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ict Attorney, Sex Crimes Unit / Trial Bureau 40 New York District Attorneys Office One Hogan Place New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYS1D # OS1909, Supreme Court Case # 30129-2010 Dear ADA Gaffney and ADA Egan: As you know, we represent Jeffrey E. Epstein, who is scheduled to
ieve expose the stark contrast between the inflammatory, speculative case summary presented by the Board of Examiners in its recommendation for Mr. Epstein, and the actual evidence that exists concerning the alleged conduct for which New York seeks to require Mr. Epstein to register under SORA. We beli
New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYS1D # OS1909, Supreme Court Case # 3
New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYS1D # OS1909, Supreme Court Case # 30
the Board of Examiners in its recommendation for Mr. Epstein, and the actual evidence that exists concerning
ngst the 13 officers that there were sex utensils or sex objects 14 That were being identified and pulled out of the trash? 15 A. Yes. 16 MS. ARBOUR: Form. 17 THE WITNESS: I recall the incident, the thing 18 you're talking about, which was later ruined out to 19 be a handle of a — utensils.
10 - - - EXHIBITS 11 12 NUMBER DESCRIPTION PAGE 13 DEPOSITION EX. 29 MESSAGE BOOKS 592 DEPOSITION EX. 30 HANDWRITTEN NOTE ON 617 14 JEFFREY E. EPSTEIN MEMO PAD 15 DEPOSITION EX. 31 HANDWRITTEN MESSAGE 622 16 17 18 19 20 21 22 23 24 25 1 counsel? 2 MS. ARBOUR: Form. 3 THE WITNESS
re talking about right before the recess, do you ever recall dicr-ncsions with the State Attorney's office about an offer that was extended to Mr. Epstein to plead guilty and receive a five-year period of probation for an aggravated assault charge? A. Yes. Q. And that was a subject of discussion bet
DEPOSITION EX. 30 HANDWRITTEN NOTE ON 617 14 JEFFREY E. EPSTEIN MEMO PAD 15 DEPOSITION EX. 31 HANDWR
DEPOSITION EX. 30 HANDWRITTEN NOTE ON 617 14 JEFFREY E. EPSTEIN MEMO PAD 15 DEPOSITION EX. 31 HANDWRI
ney's office about an offer that was extended to Mr. Epstein to plead guilty and receive a five-year period o
617 14 JEFFREY E. EPSTEIN MEMO PAD 15 DEPOSITION EX. 31 HANDWRITTEN MESSAGE 622 16 17 18 19 20 21 22 23 24 25 1 counsel? 2 MS. ARBOUR: Form. 3 THE WITNESS: I believe so, yes. 4 BY MR. WEINBERG: 5 Q. And that was an offer that was extended by the 6 State Attorney following di
d experience that code 14 words are often used? 15 A. Correct 16 MR. PIKE: Form 17 BY MI!: EDWARDS: 18 Q. In this particular case regarding Jeffrey 19 Epstein, the words work and massage in your training 20 and experience, are those code words that were used 21 by Jeffrey Epstein and the other people wo
7 TARA A FDDILGAN, ESQUIRE TARA A MINICAR. P A 8 224 Dina Street Suite 900 9 West tide 3340! Mae: 10 1/. Cte tehalfof the Defendant inlay Epstein: 12 MICHAEL PIKE, ESQUIRE BURMAN, ORITTON, LUIT1ER & COLEMAN, U.1) 13 303 Barn Bouienad Suite 4t0 14 West tads. 33401 Phone- 15 16 and 17
17 Q. And from what I understand based on the 18 report, house manager Alfredo Rodriguez, calls the 19 police because of a suspicious vehicle in Jeffrey 20 Epstein's driveway? 21 MR. PIKE: Form. 22 THE WITNESS: Correct. 23 BY MR. EDWARDS: 24 Q. Officer Munyan is the one reporting to the 25
6-b3b7-dcda51494142 EFTA00298296 Page 139 1 (Mr. Epstein returned the deposition 2 mom.) 3 BY MR. KUVI
lready 11 cameras in place? 12 MR. PIKE: Form. 13 THE WITNESS: I do not believe so. 14 BY MR. EDWARDS: 15 Q. All right So when you arrived, Jeffiey 16 Epstein was asking for your assistance in helping 17 set these cameras up? 18 A. I take that back It might have been, the 19 cameras might
to the court's 1 2 3 4 5 6 7 ‘:) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 313 need a mini or any of that. MS. ARBOUR: I don't need a fdl copy. Just a mini. I don't need any of that other stuff. MS. O'CONNOR: We're going to read. (Witness excused.) (Deposition w
d, was examined and testified as follows: DIRECT EXAMINATION BY MR. PIKE: Q. Sir, my name is Michael Pike. 1 teprrsaa a gentleman by the name of Jeffrey Epstein in this matter. Have you ever had your deposition taken before? A. No. Q. Okay. The way that it works is the person sitting to your right and to
ctronically signed by cynthia hopkins (601-051-9764934) coal 4d6c-3516.4ced.842b-e3t2cle0822ed EFTA00729391 Page 26 Page 28 1 BY MR. PIKE: 3. Epstein prior to today? 2 Q. Do you know whether Of not Jane Doe No. 4 2 A. Yes. 3 was seeing a psychologist, psychiatrist or social 3 Q. How have yo
23 because of a family matter in Al t and it was a 24 A. No. 24 legal issue that she said it was a family 25 Q. Have you over heard the name Jeffrey 25 issue, a legal issue. So, I asked her for the 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins
know where Jane Doe No. 4 worked at 14 against Mr. Epstein? 15 anyplace of employment between an? 15 MS.
