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EFTA02520052

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wrote: From: jeffrey E. <[email protected]> Sent: Monday, February 26, 2018 4:49 PM To: Lawrence Krauss Subject: Re: URGENT: BuzzFeed News inquiry re allegations of sexual harassment by Lawrence Krauss and i was right. in all instancees as if you in your=nuttiness decide to file this lawsuit you keep banging on about,.=A0 that sentence will carry the day On Mon, Feb 26, 2018 at 11:47 AM, Lawrence Kra=ss < y=s <mailto > wrote: but you did tell me to write him those words.. but yo= are correct about many things.. Lawrence M. Krauss 0=rector, The Origins Project at ASU Co-Director, Cosmology Initiative Foundation Professor <=b> School of Earth & Space Exploration and Physics Department Ar=zona State University, P.O. Box 871404, Tempe, AZ 85287-1404 =esearch Office: Origins Office (Cynthia): /span> <mailto krauss.faculty.asu.edu > I Assistant (Jessica): -Origins Project 10 Year Celebration- Be a part of something 10 yea=s in the making! April S-9th 2018 i>=804, Visit for more info <https://www.originsl0year.com/> =br> On Feb 26, 2018, at 8:46 AM, jeffrey E. =Itjeevacation@=mail.com <mailto:[email protected]» you should wish in retrospect not t= have responded at all. On Mon, Feb 26, 2018 at 11:43 AM, Lawrence Krauss < <mailto > wrote: EFTA_R1_01656556 EFTA02520052 Thanks... I am=not replying or egging them on.. I will speak to Nancy.. I wish in r=trospect I had not sent him a note using the words "false with mal=cious intent" as you recommended.. I had a piece about that =n my long response, explaining that I explained to him it was my language =ot the Unversity's, because their investigations showed the claim =as false, and I argued that was malicious.. <=div> thank you. And of course I was never banned from th=se institutions.. I should make that clear in my long response as well.. =C24> I believe what you are seeing is from=the usual suspects, but indeed, probably not best to confront them any mor= directly. LM K =b>Lawrence M. Krauss Director, The Ori=ins Project at ASU Co-Director, Cosmology Initiative Foundation Professor School of=Earth & Space Exploration and Physics Department Arizona State Univ=rsity, P.O. Box 871404, Tempe, AZ 85287-1404 Research Office:=span class="m_-6189807211976031442Apple-converted-space"> =C*I Assistant (Jessica): <tel: Origins Offic= (Cynthia):4a <tel: <=pan style="font-size:9ptcolor:rgb(68,114,196)" <mailto =u> origins.asu.edu <https://urldefense.proofpoint.com/v2/url?u=http=3A_origins.asu.edu&d=DQMFAg&c=AGbYxfJbXK67KfXyGqyv2Ejiz4 1FqQ=ZFk4A- 1IxfAU&r=DB9LvLOlQiaqWcFOihHC0LZCntZCR8Xtq5BHKNVR5To&m=c=P97mEbO4349G8_Nf9I5Up33Th7MWHYf6uw7yU BPZc&s=Gc-m4FUPqBmB-H8qg0HdYhSQ:_hZ8rHMdpRIHH3C6B0&e=> =/span> I Ikraussl <https://urldefense.pro=fpoint.com/v2/url?u=http- 3A_twitter.com_lkraussl&d=DQMFAg&c=3DAGbYxfJbXK67KfXyGqyv2Ejiz41FqQuZFk4A- 1IxfAU&r=DB9LvLOIQiaqWcFOihHC=LZCntZCR8Xtq5BHKNVRSTo&m=ciP97mEbO4349G8_Nf9l5Up33Th7MWHYf6uw7yU BP2c=amp;s=rnspp0SBZaPjp5BOPRbD2xXlzHCi4LgzTZ8KNgjNBBKg&e=> I krauss.faculty.asu.edu<=span> <https://urldefense.proofpoint.com/v2/url?u=http- 3A_=rauss.faculty.asu.edu_&d=DQMFAg&c=AGbYxf.lbXK67KfXyGgyv2Ejiz41F=QuZFk4A- 1IxfAU&r=DB9LvLOIQiaqWcFOihHC0LZCntZCR8Xtq5BHKNVRSTo&m=3DciP97mEbO4349G8_Nf9I5Up33Th7MWHYf6uw7 yUBP2c&s=f7W9C_XvplQaElpZ3o8v=h0dM_e0hTXbMIVPaUviEt8&e=> -=span style="font-size:11ptcolorwhite;background-color:black">Origins P=oject 10 Year Celebration- Be a part of something 10 years in the making! Apri= 5.9th 2018 — Visit for more info <https://www.origi=sl0year.comk =/span> =/span> <image002.png> 2 EFTA_R1_01656557 EFTA02520053 On Feb 26, 2018, at 8:37 AM, Jeffrey E. <[email protected]=/a» wrote: LAWRENCE, 4,=A0 Im not sure if you have decided to commit reputational hari kari.