This book was produced in EPUB format by the Internet Archive.

The book pages were scanned and converted to EPUB format automatically. This process relies on optical character recognition, and is somewhat susceptible to errors. The book may not offer the correct reading sequence, and there may be weird characters, non-words, and incorrect guesses at structure. Some page numbers and headers or footers may remain from the scanned page. The process which identifies images might have found stray marks on the page which are not actually images from the book. The hidden page numbering which may be available to your ereader corresponds to the numbered pages in the print edition, but is not an exact match; page numbers will increment at the same rate as the corresponding print edition, but we may have started numbering before the print book's visible page numbers. The Internet Archive is working to improve the scanning process and resulting books, but in the meantime, we hope that this book will be useful to you.

The Internet Archive was founded in 1996 to build an Internet library and to promote universal access to all knowledge. The Archive's purposes include offering permanent access for researchers, historians, scholars, people with disabilities, and the general public to historical collections that exist in digital format. The Internet Archive includes texts, audio, moving images, and software as well as archived web pages, and provides specialized services for information access for the blind and other persons with disabilities.

Created with hocr-to-epub (v.1.0.0)

Case 18-2868, Document 271, 08/09/2019, 2628203, Page1 of 1 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 9" day of August, two thousand nineteen. Julie Brown, Miami Herald Media Company, Intervenors - Appellants. V. ORDER a Docket No: 18-2868 Ghislaine Maxwell, Defendant - Appellee, V. Virginia L. Giuftre, Plaintiff - Appellee. Appellee, Ghislaine Maxwell, filed a petition for panel rehearing, or, 1n the alternative, for rehearing en banc. The panel that determined the appeal has considered the request for panel rehearing, and the active members of the Court have considered the request for rehearing en banc. IT IS HEREBY ORDERED that the petition is denied. FOR THE COURT: Catherine O'Hagan Wolfe, Clerk

Selected docket entries for case 18—2868 Generated: 08/09/2019 10:13:24 Document Description Docket Text 08/09/2019 |272 Order FILED 2 ORDER, dated 08/09/2019, directing the Clerk to issue the mandate forthwith, by JAC, RSP, CFD, FILED.[2628208] [18-2868] oso9/2019|2723 = =—sté<i«é~‘<C:~*é‘ ;CO®#*«*YC SSD GMENT MANDATE, ISSUED.[2628218] [18-2868] 273 Judgment Mandate ISSUED 273 Supporting Document 273 Supporting Document 08/09/2019 |275 UNSEALED SUMMARY 31 JUNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix | of 13 , pursuant to the Court's decision dated DOCKETED July 3, 2019, DOCKETED. [2628223] [18-2868] 08/09/2019 |276 UNSEALED SUMMARY JUDGMENT RECORD, appendix 2 of 13 , pursuant to the Court's decision dated DOCKETED July 3, 2019, DOCKETED. [2628224] [18-2868] 08/09/2019 1277 UNSEALED SUMMARY lite SUMMARY JUDGMENT RECORD. UNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 3 of 13 , pursuant to the Court's decision dated DOCKETED July 3, 2019, DOCKETED. [2628225] [18-2868]

Case 18-2868, Document 272, 08/09/2019, 2628208, Page1 of 2 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT At a Stated Term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 9" day of August, two thousand nineteen. Before: José A. Cabranes, Rosemary S. Pooler, Christopher F. Droney, Circuit Judges. Julie Brown, Miami Herald Media Company, ORDER Intervenors - Appellants, V. 18-2868 Ghislaine Maxwell, Defendant - Appellee, V. Virginia L. Giuffre, Plaintiff - Appellee. Alan M. Dershowitz, Michael Cernovich, DBA Cernovich Media, 16-3945(L) 17-1625(Con) Intervenors - Appellants, 17-1722(Con) V. Virginia L. Giuffre, Plaintiff - Appellee, V. Ghislaine Maxwell, Defendant-Appellee.

Case 18-2868, Document 272, 08/09/2019, 2628208, Page2 of 2 IT IS HEREBY ORDERED that the Clerk 1s directed to issue the mandate forthwith. For the Court: Catherine O’ Hagan Wolfe, Clerk of Court

UNITED STATES COURT OF APPEALS FOR THE CIRCUIT Case 18-2868, Document 273-1, 08/09/2019, 2628218, Pagel of 1 \/| A ARaip te Uniged Stgtes Court of Appeals for the Second Circuit, held at the Th od Mrar: Unvted Stats Céurth ™80 Foley Square, in the City of New York, on the 3™ day of July, two thousand and nineteen. Before: José A. Cabranes, Rosemary S. Pooler, Christopher F. Droney, Circuit Judges. Julie Brown, Miami Herald Media Company, JUDGMENT Intervenors - Appellants. Docket Nos. 18-2868 V. Ghislaine Maxwell, Defendant - Appellee, V. Virginia L. Giuftre, Plaintiff - Appellee. The appeal in the above captioned case from a judgment of the United States District Court for the Southern District of New York was argued on the district court’s record and the parties’ briefs. Upon consideration thereof, IT IS HEREBY ORDERED, ADJUDGED and DECREED that the orders of the District Court entered on November 2, 2016, May 3, 2017, and August 27, 2018 are VACATED. The Court further ORDERS the unsealing of the summary judgment record as described in its opinion. The case is REMANDED to the District Court for a particularized review of the remaining materials. For the Court: Catherine O’ Hagan Wolfe, Clerk of Court A True Copy Catherine O’Hagan Wo fe ele { tL Li i J H us . , r 7 | i a nh 7 oa a r —<e- aa me = rt = aie = | a @ United States Cou ly MANDATE |

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Pagel of 25 18-2868; 16-3945-cv(L) Brown v. Maxwell; Dershowitz v. Giuffre Sn the Gnited States Court of Appeals for the Second Circuit AUGUST TERM 2018 No. 18-2868-cv JULIE BROWN, MIAMI HERALD COMPANY, Intervenors-Appellants, GHISLAINE MAXWELL, Defendant-Appellee, VIRGINIA L. GIUFFRE, Plaintiff-Appellee. No. 16-3945-cv(L) No. 17-1625 (CON) No. 17-1722(CON) ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA, Intervenors-Appellants,

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page2 of 25 V. VIRGINIA L. GIUFFRE, Plaintiff-Appellee, GHISLAINE MAXWELL, Defendant-Appellee.” On Appeal from the United States District Court for the Southern District of New York ARGUED: MARCH 6, 2019 DECIDED: JULY 3, 2019 Before: CABRANES, POOLER, and DRONEY, Circuit Judges. Intervenors-Appellants Alan Dershowitz, Michael Cernovich, and the Miami Herald Company (with reporter Julie Brown) appeal from certain orders of the United States District Court for the Southern District of New York (Robert W. Sweet, Judge) denying their respective motions to unseal filings in a defamation suit. We conclude that the "The Clerk of Court is directed to amend the captions as set out above.

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Pages of 25 District Court failed to conduct the requisite particularized review when ordering the sealing of the materials at issue. At the same time, we recognize the potential damage to privacy and reputation that may accompany public disclosure of hard-fought, sensitive litigation. We therefore clarify the legal tools that district courts should use in safeguarding the integrity of their dockets. Accordingly, we VACATE the District Court’s orders entered on November 2, 2016, May 3, 2017, and August 27, 2018, ORDER the unsealing of the summary judgment record as described further herein, and REMAND the cause to the District Court for particularized review of the remaining sealed materials. Judge Pooler concurs in this opinion except insofar as it orders the immediate unsealing of the summary judgment record without a remand. SANFORD L. BOHRER (Christine N. Walz, Madelaine J. Harrington, New York, NY, on the brief), Holland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald. Ty GEE (Adam Mueller, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell.

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page4 of 25 PAUL G. CASSELL (Sigrid 5. McCawley, Boies Schiller Flexner LLP, Ft. Lauderdale, FL, on the brief), S.J Quinney College of Law, University of Utah, Salt Lake City, UT, for Plaintiff-Appellee Virginia L. Giuffre. ANDREW G. CELLI JR. (David A. Lebowitz, on the brief), Emery, Celli, Brinckerhoff & Abady LLP, New York, NY, for IntervenorAppellant Alan M. Dershowitz. MARC RANDAZZA (Jay Marshall Wolman, Las Vegas, NV, on the brief), Randazza Legal Group, PLLC, Hartford, CT, for IntervenorAppellant Michael Cernovich. JOSE A. CABRANES, Circuit Judge: Intervenors-Appellants Alan M. Dershowitz (“Dershowitz”), Michael Cernovich (“Cernovich”), and the Miami Herald Company (with reporter Julie Brown, jointly the “Herald”) appeal from certain orders of the United States District Court for the Southern District of New York (Robert W. Sweet, Judge) denying their respective motions to unseal filings in a defamation suit. We conclude that the District Court failed to conduct the requisite particularized review when ordering the sealing of the materials at issue. At the same time, we

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Paged of 25 recognize the potential damage to privacy and reputation that may accompany public disclosure of hard-fought, sensitive litigation. We therefore clarify the legal tools that district courts should use in safeguarding the integrity of their dockets. Accordingly, we VACATE the District Court’s orders entered on November 2, 2016, May 3, 2017, and August 27, 2018, ORDER the unsealing of the summary judgment record as described further herein, and REMAND the cause to the District Court for particularized review of the remaining sealed materials. I. BACKGROUND A. Jeffrey Epstein’s Conviction and the CVRA Suit The origins of this case lie in a decade-old criminal proceeding against financier Jeffrey Epstein (“Epstein”). On June 30, 2008, Epstein pleaded guilty to Florida state charges of soliciting, and procuring a person under the age of eighteen for, prostitution. The charges stemmed from sexual activity with privately hired “masseuses,” some of whom were under eighteen, Florida’s age of consent. Pursuant to an agreement with state and federal prosecutors, Epstein pleaded to the state charges. He received limited jail-time, registered as a sex offender, and agreed to pay compensation to his victims. In return, prosecutors declined to bring federal charges. Shortly after Epstein entered his plea, two of his victims, proceeding as “Jane Doe 1” and “Jane Doe 2,” filed suit against the Government in the Southern District of Florida under the Crime Victims’ Rights Act (“CVRA”). The victims sought to nullify the plea

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page6é of 25 agreement, alleging that the Government failed to fulfill its legal obligations to inform and consult with them in the process leading up to Epstein’s plea deal.! On December 30, 2014, two additional unnamed victims—one of whom has now self-identified as Plaintiff-Appellee Virginia Giuffre (“Giuffre”) —petitioned to join in the CVRA case. These petitioners included in their filings not only descriptions of sexual abuse by Epstein, but also new allegations of sexual abuse by several other prominent individuals, “including numerous prominent American politicians, powerful business executives, foreign presidents, a wellknown Prime Minister, and other world leaders,” as well as Dershowitz (a long-time member of the Harvard Law School faculty who had worked on Epstein’s legal defense) and Defendant-Appellee Ghislaine Maxwell (“Maxwell”).? Dershowitz moved to intervene, seeking to “strike the outrageous and impertinent allegations made against him and to request a show cause order to the attorneys that have made them.”° Exercising its authority to “strike from a pleading an insufficient ' On February 21, 2019, the Florida District Court ruled that federal prosecutors had violated the CVRA by failing to adequately notify the two victimsplaintiffs of the plea deal. The District Court has not yet determined the appropriate remedy. See Doe 1 v. United States, 359 F. Supp. 3d 1201, 1204-17 (S.D. Fla. 2019). 2 Doe 1 v. United States, No. 08-CV-80736-KAM, 2015 WL 11254692, at *2 (S.D. Fla. Apr. 7, 2015) (internal quotation marks omitted). 3 Id. (internal quotation marks and brackets omitted).

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page? of 25 defense or any redundant, immaterial, impertinent, or scandalous matter... on its own,”4 the Florida District Court (Kenneth A. Marra, Judge) sua sponte struck all allegations against additional parties from the pleadings, including those against Dershowitz, and therefore denied Dershowitz’s motion as moot.° The stricken allegations, however, quickly found their way into the press, and several media outlets published articles repeating Giuffre’s accusations. In response to the allegations, on January 3, 2015, Maxwell’s publicist issued a press statement declaring that Giuffre’s allegations “against Ghislaine Maxwell are untrue” and that her “claims are obvious lies.”® B. Giuffre Sues Maxwell On September 21, 2015, Giuffre filed the underlying action against Maxwell in the Southern District of New York. Giuffre alleged that Maxwell had defamed her through this and other public statements. Extensive and hard-fought discovery followed. Due to the volume of sealing requests filed during discovery, on August 9, 2016, the District Court entered a Sealing Order that effectively ceded control of the sealing process to the parties themselves. The Sealing Order disposed of the requirement that the parties file individual letter briefs to request sealing and prospectively granted all of the parties’ ‘Fed. R. Civ. P. 12(f). 5 Doe 1, 2015 WL 11254692, at *2-3. © See Giuffre v. Maxwell, 325 F. Supp. 3d 428, 434 (S.D.N.Y. 2018).

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Pages of 25 future sealing requests. In total, 167 documents—nearly one-fifth of the docket—were filed under seal. These sealed documents include, inter alia, motions to compel discovery, motions for sanctions and adverse inferences, motions in limine, and similar material. On January 6, 2017, Maxwell filed a motion for summary judgment. The parties submitted their memoranda of law and supporting exhibits contesting this motion under seal. On March 22, 2017, the District Court denied the motion in a heavily redacted 76page opinion. Once again, the entire summary judgment record, including the unredacted version of the District Court opinion denying summary judgment, remained under seal. On May 24, 2017, Maxwell and Giuffre executed a settlement agreement, and the case was closed the next day. C. Motions to Intervene and Unseal Over the course of the litigation before Judge Sweet, three outside parties attempted to unseal some or all of the sealed material. On August 11, 2016, Dershowitz moved to intervene, seeking to unseal three documents that, he argues, demonstrate that Giuffre invented the accusations against him. On January 19, 2017, Cernovich, an independent blogger and_ self-described “popular political journalist,”” moved to intervene, seeking to unseal the summary judgment record, and Dershowitz joined his motion. On April 6, 2018, after the case had settled, the Herald moved to intervene and unseal ’ Br. Appellant (Cernovich) 4.

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page9 of 25 the entire docket. The District Court granted each of these motions to intervene, but denied the related requests to unseal in orders entered November 2, 2016, May 3, 2017, and August 27, 2018, respectively. The Appellants timely appealed from each of the orders denying their respective motions to unseal. Although each Appellant seeks the release of a different set of documents, all argue that the District Court failed to analyze the documents individually or properly apply the presumption of public access to court documents. We therefore ordered that the appeals be heard in tandem and held argument on March 6, 2019. On March 11, 2019, we issued an order to show cause why we “should not unseal the summary judgment motion, including any materials filed in connection with this motion, and the District Court’s summary judgment decision.”® The parties timely filed their responses. II. DISCUSSION There are two categories of sealed material at issue in these appeals: (1) the summary judgment record, which includes the parties’ summary judgment briefs, their statements of undisputed facts, and incorporated exhibits; and (2) court filings made in the course of the discovery process and with respect to motions in limine. In this Opinion, we explain that our law requires the unsealing of the 5 Giuffre v. Maxwell, No. 18-2868-cv, Docket No. 138.

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page10 of 25 summary judgment materials and individualized review of the remaining sealed materials. While the law governing public access to these materials is largely settled, we have not yet adequately addressed the potential harms that often accompany such access. These harms are apparent. Over forty years ago, the Supreme Court observed that, without vigilance, courts’ files might “become a vehicle for improper purposes.”? Our legal process is already susceptible to abuse. Unscrupulous litigants can weaponize the discovery process to humiliate and embarrass their adversaries. Shielded by the “litigation privilege,”'!° bad actors can defame opponents in court pleadings or depositions without fear of lawsuit and liability. Unfortunately, the presumption of public access to court documents has the potential to exacerbate these harms to privacy and reputation by ensuring that damaging material irrevocably enters the public record. We therefore take the opportunity to describe the tools available to district courts in protecting the integrity of the judicial process, and emphasize the courts’ responsibility to exercise these powerful tools. We also caution the public to critically assess allegations contained in judicial pleadings. ° Nixon v. Warner Comme’ns, Inc., 435 U.S. 589, 598 (1978). 10 See notes 46-47 and accompanying text, post. 10

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page11 of 25 A. Standard of Review When reviewing a district court’s decision to seal a filing or maintain such a seal, “we examine the court’s factual findings for clear error, its legal determinations de novo, and its ultimate decision to seal or unseal for abuse of discretion.” !! B. The Summary Judgment Materials With respect to the first category of materials, it is well-settled that “documents submitted to a court for its consideration in a summary judgment motion are—as a matter of law—yjudicial documents to which a strong presumption of access attaches, under both the common law and the First Amendment.”!? In light of this strong First Amendment presumption, “continued sealing of the documents may be justified only with specific, on-the-record findings that sealing is necessary to preserve higher values and only if the sealing order is narrowly tailored to achieve that aim.” 1! Bernstein v. Bernstein Litowitz Berger & Grossmann LLP, 814 F.3d 132, 139 (2d Cir. 2016). ” Tugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties may “be assumed to have supported their papers with admissible evidence and nonfrivolous arguments.” Id. at 122. Insofar as a district court has, through striking a filing, specifically found that assumption inapplicable, the categorical rule in Lugosch may not apply. See notes 42-43 and accompanying text, post. Td. at 124. Examples of such countervailing values may include, depending on the circumstances, preserving “the right of an accused to fundamental fairness in the jury selection process,” Press-Enter. Co. v. Superior Court 11

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page12 of 25 In this case, the District Court erred in several respects." First, it failed to give proper weight to the presumption of access that attaches to documents filed in connection with summary judgment motions. The District Court reasoned that the summary judgment materials were “entitled to a lesser presumption of access” because “summary judgment was denied by the Court.” In assigning a “lesser presumption” to such materials, the District Court relied on a single sentence of dicta from our decision in United States v. Amodeo.'° We have since clarified, however, that this sentence was based on a “quotation from a partial concurrence and partial dissent in the D.C. Circuit ... [and] is thus not the considered decision of either this court or the D.C. Circuit.”!” In fact, we have expressly rejected the proposition that “different types of documents might receive different of California, Riverside Cty., 464 U.S. 501, 510 (1984); the protection of attorney-client privilege, Lugosch, 435 F.3d at 125; “the danger of impairing law enforcement or judicial efficiency,” SEC. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001); and “the privacy interest of those who resist disclosure,” id. ‘4 Our discussion here focuses specifically on the District Court’s denial of the Herald’s motion to unseal the entire record. Because this decision grants relief to all Appellants, we need not discuss any separate, additional error in the District Court’s denial of the earlier motions to unseal. S Giuffre, 325 F. Supp. 3d at 444. 1671 F.3d 1044, 1049 (2d Cir. 1995) (“Amodeo II”) (“One judge [in the District of Columbia Circuit] has pointed out, for example, that where a district court denied the summary judgment motion, essentially postponing a final determination of substantive legal rights, the public interest in access is not as pressing.” (internal quotation marks omitted; emphasis in original)). 7 Lugosch, 435 F.3d at 121. 12

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page13 of 25 weights of presumption based on the extent to which they were relied upon in resolving [a] motion [for summary judgment].”'® Second, in contravention of our precedent, the District Court failed to review the documents individually and produce “specific, onthe-record findings that sealing is necessary to preserve higher values.”!? Instead, the District Court made generalized statements about the record as a whole.”° This too was legal error. Finally, upon reviewing the summary judgment materials in connection with this appeal, we find that there is no countervailing privacy interest sufficient to justify their continued sealing. Remand with respect to these documents is thus unnecessary. Accordingly, and to avoid any further delay,?! we order that the summary judgment documents (with minimal redactions) be unsealed upon issuance of our mandate.”2 18 Td. at 123. 19 Td. at 124. 0 See, e.g., Giuffre, 325 F. Supp. 3d at 445 (summarily concluding that all “[t]he Summary Judgment Judicial Documents openly refer to and discuss these allegations [of sexual assault and sexual trafficking] in comprehensive detail, and that those allegations “establish[] a strong privacy interest here”). 21 Cf. Lugosch, 435 F.3d at 127 (ordering that “the mandate shall issue forthwith” to expedite the unsealing process). 22 Upon issuance of our mandate, a minimally redacted version of the summary judgment record will be made accessible on the Court of Appeals docket. We have implemented minimal redactions to protect personally identifying information such as personal phone numbers, contact lists, birth dates, and social 13

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page14 of 25 C. The Remaining Sealed Materials The law governing disclosure of the remaining sealed material in this case is only slightly more complex. The Supreme Court has recognized a qualified right “to inspect and copy judicial records and documents.”*° In defining “judicial records and documents,” we have emphasized that “the mere filing of a paper or document with the court is insufficient to render that paper a judicial document subject to the right of public access.”** Instead, “the item filed must be relevant to the performance of the judicial function and useful in the judicial process in order for it to be designated a judicial document.”* As our precedent makes clear, a court “perform[s] the judicial function” not only when it rules on motions currently before it, but also when properly exercising its inherent “supervisory powers.”*° A security numbers. We have also redacted the names of alleged minor victims of sexual abuse from deposition testimony and police reports, as well as deposition responses concerning intimate matters where the questions were likely only permitted —and the responses only compelled—because of a strong expectation of continued confidentiality. See Fed. R. Civ. P. 5.2. While we appreciate the views expressed in Judge Pooler’s separate opinion, the panel majority believes that the efforts invested by three former district judges in reviewing these materials adequately address those concerns. 23 Nixon, 435 U.S. at 597-98. 4 United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) (“Amodeo I’). 5 Td. 6 Cf. United States v. HSBC Bank USA, N.A., 863 F.3d 125, 135 (2d Cir. 2017) (explaining that, in considering whether the report of a monitor charged with assessing compliance with a deferred prosecution agreement is a judicial 14

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page15 of 25 document is thus “relevant to the performance of the judicial function” if it would reasonably have the tendency to influence a district court’s ruling on a motion or in the exercise of its supervisory powers, without regard to which way the court ultimately rules or whether the document ultimately in fact influences the court’s decision.” Accordingly, if in applying these standards, a court determines that documents filed by a party are not relevant to the performance of a judicial function, no presumption of public access attaches.7§ Once an item is deemed relevant to the exercise of judicial power, “the weight to be given the presumption of access must be governed by the role of the material at issue in the exercise of Article III judicial power and the resultant value of such information to those document, “[i]f the district court’s conception of its supervisory power in this context were correct, the Monitor’s Report would quite obviously be relevant to the performance of the judicial function and useful in the judicial process” (internal quotation marks omitted)). Whether a specific judicial decision constitutes a “performance of the judicial function” is a question of law. Accordingly, we review such determinations de novo. Id. at 134. 27 Amodeo I, 44 F.3d at 145-46 (concluding that documents were relevant to the performance of a judicial function because they would have “informed” the district court’s decision whether to discharge or retain a Receiver); see also FTC. v. Standard Fin. Mgmt. Corp., 830 F.2d 404, 409 (1st Cir. 1987) (citing Federal Rule of Evidence 401’s “having any tendency” definition of relevance in determining whether documents were “judicial documents”). 8 As we explain below, there are several (often preferable) tools beyond sealing that district courts can use to protect their dockets from becoming a vehicle for irrelevant—and potentially defamatory — accusations. See Section D, post. 15

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page16 of 25 monitoring the federal courts.””’ Thus, while evidence introduced at trial or in connection with summary judgment enjoys a strong presumption of public access, documents that “play only a negligible role in the performance of Article III duties” are accorded only a low presumption that “amounts to little more than a prediction of public access absent a countervailing reason.”°° Documents that are never filed with the court, but simply “passed between the parties in discovery, lie entirely beyond the presumption’s reach.”3! The remaining sealed materials at issue here include filings related to, inter alia, motions to compel testimony, to quash trial subpoenae, and to exclude certain deposition testimony. All such motions, at least on their face, call upon the court to exercise its Article III powers. Moreover, erroneous judicial decision-making with respect to such evidentiary and discovery matters can cause substantial harm. Such materials are therefore of value “to those monitoring the federal courts.”°? Thus, all documents submitted in connection with, and relevant to, such judicial decision-making are subject to at least some presumption of public access.” 29 Amodeo II, 71 F.3d at 1049. 30 Td. at 1050. 31 Td, 32 Td. at 1049. 33 In previous decisions, we have identified an important exception to this general rule: the presumption of public access does not apply to material that is submitted to the court solely so that the court may decide whether that same 16

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page17 of 25 Although a court’s authority to oversee discovery and control the evidence introduced at trial surely constitutes an exercise of judicial power, we note that this authority is ancillary to the court’s core role in adjudicating a case. Accordingly, the presumption of public access in filings submitted in connection with discovery disputes or motions in limine is generally somewhat lower than the presumption applied to material introduced at trial, or in connection with dispositive motions such as motions for dismissal or summary judgment.* Thus, while a court must still articulate specific and substantial reasons for sealing such material, the reasons usually need not be as compelling as those required to seal summary judgment filings. Here, the precise basis for the District Court’s decision to deny the motion to unseal these remaining materials is unclear. In the three paragraphs devoted to the issue, the District Court emphasized the potential for embarrassment “given the highly sensitive nature of the underlying allegations,” and concluded that “the documents sealed in the course of discovery were neither relied upon by [the District] Court in the rendering of an adjudication, nor necessary to or helpful in resolving a motion.”* It is therefore unclear whether the District Court held that these materials were not judicial documents (and thus are material must be disclosed in the discovery process or shielded by a Protective Order. See TheStreet.Com, 273 F.3d at 233. 34 Amodeo II, 71 F.3d at 1049-50. % Giuffre, 325 F. Supp. 3d. at 442 (internal quotation marks and brackets omitted). 17

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page18 of 25 not subject to a presumption of public access), or found that privacy interests outweighed a limited right of public access. On either interpretation, however, the District Court’s holding was error. Insofar as the District Court held that these materials are not judicial documents because it did not rely on them in adjudicating a motion, this was legal error. As explained above, the proper inquiry is whether the documents are relevant to the performance of the judicial function, not whether they were relied upon.** Indeed, decisionmakers often find that a great deal of relevant material does not ultimately sway their decision. And insofar as the District Court held that privacy interests outweigh the presumption of public access in each of the thousands of pages at issue, that decision— which appears to have been made without particularized review—amounts to an abuse of discretion.?” In light of the District Court’s failure to conduct an individualized review of the sealed materials, it is necessary to do so now. We believe the District Court is best situated to conduct this review. The District Court can directly communicate with the parties, and can therefore more swiftly and thoroughly consider particular objections to unsealing specific materials. Relatedly, the District Court can obtain the parties’ assistance in effecting any necessary redactions, and in notifying any outside parties whose privacy interests might be 36 See text accompanying notes 12-18 and 26-28, ante. 37 See In re City of New York, 607 F.3d 923, 943 n.21 (2d Cir. 2010) (explaining that “abuse of discretion” is a nonpejorative, legal “term of art”). 18

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page19 of 25 implicated by the unsealing. Accordingly, we remand the cause to the District Court to conduct such a particularized review and unseal all documents for which the presumption of public access outweighs any countervailing privacy interests. D. Protecting the Integrity of Judicial Proceedings While we disagree with the District Court’s disposition of the motions to unseal, we share its concern that court files might be used to “promote scandal arising out of unproven potentially libelous statements.”° We therefore describe certain methods courts can employ to protect the judicial process from being coopted for such purposes. The Supreme Court has explained that “[e]very court has supervisory power over its own records and files” to ensure they “are not used to gratify private spite or promote public scandal” or “serve as reservoirs of libelous statements for press consumption.”*? This supervisory function is not only within a district court’s power, but also among its responsibilities. In practice, district courts may employ several methods to fulfill this function. They may, for instance, issue protective orders forbidding dissemination of certain material “to protect a party or person from annoyance, embarrassment, oppression, or undue 8 Giuffre, 325 F. Supp. 3d at 447. °° Nixon, 435 U.S. at 598 (internal quotation marks). 19

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page20 of 25 burden” and require that filings containing such material be submitted under seal.*° If parties then seek to file such materials, the court may deny them leave to do so." District courts may also seek to counteract the effect of defamatory statements by explaining on the record that the statements appear to lack credibility. Moreover, under Federal Rule of Civil Procedure 12(f), the district court may strike such material from the filings on the grounds that it is “redundant, immaterial, impertinent, or scandalous.”** Because such rejected or stricken material is not “relevant to the performance of the judicial function” it would not be considered a “judicial document” and would enjoy no presumption of public access.* Finally, in appropriate 40 Fed. R. Civ. P. 26(c); see also TheStreet.Com, 273 F.3d at 229-30. 41 See, e.g., S.D.N.Y. Electronic Case Filing Rules & Instructions, February 1, 2019 Edition, Rule 6.1, http://nysd.uscourts.gov/ect/ECF%20Rules%20020119%20Final.pdf. Red. R. Civ. P. 12(f). Courts may strike material from the pleadings either “on its own” or “on motion made by a party.” Id. Although motions to strike material solely “on the ground that the matter is impertinent and immaterial” are disfavored, when material is also “scandalous,” no such presumption applies. Cf. Lipsky v. Commonwealth United Corp., 551 F.2d 887, 893 (2d Cir. 1976); see also Talbot v. Robert Matthews Distrib. Co., 961 F.2d 654, 664 (7th Cir. 1992) (“Allegations may be stricken as scandalous if the matter bears no possible relation to the controversy or may cause the objecting party prejudice.”); Wine Markets Int'l, Inc. v. Bass, 177 F.R.D. 128, 133 (E.D.N.Y. 1998) (“Motions to strike are not generally favored, except in relation to scandalous matters.”); Alvarado-Morales v. Digital Equip. Corp., 843 F.2d 613, 617-18 (1st Cir. 1988) (categorizing as scandalous “matter which impugned the character of defendants”). 43 Amodeo I, 44 F.3d at 145. 20

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page21 of 25 circumstances, district courts may impose sanctions on attorneys and parties under Federal Rule of Civil Procedure 11(c).“ E. A Cautionary Note We conclude with a note of caution to the public regarding the reliability of court filings such as those unsealed today. Materials submitted by parties to a court should be understood for what they are. They do not reflect the court’s own findings. Rather, they are prepared by parties seeking to advance their own interests in an adversarial process. Although affidavits and depositions are J offered “under penalty of perjury,” it is in fact exceedingly rare for anyone to be prosecuted for perjury in a civil proceeding.* Similarly, “4 In relevant part, Rule 11 provides: By presenting to the court a pleading, written motion, or other paper... an attorney or unrepresented party certifies that... it is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation... . [T]he court may impose an appropriate sanction on any attorney, law firm, or party that violated the rule or is responsible for the violation . . . . The sanction may include nonmonetary directives; an order to pay a penalty into court; or, if imposed on motion and warranted for effective deterrence, an order directing payment to the movant of part or all of the reasonable attorney’s fees and other expenses directly resulting from the violation. Fed. R. Civ. P. 11. See also Amodeo II, 71 F.3d at 1049 (describing sanctions available to the court). 45 Sonia Sotomayor & Nicole A. Gordon, Returning Majesty to the Law and Politics: A Modern Approach, 30 Suffolk U. L. Rev. 35, 47 n.52 (1996) ("Perjury cases are not often pursued ....”). 21

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page22 of 25 pleadings, complaints, and briefs—while supposedly based on underlying evidentiary material—can be misleading. Such documents sometimes draw dubious inferences from already questionable material or present ambiguous material as definitive. Moreover, court filings are, in some respects, particularly susceptible to fraud. For while the threat of defamation actions may deter malicious falsehoods in standard publications, this threat is nonexistent with respect to certain court filings. This is so because, under New York law (which governs the underlying defamation claim here), “absolute immunity from liability for defamation exists for oral or written statements made... in connection with a proceeding before a court.”*¢ Thus, although the act of filing a document with a court might be thought to lend that document additional credibility, in fact, allegations appearing in such documents might be less credible than those published elsewhere.” 46 Front, Inc. v. Khalil, 24 N.Y.3d 713, 718 (2015); see also Kelly v. Albarino, 485 F.3d 664, 666 (2d Cir. 2007) (adopting the reasoning of the District Court explaining that this privilege is “the broadest of possible privileges”); Restatement (Second) of Torts § 587 (1977) (“A party to a private litigation or a private prosecutor or defendant in a criminal prosecution is absolutely privileged to publish defamatory matter concerning another in communications preliminary to a proposed judicial proceeding, or in the institution of or during the course and as a part of, a judicial proceeding in which he participates, if the matter has some relation to the proceeding.”’). But see note 47, post. 47 While common law courts have generally interpreted the litigation privilege broadly, they nevertheless maintain an important (if rarely implemented) limitation on its scope: to qualify for the privilege, a statement must be “material and pertinent to the questions involved.” Front, 24 N.Y.3d at 718 (quoting Youmans ZZ.

