn/ts (3 ?zwi, 1"ch J?s' cps-95,5,v 1.0m}: VJL?puuxgIBM ?bar?s, I06): CONFIDENTIAL ILD In I 7 I . 15-? Inf/?13f, GIUFFRE007121 CONFIDENTIAL 513:6 is; I I Kn__3_ MT rJ Mi? mg: 0i, by; \ww Punt; C-I I ?6 i - ?Hbi? z? \w T5: 3 "r jim 51-. I-Ta'u hm M151 LAN-K. I I I canny that he dwomanzs made by 'm on Iins tom: are Ime. c: 0 Vi? I Faun Forwara ?I/w Sui _5 3 Total {o 03!. 1391 r. 7 - EyengIlngz 35 11": - .32! 13:" .Aa "vi-R 1? GIUFFRE007122 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page754 of 883 le?m??dums, Ill-nun", man-manic T65 . mp?m?e 3&7; 397C 9557;, 5?NON 3v; [21?1? Tr. And-"M, 5K 3913? 1 1?1! 1x: A @531: PM 2mg: mugs-13?? . '0 . v.2 g?i?l?ll ??g~ta??qafgg? 1 ?23\ I ,5 tr I Own.LL. 1 ?35pm, E193 JL P?Mpk 1 . JEL T- 18% h? 63?8?? LC I _veh PM 16% . 7.333%? 331*? I IIFK 3.3L roenlty lhal (he s?mtomeme made by me on ?nm mar 90. $71:ou [if/F Duho APcral? Mabzg i Almm?! and Moon Mart Palm; 0' bop-mar- I. Min! 0-: Hg? No. 49:: Alum"! 8mg wax-1m Fran 00m; 31? CEDNFIDENTIAL "t5 0" 3 (5m Hanan Pauu Torn! . I Amm memd A 9 Told to Date GIUFFRE007123 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page755 of 883 I 021. Mm" Mum . Avu'nf .49.: m1 mm 03mm Mai: 1-35 . lF?nm 70 ()?Evjf; 33%: swarm unsure: (3mm ?me? "38:31 ?3 17: Pm: :23) l? .69 f- it: 9:?36 Ii; 3? 0 4.. I Points 0! Depnrluu I. Ar?vul Fhuhl I 0min]. MEG Alren? . Flown No. We ??ndorlmonh .3 . 3" Lanangs . -1 25 2 YBE- Wide?: ??2233?? ~153th mm Rubia 64er ?mm. - "?93 54'. 103192323355 A NFIDENTIAL DR _000069 [900839 TV THC ?394 . 4m?? 2. at - CM .93 "98; 374-1; L__1Hv)m I H- P?i m, majjibKi?-AE?f .1 . Tax 159: H5 .. ?17:6 we; r22 52., on.? - we-? .. HST PM. Jay. (3T (19% - - 8): 1 :53 ?38:3? X1. 1 (53.15? 131328222377 MC 1' 5 .. PM .2222 . . :5 pm): ?33% 34., :0 ewe4.41:1/ - i u_ fag, 'xt-m 514 KL {1,ng 508 $7108 TL. 081? 39$. 3? 5K 3? fa; . 39? P9: 12m. PaQaTo?al (01/4: 11g '6 I at .21ku ?wn 6 3 2L H/?j d1? Cal/J '61? . Iroguaonn. (~44 311'; l" .. - 0 3.47:Im Ihc mndo by mo lam are :me. GIUFFRE007124 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page756 of 883 0an Alrucll Make Nlclafl Point: 0! Departure I: Arrival luv Prat-games. Numbu Alter-ll md Moo-cl Mn?k 0mm Na Mum Sada-?meats or . 2.ng nan I #0 ?325 palm: 3576:? an?I-?quu?a?Yx P?f I g?\L 5? I c. Mme) Cf .27" I PB 7? [81? 7M8l? 2852;?) TO, 2. I 49 e-usqo mar?839? ml V213 . 18 I ETC-R Tifs/ L. 5K 1'0 g; T03 M33 jug?: 33?33ELY) [qu LY (5?20 WSW maumwm'). LV 5. - 1&0 qulab? Bops?k CONFIDENTIAL . ?Us: I {?6f 7 1 H4 SK :ma was gnw??Im :2 5 mm BGR 1015a Aw 31? 8 I1 .t . 60"; L3 g? 533251)th1 8T 10 AW 1:ng '5 g. gnu{Vi 15? (MM-.51 tV 11.. mm mil??MK a: I r, ?w {\ng 2573 )4 . ?1 39?. 12:5? NMISKITD (.155731.: TD Iv?LOfin) Cm? 9, :1 cun?y hal Ihe slaiumulls made by no on IN: ban an: hue. Fans '1 . Arrouwll?ovcrd ?6th:: ?53) E51 2.. w. . J1. TollHo but. I Li'xy??u, (I I chic" GIUFFRE007125 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page757 of 883 22-2? ?W'Wmm- I.l?url? . - - A 73"} . - TU -, l?-mP-P?r (,me ,H?uuc?l?f .351 8? 0.137: B): T6328 22.47{cf-3 1e58- . 9 . . . has?? 1- 8.22:4 <i 7.3 I 90w: ?i gapnpw- uwma (la-.7 WHIP Ma Gr; . 1? -. 1" gafzsm?cmmga Gr; ?210 $1320th ?mg {753: Lv . ;6 ?5 .n21:_ w: 1 I - 2.22.2.? ML 129-39290"! 22:. 7- .XFY- . 199:, .751 23;. 'o 21%;ka Tisj/ 1.5 . "?0?853 jg; Hm; by ?42.7222212238583325322?21m .- ?vmm?til/g - . I 36$?fth 2.2; I 2 F'aJe I'olai 90 339.2 - . Amount Fwaustun-ma 41:1: ixm?y Total Icellify WI alalommis made b/ on ?1-3 Form ulc true 1 GIUFFRE007126 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page758 of 883 Dale anm?t Wake Alma" Points 01 Don-nun I Arrival Miles F?th ?Mnbor Alva-ll Caugoryu .19: and Maid Harl?cn?on Mam Flown ho. Mung-Ivory. ?04% Fvn-n Tn QTR FLRM GliDuL meta-5e m- 2L3 {.34 l? 121 {73?3 St?c {my 3 13436741351 . 'Taia? :?fm F1 ?53 L?o? mf? ("mp/m SK LA, pl! ?u TrevL099 mom?IMAIf?x; 31:3; (:qu 21x "f U. 11? (its): nm gory ?l_V 7) 2\ II It Tap, LV ?3 1 . p.51; ?nlbx IN 2 H. i I'r?s?r .f )SYSl-g?af: Li 7? A . 17:6 \va 07,14:ng Lv 08$ l?V I ?1 'si"Tc-:6 86:0 L.v' 0" 5?7? ?41 ?4 66:0 LV 1 mm ma (a/wrx\ 5 made by me on w: torm no mo. peg, Tom! 7/1 7: - 0191 - . . . AncuI' organ! .0- Rint'33gmturc__ CL JICA Total lo Once 1623clip .mm GIUFFRE007127 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page759 of 883 Alrcra? paint. a Daparluro 5 am": i Mlle: nqu ?nishing, an: MUCH Im-r?m?cn MM . down No ?mowing. Mot-menu "95 {To {1 1a Vw?] "031 1 ?mar Make i Arcm'! MM i jiw-Cx?n?h?j?) 1132101311 T629 1 WM) 113-3544131518" "'11 3? .mow \5133?11 be?? qow? 61 1 1714 SW39? 77%? 1433: Wm 5?13? A A DC 1% If) 735' ?3 ., MT 711131 12:21:: - r: 1/1 9.11- .. 19105916 T435 11135? LV LAG . 1 x2?) .1 3?68 J?I'h?ldz? 8L LU . k?I Il .3331 \k LPJS AIM. 6?1 2? ?1 LBS ?g?o 8V. Xmu?nr$983? 983/ ?3 3" (W?s P63: 112154 54 3C (1R ?5 1111111 11 41ids PR: 11111 ELEMT 1? 2 233:.? CONFIDENTIAL 81111?311 M11952 P332: 711353153113" ?4 ?37? A 1 1 91?73? 11 I we; "?63131 2.1054: 11451.51 ?whim? 7.5" .1 . 3413'? 9311? ?3 8? - 533?? I r151 i Jim 3?31"? 2.1 \1 L696 (4:90) 32:11-34? \1 . 1 1?5" gag? MM I oarm?y' Ina! the statements made by my un a rug. .. (A {ht-'1 (ZPZj/er.? 1 Amnuzl I'cvwau Total to Data :13? 5} V3 Ci GIUFFRE007128 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page760 mural: WJKC Alrean 0! Departure Arvlval 21m: gamut? ?pco?nt, . still-ts Alvonn . . lawn . gums. hiking-Inn I I ..od 14mm] Marx From To 0] DLM "f 1111-1141311) 1111' 8013;; I W92 ?37? ,251? ?4 TD {.15111-31 {Igld? 119.11% It: f? -) Navy :1 ??031. 13"? 111111 ?1 ?18151?; 113% (- Lulh 11,. 11.11121111111 EX 35119,}; Mfr? 711mm?;? 31" n-1011 ND ?1?1 1 CONFIDENTIAL .1 -1_1?1 3.3231311 \1 *1 11 . 061 6100131 f) 1. 1/ '3 517:1 V6109) VG I 1? mun, box) {:11ch Lb in jg? 3&1 NM. 5% J?x, Mvw-?N Lin 1 A 2331.: 1 \x 1 725111; ?10 (311131.145;? mat-11, )1 I 5%?0?12? 1,,1 314111,. 15111 om. 4031.1? . LL '761'1?1 ?Ch 1 8777' A '14 mL 01?11; 111w? L0): :an 1:11:11? ?212111.. 11911111 11;; 1. . 151111 1 K41 1L .1141T'rk.? '11? c5111?) Uul lhu statements made ?bk/2 I I fj.? 1: 1* $1.911V/?r r< l/ AmnurtF'JIwa'd It?ll}: 1.13313 Ki? '1 (151.11} 0,2145% 10m to auto U-?qq ?S??dq .3 ll?} GIUFFRE007129 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page761 of 883 4; one I Anni?! Make I Ana-an ram. 0! Depukufc a Arrival Mllos Ito-wits. PagoAuno. Wm? Ural" and Model .. . . ?mm mum.mnmmemv Lawnas . i ULrqu-L I . I Fm'1131 33? LMI IL ?1 a\ I L?t qu?sl Li; I I Lem ynw?bwjommp .1 1_ ,s LIPS ?ULigS-i?i' '3a?5_ "Te PM 9K, om ?27u$59.. ll. 4F. TV I .Lw? . LL: 118187810131. 1158..? w: . 115(?63 IT W) ?m 36?1'31 I TL3T L. 2' . IT T123 T_l ?am radon0?3? "1'14 i'T?l !w;u AxNi {1-71: wuL humans LI tar-13? mm 1:50 warm j??c T58. PIP 1 f) TEAS .9151 h. 133:155138? . . I I "1?32.18 1nd); 1mm ?$214 I 3 1 {136mui'y Ina: mo stalomom: madu by "m or Ilvls: luun axe Jaw Ida! 7/7, '3 3: \1'7 313 An )Jnl Fu?nwc .. . pm5 111754 [?61 M14GIUFFRE007130 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page762 of 883 om Amen um I A'rmll m. bop-m a. Arrival - mes am MomI Immznon ?3 Flown l? Fm i '38 G?nw? 1080936. . 20 (?ham-my N?Hoaje Agr'fw?x a "l 2.0 :sax 1 ?61: 2L9 6.20586 N40135: @611 NFIDENTIAL {2?14 ml. 3 \i Ly 2. 2.3 flu-12.7231? N01094: TVs-r (KP: . Eg? 2_ 95-1-21 smu-um .M Harm ?5 Col-W4 1&1?ch mar. Lea-bu?: \5 Pt I ??cx ?hu?m~tubm~w% Mum IL 9 1 ?81 [Tm @3883?? 2 i 2.: LU 16? rbi??_ NM, SK. 30:0: amou?f?mr f? . '50 (SH Mn ~201me LV HM -115: mannm. 2 Lv,? :33; G-xm? 1-7-5? TQFF huts 1 TQPF LXML '5 05-17/5, 0. Amour! Fem-Id a, Cb?3 "mm each 931% ?m .. - if." 1" I gimp-1722? o- 3} I 3803 GIUFFRE007131 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page763 of 883 Date ?Perl? W10 NW of Dopmlun MIMI 49: and Mariel Idoruacanon Mm .- 72421; I Foam 10 3'1? Gama 9mm; 0: 85W 3 .RSW bi; A ?1b 17 "1 dd 37; 963); . 7157 Number Allen? munanqs .Qx?vmm ?34-0111173?]=mwmiw . 71631 koncs-rxsw? Mame. m? ?Zr. V1 W4, 1? pgi Tpm- \Ts?gicoLLeg-?J .4 f! LA L. 28 (?0?51 Z. l. 3m .. ma) (?nals?v.95}; 37:1 gnu, 9mm . -. jig: .325 >24 \fl . 337557 R175 (?rm-2pc M139 MFG Wg??L-o?eo ?tC' .hmhm. i W318 R10. Run" rm.? 3 (Go 16c. 01?! '1 M119 (345% maria? PBL 5w mn?er? BM 3- MOW T523 nu . BM 'oonify mm the made by me on Iotm hue. alga?l'cml 0? I11 DJ (?2wa v1 C- r" 5 5" d? Lmnoum Fem-d nun to but. 7? l1 GIUFFREOO7132 CONFIDENTIAL 51141?? 12-. 71,? Ian? :lL-ff dam?! cam-1 Ma ?k I NH 595438 My w; - . VIZ. . . 1'51 Case 18-2868, Document 283, 08/09/2019, 2628241, Page764 of 883 Nm?bot ?ndouomonts o! Landng; Points ol napalm A Anhal Mics Plum F?wm ho. - LL91 IL 3mm Tr (O 3'3, EJM 3K CPA 013 - 8:1" ?944NMNL 3 lampm, .5 3133:331?: :e SK TL FM IL 91/ "\cil 55:110- . 135 ru- .. IMP ?Liuyiyzweeaiv; L0 A0151: I3 I cutliy mm the slalemm'r. made by me on 1 :ls low? (no me. 10(- f'w - tbsmucmz 112% nncuw 5 (210.2.- 1 i i I Page Total Alslounl Imn'd ~i w- Total to but. Case 18-2868, Document 283, 08/09/2019, 2628241, Page765 of 883 Dal-J 1111121111 .1 Dopathre?Anlval 11111112; Huh! Rmkl,lrocodum Am.? mdNuuol ldonl?z?caxbn Mark Flaw Mounts. I 2055 I ,3 11an in? 91;! 1. - G?nj?m 1x15101111 gm ,3 311191 $11 0 T613 ??1131 ?11: AM 08 1365?; Tax? 1142 322135311 1 . 17/1" 791% 1.1-1.1711 GM, LEN 421;- i 11 EFL 1519)" 171111.111 11111 I \hmbor 1- f?zl; 1} 54151013511110 mt T18 11.1.1158 13.31? .157? VM7, 51K M981 1311 [50 115-5111111111) "1151? T110 11.1121 .14\?1?14 811 81.1 BB ALL): - 1? 13?; 3? 180 QM. 1"th ??11111: 1 $491012": KIM nus: 1/?1 111 ?11:19. 113111111115-111316 1?11 1:11:14 NM I 44.- Lv?1 1' GIUFFRE007133 CONFIDENTIAL - 16:1?? Fmi 01% 1.1/ 141113 112.18 -11 1113 1:5111?111 ?11 1 11:16.8 13,111 31,113 GM 811 8 611'L7?zw5111uwm M110 My? 1 11m. Lclza ?111:qu LI I certily 'lml 11w ahlerrenls mm). by ma on 111 3 [can an: true. 6 1.11;: f1 111 0511 . (391:7? ?34 ?33 10 Page Tun! A'rounl Form-a Tu. al On ha.? GIUFFRE007134 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page766 of 883 93 . Du: Alrcan Make I Marin Paint: a! Dom-Mun a Anlval M?loa Flignl '-nm?r??Mes. . Nlmm' I Category and Ham! .uermuaucn Mat Room No. mm" Ewan-""5 . My. "in Ll Luau: . 32:22" 1 . Hum so 7 Amara? I HU- 3" Ig?ll__?zm? >w?gif": ,j?Uth: f" (1.1-44: Xvi: I Tim 2 119,1ng 32?. *0 SEEMS I am [fess gen (?$343383 1 e. mask i NFIDENTIAL .I swan -0 'ls?ggi?m SHI If mm, tsnx?iss signs: W. 15' 2.0 0 T15). 1993,: ??52;gz?qun??xgtvI ?i (.1ng V1 1 9.5. gym); ?was rs. Scumgg DJ .. as so as Imam? . a :1 - {56aux-2:21:37. 22?, 'n TS-DT 1?4, Ni: T96 661?? [33.1 a) I pan) Jug; GR 2 71/ I- OQU 1193; GM LV 3? I 2 56?0 NIGEL _1?;37 3e 08G skfasx?pss?LV ,4 3m (mi 351 32123431 039K C-ll \l cavity Nu Mada by on Ihls Ion-n ara line Pugs low! LI {3 ?z .. 5 "mun .arwat. IA l?llnl's Signatua #35 [dd/27" xaib?' I Im r" Total to on. (IQ-SUN GIUFFRE007135 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page767 of 883 :9 Onlo Ancvn?l Make Akrn? .Polm- o! Depa?u I. :Mles II um Mme! kimh?anlivm Man- ?3 Imrkt??modum 1 Wheaten.- gnaw-moms mg, Tc :5 Mun- c.5302 'chua - 3?3< A 51.83-15.30. :5 _m.Lmv??cMIV mm; . . 7? __55 13:5? Tea 1 ?as {fl/M 3 8 .5 Tic?Ls: KM 55 ALAN ()Qk?y?owz_ 4.1.3} r, 5 6CD 182+ {Mi-w 5 ?at) 111.8 Ira \q B?nnam A?u?d? X?l t% 3 g; 11?- I. T5457 -, 1%;ng 7? 5' 3 25315-8?! MW #5 14mm Ur A: . a. ?35 A :soLu-L?m ?12:8 BED git 5:5: 33 756) as? _55 <58 focw DEW . ?af?wmm \t - . ?if: ?555% ?\ij ?ll/J" 5 1) lwqy??; T528 win"; {34m GM 52?: .5 *0 0 1 TLST LIL \s?mcym anw Tet?) is 341,0 \5 Tap, sag "se5cvrnu5w5sk q' 1mm?, mat-he slalcmonls madetyy mu on #115 mm 310 true. p.198 .53. ?1/12? 561 Allen? Cutogovv. CONFIDENTIAL 9?1- 0? 6161 (09m, - .- . Amount Forward 5:"(53531 (la .02! 5Q rs?-rr r( GIUFFRE007136 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page768 of 883 5 - suoqrannsul 'n-Awuutc-tom 1. 1" dc": I Pol I tm?k?v I Miles Fig? Remarks. Ploco 985mm k1." mum UM ?Tmi?T? FM N3. Maneuvers, [Manama vmws?a??e 1 51?3? . .7515 - 5i - - Dale vaaP. "aka and Model loot 3?32? c5 415 qd?i-J?L 3&6 Egg-?n :YasL . 5 Mug WM 4?12.- I A __5_55 1% '2 . 7. Ta? m5?; 93% *sts_ 26232121?? fit-Tr: 25455 . +2 .5 50:. .AL 00082 13 #45555555nmm 35.55.5545; 5 -. M14: . 1?2? . . 115 52113 . - LL xg ?agrant/0N9V520 it} 1?7 55 86.0 W151 I _52 LC- 5 lb 55 16:6 .0261 01234137" Laxor .- .5 9- wwn? 2451255255wa 3. 7.28 '19. via 5:550me IV ER Had: 7m Est?- 74 l? 1% I I :aeowl - made bI/rnnonnmfom manna. A :ij 831? I mm 5.5. 55. om :E?gif? 'qmo'o I ZlSk?l?? 91"] LE fi-gifln?) . - Pllolx $1ng 55 . urb- I GIUFFRE007137 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page769 of 883 I Polntc Dog-nun a. Mind M186 F'lgm Mun, ?ochl, Numlm' I Aircraft - Fbwu N0. Ianouvers, Endorsements oann?ma Date a: fron' To . I I quwIirGl-M ??1,564 sq maniac 11:53" TQL ?4 ?gt 14?6 TLSJ 33? :1 Airman .l .. Mark d1 B-Tll??quwse 333? 3L \l EVK 1P 03:} 1 I . 3: E?sf? Elil?CLJN?ij- Bus-'48? 40:? b? Agw 3001.?60' 2 '1 0. 3?5: z. 7 an Ii? 20 (madam N80956: 36K LFPB m?i??mm?L - .30? 5-5 2c, .. 31258-86!? 7 4 15 7 Bee-R795?? 4 . EA 3 2.. agiliK TZST s-n?ih?d?as?l??f?I?muW-t? w- mum.? . .I ?r ,u WW314,31? 2+ 96a . {at A 1151 39K 36236-ch17?37?7?: 3435.83 8 11 34K *3 5KD5T 394 .0 ?1?3327 . 39K EGGW 3&3? 3?31 I ce?lhj Ihat tho made by me m: ?in are Ilua. mm: . .. .A, Mir-n4 ouumnin-h G. Amomtfommi ({qu Pilot?s Sly-33mg Io ?3.00410 'l w- . GIUFFRE007138 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page770 of 883 Um; I We Nrc'nlf I Point; ol Departu- I Arrival I Miss Fl! th Remit. Prue-cum 1 Nlrmat Ala: Cd u. 49!. and Mam menu-cam Man I Flown Nc. Maneuvera. Indus-Ions a 350: mamam? 31H N?tome E?cw LFPB 335:6: ?10 10 . LFPB JEX 3% :56 SK 'r 271?? SFK PM: 45:35ka ?Em A 4 jfoL' ?$613 No! OQIC: (DBL T157 $533+ TIST . SK 'jKM-Louun smmumv H: TAB gm M?._Le;6 6(3ij me! GM ?1 EGGWJ LFWH meal :w I ~28 .1?qu MAG-W 237.22512; ;Lc6:2 eeaw new GM \71_ WW CGPH 'Hoz [a [Cf-f QL -1 cm): 1. .T?g cm 3W a 2L 33 $5.33 27. A M10 WET 3?16. 1K TE 3? Mg 275 1?4 [Nqoq mMmmeV 2- 1' {11.37 .360 l/l that lhe atakxnocts made by me ler are true Page Total n. $7 is Amount Conva'd 29'! ?g 60% 0 Hal's 4am Total to am. ?5?01 3 we -M M. nmaw- We? a? Li aye: . I if; 1c? 106?? {?fm'sw 3:33, (my; WM SI 190'01 ?3&1 Q) I I. LS 5/5 JowOn) ?xv-1,5,4 cum smwams euuemsweol 5 r?wg?ygalh um? L311, 293501991 meagre {13$ 7 ?1 r? murmur] mama 2131 as?Nm7)??L911. . 7V A1 mvy??m?g?gdgg?rg HM i nu am? 273-?st mam-9 QV - 03 A UZLW {<1va . 75qu wow 1?30m 334;] Oldh 0 mew-J ox. 3X34 7.399.". L3 I 3 ?WN'zx?es'E 1913:; 999 . (Lassa saw. M: .s 1?2 A 5s, away 5571)- . 9/ ?5b Li?g?iWWh Mfr?5913 <u '0 a 5?0 . .s C11 (?go (\wrr: Mm?a?wg?w?t ?27.15. 1.x - ?00 M) 0 when 9 i \2 S. 15311"?52 I ?n Alw?f?zs?fa?aga?ifigagu91% was wow 9 ban-9 2a ?vac-19 W?nimk 'on wewuemomueu somwwn 22:6 ?Imam-a nanny mum 'umw?twmu mu mm IMM?Dunu?aulo uni-at uww writs-Laura y; 888 JO '131728292 '882 1U3LUHOOCI '8982'813 3319:) GIUFFRE007139 CONFIDENTIAL GIUFFRE007140 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page772 of 883 - 6:139: Amati Make 5 Alma" Point. a! 09mm" 5. Arrival Mics Flight loan-rim, Procoduns. 3'00: Alveran 40?- M065 ldcuh?cn'kn Mark - . Hour No. ?ndmmonn 4! 1(151 From To A (gt-50:15 mo?se _3ng,? A ?Et?gaE??E?? 935cowl?wQ we? my?? buHus??w 34 1? 21 LFPB (56R 0353;; 1; a .5qu ~83? mgc?? emu?m wane-M Tum, LL53 . an \g - \l 5 13.37; W589 ms: ?5"?ij E31 u- men 5M: my ?36?6? Qt) 5:51" [010 . 0 5m. . Eo Gaxscm N?totamwngi??15ij 5W3 2m? VJ, :3 Rm" 1 6? ?Pi? B?l'l?lr?loo swqugc A 1MP(4143" c013? wxups- I verily met "19 made by on this Ionn om Inn I Pane Tomi Armed cm?m'd ?58 Tow to 03!. 3318:8718; A 51 r? '62? at? 0. r" A 1L1: :31. (W mm GIUFFRE007141 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page773 of 883 suonoruasul ?ight Rm?, museums. Number . . - . 1 unih?val 01" Amm?w? NM Ham amounts. Endonomonh charm and Model Man??mhon Mark . ?1051 Ftorr I In 1542.14?; TLST use Jm .LLIm-?onuug? 4 '20- iTl?Sj? PM: My i i0 '9ng wk . gm Zia??sag Nc?O?T??l?v ELLST AWWL 31/? Weim?gmome <2va mm as cc?12, s-ns?qa 1151 s35; BBIML gwre ca'xu? H33~1opnm svo?cam?sL 319 La 2 Cr 7&0 was; "Siw?jogww 5W Bl -343 - ?5 ?8 uni???3,1105 . .061. PB 1 622% ?82.223 -2 . amxpe thuef?v?? {Awe?Krafmwv, PB). l?z PEI A ogre-HEM:- . ..7 eww (tpm? . 95$? 9 3 I 4 ?#234! ?2:02:45? \t ?3 CJSIZKHJ- 4M ?5 P131 . ?w 582173? be f5 (3?8 1? ?who - 6'53?? (?7qu I Md pg:%r . - 7 I Tau mt? e60 09w!? I . I Pb) I: van- 541? mummy CUNAIDR: 97w on, [501111 that the slammed: made by meonuns torm meme page Tom ?up: . guru,? \n 0 (- rlc'xe . Imlg ?lo Np Amwnl Fumnn: 5 iwlno 9mm ewwm [Mm 3 Publ?aslgl??llum . in. 1ng GIUFFRE007142 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page774 of 883 Ahn? Make Palm: 0' Departure A Anlvd Mlle:- F?ighl Romain, Hocodunu. Nmeo! Alrcm am Mam lnr-n?rmnm Mark A 2? Flown Na. Manama". Endorsement. . o4 Landings (lei Horn To 6% 541523 (BM/mm FTD Baum aw, 'rx F9060 mpg/472100 . ?3};ch .0 1?7 F006. (If Mr 3 antic venous a 9 15m, ca??ium Div-1.4? - 91. Eli SFMULMGL IFG 0 'WWe" 339$: (mime Na ?cfud p?o?ffo Eu} Jig-mam ?3 2; 11131 (MW . 21 _3 igm ew?? 1:5; WI 7:3? 11A 11.0__ 9532 ?24 La", ?a?L ?5 CECQLZA: ??95 LV 20 ngu?. PTK may LV 2 ?61114:?, Nam-534.: 1cm -?wrz 8.1, 5. EWK "$1251 1:51. _9 4 hogs-?mama MM FIDEMTIAL BR 000088 I ., 3 Jung 46?. 23 153"? 11? 9? 32:7 5522-55.. (-22 Rm~r - - N339 . ?ggm?hx-ogcacf?xu ??59 Nqoq:& 1/16 ?qqo qun-Hu EWR ?63 ((3.31 '2 I :enm that Ire statements made by me on Ihl: tonn an: the. page ?mal Vs. 3 I 'lnrz Snomn rn_ Ammll?orvgd -1323- ?11: . fauna on. ?o?hb (823?, ?5 3 it; GIUFFRE007143 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page775 of 883 . . . .. Nlc'ull Muku Mean Faith of pop-nun Arrival i Aim-? Ollogm . . . . i Modni Hort Iowan Mam Hm n, . An?pmlu: . I Gin?1403 ?11qu 4113f TEST 1 *1 A . r? 93-12qu N80831942.5% mm ?43; -Miz?qsw {w ?1 1? HBQ {-138 mm @513 L51 "gum? quge POI Wag quw-NH 'Nqoese 1V1 5' mm. mil I Gsng?m Nqoq IG 'rwr 7.1?3: H- 0836?? .. Wk: ll - It LFPB 1151 \8 10-15% I canny ma! Ir-e unlerrer-xs made h/ 'm an 01:5 lam N9 "Us. Paga Iota! I Amwm Fawn?, Total to but. 1?4 i Pilot?s 7, g. 5 GIUFFRE007144 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page776 of 883 Mammy Lam?; Airman Mme Points 0' Dow-rim a AMval Mloo ?ght Rom-Au, Number 5 animal I Unification mm Na. Managers, lndonomonk o! Landing.- I 250-: aw i G-lls?i? Nqoqx?. B?p T1351 use? nag) 3 1t; (ban-3m . .249?! lav? 1 ?il 3 '5 3 2,48% Ncioau? 11151 W66 I [lag-4 LE 1 318:9. 0 Is 1:57 SHE-1 an . It TIL-T68 M74: 3? .3 I . Wm42222 ?a $1?erc 3p ?Gw ?cum, S) 1 - ?5 332"me (5&9 LV .2 6610 WEB 4 LV mwmoz?qwr?nz? 4.2 T66 .Ml?Pr LV I 9. it?; 0 TLST 961? I182unruly that the statements may [11 mo on Iris form are bus. I S/g I Page Tout" . ?101?: smug?j ?mam 611%; '3 32?65 ?1 - A Tomtooalo aegis ?Ogg' GIUFFRE007145 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page777 of 883 Ham lum'an Mam Ailt?ral' I pain? .4 Mm a Anh-I Vlaa Fight Marks, Procedures. Number Alma-In eat-gory . mu Mods! ?nwn M) Mnnouvou, Endorsements oan'mlnux 2,00") l'ruv Ta gummy gum-r12 1? (mys?g has} Tf?'f LV 3wu_d__ 'Tlb?p ?ll-la: 4 1: 94 3?53?? ?manna I - 4 I g. A Lawn)?? anew 9W 22 . CPWT PC e. V- atim?r?ianm cnew 2L (2415016 Nab?il?Cf ,Ewrz LV ?f 1:51; Mir?(jab BPL 24?1? 1:61 1&5 3an 6h?. It? T68 [54?9 WW1 LV 2.7 669 Tea Qggy LV 1 my . LN (a ?rm/5m M??ogqe vaq VQQ Men e- (,4!qu ,NqoqszIT?G 86.0 2% r5? - Amourn?orwuru ?33$ lo'bSl 1 ?0 . an m: Pilot's Sly'aluvo_ CL?ng 516% . Told Dd. 10?" 3 Ti ?1an moranm NEH-Tramp swam? Ckew nucv?s?sw -. . F'Eflc - up 1:48:11 1:74;) ., Lns?l?ut'l?b?. I ?rwcn __Ll Pacomxm A ww?i; GIUFFRE007146 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page778 of 883 Nrua". Mum Aircraft Palm: 0! Deparhlre Mien Him! Ram-via. meow, Numtw . 49.1 mal?oce idnnl'fmImNun' Harm Va. 1 Maneuvers, Endnnunonu ofLandugu I 2% From '0 . . wand?! Mil-Mb "?13 64154-6 Malone (561; Tee. 2M. 6? . 11 '1 was nor 156.. 6n . :1 1- 2 2-3.. v. 31533 my?" ??53 i 10 8:121:51" QQ (5'80 .33 lb 13351- 1 EwaEEWE ?7 2m; LV - 3.51 1.1215? 21: LV 33:! 3: T602 2?13, . L-V as 5?7e_3 1 m??n Kwi i LV - 25 919 M?b?ge?l Ly? . 1-?Ki. W068 my. .- __Lv 26 6415915 Maggighme . 2?le . LV - 1-7-25), TEB 6? 1153 "Zuni . LV 1 . 26110.H.606 ILLBG ?n?p . - gown-(Jompr- TNNIACU 1L ?3 (J ,7 .. TLMR 1 5.131% LV . A I cam that no statements Hume mun-)1: :h 3 tour we Itue Page blal l'fl?b I Amour! Forward gm 1' 3 - Plot'a Signatam WW Total to Oak . 2323? .Eqm a . . 've-rx mm m: GIUFFRE007147 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page779 of 883 . Qv?Ai?'wonmonpmw. . Date Aidan Make Am? Pohl. of Departure Arrival ?has ng'? Ila-nth, Procedures. Numbot About! Calm-u and Mood Iden??calon Mark Rom" Nu. ?mutual, [odor-omens 0t Lan?ngl W. mm To 18% ?gamma [0903er LFPQ 2911* 14 (1qu 252215? 13V l/l? Eq? my; . lgt}_ LV . 1&6 2&9 . [Ll?m- Wee .1153". "hr-?11 540% .TEQL 2" L55 - (27 G-us?rb 2?30 u?uu A . . ?rum-?war; av [Moss-e P612 VIICQ ues 1an 2?1 a-nsm 106106138 :98 MW m; A {39 $1.13? carpal} N?om we kL933 um ms ?33? 6135162 Nqogg60\ 5NFIDEENTIA [9300009 #6 .. "u :ul. - ?2 - Ev 7. [?ogg?j 961 ?agawgmn?r?vcr? - 9346-7171160 Smouawn M19 4 HM. we? away??g 1? Gvusal? Naoqxc 965:.? 9?sadly that me slaw-ms made by me on [Ms km" ale true Page Total ?36 BLAH raj?1613 8105 Alzmunl Fomnld . a; 1m (.401. Ptol's $5113:er ?ow 0 1ohl on. I QG LL 33V?l'b 9. GIUFFRE007148 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page780 of 883 suouonnsu. Dam Much Make I A'rc'an Points 00 Dopanuro A Arrival Wes F??t Ramada. Procuduns. Nu?be' Aim-an nM Mum-I lc?anli?mbor? Marx Flown No, Hangman961: A Heep 39sz CHEW DFW 506w I I ?l Wusmw ?10.3026. argw'no, ?in HM Far-Lu?: . . . run? 5 . 6 79?1?) M19 EB lezlL?fo-leum in I ., -. Fr: ilk-"07 ?mum. LV 1 . . him. (4?wokmv? . . 0 pmwowoa. L?h . earn/Inn ?97857 6612an Lv . ,4 .. ?N?ioa'JE L-CQ "-493.21: L187 mM' 7 - . . .1 \G.:ns.qs moqx? fag, #?mw . mum: P8X um ONFI meme 798.13,, ma): 46% Bf? iG-usqtb Wang" 329m- 16s,, P31 P92: LV W?wumt mm . 1 2g ??229- 0011:5115. meme eat H80 6-?qu Name 961: 361; we; Lu 1 3131 m: 951: T6 34:63! LV 6 T68 93: 1?64 LV 1? Iourlilv Ilat [ho daemon? made by mo on 11.1: tum: an Inn. total . 2/9? 218 . I Hlol?s 3.111% . 05.? Nib-?al.. j: I \n MIWKAO oli?c? VT 4 my I id?a- r?tmmr? \nAo?oa o- ?l 3 3 \13_ knowrorwardv_ q?1' LTolflloDah if ??0343 ?05ch 13 '83 cam GIUFFRE007149 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page781 of 883 '0 Int! ol Donavon. I. Hem Inc ?In. . 961? Is '5 315f_.Czj?i??ismumm?gf-w min? . -- - - ?c?ww?m" ?Mv3.5315 '[N?toqxc a ?ag L22 1. Maui: {Was yr ?04? 1563 fold to Dale 5% I av .. {1:95 {89: 24.16 6 GIUFFRE007150 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page782 of 883 3:132:251?0 {Muslin Paint: a! Downturn 3. Arrival Milan I Hem-?u, Proceduna. I Nunmr am 0mm NM Hm Mn u-nwvon,lndonomnu I alga}; 6 IISQLNOIQCQE P$i_ IP53 mL 1/81/150 lag: 2102332?; ?1?le a! 333394 LSF is" ?1 CPIPT 7:7- 5.32621 2061 01.54005: 00W ?wagsTIES-fzm f; - 1961 gap its; . I am 1m IT68 . . 164717 LymuAml/mip, 1 ?Mow Zh?cmwc 1.5 H: cnr?irylluuho slammed? made by" atrua. I 3 3, i a 7'3? 3131 I ANA mam IJUIJIJ P?bI?sg. rm ArnmnI lag?41w)?; J11 3 BI \13 1?16. . I. .a4 mi 2 Totallo on- [155021 qS 3_ El \13 1:315 31:5; 92 co 0' on] I GIUFFRE007151 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page783 of 883 suouomzsul Data Aircraft Make Aim-an Point. 0! Departure a. Anhal Mlles Fly" WI, Procedures. NM Alta." 43.! and Iderl?mt?on Nam kam M). Mme-won, Endovumenu ul Luann: mow 2 31mm: N?ogse .LBI w9&1? if? m? Lug-15% meme vet TS-ST 96:54:"; "172067 - 60 2.0 563?s: . I free gas10?? LV _z 352? (?t?f?sL 2.8 . V. 2_ 3 766%?? @1144 4? m1; #4 0 LV .6961; 1:51? 0 DR 090097 ?1 . 0 TIST 931'. 4294.5 LN L5 ?0 . ?3 -.- 96'; 12us? _:_613 16?! 1 2. 13- 63 23?7"? ?3 L?m Tr 9? t'mgnn??fo?k BA 1 3.31m85_ ?out '9 B): 1 2w 1.x! 1 z. 1:51" 9 we LV 2 roomy Ihm Iho amumanl: rrado by rr: on lum- are Ivun. pam b/i Im??m I I (q 34156 Amount Fury-m 1 I \oqu Tom Dal. \bLL?b [a i 3 17;) Pl'm'a 3!;natuo_ GIUFFRE007152 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page784 of 883 - . sumalulsu; Du All lo A. I 43% .JQJ 2.213;an 33'3? 11$??an [m'mimw' . . Lam GLer. ?mag? ~03qu F691 1m 116 7?0.2? 4 .l?B 3L2 11!: ?Te :3 :1 $66 3T7: CYQX gmPH): LV L?l 2-13.6033. - 2 ?w u_ 88?? 2x. LVIT 3 3313214?; 3?13__ .2. 1:613 m4 _3 ?Zl 1&0 hwy-B7 96m LN u, T68 6.66screw 33333153333333 3-11va LV I certify than slazurams "made by rm: on1hia 60mm are lrua. I . Page Md! :8 I Amour?! Fomnn! . I Total to Date Hat's Smut-ya. GIUFFRE007153 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page785 of 883 .. . suonommul Date Alma? Make Alrcra? Point: 9! Departure 5 Anivd Minx Ito-M .0 0 Freeware- Number Al .10: um Model Iaonunaatlon Man-t - Flam No. lmowo'n, Enaanqvgom 0t Lanongs I 1010 From - To . (Tull-110.4 (52.19611. 2.4 Tea' - 1:312.1 =E>~1z1~3m N80831: PB): 96)? h" 313 23. Noloqxg. T151 743 . g" .. em (.ces Tee. am HA. -, T68 am 43252: Lv L. 4: am Tee-?5?s ??11 u. 1 1? 213d Lv 30+ ?1 . 1-06 113'! LV mat I ETLST 9L1: LV I \l . WEB 2.040 Ly? J?gm T??w - ORAL 'wmgw . 910338 tho?YSe. jgjiji A ?0 ("ng A?s?3?93 1361? WTEB i $01510 \3 9?qu Nay-1:525 T66 (5620 I ?ij I 9,1! up 0.1 19 Amalm I-orwam Ls-??r 5702. ?101's wk $40 1L46091?: Too 0 alumna-?5W IE GIUFFRE007154 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page786 of 883 I "nd Ume Mann Ma 0 Alvcran Pal-Is oi human 3. Arrival MI'us Flight mm. humw Alrcm? ogovv? f' I 43-: IdawhfbaUchark . "own Na. BMW-5W HAUL: I. I EL ?:32 (HELL UL I PST. 1151' 24452 LU fl . 13 316?" $11236: 1251? I3 0? Li! .. <32- 2; i Ttsr. 1. . ?23? TLs-v gs; w: II 1?5; 2 2.0 crusae {Meme _.04 26 - 2.19?m?aL I 112-5 g?'T56 .1391 . 44 2g 2: ll MDPL 1 2453 \?$17 a lq Pym} the when: I mud? by me on this Iorm ave ..ruo 9390 Tota' Arnomanmard gig 10154 Iq - It?; 654031915 GIUFFRE007155 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page787 of 883 and Model MSW .onwn No. mmuvevs, [Winona olLandInga I loll From . mum emu. LV I Dale Axon?! Make Allan". Palm- oi Depth" I. Anlm . Imus Fikjll I HMO, Proceduru. Number I Allen" 1 ?1 '13: AMImace LN 1?68 3 you 130 24 8021-9.? Wtohmh?auy: I 22?ng I ., l?x .. outcrozm-xvsy . l' - 3 !n _aad'4?L'w 3&442 A . 32? ?21223same as about: EC: wasenmaw-mg (?61 11M page; ?50 ems?: thocgs'? 245?! \l LFPB 1m: .. 1L1. . ma DJ Vx gay ?16635f'GUpg. 15,5: .LV . 7:2, ?:51 Tee HA LU BM-Ll'b'l I 8 I 140496;- as wm Madge: 3:51 we? . '50. 16.6 ?65: 1 ?2.10 I 1H I II: oo?i?VIhnt IM summon: made by me on tom: are two. P030 1cm 2.1 9/ ?8 I Amount Forwani ml-bsuwukg?id .0 .2 J. - rot-I In one 1'0ch 3 if?: - ?bPi?n 3 9159855851: Case 18-2868, Document 283, 08/09/2019, 2628241, Page788 of 883 suouormsuI Nromn Mata ma Model Nro'a? MAM Point: at Mari-In 1 Arrival me TL Mica mgr: No Remarks. Prouduno, Manon-van, Endowments Nmeor o? 1mg; Aron-ll Galogory.? mow: um?. (3 N?ioqx'?. Tee 856 AB 2WD 1? BBQ BFI L7 wig?kg; 2_o 69c. 139C TEE 2432 TA 2377 -g/x I Lt 4? Tee 1?51 233 Tee Q7: 4- ., i/x GIUFFRE007156 CONFIDENTIAL 25 5423?150 srmm-rw. MILO: I 2 ?fnafgow 15' Fe ?roman Moe mm? 51' 7.6 nan" (aw-?Amman was? M?afm?szj?p 28 s-vs?e $9901; 2.11136? if; . 9337 ?55? t; an Human 1:56 Ls: ?1.4 3? L5: L53 L.V mo Eboom'y mm tho statement:- modo by me or. Ms form 310 lme. Page Total basa . I I anm_romm Pilot's Smamo -- Trafa?b?a-vmo 000050..-. . \og?b?l. \os?GIUFFRE007157 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page789 of 883 . Dale ?Km" I Po'n" at ?Mv-l I Mac: I fl I, ll Numtov Alva.? . . 31 Model Ma I cm" Endorsement. Lardnos 3 7.633 ?m NOV F?b?n?c? mgb": ?30 crap-m; I 13?! - lg. cu.) PM 96: ?353%?3m?? 733-3 f313:31 DEM uq ?33? . i 323539.031 choqa'a 5:137.3.996 5 33_l_l 3 9593 ?333333 I 3 3 0141 I 3 t: 17mmx_oxnpi?3im LN -- I I 338?, 03 T302329 39339.32 .2311 w. I (NRC. ??353 we.-., .3. 23 (53mm Jewel? 3.233: 3 I L1 2H Cr-usneTijx? 313.4365, ?311 13.: .6 315?} P: $11043.ij 6333 3%in 3 was0?03 \1 - A {@ng Ego to Lana -5115?: t. - 331x533? SE 6163 NQQL *5 5. .. 935; 3 Hi; 3&3 ?a :5 w'gs?w 533+ 1 Icsnify that the armaments wade by me on Ms 1am are true I l- PagaTma? A 3 5 (- 3 Amount Forward i?E 0 SHE ?3080 99min: To.? a? ?361L?b 31535 GIUFFRE007158 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page790 of 883 I ham 4 Arcrun Mm Altman PM: o! Dana-dur- 5 Arrival Mia: Flighl Hon-run. Nu'nlw Aircralt md Model Mark 4 4 44 Flow er Hammers. Endonmmc 01 Lemur. . me- 1n - "Emu-unmare 5m 66% gummy: - - b: ?f9 G-us?t? N80832: Tab 116? 9111-100 ?wmart 4M LB u_ (is . ?but? .4. ?Mgw? -&mn$duk SN: 6612!! 3 jG-uS?iB _zi?q_x- q' .. 931 was pea; l-V 1161 .. "tee in.? 44 ?55; 133 my: 1,484 12961-4?91986a T?rs w? - 7?7- 4 3? 1-91 nan-L i 7.2. 12M) 1232. 4 u} 2235 w: ?irj?iddc? -- to no I ?goldfololcq rat-(cog? 7 CC FIDF DR -0 ?5 p, .29 ?1 (?81 1151? T68 i I awry mm the statement made by m- an [can arr tma. - Page "7015Annual Furwam . ?1 I Flu": Signalmegm WA foul lo Pate 225GIUFFRE007159 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page791 of 883 - 1m:r?w . z-?T 31.1- suononusu' ?a 1- Id c'ah Man) an M0:1m Mm 89?"?ch MM LPoin mu ofDoplr tuna AMI .I ?aunts. Free-duos, Nm'?u 0. anofl, ?LL-Lava. -. 1% J, I 1 191391.911: cum-a. Hemf? 12? 40:35 1-363 ?13? . . \1 66 98): 1.13128 '18" 08-1" ?1353 f? if. _u 98: 11-31:- 31:22.1 1 5 I as?. 4* . .- ?2301 ?Jm ?3me i525 12 Emo??} M33 ??11 1-9 ?3515 "t 1' ?g E31: Am ?1:32 I 1 TPBEW ?mpw #73511 Lv A19 I m31L A 3? 6-17.) HNqomg EGss E635 so} ELL HZ 1L "1 2 56351 soul .--: s, . .1le__ i. 7?1 3F: 3 sex. 1 ?Ta . 52:1 31 1 I W16 INQoqa'c; pg 41 123? 1 I - 11 10?51: 27ml P33 1 37: El?l?my 3191 ?I?mm'r WOO "y UIL .011?5?86 in?; - 5- [ff-"yr i4; ?noule {Tlf4.1- .. t" Page mu Mn., . -- 2-11GIUFFRE007160 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page792 of 883 55:23:? :12: 2'13? 2:19: :11? 2:Jaw-bur 1? sen 4_0 -0- 9? Stwunmt ()de ?mWVH'm?m Fax?mm ?fxg?g??f? 670536 moan?0:40:66 0 L6 - LV 9 2312.9115 2 2.32:8" 2 22% LN ??35 T68 98): 17-99 ml 51?. .. 1:}51? .TEB 7.251 LV frets: - 2L T68 2 25 fyw?? ase Azu591? g. i T50 TTSY . no} - w. .n 11.51 pm: i mu M8891 . I mm Iho stalamn'lis made by me on Ihls an two. page 10m Iq?09-8 b??t Flo's Sanctum 2% total I. ?086 ?d?ml L??1339-5 3M \so 6 24191? I GIUFFRE007161 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page793 of 883 Airma?t Make New." Polnil Depart-an a Aulvnl I Remarks. Moeduno. Nun?)! Alva-It 491 mm ?Jhdol Hert?ma?m Mark . Fl'wn No Manama". Endorsements rt - to? min 3% 3 ?xi? G-uswo aoaxe Mar 1:57 226 LN .5125: 228-.? ??23 ?in! 114' ?15? QTEXS 21g LN 2.31 31 --.. wsaV LV M, 3 answ- ?Ls? . .22. -3 ii? [Larva ?5 Lf?8 LP a; \6 A L907. My?: - LVI zq T1251 1'58 - n13 Lv "-581- XML-?fgg- gnu-i - 1- T682223 23%? . 2231- . .- . 6661-? 312s: and Lv BUDNH as 2:151? LV 16' 7.0 TEB utv L..V 2.5 3 ?x 421-63 waxes-sna? mmr?c?wcnon 3 ., . . uu>ugBBQ As: hislea-?y Ina! he slalenems mace :y me 011'.sz lam a?a In?. inAnmm?o-wam 3. 3559Told to p38Sam-mu? Cam: 18-7868, 782, 08/00/7010, 7678741, Pagp704 nf 882 EXHIBIT 42 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page795 of 883 GIUFFRE007162 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page796 of 883 scan scan0003 scan0004 scan0006 scan0008 scanOO 10 scanOOll scanOO 12 scanOO 13 scan0014 scanOOlS scanOO 16 scanOO 17 scan0018 scan0019 l" GIUFFRE007163 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page797 of 883 GIUFFREOO7164 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page798 of 883 GIUFFRE007165 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page799 of 883 GIUFFRE007166 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page800 of 883 GIUFFRE007167 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page801 of 883 GIUFFRE007168 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page802 of 883 GIUFFRE007169 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page803 of 883 GIUFFREOO7170 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page804 of 883 GIUFFRE007171 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page805 of 883 GIUFFRE007172 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page806 of 883 GIUFFRE007173 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page807 of 883 GIUFFRE007174 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page808 of 883 GIUFFRE007175 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page809 of 883 GIUFFRE007176 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page810 of 883 GIUFFRE007177 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page811 of 883 GIUFFRE007178 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page812 of 883 GIUFFREOO7179 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page813 of 883 GIUFFRE007180 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page814 of 883 GIUFFRE007181 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page815 of 883 GIUFFREOO7182 CONFIDENTIAL Cam: 18-7868, 782, 08/00/7010, 7678741, Pagpm 6 nf 882 EXHIBIT 43 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page817 of 883 2- - ?mm ll. 1E0: s. ?ndmi 001001111 (ceaseless-0111104201044 ROOM SERVICE 4 mmuumsmmun 60 14 8887 WAITER 1701?? PERSONS TABLE N0. CHECK NO. 062 A 6193 32098 DETAILS AMOUNTS mum-Bx? FWD 59" TBL 9221-11 0111:2030 E: WT DA 6/5 09007 32 (Ii-3:111:11 39.00 4 320.00 F000 TUTRL 320.00 70. 1mm 24.64 1" 3?46 51? SERVICE 32.00 mm DUE .64 923 HOTEL 13.76. 54 01:0 RECIEWBLE 02101190901333 TIN 3 10 1 61770 2 R00 5014 22 000232 CHECK CLOSER 06:1anm?u .?23 C. L: - NAM 899M C1 1 WV) .210?. 1d ADDRESS: - SIGNATURE .1 GIUFFRE007413 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page818 of 883 u: 0. {mm durum a. 11704 c. r?ndmi 6010011): (068) 2810334 udm?t? 281044 ROOM SERVICE ROYAL PRINCESS Cuwuu MAI 9 al . 50 14 3327 WAIT ER N0. PERSONS TABLE N0. CHECK ND. 052 1 ca I23 32106 DETAILS AMOUNTS '5 0 mo- r? 9 TBL 923.4 m: 2106 951 1 8 .nz momma amanr? sew/((9 Im . oo FRENCH FRIES 11!} .1in FOOD 110 .5829105 11.00 TUTRL DUE 1'29 . 47? 923 HOTEL GUEST 129.4? RECIEVRBLE 03010-024031? TIN 3 '10 1 61770 2 RM 5014 22 0002-32 CHECK 310551} ?5 5? ., ROOM NO. (21 2, 9 c. N0. mom-:55: SIGNATURE 0 GIUFFRE007414 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page819 of 883 .. than: a If?: 1 ?m?lmi 601001111. moss-o min-12310? ROOM SERVICE ROYAL PRINCESS Mu 4 4 . mmuumm'nmm 50 233? WAIT 0. PERS NS BLE NO. CHECK NO. 2?71) N9 32117 DETAILS 1 AMOUNTS /030 3&3: TBL 1/64 1-1? GET 1 . warm as: /0 /j 00 a 119" a 1 PORK CHIC 130.03 IM- 7 31/0 F0011 1.30.00 ?m 10.01 (H /53. 0/ 5mm; 13.0?) .3 Tom um: 1:53 . 01 92.3 HOTEL GUEST 150.01 REC RECIEWBLE {121013?02-00435 TIN 3 10 1 61770 2 501-1 2?2 0002132 CHECK CLOSED 00M "90 W2 no. ADDRESS I) "mamas 5 GIUFFRE007415 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page820 of 883 as o. lmmu mu 0. I. 50011115 50100101. (053) moss-c 11110012010? 0 ROOM SERVICE ROYAL anva MM 4 A 50 1t 2887 ?432 9 DETAILS AMOUNTS 5 Room-Bx? 004/ .250 Tea. 1x69 CHK 1:29 357 1 a? J5- 6?6" 05:03:01 . ,2 1 FRIED SPRING 5211 1200?0?; 101/ 7 [11/7 6' 1 RIIE PORK CHIC 15:0 .00 FOOD 250 .00 3:19.25 939$); SERVICE 25.00 TOTRL DUE 294 .25 923 2 HOTEL GUEST 294.25 RCC FECIEWBLE 0210144240484 3 1 61770 2 RM 5014 22 0?30232 ?m5 GEEK CHARGES "mks-V aoomNo. H3 ??ch ADDRESS. - SIGNATURE 0 GIUFFRE007416 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page821 of 883 a. ?mnu Minnow u. :1?th u. I?tvq'lmi 501001115. (053) 2510334 mini 281044 9 ROYAL Cum Mu 50 14 28!? WAITER NO. PERSONS TAFLE N0. CHECK NQ. 5 N9 23621 DETAILS 1 AMOUNTS 13 POOL - TBL 4 . '3ka 6'21 GET 1 0.282399! 1 NRTER 25.00 BEVR . TOTFL 25.00 7'31 SERVICE 2 DUE 2'3 . ~43 923 HOTEL GUEST 29.43 9813 TIN 13 10 1 61770 2 RM 53.114 0-)0332 ill-EEK ?ijrz?lF'ln?v- ROOM nofi? GIUFFRE007417 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page822 of 883 a, {mom than: a. n?m I. rim?lmi 001001111. (063) 2310334 mini 281044 0 ROOM SERVICE ROYAL PRINCESS MA: 4 A 50 1? I887 WAIngRog NO. CHECK NO. N9 3214; DETAILS AMOUNTS PUDM- 923/ 1 J: 09 'Lj?rq lair/77X 2 FRIED SPF-TING RIJL FGCI 1.:Il' 4% m? ?233.4: SERV ICE ?