EFTA00016311

From: Jack Scarola To: ' 9 Cc: "I V ' (USANYS)" > Subject: Re: 12/04/09 . vs Epstein Deposition Transcript Date: Mon, 14 Sep 2020 18:35:38 +0000 I am unaware of any protective order relating to the case. On Sep 14, 2020, at 12:10 PM, l> wrote: Jack, Are you able to tell us whether there was a protective order entered in the civil suit, or any other type of agreement that would govern disclosing materials from the civil case with us? When you shared the deposition, we assumed there were no such restrictions, but I wanted to check. Thanks, From: Jack Scarola Sent: Thursday, September 10, 2020 3:46 PM To: 1< Cc: < (USANYS) < Subject: Re: 12/04/09 . vs Epstein Deposition Transcript Please let me know if you are able to locate the transcript. On Sep 10, 2020, at 11:30 AM, wrote: Jack, Thanks for your email. We will likely reach out to your adversary in the deposition to ask for a copy, but I wanted to check to see whether you had already done so. Thanks, From: Jack Scarola Sent: Wednesday, September 9, 2020 9:53 AM To: I< ).; > (USANYS)< > Subject: Fwd: 12/04/09 vs Epstein Deposition Transcript The email exchange below confirms our inability to locate the first volume of deposition. However, attached are fairly detailed notes of Paralegal/Investigator Mike Danchuk, who attended the deposition and recorded these notes EFTA00016311 contemporaneously. appears to have held nothing back, and the notes certainly paint a picture of the kind of troubled young women who were particularly susceptible to Epstein's pattern of recruitment, grooming and victimization. Sent from my iPad Begin forwarded message: From: "Chris R. Rodgers" Date: September 8, 2020 at 3:30:51PM EDT To: Jack Scarola Cc: Mary McCann .‘c a, "Wendy P. Calvet" c >, "cmaysepsteinetalz6385257@projects.filevine.com" <cmaysepste ineta lz6385257@projects.fileyine.com> Subject: FW: 12/04/09 . vs Epstein Deposition Transcript Jack, below is the "Unable to locate" response from Prose Court Reporting. Visual Evidence, the videography service used, also confirmed on Friday that a copy of the video is no longer available. I have attached Mike Danchuk's notes from that deposition. From: toni proseflorida.com Sent: September 7, 2020 7:03 AM To: Chris R. Rodgers Subject: RE: 12/04/09 vs Epstein Deposition Transcript Chris, I have searched our records and archives and I am unable to locate Volume I of this deposition from 2009. Sincerely, Toni I Privileged and Confidential I Electronic communication is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510- 2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin. 2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this communication is strictly prohibited. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you received this communication in error, please notify the sender immediately by e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank you. EFTA00016312