10 303 Banyan Boulevard Suite 400 11 Wed Palm Florida 33401 INDEX VOLUME I 12 13 14 15 16 17 ROCKY ORE22011 BY MR. PE103 3 19 BY MS. ARBOUR 33 20 21 22 23 24 25 18 WITNESS: DIRECT CROSS REDIRECT RECRO&S 9 10 11 12 13 14 15 16 17 38 19 20 21 22 23 24 25 Page 4
Page UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME I OF II Related cases: 08-80232, 08-08380, 08-80381, 08-80994 08-80993, 08-80811, 08-80893, 09-80469 09-80591, 09-80656, 09-
T REPORT 45 PROPERTY RECEIPTS 126 1 PROCEEDINGS 2 MR. KUVIN: Just so we're clear with 3 respect to the deposition, I understand that 4 Mr. Epstein has three attorneys here today but 5 only one of them, pursuant to the Rules, is 6 going to be permitted to object to questions. 7 So I just wa
-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME I OF II Related cas
respect to the deposition, I understand that 4 Mr. Epstein has three attorneys here today but 5 only one o
is any 13 clarification on that issue, please let us 14 know. 15 MR. PIKE: Agreed. 16 MR. EDWARDS: Agreed. 17 MR. GARCIA: Agreed. 18 MS. ARBOUR: Agreed. 19 MR. KUVIN: Katherine, agreed? 20 MS. P7RII • Yes, I am here. 21 MR. KUVIN: Did you hear my stipulation? 22 MS. P7Pli : Yes. 23
ch Police Department in March of 2005, correct? A. Coned. • • Q. And they had overheard some conversation about what .. claimed to have done at Jeffrey Epstein's house, correct? • A. Correct. Q. And that they were not saying, my daughter came to me and said, please call the police, something happened to
that would be your personal summary of the interview 5 that you were conducting with one of the many people 6 that gave you information about Mr. Epstein? A. Correct. 8 Q. And it was always your practice in this case 9 to then destroy the notes that you used as a basis for 10 that typed summary;
13 know if it was exactly lingerie or... 14 Q. Okay. The father had communicated to you that 15 his daughter had told him that her connection to Jeffrey 16 Epstein was that she went to see him as a model? 17 A. Yes. 18 Q. In other words, what you took from talking to 19 the father is that M. h
e many people 6 that gave you information about Mr. Epstein? A. Correct. 8 Q. And it was always your pract
hey thought they were going there for some other purpose were the exception to the rule that was disclosure by whoever invited them, correct? MS. ARBOUR: Object to the fonn. THE WITNESS: Some girls, again, told me that they were going there to give massages, and some girls went there for other reas
16 minor inputs on the interior work. 17 0. What was your understanding back in 2001 still 18 of the relationship between Ghislaine Maxwell and Jeffrey 19 Epstein? 20 MR. PIKE: Form. 21 A. I really didn't understand it. I thought 22 it was personal - personal and business. 23 0. When you say 'personal;
arry Morrison. O. And, Larry, where are you employed right now? A. For JEGE. O. What's JEGE mean? A. It's the aviation flight department for Mr. Epstein, and my primary job is Dankjold Reed Aviation. MR. REINHART: Spell it. A. D-A-N-K-J-O-L-D, and then the second word is Reed, R-E-E-D. Aviation. I
tein? a A. Would have had to probably be around maybe 9 '98, 99. 10 O. How do you become aware that they know one 11 another? 12 A. Because Jeffrey. every one That's when 13 I became a flight engineer on the Boeing. and every 14 once in a while Jeffrey would ride on the Boeing, 15 that's a
ay 140:3 168:20 anyways 45:7 140:11 apartment 103:11 105:13,19 106:11 approached 66:25 83:17 approaching 81:15 approxima... 74:25 75:22 ARBOUR 2:10 architect 106:18 111:7 123:23 126:4 130:3 130:5 134:6 141:2 162:3 179:18 181:6 199:4 asking 13:22 17:2 Toll Free: Facsimile: ESQU
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