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

ervenors to that proceeding, have a right to participate in the discovery process. MR. LINK: We will see what Judge Hafele says. Mr. Ianno -- MR. IANNO: Well, I think what we need to do is do the read or waive and then just splice it and start -- not to continue it. We will just close it off entir

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 UNCERTIFIED TRANSCRIPT DISCLAIMER IN THE MATTER OF EPSTEIN v. ROTHSTEIN DRAFT !!!! NOT PROOFREAD EFTA00804162 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

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

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

you okay with me doing it? MR. SCAROLA: We want Mr. Epstein to invoke any privilege that Mr. Epstein consid

erveners to that proceeding, have a right to participate in the discovery process. MR. LINK: We will see what Judge Hafele says. Mr. Ianno -- MR. IANNO: Well, I think what we need to do is do the read or waive and then just splice it and start -- not to continue it. We will just close it off entir

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

ervenors to that proceeding, have a right to participate in the discovery process. MR. LINK: We will see what Judge Hafele says. Mr. Ianno -- MR. IANNO: Well, I think what we need to do is do the read or waive and then just splice it and start -- not to continue it. We will just close it off entir

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

ecord? MR. SCAROLA: My name is Jack Scarola. I am counsel on behalf of Bradley Edwards. MR. EDWARDS: Brad Edwards on behalf of 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 Repo

e deposition. MR. LINK: Mr. Scarola, is it the one that says Exhibit 1? MR. IANNO: It's the depo notice. MR. LINK: Separate from Exhibit 1? MR. IANNO: Yes. It's the notice of deposition. MR. SCAROLA: I don't have -- MR. LINK: You didn't bring copies? MR. SCAROLA: I don't have a third copy of th

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

rd? MR. SCAROLA: Jack Scarola appearing on behalf of Bradley Edwards. MR. LINK: Scott Link and Kara Rockenbach on behalf 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,

by Mr. Link at the time of his first review of the files. A That's correct. Q And then a subsequent request was made for all of Fowler White's Epstein-related files, and a second delivery occurred of all of the files, correct? MR. IANNO: Object to form. THE WITNESS: With the exception of -- Palm

describe the contents of the folders. Q I understand that. But Fowler White was closing its files because it had concluded its representation of Jeffrey Epstein as of that time, correct? A Correct. Q So as far as Fowler White knows, since it had concluded its representation of Jeffrey Epstein and was c

s because it had concluded its representation of Jeffrey Epstein as of that time, correct? A Correct.

MR. LINK: Join. Almost everything you do. MR. EDWARDS: You don't want to carve anything out. MR. LINK: Anything inappropriate I don't join. MR. IANNO: We are on the record here. BY MR. SCAROLA: Q The number of the boxes delivered to Mr. Link was 44. A I didn't count the boxes. Q Let me hand

the year 2012? A I don't know. Q All of the emails that you were able to locate between Fowler White and Judge Carney have been produced? MR. IANNO: Object to form. THE WITNESS: All the emails between Fowler White and Judge Carney which referenced the handling of the disc have been produced.