Case 18-2868, Document 271, 08/09/2019, 2628203, Page1 of 1 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT _____________________________________________ At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 9th day of August, two thousand nineteen. ________________________________________ Julie Brown, Miami Herald Media Company, Intervenors - Appellants. v. ORDER Ghislaine Maxwell, Docket No: 18-2868 Defendant - Appellee, v. Virginia L. Giuffre, Plaintiff - Appellee. _______________________________________ Appellee, Ghislaine Maxwell, filed a petition for panel rehearing, or, in the alternative, for rehearing en banc. The panel that determined the appeal has considered the request for panel rehearing, and the active members of the Court have considered the request for rehearing en banc. IT IS HEREBY ORDERED that the petition is denied. FOR THE COURT: Catherine O'Hagan Wolfe, Clerk Selected docket entries for case 18−2868 Generated: 08/09/2019 10:13:24 Filed Document Description 08/09/2019 272 Order FILED 08/09/2019 273 273 Judgment Mandate ISSUED 273 Supporting Document 273 Supporting Document 08/09/2019 275 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED 08/09/2019 276 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED 08/09/2019 277 UNSEALED SUMMARY JUDGMENT RECORD, DOCKETED Page Docket Text 2 ORDER, dated 08/09/2019, directing the Clerk to issue the mandate forthwith, by JAC, RSP, CFD, FILED.[2628208] [18−2868] JUDGMENT MANDATE, ISSUED.[2628218] [18−2868] 4 5 30 31 UNSEALED SUMMARY JUDGMENT RECORD, appendix 1 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628223] [18−2868] 49 UNSEALED SUMMARY JUDGMENT RECORD, appendix 2 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628224] [18−2868] 126 UNSEALED SUMMARY JUDGMENT RECORD, appendix 3 of 13 , pursuant to the Court's decision dated July 3, 2019, DOCKETED. [2628225] [18−2868] Case 18-2868, Document 272, 08/09/2019, 2628208, Page1 of 2 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT At a Stated Term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 9th day of August, two thousand nineteen. Before: José A. Cabranes, Rosemary S. Pooler, Christopher F. Droney, Circuit Judges. ________________________________ Julie Brown, Miami Herald Media Company, ORDER Intervenors - Appellants, v. 18-2868 Ghislaine Maxwell, Defendant - Appellee, v. Virginia L. Giuffre, Plaintiff - Appellee. ________________________________ Alan M. Dershowitz, Michael Cernovich, DBA Cernovich Media, Intervenors - Appellants, v. Virginia L. Giuffre, Plaintiff - Appellee, v. Ghislaine Maxwell, Defendant-Appellee. ________________________________ 16-3945(L) 17-1625(Con) 17-1722(Con) Case 18-2868, Document 272, 08/09/2019, 2628208, Page2 of 2 IT IS HEREBY ORDERED that the Clerk is directed to issue the mandate forthwith. For the Court: Catherine O’Hagan Wolfe, Clerk of Court Case 18-2868, Document 273-1, 08/09/2019, 2628218, Page1 of 1 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT MANDATE At a Stated Term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 3rd day of July, two thousand and nineteen. Before: José A. Cabranes, Rosemary S. Pooler, Christopher F. Droney, Circuit Judges. ________________________________ Julie Brown, Miami Herald Media Company, Intervenors - Appellants. JUDGMENT Docket Nos. 18-2868 v. Ghislaine Maxwell, Defendant - Appellee, v. Virginia L. Giuffre, Plaintiff - Appellee. ________________________________ The appeal in the above captioned case from a judgment of the United States District Court for the Southern District of New York was argued on the district court’s record and the parties’ briefs. Upon consideration thereof, IT IS HEREBY ORDERED, ADJUDGED and DECREED that the orders of the District Court entered on November 2, 2016, May 3, 2017, and August 27, 2018 are VACATED. The Court further ORDERS the unsealing of the summary judgment record as described in its opinion. The case is REMANDED to the District Court for a particularized review of the remaining materials. For the Court: Catherine O’Hagan Wolfe, Clerk of Court MANDATE ISSUED ON 08/09/2019 Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page1 of 25 18‐2868; 16‐3945‐cv(L)  Brown v. Maxwell; Dershowitz v. Giuffre   In the United States Court of Appeals for the Second Circuit         AUGUST TERM 2018    No. 18‐2868‐cv    JULIE BROWN, MIAMI HERALD COMPANY,  Intervenors‐Appellants,    v.    GHISLAINE MAXWELL,  Defendant‐Appellee,    v.    VIRGINIA L. GIUFFRE,  Plaintiff‐Appellee.            No. 16‐3945‐cv(L)  No. 17‐1625 (CON)  No. 17‐1722(CON)    ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH  MEDIA,  Intervenors‐Appellants,  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page2 of 25   V.     VIRGINIA L. GIUFFRE,  Plaintiff‐Appellee,    v.    GHISLAINE MAXWELL,  Defendant‐Appellee.*        On Appeal from the United States District Court  for the Southern District of New York          ARGUED: MARCH 6, 2019  DECIDED: JULY 3, 2019          Before: CABRANES, POOLER, and DRONEY, Circuit Judges.        Intervenors‐Appellants  Alan  Dershowitz,  Michael  Cernovich,  and the Miami Herald Company (with reporter Julie Brown) appeal  from certain orders of the United States District Court for the Southern  District of New York (Robert W. Sweet, Judge) denying their respective  motions to unseal filings in a defamation suit. We conclude that the   The Clerk of Court is directed to amend the captions as set out above.  * 2  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page3 of 25 District  Court  failed  to  conduct  the  requisite  particularized  review  when ordering the sealing of the materials at issue. At the same time,  we recognize the potential damage to privacy and reputation that may  accompany public disclosure of hard‐fought, sensitive litigation. We  therefore  clarify  the  legal  tools  that  district  courts  should  use  in  safeguarding the integrity of their dockets. Accordingly, we VACATE  the District Court’s orders entered on November 2, 2016, May 3, 2017,  and August 27, 2018, ORDER the unsealing of the summary judgment  record  as  described  further  herein,  and  REMAND  the  cause  to  the  District  Court  for  particularized  review  of  the  remaining  sealed  materials.   Judge Pooler concurs in this opinion except insofar as it orders  the immediate unsealing of the summary judgment record without a  remand.        SANFORD L. BOHRER (Christine N. Walz,  Madelaine J. Harrington, New York, NY, on  the brief), Holland & Knight LLP, Miami, FL,  for Intervenors‐Appellants Julie Brown and  Miami Herald.  TY GEE (Adam Mueller, on the brief),  Haddon, Morgan and Foreman, P.C.,  Denver, CO, for Defendant‐Appellee Ghislaine  Maxwell.    3  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page4 of 25             PAUL G. CASSELL (Sigrid S. McCawley, Boies  Schiller Flexner LLP, Ft. Lauderdale, FL, on  the brief), S.J Quinney College of Law,  University of Utah, Salt Lake City, UT, for  Plaintiff‐Appellee Virginia L. Giuffre.  ANDREW G. CELLI JR. (David A. Lebowitz, on  the brief), Emery, Celli, Brinckerhoff &  Abady LLP, New York, NY, for Intervenor‐ Appellant Alan M. Dershowitz.  MARC RANDAZZA (Jay Marshall Wolman,  Las Vegas, NV, on the brief), Randazza Legal  Group, PLLC, Hartford, CT, for Intervenor‐ Appellant Michael Cernovich.        JOSÉ A. CABRANES, Circuit Judge:  Intervenors‐Appellants  Alan  M.  Dershowitz  (“Dershowitz”),  Michael  Cernovich  (“Cernovich”),  and  the  Miami  Herald  Company  (with reporter Julie Brown, jointly the “Herald”) appeal from certain  orders of the United States District Court for the Southern District of  New York (Robert W. Sweet, Judge) denying their respective motions  to  unseal  filings  in  a  defamation  suit.  We  conclude  that  the  District  Court  failed  to  conduct  the  requisite  particularized  review  when  ordering  the  sealing  of  the  materials  at  issue.  At  the  same  time,  we  4  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page5 of 25 recognize  the  potential  damage  to  privacy  and  reputation  that  may  accompany public disclosure of hard‐fought, sensitive litigation. We  therefore  clarify  the  legal  tools  that  district  courts  should  use  in  safeguarding the integrity of their dockets. Accordingly, we VACATE  the District Court’s orders entered on November 2, 2016, May 3, 2017,  and August 27, 2018, ORDER the unsealing of the summary judgment  record  as  described  further  herein,  and  REMAND  the  cause  to  the  District  Court  for  particularized  review  of  the  remaining  sealed  materials.  I. BACKGROUND  A. Jeffrey Epstein’s Conviction and the CVRA Suit  The origins of this case lie in a decade‐old criminal proceeding  against financier Jeffrey Epstein (“Epstein”). On June 30, 2008, Epstein  pleaded guilty to Florida state charges of soliciting, and procuring a  person  under  the  age  of  eighteen  for,  prostitution.  The  charges  stemmed from sexual activity with privately hired “masseuses,” some  of whom were under eighteen, Florida’s age of consent. Pursuant to  an agreement with state and federal prosecutors, Epstein pleaded to  the  state  charges.  He  received  limited  jail‐time,  registered  as  a  sex  offender,  and  agreed  to  pay  compensation  to  his  victims.  In  return,  prosecutors declined to bring federal charges.   Shortly  after  Epstein  entered  his  plea,  two  of  his  victims,  proceeding  as  “Jane  Doe  1”  and  “Jane  Doe  2,”  filed  suit  against  the  Government  in  the  Southern  District  of  Florida  under  the  Crime  Victims’ Rights Act (“CVRA”). The victims sought to nullify the plea  5  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page6 of 25 agreement,  alleging  that  the  Government  failed  to  fulfill  its  legal  obligations to inform and consult with them in the process leading up  to Epstein’s plea deal.1   On December 30, 2014, two additional unnamed victims—one  of whom has now self‐identified as Plaintiff‐Appellee Virginia Giuffre  (“Giuffre”)—petitioned  to  join  in  the  CVRA  case.  These  petitioners  included  in  their  filings  not  only  descriptions  of  sexual  abuse  by  Epstein,  but  also  new  allegations  of  sexual  abuse  by  several  other  prominent  individuals,  “including  numerous  prominent  American  politicians,  powerful  business  executives,  foreign  presidents,  a  well‐ known  Prime  Minister,  and  other  world  leaders,”  as  well  as  Dershowitz (a long‐time member of the Harvard Law School faculty  who had worked on Epstein’s legal defense) and Defendant‐Appellee  Ghislaine Maxwell (“Maxwell”).2    Dershowitz  moved  to  intervene,  seeking  to  “strike  the  outrageous  and  impertinent  allegations  made  against  him  and  to  request a show cause order to the attorneys that have made them.”3  Exercising  its  authority  to  “strike  from  a  pleading  an  insufficient    On  February  21,  2019,  the  Florida  District  Court  ruled  that  federal  prosecutors had violated the CVRA by failing to adequately notify the two victims‐ plaintiffs of the plea deal. The District Court has not yet determined the appropriate  remedy. See Doe 1 v. United States, 359 F. Supp. 3d 1201, 1204–17 (S.D. Fla. 2019).  1  Doe 1 v. United States, No. 08‐CV‐80736‐KAM, 2015 WL 11254692, at *2 (S.D.  Fla. Apr. 7, 2015) (internal quotation marks omitted).  2  Id. (internal quotation marks and brackets omitted).  3 6  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page7 of 25 defense  or  any  redundant,  immaterial,  impertinent,  or  scandalous  matter . . . on its own,”4 the Florida District Court (Kenneth A. Marra,  Judge) sua sponte struck all  allegations against additional parties from  the  pleadings,  including  those  against  Dershowitz,  and  therefore  denied Dershowitz’s motion as moot.5   The stricken allegations, however, quickly found their way into  the  press,  and  several  media  outlets  published  articles  repeating  Giuffre’s  accusations.  In  response  to  the  allegations,  on  January  3,  2015,  Maxwell’s  publicist  issued  a  press  statement  declaring  that  Giuffre’s allegations “against Ghislaine Maxwell are untrue” and that  her “claims are obvious lies.”6   B. Giuffre Sues Maxwell  On  September  21,  2015,  Giuffre  filed  the  underlying  action  against Maxwell in the Southern District of New York. Giuffre alleged  that  Maxwell  had  defamed  her  through  this  and  other  public  statements. Extensive and hard‐fought discovery followed. Due to the  volume of sealing requests filed during discovery, on August 9, 2016,  the  District  Court  entered  a  Sealing  Order  that  effectively  ceded  control  of  the  sealing  process  to  the  parties  themselves.  The  Sealing  Order disposed of the requirement that the parties file individual letter  briefs to request sealing and prospectively granted all of the parties’   Fed. R. Civ. P. 12(f).  4  Doe 1, 2015 WL 11254692, at *2–3.  5  See Giuffre v. Maxwell, 325 F. Supp. 3d 428, 434 (S.D.N.Y. 2018).  6 7  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page8 of 25 future  sealing  requests.  In  total,  167  documents—nearly  one‐fifth  of  the  docket—were  filed  under  seal.  These  sealed  documents  include,  inter  alia,  motions  to  compel  discovery,  motions  for  sanctions  and  adverse inferences, motions in limine, and similar material.   On  January  6,  2017,  Maxwell  filed  a  motion  for  summary  judgment.  The  parties  submitted  their  memoranda  of  law  and  supporting exhibits contesting this motion under seal. On March 22,  2017,  the  District  Court  denied  the  motion  in  a  heavily  redacted  76‐ page  opinion.  Once  again,  the  entire  summary  judgment  record,  including  the  unredacted  version  of  the  District  Court  opinion  denying summary judgment, remained under seal. On May 24, 2017,  Maxwell and  Giuffre  executed  a  settlement  agreement, and  the  case  was closed the next day.  C. Motions to Intervene and Unseal  Over  the  course  of  the  litigation  before  Judge  Sweet,  three  outside parties attempted to unseal some or all of the sealed material.  On August 11, 2016, Dershowitz moved to intervene, seeking to unseal  three  documents  that,  he  argues,  demonstrate  that  Giuffre  invented  the  accusations  against  him.  On  January  19,  2017,  Cernovich,  an  independent  blogger  and  self‐described  “popular  political  journalist,”7  moved  to  intervene,  seeking  to  unseal  the  summary  judgment record, and Dershowitz joined his motion. On April 6, 2018,  after the case had settled, the Herald moved to intervene and unseal   Br. Appellant (Cernovich) 4.  7 8  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page9 of 25 the entire docket. The District Court granted each of these motions to  intervene, but denied the related requests to unseal in orders entered  November 2, 2016, May 3, 2017, and August 27, 2018, respectively.   The  Appellants  timely  appealed  from  each  of  the  orders  denying their respective motions to unseal. Although each Appellant  seeks  the  release  of  a  different  set  of  documents,  all  argue  that  the  District  Court  failed  to  analyze  the  documents  individually  or  properly apply the presumption of public access to court documents.  We therefore ordered that the appeals be heard in tandem and held  argument on March 6, 2019.   On March 11, 2019, we issued an order to show cause why we  “should  not  unseal  the  summary  judgment  motion,  including  any  materials filed in connection with this motion, and the District Court’s  summary  judgment  decision.”8  The  parties  timely  filed  their  responses.  II. DISCUSSION  There  are  two  categories  of  sealed  material  at  issue  in  these  appeals: (1) the summary judgment record, which includes the parties’  summary judgment briefs, their statements of undisputed facts, and  incorporated exhibits; and (2) court filings made in the course of the  discovery  process  and  with  respect  to  motions  in  limine.  In  this  Opinion,  we  explain  that  our  law  requires  the  unsealing  of  the   Giuffre v. Maxwell, No. 18‐2868‐cv, Docket No. 138.  8 9  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page10 of 25 summary  judgment  materials  and  individualized  review  of  the  remaining sealed materials.   While  the  law  governing  public  access  to  these  materials  is  largely  settled,  we  have  not  yet  adequately  addressed  the  potential  harms that often accompany such access. These harms are apparent.  Over  forty  years  ago,  the  Supreme  Court  observed  that,  without  vigilance,  courts’  files  might  “become  a  vehicle  for  improper  purposes.”9    Our  legal  process  is  already  susceptible  to  abuse.  Unscrupulous  litigants  can  weaponize  the  discovery  process  to  humiliate and embarrass their adversaries. Shielded by the “litigation  privilege,”10  bad  actors  can  defame  opponents  in  court  pleadings  or  depositions  without  fear  of  lawsuit  and  liability.  Unfortunately,  the  presumption of public access to court documents has the potential to  exacerbate  these  harms  to  privacy  and  reputation  by  ensuring  that  damaging material irrevocably enters the public record.  We therefore take the opportunity to describe the tools available  to district courts in protecting the integrity of the judicial process, and  emphasize the courts’ responsibility to exercise these powerful tools.  We also caution the public to critically assess allegations contained in  judicial pleadings.   Nixon v. Warner Commcʹns, Inc., 435 U.S. 589, 598 (1978).  9  See notes 46–47 and accompanying text, post.    10 10  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page11 of 25 A. Standard of Review  When  reviewing  a  district  court’s  decision  to  seal  a  filing  or  maintain such a seal, “we examine the court’s factual findings for clear  error, its legal determinations de novo, and its ultimate decision to seal  or unseal for abuse of discretion.”11   B. The Summary Judgment Materials  With respect to the first category of materials, it is well‐settled  that  “documents  submitted  to  a  court  for  its  consideration  in  a  summary  judgment  motion  are—as  a  matter  of  law—judicial  documents  to  which  a  strong  presumption  of  access  attaches,  under  both  the  common  law  and  the  First  Amendment.”12  In  light  of  this  strong  First  Amendment  presumption,  “continued  sealing  of  the  documents may be justified only with specific, on‐the‐record findings  that  sealing  is  necessary  to  preserve  higher  values  and  only  if  the  sealing order is narrowly tailored to achieve that aim.”13   Bernstein v. Bernstein Litowitz Berger & Grossmann LLP, 814 F.3d 132, 139  (2d Cir. 2016).  11  Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We  observe that our holding in Lugosch relies on the general principle that parties may  “be assumed to have supported their papers  with admissible evidence and non‐ frivolous arguments.” Id. at 122. Insofar as a district court has, through striking a  filing,  specifically  found  that  assumption  inapplicable,  the  categorical  rule  in  Lugosch may not apply. See notes 42–43 and accompanying text, post.  12   Id.  at  124.  Examples  of  such  countervailing  values  may  include,  depending  on  the  circumstances,  preserving  “the  right  of  an  accused  to  fundamental fairness in the jury selection process,” Press‐Enter. Co. v. Superior Court  13 11  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page12 of 25 In this case, the District Court erred in several respects.14 First, it  failed to give proper weight to the presumption of access that attaches  to  documents  filed  in  connection  with  summary  judgment  motions.  The  District  Court  reasoned  that  the  summary  judgment  materials  were “entitled to a lesser presumption of access” because “summary  judgment  was  denied  by  the  Court.”15  In  assigning  a  “lesser  presumption” to such materials, the District Court relied on a single  sentence  of  dicta  from  our  decision  in  United  States  v.  Amodeo.16  We  have  since  clarified,  however,  that  this  sentence  was  based  on  a  “quotation from a partial concurrence and partial dissent in the D.C.  Circuit . . . [and] is thus not the considered decision of either this court  or  the  D.C.  Circuit.”17  In  fact,  we  have  expressly  rejected  the  proposition that “different types of documents might receive different  of California, Riverside Cty., 464 U.S. 501, 510 (1984); the protection of attorney‐client  privilege,  Lugosch,  435 F.3d  at 125; “the  danger  of  impairing  law  enforcement  or  judicial efficiency,” SEC. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001); and “the  privacy interest of those who resist disclosure,” id.   Our discussion here focuses specifically on the District Court’s denial of  the Herald’s motion to unseal the entire record. Because this decision grants relief  to all Appellants, we need not discuss any separate, additional error in the District  Court’s denial of the earlier motions to unseal.  14  Giuffre, 325 F. Supp. 3d at 444.   15  71 F.3d 1044, 1049 (2d Cir. 1995) (“Amodeo II”) (“One judge [in the District  of  Columbia  Circuit]  has  pointed  out,  for  example,  that  where  a  district  court  denied the summary judgment motion, essentially postponing a final determination  of substantive legal rights, the public interest in access is not as pressing.” (internal  quotation marks omitted; emphasis in original)).  16  Lugosch, 435 F.3d at 121.  17 12  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page13 of 25 weights of presumption based on the extent to which they were relied  upon in resolving [a] motion [for summary judgment].”18  Second,  in  contravention  of  our  precedent,  the  District  Court  failed to review the documents individually and produce “specific, on‐ the‐record  findings  that  sealing  is  necessary  to  preserve  higher  values.”19  Instead,  the  District  Court  made  generalized  statements  about the record as a whole.20 This too was legal error.  Finally,  upon  reviewing  the  summary  judgment  materials  in  connection  with  this  appeal,  we  find  that  there  is  no  countervailing  privacy interest sufficient to justify their continued sealing. Remand  with respect to these documents is thus unnecessary. Accordingly, and  to  avoid  any  further  delay,21  we  order  that  the  summary  judgment  documents  (with  minimal  redactions)  be  unsealed  upon  issuance  of  our mandate.22    Id. at 123.  18  Id. at 124.  19   See,  e.g.,  Giuffre,  325  F.  Supp.  3d  at  445  (summarily  concluding  that  all  “[t]he Summary Judgment Judicial Documents openly refer to and discuss these  allegations [of sexual assault and sexual trafficking] in comprehensive detail, and  that those allegations “establish[] a strong privacy interest here”).  20   Cf.  Lugosch,  435  F.3d  at  127  (ordering  that  “the  mandate  shall  issue  forthwith” to expedite the unsealing process).  21   Upon  issuance  of  our  mandate,  a  minimally  redacted  version  of  the  summary judgment record will be made accessible on the Court of Appeals docket.  We  have  implemented  minimal  redactions  to  protect  personally  identifying  information such as personal phone numbers, contact lists, birth dates, and social  22 13  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page14 of 25 C. The Remaining Sealed Materials  The law governing disclosure of the remaining sealed material  in  this  case  is  only  slightly  more  complex.  The  Supreme  Court  has  recognized a qualified right “to inspect and copy judicial records and  documents.”23 In defining “judicial records and documents,” we have  emphasized  that  “the  mere  filing  of  a  paper  or  document  with  the  court is insufficient to render that paper a judicial document subject to  the right of public access.”24 Instead, “the item filed must be relevant  to the performance of the judicial function and useful in the judicial  process in order for it to be designated a judicial document.”25   As our precedent makes clear, a court “perform[s] the judicial  function”  not  only  when  it  rules  on  motions  currently  before  it,  but  also when properly exercising its inherent “supervisory powers.”26 A  security  numbers.  We  have  also  redacted  the  names  of  alleged  minor  victims  of  sexual abuse from deposition testimony and police reports, as well as deposition  responses  concerning  intimate  matters  where  the  questions  were  likely  only  permitted—and the responses only compelled—because of a strong expectation of  continued  confidentiality.  See  Fed.  R.  Civ.  P.  5.2.  While  we  appreciate  the  views  expressed in Judge Pooler’s separate opinion, the panel majority believes that the  efforts  invested  by  three  former  district  judges  in  reviewing  these  materials  adequately address those concerns.    Nixon, 435 U.S. at 597–98.  23  United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) (“Amodeo I”).  24  Id.   25  Cf. United States v. HSBC Bank USA, N.A., 863 F.3d 125, 135 (2d Cir. 2017)  (explaining  that,  in  considering  whether  the  report  of  a  monitor  charged  with  assessing  compliance  with  a  deferred  prosecution  agreement  is  a  judicial  26 14  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page15 of 25 document is thus “relevant to the performance of the judicial function”  if it would reasonably have the tendency to influence a district court’s  ruling on a motion or in the exercise of its supervisory powers, without  regard  to  which  way  the  court  ultimately  rules  or  whether  the  document  ultimately  in  fact  influences  the  court’s  decision.27  Accordingly,  if  in  applying  these  standards,  a  court  determines  that  documents  filed  by  a  party  are  not  relevant  to  the  performance  of  a  judicial function, no presumption of public access attaches.28   Once  an  item  is  deemed  relevant  to  the  exercise  of  judicial  power,  “the  weight  to  be  given  the  presumption  of  access  must  be  governed by the role of the material at issue in the exercise of Article  III judicial power and the resultant value of such information to those  document,  “[i]f  the  district  court’s  conception  of  its  supervisory  power  in  this  context were correct, the Monitor’s Report would quite obviously be relevant to the  performance  of  the  judicial  function  and  useful  in  the  judicial  process”  (internal  quotation  marks  omitted)).  Whether  a  specific  judicial  decision  constitutes  a  “performance of the judicial function” is a question of law. Accordingly, we review  such determinations de novo. Id. at 134.    Amodeo I, 44 F.3d at 145–46 (concluding that documents were relevant to  the  performance  of  a  judicial  function  because  they  would  have  “informed”  the  district court’s decision whether to discharge or retain a Receiver); see also FTC. v.  Standard Fin. Mgmt. Corp., 830 F.2d 404, 409 (1st Cir. 1987) (citing Federal Rule of  Evidence  401’s  “having  any  tendency”  definition  of  relevance  in  determining  whether documents were “judicial documents”).  27   As  we  explain  below,  there  are  several  (often  preferable)  tools  beyond  sealing that district courts can use to protect their dockets from becoming a vehicle  for irrelevant—and potentially defamatory—accusations. See Section D, post.  28 15  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page16 of 25 monitoring the federal courts.”29 Thus, while evidence introduced at  trial  or  in  connection  with  summary  judgment  enjoys  a  strong  presumption of public access, documents that “play only a negligible  role in the performance of Article III duties” are accorded only a low  presumption that “amounts to little more than a prediction of public  access  absent  a  countervailing  reason.”30  Documents  that  are  never  filed  with  the  court,  but  simply  “passed  between  the  parties  in  discovery, lie entirely beyond the presumption’s reach.”31  The  remaining  sealed  materials  at  issue  here  include  filings  related  to,  inter  alia,  motions  to  compel  testimony,  to  quash  trial  subpoenae,  and  to  exclude  certain  deposition  testimony.  All  such  motions, at least on their face, call upon the court to exercise its Article  III powers. Moreover, erroneous judicial decision‐making with respect  to such evidentiary and discovery matters can cause substantial harm.  Such materials are therefore of value “to those monitoring the federal  courts.”32  Thus,  all  documents  submitted  in  connection  with,  and  relevant to, such judicial decision‐making are subject to at least some  presumption of public access.33   Amodeo II, 71 F.3d at 1049.  29  Id. at 1050.  30  Id.  31  Id. at 1049.    32  In previous decisions, we have identified an important exception to this  general  rule:  the  presumption  of  public  access  does  not  apply  to  material  that  is  submitted  to  the  court  solely  so  that  the  court  may  decide  whether  that  same  33 16  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page17 of 25 Although a court’s authority to oversee discovery and control  the  evidence  introduced  at  trial  surely  constitutes  an  exercise  of  judicial  power,  we note  that  this  authority  is  ancillary  to  the  court’s  core  role  in  adjudicating  a  case.  Accordingly,  the  presumption  of  public  access  in  filings  submitted  in  connection  with  discovery  disputes  or  motions  in  limine  is  generally  somewhat  lower  than  the  presumption applied to material introduced at trial, or in connection  with  dispositive motions  such  as motions  for  dismissal  or summary  judgment.34  Thus,  while  a  court  must  still  articulate  specific  and  substantial reasons for sealing such material, the reasons usually need  not  be  as  compelling  as  those  required  to  seal  summary  judgment  filings.   Here, the precise basis for the District Court’s decision to deny  the motion to unseal these remaining materials is unclear. In the three  paragraphs  devoted  to  the  issue,  the  District  Court  emphasized  the  potential for embarrassment “given the highly sensitive nature of the  underlying allegations,” and concluded that “the documents sealed in  the course of discovery were neither relied upon by [the District] Court  in  the  rendering  of  an  adjudication,  nor  necessary  to  or  helpful  in  resolving a motion.”35 It is therefore unclear whether the District Court  held  that  these  materials  were  not  judicial  documents  (and  thus  are  material  must  be  disclosed  in  the  discovery  process  or  shielded  by  a  Protective  Order. See TheStreet.Com, 273 F.3d at 233.    Amodeo II, 71 F.3d at 1049–50.  34   Giuffre,  325  F.  Supp.  3d.  at  442  (internal  quotation  marks  and  brackets  omitted).  35 17  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page18 of 25 not subject to a presumption of public access), or found that privacy  interests outweighed a limited right of public access.  On either interpretation, however, the District Court’s holding  was error. Insofar as the District Court held that these materials are not  judicial documents because it did not rely on them in adjudicating a  motion, this was legal error. As explained above, the proper inquiry is  whether the documents are relevant to the performance of the judicial  function,  not  whether  they  were  relied  upon.36  Indeed,  decision‐ makers  often  find  that  a  great  deal  of  relevant  material  does  not  ultimately sway their decision. And insofar as the District Court held  that  privacy  interests  outweigh  the  presumption  of  public  access  in  each of the thousands of pages at issue, that decision—which appears  to  have  been  made  without  particularized  review—amounts  to  an  abuse of discretion.37  In  light  of  the  District  Court’s  failure  to  conduct  an  individualized review of the sealed materials, it is necessary to do so  now.  We  believe  the  District  Court  is  best  situated  to  conduct  this  review. The District Court can directly communicate with the parties,  and  can  therefore  more  swiftly  and  thoroughly  consider  particular  objections to unsealing specific materials. Relatedly, the District Court  can obtain the parties’ assistance in effecting any necessary redactions,  and in notifying any outside parties whose privacy interests might be   See text accompanying notes 12–18 and 26–28, ante.  36  See In re City of New York, 607 F.3d 923, 943 n.21 (2d Cir. 2010) (explaining  that “abuse of discretion” is a nonpejorative, legal “term of art”).  37 18  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page19 of 25 implicated by the unsealing. Accordingly, we remand the cause to the  District Court to conduct such a particularized review and unseal all  documents for which the presumption of public access outweighs any  countervailing privacy interests.  D. Protecting the Integrity of Judicial Proceedings  While  we  disagree  with  the  District  Court’s  disposition  of  the  motions to unseal, we share its concern that court files might be used  to  “promote  scandal  arising  out  of  unproven  potentially  libelous  statements.”38  We  therefore  describe  certain  methods  courts  can  employ  to  protect  the  judicial  process  from  being  coopted  for  such  purposes.  The  Supreme  Court  has  explained  that  “[e]very  court  has  supervisory power over its own records and files” to ensure they “are  not used to gratify private spite or promote public scandal” or “serve  as  reservoirs  of  libelous  statements  for  press  consumption.”39  This  supervisory  function  is  not  only  within  a  district  court’s  power,  but  also among its responsibilities.   In practice, district courts may employ several methods to fulfill  this  function.  They  may,  for  instance,  issue  protective  orders  forbidding  dissemination  of  certain  material  “to  protect  a  party  or  person  from  annoyance,  embarrassment,  oppression,  or  undue   Giuffre, 325 F. Supp. 3d at 447.  38  Nixon, 435 U.S. at 598 (internal quotation marks).  39 19  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page20 of 25 burden” and require that filings containing such material be submitted  under seal.40 If parties then seek to file such materials, the court may  deny them leave to do so.41 District courts may also seek to counteract  the effect of defamatory statements by explaining on the record that  the  statements  appear  to  lack  credibility.  Moreover,  under  Federal  Rule  of  Civil  Procedure  12(f),  the  district  court  may  strike  such  material  from  the  filings  on  the  grounds  that  it  is  “redundant,  immaterial,  impertinent,  or  scandalous.”42  Because  such  rejected  or  stricken  material  is  not  “relevant  to  the  performance  of  the  judicial  function” it would not be considered a “judicial document” and would  enjoy  no  presumption  of  public  access.43  Finally,  in  appropriate   Fed. R. Civ. P. 26(c); see also TheStreet.Com, 273 F.3d at 229–30.  40  See, e.g., S.D.N.Y. Electronic Case Filing Rules & Instructions, February 1,  2019  Edition,  Rule  6.1,  http://nysd.uscourts.gov/ecf/ECF%20Rules%20020119%20Final.pdf.  41  Fed. R. Civ. P. 12(f). Courts may strike material from the pleadings either  “on  its  own”  or  “on  motion  made  by  a  party.”  Id.  Although  motions  to  strike  material solely “on the ground that the matter is impertinent and immaterial” are  disfavored, when material is also “scandalous,” no such presumption applies. Cf.  Lipsky v. Commonwealth United Corp., 551 F.2d 887, 893 (2d Cir. 1976); see also Talbot  v.  Robert  Matthews  Distrib.  Co.,  961  F.2d  654,  664  (7th  Cir.  1992)  (“Allegations may be stricken as scandalous if the matter bears no possible relation  to the controversy or may cause the objecting party prejudice.”); Wine Markets Intʹl,  Inc. v. Bass, 177 F.R.D. 128, 133 (E.D.N.Y. 1998) (“Motions to strike are not generally  favored,  except  in  relation  to  scandalous  matters.”);  Alvarado‐Morales  v.  Digital  Equip. Corp., 843 F.2d 613, 617–18 (1st Cir. 1988) (categorizing as scandalous “matter  which impugned the character of defendants”).  42  Amodeo I, 44 F.3d at 145.  43 20  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page21 of 25 circumstances, district courts may impose sanctions on attorneys and  parties under Federal Rule of Civil Procedure 11(c).44  E. A Cautionary Note  We conclude with a note of caution to the public regarding the  reliability of court filings such as those unsealed today.  Materials submitted by parties to a court should be understood  for what they are. They do not reflect the court’s own findings. Rather,  they are prepared by parties seeking to advance their own interests in  an  adversarial  process.  Although  affidavits  and  depositions  are  offered  “under  penalty  of  perjury,”  it  is  in  fact  exceedingly  rare  for  anyone to be prosecuted for perjury in a civil proceeding.45 Similarly,   In relevant part, Rule 11 provides:  44 By presenting to the court a pleading, written motion, or other paper . . . an  attorney or unrepresented party certifies that . . . it is not being presented  for any improper purpose, such as to harass, cause unnecessary delay, or  needlessly  increase  the  cost  of  litigation  .  .  .  .  [T]he  court  may  impose  an  appropriate sanction on any attorney, law firm, or party that violated the  rule  or  is  responsible  for  the  violation  .  .  .  .  The  sanction  may  include  nonmonetary directives; an order to pay a penalty into court; or, if imposed  on  motion  and  warranted  for  effective  deterrence,  an  order  directing  payment to the movant of part or all of the reasonable attorney’s fees and  other expenses directly resulting from the violation.  Fed. R. Civ. P. 11. See also Amodeo II, 71 F.3d at 1049 (describing sanctions available  to the court).    Sonia  Sotomayor  &  Nicole  A.  Gordon, Returning  Majesty  to  the  Law  and  Politics: A Modern Approach, 30 Suffolk U. L. Rev. 35, 47 n.52 (1996) (ʺPerjury cases  are not often pursued . . . .”).  45 21  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page22 of 25 pleadings,  complaints,  and  briefs—while  supposedly  based  on  underlying evidentiary material—can be misleading. Such documents  sometimes  draw  dubious  inferences  from  already  questionable  material or present ambiguous material as definitive.  Moreover,  court  filings  are,  in  some  respects,  particularly  susceptible to fraud. For while the threat of defamation actions may  deter malicious falsehoods in standard publications, this threat is non‐ existent with respect to certain court filings. This is so because, under  New York law (which governs the underlying defamation claim here),  “absolute  immunity  from  liability  for  defamation  exists  for  oral  or  written statements made . . . in connection with a proceeding before a  court.”46 Thus, although the act of filing a document with a court might  be  thought  to  lend  that  document  additional  credibility,  in  fact,  allegations appearing in such documents might be less credible than  those published elsewhere.47    Front, Inc. v. Khalil, 24 N.Y.3d 713, 718 (2015); see also Kelly v. Albarino, 485  F.3d 664, 666 (2d Cir. 2007) (adopting the reasoning of the District Court explaining  that this privilege is “the broadest of possible privileges”); Restatement (Second) of  Torts  §  587  (1977)  (“A  party  to  a  private  litigation  or  a  private  prosecutor  or  defendant in a criminal prosecution is absolutely privileged to publish defamatory  matter concerning another in communications preliminary to a proposed judicial  proceeding, or in the institution of or during the course and as a part of, a judicial  proceeding  in  which  he  participates,  if  the  matter  has  some  relation  to  the  proceeding.”). But see note 47, post.  46  While common law courts have generally interpreted the litigation privilege  broadly,  they  nevertheless  maintain  an  important  (if  rarely  implemented)  limitation on its scope: to qualify for the privilege, a statement must be “material  and pertinent to the questions involved.” Front, 24 N.Y.3d at 718 (quoting Youmans  47 22  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page23 of 25 We have long noted that the press plays a vital role in ensuring  the public right of access and in enhancing “the quality and safeguards  the integrity of the factfinding process.”48 When faithfully observing  its best traditions, the print and electronic media “contributes to public  understanding  of  the  rule  of  law”  and  “validates  [its]  claim  of  functioning as surrogates for the public.”49  At  the  same  time,  the  media  does  the  public  a  profound  disservice when it reports on parties’ allegations uncritically. We have  previously  observed  that  courts  cannot  possibly  “discredit  every  statement or document turned up in the course of litigation,” and we  have criticized “the use by the media of the somewhat misleading term  ‘court  records’  in  referring  to  such  items.”50  Even  ordinarily  critical  v.  Smith,  153  N.Y.  214,  219–20  (1897)).  It  follows,  then,  that  immaterial  and  impertinent statements are (at least nominally) actionable, particularly when they  are “so needlessly defamatory as to warrant the inference of express malice.” Id.  (same). It seems to us that when a district court strikes statements from the record  pursuant to Fed. R. Civ. P. 12(f) on the ground that the matter is “impertinent” and  “immaterial,”  it  makes  the  very  same  determination  that  permits  a  defamation  action under the common law. We think the judicial system would be well served  were our common law courts to revitalize this crucial qualification to the litigation  privilege.    Westmoreland  v.  Columbia  Broad.  Sys.,  Inc.,  752  F.2d 16, 23 (2d  Cir.  1984)  (quoting  Globe  Newspaper  Co.  v.  Superior  Court  for  Norfolk  Cty.,  457  U.S.  596,  606  (1982)).  48  Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 572–73 (1980) (plurality  opinion) (internal quotation marks omitted).  49  Amodeo II, 71 F.3d at 1049.  50 23  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page24 of 25 readers  may  take  the  reference  to  “court  papers”  as  some  sort  of  marker of reliability.  This would be a mistake.  We  therefore  urge  the  media  to  exercise  restraint  in  covering  potentially defamatory allegations, and we caution the public to read  such accounts with discernment.  III. CONCLUSION    To summarize, we hold as follows:  (1) Materials  submitted  in  connection  with  a  motion  for  summary  judgment  are  subject  to  a  strong  presumption  of  public access.  (2)  The  summary  judgment  record  at  issue  will  be  unsealed  upon  issuance  of  our  mandate,  subject  to  minimal  redactions.51  (3) Materials  submitted  in  connection  with,  and  relevant  to,  discovery  motions,  motions  in  limine,  and  other  non‐ dispositive  motions  are  subject  to  a  lesser—but  still  substantial— presumption of public access.  (4) The District Court is directed to review the remaining sealed  materials  individually  and  unseal  those  materials  as  appropriate.   See note 22, ante.  51 24  Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page25 of 25 (5) District  courts  should  exercise  the  full  range  of  their  substantial  powers  to  ensure  their  files  do  not  become  vehicles for defamation.  For  the  foregoing  reasons,  we  VACATE  the  orders  of  the  District Court entered on November 2, 2016, May 3, 2017, and August  27, 2018, ORDER the unsealing of the summary judgment record as  described  herein,  and  REMAND  the  cause  to  the  District  Court  for  particularized review of the remaining materials.   In undertaking this task, the District Court may be well‐served  by ordering the parties to submit to the Court unredacted, electronic  copies of the remaining sealed materials, as well as specific, proposed  redactions.  The  District  Court  may  also  order  the  parties  to  identify  and notify additional parties whose privacy interests would likely be  implicated by disclosure of these materials.  In  the  interests  of  judicial  economy,  any  future  appeal  in  this  matter shall be referred to this panel.  25  Case 18-2868, Document 273-3, 08/09/2019, 2628218, Page1 of 1 POOLER, Circuit Judge, dissenting in part:    I join the Court’s opinion in every respect but one: the decision to unseal  the summary judgment record ourselves. I agree that all or most of the material  must be unsealed. Nevertheless, in my view, the district court is better suited to  the task. As the Court’s opinion recognizes in connection with the remaining  sealed materials, the district court is better positioned to communicate with the  parties and any nonparties whose privacy interests might be affected by  unsealing. On that score, it is worth clarifying here the breadth of the Court’s  unsealing order: it unseals nearly 2000 pages of material. The task of identifying  and making specific redactions in such a substantial volume is perilous; the  consequences of even a seemingly minor error may be grave and are irrevocable.  Moreover, although I share the majority’s concern about avoiding delay, I would  alleviate that concern through other means—perhaps with an order directing the  district court to act expeditiously and by making clear what types of limited  redactions are and are not appropriate. In sum, I would unseal the district court’s  summary judgment decision only and leave the remainder of the materials for  the district court to review, redact, and unseal on remand.   Case 18-2868, Document 275, 08/09/2019, 2628223, Page1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X Plaintiff, v. GHISLAINE MAXWELL, Defendant. ............................................. .. VIRGINIA L. GIUFFRE, 15-cv-07433-RWS --------------------------------------------------X DEFENDANT’S STATEMENT OF MATERIAL UNDISPUTED FACTS PURSUANT TO LOCAL CIVIL RULE 56.1 Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 303.831.7364 Case 18-2868, Document 275, 08/09/2019, 2628223, Page2 of 18 Pursuant to Rule 56.1 of the Local Civil Rules of this Court, defendant Ghislaine Maxwell submits this statement of the material facts as to which she contends there is no genuine issues to be tried. Ms. Maxwell expressly preserves all of her objections to the admissibility of the evidence cited herein and in the accompanying memoranda of law and does not waive any objections by making this submission. numbered. 1. Ms. Maxwell’s response to publications of plaintiff’s false allegations: the March 2011 statement. In early 2011 plaintiff in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. In the articles, plaintiff made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, plaintiff suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. 2. In the articles, plaintiff alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” 3. In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.” 4. The statement read in full: Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 2011 London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. 1 Case 18-2868, Document 275, 08/09/2019, 2628223, Page3 of 18 It is unacceptable that letters sent by Ms Maxwell’s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers. “I understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop,” said Ghislaine Maxwell. “A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-251 Email: ross@acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: +44-203008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com 5. Plaintiff’s gratuitous and “lurid” accusations in an unrelated action. In 2008 two alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against the United States government purporting to challenge Epstein’s plea agreement. They alleged the government violated their CVRA rights by entering into the agreement. 6. Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action, claiming she, too, had her CVRA rights violated by the government. On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. 7. The issue presented in her joinder motion was narrow: whether she should be permitted to join the CVRA action as a party under Federal Rule of Civil Procedure 21, specifically, whether she was a “known victim[] of Mr. Epstein and the Government owed them CVRA duties.” Yet, “the bulk of the [motion] consists of copious factual details that [plaintiff] and [her co-movant] ‘would prove . . . if allowed to join.’” Ms. Giuffre gratuitously included 2 Case 18-2868, Document 275, 08/09/2019, 2628223, Page4 of 18 provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual trafficking. 8. At the time they filed the motion, Ms. Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA action. While they deliberately filed the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. 9. As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several individuals, and she offers details about the type of sex acts performed and where they took place.” The court ruled that “these lurid details are unnecessary”: “The factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent . . ., especially considering that these details involve non-parties who are not related to the respondent Government.” Accordingly, “[t]hese unnecessary details shall be stricken.” Id. The court then struck all Ms. Giuffre’s factual allegations relating to her alleged sexual activities and her allegations of misconduct by non-parties. The court said the striking of the “lurid details” was a sanction for Ms. Giuffre’s improper inclusion of them in the motion. 10. The district court found not only that the “lurid details” were unnecessary but also that the entire joinder motion was “entirely unnecessary.” Ms. Giuffre and her lawyers knew the motion with all its “lurid details” was unnecessary because the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. The court denied plaintiff’s joinder motion. 11. One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion, 3 Case 18-2868, Document 275, 08/09/2019, 2628223, Page5 of 18 Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein:  Ms. Maxwell “approached” plaintiff in 1999 when plaintiff was “fifteen years old” to recruit her into the scheme.  Ms. Maxwell was “one of the main women” Epstein used to “procure underaged girls for sexual activities.”  Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme.  She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.”  At the mansion, when plaintiff began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.”  Epstein “with the assistance of” Ms. Maxwell “converted [plaintiff] into . . . a ‘sex slave.’” Id. Plaintiff was a “sex slave” from “about 1999 through 2002.”  Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.”  Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.”  Ms. Maxwell “participat[ed] in the sexual abuse of [plaintiff] and others.”  Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [plaintiff].” Id. She shared the photos with Epstein.  As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect[ed]” Epstein with “powerful individuals” so that Epstein could traffick plaintiff to these persons.  Plaintiff was “forced to have sexual relations” with Prince Andrew in “[Ms. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” plaintiff’s sex with Prince Andrew “by acting as a ‘madame’ for Epstein.”  Ms. Maxwell “assist[ed] in internationally trafficking” plaintiff and “numerous other young girls for sexual purposes.”  Plaintiff was “forced” to watch Epstein, Ms. Maxwell and others “engage in illegal sexual acts with dozens of underage girls.” 4 Case 18-2868, Document 275, 08/09/2019, 2628223, Page6 of 18 12. In the joinder motion, plaintiff also alleged she was “forced” to have sex with Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and “many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.” 13. Plaintiff said after serving for four years as a “sex slave,” she “managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.” 14. Plaintiff suggested the government was part of Epstein’s “conspiracy” when it “secretly” negotiated a non-prosecution agreement with Eptstein precluding federal prosecution of Epstein and his “co-conspirators.” The government’s secrecy, plaintiff alleged, was motivated by its fear that plaintiff would raise “powerful objections” to the agreement that would have “shed tremendous public light on Epstein and other powerful individuals. 15. Notably, the other “Jane Doe” who joined plaintiff’s motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of plaintiff’s allegations. 16. Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, plaintiff told Ms. Churcher of virtually none of the details she described in the joinder motion. 17. Ms. Maxwell’s response to plaintiff’s “lurid” accusations: the January 2015 statement. As plaintiff and her lawyers expected, before District Judge Marra in the CVRA action could strike the “lurid details” of plaintiff’s allegations in the joinder motion, members of the media obtained copies of the motion. 18. At Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing “a quotable statement on 5 Case 18-2868, Document 275, 08/09/2019, 2628223, Page7 of 18 behalf of Ms Maxwell.” The email was sent to more than 6 and probably less than 30 media representatives. It was not sent to non-media representatives. 19. Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. These representatives were selected based on their request—after the joinder motion was filed—for a response from Ms. Maxwell to plaintiff’s allegations in the motion. 20. The email to the media members read: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. 21. Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional press release solely to disseminate information to the media. So he intentionally did not pass it through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation. 6 Case 18-2868, Document 275, 08/09/2019, 2628223, Page8 of 18 22. The January 2015 statement served two purposes. First, Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff’s false allegations. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject plaintiff’s allegations to inquiry and scrutiny. For example, he noted in the statement that plaintiff’s allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” 23. Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish plaintiff’s allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that plaintiff’s allegations were “defamatory.” In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff’s obviously false allegations and the legal indefensibility of their own conduct. 24. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (emphasis supplied). The statement was intended to be a single, one-time-only, comprehensive response—quoted in full—to plaintiff’s December 30, 2014, allegations that would give the media Ms. Maxwell’s response. The purpose of the prefatory statement was to inform the mediarecipients of this intent. 25. Plaintiff’s activities to bring light to the rights of victims of sexual abuse. Plaintiff has engaged in numerous activities to bring attention to herself, to the prosecution and punishment of wealthy individuals such as Epstein, and to her claimed interest of bringing light to the rights of victims of sexual abuse. 7 Case 18-2868, Document 275, 08/09/2019, 2628223, Page9 of 18 26. Plaintiff created an organization, Victims Refuse Silence, Inc., a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. 27. The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse.” Toward this end, plaintiff has “dedicated her professional life to helping victims of sex trafficking.” 28. Plaintiff repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. 29. On December 30, 2014, plaintiff publicly filed an “entirely unnecessary” joinder motion laden with “unnecessary,” “lurid details” about being “sexually abused” as a “minor victim[]” by wealthy and famous men and being “trafficked” all around the world as a “sex slave.” 30. The plaintiff’s alleged purpose in filing the joinder motion was to “vindicate” her rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution agreement” with Epstein, “shed tremendous public light” on Epstein and “other powerful individuals” that would undermine the agreement, and support the CVRA plaintiffs’ request for documents that would show how Epstein “used his powerful political and social connections to secure a favorable plea deal” and the government’s “motive” to aid Epstein and his “coconspirators.” 31. Plaintiff has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s alleged “sex scheme.” 8 Case 18-2868, Document 275, 08/09/2019, 2628223, Page10 of 18 32. Republication alleged by plaintiff. Plaintiff was required by Interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were “‘published globally, including within the Southern District of New York,’” as plaintiff alleged in Paragraph 9 of Count I of her complaint. In response, plaintiff identified the January 2015 statement and nine instances in which various news media published portions of the January 2015 statement in news articles or broadcast stories. 33. In none of the nine instances was there any publication of the entire January 2015 statement. 34. Ms. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in plaintiff’s response to Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015 statement. 35. Plaintiff’s defamation action against Ms. Maxwell. Eight years after Epstein’s guilty plea, plaintiff brought this action, repeating many of the allegations she made in her CVRA joinder motion. 36. The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (b) That the allegations have been “shown to be untrue.” (c) That Giuffre’s “claims are obvious lies.” 37. Plaintiff lived independently from her parents with her fiancé long before meeting Epstein or Ms. Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999, plaintiff moved in with the family of a fellow patient. There she met, and became engaged to, her friend’s brother, James Michael Austrich. She and Austrich thereafter 9 Case 18-2868, Document 275, 08/09/2019, 2628223, Page11 of 18 rented an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs in that area. Later, they stayed briefly with plaintiff’s parents in the Palm Beach/ Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. Although plaintiff agreed to marry Austrich, she never had any intention of doing so. 38. Plaintiff re-enrolled in high school from June 21, 2000 until March 7, 2002. After finishing the 9th grade school year at Forest Hills High School on June 9, 1999, plaintiff reenrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on August 14, 2001. On September 20, 2001, Plaintiff then enrolled at Royal Palm Beach High School. A few weeks later, on October 12, 2001, she matriculated at Survivors Charter School. Id. Survivor’s Charter School was an alternative school designed to assist students who had been unsuccessful at more traditional schools. Plaintiff remained enrolled at Survivor’s Charter School until March 7, 2002. She was present 56 days and absent 13 days during her time there. Id. Plaintiff never received her high school diploma or GED. Plaintiff and Figueroa went “back to school” together at Survivor’s Charter School. The school day there lasted from morning until early afternoon. 39. During the year 2000, plaintiff worked at numerous jobs. In 2000, while living with her fiancé, plaintiff held five different jobs: at Aviculture Breeding and Research Center, Southeast Employee Management Company, The Club at Mar-a-Lago, Oasis Outsourcing, and Neiman Marcus. Her taxable earnings that year totaled nearly $9,000. Plaintiff cannot now recall either the Southeast Employee Management Company or the Oasis Outsourcing jobs. 40. Plaintiff’s employment at the Mar-a-Lago spa began in fall 2000. Plaintiff’s father, Sky Roberts, was hired as a maintenance worker at the The Mar-a-Lago Club in Palm 10 Case 18-2868, Document 275, 08/09/2019, 2628223, Page12 of 18 Beach, Florida, beginning on April 11, 2000. Mr. Roberts worked there year-round for approximately 3 years. After working there for a period of time, Mr. Roberts became acquainted with the head of the spa area and recommended plaintiff for a job there. Mar-a-Lago closes every Mother’s Day and reopens on November 1. Most of employees Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club is open, i.e., between November 1 and Mother’s Day. Plaintiff was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17. 41. Plaintiff represented herself as a masseuse for Jeffrey Epstein. While working at the Mar-a-Lago spa and reading a library book about massage, plaintiff met Ms. Maxwell. Plaintiff thereafter told her father that she got a job working for Jeffrey Epstein as a masseuse. Plaintiff’s father took her to Epstein’s house on one occasion around that time, and Epstein came outside and introduced himself to Mr. Roberts. Plaintiff commenced employment as a traveling masseuse for Mr. Epstein. Plaintiff was excited about her job as a masseuse, about traveling with him and about meeting famous people. Plaintiff represented that she was employed as a masseuse beginning in January 2001. Plaintiff never mentioned Ms. Maxwell to her then-fiancé, Austrich. Plaintiff’s father never met Ms. Maxwell. 42. Plaintiff resumed her relationship with convicted felon Anthony Figueroa. In spring 2001, while living with Austich, plaintiff lied to and cheated on him with her high school boyfriend, Anthony Figueroa. Plaintiff and Austrich thereafter broke up, and Figueroa moved into the Bent Oak apartment with plaintiff. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa in Plaintiff’s presence punched Austrich in the face. Figueroa and plaintiff fled the scene before police arrived. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance. 11 Case 18-2868, Document 275, 08/09/2019, 2628223, Page13 of 18 43. Plaintiff freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at age 17, while living in the same apartment, plaintiff and Figueroa hosted a party with a number of guests. During the party, according to plaintiff, someone entered plaintiff’s room and stole $500 from her shirt pocket. Plaintiff contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a “sex slave.” A second time, in June 2002, plaintiff contacted the police to report that her former landlord had left her belongings by the roadside and had lit her mattress on fire. Again, plaintiff met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a “sex slave.” 44. From August 2001 until September 2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel unaccompanied by Plaintiff. Flight logs maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips away from Florida that Epstein and Maxwell took, unaccompanied by Plaintiff, between August 2001 and September 2002. Rodgers maintained a log of all flights on which Epstein and Maxwell traveled with him. Epstein additionally traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial flights. For substantially all of thirteen months of the twenty-two months (from November 2000 until September 2002) that Plaintiff lived in Palm Beach and knew Epstein, Epstein was traveling outside of Florida unaccompanied by Plaintiff. During this same period of time, Plaintiff was employed at various jobs, enrolled in school, and living with her boyfriend. 45. Plaintiff and Figueroa shared a vehicle during 2001 and 2002. Plaintiff and Figueroa shared a ’93 white Pontiac in 2001 and 2002. Plaintiff freely traveled around the Palm 12 Case 18-2868, Document 275, 08/09/2019, 2628223, Page14 of 18 Beach area in that vehicle. In August 2002, Plaintiff acquired a Dodge Dakota pickup truck from her father. Figueroa used that vehicle in a series of crimes before and after Plaintiff left for Thailand. 46. Plaintiff held a number of jobs in 2001 and 2002. During 2001 and 2002, plaintiff was gainfully employed at several jobs. She worked as a waitress at Mannino’s Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at Roadhouse Grill. She also was employed at Courtyard Animal Hospital (aka Marc Pinkwasser DVM). 47. In September 2002, Plaintiff traveled to Thailand to receive massage training and while there, met her future husband and eloped with him. Plaintiff traveled to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove her to the airport. While there, she initially contacted Figueroa frequently, incurring a phone bill of $4,000. She met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until two days before Mr. Figueroa’s deposition in this matter in May 2016. 48. Detective Recarey’s investigation of Epstein failed to uncover any evidence that Ms. Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. Joseph Recarey served as the lead detective from the Palm Beach Police Department charged with investigating Jeffrey Epstein. That investigation commenced in 2005. Recarey worked only on the Epstein case for an entire year. He reviewed previous officers’ reports and interviews, conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance footage of the Epstein home, participated in and had knowledge of the search warrant executed on the Epstein home, and testified regarding the case before the Florida state grand jury against Epstein. Detective Recarey’s investigation 13 Case 18-2868, Document 275, 08/09/2019, 2628223, Page15 of 18 revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect by the government. None of Epstein’s alleged victims said they had seen Ms. Maxwell at Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her, nor told what to wear or how to act by her. Indeed, none of Epstein’s alleged victims ever reported to the government they had met or spoken to Ms. Maxwell. Maxwell was not seen coming or going from the house during the law enforcement surveillance of Epstein’s home. The arrest warrant did not mention Ms. Maxwell and her name was never mentioned before the grand jury. No property belonging to Maxwell, including “sex toys” or “child pornography,” was seized from Epstein’s home during execution of the search warrant. Detective Recarey, when asked to describe “everything that you believe you know about Ghislaine Maxwell’s sexual trafficking conduct,” replied, “I don’t.” He confirmed he has no knowledge about Ms. Maxwell sexually trafficking anybody. Detective Recarey also has no knowledge of Plaintiff’s conduct that is subject of this lawsuit. 49. No nude photograph of Plaintiff was displayed in Epstein’s home. Epstein’s housekeeper, Juan Alessi, “never saw any photographs of Virginia Roberts in Mr. Epstein’s house.” Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. 50. Plaintiff intentionally destroyed her “journal” and “dream journal” regarding her “memories” of this case in 2013 while represented by counsel. Plaintiff drafted a “journal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents in her 14 Case 18-2868, Document 275, 08/09/2019, 2628223, Page16 of 18 possession. Id. Plaintiff also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. To date, Plaintiff cannot locate the “dream journal.” 51. Plaintiff publicly peddled her story beginning in 2011. Plaintiff granted journalist Sharon Churcher extensive interviews that resulted in seven (7) widely distributed articles from March 2011 through January 2015. Churcher regularly communicated with plaintiff and her “attorneys or other agents” from “early 2011” to “the present day.” Plaintiff received approximately $160,000 for her stories and pictures that were published by many news organizations. 52. Plaintiff drafted a 144-page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, plaintiff drafted a book manuscript which purported to document plaintiff’s experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. Plaintiff communicated with literary agents, ghost writers and potential independent publishers in an effort to get her book published. She generated marketing materials and circulated those along with book chapters to numerous individuals associated with publishing and the media. 53. Plaintiff’s publicly filed “lurid” CVRA pleadings initiated a media frenzy and generated highly publicized litigation between her lawyers and Alan Dershowitz. On December 30, 2014, plaintiff, through counsel, publicly filed a joinder motion that contained her “lurid allegations” about Ms. Maxwell and many others, including Alan Dershowitz, Prince Andrew, Jean-Luc Brunel. The joinder motion was followed by a “corrected” motion and two further declarations in January and February 2015, which repeated many of plaintiff’s claims. These CVRA pleadings generated a media maelstrom and spawned highly publicized litigation between plaintiff’s lawyers, Edwards and Cassell, and Alan Dershowitz. After plaintiff publicly 15 Case 18-2868, Document 275, 08/09/2019, 2628223, Page17 of 18 alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called plaintiff a liar and accused her lawyers of unethical conduct. In response, attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. 54. Plaintiff formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, plaintiff, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to plaintiff, the purpose of the organization is to promote plaintiff’s professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Plaintiff attempts to promote Victims Refuse Silence at every opportunity. For example, plaintiff participated in an interview in New York with ABC to promote the charity and to get her mission out to the public. Dated: January 6, 2017 Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 lmenninger@hmflaw.com Attorneys for Ghislaine Maxwell 16 Case 18-2868, Document 275, 08/09/2019, 2628223, Page18 of 18 CERTIFICATE OF SERVICE I certify that on January 6, 2017, I electronically served this Defendant’s Statement of Material Undisputed Facts Pursuant to Local Civil Rule 56.1 via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. 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Plaintiff, GHISLAINE MAXWELL, Defendant. ........................................... ..... VIRGINIA L. GIUFFRE, 15-cv-07433-RWS --------------------------------------------------X Declaration of Laura A. Menninger in Support of Defendant’s Motion For Summary Judgment I, Laura A. Menninger, declare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell’s Motion for Summary Judgment.1 2. Attached as Exhibit A is a true and correct copy of an article by Sharon Churcher entitled “Prince Andrew and the 17-year-old girl his sex offender flew to Britain to meet him,” DAILY MAIL, dated March 2, 2011. 1 At trial, defendant intends to produce either the custodian of record relevant to any disputed document or a certification in compliance with either Fed. R. Evid. P. 803 and/or 902. See Fed. R. Civ. P. 56(c). Apart from deposition testimony, the majority of non-deposition documents herein were either produced by plaintiff or obtained with releases signed by plaintiff. Case 18-2868, Document 277, 08/09/2019, 2628225, Page2 of 7 3. Attached as Exhibit B is a true and correct copy of an article by Sharon Churcher entitled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill Clinton,” DAILY MAIL, dated March 5, 2011. 4. Attached as Exhibit C is a true and correct copy of a statement on behalf of Ms. Maxwell dated March 9, 2011. 5. Attached as Exhibit D (filed under seal) is a true and correct copy of the corrected Motion for Joinder, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Jan. 2, 2015). 6. Attached as Exhibit E is a true and correct copy of an Order Denying Motion to Join Under Rule 21, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Apr. 7, 2016). 7. Attached as Exhibit F is a true and correct copy of a statement on behalf of Ms. Maxwell dated January 2, 2015. 8. Attached as Exhibit G (filed under seal) are true and correct copies of excerpts from the November 18, 2016 deposition of Ross Gow, designated Confidential under the Protective Order. 9. Attached as Exhibit H (filed under seal) is a true and correct copy of Plaintiff’s Response to Second Request for Production and to Interrogatories and Requests for Admissions, dated July 1, 2016. 10. Attached as Exhibit I (filed under seal) is a true and correct copy of Plaintiff’s Supplemental Responses to to Interrogatory Nos. 6, 12 and 13, dated August 17, 2016, designated Confidential under the Protective Order. 2 Case 18-2868, Document 277, 08/09/2019, 2628225, Page3 of 7 11. Attached as Exhibit J (filed under seal) is a true and correct copy of the Declaration of Ghislaine Maxwell, dated January 6, 2017. 12. Attached as Exhibit K (filed under seal) is a true and correct copy of the Declaration of Philip Barden, dated January 6, 2017. 13. Attached as Exhibit L (filed under seal) are true and correct copies of excerpts from the June 23, 2016 deposition of James Austrich, designated Confidential under the Protective Order. 14. Attached as Exhibit M (filed under seal) is a true and correct copy of Plaintiff’s passport application, dated January 12, 2001, designated Confidential under the Protective Order. 15. Attached as Exhibit N (filed under seal) are true and correct copies of excerpts from the May 3, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective Order. 16. Attached as Exhibit O (filed under seal) are true and correct copies of Plaintiff’s school records Bates stamped GM_00888 and GIUFFREE004981-88 and designated Confidential under the Protective Order. 17. Attached as Exhibit P (filed under seal) are true and correct copies of excerpts from the June 24, 2016 deposition of Tony Figueroa, designated Confidential under the Protective Order. 18. Attached as Exhibit Q (filed under seal) are true and correct copies of excerpts from the November 14, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective Order. 3 Case 18-2868, Document 277, 08/09/2019, 2628225, Page4 of 7 19. Attached as Exhibit R (filed under seal) is a true and correct copy of Plaintiff’s Social Security records dated October 25, 2016, Bates stamped GIUFFRE009175, designated Confidential under the Protective Order. 20. Attached as Exhibit S (filed under seal) is a true and correct copy of Mar-A-Lago records, Bates stamped MAR-A-LAGO-0001 and MAR-A-LAGO-0161-0177. 21. Attached as Exhibit T (filed under seal) is a true and correct copies of excerpts from the May 20, 2016 deposition of Sky Roberts, designated Confidential under the Protective Order. 22. Attached as Exhibit U (filed under seal) ) is a true and correct copy of the Mar-ALago employee handbook, dated October 28, 1995, Bates stamped MAR-A-LAGO-0178-0243. 23. Attached as Exhibit V (filed under seal) is a true and correct copy of the Mar-A-Lago advertisement, Bates stamped MAR-A-LAGO-0086. 24. Attached as Exhibit W (filed under seal) is a true and correct copy of Plaintiff’s Courtyard Animal Hospital employment application, Bates stamped GIUFFRE009201-11, designated Confidential under the Protective Order. 25. Attached as Exhibit X(filed under seal) is a true and correct copy of the Royal Palm Beach Police Department Offense Report date, June 10, 2001, Bates stamped GM_00780-82. 26. Attached as Exhibit Y (filed under seal) is a true and correct copy of the Royal Palm Beach Police Department Probable Cause Affidavit date, November 19, 1999, Bates stamped GM_01223-28. 27. Attached as Exhibit Z (filed under seal) is a true and correct copy of the Royal Palm Beach Police Department Offense Report date, August 3, 2001, Bates stamped GM_00777-79. 4 Case 18-2868, Document 277, 08/09/2019, 2628225, Page5 of 7 28. Attached as Exhibit AA (filed under seal) is a true and correct copy of the Palm Beach County Sheriff’s Offense Report date, June 02, 2002, Bates stamped GM_00748-79. 29. Attached as Exhibit BB (filed under seal) are true and correct copies of David Rodgers flight logs from November 1995 to May 2013, Bates stamped DR__0001-DR0107. 30. Attached as Exhibit CC (filed under seal) is a true and correct copy of excerpts from the June 3, 2016 deposition of David Rodgers, designated Confidential under the Protective Order. 31. Exhibit DD left intentionally blank. 32. Attached as Exhibit EE (filed under seal) is a true and correct copy of the Royal Palm Beach Police Citation Tracking Report date, June 19, 2002, Bates stamped GM_00776. 33. Attached as Exhibit FF (filed under seal) is a true and correct copy of the Palm Beach County Sheriff’s Offense Report, Bates stamped GM_01202-28. 34. Attached as Exhibit GG (filed under seal) is a true and correct copies of excerpts from the June 21, 2016 deposition of Joseph Recarey, designated Confidential under the Protective Order. 35. Attached as Exhibit HH (filed under seal) is a true and correct copy of the Affidavit of Juan P. Alessi, dated January 13, 2016, Bates stamped GM_01197-1201. 36. Attached as Exhibit II (filed under seal) is a true and correct copy of excerpts from the Deposition of Virginia Giuffre taken in Cassell v. Dershowitz, on January 16, 2016, and designated as Confidential under the Protective Order. 5 Case 18-2868, Document 277, 08/09/2019, 2628225, Page6 of 7 37. Attached as Exhibit JJ (filed under seal) is a true and correct copy of Errata Sheet from the January 16, 2016 deposition of Virginia Giuffre taken in Cassell v. Dershowitz, dated February 11, 2016 and designated by Plaintiff as Confidential under the Protective Order. 38. Attached as Exhibit KK (filed under seal) is a true and correct copy of The Billionaire Playboys Club book manuscript, designated by Plaintiff as Confidential under the Protective Order. 39. Attached as Exhibit LL is a true and correct copy of the Victims Refuse Silence, Inc. Articles of Incorporation dated December 23, 2014, GIUFFRE001064-65. 