EFTA01126110Set 9
28p21,420w
whole story, when you met
17 A My practicing name. 17 Russell Adler, et cetera, at the gym and all of that so
18 Q All right. You're Bradley ... still pending? 20 claim for lost time, inability to work, et cetera,
21 A In that case? 21 et cetera, et cetera and his claims for punitive
22 Q Yeah ... think since I started with this, 8 claim for loss of reputation, et cetera.
9 with the diversion of time, effort, when you started the 9 MR. KING: Immaterial
https://www.justice.gov/epstein/files/DataSet%209/EFTA01126110.pdf
EFTA01150049Set 9
2011-06-14272p47,421w
where they're changing
13 around what's Swieca versus which
14 Highbridge, et cetera. I don't recall.
15 It wasn't my business; I don't recall what ... management
23 company expenses primarily as a result of
24 the Gruss actions, et cetera, and sometime
25 -- I forget the timing -- but Glenn wanted
*** UNCERTIFIED ROUGH DRAFT
COPY ONLY ... responsible for the day-to-day management
16 and operations, et cetera, et cetera.
17 Q. Got it.
18 MR. SIFFE
https://www.justice.gov/epstein/files/DataSet%209/EFTA01150049.pdf
EFTA00271746Set 9
2013-12-31100p10,042w
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https://www.justice.gov/epstein/files/DataSet%209/EFTA00271746.pdf
EFTA01103147Set 9
2013-06-1040p8,670w
because many of
9 these records involve our firm, the
10 shareholder agreement, et cetera, and so we
11 have filed a separate motion for protective
12 order ... rely upon, copies of any and all memorandum,
22 diaries, journals, et cetera upon which you
23 rely in support of your allegation of lost
24 time. We are providing ... relying upon.
6 Number 8 asks for copies of all
7 memorandum, diaries, et cetera upon which yon.
8 rely in support of your allegation of injury
9 to your
https://www.justice.gov/epstein/files/DataSet%209/EFTA01103147.pdf
EFTA01108012Set 9
2012-01-2535p7,071w
clear relative to the discovery regarding any of
11 the prior sexual allegations, et cetera. And
12 just so we don't waste your time or our time ... time out to come up here,
23 people's schedules have been made, et cetera,
24 people have traveled long distances, but we may
25 have to quit ... Brad (2) 25:7,12 26:6
27:9 27:7 4:16,16 cetera (2)
24:11
appropriate (2) Avenue (4) Bradley (10) 6:11 10:23
Adler
https://www.justice.gov/epstein/files/DataSet%209/EFTA01108012.pdf
EFTA00723105Set 9
2009-09-3034p24,961w
case was investigated by the Fetal Bureau of
15 Investigation, FBI," et cetera, et cetera.
16
18
17 19 Do you see that ... history, substance 1 to recover medical expenses associated with these
2 abuse history, et cetera, and imposing certain time 2 complex medical issues, full knowledge of the
3 restraints
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723105.pdf
EFTA00059973Set 9
2021-06-15301p49,249w
Correct.
7 : "As an Administrative
8 Lieutenant, responsible for maintaining
9 paperwork, et cetera." So, when you say an
10 Administrative Lieutenant here, are you saying
11 whoever was Acting ... event of an emergency incident, such as
13 fires, bomb threats, et cetera." So, is there
14 a - during these instances - was there an
15 Emergency Preparedness Lieutenant ... Epstein was
25 accommodated with water, visits to the
EFTA00059998
27
1 restroom, et cetera." So, did he receive - and
2 I know, it's my understanding that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00059973.pdf
EFTA00111830Set 9
2021-06-1572p51,184w
responsible for maintaining 8 MR. : So, I guess what I was
9 paperwork, et cetera." So, when you say an 9 etting at is, like, how the SHU Lieutenant ... know if he was on
13 fires, bomb threats, et cetera." So, is there 13 leave both on August 9th and August 10th? Or
14 a - during these instances ... accommodated with water, visits to the
27 28
1 restroom, et cetera." So, did he receive - and 1 MR. : Now, as far as food, I know -
2 I know
https://www.justice.gov/epstein/files/DataSet%209/EFTA00111830.pdf
EFTA01082923Set 9
2011-07-13194p59,682w
airplanes yet they went forward and took the depositions of
2 these pilots, et cetera, on the airplane causing excess
3 fees. And really what this was being used ... could be connected back to the process, i.e. the
17 pilots being deposed, et cetera, and the other one is more
18 flavor for the complaint. But to be able ... them are waived. Many of them are
18 privileged on their face, et cetera. We want to know the
19 who, the how, the when. And then there could
https://www.justice.gov/epstein/files/DataSet%209/EFTA01082923.pdf
EFTA00126647Set 9
2021-06-15301p60,569w
Correct.
