Epstein Exhibits

Case 18-2868, Document 278, 08/09/2019, 2628230, Page1 of 648 EXHIBIT A Case 18-2868, Document 278, 08/09/2019, 2628230, Page2 of 648 6114:2016 Prince Andrew and girl, 17, who sex o?er?er friend flew to Britain to meet him Daily Mail Ontine Daily ail .com Home I U.K. Sports Showbiz [Australia [Femail [Health [Science [Money [Video [Travel [Columnists tr am .22: ,t Latest wisestii?tr?e Prince Andrew and the 17-year-old girl his 1 sex offender friend flew to Britain to 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 3?lst 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? Wes Patrick Swayze a victim of domestic abuse? Wife denies claims she beatth- Dirty Dancing star throughout their 34?year marriage - and even when he was dying Advertisement First meeting: Prince around 17-year-old Virginia, centre On one of those occasions Virginia Roberts was subsequentty 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 Matt 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?ciat 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 At 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 61142016 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 teast 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 triat. 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?. Case p, . 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 steeiy, 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 small 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 Paim 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 tastieamasmsanaagamf 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!? Blonde bombshell begs doctors to make her 1,000cc implants even after they insist her enhanced breasts are 'perfect' On Botched 'lt's my iburth 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 a 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 QC. 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, Page5 of 648 6?14?2016 Case 9 Mexico and Little Saint James, a private 70_ acre atoll in the US Virgin islands. 't?d cry because there was nothing icould do to heip': Bella 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 recycfes Super Bowl Reformation look She is stilt a lrailbiazer Jenna Bush Hager shares somber message about motherhood as she reveats 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 reveals she is paralysed from the waist down after throwing herself 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 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 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 totd to start massaging Epstein, under the Instructions of the woman who had and Meiania at The Polo 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 promismg 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 bills 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 Florida's age of consent, which is 18. 3:22:22: 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 TrOubled teenager: Virginia on the billionaire's Zorro ranch in New Mali? Case 121590WWRW81 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 estabiishment. 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 wouid always receive the money immediateiy. 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 rote. ?Basicaliy, i was training to be a prostitute for him and his friends who shared his interest in young Epstein had trained me :'Aft ttwo fillsI 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 recalis: ?He said, ?We 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.? He didn?t spell out what i had to do. He didn?t have to. ?He?d trained me to do whatever a man wanted. I was shocked but i told myself he was sharing me around because he trusted me and was special. 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 i was with the iife i was leading and the money I was making. It was easy to fali into his grasp. ?The way it usually worked was id 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 isoiated.? She was ?given? to men ranging in age from their 405 to their 603. They included a wail-known businessman (whose pregnant wife was asleep in the next room). a world-renowned scientist, a respected iiberal 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 heip recruit them. ?They would lounge around the Palm Beach house, the ranch or the island. nude or topless.? she says. ?But i 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 iife now 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. i met famous friends of his such as Al Gore and Heidi Kium and Naomi Campbeil. 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. smeainageeat 9 as she ieaves her blouse undone across her chest during NYC outing with her chiidren Mom-oi?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 taiks struggle of working in LA whiie Naomi Watts and their two kids are in NYC as he sits down with Eilen He misses them 'i was too big': Khloe Kardeshien reveals styiists 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 basebali cap and matching vest as he teaves NYC hotel The Magic Mike star was hard to miss Rollin' and strollin'i Chilied Bobby Cannavale 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, Page? 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. "C?ounseliing: Virgin 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 coiled 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 smeanaagadrer 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 take 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 Nakca?Wolf Seven?year?oid's mom is Lisa Bonet Craving a Mexican! Rob Kardashian?s pregnant fiancee Biac Chyna 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 'stabte 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 sail off showdown court hearing for more talks Gillian Anderson looks demure in sophisticated navy knee-fength 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 . time 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 . iqBileid 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 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 sail 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 Thaifand 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 l?d fatten 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 tetl 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 condotence to pay their respects to the victims of Orlando killer 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 Festival Let the trading begin! independence Day's Liam Hemsworth and Vivica A. Fox ring the NASDAQ bell and help celebrate the Army's birthday in NYC Ava Sembora 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 manage 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 humiliation 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, Ghistaine Maxweli nor Prince Andrew would comment on Virginia's story. Share or comment on this article Need Business Capital? 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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, Page10 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page11 of 648 6115/2016 Bill Climon and the 15-year-old 'masseuse?: i met him twice, claims Epstein's girl Daily Mail Online Home I U.K. Sports I U.S. Showbiz I Australia I Femail I Health I Science I Money IVideo ITravel IColumnists c, .. 29,1? LE1 2:132: W??l 2:35; IA??is 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. 1 ?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, Page12 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 peopie 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 tiving area of the viila 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 ali dined together that night. Jeffrey was at the head of the table. Bill was at his ieft. i sat across from him. Emmy Tayler, Ghisiaine?s blonde British assistant, sat at my right. ?Ghistaine 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. i?d say they were no cider 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 Ghislaine 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. i 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 vitla on the covered with photos of naked girls' time and highly controversial - Clinton acquaintance, Arnold Prosperi. 'In the final hours of the Ciinton presidency, in January 2001, Prosperi was facing three years in prison after being convicted of tax fraud. Mr Ctinton commuted his sentence to house arrest. ?Clinton, Prosperi and Epstein make an odd threesome on the face of it,? says a iaw 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 DID have an affair with OJ's best friend Marcus Allen and OJ 'threatened to klli her if she saw him one month before her death' ?l've been doing him forever:' Awkward moment Sonja Morgen discovers Luann de Lesseps' ?soul mate? is her old 'hook up' Thomas D?Agostino She realty iS a lady in waiting! Amelia Windsor TatIer'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' at NYC's Mercer Hotel Dad bod! Adam Sandler, 49, shows off his naked chest white wrapped in towel during Miami vacation with his wife of 13 years Couple looked blissful Kim Kardashien?s naked ambition is told 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 iosing 60lbs after pregnancy as she admits 6am sessions and "militant diet? did trick Advertisement .html 2/31 Case 18-2868, Document 278, 08/09/2019, 2628230, Page13 of 648 6115/2016 at? aFPKCietiy 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 message. 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 sesame 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, Page14 of 648 6115/2016 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 here on a yacht in the South of France. She is a friend of Ghislaine's but she was a real bitch to me. 'She was very fake. She turned away from me when we were introduced by Ghislaine and Jeffrey. ?Donald Trump was also 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 life."? Palm Beach Police say Epstein seemed utterly unfazed by the allegations against him when they began their long and detailed investigation. @37- lJeffrey?s crew: Middle East peace envoy George Mitchell, right, pictured with President Barack Obama and US. Secretary of State Hilary Clinton, frequently visited Epsteings New York residence, Virginia also claims But he also took his defence very seriously indeed. Epstein engaged his friend, the Hanrard law professor Alan Dershowitz? whose celebrity clients have included Mike Tyson, Patty Hearst, Claus von Bulow and OJ. Simpson to run his legal defence. He also employed a ?rm of private investigators to investigate the backgrounds of the girls. Detectives painstakingly built a case which they believed showed that Epstein systematically 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 Clinton, Mr Gore and Mr Mitchell were all contacted about their friendship with Epstein but declined 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 suns" Real Housewives of Beverly Hills to ?bring back privacy' to her life after dramatic season that documented her divorce and accusations she was faking illness Victoria Beckham shows a hint of sideboob and flash of leg as she flaunts her sartorial sass for cover of Vogue Korea Striking shoot A mellow day! .Rumer Willis dresses down in a grey maxi dress as she hangs out with a friend in West Hollywood Taking a break item 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 playing 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 olive coat as she recovers from Wilmer Vaiderrama shock split Wore classic combo ?i'm not killing off Harrison Ford': Steven Spielberg reveals he won't and lndiana Jones' life in next film as he gives rare interview Good news for Ford! ns-glrl .html 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 I 7' . . I?SharethiSR PR I I 7 i I Subscribe by page Breaking News 1 Entertainment I Sports Business I Politics I Science I Technology I Odd News I Health I Law More Older News .. . 272812345 6789101112 Statement on Behalf of Ghislaine Maxwell BY l?ii?Nil MARCH i 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 acuityreputationcom [?lled under: Government and Policy, 121w, Media 'l'ags: Devonshires Solicitors, London, March 10, United Kingdom GOVERNMENT AND POLICY MARCH 10 NEWS NEWS CSA Group Selects Frankfurt, Germany for . . Tech Opens a 7 - new European Headquarters - new Development . . i 'Centrein Bonn, The First International Gateway to Africa 7? Germany Conference in Geneva: Africa&apos;s - Challenges Today and Tomorrow 7_ Website Optimisation -. and Internet Marketing Central Saint Martins and Method launch From Wehlinx Accelerator to Drive Innovation and Support UK Economic Growth Sir Paul McCartney . . . Supports BUAV IVorth East Connell Campaign to end Cruel Employees??zapoa; Ideas Win Votes 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, Page18 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 Doc #1 and Jane Doe #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 Doc #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, PagelQ 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 Doc #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 .lane Doc #2 because no federal charges had ever been filed 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 fuller 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 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 Doe #1 and Jane Doc Jane Doc #3 was repeatedly sexually abused by Epstein. The Government then concealed from Jane Doc #3 the existence of its NPA from Jane Doc in violation of her rights under the CVRA. If allowed to join this action, Jane Doe #3 would prove the following: In 1999, Jane Doc #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 eo-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 Doc #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 Doe #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 Doe and with the assistance of Maxwell converted her into what is commonly referred to as a ?sex slave.? Epstein kept Jane Doe #3 as his sex slave from about 1999 through 2002, when she managed to escape to a foreign country and hide out from Epstein and his eo-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 US. Virgin Islands, in international airspace on his Epstein?s private planes, and elsewhere. Epstein also sexually trafficked the then-minor Jane Doe, making her available for sex to politically-connected and ?nancially-power?il people. Epstein?s purposes in ?lending? Jane Doe (along with other young girls) to such power?ll people were to ingratiate himself with them for 3 GIUFFRE 004290 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page21 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 4 of 14 business, personal, political, and ?nancial gain, as well as to obtain potential blackmail information. One such power?il 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 Doe #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 Doe 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?ii individual Epstein forced Jane Doe #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 Ghisiaine 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 Doe #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 friends 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 friends, 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 Doc #3 to observe him, Brunel and Maxwell engage in illegal sexual acts with dozens of underage girls. Epstein also forced Jane Doe #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 powerful men, including numerous prominent American politicians, power?il business executives, foreign presidents, a well-known Prime Minister, and other world leaders. Epstein required Jane Doe #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 Doc 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 Doe #4 would allege, and could prove at trial, that she has CVRA claims similar to those advanced by Jane Doc #1 and Jane Doc 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 Doc 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 Doe #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 Doc #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 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 6.6., on his personal jet) for purposes of illegally sexually abusing Jane Doc 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 Doc constituted numerous federal sex o?enses, 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 US. Attorney?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 Epstein?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 Doc 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 ?11 Int?!, 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 Doc #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 preperly informed by the Government (as we believe they will), that provides a stronger case for a CVRA violation. In addition, Jane Doc #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 a fair accompli.? DE 189 at 12 n.6 (emphasis added). Jane Doe #3?5 and Jane Doe #4?s 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 from the Government to the victim?s summary judgment motion, raising numerous factually-based and other arguments against the Victim?s position). GIUFFRE 004296 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page27 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 10 M14 Jane Doe #3?5 and Jane Doe #4?5 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 bear 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?5 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 Doc #2 have alleged these materials are needed to prove their allegations that, a?er 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, 6.3., 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 power?il 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 of14 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?l 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 Doe #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 Doc #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. ll GIUFFRE 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, PageSO of 648 Case Document 280 Entered on F-LSD Docket 01/02/2015 Page 13 of 14 Jane Doc #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 Doc A proposed order to that effect is attached to this pleading. DATED: January 2. 2015 Respect?illy Submitted, ls/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, LEHRMAN, PL. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mai I: brad@pathtojustice.con1 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: cassellp@law.utah.edu Attomeysfor 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 GIUFFRE 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 O?i?gi?gl?i Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE JANE DOE 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 Doc 3 and Jane Doe 4?s Corrected Motion Pursuant to Rule 21 for Joinder in Action (?Rule 21 Motion?) (DE 280), and Jane Doe 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 Doc 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 Doc 1 and Jane Doc 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. GIUFFRE002844 Case %%EldW1%Wt Osl??t?ab?ln Page 2 of 10 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 Doc 2) support the Rule 21 Motion. at 11). Jane Doc 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. (Li. 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 Doc 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. (11). 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 GIUFFRE002845 Case 82%; O?l??l?gb?lm Page 3 of 1.0 on the part of the movant, . . . undue prejudice to the opposing party by virtue of allowance of the amendment, [and] ?ltility of amendment.? Lairie, 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 ?rst 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. R, p. 432 (3d ed. 2013); see also Galustian v. w, 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). GIUFFRE002846 Case 82%; O?t?g??gl?i %8%8%&8938839l% Page 4 of 1,0 In their Rule 21 Motion, Jane Doc 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 Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 GIUFFRE002847 Case an, O?l??l?gl?i Eig??gac??g?y?l??s Page 5 of 10 Jeffrey Epstein, and (2) the Government violated their CVRA rights by concealing the non- prosecution agreement with them7-8). However, the bulk of the Rule 21 Motion consists of copious factual details that Jane Doc 3 and Jane Doc 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, power?il business executives, foreign presidents, a well-known Prime Minister, and other world leaders.? at 3-6). She names several individuals, and she offers details about the type of sex acts performed and where they took place. (E at 5).2 At this juncture in the proceedings, these lurid details are unnecessary to the determination of whether Jane Doc 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 Doc 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). GIUFFRE002848 Case O?i?gi?glt?i Page 6 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 (Q 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 file 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. GIUFFRE002849 Case Page 7 of 10 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. ll(b)(l) 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 Doe 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 ?le in any event?), 11 (litigating Jane Doe 3 and GIUFFRE002850 Case O?f?gf??l?i Page $3 of 10 Jane Doe 4?s claims would be ?duplicative?); DE 298 at 1 n.1 (?As promised . . . Jane Doe No. 3 and Jane Doe 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 Doe No. DE 311 at 5 n3 four victims (represented by the same legal counsel) intend to coordinate efforts and avoid duplicative pleadings?), 15 (Jane Doe 3 and Jane Doe 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 Doe 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 Doe No. 3 as a witness at any trial.? (DE 311 at 17 n7). The necessary ?participation? of Jane Doe 3 and Jane Doe 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, 3 10-1). GIUFFRE00285 1 Case O?f?g??gl?i ?gg?gadf<?9??b9l?f?s Page 9 of 10 at 10). Petitioners do not contend that Jane Doc 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 Doc 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. 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 notification rights under the CVRA. (E DE 290 at 10). Any ?duplicative? litigation filed by Jane Doe 4 would necessarily raise the issue of whether she has standing under the CVRA under these circumstances. 9 GIUFFRE002852 Case aeawc?aefab?ma #Pc?k?mmt sis @{Qe?i?af??a?a??z?gcfa?d??h?l? Page in of in 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 ?1 ?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 6th day of April, 2015. KENNETH A. MARRA United States District Judge 10 GIUFFRE002853 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: <rosst?lacuitvreputationcoma? Date: 2 January 2015 at 20:38 Subject: Ghislaine Maxwell To: Rossacuitv Gow <ross@acuitvreputation.com> bcc: P.Peachevr?lindependentcouk, nick.sommerlad@mirror.co.uk, davidbrown@thetimes.co.uk, nick.alwav@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 storv 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 donles. 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 1DD 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 1HQ 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 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.alway@bbc.co.uk, 18 19 dated 2 January 2015, 20 Bates No. 21 3 Email from James Ball to Ross Gow, 3O 22 dated 1 January 2015, 23 Bates No. 24 25 DTI Court Reporting Solutions New York 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. 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. 1?800-325-3376 DTI Court Reporting Solutions New York ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 5 1 I I I 2 No. Description Page 3 10 Email from gmax1@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 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?800?325?3376 Ross NEIL SUTHERLAND GOW 11/18/2016 Page 7 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. 2O 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 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 1st 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: 0. 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 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 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. So 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 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 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 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. So 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% ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 36 1 BY MS. SCHULTZ: 0%0?28 2 Q. This is a document that is Bates labeled 090601 3 0%0604 4 A. Thank you. 090h38 5 Q. The top email on this document says ?From: Ross 090609 6 Gow.? Did you send this email? 090%02 7 A I believe I did, yes. 090%07 8 Q. Did you send it to Ms. Maxwell? 090%08 9 A Yes. 09:07:09 10 Q. In the "To? field, when it says Max," do you 090701 11 recognize that to be Ms. Maxwell's email address? 090708 12 A. Yes. 09:07:23 13 Q. In the second paragraph of this email it 090707 14 states: 090709 15 "Please advise how you wish to handle this [As 090700 16 read] . 090%43 17 Did you receive a response from Ms. Maxwell? 090703 18 A. Bearing in mind I was driving all that day, I 090707 19 can't recall what the exact response was but from memory, 090702 20 it was along the lines of she would get back to me with 090707 21 how she wished to proceed. 090903 22 BY MS. SCHULTZ: 0%0&04 23 Q. Okay. 09:08:25 24 Mr. Gow, I'm going to hand you another 090806 25 document. I'm going to mark it as Exhibit 5. 090807 DTI Court Reporting Solutions New York 1?800~325~3376 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 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 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 l~800~325~3376 ROSS 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, PageG7 of 648 Forwarded message Finn: James Ball <james.bnll@lhegmrdian.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, PageG8 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 (ihislainc 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. I am driving all day today, but can be contacted on +44 (0) 7778 755 25l Best Ross Forwarded message From: James Ball <mnesbaIl?theauardiancom> Date: 'l?hursday, January I, 20 5 Subject: URGENT Ghislaine Maxwell To: rossfmaeuilvrenutationcom Dear Ross. ?hislaine Maxwell. As you are no doubt aware, fresh 'n new US court iilings 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 lame?; Vipeeia? l?rojetls?) {Editor 203 353$ Z95 11 75408125 491 {:?Jjainesrblilt Visit theguardiancom. On your mobile and tablet. download the Guardian iPhone and Android apps theguardian.com/guardianagp 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 Subscribetheguardian.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 pic. 