40. Attached as Exhibit MM (filed under seal) is a true and correct copy of excerpts from the September 8, 2016 deposition of Brittany Henderson, designated Confidential under the Protective Order. I declare under penalty of perjury that the foregoing is true and correct. Executed on January 6, 2017. s/ Laura A. Menninger Laura A. Menninger 6 Case 18-2868, Document 277, 08/09/2019, 2628225, Page7 of 7 CERTIFICATE OF SERVICE I certify that on January 6, 2017, I electronically served this Declaration of Laura A. Menninger in Support of Defendant’s Motion for Summary Judgment via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@aol.com /s/ Nicole Simmons Nicole Simmons 7 Case 18-2868, Document 278, 08/09/2019, 2628230, Pagel of 648 EXHIBIT A Case 18-2868, Document 278, 08/09/2019, 2628230, Page2 of 648 6114:2016 Prince Andrew and girl, 17, who sex o?er?er friend flew to Britain to meet him Daily Mail Ontine Daily ail .com Home I U.K. Sports Showbiz [Australia [Femail [Health [Science [Money [Video [Travel [Columnists tr am .22: Mates: rtts?tiittr?ie Prince Andrew and the 17-year-old girl his 1 sex offender friend flew to Britain to meet him By SHARON CHURCHER UPDATED: 08:02 EST, 2 March 2011 101 View comments . Virginia Roberts reveats she is ?Jane Doe 102' in Jeffrey Epstein case . Mother-of-three spent four years as miltionaire?s personal masseuse . She describes being flown across wortd to meet Prince Andrew . Epstein trained her 'as a prostitute for him and his friends' As the UK's special representative for intemationai trade, the Duke of York holds an important position, requiring sound judgement and widespread respect. But those qualities have been thrown into question since photographs of Prince Andrew with his billionaire ?nancier friend Jeffrey Epstein, a convicted child-sex offender who was jailed for 18 months for soliciting underage prostitutes, appeared last weekend. Today, however, even more serious doubts are cast on his suitability after a woman at the centre of the Epstein case revealed to The Matt on Sunday that she had, as a 17-year-old employed by Epstein, been flown across the world to be introduced to the Prince. 11?34 Case 18-2868, Document 278, 08/09/2019, 2628230, Page3 of 648 Case. t?flE?W??Wai'P?ag'?ii?naf 9 Lindsay Lohan flashes her cleavage in a low? cut lilac number as she enjoys romantic day in Zurich with fiance Egor Tarabasov Loveiy in lilac Back in time to celebrate! Kim Kardashian and Kanye West arrive in LA on eve of daughter North's third 5 birthday Whirlwind 24-hour trip Bathing suit babes! Piayboy vet Kendra Wilkinson shows off chest in one piece white celebrating alst birthday with 'number one ho' in Arizona Sean Penn's son Hopper, 22, reveats his famous father wanted to name him ?Steak' due to his love of red meat His mom Robin Wright woutdn't have gone for it New romance for Ruby? Rose 'dating? businesswoman Harley Gusman after the pair were spotted cozying up on a date in Hollywood Offthe market? Was Patrick Swayze a victim of domestic abuse? Wife denies claims she beatth- Dirty Dancing star throughout their 34?year marriage - and ev on when he was dying Advertisement First meeting: Prince around 17-year-old Virginia, centre On one of those occasions Virginia Roberts was subsequentiy paid $15,000 Her shocking account of her four years as Epstein's personal masseuse is supported by court documents, an eyewitness, photographs and ?ight details of Epstein?s private jets. One picture, said to have been taken by Epstein during Andrew?s ?rst encounter with the girl in March 2001 and published today by The Malt on Sunday, shows the Prince with his arm around her waist. This is not the ?rst time the Duke of York?s judgment and choice of associates have been questioned. He appears to relish the company of super-rich oil billionaires from the Middle East, North Africa and the former Soviet Union. The peculiar sale of his former marital home to a Kazakh businessman for ?15 miliion after it had languished unsold for ?ve years at ?12 million has never been satisfactorin explained. in the recent leak of American diplomatic cables it was revealed that he had criticised an of?ciai corruption investigation into the huge Al-Yamamah arms deal between Britain and Saudi Arabia, while he is aiso said to be close to Self Al-isiam Gadda?, son of the beteaguered Libyan president, and may have had a role in the early release of Lockerbie bomber Abdelbaset Ai Megrahi. But it is And rew?s friendship with Epstein, whom he has known since at least 2000, and with Wh I '9 on th Streets a I Epstein?s con?dante Ghislaine Maxwell, daughter Slept With en fo of the tate disgraced newspaper baron Robert Maxweil, that gives most concernwas ?rst seen with the pair on holiday in . Thaiiand, and was pictured cavorting with p39d0 I I ream Ghisfaine at a Haltoween fetishthemed party in Case 18-2868, Document 278, 08/09/2019, 2628230, Page4 of 648 61140016 Case In .- Manhattan. The photograph that appeared iast weekend shows the prince stroiling through Centrai Park with 58-year-old Epstein. Andrew was said to have spent four days at his New York mansion in December, when he was joined by other distinguished guests, including Woody Allen, at a dinner. it is by no means the ?rst New York soiree Andrew has attended as Epstein?s guest. A pro?le of the ?nancier in Vanity Fair magazine some years ago reported that Andrew was a guest at a cocktail party thrown by Epstein and Maxwetl packed with young Russian modeis. '80 me guests were horri?ed,? said the article's author, Vicky Ward. it should not be forgotten that Epstein is a registered sex offender after recently completing his sentence for offences reiating to child prostitution. However, he avoided triai on more serious charges that carried a potential life sentence. And no one reading The Mail on Sunday?s intenriew with the woman who was prepared to testify against him can be in any doubt of the seriousness of the charges. Epstein, a Wall Street money manager who once counted Bill Clinton and Donald Trump among his friends, became the subject of an undercover investigation in 2005 after the stepmother of a 14-year oid girl claimed she was paid $200 (?125) to give him an 'erotic massage?. The subsequent FBI probe uncovered at feast 20 girls levelling sexual allegations against him. Eventually, Epstein struck a ?plea bargain? with prosecutors a practice not permitted under British law? under which he was allowed to plead guilty to two relatively minor charges. Police claim that his donations to politicians and his ?dream team? of in?uential lawyers deterred prosecutors from bringing more serious charges of The deal certainly kept the names of a lot of Epstein?s famous friends out of an embarrassing court case. However, an unusual part of the agreement was that Epstein's alleged victims were allowed to bring civil proceedings against him. He has so far made 17 out-of?court settlements, and some cases are ongoing. One of these girls was to have been a key witness for the prosecution had the case gone to triai. She was just 15 years old when she was drawn into Epstein?s expioitative world in 1998. In her civil writ against him, under the pseudonym Jane Doe 102' she alleged that her duties included being ?sexually exploited by Epstein's adult male peers including royalty?. Now, horrified by the evidence of Epstein and Andrew enjoying each other?s company in New York, Jane Doe 102 has agreed to waive her anonymity and tell for the ?rst time her deeply disturbing story. Her real name is Virginia Roberts and she now iives in Australia, where she is a happily married mother of three. Over the course of a week during which she spoke at length to The Mail on Sunday, she appeared sometimes vulnerable, and sometimes steely, but always quietly resoiute and consistent. Revisiting events from a past that she had hoped she had ieft behind,Virginia occasionally buried her face in her hands. Some recollections - and, for reasons of taste, not ail the details can be included here - wused her to flush with shame. 'l?m telling you things that even my husband didn?t know,? she said. Virginia, who has undergone counselling to try to come to terms with her past, is honest about her initiation into Epstein?s depraved worid. She was a troubled teenager, whose slender ?gure. deiicate compiexion, hesitant voice and soulful blue eyes made her iook young for her years. Born in Sacramento, California, in August 1983, Virginia spent her early years on a email ranch on the West Coast of America. This seemingly idyllic childhood ended when she was sexuaiiy molested by a man close to her family. The fallout from that led to her parents temporarily splitting up. Btaming herself, Virginia began to get into trouble Aged 11, she was sent to live with an aunt but repeatediy ran away. Living on the streets, she was beaten up and slept with at least two older men in return for food. 1 was a paedophile's dream,? she says. Three years iater, she was reunited with her family and started a new life with herfather who had moved to Palm Beach, Fiorida, where he was maintenance manager at Donaid Trump?s country club, Mar?a?Lago. Virginia got a part-time job as a changing room assistant ?which is where, soon after her 15th birthday, she met Ghislaine Maxweli, who invited her to work as Epstein?s personal masseuse. 'l was wearing my uniform a white miniskirt and a skin-tight white polo top when i was approached by Ghisiaine,? Virginia says. told her wanted to become a masseuse and she said she worked for a very wealthy gentieman who was looking for a masseuse. I'd get training and be paid welt.?Virginia?s father gave his blessing, believing his daughter was being handed the opportunity to learn a skill and to work for a weaithy and respectable employer. He drove her to Epstein?s pink mansion on the Palm Beach waterfront~ he also owns a nine-storey home in New York, the city's biggest private residence; a 7,500?acre ranch called ?Zorro? in New may toailadm?maialfma??wef 9 'Need a tight tush': LeAnn Rimes iilustrates how to get a firm 'bocty' as she does yoga in skimpy tank top and leggings Exercise tips 'i want them really big!? Blonds bombshell begs doctors to make her 1,000cc implants even after they insist her enhanced breasts are 'perfect' On Botched 'lt's my icurth favorite reality show! Jessica Aiba and Kate Hudson are mean girls as Chris Martin plays for laughs in Sara and Erin Foster' Barely Famous 'He's turned into an absolute jerk:' Former Celebrity Apprentice star Vivica A. Fox siams Donald but says he's not a racist She's no longer a fan ?l don't see a dark past anymore': Paris Jackson reveais tattoos hav heiped cover her 'scars and self-hatred? in moving lnstagram post How the season's hottest beach babes including Hailee Steinfeld and Kendall Jenner are embracing jeweiry at the seashora Chic on the beach This bid thingi Duchess of Cambridge recycles a TEN~year-old . brocade coat as she plants a tree at garden party From the back of her wardrobe EXCLUSIVE: Alexa Curtin, daughter of Real Housewives star Lynne, is charged with drug possession two months after accusing O.C. deputy sheriff of raping her during a traffic step 'i told my mom she's a grandma?: Maria Menounos shared excitement about her frozen embryos in poignant given before negative pregnancy test Gene Simmons? daughter Sophie says she was told she was 'not small enough' to be a model and reveals her mom taught her to iove her shape Case 18-2868, Document 278, 08/09/2019, 2628230, PageS of 648 6114mm Case 9 Mexico and Little Saint James, a private 70_ acre atoll in the US Virgin islands. 'i?d cry because there was nothing icould do to heip': Betta Hadid pens emotional note about her mother Yolanda's Lyme disease battle and shares the impact of her own struggle Has the Queen Bey lost her sting? Beyonce steps out in questionable out?ts as she recyctes Super Bowl Reformation look She is stilt a b?ailbiezer Jenna Bush Hager shares somber message about motherhood as she reveais her daughter was baptized oniy hours before Orlando shooting Time for Kardashian ideas! From 'bloop? to Kim schools fans in how to talk iike a true-blooded member of the family How to be like them Brazilian Miss Burn Bum model reveats she is paralysed from the waist down after throwing herseif from a fourth floor window in suicide attempt A new life: Virgina, now a mother?of-three, in Australia Southern Charm stars claim Dennis Virginia says: 'Ghislaine said I was to start immediately and that someone would drive me home. failed drug test in My father left and i was toid to go upstairs.? She was fed by another woman through Epstein?s cusmdy hams mm wealthy drug~shamed bedroom Into a massage room where he lay face down naked on a table. former politicgan He started to interviewed Virginia. This was unconventional, but Virginia had no suspicions. thgi?e?raxi?t?jget'oa?gg Presumably, she thOught, this was how the wealthy conducted their business. Epstein elicited the information that Virginia had been a runaway, and was no longer a virgin. Mini?me Barmnioms parents Donald Trump Virginia was then toid to start massaging Epstein, under the Instructions of the woman who had and Meiania at The Pole shown her in. The massage quickly developed into a sexual encounter. Bar for dinner the night . . . before his 70th birthday Virginia was uncomfortable, but reluctant to deny such Important people. ?My face was red With (and Secret Service embarrassment,? she says. ?But i felt under immense pressure to piease them. chauffeurs them the one . . . . . . The whole time It was 90an on, they were me the world, that I?d travel w1th Jeffrey on his mom wal ome) private jet and have a weii~paid profession.? Afterwards, she was given two $100 bitls and told to Lord of the manor! return the next day. Scott Disick views That was the beginning of the four years she spent with Epstein. For three of those years, she was under Fiorida's age of consent, which is 18. 3:21:22: t? ?x He is 33 Peek-a?boob! Heidi Klum flashes cleavage 4f34 Case 18-2868, Document 278, 08/09/2019, 2628230, Page6 of 648 6114/2016 Traubled teenager: Virginia on the billionaire's Zorro ranch in New Milli? Case 1: 1590WWRW81 WM mi? ??lm Virginia was fascinated by his life story: the son of a humble New York City parks worker, he was a teacher before becoming a Wall Street broker and friends with the upper echelons of the political, ?nancial and academic establishment. As a confused teenager, Virginia easily fell into the practice of sexually gratifying him for money. He guaranteed her a minimum of $200 each time she gave him what he called an ?erotic massage.? Virginia said: ?i would always receive the money immediately. He would give me the cash from a wad he carried in a black duffel bag or an assistant paid me. ?And, because of the way Epstein had warped her sensibilities, every time she took the cash, Virginia felt even more indebted to him. Secretly, he was also preparing her for an even more disturbing role. ?Basically, i was training to be a prostitute for him and his friends who shared his interest in young Epstein had trained me :'Aft ttwo t??ilsI friend?s?:Ears a to do Whatever men it started when Epstein called Virginia at the Palm wan ted . I told myself I Beach apartment he had rented for her. . was spec I al She recalls: ?He said, ?We got a good friend and I need you to fly to the island to entertain him, massage him and make him feel how you make me feel.? He didn?t spell out what had to do. He didn?t have to. ?He?d trained me to do whatever a man wanted. I was shocked but told myself he was sharing me around because he trusted me and was special. I was worried, but i would do anything to keep Jeffrey happy and to keep my place as his number one girl. He would keep telling me how lucky was with the life i was leading and the money I was making. It was easy to fall into his grasp. ?The way it usually worked was I'd be sent to meet a man on the private island Jeffrey owned in the Caribbean, or at his ranch in New Mexico, which was really isolated.? She was ?given? to men ranging in age from their 405 to their 60s. They included a well-known businessman (whose pregnant wife was asleep in the next room). a world-renowned scientist, a respected liberal politician and a foreign head of state. None appeared to think the arrangement was unusual. Virginia says there were many other girls in Epstein?s circle and that she was paid extra money to help recruit them. ?They would lounge around the Palm Beach house, the ranch or the island, nude or topless,? she says. ?But was one of the very few he trusted as "special" and chosen to "entertain? his friends.? Virginia took the sedative Xanax to detach herself from sordid reality. 'it was an escape drug,? she says. ?It made me calm and helped me forget ab0ut what eight pills a day.? Epstein had no objection to Virginia?s use of prescription drugs, no doubt recognising that they made her even more malleable. didn?t want to go back to the life I?d had before? she says. ?That made me totally obedient.? Despite the fact that Epstein was, essentially, her pimp, this life n0w seemed normal to Virginia. felt that he and Ghisiaine really cared for me,? she said. ?We?d do family things, like watch Sex And The City and eat popcorn. iot of it was very glamorous. met famous friends of his such as Al Gore and Heidi Klum and Naomi Campbell. He introduced me as his ?travelling masseuse." Some people mistook me for his daughter. ?When we were in New York or Palm Beach, Ghislaine and I would shop all day. emeairesgeerat 9 as she leaves her blouse undone across her chest during NYC outing with her children Mom-ol?four She?s almost as tall as her mom! Courtenay Cox's daughter Coco Arquette wears high heels and polka dot dress for her 12th birthday at Nobu 'lt's hard on me': Liev Schreiber talks struggle of working in LA while Naomi Watts and their two kids are in NYC as he sits down with Eilsn He misses them 'i was too big': Khloe Kardashien reveals stylists refused to work with her before she lost 40le as she wows in stunning natural shoot for Harper's Bazaar Curb Your Enthusiasm is back! Larry David's beloved comedy series will return for a ninth season The beloved HBO comedy series Super-sized diamond Her Majesty calls ?Granny's Chips? and the solitaire seed that grew into a flower: Queen's brooches and earrings have a glittering history Sporty! Channing Tatum wears a backward baseball cap and matching vest as he teaves NYC hotel The Magic Mike slar was hard to miss Rollin' and strollin'l Chilled Bobby Cannevale gets behind the wheels of baby son Rocco?s classy ride as he runs errands Star of HBO's Vinyl 5?34 Case 18-2868, Document 278, 08/09/2019, 2628230, Page7 of 648 61142016 Jeffrey bought me jeweliery - diamonds were his favourite - and wonderful furniture. He was paying me very weli because I?d give him sex whenever he wanted it.? She was, she says, deiighted when Epstein invited her to accompany him on a six-week trip in 2001. ?He said we?d be going to Europe and North Africa to meet architects and interior decorators because he wanted to redo his New Mexico house. I threw my arms around him and gave him a peck on the cheek.? They ?ew to Paris, then Spain, then Tangier. Finaliy, they went to London. 'After we ianded, we drove straight to Ghislaine?s house,? says Virginia. was given a small upstairs bedroom. The foliowing morning, Ghislaine came in. She was chirpy and jumped on the bed saying, "Get up, sleepyhead. You?ve got a big day. We've got to go shopping. You need a dress as you're going to dance with a Prince tonight." ?She said i needed to be "smileY' and bubbly because he was the Queen?s son. Ghisiaine and lwent to Burberry, where she bought me a ?5,000 bag, and to a few other designer stores where we bought a couple of dresses, a pair of embroidered jeans and a pink singlet, perfume and make-up. We got back to Ghislaine?s house at around 4pm and I ran straight upstairs to shower and dress. When I went downstairs, Ghislaine and Jeffrey were in the lounge. There was a knock at the door. Ghislaine led Andrew in and we kissed each other on the cheek. ?Ghislaine served tea from a porcelain pot and biscuits. She knew Sarah Ferguson and they talked fondly about Andrew?s daughters. Then Ghislaine asked Andrew how old he thought I was and he guessed 17 and they all laughed. Ghislaine made a joke that I was getting too old for Jeffrey. She said, ?He?ll soon have to trade her in.? It was widely known that he liked young girls.? The four of them went out to dinner and on to Tramp where, she says, Andrew danced with her. ?After about an hour?and-a-half, we drove back to Ghisiaine?s. Ail of us went upstairs and I asked Jeffrey to snap a picture of me with the Prince. I wanted something to show my Mom. Ghisiaine and Jeffrey left us after that, and later Andrew left. 'In the morning, Ghislaine said, ?You did welt. He had fun?. We ?ew straight back to the States.? The Maii on Sunday has con?rmed that the tycoon?s jet ?ew to Paris on March 6, 2001, continuing to Granada, Tangier and London, before returning to New York. On the fast leg of the trip, Virginia was paid about $15,000 (?9,400) by Epstein. ?it was amazing money, more than I?d ever made on a trip with him before. "Counseliing: Virgio Beach in 1998 He didn?t say there was any special reason, but I felt like i'd done everything he wanted. He was very pieased.? There is no suggestion that there was any sexual contact between Virginia and Andrew, or that Andrew knew that Epstein paid her to have sex with his friends. I took eight pills a day to help me forget what i had to do. It made me calm. However, the Prince must have been aware of Epstein's conviction when he stayed with him in New York in December. Virginia says she met Andrew for a second time around Easter 2001 at Epstein?s Manhattan mansion. ?When I got to the mansion, i was told, ?Get ready. You are meeting someone in the of?ce? "which is what they calied the library. Andrew was sitting there in a big ieather armchair. Ghislaine had just given him a present, a big toy that was his Spitting Image puppet. ?He was smiling ear-to-ear. He iooked like a kid whose parents were taking him to Disney World. A beautiful girl sailed Johanna Sjoberg who worked for Jeffrey was sitting on Andrew?s knee. Ghislaine guided me over to Andrew and I think he recognised me, though I don?t know if he remembered my name. Case WWI-12V smsaneageerer 9 ?l'm dating a separated married man:? Bethenny Frankel reveals she went to high school with wife of new boyfriend Dennis Shields Skinny Girl founder Get in there? Prince Harry and Zara Tindall can?t contain their excitement as they watch their horses gailop to victory at Royaf Ascot 'This isn't about you and your fake a" kiss for publicity?: Madonna is slammed for her 'self? promoting' tweets following Orlando massacre Jason Momoa's mini- met Game of Thrones hunk enjoys famiiy outing with cutie clone Nakoa?Wolf Seven?year?oid's mom is Lisa Bonet Craving a iittle Mexican! Rob Kardashian?s pregnant fiancee Biac digs into a bowl of tortiila soup during Snapchat video Another Bachelor baby! Peyton and Chris Lambton are 'thrilled? to be expecting their first chiid after four years of marriage The two wed in 2012 Lil Wayne ?guzzled three bottles of cough syrup mix lean' before suffering TWO rapper now 'stebie and in good spirits' Cowgirl chic! Alessandra Ambrosio shows off toned legs with mini skirt as the stunner goes for a denimcmdenlm took Secret Angel Madonna and Guy Ritchie on brink of deal over custody of their 15 year?old son Rocco as judge agrees to cail off showdown court hearing for more talks Gillian Anderson looks demure in sophisticated navy knee-tength dress as she attends star studded charity gala On behalf of Action on Addiction Charlie Sheen cuts a casual figure while out and about in Stockholm After becoming the new face 6?34 Case 18-2868, Document 278, 08/09/2019, 2628230, Page8 of 648 . alne Maxwell looks on as Andrewputhisarm around Virginia. Robert Maxwell?s daughter invited her to work as Epstein's personai masseuse soon after her 15th birthday Case . misled 9* We kissed on the cheek and Ghislaine placed me on his other knee.? Johanna spoke to The Mail on Sunday three years ago about this incident, which took piace when she was 21. She said: 'Ghisiaine put the puppets hand on Virginia?s breast, then Andrew put his hand on my breast. It was a greatjoke. Everybody laughed.? After this, Virginia was paid, by Epstein, around $400 She met Andrew forthe third and final time on Epstein?s Caribbean island, Little Saint James. Virginia was never under the British legal age of consent when she met Andrew. She was 17 during the ?rst two encounters and 18 at the third. By now, however, Epstein, had started to hint that she was getting ?too old? for him. But during one trip to the island, Epstein and Ghisiaine made their most astonishing proposition, and one which repulsed her. ?They said Jeffrey wanted me to have his child,? she says. ?They said I was part of their family and I was beautiful,young, loyal and nurturing and would be a great mother. They said i would have to sign a contract relinquishing rights to the chiid and consenting to Jeffrey having as many relationships as he liked. in return i would have my own mansion in Palm Beach and a large payment, a percentage of his income.? This, ?naliy, was a wake-up coil to Virginia and she began to see the way in which she had been groomed. ?it was a smack in the face,? she says. ?i ?nally realised this wasn?t ever going to be a real relationship but i knew if! refused, I'd be thrown back on the streets. So I said, "I'm too young. i want to get my massage credentials, then maybe we'li do it": The tycoon took her at her word and, for her 19th birthday in August 2002, flew her to Thaiiand where he enrolled her in a massage course. Shortly after arriving there, she met an Australian martial arts expert caiied Robert. They fell in love and, just ten days later, married in a Buddhist ceremony. ?l cailed Jeffrey and tofd him I?d fallen madly in love,? Virginia says. was hoping he?d be delighted. But he said, ?Have a nice life,? and hung up on me.? The couple now have two sons, aged ?ve and four, and a daughter who recently turned one. ?The ?rst few months after I married Robert were the worst,? she says. couldn?t bring myself to teil him much. No man wants to know his wife has been traded out. felt very alone. i was having panic attacks and seeing a and was on anti-depressants. Virginia was beginning to put her Epstein days behind her when, three years ago, she was phoned by the FBI. of condom brand Lelo Hex Wave goodbye to the rain! The deluge FINALLY stops as the Queen arrives at Ascot with and Harry after thousands of racegoers got drenched Two nations standing together: Wills and Kate sign book of condoience to pay their respects to the victims of Orlando ktlier Paying respects Time for an upgrade? David Arquette lists his historic Los Angeles mansion for $8.5m Selling Hancock Park seven-bedroom home which he bought in 2014 She's her own best adverti Jessica Alba's tresses glint in the sun as she promotes her Honest Company's new hair care range in New York Katharine McPhee ?ashes a hint of sideboob in a piunging unbuttoned black dress as she poses at the Monte Carlo Television Festive! Let the trading begin! Independence Day's Llam Hemsworth and Vivica A. Fox ring the NASDAQ bell and help celebrate the Army's birthday in NYC Ava Sambora puts on an eye-popping display for sizzling photo shoot as she parades her enviable bikini bed in Malibu Daughter of rocker Richie Sambora How does Adele make YOU feel? Sad songs provide 'enjoyment, comfort or pain to different people' Great comfort frOm seemingly sad songs Daisy Lowe and rumored beyfriend Darius Campbell appear in high spirits as they leave star-studded charity event She is 27 Sir Paui McCartney leads tributes as Wings guitarist Henry 7/34 Case 18-2868, Document 278, 08/09/2019, 2628230, Page9 of 648 61142016 ?They said they had found photos of me at Jeffrey?s Palm Beach house.? she says. ?[Epstein had] hidden cameras watching me the entire time even when I was in the bathroom. I was so embarrassed. ?l told the FBI that my true purpose was sexual. They told me everything he did was illegal because I was under age.? (The age of consent in Florida is 18). ?They said that if it had to go to trial, theYd need me because I'd lived with him and that made me a key witness. was very afraid, because he had so much power, but eventually I agreed to testify. I was glad he?d ?nally been found out. He shouldn?t be hurting other girls. Following Epstein?s arrest, investigators are believed to have found a list of men's names on his computer and asked him whether they had been 'treated? to Sexual encounters with his menage of minors. Conviction: Jeffrey Epstein ?He took the Fifth Amendment, refusing to answer, indicating that if he were to answer the question, it could be incriminating,? a source told The Mail on Sunday. Epstein struck a deai resulting in what commentators characterised as a ?slap on the wrist' for him, and ended up sewing 13 months of his sentence, much of it in a liberal work-release programme Lawyer Brad Edwards, who represented several of Epstein?s victims, said: ?Rather than punish him the way they would an average Joe, they sent a clear message that with enough money and power and in?uence, the system an be bought.? Virginia was spared her the of having to go before a jury, and has kept her feelings bottled up until last weekend?s photograph of Andrewwith Epstein triggered distressing memories. Virginia says: am appailed. To me, it?s saying, "We are above the law." But Jeffrey is a monster.? Last night, neither Epstein, Ghislaine Maxweli nor Prince Andrew would comment on Virginia's story. Share or comment on this article Need Business Capital? Get These Rare Historical Photos What Marcia Brady Looks Unsecured Loans in 24 hours That Will Leave You Snapcap.com Like Now Is Incredible Speechless Definition History Fanatic Case 9 McCullough who - - piayed on Live and Let Die Bond theme dies aged 72 Remembering his pet Bargain shopper! rew Barrymore sports colorful silk iacket as she loads up a trolley with knick~knacks at flea market She's a mom-of-two 'Actualiy done!? 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Lily Aldridge steps out in $1,250 designer SWEATSHIRT as she shows off slim legs in NYC Victoria's SecretAngel 8f34 Case 18-2868, Document 278, 08/09/2019, 2628230, PagelO of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Pagell of 648 6115/2016 Bill Climon and the 15-year-old 'masseuse?: I met him twice, claims Epstein's girl Daily Mail Onlins Home I U.K. Sports I U.S. Showbiz I Australia I Femail I Health I Science I Money IVideo ITravel IColumnists is. c, LE4 2:132: W?tl 2:35; Liliilts Teenage girl recruited by paedophile Jeffrey I I Epstein reveals how she twice met Bill Clinton By SHARON CH URCHER and POLLY DUNBAR FOR MAILONLINE UPDATED: 19:53 EST, 5 March 2011 24- Visw comments As a New Yorker from humble beginnings, Jeffrey Epstein played on his blue-collar credentials and enormous wealth to extend tentacles of in?uence throughout America's liberal political elite. During the outcry over the Epstein case, it emerged that another man with a notorious appetite for young women, Bill Clinton, travelled with Epstein to a number of destinations, including three times on the billionaire?s private aircraft. On one occasion, Epstein ?ew the former President, Hollywood actor and staunch Democrat Kevin Spacey and another actor friend of Mr Clinton's, Chris Tucker, to Africa, to ?discuss AIDS poiicy?. Claims. Virginia 0 arts says 3 stw: ent out' Epstein, who has donated more than ?75,000 over the years to candidates from the Democratic Party, also ?ew with Mr Clinton in November 2003 to destinations including Russia, Oslo, Hong Kong, Shanghai and Beijing. Yet Virginia Roberts stresses that she was never ?lent out' to Mr Clinton. On one occasion, she adds, Epstein did invite two young brunettes to a dinner which he gave on his Caribbean island for Mr Clinton shortly after he left of?ce. But, as far as she knows, the ex-President did not take the bait. ?l?d have been about 17 at the time,? she says. ?l ?ew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her. SHARE THIS RELATED ARTICLES ARTICLE ., FBI to reopen case . 7 Epstein?s Girl Friday 1:31 Case 18-2868, Document 278, 08/09/2019, 2628230, Pagel2 of 648 61152016 Case 11 Dead tycoon's 'She?d always wanted to ?y and Jeffrey paid for her to take lessons, and I remember she was very excited because she got her licence around the ?rst year we met. '1 used to get frightened ?ying with her but Bill had the Secret Service with him and I remember him talking about what a good job she did. 'l only ever met Bill twice but Jeffrey had told me that they were good friends. asked. ?How come?" and he laughed and said, ?He owes me some favours." Maybe he was just joking but it constantly surprised me that people with as much to lose as Bill and [Prince] Andrew weren?t more careful. ?Bill must have known about Jeffrey?s girls. There were three desks in the living area of the villa on the island. Speaking out: \?rgima, now aged 26. In her new home in Australia They were covered with pictures of Jeffrey shaking hands with famous peeple and photos of naked girls, including one of me that Jeffrey had at all his houses, lying in a hammock. We all dined together that night. Jeffrey was at the head of the table. Bill was at his left. i sat across from him. Emmy Tayler, Ghislaine?s blonde British assistant, sat at my right. ?Ghislaine was at Bill's left and at the left of Ghislaine there were two olive~skinned brunettes who'd ?own in with us from New York 'l'd never met them before. l?d say they were no older than 17, very innocent-looking. They weren?t there for me. They weren't there for Jeffrey or Ghislaine because I was there to have sex with Jeffrey on the trip. ?Maybe Jeffrey thought they would entertain Bill, but I saw no evidence that he was interested in them. He and Jeffrey and seemed to have a very good relationship. Bill was very funny. 'He made me laugh a few times. And he and Jeffrey and Ghislaine told blokey jokes and the brunettes listened politely and giggled. ?After dinner i gave Jeffrey an erotic massage. don't remember seeing Bill again on the trip but i assume Ghislaine ?ew him back.? According to prison records, when Epstein was serving his jail term, his visitors included a long- ?Bill must have known about Jeffrey's girls. There were three desks in the living area of the villa on the covered with photos of naked girls' time and highly controversial - Clinton acquaintance, Arnold Prosperi. 'In the ?nal hours of the Clinton presidency, in January 2001, Prosperi was facing three years in prison after being convicted of tax fraud. Mr Clinton commuted his sentence to house arrest. ?Clinton, Prosperi and Epstein make an odd threesome on the face of it,? says a law enforcement Was Prosperi visiting Epstein as some kind of intermediary for Bill? 'Maybe Bill wanted to know if Epstein knew anything that could embarrass him. Or did Bill commute Prosperi's sentence as some kind of favour for Epstein?? Virginia disclosed that Mr Clinton?s vice-president Al Gore and his wife. Tipper. were also guests of Epstein on his island. . . 5 against sex offender . .. i friend of Cambridge can?t contain her excitement as her horse wins at Royal Ascot races Whooped and cheered Brown Simpson have an affair with OJ's best friend Marcus Allen and OJ 'threatened to kill her if she saw him one month before her death' ?l've been doing him forever:' Awkward moment Sonja Morgan discovers Luann de Lesseps' ?soul mate? is her old 'hook up' Thomas D?Agostino She really iS a lady in waiting! Amelia Windsor Taller's most beautiful royal swaps high glamour for WAITRESSING as she helps out at a launch New beau? Ashley Olsen, 30, is romantically linked to artist George Condo, 59 after they are spotted 'looking romantlc' et NYC's Mercer Hotel Dad bod! Adam Sandler, 49, shows off his naked chest while wrapped in towel during Miami vacation with his wife of 13 years Couple looked blissful Kim Kardashien?s naked ambition is laid here again as she strips off to celebrate her post- baby body with 60 cover Gave birth in December Kake?gate! Kim Kardashian tries to cheat on family cake makers Hansen's by asking her followers for new bakery recommendations 'lworked my a? offi': Kim Kardashian spills secrets to losing 60lbs after pregnancy as she admits 6am sessions and "militant diet? did trick Advertisement .html 2131 Case 18-2868, Document 278, 08/09/2019, 2628230, Page13 of 848 6115/2016 a aFP?etiy images Guests: Virginia says she also met former Vice President Al Gore. pictured right with Mr Clinton Last summer, the Gores abruptly announced that they were ending their supposedly fairytale marriage and, just weeks later, it emerged that Mr Gore the famously sanctimonious global- warming disciple had been accused of trying to force sex on a woman with whom he had booked a therapeutic massage at an Oregon hotel. had no clue that anything was up,? Virginia says. ?The Gores seemed like a beautiful couple when I met them. All I knew was that Mr Gore was a friend of Jeffrey?s and Ghisiaine's. Jeffrey didn?t ask me to give him a massage. There might have been a couple of other girls there on that trip but could never have imagined this guy would do anything wrong. was planning to vote for him when I turned 18. i thought he was awesome.? Virginia said that yet another American liberal icon, President Obama?s Middle East peace envoy Senator George Mitchell, frequently visited Epstein?s New York residence. Mr Mitchell, aged 77 - who previously led America?s Northern Ireland peace initiative ?was very close to Jeffrey,? Virginia recalled. ?He is very clean-cut. You wouldn?t think of him being part of Jeffrey?s crew.? 7% Elm Scandal: U.S. authorities want to interview Jeffrey Epstein (left) and may wish to quiz his friend, Prince Andrew Epstein's contacts book contains a work and a home telephone number for the senator. Another acquaintance was Israel defence secretary Ehud Barak, whose spokesman told The Mail on Sunday: 'Mr Barak did attend several small functions in Mr Epstein?s home in New York that were usuaily attended by leading businessman, university presidents, Nobel Prize Laureates and prominent public figures.? . Case 1215999W?M??mm13m13im @?iblr?la?l 5 'We iust want them to have a normal life': Blake Lively reveals her parenthood plans now that baby no.2 is on its way and why she fell in love with Ryan Reynolds Back to work! Miley Cyrus and Liam Hemsworth temporarily go their separate after very public dinner date in NYC Ivanka Trump shares morning snap of baby Theo watching her get ready as she admits in that she wakes up at 5:30am and goes to work with her hair wet they could be sisters! Princess Mary of Denmark and Duchess of Cambridge look strikingly similar as they enjoy a catch up at Royal Ascot Brooke Shields' stalker walking into court with trial entering third day after judge hears actress?s tearful testimony about man coming to her home Mixing business with pleasure? Bodysuit-clad EJ Johnson gets in some retail therapy before filming his yet?to- air New York reality show Seth Myers 'hans' Trump from appearing on NBC's Late Night 3131 Case 18-2868, Document 278, 08/09/2019, 2628230, Pagel4 of 648 6/15/2016 Epstein's many Hollywood pals include Matt Groening, creator of The Simpsons. ?Jeffrey once had me give Matt a foot massage when he was ?ying on the jet with us,? Virginia says. ?He laughed and did drawings of Bart and Homer for my little brother and my dad. ?l also met Naomi Campbell at a birthday party of hers on a yacht in the South of France. She is a friend of Ghislaine's but she was a reef bitch to me. 'She was very fake. She turned away from me when we were introduced by Ghislaine and Jeffrey. ?Donald Trump was aiso a good friend of Jeffreys. He didn?t partake in sex with any of us but he ?irted with me. He'd laugh and tell Jeffrey, ?You?ve got the iife."? Palm Beach Police say Epstein seemed utterly unfazed by the allegations against him when they began their long and detailed investigation. @37- iJeffrey?s crew: Middle East peace envoy George Mitchell, right, pictured with President Barack Obama and US. Secretary of State Hiiary Clinton, frequently visited Epsteings New York residence, Virginia also claims But he also took his defence very seriously indeed. Epstein engaged his friend, the Harvard law professor Alan Dershowitz? whose celebrity clients have inciuded Mike Tyson, Patty Hearst, Claus von Buiow and OJ. Simpson to run his legal defence. He also employed a ?rm of private investigators to investigate the backgrounds of the girfs. Detectives painstakingly built a case which they believed showed that Epstein Systematimlly paid teenage girls to recmit other teenage girls to his sex ring. However, as the investigation continued, they found that Epstein's team had already spoken to key witnesses, suggesting that the ?nancier would reward those who helped him. In addition, Epstein?s defence team agreed to the unusual move of suggesting that the alleged victims sue Epstein in the civil courts. The result was a plea bargain in which Epstein admitted a single charge of soliciting an underage girl for prostitution a deal which infuriated many police officers who worked on the case. More than 20 of Epstein?s girls are said to have sued him for damages. At least 17 have settled out of court. Mr Ciinton, Mr Gore and Mr Mitchell were all contacted about their friendship with Epstein but destined to comment. Share or comment on this article Case 9% 5 Show - but admits the presidential hopeful wasn't going to come on anyway Yolanda Hadid cans" Real Housewives of Beverly Hiils to ?bring back privacy' to her iife after dramatic season that documented her divorce and accusations she was faking illness Victoria Beckham shows a hint of sideboob and ?ash of ieg as she flaunts her sartoriai sass for cover of Vogue Korea Striking shoot A mellow day! .Rumer Willis dresses down in a grey maxi dress as she hangs outwith a friend in West Hollywood Taking a break from the presidential campaign Catherine Zeta?Jones' daughter Carys is her doppeiganger as the pair arrive in London with Michael Douglas and son Dylan Family trip Stephen Colbert compares Trump to a as he draws a swastika on chalkboard while trying to ?figure out' Obama?s response to Orlando massacre Grieving Adam Levine is pictured piaying golf in first outing since Christina Grimmie's after offering to pay for the Voice star?s funeral Does North West have her own glam squad? Kim Kardashian 'hires daughter $5k a week team including and manicurist' The smiie's back! Demi Lovato appears happy at airport while looking chic in oiive coat as she recovers from Wiimer Vaiderrama shock split Wore classic combo ?i'm not killing off Harrison Ford': Steven Spielberg reveals he won't and indiana Jones' life in next film as he gives rare interview Good news for Ford! ns?girl .htmi Case 18-2868, Document 278, 08/09/2019, 2628230, Page15 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page16 of 648 PR Hub Breaking News 1 Entertainment I Sports Business I Politics I Science I Technology I Odd News I Health I Law Maxwell BY i?i?t?Nii MARCH 0. at.) I LONDON, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. It is unacceptable that letters sent by Ms Maxwell?s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers. understand newspapers need stories to sell copies It is well known that certain newspapers live by the adage, "why let the truth get in the way of a good story." However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop," said Ghislaine Maxwell. number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name," she said. Media contact: Ross Gow Acuity Reputation Tel; +44-203-008-7790 Mob: +44?7778-755-251 Email ross@acuityreputation . com Media contact: Ross Gow, Acuity Reputation, Tel: +44-2 03- 00 8-7790, Mob: ross at acuityreputation.com ?lled under: Government and Poiicy, 121w, Media 'l'ags: Devonshires Solicitors, London, March 10, United Kingdom MARCH 10 Share this Subscribe by page More Older News .. . 272812345 6789101112 GOVERNMENT AND POLICY NEWS CSA Group Selects Frankfurt, Germany for The First International Gateway to Africa Conference in Geneva: Africa's - Challenges Today and Tomorrow Central Saint Martins and Method launch Accelerator to Drive Innovation and Support UK Economic Growth North East Linoolnshire Council EmployeesSzapOS; Ideas Win Votes 7 _7 NEWS . Tech Mahindra Opensa 7 new European Headquarters .. i new Development Centre in Bonn, 7.7 Germany I W'ebsite Optimisation -. and Internet Marketing From eblinx Sir Paul McCartney Supports BUAV Campaign to end Cruel EXHIBIT 2b AGHEN BLANDO REPORTING 5/2: GIUFFRE001067 Case 18-2868, Document 278, 08/09/2019, 2628230, Page17 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Pagel8 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 1 mm UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-MarralJohnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #3 AND JANE DOE #4?8 CORRECTED MOTION PURSUANT TO RULE 21 FOR JOINDER IN ACTION COME NOW Jane Doc #3 and Jane Doc #4 (also referred to as ?the new victims?), by and through undersigned counsel, to ?le this motion pursuant to Federal Rule of Civil Procedure 21 to join this action, on the condition that they not re-litigate any issues already litigated by Jane Doe #1 and Jane Doc #2 (also referred to as ?the current victims?). The new victims have su??ered the same violations of their rights under the Crime Victims? Rights Act (CVRA) as the current victims. Accordingly, they desire to join in this action to vindicate their rights as well. Because the new victims will not re-litigate any issues previously litigated by the current victims (and because they are represented by the same legal counsel as the current victims), the Government will not be prejudiced if the Court grants the motion. The Court may ?at anytime? add new parties to the action, Fed. R. Civ. P. 21. Accordingly, the Court should grant the motion. FACTUAL BACKGROUND 1 As minor victims of sexual offenses, Jane Doc #3 and Jane Doc #4 desire to proceed by way of pseudonym for the same reasons that Jane Doe and Jane Doe #2 proceeded in this fashion. Counsel for the new victims have made their true identities known to the Government. 1 GIUFFRE 004288 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page19 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 2 of 14 As the Court is aware, more than six years ago, Jane Doc #1 ?led the present action against the Government, alleging a violation of her rights under the CVRA, 18 U.S.C. 3771. She alleged that Jeffrey Epstein had sexually abused her and that the United States had entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her rights. At the ?rst court hearing on the case, the Court allowed Jane Doc #2 to also join the action. Both Jane Doe #1 and Jane Doc #2 speci?cally argued that the government had failed to protect their CVRA rights (inter alia) to confer, to reasonable notice, and to be treated with fairness. In response, the Government argued that the CVRA rights did not apply to Jane Doe #1 and Jane Doc #2 because no federal charges had ever been ?led against Jeffrey Epstein. The Court has ?rmly rejected the United States? position. In a detailed ruling, the Court concluded that the CVRA extended rights to Jane Doc #1 and Jane Doc #2 even though federal charges were never ?led. DE 189. The Court explained that because the NPA barred prosecution of crimes committed against them by Epstein, they had ?standing? to assert violations of the CVRA rights. Id. The Court deferred ruling on whether the two victims would be entitled to relief, pending development of a ?ller evidentiary record. Id. Two other victims, who are in many respects similarly situated to the current victims, now wish to join this action. The new victims joining at this stage will not cause any delay and their joinder in this case is the most expeditious manner in which to pursue their rights. Because the background regarding their abuse is relevant to the Court?s assessment of whether to allow them to join, their circumstances are recounted here briefly. Jane Doe #3?5 Circumstances GIUFFRE 004289 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page20 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 3 of 14 As with Jane Doc #1 and ane Doe Jane Doc #3 was repeatedly sexually abused by Epstein. The Government then concealed ?'om Jane Doc #3 the existence of its NPA from Jane Doe in violation of her rights under the CVRA. If allowed to join this action, Jane Doc #3 would prove the following: In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator in his sexual abuse and sex traf?cking scheme. In fact, it became known to the government that Maxwell herself regularly participated in Epstein?s sexual exploitation of minors, including Jane Doe Maxwell persuaded Jane Doe #3 (who was then ?fteen years old) to come to Epstein?s mansion in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children (including Jane Doc #1 and Jane Doc When Jane Doe #3 began giving Epstein a ?massage,? Epstein and Maxwell turned it into a sexual encounter, as they had done with many other victims. Epstein then became enamored with Jane Doc and with the assistance of Maxwell converted her into what is commonly referred to as a ?sex slave." Epstein kept Jane Doc #3 as his sex slave from about 1999 through 2002, when she managed to escape to a foreign country and hide out ?'om Epstein and his ace-conspirators for years. From 1999 through 2002, Epstein frequently sexually abused Jane Doc not only in West Palm Beach, but also in New York, New Mexico, the U.S. Virgin Islands, in international airspace on his Epstein?s private planes, and elsewhere. Epstein also sexually traf?cked the then-minor Jane Doe, making her available for sex to politically-connected and ?nancially-powerful people. Epstein?s purposes in ?lending? Jane Doe (along with other young girls) to such power?il people were to ingratiate himself with them for 3 GIUFFRE 004290 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page2l of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 4 of 14 business, persona], political, and ?nancial gain, as well as to obtain potential blackmail information. One such individual that Epstein forced then?minor Jane Doc #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein?s and well-known criminal defense attorney. Epstein required Jane Doc #3 to have sexual relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but also on private planes, in New York, New Mexico, and the US. Virgin Islands. In addition to being a participant in the abuse of Jane Doc #3 and other minors, Deshowitz was an eye-witness to the sexual abuse of many other minors by Epstein and several of Epstein?s co-conspirators. Dershowitz would later play a signi?cant role in negotiating the NPA on Epstein?s behalf. Indeed, Dershowitz helped negotiate an agreement that provided immunity from federal prosecution in the Southern District of Florida not only to Epstein, but also to ?any potential co- conspirators of Epstein.? NPA at 5. Thus, Dershowitz helped negotiate an agreement with a provision that provided protection for himself against criminal prosecution in Florida for sexually abusing Jane Doc Because this broad immunity would have been controversial if disclosed, Dershowitz (along with other members of Epstein?s defense team) and the Government tried to keep the immunity provision secret from all of Epstein?s victims and the general public, even though such secrecy violated the Crime Victims? Rights Act. Ghislaine Maxwell was another person in Epstein?s inner circle and a co-conspirator in Epstein?s sexual abuse. She was someone who consequently also appreciated the immunity granted by the NPA for the crimes she committed in Florida. In addition to participating in the sexual abuse of Jane Doc #3 and others, Maxwell also took numerous sexually explicit pictures 4 GIUFFRE 004291 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page22 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 5 of 14 of underage girls involved in sexual activities, including Jane Doc She shared these photographs (which constituted child pornography under applicable federal laws) with Epstein. The Government is apparently aware of, and in certain instances possesses some of these photographs. Perhaps even more important to her role in Epstein?s sexual abuse ring, Maxwell had direct connections to other powerful individuals with whom she could connect Epstein. For instance, one such power?il individual Epstein forced Jane Doc #3 to have sexual relations with was a member of the British Royal Family, Prince Andrew (a/k/a Duke of York). Jane Doc #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 instructed Jane Doc #3 that she was to give the Prince whatever he demanded and required Jane Doc #3 to report back to him on the details of the sexual abuse. Maxwell facilitated Prince Andrew?s acts of sexual abuse by acting as a ?madame? for Epstein, thereby assisting in internationally traf?cking Jane Doc #3 (and numerous other young girls) for sexual purposes. Another person in Epstein?s inner circle of friends (who becomes apparent with almost no investigative effort) is Jean Luc Brunei. Epstein sexually traf?cked Jane Doc #3 to Jean Luc Brunei many times. Brunei was another of Epstein?s closest ?'iends and a regular traveling companion, who had many contacts with young girls throughout the world. Brunei has been a model scout for various modeling agencies for many years and apparently was able to get U.S. passports for young girls to ?work? as models. He would bring young girls (ranging to ages as 5 GIUFFRE 004292 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page23 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 6 of 14 young as twelve) to the United States for sexual purposes and farm them out to his ?'iends, especially Epstein. Brunel would offer the girls ?modeling? jobs. Many of the girls came from poor countries or impoverished backgrounds, and he lured them in with a promise of making good money. Epstein forced Jane Doe #3 to observe him, Brunel and Maxwell engage in illegal sexual acts with dozens of underage girls. Epstein also forced Jane Doc #3 to have sex with Brunel on numerous occasions, at places including Epstein?s mansion in West Palm Beach, Little St. James Island in the US. Virgin Islands (many including orgies that were comprised of other underage girls), New York City, New Mexico, Paris, the south of France, and California. Epstein also traf?cked Jane Doc #3 for sexual purposes to many other power?il men, including numerous prominent American politicians, power?il business executives, foreign presidents, a well-known Prime Minister, and other world leaders. Epstein required Jane Doc #3 to describe the events that she had with these men so that he could potentially blackmail them. The Government was well aware of Jane Doc #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the NPA. Moreover, even a rudimentary investigation of Jane Doe #3?5 relationship to Epstein would have revealed the fact that she had been traf?cked throughout the United States and internationally for sexual purposes. Nonetheless, the Government secretly negotiated a non-prosecution agreement with Epstein precluding any Federal prosecution in the Southern District of Florida of Epstein and his co-conspirators. As with Jane Doc and Jane Doe the Government concealed the non-prosecution agreement from Jane Doe #3 all in violation of her rights under the CVRA to avoid Jane Doc #3 from raising powerful objections to the NPA that would have shed tremendous public light on Epstein 004293 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page24 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 7 of 14 and other powerful individuals and that would likely have been prevented it from being concluded in the secretive manner in which it was. Jane Doe #4?3 Circumstances If permitted to join this action, Jane Doc #4 would allege, and could prove at trial, that she has CVRA claims similar to those advanced by Jane Doc #1 and Jane Doe based on the following: As with the other Jane Does, Jane Doc #4 was repeatedly sexually abused by Epstein. In or around the summer of 2002, Jane Doe an economically poor and vulnerable sixteen-year- old child, was told by another one of Epstein?s underage minor sex abuse victims, that she could make $300 cash by giving an old man a massage on Palm Beach. An acquaintance of Jane Doc #4 (also a minor sexual abuse victim of Epstein) telephoned Epstein and scheduled Jane Doc #4 to go to Epstein?s house to give him a massage. During that call, Epstein. himself got on the phone (a means of interstate communication) with Jane Doe asking her personally to come to his mansion in Palm Beach. Jane Doe #4 then went to Epstein?s mansion and was escorted upstairs to Epstein?s large bathroom by one of Epstein?s assistants. Shortly therea?er Jeffrey Epstein emerged and lay face down on the table and told Jane Doe #4 to start massaging him. Epstein asked Jane Doc #3 her age and she told him she had recently turned sixteen. Epstein subsequently committed illegal sexual acts against Jane Doe #4 on many occasions. Epstein used a means of interstate communication a cell phone) to arrange for these sexual encounters. Epstein also frequently travelled in interstate commerce on his personal jet) for purposes of illegally sexually abusing Jane Doe 7 GIUFFRE 004294 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page25 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 8 of 14 The acts Epstein committed against Jane Doe constituted numerous federal sex offenses, some of which do not carry a statute of limitations and thus are not time-barred. See 18 U.S.C. 3283. And. these offenses were the kinds of offenses that the Federal Bureau of Investigation (FBI) and U.S. Attomey?s Of?ce for the Southern District of Florida were pursuing in 2007. So far as Jane Doc #4 is aware, the U.S. Attorney?s Of?ce made no serious effort to locate her. Instead, after identifying approximately forty separate underage sexually abused victims, and apparently preparing a 53-page federal indictment and with full awareness of the existence of many victims like Jane Doe #4 unidenti?ed and not interviewed it entered into a non-prosecution agreement barring prosecution of Bpstein?s federal crimes against these victims. This is contrary to the Government?s normal approach in prosecuting federal sex offenses. It also violated Jane Doe #4?5 rights under the CVRA, including the fact that she had a ?reasonable? right to confer with the U.S. Attorney?s Of?ce before they entered into an agreement with a sex offender barring prosecution of him for the crimes he committed against her. 18 U.S.C. 3771(a)(5). MOTION FOR OINDER Jane Doe #3 and Jane Doc #4 now both move to join this action ?led by Jane Doc #1 and Jane Doe pursuant to Rule 21 of the Federal Rules of Civil Procedure. Rule 21 provides that motion or on its own, the court may at any time, on just terms, add . . . a party.? Rule 21 ?grants the court broad discretion to permit a change in the parties at any stage of a litigation.? Ford v. Air Line Pilots Ass ?n 268 F. Supp. 2d 271, 295 (E.D.N.Y. 2003) (internal quotation omitted). The new victims should be allowed to join the current victims in this action under Rule 21. GIUFFRE 004295 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page26 of 648 Case 9:08vcv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 9 of 14 The new victims will establish at trial that the Government violated their CVRA rights in the same way as it violated the rights of the other victims. The new victims? participation in this case is important because it appears that the Government intends to raise a factual defense that somehow it did keep Jane Doe #1 and Jane Doc #2 properly informed of what was happening in the criminal prosecution. Of course, if four victims all testify consistently that they were not prOperly informed by the Government (as we believe they will), that provides a stronger case for a CVRA violation. In addition, Jane Doe #3 and Jane Doe #4?5 participation is relevant to a defense the Court has allowed the Government to raise. The Court has previously ruled that the victims? request for rescission of the NPA ?implicates a fact-sensitive equitable defense which must be considered in the historical factual context of the entire interface between Epstein, the relevant prosecutorial authorities and the federal offense victims including an assessment of the allegation of a deliberate conspiracy between Epstein and federal prosecutors to keep the victims in the dark on the pendency of negotiations between Epstein and federal authorities until well after the fact and presentation of the non-prosecution agreement to them as afar?t accompli.? DE 189 at 12 n.6 (emphasis added). Jane Doe #3?5 and Jane Doe #4?5 participation in this case will help to show what the ?entire interface? was between the Government and the victims and thus to respond to the Government?s estoppel arguments as well as other defenses that it appears to be preparing to raise. See, DE 62 (52-page response ?-om the Government to the victim?s summary judgment motion, raising numerous factually-based and other arguments against the victim?s position). GIUFFRE 004296 Case 18-2868, Document 278, 08/09/2019, 2628230, Page27 of 648 Case Document 280 Entered on FLSD Docket 0110212015 Page 10 of 14 Jane Doe #3?s and Jane Doe #4?s participation is also directly relevant to the discovery disputes currently pending in this case. The Government has raised various relevancy objections to the documents that Jane Doc #1 and Jane Doc #2 are attempting to obtain. The current victims have responded by explaining how these documents are relevant, including explaining how these documents might hear on the way in which Epstein used his powerful political and social connections to secure a favorable plea deal, as well as provide proof of the Government?s motive to deliberately fail to investigate certain aspects of the victims? claims in an effort to maintain the secrecy of the facts and resolve the case without the victims? knowledge. See, DE 266 at 6-10. Jane Doc #3 and Jane Doe #4?s participation will help prove the relevancy of these requests, as well as the need for those requests. One clear example is Request for Production No. 8, which seeks documents regarding Epstein?s lobbying efforts to persuade the Government to give him a more favorable plea arrangement and/or non-prosecution agreement, including efforts on his behalf by Prince Andrew and former Harvard Law Professor Alan Dershowitz. Jane Doc #1 and Jane Doe #2 have alleged these materials are needed to prove their allegations that, after Epstein signed the non-prosecution agreement, his performance was delayed while he used his signi?cant social and political connections to lobby the Justice Department to obtain a more favorable plea deal. See, DE 225 at 7-8 (discussing DE 48 at 16-18). Jane Doc #3 has directly person knowledge of Epstein?s connection with some of these powerful people and thus how Epstein might have used them to secure favorable treatment. Adding two new victims to this case will not delay any of the proceedings. They will simply join in motions that the current victims were going to ?le in any event. For example, the 10 004297 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page28 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 11 of 14 new victims will simply join in a single summary judgment motion that the current victims anticipate ?ling after discovery has been completed. Nor will adding the new victims prejudice the United States. As the court is aware, this Court is still in its initial discovery stage. The Court is currently considering whether to reject the Government?s assertion of privilege over documents regarding the case. See DE 265 (victims? reassertion of objections to the Government privilege claims). The new victims do not seek any additional discovery beyond that previously sought by the current victims.2 Accordingly, the United States will not be prejudiced or burdened by adding them to this case. The CVRA does not contain any statute of limitations for ?ling an action to enforce rights under the statute. Accordingly, were the Court to deny this motion, the result might be that the new victims would then be forced to ?le a separate suit raising their claims, which would then possibly proceed on a separate litigation track. Rather than require duplicative litigation, the Court should simply grant their motion to join. Jane Doc #1 and Jane Doc #2 support the joinder motion. Counsel for the victims have discussed this motion with the Government at length in an effort to avoid any need to ?le a substantive pleading on the issue. Counsel for the victims asked the Government during the summer for its position on joinder. The Government, however, took the matter under advisement for months. Ultimately, after several inquiries from victims counsel, the Government indicated without explanation that it opposes this motion. Counsel for the victims has requested a meeting with the Government on this issue, which will hopefully occur in 2 Jane Doe #3 and Jane Doc #4 have asked the Government to provide them with the record of their statements that they provided to the FBI. These FBI 302?s should be only a few pages long. 1 004298 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page29 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 12 of 14 January. In the meantime, however, counsel for the victims believe that it is no longer appropriate to delay ?ling this motion and accordingly ?le it at this time. Because the Government is apparently opposing this motion, Jane Doe #3 and Jane Doc #4 have described the circumstances surrounding their claims so that the Court has appropriate information to rule on the motion. 12 GIUFFRE 004299 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page30 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 13 of 14 Jane Doe #3 and Jane Doe #4 should be allowed to join this action, pursuant to Rule 21 of the Federal Rules of Civil Procedure. Their joinder should be conditioned on the requirement that they not re-litigate any issues previously litigated by Jane Doe #1 and Jane Doe A proposed order to that effect is attached to this pleading. DATED: Januarv 2. 2015 Respect?illy Submitted, ls/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS LEHRMAN, PL. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mail: brad@pathtojustice.corn And Paul G. Cassell Pro Hac Vice SJ. Quinney College of Law at the University of Utah? 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585?5202 Facsimile: 801-585-6833 E-Mail: casselln@law.utah.edu Attorneys for Jane Doe #1 and Jane Doe #2 This daytime business address is provided for identi?cation and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah GIU FF RE 004300 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page31 of 648 Case Document 280 Entered on FLSD Docket 01/02/2015 Page 14 of 14 CERTIFICATE OF SERVICE I certify that the foregoing document was served on January 2, 2015, on the following using the Court?s system: Dexter Lee A. Marie Villafa?a 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: Dexter.Lee@usdoj .gov E-mail: Attorneys ?r the Government Bradley J. Edwards 14 GIUFFRE 004301 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page32 of 648 EXHIBIT Case aeamcaamas??w. mm as oemeraalaa Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. ORDER DENYING MOTION TO JOIN UNDER RULE 21 AND MOTION TO AMEND UNDER RULE 15 This cause is before the Court on Jane Doe 3 and Jane Doe 4?s Corrected Motion Pursuant to Rule 21 for oinder in Action (?Rule 21 Motion?) (DE 280), and Jane Doe 1 and Jane Doe 2?s Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners (?Rule 15 Motion?) (DE 311). Both motions are ripe for review. For the following reasons, the Court concludes that they should be denied. 1. Background This is an action by two unnamed petitioners, Jane Doe 1 and Jane Doe 2, seeking to prosecute a claim under the Crime Victims? Rights Act (CVRA), 18 U.S.C. 3771. (DE 1). Generally, they allege that the respondent Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein, who subjected them to various sexual crimes while they were minors. Petitioners initiated this action in July 2008. Case seawevlemssx??m mm are. Page 2 in On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280). Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. at 11). Jane Doe 3 and Jane Doe 4 argue that they ?have suffered the same violations of their rights under the as the? Petitioners, and they ?desire to join in this action to vindicate their rights as well.? (Id at 1). The Government vehemently opposes joinder under Rule 21. (DE 290). The Government argues that Rule 15 is the proper procedural device for adding parties to an action, not Rule 21. (Id. at 1). ?[O]ut of an abundance of caution,? Petitioners ?led a motion to amend their petition under Rule 15, conforming the petition to the evidence and adding Jane Doe 3 and Jane Doe 4 as petitioners. (DE 311 at 2). The Government opposes the Rule 15 Motion as well. (DE 314). Among other things, the Government argues that amending the petition to include Jane Doe 3 and Jane Doe 4 should be denied because of their undue delay in seeking to join the proceedings, and the undue prejudice that amendment will cause. After considering the parties? submissions and the proposed amended petition, the Court ?nds that justice does not require amendment in this instance and exercises its discretion to deny the amendment. 11. Discussion ?The decision whether to grant leave to amend a complaint is within the sole discretion of the district court.? Laurie v. Ala. Ct. Crim. Apps, 256 F.3d 1266, 1274 (11th Cir. 2001). ?The court should freely give leave when justice so requires.? Fed. R. Civ. P. Justice does not require amendment in several instances, ?includ[ing] undue delay, bad faith, dilatory motive Case aeamcaae?ss??w. WW 8728., cameraman semeecaageanaram Page a (3110 on the part of the movant, . . . undue prejudice to the opposing party by virtue of allowance of the amendment, [and] ?itility of amendment.? ILrie, 256 F.3d at 1274 (quoting Foman v. Davis, 371 US. 178, 182 (1962)). In addition to considering the effect of amendment on the parties, the court must consider ?the importance of the amendment on the proper determination of the merits ofa dispute.? 6 Wright Miller, Fed. Prac. Fed. P. 1488, p. 814 (3d ed. 2010). Justice does not require amendment where the addition of parties with duplicative claims will not materially advance the resolution of the litigation on the merits. Herring v. Delta Air Lines, Inc., 894 F.2d 1020, 1024 (9th Cir. 1989). A. Rule 21 Motion Jane Doe 3 and Jane Doe 4?s first attempt to join in this proceeding was brought under Rule 21. (DE 280). ?If parties seek to add a party under Rule 21, courts generally use the standard of Rule 15, governing amendments to pleadings, to determine whether to allow the addition.? 12 Wright Miller, Fed. Prac. Fed. P., p. 432 (3d ed. 2013); see also Galustian v. Peter, 591 F.3d 724, 729-30 (4th Cir. 2010) (collecting cases and noting that Rule 15(a) applies to amendments seeking to add parties); Frank v. US. West, Inc., 3 F.3d 1357, 1365 (10th Cir. 1993) motion to add a party is governed by Fed. R. Civ. P. 15(a) . . . Rule 21, ?Misjoinder and Non-joinder of Parties,? provides the court with a tool for correcting the ?misjoinder? of parties that would otherwise result in dismissal. Fed. R. Civ. P. 21. Insofar as Rule 21 ?relates to the addition of parties, it is intended to permit the bringing in of a person, who through inadvertence, mistake or for some other reason, had not been made a party and whose presence as a party is later found necessary or desirable.? United States v. Com. Bank of N. Am., 31 F.R.D. 133, 135 (S.D.N.Y. 1962) (internal quotation marks omitted). Case WW 8728., Oemefeale?i Page a (3110 In their Rule 21 Motion, Jane Doe 3 and Jane Doe 4 do not claim that they were omitted from this proceeding due to any ?inadvertence? or ?mistake? by Petitioners; rather, they seek to join this proceeding as parties that could have been permissively joined in the original petition under Rule 20 (?Permissive Joinder of Parties?). As courts generally use the standards of Rule 15 to evaluate such circumstances, the Court will consider the oinder issue as presented in the Rule 15 Motion.1 The Court will consider the arguments presented in the Rule 21 Motion as if they are set forth in the Rule 15 Motion as well. Because the arguments are presented in the Rule 15 Motion (and because the Court is denying the Rule 15 Motion on its merits, as discussed below), the Rule 21 Motion will be denied. The Court also concludes that portions of the Rule 21 Motion and related ?lings should be stricken from the record. Pending for this Court?s consideration is a Motion for Limited Intervention ?led by Alan M. Dershowitz, who seeks to intervene to ?strike the outrageous and impertinent allegations made against him and [to] request[] a show cause order to the attorneys that have made them.? (DE 282 at 1). The Court has considered Mr. Dershowitz?s arguments, but it ?nds that his intervention is unnecessary as Federal Rule of Civil Procedure 12(f) empowers the Court ?on its own? to ?strike from a pleading an insuf?cient defense or any redundant, immaterial, impertinent, or scandalous matter.? Fed. R. Civ. P. 12(f). Petitioners? Rule 21 Motion consists of relatively little argumentation regarding why the Court should permit them to join in this action: they argue that (1) they were sexually abused by 1 The Court notes that, regardless of which motion it considers, the same standard governs the addition of parties under Rule 21 and Rule 15. Goston v. Potter, No. 08?cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Gm., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 Case aeactiemsamw mm are. Demetaaia: steereacaegearearm Page 5 of 10 Jeffrey Epstein, and (2) the Government violated their CVRA rights by concealing the non- prosecution agreement with them. (DE 280 at 3; at 7-8). However, the bulk of the Rule 21 Motion consists of copious factual details that Jane Doe 3 and Jane Doe 4 ?would prove? allowed to join this action.? at 3, 7). Speci?cally, Jane Doe 3 proffers that she could prove the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein sexually traf?cked her to several high-pro?le non?party individuals, ?including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.? (Id. at 3-6). She names several individuals, and she offers details about the type of sex acts performed and where they took place. (S_ee at 5).2 At this juncture in the proceedings, these lurid details are unnecessary to the determination of whether Jane Doe 3 and Jane Doe 4 should be permitted to join Petitioners? claim that the Government violated their rights under the CVRA. The factual details regarding with whom and where the Jane Does engaged in sexual activities are immaterial and impertinent to this central claim that they were known victims of Mr. Epstein and the Government owed them CVRA duties), especially considering that these details involve non?parties who are not related to the respondent Government. These unnecessary details shall be stricken. The original Rule 21 Motion (DE 279) shall be stricken in its entirety, as it is wholly superseded by the ?corrected? version of the Rule 21 Motion (DE 280). From the corrected Rule 21 Motion, the Court shall strike all factual details regarding Jane Doe 3 between the following sentences: ?The Government then concealed from Jane Doe #3 the existence of its NPA from 2 Jane Doe 4?s proffer is limited to sexual acts between Mr. Epstein and herself. (E DE 280 at 7-8). Case acactiemsa??w. Warrant am O?matgale?i Page a of 10 Jane Doe in violation of her rights under the (Q at and ?The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the (i at 6). As none of Jane Doe 4?s factual details relate to non-parties, the Court ?nds it unnecessary to strike the portion of the Rule 21 Motion related to her circumstances. Regarding the Declaration in support of Petitioners? response to Mr. Dershowitz?s motion to intervene (DE 291-1), the Court shall strike paragraphs through 53, and 59, as they contain impertinent details regarding non-parties. Regarding the Declaration of Jane Doe 3 in support of the Rule 21 Motion (DE 310-1), the Court shall strike paragraphs 7 through 12, 16, 39, and 49, as they contain impertinent details regarding non- parties. Jane Doe 3 is free to reassert these factual details through proper evidentiary proof, should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a matter presented for the Court?s consideration. As mentioned, Mr. Dershowitz moves to intervene ?for the limited purposes of moving to strike the outrageous and impertinent allegations made against him and requesting a show cause order to the attorneys that have made them.? (DE 282 at 1). As the Court has taken it upon itself to strike the impertinent factual details from the Rule 21 Motion and related ?lings, the Court concludes that Mr. Derschowitz?s intervention in this case is unnecessary. Accordingly, his motion to intervene will be denied as moot.3 Regarding whether a show cause order should 3 This also moots Mr. Dershowitz?s Motion for Leave to File Supplemental Reply in Support of Motion for Limited Intervention. (DE 317). Denying Mr. Dershowitz?s motion to intervene also renders moot Petitioners? motion (DE 292) to ?le a sealed document supporting its response to Mr. Dershowitz?s motion. It will accordingly be denied as moot, and DE 293 (the sealed response) will be stricken from the record. Case aoawcvlaea?sax??m mm eeweamgeamwam Page 7 of in issue, the Court ?nds that its action of striking the lurid details from Petitioners? submissions is sanction enough. However, the Court cautions that all counsel are subject to Rule 11?s mandate that all submissions be presented for a proper purpose and factual contentions have evidentiary support, Fed. R. Civ. P. 11(b)(1) and (3), and that the Court may, on its own, strike from any pleading ?any redundant, immaterial, impertinent, or scandalous matter,? Fed. R. Civ. P. 12(f). B. Rule 15 Motion Between their two motions (the Rule 21 Motion and Rule 15 Motion), Jane Doe 3 and Jane Doe 4 assert that ?they desire to join in this action to vindicate their rights [under the as well.? (DE 280 at 1). Although Petitioners already seek the invalidation of Mr. Epstein?s non-prosecution agreement on behalf of all ?other similarly?situated victims12, 15, 18-19), Jane Doe 3 and Jane Doe 4 argue that they should be fellow travelers in this pursuit, lest they ?be forced to file a separate suit raising their claims? resulting in ?duplicative litigation? (DE 280 at 11). The Court ?nds that justice does not require adding new parties this late in the proceedings who will raise claims that are admittedly ?duplicative? of the claims already presented by Petitioners. The Does? submissions demonstrate that it is entirely unnecessary for Jane Doe 3 and Jane Doe 4 to proceed as parties in this action, rather than as fact witnesses available to offer relevant, admissible, and non-cumulative testimony. (See, DE 280 at 2 (Jane Doe 3 and Jane Doc 4 ?are in many respects similarly situated to the current victims?), 9 (?The new victims will establish at trial that the Government violated their CVRA rights in the same way as it violated the rights of the other victims?), 10 (Jane Doe 3 and Jane Doe 4 ?will simply join in motions that the current victims were going to file in any event?), 11 (litigating Jane Doe 3 and Case Managua ara camaraara: Page a of in Jane Doe 4?s claims would be ?duplicative?); DE 298 at 1 n.1 (?As promised . . . Jane Doc No. 3 and Jane Doc No. 4 do not seek to expand the number of pleadings ?led in this case. If allowed to join this action, they would simply support the pleadings already being ?led by Jane Doe No. 1 and Jane Doc No. DE 311 at 5 n3 four victims (represented by the same legal counsel) intend to coordinate efforts and avoid duplicative pleadings?), 15 (Jane Doc 3 and Jane Doc 4 ?challenge the same secret agreement the NPA that the Government executed with Epstein and then concealed from the victims. This is made clear by the proposed amendment itself, in which all four victims simply allege the same general As the Does argue at length in their Rule 15 Motion, Jane Doe 1?s original petition ?speci?cally allege[s] that the Government was violating not only her rights but the rights of other similarly-situated victims.? (DE 311 at 2). The Court fails to see why the addition of ?other similarly-situated victims? is now necessary to ?vindicate their rights as well.? (DE 280 at 1). Of course, Jane Doe 3 and Jane Doc 4 participate in this litigated effort to vindicate the rights of similarly situated victims there is no requirement that the evidentiary proof submitted in this case come only from the named parties. Petitioners point out as much, noting that, regardless of whether this Court grants the Rule 15 Motion, ?they will call Jane Doc No. 3 as a witness at any trial.? (DE 311 at 17 n7). The necessary ?participation? of Jane Doc 3 and Jane Doc 4 in this case can be satis?ed by offering their properly supported and w, admissible, and non-cumulative testimony as needed, whether through testimony at trial DE 280 at 9) or af?davits submitted to support the relevancy of discovery requests4 4 The non-party Jane Does clearly understand how to submit af?davits. See DES 291-1, 310-1). Case aeamctiee?se??w. Wigwam sea Demetaalaa Page a of (L at 10). Petitioners do not contend that Jane Doe 3 and Jane Doe 4?s participation in this case? can only be achieved by listing them as parties. As it stands under the original petition, the merits of this case will be decided based on a determination of whether the Government violated the rights of Jane Doe 1, Jane Doe 2, and all ?other similarly situated victims? under the CVRA. Jane Doe 3 and Jane Doe 4 may offer relevant, admissible, and non-cumulative evidence that advances that determination, but their participation as listed parties is not necessary in that regard. Herring, 894 F.2d at 1024 (District court did not abuse its discretion by denying amendment where ?addition of more plaintiffs . . . would not have affected the issues underlying the grant of summary judgment?); c-_f Arthur v. Stern, 2008 WL 2620116, at *7 (SD. Tex. 2008) (Under Rule 15, ?courts have held that leave to amend to assert a claim already at issue in [another lawsuit] should not be granted if the same parties are involved, the same substantive claim is raised, and the same relief is And, as to Jane Doe 4 at least, adding her as a party raises unnecessary questions about whether she is a proper party to this action.6 Petitioners also admit that amending the petition to conform to the evidence by including references to the non-prosecution agreement itself is ?unnecessary? as the ?existing petition is broad enough to cover the developing evidence in this case.? (DE 311). The Court 5 The Court expresses no opinion at this time whether any of the attestations made by Jane Doe 3 and Jane Doe 4 in support of their motion will be relevant, admissible, and non- cumulative. 