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she was coming to give t 20 massage? 21 A. No. I assumed she was a massage therapy 22 because I was -- I drove Ms. Maxwell to Mar-a-lago. 23 Donald Trump's residence. And I wait in the car while 24 Ms. Maxwell got a -- I think it was a facial or massage. 25 I don't know. But that day I remember this
16 17 18 19 20 21 22 23 24 25 Page 71 Diane's secretary, she stay there for a week with her kids and we took care of her. Who else? Mr. Trump. That's a celebrity. Mr. Robert Kennedy, Junior. Mr. Frederick Fekkai. Q. Who is that? A. Fekkai, Frederick Fckkai, the famous hairstylist. Who e
I was -- I drove Ms. Maxwell to Mar-a-lago. 23 Donald Trump's residence. And I wait in the car while 2
ith her kids and we took care of her. Who else? Mr. Trump. That's a celebrity. Mr. Robert Kennedy, Junior.
-- I drove Ms. Maxwell to Mar-a-lago. 23 Donald Trump's residence. And I wait in the car while 24 Ms. M
44 22 one: 22 23 (Via tekpbone) 23 24 24 25 25 Page 6 Page 8 I Appearances contimied... 1 PROCEEDINGS 2 On behalf of the Plaintiff. Jane Doe II: 3 ISIDRO MANUEL GARCIA, ESQUIRE 2 — — — GARCIA EI.K1NS & BOEHRINGER 3 THE VIDEOGRAPHER: We are now on video 4 I record. This is Media No.
tion. The undisputed facts show the following with regard to each of the persons raised in Epstein's complaint: • Complaint ¶38(i): With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts. • Complaint
ach of the persons raised in Epstein's complaint: • Complaint ¶38(i): With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts. • Complaint ¶38(ii): With regard to Alan Dershowitz (Harvard Law Pro
s complaint: • Complaint ¶38(i): With regard to Donald Trump, Edwards had sound legal basis for believi
ump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See St
, 08-80802), . (Case No.08-80811), Jane Does Nos. 101, 102 and 103 (Case Nos. 09-80591, 09-80656, 10-80309), another Jane Doe (Case No. 08-80804), Jane Doe II (Case No. 09-80469), as well as other non-filed claims. Furthermore, Defendant has also resolved three state court claims. The only cases not resolv
ulated to lead to the discovery of the admissible evidence; protected by privacy rights 11326-11331 08/03/2009 Jacquie Johnson Bradley Edwards Donald Trump depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr
ulated to lead to the discovery of the admissible evidence; protected by privacy rights 11366.11371 08/11/2009 Jacquie Johnson Bradley Edwards Trump depo info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence
31 08/03/2009 Jacquie Johnson Bradley Edwards Donald Trump depo Work product; attorney/client priv
ted to lead to the discovery of admissible evidence; protected by privacy rights 02411-02413 05/12/2009 Attorneys at RRA Bradley J. Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidenc
ulated to lead to the discovery of the admissible evidence; protected by privacy rights 11326-11331 08/03/2009 Jacquie Johnson Bradley Edwards Donald Trump depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr
ulated to lead to the discovery of the admissible evidence; protected by privacy rights 11366.11371 08/11/2009 Jacquie Johnson Bradley Edwards Trump depo info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence
31 08/03/2009 Jacquie Johnson Bradley Edwards Donald Trump depo Work product; attorney/client priv
ted to lead to the discovery of admissible evidence; protected by privacy rights 02411-02413 05/12/2009 Attorneys at RRA Bradley J. Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidenc
6007 08/05/2009 Bert Patton Jacquie Johnson RE:Epstein Depo-New York Joint W/P Priv. 16057-16065 08/06/2009 Mercedes Estrada Jacquie Johnson Trump and Maxwell Dep dates Joint W/P Priv. 15918-15949 08/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo's 08/14,17,18 in NY & OH Joint W/P
19 08/11/2009 Denis Kleinfeld Bradley Edwards Trump's Depo Work Product;attorney client privilege;i
/02/2009 Bradley Edwards Katherine Ezell RE:Meeting w/Stanley Arkin Joint W/P Priv. 06861-06863 05/12/2009 Bradley Edwards Katherine Ezell RE:Jane Doe II v. Epstein Joint W/P Priv. 06876.06879 05/12/2009 Bradley Edwards Stuart Mermelstein RE:Jane Doe II v. Epstein Joint W/P Priv. 06891-06897 05/
6007 08/05/2009 Bert Patton Jacquie Johnson RE:Epstein Depo-New York Joint W/P Priv. 16057-16065 08/06/2009 Mercedes Estrada Jacquie Johnson Trump and Maxwell Dep dates Joint W/P Priv. 15918-15949 08/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo's 08/14,17,18 in NY & OH Joint W/P
19 08/11/2009 Denis Kleinfeld Bradley Edwards Trump's Depo Work Productattorney client privilege;ir
/02/2009 Bradley Edwards Katherine Ezell RE:Meeting w/Stanley Arkin Joint W/P Priv. 06861-06863 05/12/2009 Bradley Edwards Katherine Ezell RE:Jane Doe II v. Epstein Joint W/P Priv. 06876-06879 05/12/2009 Bradley Edwards Stuart Mermelstein RE:Jane Doe II v. Epstein Joint W/P Priv. 06891-06897 05/
irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11366-11371 08/11/2009 Trump depo info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence
not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 02411-02413 05/12/2009 Attorneys at I Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidenc
Entities connected to both Donald Trump and Jane Doe II

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Barack Obama
PERSON
Stephen Hawking
PERSONMartin Weinberg
PERSON
Prince Charles
PERSON
Bloomberg L.P.
ORGANIZATION
New York
LOCATION
Vladimir Putin
PERSON