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page23 of 25 We have long noted that the press plays a vital role in ensuring the public right of access and in enhancing “the quality and safeguards the integrity of the factfinding process.”48 When faithfully observing its best traditions, the print and electronic media “contributes to public understanding of the rule of law” and “validates [its] claim of functioning as surrogates for the public.”” At the same time, the media does the public a profound disservice when it reports on parties’ allegations uncritically. We have previously observed that courts cannot possibly “discredit every statement or document turned up in the course of litigation,” and we have criticized “the use by the media of the somewhat misleading term ‘court records’ in referring to such items.”°° Even ordinarily critical v. Smith, 153 N.Y. 214, 219-20 (1897)). It follows, then, that immaterial and impertinent statements are (at least nominally) actionable, particularly when they are “so needlessly defamatory as to warrant the inference of express malice.” Id. (same). It seems to us that when a district court strikes statements from the record pursuant to Fed. R. Civ. P. 12(f) on the ground that the matter is “impertinent” and “Immaterial,” it makes the very same determination that permits a defamation action under the common law. We think the judicial system would be well served were our common law courts to revitalize this crucial qualification to the litigation privilege. 48 Westmoreland v. Columbia Broad. Sys., Inc., 752 F.2d 16, 23 (2d Cir. 1984) (quoting Globe Newspaper Co. v. Superior Court for Norfolk Cty., 457 U.S. 596, 606 (1982)). ” Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 572-73 (1980) (plurality opinion) (internal quotation marks omitted). 50 Amodeo II, 71 F.3d at 1049. 23

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page24 of 25 readers may take the reference to “court papers” as some sort of marker of reliability. This would be a mistake. We therefore urge the media to exercise restraint in covering potentially defamatory allegations, and we caution the public to read such accounts with discernment. HI. CONCLUSION To summarize, we hold as follows: (1) Materials submitted in connection with a motion for summary judgment are subject to a strong presumption of public access. (2) The summary judgment record at issue will be unsealed upon issuance of our mandate, subject to minimal redactions.>! (3) Materials submitted in connection with, and relevant to, discovery motions, motions in limine, and other nondispositive motions are subject to a lesser—but still substantial— presumption of public access. (4) The District Court is directed to review the remaining sealed materials individually and unseal those materials as appropriate. 51 See note 22, ante. 24

Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page25 of 25 (5) District courts should exercise the full range of their substantial powers to ensure their files do not become vehicles for defamation. For the foregoing reasons, we VACATE the orders of the District Court entered on November 2, 2016, May 3, 2017, and August 27, 2018, ORDER the unsealing of the summary judgment record as described herein, and REMAND the cause to the District Court for particularized review of the remaining materials. In undertaking this task, the District Court may be well-served by ordering the parties to submit to the Court unredacted, electronic copies of the remaining sealed materials, as well as specific, proposed redactions. The District Court may also order the parties to identify and notify additional parties whose privacy interests would likely be implicated by disclosure of these materials. In the interests of judicial economy, any future appeal in this matter shall be referred to this panel. 25

Case 18-2868, Document 273-3, 08/09/2019, 2628218, Pagel of 1 POOLER, Circuit Judge, dissenting in part: [join the Court’s opinion in every respect but one: the decision to unseal the summary judgment record ourselves. I agree that all or most of the material must be unsealed. Nevertheless, in my view, the district court is better suited to the task. As the Court’s opinion recognizes in connection with the remaining sealed materials, the district court is better positioned to communicate with the parties and any nonparties whose privacy interests might be affected by unsealing. On that score, it is worth clarifying here the breadth of the Court’s unsealing order: it unseals nearly 2000 pages of material. The task of identifying and making specific redactions in such a substantial volume is perilous; the consequences of even a seemingly minor error may be grave and are irrevocable. Moreover, although I share the majority’s concern about avoiding delay, I would alleviate that concern through other means— perhaps with an order directing the district court to act expeditiously and by making clear what types of limited redactions are and are not appropriate. In sum, I would unseal the district court’s summary judgment decision only and leave the remainder of the materials for the district court to review, redact, and unseal on remand.

Case 18-2868, Document 275, 08/09/2019, 2628223, Pagel of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Bg ag ee xX VIRGINIA L. GIUFFRE, Plaintiff, V. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. Sees eee XK DEFENDANT’S STATEMENT OF MATERIAL UNDISPUTED FACTS PURSUANT TO LOCAL CIVIL RULE 56.1 Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. 150 East 10" Avenue Denver, CO 80203 303.831.7364

Case 18-2868, Document 275, 08/09/2019, 2628223, Page2 of 18 Pursuant to Rule 56.1 of the Local Civil Rules of this Court, defendant Ghislaine Maxwell submits this statement of the material facts as to which she contends there is no genuine issues to be tried. Ms. Maxwell expressly preserves all of her objections to the admissibility of the evidence cited herein and in the accompanying memoranda of law and does not waive any objections by making this submission. numbered. 1. Ms. Maxwell’s response to publications of plaintiff's false allegations: the March 2011 statement. In early 2011 plaintiff in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. In the articles, plaintiff made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, plaintiff suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. 2. In the articles, plaintiff alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” 3. In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.” 4. The statement read in full: Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 2011 London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false.

Case 18-2868, Document 275, 08/09/2019, 2628223, Page3 of 18 It is unacceptable that letters sent by Ms Maxwell’s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers. ‘‘T understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop,” said Ghislaine Maxwell. ‘A number of newspapers have shown a complete lack of accuracy 1n their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-25 1 Email: ross @ acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: +44-203008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com 5. Plaintiff’s gratuitous and “lurid” accusations in an unrelated action. In 2008 two alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against the United States government purporting to challenge Epstein’s plea agreement. They alleged the government violated their CVRA rights by entering into the agreement. 6. Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action, claiming she, too, had her CVRA rights violated by the government. On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. 7. The issue presented in her joinder motion was narrow: whether she should be permitted to join the CVRA action as a party under Federal Rule of Civil Procedure 21, specifically, whether she was a “known victim[]| of Mr. Epstein and the Government owed them CVRA duties.” Yet, “the bulk of the [motion] consists of copious factual details that [plaintiff] and [her co-movant] “would prove . . . if allowed to join.’” Ms. Giuffre gratuitously included 2

Case 18-2868, Document 275, 08/09/2019, 2628223, Page4 of 18 provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual trafficking. 8. At the time they filed the motion, Ms. Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA action. While they deliberately filed the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. 9. As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several individuals, and she offers details about the type of sex acts performed and where they took place.” The court ruled that “these lurid details are unnecessary”: “The factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent . . ., especially considering that these details involve non-parties who are not related to the respondent Government.” Accordingly, “[t]hese unnecessary details shall be stricken.” Id. The court then struck all Ms. Giuffre’s factual allegations relating to her alleged sexual activities and her allegations of misconduct by non-parties. The court said the striking of the “lurid details” was a Sanction for Ms. Giuffre’s improper inclusion of them in the motion. 10. The district court found not only that the “lurid details” were unnecessary but also that the entire joinder motion was “entirely unnecessary.” Ms. Giuffre and her lawyers knew the motion with all its “lurid details” was unnecessary because the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. The court denied plaintiff's joinder motion. 11. One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion,

Case 18-2868, Document 275, 08/09/2019, 2628223, Page5d of 18 Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein: Ms. Maxwell “approached” plaintiff in 1999 when plaintiff was “fifteen years old” to recruit her into the scheme. Ms. Maxwell was “one of the main women” Epstein used to “procure underaged girls for sexual activities.” Ms. Maxwell was a “primary co-conspirator’ with Epstein in his scheme. She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.” At the mansion, when plaintiff began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.” Epstein “with the assistance of’ Ms. Maxwell “converted [plaintiff] into...a ‘sex Slave.’ Jd. Plaintiff was a “sex slave” from “about 1999 through 2002.” Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.” Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.” Ms. Maxwell “participat[ed] in the sexual abuse of [plaintiff] and others.” Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [plaintiff].” Jd. She shared the photos with Epstein. As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect|ed]” Epstein with “powerful individuals” so that Epstein could traffick plaintiff to these persons. Plaintiff was “forced to have sexual relations” with Prince Andrew in “TMs. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” plaintiff’ s sex with Prince Andrew “by acting as a ‘madame’ for Epstein.” Ms. Maxwell “assist|ed] in internationally trafficking” plaintiff and “numerous other young girls for sexual purposes.” Plaintiff was “forced” to watch Epstein, Ms. Maxwell and others “engage in illegal sexual acts with dozens of underage girls.”

Case 18-2868, Document 275, 08/09/2019, 2628223, Page6 of 18 12. Inthe joinder motion, plaintiff also alleged she was “forced” to have sex with Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and “many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.” 13. Plaintiff said after serving for four years as a “sex slave,” she “managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.” 14. Plaintiff suggested the government was part of Epstein’s “conspiracy” when it “secretly” negotiated a non-prosecution agreement with Eptstein precluding federal prosecution of Epstein and his “co-conspirators.” The government’s secrecy, plaintiff alleged, was motivated by its fear that plaintiff would raise “powerful objections” to the agreement that would have “shed tremendous public light on Epstein and other powerful individuals. 15. Notably, the other “Jane Doe” who joined plaintiff's motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of plaintiff’ s allegations. 16. Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, plaintiff told Ms. Churcher of virtually none of the details she described in the joinder motion. 17. Ms. Maxwell’s response to plaintiff's “lurid” accusations: the January 2015 statement. As plaintiff and her lawyers expected, before District Judge Marra in the CVRA action could strike the “lurid details” of plaintiff's allegations in the joinder motion, members of the media obtained copies of the motion. 18. At Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing “a quotable statement on

Case 18-2868, Document 275, 08/09/2019, 2628223, Page7 of 18 behalf of Ms Maxwell.” The email was sent to more than 6 and probably less than 30 media representatives. It was not sent to non-media representatives. 19. Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. These representatives were selected based on their request—after the joinder motion was filed—for a response from Ms. Maxwell to plaintiff's allegations in the motion. 20. The email to the media members read: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] 1t changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. 21. Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional press release solely to disseminate information to the media. So he intentionally did not pass it through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation.

Case 18-2868, Document 275, 08/09/2019, 2628223, Pages of 18 22. The January 2015 statement served two purposes. First, Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiffs false allegations. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject plaintiff's allegations to inquiry and scrutiny. For example, he noted in the statement that plaintiff's allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” 23. Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish plaintiffs allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that plaintiff's allegations were “defamatory.” In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct. 24. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (emphasis supplied). The statement was intended to be a single, one-time-only, comprehensive response—quoted in full—to plaintiff's December 30, 2014, allegations that would give the media Ms. Maxwell’s response. The purpose of the prefatory statement was to inform the mediarecipients of this intent. 25. Plaintiff’s activities to bring light to the rights of victims of sexual abuse. Plaintiff has engaged in numerous activities to bring attention to herself, to the prosecution and punishment of wealthy individuals such as Epstein, and to her claimed interest of bringing light to the rights of victims of sexual abuse.

Case 18-2868, Document 275, 08/09/2019, 2628223, Page9 of 18 26. Plaintiff created an organization, Victims Refuse Silence, Inc., a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. 27. The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse.” Toward this end, plaintiff has “dedicated her professional life to helping victims of sex trafficking.” 28. Plaintiff repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. 29. On December 30, 2014, plaintiff publicly filed an “entirely unnecessary” joinder motion laden with “unnecessary,” “lurid details” about being “sexually abused” as a “minor victim|]” by wealthy and famous men and being “trafficked” all around the world as a “sex slave.” 30. The plaintiffs alleged purpose in filing the joinder motion was to “vindicate” her rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution agreement” with Epstein, “shed tremendous public light” on Epstein and “other powerful individuals” that would undermine the agreement, and support the CVRA plaintiffs’ request for documents that would show how Epstein “used his powerful political and social connections to secure a favorable plea deal” and the government’s “motive” to aid Epstein and his “coconspirators.” 31. Plaintiff has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s alleged “sex scheme.”

Case 18-2868, Document 275, 08/09/2019, 2628223, Page10 of 18 32. Republication alleged by plaintiff. Plaintiff was required by Interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were ““published globally, including within the Southern District of New York,’” as plaintiff alleged in Paragraph 9 of Count I of her complaint. In response, plaintiff identified the January 2015 statement and nine instances in which various news media published portions of the January 2015 statement in news articles or broadcast stories. 33. In none of the nine instances was there any publication of the entire January 2015 statement. 34. Ms. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in plaintiff's response to Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015 statement. 35. Plaintiff’s defamation action against Ms. Maxwell. Eight years after Epstein’s guilty plea, plaintiff brought this action, repeating many of the allegations she made in her CVRA joinder motion. 36. The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”’: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (b) That the allegations have been “shown to be untrue.” (c) That Giuffre’s “claims are obvious lies.” 37. Plaintiff lived independently from her parents with her fiancé long before meeting Epstein or Ms. Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999, plaintiff moved in with the family of a fellow patient. There she met, and became engaged to, her friend’s brother, James Michael Austrich. She and Austrich thereafter

Case 18-2868, Document 275, 08/09/2019, 2628223, Page11 of 18 rented an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs in that area. Later, they stayed briefly with plaintiffs parents in the Palm Beach/ Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. Although plaintiff agreed to marry Austrich, she never had any intention of doing so. 38. Plaintiff re-enrolled in high school from June 21, 2000 until March 7, 2002. After finishing the 9"" grade school year at Forest Hills High School on June 9, 1999, plaintiff reenrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on August 14, 2001. On September 20, 2001, Plaintiff then enrolled at Royal Palm Beach High School. A few weeks later, on October 12, 2001, she matriculated at Survivors Charter School. Id. Survivor’s Charter School was an alternative school designed to assist students who had been unsuccessful at more traditional schools. Plaintiff remained enrolled at Survivor’s Charter School until March 7, 2002. She was present 56 days and absent 13 days during her time there. /d. Plaintiff never received her high school diploma or GED. Plaintiff and Figueroa went “back to school” together at Survivor’s Charter School. The school day there lasted from morning until early afternoon. 39. During the year 2000, plaintiff worked at numerous jobs. In 2000, while living with her fiancé, plaintiff held five different jobs: at Aviculture Breeding and Research Center, Southeast Employee Management Company, The Club at Mar-a-Lago, Oasis Outsourcing, and Neiman Marcus. Her taxable earnings that year totaled nearly $9,000. Plaintiff cannot now recall either the Southeast Employee Management Company or the Oasis Outsourcing jobs. 40. Plaintiff’s employment at the Mar-a-Lago spa began in fall 2000. Plaintiff's father, Sky Roberts, was hired as a maintenance worker at the The Mar-a-Lago Club in Palm 10

Case 18-2868, Document 275, 08/09/2019, 2628223, Page12 of 18 Beach, Florida, beginning on April 11, 2000. Mr. Roberts worked there year-round for approximately 3 years. After working there for a period of time, Mr. Roberts became acquainted with the head of the spa area and recommended plaintiff for a job there. Mar-a-Lago closes every Mother’s Day and reopens on November 1. Most of employees Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club is open, 1.e., between November | and Mother’s Day. Plaintiff was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17. 41. Plaintiff represented herself as a masseuse for Jeffrey Epstein. While working at the Mar-a-Lago spa and reading a library book about massage, plaintiff met Ms. Maxwell. Plaintiff thereafter told her father that she got a job working for Jeffrey Epstein as a masseuse. Plaintiff's father took her to Epstein’s house on one occasion around that time, and Epstein came outside and introduced himself to Mr. Roberts. Plaintiff commenced employment as a traveling masseuse for Mr. Epstein. Plaintiff was excited about her job as a masseuse, about traveling with him and about meeting famous people. Plaintiff represented that she was employed as a masseuse beginning in January 2001. Plaintiff never mentioned Ms. Maxwell to her then-fiancé, Austrich. Plaintiffs father never met Ms. Maxwell. 42. Plaintiff resumed her relationship with convicted felon Anthony Figueroa. In spring 2001, while living with Austich, plaintiff lied to and cheated on him with her high school boyfriend, Anthony Figueroa. Plaintiff and Austrich thereafter broke up, and Figueroa moved into the Bent Oak apartment with plaintiff. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa in Plaintiff’s presence punched Austrich in the face. Figueroa and plaintiff fled the scene before police arrived. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance. 11

Case 18-2868, Document 275, 08/09/2019, 2628223, Page13 of 18 43. Plaintiff freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at age 17, while living in the same apartment, plaintiff and Figueroa hosted a party with a number of guests. During the party, according to plaintiff, someone entered plaintiff's room and stole $500 from her shirt pocket. Plaintiff contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a “sex Slave.” A second time, in June 2002, plaintiff contacted the police to report that her former landlord had left her belongings by the roadside and had lit her mattress on fire. Again, plaintiff met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a “sex slave.” 44. From August 2001 until September 2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel unaccompanied by Plaintiff. Flight logs maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips away from Florida that Epstein and Maxwell took, unaccompanied by Plaintiff, between August 2001 and September 2002. Rodgers maintained a log of all flights on which Epstein and Maxwell traveled with him. Epstein additionally traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial flights. For substantially all of thirteen months of the twenty-two months (from November 2000 until September 2002) that Plaintiff lived in Palm Beach and knew Epstein, Epstein was traveling outside of Florida unaccompanied by Plaintiff. During this same period of time, Plaintiff was employed at various jobs, enrolled in school, and living with her boyfriend. 45. Plaintiff and Figueroa shared a vehicle during 2001 and 2002. Plaintiff and Figueroa shared a ’93 white Pontiac in 2001 and 2002. Plaintiff freely traveled around the Palm 12

Case 18-2868, Document 275, 08/09/2019, 2628223, Page14 of 18 Beach area in that vehicle. In August 2002, Plaintiff acquired a Dodge Dakota pickup truck from her father. Figueroa used that vehicle in a series of crimes before and after Plaintiff left for Thailand. 46. Plaintiff held a number of jobs in 2001 and 2002. During 2001 and 2002, plaintiff was gainfully employed at several jobs. She worked as a waitress at Mannino’s Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at Roadhouse Grill. She also was employed at Courtyard Animal Hospital (aka Marc Pinkwasser DVM). 47. In September 2002, Plaintiff traveled to Thailand to receive massage training and while there, met her future husband and eloped with him. Plaintiff traveled to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove her to the airport. While there, she initially contacted Figueroa frequently, incurring a phone bill of $4,000. She met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until two days before Mr. Figueroa’s deposition in this matter in May 2016. 48. Detective Recarey’s investigation of Epstein failed to uncover any evidence that Ms. Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. Joseph Recarey served as the lead detective from the Palm Beach Police Department charged with investigating Jeffrey Epstein. That investigation commenced in 2005. Recarey worked only on the Epstein case for an entire year. He reviewed previous officers’ reports and interviews, conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance footage of the Epstein home, participated in and had knowledge of the search warrant executed on the Epstein home, and testified regarding the case before the Florida state grand jury against Epstein. Detective Recarey’s investigation 13

Case 18-2868, Document 275, 08/09/2019, 2628223, Page15 of 18 revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect by the government. None of Epstein’s alleged victims said they had seen Ms. Maxwell at Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her, nor told what to wear or how to act by her. Indeed, none of Epstein’s alleged victims ever reported to the government they had met or spoken to Ms. Maxwell. Maxwell was not seen coming or going from the house during the law enforcement surveillance of Epstein’s home. The arrest warrant did not mention Ms. Maxwell and her name was never mentioned before the grand jury. No property belonging to Maxwell, including “sex toys” or “child pornography,” was seized from Epstein’s home during execution of the search warrant. Detective Recarey, when asked to describe “everything that you believe you know about Ghislaine Maxwell’s sexual trafficking conduct,” replied, “I don’t.” He confirmed he has no knowledge about Ms. Maxwell sexually trafficking anybody. Detective Recarey also has no knowledge of Plaintiffs conduct that is subject of this lawsuit. 49. No nude photograph of Plaintiff was displayed in Epstein’s home. Epstein’s housekeeper, Juan Alessi, “never saw any photographs of Virginia Roberts in Mr. Epstein’s house.” Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. 50. Plaintiff intentionally destroyed her “journal” and “dream journal” regarding her “memories” of this case in 2013 while represented by counsel. Plaintiff drafted a “Journal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents 1n her 14

Case 18-2868, Document 275, 08/09/2019, 2628223, Page16 of 18 possession. /d. Plaintiff also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. To date, Plaintiff cannot locate the “dream journal.” 51. Plaintiff publicly peddled her story beginning in 2011. Plaintiff granted journalist Sharon Churcher extensive interviews that resulted in seven (7) widely distributed articles from March 2011 through January 2015. Churcher regularly communicated with plaintiff and her “attorneys or other agents” from “early 2011” to “the present day.” Plaintiff received approximately $160,000 for her stories and pictures that were published by many news organizations. 52. Plaintiff drafted a 144-page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, plaintiff drafted a book manuscript which purported to document plaintiff’ s experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. Plaintiff communicated with literary agents, ghost writers and potential independent publishers in an effort to get her book published. She generated marketing materials and circulated those along with book chapters to numerous individuals associated with publishing and the media. 53. Plaintiff’s publicly filed “lurid” CVRA pleadings initiated a media frenzy and generated highly publicized litigation between her lawyers and Alan Dershowitz. On December 30, 2014, plaintiff, through counsel, publicly filed a joinder motion that contained her “lurid allegations” about Ms. Maxwell and many others, including Alan Dershowitz, Prince Andrew, Jean-Luc Brunel. The joinder motion was followed by a “corrected” motion and two further declarations in January and February 2015, which repeated many of plaintiffs claims. These CVRA pleadings generated a media maelstrom and spawned highly publicized litigation between plaintiff's lawyers, Edwards and Cassell, and Alan Dershowitz. After plaintiff publicly 15

Case 18-2868, Document 275, 08/09/2019, 2628223, Page17 of 18 alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called plaintiff a liar and accused her lawyers of unethical conduct. In response, attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. 54. Plaintiff formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, plaintiff, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to plaintiff, the purpose of the organization is to promote plaintiff's professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Plaintiff attempts to promote Victims Refuse Silence at every opportunity. For example, plaintiff participated in an interview in New York with ABC to promote the charity and to get her mission out to the public. Dated: January 6, 2017 Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10" Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 Imenninger @hmflaw.com Attorneys for Ghislaine Maxwell 16

Case 18-2868, Document 275, 08/09/2019, 2628223, Page18 of 18 CERTIFICATE OF SERVICE I certify that on January 6, 2017, I electronically served this Defendant's Statement of Material Undisputed Facts Pursuant to Local Civil Rule 56.1 via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley @bsfllp.com mschultz @bsfllp.com Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad @ pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp @ law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@ aol.com /s/ Nicole Simmons Nicole Simmons 17

Case 18-2868, Document 276, 08/09/2019, 2628224, Pagel of 77 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK eee ee eee oe eee eee eee e Xx VIRGINIA L. GIUFFRE, Plaintiff, V. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. se eee oe ee eres 4 Memorandum of Law in Support of Defendant’s Motion for Summary Judgment Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. 150 East 10" Avenue Denver, CO 80203 303.831.7364

Case 18-2868, Document 276, 08/09/2019, 2628224, Page2 of 77 TABLE OF CONENTS Pg Fe ey EN RY, VTE, easter eatery ce censt vier cesancaterarsnlielonec eens soar cceensaeener aula cesta. | Tessas ea et secre io ntsc ete cde ieahgn st neg he pees desea etch gas ghee ease eneloop aeneactaee SUMVEAICY. SUIDGIMIEINT SCANDIA RR DD og drscetsisastn-cacquaas anc tocieeacnaaenvastnaatantedseatvinaacrgansaebeetnends 10 gE Gy IN INT cescennntsiateseaaaauasaneseenentacaaseantaasaeaeatausassuse.sspnesaeseemeenunassaeaseuntacsospeecussanteaiaensasaevenmansas: 12 I. Ms. Maxwell is not liable for republications of her January 2015 statement that she did not authorize Or Tequest and by Chililics SiG 1G Ol CONE Oli ctsccatugc4zicasncvecee uct eiaienecesoeeassaeceeeeeaees 2 A. Summary judgment is warranted to the extent plaintiff seeks to impose liability on any media’s republication of all or a portion of the January 2015 statement. ........ ez B. Because plaintiff is a limited public figure, imposing liability upon Ms. Maxwell for republication of the January 2015 statement would violate the First Pra CMS ING, aie eis dice sehen tetanic ce oeidatel ooadanwietaeegeatatansuselietecasesmestawdenateaustaeacd 16 C. Plaintiff should be barred from introducing into evidence any republication of an BxCer pe mom Liles) away 2) Lat fle Ol xsieasnsesees aaee ese cinaaieretvsieeeenatiananoeees 17 II. Summary judgment is warranted under the New York Constitution. ..............ccccceeeeesseeeeees 18 A. The January 2015 statement constitutes nonactionable Opinion. .............ccceeeeeeeeees 18 B. In this Rule 56 proceeding, this Court’s Rule 12(b)(6) opinion does not control the question of law whether the January 2015 statement constitutes nonactionable MOA sco cc accra Soners ects es cages esac eae san oes 31 TT, IG PRC = tS AO: Piya COC at STs ACTON oct caresses casas acesicsaecesaedteanseseecatansesesiasancrseeaeconees 53 TV. Ms, Maxwell's January 4, 2015, Statement 19 MONACHONMADIC, soveceecdetieteetucistedeetenaectevacs: 38 V. The defamation claim should be dismissed because the publication is substantially true. ... 39 VI. Plaintiff cannot establish actual malice by clear and convincing evidence. .............ccccceeeeeee 40 A. TOUS 2a arts eos ce aetenterticrne bepierisp oh potashstoanene tes Gewrederhe wtorrehaseawonueaevedenadnaeee soeemteoueuessesiaeien! 40 B. Plaintiff carries the burden of proving actual malice by clear and convincing 1M i ages pater stesecec teense ale a sae pare sae, eno scene neon seen ate cnasdeene se eeeneon pss 48 c Plaintiff is a public figure who must prove actual malice. ...........eeeceeeeesseetteeees 49 he Plaintiff successfully invited public attention to influence others. ........... 51 1

Case 18-2868, Document 276, 08/09/2019, 2628224, Page3 of 77 Z Plaintiff voluntarily injected herself into public controversies related to the SU CIOL Mies MIG CALI, saxacssesceasanexseiceetexdeacsaeuseapeeeacavixesuebemensemiataraces 2 2. Plaintiff assumed a position of prominence in the public controversies. . 53 4. Plaintiff has maintained regular and continuing access to the media. ...... 54 D. Plaintiff must also prove actual malice to overcome the defenses of reply and preTUG AUIO MI INNS Cy, 5a cueecesatesesasesecamieavasacaracuvnneaed@eniacacauntesadesateadeuenresatesastusesunondaess 54 i. The January 2015 statement was substantially true, and plaintiff cannot produce clear. ang Con vincin® CVI emCe OL 11S) TAISILY .aiescedicssnceececishebeass wide aiden apcaeeevadasicivacsenes 56 i The January 2015 statement accurately denied that Ms. Maxwell met Plait, when Plambte was 15: yeats Old 101999 octet eeectcvba 56 2 The January 2015 statement accurately denied that Ms. Maxwell “regularly participate[d]| in Epstein’s sexual exploitation of minors” and thac” the (GOVermiment KNOWS SUCIATACL. sicivgenvesswenivannvcerddsnddsdavleseetecets 58 3. The January 2015 statement accurately denied that “with [Ms. Maxwell’s] assistance, [Epstein] converted [Plaintiff] into what 1s commonly referred (Osi a Sex Slay Cs cisaaiinsgasat ocnsacadetnsatneeiassacsniasaanscancaieteratanetansgatatonccsn: 59 4. The January 2015 statement accurately reported that Plaintiff alleged “sexual relations” with Professor Dershowitz which he denied. .............. 60 D: The January 2015 statement accurately denied that Ms. Maxwell created and distributed child pornography and that the Government knows of and POS sess s SUC MC MING: POTNO OFS Ol cccadcorcnysccnseasseapmaveermeue aaenesesatereaeseconees 62 6. January 2015 statement accurately denied Maxwell acted as “madame” for Epstein to tratiic Plaintiff to the rich and Tamu, <.5:0:s0ss-sssscessecessadavsonenne 63 IN aa ets ce esse sce kc rancho Anetra desea 68 Ge ee Oey Pe precios seca spasa erect tendedartnucnousenteseancsnags tenia doce eau nce eteasue aeetedoatoee: 70 ll

Case 18-2868, Document 276, 08/09/2019, 2628224, Page4 of 77 TABLE OF AUTHORITIES Cases Adelson v. Harris, 973 F. Supp. 2d 467, 490 (S.D.N.Y. 2013)... cccccccccceeeeeeeeeeeeeeeees 29 Air Wisconsin Airlines Corp. v. Hoeper, 134 S. Ct. 852, 861 (2014) oo... eee ccccccc cece eee ees 48 Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 251-52 (1986). .....ccccccccccccceeeeeeeeeeeeeeeees 1] AVONSON V;. WICKSING.A6 INE 1196, WIS 9 (19S D ) wsssscanspactrecdassedecteasbeeidaveswonsestees: 22,24 POTN CK Ve VODDCT se yc OE) ager cesses cones eaten ec cereees aenoneeeeiesenes 48 Biro v. Condé Nast, 883 F. Supp. 2d 441, 458 (S.D.N.Y. 2012) oo... ccccccccccceeeeeeeeees 39 iro Vv, Conde Naste 9603 F. Supp..2d 25); 209 (S.D.N: Y..20 13 ) sensasvdsasencxssoseencterierencsasd 49 Black v. Green Harbour Homeowners’ Ass’n, 798 N.Y .S.2d 753 (App. Div. 2005), ...... 34 Celle v. Filipino Reporter Enters. Inc., 209 F.3d 163, 176-77 (2d Cir. 2000).................. 51 Cole COTO. VCO AIT WS 977 CO) sorestccncse asa thes te eestusascoeat wae eiesee cies 12 Chambers v. Wells Fargo Bank, N.A., No. 2016 WL 3533998, at *8 (D.N.J. June 28, DO NY ga eaters coset pace eaecgip ocetne sa esravo eecoaioseseoa eens ececeacotcsece1squreeaseacesesseaeeeeaesecesseacs: 33 Chau v. Lewis, 935 F. Supp. 2d 644, 665 (S.D.N.Y. 2013) 0... ceessscsccceceeeeeeeeeeeeeeeeeeees 2 Collier v. Postum Cereal Co., 134. N.Y.S. 847, 853 (1" Dep't 1912) voceceeeessseseeeeeeee 55 Contemporary Mission, Inc. v. N.Y. Times Co., 842 F.2d 612, 617 (2d Cir. 1988).......... 50 CUS UOT So C0. Vis, 36 a NO NG) aera ca cctscie end atm egcs emer seavetstenqsmntveaeaceds 49 Davis v..Boenem, 22 N30 999, LOGGUNY.. 20149) sisseesccaccanenocetoesastanecenncesonsvessooasses 22D) Davis v. Costa-Gavras, 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984) ooo eecceeceeeeees I Dibella v. Hopkins, No. 01 CIV. 11779 (DC), 2002 WL 31427362, at *2 (S.D.N.Y. Oct. BO 22 cc ta atic nt eee seasecerne seen sade ng saeeecee vacated ae atest eaaaeesaieteueuend-aeceaietadaugeceneenaees 2 Don King Prods., Inc. v. Douglas, 742 F. Supp. 778, 780 (S.D.N.Y. 1990)... eee 1] il

Case 18-2868, Document 276, 08/09/2019, 2628224, Paged of 77 Elias v. Rolling Stone LLC, No. 15-CV-5953 (PKC), 2016 WL 3583080, at *6 (S.D.N.Y. SNES 2 520) sacs ete ageedcee caste lost sets epmerct oid etnadnldtsasteastea dei coei iow meio cicpie encennteadapatoatehaneieeeeriae 22 Enigma Software Grp. USA, LLC v. Bleeping Computer LLC, No. 16 CIV. 57 (PAE), ZONG W377 3394.a0 7 1 (SDNY ..JUly S201) sccncssasaseisnsrsanengutinwiaresasanasateanaamasiees 19 POQICULV, KREHY,. 978-1) SUNN 420, A 26 (DIN POD 7 ca secattscarcateduadseateearnalnentseceeteaameeseieses: 50 Firesione V. ime 1ne..2 71. SO. 20 745, JOD (Fae NO 7D) sccicriwntcsiacssadsassissesvidlecndsaehaientecadinss 13 Fleckenstein v..Frieaman, V93: N.E. 537,538 UNGY 1934) scississcasdncnssexeserecendncdatersstssavides 40 Flomenhaft v. Finkelstein, 8 N.Y.S.3d 161, 164 n.2 (1% Dep't 2015) wove ceeeeeeeeeeeeeeeeees 33 FOlWwelly. Aviller, JAS. TAOS; A9 1 (20 Che 10D) scsckatacitsscomepionebomadeicasssstadundeseesaunelones 13 Prankdiury. Daily Holdings, Inc.,.2\ IN.Y2S,30.6,; 12 (App. Div. 201) ) ssssscccsceaxevaninssadecss 39 Frechtman v. Gutterrnan, 979 N.Y.S. 2d 58 (App. Div. 2014) wu... eeeeeeeeeceeeeeeeeees 34 PVONE JHC, VINO 26.IN oC, Ms MOAN 5 20D), desenccezesccgncanennceeeesuesacaewssegeaeeuseusaeences 50 GOVGG VF 1008 oN 2 ON a Veg 0 FO) ise sis cac ecesoseerocanceaueaeentsneneoasneees 13,18 Germain v. M & T Bank Corp., 111 F. Supp. 3d 506, 534 (S.D.N.Y. 2015)... 19 CIA IROOM VC, Li, EN i 1 reste ast stcav nese seedetceoess 16, 48, 49 Goforth v. Avemco Life Ins. Co., 368 F.2d 25, 28 n.7 (4th Cir.1966). 0.0... eeseeseeeeeeeees 39 Goldstein v. Cogswell, No. 85 CIV. 9256 (KMW), 1992 WL 131723, at *27 n.32 CIN eV DU i rasa ses et es eer tere eect eee scene eaessee wey aeeeenccee a0 Gross v..New York Times, 623. N.E.24 1163.1 WOON. Y... 1993) seicisccteusssdivwaceitadewassaiaiantes 28 Harte-Hanks Communic’ns, Inc. v. Connaughton, 491 U.S. 657, 666 n.7 (1989) ........... 48 Hawkins v. Harris, 661 A.2d 284, 289-91 (N.J. 1995) ooo. ccccsssseeccccceeceseeeeeeeeceseeeeaaees 33 Horne v. Matthews, No. 97 Civ. 3605(JSM), 1997 WL 598452 (S.D.N.Y. Sept. 25, 1997) dgsscepatiats doadstciou sua satin wad tale cana dedeasiadsasosene tac sone<tnsasiefainntnastaeaane tac so aatee suet eee sadsasieese sales te=5-te! 2 Husemns v,. Moore, 126 IN: ..207456, 460: (NY: 1999 ) cccicsscrceensnndatnipestaanesnnenemeesatsannerecssons 48

