CQQP 18-7868, 782, 08/09/7010, 7678741, Pagm nf EXHIBIT 1 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page2 of 883 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 1, 2016 9:12 a.m. C O N F I D E N T I A L Deposition of JOHN ALESSI, 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 283, 08/09/2019, 2628241, Page3 of 883 Page 9 1 JOHN ALESSI 2 Q. You're ready to start, correct? 3 A. Yes. 4 Q. Can you tell us your current address? 5 A. 6 Florida 33472. 7 Q. 8 A. 9 Q. 10 Boynton Beach, And your date of birth? . And was there a time when you worked for a man named Jeffrey Epstein? 11 A. Yes. 12 Q. And can you tell us when you began working 13 14 for Mr. Epstein? A. I began working for Mr. Epstein part-time. 15 I cannot exactly tell you the date, but it was 16 1990/'91, probably. 17 for him. 18 19 Q. Okay. I worked a total of 13 years So you began in 1990 part-time, correct? 20 A. Right. 21 Q. And you stopped working for him when? 22 A. I stopped working for him on 23 December 31st, 2001. I was out -- yes, 2001. 24 Q. Okay. 25 A. The end of 2001. I left the last day of Case 18-2868, Document 283, 08/09/2019, 2628241, Page4 of 883 Page 10 1 2 JOHN ALESSI the year. 3 Q. Okay. I know that it's been a long time. 4 A. It's been a long time. 5 Q. I know. So I'm going to ask that you 6 refer to the statement that you provided to the 7 police November 21st, 2005, and please go to page 5. 8 I just want you to start reading at line 2 and 3, 9 and tell me if that refreshes your recollection as 10 to your time or duration of employment. 11 A. You're right. 12 Q. So sometime in 1990, you were a part-time 13 It was 2002, then. 2002. employee? 14 A. Uh-huh. 15 Q. And you worked until December 31st, 2002; 16 is that right? 17 A. Yes. 18 Q. Okay. And is it also correct that you 19 began full-time employment with Mr. Epstein on 20 January 1st, 1991, as stated in that report? 21 A. Yes. 22 Q. Prior to 1990, who did you work for? 23 A. Prior to 1990, I had a company, a 24 maintenance company, myself, my own company, Alessi 25 Maintenance. And before that, I worked for another Case 18-2868, Document 283, 08/09/2019, 2628241, Page5 of 883 Page 11 1 2 JOHN ALESSI family, the Radi family in Palm Beach. 3 Q. 4 Wexner? 5 A. 6 Did you ever work for a man named Les I did some work for him in his mother's house. 7 Q. Where was that? 8 A. Palm Beach. 9 10 11 Q. Is that who recommended that you work for Jeffrey Epstein? A. I guess so. 13 Q. Okay. 15 Before -- before I came to work for Jeffrey. 12 14 What year? When you started with Jeffrey Epstein, what were your job duties? A. I was doing maintenance. I was doing 16 building and rebuilding and maintenance work 17 basically. 18 time. 19 recommend me to go to the house and take a look at 20 the house. 21 basically, at the beginning of my job. Because he just bought the house at that And because of Mr. Wechsler knowing me, they And we start tearing the house down, 22 Q. Did you assist in the teardown? 23 A. Yes. 24 Q. Okay. 25 a maintenance? So your job duties then was that of Case 18-2868, Document 283, 08/09/2019, 2628241, Page6 of 883 Page 12 1 JOHN ALESSI 2 A. Maintenance, building. 3 Q. Got it. 4 5 And did you meet Mr. Epstein when you were -- in 1990? 6 A. Yes, I met him. 7 Q. Okay. 8 And in 1991, who made the decision for you to become a full-time employee? 9 A. Jeffrey. 10 Q. And as a full-time employee initially, 11 12 what was your job? A. I was basically maintenance, the same 13 thing as I was doing with -- I was exclusively 14 working for him. 15 maintenance, because the house was still on 16 renovation, and he wanted me there. 17 18 Q. Okay. I was full-time working for him as And how was your relationship with Mr. Epstein back then, 1991? 19 A. Great. 20 Q. It was good? 21 A. It was good. 22 Q. Did he have a girlfriend back then, in 23 24 25 No problem. 1991? MR. PAGLIUSCA: foundation. Object to the form and Case 18-2868, Document 283, 08/09/2019, 2628241, Page7 of 883 Page 13 1 JOHN ALESSI 2 You can answer the question. 3 Occasionally, I'll need to object for the 4 record in case we need to have a discussion 5 about this with the judge. 6 me preserving those objections. 7 THE WITNESS: And so that's just Yes, he had a girlfriend. 8 Her name was Dr. Andersson, Eva Andersson. 9 she was there just for a few months after I 10 11 came to the house. BY MR. EDWARDS: 12 13 And Q. And how was your relationship with Dr. Andersson? 14 A. Fine. 15 Q. Okay. And at the time when Mr. Epstein 16 was -- at the time when Dr. Andersson was Jeffrey 17 Epstein's girlfriend, did you see any other female 18 companions around the house? 19 A. Eventually -- they have a lot of guests, 20 too. 21 remember exactly who. 22 have friends. 23 They did have guests coming in. Q. But I can't It's a socialite. So they At the time when Dr. Andersson was 24 Mr. Epstein's girlfriend, was Mr. Epstein getting 25 massages? Case 18-2868, Document 283, 08/09/2019, 2628241, Page8 of 883 Page 14 1 JOHN ALESSI 2 3 MR. PAGLIUSCA: Object to the form and foundation. 4 THE WITNESS: I think so. I was not 5 involved in the house, inside of the house that 6 much. 7 BY MR. EDWARDS: 8 9 Q. But they always got massages. Okay. Always. I'm talking about the time period when Dr. Andersson was there. 10 A. Yes, they got massages. 11 Q. Okay. So do you remember other female 12 visitors when Dr. Andersson was Mr. Epstein's 13 girlfriend? 14 A. 15 16 I don't remember. I remember people being there, visitors, but I cannot remember that far. Q. Okay. After -- did there come a point in 17 time when Dr. Andersson was no longer Mr. Epstein's 18 girlfriend? 19 A. Right. 20 Q. Yes? 21 A. Yes. 22 Q. And did he -- did he have a new 23 girlfriend? 24 25 MR. PAGLIUSCA: foundation. Object to form and Case 18-2868, Document 283, 08/09/2019, 2628241, Page9 of 883 Page 23 1 2 JOHN ALESSI Q. 3 All right. Who was in charge of the Palm Beach house? 4 A. I was. 5 Q. All right. 6 7 8 9 10 11 12 Who was your direct supervisor? A. Mr. Epstein. He would deal with me directly, or if he was not available, Ms. Maxwell. Q. Okay. I want you to go to Exhibit 3 and page -- page 179, line 8. A. Line 8, "QUESTION: And then Maxwell came and she took over you as your immediate supervisor? 13 Yes. That's correct. Yes. She became 14 the supervisor not only for this house, but for all 15 the homes. 16 Q. Okay. 17 Ms. Maxwell? 18 A. So your immediate supervisor was Ms. Maxwell. But if Mr. Epstein was at 19 the house, I would never go to Ms. Maxwell; I would 20 go to him directly, or he would come to me. 21 Q. Okay. At some point in time towards the 22 end of your tenure, did you come to resent 23 Ms. Maxwell? 24 25 MR. PAGLIUSCA: foundation. Object to the form and Case 18-2868, Document 283, 08/09/2019, 2628241, Page10 of 883 Page 28 1 2 3 4 5 6 JOHN ALESSI Q. And where did the massage therapists -- where did they come from? A. Most, they came from Palm Beach. Palm Beach County. Q. And over the course of that 10-year period 7 of time while Ms. Maxwell was at the house, do you 8 have an approximation as to the number of different 9 females -- females that you were told were massage 10 therapists that came to the house? 11 MR. PAGLIUSCA: 12 Object to form and foundation. 13 THE WITNESS: I cannot give you a number, 14 but I would say probably over 100 in my stay 15 there. 16 BY MR. EDWARDS: 17 Q. And many of the times would the females 18 come only one time and not return? 19 MR. PAGLIUSCA: 20 21 22 23 Object to form and foundation. BY MR. EDWARDS: Q. Let me ask that a different way. Were there times when some of these 24 females that would come to the house, and you were 25 told that they were massage therapists, would come Case 18-2868, Document 283, 08/09/2019, 2628241, Page11 of 883 Page 30 1 2 3 4 5 JOHN ALESSI BY MR. EDWARDS: Q. Okay. And who would find the massage therapist to bring to the house? A. They would call me in my office, and they 6 would say, Get me a massage at 10:00 with this 7 person. 8 9 I have a list of the massage therapists, a Rolodex, or a card, and I would call them for the 10 specific time they want a massage. 11 that. 12 Q. And I would do I don't think I asked the right -- the 13 question that I was looking to ask, so let me go 14 back. 15 Did you go out looking for the girls -- 16 A. No. 17 Q. -- to bring -- 18 A. Never. 19 Q. -- as the massage therapists? 20 A. Never. 21 Q. Who did? 22 A. Ms. Maxwell, Mr. Epstein and their 23 friends, because their friends relayed to other 24 friends they knew a massage therapist and they would 25 send to the house. So it was referrals. Case 18-2868, Document 283, 08/09/2019, 2628241, Page12 of 883 Page 34 1 JOHN ALESSI 2 foundation. 3 happening in this deposition, because the word 4 "recruit" was introduced by the lawyers in this 5 deposition. 6 characterization of the testimony. 7 Hold on. That misstates what is So I object to your BY MR. EDWARDS: 8 Q. 9 answer. 10 I'll read for you the question and the The question was: "QUESTION: When did 11 that role get transferred from you to Ms. Maxwell, 12 the role of looking after girls or calling the 13 girls? 14 "ANSWER: I didn't look after -- out for 15 girls. 16 remember one occasion or two occasions she would say 17 to me, John, give me a list of all the spas in Palm 18 Beach County, and I will drive her from one to the 19 other to PGA in Boca; and she would go in and drop 20 credit cards -- not credit cards but business cards, 21 and she would come out. And then we'd go to -- she 22 will recruit the girls. Was never, never done by me 23 or Mr. Epstein or anyone else that I know of." 24 25 Ms. Maxwell was the one that recruit. Is that truthful testimony? A. It is truthful; however, I think I Case 18-2868, Document 283, 08/09/2019, 2628241, Page13 of 883 Page 35 1 JOHN ALESSI 2 "recruiting," for myself, for my point of view, is 3 hiring immediately and recruit the person. 4 I think she was looking for massage 5 therapists. 6 went -- and you're right, I went one time with her, 7 or twice maybe, to different spas and different 8 clubs, great clubs, I mean, in Boca, in Fort 9 Lauderdale, in -- in Palm Beach. 10 She was looking for the best kind. She was looking for the best massage therapists available. 11 How she find these girls, I don't know. 12 just drove there. 13 was involved with any of the offerings or 14 negotiations or meeting these girls. 15 16 Q. Okay. I just was the driver. I I never Never. Ms. Maxwell was the one that would meet the girls? 17 A. Yeah. 18 Q. Okay. 19 She Did you ever check any of the IDs for any of these girls? 20 A. 21 things to do. 22 Q. That was just not part of your job? 23 A. That was not my job. 24 Q. Did Ms. Maxwell take photographs while she 25 I was not -- that was not in my everyday It was not. was at the Palm Beach house? Case 18-2868, Document 283, 08/09/2019, 2628241, Page14 of 883 Page 52 1 JOHN ALESSI 2 3 MR. PAGLIUSCA: foundation. 4 5 6 7 Object to form and THE WITNESS: Himself. Himself. BY MR. EDWARDS: Q. And you do not know the ages of the various massagists, right? 8 A. No. 9 Q. Did you have occasion to clean up after 10 the massages? 11 A. Yes. 12 Q. Okay. And that is after both a massage 13 for Jeffrey Epstein, as well as clean up after a 14 massage that Ghislaine Maxwell may have received? 15 A. Yes. 16 Q. And on occasion, after -- in cleaning up 17 after a massage of Jeffrey Epstein or Ghislaine 18 Maxwell, did you have occasion to find vibrators or 19 sex toys that would be left out? 20 21 MR. PAGLIUSCA: foundation. 22 23 24 25 Object to form and THE WITNESS: Yes, I did. BY MR. EDWARDS: Q. Can you describe the types of vibrators or sex toys that you found left out after a massage Case 18-2868, Document 283, 08/09/2019, 2628241, Page15 of 883 Page 53 1 JOHN ALESSI 2 that Jeffrey Epstein had just received or Ghislaine 3 Maxwell had just received? 4 5 MR. PAGLIUSCA: Object to form and foundation. 6 THE WITNESS: It was probably two to three 7 times, I would say. It was not all the time. 8 I would find things like a dildo, it's called a 9 double. I hate to say it because these ladies. 10 But I find these things, put my gloves on, took 11 it out and rinse it, and put it in 12 Ms. Maxwell's closet. 13 14 15 16 17 18 19 BY MR. EDWARDS: Q. Why would you put the dildo or sex toy in Ms. Maxwell's closet? A. Because I knew that's where they were kept. Q. How did you know that the sex toys were kept in Ms. Maxwell's closet? 20 A. 21 that house. 22 it was a place, it was placed by me, by the cleaning 23 lady or my wife. 24 in that house, I knew it. 25 Q. Because I know where everything was in Every single room, every single thing, Every -- everything that happened Who showed you where the dildo or sex toys Case 18-2868, Document 283, 08/09/2019, 2628241, Page16 of 883 Page 54 1 2 JOHN ALESSI were kept in the house the first time? 3 4 MR. PAGLIUSCA: foundation. 5 6 Object to form and THE WITNESS: Nobody. Nobody show me. BY MR. EDWARDS: 7 Q. You just saw it? 8 A. I saw it. 9 Q. So you knew where to put it back? 10 A. Yeah. We had to open the closet, clean 11 the closet, put the clothes in place, put the shoes 12 in place, put everything in place. 13 matter of tidying things up. So it was a 14 Q. Did you ever find any costumes? 15 A. I saw one shiny black costume, but I 16 didn't even know -- 17 Q. Where did you see it? 18 A. The same place. 19 Q. In Ms. Maxwell's closet? 20 A. Yes. 21 Q. And where was Ms. Maxwell's closet in the 22 23 house? A. In the house? 24 of his bathroom. 25 bedroom. It was in the opposite side It was her bathroom in the master It was in the middle. So it was on the Case 18-2868, Document 283, 08/09/2019, 2628241, Page17 of 883 Page 94 1 2 3 4 JOHN ALESSI BY MR. EDWARDS: Q. That demonstrates that she was, I believe, terminated from her employment in 2000. 5 My question to you is: Do you remember 6 what time of year or what month it would have been, 7 whether spring, summer, fall, winter; January, 8 February, December? 9 A. Of what year? 10 Q. Of 2000, that you would have gone to the 11 Mar-a-Lago? 12 A. 13 14 15 16 17 It wasn't 2000. MR. PAGLIUSCA: foundation. BY MR. EDWARDS: Q. Okay. A. Yes. 19 Q. Okay. 21 22 Do you think it was a different year that you went to Mar-a-Lago? 18 20 Object to form and What year do you believe that you went to the Mar-a-Lago to pick Virginia up? A. I think it was 2000 and -- I think it was the summer of 2002. 23 Q. Okay. 24 A. Summer, because I remember that day that I 25 was sweating like hell in the -- in the car, waiting Case 18-2868, Document 283, 08/09/2019, 2628241, Page18 of 883 Page 95 1 2 3 4 JOHN ALESSI for Ms. Maxwell to come out of the massage. Q. Okay. So what month of the summer do you remember it being? 5 A. I think in June, July, maybe, 2001. 6 Q. 2000 and what? 7 A. 2001. 8 Q. June, July, 2001, that's when you believe 9 that it was? 10 A. Yes. 11 Q. Okay. 12 A. No, sorry. And do you remember the month -Sorry. Not 2001. We left in 13 December 31st. 14 was working for Jeffrey, when I met Virginia. 15 16 Q. It was 2000 -- the last year that I Your recollection, as you sit here today -- 17 A. It was 2002. 18 Q. -- is that it was June or July of 2002 -- 19 A. 2002. 20 Q. -- when you met Virginia Roberts at the 21 Mar-a-Lago? 22 A. My recollection. 23 Q. Okay. And other than the fact that you 24 were sweating, what else tells you what month that 25 it was that you remember meeting her at the Case 18-2868, Document 283, 08/09/2019, 2628241, Page19 of 883 Page 96 1 JOHN ALESSI 2 Mar-a-Lago? 3 A. It was -- I know it was summer of 2002, 4 and she spoke to -- far away. I wasn't -- I was in 5 the driveway, and she was far away talking to 6 Virginia. She spoke to her maybe five minutes. 7 Q. Okay. 8 A. And she came to the car, and we went home. 9 10 In the afternoon, about 4:00 or 5:00 in the afternoon, the same day, Virginia came to the house. 11 Q. Who brought her to the house? 12 A. I don't know. 13 I remember. 14 came to the house. 15 Q. She came to the back door, And she was dressed differently. She When you first arrived to the Mar-a-Lago 16 with -- are you driving the car and Ms. Maxwell is 17 in the passenger seat? 18 A. Yes. 19 Q. And could you see Virginia Roberts from 20 the car? 21 A. Yes. 22 Q. Where was she sitting or standing? 23 24 25 How far away from the car? A. driveway. She was standing right in front of the This is the Mar-a-Lago, the house, and Case 18-2868, Document 283, 08/09/2019, 2628241, Page20 of 883 Page 97 1 JOHN ALESSI 2 here is the spa, and the driveway that's here. 3 was parked this way, and I would see her with 4 Ms. Maxwell, talking. I 5 Q. Did you -- 6 A. I could not hear what they were saying, 7 but I did see it. 8 Q. 9 there and -- 10 A. 11 12 Did you park the car or did you stop right I parked the car because we are not allowed to go into Mar-a-Lago. Q. 13 Okay. Let me finish my question. Did you park the car in a parking space in 14 the parking lot or did you just stop on the side of 15 the road and Ms. Maxwell got out? 16 A. Mar-a-Lago has a -- has a long wide 17 driveway, and on the right of the driveway is -- is 18 the parking spots like this or something. 19 parked in one of those spaces. 20 I think it was over an hour that I wait for her. 21 22 23 24 25 Q. Okay. And I And waiting for her, So did you watch her first talk to -A. No. At the end. Right at the end, before -- when she was leaving. Q. So Ms. Maxwell gets out of the car. And Case 18-2868, Document 283, 08/09/2019, 2628241, Page21 of 883 Page 98 1 JOHN ALESSI 2 when you're pulling up to the Mar-a-Lago, could you 3 see Virginia Roberts then? 4 A. No. No. 5 Q. So after you wait an hour, Ms. Maxwell is 6 coming out? 7 A. And then she saw Virginia and she 8 stopped -- she went to her, she talked to her, she 9 came back to the car. 10 11 Q. And prior to that day, you had never seen Virginia at the house? 12 A. Never. 13 Q. Okay. 14 Never. Did Ms. Maxwell tell you that Virginia's father worked at the Mar-a-Lago? 15 A. I don't think so. I think it was -- I 16 think we find out later, after the -- she says, My 17 father works -- I think it was from Virginia, that 18 she says her father works at Mar-a-Lago. 19 It is information from her. I don't think 20 it was Ms. Maxwell that told me anything. 21 have to -- she don't have to talk to me. 22 Ms. Maxwell will not go and talk to me about this -- 23 these people's family. 24 did. 25 Q. Okay. I don't know. She don't I mean, She never I only have to go by what I have. Case 18-2868, Document 283, 08/09/2019, 2628241, Page22 of 883 Page 103 1 JOHN ALESSI 2 3 4 5 I don't remember that day, how she got home. I don't know. Q. I can't remember. After that day, do you recall that she started coming to the house more frequently? 6 A. Yes, she did. 7 Q. In fact, did she start coming to the house 8 approximately three times a week? 9 A. Yes, probably. 10 Q. And at times, would you go pick her up? 11 A. Yes. 12 This happened maybe twice, three times. 13 Q. And at times, would you take her home? 14 A. Yes. 15 Q. And did there come a point in time where 16 Virginia starting bringing other girls with her? 17 18 MR. PAGLIUSCA: Object to form and foundation. 19 THE WITNESS: That was maybe two weeks 20 before we left. 21 friends with her to the house. 22 remember how many times, but I was at the end 23 of our stay. 24 25 I saw her bringing some And I cannot BY MR. EDWARDS: Q. At the end of her [sic] stay, you saw when Case 18-2868, Document 283, 08/09/2019, 2628241, Page23 of 883 Page 104 1 JOHN ALESSI 2 she would come over to the house, she would bring 3 certain friends who were girls -- 4 MR. PAGLIUSCA: 5 6 Object to form and foundation. BY MR. EDWARDS: 7 Q. -- to the house, right? 8 A. Yes, females, yes. 9 Q. Do you know how long Virginia had been 10 coming over to the house before she started 11 traveling on an airplane with Ghislaine and Jeffrey? 12 MR. PAGLIUSCA: 13 THE WITNESS: 14 15 16 17 18 Object to foundation. Not too long. I don't think it was too long after that. BY MR. EDWARDS: Q. Would you drive her to the airport with them? A. Occasionally, I think so, yes. I would 19 drive everybody to the airport. 20 the chefs, the service people, the luggage to Jet 21 Aviation. 22 23 Q. My wife would drive Is that where Mr. Epstein kept his plane, Jet Aviation? 24 A. Yes. 25 Q. At some point did Ghislaine Maxwell become Case 18-2868, Document 283, 08/09/2019, 2628241, Page24 of 883 Page 141 1 JOHN ALESSI 2 MR. PAGLIUSCA: Seven. 3 MR. EDWARDS: 4 (The referred-to document was marked by Seven? 5 the court reporter for Identification as 6 Deposition Exhibit 7.) 7 MR. EDWARDS: 8 MR. PAGLIUSCA: 10 MR. EDWARDS: I have it. Okay. BY MR. EDWARDS: 12 Q. 13 four pages. 14 should be -- do you have SAO 01456? 15 MR. PAGLIUSCA: 16 MR. EDWARDS: 17 20 21 22 23 24 25 So this is a composite exhibit. It is The first one that you're looking at Yes. Okay. BY MR. EDWARDS: 18 19 I just can't find a copy right now. 9 11 I apologize, Jeff. Q. Does the format of this look familiar to A. Yes. you? It looks like the books that we used to have that has -- the message books. Q. How would that work? How would that process work? A. Somebody called, you write it down, and you take the -- you leave the copy in the -- in the Case 18-2868, Document 283, 08/09/2019, 2628241, Page25 of 883 Page 175 1 JOHN ALESSI 2 many things? 3 A. Yes, she did. 4 Q. Interesting buildings? 5 A. No. She -- she liked -- she had a dog, 6 and she took a lot of photographs of her dog. 7 us. 8 house. 9 photographs of people, young girls, girls. 10 11 And she took photographs of the cars and the Everything inside. remember that she had. Q. 12 13 And She had an album full of And I Like a hobby. Right. You never saw any pictures that were very upsetting to you, though, correct? 14 A. No. No. 15 Q. Okay. And the pictures that you saw were 16 sort of -- would you describe them as being artistic 17 kind of pictures? 18 19 20 MR. EDWARDS: Objection, counsel testifying. THE WITNESS: I think so. I don't think 21 they were pornographic. I don't think it was 22 any vaginal or things, you know, female parts 23 showing. 24 taking the sun. 25 was a beautiful setting, so she took a lot of It was some girls were topless, It was a beautiful house, it Case 18-2868, Document 283, 08/09/2019, 2628241, Page26 of 883 Page 236 1 2 3 4 5 6 7 JOHN ALESSI CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, the undersigned authority, certify that JOHN ALESSI personally appeared before me and was duly sworn. WITNESS my hand and official seal this 1st day of June, 2016. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Kelli Ann Willis, RPR, CRR Notary Public, State of Florida Commission FF928291, Expires 2-16-20 + + + + + + + + + + + + + + + + + + CERTIFICATE STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) 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 JOHN ALESSI; 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 1st day of June, 2016. KELLI ANN WILLIS, RPR, CRR Cam: 18-7868, 782, 08/09/7010, 7678741, Pag977 nf EXHIBIT 2 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page28 of 883 UNITED STATES DISTRICT COURT for the SOUTHERN DISTRICT OF NEW YORK Civil Action No. VIRGINIA GIUFFRE, Plaintiff, vs. GHISLAINE MAXWELL Defendant. VIDEO-DEPOSITION OF: JAMES MICHAEL AUSTRICH TAKEN BY: Defendant REPORTED BY: Karla Layfield, RMR Stenographic Court Reporter Notary Public State of Florida at Large DATE AND TIME: June 23, 2016; 9:03 a.m. PLACE: Owen Associates Court Reporters 108 N. Magnolia Avenue, Suite 501 Ocala, Florida APPEARANCES: Laura A. Menninger, Esquire HADDON, MORGAN FOREMAN, PC 150 East 10th Avenue Denver, Colorado 80203 Attorney for Defendant Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, FISTOS LEHRMAN, PL 425 Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Attorney for Plaintiff Also Present: Kenneth Sarsony, Videographer Virginia Giuffre Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page29 of 883 16 A Yes. Was it is a franchise, if you know? A I know when I first started there, they were corporate, but then they were a franchise. They were bought out. But I'm not sure if when I got there they were a franchise or not. Got it. Do you know if Ms. Roberts had any previous employment before she worked at Taco Bell? A I think by the apartment, she worked for KFC for a little while. MS. MENNINGER: Are you looking at Ms. Roberts? THE WITNESS: I'm thinking. I can't remember. I remember something with KFC. They had one really close to us. I think she worked there for a tiny, tiny bit. I'm not sure. MS. MENNINGER: Okay. BY MS. MENNINGER: Before the Taco Bell? A Or she could've applied there. It's just in my head. She might have just applied there, and didn't get it, and that?s why I brought her to Taco Bell. Okay. A Because we were both the night managers. Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page30 of 883 19 A No. Do you know about what years this was? A Not really. Do you know about how old you were? A When, what? I'm just focused on the period of time in which you were living at her parent's house in the trailer. A I was probably 18 when we moved in there. And you said you were only there for a couple of months? A Not that I remember. Like, it might have been a little longer. I'm not sure. Were you engaged to Ms. Roberts? A Yes. When did you become engaged to her? A When we were living in Oakland Park. Tell me about the engagement. How did it come about? A Well, we fell in love, and I believe it was Valentine's Day when I proposed. Did you have a ring? A Yes. Did she accept? A Yes. How long were you engaged? Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page31 of 883 A Yes well, for a while. I mean, I know at the end, I wasn't working anywhere. Why weren't you working? A I don't remember the exact reason. Had you quit? A I believe so. I know the pet store let me go for walking on to the other side talking to somebody. But I don't remember why I left Dunkin' Donuts. Do you believe that you were fired from Dunkin' Donuts? A No. That pet store was the only time anybody ever fired me. That will stick in your brain. A Yeah. At the time that you left the pet store, was Ms. Roberts still working there? A Yes. And how long do you recall her working there? A Not long. I hate to do this to you, but what does "not long" mean to you, weeks, months, days? A Over a month. That's really all I can say. Maybe over a month before she went to work at the Mar?a?Lago or Donald Trump's country club. Did she leave the pet store to go work at Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 3O Case 18-2868, Document 283, 08/09/2019, 2628241, Page32 of 883 34 BY MS. MENNINGER: Did you know her friend by the name of Tony Figueroa? A Somewhat. Tell me what you remember about Tony Figueroa. A Other than him being an idiot, not much. Did you have any interactions with Mr. Figueroa? A Very little. When do you recall seeing him, like, in what city, I mean? A Up in West Palm Beach. Did he come over to your apartment? A I believe so. Did you believe them to be having a relationship? A At the very end when I left, yes. Was that one of the reasons for your leaving? A One of them. What were the others? CU Well, after I found out about that, that's when I heard about all the other stuff that was happening. What did you hear about all the other stuff? A Well, I mean, after she went to work for Mar?a-Lago then she was, I guess, recruited to go work for Jeff something. I don't remember his last name. Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page33 of 883 35 Is that what she told you "she was recruited"? A Yeah. Well, she didn't use those words. But I don't know why else anybody would take -- like, they hired her over there as a massage therapist, but she didn't have any experience. At Mar-a-Lago A At Mar?a?Lago, yes. Then all of a sudden one day, she was working for Jeff, whatever his name was. Let me just take a step back. You found out towards the end of your relationship with Ms. Roberts that she was then having a relationship with Mr. Figueroa. Is that right? A I don't know if it was a relationship. But, yes. Enough to cause you to think you didn't want to be engaged anymore? A Yes. Did you and Ms. Roberts have a fight at that time? A Yes. What do you remember about the fight? What do you recall? A I don't recall. I remember us having a fight and then leaving not too long afterwards. You referred to finding out all this other stuff Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page34 of 883 92 When you got the apartment in Oakland Park, you got it with Virginia? A Well, yeah. She was living with us -- and Mario. MS. MENNINGER: All right. I think that's all I have. MR. EDWARDS: Okay. THE VIDEOGRAPHER: We're going off the record. This concludes disc one, volume one of the video-deposition of James Michael Austrich. We're going off the record. The time is approximately 11:20 a.m. (Break taken.) THE VIDEOGRAPHER: We're back on the record with disc two, volume one, of the video- deposition of James Michael Austrich. And the time is approximately 11:23 a.m. Thank you. BY MR. EDWARDS: Mr. Austrich, as you know, my name is Brad Edwards, and I represent Virginia. A Yes. I'm going to ask you some follow-up questions to the questions that you were asked previously. All right? Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page35 of 883 how long we lived there. Okay. At some point in time, though, while you're living on her parent's property, it becomes 1999? A Yeah, I believe. Okay. And so when you started living at her parent's property, you're 18, she's 15, but at some point in time you turn 19 and she turned 16? A Yes. Okay. And at some other point in time, she leaves the job at the pet store? A Pet store, yeah. And goes to work at the Mar?a-Lago? A Yes. At Donald Trump's country club, yeah. Okay. Donald Trump's country club is called the Mar?a-Lago? MS. MENNINGER: Objection. THE WITNESS: Yeah, that's what I always remember it as. Yes. BY MR. EDWARDS: Is that right? MS. MENNINGER: Objection, leading. I do get a chance to object. Leading. BY MR. EDWARDS: When you used the term "Mar-a-Lago" and used the term "Donald Trump's country club," are we talking about Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 98 Case 18-2868, Document 283, 08/09/2019, 2628241, Page36 get clean for her job, she would have gotten clean for the job. Okay. Do you remember her being hired as a bathroom attendant there, a locker room attendant? A Now that you're saying that, some kind of attendant sounds familiar. But I don't really remember. All I remember is for the massage. As a I don't remember exactly what she got hired for at Donald Trump's place. But I just remember the masseuse thing. But as you?re saying "the attendant," the attendant sounds familiar because I doubt her father would hire her as a massage therapist without knowing anything. So you had known her for some period of time before she gets this job at the Mar-a?Lago, right? A Right. Did she have any massage therapy training whatsoever? A No. Ever given a massage to anyone? A Not that I remember. Ever given a massage to you? A Not until she was already doing the massage stuff. But, no, I don?t remember any kind of massage training or even like an inkling for it. Okay. Then when she goes to work for Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 100 Case 18-2868, Document 283, 08/09/2019, 2628241, Page37 of 883 101 Mar-a-Lago, you don't remember, I think is the words you used, whether she worked there for weeks or months? A Yes. You don't remember? A No, not at all. And at the time when she gets the job at the Mar?a?Lago, do you remember where you were working, if anywhere? A No. I mean, I think at that time, I was working at one of the places. But I don?t really remember where. And then, and I believe that you used this word, correct me if I'm wrong, she's recruited to work for Jeff? A Yes. And do you remember her telling you that it was an assistant or somebody associated with Jeff that recruited her to work with Jeff? MS. MENNINGER: Objection, leading. THE WITNESS: I don't remember. MS. MENNINGER: Misstates the testimony. THE WITNESS: Sorry. I don't remember. All I remember was that somebody got her from there to Jeff. MR. EDWARDS: Got it. BY MR. EDWARDS: Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page38 of 883 109 Then there's months; November, December. A So this is the year 2000, and these are the months? MS. MENNINGER: Objection to this entire line of questioning. The witness has no foundation for talking about this particular document. BY MR. EDWARDS: Okay. So do you know how long that -- as you sit here today, do you remember how long Virginia had been going over to Jeff?s house before she started traveling on an airplane with him? MS. MENNINGER: Objection, foundation. THE WITNESS: No. BY MR. EDWARDS: It could be months, it could be a year? MS. MENNINGER: Objection, foundation. THE WITNESS: I don't think it -- I don't think she was there for very long without doing traveling. BY MR. EDWARDS: But in your mind, you can't tell me how long "very long" is? A No, I mean, I don't. Okay. And is there anything that would tell you the year or the month in which you remember Virginia first Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page39 of 883 110 going over to Jeff's house? A Not really. There's nothing I could really show you in this world that would remind you right now? A No. Okay. Before going over to work with Jeff, did Virginia have any massage experience? A No. When I think you said with respect to "bringing other girls, that sounds familiar," what other girls do you remember her bringing? Do you remember their names? A I don't remember names. MS. MENNINGER: Objection, foundation. BY MR. EDWARDS: Did you ever drive any of the other girls over to Jeff's house? A I don't think so. Okay. How many times did you to to Jeff's house? A A few times. Like, I think I went I think I dropped her off and somebody always brought her back. I don't really remember picking her up too much. Okay. And in the beginning, she was telling you that she was performing massages? Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page40 of 883 A Yeah, something like that. Do you know what time of year? A No. Do you know whether the spa at Mar?a?Lago closes during the summers? MR. EDWARDS: Form. THE WITNESS: No, I have no idea. BY MS. MENNINGER: You don't know how she got the job with Jeff? A No. I know somebody somebody like, that's why I said "recruited" that's the only word I can think of that worked for Jeff. Why do you use the word "recruited"? A Because that's the only word I don't know, football or everything. That's the only word I can think of, you recruit somebody. Hired her? A Yeah, I guess. It was it was just a very fast thing. You don't know who that person was? A No. You don't know what she said to that person? A No. You don't know what that person said to her? A Nope. Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 127 Case 18-2868, Document 283, 08/09/2019, 2628241, Page41 of 883 128 Do you remember her coming home and saying got a job with Jeff"? A I remember she said she got a job with Jeff. Did she tell about that job? A I think it was I think at the time it was for massage therapy, like, she was going to be a masseuse. And she was excited about it? A Yeah. She wasn't sad about it? A Not that I remember. But I really don't remember much from back then. She wasn't crying when she came home and said just got a job with Jeff," right? A No. You're guessing that you she got the job with Jeff before you moved into the Bent Oak apartment, but you don't know. Correct? MR. EDWARDS: Form THE WITNESS: Yes. But I would think we would have had to have had the money by then. So that was the only time she was making real good money. BY MS. MENNINGER: And do you know how much that apartment cost? A I know it was expensive. Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page42 of 883 I I A STATE OF FLORIDA COUNTY OF MARION I, Karla Layfield, RMR, Stenographic Court Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing deposition of James Michael Austrich; that said witness was duly sworn to testify truthfully; and that the foregoing pages, numbered 1 through 145, inclusive, constitute a true and correct record of the testimony given by said witness to the best of my ability. I FURTHER CERTIFY that I am not a relative or employee or attorney or counsel of any of the parties hereto, nor a relative or employee of such attorney or counsel, nor am I financially interested in the action. WITNESS MY HAND this day of June, 2016, at Ocala, Marion County, Florida. Karla Layfield, RMR Stenographic Court Reporter Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 146 Cam: 18-7808, 782, 08/00/7010, 7678741, PagpAR nf EXHIBIT 3 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page44 of 883 Page 1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS VIRGINIA L. GIUFFRE, Plaintiff, -againstGHISLAINE MAXWELL, Defendant. ___________________________/ 250 N. Australian Avenue, Suite 1400 West Palm Beach, Florida 33401 Friday, September 9, 2016 8:35 a.m. - 2:08 p.m. C O N F I D E N T I A L VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Taken before Darline M. West, Registered Professional Reporter, Notary Public in and for the State of Florida At Large, pursuant to Notice of Taking Deposition filed by the Plaintiff in the above cause. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 Case 18-2868, Document 283, 08/09/2019, 2628241, Page45 of 883 Page 74 1 2 3 J. Epstein - Confidential BY MR. CASSELL: Q. Isn't it true that Maxwell led Virginia up 4 to your Palm Beach mansion massage room the first 5 time you met her? 6 7 MR. PAGLIUCA: foundation. 8 9 10 11 THE WITNESS: Q. 16 You saw Maxwell bringing Virginia up to your room, true, sir? MR. PAGLIUCA: Object to form and foundation. 14 15 Fifth. BY MR. CASSELL: 12 13 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. Isn't it true that it was standard 17 operating procedure for Maxwell to bring underage 18 girls up to your room? 19 20 MR. PAGLIUCA: foundation. 21 22 23 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. Isn't it true that it was standard 24 operating procedure for Maxwell to bring underage 25 girls up to your room for you to sexually abuse? Case 18-2868, Document 283, 08/09/2019, 2628241, Page46 of 883 Page 116 1 J. Epstein - Confidential 2 3 4 5 THE WITNESS: BY MR. CASSELL: Q. MR. PAGLIUCA: 10 Object to form and foundation. 8 9 In 2000, Virginia was approached by Maxwell, true? 6 7 Fifth. THE WITNESS: Fifth. BY MR. CASSELL: Q. Maxwell was one of the main women whom you 11 used to procure underage girls for sexual activities, 12 true? 13 14 MR. PAGLIUCA: foundation. 15 16 17 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. It was your understanding that Maxwell met 18 Virginia at the Mar-a-Lago Club in Palm Beach in 19 2000, true? 20 21 MR. PAGLIUCA: foundation. 22 23 24 25 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. In 2000, you were a member of the Mar-a-Lago Club, true? Case 18-2868, Document 283, 08/09/2019, 2628241, Page47 of 883 Page 117 1 J. Epstein - Confidential 2 MR. PAGLIUCA: 3 THE WITNESS: 4 5 6 Q. 11 In 2000, Ms. Maxwell had access to the Mar-a-Lago Club, true? MR. PAGLIUCA: Object to form and foundation. 9 10 Fifth. BY MR. CASSELL: 7 8 Object to form. THE WITNESS: Fifth. BY MR. CASSELL: Q. The reason Maxwell had access to the 12 Mar-a-Lago Club in 2000 was because of your 13 connections to the club, true? 14 15 MR. PAGLIUCA: foundation. 16 17 18 19 THE WITNESS: Q. 24 25 Maxwell was a primary co-conspirator in your sexual abuse scheme, true? MR. PAGLIUCA: Object to form and foundation. 22 23 Fifth. BY MR. CASSELL: 20 21 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. Maxwell was a primary co-conspirator in your sex trafficking scheme, true? Case 18-2868, Document 283, 08/09/2019, 2628241, Page48 of 883 Page 118 1 J. Epstein - Confidential 2 3 MR. PAGLIUCA: foundation. 4 5 6 7 THE WITNESS: Q. 12 Maxwell herself regularly participated in your sexual exploitation of minors, true? MR. PAGLIUCA: Object to form and found. 10 11 Fifth. BY MR. CASSELL: 8 9 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. In 2000, Maxwell herself regularly 13 participated in your sexual exploitation of minors, 14 true? 15 16 MR. PAGLIUCA: foundation. 17 18 19 20 THE WITNESS: Q. 25 Maxwell herself regularly participated in your sexual exploitation of Virginia, true? MR. PAGLIUCA: Object to form and foundation. 23 24 Fifth. BY MR. CASSELL: 21 22 Object to form and THE WITNESS: Fifth. BY MR. CASSELL: Q. Did Maxwell participate in your sexual Case 18-2868, Document 283, 08/09/2019, 2628241, Page49 of 883 Page 376 1 REPORTER'S CERTIFICATE 2 STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 I, DARLINE MARIE WEST, RPR, certify that I was 6 authorized to and did stenographically report the 7 foregoing deposition; and that the transcript is a 8 true record thereof. 9 10 I further certify that I am not a relative, 11 employee, attorney, or counsel of any of the parties, 12 nor am I a relative or employee of any of the 13 parties' attorney or counsel connected with the 14 action, nor am I financially interested in the 15 action. 16 17 Dated this 13th day of September 2016. 18 19 20 21 ________________________ 22 DARLINE MARIE WEST, RPR 23 24 25 Cam: 18-7868, 782, 08/09/7010, 7678741, Pagp?n nf EXHIBIT 4 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page51 of 883 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. ____________________/ VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume 1 of 2 Pages 1 - 157 Taken at the Instance of the Defendant 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 8:59 a.m. 1:22 p.m. Sout hernR eport i ngC ompany w w w .Sout hernreport i ng.com -(3 8 6)2 57-3 663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page52 of 883 82 1 Q Right? 2 A Yeah. 3 Q And she travelled the world? 4 A Uh-huh (affirmative). 5 Q Did JJ say there was anything weird about 6 7 her job? A 10 11 12 No. MR. EDWARDS: 8 9 Yes. Object to the form. BY MS. MENNINGER: Q Did you know whether she had any massage training? A I did not. Like I said, the past three -- 13 three or four years before then, I had no contact 14 with her whatsoever. 15 certified in or had done with her life. 16 17 18 19 20 21 22 23 Q Okay. So I had no clue what she was I would like to take about a five- or ten-minute break, if that's okay with you. A That's fine. THE VIDEOGRAPHER: The time is 10:13. We are off the record. The time is 10:27. We are back on the record. MS. MENNINGER: All right. I would like 24 to mark as an exhibit now Defendant's 25 Exhibit 4. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page53 of 883 88 1 certain times and stuff. And it would just -- you 2 know, it just did not make sense to me that it it 3 was just a masseuse, you know. 4 billionaire. 5 do you need her, you know. You can afford another masseuse. 6 Q 7 (Brief interruption.) 8 A Let me turn this down. 9 Q Sorry. 10 A I'm sorry. 11 (Briefly off the record.) 12 Q 13 14 Like I said, he's a Why Do you know whether he -- Do you know whether he had other masseuses at the time? A I -- I really don't know. All I know is 15 he would have Virginia, obviously, go out and look 16 for other girls, also, to bring back, as well. 17 Q And how do you know that? 18 A Because she had explained to me that 19 sometimes when she would go out on trips that her 20 and Ms. Maxwell and stuff would go out to, like, 21 clubs and stuff and just try and pick up girls to 22 bring back, so... 23 Q That's what Virginia told you? 24 A Yes. 25 Q All right. Did any of your information -- Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page54 of 883 89 1 (Brief interruption.) 2 A I thought I muted it. 3 Q Did any of your information come from 4 5 anywhere other than Virginia? A 6 7 No. MR. EDWARDS: A Object to the form. Like I said, I did not talk -- I did not 8 really speak to any of them other than, you know, 9 hi, how's it going and stuff like that, until I had 10 actually met Jeffrey. 11 I ever really spoke with. 12 couple of times, but it was never, like, you know, 13 actual conversations, so... 14 BY MS. MENNINGER: 15 16 17 18 19 20 Q All right. And then he was the only one I had met Ms. Maxwell a Well, let me -- when did you meet Jeffrey? A I'd probably say -- probably a few months after I had moved in with her. Q Okay. And how did you come to meet Jeffrey? 21 A Dropping her off over at his mansion. 22 Q And did you drop her off using her car? 23 A Yes. 24 Q And so she just asked you: 25 Can you take me over there? Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page55 of 883 90 1 A Yeah. 2 Q And did she tell you where to go? 3 A Yeah. 4 everything. 5 car, because she was going somewhere else in the 6 world and did not need it, so... 7 8 And then obviously I got to take the Q You were dropping her off for a multi-day A Yeah. trip? 9 10 She told where he lived and She would normally go about two weeks out of every month, so... 11 Q Two weeks straight? 12 A Yeah. 13 gone, basically. 14 15 16 It was two weeks home and two weeks Q Did you always take her to his house, A Yeah. or... Pretty much every time I took her 17 there, it was always to his mansion. 18 up one time -- maybe it was a couple of times -- 19 from the jet stream place. 20 single time it was at the hou- -- at the mansion. 21 (Brief interruption.) 22 Q 23 I'm -- 24 A No, it is. 25 Q That's okay. Okay. I picked her But pretty much every So you're -- is that your phone? I thought I muted it. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page56 of 883 92 1 2 3 4 5 talking like that, so... Q Okay. Where did your first conversation with Jeffrey take place? A I'm pretty sure it was in the kitchen or the living room. 6 Q Inside the house? 7 A Yeah, it was inside the house. I've never 8 seen him anywhere else other than in the mansion or 9 getting off the jet. 10 11 Q So you were allowed to go inside the house -- 12 A Yeah. 13 Q -- with Ms. Roberts? 14 A Yeah. But I never went upstairs. I've 15 only been in the kitchen, the living room, and by 16 the pool. 17 18 19 20 21 Q How many times would you estimate that you had been over to the house? A I mean, at least once every two weeks to drop her off, you know. Q Was there a period of time between 2001 22 and when she left in 2002 where she was not working 23 for Jeffrey? 24 A Yes. 25 Q What period of time was that? Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page57 of 883 93 1 A It was pretty much, like, when she was 2 actually working as a server. 3 because we were trying to not have her go back 4 there. 5 And we were trying to just work without needing his 6 money, you know. 7 Like, basically Like, she did not want to go back there. Q All right. And if I can re-call up that 8 Exhibit 2, can you see from here when about she was 9 working as a server? 10 A March 4th, '02. 11 Q Do you know about how long she worked 12 there? 13 A I do not. 14 Q Days? 15 A I really have no clue. 16 Q Okay. 17 I'm not sure. Weeks? Months? Anything? How old was Ms. Roberts in 2002, if you know? 18 A I'd probably say, like, 18 or so, maybe. 19 Q If her birthday is in '83 -- 20 A Oh, if it's in '83, then I'd say -- 21 because I was born in '82, so a year younger than me 22 would be... 23 Q 18, 19? 24 A Yeah, somewhere around there. 25 MR. EDWARDS: Object to the form. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page58 of 883 96 1 Q I guess my question is: Did she ever tell 2 you that she had started as a regular masseuse for 3 him and then transitioned to something other than a 4 masseuse? 5 A No. She never said that it transitioned. 6 But she ended up explaining to me what had happened 7 before, so... 8 Q What has -- what is that? 9 A That her and Ms. Maxwell and Jeffrey would 10 obviously be doing stuff, all three of them 11 together. 12 to clubs to pick up girls and try and find them to 13 bring back for Jeffrey. 14 how, like I said, her and Ms. Maxwell and Jeffrey 15 were all intimate together on multiple occasions. Like I said, that they would all go out And then she told me about 16 Q When did she tell you this? 17 A I'm not exactly sure on the dates. 18 Q Was it while you were still together? 19 A Yes. 20 Q Did you -- had you met Ms. Maxwell? 21 A Yeah, I had met her a couple of times. 22 Q When did you meet Ms. Maxwell? 23 A Dates, I'm unsure of. But it was pretty 24 much, like I said, at Jeffrey's house in the 25 kitchen. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page59 of 883 97 Q 1 2 Was it earlier in the time you were with her, or... 3 A 4 or so. 5 Q It was about -- I'd say about six months I don't know. All right. I'm not exactly positive. So at the time you met 6 Ms. Maxwell, had Ms. Roberts already told you that 7 she had been intimate? A 8 9 10 11 No. She had told me about that, I believe, after I had max- -- after I had already met her. Q Okay. And tell me everything that you 12 remember about what Ms. Roberts said about being 13 intimate with Ms. Maxwell and Mr. Epstein at the 14 same time. 15 A I remember her talking about, like, 16 strap-ons and stuff like that. 17 said, all the details are not really that clear. 18 But I remember her talking about, like, how they 19 would always be using and stuff like that. 20 21 Q But, I mean, like I She and Ms. Maxwell and Mr Epstein would used strap-ons? 22 A Uh-huh (affirmative). 23 Q How did you feel about that? 24 A I just -- obviously not happy about it. 25 Q What did you say? Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page60 of 883 103 1 A I did not. 2 Q When the FBI interviewed you, did you 3 4 5 6 7 8 9 10 mention this to them? A I mentioned -- anything they asked me, I did not hold anything back. Q Okay. Do you recall specifically talking about sex with the Prince? A I -- I don't recall talking to them about that, but, I mean, it's -- it could be possible. Q Other than sex with the Prince, is there 11 anyone else that Jeffrey wanted Ms. Roberts to have 12 sex with that she relayed to you? 13 14 15 16 A Mainly, like I said, just Ms. Maxwell and all the other girls. Q Ms. Maxwell wanted -- Jeffrey wanted Virginia to have sex with Ms. Maxwell? 17 A And him, yeah. 18 Q And did she tell you whether she had ever 19 done that? 20 A Yeah. 21 Q And when did she tell you that? 22 A I'm not sure on the date. 23 Q And what did she describe having happened? 24 A I believe I already told you that. 25 She said that she did. the strap-ons and dildos and everything. Southern Reporting Company www.Southernreporting.com - (386)257-3663 With Case 18-2868, Document 283, 08/09/2019, 2628241, Page61 of 883 157 CERTIFICATE OF REPORTER 1 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 www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page62 of 883 158 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. ____________________/ VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume 2 of 2 Pages 158 - 258 Taken at the Instance of the Defendant 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 8:59 a.m. 1:22 p.m. Sout hernR eport i ngC ompany w w w .Sout hernreport i ng.com -(3 8 6)2 57-3 663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page63 of 883 168 1 A Yes. 2 Q All right. 3 And that belief was based on Virginia telling you that? 4 A And JJ and Michael. 5 Q Okay. 6 So you had heard from some other people, and then later -A 7 Yeah. Before she had come back to the 8 apartment, they said that she was a masseuse for 9 this guy. Q 10 11 All right. Once you started dating her again -- I'm sorry. Prior to dating her. 12 13 And then when she came back, she told me. time you were dating her. Go back to the first Did she have money? 14 A No. 15 Q All right. 16 place? 17 A No. 18 Q Was she doing massages, at all? 19 A No. 20 Q All right. Was she able to afford her own Fast forward to the second 21 time when you get back together with her sometime in 22 2001. 23 A Uh-huh (affirmative). 24 Q Did she appear to you to have any massage 25 training? Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page64 of 883 169 1 A No. 2 Q As a seventeen-year-old at that time, was 3 she able to afford things? MS. MENNINGER: 4 5 6 Objection. Form. Foundation. BY MR. EDWARDS: 7 Q Did she have money -- 8 A She had money. 9 Q -- while working with Jeff? And was the money in the form of cash? 10 11 A Yes. 12 Q And did she always have cash? 13 A Yes. 14 Q And how was the apartment paid for? MS. MENNINGER: 15 16 Foundation. 17 A 18 19 20 Objection. Form. Cash. BY MR. EDWARDS: Q And did you see how she was paying for the apartment? 21 A I did not watch her pay the bill, but... 22 Q Okay. 23 24 25 When you would go to dinner, who would pay? A Just whoever. MS. MENNINGER: Objection. Form. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page65 of 883 200 MS. MENNINGER: 1 2 Foundation. 3 A 4 5 Objection. Form. For Jeffrey. BY MR. EDWARDS: Q All right. Let me fix this. Ghislaine -- 6 when Ghislaine Maxwell would call you during the 7 time that you were living with Virginia, she would 8 ask you what, specifically? MS. MENNINGER: 9 10 Foundation. 11 A Objection. Form. Just if I had found any other girls just 12 to bring to Jeffrey. 13 BY MR. EDWARDS: 14 Q Okay. 15 A Pretty much every time there was a 16 conversation with any of them, it was either asking 17 Virginia where she was at, or asking her to get 18 girls, or asking me to get girls. 19 Q All right. Let's go to that second 20 category you just identified, which is asking 21 Virginia to get girls. 22 room where specifically Ghislaine Maxwell would ask 23 Virginia to bring girls? How many times were you in a 24 A None that I can recall. 25 Q Okay. How many times -- when you say they Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page66 of 883 228 1 went with Virginia, and you dropped her off; and 2 some occasions you went inside? 3 A Yeah. 4 Q And some of the occasions you went inside, 5 you hung out by the pool? 6 A Yes. 7 Q Or in the kitchen with the chef? 8 A Yeah. 9 Q All right. And in the total of all the 10 times that you went inside the house, you saw 11 Ms. Maxwell -- I think you got up to six times? 12 A Yeah, about five or six times. 13 Q All right. 14 A Total. 15 Q That's not five or six times where -- 16 A That was period, all together. 17 Q -- you brought girls? 18 A No. 19 Q All right. Total? All together, period. I thought you said when I was 20 asking you questions that Ms. Maxwell never asked 21 you to bring girls. 22 A I don't remember saying that. 23 Q Okay. 24 25 Well, tell me. When did Ms. Maxwell ask you to bring a girl? A Never in person. It was, like, literally, Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page67 of 883 229 1 like, on the phone maybe, like, once or twice. 2 Q 3 frequently? 4 A No. 5 Q All right. 6 7 8 All right. Did Ms. Maxwell call you How many times do you think Ms. Maxwell called you, at all? A I'd just say that probably a just a few, a couple of times. Maybe once or twice. 9 Q One or two -- 10 A The majority of the time it was pretty 11 much his assistant. 12 Q How do you know Ms. Maxwell's voice? 13 A Because she sounds British. 14 Q So someone with a British accent called 15 you once or twice and asked for -- 16 A Well, she told me who she was. 17 Q Okay. 18 19 And what did she say when she called you and asked you to bring girls? A She just said, "Hi. This is Ghislaine. 20 Jeffrey was wondering if you had anybody that could 21 come over." 22 Q Okay. 23 A I'm not exactly sure on the time frame. 24 Q Was it after the Roadhouse Grill or 25 When did that happen? before? Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page68 of 883 248 1 Q So the thing that Virginia was tired of -- 2 just so that the record is clear -- well, I'll let 3 you answer in your words. Just be clear. 4 What was it that Virginia was trying to 5 get away from and stop with respect to working at 6 Jeffrey Epstein's house? 7 MS. MENNINGER: Objection. Form, 8 foundation -- as to Virginia's thought 9 processes. 10 11 12 A To stop being used and abused. BY MS. MENNINGER: Q How do you know that? MS. MENNINGER: 13 14 Foundation. 15 A Objection. Form. Due to all the things that I have come 16 to -- that have been brought to light, and in the 17 experiences that I've had, and the conversations 18 that I have had with her. 19 to that, so... 20 BY MS. MENNINGER: 21 Q Like, it just all adds up When Virginia was wanting to get out, did 22 she ever express that it was the times of work that 23 she was trying to get away from? 24 A No. 25 Q Okay. What was she specifically Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page69 of 883 251 1 2 Q Was she getting paid as much as she was getting paid to work for Jeff Epstein? 3 A Definitely not. 4 Q She no longer had cash all around? 5 A Nope. 6 Q You mentioned that there was -- you had 7 several conversations with Virginia when she was 8 discussing them wanting -- or I think the word you 9 used was force, but later we tried to clarify that, 10 but them forcing her to have sex with Prince Andrew. 11 Do you remember that? 12 A Yeah. 13 Q And that you expressed that you were 14 worried for her safety if she were to decline that? 15 A Yes. 16 Q What about your conversation with Virginia 17 on that particular occasion made you worried for 18 Virginia's safety? 19 20 21 A Just the way she was talking to me. Like, she just sounded scared. Q And what -- what -- try to dig back and 22 remember what exactly she was saying and how she was 23 saying it, if you could just describe that for us. 24 25 A She said that she went to go in -- I remember at one time she was talking to me about how Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 18-2868, Document 283, 08/09/2019, 2628241, Page70 of 883 258 CERTIFICATE OF REPORTER 1 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 www.Southernreporting.com - (386)257-3663 Cam: 18-7868, 782, 08/09/7010, 7678741, Pagp71 nf EXHIBIT 5 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page72 of 883 GI UFFRE VS. IMAXWELL mm VIRGINIA GI UF FRE 05/03/2016 Agren Blando Court Reporting Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-001 7 Case 18-2868, Document 283, 08/09/2019, 2628241, Page73 of 883 ×Ò ÌØÛ ËÒ×ÌÛÜ ÍÌßÌÛÍ Ü×ÍÌÎ×ÝÌ ÝÑËÎÌ ÍÑËÌØÛÎÒ Ü×ÍÌÎ×ÝÌ ÑÚ ÒÛÉ ÇÑÎÕ Ý·ª·´ ß½¬·±² Ò±ò ïëó½ªóðéìííóÎÉÍ ÝÑÒÚ×ÜÛÒÌ×ßÔ Ê×ÜÛÑÌßÐÛÜ ÜÛÐÑÍ×Ì×ÑÒ ÑÚ Ê×ÎÙ×Ò×ß Ù×ËÚÚÎÛ Ó¿§ íô îðïê Ê×ÎÙ×Ò×ß Ôò Ù×ËÚÚÎÛô д¿·²¬·ººô ªò ÙØ×ÍÔß×ÒÛ ÓßÈÉÛÔÔô Ü»º»²¼¿²¬ò ßÐÐÛßÎßÒÝÛÍæ ÚßÓÛÎô ÖßÚÚÛô ÉÛ×ÍÍ×ÒÙô ÛÜÉßÎÜÍô Ú×ÍÌÑÍ ú ÔÛØÎÓßÒô ÐòÔò Þ§ Þ®¿¼ Û¼©¿®¼-ô Û-¯ò ìîë Òò ß²¼®»©- ߪ»²«» Í«·¬» î Ú±®¬ Ô¿«¼»®¼¿´»ô ÚÔ íííðï и±²»æ çëìòëîìòîèîð ¾®¿¼à°¿¬¸¬±¶«-¬·½»ò½±³ ß°°»¿®·²¹ ±² ¾»¸¿´º ±º ¬¸» д¿·²¬·ºº ÞÑ×ÛÍô ÍÝØ×ÔÔÛÎ ú ÚÔÛÈÒÛÎ ÔÔÐ Þ§ Í·¹®·¼ Íò ӽݿ©´»§ô Û-¯ò øÚ±® ᮬ·±²÷ ìðï Û¿-¬ Ô¿- Ñ´¿- Þ±«´»ª¿®¼ Í«·¬» ïîðð Ú±®¬ Ô¿«¼»®¼¿´»ô ÚÔ íííðïóîîïï и±²»æ çëìòíëêòððïï -³½½¿©´»§à¾-º´´°ò½±³ ß°°»¿®·²¹ ±² ¾»¸¿´º ±º ¬¸» д¿·²¬·ºº Case 18-2868, Document 283, 08/09/2019, 2628241, Page74 of 883 ï î í ì ë ê é è ç ïð ïï ïî ïí ïì ïë ïê ïé ïè ïç îð îï îî îí îì îë ßÐÐÛßÎßÒÝÛÍæ øݱ²¬·²«»¼÷ ØßÜÜÑÒô ÓÑÎÙßÒ ßÒÜ ÚÑÎÓßÒô ÐòÝò Þ§ Ô¿«®¿ ßò Ó»²²·²¹»®ô Û-¯ò Ö»ºº®»§ Íò п¹´·«½¿ô Û-¯ò ïëð Û¿-¬ ï𬸠ߪ»²«» Ü»²ª»®ô ÝÑ èðîðí и±²»æ íðíòèíïòéíêì ´³»²²·²¹»®à¸³º´¿©ò½±³ ¶°¿¹´·«½¿à¸³º´¿©ò½±³ ß°°»¿®·²¹ ±² ¾»¸¿´º ±º ¬¸» Ü»º»²¼¿²¬ ß´-± Ю»-»²¬æ Þ®»²¼¿ α¼®·¹«»¦ô п®¿´»¹¿´ Ò·½¸±´¿- Úò Þ±®¹·¿ô ÝÔÊÍ Ê·¼»±¹®¿°¸»® Case 18-2868, Document 283, 08/09/2019, 2628241, Page75 of 883 ï §±« ¼±²ù¬ò î ܱ §±« ¸¿ª» ¿²§ ®»¿-±² ¬± ¾»´·»ª» ¬¸¿¬ ¿²§ í ±º §±«® °®»ª·±«- -©±®² -¬¿¬»³»²¬- ¬¸¿¬ §±« ¸¿ª» ³¿¼» ì ¿®» ²±¬ ¬®«»á ë ß ê Ò±ò ÓÎò ÛÜÉßÎÜÍæ × ¶«-¬ ±¾¶»½¬ ¿²¼ ¿-µ ¬¸¿¬ é ·º ©»ù®» ¹±·²¹ ¬± ¿-µ ¬¸» ©·¬²»-- ¯«»-¬·±²- ¿¾±«¬ ¿²§ è ±º ¸»® -¬¿¬»³»²¬- ·² ©¸±´» ±® ·² °¿®¬ ¬¸¿¬ ¬¸» ç ©·¬²»-- ¾» ¿´´±©»¼ ¬± -»» ¬¸» -¬¿¬»³»²¬ô ®»ª·»© ¬¸» ïð ïï ïî -¬¿¬»³»²¬ ¿²¼ ¬¸»² ¿²-©»® §±«® ¯«»-¬·±²-ò Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ DZ« ³¿§ ¿²-©»® ¬¸» ¯«»-¬·±²ò ïí ß Ý¿² §±« ®»¿-µ ¬¸» ¯«»-¬·±²á ïì Ï Ü± §±« ¸¿ª» ¿²§ ®»¿-±² ¬± ¾»´·»ª» ¬¸¿¬ ¿²§ ïë ïê ïé ïè ïç ×ù³ -±®®§ò ±º §±«® °®·±® -©±®² -¬¿¬»³»²¬- ¿®» «²¬®«»á ß × ¸¿ª» ²± ®»¿-±² ¬± ¾»´·»ª» ¬¸¿¬ ³§ °®·±® -¬¿¬»³»²¬- ¿®» «²¬®«»ò Ï Ø¿- ¿²§±²» ¬±´¼ §±« ¬± -¿§ -±³»¬¸·²¹ ¬¸¿¬ ©¿- ²±¬ ¬®«» ·² ½±²²»½¬·±² ©·¬¸ ¬¸·- ½¿-»á îð ß Ò±ô ³¿ù¿³ò îï Ï ß´´ ®·¹¸¬ò ×ù¼ ´·µ» ¬± -¬¿®¬ ©·¬¸ ¿ îî ´¿©-«·¬ ¬¸¿¬ §±« º·´»¼ «²¼»® ¬¸» ½¿°¬·±² Ö¿²» ܱ» îí ª»®-«- Ö»ºº®»§ Û°-¬»·²ò îì îë ܱ §±« ®»½¿´´ ¬¸¿¬ ´¿©-«·¬á ß × ¾»´·»ª» -±ò Case 18-2868, Document 283, 08/09/2019, 2628241, Page76 of 883 ï î øÛ¨¸·¾·¬ ï ³¿®µ»¼ò÷ Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ×ù³ ¹±·²¹ ¬± -¸±© §±« í ¿² »¨¸·¾·¬ ¬¸¿¬ ©» ¿®» ³¿®µ·²¹ ¿- Ü»º»²¼¿²¬ù- ì Û¨¸·¾·¬ ïò ë ÓÎò ÛÜÉßÎÜÍæ ê ×ù¼ ¶«-¬ ´·µ» ¬± ³¿µ» ¿² ±¾¶»½¬·±² ±² ¬¸» é è ç Ý¿² × -»» ¬¸¿¬ º±® ¿ -»½±²¼á ®»½±®¼ º±® ¬¸» ³·-·¼»²¬·º·½¿¬·±² ±º ¬¸·- ¼±½«³»²¬ò ɸ·´» ¬¸»®» ©¿- ¿ ´¿©-«·¬ º·´»¼ «²¼»® ¬¸» -¬§´» ±º Ö¿²» ܱ» ª»®-«- Ö»ºº®»§ Û°-¬»·²ô Ö¿²» ܱ» ïð ©¿- ²±¬ Ê·®¹·²·¿ Ù·«ºº®»ò ïï ¾»·²¹ ¸¿²¼»¼ ¬± ¬¸·- ©·¬²»-- ·- Ö¿²» ܱ» ïðî ª»®-«- ïî Ö»ºº®»§ Û°-¬»·²ò ß²¼ ¬¸» ´¿©-«·¬ ¬¸¿¬ù- ²±© ïí ×- ¬¸¿¬ ¬¸» ¼±½«³»²¬ ©»ù®» ¬¿´µ·²¹ ¿¾±«¬á ïì ÓÍò ÓÛÒÒ×ÒÙÛÎæ ݱ«²-»´ô ·º §±« ¸¿ª» ¿² ïë ±¾¶»½¬·±²ô §±« -¸±«´¼ -¬¿¬» ¬¸» ¾¿-·- º±® §±«® ïê ±¾¶»½¬·±² ·² ¿ ²±²ó´»¿¼·²¹ô ²±²ó-«¹¹»-¬·ª» ³¿²²»®ò ïé ïè ïç ׺ §±« ¸¿ª» ¿²§ ±¬¸»® ®»½±®¼ ¬± ³¿µ»ô §±« ½¿² ¼± -± ·² ¿ °´»¿¼·²¹ º·´»¼ ©·¬¸ ¬¸» ݱ«®¬ò ÓÎò ÛÜÉßÎÜÍæ Í«®»ò Ó§ ±¾¶»½¬·±² ·- î𠧱«ùª» ³·-®»°®»-»²¬»¼ ©¸¿¬ §±«ùª» ¸¿²¼»¼ ¬¸» ©·¬²»--ò îï × ©¿²¬ ¬± ³¿µ» -«®» ¬¸¿¬ ¬¸» ©·¬²»-- ·- ¸±´¼·²¹ ©¸¿¬ îî §±« ¿½¬«¿´´§ ©¿²¬ ¸»® ¬± ¾» ¸±´¼·²¹ ¿- ±°°±-»¼ ¬± ¬¸» îí ´¿©-«·¬ §±« -¿·¼ ¬¸¿¬ §±« ©»®» ¹±·²¹ ¬± ¸¿²¼ ¸»®ò îì ̸¿¬ù- ·¬ò îë ÓÍò ÓÛÒÒ×ÒÙÛÎæ ݱ«²-»´ô × ©·´´ ¿-µ ¬¸» Case 18-2868, Document 283, 08/09/2019, 2628241, Page77 of 883 ï Ö¿²«¿®§ ï笸ô îðïëá î í ß Ö¿²«¿®§ îï-¬ô îðïëò ì ë ߬ ¬¸» ª»®§ ¬±° ±º ¬¸» °¿¹» ·¬ -¿§- Ï Ì¸» ¼¿¬» ·¬ ©¿- º·´»¼ò ×- ¬¸»®» ¿ ¼¿¬» ¶«-¬ ¿¾±ª» ¬¸» -·¹²¿¬«®» ¾´±½µá ê ß Ñ¸ô §»-ô -±®®§ò é Ï ß²¼ ©¸¿¬ ¼¿¬» óó ©¸¿¬ ¼¿¬» ©¿- ¬¸¿¬á è ß Ì¸» ï笸 ¼¿§ ±º Ö¿²«¿®§ô îðïëò ç Ï Ñµ¿§ò ïð ïí ß²¼ ¬¸·- ¼±½«³»²¬ ·- -±³»¬¸·²¹ ¬¸¿¬ §±« ¾»´·»ª» ½±²¬¿·²- ¬¸» ¬®«¬¸ô ½±®®»½¬á ïï ïî Ç»-ô ¬¸»®» ·-ò ß Ì± ¬¸» ¾»-¬ ±º ³§ µ²±©´»¼¹» ¿¬ ¬¸» ¬·³»ô Ï ß´´ ®·¹¸¬ò §»-ò Ü·¼ -±³»¬¸·²¹ ½¸¿²¹» ¾»¬©»»² ïì ¬¸» ¬·³» ¬¸»² ¿²¼ ¬±¼¿§ ¬¸¿¬ ³¿µ»- §±« ¾»´·»ª» ¬¸¿¬ ïë ·¬ù- ²±¬ ¿´´ ¿½½«®¿¬»á ïê ß É»´´ô ¿- §±« ½¿² -»»ô ·² ´·²» ì ±² °¿¹» ïô ïé × ©¿-²ù¬ ¿©¿®» ±º ³§ ¼¿¬»-ò ïè ¾»-¬ ¬± ¹«»--¬·³¿¬» ©¸»² × ¿½¬«¿´´§ ³»¬ ¬¸»³ò ïç × ©¿- ¶«-¬ ¼±·²¹ ¬¸» Í·²½» ¬¸»² ×ùª» ¾»»² ¿¾´» ¬± º·²¼ ±«¬ ¬¸¿¬ î𠬸®±«¹¸ ³§ Ó¿®ó¿óÔ¿¹± ®»½±®¼- ¬¸¿¬ ·¬ ©¿- ¿½¬«¿´´§ îï ¬¸» -«³³»® ±º îðððô ²±¬ ¬¸» -«³³»® ±º ïçççò îî Ï Ñ¸ô ×ù³ -±®®§ò îí ß Ñ² ¬¸» º·®-¬ °¿¹»ò îì Ï Ñµ¿§ò îë ß Ç»-ò ß®» §±« ¾¿½µ ±² °¿¹» ïá Case 18-2868, Document 283, 08/09/2019, 2628241, Page78 of 883 ï î í ÓÎò ÛÜÉßÎÜÍæ ß-µ»¼ ¿²¼ ¿²-©»®»¼ò Ï ì ë Ѿ¶»½¬·±²ò øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ÓÎò ÛÜÉßÎÜÍæ ß Ç±« ³¿§ ¿²-©»®ò ß²-©»® ¿¹¿·²ò ß¹¿·²ô × ©±«´¼²ù¬ -¿§ ·¬ù- «²¬®«»ò ˲¬®«» ê ©±«´¼ ³»¿² ¬¸¿¬ × ©±«´¼ ¸¿ª» ´·»¼ò é ̸·- ©¿- ³§ ¾»-¬ µ²±©´»¼¹» ¿¬ ¬¸» ¬·³»ò è ª»®§ ¾»-¬ ¬± ¬®§ ¬± °·²°±·²¬ ¬·³» °»®·±¼- ¹±·²¹ ¾¿½µ ç -«½¸ ¿ ´±²¹ ¬·³» ¿¹±ò ïð ß²¼ × ¼·¼²ù¬ ´·»ò ß²¼ × ¼·¼ ³§ ׬ ©¿-²ù¬ «²¬·´ × º±«²¼ ¬¸» º¿½¬- ¬¸¿¬ × ïï ©±®µ»¼ ¿¬ Ó¿®ó¿óÔ¿¹± ·² îðð𠬸¿¬ × ©¿- ¿¾´» ¬± ïî º·¹«®» ¬¸¿¬ ±«¬ò ïí Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ß²¼ ¿°°®±¨·³¿¬»´§ ©¸»² ïì ¼·¼ §±« ´»¿®² ¬¸±-» º¿½¬- ¿¾±«¬ ¬¸» ¼¿¬»- §±« ©±®µ»¼ ïë ¿¬ Ó¿®ó¿óÔ¿¹±á ïê ß × ©±«´¼ -¿§ ·¬ ©¿- ³·¼óîðïëò ïé Ï Ó·¼óîðïë ·- ¬¸» º·®-¬ ¬·³» §±« ¾»½¿³» ïè ¿©¿®» ±º ¬¸» ¼¿¬»- óó ïç ß × ¼±²ù¬ µ²±© ¬¸» »¨¿½¬ óó îð Ï ×º §±« ½±«´¼ ¶«-¬ ´»¬ ³» º·²·-¸ò îï ß ×ù³ -±®®§ò îî Ï Ì¸¿¬ù- ¿´´ ®·¹¸¬ò ß°°®±¨·³¿¬»´§ ³·¼óîðïë îí ©¸»² §±« ´»¿®²»¼ ¬¸» ¬®«» ¼¿¬»- ¬¸¿¬ §±« ¸¿¼ ©±®µ»¼ îì ¿¬ Ó¿®ó¿óÔ¿¹±á îë ß Ì¸¿¬ù- ½±®®»½¬ò ͱ®®§ò Case 18-2868, Document 283, 08/09/2019, 2628241, Page79 of 883 ï ÓÎò ÛÜÉßÎÜÍæ Ѿ¶»½¬ ¬± ¬¸» º±®³ò î ß Ë¸³ô × ¼±²ù¬ µ²±©ô ¬± ¾» ¸±²»-¬ò í Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ß²¼ ·² ©¸¿¬ ±®¼»® ¼·¼ ì Ì¿½± Þ»´´ô Ы¾´·¨ ¿²¼ Ó¿®ó¿óÔ¿¹± ¹±ô ¿²¼ ¬¸» ¿ª·¿®§ô ë -±®®§á ê ß é Ѹô × ©±«´¼ ¸¿ª» ¬± ¹«»--ò ܱ §±« ©¿²¬ ³» ¬± ¹«»--á è Ï Í«®»ò ç ß Ë³ô × ©±«´¼ -¿§ Ы¾´·¨ò ß²¼ ¬¸»²ô × ¬¸·²µ ï𠬸¿¬ù- ©¸»² × ¸»´°»¼ ³§ ¾±§º®·»²¼ ±«¬ ¿¬ Ì¿½± Þ»´´ ïï ¿²¼ ¬¸»² × ¬¸·²µ ¬¸» ¿ª·¿®§ò ïî Ï ß²¼ ©¸»®» ©¿- ¬¸» Ì¿½± Þ»´´á ïí ß × ©¿- ´·ª·²¹ ·² Ú±®¬ Ô¿«¼»® óó × ¬¸·²µ ·¬ ïì ©¿- Ú±®¬ Ô¿«¼»®¼¿´»ò ïë -±³»©¸»®» ·² Ú´±®·¼¿ô Þ®±©¿®¼ ݱ«²¬§ô -±³»¬¸·²¹ ´·µ» ïê ¬¸¿¬ò ܱ²ù¬ ¯«±¬» ³» ±² ¬¸¿¬ô ¾«¬ ïé Ï ß²¼ ©¸± ©»®» §±« ´·ª·²¹ ©·¬¸ ¿¬ ¬¸¿¬ ¬·³»á ïè ß Ó·½¸¿»´ò ïç Ï Í± §±« ©»®» ´·ª·²¹ ©·¬¸ Ó·½¸¿»´ ©¸»² §±« îð Ø·- ²¿³» ·- Ö¿³»-ô ¾«¬ Ó·½¸¿»´ò ©±®µ»¼ ¿¬ ¬¸» Ì¿½± Þ»´´ô ®·¹¸¬á îï ß Ç»-ô × ©¿- ´·ª·²¹ ©·¬¸ ¸·³ò îî Ï ß²¼ §±« ©±®µ»¼ ©·¬¸ Ó·½¸¿»´ ©¸»² §±« îí ©±®µ»¼ ¿¬ ¬¸» Ы¾´·¨ô ½±®®»½¬á îì ß Ò±ò îë Ï Ñµ¿§ò ͱ Ы¾´·¨ ½¿³» ¿º¬»® Ì¿½± Þ»´´ ±® Case 18-2868, Document 283, 08/09/2019, 2628241, Page80 of 883 ï î Ï É¸¿¬»ª»® ¿¼¼®»-- §±« ©»®» ´·ª·²¹ ¿¬ô ¿¬ ¬¸» ¬·³» §±« -¬¿®¬»¼ ¿¬ Ó¿®ó¿óÔ¿¹±ò í ß ì ííìéðò ë Ï ê Ó¿®ó¿óÔ¿¹±á é ß Ô±¨¿¸¿¬½¸»»ô Ú´±®·¼¿ ر© ·- ·¬ ¬¸¿¬ §±« ½¿³» ¬± ©±®µ ¿¬ Ó§ ¼¿¼ ·- ¿ ³¿·²¬»²¿²½» ³¿²¿¹»® ±® è -«°»®ª·-±®ô × ¼±²ù¬ µ²±© ©¸¿¬ §±« ½¿´´ ·¬ò ç ©±®µ»¼ ·² ¬¸» ³¿·²¬»²¿²½» ¼»°¿®¬³»²¬ô ³±-¬´§ ±² ï𠬻²²·- ½±«®¬-ô ©±®µ·²¹ ±² ¬¸» ¿·® ½±²¼·¬·±²·²¹ô ïï ¸»´°·²¹ -»¬ «° º±® º«²½¬·±²-ò ïî ¶±¾ ¬¸»®»ò Þ«¬ ¸» ß²¼ ¸» ¹±¬ ³» ¿ -«³³»® ïí Ï Ñµ¿§ò ïì ß Ç»-ò ïë Ï É¸¿¬ ©»®» §±« ±² ¿ ¾®»¿µ º®±³á ïê ß × ¬¸·²µ ´·µ» óó ¬¸·- ·- ¹±·²¹ ¾¿½µ -± ´±²¹ ß²¼ §±« -¿·¼ §±« ©»®» ±² ¿ ¾®»¿µá ïé ²±©ô ¾«¬ × ©¿- ¿¬¬»³°¬·²¹ ¬± ¹»¬ ³§ ÙÛÜò ïè -«³³»® ½¿³»ô -± -½¸±±´ -¬±°- ¼«®·²¹ ¬¸» -«³³»®¬·³» ïç ¸»®» ·² ß³»®·½¿ô ¿²¼ × ¹±¬ ¿ -«³³»® ¶±¾ò ß²¼ ·¬ô îð Ï ß´´ ®·¹¸¬ò îï ß × ¼±²ù¬ ¿½¬«¿´´§ µ²±© ¬¸» ²¿³» ±º ¬¸» îî °´¿½»ò îí Ï ß ÙÛÜ °´¿½»á îì ß Ç»¿¸ô ·¬ ©¿-ô ´·µ»ô × ©¿- °®»ª·±«-´§ ·² îë ß²¼ ©¸»®» ©»®» §±« ·² -½¸±±´á ׬ù- óó §»¿¸ô × µ²±©ò α§¿´ п´³ Þ»¿½¸ Ø·¹¸ ͽ¸±±´ô ¾«¬ô × ³»¿²ô ¾»½¿«-» ±º Case 18-2868, Document 283, 08/09/2019, 2628241, Page81 of 883 ï Ï Ñµ¿§ò ׺ × ½¿² ¼·®»½¬ §±«® ¿¬¬»²¬·±² ¾¿½µ î ¬± Ü»º»²¼¿²¬ù- Û¨¸·¾·¬ ïî ¿¬ °¿¹» ïëò í ¸»¿¼·²¹ λ-°±²-» ¬± ײ¬»®®±¹¿¬±®§ Ò«³¾»® çô ¼± §±« ì -»» ¬¸¿¬ ©¸»®» ·¬ -¿§- óó ß²¼ «²¼»® ¬¸» ë ß Ç»-ò ê Ï óó Ó-ò Ö±ºº®»§ ø°®±²±«²½·²¹÷ óó Ù·«ºº®»ô é »¨½«-» ³»ô ®»-°±²¼- ¿- º±´´±©-á è ß Ç»-ò ç Ï Ñµ¿§ò ïð ׬ -¿§- §±« ©±®µ»¼ ¿- ¿ ´±½µ»® ®±±³ ¿¬¬»²¼¿²¬ º±® ¬¸» -°¿ ¿®»¿ô ½±®®»½¬á ïï ß Ç»-ò ïî Ï ß²¼ ·¬ -¿§- ®»½±®¼- °®±¼«½»¼ ·² ¬¸·- ½¿-» ïí ·¼»²¬·º§ ¬¸» ¼¿¬» ±º »³°´±§³»²¬ ¿- îðððô ½±®®»½¬á ïì ß Ç»-ò ïë Ï É¸¿¬ ®»½±®¼- ¬¸¿¬ ©»®» °®±¼«½»¼ ·² ¬¸·- ïê ½¿-» ½¿«-» §±« ¬± ¾»´·»ª» ¬¸¿¬ ¬¸» »³°´±§³»²¬ ¾»¹¿² ïé ·² îðððá ïè ïç ß Ë¸³ô ·- ¬¸·- ¹±·²¹ ¾¿½µ ¬± ¿²±¬¸»® ¯«»-¬·±² ¬¸¿¬ ×ù³ ²±¬ ¿´´±©»¼ ¬± ¿²-©»®á îð Ï Ò±ò îï ß × ¸¿ª» -»»² ¬¸» ¼±½«³»²¬-ô ¿²¼ × µ²±© ¬¸¿¬ îî îí îì îë ³§ »³°´±§³»²¬ ²±© ©¿- ·² îðððò Ï É¸¿¬ ¼±½«³»²¬- ¼·¼ §±« -»» ¬¸¿¬ ½¿«-»¼ §±« ¬± ³¿µ» ¬¸¿¬ ¿²-©»®á ß Ì¸» Ó¿®ó¿óÔ¿¹± »³°´±§³»²¬ ¼±½«³»²¬-ò Case 18-2868, Document 283, 08/09/2019, 2628241, Page82 of 883 ï ³¿--»«-»- ¸¿¼ ¬¸»·® ±©² «²·º±®³-ò î Ï É¸¿¬ ¼·¼ ¬¸» ³¿--»«-»-ù «²·º±®³ ´±±µ ´·µ»á í ß × ¼±²ù¬ ®»³»³¾»®ò ì Ï Ò± ®»½±´´»½¬·±² ¿¬ ¿´´á ë ß Ò±²» ©¸¿¬-±»ª»®ò ê Ï Ý±´±®á é ß Ò±ô -±®®§ò è Ï Ñµ¿§ò ç × ®»³»³¾»® ³·²»ò ر© ¼·¼ ·¬ ½±³» ¬± °¿-- ¬¸¿¬ §±« ©»®» ²± ´±²¹»® ©±®µ·²¹ ¿¬ Ó¿®ó¿óÔ¿¹± ·² ¬©± ¬± ¬¸®»» ïð ©»»µ-á ïï ß × ©¿- ¿°°®±¿½¸»¼ ¾§ Ù¸·-´¿·²» Ó¿¨©»´´ò ïî Ï Ñµ¿§ò ß²¼ ¸±© ´±²¹ ¸¿¼ §±« ¾»»² ©±®µ·²¹ ïí ¿¬ Ó¿®ó¿óÔ¿¹± ©¸»² §±« ©»®» ¿°°®±¿½¸»¼ ¾§ Ù¸·-´¿·²» ïì Ó¿¨©»´´á ïë ß Î±«¹¸´§ ¬©± ¬± ¬¸®»» ©»»µ-ò ïê Ï Ñµ¿§ò ïé ïè ɸ»®» ·² ¬¸» -°¿ ©»®» §±« ©¸»² §±« ©»®» ¿°°®±¿½¸»¼ ¾§ Ù¸·-´¿·²» Ó¿¨©»´´á ß Ö«-¬ ±«¬-·¼» ¬¸» ´±½µ»® ®±±³ô -·¬¬·²¹ ïç ©¸»®» ¬¸» ±¬¸»® ¹·®´ ¬¸¿¬ ©±®µ- ¬¸»®» «-«¿´´§ -·¬-ò îð ͸» ©¿- ¿©¿§ º®±³ ¬¸» ¼»-µò îï ³¿--¿¹» ¬¸»®¿°§ò × ©¿- ®»¿¼·²¹ ¿ ¾±±µ ±² îî Ï É¿- ¬¸¿¬ ·²¼±±®- ±® ±«¬¼±±®-á îí ß Ñ«¬¼±±®-ò îì Ï Ñµ¿§ò îë ·² ¬¸» -¸¿¼»á ß²¼ ©¸¿¬ óó ©»®» §±« ·² ¬¸» -«² ±® Case 18-2868, Document 283, 08/09/2019, 2628241, Page83 of 883 ï ©¿²¬»¼ ¬± ¿·³ º±® -±³»¬¸·²¹ ¸·¹¸»® ¬¸¿² ¾»·²¹ ¿ î ´±½µ»® ®±±³ ¿¬¬»²¼¿²¬ ±²» ¼¿§ò í ì Ï ß²¼ò Ç»¿¸ò ɸ¿¬ ©¿- ¬¸» ²¿³» ±º ¬¸» ³¿--¿¹» ¬¸»®¿°·-¬ ¬¸¿¬ §±« ©»®» -°»¿µ·²¹ ©·¬¸á ë ß Ñ¸ô × ¸¿ª» ²± ·¼»¿ò ê Ï Ý¿² §±« ¹·ª» ³» ¿²§ °¸§-·½¿´ ¼»-½®·°¬·±² é ±º ¿²§ ±º ¬¸»³á è ç ß ¸¿·®ò ˳ô ¬¸»®» ©¿- ±²» ©¸± ¸¿¼ ¾´±²¼» -¸±®¬ ̸»®» ©¿- óó × ©±«´¼ -¿§ ¬¸»®»ù- °®±¾¿¾´§ ïð ¿¾±«¬ º±«® ³¿--¿¹» ¬¸»®¿°·-¬- ¬¸¿¬ ©±®µ ·² ¬¸»®»ò ïï ͱô × ³»¿²ô × ¼±²ù¬ ®»³»³¾»® ¿´´ ±º ¬¸»³ò ïî Ï ïí ѵ¿§ò ɸ¿¬ ¬·³» ±º ¼¿§ ©¿- ·¬á ÓÎò ÛÜÉßÎÜÍæ Ѿ¶»½¬ ¬± ¬¸» º±®³ò ïì ß ßº¬»®²±±²ò ïë Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ïê ß ß²§©¸»®» ¾»¬©»»² î ¬± ìò ïé Ï ß²¼ ©¸¿¬ ¬·³» ¼·¼ §±« ¹»¬ ±ºº ±º ©±®µá ïè ß × ¾»´·»ª» × ¹±¬ ±ºº ¿¬ 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¬± ¸·³ò ïè «-»¼ ¬¸» °¸±²» º®±³ Ó¿®ó¿óÔ¿¹± ¬± ½¿´´ ¸»® ¿²¼ ¬»´´ ïç ¸»® ¬¸¿¬ × ©¿- ¿´´±©»¼ ¬± ½±³» ±ª»®ò îð ß²¼ × ¬±´¼ ¸»® ×ù¼ ¸¿ª» ¬± ¿-µ ³§ ¼¿¼ò × ®¿² ±ª»®ô ¿½¬«¿´´§ô ¬± -»» ³§ Ø» -¿·¼ ·¬ ©±«´¼ ¾» ±µ¿§ò ß²¼ -¸» -¿·¼ô Ù®»¿¬ò × Ó»»¬ ³» ¸»®» ¿¬ óó × îï ¼±²ù¬ ®»³»³¾»® ¬¸» »¨¿½¬ ¿¼¼®»--ô ¾«¬ ·¬ ©¿- îî Û´ Þ®·´´± É¿§ ·² п´³ Þ»¿½¸ óó ¿º¬»® §±« ¹»¬ ±ººò îí ß²¼ ³§ ¼¿¼ ¼®±ª» ³»ò îì îë Ï Ü·¼ §±« ©®·¬» ¼±©² ¸»® ¿¼¼ óó ¬¸» ¿¼¼®»-- ¬¸¿¬ -¸» ¹¿ª»á Case 18-2868, Document 283, 08/09/2019, 2628241, Page85 of 883 ï ß Ç»-ò î Ï Ü·¼ §±« ©®·¬» ¼±©² ¸»® °¸±²» ²«³¾»®á í ß Ç»-ò ì Ï Í± ¼·¼ §±« ¹± ®«² ¿²¼ ¬¿´µ ¬± §±«® ¼¿¼ ë ©¸·´» -¸» ©¿- -¬·´´ ¬¸»®»á ê é ß ß²¼ -¸» ¬±´¼ ³» ¬± ¿-µ ³§ ¼¿¼ ¿²¼ ¬¸»² ¬± ¹·ª» ¸»® ¿ °¸±²» ½¿´´ò è ç Ò±ô × ¾»´·»ª» -¸» ´»º¬ò Ï Ñµ¿§ò Ü·¼ -¸» ¿-µ §±« §±«® ¿¹» ©¸»² -¸» ¸¿¼ ¬¸¿¬ ½±²ª»®-¿¬·±² ©·¬¸ §±«á ïð ß Ò±ô -¸» ¼·¼ ²±¬ò ïï Ï Ü·¼ §±« ¬»´´ ¸»® §±«® ¿¹»á ïî ß Ò±ô × ¼·¼ ²±¬ò ïí Ï ß²¼ -± -±³»©¸»®» §±« ©®±¬» ¼±©² ¿ °¸±²» ïì ²«³¾»® ¬± ½¿´´ ¸»® ¾¿½µ ¿¬á ïë ß Ë³ó¸«³ò ïê Ï ß´´ ®·¹¸¬ò ß Ð®±¾¿¾´§ ¶«-¬ ¿ °·»½» ±º °¿°»® ´§·²¹ ïé ïè ïç ß²¼ ©¸»®» ¼·¼ §±« ©®·¬» ¬¸¿¬ ¼±©²á ¿®±«²¼ ¬¸» ¼»-µò îð Ï Ñµ¿§ò îï ß × ³»¿²ô ²±ô × ¼±²ù¬ ¸¿ª» ¬¸¿¬ °·»½» ±º îî Þ«¬ §±« ¼±²ù¬ ®»³»³¾»®á °¿°»® ¿²§³±®»ô -± ²±ò îí Ï Ñµ¿§ò îì ß Ç»-ò îë Ï ß²¼ ©¸¿¬ ²«³¾»® ¼± §±« ¬¸·²µ §±« ½¿´´»¼á ß²¼ ¼·¼ §±« ©®·¬» ¼±©² ¿² ¿¼¼®»--á Case 18-2868, Document 283, 08/09/2019, 2628241, Page86 of 883 ï Ï É¸»² ¼·¼ §±« ¹»¬ §±«® º·®-¬ ½¿®á î ß ßº¬»® ³§ ¬®·° ¬± Ô±²¼±² ¬± ³»»¬ Ю·²½» í ß²¼®»©ò ì Ï Ñµ¿§ò ë ß ß Ü±¼¹» Ü¿µ±¬¿ò ê Ï ß²¼ ¼·¼ §±« °«®½¸¿-» ¬¸¿¬ §±«®-»´ºá é ß Ç»-ô × ¼·¼ò è Ï ß²¼ ¸±© ³«½¸ ¼·¼ ·¬ ½±-¬á ç ß × ¼±²ù¬ ®»³»³¾»® ±ºº ¬¸» ¬±° ±º ³§ ¸»¿¼ ïð ɸ¿¬ µ·²¼ ±º ½¿® ¼·¼ §±« ¹»¬á ¸±© ³«½¸ ·¬ ½±-¬ò ïï Ï É¸± ¼·¼ §±« ¾«§ ·¬ º®±³á ïî ß Ó§ ¼¿¼ ¸»´°»¼ ³» ¾¿®¹¿·² ©·¬¸ ·¬ò ïí × ¼±²ù¬ ®»³»³¾»® ©¸»®» ©» ¾±«¹¸¬ ·¬ º®±³ò ïì Ï ïë ¼¿¼ù- ²¿³»á ïê ß ïé ¬¸·²µò ïè ®»¹·-¬»®»¼ ¿ ½¿® ±® ¿²§¬¸·²¹ ´·µ» ¬¸¿¬ ¾»º±®»ò ß²¼ ©¿- ¬¸» ¬·¬´» °«¬ ·² §±«® ²¿³» ±® §±«® × ¬¸·²µ ¬¸» ¬·¬´» ©¿- °«¬ ·² ³§ ²¿³»ò × ³»¿²ô ³§ ¼¿¼ ©¿- ©·¬¸ ³»ò × ×ùª» ²»ª»® ͱ óó ïç Ï Í± ¬¸¿¬ ©¿- §±«® º·®-¬ ¬·³»á îð ß Ç»-ò îï Ï Ó»³±®¿¾´»ô ®·¹¸¬á îî ß Ç»-ò îí Ï É¸»² §±« ¹±¬ ¬¸»®»ô ¿ ¾«¬´»® ±® -±³»±²» îì îë ¿²-©»®»¼ ¬¸» ¼±±®ô ·- ¬¸¿¬ ©¸¿¬ §±« -¿·¼á ß Ò±ô Ù¸·-´¿·²» ¿²-©»®»¼ ¬¸» ¼±±®ò Case 18-2868, Document 283, 08/09/2019, 2628241, Page87 of 883 ï ß Ç»-ò î Ï É¸± »´-» ©¿- ¿¬ ¸±³» ©¸»² §±« ¹±¬ ¸±³»á í ß Ó§ ³±³ô ³§ ¼¿¼ ¿²¼ ³§ ¾®±¬¸»®ò ì Ï É¸·½¸ ¾®±¬¸»®á ë ß Íµ§ò ê Ï ß²¼ ¿²§±²» »´-» ©¸± ©¿- ¬¸»®» ¿¬ ¬¸» ¬·³»á é ß × ¾»´·»ª» Ó·½¸¿»´ ³·¹¸¬ ¸¿ª» ¾»»² ´·ª·²¹ è ©·¬¸ ³» ¿¬ ¬¸¿¬ ¬·³»ò ç ïð ïï ͱ ¸» ³·¹¸¬ ¸¿ª» ¾»»² ¬¸»®»ò Ï Ü± §±« ®»½¿´´ ·º ¸» ©¿- ¬¸»®» ©¸»² §±« ¹±¬ ß × ¼±²ù¬ ®»¿´´§ ®»³»³¾»®ò ¸±³»á × ®»³»³¾»® ©¸¿¬ ïî × ¼·¼ ©¸»² × ¹±¬ ¸±³»ô ¬¸¿¬ × ¾¿-·½¿´´§ ³¿¼» ¿ ïí ¾»»´·²» º±® ¬¸» ¾¿¬¸®±±³ò ïì Ï Ô»¬ ³» ¿-µ §±« ¿ ¯«»-¬·±²ò Ó·½¸¿»´ ©¿- ïë ´·ª·²¹ ©·¬¸ §±« ¿¬ ¬¸¿¬ ¸±³»ô ¿¬ §±«® °¿®»²¬-ù ¸±³» ïê ¿¬ ¬¸» ¬·³»ô ·- §±«® ¾»-¬ ®»½±´´»½¬·±² ¬±¼¿§å ·- ¬¸¿¬ ïé ®·¹¸¬á ïè ß Ì¸¿¬ù- ³§ ¾»-¬ ®»½±´´»½¬·±²ô §»-ò ïç Ï É¸»² §±« -¿§ ´·ª·²¹ ©·¬¸ §±«ô ©»®» §±« î𠹫§- -¬¿§·²¹ ·² ¬¸» -¿³» ®±±³á îï ß Ç»-ò îî Ï É»®» §±« »²¹¿¹»¼ ¿¬ ¬¸¿¬ ¬·³» ¬± ¸·³á îí ß Ì¸¿¬ ©¿- ¿ ®»¿´´§ ©»·®¼ ®»´¿¬·±²-¸·°ò Ø» îì ©¿- ¿ º®·»²¼ ©¸± ´±±µ»¼ ¿º¬»® ³»ô ¿²¼ ¸» ¼·¼ °®±°±-» îë ¬± ³» ¿²¼ × ¼·¼ -¿§ §»-ò Þ«¬ ³§ ¸»¿®¬ ©¿- ²»ª»® ·² Case 18-2868, Document 283, 08/09/2019, 2628241, Page88 of 883 ï ·¬ò î í ì Ø» ©¿- -±³»¾±¼§ ¬¸¿¬ ¸»´°»¼ ³» ±ºº ¬¸» -¬®»»¬- -± × º»´¬ ½±³°»´´»¼ ¬± -¿§ §»- ¬± ¸·³ò Ï Ñµ¿§ò ͱ ©¸»² ¸» °®±°±-»¼ ¬± §±« ¿²¼ §±« ë -¿·¼ §»-ô ¼·¼ ¬¸¿¬ ¬¿µ» °´¿½» ¾»º±®» §±« -¬¿®¬»¼ ê ©±®µ·²¹ ¿¬ Ó¿®ó¿óÔ¿¹± ±® ¿º¬»® §±« -¬¿®¬»¼ ©±®µ·²¹ ¿¬ é Ó¿®ó¿óÔ¿¹±á è ß Þ»º±®»ò ç Ï ß²¼ -± ·º ¸» ©»®» ´·ª·²¹ ©·¬¸ §±«® °¿®»²¬- ï𠿬 ¬¸¿¬ ¬·³»ô §±« ©»®» ´·ª·²¹ ·² ¬¸» -¿³» ®±±³å ·- ïï ¬¸¿¬ ½±®®»½¬á ïî ß × ¾»´·»ª» -±ò ïí Ï ß²¼ §±«® °¿®»²¬- «²¼»®-¬±±¼ ¸·³ ¬± ¾» §±«® ïì ïë ïê ïé ïè ïç º·¿²½»á ß × ¼±²ù¬ ¬¸·²µ ¬¸»§ ¿¹®»»¼ ©·¬¸ ·¬ô ¾«¬ × ¬¸·²µ ¬¸»§ «²¼»®-¬±±¼ ·¬ ¿- ¬¸¿¬ò Ï × ³»¿² óó × ³»¿²ô §±« ½±³³«²·½¿¬»¼ ¬± ¬¸»³ ¬¸¿¬ ¸» ¸¿¼ °®±°±-»¼ ¿²¼ §±« ¸¿¼ ¿½½»°¬»¼á ß Ç»¿¸ô ·² ²±¬ -«½¸ ¿ °®»¬¬§ ©¿§ò î𠬸»§ ±¾ª·±«-´§ ©»®»²ù¬ ª»®§ ¸¿°°§ ¿¾±«¬ ·¬ò îï ©¿-²ù¬ ³§ ¬®«» ·²¬»²¬·±²- ¬± »ª»® ³¿®®§ ¸·³ò × ³»¿²ô ß²¼ ·¬ îî Ï Ñµ¿§ò îí ß Þ«¬ × ¼·¼ ·¬ ¬± ³¿µ» ¸·³ º»»´ ±µ¿§ò îì îë ¼·¼²ù¬ ©¿²¬ ¬± ¾» ³»¿²ò Ï É¸¿¬ ¼·¼ §±«® ³±³ -¿§ ¿¾±«¬ §±«® × Case 18-2868, Document 283, 08/09/2019, 2628241, Page89 of 883 ï î ß × ¾»´·»ª» Ö«¿² ß´»--· ©¿- °®»¬¬§ ³«½¸ ©·¬¸·² »¿® ¼·-¬¿²½»ò í Ï Ý±«´¼ §±« -»» ¸·³á ì ß Ç»-ò ë Ï Ñµ¿§ò ê ß Ô·µ» × -¿·¼ô ·² »¿® ¼·-¬¿²½»ô ©¸»² × ³»¿² é »¿® ¼·-¬¿²½» ´·µ» ¸»¿®·²¹ô ·² ¬¸» ¸»¿®·²¹ ª·½·²·¬§ò è ß²¼ ·¬ ©¿- ·² ¬¸» -¿³» ¬·³» ¬¸¿¬ -¸» ©¿- ¿-µ·²¹ ¸·³ ç ¬± ¼®±° ³» ±ºº ¿¬ ¸±³»ò ïð Ï Ñµ¿§ò ɸ»² §±« ©»®» ¼®·ª·²¹ ¸±³» ¬¸» ïï º·®-¬ ²·¹¸¬ ©·¬¸ Ö«¿² ß´»--·ô ¼·¼ §±« ¸¿ª» ¿²§ ïî ½±²ª»®-¿¬·±² ©·¬¸ ¸·³á ïí ïì ß Ò±ò × ¸¿¼ ¬±´¼ ¸·³ ³§ ¿¼¼®»--ò ׬ ©¿- ¿ ª»®§ ¯«·»¬ ®·¼»ò ïë Ï Ü·¼ §±« ®·¼» ·² ¬¸» º®±²¬ ±® ¬¸» ¾¿½µá ïê ß Ì¸» º®±²¬ò ïé Ï ×¬ ·- §±«® ½±²¬»²¬·±² ¬¸¿¬ô Ù¸·-´¿·²» ïè Ó¿¨©»´´ ¸¿¼ -»¨ ©·¬¸ «²¼»®¿¹» ¹·®´- ª·®¬«¿´´§ »ª»®§ ïç ¼¿§ ©¸»² × ©¿- ¿®±«²¼ ¸»®ô ½±®®»½¬á îð ß Ç»-ò îï Ï ß´´ ®·¹¸¬ò îî îí É·¬¸ ©¸±³ ¼·¼ Ù¸·-´¿·²» Ó¿¨©»´´ ¸¿ª» -»¨ ·² §±«® °®»-»²½»á ß É»´´ô ¬¸»®»ù- ¿ ´±¬ ±º ¹·®´- ¬¸¿¬ ©»®» îì ·²ª±´ª»¼ò îë ±¬¸»®ò