7 : "As an Administrative
8 Lieutenant, responsible for maintaining
9 paperwork, et cetera." So, when you say an
10 Administrative Lieutenant here, are you saying
11 whoever was Acting ... event of an emergency incident, such as
13 fires, bomb threats, et cetera." So, is there
14 a - during these instances - was there an
15 Emergency Preparedness Lieutenant ... Epstein was
25 accommodated with water, visits to the
EFTA00126672
27
1 restroom, et cetera." So, did he receive - and
2 I know, it's my understanding that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00126647.pdf
EFTA01103222Set 9
2013-04-2239p9,054w
someone
5 is a signatory, accounts upon which you have
6 withdrawal authority, et cetera. It's a very
7 important distinction. This is a net worth
8 discovery ... some of these requests don't differentiate as
15 to his personal business, et cetera. It's
16 almost impossible to try to answer when it's
17 such ... applicable 17:3,24 21:1 bar 26:17 30:25 cetera 21:6 22:15
14:13 25:17 27:25 23:4 24:3 BARNHART 2:13 chain
https://www.justice.gov/epstein/files/DataSet%209/EFTA01103222.pdf
EFTA01103207Set 9
2013-04-2215p9,025w
have 5 situation before Your Honor. All those cases
6 withdrawal authority, et cetera. It's a very 6 deal with unique issues, two in criminal cases
7 important distinction ... resolution of the case, so it's
15 to his personal business, et cetera. It's 15 not just some abstract concern about Fifth
16 almost impossible ... applicable 17:3,24 21:1 bar 26:17 30:25 cetera 21:6 22:15
14:13 25:17 27:25 23:4 24:3 BARNHART 2:13 chain
https://www.justice.gov/epstein/files/DataSet%209/EFTA01103207.pdf
EFTA01070055Set 9
2011-07-13158p39,441w
airplanes yet they went forward and took the depositions of
2 these pilots, et cetera, on the airplane causing excess
3 fees. And really what this was being used ... could be connected back to the process, i.e. the
17 pilots being deposed, et cetera, and the other one is more
18 flavor for the complaint. But to be able ... them are waived. Many of them are
18 privileged on their face, et cetera. We want to know the
19 who, the how, the when. And then there could
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070055.pdf
EFTA00126362Set 9
2021-06-15285p52,985w
Correct.
7 MR. : "As an Administrative
8 Lieutenant, responsible for maintaining
9 paperwork, et cetera." So, when you say an
10 Administrative Lieutenant here, are you saying
11 whoever ... event of an emergency incident, such as
13 fires, bomb threats, et cetera." So, is there
14 a - during these instances - was there an
15 Emergency Preparedness Lieutenant ... accommodated with water, visits to the
EFTA00126387
LIMITED OFFICIAL USE 27
1 restroom, et cetera." So, did he receive - and
2 I know, it's my understanding that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00126362.pdf
EFTA01069861Set 9
2011-07-13194p59,835w
airplanes yet they went forward and took the depositions of
2 these pilots, et cetera, on the airplane causing excess
3 fees. And really what this was being used ... could be connected back to the process, i.e. the
17 pilots being deposed, et cetera, and the other one is more
18 flavor for the complaint. But to be able ... them are waived. Many of them are
18 privileged on their face, et cetera. We want to know the
19 who, the how, the when. And then there could
https://www.justice.gov/epstein/files/DataSet%209/EFTA01069861.pdf
EFTA00621488Set 9
2011-03-15117p29,066w
problems that will come with that relative to
6 appellate rights, et cetera, that would be
7 before Judge Crow because we can't appeal your
8 ruling ... whom the work-product
14 privilege, attorney-client privilege, privacy
15 privilege, et cetera, has been claimed.
16 SPECIAL MASTER CARNEY: Response.
17 MR. SCAROLA: Thank you, very much. There
https://www.justice.gov/epstein/files/DataSet%209/EFTA00621488.pdf
EFTA00750740Set 9
2009-09-3034p24,488w
case was investigated by the Fetal Bureau of
15 Investigation, FBI," et cetera, et cetera.
16
18
17 19 Do you see that ... history, substance 1 to recover medical expenses associated with these
2 abuse history, et cetera, and imposing certain time 2 complex medical issues, full knowledge of the
3 restraints
https://www.justice.gov/epstein/files/DataSet%209/EFTA00750740.pdf
EFTA01077565Set 9
2011-03-15117p29,114w
problems that will come with that relative to
6 appellate rights, et cetera, that would be
7 before Judge Crow because we can't appeal your
8 ruling ... whom the work-product
14 privilege, attorney-client privilege, privacy
15 privilege, et cetera, has been claimed.
16 SPECIAL MASTER CARNEY: Response.
17 MR. SCAROLA: Thank you, very much. There
https://www.justice.gov/epstein/files/DataSet%209/EFTA01077565.pdf
EFTA01143880Set 9
2013-04-2215p6,284w
someone
5 is a signatory, accounts upon which you have
6 withdrawal authority, et cetera. It's a very
7 important distinction. This is a net worth
8 discovery ... some of these requests don't differentiate as
15 to his personal business, et cetera. It's
16 almost impossible to try to answer when it's
17 such
https://www.justice.gov/epstein/files/DataSet%209/EFTA01143880.pdf