Case 18-2868, Document 276, 08/09/2019, 2628224, Page6 of 77 Immuno AG v. Moor-Jankowski, 567 N.E.2d 1270, 1282 (N.Y. 1991)... ee. 11,19 Indep. Living Aids, Inc. v. Maxi-Aids, Inc., 981 F. Supp. 124, 128 (E.D.N.Y. 1997)....... 28 INVCTH GW ONG FO ISIINe CONCCOIS THIG V, LOC OI oie serscareenenppcdonsneesiosescneseassqusiainenwniey: a James Vv. Gannett Co., 393-N.B 20834; S38: (N.Y 197 D) sscccaraccssosscssameretnesereeesess 14, 23, 49 Jewell v. NYP Holdings, Inc., 23 F. Supp. 2d 348, 366 (S.D.N.Y.1998)..... ees 40 Kane v. Orange Cnty. Publ’ns, 649 N.Y.S.2d 23, 26 (App. Div. 1996)... 56 Karaqauman vy. Newsday: ine:.41 6 NB20 557, SO0(1 980) sccipcecesecsrsecentvocdaveesiedaeiieccee: 18 Kificv..dieppi, 532.F. Supp<2d 586,593: (Ss DINGY « 2008) so sschacatesetsseceaenintaenecsategeisenseneds: 32 Klein v. McGauley, 29. A.D.2d 418, 420 (2™ Dep't 1968) ...ccccccccececececesececeseseseseceeereeseeee 34 Lehman Bros. Commercial Corp. v. Minmetals Int’! Non-Ferrous Metals Trading Co., No. 94 CIV. 8301(JFK), 1995 WL 380119, at *6 n.2 (S.D.N.Y. June 26, 1995)......... Zi Lerman v. Flynt Dist. Co., Inc., 745 F.3d 123, 136 (2d Cir. 1984)...............csscceeeseseeseeeens 49 Manny Apel, 36) INIE2G, 864, 885260 (N.Y 2008) eccaseeccctanessessatscoustosmsanccsssensetasasapecetee: 29 Martin v. City of Oceanside, 205 F. Supp. 2d 1142, 1147 (S.D. Cal. 2002), aff'd, 360 F.3d 1078 (9 Cir, 2004). ..cccccccscssssssscscscsesecescessvsvsvsesececscacsvevavevsesececacasavavavavsesesececacene 9) VEG ONO VON sus DO? INNO CIOS) arses sa vaipndutavne cs rsaconcataeasietsiwasndatateeais seavnntsenedas 34 Masnburin vy. Colin, 355 SO: 240 619.88 9s. 1977 cca sastoctcotscreninatcassaasaseueianteataoeneacesnes 30 Masson v. New Yorker Magazine, Inc., 501 U.S. 496, 510 (1991) wo. eeeneeeeeees 54 Maule v. Philadelphia Media Holdings, LLC, No. CIV.A. 08-3357, 2010 WL 914926, at PAO Crete kas Iie MO, 2 OO): oc caitneay stupas ontaceceeatenansuesiantaietanautnssabnnaastatn: Suctatanavelanneanesaens: 22 McGill v. Parker, 582 N.Y.S.2d 91, 97 (App. Div. 1992) ..............::ss0cceeeeeeeeeeececeeeenenennaes 48 MiG Vv WACOn. 159 F220 96 976 (20 Cl, NSD) cca benns aero iescenaguiussaweetiepaenecsscesnenes 11 MCHCHCFYV, NCSC), 7 Nal 2907 IN gE) earrreuese es crsuiendneseen erates ausassaveces: 14 Milkovien Vv; Lorain Journal Co, A9 7S. V(1990) scsesicscsiicscinastnvesdavedacdsossiweaseadiivaeatesaxcass 19

Case 18-2868, Document 276, 08/09/2019, 2628224, Page7 of 77 New York limes Co..y. Sullivan, 3.16: U.S, 254 (1 9GA ) cies scisessssecstennsessivsesonensensevese 16,48,49 Peopiey, Kocsis, 28..N.¥ .5,.50:466, 471 (App. Divs 2016) essavcctecnciesvarcsnetecsaeerencovadeeesd: ZA Petrus v. Smith, 91 A.D.2d 1190, 1191 (N.Y. App. App. Div. 1983)... eeecceeeees 34 Philadelphia Newspapers, Inc. v. Hepps, 475 U.S. 767, 776-77 (1986).......ccccccccceeeeeeeeees 48 In Re Philadelphia Newspapers, LLC, 690 F.3d 161, 175 (3d Cir. 2012), as corrected ig aaa aoa vce ccnp eens ee ecre certo ene iae neaeaeeneeseenetseteaseebandaneaauese 39 Rand v. New York Times Co., 430 N.Y.S.2d 271, 275 (App. Div. 1980). ........eeeeeeeeee 14 Ratajack v. Brewster Fire Dep't, Inc. of the Brewster-SE Joint Fire Dist., 178 F. Supp. 3d Tie LS SCN NS 2) WG) acta seed cated erncy te vedanta ea asak onlvaaeemesonceedionstayaubmastesaaseaveutveqereleanses > hingiar y.. Viking Peneuin, Inc:., 420 NF20 377,382 (N.Y. 1981) sicccsntspnsescnaxevvanintcadinss 13 Salyer v. S. Poverty Law Ctr., Inc., 701 F. Supp. 2d 912, 916 (W.D. Ky. 2009) .......... 39 Sexter v. Warmflash, P.C. v. Margrabe, 828 N.Y.S. 2d 315 (App. Div. 2007))............... 34 Shenkman v. O’Malley, 157 N.Y.S.2d 290, 294, 297 (App. Div. 1956)... eeeeeeee 54 Soley v. Wasserman, No. 8 CIV. 9262 KMW FM, 2013 WL 3185555, at *8 (S.D.N.Y. PENS 2M 21, 3D) )rseeceeransenuroyanseveeusaseeues spon wasoeseamananten sey <sadeseuaese wee sctamneetencdanasadauousssessceeeoeeee 18 Steinhilber v. Alphonse, 501 N.E.2d 550, 550 (N.Y. 1986)... cccccccscsssssesseesesseeeeeeees 19 Time, inc, v. Firestone, 424 U.S.448, 488 tel (1976) cscccdeseissiscestsectsssavsisveatsendstedser.vddevncs 13 Waldbaum v. Fairchild Publ'ns, Inc., 626 F.2d 1287, 1298 (D.C. Cir. 1980 ...... i e. 51] Rules TEs TROY, Ms OO ae ace sane tens aane ee ponies cen eie eee penvencncnsve te apanneeesauee:t yecnesencaneeccuensanauaee: 11, 12 V1

Case 18-2868, Document 276, 08/09/2019, 2628224, Pages of 77 Defendant Ghislaine Maxwell moves under Federal Rule of Civil Procedure 56 for summary judgment. PRELIMINARY STATEMENT FACTS The following facts are undisputed. Additional undisputed facts are set forth in specific argument sections. All paragraphs containing undisputed facts will be sequentially numbered. 1. Ms. Maxwell’s response to publications of plaintiff's false allegations: the March 2011 statement. In early 2011 plaintiff in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. ExHiBiITs A-B.' In the articles, plaintiff made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution.” Nonetheless, plaintiff suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. See generally EXHIBITS A-B. 2. Inthe articles, plaintiff alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” Id. at 5. 3. In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.” EXHIBIT C. 4. The statement read in full: 'The articles were attached as exhibits to the author Sharon Churcher’s declaration in support of her motion to quash an SDT issued to her. See Doc.216-2 & 216-3. *Doc.1 ff 11, 14.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page9 of 77 Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 2011 London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. It is unacceptable that letters sent by Ms Maxwell’s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers. ‘‘T understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop,” said Ghislaine Maxwell. ‘A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-25 1 Email: ross@acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: +44-203008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com EXHIBIT C (emphasis supplied; capitalization altered). We refer to this as “the March 2011 statement.” 5. Plaintiff’s gratuitous and “lurid” accusations in an unrelated action. In 2008 two alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against the United States government purporting to challenge Epstein’s plea agreement. They alleged the government violated their CVRA rights by entering into the agreement. See EXHIBIT D, at 2.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page10 of 77 6. Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action, claiming she, too, had her CVRA rights violated by the government. On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. EXHIBIT D, at 1, 9. 7. The issue presented in her joinder motion was narrow: whether she should be permitted to join the CVRA action as a party under Federal Rule of Civil Procedure 21, specifically, whether she was a “known victim[] of Mr. Epstein and the Government owed them CVRA duties,” EXHIBIT E, at 5. Yet, the court noted, “the bulk of the [motion] consists of copious factual details that [plaintiff] and [her co-movant] ‘would prove . . . if allowed to join.’” Id. (brackets omitted). Ms. Giuffre gratuitously included provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual trafficking. /d. 8. At the time they filed the motion, Ms. Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA action. While they deliberately filed the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. EXHIBIT D, at 1 & n.1. 9. As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several individuals, and she offers details about the type of sex acts performed and where they took place.” EXHIBIT E, at 5. The court ruled that “these lurid details are unnecessary”: “The factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent . . ., especially considering that these details involve non-parties who are not related to the respondent Government.” /d. Accordingly, “[t|hese unnecessary details shall be stricken.” /d. The court then struck all Ms. Giuffre’s factual allegations relating to her alleged sexual activities and her allegations of misconduct by non-parties. /d. at 5-6. The court

Case 18-2868, Document 276, 08/09/2019, 2628224, Page11 of 77 said the striking of the “lurid details” was a sanction for Ms. Giuffre’s improper inclusion of them in the motion. See id. at 6-7. 10. The district court found not only that the “lurid details” were unnecessary but also that the entire joinder motion was “entirely unnecessary,” id. at 7. Ms. Gituffre and her lawyers knew the motion with all its “lurid details” was unnecessary because, as the court pointed out, the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. See id. at 7-8; see also id. at 8 (noting that in the motion, Ms. Giuffre’s lawyers said that “regardless of whether this Court grants the ... Motion, ‘they will call [her] as a witness at any trial’”’). The court denied plaintiffs joinder motion. /d. at 10. 11. One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. EXHIBIT D, at 3-6. According to the “lurid details” of Ms. Giuffre included 1n the motion, Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein: e Ms. Maxwell “approached” plaintiff in 1999 when plaintiff was “fifteen years old” to recruit her into the scheme. Jd. at 3. e Ms. Maxwell was “one of the main women” Epstein used to “procure underaged girls for sexual activities.” Jd. e Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme. Jd. e She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.” Jd. e At the mansion, when plaintiff began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.” /d. e Epstein “with the assistance of’ Ms. Maxwell “converted [plaintiff] into...a ‘sex Slave.’” /d. Plaintiff was a “sex slave” from “about 1999 through 2002.” Id. e Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.” /d. at 4.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page12 of 77 e Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.” /d. e Ms. Maxwell “participat[ed] in the sexual abuse of [plaintiff] and others.” Jd. e Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [plaintiff]. Jd. She shared the photos with Epstein. /d. e As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect|ed]” Epstein with “powerful individuals” so that Epstein could traffick plaintiff to these persons. Id. e Plaintiff was “forced to have sexual relations” with Prince Andrew in “TMs. Maxwell’s] apartment” in London. Jd. Ms. Maxwell “facilitated” plaintiff's sex with Prince Andrew “by acting as a ‘madame’ for Epstein.” Jd. e Ms. Maxwell “assist[ed] in internationally trafficking” plaintiff and “numerous other young girls for sexual purposes.” /d. e Plaintiff was “forced” to watch Epstein, Ms. Maxwell and others “engage in illegal sexual acts with dozens of underage girls.” /d. 12. Inthe joinder motion, plaintiff also alleged she was “forced” to have sex with Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and “many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.” Jd. at 4-6. 13. Plaintiff said after serving for four years as a “sex slave,” she “managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.” Jd. at 3. 14. Plaintiff suggested the government was part of Epstein’s “conspiracy” when it “secretly” negotiated a non-prosecution agreement with Epstein precluding federal prosecution of Epstein and his “co-conspirators.” Jd. at 6. The government’s secrecy, plaintiff alleged, was motivated by its fear that plaintiff would raise “powerful objections” to the agreement that would have “shed tremendous public light on Epstein and other powerful individuals. Jd. at 6-7.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page13 of 77 15. Notably, the other “Jane Doe” who joined plaintiff's motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of plaintiff’ s allegations. See id. at 7-8. 16. Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, plaintiff told Ms. Churcher virtually none of the details she described in the joinder motion. See EXHIBIT A-B. 17. Ms. Maxwell’s response to plaintiff's “lurid” accusations: the January 2015 statement. As plaintiff and her lawyers expected, before District Judge Marra in the CVRA action could strike the “lurid details” of plaintiff's allegations in the joinder motion, members of the media obtained copies of the motion. See EXHIBIT G, at 31:2-36:4 & Depo.Exs.3-4. 18. At Mr. Barden’s direction, on January 2, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing “a quotable statement on behalf of Ms Maxwell.” EXHIBIT F; EXHIBIT G, at 33:8-23. The email was sent to more than 6 and probably less than 30 media representatives. See EXHIBIT G, at 33:8-34:3. It was not sent to non-media representatives. See id. at 31:2-35:21. 19. Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. See, e.g., EXHIBIT F. These representatives were selected based on their request—after the joinder motion was filed—for a response from Ms. Maxwell to plaintiffs allegations in the motion. See, e.g., EXHIBIT G, at 30:23-35:21 & Depo.Ex.3. 20. The email to the media members read: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page14 of 77 No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 1s Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] 1t changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. EXHIBIT F (emphasis supplied). We refer to this email as “the January 2015 statement.” 21. Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional press release solely to disseminate information to the media. So he intentionally did engage a public relations firm, such as Mr. Gow’s firm Acuity Reputation, to prepare the statement. See EXHIBIT K [fj 10,15. 22. The January 2015 statement served two purposes. First, Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiffs false allegations. He believed this could be accomplished by suggesting to the media that, among other things, they should subject plaintiffs allegations to inquiry and scrutiny. For example, he noted in the statement that plaintiffs allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” /d. ¥ 11.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page15 of 77 23. Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish plaintiff's allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that plaintiff's allegations were “defamatory.” In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct. Jd. ¥ 17. 24. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (emphasis supplied). The statement was intended to be a single, one-time-only, comprehensive response—quoted in full—to plaintiff's December 30, 2014, allegations that would give the media Ms. Maxwell’s response. /d. 4 19. The purpose of the prefatory statement was to inform the media-recipients of this intent. /d. 25. Plaintiffs activities to bring light to the rights of victims of sexual abuse. Plaintiff has engaged in numerous activities to bring attention to herself, to the prosecution and punishment of wealthy individuals such as Epstein, and to her claimed interest of bringing light to the rights of victims of sexual abuse. 26. Plaintiff created an organization, Victims Refuse Silence, Inc., a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. Doc.1 4 24-25. 27. The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse.” Id. § 25. Toward this end, plaintiff has “dedicated her professional life to helping victims of sex trafficking.” Jd.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page16 of 77 28. Plaintiff repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. See This Motion at 99 51-54. 29. As discussed above, on December 30, 2014, plaintiff publicly filed an “entirely unnecessary” joinder motion laden with what Judge Marra described as “unnecessary,” “lurid details’? about being “sexually abused” as a “minor victim[]” by wealthy and famous men and being “trafficked” all around the world as a “sex slave.” EXHIBIT D, at 1 n.1, 3-6. 30. The plaintiff's alleged purpose in filing the joinder motion was to “vindicate” her rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution agreement” with Epstein, “shed tremendous public light’ on Epstein and “other powerful individuals” that would undermine the agreement, and support the CVRA plaintiffs’ request for documents that would show how Epstein “used his powerful political and social connections to secure a favorable plea deal” and the government’s “motive” to aid Epstein and his “coconspirators.” See EXHIBIT D, at 1, 6-7, 10 (emphasis supplied). 31. Plaintiff has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking 1n Epstein’s alleged “sex scheme.” EXHIBIT KK. 32. Republication alleged by plaintiff. Plaintiff’ was required by Interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were “published globally, including -EXHIBIT E, at 7. “Id. at 5. “Id. °The undisputed facts relevant to this Motion are contained in the Facts section, above, and within each argument as appropriate. The undisputed facts will be sequentially numbered throughout this Motion.

Case 18-2868, Document 276, 08/09/2019, 2628224, Page17 of 77 within the Southern District of New York,’” as plaintiff alleged in Paragraph 9 of Count I of her complaint. In response, plaintiff identified the January 2015 statement and nine instances in which various news media published portions of the January 2015 statement in news articles or broadcast stories. EXHIBIT H, at 7-8; EXHIBIT I, at 4. 33. Innone of the nine instances was there any publication of the entire January 2015 statement. See EXHIBIT H, at 7-8; EXHIBIT I, at 4. 34. Ms. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in plaintiff’s response to Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015 statement. EXHIBIT J 4] 24; EXHIBIT K 4§ 2-3.. 35. Plaintiff?s defamation action against Ms. Maxwell. Eight years after Epstein’s guilty plea, plaintiff brought this action, repeating many of the allegations she made in her CVRA joinder motion. See Doc.1 § 9. 36. The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”’: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (b) That the allegations have been “shown to be untrue.” (c) That Gtuffre’s “claims are obvious lies.” Doc.1 4 30 (boldface and underscoring omitted). SUMMARY JUDGMENT STANDARD “{C]ourts should not be reluctant to grant summary judgment in appropriate cases. ‘One of the principal purposes of the summary judgment rule 1s to isolate and dispose of factually insupportable claims,’ thereby permitting courts to avoid ‘protracted, expensive and harassing trials.” Don King Prods., Inc. v. Douglas, 742 F. Supp. 778, 780 (S.D.N.Y. 1990) (quoting 10

Case 18-2868, Document 276, 08/09/2019, 2628224, Page18 of 77 Celotex Corp. v. Catrett, 477 U.S. 317, 323-24 (1986), and Meiri v. Dacon, 759 F.2d 989, 998 (2d Cir. 1985)). Where summary judgment is sought under Article I, Section 8, of the New York Constitution, the New York Court of Appeals has declared, “we reaffirm our regard for the particular value of summary judgment, where appropriate, in libel cases,” Jmmuno AG v. MoorJankowski, 567 N.E.2d 1270, 1282 (N.Y. 1991), particularly when as here a defendant 1s challenging a defamation claim under the “independent State law approach” articulated in Immuno AG that might make summary disposition more likely than under a federal approach, see id. Summary judgment is appropriate where “there is no genuine issue as to any material fact and... the moving party is entitled to a judgment as a matter of law.” Fed. R. Civ. P. 56(c). The relevant inquiry on application for summary judgment is “whether the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one-sided that one party must prevail as a matter of law.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 251-52 (1986). “T]he mere existence of some alleged factual dispute between the parties will not defeat an otherwise properly supported motion for summary judgment; the requirement is that there be no genuine issue of material fact.” Id. at 247-48. The substantive law determines what facts are material. /d. at 248. “Only disputes over facts that might affect the outcome of the suit under the governing law will properly preclude the entry of summary judgment. Factual disputes that are irrelevant or unnecessary will not be counted.” /d. A dispute about a material fact is “genuine” if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” /d. In the face of a properly supported summary judgment motion, the plaintiff may not “rest on [the] allegations” in her complaint. /d. at 249. The trial court’s function is to determine 11

Case 18-2868, Document 276, 08/09/2019, 2628224, Page19 of 77 whether there is a genuine issue for trial, and “there is no issue for trial unless there 1s sufficient evidence favoring the nonmoving party for a jury to return a verdict for that party.” Jd. “T]he plain language of Rule 56(c) mandates the entry of summary judgment . . . against a party who fails to make a showing sufficient to establish the existence of an element essential to that party’s case, and on which that party will bear the burden of proof at trial.” Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). In such a situation, “there can be ‘no genuine issue as to any material fact,’ since a complete failure of proof concerning an essential element of the nonmoving party’s case necessarily renders all other facts immaterial. The moving party is ‘entitled to a judgment as a matter of law’ because the nonmoving party has failed to make a sufficient showing on an essential element of her case with respect to which she has the burden of proof.” /d. at 323; see Fed. R. Civ. P. 56 advisory committee’s notes (2010 amendments) (restoration of “shall grant summary judgment” was intended to “express the direction to grant summary judgment, and “avoids the unintended consequences of any other word”’). ARGUMENT I. Ms. Maxwell is not liable for republications of her January 2015 statement that she did not authorize or request and by entities she did not control. A. Summary judgment is warranted to the extent plaintiff seeks to impose liability on any media’s republication of all or a portion of the January 2015 statement. Messrs. Barden and Gow, acting on behalf of Ms. Maxwell, caused the January 2015 statement to be transmitted—published—to various individuals employed by media organizations. The question presented in this Argument I is whether Ms. Maxwell is liable for any republication of all or a portion of the January 2015 statement by the media. Under New York law, the answer is no. Liability for a republication “must be based on real authority to influence the final product.” Davis v. Costa-Gavras, 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984) (emphasis supplied). 12

Case 18-2868, Document 276, 08/09/2019, 2628224, Page20 of 77 “| W |here a defendant ‘had no actual part in composing or publishing,’ he cannot be held liable ‘without disregarding the settled rule of law that no man 1s bound for the tortious act of another over whom he has not a master’s power of control.’” /d. (quoting Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906)); see Geraci v. Probst, 938 N.E.2d 917, 921 (N.Y. 2010) (holding that defendant was not liable for republication, in part because “there 1s no indication that Probst had any control over whether or not Newsday published the article”). “Conclusive evidence of lack of actual authority [is] sufficiently dispositive that the [trial court] “ha[s] no option but to dismiss the case....’” /d. (quoting Rinaldi v. Viking Penguin, Inc., 420 N.E.2d 377, 382 (N.Y. 1981)). As the New York Court of Appeals held in Geraci: It 1s too well settled to be now questioned that one who ... prints and publishes a libel[] 1s not responsible for its voluntary and unjustifiable repetition, without his authority or request, by others over whom he has no control and who thereby make themselves liable to the person injured, and that such repetition cannot be considered in law a necessary, natural and probable consequence of the original slander or libel. 938 N.E.2d at 921 (internal quotations and citation omitted). The rationale behind this rule is that “each person who repeats the defamatory statement is responsible for the resulting damages.” Jd. (internal quotations omitted). With the goal of garnering maximum publicity and defaming Ms. Maxwell, Ms. Giuffre filed an “entirely unnecessary”’ joinder motion with “lurid details” about sexual acts for the purpose of attracting the attention of the public, which was “curious, titillated or intrigued” about alleged sexual acts and relationships among the rich and famous. In defense of Ms. Maxwell’s reputation, Messrs. Barden and Gow responded with the January 2015 statement. "EXHIBIT E, at 7. *Time, Inc. v. Firestone, 424 U.S. 448, 488 n.1 (1976) (Marshall, J., dissenting) (quoting Firestone v. Time, Inc., 271 So. 2d 745, 752 (Fla. 1972)). 13

Case 18-2868, Document 276, 08/09/2019, 2628224, Page21 of 77 The email transmitting the statement explained it was “‘a quotable statement on behalf of Ms Maxwell” and “[n]o further communication will be provided by her on this matter.” EXHIBIT F (emphasis supplied). The media representatives were notified that if they intended to use the statement, it was to be quoted in its entirety. See This Motion 4 24, at 8. Ms. Maxwell and Messrs. Barden and Gow had no ability to control whether or how the media-recipients would use the statement, and they made no effort to control whether or how they would use the statement. EXHIBIT K §§ 2-3; EXHIBIT J 4] 24. Ms. Maxwell 1s not responsible for any republication of the January 2015 statement, whether it was republished in whole or in part,’ since she had no authority or control over any media that published any portion of it. In the words of this Court, she had no “real authority to influence the final product,” Davis, 580 F. Supp. at 1096. The media’s selective, partial republication of the statement 1s more problematic yet. An original publisher of a statement cannot be charged with a republisher’s “editing and excerpting of her statement.” Rand v. New York Times Co., 430 N.Y.S.2d 271, 275 (App. Div. 1980). The rule applies with even greater force where as here a defamation claim is grounded on the expression of opinion: An individual “cannot be liable for the republication of a derogatory but constitutionally protected opinion when the foundation upon which that opinion is based is omitted. The defamatory remark should be ‘read against the background of its issuance.’” Jd. (quoting Mencher v. Chesley, 75 N.E.2d 257, 259 (N.Y. 1947), and citing James v. Gannett Co., 353 N.E.2d 834, 838 (N.Y. 1976)). *Plaintiff has not disclosed under Fed. R. Civ. P. 26(a)(1)(A)(ii) any republication of the entirety of the January 2015 statement. In response to our discovery requests requiring her to identify republications of all or a portion of the statement, plaintiff identified no republication of the entirety of the statement. 14

Case 18-2868, Document 276, 08/09/2019, 2628224, Page22 of 77 The rationale for this rule is found in the New York Court of Appeals’ explanation of how an original publisher’s allegedly defamatory statement should be interpreted: The statement complained of will be read against the background of its issuance with respect to the circumstances of its publication. It is the duty of the court, in an action for libel, to understand the publication in the same manner that others would naturally do. The construction which it behooves a court of justice to put on a publication which is alleged to be libelous is to be derived as well from the expressions used as from the whole scope and apparent object of the writer. James, 353 N.E.2d at 838 (emphasis supplied; citations and internal quotations omitted). The January 2015 statement was intended to be read by the media-recipients 1n its entirety. One, it was intended to be a comprehensive, one-time-only response to all of plaintiffs lurid and false allegations of sexual and other misconduct by Ms. Maxwell. See EXHIBIT J ¥ 13. Two, the statement was complex in that it could not be quoted partially and out of context and still convey the intended meaning. Among other things, the statement was intended to show why plaintiff could not be believed—why her allegations are “obvious lies”—by pointing out how her story changed each time she retold the story. As Mr. Barden explains: Selective and partial quotation and use of the statement would disserve my purposes. It was intended to address Plaintiffs behavior and allegations against Ms. Maxwell on a broad scale, that is to say, Plaintiffs history of making false allegations and innuendo to the media against Ms. Maxwell. This is why the statement references Plaintiff's “original allegations” and points out that her story “changes” —1.e. 1s embellished—over time including the allegations “now” that Professor Dershowitz allegedly had sexual relations with her. This is why I distinguished in the statement between Plaintiffs “original” allegations and her “new,” joinder-motion allegations, which differed substantially from the original allegations. And this is why I wrote, “Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it 1s alleged by [Plaintiff] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies.” (Emphasis supplied.) Having established the dramatic difference between Plaintiffs two sets of allegations, which suggested she was fabricating more and more-salacious allegations as she had more time to manufacture them, I added the third paragraph: “[Ms. Giuffre’s] claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory.” (Emphasis supplied.) I believed then, and believe now, that it was and remains a fair inference and conclusion that her claims were and are “obvious 15

Case 18-2868, Document 276, 08/09/2019, 2628224, Page23 of 77 lies.” As noted, her claims not to have slept with Prince Andrew and to have slept with Prince Andrew are a classic example of an obvious lie. One or other account is on the face of it a lie. EXHIBIT J § 20. That Mr. Barden on behalf of Ms. Maxwell was expressing his opinion—in the form of a legal argument—as a lawyer would be lost if words and phrases are extracted from and used outside the context of the January 2015 statement. Yet, this is precisely what the media did in their articles on the statement and what plaintiff did in her complaint (see Doc.1 4 30). Finally, the statement was intended to be a “shot across the bow” of the media-recipients so that they understood the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct. See id. 4 17. Selectively excerpting from the statement would seriously undermine this purpose by changing the force of the message to the media-recipients. Under these circumstances, selective, partial and out-of-context republication of Mr. Barden’s deliberate and carefully crafted message to the media-representatives, as a matter of law, cannot result in defamation liability for Ms. Maxwell. Accordingly, the Court should enter partial summary judgment. B. Because plaintiff is a limited public figure, imposing liability upon Ms. Maxwell for republication of the January 2015 statement would violate the First Amendment. As this Court recognized in Davis, New York Times v. Sullivan'” and its progeny “preclude states from imposing liability without fault in actions for defamation, especially by public figures.” 580 F. Supp. at 1097 (citing, inter alia, Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974)). This principle precludes the imposition of liability for republication of an allegedly '°376 U.S. 254 (1964). 16

Case 18-2868, Document 276, 08/09/2019, 2628224, Page24 of 77 defamatory statement on a party who had no “actual . . . responsibility for the decision to republish” the statement. Jd. A public figure includes a person who “voluntarily injects himself or is drawn into a particular public controversy and thereby becomes a public figure for a limited range of issues.” Gertz, 418 U.S. at 351; see, e.g., James, 353 N.E.2d at 839 (public figure includes those who have “thrust themselves to the forefront of particular public controversies 1n order to influence the resolution of the issues involved’). The evidence that plaintiff is a public figure 1s overwhelming, particularly in connection with the subject matters and issues addressed by and underlying the January 2015 statement. See This Motion §f 51-54. In the case at bar, Ms. Maxwell and her agents had no responsibility for any media organization’s decision to republish the January 2015 statement, and they did not participate in any such decision. See EXHIBITS J 9 24 & K ¥§ 2-3. Liability for republication by media organizations of the January 2015 statement therefore is precluded under the First Amendment. C. Plaintiff should be barred from introducing into evidence any republication of an excerpt from the January 2015 statement. In Geraci, the plaintiff suggested in a letter to the Long Island fire district where defendant was a commissioner that defendant had engaged in self-dealing in the district’s purchase of fire trucks. At trial the plaintiff sought to introduce into evidence portions of a Newsday article that republished parts of the defendant’s letter. Defense counsel objected, arguing it was inflammatory and prejudicial. Plaintiff's counsel later argued the article “was not being offered as a republication, but on the issue of damages to show how far the allegations had circulated.” 938 N.E.2d at 920. Additionally, plaintiff’s counsel argued that the defendant “should have reasonably anticipated” that his letter to the fire district “would be newsworthy.” Id. The trial court admitted the article, and the Appellate Division affirmed. I

Case 18-2868, Document 276, 08/09/2019, 2628224, Page25 of 77 The New York Court of Appeals reversed. The risk of admitting such evidence, the court held, is the jury may “charge against defendant a separate, distinct libel (not pleaded in [the] complaint) by someone else, contrary to the rule that [t]he original publisher of a libel 1s not responsible for its subsequent publication by others.” Geraci, 938 N.E.2d at 921. Accordingly, the court held, “‘[A]bsent a showing that [defendant] approved or participated in some other manner in the activities of the third-party republisher|,|’ there 1s no basis for allowing the jury to consider the article containing the republished statement as a measure of plaintiff's damages attributable to defendants.” /d. (emphasis supplied; quoting Karaduman v. Newsday, Inc., 416 N.E.2d 557, 560 (1980)). Neither Ms. Maxwell nor her agents approved or participated in any activity of any media organization in its decision to publish or not to publish any part of the January 2015 statement. EXHIBIT J 9 2; K J 2-3.. Accordingly, “there is no basis for allowing the jury to consider [any] article containing the republished statement as a measure of plaintiff's damages attributable to [Ms. Maxwell],” id. Plaintiff should be barred from introducing any evidence of any republication of the January 2015 statement by any non-party. See, e.g., Soley v. Wasserman, No. 8 CIV. 9262 KMW FM, 2013 WL 3185555, at *8 (S.D.N.Y. June 21, 2013) (precluding plaintiff from adducing evidence intended to establish claim on which court had entered partial summary judgment). Il. Summary judgment is warranted under the New York Constitution. A. The January 2015 statement constitutes nonactionable opinion. “Whether particular words are defamatory presents a legal question to be resolved by the court in the first instance.’” Germain v. M & T Bank Corp., 111 F. Supp. 3d 506, 534 (S.D.N.Y. 2015) (brackets omitted; quoting Celle v. Filipino Reporter Enters. Inc., 209 F.3d 163, 18

Case 18-2868, Document 276, 08/09/2019, 2628224, Page26 of 77 177 (2d Cir. 2000)); accord, e.g., Aronson v. Wiersma, 483 N.E.2d 1138, 1139 (N.Y. 1985). New York defamation law applies. Doc.37 at 6 n.2. “It is a settled rule that expressions of an opinion false or not, libelous or not, are constitutionally protected and may not be the subject of private damage actions.” Steinhilber v. Alphonse, 501 N.E.2d 550, 550 (N.Y. 1986) (internal quotations omitted). Whether a challenged statement is fact or opinion 1s a question of law to be decided by the Court. Enigma Software Grp. USA, LLC v. Bleeping Computer LLC, No. 16 CIV. 57 (PAE), 2016 WL 3773394, at *11 (S.D.N.Y. July 8, 2016); accord, e.g., Steinhilber, 501 N.E.2d at 553. In Immuno AG v. Moor-Jankowski,'' the New York Court of Appeals declared that the New York Constitution provides greater protection to opinion than the First Amendment of the United States Constitution. The court recognized that in Milkovich v. Lorain Journal Co., 497 U.S. 1 (1990), the United States Supreme Court reversed a state court decision dismissing a complaint on the ground that the allegedly defamatory statement was nonactionable opinion. The Supreme Court held there is no “wholesale defamation exemption” protecting opinion. The First Amendment analysis under Milkovich, the New York court observed, was one-dimensional: the trial court should look first to the allegedly defamatory statement’s specific words as commonly understood and then determine whether the statements were “‘verifiable’’; if the statements were verifiable, then they were actionable statements of fact. See Immuno AG, 567 N.E.2d at 1274-75. The Supreme Court’s holding made it clear that it would not consider as part of the First Amendment analysis “the full context of the article in which the challenged statements appear, and the broader social context or setting surrounding the communication.” /d. at 1274. ''567 N.E.2d 1270 (N.Y. 1991). 19

Case 18-2868, Document 276, 08/09/2019, 2628224, Page27 of 77 The Immuno AG Court of Appeals held that Article I, Section 8, of the New York Constitution required a multidimensional approach to the determination whether an allegedly defamatory statement constitutes constitutionally protected opinion. The court gave numerous reasons. New York’s “expansive” constitutional guarantee of speech was formulated and adopted before the application of the First Amendment to the states; “[i]t has long been our standard in defamation actions” to consider factors beyond whether facts are “verifiable”; and the court was concerned that if “type of speech’ is to be construed narrowly|,] . . . insufficient protection may be accorded to central values protected by the law of this State.” Jd. at 1277-78. The Immuno AG court reaffirmed that where a defendant alleges that the subject statement is opinion, Steinhilber supplies the analytical framework. /d. at 1280. Steinhilber held that whether an allegedly defamatory statement is fact or nonactionable opinion should be decided based on four factors: (1) an assessment of whether the specific language in issue has a precise meaning which 1s readily understood or whether it 1s indefinite and ambiguous; (2) a determination of whether the statement is capable of being objectively characterized as true or false; (3) an examination of the full context of the communication in which the statement appears; and (4) a consideration of the broader social context or setting surrounding the communication including the existence of any applicable customs or conventions which might signal to readers or listeners that what is being read or heard 1s likely to be opinion, not fact. 501 N.E.2d at 554. Application of these factors to the January 2015 statement compels the conclusion that the allegedly defamatory words, phrases and clauses are nonactionable opinion. Whether the specific language in issue has a precise meaning which is readily understood or whether it is indefinite and ambiguous. The three sentences plaintiff alleges are 20

