EFTA00799365Set 9
10p2,661w
Broward Blvd., Suite 700
Ft. Lauderdale, FL 33301
He is expected to testify regarding the Ponzi scheme, use of the "Epstein Cases" in the
furtherance thereof.
2. Ken Jenne ... Office
2601 W. Broward Blvd.
Ft. Lauderdale, FL 33312-1308
He is expected to testify regarding the Ponzi scheme, use of the "Epstein Cases" in the
furtherance thereof ... Federal Highway, Suite 800
Ft. Lauderdale, FL 33301
He is expected to testify regarding the Ponzi scheme, use of the "Epstein Cases" in the
furtherance thereof, the abusive practices
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799365.pdf
EFTA00024954Set 8
2013-02-0228p4,678w
required by Rule 16, the
notice identifies topics on which the experts might testify. The Government is therefore not able
to interpose a Dauber: challenge at this time.' The Court ... require the defense to provide
supplemental expert notice forthwith or preclude these witnesses from testifying.
I. APPLICABLE LAW
Federal Rule of Criminal Procedure 16(b)(1)(C) provides that where ... qualifications." Fed. R.
As described below, however, insofar as two of these witnesses will testify as fact witnesses
related to computer forensics and financial records, the Government does not object
https://www.justice.gov/epstein/files/DataSet%208/EFTA00024954.pdf
EFTA00087203Set 9
2021-11-0117p5,289w
qualified as an expert by knowledge, skill, experience, training, or
education may testify in the form of an opinion or otherwise if:
1
EFTA00087203
(a) the expert's scientific, technical ... notice must not merely describe the "general topics" on which experts will testify but
actually "summarize the experts' opinions about those topics" and "describe the bases for the
experts' opinions ... S.D.N.Y. Feb. 2, 2013)
("Merely identifying the general topics about which the expert will testify is insufficient; rather,
the summary must reveal the expert's actual opinions.").
If the Defense
https://www.justice.gov/epstein/files/DataSet%209/EFTA00087203.pdf
EFTA00086375Set 9
2017-05-30143p34,595w
Eisenberg sent a letter detailing the reasons for Ms.
refusal to testify without a compulsion order. This letter, again, discusses the grand jury's
investigation and matters occurring before ... proceedings or trial, and respectfully alleges as follows:
1. That ==. has been called to testify and provide other information before the
United States District Court for the Southern District ... necessary to the public interest.
3. That is likely to refuse to testify or provide other information on the
basis of her privilege against self-incrimination.
4. That this Application
https://www.justice.gov/epstein/files/DataSet%209/EFTA00086375.pdf
EFTA01125055Set 9
2011-04-2042p17,968w
ADLER
9 acknowledged having been first duly sworn to tell the
10 truth, testified upon his oath as follows:
••••••• •••••
EFTA01125056
11 THE WITNESS: I do.
12 DIRECT EXAMINATION ... taking any medications or anything
25 that would impair your ability to testify truthfully
0006
1 today --
2 A No.
3 Q -- or impair your memory ... still am today.
13 Q Now, Brad Edwards, he has testified in his
14 deposition or you have testified today that you knew
15 him also at The Fitness Factory
https://www.justice.gov/epstein/files/DataSet%209/EFTA01125055.pdf
EFTA01116363Set 9
2009-11-0319p5,424w
done many drugs, ecstasy and -- ... and Xanax." (see Depo
Transcript 86:12-15) She testified that she started using drugs when "I was in
seventh and eight and ninth ... course.
(see Depo Transcript 305:5-306:1)
L.M. also testified under oath that she and her friend, E.W., worked as topless
dancers at a strip club when ... other clubs?
A: Yes.
(see Depo Transcript 299:2-300:21)
L.M. also testified that she "probably" told Epstein that she worked at that strip club.
(see Depo Transcript
https://www.justice.gov/epstein/files/DataSet%209/EFTA01116363.pdf
EFTA00594390Set 9
2015-10-17184p37,372w
Thereupon,
2 PAUL G. CASSELL,
3 having been first duly sworn, was examined and testified
4 as follows:
5 THE WITNESS: I do.
6 CONTINUED DIRECT EXAMINATION ... question, and -- and I will note for the record
12 that yesterday, the witness testified that the
13 fact that Mr. Boies was representing
14 was significant ... attorney -- let me rephrase it
20 a different way.
21 You testified yesterday about your
22 understanding of the scope of the alleged
23 common-interest privilege, correct
https://www.justice.gov/epstein/files/DataSet%209/EFTA00594390.pdf
EFTA01655861Set 10
2024-06-0619p11,882w
China Recruiting Western Military Trainers
CRIMINAL INVESTIGATIONS
• Hunter Biden's Ex-Wife, Ex-Girlfriend Testify About Drug Use in Gun Trial
• Judge Reshuffles Hearings in Trump Documents Case
• Detroit Nonprofit ... Cash
for a Juror in Minneapolis
EFTA01655861
• Continued Reporting: FBI Agent Testifies at Menendez Trial About Texts That Allegedly Show How
Senator's Wife Got a Mercedes
• Arrests Made, Guns ... major priority for the Justice
EFTA01655863
Department." USA TODAY (06/05, Russell) explained that Garland testified for nearly five hours on a variety of
topics before the House Judiciary Committee, addressing
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01655861.pdf
EFTA01116345Set 9
2009-11-0318p5,442w
done many drugs, ecstasy and -- ... and Xanax." (see Depo
Transcript 86:12-15) She testified that she started using drugs when "I was in
seventh and eight and ninth ... course.
