Epstein Secrets

A. December 11. Yes, I see that. Q. Palm Beach International Airport to Teterboro? A. Right, yeah. Q. Passengers, Jeffrey Epstein? A. Right, Q. GM, a reference to Ghislaine -- excuse me, Ghislaine Maxwell. A. Uh-huh. Q. And ET and Virginia, right? A. That's what it says, yes, sir. Q. And the

ig rubber things like that (indicating). And I used to go and put my gloves on and pick them up, put them in the sink, rinse it off and put it in Ms. Maxwell -- Ms, Maxwell had in her closet, she had like a laundry basket. And you put laundry in. She have full of those toys.” Is that testimony that exoner

akes, but we have this nest of criminals in Florida, but it -- it seems to be spreading to Epstein's mansion in New York; it seems to be spreading to Ghislaine Maxwell's flat in London, and -- and -- and it goes on. So those are the kinds of things that would have formed the -- the -- the basis, particularly when you

s, I see that. Q. Palm Beach International Airport to Teterboro? A. Right, yeah. Q. Passengers, Jeffrey Epstein? A. Right, Q. GM, a reference to Ghislaine -- excuse me, Ghislaine Maxwell. A. Uh-huh. Q. And ET and Virginia, right? A. That's what it says, yes, sir. Q. And then we see three of the same

there were others that had o2te47 18 done similar sorts of things. ozra40 16 So one of them was a Ghislaine Maxwell. I oz1955 17 will just call her Glenn Maxwell. I think that's kind o2z955 18 of the nickname I understand she goes by. oztese 19 So Glenn Maxwell -- remember, she is -- she 21959 20 is the one,

ncel 022123 4 the deposition and represented that Miss Maxwell was o2z2120 5 outside the United States of Americ

EY, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33402-3626 BY: JACK SCAROLA, ESQ. [email protected] On behalf of Defendant: COLE, SCOTT & KISSANE, P.A. Dadeland Centre H - Suite 1400 9150 South Dadeland Boulevard Miami, Florida 33156 BY: THOMAS EMERSON SCOTT, JR., ESQ. [email protected]

e? 2 A. That would be privileged. 3 SPECIAL MASTER POZZUOLI: Go ahead. make 3 BY MR. EDWARDS: 4 your objection. 4 Q. Your conversation with Ghislaine Maxwell. 5 MR. INDYKE: To the extent that that 5 somebody who you have just told me you did not 6 question requires Alan to disclose privileged 6 repr

he investigation in 10 Roy Black, with two -- 10 2005 was happening. did you speak with Ghalainc 11 Q. I think we're ntiscommunicating. My 11 Maxwell?" 12 question is were you one of the attorneys that 12 MR. INDYKE: That's the question? Sorry. 13 represented Jeffrey Epstein? 13 I didn't he

ith ( autlaine Maxwell? 24 attomey-client privilege in a communication 25 MR_ SCOTT: Don't reveal any privileged 25 between Alan Dershowitz and Ghalainc Maxwell. 29 (Pages 443 to 446) www.phi sre orting.com EFTA00615832 447 449 1 THE WITNESS: Yes. there can. Would you 1 that Alan knows about only be

) goes (3) Great (1) 381:21,24 hold (1) 444:24 446:10 363:11 371:8 371:12 Harvard (1) 419:23 446:25 451:17 grounds (2) 360:19 home (2) Ghislaine (11) going (54) 363:19 450:20 Hawking (11) 348:6 360:24 421:3 422:6,23 340:5,8,9,14,25 group (1) 366:15,22 367:2 Honor (1) 427:10 444:21 34

4 - 461) 5 6 6 7 ALAN M. DERSHOWITZ 7 8 Direct (continued) By Mr. Edwards 341 a On behalf of Defendam: 9 Certificate of Oath 459 9 COLE. SCOTT & KISSANE. P.A. Certificate of Reporter 460 10 Read and Sign Letter to Witness 461 10 Errata Sheet (forwarded upon execution) 462 11 BY: THOMAS EMERS

inister pattern — it is also worth noting that each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded opportunities to explain themselves — and all four have declined to take them. Eps

After extensive discussion and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality agreement prepared by Maxwell's attorney, at the eleventh hour Maxwell's attorney informed the undersigned that Maxwell's mother was very ill and that consequently Maxwell was le

entified by name in her motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have

E-mail: [email protected] E-mail: ann.marie.c.villafana@usdojdzov Attorneys for the Government Thomas Scott [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre H 9150 South Dadeland Boulevard, Suite 1400 Miami, Florida 33156 Telephone: (305) 350-5300 Facsimile: (305) 373-2294 -and

dwards and Cassell identified by name in the Joinder Motion as having had sexual relations with were Prince Andrew, Duke of York ("Prince Andrew"); Ghislaine Maxwell ("Maxwell"); and Jean Luc Brunel ("Brunel") — all of whom had previously been identified by name by in media interviews. The Joinder Motion's alle

entified by name in the Joinder Motion as having had sexual relations with were Prince Andrew, Duke of York ("Prince Andrew"); Ghislaine Maxwell ("Maxwell"); and Jean Luc Brunel ("Brunel") — all of whom had previously been identified by name by in media interviews. The Joinder Motion's allegations abo

re Prince Andrew, Duke of York ("Prince Andrew"); Ghislaine Maxwell ("Maxwell"); and Jean Luc Brunel ("Brune

etion for the Court to deny Dershowitz's request. 15 EFTA00613405 Respectfully submitted, s/ Thomas E. Scott Steven R. Safra, FBN 057028 COLE, SCOTT & KISSANE, P.A. Richard A. Simpson (pro hac vice) Ma E. Bo 'a ro hac vice) Ashle E. Filer ro hac vice) Nicole Audet Richardson (pro hac vice) Counsel for

w enforcement. EFTA00188663 Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 3 of 28 7. 1 also knew what Epstein and Maxwell had been doing the years that I was with them. In addition to constantly finding underage girls to satisfy their personal sexual desires, Epstein an

ork). Jane Doe #3 was forced to have sexual relations with this Prince when she was a minor in three separate geographical locations: in London (at Ghislaine Maxwell's apartment), in New York, and on Epstein's private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged girls). Epstein inst

that I had been sexually abused by Prince Andrew, Ghislaine Maxwell, Jean Luc Brunel, Alan Dershowitz, and o