6 The Government contends that Jane Doe 4 is not a true ?victim? in this case because she was not known at the time the Government negotiated the non-prosecution agreement, and accordingly she was not entitled to noti?cation rights under the CVRA. (E DE 290 at 10). Any ?duplicative? litigation ?led by Jane Doe 4 would necessarily raise the issue of whether she has standing under the CVRA under these circumstances. 9 Case a? u. 327$. Page 10 of it) agrees, and it concludes that justice does not require amending the petition this late in the proceedings. 111. Conclusion Accordingly, it is hereby ORDERED AND ADJUDGED as follows: the Rule 21 Motion (DE 280) is the Rule 15 Motion (DE 311) is Intervenor Dershowitz?s Motion for Limited Intervention (DE 282) and Motion for Leave to File Supplemental Reply in Support of Motion for Limited Intervention (DE 317) are DENIED AS Petitioners? Motion to Seal (DE 292) is DENIED AS the following materials are hereby STRICKEN from the record: - DE 279, in its entirety. - DE 280, all sentences between the following sentences: ?The Government then concealed from Jane Doe #3 the existence of its NPA from Jane Doe in violation of her rights under the (DE 280 at Q1 ?The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment 291-1, paragraphs through 53, and 59. - DE 310-1, paragraphs 7 through 12293, in its entirety. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 6&1 day of April, 2015. KENNETH A. MARRA United States District Judge 10 Case 18-2868, Document 278, 08/09/2019, 2628230, Page43 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page44 of 648 From: Date: 2 January 2015 at 20:33 Subject: Ghislaine Maxwell To: Rossacuity Gow bcc: P.Peachev?ilindeoendentcook. nick.sornmerlad@mirror.co.uk, clavidbrown@thetimes.co.uk, io?anne?igh?ibbcmouk To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts -so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschowitz is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. Sent from my Blackberry? wireless device Case 18-2868, Document 278, 08/09/2019, 2628230, Page45 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page46 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 THE HIGH COURT OF JUSTICE BENCH DIVISION Claim No. CR 2016?624 BETWEEN: VIRGINIA L. GIUFFRE Applicant, and ROSS GOW, Respondent. AND: UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, v. Case NO. 15-CV-07433-RWS Ghislaine Maxwell, Defendant. Friday, November 18, 2016 AT: 8:27 a.m. Taken at: Essex Chambers 29, 81 Chancery Lane, London, UK, WC2A Court Reporter: Lisa Barrett, Accredited Realwtime Reporter DTI Court Reporting Solutions New York 1?800-325m3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page47 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page Appearing for the Plaintiff: MEREDITH L. SCHULTZ, ESQ. BOIES, SCHILLER FLEXNER 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 333 DAVID TURNER, ESQ. BOIES, SCHILLER FLEXNER 25 Old Broad Street London, UK EC2N Counsel for Defendant, Ghislaine Maxwell: LAURA A. MENNIGER, P.C. HADDON, MORGAN and FOREMAN, P.C. 150 East Tenth Avenue Denver, CO 80203 Counsel for Defendant, Ross Ne (witness): RICHARD SPEARMAN, Q.C. PHILIP BARDEN, DEVONSHIRES SOLICITORS LL 30 Finsbury Circus, London EC2M 7DT, UK Examiner: ALLEN DYER, 4 Pump Court Temple, London, EC4Y 7AN DX 303 LDE LLP 01 (UK) LLP il Sutherland Gow DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page48 of 648 Ross NEIL SUTHERLAND GOW 11/18/2016 Page 3 I I 2 Witness Page 3 ROSS NEIL SUTHERLAND GOW (sworn) lO 4 Examination by Ms. Schultz 10 5 Examination by Ms. Menninger 117 6 Re?examination by Ms. Schultz 119 7 8 I I I 9 No. Description Page 10 1 Consent Order before Master Fontaine 11 11 2 Email from ross@acuityreputation.com to 13 12 Ross@acuity.com, bcc: 13 14 P.Peachy@indepedent.co.uk, 15 Nick.sommerland@mirror.co.uk, 16 david.brown@thetimes.co.uk, 17 Nick.a1way@bbc.co.uk, 18 19 dated 2 January 2015, 20 Bates No. 21 3 Email from James Ball to Ross Gow, 30 22 dated 1 January 2015, 23 Bates NO. 24 25 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page49 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 4 X-H I I I 2 No. Description Page 3 4 Email from Ross Gow to Max, 35 4 cc Brian Basham, dated January 2, 2015, 5 Bates No. 6 5 Email from ross@acuityreputation.com, 37 7 to Max, sent Friday, January 2, 2015, 8 Fw: The Times David Brown, Bates No. 9 10 6 Email from ross@acuityreputation.com 38 11 to Max, sent Friday, January 2, 12 2015, Subject: Agreed copy, 13 Bates Nos. 14 7 Email from ross@acuityreputation.com 40 15 to Max, sent Friday, January 2, 16 2015, Subject: Re: Agreed copy, 17 Bates No. GMm01040?0104l 18 8 Email from ross@acuityreputation.com 42 19 dated Friday, January 2, 2015, 20 To: Max, Bates NO. 21 9 Email from ross@acuityreputation.com, 44 22 dated 2 January 2015, To: Max 23 gmax1@ellmax.com, Cc: Philip 24 IBarden, 25 Bates Nos. _00009 1?800-325-3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page50 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 5 1 I I I 2 No. Description Page 3 10 Email from gmaxl@ellmax.com, sent: 50 4 Saturday January 10, 2015, 5 To Philip Barden; Ross Gow, 6 Bates 7 11 Email chain, latest in time from 54 8 Maxwell to Jep, sent 9 Sunday, January 11, 2015, Bates Nos. 10 11 12 Email chain, latest in time from 60 12 Jeffrey jeevacation@gmail.com, 13 dated Sunday, January 11, 2015, 14 7:15 to Maxwell, Bates 15 Nos. 16 13 Email chain, latest in time from 65 17 Jeffrey jeevacation@gmail.com, '18 sent Wednesday, January 21, 2015 19 4:47 p.m. To: Maxwell, Bates 20 NOS. 21 22 23 24 25 1?800-325?3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page51 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 6 I I I 2 No. Description Page 3 14 Email chain, latest in time from 68 4 Nick Sommerlad, dated 2 January 2015, 5 21:45, To ross@acuityreputation.com 6 Bates Nos. 000004, one page 7 15 Email from Ross Gow dated Saturday, 71 8 3 January 2015, To David Mercer, Bates Nos. 9 10 16 Email string from Ross Gow to Max; 73 11 Philip Barden, dated Tues, 12 February 24, 2015, Bates Nos. 13 one page 14 17 Email from MaxWell to Ross Gow, 75 15 dated Thurs February 26, 2015, 16 Bates Nos. 17 18 Email from Ross Gow to Maxwell, 77 18 dated Thursday, February 26, 2015, 19 Bates NOS. 20 19 Email from Ross Gow to Max; 78 21 Philip Barden, dated Wednesday, 22 April 8, 2015, Bates Nos. 23 24 25 DTI Court Reporting Solutions New York 1?800n325?3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page52 of 648 Ross NEIL SUTHERLAND GOW 11/18/2016 Page 7 1 I I I 2 No. Description Page 3 4 20 Email from Max to Ross Gow; 79 5 Philip Barden, dated Wednesday, 6 May 6, 2015, Bates Nos. 7 21 Email chain, latest in time from 81 8 Ross Gow to Maxwell; Philip Barden, 9 dated Wednesday, May 6, 2015, Bates Nos. 10 11 22 Email from Ross Gow to Scott Adam, 82 12 dated Wednesday, May 6, 2015, 13 Bates No. 14 23 Website print out Bates No. 82 15 GUIFFRE008453 16 24 Website printout, Bates Nos. 93 17 two pages 18 25 Email from Ross Gow to Max, 100 19 Philip Barden, Bates Nos. 20 26 Website screenshot printout of 109 21 Acuity Reputation two pages 22 23 24 25 1?800-325-3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page53 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 8 1 I 2 THE VIDEOGRAPHER: Here begins video card 3 number 1, volume I, in the video deposition of Ross Gow. 4 This is taken in the matter of Virgina Guiffre 5 and Ross Gow. This is being heard in the High Court of 6 Justice, Queen's Bench Division, Senior Master, claim 7 number ,8 Today's date is November 18, 2016. The time on 9 the video screen is 08:26 local time in London. 10 The video operator today is Phillip Hill from 11 DTI Court Reporting Solutions. 12 The court reporter is Lisa Barrett from DTI 13 Court Reporting Solutions. 14 This video deposition is taking place at the 15 Essex Chambers in London. 16 I will now hand over the proceedings to the 17 Examiner. Thank you, sir. 18 MR. DYER: Would counsel or lawyers present, 19 please identify themselves for the record, first? 20 MS. SCHULTZ: I'm Meredith Schultz from Boise 21 Schiller and Flexner LLP, appearing for the Plaintiff, 22 Ms. Virginia Guiffre. With me is my colleague, David 23 Turner, also from Boies, Schiller and Flexner LLP. 24 MS. MENNINGER: I'm Laura Menninger from 25 Haddon, Morgan and Foreman on behalf of Ghislaine' DTI Court Reporting Solutions - New York 1?800?325w3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page54 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page worse objection, or worse grounds for me. MR. DYER: I think questions of payment do not fall within the sc0pe. BY MS. SCHULTZ: Q. Okay. Are you currently retained by Ms. Maxwell for professional services. A. If I could go back to my previous answer, Ms. Maxwell is a project client, and it's on a day rate. If so, for the sake of argument between 2nd of January 2015 and the of February 2016 we were quite busy answering these incoming calls, so there was quite a lot of work at that point in time. Recently there's been no work. There's been no need because the press activity has died down, our function is somewhat redundant. Q. Can you estimate the last time that you worked on this account at your day rate? A. It would have been in 2015. Probably April, May, something like that. No invoices, no no payment in 2016 from my recollection. BY MS. SCHULTZ: Q. Mr. Gow, I'm going to hand you another document. (Exhibit 3 was marked for identification.) MS. SCHULTZ: Point of procedure: I have only three copies of these documents for each of the 1?800-325?3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page55 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 31 remaining, I've marked as Exhibit 3 Do you recognize this email? A. I do. Q. Did you receive this email? A. I did, on the on New Year's Day 2015. Q. Did you contact Ms. Maxwell after receiving this email? A. I did. Q. Did you make any response to Mr. Ball in any form? A. I did. Q. Can you tell me what you w~ what response you made? A. Well, the response to Mr. Ball was part of a series of responses having spoken to my client within 24 hours or so, we got back to Mr. Ball with an agreed statement which went out to a number of media. Q. When you say "agreed statement" can you tell me more about what you mean? Who agreed to the statement? A. I need to give you some context, if I may, about that statement. So, this is on New Yearls Day. I was in France so the email time here of 21:46, in French time was 22:46, and I was getting up early the next DTI Court Reporting Solutions New York 1?800?325a3376 0&5& 0&5& 0&5& 0&5& 0&5& 0&5& 0&5& 0&5& 0&5& 0&5% 0&5% 0&5% 0&5? 0&5% 0&5? 0&5% 0&5% 0&5% 0&5% 0&5% 0&5% 010m 010m 010m 010m 01 10 Case 18-2868, Document 278, 08/09/2019, 2628230, Page56 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page morning to drive my family back from the south of France to England, which is a 14?hour journey, door to door. 80 on the morning of the 2nd of January, bearing in mind that Ms. Maxwell, I think was in New York then, she was five hours behind, so there was quite a lot of, sort of time difference between the various countries here, I sent her an email, I believe, saying parsing this forwarding this email to her saying "How do you wish to proceed?" And then I was on the telephone a? I had two telephones in the car, I received in excess of 30 phone calls from various media outlets on the 2nd of January, all asking for information about how Ms. Maxwell was looking to respond to the latest court filings, which were filed on the 30th of December as I understand. And by close towards close of play on the 2nd, I received an email forwarded by Ms. Maxwell, containing a draft statement which my understanding was the majority of which had been drafted by Mr. Barden with a header along the lines of "This is the agreed statement." At close of play on the 2nd. So I I was I had gone under the Channel Tunnel and I was sitting on the other side and that email, which my understanding was that it had 1?800?325-3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page57 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page been signed off by the client, effectively, was then sent out to a number of media, including Mr. Ball and various other UK newspapers. Q. Mr. Gow, when you say "end of play" and "close of play," are you referring to sending the email that's Exhibit 2? A. Yes, I am. MR. DYER: My understanding is that it went to people other than those listed? THE WITNESS: Yes, that is MR. DYER: Just a sample. THE WITNESS: That is a sample. Everyone who effectively well, the detail on this, I was driving, so my eldest son in the back had my BlackBerry and was trying to capture it was a pretty chaotic day. Most people in the UK were on holiday. In fact, it was a holiday weekend, our office was closed, my PA was on holiday, so my son was basically doing an internship in the back of the car, downloading the names of the callers from various media outlets and so we had a list of those so when I got to the car park, at the end of the Eurotunnel thing in the UK, I had numerous names, so the email went out to a wide range of people. But the 30 or so calls I had is an aggregate number, so there might have been five calls from the BBC 1-800-325?3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page58 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page from different people so they the BBC would only write one story, there wouldn?t be five versions of it, so 30 is an aggregate number. BY MS. SCHULTZ: Q. Okay. Looking again at Exhibit 2, could you please review the individuals or email addresses of the -- listed in the "To" and "bcc" portion? A. Yep. Q. Did you send this written statement to any other individuals or entities who are not listed in that portion? A. Within f? within 24 hours of this, yes, a wider range of people, definitely. This was the initial these are the most pressing ones, who said they were going to write a story whether they had if I could just explain a bit more context again in the world of PR. When you are in the field you're engaged and you?ve just you?ve got to prioritize who you spoke to and whoever shouts the loudest usually gets responded to first. So the reason there are two BBC people there for instance, is there's BBC broadcast radio, and BBC TV, and they were coming at from different angles for different stories, but there was a certain sense of urgency and immediacy. So the half a dozen 1-800?325-3376 DTI Court Reporting Solutions New York Case 18-2868, Document 278, 08/09/2019, 2628230, Page59 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page here were the ones that we prioritized to deal with that night because they were publishing the next day or or thereabouts, but for instance we also spoke to the Daily Express. I can't remember the name of the gentleman there, or the lady, but I remember that was early the next morning when we got on to other channels. Q. So you sent this statement to additional individuals on January 3rd? A. Not just on January 3rd. I mean, as we had an agreed statement there, and I do recall there is a typo in this which is "Virginia" and "Victoria" there was a transposition there. So the original email went out with the typo because that was taken from the the statement that I believe Mr. Barden was broadly the architect of, but forwarded by Ms. Maxwell. 80 I just I took that as a verbatim statement and sent it out. I re?read it in the calm light of day the next morning. There was at least one typo in it so I changed that and reached out, again, to these people, updating the typo and sent it out to additional people. BY MS. SCHULTZ: Q. Mr. Gow, I?m going to hand you another document. I'm going to mark this as Exhibit 4. (Exhibit 4 was marked for identification.) DTI Court Reporting Solutions New York 1?800-325-3376 09?4 09?4 09?4 010k 010k 010% 0%0& 0105 09?5 0%0& 0%0& 0%0& 0%0& 0%0& 0% Case 18-2868, Document 278, 08/09/2019, 2628230, Page60 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 36 BY MS. SCHULTZ: Q. This is a document that is Bates labeled A. Thank you. Q. The top email on this document says ?From: Ross Gow.? Did you send this email? A I believe I did, yes. Q. Did you send it to Ms. Maxwell? A Yes. Q. In the "To? field, when it says Max," do you recognize that to be Ms. Maxwell's email address? A. Yes. Q. In the second paragraph of this email it states: "Please advise how you wish to handle this [As read] Did you receive a response from Ms. Maxwell? A. Bearing in mind I was driving all that day, I can't recall what the exact response was but from memory, it was along the lines of she would get back to me with how she wished to proceed. BY MS. SCHULTZ: Q. Okay. Mr. Gow, I'm going to hand you another document. I'm going to mark it as Exhibit 5. DTI Court Reporting Solutions New York 09:07: Case 18-2868, Document 278, 08/09/2019, 2628230, Page61 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 122 had existing authorization to make statements on Ms. Maxwell?s behalf due to the reauthorization letter; is that correct? A. I believe that from the 2nd of January 2015, I had an ongoing re?established authority to represent her, within the parameters of the 2011, 2015 press releases, there or thereabouts. MS. SCHULTZ: Mr. Dyer, I have no further questions. MR. DYER: Thank you. That concludes your deposition. THE WITNESS: Thank you, sir. MR. DYER: Thank you very much. THE VIDEOGRAPHER: Going off the record, the time is 11:39. End of video card number 3, volume I, and end of the video deposition of Ross Gow. (Whereupon, the deposition concluded at 11:39 Wax/M Lisa Barrett, RPR, CRR, CRC, CSR Certified Real?time Court Reporter DTI Court Reporting Solutions New York 1?800?325?3376 ?9?8 ?9?l ?9?4 :3%15 :3990 3930 :3935 ?936 ?938 ?939 39%0 ?9?l Case 18-2868, Document 278, 08/09/2019, 2628230, Page62 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 123 Subscribed and sworn to before me this 2 20th day of November, 2016DTI Court Reporting Solutions New York 1?800?325w3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page63 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 124 CERTIFICATE OF DEPONENT I, ROSS NEIL SUTHERLAND GOW, hereby certify that I have read the foregoing pages, numbered 1 through 122 of my deposition of testimony taken in these proceedings on this 18th day of November, 2016 and with the exception of the changes listed on the next. page and/or corrections, if any, find them to be a true and accurate transcription thereof. DTI Court Reporting Solutions New York 1?800?325w3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page64 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 125 CERTIFICATE OF EXAMINER I, ALLEN DYER, of 4 Pump Court Temple, London, EC4Y 7AN DX 303 LDE have been appointed as Examiner herein pursuant to an Order of Master Fontaine dated 29 September 2016. It has been agreed by all parties herein that the evidence of the witness, ROSS NEIL SUTHERLAND GOW, should be taken down in shorthand and that the transcript of the said nOtes of evidence should be deemed to be the deposition of the said witness. I certify that, the oath having been duly administered, the witness has been examined pursuant to the said order. The pages of transcript annexed hereto were furnished to me by DTI, Lisa Barrett, Accredited Realwtime Reporter, as containing the transcript of the notes of the evidence of the witness pursuant to the order. DTI Court Reporting Solutions New York 1?800?325m3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page65 of 648 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 126 10CERTIFICATE OF DEPONENT I, Ross Neil Sutherland Gow, hereby certify that I have read the foregoing pages, numbered 1 through 122, of my video deposition of testimony taken in these proceedings on this 18th day of November, 2016 and, with the exception of the changes listed on the next page and/or corrections, if any, find them to be a true and accurate transcription thereof. DTI Court Reporting Solutions New York 1~800~325~3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page66 of 648 R088 NEIL SUTHERLAND GOW - 11/18/2016 Page 127 CERTIFICATE OF COURT REPORTER I, Lisa M. Barrett, an Accredited Real?time Reporter, hereby certify that the testimony of the witness Ross Neil Sutherland Gow in the foregoing transcript, numbered pages 1 through 122, taken on this 18th day of November, 2016 was recorded by me in machine shorthand and was thereafter transcribed by me; and that the foregoing transcript is a true and accurate verbatim record of the said testimony. I further certify that I am not a relative, employee, counsel or financially involved with any of the parties to the within cause, nor am I an employee or relative of any counsel for the parties, nor am I, in any way, interested in the outcome of the within cause . Wm Signed Name: Lisa M. Barrett, RPR, CRR, CRC, CSR Date: November 30th 2016 DTI Court Reporting Solutions New York 1?800?325?3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page67 of 648 Forwarded message Finn: James Ball Date: 1 January 2015 at 21:46 Subject: URGENT Ghislaine Maxwell To: ross@amityreputalion.com Dear Ross. I'm writing Io you as you have in the past represented Gbislaine Maxwell. As you are no doubt aware. fresh allegations have been levelled against Ms Maxwell in new US coun ?lings made in Florida on 30 December. which some outlets lave already been reponed. I would urgently see]: any comment on behalf of your client. or noti?cation of her new lepresentan'nn if you no longer act for her. Many thanks for your help. James EXHIBIT LL Case 18-2868, Document 278, 08/09/2019, 2628230, Page68 of 648 From: Ross Gow Sent: Friday, January 02, 2015 1:07 AM To: Max Cc: Brian Basham Subject: Fwd: URGENT - Ghislaine Maxwell Hi Ghislainc James Ball, investigative reporter for The Guardian, who reports on US stories, has made contact, as per below. Please advise how you wish to handle this. am driving all day today, but can be contacted on +44 (0) 7778 755 251 Best Ross Forwarded message From: James Ball Date: 'l?hursday, January 1, 20 5 Subject: URGENT - Ghislaine Maxwell To: rossfmaeuitvrenutationxom Dear Ross. ?hislaine Maxwell. As you are no doubt aware, fresh 'n new US court ?lings made in Florida on 30 December, I'm writing to you as you have in the past allegations have been levelled against which some outlets have alread be I would urgently seek an longer act for her. Many thanks for your help, James huts"; Project; {Editor 203 353$ 295 i 7540 $5125 . Visit theguardiancom. On your mobile and tablet. download the Guardian iPhone and Android apps theguardian.com/guardianagg and our tablet editions theguardian.com/editions. Save up to 57% by subscribing to the Guardian and Observer - choose the papers you want and get full digital access. Visit Subscribe.theguardian.com PRIVILEGED EXHIBIT CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page69 of 648 This e-mail and all attachments are con?dential and may also be privileged. If you are not the named recipient, please notify the sender and delete the e-mail and all attachments immediately. Do not disclose the contents to another person. You may not use the information for any purpose, or store, or copy, it in any way. Guardian News Media Limited is not liable for any computer viruses or other material transmitted with or as part of this e-mail. You should employ virus checking software. Guardian News Media Limited is a member of Guardian Media Group plc. Registered Office: PO Box 68164, Kings Place, 90 York Way. London, N1 ZAP. Registered in England Number 908396 Ross Gow Managing Partner ACUITY Reputation 23 Berkeley Square London W1J6HE +44 (0) 207 204 6! 10 +44 (0) 777 875 525! mob +7 903 363 5393 Mocrtaa ity reputation .com The information contained in this e-mail and any attachments is con?dential and may be privileged or otherwise protected from disclosure. It is intended solely for the attention and use of the named addressee(s). if you are not the intended recipient, dissemination, copying or use ofthis e-mail and any attachments in whole or in part is prohibited. if you have received the e-mail in error, please notify the sender and delete the e-mail and any attachments from your computer system. Whilst any attachments may have been checked for viruses, you should rely on your own virus checker and procedures. No responsibility is accepted by ACUITY Reputation Limited for loss or damage arising from the receipt or use ol? this e-mail. PRIVILEGED CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page70 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page71 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S RESPONSES AND OBJECTIONS TO DEFENDANT’S SECOND REQUEST FOR PRODUCTION AND DEFENDANT’S INTERROGATORIES, PLAINTIFF’S ANSWERS TO DEFENDANT’S REQUESTS FOR ADMISSION Pursuant to Federal Rules of Civil Procedure 26, 33, 34, Plaintiff hereby serves her responses and objections to Defendant’s Second Set of Discovery Requests and serves her Answers to Defendant’s Requests for Admission. GENERAL OBJECTIONS Defendant’s Discovery Requests violate Rule 33, Fed. R. Civ. P., which provides “a party may serve on any other party no more than 25 interrogatories, including all discrete subparts” – in that Defendant has served a total of 59 interrogatories in this case, including subparts, in violation of Rule 33. Ms. Giuffre objects to Defendant’s Second Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege, work product privilege, joint defense privilege, public interest privilege, and any other applicable privilege. 1 Case 18-2868, Document 278, 08/09/2019, 2628230, Page72 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) on hundreds (if not thousands) of matters, and collectively have well over 100 years of combined practice experience. Accordingly, a request that each of these attorneys list all communications with the media is facially overbroad. Additionally, Ms. Giuffre objects to this Interrogatory because a response would cause Ms. Giuffre the incredible and undue burden of having to catalogue literally hundreds of communications that she has already produced in this case. Moreover, Ms. Giuffre objects because this interrogatory calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Communications with the media regarding cases that bear no relation to the subject matter of this case, from decades in the past, are facially invalid and not calculated to lead to the discovery of admissible evidence. Ms. Giuffre additionally objects to the extent that this interrogatory seeks the communications of her attorneys, any author, reporter, correspondent, columnist, writer, commentator, investigative journalist, photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any media organization or independent consultant as such interrogatory is overly broad and unduly burdensome. Furthermore, Ms. Giuffre is not obligated to produce anything currently in the possession of Defendant Maxwell or her attorneys. Notwithstanding such objections, Ms. Giuffre has already produced her responsive communications, which are found in documents Bates labelled GIUFFRE000001 to GIUFFRE007566. 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Count I of Your Complaint, including: 5 Case 18-2868, Document 278, 08/09/2019, 2628230, Page73 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) a. the exact false statement; b. the date of its publication; c. the publishing entity and title of any publication containing the purportedly false statement; d. the URL or internet address for any internet version of such publication; and the nature of the publication, whether in print, internet, broadcast or some other form of media. Response to Interrogatory No. 6: Ms. Giuffre objects because the information interrogatory above is in the possession of Defendant who has failed to comply with her production obligations in this matter, and has failed to comply with her production obligations with this very subject matter. See Document Request No. 17 from Ms. Giuffre’s Second Request for Production of Documents to Defendant Ghislaine Maxwell.1 Maxwell has not produced all “URL or Internet addresses for any internet version of such publication” that she directed her agent, Ross Gow, to send. 1 Request No. 17 stated: Produce all documents concerning any statement made by You or on Your behalf to the press or any other group or individual, including draft statements, concerning Ms. Giuffre, by You, Ross Gow, or any other individual, from 2005 to the present, including the dates of any publications, and if published online, the Uniform Resource Identifier (URL) address. In response, Defendant stated: “Ms. Maxwell objects to this Request on the grounds that it is cumulative and duplicative. Ms. Maxwell also objects to this Request to the extent it calls for information that exists within the public domain, the internet or in public court records and which are equally available to both parties and can be obtained from some other source that is more convenient, less burdensome, and less expensive. Ms. Maxwell further objects to this Request to the extent it seeks documents or information protected by the attorney/client privilege, the work-product doctrine, or any other applicable privilege. Ms. Maxwell is not producing documents that are available in the public domain. Ms. Maxwell has been unable to locate any additional documents responsive to this Request.” 6 Case 18-2868, Document 278, 08/09/2019, 2628230, Page74 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Ms. Giuffre further objects because the information requested above is in the possession of Defendant’s agent, who caused the false statements to be issued to various media outlets. Ms. Giuffre has not had the opportunity to depose Maxwell’s agent Ross Gow; therefore, this answer remains incomplete. Consequently, Ms. Giuffre reserves the right to modify and/or supplement her responses, as information is largely in the possession of the Defendant and her agent. Ms. Giuffre objects to this interrogatory in that it violates Rule 33 as its subparts, in combination with the other interrogatories, exceed the allowable twenty-five interrogatories. Ms. Giuffre objects to this request because it is in the public domain. Ms. Giuffre also objects in that it seeks information protected by the attorney-client/work product privilege, and any other applicable privilege stated in the General Objections. Notwithstanding such objections, Ms. Giuffre has already produced documents responsive to this request; Bates labelled GIUFFRE000001 to GIUFFRE007566, and supplements such responsive documents with the following list of publications. While the identification of an exhaustive responsive list would be unduly burdensome, in an effort to make a good faith effort towards compliance, Ms. Giuffre provides the following examples, which are incomplete based on the aforementioned reasons: Date Nature Januar Internet y 2, 2015 Publishi ng Entity Ross Gow Statement/URL Jane Doe 3 is Virginia Roberts - so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms. Roberts that Alan Dershowitz is involved in having sexual relations with her, which he denies. Ms. Roberts’s claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at 7 Case 18-2868, Document 278, 08/09/2019, 2628230, Page75 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Januar the repetition of such old defamatory claims. http://www.telegraph.co.uk/news/uknews/theroyalfamily/11323872/PrinceAndrew-denies-having-relations-with-sex-slave-girl.html Internet Telegrap h Internet Express http://www.express.co.uk/news/world/550085/Ghislaine-Maxwell-Jeffrey-Epsteinnot-madam-paedophile-Florida-court-case-Prince-Andrew Internet Daily Mail http://www.dailymail.co.uk/news/article-2895366/Prince-Andrew-lobbiedgovernment-easy-Jeffrey-Epstein-Palace-denies-claims-royal-tried-use-influencehelp-billionaire-paedophile-2008-police-probe html Internet Huffingt on Post http://www.huffingtonpost.co.uk/2015/01/03/duke-of-york-sex-abuseclaims_n_6409508 html Internet Jewish News Online http://www.jewishnews.co.uk/dershowitz-nothing-prince-andrews-sex-scandal/ Internet Bolton News http://www.theboltonnews.co.uk/news/national/11700192.Palace_denies_Andrew_s ex_case_claim/ Januar Internet http://www.nydailynews.com/news/world/alleged-madame-accused-supplyingprince-andrew-article-1.2065505 y 5, / NY Daily News 2015 Broadca AOL UK http://www.aol.co.uk/video/ghislaine-maxwell-declines-to-comment-on-princeandrew-allegations-518587500/ y 3, 2015 Januar y 4, 2015 Januar y 3, 2015 Januar y 3, 2015 Januar y 4, 2015 Januar y 2, 2015 st Januar Internet y 5, / 2015 Broadca st 8 Case 18-2868, Document 278, 08/09/2019, 2628230, Page76 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 Telephone: (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 Telephone: (801) 585-5202 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 1, 2016, I electronically sent the foregoing document to the counsel below via e-mail. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: lmenninger@hmflaw.com 43 Case 18-2868, Document 278, 08/09/2019, 2628230, Page77 of 648 EXHIBIT I Case 18-2868, Document 278, 08/09/2019, 2628230, Page78 of 648 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: v. Ghislaine Maxwell, Defendant. SUPPLEMENTAL RESPONSES TO DEF INTERROGATORIES 6, 12 and 13 Pursuant to Federal Rules of Civil Procedure 26, 33, 34, Plaintiff hereby serves her supplemental responses to Defendant?s Interrogatories 6, 12 and 13. OBJECTION Plaintiff maintains and hereby incorporates by reference all applicable objections, including both general objections and speci?c objections to individual interrogatories, in her prior responses and objections served on Defendant in these supplemental responses. Defendant?s Discovery Requests violate Rule 33, Fed. R. Civ. P., which provides ?a party may serve on any other party no more than 25 interrogatories, including all discrete subparts? in that Defendant has served a total of 59 interrogatories in this case, including subparts, in violation of Rule 33. Ms. Giuffre objects to Defendant?s Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege, work product privilege, and any other applicable privilege. Case 18-2868, Document 278, 08/09/2019, 2628230, Page79 of 648 Jane Doc No. 102 v. Jeffrey Epstein, Case No. 09-80656-CIV-Marra/Johnson (Southern District of Florida). Accordingly, due to the undue burden of individually logging responsive, privileged documents related to Defendant?s overly-broad requests, Plaintiff has employed categorical logging of such privileged responsive documents pursuant to Local Civil Rule Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a minor victim of sexual traf?cking. Ms. Giuffre objects to the requests to the extent they are overly broad and unduly burdensomc. Ms. Giuffre?s responses to Defendant?s Second Set of Discovery Requests are being made after reasonable inquiry into the relevant facts, and are based only upon the information and documentation that is presently known to her. Ms. Giuffre reserves the right to modify and/or supplement her responses. Ms. Giuffre has produced documents and information in response to these Requests. Ms. Giuffre incorporates her above-listed general objections in the responses herein. SUPPLEMENTAL INTEROGATORY RESPONSES 6. Identify any ?false statements? attributed to Ghislaine Maxwell which were ?published globally, including within the Southern District of New York? as You contend in paragraph 9 of Court 1 of Your Complaint, including: a. the exact false statement; b. the date of its publication; c. the publishing entity and title of any publication containing the purportedly false statement; d. the URL or internet address for any internet version of such publication; and e. the nature of the publication, whether in print, internet, broadcast or some other form of media. Case 18-2868, Document 278, 08/09/2019, 2628230, Page80 of 648 In addition to her previous response, Ms. Giuffre supplements the response to include: January 8, 2015 Internet The Sun 28 508300-Editorial-TWITTER- TheSunNewspaper-ZO 1 50108-News 12. Identify any Health Care Provider from whom You received any treatment for any physical, mental or emotional condition, including addiction to alcohol, prescription or illegal drugs, that You suffered from subsequent to the Alleged Defamation by Ghislainc Maxwell, including: a. the Health Care Provider?s name, address, and telephone number; b. the type of consultation, examination, or treatment provided; c. the dates You received consultation, examination, or treatment; d. whether such treatment was on an in?paticnt or out-patient basis; e. the medical expenses to date; f. whether health insurance or some other person or organization or entity has paid for the medical expenses; and g. for each such Health Care Provider, please execute the medical and mental health records release attached hereto as Exhibit A. Supplemental Response to Interrogatorv No. 12: Ms. Giuffre objects to this interrogatory in that it is overbroad and not limited in scope to the medical information relating to the abuse she suffered from Defendant and Jeffrey Epstein. Pursuant to the Rules, if requested documents are not yielded in a ?reasonable inquiry,? Ms. Giuffre is not obligated to expend all of her time and resources on a quest to gather medical ?les that are unknown to her or unaccessable after reasonable inquiry. See, e. Manessis v. New York City Dep't 0fTrar1sp., No. 02 359SASDF, 2002 WL 31 1 15032, at *2 (S.D.N.Y. Sept. 24, 2002) Case 18-2868, Document 278, 08/09/2019, 2628230, Page81 of 648 - Medicare Ami rulia ptovidcd health care insu: ante covaagc and men: for service: modved in Australia from July 19, 201.: thrust: the M: Giu??re?s claims histmy ?n thir. pmiud i2. 461:1in (ill 7021} Dr. Walt Walt San, Central (?oast Family Mcdicim:= Unit 2, l7 Anzac Rd, Tuggcrah 22?0_ 024 :5 2:0,:ch Ms (iiul'?c Mauh 14,. 201.3, in panic attacks as dmibed in the Mica! ward: produced at and pcm'xbly September I 301 for ?Standard Constantin? 'I'hm?e maids have requcstcai and a release sent to the pun-idea Pharmacy provided prescribed medicatims In Ms Giuf?'c as in the rounds. produced at i 08 H??valgreens Pharmacy may has proviticd Imam ihcd nwdiru?ms to M3. Giu?'we Those records haw hem and a rdcase wm?uitxl the. plum Imtu?. u?c' I N3 - Dr. ?imothy I). Ha rtwig, D1). was identi?ed in records produced by pharmacy. Ms (Shuf?e has smu?su'? ?knit m. d3. m- (ill 3-:6 {?18 0 Dr. James Nicnoss, MB was identi?ed in records gum-ed by pharmacy. Ms hm: letllk??lcd Mu 3?3] - Dr. Rodo??o "terms Jr, 51.0. ?as udcn?liui plodu'cc-tl by plwmacv Ms Giuf?c has requested those teams. we (in 8354 Dated Augmlf?zm? Signed. - '5 \y - Virgi nia (iiu?lc Roc'md': Mcdmaic Ausua?a aw. gent-mus Emil-:d I wan. Mn. (Shuffle is ?manning addltumad [cmld? mm: min: hub. 19. 20}. lhmugi: that In Annual?: Ms Ulu?'tc now Wah Walt Kan and DI was Sun In be thu- w'nc ptmidct smite but ofhcr knowledge She had pm?iousiy Eistcd both name." in an mmdancc of minim befor: Immune that Dr San NE: in: same [um-id? Dt Wall th San Case 18-2868, Document 278, 08/09/2019, 2628230, Page82 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page83 of 648 DISTRICT RT DISTRICT TURF. Ill-Inn'r'r-Ir-- . n. - VIIEGIHM. L- v- GI MAKWELL lleclarn?nn of (ihislninc Man-4'35; {?rhislaine Mam-tell- d?clarnz as fniiows; 1- I am thn: in this. anti-an. 2. i haw: nu mum} authu?ljur uvcr any ma?a urguni'wiiuns, including muse media urganizatj?ns ?'lat publishmi an}.r purl. UH. January 2015 i?tiutfj Uf'l n1}- behalf T116 dirwllun 13-1? my Minn-Lay, Philip Elan-11m. Neither I nun-r any" agent acting {an h?half appmved in an}: nt'any media urganiza?nn in its decisiml tn publish at mat [a publish any purl Gf 111:: Janlmn' 2015 I dualism undicr pcnallj' ui'ptljuq- Haul Um: Ibrcguing is Inn: and annual. ExL-uulcd mum la.- E?l T- (ihislaine: Mac-:Mall Case 18-2868, Document 278, 08/09/2019, 2628230, Page84 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page85 of 648 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X Plaintiff, v. GHISLAINE MAXWELL, Defendant. .......................................... VIRGINIA L. GIUFFRE, 15-cv-07433-RWS --------------------------------------------------X Declaration of Philip Barden I, Philip Barden, declare as follows: 1. I am a Solicitor of the Senior Courts of England & Wales based in London, England. 2. I am submitting this Declaration in support of Ghislaine Maxwell’s motion for summary judgment in this action. 3. I am not authorised to and do not waive Ms. Maxwell’s attorney-client privilege. 4. I have represented Ms. Maxwell since 2011 regarding the allegations made by Plaintiff Virginia Giuffre and as published in the United Kingdom. I continue to be retained in this regard. I am familiar generally with the subject matter of this action. 5. I first represented Ms. Maxwell in this matter over the weekend of 5th and 6th March 2011, about the time when various UK national newspapers, in hard copy and on line, published numerous and provocative allegations made by the Plaintiff Virginia Giuffre against Ms. Maxwell. The articles by Sharon Churcher were among those published in this time frame. 6. I instructed British press agent Ross Gow to assist me in representing Ms. Maxwell. 1 Case 18-2868, Document 278, 08/09/2019, 2628230, Page86 of 648 7. I caused to be prepared a statement to respond to the articles that appeared in the British Press over the weekend—March 5 and 6, 2011, and thereafter. I directed Mr. Gow to distribute the statements to various media outlets that had published articles. 8. On December 30, 2014, Ms. Giuffre made numerous salacious and improper allegations against Ms. Maxwell in a joinder motion publicly filed in a civil case involving Jeffrey Epstein. Shortly afterward, the British media gained access to the motion and began inquiring about Ms. Maxwell’s response. 9. I continued to represent Ms. Maxwell at that time and I coordinated the response to the media. I again instructed Mr. Gow to assist me. 10. In liaison with Mr. Gow and my client, on January 2, 2015, I prepared a further statement denying the allegations, and I instructed Mr. Gow to transmit it via email to members of the British media who had made inquiry about plaintiff’s allegations about Ms. Maxwell. Attached as Exhibit A1 is an email containing a true and correct copy of this statement. The statement was issued on my authority. Although it is possible others suggested or contributed content, I prepared the vast majority of the statement and ultimately approved and adopted all of the statement as my work. 11. As is evident from the timing and the typographical errors in the statement, I prepared the statement in haste. I was not in the office on 2nd January 2015 as it was the Friday immediately after New Years day which is a public holiday. Most people took 2nd January off and many business closed that day. I don’t now recall where I was that day but I was hard to reach and that indicates I was out with my family. I therefore would have prepared the statement in a hurry. I recall that I wanted to get a statement out as a matter of urgency. 12. I recall that immediately after Ms. Giuffre’s motion was filed, media representatives began contacting Mr. Gow and requesting Ms. Maxwell’s response to Ms. Giuffre’s allegations 2 Case 18-2868, Document 278, 08/09/2019, 2628230, Page87 of 648 of criminal and other misconduct by Ms. Maxwell. I believed an immediate response was imperative, even though this was happening in the midst of the holidays in the United Kingdom. My communications with Mr. Gow and with Ms. Maxwell were sporadic, delayed and hurried because of my and their own holiday schedules. I worked while on vacation and on Friday, January 2, 2015, to ensure that the statement was issued as soon as possible after receiving the media inquiries. 13. I did not ask Ms. Maxwell to respond point by point to Ms. Giuffre’s factual allegations in the CVRA joinder motion. What we needed to do was issue an immediate denial and that necessarily had to be short and to the point. It should have been obvious to the media that Ms. Giuffre’s new and significantly more salacious allegations had no credibility because they differed so substantially from her previous allegations, when she had the opportunity and incentive to disclose all relevant facts about being a victim of alleged sexual abuse and sex trafficking at the hands of the rich and powerful. I prepared the January 2015 statement based on my knowledge of Ms. Giuffre’s past statements and her most recent statements in the joinder motion, and made the point to the media-recipients that she and her new statements, which differed so substantially from her former ones, were not credible—specifically, that the new allegations were patently false—i.e., “obvious lies.” 14. By way of example I recall that prior to the December 2014 filing of the joinder motion and the subsequent press reports that Ms. Guiffre clearly stated she had not had sex with Prince Andrew. Yet in her joinder motion she claimed she did have sex with Prince Andrew and that the sex occurred in what can only be described as a very small bathtub, too small for a man of Prince Andrew’s size to enjoy a bath in let alone sex. So as of December 2014 it was clear Ms. Guiffre had made polar opposite statements. She was either lying when she said they did not have sex or when she said they did. I made the inescapable inference that she is a liar, as clearly 3 Case 18-2868, Document 278, 08/09/2019, 2628230, Page88 of 648 she is, since both statements cannot as a matter of fact be true. When someone says she did not have sex and then says she did, in other words, there is an obvious lie. 15. I did not intend the January 2015 statement as a traditional press release solely to disseminate information to the media. This is why I intentionally did not request that Mr. Gow or any other public relations specialist prepare or participate in preparing the statement. Instead, Mr. Gow served as my conduit to the media representatives who had requested a response to the joinder motion allegations and who I believed might republish those allegations. 16. My purpose in preparing and causing the statement to be disseminated to those media representatives was twofold. First, I wanted to mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff’s false allegations. I believed these ends could be accomplished by suggesting to the media that, among other things, they should subject plaintiff’s allegations to inquiry and scrutiny. For example, I noted that plaintiff’s allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” 17. Second, I intended the January 2015 statement to be “a shot across the bow” of the media, which I believed had been unduly eager to publish plaintiff’s allegations without conducting any inquiry of their own. This was the purpose of repeatedly stating that plaintiff’s allegations were “defamatory.” In this sense, the statement was very much intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff’s obviously false allegations and the legal indefensibility of their own conduct. 18. It is important to understand that any story involving a member of the Royal Family, especially a senior member such as Prince Andrew, gains huge media attention in the UK and a story alleging he had a sex with the Plaintiff caused a feeding frenzy for the press. I wanted the 4 Case 18-2868, Document 278, 08/09/2019, 2628230, Page89 of 648 press to stop and think before publishing, to cease and desist, and that if they continued then they faced higher damages for ignoring my clear warning. 19. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (italics supplied). The statement was intended to be a single, one-time-only, comprehensive response—quoted in full, if it was to be used—to plaintiff’s December 30, 2014, allegations that would give the media Ms. Maxwell’s response. The purpose of the prefatory statement was to inform the media-recipients of this intent. 20. Selective and partial quotation and use of the statement would disserve my purposes. It was intended to address Plaintiff’s behavior and allegations against Ms. Maxwell on a broad scale, that is to say, Plaintiff’s history of making false allegations and innuendo to the media against Ms. Maxwell. This is why the statement references Plaintiff’s “original allegations” and points out that her story “changes”—i.e. is embellished—over time including the allegations “now” that Professor Dershowitz allegedly had sexual relations with her. This is why I distinguished in the statement between Plaintiff’s “original” allegations and her “new,” joindermotion allegations, which differed substantially from the original allegations. And this is why I wrote, “Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by [Plaintiff] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies.” (Emphasis supplied.) Having established the dramatic difference between Plaintiff’s two sets of allegations, which suggested she was fabricating more and more-salacious allegations as she had more time to manufacture them, I added the third paragraph: “[Ms. Giuffre’s] claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory.” (Emphasis supplied.) I believed then, and believe now, that it was and remains a fair inference and conclusion that her claims 5 Case 18-2868, Document 278, 08/09/2019, 2628230, Page90 of 648 were and are “obvious lies.” As noted, her claims not to have slept with Prince Andrew and to have slept with Prince Andrew are a classic example of an obvious lie. One or other account is on the face of it a lie. 21. As an example of her lack of credibility, the Plaintiff made allegations against Professor Dershowitz, which I understand she has now withdrawn. Professor Dershowitz has credibility because his story, insofar as I am familiar with it, has been consistent; Ms. Giuffre has no credibility because her story has shifted and changed. 22. Further the Plaintiff’s account has become more salacious, for example, regarding Prince Andrew. The Plaintiff clearly has been seeking publicity for her story and it is clear to me that she understands retelling the same story doesn’t feed the media and generate publicity and so each time she appears to create new allegations to generate media interest. 23. I understand the Plaintiff alleged in her Complaint in this action that the following statements are defamatory. She alleges it was defamatory in the first paragraph of the January 2015 statement to state that “the allegations made by [the Plaintiff] against [Ms.] Maxwell are untrue.” For the reasons stated above, it was and is my considered and firm opinion that, in fact, her allegations are untrue. She alleges it was defamatory to state in the same paragraph that the “original allegations” have been “shown to be untrue.” For the reasons stated above, it was and is my considered and firm opinion that, in fact, her allegations are untrue. Finally, she alleges that it was defamatory in the third paragraph to state that her claims are “obvious lies.” For the reasons stated above, it was and is my considered and firm opinion that, in fact, her claims are obvious lies. 24. Both Mr. Gow and I understood that once the January 2015 statement was sent to the media-representatives, we had no ability to control whether or how they would use the statement and we made no effort to control whether or how they would use the statement. 6 Case 18-2868, Document 278, 08/09/2019, 2628230, Page91 of 648 25. It is my understanding that some of the media-recipients of the January 2015 statement did not publish any part of the statement. I am unaware of any media-recipient publishing the statement in full. 26. The issuance of the statement fully complied with my ethical obligations as a lawyer. Indeed it was duty in representing my client’s interests to ensure that a denial was immediately issued. I would have been remiss if I had sat back and not issued a denial, and the press had published that Ms. Maxwell had not responded to enquiries and had not denied the new allegations; the public might have taken the silence as an admission there was some truth in the allegations. 27. The content of the statement was entirely based on information I acquired in connection with my role as counsel for Ms. Maxwell. 28. At the time I directed the issuance of the statement, I was contemplating litigation against the press-recipients as an additional means to mitigate and prevent harm to Ms. Maxwell. Whilst the limitation period for a pure defamation claim has now expired, claims are still being considered for example for publishing a deliberate falsehood, conspiracy to inure and other tortious acts. 29. In any such UK defamation, or other related, action Ms. Giuffre would be a defendant or a witness. 30. I directed that the statement indicate Ms. Maxwell “strongly denie[d] the allegations of an unsavoury nature,” declare the allegations to be false, give the press-recipients notice that the publications of the allegations “are defamatory,” and inform them that Ms. Maxwell was “reserv[ing] her right to seek redress.” 7 Case 18-2868, Document 278, 08/09/2019, 2628230, Page92 of 648 I declare under penalty of perjury that the foregoing is true and correct. Executed on January 2017. A Philip Bardo?? Case 18-2868, Document 278, 08/09/2019, 2628230, Page93 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page94 of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ase 18-2868, Document 278, 08/09/2019, 2628230, Page95 of 648 , 1 ' ( ; 3$*( :,71(66 -DPHV 0LFKDHO $XVWULFK 'LUHFW ( DPLQDWLRQ E 0V 0HQQLQJHU &URVV ( DPLQDWLRQ E 0U (G DUGV 5HGLUHFW ( DPLQDWLRQ E 0V 0HQQLQJHU 5HFURVV ( DPLQDWLRQ E 0U (G DUGV , , 7 6 5HSRUWHU V &HUWLILFDWH &HUWLILFDWH RI 2DWK ( ; 3/$,17,)) )OLJKW ORJV '()(1'$17 3KRWRJUDSK 3DVVSRUW &LWDWLRQ 7UDGLQJ 5HSRUW 6FKRRO 5HFRUGV ( KLELWV DWWDFKHG 2 HQ 3 2 $VVRFLDWHV &RXUW 5HSRUWHUV R 2FDOD )ORULGD R HQDVVRFV DRO FRP 10 11 12 13 '14Case 18-2868, Document 278, 08/09/2019, 2628230, Page96 of 648 Broward and Miami a lot. -Q Okay. Where did you go to high school? A Robert Morgan. Which City is that in? A I guess Miami. Okay. When did you graduate? A '98. How old are you now? A 35. When is your birthday? A I O0 you remember a woman by the name of Virginia Roberts? A Yes. And do you see her here in the room today? A Yes. When was the last time that you saw her? A Sixteen years ago. How did you meet Ms. Roberts? A She was a friend of my sister's, and that's how I met her. What is your sister?s name? (phonetic). Last name is spelled abut I still can't spell it. My stepwsister. But after so long, she's basically my sister. Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 278, 08/09/2019, 2628230, Page97 of 648 Okay. Where is Ms. A I believe Broward County. How is it that she came to introduce you to Ms. Roberts?. A She brought her to the house. And do you know how they were friends? A They met each other in rehab. What kind of rehab? A I'm not sure. I was living in Miami at the time, and I only came up once in a while to visit her. At the very end, when I moved back to Broward with my dad, that's when- home. Do you know the name of the rehab program? A No. And you do you know what the rehab program was for, drugs, alcohol? A I don't know. I guess, everything probably. Do you recall approximately what year you met Ms. Roberts? A I believe around '98. How old were you at that time? A 18. Do you know how old Ms. Roberts wasbelieve. Was she approximately your sister?s age? Owen Associates Court Reporters P.O. 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'Irq.135; 9" MIMI l" was: --I it ?My. NiQ'a?j 1' . 2,82, 07 3 I 7 . gia?rv I. 1350.5409}. Ii" any}: I . . ..-.. . . 5 1- mum: i1 . ?33Personal Information . I'yfGIUFFREOO4721 Case 18-2868, Document 278, 08/09/2019, 2628230, Page126 of 648 EXHIBIT Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page127 of 648 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS __________________________________________________ CONFIDENTIAL VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE May 3, 2016 __________________________________________________ VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. __________________________________________________ APPEARANCES: FAMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. By Brad Edwards, Esq. 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954.524.2820 brad@pathtojustice.com Appearing on behalf of the Plaintiff BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. (For Portion) 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301-2211 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE 5/3/2016 1 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page128 of 648 1 2 3 4 5 6 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, Esq. Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant 7 8 Also Present: Brenda Rodriguez, Paralegal Nicholas F. Borgia, CLVS Videographer 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 2 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page129 of 648 1 Pursuant to Notice and the Federal Rules 2 of Civil Procedure, the VIDEOTAPED DEPOSITION OF 3 VIRGINIA GIUFFRE, called by Defendant, was taken on 4 Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150 5 East 10th Avenue, Denver, Colorado, before Kelly A. 6 Mackereth, Certified Shorthand Reporter, Registered 7 Professional Reporter, Certified Realtime Reporter 8 and Notary Public within Colorado. 9 * * * * * * * I N D E X 10 11 EXAMINATION PAGE 12 MS. MENNINGER 8 13 14 15 PRODUCTION REQUEST(S): (None.) 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 3 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page130 of 648 1 INDEX OF EXHIBITS 2 3 INITIAL REFERENCE DESCRIPTION 4 Exhibit 1 Complaint and Demand for Jury Trial re Jane Doe No. 102 v. Jeffrey Epstein 17 Exhibit 2 Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in Action 21 Exhibit 3 Declaration of Virginia L. Giuffre re Jane Doe #1 and Jane Doe #2 vs. United States of America 23 Exhibit 4 Declaration of Jane Doe 3 re Jane Doe #1 and Jane Doe #2 vs. United States of America 31 Exhibit 5 Declaration of Virginia Giuffre re Bradley J. Edwards and Paul G. Cassell vs. Alan M. Dershowitz 33 Exhibit 6 FBI documentation, date of entry 7/5/13 36 Exhibit 7 Document titled Telecon, Participants Jack Scarola, Brad Edwards, Virginia Roberts. Re Edwards adv. Epstein, 4/7/11, (23 pages of transcription) 39 Exhibit 8 The Billionaire's Playboy Club, By Virginia Roberts 41 Exhibit 9 Plaintiff's Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff re Giuffre v. Maxwell 44 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 4 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page131 of 648 1 2 INITIAL REFERENCE DESCRIPTION 3 Exhibit 10 Plaintiff's Supplemental Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff 46 Exhibit 11 Undated Declaration of Virginia Giuffre re Plaintiff's Supplemental Response and Objections to Defendant's First Set of Discovery Requests served on March 22, 2016 46 Exhibit 12 Plaintiff's Second Amended Supplemental Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff 47 Exhibit 13 Mrs. Virginia Giuffre resume 67 Exhibit 14 Compilation of e-mails re Open Position - Virginia Giuffre 68 Exhibit 15 Virginia Lee Roberts passport application 180 Exhibit 16 Composite of e-mail strings 251 Exhibit 17 Compilation of e-mails between Giuffre and Silva and others 259 Exhibit 18 Compilation of e-mails between Virginia Giuffre and Sandra White 265 Exhibit 19 Compilation of e-mails between Marianne Strong and Virginia Giuffre 269 Exhibit 20 Compilation of e-mails between Virginia Roberts and Jason Richards 276 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 5 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page132 of 648 1 2 INITIAL REFERENCE DESCRIPTION 3 Exhibit 21 Compilation of e-mails between Sharon Churcher and Virginia Giuffre Exhibit 22 Compilation of e-mails among 287 Sharon Churcher, Michael Thomas, Virginia Giuffre and others Exhibit 23 Compilation of May 2011 e-mails among Sharon Churcher, Virginia Giuffre, Paulo Silva and others Exhibit 24 Compilation of June 2011 e-mails 289 between Virginia Giuffre and Sharon Churcher Exhibit 26 PR Hub Statement on Behalf of Ghislaine Maxwell article 300 Exhibit 27 1/2/15 e-mail from Ross Gow to To Whom It May Concern 309 4 284 5 6 7 8 288 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 6 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page133 of 648 1 January 19th, 2015? 2 3 A January 21st, 2015. 4 5 At the very top of the page it says Q The date it was filed. Is there a date just above the signature block? 6 A Oh, yes, sorry. 7 Q And what date -- what date was that? 8 A The 19th day of January, 2015. 9 Q Okay. 10 13 And this document is something that you believe contains the truth, correct? 11 12 Yes, there is. A To the best of my knowledge at the time, Q All right. yes. Did something change between 14 the time then and today that makes you believe that 15 it's not all accurate? 16 A Well, as you can see, in line 4 on page 1, 17 I wasn't aware of my dates. 18 best to guesstimate when I actually met them. 19 I was just doing the Since then I've been able to find out that 20 through my Mar-a-Lago records that it was actually 21 the summer of 2000, not the summer of 1999. 22 Q Oh, I'm sorry. 23 A On the first page. 24 Q Okay. 25 A Yes. Are you back on page 1? VIRGINIA GIUFFRE 5/3/2016 25 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page134 of 648 1 Q And you're talking about line 4? 2 A Line 4. 3 Q Paragraph 4 or line 4? 4 A Oh, sorry. 5 6 7 8 number 4. Q A And what part of paragraph 4 do you In approximately -MR. EDWARDS: 10 12 Okay. now believe to be untrue? 9 11 Number 4, the paragraph Object to the form. You can answer. A In approximately 1999 when I was 15 years old I met Ghislaine Maxwell. 13 Q (BY MS. MENNINGER) 14 A I now know that it was 2000, that I was 16 15 16 Okay. years old when I met Ghislaine Maxwell. Q So when you signed this document under 17 penalty of perjury stating that it was true, you no 18 longer believe that to be true, correct? 19 A It was an honest mistake. We had no idea 20 how to pinpoint without any kind of records or dates 21 or anything like that. 22 chronologically through time. 23 time that I thought it was. 24 facts, so it's good to know. 25 Q I was just going back And that's the best And now I know the So you now believe that a document you VIRGINIA GIUFFRE 5/3/2016 26 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page135 of 648 1 filed under oath is no longer true, correct? 2 3 4 5 6 MR. EDWARDS: A Object to the form. I wouldn't say that it wasn't true. just unaware of the times and the dates. Q (BY MS. MENNINGER) Again, is there more than one truth, Ms. Roberts? 7 A No, there's no more than one truth. 8 Q All right. So a document in which you 9 swore that you were 15 years old when you met 10 Ms. Ghislaine Maxwell is an untrue statement, 11 correct? 12 13 I was MR. EDWARDS: A Object to the form. It's not that it's an untrue statement. 14 It was a mistake. 15 to say something that wasn't true. 16 knowledge that I thought it was 1999. 17 my records from Mar-a-Lago I was able to find out 18 that it was 2000. 19 found out the actual dates that I did work at 20 Mar-a-Lago. 21 Q 22 So it wasn't intentionally trying It was to my best And when I got And this was entered before I (BY MS. MENNINGER) Okay. So a document that you filed under oath -- 23 A Um-hum. 24 Q -- is now, you believe to be untrue, 25 correct? VIRGINIA GIUFFRE 5/3/2016 27 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page136 of 648 1 2 3 MR. EDWARDS: Asked and answered. Q 4 5 Objection. (BY MS. MENNINGER) MR. EDWARDS: A You may answer. Answer again. Again, I wouldn't say it's untrue. Untrue 6 would mean that I would have lied. 7 This was my best knowledge at the time. 8 very best to try to pinpoint time periods going back 9 such a long time ago. 10 And I didn't lie. And I did my It wasn't until I found the facts that I 11 worked at Mar-a-Lago in 2000 that I was able to 12 figure that out. 13 Q (BY MS. MENNINGER) And approximately when 14 did you learn those facts about the dates you worked 15 at Mar-a-Lago? 16 A I would say it was mid-2015. 17 Q Mid-2015 is the first time you became 18 aware of the dates -- 19 A I don't know the exact -- 20 Q If you could just let me finish. 21 A I'm sorry. 22 Q That's all right. Approximately mid-2015 23 when you learned the true dates that you had worked 24 at Mar-a-Lago? 25 A That's correct. Sorry. VIRGINIA GIUFFRE 5/3/2016 28 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page137 of 648 1 a lot of the circumstances that I had been subjected 2 to, I decided I wanted to get my GED. 3 4 Q Okay. So you were going to an actual school to get your GED, that's what you're saying? 5 A Yes. 6 Q And that school, whatever it was, where 7 you were getting your GED was not Palm Beach High 8 School, right? 9 A No. 10 Q And it -- whatever the school was where 11 you were getting your GED took a summer break? 12 A I believe so, yes. 13 Q And that was in 2000? 14 A Now that we know the right dates, yes. 15 Q And that's when your dad helped you get a 16 quote-unquote summer job? 17 A Yes. 18 Q All right. 19 Mar-a-Lago? 20 A Yes. 21 Q Okay. And that summer job was Now tell me how you sort of came 22 into Mar-a-Lago for the first time? 23 come? 24 25 They called you? A He asked you to What happened? My dad was very liked there. he talked to the people who were in HR. VIRGINIA GIUFFRE 5/3/2016 So I think And then 57 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page138 of 648 1 mic higher up on your jacket, please? 2 THE DEPONENT: 3 THE VIDEOGRAPHER: 4 THE DEPONENT: 5 Sure. Tell me if that's okay. Better? 6 A Okay. 7 Q (BY MS. MENNINGER) 8 Thank you. Page 40? Right. Do you see the first full paragraph on that page? 9 A I do. 10 Q The first line begins: I spent my sweet 11 16th birthday on his island in the Caribbean next to 12 Little (sic) St. James Isle. 13 Little St. Jeff's. 14 appetite for fornicating. 15 He liked to call it His ego was enormous as his Do you see that sentence? 16 A I do. 17 Q That is not true, correct? You were not 18 spending your sweet 16th birthday on Little St. James 19 Isle, correct? 20 A Based on my knowledge at the time that I 21 wrote this manuscript, I thought I did spend my 16th 22 birthday there. 23 that. And so I put it down in there as Now I know that it wasn't my 16th birthday. 24 Q Or your sweet 16th birthday? 25 A Well, we -VIRGINIA GIUFFRE 5/3/2016 101 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page139 of 648 1 2 3 4 5 MR. EDWARDS: Harassing. Q (BY MS. MENNINGER) A Is it not custom to call your 16th birthday sweet? 7 before? 9 10 Q A 15 16 17 18 19 20 Was it your sweet 16th birthday, As we -MR. EDWARDS: She's answered the question. It's been asked and answered. 13 14 Have you never heard that saying Ms. Giuffre? 11 12 Was it your sweet 16th birthday? 6 8 Object to the form. MS. MENNINGER: actually. Q She asked me a question, You're not testifying here. (BY MS. MENNINGER) Was it your sweet 16th birthday? A As I thought, in the manuscript when I wrote it, I thought it was my sweet 16th birthday. Q Okay. Now that you know it wasn't, where did you spend your sweet 16th birthday? 21 A Well, I don't know. 22 Q Well, just give us your best guess. 23 MR. EDWARDS: Objection. 24 going to guess today. 25 answers as she remembers them. And she's not She's going to tell you the VIRGINIA GIUFFRE 5/3/2016 102 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page140 of 648 1 A Again, I don't know. 2 Q Do you recall any present you actually got 3 on your sweet 16th birthday? 4 5 A No, I don't. I don't know where I spent it, who I spent it with or what I got. I'm sorry. 6 Q How long did you work at Mar-a-Lago? 7 A Best of my recollection, it was a summer 8 job. 9 only worked there approximately two weeks, two, three I believe I started in June. And I think I 10 weeks. 11 Q How many hours a week did you work? 12 A I want to say it was a -- I want to say 13 it's a full-time job. 14 Q Do you recall it being a full-time job? 15 A It was a summer job, but just thinking 16 back, my dad used to bring me in and bring me home. 17 So he worked full time, all day. 18 lounge around Mar-a-Lago so, yes, I think it would 19 have been a full-time job. So -- and I didn't 20 Q And how much did you make per hour? 21 A Approximately, I think I remember making 22 $9 an hour. 23 Q The bracelet and earrings you got for your 24 birthday, some birthday, on Little -- or where was 25 that birthday party, at Little St. James? VIRGINIA GIUFFRE 5/3/2016 104 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page141 of 648 1 Q Which brother? 2 A Sky. 3 Q What about your other brother? 4 A I think he had moved out by then. 5 Q What forms of communication did you have? 6 Just a home phone number, or what? 7 A Yeah, there was a home phone. 8 Q When do you recall ever getting a cell 9 phone? 10 A 11 12 13 14 The first cell phone I ever got was the one that Ghislaine gave to me. Q So you never had -- your parents, did they have ones when you were working at Mar-a-Lago? A No, my dad used to -- like, we had phones 15 in the spa and maintenance area and so on, so forth. 16 And you could, so to speak, page people from around 17 the courts. 18 Q Okay. So tell me what you recall of the 19 first conversation that you had with Ghislaine 20 Maxwell. 21 A I'm sitting there reading my book about 22 massage therapy, as I'm working in the spa. 23 getting my GE -- well, I was in the process of 24 getting my GED before I went to my summer job. 25 decided that I would like to become a massage VIRGINIA GIUFFRE 5/3/2016 And I'm I 113 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page142 of 648 1 A Yes. 2 Q Who else was at home when you got home? 3 A My mom, my dad and my brother. 4 Q Which brother? 5 A Sky. 6 Q And anyone else who was there at the time? 7 A I believe Michael might have been living 8 with me at that time. 9 10 11 Q So he might have been there. Do you recall if he was there when you got home? A I don't really remember. I remember what 12 I did when I got home, that I basically made a 13 beeline for the bathroom. 14 Q Let me ask you a question. Michael was 15 living with you at that home, at your parents' home 16 at the time, is your best recollection today; is that 17 right? 18 A That's my best recollection, yes. 19 Q When you say living with you, were you 20 guys staying in the same room? 21 A Yes. 22 Q Were you engaged at that time to him? 23 A That was a really weird relationship. He 24 was a friend who looked after me, and he did propose 25 to me and I did say yes. But my heart was never in VIRGINIA GIUFFRE 5/3/2016 127 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page143 of 648 1 it. 2 3 4 He was somebody that helped me off the streets so I felt compelled to say yes to him. Q Okay. So when he proposed to you and you 5 said yes, did that take place before you started 6 working at Mar-a-Lago or after you started working at 7 Mar-a-Lago? 8 A Before. 9 Q And so if he were living with your parents 10 at that time, you were living in the same room; is 11 that correct? 12 A I believe so. 13 Q And your parents understood him to be your 14 15 16 17 18 19 fiance? A I don't think they agreed with it, but I think they understood it as that. Q I mean -- I mean, you communicated to them that he had proposed and you had accepted? A Yeah, in not such a pretty way. 20 they obviously weren't very happy about it. 21 wasn't my true intentions to ever marry him. I mean, And it 22 Q Okay. 23 A But I did it to make him feel okay. 24 25 I didn't want to be mean. Q What did your mom say about your VIRGINIA GIUFFRE 5/3/2016 128 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page144 of 648 1 2 know where it was when she said to go do this. Q (BY MS. MENNINGER) Okay. Where were you 3 sent to have sex with the owner of a large hotel 4 chain by Ghislaine Maxwell? 5 MR. EDWARDS: Object to the form. 6 A I believe that was one time in France. 7 Q (BY MS. MENNINGER) 8 A I believe it was around the same time that 9 10 Which time in France? Naomi Campbell had a birthday party. Q Where did you have sex with the owner of a 11 large hotel chain in France around the time of Naomi 12 Campbell's birthday party? 13 A In his own cabana townhouse thing. It was 14 part of a hotel, but I wouldn't call it a hotel. 15 Jeffrey was staying there. Ghislaine was 16 staying there. Emmy was staying there. 17 staying there. This other guy was staying there. 18 don't know his name. 19 20 I was I was instructed by Ghislaine to go and give him an erotic massage. 21 Q She used the words erotic massage? 22 A No, that's my word. 23 24 25 I what they would use. Q The word massage is That's their code word. Was she in the room when you gave this erotic massage to the owner of a large hotel chain? VIRGINIA GIUFFRE 5/3/2016 203 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page145 of 648 1 2 3 A No, she was not in the room. She was in another cabana. Q And other than telling you to go give the 4 owner of this large hotel chain a massage, do you 5 remember any other words she used to you to direct 6 you in what you should do? 7 A Not at the time, no. 8 Q Where did -- where were you and where was 9 10 Ms. Maxwell when she directed you to go have sex with Marvin Minsky? 11 MR. EDWARDS: Object to the form. 12 A I don't know. 13 Q (BY MS. MENNINGER) 14 15 Where did you go to have sex with Marvin Minsky? A I believe it was the U.S. Virgin Islands, 16 Jeff's -- sorry, Jeffrey Epstein's island in the U.S. 17 Virgin Islands. 18 Q And when was that? 19 A I don't know. 20 Q Do you have any time of year? 21 A No. 22 Q Do you know how old you were? 23 A No. 24 Q Other than Glenn Dubin, Stephen Kaufmann, 25 Prince Andrew, Jean Luc Brunel, Bill Richardson, VIRGINIA GIUFFRE 5/3/2016 204 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page146 of 648 1 another prince, the large hotel chain owner and 2 Marvin Minsky, is there anyone else that Ghislaine 3 Maxwell directed you to go have sex with? 4 5 A I am definitely sure there is. remember everybody's name? 6 Q 7 about them? 8 A 9 Okay. No. Can you remember anything else now. Look, I've given you what I know right I'm sorry. This is very hard for me and very 10 frustrating to have to go over this. 11 don't recall all of the people. 