(see Depo Transcript 305:5-306:1)
L.M. also testified under oath that she and her friend, E.W., worked as topless
dancers at a strip club when ... other clubs?
A: Yes.
(see Depo Transcript 299:2-300:21)
L.M. also testified that she "probably" told Epstein that she worked at that strip club.
(see Depo Transcript
https://www.justice.gov/epstein/files/DataSet%209/EFTA01116345.pdf
EFTA01070585Set 9
2009-10-1223p5,769w
Report.""
If you are called as a witness at trial, prior to testifying, you will be given a copy of ""Your 302"" to
review. It is a record of what ... were lying? The government.
So hem is your um. Do you testify about your doubts about the light, which is the truth, or do
you adopt the ""302"" version ... discrepancies are a result of stupidity or cupidity makes no difference.
Testify in opposition to the ""302"" and you are in the crosshairs of the Feds.
If they believe your
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070585.pdf
EFTA01250614Set 9
2010-04-3038p10,141w
litigation. Ms. Mellon argues that
Tennessee's Shield taw protects her from having to testify in this matter, and further argues that, even if Tennessee's
Shield Law does ... clearly recognized that reporters do not possess a special privilege against being compelled to
testify. In re Grand Jury Proceedings, 810 F.2d 580, 584-85 [13 Med.L.Rptr ... burdensome to the Daily News and to me as a reporter. Forcing me to testify and to give up the
tape of my off-the-record interview would compromise
https://www.justice.gov/epstein/files/DataSet%209/EFTA01250614.pdf
EFTA00076468Set 9
2018-06-1320p6,187w
Conn. Dec. 26, 2007) (holding that prior inconsistent statements of testifying witnesses are
"properly within the scope of [a] Rule 17(c) subpoena").
Evidence showing a witness's motive ... bias, or containing prior
inconsistent statements, however, does not become relevant until the witness testifies. For this
reason, many courts have held that production of impeaching evidence pursuant to Rule ... required until after the witness testifies. United States v. Seabrook, No. 16-CR-467, 2017
WL 4838311, at *2 (S.D.N.Y. Oct. 23, 2017) (Carter, J.) ("(D]espite the fact that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076468.pdf
EFTA00728161Set 9
2009-09-3019p6,423w
whether it was
after I met Jeffity Epstein I had sex with
testified in deposition that "[p]robably a few months
my first boyfriend," See 9/30/09 Deposition of Jane ... excerpts of Jane Doe's deposition transcript are
to meeting Epstein — she had not
testified that she did not have any sexual experiences prior
t or any part ... meeting Epstein. Id. at 62-63.
13. , one of Jane Doe's ex-boyfriends, testified that Jane Doe told him
that she slept with when
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728161.pdf
EFTA00074500Set 9
90p18,563w
Instruction — Similar Act Evidence 71
Defendant's Testimony 72
Defendant's Right Not to Testify 73
Uncalled Witnesses — Equally Available to Both Sides 74
Particular Investigative Techniques Not Required ... direct examination and on cross-
examination? Consider the witness's demeanor, manner of testifying, and accuracy of the
witness's recollection. In addition, consider how well the witness recounted what ... witnesses, you should take into account any evidence that
the witness who testified may benefit in some way from the outcome of this case. If you find
that any witness
https://www.justice.gov/epstein/files/DataSet%209/EFTA00074500.pdf
EFTA00794367Set 9
2017-03-31189p25,264w
believe that it would be
24 appropriate for the plaintiffs to testify, then have Kliman
25 testify, and then during Kliman's testimony there's this staged
SOUTHERN DISTRICT REPORTERS ... need
5 the report for her to get on the stand and testify that she met
6 with FBI agents in 2011. She can just say that without ... well,
17 we don't have the FOIA request. We just have counsel
18 testifying that they issued a FOIA request and got this
19 document. We don't know
https://www.justice.gov/epstein/files/DataSet%209/EFTA00794367.pdf
EFTA00094519Set 9
2020-02-1221p10,022w
client, Gary Franklin, the founder and coach of youth basketball
team California Supreme, testified in court that Avenatti didn't keep him in the loop of the negotiations with ... authorities in cases against not only Mr. Kerik but also Mr. DiTommaso. Mr. Ray
testified against Mr. DiTommaso in a 2012 perjury trial related to the renovation scandal.
Years later ... legal team. Weinstein was not one of them. Though he was inclined to testify, he took the advice of his
attorneys to rest the case in silence. Lawyers consider
https://www.justice.gov/epstein/files/DataSet%209/EFTA00094519.pdf
EFTA00592369Set 9
2017-03-3194p24,655w
believe that it would be
24 appropriate for the plaintiffs to testify, then have Kliman
25 testify, and then during Kliman's testimony there's this staged
SOUTHERN DISTRICT REPORTERS ... need
5 the report for her to get on the stand and testify that she met
6 with FBI agents in 2011. She can just say that without ... well,
17 we don't have the FOIA request. We just have counsel
18 testifying that they issued a FOIA request and got this
19 document. We don't know
https://www.justice.gov/epstein/files/DataSet%209/EFTA00592369.pdf