É» ©»®»²ù¬ ±² ¿ º·®-¬ ²¿³» ¾¿-·- ©·¬¸ »¿½¸ × ©±«´¼²ù¬ ¾» ¿¾´» ¬± ¹·ª» §±« ´·-¬- ±º ²¿³»- Case 18-2868, Document 283, 08/09/2019, 2628241, Page90 of 883 ï î í ì ë ±º ¹·®´-ò Ï ×¬ ©¿- ½±²¬·²«±«-ò ׬ ©¿- ½±²¬·²«±«-ò Ò¿³» ±²» ¹·®´ ¬¸¿¬ Ù¸·-´¿·²» Ó¿¨©»´´ ¸¿¼ -»¨ ©·¬¸ ·² §±«® °®»-»²½»ò ß Û³³§ Ì¿§´±®ò × ³»¿²ô ¬¸¿¬ù- ¿ ²¿³» ¬¸¿¬ × µ²±© ©»´´ ¾»½¿«-» Û³³§ ©¿- ¿´©¿§- ¿®±«²¼ò ê ×ù³ ¬®§·²¹ ¬± ¬¸·²µ ±º ¸»® ²¿³»ô -±®®§ò é Í¿®¿¸ò è -¸»ù- ½¸¿²¹»¼ ·¬ ²±© ¬¸¿¬ -¸»ù- ³¿®®·»¼ò Ø»® ²¿³» «-»¼ ¬± ¾» Í¿®¿¸ Õ»´´»²ò ç × ¬¸·²µ ø°¸±²»¬·½÷ óó × ½¿²ù¬ ïð °®±²±«²½» ¸»® ´¿-¬ ²¿³» °®±°»®´§ô ¾«¬ ·¬ù- ¿®±«²¼ ïï ¬¸±-» ´·²»-ò ïî ̸»®» ©»®» ¿ ´±¬ ±º ±¬¸»® ¹·®´- ¬¸¿¬ × ïí ¸±²»-¬´§ ½¿²ù¬ ®»³»³¾»® ¬¸»·® ²¿³»-ò ïì ©·-¸ × ½±«´¼ ¸»´° ±«¬ ³±®» ¾»½¿«-» × ®»¿´´§ ©±«´¼ ïë ´·µ» ¬± °®±ª·¼» ³±®» ©·¬²»--»- º±® ¬¸·-ô ¾«¬ × ½¿²ù¬ ïê ®»³»³¾»® ¿ ´±¬ ±º ¹·®´-ù ²¿³»-ò ïé ïè Ï îï îî îë ͱ ¬¸±-» ¿®» ¬¸» ¬¸®»» ²¿³»- ±º º»³¿´»- ÓÎò ÛÜÉßÎÜÍæ Ѿ¶»½¬ ¬± ¬¸» º±®³ò Ó·-½¸¿®¿½¬»®·¦»- ¬»-¬·³±²§ò Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ óó ·- ¬¸¿¬ ©¸¿¬ × «²¼»®-¬¿²¼ §±«® ¿²-©»® ¬± ¾»á îí îì × ¬¸¿¬ §±« ±¾-»®ª»¼ Ù¸·-´¿·²» Ó¿¨©»´´ ¸¿ª» -»¨ ©·¬¸ óó ïç îð ×ù³ -±®®§ò ÓÎò ÛÜÉßÎÜÍæ Ѿ¶»½¬·±²ò Ó·-½¸¿®¿½¬»®·¦»- ¸»® ¬»-¬·³±²§ò ß Ì¸±-» ¿®» óó ¬¸±-» ¿®» -±³» ¬¸®»» ±º ¬¸» Case 18-2868, Document 283, 08/09/2019, 2628241, Page91 of 883 ï Ï Ó±®» ¬¸¿² îðá î ß × ©±«´¼ -¿§ ³±®» ¬¸¿² îðò í Ï Ó±®» ¬¸¿² ëðá ì ß × ¼±²ù¬ ¬¸·²µ ³±®» ¬¸¿² ëðô ¾«¬ óó ë Ï Ü·¼ óó ê ß × ¼±²ù¬ ¸¿ª» ¿² »¨¿½¬ ²«³¾»®ò × ³»¿²ô é ·º óó × ¬¸·²µ ·º §±« ´±±µ ¿¬ ¬¸» º´·¹¸¬ ´±¹-ô §±« è µ²±©ô ¬¸¿¬ ¸»´°-ô ¾«¬ ¬¸»² ¬¸»§ù®» ²±¬ º«´´§ ç ½±³°´»¬»ò É» ±²´§ ¸¿ª» º´·¹¸¬ ´±¹- ¬± ±²» °´¿²» ¿²¼ ï𠬸»² ¬¸»®»ù- ¿ ¬·³» × ©¿- º´±©² ½±³³»®½·¿´´§ ·²¬± ¬¸» ïï ·-´¿²¼ò ïî Ï Ë³ó¸«³ò ïí ß Í± ·¬ù- ®»¿´´§ ¸¿®¼ º±® ³» ¬± ¹¿«¹» ¿ ïì ïë ïê ïé ïè ïç ²«³¾»®ò Ï Ñµ¿§ò ܱ §±« ¸¿ª» ¿²§ °¸±¬±¹®¿°¸- ±º §±«®-»´º ±² ¬¸» ·-´¿²¼á ß × µ²±© × «-»¼ ¬±ô ¾«¬ ¬¸»§ ©±«´¼ ¾» ´»º¬ ·² ¬¸¿¬ ¿°¿®¬³»²¬ò Ï É¸¿¬ ±¬¸»® ´±½¿¬·±²- ¼·¼ §±« °¿®¬·½·°¿¬» îð ·² -»¨«¿´ ½±²¬¿½¬ ©·¬¸ Ù¸·-´¿·²» Ó¿¨©»´´ô ±¬¸»® ¬¸¿² îï ¬¸» ·-´¿²¼á îî ß Ûª»®§©¸»®»ò îí Ï É¸»®» ·² Ò»© DZ®µá îì ß Ì¸» ³¿²-·±²ô Ö»ºº®»§ù- ³¿²-·±²ò îë Ï Ñµ¿§ò Ò»© DZ®µô п´³ Þ»¿½¸ò ß²§©¸»®» »´-» ·² Ò»© DZ®µá Case 18-2868, Document 283, 08/09/2019, 2628241, Page92 of 883 ï ¬¸·²µ × ³»¬ Ю·²½» ß²¼®»© ·² îððïò î ¿²¼ ͬ»°¸»² Õ¿«º³¿²² ©»®»ô ´·µ» × -¿·¼ô ¬¸» º·®-¬ í °»±°´» × ©¿- -»²¬ ±«¬ ¬± ¿º¬»® ³§ ¬®¿·²·²¹ò ì ¼±²ù¬ µ²±©ò ë ·º × ¼±²ù¬ µ²±© ·¬ò ß²¼ Ù´»²² Ü«¾·² ͱ × ×ù³ ²±¬ ¹±·²¹ ¬± ¹·ª» §±« ¿² »¨¿½¬ ¬·³» ê Ï × ¿-µ»¼ §±« ¬¸» ®»´¿¬·ª» ±®¼»®ò é ß ß²¼ ×ù³ ¬®§·²¹ ¬± ¹·ª» §±« ·¬ò è Ï ß²¼ ©¸»®» ¼±»- ß´¿² Ü»®-¸±©·¬¦ º·¬ ·²¬± ç ïð ïï ¬¸¿¬ ¹®±«° ±º °»±°´»á ß Í¿³»ò × ½¿²ù¬ ¬»´´ §±« °·»½» ¾§ °·»½» ¾§ °·»½» ©¸± óó × µ²±© Ù´»²² Ü«¾·² ©¿- º·®-¬ò ïî Ï Ñµ¿§ò ïí ß ß²¼ × µ²±© ͬ»°¸»² Õ¿«º³¿²² ©¿- ±²» ±º ¬¸» ïì º·®-¬ × ©¿- -»²¬ ¬±ò ïë ¾»¬©»»² ¬¸»®»ò ïê ͬ»°¸»²ò ïé ©¿- ·² Ò»© DZ®µô -± × ©¿-²ù¬ ¿½¬«¿´´§ -»²¬ ¬± ¸·³ò ïè ׬ ¿½¬«¿´´§ ¸¿°°»²»¼ ¿¬ ±²» ±º Ö»ºº®»§ù- ®»-·¼»²½»-ò ïç îð îï îî ß´¿² Ü»®-¸±©·¬¦ ½±«´¼ ¸¿ª» ¾»»² Þ»¬©»»²ô -±®®§ô ¾»¬©»»² Ù´»²² ¿²¼ ̸» º·®-¬ ¬·³» × ©¿- ©·¬¸ ß´¿² Ü»®-¸±©·¬¦ øÓ-ò ӽݿ©´»§ ´»º¬ ¬¸» ¼»°±-·¬·±²ò÷ ß Í± ·¬ù- ª»®§ ¸¿®¼ º±® ³» ¬± ½¸®±²±´±¹·½¿´´§ ¹·ª» §±« »¿½¸ °»®-±² ·²¼·ª·¼«¿´´§ò Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ѵ¿§ò Ò¿³» ¬¸» ±¬¸»® îí °±´·¬·½¿´´§ ½±²²»½¬»¼ ¿²¼ º·²¿²½·¿´´§ °±©»®º«´ °»±°´» îì ¬¸¿¬ Ù¸·-´¿·²» Ó¿¨©»´´ ¬±´¼ §±« ¬± ¹± ¸¿ª» -»¨ ©·¬¸á îë ß ß¹¿·²ô ×ù³ ¹±·²¹ ¬± ¬»´´ §±« þ¬¸»§þ Case 18-2868, Document 283, 08/09/2019, 2628241, Page93 of 883 ï ¾»½¿«-» ¬¸¿¬ù- ¸±© ·¬ ©»²¬ò î ¬± Ù»±®¹» Ó·¬½¸»´´ô Ö»¿² Ô«½ Þ®«²»´ô Þ·´´ η½¸¿®¼-±²ô í ¿²±¬¸»® °®·²½» ¬¸¿¬ × ¼±²ù¬ µ²±© ¸·- ²¿³»ò ì ¬¸¿¬ ±©²- ¿ ¸±¬»´ô ¿ ®»¿´´§ ´¿®¹» ¸±¬»´ ½¸¿·²ô × ë ½¿²ù¬ ®»³»³¾»® ©¸·½¸ ¸±¬»´ ·¬ ©¿-ò ê ̸»§ ·²-¬®«½¬»¼ ³» ¬± ¹± ß ¹«§ Ó¿®ª·² Ó·²-µ§ò ̸»®» ©¿-ô §±« µ²±©ô ¿²±¬¸»® º±®»·¹² é °®»-·¼»²¬ô × ½¿²ù¬ ®»³»³¾»® ¸·- ²¿³»ò è Í°¿²·-¸ò ç ¶«-¬ óó ·¬ù- ¸¿®¼ º±® ³» ¬± ®»³»³¾»® ¿´´ ±º ¬¸»³ò Ø» ©¿- ̸»®»ù- ¿ ©¸±´» ¾«²½¸ ±º ¬¸»³ ¬¸¿¬ × ïð DZ« µ²±©ô × ©¿- ¬±´¼ ¬± ¼± -±³»¬¸·²¹ ¾§ ¬¸»-» °»±°´» ïï ½±²-¬¿²¬´§ô ¬±´¼ ¬± óó ³§ ©¸±´» ´·º» ®»ª±´ª»¼ ¿®±«²¼ ïî ¶«-¬ °´»¿-·²¹ ¬¸»-» ³»² ¿²¼ µ»»°·²¹ Ù¸·-´¿·²» ¿²¼ ïí Ö»ºº®»§ ¸¿°°§ò ïì ¿®±«²¼ -»¨ò ïë ïê ̸»·® ©¸±´» »²¬·®» ´·ª»- ®»ª±´ª»¼ ̸»§ ½¿´´ ³¿--¿¹»- -»¨ò ³±¼»´·²¹ -»¨ò ïé Ï Ì¸»§ ½¿´´ ̸»§ ½¿´´ óó × ¿-µ»¼ §±« ¬¸» ²¿³»- º±® °»±°´»ò ß®» §±« ïè ¹±·²¹ ¬± ¬»´´ ³» ¿²§ ±¬¸»® ²¿³»- ±® ·- ¬¸¿¬ ¿´´ ±º ïç ¬¸»³á îð ß ×ù³ ¬®§·²¹ ¬± ¬¸·²µò ̸¿¬ù- ¬¸» ¿²-©»® îï ×ù³ ¬®§·²¹ ¬± ¹·ª» ¬± §±«ò îî ¶«-¬ µ»»° ²¿³·²¹ ¿²¼ ²¿³·²¹ ¿²¼ ²¿³·²¹ò ׬ù- ¬¸¿¬ ·¬ù- -± ¸¿®¼ ¬± îí Ï ß´´ ®·¹¸¬ò îì ß ß ´±¬ ±º ¬·³»- × ©±«´¼ ¾» ·²¬®±¼«½»¼ ¬± îë ¬¸»³ò × ¼·¼²ù¬ µ²±© óó Case 18-2868, Document 283, 08/09/2019, 2628241, Page94 of 883 ï ³¿²§ ¬·³»- §±« ©¿²¬ ³» ¬± µ»»° ¿²-©»®·²¹ ¬¸·- î ¯«»-¬·±²ò í -»²¬ ³» ¬± ¬¸»-» °»±°´»ò ì ë ê Þ±¬¸ ¬±´¼ ³» ¬± ¼± ¬¸·-ô ±µ¿§á ̸»§ ¾±¬¸ ر© ³¿²§ ¬·³»- ¼± §±« ©¿²¬ ³» ¬± ¿²-©»® ¬¸·-á Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ × ¬¸·²µ §±«ù®» é ¿²-©»®·²¹ ¿ ¼·ºº»®»²¬ ¯«»-¬·±² -± ¬¸¿¬ù- ©¸§ ×ù³ è ¹±·²¹ ¬± ¿-µ §±« ¿¹¿·²ò ç ¿¾±«¬ ¿ ¬·³» ©¸»² Ö»ºº®»§ ¿²¼ Ù¸·-´¿·²» ¬±¹»¬¸»® ¬±´¼ × ¿³ ²±¬ ¿-µ·²¹ §±« ¿²§¬¸·²¹ ï𠧱« ¬± ¹± ¼± -±³»¬¸·²¹ò ïï -·²¹´» ¬·³» ¼«®·²¹ ©¸·½¸ Ù¸·-´¿·²» Ó¿¨©»´´ ¿½¬·²¹ ïî ¿´±²» ¼·®»½¬»¼ §±« ¬± ¹± ¸¿ª» -»¨ ©·¬¸ ¿²±¬¸»® ïí °»®-±²á ïì ïë ïê ×ù³ ¿-µ·²¹ §±« ¬± ²¿³» ¿ ÓÎò ÛÜÉßÎÜÍæ ¿²-©»®»¼ò ß Ø¿®¿--·²¹ò Ѿ¶»½¬·±²ò ß-µ»¼ ¿²¼ ß®¹«³»²¬¿¬·ª»ò ×ùª» ¹·ª»² §±« ¬¸» ²¿³»- ±º ¬¸» °»±°´» ïé ¬¸¿¬ Ù¸·-´¿·²» ·²-¬®«½¬»¼ ³» ¬± ¹± ¸¿ª» -»¨«¿´ ïè ®»´¿¬·±²- ©·¬¸ò ïç ¬¸¿¬ Ö»ºº®»§ ¿´-± ¬±´¼ ³»ò îð × ¿³ ²±¬ ¼·-½´«¼·²¹ ø-·½÷ ¬¸» º¿½¬ Ù¸·-´¿·²» ¬±´¼ ³» º®±³ ¸»® ³±«¬¸ ¬± ¼± îï ¬¸»-» ¬¸·²¹-ò îî ¬¸»-» ¬¸·²¹- ©·¬¸ ¬¸»-» °»±°´»ò îí ³» ¬± ¼± ¬¸» ¬¸·²¹- ¬¸¿¬ × ¼·¼ ©·¬¸ Ö»ºº®»§ Û°-¬»·² îì ±² ¬¸» ª»®§ º·®-¬ ³»»¬·²¹ ¬¸¿¬ × ¸¿¼ ©·¬¸ ¸·³ò îë ¾®±«¹¸¬ ³» ¬¸»®» «²¼»® ¬¸» °®»½´«-·±² ø-·½÷ ¬¸¿¬ × Ö»ºº®»§ ¬±´¼ ³» º®±³ ¸·- ³±«¬¸ ¬± ¼± Ù¸·-´¿·²» ·²-¬®«½¬»¼ ͸» Case 18-2868, Document 283, 08/09/2019, 2628241, Page95 of 883 ï ©¿- ¹±·²¹ ¬± ¾» ¬®¿·²»¼ ¿- ¿ ³¿--»«-» ¿²¼ ¬¸¿¬ -¸» î ·²-¬®«½¬»¼ ³» ¬± ¬¿µ» ±ºº ³§ ½´±¬¸»- ¿²¼ ¬± ¹·ª» ±®¿´ í -»¨ ¬± Ö»ºº®»§ Û°-¬»·²ò ì ë Ï Û¨½«-» ³»ò ×ùª» ¿-µ»¼ §±« º±® ¬¸» ²¿³»-ò ê é øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ß ×ùª» ¶«-¬ ¹·ª»² §±« ¿ ²¿³»ò Ö»ºº®»§ Û°-¬»·² ·- ¿ ¾·¹ ²¿³»ò è Ï ß´´ ®·¹¸¬ò ç ß Í¸» ·²-¬®«½¬»¼ ³» ±² ¬¸¿¬ ±²»ò ïð Ï Í± §±«ù®» -¿§·²¹ óó ïï ÓÎò ÛÜÉßÎÜÍæ ̸» ©·¬²»-- ·- º·²·-¸·²¹ ¸»® ïî ¿²-©»® ®·¹¸¬ ²±©ò ïí ±²» ±º ¬¸» °»±°´» Ù¸·-´¿·²» ¬±´¼ ¸»® ¬± ¸¿ª» -»¨ ïì ©·¬¸ò ïë Ï Í¸»ù- ·² ¬¸» °®±½»-- ±º »¨°´¿·²·²¹ øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ͱ §±«ù®» -¿§·²¹ ïê Ù¸·-´¿·²» Ó¿¨©»´´ ¼·®»½¬»¼ §±« ¬± ¸¿ª» -»¨ ©·¬¸ ïé Ö»ºº®»§ Û°-¬»·²á ïè ß Ý±®®»½¬ò ïç Ï Ù¸·-´¿·²» Ó¿¨©»´´ ¼·®»½¬»¼ §±« ¬± ¸¿ª» -»¨ îð ©·¬¸ Ù´»²² Ü«¾·²á îï ß Ý±®®»½¬ò îî Ï É¸¿¬ ©±®¼- ¼·¼ Ù¸·-´¿·²» Ó¿¨©»´´ ¬»´´ §±« îí îì îë ¬± ¹± ¸¿ª» -»¨ ©·¬¸ Ù´»²² Ü«¾·²á ß ×¬ ©¿- ¬¸» -¿³» ¿´´ ¬¸» ¬·³»ô ¿´´ ®·¹¸¬á ̸»§ ©¿²¬ ³» ¬± ¹± °®±ª·¼» ¬¸»-» ³»² ©·¬¸ ¿ ³¿--¿¹»ò Case 18-2868, Document 283, 08/09/2019, 2628241, Page96 of 883 ï ß É¸»² ·¬ ¸¿°°»²»¼á î Ï É¸»² Ù¸·-´¿·²» Ó¿¨©»´´ «-»¼ ¬¸» ©±®¼-ô Ù± í ¹·ª» ¿ ³¿--¿¹» ¬± Þ·´´ η½¸¿®¼-±²ô ©¸»®» ©»®» §±«á ì ë ÓÎò ÛÜÉßÎÜÍæ Ѿ¶»½¬ ¬± ¬¸» º±®³ò Ó·-½¸¿®¿½¬»®·¦»- ¸»® ¬»-¬·³±²§ò ê ß × ½¿²ù¬ ¬»´´ §±« ©¸»®» ©» ©»®»ò é ©¸»®» × ©¿- -»²¬ ¬±ò è -¸» ¬±´¼ ³» ¬± ¼± ¬¸¿¬ò ç × ¼±²ù¬ µ²±© ©¸»®» ©» ©»®» ©¸»² Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ïï ß Ò»© Ó»¨·½±ò ïî Ï óó ¾§ Ù¸·-´¿·²» Ó¿¨©»´´á ïð ɸ»®» ©»®» §±« -»²¬ ¬± óó ïí ïì × µ²±© ÓÎò ÛÜÉßÎÜÍæ Ѿ¶»½¬ ¬± ¬¸» º±®³ò Ó·-½¸¿®¿½¬»®·¦»- ¸»® ¬»-¬·³±²§ ¿¹¿·²ò ïë ß ß®» §±« -³·´·²¹ ¿¬ ³» ¾»½¿«-» óó ïê Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ïé ïè ïç Ò±ô ×ù³ ¿-µ·²¹ §±« ¬± ¿²-©»® ¬¸» ¯«»-¬·±²ò ß × ¸¿ª» ¿²-©»®»¼ ¬¸» ¯«»-¬·±²ò ¬± Ò»© Ó»¨·½±ò îð Ï Ñµ¿§ò îï ß × ¿´®»¿¼§ ¿²-©»®»¼ ¬¸¿¬ò îî × ©¿- -»²¬ ɸ»®» ©»®» §±« -»²¬ º®±³á × ¼±²ù¬ µ²±© ©¸»®» × ©¿- -»²¬ º®±³ò îí Ï Ñµ¿§ò îì ß × ©¿- º´§·²¹ »ª»®§©¸»®» ©·¬¸ ¬¸»-» °»±°´»ò îë Ï É¸»®» ©»®» §±« -»²¬ ¾§ Ù¸·-´¿·²» Ó¿¨©»´´ Case 18-2868, Document 283, 08/09/2019, 2628241, Page97 of 883 ï î í ß Ò±ô -¸» ©¿- ²±¬ ·² ¬¸» ®±±³ò ͸» ©¿- ·² ¿²±¬¸»® ½¿¾¿²¿ò Ï ß²¼ ±¬¸»® ¬¸¿² ¬»´´·²¹ §±« ¬± ¹± ¹·ª» ¬¸» ì ±©²»® ±º ¬¸·- ´¿®¹» ¸±¬»´ ½¸¿·² ¿ ³¿--¿¹»ô ¼± §±« ë ®»³»³¾»® ¿²§ ±¬¸»® ©±®¼- -¸» «-»¼ ¬± §±« ¬± ¼·®»½¬ ê §±« ·² ©¸¿¬ §±« -¸±«´¼ ¼±á é ß Ò±¬ ¿¬ ¬¸» ¬·³»ô ²±ò è Ï É¸»®» ¼·¼ óó ©¸»®» ©»®» §±« ¿²¼ ©¸»®» ©¿- ç ïð Ó-ò Ó¿¨©»´´ ©¸»² -¸» ¼·®»½¬»¼ §±« ¬± ¹± ¸¿ª» -»¨ ©·¬¸ Ó¿®ª·² Ó·²-µ§á ïï ÓÎò ÛÜÉßÎÜÍæ Ѿ¶»½¬ ¬± ¬¸» º±®³ò ïî ß × ¼±²ù¬ µ²±©ò ïí Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ïì ïë ɸ»®» ¼·¼ §±« ¹± ¬± ¸¿ª» -»¨ ©·¬¸ Ó¿®ª·² Ó·²-µ§á ß × ¾»´·»ª» ·¬ ©¿- ¬¸» ËòÍò Ê·®¹·² ×-´¿²¼-ô ïê Ö»ººù- óó -±®®§ô Ö»ºº®»§ Û°-¬»·²ù- ·-´¿²¼ ·² ¬¸» ËòÍò ïé Ê·®¹·² ×-´¿²¼-ò ïè Ï ß²¼ ©¸»² ©¿- ¬¸¿¬á ïç ß × ¼±²ù¬ µ²±©ò îð Ï Ü± §±« ¸¿ª» ¿²§ ¬·³» ±º §»¿®á îï ß Ò±ò îî Ï Ü± §±« µ²±© ¸±© ±´¼ §±« ©»®»á îí ß Ò±ò îì Ï Ñ¬¸»® ¬¸¿² Ù´»²² Ü«¾·²ô ͬ»°¸»² Õ¿«º³¿²²ô îë Ю·²½» ß²¼®»©ô Ö»¿² Ô«½ Þ®«²»´ô Þ·´´ η½¸¿®¼-±²ô Case 18-2868, Document 283, 08/09/2019, 2628241, Page98 of 883 ï ¿²±¬¸»® °®·²½»ô ¬¸» ´¿®¹» ¸±¬»´ ½¸¿·² ±©²»® ¿²¼ î Ó¿®ª·² Ó·²-µ§ô ·- ¬¸»®» ¿²§±²» »´-» ¬¸¿¬ Ù¸·-´¿·²» í Ó¿¨©»´´ ¼·®»½¬»¼ §±« ¬± ¹± ¸¿ª» -»¨ ©·¬¸á ì ë ß × ¿³ ¼»º·²·¬»´§ -«®» ¬¸»®» ·-ò ®»³»³¾»® »ª»®§¾±¼§ù- ²¿³»á ê Ï é ¿¾±«¬ ¬¸»³á è ß ç ²±©ò ѵ¿§ò Ò±ò Ý¿² §±« ®»³»³¾»® ¿²§¬¸·²¹ »´-» Ô±±µô ×ùª» ¹·ª»² §±« ©¸¿¬ × µ²±© ®·¹¸¬ ×ù³ -±®®§ò ̸·- ·- ª»®§ ¸¿®¼ º±® ³» ¿²¼ ª»®§ ï𠺮«-¬®¿¬·²¹ ¬± ¸¿ª» ¬± ¹± ±ª»® ¬¸·-ò ïï ¼±²ù¬ ®»½¿´´ ¿´´ ±º ¬¸» °»±°´»ò ïî ¿³±«²¬ ±º °»±°´» ¬¸¿¬ × ©¿- -»²¬ ¬±ò ïí ïì Ï Þ«¬ ½¿² × × ¼±²ù¬ óó × Ì¸»®» ©¿- ¿ ´¿®¹» ܱ §±« ¸¿ª» ¿²§ ²±¬»- ±º ¿´´ ¬¸»-» °»±°´» ¬¸¿¬ §±« ©»®» -»²¬ ¬±á ïë ß Ò±ô × ¼±²ù¬ò ïê Ï É¸»®» ¿®» §±«® ²±¬»-á ïé ß × ¾«®²»¼ ¬¸»³ò ïè Ï É¸»² ¼·¼ §±« ¾«®² ¬¸»³á ïç ß ×² ¿ ¾±²º·®» ©¸»² × ´·ª»¼ ¿¬ Ì·¬«-ª·´´» îð îï ¾»½¿«-» × ©¿- -·½µ ±º ¹±·²¹ ¬¸®±«¹¸ ¬¸·- -¸·¬ò Ï Ü·¼ §±« ¸¿ª» ´¿©§»®- ©¸± ©»®» ®»°®»-»²¬·²¹ îî §±« ¿¬ ¬¸» ¬·³» §±« ¾«·´¬ ¿ ¾±²º·®» ¿²¼ ¾«®²»¼ ¬¸»-» îí ²±¬»-á îì ß îë ×ùª» ¾»»² ®»°®»-»²¬»¼ º±® ¿ ´±²¹ ¬·³»ô ¾«¬ ·¬ ©¿- ²±¬ «²¼»® ¬¸» ·²-¬®«½¬·±² ±º ³§ ´¿©§»®- ¬± ¼± Case 18-2868, Document 283, 08/09/2019, 2628241, Page99 of 883 ï ¬¸·-ò î ¿²¼ ©» ¾»´·»ª»¼ ¬¸¿¬ ¬¸»-» ³»³±®·»- ©»®» ©±®¬¸ í ¾«®²·²¹ò ì Ó§ ¸«-¾¿²¼ ¿²¼ × ©»®» °®»¬¬§ -°·®·¬«¿´ °»±°´» Ï Í± §±« ¾«®²»¼ ²±¬»- ±º ¬¸» ³»² ©·¬¸ ©¸±³ ë §±« ¸¿¼ -»¨ ©¸·´» §±« ©»®» ®»°®»-»²¬»¼ ¾§ ½±«²-»´ ·² ê ´·¬·¹¿¬·±²ô ½±®®»½¬á é ÓÎò ÛÜÉßÎÜÍæ è ç ïð ß ¼±½«³»²¬ò ïî ̸·- ©¿-²ù¬ ¿²§¬¸·²¹ ¬¸¿¬ ©¿- ¿ °«¾´·½ ̸·- ©¿- ³§ ±©² °®·ª¿¬» ¶±«®²¿´ô ¿²¼ × ¼·¼²ù¬ ©¿²¬ ·¬ ¿²§³±®»ò ïï Ï Ñ¾¶»½¬ ¬± ¬¸» º±®³ò ͱ ©» ¾«®²»¼ ·¬ò øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ɸ»² ¼·¼ §±« ©®·¬» ¬¸¿¬ ¶±«®²¿´á ïí ß Ö«-¬ ±ª»® ¬·³»ò × -¬¿®¬»¼ ©®·¬·²¹ ·¬ ïì °®±¾¿¾´§ ·²ô × ¼±²ù¬ µ²±©ô × ½¿²ù¬ -°»½«´¿¬»ô îðïîô ïë îðïïò ïê ïé Ï Í± §±« ¼·¼ ²±¬ ©®·¬» ¬¸·- ¶±«®²¿´ ¿¬ ¬¸» ¬·³» ·¬ ¸¿°°»²»¼á ïè ß Ò±ò ïç Ï Ç±« -¬¿®¬»¼ ©®·¬·²¹ ¬¸·- ¶±«®²¿´ îð ¿°°®±¨·³¿¬»´§ ¿ ¼»½¿¼» ¿º¬»® §±« ½´¿·³ §±« º·²·-¸»¼ îï ¾»·²¹ -»¨«¿´´§ ¬®¿ºº·½µ»¼ô ½±®®»½¬á îî ß Ç»-ò îí Ï ß²¼ §±« -¬¿®¬»¼ ©®·¬·²¹ ¿ ¶±«®²¿´ ¿º¬»® îì îë §±« ¸¿¼ ¿ ´¿©§»®ô ½±®®»½¬á ß Ý±®®»½¬ò Case 18-2868, Document 283, 08/09/2019, 2628241, Page100 of 883 ï î ÌØÛ Ê×ÜÛÑÙÎßÐØÛÎæ É»ù®» ¾¿½µ ±² ¬¸» ®»½±®¼ ¿¬ îæëëò í Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ܱ §±« ¸¿ª» ¿²§ ì °¸±¬±¹®¿°¸- ±º §±«®-»´º »·¬¸»® ²«¼» ±® ·² ¿ -»¨«¿´´§ ë ½±³°®±³·-·²¹ °±-·¬·±² ¬¸¿¬ §±« ½´¿·³ ©»®» ¬¿µ»² ¾§ ê Ù¸·-´¿·²» Ó¿¨©»´´á é ß × ¼± ²±¬ ¸¿ª» ¿²§ ±º ¬¸±-» ·² ³§ »ª·¼»²½»ò è Þ«¬ ·º §±« ¿-µ Ù¸·-´¿·²» Ó¿¨©»´´ô -¸» ©±«´¼ ¸¿ª» ç °´»²¬§ò ïð ïï Ï Ü± §±« ¸¿ª» ¿²§ ·² §±«® -¬±®¿¹» ¾±¨»- ·² ͧ¼²»§á ïî ß Ò±ò ïí Ï Ü± §±« µ²±© ©¸»¬¸»® §±«® ¿¬¬±®²»§- ¸¿ª» ïì ¿²§ -«½¸ °¸±¬±¹®¿°¸- ¬¸¿¬ §±« ½´¿·³ ©»®» ¬¿µ»² ¾§ ïë Ù¸·-´¿·²» Ó¿¨©»´´á ïê ß Ò±ò ïé Ï Ç±« ¼±²ù¬ µ²±© ±® ¬¸»§ ¼±²ù¬ ¸¿ª» ¬¸»³á ïè ß × ¼±²ù¬ µ²±©ò ß²¼ × ¼±²ù¬ ¬¸·²µ ¬¸»§ ¸¿ª» ïç ¬¸»³ò îð DZ« -¸±«´¼ ¿-µ §±«® ½´·»²¬ò îï ¬¸»³ò îî îí îì îë ׺ ¬¸»§ ¸¿¼ ¬¸»³ô ¬¸»§ ©±«´¼ ¸¿ª» ¬±´¼ ³»ò ͸»ù- ¹±¬ °´»²¬§ ±º Ï É¸¿¬ ¬§°» ±º ½¿³»®¿ ¼·¼ Ù¸·-´¿·²» Ó¿¨©»´´ ß ×¬ ©¿- ¿ ¾´¿½µ ½¿³»®¿ò «-»á ß²¼ ·¬ ¸¿¼ ¿ô × ¼±²ù¬ µ²±© ¬¸» ¬§°»- ¿²¼ ²¿³»- ±º ¬¸»³ô ¾«¬ ¬¸» ´»²- Case 18-2868, Document 283, 08/09/2019, 2628241, Page101 of 883 ï ¬¸¿¬ ¹±»- ±«¬ò î Ï É¿- ·¬ ¼·¹·¬¿´ ±® -·²¹´» ®»º´»¨á í ß ß¹¿·²ô × ¼±²ù¬ µ²±© ¬§°»- ±º ½¿³»®¿-ò × ì ³»¿²ô × «-» ³§ °¸±²» º±® «-·²¹ ¿ ½¿³»®¿ò ë ¾´¿½µ ½¿³»®¿ ¿²¼ ·¬ ¸¿¼ ¿ ´»²- ¬¸¿¬ §±« ½±«´¼ °«¬ ±«¬ ê º«®¬¸»® ±® ¾®·²¹ ¾¿½µò é ͱ ·¬ù- ¿ Ï Ü·¼ §±« ¿-µ ¸»® ¬± ¬¿µ» ¿²§ °¸±¬±¹®¿°¸- ±º ç ß Ò±ò ïð Ï É¿- ·¬ ¿ º·´³ ±® ¿ ¼·¹·¬¿´ ½¿³»®¿á ïï ß × ²»ª»® -¿© ¸±© -¸» °®·²¬»¼ ¬¸»³ ±«¬ò ïî Ï É¸¿¬ù- ¬¸» º·®-¬ ¬·³» §±« ¬±´¼ ¿²§¾±¼§ è ïí §±«á ¬¸¿¬ §±« ¸¿¼ ¾»»² -»¨«¿´´§ ¬®¿ºº·½µ»¼á ïì ïë ͸» ¿-µ»¼ ¬± ¬¿µ» °¸±¬±¹®¿°¸- ±º ³»ò ÓÎò ÛÜÉßÎÜÍæ ß Ú±®³ò ̱²§ Ú·¹«»®±¿ô ³§ »¨ó¾±§º®·»²¼ô µ²»© -±³» ïê ±º ¬¸» -¬«ºº ¬¸¿¬ ©¿- ¸¿°°»²·²¹ô ¬¸±«¹¸ × ¼·¼ ²±¬ ¹± ïé ·² ¹®»¿¬ ¼»¬¿·´ ¬± ¸·³ô ¾»·²¹ ¬¸¿¬ ¸»ù- ³§ ¾±§º®·»²¼ò ïè ß²¼ ¬¸»² ¬¸» º·®-¬ °»®-±² × ®»¿´´§ ±°»²»¼ «° ¬± ¿¾±«¬ ïç »ª»®§¬¸·²¹ ©¿- ³§ ¸«-¾¿²¼ò îð Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ Ü·¼ §±« ¬»´´ ̱²§ îï Ú·¹«»®±¿ ¬¸¿¬ §±« ©»®» º±®½»¼ ¬± ¸¿ª» -»¨ ©·¬¸ îî Ö»ºº®»§ Û°-¬»·²á îí ß Ç»-ò îì Ï Ü·¼ §±« ¬»´´ ̱²§ Ú·¹«»®±¿ §±« ©»®» º±®½»¼ îë ¬± ¸¿ª» -»¨ ©·¬¸ Ù¸·-´¿·²» Ó¿¨©»´´á Case 18-2868, Document 283, 08/09/2019, 2628241, Page102 of 883 ï ¿²§ ·²¬»®¿½¬·±²- ©·¬¸ ´¿© »²º±®½»³»²¬á î ß Ç»-ò í Ï É¸»²á ì ß É¸»² × ¬®·»¼ ¬± ¾®»¿µ ¿©¿§ º®±³ Ö»ºº®»§ ë ¿²¼ Ù¸·-´¿·²»ô × -¬¿®¬»¼ ³¿µ·²¹ ³§-»´º «²¿ª¿·´¿¾´»ò ê ß²¼ × ¹±¬ ¿ ¶±¾ ¿¬ α¿¼ ر«-» Ù®·´´ò é ¬± ½±³» °·½µ ³» «° ·² ¬¸» ¿º¬»®²±±²-ô ¿¬ ²·¹¸¬¬·³»ô è ¿²¼ ¸»ù¼ -·¬ ¿¬ ¬¸» ¾¿®ò ç ¬¸¿¬ù- ¹±¬ ¬·°- ·² ·¬ò ïð ß²¼ ̱²§ «-»¼ ß²¼ ¬¸»®»ù- ¬¸·- ¾·¹ ½«° × ©¿- ·² ¬¸» ¾¿½µ ®±±³ò ß²¼ × ¸¿¼ ¬± óó ïï º·®-¬ §±« ¸¿ª» ¬± -·¹² ±«¬ ¿²¼ §±« ¸¿ª» ¬± ¬¿µ» ±ºº ïî §±«® ¿°®±²-ô °«¬ §±«® ¿°®±²- ¿©¿§ò ïí ©¸±´» ¾«²½¸ ±º ½´»¿²·²¹ «° -¬«ºº §±« ¸¿ª» ¬± ¼±ò ïì ß²¼ ¬¸»®»ù- ¿ ײ ¬¸¿¬ ¬·³» °»®·±¼ô ̱²§ ¹®¿¾¾»¼ ³±²»§ ïë º®±³ ¿ ½«° ¬¸¿¬ ¸¿¼ ³±²»§ ·² ·¬ò ïê ¾¿®¬»²¼»®- º±® ¬¸»·® ¬·°-ò ïé ²»¨¬ ¼¿§ò ïè ©¸·½¸ × ¸¿¼²ù¬ò ïç ³±²»§ ¿º¬»® × ½±²º®±²¬»¼ ̱²§ ¿¾±«¬ ·¬ò îð ³±²»§ ¾¿½µ ¬± ¸·³ ¿²¼ ¸» -¿·¼ô ×ù³ -±®®§ô ¾«¬ ·¬ù- îï ¶«-¬ ´¿© ¬¸¿¬ × ¸¿ª» ¬± ½¿´´ ¬¸» °±´·½»ò îî ½¿´´»¼ ¬¸» °±´·½»ò îí ̸¿¬ ©¿- º±® ¬¸» Ó§ ¾±-- ½¿´´»¼ ³» ¬¸» Ø» ¬±´¼ ³» ¬¸¿¬ × ¸¿¼ -¬±´»² ¬¸» ³±²»§ô ß²¼ × ½¿³» ¾¿½µ ¿²¼ × ®»¬«®²»¼ ¬¸» Ù¿ª» ¬¸» ͱ ¸» ß²¼ µ²±©·²¹ ¬¸¿¬ Ö»ºº®»§ ¸¿- ¹±¬ ¬¸» п´³ îì Þ»¿½¸ б´·½» Ü»°¿®¬³»²¬ ·² ¸·- °±½µ»¬ô × ©»²¬ ¬± îë Ö»ºº®»§ Û°-¬»·² ¿²¼ × ¬±´¼ ¸·³ ©¸¿¬ ¸¿¼ ¸¿°°»²»¼ò Case 18-2868, Document 283, 08/09/2019, 2628241, Page103 of 883 ï ß²¼ Ö»ºº®»§ -¿·¼ô ܱ²ù¬ ©±®®§ ¿¾±«¬ ·¬ò î ½¿®» ±º ·¬ º±® §±«ò í ì Ï Ñµ¿§ò ×ù³ -±®®§ò Ô»¬ ³» ¬¿µ» ɸ»² ¼·¼ §±« ¸¿ª» ·²¬»®¿½¬·±² ©·¬¸ ´¿© »²º±®½»³»²¬ô ¬¸»²á ë ß É¸¿¬ §»¿®á ê Ï Ü·¼ §±« -°»¿µ ©·¬¸ ¿ ´¿© »²º±®½»³»²¬ é è ç ï𠱺º·½»®á ß × ¼±²ù¬ ¾»´·»ª» × -°±µ» ¬± ¬¸»³ò Ö»ºº®»§ ¸¿²¼´»¼ »ª»®§¬¸·²¹ò Ï Ñµ¿§ò ß²¼ §±« -¿·¼ ¬¸¿¬ §±« ¸¿¼ º·²·-¸»¼ ïï §±«® -¸·º¬ ¿¬ óó ¬¸·- ·- ¿¬ ¬¸» α¿¼ ر«-» Ù®·´´ô ïî ½±®®»½¬á ïí ß Ý±®®»½¬ò ïì Ï Ç±« ¸¿¼ º·²·-¸»¼ §±«® -¸·º¬á ïë ß Ç»¿¸ô ·¬ ©¿- ¬¸» »²¼ ±º ¬¸» -¸·º¬ò ïê Ï Ñµ¿§ò ïé ïè ß²¼ §±« ¸¿¼ ½´»¿²»¼ «° ¿²¼ ©»®» ½¸»½µ·²¹ ±«¬ô ½±®®»½¬á ß Ç»¿¸ô ·¬ù- ¿ ½±³°´»¬»´§ -»°¿®¿¬» °¿®¬ ±º ïç ¬¸» óó ·¬ù- ´·µ» ¾¿½µ ±º ¬¸» ¸±«-»ò î𠬸¿¬ ³»¿²-ô ´·µ» ·² ©¿·¬»®·²¹ ¬»®³-á ܱ §±« µ²±© ©¸¿¬ îï Ï øײ¼·½¿¬·²¹ò÷ îî ß Ç»¿¸ô ¾¿½µ ±º ¬¸» ¸±«-»ò îí Ï ß²¼ ©¸¿¬ ©¿- óó ©¸± ©¿- ¬¸·- ¾±-- ¬¸¿¬ §±« îì îë -°±µ» ¬±á ß × ½¿²ù¬ ®»³»³¾»® ¸·- ²¿³»ò Case 18-2868, Document 283, 08/09/2019, 2628241, Page104 of 883 ï »¨½´«-·ª·¬§á î ß Ç»-ò í Ï É¸¿¬ ©¿- ¬¸¿¬ °»®·±¼á ì ß × ¾»´·»ª» ·¬ ©¿- ´·µ» ¿ ¬¸®»»ó³±²¬¸ °»®·±¼ ë ê é è ç ±® -±³»¬¸·²¹ò Ï Ñµ¿§ò ß²¼ ©¸¿¬ ±¬¸»® ¬»®³- ±º ¬¸» ½±²¬®¿½¬ô ¼± §±« ®»½¿´´á ß × ½±«´¼²ù¬ ¬¿´µ ¬± ¿²§ ±¬¸»® ²»©- °«¾´·½¿¬·±² ¿¾±«¬ ¬¸» -¬±®§ò ïð Ï ß²§¬¸·²¹ »´-»á ïï ß Ò±¬ ¬¸¿¬ × µ²±© ±ºò ïî Ï É»®» §±« ¸¿°°§ ©¸»² ¬¸» °»®·±¼ ©¿- «°á ïí ß É»´´ô × ³»¿²ô ¿¬ ¬¸¿¬ ¬·³» × ©¿²¬»¼ ¬± ïì ©®·¬» ¿¾±«¬ ³§ -¬±®§ò ïë ©¸»² ¬¸¿¬ °»®·±¼ ©¿- «°ò ïê ïé Ï Í± × ¹«»--ô §»-ô × ©¿- ¸¿°°§ ß²¼ §±« ©»®» ¿½¬·ª»´§ ©®·¬·²¹ ¿ ¾±±µ ¿¬ ¬¸¿¬ ¬·³»ô ½±®®»½¬á ïè ß Ó§ ³¿²«-½®·°¬ò ïç Ï Ç±« ©»®» ©®·¬·²¹ ¬¸» ³¿²«-½®·°¬ ¿¬ ¬¸» ×ùª» ²»ª»® °«¾´·-¸»¼ ·¬ò îð ¬·³» ±º §±«® °»®·±¼ ±º »¨½´«-·ª·¬§ ©·¬¸ ͸¿®±² îï ݸ«®½¸»®ô ½±®®»½¬á îî îí îì îë ß Ì¸±-» ¬¸®»» ³±²¬¸- ©»®» ¶«-¬ ½®¿¦·²»--ò ¬¸·²µ × -¬¿®¬»¼ ¿º¬»® ¬¸¿¬ò Ï Ç±« ¬¸·²µ §±« -¬¿®¬»¼ ©®·¬·²¹ ¬¸» ¾±±µ ¿º¬»® ¬¸» ç𠼿§- ©»®» «°á × Case 18-2868, Document 283, 08/09/2019, 2628241, Page105 of 883 ï ß Ç»¿¸ò î Ï ß²¼ ¬¸»² §±« ¿¬¬»³°¬»¼ ¬± -»´´ ¬¸¿¬ í ³¿²«-½®·°¬ô ½±®®»½¬á ì ß × ¼·¼²ù¬ ¿¬¬»³°¬ ¬± -»´´ ·¬ò × ©»²¬ ¬± ë ±¬¸»® °«¾´·½¿¬·±²-ô ´·µ»ô ©¸¿¬ ¼± §±« ½¿´´ ¬¸»³á ê л±°´» óó ×ù³ ¬®§·²¹ ¬± ¬¸·²µ ±º ¬¸» ²¿³» ±º ¬¸» é ©±®¼ò è ±® ¿²§¬¸·²¹ò ç ±º ³§ ³¿²«-½®·°¬ ¿²¼ ·º ¬¸»§ ¬¸±«¹¸¬ ·¬ ©¿-ô §±« ïð ïï л±°´» ©¸± °«¾´·-¸ ¾±±µ-ô ²±¬ ´·µ» ¿ ²»©-°¿°»® ß²¼ × ·²¯«·®»¼ ¿¾±«¬ ©¸¿¬ ¬¸»§ ¬¸±«¹¸¬ µ²±©ô ¿ ¹±±¼ -¬±®§ò Ï ß²¼ô §»¿¸ò ͱ §±« -»²¬ ¬¸» ³¿²«-½®·°¬ ¬± ¬¸»-» °»±°´» ïî º±® ¬¸» °«®°±-»- ±º ¬®§·²¹ ¬± °«¾´·-¸ ¬¸» ¾±±µô ïí ½±®®»½¬á ïì ß Í±³» °»±°´»ô §»-ò ïë Ï ß²¼ §±« ©»®» ¬®§·²¹ ¬± ¹»¬ ³±²»§ º®±³ ¬¸» ïê ïé ïè ïç îð îï ¾±±µ °«¾´·½¿¬·±²ô ½±®®»½¬á ß É»´´ô × ©¿-²ù¬ ¹±·²¹ ¬± -»´´ ·¬ ¬± ¬¸»³ º±® º®»»ò Ï Þ«¬ §±« ©»®» «²-«½½»--º«´ ·² º·²¼·²¹ -±³»±²» ¬± °«¾´·-¸ ·¬ô ½±®®»½¬á ß É»´´ô × ©¿- ¿´©¿§- ±² ¬¸» º»²½» ©·¬¸ ·¬ò îî × ©¿-²ù¬ ¬±± -«®» ·º × ©¿²¬»¼ ¬± ±® ¼·¼²ù¬ ©¿²¬ ¬±ò îí × ©¿- ³±®» -»»µ·²¹ ¶«¼¹³»²¬ ¾¿-»¼ «°±² ¬¸»-» °»±°´» îì ©¸± ¸¿ª» ¼±²» ¬¸·- °´»²¬§ ¿²¼ °´»²¬§ ±º ¬·³»-ò îë ͬ·´´ ¬± ¬¸·- ¼¿§ô × ³»¿²ô ×ùª» ¸¿¼ °»±°´» Case 18-2868, Document 283, 08/09/2019, 2628241, Page106 of 883 ï ©¸± ¸¿ª» ¾»»² ·²¬»®»-¬»¼ ·² ·¬ ¿²¼ × -¬·´´ ¼±²ù¬ µ²±© î ·º × ©¿²¬ ¬± ¼± ·¬ §»¬ò í ´±¬ ³±®» ¬¸¿¬ ½¿² ¹± ·²¬± ·¬ô §±« µ²±©ò ì Ï × ³»¿²ô × ¬¸·²µ ¬¸»®»ù- ¿ DZ« ©»®» ¿½¬·ª»´§ -»²¼·²¹ ¬¸» ³¿²«-½®·°¬ ë ¬± °»±°´» º±® °«®°±-»- ±º ¸¿ª·²¹ ¬¸»³ ®»¿½¸ ¿ ¼»¿´ ê ©·¬¸ §±« ¿²¼ °«¾´·-¸ ·¬ô ½±®®»½¬á é ß Ò± ¼»¿´ ©¿- »ª»® ¬¿´µ»¼ ¿¾±«¬ò ɸ¿¬ ©» è ¬¿´µ»¼ ¿¾±«¬ ©¿- ¬¸» °±--·¾·´·¬§ ±º °«¾´·-¸·²¹ ·¬ô ·- ç ·¬ °«¾´·-¸·²¹ó©±®¬¸§ô ©±«´¼ × ²»»¼ ¬± ¹»¬ ¿ ï𠹸±-¬©®·¬»®ò ïï »ª»® ©®·¬¬»² ¿ ³¿²«-½®·°¬ -± × ¼·¼²ù¬ µ²±© ©¸¿¬ × ©¿- ïî ¼±·²¹ò ïí Ï ïì DZ« µ²±©ô ¬¸·- ·- ¬¸» º·®-¬ ¬·³» ×ùª» ѵ¿§ò DZ« ½±²¬¿½¬»¼ Ö¿®®»¼ É»·-º»´¼ô ½±®®»½¬á ïë ß Ý±®®»½¬ò ïê Ï ×ù³ ¹±·²¹ ¬± ³¿®µ ¿ ¼±½«³»²¬ ¿- ïé Ü»º»²¼¿²¬ù- Û¨¸·¾·¬ ïêò ׬ ·- ¿ ½±³°±-·¬» »¨¸·¾·¬ò ïè øÛ¨¸·¾·¬ ïê ³¿®µ»¼ò÷ ïç ÓÎò ÛÜÉßÎÜÍæ îð Ï Ì¸¿²µ §±«ò øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ×ù³ ²±¬ ¹±·²¹ ¬± ¿-µ îï §±« ¬± ®»¿¼ »ª»®§ -·²¹´» °¿¹» ±º ¬¸·-ô ¾«¬ ·º §±« îî ´±±µ ¿¬ ¬¸» º·®-¬ °¿¹»ò îí ß Ë³ó¸«³ò îì Ï Ý¿² §±« ¬»´´ ©¸¿¬ ¬¸·- ·- ·² ¬»®³- ±º ©¸¿¬ îë ¬§°» ±º ¼±½«³»²¬á Case 18-2868, Document 283, 08/09/2019, 2628241, Page107 of 883 ï î í ½¿´³ ¬¸» ¿²¨·»¬§ ¿²¼ »ª»®§¬¸·²¹ ¼±©²ò Ï Þ»º±®» §±« ³»¬ Ö»ºº®»§ Û°-¬»·²ô ¸¿¼ §±« «-»¼ ¿²§ ¼®«¹-á ì ß Í«®»ô §»-ò ë Ï É¸·½¸ ¼®«¹- ¸¿¼ §±« «-»¼ °®·±® ¬± ³»»¬·²¹ ê Ö»ºº®»§ Û°-¬»·²á é ß × -³±µ»¼ °±¬ò è Ï Ý±½¿·²»á ç ß Ç»¿¸ô × ©±«´¼ ¸¿ª» -²±®¬»¼ ½±½¿·²»ô ïð ïï ïî ïí ×ùª» ¬¿µ»² Û½-¬¿-§ò «³ó¸«³ò Ï Ü·¼ §±« »ª»® ¿¾«-» ¿´½±¸±´ ¾»º±®» ³»»¬·²¹ Ö»ºº®»§ Û°-¬»·²á ß Ò±ô × ©¿- óó × ©¿-²ù¬ »ª»² ±º ¿¹» ¬± ¾» ïì ¿¾´» ¬± ¾«§ ·¬ò ïë °¿®¬·»- × ©±«´¼ ¸¿ª» ¼®¿²µ ·¬ô ¾«¬ × ©±«´¼²ù¬ -¿§ × ïê ¿¾«-»¼ ·¬ò ïé Ï Ñµ¿§ò × ³»¿²ô ·º ¬¸»®» ©¿- ¿´½±¸±´ ¿¬ É»®» ¬¸»®» »ª»® ±½½¿-·±²- «°±² ïè ©¸·½¸ §±« ©»®» ±¾-»®ª»¼ ¬± ¾» ¼®«²µ ¾§ ±¬¸»® °»±°´»ô ïç °®·±® ¬± ³»»¬·²¹ Ö»ºº®»§ Û°-¬»·²á îð ß ×º §±«ù®» ¼®·²µ·²¹ô ¬¸» °±--·¾·´·¬§ ±º îï ¹»¬¬·²¹ ¼®«²µ ·- ¿´©¿§- ¬¸»®»ò îî ®»½¿´´ »¨¿½¬ -·¬«¿¬·±² ©¸»®» ¬¸¿¬ ©¿- ¬¸» ½¿-»ô îí ¾«¬ óó îì Ï îë × ¼±²ù¬ óó × ½¿²ù¬ É»®» §±« ¼·¿¹²±-»¼ ¿- ¿ ¼®«¹ ¿¼¼·½¬ °®·±® ¬± ³»»¬·²¹ Ö»ºº®»§ Û°-¬»·²á Case 18-2868, Document 283, 08/09/2019, 2628241, Page108 of 883 ï í ßÙÎÛÒ ÞÔßÒÜÑ ÝÑËÎÌ ÎÛÐÑÎÌ×ÒÙ ú Ê×ÜÛÑô ×ÒÝò îïê ó ïꬸ ͬ®»»¬ô Í«·¬» êðð Ü»²ª»®ô ݱ´±®¿¼± èðîðî ììëð ß®¿°¿¸±» ߪ»²«»ô Í«·¬» ïðð Þ±«´¼»®ô ݱ´±®¿¼± èðíðí ì Ó¿§ ïïô îðïê ë é Í·¹®·¼ Íò ӽݿ©´»§ô Û-¯ò ÞÑ×ÛÍô ÍÝØ×ÔÔÛÎ ú ÚÔÛÈÒÛÎ ÔÔÐ ìðï Û¿-¬ Ô¿- Ñ´¿- Þ±«´»ª¿®¼ Í«·¬» ïîðð Ú±®¬ Ô¿«¼»®¼¿´»ô ÚÔ íííðïóîîïï è λæ î ê ç ïð ïï ̸» ¿º±®»³»²¬·±²»¼ ¼»°±-·¬·±² ·- ®»¿¼§ º±® ®»¿¼·²¹ ¿²¼ -·¹²·²¹ò д»¿-» ¿¬¬»²¼ ¬± ¬¸·- ³¿¬¬»® ¾§ º±´´±©·²¹ ÞÑÌØ ±º ¬¸» ·¬»³- ·²¼·½¿¬»¼ ¾»´±©æ ïî Ý¿´´ íðíóîçêóððïé ¿²¼ ¿®®¿²¹» ©·¬¸ «- ¬± ®»¿¼ ¿²¼ -·¹² ¬¸» ¼»°±-·¬·±² ·² ±«® ±ºº·½»ò ïí ïì ÈÈÈ ïë ïé ÈÈÈ ïç îð îï îî îí îì îë Ø¿ª» ¬¸» ¼»°±²»²¬ ®»¿¼ §±«® ½±°§ ¿²¼ -·¹² ¬¸» -·¹²¿¬«®» °¿¹» ¿²¼ ¿³»²¼³»²¬ -¸»»¬-ô ·º ¿°°´·½¿¾´»å ¬¸» -·¹²¿¬«®» °¿¹» ·- ¿¬¬¿½¸»¼ò λ¿¼ ¬¸» »²½´±-»¼ ½±°§ ±º ¬¸» ¼»°±-·¬·±² ¿²¼ -·¹² ¬¸» -·¹²¿¬«®» °¿¹» ¿²¼ ¿³»²¼³»²¬ -¸»»¬-ô ·º ¿°°´·½¿¾´»å ¬¸» -·¹²¿¬«®» °¿¹» ·¿¬¬¿½¸»¼ò ïê ïè Ê·¼»±¬¿°»¼ Ü»°±-·¬·±² ±º Ê×ÎÙ×Ò×ß Ù×ËÚÚÎÛ Ù·«ºº®» ªò Ó¿¨©»´´ Ý¿-» Ò±ò ïëó½ªóðéìííóÎÉÍ É×ÌØ×Ò íð ÜßÇÍ ÑÚ ÌØÛ ÜßÌÛ ÑÚ ÌØ×Í ÔÛÌÌÛÎ Þ§ ¼«» ¬± ¿ ¬®·¿´ ¼¿¬» ±º д»¿-» ¾» -«®» ¬¸» ±®·¹·²¿´ -·¹²¿¬«®» °¿¹» ¿²¼ ¿³»²¼³»²¬ -¸»»¬-ô ·º ¿²§ô ¿®» Í×ÙÒÛÜ ÞÛÚÑÎÛ ß ÒÑÌßÎÇ ÐËÞÔ×Ý ¿²¼ ®»¬«®²»¼ ¬± ß¹®»² Þ´¿²¼± º±® º·´·²¹ ©·¬¸ ¬¸» ±®·¹·²¿´ ¼»°±-·¬·±²ò ß ½±°§ ±º ¬¸»-» ½¸¿²¹»-¸±«´¼ ¿´-± ¾» º±®©¿®¼»¼ ¬± ½±«²-»´ ±º ®»½±®¼ò ̸¿²µ §±«ò ßÙÎÛÒ ÞÔßÒÜÑ ÝÑËÎÌ ÎÛÐÑÎÌ×ÒÙ ú Ê×ÜÛÑô ×ÒÝò ½½æ ß´´ ݱ«²-»´ Case 18-2868, Document 283, 08/09/2019, 2628241, Page109 of 883 GIUFFRE VS. IMAXWELL mm VIRGINIA GI UF FRE VOLUME II 11/14/2016 Agren Blando Court Reporting Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-001 7 Case 18-2868, Document 283, 08/09/2019, 2628241, Page110 of 883 ×Ò ÌØÛ ËÒ×ÌÛÜ ÍÌßÌÛÍ Ü×ÍÌÎ×ÝÌ ÝÑËÎÌ ÍÑËÌØÛÎÒ Ü×ÍÌÎ×ÝÌ ÑÚ ÒÛÉ ÇÑÎÕ Ý·ª·´ ß½¬·±² Ò±ò ïëó½ªóðéìííóÎÉÍ ÝÑÒÚ×ÜÛÒÌ×ßÔ Ê×ÜÛÑ ÜÛÐÑÍ×Ì×ÑÒ ÑÚ Ê×ÎÙ×Ò×ß Ù×ËÚÚÎÛô ÊÑÔËÓÛ ×× Ò±ª»³¾»® ïìô îðïê Ê×ÎÙ×Ò×ß Ôò Ù×ËÚÚÎÛô д¿·²¬·ººô ªò ÙØ×ÍÔß×ÒÛ ÓßÈÉÛÔÔô Ü»º»²¼¿²¬ò ßÐÐÛßÎßÒÝÛÍæ ÞÑ×ÛÍô ÍÝØ×ÔÔÛÎ ú ÚÔÛÈÒÛÎ ÔÔÐ Þ§ Í·¹®·¼ Íò ӽݿ©´»§ô Û-¯ò ìðï Û¿-¬ Ô¿- Ñ´¿- Þ±«´»ª¿®¼ Í«·¬» ïîðð Ú±®¬ Ô¿«¼»®¼¿´»ô ÚÔ íííðï и±²»æ çëìòíëêòððïï -³½½¿©´»§à¾-º´´°ò½±³ ß°°»¿®·²¹ ±² ¾»¸¿´º ±º ¬¸» д¿·²¬·ºº Case 18-2868, Document 283, 08/09/2019, 2628241, Page111 of 883 ï î í ì ë ê é è ç ïð ïï ïî ïí ïì ïë ïê ïé ïè ïç îð îï îî îí îì îë ßÐÐÛßÎßÒÝÛÍæ øݱ²¬·²«»¼÷ ØßÜÜÑÒô ÓÑÎÙßÒ ßÒÜ ÚÑÎÓßÒô ÐòÝò Þ§ Ô¿«®¿ Ó»²²·²¹»®ô Û-¯ò Ö»ºº®»§ Íò п¹´·«½¿ô Û-¯ò ïëð Û¿-¬ ï𬸠ߪ»²«» Ü»²ª»®ô ÝÑ èðîðí и±²»æ íðíòèíïòéíêì ´³»²²·²¹»®à¸³º´¿©ò½±³ ¶°¿¹´·«½¿à¸³º´¿©ò½±³ ß°°»¿®·²¹ ±² ¾»¸¿´º ±º ¬¸» Ü»º»²¼¿²¬ ß´-± Ю»-»²¬æ ß²² Ô«²¼¾»®¹ô п®¿´»¹¿´ Ó¿®§ª±²²» ̱³°µ·²-ô Ê·¼»±¹®¿°¸»® Case 18-2868, Document 283, 08/09/2019, 2628241, Page112 of 883 ï ß Ç»-ò î Ï ß²¼ §±« ¾»´·»ª» ¬¸» Ò»·³¿² Ó¿®½«- ©¿- í ì ´±½¿¬»¼ ·² ©¸·½¸ ½·¬§á ß É»´´ô ·¬ù- ¿®±«²¼ Ú±®¬ Ô¿«¼»®¼¿´»ò ë ½¿²ù¬ ¬»´´ §±« »¨¿½¬´§ò ê ´·µ» Þ®±©¿®¼ ݱ«²¬§á × Ú±®¬ Ô¿«¼»®¼¿´» ·- -± ¾·¹ô ×- ¬¸¿¬ ¬¸» ©±®¼ º±® ·¬á é Ï ß²¼ ©¸¿¬ ¼·¼ §±« ¼± ¿¬ Ò»·³¿² Ó¿®½«-á è ß × ©±®µ»¼ ·² ¬¸» ½¸¿²¹·²¹ ®±±³-ò ç Ï ß²¼ ©¸¿¬ ¼·¼ §±« ¼± ·² ¬¸» ½¸¿²¹·²¹ ®±±³á ïð ß × ¬¸·²µ × ¶«-¬ ´·µ» óó ·º × ®»³»³¾»® ïï ®·¹¸¬ô × ¶«-¬ °«¬ ½´±¬¸»- ¿©¿§ ¬¸¿¬ °»±°´» ´»º¬ ·² ïî ¬¸»®»ò ïí -·¦»- º±® ©±³»² ©¸± ©¿²¬»¼ ¼·ºº»®»²¬ -·¦»- ±º ¬¸» ïì -¿³» °®±¼«½¬ò ïë ïê Ï Ð®±¾¿¾´§ ©»²¬ ±«¬ ¬± ¹»¬ -·¦»-ô ¼·ºº»®»²¬ ß²¼ ©¸»®» ¼·¼ §±« ©±®µ ¿º¬»® Ò»·³¿² Ó¿®½«-á ïé ß Ì¿½± Þ»´´ò ïè Ï Ü·¼ §±« ©±®µ ¿¬ ͱ«¬¸»¿-¬ Û³°´±§»» ïç îð Ó¿²¿¹»³»²¬ ݱ³°¿²§á ß × ¼±²ù¬ ®»½±¹²·¦» ¬¸¿¬ò × ¼±²ù¬ µ²±© ·º îï ¬¸¿¬ù- ¿ °¿§®±´´ ½±³°¿²§ ±® ©¸¿¬ ·¬ ·-ò îî ©¸¿¬ ͱ«¬¸»¿-¬ óó ©¸¿¬ ·- ·¬ ½¿´´»¼á × ¼±²ù¬ µ²±© îí Ï Í±«¬¸»¿-¬ Û³°´±§»» Ó¿²¿¹»³»²¬ ݱ³°¿²§ò îì ß Ò±ô × ¼±²ù¬ ®»³»³¾»® ¬¸¿¬ò îë Ï Ü·¼ §±« »ª»® ©±®µ ¿- ¿ ¬»³°á Case 18-2868, Document 283, 08/09/2019, 2628241, Page113 of 883 ï ß Ò±¬ ¬¸¿¬ × ®»³»³¾»®ò î Ï Ù±·²¹ ¬± ¼·ºº»®»²¬ ±ºº·½»- ¿²¼ º·´´·²¹ ·²á í ß Ò±ò ì Ï Ü·¼ §±« ©±®µ º±® Ñ¿-·- Ñ«¬-±«®½·²¹á ë ß × ¼±²ù¬ óó × ¼±²ù¬ µ²±© ·º ¬¸¿¬ù- ¿ ê °¿§®±´´ ½±³°¿²§ ±® ·º ¬¸¿¬ù- ¿² ¿½¬«¿´ °´¿½»ô ¾«¬ é ¬¸¿¬ ¼±»-²ù¬ ®·²¹ ¿ ¾»´´ò è ç ïð ïï Ï Ü·¼ §±« óó ¼± §±« µ²±© ¸±© ³«½¸ §±« ¹±¬ °¿·¼ ©¸»² §±« ©»®» ©±®µ·²¹ ¿¬ °´¿½»- ´·µ» Ñ¿-·Ñ«¬-±«®½·²¹á ß É»´´ô ½±²-·¼»®·²¹ × ¼±²ù¬ µ²±© ·º × ©±®µ»¼ ïî ¿¬ Ñ¿-·- Ñ«¬-±«®½·²¹ô × ©±«´¼²ù¬ »ª»² µ²±© ¸±© ³«½¸ × ïí ¹±¬ °¿·¼ò ïì ïë Ï Ü·¼ §±« ®»ª·»© §±«® ͱ½·¿´ Í»½«®·¬§ ®»½±®¼-á ïê ß Ç»-ò ïé Ï Ç±« -¿© Ñ¿-·- Ñ«¬-±«®½·²¹ ´·-¬»¼ ¬¸»®»á ïè ß Î·¹¸¬ô ¾«¬ ´·µ» × -¿·¼ô ·¬ ¼±»-²ù¬ »ª»² ïç îð îï îî ¼·²¹ ¿ ¾»´´ ¿¬ ¿´´ò Ï Ü± §±« µ²±© ¸±© ³«½¸ ³±²»§ ¬¸»§ -¿·¼ §±« ³¿¼» º®±³ ¬¸»³á ÓÍò ÓÝÝßÉÔÛÇæ Ѿ¶»½¬·±²ò ׺ §±« ©¿²¬ ¬± îí -¸±© ¸»® ¬¸» ¼±½«³»²¬-ô -¸» ½¿² -»» ©¸¿¬ ¿³±«²¬ ·- îì ´·-¬»¼ ¿²¼ ¿²-©»® §±«® ¯«»-¬·±²-ô ¾«¬ ·º §±«ù®» ²±¬ îë ¹±·²¹ ¬± -¸±© ¸»® ¬¸» ¼±½«³»²¬ô ¬¸¿¬ù- ¬¸» ¾»-¬ -¸» Case 18-2868, Document 283, 08/09/2019, 2628241, Page114 of 883 ï î í ì ½¿² ¼±ò ß Ç»¿¸ô ·º §±« ½±«´¼ò §±«® ¯«»-¬·±²-ò Ï ×ù³ ¸¿°°§ ¬± ¿²-©»® × ©¿²¬ ¬± ¾» ¸»´°º«´ô -±òòò øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ Ù®»¿¬ò É»´´ô ¼± §±« ë ®»³»³¾»® ¸±© ³«½¸ ³±²»§ §±« ³¿¼» º®±³ Ñ¿-·- ê Ñ«¬-±«®½·²¹á é ß Ô·µ» × -¿·¼ô × ¼±²ù¬ »ª»² ®»³»³¾»® ©±®µ·²¹ è º±® Ñ¿-·- Ñ«¬-±«®½·²¹ô ±® ©¸¿¬ ·¬ ·-ô -± × ½±«´¼²ù¬ ç ¬»´´ §±«ò ïð ïï Ï Ü± §±« ®»³»³¾»® ¸±© ³«½¸ ³±²»§ §±« ©»®» ³¿µ·²¹ °»® ¸±«® ¿¬ Ò»·³¿² Ó¿®½«-á ïî ß Ò±ô ²±¬ ±ºº ¬¸» ¬±° ±º ³§ ¸»¿¼ò ïí Ï Ü± §±« µ²±© ¸±© ³¿²§ ³±²¬¸- §±« ©±®µ»¼ ïì ¬¸»®»á ïë ß ïê ¼±²ù¬ µ²±©ò ïé ¬¸®»»ó³±²¬¸ ³¿®µ ©±«´¼ ¾» ³§ óó × ¼±²ù¬ µ²±© ¬¸» ïè »¨¿½¬ ¿²-©»®ò Ò±¬ ´±²¹ò ×ù¼ °®±¾¿¾´§ -¿§ óó × ³»¿²ô × ×ù³ ²±¬ ¹±·²¹ ¬± ¹«»--ò Þ«¬ ¿®±«²¼ ¬¸» ïç Ï Ü± §±« ®»³»³¾»® ¿²§ ±º §±«® ½±©±®µ»®-á îð ß Ò±ò îï Ï Ü·¼ §±« ©±®µ ¿¬ Ó¿²²·²±ù-á îî ß Þ®·»º´§ô §»-ò îí Ï É¸¿¬ ·- Ó¿²²·²±ù-á îì ß ß ½«¬» ´·¬¬´» ׬¿´·¿² ®»-¬¿«®¿²¬ ·² îë É»´´·²¹¬±²ò Case 18-2868, Document 283, 08/09/2019, 2628241, Page115 of 883 ï Ï ß²¼ ©¸¿¬ ¼·¼ §±« ¼± ¿¬ Ó¿²²·²±ù-á î ß × ¼·¼ ©¿·¬®»--·²¹ò í Ï ß²¼ ¸±© ³«½¸ ¼·¼ §±« ³¿µ»á ì ß Ñ¸ô × ¼±²ù¬ µ²±©ò ë Ï Ü·¼ §±« ©±®µ ¿¬ ÌÙ× Ú®·¼¿§-á ê ß ß¹¿·²ô ª»®§ -¸±®¬´§ò é × ¼±²ù¬ ®»³»³¾»®ò ͸±®¬ ¬·³» °»®·±¼ô ¿²¼ × ©¿- ¿ ©¿·¬®»-- ¿¹¿·²ò è Ï ß²¼ ¸±© ³«½¸ ¼·¼ §±« ³¿µ» ¬¸»®»á ç ß × ¸¿ª» ²± ·¼»¿ò ïð Ï Ü·¼ §±« ¹»¬ º·®»¼á ïï ß Ò±ò ïî Ï É¸§ ¼·¼ §±« ´»¿ª»á ïí ß × ©¿- óó ¬¸¿¬ù- ¿®±«²¼ ¬¸» ¬·³» °»®·±¼ ïì ¬¸¿¬ × ©¿- ¿°°®±¿½¸»¼ ¾§ óó × ½¿²ù¬ ®»³»³¾»® ¸·- ïë ²¿³»ô ¾«¬ ¸» ±©²»¼ ¿ ª»¬»®·²¿®§ ½´·²·½ ±® ¸» ©¿- ¿ ïê ª»¬ô ±²» ±º ¬¸» ¬©±ô ¿²¼ ¸» ±ºº»®»¼ ³» ¬± ½±³» ©±®µ ïé º±® ¸·³ò ïè Ï É¸»² §±« ©»®» ©±®µ·²¹ ¿¬ ÌÙ óó ÌÙ× ïç Ú®·¼¿§-ô ©»®» §±« ¿´-± ©±®µ·²¹ ¿¬ ¬¸» α¿¼¸±«-» îð Ù®·´´á îï ß Ò±ò îî Ï Ì¸±-» ©»®» ²±¬ ¿¬ ¬¸» -¿³» ¬·³»á îí ß × ¼±²ù¬ µ²±©ò îì îë × ¼±²ù¬ ¬¸·²µ -±ò Ó¿§¾» ½±²-»½«¬·ª»´§ ´·µ» ¿º¬»® »¿½¸ ±¬¸»®ò Ï Ü± §±« ®»½¿´´ ©±®µ·²¹ ¿¬ ¬¸» α¿¼¸±«-» Case 18-2868, Document 283, 08/09/2019, 2628241, Page116 of 883 ï Ù®·´´á î ß Ç»-ò í Ï ß²¼ ©¸§ ¼·¼ §±« ´»¿ª» ¬¸»®»á ì ß É» ¿´´ µ²±© ¬¸¿¬ ¬¸» ¬¸·²¹ ¬¸¿¬ ©»²¬ ¼±©² ë ¬¸»®»ò ̱²§ °·½µ»¼ ³» «° ¿²¼ ¬±±µ -±³» ³±²»§ ±«¬ ±º ê ¿ ¶¿®ô ¿²¼ ¬¸»² × ©»²¬ ¬± ¹± ¹·ª» ·¬ ¾¿½µ ¬± ¬¸» ¹«§ô é ¬¸·²µ·²¹ ¬¸¿¬ ·¬ ©±«´¼ ¾» ¿´´ ®·¹¸¬ô ¿²¼ ·¬ ©¿-²ù¬ò è ͱ × ¹±¬ º·®»¼ô × ¬¸·²µò ç ïð Ï ïí ѵ¿§ò × -¸±© §±« -±³» óó ¿®» ©» ±² çá ïï ïî Í«®»ò ÓÎò ÐßÙÔ×ËÝßæ Ï Ç»-ô çò øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ Ü»º»²¼¿²¬ù- Û¨¸·¾·¬ çò ïì øÛ¨¸·¾·¬ ç ³¿®µ»¼ò÷ ïë ÌØÛ ÜÛÐÑÒÛÒÌæ ïê ïé ×ù¼ ´·µ» ¬± -¸±© §±« Ï Ì¸¿²µ §±«ò øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ ܱ §±« ®»½±¹²·¦» §±«® ¸¿²¼©®·¬·²¹ ±² ¬¸·- ¼±½«³»²¬á ïè ß Ç»-ò ïç Ï Ü·¼ §±« º·´´ ±«¬ ¿² ¿°°´·½¿¬·±² º±® îð »³°´±§³»²¬ óó îï ß Ç»-ò îî Ï óó ±² Ó¿®½¸ îꬸ ±º îððîá îí ß Ç»-ò îì Ï ß²¼ ©¸»®» ©»®» §±« ´·ª·²¹ ¿¬ ¬¸¿¬ ¬·³»á îë ß ×ùª» °«¬ ¼±©² ³§ °¿®»²¬-ù ¿¼¼®»--ô ¾«¬ × Case 18-2868, Document 283, 08/09/2019, 2628241, Page117 of 883 ï ¿²¼ -»¿-±²¿´ »³°´±§»»ô ½±®®»½¬á î ß Ý±®®»½¬ò í Ï ß²¼ §±«® ¼¿¼ ©¿- ¿ º«´´ó¬·³» §»¿®ó®±«²¼ ì »³°´±§»»ô ®·¹¸¬á ë ß Ç»-ò ê Ï Ø» ©±®µ»¼ ¬¸»®» ¿´´ ¬¸» ¬·³»ò é ß Ç»-ò è Ï ß²¼ §±«® ¶±¾ ©¿- ¿ -»¿-±²¿´ »³°´±§³»²¬ò ç ß É»´´ô ¿- º¿® ¿- × µ²±© óó ïð ÓÍò ÓÝÝßÉÔÛÇæ Ѿ¶»½¬·±²ò ïï ß óó × ©¿- ¸·®»¼ º±® ¬¸» -«³³»®ô -±òòò ïî Ï øÞÇ ÓÍò ÓÛÒÒ×ÒÙÛÎ÷ η¹¸¬ò ѵ¿§ò ͱ ¬¸» ïí ©±®µ ¸±«®-ô ·² ¬¸» ²»¨¬ °¿®¿¹®¿°¸ô ©¸¿¬ óó ©¸¿¬ ·- ïì ¬¸¿¬ óó ½¿² §±« ¶«-¬ ®»¿¼ ¬¸¿¬ ¾±¬¬±³ °¿®¿¹®¿°¸ º±® ïë «-á ïê ß þ̸» Ý´«¾ ²»ª»® -¸«¬- ¼±©² º®±³ ïé Ò±ª»³¾»® ï-¬ ¬± Ó±¬¸»®ù- Ü¿§å º±® îì ¸±«®- ¿ ¼¿§ô é ïè ¼¿§- ¿ ©»»µô ·¬ -»®ª»- ¬¸» ¼·ª»®-» ²»»¼- ±º ±«® ïç ³»³¾»®-ò î𠿬 ¿´´ ¬·³»-ô ¼»°¿®¬³»²¬- ¸¿ª» ¿®®¿²¹»¼ ¼·ºº»®»²¬ îï -½¸»¼«´»- º±® ¬¸»·® »³°´±§»»-òþ ̸»®»º±®» ¬± »²-«®» ¬¸» ¿¼»¯«¿¬» ½±ª»®¿¹» îî Ï îí Û¨¸·¾·¬ îðò îì ß Ý´±-» ¬¸·- ±²»á îë Ï Ç»¿¸ò ѵ¿§ò ×ù³ ¹±·²¹ ¬± -¸±© §±« Ü»º»²¼¿²¬ù- Case 18-2868, Document 283, 08/09/2019, 2628241, Page118 of 883 ï ÍÌßÌÛ ÑÚ ÝÑÔÑÎßÜÑ÷ î ÷ í ÝÑËÒÌÇ ÑÚ ÜÛÒÊÛÎ ÷ ì --ò ÎÛÐÑÎÌÛÎùÍ ÝÛÎÌ×Ú×ÝßÌÛ ×ô п³»´¿ Öò Ø¿²-»²ô ¼± ¸»®»¾§ ½»®¬·º§ ¬¸¿¬ ë × ¿³ ¿ λ¹·-¬»®»¼ Ю±º»--·±²¿´ λ°±®¬»® ¿²¼ Ò±¬¿®§ ê Ы¾´·½ ©·¬¸·² ¬¸» ͬ¿¬» ±º ݱ´±®¿¼±å ¬¸¿¬ °®»ª·±«- ¬± é ¬¸» ½±³³»²½»³»²¬ ±º ¬¸» »¨¿³·²¿¬·±²ô ¬¸» ¼»°±²»²¬ ©¿- è ¼«´§ -©±®² ¬± ¬»-¬·º§ ¬± ¬¸» ¬®«¬¸ò ç × º«®¬¸»® ½»®¬·º§ ¬¸¿¬ ¬¸·- ¼»°±-·¬·±² ©¿- ï𠬿µ»² ·² -¸±®¬¸¿²¼ ¾§ ³» ¿¬ ¬¸» ¬·³» ¿²¼ °´¿½» ¸»®»·² ïï -»¬ º±®¬¸ô ¬¸¿¬ ·¬ ©¿- ¬¸»®»¿º¬»® ®»¼«½»¼ ¬± ïî ¬§°»©®·¬¬»² º±®³ô ¿²¼ ¬¸¿¬ ¬¸» º±®»¹±·²¹ ½±²-¬·¬«¬»- ïí ¿ ¬®«» ¿²¼ ½±®®»½¬ ¬®¿²-½®·°¬ò ïì × º«®¬¸»® ½»®¬·º§ ¬¸¿¬ × ¿³ ²±¬ ®»´¿¬»¼ ¬±ô ïë »³°´±§»¼ ¾§ô ²±® ±º ½±«²-»´ º±® ¿²§ ±º ¬¸» °¿®¬·»- ±® ïê ¿¬¬±®²»§- ¸»®»·²ô ²±® ±¬¸»®©·-» ·²¬»®»-¬»¼ ·² ¬¸» ïé ®»-«´¬ ±º ¬¸» ©·¬¸·² ¿½¬·±²ò ïè ïç îð ײ ©·¬²»-- ©¸»®»±ºô × ¸¿ª» ¿ºº·¨»¼ ³§ -·¹²¿¬«®» ¬¸·- îí®¼ ¼¿§ ±º Ò±ª»³¾»®ô îðïêò Ó§ ½±³³·--·±² »¨°·®»- Í»°¬»³¾»® íô îðïèò îï îî îí îì îë п³»´¿ Öò Ø¿²-»²ô ÝÎÎô ÎÐÎô ÎÓÎ îïê ó ïꬸ ͬ®»»¬ô Í«·¬» êðð Ü»²ª»®ô ݱ´±®¿¼± èðîðî CQQP 18-7868, 782, 08/00/7010, 7678741, Pagp11q nf EXHIBIT 6 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page120 of 883 ÎÑÍÍ ÒÛ×Ô ï ïïñïèñîðïê ×Ò ÌØÛ Ø×ÙØ ÝÑËÎÌ ÑÚ ÖËÍÌ×ÝÛ ÏËÛÛÒùÍ ÞÛÒÝØ Ü×Ê×Í×ÑÒ î í ì ÍËÌØÛÎÔßÒÜ ÙÑÉ Ý´¿·³ Ò±ò ÝÎ îðïê êîì ÞÛÌÉÛÛÒæ ë Ê×ÎÙ×Ò×ß Ôò Ù×ËÚÚÎÛ ê ¿²¼ é ÎÑÍÍ ÙÑÉô è ç ïð 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¿®±«²¼ Ó¿®½¸ îðïïò ðèæíîæíï ïî Ïò ͱ §±«® º·®-¬ ³»»¬·²¹ ©¿- ·² °»®-±²á ðèæíîæíé ïí ßò Ú·®-¬ ³»»¬·²¹ ©¿- ·² °»®-±²ô §»-ò ðèæíîæìï ïì Ïò Ø¿¼ §±« -°±µ»² ¬± ¸»® °®·±® ¬± ¬¸¿¬á ðèæíîæìî ïë ßò × ¾»´·»ª» ¬¸¿¬ ¬¸» ª»®§ º·®-¬ »²¹¿¹»³»²¬ ©¿- óó ðèæíîæìë ïê × ©¿- ·²¬®±¼«½»¼ ¬± ¸»® ¾§ ³§ ½¸¿·®³¿² Þ®·¿² Þ¿-¸¿³ ¾«¬ ðèæíîæëð ïé × ¾»´·»ª» ¬¸» º·®-¬ ©±®¼- ©» ¸¿¼ ©»®» ·² ¬¸» Ü»ª±²-¸·®» ðèæíîæëì ïè ´¿© ±ºº·½»ò ðèæíîæëè ïç Ïò ðèæííæðð îð Ü·¼ Ó-ò Ó¿¨©»´´ ®»¬¿·² ¬¸» -»®ª·½»- ±º §±« ±® §±«® º·®³á ðèæííæðí îï ßò Ç»-ô -¸» ¼·¼ò ðèæííæðì îî Ïò ß²¼ ©¿- ¬¸¿¬ ·² Ó¿®½¸ ±º îðïïá ðèæííæðê îí ßò ׬ ©¿-ò ðèæííæðç îì Ïò ܱ §±« ¸¿ª» ¿ ©®·¬¬»² ¿¹®»»³»²¬á ðèæííæïï îë ßò É» ¼·¼ ¸¿ª» ¿ ©®·¬¬»² ¿¹®»»³»²¬ ¾«¬ × ½¿² ²± ðèæííæïì ÜÌ× Ý±«®¬ λ°±®¬·²¹ ͱ´«¬·±²ï èðð íîë ííéê Ò»© DZ®µ ©©©ò¼»°±-·¬·±²ò½±³ Case 18-2868, Document 283, 08/09/2019, 2628241, Page122 of 883 ÎÑÍÍ ÒÛ×Ô ï ÍËÌØÛÎÔßÒÜ ÙÑÉ ïïñïèñîðïê п¹» ïí ´±²¹»® ´±½¿¬» ¬¸¿¬ ¿¹®»»³»²¬ò ðèæííæïê î Ïò É¿- ¬¸¿¬ ¿¹®»»³»²¬ »ª»® ®»²»©»¼á ðèæííæïç í ßò ׬ ©¿- ®»²»©»¼ô × ¾»´·»ª» ±² ±® ¿®±«²¼ 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¾¿½µ ¬± ¬¸»³ò ðèæíìæìí îí ÌØÛ É×ÌÒÛÍÍæ îì ÓÎò ÜÇÛÎæ îë Ç»-ô -·®ò ðèæíìæìì DZ« ¼±²ù¬ ¸¿ª» ½±°·»- º±® ³» ±º ¬¸»-» ¼±½«³»²¬-á ÜÌ× Ý±«®¬ λ°±®¬·²¹ ͱ´«¬·±²ï èðð íîë ííéê ðèæíìæëë ðèæíìæëé Ò»© DZ®µ ©©©ò¼»°±-·¬·±²ò½±³ Case 18-2868, Document 283, 08/09/2019, 2628241, Page123 of 883 ÎÑÍÍ ÒÛ×Ô ï î ÍËÌØÛÎÔßÒÜ ÙÑÉ ÓÍò ÍÝØËÔÌÆæ ïïñïèñîðïê п¹» ïì × ¼± ²±¬ ¸¿ª» ¿²§ ³±®» ½±°·»- ±² ¬¸¿¬ò ðèæíìæëè ðèæíìæëç í ÓÎò ÜÇÛÎæ Ò±ô ²±ô ²±ô ·¬ù- ³«½¸ ³±®» ·³°±®¬¿²¬ ðèæíëæðð ì ¬¸¿¬ òòò ¶«-¬ º±® ¬¸» °«®°±-» ±º º±´´±©·²¹ ¬¸·²¹-ô ·¬ù- ðèæíëæðð ë »¿-·»®ò ðèæíëæðí ê é è Ïò ÞÇ ÓÍò ÍÝØËÔÌÆæ ðèæíëæïî ×- ®±--࿽«·¬§®»°«¬¿¬·±²ò½±³ §±«® »³¿·´ ðèæíëæïî ¿¼¼®»--á ðèæíëæïë ç ßò ׬ ·-ô ³§ ¾«-·²»-- »³¿·´ô §»-ò ðèæíëæïê ïð Ïò Ü·¼ §±« -»²¼ ¬¸» »³¿·´ ¼»°·½¬»¼ ·² ¬¸·- ðèæíëæïè ïï ¼±½«³»²¬á ðèæíëæîï ïî ßò Ç»-ô × ¼·¼ò ðèæíëæîê ïí Ïò Ü·¼ §±« -»²¼ ·¬ ±² Ö¿²«¿®§ î²¼ô îðïëá ðèæíëæîé ïì ßò × ¾»´·»ª» × ¼·¼ò ðèæíëæíï ïë Ïò ɸ»² §±« -»²¬ ¬¸¿¬ »³¿·´ ©»®» §±« ¿½¬·²¹ ðèæíëæíì ïê °«®-«¿²¬ ¬± Ó-ò Ó¿¨©»´´ù- ®»¬»²¬·±² ±º §±«® -»®ª·½»-á ðèæíëæíê ïé ßò Ç»-ô × ©¿-ò ðèæíëæìï ïè Ïò ݱ«´¼ §±« °´»¿-» ¬»´´ ³» »ª»®§¬¸·²¹ §±« µ²±© ðèæíëæëè ïç ¿¾±«¬ Ê·®¹·²·¿ α¾»®¬- Ù«·ºº®»ò îð ÓÍò ÓÛÒÒ×ÒÙÛÎæ îï ÓÎò ÜÇÛÎæ ðèæíêæðð Ѿ¶»½¬·±²ô º±«²¼¿¬·±² ¿²¼ º±®³ò DZ« ³¿§ ¿²-©»®ò ðèæíêæðç ðèæíêæïï îî ÞÇ ÓÍò ÍÝØËÔÌÆæ ðèæíêæïï îí Ïò DZ« ¬»-¬·º·»¼ »¿®´·»® ¬¸¿¬ §±« ©»®» ®»¬¿·²»¼ óó ðèæíêæïî îì ÓÎò ÜÇÛÎæ ðèæíêæïë îë ÞÇ ÓÍò ÍÝØËÔÌÆæ ß®» §±« ©·¬¸¼®¿©·²¹ ¬¸¿¬ ¯«»-¬·±²á ÜÌ× Ý±«®¬ λ°±®¬·²¹ ͱ´«¬·±²ï èðð íîë ííéê ðèæíêæïé Ò»© DZ®µ ©©©ò¼»°±-·¬·±²ò½±³ Case 18-2868, Document 283, 08/09/2019, 2628241, Page124 of 883 ÎÑÍÍ ÒÛ×Ô ï î Ïò ÍËÌØÛÎÔßÒÜ ÙÑÉ Ò±ô ×ù³ ²±¬ô ×ù³ ²±¬ò ïïñïèñîðïê п¹» ïë д»¿-» óó × ¿³ ©·¬¸¼®¿©·²¹ ¬¸¿¬ ¯«»-¬·±²ò ðèæíêæïé ðèæíêæîð í ÓÎò ÜÇÛÎæ ì ÓÍò ÍÝØËÔÌÆæ ë ÞÇ ÓÍò ÍÝØËÔÌÆæ ðèæíêæîî DZ« ¬»-¬·º·»¼ °®»ª·±«-´§ ¬¸¿¬ §±« ©»®» ®»¬¿·²»¼ ðèæíêæîî ê Ïò ß´®·¹¸¬ò ðèæíêæîð × ¿³ ©·¬¸¼®¿©·²¹ ¬¸¿¬ ¯«»-¬·±²ò ðèæíêæîð é ¬± ¸¿²¼´» ³¿¬¬»®- ®»´¿¬·²¹ ¬± Ê·®¹·²·¿ α¾»®¬- Ù«·ºº®»å ðèæíêæîì è ·- ¬¸¿¬ ½±®®»½¬á ðèæíêæîç ç ßò ݱ®®»½¬ò ðèæíêæíð ïð Ïò ѵ¿§ò ðèæíêæíï ïï Ù«·ºº®» ·-á ðèæíêæíë ïî ßò × ¿³ò ðèæíêæíê ïí Ïò ѵ¿§ò ͱ §±« ¿®» ¿©¿®» ±º ©¸± Ó-ò α¾»®¬- д»¿-» ¬»´´ ³» »ª»®§¬¸·²¹ §±« µ²±© ¿¾±«¬ ðèæíêæíé ïì Ê·®¹·²·¿ α¾»®¬- Ù«·ºº®»ô °´»¿-»ò ðèæíêæíç ïë ÓÍò ÓÛÒÒ×ÒÙÛÎæ ðèæíêæìî ïê ¿²¼ ³¿§ ½¿´´ º±® °®·ª·´»¹»¼ ³¿¬»®·¿´-ò ïé ïè ïç îð Ѿ¶»½¬·±²ô º±«²¼¿¬·±²ô º±®³ô Ïò ðèæíêæìí ÞÇ ÓÍò ÍÝØËÔÌÆæ ðèæíêæìë DZ« ½¿² ¿²-©»® óó ¬± ¬¸» »¨¬»²¬ ¬¸¿¬ ¿²§¬¸·²¹ ðèæíêæìê §±« ¬»-¬·º§ ¬± ·- ²±¬ °®±¬»½¬»¼ ¾§ ¿ °®·ª·´»¹»ò ßò Ó-ò α¾»®¬- º·®-¬ ½¿³» ¬± ³§ ¿¬¬»²¬·±² ±² ±® ðèæíêæìè ðèæíêæëè îï ¿®±«²¼ Ó¿®½¸ îðïï ©¸»² × ©¿- ½¿´´»¼ ·²¬± ¿ ³»»¬·²¹ ©·¬¸ ðèæíéæðí îî и·´·° Þ¿®¼»² ¿²¼ Ó-ò Ó¿¨©»´´ ¿¬ Ü»ª±²-¸·®»- ´¿© ±ºº·½»ô ðèæíéæðè îí ¬¸¿¬ -¸» ¸¿¼ ³¿¼» óó Ó-ò Ù«·ºº®» ¸¿¼ ³¿¼» »¨¬®»³»´§ ðèæíéæïì îì «²°´»¿-¿²¬ ¿´´»¹¿¬·±²- ¿¾±«¬ Ó-ò Ó¿¨©»´´ù- °®·ª¿¬» ´·º»ò ðèæíéæîð îë É» ©»®» óó ß½«·¬§ λ°«¬¿¬·±²ô ³§ º·®³ ÜÌ× Ý±«®¬ λ°±®¬·²¹ ͱ´«¬·±²ï èðð íîë ííéê Ò»© DZ®µ ©©©ò¼»°±-·¬·±²ò½±³ ðèæíéæîê Case 18-2868, Document 283, 08/09/2019, 2628241, Page125 of 883 ÎÑÍÍ ÒÛ×Ô ÍËÌØÛÎÔßÒÜ ÙÑÉ ïïñïèñîðïê п¹» ïê ï ©¿- ½¿´´»¼ ·² ¬± °®±¬»½¬ Ó-ò Ó¿¨©»´´ù- 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Ç»-ò í ÌØÛ É×ÌÒÛÍÍæ ̱ ¾» ½´»¿®ô Û¨¸·¾·¬ î ©¿- ¬¸» ì ܱ §±« ³»¿² Û¨¸·¾·¬ îá ðçæëçæëè Û¨¸·¾·¬ îò ïðæððæð𠾿-» ¼±½«³»²¬ò ïðæððæðî ïðæððæðí ë ÓÍò ÍÝØËÔÌÆæ ˸󸳳ò ïðæððæðë ê ÌØÛ É×ÌÒÛÍÍæ ײ ¿¼¼·¬·±² ¬± ¬¸» îðïï Ó¿®½¸ ïðæððæðë ̸±-» ©»®» ¬¸» ¬©± ©±®µ·²¹ ¼±½«³»²¬- ¬¸¿¬ ïðæððæïð é -¬¿¬»³»²¬ò è ©»®» ¿´©¿§- ®»º»®®»¼ ¬±ô ¾±¬¸ ±º ©¸·½¸ óó ©»´´ô ¬¸» º·®-¬ ïðæððæïë ç ±²» ©¿- ·² ¿ °«¾´·½ ¼±³¿·² ¿²¼ ©¿- ±² ®»½±®¼ ±² ¬¸» ïðæððæïé ïð Ü»ª±²-¸·®»- óó ±² óó ©·¬¸ Ü»ª±²-¸·®»- ²¿³» ¿¬ ¬¸» ¬±° ±² ïðæððæîï ïï ÐÎ Ò»©-©·®» ©¸·½¸ ·- ¿ ¹´±¾¿´ ¼»´·ª»®§ -»®ª·½»ò ͱ ¬¸¿¬ ïðæððæîì ïî ©¿- »¿-·´§ ¿½½»--·¾´» ¾§ °»±°´»ò ß²¼ ¬¸» -»½±²¼ ±²» ©¿- ïðæððæîè ïí ¬¸» óó º«®¬¸»® ¬± ¬¸» î²¼ ±º Ö¿²«¿®§ îðïëò ïì ïë Ïò ïðæððæíï ÞÇ ÓÍò ÍÝØËÔÌÆæ ïðæððæíè ̱ ¬¸» »¨¬»²¬ §±« ½¿² ®»½¿´´ ±® ½±«´¼ »-¬·³¿¬»ô ïðæððæíé ïê ¸±© ³¿²§ ±¬¸»® »³¿·´- ¼± §±« ¾»´·»ª» §±« -»²¬ ¾»¿®·²¹ ïðæððæìð ïé ¬¸¿¬ -¬¿¬»³»²¬ ¬¸¿¬ù- ·² Û¨¸·¾·¬ îá ïðæððæìí ïè ïç ßò × ®»¿´´§ ½¿²ù¬ ®»³»³¾»® ¾«¬ ½»®¬¿·²´§ ³±®» ¬¸¿² -·¨ ¿²¼ °®±¾¿¾´§ ´»-- ¬¸¿² íðô -±³»©¸»®» ·² ¾»¬©»»²ò îð ß²§ ¬·³» ¬¸»®» ©¿- ¿² ·²½±³·²¹ ¯«»®§ ïðæððæìé ïðæððæìè ïðæððæëî îï ·¬ ©¿- »·¬¸»® ¼»¿´¬ ©·¬¸ ±² ¬¸» ¬»´»°¸±²» ¾§ ®»º»®®·²¹ ïðæððæëì îî ¬¸»³ ¾¿½µ ¬± ¬¸» ¬©± -¬¿¬»³»²¬- ±º Ó¿®½¸ îðïï ¿²¼ ïðæððæëé îí Ö¿²«¿®§ îðïë ±® -±³»±²» ©±«´¼ »³¿·´ ¬¸»³ ¬¸» ïðæðïæðð îì -¬¿¬»³»²¬ò ïðæðïæðê îë ¬¸» óó ·- ©¸»®» ©» ©»®»ò ͱ ²± ±²» ©¿- ´»º¬ «²¿²-©»®»¼ô ¾®±¿¼´§ô ·Þ«¬ × ½¿²ù¬ ®»³»³¾»® »ª»®§ ÜÌ× Ý±«®¬ λ°±®¬·²¹ ͱ´«¬·±²ï èðð íîë ííéê Ò»© DZ®µ ©©©ò¼»°±-·¬·±²ò½±³ ïðæðïæðç Case 18-2868, Document 283, 08/09/2019, 2628241, Page134 of 883 ÎÑÍÍ ÒÛ×Ô ï î í ÍËÌØÛÎÔßÒÜ ÙÑÉ ïïñïèñîðïê п¹» êè -·²¹´» °»®-±² ©» ®»¿½¸»¼ ±«¬ ¬±ò Ïò ѵ¿§ò ïðæðïæïí ͱ ·- ·¬ §±«® ¬»-¬·³±²§ ¬¸¿¬ §±« ®»¿½¸»¼ ±«¬ ¬± ·²¼·ª·¼«¿´- ©¸± ¼·¼ ²±¬ º·®-¬ ½±²¬¿½¬ §±«á ïðæðïæïç ïðæðïæîî ì ßò Ò±ò É» ©»®» ·² ®»-°±²-» ³±¼»ò ïðæðïæîê ë Ïò ѵ¿§ò ïðæðïæîè ê ßò ̸»®» ©¿- »²±«¹¸ ¬± ¼± ®»-°±²¼·²¹ ¬± ·²½±³·²¹ ïðæðïæîç é ¯«»®·»-ô × ©±«´¼²ù¬ ¸¿ª» ¾»»² ³¿µ·²¹ ³±®» ©±®µô ¬± ¾» ïðæðïæíí è ¸±²»-¬ò ïðæðïæíè ç Ïò ïð ß´®·¹¸¬ò ÓÎò ÜÇÛÎæ ïðæðïæíè ͱ ¶±«®²¿´·-¬- °¿·¼ ²± ¿¬¬»²¬·±² ¬± ïðæðïæìî ïï §±«® þÒ± 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®»´¿¬·±²- ¿²¼ °®±¬»½¬·²¹ ¬¸»·® ®»°«¬¿¬·±²ò ïïæîíæîë ì ë ê Ïò -«½¸ -»®ª·½»-á ßò é è ß°°®±¨·³¿¬»´§ ¸±© ´±²¹ ¸¿ª» §±« ¾»»² °®±ª·¼·²¹ ïïæîíæîé ïïæîíæíð ß½«·¬§ ©¿- -»¬ «° ·² îðïðò ïïæîíæíï øÛ¨¸·¾·¬ îê ©¿- ³¿®µ»¼ º±® ·¼»²¬·º·½¿¬·±²ò÷ ïïæîíæìî ÞÇ ÓÍò ÍÝØËÔÌÆæ Ïò ïð Û¨¸·¾·¬ îêò ïïæîíæíç ïï ßò ̸¿²µ §±«ò ïïæîíæìí ïî Ïò ܱ»- ¬¸·- ¼±½«³»²¬ º¿·®´§ ¼»°·½¬ °¿¹»- º®±³ ïïæîíæëí ïí ×ù³ ¹±·²¹ ¬± ¸¿²¼ §±« ©¸¿¬ ×ùª» ³¿®µ»¼ ¿- ïïæîíæíé ç §±«® óó º®±³ ß½«·¬§ λ°«¬¿¬·±²ù- ©»¾-·¬»á ïïæîíæëë ïì ßò ׬ ¼±»-ò ïïæîíæëç ïë Ïò ܱ §±« -»» ©¸»®» ·¬ -¿§- þÉ» ³¿²¿¹» ®»°«¬¿¬·±² ïïæîìæðî ïê ¿²¼ º±®¹» ±°·²·±² ¬¸®±«¹¸ °«¾´·½ ®»´¿¬·±²-ô -¬®¿¬»¹·½ ïïæîìæðê ïé ½±³³«²·½¿¬·±²- ¿²¼ ¸·¹¸ ´»ª»´ ²»¬©±®µ·²¹þá ïïæîìæïð ïè ßò × ¼±ò ïïæîìæïí ïç Ïò ×- ¬¸¿¬ ¿ ¬®«» -¬¿¬»³»²¬á ïïæîìæïí îð ßò Í¿§ ·¬ ¿¹¿·²ò ïïæîìæïë îï Ïò ×- ¬¸¿¬ ¿ ¬®«» -¬¿¬»³»²¬á ïïæîìæïé îî ßò ׬ ·-ô §»-ò ïïæîìæïè × ©®±¬» ¬¸¿¬ -¬¿¬»³»²¬ò îí ÓÎò ÜÇÛÎæ îì ÌØÛ É×ÌÒÛÍÍæ îë ͱ®®§ò ͱ®®§ô §±« ®»¿¼ ·¬ ±® §±« ©®±¬» ·¬á × ©®±¬» ·¬ô -± × ¼± ®»½±¹²·¦» ·¬ò ïïæîìæîî ïïæîìæîè ÞÇ ÓÍò ÍÝØËÔÌÆæ ÜÌ× Ý±«®¬ λ°±®¬·²¹ ͱ´«¬·±²ï èðð íîë ííéê ïïæîìæîð Ò»© DZ®µ ©©©ò¼»°±-·¬·±²ò½±³ Case 18-2868, Document 283, 08/09/2019, 2628241, Page136 of 883 ÎÑÍÍ ÒÛ×Ô ï Ïò ÍËÌØÛÎÔßÒÜ ÙÑÉ ïïñïèñîðïê п¹» ïïð ×- ·¬ ½±®®»½¬ ¬¸¿¬ °«¾´·½ ®»´¿¬·±²- ¿²¼ ïïæîìæîç î -¬®¿¬»¹·½ ½±³³«²·½¿¬·±²- ¿®» ¬¸·²¹- ¬¸¿¬ §±« °»®-±²¿´´§ ïïæîìæíï í ¼± ¿- °¿®¬ ±º §±«® °®±º»--·±²¿´ ¿½¬·ª·¬·»-á ïïæîìæíê ì ë ê é è ç ïð ïï ïî ßò × °»®-±²¿´´§ óó ×ù³ ·²ª±´ª»¼ ·² °«¾´·½ ®»´¿¬·±²- ¿²¼ -¬®¿¬»¹·½ ½±³³«²·½¿¬·±²-ô §»-ò Ïò ×- ·¬ ½±®®»½¬ ¬¸¿¬ ¬¸» ³»¼·¿ ·- ¬¸» ·²¬»²¼»¼ ®»½·°·»²¬ ±º ¬¸·- -¬®¿¬»¹·½ ½±³³«²·½¿¬·±²-ò ßò ¬¸» ³»¼·¿ò ïïæîìæìì ïïæîìæìè ïïæîìæëï ׬ù- óó ¬¸» óó ·¬ù- ¿ ´¿®¹»® ¹®±«²¼ ¬¸¿² ¶«-¬ ïïæîìæëë ̸»®» ³¿§ ¾» ´±¾¾§·-¬-ô ¹±ª»®²³»²¬ ¬¸·²µ ïïæîìæëç ¬¿²µ-ô º±½«- ¹®±«°-ô ¹±ª»®²³»²¬ ¼»°¿®¬³»²¬-ò Ïò ïïæîìæìð ɱ«´¼ ·¬ ¾» º¿·® ¬± -¿§ ¬¸¿¬ ¬¸» ³»¼·¿ ·- ±º¬»² ¬¸» ·²¬»²¼»¼ ®»½·°·»²¬ ±º -¬®¿¬»¹·½ ½±³³«²·½¿¬·±²-á ïïæîëæðë ïïæîëæðç ïïæîëæïî ïí ßò ׬ ·- ¿ º®»¯«»²¬ ®»½·°·»²¬ò ïïæîëæïê ïì Ïò λº»®»²¬ ®»½·°·»²¬á ïïæîëæïè ïë ßò Þ«¬ ²±¬ ¬¸» -±´» ®»½·°·»²¬ò 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¿¾±«¬ Û¨¸·¾·¬ îëò ïï Ò»© DZ®µ Ü¿·´§ Ò»©- ¬± §±« ©¸·½¸ §±« -»²¬ ±² ¬± ïïæîêæïí ïî Ó-ò Ó¿¨©»´´ ¿²¼ Ó®ò Þ¿®¼»²ò ïïæîêæïé ïí ÌØÛ É×ÌÒÛÍÍæ ïì ÓÎò ÜÇÛÎæ ̸·- ©¿- ¬¸» »³¿·´ º®±³ ¬¸» ïïæîëæëç Ç»-ò ïïæîêæðí ïïæîêæîð ܱ §±« ®»½±´´»½¬ ©¸»¬¸»® §±« ©»®» ïïæîêæîç ïë ¿-µ»¼ ¬± ³¿µ» ¿²§ -¬¿¬»³»²¬ ·² ®»-°±²-» ¬± ¬¸·- ³¿¬¬»®ô ïïæîêæíð ïê ¬¸» ·--«» ±º °®±½»»¼·²¹- ·² Í»°¬»³¾»® ±º ´¿-¬ §»¿®á ïïæîêæíë ïé ÌØÛ É×ÌÒÛÍÍæ × ¼±²ù¬ô -·®ò ׬ù- ¿´©¿§- ¾»»² ïïæîêæìð ïè ¬¸» ½¿-» ¬¸¿¬ Ó®ò Þ¿®¼»² ¿²¼ × ©»®» »²½±«®¿¹·²¹ ïïæîêæìë ïç Ó-ò Ó¿¨©»´´ ¬± ³¿µ» ¿ -¬¿¬»³»²¬ô ¾«¬ -¸» ©¿- ª»®§ ïïæîêæëð îð ®»´«½¬¿²¬ ¬± ¼± -±ò ïïæîêæëé îï ÓÎò ÜÇÛÎæ η¹¸¬ò × ¬¸·²µ §±«ùª» ¹±¬ ¸·³ ¬± ïïæîéæðð îî ¿½½»°¬ ¬¸¿¬ «° «²¬·´ -±³» ¬·³» Ó¿®½¸ô ß°®·´ô Ó¿§ô ¸» ³¿§ ïïæîéæðî îí ¸¿ª» -°±µ»² ¬± Ó®ò ͧ-±²ò ïïæîéæðê îì -¬¿¬»³»²¬ ¬¸¿¬ ¬¸»®»ù- ¿²§ »ª·¼»²½» ±º ¸·³ ³¿µ·²¹ ¿¾±«¬ ïïæîéæïð îë ¬¸·- ³¿¬¬»®ò ïïæîéæïì ß²¼ ¬¸¿¬ ©¿- ¬¸» ´¿-¬ Þ«¬ ±² ¬¸» »ª·¼»²½»ô ¿- × «²¼»®-¬¿²¼ ·¬ô ÜÌ× Ý±«®¬ λ°±®¬·²¹ ͱ´«¬·±²ï èðð íîë ííéê Ò»© DZ®µ ©©©ò¼»°±-·¬·±²ò½±³ Case 18-2868, Document 283, 08/09/2019, 2628241, Page138 of 883 ÎÑÍÍ ÒÛ×Ô ï ÍËÌØÛÎÔßÒÜ ÙÑÉ ïïñïèñîðïê п¹» ïîé ÝÛÎÌ×Ú×ÝßÌÛ ÑÚ ÝÑËÎÌ ÎÛÐÑÎÌÛÎ î í ×ô Ô·-¿ Óò Þ¿®®»¬¬ô ¿² ß½½®»¼·¬»¼ λ¿´ó¬·³» λ°±®¬»®ô ì ¸»®»¾§ ½»®¬·º§ ¬¸¿¬ ¬¸» ¬»-¬·³±²§ ±º ¬¸» ©·¬²»-- α-- ë Ò»·´ Í«¬¸»®´¿²¼ Ù±© ·² ¬¸» º±®»¹±·²¹ ¬®¿²-½®·°¬ô ê ²«³¾»®»¼ °¿¹»- ï ¬¸®±«¹¸ ïîîô ¬¿µ»² ±² ¬¸·- ï謸 ¼¿§ é ±º Ò±ª»³¾»®ô îðïê ©¿- ®»½±®¼»¼ ¾§ ³» ·² ³¿½¸·²» è -¸±®¬¸¿²¼ ¿²¼ ©¿- ¬¸»®»¿º¬»® ¬®¿²-½®·¾»¼ ¾§ ³»å ¿²¼ ç ¬¸¿¬ ¬¸» º±®»¹±·²¹ ¬®¿²-½®·°¬ ·- ¿ ¬®«» ¿²¼ ¿½½«®¿¬» ï𠪻®¾¿¬·³ ®»½±®¼ ±º ¬¸» -¿·¼ ¬»-¬·³±²§ò ïï ïî ïí × º«®¬¸»® ½»®¬·º§ ¬¸¿¬ × ¿³ ²±¬ ¿ ®»´¿¬·ª»ô »³°´±§»»ô ïì ½±«²-»´ ±® º·²¿²½·¿´´§ ·²ª±´ª»¼ ©·¬¸ ¿²§ ±º ¬¸» ïë °¿®¬·»- ¬± ¬¸» ©·¬¸·² ½¿«-»ô ²±® ¿³ × ¿² »³°´±§»» ±® ïê ®»´¿¬·ª» ±º ¿²§ ½±«²-»´ º±® ¬¸» °¿®¬·»-ô ²±® ¿³ ×ô ·² ïé ¿²§ ©¿§ô ·²¬»®»-¬»¼ ·² ¬¸» ±«¬½±³» ±º ¬¸» ©·¬¸·² ïè ½¿«-»ò ïç îð îï Í·¹²»¼æ òòòòòòòòòòòòòòòòòòòòòòòòòòòòòòòòòò îî Ò¿³»æ Ô·-¿ Óò Þ¿®®»¬¬ô ÎÐÎô ÝÎÎô ÝÎÝô ÝÍÎ îí Ü¿¬»æ òòòòòòòòòòòòòòòòòòòòòòòòòòòòòòòòòòò îì îë ÜÌ× Ý±«®¬ λ°±®¬·²¹ ͱ´«¬·±²ï èðð íîë ííéê Ò»© DZ®µ ©©©ò¼»°±-·¬·±²ò½±³ CQQP 18-7868, 782, 08/00/7010, 7678741, Pagm RC) nf EXHIBIT 7 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page140 of 883 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 20, 2016 9:12 a.m. C O N F I D E N T I A L Deposition of pursuant to notice, taken by Plaintiff, at the offices of Podhurst Orseck, 25 West Flagler Street, Suite 800, Miami, 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 283, 08/09/2019, 2628241, Page141 of 883 Page 54 1 2 3 4 - CONFIDENTIAL BY MR. EDWARDS: Q. requested to give a massage? 