12 amount of people that I was sent to. 13 14 But can I Q I don't -- I There was a large Do you have any notes of all these people that you were sent to? 15 A No, I don't. 16 Q Where are your notes? 17 A I burned them. 18 Q When did you burn them? 19 A In a bonfire when I lived at Titusville 20 21 because I was sick of going through this shit. Q Did you have lawyers who were representing 22 you at the time you built a bonfire and burned these 23 notes? 24 A 25 I've been represented for a long time, but it was not under the instruction of my lawyers to do VIRGINIA GIUFFRE 5/3/2016 205 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page147 of 648 1 this. 2 and we believed that these memories were worth 3 burning. 4 My husband and I were pretty spiritual people Q So you burned notes of the men with whom 5 you had sex while you were represented by counsel in 6 litigation, correct? 7 MR. EDWARDS: 8 9 10 A document. 12 This wasn't anything that was a public This was my own private journal, and I didn't want it anymore. 11 Q Object to the form. So we burned it. (BY MS. MENNINGER) When did you write that journal? 13 A Just over time. I started writing it 14 probably in, I don't know, I can't speculate, 2012, 15 2011. 16 17 Q So you did not write this journal at the time it happened? 18 A No. 19 Q You started writing this journal 20 approximately a decade after you claim you finished 21 being sexually trafficked, correct? 22 A Yes. 23 Q And you started writing a journal after 24 25 you had a lawyer, correct? A Correct. VIRGINIA GIUFFRE 5/3/2016 206 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page148 of 648 1 2 Q Including Mr. Edwards, who is sitting right here, correct? 3 A Correct. 4 Q What did that journal look like? 5 A It was green. 6 Q And what else? 7 A It was just a spiral notebook. 8 Q Okay. 9 10 And what did you put into that green spiral notebook? A Bad memories. Things that I've gone 11 through, lots of things, you know. 12 There was a lot of pages. 13 that book. 14 15 Q I can't tell you. It was over 300 pages in Did you ever show that book to your lawyers? 16 A No. 17 Q Did you show that book to anyone? 18 A My husband. 19 Q Did you show it to anyone else besides 20 your husband? 21 A No. 22 Q Did you tear out pages and give them to 23 24 25 Sharon Churcher? A No, I wrote -- those pages that you're talking about, I wrote for her specifically. VIRGINIA GIUFFRE 5/3/2016 She 207 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page149 of 648 1 wanted to know about the Prince Andrew incident. 2 Q So that's a different piece of paper? 3 A Yeah, that's just random paper. 4 Q So you had a green spiral notebook that 5 you began sometime in 2011 or 2012 in which you wrote 6 down your recollections about what had happened to 7 you, and you burned that in a bonfire in 2013. 8 Did I get that right? 9 A You got that right. 10 Q And do you have no other names of people 11 to whom you claim Ghislaine Maxwell directed you to 12 have sex, correct? 13 A At this time, no. 14 Q Is there any document that would refresh 15 16 your recollection that you could look at? A If you have a document you'd like to show 17 me, I would be glad to look at it and tell you the 18 names I recognize off of that. 19 20 Q I'm just asking you if there's a document you know of that has this list of names in it? 21 A Not in front of me, no. 22 Q Where is the original of the photograph 23 that has been widely circulated in the press of you 24 with Prince Andrew? 25 A I probably still have it. VIRGINIA GIUFFRE 5/3/2016 It's not in my 208 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page150 of 648 1 2 3 other terms of his probationary period? A No. He went to everything that he was supposed to go to. 4 Q Has he paid his fines? 5 A Yes, as far as I know. 6 Q Describe for me the contract that you had 7 8 9 10 11 12 with the Mail On Sunday? A Could you be a little bit more specific? Like -Q Have you had more than one contract with the Mail On Sunday? A Well, there was one contract for the 13 picture. And that was to pay me 140,000 for the 14 picture. And then two stories were printed after 15 that for the amount of 10,000 each. 16 17 Q Is that the only money that you received from the Mail On Sunday? 18 A Correct. 19 Q Did you receive any money for syndication 20 of the photograph? 21 A Isn't that what the 140 was for? 22 Q I'm asking you. 23 A Well, I don't really know what syndication 24 means. 25 Q Did you have a written contract with the VIRGINIA GIUFFRE 5/3/2016 247 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page151 of 648 1 Mail on Sunday? 2 A Yes. 3 Q Where is that contract right now? 4 A I don't know. 5 I -- I lose paperwork wherever I go. 6 7 I've moved that many times. Q Is it possible it's in the boxes in Sydney? 8 A I don't think I kept it, to be honest. 9 Q Did you ever refer back to it after you 10 signed it? 11 A I know I kept it for a short while, but I 12 mean, like I said, I've moved countries twice in the 13 last two years and three different houses. 14 paper trail is lost. I don't know where it would be. 15 Q Did you receive it via e-mail? 16 A No. 17 So the I received it -- Sharon Churcher handed it to me by paper. 18 Q And you signed it? 19 A I signed it. 20 Q And then did you make a copy of it? 21 A No. 22 Q You never had a copy of it? 23 A Well, I had my own copy. 24 25 I'm sure she has hers. Q Do you recall there being a period of VIRGINIA GIUFFRE 5/3/2016 248 Agren Blando Court Reporting2628230, & Video, Inc. Case 18-2868, Document 278, 08/09/2019, Page152 of 648 1 STATE OF COLORADO) 2 ) 3 COUNTY OF DENVER ) 4 ss. REPORTER'S CERTIFICATE I, Kelly A. Mackereth, do hereby certify 5 that I am a Registered Professional Reporter and 6 Notary Public within the State of Colorado; that 7 previous to the commencement of the examination, the 8 deponent was duly sworn to testify to the truth. 9 I further certify that this deposition was 10 taken in shorthand by me at the time and place herein 11 set forth, that it was thereafter reduced to 12 typewritten form, and that the foregoing constitutes 13 a true and correct transcript. 14 I further certify that I am not related to, 15 employed by, nor of counsel for any of the parties or 16 attorneys herein, nor otherwise interested in the 17 result of the within action. 18 19 20 In witness whereof, I have affixed my signature this 11th day of May, 2016. My commission expires April 21, 2019. 21 22 23 ____________________________ Kelly A. Mackereth, CRR, RPR, CSR 216 - 16th Street, Suite 600 Denver, Colorado 80202 24 25 VIRGINIA GIUFFRE 5/3/2016 345 Case 18-2868, Document 278, 08/09/2019, 2628230, Page153 of 648 may. 23. 2010(3050508-2868, Document 278, 08/09/2019, 2628230, Page1540f48118 F- 2 Page: 1 Document Name: untitled PANEL: A07. ASSIGNMENT HISTORY YEAR: 16 T234 Monday May 23, 2016 9:04 am STDT: 12870606 ROBERTS, VIRGINIA SCHL: 3390 GR: 10 ST: 1 A ENTRY WITHDRAWAL CD DATE CD CD DATE PF SY CL DS SCHL DESC GR PRS ABS UNX R02 101201 W26 030702 02 01 3390 SURVIVORS 10 56 '31 R02 092001 W02 101101 02 01 2331 ROYAL PALM HIG 10 13 1 081401 W32 092001 02 A1 2192 HS ADL 30 EA1 081600 m? W47 081301 01 Al m? 2192 HS ADL 3O EA1 062100 Hm W47 081500 00 A1 mm 2192 HS ADL 30 E01 081699 mm W03 081699 00 01 ?m,2331 ROYAL PALM HIG 10 E01 081998 W02 060999 99 01 0581 FOREST HILL H1 09 155 25 E01 082097 W01 061098 98 01 2331 ROYAL PALM HIG 09 147 33 E01 082097 W22 082097 98 01 2191 WELLINGTON HIG 09 R03 040797 W02 061197 97 01 1691 CRESTWOOD MID 08 40 5 301 082294 DNE 082294 95 01 1703 ROYAL PINES SC 06 E01 082393 W02 061094 94 01 1901 LOXAHATCHEE EL 05 167 13 E01 082592 W01 061193 93 01 1901 LOXAHATCHEE EL 04 176 PAGE PAGE TERML: 11B5 Date: 5/23/2016 Time: 9:05:36 AM Case 18-2868, Document 278, 08/09/2019, 2628230, Page155 of 648 TO 00000 I 50 PALM BEACH SCHOOL: $390 DEMOGRAPHIC INFORMATION GRADE LEVEL: 10 1 TE: 03? CURRENT DISTRICT: 50 PALM BEACH PAGE CURRENT 3390 SURVIVURS CHARTER SCHOOL LEGAL NAME: ROBERTS, VIRGINIA :561) 712-1800 MAILING 12959 RACKLEY RD ;310 CONGRESS AVE ADDRESS: LUXAHATCHEE FL 33470 EST PALM BEACH FL 13409 DISTRICT STUDENT ID: 12070606 FL STUHRNT ID-ALIAS: MIGRANT STUDENT Th: 00000000000 SEX: SKY ROBERTS PARENT BIRTH VERTPICATION: LYNN ROBERTS PARENT CA 1 1 LACE SACRAMENTO IMMUNIZATION STATUS: PERMANENT IMMUNIZATION CERTIFICATE VACCINE STATUS, DATE- VACCINE CERTTFICATE EXPIRATION DATE: TYPE DOSE DATE DOSE DATE DOSE DATE DOSE DATE DOSE urn 1 11/02/1983 2 02/33/1984 5 04/27/1994 4 04/24/1987 5 09/27/1900 T0 1 06/24/1997 FOLIO 1 11/02/1983 2 02/03/1984 3 04/24/1987 4 HIB 1 04/24/1967 MMR 1 04/24/1937 MEASLES 1 04/24/1957 HEP 30053 1 04/19/1997 2 06/24/1997 1 09/03/1999 (I 04/10/1997 COURSE TNFORMATION -- DISTRICT: 50 SCHOOL: 3390 N0 COURSES TAKEN 50 SCHOOL: 1901 LOXAHATCHEE GROVES ELEM YEAR: 1989-1990 GRADE LEVEL: NA YEAR: 1991-1393 GRADE LEVEL: 03 SUBJECT CRSF CREDIT GPA QTY PTS GPA QTY PTS POURSE TITLE AREA FLAG CRD 4286 5.00 CUM: 1.5429 27.00 3 5100090 THIRD GRADE 0.00 0.00 STATE TERM: 1.4736 5.00 CUM: 1.5429 27.00 CREDIT, TERM: 0.00 0.00 1989~1990 ANNUAL DAYS-PRESENT: 0 ABSENT: 1991-1992 ANNUAL DAYS-PRESENT: 180 ABSENT: 0 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 SUMMER TERMS DAYS-PRESENT: 0 ABSENF: 0 ACADEMICALLY PROMOTED DISTRICT: 50 SCHOOL: 3390 N0 COURSES TAKEN DISTRICT: 50 SCHOOL: 1301 GROVES ELEM. YEAR: 1990-1991 GRADE NA YEAR: 1932-1993 GRADE LEVEL: 04 SUBJECT CRSE CREDIT GPA QTY PTS GPA QTY PTS COURSE TITLE AREA FLAG GRD DISTRICT-TERM: 1.4286 5.00 CUM: 1.5129 27.00 3 5100100 FOURTH GRADE 0.00 0.00 STATE-TERM: 1.4286 $.00 CUM: 1.5429 27.00 CREDIT, TERM: 0.00 U.00 1990?1991 ANNUAL DAYS PRESENT. 0 ABSENT: 0 1992-1995 ANNUAL DAYS-PRESENT: 176 ABSENT: 4 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 SUMMER TERMS 0 0 ACADEMICALLY PROMOTED ACADEMICALLY PROMOTED OFFICIAL TRANSCRIPT THE SCHOOL 015mm or A PALM BEACH COUNTY FLORID APR 1 2008 RECORDS CUSTODMN Case 18-2868, Document 278, 08/09/2019, 2628230, Page156 of 648 TU 0000050 PALM BEACH SCHOOL: 3390 COURSE TNPORMATTON FILE: TE: 03 Jl 2008 CURRENT DISTRICP: 50 PALM BEACH PAGE 2 CURRENT SCHOOL: 3590 CHARTER SCHOOL LEGAL NAME: ROBERTS, VIRGINIA (561) 712-1800 50 SCHOOL: 1901 LOXAHATCHEE GROVES ELEM. 50 SCHOOL: 3131 ROYAL PALM BEACH COMM HIC 1993?1994 GRADE LEVEL: 05 YEAR: 1997?1998 GRADE LEVEL: 09 SUBJECT CRSB SUBJECT CREE CREDIT COURSE8 COURSE TITLE AREA FLAG GRD COURSE TITLE AREA FLAG CRD 3 5100110 FIFTH GRADE 0.00 0.00 0708340 SPANISH 1 FL RJ .50 .00 3 $100110 FIFTH GRADE 0.0C 0.00 CREDIT, TERM: 0.00 0.00 1001310 ENG 1200370 ALGEBRA IA MA JR .50 0.00 1503400 BEG PE SC 0.00 1993-1994 ANNUAL DAYS-PRESENT: 167 ABSENT: 13 0.00 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 0 0 0 ACADEMICALLY PROMOTED 2001310 9C1 SC 2100410 CARTRBEAN STUDIES EL .50 .50 .00 .00 .50 .50 .50 .50 .50 0.50 .50 0.50 50 0.50 1 1 1 8500355 NUTRITION WELLNESS VO 7 1001310 ENG 1 EN RJ A DISTRICT: 50 SCHOOL: 1390 NO COURSES TAKEN 2 1200170 ALGEBRA 1A MA JR YEAR: 1994HI995 GRADE LEVEL: NA 2 1501300 PERS FIT PE RJ A 2 2001310 SCI SF A 2 2103300 WORLD CULT GEOG EL GPA QTY PTS CPA QTY PTS DISTRICT-TERM: 1.4286 5.00 CUM: 1.5429 27.00 STATE-TERM: 1.4286 5.00 CUM: 1.5429 27.00 50 SCHOOL: 9034 ESE CTHER TEACHING SERV YEAR: 1997-1998 GRADE LEVEL: 09 1994-1995 ANNUAL DAYS-PRESENT: 0 ABSENT: 0 SUBJECT CRSE CREDIT SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 COURSE TITLE AREA FLAG GRD NOT ENROLLED IN DISTRICT K?l? AT END OF SCHOOL YEAR 4 1200370 AIORERA MA JR 8 0.50 0.50 5 2001310 SPT SC A 0.50 0.50 DISTRICT: 30 SCHOOL: 1691 CRESTWOOD MIDDLE CREDIT, TERM: 7.00 4.00 YEAR: 199b?1997 GRADE LEVEL: 08 SUBJECT CRSE CREDIT GPA QTY PTS GPA QTY PTS COURSE TITLE AREA FLAG CR3 DISTRICT TERM: 1.0571 13.00 CUM: 1.8571 13.00 0400010 DRAMA 2 0.00 .00 STATE TERM: 1.8571 13.00 CUM: 1.0571 13.00 8500240 TEEN 0.00 .00 1001070 LANG ARTS 3 0.00 .00 1997~1998 ANNUAL DAYS PRESENT: 0 ABSENT: 1205070 MATH 3 0.00 .00 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 2002100 COMPRE SCI 3 0.00 .00 NOT ENROLLED IN K-12 AT END OF SCHOOL YEAR 2103050 AND CHO 0.00 .00 CREDIT, TERM: 0.00 .00 thmrorunm 1996-1997 ANNUAL DAYS-PRESENT: 40 ABSENT: 5 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 ACADEMTCALLY PROMOTED OFFICIAL TRANSCRIPT THE SCHOOL DISTRICT 0? PALM BEACH COUNTY. FLORIDA APR 1 2008 RECORDS CUST DIAN Case 18-2868, Document 278, 08/09/2019, 2628230, Page157 of 648 TO LEGAL NAME: ROBERTS, VIRGINIA DISTRICT: 50 SCHOOL: 0581 FOREST HILL HIGH YEAR: 1998-1999 GRADE LEVEL: 09 SUBJECT CRSE CREDIT COURSE TITLE AREA FLAG GRD 050C500 DEV 1 EL .50 0.50 0701320 FRENCH 1 FL RJ .50 0.50 1001340 ENG 2 EN RJ .50 0.50 120C380 ALGEBRA IE MA JR 50 0.00 1900300 DRIVER ED CLASS EL .50 0.50 2000310 BIOLOGY 1 SC RJ .50 0.50 2109310 WORLD H15T WH RJ .50 0.50 0500500 DEV 1 EL .50 0.00 0701320 FRENCH 1 FL RJ 50 0.00 0800J00 MGMT SKL LM .50 0.00 1001340 ENG 2 EN RJ .50 0.00 1200380 ALGEBRA IB MA JR .50 0.00 2000310 1 SC RJ .50 0.00 2109310 WORLD HIST NH RJ .50 0.00 CREDIT, TERM: 7.00 3.00 GPA QTY FPS GPA QTY PTS DISTRICT TERM: 1.2857 9.00 CUM: 1.5714 22.00 STATE-TERM: 1.2557 9.00 CUM: 1.5714 22.00 1998~1999 ANNUAL DAYS-PRESENT: 155 ABSENT: 25 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 ACADEMICALLY PROMOTED DISTRICT: 50 SCHOOL: 3390 N0 COURSES TAKEN YEAR: 1999 2000 GRADE LEVEL: NA GPA QTY PTS GPA QTY PTS DISTRICT-TERM: 1.4286 5.00 CUM: 1.5429 27.00 STATE TERM: 1.4286 5.00 CUM: 1.5429 27.00 1999 2000 ANNUAL DAYS-PRESENT: 0 ABSENT: 0 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: NOT ENROLLED IN DISTRICT K-12 AT END OF SCHOOL YEAR 0000050 PALM BEACH SCHOOL: 3390 COURSE INFORMATION FILE: SRTC1RTS EPARED 008 CURRENT DISTRICT: SC PALM BEACH PAGE 3 CURRENT SCHOOL: 3390 SURVIVORS CHARTER SCHOOL {561) 712?1800 DISTRICF: 50 SCHOOL: 3390 NO COURSES TAKEN YEAR: 2000-2001 GRADE LEVEL: NA GPA QTY FTS GPA QTY PTS DISTRICT-TERM: 1.4286 5.00 CUM: 1.5429 27.00 STATE-TERM: 1.4286 5.00 CUM: 1.5429 27.00 2000-2001 ANNUAL DAYS-PRESENT: 0 ABSENT: 0 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: 0 PROMOTION STATUS NOT APPLICABLE DISTRICT: 50 SCHOOL: 3390 SURVIVORS CHARTER SCHOOL YEAR: 2001-2002 GRADE LEVEL: 10 SUBJECT CRSE CREDIT COURSE TITLE AREA FIAG GRD 1 0500530 DEV 4 EL .50 0.50 1 1001440 BUSINESS ENG 1 EN .50 0.50 1 1205370 CONSUMER MATH MA .50 0.50 1 8300310 WORKPLACE ESSENTIALS V0 .50 0.50 1 8301610 WORK EXP 1 V0 .50 0.03 8101650 WORK EXP-OJT V0 .00 0.03 CREDIT, TERM: 3.5 2.00 LJGL)mink GPA QTY PTS GPA QTY PTS DISTRICT-TERM: 1.4286 5.00 CUM: 1.542? 27.00 STATE-TERM: 1.4286 5.00 CUM: 1.5429 27.00 2001-2002 ANNUAL DAYS-PRESENT: 0 ABSENT: 0 SUMMER TERMS DAYS-PRESENT: 0 ABSENT: PROMOTION STATUS NOT APPLICABLE OFFICIAL TRANSCRIPT THE SCHOOL OF PALM BEACH COUNTY. FLORIDA APR 1 2008 RECORDS Case 18-2868, Document 278, 08/09/2019, 2628230, Page158 of 648 T0 - 0000030 PALM REACH LEGAL NAME: A I A AS OF: GRADUATION OPTION: 4-YR STANDARD - - - CREDITS - - SUBJECT TOTAL TOTAL TOTAL AREA TO DATE NEEDED REMAINING ENGLISH (EN) 0.00 4.00 2.00 MATHEMATICS (MA) .50 3.00 1.50 SCIENCE (SC) .50 3.00 1.50 AMER HISTORY (AH) .00 1.00 1.00 WORLD HTSTORY (NH) .50 1.00 0.50 ECONOMICS (EC) .00 0.50 0.50 AMER GOVERNMENT (AG) .00 0.50 0.50 (v0/ .50 PERFORM FINE ART (PF) .00 .00: 0.50A LIFE MGMT SKILLS (LN) .00 0.50 0.50 PHYSICAL ED (PE) .50 0.50 0.00 FOREIGN LANGUAGE (FL) .50 0.00 LANGUAGE ARTS (LA) .00 SOCIAL STUOIES (ss) .00 ELECTIVE (EL) .00 9.00 0.50 ESE (EX) .00 COMPUTER ED (CE) .00 CREDITS, CUMULATIVE: .00 24.00 15.00 . TOTALS INCTUDE VOCATIONAL 0 PERFORM FINE ARTS- (1w. ms GPA CITY st . 1.5429 27.00 STATE: 1.5429 27.00 - +l>ri+SCHOOL: 3390 GRADUATION SUMMARY FILE: SRTSIZIS 03/31'2008 CURRENT DISTRICT: 50 PALM BEACH PAGE 4 CURRENT SCHOOL: $3.90 SURVIVORS CHARTER SCHOOL [561) 712-1800 VOCATIONAL PROGRAM COMPLETION STATUS- NUMBER: 8500355 NUTRITION WELLNESS TERMINATION: IN PROGRESS COMPLETED: VOCATIONAL PROGRAM COMPLETION NUMBER: 8300310 WORKPLACE ESSENTIALS TN PROGRESS VOCATIONAL PROGRAM COMPLETION STATUS- NUMBER: 8301610 WORK EXP TERMINATION: IN PROGRESS COMPLETPD: VOCATIONAL PROGRAM COMPLETION STATUS- NUMBER: 8301650 WORK EXP-OJT I COMPLETED: DISTRICT CLASS EFFECTIVE DATE: 03/06/2002 CLASS RANK, NUMERICAL es CLASS RANK, PERCENTILE: 70 CLASS RANK, TOT . NUMBER IN CLASS: 214 DATE PASSED ASSESSMENT TEST FOR GRADUATION COMMUNICATIONS: 10/2001 MATHEMATICS: 01/2002 COMMUNITY SERVICE HOURS: 0 REQUTFEMENT MET: OFFICIAL TRANSCRIPT THE SCHOOL DISTRICT OF PALM BEACH COUNTY. FLORIDA APR 1 2008 RECORDS CUSTODIAN Case 18-2868, Document 278, 08/09/2019, 2628230, Page159 of 648 TC - DISTRICT: BEACH SCHOOL: 3390 COMMENTS FILE: GRADE LEVEL: 13 PREPARED DATE: 03/31/2008 CURRENT DISTRICT: 50 PALM BEACH PAGE 5 CURRENT SCHOOL: 5590 SURVIVORS CHARTER SCHOOL LEGAL NAME: ROBERTS, VIRGINIA (561! 712"1000 DEFLNITION OF TERM CODES - CCDE DEFINITION CODE DEFINITION CODE DEFINITION CODE DEFINITICN CODE DEFINITION 1 SEMESTER 1 COMBINED SUMMER TRIMESTER 1 QUINMESTER SIX WEEKS SEMESTER 2 SESSION TRIMESTER 2 OUINMESTER SIX WEEKS ANNUAL THIMESTER 3 SIX WEEKS 4 5 1 9 1* 3 SUMMER SESSION 1 QUARTER 1 OUINMESTER SIX WEEKS 4 6 INTERSESSION 2? INTERSESSION 3? INTERSESSION 4? INTERSESSTON 5' Hf?it'l?'zn WKAU: SUMMER SESSTON 2 QUARTER 2 QUINMESTER SIX WEEKS QUARTER 3 YEAR OF QUARTER 4 3?1220 SHORT SIX WEEKS USED OF SUMMER SCHOOL SESSIONS) WITH YEAR-ROUND SCHOOL RECORDKEEPING USED ONLY FOR WORKFORCE DEVELOPMENT EDUCATION (ADULT GENERAL AND POSTSECONDARY VOCATIONAL EDUCATION) USED ONLY FOR REPORTING STUDENTS WHO HAVE WITHDRAWN BETWEEN SCHOOL YEARS STATE GRADING SCALE FOR HIGH SCHOOL STUDENTS (REGARDLESS 0F ENTRY DATE) EFFECTIVE SCHOOL YEAR 1997-1998 GRADING SCALE, EFFECTIVE GRADE QUALITY GRADE QUALITY GRADE QUALITY GRADE EQUIVALENT POINTS GRADE EQUTVALENT POINTS GRADE EQUIVALENT POINTS A - 90 - 100 4.00 80 - 89 3.00 - 7O - 79 2.00 60 - 69 1.00 0 - 59 0.00 GRADING SCALE, PRIOR TO 07/01/2001 GRADE QUALITY GRADE QUALITY GRADE QUALITY GRADE EQUIVALENT POINTS GRADE EQUIVALENT POINTS GRADE EQUIVALENT POINTS A 94 - 100 4.00 a 85 - 93 3.0C 77 - 84 2.00 70 76 1.00 0 - 69 0.0C NOTE: FROM THE 1987-1988 THROUGH THE 1996-1997 SCHOOL YEARS, FOR STUDENTS ENTERING HTGH SCHOOL DURING THESE YEARS, THE GRADE EQUIVALENTS FOR C, D, AND WERE: 75-84, 55-74, AND 0-64; QUALITY POINTS AND ALL OTHER GRADES WERE THE SAME AS THOSE SHOWN IN THE IMMEDIATELY PRFCEDING STATE GRADING SCALE. 996100383de Case 18-2868, Document 278, 08/09/2019, 2628230, Page160 of 648 TC DISTRICT: 0000050 SCHOOL: J390 COMMENTS FILE: SRTSI2IS GRADE LEVEL: 13 PREPARED DATE: 03/31/2008 CURRENT 50 PALM BEACH SCHOOL: 339:) SURVIVORS CHARTER scncou LEGAL NAME: ROBERTS, (561] 712-1800 STATE DEFINED COURSE FLAGS SCHOLAR-ELECTIVE SCHOLAR REQUIREMENT H?Houons CREDIT TN apn FROM PROM STATE CPA p=couusn IS IN PROGRESS AWARDED BY SLEP EXAM T-TRANSFERRED COURSE VOCATIONAL SUBSTITUTION COURSES- AIR PC SUB FOR LIFE MGMT SUB FOR PRAC ARTS SUB FOP PRACTICAL ARTS ED SUB FOR PRACTICAL ARTS FOR BUS EN I 1001440 FOR BUS EN I 1001440/11 1001450 deUE FOR MA I 1205540 FOR MA I 1205390 FOR GEN SCI 2002310 FOR ANAT PHYSIO 2000350 FOR PRE ALGEBRA 1200300 CST GD SUB FOR SCIENCE AIR FC SUB FOR SCIENCE NAVY SUB FOR SCIENCE ARMY SUD FOR LIFE MGMT MARTNE SUB FOR LIFE MGMT FOR BIO TECH 2000430 FOR BNV SCI 200134C FOR PHY SPT 2001110 FOR COURSE SPECIFIED 0N FOLLOWING LINE ON COURSE LIST ELL LANGUAGE INSTRUCTION LANGUAGE ESOL INSTRUCTION (ELEMENTARY SELF-CONTAINED) INSTRUCTION FY 1991-1992 COMMENTS THE PALM BEACH COUNTY SCHOOL DISTRICT AWARDS THE HIGH SCHOOL VAI.IDICTORTAN AND SALUTATORIAN USING A GPA AVERAGE THAT IS BASED ON COURSES TAKEN IN GRADES 9 12. HOWEVER, THE GPA ALL CREDIT COURSES. Case 18-2868, Document 278, 08/09/2019, 2628230, Pagel61 of 648 F0 DISTRICT: PALM BEACH SCHOOL: 3390 CATEGORY TNPOUMATION FILE: 03 31/2008 CURRENT DISTRICT: bU PALM BEACH PAGE 7 CURRENT SCHOOL: 3390 SURVIVORS CHARTER SCHUOL (561) 712-1800 03/07/9002 CODE: WES HOME LANGUAGE SURVEY DATE: 0&l15/2000 COUNTRY OF BIRTH: US UNITED STATES NATIVE LANGUAGE: EN ENGLISH PRIMARY HOME LANGUAGE: EN ENGLISH HEALTH EXAMINATION, SCHOOL ENTRY: SCHOOL ENTRY HEALTH EXAMINATION CERTIFIED. - STUDENT INFORMATION STUDENT PLAN DATE: 05/11/1999 CURRENT DATE: 05/11/2002 PRIMARY EXCEPTIONALITY: FEPP PROGRAM: EXCEPTIONAL STUDENT PROGRAM INFORMATION EVALUATION PLACE- DISMLS- PLACEMENT REFERRAL COMPLETE DETERM MENT SAL EXCEPTIONALITY STATUS DATE DATE DATE DATE ELIGIBLE AND PLACED 05/10/99 05/11/99 05/11/99 05/11/99 05/00/99 ELIGIBLE AND PLACED 02/03/90 02/04/98 02/04/90 02/04/90 00/11/96 DROPOUT PREVENTION PROGRAM INFORMATLON DROPOUT PREVENTION PROGRAM PLACEMENT REASONS OUTCOMES EDUCATIONAL ALTERNATIVE PROGRMS ACADEMICALLY UNSUCCESSFUL DOCUMNTD ACADMC PERFORMANCE EDUCATLONAL ALTERNATIVE PROGRMS ACADEMICALLY UNSUCCESSFUL DOCUMNTD ACADMC PERFORMANCE EDUCATIONAL ALTERNATIVE PROGRMS ACADEMICALLY UNSUCCESSFUL DOCUMNTD ACADMC PERFORMANCE TEST TEST LEVEL SUBJECT SCORE SCORE SUBJECT SCORE scnag SUBJECT SCORE SCORE GRD DATE NAME POEM FONTENT TYPE TYPE CONTENT TYPE TYPE CONTENT TYPE TYPE 30 06/:6/2000 TAB 7 A TOTBAT GE 0000 GE 0000 GE 0000 LANGUAGE GE Olin 30 00/;5/2000 TAB 4 TOTHAT GE 0000 GE 0000 CE 0126 LANGUAGE GE 0000 30 L6/;b/2000 TAB TUTUAT GE 0000 GE 0073 GE 0000 LANGUAGE GE C000 09 04/20/1990 0T0 A 19 COMPREHE ss 0801 COMPREHB NP 0005 SS 0750 NP 0034 SCIENCE 35 0000 SCIENCE NP 0000 ss 0000 NP 0000 136700385306 Case 18-2868, Document 278, 08/09/2019, 2628230, Page162 of 648 T0 - DISTRICT: 0000050 PALM BEACH SCHOOL: 3390 TEST INFORMATION FILE: SRTSIQIS GRADE LEVEL: 10 PREPARED DATE: 03/31'2008 CURRENT DISTRICT: 50 PALM BEACH PAGE 8 OF 0 CURRENT SCHOOL: 3390 SURVIVORS CHARTER SCHOOL LEGAL NAME: ROBERTS, VIRGINIA (561) TEST TEST TEST LEVEL SUBJECT SCORE SCORE SUBJECT SCORE SCORE SUBJECT SCORE SCORE HRH MATH NAME FORM CONTENT TYPE TTPF CONTENT TYPE TYPE CONTENT TYPE TYPE 08 04/15/1997 CTB 17 READIT) SS 0000 NP 0000 MATHIT) SS 0000 NP 0000 COMPREHE SS 0780 COMPREHE NP 0077 COMPUTAT SS 0000 COMPUTAT NP 0000 VOCAD SS 0000 08 04/18/1997 9TB NP 0003 SS 0798 NP 0070 05 04/22/1994 CTB 15 COMPREHE SS 0700 NP 0032 SS 0667 NP 0010 LANGUAGE SS 0694 LANGUAGE NP 0026 SS 0646 NP 0008 SS 0742 05 04/22/199a CTR 15 up 0061 on 03/29/1993 CTB A 14 SS 0711 NP 0059 SS 0568 NP 0022 COMPREHE SS 0735 COMPREHE NP 0074 COMPUTAT SS 0667 COMPUTAT NP 0021 VOCAB ss 0686 04 03/29/1993 CTB A 14 VOCAB NP 0043 55 0669 NP 0024 SCIENCE SS 0707 SCIENCE NP 0049 SS 0692 NP 0034 04 02/10/1993 WAP 04 NR NAHRA SS 0000 WR EXPOS V) 0000 WRITING U: 0000 03 04/00/1992 CTB A L3 COMPREHE SS 0733 COMPREHE NP 0085 SS 0649 NP 0026 LANGUAGE SS 0696 LANGUAGE NP 0050 SS 0679 NP 0044 SS 0712 01 04/08/1992 CTR A 11 NP 0056 02 C4/l6/1991 CTD A 12 SS 0663 NP 0000 SS 0467 NP 0001 COMPREHE SS 0659 COMPREHE NP 0051 COMPUTAT SS 0337 COMPUTAT NP 0001 VDCAB SS 0667 02 CPB A 12 VOCAB NP 0070 SS 0597 NP 0028 END OF TRANSCRIPT Case 18-2868, Document 278, 08/09/2019, 2628230, Page163 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page164 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK 3 CASE: 15-cv-07433-RWS 4 VIRGINIA GIUFFRE, 5 Plaintiff, 6 v. 7 GHISLAINE MAXWELL, 8 9 Defendant. ____________________/ 10 VIDEOTAPED DEPOSITION OF TONY FIGUEROA 11 Volume 1 of 2 12 Pages 1 - 157 13 14 15 Taken at the Instance of the Defendant 16 17 DATE: Friday, June 24, 2016 TIME: Commenced: Concluded: PLACE: Southern Reporting Company B. Paul Katz Professional Center (SunTrust Building) One Florida Park Drive South Suite 214 Palm Coast, Florida 32137 REPORTED BY: LEANNE W. FITZGERALD, FPR Florida Professional Reporter Court Reporter and Notary Public 18 19 20 21 22 8:59 a.m. 1:22 p.m. 23 24 25 Southern Reporting Company (386)257-3663 1 Case 18-2868, Document 278, 08/09/2019, 2628230, Page165 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 APPEARANCE OF COUNSEL 2 3 4 ON BEHALF OF THE PLAINTIFF: 5 BRADLEY J. EDWARDS, Esquire Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue Ft. Lauderdale, Florida 33301 954-524-2820 Brad@pathtojustice.com 6 7 8 9 10 ON BEHALF OF THE DEFENDANT: 11 LAURA A. MENNINGER, Esquire Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 303-831-7364 Lmenninger@hmflaw.com; Nsimmons@hmflaw.com 12 13 14 15 16 Also appearing: Jenny Martin, Videographer from Abel Virginia Giuffre, Plaintiff 17 18 19 20 21 22 23 24 25 Southern Reporting Company (386)257-3663 2 Case 18-2868, Document 278, 08/09/2019, 2628230, Page166 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 3 INDEX 2 3 ---------------------------------------------------- 4 VOLUME 1 (pages 1 - 157) 5 TONY FIGUEROA Direct Examination by Ms. Menninger 5 6 OATH OF REPORTER 156 CERTIFICATE OF REPORTER 157 7 8 --------------------------------------------------9 VOLUME 2 (Pages 158 - 258) 10 162 218 243 253 13 TONY FIGUEROA Cross-Examination by Mr. Edwards Redirect Examination by Ms. Menninger Recross-Examination by Mr. Edwards Further Direct Examination by Ms. Menninger 14 OATH OF REPORTER 257 15 CERTIFICATE OF REPORTER 258 11 12 16 --------------------------------------------------- 17 - - 18 19 20 21 STIPULATION It is hereby stipulated and agreed by and 22 between counsel present at this deposition and by 23 the deponent that the witness review of this 24 deposition would be waived. 25 Southern Reporting Company (386)257-3663 Case 18-2868, Document 278, 08/09/2019, 2628230, Page167 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 4 INDEX OF EXHIBITS 2 3 (MARKED BY THE DEFENDANT:) 4 5 Defendant's Exhibit 1 (Palm Beach County Sheriff's Reports Case Number 98041883) 42 Defendant's Exhibit 2 (Greenacres Reports) 71 Defendant's Exhibit 3 (Two Pictures of Apartment Building) 77 Defendant's Exhibit 4 (Palm Beach County Sheriff's Reports Case Number 02075321) 83 6 7 8 9 10 11 12 13 Defendant's Exhibit 5 (Royal Palm Beach Police Reports) 134 Defendant's Exhibit 6 (Robert's School Records) 144 14 15 16 - - - 17 18 (MARKED BY THE PLAINTIFF:) 19 Plaintiff's Exhibit 1 (Photos) 162 Plaintiff's Exhibit 2 (Passport) 163 20 21 22 23 - - 24 25 Southern Reporting Company (386)257-3663 Case 18-2868, Document 278, 08/09/2019, 2628230, Page168 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 BY MS. MENNINGER: 2 Q 3 Beach? 4 A 5 And where did you go after Royal Palm I believe it was South Area. I'm pretty sure it was South Area. 6 Q Did you go to another school after that? 7 A Yeah. 8 Q Is that also in Royal Palm Beach? 9 A No. 10 Worth. 11 alternative schools. 12 13 Q I went to Gold Coast after that. That's -- South Area was in Lake Gold Coast is in West Palm. They were both Did you ever go to a Survivors Charter School? 14 A Yes. 15 Q When did you go there? 16 A I'm not exactly sure of the date. I went there, too. But it 17 was somewhere after either -- I'm pretty sure it 18 was -- maybe -- I can't remember if it was Gold 19 Coast first or Survivor. 20 trying to remember. 21 one came first. 22 Q 23 24 25 But one of the -- I'm I honestly don't remember which That's all right. Can you describe for me Survivors Charter School? A What is it like, or was it like? I mean, like I said, it was an alternative Southern Reporting Company (386)257-3663 23 Case 18-2868, Document 278, 08/09/2019, 2628230, Page169 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 school. 2 kids, you know, who have gotten kicked out. 3 was pretty much like a last chance kind of school, 4 you know what I mean? 24 It was just pretty much a bunch of bad 5 Q Does it look like a school? 6 A Kind of. And it I mean, it had, like, a 7 cafeteria, and then it had a whole bunch of, like, 8 portables and stuff around there. 9 under -- it was, like, right near the Lake Worth. 10 remember there was, like, a bridge that went over 11 the interstate right by it. 12 just a little, you know, little crappy school. And it was I But, I mean, it was 13 Q Was it during the day or at night? 14 A It was during the day. 15 Q So regular school hours? 16 A Yeah. Well, it was actually a little bit 17 shorter hours. 18 know it was not like the full days. 19 mean, at the alternative schools, it's obviously not 20 up to regular high school standards. 21 just do pretty much stuff to get people to get out 22 of school, you know, so... I can't remember exactly. Because, I I mean, they 23 Q Get the credits that you need? 24 A Yeah. 25 But I So that way they can finish high school and not drop out and whatnot, so... Southern Reporting Company (386)257-3663 Case 18-2868, Document 278, 08/09/2019, 2628230, Page170 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 2 Q You actually go there in the morning, though, and take classes? 3 A Yeah. 4 Q And get checked in at attendance? 5 A Yeah. 6 Q And then you may leave a little earlier 7 than a regular school day? 8 A Uh-huh (affirmative). 9 Q All right. 10 A No, it was not online. 11 Q When you were at Survivors Charter School, 12 13 It's not a online program? did you ever see Ms. Roberts there? A Was it Survivors? I don't remember if it 14 was Survivors. 15 we were both -- was it -- I know we both went to one 16 of the schools. 17 maybe. 18 Q Did you see her there? 19 A Now, when we went to the school, like, we Or was it -- because I'm pretty sure I'm pretty sure it was Survivors, 20 were together afterwards. But I don't remember 21 exactly which one it was. I know it was one of 22 those alternative schools that we went to, though. 23 24 25 Q Okay. Did you -- was Wellington an alternative school? A No. Wellington is a -- is a real high Southern Reporting Company (386)257-3663 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page171 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 school, like a regular high school. 2 3 Q program? 4 5 Do you know if Wellington has an adult A They might. I mean, I really don't know. I'm not sure. 6 Q Did you ever take night classes there? 7 A No. 8 Q So you believe when you reunited with 9 10 Ms. Roberts in or around 2001, she had also gone to one of those alternative schools? 11 12 A When I reunited with her, no. We ended up, like, trying to go finish school. 13 Q Tell me about that. 14 A I mean, we just ended up going to one of 15 those alternative schools and didn't even finish 16 that. 17 18 Q So you two had both left school, but went back together -- 19 A Yeah. 20 Q -- to one of the alternative schools? 21 A Yeah. 22 Q And that may have been Survivors Charter 23 24 25 School? A Yeah. I'm pretty sure it probably was. I'm pretty sure. Southern Reporting Company (386)257-3663 26 Case 18-2868, Document 278, 08/09/2019, 2628230, Page172 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 Q You both wanted to get your GEDs? 2 A Yeah. 3 Q Get better jobs? 4 A Uh-huh (affirmative). 5 Q Things like -- that was the plan? 6 A Yeah. 7 Q But it did not work out? 8 A Yeah. 9 Q Do you know how long the two of you went 10 to Survivors Charter School? 11 A I honestly don't remember. 12 Q Okay. 13 You do have a recollection of going with her, though? 14 A Yeah. 15 Q Seeing her there? 16 A Uh-huh (affirmative). 17 Q I'm trying to get a little bit of a time 18 frame on the time that you reunited with 19 Ms. Roberts. 20 remember being in an apartment with her in September 21 of 2000 -- 9/11/2001; right? I know you said you lived -- you 22 A Yeah. 23 Q Do you think you had been together with 24 25 her for a while at that point? A It was probably, I'd say, like a month or Southern Reporting Company (386)257-3663 27 Case 18-2868, Document 278, 08/09/2019, 2628230, Page173 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 so. 2 long after I had moved in, so... 3 4 Like, I'm pretty sure. Q Because it was not too And just to be clear, she already lived in the apartment? 5 A Yeah. She lived in the apartment with her 6 ex-boyfriend Michael and JJ. 7 somebody else. 8 9 Q And I think there was I don't remember who, though. All right. That's where she was living when you reunited with her? 10 A Yeah. 11 Q And then you moved in? 12 A Yeah. 13 Q Did the other people move out? 14 A Yeah. 15 Q How long did you live there with 16 28 I kicked them out. Ms. Roberts? 17 A I think it was just till, like, the end of 18 the lease, so it was probably maybe, like, five or 19 six months. 20 not exactly [sic] on the whole time frame. 21 I'm pretty sure. I don't know. I'm Q That's okay. 23 A Yeah. 24 Q Where did you two move from there? 25 A I believe we either -- we went to her -- 22 I understand it was a while ago. Southern Reporting Company (386)257-3663 Case 18-2868, Document 278, 08/09/2019, 2628230, Page174 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 it was either her family's house or mine. 2 either one of the two. 3 another -- we were renting a house out in 4 Loxahatchee also, eventually. 5 a little trailer behind her parents' house. 6 7 8 9 10 Q It was And then we ended up getting But we also stayed in When did your relationship with Ms. Roberts end the second time? A When she went to Thailand and -- (Brief interruption.) A -- never heard from her again. 11 THE COURT REPORTER: 12 re-answer? 13 A Yeah. I'm sorry. Can you When Jeffry sent her to Thailand. 14 And then I never heard from her again until 15 freaking, like, two days ago. 16 BY MS. MENNINGER: 17 Q You heard from her two days ago? 18 A Yeah. She had called me to apologize 19 about, obviously, everything about me getting 20 dragged into this mess. 21 much about, you know, the way shit ended, and pretty 22 much tried just -- her apologizing mainly about 23 dragging me all into this and having to make me 24 get -- you know, knowing how I have my family and 25 stuff now. And we talked just pretty And that was pretty much it, so... Southern Reporting Company (386)257-3663 29 Case 18-2868, Document 278, 08/09/2019, 2628230, Page175 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 Q Another instant connection. 2 A Uh-huh (affirmative). 3 Q From the time Ms. Roberts left to go to 4 Thailand until today, have you seen her? 5 A 6 Nope. And to be honest, it still does not even 7 feel real that she's sitting right there across from 8 me. 9 10 11 Q Well, you offered to get in touch with her a couple of times? A I know. But, like I said, it's just -- it 12 still does not seem like this is actually happening. 13 Like, she's -- I don't know. 14 ghost or seeing one. It's like talking to a 15 Q Does she look different now? 16 A Yeah. 17 Q How? 18 A Just more mature, more older. 19 Q When you were with Ms. Roberts the first 20 time in '98 -- 21 A Uh-huh (affirmative). 22 Q -- you believe that relationship lasted 23 24 25 just a couple of weeks? A Yeah. I'm not exactly sure, but it was pretty brief. Southern Reporting Company (386)257-3663 37 Case 18-2868, Document 278, 08/09/2019, 2628230, Page176 of 648 Video Deposition of Tony Figueroa (Volume 1) 125 1 A I believe so, yes. 2 Q What did she tell you about that? 3 A I -- I think that maybe he -- I mean, I 4 don't know exactly. 5 remember hearing about him, but I don't remember 6 what she said about him. 7 8 Q I don't really remember. I Did Ms. Roberts ever tell you that she had met Al Gore? 9 A Not that I'm aware of. 10 Q Did Ms. Roberts ever tell you that she had 11 met a foreign president? 12 A I'm not sure; I'm not sure. 13 Q Did Ms. Roberts ever tell you she had met 14 a prime minister? 15 A I don't know. 16 Q Did Ms. Roberts ever tell she had met a 17 18 senator? A Not that I'm aware of. I mean, she's told 19 me that she met a bunch of people before. 20 it started becoming, like, an almost everyday thing 21 about -- just hearing about famous people with 22 Jeffrey and stuff like that, it's, like, I kind of 23 didn't, like, tone it out, but I just -- it became 24 normal, so I just stopped, like, listening to all 25 the details, because I was not going to meet these Southern Reporting Company (386)257-3663 And after Case 18-2868, Document 278, 08/09/2019, 2628230, Page177 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 people, you know what I mean? 2 right. 3 Q 4 It's just, like, all Was she excited that she was meeting famous people? 5 A Yeah. 6 Q Was that a job perk? 7 A Obviously. 8 Q She talked about it a lot? 9 A Yeah. 10 Q To the point where you were drowning it A Well, that's what I'm saying. 11 12 out? It was not 13 like I was drowning it out. 14 she was with Jeffrey, and he was, obviously, 15 well-connected with everybody. 16 you know, a special occasion, per se. 17 was, but it's not like it was -- it was not very not 18 rare so... 19 20 Q It's just I knew that So it was not like, You know, it Did she show you any photographs of herself with famous people? 21 A No. 22 Q Did you see a photograph of her with 23 Prince Andrew -- 24 A Yes. 25 Q -- in her possession? Southern Reporting Company (386)257-3663 126 Case 18-2868, Document 278, 08/09/2019, 2628230, Page178 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 2 BY MS. MENNINGER: Q Mr. Figueroa, you mentioned that you and 3 Ms. Roberts attempted to go to back to school while 4 you were together -- 5 A Yes. 6 Q -- to get your GED? 7 A Yeah. 8 Q And you believe that you went to the 9 10 Survivors Charter School? A 11 12 15 16 17 18 Yes. MS. MENNINGER: Okay. I'm going to mark Defendant's Exhibit 6. 13 14 Yes. (Defendant's Exhibit 6 was marked for identification.) BY MS. MENNINGER: Q This is a school record for Ms. Roberts that lists the names of various schools. A And -- So it was Survivors, obviously. That's 19 the only one on that list that isn't -- or that's 20 there that's on mine, as well. 21 Q Okay. 22 A Other than the other ones, but... 23 Q All right. 24 25 So you recognize Survivors Charter School on Ms. Roberts' school records? A Yeah. That's what I'm saying. Southern Reporting Company (386)257-3663 Since that 144 Case 18-2868, Document 278, 08/09/2019, 2628230, Page179 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 is the one on here, that's -- that's completely 2 clear. 3 Gold Coast. 4 Q I could not remember if it was that one or Okay. There is an entry date for 5 Ms. Roberts at Survivors Charter School of 6 10/12/2001, and a withdrawal on 3/7 of '02. 7 see that? 8 9 10 11 12 13 14 15 A I mean, it's this; right? Do you I mean, that's the top. Q The entry date of 10/12/01, withdrawal 3/7/02 at Survivors? A Okay. I did not know what those numbers -- I did not realize that that was a date. Q I understand. And I know you did not make this record. 16 So I'm just wanting to know if that's 17 consistent with your recollection, that you guys 18 went to school in the fall of 2001 until the -- 19 A Yeah, that sounds about right. 20 Q -- March of 2002. 21 A Yeah. 22 Q And you both went to school together? 23 A Uh-huh (affirmative). 24 Q In the mornings? 25 A Yeah. It sounds right? Southern Reporting Company (386)257-3663 145 Case 18-2868, Document 278, 08/09/2019, 2628230, Page180 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 2 Q 146 And got out of school at some earlier time than a regular school day? 3 A Yeah. 4 Q Do you recall Ms. Roberts going to Royal 5 Palm Beach High? 6 frame. 7 A I -- I don't recall. 8 Q Do you recall her, during the time you 9 10 Again, this is in the 2001 time were with her, taking any night classes at Wellington High School? 11 A I don't recall. 12 Q Is it possible? 13 A It's a possibility. 14 15 16 17 I really don't. MR. EDWARDS: Object to the form. BY MS. MENNINGER: Q Do you know whether Wellington has a night school program? 18 A 19 could. 20 Q You went there in ninth grade? 21 A Yeah. 22 23 24 25 Like I said before, I don't know. They It was during the day, though. I have no clue about night school. Q Got it. But you do have a memory about Survivors Charter School? Southern Reporting Company (386)257-3663 Case 18-2868, 08/019ng 2602?3g0dn ialge181 of 648 eposmon 156 l?guer CERTIFICATE OF OATH STATE OF FLORIDA COUNTY OF FLAGLER I, the undersigned authority, certify that TONY FIGUEROA personally appeared before me on June 24, 2016, and was duly sworn. WITNESS my hand and official seal this 5th day of July, 2016. Maj/i?gw Leanne W. Fitzgerald Notary Public - State of Florida My Commission No. FF060921 Expires: February 8, 2018 Digital Certificate Authenticated By Symantec Southern Reporting Company (386)257-3663 Case 18-2868, Document 278, 08/09/2019, 2628230, Page182 of 648 Video Deposition of Tony Figueroa (Volume 1) 1 CERTIFICATE OF REPORTER 2 STATE OF FLORIDA 3 COUNTY OF VOLUSIA ) ) ) 4 5 6 7 8 9 10 11 12 I, Leanne W. Fitzgerald, Court Reporter, do hereby certify that I was authorized to and did stenographically report the deposition of TONY FIGUEROA; and that the foregoing transcript is a true record of my stenographic notes. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. 13 Dated this 5th day of July, 2016. 14 15 16 17 18 19 20 __________________________________ Leanne W. Fitzgerald, FPR Florida Professional Reporter 21 22 Digital Certificate Authenticated By Symantec 23 24 25 Southern Reporting Company (386)257-3663 157 Case 18-2868, Document 278, 08/09/2019, 2628230, Page183 of 648 EXHIBIT !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page184 of 648 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS __________________________________________________ CONFIDENTIAL VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II November 14, 2016 __________________________________________________ VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. __________________________________________________ APPEARANCES: BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 405 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page185 of 648 1 2 3 4 5 6 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura Menninger, Esq. Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant 7 8 Also Present: Ann Lundberg, Paralegal Maryvonne Tompkins, Videographer 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 406 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page186 of 648 1 Pursuant to Notice and the Federal Rules 2 of Civil Procedure, the continued video 3 deposition of VIRGINIA GIUFFRE, called by Defendant, 4 was taken on Monday, November 14, 2016, commencing at 5 8:04 a.m., at 150 East 10th Avenue, Denver, Colorado, 6 before Pamela J. Hansen, Registered Professional 7 Reporter, Certified Realtime Reporter and Notary 8 Public within Colorado. 9 * * * * * * * I N D E X 10 11 VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II 12 EXAMINATION 13 By Ms. Menninger PAGE 354 14 15 16 17 18 19 20 21 22 23 24 25 !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 472 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page187 of 648 1 INDEX OF EXHIBITS (continued) 2 INITIAL REFERENCE 3 DESCRIPTION 4 Exhibit 1 Settlement Agreement and General Release 355 Exhibit 2 List of names 370 Exhibit 3 Photocopy of photograph 408 Exhibit 4 Photocopy of photograph, with attachments 411 Exhibit 5 Photocopy of photograph, with attachments 417 Exhibit 6 Photocopy of photograph, with attachments 423 12 Exhibit 7 Statements 437 13 Exhibit 8 History of education, with attachment 462 Exhibit 9 Application for Employment, with attachment 474 Exhibit 10 The Great Outdoors Community Services Association, Inc. Termination Form, with attachments 481 Exhibit 11 7/6/2016 letter to Schultz from Hayek, with attachments 484 Exhibit 12 Patient Registration Information, with attachments 490 Exhibit 13 CVS Prescription Records document, 7/29/2016, with attachment 502 Exhibit 14 Affidavit of Custodian of Records, Walgreen Company, with attachments 507 5 6 7 8 9 10 11 14 15 16 17 18 19 20 21 22 23 24 25 !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 47. !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page188 of 648 1 INITIAL REFERENCE DESCRIPTION 2 Exhibit 15 Patient Health Summary, Clifton Beach Medical & Surgical, printed on 6/28/2016 512 Exhibit 16 Portions of deposition transcript of Virginia Giuffre taken May 3, 2016 533 Exhibit 17 Amendment/Errata Sheet signed May 31, 2016 by Virginia Giuffre 540 8 Exhibit 18 Ad for Mar-a-Lago Club 548 9 Exhibit 19 The Mar-a-Lago Club, L.C. Employment Policies, October 28, 1995 549 Exhibit 20 Page from the Mar-a-Lago Club Employment Policies, Revised 10/2001 550 3 4 5 6 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 471 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page189 of 648 1 A Yes. 2 Q And you believe the Neiman Marcus was 3 4 located in which city? A Well, it's around Fort Lauderdale. 5 can't tell you exactly. 6 like Broward County? I Fort Lauderdale is so big, Is that the word for it? 7 Q And what did you do at Neiman Marcus? 8 A I worked in the changing rooms. 9 Q And what did you do in the changing room? 10 A I think I just like -- if I remember 11 right, I just put clothes away that people left in 12 there. 13 sizes for women who wanted different sizes of the 14 same product. 15 16 Q Probably went out to get sizes, different And where did you work after Neiman Marcus? 17 A Taco Bell. 18 Q Did you work at Southeast Employee 19 20 Management Company? A I don't recognize that. I don't know if 21 that's a payroll company or what it is. 22 what Southeast -- what is it called? I don't know 23 Q Southeast Employee Management Company. 24 A No, I don't remember that. 25 Q Did you ever work as a temp? !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 082 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page190 of 648 1 A Not that I remember. 2 Q Going to different offices and filling in? 3 A No. 4 Q Did you work for Oasis Outsourcing? 5 A I don't -- I don't know if that's a 6 payroll company or if that's an actual place, but 7 that doesn't ring a bell. 8 9 10 11 Q Did you -- do you know how much you got paid when you were working at places like Oasis Outsourcing? A Well, considering I don't know if I worked 12 at Oasis Outsourcing, I wouldn't even know how much I 13 got paid. 14 15 Q Did you review your Social Security records? 16 A Yes. 17 Q You saw Oasis Outsourcing listed there? 18 A Right, but like I said, it doesn't even 19 20 21 22 ding a bell at all. Q Do you know how much money they said you made from them? MS. MCCAWLEY: Objection. If you want to 23 show her the documents, she can see what amount is 24 listed and answer your questions, but if you're not 25 going to show her the document, that's the best she !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 08. !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page191 of 648 1 don't know where I was living. 2 3 Q Okay. Did you indicate whether you had gone to school? 4 A Yes, I did. 5 Q What did you indicate? 6 A I indicated that I attended Survivors 7 Charter School for four years and had a high school 8 diploma. 9 Q And you graduated? 10 A Well, I didn't. I just wanted to get a 11 job, and I wanted it to look good, so I fluffed it 12 up. 13 14 Q So you wrote that down in your handwriting on this application, correct? 15 A I did. 16 Q And it was not true, correct? 17 A Again, I'm not proud of it. I just didn't 18 have any other way of getting a job and I just 19 thought if I put that down there, I might be 20 considered. 21 Q You indicated when you were younger you 22 volunteered for six years at a riding clinic. 23 the name of the riding clinic? 24 25 A Vince Ramos. What's And I'm not too sure if it was six years, but I started off there quite young, !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 087 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page192 of 648 1 a former employer is the Indigo Bar and Grill, 2 correct? 3 A Yes. 4 Q Is that true? 5 A No, it was not. 6 Q On the page before that, it indicates you 7 went to Royal Palm Beach High School. 8 your handwriting? Is that in 9 A Yes, it is. 10 Q And it says you went for four years and 11 you graduated? 12 A Yes. 13 Q In your handwriting? 14 A Yes. 15 Q Is that true? 16 A No. 17 Q This was an application you filled out in 18 January of 2014, correct? 19 A Correct. 20 Q The page before that is your -- portion of 21 your resume I think we have previously discussed, but 22 just confirming, you did send that resume to this job 23 application, correct? 24 A I did. 25 Q And you indicated you had worked at !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 054 !"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67 Case 18-2868, Document 278, 08/09/2019, 2628230, Page193 of 648 1 STATE OF COLORADO) 2 ) 3 COUNTY OF DENVER ) 4 ss. REPORTER'S CERTIFICATE I, Pamela J. Hansen, do hereby certify that 5 I am a Registered Professional Reporter and Notary 6 Public within the State of Colorado; that previous to 7 the commencement of the examination, the deponent was 8 duly sworn to testify to the truth. 9 I further certify that this deposition was 10 taken in shorthand by me at the time and place herein 11 set forth, that it was thereafter reduced to 12 typewritten form, and that the foregoing constitutes 13 a true and correct transcript. 14 I further certify that I am not related to, 15 employed by, nor of counsel for any of the parties or 16 attorneys herein, nor otherwise interested in the 17 result of the within action. 18 19 20 In witness whereof, I have affixed my signature this 23rd day of November, 2016. My commission expires September 3, 2018. 21 22 23 _______________________________ Pamela J. Hansen, CRR, RPR, RMR 216 - 16th Street, Suite 600 Denver, Colorado 80202 24 25 !"#$"%"&'$"())#*'!+,(-*'""'../.0/12.3 734 Case 18-2868, Document 278, 08/09/2019, 2628230, Page194 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page195 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS SOCIAL SECURITY ADMINISTRATION OFFICE OF CENTRAL OPERATIONS 6100 WABASH AVENUE BALTIMORE MARYLAND 21215 Date: 10/25/2016 BOIES SCHILLER AND FLEXNER 401 LAS OLAS BLVD STE 1200 FORT LAUDERDALE FL 33301-2211 We are sending the statement of earnings requested for: Number Holder's Name: VIRGINIA GIUFFRE Social Security Number: Years Requested: 1998 THRU 2002; 2013 THRU 2015 Control Number: 16294125319 Remittance Number: 201610240012 Enclosure(s): Earnings Statement GIUFFRE009175 'Ivnmlu- . .. WV Case 18-2868, Document 278, 08/09/2019, 2628230, Page196 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS SOCIAL SECURITY ADMINISTRATION EARNINGS RECORD INFORMATION Date: 10/25/2016 Our records show the amount of earnings reported, not the amount of Social Security taxes that were paid. Wages were first covered under Social Security in 1937. Therefore, 1937 is the first year for which earnings may be shown on our records. Employers were required to report earnings semi-annually in 1937, and on a quarterly basis for the years from 1938 through 1977. Beginning with 1978, employers are required to report earnings annually. Our records do not show the exact date of employment (month and day) because we do not need this information to figure Social Security benefits. Employers do not give us this information. Each year, there is a maximum amount of earnings that is subject to Social Security taxes and is used to compute benefits. If a person earns more than this maximum amount, the earnings statement will usually show the maximum rather than the total earnings. Maximum benefits can be found on the SSA website. Beginning in 1951, self-employed persons could also receive Social Security credit for their work. The maximum amounts of self-employment earnings that are subject to Social Security taxes and are used to compute benefits can also be found on the SSA website. If you have any questions, you should call, write, or visit any Social Security office. If you visit or call, please bring this letter. It will help us answer questions. The toll free number to call is 1-800-772-1213 (for the deaf or hard of hearing, call our TTY number, 1-800-325-0778). GIUFFRE009176 CONHDENHAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page197 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS FROM: SOCIAL SECURITY ADMINISTRATION OFFICE OF CENTRAL OPERATIONS 6100 WABASH AVENUE BALTIMORE MARYLAND 21215 NUMBER HOLDER NAME: VIRGINIA GIUFFRE YEARS REQUESTED: 1998 THRU 2002; 2013 THRU 2015 BOIES SCHILLER AND FLEXNER 401 LAS OLAS BLVD STE 1200 FORT LAUDERDALE FL 33301 EMPLOYER NUMBER: KFC USA INC PAYROLL DEPT 5200 COMMERCE CROSSING DR LOUISVILLE KY 40229-2182 YEAR QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 1999 $140.70 EMPLOYER NUMBER: PUBLIX SUPER MARKETS INC PO BOX 32018 LAKELAND FL 33802-2018 YEAR QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 1999 $216.69 EMPLOYER NUMBER: ASCENSION CHILD CARE CENTER ASCENSION PEACE CHILD CARE CENTER 2701 STATE ROAD 7 LAUD LAKES FL 33313-2731 YEAR QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 1999 $216.97 PAGE 1 GIUFFRE009177 I W3 I M11133 Case 18-2868, Document 278, 08/09/2019, 2628230, Page198 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS EMPLOYER NUMBER: AVICULTURAL BREEDING RESEARCH CENTER ERNEST LAKS 14201 125TH AVE WEST PALM BCH FL 33418-7945 YEAR QTR 2ND QTR 3RD QTR 4TH QTR 2000 EMPLOYER NUMBER: SOUTHEAST EMPLOYEE MANAGEMENT COMPANY 2559 PALM DEER DR LOXAHATCHEE FL 33470-2563 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR EMPLOYER NUMBER: MAR-A-LAGO CLUB LLC TRUMP DONALD GEN PTR TRUMP ORGANIZATION 1100 OCEAN BLVD PALM BEACH FL 33480-5004 YEAR QTR 2ND QTR 3RD QTR 4TH QTR 2000 EMPLOYER NUMBER: OASIS OUTSOURCING VI INC 2054 VISTA PKWY STE 300 WEST PALM BCH FL 33411-6742 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR EMPLOYER NUMBER: NEIMAN-MARCUS GROUP LLC NEIMAN MARCUS GROUP LTD SOLE MBR 1201 ELM ST DALLAS TX 75270-2102 YEAR QTR 2ND QTR 3RD QTR 4TH QTR 2000 PAGE 2 TOTAL $99.48 TOTAL $3,212.44 TOTAL $1,866.50 TOTAL $2,037.60 TOTAL $1,440.79 GIUFFRE009178 Case 18-2868, Document 278, 08/09/2019, 2628230, Page199 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS FOR SSN EMPLOYER NUMBER: - MANNINOS INC MANNINOS RESTAURANT 12793 FOREST HILL BLVD WEST PALM BEACH FL 33414-4749 YEAR IST QTR 2ND QTR 3RD QTR 2001 EMPLOYER NUMBER. CCI OF ROYAL PALM INC ROBERT PURR TTEE 2255 GLADES RD STE 337-w BOCA RATON FL 33431-7379 YEAR IST QTR 2ND QTR 3RD QTR 2002 EMPLOYER NUMBER: ROADHOUSE GRILL INC ROBERT FURR TTEE IN BANKRUPTCY 2255 GLADES RD STE 337W BOCA RATON FL 33431-7379 YEAR IST QTR 2ND QTR 3RD QTR 2002 EMPLOYER NUMBER: MARC PINKWASSER DVM PA 13860 WELLINGTON TRCE STE 31 WELLINGTON FL 33414-8541 YEAR 1ST QTR 2ND QTR 3RD QTR 2002 EMPLOYER NUMBER: GREAT OUTDOORS PREMIER RV-GOLF RESORT COMMUNITY ASSOC INC 145 PLANTATION DR TITUSVILLE FL 32780-2528 YEAR IST QTR 2ND QTR 3RD QTR 2014 PAGE 3 QTR 4TH 4TH 4TH 4TH QTR QTR QTR QTR TOTAL $212.00 TOTAL $403.64 TOTAL $1,247.90 TOTAL $1,561.75 TOTAL $171.83 GIUFFRE009179 Al! Manon . . vnvn?ov- - MU I human CW Case 18-2868, Document 278, 08/09/2019, 2628230, Page200 Of 648 SSA-1826 ITEMIZED STATEME OF EARNINGS THERE ARE NO OTHER EARNINGS RECORDED UNDER THIS SOCIAL SECURITY NUMBER FOR REQUESTED PAGE 4 GIUFFRE009180 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page201 of 648 EXHIBIT January 30, 2003 To Whom It May Concern, Skye Roberts has been a most valuable employee at The Mar-a-Lago Club since April of 2000. While employed as a maintenance crew team member, he has been responsible for maintaining the ?ve championship red-clay tennis courts as well as keeping all of the individual air conditioning units working and in tip-top shape. It is my understanding that Skye is relocating to Colorado. Should he ever return to Florida, he would be eligible for re-hire. onald J. Trump {14,54,554 m. PA LM BEACH. VLDRIDA 1100 South Ocean Bouiexmrl, Palm Beach ?orid; 33%30 46373 5332608 Fax (407) 833265.469 Case 18-2868, Document 278, 08/09/2019, 2628230, Page203 of 648 TERMINATIONS LAST NAME Abbott Acevedo Adams Adams Adams Addison Adelfio Adler Aldahondo Alexis Allen Almeida Almgren Alves Anaya Anderson Andres-Felix Annunziata Anton Aquino Argueta Armstrong Ash Ashenbrenner Auguste Bacon Bader Bader Baghouli Bahena Baker Balkunas Banks Baranek Baron Barr Barr Barrett Barrill Beam Beaudoin Beckett Benarroch Bend Benitez Bennett Benney Benoit Bernal FIRST NAME Philip Michael Zane Cynthia Patrick Andrea Peter Jessica Francisco Genicia Suzanne Tiberio Shane Victor Orlando Sandra Francisco Susan Frank Jorge Irma April Carol William Firenze John Susan Erwin Adel Lucio Teresa Vicki Michael Katherine Todd James Gail Loraine London Stephen Louis Sam Alice John Sixta Thomas Tabitha Mark Ana Box #1 Box #4 Box #3 Box #1 Box #1 Box #4 Box #4 Box #1 Box #6 Box #3 Box #1 Box #4 Box #3 Box #4 Box #4 Box #6 Box #4 Box #3 Box #1 Box #4 Box #3 Box #4 Box #6 Box #3 Box #6 Box #4 Box #1 Box #1 Box #6 Box #6 Box #3 Box #6 Box #4 Box #3 Box #6 Box #4 Box #1 Box #3 Box #3 Box #6 Box #1 Box #3 Box #1 Box #1 Box #3 Box #3 Box #3 Box #1 Box #6 Page 1 of 17 MAR-A-LAGO 0161 Case 18-2868, Document 278, 08/09/2019, 2628230, Page204 of 648 TERMINATIONS LAST NAME Bernhardt Berube Beswick Beverly Bezwiechin Blake Bloch Blyth Bobrowski Bocksch Boehm Boettcher Bogert Boisvert Bonilla Bork Borrego Borrell Borrelli Boudreau Boukhalfa Bouschet Brass Brassler Brendel Brennan Briante Bridger Briggs Brown Brown Brummel Bryan Bryant Buckingham Buckley Budziak Burdett Burgess Burgon Burke Burke Burlew Burton Butler Calder Caldwell Camacho Camilleri FIRST NAME Gretchen Michael Allan Tim Cham Howard Michael Alison Michele Kristy Erica Joe Debra Cory Jose Allen Sandra Salvator Lisa Matthew Said Courtney Baysson Chris Kendra Mary Gerard Jody Jacqueline Eleanor William Denis Amy William Annette Cynthia Diane Jill Lawrence Helya Maureen Christopher Gary Myles Michael Malgorzata Karen Darren Mark Box #1 Box #4 Box #6 Box #4 Box #3 Box #3 Box #3 Box #6 Box #3 Box #4 Box #3 Box #6 Box #3 Box #1 Box #4 Box #4 Box #4 Box #1 Box #6 Box #4 Box #6 Box #4 Box #1 Box #1 Box #6 Box #1 Box #1 Box #3 Box #1 Box #6 Box #6 Box #3 Box #1 Box #4 Box #1 Box #4 Box #1 Box #6 Box #3 Box #6 Box #4 Box #4 Box #1 Box #3 Box #4 Box #3 Box #1 Box #4 Box #4 Page 2 of 17 MAR-A-LAGO 0162 Case 18-2868, Document 278, 08/09/2019, 2628230, Page205 of 648 TERMINATIONS LAST NAME Campbell Candella Cantrell Capozzi Carlisle Carr Carroll Carvalho Casher Castano Castillo Castro Catranbone Cavinee Celestin Chambers Chapuis Charles Charles Chillingsworth Chioffe Christie Ciaffone Ciccia Clark Cleveland Cloninger Coffman Cohen Cole Collins Collins Conroy Cordero Cordero Cortes Corti Coutts Cox Cronin Cross Crostic Crowley Cruz Cruz Crystle Cuervo Cummings Curran FIRST NAME Benjamin Charles Dantelle Christina Kevin Janet VALerie Deo Jeremy Ku Sandra Juan Angela Krystal Jean Craig Rene Fresnel Sylfida Vanette James Michael Cora John Kimberly Trisha Tana Connie Julius Joanne Yvette Barbara James Vera Vero Roberto Debra Rachael Emory Sonia Deborah Barbara Tricia Lonjino Israel Joshua Anamaria Meghan Maureen Box #3 Box #4 Box #4 Box #4 Box #1 Box #3 Box #4 Box #3 Box #1 Box #4 Box #6 Box #4 Box #1 Box #4 Box #3 Box #1 Box #1 Box #6 Box #6 Box #6 Box #1 Box #4 Box #6 Box #3 Box #1 Box #6 Box #3 Box #4 Box #6 Box #1 Box #1 Box #1 Box #4 Box #1 Box #1 Box #3 Box #3 Box #1 Box #1 Box #6 Box #6 Box #4 Box #6 Box #6 Box #6 Box #4 Box #4 Box #6 Box #1 Page 3 of 17 MAR-A-LAGO 0163 Case 18-2868, Document 278, 08/09/2019, 2628230, Page206 of 648 TERMINATIONS LAST NAME Czerniak Daley Damiano Davis Davis Deak Dean Deleon Delia Dellay DeLorenzo DeNarvaez DePaula DeRiso DeSernia Devine DeVito DiBenedetto Dickens Dieu Donne Dimitrova Dodge Dombayci Domnick Donnelly Dorsa Drake Drogowski Dubois Dubois Dumstra Eaton Edge Edwards Egger Elkhoury Ellingworth Ellis Elwell Enger English Espinoza Espinoza Espinoza Estime Ettehad Faaland Faba Fagen FIRST NAME Anthony Chad Anthony Jeremy Eric Stephen Laurie Elais Frank Scott Mark Claudia Danielle Gina Sulamita Keith Dawn Melissa George Jean Charles Violeta Virginia Yimaz Mark Jennie Antonio Charlie David Lydia Crystal Adam Adam Jerod Don Paul Toni David Christine Douglas Mark Mistie Francisca Henner Carlos Karl Shahla Roy Juan Lanell Box #4 Box #6 Box #4 Box #4 Box #1 Box #6 Box #6 Box #4 Box #4 Box #1 Box #6 Box #3 Box #4 Box #1 Box #3 Box #1 Box #1 Box #3 Box #6 Box #4 Box #3 Box #1 Box #6 Box #1 Box #3 Box #1 Box #6 Box #6 Box #4 Box #6 Box #6 Box #4 Box #4 Box #4 Box #6 Box #6 Box #6 Box #1 Box #1 Box #3 Box #3 Box #4 Box #3 Box #6 Box #1 Box #4 Box #1 Box #1 Box #1 Page 4 of 17 MAR-A-LAGO 0164 Case 18-2868, Document 278, 08/09/2019, 2628230, Page207 of 648 TERMINATIONS LAST NAME Faraci Fasel Faulk Feal Feick Fein Fernandez Ferree Fesser Fidanovic Figueroa Filippone Finch Finckenor Fink Fiorentino Firat Fischbach Fischer Fiumara Flores Folmer Foss Fox Francoeur Fratus Frelich Frey Friday Frith Fritz Frost Gacon Galla Galloway Galloza Garcia Garcia-Douglas Garrido Gedeum Gell Gervais Getgood Gibeault Gillie Gividen Glass Goicochea Goldrich FIRST NAME Franklin Jeremy Joel Jose Gretchen Lawrence Jose Tonya Michael Novak Irina Vittorio Michael George Roger Maria Turabi Nora Rosemary Michele Pedro Ronald John Lisa Mary Lou Donna Jason Kenneth Jennifer Cynthia John Mark Allan Galla Kurt Sergio Souad Marcia Dante Rosalie William Marie Russell Larry Barbara Nathan Kevin Darcy Amanda Box #1 Box #4 Box #1 Box #4 Box #4 Box #1 Box #6 Box #3 Box #1 Box #6 Box #3 Box #4 Box #1 Box #4 Box #4 Box #4 Box #1 Box #3 Box #4 Box #3 Box #3 Box #1 Box #1 Box #6 Box #6 Box #3 Box #6 Box #4 Box #6 Box #1 Box #1 Box #1 Box #1 Box #1 Box #6 Box #3 Box #6 Box #6 Box #4 Box #3 Box #3 Box #6 Box #1 Box #1 Box #1 Box #1 Box #1 Box #6 Box #3 Page 5 of 17 MAR-A-LAGO 0165 Case 18-2868, Document 278, 08/09/2019, 2628230, Page208 of 648 TERMINATIONS LAST NAME Golemis Gomaa Gonzales Gonzales Gonzalez Gonzalez Gonzalez Gonzalez Goodman Goupy Gowdy Granjales Grant Grasso Graves Green Greene Greenwood Gregson Grieve Griffin Griffin Griffiths Griggs Grosso Guerin Gutierez Gutierez Gutierrez Guyierrez Hader Hagen Haggar Hamby Harris Hartsough Hatch Hatfield Havican Heanssler Hefel Hemings Hennessee Hernandez Hernandez Hernandez Herrara Herth Higgins FIRST NAME Sam Ashraff Augustine Dora Raul David Elsa Alex William Bernad Charles Myriam Everton William Erika Michelle James Elizabeth Scott Daniel Mark Michael Sandra Dora Peter Jean Mauricio Porfidio Antonio Warren Karen Kyla Karen Michael Dan Cheryl Wendy Michael Robert Pete Eric Romy Jason Gladys Alexander Luis Julio Francesca Jennifer Box #3 Box #6 Box #4 Box #4 Box #3 Box #1 Box #1 Box #6 Box #4 Box #6 Box #1 Box #6 Box #4 Box #3 Box #4 Box #1 Box #1 Box #1 Box #3 Box #3 Box #1 Box #1 Box #1 Box #3 Box #1 Box #1 Box #1 Box #1 Box #3 Box #6 Box #3 Box #1 Box #3 Box #1 Box #6 Box #1 Box #1 Box #1 Box #6 Box #3 Box #6 Box #6 Box #3 Box #3 Box #3 Box #3 Box #4 Box #3 Box #4 Page 6 of 17 MAR-A-LAGO 0166 Case 18-2868, Document 278, 08/09/2019, 2628230, Page209 of 648 TERMINATIONS LAST NAME Higgs Hill Hill Hinkin Ho Hochong Hodes Holcomb Holryid Homenuik Hong Hopkins Horsky Hossain Hoyle Huber Huguet Hulsey Hutchins Hyde Hylton Ibrahim Infante Insani Ioli Irvine Jacob Jacobs Jacques Jacques Jaferali James Jankowski Jaramillo Jean Jenkins Jesperson Johnansen Johnson Johnson Johnson Johnson Johnson Johnson Johnson Johnson Jones Jones Joseph FIRST NAME Kathleen Donna Samuel Cynthia Stella Anthony Robin Mary Mary Wilfred David Victoria George Mohammed Patricia Frank Roberto Thomas Marguerite Rose Longsworth Ashraf Carlos Mark Gina Marche Maureen Rick Dudley Nixon Errol Buddy Keith Olmes Jacques Todd Henrik Elise Eric Josh Chad Debbie Laura Jade Walter Cathiejo Steve Regina Elisca Box #1 Box #4 Box #1 Box #3 Box #1 Box #6 Box #4 Box #3 Box #1 Box #6 Box #6 Box #6 Box #3 Box #1 Box #4 Box #4 Box #3 Box #4 Box #4 Box #6 Box #6 Box #4 Box #4 Box #3 Box #4 Box #3 Box #1 Box #1 Box #1 Box #6 Box #4 Box #6 Box #1 Box #1 Box #6 Box #4 Box #3 Box #6 Box #4 Box #4 Box #1 Box #1 Box #1 Box #1 Box #1 Box #6 Box #4 Box #3 Box #6 Page 7 of 17 MAR-A-LAGO 0167 Case 18-2868, Document 278, 08/09/2019, 2628230, Page210 of 648 TERMINATIONS LAST NAME Juan Juan Kaiser Kalson Kapreilian Karius Kaufman Keady Keiser Keller Kelley Kelly Kelly Kennedy Kenney Kenny Kent Kincl King King King Kirby Kleinfeld Kline Kole Kowalski Kresic Krogman Krpina-Zito Kruppenbacher Kuiper Kuntz LaCerte Laidlaw Laine Laing Lang Langford Langweiler Lanunziata Laskaris Laufenberg Lawlor Lefrancois Leite Leitzell Leone Leonova LeRoux FIRST NAME Miguel Tomas Angelina Stephen Vince Peter Michael Robert Mike Lisa Mikchael Nancy Lois John Sean Marlou Brian Scott Joseph Helen Jeffrey Michael Brian Robert Eileen Karen Susan Blago Terry Marija Michael Gary Carlson Troy Kenneth Brent Melissa Eric Chad Albert Stacia Alexandra Lynette Thomas Aaron Paulo jTara Nick Victoria Marthinus Box #4 Box #6 Box #4 Box #1 Box #4 Box #4 Box #1 Box #1 Box #4 Box #4 Box #1 Box #4 Box #1 Box #3 Box #3 Box #4 Box #4 Box #4 Box #4 Box #3 Box #6 Box #1 Box #1 Box #6 Box #4 Box #1 Box #1 Box #1 Box #4 Box #6 Box #3 Box #4 Box #1 Box #3 Box #6 Box #6 Box #4 Box #6 Box #1 Box #6 Box #1 Box #1 Box #3 Box #3 Box #1 Box #4 Box #1 Box #6 Box #6 Page 8 of 17 MAR-A-LAGO 0168 Case 18-2868, Document 278, 08/09/2019, 2628230, Page211 of 648 TERMINATIONS LAST NAME Lester Lewis Leyden Liberte Lightbourne Lisec Locke Logalbo Lopez Lopez Lopez Lopez Lopez Love Lowe Lugo Lusse Luxton Lyle Lynam Lynch MacDonnell Machado Magerus Malay Maldonado Maldonaldo Mann Mannion Marcenaro Marchman Marino Marrone Marshall Martinez Martinez Martinez Massias Mateo Maurice Max Maxwell McAlees McBrayer McCabe McCambridge McCann McCarthy McConnell FIRST NAME Carolina Corey Gene Monney Andrianne Lisa Michelle Franklin Claudio Julian Marvin Mario Roger Rena Karl Christianne Robert Stephanie Mary Jane Robert Cheri Thomas Carlos Georges Maya Juvencio James Andrew Deidre Eduardo Henry Mindy Kimberly John Steve Zach Hector Caroline Alfredo Lucas Marie Susan Terence Brook Cassandra Kevin Angela Kevin Shannon James Box #6 Box #1 Box #6 Box #3 Box #1 Box #1 Box #3 Box #6 Box #4 Box #3 Box #3 Box #6 Box #6 Box #3 Box #3 Box #3 Box #1 Box #4 Box #6 Box #6 Box #3 Box #7 Box #4 Box #4 Box #3 Box #1 Box #7 Box #3 Box #4 Box #1 Box #4 Box #1 Box #3 Box #7 Box #1 Box #7 Box #7 Box #4 Box #1 Box #3 Box #1 Box #7 Box #4 Box #1 Box #3 Box #1 Box #3 Box #3 Box #4 Page 9 of 17 MAR-A-LAGO 0169 Case 18-2868, Document 278, 08/09/2019, 2628230, Page212 of 648 TERMINATIONS LAST NAME McCormick McDaniel McDonald McDonald McFarland McGreevy McKee McKeen McKim McLean McMahon McMiled McNaughton McNicholas Mead Meade Mena Merchant Merriman Mesa Messemer Metayer Metayer Michaels Michel Miller Miller Miller Milosevic Miranda Mitchell Mohamed Monaco Monia Monson Montano Montano Montecinos Moore Moran Moree Moreno Morgan Morgan Morris Morris Mosher Moss Mullen FIRST NAME Jennifer Elizabeth Amanda Deborah Robert Barbara Wende Nohora Mark Stephen Leo Patricia Sean Marie Paul Raymond Arturo Kenneth Rita Uenoi Brian Edenes Marie Jesse Bernadette Eric Lisa Ronald Sas Cari Edward Waleid Lettia Gregory Jill Helmuth Henry James Joel Tom Darlene Aura Todd Jennifer Katherine Rebecca Neil William Coury Sony Box #7 Box #4 Box #3 Box #1 Box #4 Box #1 Box #4 Box #3 Box #1 Box #4 Box #7 Box #3 Box #7 Box #3 Box #7 Box #1 Box #1 Box #4 Box #7 Box #3 Box #4 Box #4 Box #1 Box #7 Box #7 Box #3 Box #3 Box #7 Box #1 Box #7 Box #4 Box #4 Box #1 Box #1 Box #7 Box #4 Box #4 Box #4 Box #2 Box #7 Box #4 Box #3 Box #2 Box #7 Box #3 Box #7 Box #2 Box #4 Box #7 Page 10 of 17 MAR-A-LAGO 0170 Case 18-2868, Document 278, 08/09/2019, 2628230, Page213 of 648 TERMINATIONS LAST NAME Mullen Munford Munoz Musallet Musso Myers Myers Nagy Nagy Nakoneczny Narleski Nasie Natal Neira Nelsen Nelson Nemets Nieporte Noe Noel Nolan Northern Noufal O'Boyle Oconnor Oesterling Oldfield Oliver O'Neill O'Neill O'Neill Orozco Pagen Pagliaro Palomba Parker Parker Parkinson Pavelka Pavonni Pedro Peison Pelaez Penate Perez Perkins Perrey Pesasico Petery FIRST NAME Cheryl Cheryl Mariadelrocio Hassan Diane Louisa Linda Matthew Viktoria Dawn Linda Waleed Luis Fernando Holly Lisa Tammie Joseph Thomas Marie Susan Brad Michel Thomas Kevin Emily Janice Meike Kathryn William Joseph Clemente Mitchel Peter Amanda Sandra Everett Nicole Nathan Michelle David Brenda Juan Alexander Marlow Tian Arielle Crispin Pamela Box #7 Box #7 Box #4 Box #2 Box #7 Box #3 Box #7 Box #4 Box #7 Box #4 Box #2 Box #7 Box #3 Box #3 Box #2 Box #3 Box #3 Box #4 Box #7 Box #7 Box #2 Box #7 Box #2 Box #7 Box #2 Box #7 Box #2 Box #4 Box #2 Box #2 Box #7 Box #3 Box #2 Box #4 Box #2 Box #3 Box #2 Box #4 Box #2 Box #2 Box #4 Box #7 Box #2 Box #4 Box #4 Box #4 Box #2 Box #4 Box #7 Page 11 of 17 MAR-A-LAGO 0171 Case 18-2868, Document 278, 08/09/2019, 2628230, Page214 of 648 TERMINATIONS LAST NAME Petrillo Pharr Philips Pickens Pientka Pierre-Noel Pinder Pine Pino Pinto Piques Pisani Pisani Pitot Pittinger Pitts Plaine Ponder Poston Powell Powell Presto Price Prouty Prucien Quigley Quirao Rafrano Ragland Ramirez Ramos Raphael-Dallas Reardon Reasinger Redmond Reed Reich Reil Reis Reis Reiser Rene Rene Rene Rennie Reyes Reynolds Ribeiro Richardson FIRST NAME Camille Stephanie Ralph Robert John Yvonne Patricia Jon Alex Julie Christian Craig Nicholas Patrick Mark Jeremiah Victoria Janet Roberta Nicole Kelley Nicholas Robin Joy Mona Christy Maria Dawn Leslie Roxana Milka Jamie Lisa Amy Suzanne Diana Gwendalyn Richard Brian Charles Scott Josette Jean Lamercie Kerry Randolfo Janice Gregg Brian Box #3 Box #4 Box #3 Box #2 Box #2 Box #4 Box #7 Box #3 Box #7 Box #2 Box #7 Box #2 Box #2 Box #3 Box #4 Box #2 Box #3 Box #3 Box #4 Box #3 Box #7 Box #4 Box #2 Box #2 Box #3 Box #7 Box #4 Box #2 Box #2 Box #2 Box #3 Box #3 Box #2 Box #2 Box #2 Box #4 Box #2 Box #2 Box #7 Box #7 Box #7 Box #4 Box #7 Box #7 Box #2 Box #4 Box #7 Box #3 Box #7 Page 12 of 17 MAR-A-LAGO 0172 Case 18-2868, Document 278, 08/09/2019, 2628230, Page215 of 648 TERMINATIONS LAST NAME Rinker Rivera Rivera Rivero Robbins Roberts Roberts Roberts Robsham Rodriguez Rodriguez Rodriguez Rodriguez Rogers Romeus Rony Roqueta Rose Rosenberg Rosier Rotchford Rubio Rueda Ruiz Russeau Russell Russotto Ryan Ryan Saint Gerard Saint Surin Salloum Salman Salvador Sanford Santos Sasaki Saunders Savage Savoie Scanlan Schlechter Schmantowsky Schoonover Schroeder Schumacher Schwab Scotland Scott FIRST NAME Ross Pablo Eduardo Alicia Jody Virginia Walter Diane Lydie Francisco Abel Kenia Aristalia Howard Melege Jean Maria Cheryl Bradley Sandra Bernadette Pascual Maria Juan Heidi Kathryn Vincent Megan Michael Manes Jacquest Adib David Marian Kevin Elimos Shoko Sarah Angelia Terry Peter Melissa Craig Richard Glenn Patricia Emily Jaycen Cecelia Box #7 Box #3 Box #2 Box #7 Box #4 Box #4 Box #4 Box #3 Box #7 Box #4 Box #3 Box #3 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #4 Box #2 Box #4 Box #2 Box #4 Box #4 Box #7 Box #2 Box #7 Box #7 Box #2 Box #2 Box #2 Box #2 Box #5 Box #2 Box #7 Box #2 Box #5 Box #2 Box #5 Box #5 Box #2 Box #2 Box #5 Box #2 Box #2 Box #7 Box #2 Page 13 of 17 MAR-A-LAGO 0173 Case 18-2868, Document 278, 08/09/2019, 2628230, Page216 of 648 TERMINATIONS LAST NAME Seebauer Seesholtz Sellas Serpico Sevilla Shaw Shelhamer Shepherd Shields Shumate Shumpis Similien Simms Simpson Sineni Singerline Skinner Sluzenski Smith Smith Smith Smith Smith Smith Snyder Soler Soliman Sosa Southall Souza Spencer Sprague Springer Stanfield Staniszewski Stankunas Stanley Sta-Rosa Steinberg Steinhaus Steliga Stenger Stephans Stewart Strohminger Stuart Stuhr Sturtevant Sucur FIRST NAME Gina Joseph William Joseph Carlos Tammy Sage Michael Catherine Regis David Raymond Amanda Robert Sandra Thomas Troy Jonathan Jeremiah Ivan Meadow Debbie Elizabeth Fred Lisa Luis Alex Anian Ginger Robert Sxott Steven Timothy Todd Casey Jolanta Lisa Jaime Lindo Kathleen Cynthia Stephanie Stuart Dorian Selvin Matthew Susan Kenneth Charles Nicholas Box #7 Box #2 Box #2 Box #2 Box #5 Box #7 Box #7 Box #7 Box #2 Box #5 Box #7 Box #2 Box #7 Box #7 Box #2 Box #2 Box #2 Box #7 Box #5 Box #5 Box #2 Box #2 Box #2 Box #2 Box #7 Box #2 Box #2 Box #7 Box #2 Box #2 Box #2 Box #2 Box #2 Box #5 Box #7 Box #7 Box #2 Box #2 Box #2 Box #2 Box #5 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #5 Box #7 Page 14 of 17 MAR-A-LAGO 0174 Case 18-2868, Document 278, 08/09/2019, 2628230, Page217 of 648 TERMINATIONS LAST NAME Sullivan Sumpter Swan Sweeney Swiderski Swiderski Sylne Tan Tarantino Tatum Taylor Tempfli Thelemaque Thibeault Thiel Thiel Thomas Thompson Thompson Tomer Tonge Torres Torres Toussant Trevino Tsitsirides Tucker Uljic Umpierre Valdez Valdez Valenti Vandersloot VanVliet FIRST NAME Judith Drew Pyson Bridget Richard Mark Romel Priscilia Vincenzo Christopher Kevin Glenn {ierre William Kurt Ryan Edward Derek Christine Mary Al Frank Iris Elby Danielle Alex Marie Gjon Frances Bridges Julie Paul Mildred Jane Box #2 Box #2 Box #5 Box #5 Box #2 Box #2 Box #2 Box #2 Box #2 Box #7 Box #5 Box #2 Box #5 Box #7 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #5 Box #5 Box #7 Box #7 Box #2 Box #5 Box #7 Box #2 Box #7 Box #2 Box #2 Box #2 Box #5 Box #2 Page 15 of 17 MAR-A-LAGO 0175 Case 18-2868, Document 278, 08/09/2019, 2628230, Page218 of 648 TERMINATIONS LAST NAME Vasquez Vasquez Vaughn Velasquez Vidalis Voluck Vyskrebentsev Wahl Walker Walkowiak Wallace Ward Webb Weber Weidner Weisman Wentworth Weslowski White Whitley Whitney Whittle Wilburn Williams Williams Williams Williams Williams Willoughby Willson Willson Woolf Wynn Yancey Yancey Yeskey Young Zervoulis Zivkovic Zorn Zwick FIRST NAME Sosmar Christian Matthew Rodollfo Chantal Justin Aleksey Steven Sylvia Toni Philip Terry Jacob Ronald James Brian Gayle Elaine Scott Deborah Moriah Tamara Jennifer Arhon Gretchen Jacqueline Ellen Kristin William Howard Joseph Elena Beverly Kathryn Scott Dean Martin Todd Matthew Milo Christopher Danielle Box #1 Box #2 Box #3 Box #4 Box #5 Box #6 1998 terms 1998 & 1999 terms 1999 terms 2000 terms 2000 terms 2001 terms Box #5 Box #2 Box #2 Box #2 Box #2 Box #2 Box #5 Box #5 Box #7 Box #7 Box #2 Box #5 Box #7 Box #2 Box #7 Box #2 Box #2 Box #2 Box #5 Box #7 Box #7 Box #2 Box #2 Box #2 Box #2 Box #2 Box #7 Box #7 Box #2 Box #5 Box #2 Box #2 Box #2 Box #2 Box #7 Box #5 Box #2 Box #2 Box #2 Box #7 Box #2 Page 16 of 17 MAR-A-LAGO 0176 Case 18-2868, Document 278, 08/09/2019, 2628230, Page219 of 648 TERMINATIONS LAST NAME Box #7 FIRST NAME 2001 terms Page 17 of 17 MAR-A-LAGO 0177 Case 18-2868, Document 278, 08/09/2019, 2628230, Page220 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page221 of 648 1 UNITED STATES DISTRICT COURT 2 Southern District of New York for the 3 4 5 6 7 8 9 10 Civil Action No. 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, vs. GHISLAINE MAXWELL, Defendant. ----------------------------------------------------VIDEO-DEPOSITION Sky Roberts TAKEN BY: Defendant REPORTED BY: Karla Layfield, RMR Stenographic Court Reporter Notary Public State of Florida at Large 15 DATE AND TIME: May 20, 2016; 8:33 a.m. 16 PLACE: Millhorn Law Firm 11294 North US Highway 301 Oxford, Florida APPEARANCES: Laura A. Menninger, Esquire HADDON, MORGAN & FOREMAN, PC 150 East 10th Avenue Denver, Colorado 80203 11 12 13 OF: 14 17 18 19 Attorney for Defendant 20 Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, 21 22 FISTOS & LEHRMAN, PL 425 Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Attorney for Plaintiff 23 24 25 ALSO PRESENT: Kenneth Sarcony, Videographer Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 1 2 Case 18-2868, Document 278, 08/09/2019, 2628230, Page222 of 648 1 2 3 4 5 6 7 8 I N D E X PAGE WITNESS: Sky Roberts Direct Examination by Ms. Menninger Cross-Examination by Mr. Edwards Redirect Examination by Ms. Menninger Recross-Examination by Mr. Edwards Reporter's Certificate Certificate of Oath 4 133 135 141 143 144 9 10 - - - 11 12 13 14 15 16 17 18 19 E X H I B I T S Defendant's Defendant's Defendant's Defendant's Defendant's Defendant's Defendant's Defendant's Defendant's Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit 1 2 3 4 5 6 7 8 9 (Exhibits attached.) 20 21 22 23 24 25 Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 6 28 48 52 58 116 122 125 137 Case 18-2868, Document 278, 08/09/2019, 2628230, Page223 of 648 Q 1 Do you remember there being a job posting that 2 you felt like was appropriate for Virginia or did you just 3 go out and talk to the woman who ran the spa area on your 4 own? 5 A I just talked to Angela. 6 Q Okay. 7 8 9 10 Do you recall whether this was intended to be a full-time job? A I don't remember if it was full time or just summer jobs or, you know, during season. It was probably for a season because Mar-a-Lago is seasonal. I mean, I was there year round but a lot of 11 12 people are seasonal, you know, because it's like 13 snowbirds, you know, summertime comes and nobody wants to 14 be down in south Florida. 15 16 17 18 Q What would you call the season, the seasonal aspect of Mar-a-Lago? A What's the season? Probably from September or October to, you know, maybe May, I guess. 19 Q Is that the coolest time? 20 A Times of the year, yes. 21 Q And it's more guests that come during that 22 period of time? 23 A Yes. 24 Q And is there more staff brought on during that 25 period of time? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 72 Case 18-2868, Document 278, 08/09/2019, 2628230, Page224 of 648 1 A Yes. 2 Q You saw that happen every year that you were 3 there? 4 A Every year. 5 Q And in the summer, it's relatively dead because 6 it's so hot? 7 A Basically, it closed during the summer. That's 8 when we would kind of work on everything and then make 9 sure everything is up to snuff for the next year, you 10 11 12 13 know. Q Do you remember what capacity Virginia was hired to work in, what her job title was, for example? A I don't know. I would have lunch with Virginia. 14 That's about as much as I know about what she did. 15 busy all the time. I was 16 Q I understand. 17 A I didn't have time to go see what she was doing. 18 I didn't really talk to Angela about what she had to do. 19 I think that was her name, Angela. 20 name that sticks out. But it's kind of the 21 Q We'll just use Angela. 22 A We'll use that as the name. 23 Q But we know it may not be Angela. 24 A It may not be. 25 Q Just because we have to call her something, Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 73 Case 18-2868, Document 278, 08/09/2019, 2628230, Page225 of 648 1 A Where did I learn that? 2 Q Uh-huh. 3 A I think Virginia had told me that there was a 4 lady in the spa area named Ms. Maxwell. I don't know her. 5 I couldn't tell you what she looked like. But just she said Ms. Maxwell said she can get 6 7 me a job with Jeffrey Epstein who is a friend of Donald 8 Trump, so I figured, well, he was a good guy or whatever, 9 you know, and that she was going to learn massage therapy. 10 Q When did Virginia tell you this? 11 A Oh, I can't tell you what date and time but I 12 13 don't remember. Q I understand. Did she tell you this while she was working at 14 15 Mar-a-Lago? 16 A Yes. I mean, after she had been there for a 17 little bit, you know, and then she told me, yes, that she 18 could possibly get this other job. 19 Q Okay. 20 A You know. 21 Q So she worked at Mar-a-Lago for a few months? 22 MR. EDWARDS: Form. 23 THE WITNESS: I have no idea. 24 25 how long she worked there. I don't know I don't remember. BY MS. MENNINGER: Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 79 Case 18-2868, Document 278, 08/09/2019, 2628230, Page226 of 648 1 2 A Uh-huh. Yes. It's not to me. It's up to her. I think that's the way I told her, you know. 3 Q Did you ever meet Jeffrey Epstein? 