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

fendants/Counter-Plaintiffs: SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. By JACK SCAROLA, ESQUIRE For Fowler White: CARLTON FIELDS, PA By JOSEPH IANNO, JR, ESQUIRE For L.M., E.W. and Jane Doe: S.J. QUINNEY COLLEGE OF LAW By PAUL G. CASSELL, ESQUIRE (Telephonically) ALSO PRESENT Above & Beyond R

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

fendants/Counter-Plaintiffs: SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. By JACK SCAROLA, ESQUIRE For Fowler White: CARLTON FIELDS, PA By JOSEPH IANNO, JR, ESQUIRE For L.M., E.W. and Jane Doe: S.J. QUINNEY COLLEGE OF LAW at the UNIVERSITY OF UTAH By PAUL G. CASSELL, ESQUIRE (Telephonically) ALS

0 and RICE PUGATCH ROBINSON STORFER & COHEN. by 10 of his obvious concern about the allegations in the II CHAD P. PUGATCH. Esquire On behalf of Jeffrey Epstein 11 motion. 12 12 MR. PUGATCH: Good afternoon, your Honor. 13 CARLTON FIELDS. BY NIALL SKLAUCHLAN. Esquire 13 Chad Pugatch, P-u-g-a-t-c-h, her

tive intervenors. For that reason I think the motion 23 should be denied as to E.W. and Jane Doe. 24 MR. PUGATCH: Your Honor, on behalf of 25 Mr. Epstein, we would join in that objection, that limited Page 6 THE CLERK: Okay. 2 ECRO: Do you want me to print you a 3 calendar that shows his name? 4

n the II CHAD P. PUGATCH. Esquire On behalf of Jeffrey Epstein 11 motion. 12 12 MR. PUGATCH: Good af

e. 24 MR. PUGATCH: Your Honor, on behalf of 25 Mr. Epstein, we would join in that objection, that limited P

PUGATCH: Good afternoon, your Honor. 13 CARLTON FIELDS. BY NIALL SKLAUCHLAN. Esquire 13 Chad Pugatch, P-u-g-a-t-c-h, here as co-counsel for II JOSEPH IANNO. Esquire 14 Jeffrey Epstein, along with Mr. Scott Link, who will IS On behalf of Fowler White 15 introduce himself. 16 AKERMAN. LLP. by 16 MR

RSON, Esquire On behalf of Farmer Jaffe SCOTT LINK, Esquire and RICE PUGATCH ROBINSON STORFER & COHEN, by CHAD P. PUGATCH, Esquire On behalf of Jeffrey Epstein CARLTON FIELDS, BY NIALL McLAUCHLAN, Esquire JOSEPH IANNO, Esquire On behalf of Fowler White AKERMAN, LLP, by JOAN LEVIT, Esquire On behalf of

hree putative intervenors. For that reason I think the motion should be denied as to E.W. and Jane Doe. MR. PUGATCH: Your Honor, on behalf of Mr. Epstein, we would join in that objection, that limited OUELLETTE & MAULDIN COURT REPORTERS, INC. EFTA00787723 1 2 3 4 5 6 7 8 9 10 11 12 13

COHEN, by CHAD P. PUGATCH, Esquire On behalf of Jeffrey Epstein CARLTON FIELDS, BY NIALL McLAUCHLAN, Es

Jane Doe. MR. PUGATCH: Your Honor, on behalf of Mr. Epstein, we would join in that objection, that limited O

nd RICE PUGATCH ROBINSON STORFER & COHEN, by CHAD P. PUGATCH, Esquire On behalf of Jeffrey Epstein CARLTON FIELDS, BY NIALL McLAUCHLAN, Esquire JOSEPH IANNO, Esquire On behalf of Fowler White AKERMAN, LLP, by JOAN LEVIT, Esquire On behalf of Michael Goldberg PAUL G. CASSELL, Esquire (via telephone)

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

Bradley Edwards, Esquire (Telephonically) For Fowler White: CARLTON FIELDS, PA 525 Okeechobee Boulevard, Suite 1200 West Palm Beach, FL 33401 By JOSEPH IANNO, JR, ESQUIRE Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793600 Case 09-34791-RBR Doc 6488 Filed 10/22/18 Page 103 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

By Bradley Edwards, Esquire 14 For Fowler White: 15 CARLTON FIELDS, PA 525 Okeechobee Boulevard, Suite 1200 16 West Palm Beach, FL 33401 By JOSEPH IANNO, JR, ESQUIRE 17 18 ALSO PRESENT 19 Above & Beyond Reprographics 2161 Palm Beach Lakes Boulevard, Suite 412 20 West Palm Beach, FL 33409 By M

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.

d that the transcript is a true and complete record of my stenographic notes. I further certify that on the 22nd day of October, 2018, I notified JOSEPH IANNO, ESQUIRE that the deposition of JAMES N. HURLEY, ESQUIRE was ready for reading and signing by the witness. I further certify that I am not a relat