=C240 its ok with me. but these consequences were discussed ad=nauseum with you. if four or five ASU students decide together to co=plain , all bets off. . and you are egging them on. <=p> Melody Hensley "A" (who wishes to remai= anonymous, though I'm almost positive I know who it is) Nora (= student at Case Western) Melanie Thomson (who witnessed him grab anoth=r woman's breast at a skeptic's conference in Australia, a=ong with Michael Marshall and Jo Alabaster. Four former employees of Ar=zona State's Origins Project (anonymously). They include a 19 year=old undergrad with two witnesses confirming her story of his creepy behavi=r. That's 13 separate people who either were the victims or =he witnesses of their victimization. They come from multiple universities,=three different countries, at a variety of events over a long period of ti=e. As a result of some of those investigations, two institutions —=Case Western Reserve University and the Perimeter Institute for Theoretica= Physics — banned him from their campuses. And both Arizona State =niversity and Australian National University said on the record that he li=d about what their investigation of those complaints concluded. This=is not a he said/she said. It's a he said/13 other people said and=three major educational institutions said. And those aren't the on=y ones. I know of several other people with similar stories who are afraid=to talk about them in public for fear of being attacked just like the accu=ers are now being attacked. On Mon, Feb 26, 2018 at 11:33 AM, Lawrence Krauss< <mailto > wrote: thanks.. I don't know about others I =ill relay this to Nancy. =b>Lawrence M. Krauss Director, The Ori=ins Project at ASU Co-Director, Cosmology Initiative Foundation Professor School of=Earth & Space Exploration and Physics Department Arizona State Univ=rsity, P.O. Box 871404, Tempe, AZ 85287-1404 Research Office:=span class="m_-6189807211976031442m_- 277658877943275076Apple-converted-s=ace"> <tel. > I Assistant =Jessica): <tekiIIIIIIIIIIIIII> Origins Office (Cynthia): r 3 EFTA_R1_01656558 EFTA02520054 =u> origins.asu.edu <https://urldefense.proofpoint.com/v2/url?u=3Dhttp- 3A_origins.asu.edu_&d=DQMFAg&c=AGbYxfJbXK67KfXyGqyv2Ej=z41FqQuZFk4A- 1IxfAU&r=DB9LvLOIQiaqWcFOihHC0LZCntZCR8XtqSBHKNVRSTo&am=;m=ciP97mEbO4349G8_Nf9l5Up33Th7MWHYf6u w7yUBPZc&s=Gc-m4FUPqBmB-H8qg=HdYhSQN_hZ8rHMdpPJHH3C6B0&e=> I twitter.com/Ikraussl <https://urldefe=se.proofpoint.com/v2/url?u=http- 3A_twitter.com_lkraussl&d=DQMFAg&=mp;c=AGbYxfJbXK67KfXyGqyv2Ejiz41FqQuZFk4A- 1IxfAU&r=DB9LvLOIQiaqWcF=ihHC0LZCntZCR8Xtq5BHKNVRSTo&m=ciP97mEbO4349G8_Nf9l5Up33Th7MWHYf6uw7y=B P2c&s=mspp0SBZaPjp5BOPRbD2xXlzHCi4LgzTZ8KNgjNBBKg&e=> I krauss.faculty.asu. <https://urIdefense.proofpoint.com/v2/urI?u=ht=p- 3A_krauss.facuIty.asu.edu_&d=DQMFAg&c=AGbYxfJbXK67KfXyGqyv2=jiz41FqQuZFk4A- 1IxfAU&r=DB9LvLOIQiaqWcFOihHC0LZCntZCR8Xtq5BHKNVR5To&=mp;m=ciP97mEbO4349G8_Nf9I5Up33Th7MWHYf6u w7yUBP2c&s=f7W9C_XvplQaElp=3o8vIh0dM_e0hTXbMIVPaUviEt8&e=> -</=pan>Orig=ns Project 10 Year Celebration- Be a part of something 10 years in the making! A=ril 5-9th 2018 — Visit for more info <https://www.or=ginsl0year.com/> <=i> 4>=A0 <=image002.png> =/div> On =eb 26, 2018, at 8:28 AM, jeffrey E. <[email protected] <mailto:jeevacation@gmai=.com» wrote: LAWRENCE !! Since the s=ory broke late last week in Buzzfeed about the numerous allegations of sex=al harassment and creepy behavior by Lawrence Krauss, we've been t=eated to a litany of bad arguments in his defense, many by his wife, who u=ed a secondary T=itter account <https://twitter.com/NancyMDahlPhD/with_r=plies> to engage people on the issue. The arg=ments are almost uniformly illogical and disingenuous. I prop=se you write an article debunking alien abductions using the same ar=ument. these people didnt know one abother. there are 10= of them. why should they lie. . etc. =C24) TELL nancy to stop. you are getting into dangerous territory.=C2*. this is not a court of law.. facts DO NOT=make a difference. . as you can see there are now some o=hers who have been too afraid to come forward in the article. .