-24 .01] DUE 2:82 . 48 323 HOTEL GUEST 232.43 45L: TIN 3 1 5177? MW 5014 22 01303-33 3,423.5: Pmo-CHARsag ROOM N0. Jamgs QED . SIGNATURE .I - I 1 2:332. GIUFFRE007418 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page823 of 883 u: 0. {mm imam a. lit? O. ?ndmi 501001111. (063) salon-o min-i 231cm 0 ROOM SERVICE ROYAL PRINCESS 4 A nsmaummuns'n 50 1? 3887 WAITER N0. PERSONS N0. CHECK NO. a4 3 a 32147 DETAILS AMOUNTS 5 Fa f: TEL 4231?]. 14:; n. ?32 ?3.3211? ST 9 3 FOOD 33:} VFJT 7:5 SERVICE (if. DUE 91:5: ,116 923 TE. HCITEL. GUEST 318.06 :40: Em LEI 1 ?lm! 2 5014 22 3300232 CECK CLOSED FuEznm?i-i?m? - A 2:12? 1132') ADDRESS: p\ SIGNATURE GIUFFRE007419 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page824 of 883 112 a. . m?mm o. 070: 1 ?udmi some Tm. (063) moss-011104281044 ROOM SERVICE ROYAL PRINCESS Comm Mu 4 A 50 14 2887 WAITER N0. PERSONS TABLE N0. CHECK 0% 4-237 32161 DETNLS AMOUNTS mow ?32-'35'1 0% 1:1 ZIFDCT 33:05:41". TOST. C9051. 5:13.01) FOOD HL 30 .00 2?91 77-; .15. SEEN ICE E- .331} TGTFIE- DUE '34 . 1'35- 92:: HOTEL sum 94,15 I123: RECIPIQSLE 13133?433-0363; TIN 3 1 6-1770 A 57014 32 1313923; 39::15qm- wo-cnmcesm NA ROOM N0. mm KMA c.c. NO. VIOC ADDRESS. .53 A1 0 SIGNATURE GIUFFRE007420 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page825 of 883 m: :1 album a I. mm; moo 1m. canons-a ?in; 231044 0 ROOM SERVICE ROYAL morass Cumm- MA: 4 A so 14 8827 WRITER NO. PERSONS TABLE NO. CHECK NO. 6% 1 425 32162 DETAILS I AMOUNTS I mama-*5 BL 92: ,1 1 1.5: - 1-: :c - 1 com van.- MILK 00D :l . 1:5. ICE 3 . WWII. DUE 4 . 16 ?H'n 1? 5?5 94.1.3 DEC a YIN 2? - o1?? 2 9M c3:114 22 CI Wof?f 39313233 ADDRESS. - {7 BL SIGNATURE WW5 GIUFFRE007421 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page826 of 883 u. a. ham ?man: a do: 1 1%de 60100 In (068) won-o udmi' 2am? ROYAL PRINCESS Cums 2887 WAITER N0. TABLE N0. CHECK Ob} 32160 DETAILS I AMOUNTS TEL 17H 13-5? 2 .17r-1wu2 7-3?2151: FRESI. =an 2 UR GR 7' JUII- 1:30.130 Ti .L'llj L'fj U) SE (VIE-E 2?6. JG mm- DUE 32:13 . ITI E: 823/911358 NEJZ 4L REC 35..-. $1770 3 .i14 .55. .??rfliir-z-- .-.. ?Mum KM ADDRESS-46 RE fU GIUFFRE007422 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page827 of 883 112 u. {wanna 151mm 0. 111m 1. 63411111 some 1m. moss-a uvhvf won 0 ROOM SERVICE ROYAL PRINCESS Calm Mu 9 A 60 14 8887 N0. PERSONS TABLE N0. CHECK no. 0% (31/13 32171 DETAILS I AMOU NTS 923/1 )4 17; 5807? ?l s-r?T: .3231{Eff-3-8677. 4.07.5". 3-4 .23 16? IN '11. {vi-'14 C33: gt- NAME 20:77:20. 631) A ADDRESS SIGNATURE VLv?i'?? GIUFFRE007423 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page828 of 883 .mu ?mi-mam 0. I110: n. ?u?mi smoo 1m. moss-o uim' 231044 0 ROOM SERVICE ROYAL Cuum nzlauumm?lm; 50 1? 38,7 WRITER NO. PERSONS TABLE N0. CHECK .NO. 0% Vf 3 32172 DETAILS I AMOUNTS 7PT- 31' LAN 27ri?'TrJ. my; 5-: EH: 7490.75 1 2177 PAID-CHARGES . I 5 NAME: ROOM N0. CA (??g/coma. 7? ?l I ?1,751 SIGNATURE 5 GIUFFRE007424 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page829 of 883 .a n. {:Jnmu u?unmu 0. 150: u. n'wabm' 50100 mini 231044 0 (Nu m. Mg: CA E. mx?uumm'un?u; 60 1? 28?? wanna/Np. PERSONS TABLE N0. CHECK NO. 1 a 263581 DUNLS AMOUNTS 4-8. {85. 9/4 ?35! I. 13:2*im LBS. 303,3}; FOOD TUTQL VA 15.41.! SEW It: in] mm: DUE 2121.715 . 7?05 40TH- '2'35.40 4-35 TIN 1 6177i} 2 54 501? 22 0013232 SUBSEE I ROOM no. '76? ?3 '1 Nah, C5 4, E. c. c. N0. SIGNATURE (1?4 W, . GIUFFRE007425 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page830 of 883 as I. {wanna m?mw 0. 070: 0. IiU?mi 50100103. (053) 231033-15 min-i 2010? ROYALQCESS lel Mu 60 14 8827 no. PERSONS no. QHECK NO. 0% I at 23629 DETAILS 7 mourns 12 . TEL 1.569 CHK 8-3 2 . -u i SINGHII BEEF-Z 110.30 1 DRINKS 50 .00 BEVR. mm 160 .IIH) arm - 2 .32 ICE .00 TUTRL DUE 13:3 . :32 91.3} HOTEL 188.32 .052: f3?iUlF~?2~00695 TIN 3 10 1 5.1.70 2 RM 5014 2'2 HOUSE: ""12 PAID-CHARGES ROOM NO. 90 7 Iv, c.c. no. SIGNATURE (Av? GIUFFRE007426 CONFIDENTIAL GIUFFRE007427 CONFIDENTIAL 15309 3 allHM INHODDV MOTBA )Nld JIJEIN hpun? I m1, '8 ma amuedaa ixnvf 73 lC" 'J?gj- 3? 313? 59@ {Ck fawmu/wggatz: v. womm ?6?ij w; - mm 03 '95, gent?: laws AQH ?9 a (e?Jemlns %os)ssaxixa 5 .3 36mg) aowag 960! (9609 l/paumw aq o: sums aawas Jegnbaa I 361/ nywwuzeup gunman 6 name mpghueamwmw '5 05 semwmanuh 59 mainly? om (m3) (5 as 06!! .3 mom-up 06 o: 0k. 0: wmunrwp mos/P I Lamb 3 cm oz on 1?;szer . 05 ?Mi/Winn at I an 09 wsw'r a GUI. "winner . 09 megs buoruqs/umap 0a Malay-2'1 (531?! on SW a tuna) MO) when 1000?) Ill 'nuv SNOW aango wnoulv 3390 zsang 9 wanwh mm mm mhuwh Case 18-2868, Document 283, 08/09/2019, 2628241, Page831 of 883 Case 18-2868, Document 283, 08/09/2019, 2628241, Page832 of 883 lli'mu liuduu' n: uimnw ninnam vhf-noi- ilimun 616'. (uan luduv?i?uftiumi a lo "1770 mil" u?mluu' ROYAL PRINCESS 4 1 6 0 7 MINI BAR usv 30mm N0- BEVERAGES AVAILABLE IN YOUR REFRIGERATOR NAME ROOM NO. 744041 7 PAR CONTENTS UNIT PRICE TOTAL STOCK TION BAHT Singha Beer (Small) 100 Heineken Beer 110 2 Soda Water 50 Coacola so 1 50 2 Mineral Water 60 2? no 1 Brandy V.S.O.P. 20 (I. 550 1 Scotch Whisky 20 cl. 400 1 Thai Whisky 130 1 Gin 20 d. 400 I Vodka 20 cI. 400 4 Chocolate Bar 60 I 1 Potatoes Snack 40 2 Singha Water Complimentary (I 2 Prices are inclusive of service charge and VAT (6E 20] We refill your telrigelalor daily and bill the consumption ditectly to your Hotel account And drinks will be (named lully when the bottle is open. HEASE DO NOT PAY CASH Guest's signature Relilled by. .. . . . Front Office Cashier GIUFFRE007428 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page833 of 883 I "moi: dfmu (min) . .. . - :n'?uuwwia Llu?luu' tIIMmagnhm' 3 3 1n lu'unw Edna-m ?in minlmi ROYAL PRINCESS MINI BAR LIST _??Cmm NO, 41678 BEVERAGES AVAILABLE IN YOUR REFRIGERATOR bum ROOM NO. 4?13 NAME PAR CONTENTS UMT PRICE CONSUMP- TOTAL SIOCK TION BAHT Singha Beer (Small) 100 Heineken Beer 110 2 Soda Water 50 1 Coca-Cola 50 2 Minewl Water 60 "j be 1 Randy V.S.O.P. 20 d. 550 1 Scotch Whisky 20 cl. 400 1 Thai Whisky 130 1 Gin 20 (I. 400 1 Vodka 20 d. 400 4 Chocolate Bar 60 {90 I Potatoes Stud 40 2 Singha Water Complimentary Prices are inclusive of service charge and VAT TOTA ll 90 We team withstand.? Indbl duty-d bow-Isaac?. PLEASE DO NOT PAY Guests signature Refined by Of?ce Cashier GIUFFRE007429 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page834 of 883 ui ufuwu 61h (umuu) . ?1:331:95: dim" ?Inch-vi a :0 mm 2 n: uni-norm 16le min ulm?lmi ROYAL PRINCESS MINI BAR LIST NO. 4 1 8 5 4 BEVERAGES AVAILABLE IN YOUR REFRIGERATOR . I0 NAME . ROOM "0913.3 DATE PAR CONTENTS UMT PRICE CONSUMP- IOTAL STOCK TION BAHT 2 Singha Beer (Sma?) 100 2 Heineken Beer 1 10 2 Soda Watet SO 1 Coca~Cola 50 2 Mineral Water 60 1 b0 1 Brandy V.S.O.P. 20 d. 550 1 Scotch Whisky 20 cl, 400 1 Thai Whisky 130 1 Gin 20 cl. 400 I Vodka 20 cl. 400 4 Chocdate Bar 60 9.. 4 20 Potatoes Snack 40 Singha Water Complimentary A Prices are hdusive of service charge and VAT 18 dlnalytoyouv?otdmt. And huh-god MI, whan lhoboulebopm. PLEASE DO NOT PAY CASH Guest?s ignme Re?ned by F'om Of?ce Cashlet GIUFFRE007430 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page835 of 883 mwlnuwvain dim" 03qu Ill minnow limits: qua??o gm" undan?w'mn?tlnmi a [0 ?Inc 2 045m 0 tive?luu' ROYAL PRINCESS MINI BAR u5?r ?mma?u? No. 4 8 5 8 BEVERAGES AVAILABLE IN REFRIGERATOR 915?. . - ?of NAME ROOM N0. qa?om/F?f PAR CONIENTS UNIT PRICE CONSUMP- TOTAL STOCK 110N BAHT 2 Singha Beet (Small) 100 2 Heineken Beer 1 IO 2 Soda Water 50 ?l Coca-Cola SO 2 Minetal Water 60 1 Brandy V.S.O.P. 20 d. 550 1 Scotch Whisky 20 d. 400 1 Thai Whisky 130 I Gin 20 cl. 400 ?l Vodka 20 d. 400 4 Chocolate Bar 60 2 120 Potatoes Snack 40 2 Singha Water Complimentary Prices are Inclusive of setvioe charge and VAT [2&2 We real your MW day and MI In consumption directly to your Hotel amount. And MI he Md 1dr when the Dottie one. PLEASE DO NOT PAY CASH Guest's signatute .. by .. ant Of?ce Cashier GIUFFRE007431 CONFIDENTIAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page836 of 883 mind. ?nal H. (mm) lmluuru?'t i?'um iiu'lml a law? . l. I: than?.an . ROYAL PRINCESS 4 1 9 4 3 MINI BAR usr N0- BEVERAGES AVAILABLE IN YOUR REFRIGERATOR NAME ROOM N0. PAR CONTENTS UNrr PRICE CONSUMP- TOTAL STOCK HON BAHT 2 Singha Beer (Small) 100 Heineken Beer 110 .1 4 1?0 2 Soda Water 50 i Coca-Cola so 5 2 Mineral Watei 60 1 Brandy V.S.O.P. 20 cl. 550 1 Scotch Whisky 20 cl. 400 1 Thai Whisky 130 1 Gin 20 cl. 400 1 Vodka 20 Cl. 400 4 Chocolate Bar 60 1 Potatoes Snack 40 2 Singha Water Complimentary {l Prices are inclusive of service charge and VAT ??gom. 1 (1?0 Weidlyuur??mluhilyand PLEASE DO NOT PAY CASH Gust?s signaun ae?iled by Front Of?ce Cashier GIUFFRE007432 CONFIDENTIAL Cam: 18-7868, 782, 08/00/7010, 7678741, PangR7 nf 882 EXHIBIT 44 (Filed Under Seal) -Auw 0 Reda - Video cted Contra 1 Calls Pub5?3. to 15*208 Case 18-2868, Document 283, 08/09/2019, 2628241, Page838 of 883 Cam: 18-7868, 782, 08/00/7010, 7678741, PangRQ nf 882 EXHIBIT 45 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page840 of 883 VEHICLES Mercedes Benz 600 (561) 309?6415 Rear Mercedes Benz oi Palm Beach 2001 Black (561) 379-9390 4000 Okeechobee Boulevard GP C?r We West Palm Beach, FL 33409 Licence: eospeu 47 $35 Att: Shawn Adison - Tel: 561 689-6363 he. u9o .93 ?39 ?69 ?6 Mercedes Benz 600 (561) 758?1672 Rear 1997 Black (561) 818-8867 Front Licence: G14KCT Mercedes Benz 600 Conv 1998 Silver (561) 345-7141 con/V!? Licence: WGE53R 3/ Licence: RA885L .- v9 Suburban V9 (561) 371-1686 Roger Dean Chevrolet 2001 Black $07 2235 Okeechobee Boulevard West Palm Beach, FL 33409 Tel: (561 683-8100 Mini Van 1996 White Licence: WGE52R NW 2" (561) 308-5700 Nestor Auto Repairs 2600 Florida Avenue West Palm Beach, FL 33401 Tel: (561) 835-0809 Cobra Grand 1 993 Green C97CRJ Nestor Auto Repairs 2600 Florida Avenue West Palm Beach, FL 33401 Tel: (561 835-0809 Volvo 1998 MrsEp?s/rtein I (561) 686-3707 Volvo Palm Beach 5544 Okeechobee Boulevard West Palm Beach, FL 33417 Tel: (561 471-7600 Oil Well 900 Southern Boulevard West Palm Beach, FL 33405 Tel: (561)835-9374 Oil change every 3 000 miles Pq/nr? MaleK 560/; 6946/, Registration, insurance and yearly inspection papers to be kept in the glove compartment of each vehicle Spare keys are kept in the key box in the of?ce Page 2296 02/11/2015 Public Records Request No.: 16?268 GIUFFRE007834 Case 18-2868, Document 283, 08/09/2019, 2628241, Page841 of 883 Muvico Parisian City Place 545 Hibiscus Street West Palm Beach. FL 33401 Tel: (561) 833-0400 GROCERY STORES Bishop Water Co Tel' (561)582-1367 51?? gar-n ?ij-bottled water (large and small) 1 Carmine Giardini's 2401 PGA Boulevard. Suite 172 Palm Beach Gardens, FL 33410 Tel: (561) 775-0106 1 - C'est Si Son 280 Sunset Avenue Palm Beach, FL 33480 Tel: (561)659-6503 Gourmet toods Fish. meat. gourmet foods Publix Super Market 265 Sunset Avenue Palm Beach. FL 33.480 Tel: (561) 655-4120 General, cleaning. toiletries Wild Oats 7735 South Dixie Highway West Palm Beach, FL 33405 Tel: (561) 585-8800 Health Foods HEALTH BEAUTY Pharmacy Greens Pharmacy 151 North County Road Palm Beach, FL 33480 Tel: (561) 632-4443 Lewis Pharmacy 235 South County Road Palm Beach. FL 33480 Tel: (561) 655-7867 02/11l2015 Page 2297 Public Records Request No.: 16-268 GIUFFRE007835 Case 18-2868, Document 283, 08/09/2019, 2628241, Page842 of 883 02/11/2015 Page 2298 Public Records Request No.: 16-268 GIUFFRE007836 Case 18-2868, Document 283, 08/09/2019, 2628241, Page843 of 883 Plumber (/1644 Z5 7/ Foster Plumbing 2800 Westgate Avenue West Palm Beack, FL 33409 Tel: (561) 686-1721 General plumbing repairs Roto Rooter 6600 NW 12th Avenue. Suite 213 Fort Lauderdale. FL 33309 Tel: (561) 832-1495 Blocked drains Pool Hackl Pools 1331 Central Terrace Lake Worth, FL 33460 4' Tel: (561) 588-7493 Monday and Thursday at 10:30am Clean pool, ?lter, a e: Tree Trimming County Wide Tree Service Tel: (561) 371-5786 First Monday in May and November STORAGE Storage USA 5580 Okeechobee Boulevard 10 it 20 ll unit available West Palm Beach, FL 33417 Tel: (561) 683-9955 VEHICLES Car Detailing lm Beach Wash Auto il 12 N. Dixie High (at A 0G ?3 1,505 . (561) 8 8748 9:28:15: gleam ?th sew/{ccZ7ym?017 85765 f/ Min 33 7 2 3 02/11/2015 Page 2299 Public Records Request No.: 16-268 GIUFFRE007837 Case 18-2868, Document 283, 08/09/2019, 2628241, Page844 of 883 MAIL DELIVERY SERVICES FedEx 1-800-463-3339 Account No: Drop-oft box is next to Palm Beach National Bank on Worth Avenue Post Office 401 South County Road West Palm Beach, FL Tel: (561) 832-0697 MAINTENANCE Air Conditioning Cassidy Air Conditioning service contract . 5 .. 501 Fern Street First Mongay of every moath West Palm Beach. FL 33401 30 0? Ck - l6 2% ail Tel: (561)833-6331 .Awnings American Awning Company 537 Pine Terrace West Palm Beach. FL 33405 Tel: (561) 832-7123 Cable Service Adelphia Cable 1401 North Point Parkway West Palm Beach, FL 33407 Tel: (561)478-8300 . It,? 7 - (.5 Carpet Cleaners Stanley Steamers Wall to wall Tel: (561) 586-5700 ?7 Merry Rugs Loose rugs Tel: (561) 588-8588 Computers Palm Beach consultants: Chad Bonta Peter Kapopoulos Md 02/11l2015 Page 2300 Public Records Request No.: 16?268 GIUFFRE007838 Case 18-2868, Document 283, 08/09/2019, 2628241, Page845 of 883 TRAVEL Pilots Larry Visoski Dave Rodgers Larry Morrison Mr Epstein's planes Jet Aviation (561) 233-7241 Procedure for leaving cars at the airport; Leave car at Jet Aviation landing strip Leave the keys in the car Advise Jet Aviation Tail or Tail They will tag and pull car to plane upon arrival Ms Maxwell's plane Raytheon N321 Fi? 0? k0?; 1-888-835-9782 Contract No: Air 4 Tail #1 Always a Beech Jet or Hawker .. 7 .. Commercial Airlines Air France American British Ainivays Continental Delta South African Ainivays United US Air 1-800-237-2747 1 -800-433-7300 1-800?247-9297 1-800-525-0280 1-800-221-1212 1-800-722-9675 1 -800-241 -6522 1-800-428-4322 Caybs Mb, ?Mime,? (569 02/11/2015 Page 2301 Public Records Request No.: 16268 GIUFFRE007839 Case 18-2868, Document 283, 08/09/2019, 2628241, Page846 of 883 BANKING Cale ma) [do-Yuk Am to La uwx Leonor Household Banking Account Palm Beach National Bank 125 Worth Avenue Palm Beach, FL 33480 Tel: (561) 653-5594 Account No: Send to Eric Gany for reconciliation $1,000 Petty Cash Float BICYCLES Bicycles Palm Beach Bicycle Trail Shop Mongoose Crossway 450 223 Sunrise Avenue Raleigh Aluminium 300 Palm Beach. FL 33480 Mercedes Benz Cignal Sports Bike Tel: (561)659-4583 Schwinn World . Huffy Santa Fe Raleigh Sport Scott Boston BOOKSTORES Newspapers Publix Super Market 265 Sunset Avenue Palm Beach. FL 33480 Tel: (561) 655-4120 Magazines Main Street News 255 Royal Poinciana Way Palm Beach. FL 33480 Tel: (561) 833-4027 CLEANING SERVICE Francis Peadon House Cleaning Services Every Tuesday and Wednesday 8:00am - 4:00pm (Francis and Pastora Peadon) The Breakers One South County Road Palm Beach, FL 33480 Tel: (561) 655-6611 Renew car park stickers every September Comedy Comer 2000 South Dixie Highway West Palm Beach. FL 33401 Tel: (561) 833-1812 The Mar-a-Lago Club 1100 South Ocean Boulevard Palm Beach, FL 33480 Tel: (561) 832-2600 02/11/2015 Page 2302 Public Records Request No.: 16-268 GIUFFRE00784O Case 18-2868, Document 283, 08/09/2019, 2628241, Page847 of 883 Sam coat-3M gap?! 5~ 4 832, Sam Electrician Energy E?icient Electric Tel: (561) 655-721 1 Exterminator Palm Beach Exterminating Contact is Ken First Monday of every month at 10:30am Tel: (561) 689-0808 Also use for termite tent Garden Service Alan Stopek Wellington, FL 3341 4 Jerome Pierre Part-time help. Billed through Alan Stopek. In residence: Daily from 6.30am Not in residence: Mon - Fri trom 2pm - 5pm Also maintains Epstein's property on Saturday mornings. Garage Doors The Doorsmith 4160 NW First Avenue Boca Fiaton, FL 33431 Tel: (561) 391-7768 Gates Reich Metal Fabricators Back door gate switch above garage door controls. When open, round red light is on. Tel: (561) 585?3173 '30an Front door gate switch in telephone outlet above the kitchen telephone Irrigation Dolphin Sprinkler Inc $6 7: Tel: (561) 844-8082 Landscape Spraying Academy Services Arrange through Alan Stopek Tel: (561) 478-4629 Locksmith Wilson Rowan Locksmiths 625 South Dixie Highway West Palm Beach. FL 33401 Tel: (561) 655-3637 Painter Bill {19/11/9018 Page)? Li Pu - GIUFFRE007841 Case 18-2868, Document 283, 08/09/2019, 2628241, Page848 of 883 I 92 w} 31? (83kt? 63% gc; - 57" ($6036 Haavlc-MQ 0de 2- Lou Q5244 Hoc? 3? 5,2 LL26 Vx/ CAL wa< 0 ?3 Tow (Lhc (.L a, "5 1f Page K, th7/ fir/3L; GIUFFRE007842 Case 18-2868, Document 283, 08/09/2019, 2628241, Page849 of 883 Address Telephone Sheet Save ?5 Mall 358 El Brillo Way, Palm Beach Fl, 33480 Name Address 'l?clenhone/Fax Mr. Jeffrey Epstein (NYSG LLC 01110 457. Madison Avenue Floor ken/AM}, New York. NY 10021. Email or) Ms. Ghislaine Maxwell Email Aden Fave Accountants Eric Gany .mail .. . . EMD Kgl-M' Q'ld'k gawk)- Bella Klein-Accountan Email Wily CEJK 12V . Assistants Lcslic GrofoE Scc) Email Hclan Kim Email Michelle-Compos- Email Progm Keith Blumberg Email Engineer Ill Richard Bamctl I 23:22? ?gamed? F- Computers Mark Residences of Mr. Jeffrey Epstein 9 East 71" Street. New York NY 1002] Mr. Jeffrey Epstein Ms. Ghislaine Maxwell _s_ta_rr House Manager Jojo llousc Manger Staff Phone Brent Tindall 02/11/2015 Page 2305 Public Records Request No_: 16-268 GIUFFRE007843 Yr - Pest Control Case 18-2868, Document 283, 08/09/2019, 2628241, Page850 of 883 ?17: I Palm Beach Contractors Ll General Plumbing Customer Service representative Amy 56! 585 259l Electrical Reel Power Inc Lenny (electrician) 561 706 0827 Gates Samco Systems Sam (owner) 561 71?) 4832 Service gate switch: above garage door controls, when round light is on Front gate switch: just above the telephone outlet kitchen area Garage doors The Door Smith Inc Keith Kelly Telephones Southern Bell (repairs) 56! 780 2355 Internal Phone system Repair and Programming 56! 88l 81 18 Alarm System Benham Industries Inc Keith 854 49 4] l2 Locksmith Wilson Rowan 56l 655 3637 Maintenance Cassidy 24 hr service Handyman Carlos (caypenter) In? Landseam Alan Stopcck Palm Beach Extenninator Kim 56l 844 8082 Irrigation Dolphin Sprinkle 56] 478 4696 Pool Heating National Pool Service When needed 56] 585 8866 Pool Maintenance Hack Pool Service Monday/ Thursday 56] 588 7493 Tree Trimming Country Wide Trees Twice, summer/winter 56] 371 5786 Carat Cleaners Stanley Steamers wall to wall 56l S86 5700 Men?y Rug area rug 56] 588 8588 q? 02/11/2015 Page 2306 Public Records Request No.: 16-268 GIUFFRE007844 Case 18-2868, Document 283, 08/09/2019, 2628241, Page851 of 883 . i gt; 0 'Pofi?? 3 5 Cable Adelphia cable Cable TV Bottled Water. Bishop water company nob?omen; Frank Jennes g_a? Gas Energy Inc (Joe Di Giovanni) all gas repairs) Laundg equipment May Tag Painter Sam Contact Lenny Storage Storage USA 5580, Okeechobee Unit 6218 Croceg 8: General Household items General Grocery Publix 265. Sunset Ave Gourmet food est si bon 289, Sunset Avion water 24mm 2401 PGA Take 95 North to PGA Too Jays Gravclox/ Nova sliced salmon Green Pharmagy 15 ., County Road Flowers Extra touch Flowers MILE Home Depot Sewell Hardware 528, Clematis Street Newsgagrs Main Street News 255. Royal Poinciana Way Eggt Q?ice 401, South County Road, Car Detailing George Taxi Service/Limo Dan Tischen FedEx l44208l6 (Monday Thursday) Recycling Every Thursday 6AM to 5PM Trash collection M-F once a day Early Morning Cars Mercedes of Palm Beach Chevrolet Auto Repairs Gray Sunoco 340 South County Nestor Auto 2600, Florida Avenue GasolincGray Sunoco Au. lick/192108) 02/11/2015 Page 2307 33?15787'77 ?Aged .I - ageogyl 33/22.. x/ sumo ?gee-cw?wcn 0 561582 1367 56l 963 0505 1800 622 4729 56l 683 5835 56l 655 4120 561 659 6503 561 775 9233 56l 655 6545 561 332 4443 56] 835 8000 56] 832 0783 561 832 7171 56] 833 4027 56l 832 0697 [043 561 689 6393 56l 683 8l00 56l 655 6645 561 835 0809 sol-71385581 Public Records Request No.: 16?268 GIUFFRE007845 Case 18-2868, Document 283, 08/09/2019, 2628241, Page852 of 883 MW. >1 Wm 7% WOW ij/DM SUUQ 2? 614 ??151 1e 1 "17v;- V- 1 {2193-181 19 ., .v?L L. [.6715 ~62th (F: (A C199 4? (?53213 02/11/2015 Page 2308 Public Records Request No_: 16-268 GIUFFRE007846 Case 18-2868, Document 283, 08/09/2019, 2628241, Page853 of 883 'wuyd?s haw +0 301.. ano-Iu. - - elm ?Ir/2w. all? 5?57 Pm ., 11150 - km gou? can 3% ?eas; MU. km. (,llq 102?00?. Team Lvo ??mw Lia/03? $33-01 WNW be Mm 11.30% oc/ob ?bhqlor? ltoofm RM Loo Four seasM? we .. (,hflos" qm WW - Tm?I?uodd .Com frowns 02/11/2015 Page 2309 Public Records Request No_: 16-268 GIUFFRE007847 Cam: 18-7868, 782, 08/00/7010, 7678741, PangRA nf 882 EXHIBIT 46 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, of 883 SSA-1826 ITEMIZED STATEMENT OF EARNINGS SOCIAL SECURITY ADMINISTRATION EARNINGS RECORD INFORMATION Date: 10/25/2016 Our records show the amount of earnings reported, not the amount of Social Security taxes that were paid. Wages were first covered under Social Security in 1937. Therefore, 1937 is the first year for which earnings may be shown on our records. Employers were required to report earnings semi-annually in 1937, and on a quarterly basis for the years from 1938 through 1977. Beginning with 1978, employers are required to report earnings annually. Our records do not show the exact date of employment (month and day) because we do not need this information to figure Social Security benefits. Employers do not give us this information. Each year, there is a maximum amount of earnings that is subject to Social Security taxes and is used to compute benefits. If a person earns more than this maximum amount, the earnings statement will usually show the maximum rather than the total earnings. Maximum benefits can be found on the SSA website. Beginning in 1951, self-employed persons could also receive Social Security credit for their work. The maximum amounts of self-employment earnings that are subject to Social Security taxes and are used to compute benefits can also be found on the SSA website. If you have any questions, you should call, write, or visit any Social Security office. If you visit or call, please bring this letter. It will help us answer questions. The toll free number to call is 1-800?772-1213 (for the deaf or hard of hearing, call our TTY number, 1-800-325-0778). GIUFFRE009176 CONHDENHAL Case 18-2868, Document 283, 08/09/2019, 2628241, Page856 of 883 SSA-1826 ITEMIZED STATEMENT OF EARNINGS FOR SSN FROM: SOCIAL SECURITY ADMINISTRATION OFFICE OF CENTRAL OPERATIONS 6100 WABASH AVENUE BALTIMORE MARYLAND 21215 NUMBER HOLDER NAME: VIRGINIA GIUFFRE YEARS REQUESTED: 1998 THRU 2002; 2013 THRU 2015 BOIES SCHILLER AND FLEXNER 401 LAS OLAS BLVD STE 1200 FORT LAUDERDALE FL 33301 EMPLOYER NUMBER: KFC USA INC PAYROLL DEPT 5200 COMMERCE CROSSING DR LOUISVILLE KY 40229-2182 YEAR IST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 1999 $140.70 EMPLOYER NUMBER: SUPER MARKE PO BOX 32018 LAKELAND FL 33802-2018 YEAR QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 1999 $216.69 EMPLOYER NUMBER: ASCENSION CHILD CARE ENTER ASCENSION PEACE CHILD CARE CENTER 2701 STATE ROAD 7 LAUD LAKES FL 33313-2731 YEAR QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 1999 $216.97 PAGE 1 GIUFFRE009177 OOIIZZIOGCSIEMIWBWIWZOO 0000000?) Case 18-2868, Document 283, 08/09/2019, 2628241, Page857 of 883 SSA-1826 ITEMIZED STATEMENT OF EARNINGS FOR SSN EMPLOYER NUMBER: AVICULTURAL BREEDING RESEARCH CENTER ERNEST LAKS 14201 125TH AVE PALM BCH FL 33418-7945 YEAR QTR 2ND QTR 3RD QTR 2000 EMPLOYER NUMBER: SOUTHEAST EMPLOYEE MANAGEMENT COMPANY 2559 PALM DEER DR LOXAHATCHEE FL 33470-2563 YEAR QTR 2ND QTR 3RD QTR 2000 EMPLOYER NUMBER: MAR-A-LAGO CLUB LLC TRUMP DONALD GEN PTR TRUMP ORGANIZATION 1100 OCEAN BLVD PALM BEACH FL 33480-5004 YEAR QTR 2ND QTR 3RD QTR 2000 EMPLOYER NUMBER: OASIS OUTSOURCING v1 2054 VISTA PKWY STE 300 WEST PALM BCH EL 33411-6742 YEAR QTR 2ND QTR 3RD QTR 2000 EMPLOYER NUMBER: NEIMAN-MARCUS GROUP NEIMAN MARCUS GROUP LTD SOLE MBR 1201 ELM ST DALLAS TX 75270-2102 YEAR QTR 2ND QTR 3RD QTR 2000 PAGE 2 4TH QTR 4TH QTR 4TH QTR 4TH QTR 4TH QTR TOTAL $99.48 TOTAL $3,212.44 TOTAL $1,866.50 TOTAL $2,037.60 TOTAL $1,440.79 GIUFFRE009178 Case 18-2868, Document 283, 08/09/2019, 2628241, Page858 Of 883 SSA-1826 ITEMIZED STATEMENT OF EARNINGS FOR SSN EMPLOYER NUMBER: MANNINOS INC MANNINOS RESTAURANT 12793 FOREST HILL BLVD WEST PALM BEACH FL 33414-4749 YEAR 1ST QTR 2ND QTR 3RD QTR 2001 EMPLOYER NUMBER: CCI OF ROYAL PALM INC ROBERT FURR TTEE 2255 GLADES RD STE 337-W BOCA RATON FL 33431-7379 YEAR 1ST QTR 2ND QTR 3RD QTR 2002 EMPLOYER NUMBER: ROADHOUSE GRILL INC ROBERT FURR TTEE IN BANKRUPTCY 2255 GLADES RD STE 337W BOCA RATON FL 33431-7379 YEAR QTR 2ND QTR 3RD QTR 2002 EMPLOYER NUMBER: MARC PINKWASSER DVM PA 13860 WELLINGTON TRCE STE 31 WELLINGTON FL 33414-8541 YEAR QTR 2ND QTR 3RD QTR 2002 EMPLOYER NUMBER: GREAT OUTDOORS PREMI v- OLF RESORT COMMUNITY Assoc INC 145 PLANTATION DR TITUSVILLE FL 32780-2528 YEAR QTR 2ND QTR 3RD QTR 2014 PAGE 3 QTR 4TH QTR 4TH QTR 4TH QTR 4TH QTR TOTAL $212.00 TOTAL $403.64 TOTAL $1,247.90 TOTAL $1,561.75 TOTAL $171.83 GIUFFRE009179 Anv Manna. . nun-av. . .. "Iv '10an Izumrnn Cam: 18-7868, 782, 08/00/7010, 7678741, PangRq nf 882 EXHIBIT 47 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page860 of 883 Monday, November 7, 2016 Page: 1 1Quicken Data - All Accounts QuickReport by Description 8/12/69 through 1/29/03 Date Account Num Payee Memo Category I 4/22/02 Courtyard Animal Hospital 1500 Virginia Roberts split 5/6/02 Courtyard Animal Hospital 1522 VOleirginia Roberts 5/6/02 Courtyard Animal Hospital 1523 Virginia Roberts split 5/20/02 Courtyard Animal Hospital 1541 Virginia Roberts split 6/4/02 Courtyard Animal Hospital 1555 Virginia Roberts split Total 8/12/69 - 1/29/03 Total Inflows Total Outflows Net Total GIUFFRE009203 CONFIDENTIAL Cam: 18-7868, 782, 08/09/7010, 7678741, Pangm nf 882 EXHIBIT 48 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page862 of 883 Forwarded message From: coss@aclimepmation.com> Date: 2 January 2015 at 20:29 Subject: Re; - this is the statcmom To: 6 Max <gmaxl @cllmax.oom> Cc: Philip Bardcn OK going with this, thanks Philip. Sent from my BlackBerry' wireless device From: Date: Fri, 2 Jan 2015 20:14:53 +0000 To: Ross Cc: Philip Subject: FW: URGENT - this is the statement Jane Doe 3 Is Virginia Roberts so not a new Individual. The allegations made by Victoria Roberts against Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue Each time the story is re told it changes with new salacious details about public ?gures and world leaders and now it is alleged by Ms Roberts that Alan is involved in having sexual relations with her, which he denies Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. EXHIBIT gL Cam: 18-7868, 782, 08/00/7010, 7678741, PangBR nf 882 EXHIBIT 49 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page864 of 883 TERMINATIONS LAST NAME Rinker Rivera Rivera Rivero Robbins Roberts Roberts Roberts Robsham Rodriguez Rodriguez Rodriguez Rodriguez Rogers Romeus Rony Roqueta Rose Rosenberg Rosier Rotchford Rubio Rueda Ruiz Russeau Russell Russotto Ryan Ryan Saint Gerard Saint Surin Salloum Salman Salvador Sanford Santos Sasaki Saunders Savage Savoie Scanlan Schlechter Schmantowsky Schoonover Schroeder Schumacher Schwab Scotland Scott FIRST NAME Ross Pablo Eduardo Alicia Jody Virginia Walter Diane Lydie Francisco Abel Kenia Aristalia Howard Melege Jean Maria Cheryl Bradley Sandra Bernadette Pascual Maria Juan Heidi Kathryn Vincent Megan Michael Manes Jacquest Adib David Marian Kevin Elimos Shoko Sarah Angelia Terry Peter Melissa Craig Richard Glenn Patricia Emily Jaycen Cecelia Box #7 Box #3 Box #2 Box #7 Box #4 Box #4 Box #4 Box #3 Box #7 Box #4 Box #3 Box #3 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #4 Box #2 Box #4 Box #2 Box #4 Box #4 Box #7 Box #2 Box #7 Box #7 Box #2 Box #2 Box #2 Box #2 Box #5 Box #2 Box #7 Box #2 Box #5 Box #2 Box #5 Box #5 Box #2 Box #2 Box #5 Box #2 Box #2 Box #7 Box #2 Page 13 of 17 MAR-A-LAGO 0173 Case 18-2868, Document 283, 08/09/2019, 2628241, Page865 of 883 TERMINATIONS LAST NAME Vasquez Vasquez Vaughn Velasquez Vidalis Voluck Vyskrebentsev Wahl Walker Walkowiak Wallace Ward Webb Weber Weidner Weisman Wentworth Weslowski White Whitley Whitney Whittle Wilburn Williams Williams Williams Williams Williams Willoughby Willson Willson Woolf Wynn Yancey Yancey Yeskey Young Zervoulis Zivkovic Zorn Zwick FIRST NAME Sosmar Christian Matthew Rodollfo Chantal Justin Aleksey Steven Sylvia Toni Philip Terry Jacob Ronald James Brian Gayle Elaine Scott Deborah Moriah Tamara Jennifer Arhon Gretchen Jacqueline Ellen Kristin William Howard Joseph Elena Beverly Kathryn Scott Dean Martin Todd Matthew Milo Christopher Danielle Box #1 Box #2 Box #3 Box #4 Box #5 Box #6 1998 terms 1998 & 1999 terms 1999 terms 2000 terms 2000 terms 2001 terms Box #5 Box #2 Box #2 Box #2 Box #2 Box #2 Box #5 Box #5 Box #7 Box #7 Box #2 Box #5 Box #7 Box #2 Box #7 Box #2 Box #2 Box #2 Box #5 Box #7 Box #7 Box #2 Box #2 Box #2 Box #2 Box #2 Box #7 Box #7 Box #2 Box #5 Box #2 Box #2 Box #2 Box #2 Box #7 Box #5 Box #2 Box #2 Box #2 Box #7 Box #2 Page 16 of 17 MAR-A-LAGO 0176 Cam: 18-7868, 782, 08/00/7010, 7678741, PangBB nf 882 EXHIBIT 50 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page867 of 883 EXHIBIT 1 2 Case 18-2868, Document 283, 08/09/2019, 2628241, Page868 of 883 Case Decanters; 280 Eeteredm FLSD Deeket 0110212015 Page 1 0f14 UNITED STATES DISTRICT COURT SOUTEHQRN OF FLGRIDA Case Ne. JANE BGE #1 and JANE DOE #2 V. UNITED STATES JANE DOE #3 MD JANE EOE #4?5 CORRECTEB MGTIQN PURSUANT TO RULE 21 FGR JOINDER IN ACTION COME NOW Jase Dee #3 and Jane Bee #4 (else referred te as ?the new victims?)? by and through undersigned counsel, to file this metion pursuant to Federal Rule ef Civil Procedure 21 re jein this action, era the cenditien that they not re?litigete any issues already litigated by Jane Dee #1 and Jane Dee #2 (else referred te as ?the current Victims?). The new victims have suffered the same vieiatiehs of their rights under the Crime Victims? Rights Act (CVRA) as the current victims, Accordingly, they desire to jeiri in this aetien t0 yiedieate their rights as weil. Because the new Victims will set reditigate any issues preyinssiy litigated by the current victims (and because they are represented by the same legai eeurisel as the current victims), the Government will net be prejudiced if the Ceurt grants the motion. he Court may ?at any time? add new parties te the action, Fed. R. Civ. Pg 21. the sheuid greet. the Iiietien.1 3 As mirror victims of sexual effenses5 Jane Dee #3 and Jase Bee #4 desire is proceed by way of pseudonym for the same reasons that Jane Dee #1 and Jane Doe #2 in this fashien. Ceunsel for the new Victims have made their true identities known to the Government. Case 18-2868, Document 283, 08/09/2019, 2628241, Page869 of 883 Case Decument 280 Entered en FLSD Becket 01i02/2015 Page 2 5:114 As the Ceurt is aware, mere than ?stir years age; Jane Dee#l filed the present aetien against the Gevernrnenta alleging a violation at" her rights under the CVRA, 18 U.S.C. 3771. DEL She alleged that Jeffrey Epstein had sexually abused her and that the United States had entered inte a secret nen-preseentien agreement (NPA) regarding these crimes in vieiatien of her rights. At the that court hearing on the ease, the Court allewed Jane Dee #2 t0 also join the action. Beth Jane Dee #1 and Jane Dee #2 specifically argued that the government had failed, to protect their CVRA rights (inter alia) tn center, to reasonable notice, and to be treated with fairness. in response, the Gnvernment argued that the CVRA rights did not apply tn Jane Dee #1 and ane Dee #2 because no federal charges; had ever been filed against Jeffrey Epstein. The Ceurt has ?rmly rejected the United States? position, In a detailed ruling: the (Jean; concluded that the CVRA extended rights to Jane Dee #1 and Jane Dee #2 even thengh federal Charges were never filed. DE 189. The Court captained that heeanae the NPA barred prosecution ef crimes eemmitted against them by Epstein, they had ?standing? to assert violations of the CVRA rights. Id The Cnurt deferred ruling on Whether the two Victims weuld be entitled to relief, pending development at a fuller evidentiary Id. ??ve other Vietints, whe are in many respects similarly situated to the current victims, now wish to join this actien. The new victims joining at this stage will not cause any delay and their jeinder in this case is the mast expeditions manner in which to pursue their rights. Because the background regarding their abuse is relevant to the Ceurt?s assessment of whether to allow them to join, their are recounted here brie?y. Jane Dee eit?a Cirenrnataneea Case 18-2868, Document 283, 08/09/2019, 2628241, Page870 of 883 Case Dccument 280 Entered on {Jacket 01102!2015 Page 3 0f 14 As with Jane Dec #1 and. ans D03 Jane Has #3 was repeatedly ngually abused by Epgtein, Case 18-2868, Document 283, 08/09/2019, 2628241, Page87l of 883 Case 18-2868, Document 283, 08/09/2019, 2628241, Page872 of 883 Case Document 280 Eatered 0n REE Docket 01/02/2015 Page 5 0f 14 f9; Case 18-2868, Document 283, 08/09/2019, 2628241, Page873 of 883 Case Deeumet?it 280 Entered or: FLSD Docket 01102/2015 ?Page 6 at 14 The Government was welt aware of Jane Doe #3 when it was hegetiating the NPAhas it listed her he a victim in the attachment to the NPA. Moreover, even a rudimentary investigatien of Jane Doe #3?3 relationship to Epstein wouid have revealed the fact that she had been traf?cked throughout the United States and internationally for sexuat purpeses. Nonetheless, the Gevetnmeht secretly negotiated a non?preseeution agreement with Epstein preeiuding Federal prosecutien in the Southern Distriet of Flerida of Epstein and his ee~eenspiratere As with Jane Doe and Jane Doe #25 the Government concealed the nonmpreseeutien agreement ?retn ahe Dee #3 at} in vieiatien of her tights under the CVRA - te aveid Jane Doe #3 from raising pewet?ti ebj eetiens to the NPA that weuld have shed tremende?es public light on Epstein Case 18-2868, Document 283, 08/09/2019, 2628241, Page874 of 883 Case Basement 280 Entered pp FLSD Deeket 01/02l2015 Page bf .14 and other powerful individuals and that would likely have been presented it from being conelnde? in the secretive manner in which it was. ?lane Dee #4?5 Cireumstanees If permitted to join this action, Jane Doe #4 would allege, and could press at trial, that she has CVRA claims similar to those advanced ?by Jane Bee #1 and Jane Bee based on the following: As with the other Jane Does, Jane Dee #4 was repeatedly sexually abused by Epstein, In or areund the summer of 2002, Jane Doe an peer and vnlnerable sixteeneyear- old child, was told by another one of Epstein?s underage minor sex abuse victims, that she could make $300 cash by giving an old man a massage on Palm Beach. An acquaintance ef Jane Doe #4 (also a minor sexual abuse victim at Epstein) telephoned Epstein and scheduled Jane Doe #4 to ge to Epstein?s hense to give him a massage. During that call, Epstein himself get on the phene (a means of interstate eommanicatien) with Jane Dee asking her persenally te come to his mansion in Palm Beach. Jane Doe #4 then went to Epstein?s mansion and was escorted upstairs to Epstein?s large bathroom by one of Epstein?s assistants. Shortly thereafter