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! to +44 (0) 777 875 525! mob +7 903 363 5393 Mocrrsa 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 Reputation Limited for loss or damage arising from the receipt or use of 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 y 5, / NY Daily News http://www.nydailynews.com/news/world/alleged-madame-accused-supplyingprince-andrew-article-1.2065505 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 Doe No. 102 v. Jeffrey Epstein, Case No. 09-80656-ClV-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 burdensome. 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; 0. the publishing entity and title of any publication containing the purportedly false statement; (1. the URL or intemet address for any internet version of such publication; and e. the nature of the publication, whether in print, intemet, 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 alter 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, PageB1 of 648 - Medicare Ami rulia ptovidcd health care insu: ante covaagc and men: for service: modved in Australia from July 19, 201.: 1mg: aw M: Giu??re?s claims histmy ?n thir. pmiud i2. 461:1in (ill 7021} Dr. Walt Wall San, (?cniral (?oast Family Mcdicim:= Unit 2, l7 Anzac Rd, Tuggcrah 22?0_ 024 :5 name-d Ms (iiul'?c Math 14,. 201.3, in panic attacks as dmibed in the Mica! ward: produced at and pcm'xbly Sam-misc: 301 for ?Standard Constantin? 'I'hm?e have requcstcai and a release sen: 1a the pun-idea; Pharmacy provided prescribed medicatims In Ms Giuf?'c as in the rounds. produced at i 08 H??valgreens Pharmacy may has provided Imam ihcd nwdiru?ms to M3. Giu?'we Those records haw hem and a rdcase wm?uim the. plum "max I N3 - Dr. ?imothy I). Ha rtwig, D1). was idcnzi?od in records produced by pharmacy. Ms (iim?frc has smu?su'? mm: d3. m- (ill 3-:6 {?18 0 Dr. James Nicnoss, MB was identi?ed in records mnduwd by pharmacy. Ms hm: Ihmc Mu 3?3] - Dr. Rodo??o "terms Jr, 51.0. ?as udcn?liui plodu'cc-d by plwmacv Ms Giuf?c has requested those teams. we (in 8354 Dated Signed. - '5 \y - Virgi nia (iiu?lc Roc'md': Mcdmaic Ausua?a aw. gem-mus Emil-:d I wan. Mn. (Shuffle is ?manning {mm pain! 29 ink 19. 20}. lhmugi: that vllk?u" In Annual?: Ms Ulu?ic now )dCMl?thu- mm: ptmidct smite but ofhcr knowledge She had pm?iousiy Eistcd both name." in an mmdancc of cumim befor: Immune ma: Dr San NE: in: same [um-id? Dt Wall th San Case 18-2868, Document 278, 08/09/2019, 2628230, PageS2 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page83 of 648 STATES DISTRICT RT YURK VIRGINIA L- Emi?'. v- GI Ila-clara?nn at? Eihialaina Man-4:5; {?Ihialaina We?- daclara as 1- I am thn: in this. aaliun. 1. i haw: an} mnm? (11' authu?ljur mar any ma?a ill-cha?ng lhuaa media arganiza?nna Ihat publiahmi an}r pan Ufa. January 1015 iaautd ur- my.- l'rahalf at the dirwllun Ila-fray ati?m23'. Philip Elan-den. Naithar I mar any" agmlt acting an my hahalf m- partiaipatad in an}; antiwar;-r nt'any media in its daciaiml ta publish or not la publish any pan af 111:: human 2015 stammant. I duclam 11an puma-1113' afp-aljuw ?mt lbmguing {a Inn: and Cami-l. ExL-aultd m1 E?ll T- {ihialaina Mad-?ak? Case 18-2868, Document 278, 08/09/2019, 2628230, PageS4 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 v. Plaintiff, 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, PageQ2 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, PageQ3 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page94 of 648 1 UNITED STATES DISTRICT COURT 2 for the SOUTHERN DISTRICT OF NEW YORK 3 Civil Action No. 15-cv-07433-RWS 4 VIRGINIA GIUFFRE, 5 Plaintiff, 6 vs. 7 GHISLAINE MAXWELL 8 Defendant. 9 10 ----------------------------------------------------VIDEO-DEPOSITION OF: JAMES MICHAEL AUSTRICH TAKEN BY: Defendant REPORTED BY: Karla Layfield, RMR Stenographic Court Reporter Notary Public State of Florida at Large 15 DATE AND TIME: June 23, 2016; 9:03 a.m. 16 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 11 12 13 14 17 18 19 20 Attorney for Defendant 21 Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, 22 FISTOS & LEHRMAN, PL 425 Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Attorney for Plaintiff 23 24 Also Present: 25 Kenneth Sarsony, Videographer Virginia Giuffre Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 1 Case 18-2868, Document 278, 08/09/2019, 2628230, Page95 of 648 2 I N D E X 1 2 PAGE WITNESS: 3 James Michael Austrich 4 Direct Examination by Ms. Menninger 4 5 Cross-Examination by Mr. Edwards Redirect Examination by Ms. Menninger 92 121 6 Recross-Examination by Mr. Edwards 143 7 8 Reporter's Certificate Certificate of Oath 146 147 9 10 - - - 11 12 E X H I B I T S 13 14 15 16 PLAINTIFF 1. Flight logs 108 DEFENDANT 17 1. Photograph 26 18 2. Passport 27 19 3. Citation Trading Report 38 20 4. School Records 21 22 (Exhibits attached.) 23 24 25 Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 136 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 00 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. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 278, 08/09/2019, 2628230, Page98 of 648 1 working at the Taco Bell in Sunrise. 2 right? 3 A Yeah, yeah. 4 Q Okay. 5 6 Did Ms. Roberts come to work at the Taco Bell where you worked? A Not at that one in Sunrise. 7 Broward, she worked with me. 8 in Sunrise. 9 Q 10 Did I get that Okay. When we moved to I think it was another one So you're saying sometime later you and Ms. Roberts moved to Broward. Is that right? 11 A Yes, we lived in an apartment. 12 Q Where was that apartment? 13 A Oakland Park, I believe. 14 Q And when you moved to that apartment in Oakland 15 Park, that's when she came to work with you at Taco Bell? 16 A Yes. 17 Q Do you know about how old you were when that 18 happened? 19 A 20 meeting her. 21 Q 22 It had to be around -- it wasn't long after Why don't you take a step back and tell me what you recall about meeting Ms. Roberts. 23 A It was a long time ago. 24 Q I understand. 25 A All I remember is my sister bringing her over Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 11 Case 18-2868, Document 278, 08/09/2019, 2628230, Page99 of 648 1 one day, we got to talking, we liked each other, and we 2 just got to know each other. 3 Q Was she in school at the time? 4 A No. 5 Q Why not? 6 A I'm not entirely sure. 7 Q Was she done with this rehab program? 8 A Yes, at the time. 9 Q Did she go back into it later? 10 A Not that I know of. 11 Q So your understanding is, she was not in school 12 and not in the rehab program at the time that you met 13 Ms. Roberts. 14 A Not that I know of, no. 15 Q Where was she living when you met Ms. Roberts? 16 A She was staying with us -- or she came over, and Correct? 17 then I guess she was staying with us for a little while, I 18 believe. 19 Q And who do you mean by "us"? 20 A At my dad's house. 21 Q Who else was living there besides yourself, your 22 23 24 25 dad and your sister? A My step-mom, my other step-sister, my step-brother and their grandmother. Q It was a big house. How long do you recall Ms. Roberts living at Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 12 Case 18-2868, Document 278, 08/09/2019, 2628230, Page100 of 648 1 that house with the family? 2 A No idea. 3 Q Weeks, months, years? 4 A Weeks. 5 Q Okay. 6 Not long. You said that you spent some time getting to know Ms. Roberts when you first talked to her? 7 A Uh-hmm. 8 Q Did she tell you anything about her childhood? 9 A If she did, I don't remember, it was so long 11 Q Do you recall meeting her parents? 12 A Yes. 13 Q Was that some time later? 14 A Yes. 15 Q Tell me about when you remember meeting her 10 16 ago. parents. A 17 I think that was -- all I remember -- really, 18 all I remember is going to the house and meeting her 19 parents. I don't remember much from that time. Q Okay. 22 A Yeah. 23 Q Did you and Ms. Roberts become a couple soon 20 21 24 25 I appreciate that this is all a long time ago after you met her? A Yes. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 13 Case 18-2868, Document 278, 08/09/2019, 2628230, Page101 of 648 1 Q Was she dating anyone else at that time? 2 A No. 3 Q Tell me where you -- did you both move out of 4 that home, your dad's home, together? 5 A Yes. 6 Q And where did you go directly after that home? 7 A To the Oakland Park apartment. 8 Q At the time you got the Oakland Park apartment, 9 do you recall how old you were? 10 A I had to be 18 to get an apartment. 11 Q Okay. 12 A 16. 13 Q Is that a guess, or do you remember? 14 A That's a guess. 15 Q Do you think you are about two years older than 16 she is? 17 A About. 18 Q Okay. 19 20 And do you know how old Ms. Roberts was? Maybe a little more. How long did you two live together at the Oakland Park apartment? A Less -- I know it wasn't a full year. 21 know exactly how long it was. 22 months it was. I don't I don't know how many 23 Q Did anyone else live there with you? 24 A Yes, a roommate. 25 Q Who was that? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 14 Case 18-2868, Document 278, 08/09/2019, 2628230, Page102 of 648 1 2 3 4 A Mario. Last name, I can't remember. I haven't seen him since that apartment. Q Was he a friend of yours or hers, or just someone else? 5 A He was a friend of mine. 6 Taco Bell. 7 Q He worked with me at And after you moved to this Oakland Park 8 apartment, Ms. Roberts came to work at the Taco Bell as 9 well? 10 A Yeah, with him and me. 11 Q Do you recall where that Taco Bell was? 12 A By the Sawgrass Mall. 13 Q How long did Ms. Roberts work at that Taco Bell? 14 A I don't remember. 15 Q You were a manager at the time? 16 A Yes, me and my roommate. 17 Q You were both managers? 18 A Yeah. 19 Q Was she an official employee? 20 A Yes. 21 Q She was on the payroll? 22 A Yes. 23 Q And you were the manager? 24 A Um-hmm? 25 Q And she paid -- she was paid for by Taco Bell? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 15 Case 18-2868, Document 278, 08/09/2019, 2628230, Page103 of 648 1 A Yes. 2 Q Was it is a franchise, if you know? 3 A I know when I first started there, they were 4 corporate, but then they were a franchise. 5 bought out. 6 were a franchise or not. 7 Q 10 11 Got it. employment before she worked at Taco Bell? A I think by the apartment, she worked for KFC for a little while. MS. MENNINGER: 12 13 But I'm not sure if when I got there they Do you know if Ms. Roberts had any previous 8 9 They were Are you looking at Ms. Roberts? THE WITNESS: 14 I'm thinking. I can't 15 remember. 16 had one really close to us. I think she worked 17 there for a tiny, tiny bit. I'm not sure. MS. MENNINGER: 18 19 I remember something with KFC. They Okay. BY MS. MENNINGER: 20 Q Before the Taco Bell? 21 A Or she could've applied there. It's just in my 22 head. She might have just applied there, and didn't get 23 it, and that's why I brought her to Taco Bell. 24 Q Okay. 25 A Because we were both the night managers. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 16 Case 18-2868, Document 278, 08/09/2019, 2628230, Page104 of 648 1 Q Okay. Got it. So for not a full year, the two of you worked 2 3 together at a Taco bell near the Sawgrass Mills (as 4 heard) and lived in an apartment in Oakland Park? 5 A Yes. MR. EDWARDS: 6 7 Object to the form. BY MS. MENNINGER: 8 Q With Mario? 9 A Yeah. 10 Q Did Mario live there the whole time? 11 A Yes. 12 Q What caused you to stop living at the Oakland 13 14 15 Park apartment? A I don't remember exactly. But I know we moved out before, and Mario stayed in the apartment. 16 Q Where did you move to? 17 A Her parent's house. 18 Q Did you move into the house or to someplace near 19 the house? 20 A 21 house. 22 lived in. 23 24 25 Q I don't remember if we originally moved into the But I know they had a trailer in the back that we How long did you live in the trailer in the back? A No idea. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 17 Case 18-2868, Document 278, 08/09/2019, 2628230, Page105 of 648 1 A No. 2 Q Do you know about what years this was? 3 A Not really. 4 Q Do you know about how old you were? 5 A When, what? 6 Q I'm just focused on the period of time in which 7 you were living at her parent's house in the trailer. 8 A I was probably 18 when we moved in there. 9 Q And you said you were only there for a couple of 10 11 12 months? A Not that I remember. little longer. Like, it might have been a I'm not sure. 13 Q Were you engaged to Ms. Roberts? 14 A Yes. 15 Q When did you become engaged to her? 16 A When we were living in Oakland Park. 17 Q Tell me about the engagement. 18 about? 19 A 20 How did it come Well, we fell in love, and -- I believe it was Valentine's Day when I proposed. 21 Q Did you have a ring? 22 A Yes. 23 Q Did she accept? 24 A Yes. 25 Q How long were you engaged? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 19 Case 18-2868, Document 278, 08/09/2019, 2628230, Page106 of 648 1 A I'm not entirely sure. 2 Q Do you remember an event where the engagement 3 was broken off? 4 A When I left. 5 Q Left where? 6 A When I left -- Royal Palm Beach, I guess, was 7 8 9 our apartment. Q When you left that apartment, that's when the engagement was over in your mind? 10 A Yes. 11 Q Were your families happy about the engagement? 12 A Yes. 13 Q Have you ever been married since then? 14 A No. 15 Q Have you ever been engaged since then? 16 A No. 17 Q Do you know what happened to the ring? 18 A Yes. 19 Q Where is it? 20 A I have it. 21 Q Still? 22 A Yeah. 23 Q Did you get down on one knee? 24 A Yes, at the beach, I believe. 25 Q When you were living in Oakland Park, in this My mother was. My dad wasn't too happy. It was my grandmother's. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 20 Case 18-2868, Document 278, 08/09/2019, 2628230, Page107 of 648 1 2 Q So from about the ages you were 18 to 20 is when you were living together with Virginia? 3 A Yeah. 4 Q And between the time you met her at your dad's 5 house and the time that you broke up, did you guys break 6 up and get back together, or was it one consistent 7 relationship, and then it had an end date? 8 A Yeah, one consistent relationship. 9 Q Okay. 10 You mentioned that you moved into an apartment in Royal Palm Beach? 11 A Yeah, I believe that's where it was, Royal Palm 12 Beach. 13 Q Do you remember anything about the apartment? 14 A All I remember, it was on the third floor. 15 Q And who got that apartment? 16 A I did. 17 Q Again, you were over 18 at that time? 18 A Yes. 19 Q So you got the lease? 20 A Yes. 21 Q Do you remember looking for the apartment? 22 A I believe so. 23 Q And it wasn't the first apartment you rented, 24 right? 25 A No. No, the one in Oakland Park was the first Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page108 of 648 1 2 one I rented. Q Okay. MS. MENNINGER: 3 I'm going to show you some 4 photographs. If I could have you mark this. 5 guess we'll start again with, I guess we'll start 6 again with Defendant's Exhibit -- 7 you. 8 on it. I got one for Defendant's Exhibit 1 or A, whatever you put THE COURT REPORTER: 9 1. 10 MS. MENNINGER: 11 (Defendant's Exhibit 1, photograph, was 12 13 14 15 Exhibit 1. marked for identification.) BY MS. MENNINGER: Q Please take a look at this. There are two photographs stapled together. Does that look like the apartment that you 16 17 lived in on the third floor? 18 A It could be. 19 Q The address on this is 368 Bent Oak. 20 I I don't really remember it. Does that sound about right? 21 A Bent Oak sounds familiar. 22 Q You don't recognize the -- it may have been 23 painted, for example? 24 A Yeah. 25 third floor. I mean, all I remember is being on the Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 26 Case 18-2868, Document 278, 08/09/2019, 2628230, Page109 of 648 MS. MENNINGER: 1 I'm going to show you another 2 exhibit. 3 Defendant's Exhibit 2. We'll mark this (Defendant's Exhibit 2, passport, was marked 4 for identification.) 5 6 Let me find it. BY MS. MENNINGER: Q 7 I know this is not terribly easy to read, but 8 it's a passport application that has been previously 9 identified in this case. And in the middle section, 10 there's emergency contact information that says "James 11 Austrich". Do you see that? 12 13 A Yes. 14 Q Is that you? 15 A Yes. 16 Q And it says 368 Bent Oak Drive below that? 17 A Yes. 18 Q Does that refresh your memory as to the address, 19 the apartment that you lived in in Royal Palm Beach? A 20 Like I said, Bent Oak sounds very familiar, and 21 I know it was Royal Palm Beach. 22 one. 23 24 25 Q Okay. So possibly it was that And how long do you think that you lived in this apartment? A I'm not entirely sure. Less than a year, that's Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 27 Case 18-2868, Document 278, 08/09/2019, 2628230, Page110 of 648 MS. MENNINGER: 1 2 exhibit as Defendant's Exhibit 3. (Defendant's Exhibit 3, Citation Tracking 3 4 5 6 I'm going to mark this Report, was marked for identification.) BY MS. MENNINGER: Q I'm going to have you take a look at this. 7 Actually, I apologize because I need you to turn back 8 several pages to -- the lower right-hand corner has some 9 page numbers that say G.M. And I need you to go to 781. 10 A (Witness complies.) 11 Q Could I have you take a look at the narrative 12 section of that page. 13 paragraph. 14 A 15 16 If you want to just read that "John Perkins," I don't even know that name. MS. MENNINGER: I guess you guys haven't kept in touch. 17 MR. EDWARDS: He was scared that day. 18 THE WITNESS: (cont'd) Plus, when I left 19 there, I didn't really talk to anybody from up 20 there. 21 remember the cops telling me even though it was 22 under my name, I couldn't go in. 23 later on then they got out so I could go back and 24 get me stuff. 25 animals. I remember somewhat of that. Yeah, I And I think I think I was going to see my Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 38 Case 18-2868, Document 278, 08/09/2019, 2628230, Page111 of 648 1 2 3 4 BY MS. MENNINER: Q Yeah. I didn't know if reading this might cause you to remember some things. A I somewhat remember that. I remember the cops 5 coming and telling me I wasn't allowed to go in my own 6 apartment that was under my name. 7 8 Q Okay. A Yes. 10 Q Okay. 12 13 14 15 So this is dated June 10th, of 2001. And it places you at 368 Bent Oak Drive, correct? 9 11 39 Do you understand that to likely be where you were living with Ms. Roberts? A Yeah. But at the time I was already back in Okay. Do you know how long you had been back in Broward. Q Broward? 16 A Not a clue. 17 Q And in this, it refers to Ms. Roberts as your 18 ex-fiancé, correct? 19 A Yes. 20 Q So presumably the event you described where you 21 22 had a fight and left had already occurred? A Yes. 23 MR. EDWARDS: Form. 24 THE WITNESS: I know I was already out of 25 there. And that's why when I went back, that's 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, Page112 of 648 1 when the cops said I couldn't go in my own 2 apartment. 3 4 BY MS. MENNINGER: Q So your recollection today is that you were 5 returning to that apartment to either get things or check 6 on pets? 7 A Yes. 8 Q What pets do you recall having? 9 A A dog and six cats and, I believe, ferrets and 10 rabbits. 11 liked animals. 12 Q One reason we got along so well is because we And do you remember going back to the apartment 13 to check on the pets and encountering Ms. Roberts and 14 Tony? 15 A Yeah. 16 Q Were you inside the apartment when you 17 encountered them? 18 A No, outside. 19 Q Did you understand them to be living in the 20 apartment at that time? 21 A Yes. 22 Q In the police report it says "Austrich stated 23 his ex-fiance, Virginia Roberts, who also resides at the 24 above-listed address, brought her friend to the 25 apartment." Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 40 Case 18-2868, Document 278, 08/09/2019, 2628230, Page113 of 648 1 A I believe that was Tony. 2 Q Okay. And at this time, the police are 3 indicating that you both lived there. 4 you remember? 5 A No. But that's not what They wouldn't even let me -- all I 6 remember -- I remember being outside the door and the cops 7 wouldn't let me go in there because -- even though it was 8 my apartment and my address was on the thing, I wasn't 9 allowed in there. 10 there. 11 Q 12 Because I'm pretty sure I wasn't living I just came back to get something. Do you know how long after you left you were coming back to get something? 13 A I don't remember. 14 Q If you left your pets there, I guess, I'm just 15 wondering whether you intended to go back and get your 16 pets? 17 A I couldn't because my dad didn't -- my dad 18 didn't really take -- like, he didn't want all those 19 animals. 20 a fan of cats. MR. EDWARDS: 21 22 Because he already had three dogs and he wasn't A Or ferrets. (cont'd) Or ferrets or rabbits. I think we had 23 a gerbil, mice, rats, all kinds of stuff. I know we had 24 pet store cages that we bought to keep them all in. 25 Because when we lived in West Palm Beach it was like a Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 41 Case 18-2868, Document 278, 08/09/2019, 2628230, Page114 of 648 1 2 3 little animal rescue for a while. Q Did you get that stuff from the pet store where you both had worked? 4 A Yes. 5 Q A discount, I hope? 6 A I feel like every time I went to the pet store, 7 I got a new animal. Still do the same thing. 8 Q Do you have pets today? 9 A Oh, yeah. 10 I have dogs. I have two dogs. have six cats and three birds. 11 Q No reptiles? 12 A No. 13 Q Is that a different kind of pet owner? 14 A Well, I had reptiles in West Palm Beach. 15 We No, I don't really like --- They are too hard to take care of. 16 Q Spiders? 17 A No, I don't want to be -- I have enough spiders 18 19 where I live. Q Okay. All right. Do you remember Tony punching you in the 20 21 I don't need pet spiders. face? 22 A I don't remember. 23 Q You see that's what the police report says? 24 A Yeah, yeah, yeah. 25 He might have. remember. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com I don't 42 Case 18-2868, Document 278, 08/09/2019, 2628230, Page115 of 648 1 2 3 Q And the police observed you to have minor swelling and a large red mark. A Does that sound accurate? From according to what it says, yeah. I don't 4 really remember that. 5 the cops coming and telling me I can't go in there. 6 I read that, that's really all I remember. 7 8 9 10 Q I remember being at the door and Do you believe that whatever altercation you had took place within the apartment or outside the apartment? A In the doorway at the most. I never went inside that apartment when that was happening, not I remember. 11 Q Do you ever get to see those pets again? 12 A Yes. 13 14 Once I think later on, they both left for the day and let me go in and see my pets. Q Now, this indicates that the police were there 15 at about 9:20 in the evening, and you were there with 16 Mr. Perkins. 17 A No. But you don't remember Mr. Perkins? If it would have said "Josh" 18 might be a name I remember. 19 friends up there. 20 don't really remember. 21 Q I think that But John -- I know we had two John could have been one of them, but I John Perkins. That's so weird. The police report also indicates that 22 Mr. Figueroa observed Perkins on the telephone and fled 23 the scene prior to arrival. 24 25 A No. Do you remember that? I don't remember "Perkins". As soon as I saw that name, I'm like "Who the hell is John Perkins?" Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 43 Case 18-2868, Document 278, 08/09/2019, 2628230, Page116 of 648 Q 1 All right. If you can turn to the next page. 2 The police report continues that they made numerous 3 attempts to contact you and Mr. Perkins, whoever he is -- 4 A Yeah. 5 Q -- and Ms. Roberts at the residence or on the 6 phone, but had not been able to do that? 7 A If they called the residence, I wasn't living 8 there. 9 in Broward. 10 Q 11 back in '01. 12 '01? And I don't remember them ever trying to call me Do you know if you had a cell phone? This was I don't even know if I had a cellphone in 13 A Yeah, I really couldn't tell ya'. 14 Q Okay. So your best recollection, after 15 reviewing this report, is that you had left on a previous 16 date and came back on this date to see your pets? 17 A Yeah, yeah. 18 Q And that you were ultimately able to get in and 19 see the pets? 20 A Later on, yes. 21 Q Okay. 22 A Later on. Like, the same day or -I don't really remember how much 23 longer --- how many days later, or something. 24 long. 25 Q Not too And when you came back at that later time, you Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 44 Case 18-2868, Document 278, 08/09/2019, 2628230, Page117 of 648 1 did not encounter Ms. Roberts? 2 A No, nobody was in the house but my animals. 3 Q And since that time you have not had any contact 4 with Ms. Roberts? 5 A No. 6 Q Okay. What was your opinion of Tony? 7 MR. EDWARDS: Form. 8 THE WITNESS: An idiot. 9 10 That's all I really remember. BY MS. MENNINGER: 11 Q Did you believe him to be using drugs? 12 A Yes. 13 Q Do you know what kind? 14 A Whatever he could get. 15 Q When Ms. Roberts started hanging out with Tony 16 17 again, did you then believe her to be using drugs? A MR. EDWARDS: 18 19 Yes. Form. BY MS. MENNINGER: 20 Q What caused you to have that belief? 21 A Actions. MR. EDWARDS: 22 23 Same objection. BY MS. MENNINGER: 24 Q What kinds of actions? 25 A I don't remember. All I remember is that's what Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 45 Case 18-2868, Document 278, 08/09/2019, 2628230, Page118 of 648 1 A Sorry. 2 Q You're still under oath, do you remember? 3 A Yes. 4 Q Okay. 5 So you were referring a little bit to the time that Ms. Roberts worked for Jeff? 6 A Yes. 7 Q You knew him as Jeff or Jeffrey? 8 A I remember Jeff. 9 Q Okay. 10 11 It could have been Jeffrey. Tell me what you recall about Ms. Roberts going to work for Jeff. A I don't remember much of it, really. 12 remember is that she went to work for him. 13 went to some island. 14 had a house in Palm Beach I think it was. All I I know they I know they traveled around. And he 15 Q Did she tell you what she was doing for Jeff? 16 A At the beginning, it was massage. 17 That's what I was told. 18 Q By her? 19 A Yes. 20 Q Okay. 21 A Yes. 22 Q Was she getting paid more money? 23 A Yes. 24 Q Do you know how much? 25 A No. Did she seem excited about that job? A lot more. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 56 Case 18-2868, Document 278, 08/09/2019, 2628230, Page119 of 648 Q 1 2 So she hadn't come to you before that and said, "Hey, I'm having to do something other than massages"? 3 A I don't remember. 4 Q She may have; she may not have? 5 A Yeah. 6 Q Well, why would you be fighting about it at the 8 A Well, that's because she was messing with Tony, 9 the idiot. 10 Q So the fight -- 11 A I mean, that's what he -- the fight's what 7 12 13 14 15 I don't remember. end? brought everything out. Q Okay. So she was messing with Tony, the idiot, and you guys got in a fight about her messing with Tony? A I think that's what it originally it was. 16 Because she was supposed to come home, and I think she 17 went over there instead. 18 that's when I found out about that, with the idiot. 19 I believe the other stuff came to light. 20 remember. 21 22 Q That's when I found out -Then, I don't really As you sit here, you think that's when you were finding out about all of this at the same time? 23 A I believe so, but I don't really remember. 24 Q Do you know where Tony lived? 25 A Somewhere around there, where our other Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 68 Case 18-2868, Document 278, 08/09/2019, 2628230, Page120 of 648 1 Q You had trouble figuring out what was the truth? 