•=AO you are self inflicting On Mon, Feb 26, 2018 at 10:48 =M, Lawrence Krauss < wrote: The =orrespondence from Ron Lindsey to Peter Aldhous. Lawrence M. Krauss Director, The Origins Project =t ASU Foundation Professor 4 EFTA_R1_01656559 EFTA02520055 School of Earth & Space Exploratio= and Physics Department Arizona State University, P.O. Box =71404, Tempe, AZ 85287-1404 Research =ffice: > , Assistant (Jessica): <tel:480.965.9=25> Origins Office (Cynthia): c=iv' 4>=A0 origi=s.asu.edu <http://origins.asu.edu/> j twitter.com/Ikraussl <http://twitter.com/Ikraussl> I krauss.faculty.asu.edu<=a> <mailto harassme=t by Lawrence Krauss <mailto: harassment by Lawrence Krauss <tel <DA866543-7401-4A5A-8E50-FD32E3=AS0EC.png> Sent from my iPhone </=iv> Begin forwarded message: From: Ronald Lindsay < =t; Date: February 26, 2018 at 7:17:07 AM PSTTo: Subject: <=>Fwd: Fwd: URGENT: BuzzFeed News inquiry re allegations of sexual My correspondence with Aldhous. As usual, rea= from the bottom up. Forwarded message From: Ronald Lindsay < Date: Mon, Dec 11, 2017 at 7:21=AM Subject: Re: Fwd: URGENT: BuzzFeed News inquiry re allegations of se=ual To: Peter Aldhous < /a» Dear Mr. Aldhous, <=div> Adam Isaak resigned because I had a public spat with his girlfrie=d, Rebecca Watson, who had issued a public call for CFI employees to quit.=(That dispute is a whole other story, tangential to your Krauss piece, so = will not get into it here.) Timing is important =ere. The email from Pat was in March. The dispute with Watson started in m=d-May, after which Adam stopped showing up for work. (He said he was sick =amp; then went on vacation, or vice versa). He then then left some time in=June. If the Krauss matter "pushed [him] over the edge," then he=was tenaciously hanging on to the ledge for a few months. 5 EFTA_R1_01656560 EFTA02520056 </=iv> The email from Pat Beauchamp was in the first person and Pat indic=ted she was speaking for herself. (I found the email exchange last night; = will forward it to you.) Adam had never been shy about expressing his con=erns to me -- he asked for raises, complained about the hosts on the podca=t he was producing etc. The notion that he and Pat were working together b=t that he decided he could not reveal his participation is difficult to cr=dit. I will be traveling to my home this evening.=Plan to reach my home by 7:45, but if I don't answer right away, pleas= try a bit later. My number is: <tel 9> . Sincerely, R. Lindsay =br> On Sun, Dec 10, 2017 at 10:45 PM, Peter Aldh=us <mailto > wrote: Dear Mr. Lindsay, Thank you for your response, wh=ch we will consider in detail. Shall we speak at 7.45pm Eastern tomorrow? =o let me know what number to call. To answer your question, the CFI =mployee who resigned was Adam Isaak. He told us that he helped Patricia Be=uchamp draft an email to you outlining their concerns about inviting Lawre=ce Krauss on the 2014 cruise. He explained that his resignation had = broader context, relating to his concerns about sexism and online harassm=nt in the skeptical movement. But he said that CFI's continued embrace=of Krauss, in the face of concerns expressed by staff, was what "push=d me over the edge." Sincerely, Peter Aldhous =n 12/10/17 7:27 PM, Ronald Lindsay wrote: De=r Mr. Aldhous, =font>Let me note a couple of things at the outset. First, I would be happy=to speak to you regarding the allegations in your email. You can reach me =t my cell phone number, which is <tel > . Howeve=, I am unavailable tomorrow (Monday) because of prior commitments until ap=roximately 7:45 PM. <=pan>Next, you should know that I'm not an employee of CFI no= do I have any authority to speak on behalf of CFI. I'm writing to=you from my personal email account in part to underscore that 6 EFTA_R1_01656561 EFTA02520057 point. I do =etain a CFI email address in part as a courtesy to me and in part because =t serves a business purpose (for example, I still receive occasional email= addressed to the president of the organization). Turning to the substance of your a=legations, first you should be aware that I take the issue of sexual haras=ment very seriously. This is confirmed