This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →
FBI VOL00009
EFTA00799605
176 pages
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 41 of 176 Exhibit 5 EFTA00799645
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 42 of 176 EISENBERG & Fotrrs, P.A. Attorneys At Law JAMES L. EISENBERG Pieties Bar Board Certified CrindnaltrIel LIMO. Yettienel BORN OtTrittl Advocacy Coinled Candled TrW Advocate EAI LI ALOE ItsIns Oneacirlalto Centre, Suitt) 704,250Australlan Avenue South+ WestPalm Boath,FL33401 361/654-200Fax1561/6594380 February 12, 2007 A. Marie Villefanp Asst. U.S. Attorney 500 South Australian Avenue, Suite 40.0 West Palm Beach, FL 33401 Re:. Dear Marie, for 1 As always, it was a pleasure speaking to you the other day, Pursuant to our telephone conference am writing this letter to proffer iny concerns (erg.= hashould she testify without inununity before.alliMMI„ Therefore, allow meth reiterate that Ms. mitowill refuse to voluntarily cooperate with the federal government, She has a good faith basis for er position wider the Fifth Amendment to the United States Constitution, We, of course, do not live or work in a vacuum. We have read many infiruntriatory remarks the Town of Palm Bewail Police Chief has made to the media about the state court's handling of the Jeffrey. Epstein investigation. The polkachief s remarks frighten both myself and my client. Tam aware that the town police have prepared dc•cuments to charge at least one of Mr. l3pstein's lady friends.in state court. If theyoan push to have one lady ehargedl remain unconvinced that they do not have• the ability or political clout to push to have other ladies such as Ms. ME charged. The Proffered filets that rathe my concerns are being provided via thisprofThr letter. Pursuant to our telephonaconference agreement, this letter and its contents cannot be used against Mr. MIN Ms. Minlis not at all eefitain of dates. She does remember meeting Mr. Bpstoinabout three years ago. She is not certain of her ago, it could have been when she was sixteen, A girlfriend asked her if she wanted a job giving massages. Ms. iviMagreed beetnise she bad knowledge of massages through her mother, who was a. masseuse. MS. Mewerit t0 Mr. Epstein's house via trod. Ms. girlfriend instructed Ms. Ivillthrit, if asked, she had to tell Mr. Epstein that she (M. was eighteen years old. The friend was nineteen years old and Millooked old for her age, so passing for eighttenwas nota problem. At , GOVERNMENT EXHIBIT Case No. 08-80736-CV-MARRA P-003730 EFTA00799646
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 43 of 176 the home Ms' Milinet Mr. Epstein and later gave him a massage. The friend had teildMs. to give the message toplests; Mr. Epstein told lvalthal if she were at all uncomfortable being topless, not to do it and It Was not a requirement of employment as a masseuse. Ms. laneyer touehed.Mr. Epstein in a sexual way and Mr. Epstein never touched Ms. Mild all. At one point, Mr. Epstein, did ask Ms. Milherage. Ms. Milinsisted that she was eighteen years old. Ms. mar.ontinued to see Mr. Epstein over time and massages were given in a similar fashion, She was later asked if her friends wanted to work in a similar way and she asked scime girls who did give Mr. Epstein massages. Ma. Ivilliwas never asked to bring girls of any age to Mr. Epstein's home, When She didhave bet friends some over, she instructed all Of them.that askedeibeY insist that they were eighteen years old. She is not certain at all of any of these girls' real ages. In stunmary, otrr concern is that if the govermnent believes that Mr. Epsteincomunitted some federal offense, thetafs.11licould beconsiderecia co-conspirator, We believes no Crimewas committed.. The Fifth Aniendment was not intended to protect the guilty, he/fever, It was enacted to proteot citizens who fear prosecution notwithstanding their innocence, Our fear of `any prosecution, especially j. ' the :MIND police chiefs public retrofits, is clearly in good faith. Case No. 08-80736-CV-MARRA P-003731 EFTA00799647
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 44 of 176 Exhibit 6 EFTA00799648