4 A Once. 5 Q When was that? 6 A I dropped Virginia off at the house once and he 7 came out and I met him and seemed just fine to me. 8 mean, you can't tell people by looking at them. I I mean, I know now from, you know, what I've 9 10 read that he's not a good guy. 11 know, you don't even know your neighbors sometimes, you 12 know. 13 14 Q But you can't tell. Do you remember about when you dropped Virginia off at his house that you met him? 15 A What do you mean? 16 Q Was it about the same time Virginia started 17 You working with him? 18 A Yeah. 19 Q Was it later? 20 A I think it was about the time she started. 21 Because I wanted to see where she was at, you know. 22 it was just a mansion down the street from, you know, 23 Mar-a-Lago. 24 think nothing of it. 25 very nice. So I didn't think twice about it. He came out. And I didn't He was very cordial, Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 82 Case 18-2868, Document 278, 08/09/2019, 2628230, Page227 of 648 1 2 3 Q Do you remember any part of your conversation with him? A No. It was just that, you know how a parent has 4 to meet -- you know, if my daughter is going to work 5 somewhere, I just want to meet the guy and see what was 6 going on, you know. 7 conversation, you know. I just remember meeting him and that was it and 8 9 10 11 But I don't remember any she walked into the house and -Q All right. So you recall Mr. Epstein coming outside of his home and greeting you? 12 A Yes. 13 Q Were you invited into his home? 14 A No. 15 Q Did you ever go inside of his home? 16 A No. 17 Q Other than that one time you dropped her off 18 there, do you ever remember going to that home? 19 A No. 20 Q Okay. 21 I couldn't tell you where it was at. Did you meet anyone else while you were there at the home? 22 A No. 23 Q Did you have a conversation with anyone else? 24 A No. 25 Q Did you every call Virginia at that home? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 83 Case 18-2868, Document 278, 08/09/2019, 2628230, Page228 of 648 1 2 massage therapy. Q All right. When she came home at night from 3 working with Mr. Epstein, did she look distressed to you 4 in any way? 5 A Not that I remember. 6 Q Okay. 7 Did she report any complaints about her job with Mr. Epstein? 8 A Not to me. 9 Q Okay. 10 Did she report them to anyone else who then reported them to you? 11 A No. 12 Q Your wife, for example? 13 A I have no idea. 14 Like I said, if she did tell my wife, I never heard about it. 15 Q Okay. 16 A Not that I remember ever meeting her. 17 Q Do you know what she looks like? 18 A No. 19 Q Did you ever meet anyone else who worked with 20 Mr. Epstein? 21 A No. 22 Q Do you remember anyone else who worked for 23 Have you ever met Ms. Maxwell? Mr. Epstein bringing your daughter home, for example? 24 A No. 25 Q Did your daughter ever move into the home where Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 85 Case 18-2868, Document 278, 08/09/2019, 2628230, Page229 of 648 C E R T I F I C A T E 1 2 STATE OF FLORIDA 3 COUNTY OF MARION 4 I, Karla Layfield, RMR, Stenographic Court 5 Reporter, do hereby certify that I was authorized to and 6 did stenographically report the foregoing deposition of 7 Sky Roberts; that said witness was duly sworn to testify 8 truthfully; and that the foregoing pages, numbered 1 9 through 142, inclusive, constitute a true and correct 10 record of the testimony given by said witness to the best 11 of my ability. 12 I FURTHER CERTIFY that I am not a relative or 13 employee or attorney or counsel of any of the parties 14 hereto, nor a relative or employee of such attorney or 15 counsel, nor am I financially interested in the action. 16 WITNESS MY HAND this 17 Ocala, Marion County, Florida. day of May, 2016, at 18 19 20 Karla Layfield, RMR Stenographic Court Reporter 21 22 23 24 25 Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com 143 144 Case 18-2868, Document 278, 08/09/2019, 2628230, Page230 of 648 1 CERTIFICATE OF OATH 2 STATE OF FLORIDA 3 COUNTY OF MARION 4 I, the undersigned authority, certify that Sky 5 Roberts personally appeared before me and was duly sworn 6 on the 20th day of May 2016. 7 8 WITNESS MY HAND AND OFFICIAL SEAL this day of May 2016. 9 10 11 12 13 Karla Layfield, RMR Notary Public State of Florida at Large My Commission No. FF942806 My Commission Expires 12/10/2019 14 15 16 Personally Known Professionally Known Produced Identification of FDL 17 18 19 20 21 22 23 24 25 Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com Case 18-2868, Document 278, 08/09/2019, 2628230, Page231 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page232 of 648 THE MAR-A-LAGO CLUB. L.C. POLICIES OCTOBER 28. 1995 $0 Mm?pr?? AGREN MAR-A-LAGO 017s Case 18-2868, Document 278, 08/09/2019, 2628230, Page233 Of 648 TABLE OF CONTENTS Page INTRODUCTION 1 EQUAL EMPLOYMENT OPPORTUNITY 2 ORIENTATION POLICY 3 SEXUAL HARASSMENT 4 CARE OF FACILITIES 6 ENTRY AND EXIT OF CLUB 7 PROOF OF AUTHORIZATION TO WORK 3 SECURITY 9 A. INFORMATION 9 B. CONFIDENTIALITY 9 C. FACILITIES 9 D. GUEST PRIVACY 10 E. UNAUTHORIZED AREAS 11 F. REPORTING CRIME 11 G. MEDIA 11 GUEST NAMES 12 SAFETY AND HEALTH 13 COMPENSATION 15 EMERGENCY PROCEDURES 16 USE OF COMPUTER SYSTEM AND SOFTWARE PROGRAMS 17 A. GENERAL 17 B. ELECTRONIC MAIL 17 C. VOICE MAIL 13 D. RIGHT TO INSPECT 13 DISCLOSURE OF EMPLOYEE INFORMATION 19 NO DISTRIBUTION 2o INSPECTIONS 21 INTERNAL INVESTIGATIONS 21 OUTSIDE EMPLOYMENT . 22 PROPERTY OF EMPLOYER 23 MAR-A-LAGO 0179 Case 18-2868, Document 278, 08/09/2019, 2628230, Page234 of 648 EMPLOYEE APPRAISAL 24 TELEPHONE COURTESY PROCEDURES 25 EMPLOYEE ATTENDANCE AND TARDINESS 27 LINEN ABUSE . 28 TIME REPORTING - SIGNING IN AND OUT 29 CHANGE OF ADDRESS OR STATUS 29 INITIAL EMPLOYMENT PERIOD 3o WORK HOURS, SALARY AND OVERTIME PREMIUMS 31 A WORK HOURS 31 SALARY 31 OVERTIME PREMIUMS 31 EMPLOYEE BENEFITS AND PROGRAMS 33 VACATION LEAVE 34 SICK TIME POLICY 36 HOLIDAYS AND HOLIDAY PAY . 37 BEREAVEMENT LEAVE 3a JURY DUTY 3a MILITARY LEAVE 39 MATERNITY LEAVE OF ABSENCE 39 FAMILY MEDICAL AND PERSONAL LEAVE OF ABSENCE 4o GRIEVANCE PROCEDURE 47 DISCIPLINARY ACTION 49 UNIFORMS AND PERSONAL APPEARANCE 54 AIDS POLICY 57 USE AND TESTING .., 59 POLICY ON SMOKING 61 MISCELLANEOUS 62 A. STAFF CAFETERIA 62 MAR-A-LAGO 0180 Case 18-2868, Document 278, 08/09/2019, 2628230, Page235 of 648 LOCKERS 62 PHONES 62 D. LOST AND FOUND 62 E. GIFTS 62 RIGHT TO KNOW STATION 63 EMPLOYEE ENTRANCE AND EXIT 63 IF YOU LEAVE EMPLOYMENT 64 A. RESIGNATION POLICY 64 B. DISMISSALS 64 C. WRITTEN WARNINGS 66 D. VACATION PAY 67 E. RETIREMENT PLAN 67 F. CLEARANCE PROCESS 68 EMPLOYMENT HANDBOOK RECEIPT 69 MAR-A-LAGO 0181 Case 18-2868, Document 278, 08/09/2019, 2628230, Page236 of 648 MAR-A-LAGO 0182 Case 18-2868, Document 278, 08/09/2019, 2628230, Page237 of 648 INTRODUCTION MAR-A-LAGO 0183 Case 18-2868, Document 278, 08/09/2019, 2628230, Page238 of 648 The Mar?A-Lago Club, L.C. ("the Club") seeks to provide the quality of work which will develop the potential of each employee as well as the Club as a whole. In this regard, this policy and procedures manual is designed to acquaint each employee with the administrative and personnel practices of the Club. These guidelines provide a framework for the fair and equitable treatment of all employees regardless of location, department, manager or supervisor. Each employee should be familiar with the responsibilities and opportunities available to ?make work as rewarding as possible. These policies and procedures should be read carefully and clearly understood. Each department head, manager or supervisor will be able to answer, or obtain an answer, to any questions involving interpretation or clarification of these policies and procedures. Each employee is expected to apply these general policy and procedure guidelines conscientiously iJ1.a constructive and supportive manner. The policies in this manual are only guidelines and the Club reserves the right to add to, subtract from, or change these provisions in any way, at any time, without being bound to the previously replaced or revised provisions. This handbook is not to be construed as an employment agreement or employment contract and the Club is under no obligation to provide the benefits set forth in.this manual if it determines, at a subsequent time, that these benefits are to terminate. NLARHAJQAGKJ0184 Case 18-2868, Document 278, 08/09/2019, 2628230, Page239 of 648 DAL EMPLOYMENT OPPORTUNITY The Club is an equal opportunity employer which is committed to prohibiting discrimination on the basis of race, color, sex, age, religion, national origin, sexual orientation, marital status, or' disability' throughout the employment. process, from selection through termination. The Club intends to provide a pleasant work environment that is healthful and comfortable and will not tolerate any form of employee harassment, either verbal, written, physical, or visual, based on race, color, religion, sex, national origin, age, disability or marital status. Harassment can take many forms. It may be, but is not limited to: words, signs, jokes, pranks, intimidation, physical contact, violence toward any employee by a fellow employee, a supervisor, or a person doing business with the Club. Harassment is not necessarily sexual in nature. All necessary steps will be taken to comply with existing federal, state and local fair employment laws and guidelines. MAR-A-LAGO 0185 Case 18-2868, Document 278, 08/09/2019, 2628230, Page240 of 648 ORIENTATION POLICY The first ninety days of employment are considered to be an orientation or probationary period during which you and the Club have an opportunity to know each other. Your performance will be evaluated during this time to access your potential for continued employment. Evaluations will continue as long as you are employed, but during the orientation period your supervisor may observe and evaluate your performance more closely and more frequently to ensure that you are learning your job. During this orientation period, employees may earn but may not use vacation or personal days, except with permission of the Club Manager's office. If the employment relationship is terminated during this ninety day period, you shall not be entitled to receive any payment for benefits, personal days, vacation days, or unemployment compensation . MAR-A-LAGO 0186 Case 18-2868, Document 278, 08/09/2019, 2628230, Page24l of 648 The Club strictly prohibits any form of harassment in the workplace, including sexual harassment. Definition of Sexual Harassment: 1. Unwelcome sexual advances, requests for sexual favors, and other such verbal or physical conduct constitute sexual harassment under the following conditions: Submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment. B. Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual. C. Such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile or offensive work environment. 2. Conduct which falls into the definition of sexual harassment may include, but is not limited to: A. Unwelcome physical contact of a sexual nature such as patting, pinching or unnecessary touching. B. Overt or implied threats against an individual to induce him or her to perform sexual favors or to engage in an unwelcome sexual relationship. C. Verbal harassment or abuse of a sexual nature, including intimating by way of suggestion a desire for sexual relations or making jokes or remarks of a sexual nature to or in front of a person who finds them offensive. D. Use of sexually suggestive terms or gestures to describe a person's body, clothing, or sexual activities. E. Displaying or posting offensive sexually suggestive pictures or materials in the workplace. Recourse: MAR-A-LAGO 0187 Case 18-2868, Document 278, 08/09/2019, 2628230, Page242 of 648 If an employee feels that an incident of any form of harassment has occurred, the employee is encouraged to report the matter to the Club Manager's office. All such issues will be handled in strict confidence to the extent possible with minimum embarrassment to the involved parties. As in any grievance procedure, the facts of the situation will be reviewed objectively so that appropriate disciplinary action, including discharge, can be taken if misconduct has occurred. A timely resolution of each complaint is to be reached and communicated to the parties involved. Retaliation against any employee for filing a complaint or participating in an investigation is strictly prohibited. In the event an employee files a frivolous, malicious or false claim, appropriate sanctions for discipline of the complainant, including termination, may result. MAR-A-LAGO 0188 Case 18-2868, Document 278, 08/09/2019, 2628230, Page243 of 648 CARE OF FACILITIES The Club has made a large investment in equipment and facilities to provide each employee with the necessary resources to accomplish his/her duties. It is the responsibility of management and each employee to treat equipment and facilities with respect and care. Neatness and cleanliness are required to maintain these resources at a level at which the employee can and will be proud. Abuse of equipment and facilities will not be tolerated and may lead to disciplinary action including discharge. MAR-A-LAGO 0189 Case 18-2868, Document 278, 08/09/2019, 2628230, Page244 of 648 ENTRY AND gm or CLUB All employees must enter and leave the Club at the Southern Boulevard gates unless otherwise directed by management. Employees may not enter the Club grounds/premises more than 30 minutes before the start of their scheduled shift, and employees must exit the Club grounds/premises directly after their shift ends, unless authorized by your department head. When conducting Club business off the premises of Mar? a?Lago, you must have approval of your department head or supervisor. Employees may not patronize the Club facilities without prior written approval of their department head. If an employee needs to return to the property for any reason, the employee must contact their supervisor or a department head prior to their arrival. Security must be contacted in the event no supervisor is available. Case 18-2868, Document 278, 08/09/2019, 2628230, Page245 of 648 PROOF OF AUTHORIZATION TO WORK You must comply with government regulations by furnishing valid documentation of both your identity and your authorization to work. The Club Manager will advise you what documents are acceptable. If your immigration or work authorization status changes after you begin work so that you are no longer able to continue to work in the United States, you must advise your supervisor and the Human Resources Manager. MAR-A-LAGO 0191 Case 18-2868, Document 278, 08/09/2019, 2628230, Page246 of 648 SECURITY A. INFORMATION All financial, contract, production, and administrative records and information. of the Club and its 'members are confidential. Each employee is responsible for'making certain that information under his/her control is appropriately safeguarded. ,An employee will not provide or disclose office or guest information to third parties unless it has been determined that the party has a legitimate right to know and the request has been approved by your Supervisor. Authorization by the Managing Director must be obtained before written contact is made of any member, client, purveyor, (current or prospective). Any uncertainties should.be cleared with the Managing Director before such information is provided. B. CONFIDENTIALITY - No employee shall, during the term of his/her employment or thereafter disclose to others or use, except as authorized by the Managing Director, any of the Club's confidential, technical, or other business information. "Confidential, technical or other? business information" shall mean any information, including lists of the Club's vendors and customers, which.the employee has used, learned.or contributed during the course of his/her employment, regardless of whether it was written or in other tangible form that is not generally available to the public; or (ii) gives one who uses it a competitive advantage over the Club. C. FACILITIES - Access to Club facilities will be limited to parties with a legitimate reason to be there. Employees are not permitted to have? visitors on the premises unless special arrangements have been made by the employee?s supervisor. Outside visitors will be greeted by Post One and escorted to their area of business. Each employee should feel comfortable in.politely confronting an unknown individual who appears suspicious or in need of direction. An essential element of the security procedures of the Mar? a-Lago Club is the key control process. As such, employees who have access to Club keys must recognize the importance of properly safeguarding the keys which have been entrusted to them. All employees should be aware that they may be subject to disciplinary action for any violation of the key control procedures. Guest room keys must never be left in your locker. MAR-A-LAGO 0192 Case 18-2868, Document 278, 08/09/2019, 2628230, Page247 of 648 In the event of a breach or threatened breach by the employee of provisions A, or of this section, the Club shall be entitled to an injunction restraining the employee from disclosing or using, in whole or in part, such information or from rendering any services to any person, Club, corporation, association, or other entity" to whom such information, in whole or in. part, has been disclosed or is threatened to be disclosed? Nothing herein shall be construed as prohibiting the Club from pursuing other remedies available to the Club for such breach or threatened breach, including the recovery of damages from the Club. D. GUEST PRIVACY Everyone enjoys privacy. Employees are prohibited from revealing any personal or business information about a Club member. Do not divulge names or room numbers of one guest to another. Do not let a person into any guest room without verifying with the front desk that the person is the guest registered to that room. All guest floors and, areas are off limits to employees unless they are specifically assigned to perform work duties in these areas. Employees are not allowed to accept invitations from guests to join them. in their room. Am: no time is an employee to ask: a. member for' an. autograph. or to ask a member to socialize with them off duty. E. UNAUTHORIZED AREAS - Employees may not enter areas of the building, especially guest floors, unless they have been assigned by a supervisor. Example: Building Employees require work orders on gueSt floors. Food Service Employees require valid room service checks or authorized pick?up request before going on the guest floors. - F. REPORTING CRIME - The Security Department, with its able staff, attempts to control crime and provide a safe operation. Due to the enormity of the Club, they cannot be everywhere at once, and your help is needed. Follow these simple security measures: MAR-A-LAGO 0193 Case 18-2868, Document 278, 08/09/2019, 2628230, Page248 of 648 1) Notify Security (ext. 212) of any suspicious person. 2) If you are a witness to a crime, relate to the dispatcher as much specific detail as possible, including a description of the individual and the nature of the crime. G. MEDIA Because of the celebrated and historic nature of Mar?a?Lago and its significance to Palm Beach, Florida and the united States, we are contacted daily by the umdia (television, radio, newspapers, magazines, wire services). They want to know what is happening at the Club and they want comments for their articles or newcasts. It is important that no Club employee other than the Managing Director, Special Events Manager or Director of Membership comment to the press on the Club or it's members. GUEST NAMES All guests are to .be treated in a friendly, courteous, professional manner. Systems or procedures are used within each department to inform emplyees of our guests' names. We want you to use the guests' name at all times if possible. Be friendly to guests and call them by name; however, do not be too familiar with a guest by using his/her first name. 0194 Case 18-2868, Document 278, 08/09/2019, 2628230, Page249 of 648 SAFETY AND HEALTH The Club's goal is to provide a safe and healthy environment for employees. Each employee is expected to comply with all safety and health requirements whether it is established by management or by federal, state or local law. The Club does not expect any employee to take unnessary risks. Study the job assigned to you and learn the safety rules of your department. In everything you do, make sure that you have observed every reasonable safety precaution. Most Club accidents are simple and common, such as slips and falls, cuts, burns, sprains and strains. They are easy to prevent. Observation. of the following' general rules will prevent many employee accidents: 1. Report all injuries at once to your supervisor. 2. If you are not sure how to do a job safely, ask your department head. 3. Horseplay and practical jokes are prohibited. 4. Put equipment away after use. Don't block passages. 5. Broken chairs, loose and worn carpeting,-missing lights and other equipment needing maintenance may cause accidents. Report these along with any other safety hazard at once to your department head. 6. Wear the right clothing for the job. 7. Show other employees the safe way to do the job. 8. If the load seems too heavy to lift safely, get help. When lifting any load, follow the safe lifting practice listed below: a. Be sure you can handle it alone. If not get help. b. Face the load squarely. c. Secure a firm footing with your feet properly spread. d. Bend your knees. e. Get a grip on the load. f. Keep a straight back and lift by straightening your legs gradually not suddenly. MAR-A-LAGO 0195 Case 18-2868, Document 278, 08/09/2019, 2628230, Page250 of 648 9. Keep the load close to your body. h. Don't twist your body. 9. Do not carry a load so that it will block your vision Make sure you can see where you are going. 10. Avoid slippery, wet or greasy floors. Clean up wet or greasy spots as they occur. 11. Use a ladder to reach things that are up high. See that the ladder is firmly placed. While on the ladder, don't reach too high or too far to one side. 12. Place broken glasses, dishes, etc., in special receptacles designated for this purpose. 13. Do not operate equipment unless properly trained and specifically instructed to do so by your supervisor. All accidents occurring on the Club's premises or to Club employees, regardless of whether they result in an injury, must be reported immediately to your supervisor. The Club is required to report all work?related injuries as soon as possible. If you are too seriously injured to describe the facts surrounding the accident, it is the responsibility of the supervisor to supply the information to the Human Resources Manager. If a member has an accident, you should see that he or she is comfortable and. then immediately' notify' your supervisor, department head, Managing Director and the Security Department. Any property damage due to accidents should be reported in the same manner. WORKERS COMPENSATION We all do the best job we can.to prevent accidents and.injuries at home and at work. If you spot a safety hazard on the job, report it to your supervisor immediately. Workers' Compensation is provided by the company to pay an employee partial compensation if he or she loses time due to a work-related accident. In case you are injured: 1. Report the inujury immediately to your supervisor. 2. Following first-aid or 'medical treatement, your supervisor will contact security to file an incident report and then notify the Human Resources Manager. MAR-A-LAGO 0196 Case 18-2868, Document 278, 08/09/2019, 2628230, Page251 of 648 3. The Human Resources Manager completes the Workers' Compensation Report and submits copies to the insurance carrier. When you lose work time because of an injury on the job, a medical certificate from your doctor or the Health Center must be submitted to the Human Resources Manager with a return to work date prior to return to work. Remember to report all injuries immediately, no matter how small they may be, to your supervisor. Though the injury may seem small at first, it may become serious later, and result in lost work time. MAR-A-LAGO 0197 Case 18-2868, Document 278, 08/09/2019, 2628230, Page252 of 648 EMERGENCY PROCEDURES: Adhere to the following procedures in emergency situations: A. FIRE In case of fire or smoke: STAY CALM 1. Pull fire alarm 2. Dial Security at Extension 212 and.give location of fire, (closest room number, floor, type of fire or smoke), remain on the phone to give additional information as required. 3. When the fire department or Club fire brigade arrives, direct them to the location. Remember, most persons die from smoke and poisonous gases. Stay low to the ground if there is any smoke at all. If you encounter smoke or fire at lower levels, turn around and walk up to clearer air, or use another exit. 4. Be certain to follow instructions of the fire department and the Club fire brigade in order to ensure the safety of all guests and employees. B. BOMB SCARE OR WARNING You all know your own work areas, and are usually aware of any unfamiliar items. A bomb may be concealed in a length of pipe, small parcel, suitcase or paper bag. When a suspicious item is discovered DO NOT TOUCH and report immediately to: 1. Club operator - dial 300 . 2. Security dial 212 C. GUEST ILLNESS Follow the same procedures as listed above. The most important thing to remember in an emergency is DO NOT USE OF COMPUTER SYSTEM AND SOFTWARE PROGRAMS: A. GENERAL The Club has invested a large sum of money in its computer system and software programs. The information in the computer system represents much work by many employees and is an important component of the Club. In order to protect this valuable MAR-A-LAGO 0198 Case 18-2868, Document 278, 08/09/2019, 2628230, Page253 of 648 information, no employee is allowed to bring to work any computer games, hardware, programs or software which is not licensed and registered under the Club name, or install or otherwise use any such items unless they have been approved in advance, in writing, by the Managing Director. The reason for this is simple. Outside programs may contain viruses which can disrupt or destroy our computer system. Even if you are sure that the program you bring does not contain a virus, and that it would not damage our computer system, you are not to use any outside program without written advance approval. If software programs are not properly registered, there may be criminal and civil penalties for their use. In addition, the Club has noted that some computer programs also contain games or programs which are not related to the work of the Club. These programs are not to be played by any employee at any time during the work day. Only computer programs that are directly related to the work of the Club are to be used on Club computers. No employee is authorized to download or remove any information from the Club's computer system without the expressed advance permission of the appropriate supervisor. (See the Club's policy on security.) . ELECTRONIC MAIL During your workday, the electronic mail and other information systems are not to be used in a way that may be disruptive, offensive to others, or harmful to morale. Specifically, it is against Club policy to transmit E?mail communications that contain ethnic slurs, racial epithets, or anything that may be construed as harassment or offensive to others based on their race, national origin, sex, sexual orientation, age, disability, religious or political beliefs, is strictly prohibited and may constitute grounds for termination. Employees should use the information systems for Club business only. The E?mail system also should not be used to solicit others for commercial ventures, religious or political causes, outside organizations, or other personal matters unrelated to your job. For privacy reasons, employees should not attempt to gain access to another employee's personal file of E?Mail messages without the latter's express permission. Further, employees shall not use a code, access a file or retrieve any stored communication, other than where authorized, unless there has been prior clearance by an authorized Club representative. Management reserves the right to enter an employee's E?mail files on an "as needed" basis by authorized personnel to ensure the Club's legitimate business interest in the proper use of its property. System security features such as passwords and message MAR-A-LAGO 0199 Case 18-2868, Document 278, 08/09/2019, 2628230, Page254 of 648 delete functions do not neutralize the employer's ability to access any message at any time. Employees who use E?mail for private, non?job-related purposes do so at their own risk. By using the Club's equipment and E?mail systems, employees consent to have such E-mail use, messages and files monitored by authorized firm personnel. C. VOICE MAIL The Club utilizes a voice mail system which allows employees, clients, etc. to leave voice messages. The Club reserves the right to monitor and review all messages left on the voice mail system at any time. All voice messages should be confined to business or work?related matters. D. I RIGHT TO INSPECT No employee is to have an expectation of privacy with regard to any voice mail messages, mail or computer files, and the Club has the right to monitor and review these electronic and computer systems at any time. Case 18-2868, Document 278, 08/09/2019, 2628230, Page255 of 648 DISCLOSURE OF EMPLOYEE INFORMATION REFERENCE CHECKS All inquiries regarding a current or former employee of The Mar?a-Lago Club must be referred to the Human Resources Manager. Should an employee receive a written request for a reference, he/she should refer the request to the Human Resources Manager for handling. No Mar?a-Lago Club employee may issue a reference letter to any current or former employee without the permission of the Human Resources Manager or Managing Director. under no circumstances should any Mar?a?Lago Club employee release any information about any current or former Mar-a-Lago Club employee over the telephone. All telephone inquiries regarding any current or former employee must be referred to the Human Resources Manager. In response to an outside request for information regarding a current or former Mar?a?Lago Club employee, the Human Resources Manager will furnish or verify only an employee?s name, dates of employment, job title and department. No other data or information regarding any current or former Club employee, or his/her employment with Mar?a?Lago will be released unless the employee authorizes the Club to release such information in writing or Mar?a?Lago is required by law to furnish any information. MAR-A-LAGO 0201 Case 18-2868, Document 278, 08/09/2019, 2628230, Page256 of 648 NO DISTRIBUTION Persons who are not employees of the Club are prohibited from soliciting our employees, distributing literature, or selling merchandise to our employees, on our premises at any time. The purpose of this rule is to prevent employees and customers from being disrupted or imposed upon by such activities and to maintain our operations at peak efficiency at all times. For similar reasons, solicitation and distribution of literature are prohibited during the working time of either the employee making the solicitation or distribution, or the targeted employee. The term "working time" does not include an employee's authorized lunch or rest periods, or other time when the employee is not required to be working. Distribution of literature is prohibited in work and customer areas at all times. The distribution of literature in such a manner as to cause litter on the Club's property is prohibited. Off?duty employees are not allowed to return to the interior or working areas of the Club's premises until the next scheduled work time. The Club maintains bulletin boards to communicate Club information to employees and to post notices required by law. These bulletin boards are for the posting of Club information and notices only, and only persons designated by the Managing Director may place notices on or take down material from the bulletin boards. The unauthorized posting of notices, photographs or other printed or written materials on bulletin boards or any other Club property is prohibited. MAR-A-LAGO 0202 Case 18-2868, Document 278, 08/09/2019, 2628230, Page257 of 648 INSPECTIONS The Club respects its employees' right to privacy. However, for security purposes, we maintain the right to inspect certain personal belongings. Each employee agrees, as a condition of continued employment, to allow management to inspect employee personal property on our premises. Any package brought into or taken out of our premises may be inspected. Our premises and equipment, including Club vehicles, lockers and desks, are subject to inspection at any time. Refusal to cooperate in an inspection or search will be considered a violation of your terms of hire and insubordination. INTERNIL INVESTIGATIONS From time to time The Mar-a-Lago Club may be required to conduct internal investigations pertaining to security, auditing or work-related matters. Employees are required to cooperate fully with and assist in these investigations if requested to do so. Whenever necessary, in Management?s discretion, employees? work areas desks, file cabinets, etc-) and personal belongings brief cases, handbags, etc.) may be subject to a search. Employees are required to cooperate. Management will generally try to obtain an employee?s consent before conducting a search of work areas or personal belongings, but may not always be able to do so. MAR-A-LAGO 0203 Case 18-2868, Document 278, 08/09/2019, 2628230, Page258 of 648 OUTSIDE EMPLOYMENT The Club does not object to your holding other jobs, provided that there is no conflict of interest and your job at the Club comes first. However, outside employment which interferes with your obligations to the Club is prohibited. In addition, no employee shall claim to be a Club representative in connection with any outside employment. Before accepting any supplementary job, it is mandatory that you notify your Supervisor and the Department Head to determine if there is a conflict of interest or if it would adversely affect your job performance at the Club. If the Club determines that a conflict of interest exists or acceptance would adversely affect your job performance, you shall not engage in outside employment. Failure to notify the Supervisor and the Department Head in advance of any outside employment will be grounds for immediate termination. Please note that if at any time your job at the Club suffers due to additional employment elsewhere, the Club reserves the right to ask you to give it up. Failure to comply with such a request will also be grounds for immediate termination. MAR-A-LAGO 0204 Case 18-2868, Document 278, 08/09/2019, 2628230, Page259 of 648 PROPERTY OF EMPLOYER Employees may not remove from the Club premises any Club property not belonging to the employee. Any other property that an employee removes from Club premises, must be accompanied by a Club Package Pass, signed by a department head or his/her designated supervisor. Upon termination of your employment, you must surrender to the Club any and all material including, but not limited to, drawings, manuals, reports, documents, lists of the Club's vendors and customers, and the like (including all copies thereof), that you have in your possession relating to the business of the Club, or its affiliates. You recognize that all such materials are the property of the Club solely and that you have no right, title, or other interests in or to such materials. MAR-A-LAGO 0205 Case 18-2868, Document 278, 08/09/2019, 2628230, Page260 of 648 EMPLOYEE APPRAISAL It is the objective of the Club to provide an atmosphere in which each employee can receive periodic, thorough appraisals of their performance and compensation. The Club uses the performance evaluation as a means to achieve these objectives. Each Manager, Supervisor and employee should be familiar with their role in contributing to the success of the appraisal system. TELEPHONE COURTESY Telephone Calls Personal calls are prohibited,except in an emergency, since it interferes with the flow of business. Telephone courtesy is an essential part of every employee's interaction with guests. All incoming calls should be answered according to the following mandatory procedures: 1. All calls are to be answered within three rings Case 18-2868, Document 278, 08/09/2019, 2628230, Page261 of 648 2. Answering a Department line: a. standard greeting Good Morning/Afternoon/Evening). b. Give the name of the department. c. Give your name. d. Offer assistance: "Good morning, Reception Desk. This is John. How may I help you?" 3. Answering another individual's line: a. Standard greeting. b. Identify whose office 0r department. c. Give your name. - d. Offer assistance or to take a message: "Good afternoon, Mr. Smith's office. This is Mary. How my I help you?" 4. When placing a call on "hold:" a. Use the word "wait,? not "hold." b. Always ask permission and wait for guest's response: ?Are you able to wait?" 5. Returning to a call placed on "hold": a. Always thank the guest for waiting or apologize for the wait. b. Give your name. Offer assistance: "Thank you for waiting, this is Mary. How may I help you?" 6. When transferring a call: a. Always announce the transfer of a call to the party receiving the call: "Mr. Smith, I am; transferring Bob JOnes to you." b. The caller should then be connected and an announcement of the connection made: have Mr. Smith on the line now. Go ahead, please." 7. When ending a conversation: a. Always say "thank you" or "you're welcome." b. Use the guest's name if possible. c. Let the caller know you are happy to be of service or sorry you are unable to help. d. End the conversation with "good?bye" and hand up the receiver gently: "Thank you for calling, Mr. Smith. We're glad we could help. Good-bye." MAR-A-LAGO 0207 Case 18-2868, Document 278, 08/09/2019, 2628230, Page262 of 648 MAR-A-LAGO 0208 Case 18-2868, Document 278, 08/09/2019, 2628230, Page263 of 648 EMPLOYEE ATTENDANCE AND TARDINESS Your schedule is developed after considering the Club's needs and flow of business. Your adherence to the schedule and flexibility concerning any necessary changes will help ensure our Club's success. Each employee is required to work the hours normally scheduled for his or her assigned position. Employee's work schedules will be those hours authorized by their Supervisor to meet operaional requirements. If you are unable to report to work for any reason, you must notify your supervisor no later than Three (3) hours prior to your scheduled reporting time, stating your reason for lateness or absence, and when you expect to arrive at work. Check with your supervisor to see if additional notice time is required. In the event your supervisor is not available, you are to contact SECURITY Ext.212 or the Human Resources Manager. You must call in each day of your absence. Upon the third consecutive day of absence, a Health Care Provider's note will be required of the employee before returning to work. An employee who is absent for three consecutive days without proper notice to the Club may be considered to have voluntarily resigned his or her position with the Club. Failure to adhere to employee attendance policies results in time consuming arrangements and costly replacements and may lead to disciplinary action. Tardiness places an unfair burden upon your supervisors and co-workers. All efforts should be made to be at work according to schedule. Your supervisor is to be contacted if it is unavoidable for you to be late to work. Continued tardiness will result in disciplinary action, up to and including termination. MAR-A-LAGO 0209 Case 18-2868, Document 278, 08/09/2019, 2628230, Page264 of 648 LINEN ABUSE Linen abuse is considered to be any type of mishandling or misuse of linen, causing damage to the point that the linen would be unfit to place before a guest. The following are the most common abuse occurrences. Using linen as rags for cleaning. Leaving linen lying on the floor. Cleaning ashtrays with linen. Using napkins as food covers. Carrying linen on your person to be used as sweatbands, handkerchiefs, etc. Throwing rags or linen in the trash. Mixing rags with linen. Violation of these linen abuse standards may lead to disciplinary action. The replacement of lost or damaged linen is a costly process, and we need everyone's help in curtailing this enormous expense. MAR-A-LAGO 0210 Case 18-2868, Document 278, 08/09/2019, 2628230, Page265 of 648 TIME REPORTING - SIGNING IN AND OUT You must check in first at the guard post at the employee's entrance on Southern Boulevard, and then again upon your arrival at Post One. At the end of your shift you must check out at Post One and also at the guard post at the employees' exit on Southern Boulevard. When reporting in and out of work employees will be solely responsible for keeping their own hours worked by logging in and out at the timekeeping terminal. Pay is calculated for the actual hours worked by the actual entry of this information. Any deviations in the schedule including overtime can be done with the supervisors approval only. These deviations are indicated in writing at the end of the work week for presentation to payroll. Under no condition shall an employee enter for time other than his/her own. An employee who leaves the Club during his/her work schedule must first obtain their supervisor's permission. Failure to adhere to these procedures, will result in disciplinary action, up to and including termination of employment. wait Staff employees must also sign in on the SIGN IN which will be located with your Captain. CHANGE OF ADDRESS OR STATUS - PERSONNEL RECORDS To keep necessary Club records up?to?date, it is extremely important that you notify the Human Resources Department of any changes in: Name and/or marital status. Address and/or telephone number. of eligible dependents. W4 Deductions. MAR-A-LAGO 021 Case 18-2868, Document 278, 08/09/2019, 2628230, Page266 of 648 INITIAL ?191.0me PERIOD Every new employee goes through an initial period of adjustment in order to learn about the Club and about his/her job. During this time, the employee will have an opportunity to find out if he/she is suited to, and likes, his/her new position. Additionally, the initial employment period gives the employee?s supervisor a reasonable period of time to evaluate his/her performance. The initial employment period is 3 months. During this time, the new employee will be provided with training and guidance from his/her Supervisor. He/she may be discharged at any time during this period if his/her Supervisor concludes that he/she is not progressing or performing satisfactorily. Additionally, under appropriate circumstances, the initial employment may be extended. At the end of the initial employment period, the employee and his/her supervisor may discuss his/her performance. Provided his/her job performance is ?satisfactory? at the end of the initial employment period, he/she will continue in our employment. EMPLOYEE CATEGORIES Full Time - Year Round Employee Seasonal Employee WORK HOURS. SALARY gm: A. WORK HOURS The Club never shuts down from November 1 to Mother's Day; for 24 hours a day, 7 days a week, it serves the diverse needs of our members. Therefore to ensure adequate coverage at all times, departments have arranged different schedules for their employees. MAR-A-LAGO 0212 Case 18-2868, Document 278, 08/09/2019, 2628230, Page267 of 648 SALARY The Club's policy regarding personnel is to offer competitive starting wages and to maintain a fair and equitable wage structure. Wage increases are given when appropriate based upon results of performance evaluations and/or employment status change. The work week at the Club begins on Monday and ends on Sunday. Scheduled paydays are as follows: Friday pay vouchers indicating deposit into your existing Great Western banking account will be issued. If there is a discrepancy in your paycheck, advise your department head immediately. Do not call or go to the payroll department. If your department head is not available, contact the Human Resources Manager and assistance will be provided. The Club is unable to make advances on employee paychecks. OVERTIME PREMIUMS 1. Hourly and Salaried Employee (non?exempt) Hourly or salaried employees are eligible for overtime premium at one and one-half (1.5) times their base hourly rate under the following conditions: Overtime work has been specifically authorized by the direct Supervisor in advance or in writing after the fact. More than forty (40) hours are actually worked by that individual in one work week, not including sick time, vacation, holidays and time off for personal business and other non work time. The work week commences on Monday morning and ends Sunday at midnight. 2. Salaried Employee (exempt) A salaried exempt employee is not compensated directly for specific overtime hours worked. A salaried employee is paid to accomplish a specific job and his/her salary is based upon the fact that hours in excess of 40 per week may be necessary on occasion. Overtime is at the request of a supervisor or department MAR-A-LAGO 0213 Case 18-2868, Document 278, 08/09/2019, 2628230, Page268 of 648 head for emergency client business. The Supervisor must authorize overtime and sign the employee?s schedule signifying such authorization. EMPLOYEE BENEFITS AND PROGRAMS As a regular full time year round employee you will enjoy an excellent benefits package which is designed to help protect your health, and plan for your future. The Mar-a?Lago Club reserves the right to change any or all of these benefits at any time. Group Health Insurance Group Life Insurance Group Dental Insurance 401K After one full year of continuous employment For information relating to the cost of such benefits, eligibility requirements, etc. please contact the Human Resources Manager. MAR-A-LAGO 0214 Case 18-2868, Document 278, 08/09/2019, 2628230, Page269 of 648 BEREAVEMENT LEAVE In the event of a death in an employee?s immediate family, the Club will allow a maximum of three (3) days off with pay for funeral related leave. Immediate family includes spouse, child, mother, father, brother, sister, grandparent, grandchild, aunt, uncle, daughter?in?law, son?in?law, mother?in?law, father-in-law, step?child, step?parent. When a death occurs, notify your supervisor at once with all of the details, including the family member who died and where the funeral will take place. The supervisor should notify the Human Resources Manager of the reason and length of the employee's absence. JURY DUTY An employee summoned for jury duty will be compensated in the following manner only if he/she notifies his/her supervisor and provides him/her with a copy of the summons. During the jury leave, the employee will be paid the difference between jury compensation and the employee's regular pay for up to three days. Any day in which you are excused from jury service at a time when there are three (3) or more hours remaining in your daily scheduled shift, you will report for work. the jury duty falls at a time when the employee cannot be away from work, the court may allow the employee to choose a more convenient time to serve if he/she makes a request in accordance with the court's procedure. MAR-A-LAGO 02 15 Case 18-2868, Document 278, 08/09/2019, 2628230, Page270 of 648 MILITARY LEAVE An employee who is a member of the united States Army, Navy, Air Force, Marines, Coast Guard, a member of the National Guard, a member of the Reserves or Public Health Service will, where a specified period of active or reserve duty is mandatory, be granted a leave of absence in accordance with applicable law. Upon receipt of orders for active or reserve duty, the employee should notify his/her supervisor, as well as the Human Resources Manager immediately and he/she must submit a copy of his/her orders to his/her supervisor and the Human Resources Manager. MATERNITY LEAVE or ABSENCE Pregnancy, childbirth, and related medical conditions are temporary disabilities for the purpose of any health or temporary disability insurance or sick leave policy maintained by the Club. An employee who is pregnant, or has medical conditions related to pregnancy will be granted a leave of absence and will be eligible for the same leave benefits as received by employees suffering from illness or other temporary disabilities. FAMILY MEDICAL AND PERSONAL LEAVE OF ABSENCE MAR-A-LAGO 0216 Case 18-2868, Document 278, 08/09/2019, 2628230, Page271 of 648 As a result of the Federal Family and Medical Leave Act the Club provides an added benefit to each employee. Each employee will have up to 12 weeks of unpaid family leave during a "rolling" 12-month period month period for: (1) the birth and care of a newborn child; (2) adoption or foster care of a child; (3) to provide care to an employee's spouse, son, daughter or parent (or grandparent under certain circumstances) who has a serious health condition; and (4) the employee's own serious health condition which makes the employee unable to perform his/her job functions. Upon an employee's return from this leave, the Club guarantees that the employee will be placed in the same or equivalent position, absent grievous and substantial business reasons affecting the Club. This leave may be used during the rolling 12?month period even if the full 12 weeks have not been taken. Intermittent use of this leave or a reduced leave schedule may be allowed only where leave is taken for a sick family member, or for an employee's own serious health condition, when medically necessary. If you are not eligible for the 12 weeks unpaid leave, you may still be eligible to take-an unpaid leave of absence for medical reasons or a personal leave of absence at the discretion of the Club. As a result of the Act, it has been necessary to modify some provisions of our policies on sick days, short term disability and personal leaves of absence to comply with the Act. The information that follows is designed to address the great majority of situations that arise in a regular or routine manner. The federal Family Leave Law, however, is subject to on?going review process and interpretation by the courts, therefore, the statements made here can not possibly address every contingency that may arise in interpreting this new and broad Law. For these reasons, special situations will be reviewed on a case?by?case basis. Set forth below is the Club policy with regard to medical and personal leaves of absence, including provisions of Act. If you have any questions, please contact the Human Resources Manager who will be glad to answer your questions. A. 12 Week Family Medical Leave Purpose: I This policy allows an employee to request a family or regular medical leave of absence (LOA) because the employee has a serious health condition which makes the employee unable to perform the functions of the job position (this policy includes a serious health condition related to pregnancy). MAR-A-LAGO 0217 Case 18-2868, Document 278, 08/09/2019, 2628230, Page272 of 648 Policy: All employees with a minimum of 12 months of service (and 1250 or more hours worked during the previous 12 months) at the time the family medical LOA begins, are eligible for up to 12 weeks of unpaid family medical LOA during a rolling 12?month period. Employees are eligible so long as the employee is certified to be unable to work during this LOA period. See Section below for details on requesting this LOA. B. Regular Policy for those Not Eligible for Family Medical LOA ie.q. previously used Familv LOA) All employees who are not eligible for the 12 week family medical LOA at the time the medical LOA begins less than 12 months of service, less than 1250 hours worked, or insufficient time has passed since a previous LOA) are eligible for unpaid medical LOA normally not to exceed 10 days. See Section below for details on requesting this LOA. C. Family and Personal LOA This policy allows an employee to request consideration for a family or personal LOA.I 1. Policy {Family LOA): All employees with a minimum of 12 months of service and 1250 or more hours worked in the previous 12 months at the time the family LOA begins are eligible for up to 12 weeks of unpaid LOA during a rolling 12-month period for: the birth or adoption (or foster care) of a child. providing care to a family member who has a serious health condition (family member is defined as spouse, child, or parent). Please Note: A child is one who is under 18 years of age or if 18 years or older must be incapable of self?care because of mental or physical disability. 2. Policy (Personal LOA) Employees who are not eligible for the 12 weeks family LOA at the time the LOA begins less than 1 year of service, less than 1250 hours worked, or insufficient time has passed since previous LOA) are eligible for a personal LOA without pay in the Club's sole discretion. MAR-A-LAGO 0218 Case 18-2868, Document 278, 08/09/2019, 2628230, Page273 of 648 Employees requiring additional time may be required to terminate employment and advise the Club of availability for future rehire. Request for non?family personal LOA may not be approved due to the effect on department operations and/or due to the individual's job performance. See Section below for details on requesting this LOA. D. General Procedures for LOA 1. While on an approved family or other LOA, an employee does not accrue time toward sick leave, vacation days, merit review nor does he/she receive holiday pay. 2. Detailed Procedures: A request for any medical LOA must be certified by the employee's health care provider on the claim form supplied by the Human Resources Manager. An employee requesting a medical LOA must provide the Human Resources Manager with sufficient medical evidence to support the condition that prevents the employee from performing the assigned job duties. ?This signed health care provider's statement must include effective date of the LOA, reason for the LOA and approximate date of return. If the medical evidence is deemed to be inconclusive, the Human Resources Manager may arrange for a medical examination (at the Club's expense) to determine the extent of the employee's condition. The Club may require periodic recertification. The duration of a medical LOA is determined by the period of time the employee has a serious health condition which makes the employee unable to perform the job efficiently and safely. Reinstatement may not be guaranteed in management's discretion (employee will be notified prior to beginning the LOA) if the employee is a key salaried employee. An employee who returns from a family medical or family LOA on or before the approved LOA has elapsed will be reinstated to his/her previous department and job. Otherwise, every effort will be made to place the returning employee into an equivalent position. However, for an employee returning from a LOA that has exceeded the allowed maximum calendar days, no MAR-A-LAGO 0219 Case 18-2868, Document 278, 08/09/2019, 2628230, Page274 of 648 guarantee of reinstatement can be made. In addition, no guarantee of reinstatement can be -made for a regular medical or non-family personal LOA. However, if possible, the employee will be re?employed in accordance with the following priorities: In his or her former job if available; In a comparable job at the same (or higher grade) if available, and if the employee is qualified for that job (at the same salary or higher); In a lower grade job, if available, and if the employee is qualified for that job. If reemployed, the employee will receive the same salary as he or she received immediately prior to the LOA unless such salary exceeds the maximum salary for the employee's grade upon reemployment, in which case the employee will be paid at that grade maximum; or If no job is available at the termination of the LOA, the employee will be placed on a preferential hiring list at the Club's sole discretion in a position for which the employee is qualified. A request for an LOA is expected to be submitted to the employee's supervisor and the Human Resources Manager at least 30 days prior to the effective date of the LOA (emergencies excepted). This request should include the effective date of the LOA, reason for the LOA and approximate date of return. For a medical or family LOA, each employee will be required to use earned vacation, personal days and sick pay benefits at the beginning of the LOA. For a personal LOA, only earned vacation will be required to be used. For each employee granted a family medical or family LOA, the Club will continue the group health insurance benefit coverage under which the employee was covered as of the last day worked. However, any premiums paid by the employee prior to the LOA must continue to be paid by the employee during the LOA. Payments are due at the same time as they would be made by payroll deduction. If an employee fails to return to work after taking a family or medical LOA, the employee may be potentially liable for payment of health MAR-A-LAGO 0220 Case 18-2868, Document 278, 08/09/2019, 2628230, Page275 of 648 insurance premiums paid by the employer during the LOA. (9) An employee on an LOA must notify the Human Resources Manager of intent to return at least 7 days prior to the desired return date. Medical certification of ability to resume duties must be provided to the Human Resources Manager prior to returning to work. Failure to provide medical certification may result in disciplinary action or termination. An employee must contact the Human Resources Manager with a request for an LOA extension at least 14 days in advance of the scheduled return (emergencies excepted). Medical certification is required prior to the beginning of the extension for a medical LOA. The Human Resources Manager will notify the appropriate Manager of the date of return of an employee returning from an approved LOA. If an employee fails to return to work at the conclusion of an LOA, the LOA will be cancelled and employment will be discontinued as a voluntary termination with the effective date of termination the last day actually worked. An employee requiring a medical or personal LOA who has not completed the initial probation period is not eligible for such a LOA and must terminate his/her employment. These employees may be eligible for conversion of group medical insurance. At the Club's option this category of employee may be placed on a preferential hiring list. (1) Abuse of an LOA may result in termination of employment. In any case in which a husband and wife are entitled to a LOA, the total days of family LOA to which both may be entitled may be limited to 12 weeks during any rolling 12-month period if the family LOA is taken for the birth, adoption (or foster care) of a child. In addition, as an alternative to the LOA, the Club and each employee may mutually agree to 'alternate employment for the employee for the time during which the employee would otherwise be entitled to a LOA under Club policy. Such period of alternate employment will not cause a reduction MAR-A-LAGO 0221 Case 18-2868, Document 278, 08/09/2019, 2628230, Page276 of 648 in the period of the LOA to which the Club employee is otherwise entitled for their own serious illness. (0) The rolling 12?month period in which the 12 weeks of LOA entitlement occurs is a "rolling" 12?month period measured backwards from the date an employee uses a family or medical LOA. Exception Approval: Questions concerning this policy should be directed to the Human Resources Manager. GRIEVLNCE PROCEDURE The Club recognizes that employees may have questions or problems concerning the Club's policies and procedures. In order to encourage employees to voice these concerns and try to solve the questions or problems that may arise, we have a formal problem solving procedure. Please follow these steps: Step 1: You should first request to meet with your immediate supervisor (the person you report to directly). The supervisor will listen and investigate the problem with the intention of finding an agreeable solution for those concerned. In order to facilitate a fair and timely solution, you must contact your supervisor within three days MAR-A-LAGO 0222 Case 18-2868, Document 278, 08/09/2019, 2628230, Page277 of 648 of the occurrence that created the question or problem. If you feel the problem is with your immediate supervisor, you may skip step 1 and start the grievance procedure with Step 2. Step 2: Request to meet with your Department Head. Your Department Head will review the problem (including any action taken by your immediate supervisor) and any other relevant facts involved in order to suggest a reasonable solution. In order to facilitate a fair and timely solution, you must contact your Department Head within three days of the occurrence that created the question or problem (if you skipped Step 1) or within two days of your supervisor's resolution (if you followed Step 1. If you are not satisfied with your Department Head's handling of the problem, you may proceed to Step 3. Step 3: Request to meet with the Managing Director, or a designated representative, will thoroughly investigate the problem, review Club policies, procedures, rules and regulations and will make a determination. In order to facilitate a fair and timely solution, you must contact the Managing Director within two days of your Department Head?s determination. The Managing Director, or his or her designee, may review the matter and offer a final decision. Time spent by an employee in discussing a complaint with management during normal working hours will be considered hours worked for pay purposes. When two or more employees have a common or similar complaint, the employees may select a spokesperson to represent the group. The final decision on the complaint submitted by several employees through a spokesperson will be binding on all members of the group. If at any time you feel uncomfortable with this process, as it is outlined here, please feel free to contact the Managing Director to assist you before taking further action. Due to the serious nature of sexual harassment, such complaints should be referred immediately and directly to the Managing Director and Human Resources Manager. MAR-A-LAGO 0223 Case 18-2868, Document 278, 08/09/2019, 2628230, Page278 of 648 The Club will not tolerate any form of retaliation against employees who have used the Club's problem solving procedure. In the interest of creating a positive and enjoyable work environment, all employees shall be able to use this procedure . without fear of retaliation. However, it is equally important to realize that the problem solving procedure will not prevent the Club from taking disciplinary action, up to and including termination, against any individual under circumstances where the Club deems disciplinary action to be appropriate. MAR-A-LAGO 0224 Case 18-2868, Document 278, 08/09/2019, 2628230, Page279 of 648 DISCIPLINARY ACTION A. GENERAL POLICY ADHERENCE Policies and procedures are necessary guidelines to provide a basis for fair and equitable treatment of each employee. In addition, these guidelines serve as the basis for a fair relationship between the employee and the Club. It is necessary that these guidelines be applied consistently to each employee regardless of location, department or manager. Then, and only then, can the Club establish the confidence that each employee will be treated consistently according to the administrative and operational guidelines. It is the responsibility of each officer, manager, supervisor and employee to contribute fully toward the achievement of this objective. B. DISCIPLINARY ACTIONS Violations of any of the established policies and procedures may result in disciplinary action including probation or discharge. The nature of the disciplinary action is contingent upon the facts and circumstances of the individual situation. The following employee actions are not all inclusive but, by way of illustration only, are some of the events which could result in discipline including discharge. Thus, your department head may establish additional rules and regulations he or she feels are necessary for the orderly fulfillment of your department's responsibilities. These also must be followed. Other actions may also result in discipline including discharge. (It should be noted that the Club and each employee recognize that the employment relationship is for an indefinite period and may be terminated by either party at will.) By providing this list, the Club in no way restricts its legal discretion to terminate employment. a. Insubordination, refusal or inability to comply with reasonable instructions of supervisors or department heads. If your supervisor requests you to do something with which you disagree, always follow the instructions at the time and then discuss it later at an appropriate time and location. However, this excludes obedience to demands constituting discrimination, sexual harassment or illegal conduct. b. Interference or hindrance with shift schedules. Failure to work on a shift as scheduled or arranging your own shift replacement without the supervisor's permission. c. unauthorized use of Club telephone or property and/or guest facilities. d. Entering the Club more than 30 minutes before your shift begins or leaving the Club more than 30 minutes after the end of your shift without the permission of your department head or supervisor. Entering or MAR-A-LAGO 0225 Case 18-2868, Document 278, 08/09/2019, 2628230, Page280 of 648 presence in areas within the Club premises without authorization or just cause. e. Presence on Club premises at anytime other than your assigned work shift unless specifically authorized by your department head in advance. f. An essential element of the security procedures of the Mar-a?Lago Club is the key control process. As such,_ employees who have access to Club keys must recognize the importance of properly safeguarding the keys which have been entrusted to them. All employees should be -aware that they may be subject to disciplinary action for any violation of the key control procedures. Guest room keys must never be left in your locker. g. Theft (unauthorized removal) or misappropriation (unauthorized storage, transfer, utilization or possession) of Club services unauthorized telephone calls, laundry/valet, food and beverage), or guest, employer or Club property, including items found on the Club premises. All articles found on Club premises must be turned into the Lost and Found area at Security in the Timekeeper's area. h. Altering or falsifying a guest check or credit voucher or forging tips through guest checks. i. Refusal to comply with Club rules, policies or procedures. j. Poor job performance, including unsatisfactory attitude that detracts from job performance or the efficient operation of the Club. k. Violation of sexual harassment policy. 1. Failure to report for duty without a bona fide excuse and proper notification to your supervisor. m. Failure to comply with established safety and health rules and safe work procedures or engaging in any conduct that creates a safety hazard. Failure to meet performance standards. Failure to follow grooming and appearance standards. Failure to report a workplace accident immediately. If you are injured on the job, you must immediately report this to your supervisor or Human Resources Manager. Falsely stating claims of injury. Disorderly conduct on the Club premises, including fighting, horseplay or other action that endangers others or Club property. 5. Offensive or disruptive behavior, including threatening employees, using abusive or vulgar language, interfering with others in the performance of their duties, or acting in an immoral or indecent manner on Club property, or while off the Club premises in performance of Club duties. 0:3 Fi? t. Destruction, misuse, or removal of Club property, a guest's property or another employee's property. u. Unauthorized disclosure, discussion, removal or use of Club confidential, information, trade secrets or other MAR-A-LAGO 0226 Case 18-2868, Document 278, 08/09/2019, 2628230, Page28l of 648 proprietary information (including information contained in personnel records). v. Deliberate omission or falsification of information on employment application, time sheets, production or other Club records. w. Unauthorized distribution of literature, posting Of notices or signs on Club, premises, fundraising, selling lottery tickets or merchandise, or soliciting donations or any other type of money raising on Club premises, unless specifically authorized by the Managing Director. x. Refusal to allow security checks and package inspections. y. Reading books, magazines, or newspapers while on duty, except where required in the line of duty. 2. Loitering, loafing or sleeping on duty. aa. Neglect of duty causing defective work. bb. Smoking anywhere on club property including 124 Woodbridge Rd. and 1094 WOodbridge Rd. cc. Reporting for duty under the influence of intoxicating liquor, marijuana and/or illegal drugs. dd. Bringing, consuming, possessing, providing, selling, or otherwise using intoxicating liquors, marijuana and/or illegal drugs on Club premises. ee. Dishonesty, including but not limited to intentionally not providing full and truthful information when requested by management. ff. Gambling on Club premises. gg. Bringing, discharging, and/or possessing unauthorized firearms or other weapons on Club property or while off Club Property in the performance of Club duties. hh. Giving or taking a bribe of any nature. ii. Being arrested and/or convicted of any crime which the Club believes is detrimental to the Club and/or its other employees. jj. Theft, attempted theft, removal or unauthorized possession of the Club's property or property of other employees or customers. kk. Misappropriation of Club funds or failure to handle funds in accordance with Club guidelines. ll. Irregular attendance including excessive absenteeism, tardiness and/or unexcused absences. mm. Leaving work station or work without authorization or being in an unauthorized work area during your scheduled work period or on your days off, without your supervisor's specific authorization. nn. Interfering with or hindering of work schedules; failing to work on a scheduled shift; or arranging your own replacement on a shift without permission from a supervisor. 