by the fact that after I was hired =y CFI as its in- house lawyer (a position I held prior to becoming presiden= and CEO) I insisted that the organization adopt a comprehensive zero-tole=ance harassment policy covering workplace harassment. Moreover, during the=time I was president and CEO we had three separate state trainings for the=entire staff on sexual harassment issues. In addition, where necessary, we=did not hesitate to expend significant resources, including retaining outs=de investigators, to conduct serious, detailed inquiries into harassment c=aims. One such inquiry cost the organization over $40,000. Therefore, any =uggestion that I do not personally take harassment claims seriously is amp=y disconfirmed by my record. Regarding the alleged incident on the 2011 cruise, the =irst I became aware of it was when Pat Beauchamp, CFI's business m=nager and the employee responsible for cruise logistics, wrote to me in 20=3 indicating she objected to inviting Lawrence Krauss on our upcoming Gala=agos cruise. I found this strange, and I responded to her almost immediate=y asking the reasons for her objection. She gave two reasons. The first wa= that Krauss did not pay sufficient attention to the guests on the 2011 cr=ise. I had heard this concern from one guest myself; on the other hand, I =Iso heard from several guests that they thought Krauss's presentat=ons were excellent and a highlight of the cruise. Accordingly, I did not g=ve this concern much weight. The second reason was that Krauss h=d allegedly asked a female guest on the cruise to join him and his partner= apparently for some sort of sexual activity (I cannot recall whether Krau=s was engaged or married or just seriously involved with his female compan=on at the time, although they were clearly romantically involved and seeme= very much in love). This is the first I had heard of this proposition. No=complaint by the guest or anyone else had been made to me at the time of t=e cruise, although I was on the cruise and clearly visible throughout the =ruise. I =sked Ms. Beauchamp for contact information for this guest. I did call the =uest and she substantially confirmed what Ms. Beauchamp had said. I apolog=zed on behalf of the organization. The guest indicated although she was ta=en aback by Krauss's proposition at the time, she did not want to =ursue the matter further. I then got in contact with Krauss. Krauss denied=the allegation. In light of the guest's reluctance to pursue the m=tter and Krauss's own denial and, importantly, because between the=time of the 2011 cruise and the Galapagos cruise we had instituted a polic= regarding harassment at any CF= event, which covers not just employees, but speakers and attendees, I dec=ded to go ahead with my plan and have Krauss as a speaker on the Galapagos=cruise. Krauss was fully aware of our harassment policy regarding CFI even=s because we had had a discussion about it. Therefore, I expected him to c=mply with that policy on the Galapagos cruise. As far as I know he did, be=ause we received no complaints about his conduct. Nor have we received any=complaints about his conduct at other events. Let me just take a moment to highlight=the 2012 policy, which you can find in full here, http://www.centerforinquiry.net/blogs/entry/cfis_new_policy_on_hostile_conductharassment_at=conferences/ <http://=ww.centerforinquiry.net/blogs/entry/cfisnew_policy_onhostileconducthar=ssmentatconferencesh along wi=h the announcement I made explaining the rationale for the policy. This po=icy was, certainly at its time, arguably the strongest any nonprofit organ=zation had regarding conduct at its events. Again, this policy shows that =ny suggestion that CFI, as an organization, or that I personally took a la= attitude regarding harassment is completely without factual foundation.q=ont> In your ema=l you mentioned that one staffer resigned after I invited Krauss on the Ga=apagos cruise. I'm not aware of any staffer resigning because of t=at. If you give me a name I could comment on the reasons for the staffer l=aving. Ms. Beauchamp remained an employee of CFI (and went on the Galapago= cruise with Krauss). 