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 45 of 176 UNITED STATES DISTRICT COURT SOTJTIIERN DISTRICT OF FLORIDA NORTHERN (WEST PALM BEACH) DIVISION IN RE: / SEALED ORDER On Application of the United States Attorney for the Southern District of Florida, and it appearing to the satisfaction of the Court: 1. That TINMIIIIIhas been called to testify and to provide other information before the United States District Court for the Southern District of Florida, and 2. That in the judgment of the said United States Attorney, 1 MN has refused to testify and provide other information on the basis of her privilege against self-incrimination; and 3. That in the judgment of the said United States Attorney, the testimony and other infonnatiim from' J ME may be necessary to the public interest; and 4. That the aforesaid Application has been made with the approval of the Assistant Attorney General in. charge of the Criminal Division of the Department of Justice or a duly designated Acting Assistant Attorney General, pursuant to the authority vested in hint by Title 18, United States Code, Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and 0.132(e). NOW, IHEREFORE, it is orderedpursuant to Title 18, United States Code, Section 6002, that TOgive testimony and provide other information which she refus • EFTA00799649
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 46 of 176 provide on the basis of herprivilege against self-incrimination, as to all matters aboutwhich she may be interrogated before said United States District Court, as well as any subsequent proceeding or trial. However, no testimony or other information compelled under this Order (orsny information directly or indirectly derived from such testimony or otheiinfomiation) may be used against TM .MIllin any criminal case, except a prosecution for perjury, giving a false statement, or otherwise failing to comply with this Order. IT IS FURTHER ORDERED the this Order shall be SEALED in accordance with Fed. Crim. P. 6(e)(6), except that a copy of this Order shall bo provided to counsel for the United States, who may disclose the existence of the Order to the witness, to counsel for the witness, and to law enforcement officers engaged in the investigation Those persons may review the Order, but may not retain a copy of the Order, nor may they disclose the existence of the Order to any others. DONE and ORDERED this day of April, 200 ie t Palm Beach, Florida. cc: A Marie Villafaila, AUSA DONALD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE 2 ti EFTA00799650
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 47 of 176 Exhibit 7 EFTA00799651
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLED Docket 06/02/2017 Page 48 of 176 U.S. Department of Justice United States Attorney Southern District of Florida DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: SOO S. Australian Ave, Ste 400 West Palos Beach, FL 33401 December 13, 2007 I am writing not to respond to your asserted "policy concerns" regarding Mr. Epstein's Non- Prosecution Agreement, which will be addressed by the United States Attorney, but the time has come for me to respond to the ever-increasing attacks on my role in the investigation and negotiations. It is an understatement to say that I am surprised by your allegations regarding my role because I thought that we had worked very well together in resolving this dispute. I also am surprised because I feel that I bent over backwards to keep in mind the effect that the agreement would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the agreement. For example, I brought to your attention that one potential plea could result in no gain lime for your client; I corrected one of your calculations of the Sentencing Guidelines that would have resulted in Mr. Epstein spending far more time in prison than you projected; I contacted the Bureau of Prisons to see whether Mr. Epstein would be eligible for the prison camp that you desired; and I told you my suspicions about the source of the press "leak" and suggested ways to avoid the press. Importantly, I continued to work with you in a professional manner even after I learned that you had been proceeding in bad faith for several weeks — thinking that I had incorrectly concluded that solicitation of minors to engage in prostitution was a registrable offense and that you would "fool" our Office into letting Mr. Epstein plead to a non-registrable offense. Even now, when it is clear that neither you nor your client ever intended to abide by the terms of the agreement that he signed, I have never alleged misconduct on your part. The rust allegation that you raise is that I "assiduously" hid from you the fact that Bert Ocariz is a friend of my boyfriend and that I have a "longstanding relationship" with Mr. Ocariz. I GOVERNMENT EXHIBIT EFTA00799652