2 A Yeah. 3 But I know for sure she was with the idiot, so that's the main reason. 4 Q Well, you saw her with him, right? 5 A Well, I found out that she was in town, but not 6 here, and that's when I found out. 7 Q Okay. Not at home -- not at your home? 8 A Yeah. 9 Q When you believed yourself to be engaged? 10 A Yes. 11 Q Okay. 12 whereabouts? She was not truthful with you about her 13 MR. EDWARDS: 14 THE WITNESS: 15 Object to the form. Yes. BY MS. MENNINGER: 16 Q And you confirmed that in some fashion? 17 A Yes. 18 Q When another problem arose at the apartment, the 19 police were called, correct? 20 MR. EDWARDS: Form. 21 THE WITNESS: Other than that? 22 BY MS. MENNINGER: 23 Q With Mr. Perkins? 24 A I don't -- all I remember is that one time. 25 Q I just did a really bad question, so let me try 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, Page121 of 648 1 2 about being forced to do things -A No. She might have told me some stuff, but 3 what, I don't remember really. 4 truth at the time anyway. Who knows if it was the 5 Q And you weren't doing drugs at that time? 6 A I wouldn't say no. 7 smoking a lot. 8 stuff. 9 Q I know at the end, I was And I might have been doing some other I'm not sure. Okay. Regardless, you would not have been 10 comfortable believing your fiancé was having sex with 11 other people? 12 A No. 13 Q Did she, Ms. Roberts ever tell you that she was 14 posing naked for photographs? 15 A No. 16 Q Would you have been okay with her posing naked 17 for photographs? 18 A No. 19 Q Did Ms. Roberts ever mention Ghislaine Maxwell, 20 my client? 21 A If she did, I don't remember the name. 22 said, I only remember Jeff. 23 remember. 24 25 Q Like I That name is all I really Because you don't remember Ms. Maxwell's name, I assume you don't remember Ms. Roberts telling you that Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 74 Case 18-2868, Document 278, 08/09/2019, 2628230, Page122 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 James Michael Austrich; that said witness was duly sworn 8 to testify truthfully; and that the foregoing pages, 9 numbered 1 through 145, inclusive, constitute a true and 10 correct record of the testimony given by said witness to 11 the best 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, 15 counsel, nor am I financially interested in the action. 16 17 nor a relative or employee of such attorney or WITNESS MY HAND this ___ day of June, 2016, at Ocala, Marion County, Florida. 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 146 Case 18-2868, Document 278, 08/09/2019, 2628230, Page123 of 648 1 CERTIFICATE OF OATH 2 STATE OF FLORIDA 3 COUNTY OF MARION 4 I, the undersigned authority, certify that James 5 Michael Austrich personally appeared before me and was 6 duly sworn on the 23rd day of June, 2016. 7 8 WITNESS MY HAND AND OFFICIAL SEAL this _____ day of June, 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 X Produced Identification of FDL Exp. 07/9/80 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 147 Case 18-2868, Document 278, 08/09/2019, 2628230, Page124 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page125 of 648 If. 'Irq.135; 9" MIMI l" was: --I it ?My. NiQ'a?j 1' . 2,82ia?rv fife-70" .5409}. Ii" any}: I . . ..-.. . . 5 1- mum: i1 . ?33Personal Information . I'yfF019Otin?n?u GIUFFRE004721 Case 18-2868, Document 278, 08/09/2019, 2628230, Page126 of 648 EXHIBIT Agren Blando Court Reporting2628230, & Video,Page127 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page128 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page129 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page130 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page131 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page132 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page133 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page134 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page135 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page136 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page137 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page138 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page139 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page140 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page141 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page142 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page143 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page144 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page145 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page146 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page147 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page148 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page149 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page150 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page151 Inc. Case 18-2868, Document 278, 08/09/2019, 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,Page152 Inc. Case 18-2868, Document 278, 08/09/2019, 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 EXHIBIT 0 may. 25. 20 10053305102868, Document 278, 08/09/2019, 2628230, Page1541?cof4648 r. 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: I 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 EA1 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 HI 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 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 PAGE PAGE TERML: Date: 5/23/2016 Time: 9:05:36 AM Case 18-2868, Document 278, 08/09/2019, 2628230, Page155 of 648 TO 00000 I SO PALM BEACH SCHOOL: $390 INFORMATION GRADE LEVEL: 10 1 TE: 03?? CURRENT DISTRICT: 50 PALM BEACH PAGE CURRENT 3390 SURVIVURS CHARTER SCHOOL LEGAL NAME: ROBERTS, VIRGINIA :551) 712-1000 MAILING 12959 RACKLEY ED ;310 CONGRESS AVE ADDRESS: LUXAHATCHEE FL 33470 EST PALM BEACH FL 13409 DISTRICT STUDENT ID: 12070606 FL STUDENT ID-ALIAS: MIGRANT STUDENT In: 00000000000 SEX: SKY ROBERTS PARENT BIRTH VERIFICATION: 1 LYNN ROBERTS PARENT . LACE: SACRAMENTO CA IMMUNIZATION STATUS: PERMANENT IMMUNIZATION CERTIFICATE VACCINE STATUS. DATE- VACCINE CERTIFICATE EXPIRATION DATE: TYPE DOSE DATE DOSE DATE DOSE DATE DOSE DATE DOSE DATE DVD 1 11/02/1983 2 02/33/1984 5 04/27/1904 4 04/24/1987 5 09/27/1900 TD 1 06/24/1997 FOLIO 1 11/02/1983 2 02/03/1984 3 04/24/1907 4 HIB 1 04/24/1967 MMR 1 04/24/1987 2 04/18/1997 MEASLES 1 04/24/1957 HEP 3DOSE 1 04/10/1997 2 06/24/1997 3 09/03/1999 COURSE INFORMATION -- DISTRICT: 60 SCHOOL: 3390 NO COURSES TAKEN DISTRICT: 50 SCHOOL: 1901 LOXAHATCUEE GROVES ELEM YEAR: 1989-1990 GRADE LEVEL: NA YEAR: 1991-1993 GRADE LEVEL: 03 SUBJECT CRSE CREDIT GPA QTY PTS GPA OTY DTS COURSE TITLE AREA FLAG GRD DISTRICT-TERM: 1.4286 5.00 CUM: 1.5429 27.00 3 5100090 THIRD GRADE 9 0.00 0.00 STATE-TERM: 1.4286 5.00 CUM: 1.5429 27.00 CREDIT, TERM: 0.00 0.00 1909~199o ANNUAL DAYS-PRESENT: 0 ABSENT: 0 1991?1992 ANNUAL DAYS-PRESENT: 180 ABSENT: 0 SUMMEN TERMS DAYS-PRESENT: 0 ABSENT: 0 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 ACADEMICALLY PROMOTED DISTRICT: 50 SCHOOL: 3390 NO COURSES TAKEN DISTRICT: 50 SCHOOL: 1901 LOXAHATCHEE GROVES ELEM. YEAR: 1990-1991 GRADE NA YEAR: 1992-1993 GRADE LEVEL: 04 SUBJECT CRSE CREDIT GPA QTY PTS GPA QTY PTS COURSE TITLE AREA FLAG GRD DISTRICT-TERM: 1.4236 5.00 CUM: 1.5429 27.00 3 5100100 FOURTH GRADE 0.00 0.00 STATE 1.4286 s.oo CUM: 1.5429 27.00 CREDIT, TERM: 0.00 0.00 1990-1991 ANNUAL DAYS PRESENT. 0 ABSENT: 0 1992-1995 ANNUAL DAYS-PRESENT: 176 ABSENT: 4 SUMMER TERMS 0 ABSENT: 0 SUMMER TERMS 0 ABSENT: 0 ACADEMICALLY PROMUTED ACADEMICALLY OFFICIAL TRANSCRIPT THE SCHOOL DISTRICT OF A PALM BEACH COUNTY FLORID APR 1 2008 RECORDS CUSTODIAN GIUFFRE004981 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, of 648 TO - 0000050 PALM BEACH ROBERTS, VIRGINIA SCHOOL: 3390 TE: 03 J1 200E CURRENT DISTRICP: CURRENT SCHOOL: COURSE INFORMATION 50 PALM BEACH FILE: . 3590 SURVIVORS CHARTER SCHOOL (561) 712-1800 50 SCHOOL: 2J31 ROYAL PALM BEACH COMM 1997~1998 GRADE LEVEL: SUBJECT COURSE TITLE AREA SPANISH 1 FL ENG 1 EN ALGEBRA IR MA BEG AEROBICS PE 9C1 SC CARIBBEAN STUDIES EL NUTRITION 5x WELLNESS V0 ENG 1 EN ALGEBRA 1A MA PERS FIT PE SCI SP WORLD CULT GEOG EL 50 SCHOOL: 9034 ESE SUBJECT CRSE COURSE TITLE AIORERA SPT CREDIT, GPA QTY PTS MIC 09 CREE CREDIT FLAG CRD RJ 0.50 0.00 RJ 1) 0.50 0.50 JR 0.50 0.00 0.50 0.00 0.50 0.00 0.50 0.00 0.50 0.00 RJ A 0.50 0.50 JR 0.50 0.50 RJ A 0.50 0.50 A 0.50 0.50 0.50 0.50 CTHER TEACHING SERV 1997-1998 GRADE LEVEL: 09 TERM: 1.8571 13.00 CUM: TERM: 1.8571 13.00 ANNUAL DAYS PRESENT: SUMMER TERMS DAYS-PRESENT: NOT ENROLLED IN DISTRICT: 50 SCHOOL: 1901 LDXAHATCHEE GROVES ELEM. DISTRICT: 1991-1994 GRADE LEVEL: 05 YEAR: 5000501 CRSB 005011 COURSE: COURSE TITLE AREA FLAG CRO 0000550 3 5100110 FIFTH GRADE 9 0.00 0.00 1 0700340 3 5100110 FIFTH GRADE 0.0c 0.00 1 1001310 CREDIT, TERM: 0.00 0.00 1 1200370 1 1503400 1993-1994 ANNUAL DAYS-PRESENT: 157 ABSENT: 13 1 2001310 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: a 1 2100410 ACADEMICALLY PROMOTED 1 8500355 2 1001310 DISTRICT: 50 SCHOOL: 1190 N0 COURSES TAKEN 2 1200170 YEAR: 1994 1995 GRADE LEVEL: NA 2 1501300 2 2001110 GPA 017 p73 CPA QTY 979 2 2103300 DISTRICT-TERM: 1.4280 5.00 CUM: 1.5429 27.00 STATE-TERM: 1.4286 5.00 cum; 1.5429 27.00 DISTRICT: YEAR: 1994-1995 ANNUAL DAYS-PRESENT: 0 ABSENT: 0 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 counsaa NOT ENROLLED IN DISTRICT K-12 AT END OF SCHOOL YEAR 4 1200370 5 2001310 DISTRICT: 50 SCHOOL: 1691 CRESTWOOD MIDDLE YEAR: 1990?1997 GRADE LBVEL: 08 SUBJECT CRSE CREDIT COURSE TITLE AREA FLAG CR3 DISTRICT 2 0400010 DRAMA 2 A 0.00 0.00 STATE 2 3500240 TEEN CHALLENGES 0.00 0.00 3 1001070 LANG ARTS 1 0.00 0.00 1997~1998 3 1205070 MATH 3 0.00 0.80 3 2002100 COMPRE SCI 3 0.00 0.00 1 2103050 AND CHO 0.00 0.00 CREDIT, TERM: 0.00 0.00 1990-1997 ANNUAL DAYS-PRESENT: 40 ABSENT: 5 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 ACADEMTCALLV PHOMUTED OFFICIAL TRANSCRIPT THESCHOOLDISTRICTOF PALM BEACH COUNTY. FLORIDA APR 1 2008 RECORDS CUST DIAN AT CREDIT AREA FLAG GRD MA JR 0.50 0.50 so A 0.50 0.50 TERM: 7.00 4.00 GPA QTY 979 1.0571 13.00 CUM: 1.8571 13.00 ABSENT: 0 ABSENT: 0 END OF SCHOOL YEAR GIUFFRE004982 CONHDENUAL TO DISTR LEGAL NAME 13?: 0000050 PALM BEACH EPARED ROBERTS, VIRGINIA 50 SCHOOL: 0581 FOREST HTLU HIGH SCHOOL: 3390 COURSE INFORMATION CURRENT DISTRICT: SC PALM BEACH CURRENT SCHOOL: {561) 712?1000 FILE: SRTCIRTS PAGE 3 3390 SURVIVORS CHARTER SCHOOL 50 SCHOOL: 3390 NO COURSES TAKEN YEAR: 1998-1999 GRADE LEVEL: 09 YEAR: 2000-2001 GRADE LEVEL: NA SUBJECT CRSE CREDIT COURSE TITLE AREA FLAG GRD GPA QTY FTS GPA QTY PTS 1 0500500 UEV 1 EL 0.50 0.50 DISTRICT-TERM: 1.4286 5.00 CUM: 1.5429 27.00 1 0701320 FRENCH 1 FL RJ 0.50 0.50 STATE-TERM: 1.4286 5.00 CUM: 1.5429 27.00 1 1001340 ENG 2 EN RJ A 0.50 0.50 1 120C380 ALGEDRA IB MA JR 0 50 0.00 2000-2001 ANNUAL DAYS-PRESENT: 0 ABSENT: 0 1 1900300 DRIVER ED CLASS EL 0.50 0.50 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 1 2000310 BIOLOGY 1 SC RJ A 0.50 0.50 PROMOTION STATUS NOT APPLICABLE 1 2109310 WORLD WH RJ 0.50 0.50 2 0500500 DEV 1 EL 0.50 0.00 DISTRICT: 50 SCHOOL: 3390 SURVIVORS CHARTER SCHOOL 3 0701320 FRENCH 1 FL RJ 0.50 0.00 YEAR: 2001-2002 GRADE LEVEL: 10 2 0800J00 MGMT SKL LM RJ 0.50 0.00 SUBJECT CRSE CREDIT 2 1001340 ENG 2 EN RJ 0.50 0.00 COURSE TITLE AREA FIAG GRD 2 1200380 ALGEBRA 18 MA JR 0.50 0.00 1 0500530 DEV 4 EL 0.50 0.50 2 2000310 1 SC RJ 0.50 0.00 1 1001440 BUSINESS ENG 1 EN 0.50 0.50 2 2109310 WORLD HIST NH RJ 0.50 0.00 1 1205370 CONSUMER MATH MA 0.50 0.50 CREDIT. TERM: 7.00 3.00 1 8300310 WORKPLACE ESSENTIALS V0 0.50 0.50 1 8301610 WORK EXP 1 V0 0.50 0.8101650 WORK EXP-OJT V0 1.00 0.03 DISTRICT TERM: 1.2857 9.00 CUM: 1.5714 22.00 CREDIT, TERM: 3.5 2.00 STATE-TERM: 1.2357 9.00 CUM: 1.5714 22.00 GPA QTY PTS GPA QTY PTS 1998-1999 ANNUAL DAYS-PRESENT: 155 ABSENT: 25 DISTRICT-TERM: 1.4286 5.00 CUM: 1.5420 27.00 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 STATE-TERM: 1.4286 5.00 CUM: 1.5429 27.00 ACADEMICALLY PROMOTED 2001-2002 ANNUAL DAYS-PRESENT: 0 ABSENT: 0 DISTRICT: 50 SCHOOL: 3390 NO COURSES TAKEN SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 YEAR: 1999_2000 GRADE LEVEL: NA PROMOTION STATUS NOT APPLICABLE GPA 918 GPA QTY PTS GIUFFRE004983 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page157 of 648 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: 3 NOT ENROLLED IN DISTRICT AT END OF SCHOOL YEAR OFFICIAL TRANSCRIPT THE SCHOOL DISTRICT OF PALM BEACH COUNTY. FLORIDA APR 1 2008 RECORDS CUSTODIAN Case 18-2868, Document 278, 08/09/2019, 2628230, Page158 of 648 T0 - 0000030 PALM REACH 5 . LEGAL NAME: A I A 0 AS OF: 04/11/2000 i i GRADUATION OPTION: 4-YR STANDARD - - - CREDITS - SUBJECT TOTAL TOTAL TOTAL AREA TO DETE NEEDED REMAINING ENGLISH (EN) 2.00 4.00 2.00 MATHEMATICS (MA) 1.50 3.00 1.50 SCIENCE (SC) 1.50 3.00 1.50 AMER HISTORY (AH) 0.00 1.00 1.00 WORLD HTSTORY (NH) 0.50 1.00 0.50 ECONOMICS (EC) 0.00 0.50 0.50 . AMER GOVERNMENT (A6) 0.00 0.50 0.50 0.50 PERFORM FINE ART (PF) 0.00 1.00? 0.50A LIFE MGHT SKILLS (LM) 0.0C 0.50 0.50 . PHYSICAL ED (PE) 0.50 0.50 0.00 . FOREIGN LANGUAGE (FL) 0.50 0.00 LANGUAGE ARTS (LA) 0.00 i SOCIAL STUDIES (33) 0.00 ELECTIVE (EL) 2.00 9.00 6.50 ESE (EX) 0.00 COMPUTER ED (CH) 0.00 CREDITS, CUMULATIVE: 9.00 24.00 15.00 . . TOTALS TNPYUDE VOCATIONAL PERFORM FINE . mm GPA CITY PTS 1 1.5429 27.00 STATE: 1.5429 27.00 BY: 9 .. 1' SCHOOL: 3390 GRADUATION SUMMARY FILE: SETS 21' 03/31'2008 CURRENT DISTRICT: 50 PALM BEACH PAGE 4 CURRENT SCHOOL: $390 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 COMPLETED- VOCATIONAL PROGRAM COMPLETION STATUS- NUMBER: 8301610 WORK RXP TERMINATION: IN PROGRESS COMPLETPD: VOCATIONAL PROGRAM COMPLETION STATUS- NUMBER: 8301650 WORK EXP-OJT TERMLNATLUN: IN PROGRESS COMPLETED: DISTRICT CLASS RANK- EFFECTIVE DATE: 03/06/2002 CLASS RANK, POSITLON: es CLASS RANK, PERCENTLLE: 70 CLASS RANK, TOTAL NUMBER IN CLASS: 214 DATE PASSED ASSESSMENT TEST FOR GRADUATION COMMUNICATIONS: 10/2001 MATHEMATICS: 01/2002 COMMUNLTY SERVICE HOURS: 0 REQUIREMENT MET: OFFICIAL TRANSCRIPT THE SCHOOL DISTRICT OF PALM BEACH COUNTY. FLORIDA APR 1 2008 RECORDS CUSTODIAN GIUFFRE004984 CONFIDENTIAL 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: 5390 SURVIVORS CHARTER SCHOOL LEGAL NAME: ROBERTS, VIRGINIA (561! 712"1000 DEFINITION OF TERM CODES CCDE DEFINITION CODE DEFINITION CODE DEFINITION CODE DEFINITION CODE DEFINITION 1 SEMESTER 1 COMBINED SUMMER TRIMESTER 1 QUINMESTER 1 SIX WEEKS 1 2 FEMESTER 2 SESSION TRIMESTER 2 OUINMESTER 2 SIX WEEKS 9 3 ANNUAL 1* THIMESTER 3 OUINMESTER 3 SIX WEEKS 3 4 SUMMER SESSION 1 INTERSESSION 2? 6 QUARTER 1 OUINMESTER 4 SIX WEEKS 4 5 SUMMER SESSTON 2 3' 7 QUARTER 2 i QUINMESTER 5 SIX WEEKS 5 SHORT INTERSESSION 4? 8 QUARTER 3 YEAR OF 0 SIX WEEKS 6 5' 9 QUARTER 4 USED OF SUMMER SCHOOL SESSIONS) WITH YEAR-ROUND SCHOOL RECORDKEEPING USED ONLY FOR WORKFORCE DEVELOPMENT EDUCATION GENERAL AND POSTSECONDARY VOCATIONAL EDUCATION) USED ONLY FOR REPORTING STUDENTS WHO HAVE WITHDRAWN BETWEEN SCHOOL YEARS STATE GRADING SCALE FOR HIGH SCHOOL STUDENTS (REGARDLESS OF 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 PRECEDING STATE GRADTNG SCALE. GIUFFRE004985 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page160 of 648 TC - DISTRICT: 0000050 SCHOOL: JJUO COMMENTS FILE: SRTSI2IS GRADE LEVEL: 13 PREPARED DATE: 03/31/2008 CURRENT DISTRICT: 50 PALM BEACH PAGE 0 CURRENT SCHOOL: 3393 SURVIVORS CHARTER SCHUOH LEGAL NAME: ROBERTS, (561} 712-1800 - - STATE DEFINED COURSE FLAGS SCHOLAR- ELECTIVE CRADER H-HONOPS CREDIT TN GPA FROM GPA PROM STATE CPA IS IN PROGRESS AWARDED BY SLEP EXAM T-TRANSFERRED COURSE COURSES- AIR PC SUB FOR 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 ALGEDRA 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 SCT 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 WEIGHTED GPA AVERAGE THAT IS BASED ON COURSES TAKEN IN GRADES 9 12. HOWEVER, THE DISTRICT GPA INCLUDES ALL CREDIT COURSES. GIUFFRE004986 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page161 of 648 CURRENT DISTRICT: bU PALM BEACH (561) 712-1800 03/07/2002 CODE: WES LANGUAGE SURVEY DATE: COUNTRY OF BIRTH: US UNITED STATES NATIVE LANGUAGE: EN ENGLISH PRIMARY HOME LANGUAGE: EN ENGLISH HEALTH EXAMINATION, SCHOOL ENTRY: SCHOOL ENTRY HEALTH EXAMINATION CERTIFIED. EXCEPTIONAL STUDENT INFORMATION S1UDENT PLAN DATE: 05/11/1999 CURRENT DATE: 05/11/2002 PRIMARY EXCEPTIONALITY: FEPP PROGRAM: EXCEITIONAL STUDENT PROGRAM INFORMATION EVALUATION PLACEMENT REFERRAL COMPLETE DETERM EXCEPTIONALITY STATUS DATE DATE DATE ELIGIBLE AND PLACED 05/10/99 05/11/99 05/11/99 ELIGIBLE AND PLACED 02/03/90 02/04/98 02/04/90 DROPOUT PREVENTION PROGRAM INFORMATION DROPOUT PREVENTION PROGRAM PLACEMENT REASONS OUTCOMES EDUCATIONAL ALTERNATIVE PROGRMS ACADEMICALLY UNSUCCESSFUL DOCUMNTD EDUCATIONAL ALTERNATIVE PROGRMS ACADEMICALLY DOCUMNTD EDUCATIONAL PROGRMS ACADEMICALLY UNSUCCESSPUL DOCUMNTD TEST . . 'l?FlS'l? lN FORMAT I 0N FC - DISTRICT: PALM BEACH SCHOOL: 3390 CATEGORY TNPOUMATION FILE: CURRENT SCHOOL: 3390 SURVIVORS CHARTER SCHUOL PAGE 7 PLACE- DISMLS- MENT SAL DATE 05/11/99 05/03/99 02/04/90 06/11/98 PER FCRMANCE ACADMC PERFORMANCE ACADMC PERFORMANCE TEST TEST LEVEL SUBJECT SCORE SCORE SUBJECT SCORE SCORE SUBJECT SCORE SCORE GRD DATE NAME POEM FONTENT TYPE TYPE CONTENT TYPE TYPE CONTENT TYPE TYPE 30 TAB 7 A TOTBAT GE 0000 GE 0000 GE 0000 LANGUAGE GE 0110 30 05/;5/2000 TAB 7 A GE 0000 GE 0000 CE 0126 LANGUAGE GE 0000 30 TAB 7 1UTUAT GE 0000 GE 0073 GE 0000 LANGUAGE GE 0000 09 04/20/1990 0T0 A 19 COMPREHE ss 0801 COMPREHE NP 0005 SS 0750 NP 0034 SCIENCE 35 0000 SCIENCE NP 0000 ss 0000 NP 0000 GIUFFREOO4987 CONHDENNAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page162 of 648 TO - DISTRICT: 0000050 PALM BEACH SCHOOL: 3390 TEST INFORMATION FILE: SRTSIQIS GRADE LEVEL: 10 PREPARED DATE: 03/31?2008 CURRENT DISTRICT: 50 PALM BEACH PAGE 0 OF 8 CURRENT SCHOOL: 3390 SURVIVORS CHARTER SCHOOL LEGAL NAME: ROBERTS, VIRGINIA (561) 712~1800 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 CTB 17 VOCAH NP 0000 SS 0790 NP 0070 05 04/22/1994 CTB 15 COMPREHE SS 0700 COMPREHE NP 0032 SS 0667 NP 0010 LANGUAGE SS 0694 LANGUAGE NP 0026 SS 0646 NP 0008 SS 0742 05 04/22/1991 CTR 15 up 0061 on 03/29/1993 CTB A 14 SS 0711 NP 0059 ss 0668 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 55 0707 SCIENCE NP 0049 ss 0692 NP 0034 04 02/10/1993 WAP 04 wn SS 0000 WR EXPOS as 0000 WRITING SS 0000 03 04/00/1992 CTB A 13 COMPREHE ss 0733 COMPREHE NP 0085 ss 0649 NP 0026 LANGUAGE 55 0696 LANGUAGE NP 0050 SS 0679 NP 0044 SS 0712 01 04/09/1902 CTR A 11 NP 0055 02 01/16/1991 CTD A 12 ss 0663 NP 0000 ss 0467 NP 0001 COMPREHE 55 0659 COMPREHE NP 0051 COMPUTAT SS 033? COMPUTAT NP 0001 VDCAB SS 0667 02 era A 12 VOCAB NP 0070 ss 0597 HP 002% ml) OF GIUFFRE004988 CONHDENUAL 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 23 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 Case 18-2868, Document 278, 08/09/2019, 2628230, Page169 of 648 Video Deposition of Tony Figueroa (Volume 1) 24 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? 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 Do you know if Wellington has an adult program? 4 5 26 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 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. 29 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 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 4 126 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 Case 18-2868, Document 278, 08/09/2019, 2628230, Page178 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 2 144 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 Case 18-2868, Document 278, 08/09/2019, 2628230, Page179 of 648 Video Deposition of Tony Figueroa (Volume 1) 145 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 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, Document 278, 08/09/2019, 2628230, Page181 of 648 Video Deposition of Tony Figueroa (Volume 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 $JUHQ %ODQGR &RXUW 5HSRUWLQJ 9LGHR ,QF Case 18-2868, Document 278, 08/09/2019, 2628230, Page184 of 648 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS __________________________________________________ CONFIDENTIAL VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II November 14, 2016 __________________________________________________ VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. __________________________________________________ APPEARANCES: BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff 9,5*,1,$ *,8))5( 92/80( ,, $JUHQ %ODQGR &RXUW 5HSRUWLQJ 9LGHR ,QF Case 18-2868, Document 278, 08/09/2019, 2628230, Page185 of 648 1 2 3 4 5 6 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura Menninger, Esq. Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant 7 8 Also Present: Ann Lundberg, Paralegal Maryvonne Tompkins, Videographer 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 9,5*,1,$ *,8))5( 92/80( ,, $JUHQ %ODQGR &RXUW 5HSRUWLQJ 9LGHR ,QF Case 18-2868, Document 278, 08/09/2019, 2628230, Page186 of 648 1 Pursuant to Notice and the Federal Rules 2 of Civil Procedure, the continued video 3 deposition of VIRGINIA GIUFFRE, called by Defendant, 4 was taken on Monday, November 14, 2016, commencing at 5 8:04 a.m., at 150 East 10th Avenue, Denver, Colorado, 6 before Pamela J. Hansen, Registered Professional 7 Reporter, Certified Realtime Reporter and Notary 8 Public within Colorado. 9 * * * * * * * I N D E X 10 11 VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II 12 EXAMINATION 13 By Ms. Menninger PAGE 354 14 15 16 17 18 19 20 21 22 23 24 25 9,5*,1,$ *,8))5( 92/80( ,, $JUHQ %ODQGR &RXUW 5HSRUWLQJ 9LGHR ,QF Case 18-2868, Document 278, 08/09/2019, 2628230, Page187 of 648 1 INDEX OF EXHIBITS (continued) 2 INITIAL REFERENCE 3 DESCRIPTION 4 Exhibit 1 Settlement Agreement and General Release 355 Exhibit 2 List of names 370 Exhibit 3 Photocopy of photograph 408 Exhibit 4 Photocopy of photograph, with attachments 411 Exhibit 5 Photocopy of photograph, with attachments 417 Exhibit 6 Photocopy of photograph, with attachments 423 12 Exhibit 7 Statements 437 13 Exhibit 8 History of education, with attachment 462 Exhibit 9 Application for Employment, with attachment 474 Exhibit 10 The Great Outdoors Community Services Association, Inc. Termination Form, with attachments 481 Exhibit 11 7/6/2016 letter to Schultz from Hayek, with attachments 484 Exhibit 12 Patient Registration Information, with attachments 490 Exhibit 13 CVS Prescription Records document, 7/29/2016, with attachment 502 Exhibit 14 Affidavit of Custodian of Records, Walgreen Company, with attachments 507 5 6 7 8 9 10 11 14 15 16 17 18 19 20 21 22 23 24 25 9,5*,1,$ *,8))5( 92/80( ,, $JUHQ %ODQGR &RXUW 5HSRUWLQJ 9LGHR ,QF Case 18-2868, Document 278, 08/09/2019, 2628230, Page188 of 648 1 INITIAL REFERENCE DESCRIPTION 2 Exhibit 15 Patient Health Summary, Clifton Beach Medical & Surgical, printed on 6/28/2016 512 Exhibit 16 Portions of deposition transcript of Virginia Giuffre taken May 3, 2016 533 Exhibit 17 Amendment/Errata Sheet signed May 31, 2016 by Virginia Giuffre 540 8 Exhibit 18 Ad for Mar-a-Lago Club 548 9 Exhibit 19 The Mar-a-Lago Club, L.C. Employment Policies, October 28, 1995 549 Exhibit 20 Page from the Mar-a-Lago Club Employment Policies, Revised 10/2001 550 3 4 5 6 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 9,5*,1,$ *,8))5( 92/80( ,, $JUHQ %ODQGR &RXUW 5HSRUWLQJ 9LGHR ,QF Case 18-2868, Document 278, 08/09/2019, 2628230, Page189 of 648 1 A Yes. 2 Q And you believe the Neiman Marcus was 3 4 located in which city? A Well, it's around Fort Lauderdale. 5 can't tell you exactly. 6 like Broward County? I Fort Lauderdale is so big, Is that the word for it? 7 Q And what did you do at Neiman Marcus? 8 A I worked in the changing rooms. 9 Q And what did you do in the changing room? 10 A I think I just like -- if I remember 11 right, I just put clothes away that people left in 12 there. 13 sizes for women who wanted different sizes of the 14 same product. 15 16 Q Probably went out to get sizes, different And where did you work after Neiman Marcus? 17 A Taco Bell. 18 Q Did you work at Southeast Employee 19 20 Management Company? A I don't recognize that. I don't know if 21 that's a payroll company or what it is. 22 what Southeast -- what is it called? I don't know 23 Q Southeast Employee Management Company. 24 A No, I don't remember that. 25 Q Did you ever work as a temp? 9,5*,1,$ *,8))5( 92/80( ,, $JUHQ %ODQGR &RXUW 5HSRUWLQJ 9LGHR ,QF Case 18-2868, Document 278, 08/09/2019, 2628230, Page190 of 648 1 A Not that I remember. 2 Q Going to different offices and filling in? 3 A No. 4 Q Did you work for Oasis Outsourcing? 5 A I don't -- I don't know if that's a 6 payroll company or if that's an actual place, but 7 that doesn't ring a bell. 8 9 10 11 Q Did you -- do you know how much you got paid when you were working at places like Oasis Outsourcing? A Well, considering I don't know if I worked 12 at Oasis Outsourcing, I wouldn't even know how much I 13 got paid. 14 15 Q Did you review your Social Security records? 16 A Yes. 17 Q You saw Oasis Outsourcing listed there? 18 A Right, but like I said, it doesn't even 19 20 21 22 ding a bell at all. Q Do you know how much money they said you made from them? MS. MCCAWLEY: Objection. If you want to 23 show her the documents, she can see what amount is 24 listed and answer your questions, but if you're not 25 going to show her the document, that's the best she 9,5*,1,$ *,8))5( 92/80( ,, $JUHQ %ODQGR &RXUW 5HSRUWLQJ 9LGHR ,QF Case 18-2868, Document 278, 08/09/2019, 2628230, Page191 of 648 1 don't know where I was living. 2 3 Q Okay. Did you indicate whether you had gone to school? 4 A Yes, I did. 5 Q What did you indicate? 6 A I indicated that I attended Survivors 7 Charter School for four years and had a high school 8 diploma. 9 Q And you graduated? 10 A Well, I didn't. I just wanted to get a 11 job, and I wanted it to look good, so I fluffed it 12 up. 13 14 Q So you wrote that down in your handwriting on this application, correct? 15 A I did. 16 Q And it was not true, correct? 17 A Again, I'm not proud of it. I just didn't 18 have any other way of getting a job and I just 19 thought if I put that down there, I might be 20 considered. 21 Q You indicated when you were younger you 22 volunteered for six years at a riding clinic. 23 the name of the riding clinic? 24 25 A Vince Ramos. What's And I'm not too sure if it was six years, but I started off there quite young, 9,5*,1,$ *,8))5( 92/80( ,, $JUHQ %ODQGR &RXUW 5HSRUWLQJ 9LGHR ,QF Case 18-2868, Document 278, 08/09/2019, 2628230, Page192 of 648 1 a former employer is the Indigo Bar and Grill, 2 correct? 3 A Yes. 4 Q Is that true? 5 A No, it was not. 6 Q On the page before that, it indicates you 7 went to Royal Palm Beach High School. 8 your handwriting? Is that in 9 A Yes, it is. 10 Q And it says you went for four years and 11 you graduated? 12 A Yes. 13 Q In your handwriting? 14 A Yes. 15 Q Is that true? 16 A No. 17 Q This was an application you filled out in 18 January of 2014, correct? 19 A Correct. 20 Q The page before that is your -- portion of 21 your resume I think we have previously discussed, but 22 just confirming, you did send that resume to this job 23 application, correct? 