7 EFTA_R1_01656562 EFTA02520058 You mentioned also the comments that were made to me in March =012 by Melody Hensley. let me give you the background for that. CFI was ho=ding an event prior to the 2012 Reason Rally in DC. Richard Dawkins, Jessi=a Alquist, Jamie Raskin, and Lawrence Krauss were scheduled to speak at th= event. Melody Hensley was heavily involved in the planning for the event =nd in fact was tapped to make introductions for the speakers, including Kr=uss. (At the time she was in charge of the DC local branch.) During the pl=nning for the event she gave no indication whatsoever that she had any hes=tation about introducing or dealing with Krauss. (I will forward you some =mail correspondence confirming this.) =p style="margin:Opx 0px 10.66px">As I recall, Krauss4,=99s schedule resulted in his planned arrival being a little later than the=others. As it turned out, he was even further delayed. At some point when =t became clear that Krauss was going to be late, Hensley turned to me and =aid, "I know why Krauss isn't coming; he's embarra=sed to see me." I asked Hensley what she meant by this. She said K=auss had made a pass at her several years earlier and she had rebuffed him= I asked for some details. She said she was in a hotel room with him (I ca='t recall whether she said it was Krauss's hotel room, but=l think it was), and that Krauss tried to kiss her. She pushed him away an= said she wasn't interested. I asked if Krauss persisted; she said=he did not. Thinking out loud, I believe I said something to the effect of='well, if you want to make a complaint you probably can, although ='m not sure our policy at that time would cover that.' Ms.=Hensley said she was not interested in making a formal complaint.</=pan> Ms. Hensley40=99s statement that I "responded to her with silence" is ab=olutely false and I categorically and unqualifiedly deny it. We talked abo=t her concern, as indicated. Ms. Hensley's recall must be failing =er. Given=the passage of time (six years), the fact that Hensley did not want to pur=ue the matter, the fact that Krauss desisted when Hensley indicated she wa=n't interested, the fact that Hensley didn't even seem ver= bothered by the incident (as indicated, she had expressed no hesitation i= seeing Krauss), and the fact that we had no policy covering conduct by no=employees back in 2006 (in fact, CFI's zero-tolerance policy cover=ng employees themselves was not implemented until 2007, I believe -- I was=just hired as the attorney in July 2006), I decided not to do any further =bout this particular incident. However, the incident, along with observati=ns I heard at the Women in Secularism conference which we held later in th= spring of 2012 (observations which did not=C24emention Krauss, but rather some speakers at non-CFI events), w=s a factor in my thinking about the need for a policy covering conduct by =nvited speakers and guests at CFI conferences. Ms. Hensley made no other complaint=to me about Krauss, nor did she ever express to me her belief that we shou=d not invite Krauss to events. In closing, let me state that any accusations stating=that I neglected to take harassment complaints seriously are false. Furthe=more, I would regard them as a malicious attack on my character and my pro=essional reputation. </=pan> Sinc=rely, Ron=ld A. Lindsay =div class="gmail_quote"> Forwarded message From: =span class="m_-6189807211976031442m_-277658877943275076Apple- converted-s=ace"> Ronald Lindsay=C24 1<mailto Date: Sun, Dec 10, 2017 at 9:15 PM 8 EFTA_R1_01656563 EFTA02520059 Subject: Fwd: URGENT: BuzzFeed N=ws inquiry re allegations of sexual harassment by Lawrence Krauss To: <mailto Forwarded messa - From: Peter=Aldhous < </=» <nlailtc > Date: Sun, Dec 10, 2017 at 8:13 PM Subject: URGENT: Buz=Feed News inquiry re allegations of sexual harassment by Lawrence KraussTo: <mailto Mr. Lindsay: I'm a reporter for BuzzFeed=News who has been investigating sexual misconduct allegations against Lawr=nce Krauss. The story =oncerns Krauss's actions towards students while a professor of phy=ics at Case Western Reserve University, as well as his conduct in non-acad=mic settings as a prominent figure in the skeptics movement. I am reportin= this story along with two of my colleagues on the science desk, Azeen Gho=ayshi and Virginia Hughes. O=r story is about several allegations of sexual misconduct dating from 2006=to 2016. Our reporting also goes into how the various institutions Krauss =as been affiliated with — Case Western, Arizona State University, =he Australian National University, the New College of the Humanities and t=e Center for Inquiry, for which you formerly served as president —=have handled complaints and concerns about his behavior during this time. =/span> Our story is corroborated by =mails, university documents, official complaints, testimony from victims a=d witnesses, and interviews with more than two dozen of Krauss's c=rrent and former academic colleagues, students, and peers in the skeptics =ovement. I am writing to you =ow because you are personally named in the story, and because you had exec=tive responsibility for CFI's actions during the time of some of t=e alleged incidents. I wante= to offer you the opportunity to comment and/or respond to the main facts =e plan to publish regarding your involvement as the former head of CFI dur=ng this time. If you wish to comment on any of these findings, we need to =ear from you as soon as possible. We are planning on publishing our story Tuesday morning US Eastern Ti=e. Based on our reporting so=far, this is what we plan to publish that concerns you: 9 EFTA_R1_01656564 EFTA02520060 One incident involving Krau=s allegedly occurred in May 2011 on a CFI cruise <https://www.youtubr.com/watch?v=qnrP8B-IKxE> . Attendees had Krauss allegedly propositioned a f=male cruise-goer, who rejected an invitation to join him and his female co=panion for sex in their cabin. <https://web.archive.org/web/20100919014301/http://centerforin=uiry.net/cruise2011/reservations> No complaint was made,=but the incident was reported to a CFI staffer at the time. <=li> CFI's leadership continued to embrace Krauss, making him an honorary member of its board of directors in December 2011. =/span> * But at least two staffers were sufficiently concerned =bout reports of Krauss's behavior that they urged you not to invit= him on a 2014 cruise <http://action.centerforinquiry.net/site/M=ssageViewer?em_id=49328.0> of the Galapagos Islands. <=li> In June 2013, after you rejected their advice and invited him on the=cruise, one of those staffers resigned. At a conferen=e in March 2012, another woman, who at that point was also an employee of =FI, told you about an incident in 2006 in which Krauss forcibly kissed and=groped her in a hotel room. According to this woman, after she told you ab=ut this in person, you responded to her with silence. =he woman later told two other employees in CFI's management about =he incident, and expressed her discomfort at having Krauss continue to spe=k at events. CFI continued to book Krauss as a speaker=at its events. =gain, if you wish to comment on or clarify any of these points, please get=in touch with us as soon as possible. If I do not respond immediately it i= because I am on another call, so please leave the best phone number to re=ch you. Thanks, <= iv style="line-height:1.38;margin-top:0pt;margin-bottom:0pt">Peter Aldhous <tel:%28415%29%20800-3471> =415) 503-7323 =/b> --=span class="m_-6189807211976031442m_-277658877943275076Apple- converted-s=ace"> converted-s=ace"> Peter Aldhous, PhD Science reporter I BuzzFeed News tel:=span class="m_ m_-27765887794327S076Apple- <tel:%28415%29%20800-3471> cell: <mailto ©paldhous <https://twitter.com/paldhous> www.peteraldhous.com <http://www.peteraldhous.com/> 10 EFTA_R1_01656565 EFTA02520061 =/div> <=1"-- =div> Ronald A. Lindsay Senior Research