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 49 of 176 JAY P. LEFKOWFTZ, ESQ. DECEMBER 13, 2007 PAGE 2 OF S I informed you that I selected Mr. Ocariz because he was a friend and classmate of two people whom I respected, and that I had never met or spoken with Mr. Ocariz prior to contacting him about this case. All of those facts are true. I still have never met Mr. Ocariz, and, at the time that he and I spoke about this case, he did not know about my relationship with his friend. You suggest that I should have explicitly informed you that one of the referrals came from my "boyfriend" rather than simply a "friend," which is the term I used, but it is not my nature to discuss my personal relationships with opposing counsel. Your attacks on me and on the victims establish why I wanted to find someone whom I could trust with safeguarding the victims' best interests in the face of intense pressure from an unlimited number of highly skilled and well paid attorneys. Mr. Ocariz was that person. One of your letters suggests a business relationship between Mr. Ocariz and my boyfriend. This is patently untrue and neither my boyfriend nor I would have received any financial benefit from Mr. Ocariz's appointment. Furthermore, after Mr. Ocariz learned more about Mr. Epstein's actions (as described below), he expressed a willingness to handle the case pro bono, with no financial benefit even to himself. Furthermore, you were given several other options to choose from, including the Podhurst firm, which was later selected by Judge Davis. You rejected those other options. You also allege that I improperly disclosed information about the case to Mr. Ocariz. I provided Mr. Ocariz with a bare bones summary ofthe agreement's terms related to his appointment to help him decide whether the case was something he and his firm would be willing to undertake. I did not provide Mr. Ocariz with facts related to the investigation because they were confidential and instead recommended that he "Google" Mr. Epstein's name for background information. When Mr. Ocariz asked for additional information to assist his firm in addressing conflicts issues, I forwarded those questions to you, and you raised objections for the first time. I did not share any further information about Mr. Epstein or the case. Since Mr. Ocariz had been told that you concurred in his selection, out of professional courtesy, I informed Mr. Ocariz of the Office's decision to use a Special Master to make the selection and told him that the Office had made contact with Judge Davis. We have had no further contact since then and I have never had contact with Judge Davis. I understand from you that Mr. Ocariz contacted Judge Davis. You criticize his decision to do so, yet you feel that you and your co-counsel were entitled to contact Judge Davis to try to "lobby" him to select someone to your liking, despite the fact that the Non-Prosecution Agreement vested the Office with the exclusive right to select the attorney representative. Another reason for my surprise about your allegations regarding misconduct related to the Section 2255 litigation is your earlier desire to have me perform the role of "facilitator" to convince the victims that the lawyer representative was selected by the Office to represent their interests alone and that the out-of-court settlement of their claims was in their best interests. You now state that doing the same things that you had asked me to do earlier is improper meddling in civil litigation. Much of your letter reiterates the challenges to Detective Recarey's investigation that have EFTA00799653
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLED Docket 06/02/2017 Page 50 of 176 JAY P. LEFKOWITZ, ESQ. DECEMBER 13, 2007 PAGE 3 OF 5 already been submitted to the Office on several occasions and you suggest that I have kept that information from those who reviewed the proposed indictment package. Contrary to your suggestion, those submissions were attached to and incorporated in the proposed indictment package, so your suggestion that I tried to hide something from the reviewers is false. I also take issue with the duplicity of stating that we must accept as true those parts of the Recarey reports and witness statements that you like and we must accept as false those parts that you do not like. You and your co-counsel also impressed upon me from the beginning the need to undertake an independent investigation. It seems inappropriate now to complain because our independent investigation uncovered facts that are unfavorable to your client. You complain that I "forced" your client and the State Attorney's Office to proceed on charges that they do not believe in, yet you do not want our Office to inform the State Attorney's Office of facts that support the additional charge nor do you want any of the victims of that charge to contact Ms. Belohlavek or the Court. Ms. Belohlavek's opinion may change if she knows the full scope of your client's actions. You and I spent several weeks trying to identify and put together a plea to federal charges that your client was willing to accept. Yet your letter now accuses me of "manufacturing" charges of obstruction of justice, making obscene phone calls, and violating child privacy laws. When Mr. Lourie told you that those charges