Jeffrey Epstein emerged and lay face down en the table and told lane Dee #4 to start massaging hint. Epstein asked lane Bee #3 her age and sire told hirn she had recently turned sixteen. Epstein subsequently committed illegal sexual acts against Jane Bee #4 on many occasions. Epstein used a means of interstate eemmnnicatien (is, a cell phone) to arrange far these sexual encounters. Epstein also frequently travelled in interstate commerce (in, on his personal jet) for pnrposes of illegally sexually abusing Jane Doe 7 Case 18-2868, Document 283, 08/09/2019, 2628241, Page875 of 883 Case 9:08Aevm80788uKAM Document 280 Entered on FLESH Doeket01i02/2015 Page 8 of 14 The nets Epstein against Jane Doe constituted numerous federal sex offenses, some of which do not carry a statute of limitatieus and thus are not tiruebarred. Seem U.S.C. 3283. And these offenses were the kinds of offenses that the Federal Bureau of Investigation (FBI) and Us. Attorney?s Of?ce for the Southern District of Florida were pursuing in 2007aware? the US. Attorney?s Office made no serious effort to locate her. Instead, after identifying approximately forty separate underage sexually abused Victims, and apparently preparing a 53?page federal indictment and with full awareness of the existence at many victims like Jane Doe #4 unidenti?ed and not interviewed it entered into a non-prosecution, agreement barring prosecution of Epstein?s federal crimes against these victimst This is contrary to the Government?s normal approach in prosecuting federal sex offenses. It also violated Jane Doe #4?3 rights under the including the fact that she had a ?reasonable? right to confer with the US. Attorney?s Office before they entered into an agreement with a sex offender barring prosecution of hire for the crimes he committed against 3771(a)(5)- MOTIQN FOR BINDER Jane Doe and Jane Bee #4 now beth more to join this action Bee #1 and Jane Doe #2,.pursuant to Rule 21 of the Federal Rules of Civil Procedure, Rule 21 provides that motion or on its own, the eourt may at any time, on just terms, add a party.? Rule 21 an: ?grants the court bread discretion to permit a change in the parties at any stage of a litigation.? Ford Air Line Pilots Ass a In: t, 268 F. Supp 2d 271, 29s (E.D.N.Y. 2093) (internal quotation omitted), The new victims should he allowed to join the current vietima in this action under Rule 21. Case 18-2868, Document 283, 08/09/2019, 2628241, Page876 of 883 Case Document 280 Entered on PLSD Docket 011032015 Page 9 of 14 The new Victims will establish at trial that the Government violated their CVRA rights in the same way as it violated the rights of the other victims. The new victims? participation in this case is important because it appears that the Government intends to raise a factual defense that somehow it did keep Jane Doc #1 and Jane Doe properly informed of what was happening in the erirninal prosecution. Of course; if four Victims ail testify consistently that they were not ?properly infonned by the Government (as we believe they Krill), that provides a stronger ease for a CVRA violation. addition, Jane Doe #3 and Jane Doe #4?5 participation is relevant to a defense the Court has allowed the Government to raise. The Court has previously ruled that the vietirns? request for rescission of the NPA ?implicates a faobsensitive equitable defense which must be considered in the historical factual context of the entire interface between Epstein, the relevant prosecutorial authorities and the federal offense victims including an assessment of the allegation of a deliberate conSpiraey between Epstein and federal prosecutors to keep the victims in the dark on. the pendenoy of negotiations between Epstein and federal authorities until Well after the fact and presentation of the non-proseoution agreement to them as a?rr?t accompirl? DE 189 at 12 no (emphasis added). Jane Doe #3?5 and Jane Doe #4?5 participation in this ease will help to show what the ?entire interface? was between the Government and the Victims and thus to respond to the Government?s estoppel arguments as well as other defenses that it appears to be preparing to raise. See, rag, DE 62 (52?page response from the Government to the victim?s summary judgment motion, raising numerous factually?based and other arguments against the Victim?s position) Case 18-2868, Document 283, 08/09/2019, 2628241, Page877 of 883 Case Document 280 Entered on FLSD Docket 01i02/2015 Page .10 of 14 Jane Doe #3?sand Jane Doe #4?s participation is also directly relevant to the discovery disputes currently pending in this case. The Government has raised various relevancy objections to the documents that Jane Doe #1 and Jane Doe #2 are attempting to obtain. The current victims have responded by explaining how these documents are relevant, including explaining how these documents might hear on the way in which Epstein used his powerful political and social connections to secure a favorable plea deal, as well as provide proof of the Government?s motive to deliberately fail. to investigate certain aspects of the victims? claims in an effort to maintain the secrecy of the facts and resolve the ease without the victims? knowledge. See, eg, DE 266 at 6?18. Jane Doe #3 and Jane Doe #4?s participation will help prove the relevancy of these requests, as well as the need for those requests. One clear example is Request for Production No. 8, which seeks documents regarding Epstein?s lobbying to persuade the Government jg give hint a more favorable plea arrangement and/or non-prosecution agreement, including efforts on his behalf by Prince Andrew and former Harvard law Professor Alan Dershowitz. Jane Doe #l and Jane Doc #2 have alleged these materials are needed to prove their allegations that, after Epstein signed the non~proseention agreement, his performance was delayed while he his signi?cant social and political connections to lobby the nstice Department to obtain a more favorable plea deal. See, age, DE 225 at 7-8 (discussing DE 48 at 1648), Jane Doc #3 has directly person knowledge of Bpstein?s connection with some of these powerful people and thus how Epstein might have used them to secure favorable treatrn ent. Adding two new victims to this case will, not delay any of the proceedings. They will simply join in motions that the current victims were going to file in any event. For example, the 10 Case 18-2868, Document 283, 08/09/2019, 2628241, Page878 of 883 ?Case Document 280 Entered on FLSD Docket 0110212015 Page 11 of 14 new Vioti?msmwill simply join in a single summary judgment motion that the current Viotitns anticipate tiling after discovery has been completed. Nor will adding the new victims prejudice the United States. ?As the sourt is aware; this Court is still in its initial discovery stage. The Court is currently considering whether to reject the Goverrunent?s assertion of privilege over documents regarding the ease. See DB 265 (victims? reassertion of objections to the Government privilege claims). The new Victims do not seek any additional discovery beyond that previously sought by the current Vidtii?r?t?t.2 Accordingly, the United States will not be prejudiced or burdened by adding them to this case. The CVRA does not oontain any statute of limitations for ?ling an action to enforce rights under the statute, Accordingly: were the Court to deny this motiona the result might be that the new victims would then be forced to file a separate suit raising their claims; which would then possibly proceed on a separate litigation track. Rather than require duplicativewlitigation, the Court should simply grant their motion to join. Jane Doe #1 and Jane Doe #2 support the joinder motioni Counsel for the Victims have discussed this motion with the Government at length in an effort to avoid any need to file a substantive pleading on the issue. Counsel for the Vietirns asked the Government during the summer for its position on joinder. The Government, however, took the matter under advisement for months. Ultimately, after several inquiries front viotirns counsel, the Government indicated without explanation that it opposes this motion. Counsel for the victims has requested a meeting with the Government on this issue, which will occur in 2 Jane Doe #3 and Jane Doe #4 have asked the Government to provide them with the record of their ?statements that they provided to the FBI, These FBI 382?s should be only a few pages long, ll Case 18-2868, Document 283, 08/09/2019, 2628241, Page879 of 883 Cage Document 280 Entered 0n FLSD Docket 01/022015 Page 12 of 14 January. In the. maantime, 601133861 for tha victims believe ihat it is 139 101136: appropriate t0 delay filing this motion and accordingly ?ls it at this tima. Because the Gowrnment is apparently 0333395ng this motion, Jane 1303 #3 and Jam: D06 #4 have described the circumstancss surreunding their claims 30 that the Gear: has apprapriat? infermation to rah-3 on the metion, Case 18-2868, Document 283, 08/09/2019, 2628241, Page880 of 883 Case Deeumept 280 Entered or: FLSD Docket 0110212018 Page 13 pt 14 Jane Dee #3 and large Dee #4 sheuid be aliowed to jein this adieu, pursuant te Rule 21 of the Federal Rules pf Civil Prpeedure, Their jeinder sheuld he eunditipned err the requirement that they not re?litigate arty issues previously iitigated ?iahe Due #1 and Jane Dee A proposed order to that effect is attached to this pleading. DATED: l'ertuarv 2 2015 Respectfully Submitted, 15/ Bradleyr 3. Edwards Bradiey 5. Edwards FARMER, JAFFE, REWARDS, FISTOS 65 PL, 425 North Andrewe Avenue, Suite 2 Fort Lauderdale, Flerida 33301 Telephone (954) 5242820 Facsimile (954) 524?2822 Email: brad@pathtuj And Paul G. Carrel} Pro Hac Vice. Quinrrey College pf Law at the University pf Utah? 332 S. 1408 E. Salt Lake City, UT 84-112 Telephone: 801-585?5202 Facsimiie: 881-585~6833 E-Mail: caeselipditlewutehedu Arrprueysfur Jane Doe #1 and Jane Due #2 mThis daytime business address is provided fer identi?cation and correspondence purposes early and is not intended :0 imply institutional endorsement by the University of Utah Case 18-2868, Document 283, 08/09/2019, 2628241, Page881 of 883 Cage 9:08-cvm80736-KAM Decument 280 Entered 0n FLSD {Docket 01i02/2015 Page 14 0114 CERTIFICATE OF SERVICE I certify that the foragoing document was servcd {an January 2, 20155 011 the follewing using the Court?s system: Dexter Lee A. Marie Villafa?a 500 S. Augiralian Ava, Suite Wast Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E?ma?: Dcxter.Lee@usd0j.ng E-ma?: Arrarney?for the Gavemmem? is/ Bradkv J. Edwards Cam: 18-7868, 782, 08/00/7010, 7678741, PangRQ nf 882 EXHIBIT 51 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page883 of 883 GIUFFRE009209 CONFIDENTIAL Selected docket entries for case 18−2868 Generated: 08/09/2019 10:07:40 Filed Document Description 08/09/2019 284 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED 08/09/2019 285 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED 08/09/2019 286 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED 08/09/2019 287 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED Page Docket Text 2 UNSEALED SUMMARY JUDGMENT RECORD, appendix 10 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628244] [18−2868] 40 UNSEALED SUMMARY JUDGMENT RECORD, appendix 11 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628246] [18−2868] 44 UNSEALED SUMMARY JUDGMENT RECORD, appendix 12 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628248] [18−2868] 99 UNSEALED SUMMARY JUDGMENT RECORD, appendix 13 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628251] [18−2868] Case 18-2868, Document 284, 08/09/2019, 2628244, Page1 of 38 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------------- ............................................. VIRGINIA L. GIUFFRE, 15-cv-07433-RWS Defendant’s Reply to Plaintiff’s Statement of Contested Facts and Plaintiff’s “Undisputed Facts” Pursuant to Local Civil Rule 56.1 Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 303.831.7364 Case 18-2868, Document 284, 08/09/2019, 2628244, Page2 of 38 Pursuant to Rule 56.1 of the Local Civil Rules of this Court, defendant Ghislaine Maxwell submits this Reply to Plaintiff’s Statement of Contested Facts and Plaintiff’s Undisputed Facts (“Response”), Doc. 586-1. INTRODUCTION Plaintiff’s Response fails under both the Federal Rules of Evidence and the Local Civil Rules of Procedure. First, Plaintiff largely failed to provide any “citation to evidence which would be admissible” to challenge Defendant’s Statement of Material Undisputed Facts and therefore Ms. Maxwell’s undisputed facts should be deemed admitted. Second, rather than set forth “additional material facts as to which it is contended that there exists a genuine issue to be tried” (Local Civil Rule 56.1(b)), Plaintiff instead set forth her own purportedly “undisputed facts.” Because Plaintiff did not cross-move for summary judgment, her supposedly “undisputed facts” are not permitted by the Rules and should be stricken. I. Ms. Maxwell’s reply in support of statement of undisputed facts. 1. Undisputed Fact 1: In early 2011 plaintiff in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. In the articles, plaintiff made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, plaintiff suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. Exs. A and B. a. Reply: Plaintiff cites no admissible evidence to contest these undisputed facts. McCawley Ex.34 (GIUFFRE368) is an email from Sharon Churcher to Plaintiff. It is Ms. Churcher’s hearsay and therefore inadmissible. In any event, it does not speak to the 1 Case 18-2868, Document 284, 08/09/2019, 2628244, Page3 of 38 contents of Plaintiff’s interviews with Churcher. McCawley Decl. Ex. 31 is an FBI interview, also inadmissible hearsay, which again does not describe Plaintiff’s interviews in news articles. In the absence of contrary evidence, Undisputed Fact 1 should be deemed admitted. 2. Undisputed Fact 2: In the articles, plaintiff alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” Exs. A-B at 5. a. Reply: Plaintiff does not contest these facts and they therefore should be deemed admitted. 3. Undisputed Fact 3: In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.” Ex.C. a. Reply: Plaintiff “denies” that Mr. Barden “issued a statement,” but offers no admissible evidence to refute this point. Further, she acknowledges that the Statement was issued “By Devonshires Solicitors,” Mr. Barden’s law firm. 4. Undisputed Fact 4: The statement read in full: Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 2011 London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. It is unacceptable that letters sent by Ms Maxwell’s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers. 2 Case 18-2868, Document 284, 08/09/2019, 2628244, Page4 of 38 “I understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop,” said Ghislaine Maxwell. “A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-251 Email: ross@acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: +44-203008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com Ex.C. a. Reply: Plaintiff does dispute the contents of the 2011 statement and therefore it should be deemed admitted. 5. Undisputed Fact 5: Plaintiff’s gratuitous and “lurid” accusations in an unrelated action. In 2008 two alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against the United States government purporting to challenge Epstein’s plea agreement. They alleged the government violated their CVRA rights by entering into the agreement. Ex.D, at 2. a. Reply: Plaintiff “stipulates” to the facts contained in paragraph 5 and therefore they should be deemed admitted. 6. Undisputed Fact 6: Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action, claiming she, too, had her CVRA rights violated by the government. On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. Ex.D at 1, 9. a. Reply: Plaintiff “agreed” to this paragraph. 3 Case 18-2868, Document 284, 08/09/2019, 2628244, Page5 of 38 7. Undisputed Fact 7: The issue presented in her joinder motion was narrow: whether she should be permitted to join the CVRA action as a party under Federal Rule of Civil Procedure 21, specifically, whether she was a “known victim[] of Mr. Epstein and the Government owed them CVRA duties.” Yet, “the bulk of the [motion] consists of copious factual details that [plaintiff] and [her co-movant] ‘would prove . . . if allowed to join.’” Ms. Giuffre gratuitously included provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual trafficking. Ex.E, at 5. a. Reply: Plaintiff does not dispute that Judge Marra made the findings detailed in Undisputed Fact 7. Further, she admits that the Government refused to stipulate that she “had been sexually abused by Jeffrey Epstein and his co-conspirators (including coconspirator Alan Dershowitz), which would make her a ‘victim’ of a broad sex trafficking conspiracy.” Although she now submits there were other reasons for inclusion of such lurid details, those reasons were rejected by Judge Marra. As she does not offer any admissible evidence to contradict the findings made by Judge Marra, this “fact,” specifically Judge Marra’s findings, should be deemed admitted. In any event, we request under Fed. R. Evid. 201(c)(2) that the Court take judicial notice of the contents of Judge Marra’s ruling and order. 8. Undisputed Fact 8: At the time they filed the motion, Ms. Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA action. While they deliberately filed the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. Ex.D, at 1 & n.1. 4 Case 18-2868, Document 284, 08/09/2019, 2628244, Page6 of 38 a. Reply: Plaintiff offers no admissible evidence to refute these facts and they therefore should be deemed admitted. Specifically, she does not offer any evidence to dispute that she knew the media had been following Epstein and the CVRA action, nor does she dispute that her attorneys made no attempt to file the motion under seal, rather filing it publicly. The facts are thus admitted. 9. Undisputed Fact 9: As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several individuals, and she offers details about the type of sex acts performed and where they took place.” The court ruled that “these lurid details are unnecessary”: “The factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent . . ., especially considering that these details involve non-parties who are not related to the respondent Government.” Accordingly, “[t]hese unnecessary details shall be stricken.” Id. The court then struck all Ms. Giuffre’s factual allegations relating to her alleged sexual activities and her allegations of misconduct by nonparties. The court said the striking of the “lurid details” was a sanction for Ms. Giuffre’s improper inclusion of them in the motion. Ex.E at 5-7. a. Reply: Plaintiff offers no admissible evidence to refute these facts and they therefore should be deemed admitted. See Reply to Undisputed Fact 7, supra. In any event, we request under Fed. R. Evid. 201(c)(2) that the Court take judicial notice of the contents of Judge Marra’s ruling and order. 10. Undisputed Fact 10: The district court found not only that the “lurid details” were unnecessary but also that the entire joinder motion was “entirely unnecessary.” Ms. Giuffre and her lawyers knew the motion with all its “lurid details” was unnecessary because the motion 5 Case 18-2868, Document 284, 08/09/2019, 2628244, Page7 of 38 itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. The court denied plaintiff’s joinder motion. Id. at 7-10. a. Reply: Plaintiff offers no admissible evidence to refute these facts and they therefore should be deemed admitted. See Reply to Undisputed Fact 7, supra. 11. Undisputed Fact 11: One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion, Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein:  Ms. Maxwell “approached” plaintiff in 1999 when plaintiff was “fifteen years old” to recruit her into the scheme.  Ms. Maxwell was “one of the main women” Epstein used to “procure underaged girls for sexual activities.”  Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme.  She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.”  At the mansion, when plaintiff began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.”  Epstein “with the assistance of” Ms. Maxwell “converted [plaintiff] into . . . a ‘sex slave.’” Id. Plaintiff was a “sex slave” from “about 1999 through 2002.”  Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.”  Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.”  Ms. Maxwell “participat[ed] in the sexual abuse of [plaintiff] and others.”  Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [plaintiff].” Id. She shared the photos with Epstein. 6 Case 18-2868, Document 284, 08/09/2019, 2628244, Page8 of 38  As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect[ed]” Epstein with “powerful individuals” so that Epstein could traffick plaintiff to these persons.  Plaintiff was “forced to have sexual relations” with Prince Andrew in “[Ms. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” plaintiff’s sex with Prince Andrew “by acting as a ‘madame’ for Epstein.”  Ms. Maxwell “assist[ed] in internationally trafficking” plaintiff and “numerous other young girls for sexual purposes.”  Plaintiff was “forced” to watch Epstein, Ms. Maxwell and others “engage in illegal sexual acts with dozens of underage girls.” Id. at 3-6. a. Reply: Plaintiff offers no admissible evidence to refute the facts actually stated in the paragraph, i.e., that the “lurid” details (as coined by Judge Marra) were included in her CVRA Joinder Motion. Plaintiff claims to offer “admissible evidence” to “corroborate the statements [she] made in the joinder motion.” Setting aside for the moment that most of the cited documents are inadmissible hearsay, as addressed later, such evidence should be disregarded because none of the offered documents speak to fact that these “lurid” details were actually included in the joinder motion, as a simple reading of Ex.D reveals. Because Plaintiff does not refute that point, the fact that the details were in the Joinder Motion should be deemed admitted. In any event, we request under Fed. R. Evid. 201(c)(2) that the Court take judicial notice of the contents of plaintiff’s CVRA joinder motion. 12. Undisputed Fact 12: In the joinder motion, plaintiff also alleged she was “forced” to have sex with Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and “many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.” Id. at 4-6. 7 Case 18-2868, Document 284, 08/09/2019, 2628244, Page9 of 38 a. Reply: Again, Plaintiff offers no evidence that these “lurid details” were included in the Joinder Motion, as indeed they were, and thus the fact that they were should be deemed admitted. 13. Undisputed Fact 13: Plaintiff said after serving for four years as a “sex slave,” she “managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.” Id.at 3 a. Reply: Plaintiff does not dispute that she made this statement in her joinder motion and it is admitted. 14. Undisputed Fact 14: Plaintiff suggested the government was part of Epstein’s “conspiracy” when it “secretly” negotiated a non-prosecution agreement with Eptstein precluding federal prosecution of Epstein and his “co-conspirators.” The government’s secrecy, plaintiff alleged, was motivated by its fear that plaintiff would raise “powerful objections” to the agreement that would have “shed tremendous public light on Epstein and other powerful individuals. Id. at 6-7. a. Reply: Plaintiff does not contest the quoted contents of the joinder motion, but rather offers argument regarding Plaintiff’s purported “belief.” Plaintiff did not submit an affidavit attesting to such “belief” and therefore no admissible evidence was cited or offered. The facts should therefore be deemed admitted. 15. Undisputed Fact 15: Notably, the other “Jane Doe” who joined plaintiff’s motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of plaintiff’s allegations. Id. at 7-8. a. Reply: Plaintiff states the facts are “untrue” but offers no admissible evidence to support that statement. She has no affidavit or other statement from “the other ‘Jane 8 Case 18-2868, Document 284, 08/09/2019, 2628244, Page10 of 38 Doe’ (who was represented by Plaintiff’s counsel, and therefore had the ability to furnish such an affidavit). Indeed, Plaintiff acknowledges that the “other Jane Doe” “does not know Ms. Giuffre.” These facts must be deemed admitted. , who is NOT the other Jane Doe, is irrelevant to the undisputed fact asserted. She also offers no corroboration of the ‘same pattern of abuse,’ and in fact does not “remember” any such facts, as already briefed. See Doc. 567 at 12-14. 16. Undisputed Fact 16: Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, plaintiff told Ms. Churcher of virtually none of the details she described in the joinder motion. Exs. A-B. a. Reply: Plaintiff’s protestation aside, the Churcher articles (attached to Ms. Churcher’s sworn affidavit filed in this case at Doc. 216 and 216-1 through 216-8) fail to include the vast majority of details included in Plaintiff’s CVRA joinder motion, as any side-by-side comparison will reveal. Plaintiff’s simple facile response is that she “did reveal details in 2011 consistent with those in the joinder motion.” She offers no admissible evidence of these details she “revealed” to Ms. Churcher, instead citing to a heavily redacted interview she purportedly gave to the FBI, not Ms. Churcher. The purported FBI report is itself hearsay, not to mention, redacted and prepared years after any supposed interview of Plaintiff. McCawley Decl. Ex.31. Because Plaintiff offers no admissible evidence to contradict the discrepancies between the Churcher articles and the joinder motion, these facts should be deemed admitted. 17. Undisputed Fact 17: Ms. Maxwell’s response to plaintiff’s “lurid” accusations: the January 2015 statement. As plaintiff and her lawyers expected, before District Judge Marra in the CVRA action could strike the “lurid details” of plaintiff’s allegations in the joinder 9 Case 18-2868, Document 284, 08/09/2019, 2628244, Page11 of 38 motion, members of the media obtained copies of the motion. Ex.G at 31:2-36:4 & Depo. Exs. 3-4. a. Reply: Plaintiff cites no contrary evidence and therefore the facts should be deemed admitted. 18. Undisputed Fact 18: At Mr. Barden’s direction, on January 2, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing “a quotable statement on behalf of Ms Maxwell.” EX.F; EX.G, at 33:8-23. The email was sent to more than 6 and probably less than 30 media representatives. See Ex.G, at 33:8-34:3. It was not sent to nonmedia representatives. See id. at 31:2-35:21. a. Reply: Plaintiff disputes as “blatant falsehood,” without admissible evidence, that it was Mr. Barden who directed that the January 2 email be sent to media organizations. She then goes on to quote the very section of Mr. Gow’s deposition in which he surmises (but does not know, indicated by his statement it was his “understanding”) that it was something that had been sent to Maxwell by Barden. Indeed, Mr. Barden clears up this confusion in his Declaration, in which he unequivocally swore, 10 Case 18-2868, Document 284, 08/09/2019, 2628244, Page12 of 38 Ex.K ¶ 10. Mr. Gow’s surmise as to how the statement was “forwarded to him” and by whom does not controvert the sworn testimony of Mr. Barden himself. Again, without admissible evidence to the contrary, the facts must be deemed admitted. With regard to the number of media representatives to whom he sent the email, Mr. Gow testified it was between 6 and 30. Ex.G at 33-34. His further testimony, offered by Plaintiff, that he spoke to “over 30 journalists” does not contradict that statement. Nowhere does Plaintiff offer testimony that he read the statement to over 30 journalists. Instead, Mr. Gow acknowledged it was “very possible” that he had “ever read[] the statement to press or media over the phone,” not that he read it to “over 30 journalists.” Plaintiff’s selective cutting and pasting undercuts her so called evidence that the facts in Paragraph 18 are “false,” and thus they ought be deemed admissible. 19. Undisputed Fact 19: Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. These representatives were selected based on their request—after the joinder motion was filed—for a response from Ms. Maxwell to plaintiff’s allegations in the motion. See, e.g., EX.G, at 30:23-35:21 & Depo.Ex.3. a. Reply: While Plaintiff decries the second sentence as “false,” her cited evidence contradicts her conclusion. Mr. Gow testified that “any time there was an incoming query it was either dealt with on the telephone by referring them back to the two statements…or someone would email them the statement. So no one was left unanswered.” McCawley Decl., Ex.6 at 67. As his testimony makes clear, Mr. Gow sent 11 Case 18-2868, Document 284, 08/09/2019, 2628244, Page13 of 38 the statement to those journalists who made inquiry; he did not sent it to anyone who did not. Based on the admissible evidence, this fact remains undisputed. 20. Undisputed Fact 20: The email to the media members read: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. Ex.F. a. Reply: Plaintiff does not dispute the contents of the email and therefore it should be deemed admitted. 21. Undisputed Fact 21: Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional press release solely to disseminate information to the media. So he intentionally did not pass it through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation. EX.K ¶¶ 10,15. 12 Case 18-2868, Document 284, 08/09/2019, 2628244, Page14 of 38 a. Reply: Plaintiff makes two responses. As to the first sentence, she asserts without evidentiary support that “the Court should not consider” the Barden Declaration. This argument is frivolous for the reasons given on pages 8, 11-12, 18-19 of the Reply Brief in Support of Motion for Summary Judgment. It is a Declaration provided by an attorney with knowledge of the facts, Mr. Barden, disclosed by Defendant in her Rule 26 witnesses, whom Plaintiff chose not to depose. As to the second sentence, Plaintiff offers two pieces of evidence which she argues dispute the facts in question; they do not. That Mr. Gow forwarded the statement, prepared by Mr. Barden, to the media is not disputed. Rather, as Mr. Barden asserted in his declaration, and Plaintiff failed to cite contradictory evidence, he was the one who prepared the vast majority of the statement and instructed Mr. Gow to transmit it via email to members of the British media. Ex.K ¶¶ 10. He likewise avers that he “did not intend the January 2015 statement as a traditional press release solely to disseminate information to the media [and] this is why I intentionally did not request that Mr. Gow or any other public relations specialist prepare or participate in preparing the statement.” Id. at ¶ 15. Plaintiff fails to contradict Mr. Barden’s sworn statement. 22. Undisputed Fact 22: The January 2015 statement served two purposes. First, Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff’s false allegations. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject plaintiff’s allegations to inquiry and scrutiny. For example, he noted in the statement that plaintiff’s allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” Id. ¶ 11. 13 Case 18-2868, Document 284, 08/09/2019, 2628244, Page15 of 38 a. Reply: This paragraph, eliciting Mr. Barden’s intent, is uncontroverted by Plaintiff. She fails to cite any contradictory admissible evidence, instead making legal arguments. Her arguments are not admissible evidence (e.g., “it is her statement and she directed that it be sent to the media and public,” lacks any citation to record evidence). Plaintiff’s list of evidence she contends “corroborates” Plaintiff’s claims should be ignored as they do not pertain to Mr. Barden’s purposes in drafting the January 2 statement. 23. Undisputed Fact 23: Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish plaintiff’s allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that plaintiff’s allegations were “defamatory.” In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff’s obviously false allegations and the legal indefensibility of their own conduct. Id. ¶ 17. a. Reply: Again, Plaintiff “disputes” Mr. Barden’s intent without citation to record evidence. Plaintiff claims that Barden did not “note” anything in the statement, but the statement itself contains the phrase: “Ms. Roberts claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory.” Plaintiff’s unsupported arguments should be ignored and these facts pertaining to Mr. Barden’s intent deemed admitted. 24. Undisputed Fact 24: Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (emphasis supplied). The statement was intended to be a single, one- 14 Case 18-2868, Document 284, 08/09/2019, 2628244, Page16 of 38 time-only, comprehensive response—quoted in full—to plaintiff’s December 30, 2014, allegations that would give the media Ms. Maxwell’s response. Id. ¶ 18. The purpose of the prefatory statement was to inform the media-recipients of this intent. Id. a. Reply: Plaintiff again “disputes” any statement related to Mr. Barden’s purpose or intent, but offers no evidence contradicting his purpose or intent. She simply points out that Ms. Maxwell retained Mr. Gow in early 2015, and that he works for a public relations firm, which is non-responsive to the fact at issue, i.e., Mr. Barden’s intent with respect to language included in the statement. No one has contested that it was Mr. Gow who actually forwarded the statement to select members of the media who had requested a response. The fact set forth should be deemed admitted. 25. Undisputed Fact 25: Plaintiff’s activities to bring light to the rights of victims of sexual abuse. Plaintiff has engaged in numerous activities to bring attention to herself, to the prosecution and punishment of wealthy individuals such as Epstein, and to her claimed interest of bringing light to the rights of victims of sexual abuse. a. Reply: Plaintiff offers no evidence to dispute the facts cited and so they should be deemed admitted. 26. Undisputed Fact 26: Plaintiff created an organization, Victims Refuse Silence, Inc., a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. Doc. 1 (Complaint), ¶¶ 24-25. a. Reply: Plaintiff does not dispute this statement. 27. Undisputed Fact 27: The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by 15 Case 18-2868, Document 284, 08/09/2019, 2628244, Page17 of 38 victims of sexual abuse.” Toward this end, plaintiff has “dedicated her professional life to helping victims of sex trafficking.” Id. a. Reply: Plaintiff “agrees.” 28. Undisputed Fact 28: Plaintiff repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. This Reply Statement at ¶¶ 51-54 (citing inter alia Doc. 216 ¶¶ 2-11 and referenced exhibits, Doc. 261-1 to 216-8; Exs. N, KK, LL, MM). a. Reply: Plaintiff “denies” this contention, points to an email from Sharon Churcher seeking to interview her, and asserts that it was the media that sought her out. The weight of evidence, cited by Defendant at paragraphs 51-54, in addition to Plaintiff’s own documents, belie this assertion. She through her attorneys sought out a videotaped interview with ABC News, she sent her “book manuscript” to publishers and literary agents, and expressed anticipation and frustration that her “exclusive contract” with The Mail prevented her for a period of time from marketing her book. See, e.g., EXHIBIT QQ at GIUFFRE003959. 