Fellow=br>Center for Inquiry <mailto:rlindsay@centerforin=uiry.net> Cerl: <tel <=div> <=span> Peter Aldhous, PhD Sci=nce reporter I BuzzFeed New= tel: <tel cell:. <=div> Q=A0please note @paldhous www.peteraldhous.com</=> The information contained in this communicati=n is confidential, may be attorney-client privileged, may constitute=inside information, and is intended only for the use of the addressee. =t is the property of JEE Unauthorized use, disclosure or copying of =his communication or any part thereof is strictly prohibited 11 EFTA_R1_01656566 EFTA02520062 and may=be unlawful. If you have received this communication in error, please n=tify us immediately by return e-mail or by e-mail to =a href="mailto:[email protected]" target="_blank">jeevacation@gmai=.com, and destroy this communication and all copies thereof, inc=uding all attachments, copyright -all rights reserved please note <=iv>The information contained in this communication is confidential, may=be attorney-client privileged, may constitute inside information, and i= intended only for the use of the addressee. It is the property of J=E Unauthorized use, disclosure or copying of this communication or a=y part thereof is strictly prohibited and may be unlawful. If you have =eceived this communication in error, please notify us immediately by [email protected] <mailto:[email protected]> , and destroy =his communication and all copies thereof, including all attachments. co=yright -all rights reserved please not= The information contained in this communication is confidentia=, may be attorney-client privileged, may constitute inside information,=and is intended only for the use of the addressee. It is the property o= JEE Unauthorized use, disclosure or copying of this communicatio= or any part thereof is strictly prohibited and may be unlawful. If you=have received this communication in error, please notify us immediately=by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communicat=on and all copies thereof, including all attachments. copyright -all ri=hts reserved 12 EFTA_R1_01656567 EFTA02520063 =C24> please note The information containe= in this communication is confidential, may be attorney-client privileg=d, may constitute inside information, and is intended only for the u=e of the addressee. It is the property of JEE Unauthorized use, disc=osure or copying of this communication or any part thereof is strictly =rohibited and may be unlawful. If you have received this communicati=n in error, please notify us immediately by return e-mail or by e-mail =o jeevacation@g=ail.com <mailto:[email protected]> , and destroy this communication and all copies thereof, =ncluding all attachments. copyright -all rights reserved <1=iv> 13 EFTA_R1_01656568 EFTA02520064

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Exhibit G Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 1 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 1 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, Plaintiffs, -vs- CONFIDENTIAL ALAN M. DERSHOWITZ, Defendant. ____________________________________/ VIDEOTAPED DEPOSITION OF VIRGINIA ROBERTS GIUFFRE Saturday, January 16, 2016 9:07 a.m. - 2:48 p.

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Dept. of JusticeAug 22, 2017

11 MAY 25-MAY 27 901_Redacted.pdf

Kristen M. Simkins From: Irons, Janet Sent: Wednesday, May 25, 2016 11-29 AM To: Richard C. Smith Cc: Jeffrey T. We Subject: Meeting with Prison Society tomorrow Hello Warden Smith, I'm writing in preparation for our meeting with you and Director Hite tomorrow at 9:30 to talk about the Law Library. We have been in touch with Kim Kelmor, Assistant Director ofthe Law Library at Penn State, who has experience with prison libraries. She has helpfully provided us with some questions and guida

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Court UnsealedSep 9, 2019

Epstein Depositions

10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Eps

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