would "embarrass the Office," he meant that the Office was unwilling to bend the facts to satisfy Mr. Epstein's desired prison sentence — a statement with which I agree. I hope that you understand how your accusations that I imposed "ultimatums" and "forced" you and your client to agree to unconscionable contract terms cannot square with the true facts of this case. As explained in letters from Messrs. Acosta and Sloman, the indictment was postponed for more than five months to allow you and Mr. Epstein's other attorneys to make presentations to the Office to convince the Office not to prosecute. Those presentations were unsuccessful. As you mention in your letter, I —a simple line AUSA — handled the primary negotiations for the Office, and conducted those negotiations with you, Ms. Sanchez, Mr. Lewis, and a host of other highly skilled and experienced practitioners. As you put it, your group has a "combined 250 years experience" to my fourteen. The agreement itself was signed by Mr. Epstein, Ms. Sanchez, and Mr. Lcfcourt, whose experience speaks for itself. You and I spent hours negotiating the terms, including when to use "a" versus "the" and other minutiae. When you and I could not reach agreement, you repeatedly went over my head, involving Messrs. Lourie, Menchel, Sloman, and Acosta in the negotiations at various times. In any and all plea negotiations the defendant understands that his options are to plead or to continue with the investigation and proceed to trial. Those were the same options that were proposed to Mr. Epstein, and they are not "persecution or intimidation tactics." Mr. Epstein chose to sign the agreement with the advice of a multitude of extremely noteworthy counsel. You also make much of the fact that the names of the victims were not released to Mr. Epstein prior to signing the Agreement. You never asked for such a .term. During an earlier meeting, where Mr. Black was present, he raised the concern that you now voice. Mr. Black and I did not have a chance to discuss the issue, but 1 had already conceived of a way to resolve that EFTA00799654
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLED Docket 06/02/2017 Page 51 of 176 JAY P. LEFKOvirTZ, ESQ. DECEMBER 13, 2007 PAGE 4 OF 5 issue if it were raised during negotiations. As I stated, it was not, leading me to believe that it was not a matter of concern to the defense. Since the signing of the Non-Prosecution Agreement, the agents and I have vetted the list of victims more than once. In one instance, we decided to remove a name because, although the minor victim was touched inappropriately by Mr. Epstein, we decided that the link to a payment was insufficient to call it "prostitution." I have always remained open to a challenge to the list, so your suggestion that Mr. Epstein was forced to write a blank check is simply unfounded. Your last set of allegations relates to the investigation of the matter. For instance, you claim that some of the victims were informed of their right to collect damages prior to a thorough investigation of their allegations against Mr. Epstein. This also is false. None of the victims was informed of the right to sue under Section 2255 prior to the investigation of the claims. Three victims were notified shortly after the signing of the Non-Prosecution Agreement of the general terms of that Agreement. You raised objections to any victim notification, and no further notifications were done. Throughout this process you have seen that I have prepared this case as though it would proceed to trial. Notifying the witnesses of the possibility of damages claims prior to concluding the matter by plea or trial would only undermine my case. If my reassurances are insufficient, the fact that not a single victim has threatened to sue Mr. Epstein should assure you of the integrity of the investigation.' 'There are numerous other unfounded allegations in your letter about document demands, the money laundering investigation, contacting potential witnesses, speaking with the press, and the like. For the most part, these allegations have been raised and disproven earlier and need not be readdressed. However, with respect to the subpoena served upon the private investigator, contrary to your assertion, and as your co-counsel has already been told, I did consult with the Justice Department prior to issuing the subpoena and I was told that because I was subpoenaing an attorney's office or an office physically located within an attorney's office, and because the business did private investigation work for individuals (rather than working exclusively for Mr. Black), I could issue a grand jury subpoena in the normal course, which is what I did. I also did not "threaten" the State Attorney's Office with a