Case 18-2868, Document 276, 08/09/2019, 2628224, Page28 of 77 defamatory are indefinite and ambiguous. The first says plaintiff's “allegations” against Ms. Maxwell are “untrue.” But plaintiff has made many dozens of allegations against Ms. Maxwell, and some are provably false. See This Motion, at J§ 37-50. The statement does not specify which of the allegations are untrue. The second statement is that the “original allegations” have been “shown to be untrue.” The “original allegations” were first revealed in the 2011 Churcher articles. Plaintiff made many dozens of allegations “originally.” The statement does not specify which of the “original” allegations were shown to be untrue. Some have been shown to be untrue. See This Motion, at 53-65. The third statement is that plaintiffs “claims” are “obvious lies.” This too is indefinite and ambiguous. Plaintiff has made many dozens of claims. The statement does not specify which ones are being referenced. More importantly, it does not say how or why some of the claims are “obvious” lies. Regardless, some of plaintiffs claims are “obvious lies.” See This Motion, at 53-65. Whether the three sentences in the January 2015 statement are capable of being objectively characterized as true or false. Can the three sentences be characterized as true or false? They cannot, because the statement does not specify which of the many dozens of allegations plaintiff has made are “untrue” and “shown to be untrue,” and which of plaintiffs many dozens of “claims” are “obvious lies.” It is axiomatic that the plural form of a word, e.g., “allegations” and “claims,” universally denotes—only—‘“‘more than one,” People v. Kocsis, 28 N.Y.S.3d 466, 471 (App. Div. 2016) (emphasis supplied). See, e.g., Lehman Bros. Commercial Corp. v. Minmetals Int’! Non-Ferrous Metals Trading Co., No. 94 CIV. 8301(JFK), 1995 WL 380119, at *6 n.2 (S.D.N.Y. June 26, 1995). So for Steinhilber purposes it is dispositive of the fact versus opinion question 1f we can 21

Case 18-2868, Document 276, 08/09/2019, 2628224, Page29 of 77 identify swo instances in which plaintiff's allegations or claims’ are incapable of being proved true or false. Such examples abound. It cannot be proven true or false whether Ms. Maxwell “appreciated the immunity granted”” under the Epstein plea agreement or whether she “act/ed] »!* That is because these are plaintiff's counsel’s arguments or as a ‘madame’ for Epstein. opinions. The January 2015 statement asserts that these allegations/claims are “false” or “obvious lies.” That assertion cannot be proven true or false under Steinhilber. The full context of the communication in which the statement appears. This factor “1s often the key consideration in categorizing a statement as fact or opinion.” Davis v. Boeheim, 22 N.E.3d 999, 1006 (N.Y. 2014) (internal quotations omitted). In deciding whether a statement 1s defamatory, “[t]he words must be construed in the context of the entire statement or publication as a whole, tested against the understanding of the average reader.” Aronson v. Wiersma, 483 N.E.2d 1138, 1139 (1985); accord Elias v. Rolling Stone LLC, No. 15-CV-5953 (PKC), 2016 WL 3583080, at *6 (S.D.N.Y. June 28, 2016). “It is the duty of the court, 1n an action for libel, to understand the publication in the same manner that others would naturally do. The construction which it behooves a court of justice to put on a publication which is alleged to be libelous is to be derived as well from the expressions used as "In the context of the January 2015 statement, an “allegation” is synonymous with a “claim.” See, e.g., Maule v. Philadelphia Media Holdings, LLC, No. CIV.A. 08-3357, 2010 WL 914926, at *10 (E.D. Pa. Mar. 15, 2010); see generally Black’s Law Dictionary 68 Ce ed.1979) (defining “allegation” as “[t|he assertion, claim, declaration, or statement of a party to an action, made in a pleading, setting out what he expects to prove’), quoted with approval in Martin v. City of Oceanside, 205 F. Supp. 2d 1142, 1147 (S.D. Cal. 2002), aff'd, 360 F.3d 1078 (9"" Cir. 2004). 'SEXHIBIT D, at 4. 40g. 22

Case 18-2868, Document 276, 08/09/2019, 2628224, Page30 of 77 from the whole scope and apparent object of the writer.” James v. Gannett Co., 353 N.E.2d 834, 838 (N.Y. 1976); accord, e.g., Chau v. Lewis, 935 F. Supp. 2d 644, 665 (S.D.N.Y. 2013). In general the trial court should view allegedly defamatory statements from the perspective of the average member of the public. Statements directed to a specific audience, however, are considered from the viewpoint of that audience. Instructive is this Court’s analysis of the perspective from which it should assess an allegedly defamatory article on boxing published to sports readers: The issue of how the “average reader” would construe the statements 1s certainly a fair one, for the question of whether statements are defamatory turns on how the audience to whom the statements are addressed would interpret them. ... As the New York State Court of Appeals has explained in [a] boxingdefamation case[]:.... “The words are to be construed not with the close precision expected from lawyers and judges but as they would be read and understood by the public to which they are addressed... .” Here, the statements in question were addressed to readers of an Internet boxing website and the sports pages of daily newspapers. The statements must be considered from their viewpoint. As Judge Martin .. . held [in Horne v. Matthews, No. 97 Civ. 3605(JSM), 1997 WL 598452 (S.D.N.Y. Sept. 25, 1997)]: “An article on the sports page of a newspaper should be viewed from the perspective of the audience to whom it is addressed, i.e., the understanding of “a sophisticated and sports-conscious reader.” Dibella v. Hopkins, No. 01 CIV. 11779 (DC), 2002 WL 31427362, at *2 (S.D.N.Y. Oct. 30, 2002) (emphasis supplied; citation omitted). The entirety of the email containing the January 2015 statement from Mr. Gow sent to various media representatives reads: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation 2

Case 18-2868, Document 276, 08/09/2019, 2628224, Page31 of 77 Jane Doe 3 1s Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts [sic] against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] 1t changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. EXHIBIT F (italics and underscoring supplied). Plaintiff listed the underscored clauses/phrases in the Complaint as the “deliberate falsehoods,” Doc.1 4 30, and “false and defamatory statements,” id. J 32, plaintiff is suing on.'° As discussed above, it is improper to remove from their context and isolate allegedly defamatory words, phrases and clauses of sentences from an allegedly defamatory publication. Instead, the allegedly defamatory words, phrases and clauses must be (a) “construed in the context of the entire statement or publication as a whole”;'° (b) considered “from the whole scope and apparent object of the writer”;'’ and (c) “viewed from the perspective of the audience to whom it is addressed.””'® The statement was directed at a discrete number of—some 30—members of the media in reply to their request for a response from Ms. Maxwell to Ms. Giuffre’s CVRA joinder motion. Plaintiff also alleges that Ms. Maxwell slandered her on January 4, 2015, when responding to a question posed to her while she was on a Manhattan street. Doc.1 9 37. This allegedly defamatory statement is addressed in Argument IV, below. '® Aronson, 483 N.E.2d at 1139. '” James, 353 N.E.2d at 838. 'SDibella, 2002 WL 31427362, at *2. 24

Case 18-2868, Document 276, 08/09/2019, 2628224, Page32 of 77 Mr. Barden, who prepared the January 2015 statement, did not intend the January 2015 statement to be a traditional press release solely to disseminate information to the media. EXHIBIT K § 15. So he did not request that Mr. Gow or any other public relations specialist prepare the statement. Id. Instead, Mr. Gow served only as Mr. Barden’s conduit to the media representatives who had requested a response to the joinder motion allegations and who Mr. Barden believed might republish those allegations. /d. Mr. Barden intended the statement to mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff's false allegations. /d. 4 16. He believed this could be accomplished by suggesting to the media that, among other things, they should subject plaintiff’ s allegations to inquiry and scrutiny. /d. For example, he noted that plaintiff's allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” Jd. Mr. Barden also intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish plaintiffs allegations without conducting any inquiry of their own. /d. § 17. So Mr. Barden stated repeatedly that plaintiff’ s allegations were “defamatory.” /d. In this sense, the statement was very much intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct. Jd. Consistent with Mr. Barden’s purposes for the statement, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (emphasis supplied). /d. §] 19. The statement was intended to be a single, onetime-only, comprehensive response—quoted in full—to plaintiff's December 30, 2014, ZS

Case 18-2868, Document 276, 08/09/2019, 2628224, Page33 of 77 allegations that would give the media Ms. Maxwell’s response. /d. The purpose of the prefatory statement was to inform the media-recipients of this intent. Jd. We note that plaintiff in her Complaint makes the same mistake as the Steinhilber plaintiff—extracting words and phrases from their opinion context so that she can claim the assertion of a “defamatory” fact. See Doc.1 § 30. That is not permissible. See Steinhilber, 501 N.E.2d at 555 (“The sentence which plaintiff selects from the message and claims 1s “factually laden”—impugning her as lacking in “talent, ambition, and initiative’”—is preceded and followed by statements which are clearly part of the attempt at humor prevailing throughout... .”). The broader social context or setting surrounding the communication, including the existence of any applicable customs or conventions which might signal to readers that what is being read is likely to be opinion, not fact. This factor 1s concerned with “the factual background” leading up to the preparation of the statement. It is a critical factor here. In December 2014, plaintiff and her lawyers had timed for maximum effect—during the slow news cycle between Christmas and New Year’s Day—the public filing of a superfluous motion filled with salacious and provocative allegations of “sexual abuse” and “sexual trafficking” involving wealthy and prominent Americans. Plaintiff deliberately placed Ms. Maxwell in the middle of the abuse and trafficking, alleging that she recruited plaintiff into the sexual abuse/trafficking scheme and engaged in numerous criminal acts. Importantly, three years earlier when plaintiff was interviewed extensively by Churcher for two lengthy articles published in March 2011, plaintiff's allegations concerning Ms. Maxwell 9919 were very much different. In the articles discussing plaintiff's “shocking account” ” of being ‘EXHIBIT A, at 2. 26

Case 18-2868, Document 276, 08/09/2019, 2628224, Page34 of 77 9920 sexually exploited by Epstein, Prince Andrew and Epstein’s “male peers,” plaintiff made 9921 9922 virtually none of what Judge Marra found were “unnecessary” and “lurid details’””~ about how Ms. Maxwell allegedly had subjected her to sexual abuse and trafficking. After plaintiff filed the CVRA motion, some thirty reporters contacted Ms. Maxwell’s press representative, Mr. Gow, for Ms. Maxwell’s response. As Ms. Maxwell’s lawyer, Mr. Barden undertook that task. Relying on his knowledge of the 2011 articles publishing plaintiff s allegations and drawing on his experience and training as a lawyer, Mr. Barden crafted a response with the goal of discrediting plaintiff and what the statement called plaintiff's “new” allegations. To that end Mr. Barden contrasted plaintiff's “old” allegations from 2011 with the “new” 2014 allegations. The second paragraph of the statement 1s indicative of this strategy: “Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by [Ms. Giuffre] that Alan Derschowitz [sic] 1s involved in having sexual relations with her, which he denies.”” EXHIBIT F (emphasis supplied). Having established the dramatic difference between these sets of allegations suggesting plaintiff was fabricating more and more-salacious allegations as she had more time to manufacture them, Mr. Barden added the third paragraph: “[Ms. Giuffre’s] claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory.” /d. (emphasis supplied). Mr. Barden’s arguments constitute “pure opinion,” Steinhilber, 501 N.E.2d at 552. They take established and revealed facts—plaintiff’s modest 2011 allegations to a newspaper reporter and plaintiff’s expansive, unnecessary and lurid 2014 allegations in a motion to open the door to °° Td. “lAXHIBIT E, at 5. ig ZT

Case 18-2868, Document 276, 08/09/2019, 2628224, Page35 of 77 criminal prosecutions of (and civil lawsuits against) wealthy and prominent men around the world—to draw an obvious inference that plaintiff was (more) truthful in the 2011 articles and engaged in massive manufacturing of fiction in the 2014 joinder motion. There is no limit to the subject matters on which pure opinions may be expressed with constitutional immunity, including whether a person believes another 1s “lying” or is a “liar.” See, e.g., Indep. Living Aids, Inc. v. Maxi-Aids, Inc., 981 F. Supp. 124, 128 (E.D.N.Y. 1997) (granting summary judgment: “Read in the context of the entire article, Zaretsky’s remarks, calling Sandler and others ‘liars,’ can only be understood as a denial of their accusations. .. . Even the most careless reader must have perceived that the words were no more than rhetorical hyperbole, a vigorous epithet used by Zaretsky who considered himself unfairly treated and sought to bring what he alleged were the true facts to the readers. The epithet ‘liar’ in this context, standing by itself, merely expressed the opinion that anyone who persisted in accusing Zaretsky of improper business practices could not be telling the truth. Since the basis for this opinion was fully set forth, the communication of Zaretsky’s views cannot be libelous.”’) (citations, ellipsis, brackets and internal quotations omitted); see Gross v. New York Times, 623 N.E.2d 1163, 1169 (N.Y. 1993) (“[E]ven when uttered or published in a... serious tone, accusations of criminality could be regarded as mere hypothesis and therefore not actionable if the facts on which they are based are fully and accurately set forth and it is clear to the reasonable reader . . . that the accusation 1s merely a personal surmise built upon those facts. In all cases, whether the challenged remark concerns criminality or some other defamatory category, the courts are obliged to consider the communication as a whole, as well as its immediate and broader social contexts, to determine whether the reasonable listener . . . is likely to understand the remark as an assertion of provable fact.”’). 28

Case 18-2868, Document 276, 08/09/2019, 2628224, Page36 of 77 Mr. Barden’s inference from disclosed facts qualifies as “pure opinion,” Steinhilber, 501 N.E.2d at 552. Accordingly, that Mr. Barden characterized plaintiff's 2014 allegations harshly as “obvious lies” as opposed to “untruths” or some softer term 1s of no moment. “[U]nder New York law, pure opinion . . . is not actionable because expressions of opinion, as opposed to assertions of fact, are deemed privileged and, no matter how offensive, cannot be the subject of an action for defamation.” Ratajack v. Brewster Fire Dep't, Inc. of the Brewster-SE Joint Fire Dist., 178 F. Supp. 3d 118, 158 (S.D.N.Y. 2016) (internal quotations and ellipsis omitted; brackets altered); accord, e.g., Mann v. Abel, 885 N.E.2d 884, 885-86 (N.Y. 2008). The drawing of such inferences would be constitutionally protected even under the standards of the First Amendment that are less protective of opinion than is Article I, Section 8, of the New York Constitution. See Adelson v. Harris, 973 F. Supp. 2d 467, 490 (S.D.N.Y. 2013) (“In determining whether a statement constitutes constitutionally protected opinion, courts also look to the specific context of the statement. When looking at a statement’s specific context, of particular importance 1s the principle that when an author outlines the facts available to him, thus making it clear that the challenged statements represent his own interpretation of those facts and leaving the reader free to draw his own conclusions, those statements are generally protected by the First Amendment.”’) (internal quotations and brackets omitted). The application of the four Steinhilber factors confirms that the three phrases and/or clauses plaintiff alleges are defamatory are in fact part of a statement that taken as a whole constitutes nonactionable opinion. The premise of plaintiff's Complaint is that once she is able to identify references in the January 2015 statement to any assertion of fact that potentially 1s subject to proof, e.g., the truth or falsity of her many dozens of allegations old and new, then she has a viable defamation claim. That ignores the teaching of Steinhilber and Immuno AG. As the 29

Case 18-2868, Document 276, 08/09/2019, 2628224, Page37 of 77 Steinhilber court held, “even apparent statements of fact may assume the character of statements of opinion, and thus be privileged, when made in public debate, heated labor dispute, or other circumstances in which an audience may anticipate the use of epithets, fiery rhetoric or hyperbole.” /d. (internal quotations and brackets omitted); see Gross, 623 N.E.2d at 1169 (“we stress once again our commitment to avoiding the ‘hypertechnical parsing’ of written and spoken 999 words for the purpose of identifying “possible “fact[s]”’ that might form the basis of sustainable libel action”) (quoting Jmmuno AG, 567 N.E.2d at 1282). To the same effect is this Court’s citation to a Louisiana Supreme Court decision for the proposition that “‘[w]ords which, taken by themselves, would appear to be a positive allegation of fact, may be shown by the context to be a mere expression of opinion or argumentative influence.’” Adelson, 973 F. Supp. 2d at 488 (emphasis supplied; quoting Mashburn v. Collin, 355 So. 2d 879, 885 (La. 1977)). It also is important to take into account, as Steinhilber requires, that Mr. Barden was directing the January 2015 statement to a discrete number of media representatives who were aware of plaintiff's “original” and “new,” joinder-motion allegations and who were requesting a response from Ms. Maxwell to the “new” allegations. These newspaper reporters and other media representatives would have the point Mr. Barden was making—the opinion he was expressing—namely, that there was good reason to believe plaintiff was fabricating allegations for her purposes. In the context of the media circus that ensued the public filing of the joinder motion and the media’s repeated and insistent requests for an immediate response from Ms. Maxwell, it is highly unlikely any media-recipients of the January 2015 statement expected anything other than a statement equivalent to the March 2011 statement condemning the allegations; and it 1s highly likely all the media-recipients understood the statement to be a 30

Case 18-2868, Document 276, 08/09/2019, 2628224, Page38 of 77 forceful argument that plaintiffs shifting and inconsistent stories about what allegedly happened rendered her inherently unbelievable and proved her increasingly provocative and lurid allegations were “obvious lies.” These are precisely the messages Mr. Barden sent to them. 99 66 The general nature of Mr. Barden’s assertions (“allegations,” “original allegations,” “claims’’), the distinction between plaintiffs “original” and “new” allegations, and the inferences he drew from comparing the “original” and “new” allegations—together—powerfully demonstrate that the January 2015 statement was nothing more than opinion. B. In this Rule 56 proceeding, this Court’s Rule 12(b)(6) opinion does not control the question of law whether the January 2015 statement constitutes nonactionable opinion. In its Rule 12(b)(6) opinion the Court, relying on Davis v. Boeheim, 22 N.E.3d 999 (2014), ruled that the three allegedly defamatory statements in the January 2015 statement (see Doc.1 § 30(a)-(c)) have a specific and readily understood factual meaning, are capable of being proven true or false, and “clearly constitute fact to the reader.” Doc.37 at 9. We respectfully suggest the Court’s Rule 12(b)(6) decision does not control in this Rule 56 proceeding. To begin with, the standards for deciding a Rule 12(b)(6) motion are substantially different from the standards for deciding a Rule 56 motion. As the Court noted, in deciding a 12(b)(6) motion the court must accept as true the factual allegations and draw all inferences in the plaintiff's favor; a plaintiff need only state a claim that is “plausible on its face.” Jd. at 3 (internal quotations omitted). In contrast, in deciding a Rule 56 motion the plaintiff defending the motion may not “rest on [the] allegations” in her complaint. Anderson, 477 U.S. at 249. The difference in the standards 1s crucial here. 999 As this Court recognized, “‘[t]he dispositive inquiry’” for purposes of deciding whether an allegedly defamatory statement is fact or nonactionable opinion is whether “‘a reasonable 999 reader could have concluded that the statements were conveying facts about the plaintiff. 31

Case 18-2868, Document 276, 08/09/2019, 2628224, Page39 of 77 Doc.37 at 7 (quoting Davis, 22 N.E.3d at 1005). To answer that inquiry, the Court applied the three factors enumerated in Davis. See id. These three factors are the same as the four factors in Immuno AG; the difference is that the Davis court collapsed the Jnmuno AG’s third and fourth factors into one. See Davis, 22 N.E.3d at 1005. As framed by the Davis court, the third factor is “whether either the full context of the communication in which the statement appears or the broader social context and surrounding circumstances are such as to signal . . . readers or listeners that what is being read or heard is likely to be opinion, not fact.” /d. (internal quotations omitted; emphasis supplied), quoted in Doc.37 at 7. Although this Court did not note this in its opinion, this third factor “is often the key consideration in categorizing a statement as fact or opinion.” /d. at 1006 (emphasis supplied). As in Davis, which also was decided on a Rule 12(b)(6) motion,” this Court when considering the third factor did not have the benefit of any of the evidence presented 1n this motion. That is to say, the Court did not have the “full context of the” July 2015 statement or the “broader social context and surrounding circumstances” of the statement, since none of the evidence presented in this Motion was pleaded in the Complaint. Nor, in the context of the 12(b)(6) motion, did the Court consider that the relevant 9924 “readers” of the July 2015 statement were not the “average reader’ in the general public, but a > q-° “cynical” and “sophisticate group of about 30 reporters and journalists who were knowledgeable about plaintiffs allegations of being the victim of sexual abuse and sexual *3 Davis, 22 N.E.3d at 1001. ** Aronson, 483 N.E.2d at 1139. Steven Shiffrin, The Politics of the Mass Media and the Free Speech Principle, 69 Ind. L.J. 689, 702 (1994). *°Dibella, 2002 WL 31427362, at *2. 32

Case 18-2868, Document 276, 08/09/2019, 2628224, Page40 of 77 trafficking. Viewing the July 2015 statement from the perspective of these reporters and journalists—the only persons who received the July 2015 statement—presents a different landscape in the “fact versus opinion” analysis. Applying the third factor with the benefit of the Rule 56 records compels a conclusion different from the one this Court reached on the barren Rule 12(b)(6) record. For example, this Court did not consider that the media-recipients of the July 2015 statement would have understood the statement in precisely the way Mr. Barden intended: Based on a comparison of dramatic differences between her “original” and “new” allegations, Ms. Giuffre is a teller of falsehoods—is a liar—and cannot be trusted, and her new CVRA joint-motion allegations, which deviated so substantially from her originally allegations, are falsehoods—proven false by her increasingly provocative and lurid versions of her story of “victimhood.” See generally Exhibit J. II. The pre-litigation privilege bars this action. Statements pertinent to a good faith anticipated litigation made by attorneys (or their agents under their direction’’) before the commencement of litigation are privileged and “no cause of action for defamation can be based on those statements,” Front, Inc. v. Khalil, 28 N.E.3d 15, 16 (N.Y. 2015). So long as there was “a good faith basis to anticipate litigation,” a statement concerning either “actual litigation or prelitigation matters” is subject to an “absolute privilege.” Flomenhaft v. Finkelstein, 8 N.Y.S.3d 161, 164 n.2 (App. Div. 2015) (emphasis supplied); accord Kirk v. Heppt, 532 F. Supp. 2d 586, 593 (S.D.N.Y. 2008). The privilege covers statements made in connection with “pending or “contemplated litigation.” Goldstein v. Cogswell, No. 85 CIV. 9256 (KMW), 1992 WL 131723, at *27 n.32 (S.D.N.Y. June 1, 1992) It covers statements made outside court, including 1n written “"See Chambers v. Wells Fargo Bank, N.A., No. 2016 WL 3533998, at *8 (D.N.J. June 28, 2016); see generally Hawkins v. Harris, 661 A.2d 284, 289-91 (N.J. 1995). 33

Case 18-2868, Document 276, 08/09/2019, 2628224, Page41 of 77 communications “between litigating parties or their attorneys.” Klein v. McGauley, 29. A.D.2d 418, 420 (N.Y. App. Div. 1968), cited with approval in Petrus v. Smith, 91 A.D.2d 1190, 1191 (N.Y. App. App. Div. 1983). It covers “cease and desist letters.” Khalil, 28 N.E.3d at 19. And it covers “all pertinent communications among the parties, counsel, witnesses and the court,” regardless “|w]|hether a statement was made in or out of court, was on or off the record, or was made orally or in writing.” Frechtman v. Gutterrnan, 979 N.Y.S. 2d 58 (App. Div. 2014) (quoting Sexter v. Warmflash, P.C. v. Margrabe, 828 N.Y.S. 2d 315 (App. Div. 2007)). When the pre-litigation privilege is invoked 1n connection with an allegedly defamatory statement made during pending or contemplated litigation, “any doubts are to be resolved in favor of pertinence.” Flomenhaft, 8 N.Y.S.3d at 164. “[T]he test to determine whether a statement is pertinent to litigation is “““extremely liberal,’”’’ such that the offending statement, to be actionable, must have been ‘outrageously out of context.’” Id. at 164-65 (emphasis supplied; quoting Black v. Green Harbour Homeowners’ Ass’n, 798 N.Y .S.2d 753 (App. Div. 2005), and Martirano v. Frost, 255 N.E.2d 693 (1969)); Kirk, 532 F. Supp. 2d at 593. In denying Ms. Maxwell’s motion to dismiss the Complaint based on the pre-litigation privilege, this Court limited its analysis of the privilege to whether under the Rule 12(b)(6) standard plaintiff had sufficiently pleaded that the January 2 and 4 statements were made with actual malice. Doc.37 at 18-19. The Court’s Rule 12(b)(6) analysis does not bear on the question presented here, for two reasons. 9928 Under the “substantive law’ actual malice is not relevant to the pre-litigation defense. The New York Court of Appeals in Khalil held that to prevail on the pre-litigation privilege the defendant need only establish one element: the allegedly defamatory statement at issue was *8 Anderson, 477 U.S. at 248. 34

Case 18-2868, Document 276, 08/09/2019, 2628224, Page42 of 77 “pertinent to a good faith anticipated litigation.” 28 N.E.3d at 16. Upon establishing that element, summary judgment for the defendant 1s required. See id. Additionally, this 1s a summary judgment proceeding. Plaintiff cannot rely on the allegations of her Complaint. Evidence is required. The following evidence is not in dispute. By January 2015 Ms. Maxwell had retained British Solicitor Philip Barden to represent and advise her in connection with plaintiff s publication in the British press of salacious, defamatory allegations of criminal sexual abuse during the period 1999-2002. EXHIBIT K 4 8-10. Mr. Barden in turn engaged UK press agent Ross Gow. Id. § 9. Mr. Barden prepared the January 2015 statement and instructed Mr. Gow to transmit it via email to members of the UK media who had made inquiry about the allegations in the joinder motion. Jd. § 10. Mr. Barden did not intend the January 2015 statement as a traditional press release solely to disseminate information to the media. Jd. 9 15. This is why he intentionally did not request that Mr. Gow or any other public relations specialist prepare the statement. Jd. Instead, Mr. Gow served as his conduit to the media representatives who had requested a response to the joinder motion allegations and who Mr. Barden believed might republish those allegations. /d. Mr. Barden had two purposes in preparing and causing the statement to be disseminated to those media representatives. First, he wanted to mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff's false allegations. /d. § 16. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject plaintiff's allegations to inquiry and scrutiny. /d. For example, he noted in the January 2015 statement that plaintiff's allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” Jd. 35

Case 18-2868, Document 276, 08/09/2019, 2628224, Page43 of 77 Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish plaintiff's allegations without conducting any inquiry of their own. Jd. § 17. This was the purpose of repeatedly stating that plaintiff's allegations were “defamatory.” Jd. The statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct. Id. At the time Mr. Barden directed the issuance of the statement, he was contemplating litigation against the media-recipients as an additional means to mitigate and prevent harm to Ms. Maxwell. /d. 9 28. Toward this end, he prepared the statement so that it made clear Ms. Maxwell “strongly denie[d] the allegations of an unsavoury nature,” declared the republications of the allegations to be false, gave the press-recipients notice that the republications of the allegations “are defamatory,” and informed them that Ms. Maxwell was “reserv[ing| her right to seek redress.” Jd. § 30. In any such UK defamation, or other related, action Ms. Giuffre would be a defendant or a witness. Jd. 4 29. The question presented 1s whether Mr. Barden’s statement, which he directed to be sent to various media representatives, is “pertinent to a good faith anticipated litigation,” Khalil, 28 N.E.3d at 16. The requirement of “good faith” anticipated litigation is intended to prevent attorneys (or their agents) from “bully[ing], harass[ing], or intimidat|ing] their client’s adversaries by threatening baseless litigation or by asserting unmeritorious claims, unsupported in law and fact, in violation of counsel’s ethical obligations,” id. at 19. The statement Mr. Barden prepared and caused to be issued was not intended to bully, harass or intimidate the press-recipients, 1.e., the 36

Case 18-2868, Document 276, 08/09/2019, 2628224, Page44 of 77 potential defendants in an action by Ms. Maxwell for defamation. See EXHIBIT K § 26-30. Nothing about the statement on its face suggested bullying, harassing or intimidating the pressrecipients (or anyone else). At the time Mr. Barden directed the issuance of the statement, he had sufficient factual and legal grounds to pursue in good faith a defamation action against one or more of the press-recipients for republishing plaintiff's allegations. See generally id. JJ 8-30. That the statement was directed at the press-recipients—which had republished plaintiff s false allegations and was not directed at plaintiff—is irrelevant to the absolute privilege protecting pre-litigation communications. In International Publishing Concepts, LLC v. Locatelli, letters and emails detailing likely litigation and an intent to sue were extended the same pre-litigation privilege although sent to two non-parties who were only potentially affected by the litigation or witnesses to it. See also Kirk, 532 F. Supp. 2d at 593 (“The privilege is broad, and embraces anything that may possibly or plausibly be relevant to the litigation.”) (internal quotations omitted). The only issue remaining 1s whether the statement was pertinent to the contemplated litigation. Applying the “extremely liberal” test of pertinence, in which “any doubts are to be °° the court must decide whether the allegedly defamatory resolved in favor of pertinence, statement is “outrageously out of context” in relation to the contemplated litigation. Flomenhaft, 8 N.Y.S.3d at 164-65 (internal quotations omitted). Nothing in the statement is “outrageously out of context.” Every statement was directly related to the press-recipients’ republication of plaintiffs false allegations against Ms. Maxwell. The January 4 statement also 1s absolutely privileged. According to plaintiff, Ms. Maxwell told a reporter on that date when asked to comment on plaintiffs joinder-motion oe lomenhaft, 8 N.Y.S.3d at 164 (internal quotations omitted). 37

Case 18-2868, Document 276, 08/09/2019, 2628224, Page45 of 77 allegations: “I am referring to the statement that was made.” Doc.1 § 32. Assuming arguendo the statement is defamatory,” it is absolutely privileged since it simply refers to an absolutely privileged statement. See, e.g., Klein, 29 A.D.2d at 420 (privilege protects communications “between litigating parties”); Frechtman, 979 N.Y.S.2d at 63 (privilege protects communications “made in or out of court, ... on or off the record, ... orally or in writing’’) (internal quotations omitted). Under these circumstances the pre-litigation privilege is absolute and “no cause of action for defamation can be based on those statements,” Khalil, 28 N.E.3d at 16. The Court should enter summary judgment on plaintiff's defamation claim. IV. Ms. Maxwell’s January 4, 2015, statement is nonactionable. Plaintiff alleges that on January 4, 2015, a reporter approached Ms. Maxwell on a public street in Manhattan and “asked Maxwell about Giuffre’s allegations against Maxwell.” Doc. 1 437. Plaintiff alleges that Ms. Maxwell responded with a single sentence: “‘I am referring to the statement that we made.’” /d. According to plaintiff, Ms. Maxwell’s statement was defamatory. See id. 437 & Count I 4 5, at 8. Judgment should enter against plaintiff as to Ms. Maxwell’s Statement. Adelson controls this portion of plaintiff's defamation claim. In Adelson a non-profit organization during the 2012 presidential campaign published a statement on its website critical of Sheldon Adelson, a wealthy Republican donor. The statement alleged Adelson had donated “tainted” and “dirty” money to Governor Romney. Eight days later the organization withdrew the statement from its website. On the same day it issued a press release explaining that although *°As discussed in Argument IV, the January 4 statement is nonactionable. 38

Case 18-2868, Document 276, 08/09/2019, 2628224, Page46 of 77 it took down the statement, “we stand by everything we said, which was sourced from current, credible news accounts.” 973 F. Supp. 2d at 474. Adelson sued. He alleged that the statement was defamatory and that the press release constituted a republication of the defamatory statement. This court held that the statement contained only constitutionally protected opinion and was nonactionable. The court then rejected the defamation claim based on republication: “‘[A] mere reference to another writing that contains defamatory matter does not constitute an actionable repetition or republication.” /d. (quoting Goforth v. Avemco Life Ins. Co., 368 F.2d 25, 28 n.7 (4th Cir.1966)). This is the settled tule. See In re Philadelphia Newspapers, LLC, 690 F.3d 161, 175 (3d Cir. 2012), as corrected (Oct. 25, 2012) (“under traditional principles of republication, a mere reference to an article, regardless how favorable it 1s as long as it does not restate the defamatory material, does not republish the material’); Salyer v. S. Poverty Law Ctr., Inc., 701 F. Supp. 2d 912, 916 (W.D. Ky. 2009) (“[T]he common thread of traditional republication is that it presents the material, in its entirety, before a new audience. A mere reference to a previously published article does not do that.’’). Ms. Maxwell’s one-sentence response that merely referenced an earlier statement 1s nonactionable. This Court should enter partial summary judgment on the defamation claim to the extent it is based on Ms. Maxwell’s response. V. The defamation claim should be dismissed because the publication is substantially true. “TA ] statement is substantially true if the statement would not “have a different effect on the mind of the reader from that which the pleaded truth would have produced.” Franklin v. Daily Holdings, Inc., 21 N.Y .S.3d 6, 12 (App. Div. 2015) (quoting Biro v. Condé Nast, 883 F. Supp. 2d 441, 458 (S.D.N.Y. 2012) (quoting Jewell v. NYP Holdings, Inc., 23 F. Supp. 2d 348, a7

Case 18-2868, Document 276, 08/09/2019, 2628224, Page47 of 77 366 (S.D.N.Y.1998) (quoting Fleckenstein v. Friedman, 193 N.E. 537, 538 (1934)))). Indeed, it is well settled in New York “that an alleged libel is not actionable if the published statement could have produced no worse an effect on the mind of a reader than the truth pertinent to the allegation.” /d. (internal quotations omitted). “When the truth is so near to the facts as published that fine and shaded distinctions must be drawn and words pressed out of their ordinary usage to sustain a charge of libel, no legal harm has been done.” Fleckenstein, 193 N.E. at 538. For the reasons articulated in Argument VI, the January 2015 statement 1s substantially true as matter of law. VI. Plaintiff cannot establish actual malice by clear and convincing evidence. A. Facts. The following numbered facts are not in dispute and are sequentially numbered following the undisputed facts cited earlier. See This Motion at F§ 1-36. 37. Plaintiff lived independently from her parents with her fiancé long before meeting Epstein or Ms. Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999, plaintiff moved in with the family of a fellow patient. EXHIBIT L at 7-8, 12-14. There she met, and became engaged to, her friend’s brother, James Michael Austrich. Jd. & at 19. She and Austrich thereafter rented an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs in that area. /d. at 11, 13-17. Later, they stayed briefly with plaintiff's parents in the Palm Beach/Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. Jd. at 17, 19, 25-27; EXHIBIT M. Although plaintiff agreed to marry Austrich, she never had any intention of doing so. EXHIBIT N at 127-128. 38. Plaintiff re-enrolled in high school from June 21, 2000 until March 7, 2002. After finishing the 9"" grade school year at Forest Hills High School on June 9, 1999, plaintiff re40