16 Case 18-2868, Document 284, 08/09/2019, 2628244, Page18 of 38 Plaintiff has disputed none of these activities she freely engaged in for years, and thus these facts should be deemed admitted. 29. Undisputed Fact 29: On December 30, 2014, plaintiff publicly filed an “entirely unnecessary” joinder motion laden with “unnecessary,” “lurid details” about being “sexually abused” as a “minor victim[]” by wealthy and famous men and being “trafficked” all around the world as a “sex slave.” Ex.J ¶ 24; Ex.K ¶¶ 2-3. a. Reply: Plaintiff argues that her “lurid details” were necessary legally. Judge Marra, however, has already held that they were not and her legal arguments, unsupported by any actual evidence in this case, cannot serve to controvert his findings as quoted. 30. Undisputed Fact 30: The plaintiff’s alleged purpose in filing the joinder motion was to “vindicate” her rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution agreement” with Epstein, “shed tremendous public light” on Epstein and “other powerful individuals” that would undermine the agreement, and support the CVRA plaintiffs’ request for documents that would show how Epstein “used his powerful political and social connections to secure a favorable plea deal” and the government’s “motive” to aid Epstein and his “co-conspirators.” Ex.D, at 1, 6-7, 10 (emphasis supplied). a. Reply: Plaintiff fails to offer any evidence to controvert the contents of her CVRA Joinder Motion and thus, the fact should be deemed admitted. 31. Undisputed Fact 31: Plaintiff has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s alleged “sex scheme.” Ex.KK. 17 Case 18-2868, Document 284, 08/09/2019, 2628244, Page19 of 38 a. Reply: Plaintiff directs the Court to her response to paragraph 52 and suggests the factual statement is misleading. She, however, offers no contradictory admissible evidence and thus the fact should be deemed admitted. 32. Undisputed Fact 32: Republication alleged by plaintiff. Plaintiff was required by Interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were “‘published globally, including within the Southern District of New York,’” as plaintiff alleged in Paragraph 9 of Count I of her complaint. In response, plaintiff identified the January 2015 statement and nine instances in which various news media published portions of the January 2015 statement in news articles or broadcast stories. Ex.H, at 7-8; Ex.I, at 4. a. Reply: Her argument aside, Plaintiff offers no admissible evidence to controvert the interrogatory request and her response, which was limited to “nine instances” in which the press published “portions of the January 2015 statement.” For example, Plaintiff does not point to a single news story that published the entirety of the January 2015 statement. In the absence of contrary evidence, the fact should be deemed admitted. 33. Undisputed Fact 33: In none of the nine instances was there any publication of the entire January 2015 statement. Ex.H, at 7-8; Ex.I, at 4. a. Reply: Plaintiff does not and cannot point to any of the nine publications she disclosed, or any other publication, that published the entire January 2015 statement, and this fact thus must be deemed admitted. 34. Undisputed Fact 34: Ms. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in plaintiff’s response to 18 Case 18-2868, Document 284, 08/09/2019, 2628244, Page20 of 38 Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015 statement. Ex.J ¶ 24; Ex.K ¶¶ 2-3. a. Reply: Plaintiff’s proffered evidence, testimony from Mr. Gow, fails to support her argument and fails to controvert the Barden Declaration as cited by the defendant. Nothing in the testimony establishes, as Plaintiff argues, that “Defendant hired Gow because his position allowed him to influence the press to publish her defamatory statement.” The testimony is irrelevant to the factual point. The Gow testimony at most relates to why Ms. Maxwell engaged Mr. Gow. It does not bear on the factual point, i.e., that Ms. Maxwell, Mr. Gow or Mr. Barden did not exercise any control or authority over the media in the media’s republication of portions of the statement. On this point plaintiff has failed to introduce any contrary evidence. Accordingly, the fact should be deemed admitted. 35. Undisputed Fact 35: Plaintiff’s defamation action against Ms. Maxwell. Eight years after Epstein’s guilty plea, plaintiff brought this action, repeating many of the allegations she made in her CVRA joinder motion. Doc. 1, ¶ 9. a. Reply: Plaintiff “agrees.” 36. Undisputed Fact 36: The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (b) That the allegations have been “shown to be untrue.” (c) That Giuffre’s “claims are obvious lies.” Doc. 1 ¶ 30 (boldface and underscoring omitted). (a) Reply: Plaintiff “agreed.” 19 Case 18-2868, Document 284, 08/09/2019, 2628244, Page21 of 38 37. Undisputed Fact 37: Plaintiff lived independently from her parents with her fiancé long before meeting Epstein or Ms. Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999, plaintiff moved in with the family of a fellow patient. Ex.L at 7-8, 12-14. There she met, and became engaged to, her friend’s brother, James Michael Austrich. Id. and at 19. She and Austrich thereafter rented an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs in that area. Id. at 11, 13-17. Later, they stayed briefly with plaintiff’s parents in the Palm Beach/ Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. Id. at 17, 19, 25-27. Although plaintiff agreed to marry Austrich, she never had any intention of doing so. Ex.N at 127-128. a. Reply: Plaintiff offers argument, without an affidavit or any other contradictory evidence, regarding whether Plaintiff “voluntarily live[d] independently” or whether a “reasonable person” could assert she was “engaged.” Mr. Austrich and Plaintiff agreed that they were engaged and testified accordingly, as cited. In the absence of admissible evidence to the contrary, the facts as described by her fiancé in his deposition should be deemed admitted. 38. Undisputed Fact 38: Plaintiff re-enrolled in high school from June 21, 2000 until March 7, 2002. After finishing the 9th grade school year at Forest Hills High School on June 9, 1999, plaintiff re-enrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on August 14, 2001. Ex.O. On September 20, 2001, Plaintiff then enrolled at Royal Palm Beach High School. Id. A few weeks later, on October 12, 2001, she matriculated at Survivors Charter School. Id. Survivor’s Charter School was an alternative school designed to assist students who had been unsuccessful at more traditional schools. Ex.P at 23-24. Plaintiff 20 Case 18-2868, Document 284, 08/09/2019, 2628244, Page22 of 38 remained enrolled at Survivor’s Charter School until March 7, 2002. Ex.O. She was present 56 days and absent 13 days during her time there. Id. Plaintiff never received her high school diploma or GED. Ex.Q at 475, 483. Plaintiff and Figueroa went “back to school” together at Survivor’s Charter School. Ex.P at 23-27. The school day there lasted from morning until early afternoon. Id. at 23-27, 144-146. a. Reply: Plaintiff argues, again without evidentiary support, that the “codes” on the school records indicate “semester start and end dates” rather than dates Plaintiff was in school. Her mis-reading of the records is apparent from their face. One column is labelled “Entry date,” and the next “Withdrawal Date.” Neither say “semester start date” or “semester end” date. Moreover, the “codes” simply prove the point: Plaintiff “entered” school (codes E01 and EA1) on the designated “entry date” and withdrew (either prior to completion, to enter another training program, or who “will continue in the class/program the next term or school year”) on the dates designated “withdrawal.” The school records display entry and withdrawal dates for Wellington High School Adult Program, from June 21, 2000 – August 15, 2000, from August 16, 2000 – August 13, 2001, and from August 14, 2001- September 20, 2001 and then an entry, that same day, September 20, 2001 at Survivor’s Charter School. Plaintiff would have one believe that the records show a school on Plaintiff’s official transcript that she never went to, Wellington High School Adult Program, that indicates she withdrew the very day she concededly entered Survivor’s Charter School. Her intentional misreading of the record is yet another attempt to obfuscate Plaintiff’s lack of memory regarding where and when she went to school, just like she failed to remember 8 jobs she held in 2000 whereas she claimed to have had one. The test is admissible evidence to the contrary, and Plaintiff 21 Case 18-2868, Document 284, 08/09/2019, 2628244, Page23 of 38 offers none. The flight logs (which show trips in early 2001) do not contradict the evidence because they are during the period of time she was enrolled in “Adult High School,” a place where night classes were taught and where one might circumstantially infer, careful attendance records were not kept. 39. Undisputed Fact 39: During the year 2000, plaintiff worked at numerous jobs. In 2000, while living with her fiancé, plaintiff held five different jobs: at Aviculture Breeding and Research Center, Southeast Employee Management Company, The Club at Mar-a-Lago, Oasis Outsourcing, and Neiman Marcus. Ex.R. Her taxable earnings that year totaled nearly $9,000. Id. Plaintiff cannot now recall either the Southeast Employee Management Company or the Oasis Outsourcing jobs. Ex.Q at 470-471. a. Reply: Plaintiff does not dispute the facts as presented, merely argues regarding their significance. The Social Security Administration records detail the five jobs at which she worked in 2000; the month and day of the jobs are irrelevant for purposes of this recitation of facts. Likewise, Plaintiff does not dispute the taxable earnings she made that year, or that she does not “remember” the jobs associated with Southeast Employee Management Company or Oasis Outsourcing (whether they were payroll or not), where she made $3,212 and $2,037 that year. She also “forgot” about her job at Neiman Marcus, where she made $1,440 in 2000, until she was confronted with the SSA records. McCawley Dec. Ex.5 at 53, 470. 40. Undisputed Fact 40: Plaintiff’s employment at the Mar-a-Lago spa began in fall 2000. Plaintiff’s father, Sky Roberts, was hired as a maintenance worker at the The Mar-aLago Club in Palm Beach, Florida, beginning on April 11, 2000. Ex.S. Mr. Roberts worked there year-round for approximately 3 years. Id.; Ex.T at 72-73. After working there for a period 22 Case 18-2868, Document 284, 08/09/2019, 2628244, Page24 of 38 of time, Mr. Roberts became acquainted with the head of the spa area and recommended plaintiff for a job there. Id. at 72. Mar-a-Lago closes every Mother’s Day and reopens on November 1. Ex.U at Mar-a-Lago0212. Most of employees Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club is open, i.e., between November 1 and Mother’s Day. Ex.T at 72-73; Ex.U at Mar-a-Lago0212; Ex.V. Plaintiff was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17. a. Reply: Plaintiff’s response is misleading. First, she does not dispute that Mr. Roberts, her father began working at Mar-a-Lago in April 2000, nor that he worked there for some time, became acquainted with the head of the spa area and recommended his daughter for a job. Second, Plaintiff contends that “job postings and job descriptions” “from 2002 and later are irrelevant.” There are no such “job postings” cited. Rather, the job posting cited was from October 2000, the same time that Plaintiff was hired. Compare Ex.V (posting for “Saturday October 14 and Sunday October 15”) with calendar for year 2000, showing Saturday and Sundays in October corresponding to those dates. Finally, Plaintiff points to her own “recollection” as contrary proof. Her “recollection” about when she worked at Mar-a-Lago has shifted dramatically over time. First, she claimed it was 1998. See Jane Doe 102 complaint. Then, it was 1999. See Doc. 1, Complaint in this matter. Now, in this response she has changed her answer to 2000. Her vague recollections about what year have been off base, no credit should be given to her newfound recollection of which month she worked there. In any event, she presents no admissible credible evidence to contradict Mar-a-Lago’s own records. Ex.U 23 Case 18-2868, Document 284, 08/09/2019, 2628244, Page25 of 38 at Mar-a-Lago0212 (spa not open from Mother’s Day until November 1). Even Plaintiff’s father, a longtime employee of Mar-a-lago admitted that the place “closed down” in the summer. Ex.T at 72-73. Plaintiff simply is not credible in her testimony that she recalls it being a “summer job,” and the fact that she did not work at the spa until at least November 2000 at the age of 17 should be deemed admitted. 41. Undisputed Fact 41: Plaintiff represented herself as a masseuse for Jeffrey Epstein. While working at the Mar-a-Lago spa and reading a library book about massage, plaintiff met Ms. Maxwell. Plaintiff thereafter told her father that she got a job working for Jeffrey Epstein as a masseuse. Ex.T at 79. Plaintiff’s father took her to Epstein’s house on one occasion around that time, and Epstein came outside and introduced himself to Mr. Roberts. Id. at 82-83. Plaintiff commenced employment as a traveling masseuse for Mr. Epstein. Plaintiff was excited about her job as a masseuse, about traveling with him and about meeting famous people. Ex.L at 56; Ex.P at 126. Plaintiff represented that she was employed as a masseuse beginning in January 2001. Ex.M; Ex.N. Plaintiff never mentioned Ms. Maxwell to her thenfiancé, Austrich. Ex.L at 74. Plaintiff’s father never met Ms. Maxwell. Ex.T at 85. a. Reply: Plaintiff does not actually refute any of the facts set forth above, but rather spends her time discussing different facts. Plaintiff’s father testified to what she told him, that she “was going to learn massage therapy.” Ex.T at 79. She does not contest her father’s testimony that Mr. Epstein came out of the house and greeted her father and that her father never met Ms. Maxwell. See Reply to Undisputed Fact 41. Whether someone can receive a “massage license” under Florida law without a high school equivalency diploma is of no moment. Plaintiff does not dispute she represented 24 Case 18-2868, Document 284, 08/09/2019, 2628244, Page26 of 38 herself as a masseuse to others, in her own handwriting, beginning in January 2001. Exs. M and N. These facts should be deemed admitted. 42. Undisputed Fact 42: Plaintiff resumed her relationship with convicted felon Anthony Figueroa. In spring 2001, while living with Austrich, plaintiff lied to and cheated on him with her high school boyfriend, Anthony Figueroa. Ex.L at 68, 72. Plaintiff and Austrich thereafter broke up, and Figueroa moved into the Bent Oak apartment with plaintiff. Ex.L at 20; Ex.P at 28. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa in Plaintiff’s presence punched Austrich in the face. Ex.X; Ex.L at 3845. Figueroa and plaintiff fled the scene before police arrived. Ex.X. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance. Ex.Y. a. Reply: Plaintiff argues relevance regarding these facts, but contests none of them. They should be deemed admitted. Plaintiff’s lies, cheating, and association with a convicted felon and known drug abuser all are relevant in this defamation case concerning her reputation, purported damage to such reputation, and whether she was a known liar, as the January 2015 statement contends. 43. Undisputed Fact 43: Plaintiff freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at age 17, while living in the same apartment, plaintiff and Figueroa hosted a party with a number of guests. Ex.Z. During the party, according to plaintiff, someone entered plaintiff’s room and stole $500 from her shirt pocket. Id. Plaintiff contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a “sex slave.” A second time, in June 2002, plaintiff contacted the police to report that her former landlord had left her belongings by the roadside and 25 Case 18-2868, Document 284, 08/09/2019, 2628244, Page27 of 38 had lit her mattress on fire. Ex.AA. Again, plaintiff met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a “sex slave.” Id. a. Reply: Plaintiff, again, presents no admissible evidence to contradict these facts, instead arguing their relevance. They should be deemed admitted. 44. From August 2001 until September 2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel unaccompanied by Plaintiff. Flight logs maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips away from Florida that Epstein and Maxwell took, unaccompanied by Plaintiff, between August 2001 and September 2002. Ex.BB. Rodgers maintained a log of all flights on which Epstein and Maxwell traveled with him. Ex.CC at 6-15. Epstein additionally traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial flights. Id. at 99-100, 103. For substantially all of thirteen months of the twenty-two months (from November 2000 until September 2002) that Plaintiff lived in Palm Beach and knew Epstein, Epstein was traveling outside of Florida unaccompanied by Plaintiff. Ex.BB. During this same period of time, Plaintiff was employed at various jobs, enrolled in school, and living with her boyfriend. a. Reply: Plaintiff goes to great lengths to dispute facts other than those presented as Undisputed Fact 44. Her voluminous, repetitive recitation of the flights that Plaintiff was on do nothing to demonstrate the 13 months of flights from July 2001 until August 2002 that Epstein and Maxwell were on without Plaintiff, as reflected in the logs. Her assertions regarding the other flights that she took, commercial or on another plane, do nothing to establish all of the many flights she was not on during 13 of the 22 month period during which Epstein and Maxwell were away from Palm Beach. Plaintiff does 26 Case 18-2868, Document 284, 08/09/2019, 2628244, Page28 of 38 not dispute that Epstein and Maxwell were on the flights without her. The facts as presented by Defendant should be deemed admitted. 45. Undisputed Fact 45: Plaintiff and Figueroa shared a vehicle during 2001 and 2002. Plaintiff and Figueroa shared a ’93 white Pontiac in 2001 and 2002. Ex.P at 67; Ex.EE. Plaintiff freely traveled around the Palm Beach area in that vehicle. Id. In August 2002, Plaintiff acquired a Dodge Dakota pickup truck from her father. Ex.P at 67-68. Figueroa used that vehicle in a series of crimes before and after Plaintiff left for Thailand. Id.; Ex.FF. a. Reply: Again, the Response has nothing to do with the facts stated. As Plaintiff concedes, she and Mr. Figueroa had one car that they both used. In fact, they traveled to and from school together. Ex.P at 67-68. She also does not dispute that she traveled freely around the Palm Beach area in that vehicle, or that “her car” was used in a series of thefts while she was in Thailand. All should be deemed admitted. 46. Undisputed Fact 46: Plaintiff held a number of jobs in 2001 and 2002. During 2001 and 2002, plaintiff was gainfully employed at several jobs. She worked as a waitress at Mannino’s Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at Roadhouse Grill. Ex.R. She also was employed at Courtyard Animal Hospital (aka Marc Pinkwasser DVM). Id.; Ex.W. a. Reply: Plaintiff admits all of the facts set forth above, aside from the use of the word “gainfully.” They should be deemed admitted. 47. Undisputed Fact 47: In September 2002, Plaintiff traveled to Thailand to receive massage training and while there, met her future husband and eloped with him. Plaintiff traveled to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove her to the airport. While there, she initially contacted Figueroa frequently, 27 Case 18-2868, Document 284, 08/09/2019, 2628244, Page29 of 38 incurring a phone bill of $4,000. Ex.P at 35. She met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until two days before Mr. Figueroa’s deposition in this matter in May 2016. Id. at 29, 37. a. Reply: Again, Plaintiff does not refute the facts set forth, she simply offers her own interpretation of those facts. In the absence of any contrary evidence, they should be deemed admitted. 48. Undisputed Fact 48: Detective Recarey’s investigation of Epstein failed to uncover any evidence that Ms. Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. Joseph Recarey served as the lead detective from the Palm Beach Police Department charged with investigating Jeffrey Epstein. Ex.GG at 10. That investigation commenced in 2005. Id. Recarey worked only on the Epstein case for an entire year. Id. at 274. He reviewed previous officers’ reports and interviews, conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance footage of the Epstein home, participated in and had knowledge of the search warrant executed on the Epstein home, and testified regarding the case before the Florida state grand jury against Epstein. Id. at 212-215. Detective Recarey’s investigation revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect by the government. Id. at 10-11, 180-82, 187-96, 241-42, 278. None of Epstein’s alleged victims said they had seen Ms. Maxwell at Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her, nor told what to wear or how to act by her. Id. Indeed, none of Epstein’s alleged victims ever reported to the government they had met or spoken to Ms. Maxwell. Maxwell was not seen coming or going from the house during the law enforcement surveillance of Epstein’s home. Id. at 214-215. The arrest warrant did not mention Ms. Maxwell 28 Case 18-2868, Document 284, 08/09/2019, 2628244, Page30 of 38 and her name was never mentioned before the grand jury. Id. at 203, 211. No property belonging to Maxwell, including “sex toys” or “child pornography,” was seized from Epstein’s home during execution of the search warrant. Id. at 257. Detective Recarey, when asked to describe “everything that you believe you know about Ghislaine Maxwell’s sexual trafficking conduct,” replied, “I don’t.” Id. at 278. He confirmed he has no knowledge about Ms. Maxwell sexually trafficking anybody. Id. at 278-79. Detective Recarey also has no knowledge of Plaintiff’s conduct that is subject of this lawsuit. Id. at 259-260. a. Reply: Plaintiff offers several misleading “contrary” facts, none of which actually address the facts presented herein, namely whether Ms. Maxwell was ever mentioned by any of Epstein’s alleged victims, whether she was the target of their investigation, and whether any of her property was seized from Epstein’s home. Plaintiff cites to numerous inadmissible pieces of evidence on facts other than those. Mr. Rodriguez, a convicted felon for obstructing justice related to the Epstein case, is dead and his deposition testimony is the subject of a motion in limine because Ms. Maxwell has never had the opportunity to cross examine him. Doc. 567 at 14. Ms. Rabuyo likewise is not a witness who has been deposed in this case, and therefore her “testimony” is not admissible against Ms. Maxwell. The message pads are not authenticated by anyone, as will be the subject of a forthcoming motion in limine. And there is not one shred of evidence that any child pornography, as opposed to a topless photo of a very adult Ms. Maxwell, were ever found in Epstein’s home. The facts should be deemed admitted, as those proferred by Defendant are based on admissible evidence. 49. Undisputed Fact 49: No nude photograph of Plaintiff was displayed in Epstein’s home. Epstein’s housekeeper, Juan Alessi, “never saw any photographs of Virginia 29 Case 18-2868, Document 284, 08/09/2019, 2628244, Page31 of 38 Roberts in Mr. Epstein’s house.” Ex.HH at ¶ 17. Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. Ex.GG at 289-90. a. Reply: Plaintiff offered no evidence that a nude photograph of her was displayed in Epstein’s home. All of the testimony she submits has nothing to do with a nude photograph of herself. The fact should be deemed admitted. 50. Undisputed Fact 50: Plaintiff intentionally destroyed her “journal” and “dream journal” regarding her “memories” of this case in 2013 while represented by counsel. Plaintiff drafted a “journal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. Ex.II at 6465, 194; Ex.N at 205-08. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents in her possession. Id. Plaintiff also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. Ex.II at 194-96. To date, Plaintiff cannot locate the “dream journal.” Id. a. Reply: Plaintiff offers no contrary admissible regarding her destruction of her journal and it should be deemed admitted. 51. Undisputed Fact 51: Plaintiff publicly peddled her story beginning in 2011. Plaintiff granted journalist Sharon Churcher extensive interviews that resulted in seven (7) widely distributed articles from March 2011 through January 2015. Doc. 216 ¶¶ 2-11 and referenced exhibits; Doc. 261-1 to 216-8, incorporated by reference. Churcher regularly communicated with plaintiff and her “attorneys or other agents” from “early 2011” to “the present day.” Plaintiff received approximately $160,000 for her stories and pictures that were published by many news organizations. Ex.N at 247-248. 30 Case 18-2868, Document 284, 08/09/2019, 2628244, Page32 of 38 a. Reply: Plaintiff offers no evidence to contradict the facts asserted and they should therefore be deemed admitted. Plaintiff’s unsupported spin of those facts should be stricken. 52. Undisputed Fact 52: Plaintiff drafted a 144-page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, plaintiff drafted a book manuscript which purported to document plaintiff’s experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. Ex.KK. Plaintiff communicated with literary agents, ghost writers and potential independent publishers in an effort to get her book published. She generated marketing materials and circulated those along with book chapters to numerous individuals associated with publishing and the media. a. Reply: Plaintiff cites inadmissible evidence, and attorney argument, in contradiction of these facts. They should be ignored. The “Victim Notification Letter” is inadmissible hearsay. The psychologist records likewise are inadmissible hearsay. The FBI interview is inadmissible hearsay. Plaintiff’s counsel then flatly misrepresents to the Court her own client’s characterization of the book manuscript, calling it a “fictionalized account.” Plaintiff, contradicting her counsel, testified that the book manuscript is “99% true.” Q Is there anything -- well, first of all, did you author that entire manuscript? A Yes, I did. Q Did anyone else author part of that manuscript? A Do you mean did anyone else write this with me? Q Right. A No. Q That's all your writing? 31 Case 18-2868, Document 284, 08/09/2019, 2628244, Page33 of 38 A This is my writing. Q Okay. To the best of your recollection as you sit here right now, is there anything in that manuscript about Ghislaine Maxwell that is untrue? A I don't believe so. Like I said, there is a lot of stuff that I actually have left out of here. Q Um-hum. A. So there is a lot more information I could put in there. But as far as Ghislaine Maxwell goes, I would like to say that there is 99.9 percent of it would be to the correct knowledge. Q All right. Is there anything that you -- and I understand you're doing this from memory. Is there anything that you recall, as you're sitting here today, about Ghislaine Maxwell that is contained in that manuscript, that is not true? A You know, I haven't read this in a very long time. I don't believe that there's anything in here about Ghislaine Maxwell that is not true. EXHIBIT RR at 42-43 (emphasis added). Plaintiff clearly now would like to spin the book manuscript as “fictionalized” because she is well aware that the “facts” presented by her in that manuscript are contradicted by many other documentary and testimonial records. Yet she offers no admissible evidence that Plaintiff intended the manuscript to be fictional. Citations to social scientists who have not testified in this case and whose work has not even be cited by any expert in this case is wholly improper and should be stricken. 53. Undisputed Fact 53: Plaintiff’s publicly filed “lurid” CVRA pleadings initiated a media frenzy and generated highly publicized litigation between her lawyers and Alan Dershowitz. On December 30, 2014, plaintiff, through counsel, publicly filed a joinder motion that contained her “lurid allegations” about Ms. Maxwell and many others, including Alan Dershowitz, Prince Andrew, Jean-Luc Brunel. The joinder motion was followed by a “corrected” motion (Ex.D) and two further declarations in January and February 2015, which repeated many of plaintiff’s claims. These CVRA pleadings generated a media maelstrom and spawned highly publicized litigation between plaintiff’s lawyers, Edwards and Cassell, and Alan 32 Case 18-2868, Document 284, 08/09/2019, 2628244, Page34 of 38 Dershowitz. After plaintiff publicly alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called plaintiff a liar and accused her lawyers of unethical conduct. In response, attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. Doc. 363 at 363-1 through 363-14. a. Reply: Plaintiff offers no contrary facts and so they should be deemed admitted. 54. Undisputed Fact 54: Plaintiff formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, plaintiff, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to plaintiff, the purpose of the organization is to promote plaintiff’s professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Ex.LL. Plaintiff attempts to promote Victims Refuse Silence at every opportunity. Ex.MM at 17-18. For example, plaintiff participated in an interview in New York with ABC to promote the charity and to get her mission out to the public. Id. at 28. a. Reply: Plaintiff offers no contrary evidence and the facts should be deemed admitted. II. The Court should strike plaintiff’s statement of “undisputed facts.” The summary-judgment procedure is well established. When the summary-judgment nonmovant bears the burden of proof at trial, as in the case at bar, the movant may show a prima facie entitlement to summary judgment in one of two ways: (1) the movant may point to evidence that negates the non-movant’s claims, or (2) the movant may identify those portions of its opponent’s evidence that demonstrate the absence of a genuine issue of material fact. 33 Case 18-2868, Document 284, 08/09/2019, 2628244, Page35 of 38 Salahuddin v. Goord, 467 F.3d 263, 272-73 (2d Cir. 2006). If the movant makes this showing in either manner, the burden shifts to the nonmovant to identify record evidence creating a genuine issue of material fact. Id. at 273. Local Civil Rule 56.1(a) carries out this summary-judgment procedure by requiring the summary-judgment movant to set forth “material facts as to which she contends there is no genuine issue to be tried.” Subsection (b) of the rule requires the party opposing summary judgment to set forth a “statement of additional material facts as to which it is contended that there exists a genuine issue to be tried” (emphasis supplied). Ms. Maxwell has moved for summary judgment; plaintiff has not. As movant, Ms. Maxwell is required under Local Civil Rule 56.1 to enumerate the facts she is asserting as undisputed; as the party opposing summary judgment, plaintiff is permitted—if she can—to introduce admissible evidence creating a genuine issue of material fact. See Fed. R. Civ. P. 56(c)(1). Plaintiff is confused. Plaintiff believes she—the party opposing summary judgment— must enumerate facts she is asserting as undisputed, and so she has submitted her own Rule 56.1 statement of “undisputed facts.” That gets the summary-judgment procedure exactly backwards. Plaintiff’s “undisputed facts” are irrelevant. Plaintiff cannot avoid summary judgment by proposing “undisputed facts”; she may only do so by creating a genuine issue of material fact as to Ms. Maxwell’s statement of undisputed facts. Accordingly, this Court should strike plaintiff’s statement of “undisputed facts.” Although Ms. Maxwell as the summary-judgment movant has no duty to respond to plaintiff’s alleged “undisputed facts,” we hasten to add that Ms. Maxwell in fact opposes and disputes most of plaintiff’s alleged “undisputed facts.” For example, Defendant’s Undisputed 34 Case 18-2868, Document 284, 08/09/2019, 2628244, Page36 of 38 Fact 40 includes the statement, “Ms. Giuffre was hired as a ‘seasonal’ spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17.” Yet, Plaintiff sets forth as her own “Undisputed Fact 58” that “Virginia [got] job at Mar-a-Lago in 2000, either months before or just after [her] 17th birthday.” Plaintiff has done nothing more than set forth her “dispute” with Defendant’s Undisputed Fact 40 as her own “undisputed fact.” It makes no sense. See also Plaintiff’s “Undisputed Fact” 63. The other alleged undisputed facts are simply Plaintiff’s assertion of her deposition testimony, and hearsay of her statements to other witnesses, couched as “Undisputed Facts.” Ms. Maxwell strenuously disputes almost all of the alleged “undisputed facts” claiming that she engaged in any sexual acts, misconduct or communications with plaintiff or others; indeed, over the course of two days and thirteen hours of deposition Ms. Maxwell disputed all such allegations. Because none of Plaintiff’s “undisputed facts” have anything to do with the issues raised by Defendant’s Motion for Summary Judgment, Ms. Maxwell moves to strike plaintiff’s statement of “undisputed facts.” Conclusion For the foregoing reasons, Ms. Maxwell requests that the Court deem her Undisputed Facts admitted, and that the Court strike plaintiff’s statement of “undisputed facts.” 35 Case 18-2868, Document 284, 08/09/2019, 2628244, Page37 of 38 Dated: February 10, 2017 Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 lmenninger@hmflaw.com Attorneys for Ghislaine Maxwell 36 Case 18-2868, Document 284, 08/09/2019, 2628244, Page38 of 38 CERTIFICATE OF SERVICE I certify that on February 10, 2017, I electronically served this Defendant’s Reply to Plaintiff’s Statement of Contested Facts and Plaintiff’s “Undisputed Facts” Pursuant to Local Civil Rule 56.1 via ECF on the following: Sigrid S. McCawley Meredith Schultz Boies, Schiller & Flexner, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@aol.com /s/ Nicole Simmons Nicole Simmons 37 Case 18-2868, Document 285, 08/09/2019, 2628246, Page1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X Plaintiff, v. GHISLAINE MAXWELL, Defendant. ....................................... VIRGINIA L. GIUFFRE, 15-cv-07433-RWS --------------------------------------------------X Declaration of Laura A. Menninger in Support of Defendant’s Reply in Support of Motion for Summary Judgment I, Laura A. Menninger, declare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell’s Reply in Support of Motion for Summary Judgment.1 2. In Defendant’s Memorandum of Law in Support of Motion for Summary Judgment (filed Jan. 9, 2017), I included numbered paragraphs corresponding to undisputed facts from the movant’s perspective as contemplated by Local Civil Rule 56.1(a), together with the citation to admissible evidence as required by Fed. R. Civ. P. 56(c). See Doc. 541, passim. 