5 6 When you got to his house, you were MR. PAGLIUCA: Object to foundation and form. 7 THE WITNESS: I don't exactly remember. 8 don't remember if I was asked in the kitchen. 9 I don't remember if -- I don't remember. 10 11 BY MR. EDWARDS: Q. 12 13 Massage was part of the game, though? MR. PAGLIUCA: THE WITNESS: 15 sorry. 16 BY MR. EDWARDS: 18 19 20 21 22 Object to form and foundation. 14 17 Q. I don't remember. I'm But even during this deposition today, we have described at times you giving him a massage? A. Yes. You're asking about my first encounter, though. Q. Sorry, I'm just trying to sum up the whole thing. 23 A. Okay. 24 Q. Was massage part of the lure to get you 25 I specifically to his house? Case 18-2868, Document 283, 08/09/2019, 2628241, Page142 of 883 Page 55 1 2 - CONFIDENTIAL A. 3 4 5 6 7 MR. PAGLIUCA: BY MR. EDWARDS: Q. And at the time, you are 15, 16 or 17 years old? MR. PAGLIUCA: Object to form and foundation. 10 11 Object to form and foundation. 8 9 Yes. THE WITNESS: Yes. BY MR. EDWARDS: 12 Q. No massage experience? 13 A. No. 14 Q. You were told to bring other girls to his 15 house? 16 17 MR. PAGLIUCA: foundation. 18 19 20 21 22 23 24 25 Object to form and THE WITNESS: After a while, yes. BY MR. EDWARDS: Q. These massages were turned sexual by Jeffrey, as opposed to by anyone else? A. Jeffrey took my clothes off without my consent the first time I met him. Q. The massages were scheduled by people working for Jeffrey? Case 18-2868, Document 283, 08/09/2019, 2628241, Page143 of 883 Page 56 1 - CONFIDENTIAL 2 A. 3 MR. PAGLIUCA: 4 5 Object to form and foundation. BY MR. EDWARDS: 6 7 I don't recall. Q. Jeffrey Epstein, during these massages, would use sex toys or have sex toys used? 8 MR. PAGLIUCA: 9 Object to form and foundation. 10 THE WITNESS: 11 longer a massage. 12 But, yes, he would take out adult toys and 13 different things. 14 Something else is going on. BY MR. EDWARDS: 15 16 Well, at that point, it's no Q. While you were a teenager, Jeffrey Epstein asked you to live with him? 17 A. Yes. 18 Q. Jeffrey Epstein encouraged girl-on-girl 19 sex? 20 21 MR. PAGLIUCA: 24 25 Object to form and foundation. 22 23 He wanted me to be emancipated. THE WITNESS: Yes. BY MR. EDWARDS: Q. And after you cooperated with the police, you were intimidated by people working for Jeffrey Case 18-2868, Document 283, 08/09/2019, 2628241, Page144 of 883 Page 57 1 2 - CONFIDENTIAL Epstein? 3 4 MR. PAGLIUCA: Object to form and foundation. 5 THE WITNESS: Yes. 6 MR. EDWARDS: All right. I don't have 7 anything further for you. 8 even had to go through this, all right? 9 THE WITNESS: 10 11 12 I apologize that we Okay. E X A M I N A T I O N BY MR. PAGLIUCA: Q. Ms. , by name is Jeff Pagluica. 13 live in Denver, Colorado. 14 want to be here today either, okay? 15 be in Denver. 16 I And, like you, I don't I would rather I just want to -- as I understand it, and 17 I'm not trying to get into any of your treatment 18 over the last, let's say, 10 years, because I don't 19 know how long it's been, but as I understand what 20 you and your lawyer have said here today, you have 21 been involved in some number of years of therapy, in 22 which the purpose -- part of the purpose of the 23 therapy has been to forget all of these events that 24 Mr. Edwards was asking you questions about; is that 25 correct? Case 18-2868, Document 283, 08/09/2019, 2628241, Page145 of 883 Page 71 1 2 3 4 5 6 7 - CONFIDENTIAL CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, the undersigned authority, certify that personally appeared before me and was duly sworn. WITNESS my hand and official seal this 23rd day of June, 2016. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Kelli Ann Willis, RPR, CRR Notary Public, State of Florida Commission FF928291, Expires 2-16-20 + + + + + + + + + + + + + + + + + + CERTIFICATE STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) 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 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 23rd day of June, 2016. KELLI ANN WILLIS, RPR, CRR CQQP 18-7868, 782, 08/00/7010, 7678741, nf EXHIBIT 8 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page147 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA L. GIUFFRE, Plaintiff, v. CASE NO.:15-CV-07433-RWS GHISLAINE MAXWELL, Defendants. _______________________________ January 25, 2017 9:05 a.m. - 12:44 p.m. 401 E. Las Olas Boulevard Fort Lauderdale, Florida **** C O N F I D E N T I A L **** VIDEOTAPE DEPOSITION OF SARAH KELLEN Taken on behalf of the before Michael J. D'Amato, RMR, Notary Public in and for the State of Florida at Large, pursuant to Notice of Taking Deposition in the above cause. Job # 293966 Case 18-2868, Document 283, 08/09/2019, 2628241, Page148 of 883 Page 15 1 decline to answer. 2 Q. Who introduced you to Ghislaine Maxwell? 3 A. On advice of my counsel I must invoke my Fifth 4 and Sixth Amendment privilege which I understand 5 protect the innocent and therefore I must unfortunately 6 decline to answer. 7 8 9 Q. When you met Ghislaine Maxwell was she working for Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth 10 and Sixth Amendment privilege which I understand 11 protect the innocent and therefore I must unfortunately 12 decline to answer. 13 14 15 Q. Did Ghislaine Maxwell work as a recruiter for young girls for Jeffrey Epstein when you met her? A. On advice of my counsel I must invoke my Fifth 16 and Sixth Amendment privilege which I understand 17 protect the innocent and therefore I must unfortunately 18 decline to answer. 19 20 21 Q. I'm defining young girls to mean females the ages 12 to 23. A. Do you understand that? On advice of my counsel I must invoke my Fifth 22 and Sixth Amendment privilege which I understand 23 protect the innocent and therefore I must unfortunately 24 decline to answer. 25 Q. Didn't Ghislaine Maxwell approach you to Case 18-2868, Document 283, 08/09/2019, 2628241, Page149 of 883 Page 20 1 2 girls for sex with Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth 3 and Sixth Amendment privilege which I understand 4 protect the innocent and therefore I must unfortunately 5 decline to answer. 6 7 8 9 Q. Did you assist Ghislaine Maxwell in procuring underage girls for sex with Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand 10 protect the innocent and therefore I must unfortunately 11 decline to answer. 12 Q. Isn't it true that Ghislaine Maxwell would 13 recruit underage girls for sex and sex acts with 14 Jeffrey Epstein? 15 A. On advice of my counsel I must invoke my Fifth 16 and Sixth Amendment privilege which I understand 17 protect the innocent and therefore I must unfortunately 18 decline to answer. 19 20 21 Q. Did Ghislaine Maxwell give you information on what underage girls she had contact information for? A. On advice of my counsel I must invoke my Fifth 22 and Sixth Amendment privilege which I understand 23 protect the innocent and therefore I must unfortunately 24 decline to answer. 25 Q. Did Ghislaine Maxwell teach you to offer these Case 18-2868, Document 283, 08/09/2019, 2628241, Page150 of 883 Page 199 1 2 CERTIFICATE OF COURT REPORTER I, MICHAEL J. D'AMATO, a Registered Merit Reporter 3 and Notary Public in and for the State of Florida at 4 Large, do HEREBY CERTIFY that I was authorized to and 5 did stenographically report the deposition of SARAH 6 KELLEN; that a review of the transcript was requested; 7 and that the foregoing transcript, pages from 1 to 197, 8 is a true and accurate record of my stenographic notes. 9 I FURTHER CERTIFY that I am not a relative, 10 employee, attorney, or counsel of any of the parties, nor 11 am I a relative or employee of any of the parties' 12 attorney or counsel connected with the action, nor am I 13 financially interested in the action. 14 Dated this 27th day of January 2017. 15 _______________________ 16 MICHAEL J. D'AMATO, 17 Registered Merit Reporter 18 19 20 21 22 23 24 25 CQQP 18-7868, 782, 08/09/7010, 7678741, Pagm '31 nf EXHIBIT 9 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page152 of 883 Page 1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS ______________________________________________________ VIDEOTAPE DEPOSITION OF: PETER KENT November 29, 2016 ______________________________________________________ VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. ______________________________________________________ PURSUANT TO SUBPOENA AND NOTICE, the videotape deposition of PETER KENT was taken on behalf of the Plaintiff at 150 East 10th Avenue, Denver, Colorado 80230, on November 29, 2016, at 9:00 a.m., before Sandra L. Bray, Registered Diplomate Reporter, Certified Realtime Reporter, and Notary Public within Colorado. MAGNA LEGAL SERVICES (866) 624-6221 Case 18-2868, Document 283, 08/09/2019, 2628241, Page153 of 883 Page 25 1 MS. McCAWLEY: I'm just asking about his 2 retention, which I believe is discoverable under 3 Rule 26. 4 Q. (BY MS. McCAWLEY) Do you recall whether 5 you were retained to perform work for one expert or 6 two experts? 7 8 THE DEPONENT: Am I allowed to answer MR. PAGLIUCA: Yes. this? 9 10 A. I actually don't recall. 11 Q. (BY MS. McCAWLEY) Do you know whether 12 you were provided with one report or two reports when 13 you initially were retained? 14 15 16 A. I believe I was provided with both the reports at the same time. Q. Let me turn to about halfway back. So 17 it's going to be -- there's markings on the bottom. 18 It says PK-005. 19 A. Yes. 20 Q. And it indicates an amount there, an 21 invoice. Is this one of your invoices? 22 A. Yes. 23 Q. It indicates an amount of $17,875? 24 A. Yes. 25 Q. Is that the total amount you've been Case 18-2868, Document 283, 08/09/2019, 2628241, Page154 of 883 Page 26 1 paid, with the exception of what we paid you for your 2 testimony here today, in this matter? 3 A. I think so. 4 Q. It looks like it's dated October 29th, 6 A. Oh, yes. 7 Q. Have you performed any work after that 5 8 What date was this? 2016. In that case, yes. date that you've been paid for? 9 A. Only in preparation for this deposition. 10 Q. Have you been paid for that work? 11 A. No. 12 Q. No. 13 A. No. 14 Q. All right. Have you invoiced that work yet? And then I'm going to turn 15 you to the next page -- please don't put it away 16 yet -- which appear to be invoices. 17 A. Time sheets. 18 Q. Time sheets? 19 A. It's a time sheet. 20 Q. Is this typically how you record your 21 You tell me. time when you're doing expert work? 22 A. Yes. 23 Q. And this indicates -- the first entry is 24 on 9/28/2016. 25 matter? Is that when you commenced work on this Case 18-2868, Document 283, 08/09/2019, 2628241, Page155 of 883 Page 162 REPORTER'S CERTIFICATE STATE OF COLORADO ) ) ss. CITY AND COUNTY OF DENVER ) I, SANDRA L. BRAY, Registered Diplomate Reporter, Certified Realtime Reporter, and Notary Public ID 20084001729, State of Colorado, do hereby certify that previous to the commencement of the examination, the said PETER KENT was duly sworn by me to testify to the truth in relations to the matters in controversy between the parties hereto; that the said deposition was taken in machine shorthand by me at the time and place aforesaid and was thereafter reduced to typewritten form; that the foregoing is a true transcript of the questions asked, testimony given, and proceedings had. I further certify that I am not employed by, related to, nor of counsel for any of the parties herein nor otherwise interested in the outcome of this litigation. IN WITNESS WHEREOF, I have affixed my signature this 8th of December, 2016. My commission expires January 16, 2020. __X__ Reading and Signing was requested. _____ Reading and Signing was waived. _____ Reading and Signing is not required. CQQP 18-7868, 782, 08/00/7010, 7678741, Pagm '36 nf EXHIBIT 10 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page157 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: 15-cv-07433-RWS -againstGHISLAINE MAXWELL, Defendant. - - - - - - - - - - - - - - - - - - - - x C O N F I D E N T I A L Videotaped oral deposition of NADIA MARCINKO, taken pursuant to notice, was held at the law offices of BOIES SCHILLER & FLEXNER, LLP, 575 Lexington Avenue, New York, New York commencing January 17, 2017, 1:04 p.m., before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 Case 18-2868, Document 283, 08/09/2019, 2628241, Page158 of 883 Page 10 1 N. Marcinko - Confidential 2 reside, a dwelling that is paid for by either 3 Jeffrey Epstein or Ghislaine Maxwell? 4 A. Same answer. 5 Q. Do you know Jeffrey Epstein? 6 A. Same answer. 7 Q. Do you know Ghislaine Maxwell? 8 A. Same answer. 9 Q. How old were you when you met 10 either Jeffrey Epstein or Ghislaine Maxwell? 11 A. Same answer. 12 Q. Who introduced to you Ghislaine 13 Maxwell? 14 A. Same answer. 15 Q. When you met Ghislaine Maxwell, was 16 she working for Jeffrey Epstein? 17 A. Same answer. 18 Q. Did Ghislaine Maxwell work as a 19 recruiter of young girls for Jeffrey Epstein 20 when you met her? 21 A. Same answer. 22 Q. Did Ghislaine Maxwell instruct you 23 to recruit young girls for Jeffrey Epstein? 24 A. Same answer. 25 Q. Did Ghislaine Maxwell encourage Case 18-2868, Document 283, 08/09/2019, 2628241, Page159 of 883 Page 12 1 2 N. Marcinko - Confidential Ghislaine Maxwell? 3 A. Same answer. 4 Q. Have you observed Ghislaine Maxwell 5 and Jeffrey Epstein offering these young 6 girls money, education or other things of 7 value during the massage to get that young 8 girl to return to Jeffrey Epstein for sexual 9 purposes? 10 A. Same answer. 11 Q. Have you observed Ghislaine Maxwell 12 and Jeffrey Epstein convert what started as a 13 massage with these young girls into something 14 sexual? 15 A. Same answer. 16 Q. Have you understood when I talk 17 about young girls, I'm talking about girls 18 between the age range of 13 and 23 years old? 19 A. Same answer. 20 Q. Have you observed that when 21 Ghislaine Maxwell and Jeffrey Epstein used 22 the term, massage, it always includes sex? 23 A. Same answer. 24 Q. Was massage a word used by 25 Ghislaine Maxwell to lure girls into sex with Case 18-2868, Document 283, 08/09/2019, 2628241, Page160 of 883 Page 96 1 2 CERTIFICATE 3 I HEREBY CERTIFY that the witness, 4 NADIA MARCINKO, was duly sworn by me and that the deposition is a true record of the 5 6 testimony given by the witness. _______________________________ Leslie Fagin, 7 Registered Professional Reporter Dated: January 17, 2017 8 9 10 (The foregoing certification of 11 this transcript does not apply to any 12 reproduction of the same by any means, unless 13 under the direct control and/or supervision 14 of the certifying reporter.) 15 16 17 18 19 20 21 22 23 24 25 Cam: 18-7868, 782, 08/09/7010, 7678741, Pagmm nf 882 EXHIBIT 11 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page162 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: 15-cv-07433-RWS -againstGHISLAINE MAXWELL, Defendants. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 Case 18-2868, Document 283, 08/09/2019, 2628241, Page163 of 883 Page 23 1 2 3 G Maxwell - Confidential Q. I'm not talking about friends. I'm talking about individuals -- 4 MR. PAGLIUCA: I'm going to object 5 to you interrupting the witness who was 6 answering your question. 7 was, have you ever seen anyone, female 8 under the age of 18 at the house and 9 that's the question she was answering. 10 If you want to strike that question and 11 ask another question, feel free, but let 12 the witness respond, please. 13 14 MS. McCAWLEY: Q. The question I will do that. Have you ever observed a female 15 under the age of 18 at Jeffrey Epstein's home 16 that was not a friend, a child -- one of your 17 friend's children? 18 A. Again, I can't testify to that 19 because I have no idea what you are talking 20 about. 21 Q. You have no idea what I'm talking 22 about in the sense you never observed a 23 female under the age of 18 at Jeffrey 24 Epstein's home that was not one of your 25 friend's children, is that correct? Case 18-2868, Document 283, 08/09/2019, 2628241, Page164 of 883 Page 24 1 G Maxwell - Confidential 2 MR. PAGLIUCA: 3 and foundation. 4 A. Object to the form How would I possibly know how 5 someone is when they are at his house. 6 are asking me to do that. 7 testify to that. 8 everyone who came to his house was an adult 9 professional person. 10 Q. You I cannot possibly As far as I'm concerned, Are you familiar with the police 11 report that was issued in respect to the 12 investigation in this matter? 13 MR. PAGLIUCA: 14 and foundation. 15 Q. Object to the form Are you familiar with the police 16 report that was used in this matter, the 17 investigation of Jeffrey Epstein, has been 18 produced as a document in this matter? 19 A. 20 I have seen a police report. (Maxwell Exhibit 1, police report, 21 marked for identification.) 22 Q. The police report that you have in 23 front of you, can you turn to page 28 of that 24 report, the numbers are on the top right-hand 25 corner. Case 18-2868, Document 283, 08/09/2019, 2628241, Page165 of 883 Page 31 1 G Maxwell - Confidential 2 -- just another one of Virginia's many 3 fictitious lies and stories to make this a 4 salacious event to get interest and press. 5 It's absolute rubbish. 6 Q. Were you in charge of hiring 7 individuals to provide massages for Jeffrey 8 Epstein? 9 A. My job included hiring many people. 10 There were six homes. 11 assistants, I hired architects, I hired 12 decorators, I hired cooks, I hired cleaners, 13 I hired gardeners, I hired pool people, I 14 hired pilots, I hired all sorts of people. 15 As I sit here, I hired In the course and a very small part 16 of my job was from from time to time to find 17 adult professional massage therapists for 18 Jeffrey. 19 Q. When you say adult professional 20 massage therapists, where did you find these 21 massage therapists? 22 A. From time to time I would visit 23 professional spas, I would receive a massage 24 and if the massage was good I would ask that 25 man or woman if they did home visits. Case 18-2868, Document 283, 08/09/2019, 2628241, Page166 of 883 Page 41 1 G Maxwell - Confidential 2 Q. Did you hire her? 3 A. First of all, I don't hire girls 4 like that, so let's be clear, I already 5 testified to that, and I have no idea what 6 you are referring to. 7 Q. When you say girls like that, what 8 do you mean? 9 A. I hire people who are professional 10 at the house. 11 somebody to do what, I don't know what you 12 are talking about. 13 the homes. 14 Q. 15 You are asking if I hired I hired people to work in What was Nadia Marcinkova doing? MR. PAGLIUCA: 16 and foundation. 17 A. Object to the form I have no idea what Nadia 18 Marcinkova was doing. I didn't hire her and 19 I don't know what you are referring to. 20 Q. You met Nadia Marcinkova? 21 A. I testified I did. 22 Q. Did she work for Jeffrey Epstein? 23 A. I have no idea what she did. 24 Q. Have you flown on planes with Nadia 25 Marcinkova? Case 18-2868, Document 283, 08/09/2019, 2628241, Page167 of 883 Page 77 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I don't know what that means, 5 masseuse obligation, I don't know what you 6 are referring to. 7 question properly? 8 9 Q. Would you like to ask the I think it was proper. I will ask it again. 10 Did you ever assist in getting 11 Virginia Roberts a cell phone to use during 12 the time that she worked for Jeffrey Epstein? 13 14 15 A. I have no recollection of doing anything of that nature. Q. Did you ever tell Virginia that you 16 wanted her to have a cell phone so that she 17 could be on call regularly? 18 19 20 21 A. I have no recollection of that conversation. Q. How often would Virginia come over to the house in Palm Beach to give massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Ask the question again, please. 25 Q. How often did Virginia Roberts come Case 18-2868, Document 283, 08/09/2019, 2628241, Page168 of 883 Page 78 1 G Maxwell - Confidential 2 over to the house in Palm Beach to give 3 massages? 4 A. It's important to understand that I 5 wasn't with Jeffrey all the time. 6 was only in the house less than half the 7 time, so I cannot testify to when I wasn't in 8 the house how often she came when I wasn't 9 there. 10 In fact, I What I can say is that I barely 11 would remember her, if not for all of this 12 rubbish, I probably wouldn't remember her at 13 all, except she did come from time to time 14 but I don't recollect her coming as often as 15 she portrayed herself. 16 17 Q. How many times a day on an average day would Jeffrey Epstein get a massage? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. When I was at the house and when I 21 was there with him, he received a massage, on 22 average, about once a day. 23 Q. Just once? 24 A. Yes. 25 Q. Were there days when he received Case 18-2868, Document 283, 08/09/2019, 2628241, Page169 of 883 Page 79 1 2 G Maxwell - Confidential four or five? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. 6 7 When I was present at the house, I never saw something like that. Q. Do you know if Virginia was 8 required to be on call at all times to come 9 to the house if Jeffrey wanted her there? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. 13 14 I have no idea of the arrangements that Virginia made with Jeffrey. Q. When Virginia was in New York, 15 would Virginia sleep at Jeffrey's mansion in 16 New York? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. 20 21 22 I don't recollect her being in New York and I have no idea where she slept. Q. You don't ever remember seeing Virginia Roberts in New York? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I would barely recollect her at Case 18-2868, Document 283, 08/09/2019, 2628241, Page170 of 883 Page 135 1 2 3 G Maxwell - Confidential him at any of those homes? A. Again, Virginia is absolutely 4 totally lying. 5 defamation about Virginia and the lies she 6 has told and one of lies she told was that 7 President Clinton was on the island where I 8 was present. 9 a flat out total fabrication and lie. 10 Q. This is a subject of Absolutely 1000 percent that is You did fly on planes, Jeffrey 11 Epstein's planes with President Clinton, is 12 that correct? 13 A. I have flown, yes. 14 Q. Would it be fair to say that 15 16 17 President Clinton and Jeffrey are friends? A. I wouldn't be able to characterize it like that, no. 18 Q. Are they acquaintances? 19 A. I wouldn't categorize it. 20 Q. He just allowed him to use his 21 22 23 24 25 plane? A. I couldn't categorize Jeffrey's relationship. Q. When you were on the plane with Jeffrey and President Clinton, did you Case 18-2868, Document 283, 08/09/2019, 2628241, Page171 of 883 Page 144 1 G Maxwell - Confidential 2 building that you would have seen when you 3 were on the trip in Europe? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I can't possibly answer that. 7 Q. Do you recall Virginia ever taking 8 pictures? 9 A. I barely recall Virginia, period. 10 Q. Do you recall her ever taking 11 pictures? 12 A. No, I don't. 13 Q. I'm going to direct your attention, 14 still within the flight logs to -- starting 15 on the next page from where you just were 16 which is going to be 000747. 17 the top says 2001, you will see March and I'm 18 directing your attention down towards the 19 middle to the bottom where you will see the 20 numbers 27, 29 and 31. And the date at 21 A. Uh-huh. 22 Q. And we've got actually I'm going to 23 direct your attention to the one that starts 24 with TEB for Teterboro to SAF for Santa Fe 25 and the one below it Santa Fe to Palm Beach Case 18-2868, Document 283, 08/09/2019, 2628241, Page172 of 883 Page 147 1 G Maxwell - Confidential 2 her but you would have to ask Jeffrey what he 3 brought her on the trip for. 4 5 Q. But she would travel with him when there was a work trip like this? 6 A. I can't -- I'm seeing that she is 7 on this flight but I have no idea what she is 8 doing, he invited her, it would not be my 9 job. 10 11 Q. What about Nadia Bjorlin, would she regularly travel with Jeffrey on flights? 12 A. I have no idea, you would have to 13 look through the flight logs. 14 idea. 15 Q. I have no Your recollection is -- what is 16 your recollection, do you recollect Nadia 17 traveling often on flights with Jeffrey? 18 A. Absolutely not. No, not at all. I 19 don't recollect her actually on the flight at 20 all. 21 Q. 22 the moment. 23 I think you can set that aside for (Maxwell Exhibit 9, message pad 24 pages, marked for identification.) 25 Q. We will mark as Exhibit 9 these Case 18-2868, Document 283, 08/09/2019, 2628241, Page173 of 883 Page 148 1 G Maxwell - Confidential 2 excerpts from -- we will identify what they 3 are but from the message pads. 4 5 Did you want to correct anything? A. 6 7 Would you mind rereading the last question back to me? 8 9 I want to make an addendum. (Record read.) A. I also just want to say that at 10 this point I cannot recollect flying to 11 parties. 12 this in Santa Fe, this flight as well. 13 14 15 Q. Jeffrey went for work so -- was The flight we were looking at, yes but it was to Santa Fe -A. I don't recall going to any parties 16 in Santa Fe at any time but certainly flying 17 to Santa Fe for a party seems highly 18 improbable. 19 Q. So I'm going to direct your 20 attention to the document that I set before 21 you which is Bates number SAO 01456 and it 22 has different Bates numbers because it's a 23 smaller version of the larger production. 24 These are the pages I will be asking about. 25 In the time that you were working Case 18-2868, Document 283, 08/09/2019, 2628241, Page174 of 883 Page 149 1 G Maxwell - Confidential 2 with Jeffrey in Palm Beach, do you recall a 3 process for taking, anybody at the house 4 taking messages when incoming phone calls 5 came in? 6 A. You are supposed to take a message 7 and receive the message and write the message 8 down. 9 it was taken and who took it and what the 10 11 Who was the message was for, what time message was, obviously. Q. Does what's in front of you look 12 familiar with respect to the message pads 13 that you would have used at the house? 14 A. It is familiar. 15 Q. I'm going to direct your attention 16 17 to the second page of it? MR. PAGLIUCA: These all have SAO 18 numbers on them or Bates ranges and I 19 don't see any of your Bates ranges on 20 these. 21 pads but those have your Bates range 22 numbers on them and I'm wondering if 23 these are different documents. 24 25 I know you have produced message MS. McCAWLEY: It's the same, just ours have the Bates underneath them. Case 18-2868, Document 283, 08/09/2019, 2628241, Page175 of 883 Page 174 1 2 G Maxwell - Confidential believe. Do you believe -- 3 A. I can only testify -- 4 Q. Let me finish the question so the 5 record is clear. 6 Do you believe Jeffrey Epstein 7 sexually abused minors? 8 MR. PAGLIUCA: 9 Objection to the form and foundation. 10 Q. You can answer. 11 A. I can only testify to what I know. 12 I know that Virginia is a liar and I know 13 what she testified is a lie. 14 testify to what I know to be a falsehood and 15 half those falsehoods are enormous and so I 16 can only categorically deny everything she 17 has said and that is the only thing I can 18 talk about because I have no knowledge of 19 anything else. 20 Q. So I can only I'm not asking about Virginia. 21 asking whether you believe that Jeffrey 22 Epstein sexually abused minors? 23 A. I'm Again, I repeat, I can only go on 24 what I know and what I know is a falsehood 25 based on what Virginia said. Case 18-2868, Document 283, 08/09/2019, 2628241, Page176 of 883 Page 178 1 G Maxwell - Confidential 2 3 What I'm asking you is whether you believe Jeffrey Epstein abused minors? 4 MR. PAGLIUCA: I object to the form 5 and you made your record, she answered 6 the question. 7 answer is she doesn't have a belief 8 because she doesn't have any personal 9 knowledge. 10 A fair reading of her MS. McCAWLEY: Now you are 11 testifying for the witness. 12 answer the question. 13 MR. PAGLIUCA: 14 to the question. 15 A. Let her It's a fair answer Again, I testified my only personal 16 knowledge concerns Virginia and everything 17 Virginia has said is an absolute lie, which 18 is why we are here in this room. 19 asking me to testify about things I have no 20 knowledge of other than the police report 21 that you showed me, I am not in a position to 22 make a statement based on that because you 23 are asking me to speculate and I cannot 24 speculate. 25 Q. If you are I'm asking you about your belief. Case 18-2868, Document 283, 08/09/2019, 2628241, Page177 of 883 Page 179 1 G Maxwell - Confidential 2 I'm not asking you to speculate at all. 3 asking what you believe. 4 5 6 7 A. Q. I'm not asking you to speculate. I'm asking what you believe. MR. PAGLIUCA: She answered the question and we can move on. 10 11 You are asking me to speculate and I won't speculate. 8 9 I'm MS. McCAWLEY: She hasn't answered the question. 12 MR. PAGLIUCA: We are not going to 13 engage in this debate. She answered the 14 question. 15 move to compel an answer to the 16 question, have at it. 17 Q. If you want to mark it and Okay. Ms. Maxwell, is it your belief that 18 Jeffrey Epstein interacted sexually with 19 minors? 20 A. Again, you are asking me the same 21 type of question exactly but with different 22 language. 23 somebody who claims these things that I have 24 personal knowledge of is Virginia. 25 is an absolute liar and everything she has Again, my only knowledge of Virginia Case 18-2868, Document 283, 08/09/2019, 2628241, Page178 of 883 Page 180 1 G Maxwell - Confidential 2 said is a lie. 3 lies I cannot speculate on what anybody else 4 did or didn't do because if Virginia is the 5 example of what that story is and everything 6 she said is false, so everything that leads 7 from that is false. 8 9 Q. Therefore, based on those So the 30 other minor children in the police report are also telling lies about 10 being sexually abused during massages with 11 Mr. Epstein? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 show me in these police reports who the 15 30 minors are? 16 17 18 MS. McCAWLEY: Counsel, can you I'm asking my question. MR. PAGLIUCA: You are making a 19 representation about numbers, you are 20 making a representation on the record 21 about what people said or didn't say. 22 We have no knowledge about that. 23 are all redacted records so these are 24 bad questions. 25 admissible evidence. These They don't lead to any It is only being Case 18-2868, Document 283, 08/09/2019, 2628241, Page179 of 883 Page 214 1 G Maxwell - Confidential 2 A. I'm carrying on. 3 Q. I'm sorry. 4 5 I thought you were done. A. Please. Her statement also that 6 she was driven by her father to Palm Beach. 7 She was driven by her mother, as a matter of 8 fact. 9 the first meeting with Jeffrey, as I was 10 11 Her whole entire characterization of outside speaking to her mother. Q. Let me stop you there, so we don't 12 get too far ahead. 13 understand your testimony. 14 Let me make sure I The first, in the first piece when 15 you were talking, I believe you said and 16 correct me if I'm wrong, that her 17 characterization of the first meeting at 18 Mar-a-Lago was an obvious lie. 19 What part of that meeting was an 20 obvious lie? 21 A. By her own testimony, all her 22 various many different descriptions of what 23 she was or wasn't or where she was or wasn't, 24 they have all changed. 25 of house or bathroom attendant. She was either front I don't know Case 18-2868, Document 283, 08/09/2019, 2628241, Page180 of 883 Page 215 1 G Maxwell - Confidential 2 what she was, so just by her own words, one 3 doesn't know what's true and what isn't true. 4 Q. Are you saying what position she 5 said she was working in, is that what you are 6 considering the obvious lie? 7 A. I said inconsistency within her own 8 statement from everything, so in the 9 beginning it starts off with different 10 statements. 11 Q. 12 Then I believe you said the second piece was that she was driven by her father? 13 A. I said she was driven by her 14 mother. 15 Q. That's the obvious lie? 16 A. It's an obvious lie to me. 17 Q. You said why don't you state it in 18 your own words but the characterization of 19 how she was with Jeffrey, what about that is 20 an obvious lie? 21 A. I was standing outside talking to 22 her mother so the entire story is a 23 fabrication. 24 Q. 25 Did she not have sex with Jeffrey Epstein during that first massage? Case 18-2868, Document 283, 08/09/2019, 2628241, Page181 of 883 Page 220 1 2 G Maxwell - Confidential up to the room and start a massage? 3 A. He would not. 4 Q. So the young girls in the police 5 report who say they came over and were led up 6 to the room on the first day, would they be 7 wrong about that? 8 MR. PAGLIUCA: 9 Objection to form and foundation. 10 A. I can't comment what happened when 11 I was not at the house. 12 when I was at the house. 13 Q. I can only comment Was there ever a time where a woman 14 came to the house for the first time to give 15 a massage and Jeffrey had the massage that 16 day? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. 20 21 22 23 Can we talk about adult professional masseuses, please? Q. I'm asking, whether adult or underage? A. I'm not interested in talking about 24 underage. I can only testify to what I know, 25 professional masseuses, adult, I cannot Case 18-2868, Document 283, 08/09/2019, 2628241, Page182 of 883 Page 221 1 2 3 G Maxwell - Confidential testify to anything else. Q. Why can't you testify to an 4 underage girl that came over and was led up 5 to the room for a massage? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. 9 10 The police records you are referring to? Q. You are saying that didn't happen. 11 You're saying I can only testify to adults 12 that came for an interview and were led up to 13 the room. 14 an underage girl was brought in for an 15 interview and led up -- 16 MR. PAGLIUCA: Why can't you testify to whether Objection to the 17 form and foundation. 18 Q. Go ahead. 19 A. Can you reask the question. 20 Q. Why can't you testify as to an 21 underage girl who came over for an interview 22 and then was then led up to the room for the 23 massage? 24 25 A. question. You've mangled your entire Can you please reask that in a way Case 18-2868, Document 283, 08/09/2019, 2628241, Page183 of 883 Page 225 1 G Maxwell - Confidential 2 present at the home when a girl under the age 3 of 18 came over for the purposes of giving a 4 massage? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 Q. You can answer. 8 A. You can be a professional masseuse 9 at 17 in Florida, so as far as I am aware, a 10 professional masseuse showed up for a 11 massage. 12 incorrect about that and your 13 mischaracterization of it, I think is 14 unfortunate. 15 Q. There is nothing inappropriate or How many teenagers did he have that 16 were professional masseuses that worked in 17 his home? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 Q. How many? 21 A. First of all, I am not aware of 22 23 teenagers who worked in his home. Q. You are aware of Virginia Roberts 24 and you've stated she was 17 and she worked 25 for him, correct? Case 18-2868, Document 283, 08/09/2019, 2628241, Page184 of 883 Page 226 1 2 G Maxwell - Confidential A. No. I did not state that at all, 3 you are mischaracterizing my words and what I 4 said. 5 What I said was that we can all 6 agree and I think at this point there is not 7 one person in this room, however much you 8 would like her to be younger, to say she was 9 not 17 because that has been a very offensive 10 thing that you have all done. 11 At 17 you are allowed to be a professional 12 masseuse and as far as I'm concerned, she was 13 a professional masseuse. 14 inappropriate or incorrect about her coming 15 at that time to give a massage. 16 characterization of her first time at the 17 house was to me an obvious lie, given it was 18 impossible for her entire story to take place 19 given I was speaking to her mother the entire 20 she was at the house. 21 Q. So she was 17. There is nothing Her entire So it was impossible that day, that 22 first day she came and you were speaking to 23 the mother, for Virginia Roberts to have had 24 sex with Jeffrey Epstein during the time that 25 you were outside with her mother? Case 18-2868, Document 283, 08/09/2019, 2628241, Page185 of 883 Page 228 1 G Maxwell - Confidential 2 absolutely 1000 percent that she did not have 3 any type of sexual relations as described by 4 you in your court papers that took place 5 because those allegedly according to her lies 6 involved some aspect of me. 7 As I was standing outside with her 8 mother the entire time, her entire story is a 9 lie. Therefore, to ask me what she did or 10 didn't do during that time, I can only 11 testify to what she said about me, which was 12 1000 percent false. 13 14 15 Q. So let's not take the first time, let's take the next time she comes. A. No no, how can do you that, when 16 the basis of this entire horrible story that 17 you have put out is based on this first 18 appalling story that was written, repeated, 19 multiply by the press that lied about her 20 age, lied about the first time she came, lied 21 about and characterized the entire first 22 time. 23 her story and appalled by the entire 24 characterization of it and I apologize 25 sincerely for my banging at the table I have been so absolutely appalled by Case 18-2868, Document 283, 08/09/2019, 2628241, Page186 of 883 Page 229 1 G Maxwell - Confidential 2 earlier, I hope you accept my apology. 3 borne out of years of feeling the pressure of 4 this entire lie that she has perpetrated from 5 our first time and whilst I recognize that 6 was -- I hope you forgive me sincerely 7 because it was just the length of time that 8 that terrible story has been told and retold 9 and rehashed when I know it to be 100 percent 10 11 It's false. Q. So not the first time she came, but 12 the second time she came or the third time or 13 any time she came, did you ever participate 14 in a massage with her in Jeffrey Epstein's 15 room? 16 17 18 A. I have never participated at any time with Virginia in a massage with Jeffrey. Q. Have you ever participated at any 19 time with Virginia in any kind of sexual 20 contact or sexual touching with Jeffrey and 21 Virginia? 22 A. I have not. 23 Q. So we were going through the list 24 of obvious lies and you were talking about 25 the first time which I believe we have Case 18-2868, Document 283, 08/09/2019, 2628241, Page187 of 883 Page 248 1 2 3 4 5 G Maxwell - Confidential of 18? A. I think we can establish what adult would be. Q. You never interviewed or I know you 6 don't want to use the word hired, whatever 7 your role was, you brought in an exercise 8 instructor that was under the age of 18 to 9 work at the house? 10 MR. PAGLIUCA: 11 and foundation. 12 A. Object to the form I have already testified that what 13 I was responsible for was to find people who 14 had competencies in whatever area I was 15 looking for. 16 for were professional and adult. 17 Q. The competencies I was looking So there was no exercise instructor 18 that worked at the Palm Beach house or the 19 New York house or the New Mexico house or the 20 USVI under the age of 18? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. 24 25 I can only testify to when I was at the house. Q. Yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page188 of 883 Page 310 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. 5 That's not how I would characterize that. 6 Q. How would you characterize it? 7 A. I have testified that I'm 8 responsible for finding professional people 9 to work in the homes, age appropriate adult 10 people, so from pool attendants, to 11 gardeners, to chefs, to housekeepers, to 12 butlers, to chauffeurs and one of the 13 functions was to be able to answer the 14 telephones and in the context of finding 15 someone to answer the telephones, I did look 16 to try to find appropriate people to answer 17 the phones. 18 Q. 19 20 So did you find Johanna for purposes of that role? A. So in the course of looking for 21 somebody to answer phones at the house, 22 Johanna was one of the people who said that 23 she was willing to answer phones. 24 Q. 25 campus? Did you approach her at her school Case 18-2868, Document 283, 08/09/2019, 2628241, Page189 of 883 Page 383 1 2 G Maxwell - Confidential Q. List all of the girls you met and 3 brought to Jeffrey Epstein's home for the 4 purposes of employment that were under the 5 age of 18? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. 9 I've already characterized my job was to find people, adults, professional 10 people to do the jobs I listed before; pool 11 person, secretary, house person, chef, pilot, 12 architect. 13 Q. I'm asking about individuals under 14 the age of 18, not adult persons, people 15 under the age of 18. 16 A. I looked for people or tried to 17 find people to fill professional jobs in 18 professional situations. 19 20 21 22 23 24 25 Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual that you met for purposes of hiring someone for Case 18-2868, Document 283, 08/09/2019, 2628241, Page190 of 883 Page 390 1 G Maxwell - Confidential 2 MR. PAGLIUCA: 3 and foundation. 4 A. Object to the form If you want to ask Jeffrey 5 questions about me, you would have to ask 6 him. 7 8 Q. Have you ever been involved in any illegal activity in your lifetime? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. 12 I can't think of anything I have done that is illegal. 13 Q. Have you ever been arrested? 14 A. I have a DUI in the U.K. a long 15 time ago. 16 Q. 17 your record? 18 A. Yes. 19 Q. I will mark as Maxwell 22 this 20 Is that the only arrest you have on email? 21 (Maxwell Exhibit 22, email, marked 22 for identification.) 23 Q. This is dated January 21, 2015. 24 It's from Jeffrey Epstein to you, forwarding 25 the Guardian and I would like you to look at Case 18-2868, Document 283, 08/09/2019, 2628241, Page191 of 883 1 2 CERTIFICATE 3 4 5 I HEREBY CERTIFY that the witness, 6 GHISLAINE MAXWELL, was duly sworn by me and 7 that the deposition is a true record of the 8 testimony given by the witness. 9 3/ 10 Wr?cg/?j? 11 Leslle Fagf?i Registered Professional Reporter 12 Dated: April 22, 2016 13 14 15 (The foregoing certification of 16 this transcript does not apply to any 17 reproduction of the same by any means, unless 18 under the direct control and/or supervision 19 of the certifying reporterPage 416 MAG NA9 LEGAL SERVICES Case 18-2868, Document 283, 08/09/2019, 2628241, Page192 of 883 Confidential Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: 15-cv-07433-RWS -againstGHISLAINE MAXWELL, Defendant. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Continued Videotaped Deposition of GHISLAINE MAXWELL, the Defendant herein, taken pursuant to subpoena, was held at the law offices of Boies, Schiller & Flexner, LLP, 575 Lexington Avenue, New York, New York, commencing July 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 Case 18-2868, Document 283, 08/09/2019, 2628241, Page193 of 883 Confidential Page 44 1 G. Maxwell - Confidential 2 thought. 3 hard for me to testify what I thought about 4 her age at the time. 5 Q. I really don't recall her, so it's Was Virginia, in the period of 6 around 2000, the youngest person that, as you 7 understood it, was giving Mr. Epstein 8 massages? 9 MR. PAGLIUCA: 10 and foundation. 11 A. Object to the form Again, I can't testify to her age, 12 but everybody else that I can recall seemed 13 to be again, like I would say, adults. 14 15 Q. You didn't think Virginia was an adult, did you? 16 MR. PAGLIUCA: 17 and foundation. 18 A. Object to the form Like I said, I don't recall her. 19 don't recall thinking about -- my memory is 20 of adults giving Jeffrey massages, and as I 21 don't really remember Virginia around that 22 time, I don't know what I think. 23 Q. You do remember Virginia, about 24 that time back in the 2000s, giving 25 Mr. Epstein massages? I Case 18-2868, Document 283, 08/09/2019, 2628241, Page194 of 883 Confidential Page 45 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. I barely remember her at all. 5 Q. Whether you barely remember her or 6 not, you do remember that back in the period 7 around 2000, Virginia was giving Mr. Epstein 8 massages, right? 9 MR. PAGLIUCA: 10 and foundation. 11 A. Objection to form Only in the most general terms. 12 would be somebody who would give him a 13 massage, and that's it. 14 Q. During the period of time back in 15 the period around 2000, when you knew that 16 Virginia was somebody who would give 17 Mr. Epstein a massage, was she somebody who 18 you considered an adult? 19 MR. PAGLIUCA: 20 and foundation. 21 A. Objection to form I didn't consider her at all 22 because she is not somebody that I really 23 interacted with. 24 25 Q. It It is your testimony that Virginia was not somebody that you interacted with, is Case 18-2868, Document 283, 08/09/2019, 2628241, Page195 of 883 Confidential Page 55 01 (A) G. Maxwell Confidential Epstein's home in Palm Beach? MR. PAGLIUCA: Objection to form and foundation. MAG NAQ LEGALSERVKES Case 18-2868, Document 283, 08/09/2019, 2628241, Page196 of 883 Confidential Page 56 1 G. Maxwell Confidential MAG NA9 LEGALSERVKES Case 18-2868, Document 283, 08/09/2019, 2628241, Page197 of 883 Confidential Page 57 1 G. Maxwell Confidential 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 I 8 MR. PAGLIUCA: Objection to form 9 and foundationMAG NA9 LEGAL SERVICES Case 18-2868, Document 283, 08/09/2019, 2628241, Page198 of 883 Confidential Page 58 1 2 G. Maxwell - Confidential Q. 7 11 20 21 22 23 24 MR. PAGLIUCA: and foundation. Objection to form Case 18-2868, Document 283, 08/09/2019, 2628241, Page199 of 883 Confidential Page 86 1 G. Maxwell - Confidential 2 and foundation. 3 A. 4 Q. 8 9 10 No. MR. PAGLIUCA: Objection to form and foundation. A. I don't know. 11 17 MR. PAGLIUCA: Objection to form 18 and foundation. 19 A. No. 20 Q. Were they ever in the Virgin 21 Islands? 22 MR. PAGLIUCA: 23 and foundation. 24 A. 25 Asked and answered. No. Objection to form Case 18-2868, Document 283, 08/09/2019, 2628241, Page200 of 883 Confidential Page 87 1 8 17 23 24 25 MR. PAGLIUCA: and foundation. Objection to form Case 18-2868, Document 283, 08/09/2019, 2628241, Page201 of 883 Confidential Page 91 1 2 G. Maxwell - Confidential it to something in the case. 3 MR. BOIES: I think it's tied, but 4 if you instruct her not to answer, it 5 goes into the -- 6 7 8 MR. PAGLIUCA: Meat grinder. BY MR. BOIES: Q. . 14 A. 15 Q. 20 MR. PAGLIUCA: 21 A. 22 Q. 24 Can you repeat the question? No. Same objection. Case 18-2868, Document 283, 08/09/2019, 2628241, Page202 of 883 Confidential Page 197 1 2 CERTIFICATE 3 4 5 I HEREBY CERTIFY that GHISLAINE 6 MAXWELL, was duly sworn by me and that the 7 deposition is a true record of the testimony 8 given by the witness. 9 10 {37/ _?4Lg 11 LesYie Fag in, Registered Professional Reporter 12 Dated: July 22, 2016 13 14 15 (The foregoing certification of 16 this transcript does not apply to any 17 reproduction of the same by any means, unless 18 under the direct control and/or supervision 19 of the certifying reporterMAG NA9 LEGAL SERVICES Cam: 18-7868, 782, 08/00/7010, 7678741, Pag9702 nf 882 EXHIBIT 12 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page204 of 883 GI UFFRE VS. IMAXWELL mm YNN TR UDE MILLER 05/24/201 6 Agren Blando Court Reporting Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-001 7 Case 18-2868, Document 283, 08/09/2019, 2628241, Page205 of 883 ×Ò ÌØÛ ËÒ×ÌÛÜ ÍÌßÌÛÍ Ü×ÍÌÎ×ÝÌ ÝÑËÎÌ ÍÑËÌØÛÎÒ Ü×ÍÌÎ×ÝÌ ÑÚ ÒÛÉ ÇÑÎÕ Ý·ª·´ ß½¬·±² Ò±ò ïëó½ªóðéìííóÎÉÍ ÝÑÒÚ×ÜÛÒÌ×ßÔ Ê×ÜÛÑÌßÐÛÜ ÜÛÐÑÍ×Ì×ÑÒ ÑÚ ÔÇÒÒ ÌÎËÜÛ Ó×ÔÔÛÎ Ó¿§ îìô îðïê Ê×ÎÙ×Ò×ß Ôò Ù×ËÚÚÎÛô д¿·²¬·ººô ªò ÙØ×ÍÔß×ÒÛ ÓßÈÉÛÔÔô Ü»º»²¼¿²¬ò ßÐÐÛßÎßÒÝÛÍæ ÍòÖò ÏË×ÒÒÛÇ ÝÑÔÔÛÙÛ ÑÚ ÔßÉô ËÒ×ÊÛÎÍ×ÌÇ ÑÚ ËÌßØ Þ§ п«´ Ùò Ý¿--»´´ô Û-¯ò íèí Íò ˲·ª»®-·¬§ ͬ®»»¬ Í¿´¬ Ô¿µ» Ý·¬§ô ËÌ èìïïî и±²»æ èðïòëèëòëîðî Ý¿--»´´°à´¿©ò«¬¿¸ò»¼« ß°°»¿®·²¹ ±² ¾»¸¿´º ±º ¬¸» д¿·²¬·ºº ØËÌÝØ×ÒÍÑÒ ÞÔßÝÕ ßÒÜ ÝÑÑÕô ÔÔÝ Þ§ Ö±¸² Ý´«²»ô Û-¯ò çîï É¿´²«¬ ͬ®»»¬ Í«·¬» îðð Þ±«´¼»®ô ÝÑ èðíðî и±²»æ íðíòììîòêëïì ½´«²»à¸¾½¾±«´¼»®ò½±³ ß°°»¿®·²¹ ±² ¾»¸¿´º ±º ¬¸» Ü»°±²»²¬ Case 18-2868, Document 283, 08/09/2019, 2628241, Page206 of 883 ï î í ì ë ê é è ç ïð ïï ïî ïí ïì ïë ïê ïé ïè ïç îð îï îî îí îì îë ßÐÐÛßÎßÒÝÛÍæ øݱ²¬·²«»¼÷ ØßÜÜÑÒô ÓÑÎÙßÒ ßÒÜ ÚÑÎÓßÒô ÐòÝò Þ§ Ô¿«®¿ ßò Ó»²²·²¹»®ô Û-¯ò Ö»ºº®»§ Íò п¹´·«½¿ô Û-¯ò ïëð Û¿-¬ ï𬸠ߪ»²«» Ü»²ª»®ô ÝÑ èðîðí и±²»æ íðíòèíïòéíêì ´³»²²·²¹»®à¸³º´¿©ò½±³ ¶°¿¹´·«½¿à¸³º´¿©ò½±³ ß°°»¿®·²¹ ±² ¾»¸¿´º ±º ¬¸» Ü»º»²¼¿²¬ ß´-± Ю»-»²¬æ Ó¿®§ª±²²» ̱³°µ·²-ô Ê·¼»±¹®¿°¸»® Case 18-2868, Document 283, 08/09/2019, 2628241, Page207 of 883 ï ß Þ»½¿«-» × ©¿-²ù¬ ¬±´¼ ¿²§ ¼·ºº»®»²¬ò î Ï Ü± §±« µ²±© ©¸»®» ¿²§ óó ¿²§ -±«®½» ±º í ¬¸¿¬ ·²º±®³¿¬·±² ½¿³» º®±³á ì ß ×¬ ½¿³» º®±³ ͵§ò ë Ï Ñµ¿§ò É¿- ·¬ ͵§á ß²¼ ©¸¿¬ ¼± §±« ®»½¿´´ ¸·³ ¬»´´·²¹ ê §±« ¿¾±«¬ ©¸»² Ê·®¹·²·¿ -¬±°°»¼ ©±®µ·²¹ ¿¬ é Ó¿®ó¿óÔ¿¹±á è ß ç ïð ͸» ©¿- ·² ¿ ¼·-½«--·±² ©·¬¸ Ó®-ò Ó¿¨©»´´ ¬± »¼«½¿¬» ¸»® ¿²¼ ¬¿µ» ¸»® «²¼»® ¸»® ©·²¹ ¿²¼ ¾» ¸»® ²»© ³±³³¿ò ̸¿¬ù- ©¸¿¬ × ¸»¿®¼ò ïï Ï Ñµ¿§ò ïî ß Íµ§ò ïí Ï Ñµ¿§ò ïì ß²¼ ©¸± ¬±´¼ §±« ¬¸¿¬á ß²¼ ¼± §±« ®»³»³¾»® ©¸»² ͵§ ¬±´¼ §±« ¬¸¿¬á ïë ß × ¼±²ù¬ ®»³»³¾»®ò ïê Ï Ñµ¿§ò ïé ¬¸¿¬ô ±¬¸»® ¬¸¿² ©¸¿¬ §±« ¶«-¬ -¿·¼á ïè ß Ò±ò ïç Ï Ñµ¿§ò îð Ü·¼ §±« ´»¿®² ¿²§¬¸·²¹ »´-» ¿¾±«¬ ܱ §±« µ²±© ©¸»®» -¸» ©»²¬ ¬± ©±®µ ¿º¬»® Ó¿®ó¿óÔ¿¹±á îï ß × ¬¸·²µ -¸» ©»²¬ ©·¬¸ Ó®-ò Ó¿¨©»´´ò îî Ï Þ«¬ ¼± §±« µ²±© ©¸»®»ô °¸§-·½¿´´§á îí ß Ð¸§-·½¿´´§ô ͵§ ¿²¼ × ¼®±°°»¼ ¸»® ±ºº ±²» îì ¼¿§ ¿¬ Ó®-ò Ó¿¨©»´´ù-ò îë Ó®-ò Ó¿¨©»´´ò × ¼·¼ ²±¬ -°»¿µ ©·¬¸ × ¼·¼²ù¬ ¸¿ª» ¿²§¬¸·²¹ ¬± -¿§ ¬± ¸»®ò Case 18-2868, Document 283, 08/09/2019, 2628241, Page208 of 883 ï ÍÌßÌÛ ÑÚ ÝÑÔÑÎßÜÑ÷ î ÷ í ÝÑËÒÌÇ ÑÚ ÜÛÒÊÛÎ ÷ ì --ò ÎÛÐÑÎÌÛÎùÍ ÝÛÎÌ×Ú×ÝßÌÛ ×ô Õ»´´§ ßò Ó¿½µ»®»¬¸ô ¼± ¸»®»¾§ ½»®¬·º§ ë ¬¸¿¬ × ¿³ ¿ λ¹·-¬»®»¼ Ю±º»--·±²¿´ λ°±®¬»® ¿²¼ ê Ò±¬¿®§ Ы¾´·½ ©·¬¸·² ¬¸» ͬ¿¬» ±º ݱ´±®¿¼±å ¬¸¿¬ é °®»ª·±«- ¬± ¬¸» ½±³³»²½»³»²¬ ±º ¬¸» »¨¿³·²¿¬·±²ô ¬¸» è ¼»°±²»²¬ ©¿- ¼«´§ -©±®² ¬± ¬»-¬·º§ ¬± ¬¸» ¬®«¬¸ò ç × º«®¬¸»® ½»®¬·º§ ¬¸¿¬ ¬¸·- ¼»°±-·¬·±² ©¿- ï𠬿µ»² ·² -¸±®¬¸¿²¼ ¾§ ³» ¿¬ ¬¸» ¬·³» ¿²¼ °´¿½» ¸»®»·² ïï -»¬ º±®¬¸ô ¬¸¿¬ ·¬ ©¿- ¬¸»®»¿º¬»® ®»¼«½»¼ ¬± ïî ¬§°»©®·¬¬»² º±®³ô ¿²¼ ¬¸¿¬ ¬¸» º±®»¹±·²¹ ½±²-¬·¬«¬»- ïí ¿ ¬®«» ¿²¼ ½±®®»½¬ ¬®¿²-½®·°¬ò ïì × º«®¬¸»® ½»®¬·º§ ¬¸¿¬ × ¿³ ²±¬ ®»´¿¬»¼ ¬±ô ïë »³°´±§»¼ ¾§ô ²±® ±º ½±«²-»´ º±® ¿²§ ±º ¬¸» °¿®¬·»- ±® ïê ¿¬¬±®²»§- ¸»®»·²ô ²±® ±¬¸»®©·-» ·²¬»®»-¬»¼ ·² ¬¸» ïé ®»-«´¬ ±º ¬¸» ©·¬¸·² ¿½¬·±²ò ïè ïç îð ײ ©·¬²»-- ©¸»®»±ºô × ¸¿ª» ¿ºº·¨»¼ ³§ -·¹²¿¬«®» ¬¸·- íï-¬ ¼¿§ ±º Ó¿§ô îðïêò Ó§ ½±³³·--·±² »¨°·®»- ß°®·´ îïô îðïçò îï îî îí îì îë Õ»´´§ ßò Ó¿½µ»®»¬¸ô ÝÎÎô ÎÐÎô ÝÍÎ îïê ó ïꬸ ͬ®»»¬ô Í«·¬» êðð Ü»²ª»®ô ݱ´±®¿¼± èðîðî Cam: 18-7868, 782, 08/00/7010, 7678741, Pag970q nf 882 EXHIBIT 13 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page210 of 883 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 283, 08/09/2019, 2628241, Page211 of 883 Page 25 1 2 3 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Q. All right. 4 Was SG a licensed massage therapist? 5 MR. PAGLIUCA: 6 foundation. 7 8 9 10 Object to form and THE WITNESS: No. BY MR. EDWARDS: Q. And at 14 years old, are you permitted to be a licensed massage therapist? 11 A. Not to my knowledge. 12 Q. After speaking with SG and understanding 13 her account of what took place at Jeffrey Epstein's 14 home, what -- what happened next in the 15 investigation? 16 A. At some point the investigation was turned 17 over to me for follow-up. 18 pulled that was done prior to -- and surveillance 19 that was done prior to the case being turned over to 20 me; and trash pulls being an investigative technique 21 to acquire intelligence, information and evidence. 22 Q. Okay. I know there was trash If we go to page 17, at the top, 23 and, first of all, I will ask you from memory, do 24 you remember if 25 Epstein in a photo lineup? identified Jeffrey Case 18-2868, Document 283, 08/09/2019, 2628241, Page212 of 883 Page 27 1 2 JOSEPH RECAREY - CONFIDENTIAL "a cross-reference"? 3 A. Uh-huh. 4 Q. How is a cross-reference performed? 5 6 What does that mean? A. When -- when something is 7 cross-referenced, they -- they jot down license 8 plate numbers. 9 the individuals; photographs, computer research. 10 11 12 Q. They conduct their background into A cross-reference of Jeffrey Epstein's residence revealed which affiliated names? A. It revealed Nadia Marcinkova, Ghislane 13 Maxwell, Mark Epstein. 14 any previous reports from the residence as well. 15 Q. Also, the cross-reference, During your investigation, did you learn 16 of any involvement that Nadia Marcinkova had with 17 any of the activities you were investigating? 18 19 MR. PAGLIUCA: foundation. 20 21 22 23 24 25 Object to form and THE WITNESS: Yes. BY MR. EDWARDS: Q. And what involvement did you learn of Nadia Marcinkova? MR. PAGLIUCA: foundation. Object to form and Case 18-2868, Document 283, 08/09/2019, 2628241, Page213 of 883 Page 28 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 4 5 6 THE WITNESS: with one of the victims at Epstein's request. BY MR. EDWARDS: Q. Okay. A. AH. 8 Q. Okay. 10 11 14 is that possible as well? A. Yes. MR. PAGLIUCA: BY MR. EDWARDS: Q. 16 mind is AH? 17 21 22 Okay. The one that you remember in your MR. PAGLIUCA: Object to form and foundation. 19 20 Object to form and foundation. 15 18 If it indicates in the report that she was also sexually involved with other victims, 12 13 Do you remember which victim you're remembering right now? 7 9 Nadia was involved sexually THE WITNESS: Correct. BY MR. EDWARDS: Q. The other name that is on here as a cross-reference is Ghislane Maxwell. 23 Did you speak with Ghislane Maxwell? 24 A. I did not. 25 Q. Did you ever attempt to speak with Case 18-2868, Document 283, 08/09/2019, 2628241, Page214 of 883 Page 29 1 2 3 JOSEPH RECAREY - CONFIDENTIAL Ghislane Maxwell? A. I wanted to speak with everyone related to 4 this home, including Ms. Maxwell. 5 through Gus, Attorney Gus Fronstin, at the time, who 6 initially had told me that he would make everyone 7 available for an interview. 8 conversations later, no one was available for 9 interview and everybody had an attorney, and I was 10 11 My contact was And subsequent not going to be able to speak with them. Q. Okay. During your investigation, what did 12 you learn in terms of Ghislane Maxwell's 13 involvement, if any? 14 15 MR. PAGLIUCA: Object to form and foundation. 16 THE WITNESS: Ms. Maxwell, during her 17 research, was found to be Epstein's long-time 18 friend. 19 involved in seeking girls to perform massages 20 and work at Epstein's home. 21 22 23 24 25 During the interviews, Ms. Maxwell was MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. Did you interview -- how many girls did you interview that were sought to give or that Case 18-2868, Document 283, 08/09/2019, 2628241, Page215 of 883 Page 30 1 2 JOSEPH RECAREY - CONFIDENTIAL actually gave massages at Epstein's home? 3 4 5 6 MR. PAGLIUCA: foundation. BY MR. EDWARDS: Q. Approximately. 7 MR. PAGLIUCA: 8 THE WITNESS: 9 10 11 Q. And of the 30, 33 or so girls, how many 13 MR. PAGLIUCA: 18 19 20 21 22 THE WITNESS: I believe two of them may have been -- two of them. BY MR. EDWARDS: Q. Okay. And as we go through this report, you may remember the names? A. Correct. Let me correct myself. I believe only one had. Q. And was that -- was that one of similar 23 age to the other girls? 24 MR. PAGLIUCA: 25 Object to form and foundation. 15 17 I would say approximately BY MR. EDWARDS: had massage experience? 16 Same objection. 30; 30, 33. 12 14 Object to form and foundation. Object to form and Case 18-2868, Document 283, 08/09/2019, 2628241, Page216 of 883 Page 40 1 2 JOSEPH RECAREY - CONFIDENTIAL foundation. 3 4 5 6 THE WITNESS: Yes, I did. BY MR. EDWARDS: Q. And were trash pulls done at the property of Jeffrey Epstein? 7 A. Yes. 8 Q. What is the purpose of a trash pull, and 9 10 what is a trash pull? A. A trash pull is when property is 11 discarded, such as trash, we coordinate with the 12 sanitation department to collect the trash, once it 13 leaves the property, and it's put into an empty well 14 of the trash truck. 15 sift through the contents of the trash. 16 Q. We acquire the bags, and we Did you or another detective from the unit 17 observe each step of the trash pull to make sure 18 that you had a good chain of custody of the 19 evidence? 20 21 MR. PAGLIUCA: foundation. 22 23 24 25 Object to form and THE WITNESS: Yes. The members of the OCTAN unit at that time did. BY MR. EDWARDS: Q. Okay. And what is that process? Case 18-2868, Document 283, 08/09/2019, 2628241, Page217 of 883 Page 41 1 2 JOSEPH RECAREY - CONFIDENTIAL A. 3 4 The process -MR. PAGLIUCA: Object to form and foundation. 5 THE WITNESS: The process is when the -- 6 once you coordinate a trash pull with the 7 sanitation supervisor, you meet with the 8 sanitation worker and ensure that either the 9 can that he's going to place in the well is 10 completely empty and you physically observe him 11 collect the trash and place it into the empty 12 container. 13 disclosed area, and we retrieve the bags and 14 you sift through the trash. 15 16 17 BY MR. EDWARDS: Q. Okay. What were you looking for in terms of evidentiary value from these trash pulls? 18 19 And then you follow him to a MR. PAGLIUCA: Object to form and foundation. 20 THE WITNESS: We were looking for any -- 21 any form of identification. 22 for -- to gather any kind of intelligence 23 and/or evidence. 24 25 You were looking BY MR. EDWARDS: Q. Okay. If we go to page 20 of the report, Case 18-2868, Document 283, 08/09/2019, 2628241, Page218 of 883 Page 42 1 JOSEPH RECAREY - CONFIDENTIAL 2 I guess I'll start with where it says on 4/4/2005, I 3 just want to ask you, was a voice mail message taken 4 into evidence from HR to SG? 5 A. Yes. 6 Q. Okay. 7 to corroborate what? 8 9 And the purpose of that evidence is MR. PAGLIUCA: Object to form and foundation. 10 THE WITNESS: It was actually a phone call 11 from HR to SG confirming an appointment to go 12 work at Epstein's residence. 13 14 15 16 BY MR. EDWARDS: Q. The next line down is what I wanted to focus on, April 5th, 2005. This trash pull, what evidence is yielded 17 from this particular trash pull? 18 MR. PAGLIUCA: 19 20 Object to form and foundation. THE WITNESS: The trash pull indicated 21 that there were several messages with written 22 items on it. 23 indicating that there would be an 11:00 24 appointment. 25 had called during that day. There was a message from HR There were other individuals that Case 18-2868, Document 283, 08/09/2019, 2628241, Page219 of 883 Page 43 1 2 3 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Q. And when you would -- when you would see 4 females' names and telephone numbers, would you take 5 those telephone numbers and match it to -- to a 6 person? 7 8 MR. PAGLIUCA: foundation. 9 10 11 12 Object to form and THE WITNESS: We would do our best to identify who that person was. BY MR. EDWARDS: Q. And is that one way in which you 13 discovered the identities of some of the other what 14 soon came to be known as victims? 15 MR. PAGLIUCA: 16 foundation. 17 18 19 Object to form and THE WITNESS: Correct. BY MR. EDWARDS: Q. Okay. There's the second paragraph from 20 the bottom, it starts, "Detective Leigh provided 21 trash from 4/06, 4/07/2005." 22 Do you see that? 23 A. Yes. 24 Q. And what is the purpose of the indication 25 that "the following information was retrieved: Jet Case 18-2868, Document 283, 08/09/2019, 2628241, Page220 of 883 Page 45 1 2 3 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Q. And then some of the remaining messages, 4 "Johanna, work Sunday at 4 p.m.; A, Monday after 5 school; left message for Courtney W and NT," are 6 these individuals that you later learned were 7 underaged girls that had been to Jeffrey Epstein's 8 home? 9 10 MR. PAGLIUCA: foundation. 11 12 13 Object to form and THE WITNESS: That's correct. BY MR. EDWARDS: Q. What types of documents do you remember 14 retrieving from the trash pulls from Jeffrey 15 Epstein's home? 16 A. There was numerous items. It was a lot of 17 handwritten notes on different -- different pads of 18 paper. 19 was Epstein, whether it was Ghislane Maxwell, 20 whether it was -- there were phone messages. 21 Some of the pads had names on it, whether it When I say "phone messages," I mean, you 22 know, the kind that come in a book. They are carbon 23 copied, so the yellow copy always stays with the 24 book, but the white copy is torn off. 25 always a carbon copy of the actual phone message. So there was Case 18-2868, Document 283, 08/09/2019, 2628241, Page221 of 883 Page 72 1 JOSEPH RECAREY - CONFIDENTIAL 2 3 4 5 THE WITNESS: Correct. BY MR. EDWARDS: Q. And let me go back to the beginning six pages of that exhibit, No. 4. 6 MR. PAGLIUCA: Why don't we just make a 7 copy of it now if we're going to ask questions 8 about it? 9 10 I'm not trying to -- MR. EDWARDS: Yes, I know. It's just the first six pages. 11 (A discussion was held off the record, 12 after which the following proceedings were 13 held:) 14 15 16 THE VIDEOGRAPHER: On the record at 10:32. BY MR. EDWARDS: Q. And what were some of the items that were 17 found in -- well, are the documents that you're 18 holding, 1 through 6, an accurate reflection of the 19 items that were found in Jeffrey Epstein's home 20 during the search warrant execution? 21 22 MR. PAGLIUCA: foundation. 23 24 25 Object to form and THE WITNESS: Yes. BY MR. EDWARDS: Q. And I believe that you described that some Case 18-2868, Document 283, 08/09/2019, 2628241, Page222 of 883 Page 73 1 JOSEPH RECAREY - CONFIDENTIAL 2 of the -- that the house appeared to be -- I don't 3 remember the word you used -- sanitized, for lack of 4 a better word? 5 6 7 MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: 8 Q. How did you know that? 9 A. The computers had been removed from the 10 11 12 13 home. Q. How did you know the computers were removed? A. Based on -- based on the dangling wires 14 left behind, the monitors left, but the actual CPU 15 of it was missing. 16 When you went into the bedroom of Jeffrey 17 Epstein, everything was removed from the -- the 18 shelves, from the armoire. 19 Q. Did you find nude photographs of girls? 20 A. Yes. 21 Q. All right. 22 23 24 25 And what did you do with that evidence? A. That was collected and placed into our crime scene unit. Q. And where is that evidence today? Case 18-2868, Document 283, 08/09/2019, 2628241, Page223 of 883 Page 74 1 2 3 4 JOSEPH RECAREY - CONFIDENTIAL A. Any evidence that was not returned to its rightful owner was turned over to the FBI. Q. And evidence which would be nude 5 photographs of girls would be evidence not turned 6 back over to Epstein? 7 A. 8 9 Correct. MR. PAGLIUCA: Object to form and foundation. 10 THE WITNESS: Some of the items that were 11 collected were later found to be personal items 12 of the houseman, Janush. 13 his personal photographs on -- on a micro SD 14 card for, like, photos of him and his wife or 15 girlfriend at the time. 16 17 I recall reviewing BY MR. EDWARDS: Q. And the underaged girls that you had 18 spoken with during your investigation, had they 19 described seeing photographs of naked girls in the 20 house? 21 22 MR. PAGLIUCA: foundation. 23 24 25 Object to form and THE WITNESS: Yes, they did. BY MR. EDWARDS: Q. That's something that ran consistent with Case 18-2868, Document 283, 08/09/2019, 2628241, Page224 of 883 Page 78 1 2 3 4 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Q. MR. PAGLIUCA: 9 THE WITNESS: Q. of whose property is that? MR. PAGLIUCA: 16 17 Object to form and foundation. 14 15 All right. And where were those taken from, in terms 12 13 Correct. BY MR. EDWARDS: 10 11 Object to form and foundation. 7 8 Also reflected are the property receipts? 5 6 Okay. THE WITNESS: This would have been taken from the home of Jeffrey Epstein. BY MR. EDWARDS: Q. And in reviewing that evidence, were you 18 able to substantiate or corroborate certain victims' 19 accounts of their allegations of having been at the 20 house? 21 22 MR. PAGLIUCA: foundation. 23 24 25 Object to form and THE WITNESS: Correct. BY MR. EDWARDS: Q. Did you find names of other witnesses and Case 18-2868, Document 283, 08/09/2019, 2628241, Page225 of 883 Page 79 1 JOSEPH RECAREY - CONFIDENTIAL 2 people that you knew to have been associated with 3 the house in those message pads? 4 MR. PAGLIUCA: 5 foundation. 6 7 8 9 10 THE WITNESS: Yes. BY MR. EDWARDS: Q. And so what was the evidentiary value to you of the message pads collected from Jeffrey Epstein's home in the search warrant? 11 12 Object to form and MR. PAGLIUCA: Object to form and foundation. 13 THE WITNESS: It was very important to 14 corroborate what the victims had already told 15 me as to calling in and for work. 16 17 BY MR. EDWARDS: Q. Okay. And did you learn the identities of 18 some of the other individuals associated with 19 Jeffrey Epstein through the review of that 20 particular evidence? 21 22 MR. PAGLIUCA: foundation. 23 24 25 Object to form and THE WITNESS: Correct. BY MR. EDWARDS: Q. Okay. And what did you do with that Case 18-2868, Document 283, 08/09/2019, 2628241, Page226 of 883 Page 83 1 2 3 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Q. In these messages, did you see messages 4 that were taken by Ghislane Maxwell or left for 5 Ghislane Maxwell? 6 7 MR. PAGLIUCA: foundation. 8 9 10 11 Object to form and THE WITNESS: I do recall seeing messages utilizing her pad, her stationery. BY MR. EDWARDS: Q. Okay. Do you remember messages 12 specifically that Ms. Maxwell, she is home, or calls 13 for Ms. Maxwell, or indicating that the person 14 taking the message is GM? 15 A. 16 17 18 19 Do you remember those? Yes. MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. And did that give you further reason to 20 want to speak to Ghislane Maxwell? 21 MR. PAGLIUCA: 22 23 Object to form and foundation. THE WITNESS: Correct. I wanted to speak 24 with everyone in the home and everyone 25 associated with Jeffrey Epstein. Case 18-2868, Document 283, 08/09/2019, 2628241, Page227 of 883 Page 97 1 JOSEPH RECAREY - CONFIDENTIAL 2 anything that's found that has any kind of 3 identifiers, any kind of names, phone numbers, 4 anything that could be used to identify further 5 victims and/or to corroborate what the information 6 we already obtained, that information would be kept. 7 Q. Okay. 8 A. Be followed up on. 9 Q. You testified earlier about certain pieces 10 of paper that had Ghislane Maxwell's name on it that 11 were obtained. 12 Are the documents that are listed, the 13 first one, two, three, four pages of Exhibit 8, some 14 of the documents that you're referring to? 15 16 MR. PAGLIUCA: foundation. 17 18 19 Object to form and THE WITNESS: That is correct. BY MR. EDWARDS: Q. And if we go through this stack of 20 documents, if you could just review them and tell me 21 if these are some of the items obtained through the 22 trash pulls at Jeffrey Epstein's home? 23 24 25 MR. PAGLIUCA: Object to form and foundation. THE WITNESS: That is correct. This is -- Case 18-2868, Document 283, 08/09/2019, 2628241, Page228 of 883 Page 98 1 JOSEPH RECAREY - CONFIDENTIAL 2 these items were collected in the trash pull. 3 4 5 BY MR. EDWARDS: Q. MR. PAGLIUCA: 10 Object to form and foundation. 8 9 And these are items that you felt had some evidentiary value? 6 7 Okay. THE WITNESS: Yes. BY MR. EDWARDS: Q. Were there other items within the trash 11 that were discarded as not having any apparent 12 evidentiary value? 13 A. Correct. There was stuff like food trash 14 we're not going to keep. 15 None of that's going to be kept. 16 17 18 Q. Okay. You know, an apple core. And when you took this stuff into evidence, how was it maintained? A. It was placed in a -- in a sealed 19 container, a sealed Ziploc, and placed into 20 evidence. 21 22 23 24 25 Q. And then was that file later transferred to the State Attorney's Office or the FBI? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: It was collected by the FBI. Case 18-2868, Document 283, 08/09/2019, 2628241, Page229 of 883 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 Cam: 18-7868, 782, 08/00/7010, 7678741, Pag9720 nf 882 EXHIBIT 14 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page231 of 883 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: 15-cv-07433-RWS -againstGHISLAINE MAXWELL, Defendant. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Videotaped deposition of RINALDO RIZZO, taken pursuant to subpoena, was held at the law offices of Boies Schiller & Flexner, 333 Main Street, Armonk, New York, commencing June 10, 2016, 10:06 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 Case 18-2868, Document 283, 08/09/2019, 2628241, Page232 of 883 Page 25 1 R. Rizzo - Confidential 2 even Nadia. 3 out of the ordinary, was Nadia was wearing a 4 swimsuit that was very revealing and 5 basically, her bottom basically went up her 6 butt, revealing all of her buttocks. 7 again, in the context not very appropriate 8 for the situation. 9 Q. And what I found very repulsive, So Could you tell the relationship of 10 age between the three girls that you have 11 described and Nadia, for instance? 12 MR. PAGLIUCA: 13 and foundation. 14 A. 15 16 Object to the form Nadia seemed to be a bit older, I would say. Q. How does this end, or is there, 17 what do you do next? 18 that you've just described break up? 19 A. How does this meeting I asked to excuse myself and asked 20 where the bathroom was, so I'm pointed inside 21 the house, to go inside the house to the 22 bathroom. 23 I walk in there, and I walk, as I'm 24 walking to the bathroom, what caught my eye, 25 and I had to take a double lock, there were Case 18-2868, Document 283, 08/09/2019, 2628241, Page233 of 883 Page 26 1 R. Rizzo - Confidential 2 pictures of naked women, half-dressed girls. 3 So I went to the bathroom, again, from 4 someone, myself working in private service, I 5 always know in houses there are cameras, so 6 again, I was very reluctant to stare, because 7 you never know when you are on camera. 8 So I used the bathroom, and I came 9 out, and you know, curiosity got the best of 10 me, and I leaned over and started looking at 11 these pictures for a brief minute, and it was 12 just so coincidental that as I did that, Ms. 13 Maxwell enters, and she immediately says to 14 me that Jeffrey would like for me to rejoin 15 the party immediately. 16 17 Q. How many pictures of nude females did you see in Jeffrey Epstein's home? 18 MR. PAGLIUCA: Object to the form 19 and foundation. 20 A. I can't recall the exact number. 21 Q. Can you describe the pictures that 22 you saw in terms of what the people, what the 23 people or person within the picture was 24 wearing, what the age range would be of the 25 person that's in the photograph, any poses, Case 18-2868, Document 283, 08/09/2019, 2628241, Page234 of 883 Page 52 1 R. Rizzo - Confidential 2 Q. Did you learn whether your 3 perception was correct? 4 MR. PAGLIUCA: Same objection. 5 A. It was younger. 6 Q. How old was this girl? 7 A. 15 years old. 8 Q. What happens next when Ghislaine 9 10 Yes, I did. Maxwell and Jeffrey Epstein and a 15-year-old girl walk into Eva Anderson's home? 11 MR. PAGLIUCA: 12 Foundation. 