Case 18-2868, Document 276, 08/09/2019, 2628224, Page48 of 77 enrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on August 14, 2001. EXHIBIT O. On September 20, 2001, Plaintiff then enrolled at Royal Palm Beach High School. /d. A few weeks later, on October 12, 2001, she matriculated at Survivors Charter School. /d. Survivor’s Charter School was an alternative school designed to assist students who had been unsuccessful at more traditional schools. EXHIBIT P at 23-24. Plaintiff remained enrolled at Survivor’s Charter School until March 7, 2002. EXHIBIT O. She was present 56 days and absent 13 days during her time there. /d. Plaintiff never received her high school diploma or GED. EXHIBIT Q at 475, 483. Plaintiff and Figueroa went “back to school” together at Survivor’s Charter School. EXHIBIT P at 23-27. The school day there lasted from morning until early afternoon. /d. at 23-27, 144-46. 39. During the year 2000, plaintiff worked at numerous jobs. In 2000, while living with her fiancé, plaintiff held five different jobs: at Aviculture Breeding and Research Center, Southeast Employee Management Company, The Club at Mar-a-Lago, Oasis Outsourcing, and Neiman Marcus. EXHIBIT R. Her taxable earnings that year totaled nearly $9,000. /d. Plaintiff cannot now recall either the Southeast Employee Management Company or the Oasis Outsourcing jobs. EXHIBIT Q at 470-471. 40. Plaintiff's employment at the Mar-a-Lago spa began in fall 2000. Plaintiff’s father, Sky Roberts, was hired as a maintenance worker at the The Mar-a-Lago Club in Palm Beach, Florida, beginning on April 11, 2000. EXHIBIT S. Mr. Roberts worked there year-round for approximately 3 years. /d.; EXHIBIT T at 72-73. After working there for a period of time, Mr. Roberts became acquainted with the head of the spa area and recommended plaintiff for a job there. Id. at 72. Mar-a-Lago closes every Mother’s Day and reopens on November |. EXHIBIT U at Mar-a-Lago0212. Most of employees Mar-a-Lago, including all employees of the spa area 41

Case 18-2868, Document 276, 08/09/2019, 2628224, Page49 of 77 such as “spa attendants,” are “seasonal” and work only when the club 1s open, 1.e., between November | and Mother’s Day. EXHIBIT T at 72-73; EXHIBIT U at MAR-A-LAGO 0212; EXHIBIT V. Plaintiff was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17. 41. Plaintiff represented herself as a masseuse for Jeffrey Epstein. While working at the Mar-a-Lago spa and reading a library book about massage, plaintiff met Ms. Maxwell. Plaintiff thereafter told her father that she got a job working for Jeffrey Epstein as a masseuse. EXHIBIT T at 79. Plaintiff's father took her to Epstein’s house on one occasion around that time, and Epstein came outside and introduced himself to Mr. Roberts. /d. at 82-83. Plaintiff commenced employment as a traveling masseuse for Mr. Epstein. Plaintiff was excited about her job as a masseuse, about traveling with him and about meeting famous people. EXHIBIT L at 56; EXHIBIT P at 126. Plaintiff represented that she was employed as a masseuse beginning in January 2001. EXHIBIT M; EXHIBIT N. Plaintiff never mentioned Ms. Maxwell to her thenfiancé, Austrich. EXHIBIT L at 74. Plaintiff’s father never met Ms. Maxwell. EXHIBIT T at 85. 42. Plaintiff resumed her relationship with convicted felon Anthony Figueroa. In spring 2001, while living with Austich, plaintiff lied to and cheated on him with her high school boyfriend, Anthony Figueroa. EXHIBIT L at 68, 72. Plaintiff and Austrich thereafter broke up, and Figueroa moved into the Bent Oak apartment with plaintiff. EXHIBIT L at 20; EXHIBIT P at 28. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa in Plaintiff's presence punched Austrich in the face. EXHIBIT X; EXHIBIT L at 38-45. Figueroa and plaintiff fled the scene before police arrived. EXHIBIT X. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance. EXHIBIT Y. 42

Case 18-2868, Document 276, 08/09/2019, 2628224, Page5O of 77 43. Plaintiff freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at age 17, while living in the same apartment, plaintiff and Figueroa hosted a party with a number of guests. EXHIBIT Z. During the party, according to plaintiff, someone entered plaintiff's room and stole $500 from her shirt pocket. /d. Plaintiff contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a “sex slave.” A second time, in June 2002, plaintiff contacted the police to report that her former landlord had left her belongings by the roadside and had lit her mattress on fire. EXHIBIT AA. Again, plaintiff met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a “sex slave.” Jd. 44. From August 2001 until September 2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel unaccompanied by Plaintiff. Flight logs maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips away from Florida that Epstein and Maxwell took, unaccompanied by Plaintiff, between August 2001 and September 2002. EXHIBIT BB. Rodgers maintained a log of all flights on which Epstein and Maxwell traveled with him. EXHIBIT CC at 6-15. Epstein additionally traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial flights. /d. at 99-100, 103. For substantially all of thirteen months of the twenty-two months (from November 2000 until September 2002) that Plaintiff lived in Palm Beach and knew Epstein, Epstein was traveling outside of Florida unaccompanied by Plaintiff. EXHIBIT BB. During this same period of time, Plaintiff was employed at various jobs, enrolled in school, and living with her boyfriend. 43

Case 18-2868, Document 276, 08/09/2019, 2628224, Page51 of 77 45. Plaintiff and Figueroa shared a vehicle during 2001 and 2002. Plaintiff and Figueroa shared a ’93 white Pontiac in 2001 and 2002. EXHIBIT P at 67; EXHIBIT EE. Plaintiff freely traveled around the Palm Beach area in that vehicle. /d. In August 2002, Plaintiff acquired a Dodge Dakota pickup truck from her father. EXHIBIT P at 67-68. Figueroa used that vehicle in a series of crimes before and after Plaintiff left for Thailand. /d.; EXHIBIT FF. 46. Plaintiff held a number of jobs in 2001 and 2002. During 2001 and 2002, plaintiff was gainfully employed at several jobs. She worked as a waitress at Mannino’s Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at Roadhouse Grill. EXHIBIT R. She also was employed at Courtyard Animal Hospital (aka Marc Pinkwasser DVM). /d.; EXHIBIT W. 47. In September 2002, Plaintiff traveled to Thailand to receive massage training and while there, met her future husband and eloped with him. Plaintiff traveled to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove her to the airport. While there, she initially contacted Figueroa frequently, incurring a phone bill of $4,000. EXHIBIT P at 35. She met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until two days before Mr. Figueroa’s deposition in this matter in May 2016. /d. at 29, 37. 48. Detective Recarey’s investigation of Epstein failed to uncover any evidence that Ms. Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. Joseph Recarey served as the lead detective from the Palm Beach Police Department charged with investigating Jeffrey Epstein. EXHIBIT GG at 10. That investigation commenced in 2005. /d. Recarey worked only on the Epstein case for an entire year. Id. at 274. He reviewed previous officers’ reports and interviews, conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance footage of the Epstein 44

Case 18-2868, Document 276, 08/09/2019, 2628224, Page52 of 77 home, participated in and had knowledge of the search warrant executed on the Epstein home, and testified regarding the case before the Florida state grand jury against Epstein. /d. at 212-15. Detective Recarey’s investigation revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect by the government. /d. at 10-11, 177, 180-82, 187-96, 241-42, 278. None of Epstein’s alleged victims said they had seen Ms. Maxwell at Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her, nor told what to wear or how to act by her. /d. Indeed, none of Epstein’s alleged victims ever reported to the government they had met or spoken to Ms. Maxwell. Jd. Maxwell was not seen coming or going from the house during the law enforcement surveillance of Epstein’s home. /d. at 214-215. The arrest warrant did not mention Ms. Maxwell and her name was never mentioned before the grand jury. /d. at 203, 211. No property belonging to Maxwell, including “sex toys” or “child pornography,” was seized from Epstein’s home during execution of the search warrant. Id. at 257. Detective Recarey, when asked to describe “everything that you believe you know about Ghislaine Maxwell’s sexual trafficking conduct,” replied, “I don’t.” /d. at 278. He confirmed he has no knowledge about Ms. Maxwell sexually trafficking anybody. Jd. at 278-79. Detective Recarey also has no knowledge of Plaintiff's conduct that is subject of this lawsuit. /d. at 259-60. 49. No nude photograph of Plaintiff was displayed in Epstein’s home. Epstein’s housekeeper, Juan Alessi, “never saw any photographs of Virginia Roberts in Mr. Epstein’s house.” EXHIBIT HH at 4 17. Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. EXHIBIT GG at 289-90. 45

Case 18-2868, Document 276, 08/09/2019, 2628224, Page5d3 of 77 50. Plaintiff intentionally destroyed her “journal” and “dream journal” regarding her “memories” of this case in 2013 while represented by counsel. Plaintiff drafted a “Journal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. EXHIBIT II at 64-65, 194; EXHIBIT N at 205-08. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents in her possession. /d. Plaintiff also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. EXHIBIT II at 194-96. To date, Plaintiff cannot locate the “dream journal.” Jd.*! 51. Plaintiff publicly peddled her story beginning in 2011. Plaintiff granted journalist Sharon Churcher extensive interviews that resulted in seven (7) widely distributed articles from March 2011 through January 2015. Churcher regularly communicated with plaintiff and her “attorneys or other agents” from “early 2011” to “the present day.” See Doc.216 4 2-11 and referenced exhibits; Doc.261-1 to 216-8, incorporated by reference. Plaintiff received approximately $160,000 for her stories and pictures that were published by many news organizations. EXHIBIT N at 247-48. 52. Plaintiff drafted a 144-page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, plaintiff drafted a book manuscript which purported to document plaintiff’ s experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. EXHIBIT KK. Plaintiff communicated with literary agents, ghost writers and potential independent publishers in an effort to get her book published. She generated marketing materials °' Defendant has moved for sanctions against plaintiff premised on her admitted destruction of this evidence. Doc.509-510. 46

Case 18-2868, Document 276, 08/09/2019, 2628224, Page54 of 77 and circulated those along with book chapters to numerous individuals associated with publishing and the media. 53. Plaintiff’s publicly filed “lurid” CVRA pleadings initiated a media frenzy and generated highly publicized litigation between her lawyers and Alan Dershowitz. On December 30, 2014, plaintiff, through counsel, publicly filed a joinder motion that contained her “lurid allegations” about Ms. Maxwell and many others, including Alan Dershowitz, Prince Andrew, Jean-Luc Brunel. The joinder motion was followed by a “corrected” motion (EXHIBIT D) and two further declarations in January and February 2015, which repeated many of plaintiff's clams. These CVRA pleadings generated a media maelstrom and spawned highly publicized litigation between plaintiff's lawyers, Edwards and Cassell, and Alan Dershowitz. After plaintiff publicly alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called plaintiff a liar and accused her lawyers of unethical conduct. In response, attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. See Doc.363 at 363-1 through 363-14. 54. Plaintiff formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, plaintiff, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to plaintiff, the purpose of the organization is to promote plaintiff's professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. EXHIBIT LL. Plaintiff attempts to promote Victims Refuse Silence at every opportunity. EXHIBIT MM at 17-18. For example, plaintiff participated 47

Case 18-2868, Document 276, 08/09/2019, 2628224, Page5d5 of 77 in an interview in New York with ABC to promote the charity and to get her mission out to the public. Jd. at 28. B. Plaintiff carries the burden of proving actual malice by clear and convincing evidence. In New York Times Co. v. Sullivan, 376 U.S. 254, 270 (1964), the Supreme Court recognized that our country has made a “profound national commitment to the principle that debate on public issues should be uninhibited, robust, and wide-open.” The overriding importance of that commitment led to the Court’s holding that “neither factual error nor defamatory content, nor a combination of the two, sufficed to remove the First Amendment shield,” Bartnicki v. Vopper, 532 U.S. 514, 535 (2001), from speech relating to public officials and public figures. See, e.g., Gertz v. Robert Welch, Inc., 418 U.S. 323, 345 (1974). Under the First Amendment of the Constitution and Article I, Section 8, of the New York Constitution, in defamation actions by public officials and public figures and in defamation actions concerning matters of public concern, the plaintiff must prove that the allegedly defamatory statement was made with “actual malice.” See, e.g., id.; Philadelphia Newspapers, Inc. v. Hepps, 475 U.S. 767, 776-77 (1986); Huggins v. Moore, 726 N.E.2d 456, 460 (N.Y. 1999); McGill v. Parker, 582 N.Y.S.2d 91, 97 (App. Div. 1992). As the Supreme Court has noted, the term “actual malice” can be confusing because in the First Amendment context “it has nothing to do with bad motive or ill will.” Harte-Hanks Communic’ns, Inc. v. Connaughton, 491 U.S. 657, 666 n.7 (1989). Instead proof of actual malice requires evidence that the publication contains a “material” false statement of fact that was made “with knowledge that the statement was false or with reckless disregard as to whether or ** 4ir Wisconsin Airlines Corp. v. Hoeper, 134 8S. Ct. 852, 861 (2014) (‘minor inaccuracies do not amount to falsity so long as ‘the substance, the gist, the sting, of the libelous charge be justified’’) (internal quotations and brackets omitted). 48

Case 18-2868, Document 276, 08/09/2019, 2628224, Page56 of 77 not it was true.” Jd. at 667 (internal quotations omitted). Reckless disregard means the defendant made the false publication “with a high degree of awareness of probable falsity” or “entertained serious doubts as to the truth of [the] publication.” /d. (internal quotations omitted). In a defamation action, a plaintiff will be required to prove actual malice in two different and independent contexts: a defamation action in which the plaintiff is a public figure, and a defamation action in which the defendant asserts the privilege of reply. The defamation plaintiff at trial and in summary judgment proceedings must prove her case by clear and convincing evidence. C. Plaintiff is a public figure who must prove actual malice. Public figures include those who have “thrust themselves to the forefront of particular public controversies in order to influence the resolution of the issues involved. .. . [T]hey invite attention and comment.” Gertz, 418 U.S. at 345. The essential element for a finding that a person is a public figure is that she has “taken an affirmative step to attract public attention,” has “strived to achieve a measure of public acclaim.” James v. Gannett Co., 353 N.E.2d 834, 876 (N.Y. 1976). In New York Times Co. v. Sullivan, 376 U.S. 254 (1964), the United States Supreme Court held that, in cases involving public officials, the interests of an individual are trumped by society's interest in promoting free press discussion of matters of general concern. Biro v. Condé Naste, 963 F. Supp. 2d 255, 269 (S.D.N.Y. 2013). Thus, the Court held that a public official alleging defamation must establish that a falsehood has been published with “actual malice.” Sullivan, 376 U.S. at 279-80; accord, Lerman v. Flynt Dist. Co., Inc., 745 F.3d 123, 136 (2d Cir. 1984); Biro, 963 F. Supp. 2d at 269. Subsequently, the Supreme Court extended this standard to all public figures, Curtis Publ'g Co. v. Butts, 388 U.S. 130 (1967), and decided in Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974), that individuals that “are not public figures for all purposes 49

Case 18-2868, Document 276, 08/09/2019, 2628224, Page57 of 77 may still be public figures with respect to a particular controversy.’ Contemporary Mission, Inc. v. N.Y. Times Co., 842 F.2d 612, 617 (2d Cir. 1988). As the Second Circuit has observed, the reason for distinguishing between private and public figures in defamation claims flows from the recognition of two things: First, “that private figure are more vulnerable to injury from defamation, because public figures have greater access to the media and thus are in a better position to contradict a lie or correct an error.” Contemporary Mission, Inc., 842 F.2d at 619-20. Second, “and more important, public figures generally ‘have voluntarily exposed themselves to increased risk of injury from defamatory falsehood concerning them.’” /d. at 620 (quoting N.Y. Times, 418 U.S. at 344-45) (emphasis added). In the Second Circuit, to establish that a plaintiff is a limited purpose public figure, a defendant must prove that she: 1. successfully invited public attention to [her] views in an effort to influence others prior to the incident that 1s the subject of litigation; 2. voluntarily injected [her]self into a public controversy related to the subject of the litigation; assumed a position of prominence in the public controversy; and 4. maintained regular and continuing access to the media. Lerman, 745 F.2d at 136-37; accord, Contemporary Mission, Inc., 842 F.2d at 617; Biro, 963 F. Supp. 2d at 270. Statements regarding a limited purpose public figure are subject to enhanced protection only if relevant to the public figure's involvement in a given controversy. Biro, 963 F. Supp.2d at 270-71 (citing Faigin v. Kelly, 978 F. Supp. 420, 426 (D. N.H. 1997)). “Yet, once a plaintiff 1s deemed a limited purpose public figure, courts allow the heightened protections to sweep broadly, covering all statements by defendants that are not ‘wholly unrelated to the controversy.’” Biro, 963 F. Supp. 2d at 271 (quoting Waldbaum v. Fairchild Publ'ns, Inc., 626 50

Case 18-2868, Document 276, 08/09/2019, 2628224, Page5ds of 77 F.2d 1287, 1298 (D.C. Cir. 1980)). The law requires only that “the statement need be no more than generally related to a dispute in issue to qualify for protection.” Robert D. Sack, Sack on Defamation: Libel, Slander, and Related Problems (“SACK ON DEFAMATION’) § 5:3.3 (4th ed. 2015). The question whether a plaintiff is a public figure 1s a question of law for the court to decide. Celle v. Filipino Reporter Enters. Inc., 209 F.3d 163, 176-77 (2d Cir. 2000); accord Biro, 963 F. Supp. 2d at 270. 1. Plaintiff successfully invited public attention to influence others. The record amply demonstrates that plaintiff invited public attention to herself and her views regarding the Plaintiff’s alleged desire to draw attention to the issue of her purported sex slavery. Beginning 1n at least 2011, the Plaintiff met with Sharon Churcher to promote her cause and economic interests. According to Ms. Churcher, the Plaintiff granted Ms. Churcher extensive interviews that resulted in 7 widely distributed articles from March 2011 through January 2015. According to Ms. Churcher, she regularly communicated with the Plaintiff and her “attorneys or other agents” from “early 2011” to “the present day.” See Doc.216 F§ 2-11 and referenced exhibits; Docs.261-1 to 216-8, incorporated by reference. Plaintiff was amply compensated for this “public attention” and received approximately $160,000 for her stories. and pictures that were published by many news organizations. EXHIBIT N at 247-248. Plaintiff had a contract with the news organizations, The Mail on Sunday. Plaintiff, 1n addition to selling this story to the media, again thrust herself into the public’s attention when she sought to join the ongoing CVRA litigation against Jeffrey Epstein in the United States District Court in Florida. The Plaintiff, through the same lawyers in this matter, publicly filed a joinder motion that was the equivalent of a press release. The unnecessary and 51

Case 18-2868, Document 276, 08/09/2019, 2628224, Page5d9 of 77 lurid allegations were ultimately stricken by the Court but accomplished the desired result for the Plaintiff, more public attention. The CVRA pleading created a media frenzy and spawned highly publicized litigation between Plaintiff's lawyers, Edwards and Cassell, and Alan Dershowitz. After the Plaintiff publicly alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called the Plaintiff a liar and accused her lawyers of unethical conduct. In response, the lawyers, Edwards and Cassell, sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. See Doc.363 at 363-1 thorough 363-14 and accompanying exhibits. In addition, plaintiff claims to have established a non-profit organization, Victims Refuse Silence, the purpose of which was to promote plaintiff's professed cause against sex slavery. In paragraphs 23 through 26 of her complaint in this matter she makes the following admissions on this issue: e Ultimately, as a mother and one of Epstein’s many victims, Giuffre believed that she should speak out about her sexual abuse experiences in hopes of helping others who had also suffered from sexual trafficking and abuse. Jd. 23 e On December 23, 2014, Giuffre incorporated an organization called Victims Refuse Silence, Inc., a Florida not-for-profit corporation. Id. 24 e Guuffre intended Victims Refuse Silence to change and improve the fight against sexual abuse and human trafficking. The goal of her organization was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Giuffre has now dedicated her professional life to helping victims of sex trafficking. Id. 25 e On December 30, 2014, Giuffre moved to join the on-going litigation previously filed by Jane Doe | in the Southern District of Florida challenging Epstein’s nonprosecution agreement by filing her own joinder motion. /d. 26 52

Case 18-2868, Document 276, 08/09/2019, 2628224, Page60 of 77 In sum, the record includes ample evidence of plaintiff's efforts to garner public attention in order to influence others and the success of those efforts. 2. Plaintiff voluntarily injected herself into public controversies related to the subject of this litigation. The second prong of the Lerman test requires an examination of whether plaintiff voluntarily injected herself into a public controversy related to the subject of the litigation. The Second Circuit has held that the term should be defined broadly to mean “any topic upon which sizeable segments of society have different, strongly held views.” Lerman, 745 F.2d at 138; see also Biro, 963 F. Supp. 2d at 272 (“A public controversy is simply ‘any topic upon which sizeable segments of society have different, strongly held views,’ even if the topic does ‘not involve political debate or criticism of public officials.’’’) (quoting Lerman, 745 F.2d at 138) (alteration omitted). The public controversy requirement, however, is not necessarily limited to what would be considered “a classic debate.”” SACK ON DEFAMATION § 5:3.11[B]. “An investigation into alleged corruption or drug dealing, for example, could meet the test.” Jd. As demonstrated by the Declaration of Ms. Churcher, the articles attached to the declaration, and the joinder motion filed by plaintiff in the CVRA litigation and the litigation initiated by her lawyers there can be no doubt that the plaintiff’s actions were voluntary and that she injected herself into this “public controversy.” Indeed, it is clear that plaintiff created this “public controversy.” 3. Plaintiff assumed a position of prominence in the public controversies. The third relevant factor focuses on whether plaintiff has voluntarily assumed a sufficient degree of prominence in the controversies at issue. Plaintiff sold and published her story. She publicly sought to join the CVRA litigation. She established a non-profit organization, the 3

Case 18-2868, Document 276, 08/09/2019, 2628224, Page61 of 77 mission of which is purportedly to “spread the word for victims of human trafficking”. EXHIBIT MM at 17; see also EXHIBIT LL. According to Brittany Henderson, the Rule 30(b)(6) designee of VRS, plaintiff has “continued to try to promote Victims Refuse Silence at every possible chance she gets ...” EXHIBIT MM at 17-18. Plaintiff participated in an interview in New York with ABC in “the beginning of 2015,” id. at 27, so that she could “promote the charity, so that she could start getting her mission out to the public.” /d. at 28. Having affirmatively injected herself into the public spotlight in connection with these issues, plaintiff cannot now be heard to argue that this Lerman factor has not been satisfied. Cf, Contemporary Mission, 842 F.2d at 618-19 (finding the plaintiffs' assertion that they have assumed a private life was “belied by the fact that they continued to thrust themselves into the public eye” through their conduct on behalf of a non-forprofit organization). 4. Plaintiff has maintained regular and continuing access to the media. Plaintiff has had substantial access to the media. Ms. Churcher has answered every call or email sent by plaintiff. Plaintiff's lawyers have regularly communicated with the media. Plaintiff and her lawyers have been interviewed by numerous major media organizations. Accordingly, the First Amendment requires that public figures like plaintiff claiming defamation must establish actual malice—actual and material falsity or a high degree of awareness of probable falsity—by clear and convincing evidence. E.g., Masson v. New Yorker Magazine, Inc., 501 U.S. 496, 510 (1991). D. Plaintiff must also prove actual malice to overcome the defenses of reply and pre-litigation privilege. The qualified privilege of reply to a defamatory attack 1s a complete defense to a claim of defamation. Shenkman v. O’Malley, 157 N.Y.S.2d 290, 294, 297 (App. Div. 1956). The defense 54

Case 18-2868, Document 276, 08/09/2019, 2628224, Page62 of 77 is available to a person “who has been defamed in the first instance,” here, Ms. Maxwell, and “who, in response to the attack, responds in kind.” /d. The privilege of the initially-attacked person (Ms. Maxwell) includes in rebuttal of the initial attack the right to speak the truth, but the right to rebut is not confined to the truth or to mere denial: This defense of reply is material, of course, only where the response 1n kind is defamatory. The injury, if any, to plaintiff 1s excused, because it is the plaintiff who started the altercation. ... It is a contradiction in terms to say that the one attacked is a privileged only to speak the truth, and not to make a counter attack, or that legitimate self-defense consists only in a denial of the charge or a statement of what is claimed to be the truth respecting its subject-matter. Id. (emphasis supplied; quoting Collier v. Postum Cereal Co., 134 N.Y.S. 847, 853 (1" Dep’t 1912)); see generally Restatement of the Law of Torts (Second) § 594 cmt. k (1977) (noting that to protect her reputation from attack by another person, she is conditionally privileged to publish defamatory matter about her attacker reasonably believed necessary to defend her reputation, “including the statement that [her] accuser 1s an unmitigated liar’). A defendant asserting the defense of reply need only establish she has been attacked with a defamatory statement. See id. at 297. Beginning no later than 2009 plaintiff attacked Ms. Maxwell with defamatory statements. In 2014, plaintiff knew the press was giving extensive coverage to, and scrutinizing all filings in, the Crime Victim’s Rights Act case pending in the United States District Court for the Southern District of Florida and in plaintiff's 2009 civil action against Mr. Epstein. Knowing this, plaintiff repeatedly filed papers in court alleging that Ms. Maxwell participated as a “recruiter” in a “sex trafficking” scheme operated by Mr. Epstein. E.g., Exhibit D. In 2011, plaintiff granted “exclusive” interviews to the British tabloid press during which she repeated her false allegations against Ms. Maxwell and also alleged that as part of the “sex trafficking” scheme she had sex with numerous prominent public figures, including 5

Case 18-2868, Document 276, 08/09/2019, 2628224, Page63 of 77 Prince Andrew and Harvard law professor Alan Dershowitz. EXHIBIT A. The false allegations against Ms. Maxwell constituted defamation per se. A plaintiff may defeat a qualified privilege only by proving actual malice. See, e.g., Kane v. Orange Cnty. Publ’ns, 649 N.Y.S.2d 23, 26 (App. Div. 1996) (qualified privilege of reply); see generally Gertz, 418 U.S. at 323; Restatement (Second) of Torts, supra, § 594 cmt. b. E. The January 2015 statement was substantially true, and plaintiff cannot produce clear and convincing evidence of its falsity. The January 2015 statement accurately and properly denies the factual assertions regarding Ms. Maxwell contained within plaintiff's joinder motion that had been issued two days prior to which it responded. With respect to each claim in the joinder motion that concerns Ms. Maxwell, the evidence elicited through discovery undercuts any evidence — clear and convincing or otherwise — that plaintiff may proffer to buttress her false allegations. 1. The January 2015 statement accurately denied that Ms. Maxwell met Plaintiff when Plaintiff was 15 years old in 1999, Plaintiff's relative youth at the time of her initial contact with Epstein and Maxwell forms the core of Plaintiff's story, in her joinder motion and in the press, that she was an underage victim of sexual slavery. Plaintiff has made a point of mentioning her age of 15, in the year 1999, as the starting point for her “four years” of “sex slavery” at every opportunity. The young age no doubt heightens the offensiveness of the claimed abusive conduct and also supplies enough time to allow for the “thousands” of times she was purportedly abused and the numerous opportunities for her to be trafficked to countless famous individuals. Reiterating this point in the joinder motion, plaintiff asserted again that she met Ms. Maxwell in the year 1999 when she was a mere 15 years old. EXHIBIT D at 3. As she now admits and her employment records confirm, plaintiff did not actually meet Ms. Maxwell or Epstein until the year 2000. Plaintiff acknowledges that she did not meet Ms. 50

Case 18-2868, Document 276, 08/09/2019, 2628224, Page64 of 77 Maxwell until she worked at the Mar-A-Lago as a spa attendant, and she confirms that she obtained that job with the assistance of her father who already was employed as a maintenance worker at the club. Records subpoenaed from Mar-A-Lago reflect that plaintiff's father commenced employment on April 11, 2000. EXHIBIT S. Additionally, they show that plaintiff terminated in the year 2000. /d. Finally, plaintiff's social security report confirms plaintiff’ s Mar-a-lago employment was confined to calendar year 2000. EXHIBIT R. Faced with overwhelming proof that her claims of meeting Ms. Maxwell at the age of 15 1n the year 1999 were false, plaintiff finally conceded as much at her deposition on May 3, 2016. EXHIBIT N at 2528. She also confessed that she did not spend her “sweet 16'"” birthday with Ms. Maxwell, as detailed in her book manuscript and in the press. Compare EXHIBIT N at 101-02 with EXHIBIT KK at Giuffre04173 (“I spent my sweet 16" birthday on his island in the Caribbean next to ‘St. James Isle’ he liked to call it ‘Little St. Jeff's’, his ego was as enormous as his appetite for fornicating. I was given a birthday cake and a new collection of designer make-up from London. Ghislaine made a joke after I blew out my array of candles and said, ‘I’d be soon getting too old 999 for Jeffrey’s taste, and soon they’d have to trade me in.’”’); Paul Lewis, “Jeffrey Epstein: Inside the Decade of Scandal Entangling Prince Andrew,” The Guardian (Jan. 10, 2015)”. Yet, even after conceding she was off by a year, plaintiff persists in suggesting that she must have been a mere “16 year old” when she worked at Mar-a-Lago and met Ms. Maxwell. It was, She testified, a “summer job” for which she had taken a break from school, and she did not turn 17 until later that summer on August 9, 2000. EXHIBIT N at 25-28, 57,104, 113. But the Mar-a-Lago documents conclusively disprove this claim: the spa where plaintiff worked closes every year from Mother’s Day until November |. EXHIBIT U at Mar-a-Lago0212 (“The club °3 https://www.theguardian.com/world/2015/jan/10/jeffrey-epstein-decade-scandalprince-andrew (last visited Jan. 6, 2017). 57

Case 18-2868, Document 276, 08/09/2019, 2628224, Page65 of 77 never shuts down from November | to Mother’s Day.”’). Spa attendants such as plaintiff are “seasonal” employees. /d. Indeed, the spa advertises for its new employees in local newspapers in the fall of every year. EXHIBIT V. Even plaintiff's father — a long time employee of Mar-aLago -- described the seasonal nature of the club during his deposition: “Plaintiffs employment] was probably for a season because Mar-a-Lago 1s seasonal. I mean, I was there year round but a lot of people are seasonal, you know, because it’s like snowbirds, you know, summertime comes and nobody wants to be down in south Florida....[The season is] probably from September or October to, you know, maybe May, I guess.” EXHIBIT T at 72. With the spa closed from Mother’s Day to November 1, plaintiff could not have had a “summer job” and could not have worked at Mar-a-Lago until November 2000, at the earliest, when she was over 17 years old. In sum, Plaintiff’s claim in the Joinder Motion that she met Ghislaine Maxwell in 1999 when she was 15 years old is a false statement. Therefore, the January 2015 statement calls the allegations against her “untrue” was factually accurate. 2. The January 2015 statement accurately denied that Ms. Maxwell “regularly participate|d] in Epstein’s sexual exploitation of minors” and that “the Government knows” such fact. The January 2015 statement also accurately denied plaintiff’s joinder motion allegation that “it became known to the government that Maxwell herself regularly participated in Epstein’s sexual exploitation of minors, including Jane Doe #3.” EXHIBIT D at 3. Ms. Maxwell did not “regularly participate in in Epstein’s sexual exploitation of minors” as confirmed by the lead Palm Beach Detective, Joseph Recarey. Det. Recarey confirmed that none of the alleged Epstein victims ever mentioned Ms. Maxwell’s name, either in reports he reviewed or in interviews he conducted. None of the alleged victims said they had been “recruited,” paid or exploited by Ms. Maxwell. EXHIBIT GG at 10-11, 177, 180-82, 187-96, 241-42, 278. He verified that the twenty58

Case 18-2868, Document 276, 08/09/2019, 2628224, Page66 of 77 two page Palm Beach Police Department affidavit does not mention Ms. Maxwell’s name once (id. at 177), and she was never considered a suspect and she was never mentioned 1n the grand jury testimony. Jd. at 203. Ms. Maxwell was not seen coming or going from the house during any of the Palm Beach Police Department’s surveillance of Epstein’s home. /d. at 214-15. None of her property was seized from Epstein’s home. /d. at 257. In sum, Det. Recarey denied that knowing anything “about Ghislaine Maxwell’s sexual trafficking conduct.” /d. at 278. He confirmed he has no knowledge that Ms. Maxwell sexually trafficking “anybody.” Id. at 278-79. Likewise, he has no knowledge of Plaintiff's conduct that is subject of this lawsuit. Jd. at 259-60. Plaintiff thus has uncovered no evidence that the “government” came to “know” that Maxwell participated in sexual exploitation of Jane Doe #3, 1.e., Plaintiff. Plaintiff has not and cannot present clear and convincing evidence to demonstrate the falsity of Ms. Maxwell’s denial. 3. The January 2015 statement accurately denied that “with [Ms. Maxwell’s| assistance, [Epstein] converted [Plaintiff] into what is commonly referred to as a ‘sex slave.’” Plaintiff claimed in the joinder motion that Ms. Maxwell helped Epstein transform her into a “sex slave” as that term is “commonly” used, yet the incontrovertible evidence establishes the opposite. A “slave” as defined by Merriam-Webster 1s a “person held in servitude as the chattel of another.” Oxford Dictionary defines “slave” as a “person who 1s the legal property of another and is forced to obey them.” Common definitions of “‘sex slave” include a person who 1s confined and is raped, sexually abused or prostituted. See “Sex Slave,” Free Dictionary, located at http://www.thefreedictionary.com/sex+slave (last visited Jan. 5, 2017) (underlining supplied). Plaintiff, however, was far from confined or the legal property of another. Throughout 2000, 2001 and 2002, Plaintiff enjoyed complete freedom of movement and choice. She had a car and then a pickup truck she shared with Figueroa. EXHIBIT P at 67.. She traveled freely to and from multiple jobs working as a waitress, bird aviaries, veterinarian 7

Case 18-2868, Document 276, 08/09/2019, 2628224, Page67 of 77 hospital, Nerman Marcus, Oasis Outsourcing and Southeast Employee Management Company. EXHIBIT R. Plaintiff enrolled in school in June 2000 before she met Maxwell or Epstein and continued her enrollment throughout 2000, 2001 and until March 2002. EXHIBIT O. She worked at multiple restaurants and the animal hospital in 2002. EXHIBIT R. She came and went from her apartment, moved to a new apartment and then moved in with Figueroa’s family. She held parties at her apartment with Figueroa and other friends. EXHIBIT Z. When something did not go well, she called the police and filed police reports, without mentioning anything about captivity, confinement or forced sexual exploitation or trafficking, much less “sex slavery.” /d. and EXHIBIT AA. She had her own money, paid her rent, and bought a vehicle. To Figueroa, she seemed “excited” about meeting famous people and discussed it so much that he tuned it out. EXHIBIT P at 125-26. By any commonly understood definition of sex slavery, Plaintiff did not match the description. Witness testimony and documentary evidence demonstrate the absence of substantial truth to Plaintiffs claim that Maxwell assisted Epstein in converting her into what is commonly referred to as a “sex slave.” The January 2015 statement’s denial of that claim cannot therefore be defamatory. 4. The January 2015 statement accurately reported that Plaintiff alleged “sexual relations” with Professor Dershowitz which he denied. The January 2015 statement accurately reports that “now it is alleged that Alan Derschowitz [sic] is involved in having sexual relations with [Plaintiff], which he denies.” The joinder motion made such a claim and Professor Dershowitz publicly and vehemently denied any such sexual contact. See, e.g., Dershowitz Denies Sex Charge, JTA (Jan. 2, 2015) (“Dershowitz 60

