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"Epstein-Depo"
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EFTA00767958
Dataset 9
2009-10-30
2p
106w
Subject:
FW:
Epstein - Depo
of Ghislane Maxwell
From:
story cowles
To:
Jeffrey Epstein <
[email protected]
>
From: story cowles To: Jeffrey Epstein <
[email protected]
> Subject: FW:
Epstein - Depo
of Ghislane Maxwell Date: Fri, 30 Oct 2009 19:38:48 +0000 Attachments: 20091030144402300.pdf This is the notice of taking GM's depo in NYC on the 9th of December. I put it on the calendar. - - On Fri, 10/30/09, From Subject: FW:
Epstein - Depo
of Ghislane Maxwell To: "story cowles" Date: Friday, October 30, 2009, 2:57 PM FY From: Jacquie Johnson [mailto: Sent…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00767958.pdf
EFTA00911546
Dataset 9
2011-05-19
1p
59w
Subject:
Epstein Depo
Corrections
From:
"Harry Susman" I).
To:
"Daniel Reynolds" I).
From: "Harry Susman" I). To: "Daniel Reynolds" I). Cc: "John Siffert" , "Andrew Lee" , "O'Brien, William" Arastu" , "Schwartz, William" Subject:
Epstein Depo
Corrections Date: Thu, 19 May 2011 20:34:05 +0000 Mr. Epstein is out of the country. He will be back in NY on Monday. Can we have until Monday to get you his depo corrections? EFTA00911546
https://www.justice.gov/epstein/files/DataSet%209/EFTA00911546.pdf
EFTA02406993
Dataset 11
2010-05-17
2p
211w
Subject:
Re: Regarding:
Epstein - Depo
of Jean Luc Brunel
From:
Tama Beth Kudman
To:
Beth Williamson
…80119-KAM Document 547-2 Entered on FLSD Docket 05/17/2010 Page 2 of 2 Beth Williamson From: Tama Beth Kudman Sent: Monday. January 25,MINI To: Beth Williamson Subject: Re: Regarding:
Epstein - Depo
of Jean Luc Brunel I have just been informed that my client will be out of the country until the end of March. Please ask Mr Edwards to call me to discuss this. Thank you Sent from my iPhone Tama Beth Kudman On Jan 25…
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02406993.pdf
EFTA00194822
Dataset 9
2015-06-23
18p
3,778w
…Final Contact (file folder) with Non Prosecution Agreement M. & M. Civil Complaints (green file folder) White binder with Westlaw cases CD — Epstein Files to FBI 3.8.2011 provided by CD —
Epstein Depo
of Jeffrey Epstein 2.17.2010 provided by (part 1) EFTA00194827 CD — Mt
Epstein Depo
of Jeffrey Epstein 2.17.2010 provided by (part 2) Box M: Redwell — Stolen Globe folder with draft indictment and documents from case; copies of phone number lists; copies of case law…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00194822.pdf
EFTA00622175
Dataset 9
2005-02-17
54p
7,431w
… see also id. at 199:21-200:7 (Defendant's counsel instructing Defendant not to answer a question about Epstein based on "communications subject to a joint defense agreement or common 5 EFTA00622182 interest agreement"); see also McCawley Dec. Exhibit 2,
Epstein Depo
. Tr. at 20:16-21:8 (Epstein takes the Fifth when asked about a joint defense agreement with Maxwell); id. at 23:3-8 (attorney for Epstein invokes common interest agreement as a basis for Epstein not…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00622175.pdf
EFTA00793499
Dataset 9
2018-10-13
165p
32,130w
…lawyer. I want to know everything that your lawyer told you in this conversation that you have partially disclosed.... What else did he tell you? MR. LINK: So, I'm going to instruct you not to answer based both on attorney- client privilege and exceeds the scope of Judge Hafele's order. I"
Epstein Depo
. Tr. at 22. Clearly Epstein put forward the conversation with his attorney about the disc in paragraph four of his declaration in this case. Accordingly…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793499.pdf
EFTA00081180
Dataset 9
2010-03-17
40p
13,196w
…By Epstein 1. Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "
Epstein Depo
