Epstein Secrets

who you reported their allegations, correct? 12 A. Correct. Actually, it's Dawson — 13 Q. One was from New York and California — 14 A. — Sergeant Dawson, right. 15 Q. — and they had — they were kind of jumping 16 on the Internet train that resulted from the publicity 17 of Mr. Epstein's charge.

A. Correct. 10 Q. And then you had occasional calls from people 11 who you reported their allegations, correct? 12 A. Correct. Actually, it's Dawson — 13 Q. One was from New York and California — 14 A. — Sergeant Dawson, right. 15 Q. — and they had — they were kind of jumping 16 on the Inter

tirt & P.A. 1820513ismne Boulevard B.B. Susie 2218 4 Plaintiff Miami, Phone S 1, 6 ws- VOLUME al OF IV 7 8 Oa behalf of the Plaintiff, Jame Doe No. IL ISIDRO MAKIJEI. GARCIA, ESQUIRE GARCIA, MAINS& BOO-RINGER 9 224 Dan Awnuo Suite 90) West 33401 Dcfaxlinta. 10 tilde Phan( 9 11 in

tein would ask them to take off all 23 BY MR. WEINBERG: • 23 thek clothes, and they would take off as much clothes 24 • Q. Page 9 on So Ms. Jane Doe 4's 24 as they felt comfortable with and we re not forced to 25 . aaffidavit. date of birth is and she was 18 at the time of 25 take off

m what they did with the 14 $200 they received? 15 A. I might have. I can't recall at this time if 16 I did or didn't. 17 Q. Did you ever ask lane Doe 103 — strike that. 18 • • Jane Doe I.03 told you that she had received a 19 significant amount of money because she said she bad 20 • gone to

phone 23 numbers connected, but not the content of the call, 24 correct? 25 A. No, not the content. Date and time. Page 546 1 now, Sergeant Dawson, but back then it was Detective 2 Dawson. 3 Q. Were you a participant in that second 4 investigation — 5 A. Yes. 6 Q. -- that has a separate

content of the call, 24 correct? 25 A. No, not the content. Date and time. Page 546 1 now, Sergeant Dawson, but back then it was Detective 2 Dawson. 3 Q. Were you a participant in that second 4 investigation — 5 A. Yes. 6 Q. -- that has a separate case number, an 7 '06 number instead of

Doe 103 was one of the witnesses who was 19 at the center of the State investigation, correct? 20 A. One of them, yes. 21 Q. And you knew that Jane Doe 103 had a MySpace 22 page that was one of the MySpace profiles that was 23 provided to the State Attorney by Mr. Epstein's then 24 counsel, Pro

3 A. Correct 4 Q. And she made a phone call to you to complain 5 about the service? 6 A. Correct. 7 Q. And what was the conversation between Jane Doe 8 103 and you on that occasion? 9 A. It was finals week and she could not leave and 10 not take her final to come down for the grand jury. I 11

his particular date, 2 October 6th, 2005 well, you tell me. What did 3 you do on that date? 4 A. That was the date back then when Detective 5 Dawson and I went to down to speak to Jane Doe No. 4. 6 Q. Jane — 7 A. Doe No.4. 8 Q. Okay. And where did you have to go? 9 A. To the university she

VIN, ESQUIRE LEOPOLD KUVIN 2925 PGA Boulevard State 200 5 Palm Beach Gardens, Florida 33410 Phone: 6 On behalf of the Plaint", L.M., SW. and Jane Doe: e 9 BRADLEY J. EDWARDS. ESQUIRE FARMER. LOW, WEISSRM. EDWARDS 10 195 Kra & LEHRMAN, P.L 425 North Andrews Avenue 11 Suite 2 Fort Lauderdal

g the question. So if you would, 5 103 at this point. 5 rather than lead the witness through his answer 6 A. "Jane Doe No. 103 advised one day, Jane Doe 6 so he can answer the way that you would like, 7 No. 103 was unable to state the exact date this incident 7 would you please ensure that the witn

nds, Miller-El t i Cock- rell, 537 U.S. 322, 123 S. . 1029, 154 L.Ed.2d 931 (2003), Fuller Johnson, 114 F.3d 491, 498 ( Cir.1997) (distinguishing Dawson based on the fact that the govern- ment presented evidence that de- fendant was a member of a gang that had committed violen and un- lawful acts);

ney General or any office under his direction.'" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)). For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

LM BEACH POLICE DEPARTMENT rime: 15:01:37 Page: 23 Incident Report Program: CMS301L :ase No • 1-05-000368 attachment file. (Continued) Det. Dawson was assigned to relieve Officer Munyan at 4:00 pm; he informed me that at approximately 8;00 pm, Epstein had left for the airport and his private j

e informed the USAO and the FBI that she was not a victim of any offense committed by Epstein, and, as a result, the USAO did not consider informing Jane Doe #2 about the non-prosecution agreement. Except as otherwise admitted above, the government denies Request No. 2(e). 3. Denied. 4. Denied. 5. The

was in the shower at the moment and would be traveling back to Orlando to attend Colle e..4 I informed her I would be en route to her home in Det. Dawson and I drove to the...1ft home and met with 'and During a sworn taped statement, iller stated she was taken to the house by Haley Robson. She was

etisatabnFIESB0DEitdaidagaMGM 6 P r. fc2 6 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 OF AMERICA, Respondent. GOVERNMENT'S NOTICE OF FILING DECLARATION OF FBI SPECIAL AGENT TIMOTHY R. Responden

l. 17 BY MR. KUVIN: 18 Q. Let's take a look at Narrative 17. It 19 looks like you made contact with someone else, you 20 along with Detective Dawson made contact with 21 somebody and left a business card at the front door. 22 Do you see that? 23 A. Yes. Yes,' do see it. 24 Q. Do you recall

3 SPENCER T. KUM!. ESQUIRE LEOPOLD KUVIN 4 2925 PGA Bodevard Suite 200 5 Pam flaida 33410 Phone. 7 On behalf et the Pin:dirk Ltd E.W and Jane Doe: 6 15 16 17 18 19 20 KAI/691M W EZELL, ESQUIRE PODHURST ORSEOC 21 25 Wen Hagler Street SAC 800 22 Moe: 23 (Via one) 24 25 9 BRAD