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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
answer questions. Dershowitz set up, then cancelled, Epstein interviews with the police "several times." See B.B. Epstein, No. 502008CA037319XXXX MB AB, Depo. of Police Chief Michael Reiter at 80 (Palm Beac Cty. Cir. Ct. Nov. 23, 2009). 15 EFTA00191417 Brunel. In 2009, undersigned counsel (Brad
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
g to answer uestions. Dershowitz set up. then cancelled, Epstein interviews with the police "several times." See. Epstein, No. 502008CA037319XXXX MB AB. Depo. of Police Chief Michael Reiter at 80 (Palm Beach Cty. Cir. Ct. Nov. 23. 2009). 15 EFTA00188762 Case 9:08-cv-80736-KAM b1/4,curnent 291 En
11 floor of the house. 12 Q. Did you ever see Ms. Maxwell taking 13 pictures of the girls? 14 A. No, ma'
w her doing that where were 9 they, the girls? 10 A. The dining room, the library, the first 11 floor of the house. 12 Q. Did you ever see Ms. Maxwell taking 13 pictures of the girls? 14 A. No, ma'am. 15 Q. Did you ever see Mr. Epstein taking 16 pictures of the girls? 17 A. No, ma'am. 18 Q
11 JEFFREY EPSTEIN, 1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR 2 PALM BEACH COUNTY, FLORIDA 3 CASE NO. 502008CA0373199000<MB AB 4 B.B., 5 Plaintiff, 6 Vs. 7 JEFFREY EPSTEIN. B Defendant. 9 10 11 12 1031 Ives Dairy Road 13 14 :5 16 CONTINUED 17 VIDEOTAPE
NAME: DATE AND TIME: LOCATION: Ghislane Noelle Maxwell August 17, 2009 Esquire Court Reporters 11:00
DEPOSITION OF: NAME: DATE AND TIME: LOCATION: Ghislane Noelle Maxwell August 17, 2009 Esquire Court Re
IN THE CIRCUIT COURT OF THE le i JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BB, Case No: 502008CA 37319XXXX MB AB Plaintiff, Florida Bar No: 089737 vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE THAT T
— ■ Page 151 i i 1 with Mr. Indyke? 2 A No. 3 Q There appear to be a number of 4 corporations. El Zorro Ranch Corporation, New York 5 Strategy Group, Ghislaine, G-HT-S-L-ArEN-E, 6 Corporation, J. Epstein and Company and the 7 Financial Strategy Group. Do you see those? 8 A Ido. 9 Q‘ Do you recall anything, s
t/ Unit, Offense* Cwnts' Domestic.'- Valence-' □Y GM ^ugType^^^T-nSrb^^ ‘Ni wA/. . 'C?Cocaine- ' ■AMmo
OT A CERTIFIED COPY VS. • Page 1 TN T}IE Fl HEE NTH JUDiCiAL cf RCQiT co-Urn IN AND FOR PALMBEACH COUNTY, FLORIDA CASE NO.: 502008CA03 7319 XXXX MB AB Plaintif~ JEFFREY EPSTEIN, Defendant. ----------------'/ V.OLUfyl.E I i 2 ·3 n 15 VIDEO-TAPED DEPOSITIONOF'MlCHAELREITER 16 1 2 3 4
dent of Florida. 13440 This tax was received by GM FAXMakes fax server. For more information, visit
ew York, New York. 4. 1 have not resided in Florida at any time during the pendency ()Heine Doe v. Jeffrey Epstein, Case No. 50 2008 CA 00656 XXXX MB AB, including upon the removal of that case to federal court. PURSUANT TO 28 U.S.C. § 1746, I STATE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE UN
Entities connected to both Ghislaine Maxwell and MB AB

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
FedEx
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSONJane Doe
PERSON
Joe Biden
PERSON
Vicky Ward
PERSON
New York City
LOCATION