1 At trial, defendant intends to produce either the custodian of record relevant to any disputed document or a certification in compliance with either Fed. R. Evid. P. 803 and/or 902. See Fed. R. Civ. P. 56(c). Apart from deposition testimony, the majority of non-deposition documents herein were either produced by plaintiff or obtained with releases signed by plaintiff. Case 18-2868, Document 285, 08/09/2019, 2628246, Page2 of 4 3. On January 9, 2017, I also prepared and served on the Court and counsel, under seal, Defendant’s Statement of Material Undisputed Facts Pursuant to Local Civil Rule 56.1 (“Statement”). Those paragraphs mirror the numbered paragraphs contained within the Memorandum of Law, minus the citations to the evidentiary record. The Statement was filed with the Court in hard-copy and placed in the vault (see Doc.543). 4. Through a clerical oversight, a redacted version of the Statement was not appended to the filed ECF version of the Notice of Motion for Summary Judgment (Doc. 537). However, as noted in the previous two paragraphs, Ms. Maxwell enumerated all undisputed facts in accordance with Local Civil Rule 56.1(a) in:  Ms. Maxwell’s Memorandum of Law in Support of Motion for Summary Judgment (Doc.541); and  the Local Rule 56.1 Statement served on the the Court and counsel and filed in hard copy with the Court. 5. Attached as Exhibit NN (filed under seal) is a true and correct copy of Defendant, Ghislaine Maxwell’s Initial Disclosure Pursuant to Fed. R. Civ. P. 26, served February 24, 2016. 6. Attached as Exhibit OO (filed under seal) is a true and correct copy of an email correspondence from Plaintiff to Sharon Churcher, dated May 12, 2011, Bates stamped GIUFFRE004096-7; 004028-30. 7. Attached as Exhibit PP (filed under seal) are true and correct copies of excerpts from the November 14, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective Order. 2 Case 18-2868, Document 285, 08/09/2019, 2628246, Page3 of 4 8. Attached as Exhibit QQ (filed under seal) is a true and correct copy of an email correspondence from Plaintiff to Sharon Churcher, dated May 12, 2011, Bates stamped GIUFFRE003959. 9. Attached as Exhibits RR (filed under seal) are true and correct copies of excerpts from the May 3, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective Order. I declare under penalty of perjury that the foregoing is true and correct. Executed on February 10, 2017. s/ Laura A. Menninger Laura A. Menninger 3 Case 18-2868, Document 285, 08/09/2019, 2628246, Page4 of 4 CERTIFICATE OF SERVICE I certify that on February 10, 2017, I electronically served this Declaration of Laura A. Menninger in Support of Defendant’s Reply to Her Motion for Summary Judgment via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@aol.com /s/ Nicole Simmons Nicole Simmons 4 Case 18-2868, Document 286, 08/09/2019, 2628248, Pagel of 55 EXHIBIT Case 18-2868, Document 286, 08/09/2019, 2628248, Page2 of 55 United States District Court Southern District Of New York --------------------------------------------------X Plaintiff, v. Ghislaine Maxwell, Defendant. -----------------------------------------------X ............................................... Virginia L. Giuffre, 15-cv-07433-RWS DEFENDANT GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(a)(1)(A) DISCLOSURES Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following disclosures: I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH PARTICULARITY IN THE PLEADINGS 1. Ghislaine Maxwell c/o Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10th Ave. Denver, CO 80203 303-831-7364 LMenninger@HMFLaw.com Ms. Maxwell is the Defendant and may have knowledge concerning matters at issue, including the events of 1999-2002 and the publication of statements in the press in 2011-2015. 2. Virginia Lee Roberts Giuffre c/o Sigrid S. McCawley, Esq. Boies, Schiller & Flexner LLP 401 East Las Olas Boulevard, Suite 1200 Case 18-2868, Document 286, 08/09/2019, 2628248, Page3 of 55 Miami, Florida 33301 (954) 356-0011 smccawley@bsfllp.com Ms. Giuffre is the Plaintiff and has knowledge concerning the matters at issue in her Complaint, including the events of 1996-2015 and the publication of statements in the press in 2011-2015. 3. Philip Barden Devonshires Solicitors LLP 30 Finsbury Circus London, United Kingdom EC2M 7DT DX: 33856 Finsbury Square (020) 7628-7576 Philip.Barden@devonshires.co.uk Mr. Barden has knowledge concerning press statements by Plaintiff and Defendant in 2011-2015 at issue in this matter. 4. Paul Cassell College of Law, University of Utah 383 South University Street Salt Lake City, UT 84112 801-585-5202 paul.cassell@law.utah.edu Mr. Cassell has knowledge concerning press statements by Plaintiff, Plaintiff’s court pleadings, and Plaintiff’s sworn testimony. 5. Alan Dershowitz c/o Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 (202) 719-7000 Mr. Dershowitz has knowledge concerning Plaintiff’s false statements to the press, in court pleadings, and in sworn testimony, at issue in this matter. 6. Bradley Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Ft. Lauderdale, FL 33301 (954) 524-2820 brad@pathtojustice.com 2 Case 18-2868, Document 286, 08/09/2019, 2628248, Page4 of 55 Dated: February 24, 2016. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 lmenninger@hmflaw.com Attorney for Ghislaine Maxwell CERTIFICATE OF SERVICE I certify that on February 24, 2016, I electronically served this DEFENDANT GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(A)(1) DISCLOSURES via e-mail on the following: Sigrid S. McCawley BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com s/ Laura A. Menninger Laura A. Menninger 7 Case 18-2868, Document 286, 08/09/2019, 2628248, PageS of 55 EXHIBIT OO To: P3996 0f 55 From: Virginia Giuffre Sent: Thur 5"12/2011 2:21 :43 AM luportanoe: Normal Subject: Re: Good News!! Received: Thur 5/12/2011 2:21:43 AM Thanks again Shazza, I'm bringing down the house with this book!? xoxo Jenna 011 Wed, 11/5/11. Sha ?Sharon. y. uk> wrote: From; Sha rou.Clturchc .co. uk maj .co. uk> Subject: Re: Good News? To: "Virginia Giu??rc" Received; W'?duesday, 1] May. 2011, 4.17 PM Don't forget Alan Detshowitz. JE's buddy and lawyer..good name for your pitch as he rapped Claus von Bulow and a movie was made about that was Revetsal of Fortune. We all suspect Alan is a pedo and tho no proof of that, you probahiy met him when he was hanging put .IE lFrom: - MW Giu??rc vac?1 lTo: . - "i Sharon Churcher 'l [Date I I -- I I 23:00 . I l" I Good News? Q~nuo? -- I I Hi Sharon> chUo gorgeous, I hope this message comes to you on a. bright} sunny dayHH took your advice about what to offer Sandra. and she accepted. Were [drawing up a contract through her agent right now and getting busy to Com-nght Pmlecled Mutemtl CONFIDENTIAL 18-2 68 Document 286,, 08/09/2019, 2628248, Page7 of 55 . Gas?i . . Im}: dcadimc. Just won 1 youhmc any minimization on yciu ham when I 2:11:11 were doing intewiews about the IE. story: I wanted to put the I Iriames of some of these asshoies, mops, meant to say, IledO'F-i: that .E Ismt mu: to. With everything going on my brain fccis like mush and it wm?dl lbs: 3 great dcai I IHaving fun sweetie? I IThanks? I Ileaml I wan-A JI-Irwu-u warm-I'? i?his emaii has been scanned by the Messagaidabs Emaii System Far more information please visit This c-maii and any attached ?ics are for the married addressee oniy. it contains infonnation, which may be confidential and icgaliy priviicgcd and also prorated by copyright. Unlesg you are the named (or anthm?ised to receive for the addressee) you may not copy or use it; or disclose it to anyone else? Ifyou received is in uimr please noii 1" ihC sender immc?iaicly and then ii li?m?n your system. Phase be advised that {he views a?d opinions in this c-maii may not re?ect the views and opinions of?ssuciatcd Newspapers Lim?cd or any of its subsidiary companias. We mak?t evm'y effort ?0 keap our network ?free from viruses. Naive-vat; 3:011 (in need In Check this c?maii and any attachments to it for viruses as we can take no responsibility For any computer virus which may be transferred by way of this e-maii. Use of this or any U?ler e?mail signifies consent to any interception we might Iawfu?y carry- out to prevent abuse of these facilities. Associated Newspapers Ltd. Registered Of?ce: No?hciiffe House, '2 Derry Remington, oudoni 8 Registered No 8412.; England, I Cupyrighl i?riilmied Mumriaii To: Sharon 2628248, P3998 0? 55 From: Virginia Giuffre Sent: Wed 61812011 11:19:55 PM Importance: Normal Subject: Re: Virginia Roberts Received: Wed 5/812011 11:19:55 PM Hi Buddy, You are absolutely biting is an understatement of the century?? We didn?t. have any trouble with spiders or anything like that it was more my daughter that gave everyone a spook! She wandered off when I turned my back to look at homemade jam and found her outside in the bush chasing the rods? My Own miniatmL? My ?ngers and toes me crossed and I'm thinking positive? 5! Much Love, Jenna On W'ed, 816/11, Sharon ureher wrote. From~ Sharon Subject: Re: Vir inia Roberts in Received: Wednesday, 8 June, 2011, 11:59 AM Rum. Yen lle?i?Tf" :?nmfte .. but did {~32 item: to duck urz-zlet wider They Wd?it: same-g hcween treat mien 3: went. KL: Litre-:1: it is; .1 nailbiung; art-1n but remember he 13 only me: 533mm 1-111. vex ?16113 it wind; [8 good. .ii?ne Lin-:31: go for it. there an: mhenz. Dii?i?eren-r. tea-ties. When (he. you tend Midi} From. Virginie (iinffi'e Sent: 11:00.03. 2011 01327 AM To Sharon C'luuehcr Subject: Re: Roberts Dearest Shazza, Once again you have really outdone MANY, I took the kids to the Australian Walkabout Park today and enjoyed the scenic walks and many kangaroos. Rob and I hat good chuckle about our adventures at the Reptile Park with you and Mike times! !3 Have you heard from Mike? I hope he is well and if you ever speak, tell him I sent 21 BK) hello. Ireally appreciate evelything you have helped with. as a friend you have gone beyond the call ofdutyl I hope we hear back from Jarred sooull xomxo Jenna On Wed, 8/6/11, Sharon ('Jhurcher wrote: From: Sharon Churchei? Subject: Virginia Roberts To: "jawedhalperin agent ?ari'ed?c'lloh'cctiveenmom <jarrcd@ohjcetivcentcomf'? Cc: "Virginia Giuffre" Received: Wednesday. 8 June, 201 1. 2:31 AM Comrighl Pmlecled Material (IINFIDENTML Glumz?rmozg Case 18-2868, Document 286, 08/09/2019, 2628248, Page9 of 55 Hi Jarred Hopefuily you have Virginia?a hank pitch by new, She has some amazing names; which she can share with you in confidence and i think she also has a human interest story that cauld appeal to the Omani/female set as welt as the Wall Streetere whe teltdw Epstein a hedge fund king. Here are a few of our stories about Virginia, plus some examples of the massive US and other internationai media pickup. Vanity Fair are riding a piece i believe in theirAugust issue. The FBI have reopened the Epstein case due to Virginia?s revelations. I also am attaching a link to a NY Magazine profile of Epstein written before his world combusted. The FBI believe he was essentially running a private and imbue brothel for some at the world's richest and meat in?uential men. He got off the ?rst time round after retaining Kenneth Starr (who witchhuntecl Biil Clinton) and Alan Dershowitz (van Butdw?s appeal lawyer, who inspired the movie Reversal of Fortune). The US Justice Dept is investigating corruptien altegations against at. least one prosecutor involved in the case. Best regards, Sharon tum-gr demurrer an .ti?i wraurtr?f mead? the? ism?dmt?n-unn t??l?fi??i??zilf??ii 1?5; 3935.353 :23 ?ill ?Mn nitrati-ixnranrarz2;ear i: menu tent nae eat. Bei- fir; Miner?..- izttp. first innai tea ie1vvt'aetz. 321:2; ?3'3 math."- Went: (This one, in Forbes Magazine, seems to require subscribing but you get the gist) latte. emanate; ee- it? denied are? a 32.3% ?333994 http:tf i139 1 2i This e-tnaii and any attached ?les are intended for the named addressee only It mutating which may be con?dential and legaliy privileged and also protected by copyright. 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For more atinn please visit This cmaii has: been scanned by the Messachabs Email Seetirity Sign; tcm. I Copyright Pmleuted Material Case 8-2868, Document 286, 08/09/2019 For more information is case Visit 2628248, PagelO of 55 This c-maii and any attached ?les are intcudcd for the named addresses only. it contains iuibmiatiou, which may be sordid entiz-ii and legaliy privileged and also protected by copyright. Unless you are the named addressee (or authmised to receive far the addressee) yeti may not copy or use it, or disclose it to anyone else, tfyou received it in carer please natif} the sea-tier immer?ately and then delete it from your system. P123358 be advised that the views and opinions expressed it} tl a-maii may tint reflect the views and npinirms of Associated Newspapers Limited or any of its subsidiary crimpanies. We make every ct?t'ort tr: mir network true from viruses. However, you do need to check this c-mail and any attachments it for Viruses as we can take no responsibility for any computer Vitus which may be transferred by way of this e?maii. Use this or any other c-mail facility signifies consult to any interception we. might lawfully {3311ij out to facilities. Assecistcci Newspapers Ltd. Registered Of?ce: House, Derry St, Kcnsington, London, W8 STT. Registered No 84121 E?glalld. Copyriglil Prulemted Material Case 18-2868, Document 286, 08/09/2019, 2628248, Pagell of 55 EXHIBIT PP Agren Document Blando Court Reporting 2628248, & Video, Page12 Inc. Case 18-2868, 286, 08/09/2019, of 55 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS __________________________________________________ CONFIDENTIAL VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II November 14, 2016 __________________________________________________ VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. __________________________________________________ APPEARANCES: BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE VOLUME II 11/14/2016 348 Agren Document Blando Court Reporting 2628248, & Video, Page13 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 3 4 5 6 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura Menninger, Esq. Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant 7 8 Also Present: Ann Lundberg, Paralegal Maryvonne Tompkins, Videographer 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 349 Agren Document Blando Court Reporting 2628248, & Video, Page14 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Pursuant to Notice and the Federal Rules 2 of Civil Procedure, the continued video 3 deposition of VIRGINIA GIUFFRE, called by Defendant, 4 was taken on Monday, November 14, 2016, commencing at 5 8:04 a.m., at 150 East 10th Avenue, Denver, Colorado, 6 before Pamela J. Hansen, Registered Professional 7 Reporter, Certified Realtime Reporter and Notary 8 Public within Colorado. 9 * * * * * * * I N D E X 10 11 VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II 12 EXAMINATION 13 By Ms. Menninger PAGE 354 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 350 Agren Document Blando Court Reporting 2628248, & Video, Page15 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 INDEX OF EXHIBITS (continued) 2 INITIAL REFERENCE 3 DESCRIPTION 4 Exhibit 1 Settlement Agreement and General Release 355 Exhibit 2 List of names 370 Exhibit 3 Photocopy of photograph 408 Exhibit 4 Photocopy of photograph, with attachments 411 Exhibit 5 Photocopy of photograph, with attachments 417 Exhibit 6 Photocopy of photograph, with attachments 423 12 Exhibit 7 Statements 437 13 Exhibit 8 History of education, with attachment 462 Exhibit 9 Application for Employment, with attachment 474 Exhibit 10 The Great Outdoors Community Services Association, Inc. Termination Form, with attachments 481 Exhibit 11 7/6/2016 letter to Schultz from Hayek, with attachments 484 Exhibit 12 Patient Registration Information, with attachments 490 Exhibit 13 CVS Prescription Records document, 7/29/2016, with attachment 502 Exhibit 14 Affidavit of Custodian of Records, Walgreen Company, with attachments 507 5 6 7 8 9 10 11 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 351 Agren Document Blando Court Reporting 2628248, & Video, Page16 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 INITIAL REFERENCE DESCRIPTION 2 Exhibit 15 Patient Health Summary, Clifton Beach Medical & Surgical, printed on 6/28/2016 512 Exhibit 16 Portions of deposition transcript of Virginia Giuffre taken May 3, 2016 533 Exhibit 17 Amendment/Errata Sheet signed May 31, 2016 by Virginia Giuffre 540 8 Exhibit 18 Ad for Mar-a-Lago Club 548 9 Exhibit 19 The Mar-a-Lago Club, L.C. Employment Policies, October 28, 1995 549 Exhibit 20 Page from the Mar-a-Lago Club Employment Policies, Revised 10/2001 550 3 4 5 6 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 352 Agren Document Blando Court Reporting 2628248, & Video, Page17 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 didn't see them take pictures of the backs of them. 2 I'm not too sure who. 3 Q You don't remember sending to them a 4 photograph that included this wood around another 5 photograph? 6 A No. 7 Q Okay. 8 You have mentioned a journalist by the name of Sharon Churcher. 9 A Yes. 10 Q You are aware that Sharon Churcher 11 12 published news stories about you? A Yes. 13 MS. MCCAWLEY: 14 Go ahead. 15 Q Objection. (BY MS. MENNINGER) Is anything that you 16 have read in Sharon Churcher's news stories about you 17 untrue? 18 A I think Sharon did print some things that 19 I think she elaborated or maybe misheard. 20 mean, if you have a specific document to show me, I'd 21 love to look at it and read it and tell you what I 22 think. 23 Q But, I Is there anything, as you sit here today, 24 that you know of that Sharon Churcher printed about 25 you that is not true? VIRGINIA GIUFFRE VOLUME II 11/14/2016 435 Agren Document Blando Court Reporting 2628248, & Video, Page18 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 A Not off the top of my head. If you show 2 me, like, a news clipping article or something, I can 3 definitely read it for you. 4 Q Is there anything that you know of that 5 Sharon Churcher has printed about Ghislaine Maxwell 6 that is not true? 7 8 9 A No, not off -- no, not off the top of my head. Q Is there anything that you recall saying 10 to Sharon Churcher that she then printed something 11 different than what you had said to her? 12 A Yeah, I've read stuff. I mean, I just -- 13 I can't remember what, but I read something that I 14 think was, Oh, she got that wrong. 15 an exact example off the top of my head. 16 17 18 Q I can't remember Did you ever complain to Sharon Churcher about things that she got wrong? A I didn't see a point. I might have, but 19 I -- I didn't see a point really because it's already 20 printed, you know. 21 Q You had a fairly voluminous set of 22 communications with Sharon Churcher by e-mail, 23 correct? 24 25 MS. MCCAWLEY: A Objection. Voluminous, like a lot of them? VIRGINIA GIUFFRE VOLUME II 11/14/2016 436 Agren Document Blando Court Reporting 2628248, & Video, Page19 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Q (BY MS. MENNINGER) 2 A Yes. 3 Q And during any of those communications, do Yes. 4 you know whether she printed things about you after 5 you had any of those communications? 6 7 A MS. MCCAWLEY: Objection. I don't know. I know a lot of stuff was 8 printed, and I never really stopped to read who 9 printed the article, or wrote the article, I should 10 11 12 say. Sorry. Q (BY MS. MENNINGER) I'll show you Defendant's Exhibit 7. 13 (Exhibit 7 marked.) 14 THE DEPONENT: 15 Okay. Q Thank you. (BY MS. MENNINGER) I'll let you read 16 through the statements on the first page there, and 17 if there is anything that is not absolutely true, 18 just put a check by it and we'll come back to it. 19 A It's not very clear how she wrote it. "I 20 flew to the Caribbean with Jeffrey and then Ghislaine 21 Maxwell went to pick up Bill in a huge black 22 helicopter that Jeffrey had bought her." 23 That wasn't an eyewitness statement. 24 Like, I didn't see her do it. 25 who told me about that; that she's the one who flew Ghislaine was the one VIRGINIA GIUFFRE VOLUME II 11/14/2016 437 Agren Document Blando Court Reporting 2628248, & Video, Page20 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 Bill. Q All right. If you just want to put a 3 check by it, then we'll just come back and talk about 4 each one. 5 A Okay. 6 Q Just to move things along. 7 A Okay. 8 Q All right. 9 I have made three checkmarks. MS. MCCAWLEY: And I just -- before you 10 continue, I just want to identify for the record, 11 since this doesn't have any identifiers on it, are 12 you representing that these are statements from 13 Sharon Churcher? 14 MS. MENNINGER: 15 anything. 16 these statements. 17 not true. 18 19 20 Q I'm not representing I'm asking the witness questions about I asked her is anything on here That's all I asked her. (BY MS. MENNINGER) So which ones did you put checkmarks by, Ms. Giuffre? A I'd have been -- I'm sorry. "I'd have 21 been about 17 at the time. 22 with Jeffrey and then Ghislaine Maxwell went to pick 23 up Bill in a huge black helicopter that Jeffrey had 24 bought her." 25 Q Okay. I flew to the Caribbean And what else did you put a check VIRGINIA GIUFFRE VOLUME II 11/14/2016 438 Agren Document Blando Court Reporting 2628248, & Video, Page21 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 by? 2 A "I used to get frightened flying with her 3 but Bill had the Secret Service with him and I 4 remember him talking about what a good job" -- 5 sorry -- "job she did." 6 7 Q Okay. A "Donald Trump was also a good friend of by? 8 9 And what else did you put a check Jeffrey's. He didn't partake in any sex with any of 10 us but he flirted with me. 11 Jeffrey, 'you've got the life.'" 12 13 Q He'd laugh and tell Other than the three you've just mentioned -- 14 A Yeah. 15 Q -- everything else on here is absolutely 16 accurate? 17 MS. MCCAWLEY: 18 19 A Yes. Objection. Well, to the best of my recollection, yes. 20 Q (BY MS. MENNINGER) All right. What is 21 inaccurate about, "I'd have been about 17 at the 22 time. 23 Ghislaine Maxwell went to pick up Bill in a huge 24 black helicopter that Jeffrey had bought her"? 25 I flew to the Caribbean with Jeffrey and then A Because it makes it kind of sound like an VIRGINIA GIUFFRE VOLUME II 11/14/2016 439 Agren Document Blando Court Reporting 2628248, & Video, Page22 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 3 4 eyewitness thing. Q Okay. Did you say that statement to Sharon Churcher? A I said to Sharon that Ghislaine told me 5 that she flew Bill in the heli- -- the black 6 helicopter that Jeffrey bought her, and I just wanted 7 to clarify that I didn't actually see her do that. 8 heard from Ghislaine that she did that. 9 Q You heard that from Ghislaine, and then 10 you reported to Sharon Churcher that you had heard 11 that from Ghislaine. 12 A 13 14 Correct. MS. MCCAWLEY: A Objection. I heard a lot of things from Ghislaine 15 that sounded too true -- too outrageous to be true, 16 but you never knew what to believe, so... 17 Q (BY MS. MENNINGER) Okay. And after 18 Sharon Churcher printed what she said you said, did 19 you complain to her that it was inaccurate? 20 A I might have verbally with her, but again, 21 I didn't see a point in making a hissy over it 22 because what was done was done. 23 printed. 24 25 Q I She had already What was inaccurate about, "I used to get frightened flying with her but Bill" said -- "had the VIRGINIA GIUFFRE VOLUME II 11/14/2016 440 Agren Document Blando Court Reporting 2628248, & Video, Page23 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Secret Service with him and I remember him talking 2 about what a good job she did"? 3 A I just don't remember saying that to her. 4 I don't remember saying I remember him talking about 5 what a good job she did. 6 Q All right. 7 A I just don't remember that at all. 8 Q Okay. 9 And I guess, just to be clear, my questions wasn't do you remember saying this to 10 Sharon Churcher; my question is, is that statement 11 accurate? 12 13 14 MS. MCCAWLEY: Q (BY MS. MENNINGER) A Yes. 16 Q Okay. 18 19 20 21 Did you used to get frightened flying with her? 15 17 Well, objection. Did Bill have the Secret Service with him? A They were there, but not like on the -- not where we were eating. Q Do you remember Bill talking about what a good job she did? 22 A I don't remember that. 23 Q So what is inaccurate about that 24 25 statement? A I just -- it's inaccurate because I don't VIRGINIA GIUFFRE VOLUME II 11/14/2016 441 Agren Document Blando Court Reporting 2628248, & Video, Page24 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 remember him talking about what a good job she did. 2 I don't remember that. 3 4 Q Does it inaccurately suggest that Bill had the Secret Service with him on a helicopter? 5 6 MS. MCCAWLEY: A Objection. Well, not being an eyewitness to it, I 7 wouldn't be able to tell you. 8 I don't know. 9 10 11 Q (BY MS. MENNINGER) I can't tell you what And do you believe you said that statement to Sharon Churcher? A I mean, Sharon and I talked a lot, and if 12 she misheard me or just wrote it in the way that she 13 thought she should, I have no control over that. 14 I'm not too sure. 15 Q Did she record your interviews? 16 A Some of them. So Some of them she didn't. 17 mean, we, like -- we, like, met for like a week, and 18 we spent a lot of time together, and then even after 19 that we just continued, like, kind of a friendship. I 20 21 Q All right. last statement on that page? 22 A 23 Jeffrey's." 24 25 What's inaccurate about the "Donald Trump was also a good friend of That part is true. "He didn't partake in any" of -- "any sex with any of us but he flirted with me." VIRGINIA GIUFFRE VOLUME II 11/14/2016 It's true 442 Agren Document Blando Court Reporting 2628248, & Video, Page25 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 that he didn't partake in any sex with us, and but 2 it's not true that he flirted with me. 3 never flirted with me. 4 Then the next sentence is, "He'd laugh and 5 tell Jeffrey, 'you've got the life.'" 6 that to her. 7 8 Donald Trump Q I never said When you say, "he didn't partake in any sex with any of us," who is "us"? 9 A Girls. 10 Q How do you know who Donald Trump -- Trump 11 12 Just -- had sex with? A Oh, I didn't physically see him have sex 13 with any of the girls, so I can't say who he had sex 14 with in his whole life or not, but I just know it 15 wasn't with me when I was with other girls. 16 17 18 19 Q And who were the other girls that you were with in Donald Trump's presence? A None. There -- I worked for Donald Trump, and I've met him probably a few times. 20 Q When have you met him? 21 A At Mar-a-Lago. My dad and him, I wouldn't 22 say they were friends, but my dad knew him and they 23 would talk all the time -- well, not all the time but 24 when they saw each other. 25 Q Have you ever been in Donald Trump and VIRGINIA GIUFFRE VOLUME II 11/14/2016 443 Agren Document Blando Court Reporting 2628248, & Video, Page26 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Jeffrey Epstein's presence with one another? 2 A No. 3 Q What is the basis for your statement that 4 Donald Trump is a good friend of Jeffrey's? 5 6 A Jeffrey told me that Donald Trump is a good friend of his. 7 Q But you never observed them together? 8 A No, not that I can actually remember. 9 I mean, not off the top of my head, no. 10 Q When did Donald Trump flirt with you? 11 A He didn't. 12 Q Did you ever see Donald Trump at Jeffrey's 13 That's what's inaccurate. home? 14 A Not that I can remember. 15 Q On his island? 16 A No, not that I can remember. 17 Q In New Mexico? 18 A No, not that I can remember. 19 Q In New York? 20 A Not that I can remember. 21 Q All right. If you could turn to the 22 second page and read through those. 23 any of those are inaccurate. 24 them and then we'll come back. 25 A Let me know if Just put a check by Okay. VIRGINIA GIUFFRE VOLUME II 11/14/2016 444 Agren Document Blando Court Reporting 2628248, & Video, Page27 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 MS. MCCAWLEY: Before you go, Virginia, 2 I'm going to object to the use of the second page of 3 this document. 4 no source reference to it, so it's entirely unclear 5 where this has come from. There's no time frame on it. 6 Q (BY MS. MENNINGER) 7 A Yes. 8 Q Okay. 9 10 Okay. There's Are you done? What's the first one you've put a check by? A "The hammock photo was all over the 11 houses," in parentheses. 12 sorry, "Bill Clinton and Andrew," in parentheses, 13 "had to have seen it." 14 And Bill Clinton and -- I'm "All over the houses" is not my statement 15 and an exaggeration. 16 the houses. 17 conversation correctly, she asked, Could have Bill 18 Clinton and Andrew seen the picture? 19 Yes, it's possible that they could have seen it. 20 They did have that picture in And I believe, if I remember the And I said, So, I mean, it's just that -- it's not 21 that it's totally inaccurate. 22 journalist writing, had to have seen it. 23 mean they saw it. 24 front of them, they would have seen it. 25 Q I just think it's like It doesn't I just think that if it was in So she told you that -- you told her that VIRGINIA GIUFFRE VOLUME II 11/14/2016 445 Agren Document Blando Court Reporting 2628248, & Video, Page28 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 the photograph was in the houses -- houses? 2 A Yes. I know he had it in New York on his 3 desk. 4 it in the Caribbean. 5 in New Mexico. I know he had it in Palm Beach. I know he had And I don't know if he had it I can't remember New Mexico. Maybe. 6 Q Where in Palm Beach was the photograph? 7 A The massage room. 8 Q Was that -- you did not say that they -- 9 10 11 12 13 14 it was all over the houses? A Correct. All over the houses would imply that it's everywhere in the house, so... Q You did not say that Andrew and Clinton had to have seen the photograph? A Correct. I -- it was more of a, if they 15 were in front of it, they would have seen it, kind of 16 a thing. 17 like, had to have seen it. 18 19 20 21 Q All right. But it wasn't, What's the next statement that you put a check by? A I'm sorry, excuse me. My kids shared a beautiful cough with me again. 22 23 I'm not saying it right. "I spent four years as a millionaire's personal masseuse." 24 Q What is inaccurate about that statement? 25 A We now know, according to the timelines VIRGINIA GIUFFRE VOLUME II 11/14/2016 446 Agren Document Blando Court Reporting 2628248, & Video, Page29 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 that Mar-a-Lago was able to provide for us, that it 2 was not four years. 3 Q How many years was it? 4 A More like 2-1/2, I think, if I'm right, or 5 two. 6 the two period. 7 8 I'm sorry, I'm really bad at math. Q But yes, What's the next statement that you have put a check by? 9 A "I was a pedophile's dream." I think she 10 took that out of context and made that her own little 11 headline. 12 Q Did you say that to her? 13 A I said something along the line like, I -- 14 the -- the pedos loved me because I would do 15 everything that they wanted for them. 16 that -- yeah, I -- I know she made that line up 17 herself, the pedos -- pedophile's dream. But do I think 18 Q What's the next one you put a check by? 19 A I put a question mark next to the next 20 one. 21 with her family." 22 to. 23 24 25 It says, "Three years later she was reunited I don't know what that pertains I don't know what timeline that means. Q Was there a period of three years where you were not with your family? A There's been longer periods than that VIRGINIA GIUFFRE VOLUME II 11/14/2016 447 Agren Document Blando Court Reporting 2628248, & Video, Page30 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 that -- when I wasn't with my family. 2 mean, I don't understand where that comes from. 3 "Three years later she was reunited with her family." 4 5 Q Prior to 2002, was there a period of three years where you were not with your family? 6 A No. 7 Q Okay. 8 9 10 11 12 That's what I Did you say to Sharon Churcher, three years later, she was reunited with her family? A That's what I don't understand. I don't even know what that time periods pertains to. Q Do you recall saying that to Sharon Churcher? 13 A No. 14 Q What's the next one you put a check by? 15 A "After about two years he started to ask 16 me to entertain his friends." 17 Q What's wrong with that statement? 18 A It wasn't two years. 19 I don't know where she got that from. 20 Q Okay. 21 A Like, I can't give you an exact time How long was it? 22 period, but it wasn't right in the beginning. 23 after my training, or so to speak training. 24 mean, my best guesstimate would be anywhere between 25 four to six months. VIRGINIA GIUFFRE VOLUME II 11/14/2016 It was So, I 448 Agren Document Blando Court Reporting 2628248, & Video, Page31 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Q So you did not say to Sharon Churcher, 2 "After about two years he asked me to entertain his 3 friends"? 4 A Correct. 5 Q What's the next one you put a check by? 6 A That's it. 7 8 9 10 11 12 That's all I put a checkmark next to. Q So the rest of these are absolutely accurate? A Nothing a journalist writes is absolutely accurate, but it's -- it sounds accurate, yes. Q Do you recall Jeffrey Epstein saying to 13 you, "I've got a good friend and I need you to fly to 14 the island to entertain him, massage him and make him 15 feel how you make me feel"? 16 MS. MCCAWLEY: 17 Go ahead. 18 A Objection. I do remember him saying that, and I think 19 that's more of a general- -- generalization for all 20 the times that I was sent to the -- where is this -- 21 the island to entertain people. 22 quote that she made but from my words saying that's 23 what he said to me when I had to go be with these 24 people that he sent me to. 25 Q (BY MS. MENNINGER) And that would be a Did you say that VIRGINIA GIUFFRE VOLUME II 11/14/2016 449 Agren Document Blando Court Reporting 2628248, & Video, Page32 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 sentence to her? 2 MS. MCCAWLEY: 3 4 A Objection. I -- I can't remember. Like I said, I think it's more of a generalization. 5 Q (BY MS. MENNINGER) 6 A Yes. 7 Q Did you meet Heidi Klum? 8 A Yes. 9 Q Did you meet Naomi Campbell? 10 A Yes. 11 Q Did you go on a six-week trip with Epstein 12 Did you meet Al Gore? in 2001? 13 A Yeah. 14 Q When in 2001 did you go on a six-week trip 15 Yes. Sorry. with him? 16 A I don't remember exactly when it was, but 17 it's that -- it's the one where we went to Tangier, 18 Morocco, England. 19 went. 20 I can't remember where else we France. Q Did the FBI tell you that Epstein had 21 hidden cameras watching you the entire time, even 22 when you were in the bathroom? 23 A Yes. 24 Q Did the FBI tell you "Everything he did 25 was illegal because I was under age"? VIRGINIA GIUFFRE VOLUME II 11/14/2016 450 Agren Document Blando Court Reporting 2628248, & Video, Page33 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 A Yes. 2 Q Who in the FBI told you that? 3 A Whichever agent I was talking to. 4 Q Which agent were you talking to? 5 A I can't remember. I know I was talking to 6 Jason Richards, and there was a girl, I think -- I 7 want -- I want to say her name was Christina Pryor, 8 just off the top of my head. 9 was two other agents actually at the consulate 10 building. And then I think there I don't remember their names. Very hazy. 11 Q When was this conversation with the FBI? 12 A After Sharon printed the articles, the 13 first articles that came out. 14 she printed, but when the first articles came out, 15 after that the FBI contacted me. 16 Q I don't know how many And was the statement that the FBI told 17 you "Everything he did was illegal because I was 18 under age," in response to you telling them that you 19 were age 15 when you met Jeffrey? 