500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: 561 820-8777 Attorneys for the Government Thomas Scott ar COLE. SCOTT & KISSANE, P.A. -and- Kendall Coffey Gabriel Groisman Benjamin H. Brodsk n om COFFEY BURLINGTON. P.L. Attorneys for Alan Dershowit: /s/ Bradley J. Edward

inister pattern — it is also worth noting that each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey Epstein. Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded opportunities to explain themselves — and all four have declined to take them. Eps

ked questions about his sexual abuse of young girls. including Jane Doe No. I. Jane Doe No. 2, and Jane Doe No. 3. See generally Exhibit 16 at 1-7. Maxwell. In 2009, undersigned counsel (Brad Edwards) served Ghislaine Maxwell with a subpoena for a deposition in a civil case against Jeffrey Epstein. Afte

entified by name in her motion (Jeffrey Epstein. Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have

Case 9:08-cv-80736-KAM Document 282 Entered on FLSD Docket 01/05/2015 Page 8 of 10 Respectfully submitted, Thomas Scott Fla. Bar No. 149100 COLE, SCOTT & KISSANE, P.A. -and- /s/ Kendall Coffey Kendall Coffey, Fla. Bar No. 259681 Benjamin H. Brodsky, Fla. Bar No. 73748 Counsel for Prof Alan Al. Dershowiiz

said she met me at the ranch. So I cannot believe 20 anything she says about the ranch. 21 BY MR. EDWARDS: 22 Q. Was she lying when she says Ghislaine 23 Maxwell and Jeffrey Epstein used sex toys on her 24 when she was underage? 25 MR. INDYKE: Same objection, same www.phi sre orting.com EFTA

me at the ranch. So I cannot believe 20 anything she says about the ranch. 21 BY MR. EDWARDS: 22 Q. Was she lying when she says Ghislaine 23 Maxwell and Jeffrey Epstein used sex toys on her 24 when she was underage? 25 MR. INDYKE: Same objection, same www.phi sre orting.com EFTA00615629 50

that, right? 6 MR. INDYKE: Same objection, same 7 instruction. 8 BY MR. EDWARDS: 9 Q. Is that privileged, the answer to that 10 question, Ghislaine Maxwell's relationship with 11 Prince Andrew? Let me ask it this ■ -- 12 MR. INDYKE: To the extent that 13 Mr. Dershowitz obtained that information in 1

1 APPEARANCES: 2 On behalf of Plaintiffs: 3 4 5 SEARCY, DENNEY, SCAROLA BARNHART & SHIPLEY, P.A. 6 7 8 On behalf of Defendant: 9 COLE, SCOTT & KISSANE, P.A. Dadeland Centre II - Suite 1400 10 I II. P IRIR 11 12 : , . (Via phone) il 13 --an -- 14 SWEDER & ROSS, LLP 15 BY: KENNETH A. SWED

own internal work product. my own 24 that you maintain with Jeffrey Epstein. Chislaine 24 internal dynamic. my own thinking process. I didnt 25 Maxwell or anyone else a part of that agreement. 25 think it was necessary for me to call you and ask 718 720 1 MR. SIMPSON: Object to the form as 1

leman's (2) 709:8 714:21 genuinely (1) 753:16 Gertner (6) 765:10 766:3,5 766:11,18,24 getting (6) 680:10 681:5 693:25 721:13 754:14 761:13 Ghislaine (1) 717:24 give (26) 653:8 668:5,8 669:5,7 680:19 682:19 697:19 701:8 707:10 707:12 716:1 721:23 724:17 725:22 731:5 731:11,21 734:15 741:

1) BY: JACK SCAROLA. ESQ. 6 7 6 jsx esearcyhw.com 7 Certificate of Oath 778 a On behalf of Defendant: Certificate of Reporter 779 9 COLE. SCOTT & KISSANE. P.A. 8 Read and Sign Letter to Witness 780 10 Dadeland Centre II - Suite 1400 9150 South Dadeland Boulevard Miami. Herida 33156 9 Errata She

:10,13 506:6 Hawking (1) 579:19 588:7 602:17 615:16 546:3,6 547:2 guard (1) 574:1 594:12 630:10 616:15 637:1 556:3 559:25 607:8 head (2) Ghislaine (35) 640:2,17 641:7 560:1,17 561:3 guess (4) 489:8 597:25 508:22 509:4 given (7) 562:7 563:7 467:15 499:1 headed (1) 510:11 519:21 537:10 5

, who is a young 4 woman. I saw Giselle [sic] Maxwell, who is a young 5 woman. I saw women in their l

the action. Dated this 14th day of January, 2016. KIMBERLY FONTALVO, RPR, CLR www.phi sre orting.com EFTA00615766 646 January 14, 2016 COLE, SCOTT & KISSANE, P.A. 10111111111111 BY: THOMAS EMERSON SCOTT, JR., ESQ. Re: Bradley Edwards, et al., v. Alan M. Dershowitz Please take notice that on the 12th d