From: Jack Scarola
To: r
Cc: '1 Ir <I >, (USANYS)"
Subject: Re: 12/04/09 M. vs Epstein Deposition Transcript
Date: Thu, 10 Sep 2020 19:46:13 +0000
Please let me know if you are able to locate the transcript.
On Sep 10, 2020, at 11:30 AM, )H > 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:
(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
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 c ›
Cc: Mary McCann "Wendy P. Calvet"
"cmaysepsteinetalz6385257@projects.filevine.com" <cmaysepsteinetalz6385257@projects.filevine.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
EFTA00023536
To: Chris R. Rodgers a>
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
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