20 21 22 MS. MCCAWLEY: A Objection. Well, that was the closest proximity I had to go off of. 23 Q (BY MS. MENNINGER) 24 A So, yes. 25 Okay. Although I still was under age, I mean, even if I was 16 and 17. VIRGINIA GIUFFRE VOLUME II 11/14/2016 451 Agren Document Blando Court Reporting 2628248, & Video, Page34 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Q Okay. And then if you could do the last 2 page, same way; a check by anything that's not 3 absolutely accurate. 4 MS. MCCAWLEY: Okay. I'm going to object 5 to this as the last page has no identifier of time or 6 source on it. 7 A Okay. 8 Q (BY MS. MENNINGER) 9 10 I'm ready. All right. Which ones are inaccurate? A The first one is, "Virginia got a 11 part-time job as a changing room assistant." 12 full-time person there. I was a Sorry. 13 Q Okay. 14 A Again, I don't remember that exact So did you say that to Sharon? 15 conversation, but I know it was a full-time job, 16 and -- I mean, full-time as in the, you know, the 9 17 to 5 or whatever hours it was, so it wasn't 18 part-time. 19 that we had. 20 21 22 Q I don't remember the exact conversation Okay. What's the next thing you put a check by? A I put a question mark next to, "Another 23 lady led me into Jeffrey's bedroom. 24 me straight through into the massage room." 25 The lady walked I have no idea what circumstance that VIRGINIA GIUFFRE VOLUME II 11/14/2016 452 Agren Document Blando Court Reporting 2628248, & Video, Page35 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 pertains to. 2 don't even know what other lady she's talking about. 3 So... 4 5 Q Again, I don't know what that means. So you don't recall saying that to Sharon Churcher? 6 A Correct. 7 Q Okay. 8 I I don't even know what it means. What's the next one you have a check by? 9 A "Afterwards, she was given two $100 bills 10 and told to return the next day. 11 beginning of the four years she spent with Epstein." 12 13 Q All right. That was the What's wrong about that statement? 14 A Well, again, I just want to say that the 15 four years was inaccurate based upon memory and not 16 an actual timeline that we were able to get. 17 18 Q Did you say that to Sharon Churcher, that it was four years? 19 A I don't know if I said that to her or -- 20 oh, yeah, did I tell her it was four years? 21 did. Yes, I I'm sorry. 22 Q Okay. 23 A Well, this one is a question mark again. What else did you put a check by? 24 "Radar online has obtained exclusive diary entries of 25 a Teen Sex Slave." VIRGINIA GIUFFRE VOLUME II 11/14/2016 453 Agren Document Blando Court Reporting 2628248, & Video, Page36 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 It wasn't really a diary. It was, like, I 2 don't know how many pages of something that I wrote, 3 and Sharon used it, so... 4 Q 5 entry? 6 A She knew it wasn't a diary entry. 7 Q Okay. 8 A Yes. 9 Q What's the next one you have a checkmark A "I also saw Prince Andrew at a Ranch in 10 11 12 Did you tell Sharon it was your diary No. Were you a teen sex slave? by? New Mexico." 13 Q Did you tell that to Sharon Churcher? 14 A No. And I think it's a mistake. Maybe 15 she meant somewhere else, but because we had been 16 talking about so much, maybe she just put New Mexico. 17 I don't think Sharon intentionally lied on any of 18 these. 19 period of a week, and then after that we had phone 20 conversations, and so on and so forth, that some of 21 the information just got misheard or mishandled, or 22 whatever. I just -- I think we talked so much over a 23 Q And what was printed was inaccurate? 24 A Was that printed? 25 I don't -- I don't remember reading that in the papers, but if it was VIRGINIA GIUFFRE VOLUME II 11/14/2016 454 Agren Document Blando Court Reporting 2628248, & Video, Page37 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 3 4 printed it's inaccurate. Q Do you recall reading any of the ones that you put a checkmark by in the papers? A There's been so much printed, it's hard 5 for me to remember. 6 stuff I read before. 7 8 Q I mean, yes, it does sound like When you spoke with Sharon Churcher, you agreed to waive your anonymity, right? 9 A I did. 10 Q Why did you agree to do that? 11 A I felt it was time for me to tell my 12 story. 13 forward. 14 that it would be good for other people to hear what's 15 going on, how it's happening, how vulnerable other 16 girls can be and not even know the damage that it 17 causes later in life. 18 the right thing to do to come forward. I felt it was a good time for me to come I had done so much healing, and I thought And I just thought it would be 19 Q You authorized her to publish your name? 20 A I did. 21 Q And your photograph? 22 A Yes. 23 Q In 2011? 24 A I think that was the year, yes. 25 Q You posed for photographs with her, VIRGINIA GIUFFRE VOLUME II 11/14/2016 455 Agren Document Blando Court Reporting 2628248, & Video, Page38 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 I, VIRGINIA GIUFFRE, do hereby certify that 2 I have read the foregoing transcript and that the 3 same and accompanying amendment sheets, if any, 4 constitute a true and complete record of my 5 testimony. 6 ____________________________ Signature of Deponent 7 ( ) No amendments ( ) Amendments attached 8 9 10 11 Acknowledged before me this _______ day of _____________, 20___. 12 13 Notary Public: ___________________ 14 My Commission Expires: ___________ 15 Seal: 16 PJH 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 562 Agren Document Blando Court Reporting 2628248, & Video, Page39 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 STATE OF COLORADO) 2 ) 3 COUNTY OF DENVER ) 4 ss. REPORTER'S CERTIFICATE I, Pamela J. Hansen, do hereby certify that 5 I am a Registered Professional Reporter and Notary 6 Public within the State of Colorado; that previous to 7 the commencement of the examination, the deponent was 8 duly sworn to testify to the truth. 9 I further certify that this deposition was 10 taken in shorthand by me at the time and place herein 11 set forth, that it was thereafter reduced to 12 typewritten form, and that the foregoing constitutes 13 a true and correct transcript. 14 I further certify that I am not related to, 15 employed by, nor of counsel for any of the parties or 16 attorneys herein, nor otherwise interested in the 17 result of the within action. 18 19 20 In witness whereof, I have affixed my signature this 23rd day of November, 2016. My commission expires September 3, 2018. 21 22 23 _______________________________ Pamela J. Hansen, CRR, RPR, RMR 216 - 16th Street, Suite 600 Denver, Colorado 80202 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 563 Case 18-2868, Document 286, 08/09/2019, 2628248, Page40 of 55 Epstein did invite two young brunettes to a dinner which he gave on his Caribbean island for Mr. Clinton shortly after he left of?ce. I'd have been about 17 at the time. I ?ew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her. I remember she was very excited because she got her license around the ?rst year we met. I I used to get frightened ?ying with her but Bill had the secret service with him and I remember him talking about what a good job she did. I don't remember seeing Bill again on the trip but I assume Ghislaine ?ew him back. Virginia disclosed that Mr. Clinton's vice-president Al Gore and his wife, Tipper, were also guests of Epstein on his island. Virginia said that yet another American liberal icon, Senator George Mitchell, frequently visited Epstein?s New York residence. Mr. Mitchell, aged 77, was very close to Jeffrey, Virginia recalled. I also met Naomi Campbell at a birthday party of hers on a yacht in the South of France. She is a friend of Ghislaine's but she was a real bitch to me. 1 Donald Trump was also a good friend of effrey's. He didn't partake in any sex with any of us but he ?irted with me. He'd laugh and tell Jeffrey, ?you?ve got the life.? $7 ft 'n74/4M~ AGREN BLANDQ P0 if}; Case 18-2868, Document 286, 08/09/2019, 2628248, Page4l of 55 Ghislaine took nude picture of me lying naked in a hammock, posed with my legs open, a bit provocatively that I gave to Jeffrey for his birthday. The hammock photo was "all over the houses? and Bill Clinton and Andrew "had to have seen" 4 it. I spent four years as millionaire's personal masseuse. I was living on the streets, beaten up and slept with at least two older men in return for food. While on the streets, I slept with men for money. I was a paedophile?s dream. KL Three years later she was reunited with her family. After about two years, he started to ask me to 'entertain' his friends. She recalls he said ?I?ve got a good friend and I need you to ?y to the island to entertain him, massage him and make him feel how you make me feel.? The way it usually worked was I'd been sent to meet a man on the private island Jeffrey owned in the Caribbean, or at his ranch in New Mexico, which was really isolated. I met famous friends of his such as Al Gore and Heidi Klum and Naomi Campbell. She was, she says, delighted when Epstein invited her to accompany him on a six-week trip in 2001. FBI told me that Epstein had hidden cameras watching me the entire time even when I was in the bathroom. I was so embarrassed. The FBI told me everything he did was illegal because I was under age. Case 18-2868, Document 286, 08/09/2019, 2628248, Page42 of 55 Virginia got a part~time job as a changing room assistant. I told Ghisla-ine I wanted to become a masseuse and she said she worked for a very wealthy gentleman who was looking for a traveling masseuse. I?d get training and be paid well. (-3, Another lady led me into Jeffrey's bedroom. The lady walked me straight through into the a massage room. Afterwards, she was given two $100 bills and told to return the next day. That was the beginning of the four years she spent with Epstein. Radar Online has obtained exclusive "Diary entries" of "Teen Sex Slave". I led Prince Andrew into the upstairs bathroom next to the room I was staying in. I was doing my best trying to put on a good show for him by slowly undressing and started to pour a bath. He was caressing every part of my naked body and ?lling my head with endless compliments about my blossoming ?gure. He paid careful attention to my toes and was licking them. 1 I also saw Prince Andrew at the Ranch in New Mexico. Case 18-2868, Document 286, 08/09/2019, 2628248, Page43 of 55 EXHIBIT QQ 2628248, Page44 of 55 Sent: Fri 55/20/2011 2:20:09 AM Importance: Normal Subject: How ya doing?? Received: Fri 5/20/2011 2:20:09 AM Hi Buddy, I hope you are stopping to smell the daffodils once in a while and having a good day!! I am so excited today because I ca] go sign with an agent as my contract is finished with "Mail On Sandra and I have been working really hard to get me ready for my trip to the US in a few weeks and I was wondering if I could use your advice again. She has got an agent who is interested in speaking with me and I don?t want to say "Yes" to the first bite because I?m not su what to look for in an agent. What could you recommend that I do? I will send Jarred and Irene (your recommended agen a copy of the synopsis and sample chapters but how do I choose the right one for "The Story"? Do you know anyone else that might be interested in this as well? If so, i am keen on speaking with anyone who might be. I am excited about this and will keep you updated with the progressing events. When I am in New York we have to meet up for some city shopping and take the kids to Central Park to see the Zoo, given there will be no masturbating kangaroo's for you to make friends with, but who know's? I am looking forward to showing Robbie around and he's got some family out there 2 well we have to catch up with. Such busy times, but I?m loving it!! Anyways I hope your taking care and catch me up on your fun times?! Take care, Jenna CONFIDENTLAL GIUFFRE003959 Case 18-2868, Document 286, 08/09/2019, 2628248, Page45 of 55 EXHIBIT RR Agren Document Blando Court Reporting 2628248, & Video, Page46 Inc. Case 18-2868, 286, 08/09/2019, of 55 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS __________________________________________________ CONFIDENTIAL VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE May 3, 2016 __________________________________________________ VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. __________________________________________________ APPEARANCES: FAMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. By Brad Edwards, Esq. 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954.524.2820 brad@pathtojustice.com Appearing on behalf of the Plaintiff BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. (For Portion) 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301-2211 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE 5/3/2016 1 Agren Document Blando Court Reporting 2628248, & Video, Page47 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 3 4 5 6 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, Esq. Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant 7 8 Also Present: Brenda Rodriguez, Paralegal Nicholas F. Borgia, CLVS Videographer 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 2 Agren Document Blando Court Reporting 2628248, & Video, Page48 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Pursuant to Notice and the Federal Rules 2 of Civil Procedure, the VIDEOTAPED DEPOSITION OF 3 VIRGINIA GIUFFRE, called by Defendant, was taken on 4 Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150 5 East 10th Avenue, Denver, Colorado, before Kelly A. 6 Mackereth, Certified Shorthand Reporter, Registered 7 Professional Reporter, Certified Realtime Reporter 8 and Notary Public within Colorado. 9 * * * * * * * I N D E X 10 11 EXAMINATION PAGE 12 MS. MENNINGER 8 13 14 15 PRODUCTION REQUEST(S): (None.) 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 3 Agren Document Blando Court Reporting 2628248, & Video, Page49 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 INDEX OF EXHIBITS 2 3 INITIAL REFERENCE DESCRIPTION 4 Exhibit 1 Complaint and Demand for Jury Trial re Jane Doe No. 102 v. Jeffrey Epstein 17 Exhibit 2 Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in Action 21 Exhibit 3 Declaration of Virginia L. Giuffre re Jane Doe #1 and Jane Doe #2 vs. United States of America 23 Exhibit 4 Declaration of Jane Doe 3 re Jane Doe #1 and Jane Doe #2 vs. United States of America 31 Exhibit 5 Declaration of Virginia Giuffre re Bradley J. Edwards and Paul G. Cassell vs. Alan M. Dershowitz 33 Exhibit 6 FBI documentation, date of entry 7/5/13 36 Exhibit 7 Document titled Telecon, Participants Jack Scarola, Brad Edwards, Virginia Roberts. Re Edwards adv. Epstein, 4/7/11, (23 pages of transcription) 39 Exhibit 8 The Billionaire's Playboy Club, By Virginia Roberts 41 Exhibit 9 Plaintiff's Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff re Giuffre v. Maxwell 44 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 4 Agren Document Blando Court Reporting 2628248, & Video, Page50 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 INITIAL REFERENCE DESCRIPTION 3 Exhibit 10 Plaintiff's Supplemental Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff 46 Exhibit 11 Undated Declaration of Virginia Giuffre re Plaintiff's Supplemental Response and Objections to Defendant's First Set of Discovery Requests served on March 22, 2016 46 Exhibit 12 Plaintiff's Second Amended Supplemental Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff 47 Exhibit 13 Mrs. Virginia Giuffre resume 67 Exhibit 14 Compilation of e-mails re Open Position - Virginia Giuffre 68 Exhibit 15 Virginia Lee Roberts passport application 180 Exhibit 16 Composite of e-mail strings 251 Exhibit 17 Compilation of e-mails between Giuffre and Silva and others 259 Exhibit 18 Compilation of e-mails between Virginia Giuffre and Sandra White 265 Exhibit 19 Compilation of e-mails between Marianne Strong and Virginia Giuffre 269 Exhibit 20 Compilation of e-mails between Virginia Roberts and Jason Richards 276 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 5 Agren Document Blando Court Reporting 2628248, & Video, Page51 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 INITIAL REFERENCE DESCRIPTION 3 Exhibit 21 Compilation of e-mails between Sharon Churcher and Virginia Giuffre Exhibit 22 Compilation of e-mails among 287 Sharon Churcher, Michael Thomas, Virginia Giuffre and others Exhibit 23 Compilation of May 2011 e-mails among Sharon Churcher, Virginia Giuffre, Paulo Silva and others Exhibit 24 Compilation of June 2011 e-mails 289 between Virginia Giuffre and Sharon Churcher Exhibit 26 PR Hub Statement on Behalf of Ghislaine Maxwell article 300 Exhibit 27 1/2/15 e-mail from Ross Gow to To Whom It May Concern 309 4 284 5 6 7 8 288 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 6 Agren Document Blando Court Reporting 2628248, & Video, Page52 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Some names have been changed in order to protect 2 other people. 3 Q (BY MS. MENNINGER) 4 A Protect their privacy, yeah, I would say, Protect their privacy? 5 just not getting them involved in, if this were to 6 ever go public. 7 8 9 10 11 12 Q Well, again, without rereading the whole manuscript -A Reading it, yeah. I'm trying to see if I can -- see something in here. Q Let me narrow my question and maybe that will help. 13 A Yes. 14 Q Is there anything -- well, first of all, 15 did you author that entire manuscript? 16 A Yes, I did. 17 Q Did anyone else author part of that 18 manuscript? 19 A 20 Do you mean did anyone else write this with me? 21 Q Right. 22 A No. 23 Q That's all your writing? 24 A This is my writing. 25 Q Okay. To the best of your recollection, VIRGINIA GIUFFRE 5/3/2016 42 Agren Document Blando Court Reporting 2628248, & Video, Page53 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 as you sit here right now, is there anything in that 2 manuscript about Ghislaine Maxwell that is untrue? 3 4 A I don't believe so. Like I said, there is a lot of stuff that I actually have left out of here. 5 Q Um-hum. 6 A So there is a lot more information I could 7 put in there. 8 I would like to say that there is 99.9 percent of it 9 would be to the correct knowledge. 10 Q But as far as Ghislaine Maxwell goes, All right. Is there anything that you -- 11 and I understand you're doing this from memory. 12 there anything that you recall, as you're sitting 13 here today, about Ghislaine Maxwell that is contained 14 in that manuscript, that is not true? 15 A You know, I haven't read this in a very 16 long time. 17 here about Ghislaine Maxwell that is not true. 18 I don't believe that there's anything in MR. EDWARDS: I'd just ask, Counsel, if 19 you have anything specific to show her about 20 Ghislaine Maxwell -- 21 MS. MENNINGER: 22 MR. EDWARDS: 23 MS. MENNINGER: 24 MR. EDWARDS: 25 Is I'll ask questions. -- I'll have her look at it. I'll ask questions. I know, but I want the record clear that if she hasn't read it in a long VIRGINIA GIUFFRE 5/3/2016 43 Agren Document Blando Court Reporting 2628248, & Video, Page54 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 I, VIRGINIA GIUFFRE, do hereby certify that 2 I have read the foregoing transcript and that the 3 same and accompanying amendment sheets, if any, 4 constitute a true and complete record of my 5 testimony. 6 7 8 ________________________________ Signature of Deponent ( ) No Amendments ( ) Amendments Attached 9 10 11 12 Acknowledged before me this _____ day of ______________, 2016. 13 14 Notary Public: ________________________ 15 Address: _____________________________ 16 _____________________________ 17 My commission expires _________________ 18 Seal: 19 20 21 KAM 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 344 Agren Document Blando Court Reporting 2628248, & Video, Page55 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 STATE OF COLORADO) 2 ) 3 COUNTY OF DENVER ) 4 ss. REPORTER'S CERTIFICATE I, Kelly A. Mackereth, do hereby certify 5 that I am a Registered Professional Reporter and 6 Notary Public within the State of Colorado; that 7 previous to the commencement of the examination, the 8 deponent was duly sworn to testify to the truth. 9 I further certify that this deposition was 10 taken in shorthand by me at the time and place herein 11 set forth, that it was thereafter reduced to 12 typewritten form, and that the foregoing constitutes 13 a true and correct transcript. 14 I further certify that I am not related to, 15 employed by, nor of counsel for any of the parties or 16 attorneys herein, nor otherwise interested in the 17 result of the within action. 18 19 20 In witness whereof, I have affixed my signature this 11th day of May, 2016. My commission expires April 21, 2019. 21 22 23 ____________________________ Kelly A. Mackereth, CRR, RPR, CSR 216 - 16th Street, Suite 600 Denver, Colorado 80202 24 25 VIRGINIA GIUFFRE 5/3/2016 345 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA GIUFFRE, Giuffre, 15 Civ. 7433 ?against? SEALED .OPINION GHISLAINE MAXWELL, Maxwell. A A A S: Counsel for Giuffre BOIES, SCHILLER FLEXNER LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 By: Sigrid S. McCawley, Esq. Meredith L. Schultz, Esq. Counsel for Maxwell HADDON, MORGAN AND FOREMAN, P.C. 150 East Tenth Avenue Denver, CO 80203 By: Laura A. Menninger, Esq. Jeffrey S. Pagliuca, Esq. Case 18-2868, Document 287, 08/09/2019, 2628251, Page2 of 76 Sweet, D.J. The defendant Ghislaine Maxwell (?Maxwell? or the ?Maxwell?) has moved pursuant to Rule 56, Fed. R. Civ. P., for summary judgment dismissing the complaint of plaintiff Virginia L. Giuffre (?Giuffre? or the ?Giuffre?) alleging defamation. Upon the facts and conclusions set forth below, the motion is denied. I. Prior Proceedings Since the filing of the complaint on September 21, 2015, setting forth Giuffre?s claim of defamation by Maxwell, this action has been vigorously litigated, as demOnstrated by the 704 docket entries as of March 8, 2017. At issue is the truth or falsity of a January 2015 statement issued by Maxwell. Discovery has proceeded, a joint pretrial order has been filed, and the action is set for trial on May 15, 2017. The instant motion was heard and marked fully submitted on February 16, 2017. Case 18-2868, Document 287, 08/09/2019, 2628251, Page3 of 76 II. The Facts The facts have been set forth in Maxwell?s Memorandum of Law in Support of Maxwell?s Motion for Summary Judgment, Southern District of New York, Local Rule 56.1; Giuffre?s Statement of Contested Facts and Giuffre?s Undisputed Facts; and Maxwell?s Reply to Giuffre?s Statement of Contested Facts and Giuffre?s Undisputed Facts pursuant to Local Civil Rule 56.1. They are not in dispute except as noted below. 1. rIn early 2011, Giuffre, in two British tabloid interviews, made numerous false and defamatory allegations against Maxwell. In the articles, Giuffre made no direct allegations that Maxwell was involved in any improper conduct with Jeffrey Epstein (?Epstein?), who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, Giuffre suggested that Maxwell worked with Epstein and may have known about the crime for which he was convicted. Giuffre has denied that the allegations she made against Maxwell were false and defamatory. She noted that she did give an interview to journalist, Sharon Churcher (?Churcher?), in which she described Maxwell?s role as someone Case 18-2868, Document 287, 08/09/2019, 2628251, Page4 of 76 who recruited or facilitated the recruitment of young females for Epstein, that she was interviewed by the FBI in 2011, and that she discussed Maxwell?s involvement in the sexual abuse. 2. In the articles, Giuffre alleged she had sex with Prince Andrew, ?a well?known businessman,? a ?world?renowned scientist,? a ?respected liberal politician,? and a ?foreign head of state.? Giuffre did not contest this statement but noted it is irrelevant. 3. In response to the allegations, Maxwell?s British? attorney, working with Ross Gow Maxwell?s public relations representative, issued a statement on March 9, 2011, denying ?the various allegations about [Maxwell] that have appeared recently in the media. These allegations are all entirely false.? Giuffre has denied that Maxwell?s British attorney, Philip Barden (?Barden?), ?issued a statement,? noting that it appears to have the contact ?Gow? and a reference to.Devonshire Solicitors. Case 18-2868, Document 287, 08/09/2019, 2628251, Page5 of 76 4. The March 9, 2011 statement read in full: Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 2011 London, March 10, 2011 Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. It is unacceptable that letters sent by Maxwell?s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Maxwell is now_proceeding to take legal action against those newspapers. understand newspapers need stories to sell copies. It is well known that certain newSpapers live by the adage, ?why let the truth get in the way of a good story.? However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop,? said Ghislaine Maxwell. number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,? she said. Media contact: Ross Gow Acuity Reputation' Tel: Mob: +44?7778?755?251 Email: ross@acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: Case 18-2868, Document 287, 08/09/2019, 2628251, Page6 of 76 Mob: +44?7778-755?251, Email: rose at acuityreputation.com Giuffre has noted it is unclear if the original included the italics that are inserted above. 5. In 2008, two alleged victims of Epstein brought an action under the Crime Victims? Rights Act (the I Action?) against the United States Government purporting to challenge Epstein?s plea agreement. They alleged the Government violated their CVRA rights by entering into the agreement. 6. 'Giuffre moved to join the CVRA Action on December 30, 2014, claiming she, too, had her CVRA rights violated by the Government. On January 1, 2015, Giuffre filed a ?corrected? joinder motion. See Jane Doe 1 and Jane Doe 2 v. United States, No. Docket No. 280 (S.D. Fla. Jan. 2, 20l5) Joinder Giuffre?s joinder motion in this unrelated action included gratuitous and ?lurid? accusations. Giuffre has denied the final sentence fragment. 7. The issue presented in the joinder motion was narrow: whether Giuffre should be permitted to join the CVRA Case 18-2868, Document 287, 08/09/2019, 2628251, Page7 of 76 8 Action as a party under Federal Rule of Civil Procedure 2l, specifically, whether she was a ?known victim[] of Mr. Epstein and the Government owed them CVRA duties.? Jane Doe and Jane Doe 2 v. United States, No. Docket No. 324 (S.D. Fla. Apr. 7, 2015) Mot. at 5. Yet, ?the bulk of the [motion] consists of copious factual details that [Ms. Giuffre] and [her co?movant] ?would prove . . . if allowed to join.?? Id. Giuffre gratuitously included provocative and ?lurid details? of her alleged sexual activities as an alleged victim of sexual trafficking. Giuffre has denied that the issues presented in her joinder motion were narrow and has noted that the issues presented by the joinder motion and related pleadings were multiple and Complex, requiring numerous details about Giuffre?s sexual abuse and the listing of the perpetrators of her abuse. In a pleading explaining why the motion was filed, see Jane Doe and Jane Doe 2 v. United States, No. Docket No. 291 at 18?26 n.l7 (S.D. Fla. Jan. 2l, 2015), Giuffre?s lawyers specifically listed nine separate reasons why Jane Doe 3?s allegations that Alan Dershowitz (?Dershowitz?) had sexually abused her were relevant to the case and appropriately included in the relevant filings. Additionally, Giuffre states that Judge Case 18-2868, Document 287, 08/09/2019, 2628251, Page8 of 76 Marra?s ruling concluded that certain allegations were not necessary ?at this juncture in the proceedings,? adding that ?Jane Doe 3 is free to reassert these factual details through proper evidentiary proof, should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a matter presented for the Court?s consideration.? CVRA Mot. Op. at 5?6. Giuffre notes that the CVRA litigation continues and no trial has been held as of the filing of this motion so that the extent to which these factual details will be used at trial has not yet been determined. See Docket Sheet, Jane Doe and Jane Doe 2 V. United States, No. 8. At the time they filed the motion, Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA Action. While they deliberately filed the motion without disclosing Giuffre?s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. Giuffre has noted her denial as Set forth to Statement 7 above. Case 18-2868, Document 287, 08/09/2019, 2628251, Page9 of 76 9. As the district court noted in ruling on the joinder motion, Giuffre ?name[d] several individuals, and she offers details about the type of sex acts performed and where they took place.? CVRA Mot. Op. at 5. The court ruled that ?these lurid details are unnecessary,? explaining that ?[t]he factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent . . . especially considering that these details involve nonparties who are not related to the respondent Government.? Id. Accordingly, ?[tJhese unnecessary details shall be stricken.? Id. The court then struck all Giuffre?s factual allegations relating to her alleged sexual activities and her allegations of misconduct by non?parties. Id. at 6. The court said the striking of the ?lurid details? was a sanction for Giuffre?s improper inclusion of them in the motion. Id. at 7. Giuffre has noted her denial as set forth in Statement 7 above. 10. The district court in the CVRA Action found not only that the ?lurid details? were unnecessary but also that the joinder motion itself was ?entirely unnecessary.? Id. at 7. Giuffre and her lawyers knew the motion with.all its ?lurid Case 18-2868, Document 287, 08/09/2019, 2628251, Page10 of 76 details? was unnecessary because the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. The court denied Giuffre's joinder motion. Id. at 10. Giuffre has noted her denial as set forth in Statement 7 above. ll. One of the non?parties Giuffre ?named? repeatedly in the joinder motion was Maxwell. According to the ?lurid details? of Giuffre included in the motion, Maxwell personally was involved in a ?sexual abuse and sex trafficking scheme? created by Epstein: I Maxwell ?approached? Giuffre in 1999 when Giuffre was ?fifteen years old? to recruit her into the scheme. 0 Maxwell was ?one of the main women? Epstein used to ?procure under?aged girls for sexual activities.? 0 Maxwell was a ?primary co?conspirator? with Epstein in his scheme. 0 She ?persuaded? Giuffre to go to Epstein's mansion ?in a fashion very similar to the manner in which Epstein and his other co?conspirators coerced dozens of other children.? 10 Case 18-2868, Document 287, 08/09/2019, 2628251, Pagell of 76 0 .At the mansion, when Giuffre began giving Epstein a massage, he and Ms. Maxwell ?turned it into a sexual encounter.? 0 Epstein ?with the assistance of? Maxwell ?converted [Giuffre] into . . . a ?sex slave.?? Id. Giuffre was a ?sex slave? from ?about 1999 through 2002.? 0 Maxwell also was a ?co-conspirator in Epstein?s sexual abuse.? 0 Maxwell ?appreciated the immunity? she acquired under Epstein?s plea agreement, because the immunity protected her from prosecution ?for the crimes she committed in Florida.? 0 Maxwell ?participat[ed] in the sexual abuse of [Giuffre] and others.? Maxwell ?took numerous sexually explicit pictures of underage girls involved in sexual activities, including [Giuffre].? Id. She shared the photos with Epstein. 0 .As part of her ?role in Epstein?s sexual abuse ring,? Maxwell ?connect[ed]? Epstein with ?powerful individuals? so that Epstein could traffic Giuffre to these persons. 0 Giuffre was ?forced to have sexual relations? with Prince Andrew in ?[Maxwell?s] apartment? in London. Maxwell ?facilitated? Giuffre?s sex with Prince Andrew ?by acting as a ?madame? for Epstein.? - Maxwell ?assist[ed] in internationally trafficking? Giuffre and ?numerous other young girls for sexual purposes.? 0 Giuffre was ?forced? to watch Epstein, Maxwell and others ?engage in illegal sexual acts with dozens of underage girls.? See CVRA Joinder Mot. ll Case 18-2868, Document 287, 08/09/2019, 2628251, Page12 of 76 Giuffre has denied the reference to ?lurid details? and has noted her denial as set forth in Statements 6 and 7 above and that the testimony from numerous witnesses has corroborated the statements Giuffre made in her joinder motion: 0 [Johanna Sjoberg (?Sjoberg?) May 18, 2016 Dep. Tr. at 8?9, 13, 33?35, 142?143. 0 .Anthony Figueroa (?Figueroa?) June 24, 2016 Dep. Tr. Vol. 1 at 96?97 and 103. 0 Rinaldo Rizzo (?Rizzo?) June 10, 2016 Dep. Tr. at 52?60. 0 Miller?s May 24, 2016 Dep. Tr. at 115. 0 Joseph Recarey?s June 21, 2016 Dep. Tr. at 29?30. 0 David Rodgers? June 3, 2016 Dep. Tr. at 18, 34?36. 0 Excerpted Rodgers Dep. Ex. 1 at flight #8 143391434, 1444?1446, 1464?1470, 1478?1480, 1490?1491, 1506, 1525?1526, 1528, 1570, and 1589. 0 NadiaMarcinkova (?Marcinkova?) Dep. Tr. at 10:18?21; 12:11?15; etc. 12 Case 18-2868, Document 287, 08/09/2019, 2628251, Page13 of 76 0 Sarah Kellen (?Kellen?) Dep. Tr. at 15:13- 18; 20:12?16; etc. 0 Epstein Dep. Tr. at 116:10-15; 117:18? 118:10; etc. 0 Juan Alessi (?Alessi?) DepU.S. Attorney Victim Notification Letter GIUFFRE002216-002218. 0 July 2001 New York Presbyterian Hospital Records GIUFFREOO3258-OO3290. 0 Judith Lightfoot records 0 Message Pad evidencing Maxwell arranging to have underage girls and young women come to Epstein?s home 0 ?Black Book? in which Maxwell and other household staff maintained a roster of underage girls including minors at the time the Palm Beach Police?s Investigation of Jeffrey Epstein GIUFFRE001573-00669. 13 Case 18-2868, Document 287, 08/09/2019, 2628251, Page14 of 76 0 Sex Slave books Epstein ordered from Amazon.com at GIUFFRE006581. 0 The folder Maxwell sent to Thailand with Giuffre bearing Maxwell?s phone number 0 The Palm Beach Police Report showing that Epstein used women and girls to collect underage girls for his abuse 005700. 0 Epstein?s Flight Logs showing that Maxwell flew with Giuffre 23 times 007161. 12. In the joinder motion, Giuffre also alleged she was ?forced? to have sex with Dershowitz, ?model scout? Jean Luc Brunel, and ?many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well?known Prime Minister, and other world leaders.? CVRA Joinder Mot. at 5?6. Giuffre has noted her denial as set forth in Statements 7 and 11 above. 14 Case 18-2868, Document 287, 08/08/2019, 2628251, PagelS of 76 13. Giuffre said after serving for four years as a ?sex slave,? she ?managed to escape to a foreign country and hide out from Epstein and his co?conspirators for years.? Id. at 3. Giuffre has admitted making this statement and has noted since discovered evidence that indicates she was mistaken on the exact timeframe of her abuse and was with Maxwell and Epstein?from the years 2000?2002. 