Epstein Secrets

t within his law firm and his client, that being Mr. Epstein. When further asked by the court, has Mr. Epstein

-RBR Doc 6482 Filed 10/19/18 Page 4 of 97 COURT: I disagree with you. .... Take that up in your state court litigation. (Apr. Tr. 43:19-45:6.) B. Epstein has Provided Sworn Testimony and His Attendance at the Show Cause Hearing is Not Necessary. The Court allowed Movants to take Epstein's deposition

bove cause, testified on his oath as follows: THE WITNESS: Yes. DIRECT EXAMINATION BY MR. SCAROLA: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each of your residence addresses? MR. GOLDBERGER: I think it's beyond the scope. I'm going to object to Fifth

ief Expedited Hearing Requested on or before October 24, 2018, so that the Court may rule prior to the October 26, 2018, hearing) Jeffrey Epstein ("Epstein") moves the Court, on an expedited basis, to be excused from attending the October 26, 2018, show cause hearing, and states: INTRODUCTION On April

n the United States Virgin Islands, August /‘(2018. I declare under penalty of perjury that the foregoing is true and correct. APPROV FORM: RNEY REY EPSTEIN EFTA00793497

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

r L.M., E.W. and Jane Doe: S.J. QUINNEY COLLEGE OF LAW By PAUL G. CASSELL, ESQUIRE (Telephonically) ALSO PRESENT Above & Beyond Reprographics By Manuel Santiago, Videographer Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793411 Case 09-34791-RBR Doc 6482 Filed 10/19/18 Page 12 of 97 1 2 3 4

bove cause, testified on his oath as follows: THE WITNESS: Yes. DIRECT EXAMINATION BY MR. SCAROLA: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each of your residence addresses? MR. GOLDBERGER: I think it's beyond the scope. I'm going to object to Fifth

wed to intervene in this action, now respectfully submits this Motion to Compel Jeffrey Epstein to Provide Answers to Deposition Questions. Because Epstein has improperly refused to answer multiple questions at his recent deposition, the motion should be granted. Relevant Factual Background The facts

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

he Agreed Order." DE 6366 at 5 (citing DE 1194). Mr. Epstein improperly refused to answer many questions about

S.J. QUINNEY COLLEGE OF LAW at the UNIVERSITY OF UTAH By PAUL G. CASSELL, ESQUIRE (Telephonically) ALSO PRESENT Above & Be ond Reprographics By Manuel Santiago, Videographer Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793513 Case 09-34791-RBR Doc 6488 Filed 10/22/18 Page 16 of 165 1 2 3

Have you over pied any allegations, Mr. Berger, that turned out to be untrue. down the lino? 1 4 S 147 Epstein? A It's patently [also that Jeffrey Epstein wan not Intel injured by anything that Brad Edwards did or if -- I don't deny that there wan a 0042l scheme that used the three cases we had as bait.

Boulevard, Suite 1001 $ 9:27 West Palm Beach, FL 33401 4 This is the videotaped deposition of 4 1561) 471-2995 5 Berger in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555 Palm Beach Lakes Boulevar

, FL 33401 4 This is the videotaped deposition of 4 1561) 471-2995 5 Berger in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555 Palm Beach Lakes Boulevard, Suite 301 0 9 West Palm Beach, FL 33401 B

th Florida. He had a case -- ho had cases against Mr. Epstein. Or he had clients -- I don't know if he actuall

position is being hold 2255 Glades Road, Suite 218-A, Boca Piton, :0 Florida 23431. 10 For Plaintiff: 11 DARREN K. INDYKE, PLLC Ii My name is Manuel Santiago. I am the 575 Lexington Avenue 12 VICIOD9taptier representing Above a Beyond 12 New York, NY 10022 By DARREM K. INDERE, ESQUIRE 29 Reprograph

r. Scarola 57 Certificate of Oath 62 Certificate of Reporter 63 Read & Sign Letter to Witness 64 EXHIBIT INDEX No. Description Page No 1 Jeffrey Epstein's Sworn Declaration 13 5 Bankruptcy Court Order 34 (Exhibits 2-4 are incorporated in the prior deposition, as agreed by Counsel.) Palm Beach Rep

ehalf of Jeffrey Epstein. MR. IANNO: Joseph Ianno, Carlton Fields on behalf of Fowler White. MR. GOLDBERGER: And Jack Goldberger on behalf of Mr. Epstein. MR. CASSELL: Paul Cassell, an attorney in Utah on behalf of L.M., E.W. and Jane Doe. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA0079360

to L.M. on that CD? MR. GOLDBERGER: I'm going to instruct Mr. Epstein to invoke his Fifth Amendment privileges as to that question, Mr. Cassell. Jeffrey, just say Fifth. THE WITNESS: Fifth. BY MR. CASSELL: Q When did you first learn about information regarding L.M. on that CD? A Sorry. The ques

MR. GOLDBERGER: And Jack Goldberger on behalf of Mr. Epstein. MR. CASSELL: Paul Cassell, an attorney in Utah

SELL, ESQUIRE (Telephonically) ALSO PRESENT Above & Beyond Reprographics 2161 Palm Beach Lakes Boulevard, Suite 412 West Palm Beach, FL 33409 By Manuel Santiago, Videographer Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793601 Case 09-34791-RBR Doc 6488 Filed 10/22/18 Page 104 of 165 1 2 3

Are you aware of strong reservations having been expressed by Gary Farmer to turning over the discs containing potentially privileged materials to Jeffrey Epstein's legal counsel. MR. IANNO: You're asking if he was aware then or based on reading this? BY MR. SCAROLA: Q Are you aware, as you sit here today, t

Farmer Jaffe. MR. IANNO: Joseph Ianno, Carlton Fields, on behalf of Fowler White. MR. LINK: Scott Link and let Jennifer Lettman on behalf of Mr. Epstein. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00803635 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 2

EFTA00803632 L 1 2 3 4 APPEARANCES: For Jeffrey Epstein: LINK & ROCKENBACH, P.A. 1555 Palm Beac

Scott Link and let Jennifer Lettman on behalf of Mr. Epstein. Palm Beach Reporting Service, Inc. 561-471-2995

O, JR, ESQUIRE 17 18 ALSO PRESENT 19 Above & Beyond Reprographics 2161 Palm Beach Lakes Boulevard, Suite 412 20 West Palm Beach, FL 33409 By Manuel Santiago, Videographer 21 22 23 24 25 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00803633 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15