13 A. Object to the form. They proceed into the dining room 14 area, which is across from the living room 15 area. 16 conversation start. 17 not hear any particulars about the 18 conversation whatsoever. I go into the kitchen and I hear a 19 Very muffled, I could My wife and I are in the kitchen 20 preparing the evening meal. 21 young girl into the kitchen. 22 there is an island with three barstools. 23 instructs the young girl to sit to the 24 furthest barstool on the right. 25 Q. Eva brings the In the kitchen, Describe for me what the girl Eva Case 18-2868, Document 283, 08/09/2019, 2628241, Page235 of 883 Page 53 1 R. Rizzo - Confidential 2 looked like, including her demeanor and 3 anything else you remember about her when she 4 walks into the kitchen. 5 A. Very attractive, beautiful young 6 girl. Makeup, very put together, casual 7 dress. 8 distraught, and she was shaking, and as she 9 sat down, she sat down and sat in the stool But she seemed to be upset, maybe 10 exactly the way the girls that I mentioned to 11 you sat at Jeffrey's house, with no 12 expression and with their head down. 13 could tell that she was very nervous. 14 15 16 17 Q. But we What do you mean by distraught and shaking, what do you mean by that? A. Shaking, I mean literally quivering. 18 Q. What happens next? 19 A. We were, again, the absurdity, 20 never introduced. Like you would walk into a 21 room and say this is -- so my wife and I are 22 in the kitchen and this young girl is sitting 23 there. 24 I look at my wife. 25 moment, and so I introduced myself and I It was a very uncomfortable moment. And so I want to ease the Case 18-2868, Document 283, 08/09/2019, 2628241, Page236 of 883 Page 54 1 R. Rizzo - Confidential 2 introduced my wife, and she doesn't really 3 respond. 4 And I asked her, are you okay? And 5 she doesn't really respond. Nothing verbal, 6 no cues, her head is still down. 7 if she would like some water, tissue, 8 anything, and she basically doesn't respond. I ask her 9 Q. You ask her for a tissue? 10 A. If she would like a tissue or some 11 water at the time. 12 Q. Was she crying at the time? 13 A. My perception, she was on the verge 14 of crying. 15 situation every way I know how, so the only 16 way I knew how, and I thought maybe this will 17 comfort her, I said oh, by the way, do you 18 work for Jeffrey. 19 And I'm trying to loosen the And she says that, I guess kind of 20 made her feel comfortable, because maybe it 21 was that comment or my persistence, and she 22 said yes. 23 she says I'm Jeffrey's executive assistant, 24 personal assistant. 25 her, just didn't seem to suit. So I said, what do you do? And Which, from looking at Case 18-2868, Document 283, 08/09/2019, 2628241, Page237 of 883 Page 55 1 R. Rizzo - Confidential 2 And I blurted out: 3 executive personal assistant? 4 do? 5 executive personal assistant. 6 appointments. You're his What do you And she says I was hired as his 7 I schedule his And I'm shocked, and I blurt out: 8 You seem quite young, how did you get a job? 9 How old are you? 10 blank: And she says to me, point I'm 15 years old. 11 And I said to her: 12 old and you have a position like that? 13 that point she just breaks down hysterically, 14 so I feel like I just said something wrong, 15 and she will not stop crying. 16 were at a loss for words, and I keep on 17 trying to console her, and nothing I was 18 saying, are you all right, do you need a 19 tissue, do you need water, consoles her. 20 You're 15 years At My wife and I And then in a state of shock, she 21 just lets it rip, and what she told me was 22 just unbelievable. 23 24 25 Q. What did she say? MR. PAGLIUCA: and foundation. Object to the form Case 18-2868, Document 283, 08/09/2019, 2628241, Page238 of 883 Page 56 1 R. Rizzo - Confidential 2 A. She proceeds to tell my wife and I 3 that, and this is not -- this is blurting 4 out, not a conversation like I'm having a 5 casual conversation. 6 an island, I was on the island and there was 7 Ghislaine, there was Sarah, she said they 8 asked me for sex, I said no. 9 That quickly, I was on And she is just rambling, and I'm 10 like what, and she said -- I asked her, I 11 said what? 12 island, I don't know how I got from the 13 island to here. 14 afternoon I was on the island and now I'm 15 here. 16 not making any sense to me, and I said this 17 is nuts, do you have a passport, do you have 18 a phone? 19 And she says yes, I was on the Last afternoon or in the And I said do you have a -- this is And she says no, and she says 20 Ghislaine took my passport. And I said what, 21 and she says Sarah took her passport and her 22 phone and gave it to Ghislaine Maxwell, and 23 at that point she said that she was 24 threatened. 25 yes, I was threatened by Ghislaine not to And I said threatened, she says Case 18-2868, Document 283, 08/09/2019, 2628241, Page239 of 883 Page 57 1 2 R. Rizzo - Confidential discuss this. 3 And I'm just shocked. So the 4 conversation, and she is just rambling on and 5 on, again, like I said, how she got here, she 6 doesn't know how she got here. 7 asked her, did you contact your parents and 8 she says no. 9 Again, I At that point, she says I'm not 10 supposed to talk about this. I said, but I 11 said: I don't 12 understand. How did you get here. We were totally lost for words. 13 And she said that before she got 14 there, she was threatened again by Jeffrey 15 and Ghislaine not to talk about what I had 16 mentioned earlier, about -- again, the word 17 she used was sex. 18 Q. And during this time that you're 19 saying she is rambling, is her demeanor 20 continues to be what you described it? 21 A. Yes. 22 Q. Was she in fear? 23 A. Yes. 24 25 MR. PAGLIUCA: and foundation. Object to the form Case 18-2868, Document 283, 08/09/2019, 2628241, Page240 of 883 Page 58 1 R. Rizzo - Confidential 2 Q. You could tell? 3 A. Yes. 4 MR. PAGLIUCA: Same objection. 5 A. She was shaking uncontrollably. 6 Q. What happens with this 15-year-old 7 girl next? 8 9 10 MR. PAGLIUCA: Object to the form and foundation. A. As she is trying to explain, and 11 I'm asking questions because I'm as feared as 12 she is at this point. 13 approach and she just shuts up. We hear people 14 Q. What happens next? 15 A. Eva comes in and tells her that she 16 will be working for Eva in the city. 17 Q. As what? 18 A. As a nanny. 19 Q. Did you see this girl again? 20 A. Yes. 21 Q. And when? 22 A. On a flight maybe a month or so to 23 Sweden. 24 Q. What was the purpose of the flight? 25 A. We were going to Sweden for the Case 18-2868, Document 283, 08/09/2019, 2628241, Page241 of 883 Page 59 1 R. Rizzo - Confidential 2 summer. 3 Q. Who was on the flight? 4 A. The Dubin family. 5 Q. As well as this girl? 6 A. Yes. 7 Q. What happens? 8 A. One thing that I forgot to mention 9 is during our initial conversation, I asked 10 her what her name was 11 was she said her name 12 Q. What happened with ? 13 A. We flew to Sweden, we stopped at an 14 airport that we didn't usually stop at and 15 she got off the plane. 16 Q. Just so that I make sure I 17 understand, who it was that she says asked 18 her for sex on the island, who was that? 19 MR. PAGLIUCA: 20 Foundation. 21 A. Object to the form. She didn't specify who asked for 22 sex. 23 Immediately after that she put Ghislaine and 24 Sarah into the conversation. 25 She said that they asked for sex. Q. Taking her passport? Case 18-2868, Document 283, 08/09/2019, 2628241, Page242 of 883 Page 60 1 R. Rizzo - Confidential 2 A. Yes. 3 Q. From -- are there any other 4 incidents or occurrences that you observed 5 personally with Jeffrey Epstein and Ghislaine 6 Maxwell? 7 MR. PAGLIUCA: Object to the form 8 and foundation. 9 A. Not that I can recall. 10 Q. This last event that you described, 11 what's the timeframe when that occurred? 12 A. Late 2004, 2005. 13 Q. When did you resign your employment 14 from the Dubin family? 15 A. I think roughly October. 16 Q. Of what year? 17 A. 2005. 18 Q. Why? 19 A. My wife and I had discussed these 20 incidents, and this last one was just, we 21 couldn't deal with it. 22 23 24 25 Q. When you left your employment with the Dubin family, did you have a job? A. When we finally left, I stayed on three months after my resignation, I had a Case 18-2868, Document 283, 08/09/2019, 2628241, Page243 of 883 Page 141 1 2 CERTIFICATE 3 4 5 I HEREBY CERTIFY that RINALDO 6 RIZZO, was duly sworn by me and that the 7 deposition is a true record of the testimony 8 given by the witness. 9 10 _______________________________ 11 Leslie Fagin, Registered Professional Reporter 12 Dated: June 10, 2016 13 14 15 (The foregoing certification of 16 this transcript does not apply to any 17 reproduction of the same by any means, unless 18 under the direct control and/or supervision 19 of the certifying reporter.) 20 21 22 23 24 25 Cam: 18-7868, 782, 08/00/7010, 7678741, nf 882 EXHIBIT 15 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page245 of 883 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 283, 08/09/2019, 2628241, Page246 of 883 Confidential Page 18 1 DAVID RODGERS 2 flyer person, then you would reduce it to an 3 initial? 4 5 MR. PAGLIUCA: foundation. 6 7 MR. REINHART: 10 11 12 You can answer the question. 8 9 Object to form and You can answer the question, if you can answer the question. You are allowed to answer the question, if you understand the question. BY MR. EDWARDS: Q. 13 I'm trying to understand your testimony. Is it, if you came to know that person -- 14 A. Uh-huh. 15 Q. -- as a frequent flyer passenger, you 16 would begin to reduce that person's name to an 17 initial at some point? 18 MR. PAGLIUCA: 19 THE WITNESS: Same objection. Well, we don't really have a 20 frequent flyer program that we do, so to speak. 21 A lot of times I would do it because if you 22 would write out everybody's name there is not 23 enough space, you know, to get everybody's name 24 in that little square there. 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page247 of 883 Confidential Page 34 1 2 DAVID RODGERS Q. 3 -- is that right? And is that -- is Ghislaine Maxwell 4 somebody that through the years 1995 through 2013 5 was somebody who flew very frequently? 6 A. What were the years again? 7 Q. The years of this book, 1995 -- 8 A. I wouldn't say through 2013. 9 10 '95 through 2000 sometime. But, yes, Probably, I would have to go back and -- well, you can see in there. 11 Q. We will get to it. 12 A. There will be a point where you don't see 13 her much. 14 be accurate. 15 Q. 16 But to say it went through 2013 would not Let's do it this way: The person that you have reflected on numerous notations -- 17 A. Yes. 18 Q. -- through here as GM -- 19 A. Yes. 20 Q. -- just by the initials, are we able to 21 22 23 24 25 safely know that that is Ghislaine Maxwell? A. Yes. MR. PAGLIUCA: Object to form and foundation. MR. EDWARDS: Court reporter, did you get Case 18-2868, Document 283, 08/09/2019, 2628241, Page248 of 883 Confidential Page 35 1 2 DAVID RODGERS the answer? 3 4 5 6 7 THE REPORTER: Yes. The answer came before the objection. BY MR. EDWARDS: Q. So on the next flight, the next day, from Palm Beach to SAF. Is SAF Santa Fe? 8 A. Yes. 9 Q. And it indicates JE and GM. 10 Are we able to then know that those 11 passengers on that flight were Jeffrey Epstein and 12 Ghislaine Maxwell? 13 A. 14 15 16 17 18 Yes. MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. And where would you land at SAF? Is that an airport? 19 A. It is an airport. 20 Q. Is it a private airport? 21 A. No. 22 Q. Did Jeffrey Epstein also have a landing 23 It's -- airlines go in there. strip at his property in New Mexico? 24 A. He did at one time. 25 Q. What would that -- do you remember what Case 18-2868, Document 283, 08/09/2019, 2628241, Page249 of 883 Confidential Page 36 1 2 DAVID RODGERS that code would be? 3 A. I don't believe there was a code. 4 Q. All right. 5 Were there times that you landed either the Gulfstream or the Boeing -- 6 A. No. 7 Q. No. 8 MR. REINHART: 9 before you answer. 10 11 12 THE WITNESS: Let him finish the question Oh, I'm sorry. BY MR. EDWARDS: Q. Sure. We are doing fine so far. But the 13 court reporter is taking down all of our questions 14 and all of our answers. We are communicating well. 15 A. Okay. 16 Q. But when I go to read this back, we may 17 not get that. 18 A. Okay. Go ahead. 19 Q. So were there times where you landed one 20 of Jeffrey Epstein's planes on his private landing 21 strip at the New Mexico property? 22 A. Yes. But not the Gulfstream and not the 23 Boeing. 24 Q. What plane did you land on his property? 25 A. The Cessna 421. And probably a Case 18-2868, Document 283, 08/09/2019, 2628241, Page250 of 883 Confidential Page 96 1 DAVID RODGERS 2 3 9:00, so it is 20 to 11:00 here. BY MR. EDWARDS: 4 5 Q. So I want to go to page 41, and down to December 9th. Sorry. December 11. 6 A. Okay. 7 Q. Palm Beach to Teterboro. 8 A. Yeah. 9 Q. And who are the passengers? 10 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 11 Tayler, Virginia. 12 13 Q. And this appears to be the first time that Virginia's name appears in the log? 14 A. Right. 15 Q. Is there a -- is there a reason why the 16 first time -- I notice that the first time on some 17 of the other passengers, you use a first and last 18 name. 19 first and last name? Is there any reason why you didn't use her 20 A. I probably didn't know her last name. 21 Q. Just didn't catch it. 22 A. Yes. 23 Q. Okay. 24 25 It was not that somebody told you not to use the last name? A. No. No. Case 18-2868, Document 283, 08/09/2019, 2628241, Page251 of 883 Confidential Page 97 1 2 3 DAVID RODGERS Q. Teterboro. 4 5 So that flight goes from Palm Beach to Can you remember whether that's the first time that you flew on a plane with Virginia Roberts? 6 MR. PAGLIUCA: 7 THE WITNESS: 8 MR. PAGLIUCA: 9 10 Object to -I believe it is. Object to form and foundation. BY MR. EDWARDS: 11 Q. Do you remember the flight? 12 A. No. 13 Q. The next flight three days later goes from 14 Teterboro to Virgin Islands with Jeffrey Epstein, 15 Ghislaine Maxwell, Adam Perry Lang, and Virginia; is 16 that right? 17 A. Yes. 18 Q. And below that, it says, "Reposition." 19 20 What does that mean? A. We were taking the airplane with no 21 passengers to go into maintenance, or an OPS2 22 inspection. 23 24 25 Q. Okay. This is -- this is the same Gulfstream, is that right? A. Yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page252 of 883 Confidential Page 98 1 DAVID RODGERS 2 3 Q. How many passengers would that Gulfstream allow? 4 A. Twelve passengers, I believe. 5 Q. And do you know how Jeffrey Epstein, 6 Ghislaine Maxwell, Adam Perry Lang, and Virginia get 7 off of St. Thomas or leave the island? 8 9 A. No. I do not. Probably a charter, I'm guessing. 10 Q. If -- who would fly the -- well, is there 11 any other plane that Jeffrey Epstein was able to 12 access back then that was a private plane? 13 MR. PAGLIUCA: 14 THE WITNESS: 15 16 No. At that point in time we don't have the Boeing yet. BY MR. EDWARDS: 17 18 Object to foundation. Q. So how many airplanes did Jeffrey Epstein back then? 19 A. Well, we -- I don't know if we had the 421 20 then. We may or may not have. But it wouldn't -- 21 you know, you wouldn't be flying the 421 down to 22 St. Thomas with Jeffrey. 23 flight. 24 Q. The Cessna? 25 A. The Cessna 421, correct. It is too long of a Case 18-2868, Document 283, 08/09/2019, 2628241, Page253 of 883 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 283, 08/09/2019, 2628241, Page254 of 883 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 283, 08/09/2019, 2628241, Page255 of 883 Confidential Page 101 1 DAVID RODGERS 2 A. I do not. I would guess the airlines. 3 Q. At this point in time, did you know what 4 her -- what her relationship was with Jeffrey 5 Epstein or Ghislaine Maxwell? 6 MR. PAGLIUCA: 7 THE WITNESS: 8 9 Q. Did you -- was she a masseuse? MR. PAGLIUCA: 11 THE WITNESS: 13 14 15 No. BY MR. EDWARDS: 10 12 Object to form. Object to foundation. I -- I'm not sure what she was. BY MR. EDWARDS: Q. Did you form any -- any belief that she was a friend or a business associate or anything? 16 MR. PAGLIUCA: 17 THE WITNESS: Object to foundation. Well, I mean, we had a lot 18 of people on the airplane. 19 just another one of those passengers. 20 21 22 And Virginia was BY MR. EDWARDS: Q. Beach. Okay. So on the 26th, flies to Palm And then -- and then I guess the 27th -- 23 A. Right. 24 Q. -- leaves from Palm Beach to the Virgin 25 Islands -- Case 18-2868, Document 283, 08/09/2019, 2628241, Page256 of 883 Confidential Page 102 1 DAVID RODGERS 2 A. Yes. 3 Q. -- with Jeffrey Epstein, Ghislaine 4 Maxwell, Emmy Tayler, and Virginia Roberts, right? 5 A. Yes. 6 Q. And on the 30th, you fly it back. 7 That's still the Gulfstream, right? 8 A. Yes. 9 Q. From the Virgin Islands to Palm Beach with 10 the same four passengers, correct? 11 A. Yes. 12 Q. And that's Jeffrey Epstein, Ghislaine 13 Maxwell, Emmy Tayler, and Virginia Roberts? 14 A. Correct. 15 Q. And then what happens to that plane, the 16 Gulfstream, for the next month, from February 1st 17 through March 5th? 18 A. Well, I don't know what happened to it, 19 but I'm -- from, looks like February 17th, I'm going 20 to school to get a type rating on the Boeing. 21 I'm gone for about three weeks. 22 23 Q. And So this is when you're doing a simulator on the Boeing? 24 A. Correct. 25 Q. And getting your certification to fly the Case 18-2868, Document 283, 08/09/2019, 2628241, Page257 of 883 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 283, 08/09/2019, 2628241, Page258 of 883 Confidential Page 104 1 2 3 DAVID RODGERS Q. Just let me finish my question. -- but for the month that you were training on the Boeing? 6 A. No. 7 Q. All right. So the last flight that you 8 took in the Gulfstream before you began, before you 9 flew the Cessna for a day, I guess, right, from 10 I know I was getting it out slow. 4 5 Sorry. Santa Fe to DFW -- 11 A. Right. 12 Q. -- February 3rd -- 13 A. Yes. 14 Q. And that's the Cessna with 908GM tail 15 number? 16 A. Yes. 17 Q. The last flight that you flew on the 18 Gulfstream was the flight back from St. Thomas with 19 Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and 20 Virginia Roberts, right? 21 A. Uh-huh. 22 Q. And then the next time that you're on the 23 plane is -- on the Gulfstream is when? 24 A. It looks like March the 5th. 25 Q. And who are the passengers on that flight? Case 18-2868, Document 283, 08/09/2019, 2628241, Page259 of 883 Confidential Page 105 1 2 3 4 5 6 DAVID RODGERS Where is it going to? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia Roberts. Q. And then there's notation of Gary Roxborough? 7 A. Yes. 8 Q. Do you know why that is? 9 A. Yeah. 10 Q. Why did he become the first officer? 11 A. Because Larry was probably in training for 12 He was the first officer. the Boeing. 13 Q. Okay. You took -- you alternated? 14 A. Right. 15 Q. All right. We didn't go at the same time. Then the Gulfstream has the 16 same aircraft make and model. 17 Gulfstream airplane, right? That's the same 18 A. Yes. 19 Q. But the aircraft identification mark 20 changes -- 21 A. Correct. 22 Q. -- on March 5th, 2001. 23 A. Correct. 24 Q. And it changes to N -- it changes from 25 N908JE to N909JE. Case 18-2868, Document 283, 08/09/2019, 2628241, Page260 of 883 Confidential Page 106 1 DAVID RODGERS 2 A. Yes. 3 Q. Why was that? 4 A. Because the N908JE went to the Boeing. 5 6 7 That was going to be on the Boeing now. Q. And the new number for N909JE was transferred to the Gulfstream? 8 A. Correct. 9 Q. And where does that first flight on the 10 5th go? 11 A. 12 13 14 15 16 17 From Palm Beach to Stephenville up in Newfoundland for a fuel stop. Q. Okay. And then how do you know it is a fuel stop? A. Because we are going to Paris, and so we have to stop there for fuel. Q. Okay. I know how -- I know how you would 18 know that. But is there any indication on any of 19 the numbers that go off to the right that would tell 20 me that it's a fuel stop as opposed to -- 21 A. No. 22 Q. No? Okay. All right. So there's no way 23 after today's deposition I can look at any of the 24 numbers; it's not going to tell me what it was for? 25 A. No. No. And it's -- obviously it looks Case 18-2868, Document 283, 08/09/2019, 2628241, Page261 of 883 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 283, 08/09/2019, 2628241, Page262 of 883 Confidential Page 108 1 2 DAVID RODGERS Tangiers. 3 4 Q. When you landed -- sorry to go back -- when you landed in -- what did we say LEGR was? 5 A. Granada, Spain. 6 Q. Where did -- where did you stay? 7 you stay on those trips? 8 9 Where do A. We didn't stay. We left the same day, I believe. 10 Q. Okay. 12 A. Uh-huh. 13 Q. That's Paris? 14 A. Yeah. 15 Q. And do -- 16 A. We stayed there. 17 Q. Do you know -- do you stay at the same 11 What if we go back to one flight to LFPB? LFPB. We stayed in Paris. 18 location where Jeffrey Epstein, Ghislaine Maxwell, 19 Emmy Tayler, and Virginia Roberts stay? 20 A. No. 21 Q. Where do you stay while you are in Paris? 22 A. Hotel. 23 Q. Where do they say? 24 MR. PAGLIUCA: 25 THE WITNESS: Object to foundation. He has a place there, in Case 18-2868, Document 283, 08/09/2019, 2628241, Page263 of 883 Confidential Page 109 1 2 3 4 5 DAVID RODGERS Paris. BY MR. EDWARDS: Q. Okay. Jeffrey Epstein has a home or a house in Paris? 6 A. Right. 7 Q. Okay. 8 A. Yes, I believe I have. 9 Q. Have you ever stayed there? 10 A. No. 11 Q. And getting to and from the airport, were Have you been to it? 12 you ever in the car riding to or from the airport in 13 Paris with Jeffrey Epstein? 14 A. No. 15 Q. So going down to the 9th, then, where is 16 that flight? 17 A. 18 19 20 21 That is from Tangiers to London Luton Airport. Q. And is Luton Airport, is that a major airport? A. For general aviation it is. There is 22 airline service in there, but it is not a huge one, 23 for sure. 24 Q. Who were the passengers? 25 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Case 18-2868, Document 283, 08/09/2019, 2628241, Page264 of 883 Confidential Page 110 1 2 DAVID RODGERS Tayler, and Virginia Roberts. 3 4 Q. And am I reading this correctly that the next flight is two days later, on the 11th? 5 A. Yes. 6 Q. And where does the flight on the 11th go? 7 A. From Luton to Bangor, Maine. 8 Q. All right. 9 10 While in London, do you know what Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts did? 11 A. No, I do not. 12 Q. Do you know who they saw? 13 A. No, I do not. 14 Q. After the flight to Maine, where is the 15 next flight? 16 A. Maine is from Bangor to Teterboro the same 18 Q. Okay. 19 A. So that was a fuel stop. 17 20 day. MR. EDWARDS: 21 time to stop. 22 tapes. All right. We are at a good The videographer has to change 23 THE WITNESS: Okay. 24 MR. EDWARDS: So we why don't we take a 25 five-minute break. Case 18-2868, Document 283, 08/09/2019, 2628241, Page265 of 883 Confidential Page 111 1 DAVID RODGERS 2 THE WITNESS: 3 THE VIDEOGRAPHER: 4 (Thereupon, a recess was taken, after which the following proceedings were held:) 7 THE VIDEOGRAPHER: 8 of Disk 2. 9 BY MR. EDWARDS: 10 11 Q. Sure. This is the beginning On the record at 11:12. If we go back to page 41, December 7th, 2000. 12 13 Off the record at 10:57. 5 6 Okay. MR. PAGLIUCA: Give us a Bates page, please. 14 MR. EDWARDS: Right, 41. For the 15 remainder, when I say "page," I'm really just 16 referring to the Bates number. 17 BY MR. EDWARDS: 18 Q. So page 41, December 7th, 2000. 19 A. Okay. 20 Q. Do you see that? 21 22 23 24 25 Where was that flight going from and to? A. Luton to -- Luton -- that's going into Marham Air Force Base. Q. Do you remember why you would have flown into the Air Force base? Case 18-2868, Document 283, 08/09/2019, 2628241, Page266 of 883 Confidential Page 112 1 DAVID RODGERS 2 A. We flew in there to drop the passengers 3 off. And then these passengers that were on there, 4 we dropped them off. 5 repositioned. 6 7 And then -- let's see. I don't remember. We We dropped passengers off, and we had to leave, I believe. 8 Q. Okay. 9 A. We weren't allowed to stay there. 10 Q. That was Tom Pritzker? 11 A. Yes. 12 Q. And then did you also drop off Jeffrey 13 That was -- Epstein, Ghislaine Maxwell, Kelly Spamm? 14 A. Yes. 15 Q. Okay. 16 A. I believe everyone got off the airplane 17 there. 18 Q. And where did you reposition to? 19 A. It says, "Positioned in Norwich, England." 20 21 22 23 24 25 I guess it's Norwich. Q. Sandringham, that is what it says right above that. A. What is that? Sandringham. I believe Sandringham is the estate that the queen has -Q. Okay. Case 18-2868, Document 283, 08/09/2019, 2628241, Page267 of 883 Confidential Page 113 1 DAVID RODGERS 2 A. -- near there. 3 Q. All right. 4 And the flight on December 9th -- 5 A. Uh-huh. 6 Q. That's Jeffrey Epstein, Ghislaine Maxwell, 7 Emmy Tayler, Kelly Spamm? 8 A. Right. 9 Q. And then what did you write in the 10 11 12 13 14 parenthesis under that? A. "Blowing snow on runway." It was a great weird phenomenon that happened that night. Q. And then you're leaving out of that Sandringham Airport; is that right? 15 A. We are -- which one are you on? 16 Q. On the 9th. 17 A. On the 9th -- 18 Q. The first entry on the 9th. 19 A. The 9th, we're leaving, looks like 20 Norwich, England, I believe, EGSH, and we go to 21 Gander, Newfoundland -- 22 Q. Okay? 23 A. -- for a fuel stop. 24 Q. I think before we took a break that we 25 were on page 43. Case 18-2868, Document 283, 08/09/2019, 2628241, Page268 of 883 Confidential Page 114 1 DAVID RODGERS 2 A. Uh-huh. 3 Q. And the flight that began in Palm Beach, 4 before going to Paris and Belgium, Tangier, I think 5 you told me, it ended up in Maine -- 6 A. Correct. 7 Q. -- on March 11th, 2001. 8 A. Right. 9 Q. Or, sorry, it ended up in Teterboro. 10 A. Teterboro. 11 Q. Okay. And then on the 15th, you fly 12 from -- on the Gulfstream out of Teterboro to ISP. 13 Do you know where that is? 14 A. Islip, New York. 15 Q. Okay. And Virginia Roberts was on the 16 flight that landed in Teterboro on the 11th, 17 correct? 18 19 MR. PAGLIUCA: foundation. 20 21 22 23 Object to form and THE WITNESS: Yes. BY MR. EDWARDS: Q. But leaving out of Teterboro, she's not one of the passengers on the flight. 24 A. No. 25 Q. Any idea where she went? Case 18-2868, Document 283, 08/09/2019, 2628241, Page269 of 883 Confidential Page 115 1 DAVID RODGERS 2 A. No. 3 Q. Okay. 4 MR. PAGLIUCA: Are you referring to 5 Bates 0041, the 11th through 14th? 6 what you're talking about? 7 MR. EDWARDS: 8 MR. PAGLIUCA: 9 MR. EDWARDS: 10 Is that Forty-three. Forty-three. March 11th and March 15th, 2001. 11 MR. REINHART: If it will help there, the 12 flight numbers column, like the fifth or sixth 13 column over, are sequentially numbered and 14 unique numbers. 15 "flight 1468" -- So if you want to just say 16 MR. EDWARDS: 17 MR. REINHART: 18 MR. EDWARDS: 20 MR. REINHART: 21 MR. EDWARDS: 22 MR. REINHART: 24 25 -- that might help everybody -- 19 23 Okay. Right. -- follow along. Okay. Thanks, Bruce. Uh-huh. BY MR. EDWARDS: Q. So the flight now that I'm talking about that leaves out of Teterboro on the 15th, flight Case 18-2868, Document 283, 08/09/2019, 2628241, Page270 of 883 Confidential Page 116 1 2 DAVID RODGERS No. 1471 -- 3 A. Right. 4 Q. -- the passengers appear to be Jeffrey 5 Epstein, Ghislaine Maxwell, Adam Perry Lang, Alexia 6 Wallert and Banu Cukuglu? 7 A. I think so. 8 Q. Do you remember Banu? 9 A. I definitely remember that. 10 It was a hard name to spell. 11 Yeah. Sort of, I guess. I mean, if she 12 walked in right now, I probably wouldn't recognize 13 her. 14 Q. Well, it has been since 2001, so -- 15 A. Yeah, I know. 16 Q. Okay. 17 Where is that? So then the next flight is 1472. Where is that going? 18 A. From Islip to Lake City, Florida. 19 Q. All right. A. Jeffrey Epstein, Ghislaine Maxwell, Adam 20 21 And the passengers, again, are who? 22 Perry Lang, Alexia Wallert and Banu Cukuglu, 23 whatever her name is. 24 25 Q. Did you know what relationship she had, if at all, with Jeffrey Epstein? Case 18-2868, Document 283, 08/09/2019, 2628241, Page271 of 883 Confidential Page 117 1 DAVID RODGERS 2 A. No. No. 3 Q. Do you remember an Ed Tuttle? 4 A. Yes. 5 Q. And who was he? 6 A. I believe Ed was a, probably in 7 construction. 8 before the Jeffrey -- well, let me think. 9 10 11 Q. name. I think he may have been around If we skip down to March 16th, I see his So I don't know if that's going to help you. A. I believe -- I believe Ed Tuttle was like 12 maybe an architect, or somewhere in the 13 construction, real estate side, I believe. 14 Q. Okay. So flight No. 1477 -- 15 A. Uh-huh. 16 Q. -- from LaGuardia to Palm Beach, is that 17 Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Joe 18 Pagano, Eva Dubin? 19 A. Yes. 20 Q. Celina Dubin? 21 A. Yes. 22 Q. Jordan Dubin? 23 A. Right. 24 Q. Maya Dubin and two nannies? 25 A. Yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page272 of 883 Confidential Page 118 1 DAVID RODGERS 2 Q. And Alexia Wallert? Is that what that is? 3 A. I would assume so, yes, AW. 4 Q. That is sort of what we talked about in 5 the beginning, where Alexia Wallert appears in full 6 name at the top -- 7 A. Right. 8 Q. -- and it's AW, AW, AW. 9 A. And there's no room to write her name out 10 there -- 11 Q. Right. 12 A. -- so she's AW. 13 Q. Okay. And then the next flight, the 27th, 14 leaves out of Palm Beach. 15 that flight and where's it going? 16 flight. 17 A. Yeah. Who are our passengers on 1478 is the Jeffrey Epstein, Ghislaine Maxwell, 18 Emmy Tayler, Virginia Roberts, two females, Banu, 19 and that's it. 20 Q. And do you know, in New York, when that 21 plane lands in Teterboro, where do you stay when the 22 plane is up there? 23 A. It is 2001. At an apartment there. 24 Q. Did you have your own apartment? 25 A. Yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page273 of 883 Confidential Page 119 1 DAVID RODGERS 2 3 Q. Epstein's apartments? 4 5 Or did you stay at one of Jeffrey A. No. It was his apartment, Jeffrey's apartment. 6 Q. Was that one of the apartments at 301 East 7 66th Street? 8 A. Yes. 9 Q. And did any of the other passengers from 10 that flight, that 1478, did any of them stay at any 11 of those apartments? 12 13 14 15 A. Yeah. Emmy would have. Virginia probably Q. Did you see Virginia stay at the did. apartment? 16 A. I don't know. 17 Q. When you were in New York and you left 18 from the airport, did you ride in the same car with 19 Virginia? 20 21 22 A. ever did. Q. Not usually. I mean, I don't know if we It's possible we did. Do you know whether Virginia Roberts 23 stayed at Jeffrey Epstein's townhouse or whether 24 Virginia Roberts stayed at the apartments? 25 MR. PAGLIUCA: Object to form. Case 18-2868, Document 283, 08/09/2019, 2628241, Page274 of 883 Confidential Page 120 1 DAVID RODGERS 2 THE WITNESS: I don't know for sure. 3 4 5 BY MR. EDWARDS Q. Can you recollect riding in a car with 6 her, or can you recollect whether she got in a car 7 with anyone else? 8 MR. PAGLIUCA: 9 THE WITNESS: I can't. 10 MR. EDWARDS: Okay. 11 MR. REINHART: 12 I'm sorry. Are you asking about that specific trip or -- 13 14 Object to form. MR. EDWARDS: Sorry. BY MR. EDWARDS: 15 Q. I mean that specific trip. 16 A. No. 17 Q. How about in general at any time? 18 A. No. I can't. I don't recall. I mean, I can 19 recall, I would ride sometimes with Emmy, with Adam 20 I remember them being in the car. 21 was unusual. 22 myself. 23 ride with us. 24 25 Q. But, again, that Usually it would just be Larry and But on occasion, you know, somebody might When you would stay at the apartment in New York on East 66th Street, would it always be in Case 18-2868, Document 283, 08/09/2019, 2628241, Page275 of 883 Confidential Page 121 1 2 DAVID RODGERS the same apartment? 3 A. Yes. 4 Q. All right. 5 There are multiple apartments owned by Jeffrey Epstein? 6 A. At that time, it was the same apartment. 7 Q. Okay. 8 Have you stayed in other apartments since that time? 9 A. Yes. 10 Q. All at that East 66th Street location? 11 A. Yes. I really don't -- I don't have an 12 apartment there now. 13 probably 2008. 14 15 Q. We haven't gone there since How about Banu? 301 East 66th Street? 16 MR. PAGLIUCA: 17 THE WITNESS: 18 Would she have stayed at Object to foundation. Most likely. BY MR. EDWARDS 19 Q. Why do you say that? 20 A. Well, if she's on the plane with us on 21 multiple trips, then most likely she probably stayed 22 there. 23 24 25 Q. Have you been to Jeffrey Epstein's townhouse as 9 East 71st Street? A. Yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page276 of 883 Confidential Page 122 1 DAVID RODGERS 2 Q. And it's a pretty big place, right? 3 A. Pretty big. 4 Q. And it has numerous bedrooms? 5 A. Yes. 6 Q. Any reason why Banu would not have been 7 staying there? 8 MR. PAGLIUCA: 9 THE WITNESS: 10 11 Object to foundation. I don't know. BY MR. EDWARDS Q. I'm just trying to get to, is there a 12 reason why you believe that Banu would have, I think 13 you said, probably have stayed at the apartment 14 versus the townhouse? 15 16 A. Well, I only say that because Emmy, you know, stayed there. 17 Q. Stayed where? 18 A. At the -- at our apartments. 19 Q. Okay. 20 A. I'm pretty sure Adam, yeah, Adam stayed 21 there at the time. 22 regulars on the flight, they would stay there in the 23 apartments. 24 25 Q. Okay. So most of the people that were But do you remember Virginia or Banu staying in the apartments? Case 18-2868, Document 283, 08/09/2019, 2628241, Page277 of 883 Confidential Page 123 1 DAVID RODGERS 2 A. I do not specifically. 3 Q. Okay. The next flight on the next day, 4 1479, is flying from Teterboro to Santa Fe; is that 5 right? 6 A. Yes. 7 Q. And who are those passengers? 8 A. Jeffrey Epstein, Ghislaine Maxwell, Adam 9 10 Perry Lang, Virginia Roberts, Banu, Marvin Minsky, Henry Jarecki. 11 Q. Do you remember Marvin and Henry? 12 A. I remember Henry. 13 Marvin. 14 Q. Okay. I don't really remember And then two days later -- again, 15 where would you have stayed if you landed in 16 Santa Fe on March 29th, 2001? 17 A. Probably would have stayed at the ranch. 18 Q. At the Zorro Ranch? 19 A. Yes. 20 Q. All right. Did the other passengers that 21 were on the plane, Jeffrey Epstein, Ghislaine 22 Maxwell, Adam Perry Lang, Virginia Roberts, Banu -- 23 I'm not evening going to try her last name -- 24 A. Right. 25 Q. -- Marvin Minsky and Henry Jarecki also Case 18-2868, Document 283, 08/09/2019, 2628241, Page278 of 883 Confidential Page 124 1 2 DAVID RODGERS have stayed at the ranch? 3 MR. PAGLIUCA: 4 THE WITNESS: 5 they did. 6 BY MR. EDWARDS 7 8 Q. Object to foundation. I'm going to say most likely Was there any other location in Santa Fe where you are aware passengers would have stayed? 9 A. Not that I'm aware of. 10 Q. If you were all going to the same place, 11 is that an occasion where you would all ride in the 12 same vehicle from the airport to the ranch? 13 MR. PAGLIUCA: 14 THE WITNESS: 15 16 17 18 19 Object to foundation. I don't know. BY MR. EDWARDS Q. You would still right in separate vehicles? A. Right. Because it takes us about an hour to finish up at the airport. 20 Q. And then the 31st, so two days? 21 A. Let me go back to that one -- 22 Q. Sure. 23 A. -- and say, it is possible. 24 has ridden with us before. 25 one way or the other. I think Adam So I couldn't swear that But he has probably ridden Case 18-2868, Document 283, 08/09/2019, 2628241, Page279 of 883 Confidential Page 125 1 DAVID RODGERS 2 with us before to the airport; to or from the 3 airport. 4 Q. Two days later, flight No. 1408 out of 5 Santa Fe to Palm Beach, who were the passengers 6 there? 7 A. Jeffrey Epstein, Ghislaine Maxwell, Prince 8 Andrew, Virginia Roberts, Nadia Bjorlin, Henry 9 Jarecki, Marvin Minsky. 10 11 Q. Do you remember when you were at the ranch Nadia Bjorlin arriving? 12 A. I would assume that she airlined in there. 13 Q. Do you remember her at the ranch? 14 perform for you or anything? 15 A. No. 16 I don't remember her at the ranch. 17 mean, I'm sure she was there. 18 remember. 19 Q. Okay. 20 Heather Mann? 21 Lydia. Do you remember a person named She's found on flight 1438 next to A. Heather Mann, not really. 23 Q. Okay. 25 1488. The next flight, on page 45, is The flight number. A. I I just don't 22 24 Did she Right. April 9th, 2001. Case 18-2868, Document 283, 08/09/2019, 2628241, Page280 of 883 Confidential Page 126 1 2 3 DAVID RODGERS Q. Where does that flight take off from and where does it go? 4 A. Palm Beach to Atlantic City. 5 Q. Who is on that flight? 6 A. Jeffrey Epstein, Emmy Tayler, Virginia 7 Roberts, Banu and Johanna. 