00. Failure to report to work after the expiration of a leave?of?absence or layoff. pp. Defrauding customers of the Club. qq. Embezzlement. MAR-A-LAGO 0227 Case 18-2868, Document 278, 08/09/2019, 2628230, Page282 of 648 rr. Disloyalty to the Club, including but not limited to, slandering the Club, or acting in such a manner that could damage the Club's reputation. ss. Moral turpitude. tt. Failure to wear assigned uniform. uu. Entering or leaving the property through any entrance or exit other than the designated employee entrance or exit. Punching in/out with another employee's I.D. Card or allowing another employee to punch in/out on your card. Unauthorized attendance at guest functions and/or in guest areas, or on the premises including guest rooms, dining rooms and lounges. No unauthorized social contact will be permitted at any time with Club guests. Discourteous or inappropriate conduct with guests/members. Using guest elevators, escalators, restrooms or any guest facility except when specifically required by job functions or authorized by management. zz. Gum chewing, eating or drinking in any public area of the Club. Soliciting gratuities frOm guests or commenting on the amount of a gratuity. .5 MAR-A-LAGO 0228 Case 18-2868, Document 278, 08/09/2019, 2628230, Page283 of 648 UNIFORMS AND PERSONAL APPEARANCE A. UNIFORMS Employees issued a uniform are responsible for turning their soiled uniform to the Laundry Department at the end of their shift and picking up a clean one for the next day of work. All employee uniforms are laundered by the Club at no charge to the employee. B. PERSONAL APPEARANCE Departure from conventional Club attire or personal grooming are not permitted, regardless of the nature of the job performed. (1) Every employee has some contact with the public and therefore represents the Club in appearance as well as by actions. The properly attired employee helps to create a favorable image for the Club. Accordingly, personal appearance shall be governed by the following standards: Good hygiene and grooming practices are required. A daily bath or shower is a necessity and all employees should report to work freshly bathed. Keep in mind you may be going from a hot kitchen to an air conditioned guest room. Body temperatures will change quickly and body odors are offensive. Remember, there is no substitute for good deodorant. Bad breath is also offensive and mouthwash should be used in addition to brushing teeth. Good hygiene and grooming practices are required. Fingernails, and hair must be clean and neatly trimmed at all times. Beards,goatees, and un?trimmed sideburns are not permitted. Mustaches must be neatly trimmed. Men's hair should not exceed collar length and must be conservatively styled. Visible body piercing is not permitted for men or women, nor ear jewelry for men. Hair must be neatly arranged and kept from covering eyes, and must be covered or restrained where required by health code. All employees must wear their nametags (to be provided) at all times while on duty. MAR-A-LAGO 0229 Case 18-2868, Document 278, 08/09/2019, 2628230, Page284 of 648 All employees are expected to report to work in clean, neatly pressed clothing, clean shoes and clean personal appearance. Female employees who are not required to wear a uniform may wear suits, dresses, skirts or slacks with blouses or sweaters. ?Mini" skirts are not permissible. No blue jeans or jeans of any color are permitted. Denim outfits resembling blue jeans and jean skirts are also unacceptable. No strapless or backless garmets may be worn. Females must wear the proper undergarments, including a bra and a full or half slip where necessary, depending on the Sheerness of the outer garment. Hose are required with skirts and dresses. Hose or socks are required with pants. Jewelry: For safety reasons, jewelry should be kept to a minimum. Acceptable jewelry for service employees is a wrist watch and a total of three rings. Female service employees are allowed to wear one pair of small earrings (no larger than a dime). Non guest contact female emplOyees are allowed to wear a maximum of two earrings in each ear. Tattoos: Exposed tatoos are not allowed on any public contact employees. FULL TIME YEAR ROUND EMPLOYEES - During the summer months when the Club is closed and there is no public contact you may see your Department Head as to - what is considered to be proper attire for your position. (2) Supervisors have the responsibility to decide when an employee's appearance is unacceptable. In the event of an unacceptable appearance, the Supervisor may request that the employee return home to change or take an appropriate corrective action. The employee generally shall not be compensated for any such time away from work, and repeated violations of this Policy will be cause for disciplinary action. MAR-A-LAGO 0230 Case 18-2868, Document 278, 08/09/2019, 2628230, Page285 of 648 AIDS POLICY The Club recognizes that Acquired Immune Deficiency (AIDS), its related conditions such as AIDS Related Complex (ARC), and persons with seropositive test results pose significant and delicate issues for employees in the workplace. Accordingly, we have established the following guidelines for handling employee issues that arise when an employee is affected by this disease. (1) The Club is committed to maintaining a safe and healthy work environment for all employees. (2) Consistent with this commitment, the Club will treat AIDS the same as other illnesses in terms of all our employee policies and benefits, such as group health and disability benefits. (3) Based on the overwhelming preponderance of available medical and scientific opinion, including statements from the U.S. Public Health Service, Centers for Disease Control, there is no evidence that the AIDS virus is casually transmitted in ordinary social or occupational settings or conditions. Therefore, subject to changes in available medical information, it is the policy of the Club that employees with AIDS or any of its related conditions may continue to work and the Club will provide them with reasonable accommodation as long as they are medically able to perform the duties of their position. (4) Employees who are affected by AIDS or any other life-threatening illness will be treated with compassion and understanding in dealing with their personal crises. Co?workers will be expected to not refuse to work or withhold their services for fear of contracting AIDS by working with an AIDS affected person, and to not harass or otherwise discriminate against an AIDS?affected employee. (5) Recognizing the need for all employees to be able to be accurately informed about AIDS, upon request, the Club will make every effort to have information available regarding the facts about this disease, how it is transmitted and not transmitted and how best to contain it from spreading. Employees affected by AIDS or any of its related conditions or concerned about AIDS are encouraged to contact Human Resources Manager to discuss their concerns and to obtain additional information. (6) The Club will treat all medical information obtained from employees with AIDS or any of its related conditions confidentially as required by law. The Club reserves the right to change this policy or make appropriate revisions, additions, amendments or corrections. We will notify you of any substantive changes. MAR-A-LAGO 0231 Case 18-2868, Document 278, 08/09/2019, 2628230, Page286 of 648 . If you have any questions about this policy or its interpretation or the information upon which it is based, please contact the Human Resources Manager. MAR-A-LAGO 0232 Case 18-2868, Document 278, 08/09/2019, 2628230, Page287 of 648 SUBSTANCE ABUSE POLICY Our Club strives to provide a safe work environment and encourages personal health. In regard to this, the Club considers the abuse of drugs or alcohol on the job to be an' unsafe and counterproductive work practice. Quite simply, our goal is to maintain a work environment that is free from the effects of alcohol and drug abuse. While the Club has no intention of intruding into the private lives of its employees, the Club does expect employees to report for work in condition to perform their duties. It is, therefore, Club policy that an employee found with the presence of alcohol or illegal drugs in his/her system, in possession of, using, selling, trading, or offering for sale illegal drugs or alcohol during working hours, may be subject to disciplinary action up to and including discharge. (Club sponsored activities which may include the service of alcoholic beverages are not included in this provision.) Substance Abuse includes possession, use, purchase or sale of drugs or alcohol on Club premises. It also includes reporting to work under the influence of drugs or alcohol. Prescription drugs?prescribed by the employee's physician may be taken during work hours. The employee should notify the Supervisor if the use of?properly prescribed prescription drugs will affect the employee's work performance. Abuse of prescription drugs will not be tolerated. An employee reporting for work visibly impaired is unable to properly perform required duties and will not be allowed to work. MAR-A-LAGO 0233 Case 18-2868, Document 278, 08/09/2019, 2628230, Page288 of 648 POLICY ON SMOKING Smoking is prohibited by any staff employee of The Mar?a- Lago Club on any and all properties adjacent to or that of The Mar?a?Lago Club to include: 124 Woodbridge Road Palm Beach, FL 1094 Woodbridge Road Palm Beach, FL MAR-A-LAGO 0234 Case 18-2868, Document 278, 08/09/2019, 2628230, Page289 of 648 USE AND The Mar?a?Lago Club recognizes that employee drug abuse interferes with the Club?s level of production, as well as its competitive position in the marketplace, and can result in costs, delays, and tragedies associated with work?related accidents. As a condition to employment or continued employment, you must refrain from reporting to work or working with the presence of drugs or alcohol in your body. To address the problem of drug/alcohol abuse and to comply with Florida's Workers? Compensation Drug?Free Workplace Act (the Act) The Mar-a-Lago Club adopts the policies and procedures detailed below. This policy will be administered in accordance with all relevant laws (state and local), including the ADA, the Florida Civil Rights Act, the Workers' Compensation Act, and in a non? discriminatory fashion. To protect the health, safety, and welfare of all Mar-a-Lago Club employees, it is the Club?s policy that the unlawful manufacture, distribution, dispensation, possession, or use of controlled substance on any Club property is absolutely prohibited. Controlled substances include, but are not limited to, amphetamines, barbiturates, cocaine, heroin, morphine, PCP, marijuana, hashish, and any other controlled substance listed in Schedules I through of Section 202 of the Controlled Substance Act, 21 U.S.C. 812 or in the Florida Statute on controlled substances, except for medication prescribed by the employee's physician. You are also prohibited from drinking alcohol during the business day. You are also prohibited from bringing alcoholic beverages onto the Club premises. Special care shall be taken during Company?sponsored social events for employees. In these cases, employees and guests below the legal age will not be allowed to drink alcoholic beverages. The amount of time alcohol is served will be limited as well as the quantity of the alcohol. If necessary, transportation will be arranged for someone if his or her driving ability seems to be impaired. The Mar-a-Lago Club will test for the presence of drugs under the following circumstances: 1) pre?employment testing, 2) reasonable suspicion testing (including post?accident incidents), and 3) follow?up testing. Such testing will be done in accordance with the Worker's Compensation Drug Testing Program, which policy had been given to all employees or can be obtained from the Human Resources Manager. Refusal to submit to the test or having a confirmed, positive test result will result in immediate discipline, including termination. Any questions about this policy should be referred to the Human Resources Manager. MAR-A-LAGO 0235 Case 18-2868, Document 278, 08/09/2019, 2628230, Page290 of 648 Any violation of The Mar?a-Lago Club's Drug/Alcohol Free Workplace Policy will result in appropriate discipline, up to and including termination. THIS POLICY REPRESENTS THE CURRENT POLICY FOR DEALING WITH A SERIOUS NATIONAL PROBLEM WHICH POSES A SAFETY THREAT TO THE WORKFORCE. THIS POLICY MAY BE CHANGED BY THE A-LAGO CLUB IN ITS DISCRETION. THIS POLICY IS NOT INTENDED TO CREATE A CONTRACT BETWEEN THE MAR-A-LAGO CLUB AND ANY EMPLOYEE. NOTHING IN THIS POLICY CHANGES THE ABILITY TO TERMINATE AN EMPLOYEE AT WILL, WITH OR WITHOUT CAUSE OR NOTICE. MISCELLANEOUS A. STAFF CAFETERIA For the purpose of control, the Cafeteria must remain for use of Club employees only. Any exceptions to this rule must be cleared by your department head in advance. In addition, all employees must adhere to the rules posted in the Cafeteria concerning its use. You are entitled to one meal per eight hour shift only. B. LOCKERS Those employees issued lockers are obligated to keep them clean and use them for storage of a change of clothing only. Lockers are not the areas for storage of valuables. Lockers are subject to inspection by management. Unauthorized materials such as alcoholic beverages, weapons, Club property and illegal drugs are prohibited. The Mar?a-Lago Club is not responsible for lost or stolen property. MAR-A-LAGO 0236 Case 18-2868, Document 278, 08/09/2019, 2628230, Page291 of 648 C. PHONES Employees on duty are not allowed to use the public phones in the lobbies or any guest areas. Phones are furnished out? side the staff dining room for employee use. D. LOST AND FOUND ARTICLES You must turn in lost and found articles to your supervisor, the Security Department or a security officer at One. E. GIFTS Gifts from guests of the Club of a value exceeding $25.00 are not to be accepted by employees of The Mar-a Lago Club unless approved in writing by the Department Head. No employee shall accept any gift from any vendor. F. TO KNOW STATION. The Occupational Safety Hazard Administration requires all employees be provided with information of all potentially hazardous substances used in the course of our daily business. The location of these documents (Material Safety Data Sheets) is in the staff dining room on the wall adjoining the Food and Beverage office. G. EMPLOYEE ENTRANCE AND EXIT All employees required to log in and log out their daily time must enter and exit the building through the entrance on the east side of the house leading to Post One. MAR-A-LAGO 0237 Case 18-2868, Document 278, 08/09/2019, 2628230, Page292 of 648 TERMINATION PROCEDURE Clearance Process a. Clearance of locker. b. Return of uniform to Laundry. c. Nametag, locker key, any property keys, and uniform returned to Executive Office. d. Any outstanding accounts settled. NOTE: If you abandon your job without notice, your final paycheck will not be mailed until you have returned to the Club and completed the clearance process. MAR-A-LAGO 0238 Case 18-2868, Document 278, 08/09/2019, 2628230, Page293 of 648 IF YOU LEAVE EMPLOYMENT RESIGNATION POLICY When an employee decides to leave for any reason, his/her supervisor and the Human Resources Manager would like the opportunity to discuss the resignation before final action is taken. The Mar?a?Lago Club often finds during such a conversation that another alternative may be better. If, however, after full consideration the employee decides to leave, it is expected that the employee will provide the Club with a written two?week advance notice period (bear in mind that vacation days or personal days may not be included in the two? week notice period). Generally, in order to qualify for payment of earned unused vacation, the employee must work throughout the notice period. If, as sometimes hapens, the employee's supervisor believes it advisable for the employee to leave prior to the end of the employee's two?weeks notice, the employee may be paid for the remainder of that period. ~Note: You are not entitled to be paid for any unused, accrued sick time. DISMISSALS Every Mar-a?Lago employee has the status of meaning that no one has a contractual right, express or implied, to remain in The Mar?a?Lago Club?s employ. The Club may terminate an employee's employment, or an employee may terminate his/her employment, with or without cause, and with or without notice, at any time. No supervisor or other representative of the Club (except the owner) has the authority to enter into any agreement for employment for any specified period of time, or to make any agreement contrary to the above. IMMEDIATE DISMISSALS - MISCONDUCT Any employee whose conduct, actions or performance violates or conflicts with the Club's policies may be terminated immediately and without warning. The following are some examples of grounds for immediate dismissal of an employee: *Breach of trust or dishonesty *Conviction of a felony *Willful violation of an established policy or rule *Falsification of Club records *Gross negligence *Insubordination *Fighting or serious breach of acceptable behavior *Violation of the Alcohol or Drug Policy MAR-A-LAGO 0239 Case 18-2868, Document 278, 08/09/2019, 2628230, Page294 of 648 *Theft *Violation of the Club?s Conflict of Interest/Outside Employment Policy and/or Confidentiality Policy. This listing is not exhaustive. Should the employee be covered in our group health plan, all benefits will cease on the last day of the month in which the employee?s last day of employment falls. The employee will then have the option to continue coverage in accordance with COBRA regulations. In the event that the employee is asked to leave his/her employment with The Mar?a?Lago Club due to the above misconduct, the employee will not be entitled to any earned unused vacation benefits. Also, the employee will not be entitled to be paid for any unused accrued sick time. DISMISSALS - OTHER THAN IMMEDIATE TERMINATION All employees are expected to meet the Club?s standards of work performance. Work performance encompasses many factors, including attendance, punctuality, personal conduct, job proficiency and general compliance with the Club?s policies and procedures. If an employee does not meet these standards, the Club, may, under appropriate circumstances, take corrective action, up to and including dismissal. The intent of corrective action is to formally document problems while providing the employee with a reasonable time within which to improve performance. The process is designed to encourage development by providing employees with guidance in areas that need improvement such as poor work performance, attendance problems, personal conduct, general compliance with the Club?s policies and procedures and/or other disciplinary problems. Supervisors should use the procedure described below except in those cases which may require an employee's immediate termination. WRITTEN WARNINGS: The supervisor should discuss the problem and present a written warning to the employee. This should clearly identify the problem and outline a course of corrective action within a specific time frame. The employee should clearly understand both the corrective action and the consequence termination) if the problem is not corrected or recurs. The employee should acknowledge receipt of the warning and include any additional comments of their own before signing it. A record of the discussion and the employee? 5 comments should be placed in the employee? 3 personnel file. MAR-A-LAGO 0240 Case 18-2868, Document 278, 08/09/2019, 2628230, Page295 of 648 POST RESIGNATIONZTERMINATION PROCEDURES The Human Resources Manager is responsible for scheduling an exit interview with a terminating employee on the employee's last day of employment and for arranging the return of Club property including: Club issued credit card Club manuals Office keys Beeper Two-way radio Any additional club-owned or issued property In order to receive a disbursement of any amounts due from the Retirement Plan, the employee is required to complete and sign a distribution form which can be obtained from the Human Resources Manager. Specific information will be provided at the exit interview. Employees may choose the continuation of medical benefits under COBRA. Specific information will be provided by the Human Resources Manager at the exit interview. Benefits (Life and Medical) end on the last day of the month in which the employee?s last day of employment falls. An employee has the option to continue Medical Benefits in accordance with The Consolidated Omnibus Budget Reconciliation Act regulations. Employees leaving the Club must return office keys, club credit cards, etc., before their final paycheck can be issed. This final paycheck will be mailed during the next normal pay period. If there are unpaid obligations to the Club, the final paycheck will reflect the appropriate deductions. VACATION PAY Vacation pay is calculated in accordance with our vacation policy. If the employee took more vacation days than he/she was entitled to under the vacation policy, the time will be deducted from the employees final paycheck. RETIREMENT PLAN If an employee is in the retirement plan, information regarding this plan will be provided at the exit interview. MAR-A-LAGO 0241 Case 18-2868, Document 278, 08/09/2019, 2628230, Page296 of 648 EMPLOYEE HANDBOOK RECEIPT INSTRUCTIONS: PLEASE READ THIS PERSONNEL POLICIES AND PROCEDURES EMPLOYEE HANDBOOK CAREFULLY. IF YOU DO NOT UNDERSTAND ANY PORTION OF IT, ASK FOR AN EXPLANATION FROM THE CLUB OFFICE. RETURN THIS SIGNED RECEIPT TO THE CLUB OFFICE IMMEDIATELY AFTER YOU HAVE RECEIVED THIS MANUAL. PLEASE KEEP THE HANDBOOK FOR FUTURE REFERENCE. I received the Policy Manual of The Mar?A- Lago Club, L.C. on the date indicated below. I will carefully read the policies, procedures, and other information contained in the Manual and will ask the Club Manager's office for an explanation if I do not fully understand them. I agree as a condition of my employment to comply with the policies and procedures which exist now or which may come into existence in the future. I understand that if I do not comply with the policies and procedures, I may be subject to disciplinary action. I also understand that I or the Club may terminate employment at any time, for any reason. The Club reserves the right to modify or terminate any policies or procedures, in whole or in part, at any time, with or without notice. I understand that only the Managing Director is authorized to set policy or make any promises with respect to my employment. The language used in this Handbook is not intended to create, nor is it to be construed to constitute, a contract between the Club and any one or all of its employees. Date Employee's Name MAR-A-LAGO 0242 Case 18-2868, Document 278, 08/09/2019, 2628230, Page297 of 648 Employee's Signature 159816 MAR-A-LAGO 0243 Case 18-2868, Document 278, 08/09/2019, 2628230, Page298 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page299 of 648 Vicki Yawnick: Please run the following this Saturday October 14 and Sunday October 15: THE G0 CLUB Private Club in Palm Beach now seeking quali?ed individuals for the following seasonal positions: *Wait Staff *Asst. Food Server *Banquet Servers Sous Chef *Asst. Banquet Chef *Line Cooks *Pastry Cooks *Steward *Dishwashers *Housekeepers- llpm-3am *Houseperson ll pm-3am *Valet - must have a clean driving record. *Salon Asst. *Nail Technician *Make?Up Artist Part Time *License Massage Therapist-must have experience in wet treatments. *Esthetician *Spa Attendants - College students encourage to apply. Call Carol Ash, M-F, 9am-5pm, (561) 833-8767, ext. 313 or fax resume to (561) 832-2194. Drug/Smoke Free Workplace. EOE TING MAR-A-LAGO 0086 Case 18-2868, Document 278, 08/09/2019, 2628230, Page300 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page301 of 648 A. ..- . FIQIJIV .RE i A . vi? - 512COJE . l? -22 :Squk' - inn com: . I P'Hb'ru?u; . ?n?g?rf?gfiey EMPLOYMENT DESIRED Eogn. CN DATE you CAN sun DESIRED INQUIRE . I EMPLOYED VF No I OF YOUR PRESENT YHISTORY DID mu . ATTENDED SUBJECIS JUCJ. l) NAME Locmou or SCHOOL i I . GRAMMAR SCHOOL SCHOOL "92? CL i 3 D?v COLLEGE I . TRADE. BLSINESS OR . CORFIFSF SCHOOL I I I I 5 I GENERAL INFORMATION 5- 50F STUDY-RESEARCH WORK OR SPECIAL TRAN NC8.;wise-Luvs? MW, 33,5951; LL OJ 0.1:ng JS CR 3 NAVAL CE I FORMER EMPLOYERS LAST FOUR EMPLOVERS, STARTING WITH LAST ONE ig?bh?o?iyem NAME 6. ADDRESS OF EMPLOYER POSITION REASON FOR LEAVING I.-. .9 IS I [3800' 5-. . 2.. 7'?424.21.? _j f6 ?3 Manqgu 30?! Ia 33.4% 4.. . . {5ch Ix"? Ii. C. '3 COL/douv? I Rina: 0 (mi CAdams 9661 .1 MA APPLICATION FOR MPLOYMENT ?g AGRENMY Case 18-2868, Document 278, 08/09/2019, 2628230, Page302 of 648 0 REFERENCES GIVE BELOW THE NAMES THREE INOF RELATED TO YOU, WHOM YOU HAVE KNOWN AT LEAST ONE YEAR NAME i nooness $5353?? I . I, ?t A :11;an "dawn .2 92 2 a 7 juc?QMVt__3__ . . f" . . . - ?1 1"?f (Kai/\m' (x 3 1 . certify toe: the lacis certaned in this application are true and complete to the best of my knowledge and urderstand the: it employed, falsified statements on this application shall be grounds for dismissal. I authorize investigation of all statements contained herein and the reterences and employers listed above to g.ve you any and all intormation concerning my previous employment and any pertinent information they may have. personal or otherwise. and release the company from at: liability for any damage that may result from utilizatior of such inlormation. 5 also understand and agree that no representative of the company has any authority to enter into any agreement tor employment for any speci?ed period of time, or to make any agreement contrary to the forego- ing. unless it is in writing and signed by an authorized company representative Tnis waiver does not permit the release or use of disability-related or medical information in a manner pro- noted by the Americans with Disabilities Act (ADA) and other relevant (rm; and state laws." ave ?3 :1 SIGNATURE \A/?tywm ?3ng _w a) ,2 DATE DO NOT WRITE BELOW THIS LINE REMARKS .. 'ti'ei?? . 53amltlu - Eneime i Q-LAQKQ . 3X86 latte): to Chasm arr-caaiamcs i tamed. to #t?ch, Kim I I ME amass CHARACTER P?asGN/Emv - mail}? . 3. mes: ?Fon wosmon SALARY DEPT, REPORT WAGES APPROVED 1. 2 3. . mp. unmet]? new uENtmL MMIAGER l" axhtahO'l 'or e'nplOyme-i is sold only tor :owral?uae throughout the United States News assumes no and "crew (reclaims err; limit, lot the rchissor. u- this war at any cuatlan: or requests for manual-m upon much a Violation oi local state and/(x luderal 'aw may be based. it is the user's respmsibility to ersure that this tom's use carn- r; my amicable laws. which change from time to line. .-. .- Case 18-2868, Document 278, 08/09/2019, 2628230, Page303 of 648 Monday, November 7, 2016 I Page: 1 1Quicl 1? [9,4 annoy-r- mm. m: Emu: Oomphma.? 0 Olin. coda um id imam- bvo?ulim numb-r sun-0100200 CONFDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, PageBll of 648' Courtyard Animal Hospital 13860-31 Wellington Trace Wellington, Fl. 33414 (561] 784-7387 Ms. Roberts [jenna], It is obvious that you have a number of personal issues going on that need your immediate attention and keep you from being able to focus on and perform the material duties of your job here at Courtyard Animal Hospital. In the short time you have been employed here, you have missed?multiple clays. arrived late, called in sick multiple times. The reasoning you have given has shown that you are ?distracted" at minimum. Between your ?engine falling out of your car, your axle breaking off which your boyfriend 'repaired it roadside? and your landlord tossing all your furniture and clothing out in the front yard and setting it onfire", it is clear that you have more pressing issues in your life to focus on. You have been unable to perform to an acceptable standard within our company. It is because of your inability to perform your duties here, be in attendance when scheduled and focus on the job requirements that we are forced to terminate your employment. - . - r. Pinkwasser .. murrneooazn CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page312 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page313 of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 1 Time: 8:52:02 Offense Report Program: CMS301L Day Of Week . Sunday Report Date . 6/10/01 21:25 Occur From Date: 6/10/01 21:00 Occur To Date 6/10/01 21:05 Dept Class . . BURGLARY - Non?vehicle Street Number - - - City . . ROYAL PALM BEACH, FL 33411 Zone/division Zone One (1) (No of Okee) Location Type Case Status . EXCEPTIONALLY CLEARED Report Officer WOOD, FRANK Supervisory Emp: HUGHES, THOMAS 6/17/01 Case Status Dt 8/21/Case Number . 1-01?002214 Dept Class . . BURGLARY - Non-Vehicle Case Status . EXCEPTIONALLY CLEARED Case Status Dt 8/21/01 Investigator . KACZOR, K. Case Number . 1?01?002214 Dept Unit . . DETECTIVE Investigator . KACZOR, KENNETH Supervisor . . ROBKIN, ROBERT Assignment Date: 6/19/01 State Class . Burglary Non-Vehicle Committed Statute/Ordin Forced Entry Yes Premises Enter 1 Structure Occup: Unoccupied 2 State Class . Assault Simple Committed Statute/Ordin Weapon Type . Hands/Fists/Feet I A A I I Offense 001 Burglary - Non Vehicle - Name 001 (SUSP) UNKNOWN, Name 001 (VICT) AUSTRICH, JAMES M. Offense 002 Assault Simple Name 001 (SUSP) UNKNOWN, Name 001 (VICT) AUSTRICH, JAMES M. A I A I 1 Case Number . 1-01?002214 Prompt valid in: UNKNOWN, City . . ROYAL PALM BEACH, FL 33411 Home Phone No. 561/000?0000 Business Phone 561/000-0000 RaCe . . Unknown Sex . . . . . Unknown Ethnic Origin Hispanic Case Number . - 1-01?002214 Last Name . . PERKINS JR, JOHN MARTIN Street Number - - I City . . . . . ROYAL PALM BEACH, FL 33411 County . . . PALM BEACH Home Phone No. Business Phone Birth Date . . - Birth Country Unknown Oper Lic No. . FL United States Race . . . . . White Sex . . . . . Male CERTIFIED TO BE A TRUE COPY RICL Case 18-2868, Document 278, 08/09/2019, 2628230, Page314 Of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 2 T1me: 8:52:02 Offense Report Program: CMSBO1L 1-01-002214 (Continued) Ethnic Origin WHITE I I I A I 1 Case Number . 1?01-002214 Prompt valid in: AUSTRICH, JAMES MICHAEL Street Number - - - - City . . . . . ROYAL PALM BEACH, FL 33411 County . . . . PALM BEACH Home Phone No. Business Phone 561/000?0000 Birth Date . . Birth Country Unknown Oper Lic Unknown Race . . White Sex . . . . Male Ethnic Origin WHITE Victim Type . Adult I A I - 1 Case NUmber . 1-01-002214 Last Name . . ROBERTS, VIRGINIA Person Type . OTHER PERSON Street Number 368 BENT OAK DR City ROYAL PALM BEACH, FL 33411 County . PALM BEACH Home Phone No. Business Phone 561/714-5252 Birth Date . . l/ - I Birth Country Unknown Oper Lic Unknown Race . White Sex . . . Female Ethnic Origin WHITE Height . . . . 506 Weight . . . . 103 A A I 1 Original Report Reported By: WOOD, FRANK T. 6/10/01 Entered By.: JARRETT, DAWN M. 6/21/01 ON SUNDAY, JUNE 10, 2001 AT APPROXIMATELY 2124 HOURS, I RESPONDED TO - - - -, ROYAL PALM BEACH, FLORIDA IN REFERENCE TO A BATTERY COMPLAINT. UPON MY ARRIVAL I MET WITH THE VICTIM JAMES MICHAEL AUSTRICH. AUSTRICH STATED THAT HIS EX- FIANCE VIRGINIA ROBERTS, WHO ALSO RESIDES AT THE ABOVE LISTED ADDRESS BROUGHT HER FRIEND ANTHONY TO THE APARTMENT. AUSTRICH AND UNKNOWN SUSPECT ANTHONY GET ALONG. THE SUSPECT THEN BECAME VERBALLY ABUSIVE TO AUSTRICH. AUSTRICH THEN TOLD ANTHONY To LEAVE THE APARTMENT. ANTHONY THEN BECAME AGITATED AND AGAIN AUSTRICH TOLD HIM TO LEAVE. FRIEND JOHN PERKINS WAS PRESENT DURING THE ALTERCATION AND STATED IN A SWORN WRITTEN STATEMENT THAT HE ALSO TOLD ANTHONY TO LEAVE THE APARTMENT. PERKINS WAS IN FEAR THAT AUSTRICH AND ANTHONY WERE GOING TO FIGHT. ANTHONY FINALLY LEFT THE APARTMENT. AUSTRICH GOT THE APARTMENT DOOR CLOSED ANTHONY THEN REOPENED THE DOOR AND ENTERED THE APARTMENT WITHOUT PERMISSION, AND PUNCHED AUSTRICH ON THE LEFT SIDE OF HIS FACE WITH A CLOSED FIST CAUSING MINOR SWELLING AND A LARGE RED MARK. PERKINS THEN WENT TO THE TELEPHONE AND CALLED POLICE. ANTHONY OBSERVED PERKINS ON THE TELEPHONE AND FLED THE SCENE PRIOR TO MY ARRIVAL. AUSTRICH ALSO PROVIDED ME WITH A SWORN WRITTEN STATEMENT. I ASKED AUSTRICH IF HE NEEDED MEDICAL AUSTRICH VERBALLY STATED THAT HE DID NOT NEED ANY MEDICAL TREATMENT. CERTIFIED TO BE A TRUE COPY RIC L. BRADSHAW, SHERIFF Case 18-2868, Document 278, 08/09/2019, 2628230, Page315 of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 3 Time: 8:52:02 Offense Report Program: 1?01?002214 (Continued) N.A A I 2 SUPPLEMENT Reported By: WOOD, FRANK T. 6/16/01 Entered By.: JARRETT, DAWN M. 6/21/01 SINCE 6/10/01 NUMEROUS ATTEMPTS BY TELEPHONE AND IN PERSON HAVE BEEN MADE TO GET MORE SUSPECT INFORMATION. NOR JAMES AUSTRICH, JOHN PERKINS, AND OR VIRGINIA ROBERTS HAVE BEEN AT THE RESIDENCE OR ANSWERING MY TELEPHONE MESSAGES, AT THIS TIME I WISH CLASSIFY THIS CASE AS INACTIVE DUE TO SUSPECTS LACK OF COOPERATION. A A I 3 SUPPLEMENT Reported By: KAC ZOR KENNETH A. 8 /14. 0 1 Entered By.: KACZOR, KENNETH A. 8/14/01 Reviewed By: PERVENECKI DAVID A. 8 2 1/0 1 I have attempted contact with the victim numerous times and have been, unsuccessful. Messages left with roommates have been ignored and the victim has refused to call me regarding this case. This case is exceptionally cleared due to the victim's lack of cooperation. END OF REPORT CERTIFIED To NE A TRUE cow Nu: L. BRAKESHAW, SHERIFF Case 18-2868, Document 278, 08/09/2019, 2628230, Page316 of 648 EXHIBIT om Numw. P2198317 Of 648 oqueat tor Warrant Juvenile 4. Request for Contact Agency ORI Number Annoy Nome ?0502800 YALP DEP ENT 993046 crime was: as "my 1. Felony 3. Misdemeanor 5. Ordnance '3 2. Traffic Felony 4. Traf?c Misdemeanor Other ADMIN. ONY 0F MARIJUANA OVER 20 GRAMS WITH INTENT TO SELL Charge Dow $635 OF DRUG PARAPHERNALIA 0F CONTROLLED SUBSTANCE TATE 0 A Local Address (Street. Apt, Number) CHARGES DEF. VICTIM Bus neu Addrm (N amo. Street) IWOUB Tho Person taken into custody committed the below acts In my presence. we: observed by confessed to admitting to the below facts. Onthe 191? dayoi? NOVEMBER 19.93:: who told that holshe saw the armted person commit the below acts. we: found to have committed the below acts. matting from my (described) investigation. AM. 8 PM. (Speci?cally include facts constituting cause for arrest) THE ROYAL PALM BEACH POLICE DEPARTMENT WITH MUTUAL AID RTH POLICE DE PROBABLE A LARG A 00 MARIJU of the in my oilice wit ns, DEPUTY CLE swonu AND suaschaeo espoae ME NOTARY PUBLIC I OF COUEI OFFICER 11-19-99 DATE ADMINISTRATIVE 11-19-99 DATE DISTRIBUTION: WHITE - Court Copy GREEN Attorney Agency PINK Agency e318 of 648 mm, com 18 2% 08/09/2019, 2628230 ag SE AFFIDAVIT 1. Arr 3. Raquest for Waml I Juvenie 1.1 l- 1 1 I race? 1. i Mm Money Nam Agency Ropon umber Esto.s.o.2.a.0.o ROYALPALMBEACHPOUCEDEPARTMENT 3.5 Ill I, mum 1. Folony 3. mama-nor s. Ordhance . 2. Tram Felony 4. Tri?e Mlndornomor e, on?; Nam (Last. Fm. Midas Alias Raoo Sex :2 igueroa, Anthony 8 2 U) Chm. Duabtion Chap. . . Poss. marijuana over 20 gms. Poss. With intent to sell Charm Desorption . 01mm Poss. of Drug Paraphern aha Poss. of Controlled Substance (MDMA) warm Nun. (if. Middle) 80x WM StateOf lori a I 1 LoalMdruotSnd. Apt, Noam (City) We) (zip) Phano Am Sauce 5 auulnm Adm? (Name. Street) (City) (State) (up) Phone Occupation ??Tho undetalmod 00:1nt and two that helm has just and reasonable orounda to believe. ma docs bellow that the above named Dolmam the following violation of law. The Person taken ?custody committed the hem acts In my presence. was observed by who told confessed to that lie/she saw the arrested person commlt the below acts. admitting to the below facts. was found to have committed the below acts. resulting from my (deserted) investigation. om am, April 2000 xx 19 It AM. 8 PM. (Speci?cally Include facts constituting cause for arrest.) PROBABLE CAUSE On 04-13 -00, I received from Evidence Custodian Fanelii, one pill inside a purple pill case seized from the search warrant executed on 11-19-99 on Anthony Figueroa residence. The purpose of this was to test this one pill for the presence of MDMA, usin a heroin test kit. The pill tested positive for the presence of MDMA by turning the color black. It should be noted that on 11-19-1999, after Anthony Figueroa was read his Miranda rights, he was interviewed and admitted that the pill inside the purplecase was indeed ecstasy or MDMA. This pill has a "Batman" symbol imprinted on it. This pill was placed back into evidence. Based on this information, I believe probable cause now exists for the poss. of a controlled substance (MDMA). Note, all E, suspect marijuana seized tested positive for narcotic content. p. This amended probable cause was sent to Debra Colton for charge purposes. Nothing further. 6 i 0. arm or FLORIDA - FALM BEACH COUNTY ?lef?bv cedily that the loregoing ls_La_ . 1.. .. uuzwun .. law.? A "firstor? cull? wow-pm) m. V) DEPUTY fficer George Searing 101 04-1 7-2000 we or: OFFICER (PLEASE PRINT) FAG DATE 04-17-2000 5 DATE 1 1 1 AA UILLH- . Case 18-286i Document 2628230, Page319 of 648 IN THE CIRC COURT OF FIFTEENTH IUDQAL CIRCUIT IN AND FOR PALM BEACH COUNTY, ATE OF FLORIDA CRIMINAL DIVISION STATE OFFLORJDA OREGINAL (ID-H {Cb ISSUE WARRANT ,3 vs. 0233 5 tag - ANTHONY LUIS FIGUEROA, 32:53 .r - "<3:va . SO: I INFORMATION FOR: g3; E?Dgt- g3 l) POSSESSION OF SCHEDULE I SUBSTANCE gfi? a '5 i 2) POSSESSION OF MARIJUANA IN EXCESS OF 20 GRAMS ?13 3) POSSESSION OF PARAPHERNALIA (PRODUCTION) "gs; - 4) POSSESSION OF PARAPHERNALIA (USE) In the Name and by Authority of the State of Florida: BARRY E. KRISCHER, State Attorney for the Fifteenth Judicial Circuit, Palm Beach County, Florida, by and through his undersigned Assistant State Attorney, charges that ANTHONY LUIS FIGUEROA on or about November 19, 1999, in the County of Palm Beach and State of Florida, was unlawfully and knowingly in actual or constructive possession of a substance classi?ed within Schedule 1, Florida Statute 893,03 (4), commonly known as MDMA, a controlled substance, contrary to Florida Statute (3 DEG FEL) COUNT 2: Informant aforesaid, under oath, further information makes that ANTHONY LUIS FIGUEROA on or about November 19, 1999, in the County of Palm Beach and State of Florida, was unlawfully and knowingly in actual or constructive possession of more than 20 grams of a material, compound, mixture or preparation which contained cannabis, commonly known as marijuana, a controlled substance, contrary to Florida Statute (3 DEG FEL) COUNT 3: Informant aforesaid, under oath, further information makes that ANTHONY LUIS FIGUEROA on or about November 19, 1999, in the County of Palm Beach and State of Florida, was unlawfully and knowingly in actual or constructive possession of bags, and/or a pill box, and/or a box, which was drug paraphernalia being used, intended for use, or designed for use in planting, propogating, cultivating, growing, harvesting, manufacturing, compounding, converting, producing, processing, preparing, testing, analyzing, packaging, repackaging, storing, containing or concealing a controlled substance, contrary to Florida Statute (1 DEG MISD) COUNT 4: Informant aforesaid, under oath, further information makes that ANTHONY LUIS FIGUEROA on or about November 19, 1999, in the County of Palm Beach and State of Florida, was unlawfully and knowingly in actual or constructive possession of a pipe, and/or balloons, which was drug paraphernalia being used, intended for use, or designed for use in injecting, ingesting, inhaling, or otherwise introducing into the human body a controlled substance, contrary to Florida Statute 893. (l DEG MISD): DEBRA COLTUN FL. BAR NO. 0561622 Assistant State Attorney Palm Beach County, Florida SA 00CJ001567A02 GM 25 {In i . Case 278, 08/09/2019, 2628230, Page320 of 648 STATE OF FLORIDA COUNTY OF PALM BEACH Appeared before me, DEBRA COLTUN Assistant State Attorney for Palm Beach County, Florida, personally known to me, who, being ?rst duly sworn, says that the allegations as set forth in the foregoing information are based upon facts that have been sworn to as true, and which, if true, would constitute the offense therein charged, that this prosecution is instituted in good faith, and certi?es that testimony under oath has been received from the material witness or witnesses fort se. Assistant State Attorney Sworn to and subscribed to before me this 2: day of 2000. ?ash- I?m, my NOTARY PUBLIC, State of Florida Citation Nos. (if applicable) 33:! ?I?ll-Ir" Puha?imil Engliaiti ii I, p?ts coasts. April. ?95 2W1 2:3" . I . STATE 0F FLORIDA - PALM BEACH COUNTY I hereby certify that the foregoing the record in my oiitcs wi Keith A: i its, i@ as Etu' .u by i . M, was smit- .2 I. it BF DEPUTY CLERK SA 226 Case 18-2868 Document 278, 08/09/2019, 2628230, Page32l of 648 . IN THE COURT or THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH FLORIDA SENTENCE (Probation ommunity Control Violator] (As to Count(s) I Defendant A Case Number GETS Number I ??l?in WWI woo Within; Victim I . 3L COUNTY EGUHTS 1?11th Ffing personally baf?e this Court, accompanied by the of record, 9r IArIl/l I and having been adjudicated guilty herein, and the Court having given the Defendant an opportunity to be heard and to offer matters in mitigation of sentence, show cause why defendant should not be sentenced as provided by law, and no cause being sh the Court having placed the Defendant on probation/ community control and havin revoked the Defendant?s probation/ community control for violation[s) of condition(s] and to own, and subsequently IT IS THE SENTENCE OF THE COURT that: The Defendant pay a ?ne of pursuant to Fla. Stat, plus :3 as the 5% surcharge (of the ?ne impose required by RS. 960?25, which shall be deposited in the Crimes Compensation Trust Fund, . The Defendant is hereby committed to the custody of the Department of Corrections Sheriff of Palm Beach County, Florida for a term of . further ordered that the Defendant shall be allowed a total of 2 days as credit for time incar rated prior to imposition of this sentence. It is further ordered that the composite term of all sentences imposed for the counts specified in the order shall run consecutive to [y concurrent with [check one] the following: Any active sente ce being served. - Specific sentences: [n the event the above sentence is to the Department of Corrections, the Sheriff of PalrnBeach County, Florida is hereby ordered and directed to deliver the Defendant to the Department of Corrections together with a copy of the Judgment and Sentence, and any other documents Specified by Florida Statue. The defendant in open court was advised of right to appeal from this Sentence by filing notice of appeal within thirty days from this date with the Clerk of the Court, and the Defendant's right to the assistance of counsel in taking said aptly emissLofatbre have upon showing of indigency. Inamoy certify that the tores?ilja is}; ?0 DONE AND if? . amuoyeaggiu pWalm ach County, Florida this .. .. 3 iions-ARON a. so (rev. 12/98) A CIRCUIT couar JUDGE 7 DEPUTY CLERK EDWARD A. GAHHISON CaSe 18-286 ocument 278, 08/09/2019, 2628230 Page322 of 648 IN THE CIRCUIT COURT ISTII JUDICIAL CIRCUIT OF FLORIDA, IN BEACH COUNTY use 3 7 CF 401, V0 09~455611 62 DOROTHY ll. HILKEN 9 984 CLERK PB FL millennial-lanai. STATE OF FLORIDA 1 COMMUNITY CONTROL VIOLATOR V. . PROBATION VIOLATOR EFEND I LE The above represented by I. APD (attorney) CIRCUIT 8; COUMTY COURTS I Having been tried and found guilty of the following crime?): Having entered a plea of guilty to the Having entered a plea of nolo following crime(s): eontendere to the following crime(s): COUNT CRIME or ENSE STATUTE NUMBERISJ DEGREE CASE oars 3 NUMBER NUMBER . L201) I and no muse having been shown why the Defendant should not be adjudicated guilty, 1T IS ORDERED THAT the Defendant is hereby ADJUDICATED GUILTY of the above erime(s). and having been convicted or found guilty of. or having entered aplea of nolo contendere or guilty, regardless of adjudication, to attempts or offenses relating to sexual battery (ch. 794), lewd and lascivious conduct (ch. 800). or murder (3. 782.04). aggravated battery (5. 784.045), carjacking 812.133), or home invasion robbery 812.135). or any other offense speci?ed inrsection 943.325, the defendant shall be required to submit blood specimens. [1 and good cause being shown: TT IS ORDERED THAT ADJUDICATION OF GUILT BE SENTENCE. . STAYED The Court hereby stays and withholds imposition of sentence as to countts) and places the Defendant on Probation and/or I 1 Community Control under the supervision of the Dept. of Corrections (conditions of probation set forth in separate order). SENTENCE DEFERRED The Court hereby defers imposition of sentence until The Defendmt in Open Court we advised of his right to appeal from the Judgment by ?ling notice of appeal with the Clerk of Court within thirty days . following the date sentence is imposed or probation is ordered pursuant to this adjudication. The defendant was also advised of his right to the assistance of counsel in taking said appeal at the expense of the State upon showing of indigency. DONE ANR Beach County, Florida this 2" day of Q12 ex: #10, 0/ I hereby celilly that the foregoing true py of the record in my of?ce with k. .. g: Ia tionsCIRCUIT COURT r3 C?Jr?pl CL a-I DEPUTY CLERK EDWARD A. Case 18-2868, Document 278, 08/09/2019, 2628230, Page323 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, Page324 of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 1 Time: 8:51:59 Offense Report Program: CMS301L Day Of Week . 2 Friday Report Date . 8/03/01 23:43 Occur From Date: 8/03/01 20:00 Occur To Date 8/03/01 23:42 Dept: Class . . Street Number HIDDEN HARBOR, - - - City . . ROYAL PALM BEACH, FL 33411 Zone/division Zone Two (2) (So of Okee/E Wil) Location Type Case Status . OPEN NOT ACTIVE Report Officer LLEWELLYN, CRAIG Supervisory Emp: MURPHY, THOMAS 8/06/01 Case Status Dt 8/03/Case Number . 1?01?003008 Dept Class . . Case Status . OPEN NOT ACTIVE Case Status Dt 8/03/01 State Class . Larceny From Building Committed Statute/Ordin I A I Category . . . STOLEN UCR Prop Type CURRENCY, NOTE, ETC. Quantity . . . 5 Description . US CURRENCY Value . . . . 500.00 Property type A I A I 1 Case Number . 1-01?003008 Prompt valid in: UNKNOWN, City . . . ROYAL PALM BEACH, FL 33411 Home Phone No. 561/000?0000 Business Phone 561/000?0000 Race . . Unknown Sex . . . . . Unknown Ethnic Origin Hispanic I I I A I 1 Case Number . 1-01-003008 Prompt valid in: ROBERTS, VIRGINIA Street Number - - I City . . . . . ROYAL PALM BEACH, FL 33411 County . . PALM BEACH Business Phone 561/714-5252 Birth Country Unknown Race . . . White Ethnic Origin WHITE . . . . . Weight . . . . 103 Victim Type . Juvenile I A I - 1 Case Number . 1-01-003008 Last Name . . FIGUEROA, ANTHONY Person Type . OTHER PERSON Street Number - - City . . . . . ROYAL PALM BEACH, FL 33411 County . . . PALM BEACH - - Business Phone 561/000-0000 - . Birth Country Unknown Oper Lic Unknown Race . . . White Sex . . . . 1 Male Ethnic Origin WHITE Juvenile . . . ADULT I A I - 2 Case Number . 1?01?003008 Last Name . . SWITZER, KYLE CERTIFIED TOBEATRUECOPY RIC L. BRADSHAW. SHERIFF Case 18-2868, Document 278, 08/09/2019, 2628230, Page325 of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 2 Time: 8:51:59 Offense Report Program: CMS301L 1?01?003008 (Continued) Person Type . OTHER PERSON Street Number - - City . . . . . ROYAL PALM BEACH, FL 33411 County . . . . PALM BEACH - - - Birth Date . . - Birth Country Unknown Oper Lic No. . FL United States Race . . White Sex . . . . . Male Ethnic Origin WHITE I A I - 3 Case Number . 1?01-003008 Last Name . . RIGEL, DUSTIN Person Type . OTHER PERSON Street Number - - - City . . . . . LOXAHATCHEE, FL 33470 County . . . PALM BEACH - -. Business Phone 561/000-0000 Birth Country Unknown Oper L1c Unknown Race . . . White Sex . . . . . Male Ethnic Origin WHITE I A I - 4 Case Number 1?01-003008 Last Name JEFFERSON CRAIG Person Type . Street Number City County Business Phone Birth Country Race Ethnic Origin I A I - 5 Case Number 1?01?003008 Last Name URVIS SCOTT Person Type Street Number City County . . Business Phone Birth Country Race . Ethnic Origin I A I - 6 Case Number . 1-01-003008 Last Name . . RISDEN, RICHARD ARTHUR Person Type . OTHER PERSON Street Number - - - City . . . . . ROYAL PALM BEACH, FL 33411 County . . . PALM BEACH Home Phone No. Business Phone 561/000?0000 Birth Date . . I I'll l' Birth Country Unknown Oper Lic No. . FL United States Race . . . . . White Sex . . . . . Male . CERTIFIED RIC L: BRADSHAW, SHERIFF Case 18-2868, Document 278, 08/09/2019, 2628230, Page326 Of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 3 Time: 8:51:59 Offense Report Program: 1~01-003008 (Continued) Ethnic Origin WHITE Height . . . . 511 Weight . . . . 160 - A A I Original Report Reported By: LLEWELLYN, CRAIG R. 3/03/01 Entered By.: JARRETT, DAWN M. 8/16/01 ON 080301 AT 2343 HOURS I WAS DISPATCHED TO - IN REFERENCE TO A SUSPICIOUS INCIDENT. UPON ARRIVAL I MADE CONTACT WITH VIRGINIA ROBERTS AND ANTHONY FIGUEROA THE RESIDENTS OF - - -. V. ROBERTS STATED THAT EARLIER IN THE EVENING SHE HAD SEVERAL PEOPLE VISITING HER AND A. FIGUEORA. ROBERTS STATED THAT WHILE THE PEOPLE WHERE IN HER APARTMENT, ONE OF THEM WENT INTO HER BEDROOM AND REMOVED $500.00 CASH FROM HER WALLET. v. ROBERTS STATED THAT SHE DOES NOT KNOW WHICH OF HER VISITORS TOOK THE MONEY. A. FIGUEROA STATED THAT V. ROBERTS WALLET WAS LOCATED IN A POCKET OF A SHIRT WHICH WAS INSIDE THE CLOSET OF THE MASTER BEDROOM. A. FIGUEROA STATED THAT HE SPOKE TO ALL OF THE VISITORS ABOUT THE MISSINGMONEY, AND THAT NO ONE ADMITTED To TAKING IT. v. ROBERTS AND A. FIGUEROA STATED THAT SEVERAL OF THE VISITORS HAD ALREADY LEFT PRIOR TO MY ARRIVAL, AND THAT THEY COULD NOT PROVIDE NAME OR CONTACT INFORMATION FOR THOSE THAT ALREADY LEFT. I THEN MADE CONTACT WITH THE REMAINING VISITORS RICHARD RISDEN, SCOTT ORVIS, CRAIG JEFFERSON, DUSTIN RIGEL, AND KYLE SWITZER, A RESIDENT OF - - -. ALL INDIVIDUALS STATED THAT THEY WERE NOT RESPONSIBLE FOR TAKING THE MONEY NOR DID ANY OF THEM KNOW WHO TOOK IT. I TOOK THE NECESSARY INFORMATION FROM V. ROBERTS AND A. FIGUEROA AND PROVIDED ME WITH A RIGHTS SHEET THAT CONTAINED A CASE NUMBER. NO FURTHER SUSPECT INFORMATION AT TIME OF REPORT. END OF REPORT i TO A TRUE COPY RIC BRADSHAW, SHERIFF Case 18-2868, Document 278, 08/09/2019, 2628230, Page327 of 648 EXHIBIT AA OQS - 278, 08/09/2019, 2628230, Page328 of 648 Page PAGE 1 CASE NO. 02075321 0 CASE NO. 02075321 DISPOSITION: ZULU DIVISION: ROAD PATROL CIVIL MATTER SIGNAL CODE: 66 CRIME CODE: NON CRIME CODE: CC CODE: 9566 06/02/02 SUNDAY ZONE: A81 GRID: 3C2l DEPUTY I.D.: 6933 NAME: WIKSE JOHN ASSIST: TIME 2148 A 2159 2249 OCCURRED BETWEEN DATE: 06/02/02 2148 HOURS AND DATE: 0000 HOURS EXCEPTION TYPE: INCIDENT LOCATION: 13475 24 CT APT. no.2 CITY: LOXAHATCHEE STATE: FL ZIP: 33470 NO. OFFENSES: 00 NO. OFFENDERS: 00 NO. VEHICLES STOLEN: 0 N0. PREMISES ENTERED: 0 LOCATION: NO. VICTIMS: 00 NO. ARRESTED: FORCED ENTRY: 0 NAME LIST: ROLE: OTHER PHILLIP RATCLIFFE OTHER VIRGINIA ROBERTS SEX: RACE: HT: 504 WT: 108 HR RESIDENTIAL ADDRESS: 155 SANTIAGO ST BUSINESS PHONE: 561 000-0000 :s ON JUNE 2, 2002 AT 2148 HOURS, I WAS DISPATCHED TO 13475 24TH COURT, NORTH, LOXAHATCHEE, FLORIDA IN REFERENCE TO A REPORT OF A CIVIL DISPUTE. UPON ARRIVAL, I MET WITH WHITE FEMALE, VIRGINIA L. ROBERTS, DATE OF BIRTH AND WHITE MALE, ANTHONY L. FIGUEROA, DATE OF BIRTH -, WHO WERE STANDING AT THE END OF THE DRIVEWAY ACCESS TO THE PROPERTY. THERE WAS A PILE OF PERSONAL EFFECTS (I.E. A LAMP, CLOTHING AND OTHER CERTIFIED ?r?E A TRUE COPY I SHERIFF 4/22/2016 OQS - W??r?alnt 278, 08/09/2019, 2628230, Page329 of 648 Page 2 of 2 PALM BEACH COUNTY OFFICE PAGE 2 CASE NO. 02075321 OFFENSE REPORT CASE NO. 02075321 DISPOSITION: ZULU MISCELLANEOUS ITEMS) NEXT TO THEM. VIRGINIA EXPLAINED THAT THEY HAD BEEN LIVING AT THE RESIDENCE FOR APPRO- FOUR MONTHS AND THAT HAD MADE AN AGREEMENT WITH THE LANDLORD To VACANT THE PROPERTY As OF 060102. SHE CONCLUDED BY STATING THEY HAD TRANS- PORTED ONE LOADED OF THEIR BELONGINGS AND HAD RETURNED FOR THE REMAINING ITEMS WHEN THEY FOUND THEM AT THE END OF THE DRIVEWAY IN DAMAGE CONDITION. ADDITIONALLI, HAD LEFT A MATTRESS THAT WAS NOW BURNING ON THE PROPERTI. I WENT OUT TO THE PROPERTY AND MADE CONTACT WITH THE LANDLORD, A WHITE MALE, PHILLIP E. RADCLIFFE, DATE OF PHILLIP STATED THAT PRIOR TO LEAVING, ANTHONY AND VIRGINIA MADE STATEMENTS SUCH AS CAN KEEP THE REST IOU THIS STATEMENT AS WELL As OTHERS WERE WITNESS BY WHITE FEMALE, LORRI M. DESPAQUA, DATE OF BIRTH -. PHILLIP STATED THAT THERE WAS A SUBSTANTIAL AMOUNT OF TIME SINCE THEIR DEPARTURE FRCM PHILLIP. HE FELT THAT THEY HAD DISCARDED THE ITEMS SO HE PLACED THEM OUT FOR TRASH PICKUP. HE ALSO STATED THAT THE MATTRESS WAS COVERED IN CAT URINE SO HE BURNED IT FOR SANITARY PURPOSES. ALL PARTIES WERE ADVISED THAT AN INFORMATION REPORT WILL BE COMPLETED IN REGARD TO THE INCIDENT AND EXPLANATION OF CIVIL REMEDIES WERE GIVEN. IT SHOULD NE NOTED THAT VIRGINIA PRIOR To LEAVING ADVISED ME THAT SHE WOULD PROVIDE ME WITH A LIST OF DAMAGE RUIN ITEMS AS SOON AS POSSIBLE. J. DICT: 060302/1418 HRS. CERTIFIED TO BE A TRUE COPY L. BRADSHAW, SHERIFF 3 4/22/2016 Case 18-2868, Document 278, 08/09/2019, 2628230, Page330 of 648 EXHIBIT BB Case 18-2868, Document 278, 08/09/2019, 2628230, Page331 of 648 I Anoran Make Auuan Palm- 0! neparturo 5 Arrival Mlle: Fll?u nan-nun, Proms, Number Alrcr-n 19% and Mark Flam No Maneuvers. Endmomonu ol From To \1 M09311 51m. 77? :31Te") pg; v.3, 78? \f?jvww 19 PSI "(613 ?z?mmWW? 1a 1 166 .6 133 Jae/savory Iiumw, 3 MM) 2" 3.98)? 794 Wu;- 3 e? Jig 3-4., ,?158as; 81m? . A 1?ma?a/4 - I TIM ,3 5 mi!? DR - 001?? 7., 7? SM L074 01% 37?1? . - "m 25;: 3&5 re; 7463" 2, A ml I QM T655 31. I Tee Pm: ?mj? Icem?y Lnal he mace hy the on INA form are true, Page Tom! Cg Amount Forwaxd Ifsgi'gnsa'? - Pilm?s $63!"!th QM W41 Tobi ?oo??moomAJeo :8 Case 18-2868, Document 278, 08/09/2019, 2628230, Page332 of 648 Alter-? I I Number mm.- Points 9! Depamre 8. Arrival Was ?Uh! Remarks. Weed-"5' cl - 1 19 (a and Model manmmnonmm Ng. Manuwm.E-domemon From 0 c: I 3 I TNQA ?agigg NCM 803 Jl/ 1? (761:? .. Rey/ova) - - a an Aww?am TCB [3 Pgw??gwr?) mam I . 3 M1 3?15. .I - - 807 m3 Egg ?227?? T579 '86]!an 9105a! 62,?951 fg?g? 8n I own/aw TEE P51: mifyz?m' PISexs?a?wwm?S?W{597(1on cunmmu 17m: (jg-LU" I I I I nntcI . 2? I 3-183 ?Ianwdm-NI I I m?In?'V?l?k?NprJU . I I ceni'y that the mtommts rr'eds by me an 1h: for-n am we. tag? g3 PI'ot's Signaurel >?g??kr?OA?V -oe0cp Anounl Forward U001 Total to OIIO 96 Q'Lgk Case 18-2868, Document 278, 08/09/2019, 2628230, Page333 of 648 More? Make Allum?! I Henlibmucn Mam .Irsz Flight Remarks. Procedures. Points 0! Dara-"m l. Anlvul Maneuvers, Endorsements . Numbe? OI 1 Alicrall Ewing'? ?559 <10?)ng . 1 4? \M/awjamm (r 1 4.22.9305?) 319M 3. saucy), 2-3219 LL CQ?ijnu c. 36, Hanan so mi? ems? ff, Somol??b?c WMELA :mwb/v- 0% J?l Framed? sown MN 09+ 32, aminwm?? ?5:742:? 31?, n, MIMI: If) Kama ??omt Warrant? Kunm- q0/07/95, I 65an 39mm Mme mm! sonny lha! ma statamwls mode me an lo'm are two. $28282-.. Case 18-2868, Document 278, 08/09/2019, 2628230, Page334 of 648 will: i Anord? Mak? Aircraft Points 0! Departure I. ArrivaI Miles F?yh! Renurkn, Proceduras. Numbe: Aircrm I ?9 and Model Idenlilimuon Marv 5mm Nu ?name's. I non-rm@2pr. . ,5 set Eu L. 7:0 Glls?? Nqo?c??t: T68 98f 8173922w mews, 3/2 29282192222225 Tar TCG Bgt. 6365;, 7 if 2 7. ISPN SW macaw?, (3 3F quje {596 we 293, ECGM i. ?ovm ?u :86 L?p 7 1'7: 1C6 . 80?, 33 (7 PMVY T66 - 863 'WELL 2_ $591 9" ib/ 96124;,- Tc? a; GM . I Tea FBI ea: 34', Get/tr?: DR: _000094 5 ?1 "-42:361? SPN 095 wgsoemw l/l I 2~ ?Sm Tc. 'wn woes i I m, .2 166 9,313,024 rem? 13% 814 3616!? '1 3 - 1&8 I 87536le a 1 Kiwi": K7l (J2 ,2 I TM like: .va that ho slatgmenta made by ma an a term 8'0 l?ua. Page Total f. Amount Funk'mi 2:75,? (>102. l?lml?a Slg?nluw_ a? jab) '%is 4 In Date $95 (3qu 5f 1 (4 Case 18-2868, Document 278, 08/09/2019, 2628230, Page335 of 648 A 1 ,ooPr I Numm' Alrerall a class . . duro . qu Nrcm?Make Aman Poi"! Heep armtAnlval Mlle: Wulga 2 A - Illneu Ve?f? {Mp0 "flat.? ldur IUHIR In] ?.16 IV N3 (4p own/'9? $011316, N?Iogj? mw_ 232622 ?11m EM V5 ?13 A \iL??Ow?lv 1?me _2 1 _2 (131 - FFWW 1 1 22_ 22 2 2. 1939i: 3 222 1 1?7, 31L {-19% Te??22p2 3:22 2 171? 21' '1 11 ?16.9 ?383 2108. 1 -2 %x.1w~ww? 1 1 222131.11 cm?. :11? :2 ?r??ww 1' 8? Sar??DeQSHowtu?z, 7 1212211313 22 2.. 8 7T- ,1 . (.503 166 10 ?10 16.0 I - I. 2- N0 Mc?OLe-Grmf - _49?g?j56 :37: 37:: 25? \1 Tee; 861333.64? - . 111135 4 723' 0CD 8 2:122 as??f 11 W15 3 11 281,1 2 12 1 {?10110a anorwmd ?/g??an?hr 2 1 - Eei;;u1 ?Ilnl'u Sgrau'a 2 3 Case 18-2868, Document 278, 08/09/2019, 2628230, Page336 of 648 Dame Alrcm ft Ig?f mdl?mdel Ida tti?ca Mann rk .cProcdurIa. Manveeu Ime I 8% 1% I. CMH ?9le -Eee? ?(Inc GM 1&4 __Iro235 BT Il?fs ?103ij I ??730; mu; 19%. xI in?ll 118}: 3c", pmjmeeimqa I lC? .qo?ll 36', I .. FunowlN In ts omapanma Arrival ?IMeslI -I 15/ 4 I 'P?l [610614 3616M SMNM PPYL I 566 ?lqlo?fgLad-Gawa? LL94 4r) 4 0C9 TEE cum M?soLl?llsf/zfg?sam ??igj?Hb ,Gm, more?: wwoom: . 4 Ag?. I 3:6: I "e (9M, .3 CFC I Wex?t - I: P?f_ 24:569912'; (Z- m?2115204I417 with, 326a scam-ML,? a I ?My: Mun saI ?moms Sam @9an 0mm; form on I 05221106 P?g'g Say I (m A81 I 6261?? Vac (>105 _gun I I -743 E3 Case 18-2868, Document 278, 08/09/2019, 2628230, Page337 of 648 Points of Departure 8- Milo: I Bavaria. Procedures, Dale Mam Alma? ?mum", Endw'manu and Mom-l Idmd?callnn Mark Fluwr Na I Number Aircraft NOV From lo 15? Cm? CLMV, - fig? 16:3- ?m CW (if? wuss [536.) 4T- [?23 yea ?n1nu?wm?7 an" 0 mg, om? yam) ?La-mews 01"? Big 11+- 32:, r13? 17:, em \4 I 47? nuw 6950?:an 1 $3832 9mm? - -. . 11. woraz c.0100 {Jo/At.- I pgpyen. cezhumeg 3?6 cm, un?t, ummr Mwmow, u?nu 12: 3mm! mm;- wah' i 1 I 16,0 10:4] ny?pu? CM Wham C: Crag)?, m" r" 1 ovum ouwv bin.) 9 31-; I 3?1 3p) ?zoym. alluding: h?ml?? I, 51211.5. - 2 ?ll yo-u-pu-Duml?, 656..: U\/vv' T, I a - ,L?f?b?ft; wum?izg. . ((270 0074-31-55ng I (4:14:10 . law". I Nu. - 4 ?57557,:an I Page Iota! I (mount Fomar? You! In Data 3 Case 18-2868, Document 278, 08/09/2019, 2628230, Page338 of 648 Dally Almah Make unc M009: Nrcm?t Points 0! Departure 8. Arrival Males Film Remarks, Pmnoduns. mm. ?mm" m? . Idenll?cnnm Mark M3. Maneuvers, Endorsements - ?r I 011121er - ?lx 91119 (10.33;; Pr}: 1' "Inf 2, ,1 1L1 I T56 13% Begum! u. 11/ ?nu-Ll 171? 2?9] (301?; -. pun-?1 nmn?i?? A VI 3 I QUIr?IE-mwoubcv 1/1 - out?RM? Marta?0;: (MI cwwamyg 117:1 Mfr/33It, at. ~5ny Ma, 90:13; A u? MN 00;?va I ,Eitm?glhg {?91 . . 2. . 1?43 E?nuf- (Q7131 a N0 00356949515 51%? 4 ?a UM Hum- ?bgL?kfgu?JhEz/?R??uwm? 110,90, 4. ICC.) ff}, I: Jig, Anion ?marl A u. :56? - A NNFI . 1 - IL.- A 312:?, 1 pr); .1: I ?6 I m. whim, .:va A 6-6 Sup-1". Ln g. . ,4 (3T {50? - 2 .. 31553?; qu SayerMmePM: QSH MinaCg? Nr??Ig?jcx S'T?ue?l? . I I 08me that Ibo made by mo nn lu'm are 1.11? Pace Total 10Annunl Forward 536.3%? ?10% A Wat's Siamtue UL Tobi to Oak (akinf?JNd I 52262,? Case 18-2868, Document 278, 08/09/2019, 2628230, Page339 of 648 . Murat! Mm: Am: all Mono and Mad? E?S?c?x 7 MM From Points ol Deparluvo 8: Arrival Mites Fight No. Remarks. Procedures, Marrow-n. inanim- Nunbor LH'lurgs chra? m? LM - (In-3?10 15 l\ Nw?quwc psp__ 060 Tel-qt?fa, Mmeulxmx? \5 8 ?98 iQ/zpct-mmw (rut Qua/raw Ate, Cetqum 1" bl @1019 WL 2% aw f4 )Gm 50?- an? :76, GM, OLD Slat d1 inommec ft.- CJI i Cm w- (1&2 Dc. .3 6/ (87/00:? Mmm. . ITLI-B MA 5136/", -l - FZL Nm; +Ff- mm; Hg; DC [Darval (0 L01 ac; 23? immv. gr; (66 i? . ,tm, {it?mauoa', G-w type] 56:, Gucci? q/ 2 Lu 9. ?90; .1: GM, 1L T69 %q -BCO ICE?ecw 3e Cur. awmr bumf?uta?? ?gk??gss?? m! u; 51,09 . mm;? ,3?bim?xn.?, I 1 l/l A4 l/n 3c; .SG, 506,99?? 04 CH L+3e) WI cem?fy hell the ?alumina mudu by on form are true. Page 1'4qu ?1ch Forwsvu Total to am swung), am I . save-1 5? rm?hr~mswn& No (98 15 marl! Case 18-2868, Document 278, 08/09/2019, 2628230, Page340 of 648 Number I Alta-n Mules Remark, Honduras, I Maku N'Cnl? Points 0! Dopartun Arrival 01 . 2 i 1561:} and Mncol Mam Flown. ho. Mmoum, Endorsam-nu . SC, 31 M97 l'lb Hiram C?nsjl?i N0108y?; - A LLff? (-jlj: - (Hi?Te, GM (a ?4 A- T636 L175 69" CL (?1:39 2 I 12-? 380 1/1 23813858?? MOLE ?22 - -7 ?xg. 56? new Cm ?asw??gaia??i? J: - . try-Jud - [Kn (4m 22 new 8833a?ws?fod To 2 . "J'Ecz: [m WMch-mm 7A Jen PBI qes u?umhg-Ip?: CNN TMQJ) 48L ?14 93 . - PE) 0?81 5g, gm, pmrefz Iii-V151 - Tie?rs MV \f 3'5) . 2421112.. i ?23" -2 cm Te (5 (4611': 521 Tea 9:3 1? I $143 Mom Em stalemerls armrue. Fum??oml Iii? Li Amnunl meam . E) Qg?zt Tot-Ho Dale Slomiure K) 1" 3R 2 91.31739] 1? . all? Case 18-2868, Document 278, 08/09/2019, 2628230, Page341 of 648 191', . JUL Ararat! Man. and Mu'lnl AI royal! Vdunt?mlv In Malk . I Palm: 0! Departure .- An?lval T. 1 Han Mibs Fright No Remarks. Maceduns, Munnwon, Eudora-Inca" Lansing: Mmbor I Amt {11m \o N?wil??j 6?61: Tera ?i?N em, mum L/x, .CMH 2.1- 'E??f339 qq 010L641 be'i . :36, mum pm at. ?Oec. \ll SLnumwxg I SK?t?r? V30, '5va Lime-rum?. rumwgc?cm g3 was VI \1 D?nznd 2332mm ?ja Nam-x) ?mm-v.06 H?fmbv Mus qugaww wuo??m?. 1: 2441\6 \vL qugirm Zore- sat: . Tan: *mem'Nqbisze? RBI J96 \ol3 (2, GM 3e, Ham gen, Maw? my} 2,0 "[93 36;, cnmerz Mia/Ur) TE 6 32;, cemwn?mw' e09, cumEma/(10M, phy?e: tr": man. uan 25' FOK cemab ?0 (10155 to i/vwv .4 1 min saleawo MVJC FM 1' MVY Pr}: 1011: Myoct?mf loamy hat 1hr: summons made by me on U13 loan are his WQ )m?k WW Page Tola? 3?1 Anwuw Fume-HI Total to Date ?10022 \n 001 Case 18-2868, Document 278, 08/09/2019, 2628230, Page342 of 648 Dale Make Alva" I Points 0! Donahue 3. Arrival Miles Fright Remarks. Procedures. Number Alfall? 1&7 and Mode! ld?nlmcalion Mart FW No. Endo'uments OI 66? .Fm. To 1.9mm 5a \022 1914 "reg Lobe V, i 24* ?x 6 LGMN m9 ?mc?m? 1:11:38? LFMN EGGW 216:1 I GE): '\ul?1 3-6er 1 P?f ., T66 ?30 Igor? T66 m9 ?231,38! H/l - am (am @2138 CONFIDI mar 39? 3 ,8 9? 33$? 3 . . V?l? ms 375/ 1 . - 8063 SHV . g0?85!? 'Lvn- 2m ?5 ?4 7; 5L 646%: 1086836 PEST. 33L Wi?e?r?p?bgmw 9. 4) ?1 I 301 JTIAL E) 291122 NI (N rl?T-A?n $153319certify that me slalmnwufs nude by me on (Na 10m aw hue. Pam Tolal . 50 Amounl Forward %1 003 Pulct?s Signame QGUM To?. '0 Iii?? 1? 74 I t, Case 18-2868, Document 278, 08/09/2019, 2628230, Page343 of 648 Alraa? Make Aircraft Palm: 0! Departure 8. Arrival Miles Fligm lam-rim, Procodureg Numbor Alrcn? . an 19 and Nudui A Flawn No. Maneuvers, madame-ont- ovum-my me To m: WW9- A I . L0 (Z. \flJ Gtusqa T68 \m 5% (?158 509? :1 .477lee, (56.5.an I 39: 5 1+ \1 36? \ms 55"; GM. CT, I Gamma . ?8 "?5'r- ?a owl 6? 8. I .1). <51 - 33X F?viesT?E A 1 i 3M FBI ??973 Q?Lvu mm L?R?YV1sosxs_ (3038 ?was sex? More \cs?f? 5* 3 xx (>641: T66 . \osz 2: 2.2., 4881? . 2 (>61 8 Tee? 6" 8T ,1 pg; \054/?23 (cu 008pcomfy that ma statements made hv ma an this {am nrotnza. Page Total ?39, L1 Alncull Forward I 7 05(1? sch; PINS Signal-ma Tau! to Data 1? 19 as i Case 18-2868, Document 278, 08/09/2019, 2628230, Page344 of 648 %1 pg; Nm?m Nmrn? Idanl?kzailm Mark Points 0! 0mm": A Anival From Flluhl No. . nu\ mam: 1! Numhu Allol?? Qmpwe GHSOIB 96106:1 a5?! and CL ?l F?em'EL??mow ma] ?1 Mar sum?, 827:. I was com ampubaurp Mi Ta?t Lem Sam PEI 6M anew avenuc wwmeyummaw ?91 8 \l ?(65 3?3. PM Nb 32?1 cm, 61?, bous? scwoer?mt \dal newer, bow scwnem Tear E6: .0153 Tep?, I ?10 Pm??hm' WW '15 :mn4mum- w; ?2,163 5% _Lvm, swam ?25 TNCM T126 Bo 1756? Nd Nm8de-3N \k 36% 1068 3?16, 63001?6 17:6 W: \cm. $2.?ng l/ ?1 Mr pm ?laml'ar?ctm ?573 Mamet; w?ma? $5515? E. VL 17:6 pm GM 5364. vmw. ms 5 loamymumomlamnls madebymaonl?nommlmo. 101V WW t/ Page man '38 Arnmm Fommd . In Dal. Case 18-2868, Document 278, 08/09/2019, 2628230, Page345 of 648 _i 103%?: pea Alral? Make and Modd Nm? ldoM?m?on Mam Point- 00 Dummy. 1. Arrival mm Pram Gums 5155336 Tee Peal? I cm; 6M 55' GLAW 0mm. 0' um NWO Wham yl at, cm, Doua- ?smoer?ym I ~l new aha/mg l/ S?,em,er \n Magma-.4 GM (2356349419 5\i: Vl \an SC Tana?~90: old. 5'01 Sf 367? 105835: 69F 36:, \l 3B1 Mo 36-, came \pg; 101?! J?enTa-Pilaf: Signature 34M +Mabc2-Mm Wm mm 49r? I NddAg Amoum Forward Case 18-2868, Document 278, 08/09/2019, 2628230, Page346 :umom About: (ab gm 3:39qu 1 m. um - 86mm, ?Duo '1 CV12. 3/3 '1 @546 Nqoase 38?1335; mm: 2.3 MRY ?1?1 112?. . lose . . . 2t] . .T?s ?ack 22r?44? 2? -Jff??f 19, 1? 1751 par ??33 ?04.61", Ga, GIN-Y Keri/var ?11??97 {961 we 833%? - AVO 9E5): ib?m?iy P61 I ?ww (PM 10 60.586 N40953: i981 \aeu MI madebymeon ?siormarouue. manual '5 I Amount Fomutd 1? 1 3q- 3 am To!? (0 DI. 0m Aircraft Mcko Aim! Point. at ?op-tun Arrival 193? rd Mode! uenuscanm Mark 1 5" so og-mx?uommoNr? P?Omoo - Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9347 of 648 Main Main: and mad Nam" ldan??callon ?art 0' Dev-mu 1. Arrival From Tu Flick: ?own No. Allen? 61 T66 N?W?ff? T66 SBF VA ?6.th n?d?m may Mai/r 21. see {?61 Oouc. 81 46,9?, ram? Luna. 1.23%? 1/ '"ImeL 86$ Tom 639062 mi) T0 1N5 urz Md be shamans mdabymoonl?afovm arem WTdal L13 a Wm 1M Manchu-n (?le I A Total [a I I I orahrwz4??omav?.b ?w 01? de-df?T?HclU?3NN "d <1 F?w mm -- "t Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9350 of 648 03?! Make Nmm! unaMoru Imnrmunn mu: an Pohls cl Doom-lun- Arvin! About! Nmubat a. 0? Lamas [km 5 sugars meme PM 5 lo ?6 ?,swm [Swat-0,0. aspen) H3563 3W SD ?At . <4 39:22? ?2 N11?bme guuh?mnu time - Meewnw cub-?vast, 1/ amt?mu 'mm. nurvmua ?1ka 73- ?5 am?: we ?Mmm um: . mm?dawmgi?smc .meMi; 6) 3/3 ?3 \1 I ?mlww Lav-Imam?, ?Mni??GM's 9?12. MMD, Sfaw W5, M40 rm 5W yumm? Mb?? c~zm:w1mm nemnrmi' 3 iv ?h *r nuo crow aF'xm?pa QQELW Mg? - 1m, samg.mp?1nmleuw Comm;- 1' \1 NHS SL3 IVY vcr? Mama. (5119.6 {mu rat-WK! EQM m. (WM. as ,6 aw CW: ?843% '8 {Jr?(poo a? - N-neme 3w vatwum I 5 5/5. camsw 4r mum?lpumws yam?. 81513.}qung Damn-?Mo - 3w Clm?m Folk-Wt Madlgirluomm p69 W: 1M5 Va: 456;- 28 IRW Lavawas.? new .5?;ka - Gstuac/stm- exam (:15 man 50 CYS Own-buoy. 667 Mm? man we aanJo, WV 00%? . I canny ma! Iho ?anthem made by me on IN: form an true. .. 42an ?M"wa Page ms ?3/43 Amounl Forward 4 1'qu In one 3 A - . Case 18-2868, Document 278, 08/09/2019, 2628230, PageBSl of 648 Du Amt! um Nruni "19' and Modal Hub! Palm of Denomi- I Arrival Mlot Fiahl OdomEudora-mm.- me Tn ?mm (Trim Gum ELI {n ?551. Pm?, GMN@meuanm s'maucs CDQU No ?gu 1\ Gem Tee\ H39 3'6; ONFIDENTIAL 5 EST mo 51 66-0 Sc:? 5 IVNY f" e, 166w We V1-00m 065m . im?~ cm CNN T??j mu T6 \ttusd??TGPY,E "\?MCCibon was:e,em,e< I Ohm.? acme-ma \jl ?l PST. (Viz?ream mm (J (?4?77 2m Sod} as& TC, ZL'smtpe SPEH L4H we - Wha?mb?vtu? oc?o VNV 3"3155116: 0w, Gmumqw 23? 15 60915 M10532 NY. 98 1: \62. Se 93:1. 11:6 . MS. 3?3! GM 989on 3 pm??m I), tau In on. Amoum anrd FE \h ?2 .I: Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9352 of 648 1' Gt, (sum n, ?rm Mm! ldonlilhnuon Points 0' Departure 5 Arrival To 3 9m: me Tm T3331 1. I sec: mun?:37! a-c. a?lrru'?'56W, Cwawocuw 69x; 3' (4M1 CUCLECW L?f (?o?t?fca(5E Wayofg?, (x 0mm mew AmnFOI-nm Tibial to M. FIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9353 of 648 MIXER Malta Airman POIMI 00 l- Anhml M1591 Flbh! Nunbov Mnn? :9 and Mom! Mammalian Mam Flam No. II Endcsomonu 01 um - ekbk GLIM 0? From To 5, o-usqg Nqotbsg {5&9 moans; 9w: V: L9 1! 65.0 T63 ?mom-mm Nuasnm 0? Te?) 0L0 3a, (4.1., BDBM Mavwwa . EL OLA um ?311, 06? L1. PM \noT?/bmerm l/ .3 Li 1236.? l/ I m3 Vt (.360 T60 WW :sco, Deesvowmm i . .13. 17:3 .(Jgf . (5ch g/tm. .- - i \l N0 P?sbu?cx:ree m: 39 (79$ ?59 ?[213 T157 15' 3 (98$ ?95, 3e,c,m,cmm& Mien, e1, mama Ila P31 Us! 3949"? I L. \b CMW 1&4} mu Ecume99?; ween: Panama! V), I ONFIDENTIAL JV?iI?ocOw ~9oav Nd??ric?o?h] [.51 ?fn$ 3.1 Amount Fomard 1 325.5 Total to on. #254113,- ?Ill Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9354 of 648 =rum To 2L7 @11qu Naomi: 1151 PM . 201 -1681? .. was Emu? T66 6?61 A Mama 5 (I: 991?. lT?z? $008811: (amine 45 ?g :5 u" 0&51 stmem'm? 3 sac-w - We] 08.) 9/ 001? I Mo Resubma-sr? Amp-Wt 19.3mm ONFIDENTIAL 11.5) a; 51 M1 ?58me i PM We 84% m8?? 2,9230" Ci. . .H - .0 7?ng ?at; St}. L0 59?1_ r, 90w I (Mum \5 WW my 54;, may 0012 115*; 59,41? GT :a 1751? T03 WM 55) Tub he); 1m gammy "3.64.30, own, bU?Oic" 9m ?8'?ff."ftwm 1 I I 9? m1 2, 10?: 2 1 ?a I PaggToul ?47:6 1,0 i - "135g?; 13(41 b5 3 7) Paar; Signature aw?) M. . 717/ Tut-norm. qo? 2W3 Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9355 of 648 Aim-ax Make Ind Model Points 01 Don-nun 5 Arrival AW Won Mam Fun To Mar Aha-n 0! Landing: (?Team (3!;ng can?. n. [Manon-"Is 20985 661 u? ,9 \l (7?0?5?16 WSQ 1:167 20683 Wm w?l? em yummy .5 . knit-1.4.4.. I: Adm-1m maneuver; QJ NFIDENTIAL [966? l ?wig! Gig-E/J/Mfcv, 16 WA-sr {cg?me \a NEW 9651. EV MED . N?vmbm' wgutr?am 1 ?T?giawce ?mom? It 96]. NW4 mc??3 52? WW MIL-L ct- 11 PM 100.09. u'k'naH vm? Pm: WY C: V6.52: 1 599 mg TQGM, (,0ch \l 39?, wax" He 6?23 (215 Unmet an - 11 641qu LOI \l 2'19; I Wm (Xx-rm Mam-Hrs. manna I Mu'r Alarm emu-{s MREE rzc?l 3?"3 two 3.11: um Maw T63 17A 0 Tag, PEI . acmmur. l/ 3 2. LLlo L?i 50?37? W, Reviewed Hora SwamiArmum Pom-n! 9% ?6 mu u. om 1%nu) St L. I Page Total 3P Case 18-2868, Document 278, 08/09/2019, 2628230, Page356 of 648 . To slugs?? .21 cm 1% L3 ms?oom MP -. /Domv~ ?mm? ?2mm; PMP L?s, Fu-?v 23?11]? 16?:be N70 PW ?Lm? 6 719.0220? (I 7~5Lym L761. @2226 3 new PM pn'p_ 13' 9.3/52 4?1? {543? 7175 LJ {021,4 1m. - [k 4 ?l ?re-Mo my) 5.001.774 :14 y_ f?/r?ja/o fie/y 5? 3 5003.4 -f F/A/dl/ prun7/Wo? a 25/7 (Sr-?5?16 66 if: ?M?tff' Maw? Lw?q 9 JV ll.? 6RD 16! Nsmev Gm om. g?z?gzgigr??g? mg: if 5'00 39 mm meats: WW- 1: Ex 9;an WW 6 N05 7W: Mama)?? - Dab Alma! um Auaan mm 19% and Model um mm Mn'n'?'m Four 82' an ?wa?r? 3?3? S. ISM ~clz?rr3? W): m, msgeu URL 831849 06v) JW 2 mm (5 ova 1161' T?fb ?mid? @115:an 3m ?JdoL?b Socma 50m, musgecpowg KT 90cm} (500 - 7; PageTbtal_l_ 7 29, J3 %qu23 10 Tom to on. CH '3 mcdoa whom ?a b\ (J?s (?if 4o! cr ?Hot?s Sly-nature Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9357 of 648 Altman Make and Made! Award! *1th Mn Felon ol DOW l. Mlval me FR) {Ebb} $0035 PM ?Nom Mar? Numba 0! Category? (sutoen- Mom . lat-LS 50030 132343010 a: V) 'c [Zeus cwv'ril?r 51.05 KB 5?00:wa firN$>tjwi (A511 55 N?mg?: Tea MBA Sui." amass Locum? .26 5? LEW: mum) gummy/m," 9. 41.119 NFIDENTIAL .- (3M0 4' jump (41.13:. 1050 53?! M1- 9 ans- v.17- ?Orl- X162. (3mm Nclo?sic? 1961:!- 1' 11M: feign" Bf; a. (cw-nus \ll ?utguxai Dmu Luv 115 Ti? PM Mae 9 N7 ?tr?wan? Knn?lw C?mea l/?j?l \243in. zinc? two 1:13) T??l Lamayj?gi {in?ame}; mule\win?mpm A351: 53?. .ML-Mkoz?w?ptvm . I '4 95m TOE L/l ?3ng Lol?k i I in? . C?w *1be "Ms I WK 94:91.3 WNW lat/L Foe PW wegr 1 214591..) N355 JL (KEY r-z: jack-Lb .5 mm sf) .30) Gir?b TCB {381 he @37an 4/110 - 1.1- '0le '77 Ll?drA/ch" rue. Pl'lol?s Slanaluro . ml Mid/w?- Page 10ml Amman Forward 4 3,1 8?6 143?) Wm- co. to Dal. - 93-- su??c .2 Case 18-2868, Document 278, 08/0 - 9/2019, 2628230, Pag6358 Of 648 Alma? Nhko Mum Pom.? Don-man I. ma andMod-l *4 -I- .. To From @1513 Netos?ra PM ??98 Gm? Pil? h? .9?913332. I m: v11. PP CtmuumrMomzn, '3 . I 9.5-1 web" 692?? ?mc?b Nqo?sxc Tee rm I), A: '1 1 may Dee-s wamz. [Moe I I I c; .NFIDENTIAL $0 9. a? 1L2. 1L. 20 \4 (?81 {m ?Ame m1 5333' [12:6 36,0 C6 2 TCST ?mgr/?ts? ?Int-C) a? . Scrum; hmou. . Hm I . cannwacm? 9,091.4 50mm P011 Jr?, n57.?- 'FBE PPL pin-,0 Pn9-Lm PVWI Rc?ro?l?h/J?flnfearch H, 11mm, MchJ, Wipe?! 5-7m; r7 1 Pm 3: 1' PGE- um W20 H?v/ (my) -6r\cmm - . \mg?nnimn?c??m ?Em? [o @1910 N10933: Pm:_ 6&0 Tar-3 mu Gamma 1Q aim-77 $0033 I PW sap-far] formantmo. Pam swung) W14, 0 Pmotni :1 2t; Amount Forward 5 ?3 A83 - row to but. I a? crow *1 .g .- - -- Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9359 of 648 lingo Almn Make 19? and Mode! Mm Alum" 3 Flown No. Menu 0! Landnga Fm A (ll-L Altman Points 0! bop-nun 57.5 Meaga- M. An '1 8 6 =3f-r (WM 635?, ?1 .. 1.136% Max:339 9333?? NA Tc NFIDENTIAL swan-em av Mu M. mam-4e. swim-e ml 1.1ch 12ft? 1? Pm?? 0.. Wm Slowlum 1 a? (9.531- 0.31m Iver PB 1. '4 - {[66 IQIQM, GT, VI. RePoMgo Tc? 1990.? c0 . A: zvh. (44., um! mam? m? {Te/Gr"! II TLST 9? em: 5m? ?m IGIGWGT we (733; ?V?Fme 620%2?9 PM T535 m6 (?47 6?27?? 1/1 i ?59 995L \le 5? MW, (219%. ?{Wm I57 (5 ?1 lg?, mag,? Gil?mtgl VL ppOOt?lamrna? 40 Mg. Tom ?1 Amount Form 'l 3% Thu-l a- 6.1 ?1/1 {41 Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9360 of 648 . Duo Arman mu AW Hmd?opMIAv?wl Mics nm A In. - Number Tlunar-M:- .. . 19:17 andMuod naenmmumm kan No - mom- ?mam um Pm To - 9mm arm-xx lwma 14? 72mm 1823 Br?we- PM w? (J14 (mm mom Td?? Per 4, 2 . 16M, er 9. 21 (?81 Tee Sc, 6115 V1 2. 23? {390 31, an .. (560 TV :2 ?1?4 Tea semi 0mm mgmmi 9'n-sr - ~98 \15 33?4?? 1?;wa ?l ?3 ??tfzs?t'l? Pmpm??iurLummb SOLO Niko 2.0 NIISMF Hw Hwa P??zzw?ergazm?gzcm 2h, ?1 Le. on to Mist 0w. 3/3 ?1 15 eusqb mow: T66 PEI us; 17/ 9338/0016" ?75 50?? ?-59 .. MW cm? was '36, weld?e?! OPAL 59,9 \194 32-1 9 \a ew?v - 1' PagoTolnl y-gqIFomam 1547. - - 0M .4. jinn..-? ?5 3:??wa CM 0.4 Aldo! a . war-eon- Case 18-2868, Document 278, 08/09/2019, 2628230, PageBSl of 648 43y Moran Make and Mom! Mun}! Idan?cauon Mm Points 0! bop-lulu MVII T0 EE Fig?! Nunbm M. In?ation? Landnga Aim-n MOM.. {mom Guam W?Hrm 6mm :3 Grimm: g. mm. SW- '1l 9 N?st TY: b?Lk??f ?m Miduh?m?IMNM - - mm unacJ-tMJ-W 5 30? G-wma Ho. ILUMML. Mama?; ?1 MMnyuQ .muruv-? SCh'uu'. 6:?me Uum?ly. we .vd- mm $2857.2me W5 312,57, ??fm fuel!? rm:? \26? j/ (FM .67: :LL?tiLr ?1 i 09' 332-5" 9?31?? 0 44 ?2.0037 l' 11,403!? 51334" kl-??h ?3 .114? om \s?m m. 31.5, m. . 2:5 (sum?) mu 21% ll ?mat. m9: 'selmoM, W?th?v'f; {Mud} h?b uk it ?21 SEEN ,r?fj l( ?23; 3224-3", Mm; 1 La?. 129 I . I. ?Cm! p?fn?? I I lkmw?te?MMf?m-im? loen?y 11ml Ibo statements nude by me on thin town in lml. Page Total Amount Fawn '5 118 total to Dole Plot's Signature ?Aug I . c" :r CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page362 of 648 0% Alma" Value Number All-cull ('3le We: 3 i a "v Arman rom- mm c. Mia: Flluhl ham m, Ioumncaum Mam ?own Na onl- Fram To name 599 ram.) Hem-?7 59;, Tag ?ML/9mm T65 [1 ?my. CWL 1'66 at?, Mme 169 V?sf 55, 914298879: {?61 trot $326353 6 @2922 my 122,2?! @553 mm 9' a kn?? 19/ 983: ?3 (7-1646 ?38%, lo G-lm? qut \k A NFIDENTIAL 000032 1&6 um 37: WW 3): 27> (59 01'" 97? CPI RCNC-WQL .vEE?Wu-wa er-mm :rJ?r-mJ .. ?(01?44 69? 2?13 f'X? 59mm CE: Renew-M. '75 (316% N?iO?da'E PM I?d-jam, S?eu?v Im?c?m 19 TEST T66 p39. ?aw. M. anew? nomw car 't 17:6 61 Tm PB: 96?; V). 3% mm 75' 1&6 mqse, same Nerf?M Tea BE-J GM. Fag. Total Amounl '7on 181% to Dal. em. 166? "l Case 18-2868, Document 278, 08/09/2019, 2628230, Page363 of 648 0 5 was 0LT Am" Make and Mode! Al'cmll ?uni?cation Mari Points 0! napalm 0. Arrival Milan From To _.Flown nun No. [350 PBS Us \4 P31: 4.. lumber Allen? ludlngo RP, Mlle? Mm 6W cm, am.? am er l/x T131 T63 (Hangman-1, Manon Law 1 vi 7A \0 961' nas- 1'$6.6m ET, A 96: w?q/ u. 37:, 610,61} meme mun?141(th Lewis V1 5 860 Tasmwr act-gas 3L ?4 PB: T39 Se; ET 1223 SAP 912w: ALL $3421 ?36? SE. 13 SAN \36 5'6: 50? TEB 3'6, ?memo mam, Mm?" ?L?s HM: I301 3'111? 96 I 3301 34' . MANY album? 7.7. ll 96f TIST me 36,'Cm,ef, Anew emu m. MMQMEJ {PM/ma. Page Total "3/1 Amour! Forward wJof Ii Hal-I On "I'l Case 18-2868, Document 278, 08/09/2019, 2628230, Page364 V?a- ?l?t a: 0? .. 33-. . . $3051.? mm if?" N10836: T?sf PM: ,c?r 1?61: 1563 Wad? Tee 5M 1. GM?mgcmeuw-ma am 59? vm . um stats-mar 3-5 17:? an W- cum . I: 16:6 mpsi-?n?negevalwmwim 163 an 3'61 Sovmz: mom, 96F 08?! ma V: 3 Or 1116 9mm? - 73mg Mamba ?Hooch .. - 1 Endorsement. Landing ?aw r4:- 240484 . "t a- Jx?f?r Tea 1151* ms 16; {50, 53mm, 3 . 11.53? 82936189130ka saw?v Um; N11 90 9m 9 Pm? swmw, 20L L3 gangW145 0336 $Modify thallhomtemonb madebymoonthlakxm mm. PloeTotd {Kl/?Momma 9?1 mm Germ-,1. 3 3 1? i .E plox'a signaluva . dm?Td?dda?dm 4. :t on min 3 Toll-Mn nu.- "Jar. '3 "?10 Case 18-2868, Document 278, 08/09/2019, 2628230, Page365 31?..219: mm? Fm *0 Wham?- MomTe? 67$? - . . WW. mgz?mev?Lu '5 .. gage, ,mwro 4- Ma 2261,} 72.51 ?ap-NH?) PM ghgg??z?igl? "?f?pm 2:63 me? Mu; Nun; mi) lea?3 M7 NW - WM ?C?m ?23? 160.} Mum ?if? IE we 724014 101230 FL-L, 100.3 mi?? Pu. pmo \3 wow (?745 k; mew (57% :6 zaug hm PM mp ace/y I [11.126113 inf/7? in?vLcl-IOMF ,up as I 1.3- 10903 1190' row r: . A9M9 V??/L?Ifr?yfyqumm as ?35 Wit 'pmm.? Jr (a 0 Lb Qd?r ?mm? 351$ 11.s?+ 33 I did Tot-noon. 1150 3 3 ?15 Man?! Mona Point. of nap-nun I Anon! anc Mada! Idamlfuatlon Mam '07 .. - Case 18-2868, Document 278, 08/09/2019, 2628230, Page366 of 648 Data Aircraft Make Aim" PolahotbepanmlAMv-l 38299 WModol ldantl?uulonmn From To .?mt 6:1,th 23 9.061.} Mu?? m9 3 ?0 mix/LL12: Lyman. 1H wl?zg ,f f'sz?nry??j?f ZOQL ?3 w/sz/ 1. 7 X7 :A?Z-E??Lm-Vifvml 1; law?3 N119 p, $143 5? :3 034 12/" :m 1? vK ,4 . 353: 1\ \l RV -0 [?7f 1: 31?; It. ?9ng . 2 Map/He n.2, 19,5, 1% a- 7?2- cr?Lm?w muzzle wF?/n? 6 8 ., 1} 5323/7 ln/orji?frirug? 7 "0 PM f?M/o 1200; - L3: 0 ?m mm?zqu mi ??owery; - Lu C, qugy?: j; News's are ll . U37 0. wt: Mama. ?4 i? P9 Ti? 5551 ?16% chy?kiTrc, up ??51k Lung quv ID lcetmymumstmomenu Mela bymoonninlonn arolnn huge Tom! ?{rJd'T? FWJ a . Amou?anard . I, . I IN ?.o?uf I runs). .. Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9367 of 648 Dale Nm? Make Aumn pom. a a nun: Mloa Hm 7 . andModal . 5' I . 1 {3.3mm x-a'i-i AM From To Ct ?04! 6 "3-5-6 m? Hum-mu (?36 I WM: 166 ?9ng T53 ?:57 4:345 L?wm 1/ 3? 13?? ire, 5 Lawn 31> \c ow ?ng Rc?zomfpr? 3? 3?1? [344 115??: U. \t (3:445 je?m?es?, Ct T628 50? metreSP0 L115 um 31? - 1mm Number Alva-? Tr?0rr? .. l\ I A ?t LBS 990? 1359 1'1 Ph)? V9: ?35] at" we 9m: ??66 his?- JG 15? T655 .53 f?rr?ma 25 TEST 1315 3554?? ?934%; 25- Ll Pg; ?35; lmo. leTdi 2? Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9368 of 648 Alma Max- Alma Points 0! an An! on ?lm and Mode! Iaanmcunn Mam nap II. No. Fun: To e-nsqe mom: ear 1:57 osmo?) VD 1351 e31. 6?8; T63 A ?mm?wwm .. 4 129 Babe/?it LIE-O 3"Allen? ?(:4ch fa i GMMX I 1: GNP $036 ma 3610'? ('66 [Ea-6w my ?yam EGGW 66% ms Tel GM ?608 GK {365 Salem 66R T615 1 I367 17:10? ?3 was $95 MAW Laws Vt 61 T60 ?$315 A: Tag 5 \310 PW, 50mm, y?wfao? 04 31;,vame 39K a 3W 4?st i :rcz'sw [aw wanpp?rmm?w 3% Mickie 98]: 59? Vac/?Ham? 1/ 3 Page?lbul I 1 63? - 211% - ~r?3?dNT? Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9369 of 648 on Aman Alma Point- non-Nunim Aim-n 1&0 "?u-119' ldonl?cauon Mark New No. mot-lo 0".an AUG Fun: To G?st sac 5 \wv T626 3 Tc? 5&1? 661 T59 A \g TCB \333 16,5?1?1139 l0 ?9 B: Kama 1 L2- (16 ?5po 1/ ?24 T613 f? m: Flame new?; 25 sag 743?? - 5 1:51 5336] T5) 96?3?? '30 TEST Penn. 1 05-: pp; Tag I45, Gmcw, 1/1 5 It QB: \?LJ?-Vsb?u?YL?wg? I. (get .1c? ?3413 372? Car/?5) l/ T68 L09 BCHTEF, ?32:85:52?! P9235 ?3 Leg LCPB \3 3e. Howwe \5 #90 ?9 8 me 1'6, 5 heme? Laws .. gems 66K 9993?? 3 I WFmard t, a? 7375 Plot?: mm. 'I?ol-l (0 but. 633 (cots 7?135? Gums/L H?rb?w?lj w. -u-v CONFIDENTIAL -rmddol e4 \n?qv'?j?r?r?l 7?1-36 I tn mm ?1 3 Case 18-2868, Document 278, 08/09/2019, 2628230, Page370 of 648 . . '71(1.. - -. .. .5- -. 2y: .jf?wy, qr 1' 111d: :3 -. ?foxy-312.34 9-.- . . Number - ?aming: Dab nm-umma.mm We: -- .19: md Mada! ldonllaa?on Mad: I Flow No I ?g 1m?: me Tn 1' .1. . mun?Me own New. 6?Il5q6 Nq 083-6 (3 GR a! LQY ?96: me i - GMT: gm 2x mm TIST A 7.3 1161 m2 3810?? V1 '25? ?qu N03 6'1? 11 EGGW 14M mes 2?1 ?t PM was 3816?", 9'7 11-; i PM ?5 Iqb?tl?m?" 3? 12:9 P81: um 37:, sacrum LL-WIS P813 1751 ?Wje?aewrl '1 T157 17-9 PM 1,59%? l/ ?(as 98: we 3% ET \2 Poi): cm? muff-?5; VI (mar Par 4'3 VNY SHIV ms ?77 l/ .. San) PB: mu. 66:0 mldobymoonthluomam true. pm NTUOUMFDNIYO 631? (ooLT 7?135 @4412! (33141- ?no .4: 7.. .rv . . Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9371 of 648 umnm mdMuou loll-ho! mum I ml From TO Flown No Winn Hm 19313:; . "r (7435018 (BC-D Tee Nmnbet Landings a 3 LEWIS (?1.me 1k.- - 0GP) 1 WW a9, shame? Laws H. 0&8 PS): I?m 37:13", Lawn 86; 1763? 3318 ?s21 36mm um 2:616!? it 861 cm, re: team leccu?erfk b4 on ABQ ms?e?xfnm1 168 Muse! 5" Th6 LFPB Mus-elm?) EV, LFeb E6 cw 141% Ian, 614,95, Kid?L7 59mm ?e?w mm KaLur 5191mm mm Mum; ??611: EGYM 66-5 HS: I ?65? CYQ Nb! Wm?wW mo) . cg??c?L?fimgmy? M3 r? Pr-c? CYQX 98): N31- 217:, anew, new? smwa . WU: T63 ?13 3e. ?rmer. \rmm T1137 N34 71?, HP, Vucaupr fw- cars a. was 532?! 96; PSI W35 Immuthammumdobymm?cmanwo. .. A Page Total Am! Pamud Ovsrol?JMg-pmr, s5} NFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page372 of 648 NnInMaka Pohudhopaminl-Anlvd Miss and Mode! Idon?iaUmet Fm To New 33.: 6-?qu Nqouc PM LCQ . L61 0, :x ,6M,?r 1&6 96): Lew 23, 98: T68 Wile 7.3 My 315/ Qatar 95 L998 31-, 6mg, vmomm 12m Cluvou?r peye soapy?: 2/4, 0 1?6 LC 3?m ?Janus SOSLS g?l?i? Nat 0361? p6 115?? ?41.6361012mm. WW - A \g SLrwumw- a? v. 23:323qu lug?? I 1- wane meant cue-uwa Mme. 'n a NH) B?bmh?nqu ?Raine f?Wnoh?f 2:0 MC: ?Mr-4.9 sv?pg-LBT; 1 - . guns ?6 team? A A 16m cue (Jo new mug. I ImamhuumMom-mmuym-onmtommum. pagan?, 19.; 2 m, Liv P?d'a small. .0 M. kab.?o . . I Numba . ot Landings (?31:9 gm a ?7 f?ru? ?U?Ndmw?vir??d 2? Wt 3 s3 Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9373 of 648 Due ?mm Max. mm: Poi-n; of bop-nu. MN. I. I. -. nna Mood Mm a :m . no, Gan-lea ogw ng mm - mm -. Hamm: . mm . LL M614 MGM [Jamal s; -w??bp?emm . 5 2?5 1mm WQMIM ?nw 7.3 C-H 1m 106509,ch new nos gm.? V1 21. 9m 5:512- "Wt? PNS (33 ?uomsm Q930- ll Km: aw b' A. 99): sm?imnruzfiet ?f??m?vw ?1561?! Roman?- M?fs?emurwcu 1., ?9 5 I CQNFIDENTIAL V1 LQL PE Kins-w Was same may: 9% Mr PM ?am $32? C?f 3T L?'lyg . .. ??96 Lem f? LEGK GMTT Hg :21:be t?vpm, ALMvaI-wm rcmo .4 gagw ELM RUE EGK 3616-1", Q, (5 Nqomx P0): Fm. VJ II 96f Cum-um, Horace-em @1641? (408:3 "(as 3.59 1H1 F?Jw??a? New? waW??mw El is KM I Pan-W 3/7 L13 Area?W'mmwy?b v1 a -.J 2345' to +3 HUSH mamq?wao?w 23:? em ?33 1110 3 3 m. t. Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9374 ..7rpum-..- ?h Alma [mm of nap-nun 0. mm: Inonrnnanon Mark Fm TD ?ight No. II Edema-alt a! Landing Ha. um: NKOQIC: LCQ l/ I a {?61 anewpump, 0w, swear-m 3' W51 6; M, 6W, ?v?wmkm? Uni. 0W, feral: l/ TBS wimp; \qm??iw?i? Um Rubens - 09? pg. W- Su?-ruus VI FLL ~98; :mamw 11.5 - 96: . ISM aoymyw ?App-1 (news Caum 61% am? Juana l/ I 1% SSM PBX JUNMM If? a?og?cwM mamnammummws ZN Nq 011?: @831 23 \l 39? img?m??wi /1 ?22,2? A?n?c Lt EM veg 34.. Mb - 8818220? ?23535 1/ V01: Lani Lag [km 36:6?; ?9 Tee Gm: g/L (am: ?(Hi 1e, carom 6.6 (Der: 3 3 l?I out! [y WEN 9.9.73. ?70. 3 gm -WVbarn-w mm 8le Case 18-2868, Document 278, 08/09/2019, 2628230, Page375 of 648 om mam Make I pom. cl anamln I. Arrival Miles ?19? Model klenli?enuon Mark Flown 19% Ram I To {0qu2% (5FLL 4/3 mbar .. mu 9? Alma" Category Am Hemtm? 3" er, a? 2 58?! Egg El,- NFIDENTIAL ?chcosi- 1:51, 5,1,.an guwsfeazo-sc?r?n [051131.373 Ac,? MN 3L,e1/vk,6 a, saw-1 ?f ?1 Ma 16,6470 12,15? mow?) ., Am, 572,9,4, M, (5 1/ lb T131 em W56 Inn; 1? 90 we JIGMWL 13 on; \qu \71 cm, T66 ,cm (st/mmm??Kcu??f Bovrwq- I I NY ?ms" 'r 13 500.1 L-Iif 3 5/ ?0de mwdr?hq I .1 LET P105 [500.10 mos 58-1? \s'ol S?qwz?wwr Rosa-ms VF SAT ?53: I562 37'] W2 awmw 2? Panama! 63 1 Amuum Forwud 3 3 3 Fibre Snnatua A ?2621?!? Total 1. Date ?351:Case 18-2868, Document 278, 08/09/2019, 2628230, Page376 of 648 m. CH From To I Dunn?s?; ?-?f?G-usqo qug?e P61: on p, ,pmkooezngg U1 . 1 CPro Tee .e1,;Mnowm \6 (AMY) ?cj??mp? MCM 1/1 mm 17 gamma: m'mzzg? Vi? \t 30 1' 11K 06.x.) a ten. Kc \0 090 aroma-ass - 30 AQ. Meme? i \1 K, we no Wigwam; ?3 :1 5: :21, my 1- mm ?:1;ng Mm; 1?4 @1389 N?fom?, ?g 169 5mm wane? I I 5 1.0 15M oen? ma poet/Ab 34 Case 18-2868, Document 278, 08/09/2019, 2628230, Pag9379 of 648 Data Nam-ll Mme Mint! - Polnb 0! Doom 8. Arrival Mics FilaM Roan Una. Murmur and Mode! ?emanation Marx Ram No About: Gun-r1 . Relic?? .. i 262' Ham ?Landings 817nm I (461023;; 65; Hp p. em? ngue wmm. 38 - \x/f r1 \Wr? -,533:1}, 411?? 13:57 a?crm?ygfg?'gw?fi? a 1' Hip l'z. Hem? N. ?3 BK l/ 515W: ?q mm) 1? F12): Way; (4:40 1? Np; mm? Thur, 131' e. :1 7:141 Masai-m, 981: mm xs 6&5? 33? 2? IL) 1L (\qu LEW 1 AS LFVB CTQK {q 34/63, emv?iv 15? (3(ny [q T4567, @91va 1?6 wp 1: ?10 16,5, WM emu/1.4 (t 93}: BBQ 3?6, em, s??i/Wr mum.j?A7( 13 Mbwams '1 KLL 2.9be ddolm JONFIDENTIAL a - - -. van-a,? ?w??rj inor?a H: Page Tam337Tot-Hob.? 253\ns . c.21- - -: . - Case 18-2868, Document 278, 08/09/2019, 2628230, Page380 of 648 Alma Mam and Mode! Aimll mm Mam Muhamm?Anh-l We: Flown No. From To Nmber oi Malt 1; ,B?mm N?to?zm/ LND: (033536" tam-gm N385 if 373154 LCQ MW Mam? - 8H2 sm'xswacpar ausmm IUD G?a?ls @4685 PST. TEE 0' N0 96:56ewuw (JOIQFIDENTIAL 7:35 '631 15, 5mm? 98.1: me,m,sx,mm Steven Famuc 35? CE 692-175; flu/WWI 2 mam; 16mm 9,5 mi??wwg 5595 375,571? Z?cm \su?l :emmu we trap?. 5L 5'49 \593 3?96er 5K 981: 31?; 5K vhwuufs WNWL Gabe-PT 3613K T60 $553 PMSKIJUMZ- m?xw (2,58% lhal tho untornonla made by me onihb tom m. Pap Amoml Forward H1 'l'hhl On Data mt" . . . ?av-4 - ac. .2 a. . .un?qlrutA?rmuuwmaw m" I ?19:4. rm To 1 6-0500 Nc?quc: ch Pb; 9911 T68 .. ?g was m. - meme LGQ m; A - fV?W?w 10 .3 ?y \i CHEM 2L?f? 1M1, 30 Skl?owe?oo 10 (icow 3? 1e, 3 .19 EGGW 32 3C: u~ ?57,4 pp)? 33' 36 SK sun. row-3530'? i Vb}: K157 '56 3L: L: 132 MW 31 ?029 6? ?mm \g I CLMW Numhav Micron Ammw (rum-I. at; L): 173:1. qu?bc F95 BCOU, MLwJ?na'Urfl Oln?nu- 3 i QNFIDENTIAL 000051 s-nSbo-rr-m?nm . 440m} 7/b - I (Q (Lida/av,? 33 (J: WM) numb-to 3 \Il. 0" ".(Irx .- Leer :4 43: c" U: :r '30 AV- .903 Case 18-2868, Document 278, 08/09/2019, 2628230, Page381 of 648? Amt! Idmt?lcanon Mark o! napalm AMMI Hum To :1le cums ?1 ?Lo?ko 347,2. nechmt-mr' SM, 20440 41?] ?g 0? ?LoMo wk?o unruly, 7. (ha/was A out \t 92w (cactus) WW - 0 3e51, VISL 53% 1745* 5C 5517 \l b<3emm W31: 8 NC mama 11 mi 35%} 37 Shamsxme-mvcw,? (48?le MN \{Mw 5% 3L, \l F615 3% i ?gzemw? I misT TLPL (?Bi 1" Wm? $915 0/0 \l L9 ?wft LN WALLMV, P9 w; Ie/s?mm MW 53, (3-0686 Nat MIC: m6 PV 155?? ?36'6? V5 9 BF ?rm-3! 0?63? 96(41% O. I, WQCMELWW Page Total .31? ma? Nnothomrd 6?55 -Naamaral?Ng? 0' 70th! to Dal. (bog: 1 ght?tlbo?a vim (4 Case 18-2868, Document 278., 08/09/2019, 2628230, Page382 of 648 >53: :38 use 2.35 .8338; 2.5. ?23. 0- 082930 Zn. owum and: L: 43% .- 0? 2m? 2923 E52. arm?: 0 Db any Fm?-ufmmzartmx?b?i?. ,gcv m: Ho 93% Va 6034592263 3932b MT 3. an 3 wmw?m? may.? .woemaum?w .3 ?Ba .3358 mm. QFMK99. Haws $530? 8 i 5 H5032 10.), Em?. umx 25.6qu a, a? @334 9E Egg? use 458. . ammw?yzaongr Case 218, 08/09201972628230 ,Page3830i648 r4 Th?o >395? moga ?F\vl .633. .5 Ola. ~19 . - ?317w" 'cl? . 54' Dale Nu.? Main Marin Points of boastful. Ania! 49: .amuodu mmnmum 7.007,- From To High! Mamba Aim-? No. Finder-uncut: on A ?32? {Hm-3: mogul PM 68V 93$ GLEN DOW 0117pr Cal-M ?Ll/[l cams?A cad-wow 1.0 \t 19134 M?lf? ?o?m ,t'Nb . ITLHIW 91' l. A ni) ['il?l 3 1 - mfg: :91 mag ?1 lured #ng" W?w?g NFIDENTIAL @131 3 my mum ,V-nmm Nanakcmm K0me 1\ 23 U) ?gu?am??wz ?m mnar nannies?: SH.- Emmy/w Nauru? 