24 A I did. 25 Q And you indicated you had worked at 9,5*,1,$ *,8))5( 92/80( ,, $JUHQ %ODQGR &RXUW 5HSRUWLQJ 9LGHR ,QF Case 18-2868, Document 278, 08/09/2019, 2628230, Page193 of 648 1 STATE OF COLORADO) 2 ) 3 COUNTY OF DENVER ) 4 ss. REPORTER'S CERTIFICATE I, Pamela J. Hansen, do hereby certify that 5 I am a Registered Professional Reporter and Notary 6 Public within the State of Colorado; that previous to 7 the commencement of the examination, the deponent was 8 duly sworn to testify to the truth. 9 I further certify that this deposition was 10 taken in shorthand by me at the time and place herein 11 set forth, that it was thereafter reduced to 12 typewritten form, and that the foregoing constitutes 13 a true and correct transcript. 14 I further certify that I am not related to, 15 employed by, nor of counsel for any of the parties or 16 attorneys herein, nor otherwise interested in the 17 result of the within action. 18 19 20 In witness whereof, I have affixed my signature this 23rd day of November, 2016. My commission expires September 3, 2018. 21 22 23 _______________________________ Pamela J. Hansen, CRR, RPR, RMR 216 - 16th Street, Suite 600 Denver, Colorado 80202 24 25 9,5*,1,$ *,8))5( 92/80( ,, 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 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 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 EURR 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 IST 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 Case 18-2868, Document 278, 08/09/2019, 2628230, Page202 of 648 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 {13,54,554 m. PA LM BEACH. VLDRIDA 1100 South Ocean Bt'miexxm?l, Palm Beach, ?orid; 3,4930 46373 5332608 Fax (407) 832265.469 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 UNITED STATES DISTRICT COURT 1 for the Southern District of New York 2 3 Civil Action No. 15-cv-07433-RWS 4 VIRGINIA GIUFFRE, 5 Plaintiff, 6 vs. 7 GHISLAINE MAXWELL, 8 Defendant. 9 10 ----------------------------------------------------VIDEO-DEPOSITION Sky Roberts OF: 11 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 12 13 14 17 18 19 20 Attorney for Defendant 21 Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, 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 Case 18-2868, Document 278, 08/09/2019, 2628230, Page222 of 648 1 2 I N D E X 2 PAGE WITNESS: 3 Sky Roberts 4 Direct Examination by Ms. Menninger 4 5 Cross-Examination by Mr. Edwards 133 6 Redirect Examination by Ms. Menninger Recross-Examination by Mr. Edwards 135 141 7 8 Reporter's Certificate Certificate of Oath 143 144 9 10 - - - 11 12 E X H I B I T S 13 14 15 16 17 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 18 19 (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. You 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 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 Case 18-2868, Document 278, 08/09/2019, 2628230, Page230 of 648 1 144 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, Page241 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 PROCEDURLS: 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: 9) 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: 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, Page281 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 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 . .. . 3.9. .. . .-. nu ?nus-00 :Sq_0_l.L? - inn swe? com: I new?; . ?n?Ef-E?gfiey {Limif I I J'Tvugz- 'r EMPLOYMENT DESIRED CN DATE you CAN sun DESIRED 000.00: 0 ELL I I Im?INQUIRE 12?? I OF YOUR PRESENT 22! "3 r0 - i was coumwasroaco I '55 ?0 - HISTORY NAME Locmou OF SCHOOL ?1%ng 0&(032357 sumcc IS mums i I . GRAMMAR SCHOOL SCHOOL 30\x?vt I i 3 3 WW ??04 COLLEGE i i i . - TRADE. BLSINESS OR . I CORHFSI SCHOOL 1 I GENERAL INFORMATION 5- 50F STUDY-RESEARCH WORK OR SPECIAL NC"Lnbc-u 310-0; I uii?V-mn ?x 00? ?.03 33009011 615" 1.1.9.3 ?21 HXKC A (LY 3 CR 5 5 VFVAI SLRV CL- .. I FORMER EMPLOYERS LAST FOUR EMPLOVERS, STARTING WITH LAST ONE IE?bI??i?vun NAME 6. ADDRESS OF EMPLOYER posmou 2 REASON FOR LEAVING 1W . bin/L" -- . 4- 022FROAM 'hw i TO . I): 2's. [1+9 ?1 (MM [v akLu?gSJ I 'wom ?b'u:5ch LEO L, A) Kern-2Q} i) i CAdams 9661 :4 MR APPLICATION FOR MPLOYMENT ?g BLyuoyypogmc 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 BUSINESS $5353?? I . v? ?t A ?own .?vv's? on'v?m 5 (?remade-?v- 1 I . 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 app'ication shall be grounds for dismissal. I authorize investigation of all statements contained herein and the reterencee and employers listed above to g.ve you any and all intormatton concerning my previous employment and any pertinent inlormation they may have. personal or otherwise. and release the company from al: liability for any damage that may result 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 eral and state lawsSIGNATURE \i OLW x) .R 7 DATE DO NOT WRITE BELOW THIS LINE REMARKS .. r7 ?7 1711" . . -. r: .- Vii iiFQLiL?Irilis genial. remit? Gleam - meme magma? Q-LAQKQ l?gku-?s?tg?t?e?. . Evie): Wham Easy: (Mg; I in EEK) ME amass CHARACTER - Inert}? . 3. . meg: ?Fon wosmom lwru. SALARY DEPT, REPORT WAGES i APPROVED 1. 2 3. . we. ?rem inmate new uENtmL MANAGER l" apparaliou 'or encloymem is sold only tor general'uae throughout the Limbo States Adams assumes no and "crew (?claims 80?; ?1'90? war at any cuatlan: or requests for "normal-m upon much a Violation at local state and/(x tuderal law may be based. is the user's to ersure that this tom's use c011- r; my amicable laws. which dunge from time to line. .-. .- Case 18-2868, Document 278, 08/09/2019, 2628230, PageBO3 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 8/12/69 - 1/29/03 I Total Inflows Total Outflows Net Total GIUFFREWSZO3 CONFIDENTIAL 2 Case 18-2868, Document 278, 08/09/2019, 2628230, Page304 of 648 Moriday, November 7, 2016 I Page: 2 1Quicken Data - All 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 I259.27 GIUFFREOW CONFIDEN Case 18-2868, Document 278, 08/09/2019, 2628230, PageBO5 of 648 Monday, November 7. 2016 Page: 1 IQuicken Data - Ail 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 - $07.50 5/6/02 Courtyard Animai Hospitai 1523 Virginia Roberts Salary ?472.50 5/20/02 Courtyard Animal Hospital 1541 Virginia Roberts Salary 699.75 6/4/02 Courtyard Animal; Hospital 1555 Virginia Roberts Salary -1 82.00 Totai Salary I I -1 561.75 Taxes: 5 . . 4/22/02 Courtyard Animal Hospital 1500 Virginia Roberts Taxes:Sociai security - 38.82 5/6/ 02 Courtyard Animal Hospital 1523 Virginia Roberts Taxes;Sociai security 36.15 5/20/02 Courtyard Animal Hospital 1541 Virginia Roberts Taxes:Social security 30.59. 6/4/02 Courtyard Animal Hospital 1555 Virginia Roberts Taxes:$ocial security 13.92 Total Social security 119.43 I 155' i l' 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 Heapital 1555 Virginia Roberts 12.00 Totai Withoiding 173.00 Totai Taxes 29 2.43 5/6/02 Courtyard Animal Hospital Total Expenses - Other Totai Expenses Total lncome/Expenses ?1522 VOiDvirginia Roberts 0.00 0.00 -1 269.2 ~1,269.27 olurmeooszos CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, of 648 Aprii 2002 Payroli Paycheck 1 Paycheck 2 Paycheck 3 Tatai Sociat Security - a m. . Withholding - - .- Social Security - W?thholding gs 5; a Soc?ai Security 3 - - - Withhoiding 3; - - g? - Sccial Security 5 a 3 .: - 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! 0 ?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 Withhniding 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 1 Paycheck 2 Paycheck 3 C: tal Saiary Social Security Withholding Salaiy Social Withhciding wwmmawmen Salary Social Security Withholding - Ml Jenna Salary Social Security Withholding 132.00. . 13.92 - 12.00 - 182.00 13.92 Saiary Social Security Withholding Totais Salary 7. Social Security Withholding Totai Liability as 12.00 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 85,23/280. 13:12 3055533363 GLLEN we: CL Fa'm '4 (2001) pm. leuMW.Mwm hm tow-u. am tor mm 0mm.mmwmudmm. Two-mm" Mow-um cum ?:me wamww . new Mmaymm mummy. Motown myoammnwuvmm W4. 1? ?mmzx'm m? ?pm: . . no um - ?guru Pwlovdmon Marmot-an 1wh'mw?9. 3003. dewu WM-9910?m??m' mung 010mm Clean cud or my?! on having ulnhoc g. to mmtouwuzoovou .919 mm oom- mowumu mwmnoumtum- ?mes-?wanna. (Mm?a. Mom-Monumwm: mummwnuowz'qyourom'cwm vim-(hm mum? i mm ?cm band on Hum-d Nmohcoa-Jyouhnosluoo Hunt-a. 3m!? roam. mum-rm to mnwmim??q Aunt-w cram. ?(mum Imam-smglo and mm onwonopb; or a Emor?'Emu?? 0 child Tu Crud! Oncludhg wdlional chic tax erod?): ?vanadium, mm 0mm. 0!.an 'S'Nyouhmlvoumwbu alum. o? anthem ?km ??me MMNM- ?4 Employee?s Withhoidlng Allowance Certi?cate m~w?m Damn Act-nu a. Lam-m (A {Tnhu 3 Iman Dumwmumwm mnmumwmmummudngzu lemum.mzp gm} :1 . . oThb youloxpoctlm'undofallhdud momhanhmubocnuulupocno hwonotulinbu wmo'Exompt'm . . . . . 533.23%; -31.. m> 0 0 0m ?5 mummnm For accuser. compbto m1 Wat: that may. sun-0100200 CONFDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, PageBH 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 .. GIUFFRE009211 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 an: L. sweet-aw, SHERIFF Case 18-2868, Document 278, 08/09/2019, 2628230, Page316 of 648 EXHIBIT cument 2628230, Page317 of 648 CAUSE AFFIDAVIT 1. 3. Request Ior Warrant Juvenile 2.N titan-snore.? OBTS Numw . . 1 Agency ORI Number Agncy Nome ?0502800 YALP DEP ENT 993046 crime was: as "my 1. Felony 3. Misdemeanor 5. Ordnance '3 2. Traffic Felony 4. Traf?c Mledemeenor Other ONY 0F MARIJUANA OVER 20 GRAMS WITH INTENT TO SELL Charge Dew $635 OF DRUG PARAPHERNALIA 0F CONTROLLED SUBSTANCE TATE 0 A Local Address (Street. Apt, Number) ADMIN. CHARGES DEF. VICTIM Bus nose Address (N amo. Street) no email The Person taken into custody . committed the beiow acts In my presence. woe observed by confessed to admitting to the below facts. Onthe 191? daon? NOVEMBER 19.93:: who told that holshe saw the arrested person oommlt the below acts. we: found to have committed the below acts. matting from my (described) Investigation. MI. 8 PM. (Speci?cally Include facts constituting cause for mom THE ROYAL PALM BEACH POLICE DEPARTMENT WITH MUTUAL AID RTH POLICE DE PROBABLE A LARG A 00 MARIJU of the in my ottice wit ns, DEPUTY CLE swonu AND suascmaeo espoae ME NOTARY PUBLIC I OF COUEI OFFICER 11-19-99 DATE ADMINISTRATIVE 11-19-99 DATE PINK Agency DISTRIBUTION: WHITE - Court Copy GREEN Attorney Agency Case 18-286 Document 278, 08/09/2019, 2628230, Page318 of 648 oaT? mm PROBABLE CAUSE AFFIDAVIT 1.Arr 3.RoquesttorWanmt mm I'll] ll 1 i womm Poonch-m Money Row: Eruol5lol2.8.0.0 ROYALPALMBEACHPOUCEDEPARTMENT 3.5 Ill . ll mum 1. Polony 3. mam-.m- sol-drum . 2. Tram Felony 4. Tri?e Modem e, on?; Humanism. Midas Alias Rae. Sex :2 igueroa, Anthony 8 2 MW Chara-Mien . Poss. marijuana over 20 gms. Poss. intent to sell MW . Ch Datamation Poss. of Drug Paraphernaha Poss. of Controlled Substance (MDMA) Vidht't Mn. thMiddlo) Rae. 80x DI. 3 Elm StateOf lori a I Loalmuatsnd. Autumn) (my) TsElo) (zip) Phone Adam-cam- 5 BulnmAddreu(Nm.5lreat) (City) (State) (zip) Phone Ooalpdlon ??Tho undetalmod outflo- and two that helm has just and roaconablo mum to boiove, and does bellow mat the above mTa'Dd-mm mm the lollowing violation oflaw. Tho Pomon taken Noam committed the hem acts In my presence. was observed by who told confessed to that he/she saw the arrested person commlt the below acts. was found to have committed the below acts. resulting from my (deserted) investigation. admitting to the below facts. On the day of April 2000 19 a AM. 8 PM. (Speci?cally Include facts constituting cause for arrest.) PROBABLE CAUSE On 04-13 -00, I received from Evidence Custodian Fanelli, 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. :5 This amended probable cause was sent to Debra Colton for charge purposes. Nothing further. 6 i 0. nuts or FLORIDA - FALM BEACH COUNTY ?lef?bv cedily that the ioregoing ls_La_ . 1.. .. uuzwun 1r. yol th- a 0d (?Elm law.? A "firstDEPUTY fficer George Searing 101 3 04-1 7-2000 we or OFFICER (PLEASE PRINT) PAGE one 04-17-2000 DATE 1 1 1 AA UILLH- . . Case 18-2868, 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 1% ISSUE WARRANT ,3 vs. 0233 5 - ANTHONY LUIS FIGUEROA, 32:53 .r - "<3:va . SO: I INFORMATION FOR: ?:13 l) POSSESSION OF SCHEDULE I SUBSTANCE gfi? '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 ofFlorida, 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 STATE OF FLORIDA COUNTY OF PALM BEACH . Case 18-2868, Document 278, 08/09/2019, 2628230, PageB20 of 648 9 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 so. I I Assistant State Attorney Sworn to and subscribed to before me this 2: day of 2000. Citation Nos. (if applicable) SA XZM- {gal/May NOTARY PUBLIC, State orF?iorida iin?jll .ii- ?its. up! assassins instant amass 55? [Eli spat its, ig. . - I .. w?mimnntinmimm? . STATE FLORIDA - PALM BEACH COUNTY I hereby certify that the foregoing is a A Allirecord in my ethos WI ?isTsis it- so ii .2 0 r77; ;7 . COMPTROLLER Eli DEPUTY CLERK 226 Case 18-2868, Document 278, 08/09/2019, 2628230, Page321 of 648 IN THE CIR.T COURT or THE FIFTEENTH JUDICIAL CIRCUIT. IN AND FOR PALM BEACH COUNTY.- FLORIDA SENTENCE (Probation ommunity Control Violator] (As to Count(s) I Defendant A Case Number GETS Number Wt BEES my Within: scenic. I . Bite-gm a COUNTY couaTs Ffing personally before this Court. accompanied by the of d, Or I w?r {fl?1V! . 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, and to show cause why defendant should not be sentenced as provided by law, and no cause being shown, and the Court having placed the Defendant on probation/community control and having subsequently revoked the Defendant?s probation/ community control for violation[s) of condition(s] 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 fine 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 Palm_Beach 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 appeal more upon showing of indigency. kna?i?y?f I hereby certify that 1h?- 10r93?3'i'j3 is?? . DONE AND r, . cabi??fe?t??lu ?Walm Etch County, Florida this @7 2! i .. 3 tionsj - ARON a. so (rev. 12/98) . cmcurr cover JUDGE 7 DEPUTY CLERK EDWARD A. GAHHISON . Case 18-2868 Document 278, 08/09/2019, 2628230, Page322 of 648 IN THE CIRCUIT COURT 0.5 JUDICIAL CIRCUIT OF FLORIDA, IN PALM BEACH COUNTY use Ll 3 7 CF 401, V0 09~455611 62 DOROTHY ll. HILKEN 9 984 CLERK PB FL Insolence-'IIr-nnrlin STATE OF FLORIDA 1 COMMUNITY CONTROL VIOLATOR V. . PROBATION VIOLATOR EFEND I LE The above represented by r. APD (attorney) CIRCUIT 8; COURTS I Having been tried and found guilty of the following crime(s): Having entered a plea of guilty to the Having entered a plea of nolo following crime(s): contendere to the following crime(s): COUNT CRIME or ENSE STATUTE NUMBERISJ DEGREE CASE oars 3 NUMBER NUMBER . L201) I and no cause having been shown why the Defendant should not be adjudicated guilty, 1T IS ORDERED THAT the Defendant is hereby ADJUDICATED GUILTY of the above crime(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 insection 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 Defendant 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 ANQ qantust Beach County, Florida mu 2? day or UL212 296130 clef- . . thereby Lt??illy thattno taregmng Is'a 5- true py of the record in my office with 1% . . - :a tions. v, 'red CIRCUIT COURT r3 C?Jr?pl CL Gm?01228 av 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, PageB25 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 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: CMS301L 1~01-003008 (Continued) Ethnic Origin WHITE Height . . . . 511 Weight . . . . 160 - A A I Original Report Reported By: LLEWELLYN, CRAIG R. 8/03/01 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 MISSING MONEY, 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 TO ATRUECOPY RIC BRADSHAW, SHERIFF Case 18-2868, Document 278, 08/09/2019, 2628230, PageB27 of 648 EXHIBIT AA - 278, 08/09/2019, 2628230, Page328 of 648 Page 1 of2 A A I I 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: 0 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 - Viewix?m? M8585 dent 278, 08/09/2019, 2628230, Page329 of 648 Page 2 of2 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 . Make Auuall Punt-unwartuml Arrival Mlle: Fll?u Number Alter-? 19% and Mode' Flam No Maneuvers. Endmmonu '2 MV From yes 36363 i 7 2A Tc,? QB v.PEI T613 Laz?m??g?. L-ua?wnmw? 1 2m 14?6 c?yni3'6, as I 61 135? I (5 ?2 3 .. fig; 1&8 1m acgmeipzm - 3?6. Scowx 3 LBIif? (>61 1E6 131?66 P?f_ ?fic??mm? DR, 001? 1'0 PM sup -1, mace/cg!) 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Anlval Mira Flinn! Remarks, Procedures. . Numbe? Alicral'l 9 _..and Cl: .991. and Mode Henliboaucn Mam Hun-n No Maneuvers, Endorsements A in APR I Horn Tu BER _r 31am? ?11 - f4 - 1C1 OBI 1?68 5?55'93 830 3?4" r4218?) New) 9.45009? 2?4 1 *Ezzaw?aawwm?smm?v . $91 sgiuwea?-Jsgq .wng? :1 WL . . 3 [33% ijb??gg". 3 -399..- 4533 5" - U4 A 8314 Se, Pram,? Sam?! on ML mwbw?xflo?rjj/ Lace; 1520?? 11.5 8373b1bm' {019(11wa szre 0? -Qf; 312-, on, 1 ?if" 'u m, . 31$; @?Hd 60/03/95, I ?zmpt? PM mi 7W 4' #126; _s 89!. .19sonny Iha! Iha statamwls mndo tv/ me an lh'G lo'm are ane. kg 8V9 JO 888959c ?0888898 ?818 939C) Altman Mat? Um?1 Aircraft Points olDoparluro?Arrlval Miles Flight Renurku, Procedures. INumbm Aircraft en and Model ldenlilimuon Mark Fawn Nu Maneuvers. Endorse-unis I Er 2 Class From I '0 - 7G '39?gnsq6 mom Tee 9531 an 36 1 2 a E: 351:4 16f?) 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[qu8 7 ll_ iv; 511, PSI ma?a/GM 1 \1 PB j: .T66 \o 3?s; hea?mc MRNN 1/ Q. 01 Iocmry thalme (Hs 10m aw hue. Page Tolal Ila/?15 50 q, Amounl Forward qb 1003 Pulct?s szgnatue EGUM ,?Jg 8W0 gaff; "IDsq 3 74 I 1, 817940 8178959c ?0888898 ?818 939C) (?1398- :lg?mako Pom? o. Doparlurol. Eight Number Altar." . me T9 o'lJmi-my . \flJ INC?oggx-? Tag Plat: seem/sigma ?mat! 63:13; I i 1w? cam Worm .- ?zva?o ma A1209?166 ?61; 7; T60 \otxg?z' EMMY 10ceL?1~ff?_ _1 7 T66 1" 3:3: \wi?s?'sfy?z?swm Eggs12, LVN?N'??fze?(Naggcm? EM: mm mm Whalin? AR 000015 2A (X 0?83? 1_ 96 1: T63 ?(om ?10 Tags 2 3 I 23.? 1 - o$o 3'39E (?61 WE ET 3 o_ ?tiL?H - . I T66 (032 J??noe ?9155555? 8 ca 79(31- ?353:4: Gm.(051331 GM.323 manpmsoemu Oua?: 7 ll lconifyummastatementgmadamma anthisfom nromza. Vb 9. 1 Pagonul I - Arm-IIFomayd - 1 I plums Slmalm? gq?q?i? 7 05 q? :5 to Data L?s-n 1?qs i 817940 8178959c ?0888898 ?818 939C) ma Aircrn? 19_1 Idenl?lnatlm Mark From GHSQ ea c:r (-5 as \l leen?ylhumomlsmenls madebyrnoonl?aiommlmo. 3 s?gn?mm Point: at Dammit: a Anival Hues No. Numhu About! of Landing on ex, WMET, 5r. ,Gn,er Fan new? - (3M, Page 1am Arnoum Fommd ?In. In Dal. FIDENTIAL 89888 9390 i 1uewnoog 8179 40 1778959d i Alrul? Make Nm? Point- at comma. l. Ann-I We: 19_ 1 and ?odd ldm??m?on Mam ?own No Pram Gusq 6Pilm?s Signature 5.7, 3mm, 1, ?sewers W17 3C4, I 0M, ewe? I Page lull Amoum Forwad 'nml to [1th ONFIDENTIAL ?818 939C) 6 -1 0888898 8179 40 gvse?ed 89888 9?390 Date Aim'l thaw-I Miss 1 Flt-9:1;le 0% "a LHS FIDENTIAL Li), ?4/914: 1 - . 391??) [e I .033 mini; 74 \l . \l 75044119391135 . vo - I 6-. W?s; 095 51' {5 16m new? ops. comfy that the statement made by me on hlsiorm are line. Page 11ml Amount Forum! Hm: ?anking) 9" . 8179 33/ . Mann Mam Altman L. and was ldan??callon Mart I From To 0% 61 EB - - T66 399Dev-nun a. mum VI mm WCQW WM WW Tohl Io Dab ON FIDENTIAL -- -- .-IV .. 989:) 8?79 ?0888892 luewnooa 05 Autumn Make Airman Poms ol Donna: A Anival We. 131!? and Modd Imam-non Man No3086M 8 CH1 '1 cg FIDENTIAL 9. \r v) 13 \5?16 (108.04?15331certify cm the untamed: made by ms on ml: loan are true Page Total 1 I Plot'ssiamliwe?) (QWLCA 989:) gig luewnood i 98 6 8?79 409?78959d 08388 v5? Point: 0! Dan-ml. I. AnlvnI Malta Alum-all Flam . 0(me From To 3 IS (Lam Ham. umuvmzu 96 CELL FIDENTIAL f5 - (3mm 15?) I ?and, m6: . ?e . UAW- m1?. (9M. Um? ?31;wa e, ya 9 66 HENRY osamy I unity that the mums-ms made by me on we fovm are In. Page Tum 2 I Amounl Forward aw. Nahum": (11 I Ad?l '9 foul on. 8?79 40 678959d ?0888898 ?818 1U9LUHOOG 9390 Du Almanac ?le nudMorhl H55 N-neme \canny ma! Ihe stamens made Dy me on this form an true. .. 4ng Pohls a! Doom-Inn Arvin! TD OKL 6 C6 HOU COS Mien Flu? Rom No. Seem Fermi-2 (?Sb OW ?cu rum? 6 W03 uaR ?Mums, Wyl- E-sx-Luac ?smw- (:15 man one ?at, Amounl Forum Yul-I In on. IDE NTIAL 89888 9390 8?79 40 0989598 ?9181U9wn0001 Daz- Amt! Make Mlea Fight Nunbet uncut ., mm. Eudora-moll- a! Landings - n, MN, R0 mews $10wa '5390 (3:415 GMT Cr C. ?3 GM mm 7am.? 2A 162-5 0691?: Isuzu!"? 13" 1. ?31. . IGH madebymeonll?hfomarem m-u? a I), TM .0 FIDENTIAL 898881?9393 8?79 40 L98959d ?0838893 1' ET 36,600, Gt, cum n, T, .9an Mani ldonli'hn?on Ma?l Points 0' Don-?ue Arrival me T6379 T3331 To 3 I 1. sec: 0104537! a?lrru?o rm 7. 1/ OIL. e,e 3? Gvawocuw 694'; I 5r (4M1 Cun?'cw a car ?3 At?fa?, (92E (Ma?a, (x 0mm mew AmnFome to 3.1. FIDENTIAL ?6 Loam/807mg luewnooa 9390 0878898 8179 ,to 898959d w-J; 919m, Page Tow Amount Fomard Airman Man Moran pom- .0 a. mum mun-n [9 andMoml Imam Mam 0d From To Sq 64?5? qo?bsG {5&9 9W3 650 Tag +Wasnm .1 0? Tee; OLD 3a, (4.OCR P?r 644,21117:6 56 SQMIZ: \q .. pg; 1- - 3a, seam 61.0014: 1! ?e ?9 2% (7 (.360 T66 3(9) DLQR 3 .13. .-.. .. 17:3 .- .(Jgf eeqc ?t T66 No Wm?99.31 ?5:60: ?59 .. ?[ui 36,65 Cme MAL, hammers 2.. i 5' ,3 (38 1: mun, ex, mamas ?0 -. PB: cm? 3G. Gina-13904 u, c; [Mk 1&Nqoaem 0 IA ?5 Total to Dan 939C) 1? ONFIDENTIAL 40 8999598 Arum: ldanl?laulun Mm =run~ . :3 2, that: MP PilorsSignatuI-Q) CLOTJ Mag/by Folds of Donna. I Anlnl We: anm Fiawn No 1 v" LYNN 732?. mama; at 80915561 din Lb?'cm 8er Se em . 0169423 Sb"- 0&7?739 .54; cw tune MANIIHOI "a Page Total Amoum Focward mm to Date FIDENTIAL ?0888898 ?8181U9wn000 939C) 8179 ,to vgse?ed - . ?ml Make Ind Model Flam 20965 . \l (746% - as a? l (21636 \a '1 mama: \l H, G73 I 6 2,01 (2?1 5a? L1 00 Flora [aka/6&4, Points 01 Bop-nun A Arrival To I. SH Mk: high: mm. .1 i? ?uAr} Maneuver; 19-; 5? Mi: "b ,Grn, Launc- s. um {thm I ommd ,1 PawTotal AmmFomm Total to on. I FIDENTIAL 89?88-91 9390 97?940 Alma! um Alraa? Point- 00 Bop-Mo I Annual and Model Mam lob L3 00 OCT 61:67, 6.53 Fun: To 5'00 2-86 . 0(5 {b "24$ MP Ioonlfy?ullhe ahlomnlanude by moon Irds 7~ . ?lbt's mum nagd,61g~7, Hunter of mm CO W85 03001 Page m1 Mount meard Tom to on. Alma NFIDENTIAL ?0888898 ?81? lueumooc] 939C) 8179 40 999952d DIR Airman Make Palm: 0' DOW l. Mlval Mllos Numbu Category? and Made! ?own No. Ind-man!- ol AWL Fun? To 5440?} ?(than 23 vim? I: 2125?- - .2 :c a . FIDENTIAL ,manu. (4 5? . l, . Su??Pr . f! 9414;} m- - f? ?1 . ~Pr\\3 .jL . "i'z 5790.?? ?ragdog, .4 L9 . CT t?t?lL", ?Av I L, loudly Ihalmo statements and: by ma on lustolm ma Inc. Page 10ml 3.13 . Amman Forward mu'sslunamm ani ?(11/1 - ?43. :5 LR 8?79 40 ?98959d ?0888898 ?828 1U9LUHOOG 9390 nugqg A I (MOIU (v.4 I I pan?av Dee-s ?Wm-e on, .13 I. - Q?I?o?l?h In a CPL ?Wmm?? I 045]). f, 4v I Le FIDENTIAL ?ezz?wewnooa 989:) i 0888892 8179 ,to Sgse?ed fammhu. Puma swung) WW 0 E031?, 19?l and Mode! r5 1 Almn Mail's .4 57.3 I Wmunx Points 0! bop-nun I: Mal a . I'x?u?a} (553?, {Lin '57 . 3?67, Triir??N. (F - - a? ?u 09133.1; I I 9 prior?93' 1767:?? GT, co Li 15?! ET (61, 0:?qu 429%: rt? 16mm MWAW . ?mama Pagond 0- um I 1 I Alum" . FIDENTIAL 8?79 40 698959d ?0838898 ?818 1U9LUHOOG 939C) Duo Amt: Make AW Points of honor?. I Anival 19:1? and Mannstalemlomodobymonhlsiomnm. - - GM GT C: IC: 312,5 11mm use: . Wham, Wu: C. I I one; L-Y-SB 3?6, sweLA?C? Gulf! - Amounl Fomarn v.s-u n- FIDENTIAL 8?79 40 098959d ?0888398 9395 43y Points 0! bop-nun 1: Arrival Mammalian Mm From loenlfy Ihal Ibo statements rnado by me on town in lml. Paar: st; martian ?1:5 - ?Asia v\ [Menu-n. iLL-?rf on 4-91 u- .mcrr cmm. ?01447 T, u: .175, L4 1411.:- w: wacky 31?: Pia-34?- Page Total Amount Forward To"! to Dole Aim-ll MOM.. FIDENTIAL umoog ?8988?8 939C) SlaiUe 6 8179 .to 199669d ?0938397? Da Alma? Value Arman Palm. Dion-tun I. AMv-l Miles Filghl Number Alter-h 1 and Mada mmuon Mum Flown Nu ol Landings From To 5 U03) 9 34; cam, our, MPHPilots 8'0qu 1000/4 Fag. Tom Amour? Fol-we'd to Dal. . .. u. . EPNFIDENTIAL 3% umooa 939:) 818 we l' 0888298 3" Duo Amn Make Mann Points olnepnrluna Arrival Milan Film 1513 andModa! amwm Flown No, OCT From 1-4, (m gr Mummy? FIDENTIAL 6? 5W . 3' ET ?Mi-men. GM 0.19?? \1 LEWIS RNNG Br 3?6 ET II as x6 ?Mp PIZNTO a E. SC: a? memo ?5 ems? 7-7- 96 can 8?79 40 89895Bd 0538898 ?818 lueumooc] Page Total Tiff Manama?; Alma" Mum and Nodal Antwan ldet??cmlon Mark Points 0! 0.93M In Arrivnl Mics Flown No. EndorsementLL55 2, of. L3 343? 6:3 GENT 13' 0 WM (51? ET 0 1.. can. cm aw: omen 5mm: 13:30!) Some l- 9mm? 1? h? 509 ?169 exude Ga 04 "Wow: soot-b \k ?sq?:5 \l (r owC?l (on (WP CD GLKL Icemfy the! the satanonb made by me on this harm no (mo. pioxa Signal; Can/{Pg v1. Pugs Tow mmForvmd FIDENTIAL ?818 luew?noocf??esz-SL 989:) 6 [53/60/90 i 59373938898 8?79 40 17989 Point. of nap-mm I Anon! Numm ?mun ldonllfua?m Mam . ol Land?lgs anI V?idoL": FLL. \3 9M9 x) lug/o '7 row-v - 4 1.3- 1096 1 ?ance PagaToml ?3.!me Mount Forward - lo DIM FIDENTIAL 8988-8L ?9323 8?79 40 998959d ?0888898 ?818 lueumooc] Date Nrm? Make km" . and Model lduntl?uulon Man From 0.'i-xl r) Point. at Departu- I Arm-I Mlle: Fm Minna, Flow No. End-neuron? To I I-pjp x?Hannuc #34 4 9M 1? c, erou 9's 1 F. '5 yognf?p? Lu? J: c. - . 43w cage Tom Amomt Puma?! FIDENTIAL 8?79 40 998959d ?0?838398 ?813 1U9LUHOOG 9390 . "rec Qnmig Vy Number Alva-? OI Lam WM wt. Exam-L I I :rc? 5 Haney Sammy]; on 116M, mm", ?Sammy j??IGr?n??T, Tel IDENTIAL ?8988?8 9390 81?8 luewnoog 8?79 40 1989598 ?0888892 9. Date Malt- Points 0! hop-run MM. 1299 and Mode! Iammuunn Mam Fm To '1 1?63 6 '3 gromil 0 M?Jmn NFIDENTIAL 8?79 40 898959d ?0838898 ?818 1U9LUHOOG 939C) .. Iummn? Pamsamauuo Point. at Don-7m 1 Arrival We)? Mark From 0 {3 eff? Bf 68 AQE CB 124-15 as g, (:66 madobymonl?sbmmuu,om, ,Joe was, ?16mm I I 1 1'6, GM, Cir; I 61? 295 3'6: HOLDWG 1?6 be ems If Hem er Lewis Panama! Mural-inward 'I?oI-l to but. Mum? Alma Lancing".pL nu; - (3 111a 596 ?0838898 ?818 1U9LUHOOG @3190 8?79 40 6989 Mai! 49:: Md M0081 Idenllaa?on Mad: 1m?: me Tn L68 made uymoonmluomm true. @443} Pulm- of l. Number 1 ?03 umw mes WE) LEWIS e, 31:55:09 I mu 3?5; \3 -T Crime? I M: FIDENTIAL 8?79 40 018959d ?0888393 ?8?18 1U9LUHOOG 939C) Vy Alvumn MM: 0! Donal-hr. I Arrival Nmnbu Alnn? mnumm Marx Landings From To 0836 -D c8 Lewls 0C6 Sh?u?'f? Lewxs 0&5 PB 3615M I442GM, EV, (any 1'49 614(95, Kid?L7 sm/vm \f Tom :17. cm Kt SIAMM wit? 5,61%, PW, Vucaupr Ware! was 9B 5 C?a?cumx 6M Immuthomnmumdobymm?cmanwa. PagaTow Amount Forward .. A NFIDENTIAL ?818 989:) 6 8179 ;0 L'Fa?e??ed ?0888898? I Niall: Make ?0 . lr? ill: .1 heparin? I. Nth-l Fm . ,6M,?r I SEC-.LLGY WIS 68 ,cmxn, QNFIDENTIAL SE Lawns 4? S?eum? c-wr? 3Z3 VFKGENM Cmva pare 36:1:va G?m A - - 6 Inner/ma Rm wad/van I F. :1 2:0 luthlhodMom-mmadobymu Page Tow i 19 Amaml Fom?d P?d's Signalm . TMQI In Dal. -8L 9895 8?79 ?818 1U9LUTTOOG ?ggSZ NW of GI. Ulla Akin? Max- Gan aloe Swwmeb?uam 3b~mm~ leo- MM 31?) Mh?w - A, :l NFIDENTIAL .I- QJ?s?-?au?a? KO - pp T, \l ?3me lb?! . 1? gm Qamx . no - II (A, Ola Pag- Tad PM, [gum TM ?0 DIN 8?79 40 SiSe?ed ?0838893 ?818 939C) Alma Mark loamy Points of Don-nu. 0. Arrival Mute ?ight Mmbu Aim-? No. lateral-nuts o! Landing Fm TD wwv, mn LC -, Lima{19-550, mmeMBW~1l?S- 11 3? cumsc?oumv urrmlov coo/um] '16st?nw I Rmv?f?[L?fn?Pr wow; Pago'rdu AmmForward Pilot's "35 8?79 40 718959d ?0888898 ?818 939C) Almm rom- ol ana?m I. Arrival alen??en?on Mark me To Nqo?flt? (5?i?nueoecd ~37: ?31 c, ,ewlvk?u, saw? 1 10M, new. 683661., . .1 i I (6T, ?7 j?mww .9 K, \{cwf Baum!?