8 Q. Do you remember Johanna Sjoberg? 9 A. I don't. 10 Q. On that same day, you take a flight to 11 Teterboro? 12 A. Right. 13 Q. Did you go to the casinos at all that day? 14 A. I don't think so. 15 Q. Would that be something that you would do 16 with them? Or you would stay back? 17 A. No. 18 Q. All right. 19 20 We would stay at the airport. And then two days later, on the 11th, flight 1490, the plane flies out of Teterboro. 21 For that two-day period of time, the night 22 of the 9th and the night of the 10th, would you have 23 stayed at the apartment? 24 MR. PAGLIUCA: 25 MR. EDWARDS: Object to foundation. In New York. Case 18-2868, Document 283, 08/09/2019, 2628241, Page281 of 883 Confidential Page 127 1 DAVID RODGERS 2 3 4 5 THE WITNESS: I would say, yes. BY MR. EDWARDS: Q. All right. Do you know where Virginia and Banu and Johanna stayed? 6 A. No idea. 7 Q. You can't recollect whether they were -- 8 you can't recollect seeing them at the apartments? 9 MR. PAGLIUCA: 10 11 12 THE WITNESS: No. BY MR. EDWARDS: Q. 13 14 Object to foundation. All right. Then on the 11th, you leave from Teterboro and go to where? 15 A. St. Thomas. 16 Q. That is flight 1490. And on that flight, 17 Jeffrey Epstein, Ghislaine Maxwell, Prince Andrew, 18 Banu, Virginia Roberts and Johanna? 19 A. Yes. 20 Q. And that is -- that is a flight -- how 21 does -- how did those passengers get from -- does 22 Jeffrey Epstein have a place in St. Thomas? 23 MR. PAGLIUCA: 24 THE WITNESS: 25 Object to form. Well, yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page282 of 883 Confidential Page 128 1 2 DAVID RODGERS BY MR. EDWARDS: 3 Q. Where is that? 4 A. In St. Thomas, he has an office. 5 Thomas. 6 Q. Where does he stay in the Virgin Islands? 7 A. On Little St. James. 8 Q. And how do the passengers get from 9 In St. St. Thomas to Little St. James? 10 A. Most likely, helicopter. 11 Q. How many people does the helicopter fit? 12 A. We didn't own a helicopter then. 13 Probably -- probably 5. It depends, 14 because they had different helicopters. 15 sure which one they used that day. 16 17 Q. I'm not What is the duration of the flight from St. Thomas to Little St. James? 18 A. About six minutes. 19 Q. What is the duration of a boat trip from 20 21 Little St. James to St. Thomas? A. Probably about, let's say, 15 to 20 22 minutes. But you are on the east side of the island 23 and the airport is almost to the west side of the 24 island. 25 Q. So you have to almost circle the island? Case 18-2868, Document 283, 08/09/2019, 2628241, Page283 of 883 Confidential Page 129 1 2 DAVID RODGERS A. To get from the island by boat, to get 3 to -- there's land there and take a car, it is 4 probably -- it is probably close to an hour, 45 5 minutes for sure. 6 7 Q. Are there passenger manifests that are kept for the helicopters? 8 MR. PAGLIUCA: 9 THE WITNESS: 10 11 12 Object to foundation. I'm not sure. I'm not sure. BY MR. EDWARDS: Q. Back in this time, in around April of 2001, did Jeffrey Epstein have a helicopter yet? 13 A. No, he did not have a helicopter. 14 Q. At that time? 15 A. Correct. 16 Q. And so do you remember the name of the 17 company or corporation that they rented or 18 transported? 19 A. 20 I don't. It was the only -- helicopter service there in St. Thomas is no longer there. 21 Q. Okay. 22 A. Air Center Helicopter. 23 Q. Was there a particular person at Air 24 25 Center Helicopter that you ever coordinated with? A. We would, like, call a dispatcher. Or you Case 18-2868, Document 283, 08/09/2019, 2628241, Page284 of 883 Confidential Page 130 1 DAVID RODGERS 2 know, whoever picked up the phone, we would call 3 them. 4 5 Q. All right. So 1491 is a flight from St. Thomas to Palm Beach; is that right? 6 A. Yes. 7 Q. And Gwendolyn Beck is now on that flight? 8 A. Yes. 9 Q. Do you remember that flight at all, 1491? 10 A. Not really. 11 Q. Anything about it stick out in your mind? 12 A. No. 13 Q. All right. 14 remember a female name Kelly Bovina? 15 16 17 18 The next flight that -- do you A. I remember the name, but I don't remember Q. Was she an actress as well, do you her. remember that? 19 A. I don't recall. 20 Q. The next flight I want to direct your 21 attention is 1501, May 3rd, 2001. 22 A. Okay. 23 Q. What is that airport, ADS? 24 A. Addison, Texas. 25 Q. And who are the passengers on that? San Antonio, Texas. Case 18-2868, Document 283, 08/09/2019, 2628241, Page285 of 883 Confidential Page 131 1 DAVID RODGERS 2 A. Jeffrey Epstein, Virginia Roberts. 3 Q. Do you know how Virginia Roberts got to 4 Addison, Texas? 5 A. No. 6 Q. Was that flight -- was the purpose of that 7 flight only to pick up Virginia Roberts? 8 MR. PAGLIUCA: 9 10 Object to form and foundation. BY MR. EDWARDS: 11 Q. Can you tell by your logs? 12 A. Not really. Q. The flight previous on the 3rd flies in 13 14 15 Let's see. We -- no, I don't know. from where? Where is that? 16 A. Little Rock. 17 Q. Arkansas? 18 A. Correct. 19 Q. So the only passenger on that flight from 20 Little Rock, Arkansas, to Addison, Texas, flight 21 1500, is Jeffrey Epstein, right? 22 A. Right. 23 Q. And then you land in Addison before going 24 to Santa Fe? 25 A. That is actually San Antonio, I believe. Case 18-2868, Document 283, 08/09/2019, 2628241, Page286 of 883 Confidential Page 132 1 2 3 4 DAVID RODGERS Yes. That is San Antonio, SAT. Q. How long is the flight from Addison to San Antonio? 5 A. I would be guessing, probably an hour. 6 Q. Do you know what the purpose was for 7 8 9 10 landing -A. 9/10s. Q. Well, you know, I can tell you. It is Fifty-four minutes. Do you know what the purpose was to be to 11 land in Addison, Texas, before arriving in San 12 Antonio? 13 A. I do not. But it appears that we spent 14 the night in San -- oh, I see what you are saying. 15 No, I don't know. 16 the same day. 17 18 Q. That I went to Addison probably Went to Addison and picked up Virginia Roberts? 19 A. It looks like it. 20 Q. And then in San Antonio, two days later, 21 who are your passengers on that flight, 1502? 22 A. Jeffrey Epstein, Virginia Roberts. 23 Q. Where do you fly? 24 A. From San Antonio to Palm Beach. 25 Q. And in May, on May 14th, 2001, flight Case 18-2868, Document 283, 08/09/2019, 2628241, Page287 of 883 Confidential Page 133 1 2 DAVID RODGERS 1506, where is that flight leaving from? 3 A. St. Thomas. 4 Q. And going where? 5 A. Teterboro. 6 Q. And who are your passengers? 7 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 8 9 10 Tayler, Banu, Virginia Roberts and one female. Q. And, again, do you remember who the one female would have been with Virginia Roberts? 11 A. No. 12 Q. Can you tell by this how any of those 13 individuals that were on that flight leaving from 14 the Virgin Islands to Teterboro got to the Virgin 15 Islands? 16 A. No. 17 Q. What were the other possible avenues back 18 in those days for Jeffrey Epstein, Ghislaine Maxwell 19 to travel to the Virgin Islands? 20 A. They could have done a charter, possibly. 21 Q. Okay. Was there ever a time when, it 22 looks like that is the -- that is the Gulfstream 23 that you fly out of the Virgin Islands to Teterboro, 24 correct? 25 A. Correct. Case 18-2868, Document 283, 08/09/2019, 2628241, Page288 of 883 Confidential Page 134 1 2 3 DAVID RODGERS Q. Was there ever a time you were flying the Gulfstream and -- well, let's go back a little bit. 4 A. Okay. 5 Q. On May 7th, at the top. 6 A. Right. 7 Q. Flight 1503, that is the Gulfstream 8 9 10 11 12 traveling from Palm Beach to CHO? A. That is Charlottesville, I believe, Virginia. Q. And then on that same day from Charlottesville to Teterboro? 13 A. Correct. 14 Q. So when does the Gulfstream get from 15 16 17 Teterboro to St. Thomas? A. Hmm, I don't know. that I'm on vacation at that time. 18 Q. 19 to fly? 20 A. Airline. 21 Q. All right. 22 Because it appears So I don't know. How did you get to St. Thomas for the 14th So at some point in time, between May 7th and May 14th -- 23 A. Uh-huh. 24 Q. -- somebody flies the Gulfstream to the 25 Virgin Islands. Case 18-2868, Document 283, 08/09/2019, 2628241, Page289 of 883 Confidential Page 135 1 DAVID RODGERS 2 A. Correct. 3 Q. And who would that be? 4 MR. PAGLIUCA: 5 THE WITNESS: 6 7 Larry Visoski and I don't know who the other person would have been. BY MR. EDWARDS: 8 9 Object to foundation. Q. When you pick up passengers in the Virgin Islands and you are taking them to Teterboro, do you 10 speak with Larry Visoski about when he arrived in 11 the Virgin Islands? 12 A. Yeah. Yeah. We would coordinate that. 13 mean, usually we would go down there together. 14 would ride in the same airline down. 15 16 Q. We In this particular case, you were on vacation? 17 A. Well, that is true. However, most likely 18 he airlined home once he got to St. Thomas. 19 then most likely, we drove in a car to Miami and 20 road the same airline down there. 21 And Q. That was something that you customarily 23 A. Yes. 24 Q. Okay. 22 25 did? So then you have -- we have no way of knowing then who the passengers that flew to the I Case 18-2868, Document 283, 08/09/2019, 2628241, Page290 of 883 Confidential Page 136 1 DAVID RODGERS 2 Virgin Islands would have been, if there were any in 3 addition to those that left? 4 A. No. 5 Q. All right. You fly into Teterboro on 6 flight 1506 on May 14th, 2001, and fly out in the 7 Gulfstream on the 24th, 10 days later; is that 8 right? 9 A. Yes. 10 Q. And your passengers, 10 days later flying 11 to Palm Beach are Jeffrey Epstein, Ghislaine 12 Maxwell, Emmy Tayler, Adam Perry Lang and a female. 13 A. Right. 14 Q. Do you know where Virginia Roberts went 15 during that time after she landed in Teterboro on 16 the 14th? 17 A. I do not. 18 Q. Page 47, I'm going to go to flight 19 No. 1510. 20 June 3rd, 2001. Who is on that flight? 21 A. Jeffrey Epstein, Virginia Roberts, Banu. 22 Q. And you are flying from Palm Beach to 23 St. Thomas again? 24 A. St. Thomas, yes. 25 Q. And then from St. Thomas to Teterboro two Case 18-2868, Document 283, 08/09/2019, 2628241, Page291 of 883 Confidential Page 137 1 2 DAVID RODGERS days later, on June 5th? 3 4 Jeffrey Epstein, Virginia Roberts, and Q. All right. Banu. 5 6 A. And then where is the next flight on the 8th? 7 A. On the 8th, from Teterboro to Montreal. 8 Q. Do you know what -- so Virginia Roberts 9 and Banu were not on the flight on the 8th, right? 10 A. That's correct. 11 Q. Okay. 12 Do you remember the flight on the 8th with Naomi Campbell, Rebecca White, Ana Malova? 13 A. Sort of. 14 Q. Okay. 16 A. No. 17 Q. Do you remember how old Rebecca White was? 18 A. No. 19 Q. The next flight I want to direct your 15 20 But not really. Do you remember who Rebecca White is? attention to is on the 15th of June, flight 1516. 21 A. Uh-huh. 22 Q. Passengers: 23 Jeffrey Epstein, Ghislaine Maxwell, and then does that say Sheridan? 24 A. Yes. 25 Q. Do you remember a passenger named Sheridan Case 18-2868, Document 283, 08/09/2019, 2628241, Page292 of 883 Confidential Page 138 1 DAVID RODGERS 2 Gibson? 3 A. Possibly. 4 Q. And then it says, Caroline. 5 Do you know who Caroline is? 6 A. I do not. 7 Q. And then one female? 8 A. Yeah, I don't know who the female is. 9 Q. Okay. 11 A. Uh-huh. 12 Q. From -- is that Portugal to St. Thomas? 13 A. No. 14 Q. LPAZ? 15 A. Yes. 16 Q. To St. Thomas? 17 A. Right. 18 Q. And then on that flight is Jeffrey 10 On the 28th, there is a flight 1523. It is the Azores. It was a fuel stop. 19 Epstein, Ghislaine Maxwell, Emmy Tayler and Ed 20 Tuttle, right? 21 A. Yes. 22 Q. Six days later, leaving on July 4th from 23 24 25 St. Thomas, who are your passengers? A. Jeffrey Epstein, Prince Andrew, Virginia Roberts, one female. Case 18-2868, Document 283, 08/09/2019, 2628241, Page293 of 883 Confidential Page 139 1 DAVID RODGERS 2 3 Q. And do you know how Virginia Roberts got to the Virgin Islands? 4 A. No. 5 Q. Is there any -- is it possible that the 6 Cessna took her or the Boeing took her? 7 other aircraft that is owned by Jeffrey? 8 MR. PAGLIUCA: 9 THE WITNESS: 10 11 Or any Object to foundation. No, I would -- if I had to guess, I would guess the airlines. BY MR. EDWARDS: 12 Q. Okay. 13 A. Well, I know it wasn't the Boeing, because 14 the Boeing is not in operation at that point in 15 time. 16 any passengers on board yet. 17 of 2001. 18 19 Q. Okay. A. That is like in August And the Cessna, did you take that It has been to the Virgin Islands, but I don't think we ever took any passengers down there. 22 Q. Okay. 24 A. Okay. 25 Q. On July 8th, 2001. 23 I mean, it hadn't had from Florida to the Virgin Islands? 20 21 We hadn't flown it. All right. 1525. The next flight is Case 18-2868, Document 283, 08/09/2019, 2628241, Page294 of 883 Confidential Page 140 1 DAVID RODGERS 2 A. Okay. 3 Q. That leaves out of Palm Beach? 4 A. Okay. 5 Q. Where do you go on that? 6 A. Teterboro. 7 Q. And who are your passengers? 8 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 9 Tayler, Prince Andrew, Virginia Roberts, Sheridan 10 Gibson, maybe Sheridan Gibson-Beaute, I guess, and 11 one female. 12 13 Q. And then three days later, you leave out of Teterboro to CPS? 14 A. Yes. 15 Q. Where is that? 16 A. That is St. Louis, actually it is Cahokia, 17 Illinois, across the river from St. Louis. 18 Q. Who are your passengers? 19 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 20 Tayler, Virginia Roberts. 21 to Santa Fe. 22 to go into there for maintenance. 23 24 25 Q. We were actually en route We had a mechanical problem. We had Do you remember having a mechanical problem or is the log just refreshing your memory? A. No, I remember because that was the only Case 18-2868, Document 283, 08/09/2019, 2628241, Page295 of 883 Confidential Page 141 1 2 DAVID RODGERS time we landed at Cahokia with passengers on board. 3 Q. What was the problem? 4 A. We had a -- we had a static line that had 5 cracked and it was causing our altimeters to not 6 agree. 7 things got really worse because it was stopped up 8 with a mud dauber somewhere in the system. 9 why I remember that flight. 10 11 12 Q. And then we went to the alternate system, When you landed in St. Louis did the passengers get off the plane? A. Yes. 13 they airlined. 14 don't recall. 15 That is Q. And then they airlined -- I believe They could have taken a charter, I But I know they didn't leave with us. All right. And the passengers that got 16 off the plane would have been Jeffrey Epstein, 17 Ghislaine Maxwell, Emmy Tayler and Virginia Roberts? 18 A. Yes. 19 Q. And then on the 16th, those five days 20 later, those same passengers leave Santa Fe? 21 A. Right. 22 Q. And go back to Teterboro? 23 A. Correct. 24 Q. When Jeffrey Epstein would go to his 25 townhouse in New York, would you always fly into Case 18-2868, Document 283, 08/09/2019, 2628241, Page296 of 883 Confidential Page 142 1 2 DAVID RODGERS Teterboro? 3 A. Most of the time. 4 airplane, too. 5 to take it into Teterboro. 6 7 Q. Like the Boeing, you are not allowed So while you had the Gulfstream, it seemed like Teterboro? 8 9 It would depend on the A. Yeah, it is -- I mean, occasionally there would be a LaGuardia in there, but not really often. 10 Q. So on the 16th, you fly in to Teterboro. 11 And then six days later, it looks like, flight 12 No. 15 -- oh, wait. 13 All right. So flight No. 1528, you fly into 14 Teterboro, Jeffrey Epstein, Emmy Tayler, Ghislaine 15 Maxwell and Virginia Roberts. Do you see that? 16 A. Yes. 17 Q. Then the next flight I have listed is 18 1530. 19 20 21 Do you know where 1529 is? A. I wasn't on that flight. 22 23 24 25 No, other than I'm gone for some reason. Let's see. July, approximately. I see I went on vacation. Q. Okay. And the 23rd, there is a flight from Palm Beach to St. Thomas with Jeffrey Epstein, Case 18-2868, Document 283, 08/09/2019, 2628241, Page297 of 883 Confidential Page 143 1 2 DAVID RODGERS Shelly Lewis. Do you see that? 3 A. Yes. 4 Q. Five days later, the flight that leaves 5 St. Thomas does not have Shelly Lewis; is that 6 right? 7 A. Correct. 8 Q. And then you fly to Palm Beach? 9 A. Yes. 10 Q. And who are your passengers at that time? 11 A. Jeffrey Epstein, Virginia Roberts, yes. 12 Q. When you had the mechanical problem, do 13 you remember any of the passengers being scared or 14 frightened? 15 A. No. Not really. I mean, they didn't 16 really know that we had a problem. We just informed 17 them that we couldn't continue on to Santa Fe. 18 Q. Okay. 19 A. Uh-huh. 20 Q. Is that the first flight that the Boeing 21 And August 7th, 2001, flight 2? makes with passengers? 22 A. Correct. 23 Q. And that is Jeffrey Epstein, Ghislaine 24 Maxwell, Emmy Tayler, Prince Andrew and two females. 25 Do you remember who the two females were on the Case 18-2868, Document 283, 08/09/2019, 2628241, Page298 of 883 Confidential Page 144 1 2 DAVID RODGERS first passenger flight of the Boeing? 3 A. I do not. 4 Q. And then on the 7th -- at that flight flew 5 from Los Angeles to Albuquerque, correct? 6 A. Uh-huh. 7 Q. On the 14th, you were flying the Cessna 8 that has the 908GM tag. 9 A. Correct. 10 Q. And then the next entry with passengers is 11 on the 16th. 12 right? And you are flying the Boeing again, 13 A. Yes. 14 Q. All right. 15 16 17 20 21 Do you know who flew the Boeing for flight 3, 4 and 5? A. wasn't me. 18 19 Right. For 3, 4 and 5, no. Oh, yes. I know it I do remember that now. I went on vacation. And it was a contract guy that flew for us while I was gone. Q. Do you remember a passenger named Alexander Dixon? 22 A. Alexander Dixon, no. 23 Q. Flight No. 11 on the Boeing? 24 A. Uh-huh. 25 Q. Now, the Boeing has the tag 908JE? Case 18-2868, Document 283, 08/09/2019, 2628241, Page299 of 883 Confidential Page 145 1 DAVID RODGERS 2 A. Correct. 3 Q. That is what you were explaining in the 4 beginning, correct? 5 A. Correct. 6 Q. So September 3rd, the Boeing flies from 7 St. Thomas to HPN? 8 A. Yes, White Plains, New York. 9 Q. And your passengers? 10 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy 11 Tayler, Adam Perry Lane, Banu, Sarah Kellen, 12 Alexander Dixon. 13 Q. Do you remember Sarah Kellen? 14 A. Yes. 15 Q. And do you remember what -- is that your 16 17 first time meeting Sarah Kellen, when she appears? A. I don't think so. 18 earlier flight. 19 could be, I'm not sure. 20 21 Q. Let's see. I thought she was on an But it could be. It Do you know how Sarah Kellen got to St. Thomas to be leaving St. Thomas with you? 22 A. No. 23 Q. Do you know what her relationship was, if 24 25 any, with Jeffrey Epstein? A. She was -- Sarah was sort of taking over Case 18-2868, Document 283, 08/09/2019, 2628241, Page300 of 883 Confidential Page 146 1 2 DAVID RODGERS Emmy's position. Like an assistant to Ghislaine. 3 Q. All right. 4 A. Okay. 5 Q. There is a flight from Bedford, 6 Page 53. January 15th, 2002. Massachusetts; is that right? 7 A. Yes. 8 Q. To where is that going? 9 A. White Plains. 10 Q. And it's Jeffrey Epstein and Jessica. 11 A. Yes. 12 Q. Do you remember who Jessica is? 13 A. I do not. 14 Q. From White Plains, who are the passengers 15 16 going to St. Thomas? A. Jeffrey Epstein, Ghislaine Maxwell, Sarah 17 Kellen, Prince Andrew, Cindy Lopez, Johanna and one 18 female. 19 Q. Do you remember Cindy Lopez? 20 A. Yes. 21 Q. And what did she do? 22 A. I don't know what she did, but I do 23 24 25 remember Cindy Lopez. Q. masseuse? Was she somebody that you believed to be a Case 18-2868, Document 283, 08/09/2019, 2628241, Page301 of 883 Confidential Page 147 1 2 3 4 5 DAVID RODGERS A. I'm not sure what her position was. It is possible. Q. All right. February 9th, 2002, flight 57 on the Boeing. 6 A. Okay. 7 Q. From Miami to White Plains. 8 A. Yes. 9 Q. Your passengers include Bill Clinton, four 10 Secret Service. 11 12 Did the Secret Service ask that you not identify them by name? 13 A. No. 14 Q. Any reason that you didn't identify them 15 by name? 16 A. Didn't know their name. 17 Q. Two males, one female. 18 A. Right. 19 Q. Jeffrey Epstein, Ghislaine Maxwell, Sarah 20 Kellen and Prince Andrew. 21 A. Correct. 22 Q. Was that your first time meeting Bill 23 Clinton? 24 A. Yes. 25 Q. At that point, did you have any Case 18-2868, Document 283, 08/09/2019, 2628241, Page302 of 883 Confidential Page 148 1 DAVID RODGERS 2 understanding of what was the relationship between 3 Jeffrey Epstein and Bill Clinton or Ghislaine 4 Maxwell and Bill Clinton? 5 A. No, I didn't have any idea. 6 Q. Had you seen any pictures, prior to that 7 time, of Bill Clinton in any of Jeffrey Epstein's 8 planes or homes? 9 A. Not him I'm aware of. 10 Q. Have you ever seen a picture of Bill 11 Clinton in Jeffrey Epstein's plane? 12 A. In his plane? I don't think so. 13 Q. Have you ever seen one in his homes? 14 A. Not that I can recall. 15 Q. Okay. 16 A. Oh, wait, wait. Back up. A picture of 17 Bill Clinton in the plane? 18 is on the wall in the airplane or a picture taken of 19 Bill Clinton on the plane? 20 21 22 Q. Do you mean the picture A picture of Bill Clinton on the wall of the airplane. A. I have a picture of me and actually the 23 crew with Bill Clinton on the plane, but it is not 24 on the wall of the airplane. 25 Q. And when was the picture of you with Bill Case 18-2868, Document 283, 08/09/2019, 2628241, Page303 of 883 Confidential Page 149 1 2 DAVID RODGERS Clinton taken? 3 A. I think it was the first flight. 4 Q. The flight that we just looked at? 5 A. Yes. 6 Q. To the best of your knowledge, is that the 7 first time that Bill Clinton flew with Jeffrey 8 Epstein or Ghislaine Maxwell? 9 10 11 12 A. To the best of my knowledge. It was the first time that we had flown him. Q. Okay. On flight No. 72, which is page 54, March 10th. 13 A. Okay. 14 Q. The Boeing flies from St. Thomas to JFK; 15 is that right? 16 A. Yes. 17 Q. Is there any way of knowing when the 18 19 Boeing got to St. Thomas by these logs? A. Yes, it got there on the 28th. 20 is trip No. 71 above it. 21 State the question again. 22 23 Q. Oh, wait. Oh. Because it Wait. Yes, exactly. Do we know how or when the Boeing got to 24 St. Thomas? It is leaving out of St. Thomas on 25 flight 72, but flight 71 seems to me to land in Palm Case 18-2868, Document 283, 08/09/2019, 2628241, Page304 of 883 Confidential Page 150 1 2 DAVID RODGERS Beach. 3 A. Correct. 4 Q. So I'm just missing the kind of connection 5 there. 6 A. Yes. Me, too. 7 Q. Okay. 8 A. Yeah, I don't have an answer for that. 9 Q. Okay. Would somebody else have flown the 10 Boeing, while you were doing this simulator, the 6th 11 and 7th and 8th? 12 A. It is possible. 13 Q. That is one possible conclusion, based 14 upon what we have here? 15 A. That is probably what happened. 16 Q. Okay. 17 18 So then March 10th -- sorry. March 10th, you fly to JFK, right? 19 A. Yes. 20 Q. March 4th, from JFK to Palm Beach. March 21 the 17th, from Palm Beach back to JFK. 22 March 19th, 2002, you fly from JFK to -- where is 23 that? 24 A. Luton, London. 25 Q. And who are your passengers? And then Case 18-2868, Document 283, 08/09/2019, 2628241, Page305 of 883 Confidential Page 151 1 2 DAVID RODGERS A. Bill Clinton. Doug Band. Three Secret 3 Service, Jeffrey Epstein, Ghislaine Maxwell, Sarah 4 Kellen. 5 Q. 6 later. 7 8 9 And the next day -- or, sorry, two days Do you know where those passengers stayed in London? A. I have to think about this one second. 10 No, in fact, I don't think they did. 11 didn't spend the night there. 12 to the hotel. 13 word from Secret Service that President Clinton 14 wanted to leave that night, so we left that night. 15 We went there. So we made it to the hotel, the crew did, but we were there not that long. 17 hours, four hours, maybe. 19 20 I got As soon as I got to the hotel, I got 16 18 Because we Q. Two or three Do you remember why he wanted to leave that night? A. No. No, because when we went there, we 21 thought we were going to be there for like probably 22 at least a couple of nights. 23 out -- we didn't even spend one night there. 24 25 Q. Okay. But it didn't turn So does this probably mean that you got there late at night on the 19th, the early Case 18-2868, Document 283, 08/09/2019, 2628241, Page306 of 883 Confidential Page 152 1 2 3 DAVID RODGERS morning on the 21st? A. We took off the 19th. So when we land 4 there, it is really the 20th. 5 took off there, it is like after midnight or 6 thereabouts. 7 Q. And that is when you fly back to JFK? 8 A. Back to JFK, yes. 9 Q. And you went there with three Secret 10 And probably when we Service and came back with 10? 11 A. Yes. 12 Q. How did that happen? 13 A. Well, there was an advance party waiting 14 for us when we got there and then when we came back, 15 they just flew back with us. 16 17 18 19 20 21 Q. What was the events that you were traveling to London for? A. I'm not sure. I would imagine, he was probably giving a speech. Q. Okay. And you came back with Bill Clinton, Doug Band? 22 A. Yes. 23 Q. Who was Doug Band? 24 A. Doug was Bill Clinton's, he's an attorney, 25 and he was like his right-hand guy, really, as far Case 18-2868, Document 283, 08/09/2019, 2628241, Page307 of 883 Confidential Page 153 1 2 3 DAVID RODGERS as doing anything. Q. Okay. And you also flew back with Jeffrey 4 Epstein, Ghislaine Maxwell, Sarah Kellen and Naomi 5 Campbell? 6 A. Yes. 7 Q. How did it happen that Naomi Campbell 8 9 joined the plane to come home? A. I don't know. The same way she joined it 10 before I guess in Montreal. 11 was there. 12 13 Q. I don't know how she And one male, too. All right. It looks like. The next page is page 56, flight 96. 14 A. Okay. 15 Q. Sorry. Let's back up to 94. 16 When the Boeing takes off from JFK, do you 17 know sometime during that trip that you are going to 18 be picking up President Clinton? 19 20 A. Let me see. We went to Paris. 21 22 I think so. Yes, oh, yes. We knew that was going to be a long trip. 23 Q. Okay. 24 A. So we knew at that point in time. 25 almost certain that we knew. I'm Case 18-2868, Document 283, 08/09/2019, 2628241, Page308 of 883 Confidential Page 154 1 DAVID RODGERS 2 Q. What did you know about that trip? 3 A. We knew that was going to be a long trip 4 because we were going to go around the world. 5 So when we departed, it was a about a week 6 later, as I recall, that we picked up Clinton. 7 left JFK on the 11th, a little less than a week. 8 Half a week later, we picked up Clinton and from 9 there, we went to -- Hong Kong. 10 Q. We So you fly in to -- on the 20th, flight 11 99, Jeffrey Epstein, Ghislaine Maxwell, and Sarah 12 Kellen. 13 A. Right. 14 Q. You fly in to a Naval air base in Japan? 15 A. Correct. 16 Q. How were you given access to stay in the 17 Naval air base? 18 MR. PAGLIUCA: 19 THE WITNESS: 20 21 22 23 24 25 Object to foundation. The airplane, you mean? BY MR. EDWARDS: Q. Yes. It looks like it is there two days. That is why -A. I guess because we were picking up President Clinton. Q. And do you know where Jeffrey Epstein, Case 18-2868, Document 283, 08/09/2019, 2628241, Page309 of 883 Confidential Page 155 1 2 DAVID RODGERS Ghislaine Maxwell and Sarah Kellen stayed? 3 A. I do not. 4 Q. Was there a room for them on the Naval air A. No, I don't think -- nobody stayed at the 5 6 7 8 9 base? Naval air base. Q. All right. And then on the 22nd, you leave the Naval air base with -- who is that on that 10 flight? 11 A. Jeffrey Epstein, Ghislaine Maxwell, Sarah 12 Kellen, President Bill Clinton, Mike, Doug Band, 13 Janis and Jessica. 14 15 Q. You flew into the Naval air base with Jeffrey Epstein? 16 A. Plus six other passengers. 17 Q. Okay. 18 A. Most likely. 19 Q. You flew in to the Naval air base with Are those secret service? 20 Jeffrey Epstein, Ghislaine Maxwell and Sarah Kellen 21 only, right? 22 A. Right. 23 Q. And nobody stayed on the Naval air base? 24 A. No. 25 Q. And you are there to pick up Bill Clinton? Case 18-2868, Document 283, 08/09/2019, 2628241, Page310 of 883 Confidential Page 156 1 DAVID RODGERS 2 A. Yes. 3 Q. And you pick up Bill Clinton and six 4 passengers plus Mike? 5 A. Correct. 6 Q. Doug Band, who you have already explained 7 who that is with relation to Bill Clinton, and Janis 8 and Jessica. 9 A. Yes. 10 Q. Do you know who they are? 11 A. Yes. 12 Q. Who are Janis and Jessica? 13 A. Secret Service. 14 Q. How do you remember that? 15 A. Well, there is probably 8, 8 or 9 Secret 16 Service people there, two of them were women. 17 other 7 -- and it was just easier to remember the 18 two women's names than the 7 other guys' names. 19 20 Q. This entry on January 22nd, 2002, Jessica, is that the same or a different Jessica from -- 21 A. On which one? 22 Q. Sure. 23 The Sorry. May 22nd. I think I butchered the date before. 24 A. Right. 25 Q. May 22nd, 2002. Is that the same Jessica Case 18-2868, Document 283, 08/09/2019, 2628241, Page311 of 883 Confidential Page 157 1 2 3 DAVID RODGERS as January 15th, 2002, flying with Jeffrey Epstein? A. 4 5 January 15th. MR. REINHART: Flight 48. BY MR. EDWARDS: 6 Q. Right. 7 A. I'm don't think -- no, I they wouldn't be 8 9 10 It is flight 48. the same Jessica, no. Q. Okay. After you pick up President Bill Clinton, where did you fly? 11 A. We went to Hong Kong. 12 Q. Do you know what the purpose was? 13 A. I believe he was giving a speech. 14 Q. All right. 15 And then from there, where did you fly? 16 A. That would be Shenzhen, Japan -- or China. 17 Q. Okay. 18 And do you remember the purpose there? 19 A. Speech. 20 Q. And then where did you fly? 21 A. Singapore. 22 Q. Again, another speech? 23 A. Another speech. 24 Q. During the course of these days, where did 25 President Bill Clinton sleep? Case 18-2868, Document 283, 08/09/2019, 2628241, Page312 of 883 Confidential Page 158 1 DAVID RODGERS 2 3 4 5 A. I guess at a hotel somewhere. Q. Did he stay at the same place as Jeffrey sure. Epstein, Ghislaine Maxwell and Sarah Kellen? 6 MR. PAGLIUCA: 7 THE WITNESS: 8 9 10 11 Foundation. I don't know. BY MR. EDWARDS: Q. All right. Were meals served on the plane? A. Something was served, but I don't know if 12 you would call it a meal. 13 had catering and stuff. 14 15 16 17 Q. Probably. I'm sure we I just don't recall. That was just typical back then to have meals, especially for the President, right? A. Normally we do not. And we probably did have catering back then, but I don't recall. 18 Q. Okay. 19 A. Singapore, VTBD, I don't know. 20 I'm not Where did you fly from Singapore? You have your cheat sheet over there? 21 Q. VTBD, mine says Thailand. 22 A. I was going to guess Thailand. 23 Then from Thailand, I think we went to -- 24 Q. My cheat sheet says Brunei? 25 A. Exactly. You don't want to go there. Case 18-2868, Document 283, 08/09/2019, 2628241, Page313 of 883 Confidential Page 159 1 DAVID RODGERS 2 Q. You don't? 3 A. No. 4 Q. Okay. 5 Was the purpose a speech at each location to the best of your knowledge? 6 A. To the best of my knowledge, it was. 7 Q. All right. Do you know why it was that 8 Jeffrey Epstein and Ghislaine Maxwell and Sarah 9 Kellen accompanied him? 10 A. No. 11 Q. And then did you leave? 12 13 MR. REINHART: Did you answer that question? 14 THE REPORTER: He said no. 15 MR. REINHART: I didn't hear it. 16 17 18 19 BY MR. EDWARDS: Q. Did you leave President Bill Clinton and Doug Band and the Secret Service in Brunei? A. 20 Hmm. It is possible. What is WRR? 21 Q. Not found. 22 A. Not good. 23 Q. That is the only entry in here that is not 24 25 Sorry. found. But the next one, VCBI says Sri Lanka? Case 18-2868, Document 283, 08/09/2019, 2628241, Page314 of 883 Confidential Page 160 1 2 DAVID RODGERS A. Okay. Then if that says Sri Lanka, then, 3 yes, we probably did leave Clinton in Brunei, I 4 think. 5 We went to Bali without -- And I think we went from there down to Bali. 6 Q. Without Bill Clinton? 7 A. Yes. 8 Q. What was the purpose of the trip to Bali? 9 A. Just to get away. 10 Q. And then to Sri Lanka? 11 A. Sri Lanka was just a fuel stop on the way 12 to Paris. Two fuel stops. 13 Q. That's in Dubai? 14 A. Yes. 15 Q. And then you get to Paris? 16 A. Correct. 17 Q. And then you fly back to London? 18 A. Yes. 19 Q. All right. 20 Yes. Do you remember the purpose of the trip to London? 21 A. Yes. 22 Q. What was that? 23 A. We had to have our APU changed on the 24 airplane. 25 there. It quit working in Paris. And we landed Case 18-2868, Document 283, 08/09/2019, 2628241, Page315 of 883 Confidential Page 161 1 DAVID RODGERS 2 Q. All right. 3 June 21st. 4 leaving from? The next page, page 57, Flight 1570. Where is that flight 5 A. Palm Beach to the Bahamas. 6 Q. And who is on the flight from Palm Beach 7 to the Bahamas? 8 9 10 A. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Cindy Lopez, Jean-Luc Brunel, Virginia Roberts. 11 Q. All right. 12 A. Yes. 13 Q. All right. 14 And that is on June 21st? And then there is a couple of entries that say "reposition." 15 A. Right. 16 Q. That is flying back to Palm Beach and then 17 back down to the Bahamas? 18 19 A. Correct. Yeah, we left them there. we flew the airplane home. 20 Q. 21 on the 23rd. 22 A. Yes. 23 Q. Up to Teterboro. 24 25 And And then did you leave out of the Bahamas And who are your passengers on flight 1573? Case 18-2868, Document 283, 08/09/2019, 2628241, Page316 of 883 Confidential Page 162 1 2 DAVID RODGERS A. Jeffrey Epstein, Ghislaine Maxwell, Sarah 3 Kellen, Cindy Lopez, Juliana Borres, I guess, 4 Jean-Luc Brunel, Melissa Stahl. 5 6 Q. Bahamas. A Virginia Roberts was taken to the Do you know where she went from there? 7 A. I do not. 8 Q. Do you remember a Frederic Fekkai? 9 A. What is the name again? 10 Q. Fekkai, F-E-K-K-A-I. 11 A. First name? 12 Q. Fred. 13 A. Fred. 14 Q. Hairdresser? 15 A. The last name sounds familiar. 16 Q. All right. 17 Frederic Fekkai? He's on a flight No. 116 on the Boeing. 18 A. Uh-huh. 19 Q. June 27th? 20 A. Okay. 21 Q. And there are -- it looks like a bunch of 22 passengers. I see. Do you remember Daralyn Priest? 23 A. No. Where is she? 24 Q. Middle column. 25 A. Daralyn. Oh, yes, I see her. Right. I Case 18-2868, Document 283, 08/09/2019, 2628241, Page317 of 883 Confidential Page 163 1 2 DAVID RODGERS don't remember her. 3 Q. Do you remember that flight? 4 A. To Paris. 5 flight. 6 unusual, going to Paris. Not really. It was a big We had a lot of people on it, which was No, I don't. 7 Q. You don't remember it. 8 A. No. 9 Q. So you don't remember the purpose of the 10 flight? 11 A. No. 12 Q. July 2002, it is page 58. 14 A. Okay. 15 Q. LF? 16 A. That is Nice. 17 Q. And where do you go? 18 A. Tangiers. 19 Q. And then from Tangiers to? 20 A. To another place in Morocco. 13 120. 21 I think it is Marrakesh. 22 one. 23 24 25 Go to flight Marrakesh. I could be wrong on that It is definitely Morocco. Q. From there, is that where you pick up Bill Clinton? A. Let's see. GMME would be Rabat, the Case 18-2868, Document 283, 08/09/2019, 2628241, Page318 of 883 Confidential Page 164 1 2 DAVID RODGERS capital of Morocco, I believe. 3 4 Q. Did you know before this flight that you at some point would be picking up Bill Clinton? 5 A. I think we did, yes. 6 Q. Who was on the flight with Bill Clinton? 7 A. Jeffrey Epstein, Ghislaine Maxwell, Sarah 8 Kellen, Prince Andrew, Cindy Lopez, President 9 Clinton, Doug Band, Mike, with Secret Service and 8 10 Secret Service people. 11 people. 12 Q. So Mike is a person that is also -- that A. He's Secret Service, yes. 13 14 So probably 9 Secret Service is? 15 what I recall. 16 Service. That is just He was the lead guy of the Secret 17 Q. Where do you take Bill Clinton? 18 A. We went to the Azores for a fuel stop and 19 20 then we went to JFK. Q. Kennedy, New York. Then on August 5th, in the Gulfstream, on 21 flight 1586, you leave from Teterboro and go to 22 Santa Fe; is that correct? 23 A. Correct. 24 Q. On that flight, you have Jeffrey 25 Epstein -- sorry, Jeffrey Epstein, Sarah Kellen and Case 18-2868, Document 283, 08/09/2019, 2628241, Page319 of 883 Confidential Page 165 1 DAVID RODGERS 2 two females? 3 A. Yes. 4 Q. Do you know who those two females were? 5 A. No. 6 Q. How long does the plane, the Gulfstream, 7 8 9 stay in Santa Fe? A. Let's see. 1586, Gulfstream. I don't really know, because apparently, we had 1586 and the 10 next one I see is 1589. So it flew three places, 11 but I wasn't on that trip. 12 Q. 1587 and 1588 are missing, right? 13 A. That is what I'm saying. 14 Q. Because you are not on it? 15 A. I'm not on the trip. 16 Q. And 1589? 17 A. Uh-huh. 18 Q. Leaving out of Santa Fe, who are the 19 20 passengers? A. Jeffrey Epstein, Ghislaine Maxwell, Sarah 21 Kellen, Cindy Lopez, Virginia Roberts, Dan Moran, 22 Eduardo, Alfred, Margarita and Nick Simmons. 23 24 25 Q. Do you know how Virginia Roberts got to Santa Fe? A. No. Case 18-2868, Document 283, 08/09/2019, 2628241, Page320 of 883 Confidential Page 166 1 2 3 DAVID RODGERS Q. say, Florida -- well, strike that. 4 5 6 7 Is there any way to get to Santa Fe from, MR. PAGLIUCA: Bus, train, car. BY MR. EDWARDS: Q. Did you ever know Virginia Roberts to take a train? 