grand jury subpoena, as the correspondence with their grand jury coordinator makes perfectly clear. With regard to your allegation of my filing the Palm Beach Police Department's probable cause affidavit "with the court knowing that the public could access it," I do not know to what you arc referring. All documents related to the grand jury investigation have been filed under seal, and the Palm Beach Police Department's probable cause affidavit has never been filed with the Court. If, in fact, you are referring to the Ex Parte Declaration of Joseph Recarey that was filed in response to the motion to quash the grand jury subpoena, it was filed both under seal and ex parte, so no one should have access to it except the Court and myself. Those documents are still in the Court file only because yaLhave violated one of the tenns of the Agreement by failing to "withdraw [Epstein's] pending motion to intervene and to quash certain grand jury subpoenas." EFTA00799655
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 52 of 176 JAY P. LEFKOWITZ, ESQ. DECEMBER 13, 2007 PAGE 5 OF 5 With respect to Ms. K I contacted her attorney — who was paid for by Mr. Epstein and was directed by counsel for Mr. Epstein to demand immunity — and asked only whether he still represented Ms. MMand if he wanted me to send the victim notification letter to hint. He asked what the letter would say and I told him that the letter would be forthcoming in about a week and that I could not provide him with the terms. With respect to Ms. Ives status as a victim, you again want us to accept as true only facts that are beneficial to your client and to reject as false anything detrimental to him. Ms. NM made a number of statements that are contradicted by documentary evidence and a review of her recorded statement shows her lack of credibility with respect to a number of statements. Based upon all of the evidence collected, Ms. MMis classified as a victim as defined by statute. Of course, that does not mean that Ms. M_considers herself a victim or that she would seek damages from Mr. Epstein. I believe that a number of the identified victims will not seek damages, but that does not negate their legal status as victims. I hope that you now understand that your accusations against myself and the agents are unfounded. In the future, I recommend that you address your accusations to me so that I can correct any misunderstandings before you make false allegations to others in the Department. I hope that we can move forward with a professional resolution of this matter, whether that be by your client's adherence to the contract that he signed, or by virtue of a trial. Sincerely, IL Alexander Acosta United States Attorney By: s/A. Marie Villafaffa A. Marie Villafafia Assistant United States Attorney cc: It Alexander Acosta, U.S. Attorney Jeffrey Sloman, First Assistant U.S. Attorney You also accuse me of "broaden[ing] the scope of the investigation without any foundation for doing so by adding charges of money laundering and violations of a money transmitting business to the investigation." Again, I consulted with the Justice Department's Money Laundering Section about my analysis before expanding that scope. The duty attorney agreed with my analysis. EFTA00799656
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 53 of 176 Exhibit 8 EFTA00799657
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 54 of 176 Case 9:08-cv-80736-KAM Document 304-1 Entered on FLSD Docket 01/30/2015 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE N I and JANE DOE //2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. DECLARATION OF FBI SPECIAL AGENT TIMOTHY R. SLATER TIMOTHY R. SLATER declares as follows: I. I am a Special Agent, Federal Bureau of Investigation (FBI), currently assigned as a Section Chief at FBI Headquarters, Washington, D.C. I was appointed a Special Agent in May 1999. Upon graduation from the FBI Academy at Quantico, Virginia, in September 1999, I was assigned to the Detroit Field Office. I was subsequently transferred to the FBI Miami Field Office in May 2006. 2. In 2006. I was assigned to work on an investigation of Jeffrey Epstein, who was accused of sexually abusing many young girls under the age of 18. In the course of our investigation, the FBI identified many potential victims asexual abuse by Epstein. We obtained names by speaking to other victims, who frequently knew of friends who had also been paid money by Epstein to provide sexual services to him. 3. One of the victims identified was—In January — February 2007,1 used various computer indices to try and locate Ms. By using these indices and other means, I found two international phone numbeis which I believed were being used by Ms. GOVERNMENT EXHIBIT Case g EFTA00799658