- E: A 44?! ?lCilb" mama R0 was 5? 3?6 Paw Total Amuum Forward P=brs9anam_ 262122394. rm: 1. on. ?8988'8 939C) ?373 lueumooc] 6 i 0878393 519d 879?40 9189 1 ?5?1 mm Mam Will. of Daplrh'l I: From To Nqo?i P6 CW6 1191 p6 cu 1" VB, pg?? peerage :m covarbf?-?l MAHO- ?at; can02505015 rh), {3.1513 I w, must?; quvssn Fem/im? I ?15 Page Tomi Amount Forum! in 0-0: FIDENTIAL 89888 9390 8?79 ,lO 918959d ?0888898 ?8181U9wn000 Doha ol Down-r0 Arrival Hum Gawogozpaur 322. as 3' on em.? 15M. 5.2 16:,th fe?rm. Trev mm: 355,61?. 44', NW 1 I ?1,949, ve?mw as ?rmer ?vR u, wanna; was NFIDENTIAL ?8988?8 933-3 gig luewnoog i 6 i 8?79 40 1199" ad 0888898- Pam-Tom] \l 2 Arnomt Fm"! Plot's Sbnature (W11. I To"! to Dal. Due Amt! Man Airman Polnu o! bop-nu. Arrival Fuml Ind Mom Men??wbn Mark Flam Nu5?5" 7f\ (Che ?5 Gnu-am . NJIIBT conga?? - A) ~711? LGQ C- "4 3 \l L525 It a ?71' {5:2 mmfg> ma peed/AKA I M. FIDENTIAL ?70838898 939C) 8179 ,to 818959d .1 2.we?! pawn. Points of Doom 8. Arrival GM. '7 1? I eh? 5 7%5614231 1 Page Tue! Amoum Found 1'in to M. ?dit'??i'5b ?emwwaw 1442a). mum?H? .n-u-vb-T-VNM? FIDENTIAL ?0888898 ?818 939C) 8179 618959d From Vk T60 lequhan-dntomonm nudobymoonmslommuuo. 70 a I 0'75 K, I K.- trap?. 5v. 31?. I I \M-wuufs NWL Page Tm! Amoml mm 'l'hhl On Walk I FIDENTIAL ?988'? 9390 8179 40 088959840838393 ?8281U3wn000 - - u-w- - .2 a. . .?atruu?zru . .A . . man! Maia WWI Nana Idonlt?cdton mm I'm To Micron 3::an Gum-z. W3 L): (4 643506 N?Koqsc: LCQ Pb; 9&1: WEB 7?42" mqjil. T66 (5511?? meme LGQ F?i A ?5:4 ?g-an Ma?a Muir Items) Oln?nu- m?g'3519??; 51 23) 23 LIM f. Isa/W 3: WM 00 Lx??fi 3&1 (cowefc?OU ?24 EGcw 3'2. WM '33 35 SK awermwn?euc sun. row-a1 (?8561 5e ,sL 7 s-nSbo-rr-m?nm ?55 We: '56 313,61?, L: 32 1' CM . -3e,sn?u2w. ?2 $901? 3% F. I 440%} mm? ?Aida/av,? 1-. Page Tel-l Mum! Foiwnm 5 :4 3 Leer Ill ran-mm .3x9 g- a mm (m \Il. Case 18-2868, Document 278, 08/09/2019, 2628230, Page381 of 648 0 Mann Mm Amt! o! napalm hi 9 Ind Modal Mark ?own r? wuV nun To duo?n5 N?quaLrA ?Latm SM, . Nun'bor Aim? a! Mfume Gum ,le rag/mas) ?3 (0554245 A . ?l 59", . 1 i? ?LoMo wmo ?g?gtf?sclg?fw rim-ones VK ,0 VB 3 7 3e51, ms; gq T291 0t 9131: wanna. I \o 1! $155,. c_ \3 ?37 lg: hpN\{M\y 5% 3L, 1'2 MW F61: 36132 max mf Hoj??cms?; - 1L9 1L, (48?le ?$er mama-06922:? . TLPL (78$ 0/0 Bo 961: 1133' H3 . shrub ?yu? LN 35%, pg 3: W5 wm??r; Mum-3 I A32 thoqr? (Jea? m6 PV 1557'36,Gn A ?3 96? 55$ ?rm-3 Meme PM Lea Lu, 36pm I canny {hat the simmer?: made by ma on his fovm are Inn. Page Total i 2123; 8?45 Pilot?s Sly-m to Dal. t?nr?d 9hraw?a (Q r? Case 18-2868, Document 278, 08/09/2019, 2628230, Page382 of 648 Case 8- Alma" Make me Mow Muzak Mam Points OI 0mm I Fran Flam . - 3 Mon-mun during: Nq 0?63? Alum 286_8_ Docu_m (3112?! .3. 66:9 WW) W51 T?gr k??tg 7c; om 5K Ncpnoq Loan, ent278 z: qwgg, $139k? Pa:? -T/x Fm?-w 06$ 5? 34:56 ?2,611, 0 967- 51 53 ?eJowv?LL 5L, 3rd: M5163 39K 55? ?Lama, 6?5} [?139 gm ammo? suwu. 5'7 1mws. I ?crab Jo GASK. WW 5?6 LGVB 5?1 was: 6559 . \f LFML. 32:, ll EGGW ?l BGR STCIGMISK ?2 6?4 0 Nao?w tl W551 Lisa 31? Pr??i KY m8! ?aw/V Page Total 08/09/2019. (To! A a! <4 ,_2_628230, I-Tr?aoho ?11.va ?4 Eage383 Law/o Amounl Total In Dita La om mm mm mar-n mm of noon-nun mm: mu High! Number Aim-? 3 .and Model Mat Flam No. nun-nab on 100% Fm To mm am can Hear! ?f?s Elm-3: mam 913; 513V gait \q . 59y; 014,534 1WW . 7?0 1(3?14 - mfg?K :61? ?brin 91' . - nan . -m but-m mm??mmMkawM Th" mv mum lawn/muck xzqux??gm 23? MR1 ?7 mL5W%?om mnem-m 714$!er ELWWM I: (max: Noma? was ?a?mm?wm 6mm A ?15? T63 \su. em . b4? 72? NKDW Biq 81.91011. "Ln '9 '3 FM ULQM Mm ?ca swans-3 ?an?197mm I WW $1?me I Awreo e- vow . . emu-x. :25ch giga? '1 new: wf?t 1? (29.6 wmwcu? '?gw?mw LO ?73\ T1194 TQK SIC my mm, mwmua \q pg; 13395110430?: 1?9?)er ,Juupe H1300 Lg Ix EGG-W 15 . emu/?52?, MUG Mwos, 35??m Suva? 1? EGG Btu? cq?w 2w, noucr nm?ml? [Ogeuzm as?: ?r Ire. it NAOMI ?an Mu. .nmIcenlfy In summon man by me on w: 1mm In true. Page Tow 3 1 ?1 mgr?xm NFIDENTIAL OD Idiv?dad??dn?43rd? Amount Fatwaru I: \u Fail-'5? <2ch (m so mar ?11* Pilot?s Simulate This! to but. Case 18-2868L Document 278 08/09/2019, 2628231L Page384 01?648 Due - ?can Mam Allard! Points 91 Departure 1 Arrival 1-19? and Mode! Mammalian Matt 5 3 5 2 Eg Flat} Ian-kl. Dd Number About! 1?77. mm A 3421,31 Meme 961 1:57 17; 5 V1 1151 (715; 833:1?" . FBI A. mm 7\ {35; Len-45 5. Z: - we? 3 2.0 RWomw-R Loss :50 prw. W?Srm?' b55- mam (5 $17.1 Stnuunuc M991 . - Ho {Thu- Co" emu?. At?? . (wt/31314 ?WK-jg??l?gm .. . 9W me- an ck?r 5'?th dame? t' smf? Murrow? . -.., . :vma191m Fuel. Our w. sus? 6:0510?. 43;:me 6, 7W0 em- - 4?6me (em-We mam: Wu?, Apufr?f, Leo 0&3 mtg-ruff, 5(4ch egg was or oc?em rang sum nu (Imw ?4013' fka A 1066 S?wog-At?hf pm, QC attic-nae (A?o?z 34$ If mw?aMOQOOanaNr i 1+ :ng 961 ?lmswuw? A A L/n 44/ I VI) pal-'7 v! I canny mm. Untamm made by me on link form are true. i Amount Forum 35?} Plot?s Signature - nu to W. 2322 83 rv-f rv-?wy. .029" H1 Case 18-2868 Document 278 08/0_9/201 9 2628230, Page385 of 648 Nunba Alter-? 641m?! ?($1161 Wt mNdd'Jlj-m Qoo?b ?00.0838 91193-3: 96L A 2 L3 may; 60 CH: 10 39'6? 5? - /1 25?? 0'1 $135346 10L .. 14cm: woe 33pm? Wm aw k) ?a RePosMrw Dale mm mm Ararat! muo- Fight 7' ?2:1 ?44749, PM 949 (arm-3x N?oa-sc?. 3m L699 500?? 4?5 .. 2957. 5&0 i wuss mum ?be OMDB \ogl?xyn?. Icer?ly 1h! lho Wmenumadebyme 53.9ng (9/1 A yr '52 ?Modal Mun. . rm No. . (H (57- (1 ?239 UCW _yl L3 LFFG a; ic? LFMNIIU 618 3 f3 15?} 311$!) \03 351 mm Vail: we. ?lm?s" ?51 LPN). Pi? poms- mm Amaanomard m" I nnwul . 3? H7. '3 [In I Case 18-2868, Docum_ent..27_& 08/09/2019, 2628230,.Page386 of 648 Data New: Make Altai? Points of 0mm Auk-I and Mode! Idan??mlkn Mark 1062 Fm of Lancing! To Number 3L ban-3w Nqoexe emw JFK V1 SFK. 95): )534' n. C: 4qu6 Nqoqsc/PM 555 Lt We?: \1 "303 1 W4 m??lcxyov Lomiluhurle W?bs \k TIST ?i (yng?m ?oqzw i??L I 1560 (?533% ML T515 .- W1 Du?mlcuppm Lopez if? 156MYQQ INFIDENTIAL Fm?s? 98 ms [Qt-9mm?) 0/0 23 Witt? \m $6.me Mam 0/6 . (??1579 - a' T66 1573 53%12?5??li?wo 6-1999 3,3135??! Wfbv? ?1 gnaw mam 3.44 6-in- LF-VB us z?xw DNA pam- o?-W?vh: wuz- cr-nu- Iz-Ubw- :?muc U. 1'1 - ??78 mm 55" as 3?3" LFPB ?3 Se?mx?ns eavce?mtl I LFNJ 0/0 (1.. If?, 0.24710! g/ '1 Forward Big b?u7 . - Case 18-2868, Document 2628230, PageBB7 of 6.4.8. Duh Ahm? Mala SM Mow 2.00.5. Aim-aft uni?cation Mm Paint: a! Man I. Arrival otLandnm 3113? r5 N?o?oje rem #7 \3 GMTT GMNC l? .ewme IIHQ \1 L901: MekiGRc-cr car AQYSSE egg-291 I 6 meme 1 PCS: 1993!:55' .GEWNFIDENTIAL (I It A 1 jMvY 1?5. MLG \7 $01313? ?tG max. 001' URN) 99?S%Tfmodb N90831- m, (?Fm 1851 ll \l . - -- . RLrutz (now a ?23% SM 3G OMS (no; nowm Esq \l \l \Sjo sax/amaze (200.3175, I (ammo :9 3 $5939 8512.}! m? N?oism 1951 33$ \93 5?1 II ?3 Jasxluwar Laf?cZ; IW wanML? Page~94 Case 18-28%, Docyment 278 PageB?B of 64_8__ W..- AMVII MMS FT mmum m: Pohhdnopmml {111 all. and mu lamination Man: Flown NO. From Altar-l! ma pwe Baum? chexe E6633 \3 I .. cast-3 me E?s??zd LFPB 19K - 3m 3% ?deN ?105.39 c\ WES): 1511.5"! 1 [4&5 "(68 swam LGWII 00'0" 01? 9 T66 ?393 - Ben \s?x muss 1' T157 I649 WW 4?11 0963?: 3' {517. 5mg?) 5 NH ms IRL??znaw-r wan?Lama 84M 1 DGHD \37 i555; ?n .- .n 21m l- Beep: ONBQ 13B ?wmmw 5? . same as Anwa Less mum avgd?a? \t qug No PLUS ?15 FGUVW $9.07- (?5er hhfr9?HanQf SW. - mbwer {4:31. (co/?sum75x, char melt)? W1 911 05m} L995 1 /l Wu? Panama 5/(2 Amount Forward hm 8194? SignauQ TM 3:135 ma.? 913% "33 'g EEHWA NFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page389 of 648 A. Dal: ma Mu: Aircraft helm: at boparluro a. Arm-I Miles Hm Wot-u. Nunbev Alva-n . ard Model Idm?fbauan Ham Ham No ?Immutlet 8-12.14} Ir Ox 09:36 EGGW 1 1 \v .. Lgp? NECK a enth?cM/wm . . LFF .3 Y- meat-1?j?ng'A?v?fgif avg?): um.) (J 86? N61 (ix-m 061 \gnjulsvv Pi GL- #1096 \t (I )3 648 1; Ian, Macaw/m nu, {?aw r? \S?q 1L5 5mm amine *6onemw Sc 3 If 06$: msewm?m 91%. 160 1131? ovmuv 7A 50 A ?71? (mt ?Mimi?72!? AL ?I'Lru . m! K. 3:71" mettiw (?518.55 -wr. vv ?3 k? around. 4 2m- ?#11006? 3 :33" ?11) 0mm gifuctmr Mu? . - e. . A brunt-4T. E. Mow: 9m T131, m: . . a .Lot. - crawler Huh 3 a. UL- L. Mum?wt NILE A [5331er [1.2582 ?faib?-U?s $.50 Luv/pa, 1.1.55 war, mi,? Ply-L 11* (a Cf} 6 in": Gaff! ~1?u1$ ?2(y-n 40?13, war was um my 51;; wa/ .(nv'su ;s 16 ms? Jim? #11sz x: 1:37 M. 3/5 Amour: Fomam [-9.709 ?Li" - {1 arm/.917. 2gb} - .. nmaqr?qj~9lnw? f" (A Case 18-2868, Document 278_,_ 08/09/2019, 2628230, Page390 of 648 on. E333 2.5.. 4 23* :33: 93332 63593: I: 39.5 29 iras?auw . Sula: ?o . r.._t5.n.u C. I .. 93.55:. 73 Ra? 63% A ran.334 :50- .me wh?ksw? 3 . - 1.33 wac??wr 1. a r1. ?wryk?nwms 3 1 . . 2 Tam ?3932.932 ?$295235 - . 1 ran \n and ?Fm 3. 25.1Mn? PEEK-.3 .S n.$.33.hK..3.5.4.1.). C2 v3.5735ur Mb 1 I JDVH. F: W. ?gum .v v.1. .. ..P I .. .3 e517): 1 2.5- Fc Fain. {?85 0 unh? t. 3:12.. .2 P?zer23.? 2:..ch . - 4 .. ?alal 2 ?was-239 2.await. . . . 15.. a- ?when; .5 .: ., a3 -23 may?: 2\ n. . . .. 36.. 3. z: 3.32.? manic. 9..li 1 \m?wIA Aw .p . v, ma?? .Mlmu?w .C.b (V 47.. 3 a. edna Aumu? ?did?. C3(.n.72 .85.:lggi333in33o3283o355 150.38. . >395. 133:. . 48.. 8 air??K 3? ?0 .. _zm_UmZH_>r aha :r?oo .f ?ve .. I'w-r?M'nTj'Fi?i? Case 18-2868, Document 278, 08/09/2019, 2628230, Page391 of 648 'va Dale Alma um: Mum! Points of nap-rim a Arrival um High! it Number Alum? . mm lamination Mam Flown No It, autumn: ?Landau ?4 Mr; To I . Fun 35") - .- . 1 H4 ?3er8 A gr ?LenmeQLf?m . thc?sc 2: 334? ?1 - Ks. xv. r. win-391.1 L. 1 I I b? SEK 1.4 1:151 Lu. Mugg??g?u I L05 'Ylb? ?n'mnghuz uavnmuw, 1133'?? H's. 25? Awnwi?mr?ab? 1L P81 lb (Ml-5?13 V911 i cm ?Tc-96 )1 mszfo?khm? ammo? gm; ?1 1) Kl [Nuns/:1. Eqn JC-iof-?f?fgg?; 113.74; FM \t 99? 1P1 hairyNg?L-f? HUKBOM . 1? P61: WUVT $28333 I 42- a pawnmm; ??x"g?mcj; 7: Grebe \Bu mm?? - I?Mgem-L we? 8 )1 CE): PM m? I 3 '24383%. Mm 163 imam? OMUTQO Lug-shack (at . Billoil?NQU?xrd .J :0 c0 (JAE Case 18-2868, Document 278 Page3_92 of 648 Date 1138-5 Altman Mama and Mode! Allutl? mulbn Mark Point: at Denm- I. Atrial Mica Flight Flown No. Run To litmus Ian-ml . 1 Number 0! [mange IE per; (3'72'7?'31 N3 0881- MRY BBQ \B?f 98 18 \e 3 PK {Harma?nv 98): ?-M?lrldo Snkumw 6? 197%,an 13651;): gunman?J OW \t may} Rt.? I .T66 'MYNM 9mm. 31% 3d: (mg; n, UL, Jab.? .SK, 3th!" ??wuL-L (J 5c: uni?? M?ch? Luv HRUNEL 5 WI- L?cfrm?j? ?11 J?k C: 'c ?1 AM- Lat-wow LB a 1157 \sq sac 5 596E NLuc GVQL W3 3U: 19 (-3 warm! (a tha L695 r?G. 5K1 ix (In: Lot mucL - (HoMums? ave,? an. ?ue-{LB c. {um?Now . Pilot?s P?s/deg?; Pugs mm Amman! Forward Total to but. ?mepr??d?o?aoou??mrJ'dx?A r1:? Qo?u c" U) H3 . Case 18-2868, Doqument 27?8, Page393 of 648 Page394 of 648 Case 18-2868, Document 2_78, . I t, - ve? mum-M ?Mrz; ?o "Mm?Mmde?? 7w): L911. ?aQbN mama . Esau-u $833 353 33hN 1 r? Lomrw .. (?u??ryuzi?a?geazz-?fm??x .. .21. E, {L'my?a ?:19 L0 hN ?c um 33?; (NI s: ?9 1.3% '13 u-mow?; 7W 9571- i . X9 lag-+553? 9 37.1, A A A ?71 May?wy 522%} W: - 1 ma?a barn-5:: muvL?xg?ar.?19m ?xg?yrmWUNVQJEDW I?g? 3?5? 1 93.1. i Aiw 2? ?IquaoHN?Jo 3: MW 97?? i. ?43ij I 57? 7" (4W7 i 7, .f {Di 4? w; $53991? 41 I 5 gm '5 195 ?99:3 W1 mm, (?571(79? 1W9 ?r 01 mm: 4,907 r? ?lama-m ?33's not: ?Iumuummoolo mm: 5&3} 0133mm; I Pa99395 of 648 Case 18-2868, Document 278, 08/09/2019, 2628230, 3 3 (I: +175?? :ng Own Oil-m- ?3'?ng ?.6106 CL 5.: 15W, 333;; emu-mu? . 51 . [01558694 I "can 0:9 ltd-clam to M: Baa-u awaumms eullaqahrueo?wV'vl?K?h?n 917:1; . 19:90 3? 1? 3?33 3.3-3 I 3-3/0 #33 new ?5:73333 1936 @1735.5 559-55550 3m 5 ad 4555594: 5 ?1 3' Wei-33358537435 FZF, 1] 919; 73517294005: Sg?t? am? . 7373: 3 3 3?1, C3 'm?m?wdwv ?Kim 73233 gym-5 .5 3?75 (?3th 190_ 35305?33903 1/3 3'3 v?yg?lft . 393d- 1207 3? 3 3'3 I. 5) 52.0320 ,5 50 :57: 1 0:152 99L 55 1. '31 3/3 3 {97?3" Sig-)3 ?3 3? ?c 3,5055.? 5,7:th I 1-83 A M213: ZXPOBN 90950?1.) L. 5 3-3 5 5 (?my-wr-m?wn Www? 1 5593.5- -- >9 :51 W7me (95er 5.953110555335315?; L35 Ii 9?73 ?3 . Q1 990000 ac P. 5 :5 =7;an 99" f_ 8391 1?9? 5 . 95330533293331?? I 39 I July-t'gjv?mm-um? -. 5 I 52 'z iggigl?ggmumm 00-2003ij?wiv s?upuuno 3 0N um?U3 L7 03 mm mammal 9903?; mqunN 5 mmuI ?451d luluv '3 I0 "?201! 131133? ?mun" ?"30 Paint: 0! Departure I. Avdual Was ?ight Rom Procedures, V0 Mulouvn Emerson-cm: [9 Aircraft Guam" (1E .3: Wham? 50mg Mn" Lt: VJ) v57 5.4g. 4a GM 5? L's LPFH aim 1:67; {5?7173 v. Mi 511 LU. Lm?yitV?QL?? ?5?49 3:54 [35le (P- ?3 )1 9.x 3; pm 319,945 D?vts'ofmA Ell?J? 715054 166?0:511 7 a" I 711- 1-. 13:1. 6) Ln Sign Omen I ?3035? M06139 . {397? I Tag, ?95? \l L08 952$ [1151 11:13 has? W'm ?30,373? imp) Amati! Lug Im?ujgmw 2.- I t; 32:" . 5' \n WEE4.60 V3 Mm I - 00": .5 I W?f? y? OAQC I cemly ma! 518. emcms made by me on lhis {urm era tme. . age Total Amwnl =orw1rr! 3-103 o?Io CY - fa: 4" nn?~~wryf 1 0 ram-(e: 7-1 Case 18-2868, Document 278, 08/09/2019, 2628230 5 of 648 4 7 Drill: Arman Make and Nate! 71?93 A'rcran Men! ?cation Mark Palm: of Dcparlurc 8: Miles Flighl Raw-nary), Prouduru, Number Flown No. Munom?. Mum-nu ur Nrcu? Cotonou. '1 L, 13'717 18>! S?l?uumw}, WY 11 211;; ?56m? ma 30: AM To ?229 _L_Auk_ I M2, I L198 . 32mm ?mE?Mmmr-qu? 55 - (J) .vm TC ?1er (381 wen 8 (3M - \k 17:33 PM i ?gnaw (?er 0* ?38595 1Lmusmb .1 . II . Eli/? 1 Tl??'j #4 ?10m? {mm} :0 . L. an $31 V4.7 mix, P81 we? ?wv L.v' w? -4118)? 00f A ?1:3 3:[35:0 ?if! I [061: PM ?510 f-ga-q (-f??bi-Rfuvo? i 11:13 Pm 3?9; (1T, .D?r's - - .35; 12:8 MT . 3c, 7% (WW 91921 rJ T2: 6 [1051 311173. I cenify that lhe made by nm un Ibis ?01m are lme. pilo' Signalue 2? CH )M?geew; .ub" 1.51 Law AL ?/10 Page mm 1?5? . _b)55_ Arnoml 3 3 5118 Tali! to DIN __Lz32.i .3 .5 $0931?; CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Pa99397 of 648 Case 18?2868, Document 278, 08/09/2019, 2628230, Page398 of 648 (L .587- l; Em,? 832:0; Inn;? 771% . :83 .53 L733.) (ESP: mkusIunowv mama wwswuuoaqu opau. 30mm? mum 640190: i . ?1th mans-YE] II QT r; 3 1.19%: . II 9 3 13330475662 ,0 0?0?333?? - 9 gig. . 37. I ??dgl 5? I nth: (n All"? {c ?r 3?12" - I ?waw mg Q30 7? ?3 5 C) $020330 WEI(1va spa/0? 7,0; {If 7:9 Vi ,wuygm' II II '5 7.ij 2 ?g $90193 I ?h E0 ~n arm- - 3:5 P- '68 3 :mnuu: 953 3897 L. . ?kWh?fa 37?? @ij" 3 div 3 33:? 555' .7335: .I II . Oi.- -: ?3 i1! I 990000 acI232 NJ: >135 amowf It'LZwa-j L7. . . -. as! 991.- II I3 w; 3?011?) :3,in 01? *5 LL??x'qm? 8'91? >93 'VIloObNi? 0 1513?530 -E201 "0050360 uelallv/l quJn?N 3 . ?31;ch sap? pnguy 1 nap-dag 5o gum mew ?519291;: Case 18-2868, Document 2628230, P898399 of 648 5) Ll 31512.1; - 5.) 515qu mama-I \b - jailw-ed? mammals nunvruwoo; 1 . 5 $53. 1 5&1 1:3 $51; I )Ef?sazom 3E 93 1 9c} 35?8? W917 USE E- 5 A ?-551 .1 ad 9317); \5 {5 7&7: Eg:. 7" Em ?zq?u?gug?vg Em? 19:5 5? ?55 5 . - 155.-LJ/Liawnmi??rtw?i??m 15551 >914- 55 [l 7558?? ~1ch '5 '5 7 ??>55? um 55;; 7i .. :5 9 (Ami-311 1? ECLS. '25 ?3?ng a 5'91 E- I 5? l?crazvgji?v'am Gian/vXHEmE ?f'j?l 379d ?7 E: .5 37579111 ma-?vm?a??w: 53?? J?fm?k W7 . 53 45 WEE {?ka 7? 5 ESE - 5 B??su- 9 690000?30 N90 .7 ??#5575317st?; D755 59:; awv Swim; g; sow 5555: m, . "an" mum? awn-dome Iwm I Endg?l 65:22:33: Dab Alma" Make Alma? Points 0! Departure 0: Arrival I Mfk-Is F'ugh! Vitamifrocedu-i'es. Number and Model Idenmmum M111 Ftovn Nn M?oupm?. Endorsements of dertw p: rt Gumm? (11' ?3 Flc1e. (yu?cs Meme 11ers i_ 2 LB a ?agITGB ?30-?51 lb?N LY .5 WSCD lmS?Am? numhuwm(5-111 5M {0qu1/ 3 '4 H4 LL LFPB 1% :24 ?1 4 [4:393 BGK his (iv? quqaews?wws?wm' 5-6 A CONFIDENTIAL -..- 4-50 Yr; 05-h - .r wraps: .. 1 3' ?1 2 136$ :Lw wm?Fw x/ a 2:2 \t ?gy? MR9 lg" icy? 5- 23 mK?f {'31 7&3 'w . V/Camp! {36? canary mu lhe simunms made by me on this tom ttue Page Tag: 6/ 5? .-:-:27tamFwy-Tray:r~ . r. orms&fm? 0? An?ouanomam? TolaltoDalO ting: -H. .. - Case 18?2868, Document 278, 08/09/2019, 2628230, Page400 of 648 Point: at Dopadm a. Arrival To '?-n-ruLPuzlduru, Mine-31mg Worn-Mu Numbor ?you" 0' Lond?ngu If: man/w: ?saw-(I553 95: v28 M7 TDM 13 1660 39-HoITGB ijfif . \1?34 {1ng TQM. $2ij ma?as C. Mm we?? f" mew ?1 Hanna?LIL - mm: Gar-R'c?nr H1?lu Inuit?. #?ilp CR7 Ti?vi Wm): 4 'Psf [39$ Samar?: . my; ppm?3.9 .. ?a .f ,v v.13 F79 NMno NW 6?13": . 454* . j' (1:16? 40,613; h. {if c? ,?30 c. va . 1 I 6&0 vs; .36., Fax 361 36L. 565,51, .Ach'J Wadi ?df?1?LCrM 1 -1. Iccvu'y ha?. m: ?elements node by me on his 30m arc Irua :4 {waw (1541* 5339? (f a} 169355910 .1. 2 ?17. my?. - . 9 I Case 18-2868, Document 278, of 648 41% Dale Alrclah Make Akcra? and Model Mart Pom oi began-no l- Arrival lac?Ll From To Wes Flight Flown No. Ramada; Mowing?. Mum adoration? Number 01 Landings Alma" (yum Nq 3559 81?F?i :362 2i, M?ri?mp Cw Luz MM, SK - ?S?i LWB NM WmL699 ways/M34, 3'32". C}a;x ?32817 2WNUR P?z Ev? man/M .651 RON 111?? VB f- T5353 2? 2L TEE ?(p51 TEE ?v;53' Tex3__ quv 3304 13? (-51 NM, 10 25// @mr?hh! 4? TD N. 51kg mg I) WW PBF was 931 JZI Te?) ?6 6:0 E?exa X615 SK I unity that the staffin? 5 made by me on this ?onn ue lruo. p13". P?m?s Signazuo_,4_ Pug: Total Autumn! meu-u? y? . 1 Tot-l to Date ?1 Tl . 14511323" .1 - . I, 1.1, .Lj'n v, . . 713:.) . CONFIDENTIAL 5-4; 5?35.331 Case 278, Page402 of 648 Dale Alru?cll Make Aucrun pom. of popular. 5 Arrival and um Fron- In Mics Fight . Flown imam, N9. ?inquiry, [Islam-menu .K 43 x. x. Numtm a! Landings I Ow ., NQOCIIGW U) _u Efm w' Notocaf? 61 PSI .191, '5 7:71 ?i??fsic .0. (.705 mg 19.75,; a. - 73 we AM 4W. rag?3n a gem?, msj?? Gwv?e Nqo%m: c158 so? fsac SK- (5?5 kaa Kub?'il?ms?Et?er?w 13w? 4 Luis V) U. gu?t} $9 \11? GR 5C1. GRI gems/T. wipe-Mow a: .859 WM riff mam . M5 AL 514.12., \q 93-1-1?? nm?r N01095: 9&7: ?xmwm K, WW GR rumi 34374; L__v 1' 5T<=vc mam-xv- d) . lg' . .231 ?3 {31? ?3 ?16am, Lam 2m, NV). NM, SK 3Tb .I-m . ?aw 1?6: TD \f 2.14 I cerlifv ha?. tre summons made by me on Ms lam are l?uu. N.-..- {Lug-=1 Qprli'l . .4 . i Page Tole! Arm-mm Fn'wmd Total to Dan OLM .. CONFIDENTIAL Case 18-2868, Document 228, Page403 of 648 - '3 .. Date Airml: Make Aimah Points 9! Departure I. Arrival Milne Fug"! Nomi; I ?ransxrul \Arrml IdanuhramnMam . Flown M. Mgwouvgs. It; moments ()0-4-2qu 25301 )4 ptanaarwperm M3 v31; 2? \0 4 PH): - Lu. I paste H1 4 CONFIDENTIAL . (who, . 7-d?i LV . 0 .- in"! 3330??! \3 :osU'L?r to? muckd5?, . I 1 321,.1- ?[914ng Q'nuan Ln LM w: 399,; ?af-gcc-Um .15] I 7ij y; ,0 TD way; 951 am rib-1 . . gaming (14561Bari-am M1 ugrg EST "3 H: 0 :tho ?g?t?w?wn'?'94H 3-4. MA own(31M . 7' 10 QA??ch munlW?Ho'l ?Wimp? .- 3 vw?wzww 33x :r3 qzv?m Niven @165 Z. i' I 5?23 1M "ti-mi Aw?h? u~ - - .. 3440:: Amy-AxumL?j-wsq? ?waif T66 is . Icemtyumwmaomxs PagoTotIl 9/5 5'3 Amount roman! U112 H531 Total?10V Data 3:32.? ?515?Mjii'f? rat-?j: (it ch. 6? Case 18-2868, Document 278, 08/09/2019, 26282304 Page404 of 648 005 7382.33 33.3KB an 933 Sn 3.500. . 333335.335: . GPA 33333., 16.3.0 2 Uni-3!. P323. .0 73.3033 3 39.3 23. ?03.53. 3350.35 "3.8333303. 235.3332 03 3.033032? 2.6.6: 33.53.5509 .. .3. 73A. ?aw. 3.. .3. 332.33333.3? a: .3 .- uy?hximmr. ?(33.7 ?37Swan}; ?35.Sham. 3. .. -U 39h HR 23.. 3.33.new; NU- . .3 W333: ?3.1.33.0.3Mw dam .3.33-333 .2 ..3 .3 $.33 navy 3.3.3. 3 .333 33.5.5323. 7.33an v) 3 3 33 33 m. Mania? 3033.3. 3 3.3. H9313 43.3.3.3. .IN 3.3 .39 Cu 3.7393 a? .. .530. ?3.31 HR. 3.th 3.1.1.23. .013? 303.1374. 3.93.7? pacha I 3.33.573 7.2.3323qu ?drink?Ld? IS {33137.3 2.15 F. 332v 3 33 .33 .1.me 33Wmu3x .33mJHh 3.3 .. .. 33;? 33 333. ibavk33x; .3 1.3. 33A laud mu. 33o 33 @930 3 33-3.39. Hm. -- .2 2.2.5.. 3.4. 333 3.53 30 35mass?3.3L. 3? (SWIM El use ~08. >395. newts: no on: Case 18-2868, Document 278, 08/09/2019. 2628230, Page405 of 648 -- .l 1 Ntmoat m? {mam Hcc. ?:31 Due Mann Me I Moran new a nap-run a Mini Ultimo! I 2.0 Flam L's-um quse 15% ("at Nqo?'se 2.0 33% 23 \l 1963: 2.8 e-m?w N?Ilo?ifg: 93" {Banzw 5Lmoumb-L (?35qu 2:1 i x} {?32va M85310 3K scyum, MM 1061;? \mu K. NSYIQUCTEIL (Wt M. wit-WW" mm \mjemv-wmsn . sewml'sn . 1141 '35. SK LV 7 as} I NFIDENTIAL DR _000076 r491"? '4 16? It (501401 Ntimom Tim-2.515- ?30 1? Li): 1:77 N61613: Tm MW magi?; TQPF (?Er 31,032;, Milk/F" LU oenily that [ha summons mods by mo on 1am In true 11 Pugs Tdal ml 3'3 51? 1 lAmoun! roman! ?Ail, .. l?r?d?hm lTohHoD-to qb?YB Mr? Case 18-2868, Document 27_8, 08/09/2019, 2628230, Page406 of 648 Date Arum Make 40: all?! Mariel Marni: Identi?cation Mark Points 0! Dopnturo A Arrival Fle Fl 11 son was?. Number 9 again, . 1 qu AIKEN: mama-m 8? \?st 0, I ?w PM {ii-?3 ?31 3151? 1' ZL 5 751 \l ?(5.51 . fj? NM, A mama LV I 5 ?5 ?ag?a' Raw-5122, 1. pa (2&3 i SKY: (3me 340M, mm mun__\f ?.114 l?V '7 ll Lb Qa?use KM 6131': W1 ., . L5H 34?: 3 . 5K 955$ C, ?ch, age-(r; {4:16 mm I?q 2H - 0 me?urJ ?151 ?dg?i Mayouac?c?c I Gan-m 96; 3'13 nnymakv?f.? N. I W: Wm lzuo 5 mm mm MLQ ?t?z?a V1 .[jm . I he?gr?co ?a mg m? MW NW9 Rm?w": wane? amu? (?2,160 0:9.wa 004.9,, um, Eb: D3 GM 3334. Mb?i?W 1 4535.- ~99 am: pm HM L5 Ecenl?vy hat the smements made by me on [hh town are We. QinJ?j?A DJ (31% PagITom?- Amount Forwm! In Dd. ?u a .L mongmr~r19 Case 18-2868, Document27&08/09/m19, 2628230, Page407 of 648 96408 of 648 Pa 2868, Document 278, 08/09/2019, 2628230, Case 18- 53.1 ?"25 A165 ?(Avg WA In Lil-b pmww'mmw . ?35 5?/01 ?ml coed 1 mu men'zw smumars [jg A l_ 9'75?. ?3 A1713 ?1:1 71-ng TA 9 ?w?d M1 I (,Ljrl mm AA AA Ami?- gear)? 19M AA I NE 5 73:37 Time-Em TA A gzr'A A .. FA: AA AMA57." (\71 Eti'ww'wd'ww?nKt?L?J . ",pri'wv'ax; ?7:355 A AA km A Lari 8??i?ji? 913. ,w7?3?3- 715:3. SOJWEIIU swan-"NP": 0N 01 ?ms Amowoua g? "-Monolna uumm ADQUHNI ?mid helm wow meumsw mo a A. 4 'Jnle Airman Make 49,. an! Mooel Idenli?lcan?cn M31: me Pain; of Daparture Arrival Figh: 51mm N1, mam?Mann Retains. Procedural, NumbOI ?rev-? ?gunman; Indonomonl- n! I amino: sue: (3min?) 3 T157 . 3&9) #93 rgii)? an? 6._696): T613 Scp.382 v' '17?3?456'93 1.19?} {.ng 39% In momld . ?33 33L I D?sj :81- SK 106 0H at lf?gf D?il T393 135:? of: TM: ownm 8H i I IENM .55 NJ v-L CU hi mg 51k!" 3 1m T5333 W16 m3 1? m; T59 3.0? 63); ,H?i?l 93? SK 08 mail menizrw??i" qua?, vn'mw QM. 3.1mm 1m 9" r? :13 .390 pl Tm ?35 {13369 (mi 3 3 3? b! 31951 3 1 .321:an MW PM . ?3 TVDT Vina ?36.4176; 990M .33: 21ng T737 - 16? I $2,057. 0M, . "4o 8 "1?1-7?1d1534wwm PB): T68 mm ?56: '06, (3M (NM 6? um. Laue ?mm mm slaletrenla made by me on this loan are true. cum-.- 0W4w, .3303 Amounl Forwnr?ou .. (fly, 7..-: 0.. (H). A p1 IN I Case 18-2868, Document 278, 08/09/2019, 2628230, Page409 of 648 Sula Alcra? Make Altman Paint: a! Dupa?url I. Arrival an} Modal den??mhon Mavk 3?4117; From I To Mile: High! ?own No. linen-Ms, Mos, Muf?uvon, Endonuuonta Number I mummy; Aivoull EL Mi??Pf jib/??r E5 I Lu 3? xi LTSB 18:7 gag!? NM Rp'lut. "Sew Pm? i'TcE 18:8 3CD - E'?pm HEW J3): T157 1 1? 181?) SK 15ny 33 1 . SK 182 A H513 WA 5K mummy LL36 SK 311m 'anlrx 3 in sewof m?ucT?V inmwum lam?"H HNM ZR 192.7? JLJAM. NM [8'4 @5111 \3 NC Must .313 723. 13:77 We L.-. 3?71? RM NM LV 34:, NM 'Cr?s?v EL 31:6 6mm.- 6 1L 0 1 a? 1353?! 16. on rht" GIVL OQU GM . 6L0 if IL A {?5?1'7?r3m K231 3'6 06 GMAK mun/awn; 3 Kill TEST 4 TSFK Mr-Yf :gc MASK 91'" ?man? when. f?i?ln.V36?TO" 5 'acni?y Iha: :?uu staiemenls (?306 by me on VHS lon'n are true (w Pliers gimme laid (in?atm. [out mama; (134-97: manifpwr nu: 01a! 5) ?74 Total to Onto 1 LL ?a (l?c?fabp m'vc Mr?. ?yim?w (Jung! Hill- I Case 18-2868, Document 278, Bage410 of 648 4% Dam Aircraft Make Alma? I Polnil at De I 153?; .. . . pant-o I. Amnl Miles High! Rum-r uProcedurcs, Number Aircraft Cat and Mode! Ideml'lcanon Man- r? 4 4 . ?awn Na ?out?? ?nders-mom. of 99?" ram 7? - m; ?karu (203132 'KIcha: wr- (gr-?5639? \ng awning-l Via-ons . 7114Geo ,I?uc .LVLN, IscasIs-owm'z. W. m. 1 o; CONFIDENTIAL 'l C. 1514 LV 3 '4 (Eco 11,8 . 4.34? 6-7237)? Momma .- WT BA 7) .3 5? Db)? 7,311.56: NMISK 4? INTI Tiff? "~35 135m MUNL. 13! II 3.753;- IEK 3 MIMI: 12:8 33:15: Kim ?Immwn 4 . . .- 0&0 171:6 L33 TEAM . NM Ebb \l EQLW 0 Ernunuf 2 Ir rm; cam! Lanniwmvuom mimic, I . ., II Nam/1J2;- Tag W31 'i nth?Tr . A a . HOD T7577 ?38 30mmet5LV MESH AgniTag, my; [certify Ira! the slatemorls made by Inn on this [am are lruo. 1/{1 0? :Iaf'c'oo ?n :5 5?6) TITS: 7.4 . . -, mm?: Pam Total 561 (FA -: Arm-Int l-omard (M315 [0 '3 Plol's GM 7669? A LA. Tau! Data [6931 i9 '93 ?0.11 WI l?1l1 (J Irma Case 18-2868, Document 278, 08/09/2019, 2628230, Page411 of 648 Case 18-2868, Document 278, 08/09/2019, 2528230, Page412 of 648 i, 2: bm?l (C, 901363) WI 0E ?73 ?-my=nmu7 30124 17v?? L. 9W93rl7?r) nnumjwz Lib-I 973%er ?r11 .- 49? wN? 9 (ma?a/f1; ?100 N61 IS 191? 7Q Rue-9 1M6 I e??go? WW 201mm 9 "a '1?me 0N Wd ?sunpaoou ?9qu #5115 3mm @mxu?0pm mueumulu ow magmaRETQF mag wen IMIWJIMGDI I. wand-q SUOHOHJISUI . 9' ?ram A Points of Don-nun a. Anlvd MJes Remarks PIOOBMI. Nurnh I DEM Alla,? Icra ?own No. Maneuve'rs, MIC?en's o! Laviugs and Mode Identl calor? rx non- To 6430512 3 \l C34 5? vao?ltxe 1:51 Baxff??m?s?f?l - i/l 1755 . . . 0 \1 Meme ?Ben ?ff-3T .r 2.5 is; ?4?752.42 Ba 2?5 . 23, . 1761? 8:3 .0 - 1% . ?fe; ?3,833: m??smw?n ?1 T1251 i 2% - :3 9K sao?wm, 55,514ecew 33g memos,? an Iceniry madobyme 0'1 tht?nnarettue. I PageTcm? I Amoml Forward $32? (LVN: lc? Qq Pilot?s Sigm?urw_ Toll '0 MSG _h?lo? 3 '5 ?32 r?j't??hm r'rtorr'm Db 4p--mm?r?c?r?w?5 A . 3 19w. .Z-QmemCase 18-2868, Document 278, 08/09/2019, 2628230, Page413 of 648 squmsu; Dal: Alf-21a 1-. wt '1 491 Md Maw J?mu .I Am? I 520m 332;: 32:22:10.3 I Amt-n if? ?mm To GLt-m?Vl He {5:17:7- 3IH ?909,13 LFPB 3%31: GMISK $4543? 710cm: PB: 1:51 5124632 s.K sown ??rmgownqu?V 2. '3 3. 2.3 Ewe 344) 3K ?roam (Tau it? . TAG EGGW 37:? mam? J1 . EGGW l??i?l GM 3w. tr I p.615 me GM 3w EGGWJ LFTH VJ ng? I _J_fu Lga? 6'wa G-M 1 I <5 -W EGPH I?m ?$555 302' . i . EGWJ (.qu ma CM :wd' . 41 Cj?ux_ How GM 9: ?mmogm 6M Mm sag?iggz?mmw ?3 AALL Mm TLST ??pfn?v'?ww 3.1M TLS 90:15! . TIST Ben Hos 9 ??25553? '3 ??1111th lhe swtumorls made by form are lm pa?B Tow] IL $7 Z: '1 5 Amoum reward e?qgo ?3 out (3 5 3?3 \311 2? 316-link ?a '5 3 7 . Case 18-2868, Document 278, 08/09/2019, 2628230, Page414 of 648 ITSJ m: @168? 9i Alma? Make Nrcm?l Points 0! Demure Arrival Flight Remarks, Procedutu. N-mee: Abra? 45:; and Mode! F?xown No. Maneuvers. Endorsements an?ngs ?22::53 From I To . 1 (2qu q, (3 4136? ?1 oqrr? _,36 I?m nl?V 1 - . _b :1131 09352 LU .. . -, 29?- 1121 153 12m 125%? 6" m- V- 8 Mnm:?uav9 6i?; NEU I A it"- 1&0 cram {5 I DFW DFW I - 34?}sz ?2 IMAM . 1.53:. - - +130 ?7%!th emmi 159 610835 J?S?mi? a; 11:51:; Law}: .21 Lam?gm?kgw?i?? 1&5 Hg 21 6914497 'Nqonem ?93? @512 - p31: . (?on UN 75231 ?o/Lanm - O?mci _l I I I I 3 1237-190 _Sm MILK. . ??vga? Luz539_ng3 m, I .J __Vt EU: ?11 WU) Ld?aun-r \m ,1 I co . 23?3?? 6mm 092:6 1 Tis?v aw: E231N?1'sv?l?? mm )3 V1 Wham Cuc?or Page-TmSgnamo 4/ Totalln 65- MILO 3 3 ?33 1 1? oars-M0; Case 18-2868, Document 278, 08/09/2019, 2628230, Page415 of 648 Dam. Alm? Make Alrcrah 40-: and Model Mark . Q51 Fron- 17-23-31?- N?o?z? Ew . - L9 ?w LVPB ?1 LFTB \l I EWR (bvml-Io?l Ll l?m Ls . ?3 .1- Jgiijrvm 03mg 3w 10 1? 4&5 13lw'tify lhat lhe made by me on this am lluo. Fun: 5 sgnatu's I Points of Departure Arrival . . Flown No. Mnmuvara. Endorsements ew2__ LFPB 5:10?? LF LBJ TEST 5W3: EWR Ewk IS Pr I Mlios Film Rom-rim. Procedues. Nun?DeI suonannsw ul - I mm Almaty/(?Kr ?gm _g5_?gm 32,5 951,354 as p, mum-Page Tow! Annunl Fnrward Told 03!. Alva-fl can'F-u -: . - y. 63km gif-?E?lat??l? 8179 40 9L17959c ?0838898 939C) suouonusul Dab: Alma Make More? Polnts ol Dopartura a. Anival Roman?, Procedures. I Number Alrern? 2.19.: and Mom-l Illulm?wlmn Mam Mamuvon. Endorsements of lmu?rgs 1M1 I 1? 1 Eg?frl?l?zl??Nquje EW 3 IS .10 1H1, I 0 BL. ?llb'g 23 o-nsgs N?io?s??lx?i? wss? 7. up 3 Nqome ?wR T133 mg?, :9 '5 115T ?wR mm LA. (735ch T153: BM Ll . gw? $.1ng \qggr?ro pew 0r B-7z?