Case 18-2868, Document 276, 08/09/2019, 2628224, Page68 of 77 declared ‘totally, unequivocally and completely false’ allegations that he had sex with the former staffer for investor Jeffrey Epstein.”).”* Professor Dershowitz has gone beyond a simple denial: he has sworn, repeatedly and in almost every conceivable forum, including the New York Times, the Wall Street Journal, and Good Morning America, that he never had any sexual contact with Plaintiff and never met her. As he set forth in this case in his Declaration in Support of Motion to Intervene, Plaintiff never mentioned his name during her weeklong 2011 interview with journalist Sharon Churcher. Doc.363. It was only after Churcher suggested to Plaintiff that she “must have” met Dershowitz because “we all know he’s a pedo, though we have no proof of that” that Plaintiff then included Dershowitz in her book manuscript, not as a perpetrator of hers, but as someone she had “met” while with Epstein. Jd. The CVRA joinder motion more than three years later was the first time plaintiff publicized her remarkable claim that she had been sexually trafficked to Dershowitz on 99 66 “numerous occasions” “while she was a minor,” in Florida, private planes, in New York, New Mexico, and the U.S. Virgin Islands. EXHIBIT D. Dershowitz, 1n his own subsequent defamation action against plaintiff's attorneys Edwards and Cassell, produced approximately 10,000 pages of documents capturing his travels during the 1999-2002 timeframe, none of which coincided with Plaintiff's story. For example, Dershowitz demonstrated that the only time he visited Epstein’s home in the U.S. Virgin Islands he was accompanied by his wife and his 12 year old daughter. Plaintiff, on the other hand, produced no records demonstrating that any portion of her allegation against him 1s true. For example, she claimed one sexual encounter occurred on a private plane on which she traveled **http://www.jta.org/2015/01/02/news-opinion/united-states/dershowitz-denies-lawsuitssex-charges?utm_source=twitterfeed&utm_ medium=twitter&utm_ campaign=jtafeed (last visited Jat. 5; 2017). 61

Case 18-2868, Document 276, 08/09/2019, 2628224, Page69 of 77 with Professor Dershowitz. EXHIBIT II at 85. None of the flight logs reveal a flight with the two of them as passengers. EXHIBIT BB. Another time, plaintiff claims, she and Epstein flew together to Boston and she engaged in sexual relations with Professor Dershowitz in the backseat of a limousine between the airport and his home with another female and Epstein next to them. EXHIBIT IJ at 110-15. No flight logs document any trip with Epstein and plaintiff to Boston and plaintiff cannot recall the other female in the car. EXHIBIT II at 113. Professor Dershowitz has signed affidavits, provided sworn deposition testimony and sworn pleadings, offered to take a lie detector test, offered to waive the statute of limitations as to himself, and given countless broadcast and news interviews disclaiming any sexual contact with Plaintiff and calling her an outright “liar.”’? The January 2015 statement recounting the allegation against him and his denial 1s substantially true. 5. The January 2015 statement accurately denied that Ms. Maxwell created and distributed child pornography and that the Government knows of and possesses such child pornography. Plaintiff's next assertion regarding Maxwell in the joinder motion was that “Maxwell also took numerous sexually explicit pictures of underage girls involved in sexual activities, including Jane Doe #3,” and that Maxwell “shared these photographs (which constituted child pornography under applicable federal laws) with Epstein.” EXHIBIT D at 4-5. Plaintiff continued: the “Government is apparently aware of, and in certain instances possesses some of these photographs.” Jd. Yet again, the evidence demonstrates the falsity of Plaintiffs claim. Detective Recarey testified that none of Epstein’s alleged victims even mentioned Ms. Maxwell, much less claimed that she had taken naked photographs of them. EXHIBIT GG at 18082, 187-96, 241-42, 278. Recarey also denied that any evidence belonging to Ms. Maxwell was *>Perhaps most telling, Plaintiff and her phalanx of attorneys have never sued Mr. Dershowitz for his many vociferous attacks on her credibility. 62

Case 18-2868, Document 276, 08/09/2019, 2628224, Page/7O of 77 seized from Epstein’s home during the execution of the search warrant, which would include any “child pornography” reportedly created by her. /d. at 257. Detective Recarey who had entered Epstein’s home in 2002 to install security cameras to catch a thief did not observe any “child pornography” within the home, including on Epstein’s desk where Plaintiff alleges he kept such a nude photograph of herself. /d. at 289-90. And Epstein’s housekeeper, Juan Alessi, swore that he “never saw any photographs of Virginia Roberts in Mr. Epstein’s house,”’ EXHIBIT HH at § 17, contradicting Plaintiffs claims that nude photographs of her were prominently displayed throughout all of Epstein’s homes. No sexually explicit photographs of Plaintiff were ever produced in discovery in this case or subpoenaed by Plaintiff from any governmental agency. Plaintiff has presented no evidence the government “possesses” any such photographs or indeed ever became "aware of" them. 6. January 2015 statement accurately denied Maxwell acted as “madame” for Epstein to traffic Plaintiff to the rich and famous. Finally, in the joinder motion, Plaintiff asserted that Ms. Maxwell had “facilitated” sexual abuse “by acting as a ‘madame’ for Epstein, thereby assisting in internationally trafficking Jane Doe #3 (and numerous other young girls) for sexual purposes.” Plaintiff has utterly failed to substantiate her allegation. Not a single “other young girl” made a claim that Maxwell, or even Epstein for that matter, trafficked them to a third-person for commercial sexual acts. Detective Recarey confirmed that he had no knowledge of Ghislaine Maxwell sexually trafficking anyone. EXHIBIT GG at 278-79. He also confirmed that not a single one of the alleged victims of Epstein ever claimed to have any sexual contact with any man other than Epstein, or that they were sent to another location to have sex with another man or to give a massage to another man. /d. at 30002. None of the other alleged victims of Epstein ever claimed to have gone on his plane with him 63

Case 18-2868, Document 276, 08/09/2019, 2628224, Page71 of 77 or to have had sexual acts with him on his plane. /d. at 302-04. None claimed they had gone to New York with him and stayed in his residence. /d. at 304-05. Plaintiff, 1t appears, is the only alleged victim of Epstein who claims she was the subject of such trafficking, yet even she has retracted, amended, and withdrawn many of her allegations, thus rendering (by her own admission) such claim substantially untrue. Foreign Presidents. Upon questioning under oath, Plaintiff admitted that she had never even met a “foreign president,” much less ever been sexually trafficked to one or to the multiple “foreign presidents” referenced in the joinder motion. Q: The reference there to foreign presidents, do you see that? A: Yes. Q: You were sexually trafficked to foreign presidents? A: No. Q: So that’s not true, you were not sexually trafficked to foreign presidents? A: I don’t know what foreign presidents you’re talking about. Q: Have you ever been sexually trafficked to any foreign president? [Objection interposed by Ms. McCawley; Special Master overruled] A: I understand well-known prime ministers and other world leaders; as far as foreign presidents, I’m not too sure, I don’t know. Q: Have you ever met any foreign presidents? A: Foreign presidents as 1n overseas? Q: Sure, okay, overseas. A: No. Q: Have you ever met any foreign presidents from countries not overseas such as Canada or Mexico? A: No. Q: So you were not sexually trafficked to any foreign presidents, is that correct? A: As far as I know right now, yes. 64

Case 18-2868, Document 276, 08/09/2019, 2628224, Page72 of 77 Q: It’s correct that you were not sexually trafficked to them, right? A: You’ve asked me this three times and I’m telling you. EXHIBIT IJ at 10-12. Indeed, Plaintiff became frustrated by what she perceived as the third time she was asked the question, each time denying that she had met a foreign president or been sexually trafficked to one, clearly indicating that she understood the question, had answered it in the negative and did not want to be re-asked the question again.°’ Notably, not a single “foreign president” is listed as a witness with knowledge of Plaintiff's claims in her Rule 26 disclosures. “Well-known prime minister.” Plaintiff also has failed to establish any evidence to support her fantastical claim that she was sexually trafficked to a “well-known prime minister.” When questioned, she refused to disclose the identity of the prime minister, even with the protection of a protective order. EXHIBIT II at 12. She has not produced photographs of her with any well-known prime minister, nor any flight log showing a well-known prime minister on Epstein’s airplane. She has not identified herself as being in any location with a well-known prime minister, nor the date of any such encounter. The only evidence that Plaintiff has ever been even in the company of a well-known prime minister is her uncorroborated word. “World leaders.” Likewise, when asked about “world leaders” to whom she was trafficked, Plaintiff referred vaguely to someone she was introduced to as a “prince.” Q: Other world leaders, what other world leaders were you sexually trafficked to? [Objection interposed and overruled by Special Master] A: Okay. Prince Andrew for one. Q: Other than Prince Andrew’? *°Plaintiff and her counsel later devised a plan to just outright change these three answers through the errata sheet, claiming that Plaintiff had “misunderstood the question” and she had in fact been trafficked to such a president. EXHIBIT JJ. As her clear answers and frustration at the repeated nature of the questioning demonstrates, however, she had no trouble whatsoever understanding the question at the time. 65

Case 18-2868, Document 276, 08/09/2019, 2628224, Page73 of 77 A: There is another individual that I honestly do not know his name. Q: What country 1s he from? A: I’m not too sure, he spoke in a foreign—he did speak foreign tongue, he spoke English as well, but I’m not too sure where he was from? Q: How do you know he is a world leader? A: I was introduced to him as a prince. Q: Did you — where were you when you met him? A: On this occasion the South of France. Q: Where in the South of France were you? A: I don’t know. Q: Were you on a boat, were you in a house? A: We were at a like a cabana, not cabana, like a resort, but 1t was a big party. Q: Who was throwing the party? A: I don’t know. I was just brought there. EXHIBIT II at 15-17. Indeed, this is almost the identical answer that Plaintiff later gave when questioned about what which “powerful businessmen” she had been sent to have sex with: Q: Where were you sent to have sex with the owner of a large hotel chain by Ghislaine Maxwell? A: I believe that was one time in France. Q: I believe it was around the same time that Naomi Campbell had a birthday party. A: Where did you have sex with the owner of a large hotel chain in France around the time of Naomi Campbell’s birthday party? A: In his own cabana townhouse thing. It was part of a hotel, but I wouldn’t call it @ HOU «2. 66

Case 18-2868, Document 276, 08/09/2019, 2628224, Page74 of 77 EXHIBIT N at 203. In fact, Naomi Campbell’s birthday is May 22, 1970. [WIKIPEDIA]. The flight logs do not show plaintiff traveling to France in May 2001 or May 2002. EXHIBIT BB at DR_ 0046, DR_0056. On May 22, 2002, for example, Epstein was in Russia. In her joinder motion, Plaintiff made the additional claim that Epstein (not Maxwell) sexually trafficked her to “model scout” Jean Luc Brunel on numerous occasions and in numerous places, including “the South of France.” EXHIBIT D at 5-6. The flight logs, however, demonstrate that Plaintiff was never in the “south of France,” much less on multiple occasions. The one and only trip reflecting travel by Plaintiff to France was a trip on March 6, 2001 from a fueling stop in Canada to Paris, followed by a departure from Paris on March 8, 2001 to Granada. EXHIBIT BB at DR_000043; EXHIBIT CC at 107. Although there are other flights in which Epstein went to Nice in the south of France, Plaintiff 1s not on any of them and none are near Naomi Campbell’s birthday on May 22. Plaintiff's claim in her joinder motion about having been trafficked to other “prominent American politicians” and other world leaders have gone unsubstantiated and are patently incredible. Because these men are publicized to have been in the company of Epstein on at least one occasion, such was apparently sufficient for Plaintiff to claim she had been trafficked to them. For example, Plaintiff claimed at her deposition that these powerful men to whom she was trafficked included Marvin Minsky. EXHIBIT N at 204. Dr. Minsky, a world-renowned scholar and long-time professor at MIT, passed away in January 2016 at the age of 88. °’ At the time of his passing, he had been married to his wife, pediatrician Dr. Gloria Rudisch, since 1952 and had three children and four grandchildren. His name appears on one of Epstein’s flight logs as having traveled with a large group of individuals, including plaintiff, from New Jersey to Santa Fe on *’ https://www.bostonglobe.com/metro/2016/01/25/marvin-minsky-dies-mit-professorhelped-found-field-artificial-intelligence/A8 y6ey8S0QAaa0463Z2000/story. html 67

Case 18-2868, Document 276, 08/09/2019, 2628224, Page75 of 77 March 29 and returning on March 31, 2001.°° The other passengers included world-renowned philanthropist Dr. Henry Jarecki, now aged 83, also a long-time husband, famed academic and scholar, and famous philanthropist.”” Plaintiff produced no evidence substantiating any of her fantastical claims that she had been trafficked by Epstein, or by Maxwell, to any of these men or any others. No witnesses vouched for seeing plaintiff in the company of politicians George Mitchell or Bill Richardson to whom plaintiff claims she was sent. She produced no photographs of herself with them. She had a journal where she claims she documented their names, but she claims she burned that journal in 2013. In May 2011, plaintiff inquired by email to journalist Sharon Churcher to “remind” her of the famous people to whom she was trafficked. Plaintiff has not supported her claims with clear and convincing evidence and thus, Ms. Maxwell’s denials and characterizations of these claims as “obvious lies” is not defamatory as a matter of law. CONCLUSION For the foregoing reasons, the Court should grant summary judgment in favor of Ms. Maxwell. *® Plaintiff claims, however, that she was trafficked to Dr. Minsky in the U.S. Virgin Islands. * https://en.wikipedia.org/wiki/Henry Jarecki 68

Case 18-2868, Document 276, 08/09/2019, 2628224, Page76 of 77 January 6, 2017. Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10" Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 Imenninger@hmflaw.com Attorneys for Defendant Ghislaine Maxwell 69

Case 18-2868, Document 276, 08/09/2019, 2628224, Page77 of 77 CERTIFICATE OF SERVICE I certify that on January 6, 2017, I electronically served this Memorandum in Support of Defendant’s Motion for Summary Judgment via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com 70 Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@aol.com /s/ Nicole Simmons Nicole Simmons

Case 18-2868, Document 277, 08/09/2019, 2628225, Pagel of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Se eee X VIRGINIA L. GIUFFRE, 3 Plaintiff, 3 V. 15-cv-07433-RWS GHISLAINE MAXWELL, 3 Defendant. | eee eee ne eee eee X Declaration of Laura A. Menninger in Support of Defendant’s Motion For Summary Judgment I, Laura A. Menninger, declare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I ama member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell’s Motion for Summary Judgment.’ 2. Attached as Exhibit A is a true and correct copy of an article by Sharon Churcher entitled “Prince Andrew and the 17-year-old girl his sex offender flew to Britain to meet him,” DAILY MAIL, dated March 2, 2011. ' At trial, defendant intends to produce either the custodian of record relevant to any disputed document or a certification in compliance with either Fed. R. Evid. P. 803 and/or 902. See Fed. R. Civ. P. 56(c). Apart from deposition testimony, the majority of non-deposition documents herein were either produced by plaintiff or obtained with releases signed by plaintiff.

Case 18-2868, Document 277, 08/09/2019, 2628225, Page2 of 7 3. Attached as Exhibit B is a true and correct copy of an article by Sharon Churcher entitled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill Clinton,” DAILY MAIL, dated March 5, 2011. 4. Attached as Exhibit C is a true and correct copy of a statement on behalf of Ms. Maxwell dated March 9, 2011. 5. Attached as Exhibit D (filed under seal) is a true and correct copy of the corrected Motion for Joinder, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Jan. 2, 2015). 6. Attached as Exhibit E is a true and correct copy of an Order Denying Motion to Join Under Rule 21, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Apr. 7, 2016). 7. Attached as Exhibit F is a true and correct copy of a statement on behalf of Ms. Maxwell dated January 2, 2015. 8. Attached as Exhibit G (filed under seal) are true and correct copies of excerpts from the November 18, 2016 deposition of Ross Gow, designated Confidential under the Protective Order. 9. Attached as Exhibit H (filed under seal) is a true and correct copy of Plaintiffs Response to Second Request for Production and to Interrogatories and Requests for Admissions, dated July 1, 2016. 10. Attached as Exhibit I (filed under seal) is a true and correct copy of Plaintiff’s Supplemental Responses to to Interrogatory Nos. 6, 12 and 13, dated August 17, 2016, designated Confidential under the Protective Order.

Case 18-2868, Document 277, 08/09/2019, 2628225, Page3 of 7 11. Attached as Exhibit J (filed under seal) is a true and correct copy of the Declaration of Ghislaine Maxwell, dated January 6, 2017. 12. Attached as Exhibit K (filed under seal) is a true and correct copy of the Declaration of Philip Barden, dated January 6, 2017. 13. Attached as Exhibit L (filed under seal) are true and correct copies of excerpts from the June 23, 2016 deposition of James Austrich, designated Confidential under the Protective Order. 14. Attached as Exhibit M (filed under seal) is a true and correct copy of Plaintiffs passport application, dated January 12, 2001, designated Confidential under the Protective Order. 15. Attached as Exhibit N (filed under seal) are true and correct copies of excerpts from the May 3, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective Order. 16. Attached as Exhibit O (filed under seal) are true and correct copies of Plaintiff's school records Bates stamped GM_00888 and GIUFFREE004981-88 and designated Confidential under the Protective Order. 17. Attached as Exhibit P (filed under seal) are true and correct copies of excerpts from the June 24, 2016 deposition of Tony Figueroa, designated Confidential under the Protective Order. 18. Attached as Exhibit Q (filed under seal) are true and correct copies of excerpts from the November 14, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective Order.

Case 18-2868, Document 277, 08/09/2019, 2628225, Page4 of 7 19. Attached as Exhibit R (filed under seal) is a true and correct copy of Plaintiffs Social Security records dated October 25, 2016, Bates stamped GIUFFRE009175, designated Confidential under the Protective Order. 20. Attached as Exhibit S (filed under seal) is a true and correct copy of Mar-A-Lago records, Bates stamped MAR-A-LAGO-0001 and MAR-A-LAGO-0161-0177. 21. Attached as Exhibit T (filed under seal) is a true and correct copies of excerpts from the May 20, 2016 deposition of Sky Roberts, designated Confidential under the Protective Order. 22. Attached as Exhibit U (filed under seal) ) is a true and correct copy of the Mar-ALago employee handbook, dated October 28, 1995, Bates stamped MAR-A-LAGO-0178-0243. 23. Attached as Exhibit V (filed under seal) is a true and correct copy of the Mar-A-Lago advertisement, Bates stamped MAR-A-LAGO-0086. 24. Attached as Exhibit W (filed under seal) is a true and correct copy of Plaintiffs Courtyard Animal Hospital employment application, Bates stamped GIUFFRE009201-11, designated Confidential under the Protective Order. 25. Attached as Exhibit X(filed under seal) is a true and correct copy of the Royal Palm Beach Police Department Offense Report date, June 10, 2001, Bates stamped GM_00780-82. 26. Attached as Exhibit Y (filed under seal) is a true and correct copy of the Royal Palm Beach Police Department Probable Cause Affidavit date, November 19, 1999, Bates stamped GM_01223-28. 27. Attached as Exhibit Z (filed under seal) is a true and correct copy of the Royal Palm Beach Police Department Offense Report date, August 3, 2001, Bates stamped GM_00777-79.

Case 18-2868, Document 277, 08/09/2019, 2628225, Paged of 7 28. Attached as Exhibit AA (filed under seal) is a true and correct copy of the Palm Beach County Sheriff’s Offense Report date, June 02, 2002, Bates stamped GM_00748-79. 29. Attached as Exhibit BB (filed under seal) are true and correct copies of David Rodgers flight logs from November 1995 to May 2013, Bates stamped DR__0001-DRO107. 30. Attached as Exhibit CC (filed under seal) is a true and correct copy of excerpts from the June 3, 2016 deposition of David Rodgers, designated Confidential under the Protective Order. 31. Exhibit DD left intentionally blank. 32. Attached as Exhibit EE (filed under seal) is a true and correct copy of the Royal Palm Beach Police Citation Tracking Report date, June 19, 2002, Bates stamped GM_ 00776. 33. Attached as Exhibit FF (filed under seal) is a true and correct copy of the Palm Beach County Sheriff’s Offense Report, Bates stamped GM_01202-28. 34. Attached as Exhibit GG (filed under seal) is a true and correct copies of excerpts from the June 21, 2016 deposition of Joseph Recarey, designated Confidential under the Protective Order. 35. Attached as Exhibit HH (filed under seal) is a true and correct copy of the Affidavit of Juan P. Alessi, dated January 13, 2016, Bates stamped GM_ 01197-1201. 36. Attached as Exhibit II (filed under seal) is a true and correct copy of excerpts from the Deposition of Virginia Giuffre taken in Cassell v. Dershowitz, on January 16, 2016, and designated as Confidential under the Protective Order.

Case 18-2868, Document 277, 08/09/2019, 2628225, Page6 of 7 37. Attached as Exhibit JJ (filed under seal) is a true and correct copy of Errata Sheet from the January 16, 2016 deposition of Virginia Giuffre taken in Cassell v. Dershowitz, dated February 11, 2016 and designated by Plaintiff as Confidential under the Protective Order. 38. Attached as Exhibit KK (filed under seal) is a true and correct copy of The Billionaire Playboys Club book manuscript, designated by Plaintiff as Confidential under the Protective Order. 39. Attached as Exhibit LL is a true and correct copy of the Victims Refuse Silence, Inc. Articles of Incorporation dated December 23, 2014, GIUFFRE001064-65. 40. Attached as Exhibit MM (filed under seal) is a true and correct copy of excerpts from the September 8, 2016 deposition of Brittany Henderson, designated Confidential under the Protective Order. I declare under penalty of perjury that the foregoing is true and correct. Executed on January 6, 2017. s/ Laura A. Menninger Laura A. Menninger

Case 18-2868, Document 277, 08/09/2019, 2628225, Page? of 7 CERTIFICATE OF SERVICE I certify that on January 6, 2017, I electronically served this Declaration of Laura A. Menninger in Support of Defendant’s Motion for Summary Judgment via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@aol.com /s/ Nicole Simmons Nicole Simmons

Case 18-2868, Document 278, 08/09/2019, 2628230, Page1 of 648 EXHIBIT A

Case 18-2868, Document 278, 08/09/2019, 2628230, Page2 of 648 6/14/2016 Prince Andrew and girl, 17, who sex offender friend fiew to Britain to meet him | Daily Mail Online Daily Com 8 Sports | U.S. Showbiz | Australia | Femail | Health | Science | Money | Video | Travel | Columnists tt ostmeat bbegeneliirseres ei VASardel Sfeaanes re Ld sone lieeeny GSiedipan Adeeb preach Aden Ulesceeed Lafle aw eres i LaPasd 3 ia diyas PISwsi Yue iivews Aris rMagcres reishiyes Moarrand News Goarcd Wires LOCH Prince Andrew and the 17-year-old girlhis [| |_ sex offender friend flew to Britain to meet him « Virginia Roberts reveals she is ‘Jane Doe 102' in Jeffrey Epstein case « Mother-of-three spent four years as millionaire's personal masseuse - She describes being flown across world to meet Prince Andrew e Epstein trained her ‘as a prostitute for him and his friends’ As the UK's special representative for international trade, the Duke of York holds an important position, requiring sound judgement and widespread respect. But those qualities have been thrown into question since photographs of Prince Andrew with his billionaire financier friend Jeffrey Epstein, a convicted child-sex offender who was jailed for 18 months for soliciting underage prostitutes, appeared last weekend. Today, however, even more serious doubts are cast on his suitability after a woman at the centre of the Epstein case revealed to The Mail on Sunday that she had, as a 17-year-old employed by Epstein, been flown across the world to be introduced to the Prince. http:/Avww.dailym ail.co.uk/news/article-1361039/Prince-Andrew-girl-17-sex- offender -friend-flew-Britain-meet-him .htm| | 1/34

: eee Case LT SECOROTM SO RYS?. bercurtreit QHGIm oie O64 5M PailPagOBef 9 Lindsay Lohan flashes her cleavage in a lowcut lilac number as she enjoys romantic day in Zurich with fiancé Egor Tarabasov Lovely in lilac Back in time to celebrate! Kim Kardashian and Kanye West arrive inLA on eve of daughter North's third birthday Whirlwind 24-hour trip Bathing suit babes! Playboy vet Kendra Wilkinson shows off S chestin one piece while #2: celebrating 31st birthday with ‘number one ho’ in Arizona Sean Penn's son Hopper, 22, reveals his famous father wanted to name him ‘Steak’ dueto | his love of red meat His mom Robin Wright wouldn't have gone for it New romance for Ruby? Rose ‘dating’ businesswoman Harley Gusman after the pair were spotted cozying up on a date in Hollywood Off the market? Was Patrick Swayze a victim of domestic abuse? Wife denies claims she beat the Dirty Dancing star throughout their 34-year marriage - and even when he was dying Advertisement On one of those occasions Virginia Roberts was subsequently paid $15,000 (£9,400). Her shocking account of her four years as Epstein’s personal masseuse is supported by court documents, an eyewitness, photographs and flight details of Epstein’s private jets. One picture, said to have been taken by Epstein during Andrew's first encounter with the girl in March 2001 and published today by The Mail on Sunday, shows the Prince with his arm around her waist. This is not the first time the Duke of York's judgment and choice of associates have been questioned. He appears to relish the company of super-rich oil billionaires from the Middle East, North Africa and the former Soviet Union. The peculiar sale of his former marital home to a Kazakh businessman for £15 million after it had languished unsold for five years at £12 million has never been satisfactorily explained. in the recent leak of American diplomatic cables it was revealed that he had criticised an official corruption investigation into the huge Al-Yamamah arms deal between Britain and Saudi Arabia, while he is also said to be close to Saif Al-lsiam Gaddafi, son of the beleaguered Libyan president, and may have had a role in the early release of Lockerbie bomber Abdelbaset Al Megrahi. But it is Andrew's friendship with Epstein, whom : he has known since at least 2000, and with While on the streets, | Epstein’s confidante Ghislaine Maxwell, daughter s| ept with men for of the late disgraced newspaper baron Robert Maxwell, that gives most concern. mon ey. | was a He was first seen with the pair on holiday in 1. fg Thailand, and was pictured cavorting with paedophile's dream Ghislaine at a Halloween fetishthemed party in http:/Avww.dailym ail.co.uk/news/article-1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.htm| 2/34

Case 18-2868, Document 278, 08/09/2019, 2628230, Page4 of 648 6/14/2016 Manhattan. The photograph that appeared last weekend shows the prince strolling through Central Park with 58-year-old Epstein. Andrew was said to have spent four days at his New York mansion in December, when he was joined by other distinguished guests, including Woody Allen, at a dinner. It is by no means the first New York soiree Andrew has attended as Epstein’s guest. A lengthy profile of the financier in Vanity Fair magazine some years ago reported that Andrew was a guest at a cocktail party thrown by Epstein and Maxwell packed with young Russian models. ‘Some guests were horrified,’ said the article’s author, Vicky Ward. it shouid not be forgotten that Epstein is a registered sex offender after recently completing his sentence for offences relating to child prostitution. However, he avoided trial on more serious charges that carried a potential life sentence. And no one reading The Mail on Sunday's interview with the woman who was prepared to testify against him can be in any doubt of the seriousness of the charges. Epstein, a Wall Street money manager who once counted Bill Clinton and Donald Trump among his friends, became the subject of an undercover investigation in 2005 after the stepmother of a 14-year old girl claimed she was paid $200 (£125) to give him an ‘erotic massage’. The subsequent FBI probe uncovered at least 20 girls levelling sexual allegations against him. Eventually, Epstein struck a ‘plea bargain’ with prosecutors — a practice not permitted under British law — under which he was allowed to plead guilty to two relatively minor charges. Police claim that his donations to politicians and his ‘dream team’ of influential lawyers deterred prosecutors from bringing more serious charges of sex-trafficking. The deal certainty kept the names of a lot of Epstein’s famous friends out of an embarrassing court case. However, an unusual part of the agreement was that Epstein’s alleged victims were allowed to bring civil proceedings against him. He has so far made 17 out-of-court settlements, and some cases are ongoing. One of these girls was to have been a key witness for the prosecution had the case gone to trial. She was just 15 years old when she was drawn into Epstein’s exploitative world in 1998. In her civil writ against him, under the pseudonym Jane Doe 102’ she alleged that her duties included being ‘sexually exploited by Epstein’s adult male peers including royalty’. Now, horrified by the evidence of Epstein and Andrew enjoying each other’s company in New York, Jane Doe 102 has agreed to waive her anonymity and tell for the first time her deeply disturbing story. Her real name is Virginia Roberts and she now lives in Australia, where she is a happily married mother of three. Over the course of a week during which she spoke at length to The Mail on Sunday, she appeared sometimes vulnerable, and sometimes steely, but always quietly resolute and consistent. Revisiting events from a past that she had hoped she had left behind, Virginia occasionally buried her face in her hands. Some recollections — and, for reasons of taste, not all the details can be included here — caused her to flush with shame. ‘I'm telling you things that even my husband didn’t know,’ she said. Virginia, who has undergone counselling to try to come to terms with her past, is honest about her initiation into Epstein’s depraved world. She was a troubled teenager, whose slender figure, delicate complexion, hesitant voice and soulful blue eyes made her look young for her years. Born in Sacramento, California, in August 1983, Virginia spent her early years on a small ranch on the West Coast of America. This seemingly idyllic chitdhood ended when she was sexually molested by a man close to her family. The fallout from that led to her parents temporarily splitting up. Blaming herself, Virginia began to get into trouble Aged 11, she was sent to live with an aunt but repeatedly ran away. Living on the streets, she was beaten up and slept with at least two older men in return for food. ‘I was a paedophile’s dream,’ she says. Three years later, she was reunited with her family and started a new life with her father who had moved to Palm Beach, Florida, where he was maintenance manager at Donald Trump’s country club, Mar-a-Lago. Virginia got a part-time job as a changing room assistant —which is where, soon after her 15th birthday, she met Ghislaine Maxwell, who invited her to work as Epstein’s personal masseuse. ‘| was wearing my uniform — a white miniskirt and a skin-tight white polo top — when | was approached by Ghislaine,’ Virginia says. ‘I told her | wanted to become a masseuse and she said she worked for a very wealthy gentleman who was looking for a travelling masseuse. I'd get training and be paid well. Virginia’s father gave his blessing, believing his daughter was being handed the opportunity to learn a skill and to work for a wealthy and respectable employer. He drove her to Epstein’s pink mansion on the Palm Beach waterfront — he also owns a nine-storey home in New York, the city’s biggest private residence; a 7,500-acre ranch called ‘Zorro’ in New ‘Need a tight tush’: LeAnn Rimes illustrates how to get a firm ‘booty’ as she does yoga in skimpy tank top and leggings Exercise tips ‘'twant them reaily big!’ Blonde bombshell begs doctors to make her 1,000cc implants - even after they insist her enhanced breasts are ‘perfect’ On Botched ‘it's my fourth favorite reality show! Jessica Alba and Kate Hudson are mean girls as Chris Martin plays for taughs in Sara and Erin Foster’ Barely Famous ‘He’s turned into an absolute jerk:' Former Celebrity Apprentice star Vivica A. Fox slams | Donald Trump... but says he's not a racist She's no longer a fan ‘| don't see a dark past anymore’: Paris Jackson reveals tattoos | have helped cover her ‘scars and seif-hatred’ in moving Instagram post How the season’s hottest beach babes including Hailee Steinfeld and Kendall Jenner are embracing jeweiry at the seashora Chic on the beach This old thing! Duchess of Cambridge recycles a TEN-year-old | brocade coat as she plants a tree at garden party From the back of her wardrobe EXCLUSIVE: Alexa Curtin, daughter of Real | Housewives star Lynne, | is charged with drug possession two months after accusing O.C. deputy sheriff of raping her during a traffic stop ‘told my mom she's a A : grandma’: Maria Menounos shared excitement about her frozen embryos in poignant IVF interview... given before negative pregnancy test Gene Simmons' daughter Sophie says she was told she was ‘not small enough’ to be a model and reveals her mam taught her to love her shape http:/Avww.dailym ail.co.uk/news/article- 1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.htm! Case 1:15°CrGTM gray 9’. Dercuerreset DpSim toBiieid G74 5/11 Daly Oninaf 9 essa] Beiirsee a

Case 18-2868, Document 278, 08/09/2019, 2628230, Page5d of 648 6/14/2016 Mexico and Little Saint James, a private 70acre atoll in the US Virgin Islands. - , hr ee The or Tae ee PTE: | re. fa A new life: Virgina, now a mather-of-three, in Australia Virginia says: ‘Ghislaine said | was to start immediately and that someone would drive me home. My father left and | was told to go upstairs.’ She was led by another woman through Epstein’s bedroom into a massage room where he fay face down naked on a table. He started to interviewed Virginia. This was unconventional, but Virginia had no suspicions. Presumably, she thought, this was how the wealthy conducted their business. Fpstein elicited the information that Virginia had been a runaway, and was no longer a virgin. Virginia was then told to start massaging Epstein, under the instructions of the woman who had shown her in. The massage quickly developed into a sexual encounter. Virginia was uncomfortable, but reluctant to deny such important people. ‘My face was red with embarrassment,’ she says. ‘But | felt under immense pressure to please them. The whole time it was going on, they were promising me the world, that I’d travel with Jeffrey on his private jet and have a well-paid profession.’ Afterwards, she was given two $100 bills and told to return the next day. That was the beginning of the four years she spent with Epstein. For three of those years, she was under Fiorida’s age of consent, which is 18. Case 1:1 5°UrOT@aeeRIVS. Dersuetredet DHGIM toiled OG 51 PaIPYyOG ‘fd cry bacause there was nothing I could do to help’: Bella Hadid pans emotional note about her mother Yolanda‘s Lyme disease battle and shares the impact of her own struggle Has the Queen Bay lost her sting? Beyonce steps out in two questionable outfits as she recycles Super Bowl Reformation look She is still a trailblazer Jenna Bush Hager shares somber message about motherhood as she reveals her daughter was baptized only hours before Orlando shooting Time for Kardashian kiass! From ‘bloop’ to ‘ratchet’... Kim schools fans in how to talk like a trug-blooded member of the family How to be like them Brazilian Miss Bum Bum model reveals she is paralysed from the waist down after throwing herself from a fourth floor window in suicide attempt Southern Charm stars claim Kathryn Dennis failed drug test in custody battie with weaithy drug-shamed former politician Thomas Ravenel as he takes their kids to NYC Mini-me Barron joins parents Donald Trump and Melania at The Polo Bar for dinner the night before his 7Oth birthday (and Secret Service chauffeurs them the one block walk home) Lord of tha manor! Scott Disick views $2.Bmillion property in Baverly Hills as he hunts for a house to fix up and sell He is 33 Peek-a-boob! Heidi Kium flashes cleavage http:/Avww.dailym ail.co.uk/news/article- 1361039/Prince-Andrew-girl-17-sex- offender -friend-flew-Britain-meat-him.htmI f9