.") (Deposition Attachment #1).1 2. Epstein repeatedly sexually assaulted more than forty (40) young girls on numerous When questioned about this subject at his deposition, Epstein invoked his Fifth Amendment right to remain silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the adverse inference against Epstein that, had Epstein answered, the answer…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00081180.pdf
EFTA01100608
Dataset 9
2011-04-08
30p
8,889w
…the attorney/client privilege. See Deposition of Jeffrey Epstein, Mar. 17, 2010 (hereinafter "
Epstein Depo
.") at 67-68. Therefore summary judgment should be granted for Edwards on all claims involving any Ponzi scheme by Rothstein. b. Epstein Did Not Suffer Any Harm from Allegedly Fraudulent Presentations to Investors. 7 EFTA01100615 Case 09-34791-RBR Doc 1603-2 Filed 04/08/11 Page 9 of 30 At various points in his Complaint, Epstein seems to be alleging that he can pursue…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100608.pdf
EFTA00725998
Dataset 9
2010-03-17
39p
12,410w
…Epstein 1. Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "
Epstein Depo
.") (Deposition Attachment #1).1 2. Epstein repeatedly sexually assaulted more than forty (40) young girls on numerous 1 When questioned about this subject at his deposition, Epstein invoked his Fifth Amendment right to remain silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the adverse inference against Epstein that, had Epstein answered, the answer…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725998.pdf
EFTA00729910
Dataset 9
2010-03-17
38p
12,463w
…Epstein 1. Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "
Epstein Depo
.") (Deposition Attachment #1).1 2. Epstein repeatedly sexually assaulted more than forty (40) young girls on numerous 1 When questioned about this subject at his deposition, Epstein invoked his Fifth Amendment right to remain silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the adverse inference against Epstein that, had Epstein answered, the answer…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00729910.pdf
EFTA01100999
Dataset 9
39p
13,881w
…m going to have to assert the attorney/client privilege. See Deposition of Jeffrey Epstein, Mar. 17, 2010 (hereinafter "
Epstein Depo
.") at 67-68. EFTA01101005 Case No. 502009CA040800XXXXMBAG Edwards Motion for Leave to Amend To Assert a Claim for Punitive Damages Page 8 of 27 B. Epstein Did Not Suffer Any Hann from Allegedly Fraudulent Presentations to Investors. At various points in his Complaint, Epstein seems to have alleged that he can pursue a claim against Edwards because Rothstein defrauded…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100999.pdf
EFTA01076368
Dataset 9
15p
3,397w
…conspirato estified: Q. Does your mom know who is paying for the civil attorneys? A. Yes. Q. How does she know? A. Because I told her. Q. What did you tell her? A. I told her that my attorney was being paid by Mr.
Epstein. depo
at 145). Q. The times that you would bring the other girls, you would get paid money, correct? A. Yes. Q. Who would give you the money? A. Jeffrey [Epstein]. Q. Anyone else? A. …
https://www.justice.gov/epstein/files/DataSet%209/EFTA01076368.pdf
EFTA00725968
Dataset 9
30p
8,528w
…I'm going to have to assert the attorney/client privilege. See Deposition of Jeffrey Epstein, Mar. 17, 2010 (hereinafter "
Epstein Depo
.") at 67-68. Therefore summary judgment should be granted for Edwards on all claims involving any Ponzi scheme by Rothstein. b. Epstein Did Not Suffer Any Harm from Allegedly Fraudulent Presentations to Investors. 7 EFTA00725975 At various points in his Complaint, Epstein seems to be alleging that he can pursue a claim against Edwards because Rothstein defrauded third…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725968.pdf
EFTA01120533
Dataset 9
2010-06-30
29p
8,593w
…Epstein, Mar. 17, 2010 (hereinafter "
Epstein Depo
