EFTA00722991Set 9
2009-08-074p1,072w
First ROGS
Answers to Expert ROGS
Initial Replenishable Retainer Agreement & Fee Schedule
Kliman Contemporaneous Notes
Kliman Contemporaneous Notes ID
Transcripts of Interview with Dr. Kliman, Tape ... First ROGS
Answers to Expert ROCS
Initial Replenishable Retainer Agreement & Fee Schedule
Kliman Contemporaneous Notes
Kliman Contemporaneous Notes II
Kliman Contemporaneous Notes III
Transcripts of Interview with Dr. Kliman, Tape ... First RODS
Answers to Expert ROGS
Initial Replenishable Retainer Agreement & Fee Schedule
Kliman Contemporaneous Notes
Kliman Contemporaneous Notes Tape 4
Transcripts of Interview with Dr. Kliman, Tape
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722991.pdf
EFTA00077571Set 9
2017-04-1334p9,022w
conduct.
• Defense 1: The February 29, 2016 meeting was only about Epstein.
AUSA contemporaneous hand-written notes entirely undermine the
government's claim that the February 29, 2016 meeting ... trafficked and abused were focused only on Epstein
and not on Maxwell.
Despite AUSA contemporaneous notes showing that the meeting very much
concerned Maxwell, the government now claims that ... least the best evidence the
government has produced so far—is AUSA contemporaneous notes.8 Ex. J.; Abdell v.
City of New York
https://www.justice.gov/epstein/files/DataSet%209/EFTA00077571.pdf
EFTA00029100Set 8
2017-04-1334p8,943w
conduct.
• Defense 1: The February 29, 2016 meeting was only about Epstein.
AUSA contemporaneous hand-written notes entirely undermine the
government's claim that the February 29, 2016 meeting ... trafficked and abused were focused only on Epstein
and not on Maxwell.
Despite AUSA contemporaneous notes showing that the meeting very much
concerned Maxwell, the government now claims that ... least the best evidence the
government has produced so far—is AUSA contemporaneous notes.8 Ex. J.; Abdel! v.
City of New York
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029100.pdf
EFTA00028929Set 8
2017-04-1334p8,953w
conduct.
• Defense 1: The February 29, 2016 meeting was only about Epstein.
AUSA contemporaneous hand-written notes entirely undermine the
government's claim that the February 29, 2016 meeting ... trafficked and abused were focused only on Epstein
and not on Maxwell.
Despite AUSA contemporaneous notes showing that the meeting very much
concerned Maxwell, the government now claims that ... least the best evidence the
government has produced so far—is AUSA contemporaneous notes.8 Ex. J.; Abdel! v.
City of New York
https://www.justice.gov/epstein/files/DataSet%208/EFTA00028929.pdf
EFTA00009116Set 7
113p25,924w
have an
15 independent recollection of that breakfast, but in the
16 contemporaneous e-mails and the contemporaneous record, there
17 is correspondence between -- between ... Again, no independent recollection. This is just
9 based on inferring from the contemporaneous e-mails.
0 Q Okay.
1 BY MS.
What I would like ... position of fearing review.
23 think if you look at the contemporaneous record, there's an
24 effort on our part to expedite the review.
25 BY MS.
EFTA00009136
Page
https://www.justice.gov/epstein/files/DataSet%207/EFTA00009116.pdf
EFTA00999402Set 9
2014-10-317p3,798w
addition, Mr. Lack personally
paid amounts that petitioner deducted. Nevertheless, the evidence which is contemporaneous
to the events readily establishes that some of the travel expenses were for petitioner ... establish business purpose depends upon the facts and
circumstances of each case, but contemporaneous documentation is deemed more credible
than after-the-fact reconstructions ... these flights
as they were not clearly for petitioner's business and the contemporaneous records do not
show the business purpose of the flights. On other flights Mr. Lack
https://www.justice.gov/epstein/files/DataSet%209/EFTA00999402.pdf
EFTA00065716Set 9
2000-07-2045p12,732w
weakness of
the government's case against Ms. Maxwell, including the lack of corroborative,
contemporaneous documentary evidence in support of the three accusers.