Case 18-2868, Document 278, 08/09/2019, 2628230, Page6é of 648 6/14/2016 Troubled teenager: Virginia on the billionaire’ 8 Zorro ranch i in New Mexico i in 2001 Virginia was fascinated by his life story: the son of a humble New York City parks wore eG was a teacher before becoming a Wall Street broker and friends with the upper echelons of the political, financial and academic establishment. As a confused teenager, Virginia easily fell into the practice of sexually gratifying him for money. He guaranteed her a minimum of $200 each time she gave him what he called an ‘erotic massage.’ Virginia said: ‘| would always receive the money immediately. He would give me the cash from a wad he carried in a black duffel bag or an assistant paid me. ‘And, because of the way Epstein had warped her sensibilities, every time she took the cash, Virginia felt even more indebted to him. Secretly, he was also preparing her for an even more disturbing role. ‘Basically, | was training to be a prostitute for him and his friends who shared his interest in young girls,’ she says: ‘After about two years, he started to ask me to “entertain” his friends.’ It started when Epstein called Virginia at the Pam Wanted. Beach apartment he had rented for her. She recalls: ‘He said, “!’ve got a good friend and | need you to fly to the island to entertain him, massage him and make him fee! how you make me feel.” He didn’t spell out what | had to do. He didn’t have to. ‘He’d trained me to do whatever a man wanted. | was shocked but ! told myself he was sharing me around because he trusted me and | was special. Epstein had trained me to do whatever men | told myself | was special | was worried, but | would do anything to keep Jeffrey happy and to keep my place as his number one girl. He would keep telling me how lucky | was with the life | was leading and the money | was making. It was easy to fall into his grasp. ‘The way it usually worked was I’d be sent to meet a man on the private island Jeffrey owned in the Caribbean, or at his ranch in New Mexico, which was really isolated.’ She was ‘given’ to men ranging in age from their 40s to their 60s. They included a well-known businessman (whose pregnant wife was asleep in the next room), a world-renowned scientist, a respected liberal politician and a foreign head of state. None appeared to think the arrangement was unusual. Virginia says there were many other girls in Epstein’s circle and that she was paid extra money to help recruit them. ‘They would lounge around the Palm Beach house, the ranch or the island, nude or topless,’ she says. ‘But | was one of the very few he trusted as “special” and chosen to “entertain” his friends.’ Virginia took the sedative Xanax to detach herself from sordid reality. ‘It was an escape drug,’ she says. ‘It made me calm and helped me forget about what | had to do. | was up to eight pills a day.’ Epstein had no objection to Virginia’s use of prescription drugs, no doubt recognising that they made her even more malleable. ‘! didn’t want to go back to the life I’d had before’ she says. ‘That made me totally obedient.’ Despite the fact that Epstein was, essentially, her pimp, this life now seemed normal to Virginia. ‘I felt that he and Ghislaine really cared for me,’ she said. ‘We'd do family things, like watch Sex And The City and eat popcorn. ‘A iot of it was very glamorous. | met famous friends of his such as Al Gore and Heidi Kium and Naomi Campbell. He introduced me as his “travelling masseuse.” Some people mistook me for his daughter. ‘When we were in New York or Palm Beach, Ghislaine and | would shop all day. Case 1:1L5°oregyd eRe’. Dersuerrett Ppgim tole G94 Hi PalPygagref 9 as she feaves her blouse undone across her chest during NYC outing with her children Mom-of four he’s almost as fal! her mom! Courteney Cox's daughter Coco Arquette wears high heels and pofka dot dress for her 12th birthday at Nobu ‘It's hard on me’: Liev Schreiber talks struggie of working in LA while Naomi Watts and their two kids are in NYC as he sits down with Ellen He misses them ‘i was too big’: Khioe Kardashian reveals stylists refused to work with her before she lost 40ibs as she wows in Stunning natural shoot for Harper's Sazaar Curb Your Enthusiasm is back! Larry David's beloved comedy series will return for a ninth season Ths beloved HBO comedy series Super-sized diamond Her Majesty calls F ‘Granny's Chips’ and the & solitaire seed thataqrew into a flower: Queen's brooches and earrings have a glittering history Sporty! Channing Tatum wears a backward basebali cap and matching vest as he jieaves NYC hotel Ths Magic Mike star was hard to miss Rollin’ and stroilin'! Chilled Bobby Cannavaie gets behind the wheels of baby son Rocco's classy ride as he runs errands Star of HBO's Vinyl hitp:/Avww.dailymail.co.uk/news/article- 1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.htm! 5/34

Case 18-2868, Document 278, 08/09/2019, 2628230, Page/7 of 648 @/14/2016 Case 1:15°ovOTd@GeRYVS, Dencuetrevt Jeffrey bought me jewellery -- diamonds were his favourite ~ and wonderful furniture. He was paying me very well because I'd give him sex whenever he wanted it.’ She was, she says, delighted when Epstein invited her to accompany him on a six-week trip in 2001. ‘He said we'd be going to Europe and North Africa to meet architects and interior decorators because he wanted to redo his New Mexico house. | threw my arms around him and gave him a peck on the cheek.’ They flew to Paris, then Spain, then Tangier. Finally, they went to London. ‘After we landed, we drove straight to Ghislaine’s house,’ says Virginia. ‘l was given a smail upstairs bedroom. The following morning, Ghislaine came in. She was chirpy and jumped on the bed saying, “Get up, sleepyhead. You've got a big day. We've got to go shopping. You need a dress as you're going to dance with a Prince tonight.” ‘She said | needed to be “smiley” and bubbly because he was the Queen's son. Ghislaine and | went to Burberry, where she bought me a £5,000 bag, and to a few other designer stores where we bought a couple of dresses, a pair of embroidered jeans and a pink singlet, perfume and make-up. ‘Counselling: Virg Beach in 1998 We got back to Ghislaine’s house at around 4pm and | ran straight upstairs to shower and dress. When | went downstairs, Ghislaine and Jeffrey were in the lounge. There was a knock at the door. Ghislaine led Andrew in and we kissed each other on the cheek. ‘Ghislaine served tea from a porcelain pot and biscuits. She knew Sarah Ferguson and they talked fondly about Andrew's daughters. Then Ghislaine asked Andrew how old he thought | was and he guessed 17 and they all laughed. Ghislaine made a joke that | was getting too old for Jeffrey. She said, “He'll soon have to trade her in.” It was widely known that he liked young girls.’ The four of them went out to dinner and on to Tramp nightclub where, she says, Andrew danced with her. ‘After about an hour-and-a-half, we drove back to Ghisiaine’s. Ail of us went upstairs and | asked Jeffrey to snap a picture of me with the Prince. | wanted something to show my Mom. Ghislaine and Jeffrey left us after that, and later Andrew left. ‘In the morning, Ghislaine said, “You did well. He had fun”. We flew straight back to the States.’ The Mail on Sunday has confirmed that the tycoon’s jet flew to Paris on March 6, 2001, continuing to Granada, Tangier and London, before returning to New York. On the last leg of the trip, Virginia was paid about $15,000 (£9,400) by Epstein. ‘It was amazing money, more than I'd ever made on a trip with him before. He didn’t say there was any special reason, but | felt like I’d done everything he wanted. He was very pleased.’ There is no suggestion that there was any sexual contact between Virginia and Andrew, or that Andrew knew that Epstein paid her to have sex with his friends. | took eight pills a day to help me forget what | had to . do. It made me calm. However, the Prince must have been aware of Fpstein’s conviction when he stayed with him in New York in December. Virginia says she met Andrew for a second time around Easter 2001 at Epstein’s Manhattan mansion. ‘When | got to the mansion, | was told, “Get ready. You are meeting someone in the office” — which is what they called the library. Andrew was sitting there in a big feather armchair. Ghislaine had just given him a present, a big toy that was his Spitting Image puppet. ‘He was smiling ear-to-ear. He looked like a kid whose parents were taking him to Disney World. A beautiful girl called Johanna Sjoberg who worked for Jeffrey was sitting on Andrew's knee. Ghislaine guided me over to Andrew and | think he recognised me, though | don’t know if he remembered my name. SM Papa OrPinef Q ‘I'm dating aseparated ; married man:’ Bethenny Frankel reveals she went to high school with wife of new boyfriand Dennis Shields Skinny Girt founder Get in there! Prince Harry and Zara Tindall can’t contain their excitement as they watch their horses gallop to victory at Royal Ascot ‘This isn't about you and your fake a** kiss for publicity’: Madonna § is slammed for her 'self- & promoting’ tweets following Orlando massacre Jason Momoa's minime! Game of Thrones hunk enjoys family outing with cutie clone Nakoa-Wolf Seven-year-oild’s mom is Lisa Bonet Craving a little Mexican! Rob Kardashian's pregnant flancée Blac Chyna digs into a bow! of tortilla soup during Snapchat video Another Bachelor baby! Peyton and Chris Lambton are 'thrilled’ to be expecting their first child after four years of marriage The two wed in 2012 Lil Wayne ‘guzzled three bottles of cough syrup mix lean’ before suffering TWO seizures...as rappernow } ‘stable and in good i spirits’ Cowgirl chic! Alessandra Ambrosio shows off toned lags with mini skirt as the stunner goes for a denim-on-denim look Victoria's Secret Angei Madonna and Guy Ritchie on brink of deal over custody of their 15year-old son Rocco as judge agrees to call off showdown court hearing for more talks Gillian Anderson looks # demure in sophisticated § navy knee-lengthdress as she attends star Studded charity gala On behalf of Action on Addiction Charlie Sheen cuts a casual figure while out and about in Stockholm... After becoming the new face http:/Avww.dailymail.co.uk/news/articie- 1361039/Prince-Andrew-girl-17-sax-offender-friend-flew-Britain-meet-him.htm! 6/34

6/14/2016 pecnes! ri Organiser: Ghislaine Maxwell looks on as Andrew put his arm around Virginia. Robert Maxwell's daughter invited her to work as Epstein's personal masseuse soon after her 15th birthday We kissed on the cheek and Ghislaine placed me on his other knee.’ Johanna spoke to The Mail on Sunday three years ago about this incident, which took place when she was 21. She said: ‘Ghislaine put the puppet’s hand on Virginia’s breast, then Andrew put his hand on my breast. It was a great joke. Everybody laughed.’ After this, Virginia was paid, by Epstein, around $400 (£250).’ She met Andrew for the third and final time on Epstein’s Caribbean island, Little Saint James. Virginia was never under the British legal age of consent when she met Andrew. She was 17 during the first two encounters and 18 at the third. By now, however, Epstein, had started to hint that she was getting ‘too old’ for him. But during one trp to the island, Epstein and Ghislaine made their most astonishing proposition, and one which repuised her. ‘They said Jeffrey wanted me to have his child,’ she says. ‘They said | was part of their family and | was beautiful,young, loyal and nurturing and would be a great mother. They said | would have to sign a contract relinquishing rights to the child and consenting to Jeffrey having as many relationships as he liked. In return | would have my own mansion in Palm Beach and a large monthly payment, a percentage of his income.’ This, finally, was a wake-up call to Virginia and she began to see the way in which she had been groomed. ‘It was a smack in the face,’ she says. ‘I finally realised this wasn’t ever going to be a real relationship but | knew if ! refused, I'd be thrown back on the streets. So | said, “I’m too yaung. | want to get my massage credentials, then maybe we'll do it".’ The tycoon took her at her word and, for her 19th birthday in August 2002, flew her to Thailand where he enrolled her in a massage course. Shortly after arriving there, she met an Australian martial arts expert called Robert. They fell in love and, just ten days later, married in a Buddhist ceremony. ‘| called Jeffrey and told him I'd fallen madly in love,’ Virginia says. ‘I was hoping he'd be delighted. But he said, “Have a nice life,” and hung up on me.’ The couple now have two sons, aged five and four, and a daughter who recently turned one. ‘The first few months after | married Robert were the worst,’ she says. ‘I couldn't bring myseif to tell him much. No man wants to know his wife has been traded out. 'l felt very alone. | was having panic attacks and seeing a psychiatrist and was on anti-depressants. ’ Virginia was beginning to put her Epstein days behind her when, three years ago, she was phoned by the FBI. hitp:/Avww.dailymail.co.uk/news/article- 1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.htm! Case 1:1 5°00 SGRWS”. DeRsuefredt DLGIR tilted 64 SPP Osref 9 of condom brand Lelo Hex Wave goodbye to the rain! The deluge FINALLY stops as the Queen arrives at Ascot with Philip and Harry after thousands of racegoers got drenched Two nations standing together: Wills and Kate 3 sign book of condofence : to pay their respects to the victims of Orlando nightclub killer Paying respects Time for an upgrade? David Arquette lists his historic Los Angeles mansion for $8.5m Selling Hancock Park saven-bedroom home which he boughtin 2014 She's her own best advert! Jassica Alba's tresses glint in the sun as she promotes her Honest Company’s new hair care range in New York Katharine McPhee flashes a hint of sideboob in a plunging unbuttoned black dress as she poses at the Monte Carlo Telavision Festival Let the trading begin! Independence Day's Liam Hemsworth and Vivica A. Fox ring the NASDAQ bell and help celebrate the Army's birthday in NYC Ava Sambora puts on an eye-popping display for sizzling photo shoot as she parades her enviable bikini bod in Matibu Daughter of rocker Richie Sambora How doas Adele make YOU feel? Sad songs provide ‘enjoyment, comfort or pain to different people’ Great comfort from seemingly sad songs Daisy Lowe and rumored boyfriend Darius Campbell appear in high spirits as they leave star-studded charity event She is 27 sir Paul McCartney leads tributes as Wings guitarist Henry 7/34

i Case 18-2868, Document 278, 08/09/2019, 2628230, Page9 of 648 6/14/2016 ‘They said they had found photos of me at | Jeffrey’s Palm Beach house,’ she says. ‘[Epstein _ had] hidden cameras watching me the entire time even when | was in the bathroom. | was so embarrassed. ‘t told the FBI that my true purpose was sexual. They told me everything he did was illegal because | was under age.’ (The age of consent in Florida is 18). ‘They said that if it had to go to trial, they'd need me because I'd lived with him and that made me a key witness. { was very afraid, because he had so much power, but eventually | agreed to testify. | was glad he’d finally been found out. He shouldn't be hurting other girls. Following Epstein’s arrest, investigators are believed to have found a list of men’s names on his computer and asked him whether they had been ‘treated’ to sexual encounters with his menage of minors. Conviction ‘He took the Fifth Amendment, refusing to answer, indicating that if he were to answer the question, it could be incriminating,’ a source told The Mail on Sunday. Epstein struck a deal resulting in what commentators characterised as a ‘slap on the wrist’ for him, and ended up serving 13 months of his sentence, much of it in a liberal work-release programme Lawyer Brad Edwards, who represented several of Epstein’s victims, said: ‘Rather than punish him the way they would an average Joe, they sent a clear message that with enough money and power and influence, the system can be bought.’ Virginia was spared her the humiliation of having to go before a jury, and has kept her feelings bottled up until last weekend’s photograph of Andrew with Epstein triggered distressing memories. Virginia says: ‘| am appalled. To me, it’s saying, “We are above the law.” But Jeffrey is a monster.’ Last night, neither Epstein, Ghislaine Maxwell nor Prince Andrew would comment on Virginia’s story. Share or comment on this article Need Business Capital? Get These Rare Historical Photos What Marcia Brady Looks Unsecured Loansin 24 hours That Will Leave You Like Now Is Incredible Snapcap.com Speechiess Definition History Fanatic Case 1:15°CvydseRwWVS’ Decuria DHEIM Fie O64 51 HalPYgOGref 9 McCullough who played on Live and Let Die Bond theme dies aged 72 Remembering his pal Bargain shopper! Barrymore sports colorful silk jacket as she loads up a trolley with knick-knacks at flea market She's a mom-of-two ‘Actually done!’ Arie! Winter arrives to her high school graduation ceremony in form-fitting nude dress A landmark day for the 18-year-old actress Kevin Hart has $500k of possessions stolen as thieves raid his LA home while he’s away in Miami Break-in at his Tarzana home over the weekend ‘Nothing makes me happier’: Alyssa Milano reunitas with Who's The Boss? co-star Judith Light... 24 years after the show ended Catching up No show: Mets pitcher Bartolo Colon skips court hearing over dispute with once-secret 3 ex-girlfriend and their : two Jove children ‘fve embraced the Bi/Queer label lately’: Matilda star Mara Wilson reveals her sexuality on Twitter Also starred in Mrs Doubtfire Prettiest delivery giri ever! Makeup-free Heidi Klum, 43, carries three large coffees in NYC after revealing beau Vito ; gifted her 10 dozen red roses Sizzling Katie Holmes gives a rare glimpse at her sultry side as she poses nude in gorgeous throwback snaps from jewelry campaign She is 37 A Givenchy girl! Mode! Lily Aldridge steps out in | $1,250 designer SWEATSHIRT as she shows off slim legs in NYC Victoria's Secret Angel http:/Avww.dailym ail.co.uk/news/article- 1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.htm! 8/34

Case 18-2868, Document 278, 08/09/2019, 2628230, Page10 of 648 EXHIBIT B

Case 18-2868, Document 278, 08/09/2019, 2628230, Page11 of 648 6/15/2016 Bill Clinton and the 15-year-old ‘masseuse’: | met him twice, claims Epstein's girl | Daily Mail Online Daily Mail com : Home |U.K. News Sports | U.S. Showbiz | Australia | Femail | Health | Science | Money | Video | Travel | Columnists i avne eeee Bt syd eyed Libs oy idee eyes Niesyaer LAs ted 2 j se aa ets fe pie ed are te set $3 ay pin te Bye. ee pate on SAoreen & a pyen ot Ri seagee EX aera 2 t3 fers © gage tg ; TSSE MOTs Mey MOG Mews Arie Pesedines Picturas Mostrasd N SS CARAT ED | YYEP RS LAI : mI x Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill Clinton By SHARON CHURCHER and POLLY DUNBAR FOR MAILONLINE PO en eee AN ONY RINE RAMEE AREAL LLANE N ALAIN DIOS TALE EE PUOOL SN HOSS S SRAAA ERE EARA DUNE SDAM DOPEL INE RIOT OU TARIEL LISIAALD DERE AMY RAS SABANARALN ES ARS RD PE EOSNNCEHEAAARALE ANIM UI ALDINE ELE AREAL AL A BBV DA SARL eetneser AAPHANUS pera erri fae nae aP ornare eRe enateateimnanenne 24 View commen As a New Yorker from humble beginnings, Jeffrey Epstein played on his blue-collar credentials and enormous wealth to extend tentacles of influence throughout America’s liberal political elite. During the outcry over the Epstein case, it emerged that another man with a notorious appetite for young women, Biil Clinton, travelled with Epstein to a number of destinations, including three times on the billionaire’s private aircraft. On one occasion, Epstein flew the former President, Hollywood actor and staunch Democrat Kevin Spacey and another actor friend of Mr Clinton’s, Chris Tucker, to Africa, to ‘discuss AIDS policy’. Claims: Virgir as never ‘tent out’ Epstein, who has donated more than £75,000 over the years to candidates from the Democratic Party, also flew with Mr Clinton in November 2003 to destinations including Russia, Oslo, Hong Kong, Shanghai and Beijing. Yet Virginia Roberts stresses that she was never ‘tent out’ to Mr Clinton. On one occasion, she adds, Epstein did invite two young brunettes to a dinner which he gave on his Caribbean island for Mr Clinton shortly after he left office. But, as far as she knows, the ex-President did not take the bait. ‘’d have been about 17 at the time,’ she says. ‘I flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her. PRET RETALIATION ELLE LESS ILLES ENT OLAS IAAL LAL SHARE THIS RELATED ARTICLES ARTICLE EILEP LO LIER ISE LE ISIN IN INDE SY PFT SEY ES TOE NS TESLA LEER PSI NP LTA SEL IDI ON ECE IES III LE ERIN NE PILES SPREAD A = |. FBI to reopencase oo o Epstein’s Girl Friday http:/Avww.dailym ail.co.uk/news/article- 1363452/Bill-Clinton- 15-year-old-masseuse-I-met-twice-claims-Epsteins-girl.htm! 1/31 a 2 ae

Case 18-2868, Document 278, 08/09/2019, 2628230, Page12 of 648 BNEW OO TAS Es FES oO Dereerrre hin 6Bicohaet SSG a6] Mele! Sine 5 6/15/2016 Case 1:1 against sex offender , friend of Prince... ‘fixer’: Dead tycoon's daughter... NISL ELITES FOL ‘She'd always wanted to fly and Jeffrey paid for her to take lessons, and | remember she was very excited because she got her licence around the first year we met. ‘l used to get frightened flying with her but Bill had the Secret Service with him and | remember him talking about what a good job she did. ‘t only ever met Bill twice but Jeffrey had told me that they were good friends. ‘l asked, “How come?” and he laughed and said, “He owes me some favours.” Maybe he was just joking but it constantly surprised me that people with as much to lose as Bill and [Prince] Andrew weren't more careful. ‘Bill must have known about Jeffrey's girls. There were three desks in the living area of the villa on the island. Speaking out: Virginia, now aged 26, in her new home in Australia ‘They were covered with pictures of Jeffrey shaking hands with famous people and photos of naked girls, including one of me that Jeffrey had at all his houses, lying in a hammock. ‘We all dined together that night. Jeffrey was at the head of the table. Bill was at his left. | sat across from him. Emmy Tayler, Ghisiaine’s blonde British assistant, sat at my right. ‘Ghislaine was at Bill's left and at the left of Ghislaine there were two olive-skinned brunettes who'd flown in with us from New York. ‘ld never met them before. I’d say they were no older than 17, very innocent-looking. ‘They weren't there for me. They weren't there for Jeffrey or Ghislaine because | was there to have sex with Jeffrey on the trip. ‘Maybe Jeffrey thought they would entertain Bill, but | saw no evidence that he was interested in them. He and Jeffrey and Ghislaine seemed to have a very good relationship. Bill was very funny. ‘He made me laugh a few times. And he and ‘Bill must have known about Jeffrey and Ghislaine told blokey jokes and the Jeffrey's girls. There were three brunettes listened politely and giggled. - ; ‘After dinner | gave Jeffrey an erotic massage. | desks in the living area of the don’t remember seeing Bill again on the trip but: Villa on the island... covered with | assume Ghislaine flew him back.’ photos of naked girls’ According to prison records, when Epstein was serving his jail term, his visitors included a longtime - and highly controversial — Clinton acquaintance, Arnold Prosperi. ‘In the final hours of the Clinton presidency, in January 2001, Prosperi was facing three years in prison after being convicted of tax fraud. Mr Clinton commuted his sentence to house arrest. ‘Clinton, Prosperi and Epstein make an odd threesome on the face of it,’ says a law enforcement source. ‘Was Prosperi visiting Epstein as some kind of intermediary for Bill? ‘Maybe Bill wanted to know if Epstein knew anything that could embarrass him. Or did Bill commute Prosperi’s sentence as some kind of favour for Epstein?’ Virginia disclosed that Mr Clinton’s vice-president Al Gore and his wife, Tipper, were also guests of Epstein on his island. Cambridge can't contain her excitement as her horse wins at Royal Ascot races Whooped and cheered Brown Simpson DID have an affair with O's best friend Marcus Allen -and OJ ‘threatened to kil her if she saw him again... one month before her death’ ‘I've been doing him forever:' Awkward moment Sonja Morgan discovers Luann de Lesseps’ ’soul mate’ is her old ‘hook up’ Thomas D'Agostino She really IS a lady in waiting! Amelia Windsor; ~ Tatler’s most beautiful royal - swaps high glamour for WAITRESSING as she helps out at a launch New beau? Ashley Olsen, 30, is romantically linked to artist George Condo, 59 : after they are spotted ‘looking romantic’ at NYC's Mercer Hotel Dad bod! Adam Sandler, 49, shows off his naked chest while wrapped in towel during Miami vacation with his wife of 13 years Couple fooked blissful Kim Kardashian’s naked ambition is taid bare again as she Strips : off to celebrate her post baby body with GQ cover Gave birth in December Kake-gate! Kim Kardashian tries to cheat on family cake makers Hansen's by asking her followers for new bakery recommendations ‘lworked my a** offi’: Kim Kardashian spilis secrets to losing 60ibs after pregnancy as she admits 6am gym sessions and ‘militant diet’ did trick Advertisement http:/Avww.dailym ail.co.uk/news/article-1363452/Bill-Clinton- 15-year-old-masseuse-I-met-twice-claims-Epsteins-girl.htm|

aa Case LS CUOO TASER? RVES O DrRCERE tS BE ABicore Renee BCR IS) OMe Gnigp 5 @ AFP/Getty Images | Guests: Virginia says she also met former Vice President Al Gore, ‘pictured right with Mr Clinton Last summer, the Gores abruptly announced that they were ending their supposedly fairytale marriage and, just weeks later, it emerged that Mr Gore — the famously sanctimonious globalwarming disciple ~ had been accused of trying to force sex on a woman with whom he had booked a therapeutic massage at an Oregon hotel. ‘| had no clue that anything was up,’ Virginia says. The Gores seemed like a beautiful couple when | ‘We just want them to met them. All| knew was that Mr Gore was a friend of Jeffrey's and Ghislaine’ s. Jeffrey didn'task me have anormal lite’: to give him a massage. Blake Lively reveals her parenthood plans now ‘There might have been a couple of other girls there on that trip but | could never have imagined this —_— that baby no.2 is onits guy would do anything wrong. | was planning to vote for him when | turned 18. | thought he was way and why she fell in awesome.’ love with Ryan Reynolds Virginia said that yet another American liberal icon, President Obama’s Middle East peace envoy Senator George Mitchell, frequently visited Epstein’s New York residence. ean stolen Miley yrus and Liam Mr Mitchell, aged 77 ~ who previously led America’s Northern Ireland peace initiative - ‘was very Hemsworth temporarily close to Jeffrey,’ Virginia recalled. ‘He is very clean-cut. You wouldn't think of him being part of go their separate ways... Jeffrey's crew.’ after very public dinner a - date in NYG lvanka Trump shares morning snap of baby Theo watching her get ready as she admits in that she wakes up at §:30am and goes to work with her hair wet They could be sisters! Princess Mary of Denmark and Duchess of Gambridge look strikingly similar as they enjoy a catch up at Royal Ascot Brooke Shields’ stalker GRINS waiking into court with trial entering third day after judge hears actress’s tearful testimony about man coming to her home Mixing business with pleasure! Bodysuit-clad EJ Johnson gets in ‘Scandal: v. S. - authorities want to interview Jeffrey Epstein (left): and may wish to quiz his friend, Prince Andrew some retail therapy ” before filming his yet-toEpstein’s contacts book contains a work and a home telephone number for the senator. air New York reality show Another acquaintance was Israel defence secretary Ehud Barak, whose spokesman told The Mail on Sunday: ‘Mr Barak did attend several small functions in Mr Epstein’s home in New York that were on usually attended by leading businessman, university presidents, Nobel Prize Laureates and Seth Myers ‘bans ; : ; Trump from appearing prominent public figures. on NBC's Late Night http:/Avww.dailymail.co.uk/news/article- 1363452/Bill-Clinton- 15-year-old-masseuse-!-met-twice-claims-Epsteins-girl.htm| 431

Case 18-2868, Document 278, 08/09/2019, 2628230, Page14 of 648 6/15/2016 Epstein’s many Hollywood pals include Matt Groening, creator of The Simpsons. ‘Jeffrey once had me give Matt a foot massage when he was flying on the jet with us,’ Virginia says. ‘He laughed and did drawings of Bart and Homer for my little brother and my dad. ‘| also met Naomi Campbell at a birthday party of hers on a yacht in the South of France. She is a friend of Ghislaine’s but she was a real bitch to me. ‘She was very fake. She turned away from me when we were introduced by Ghislaine and Jeffrey. ‘Donald Trump was also a good friend of Jeffrey's. He didn’t partake in sex with any of us but he flirted with me. He'd laugh and tell Jeffrey, “You’ve got the life.” ' Paim Beach Police say Epstein seemed utterly unfazed by the allegations against him when they began their long and detailed investigation. i i he A : U.S. Secretary of State Hilary Clinton, frequently visitad Epsteings New York residence, Virginia also claims But he also took his defence very seriously indeed. Epstein engaged his friend, the Harvard law professor Alan Dershowitz — whose celebrity clients have included Mike Tyson, Patty Hearst, Claus von Bulow and O.J. Simpson — to run his legal defence. He also employed a firm of private investigators to investigate the backgrounds of the girls. Detectives painstakingly built a case which they believed showed that Epstein systematically paid teenage girls to recruit other teenage girls to his sex ring. However, as the investigation continued, they found that Epstein’s team had already spoken to key witnesses, suggesting that the financier would reward those who helped him. In addition, Epstein’s defence team agreed to the unusual move of suggesting that the alleged victims sue Epstein in the civil courts. The result was a plea bargain in which Epstein admitted a single charge of soliciting an underage giri for prostitution — a deal which infuriated many police officers who worked on the case. More than 20 of Epstein’s girls are said to have sued him for damages. At least 17 have settled out of court. Mr Clinton, Mr Gore and Mr Mitchell were all contacted about their friendship with Epstein but declined to comment. Share or comment on this article Yolanda Hadid QUITS | Case 1:18 @}oo 7h is VES OD erecta hs HEGicorihins BSF) Deel Sor 5 show - but admits the presidential hopeful wasn't going to come on anyway Real Housewives of Beverly Hills to ‘bring back privacy’ to her life after dramatic season that documented her divorce and accusations she was faking illness Victoria Beckham shows a hint of sideboob and flash of leg as she flaunts her sartorial sass for cover of Vogue Korea Striking shoot A mellow day! Rumer Willis dresses downina grey maxi dress as she hangs out with a friend in West Hollywood Taking a break from the presidential campaign Catherine Zeta-Jones’ daughter Carys is her doppeigdnger as the pair arrive in London with Michael Douglas and son Dylan Family trip Stephen Colbert compares Trumptoa NAZI as he draws a swastika on chalkboard while trying to ‘figure out’ Obama’s response to Orlando massacre Grieving Adam Levine is pictured playing golf in first outing since Christina Grimmie's death... after offering to pay for the Voice star’s funeral Does North West have herowngiam squad? =; Kim Kardashian ‘hires daughter $5k a week team including hairstylist and manicurist’ The smile’s back! XS £ DemiLovato appears == | happy at airport while dime looking chic in olive coat | as sherecovers from Wilmer Valderrama shock split Wore classic combo ‘fm not killing off Harrison Ford’: Steven Spielberg reveals he won't end indiana Jones’ life in next film as he gives rare interview Good news for Ford! http:/Avww.dailymail.co.uk/news/article-1363452/Bill-Clinton- 15-year-old-masseuse-|-met-twice-claims-Epsteins-girl.htm! 4/31

Case 18-2868, Document 278, 08/09/2019, 2628230, Page15 of 648 EXHIBIT C

Case 18-2868, Document 278, 08/09/2019, 2628230, Page16 of 648 | Share this_ + R Hub | Subscribe by Email... page iene Neve t ar iretenininedt i Snes. TE meine a Politics 1s Science a Feces | Odd News | Health h{l Law More Sao Statement on Behalf of Ghislaine Maxwell BY DEVONSHIRES SOLICITORS, PRNE WRDONESDAY, MARCH o, 2011 LONDON, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. It is unacceptable that letters sent by Ms Maxwell's legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. bind SOGGSUR MASEL In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers. “I understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop,” said Ghislaine Maxwell. “A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mop: +44=-7778=755=251 Email: ross@acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: +44-203008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com Kiled under: Government and Policy, Law, Media "= : | NEWS Pa bei ner Bo ESOS - . CSA Group Selects Frankfurt, Germany: for . : ° new European Headquarters } The First International Gateway to Africa _ . Conference in Geueva: Africa&apos;s ©. . | Challenges Today and Tomorrow | eRne 10 "NEWS -. Tech Mahindra Opensa | a _ . new Development — ee 3 . Centrein Bonn, . . .. Germany "Website Optimisation - "and Internet Marketing - Central Saint Martins and Method Launch From Weblinx - . Accelerator to Drive Innovation and Support ne - UK EconomicGrowth = = - ............. Sir Paul McCartney a : ; ; Supports BUAV - . North East Lincolnshire Council Campaign to end Cruel Emplovees&apos; Ideas Win Votes SM TWT F S&S 20 2122 23 24 25 26 2728 12 3 4 5 6 7 8 910 Ill 12 EXHIBIT 4 . Giuttre AGREN BLANDO REPORTING 5/alie KAM GTUFFRE00 1067

