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efta-efta00030491DOJ Data Set 8Correspondence

EFTA00030491

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DOJ Data Set 8
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efta-efta00030491
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
August 16, 2021 AUSA Det. Attorneys prep shown photobook containing 20 photographs. Asked to see if recognize anyone in the book. Instructed that just because someone is in the book, does not mean knows them or that they have anything to do with this case. Instructed just to look and see if. recognizes anyone. o 1 — DNR (do not recognize) o 2 — DNR o 3 — DNR o 4 — DNR o 5 — (bad picture of her) o 6 — DNR o 7 — Jeffrey Epstein o 8 - DNR o 9 - DNR o 10 - DNR o 11 - DNR o 12 - DNR o 13 - DNR o 14 - DNR o 15 - DNR o 16 - Ghislaine Maxwell (bad picture of her; ■ recalls her having longer hair) o 17 — DNR o 18 - DNR o 19 - DNR o 20 - DNR shown additional photographs and asked if he recognized them: o 1 — Little St. James o 2 - Big House at Zorro Ranch o 3 — 9 E 71' Street o 4 — Building in Paris where JE's apartment was o 5 — DNR (looks somewhat like GM's townhouse, but can't be sure) • • did not know how old was when he met her. He believes she looked like she was in her 20s, but he had no idea of her actual age. did not know how old was when he met her. He believes she looked like she was in her 20s, but he had no idea of her actual age. EFTA00030491 confirmed that he does not have any flight records for JE's planes from before 1999. All were turned over to JE's attorney in or about 2006. [At this point, AUSAs & joined] Prepared for trial testimony. previously undisclosed, clarifying, or different recollections below. o JE had the G2B from approximately 1994 through approximately 2012 or 2013. G2B was silver with burgundy strip at first, then painted black. Inside had burgundy carpet. o JE had the Boeing form approximately 2000 through approximately 2017 o JE bought the G4 in approximately 2012 or 2013 o JE bought firs helicopter in approximately 1999 or 2000. Between approximately 1999 and the mid-2000s, GM flew JE's helicopter at least 30 times. U would be in the helicopter with GM. To knowledge, JE owned all the helicopters, GM never owned any of the helicopters. also flew JE's helicopters. o • does not recall being told any rules for him or other pilots regarding how to interact with passengers on JE's planes. • does remember having to sign confidentiality forms, which understood meant he could not write a book about his employment. o GM seemed to like and was nice to M. • remembers GM as a nice person. reported to GM, and GM was second in charge under JE above JE's other employees. In JE's office, JE had his own separate office; GM had a desk in the office but not her own separate office room. o During initial meeting with SDNY, may have had trouble remembering which he met first ( or but in thinking about the context in which he saw those two passengers since then,. has remembered that he only saw on the G2 (not the Boeing) and he only saw on the Boeing (not the G2). That recollection helped • confirm in his own mind that he met first and second. o Over time knew GM, her hair length varied from about shoulder length to shorter cuts. o JE primarily took the Concord to go to Paris in the 1990s. o visited JE's home in Columbus, OH o recalls that JE purchased the 71' Street NY residence in approximately the mid-1990s (recalls it was 7 stories); the Palm Beach residence in approximately the early 1990s; the NM ranch in approximately 1996 or the late 1990s (recalls it had approximately 11,000 acres); Little St. James in approximately the 2000s; and the Apartment in Paris in approximately the 2000s. o • recalls meeting U in approximately the late 1990s/early 2000s o U recalls meeting U in approximately the late 1990s 2 EFTA00030492 EFTA00030493 tte-Str:-Si Amp •••• • I FA: '4 EFTA00030494 EFTA00030495 Ite o we - ..• • • 5 .7. .1 k rr, 4 •• ; 4: . F. -..„..i. A •••.j. .... - , ...‘ ' ;.: • %) %.60 C.4 1 ° f.. • :T i hh.t.. • : . 4.. . .. • .. ."..t......• t ""i . _ N, LPY 1161.4 . .. lik. ..ett er . . " ii. keit; .. ii I • ir.,,,r , ii : , a •••• jic42,„„..... . ,• iy. . i• 0, .t..4 , 1•Sie a al‘ .1 . !" S=if.141 I lI 1"---1111-rfEr EFTA00030496 EFTA00030497

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Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33

Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work Product and Similar Protections by Government and for Production of Documents (DE 414). The Motions are fully briefed and ripe for review. The Court has carefully considered the Motions and is otherwise fully advised in the premises. I. Background The facts, as culled from affidavits, exhibits, depositions, answers to interrogatories and reasonably inferred, for the purpose of these motions, are as follows: From betw

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