14. Giuffre suggested the Government was part of Epstein?s ?conspiracy? when it ?secretly? negotiated a non? prosecution agreement with Epstein precluding federal prosecution of Epstein and his ?co?conspirators.? Id. at 6. The Government?s secrecy, Giuffre alleged, was motivated by its fear that Giuffre would raise ?powerful objections? to the agreement that would have ?shed tremendous public light? on Epstein and other powerful individuals. Id. at 6-7. Giuffre has denied that she suggested that the Government was part of Epstein?s conspiracy to commit sex offenses and has noted that the CVRA Action deals with whether the Government failed in their responsibilities to the victims 15 Case 18-2868, Document 287, 08/09/2019, 2628251, Pagel6 of 76 to inform the Victims that the Government was working out an NPA, that the Government did fail to so inform the victims, and that it intentionally did not inform the victims because the expected serious objection from many of the victims might prevent the Government from finalizing the NPA with Epstein. 15. The other ?Jane Doe? who joined Giuffre?s motion who alleged she was sexually abused on ?many occasions? by Epstein was unable to corroborate any of Giuffre's allegations. Giuffre has denied the statement and noted that the other Jane Doe could corroborate many of Giuffre's allegations based on a similar pattern of abuse by Epstein that she suffered, that she did not know Giuffre, and further has noted who was deposed in this case, and who was a minor, corroborates the same pattern of abuse. 16. In her multiple and consensual interviews with Churcher three years earlier, Giuffre told Churcher of virtually none of the details she described in the joinder motion. 16 Case 18-2868, Document 287, 08/09/2019, 2628251, Page17 of 76 Giuffre has denied the statement and noted that absence of any citation or evidence on this point and that the statement here is knowingly false based on the articles and Giuffre?s deposition. 17. As Giuffre and her lawyers expected, before Judge Marra in the CVRA Action could strike the ?lurid details? of Giuffre's allegations in the joinder motion, members of the media obtained copies of the motion. Giuffre has denied the statement as set forth in Statement 7 above. 18. At the direction of Barden, on January 2, 2015, Gow sent to numerous representatives of British media organizations an email containing ?a quotable statement on behalf of Maxwell? (the ?Press Release?). The email was sent to more than six and probably fewer than 30 media representatives. It was not sent to non?media representatives. Giuffre has denied that Mr. Barden?s direction, on January 2015, Gow sent to numerous representatives of British media organizations an email containing ?a quotable l7 Case 18-2868, Document 287, 08/09/2019, 2628251, Pagel8 of 76 statement on behalf of Maxwell?? and has noted that Gow produced an email exchange he had with Maxwell in which Maxwell directs Gow to send the Press Release as follows: 3-3-3, 2 has: 2333 23*2433 +3333 2m3mam Ca: 33233;: hardan?mnahamatm hits Saki?rah 333m?? Ethis ia than as man new ihdhri?hah Jena 5304: .3 is? 333,; aha?gm made 15,, vm?; 352mm against =i3i3aiaine Mat-await an: ?i'ha insights? 3331;131:4133: has hat may and have has remains an and smith in am: Earth aim the may i3 he this it ahames with new awn about 31033:: 333m and maid in and by at mama in 3333a wait has. ?nish its hernias Magnum shims a: as abstain he heat?? as sash awash hahfiai?aas 332131135, as they are . Giuffre has further noted that chronologically, this email comes at the end of various other email exchanges between Maxwell and Gow that discuss issuing a press release and that the subject line of this email that Maxwell wrote to Gow states this is the statement,? thereby instructing Gow to release this statement to the press. Additionally, Giuffre notes that shortly after Maxwell sent this email to Gow directing him to release the Press Release, Gow distributed it to multiple media outlets, and that no email has been produced.in which 18 Case 18-2868, Document 287, 08/09/2019, 2628251, Page19 of 76 Barden directed Gow to issue this press release. At his deposition, Gow authenticated this email and confirmed that Maxwell authorized the statement. Giuffre has noted that the email and Gow?s testimony establish that Maxwell, not Barden, directed and ?command[ed]? \Gow to publish the defamatory statement and the first sentence of the statement is false and the second sentence ?This email was sent to more than 6 and probably less than 30 media representatives? omits the fact that not only did Gow admit to emailing the statement to the press, but he also read it to over 30 media representatives over the phone. Giuffre has denied the statement. 19. Among the media representatives who received the Press Release were Martin Robinson of the Daily Mail, P. Peachey of The Independent, Nick Sommerlad of The Mirror, David Brown of The Times, Nick Always and Jo?Anne Pugh of the BBC, and David Mercer of the Press Association. These representatives were selected based on their request after the joinder motion was filed?for a response from Maxwell to Giuffre?s allegations in the motion. l9 Case 18-2868, Document 287, 08/09/2019, 2628251, Page20 of 76 Giuffre has denied the second sentence and has noted there is no record evidence that Gow (or anyone else) ?selected? journalists ?for a response,? or that there was any selection process and that Gow testified that anyone who inquired received a reference to the Press Release. 20. The email to the media members read: To Whom It May Concern, Please find attached a quotable statement on behalf of Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts?so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms. Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms. Roberts claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory. 20 Case 18-2868, Document 287, 08/09/2019, 2628251, Page21 of 76 Ghislaine Maxwell?s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. Giuffre has noted that the body text of the email that was sent to news media was cropped and the headings and metadata were omitted and has further noted the image of the email set forth below. 21 333333 3 3333333 23333 333 33 33333333 33333333 3.333333 33333333333333= - - 3.33333 3333 333333333 3 3333333333 3333333333: 333 33333313 33 M3 333333333 333 33.333333333333333; 3333 '33 33333333 33- 333333 3333 333333333 333331.333 3?33 33333 3333333333333 3333: 3333 33333 332331333 3333333332333 33333 3333 33333333 33 333 33333 33 33 333333 333.33 33333 3333 1333.33 E33- 33? 3331 13 3333333 3.3333 3333 3333333333 31333333 333333 3333333 {?33333 3333 33.3313! 3333333. 3331 33333 33 3'3 33333331 by 1333 333333333 3333 31333 33333- 333 13 333313331 3'3 33333333 33333 3333333333 33333 33333 33131333 '33 333333 333 33333333 33333333 333 3333333 3333 33:33 33333333 333- 33333333 33 33333 3333' 3333: 33333333333 33 333333 33 33" 33 3333333333333 33333333333 33333 33333331 33333333 33 333 3331 3333333333 31333333 33333333 3.33 333333 133333133 5.3333313 3.3333333 33333333333 33 3333 3353333333 33333333 3333333 13333 333333333 333 3333 33333313 33333 3.33 333333333 3.3331 33333333 3333 333333 :33 3333 33333333 33 3333 33333333333 33 333313 33131 3333333333 33313333 33333 333333 3333333 .1333?? 33333333 3333133 21. Barden, who prepared the Press Release, did not intend it as a traditional press release solely to disseminate information to the media, and he intentionally did not pass it through a public relations firm, such as Gow?s firm, Acuity Reputation. 22. Case 18-2868, Document 287, 08/09/2019, 2628251, Page23 of 76 Giuffre has denied the statement and has noted that the Barden Declaration should not be considered. She has further noted that there is no evidence to support any assertion of Barden?s intent and that Maxwell gave the statement to Gow with instructions to publish it. Giuffre also has denied that the statement did not pass ?through a public relations firm, such as Gow?s firm, Acuity Reputation? and has noted that record documentary evidence and testimony establish that this statement was disseminated through Gow?s firm, Acuity Reputation. 22. The Press Release served two purposes. First, Barden intended that it mitigate the harm to Maxwell?s reputation from the press?s republication of Giuffre?s false allegations. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject Giuffre?s allegations to inquiry and scrutiny. For example, he noted in the statement that Giuffre?s allegations changed dramatically over time, suggesting that they are ?obvious lies? and therefore should not be ?publicized as news.? Giuffre has denied this statement and any statement of Barden?s intent and that there was any ?republication? by the 23 Case 18-2868, Document 287, 08/09/2019, 2628251, Page24 of 76 press as a matter of law as the press did not ?republish? the press statement under New York law and that the allegations in the statement are ?false,? and cites to the evidence set forth in Statement ll above. Giuffre has further disputed that the harm to Maxwell?s reputation could be mitigated by the media?s inquiry into and scrutiny of Giuffre?s allegations, because a deeper inquiry would only reveal additional evidence corroborating Giuffre?s allegations, and has noted that the record does not establish who drafted the Press Release, and that it was ultimately Maxwell who ?noted? anything because it is her statement and that she directed that it be sent to the media and public. Giuffre has also disputed that her allegations have changed over time, ?dramatically? or otherwise, that the Press Release ?suggest[ed]? that her allegations are ?obvious lies,? because the Press ReleaSe affirmatively stated that her allegations are ?obvious lies? there is no subtlety, suggestion, or statement of opinion here. 24 Case 18-2868, Document 287, 08/09/2019, 2628251, Page25 of 76 23. Barden intended the January 2015 statement to be ?a shot across the bow? of the media, which he believed had been unduly eager to publish Giuffre?s allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that Giuffre?s allegations were ?defamatory.? In this sense, the statement was intended as a cease and desist letter to the media?recipients, letting the media?recipients understand the seriousness with which Maxwell considered the publication of Giuffre?s obviously false allegations and the legal indefensibility of their own conduct. Giuffre has denied this statement and the statement that Barden repeatedly noted that Giuffre?s allegations were ?defamatory? as he did not ?note? anything in the statement, nor does Maxwell cite to any record evidence that he did. Giuffre further denies the sentence, ?In this sense, the statement was intended as,a cease and desist letter to the media?recipients, letting the media?recipients understand the seriousness with which Maxwell considered the publication of Giuffre's obviously false allegations and the legal indefensibility of their own conduct,? as there is no record 25 Case 18-2868, Document 287, 08/09/2019, 2628251, Page26 of 76 evidence in support of this claim, and Maxwell has not cited any. 24. Consistent with his purposes as described by Maxwell, Gow?s emails prefaced the statement with the following language: ?Please find attached a quotable statement on behalf of Maxwell.? The statement was intended to be a single, one?time only, comprehensive response, quoted in full, to Giuffre?s December 30, 2014, allegations that would give the media Maxwell?s response. The purpose of the prefatory statement was to inform the media?recipients of this intent. Giuffre has disputed the statement and any statement relating to Barden?s ?purposes,? as explained above, and has noted that Gow repeatedly issued this statement via email and over the phone for months on end and that Maxwell instructed them to publish it by telling them it was ?quotable,? and hired a press agent to distribute it to the press with the intent for the press to publish the Press Release. 25. Giuffre has engaged in numerOus activities to bring attention to herself, to the prosecution and punishment of 26 Case 18-2868, Document 287, 08/09/2019, 2628251, Page27 of 76 wealthy individuals such as Epstein, and to her claimed interest of bringing light to the rights of victims of sexual abuse. Giuffre has denied that she engaged in activities to bring attention to herself but has noted that she has taken action to aid in the prosecution of her abusers, and she seeks to bring light to the rights of victims of sexual abuse. 26. Giuffre created an organization, Victims Refuse Silence, Inc., a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. 27. The ?goal? of Victims Refuse Silence ?was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse.? Toward this end, Giuffre has ?dedicated her professional life to helping victims of sex trafficking.? 28. Giuffre repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. 27 Case 18-2868, Document 287, 08/09/2019, 2628251, Page28 of 76 Giuffre has denied the statement and noted that she was approached by numerous media outlets and refused to speak to most of them, that media organizations sought her out and she did not seek them out. 29. Giuffre has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein?s alleged ?sex scheme.? Giuffre has stated that this mischaracterizes these activities, that it was against a backdrop of seeking counseling that she drafted the manuscript as an ?act of empowerment? and ?a way of reframing and taking control over the narrative.? Pl.?s Opp?n at 60. Giuffre notes that she ultimately decided not to publish the manuscript. See Giuffre Dep. Tr. 249:16?18; 250:19?2Slz3. 30. Giuffre was required by Interrogatory No. 6 to identify any false statements attributed to Maxwell that were ?published globally, including within the Southern District of New York,? as Giuffre alleged in Paragraph 9 of Count One of her complaint. In response, Giuffre identified the Press Release and 28 Case 18-2868, Document 287, 08/09/2019, 2628251, Page29 of 76 nine instances in which various news media published portions of the Press Release in news articles or broadcast stories. Giuffre has denied this statement. There is no ?republication? as a matter of law and Maxwell possesses the knowledge as to where the defamatory statements were published, and Giuffre has noted that she has provided a sampling of Maxwell?s defamatory statements published by the news media and that Maxwell caused her statement to be published in an enormous number of media outlets. 29 Case 18-2868, Document 287, 08/09/2019, 2628251, Page30 of 76 REDQED, . 31111 DDE 3 1 Virgma 1111313315 DADEW 11111131111131 1113113- 1111 1313111113 33311111 11133113111 31E 1111311131 3111233111133 31E DEE DEW 31111 DEED 1'11 311d- 311-DEED .13. DE DDEEDE- ?3111 DEDE 111E 510111 125' IE 13111 it 1111111 1111111; 1133113113 {11113133 3113111 31111111: ?gurEE 311131. 11311111 . 31111 1111111 it 1S 1111331111 D11 11113 11131 131311. 1E 11213113113 1111111 DEE Wilich DE EDD 3 111311113 31E 111111111115 DEE 311131- 51111111111111 33 DEED 31111 DEE :11 111251315. 35 111E111 31E deform 61115131112 0113,1113. ED EDE DEE 31111. .dEfamazEry EIEDDE 1:qu EDE $311112 DEEMED 311311311; of 311 113111111, 111111111 DDVE 3311111311311 111 EDE 31111511 DEEDS and . . DE: 113111 111 DEED 31 DEE SEED 11111 1111111111 [31111 11m dEfamamry 121311113 DEIEDE 3111111511 3E3. EDEE. 151131111 31111131113315 {1311111111 DEED 1 D1311 1323 '11::an 31:23:11 ?3112111 1321: 131111311 3.131115 3.1311133 5111153 11311311111115 - DEE-1.11 21111111 3111119. 111:1 I113. newest ar?EIEs 113111135 1111311 1:61:24 E11 1?3- 11113 111113 11131 1111111113 DEEDEE 31111135337333 31115 30 Case 18-2868, Document 287, 08/09/2019, 2628251, Page31 of 76 31. In none of the nine instances was there any publication of the entire Press Release. Giuffre has noted extensive evidence of the mass distribution of Maxwell?s defamatory statement to over 66 million viewers as stated by her expert witness James Jansen (?Jansen?). 32. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in Giuffre?s_response to Interrogatory No. 6, in connection with the media?s publication of portions of the Press Release Giuffre has disputed this statement and noted it is completely devoid of record evidence and that the record establishes that Maxwell hired Gow because his position allowed him to influence the press to publish her defamatory statement, Dep. Tr. at 13:9-16; 15:18?16:3; 109212?22; llO:l6-21; and that Maxwell caused her statement to be published by numerous major news organizations with wide readership all over the globe. 3l Case 18-2868, Document 287, 08/09/2019, 2628251, Page32 of 76 33. Eight years after Epstein?s guilty plea in Florida, Giuffre brought this action, repeating many of the allegations she made in her CVRA joinder motion. Giuffre has noted that the defamation cause of action against Maxwell did not accrue until Maxwell defamed her in January of 2015. 34. The complaint alleged that the January 2015 statement ?contained the following deliberate falsehoods?: That Giuffre?s sworn allegations ?against Ghislaine Maxwell are untrue.? That the allegations have been ?shown to be untrue.? That Giuffre?s ?claims are obvious lies.? 35. Giuffre lived independently from her parents with her fiance long before meeting Epstein or Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999, Giuffre moved in with the family of a fellow patient. There she 32 Case 18-2868, Document 287, 08/09/2019, 2628251, Page33 of 76 met, and became engaged to, her friend?s brother, James Michael Austrich (?Austrich?). She and Austrich thereafter rented an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs in that area. Later, they stayed briefly with Giuffre?s parents in the Palm Beach/Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. Although Giuffre agreed to marry Austrich, she never had any intention of doing so. Giuffre has denied that she voluntarily lived independently from her parents with her fiance; she states that she was a troubled minor child who was not realistically engaged prior to meeting Maxwell and Epstein, as she was not of legal age to marry. She confirms she had no intention of marrying Austrich. 36. Giuffre re?enrolled in high school from June 21, 2000 until March 7, 2002. After finishing the 9th grade school year at Forest Hills High School on June 9, 1999, Giuffre re? enrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on August 14, 2001. On September 20, 2001, Giuffre then enrolled at Royal Palm Beach High School. A few weeks later, on October 12, 2001, she matriculated at 33 Case 18-2868, Document 287, 08/09/2019, 2628251, Page34 of 76 Survivors Charter School. Survivor?s Charter School was an alternative school designed to assist students who had been unsuccessful at more traditional schools. Giuffre remained enrolled at Survivor?s Charter School until March 7, 2002. She was present 56 days and absent 13 days during her time there. Giuffre never received her high school diploma or GED. The school day at Survivor's Charter School lasted from morning until early afternoon. Giuffre has denied the statement and has noted that Giuffre?s school transcripts indicate COURSES for the 1999?2000 and 2000?200l school years and that her attempt to work and resume school at Survivor?s Charter School as a 10th grader in the 2001?2002 school year was limited to a portion of the school year, spanning fewer than six months from October 2001 to March 7, 2002. She states that she attempted to get away from Epstein?s abuse and that the records indicate that Giuffre?s attendance was poor, with 69 days present and 32 days absent out of a required l80 day school year. She was not enrolled at the end of the school year. Her presence on flights with Epstein, verified by Epstein?s pilot on flight logs, and an abundance of witness testimony corroborate her story that she was flying domestic and internationally with Epstein at least 32 34 Case 18-2868, Document 287, 08/09/2019, 2628251, Page35 of 76 times between December ll, 2000 to July 28, 2001 and June 21, 2002 to August 21, 2002. 37. During the year 2000, Giuffre worked numerous jobs. In 2000, while living with her fiance, Giuffre held five different jobs: at Aviculture Breeding and Research Center, Southeast Employee Management Company, The Club at Mar?a-Lago, Oasis Outsourcing, and Neiman Marcus. Her taxable earnings that year totaled nearly $9,000. Giuffre cannot now recall either the Southeast Employee Management Company or the Oasis Outsourcing jobs. Giuffre has disputed the statement and has noted that while she held various jobs in 2000, Social Security Administration records do not show the exact dates of employment (month and day) because they do not need this information to figure Social Security benefits. She states that neither Southeast Employee Management Company nor Oasis Outsourcing were her employers. She states that she worked at Taco Bell, as well as a pet store, but that neither of these are listed on her Social Security Administration records because they were most likely paid through payroll companies. She subsequently worked at Mar?a?Lago. She also volunteered at Aviculture Breeding and 35 Case 18-2868, Document 287, 08/09/2019, 2628251, Page36 of 76 Research Center, where they eventually put her on the payroll but paid her very little. 38. Giuffre?s employment at The Mar?a?Lago spa began in fall 2000. Giuffre?s father, Sky Roberts was hired as a maintenance worker at lhe Mar?a?Lago Club in Palm Beach, Florida, beginning on April 11, 2000. Roberts worked ,there year?round for approximately 3 years. After working there for a period of time, Roberts became acquainted with the head of the spa area and recommended Giuffre for a job there. Mar?a?Lago closes every Mother?s Day and reopens on November 1. Most employees at Mar?a?Lago, including all employees of the spa area such as ?spa attendants,? are ?seasonal? and work only when the club is open, between November 1 and Mother?s Day. Giuffre was hired as a ?seasonal" spa attendant to work at the Mar-a? Lago Club in the fall of 2000 after she had turned 17. Giuffre has disputed the statement and noted that the Mar?a?Lago Club produced 177 pages of records in response to Maxwell?s subpoena which did not indiCate Giuffre?s actual dates of employment, nOr whether she was a full?time or seasonal employee. The only significant record produced was a single, 36 Case 18-2868, Document 287, 08/09/2019, 2628251, Page37 of 76 vague chart entry indicating that Giuffre was terminated in 2000 and that Mar?a?Lago was a summer job. 39. Giuffre represented herself as a masseuse for Epstein. While working at the Mar?a?Lago spa and reading a library book about massage, Giuffre met Maxwell. Giuffre thereafter told her father that she got a job working for Epstein as a masseuse. Giuffre?s father took her to Epstein?s house on one occasion around that time, and Epstein came outside and introduced himself to Roberts. Giuffre commenced employment as a traveling masseuse for Epstein. Giuffre was excited about her job as a masseuse, about traveling with him and about meeting famous people. Giuffre represented that she was employed as a masseuse beginning in January 2001. Giuffre never mentioned Maxwell to Austrich. Giuffre?s father never met Maxwell. Giuffre has denied the statement and has noted that in Florida, a person cannot work as a masseuse unless she is ?at least 18 years of age or has received a high school diploma or high school equivalency diploma,? Fla. Stat. 480.04l. She was a minor child, under the age of 18, when she was working at Mar? a?Lago as a spa attendant and was approached by Maxwell who told her she could make money as a masseuse, a profession in which 37 Case 18-2868, Document 287, 08/09/2019, 2628251, Page38 of 76 Giuffre had no experience. She states that her father drove her to Epstein?s house, the address of which was given to her by Maxwell, that she was led into the house and instructed by Maxwell on how to give a massage. She states that Epstein and Maxwell turned the massage into a sexual encounter, and offered her money and a better life to be compliant in the sexual demands of Maxwell and Epstein. She then began travelling with Maxwell and Epstein on private planes and servicing people sexually for money working not as a legitimate masseuse, but in a position of sexual servitude. Giuffre further noted that Epstein?s house manager, Alessi, described Maxwell?s methodical routine of how she prepared a list of places ahead of time, then drove to each place for the purpose of recruiting girls to. massage Epstein. Alessi stated that on multiple occasions he drove Maxwell to pre?planned places while she recruited girls for massage, and that he witnessed Giuffre at Epstein?s house on the very same day that he witnessed Maxwell reoruit Giuffre from Mar?a-Lago. Giuffre further noted Sjoberg?s testimony that she was similarly recruited. 40. In spring 200l, while living with Austrich, Giuffre lied to and cheated on him with Figueroa, her high school boyfriend. Giuffre and Austrich thereafter broke up, and 38 Case 18-2868, Document 287, 08/09/2019, 2628251, Page39 of 76 Figueroa moved into the Bent Oak apartment with Giuffre. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa punched Austrich in the face. Figueroa and Giuffre fled the scene before police arrived. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance. Giuffre has objected to the statement as irrelevant and unrelated to the allegations made in Giuffre?s complaint against Maxwell and the alleged information should be excluded by multiple rules of evidence, and has been contested by Giuffre. 41. Giuffre freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to ,them that she was Epstein?s ?sex slave.? In August 2001 at age 17, while living in the same apartment, Giuffre and Figueroa hosted a party with a number of guests. During the party, according to Giuffre, someone entered Giuffre?s room and stole $500 from her shirt pocket. Giuffre contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a ?sex slave.? A second time, in June 2002, Giuffre contacted 39 Case 18-2868, Document 287, 08/09/2019, 2628251, Page40 of 76 the police to report that her former landlord had left her belongings by the roadside and had lit her mattress on fire. Again, Giuffre met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a sex slave.? Giuffre has objected to the statement as misleading and irrelevant and further noted that she was fearful of Maxwell and Epstein, and, accordingly, she would not have reported her abusers and noted that she knew that Epstein had control over the Palm Beach Police. 42. From August 2001 until September 2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel unaccompanied by Giuffre. Flight logs maintained by Dave Rodgers (?Rodgers?), Epstein?s private pilot, evidence the substantial number of trips away from Florida that Epstein and Maxwell took, unaccompanied by Giuffre, between August 2001 and September 2002. Rodgers maintained a log of all flights on which Epstein and Maxwell traveled with him. Epstein additionally traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial flights. 40 Case 18-2868, Document 287, 08/09/2019, 2628251, Page4l of 76 For substantially all of thirteen months of the twenty?two month period from November 2000 to September 2002, Epstein was traveling outside of Florida unaccompanied by Giuffre. During this same period of time, Giuffre was employed at various jobs, enrolled in school, and living with her boyfriend. Giuffre has disputed this statement and noted the flight logs produced in this matter provide substantive evidence of Giuffre?s travel while in the control of Maxwell and Epstein, but are incomplete as Giuffre also was flown by Maxwell on commercial flights. The flight logs and pilot testimony clearly prove that Giuffre was flying domestic and internationally with Epstein at least 32 times between December 11, 2000 to July 28, 2001 and June 21, 2002 to August 21, 2002. Maxwell has acknowledged the flight logs are incomplete and that there were several pilots and co?pilots that flew Epstein and Maxwell Rodgers, Lawrence ?Larry? Visoski, Bill Hammond, Pete Rathgeb, Gary Roxburgh, and Bill Murphy) in multiple aircrafts and that only Rodgers produced flight records. Giuffre states that Maxwell has also acknowledged that many of the girls recruited by Maxwell routinely traveled on commercial flights for the purposes of providing massages to Epstein or guests at Epstein?s New York, New Mexico, or U.S. Virgin Island homes. 41 Case 18-2868, Document 287, 08/09/2019, 2628251, Page42 of 76 Giuffre has further noted that her passport application, travel records, and witness testimony demonstrate flight logs are incomplete, that she also flew commercially while she worked for Maxwell and Epstein. Her passport application, for example, listed travel plans to London, and subsequent flight logs listed Giuffre traveling to London with Maxwell, Epstein, and others. Giuffre has cited the evidence she contends establish her travel with Epstein and Maxwell, including massage training in Thailand. 43. Giuffre and Figueroa shared a ?93 white Pontiac in 2001 and 2002. Giuffre freely traveled around the Palm Beach area in that vehicle. In August 2002, Giuffre acquired a Dodge Dakota pickup truck from her father. Figueroa used that vehicle in a series of crimes before and after Giuffre left for Thailand. Giuffre has denied the statement and has noted that she purchased a car from the $10,000 payment she received from Epstein after she was forced to have sex with PrinCe Andrew in London at Maxwell?s home. 42 Case 18-2868, Document 287, 08/09/2019, 2628251, Page43 of 76 44. Giuffre held a number of jobs in 2001 and 2002. During 2001 and 2002, Giuffre was gainfully employed at several jobs. She worked as a waitress at Mannino?s Restaurant, at TGIFriday?s restaurant of Royal Palm and at Roadhouse Grill. She also was employed at Courtyard Animal Hospital (?Marc Pinkwasser Giuffre has denied the statement and noted that in 2001 and 2002 she attempted to go back to school to earn her GED, and tried unsuccessfully to hold down waitressing jobs. She earned $212.00 as a waitress working ?briefly? at Mannino?s Restaurant and, in 2002, earned $403.64 working at the TGIFriday?s restaurant of Royal Palm Beach?) for a ?short time period.? She earned about $1,247.90 at Roadhouse Grill until about March 2002, and at the Courtyard Animal Hospital '(?Marc Pinkwasser she received payroll checks for weeks ending April 22, 2002 to June 4, 2002, earning a total of $1,561.75. Not long after she lost her job at the Courtyard Animal Hospital, she was traveling with Maxwell to the Bahamas, Santa Fe, New Mexico, and New York. 45. Giuffre traveled to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove her to the 43 Case 18-2868, Document 287, 08/09/2019, 2628251, Page44 of 76 airport. While there, she initially contacted Figueroa frequently, incurring a phone bill of $4,000. She then met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until two days before Figueroa?s deposition in this matter in May 2016. Giuffre admitted traveling to Thailand to receive massage training in September 2002 but noted that she was given an assignment from Maxwell and Epstein that she had to recruit another underage girl from Thailand, and bring that young girl back to Epstein. Giuffre stated that she was expected to return to Epstein and Maxwell upon completion of her massage training and assignment, and that instead she escaped to Australia where she remained in hiding from Maxwell and Epstein for several years. 46. Detective Joseph Recarey (?Recarey?) investigated Epstein and failed to uncover any evidence that Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. Recarey served as the lead detective from the Palm Beach Police Department charged with investigating Epstein. That investigation commenced in 44 Case 18-2868, Document 287, 08/09/2019, 2628251, Page45 of 76 2005. Recarey worked only on the Epstein case for an entire year. He reviewed previous officers? reports and interviews, conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance footage of the Epstein home, participated in and had knowledge of the search warrant executed on the Epstein home, and testified regarding the case before the Florida state grand jury against Epstein. Recarey?s investigation revealed that not one of the alleged Epstein victims ever mentioned Maxwell?s name and she was never considered a suspect by the Government. None of Epstein?s alleged victims said they had seen Maxwell at Epstein?s house, nor said they had been ?recruited by her,? nor paid any money by her, nor told what to wear or how to act by her. Indeed, none of Epstein?s alleged victims ever reported to the Government they had met or spoken to Maxwell. Maxwell was not seen coming or going from the house during the law enforcement surveillance of Epstein?s home. The arrest warrant did not mention Maxwell and her name was never mentioned before the grand jury. No property belonging to Maxwell, including sex toys? or ?child pornography,? was seized from Epstein?s home during execution of the search warrant. Recarey, when asked to describe ?everything that you believe you know about Ghislaine 45 Case 18-2868, Document 287, 08/09/2019, 2628251, Page46 of 76 Maxwell?s sexual trafficking conduct,? replied, don?t.? He confirmed he has no knowledge about Maxwell sexually trafficking anybody. Recarey also has no knowledge of Giuffre?s conduct that is subject of this lawsuit. Giuffre has denied the statement and noted that Recarey wanted to speak to Maxwell, but she did not return his calls and he concluded that Maxwell?s role was to procure girls for Epstein. Giuffre further noted that in the execution of the search warrant, stationary was found in the home bearing Maxwell?s name, and notes were written by house staff to Maxwell and message pads uncovered in trash pulls revealing numerous calls left at the house for Maxwell, indicating she was staying in the house during the days when Epstein was engaging in illegal sex acts with minors. Giuffre further noted that a walk through video taken during the execution of the search warrant revealed photos of topless females at the home, including a photograph of Maxwell naked hanging in the home. Alfredo Rodriguez (?Rodriguez?), the house butler from 2004 through 2005, a time period that included daily sexual abuse of underage females, testified that Maxwell kept a list of the local girls who were giving massages at her desk, and that Maxwell kept nude photos of girls on her computer. Giuffre states that Recarey 46 Case 18-28-68, Document 287, 08/09/2019, 2628251, Page47 of 76 testified that when the search warrant was executed, the house had been sanitized and the computers removed from the home. Giuffre states that the co?conspirator who maintained direct contact with the many underage victims was Kellen, whose sole responsibility was to schedule underage girls to visit Epstein for sex and reported directly to Maxwell. Figueroa testified that Maxwell personally requested that he find and bring girls to Epstein for sex once Giuffre had escaped, and that when he brought the girls Maxwell interacted with them, that Maxwell was ?the boss? and that she knew everything that was going on. 47. No nude photograph of Giuffre was displayed in ?Epstein?s home. Epstein?s housekeeper, Alessi, ?never saw any photographs of Virginia Roberts [Giuffre] in Epstein?s house.? Recarey entered Epstein?s home in 2002 to install security cameras to catch a thief and did not observe any ?child pornography? within the home, including on Epstein?s desk in his office. Giuffre has denied this statement and noted that Maxwell had pornography on her computer, that there was a 47 Case 18-2868, Document 287, 08/09/2019, 2628251, Page48 of 76 collage of nude photos in Epstein?s closet, that the collage was taken into evidence by Recarey, who testified to that fact in his deposition, that Rizzo, a visitor to the home on numerous occasions, was reprimanded by Maxwell for looking at the nude photos, and that the search warrant revealed photographs of nudity displayed, including a photograph of Maxwell herself in the nude. Sjorberg testified that Maxwell bought her a camera for the specific purpose of her taking nude photos of herself and Giuffre has testified that there was a nude photograph of lher at the house. 