8 A. Not that I'm aware. 9 Q. Did you ever know her to take a bus? 10 MR. REINHART: 11 THE WITNESS: 12 13 14 15 To go to New Mexico? Not that I'm aware. Maybe she has, but I don't know about it. BY MR. EDWARDS: Q. Okay. I have a picture of her on horseback at the ranch, so who knows. 16 Let's see. August 17th, sorry, 17 August 18th. 18 A. Okay. 19 Q. From Teterboro to Palm Beach? 20 A. Right. 21 Q. Who are your passengers? 22 A. Jeffrey Epstein, Virginia Roberts, one 23 female. 24 Q. 25 All right. female was? Do you remember who that Case 18-2868, Document 283, 08/09/2019, 2628241, Page321 of 883 Confidential Page 219 1 DAVID RODGERS 2 CERTIFICATE OF OATH 3 STATE OF FLORIDA ) 4 COUNTY OF MIAMI-DADE ) 5 6 7 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. 8 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 Cam: 18-7868, 782, 08/00/7010, 7678741, P292277 nf 882 EXHIBIT 16 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page323 of 883 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 May 18, 2016 9:04 a.m. C O N F I D E N T I A L Deposition of JOHANNA SJOBERG, 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 283, 08/09/2019, 2628241, Page324 of 883 Page 8 1 Q. 2 3 Okay. Great. All right. Do you know a female by the name of Ghislaine Maxwell? 4 A. Yes. 5 Q. And when did you first meet Ms. Maxwell? 6 A. 2001. 7 March probably. End of February/beginning of March. 8 Q. And how did you meet her? 9 A. She approached me while I was on campus at 10 Palm Beach Atlantic College. 11 Q. And what happened when she approached you? 12 A. She asked me if I could tell her how to 13 find someone that would come and work at her house. 14 She wanted to know if there was, like, a bulletin 15 board or something that she could post, that she was 16 looking for someone to hire. 17 Q. And what did you discuss with her? 18 A. I told her where she could go to -- you 19 know, to put up a listing. 20 I knew anyone that would be interested in working 21 for her. 22 23 24 25 Q. And then she asked me if Did she describe what that work was going to be? A. She explained that she lived in Palm Beach and didn't want butlers because they're too stuffy. Case 18-2868, Document 283, 08/09/2019, 2628241, Page325 of 883 Page 9 1 And so she just liked to hire girls to work at the 2 house, answer phones, get drinks, do the job a 3 butler would do. 4 5 Q. And did she tell you what she would pay for that kind of a job? 6 A. At that moment, no, but later in the day, 8 Q. And what did she say? 9 A. Twenty dollars an hour. 10 Q. Was there anybody else with Ms. Maxwell 7 11 yes. when you met her? 12 A. There was another woman with her. I don't 13 recall her or what she looks like or how old she 14 was. 15 Q. And what happened next? 16 A. And then she asked me if I would be 17 interested in working for her. 18 she was -- I could trust her and that I could jump 19 in her car and go check out the house at that moment 20 if I wanted. 21 22 And she told me that And so I said, Sure, let's do it, and went to her home with her. 23 Q. And where was that home? 24 A. In Palm Beach. 25 Q. And did she describe that home as being Case 18-2868, Document 283, 08/09/2019, 2628241, Page326 of 883 Page 12 1 magazines. 2 She and I went -- she wanted to take me 3 shopping to Worth Avenue, but it was a Sunday and 4 Nieman Marcus was closed, so we went back to, like, 5 a little book store. 6 think, five pairs of reading glasses because she 7 thought Jeffrey would like them. 8 over the house. 9 glasses. 10 And I remember she bought, I He had them all On every table there was reading And that's about it. It was a pretty 11 simple day. 12 Q. Were you paid that day for that work? 13 A. Yes. 14 Q. And how much were you paid? 15 16 17 Do you remember? A. I don't remember how many hours I was there -- I was there. She paid me cash. 18 Q. So Maxwell paid you? 19 A. Yes. 20 Q. And then was she the one who trained you 21 with what -- with respect to what you were supposed 22 to do during the day, directed you to, like you 23 said, go to -- 24 25 A. I believe she was the one that was kind of showing me around. Case 18-2868, Document 283, 08/09/2019, 2628241, Page327 of 883 Page 13 1 2 Q. And how long did you work in that position answering phones and doing -- 3 A. Just that one day. 4 Q. Just that one day. 5 6 And did your duties change? A. Well, the next time she called me, she 7 asked me if I wanted to come over and make $100 an 8 hour rubbing feet. 9 Q. And what did you think of that offer? 10 A. I thought it was fantastic. 11 Q. And did you come over to the house for 12 that purpose? 13 A. Yes. 14 Q. And when you came over to the house, was 15 Maxwell present? 16 A. I don't recall. 17 Q. And what happened that second time you 18 19 came to the house? A. At that point, I met Emmy Taylor, and she 20 took me up to Jeffrey's bathroom and he was present. 21 And her and I both massaged Jeffrey. 22 showing me how to massage. 23 She was And then she -- he took -- he got off the 24 table, she got on the table. She took off her 25 clothes, got on the table, and then he was showing Case 18-2868, Document 283, 08/09/2019, 2628241, Page328 of 883 Page 14 1 me moves that he liked. 2 off. 3 feel it. 4 5 And then I took my clothes They asked me to get on the table so I could Q. Then they both massaged me. So it was more than a foot massage at that point? 6 A. Yeah, it was mostly, like, legs and back. 7 Q. Was everybody in the room without clothes 9 A. When they were on the massage table, yes. 10 Q. Did they -- when they got off the massage 8 on? 11 table to perform the massage, did they dress or 12 did -- 13 A. Yes. 14 Q. They dressed. 15 16 And do you recall who paid you for that first day that you did the massages? 17 A. I don't recall. 18 Q. Do you recall whether Maxwell was at the 19 house during that first day when you were doing the 20 massage with Emmy and Jeffrey? 21 22 23 MS. MENNINGER: answered. BY MS. McCAWLEY: 24 Q. You can answer. 25 A. I don't recall. Objection, asked and Case 18-2868, Document 283, 08/09/2019, 2628241, Page329 of 883 Page 15 1 Q. Who did Emmy work for? 2 A. Ghislaine. 3 Q. Did Maxwell ever refer to Emmy by any 4 particular term? 5 A. She called her her slave. 6 Q. You said your job duties changed. Did you 7 start to travel as part of your job with Jeffrey and 8 Ghislaine? 9 10 11 12 A. Yes. The next time they called me, they asked me to go to New York. Q. And did you -- do you recall when that was approximately? 13 A. That was Easter of 2001. 14 Q. And do you recall who was on the plane 15 with you for that trip? 16 MS. MENNINGER: 17 MS. McCAWLEY: Objection, leading, form. Actually, I'm going to stop 18 really quickly and I'm going to ask for the 19 next exhibit, please. 20 MS. MENNINGER: 21 MS. McCAWLEY: This is 3? Yes. I'm going to mark 22 this as Exhibit 3 for purposes of the 23 deposition. 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page330 of 883 Page 27 1 leading. 2 THE WITNESS: Jeffrey Epstein; Ghislaine 3 Maxwell; AP and PK are the two women I do not 4 recall; Virginia Roberts; and myself. 5 BY MS. McCAWLEY: 6 7 Q. location in the US Virgin Islands? 8 9 A. They put me on a commercial flight. Q. When you say "they," do you recall who made those arrangements for you? 12 A. It could have been Ghislaine. 13 Q. Did you -- do you recall performing 14 I wanted to be home in time for Easter. 10 11 Do you recall how you flew back from the massages while you were in the US Virgin Islands? 15 A. Yes. 16 Q. Who was involved in -- was there more than A. Yes. 17 18 one? I massaged Ghislaine at one point. 19 And I massaged Jeffrey, Virginia and I, both, on the 20 beach. 21 22 Q. Were you dressed during the massage that was on the beach? 23 A. Yes. Bikinis probably, most likely. 24 Q. Do you recall what Virginia was wearing? 25 A. I believe she was wearing a bathing suit, Case 18-2868, Document 283, 08/09/2019, 2628241, Page331 of 883 Page 32 1 to object and then you can still answer. No 2 one is going to stop you from answering. I 3 just need to get the objection on the record, 4 in the same way she needs to be able to talk 5 before you. 6 cut you off, but I am supposed to get it in 7 before you answer. 8 9 10 I'm not trying to BY MS. McCAWLEY: Q. Did Jeffrey ever tell you why he received so many massages from so many different girls? 11 12 My apologies. MS. MENNINGER: Objection, hearsay. BY MS. McCAWLEY: 13 Q. You can answer. 14 A. He explained to me that, in his opinion, 15 he needed to have three orgasms a day. 16 biological, like eating. 17 18 Q. It was And what was your reaction to that statement? 19 A. I thought it was a little crazy. 20 Q. And what did -- do you recall what -- when 21 you observed the other females giving massages, do 22 you recall what they would dress like? 23 wear scrubs or did they typically wear normal 24 clothes? 25 A. Normal clothes. Did they Case 18-2868, Document 283, 08/09/2019, 2628241, Page332 of 883 Page 33 1 2 3 MS. MENNINGER: Objection, leading. BY MS. McCAWLEY: Q. Do you believe that from your 4 observations, Maxwell and Epstein were boyfriend and 5 girlfriend? 6 A. Initially, yes. 7 Q. Did Maxwell ever share with you whether it 8 bothered her that Jeffrey had so many girls around? 9 10 MS. MENNINGER: hearsay. 11 12 Objection, leading, THE WITNESS: No. Actually, the opposite. BY MS. McCAWLEY: 13 Q. What did she say? 14 A. She let me know that she was -- she would 15 not be able to please him as much as he needed and 16 that is why there were other girls around. 17 18 Q. Did there ever come a time -- did you ever take a photography class in school? 19 A. Yes. 20 Q. And did there ever come a time when 21 22 Maxwell offered to buy you a camera? A. 23 24 25 Yes. MS. MENNINGER: Objection, leading. BY MS. McCAWLEY: Q. Did Maxwell ever offer to buy you a Case 18-2868, Document 283, 08/09/2019, 2628241, Page333 of 883 Page 34 1 camera? 2 MS. MENNINGER: 3 THE WITNESS: 4 5 6 Yes. BY MS. McCAWLEY: Q. Was there anything you were supposed to do in order to get the camera? 7 MS. MENNINGER: 8 THE WITNESS: 9 Objection, leading. Objection, leading. I did not know that there were expectations of me to get the camera until 10 after. 11 and I was over there giving Jeffrey a massage. 12 I did not know that she was in possession of 13 the camera until later. 14 She had purchased the camera for me, She told me -- called me after I had left 15 and said, I have the camera for you, but you 16 cannot receive it yet because you came here and 17 didn't finish your job and I had to finish it 18 for you. 19 20 21 22 23 24 25 BY MS. McCAWLEY: Q. And did you -- what did you understand her to mean? A. She was implying that I did not get Jeffrey off, and so she had to do it. Q. And when you say "get Jeffrey off," do you mean bring him to orgasm? Case 18-2868, Document 283, 08/09/2019, 2628241, Page334 of 883 Page 35 1 A. Yes. 2 Q. Did Ghislaine ever describe to you what 3 types of girls Jeffrey liked? 4 A. Model types. 5 Q. Did Ghislaine ever talk to you about how 6 7 8 9 10 11 12 13 14 15 16 you should act around Jeffrey? A. She just had a conversation with me that I should always act grateful. Q. Did Jeffrey ever tell you that he took a girl's virginity? A. He did not tell me. He told a friend of mine. Q. And what do you recall about that? MS. MENNINGER: Objection, hearsay, foundation. THE WITNESS: He wanted to have a friend 17 of mine come out who was cardio-kickboxer 18 instructor. 19 She was a physical trainer. And so I brought her over to the house, 20 and he told my friend Rachel that -- he said, 21 You see that girl over there laying by the 22 pool? 23 her virginity. 24 mortified. 25 She was 19. And he said, I just took And my friend Rachel was Case 18-2868, Document 283, 08/09/2019, 2628241, Page335 of 883 Page 36 1 2 BY MS. McCAWLEY: Q. Based on what you knew, did Maxwell know 3 that the type of massages Jeffrey was getting 4 typically involved sexual acts? 5 6 MS. MENNINGER: leading. 7 8 Objection, foundation, THE WITNESS: Yes. BY MS. McCAWLEY: 9 Q. What was Maxwell's main job with respect 10 to Jeffrey? 11 MS. MENNINGER: 12 THE WITNESS: Objection, foundation. Well, beyond companionship, 13 her job, as it related to me, was to find other 14 girls that would perform massages for him and 15 herself. 16 17 18 19 BY MS. McCAWLEY: Q. Did Maxwell ever refer to the girls in a particular way? A. At one point when we were in the islands, 20 we were all watching a movie and she called us her 21 children. 22 Q. Did anybody respond to that? 23 A. I don't recall. 24 Q. Did she ever refer to herself as a mother? 25 A. Yes, like a mother hen. Case 18-2868, Document 283, 08/09/2019, 2628241, Page336 of 883 Page 64 1 Q. 2 phone calls? 3 A. 4 Do you remember anything notable about the I just remember I always had to say, He's unavailable, can I take a message? 5 Q. And where did you take a message? 6 A. On a little notepad next to the phone. 7 Q. Do you recall any small children calling 8 the house that day? 9 A. No. 10 Q. Were you speaking to anyone about their 11 school experience or anything like that? 12 A. No. 13 Q. Did you take any messages for famous 14 people? 15 A. 16 17 18 They could have been famous and I would have been clueless. Q. Did you take messages at any other point during the time that you worked with Jeffrey? 19 A. No. 20 Q. And you said you remember at the end of 21 that day being paid by Ghislaine? 22 A. Yes. 23 Q. And you were paid for doing the errands 24 25 and answering phones and whatever else you did? A. Yes. Case 18-2868, Document 283, 08/09/2019, 2628241, Page337 of 883 Page 82 1 2 Q. When you came upstairs, where was Virginia sitting? 3 A. I don't remember. 4 Q. Do you remember what she was wearing? 5 A. No. 6 Q. She was already there when you got back 7 from sightseeing? 8 A. Yes. 9 Q. Tell me what happened with the caricature. 10 A. Ghislaine asked me to come to a closet. 11 She just said, Come with me. 12 and grabbed the puppet, the puppet of Prince Andrew. 13 And I knew it was Prince Andrew because I had 14 recognized him as a person. 15 was. 16 We went to a closet I didn't know who he And so when I saw the tag that said Prince 17 Andrew, then it clicked. 18 is. 19 I'm like, that's who it And we went down -- back down to the 20 living room, and she brought it in. 21 funny because -- he thought it was funny because it 22 was him. 23 24 25 Q. It was just Tell me how it came to be that there was a picture taken. MS. McCAWLEY: Objection. Case 18-2868, Document 283, 08/09/2019, 2628241, Page338 of 883 Page 83 1 THE WITNESS: I just remember someone 2 suggesting a photo, and they told us to go get 3 on the couch. 4 on the couch, and they put the puppet, the 5 puppet on her lap. And so Andrew and Virginia sat 6 And so then I sat on Andrew's lap, and I 7 believe on my own volition, and they took the 8 puppet's hands and put it on Virginia's breast, 9 and so Andrew put his on mine. 10 11 BY MS. MENNINGER: Q. And this was done in a joking manner? 12 MS. McCAWLEY: 13 THE WITNESS: 14 15 16 Objection. Yes. BY MS. MENNINGER: Q. Do you recall a photo being taken of that event? 17 A. Yes. 18 Q. You've never seen the photo? 19 A. No. 20 Q. You don't know whose camera it was? 21 A. No. 22 Q. Virginia was sitting on the couch next to 23 Andrew, not in a big leather armchair? 24 A. Maybe. 25 remember it. I'm just trying to remember how I Case 18-2868, Document 283, 08/09/2019, 2628241, Page339 of 883 Page 142 1 exposed her bra, and she grabbed it and pulled it 2 down. 3 Q. Anything else? 4 A. That was the conversation that he had told 5 her that he had taken this girl's virginity, the 6 girl by the pool. 7 Q. Okay. Did Maxwell ever say to you that it 8 takes the pressure off of her to have other girls 9 around? 10 A. She implied that, yes. 11 Q. In what way? 12 A. Sexually. 13 Q. And earlier Laura asked you, I believe, if 14 Maxwell ever asked you to perform any sexual acts, 15 and I believe your testimony was no, but then you 16 also previously stated that during the camera 17 incident that Maxwell had talked to you about not 18 finishing the job. 19 Did you understand "not finishing the job" 20 meaning bringing Jeffrey to orgasm? 21 MS. MENNINGER: 22 23 24 25 Objection, leading, form. BY MS. McCAWLEY: Q. I'm sorry, Johanna, let me correct that question. What did you understand Maxwell to mean Case 18-2868, Document 283, 08/09/2019, 2628241, Page340 of 883 Page 143 1 when she said you hadn't finished the job, with 2 respect to the camera? 3 MS. MENNINGER: 4 THE WITNESS: 5 brought him to orgasm. 6 7 Objection, leading, form. She implied that I had not BY MS. McCAWLEY: Q. So is it fair to say that Maxwell expected 8 you to perform sexual acts when you were massaging 9 Jeffrey? 10 11 MS. MENNINGER: Objection, leading, form, foundation. 12 THE WITNESS: 13 Yes, I took that conversation to mean that 14 15 16 I can answer? is what was expected of me. BY MS. McCAWLEY: Q. And then you mentioned, I believe, when 17 you were testifying earlier that Jeffrey told you a 18 story about sex on the plane. 19 MS. MENNINGER: 20 THE WITNESS: What was that about? Objection, hearsay. He told me one time Emmy was 21 sleeping on the plane, and they were getting 22 ready to land. 23 and she thought that meant he wanted a blow 24 job, so she started to unzip his pants, and he 25 said, No, no, no, you just have to be awake for And he went and woke her up, Case 18-2868, Document 283, 08/09/2019, 2628241, Page341 of 883 Page 150 1 A. No. 2 Q. Was it in the context of anything? 3 A. About the camera that she had bought for Q. What did she say in relationship to the 4 5 me. 6 camera that she bought for you and taking 7 photographs of you? 8 9 A. Just that Jeffrey would like to have some photos of me, and she asked me to take photos of 10 myself. 11 Q. What did you say? 12 A. I don't remember saying no, but I never 13 ended up following through. I think I tried once. 14 Q. This was the pre-selfie era, correct? 15 A. Exactly. 16 Q. I want to go back to this: You testified 17 to two things just now with Sigrid that you said 18 were implied to you. 19 A. Okay. 20 Q. The first one was it would take pressure 21 off of Maxwell to have more girls around? 22 A. Right. 23 Q. What exactly did Maxwell say to you that 24 25 led you to believe that was her implication? A. She said she doesn't have the time or Case 18-2868, Document 283, 08/09/2019, 2628241, Page342 of 883 Page 160 1 2 3 C E R T I F I C A T E STATE OF FLORIDA ) : ss 4 COUNTY OF MIAMI-DADE ) 5 I, KELLI ANN WILLIS, a Registered 6 Professional, Certified Realtime Reporter and 7 Notary Public within and for The State of 8 Florida, do hereby certify: 9 That JOHANNA SJOBERG, the witness whose 10 deposition is hereinbefore set forth was duly 11 sworn by me and that such Deposition is a true 12 record of the testimony given by the witness. 13 I further certify that I am not related 14 to any of the parties to this action by blood 15 or marriage, and that I am in no way interested 16 in the outcome of this matter. 17 18 IN WITNESS WHEREOF, I have hereunto set my hand this 18th day of May, 2016. 19 20 __________________________ KELLI ANN WILLIS, RPR, CRR 21 22 23 24 25 Cam: 18-7868, 782, 08/00/7010, 7678741, PagprR nf 882 EXHIBIT 17 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page344 of 883 UNITED STATES DISTRICT COURT for the Southern District of New York Civil Action No. VIRGINIA GIUFFRE, Plaintiff, vs. GHISLAINE MAXWELL, Defendant. VIDEO-DEPOSITION Sky Roberts OF: TAKEN BY: Defendant REPORTED BY: Karla Layfield, RMR Stenographic Court Reporter Notary Public State of Florida at Large DATE AND TIME: May 20, 2016; 8:33 a.m. 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 Attorney for Defendant Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, FISTOS LEHRMAN, PL 425 Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Attorney for Plaintiff ALSO PRESENT: Kenneth Sarcony, Videographer Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page345 of 883 Do you remember there being a job posting that you felt like was appropriate for Virginia or did you just go out and talk to the woman who ran the spa area on your own? A I just talked to Angela. Okay. 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 people are seasonal, you know, because it's like snowbirds, you know, summertime comes and nobody wants to be down in south Florida. What would you call the season, the seasonal aspect of Mar?a?Lago? What's the season? A Probably from September or October to, you know, maybe May, I guess. Is that the coolest time? A Times of the year, yes. And it's more guests that come during that period of time? A Yes. And is there more staff brought on during that period of time? Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 72 Case 18-2868, Document 283, 08/09/2019, 2628241, Page346 of 883 we'll call her Angela. A We?ve got to call her something, but, you know, I didn't really know what her job title was, but I was glad that they would give her a job. Right. A You know, and that, you know, I was hoping she would be happy; that way she could, you know, go back and forth to work with me. She didn't have to drive or nothing. Did you drive to and from work with her? A Yes. Pretty sure I did, yeah. Do you remember her hours being relatively the same as yours? A I'm pretty sure they were. Yes. Do you recall her being in school at the same time? A No, I don't recall. I don't remember if she was in school or not. Is it possible it was over, say, winter break or A I don't remember. I'm sorry. This is so long ago. I mean, some things stick in my mind but some things I just don't remember. Do you remember whether Virginia wore a uniform? A Yes, I think she did. Yeah. I think everybody Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 74 Case 18-2868, Document 283, 08/09/2019, 2628241, Page347 of 883 So you don't know if it was a couple days or a couple weeks or a couple months or a couple years? Anything in that -- A Well, it wasn't a couple years. It might have been two weeks to two months. I don't know. It wasn't a whole long time, you know. Where were you when Virginia told you she might be going to try to get this other job? A Probably at work. She might have told me, like, at lunch or whatever. I don't remember. That was so many years ago. I just remember she said Ms. Maxwell was going to, you know, get her a job with Jeffrey Epstein and learn massage therapy. And I thought, well, that's great, you know, because learning new jobs is all about life, you know. You've got to learn each you know, I've learned a lot of different things over my lifetime so it's good to learn every new job you can because that can help you later in life and that's what I think I told her. Okay. So the best you can recall today is you had a conversation with her sometime at lunch perhaps at Mar?a?Lago where she told you she was going to try to get another job? A Yes. And I thought that was a good thing. Do you know now that you recall that, what Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 8O Case 18-2868, Document 283, 08/09/2019, 2628241, Page348 of 883 A No. Did she ever call you from that home? Not that I know of. Was this when she was still living at home with you on Rackley Road? A A Yes. Yes. Not Rackley Drive. Rackley Road. Do you know whether Michael was living with you at Rackley Road at the time or not? A I don't think so. I don't remember. I didn't care for Michael. Of course, what parent cares for your daughter's boyfriend. A Why didn't you care for Michael? I didn't think anybody was good enough for my daughter but that's just me. I suspect you're right about all fathers. Do you remember her telling you anything about what her job with Mr. Epstein was going to be or was? A training? A She said it was going to be massage therapy. Okay. Did she tell you she was getting some Yes. Did she tell you about the training? No. She just said she was being trained in Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page349 of 883 85 massage therapy. All right. When she came home at night from working with Mr. Epstein, did she look distressed to you in any way? A Not that I remember. Okay. Did she report any complaints about her job with Mr. Epstein? A Not to me. Okay. Did she report them to anyone else who then reported them to you? A No. Your wife, for example? A I have no idea. Like I said, if she did tell my wife, I never heard about it. Okay. Have you ever met Ms. Maxwell? A Not that I remember ever meeting her. Do you know what she looks like? A No. Did you ever meet anyone else who worked with Mr. Epstein? A No. Do you remember anyone else who worked for Mr. Epstein bringing your daughter home, for example? A No. 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 Case 18-2868, Document 283, 08/09/2019, 2628241, Page350 of 883 Okay. But your hours, if I understood you right, were approximately 7:00 a.m. to 3:00 A Yes. And Tuesday through Saturday? A Yes. Those hours would be the same time as somebody her age would have been in high school? A Yes. Okay. So does that does that give an indication to you that the short period of time she was working was during the summer when there was not school? A It seems to be that way. Okay. A I mean, to me, yeah. It could have been a summer job? A Yes, it could have been. Okay. You would not have, as a father, had her working somewhere instead of going to school? A No, I wouldn?t. And the day that Virginia came and spoke to you about meeting someone named Ms. Maxwell who was offering her another job, do you remember the conversation that you had with Virginia on that day? A No, not really. I just remember Virginia saying that, you know, she met Ms. Maxwell at the spa and that Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 134 Case 18-2868, Document 283, 08/09/2019, 2628241, Page351 of 883 138 And there it describes her job at Mar-a-Lago as lasting from August 2000 to September of 2001. Do you see that? A Yes. Does that refresh your memory about how long she was working there? MR. EDWARDS: Form. THE WITNESS: She didn't work that long. MS. MENNINGER: Okay. THE WITNESS: Like I say, it was more, like, a couple of weeks. It wasn't BY MS. MENNINGER: Well, earlier you testified it, might have been a couple of months? A Well, you know, for me, two weeks, two months, I mean, I don't even remember how long I worked at Mar?a?Lago. I told you I worked there six years and according to them, it was, like, three years. Seemed like six. Well, earlier you testified that Mar?a?Lago was more of a seasonal place, correct? A Yes, well, it is seasonal. But I mean, they could be open up the spa area during the summer too because I'm sure a lot of people in Palm Beach come to get massages and things like that. I mean, you know, the only Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page352 of 883 139 part they close off is where the chefs and all that, where they didn't do any more big events and stuff. Okay. A But I think the kitchen was still open. I mean, they had a dining room. So if she didn't work there that long August 2000 even though August is in the summer it would not be unusual in your mind? A No. Okay. So she could have started working in August of 2000, correct? A She could have, yeah. And while you don't think she worked all the way until September of 2001 A No. -- that would be consistent with your recollection of it being more seasonal in the fall, September MR. EDWARDS: Object to the form. THE WITNESS: Yes. BY MS. MENNINGER: So if she worked in the fall, September, October, something like that, that seems likes that accords with your memory, correct? MR. EDWARDS: Object to the form. Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com Case 18-2868, Document 283, 08/09/2019, 2628241, Page353 of 883 I I A STATE OF FLORIDA COUNTY OF MARION I, Karla Layfield, RMR, Stenographic Court Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing deposition of Sky Roberts; that said witness was duly sworn to testify truthfully; and that the foregoing pages, numbered 1 through 142, inclusive, constitute a true and correct record of the testimony given by said witness to the best of my ability. I FURTHER CERTIFY that I am not a relative or employee or attorney or counsel of any of the parties hereto, nor a relative or employee of such attorney or counsel, nor am I financially interested in the action. WITNESS MY HAND this day of May, 2016, at Ocala, Marion County, Florida. Karla Layfield, RMR Stenographic Court Reporter Owen Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 owenassocs@aol.com 143 Cam: 18-7868, 782, 08/00/7010, 7678741, Pagpg?d nf 882 EXHIBIT 18 (Filed Under Seal) Case 18-2868, Document 283, 08/09/2019, 2628241, Page355 of 883 slruvin@leopoldlruvin.com 23 Page 1 Page 3 r? SOUTHERN DISTRICT OF FLORIDA CASE ON 2 ROBERT CRITTON, ESQUIRE BURMAN, CRITTON LUTTIER JANE DOE NO- 2: 3 515 North Flagler Drive, Suite 400 Plaintiff: West Palm Beach, Florida 33401 -vs- 4 Phone: 561.842.2820 JEFFREY EPSTEIN 5 inpike@belelaw.eom Defendant. 6 Related cases: 7 08-80232, 08-803 80, 98-80381, 08-80994, 8 08-80993, 08-80811, 08-80893, 09-80469, 9 09-80591, 09-80656, 09-80802, 09-81092 1 1 VIDEOTAPED DEPOSITION OF IUAN ALESSI 1 2 VOLUME I 1 3 Tuesday, September 8, 2009 1 4 10:12 am. - 3:45 p.111. 1 5 6 2139 Palm Beach Lakes Boulevard 1 7 West Palm Beach, Florida 33401 1 8 9 2 0 Reported By: 2 1 Sandra W. Townsend, FPR Notary Public, State of Florida 2 2 PROSE COURT REPORTING AGENCY 2 3 West Palm Beach Office 2 4 2 5 Page 2 Page 4 APPEARANCES: 1 2 On behalf of tlie Plaintiffs: 3 RICHARD WILLITS, ESQUIRE 2 1 1 RICHARD H. WILLITS, RA. 3 4 2290 lOtli Avenue North, Suite 404 Lake Worth, Florida 33461 4 5 1.3110?: 5615827600 NUMBER DESCRIPTION PAGE ieelrliw@hotmail.com 5 6 7 STUART ESQUIRE - - MERMELSTEIN HOROWITZ, PA. 6 number 1 Photographs 45 8 18205 Biscayne Boulevard, Suite 2218 7 Exhiblt number 2 TranSC?p?t 130 Fl 'd 33160 . . . 9 38551932200 8 Exhibit number 3 InCident Report 137 Sim asexabuseat?omsy-com 9 Exhibit number 4 Incorporation Papers Exhibit number 5 Inc orporation Papers 150 ROTHSTEIN ROSENFELDT ADLER 1 12 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 33301 1 2 13 Phone: 954.522.3456 KATHERINE W. EZELL, ESQUIRE 5 PODHURST GRSECK, BA. 16 25 West Flagler Street, Suite 800 6 Miami, Florida 33130 1 7 17 Phone: 305.358.2800 ijosefsberg@podhurst.com 8 1 8 kezell@podhurst.eom 9 9 ADAM I. LANSING, ESQUIRE LEOPOLD KUVIN 2 0 2 0 2925 PGA Boulevard, Suite 200 2 3. Palm Beach Gardens, Florida 33410 21 Phone: 561.515.1400 22 (561) 832-7500 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) PROSE COURT REPORTING AGENCY, INC. 1 (Pages 1 to 4 (561) 832-7506 GIUFFRE000091 Case 18-2868, Document 283, 08/09/2019, 2628241, Page356 of 883 (561) 832-7500 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) PROSE COURT REPORTING AGENCY, Page 4 5 Page 4 7 1 MS. EZELL: I'm going to ask -- I don't know 1 THE WITNESS: Could have been. But, you know 2 Whether you've still been serially designating 2 I am not -- I don't think I am a very good judge of ii 3 Exhibits or whether we're doing them separately for 3 ages. If you ask me how old you are, I really 4 deposition. 4 couldn't tell you. 5 MR. CRITTON: I think we cannot trust that 5 MR. CRITTON: Kathy thinks she?s 25. 6 people will do them serially. I'd do them with 6 MS. EZELL: In my dreams. 7 each one. 7 THE WITNESS: Now, again, I must tell you, I 8 MS. EZELL: Then would you mark this, please, 8 was never told to check any i.dExhibit 1 to this deposition. 9 people who work at the house. 10 And I'm just going to state on the record that 1 0 BY MS. EZELL: 1 1 I will keep that original. We will not attach it 1 1 Q. 1 understand that. And, so, 1 think I'm just 12 to the deposition. 1 2 trying to establish that you didn't consider it part of 13 (Exhibit number 1 was marked for 1 3 your job description to worry about or consider the 1 4 identi?cation purposes and retained by Counsel for the 1 4 ages -- 1 5 PlaintiffsTHE WITNESS: Yes, thatthe young women that came there? 17 BY MS. EZELL: 1 7 A. Absolutely not. Absolutely not. 18 Q. Can you identify that -- the young woman in 1 8 Q. And, so, you never really focused on that or 1 9 those pictures? 1 9 particularly thought about it if they seemed young? 20 A. Yes. 2 0 MR. CRITTON: FormTHE WITNESS: I don't -- I didn't see that 22 A. That's V. -- V. Now that you says R., that 2 2 many young girls, you know, young, underage girls 2 3 is VR. de?nite, a hundred percent. 2 3 at the house. I never saw except the two girls 2 4 MR. CRITTON: Let me just note my objection, 2 4 that I mentioned that I think it was underage was 25 as I did in A. Rod's deposition or Mr. Rodriguez's 2 5 N. for sure because she was still in high school. Page 46 Page 48 1 deposition, that I know you're going to con?scate 1 And she she had dinner with her mother, a couple 2 Exhibit number 1. I think it's inappropriate. I 2 times with her mother. And she become an actress. 3 think I should be allowed to have a copy of 3 She's an actress and she has done movies. And he 4 Exhibits that are being used in deposition. But 4 help her in her career. 5 I'll file a motion with the Court so we don't get 5 That's the only girl that I knew she was young 6 into a pulling match over your Exhibits. 6 because she was going to high school and 1 pick her 7 MR. BERGER: I would ask that the court 7 up from high school sometimesreporter initial that. 8 massage therapist. She wiil go for dinner. And 9 MS. EZELL: Sure. 9 they wiil go for the movies and she sang sometimes 10 Oh, you did? 10 because she was a singer. So she sung at the 1 1 MR. WILLITS: She marked it. 11 house. Beautiful girl. Very talented. 12 MR. BERGER: Did she put her initials or did 12 That's the only girl that I know that it 1 3 she just put a number or a letter? 1 3 was i would says, underage. 14 MR. CRITTON: She's nodding that she did 14 BY MS. EZELL: 15 everything that she usually does, which means, 15 Q. Okay. Did who toid you that V.R. was a 1 6 initials, date and number. 1 6 massage therapist? 17 MR. MERMELSTEIN: You can talk. 17 A. Nobody. 18 MR. WILLITS: But when you talk, use your 18 Q. Did you assume that she was a massage 1 9 initials. 1 9 therapist because you were told she was coming to give 20 BY MS. EZELL: 20 massage? 2 1 Q. How old did you think VR. was at the time she 2 1 A. No. I assumed she was a massage therapy 2 2 began coming to Mr. Epstein?s home? 22 because I was I drove Ms. Maxweil to Mar?a-lago, 2 3 A. She could have been 17, 18, 19. 2 3 Donald Trump's residence. And I wait in the car while 2 4 Q. Could she have also been 15? 24 Ms. Maxweli got a I think it was a facial or massage. MR. CRITTON: Form. 25 I don't know. But that day I remember this girl, V., INC. 832-7506 (561) 102 Case 18-2868, Document 283, 08/09/2019, 2628241, Page357 of 883 Page 49 Page 51 1 walking down from the main lobby towards the spa of 1 there. So I would says, between three months maybe 2 Mar-a-lago. And I was driving Ms. Maxwell up, up the 2 before I left. And think I left at the end of the 3 ramp. It?s a little ramp there. 3 year, so it could have been -- I remember it was a very 4 And Ms. Maxwell says, stop. And she went and 4 hard day because I had to wait in the sun outside in a 5 talked to she went inside. 5 convertible and was dying, waiting for an hour for 6 And that afternoon around 5:00 saw V. came. 6 Ms. Maxwell. I think it was in the summer of 2002. 7 She came to the house already, so she was there already. 7 Q. And if remember correctly, you left in 8 That was the ?rst day I knew. And then she would comt 8 November or December of 2002? 9 regularly. 9 A. Yes. 1 0 Q. Did you ever meet any of V.?s family? 1 0 Q. So that might have been perhaps July or August 1 1 A. No. think she was one time I think her 1 1 of 2002? 12 father drove her there. And I met I don't know if it 12 A. Uh-huh. 1 3 was the boyfriend or husband or but he had to wait, 1 3 Q. And, so, as I understand it, you only saw V.R. 1 4 make him wait outside while she was at the house. 1 4 come to that house during the last three months of your 1 5 Q. Do you know the name or recognize the name 1 5 time at Mr. Epstein?s? 1 6 Tony Santiago? 1 6 A. Yes. 1 7 A. think it was him. 1 7 Q. Do you have any -- any sense or can you 1 8 Q. That was her 1 8 approximate how many times she came? 1 9 A. know he had an old beat-up car, Camaro or 1 9 A. I cannot give you a number, but I would says, 2 Mustang. ll