153'. T63 \su. bem? 3\ N?o?b?f 3PM 6IQ Ema-L Vi b?z??zw Smuwm Mm IVER 5W P5176 gm?) ?ouIJFNol I In [2?on ?gum. '1 H, OD - ?imam Emmi: MS i?ntUgLid 63mg; ciao wmwmu L0 40?an 610m TQK S14 M, cr-MH, 1 mamas 39% 13 36751, Sec Monm, Tour: from} .. PB: 36% T11 es: Soc: Mew": ,auupe ?Two 3% EGGW 15 . muf?n?, owo gas-2m Scum /l 7.x Eeew Btu? cq?wwr', noucr nm?m [aged as?: ?r 1" :re. it NAOMI :nm-e 2 3% Mar-w- 2w MW 1.1% 3m m. mgam/ (Mew, Idiv?dad??dn?43rd? Page Tow Amount Fatwaru l: mu to on. 725-15, 0:3? \u (m so mu "1h Case 18-2868rDocumenL278, 08/09/2019, 2628230,? Page384 01?648 Due u-19" . mum manmunon Mam - Main Allard! Points 91 bop-now 1 Arrival Flat} Ian-kl. Dd Number 5 3 5 2 Eg 1?77. mm A 8421,31 N?w?e P6 )1 T3357 Ame-um woe/L mum?" .13 6 A 9:??va \l (715; cum-IE; (LL LH 57:9? no 1! Gout Wig??7?- A . 3?:qu Laws 5 951 3 2.0 Stnuunuc M991 Los?1:955 Ok?ww?f?g aw me G??ck?r m6 c-n?oxz Fate. mum?m 5mm 0? :umms'mm, Fuel. dump/ml}, sun? 6:05- mm ?lat. 43;:me 6, TWO em- ~I'6Mmu$ ?M-we mam: ?mwn?nf?? gcul?, Apuft?f, km 7. 1.0550? 0&3 mtg-ruff, 5(4ch egg was or oc?em rang sum nu (Imw ?4013' fka A 1066 sutum-At?hf 2% {arm/3x N?oge? PG ML: C10 61167716? . c? gem/yak 1f 9. 961 cm Jame?! UNI-5 /1 mw?aMOQOOanaNr WA u! L/n VD pal-'7 on mbbmanm CE 991.5 Amount Forum [5.1 Plot?s Signature - -.., 3'57 "815} '5 '5 H1 Cas ocument 228708/0912019, 2628230, Page385 of 648 Nm? wake Moran Modal ldanll?uubm Mun. Qoo?b Polnhd?mlm?vd muo- Fight 7' Nunba Alter-? Gum: 1?21 ?44749, ?549 (H (00.08.38 a, 49,? 96L :9 2 6.72:) ?og-5c: 2ch L699 0 7 LFFG a; 66 CH: S?ic'? 5" u, (:er an 3916?? LFMN 37?9?? 36,6? 5% . /l 13 mm? 15?} Wm? - - M1 - \fwa mew?H 295:2 k1wa?SMM? eh i 25mm! wess mum 0 v18 0 Miss 0'1 0) c6 mm Yams" 10k ?Car OMDB 13pm: E??w 30 l? I. owe mes '51 533;. u. . mNdd'Jlj-m 5% m: mm 566W 6147M) RePosMrw I canny 1h! lho Manama made by me on 10ml an flue. 9.99 Tom (9/1 nail p?mdn 1 Amanl Forward 533' .3, ?635 h; Case 18-2868, Document-27%, 08/09712019, 2628230 -Page386 of 648 mm mm noun. 0! a An! I 49?. and Mode! Idan??mllm mm . A A Numbar 1062 Fm To of i Nqo?ixe ELDW JFK l/L ?2 PB): n. (335% Nqoqmvm 965 EM ?Mf?sw?msww H4 B-?WZ?Wlmuqom leg; Bog Ravmm? \1 Lt 03 1 W4 313,?,qu wag-5 \g TIST ?1 Mm m?smm? (Waco .- T615 m? 391 2: I We? a INFIDENTIAL (Pravda \t [ma-.9 QBK Re?mrmw 0/0 Z3 952: MYEV ?e?isnnu Mom 0/6 I . 1e 9 Tu; ggaag?littf?fm 3am 1/1 z? was ?rm? 1m 35? 6-in- gnaw Wes-e 3.44 mm us z?xw DNA pam- O?-W?vh :glw'f-t. wuz- cr-nu- Iz-Ubw- Mm?: Mamzqu U. 1?1 1-1993 mm P6 lle 3?3" 3?51?? mpceamg I LFVB 75? 0/0 55 PanaTohl '1 anal] 02/520,110 Egg 8.6.11. Case 18-2868, Document 26-2-8230, Page-387 Of 648- Duh 2.00.5. Ahm? Mala 3M Mow Aim-aft uni?cation Mm Paint: a! Man I. Arrival otLandnga Sup Fm ?o?oje \3 v' 6mm GMNC emme LLPM. IIHQ L901: Recy- ram-?oat, ALXSS m?enrvc 6 meme 1 PCS: Wm? 1 .GEWNFIDENTIAL (I 1?5. MLG ISBLI manque. '3 \7 mm 3? 13166? max. 001' 3/3 ?LbR?o 99?S%Tfmodb N?lo?b?? SM m, (?Fm 1851 . - -- . RLrutz (now a ?23% 'quue 59? 3G OMS (no; nowm \l [169 N?io?m? 19m: Aze?? 8'31? I 732% '3 sawmzran Remus, I ((7th Jasxluwar Laf?cZ,Ni'ipN Dora-uro- 9 90 r: ~94 Casal8?2868, Document 218, Page388 of 648? Nwrhar Altar-? anthxu Identi?cation Man: Flown No. . Hm To A mum $918934?: (rum. 6317-24? Nqb?z?? LFFB ?3 3? Le ?~LFPB 19K 3m . 961*; \3 fed?; WM: 3 511.?! ?35 "$68 GER my?? BED muss it "1'66 2' 11.. w; 1' . TIST WW9 8 4m Dare 3 v. urn we. 135303538242 mi; 067% \371506; (SN-cm] Ii mewm 0 . 6, a 4: ?9.07Rhaaluib/g. m, -. . cm {was um mam? 911 050?? L995 1 \qb?We A5 NSOW /l Panama 5/(2 Mouchmm baa; $3194 mm?b 31%{Qm6j11/ wan-o- 851?; 923% Natal Mm Ntu?ak Foils 0! MG MMs WW NFIDENTIAL ?deN hhfr??r~ir?n?~xfuo?mma3 sofa? 01? $5 579. _Case 18-2868, Document 278, 08/09/2019, 2628230, PageB89 Of 648 AV 200 1. Fun Dal: ma Mm: Aircraft helm: at boparluro a. Arm-I Miles Hm Nod-.3. Nunbev ard Model Idm?fbaban Mm Flown No don-maul: Landings To I Alva-? my own cu?? B??b/?ur Nqo?x? . 6 EGGW I .L?vm?h?gz?e?w Lgp? I NECK. A ?217me cM/?rm LIPS . l( 1 3 mm?? ?4?1 mil?H emscm (3'61 (I T86 1 Wmaahmnu? Maw? A ll ?48 millimetr? PVG 1L8 5mm an? ar?onemw St. 1 06? H500 9m 954*: 1131? lA BMMB ovmuv f1? 98; ??6??mm3m ll Sin um-m i Vanni.? suw 34.(1,411 ice 5.: muwrvt (3 (a \1 ?3 (y-Hscm '54 0?11?, WET (5,2425. ~43:er Dr! ya LN: Lem? 00 .- $.50 T63 But.?- Tml?x551'31401, 331? mecw i?cgtcem. If; .u :33" gut/INL- Gen??2 Ltuctmr mu? homo/mg? ?3:15.003 . 1? CH 6 at. ?t 11414;. 11:2; 03- DU. LL {83? 33km (1;:me 1mm? :35? \7 TEST ?.5170.? . (Win-3w ht." (if-cum? 131 ?70} 0 07462!" Mr?T??ww I .7 i. 9" ?0rj, 16Min?. Pogo Tow 71/5 37? Amour: Formed (3958 7.453'45 amaqr?KJJ?Dln?o? f" (A Case 18-2868, Document 278,? 08/09/2019, 2628230, of 648 om mu Make Alma 1 mu 01mm mm: mu Hm I Number mm: 45? am Mona! lawman" Mutt Flown No. ammo-ls - 17!, [Tm To D. . 1 (Adm?1 ? P??wu- (95 T161 L030. 3'34; aid-7? rgvvag 1 1- 033m 1 u, . Lu . Mu?xnyv?nw 44 . 17 1\ Lag: .M In? .18 UUWW 3L- ?:va 3K, (Mamas/.13 .14 f? ax?ANma?rMn?wsui -- -- f?v- fs?u'EK IN I: ?t?d g~ (?3M4hnry. Lita-Maxi, 2.1; 31" - ?39% 14 W311 -3 W1 Egg-M33inmk. ?1 PM T15gnowreg- (1149'ch ?Iv. ?13m 'n/xv'a} M712 numbigi?aqwt(HAT '17- ?m cm . wk ml Maw" M31. . $151 (LET Ma ?391?:va 1/ - . (NM . L1: aa?b ?3 . ,cw?w L5 . 951 $6.13 . \t ?(as P?i 3191:?? [3.9.1018] 75(3 ?2.75 3? ?0 INFIDENTIAL aha :r?oo .f Trc?r .1 I'w-r?M'nTj'Fi?i? Amounl roman! 535$ . 1.x . r7 . Q/Ir?f?lzbv 1'01" ?0 kW t! Squ Case 18-2868, Document 278, 08/09/2019, 2628230, Page391 of 648 We ?nd} mm mm Mum! lam?limlbn Mam Points of Dip-rim a Arrival TO .. I Number ?on? cl ?new: SAN Fm W-?ss?w NC-wme PM, drum up 6.180;? f? r. 5m ?chv-gi?ni fir'wzrw N?tu?c 2; :Wm 38? W3): ?q ?Mm(34' 25%?851 WM. 11357:? It P81 T15 DI (3mm Q?vnwm.? 2mm. pgv-Mr, mewLx-?fmg. (mama Nam-{Ia Pm". \l 36-115): mama. Lr?rwvw \?us (.7: Rim: 0 ~an 2ch ~31 wm?c mocnw B4111 rm \i ch?rgc: 1?90? 99? 1P1 nmenqL :mv?ON P61: ?mi? . mm-r. Hokww~lpnr?mt a! Z. 2.. A ??71 Lt?g . I ?r mama, numb? mm. .. . IL Lem: L't?m 1761 :m moonu: Mama: 0 ?lm 'u 1 in?? V1 \l GI (Joe \?MLMW ,Wnru-c mnkt' a 1 PER )l It CE): P61 Lm?n Mm 1t '81- IR. 332. 15?} N, minaret-e Wm: . may,? ?x am? b1 9w a mum; new mm; OMUTQO Lug-shack epTRf?? 1 f3 ?Wm . Din-? .1 ?345' (at Amount Found 3535: 'l .J (.4 . Case 18-2868, Document 278, of 648 Date Ammo Mam 1g and Mode! 1065 Allutl? Mark Point: at Denm- I Run To Mica Flown No. Flight litmus Ian-ml . 1 Number [mange IE per; N30881- BBQ 9.V1. {5411,100 (ram; 36!? Le ankumw 329 LCL \8 .LZ?Ll-Jcaov - 13651;): gmuik?v 6? Tamar", swan OW "Aydw 5! WM 1&6 WM 9313" V4 8 T66 '23 .PSL Jab.? .SK, 3th!" ??wuL-L (J N51 037?: i?t at)? va I- L?cfrm?j? ?11 't It Nb J??z?yllc; Loki, 1137599$ (NHL 6. 1 \qo I. {216. L695 Lua mucL - (Ho-u Lb (x a! 225%}: 2.113%. sue-{La 6 ?rm?Now Imam? Lia-W ?7 Pilot?s {Cf/deg?; Pugs mm gmxnembxag Amman! Forward Total to but. r12? Qo?u c" H3 U) . DNFIDENTIAL Case 18-2868, Document 218, of 648 om Anon" Malta pom ol mm a. mum I andundel Mart - cements oHJIm'ngu (329;? A Guadax km {5111 Meme 0(an 9 Bi . 9 $237 . ?3 ?13661 9 CM T66 3e,AL,5x,6'r 3 p? Kl EMMALDM ?3'3 L: If ?If Nunbac f?g?w 1H- '5 3 BC: \lN?f K3 Ezm??mm \?nivi Len '15 \m?t T488 Ima??'?mm? WV 3 . 1253(Duane-p5 ymus', fro-vs, 1 . mazmw?mwzm - (L00 I I NO ?ma?a :Ecwgu?g?n?kwm - NW is? TEST w. %~1n'3m N?bast TIST 3% 9? ??25.pr 3 Pas-Tom 4/3 3] MIMI mm" (213% cm"; ?3 33 H3 1? I byOldjad? d'if?. f? f. .4 . :F?g Ln Case 18-2868, Document 278, PageBQ4 of 648 I - . .. . - Dale Alnmn Mam Alrcm?I Points 0! Doparturo a. Anlv-l Mum Fight nomu?whoom. I ?uni?? 7 19 an: Mace! Identification Ma?x Flown No I :mw c-Liosr?l \wcmq {13:12) a? ?1 e- 51 Leyp MB 7? Lt: mo 3 9* qu?ln?fm? Mi mm UEJMJEB mm?) Ethan?e . gs): mm? Isaa??/?Gf; :w'em - 57 CQNFIDENTIAL ED ye; AM, Y?is.? lum3z?m?v7?' L1 [um/?GM Til-5'? 1-.ng i . 1 1 N80813: Tifuf - @181): I 9m 'T?tf} 94.6; T56 EQUL nae. (1.013173, . CW1, P?l? mm' ??vmw [0510532 961: - 2m rib/?MIG?? E: 8 39L r1023?! Aggy-?16'] bi?, (513mm: L. N?oqjtg PBE TCB I Ta?) 981 lmts??-?WW 0/9 055$ 2 i E62 \Gujfl?53'wv Tag - ?Mk? - lcer'Jty the! Ihe matemen?ta trade by me on L519 loam are true. p3939231 W1 . "p - . Mars 3mm? (M1110 {gr-:or.- ?5-11er: (A v, I-) My?, .2. It?mwn. . 2; 07301353: :3 jaw? 00 33 5 If Case 18-2868, Document 278, 08/09/2019, 2628230 Page395 of 648 Case 18-2868, Document 278, 08/09/2019, 2628230, Page396 10L. moi 9?3973- 161W ?Lew~73: $91? .1 lib 71/ t3". 1 - .0 0 W2 *wun?czgjQ91 90?] sea?NM] 19 ?n i? I I5: -L?nvtm0571, 993/ 99$, 7?33 ?7953??. lo 111.] )er 3 :1 (ac) a?coohw I WL'ygv? {?gs-6n037337'? 1,391.9 J1. ?191 4% . 87? E: 10 a} TinaN . @0905.7: @175? 9 49:1 WS . .. a 31 \tnU?57T??m71-I? 1 ?1-53 SELL ??9.05 -. 109vu?j?od aQ'v I vi ((413: 5. r; 990000 80 2 9/9 . Argos; 59"] *3th . - 5.933. 196 1 I h?L Xs?w?) . . 14nd - 5 5. ?$2.00le .r 5i hm.m (mu mm: Lg?? 19341 3 57 9: 2.27- E04 .- 431 v.1. . 0 'lr'gua 1.5; T11 WJ?A?Ju?tunm: M31: 8221'? Innwv-loanuodoalo tuned WM 7.ng man 4" Dun: Arman Make II A'rmn Palm: of Dcpavlurc a. Miles Flluhl RanaI-Iks, l?roouluruw Number W3 and ?u?CdeI IdenlIIcazI'on Mark Flown No. Mun-emu. Mum-nu u! 13an La? Fm" I To ?1 L, szywumw, )jpr ?gf y?w1 4.2, . LID lilIrInx Java jauhg?em?g?amm "4Cn?f?i??l' 1/2, 6 ?5603? [106me ?wen .. 23m . Li 30' 17:33 PB): 4?14; $1?ka Pm) 0s- era-g To . 115: LID I IIGMJ I Lf?mm - . I I man we? mes-W I r?.Z <5 i mm goo?Nrcu? Cotonou. CONFIDENTIAL LMIISCIB Mom T86 ?g WI Sewn? . 3 I I1 [Tmf T1{?{35:0 - I. I123 I510 Kai[913% ??ashc I 2i_ MN J- an 911933,}. 1\ I $1113): mm. ruwxw? .un 1.51 Law AL .J) I cenify that lhe made by nm un Ibis ?01m are lme. Page Tcdal Slmalg?LJ 1? C9 I15 A (Z): fee-(Ii; .. . A: Arnoml Tali! to DIN Case 18-2868, Document 278, 08/09/2019, 2628230, Page397 of 648 0an A?crafv Make Aircraft Polnls of Dopudm 8. Arrival Mics Flown High! Run-0&3. Mcmul, Number AI ar: Mode Mam No I ?imam." 0&8an mt" 091mm? :503 Fun 1'0 Az?tpuj?; eLLne ?501 0_ :31? Tee ?,9th 5? TO I a, i 2?0? 1? II [517 2; ?rm?zII-I 1000837: :35 9?"2.511 - "52> I. P6: gm; 1 - ?-30 I 1' I a ZS (?(21952 1 117- ll: II .4562? 22.2 BM (la r, ?60. I I 7:91? 22] 228 'i CONFIDENTIAL :l 2 1 II . Sv'x I?m?Mwh AM I ,m (?9be N1 I 2?1? Laid-u I t? II .- I .SC: ?94 (>13 my Inabm. I HEW ?232: pmj?in?v '5?th . I - IdsAern SA 08 ?two, . m. I lUUk? 1699 Lam}. \1 ZBAPS ()9,qu I1 520939124 - 44 J11 3 36K ?1 2?53 1? /l I 394 i FBI KIWI. I.C. PM THC [75-21?92 II. .. [331, .?Scm?x roenl? the! 1M statements made byme on Ihls 1mm are hue. 1/ Page Tulel I i ?111-1 . - HHoisSmaIuru 1: - Total to Date b.1314. [11?35' 7? In,? 'o :j?x r3- 01m Ln 3? ?Hr. . 1' 7?35?! 212.01.?. air 9.: 5n imp-{cam 1.2.r?derar? i . V) hi Case 18-2868, Document 278, 08/09/2019, 2628230, Page398 of 648 Arman Mass 1 and Madai Mark Aucrah I Pain? of Departure Arrival I me 13in) Tu Number 0! Abua? Gimrw- macarg cm? ?rt? 73'! 1L 2 T253: 15] 4 P82: P81x1134. (A A rm? 9:11:53- Ahmed?), V?z?fk': IQ, I 321,51 .15- 3 6K. x? \3 .34 (ST 63.13. CPM Luz-9'! (it "1v besi- 3 *1 "251%? :32? TV a 91ch law \k r. . ~12. - - ?U?f?l?mti? . ?aw-3m. ??uxgqaw- .C CM Pf); 1 My? Ik??l 3 Kym-V3320. Viz?m'aqug?ia; 3g I be: . TD L?W?jjl?ej? {?1215 I 3:51 ?Tc. 1?5 v97 15551 3253? 6 (.5 Tiff? )Lgl: M9299 9?3 g: PET. J?o?uo?hm mow ?Lv's nH9?M??~a, LV Gm' - .mm 1343p! M?N?sw ?zg?mm?f, my Mt: It: in NM Max: 15?" . ?(2:133 [56? 34., an, 2mm, 51, PM 36K '7 [6:10 61 LB, 5K LU lb? 34? {ream-n Mvz?si 5K [\zjoajc P81: 5H 1 I PIN nqz?i? H10, NM Ly fooril?y ?ml the made :me. (TA: Page Total ?0/43 I Anoun' Forward 17* 1 Total to nu. .. .. - -- jls' chm-k? tor" l?1< ?Cw-?g I 2? 1 of ?h-?hg e: . P..- . again . . 2 w~ 2. gs-- n: air. -. NFIDENTIAL Case 18-2868, Document 2628230, Page399 of 648 Page4OO of 648 7 1 010000110 2: Case 18-2868, Document 278?, 08/09/2019, 2628230, 1 - - 1,9, .. . 8?83} bw??git? out: ouuo; r/V?ypw i: (2 STYQ '13) like; 5 ?3 5 [dam mgo?wlx?m?wN?a?s?QZ 593 I CE.- ?95, onus'wN?wa'"1?57; ?83:3; .C 0 9 M5. 1995 2 i ??93 1?36. 1&1 5 mu'wN?aL'Qwr?wO?Wa?h?c ?55; [9399 LY 7 \of) ?13. Me?ox'u N?9151'w9'acl3'7'5 . 1198 if L- X31 ?33:;th %qh?L 7? 57., 'xsuwmg? 7% $93: amow Nun-9 I 9 ?909 ,3;qu gd 0/75.- a: mums? mm 09?? I 5 . WE -993527i (C 4"}gil I 8171- I 97 ?Ml 259505?? ?32. TC :o?aia??sm??'?afv?xs 'wM?Lerniig-hu I 7?2 3 I WIT-H4 11mm? ?(16:41 gupuawo wow 0; mum mow are "206*? "Worm-o 11.134?! menN ww' "New ewe ?g ?v Duh; Maxu M'oratl Point: at Dopadm a. Arrival Ml'ea Fli v. . Run-m .Proclduru Number Al .7 Elm! "61>!an Mm NO 0' Lond?ngu '70'3" categoWW: 9931714 We mu (1 or To NCN o?lfGukxw 33 Lw 3560 ef?gy 1: gap Tag - L- 11143 If . L: [@Bf 5 ?38,105 65773-10) - W9Y4Hb1?wui. .5 . \xl . Radar/vb- LnaP-w-c ~24"be 554%; . - mm?: - 33Eqrp, (3f: A . M139 - wafmm Ga 9 198$ Pg?: 4 nuLm/?k??ONL LVI 2n P81: [39? 1.4, sewmno, I .H -M 1 F79 .751 153 519ng 18831 2% 9m mega? mgji?g?ga LIHL V3 C117(ac-so m: Jeni: \q mg 73; mm 56,61, .AawI?Qet LV ?5 Se, (-31 Mm?? NM :33? 3 I 74L 709.1600. cm? . Iccvu'y haunt ?elements node by urclrua I Page Total 9c? ?1 . {mount Fowrd 53.15 Pm 2: Sigr?afugegivctl 1(<51 Toll! lo Duh 1 ?5?39 (1H3 I 13"; . D. 1 83?03:? 1 ?33;le fr - 4 -. 12-, PEN C1 CC: 0 ab?OJ may: .39? I smram.33 Case 18-2868, Document 278, 08/09/2019, 26282305Page401 of 648 41% Pom oi began-no l- Arrival Ramada; Mowing?. Mum adoration? famnm 10 Luz MM, SK Alma" mama (yum - - NM Wm?! 34? SK- ways/M34, man/M .651 Cs ??48 RON 543$ 3'32". 0}de j/mj {i a @mr?hh! not:Se 0? '0an '1?1'1 4? {may Case 18-2868, Document 278, .44. ?rpm TD 21? NASA-K . ?th?:La_ BY 51kg wold: Wm Ii.? JZI SK n. . made by me on this ?Otrn ue lruo ?p . I . . ?3312. v, -. 'v - . Page402 of 648 ., . vs?wm, ?2 0am Aucnm Pohh of Doparlm 5 Arrival 'Mies Figm "mm?59:1 andN-duc . um Fm [m N9 ?smut? drum? .. Imow mn-?QNMom) E) 51; LY Vr?m psi 1mg 17i3r?m? a. 0 (MW 1 _g 30? 33:5 31 miima, 37- GEMS, Wm: t" 1 ?3 ?3:373 '34 mo?m 4-76; 11141138,,05V121 ?z?kwl NM SK C: Cr: 11214:: seMMw on m? EMT W) 2531K K?S?fapwze 73Gb NM, SK 5K .3ch?: mam A 758 HEM CONFIDENTIAL LIES q? A L4 95C, PM M5 Tm? 9&7: 17? 1? $7,945 73; . I d) (4 ?451;; 1" 1 [9:95 2:7" 2" SK 513:1 1 1. ch?Pr 13,; TD 45% 1 I certify ha?. tre summons made by me on Ms lam are l?uu. i Page Tom! E/u] 5 frnnum Forward t?ijici {rig 25 441-91 (7 rim" 3 I Total to Dan Bid ict 3 Case 18-2868, Document 278, 08/09/20191-2628230 Page403 of 648 . .47.). Dale Aircral: Make 7 Airual" Points 0! Departure I. Arrival Milne ?lly? Rom-yin, N'uganzrh l_ Allan? sxrul \Am?q IdantlliraNnnMam [mm .70 Flown M. Manama?. Itdonomonu .aw: amt may 42;??lth? 3" Pn?r?mmw - . - 0'0 \0 44 PH): TKK {-83 53?. 330443;.? Q?n um 22- 3 W4-5E 5 Aaaccuuv?) (-Lv'rin, LY3 :3 3 3,33 333,3; -4 r; 43: _4 4 CONFIDENTIAL IE LL WW I VNW 33303{.61 76': i" i sew rum 36394.1 twa?t 3, 37481 1m ?0 . . 2.. (3-4 (1 {5 E6 $3395173-3 TVDT ,5 9K 3 9.41013, 323%?, 5330 ?mm??i'lu? .13 3b 0 8: 3 1333 ?54) .5K3TK, ?2 1 . If 1- A_b ?10 333 3312(404?7 "1711?? ?56 gff?i?'u?n LL 0 93-35%? 1 (n no 4 . 15:51 f? _1 3-30 V- ?3114.134 . ?1ngm.JwW1mrw7?v 1? ifInn-5.25m 3m 33 i 323.9 . . L?v L) H?s? 032.0 J?grr. 3" (4:524 1: 05? I I I 1 Var-cemly Unl thu made by me on this tam are true P596 Tom Amcu?lfotwafd till (3:5 31 kL [2?33 Total lo Data :gaf? "313:" 5 1093'!" ??rm Case 18-2868, Document 278, 08/09/2019, 2628230, Page404 of 648 Points 0! Departure In Arrival Mlles I High. Remarks, Phoedun'o. Number Alma" Calocorvm ?own No. faanmun. man-mu of Landings ?i8; 85m in Hich?m 036:; a 5?2.9 T. I MAE ?w \Noaew 91 I 1221?\ 5346243 'Iw?w 1- 3 I 1 Ln 8.. f2?931thm? LV CONFIDENTIAL 00??,ng we; 1 Wyn: um mm; rum. (Man. vauum?r [150 ?rr?g? ,5 K?x PIP: 1\ n, tramIn?zxa, Moi-1m? I nen?y that me stalemeMs made; by me on ll Is lonn are we. 4? PA!o?s Slgnalurda'luh Dwe Tota' Li//3 I Amounl Forwad 7 x) f" To" #6033 0?54 Case 18-2868, Document 278, 08/09/2019, 2628230, Page405 of 648 Total to Date I 1 NW Ji.) [i=3 74? a: v9 -- .l 1 Ntmoat CHM- mam mg; Due Mann Me I Moran new a nap-run a Mini andMouu Immazm?m 20- Flam [To L's-mew mmse 16.93?, 19%: 2.0 (542.19)? Wheat: Jema?uiu'i?ax 2.0 .. 33M (?61 2.2: 21:: e-wsm Nqocm?: 2.8 e-m?w {001085; . {5-121 ace V-I x} - .4 u! ?mm, mt 1/ . L9 a? gm?nm?t?; HANK. Couut NSYIQUCTEIL HPNK cw?; wmtvum. WW: fifty Amman. 1T5. \mS?-psv-wmsn . 21?} . NFIDENTIAL DR _000076 r491"? '4 SK Ntimom Txfn-Lz?ls-Ws?? LV ?30 1.5: T107 Lv. N61613: Taft; vgmn?w a 7; gig _Tci8 use mm I row 5 \f 32;, LU oenily that [ha summons mods by mo on 1am In true I Pugs Tan! 7/ 1 1 lAmoun! roman! IRE-1, .. l?r?d?hm lTohHoD-to qb?? -.D 0? c4333 Case 18-2868, Document 278, 08109/2019, 2628230, Page406 of 648 Date Arum Make Mariel Identi?cation Mark Marni: Points 0! Dopnturo A Arrival Fle Nunba' o! Lmd'mgs 1 qu mm? Cad-Low 3315:355qu 8? \?st 0 L) (:st f5; Ml 6 $173-$115 3151? ZL A I 31.1 )1 ?(5.51 . NM, A mama360M, mm mamtg i a mpmam?w.? mi .1 ?7 -2 Lb (3556156 Mid'h??. FM 236'? Lb??i 3?3) Db?) . 5K 955 {4:16 Ken C, (sf: I?q CVO np?iES?SurJ ?Wm I Gan-m 96; 3.33 Btu. 1w JMDW 57 EM 1 I I W: ?t?z?a 5/1 6mm ?Loo .5 l: mu who: M39 ?ow time ml Mmmw, me. i \e no? amp. . NW9 4mg)? Eb: Spud D3 GM Rm?w": wane? 3m We?l?o?efmuw (1:9.wa um, BMMUNW amEcenl?vy hat the smements made by me on [hh town are me. Q: rm DJ 610/9. Pag- Total Amount Forwm! .L In Dan f? 1 Case 18-2868, Document278708/09/2019, 2628230, Page407 of 648 v23.- 0. actual: 9 . . 5.01st Minnow-530:3 a 1 r3. 33 um. 23? ?fez/.03 .. . Hfoibm :9 1?:36. a? H, :3 a 2 F17) .22 1-- $022821? .535 .H 333 2 on r. qr?. REES. HFDEEBZP ?aa?av . {Iv 37.2} h. .1: Lcabrtva? r4315) EA .r I an. 23:1? .0 a a .7. ?n .3. 81w. :El MR my?? 93 .23.. .vm WinLP. ?Ncu: Case 18-2868, Document 278, 08/09/2019, 2628230, f; '13 A I v) >922?- nrn?rmr? WE Xr? 3394:? i .0 .mk/ . 5a 2.3 23033.? 328 5 :6 a: 63.wLniub? F. ?8fo . m5 3 Page408 of 648 mir' a. 43.. Case 18-2868, Document 278, 08/09/2019, 2628230, Page409 Of 648 . Q. (7 5.339 rm . - I wave-we ?Mm 4? [47 km," jag; W2 1 'Gmlmunclmuuoow?qenam :07; mm c197 'er wa 3 TH 7. H0 N'wa'g?o' max gel 103? .. 32;, 1c; -071 - . max 103 m; Q. i I am i911: gyi' 71 L3 90f]? 2 433. f? 90:33:12101! )(Oj 9971,, - 1-97 WN W712 306 .x [?22 AW jg _u - 15?? ?0 . . 2.2231222233224va 50's 0172 c; {a (49 $ij $310023 Sgt: 0 Irate H8 WN 32$ ?21 ?3:214 ?8 '9 H9 8932 1931 .. 5,7; :1 H0 1,102 0:1 I .. 2; cmuw?u? .. .jgf?ji; 1703??- 2:5 610000-80 mmaamm?? . 1 04:39: ?Si? ?3 . 23771:] 27" "Of 1 ?3 213,90 "-75:52? gm 691 29:1, ?m . A 093: m?WbH?v 23;, Wismwm A, ., - 30-2 35?? f? ?Medusa ?"341 w?qum'n'N I 33:1 unplviaumudquo ?mod: "mifgg?? $43332 if: a: 9 Sale Almra? Make Altman Paint! a! Dapa?uro I. al M'l I'll '3 A I an! Modal demi?mhon Mavk Kai.i I Number tun-'9' I To II Alter-ll 0a! 0 MIu/uuvorg IEndonuuonta mummy; ammw (Janna! Ha. V?l?l-a (Ir-72:: 10:3qum: Mie- jib/?8? 32.911? 'Tfm? QMNM LV 1' . . - L196 AM 33 [Tag (5CD 1m SK SH - IBHJQ 214 .1, 6:3 sewon?uiuc. . . ITIJT . 18(9?5 . Ir. It) 3 2.2: 1 A (.IMBH Nana MM SKmumnoQ V1 Ith .NM. SK 1.1 ?519 was? JLAAM NM Er 3 4?56? my?) 184 *3 AM NM 1 ?54-111 ban-Lt . I I i Zr): . A TLDT NM ?3 1m! 3 '669_ 2 [3639 0620 has 0va 'anlrx 3? NFIDENTIAL i L, A OCN (569 m; GM . 6L0 ng_, 1037 OB '3 ?gs-19.14313 J?i ?7)?sz '31]@2253 Um? 3 'ccni?y Iha: :?uu staIiemenls Paaebymc on VHS lam arolmu Wilma! 15/1ij ll A 1 091.: . moun rarwa'd I l?lbfs Signalue (Ltd gin" A 9'14, I I, LEM (l?c?fab?) Total to Onto '1 LL L?At?oo 13m ?74 m'vc Case 18-2868, Document 278, Page410 of 648 ?vi- 3 4% Data Aircraft ?rm" I Polnll 0! Departure I. Amnl Miles F15: ZN, . 3h! Rum-r uProcedurc .9 and Mode! Ideml'lcanon ManMonti?? ?nder-1:91:13 ?nalizing ?mm" (30:090" 7? 4 ., (54-152 ?5 1. mm?! :Mu cl-:qu 163-3 y??i?Tx?x? T6413 Mu? AM Wk? sv'M 5 3g i 9&0 .LV. V, '8 D. - Wm much W, masxs-owm'z. W: m, 1 o; CONFIDENTIAL 1 I: (.va L3L. 15:: Lv '2 '4 9L0 T98 Li?. L1 1W war 1 ?2:3 t??x 7) lbi 5? ??90 I 7:31:35? Sij'f?o (a Tmm.? TI 3? 2?35 mi: N: 3% 10, 2.. '1?ch 336 Lxe?g? htgl?h'dmixzi?: (CHI): 44 3 3?141335?1 P: N?susc 12:8 Baa: :euq ?mmwn 4 A 0, 9&0 NM 35?? \l 33433?9wa EQLW 0 3:7?:qu 2 oft?PIP anoiwLmuom Wiggly ll - . I: I 7? mam58:00 T157 39-; 56M mm?: 44st svmheitsi-V . 0 3:53 312st: ISL VV 8 MD 2535)? . \l ?93 scam? . I ce?ify Ira! the slatemorls made by on this [am an lruo. Pam Total 1/{1 551 I. (FA -: A100ntl-ommd ?3 1.1., Plot's Sinnanmx GL1 7&3" A LA. Tau! Data [6931 ?7.4' . . mm?: Irma Case 18-2868, Document 278, 08/09/2019, 2628230, Page411 of 648 Case 18-2868, Document 278, 08/09/2019, 2628230, Page412 of 648 is I, 2: 1mqu bm?l (C, 901363) WI 0E ?73 ?-my=nmu7 20124 177%? L. 9W93rl7?r) nnumjwz Lib-I 913%er 50'? ?r11 7?5- .- 49? wN? I. Ls?vl Wm?i?fuwv 711$ 12% '33, ?29" .63. 191? 7Q Rue-9 "meo??azg 1M6 I VJ WW 2010on "a '1?me 0N Wd ?sunpaoou ?9qu #5115 3mm @mxu?0pm mueumulu ow magmaRETQF mag wen Input 1 emu-doc )0 "de 1.2mm SUOHOHJISUI .1 I Date 1 Aircraft Make Aircran Polatsofoopmun 0. Arrival M993 Remarks, Precaml. oN?urnhre' I Alrcun 49? 1 and Mode lden?l?calor? Marx . ?own No. Maneuvers, Mun-en's .. i Frorr To . . . . ?Ef?gy; - 174?6 TLSJ . Egghb?ms? \156-?127419 1?53? 1 3?1, 3.5?5? TSFK Ben ?ff-3T 737191105" .r 25 ?g ?407 6P ?gwgf313?)?1311 Ba - 27: ?8 . 1731? ?mama9:8 ki?se??ym?mww?n 1 LV . .. T1251 i -. . 20 (b-?l?Fsm N?ioare d) - 'zumWiW?vaEv-L .. t'wMtECW--nm0wm I - -: tm ~r?r .- a .. mwewmww VB ?-sawm?, in H, ecew .n r?j't??hm r'rtorr'm Db 4p--mm?r?c?r?w?5 I unity that the armaments made by me on (N5 than are ?ue. I page Tcta? I Amoml Forward $32? (LVN: lc? Qq . 3 El Pilot?s Sigm?urw_ Toll '0 so ?32 c? A Case 18-2868, Document 278, 08/09/2019, 2628230, Page413 of 648 squmsu; I On: 1 Air-rah Mew: Maw Palm; 01 Manor. I. Arrival Mllas Fight Remarks, Procoduna, I Number Aim-n and Mom Maw F:own No. ?Maneuvers. Endonmolls "(Innings rm re 9mm gamma? - 33;; Ewan-am Naome EGGW gigs-8521, JFK 38: 'JeiastKf?f?msmT??E 3, mica-?sac, acme PM 1:55 gimg??mmom $3 313" Ewe '3 - . TAG: EQGW mm {?wwth? I _n .. ?ggew Leis-6;" m1 GM ~25: p.615 me GM L1 1 . EGGWJ 3W V1 UT ?11586. Ht? GM NEIDEN 2% -W 699? l?b} 30?, ,l i0 In 126993 (1?qu we!? T. . 41 Cjax_ How GM 3Wl\ 1 27: EM Mm saaw?m??1.ng 3?1?l #5319 Case 18-2868, Document 278, 08/09/2019, 2628230, Page414 of 648 wromwr TLST VQQ a I it}: . TIST qos?mxgz?uijgi 1223.). my?, cmwmTE: ?401338 .3 I certify that lhe swtumorls made by mo on form are lm. 3? Paga Tow] l1- $7 Amoum reward eggs-Bu ?g Oogt Pilot's a?QZl g3 ?Dlobl kn Lag-?2008433 oLn V3 3,3 3 3 ci Aircraft Make and Mode! Nrcm?t Mat Points 0! Demure I, Arrival Rom From I To Flight ND. "marks, Procedura. Maneuvers. Endorsements N-ere: an?ngs Abate" ?wmm (,qu (3-1136! 3 #8360 was GM TCB ?1.51 \l . A4K6U9, 69' 5436mm MnmxudeR L97 0R DFW c? new I. khg?l - magi-1: .Jm?ui?i?bft 3Q. WV ?Wvagus 3:2 Lam: cal-law Magma LU Mum 69? meaE??-m?w tww:. Grog: 2 nix, ?mam ALL O?mci 2' 92? meg, g?w 610835 . ?wrg ?892 lid, Lice Hwi?j?wmz?an Km?: 9 Marten?z?). ?pvr?fsrx I on Monumw?v' 61161-4212, 5K IWMW Kb ?(aims 621% 1. NM Ive. ?moo ?7%!th 1 $9 - @x 1 Xmoncm FXE ?10 66V Alt/L 2211?? ?3010 117-1? _sm MILR JOE 5? [5 LM LV Tol?d?f?m- 3 . (?Aon chi) 7523?. NWFJ WED-CAM Wilm- LB i \b (3-0586 'N'?oqszc? 115T 858%??71m 6WD 213/1! ?yaw - galQueen.? mg cm; WM) L??aun-r 1091 ,mm 635mm Ncib?bj?lTIST 6 Hamid M79195 3%ng oars-M0; 30ml h??al-J?bb )3 I comfy ma! ma ?moments made by me on 1011! are twole?s Sgnamo 4/ W49 Lawn (ucMDr Pug:- Tctal Amour? Forward Yotal In Date v, a Case 18-2868, Document 278, 08/09/2019, 2628230, Page415 of 648 Case 18-2868, Document 278, 08/09/2019, 2628230, Page416 of 648 suonannsu. Aircra? Make Aircraft I Points of Departure Arrival M?os Film? Rom-rim. Procodlves. Numb; . Alva-n Canaan-u and Model Idelca?m Mark Flown No. Mnmuvors. Endorsements ul Lar 1&51 am. To (,qu 3 a: Exam-mn- mmze Ew? 13:31? J13 3331'- 3 3 Us 65;? 0183,5531 We g, 3 4g ewe QEJKWMISK - . 25?95- 5 20 . ewe LFPB fa? ?3.st L- (9 2? I - 5:2" - 2L EUDM - I I .27 LFPB ?133? 7 i EWR . ?Kw-5'11 wagceua 3 $1591on ?my, as) 0; Lg; Li_ . NOLOBIC: ms'r. msg??mwm i I E11 735530 Lg 21> 1418 Lava ?f 0 Ci 5 20 Euscxs . 31$? L?m?l? 51mu?? Qu-u?m M318 1 lwftify lhut lhe made by me on this am nun. 4300] S. 2' iL 63911 Ligatm? Page Total Annunl Fnrward_ bags-S ?3&3 _Toln? 03!. N?rl (0 fl (W Mm Fun: 5 sgnatva Case 18-2868, Document 278, 08/09/2019, 2628230, Page417 of 648 A SUOQLOHJJSUI - I h- Alma Make New? Polnts ol Dopartura 3. Arrival Miles Flight Roman?, Procedures. :qu?g'?rgs About! I navy a - and Mom-l qummunmn Mam Flown No Hangman. Endorsements 1 Gum,?- Clm?} 010%:igw??) 2c~00) 2.0 PHL Zw? L135 5 2 8w 556-0536 WEI Nqome 7 ?wR T1327 6?115?6 gig? pew 15* or ngq?Wg?mlbj?l??"? {:31 I Ban-m N51093: 'Ew? B'Eb?l 9?QUHUL PET.160 psi 9"ng 2?53?? wt.? "pt; Gbxog??mm?fmppown?ow pawu?h?}Mwb ?r '5 PSI f?oux-a, maniamwwuzaw VB A?ing?mf (betc-o'mm ?5 . 6 eye??(307211?- 573?1754 . . BI ?fixmga - - .- 13W anng??j aegis?0' 5 am. 5611wa ?magic, ?Cu :b New!? that the made by me on this fun are me P?go TotaAnoum Forward bitm? Piiot?s SigumeMM 71L, than u? Data E?h? ?01cc 6 27' G- I Gil mm . ?53.02? 4 ea Case 18-2868, Document 278, 08/09/2019, 2628230, Page418 of 648 ?og?:1 Airman Make ?43- nv Model Aircra? Point: at Departure 0. Arrival Muss Fug" Prue-dams. Numbe! I Alvcm? Mmunuauun Flown Nn. Maneuvers, Endorsements 0' Landings From To A (#1th 54,-93 m7 ETD #561147? 3241, rx \0 T1 13241.0, 17 Fnocc TIMI, 51?? rink?p Simuugya: 6 (7 0 1? $14?ch {52px; p?i Pb; law!) w>c1 vow/1., o. 10L, scum-.0 9,1sz 3' ?1?:er HRH, 2.3 Ji?jg?m?mwse ewfl T251 9 111.76 aw U4 m. TOanofm 9139595? Eu; i Fri: TIST I451 ?33) LVI ?15 JUL ?l CMH 4cw,_ 953 0 . '23? 01 T1337 us-u 20 \l .o 43163.15? 97K we 4 LV Vi LL15 12-11-332. 21?, I Maggi?:33 Hep EL y, __d3 -. GWK 11:11 1m. .ti 1461 '23 (571m T. Pr My!) Redmur 020 Do :55: WE Rf?Jf' Pa r-c Mf?r NY-Q ?neg. Us?) :55 6094.50?: N80613: imqo BB Mint Wu 8% 7M ?an-m? 1 09.32, mm- ewra .ch comfy lhal the statements made by me on 1H3 form are true. Pilot?s Slmalug? 2 "ago Tom! 5 chOPI-?Jxo Fulwuld 68"? 3 5 4? Told [0 on. ?0qu tang I ?5 3 Case 18-2868, Document 278, 08/09/2019, 2628230, Page419 of 648 IJISUI Alford" Make Aircraft Points 0! Doparlm a. M?es Fllg?lf Rom-7kg. hocaduns. {fullba'n 3 Iliad! 2.21:1 and Mod?? mewmlmuon Mam Flown Na. ?Munro's. IndoMOII-nb (L nd :1 An?p?m ??z?l?-quj \3 B-?mxbm N40811: Ewe N5 e-nsms meagre MWL 16 Gav?ma meme Ewrc__ Jk _ij HBQ 2t 0862 mm - N19 1:51.. 27 Tm- awe. 2a (fume) Nth-?g: P811 ., '30 ll T66 ,x 30 pr'a Sir Bart-3i 1% Moqx? '50 (3.7213119. it i423. LV ow 3 at? 3 (IMAM Wits LV 4L LU '41) 143:? 4 Lv 91% 31+ ?gfm LDU ?quqsc? 1 mu m; Q. I 00"in that the slalcmoms made by mm on his [arm on: "us Page A, I Amoum Forward $8le 2 [p.138 @ch 6881 i 61 6 Pllot's Signature {LPHL \Qx? Case 18-2868, Document 278, 08/09/2019, 2628230, Page420 of 648 Dan Alucwn Mmu 1 Alma" Points 0! Departure 8. amnl Mules H}g?1t PWHMI, Number and Model Mark Flown No. Maneuvers, Endorsements Lusdings 2 co? I-rom a? Emu. GLUEK ,3 Crus?t? ,Nq acme 860 ?51' 2.5 i mwuwrm - gw?m __Ew_r_L {gig N?qcu? 1151? 16?6 -- T151 1131 ?50 . 2 L1. 860 163: i a 33:1: - 1g, 1151 ?,1?b3 DFWW ?in?ows chm?, 1 Alva-? Wt? {Jami-P} L. 0:035 2. V'm In V) m\ I all .?Ql may? carp-7W" .1 . - . 1 Bacvgf?gzg?n Ln?slzm (M - -3. 2.: 2 . Wee?) ?nally- (new 6 thocixc: ,T?s?i 166 141.- LV .3, 04,165 PWM m) V3 - (5&0 Wm LV . . 6&0 3cm9.9, 18 A TLST PEI .432army that the slatemenls media by the on Iris ton-n are true I Page Tou? Pilot'u Slgnalum l' Total to 688?. Iogginc, es em 3115qu sunnonnsul Aircraft Mano Ammll Palms of banana" 8. Arrival Moe ?ight Remarks. Procedures, I Number Alrcm? .19.- and Mode! Irlenli?callon Nam NO Mancunian, Endusenlauln olln'lr?np; 2922?, Path To ?kw; ?memjx: (give; 224 64545 N??xe Tag &m g? _gy_a 39w J69 1.1.5? ma? ,3 EMMA) - ?9 577-71?? J4 I 13?; A see Etc-?64?! cm?; '3 n?za~n~ c. [e - L: ?ma -L?ch 7? I - E?h?-ff?a ?Ezi?g?gew um "71-5. - f: ?of - 3 Euj??cgng?cgmen-cri?w 29 6415016 MM .6192 3?13 4? .. .. ?rxsy?jut?rs ms 8 lao? A IL, rApa ma LV 1/ ?5 ., ETAIQ T66 62' \5 Tag) 71267 T66 bCEmma? thoqmc: Vaq I480 3 61061361613 (56.0 2003 m} oeqzry mm me statements made by me on m: (om are true. Page Total 3/q, km Amounl mennl Io?Bgl 3 3 Pilots Slgnalu'a_ (UM. dza?le . ?833; 10.4?) 3 ?63 A hpw-mv-Mwu T?wfnf ??iw I Li gm: Case 18-2868, Document 278, 08/09/2019, 2628230, Page422 of 648 suonomlsul 5' fr? ?ml Clan ?iwmw 200-9: From To Bx?pw?t (:41ng meme (secBazvbm Nqoax? UQQ LCij tier 7.33. 18 Q??qb?ii? 115T Ewa?o. ?mo LV EWR SSL on LV, ?$7.511 2a 1:4 WET 206 i {45 139$sz LV. 25 34% Maegan Big-L ?Lb 086 L-Vj-b?: A, 26 98f. 2.8 Tiff1:51 T66 2m LV ?5 V) BIND) zeta 6 L4 :N0n? EE .. Emu ILFPB 2; .. we gLLee we Lv 1/ 25 LLBG mam 1cm locum; that the stalemenls made by me or. this form an: me Page Tom n+1} Amounl Forward kw \oqoo - Wk W'm- E333. Mm 1?1 3 4' Case 18-2868, Document 278, 08/09/2019, 2628230, Page423 of 648 Daze Muak Make Aircraft Pohls of Departure 1. Arrival Miss Rom-tn. Fwd-ares, Number Aha-n and Modal Meow-canon Mark Flown No. Maneuvers, Endarumonu oi Lanaungs 1966 From To 918% Gum?s-IL ?10% 645% Nc?he 20 LFWS 261 arr 2? 7<__71u 225.18%qu Lg:- . 2L L55 yt?sg?c' . G-usab macaqg 1:31 263:: 1:3 ?5 2.51 {5:127:53}; 983 G-nsm (09106138 Tee .. Mw_ Bean $487214le NQQ um m? usae Noloqr?_j?t31 Eco m?m ONFI 4 ?r?w I .. on ?res 6g 33? 15:17.1st Nof?oeut was? M129 MEH- 17 w?r? A. ML, ustmc z, 645% PB): 20% LV 0 4, 1? new} LV 3 2'1 56F 1?95: LV '29. 0 sec, #4 LV Ioen'tythatthesule-ums areUue. PageTotal <5 3Q, baa; Amount Fonvard QQOL PJot's Slew-18mm ??icb?d?i lo Duo ?9 QC. dirk: - 3151315?: 881631) 2m," 83?31 33x13 tr? 3 3 0? Case 18-2868, Document 278, 08/09/2019, 2628230, Page424 of 648 suononnsu; Date Alma?! Make I Mean Points 0! Dopanuro 8 Arrival Mass Remarks, Procoduns, Number Aircraft 49__ and Mooel lamli'lmtvon Mark Flown No. Maneuvers. Endorsemenh 0? 2503 To Quit-{2. 0?1214!? NESJG LCQ . - - Slim 'teAL-v LN. 0mm ?5616 OFW 04W Magi?3973:1594?: dafcquchc-uJy (j . ?we 92. new Lny?'p?d?. seTLs 4. cc??ww, 4L1 mo "5 mo? 6?727'20u Hm L?ro?~3mucm EA :4 90?an 689291cnmnaw wax/?w TV- A -. - Hum? pmamw. Ln; ?4 7N a. :5 cemnnu I?c- way nmeznm; LV - - LAM age?12331.4 megs LCQTAMVAL Lam .1 g-nsm. N80437: PMA ?9?wa awe . w? 7 mvw', PB: 1% arm?302 mom-e: (3813:" Pa; nag, 3? 31%" 2650; 8' A931: P91: 4 Lv 5% G?z?I?m Striuw??t Mm: mgr.) 1 V, 2g. Hm? (arm-MB meme, EAL ng. tn - Mme Hz): 861 As; .A 961: T5 39%! LV 6 was 931: Page rotal 2/9. A HZ ?momrroryng_ 22,:q norm. 33113 2214?? 8 Plot's Slgna?um Tolfllo Dan latt?? ajy?ls 3 009101 1 Grooms?i IT riff/71 ,1 I O??lVl lcer1ily Ihat [ho slalomems made by me on this form ane1rue, kno??aba?ranVerMvg?oo A?g 1 col ,an Case 18-2868, Document 278, 08/09/2019, 2628230, Page425 of 648 . [ban ??"93 I Flight a BI 8rd MUSE . VI 1 . emu I, I: Fian No, I?$31t2. ?In; it": Ii:_ 4 anc- Aime" Mam Aircraft Pohls oi Departure I: Arrival Mlle: Fligth as, and Mom launu?canm Marx Flown Na. 10 10? I From I T?o A?lcran Ammw am 9&1- 'nl 7. 26" Iv? Jun-m? . - Nd 5I 31' 8?727 1w spam?m 11/129: \l vomrm M738 (112mm 3 32312;? N53061: P61 p?kg 30m) (20663:; G- Homage 8:6; TTEB ?i 3 LV LV 7 1 laxantr?: 4 j~ol~?L Pl! m! a 88 538w 5 \4 . T66 Pm? I .6017,ch Mia M19 kiwi 99mm Martin; that the statement: made by mat on Hl?s aid hue. I pay cTo-(mil (wand .D .9 I ?0 Mom fa?d In Date Case 18-2868, Document 278, 08/09/2019, 2628230, Page426 of 648 Date Make Aircraft Points 0! Manure I. Arrival Reno-ks, Procedures, Numbev Aircraft 43.; Idenl?mt?on Mam -- Flown N) Maneuvers, Endorsements ulLancinga mum ?Lmb From To 4. 932: 96,: 163+ 23 642546 030336-19; 12:51 ME an 1.5. T3231 6H E1 v.01; WITMFM: -: 5 20 (261' - Tee; E, 1:69 DJ 2/1 9. - 3! <96: 21' T2511 w? - 3? 9.91 16?? LV 2. 95235,, 28 1?92- 3 Tam" e61: um - o, pg); 1022 - TIST PB), 1015 LN ?Ji 9-2963: LV .- T155 61Case 18-2868, Document 278, 08/09/2019, 2628230, Page427 of 648 L2 Emaigv? z?i any-7.00 $1220an mm ?9 BA VB: 1132" m, Ly 2~ TEST . 54o; ESL so 25 (?61 mm mot LV 2 Icon'ty 1halthe stalamem: made by no on [turn me two. Page Total 36/ ?0 ?6 . . Anna-f {onward pun-s sma'ua 2 4 I 5a Total to Dalknot??Nahum .. Case 18-2868, Document 278, 08/09/2019, 2628230, Page428 of 648 . fur?op?f-ng?ri??U?JW6? 3 Mann Make Amen Points of Depanun A Arrivd Miles ?In" Roman: my 3, Proceduno Number and Mme] identification Mark Flown No. Man-wars. Endorsenzerns (y ran" an" Gum l??ummMame .12. Lv 4:4 3 . .. ?mum-?u! a. ?9 LV 2 'LFeb 9:393 2V ml CYQK .. 2113?: tree max 92319 . .H mm 8661:? .3 "1.2an . Lv T63487151' 59??0 I ma LV 3 4833 .. -. 2?14 3 -113; VHS: I . 1165? :20 LV 2L 3 T55 ?66? in? om?m'eo ?o numumxe LV A 7?7 ?92? WM 2.8 LV ,3 a? EGGW LFee - .3, \1 . L??s 566W 1?13 T6 E: (56? *Ef: 666w BG-R 1632mm? 98 ,q eon T66 8.me 54w A i (:6me thal the slate/manta made by mo on his form are true . - . Pam Tnlal 8] I 6] P1tm's Stonnh'a 2 0 swd?g? 3?1 Amuuql Forwanl 4.525 Tot-l Io Dal. ?x 09?, . . . .. .. .. . sm;g;oru;sul 1 a Rural Make Meta?! Points of Departure 8. Arrival Fug Remarks, choduron, Mmeer Alien? and Model ldonh'mllm Mam Na. Manman, SMonomonh oi . From . gm)? 670586 Nqocxx?.? 43;? 4. 3:5? 8~m~3m Nqoasz PSI 106): Ix.-6' 313+ \7 ale 9:1 may.) . LN 2? 6:162_ (.95 4 mm . CPS T66 ?66-..m'owmm$66 39*. 1:51 3,636 LV 4/ E153 4L . . ?1 TISY 261 4 Ag- P672: "29?1'56 *uq L.V sxmvuzm or31;? ?3/3 ?8:366? r?mgr, 3900490) Mowe? ?fys?f . 1N dole) (4 (4?an i4l$ (n <0 .rncr s5? 33 \0 6mm N53590: -961? sow ?mm: \3 6??qu T66 (560 bus . L-V V1 luurl'ly that rho statements made by ma on this tom me two. Page Tolnl . Amoum Forward Slamtum Total to Data qu' ?159 V?v Us a me H.343 2.536 T3398 Case 18-2868, Document 278, 08/09/2019, 2628230, Page429?of 648 suouomvsuu Abram! Make Polo-I: oi non-dun a. Anlval Muss Remarks, Procedures, Numbe! I Allcra? 19?- and Mode! ldond?camon Mark Hem N3. Manouvon, ol Lg?- From panama 9.33 945016 Nqocm?? (sen. 961, am LV \b ?61: 1&5: I a 2 '1 115;, Lg lei?? Zo T151 ml ?61 \t TLSL 20 1.5: (figs: I. Li T68 . .5 21'4?? Li do [78.1? may(:T3257 MDPC. 2453 MORE. 1151? ?as: A 21 Mow. 3455? 4 LV 7 7.8 M0 Pc. TEST {236$ . . I certify that the slatenewts rrade by me on his turn are true. _Pago Tom Amount Forward 2Films a a 55140 . 4 . \s Case 18-2868, Document 278, 08/09/2019, 2628230, Page430 of 648 . . .-.. smnannsul Dale Alrom? Mako Nrcra? Polnu of Dopavtun 0. Arrival . [Miles Fliwl Remarks, Procedures. Numbet Alvaa? 49?4 and Model ksonll?catov?. Mark FSown No. Manouvon. Momma?: oILawdingo 16% From To 6415? M0 vs, ugugam mee .1151 Tea ms: \1 1 :50 &?Ie,c Nizzxa 169:86: Rersmra un?t Tara-Ilwr smuumt- - 2' ee?efmw ?6 I 1 puaegamgsn?mcw W??lsw (a - .srrz two . ?we? a? f??az' g9 emu?; MAL$9Ml= 65 ea (Mack q? 216 baa?mam- moqu 9 61 12??ng 3 '7 (a (9 ?50 Mom 945" l-V \l 168: 1?45 u, ?1493?? 600? UH LV 2o?, 66%: GVHC. ma . LV . 2.0 :6th . S115: T68 L-V fl 51,? Bqum Numam 9612-945- 90; 932%" '?Mmm 8 \l 1?pr ?91??st 26 (??586 11:5: TEES MU: ML '50 was 3: I ?3-30 I certify mm statements made by me on this form are true. Pogo Total W. Amoml ?53* ?61 63 Total to M. titif- 313 r301 Case 18-2868, Document 278, 08/09/2019, 2628230, Page431 of 648 . . a . suouomqsul Condmt C. Date Mme Aircraft Points at Departure Arrival Wes High! lam-nu, Proceduns. Number Aircrall 49.: and Node! h? Mark "own No Maneuvers, Enthusiasm: 01 Landings mu From T3 $2 mat-?z cum-1 ?ti" G?usq macaw: 61 Tet1356-19.12.? 1 Mppy we} <0??me cheat new: n. hang? GROW n. LIL 3691? cyan?? $604" 7.9 i Le . 28 G-us?m N?c?se \?a?ou?mm - 2m} a??xcwm qune may?: 3/3 3 6-123-an 133% LPN 3L3HT4491 Ls: . 0% 3? 1.5: Ls: sill-c: %_g_??a_s_moqwe SWF a? ?53s oani'y that :ha statements made by Ina on "1 510m are true. Page rural q/a Lb Li mm mm- 4? baea . i SI . Tom ?0 Dale . Plot's gnatu'a 0. . . 636?): ?0311 Li 86% 5A5 Case 18-2868, Document 278, 08/09/2019 2628230, Page432 Of 648 SUDIIGHIISUI Data Alrcm? Palm: Dopnrlun I Arrival Mlle: Ham Roman?, Procedmu, Nurrbo' 4.9., an .016 Identi?cation Mark ?own No. Maneuvers, Endouomonn =anan cnry/a; . 2 Nb W3 915:? hi4. ?5 06': EB: Moe!? wig-3111511 4/ 4? 2 1?44} 5-: Li _jfo \l QQ I thoq ng ,Lwa a 3 EMT 17?: 1" 4' 1 2 0139 . ix 4 56 JQLELP. __Gyhc LV _3 1% ma Di .., 7-3 Manon 3; 2H w?mmc ?84; 74 7? 1LL?SiL_51numm_6?W 06W men (In-7?9, woe oz: ?and m% 3 0 02254?:th - ?51? 9 ch?gs?36% mm soul that ?he wade by mo on his form are true 3 go 013! /q NEE Amount Forward 88'9 Tb?! to an. ?2655 - Miilqb gqu R_oog QB 1 I :1 Vivian 1w Ir I i Case 18-2868, Document 27-8, 2628230, Page433 0f?648 . . . .u . {economjsui and Mode! Mcruf? Maks Ailca? Identi?caton Mark Points ol Doparluru 5 Arrival From Mules F?ghl ?nnafks,Pmcadures, Flown No. Maneuvers. ?1160an- Number of Landings Allen? Imam/10 nu. [Mn-11112 ?jg (141536 '50 _moaxe MW \vl T?b 11. O1 3 6:053 NCLOQIE T1254 nice 2 ??97in LS7 Howard; (6?95 mm? ow? 6101191.}. magma? LV Ll \l (>81 \l I 1&6 2? 1, shag TEST '9 LV 1:51 363 1.11% 7.115 1? ~11 mm 7.1% CC 12W game. LV LV, 550 in 0913? F1. IABQ 21 7.7. 119A IP19 LU {1 981 TS-ST LV LV I the s' ammonia nude by m1 on this tor nn an: true. aunt's Signamregad? i Tot-l lo Dale 6?1 1 Amount Forwam 5 \oan'L molwioldlm (qclcogf; Case 18-2868, Document 2.78, 08/09/2019, 2628230, Page434 of 648 suogotmsu' I bah.- Alucran Maln- m: Mcdol lam?ilcalnnMulk Flown No Maneuver- .Endomm. 2M2 11111 Fa u! Lm wags Numtev I Altman, 2am 2 Akann Point: at Dopulun 1 Annual lMMes Fli ugh! Rem-?u, Pmudurcs, 1 i ?LIZ-us?m Mama 66 ?gg ,5 . JAAL li_ I #18 T?sn Aug067'- LV ll 1351-? @1?3/7?Ui?gg. 7 ?9 6_ 1230. LL. :3 24-6-7273)! ?30? EEG thupun to 4&6? 5? 05% Nqoqsc Tee 241;; I. r'i?u" ?1 .6 qm-lcob @0me A29 .62 ?6 Fe 6 .mm?mm?i'v - l2 - ale-"u W. . 1 9.13951pr 5.25;: ping I 0.6?qu u! if ".4922:Mjw 156 E31 LV . Flyw? ?685 553 A 7 3.: 5695 sou .: ii same sob jl'v'uf<4de co .9 I Pilo?s Case 18-2868, Document 278, 08/09/2019, 2628230, Page435 of 648 . . Aircraft Makn and Mode! . Points oi Dopamlro l. Arrival Honln?muou Mm me !Tu Flown No Hon-mks, Mcedmea, Ilanouuavn. Elmer-9mm?! Numbev my 8 721-3 UFW Mom's L961 4 [4 95?, SI .AUan G?ns? [00LVA P?s: LV H.692 T66 m: LV L53 DJ: T68 ?31:5r .132er :36 Nder#mdim .4 ?rec @56- ?ne TUL- 30 TPE VNY TED ?1 1151 WW n? Tea A. 96? 2.1% Immly mm the statements rrade by me on this form are we. Plot?s Slgratal?m Page Tols. Annum Forward Total to but. no'mc?fmr?m's Case 18-2868, Document 278, Page436 Gf648~ {1 Aivcva? Make 0rd Modal Identi?cation Mark Poll-Ii: 0! Departure I. Arrival Fugm Flown No. me - To Remarks. Number Maneuvers. Endorsements a! Landings Aileen? 3 MN v; N?b?ia?e f6)? 1322)? 2:16 LN on 1w 2. yr azi__ l\ usf n59 :59 3'1256 ?33 Rad LXZL 2?4 3 31151 Tiff! j; w' 32' LFVB LFPB ?mc' :34 m. 29:21 i TisTf ?a 7333- THT sut- 13.97 uu? 1:151?- AIBM?yggk 36L o?u?o rear; mienQua L85 .916] _E*6x2 ?l ASE. \l A56: SGT: Flint: Sinnelure that the slaleneMS made by me on [Na lovm a'e lrue. Page Total ddrwiJ?? Am"! Forward Total to up? 3?03- NM Hencn 1.04 Case 18-2868, Document 278, 08/09/2019, 2628230, Page438 of 648 EXHIBIT CC Case 18-2868, Document 278, 08/09/2019, 2628230, Page439 of 648 Confidential Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 3, 2016 9:07 a.m. C O N F I D E N T I A L Deposition of DAVID RODGERS, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 18-2868, Document 278, 08/09/2019, 2628230, Page440 of 648 Confidential Page 2 2 3 A P P E A R A N C E S: 4 BOIES SCHILLER & FLEXNER, LLP Attorneys for Plaintiff 401 East Las Olas Boulevard Fort Lauderdale, Florida 33301 BY: BRADLEY EDWARDS, ESQ. 5 6 7 8 9 10 HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant 150 East 10th Avenue Denver, Colorado 80203 BY: JEFFREY PAGLIUCA, ESQ. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALSO PRESENT: Sandy Perkins, Paralegal Boies Schiller & Flexner Ryan Kick, Videographer Case 18-2868, Document 278, 08/09/2019, 2628230, Page441 of 648 Confidential Page 3 2 3 4 5 I N D E X Examination by Mr. Edwards .................... 5 Examination by Mr. Pagliuca .................... 209 Further Examination by Mr. Edwards ............. 217 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 E X H I B I T S Deposition Exhibit 1 ........................... Flight logs 6 Deposition Exhibit 2 ........................... Photo 77 Deposition Exhibit 3 ........................... Photo 84 Deposition Exhibit 4 ........................... Photo 85 Deposition Exhibit 5 ........................... Photo 86 Deposition Exhibit 6 ........................... Photo 87 Deposition Exhibit 7 ........................... Photo 88 Deposition Exhibit 8 ........................... 203 Confidential list Deposition Exhibit 9 ........................... 216 Equus Global Aviation offering Case 18-2868, Document 278, 08/09/2019, 2628230, Page442 of 648 Confidential Page 6 1 DAVID RODGERS 2 A. Yes. 3 Q. Can you -- can you tell me -- I have been 4 provided by your attorney a -- what has been 5 represented to be a copy, a direct copy of that 6 logbook. 7 Plaintiff's 1. 8 is an accurate copy of the original logbook that you 9 brought to your deposition today. 10 A. 11 12 13 14 And I'm going to mark this as I just want you to confirm that this Yes. MR. REINHART: Let him show it to you. BY MR. EDWARDS: Q. There you go. (The referred-to document was marked by 15 the court reporter for Identification as 16 Deposition Exhibit 1.) 17 MR. REINHART: It is not a copy of the 18 entire book. 19 covered by the subpoena. 20 clear the book covers the time period outside 21 the subpoena. 22 23 24 25 It is the time period that was MR. EDWARDS: Okay. I just want to make I will let him clarify that, of course, too. THE WITNESS: Yes. It is logbook. not 40 years, but it is my logbook. It is Case 18-2868, Document 278, 08/09/2019, 2628230, Page443 of 648 Confidential Page 7 1 2 DAVID RODGERS BY MR. EDWARDS: 3 4 Q. Okay. You can keep this -- that down there -- 5 A. Okay. 6 Q. -- so we can keep track of the exhibits. 7 A. Okay. 8 Q. So does the copy that you just went 9 through, is that an exact copy of the original 10 logbook from the November 1995 date through, it 11 looks like, September 2013? 12 A. Yes. 13 Q. Okay. 14 17 18 And what is this book? A. It is called the standard pilot master Q. All right. log. And who made the various entries in the book? 19 A. I did. 20 Q. When did you make -- 21 22 MR. PAGLIUCA: Brad, can you hang on for one second. 23 MR. EDWARDS: 24 MR. PAGLIUCA: 25 What do you call the book? 15 16 That period of time? thought. Sure. You said September 2013, I Case 18-2868, Document 278, 08/09/2019, 2628230, Page444 of 648 Confidential Page 8 1 DAVID RODGERS 2 3 MR. EDWARDS: last page. 4 5 MR. PAGLIUCA: MR. REINHART: There's 108 pages to the exhibit. 8 9 My last page is 2008 on this copy, 093 Bates label. 6 7 That is what I have on the MR. PAGLIUCA: pages. 10 I'm missing the last 8 That is why. MS. PERKINS: Do you want the last copy? 11 What is your last page? 12 MR. PAGLIUCA: 13 Ninety-three is my last page. 14 That is why I only go through '08. 15 MS. PERKINS: So I will give you my '94 to 16 the end. That should give you a complete. 17 you're looking -- which one are you looking at, 18 the new one or the old one? 19 MR. EDWARDS: 20 MR. PAGLIUCA: 21 MR. EDWARDS: 22 MR. PAGLIUCA: 23 Oh, The one through '08. Okay. Okay. Are you ready, Jeff? Yes. BY MR. EDWARDS: 24 Q. When did you make each individual entry? 25 A. It could have been on that date that it Case 18-2868, Document 278, 08/09/2019, 2628230, Page445 of 648 Confidential Page 9 1 DAVID RODGERS 2 says. 3 Most likely, fairly close to that date. 4 5 6 7 8 9 10 It could have been possibly a later date. Q. Okay. How did you make sure that the log entries that you were creating were accurate? A. Well, people get on the airplane and I see who the people are, and I put them down there. Q. Okay. So you are making the notation at or around the time that you are making this observation -- the observations? 11 A. Correct. 12 Q. And you are recording the data accurately 13 in your logbook? 14 A. As accurately as I can. 15 Q. Okay. 16 A. Yes. 17 Q. Can we just look at the first page of the 18 exhibit? 19 A. Uh-huh. 20 Q. And if you could walk me through, let's 21 just take the first line. 22 A. Uh-huh. 23 Q. In the top left corner, there is a date. 24 A. Correct. 25 Q. And it says, "NOV '95." Is that you Case 18-2868, Document 278, 08/09/2019, 2628230, Page446 of 648 Confidential Page 10 1 2 DAVID RODGERS indicating that this is November 1995? 3 A. Yes. 4 Q. Okay. And the first line under that in 5 the date column says 17. 6 1995? Is that November 17th, 7 A. Yes. 8 Q. Is that a notation that you would have 9 made on November 17th, 1995? 10 A. Yes. 11 Q. And the next column over under "aircraft 12 make and model," there is a number there. 13 that number? 14 A. 15 16 17 18 19 20 21 22 That's the model of aircraft we're flying. It's a G-1159B. Q. What is Okay. It is Gulfstream, II-B aircraft. And then the next column over, aircraft identification mark? A. It is the registration number of the aircraft. Q. And what is the registration number? What does that mean? A. The number that is on the side of every 23 aircraft to identify what country it is from and 24 what particular airplane it is in that country. 25 N means United States. The Case 18-2868, Document 278, 08/09/2019, 2628230, Page447 of 648 Confidential Page 11 1 DAVID RODGERS 2 Q. And is that number unique to the aircraft? 3 A. Yes. 4 Q. So there is no other aircraft at the same 5 time bearing the identification number in N908JE? 6 A. That's correct. 7 Q. Who picks the identification number? 8 I understand N means United States. 9 A. Right. 10 Q. Who picks the 908JE? 11 A. It depends -- some aircraft, I mean, when 12 you get them, they already have the number on there, 13 and so that would be one way. 14 manufacturer puts them on there. 15 16 17 Sometimes the You can also request a certain number, if you so chose to do so. Q. Okay. The particular air -- these 18 particular logs were produced in a -- as a 19 consequence of a subpoena issued in the case of 20 Virginia Roberts Giuffre versus Ghislaine Maxwell. 21 A. Uh-huh. 22 Q. Is that your understanding? 23 A. Yes. 24 Q. And the period of time that we were 25 produced -- I understand you have flown for 40 Case 18-2868, Document 278, 08/09/2019, 2628230, Page448 of 648 Confidential Page 12 1 DAVID RODGERS 2 years. The period of time -- or that is evidenced 3 by this logbook is '95 through 2013. 4 Why was it that period of time that was 5 chosen? 6 A. 7 8 9 Because that is what the subpoena requested. Q. Okay. Is that when you started flying for Jeffrey Epstein? 10 A. No. 11 Q. When did you start flying for Jeffrey 12 Epstein? 13 A. July of 1991. 14 Q. Okay. 15 Do you have available today the entries going back as far as July 1991? 16 A. I don't know. 17 Q. Okay. 18 A. No. 19 Q. Okay. 20 I have to look and see. Because this is from 7/28 of '94. So that particular logbook begins July 28th, 1994? 21 A. Yes. 22 Q. And were you privately flying for Jeffrey 23 Epstein on November 17th, 1995? 24 A. Yes. 25 Q. And is that Gulfstream that you described Case 18-2868, Document 278, 08/09/2019, 2628230, Page449 of 648 Confidential Page 13 1 2 3 DAVID RODGERS a Jeffrey Epstein owned or controlled airplane? A. 4 5 6 It was -- let me think. This was 908 Juliet, Echo -- I believe it was owned by Hyperion Air, Inc., I believe. Q. And is Hyperion Air, to your 7 understanding, a company associated with Jeffrey 8 Epstein? 9 10 A. As far as I know. I mean, I would assume so, but -- 11 Q. Was Jeffrey Epstein your primary 12 passenger -- 13 A. Yes. 14 Q. -- on that airplane? 15 A. Yes. 16 Q. And who was the individual that gave you 17 direction as to what passengers to let on and off 18 the airplane and where to fly, et cetera? 19 A. Well, Jeffrey was usually -- I mean, 20 almost always on the airplane, unless we were going 21 to maintenance. 22 have the people with him. 23 Q. Okay. And so when he got there, he would So going back to the aircraft 24 identification mark, 908JE, does the JE signify the 25 initials of Jeffrey Epstein? Case 18-2868, Document 278, 08/09/2019, 2628230, Page450 of 648 Confidential Page 14 1 DAVID RODGERS 2 A. I would assume so. 3 Q. Okay. 4 A. But technically they are actually the 5 phonetic letters that we use. 6 Juliet echo; it is not Jeffrey Epstein. 7 radio phraseology, we don't answer Jeffrey Epstein; 8 we answer Juliet. 9 10 Q. Okay. But technically it is As far as But the JE doesn't signify some jurisdictional code? 11 A. No. 12 Q. It is -- it is chosen by the owner of the 13 aircraft? 14 A. Right. Right. 15 Q. So as his pilot and as Jeffrey Epstein 16 being the main passenger, you have presumed that JE 17 signifies his initials? 18 A. I would assume so. 19 Q. In fact, we will get to it later down the 20 road, but the -- the other plane also bears the 21 ending initials JE; is that right? 22 A. 23 24 25 Yes. And this N number that's on this airplane was eventually switched to another airplane. Q. To the Boeing? Case 18-2868, Document 278, 08/09/2019, 2628230, Page451 of 648 Confidential Page 15 1 DAVID RODGERS 2 A. To the Boeing, correct. 3 Q. Okay. 4 5 So if we go back to this first entry, the next column says, "From CMH." 6 A. Yes. 7 Q. And what is that? 8 A. Columbus, Ohio. 9 Q. That is an airport code? 10 A. Airport identifier. 11 Q. And, again, that airport code is unique to 12 a particular airport? 13 A. Correct. 14 Q. The next is "To PBI"? 15 A. Yes. 16 Q. Where is that? 17 A. West Palm Beach. 18 Q. And flight number? 19 The next column says "Miles Flown." 20 A. Right. 21 Q. That is not something that you log. 22 A. I don't. 23 Q. You kept pretty meticulous logs. 24 25 So the next column is flight log -- or flight number? Case 18-2868, Document 278, 08/09/2019, 2628230, Page452 of 648 Confidential Page 99 1 DAVID RODGERS 2 Q. Okay. 3 A. But I'm not even sure we still had it at 4 this point in time. 5 6 Q. A. 8 10 11 It shows up on the next page. We will get there. 7 9 Yeah. Does it? Okay. So then, yes, the answer is, yeah, we still had the airplane. But we wouldn't have used that. Q. So is there any way of telling how Jeffrey 12 Epstein, Ghislaine Maxwell, Adam Perry Lang, and 13 Virginia were in the Virgin Islands on that, from 14 December 14th, 2000 -- 15 16 17 18 MR. PAGLIUCA: Object to foundation. BY MR. EDWARDS: Q. -- based on your knowledge or your logs or anything else? 19 A. No, I wouldn't have any way of knowing. 20 Q. Okay. 21 A. Because the next flight that they are on 22 was like this Palm Beach one, January 16th. 23 wouldn't have any idea. 24 25 Q. Okay. So I To your knowledge, did Jeffrey Epstein ever fly commercially? Case 18-2868, Document 278, 08/09/2019, 2628230, Page453 of 648 Confidential Page 100 1 DAVID RODGERS 2 A. He probably has. Back then at this time, 3 I'm going to say probably not. 4 has flown commercially. 5 like going to Europe, maybe. 6 Q. Okay. But I know that he But usually that would be January 16th through the 25th, 7 those flights, do you see that block that I'm 8 talking about? 9 A. Yes. 10 Q. Jeffrey Epstein, Ghislaine Maxwell, Emmy 11 Tayler, and then at times Shelly Lewis, do you see 12 that? 13 A. Yes, right. 14 Q. The 25th it lands in Teterboro. And the 15 next day, on the 26th, leaves out of Teterboro with 16 Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and 17 Virginia Roberts. 18 name. This time you wrote the whole 19 A. Right. Right. 20 Q. So when you write the full name, does that 21 signify -- that's when you may have learned her last 22 name? 23 A. Correct. 24 Q. And do you know how she -- how she got up 25 to New Jersey or New York? Case 18-2868, Document 278, 08/09/2019, 2628230, Page454 of 648 Confidential Page 103 1 DAVID RODGERS 2 Boeing? 3 A. Yes. 4 Q. The Boeing, was that previously owned by 5 6 7 The Limited or Les Wexner? A. I'm not sure of the company name, officially. But probably, yes. 8 Q. Some association with him? 9 A. Some association, yes. 10 Q. Do you know who flew the Gulfstream while 11 12 13 14 15 you were doing the simulator? A. Well, it would have been Larry Visoski, I'm not sure who the first officer was. Q. Do you know if any logs were kept of the passengers' names? 16 A. While I was at school? 17 Q. Right, while you were at school. 18 A. There probably were logs, but I don't know 19 20 21 where they are. Q. Have you ever spoken with Larry about whether he kept names of passengers? 22 A. I don't think he does. 23 Q. Do you know where Larry Visoski flew the 24 25 Gulfstream for the month that you were -A. No. Case 18-2868, Document 278, 08/09/2019, 2628230, Page455 of 648 Confidential Page 107 1 DAVID RODGERS 2 different, because one day is the 5th; one day is 3 the 6th. 4 night. 5 the next day. 6 Q. 7 A. Q. Got it. We went from Stephenville to And who were the passengers going to Paris? 12 13 Okay. Paris-Le Bourget. 10 11 And then when we took off, it was, you know, And then where do you go the next day? 8 9 But we landed there like at 11:50 at A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts. 14 Q. And then what's the next flight? 15 A. On the 8th, from Paris to -- I believe 16 that is in Spain. 17 Q. Granada, Spain? 18 A. Granada, Spain. 19 Q. Okay. A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 20 21 Correct. And who are the passengers on that trip? 22 Tayler, Virginia Roberts, Alberto and Linda Pinto, 23 one female, and Ricardo, it looks like Orieta. 24 Q. And then what's the next flight? 25 A. From there to Tangiers. From Granada to Case 18-2868, Document 278, 08/09/2019, 2628230, Page456 of 648 Confidential Page 219 1 DAVID RODGERS 2 CERTIFICATE OF OATH 3 STATE OF FLORIDA ) 4 COUNTY OF MIAMI-DADE ) 5 6 7 8 I, the undersigned authority, certify that DAVID RODGERS personally appeared before me and was duly sworn. WITNESS my hand and official seal this 8th day of June, 2016. 9 Kelli Ann Willis, RPR, CRR Notary Public, State of Florida Commission FF928291, Expires 2-16-20 + + + + + + + + + + + + + + + + + + 10 11 12 CERTIFICATE 13 STATE 14 COUNTY OF MIAMI-DADE ) 15 16 17 18 19 20 21 22 OF FLORIDA ) I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime Reporter do hereby certify that I was authorized to and did stenographically report the foregoing deposition of DAVID RODGERS; that a review of the transcript was not requested; and that the transcript is a true record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 8th day of June, 2016. 23 24 25 KELLI ANN WILLIS, RPR, CRR Case 18-2868, Document 278, 08/09/2019, 2628230, Page457 of 648 EXHIBIT DD INTENTIONALLY LEFT BLANK Case 18-2868, Document 278, 08/09/2019, 2628230, Page458 of 648 EXHIBIT EE Case 18-2868, Document 278, 08/09/2019, 2628230, Page459 of 648 Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 1 Time: 8:51:56 Citation Tracking Report Program: CMS307L Case Number . 1-02?009702 Issued By . . KLOEPPING, KURT 6/19/02 13:55 Entry Employee STEPNOWSKI, DOROTHY 6/24/02 13:55 Zone/Division Zone Two (2) (So of Okee/E Wil) District . . . PATROL Street Name . CRESTWOOD BL Last Name . . ROBERTS, VIRGINIA LEE Street Number - RD City . . . . . LOXAHATCHEE, FL 33470 Birth Date . . Oper Lic No. . - Race . . . . . White Sex . . . . . Female I I A I 0 1 Case Number . 1-02?009702 License Number G13BTQ FL Vehicle Year . 1993 Make . . . . . PONTIAC Style . . . . TWO DOOR Color Top . White Color - Bottom White I A I I A I Case Number . 1-02-009702 Citation Number: 97OZBOE5 Statute/Ordin 316.189 REPORT TO BE A TRUE COPY R10 L. BRADSHAW. Case 18-2868, Document 278, 08/09/2019, 2628230, Page460 of 648 EXHIBIT FF . . Case 18-2868, Document 278908109/2019, 2628230, Page461 of 648 0818 Number - PROBABLE CAUSE AF DAVIT - 1. 3. Request for Warrant Juvenile i 2. N. .A. 4 Request lor Copies 1 c__L 1 Agency OHI Number Agency Name ADMIN. Chec Mummy B4 8 3. Msdmenor Ordinance Agency PALM BEACH COUNTY SHERIFFS OFFICE - 0.6; ?.21 -100 Charge Type; 2. Tre?ic Felony 4. Traffic Misdemeanor 6. Other .. Lqu Name (Last. First. Alias Rm Sex MD ip?l?ol?l Mm. t. l)m to Oh Description Charge Description . u.I wg; in?anwd SKID Did l\ Cha Description 641190 Description . Victim's Nam (Last Middle) Race Sex rem I a . - Local Addrm [Sign (City) up ff' Address Source mTLi $5?th ?ght/At web/c, AddwsatName. Street) 7' (Stale) [ZIol PM Occup- I - - . . The undersignedeertilles and man that helshehu just and mem?qounds to believe. end done believe the: the above named Defendant committee the IIowmg violation or law. The Person taken into custody, 1 committed the below acts in my presence. . . was observed old W4 confessed to hat nelshe saw the arrested person commit the belOw acts. admitting to the below facts. was found to have commited the below acts. resulting lrom my. (described) investigation. 0n the of at DAM. PM. (Speci?cally include lacts constituting cause tor arrest.) -r .5. wt: ?Ioh?7l'32?wm? I ?m I 1-. 11:9' I. [-71.7.1.3175 . . . gyrl??ta -I q. i. .ugrg:159-9" turf. a. ?4.517. . . . . . ?5-3CAUSE STIATEMENT - fr"55+33~57: "?92351"; r551 lit, g! (P int-d): if 1?4 63339 5 (E33 117.10) L5. . . WHITE "$76365!? State 111nm? .- YELLOW Adena - PINK Aaencv - . Case 18-286 [Ebocument278108?/109/2019, 2628230, Page462 of 648 - GETS Numbat' - PROBABLE CAUSE AF DAVIT 1. AI- 3. Request to: Warril'tt Juvomlc I I I I I 2. N.T.A. 4. Request for Cantu ORI NumbeI Agency Nm 5 Agency Report Number 5 1 ol 0 1-0. 0. PALM BEACH COUNTY OFFICE L0.6 0-9 ID ll ?low a a. Misdemeanor 5. Ordinance . . . 2. Felony . 4. Traf?c Misdemeanor 6. Other - Namemy p[L . 'tst. Middle). . Alias Race Sax 1 - I) 3 Chugo Description 8 . ?1 Change Oucnpuon VICTIM .F-rst. Mimic] . - - Local?Add ?Swot! A Nu ?pr 221540170 (3%in 8min.? Adare'sg? Name Street) <0 (City) $(Statel (le) Occupalton . The undeIsIQned certilles and Man that rte/she has just and reasonable qounds to believe. and do? not at the above him Dolendant wrangled the foaming violation my i . Thu Potion taken into . I I. i committed the below acts in my presence. - . was obsarved D, {?18m 3/ confessed to at helshe saw the arrested person com "19 acts admitting to the below lacts. as laund to have oommitod the below acts. rasulting from my (described) investlgatlon DAM. [3 PM. (Speci?cally include (acts constitutlhq causonlor arrest.) . - .1.- 0; a It!? {5-9 V: a? a - )t?f-?Pru -. - .Z . 110"." . .-: - A liq-Qt i} 1.5. A Dr J. ?t I l?mm ?31919 am {353m 09 fl ma Am J: .- .L. la- nuk- . athjatm met 1&5?qu I: a A v: I 11' 251-?? 3 . .1. h. goli - 9 RF) NalaPubla ssn: I I 5 I .. ..-. - Com Cnov .. Qtavo I I'm sum A Case 18-28%Document 278,. 08/09/2019, 2628230, Page463 of 648 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA CRIMINAL DIVISION (CGS) STATE OF FLORIDA CASE NO. 02CF012205A02 BOOKING NO. 2002343589 vs. 3 ANTHONY LUIS FIGUEROA, 7'5? . {0 IT: i -41, Li.) ., INFOWOQWGINAI GRAND THEFT In the Name and by Authority of the State of Florida: BARRY E. KRISCHER, State Attorney for the Fi?eenth Judicial Circuit, Palm Beach County, Florida, by and through his undersigned Assistant State Attorney, charges that ANTHONY LUIS ZAC FIGUEROA on or about August 11, 2002, in the County of Palm Beach and State of Florida, did knowingly obtain or use, or endeavor to obtain or use video games of a value of $300.00 or more, which was the prOperty of HOLLYWOOD VIDEO, or any other person not the defendant(s), with the intent to permanently or temporarily deprive HOLLYWOOD VIDEO or any other person not the defendant(s) of the prOperty. or bene?t therefrom or to apprOpriate the property to the use of ANTHONY LUIS ZAC FIGUEROA or to the use of any person not entitled thereto, co trary to Florida Statute 812.0140) and (3 DEG FEL) RICHSYONE FL. BAR NO. 0928933 Assistant State Attorney STATE OF FLORIDA COUNTY OF PALM BEACH Appeared before me, JILL ESTEY RICHSTONE Assistant State Attorney for Palm Beach County, Florida, personally known to me, who, being ?rst duly sworn, says that the allegations as set forth in the foregoing information are based upon facts that have been sworn to as true, and which, if true, would constitute the offense therein charged, that this prosecution is instituted in good fai and certi?es that testi ny under oath has been received from the material witness or witnesses for the a Assistant State Attog?y Sworn to and subscribed to before me 033s day of October, 2002. - STATE OF - PALM BEACH L- r" a; ?sh-39s: i . i the foregoing is- a 3:33: it? i ,9 '2 "megs: glib? igfmd in my of?ce with mm . ?3:3 5 tions. if as req red by 13?: NOTARY PUBLIC, State OfFlonda if A: Mg? . 20 n'mm. MPTROLLER AWE, Ellen Jordon r45.) 3% a ?x mass ecemb GRAND THEFT 2399 By DEPUTY CLERK an semen 9'28: 29?? THRU TROY FAJN WC ?x671 . Case 18-28 IN THE CRIMINAL DIVISION OF THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA. IN AND FOR PALM BEACH COUNTY magi 740a (A) 01/28/2003 11:36:12 200300?76?7 ocument 278, 08/09/2019, 262?82?Page464 of 648 oars NUMBER on BK 14720 PG 1935 Palm Beach Count STATE OF FLORIDA I 1 COMMUNITY Dorothy H. ?uke? Florlda SIWTROL - STATE or riot-tie! .Qi?fi?escu COUNT OLATOR . is a v. I hereby certify that w'Ith NW copy aI the IECOICI -- 1 PROBATION lionsVIOLATOR .2 I I one it." I H's ARON a. gait B, a coup: omen DEPUTY CLERK RACE GENDER I 3 . cream 5 course-i 3 - "pi-TH. . The above Defendant. bemz rsoh?a ly before this Court re resented Having entered a plea of nolo contenderc to the following the following crime(s): the folloWing crime(s); Having been tried and found guilty of Having entered a plea of guilty to - OFFENSE STATUTE Emmi 4 I and no cause having been shown why the Defendant should not be adjudicated guilty. IT [8 ORDERED THAT the Defendant ishereby ADJUDICATED GUILTY ofthe above crime(s). and having been convicted or found guilty of. or having entered a plea of nolo contendere or guilty.regard ess of adjudication, to attempts or offenses relating to sexual battery (ch. 794). lewd and lascivious conduct (ch. 800). or murder (5. 782.04). aggravated battery (5. burglary 810.02). carjacking or home invasion robbery (5. SIZE. BS). or any other offense speci?ed in section 943.325. the defendant shall be required to submit blood specimens. - ENTENCE The Court hereby stays and withholds imposition of sentence as to countts) and places the Defendant on STAYED Probation and/oil Community Control under the supervision ofthe Dept. of Corrections (conditions ofprobation set forth in separate order). SENTENCE DEFERRED The Court hereby defers imposition of sentence until The Defendant in Open Court was advised of his right to appeal from the Judgment by ?ling notice of appeal with the Clerk of Court within thirty days following the date sentence is imposed or probation is ordered pursuant to this adjudication. The defendant was also advised of his right to the assistance of counsel in taking said appeal at the expense ofthe State upon showing of indigency. DONE AND ORDERED in Open Court at Palm Beach County. Florida. this 15, day om . 2003 - . Case 18-286.ocument 26282.9age465 of 648 PLEA IN THE CIRCUIT COURT THE FOL OWING Is To ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: J: LUIS 261C Wax/Wm, Plea: Guilty _X7Guilty/B?s) Interest ContendereU_ No. Less?er _eg_D ree 801W GI: MIT H. II. KEN, CL I DEBIT- IF PSI: Waived/Not Req . ed/Requeste {13: a. II ADJUDICATION: Court?s Discretion If the Defendant Is convicted 1? or conspiracy to sess sell or traf?c' In any controlled substance. the Court directs the Department of Motor Vehicles and Highway 1 . - . Wefendant driver?s license for two (2) years. If the Defendant' Is convicted of grand theft of a motor vehicle; theft of motor vehicle parts; or, any felony mission of which a motor vehIcle was used the Court directs the Department of Motor VehICles and Highway Safety to revoke the Defendant?s driver?s - - as mandated bylaw. The Clerk' IS directed to make the proper notifications. SENTENCE: Fine 5 Court Costs Drug Trust Fund Cost of Prosecution Public Defender Fees/Costs Incarceration: Days Months Years wit creditfortim/ezsewed; which is days. 0 ATION: onths ars- Drug Offenderi ALL CONDITIONS OF ROBA UST BE SFULLY COMPLETED NO LESS THAN 30 DAYS EF RE I PROBATION IS SCHEDUL TERMINATE UNLESS STATED BELOW. m5 STANDARD CONDITIONS OF PROBATION HAVE BEEN EXPLAINED BY DEFENSE COUNSEL. a. CONDITIONS OF PROBATION: Restitution rthe accompanying order. check if ordered) $7 360 a) FineLji Court Costs: Drug Trust Fund. 5373 00 Cost of Prosecution 5 9 Public Defender Fees/Costs ff Substance abuse evaluation and successful completion of recommended treatment ordered) (enroll within 30 days) If in custody, release only to D) Random Drug Testing at Defendant? expense (check if ordered) ?oiw E) hours of community service at a rate of no less than hours per month F) Incarceration: Days Months . . . with credit for time served; which is days. 335 ?haw-TM OTHER COMMENTS 0 . he 5% . A UTE. .420 UIJJUW I, a Kare MM SENTEN - r\ d?br?h THE of? . OR IS ARRESTED ON :1 CHA GES. A PIA wui?h E0 A {1:1 (I: ice Own In} re. atons if a rg ed 1:114; a 3 It .. . for Dfendant ASSIs ant 17M X. xg/M/hGM- Date of Plea DEPUTY CLERK Defendant A . Ba?k A lhnn?? . Case 18-2868; Document 278,- 08/09/2019, 2628230, Page466 Of 648 In the'Circuit Court of the Fifteenth Judicial Circuit In and For Palm Beach County, Florida CaseNo. blotlzab Division: VJ STATE OF FLORIDA vs. he ref?; it . wltuJiri 1?qu Fmi'ii?, ?g \Muwl Defendant I ORDER MODIFYING THIS cause has come before the Court on the Defendant's Violation of Probation. Upon consideration, it is hereby: ORDERED AND ADJUDGED that the Defendant obation 15 modi?ed as follows: OWipd/?hOt/i Mil/re vinyl k0. Monti/6 hut-WW ri? wili AM (Liam mm!? Defendant admits the Violation ofBrobation. All Original terms and conditions to remain in effect. El Defendant is sentenced to days/months Palm Beach County I ail with credit for days. I I DONE AND ORDERED this day of 20 0,13 STATE or FLORIDA . PALM BEACH coumr a I hereby certify that the foregoing is a :11, q, true copy of the record in my office 1' 1" I 5 AA /Circud Judg/ - 5? DEPUTYCLERK 35 MAY 25 2955 . Case-182868 ocument~278, 08/09/2019, 2628230, Page467 of 648 ooTs NumDoi' PROBABLE CAUSE AFFIDAVIT I. An 3. Muesli lor Wetranl Juvenile '2.NT.A. 4. Raquesl for Capias .2. Agency om Numw 1 Agency Nam. Agency Report Numboc gm 5 0? ol 0 PALM BEACH COUNTY OFFICE 6 1-10 "11 L, 11(7111 1 gaggl?ymny i 1. Faiony J. Misdemeanot 5. Ordnance . 2. Traf?c Felony a. Traf?c Misdemeano: 6. Other .. ?15 Name1Lm. whammy) _A?u Rance Sex :1 1- rem-151a . (Sn-megm'. 1 (a Charge Doscr tnon ?1 Charguo criptiOn 41121 Charge De puon Charge Du?lpuon Viaim'sNamelLut.F 31:11.11 Race So: Damn! 81m: 1.151301 11% 111mg LicelAddruHSIwet. DTP. N'ta'rnbel'P' (CW) 9 . Phone . ?(1111555011113 1 9 no (51.1) 383-03213 111m} 5 . 3113111115 Ador?eas?T?mo Street) ily) 1m ID Phone Occupanon 5 mm, 16 The undersigned certi?es and swear: that helshe has just and reasonaolo grounds to beliave. and does bciiovo that the above named Delendant cornm1ned,tne Tho Person taken into cuuody. committed the below acts in my presence.- yin: observed JA mad ngko?? confessed to - that helshe saw the anested person cornmit the below acts. admitting to the below lacts..- -. On the day ot- following Violation oi law. was lound to have cammited the below acts from my (described) investigation. DAM. Cl (Specifically include facts constituting cause tor arrest.) .- .. '3113"?ng . 1 051$) _nmnnorjs Vina?! Tings. 1 An?i?x 130?,an hind 1mm mmom 011:} (3nd 1 a? (A i. . PncmeLECAufSI?z sfmeugsm {312131 b.1313 A _{15 ??nd . -. - STA -.. FLORIDA hail (911111 7191 [am/.1 - wownonpusonanymawniome lain-1-1- .13Pam .?mdc'v mm DISTRIBUTION: ??75 - CONCOPV GREEN - Slat! Mom-v YELLOW Aconcv PINK .. Anmvv . ?1 if . Case'18-286 ocument-278, 08/09/2019, 2628236Pag-?468 Of 648 0915 Number PROBABLE CAUSE AFFIDAVIT l. Ant-1 3. Request for Warrant 4mBowen for Canine 2-5 Ag?nc?y ORI Nunbet Agency Meme . Agency Renae Nu ?1 gm 5 o, PALM BEACH COUNTY OFFICE 0 61-16 1621-1 711C211, 7111 . 11 $11:wa FWW 3. Misdemeanor Be 5. Ordinance. Special News; 2 Tlettic Felony Tn?lc Misdemeanor .omr . u; NemetLaet. FIWII) Alia 1' Rece Sex 3? (4)07 03 Deecmmn r9 cosmipiion Lu 11311111ij ?1 11.1%: $112 . Charge Description chu??g D'scriplion 0 . 11711 111111111x 1: 'm LocalAdd Iut mil 1 I (Cay) {@1410 e) d: (2.) (Phone :gaems 11169 i . 1? a "Mealtmmo14,012 I hatch 032 (30c fog in far - mesa . K, I: 1. ID I ?981533-The undersigned certl?e and sweet: um helshe has just and reasonable rounds to bellow.- and do ve the: the ewe ed Oet dent comm tree the I I The Persm. tel-en htci?piitody 9 913? i owing vioetion .1111 a Lei NC. I committed ihe?beibw ?1111:1313 my presence - . 1 Ignaz: observe?dgyb LL19 Eni- CI confessed to . - heletto saw the arrested person cummit the below acts. admitting to the below facts. . was to'und to have commited the below acts resulting lrom my (described) Investigation. VICTIM .. Onlhe CIA. M. P. M. (Speci?cally include facts constituting cause for Ianest) day of .l .11. .353. 7 I u- lie-.1'11 ..J . -11 1:1- . I -. - . PROBABLE CAUSE STATEMENT .1 fig-J $31? .?tIiL15,111,315": 16%? {:33 31%; :1 macaw? 1 31:11'11: gird? .ZOFI-A uw?mru? K??bnff?ftw?l"?! Demo. 1110111 Hum 1. 11mm Mum . ~11. 1:1 11. 1111111 1 \11111 $111111: 1 1 1 1 Air-1* Ht?? {into )1 ?21 ?Zrt'3~0? ihaI-mlm LII-lick} 3159mm NF?OAtmTOmquith I I XCOVF I I. 11151 Hath?? I .59" - 2-1 - omnmmemrsm?ymownioinu [-04 ., 1 63.3.1731? 7 ?r 56/ 0291'? . WHITF Chm-t C?rw Emu?1 VCI Inn: AOMINISTRATIVEI I I CatSe 18- -2&3Document 278?, 08/09/2019, 262828 Page469 of 648 Numoe!? PROBABLE CAUSE AFFIDAVIT i. Arrest 3. Request for Warrant Jm?fl. I I 2. N.T.A. d. Request lo! Cecil: ZI Assn-Icy ORII NurtIOet I I I AgetIhcy Nine Agency Num o, PALM BEACH COUNTY SHERIFFSOFFICE 6 ?:th 7 fr, 7m 1i gar: ?11133, g? 3- Misdemeanor s. oIdinanco apply. 2. Traffic Felony 4. Traffic Miiaomeemr 6. Other .. Lg Nameth. First. Middle)? Ins Fl 0 Sex 8? 4:9- 1? \in art; I PK fun (a Description 6 mp?llon ?ftml - Charge Dmriptlon Gi'arge Description 0 I Victim' Na eLLast ?rst. Mica?) Race :53: PM: Finn Local mares: ?Sfreet'. Agni? 'Ju? (Stare? [at Phone Address SourE? 9. tr 0 I iamIneisrAdhnisImIimo. S'H?'et?l - (City) (State . ?*Fiiona ?m5 . I the uncon?ned cpm'fiuand NunWhuaM has just and reasonable grounds tabelieve. and does believe that [he (above) named fondant CDmrI'Irlted the MI wing mutation at law Yhe Fe IIan Into custody I committed the below acts in my presence. . was observed ?I'm IWIOU - I . . confessed to at helehe saw the arrested person commlt the below I admitting._to the below facts. as found to have commited the below acts. resulting from my (dIIucribea) investigation. the at 20_ at DKMJ: PM. (Speci?calry induce facts constituting cause lor arrest2-3-77; - -. ~35, mm (In-em a 4 - mm? I111 kph-u nun-3n23,3" .gW31? ~49: :5 110 0 RY. _inIn 033 3\ . nDY:i (31f) R51: 11356.2 10mm . 3mGm: 101% 1 W10 I II ~t-Ixmt 1w!? AT ?f3 mm ii) cnuse STATEMENT . u. 'm-i I thIe tyne; me. tangent; is a .3:th cog?itwowd?nmy atfumtrta a? 16? I- grey-315.1: I . LEI ONR. BIOQE - - A I DEPUTY CLERK- ADMIWRATIVE rt :er .Of?cer (ESHS 117. DIAMA an; mm WHITE -- COURT Copy GREEN State Attorney - YELLOW ~30ch . PINK - Aoencv Case 18-286 Document 278', 08/09/2019, 262860, Page470 Of 648 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA CRIMINAL DIVISION (CGS) STATE OF FLORIDA CASE NO. 02CF012206A02 BOOKING NO. 2002343590 vs. ANTHONY LUIS ZAC FIGUEROA, WM, 0 :1 INFORMATION FOR: if" GRAND THEFT In the Name and by Authority of the State of Florida: BARRY E. KRISCHER, State Attorney for the Fifteenth Judicial Circuit, Palm Beach County, Florida, by and through his undersigned Assistant State Attorney, charges that ANTHONY LUIS ZAC FIGUEROA on or about October 24, 2002, in the County of Palm Beach and State of Florida, did knowingly obtain or use, or endeavor to obtain or use video games of a value of $300.00 or more, which was the property of HOLLYWOOD VIDEO, or any other person not the defendant(s), with the intent to permanentlyorternporarily deprive HOLLYWOOD VIDEO or any other person not the defendant(s) of the property or bene?t therefrom or to appropriate the property to the use of ANTHONY LUIS ZAC FIGUEROA or to the use of any person not entitled thereto, contrary to Florida Statute 812.0140) and (3 DEG FEL) FL. BAR NO. 0928 3 Assistant State Attorney STATE OF FLORJDA COUNTY OF PALM BEACH Appeared before me, JILL ESTEY RICHSTONE Assistant State Attorney for Palm Beach County, Florida, personally known to me, who, being ?rst duly sworn, says that the allegations as set forth in the foregoing information are based Upon facts that have been sworn to as true, and which, if true, would constitute the offense therein charged, that this prosecution is instituted in good faith, and certi?es that testimon under oath has been received from the material witness or witnesses for the offe e. Sworn to and subscribed to before me this I day of October, 2002. NOTARY PUBLTC, State of Floh'da or FLORIDA . mu BEACH comm .- . - ihmeny certifythat the '2 ?53 Ellen Jord VFCIC 11:3 :93- GRAND THEFT .1 ?ecember28.2ooz Nose mau worm? INSURANCE, wc ?g ?j Case 18-2 Document 278, 08/09/2019, 2628 Page471 Of 648 Qt IN THE CRIMINAL DIVISION OF THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA. .N 11:36:12 OBTSNUMBER UR BK ?72. PG 1937 Palm Beach County, Florida STATEOF FLORIDA 1] COMMUNITY Dorothy H- Hill-ten, Clerk - CONTROL VIOLATOR V. PROBATION DEFENDANT RACE VIOLATOR H. . ff; . The above Defendant, being person I 1* Having been tried and found guilty of the following crime(s); Having entered a plea of nolo Having entered a plea of guilty to contendcre to the following the following crime(s): crimc(s): h? COUNT RIME . OFFENSE STATUTE NUM DEGREE . W. We 3E and no cause having been shown why the Defendant should not be adjudicated guilty. IT is ORDERED THAT the Defendant is hereby ADJUDICATED GUILTY of the above crime(s). I and having been convicted or found guilty of. or having entered a plea of nolo contendere or guilty.regardless ofadjtidication. to attempLs or offenses relating to sexual battery (ch. 794). lewd and lascivious burglary 810.02). carjacking 812.133). or home i defendant shall be required to submit blood specimens. conduct (ch. 800). or murder (5. 782.04). aggravated battery (5. 784.045). nvasiOn robbery SIZ. I35). or any other offense speci?ed in section 913.325. the SENTENCE The Court hereby stays and withholds impositieguil?lientence as to countts) and places the Defendant on STAYED Probation and/or[ Co? . lib)? orgroal the supervision ofthe Dept. of Corrections (conditions of probation set forth in separate or ts cc mt SENTENCE fin mfg; \a DEFERRED oil Iling notice ofappeal with the Clerk of Court within thirty days 'lOl?l. The defendant was also advised of his right to the assistance ei?r?ia. this day of . 2003 W14116 Officer: 15-3 ff?? i JUDGMENT 0F GUILT I, EB AND PLACING DEFENDANT ON PROBATION ?at: e3? STATE OF FLORIDA In The Circuit Court -vs- Plaintiff of Palm Beach County, Fl ANTHONY LUIS ZACFIGUEROA Case No. 02-12205CFA0293 Defendant 1 ?18 'er lid 93 This cause coming on this day to be heard before me, and you, the defendant ANTHONY LUIS ZACFIGUEROA, being now present before me, and you having: PLED GUILTY TO The offense of COUNT 1. GRAND THEFT the court hereby adjudges you to be guilty of said offense; and . It appearing to the satisfaction of the Court that you are not likely again to engage in a criminal course of conduct, and that the ends of justice and the welfare of society do not require that you should suffer the penalty authorized by law: Now, therefore, it is ordered and adjudged that the imposition of sentence are hereby withheld, and that you are hereby placed on probation for a period of EIGHTEEN Q8) MONTHS CONCURRENT WITH 02-12205CFA02 under the supervision of the Department of Corrections and its Of?cers, such supervision to be subject to the provisions of the laws of this State. It is further order that you shall comply with the following conditions of probation: (I) Not later than the fifth day of each month or as directed, you will make a full and truthful report to your Probation Of?cer on the form provided for that purpose. (2) You will pay to the State of Florida the amount of 50.00 FIFTY DOLLARS per month, plus a 4% surcharge, toward the cost of your supervision, unless otherwise exempted in compliance with Florida Statutes. (3) You will not change your residence or employment or leave the county of your residence without ?rst procuring the consent of your Probation Officer. You will neither possess, carry or own any weapons or ?rearm without ?rst securing the consent of your Probation Of?cer. (4) G) 1 . 01213 817910 8982'813 3319 \ko . . Case 18-2868 Document 278; 08/09/2019, 2628230, Page473 of 648 . ZacFigueroa, Anthony Case 02-12206CFA02 (5) (6) (7) (3) (9) (10) (11) (12) You will live and remain at liberty without violating any law. A conviction in a court of law shall not be necessary in order for such a violation to constitute a violation of your probation. You will submit to Urinalysis, Breathalyzer or Blood tests, as directed by your Probation Of?cer or the Professional Staff of any treatment center where you may be reCeiving treatment, to determine the possible use of alcohol, drugs or controlled substances. You will make a good faith effort to obtain lawful employment and support any dependents to the best of your ability as directed by your Probation Of?cer. You will and truthfully answer all inquiries directed to you by the Court or the Probation Of?cer, and allow the Of?cer to visit in your home, at your employment site, or elsewhere, and you will comply with all instructions he may give you. TO: HOLLYWOOD VIDEO IN THE AMOUNT OF $1000.00 MINIMUM PAYMENT OF $55.56 PER MONTH CRO FILED NO CONTACT WITH HOLLY VIDEO 1N PALM BEACH CO. ENTER AND COMPLETE: THEFT ABATEMENT PROGRAM AUTOMATIC EARLY TERMINATION AFTER 12 MONTHS PROVIDED ALL CONDITIONS ARE SATISFIED You are hereby placed on notice that the Court may at any time rescind or modify any of the conditions of your probation, or may extend the period of probation as authorized by law, or may discharge you from further supervision; and that if you violate any of the conditions of your probation, you may be arrested and the Court may revoke your probation and impose any sentence which it might have imposed before placing you on probation. It is further ordered that when you have reported to the Probation Of?cer and have been instructed as to the conditions of probation you shall be released from custody if you are in custody and if you are at liberty on bond, the sureties thereon shall stand discharged from liability. . Case'l8-2868 Document-278, 08/09/2019, 2628230, Page474 of 648 ZacFigueroa, Anthony Case 02-12206CFA02 It is further ordered that the Clerk of this Court ?le this order in his of?ce, record the same in the Minutes of the Court, and forthwith provide certi?ed copies of same to the Probation Of?cer for his use in compliance with the requirements of law. DONE AND ORDERED IN OPEN COURT THIS 15TH DAY OF JANUARY, 2003. Signed this day of ,2003. 91.0. 1441 I acknowledge receipt of a certi?ed copy of this order and that the conditions have been explained to me. Date: Probationer Instructed by: Original: Court DC4-9OOA Copies: ProbationerfFile JF 1/ 16/03 STATE OF FLORIDA - PALM BEACH COUNTY hereby certify that the foregoing ?agthe reborn 111 (W 0mm 3 ?rms- Case 18-286wocument 278, 08/09/2019, 2628230, Page475 of 648 In the Circuit Court of the Fifteenth Judicial Circuit In and For Palm Beach County, Florida . 020112119111: new. Case No. Division: STATE OF FLORIDA 101' L: :31 A151 Pt?uem-L Defendant 2 His; ORDER MODIFYING PROBATION -- THIS cause has come before the Court on the Defendant's Violation of Probation. Upon consideration, it is hereby: ORDERED AND ADJUDGED that the Defendant' sP obation' 15 modified as follows: Ov?? bale-?o 1/1 in 1121/10 a, @1111th wtihw bid/1 ?111% UJ L1 WKMD 0? . Odom 0.1/ aimed/16121 1. Gamma,? CL 0.11/11 H, em MMwel?Lc level HM Defendant admits the Violation ofProbation. All Original terms and conditions to remain in effect. 