.") at 67-68. Therefore summary judgment would clearly have been granted for Edwards on all claims involving any Ponzi scheme by Rothstein had the issue not been mooted by Epstein's dismissal of his claims. b. Epstein's Allegations of Negligence by Edwards Were Unfounded and Not Actionable in Any Event. In his Second Amended Complaint Epstein recognized at least the possibility that Edwards was not involved in any Rothstein Ponzi scheme. Therefore…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120533.pdf
EFTA00729953
Dataset 9
29p
8,607w
…I'm going to have to assert the attorney/client privilege. See Deposition of Jeffrey Epstein, Mar. 17, 2010 (hereinafter "
Epstein Depo
.") at 67-68. Therefore summary judgment should be granted for Edwards on all claims involving any Ponzi scheme by Rothstein. b. Epstein Did Not Suffer Any Harm from Allegedly Fraudulent Presentations to Investors. 7 EFTA00729959 At various points in his Complaint, Epstein seems to be alleging that he can pursue a claim against Edwards because Rothstein defrauded third…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00729953.pdf
EFTA01660111
Dataset 10
2010-03-10
10p
2,027w
…KAM Document 547-2 Entered on FLSD Docket 05/17/2010 Page 2 of 2 Beth Williamson From: Tama Beth Kudman [FIIIII I] Sent: Monday, January 25, To: Beth Williamson Subject: Re: Regarding:
Epstein - Depo
of Jean Luc Brunel I have just been informed that my client will be out of the country until the end of March. Please ask Mr Edwards to call me to discuss this. Thank you Sent from my iPhone Tama Beth Kudman On Jan 25…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01660111.pdf
EFTA01695531
Dataset 10
2006-01-01
92p
8,198w
…II) 12. Statement of Martiza Vazques 13. Confidentiality agreement with Ghislaine Maxwell. 14. Jeffrey Probation file Hard Copies: 1. Complete flight logs 2. NPA (several copies) 3. Transcript Jeffrey
Epstein Depo
taken 2/17/2010 in s. EPSTEIN 4. Court Reporter Affidavit (not signed) 5. Copy of portion of Epstein probation file showing Brunel staying there 6. Violation of Probation Jeffrey Epstein 7. Videotape Depo of Epstein taken 2/17/2010 (2 DVDs) EFTA01695607 Flowery Branch, GA 30542 Tony Crystal…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01695531.pdf
EFTA00794324
Dataset 9
2018-11-30
3p
909w
…new documents; Email correspondence with opposing counsel, serve responses; telephone call with Indyke and Link 2.60 1,365.00 11/02/2018 LAM Depo prep-gather & organize documents, email correspondence with paralegal, intemet research, review
Epstein depo
transcript, review doc production by defendant Epstein; draft subpoenas to Sugardaddy, research FIT office of general counsel; email correspondence with Boise et al re. protective order; telephone client- depo prep 5.40 2,835.00 11/04/2018 LAM Depo prep, FaceTime…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00794324.pdf
EFTA00802137
Dataset 9
2011-04-15
2p
466w
…2013 Interrogatories - December 21, 2012 8. BE Notices of Designations Re Page and Line of Depos 9/22/17 Scott Rothstein Depo - 6/14/12 Jeffrey
Epstein Depo
- 3/17/10 Jeffrey
Epstein Depo
- 1/25/12 9. Edwards Motion in Limine to Strike 6/30/17 Affidavit ofJE 9/25/17 and to Exclude Evidence as to which discovery was withheld under claims of privilege 10. Motion to Strike SJM based on law of the case 9/25/17…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802137.pdf
EFTA01105964
Dataset 9
2011-02-23
160p
42,273w
…Johnson RE: Epstein-Notice of production Joint W/P Priv. from non parties/depo of Jane Doe 10372-10373 09/17/2009 Bradley Edwards Katherine Ezell RE: Leslie Wexner Joint W/P Priv. 10490-10493 09/21/2009 Bradley Edwards Amy Ederi FW:
Epstein Depo
Joint W/P Priv. 10592-10593 09/29/2009 Bradley Edwards Katherine Ezell RE: Leslie Wexner Joint W/P Priv. 10604-10620 10/01/2009 Bradley Edwards Katherine Ezell FW:meeting w/ any fr wexner…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01105964.pdf
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