Ms. Maxwell vehemently maintains her innocence ... Lack of corroborating evidence. The government represented to the Court that it
had "contemporaneous documents," including "diary entries" in support of its case.
(Dkt. 4 at 5). The defense ... government had proffered that its "witness testimony will be corroborated
by significant contemporaneous documentary evidence" (Tr. 82).
The additional evidence submitted herewith demonstrates that Ms. Maxwell does have
significant family
https://www.justice.gov/epstein/files/DataSet%209/EFTA00065716.pdf
EFTA00154512Set 9
2000-07-2045p12,732w
weakness of
the government's case against Ms. Maxwell, including the lack of corroborative,
contemporaneous documentary evidence in support of the three accusers.
Ms. Maxwell vehemently maintains her innocence ... Lack of corroborating evidence. The government represented to the Court that it
had "contemporaneous documents," including "diary entries" in support of its case.
(Dkt. 4 at 5). The defense ... government had proffered that its "witness testimony will be corroborated
by significant contemporaneous documentary evidence" (Tr. 82).
The additional evidence submitted herewith demonstrates that Ms. Maxwell does have
significant family
https://www.justice.gov/epstein/files/DataSet%209/EFTA00154512.pdf
EFTA00094289Set 9
2000-07-2045p14,069w
weakness of
the government's case against Ms. Maxwell, including the lack of corroborative,
contemporaneous documentary evidence in support of the three accusers.
Ms. Maxwell vehemently maintains her innocence ... Lack of corroborating evidence. The government represented to the Court that it
had "contemporaneous documents," including "diary entries" in support of its case.
(Dkt. 4 at 5). The defense ... government had proffered that its "witness testimony will be corroborated
by significant contemporaneous documentary evidence" (Tr. 82).
The additional evidence submitted herewith demonstrates that Ms. Maxwell does have
significant family
https://www.justice.gov/epstein/files/DataSet%209/EFTA00094289.pdf
EFTA00180621Set 9
2009-06-30114p22,254w
Addendum to the Non-Prosecution
Agreement ("Addendum"), which are the subject of his contemporaneously filed
emergency petition for certiorari and emergency motion to review denial of stay,
under seal ... STAY
Petitioner, JEFFREY EPSTEIN, moves to file one appendix in support of his
contemporaneously filed emergency petition for writ of certiorari and emergency
motion to review denial of stay ... Motion to Stay
Disclosure of Federal Non-Prosecution Agreement and Addendum pending his
contemporaneously filed petition for certiorari and grant the stay.' Mr. Epstein seeks
review of the stay denial
https://www.justice.gov/epstein/files/DataSet%209/EFTA00180621.pdf
EFTA00601154Set 9
2015-10-15179p36,459w
SCAROLA: 10:25:26
12 Q. Did you take contemporaneous notes of 10:25:30
13 those phone conversations?
14 A. No. I took notes of names, but not really ... defense lawyer, 11:04:34
13 you certainly recognize the importance of a
14 contemporaneous record of significant
15 communications, don't you?
16 A. Sometimes. But it's more ... there something that prevented you 11:04:56
21 from taking contemporaneous notes with regard to
22 these communications?