-mn Naio?? Ew? I443 cw .1153" mm use 06 1193 ignom?m ?9 067); PB 6mm. ,T?cvm Twas?mine?: P?m be?? PB 1 ?n?zm Pris?? Tat-91011118, Amt) . . u? - . BUTD [Z?w'flamr 3TJ-ZV-L7- mom (- r: u?uao. E?i V?i 53.x,? efm?m T0 mww???69 3mm vat. $611wa manic lce'?fy that the made by me on this fun are me Page Total Anoum Forward ?bi/LE Piiot?s Sigu'um 1 122212 71L, Tom on. 67-91% 40 . 8179 40 AL?Ve?ecl ?0888393 ?818 999C) Airman Make AJrcran Point: at Departure 0. Arrival Muss Flighl Prue-dams. Numbe! 1 Alrcm? ?43: m1! Modal Flown N0. Maneuvers. o'Landings 9.051 me To Gum uneL c. 03 ETD .3597.? Bed. F9960 - 5294?? Bath r7 Fnocc Tran Aer .. a SK ?7 614-" ?7 0 1: 51?? mm?g 937. Pm 89$?ng bragm?sim 11134713551? ewrl T251 4 145a by TIST I451 23 CMH n52 2K, 7:5 ?W'Lmi LL- 5i? 2.9 .. TIfgxza?? Ewe um _75 8 G?EquV??li?ii?breiFlDENT LL13 ALWE EL 1 Ewart 1135?; '5 1? 1131? 146?; 2 1 '23 arm I100 1; Pr Mm may.? 1.2, v? Mff?r ?3 0 2945?3 N?io?igfi {qu a T623 Mint mm 6H ?an-m? (:wa .463 '2 1 Icemfy Mame statements madehyme on m: form are true. nagomm 5/5? 6 gem :5 '5 ?55- F'?ol?sSlmalum 31% ?32115; 1? ?5 3 ?65 lg 8179 40 8L17959c ?0888898 ?818 939C) Altman Make Aircraft Points 0! Doparlun e. um"! and Mada! lue'?ztlmuon Mam Hum '0 147-140 MIG/vs?i?r TEST B-?mxbm N40011: Ewe cum Moos?31' Mi 1:3: nva moss? _u HBQ II quge P811 t; a 217-17! 0836 N??o 1e ?7 7:19)} 0 Wm? 115: ge. I cenily the! the slalcmoms made by mm on his lorm mg 1rua cw}! WMW M?es Fug-It Flown No. Remarks. onceduns. ?moum. Indiana-mtg IJISUI Nun?ba' u! Landings Aim-? Cal??1111 Pagn Total Amour? Forward Date gag 882$; "-35:09 2? 8179 40 ?0888898 6108/60/80 ?818 939C) Pomls cl Departure 8. amv-I Was ng'u Human". PWIIMI, Alien" Maneuvers, Endorsements an? ?0119.! i 4, 4:566 I unity that the slatemenls made by am on this ton-n are true was! 3 [65 Egg-7.116 958 999C) 818 lueuTnaoq 8179 40 0817959c ?0838398 . . I -. Dale 2 39? \f Autumn Male and Mode! (3?054 lb 8 5721-160 J9 r) -l 9 ?1 G-nsq .if}, Ammll Palms of Dopavtun 8. Arrival Irlemi?callon Mark F?om To 1?1261 :6 - SzanMa?L \l ?l N?io({le??AN (5 (CE I 09.1in M1 the statements made by me on (om are true. pm swag (WA. ?bdz?g suononnsul Moe =light Remarks. Procedures, I Number Alrcm? Maneuvers, Endusenlauln 0! Until)"; No I 5- _L_v LV L): an on ?rcrz?v - ?WM-rm. C. n?znvn 93?7?bw MIJLH 1.1mm?) We - UWTHL 074)) Bomb-M? Gnezmm rs gnagg?eN-CRGW L133i. Page Total Amounl Forward Total to Dan, 8179 40 $173596 ?0838393 ?818 999C) suonomlsul ?if lumen Mam 'Amaty Points olDeparmrelAMvd Was Right Number "anneal-any": anauoce lumurmmlunMaIk kan Nn. unneavomsndonomma alumina? g: 2006 "cm 1? momma "?35 mama 9:64(101? 2?1_ ?539 7 3: lb B?mr?bm N?xoax? UQQ tier u, g?-nsm?quqse TIST Ewg?u, 101:61119$sz L\l_ . g: g; ., 25 gm. auger/x 333; a 096 a gs 2c, nmmj?pms per. g; 26 ?33. W111- 15?? zew LV 5 ?it TEB zone El} 3.3 l? 1:51 T66 21?) LV '5 7 r) ?7&6 Elmo 2N8 . LFFB LL60 ILMK cum LV ammo Page Tom 5-1.3 3q 5 Amounl Forward 9133:. Q- 3 3 W104 63:2, ??3313 3 3 ?15 236 82' 8179 40 8317959c ?0888893 3108/60/80 ?818 939C) 33x13 tr? 3 3 :1 .. Amouanonvard PJot's Signatum {35%ch . Fi? lo Date 23:12 bq?x? vase Tux-m: Make Amen Point. of Departure :4an Hum mam nmuI-.Pmdures. Numb? Alter-? 1.. 1 andModol lden?flcallon Mark Flown No. Maneuvers, Instruments 2; From To 918M CW (rum Nqitf?. Lang. 2w g1 EV 59 361. .. cm 3 Tee 4sz .w11 5? i; 166 . I 274__ 3 7 "1131? ?we: LV 3 BJELWLM qucm 11:214. 3L . G-us?m Nqoqggji?nm 2030 LV ?5 4m 161 3:127:53 61083.2 @8123 TKC was ?1 a-nsm MW ?631 ?53? ?ma-?NH Nom??flx?? QQ H84 ?15? Ll g: ?Elite-m (5 ?Nqoqxzz 3131 PDK 24213315-1213)? Nq'bgg? - x3, ?1 1-3 SIMOLJSTIOR M129 MEH- 3312?;meme 2 0 TT 1 1, 645016 PM PB): 20% LV 7 ,7 LL. ?ii-J43 sf: 09?? 31.3 SEE 1095?? LV 3* ifwarm that the sule'uents made by me on INS fonn are Uue. Page Total 3/93 35 01 53013 ,1 8 8179 40 831795133 T818 939C) Date 49?. Amaft Make and Mooel A'rc'an lamli'lmhon Man ?g (3421 3m 52% ~11 G- {is??16 FW 1' 6 ?Imam II :4 ?4 \l I 2% 6-1271 am HOE-56 m1 6 3 '7 8513-: BL 29 1K QOBIG NQo?ng?" en Brian-313 G-n e; \l 1 (3*717?190 2.3, 3? '33" 6 Icer1ily Ihat [ho staloments made by me on this tom: ane1rue? Plot's Slgna?um (M 96 Palm: 0! Dopanuro I Arrival To LC 04w ?816.16;? _91? ion?s ?Moms 91L 9B suononnsu; M095 Flown No. Remarks. Procoduns, Maneuvers. EndoncmeMI Number 0! Aircraft Gait-12 0 TVI- nvpf?cgcp \c ?ma: 10 new Lny?'p?d?. SC: L5 (gt?19M ran . Lumum - Ltg-Xb cam/11.? lb 5?8 Page fatal Amount Forward 1. bad? Total to Dal_f1, 1. 1114.5 ,j -11 ?1 as 8 81?01: .21 mg 8318 8179 40 17317959c ?0838898 ?818 999C) sunuomxsul I Data I Alvnm? Muku Alum" Points 0! Dcparlun A Arum mass :anm Procoduns. 19?) mm.- mm curim Math J, . N?urrbeu Alrcmu Ei-"m invm anouvms, ndommonts 0 Lancing! Jr" . uuL- Gum. ?x J- LL 5:39-31: N?toqxc PSI: 61mm? 08% WW Iconi I) that (he slatanuc It: made by mu on [mm are .me. Page Total know: Forward -- j: P?oz' Signalur ?0 Total to Date ?1?;qu - 8819 8179 40 9817959c ?0888898 818 8988 3 suouonnsul Date- I A-?rcratl Make Nrcra't Pohls oi D. F) I parturo I: Arrival MI ?aunts. dung, mu and Identl?canm Mark 50h Mn nnouvars, lnzornomon nu I Nn. 10 10? I From I 1T0 M92 7. 9mm 31910213; Pg- fj? 'nl J16 *2b7f?T ?57 5, .2595? -LV ?3 xB-m-w Spam?m 11/119; M939 Fe ?gammy 30mg? 14 \l ?1 CBFT Lcjg?mga g3. P6: 3cm) Rosenss 15.141236 Mamie Tag ?34% Ev i? ?h g; A?lcran Ammw Orr-wove?\Ahm ?i .. 2? I E-l UL ?nal-?40 j~ol~?L c479} . I amt-m I Case 18-2868, Document 278, 08/09/2019, 2628230, Page426 of 648 laxomrr ad 4 Pa; T68 "1 33W ?Va? 951 A 6?27?1w Mia M19 [6311- ?(drama 35.? {5 ?ho nibXh?s aro' hue. I I 93.. q'Tota :1 L?q PM. I. ?omlil?olwmd ?5232: ?bSS'l 3 '1 831'?. U?Ennu?o i 2 . roman Oft- ?3 hbsquS Date Make Aircraft Reno-ks, Procedures, Numbev Aircraft 43.; Idenl?mt?on Mam Flown N) Maneuvorc,Endorsomnu ulLancinga me To A PSI 96,: 0 0 ?3 cmsqe Njo?smmi 0 an bef?jh?pen . an 20 LL (961' and? DJ 2\ 4 E61. 9. ea: am: 3 1 ?61m? 1?51 16?? LV 53.? 96% 1' 2.8 1013:. 3 Tag? o, pg]; 1_ 1:51?_ JLoqqr L91 c! ng'ST 981'. +2913; LN H2, g: .2933: ?(as 4 ml u, .. .. 1.T53 16*" I 23 any-7.00 M19 M119 HA I N?kb?m?? VB: 1131" m, Ly u_ 1:151? . QB: has ESL 95-; mos LV Icon'ty 1halthe stalamem: made by no on [turn me two. Page Total 36/ ?0 ?6 . . Amou-f {onward r2 pun-s sma'ua 2 4 I 5a Total to Dal. Poll?; 0! Manure I. Arrival E1 i3: v.01; 1, _f WITMFM: -: 1 $3 DLR 090097 so ?JolAidnlac?Case 18-2868, Document 278, 08/09/2019, 2628230., Page427 of 648 -- . - .. .. P1tm's Sonnh'a ?53131?? i?kuonum Flown 337" 31223;? . 0 gag-ma mqje. 6LT my Q: a. 6 leer Tee 2 ?l _u ILFFB m3: 6? ?1 'LFeb 2\ 51 ?z?a 2.5 753 PBX 2319 L'l 97? 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Page Total 2:23 ?oat, 3 Totallo up? mL ??qu 3 3 817940 18179596 ?0888898 918 939:) 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 ALSO PRESENT: Sandy Perkins, Paralegal Boies Schiller & Flexner 14 Ryan Kick, Videographer 15 16 17 18 19 20 21 22 23 24 25 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 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 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 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 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 278,,08/09/2019, 2628230, Page461 of 648 0818 Number - . . PROBABLE CAUSE AFFSDAVIT - i. 3. Request for Warrant Juvenile N. .A. I 2. 4 Request lot tea 1 1 cm ADMIN. Agency OHI Number Agency Name Agenm/ m2PALM BEACH COUNTY OFFICE 0i6- ?.21 -00, gygil [1 Charge Type; (3th may El: Felony a. Miedememoi Ordinance 2. TrettIc Felony 4. Traf?c Mlsdemeenor 6. Other .. Name (Last. First. wane) Alias Rm 5011 MD ip?bol?l Mm. u. l)m (I) Ch Description If}? Charge Description u.I Mg in?anid SKID Did l\ Cha Description 641190 Description . . . Victim's Nam (Last Middio) Race 501 rem iy . . - mimQLuneD Local Addtm (City) up fie' Address Source 9 I. Sagittmm ail/4i 368-052 web/c, Bulsmees Adetese (Name. Street) (State) {Zn} PM Occup- . - - . . The underswedeertillos and my: that humane: just end runneble?qounds to believe. end does believe tl'u: the above named Defendant committee in. IIowmg violation at law. The Person taken into custody., . committed the below acts in my presence. . . was observed otd 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 myI (described) investigation. 0n the _mjd'ay of at DAM. PM. .(ISpeci?celly include lacts constituting ceuse tor arrest.) -r .5. wt: H??lg? It: 1:31 I -I minimal 213?. 1- in c. -O)Att.? ft 1 fit 395* 7?9 fifizfx 59:: u. Wm MMQBABLE CAUSE STATEMENT '1 9? L. .I_Ayt?Mott-53.. InnioA - UJ SI lug?A" I. y) --, .. .I?moo'rji" hf I . 117. .- . . - _.WHITE State 111nm? .- YELLOW Adena - PINK Aaencv . Case 18- 2868 Document 278 08/09/2019, 2628230 Page462 of 648 GETS Number - PROBABLE CAUSE AF DAVIT 1. AI- 3. Request 10: Warrutt Juvomle N-T-A- 4- Ramon for Capiu 2 Agency ORI NumbeI Agency Name 5 . Agency Report Number 2 I err-510.0 1.0. o. PALM BEACH COUNTY SHERIFFS OFFICE i016 -D-Q ll 4/ ngI l-?i ?low a a. Misdemeanor 5. Ordinance . . . . 2. Traf?c Fuiony . 4. Traf?c Misdemeanor 6. Other u; Name Du. . mom I - . Aha: Race Sex UJ - - I) 3 Chuge Description 0 I ?1 Change Oucnpuon . .F~rst. Middei . . - - Race Local'Add A Nu 1b} CD ?ziprLI-I/ um . 3 never?? mama 32ng S270 Minna . 8min.? Adare'sg? Name Smut) (City) $(Stalei (2ij OccupaIIon . (p a) 2" gadgzm :23, mafs that he/she has just and reasonable qounds to believe and do? bet at the above him I Dolendant wrangled the foaming law committed the below acts in my presence. - . was observed 1/ confessed to . - at helshe saw the arrested person com I the beiow acts. admitting to the below Ifacts. - as bond to have oommited the below acts. resulting from my (described) investlgatlon 20.2. at DAM. [3 PM. (Speci?cally include (acts constitutlhq causoIItor arrest.) . - Ia ?aw 41 La? II.- I- WV It?I?Pru 1; . - .Z . I (IN-5 . 41.Inf";- .1bh A a. ?Imm 1 01139 am {353m 09 5? ma jugAft-2i? (1181\1?771 LLQA C339: (9.2) 7Q "g iijiI-II' ?1 QIOIIMA 931% with 7-1? AJqu . . I a '14:r3' ..v/722Lil?vvr'111'?- ?72 f? - 5. ?5 3:31?459?5? ., ?53. - . If I 2,1: '15, - i a .II5.5.3.1152er ms . - 2. ..-- :?MaIn? l??g Elf; - v: 7 953COPY 0f the .?ecord .n my Off' CC. Wli . 51.15.5482 - r: ons law as remlred by WWI..jeim 9 R0 -h - COMPTROL . .1 .- ?Fl JIM '2 ?It" 5? .1 CLERK 9 . ?til-(l Ah? Wilealmemnpamnal'yknowntomem/ [Id ti {filmPAGE ..-. - Cnov .. QIavo Arum-II I nw sum II Case 18-2868, 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, :13, TE, . IT: A -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 goowd 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 03'st day ofAOctober, 2002. sme or FLORIDA - PALM BEACH I .53 .1 . I Less: an:sexiness tum Wm ?33 ?2 (Ensign: We? DI lax. NOTARY PUBLIC, State ofFlorida . IggyROLLER es? Enen Jord muses GRAND THEFT 23 99 By wp?g 8mmjDecember 28, 2002 "-130 TROY FAJN WC DEPUTY CLERK ocument 278, 08/09/2019, 262?826Page464 of 648 ?nxg?? Case 1828? IN THE CRIMINAL DIVISION OF THE CIRCUIT COURT OF THE JUDICIAL CIRCUIT OF FLORIDA. IN AND FOR PALM BEACH COUNTY moo 740a (A) 01/23/2003 11:35:12 am OBTS NUMBER on BK 14720 no 1935 3001076!? Palm Beach Count STATE OF FLORIDA I 1 COMMUNITY Dorothy ?uke? Florlda CONTROL STATE 0F COUNTY VIOLATOR -. . I Newby certify that the foregoing . true (.095 of the recon: In my 0.1ILO WI In tions,? a re 'red [3le . .2 IS ARON a. e' B, MPTOLLER DEPUTY CLERK I PROBATION IOLATOR . RACE . GENDER c1 Having entered a plea of nolo to the following the following crime(s): the folloiving crime(s); 4? Having been tried and found guilty of Having entered a plea of guilty to - OFFENSE STATUTE gmmi 4 I and no cause having been shown why the Defendant should not be adjudicated guilty. IT [8 ORDERED THAT the Defendant whereby ADJUDICATED GUILTY ofthe above crime(s). and having been convicted or found guilty of. or having entered a plea of nolo contenderc or guilty.regard ess of adjudication, to attempts or offenses relating to sexual battery (ch. 794). and lascivious conduct (ch. 800). or murder (5. 782.04). aggravated battery (5. burglary 810.02). carjacking 812.133). 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/orl 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 DONE AND ORDERED in Open Court at Palm Beach County. Florida. this 15, day 03f; . 2003 - Case 18-286'ocument 278,,08/09/2019, 26282?Page465 of 648 PLEA IN THE CIRCUIT COURT THE FOL OWING Is TO ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: AI LUIS ZQC EQIAJIOQ Plea: Guilty _X7Guilty/B?s) Interest ContendereU_ Case No. Less?er De ree HEIDI) 803W Gil: H. CL I PSI. Waived/Not Req ed/Requeste Is: our ADJUDICATION: Courts Discretion I i 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 RI PROBATION IS SCHEDUL TERMINATE UNLESS STATED BELOW. STANDARD CONDITIONS OF PROBATION HAVE BEEN EXPLAINED BY DEFENSE COUNSEL. a. . CONDITIONS OF PROBATION: Restitution rthe accompanying order. Check if ordered) $7 360 CD FineLji Court Costs: I Drug Trust Fund. 5373 00 Cost of Prosecution 5 9 Public Defender Fees/Costs f? 60 I, I 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) 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 OTHER COMMENTS 0 CON-BITCH . A4 5% . A UTE. 14,0 UIAATQAA I- MM SENTEN - d?br?h THE riff . OR IS ARRESTED ON :1 CI-IA GES. A PIA er?h E0 A Iii-.1 (I: ice Own PHI- In rehatonsuif?a rva'gedbyla?I out fit-:43 .-- ASSIs ant {7e A Dfendant X. M7: xg/tx-MDGM_ Date of PleaI DEPUTY CLERK Defendant . A lhnn?? Case 18-2868! Document 2628230, Page466 of 648 In the'Circuit Court of the Fifteenth Judicial Circuit In and For Palm Beach County, Florida CaseNo. blotlzah comp Division: VJ STATE OF FLORIDA vs. mini it) . ?4th?: I 1?qu me'i'i?f ?g \Muwl LW 9 Pi 5 L. er 'Defendant I ORDER MODIFYING PRO f" - 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: OWipa/?hOt/i wan/k vinyl k0. Monti/6 hut-WW ri? wili AM Odom mm!? \rcmaMttuv?M 4' Defendant admits the Violation of Probation. 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. . DONE AND ORDERED this day of 6V 20 a .r . STATE or FLORIDA . PALM BEACH coumr a . E. ?if-"bf "o I hereby certify that the foregoing is a i? true copy of the record in my office 1' I 5 AA /Circv.}t{ Judg/ - 5? DEPUTYCLERK 35 MAY 25 2955 Case-182868, ocument.278, 08/09/2019, 2628230, Page467 of 648 OGTS NumDoi' PROBABLE CAUSE AFFIDAVIT I. 3. Muesli lor Warrant Juvenile I i 1 I 1 2. T.A. 4. Request tar Capias Agency or-II Number r. Agency Nam. Agency Report Number PALM BEACH COUNTY SHERIFFS OFFICE 6 HO -11. 10.1163. J?lel . ngg?y'?rm 1. Felony J. Misdemeanor 5. Ordnance a: 2. Traf?c Felony 4. Trent: Misdemeanor 6. Other . luLl Name m?m. Withdraw) Ana; Race Sex 5. rem-159 . (a Charge Doscr hon 1 Charguo cription 5%;de I E55 Charge De plion Charge Du?tpuon Victim's Name (Last. It: Mi Race Sex Date 0! Birth 2. {45600 .lt?rr? {\me Local Address (Street. 'Aof. Nil?tuber (City) 0 . Phone Address Source nine L524) 383-0320 tum-t album Adar/?mun. Street) ity) tat Ip Phone Occupation 3 mm, I6 The undersigned certi?es and near: that helshe has just and reasonable grounds to believe. and does believe that the above named Delendent cornmmedune foiktwing Violation oi law. The Person taken into cuuody. ?3.10 .w committed the below acts in my presence.- - . yells observed JA mad 1 I :5 {31? - yr confessed to - hat rte/she saw the arrested person cornmit the below acts. ?3 admitting to the below iacts.~- -. - . . . Klara lound to have cummited the below acts from rny (described) investigation. - On the day 0! 20;.at DAM. Cl PM (Specifically include facts constituting cause lor arrest.) 4-.- - .. - . .- . a? 1 . . ?xmnnornb *r'irxnd? jhmn? Eng-- 4&xxom0 1M mtjlom {One} and sfmeutsm .. ?fn- A . . 1 mow-11' . . . as}; a" . if?? ?1333352:12: N- 35211vg'v .. . . If: 5512??: ?Wage-?-33 p.51.? . . .A-I .. t; :5 .. ., Jy?jhADMINIBTFIATIVES I i I STA -.. FLORIDA 33.1/ego wholspetsonaiymawntome ?Iyz? I i I I Pam e'md?v mm DISTRIBUTION: ??75 - CONCOPV GREEN Stall Morn-v YELLOW Money PINK .. AnbMv i Case-182868 ocument278, 08/09/2019, 2628230, Pag?468 of 648 . ?1 3 0835 Number PROBABLE CAUSE AFFIDAVIT t. Ant-J 3. Request for Warrant 4mSmut for Capias 2-5 Ag?nc?y ORI Nut-that Agency Mm . Agency Report Nu $01 no 5 o, PALM BEACH COUNTY OFFICE 6146 IO 7 Q2. . $033.33.?, 3 FWW 3. Madam?; Be 5. Ordinance. Special News; 2 Tlal?tic Felony Tame Misdumoanor .omr . u; Namotle. FIWII) Alia - 99:. Sex 8- HQ- 07 U) Ducmmn r9 cosmiption Lu 3.81m de JAE-Es Riz . Charge Description @955. D'scriplion . .. mJ JJ. {Jm r: J: ?my VICTIM PROBABLE CAUSE STATEMENT 7.- . t- - rfm-if?niu? ADMINISTRATIVE??vi'n?glr?g. . ah}; jJ-nw 1. mom13;. it - I. 3 "-1113 II. gut;- u- is" u: '41.11. . -- A. 1?1 ?All. "n - ?Ju? .3 ?nd ammo Ct; Dun? 3 Local Add at rest (City) a) (2.) (Phone Mums urco 3 a! I . . me ?3.937.032 {feast/OJ Human Addtus (Ngmo. 5% . (Staten (zip) Occupatgt-The nd nod cmmo a am that hot he has late a do The Bemalm high?? ?33: 3 just and reason: gram 3 to believe; and the mow Widtc?im the tollowing violation of law. committed the beibw acts in my presence - . . -M"as observo?diby. I whotold LL79 ?51- CI confessed to 1- - helsho saw the arrested person cummit the below acts. admitting to the below facts. . was to'und to have commitod the below acts resulting trom my (described) Investigation. On.the day of at CIA. M. P. M. (Speci?cally include facts constituting cause for west) 5m 0: JUL 1 D?n 'B?S?F?itb: Jn - . Ali-1* Juan BATCH PX J?Vi?d?mim wig .- .0 Jig II, (Mn, G??i _Ird ?n 1er- a .. m? .63341710) - 0? ?l . WHITF Chm-t C?rw Emu?J VCI unui CaSe 18-286i Document 278. 08/09/2019, 262823 P896469 Of 648 oB?rS Numoo!? PROBABLE CAUSE l. Arron 3.:Roqmsl for Warrant onnilo I 2 I I . 2. N.T.A. d. Requosllo! Capt? Agni-icy ORlNumoor Agoncy Nun. Agency?eoon Num gm, 5 . god-o. o, PALM BEACH COUNTY 6 sr?j 7 7m. 1; 22:; g?ggy gt Felony a 3. Misdemeanor 5. Ordinance apply. 2. Traf?c: Felony 4. Traf?c Miiaomoamr 6. Other .. Name (Last. First. Miriam)? giitic ti .W amt: 72/55? filial ?All Mr .153 9-4111 {3(le Charge Dmripllon C??argo Description CHARGES-DEER: Victim' Na First. MiddiI) Race ..Sox Pate Birth . . . Local mam: ?Slreotik Mb ?0:33: (Stale) [Bl Phonn Address SourE? <52 fr??i ?lth.? i tar? QTOMM ?Jr: (r :137r057n 0 Mimi; minis. Sushi) - (City) (Sun. . ?*Fnona ?ma . 0 1 l'ho undonlgned cpm'fiurand swears t?it hustle has just and reasonable grounds labelieve. and don bougve that the (above) named tnndant Committed the toll wing violatlon of law The Pa :3an into cuuody commimeld the below acts in my presence. was observed ?rm wFio told confessed to at helsho saw the arrested person commlt the below admittingto the below lacta. as found to have commited the below acts. resulting from my (described) investigationPM. (Speci?cally include facts constituting cause lor arrest.) i 1 .. --. my?: I . a - - mania .. -.- I I Lf-lAh Iqun?m?in. II 4: . a In? 1-9-x. "o I ?Ci It. 1?41irw?mtr?x (11erde 305mm 1. . .. 1 ?xiomm Am - I - 9.5 .0 Anon?i Tn 3 anmM 3 ?Um (Ox ??th Ely?n}? (i An MD (DAG ?x \f 3? 1mm wxi?_ Ev I CAUSE SEATEMENT . a Li? I @135 taEux?f - ?Igor If?. .53.. I 'h'i?h 'gp?hi" ?7 ?if: ?an? - - - - :w'hete 111mm: brewing is ?17: ?3 1 1? ?353 .?ttue comrewd?nmy Maximum..1 ONR. Bock - - A DEPUTY CLERK- ADMIWRATIVE 5W/?ub?c rt I?m; an, WW5 - COURT COW GREEN State Anomey - YELLOW Anoncv . PINK -- Amncv Case 18-288, Document 278., 08/09/2019, 2628230, 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, 7-3 LID 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 permanentlyortemporarily 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 ofFloIida . STATE or FLORIDA . mu BEACH COUNTY 53.: 4. 1 hmeny certify that the v.15? Ellen Jor FCIC REFE . 'fa. rue cripv of the fer-0": '3 ?ltvcorz-ia.1tssrom c5337? EXPIRES .- was. a - GRAND THEFT x, 6; - Memberzmooz NDSD mac worm? INSURANCE, wc ?g ?j Case 18-2 Document 278, 08/09/2019, 2628 Page471 of 648 IN THE CRIMINAL DIVISION OF THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA. .N 11:36:12 OBTSNUMBER DR BK ?730 PG 1937 Palm Beach County, Florida STATEOF FLORIDA COMMUNITY Dorothy H- Hill-ten, Clerk - CONTROL VIOLATOR V. DEFENDANT RACE VIOLATOR Dog only H. . t: The above Defendant, being person I I 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): crime(s): h? COUNT RIME . OFFENSE STATUTE NUM DEGREE . W. wintertime 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 ofadjudication. to attempLs or offenses relating to sexual battery (ch. 794). lewd and lascivious burglary 810.02). carjacking 812.l33). or home defendant shall be required to submit blood specimens. conduct (ch. 800). or murder is. 782.04). aggravated battery (5. 784.045). invasiOn robbery SIZ. I35). or any other offense speci?ed in section 913.325. the SENTENCE The Court hereby stays and withholds impositiegu?entencc as to countts) and places the Defendant on STAYED Probation and/or[ Co . r05)? ontroal the supervision ofthe Dept. of Corrections (conditions of probation set forth in separate or cc mt SENTENCE WE oi or?? :32? mfg; DEFERRED I The. four! ef?eb? *lgil?fl .. .rd Iling notice ofappeal with the Clerk of Court within thirty days - . W5- 1 The Defendant In Open Conga?; i-If. ?lth. following the date sentence.? n? - uag? 'lOl?l. The defendant was also advised ofhis right to the assistance ofcounsel in taking said ap'a?. se ofthe 599$ I - 3? DONE AND ORDERED in Ope'n? - at 0? W-lgrida. this day of . 200 {3 3' . Case 18-2868, Document278, 08/09/2019, 2628230, Page472 of 648 W14116 Of?cer: 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 Defendant Case No. 02-122050171310293 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 Of?cer. You will neither possess, carry or own any weapons or ?rearm without ?rst securing the consent of your Probation Of?cer. (4) c: \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-182868, Dooument278, 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 the record 111 ray gigpelwdu win-M .- chonsMap??rho .OL - I 00 . Case 18-2868, Document 278, 08/09/2019, 2628230, Page475 of 648 In the Circuit Court of the Fifteenth Judicial Circuit In and For Palm Beach County, Florida . Case No. Division: STATE OF FLORIDA V5.1: 1,13; 1131 La. 1} A151 Lu? (J P15 Mew:- Defendant .1 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? 5P obation 15 modi?ed as follows: 01/1- Who 1/1 a We a, mop L0. Mix-?Aw bid/t ?Jam 1,11 Uwchu/t?o 0? Odom 0.1/ animal/111121 1. Gamma,? CL H, em 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. - DONE AND day of 31175?? 20 0 {fir- STATE toregotng 1% .e '1 ?nerebit (1911- {51 that the 51 bottles: with . . - '1 rm ?n 1 1110?? cm t?%?0nsh '11 51 (111x120 -. 11.1101, :9 .11 c111~ 1.0 twee" 8V7 Begum CLERK MAY 2 4 2005. 01216 (?19 $8 8 18-2868, Document 278, 08/09/2019, 2628230, Page476 013435 7 NOTICE TO APPEAR . JUVBHIIG Refena 2. N.T.A. MUG: 8" Warrant Juvamlo OBTS NumberJ 5T .0 0 OFFICE 6 - ?many 1- Fm? 3- Misdemenot as apply. 2. Traf?c Felony Locinon or Arrest (Indudng Nsma ol 'u 5. Ordnance legible . . stance c. Tre?Ic Mlademeenor 6. 0mm 1 Indicator ADMINISTRATIVE LoceIiOn of (Business Name. Address) arrest JeiI Dale Ame Locsnon 0! (Last. Middle) I Rm Allan (Name. Soc. - American Indian menu. 0- 4/ .5 . Moos. Uanue Alcohol Influence In?uence - we: I. City 3. Flonda 2. County 4. Out 01 Stan: Address Scores 4 usiness Address (Name, StreeI) - (Slate) Occupallon DEFENDANT Of Co-Doiendam Name Date 01 Peron! F'rsI I - Lsgei CusIodiaI-I I '06 B) Other: (Street. Am. Juvemle . within 2, 161 Has'mvis Dept. and Released. 3, NVENILE above address and I . Ilg? [hi Juvenile 83.3% gunk?; g" or Imam was told . scram} Amended Yes. by: - [Yes . - Type . . UnknOWn N. . Producel. A . Cocaine . . Z. Other P. Possess Herom . Charge Descruplion Counts 81?07?10??: VIoIatiorI Number Vlolation of 080 CY . 0 I ICapias Number Bond CHARGE Drug Drug Amounll Unit Number Violation oi 0RD 0 I I DY Drug Drug Amount Unit CHARGE WarranI I Capiu Number Bond 17' Count: Domestic VIoIaz'Ion Number Violmion of can I: Vlolen c_o CHARGE Werrem 1 Nu Der Bond Smule Violalion Number - 0! 090 Drug Type Amoum UniI I Number CHARGE I . . Locetlon (Coun. Room Number. Address) - 2.3 Conn Date and Time - . ,1 55: f1"; Moan-I You Tums AM. . rm. if?? I AGREE TO APPEAR AT THE TIME AND PLACE DESIGNATED TO ANSWER THE OFFENSE CHARGED on PAY THE FINE SUBSCRIBED. I SHOULD I WILLFULLY FAIL To APPEAR BEFORE THE COURT AS REQUIRED THIS NOTICE to APPEAR. THAT I MAY BE HELD IN CONTEMPT 0F coum AND A FOFI ARREST SHALL BE ISSUED MTICE T0 APPEAR smeture or Defendant (or Juvenile and Perenll Custodlm) Daie Signed HOLD 107 who! Agency Name.- Dlngerous assisted Men of "?65 LD. 1' Other. AH Mn.) LD. 0 Tremponing LD, tr 3hr? Name Venticetion (Punter! by Arreeree] neve?swpasagned 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 Case 18-2868 Document 2628230, Page477 of 648 OBTS Numbe' - PROBABLE CAUSE AFFIDAVIT 1. Arrest 3. Reouest lot Warren! Juvenile '1 I 1 2. T.A 4, Roquut for Caain Agency OFlt Numbet Agency Name Agency Report Numbet 9 ml 5 o. 01 PALM BEACH COUNTY OFFICE 1 6 113:)l 1) A ll2 [ll gmgeagym: g; . Fwd, 1 ?Memo? 5. o?dmnce Special Notes: . as apply Tra?Ic Falony 4. Tratlic Misdomaancx 6. Other Last. First Middle) Alias Race Salt 4: A . I Charge Description Charge DeseriptIOn CHARGES DEF :Charge Dosaiption Victim' 3 Name I(Last F- wot. Middiot Raca 5.: Data 0' Berth t/I?Ago .. .. ..I I 1 I I Local Address nut. Am. Numbort" (Cttyi [Swot (Zip) Phone Address Sourco Byainass Morass (Name. 5 (Sign (Zip) Phone . occupattm 134 I The undersigned unifies and that- helsho hos lust and assemble grou to helium. and does believe that tho above named Dolenaant the following vioithon at law . The Person 13km into Custody? a committed the below acts in my presence. was observed by Whine told j/S confessed to - I a that helsho saw the arrested :3 son commit the below acts. admitting to the below lacts. was lound to have commited the below acts. resulting from my (described) InvestigatIon 0n the ?i day of 0 C-?l?olo 20_0_2u CIA 81 P. M. (Speci?cally include facts constituting cause lor arrestTrecg Q9194 ?Btegh [mmiic (15,293?: 14:0 A P850 (?ka 39.22:} a?otgia 55f Sim-i. M??qc?ir? 'Piml LO m" +006 Mk5 -..L . 1350 A. is it: ?Dk (01016! 120;. sing", 1L: Sgsa'gcks K153 ?7 VIJCQ 6; PA) hookah ok?eur ?k0r+s {3 Qinds?hhoro .3 7? 301 Waiter.) West. 639/?; ?iaigA?Ja?g ,QQgAlse g?g?gts Mfr; ?9 "'95 ib??f Iggy?2. keghvc?. ?rite. ?xarz I PROBABLE CAUSE STATEMENT . comm 3:35vii-1?5 tummy carii?ythatthe oreg-I . . - upyo in tha more in my office :g . -. ired by . )7?me ADMINISTRATIVE 3' DEPUTY CLERK LOF .2. D?cn I Nvu new nun 0157380710?? WHITE Court CODY GREEN Slant ?tnmm VCI I nw Ina-ban atuv Case 18-2868, D'ment 278, 08/09/2019, 2628230, Pie478 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 - we. vs. . 1:3 ANTHONY LUIS ZAC FIGUEROA, 3.3 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: ILL ESTEY RICHSTONE Assistant State Attorney FL. BAR NO. 0928933 CLERK AND SHERIFF T0 RESCIND NO CONTACT ORDER 251% or mama - PALM BEACH COUNTY .3 . Dummy cartily that the foregoiflg . . .. m, ?1 Con-1 in my of?ce ("am-3 .53 (We. sr by In mo (1m, CHARGES DEF. VICTIM ADMINISTRATIVE 08 I Numhat Agency ORI Number FLO 5 0 2 799 Chock as many as A gun:y Name 800 1A Felony 2. Traf?c Felony 3. Misdemeanor 4. Traf?c Misdomalnor (Last. First, Mk1 ierAn Cna'ge Desc?plion on Luis Zac Grand Theft Auto Charge Desorption Vlslim's Name PI uoro 'chartI) Jr. undersigned and swears that ho/she and reasonable The Person taken Into custody? El committed the below acts in my presence I: contessed Io admitting to the below facts. On the 22nd I met with victim Richard Fi rIve a ome to ut were no we day of October minutestescrrousnessa -outthis forma an W35 nce en ut esame I ve At a ut cva were 5 ossess on dc ri the er was museo sam ent ctim ve to etec an e? cnceo a uc errn or usco a on to are eroa went to ent to I SWORN AND SUBSCRIBED BEFORE ME OF COURT I POLICE OFFICER 10-22-00 DATE WHITE - Court Copy ROYAL PALM BEACH POLICE DEPARTMENT to believearrest or GREEN -- State Attorney cument 278 08/09/2019, 2628230, Page479 of 648 CUBABLE CAUSE AFFIDAVIT Requesl Iur We rent 4. RGQLest?a Caplas 003812 6. 