48. Giuffre drafted a ?journal? describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents in her possession. Giuffre also kept a ?dream journal? regarding her thoughts and memories that she possessed in January 2016. To date, Giuffre cannot locate the ?dream journal.? 49. Giuffre publicly peddled her story beginning in 2011. Giuffre granted journalist Churcher extensive interviews 48 Case 18-2868, Document 287, 08/09/2019, 2628251, Page49 of 76 that resulted in seven widely distributed articles from March. 2011 through January 2015. Churcher regularly communicated With Giuffre and her ?attorneys or other agents? from ?early 2011? to ?the present day.? Giuffre received approximately $160,000 for her stories and pictures that were published bymany news organizations. Giuffre has denied this statement in part and admitted it in part, noting that in 2011, Giuffre was still in hiding from Epstein and Maxwell in Australia and not looking to sell anything or even speak with anyone about what had happened to her. Churcher located Giuffre and impressed the importance of Giuffre standing up to those who had harmed her and speaking with federal authorities. Giuffre did so in 2011, bringing the abuse of Maxwell and Epstein to public light to prevent their continued abuse of others. Giuffre agreed to be interviewed by Churcher and was compensated for sharing her story, which came at the heavy price of being publicly scrutinized. 50. Giuffre drafted a l44?page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, Giuffre drafted a book manuscript which purported to 49 Case 18-2868, Document 287, 08/09/2019, 2628251, Page50 of 76 document Giuffre?s experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. Giuffre communicated with literary agents, ghost writers, and potential independent publishers in an effort to get her book published. She generated marketing materials and circulated those along with book chapters to numerous individuals associated with publishing and the media. Giuffre has denied the statement in part and admitted it in part, stating that she received a Victim Notification Letter from the United States Attorney?s office for the Southern District of Florida regarding her sexual victimization by Epstein, that in 2011 she sought counseling from a for the trauma she endured, and that also that year Churcher sought her out and interviewed her. Giuffre was interviewed by the FBI in-ZOll. Giuffre has noted that she began to draft a fictionalized account of what happened to her as an act of empowerment and a way of reframing and taking control over the narrative of her past abuse that haunts her and, while she explored trying to publish her story to empower other individuals who were subject to abuse, she ultimately decided not to publish it. 50 Case 18-2868, Document 287, 08/09/2019, 2628251, Page51 of 76 51. The CVRA joinder motion filed by Giuffre generated a media maelstrom and spawned highly publicized litigation between Giuffre?s lawyers Bradley Edwards (?Edwards?) and Paul Cassell (?Cassell?) and Dershowitz. After Giuffre publicly accused Dershowitz of sexual misconduct, Dershowitz vigorously defended himself in the media. He called Giuffre a liar and accused her lawyers of unethical conduct. In response, Edwards and Cassell sued Dershowitz, who counterclaimed. This litigation, in turn, cauSed additional media attention by national and international media organization. Giuffre has denied the statement as set forth in Statement 7. 52. Giuffre formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 20l4, Giuffre, with the assistance of the same counsel, formed a non?profit organization, Victims Refuse Silence. According to Giuffre, the purpose of the organization is to promote Giuffre?s professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual 51 .. Case 18-2868, Document 287, 08/09/2019, 2628251, Page52 of 76 abuse. Giuffre attempts to promote Victims Refuse Silence at every opportunity. For example, Giuffre participated in an interview in New York with ABC to promote the charity and to get her mission out to the public. Giuffre has denied that she formed the non?profit Victims Refuse Silence to ?speak out on a public controversy,? and noted she sought to help survivors of sexual abuse and sexual trafficking and in order to provide assistance to victims, she attempted to talk about the non?profit?s mission when she had the opportunity to do so. The Applicable Standard Summary judgment is appropriate only where ?there is no genuine issue as to any material fact and . . . the moving party is entitled to a judgment as a matter of law.? Fed. R. Civ. P. 56(c). ?[T]he substantive law will identify which facts are material.? Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). A dispute is ?genuine? if ?the evidence is such that a reasonable jury could return a verdict for the nonmoving party.? 52 Case 18-2868, Document 287, 08/09/2019, 2628251, Page53 of 76 Id. The relevant inquiry on application for summary judgment is ?whether the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one?Sided that one party must prevail as a matter of law.? Id. at 251?52. A court is not charged with weighing the evidence and determining its truth, but with determining whether there is a genuine issue for trial. Westinghouse Elec. Corp. v. N.Y. City Transit Auth., 735 F. Supp. 1205, 1212 (S.D.N.Y. 1990) (quoting Anderson, 477 U.S. at 249). ?[T]he mere existence of some alleged factual dispute between the parties will not defeat an otherwise properly supported motion for summary judgment; the requirement is that there be no genuine issue of material fact.? Anderson, 477 U.S. at 247?48 (emphasis in original). While the moving party bears the initial burden of showing that no genuine issue of material fact exists, Atl. Ins. Co. V. CSX Lines, L.L.C., 432 F.3d 428, 433 (2d Cir. 2005), in cases where the non?moving party bears the burden of persuasion at trial, ?the burden on the moving party may be discharged by ?showing??that is, pointing out to the district court?that there is an absence of evidence to support the nonmoving party?s case.? Celotex Corp. v. Catrett, 477 U.S. 317, 325 (1986). ?It is ordinarily sufficient for the movant to point 53 Case 18-2868, Document 287, 08/09/2019, 2628251, Page54 of 76 to a lack of evidence . . . on an essential element of the non? movant?s claim . . . . [T]he nonmoving party must [then] come forward with admissible evidence sufficient to raise a genuine -issue of fact for trial . . . Jaramillo v. weyerhaeuser Co., 536 F.3d 140, 145 (2d Cir. 2008) (internal citations omitted); see also Goenaga V. March of Dimes Birth Defects Found., 51 F.3d 14, 18 (2d Cir. 1995) (?Once the moving party has made a properly supported showing sufficient to suggest the absence of any genuine issue as to a material fact, the nonmoving party must come forward with evidence that would be sufficient to support a jury verdict in his favor?). IV. The Motion for Summary Judgment on Republication Grounds is Denied Maxwell has moved for summary judgment dismissing Giuffre?s complaint on the grounds that Maxwell is not liable for the republication of her Press Release by the media. Because as a matter of law the issuer of a press release is responsible for its publication, the motion is denied. In New York, liability for a republication ?must be based on real authority to influence the final product.? Davis 54 Case 18-2868, Document 287, 08/09/2019, 2628251, Page55 of 76 V. Costa?Gavras, 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984); see also Hoffman V. Landers, 146 744, 747 (N.Y. App. Div. 2d Dep?t 1989) (?One who makes a defamatory statement is not responsible for its recommunication without his authority or request by another over whom he has no Where a defendant ?had no actual part in composing or publishing,? he cannot be held liable ?without disregarding the settled rule of law that no man is bound for the tortious act of another over whom he has not a master?s power of control.? Davis, 580 F. Supp. at 1096 (internal quotation marks and citation omitted). The New York Court of Appeals summarized New York?s republication liability standard in Geraci V. Probst, 938 917 (N.Y. 2010), stating that one who . . . prints and publishes a libel[] is not responsible for its voluntary and unjustifiable repetition, without his authority or request, by others over whom he has no control and who thereby make themselves liable to the person injured, and that such repetition cannot be considered in law a necessary, natural and probable consequence of the original slander or libel. 938 at 921 (internal quotation marks and citation omitted). Thus, ?conclusive evidence of lack of actual authority [is] sufficiently dispositive that the [court] ?ha[s] no option but to dismiss the case . . . Davis, 580 F. Supp. at 1096 55 Case 18-2868, Document 287, 08/09/2019, 2628251, Page56 of 76 (quoting Rinaldi v. Viking Penguin, Inc., 420 377, 382 (N.Y. 1981)). However, New York law assigns liability to individuals for the media?s publication of press releases. New York appellate courts have held that an individual is liable for the media publishing that individual?s defamatory press release. See Levy v. Smith, 132 961, 962?63 (N.Y. App. Div. 2d Dep?t 2015) (?Generally, [o]ne who makes a defamatory statement is not responsible for its recommunication without his authority or request by another over whom he has no control . . . . Here, however, . . . the appellant intended and authorized the republication of the allegedly defamatory content of the press releases in the news see also OF Twas 576 (1977) (?The publication of a libel or slander is a legal cause of any special harm resulting from its repetition by a third person if . . . the repetition was authorized or intended by the original defamer, or . . . the repetition was reasonably to be expected.?) The facts as set forth above establish that Maxwell approved the Press Release. The Press Release was sent to between six and 30 media representatives by Gow as an employee 56 Case 18-2868, Document 287, 08/09/2019, 2628251, Page57 of 76 of Acuity Reputation, the public relations firm hired by Maxwell. The initial sentence of the Press Release ?Please find attached a quotable statement on behalf of Maxwell? communicates Maxwell's authorization for the media recipients of the Press Release to publish it. See Nat?l Puerto Rican Day Parade, Inc. V. Casa Pubs., Inc., 79 592, 595 (N.Y. App. Div. Dep?t 2010) (affirming the refusal to dismiss defamation counts against a defendant who ?submitted an open letter that was published in newspaper, and that [the defendant] paid to have the open letter published,? finding that the defendant ?authorized [the newspaper] to recommunicate his Maxwell has cited Geraci v. Probst in support of her position, but Geraci is distinguishable from the instant action. In Geraci, the defendant sent a letter to the Board of Fire Commissioners, and, more than three years later, a newspaper published the letter. The court held that the defendant was not liable for that belated publication, ?made years later without his knowledge or participation.? 938 at 919. Here, unlike in Geraci, the Press Release was not published ?without [her] authority or request,? but rather with Maxwell?s authority and 57 Case 18-2868, Document 287, 08/09/2019, 2628251, Page58 of 76 by her express request. Gow?s testimony establishes Maxwell?s authority and control over the Press Release: Q. When you sent that email were you acting pursuant to Ms. Maxwell?s retention of your services? A. Yes, I was Q. The subject line does have which to me indicates it?s a forward. Do you know where the rest of this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, ?Okay, Ghislaine, I?ll go with this.? ?It is my understanding that this is the agreed statement because the subject of the second one is ?Urgent, this is the statement? so I take that as an instruction to send it out, as a positive command: ?This is the statement.? Maxwell also cites Davis v. Costa?Gavras, involving a libel claim against an author who wrote a book about a military coup in Chile. 580 F. Supp. at 1085. Years after the author published the book, a third?party publishing house republished the book in paperback form and a third?party filmmaker released a movie based on the book. The book author did not actually participate in the republications, though he was aware of the 58 Case 18-2868, Document 287, 08/09/2019, 2628251, Page59 of 76 projects. The court held that the author of the book could not be held liable for the republications, explaining that a ?party who is ?innocent of all complicity? in the publication of a libel cannot be held accountable.? 580 F. Supp. at 1094 (internal citations omitted). The court further noted that ?active participation in implementing the republication resurrects the liability.? Id. Likewise, in Karaduman v. Newsday, Inc., 416 557 (1980), also cited by Maxwell, the court held that reporters of a series of articles on narcotics trade ?cannot be held personally liable for injuries arising from [the] subsequent republication in book form absent a showing that they approved or participated in some other manner in the activities of the third?party republisher.? Id. at 559? 560. However, the court explicitly noted that this result was required because ?the record [wa]s barren of any concrete evidence of the reporters? involvement in the republication of the newspaper series.? Id. at 540. Here, there is evidence in the record that Maxwell' ?actively participated? in influencing the media to publish the Press Release, Davis, 580 F. Supp. at 1094, and ?approved? of and sought the publication of the press release, Karaduman, 416 at 560. Maxwell retained a public relations media 59 Case 18-2868, Document 287, 08/09/2019, 2628251, Page60 of 76 specialist. The Press Release was sent by Maxwell's express request. Gow?s testimony about the process leading up to the dissemination of the Press Release indicates that Maxwell did, indeed, ?authorize or intend? for the media recipients to publish the statement. Because there are sufficient facts to demonstrate Maxwell?s authority and control over the publication of the Press Release, Maxwell?s liability for the Press Release?s publication survives the motion for summary judgment. Maxwell has additionally asserted that subjecting her to liability for republication is ?particularly unfair? because excerpts of the Press Release, rather than the whole statement, were published. Def.?s Reply at 9. Maxwell cites to Rand V. New York Times Co., 75 4l7 (N.Y. App. Div. Dep?t 1980), in which a newspaper paraphrased the defendant?s opinion, essentially ?excis[ing] the opinion from the context in which it was given.? Id. at 424. No similar alteration, sanitization, hyperbolizing, or paraphrasing of Maxwell?s statements has been established here. Nor does the record establish that any statements of Maxwell?s were taken out of context; rather, they were directly guoted, accurately and unchanged. The publication of Maxwell?s statement that Giuffre?s claims are ?obvious lies? 6O Case 18-2868, Document 287, 08/09/2019, 2628251, Page61 of 76 does not distort or misrepresent the message Maxwell intended to convey to the public with the Press Release. Because the purpose-of the issuance of the Press Release was publication, Maxwell is liable for its content and the motion for summary judgment on the grounds of non?liability for republication is denied. The Motion for Summary Judgment to Dismiss the Defamation Claim on the Ground of Substantial Truth is Denied Maxwell has asserted that the Press Release is substantially true and that the defamation claim should therefore be dismissed. See Def.?s Br. at 39. Whether or not Giuffre lied about Maxwell?s involvement in the events that Giuffre has alleged took place is the intensely contested factual issue that is the foundation of this action. Accordingly, summary judgment is not appropriate. See Mitre Sports Intern. Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 255 (S.D.N.Y. 2014) (denying summary judgment because it would require the Court to decide disputed facts to determine whether the statement at issue was substantially true); Da Silva v. Time Inc., 908 F. Supp. 184, 187 (S.D.N.Y. 1995) (denying motion for summary judgment because there was a genuine issue of 61 Case 18-2868, Document 287, 08/09/2019, 2628251, Page62 of 76 material fact as to whether defamatory photo and caption were true). Under New York law, ?truth is an absolute, unqualified defense to a civil defamation action? and ??substantial truth? suffices to defeat a charge of libel.? Jewell v. NYP Holdings, Inc., 23 F. Supp. 2d 348, 366 (S.D.N.Y. 1998) (internal quotation marks and citations omitted). A statement is substantially true if the statement would not ?have a different effect on the mind of the reader from that which the pleaded truth would have produced.? Id. (quoting Fleckenstein V. Friedman, 193 N.E. 537, 538 (N.Y. 1934)). Thus, ?it is not necessary to demonstrate complete accuracy to defeat a charge of libel. It is only necessary that the gist or substance of the challenged statements be true.? Printers II, Inc. v. Professionals Publishing, Inc., 784 F.2d 141, 146 (2d Cir. 1986); see also KOrkala v. W.W. Norton Co., 618 F.Supp. 152, 155 (S.D.N.Y. 1985) (?Slight inaccuracies of expression are immaterial provided that the defamatory charge is true in substance.?) (internal quotation marks and citation omitted); Sharon V. Time, Inc., 609 F.Supp. 1291, 1294 (S.D.N.Y. 1984) (?Defendant is permitted to prove the substantial truth of this statement by establishing any other proposition that has the 62 Case 18-2868, Document 287, 08/09/2019, 2628251, Page63 of 76 same ?gist? or ?sting? as the original libel, that is, the same effect on the mind of the The Honorable Loretta A. Preska has noted that cases addressing whether a statement is substantially true ?fall along a broad spectrum.? Jewell, 23 F. Supp. at 367. There are cases in which a statement is non?actionable because it is completely true. See, Carter, 233 473, 474 (N.Y. App. Div. 2d Dep?t 1996) (claim that defendant committed libel by informing -the authorities that plaintiff was endorsing checks made payable to the defendant and depositing them in plaintiff?s account held non?actionable where plaintiff had in fact endorsed checks made payable to the defendant). There are cases where ?one struggles to identify any area of ambiguity as to truth.? Jewell, 23 F. Supp. at 368; see, Miller v. JOurnal?News, 211 626, 627 (N.Y. App. Div. 2d Dep?t 1995) (statement that plaintiff was ?suspended? substantially true where plaintiff was placed on ?administrative leave?). There are cases where the line between the statement and the admitted truth is more tenuous, but the overall ?gist? cannot be said to be substantially different. See, Guccione v. Hustler Magazine, Inc., 800 F.2d 298, 302?03 (2d Cir. 1986) (holding that statement which implied that plaintiff was then currently an adulterer was substantially true 63 Case 18-2868, Document 287, 08/09/2019, 2628251, Page64 of 76 where plaintiff had ceased being an adulterer but had ?unabashedly committed adultery? for thirteen of seventeen years). Finally, there are ?those cases in which a defendant simply asks too much in asserting that a statement is subStantially true because the difference between the two is plainly substantial.? Jewell, 23 F. Supp. at 368. For example, the court in Da Silva, 908 F. Supp. at 186?87, held that a photograph of plaintiff which identified her as a prostitute was not substantially true where the plaintiff had been a prostitute for some six years but was not at the time of publication. After reviewing this spectrum of cases, the facts upon which Maxwell bases her argument are insufficient to allow this Court to find substantial truth as a matter of law. A material dispute of fact exists as to the ?admitted truth? or the ?reality? in this case. Maxwell has cited to various facts to counter Giuffre?s claims, such as Giuffre?s high school enrollment, short?term jobs, and lack of record on private flight logs during some of the relevant time period, as evidence that Maxwell and Epstein did not abuse Giuffre. The details and significance of the facts offered are highly contested, and therefore cannot establish the ?substantial truth? of the Press Release. ?[R]easonable jurors could conclude that the statements 64 Case 18-2868, Document 287, 08/09/2019, 2628251, Page65 of 76 are not substantially true.? Boehner V. Heise, 734 F. Supp. 2d 389, 399 (S.D.N.Y. 2010). The motion for summary judgment to dismiss the defamation on the ground of substantial truth is denied as not having been established by undisputed material facts. VI. The Defamation Claim is Not Barred by New York Law Maxwell has moved to dismiss the complaint on the ground that the Press Release is opinion and protected by the pre?litigation privilege under New York law. Because New York law does not support Maxwell?s position, the motion for summary judgment based on the characterization of the Press Release as opinion and as protected by a pre?litigation privilege is denied. 1. The Press Release is Net Opinion. As previously held, Maxwell?s statement that Giuffre?s claims of sexual assault are lies is not an expression of opinion: 65 Case 18-2868, Document 287, 08/09/2019, 2628251, Page66 of 76 First, statements that Giuffre?s claims ?against [Maxwell] are untrue,? have been ?shown to be untrue,? and are ?obvious lies? have a specific and readily understood factual meaning: that Giuffre is not telling the truth about her history of sexual abuse and [Maxwell]?s role, and that some verifiable investigation has occurred and come to a definitive conclusion proving that fact. Second, these statements (as they themselves allege), are capable of being proven true or false, and therefore constitute actionable fact and not opinion. Third, in their full context, while [Maxwell]?s statements have the effect of generally denying Giuffre?s story, they also clearly constitute fact to the reader. Giuffre v. Maxwell, 165 F. Supp. 3d 147, 152 (S.D.N.Y. 2016). This Court further concluded that [Giuffre] cannot be making claims shown to be untrue that are obvious lies without being a liar. Furthermore, to suggest an individual is not telling the truth about her history of having been sexually assaulted as a minor constitutes more than a general denial, it alleges something deeply disturbing about the character of an [individual willing to be publicly dishonest about such a reprehensible crime. [Maxwell]?s statements clearly imply that the denials are based on facts separate and contradictory to those that [Giuffre] has alleged. Id. Maxwell argues that the ?context? of the entire statement ?tested against the understanding of the average reader? should be that of a press release as a whole being read only by journalists. Def.?s Br. at 22 (quoting Aronson v. Wiersma, 483 1138, 1139 (1985)). However, the ultimate 66 Case 18-2868, Document 287, 08/09/2019, 2628251, Page67 of 76 audience for a press release is the public. The motion to dismiss opinion clearly addressed this issue: Sexual assault of a minor is a clear?cut issue; either transgression occurred or it did not. Either Maxwell was involved or she was not. The issue is not a matter of opinion, and there cannot be differing understandings of the same facts that justify diametrically opposed opinion as to whether Maxwell was involved in Giuffre?s abuse as Giuffre has claimed. Either Giuffre is telling the truth about her story and Maxwell?s involvement, or Maxwell is telling the truth and she was not involved in the trafficking and ultimate abuse of Giuffre. Giuffre, 165 F. Supp. at 152. Maxwell has urged that these conclusions at the motion ~to dismiss stage should be revisited and revised when considering the summary judgment motion since the standard for deciding a Rule 12(b)(6) motion is different from the standard for deciding a Rule 56 motion. In deciding a 12(b)(6) motion, the court must accept as true the factual allegations and draw all inferences in the plaintiff?s favor; a plaintiff need only state a claim that is ?plausible on its face.? Id. at 149 (internal quotation marks and citation omitted). In contrast, for a Rule 56 motion, the plaintiff defending the motion may not ?rest on [the] allegations? in her complaint. Anderson, 477 U.S. at 249. 67 Case 18-2868, Document 287, 08/09/2019, 2628251, Page68 of 76 In deciding its motion to dismiss opinion, the Court relied on Davis v. Boeheim, 22 999 (2014), and held that the three allegedly defamatory statements in the Press Release have a specific and readily understood factual meaning, are capable of being proven true or false, and ?clearly constitute fact to the reader.? Giuffre, 165 F. Supp. at 152. The Court determined that ?[t]he dispositive inquiry? for purposes of deciding whether an allegedly defamatory statement is fact or nonactionable opinion is whether ?a reasonable reader could have concluded that the statements were conveying facts about the plaintiff.? Id. at 151 (internal quotation marks and citation omitted). To answer that inquiry, three factors enumerated in Davis were applied. See id. These three factors are the same as the four factors in Immuno AG v. Meor?Jankowski, 567 1270 (N.Y. 1991); the difference is that the Davis court collapsed the Immuno third and fourth factors into one. See Davis, 22 at 1005. ?[T]he critical aspect of the inquiry, as articulated in the third factor set forth above, is to view the statements in context.? Jewell, 23 F. Supp. 2d at 377. This contextual analysis ?proceeds on two levels, the ?broader social setting? of the statements, as well as their ?immediate context.?? Id. (citing Immuno, 567 at 1280). 68 Case 18-2868, Document 287, 08/09/2019, 2628251, Page69 of 76 Maxwell acknowledges that the Court properly applied Davis at the motion to dismiss stage, but argues that the third factor, especially, benefits from the evidence presented in the motion for summary judgment. See Def.?s Br. at 32. In other words, Maxwell argues that ?the Court did not have the ?full context?? of the Press Release or the ?broader social context and surrounding circumstances of the statement." Id. At the motion to dismiss stage, the text of the Press Release had not yet been produced, nor had there been production of emails or deposition testimony regarding the Press Release. The developed record necessitates the same conclusion as at the motion to dismiss stage. The context and surrounding circumstances remain the same. The publication was intended by Maxwell to reach the average reader, not simply the reporters, Barden?s intent, a factual issue in contest, notwithstanding. The issue of truth or falsity is a factual determination, not a matter of opinion. See Giuffre, 165 F. Supp. 3d at 152 that Giuffre?s claims ?against [Maxwell] are untrue,? have been ?shown to be untrue,? and are ?obvious lies? have a specific and readily understood factual 69 I Case 18-2868, Document 287, 08/09/2019, 2628251, Page70 of 76 2. The Pre?Litigation Privilege is Inapplicable. Maxwell has contended that the pre?litigation privilege as enunciated in Front, Inc. V. Khalil, 28 15, 16 (N.Y. 2015), applies. See Def.?s Br. at 33. privileged communication is one which, but for the occasion on which it is uttered, would be defamatory and actionable.? Park Knoll Assocs. v. Schmidt, 451 182, 184 (N.Y. 1983). is well?settled that statements made in the course of litigation are entitled to absolute privilege.? Front, 28 at 18. The privilege that protects statements made in the course of litigation ?can extend to preliminary or investigative stages of the process, particularly where compelling public interests are at stake.? Rosenberg v. Mthife, Inc., 866 439, 443 (N.Y. 2007). In Front, the New York Court of Appeals ruled that the privilege for ?statements made by attorneys prior to the commencement of litigation? is qualified rather than absolute. Id. at 16. Specifically, the Court held that an attorney?s statements made before litigation has commenced are privileged if (1) the attorney has ?a good faith basis to anticipate litigation? and (2) the statements are ?pertinent to that anticipated litigation.? Id. at 20. 7O Case 18-2868, Document 287, 08/09/2019, 2628251, Page7l of 76 The anticipated litigation, according to the Press Release, was ?redress at the repetition of such old defamatory claims.? See Press Release. According to Barden, Maxwell?s lawyer, he participated in the preparation of the Press Release, the purpose of the Press Release was to dissuade the media from publishing Giuffre?s allegations, and the implication of the Press Release was that any redress sought by Maxwell would be against the media. Giuffre has disputed Barden?s claim that the Press Release was his own statement. Certain of the cases cited by Maxwell in support of the privilege can be distinguished, according to Giuffre, in that they involve communications to or from parties to the ultimate litigation. See, Kirk v. Heppt, 532 F. Supp. 2d 586, 593 (S.D.N.Y. 2008) (the communication at issue was made by an attorney?s client to the attorney?s malpractice carrier concerning the client?s justiciable controversy against the attorney over which the clients actually sued); Black v. Green Harbour Homeowners? Ass?n, Inc., l9 962, 963 (N.Y. App. Div. 3d Dep?t 2005) (privilege applied to a letter sent by a home owner?s association board of directors to the association?s members informing them of the status of litigation to which the 7l Case 18-2868, Document 287, 08/09/2019, 2628251, Page72 of 76 association was a party). Giuffre contends that ?there was no statement made by anyone before the commencement of litigation because litigation never commenced.? See Pl.?s Opp?n at 42. Here, the communication at issue was sent to members of the media, and no litigation took place between Maxwell and the media recipients of the Press Release. However, the pre?litigation privilege is not limited to statements between parties and their lawyers. ?While the communications at iSsue in Front were among lawyers and potential parties, the New York Court of Appeals did not explicitly require the recipient of the challenged statements to be a lawyer or potential party.? Feist v. Paxfire, Inc., No. 11 CIV. 5436 (LGS), 2017 WL 177652, at *5 (S.D.N.Y. Jan. 17, 2017); see Front, 28 at l6?l7. The Second Circuit ?summarily rejected this interpretation when it applied Front to an attorney?s communicatiOns to the press.? See Tacopina v. ?O?Keeffe, 645 F. App?x 7, 8 (2d Cir. 2016) (?Even crediting [the plaintiff]?s allegation that [the attorney] shared the affidavit with the Daily News before filing it in court, Tacopina has still not sustained his burden of showing that the statements were not pertinent to a good faith anticipated 72 Case 18-2868, Document 287, 08/09/2019, 2628251, Page73 of 76 Though a statement made to a non?party may be privileged, the pre?litigation privilege does not apply here because the Press Release cannot be considered a ?statement[] made by [an] attorney.? Front, 28 at 16. Whether Maxwell's attorney, Barden, had a hand in drafting the Press Release, and the extent to which he may have been involved, is a disputed issue of fact. The record evidence establishes that, regardless, the Press Release is properly attributable to Maxwell. Maxwell retained a public relations firm and sent her representative there, Gow, a forwarded email with the statements\ that were to be used in the Press Release. Maxwell instructed Gow to send it, as he testified in his deposition. While Maxwell herself did not disseminate the email to the media recipients, neither did Barden. The statement was sent out by Gow. Additionally, the alleged defamatory statements in the Press Release were attributed to Maxwell, and not to her attorney or his agents. The email stated that the Press Release was a ?statement on behalf of? Maxwell and notified the media recipients that further communication will be provided by her [Maxwell] on this matter.? There is no evidence in the email 73 Case 18-2868, Document 287, 08/09/2019, 2628251, Page74 of 76 that the Press Release was anything near an attorney?s, statement; Barden was not even copied on the email. The pre?litigation privilege is intended to protect attorneys from defamations claims ?so that those discharging a public function may speak freely to zealously represent their clients without fear of reprisal or financial hazard.? Id. at 18. Where the statement cannot be attributed to an attorney, there is no justification for protecting it by privilege. In addition, as this Court concluded in denying Maxwell?s motion to dismiss, ?[t]here is no qualified privilege under New York law when such statements are spoken with malice, knowledge of their falsity, or reckless disregard for their truth.? Giuffre, 165 F. Supp. 3d at 155 (internal quotation marks and citation omitted). It is Giuffre?s contention that Maxwell knew the statements were false because she engaged in and facilitated the sexual abuse of Giuffre. Therefore, according to Giuffre, they were not made in good faith anticipation of litigation, and instead were made for the rinappropriate purpose of ?harass]ment],? and See Front, 28 at 19 (2015). According to Giuffre, there is ample record evidence that Maxwell acted 74 Case 18-2868, Document 287, 08/09/2019, 2628251, Page75 of 76 with malice in issuing the Press Release, thereby making the pre?litigation privilege inapplicable. Because of the existence of triable issues of material fact rather than opinion and because the pre?litigation privilege is inapplicable, the motion for summary judgment is denied. 75 Case 18-2868, Document 287, 08/09/2019, 2628251, Page76 of 76 VII. Conclusion For the reasons set forth above, the motion for} summary judgment is denied. The parties are directed to jointly file a proposed redacted version of this Opinion consistent with the Protective Order or notify the Court that none are necessary within one week of the date of receipt of this Opinion. It is so ordered. New York, NY March24p, 2017 Lots?(7? OBERT w. SWEET U.S.D.J. 76