23 A. I -- I generally don't take
https://www.justice.gov/epstein/files/DataSet%209/EFTA00601154.pdf
EFTA01124129Set 9
2016-01-19216p110,656w
another
share of junior stock, (vi) through the use of proceeds of a
substantially contemporaneous sale of other shares of
junior stock, (vii) any purchase, redemption or other
acquisition ... parity stock or junior stock, (iii) through the use
of proceeds of a substantially contemporaneous sale of
other shares of parity stock or junior stock, (iv) any
purchase, redemption ... another share of junior
stock, (vi) through the use of proceeds of a substantially contemporaneous sale of other shares of junior
stock, (vii) any purchase, redemption or other acquisition
https://www.justice.gov/epstein/files/DataSet%209/EFTA01124129.pdf
EFTA00095558Set 9
2006-07-1914p6,638w
court reporter. Each subject was represented by counsel and had access to relevant
contemporaneous documents before the subject's OPR interview. The subjects reviewed and
provided comments on their respective ... times However, OPR's evaluation of the subjects' conduct was aided significantly
by extensive, contemporaneous emails among the prosecutors and communications between the
government and defense counsel. These records often ... been signed weeks earlier,
or to any other significant decision that benefited Epstein. The contemporaneous records show
that USAO managers' concerns about legal issues, witness credibility, and the impact
https://www.justice.gov/epstein/files/DataSet%209/EFTA00095558.pdf
EFTA00597318Set 9
2017-08-1133p10,597w
them.
The victims have already discussed many of these issues in connection with their
contemporaneously-filed Response in Opposition to the Government's Motion for Summary
Judgment. In the interests ... case." 18
s The victims also adopt the information provided in the contemporaneously-filed Edwards Aff. of August 11, 2017,
to the extent that the Government does not contest ... also Victims' Resp. to Gov't
S.J. Mot., Part VI (filed contemporaneously with this brief). But the simplest way for the Court
to proceed at this juncture is to grant
https://www.justice.gov/epstein/files/DataSet%209/EFTA00597318.pdf
EFTA00011475Set 8
2006-07-1914p6,638w
court reporter. Each subject was represented by counsel and had access to relevant
contemporaneous documents before the subject's OPR interview. The subjects reviewed and
provided comments on their respective ... times However, OPR's evaluation of the subjects' conduct was aided significantly
by extensive, contemporaneous emails among the prosecutors and communications between the
government and defense counsel. These records often ... been signed weeks earlier,
or to any other significant decision that benefited Epstein. The contemporaneous records show
that USAO managers' concerns about legal issues, witness credibility, and the impact
https://www.justice.gov/epstein/files/DataSet%208/EFTA00011475.pdf
EFTA00023059Set 8
2006-07-1914p6,635w
court reporter. Each subject was represented by counsel and had access to relevant
contemporaneous documents before the subject's OPR interview. The subjects reviewed and
provided comments on their respective ... times However, OPR's evaluation of the subjects' conduct was aided significantly
by extensive, contemporaneous emails among the prosecutors and communications between the
government and defense counsel. These records often ... been signed weeks earlier,
or to any other significant decision that benefited Epstein. The contemporaneous records show
that USAO managers' concerns about legal issues, witness credibility, and the impact
https://www.justice.gov/epstein/files/DataSet%208/EFTA00023059.pdf
EFTA00799888Set 9
2017-08-1176p27,084w
F.2d 1017, 1023 (5th Cir. 1975)). In evaluating cross motions, "[a] court must consider
contemporaneously filed a Motion for finding of Waiver of Work Product and Similar Protections ... proceedings." Id. (statement of Senator Feinstein, agreed with by Senator
3 In their contemporaneously-filed motion for partial summary judgment, the victims explain why the Government's
actions so clearly ... Because the Government has placed its internal motivations at issue, the victims have contemporaneously filed a
motion for finding of work product protections over documents that might shed light
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799888.pdf
EFTA00095727Set 9
2006-07-1914p6,633w
court reporter. Each subject was represented by counsel and had access to relevant
contemporaneous documents before the subject's OPR interview. The subjects reviewed and
provided comments on their respective ... times However, OPR's evaluation of the subjects' conduct was aided significantly
by extensive, contemporaneous emails among the prosecutors and communications between the
government and defense counsel. These records often ... been signed weeks earlier,
or to any other significant decision that benefited Epstein. The contemporaneous records show
that USAO managers' concerns about legal issues, witness credibility, and the impact
https://www.justice.gov/epstein/files/DataSet%209/EFTA00095727.pdf