6, Other OX WM Charge Description (State) the above named CammIZIod v:olalion ct law was observed by who told that helshe Saw the arrested person commit the below acts was tound to have committed the below acts. resulting from my (describes) investigation, at -lzi 8 AM. PM. (Speci?cally include facts constituting caUSe for arrest.) eroa, Jr., who told me that he allowed his brother Anthon to use his 1986 Mazda me at as 011 ick-u truck tre, on wo am, on to eextentt at co on tate to t. at war nt emornn near un er seat. ran or 11 Autoeret etwo ueroa, nee rs! ad a ma contro 8110 were tten 0 cnt, C3 an coul not to me I i with as req by law. RB 64. (AH SIGNATURE OF ARRESTING I OFFICER Eli Shaivitz #70 (PLEASE PRINT) 10-22-00 DATE PINK -- Agency NAME OF YELLOW-- Agency GOLD Agency ORI Number HARG ES DEF . PROBABLE CAUSE ADMINISTRATIVE DIETS I PROBA Agency Name FLOSOZSDO ?l Felony . . my 2. Traffic Felony (Last. First. LUIS Zac eroa An on Grand Theft Auto 3. Mlsdomonnor Charge Description Vet-m . underSIgnec? and swears tnat Tre Parson taken .I-Ito custody .. committed the below acts in my presence. ccnlessed to admitting to the below facts. On the 22nd day of October 2093M ADDITIONAL PROBABLE CAUSE: At a ve ate a time, was sou a2 a no truck whic has, tano on ca tru 021 stolen car case. to co station SWORN AND BEFORE ME (A 99 NOTARY PUBLIC i CLERK OF COURT I 10-22-00 DATE FFICER DISTRIBUTION: WHITE - Court Copy Docume BLC ROYAL PALM BEACH POLICE DEPARTMENT 4. Traftic Misdemeanor 1:55 GREEN -- State Attorney 278 08/09/2019, 2628230, Page480 Of 648 AUSE AFFIDAVIT 3. Request tor Warrant Juvenna 2. 4. Request for Capas I .00 3812 5. Ordnance Other harge Description a (zip) to eve. and does believe the above cornmIzteu the violation was observed by who told that he/she saw the arrested person commit the below acts. was tound to have committed the below acts. resulting from my (described) investigation AM. PM. (Specifically include facts Cause fo.r arrest.) en 0 no to an maroon report on a wast ta . r. cust secure an tz. owner an 8015 were I. over to c. SIGNATURE OF ARRESTING I INVESTIGATING OFFICER T. E. by #100 NAME OF OFFICER (PLEASE PRINT) 10-22-00 DATE PINK -- Agency YELLOW-- Agency Case 18-2868000ment 278,. 08/09/2019, 2628230 Page481 of 648 a Case No.: ST ANTHONY LUIS ZAC FIGUEROA Charges: GRAND THEFT (MOTOR VEHICLE) Arrest# 2000346620 Bond# 7-5 Type 3 3,000 AJC Date .-I a Judge LT. ?dug Crt. Rep,_ I ASA 2-6?ma havoc. r_ DC REVRL nt Pres. - Def, 'Co. \3 K.) Cb Esq (TD-E Not Pres. Before I Court for: I I I ?bf?b Granted Denied With Without Prejudice. CI Withdrawn CI Court ResdrveSRuling I3 Written Order to Follow CI Warrant CI Ordered CI Recalled Eon tat$ SeeBelow CIAlso Covers 138;: Cond CI Bond Forf CI OR: Disch/ Revoked/ Reinstated Bon @?evoked/ Reinstated CI SOR: Disch/ Revoked/ Reinstated CI Bond Forf Vacated Previous Bond Reinstated, if onds - .3 ees CI State failed to ?le charges CI ReleaSed O.R. CI Deft'__ Indigent CI PD Appt only PD Pres Evaluation for: CI Drug Farm CI .DOC Non-Secure Bed by CI Pre-Plea PSI ordered by/within days CI w/input from DJJ Staffing DEFT ENTERED OF: CI NOT GUILTY CI GUILTY As Charged?Cts CI Court Appts CI NO CONTEST CI BEST INTEREST To THE COURT Lesser Lesser Charge - CI Sw Test CI?Adv-of CI Waived PSI Lesser Lesser Charge CI ADJ GUJLTY as Chargedas to I Lesser CI FOUND GUILTY as Charged as to Lesser . El ADJ as to CI SENT as-to . . . CI FOUND AND ADIUDICATED DELINQUENT as to I CI Dispo Order gollow Filed CI POUNDS: ADJ NOT GUILTY as to Cts' - CI Dismiss NolIe Prosse .- I - Prob/Comm Control: CI Revoked Reinstated CI Modi?ed Term. successfully Unsuccessfully CI SEE ORDER ASSESSING COSTS CI SEE REVERSE SIDE FOR INSTRUCTIONS REGARDING FURTHER HEARING CI Stip/Found: (violent) Habitual Off. 775.034 - .El Stip/Found: Sexual Offender/Sexual Predator CI Stip/Found: P.R.R. SENTENCE: PBCJ: Cts: . IDOC: - Cts: PBCJ: Cts: - IDOC: . . I i Cts: CI W/Credit for - Days Mos-I Yrs. CI Deft Remanded .CI Deft to remain on Conc I Consec I Co-Terrn w/cases I cts: . ame rel. status pending sent. Execution of Sentence Stayed CI Sentence Suspended CI Time served as to CI YouthfuIOff CI Habitual Off CI Min/Maud: as to El ABOVE SENTENCE FOLLOWED By: CI Probation CI Drug OffProb CI Comm. Control CI I CI 1] ?SeePage2 TATE FLORIDA . PALM BEACH 000m. I Set/Remai gamma. 1? I Rm at . THISDW Set/ Remainsn Rm at l" Deft Sign . (It - Def Co CI ASA BIWY OLE CI Bondsman El Prob CI Jail CI 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 WITH A DISABILITY WHO NEEDS ANY ACCOHHODATION IN ORDER TO PARTICIPATE IN THIS PROVISION OF CERTAIN ASSISTANCE. PLEASE CONTACT THE ADMINISTRATIVE OFFICE OF THE COURT - 205 NORTH DIXIE HI TELEPHONE (581) 355-2431, WITHIN 2 WORKING DAYS OR YOUR RECEIPT OF THIS NOHCE. IF YOU ARE HEARING INPAIRED. NG. YOU ARE ENTITLED, AT NO COST TO YOU. TO THE anAY, noon 5.2500. mam 133233-101- ALL 1-800-955-8771: IF VOICE . 1-000-955-3770 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 But, 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 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 6 MS. SCHULTZ: foundation. 7 8 9 Object to form and THE WITNESS: Yes. BY MR. PAGLIUCA: 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, 08/09/2019, 2628230, Page528 of 648 (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, Page529 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 reflect 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 Case 18-2868, Document 278, 08/09/2019, 2628230, Page530 of 648 10. 11. 12. 13. 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 278, 08/09/2019, 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 ?nes andfor imprisonment. Dated: January 13, 2016 STATEOF COUNTY or i?w?Jq @Eze-pw Sworn to or affirmed and signed before rum PATRICLHD, ulna atrium-.5 ?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 B1vd., Suite 1200 Fort Lauderda1e, 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 beha1f 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 beha1f of the Deponent: Sigrid McCawTey, Esquire BOIES, SCHILLER FLEXNER, LLP 401 East Las 01as Bouievard, Suite 1200 Fort Lauderdaie, Fiorida 33301 (954) 356-0011 0n beha1f of the Defendant: Mary Borja, Esquire WILEY REIN, LLP 1776 Street NW Washington, DC 20006 (202) 719-7000 0n beha1f of the Defendant: Richard Simpson, Esquire WILEY REIN, LLP 1776 Street NW Washington, DC 20006 (202) 719-7000 0n beha1f 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 beha1f 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, piease. 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 generaiities in this document. SPECIAL MASTER: Objection overruied. You can answer. A. I understand we11-known prime ministers and other wor1d Ieaders; 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 Ieaders, what other wor1d Ieaders 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 feeI 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 honestIy 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 Ieader? 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 sexua1 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 powerfui 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 Case 18-2868, Document 278, 08/09/2019, 2628230, Page543 of 648 64 Q. Do you have the origina1s? A. Again, between the FBI and giving them to my 1awyers and Sharon Churcher, the circuiation, 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 bookiet? 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 affi1iated 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 ciear, 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 maie 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 Is1ands, 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 Case 18-2868, Document 278, 08/09/2019, 2628230, Page553 of 648 195 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 counse1 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, PageS57 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page558 of 648 BOIES, 40 LAS OLFS APD SLHTE DEPOSITION- SPECIAL REQUIRED I [:32 PAR. 9541 35.31002: U) 37w? Sigrid S. McCawiey, Esq. E-mail: 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. If you have any questions regarding the errata changes or treatment of?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, 2628230, Pa99559 of 648 Confidential/Sealed Transcript Pursuant to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Iob N0. I0277789 DEPOGIFIOH LRRAIA 3 3 A?signment no: 4 Bradlry 1. Idwurd? 4nd Paul L. (asgell va. 6 Tan Dershowitz I DECLARATTON UNDFR PFNAITY 0r PLRJURY 0 10 I dcc1are under penaity of perjury that I 11 have read Ihc rntirc [ranarript of my videoxaped deposition Taken in the captioned marrcr or Khe same has 1% been read to me. and the acme is true and accurate, save 14 and extupr fur ghangua andfor gorrc(Lion3. if any. as 15 indicated by me on the FRRAIA SHEET hereof, .11} Ni the under-Hand i nq that I fer T. he '10 hanger. JV. 1' l? at?? under math. 10 . 19 F: igned It" 5541-? 1?3 20 zolL[1.3311 -. 24 VLRGINIA :Iurrnr 2 ?3 GIUFFRE005311 CONFIDENTIAL 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. 10277789 DISPOSITION ICRRATA SHEET Page No. (3 Line No. Chanee Io: ?Yes. I signed the subpoena (luees teeum." Reason For elizinge; Did not initially I'eeognire the tloennient Page No. 6 Line No, 30 Change to: "No. My lawyers worked with me to collect documents and my understanding is that we turned those documents over to Dershowitz?s counsel prior to the deposition.? Reason for change: Clari?cation \1 {?13 Chunee to: ?Yes." Reason for change: Did not initial!) reeognj/e the document Page No 1! line No. I (?hznieetq ?Yes.? Reason for change: N-liSLIIitlerStood the question Page ll Line Nos. 4-5. Change to: ?I?m confused. I don't know what foreign president you?re talking about.? Reosun For Change: [he Page No. I 1 Line No. 23 (?hanee understand prime ministers and other world lenders; as to as foreign presidents, I believe so.? Reason for change: hliihtinilel'stootl the question Page No. 12 Line No. 2 Chonee to: ?Yes. assuming South Amerien is considered overseas." Reason for change: the question Page No. l2 Line No, 8 Chnnee to: ?As to 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) lob N0. I0277789 Reason tor change: Misunderstood the question Page No. 38 Line No. I Chanee to: ?I?ll eontinue with the list here. Nadia I was not sent to her, but she was part ot?it with Jeff Epstein. Others on the list include Marvin h'linsk)? and Tom I?ritzker." Reason for change: Clari?cation at?answu' Chance to: ?Off the top of my head, once. but it could have been more." Reason For Change: Clari?cation ot?ansuer Page No. 38 Line No. 2] Change to: believe Tom was at Mexico. I may have also been with him in other plaees.? Reason litt' Change: Clari?cation al'ansner Page No. Line No, Chanue to: ?On an airplane a llti in a limo." Reason for change: Clari?cation ot'ansuet' Page No. II Line No. It) Chanee to: "One, each time." Reason Ibl' change: Clari?cation nl'ansn er Page No. 41 line No. 12 to: ?On airplane, bland, you 11g.? Reason for change: Clari?cation otansn-ei' Page No. 98 Line No. 16 C'hanee to: ?As you can see in that answer I?m not even sure. It wasn?t six months. but between six months and a 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?answer 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 190 Line No. 23 Change 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 tor change: Clar'itieation ot? [mm er Page Line 5 Choose to: ?Why would I do no. I did eolleet documents and gave them to my lawyers in response to this subpoena. And my understanding is those documents were produced." Reason for change: Misumlerstood the question Page 19} line 20 C'hanee to: ?Yes, but I did no! have any pietures of myself with Professor Reason l?ot' change; Misunderslumd the question GIUFFRE005314 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page563 of 648 EXHIBIT KK 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! Chapterl 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 wouid 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 l. Copyright Protected Material 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 I didn?t realize how much worse it could 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 i 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 fulfill 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 i 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 I 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 you. .. 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 BIT l35 ?3 I AGREE REPORTING 515! i Lg 8V9 lo V99959c ?0888898 ?818 999C) 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 tumed back around to face him. Backing me up against the wall and now cornered by this iarge man I felt his slithering hands began to creep under my shirt, writhing my skin. I closed my eyes and turned 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 me.'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 Copyright Material 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 clearly 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 I39 8V9 lo 999959c ?0888898 ?818 999C) 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 fit, 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 I 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 decor, 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 hall 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 Copyright Protected Material 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 first 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 I 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 turns 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 137 8V9 40 999959c ?0888898 ?818 999C) 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 (J Copyright Protected Material 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 first. 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 (JlUlii-?Rliotl-l 141 8V9 40 199959c ?0888898 ?818 999C) 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 hini, 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 I 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 nunierously 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 Copyright Protected. Material 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 GIU 1"i"lill004 143 8179,10 899959c ?0888898 ?818 999C) 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, I was out to piss him off so I didn?t remove my shirt. Iput 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. Ireplied 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 first 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 terrified 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 find. out through the broken sobs off of 11 Copyright Protected Material 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 five 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 five 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 GlUlil?liL-?UU-l l-lS 8V9 l0 699959c ?0888898 ?818 ?8988'8l- 999C) 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] 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 failing 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 iike 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 stili 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 Copyright Protected Material GlUl?IillEOO?l 146 knew what I had to do to get this over and done 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. lust iike 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 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. Coming 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 GlUlii?liljotH I47 8V9 :10 Oige?ed ?0888898 ?818 tueumooc] 999C) 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 TJ 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 checked 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 3 Copyright Protected Material GIUFFREOCM 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 tip 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 Out 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 I 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 I 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 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 14?) 8V9 IO Lige?ed ?0888898 ?818 999C) 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 FBI 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 ?ghts 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 ill Copyright Protected Material GIUFFILE004150 whole life they ended up repeating the same attributes as the people who initially hurt them in the ?rst place. One very sad girl I?ll never forget her, had 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 I leapt in with my two bits and made it obviously clear to my Dad that ifI was sent away to 18 Copyright Protected Material 15 8V9 :10 Zige?ed ?0888898 ?818 999C) . 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 musciy 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 wouid 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 floorin 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 filled with my stowed away cash that no one had fOund during my unpleasant strip- searches. I would spend hours in the white room for objecting to their 19 Copyright Protected Material CONFIDENTIAL GIUFFREUD4152 conformity and unwilling to participate in their drilling regime. I didn?t feel like] owed any,explanation to these peeple even when they brought a physioiogist in to speak with me, ?What was the point when Iwould 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 tomient 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 of?ce, my whereabouts told me I had plenty of ways to run and I 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 smail framed Spanish man tried to make pleasant conversation but I couidn?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 toid myself, and pushed past the volunteer. I-Iis arms 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, [had 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 Protected Material CONFIDENTIAL GlUl?i?RLiotJ-?l 53 8V9 :10 Sige?ed ?0888898 ?818 999C) 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 d0ubts 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 noti?ed 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, 1' 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 first 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 Copyright Protected Material GIUFF [(15004 I 54 waited for me to come find 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 8V9 lo Vige?ecl ?0888898 ?818 999C) 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 Copyright Protected Material GIUFFRE004156 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 tip 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 1 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, ?It 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, if} 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- El Copyright Protected Material UlUlil?RliOOtilS'l? 8V9 40 Sige?ed ?0888898 ?818 ?8988'8l- 999C) 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 with that wry smile of his, and half playful and half defensive, 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 iegs 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 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 58 ?what have I been trained tip for until now?. Nobody ever stopped to ask ifI 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, 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 history 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 undemeath 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 OlUlili?RlEUO-l 8V9 40 919959c ?0888898 ?818 999C) 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 GIUFFRE 004 1 60 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 161 8V9 l0 Lige?ed ?0888898 ?818 999C) 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 Copyright Protected Material CONFIDENTIAL GIUFFRE004162 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 fifties 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 ifali 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! 163 8V9 lo 819959c ?0888898 ?818 999C) 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, I?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 ?fteen 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 ?rst 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 ll Copyriglil Protected Material GIUFF 1115004 l64 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 L1 Copyright Protected Material (J?lLlI?liRliOll-l 165 8V9 JO 619959c ?0888898 ?818 999C) 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 Ihad 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 ll Copyright Protected Material GIUFFREOU4166 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, Ihad 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 flashed 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 817940 089959c ?0888898 ?818 tueumooc] 939C) he?d take care of it for me. We said our g00d~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 of?ce, 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 Ill Copyright Protected Material 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 ?gures 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 17?? 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 de?cor 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 of?ce 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, ?t 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 CONFIDENTLAL 16?) 817940 L89959c ?0888898 ?818 999C) 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 flesh, 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 fit 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 TV 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 ll Copyright Protected Material 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 office 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 first 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 Copyright Protected Material l7] 817940 889959cl ?0888898 ?818 999C) 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 ofine 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 batties 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 GIUFFILEOIM I72 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 1 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 CONFEDENTIAL 173 817940 889959c ?0888898 ?818 939C) 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, Ijust 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 GIUFFILEOO4174 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 anival. 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 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 Protccled Material GlUliliRliOM 175 8V9 l0 V89959cl ?0888898 ?818 ?8988'8l- 999C) 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.J, 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 Copyright Protected Material 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 be 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 04 177 817940 989959c ?0888898 3108/60/80 ?818 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 con?dent 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 Il Copyright Protected Material CONFIDENTIAL 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 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. 1 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 1 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 Protected Material CONFIDENTIAL GlUliliRliOO-l 179 8179,10 989959c ?088?8898 ?818 tueumooc] 999C) 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 fl Copyright Protected Material 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 film. 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 I 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 ?ngers 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 cue 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 Copyright Protected Material 181 8V9 lo 189959c ?0888898 ?818 tueumooc] 999C) 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 finally 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 Copyright Protected Material 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 NYC, 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 ?nd 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 8179l0 889959cl ?0888898 ?818 939C) 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 I?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 find 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 fulfilled my chocolate cravings only hours ago. Telling him ofthe places I ventured into Imentioned to him ?We?d have to hit the fisherman?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 [1 Copyright Protected Material GIUFFREOO4 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 wharl?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. On 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 8179,10 689959c ?0888898 ?818 tueumooc] 999C) 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 would 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 flight 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 Copyright Protected Material 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 baffled 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 flew 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- Cl Copyright Protected Material 187 8179,10 069959c ?0888898 ?818 tueumooc] 999C) 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 ?rst 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 bene?ted in their career, ?nances, 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 fl Copyright Protected Material 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. i 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 I couldn?t have, but I needed some time to cool down and accept my situation. I 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 I 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!) 8V9 l0 L69959c ?0888898 ?818 999C) 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 I 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 [3 Copyright Protected Material GIUFFRE004 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 ?nding 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 flight, 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 of?ce 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 ?rst 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 wore 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 lUl 8V9 JO Z69959cl ?0888898 ?818 ?8988'8l- 999C) 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 who just 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 of the 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, he just 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 of believing 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 himself who took the doctor alone to the side of the 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 if Jeffrey 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. 