1:1 . Defendant is sentenced to days/months Palm Beach County Jail with credit for . days. - DON AND day of 31175?? 20 0 if?" . STATE OF is a {1e11, 1-23? 1 hereby cent that the {megomg 11 in ?11' bottles: with py 01' th? NEW 1 ji%i0nsh if? a r3"; 0m R3013 W90 ?1 CLE 11- 9, FL0 DEPUTY CLERK 3?1 .7 &8 18-28 Document 278, 08/09/2019, 2628230, Page476 ofg455 NOTICE TO APPEAR . Juvenile Refena 2. N.T.A, MUG: 8" Warrant Juvamlo OBTS Number2 5 0 0 1- Wow 3. modem-no: as apply. 2. Traf?c Felony Location or Arrest (Indudng Nema ol OFFICE 6 - 5. Ordinance legible . . erance c. Tre?nc Mledemunor 6. 0mm 1 Indicator ADMINISTRATIVE LocaIiOn of (Business Name. Address) arrest Jeil Dale ame Locenon 0! (Last. Middle) I Rm Allan (Name. Soc. - - American Indian 8 - Bleak 0- 5 81005, Unlque Alcohol Influence In?uence - I. City 3. Florida 2. County 4. Out 01 Sun: Address Samoa 4 usiness Address (Name, StreeI) - (Slate) Occupallon DEFENDANT Of CD-Doiondam Name Date oi Parent (Firsu (Muodla) - Legei Cumodun Other: (Street. Am. Juvemle - . within 2, TOT Has/ms Dept. and Released. 3, NVENILE above address and I I . [hi Juvenile 833A (Bank?s g" or Dawn wu told . scrum} Amended Yes. by: - T730 . . Unknown Producol. A . Cocaine N. . . 0(h P. Possess T. A Herom o. . . 2 Dow-prion Counts Domestic VIoIatioI-I Number WOI I CY I Capias Number Bond Vlolation of 080 0 Drug Drug Amounll Unh CHARGE Number Violation DI 0RD 0 I I DY Drug Drug Amount Unit CHARGE Warrenl I Capiu Number 80er 17' Count: Domestic SmuIe Violation Number Vlolen c_o Violmion of CEO I CHARGE Wenem 1 Nu be! Bond Smule Violalion Number - V-oialion 0! 090 CHARGE Drug Type Amoum 1 Unit I Cepdae Numbel '3 c. CouanendTarne Locetlon (Coun. Room Number, AddressMoan-I You Tlme AM. . rm. if?? I AGREE APPEAR AT THE TIME AND PLACE DESIGNATED To ANSWER THE OFFENSE CHARGED on PAY THE FINE SUBSCRIBED. I SHOULD I WILLFULLY FAIL To APOPEAR BEFORE THE COURT As REQUIRED arms To APPEAR. THAT I MAY BE HELD IN CONTEMPT 0F COURT AND A FOFI ARREST SHALL BE ISSUED MTICE T0 APPEAR Signature at Defend-m (or Juvenile and Parent! Custodlm) Dam Signed HOLD 107 who! Agency Name.- Dlngerous Reeieted Men of "?65 ID. Other. AH Mn.) LD. 0 Tremponing LD, tr gnu Name thicetion (PnnIad by Arreeree] Ime?swpaeagned an"X 12 OF P850 DISTRIBUTION: WHITE - COURT COPY GREEN - STATE ATTORNEY YELLOW - AGENCY PINK - AGENCY GOLD - DEFENDANT (N.T.A.'s ONLY) 0 m7 The undersigned unifies and . The Person 13km into Custody? a committed the below acts in my presence. confessed to that- helshe hos lust and reasonable grou to helium. and does believe that tho above named Dalendant Case 18-28 Document 278,08/09/2019, 2628230, Page477 Of 648 OBTS Numbe' - PROBABLE CAUSE AFFIDAVIT 1. Arrest 3. Reouest for Warren! Juvemlo 'Roquut for Caain Agency OFit Number Agency Name Agency Report Number 9 ml 5 o. 01 PALM BEACH COUNTY OFFICE 1 61101 t) A ll2 I ll Emaialvr?tgny ?g ??057 3. Mlsdemoanor 5. Ordinance SpeCIal as apply Tra?rc Falony 4. Trattic Misdomaanor 6. Other b? Last. First. Middle) Alias? Race Sort a ?warm AM to Cmem Charge Description m? Charge Description Charge Description I. ..- I. . yum-1 5. Victim' 3 Name (Last F- wot. Middiot Raca 5.: Dale 0' Berth /..11111 Local Address Irut. Apt Numbort" (City) [Surat (Zip) Phone Address Scum . again.? mattress (Name. 5 (Sign Phone OccupatIOn 134 I the following violatpn 0! Int admitting to the below tacts. I. dayot OC?bbir On the was observed by Whoa told j/S Dnsux) .. that helsho saw the arrested :3 son commit the b_elow acts. was lound to have commited the below acts. resulting from my (descn'bed) Investigatlon 20_0_2u DA M. at P. M. (Specilic'ally include facts censtituting cause tor arrest) 4-. .13 l? 0 (.2. WM I ?j SEC) ?612'! Q9194 ?Btegh [mmiic (15,293?: 14:0 A P850 (?ka +wb MISS lath} a?tnghA 55f Storiit: ?Dk (molev K153 ?7 Video 6; PA) hookah ok?err ?k0r+s {3 Qinds?hhoro .3 7?30! miss. 639mg; . . PROBABLE CAUSE STATEMENT b- Ncl. ?me. QXal-z . . .I?ctng EA rL curtl?y that the oreg-I - . up)" at the) racers pug/v a DEPUTYCLERK GM LOFJ. DISTRIBUTION: I WA nah. WHITE Court CODY GREEN Stats chInw Ana-w? Case 18-2868, D.ment 278, 08/09/2019, 2628230, @8478 Of 648 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION DS JASON VANDUSEN, 6142 CASE NO. 02CF012204A99 PALM BEACH COUNTY SHERIFF OFFICE Booking No. 2002343586 Agency case number 02?12882] 33 STATE OF FLORHDA - (?It vs. . 1:3 ANTHONY LUIS ZAC FIGUEROA, If NO FILE FOR: GRAND THEFT The State enters a no-?le because the elements of the crime cannot be proven beyond a reasonable doubt. BARRY E. KRISCHER, STATE ATTORNEY DATE: October 28, 2002 5 By: JILL ESTEY RICHSTONE Assistant State Attorney FL. BAR NO. 0928933 CLERK AND SHERIFF T0 RESCIND N0 CONTACT ORDER $1532 or mama - PALM BEACH COUNTY .3 . Dummy cartily that the foregoiflg .J . .. .0. m, ?1 Con-1 in my of?ce .53 (2005. sr by 3.2.15." ws? mm (545 Page479 of 648 SI Requesl tot Wa'ranl 5. Recuest Caplas 08 I Numhat tom 262?. ROYAL PALM BEACH POLICE DEPARTMENT 3. Misdemeanw 6. 4. Traflic Misdomalnor 6? Other Agency ORI Number FLO 5 0 2 we check as many as 0 0 800 1A Felony 2. Traf?c Felony 3812 . (Last First, Mk1 ierAn Cna'ge Desc?plion Oil on Luis Zac Grand Theft Auto Charge Desorption Charge Description CHARGES DEF. Victim's Name Fl uero 'chartlie) Jr. VICTIM (Stale) undersigned and swears that ho/she The Person taken into custody and reasonable to believe, and the above named Committed v:olalion ct law 8' committed the below acts in my presence. I: was observed by I: coniessed Io admitting to the below facts. On lne 22nd day of 20% at -lzi 8 AM. PM. (Specifically include facts constituting caUSe for arrest.) eroa, Jr., who told me that he allowed his brother Anthon to use his 1986 Mazda who told that heishe Saw the arrested pexson commit the below acts was iound to have committed the below acts. resulting from my (describes) investigation I met with victim Richard Fi rive a ome to ut ick-u truck were 110 to 521 not sa . or etr 8W0 minutesseriousness a -out this form a an was concer nce ut esame I ve to n. extent at co 5 one tate a to atw0r ntemornn Ata ut eva weres assess ono i do ri the .m'l was er ll 0C2 were near un er seateret etwo ueroa, nee rs! ad ica contro arrest or esam a 11 Auto. 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ADDITIONAL PROBABLE CAUSE: At a ve ate a time, was sou CIIO na to an maroon report on a was a2 a truck whic stolen car case. ce station ta 0 r. cust secure an owner an I. ect ects were over to etot cl PROBABLE CAUSE u, swoon AND BEFORE ME 2 l- 0 0A SIGNATURE OF ARRESTING I INVESTIGATING OFFICER FFI ER NOTARY UBLICIC KOF CCU TIP T. by #100 1 0'22?00 NAME OF OFFICER (PLEASE PRINT) DATE 10-22-00 DATE PINK -- Agency - DISTRIBUTION: WHITE - Court Copy GREEN -- State Attorney YELLOW-- Agency Case 18-286iocument 278; 08/09/2019, 262823Page481 Of 648 JB I . . Case No.: ST ANTHONY LUIS ZAC FIGUEROA Charges: GRAND THEFT (MOTOR VEHICLE) Arrest# 2000346620 Bond# 7-5 Type 3 3,000 AJC Date a Judge L n?m Crt.Rep.__ I ASA 2-6?ma manic. r_ DC HTRL nt Pres. - Def. 'Co. \3 K.) Cb Esq (TD-E Not Pres. Before Court for: I I (DOS) I ?bf?b CI Granted CI Denied CI With Without Prejudice. CI Withdrawn CI Court Rese?rveSRuling CI Written Order to Follow Warrant Cl Ordered CI Recalled CI Bon tat CI See_B.elow Also Covers Sp Cond Bond Forf OR: Disch Revoked Reinstated Bon evoked Reinstated CI SOR: Disch Revoked Reinstated Bond Forf Vacated Previous Bond Reinstated, if onds - .3 ees_ State failed to ?le charges ReleaSed O.R. CI Deft'__ Indigent CI PD Appt only PD Pres Court Appts Evaluation for: Drug Farm DOC Non-Secure Bed by Pre-Plea CI PSI ordered by/within days CI w/input from DJJ Staffing DEFT ENTERED OF: CI NOT GUILTY CI GUILTY As Charged?Cts CI NO CONTEST CI BEST INTEREST To THE COURT Lesser Lesser Charge - SW Test CI?Adv-of CI Waived PSI Lesser Lesser Charge ADJ GUJLTY as Chargedas to I Lesser CI FOUND GUILTY as Charged as to Lesser . El ADJ as to SENT as-to . . . Cl FOUND AND ADIUDICATED DELINQUENT as to I CI Order gollow Filed CI POUNDS: ADJ NOT GUILTY as to Cts' - CI Dismiss Nolle Prosse .- I - Prob/ Comm Control: CI Revoked CI Reinstated CI SEEORDER ASSESSING COSTS SEE REVE Modi?ed Term. SIIC'cessfully I Unsuccessfully RSE SIDE FOR INSTRUCTIONS REGARDING FURTHER HEARING CI Stip/Found: (violent) Habitual Off. 775.034 - Stip/Found: Sexual Offender/Sexual Predator CI Stip/Found: P.R.R. SENTENCE: PBCJ: Cts: IDOC: - Cts: PBCJ: Cts: - IDOC: . . I i Cts: Cl W/Credit for - Days MOS-I Yrs. CI Deft R'emanded .Cl Deft to remain on Conc I Consec I Co-Tertn w/cases I cts: . ame rel. status pending sent. CI Execution of Sentence Stayed CI SentOnce Suspended CI Time served as to Cl YouthfulOff CI Habitual Off Min/Maud: as to El ABOVE SENTENCE FOLLOWED By: CI Probation CI Drug OffProb CI Comm. Control CI I CI 1] ?SeePageZ FATE FLORIDA . PALM BEACH 000m. I I 1 011qu 'v?v'iw 95?; mm (5919?! . Set Remai 0yTHISDW UM OF Setl Remainsn Rm at l" CIDeftsign A - Def Co CI ASA EJWY OLE CI Bondsman El Prob CI Jail DJJ CI GAL Noti?ed by mail by: on . I I CountyCourthouse CI Courtroom, Criminal Justice Bldg. . CI Courtroom, Criminal Justice Complex 205 N. Dixie, West Palm Beach 38844 State Road 80, Belle Glade 3228 Gun Club Rd., West Palm Beach IF YOU ARE A PERSON INITH A DISABILITY NEEDS ANY ACCOMMODATION IN ORDER To IN THIS PROOEEDINO. 'vou ARE ENTITLED, AT NO COST TO YOU. To THE PROVISION OF CERTAIN ASSIST ANOE. PLEASE CONTACT THE OFFICE or THE COURT - 205 NORTH DIXIE 5.2500. ag??mmoh TELEPHONE (501) 355-2431. 2 INORKING DAYS on YOUR RECEIPT OF THIS NOHCE. IF YOU ARE HEARING INPAIRED. CALL 1-800-955-8771; IF VOICE RE . 1-500-055-3770 Form 61] Case 18-2868, Document 278, 08/09/2019, 2628230, Page482 of 648 EXHIBIT GG Case 18-2868, Document 278, 08/09/2019, 2628230, Page483 of 648 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 21, 2016 9:17 a.m. C O N F I D E N T I A L Deposition of JOSEPH RECAREY, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 18-2868, Document 278, 08/09/2019, 2628230, Page484 of 648 Page 2 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 A P P E A R A N C E S: BOIES SCHILLER & FLEXNER, LLP Attorneys for Plaintiff 401 East Las Olas Boulevard Fort Lauderdale, Florida 33301 BY: BRADLEY EDWARDS, ESQ. HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant 150 East 10th Avenue Denver, Colorado 80203 BY: JEFFREY PAGLIUCA, ESQ. JONES FOSTER JOHNSTON & STUBBS, P.A. Attorneys for Deponent 505 South Flagler Drive Suite 1100 West Palm Beach, Florida 33401 BY: JOANNE O'CONNOR, ESQ. ALSO PRESENT: Sandy Perkins, Paralegal Boies Schiller & Flexner 17 Ryan Kick, Videographer 18 19 20 21 22 23 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page485 of 648 Page 3 2 3 4 5 6 7 8 9 10 11 I N D E X Examination by Mr. Edwards .................... Examination by Ms. Schultz ..................... Examination by Mr. Pagliuca .................... Further Examination by Ms. Schultz ............. Further Examination by Mr. Pagliuca ............ E X H I B I T S Deposition Exhibit 1 ........................... Palm Beach Police Department Incident Report Deposition Exhibit 2 ........................... AH statement 9 123 165 329 355 11 59 12 13 14 Deposition Exhibit 3 ........................... CD with video (retained by Boies) Deposition Exhibit 4 ........................... Search warrant return 66 69 15 16 17 Deposition Exhibit 5 ........................... Property receipts Deposition Exhibit 6 ........................... Additional search warrant returns 76 77 18 19 20 Deposition Exhibit 7 ........................... Probably cause affidavit Deposition Exhibit 8 ........................... Trash pull return 84 96 21 22 23 24 25 Deposition Exhibit 9 ........................... 102 Folder with evidence Case 18-2868, Document 278, 08/09/2019, 2628230, Page486 of 648 Page 4 2 Deposition Exhibit 10 .......................... 119 Investigative report 3 Deposition Exhibit 11 .......................... 165 4 5 CD with audio recording (retained by Boies) Deposition Exhibit 11 .......................... 178 Supplement to incident report 6 Deposition Exhibit 12 .......................... 259 7 8 Rule 26 disclosure Deposition Exhibit 13 .......................... 282 Vol. 2 of prior Recarey transcript 9 Deposition Exhibit 14 .......................... 292 10 Vol. 1 of prior Recarey transcript 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 *** Exhibit 11 was used on two different exhibits. Case 18-2868, Document 278, 08/09/2019, 2628230, Page487 of 648 Page 10 1 2 JOSEPH RECAREY - CONFIDENTIAL Q. Most of the events that we are going to 3 discuss today occurred, at least the investigation 4 that we're going to discuss today, occurred in 2005 5 and 2006. 6 So can you just tell us what your position 7 was with the Palm Beach Police Department at that 8 time? 9 A. I was a police detective. 10 Q. And did you investigate a person by the 11 name of Jeffrey Epstein? 12 A. I did. 13 Q. All right. 14 15 16 17 18 What was your role in the investigation of Jeffrey Epstein? A. I was the lead detective once the case was turned over to me by Michelle Pagan. Q. Okay. And as the lead detective, did you 19 review all of the history of the investigation up to 20 the point it was turned over to you? 21 22 MR. PAGLIUCA: foundation. 23 24 25 Object to form and THE WITNESS: Correct. BY MR. EDWARDS: Q. And was that one of your jobs as the lead Case 18-2868, Document 278, 08/09/2019, 2628230, Page488 of 648 Page 11 1 JOSEPH RECAREY - CONFIDENTIAL 2 investigator over a case, is to acclimate yourself 3 to the history of the case? 4 5 MR. PAGLIUCA: foundation. 6 7 8 9 10 Object to form and THE WITNESS: Yes. BY MR. EDWARDS: Q. Just so that the record is clear, will you just give a brief pause in case Mr. Pagliuca has an objection? 11 A. All right. 12 Q. So they can also capture your answer. 13 A. Okay. 14 Q. In reviewing the history of the case, did 15 you review prior police reports, police reports 16 prior to you becoming involved personally? 17 A. I did. 18 Q. Okay. 19 And I've handed you what is marked as Plaintiff's Exhibit 1. 20 (The referred-to document was marked by 21 the court reporter for Identification as 22 Deposition Exhibit 1.) 23 BY MR. EDWARDS: 24 Q. Do you recognize that? 25 A. Yes. Case 18-2868, Document 278, 08/09/2019, 2628230, Page489 of 648 Page 177 1 2 JOSEPH RECAREY - CONFIDENTIAL Police Department incident report as suspects? 3 MS. SCHULTZ: 4 foundation. 5 BY MR. PAGLIUCA: Object to form and 6 Q. These people, right? 7 A. At that time, yes. 8 Q. Well, and then are you aware -- were there 9 10 any suspects added in any subsequent reports, to your knowledge? 11 A. Not that I'm aware of. 12 Q. In fact, you did not seek a probable cause 13 warrant for any other suspects in this case, 14 correct? 15 16 MS. SCHULTZ: foundation. 17 18 19 Object to form and THE WITNESS: That's correct. BY MR. PAGLIUCA: Q. And Ms. Ghislaine Maxwell is not listed in 20 any of your Palm Beach Police Department incident 21 reports as a suspect in this case, correct? 22 23 MS. SCHULTZ: Object to form and foundation. 24 THE WITNESS: 25 in this case, no. Not -- no, not as a suspect Case 18-2868, Document 278, 08/09/2019, 2628230, Page490 of 648 Page 180 1 2 JOSEPH RECAREY - CONFIDENTIAL Exhibit 1. Are you with me? 3 A. Uh-huh. 4 Q. Okay. 5 Again, this was information that was obtained by Detective Pagan, correct? 6 A. Correct. 7 Q. And it's true, is it not, that this 8 alleged victim never claimed to have been recruited 9 by Ghislaine Maxwell; true? 10 11 MS. SCHULTZ: foundation. 12 13 14 Object to form and THE WITNESS: Correct. BY MR. PAGLIUCA: Q. And this individual, alleged victim No. 1, 15 never identified Ghislaine Maxwell as being at 16 Mr. Epstein's house when she was there, correct? 17 18 MS. SCHULTZ: foundation. 19 20 Object to form and THE WITNESS: I don't believe so. BY MR. PAGLIUCA: 21 Q. You don't believe so -- 22 A. I don't believe so. 23 Q. That she ever identified Ghislaine Maxwell 24 25 as being in the house? A. Right. Case 18-2868, Document 278, 08/09/2019, 2628230, Page491 of 648 Page 181 1 2 JOSEPH RECAREY - CONFIDENTIAL Q. Okay. She never -- this individual, 3 victim No. 1, never claimed that Ghislaine Maxwell 4 paid her any money, correct? 5 A. Correct. 6 Q. And this individual No. 1 never claimed 7 that Ms. Maxwell instructed her what to wear, 8 correct? 9 A. Right. 10 Q. This individual never claimed that 11 Ghislaine Maxwell told her how to act, correct? 12 A. Correct. 13 Q. This individual never claimed to have met 14 Ghislaine Maxwell ever, correct? 15 A. I don't believe so, no. 16 Q. This individual never claimed to even have 17 spoken to Ghislaine Maxwell ever, correct? 18 A. I don't believe so, no. 19 Q. And when you say "I don't believe so, no," 20 that means my statement to you is correct; is that 21 right? 22 MS. SCHULTZ: Object to form, foundation. 23 THE WITNESS: Well, you're saying "ever." 24 25 I don't know if she's ever, ever spoken to -- Case 18-2868, Document 278, 08/09/2019, 2628230, Page492 of 648 Page 182 1 2 JOSEPH RECAREY - CONFIDENTIAL BY MR. PAGLIUCA: 3 Q. To Detective Pagan. 4 A. Right. To my knowledge, I don't know, 5 because Detective Pagan is the one who actually 6 interviewed her. 7 "ever." 8 Q. 9 10 So I don't know to the answer of So not to my knowledge. Certainly, nothing in Exhibit 1, Narrative 1 reflects that this individual ever met or talked to or spoke to Ghislaine Maxwell, right? 11 A. Right. Not to my knowledge. 12 Q. And, indeed, you would agree with me that 13 if this individual claimed that Ms. Maxwell had 14 something to do with the events listed in Narrative 15 1, you would have folded up on it, as the 16 investigating detective, right? 17 MS. SCHULTZ: Object to the form. 18 THE WITNESS: Either myself or Detective 19 Pagan would have. 20 21 BY MR. PAGLIUCA: Q. Sure. And when you got the case six 22 months later, if there hadn't been follow-up, you 23 would have followed up on it, right? 24 MS. SCHULTZ: Object to form. 25 THE WITNESS: Correct. Case 18-2868, Document 278, 08/09/2019, 2628230, Page493 of 648 Page 187 1 2 JOSEPH RECAREY - CONFIDENTIAL Q. Okay. The person alleged to have brought 3 the alleged victim No. 1 to Mr. Epstein's house is 4 this Hayley Robson individual, correct? 5 A. Yes. 6 Q. Okay. Then with regard to alleged victim 7 No. 2, then this individual did not claim to have 8 been recruited by Ms. Maxwell, correct? 9 MS. SCHULTZ: Object. 10 THE WITNESS: Who would be victim No. 2? 11 12 BY MR. PAGLIUCA: Q. Well, you can either go to the second page 13 of Exhibit 1 and we can just follow down the victim 14 information, or you can go to the body of the 15 report, whichever is easier for you. 16 MS. SCHULTZ: 17 MR. PAGLIUCA: Can you use the initials? Sure. I can call them 1 or 18 AH or whatever you want to call them. 19 fine with me. 20 21 That's BY MR. PAGLIUCA: Q. So I'll just say alleged victim AH never 22 claimed to have been recruited by Ms. Maxwell, 23 correct? 24 A. Correct. 25 Q. And alleged victim AH did not claim to Case 18-2868, Document 278, 08/09/2019, 2628230, Page494 of 648 Page 188 1 2 JOSEPH RECAREY - CONFIDENTIAL have spoken to Ms. Maxwell ever, correct? 3 MS. SCHULTZ: Object to form. 4 THE WITNESS: It's been a while since I 5 read this report. 6 7 BY MR. PAGLIUCA: Q. Sure. Is it fair to say, Detective, that 8 this investigation occurred some 12 years ago, 9 right? 10 A. Yeah. Well, yeah. 11 Q. And is it fair to say that you've 12 conducted quite a few investigations over your 13 career? 14 A. Yes. 15 Q. All right. 16 And it's fair to say that it would be 17 impossible for you to remember all the details of 18 this investigation as you sit here today, correct? 19 A. Correct. 20 Q. And you've been referring to Exhibit 1 21 frequently throughout this deposition, correct? 22 A. Yes. 23 Q. And that's because you don't have any 24 25 present memory of these details, correct? MS. SCHULTZ: Object to form, foundation. Case 18-2868, Document 278, 08/09/2019, 2628230, Page495 of 648 Page 189 1 JOSEPH RECAREY - CONFIDENTIAL 2 THE WITNESS: I have some recollection, 3 but I'm not going to have exact dates and times 4 off the top of my head. 5 BY MR. PAGLIUCA: 6 Q. Sure. 7 A. You know, I spoke to over 33 girls 8 regarding this case. So when you say an initial, it 9 takes me a little while to go through the entire 10 list. But to have specifics, I'm not going to be 11 able to remember the exact specifics of -- of the 12 report. 13 Q. 14 I appreciate that. So we can take our time, but do you 15 recall, did AH ever identify Ms. Maxwell has someone 16 she spoke to? 17 A. I don't recall. 18 Q. You don't recall at all? 19 A. I don't recall that she had mentioned 20 Ms. Maxwell. 21 Q. 22 And if she had, you would have put that in your report, correct? 23 A. I believe so, yes, I would have. 24 Q. All right. 25 And so the absence of alleged victim AH Case 18-2868, Document 278, 08/09/2019, 2628230, Page496 of 648 Page 190 1 JOSEPH RECAREY - CONFIDENTIAL 2 referring to Ms. Maxwell means that she didn't, 3 right? 4 MS. SCHULTZ: Object to form. 5 THE WITNESS: Say the question one more 6 time. 7 BY MR. PAGLIUCA: 8 9 Q. When we go through this report, and I've gone through it, if any of the alleged victims had 10 identified Ms. Maxwell as someone that they spoke to 11 at Mr. Epstein's house, you would have listed that 12 in your report, right? 13 MS. SCHULTZ: Object to form. 14 THE WITNESS: I believe I would have, yes. 15 16 BY MR. PAGLIUCA: Q. 17 18 Yeah. You tried to be thorough and accurate when you were writing your reports, right? 19 A. Yes. 20 Q. And, certainly, you've indicated on direct 21 examination that the identity of people who were at 22 the house was something that was important to your 23 investigation, correct? 24 A. Yes. 25 Q. And that's why you did trash pulls, right? Case 18-2868, Document 278, 08/09/2019, 2628230, Page497 of 648 Page 191 1 JOSEPH RECAREY - CONFIDENTIAL 2 A. Yes. 3 Q. And then you asked various individuals who 4 was there when you went to Mr. Epstein's house, 5 right? 6 A. Correct. 7 Q. And you then, to the best of your ability, 8 recorded those answers, I take it, as to who was 9 there, right? 10 A. Yes. 11 Q. And with regard to AH, she never said 12 anything about Ghislaine Maxwell being at 13 Mr. Epstein's house, did she? 14 MS. SCHULTZ: 15 foundation. 16 BY MR. PAGLIUCA: Object to form and 17 Q. To you? 18 A. I don't believe she did. 19 Q. Okay. 20 21 22 23 24 25 And if she did, it's likely that you would have recorded it, correct? A. Correct, and it would be on the -- it would be on the tape. Q. Right. She never claimed, AH, that Ms. Maxwell paid her, right? Case 18-2868, Document 278, 08/09/2019, 2628230, Page498 of 648 Page 192 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 MS. SCHULTZ: foundation. 4 5 6 Object to form and THE WITNESS: Correct. BY MR. PAGLIUCA: Q. She never claimed that -- AH never claimed 7 that Ms. Maxwell instructed her about what to wear, 8 correct? 9 MS. SCHULTZ: Object to the form. 10 THE WITNESS: Correct. 11 12 13 BY MR. PAGLIUCA: Q. AH never claimed that Ms. Maxwell told her how to act at Mr. Epstein's house, correct? 14 MS. SCHULTZ: Object to form. 15 THE WITNESS: Correct. 16 17 18 BY MR. PAGLIUCA: Q. AH never claimed to have met Ghislaine Maxwell anywhere, correct? 19 MS. SCHULTZ: Object to form. 20 THE WITNESS: I don't believe so, no. 21 22 BY MR. PAGLIUCA: Q. Okay. If we go on to individual alleged 23 victim No. 3, AY, the same question: AY never 24 identified Ms. Maxwell as someone she knew or 25 interacted with in any fashion, correct? Case 18-2868, Document 278, 08/09/2019, 2628230, Page499 of 648 Page 193 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to form. 3 THE WITNESS: No. 4 BY MR. PAGLIUCA: 5 Q. No, she did not? 6 A. No, she did not. 7 Q. Okay. The same with individual No. 4, 8 alleged victim FP: 9 met with Ms. Maxwell, correct? 10 11 MS. SCHULTZ: 14 15 Object to form and foundation. 12 13 Again, FP never claimed to have THE WITNESS: I don't believe so, no. BY MR. PAGLIUCA: Q. Okay. And FP never identified Ms. Maxwell as someone being at Mr. Epstein's house, correct? 16 MS. SCHULTZ: 17 foundation. 18 BY MR. PAGLIUCA: Object to form and 19 Q. And if you need to look at your report -- 20 A. No, I don't -- I don't believe so. The 21 only people that recalled Ghislaine at the house 22 was -- 23 Q. Sjoberg? 24 A. Johanna Sjoberg. 25 Q. Who was over the age of 18, correct? Case 18-2868, Document 278, 08/09/2019, 2628230, Page500 of 648 Page 194 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 MS. SCHULTZ: foundation. 4 THE WITNESS: 5 Venero. 6 BY MR. PAGLIUCA: 7 Q. MS. O'CONNOR: 9 THE WITNESS: 11 And Venero, Christina Who is an adult as well? 8 10 Object to form and Object to form. Yes. BY MR. PAGLIUCA: Q. So out of your entire report, the only two 12 people who ever said anything about Ms. Maxwell were 13 Ms. Sjoberg, who I believe was 23 when you 14 interviewed her? 15 A. 16 17 Right, but she was -MS. SCHULTZ: Object to form and foundation. 18 THE WITNESS: She was -- she had worked 19 there for quite some time, so you would have to 20 back up, I think, a year or two. 21 BY MR. PAGLIUCA: 22 Q. She was an adult when she worked there? 23 A. Right. 24 25 She was over the age of 18, right, let's put it that way. Q. And she was not listed by you as a victim Case 18-2868, Document 278, 08/09/2019, 2628230, Page501 of 648 Page 195 1 2 3 4 5 JOSEPH RECAREY - CONFIDENTIAL as part of this case, right? A. Correct, because it was between two consenting adults. Q. 6 Exactly. And so that's Ms. Sjoberg, and then the 7 other individual, I think you said Bolero; is that 8 right? 9 A. Venero, Christina Venero. 10 Q. Adult masseuse, correct? 11 A. Yes. 12 Q. Tatts, right. 13 She's a -- I remember she had lots of tattoos. But the 17 individuals that you listed in 14 Exhibit 1, none of those individuals ever said the 15 word -- the words "Ghislaine Maxwell" during the 16 course of this investigation to you, correct? 17 18 MS. SCHULTZ: foundation. 19 20 21 22 23 24 25 Object to form and THE WITNESS: I don't believe so. It would be on the tapes if they did. BY MR. PAGLIUCA: Q. Well, or it would be in your report, right? MS. SCHULTZ: foundation. Object to form and Case 18-2868, Document 278, 08/09/2019, 2628230, Page502 of 648 Page 196 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 4 5 6 THE WITNESS: Either in the report or on the tapes. BY MR. PAGLIUCA: Q. That's an interesting point, so let's talk about that for a moment. 7 This report, this Palm Beach Police 8 Department incident report, Exhibit 1, is a summary 9 of your investigation, correct? 10 A. Correct. 11 Q. And these recitations of your interviews 12 are abbreviated summaries, correct? 13 A. Correct. 14 Q. And so you're typing into this report 15 parts of it but not every word verbatim into the 16 report, correct? 17 A. Right. 18 Q. And, again, the originals of these tapes 19 are somewhere with the FBI at this point, correct? 20 21 MS. SCHULTZ: foundation. 22 23 24 25 Object to form and THE WITNESS: Correct. Or at the State Attorney's Office. BY MR. PAGLIUCA: Q. Are you aware of any of these originals Case 18-2868, Document 278, 08/09/2019, 2628230, Page503 of 648 Page 203 1 JOSEPH RECAREY - CONFIDENTIAL 2 That would be one. 3 another. 4 Q. Probably victim JB would be I believe there was a victim ML, as well. Let me ask this question: As you sit here 5 today, do you know who the subjects of the four 6 counts that are referenced on the first page of 7 Exhibit 7 are? 8 9 10 A. If I went through the entire PC affidavit, I could -- I could tell you who. But I just named three. 11 Q. Okay. 12 A. So, like I said, I can go through it and 13 14 15 16 tell you who exactly those four counts were for. Q. 19 We are limited to four, though, right? A. 17 18 Okay. Four instances. MS. SCHULTZ: Object to form. BY MR. PAGLIUCA: Q. 20 Right. And then throughout this entire 22-page, 21 Palm Beach Police Department affidavit, 22 Ms. Maxwell's name does not appear in here once, 23 does it? 24 MS. SCHULTZ: Object to form. 25 THE WITNESS: I don't believe so, no. Case 18-2868, Document 278, 08/09/2019, 2628230, Page504 of 648 Page 211 1 JOSEPH RECAREY - CONFIDENTIAL 2 A. Correct. 3 Q. And then Mr. Epstein is arrested and ends 4 up pleading guilty and all of that, right? 5 MS. SCHULTZ: Object to form. 6 THE WITNESS: I think there was a 7 non-prosecution agreement prepared between the 8 Feds and some kind of agreement was made. 9 yes, he did end up pleading guilty. 10 11 BY MR. PAGLIUCA: Q. 12 All right. Now, based on the questions that were 13 asked of you in the grand jury, it's fair to say 14 that Ms. Maxwell was not a target of the grand 15 jury's investigation, correct? 16 17 MS. SCHULTZ: Object to form and foundation. 18 THE WITNESS: Not based on the questions 19 that the state was asking me, no, the state 20 wasn't... 21 22 23 24 25 But, BY MR. PAGLIUCA: Q. In fact, it's fair to say that you never said Ms. Maxwell's name in the grand jury, right? MS. SCHULTZ: foundation. Object to form and Case 18-2868, Document 278, 08/09/2019, 2628230, Page505 of 648 Page 212 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 4 5 6 7 THE WITNESS: No. Based on the questions that the state was asking, no. BY MR. PAGLIUCA: Q. Were you aware of who was being issued subpoenas by the grand jury? A. No. But it wasn't the actual subpoena 8 from the grand jury; it came from the State 9 Attorney's Office. 10 11 Q. though, right? 12 13 At the direction of the grand jury, MS. SCHULTZ: foundation. 14 THE WITNESS: 15 don't know. 16 BY MR. PAGLIUCA: 17 Object to form and Q. I don't know. Again, I I would like to talk a little bit about 18 the surveillance that you initiated at Mr. Epstein's 19 house, okay? 20 21 22 23 Can you tell me when the surveillance began? A. It would have started under Detective Pagan and gone through -- 24 Q. The entire investigation? 25 A. Pretty much trash pulls. We stopped the Case 18-2868, Document 278, 08/09/2019, 2628230, Page506 of 648 Page 213 1 JOSEPH RECAREY - CONFIDENTIAL 2 actual physical surveillance sometime during the 3 investigation. 4 Pagan. 5 6 Q. But it would have started under Okay. Do you recall in what -- well, how was surveillance conducted, if you recall? 7 I didn't conduct it personally, no. That 8 would have been under plainclothes unit team. They 9 would have sent out a vehicle and recorded vehicles 10 A. coming and going and actual physical surveillance. 11 12 Q. So physical surveillance means eyes on the property, correct? 13 A. Right. 14 Q. And eyes on the property by a police 15 officer, correct? 16 A. Correct. 17 Q. And that police officer would be charged 18 with the obligation of recording the incomings and 19 outgoings of people to the property, correct? 20 A. Correct. 21 Q. Is there a log that's maintained during 22 surveillance? 23 A. I'm not sure who -- if there was a log or 24 not. I know that they set up a vehicle with cameras 25 facing -- facing Epstein's residence. Case 18-2868, Document 278, 08/09/2019, 2628230, Page507 of 648 Page 214 1 JOSEPH RECAREY - CONFIDENTIAL 2 Q. And so these were video cameras? 3 A. Correct. 4 Q. And so whoever was coming and going, 5 whenever -- an officer saw somebody coming or going, 6 they would videotape that person; is that correct? 7 8 9 10 11 A. Or they would just leave the video rolling, time lapse. Q. And did you have the opportunity to observe any of that video? A. I did observe a couple, but the person who 12 actually set it up would review it and then submit a 13 supplement to the report. 14 Q. Okay. It's true that none of the video of 15 the surveillance led to the identification of 16 Ghislaine Maxwell as coming or leaving the house 17 during the time of surveillance, correct? 18 19 MS. SCHULTZ: Object to form and foundation. 20 THE WITNESS: I don't know. I didn't see 21 all of the video, so I can't -- I can't attest 22 to that. 23 24 25 BY MR. PAGLIUCA: Q. Okay. Did anybody report to you that Ms. Maxwell was seen coming or going? Case 18-2868, Document 278, 08/09/2019, 2628230, Page508 of 648 Page 215 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to form, foundation. 3 THE WITNESS: I don't recall. 4 5 BY MR. PAGLIUCA: Q. If someone had reported to you that 6 Ms. Maxwell was seen coming or going, you would have 7 recorded it in your Palm Beach Police Department 8 incident report, Exhibit No. 1, correct? 9 10 MS. SCHULTZ: Object to form and foundation. 11 THE WITNESS: I would have told the 12 officer who was conducting the surveillance or 13 reviewing the video to document it in the 14 supplements. 15 16 BY MR. PAGLIUCA: Q. And there is no documentation in the 17 supplement of Ms. Maxwell either coming or going 18 from Mr. Epstein's house during this time frame, 19 correct? 20 MS. SCHULTZ: Object to the form. 21 THE WITNESS: I don't believe so. 22 23 24 25 I don't -- I don't -- I don't believe so. BY MR. PAGLIUCA: Q. And, again, so we're on the same page, when you say "I don't believe so," I interpret that Case 18-2868, Document 278, 08/09/2019, 2628230, Page509 of 648 Page 241 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 4 THE WITNESS: Correct. BY MR. PAGLIUCA: Q. And none of these individuals was employed 5 as a massage therapist at the time of their alleged 6 involvement with Mr. Epstein, correct? 7 A. Correct. 8 Q. Each of these individuals, as I recall, 9 10 claimed to have been paid directly by Mr. Epstein or Ms. Kellen, correct? 11 12 MS. SCHULTZ: foundation. 13 14 15 Object to form and THE WITNESS: Correct. BY MR. PAGLIUCA: Q. Most often, these individuals, these 17 16 individuals, were paid directly by Mr. Epstein, 17 correct? 18 19 MS. SCHULTZ: foundation. 20 21 22 Object to form and THE WITNESS: Mr. Epstein or Sarah Kellen. BY MR. PAGLIUCA: Q. Okay. None of these individuals identify 23 Ms. Maxwell as someone who was paying them money, 24 correct? 25 MS. SCHULTZ: Object to form and Case 18-2868, Document 278, 08/09/2019, 2628230, Page510 of 648 Page 242 1 2 JOSEPH RECAREY - CONFIDENTIAL foundation. 3 4 5 6 THE WITNESS: I don't believe so, no. BY MR. PAGLIUCA: Q. And each of these individuals identified receiving cash, correct? 7 MS. SCHULTZ: Object to the form. 8 THE WITNESS: Correct. 9 10 BY MR. PAGLIUCA: Q. Each of these individuals claimed varying 11 amounts, generally between $200 and up to $1,000, 12 correct? 13 MS. SCHULTZ: Object to form. 14 THE WITNESS: Correct. 15 16 BY MR. PAGLIUCA: Q. According to each of these individuals, 17 Mr. Epstein, when the massage was over, would either 18 hand them the money -- that happened according to 19 these individuals, right? 20 MS. SCHULTZ: Object to form. 21 THE WITNESS: At times, yes. 22 23 BY MR. PAGLIUCA: Q. Or Mr. Epstein had laid out the money 24 somewhere and directed them to where to go get it, 25 correct? Case 18-2868, Document 278, 08/09/2019, 2628230, Page511 of 648 Page 257 1 JOSEPH RECAREY - CONFIDENTIAL 2 A. I don't believe clothing was seized. 3 Q. To your knowledge, did you seize any 4 property belonging to Ghislaine Maxwell from the 5 home? 6 7 MS. SCHULTZ: foundation. 8 THE WITNESS: 9 knowledge. 10 BY MS. SCHULTZ: 11 Object to form and Q. Okay. I'm not sure. Not to my No one ever came to you and said, 12 Could you please return these items to Ms. Maxwell, 13 correct? 14 MS. SCHULTZ: Object to form. 15 THE WITNESS: No. 16 17 BY MS. SCHULTZ: Q. 18 All right. You did that with Janush? 19 A. Yes, he had photos and -- 20 Q. But nothing like that ever happened with 21 Ms. Maxwell, correct? 22 MS. SCHULTZ: Object to form. 23 THE WITNESS: No. 24 25 BY MS. SCHULTZ: Q. Ms. Maxwell was not present when you Case 18-2868, Document 278, 08/09/2019, 2628230, Page512 of 648 Page 259 1 2 JOSEPH RECAREY - CONFIDENTIAL Q. Any way that you get contacted by a police 3 officer, if they put it into your database, it will 4 come up when you do the CAD search, correct? 5 A. Right. 6 Q. And that's all that came up with regard to 7 Ms. Maxwell, was her name was somewhere in the 8 system. 9 10 Do you know or not know? MS. SCHULTZ: Object to form and foundation. 11 THE WITNESS: I don't know. 12 MR. PAGLIUCA: 13 (The referred-to document was marked by Okay. 14 the court reporter for Identification as 15 Deposition Exhibit 12.) 16 17 BY MR. PAGLIUCA: Q. I have handed you what has been marked as 18 Deposition Exhibit 12, which I will represent to you 19 are the Plaintiff in this case, Ms. Giuffre's Rule 20 26 disclosure. 21 22 I want to just go through very quickly and ask you if you know any of these individuals. 23 24 25 So, let's start with No. 1, Virginia Giuffre. A. Have you ever met Virginia Giuffre? No. Case 18-2868, Document 278, 08/09/2019, 2628230, Page513 of 648 Page 260 1 JOSEPH RECAREY - CONFIDENTIAL 2 Q. Have you ever talked to her? 3 A. I don't recall. 4 Q. Do you know what information that she may 5 have that's referenced below? 6 subject of this action. 7 of that? 8 MS. O'CONNOR: 9 THE WITNESS: 10 11 12 Do you have any knowledge Object to form. No. BY MR. PAGLIUCA: Q. Number 2, Ghislaine Maxwell, I'm going to come back to her. 13 14 Conducted is the Number 3, Juan Alessi, you did interview Mr. Alessi, correct? 15 A. Yes. 16 Q. I have seen a transcript of that 17 interview, and I have seen Exhibit 2, which is a 18 transcript of the interview with Ms. 19 to ask you a couple of questions about the 20 transcription process. 21 . I want As I understand your testimony previously, 22 the electronic recordings are sent somewhere, you 23 don't know where, for transcription; is that right? 24 MS. SCHULTZ: Object to form. 25 THE WITNESS: I didn't request a Case 18-2868, Document 278, 08/09/2019, 2628230, Page514 of 648 Page 274 1 JOSEPH RECAREY - CONFIDENTIAL 2 different investigators Mr. Black uses in a 3 particular calendar year, do you? 4 MS. SCHULTZ: Object to form. 5 THE WITNESS: No. 6 7 BY MR. PAGLIUCA: Q. And so you don't know whether Mr. Black's 8 association with this law firm was in connection 9 with Mr. Epstein's case or some other case, do you? 10 MS. SCHULTZ: Object to form. 11 THE WITNESS: I worked this case, 12 nothing -- nothing but this case for an entire 13 year. 14 This was my only case for a year. BY MR. PAGLIUCA: 15 Q. Okay. 16 A. If it walks like a duck. 17 18 19 20 That's it? MS. SCHULTZ: Objection. BY MR. PAGLIUCA: Q. Okay. So we're finished with Dershowitz. Keep on going. 21 A. Number 28, obviously, 22 Q. Okay. 23 A. Right. 24 Q. And, again, she never discussed Ghislaine 25 . And you've talked about her? Maxwell with you, correct? Case 18-2868, Document 278, 08/09/2019, 2628230, Page515 of 648 Page 278 1 2 JOSEPH RECAREY - CONFIDENTIAL Q. Right. So you're 75. So I want you -- I 3 want to take a moment and read what's under 75: 4 "Detective Recarey was the chief investigator of the 5 crimes committed at Jeffrey Epstein's Palm Beach 6 mansion." Is that true? 7 MS. SCHULTZ: Object to form. 8 THE WITNESS: Yes. 9 10 BY MR. PAGLIUCA: Q. "And has information about Ghislaine 11 Maxwell and Jeffrey Epstein's sexual trafficking 12 conduct and interaction with underaged minors." 13 Tell me everything that you believe you 14 know about Ghislaine Maxwell's sexual trafficking 15 conduct. 16 MS. SCHULTZ: Object to form. 17 THE WITNESS: I don't. 18 19 BY MR. PAGLIUCA: Q. So that's inaccurate, then? I mean, you 20 have no knowledge about Ghislaine Maxwell sexually 21 trafficking anybody, do you? 22 MS. SCHULTZ: Object to form. 23 THE WITNESS: Not with -- not with the 24 25 girls that I spoke with, no. Case 18-2868, Document 278, 08/09/2019, 2628230, Page516 of 648 Page 279 1 2 JOSEPH RECAREY - CONFIDENTIAL BY MR. PAGLIUCA: 3 Q. But that's your investigation, right? 4 A. Right. 5 Q. Okay. 6 A. Right. 7 8 9 Let's see. Q. And you've talked about her. Whatever happened to her, do you know? 10 11 Okay. Seventy-six. MS. SCHULTZ: Object to form. BY MR. PAGLIUCA: 12 Q. Haley Robson? 13 A. No. 14 Q. She was never charged, as I understand it, 15 correct? 16 A. Correct. 17 Q. And after you spoke to her in connection 18 with your investigation, did you ever speak to her 19 again? 20 A. No. 21 Q. Okay. 22 A. David Rogers, 77. 23 Q. And you know him because he was identified 24 25 as one of the pilots for Mr. Epstein, right? A. Right. Case 18-2868, Document 278, 08/09/2019, 2628230, Page517 of 648 Page 289 1 2 JOSEPH RECAREY - CONFIDENTIAL in your mind, right? Correct? 3 MS. SCHULTZ: Object to the form. 4 THE WITNESS: Yes. 5 6 BY MR. PAGLIUCA: Q. And you're a peace officer, obligated to 7 arrest when a felony is committed in your presence, 8 correct? 9 A. Correct. 10 Q. And the possession of child pornography is 11 a felony, correct? 12 A. Correct. 13 Q. And had you seen any child pornography in 14 Mr. Epstein's house when you were there installing 15 these cameras, you would have done something about 16 it, correct? 17 MS. SCHULTZ: Object for form. 18 THE WITNESS: Right. 19 20 21 BY MR. PAGLIUCA: Q. You wouldn't have just walked out and said, Nice pics, have a nice day, correct? 22 A. Correct. 23 Q. So is it fair to say the entire time you 24 were in Epstein's house, whether it's 2002, 2003, 25 you did not observe any child pornography, right? Case 18-2868, Document 278, 08/09/2019, 2628230, Page518 of 648 Page 290 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to the form. 3 THE WITNESS: Not in the areas I was in. 4 5 6 BY MR. PAGLIUCA: Q. You don't recall seeing any pictures of naked women, do you? 7 MS. SCHULTZ: Object to form. 8 THE WITNESS: Again, I was only confined 9 to where that desk was. That's where I set up 10 the camera, and then after it was set up, I 11 left. 12 BY MR. PAGLIUCA: 13 Q. Okay. But, again, all I'm asking you is 14 wherever you were, you didn't see any pictures of 15 naked women? 16 A. Right. 17 Q. And at the time you recall that he had No, I didn't see any. 18 these surveillance cameras already installed; is 19 that true? Other cameras, the clock cameras? 20 MS. SCHULTZ: Object to form. 21 THE WITNESS: I'm not sure if he had the 22 23 24 25 cameras installed or not. I can't recall. BY MR. PAGLIUCA: Q. Why would he need your cameras if he already had cameras? Case 18-2868, Document 278, 08/09/2019, 2628230, Page519 of 648 Page 300 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 None of these alleged victims claimed to have ever traveled with Mr. Epstein, correct? 4 MS. SCHULTZ: Object to form. 5 THE WITNESS: No. 6 7 8 BY MR. PAGLIUCA: Q. No, they did not? They did not travel with Mr. Epstein, right? 9 MS. SCHULTZ: Object to form. 10 THE WITNESS: I don't believe so, no. 11 BY MR. PAGLIUCA: 12 Q. None of them reported that to you? 13 A. Not reported, correct. 14 Q. None of them reported to you that they 15 ever spent the night with Mr. Epstein, did they? 16 MS. SCHULTZ: Object to form. 17 THE WITNESS: I don't believe so. 18 19 20 BY MR. PAGLIUCA: Q. None of them ever reported being trafficked by Mr. Epstein to other men, correct? 21 MS. SCHULTZ: Object to form, foundation. 22 THE WITNESS: I don't believe so. 23 24 25 BY MR. PAGLIUCA: Q. The only other men that any of these alleged victims -- the only man that any of these Case 18-2868, Document 278, 08/09/2019, 2628230, Page520 of 648 Page 301 1 JOSEPH RECAREY - CONFIDENTIAL 2 alleged victims ever claimed to have any contact 3 with that was sexual in nature was Mr. Epstein, 4 correct? 5 MS. SCHULTZ: 6 foundation. 7 8 Object to form and THE WITNESS: Yes. BY MR. PAGLIUCA: 9 Q. Okay. None of these alleged victims ever 10 claimed to have been sent to another location to 11 have sex with another man, correct? 12 13 MS. SCHULTZ: foundation. 14 15 16 17 THE WITNESS: I don't believe so. BY MR. PAGLIUCA: Q. Meaning my statement is correct; is that right? 18 19 Object to form and MS. SCHULTZ: Object to form. BY MR. PAGLIUCA: 20 Q. I'm just trying to -- 21 A. Meaning I don't believe they've ever said 22 23 that. I don't recall any of them ever saying... Q. Had they claimed that they were sent 24 somewhere else to have sex with another man, you 25 would have followed up on that, correct? Case 18-2868, Document 278, 08/09/2019, 2628230, Page521 of 648 Page 302 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to form. 3 THE WITNESS: Correct. 4 5 BY MR. PAGLIUCA: Q. And none of them ever claimed to have been 6 sent to another location to give another man a 7 massage, correct? 8 MS. SCHULTZ: Object to form. 9 THE WITNESS: No, not the victims. 10 BY MR. PAGLIUCA: 11 Q. Right. That's who I'm talking about. 12 A. I believe 13 Q. Who is an adult, right? did. 14 MS. SCHULTZ: Object to form. 15 THE WITNESS: Right. 16 17 18 BY MR. PAGLIUCA: Q. We covered this, I believe: None of them ever was on Mr. Epstein's airplane, correct? 19 MS. SCHULTZ: Object to form. 20 THE WITNESS: I believe one of the victims 21 were, but not to a private island. 22 they went -- they didn't go to a private 23 island; they went to some other trip. 24 25 I think BY MR. PAGLIUCA: Q. I think maybe you're referring to AH, who Case 18-2868, Document 278, 08/09/2019, 2628230, Page522 of 648 Page 303 1 JOSEPH RECAREY - CONFIDENTIAL 2 went to New York but on a commercial flight. 3 that jog your memory? 4 MS. SCHULTZ: Object to form. 5 THE WITNESS: No. 6 BY MR. PAGLIUCA: 7 Q. Okay. 8 A. It would have been FP. 9 Q. Okay. Do you recall who it is? Was on Mr. Epstein's airplane? 10 MS. SCHULTZ: Object to form. 11 THE WITNESS: I believe so. 12 13 Does BY MR. PAGLIUCA: Q. Would that be reflected in Exhibit 1? 14 MS. SCHULTZ: Object to form. 15 THE WITNESS: But she flew alone. It 16 wasn't like Epstein was there. 17 someplace else, not to his private island, 18 nothing to do with Epstein. 19 she wanted to do. 20 plane, but it was, like, her by herself. 21 BY MR. PAGLIUCA: 22 Q. Alone. 23 A. Right. 24 Q. With a pilot? 25 A. Right. She went It was something And I think she flew on his Case 18-2868, Document 278, 08/09/2019, 2628230, Page523 of 648 Page 304 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 4 MS. SCHULTZ: Object to form. BY MR. PAGLIUCA: Q. None of the alleged victims in your 5 investigation claimed to have gone to the Caribbean 6 island of Little St. James, correct? 7 MS. SCHULTZ: Object to form. 8 THE WITNESS: No. 9 10 11 BY MR. PAGLIUCA: Q. "No" meaning they never went there, correct? 12 MS. SCHULTZ: Object to form. 13 THE WITNESS: Not that I'm aware of. 14 15 BY MR. PAGLIUCA: Q. None of the alleged victims ever went to 16 Mr. Epstein's New York residence, to your knowledge, 17 correct? 18 MS. SCHULTZ: Object to form. 19 THE WITNESS: Not that I'm aware of. 20 21 BY MR. PAGLIUCA: Q. None of them ever reported that to you? 22 MS. SCHULTZ: Object to form. 23 THE WITNESS: No. 24 25 BY MR. PAGLIUCA: Q. Okay. And none of them ever claimed to Case 18-2868, Document 278, 08/09/2019, 2628230, Page524 of 648 Page 305 1 JOSEPH RECAREY - CONFIDENTIAL 2 have been outside of the country with Mr. Epstein, 3 ever, correct? 4 MS. SCHULTZ: Object to the form. 5 THE WITNESS: Not that I'm aware of. 6 MR. PAGLIUCA: 7 Can we go off for a second? Time check. 8 THE VIDEOGRAPHER: 9 (Thereupon, a recess was taken, after 10 which the following proceedings were held:) 11 12 Off the record at 4:13. THE VIDEOGRAPHER: On the record at 4:14. BY MR. PAGLIUCA: 13 Q. Can you take a look at Exhibit 4, please? 14 A. Which one is 4? 15 Q. Four is the True Copy. 16 says at the top. Exhibit 4. That's what it Six pages. 17 A. Yes. 18 Q. Do you have that? 19 A. Yes, sir. 20 Q. There's yellow highlighting on the exhibit 21 that's in front of you. 22 Do you know how that got there? 23 A. No. 24 Q. And there's a -- there are numbers, item 25 numbers. Do you see that in the left column? Case 18-2868, Document 278, 08/09/2019, 2628230, Page525 of 648 Page 365 2 3 CERTIFICATE OF OATH 4 STATE OF FLORIDA ) 5 COUNTY OF MIAMI-DADE ) 6 7 I, the undersigned authority, certify 8 that JOSEPH RECAREY personally appeared before me 9 and was duly sworn. 10 11 WITNESS my hand and official seal this 24th day of June, 2016. 12 13 KELLI ANN WILLIS, RPR, CRR 14 Notary Public, State of Florida My Commission No. EE911443 15 Expires: 2/16/16 16 + + + + + + + + + + + + + + + + + + 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page526 of 648 Page 366 2 3 4 C E R T I F I C A T E STATE OF FLORIDA ) : ss 5 COUNTY OF MIAMI-DADE ) 6 I, KELLI ANN WILLIS, a Registered 7 Professional, Certified Realtime Reporter and 8 Notary Public within and for The State of 9 Florida, do hereby certify: 10 That JOSEPH RECAREY, the witness whose 11 deposition is hereinbefore set forth was duly 12 sworn by me and that such Deposition is a true 13 record of the testimony given by the witness. 14 I further certify that I am not related 15 to any of the parties to this action by blood 16 or marriage, and that I am in no way interested 17 in the outcome of this matter. 18 19 IN WITNESS WHEREOF, I have hereunto set my hand this 24th day of June, 2016. 20 21 __________________________ KELLI ANN WILLIS, RPR, CRR 22 23 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page527 of 648 EXHIBIT HH Case 18-2868, Document 278, 262?230, Page528 Qi?48 (Jase Document 435?3 Filed 09/15/16 Page 2 of 6 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 EDWARDS, et 01., Plainti?s Counterclaim Defendants, V. DERSHOWITZ, Defendant Counterclaim Plaintiff. AFFIDAVIT 0F JUAN P. ALESSI REGARDING KNOWLEDGE 0F ALAN M. DERSHOWITZ A. Introduction 1. My name is Juan P. Alessi. I make this declaration voluntarily and without compensation on personal knowledge concerning Alan Dershowitz and his visits at my former employer Jeffrey Epstein?s home in Palm Beach, Florida. I worked for Mr. Epstein from January 1991 to December 2002 as a full-time employee performing maintenance services and then also became the manager for the home on 358 El Brillo Way in Palm Beach, Florida. Since Mr. Epstein was investigated and arrested, I have spoken with police, investigators, and attorneys concerning my time working for Mr. Epstein. On September 8, 2009, I gave a deposition in the case captioned Jane Doe No. 2 v. Jef??ey Epstein, Case No. in which I truthfully answered the questions posed by the attorneys. I also gave a sworn statement on November 21, 2005 to Case 18-2868. Document 278. 08/09/2019. 2628230. Paoe529 of 648 Case Document 435?3 Filed 09/15/16 Page 3 of 6 Detective Joseph Recarey of the Palm Beach P.D. during their investigation of Mr. Epstein. . I have reviewed the statements that Bradley Edwards and Paul Cassell attribute to me in their papers in the cases against the Government and against Mr. Dershowitz. Because I do not believe they accurately re?ect the statements I previously made, I submit this affidavit to have my statements accurately reflected and made clear on the record. . Summary of My Knowledge of Massages at Mr. Epstein?s Palm Beach Home . As I stated in my deposition, a massage was like a treat for all the guests at Mr. Epstein?s home. Mr. Epstein usually received his massages in his private suite, but guests would also be given massages in their respective rooms or by the pool area. . There were between ?fty (50) to one hundred (100) masseuses mostly women but also some men - who would come to give massages during this time. I provided names of masseuses in my deposition. . As I stated in my deposition, I was unaware of any masseuses being under the age of 18. I believed that the females? age ranged from overage to maybe mid-forties. As I stated in my deposition, I received as a gift a massage from a male masseuse at Mr. Epstein?s home in Palm Beach. . In my deposition, I was asked about cleaning up after massages. I stated that when I cleaned Mr. Epstein?s bedroom suite, which included the bathroom of Ms. Maxwell, after massages, I would, on occasion, ?nd vibrators and sex toys. I have speci?c recollection of ?nding these items in the sink of Ms. Maxwell?s bathroom. I did not state or imply that vibrators or sex toys were found a?er massages in other rooms used by guests because that was not the case. Guests having massages did not have 2 10. 11. 12. 13. Case 18-2868. Document 278. 08/09/2019. 2628230. P6108530 of 648 Case Document 435?3 Filed 09/15/16 Page 4 of 6 massages in Mr. Epstein?s private bedroom suite. This area was private and off?limits to guests, which I explained to the lawyers during my deposition. As I said in my deposition, massage tables were located in almost every room, including guest rooms and by the pool. I never found, and never heard anyone in the house ?nding, a vibrator or a sex toy in the same room where any guest, including Alan Dershowitz, had a massage. The following statement made by Virginia Roberts?s attorneys in a ?ling on January 21, 2015 is not accurate and is a misrepresentation of what I said in my deposition: ?The private, upstairs room where Dershowitz got his ?massages? was one that contained a lot of vibrators Maxwell had ?a laundry basket . . . full of those toys? in that room.? Summary of My Interaction with Alan M. Dershowitz During the approximate thirteen years I worked for Mr. Epstein, I believe I saw Mr. Dershowitz visit Mr. Epstein?s Palm Beach home approximately four or ?ve times a year. I recall driving him to the airport on multiple occasions. At the time, I understood that Mr. Dershowitz was a famous lawyer. His visits to the house would typically involve a group of intellectuals or business men in social, but professional type gatherings. I can recall that Mr. Dershowitz had a massage on at least one occasion during a visit to Mr. Epstein?s home in Palm Beach (although I cannot recall that Mr. Dershowitz received a massage on more than one occasion). I do not recall Mr. Dershowitz being massaged by anyone whorl thought was less than 18 years old. I have no reason to doubt Mr. Dershowitz?s statement that this massage was done by a woman named Olga who was in her forties. In fact, I do remember a masseuse named Olga that 3 14. 15. Case 18-2868, Document 278I 08/09/2012, 2628230, Page531 of 648 Case Document 435-3 Filed 09/15/16 Page 5 of 6 lived in Palm Beach, though I do not know her last name. As I have said, I never saw Mr. Dershowitz around young girls. I have also explained that there were masseuses, both male and female, that were in their mid?forties. I never saw Mr. Dershowitz do anything improper or be present while anyone else was being improper. Before asking me about Jeffrey Epstein speaking to celebrities at the house, the attorney for ?Jane Doe 102? asked me about Jean Luc Brunel, Mark Epstein, Daniel Estes, Matt Groening, and Leslie Wexner. I then listed Senator Mitchell, Prince Andrew, Princess Sarah Ferguson, Miss Yugoslavia, Miss Germany, Alan Dershowitz, Princess Diana?s secretary with her children, Mr. Trump, Mr. Robert Kennedy, Jr., Frederik Fekkai, and a couple Noble prize winners as celebrities that I had seen while working for Mr. Epstein. I also mentioned a reunion of Nobel prize winners that was held at the house, and that I met President Clinton at Mr. Epstein?s plane the last month that I was working for Mr. Epstein. C. Summary of My Interaction with Virginia Roberts 16. 17. 18. The ?rst time I saw Virginia Roberts was at Mar?a?Lago where I believed she worked in the spa. I only recall seeing Virginia Roberts come to Mr. Epstein?s house during the last year that I worked for Mr. Epstein. During this time, I believe she visited Mr. Epstein?s home in Palm Beach two or three times a week. I never saw any photographs of Virginia Roberts in Mr. Epstein?s house. I was shown a photo of Virginia Roberts during my deposition, and I recognized the woman in the photo as Virginia Roberts. As I stated in my deposition, I am not sure whether Virginia Roberts came to the house when Prince Andrew was there. Case 18-2868, Document 278, 08/09/2019, 2628230, Page532 of 648 Case Document 435?3 Filed 09/15/16 Page 6 of 6 19. was never asked by any attorneys if Virginia Roberts came to the house when Mr. Dershowitz was there. If I had been asked, I would have answered that I never saw Virginia Roberts at the house when Mr. Dershowitz was there. 20. The following statement made by Virginia Roberts?s attorneys and their own attomey in a ?ling on December 4, 2015 is not accurate and is a misrepresentation of what I said in my deposition: ?Alessi was able to identify a photograph of Ms. Giuffre as someone who was at the mansion as the same time as Dershowitz.? 21. As far as I can recall, since I gave my deposition in 2009, I have never been asked by Brad Edwards or Paul Cassell about my knowledge regarding Virginia Roberts or Alan Dershowitz or about my 2009 deposition testimony. I understand that I am swearing or af?rming under oath to the truthfulness of the claims made in this af?davit and that the punishment for knowingly making a false statement includes fines and/or imprisonment. Dated: January 13, 2016 STATEOF COUNTY OF i?w?Jq @Eze-pw Sworn to or affirmed and signed before rum uJL-o atrium-.5 ItC-euhs-o. ?41-685; WTARY PUBLIC or DEPUTY CLERK A U?r 1? A- . Cab Hrs-7?7 [Print, type, or stamp commissioned name of notary or clerk.] Case 18-2868, Document 278, 08/09/2019, 2628230, Page533 of 648 EXHIBIT II Case 18-2868, Document 278, 08/09/2019, 2628230, Page534 of 648 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, P1a1nt1ffs, -vs- CONFIDENTIAL ALAN M. DERSHOWITZ, Defendant. VIDEOTAPED DEPOSITION OF VIRGINIA ROBERTS GIUFFRE Saturday, January 16, 2016 9:07 a.m. - 2:48 p.m. 401 East Las 01as BTvd., Suite 1200 Fort LauderdaTe, F10r1da 33301 Reported By: Deborah A. Harris, Court Reporter Notary Pub11c, State of F10r1da Phone - 305.651.0706 Job No. J0277789 CONFIDENTIAL GIUFFRE005093 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page535 of 648 APPEARANCES: 0n behaif of the PTaintiffs: Jack Scaroia, Esquire SEARCY, DENNEY, SCAROLA, BARNHART SHIPLEY, P.A. 2139 PaTm Beach Lakes Bouievard West Paim Beach, Fiorida 33409 (561) 686-6300 0n behaif of the Deponent: Sigrid McCawTey, Esquire BOIES, SCHILLER FLEXNER, LLP 401 East Las Dias Bouievard, Suite 1200 Fort Lauderdaie, Fiorida 33301 (954) 356-0011 0n behaif of the Defendant: Mary Borja, Esquire WILEY REIN, LLP 1776 Street NW Washington, DC 20006 (202) 719-7000 0n behaif of the Defendant: Richard Simpson, Esquire WILEY REIN, LLP 1776 Street NW Washington, DC 20006 (202) 719-7000 0n behaif of the Defendant: Thomas E. Scott, Esquire COLE, SCOTT KISSANE, P.A. 9150 South Dadeiand Bouievard, 14th Fioor Miami, Fiorida 33156 (305) 350-5300 0n behaif of the Defendant: Kenneth A. Sweder, Esquire SWEDER ROSS, LLP 131 01iver Street. Boston, Massachusetts 02110 (617) 646-4466 CONFIDENTIAL GIUFFRE005094 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page536 of 648 ALSO PRESENT Edward J. PozzuoTi, SpeciaT Master Robert Pacheco, Videographer Ryan Kick, Videographer BradTey J. Edwards PauT G. CasseTT ATan M. Dershowitz Brittany N. Henderson, Esq. Meridith Schuth, Esquire I WITNESS DIRECT CROSS REDIRECT Virginia Roberts Giuffre By Ms. Borja 5 By Mr. ScaroTa 201 By Ms. Borja 204 I I DEFENDANT VR EXHIBITS - Notice. - DiscTosure Tist. - Order. - E-maiT. Photo (ConfidentiaT) - ArticTe. - DaiTy Mai]. - DaiTy Mai]. - DecTaration. FBI doc. I _x CD I RECROSS FOR ID 6 26 59 92 100 124 155 168 170 187 NOTE: Exhibit 5 marked confidentiaT, seaTed, and retained by the SpeciaT Master. CONFIDENTIAL GIUFFRE005095 CONFIDENTIAL MR. SCAROLA: It is a minor discrepancy, but I think you read it as when she was a minor and it's whi1e she was a minor. BY MS. BORJA: Q. Whi1e she was a minor. Do you see where I'm reading starting in the third 1ine? A. Yes. Q. Is that a11egation true? A. Yes. Q. If you go to page 6 of the document, do you see the paragraph that's starts, Epstein a1so trafficked? A. Yes. Q. Is says Epstein a1so trafficked Jane Doe #3 for sexua1 purposes to many other powerfu1 men inc1uding numerous prominent American poiiticians, powerfu1 business executives, foreign presidents, a we11-known prime minister and other wor1d 1eaders. Do you see that? A. Yes. Q. Is that a11egation true? A. Yes. Q. The reference there to foreign presidents, do you see that? A. Yes. Q. You were sexua11y trafficked to foreign presidents? CONFIDENTIAL GIUFFRE005102 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page538 that's not true, you were not sexua11y trafficked to foreign presidents? A. I don't know what foreign president you're ta1king about. Q. Have you ever been sexua11y trafficked to any foreign president? MS. MCCAWLEY: I'm going to a110w you to ask that question, but with respect to specific identification of an individua1 we're not going to do that. At this point she has. MS. BORJA: Counsei, your objection has been made. No speaking objections, p1ease. Let's move on. MS. MCCAWLEY: I can make my record, and my record is she's not going to be speaking with respect to individua1s' names that are named in genera1ities in this document. SPECIAL MASTER: Objection overru1ed. You can answer. A. I understand we11-known prime ministers and other wor1d 1eaders; as far as foreign presidents, I'm not too sure, I don't know. Q. Have you ever met any foreign presidents? A. Foreign presidents as in overseas? CONFIDENTIAL GIUFFRE005103 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page539 of 648 12 Q. Sure, okay, overseas. A. No. Q. Have you ever met any foreign presidents from countries not overseas such as Canada or Mexico? A. No. Q. So you were not sexua11y trafficked to any foreign presidents; is that correct? A. As far as I know right now, yes. Q. It's correct that you were not sexua11y trafficked to them, right? A. You've asked me this three times and I'm te11ing you. Q. Okay. A we11-known prime minister. Were you sexua11y trafficked to a we11-known prime minister? A. Yes. Q. Who was that? MS. MCCAWLEY: I'm going to object to this 1ine of questioning. This has to do with safety concerns for her. MS. BORJA: Counsei, this is under sea1. You can answer. MS. MCCAWLEY: No, she's not going to answer. SPECIAL MASTER: Hang on one second. MS. MCCAWLEY: Let me make my objection. CONFIDENTIAL GIUFFRE005104 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page540 of 648 15 SPECIAL MASTER: Okay. I can't twist her arm and force her so we'11 dea1 with it. BY MS. BORJA: Q. Okay. Other wor1d 1eaders, what other wor1d 1eaders were you sexua11y trafficked to? MS. MCCAWLEY: We have the same objection. SPECIAL MASTER: And I wou1d have the same ru1ing based upon the arguments. MS. MCCAWLEY: Let me just make my record. To the extent that there's a name of an individua1 that you can revea1 that you do not fee1 wou1d harm your physicai safety, you're weicome to revea1 them. Anybody eise, you don't have to revea1 at this time and we'11 take that to Judge A. Okay. Prince Andrew for one. Q. Other than Prince Andrew? A. There is another individua1 that I honest1y do not know his name. Q. What country is he from? A. I'm not too sure, he spoke in a foreign -- he did speak foreign tongue, he spoke Eng1ish as we11, but I'm not too sure where he was from. Q. How do you know he is wor1d 1eader? A. I was introduced to him as a prince. CONFIDENTIAL GIUFFRE005107 CONFIDENTIAL (when I was with him. A. Q. trafficked to 16 Okay. Did he have security with him? I'm sure he did somewhere around, but not Did you see security? No. Did you -- where were you when you met him? On this occasion the South of France. Are there witnesses to you being sexua11y this prince? Yes. Name them. Jeffrey Epstein, GhisTaine MaxweTT. Anyone e1se? There was a whoTe bunch of peopTe in the room so of course. their names. Q. A. Was this an orgy? No. Who eise was in the room? I can't name them a11, there was a Tot. Name as many as you can name? I don't know their names. I can't name They were present during sexua1 activity? They were present before the sexuaT activity and then I went to have sexuaT activity with him CONFIDENTIAL GIUFFRE005108 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page542 of 648 17 aione. Q. So he's the on1y witness to your sexuai activity, the prince? A. On the instruction of Epstein and Ghis1aine, yes. Q. Where in the South of France were you? A. I don't know. Q. Were you on a boat, were you in a house? A. We were at a 1ike a cabana, not cabana, 1ike a resort, but it was a big party. Q. Who was throwing the party? A. I don't know. I was just brought there. Q. You aiso refer to powerfu1 business executives. What powerfu1 business executives were you sexua11y trafficked to? MS. MCCAWLEY: Again, to the extent you can revea1 somebody without a safety concern you're weicome to do that. SPECIAL MASTER: We11, again -- MS. MCCAWLEY: Right. I understand. SPECIAL MASTER: Same objection, same ru1ing. A. George Mitche11. Q. When were you sexua11y trafficked to George Mitche11? CONFIDENTIAL GIUFFRE005109 CONFIDENTIAL h) 01 64 Q. Do you have the origina1s? A. Again, between the FBI and giving them to my 1awyers and Sharon Churcher, the circu1ation, I'm not too sure if I have the originais. I know I have copies. So I'm not too sure if they're the origina1s. Q. The book1et that you gave pages from to Ms. Churcher where is that book1et? A. Burned. Q. When did you burn it? A. In, I think it was 2013. Me and my husband had a bonfire. Q. What did you put in the bonfire? A. Any kind of memories that I had written down about a1] the stuff going on. Q. Had you written anything about Professor Dershowitz? A. He cou1d have been there, yes. Q. And you burned that? A. I wanted to burn my memories. I wanted to get rid of it. It was very painfu1 stuff. Q. Other than what you had written down did you burn anything e1se? I don't mean the wood, when you ta1k about burning your memories, what were you burning? A. I was burning 1ike memories, thoughts, dreams that I had, just everything that was kind of CONFIDENTIAL GIUFFRE005156 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page544 of 648 65 with the abuse I endured, and there was a Iot of it in there. My husband is pretty spiritua1 so he said the best thing to do wou1d be burn them. Q. Is there anything you decided to keep and not burn? A. Just the photographs. Q. Anything e1se that you can think of? A. Photographs, that's it. Q. Approximateiy when in 2013 was this bonfire? A. I don't know what month it was. Q. Did you do it outside? A. Yeah, it was outside. I wasn't going to do it in my 1iving room. Q. Did it fee1 good to be ciose to the fire because it was coid out or was it a summertime bonfire? A. I be1ieve I had just bought my house in Titusvi11e, Fiorida. I bought my house in, I think, I either got it October or November of 2013. It wou1d have been around probab1y November. Q. Why did you decide to keep the photos? A. They're evidence. Q. Do you have any photographs of yourse1ves with Professor Dershowitz? A. No. CONFIDENTIAL GIUFFRE005157 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page545 of 648 85 Beach, I've seen him in New York. So I mean, if we're going to pin point how many times I've seen him or the next time I saw him after that I don't know. Q. Then te11 me -- Tet's do it this way, what was the most recent time that you recaTT having sex with Professor Dershowitz? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. The first time I recaTT having sex with Professor Dershowitz was in New York. Q. My question was, the most recent time now. What's the most current, most recent memory of having sex with Professor Dershowitz? MS. MCCAWLEY: Objection. Just so I'm c1ear, you're going backward? MS. BORJA: Correct. MS. MCCAWLEY: The Tast time. A. The Tast time that I remember having sex with him? Okay. I beTieve it was on an airpTane. Q. Where were you going? A. On, I beTieve it was Massachusetts. I don't know. It's very hard for me to remember exactTy where we were going, what were the circumstances. Q. So that's the time you testified about earTier? CONFIDENTIAL GIUFFRE005177 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page546 That were providing massages to Jeffrey Epstein? A. Just the ma1e that was teaching me on the USVI and Sheridan, but she was a1so invoived in sexua1 acts. She wasn't over the age of -- she cou1d have been around 30, but she wou1d have been over 30. Q. Did you keep a 1ist of the masseuses who came to Epstein's properties? A. No. Did some of them come on1y once? A. Uh-huh. Are there some that came when you weren't there? A. I wasn't there, how am I to know. Q. You don't know if any came as a masseuse whi1e you were not at Jeffrey Epstein's property? MS. MCCAWLEY: Objection, asked and answered. A. I wasn't there so I couidn't have. Q. What's the sixth incident that you say happened where you were sexua11y trafficked to Professor Dershowitz? A. We've ta1ked about New York, we taiked about Pa1m Beach, New Mexico, U.S. Virgin Isiands, ta1ked CONFIDENTIAL GIUFFRE005202 CONFIDENTIAL h) to 24 25 111 about we took the airp1ane? Q. Yes. A. There was an instance in a car, but it was more -- it wasn't intercourse, it was more -- MS. MCCAWLEY: Use a term you're comfortab1e with. A. More ora1 is the good term to use, ora1 sex. Q. Where were you? Where was his car, what city, what state, what jurisdiction? Where were you? A. This was in Massachusetts. It was a biack 1imousine. Q. Who e1se was in the car other than yourse1f and Professor Dershowitz? A. Jeffrey Epstein and another young gir1. Q. How many peop1e participated in the sexua1 activity in the car? A. Inciuding myse1f? Q. Uh-huh. A. Four. Q. Where was everybody in the car? A. Sitting down. Q. Were peop1e -- was this a town car, was this a 1imousine? A. Like a 1on9 1imousine. CONFIDENTIAL GIUFFRE005203 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page548 of 648 112 Q. Where was the car going? A. To Mr. Dershowitz' house. Q. Where was it coming from? A. An airport. Q. When was this? A. I don't know. Q. What's your best recoIIection? A. It wasn't snowing. It wasn't hot. So I wou1d 1ike to say -- I'm trying to think of the trees around, but I don't know, maybe spring. Q. Why were you going to Professor Dershowitz' house? A. Jeffrey and him were doing some business. They were doing something at his house. Nothing sexua1 happened at his house. Did you go in Professor Dershowitz' house? Yes, I did. How Iong were you there? Not even twenty minutes, ha1f an hour. What did you do whi1e you were in the house? A. I sat in, I don't know, a foyer with another gir1 and Jeffrey and Dershowitz went to a different part of the house. There was a desk there and we just sat, not sat, stood in the foyer. CONFIDENTIAL GIUFFRE005204 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page549 of 648 113 Q. Who was this other gir1? A. I don't know who she is. Q. Had you ever met her before? A. No. Q. When you were coming from the airport had you fiown in? A. Yes, me and Jeffrey and the gir1 had fiown in, Dershowitz had not. Q. How did he get into the 1imousine? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. BY MS. BORJA: Q. Where did he get into the 1imousine? A. At the airportf1ight with Mr. Epstein? A. Not on this occasion. Q. Did you te11 anybody about this incident in the car? A. Like anybody that I know persona11y? Q. Anybody in the worid? MS. MCCAWLEY: Objection to the extent you re1ayed something to your 1awyer. You can say that you toid your 1awyers but you can't discuss what you said. SPECIAL MASTER: Other than -- CONFIDENTIAL GIUFFRE005205 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page550 toid my 1awyers. Did you te11 anybody about it cioser in time to the event? A. no. Q. where did you A. A. 0 you go? A. Like my boyfriend or something 1ike that, After you 1eft Professor Dershowitz's house go? Back to the airport. Where did you f1y in from? I be1ieve it was New York. When you went back to the airport where did I be1ieve, see, that's the hard thing. I want to say either New York or Pa1m Beach. I'm no 100 percent sure. Q. So I understand the time frameprivate jet or commerciai? A. Q. A. 0. Private. You f1ew out again on private? Yes. So the time frame is that you and Jeffrey were on the p1ane? MS. MCCAWLEY: Objection. Yes. MS. MCCAWLEY: Objection, mischaracterizes CONFIDENTIAL GIUFFRE005206 CONFIDENTIAL h) 01 115 the testimony. Go ahead. A. Yes, me and Jeffrey were on the p1ane together. Q. And the gir1 was on the p1ane? A. Yes. Q. Anybody e1se? A. The piiots. Q. So the three of you took the f1ight, correct? A. Yes. Q. And you f1ew into an airport in Massachusetts? A. Yes. Q. Then you took a 1imousine to the Professor's house and you were there for about ten minutes, is that right? MS. MCCAWLEY: Objection. Go ahead. A. About 20, 25 minutes. I didn't iook at my watch. Q. A very brief period of time? A. Very brief. Q. And then you went back to the airport and you f1ew out? A. Yes. Q. And you f1ew back either to New York or to CONFIDENTIAL GIUFFRE005207 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page552 of 648 194 A. Besides what's in these? Q. Did you ever Iook to see if you had any persona1 notes in your writing that pertain to Professor Dershowitz? A. Like from my 01d journa1, the one that I burned? Q. From anywhere. Did you ever make an effort to 100k? A. Dershowitz cou1d have been in my journa1, he cou1d have been. We're ta1king about an 85 page, if not more, you know, things that I had written to get my story out of my head and into pages; and yes, Dershowitz cou1d have been in there, but that's up in the c10uds now, bonfire. Q. That's what you ca11 your journa1s, what you burned, right? A. Yes. Q. And you wrote that journa] in order to c011ect your thoughts? A. To get everything out of here and on to paper. Q. Have you made any other notes, though, since then to he1p you when you think of things? A. Yes, sometimes 1ike I said, sometimes when I read my affidavits and stuff 1ike that, you know, and I CONFIDENTIAL GIUFFRE005286 CONFIDENTIAL h) 01 195 think of something e1se 1ike a description of something that I forget about, you know what I mean, then yeah, go back and write it in the journa1, you know, for instance, you know, what another gir1 wou1d have 1ooked 1ike. Even though I can't identify her name or her age or anything 1ike that, but I do remember 1ike f1ashes of b1onde, 1itt1e things 1ike that, but nothing -- I don't have any more journa1s. Q. But those notes, they he1p your memory? A. Sometimes. I'm a very visua1 person. Q. And they he1p you with your affidavits? A. No, they don't he1p me with my affidavits, my affidavits are a1ready done, I just go back and it he1ps my memory. It he1ps me bring stuff out. Q. What do you do with those notes? A. Nothing, 1itera11y nothing. They're in a notebook that if I need to write it down. I have a dream notebook as we11 where just write down my dreams and stuff. I do nothing, no one is seeing it. Q. You read it? You keep it? A. Yeah, I keep it. Q. Okay. Have you gone back and read that recent1y? A. No. Q. Okay. You continue to make entries into CONFIDENTIAL GIUFFRE005287 CONFIDENTIAL h) 01 Case 18-2868, Document 278, 08/09/2019, 2628230, Page554 much about Dershowitz. It's most1y 1ike fee1ings, dreams, you know, past things that I've gone through. Like I said, not so much pertaining to Dershowitz himse1f. Q. And that's separate from your dream book? A. No, it's a11 in one. Q. Is it a spira1 bound notebook? A. Yes, it's just a cheap, 1ike, actua11y it's in my kid's c10set. Q. At this point in time are you angry with Mr. Epstein? A. Furious. Q. Are you angry with Professor Dershowitz? A. Absquter. Q. Are you angry with famous poIiticians? A. I'm angry with anybody who has it in their mind that they can hurt and abuse a minor chi1d and continue to 1ie about getting away with it and that what they've done is okay and they can continue to harass victims, yes, I'm furious. Q. Are you angry with Professor Dershowitz for his roIe in representing Jeffrey Epstein in the crimina1 action? A. Do I think he p1ayed a big part getting him CONFIDENTIAL GIUFFRE005288 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page555 STATE OF FLORIDA, COUNTY OF DADE, I, Deborah A. Harris, the undersigned authority and Notary Pub1ic certify that VIRGINIA ROBERTS GIUFFRE persona11y appeared before me and was du1y sworn on the 16th day of January, 2016. Sworn to before me this 20th day of January, 2016. Deborah A. Harris, Court Reporter Notary Pub1ic - State of F10rida My Commission No. FF 246867 My Commission Expires: October 31, 2019 Job No. J0277789 GIUFFRE005305 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page556 of 648 214 CERTIFICATE I, Deborah A. Harris, F10rida Professiona1 Court Reporter and Notary Pub1ic in and for the State of F10rida at Large, do hereby certify that I was authorized to and did report said deposition in stenotype; and that the foregoing pages 1 through 216 are a true and correct transcription of my shorthand notes of said deposition. I further certify that said deposition was taken at the time and pIace hereinabove set forth and that the taking of said deposition was commenced and compIeted as hereinabove set out. I further certify that I am not an attorney or counseI of any of the parties, nor am I a re1ative or emponee of any attorney or counseI of party connected with the action, nor am I financia11y interested in the action. The foregoing certification of this transcript does not appIy to any reproduction of the same by any means un1ess under the direct controI and/or direction of the certifying reporter. DATED this 20th day of January, 2016. Deborah A. Harris, Court Reporter Job No. J0277789 GIUFFRE005306 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230, Page557 of 648 EXHIBIT Case 18-2868, Document 278, 08/09/2019, 2628230, PageSS8 of 648 BOIES, 40 LAS OLFS APD SLHTE DEPOSITION- SPECIAL REQUIRED U) 37w? Sigrid S. McCawley, Esq. E-Inail: February 10. 2016 VIA E-MAIL FEDERAL EXPRESS Esquire Solutions PRODUCTION DEPARTMENT 101 Marietta Street Atlanta, Georgia 30303 Re: Con?dential/Sealed Deposition Transcript, Job No. .102777789 (Errata changes to be treated in same manner). To Whom It May Concern: Attached please find the errata changes for the Videotaped Deposition ol'Virginia Roberts Giuffre taken January 16, 2016. This transcript has been designated as Con?dential and has been sealed by the Court. Please ensure that all materials including transcript, errata changes and video tape are treated accordingly. It you have any questions regarding the errata changes or treatment ot?con?dential/sealed materials, please do not hesitate to contact me at (954) 356-001 1. Sincerely, Sigrid S. McCawley Enclosures COM GIUFFRE005310 CONFIDENTIAL Case 18-2868, Document 278, 08/09/2019, 2628230Con?dential/Sealed Transcript Pursuant to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Job No. 10277789 I E: DEPOSITION LRRAIA SHEET ASSignment no: 4 ?radloy 1. Idward? and Paul 0. Lasaell AYan M. Derghow?tz DECLARATTON UNDFR PFNAITY 0F I dcc1are under penaWty of perjury that I have read the entire [ranntript of my videomaped deposition Taken in the raprinnad mathr or xhe same has been read to me. and the same is true and arcuratc, save und extent fur ghangca andfor LorrC