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 55 of 176 Case 9:08-cv-80736-KAM Document 304-1 Entered on FLSD Docket 01/30/2015 Page 2 of 3 NIB 4. Sometime during January — February 2007, I called the one of the numbers, in an attempt to speak to Ms. Also in my office was FBI Special Agent Nesbitt E. Kuyrkendall, the lead agent for the investigation of Jeffrey Epstein. I was not using a speakerphone when I spoke with Ms. I asked S/A Kuyrkendall to be present because she, as the lead agent, was thoroughly versed in the details of the entire investigation, and I might need her assistance to respond to a question posed by Ms that I was unable to answer. 5. When I dialed the number, a young woman answered the phone. I told her my name, identified myself as a Special Agent with the FBI, and asked if she was She said yes. I used a technique which I employ when speaking to people on the phone, who might question whether I am truly an FBI agent. I provided her with the phone ntunber of the FBI Field Office in Miami, Florida, and told•her she could hang up and verify the number. She could then call me back at the ntunber, and her call would be routed to inc. Ms. said that would not be necessary. 6. I told Ms. about our investigation of Jeffrey Epstein, and the allegations that Epstein had sexually abused many underage young girls. I told her we believed she might be a victim of sexual abuse by Epstein. 7. Ms. answered basic questions, telling me that she did know Jeffrey Epstein. She quickly became uncomfortable, telling me she moved away to distance herself from this situation, and expressing her desire to "let this be in my past." She asked that I not bother her with this again. 8. I thanked Ms. and told her I appreciated her time. I provided my name and encouraged her to call the FBI Miami Field Office, if she had any questions or needed assistance. 2 Govt Exhibit I) Case No. 06-60736-CIV-MARRA EFTA00799659
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 56 of 176 Case 9:08-cv-80736-KAM Document 304-1 Entered on FLSD Docket 01/30/2015 Page 3 of 3 The entire phone conversation only last several minutes. 9. I did not hear from Ms. again. In mid-March 2007, I reported for my new assignment at FBI Headquarters in Washington, D.C. 10. I declare under penalty of perjury that the foregoing is true and correct. Executed on January 26, 2015. TIMOTHY R. SLATER Section Chief Federal Bureau of Investigation Washington, D.C. 3 Gov't Exhibit D Case No. 08.80736-0N-MARRA EFTA00799660
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 57 of 176 Exhibit 9 EFTA00799661
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 58 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 27 of 100 nsor & Associates Rernnin,aud TranscrimIce, lac. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2006 CF09454AXX STATE OF FLORIDA, -VS- JEFFREY EPSTEIN, Defendant. DEPOSITION OF Wednesday, February 20, 2008 2:00 p.m. - 4:30 p.m. Palm Beach County Courthouse 205 North Dixie Highway West Palm Beach, Florida 33401 Reported By: Judith F. Consor, FPR COPY' Notary Public, State of Florida Consor & Associates Reporting and Transcription Phone - 561.682.0905 Ph. 561.682.0905 - Fax. 561.682,1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 1! GOVERNMENT EXHIBIT I tr W )I 08-80736-C V-MARRA 001233 EFTA00799662
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 59 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/2112008 Page 28 of 100 nsor & Associates Repartins and TraeseripSon, inc. Page 2 1 APPEARANCES: 2 On behalf of the State: 3 LANNA BELOHLAVEK, ESQ. ASSISTANT STATE ATTORNEY 4 401 North Dixie Highway West Palm Beach, Florida 33401 5 561.355.7100 6 On behalf of the Defendant: MICHAEL R. TEIN, ESQ. 7 KATHRYN A. MEYERS, ESQ. LEWIS TEIN, PL 8 3059 GRAND AVENUE, SUITE 340 COCONUT GROVE, FL 33133 9 10 11 12 13 14 On behalf of the Defendant: JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 250 AUSTRALIAN AVENUE SOUTH SUITE 1400 WEST PALM BEACH, FLORIDA 33401 561.659.8300 ALSO PRESENT: ON BEHALF OF THE WITNESS: THEODORE J. LEOPOLD, ESQ. 15 KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, LEGAL-EZE 16 17 18 19 20 21 22 23 24 25 Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 21 /4311 08-80736-CV-MARRA 001234 EFTA00799663
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 60 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 29 of 100 nsor & Associates Repnronp and ItanicrIpcinn, Inc. 1 2 3 WITNESS: INDEX Page 3 PAGE: DIRECT EXAMINATION 4 4 BY MR. TEIN: 5 6 7 NOEXHIBITS MARKED 8 9 CERTIFIED QUESTIONS 10 Page Line 53 22 11 55 1 59 2 12 111 14 112 2 13 14 )5 16 17 18 19 20 21 22 23 24 25 - - - Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 29 oral 08-80736-CV-MARRA 001235 EFTA00799664