Key information:
*   Email correspondence.
*   From: [Redacted].
*   To: Jack Scarola.
*   Cc: [Redacted], [Redacted] (USANYS).
*   Subject: RE: 12/04/09 [Redacted] vs Epstein Deposition Transcript
*   Date: Tue, 22 Sep 2020 20:51:53 +0000

Jack,

Thanks for speaking with me earlier today. The attorneys I mentioned are Marc Weinstein and Andrew Tomback, who represent the executors of Epstein's estate. I've provided them with your contact information, and as we discussed, they will likely be in touch to discuss whether you have any objections to them providing the transcript to us.

On this subject, I wanted to let you know that our communications with the estate's attorneys about your client have been limited to our request for the transcript. We have not shared any details regarding your client or her cooperation with our investigation.

Thank you,



From: [REDACTED 1]
Sent: Tuesday, September 22, 2020 11:55 AM
To: [REDACTED 2]
Cc: [REDACTED 3]; [REDACTED 4] (USANYS); [REDACTED 5]
Subject: Re: 12/04/09 [REDACTED] vs [REDACTED] Deposition Transcript

Message (top):
- "I am available right now."
- "Sent from my iPad"

Quoted prior messages:
- On Sep 22, 2020 at 11:41 AM, [REDACTED 2] wrote:
  - "Hi [REDACTED 1], Do you have a moment for a brief call about this today or tomorrow? Thanks, [REDACTED]"
  - "Sent from my iPhone"

- On Sep 14, 2020 at 2:35 PM, [REDACTED 1] wrote:
  - "I am unaware of any protective order relating to the CMA case."

- On Sep 14, 2020 at 12:10 PM, [REDACTED] wrote: (message header shown; content not visible)

EFTA00023750

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,

Key information from the email:

*   **From:** Jack Scarola
*   **Sent:** Thursday, September 10, 2020, 3:46 PM
*   **Subject:** Re: 12/04/09 vs Epstein Deposition Transcript
*   **CC:** USANYS

Please let me know if you are able to locate the transcript.

On Sep 10, 2020, at 11:30 AM,
[REDACTED] < [REDACTED] > 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,

- Image type: email header (screenshot) with heavy redactions
- From: [REDACTED] <[redacted]>
- Sent: Wednesday, September 9, 2020, 9:53 AM
- To: multiple recipients (addresses/names redacted; one recipient label visible as “(USANYS)”)
- Subject: Fwd: 12/04/09 [REDACTED] vs [REDACTED] Deposition Transcript
- Notes: several names and email addresses obscured by black bars; indicates a forwarded message about a 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 3:30:51 PM EDT
To: Jack Scarola <
Cc: Mary McCann < "Wendy P. Calvet" <
"cmavsepsteinetalz6385257@projects.filevine.com" <cmavsepsteinetalz6385257@projects.filevine.com>
Subject: FW: 12/04/09 vs Epstein Deposition Transcript

EFTA00023751

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 M. 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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EFTA00023752