1 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 I greeted him when one of the 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 himself with 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 of the untouched parts of the island, we sat at a cliff and just sat there, not saying a word to each other besides to 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, f just couldn't be myself. We got back to the main villa to see what time dinner would be se1ved 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 of the 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 of my 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 wam1 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 of the 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 of the cabana's. 1 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 of the 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 1 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 bad done enough. The next day I took him down to the beach for a real massage under a tiki-hut on the waters edge. ft was one of Jeffrey's favorite places to have a massage, as he droned out to the sound of the 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 59 60 , l Copynght Protected Material CONFIDENTlAL GIUFFR.E004192 □ Copyright Protected Material CONFIDENTIAL GIUFFRE004193 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 flight 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 I was ?xed 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. I 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 office 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 1] Copyright Protected Material GIUFFRE004 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 I 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 195 8V9 lo 17699519c ?0888898 ?818 999C) 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 out?ts, 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 Copyright Protected. Material 196 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 her meaner streak s?ne would?ve been a great friend. I will never 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 girtfriend 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. [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 1 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 office 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 of?ce. 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 ?rst 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- Copyright Protected Material CONFIDENTIAL 197 8V9 l0 969959c ?0888898 ?818 999C) 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 ?oated 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 Copyright Protected. Material GIUFFREOO4 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 oftheni. 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. I gave him affirmation of my understood instructions and headed off with this stranger into the darkness. I 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 first 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 GlUlil?leOO-l 19?) 8V9 JO 969959c ?0888898 ?818 999C) 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 ?attering 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 iured 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 wiid 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 ?replace 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 Copyright Protected Material 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 first 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 first 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 [fl Copyright Protected Material 8V9 JO A69959c ?0888898 ?818 999C) such high prospects lowering herseifto 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 rimming 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 magni?cent 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 pennanent 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 first 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 Fl Copyright Protected Material 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 Copyright Protected Material CONFIDENTIAL 8179,10 869959c ?0888898 ?818 999C) 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. i 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 I 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 Copyright Protected Material CONFIDENTIAL 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 1 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 8V9 l0 669959c ?0888898 ?818 999C) 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 iife 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, 1 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 case. 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 Copyright Protected Material 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 all 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? El Copyright Protected Material 817940 009959c ?0888898 ?818 939C) 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 tools 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 and 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 style 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 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 Hunt Pieces? throughout history. Jeffrey took notice of my enchantm ent into 75 Copyright Protected Material GIUFFREOM208 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. 1 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 Maxwell 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 1 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 817940 L09959c ?0888898 ?61-08/60/80 ?818 999C) custom, we both kissed on the check. We all sat down on the lounges 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 first one to throw in her quick-witted two bits, all ofthem chuckling along with her. Hardly a laugh at all, unknown to me at the time his eldest daughter is only five years my junior. I was finding 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 first 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 . Copyright Protected Material CONFIDENTIAL 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 1 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 definitely a first for me and I couldn?t help 78 Copyright Protected Material 817940 809959c ?0888898 ?818 999C) 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 finally 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 GIUFFRE0042 12 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 ifI 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 fixation 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 find 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 fl Copyright Protected Material CONFIDENTIAL 13 8179l0 809959c ?0888898 ?818 939C) 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 hall, 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. Ghislane 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 Copyright Protected Material 14 )cc encounters with Jeffrey 5 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 couid handle the abusive state of affairs I had drifted into. Sinking deeper in the euphoric state of being on coke and pills, 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, I 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 yOu 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 IS 8V9 :10 V09959c ?0888898 ?818 999C) 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 ofiny 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. I-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 ?lled 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 ?res 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 Copyright Protected Material 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 ioved 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. T.J 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. 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, aithough 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 GIU i?l?RliO 042 17 8179,10 909959c ?0888898 ?818 999C) 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 fifty 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 police report for the missing money?. 1 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 cali from a familiar voice. Jeffrey decided to give me a cali 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 i] Copyright Protected Material CONFIDENTIAL 18 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 stem, 1 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 ?le 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 yourseif, 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 rue to come in. I don?t want to have a record for something 1 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 Copyright Protected Materiai 817940 909959c ?0888898 ?818 999C) 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 too I 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, Brunel, 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 Copyright Protected Material 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 Brunel, 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 finished 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 100k 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 El Copyright Protected Material CONFIDENTIAL 8V9 :10 109959cl ?0888898 ?818 999C) 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 biilionaires. . ,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 de?nitely 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 Copyright Protected Material 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. I?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 goiden shine. To grasp that feeling I was absolved in at the hardest of times became my greatest inner? 90 Copyright Protected Material 817940 809959d ?0888898 ?818 939C) 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 findings I decided to do some more exploring around the fields 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 find 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 amplified 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 find 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 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 findings and he scolded me for being gone for so long without anyone knowing where I was. Going back to the Indian remnants, 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?. I satis?ed his worry of me being a future nuisance and with that I was finally 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 Copyright Material 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 find 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 flick 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 fist 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 817940 609959c ?0888898 ?818 999C) 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 fully 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 ofthern all, is sex and money. Chapter 15 93 l} Copyright Protected Material 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 actual 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 figuring 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 Copyright Protected Material ONFIDENTLAL GlUliliRli004227 817940 0L9959c ?0888898 ?818 tueumooc] 999C) 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 floors 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 finished it was already a work of art, a sanctuary for any woman. She adorned herselfin her future home, finally 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 flow, they had an abundance of girls at their disposal. 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 ll Copyright Protected Material 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 satis?ed 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 1 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 niyselfto 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 817940 ?0888898 ?818 999C) 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, I 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 ?nally 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 Copyright Protected Material 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 ofmy bodies? curves in the reflection of the moonlight. It only encouraged me to stay lOnger under the warmth from the spray of rushing water. I let the hot water run out before I was suf?ced 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 I 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 whatI 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 ?ve 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 Kl Copyright Protected Material 817940 Zl-Qe?ecl ?0888898 ?818 999C) 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 people 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 ofliim 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 Copyright Protected Material 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 ?rst ring. ?Hi ?Uh- Rich, lt?s Jenna, ex, we met a 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 ?ve o?clock watching the minutes on the clock tick past and when five 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 Copyright Protected Material (JlUl'il?le004233 817940 8L9959cl ?0888898 ?818 999C) 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 ?nd 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 all 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 1 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. 1 could hear babies screaming Copyright Protected Material 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 myselfto 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 ?uffy 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 T..I, 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 8V9 lo 17L9959c ?0888898 ?818 999C) 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 un?nished 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 ll Copyright Protected Material 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 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 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 longer 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 iicked 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 104 ICE Copyright Protected Material 8V9 JO 9L9959cl ?0888898 ?818 tueumooc] 999C) 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 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 Copyright Protected Material GIUFFILE004233 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. 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?? 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 ?3 Copyright Protected Material 8V9 l0 9L9959cl ?0888898 ?818 999C) 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 filled 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 oId bookshop to browse at their assortment of old titles. 1 wasn?t in any hurry so Itook my time 107 Copyright Protected Material GIU FFREO 04240 reading the backs ofinteresting looking books. I bumped into a girl looking down the same aisle 1 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 ?owery 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 iot, 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 pientiful 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 8V9 :10 AL9959cl ?0888898 ?818 999C) 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?ll 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 109 [l Copyright Protected Material 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 pirate?s 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 ?nds 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 i loved all the little knick knacks one could find 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 lifestyie. 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 817940 8L9959c ?0888893 ?818 939C) 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 blue 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. CI Copyright Protected Material GIUFFRED 04244 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, Iliad 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 i 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 he 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 FI Copyright Protected Material CONFIDENTLAL 8V9 :10 6L9959d ?0888898 ?818 999C) 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 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 I 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 Copyright Protected Material CONFIDENTIAL 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. Ghislane 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, Ghislane made the ?nishing 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 817940 089959c ?0888898 ?818 999C) 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 ?esh 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 loud 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 Til Copyiight Protected Material GIUFFILEOOAZLIE 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 [l Copyright Protected Material 24?) 817940 L89959cl ?0888898 ?818 999C) 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. 1 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 iast 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 ail 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 l; Copyright Protected Material CONFIDENTIAL 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 .Fane 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 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 office 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 817940 889959c ?0888898 ?818 999C) 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 Copyright Protected Material GIUFFRJEOIMZSZ Throw out your confetti because here i come Chang-Mail! 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 ?rst 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 first time out of the country an unforgettable experience then I was also gaining 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 fly 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 ?rst one as soon as your course ?nishes 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 8179310 889959c ?0888898 ?818 tueumooc] 999C) 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? 1 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 Li Copyright Protected Material 254 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 ineving 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 El Copyright Protected Material :35 817940 1789959c ?0888898? ?818 tueumooc] 939C) 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 actuaily? 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 butter?ies 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 1 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 ?nd 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 3 Copyright Protected Material 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 1 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. He?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 Iayirrg 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, 1 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 8V9 IO 989959c ?0888898 ?818 tueumooc] 999C) 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. Many 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 Copyright Protected Material 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 dolithan 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 8V9 lo 989959c ?0888898 ?818 999C) 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 ?ght, 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, turning nothing into something, which I had also come to realize, was the most precious gift in 127 Copyright Protected Material GIUFFRE004260 Falling asleep was easy to do in his arms that night. I laid my head on tOp 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 would 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 ?owers made up of baby?s breath and small yellow and purple budding flowers. I couldn?t have dreamt it up better myself and when I met my husband to be at the bottom of the mountain he stood before me Speechless ?You look beautiful!? were his ?rst 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 8V9 lo 189959d ?0888898 ?818 999C) 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 officially 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 Copyright Material whole life around and how I would dedicate my entire being to loving him and only him until I blew my final 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 finally 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 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 . 263 817940 889959c ?0888898 ?818 999C) 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 liOneymoon 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!? I 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 GIUFFREOMZM 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 ?ick. 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 265 8179,10 689959c ?0888898 ?818 999C) 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 ?ve 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 flight 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 flight 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 officer. 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 133 Ll Copyright Protected Material 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 1 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 plans 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 i 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 certificates. 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 finally 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 really 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 Copyright Protected Material 817940 089959c ?0888898 ?818 939C) my adrenaline was still pumping from the previous encounter with the officials 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. lwas 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 ?rst steps I walked off the plane and onto a new soil for the first 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 Copyright Prnteeted Material 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 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 first 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 agent from America. The American agent asked ifl 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 continued 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 fine. 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 817940 L89959c ?0888898 ?818 999C) 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 ?rst 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 noti?cation 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 30?? 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 confinement 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 LI Copyright Protected Material GIUFF 1113004270 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 1' 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, 1 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 l] Copyright Protected Material 817940 889959c ?0888898 ?818 999C) 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 enslavement 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 Copyright Protected Material Ll Copyright Protected Material CON 1* N'l?lAl. GIUFHLE004272 CON FIDENTIAL 8V9 JO 889959c ?0888898 ?818 939C) Case 18-2868, Document 278, 08/09/2019, 2628230, Pa99634 Of 648 141 CO wright Protected Material CONFIDEN TLAL GIUFFRE004274 Case 18-2868, Document 278, 08/09/2019, 2628230, of 648 EXHIBIT LL Case 18- 2868 Document 278 08/09/2019 2628230 Page636 of 648 .i ARTICLES OF INCORPORATION In compiiance with Chapter 61?, F.5d, (Not for Pro?t) ARTICLE I NAME Refuse Silence, lnc. ARTICLE If PRINCIPAL OFFICE Principai street address; 425 North Andrews Ave. Mailing address, if different is: Suite 2 Fort Lauderdale, FL 33301 ARTICLE PURPOSE . . . . Victims Refuse Silence, Inc. is organized exciusiveiy for charitable and The purpose for which the corporation is organized 15: educational purposes inciuding, for such purposes, the making of distributions to organizations that quaiify 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 trafficking. Upon the dissoiution of Victims Refuse Siience. inc, assets shaii be distributed for one or more exempt purpose within the meaning of section 501(c)(3) of the Internet Revenue Code, or corresponding section of any future federai tax code, or shatt be distributed to the federal government, or to a state or iocal government, for a pubiic purpose. ARTICLE IV MANNER OF ELECTION The manner in which the directors are eiected and appointed: which the directors are elected or appointed is provided in the bylaws of the Corporation. ARTICLE INITIAL OFFICERS DIRECTORS Name and me: Virginia Roberts, Director Address 425 North Andrews Ave. Suite 2 Fort Lauderdale, FL 33301 Nameand We: Bradley J. Edwards Director Address 425 North Andrews Ave. Address: Address: Name and Titie: ?rl Name and Title: a 41? SZ iZl iid E38 330 Suite 2 Fort Lauderdale, FL 33301 Name and me: Brittany N. Henderson, Director Name and Titie? Address 425 North Andrews Ave. Address: Suite 2 Fort Lauderdaie, FL 33301 The manner in :l n. GIUFFREOO 1063 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 REGIS mega AGENT The nag}; Flerida street add regs (PO. Box NOT acceptabk) of the registered agent is: Bradley .J. Edwards 425 North Andrews Ave, Suite 2 Fort Lauderdale, FL 33301 Name; Address: ARTICLE VII INCORPORA TOR The ngme and address of the Incorporawr is: Brittany N. Henderson 425 North Andrews Ave, Suite 2 Fort Lauderdale, FL 33301 Name: AddressHaving been named as registered agent to accept service ofproces's for the above stated corporation at the place designated in this certi?cate, I :1 ?or with and accept gs registered agent and agree to act in tins capacigr 22-474? Date I submit this document and a?t?rm that thefnets stated herein are true. I am aware that anyfatse information submitted in a document to Department of State constitutes a third degree fetony as provided for in 3.81 7.155, ES. Reqetreg Signature 0? Incomerater Date GIUFFREOO 1064 Case 18-2868, Document 278, 08/09/2019, 2628230, Page638 Of 648 2015 FLORIDA NOT FOR PROFIT CORPORATEON AMENDED ANNUAL FILED Apr 22, 2015 N14000011657 Secretary of State Entity Name: REFUSE SILENCE, INC. 007801725405 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 of?ce 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, VIRGINIA 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 GIUFFREOO 1065 Case 18-2868, Document 278, 08/09/2019, 2628230, PageG39 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