Case 18-2868, Document 278, 08/09/2019, 2628230, Page1/ of 648 EXHIBIT D

Case 18-2868, Document 278, 08/09/2019, 2628230, Page18 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES / JANE DOE #3 AND JANE DOE #4’s CORRECTED MOTION PURSUANT TO RULE 21 FOR JOINDER IN ACTION COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”), by and through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21 to join this action, on the condition that they not re-litigate any issues already litigated by Jane Doe #1 and Jane Doe #2 (also referred to as “the current victims”). The new victims have suffered the same violations of their rights under the Crime Victims’ Rights Act (CVRA) as the current victims. Accordingly, they desire to join in this action to vindicate their rights as well. Because the new victims will not re-litigate any issues previously litigated by the current victims (and because they are represented by the same legal counsel as the current victims), the Government will not be prejudiced if the Court grants the motion. The Court may “at any time” add new parties to the action, Fed. R. Civ. P. 21. Accordingly, the Court should grant the motion.’ FACTUAL BACKGROUND ' As minor victims of sexual offenses, Jane Doe #3 and Jane Doe #4 desire to proceed by way of pseudonym for the same reasons that Jane Doe #1 and Jane Doe #2 proceeded in this fashion. Counsel for the new victims have made their true identities known to the Government. l GIUFFRE 004288 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page19 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 2 of 14 As the Court is aware, more than six years ago, Jane Doe #1 filed the present action against the Government, alleging a violation of her rights under the CVRA, 18 U.S.C. § 3771. DE1. She alleged that Jeffrey Epstein had sexually abused her and that the United States had entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her rights. At the first court hearing on the case, the Court allowed Jane Doe #2 to also join the action. Both Jane Doe #1 and Jane Doe #2 specifically argued that the government had failed to protect their CVRA rights (inter alia) to confer, to reasonable notice, and to be treated with fairness. In response, the Government argued that the CVRA rights did not apply to Jane Doe #1 and Jane Doe #2 because no federal charges had ever been filed against Jeffrey Epstein. The Court has firmly rejected the United States’ position. In a detailed ruling, the Court concluded that the CVRA extended rights to Jane Doe #1 and Jane Doe #2 even though federal charges were never filed. DE 189, The Court explained that because the NPA barred prosecution of crimes committed against them by Epstein, they had “standing” to assert violations of the CVRA rights. Jd. The Court deferred ruling on whether the two victims would be entitled to relief, pending development of a fuller evidentiary record. Jd. Two other victims, who are in many respects similarly situated to the current victims, now wish to join this action. The new victims joining at this stage will not cause any delay and their joinder in this case is the most expeditious manner in which to pursue their rights. Because the background regarding their abuse is relevant to the Court’s assessment of whether to allow them to join, their circumstances are recounted here briefly. Jane Doe #3’s Circumstances GIUFFRE 004289 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page20 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 3 of 14 As with Jane Doe #1 and Jane Doe #2, Jane Doe #3 was repeatedly sexually abused by Epstein. The Government then concealed from Jane Doe #3 the existence of its NPA from Jane Doe #3, in violation of her rights under the CVRA, If allowed to join this action, Jane Doe #3 would prove the following: In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator in his sexual abuse and sex trafficking scheme. In fact, it became known to the government that Maxwell herself regularly participated in Epstein’s sexual exploitation of minors, including Jane Doe #3. Maxwell persuaded Jane Doe #3 (who was then fifteen years old) to come to Epstein’s mansion in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children (including Jane Doe #1 and Jane Doe #2). When Jane Doe #3 began giving Epstein a “massage,” Epstein and Maxwell turned it into a sexual encounter, as they had done with many other victims. Epstein then became enamored with Jane Doe #3, and with the assistance of Maxwell converted her into what is commonly referred to as a “sex slave.” Epstein kept Jane Doe #3 as his sex slave from about 1999 through 2002, when she managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years. From 1999 through 2002, Epstein frequently sexually abused Jane Doe #3, not only in West Palm Beach, but also in New York, New Mexico, the U.S. Virgin Islands, in international airspace on his Epstein’s private planes, and elsewhere. Epstein also sexually trafficked the then-minor Jane Doe, making her available for sex to politically-connected and financially-powerful people. Epstein’s purposes in “lending” Jane Doe (along with other young girls) to such powerful people were to ingratiate himself with them for 3 GIUFFRE 004290 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page21 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 4 of 14 business, personal, political, and financial gain, as well as to obtain potential blackmail information. One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein’s and well-known criminal defense attorney. Epstein required Jane Doe #3 to have sexual relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but also on private planes, in New York, New Mexico, and the U.S. Virgin Islands. In addition to being a participant in the abuse of Jane Doe #3 and other minors, Deshowitz was an eye-witness to the sexual abuse of many other minors by Epstein and several of Epstein’s co-conspirators. Dershowitz would later play a significant role in negotiating the NPA on Epstein’s behalf. Indeed, Dershowitz helped negotiate an agreement that provided immunity from federal prosecution in the Southern District of Florida not only to Epstein, but also to “any potential coconspirators of Epstein.” NPA at 5. Thus, Dershowitz helped negotiate an agreement with a provision that provided protection for himself against criminal prosecution in Florida for sexually abusing Jane Doe #3. Because this broad immunity would have been controversial if disclosed, Dershowitz (along with other members of Epstein’s defense team) and the Government tried to keep the immunity provision secret from all of Epstein’s victims and the general public, even though such secrecy violated the Crime Victims’ Rights Act. Ghislaine Maxwell was another person in Epstein’s inner circle and a co-conspirator in Epstein’s sexual abuse. She was someone who consequently also appreciated the immunity granted by the NPA for the crimes she committed in Florida. In addition to participating in the sexual abuse of Jane Doe #3 and others, Maxwell also took numerous sexually explicit pictures 4 GIUFFRE 004291 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page22 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 5 of 14 of underage girls involved in sexual activities, including Jane Doe #3. She shared these photographs (which constituted child pornography under applicable federal laws) with Epstein. The Government is apparently aware of, and in certain instances possesses some of these photographs. Perhaps even more important to her role in Epstein’s sexual abuse ring, Maxwell had direct connections to other powerful individuals with whom she could connect Epstein. For instance, one such powerful individual Epstein forced Jane Doe #3 to have sexual relations with was a member of the British Royal Family, Prince Andrew (a/k/a Duke of York). Jane Doe #3 was forced to have sexual relations with this Prince when she was a minor in three separate geographical locations: in London (at Ghislaine Maxwell’s apartment), in New York, and on Epstein’s private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged girls). Epstein instructed Jane Doe #3 that she was to give the Prince whatever he demanded and required Jane Doe #3 to report back to him on the details of the sexual abuse. Maxwell facilitated Prince Andrew’s acts of sexual abuse by acting as a “madame” for Epstein, thereby assisting in internationally trafficking Jane Doe #3 (and numerous other young girls) for sexual purposes. Another person in Epstein’s inner circle of friends (who becomes apparent with almost no investigative effort) is Jean Luc Brunel. Epstein sexually trafficked Jane Doe #3 to Jean Luc Brunel many times. Brunel was another of Epstein’s closest friends and a regular traveling companion, who had many contacts with young girls throughout the world. Brunel has been a model scout for various modeling agencies for many years and apparently was able to get U.S. passports for young girls to “work” as models. He would bring young girls (ranging to ages as 5 GIUFFRE 004292 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page23 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 6 of 14 young as twelve) to the United States for sexual purposes and farm them out to his friends, especially Epstein. Brunel would offer the girls “modeling” jobs. Many of the girls came from poor countries or impoverished backgrounds, and he lured them in with a promise of making good money. Epstein forced Jane Doe #3 to observe him, Brunel and Maxwell engage in illegal sexual acts with dozens of underage girls. Epstein also forced Jane Doe #3 to have sex with Brunel on numerous occasions, at places including Epstein’s mansion in West Palm Beach, Little St. James Island in the U.S. Virgin Islands (many including orgies that were comprised of other underage girls), New York City, New Mexico, Paris, the south of France, and California. Epstein also trafficked Jane Doe #3 for sexual purposes to many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders. Epstein required Jane Doe #3 to describe the events that she had with these men so that he could potentially blackmail them. The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the NPA. Moreover, even a rudimentary investigation of Jane Doe #3’s relationship to Epstein would have revealed the fact that she had been trafficked throughout the United States and internationally for sexual purposes. Nonetheless, the Government secretly negotiated a non-prosecution agreement with Epstein precluding any Federal prosecution in the Southern District of Florida of Epstein and his co-conspirators. As with Jane Doe #1, and Jane Doe #2, the Government concealed the non-prosecution agreement from Jane Doe #3 — all in violation of her rights under the CVRA — to avoid Jane Doe #3 from raising powerful objections to the NPA that would have shed tremendous public light on Epstein GIUFFRE 004293 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page24 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 7 of 14 and other powerful individuals and that would likely have been prevented it from being concluded in the secretive manner in which it was. Jane Doe #4’s Circumstances If permitted to join this action, Jane Doe #4 would allege, and could prove at trial, that she has CVRA claims similar to those advanced by Jane Doe #1 and Jane Doe #2, based on the following: As with the other Jane Does, Jane Doe #4 was repeatedly sexually abused by Epstein. In or around the summer of 2002, Jane Doe #4, an economically poor and vulnerable sixteen-yearold child, was told by another one of Epstein’s underage minor sex abuse victims, that she could make $300 cash by giving an old man a massage on Palm Beach. An acquaintance of Jane Doe #4 (also a minor sexual abuse victim of Epstein) telephoned Epstein and scheduled Jane Doe #4 to go to Epstein’s house to give him a massage. During that call, Epstein himself got on the phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to his mansion in Palm Beach. Jane Doe #4 then went to Epstein’s mansion and was escorted upstairs to Epstein’s large bathroom by one of Epstein’s assistants. Shortly thereafter Jeffrey Epstein emerged and lay face down on the table and told Jane Doe #4 to start massaging him. Epstein asked Jane Doe #3 her age and she told him she had recently turned sixteen, Epstein subsequently committed illegal sexual acts against Jane Doe #4 on many occasions, Epstein used a means of interstate communication {i.e., a cell phone) to arrange for these sexual encounters. Epstein also frequently travelled in interstate commerce (i.e., on his personal jet) for purposes of illegally sexually abusing Jane Doe #4. 7 GIUFFRE 004294 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page25 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 8 of 14 The acts Epstein committed against Jane Doe #4, constituted numerous federal sex offenses, some of which do not carry a statute of limitations and thus are not time-barred. See 18 U.S.C. § 3283. And these offenses were the kinds of offenses that the Federal Bureau of Investigation (FBI) and U.S. Attorney’s Office for the Southern District of Florida were pursuing in 2007. So far as Jane Doe #4 is aware, the U.S. Attorney’s Office made no serious effort to locate her. Instead, after identifying approximately forty separate underage sexually abused victims, and apparently preparing a 53-page federal indictment and with full awareness of the existence of many victims like Jane Doe #4 — unidentified and not interviewed — it entered into a non-prosecution agreement barring prosecution of Epstein’s federal crimes against these victims. This is contrary to the Government’s normal approach in prosecuting federal sex offenses. It also violated Jane Doe #4’s rights under the CVRA, including the fact that she had a “reasonable” right to confer with the U.S. Attorney’s Office before they entered into an agreement with a sex offender barring prosecution of him for the crimes he committed against her. 18 U.S.C. § 3771(a)(5). MOTION FOR JOINDER Jane Doe #3 and Jane Doe #4 now both move to join this action filed by Jane Doe #1 and Jane Doe #2, pursuant to Rule 21 of the Federal Rules of Civil Procedure. Rule 21 provides that “fo]n motion or on its own, the court may at any time, on just terms, add... a party.” Rule 21 “grants the court broad discretion to permit a change in the parties at any stage of a litigation.” Ford vy. Air Line Pilots Ass’n Int'l, 268 F. Supp. 2d 271, 295 (E.D.N.Y. 2003) (internal quotation omitted). The new victims should be allowed to join the current victims in this action under Rule 21. GIUFFRE 004295 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page26 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 9 of 14 The new victims will establish at trial that the Government violated their CVRA rights in the same way as it violated the rights of the other victims. The new victims’ participation in this case is important because it appears that the Government intends to raise a factual defense that somehow it did keep Jane Doe #1 and Jane Doe #2 properly informed of what was happening in the criminal prosecution. Of course, if four victims all testify consistently that they were not properly informed by the Government (as we believe they will), that provides a stronger case for a CVRA violation. In addition, Jane Doe #3 and Jane Doe #4’s participation is relevant to a defense the Court has allowed the Government to raise. The Court has previously ruled that the victims’ request for rescission of the NPA “implicates a fact-sensitive equitable defense which must be considered in the historical factual context of the entire interface between Epstein, the relevant prosecutorial authorities and the federal offense victims — including an assessment of the allegation of a deliberate conspiracy between Epstein and federal prosecutors to keep the victims in the dark on the pendency of negotiations between Epstein and federal authorities until well after the fact and presentation of the non-prosecution agreement to them as a fait accompli.” DE 189 at 12 n.6 (emphasis added). Jane Doe #3’s and Jane Doe #4’s participation in this case will help to show what the “entire interface” was between the Government and the victims and thus to respond to the Government’s estoppel arguments as well as other defenses that it appears to be preparing to raise. See, e.g., DE 62 (S2-page response from the Government to the victim’s summary judgment motion, raising numerous factually-based and other arguments against the victim’s position). GIUFFRE 004296 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page27 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 10 of 14 Jane Doe #3’s and Jane Doe #4’s participation is also directly relevant to the discovery disputes currently pending in this case. The Government has raised various relevancy objections to the documents that Jane Doe #1] and Jane Doe #2 are attempting to obtain. The current victims have responded by explaining how these documents are relevant, including explaining how these documents might bear on the way in which Epstein used his powerful political and social connections to secure a favorable plea deal, as well as provide proof of the Government’s motive to deliberately fail to investigate certain aspects of the victims’ claims in an effort to maintain the secrecy of the facts and resolve the case without the victims’ knowledge. See, e.g., DE 266 at 6-10. Jane Doe #3 and Jane Doe #4’s participation will help prove the relevancy of these requests, as well as the need for those requests. One clear example is Request for Production No. 8, which seeks documents regarding Epstein’s lobbying efforts to persuade the Government to give him a more favorable plea arrangement and/or non-prosecution agreement, including efforts on his behalf by Prince Andrew and former Harvard Law Professor Alan Dershowitz. Jane Doe #1 and Jane Doe #2 have alleged these materials are needed to prove their allegations that, after Epstein signed the non-prosecution agreement, his performance was delayed while he used his significant social and political connections to lobby the Justice Department te obtain a more favorable plea deal. See, e.g., DE 225 at 7-8 (discussing DE 48 at 16-18). Jane Doe #3 has directly person knowledge of Epstein’s connection with some of these powerful people and thus how Epstein might have used them to secure favorable treatment. Adding two new victims to this case will not delay any of the proceedings. They will simply join in motions that the current victims were going to file in any event. For example, the 10 GIUFFRE 004297 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page28 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 11 of 14 new victims will simply join in a single summary judgment motion that the current victims anticipate filing after discovery has been completed. Nor will adding the new victims prejudice the United States. As the court is aware, this Court is still in its initial discovery stage. The Court is currently considering whether to reject the Government’s assertion of privilege over documents regarding the case. See DE 265 (victims’ reassertion of objections to the Government privilege claims). The new victims do not seek any additional discovery beyond that previously sought by the current victims,” Accordingly, the United States will not be prejudiced or burdened by adding them to this case. The CVRA does not contain any statute of limitations for filing an action to enforce rights under the statute. Accordingly, were the Court to deny this motion, the result might be that the new victims would then be forced to file a separate suit raising their claims, which would then possibly proceed on a separate litigation track. Rather than require duplicative litigation, the Court should simply grant their motion to join. Jane Doe #1 and Jane Doe #2 support the joinder motion. Counsel for the victims have discussed this motion with the Government at length in an effort to avoid any need to file a substantive pleading on the issue. Counsel for the victims asked the Government during the summer for its position on joinder. The Government, however, took the matter under advisement for months. Ultimately, after several inquiries from victims counsel, the Government indicated without explanation that it opposes this motion. Counsel for the victims has requested a meeting with the Government on this issue, which will hopefully occur in * Jane Doe #3 and Jane Doe #4 have asked the Government to provide them with the record of their statements that they provided to the FBI. These FBI 302’s should be only a few pages long. 11 GIUFFRE 004298 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page29 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 12 of 14 January. In the meantime, however, counsel for the victims believe that it is no longer appropriate to delay filing this motion and accordingly file it at this time. Because the Government is apparently opposing this motion, Jane Doe #3 and Jane Doe #4 have described the circumstances surrounding their claims so that the Court has appropriate information to rule on the motion. GIUFFRE 004299 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page30 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 13 of 14 CONCLUSION Jane Doe #3 and Jane Doe #4 should be allowed to join this action, pursuant to Rule 21 of the Federal Rules of Civil Procedure. Their joinder should be conditioned on the requirement that they not re-litigate any issues previously litigated by Jane Doe #1 and Jane Doe #2. A proposed order to that effect is attached to this pleading. DATED: January 2, 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mail: brad@pathtojustice.com And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah” 332 S. 1400 E. Salt Lake City, UT 84112 Telephone; 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu Attorneys for Jane Doe #1 and Jane Doe #2 " This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah GIUFFRE 004300 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page31 of 648 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 14 of 14 CERTIFICATE OF SERVICE I certify that the foregoing document was served on January 2, 2015, on the following using the Court’s CM/ECF system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: Dexter. Lee@usdoj.gov E-mail: ann.marie.c. villafana@usdoj.gov Attorneys for the Government /s/ Bradley J. Edwards GIUFFRE 004301 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page32 of 648 EXHIBIT E

Case 9:08-c¥20736-RAH8, Docwrnent 32a, OS Herealh LOS EihcRaGeAMPIAHH Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-KAM JANE DOE | and JANE DOE 2, Petitioners, VS. UNITED STATES OF AMERICA, Respondent. j ORDER DENYING PETITIONERS’ MOTION TO JOIN UNDER RULE 21 AND MOTION TO AMEND UNDER RULE 15 This cause is before the Court on Jane Doe 3 and Jane Doe 4’s Corrected Motion Pursuant to Rule 21 for Joinder in Action (“Rule 21 Motion”) (DE 280), and Jane Doe | and Jane Doe 2’s Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners (“Rule 15 Motion”) (DE 311). Both motions are ripe for review. For the following reasons, the Court concludes that they should be denied. I. Background This is an action by two unnamed petitioners, Jane Doe | and Jane Doe 2, seeking to prosecute a claim under the Crime Victims’ Rights Act (CVRA), 18 U.S.C. § 3771. (DE 1). Generally, they allege that the respondent Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein, who subjected them to various sexual crimes while they were minors. (Id.). Petitioners initiated this action in July 2008. (Id.).

Case 9:08-cV-287 36-KSN4, Document 32a, OSlerealsh EOS? BiddReged4MT/IZIHS Page 2 of 10 On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280). Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. (Id. at 11). Jane Doe 3 and Jane Doe 4 argue that they “have suffered the same violations of their rights under the [CVRA] as the” Petitioners, and they “desire to join in this action to vindicate their rights as well.” (Id. at 1). The Government vehemently opposes joinder under Rule 21. (DE 290). The Government argues that Rule 15 1s the proper procedural device for adding parties to an action, not Rule 21. (Id. at 1). “{O]ut of an abundance of caution,” Petitioners filed a motion to amend their petition under Rule 15, conforming the petition to the evidence and adding Jane Doe 3 and Jane Doe 4 as petitioners. (DE 311 at 2). The Government opposes the Rule 15 Motion as well. (DE 314). Among other things, the Government argues that amending the petition to include Jane Doe 3 and Jane Doe 4 should be denied because of their undue delay in seeking to join the proceedings, and the undue prejudice that amendment will cause. (Id.). After considering the parties’ submissions and the proposed amended petition, the Court finds that justice does not require amendment in this instance and exercises its discretion to deny the amendment. II. Discussion “The decision whether to grant leave to amend a complaint is within the sole discretion of the district court.” Laurie v. Ala. Ct. Crim. Apps., 256 F.3d 1266, 1274 (11th Cir. 2001). “The court should freely give leave when justice so requires.” Fed. R. Civ. P. 15(a)(2). Justice does not require amendment in several instances, “includ{ing] undue delay, bad faith, dilatory motive

Case 9:08-c¥20736-RAN, Docwrnent 32a, OS Werealh EOS SihcRageAMPIEHH Page 3 of 10 on the part of the movant, . . . undue prejudice to the opposing party by virtue of allowance of the amendment, [and] futility of amendment.’” Laurie, 256 F.3d at 1274 (quoting Foman v. Davis, 371 U.S. 178, 182 (1962)). In addition to considering the effect of amendment on the parties, the court must consider “the importance of the amendment on the proper determination of the merits of a dispute.” 6 Wright & Miller, Fed. Prac. & Fed. P. § 1488, p. 814 (3d ed. 2010). Justice does not require amendment where the addition of parties with duplicative claims will not materially advance the resolution of the litigation on the merits. See Herring v. Delta Air Lines, Inc., 894 F.2d 1020, 1024 (9th Cir. 1989). A. Rule 21 Motion Jane Doe 3 and Jane Doe 4’s first attempt to join in this proceeding was brought under Rule 21. (DE 280). “If parties seek to add a party under Rule 21, courts generally use the standard of Rule 15, governing amendments to pleadings, to determine whether to allow the addition.” 12 Wright & Miller, Fed. Prac. & Fed. P., p. 432 (3d ed. 2013); see also Galustian v. Peter, 591 F.3d 724, 729-30 (4th Cir. 2010) (collecting cases and noting that Rule 15(a) applies to amendments seeking to add parties); Frank v. U.S. West, Inc., 3 F.3d 1357, 1365 (10th Cir. 1993) (“A motion to add a party is governed by Fed. R. Civ. P. 15(a)... .”). Rule 21, “Misjoinder and Non-joinder of Parties,” provides the court with a tool for correcting the “muisjoinder” of parties that would otherwise result in dismissal. Fed. R. Civ. P. 21. Insofar as Rule 21 “relates to the addition of parties, it is intended to permit the bringing in of a person, who through inadvertence, mistake or for some other reason, had not been made a party and whose presence as a party is later found necessary or desirable.” United States v. Com. Bank of N. Am., 31 F.R.D. 133, 135 (S.D.N.Y. 1962) (internal quotation marks omitted).

Case 9:08-c¥20736-RAH8, Docwrnent 32a, OS Werealh EOS2EihcRageAMPIAHH Page 4 of 10 In their Rule 21 Motion, Jane Doe 3 and Jane Doe 4 do not claim that they were omitted from this proceeding due to any “inadvertence” or “mistake” by Petitioners; rather, they seek to join this proceeding as parties that could have been permissively joined in the original petition under Rule 20 (“Permissive Joinder of Parties”). As courts generally use the standards of Rule 15 to evaluate such circumstances, the Court will consider the joinder issue as presented in the Rule 15 Motion.’ The Court will consider the arguments presented in the Rule 21 Motion as if they are set forth in the Rule 15 Motion as well. Because the arguments are presented in the Rule 15 Motion (and because the Court is denying the Rule 15 Motion on its merits, as discussed below), the Rule 21 Motion will be denied. The Court also concludes that portions of the Rule 21 Motion and related filmgs should be stricken from the record. Pending for this Court’s consideration is a Motion for Limited Intervention filed by Alan M. Dershowitz, who seeks to intervene to “strike the outrageous and impertinent allegations made against him and [to] request[] a show cause order to the attorneys that have made them.” (DE 282 at 1). The Court has considered Mr. Dershowitz’s arguments, but it finds that his intervention is unnecessary as Federal Rule of Civil Procedure 12(f) empowers the Court “on its own” to “strike from a pleading an insufficient defense or any redundant, immaterial, impertinent, or scandalous matter.” Fed. R. Civ. P. 12(f). Petitioners’ Rule 21 Motion consists of relatively little argumentation regarding why the Court should permit them to join in this action: they argue that (1) they were sexually abused by ' The Court notes that, regardless of which motion it considers, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4

Case 9:08-c¥26736-RAH8, Docwrnent 32a, OS Werealh EOS SihcRage4HOPIAH Page 5 of 10 Jeffrey Epstein, and (2) the Government violated their CVRA rights by concealing the nonprosecution agreement with them. (DE 280 at 3; see id. at 7-8). However, the bulk of the Rule 21 Motion consists of copious factual details that Jane Doe 3 and Jane Doe 4 “would prove” “[i]f allowed to join this action.” (Id. at 3, 7). Specifically, Jane Doe 3 proffers that she could prove the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein sexually trafficked her to several high-profile non-party individuals, “imcluding numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.” (Id. at 3-6). She names several individuals, and she offers details about the type of sex acts performed and where they took place. (See id. at 5)? At this juncture in the proceedings, these lurid details are unnecessary to the determination of whether Jane Doe 3 and Jane Doe 4 should be permitted to join Petitioners’ claim that the Government violated their rights under the CVRA. The factual details regarding with whom and where the Jane Does engaged in sexual activities are immaterial and impertinent to this central claim (1.e., that they were known victims of Mr. Epstein and the Government owed them CVRA duties), especially considering that these details involve non-parties who are not related to the respondent Government. These unnecessary details shall be stricken. The original Rule 21 Motion (DE 279) shall be stricken in its entirety, as it is wholly superseded by the “corrected” version of the Rule 21 Motion (DE 280). From the corrected Rule 21 Motion, the Court shall strike all factual details regarding Jane Doe 3 between the following sentences: “The Government then concealed from Jane Doe #3 the existence of its NPA from * Jane Doe 4’s proffer is limited to sexual acts between Mr. Epstein and herself. (See DE 280 at 7-8).

Case 9:08-c¥26736-RAH8, Docwrnent 32a, OS Werealh EOS EihcRaGeAMPIAHH Page 6 of 10 Jane Doe #3, in violation of her rights under the CVRA” (id. at 3); and “The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim 1n the attachment to the NPA” (id. at 6). As none of Jane Doe 4’s factual details relate to non-parties, the Court finds it unnecessary to strike the portion of the Rule 21 Motion related to her circumstances. Regarding the Declaration in support of Petitioners’ response to Mr. Dershowitz’s motion to intervene (DE 291-1), the Court shall strike paragraphs 4, 5, 7, 11, 13, 15, 19 through 53, and 59, as they contain impertinent details regarding non-parties. Regarding the Declaration of Jane Doe 3 1n support of the Rule 21 Motion (DE 310-1), the Court shall strike paragraphs 7 through 12, 16, 39, and 49, as they contain impertinent details regarding nonparties. Jane Doe 3 is free to reassert these factual details through proper evidentiary proof, should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a matter presented for the Court’s consideration. As mentioned, Mr. Dershowitz moves to intervene “for the limited purposes of moving to strike the outrageous and impertinent allegations made against him and requesting a show cause order to the attorneys that have made them.” (DE 282 at 1). As the Court has taken it upon itself to strike the impertinent factual details from the Rule 21 Motion and related filings, the Court concludes that Mr. Derschowitz’s intervention in this case 1s unnecessary. Accordingly, his motion to intervene will be denied as moot.’ Regarding whether a show cause order should * This also moots Mr. Dershowitz’s Motion for Leave to File Supplemental Reply in Support of Motion for Limited Intervention. (DE 317). Denying Mr. Dershowitz’s motion to intervene also renders moot Petitioners’ motion (DE 292) to file a sealed document supporting its response to Mr. Dershowitz’s motion. It will accordingly be denied as moot, and DE 293 (the sealed response) will be stricken from the record.

Case 9:08-cV-28736-KSN4, Document 324, OS ered lsh FOS? BiddReged4MTI AS Page 7 of 10 issue, the Court finds that its action of striking the lurid details from Petitioners’ submissions 1s sanction enough. However, the Court cautions that all counsel are subject to Rule 11’s mandate that all submissions be presented for a proper purpose and factual contentions have evidentiary support, Fed. R. Civ. P. 11(b)(1) and (3), and that the Court may, on its own, strike from any pleading “any redundant, immaterial, impertinent, or scandalous matter,” Fed. R. Civ. P. 12(f). B. Rule 15 Motion Between their two motions (the Rule 21 Motion and Rule 15 Motion), Jane Doe 3 and Jane Doe 4 assert that “they desire to join in this action to vindicate their rights [under the CVRA] as well.” (DE 280 at 1). Although Petitioners already seek the invalidation of Mr. Epstein’s non-prosecution agreement on behalf of all “other similarly-situated victims” (DE 189 at 1; DE 311 at 2, 12, 15, 18-19), Jane Doe 3 and Jane Doe 4 argue that they should be fellow travelers in this pursuit, lest they “be forced to file a separate suit raising their claims” resulting in “duplicative litigation” (DE 280 at 11). The Court finds that justice does not require adding new parties this late in the proceedings who will raise claims that are admittedly “duplicative” of the claims already presented by Petitioners. The Does’ submissions demonstrate that it is entirely unnecessary for Jane Doe 3 and Jane Doe 4 to proceed as parties 1n this action, rather than as fact witnesses available to offer relevant, admissible, and non-cumulative testimony. (See, e.g., DE 280 at 2 (Jane Doe 3 and Jane Doe 4 “are in many respects similarly situated to the current victims”), 9 (“The new victims will establish at trial that the Government violated their CVRA rights in the same way as It violated the rights of the other victims.”), 10 (Jane Doe 3 and Jane Doe 4 “will simply join in motions that the current victims were going to file in any event.”), 11 (litigating Jane Doe 3 and

Case 9:08-c¥20736-RAH8, Docwrnent 32a, OS Werealh EOS EihcRAaGCAMPIEHH Page 8 of 10 Jane Doe 4’s claims would be “duplicative”); DE 298 at 1 n.1 (“As promised . . . Jane Doe No. 3 and Jane Doe No. 4 do not seek to expand the number of pleadings filed in this case. If allowed to join this action, they would simply support the pleadings already being filed by Jane Doe No. 1 and Jane Doe No. 2.”); DE 311 at 5 n.3 (“[A]ll four victims (represented by the same legal counsel) intend to coordinate efforts and avoid duplicative pleadings.”), 15 (Jane Doe 3 and Jane Doe 4 “challenge the same secret agreement 1.e., the NPA that the Government executed with Epstein and then concealed from the victims. This is made clear by the proposed amendment itself, in which all four victims simply allege the same general facts.”)). As the Does argue at length in their Rule 15 Motion, Jane Doe 1’s original petition “specifically allege|s]| that the Government was violating not only her rights but the rights of other similarly-situated victims.” (DE 311 at 2). The Court fails to see why the addition of “other similarly-situated victims” 1s now necessary to “vindicate their rights as well.” (DE 280 at 1). Of course, Jane Doe 3 and Jane Doe 4 can participate in this litigated effort to vindicate the rights of similarly situated victims there is no requirement that the evidentiary proof submitted in this case come only from the named parties. Petitioners point out as much, noting that, regardless of whether this Court grants the Rule 15 Motion, “they will call Jane Doe No. 3 as a witness at any trial.” (DE 311 at 17n.7). The necessary “participation” of Jane Doe 3 and Jane Doe 4 1n this case can be satisfied by offering their properly supported and relevant, admissible, and non-cumulative testimony as needed, whether through testimony at trial (see DE 280 at 9) or affidavits submitted to support the relevancy of discovery requests’ (see * The non-party Jane Does clearly understand how to submit affidavits. (See DEs 291-1, 310-1).

Case 9:08-c¥20736-RAH8, Docwrnent 32a, OS Werealh EOS SihcRage4oViAHt Page 9 of 10 id. at 10). Petitioners do not contend that Jane Doe 3 and Jane Doe 4’s “participation in this case” can only be achieved by listing them as parties. As it stands under the original petition, the merits of this case will be decided based on a determination of whether the Government violated the rights of Jane Doe 1, Jane Doe 2, and all “other similarly situated victims” under the CVRA. Jane Doe 3 and Jane Doe 4 may offer relevant, admissible, and non-cumulative evidence that advances that determination, but their participation as listed parties is not necessary in that regard. See Herring, 894 F.2d at 1024 (District court did not abuse its discretion by denying amendment where “addition of more plaintiffs .. . would not have affected the issues underlying the grant of summary judgment.”):; cf. Arthur v. Stern, 2008 WL 2620116, at *7 (S.D. Tex. 2008) (Under Rule 15, “courts have held that leave to amend to assert a claim already at issue in [another lawsuit] should not be granted if the same parties are involved, the same substantive claim is raised, and the same relief is sought.”)” And, as to Jane Doe 4 at least, adding her as a party raises unnecessary questions about whether she is a proper party to this action.® Petitioners also admit that amending the petition to conform to the evidence by including references to the non-prosecution agreement itself is “unnecessary” as the “existing petition is broad enough to cover the developing evidence in this case.” (DE 311). The Court > The Court expresses no opinion at this time whether any of the attestations made by Jane Doe 3 and Jane Doe 4 in support of their motion will be relevant, admissible, and noncumulative. ° The Government contends that Jane Doe 4 is not a true “victim” in this case because she was not known at the time the Government negotiated the non-prosecution agreement, and accordingly she was not entitled to notification rights under the CVRA. (See DE 290 at 10). Any “duplicative” litigation filed by Jane Doe 4 would necessarily raise the issue of whether she has standing under the CVRA under these circumstances. 9

Case 9:08-cCR@SPESES RRS, Dogue 378, CHRGe0 oh, AG BASeckagRHanb648 Page 10 of 10 agrees, and it concludes that justice does not require amending the petition this late in the proceedings. II. Conclusion Accordingly, it is hereby ORDERED AND ADJUDGED as follows: the Rule 21 Motion (DE 280) is DENIED; the Rule 15 Motion (DE 311) 1s DENIED; Intervenor Dershowitz’s Motion for Limited Intervention (DE 282) and Motion for Leave to File Supplemental Reply in Support of Motion for Limited Intervention (DE 317) are DENIED AS MOOT; Petitioners’ Motion to Seal (DE 292) is DENIED AS MOOT; the following materials are hereby STRICKEN from the record: ° DE 279, in its entirety. ° DE 280, all sentences between the following sentences: “The Government then concealed from Jane Doe #3 the existence of its NPA from Jane Doe #3, in violation of her rights under the CVRA” (DE 280 at 3); and “The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the NPA” (DE 280 at 6). ‘ DE 291-1, paragraphs 4, 5, 7, 11, 13, 15, 19 through 53, and 59. ° DE 310-1, paragraphs 7 through 12, 16, 39, and 49. ° DE 293, in its entirety. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 6" day of April, 2015. ORONO RD. ey, fA. an ff ol os er ra KENNETH A. MARRA United States District Judge 10

Case 18-2868, Document 278, 08/09/2019, 2628230, Page43 of 648 EXHIBIT F

Case 18-2868, Document 278, 08/09/2019, 2628230, Page44 of 648 From: <ross@acuityreputation.com> Date: 2 January 2015 at 20:38 Subject: Ghislaine Maxwell To: Rossacuity Gow <ross@acuityreputation,.com> bec: martin.robinson@mailonline.co.uk, P.Peachey@independent.co.uk, nick.sommerlad@mirror.co.uk, david. brown @thetimes.co.uk nick.alway@ bbc.co.uk, jo-anne.pugh@bbc.co.uk To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts - so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue, Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschowitz is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims, Sent from my BlackBerry® wireless device GM_00068

Case 18-2868, Document 278, 08/09/2019, 2628230, Page45 of 648 EXHIBIT G

0 11 12 LS 14 is 16 Le 18 Lo 20 21 22 23 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page46 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 IN THE HIGH COURT OF JUSTICE QUEEN'S BENCH DIVISION Claim No. CR 2016-624 BETWEEN : VIRGINIA L. GIUFFRE Applicant, - and ROSS GOW, Respondent. AND: UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, Case No. 15-cv-07433-RWS V. Ghislaine Maxwell, Defendant. Ne ee ee ee ee ee ee” — rer eee femme ere meen eerste ye ms ties Friday, November 18, 2016 AT: 8:27 a.m. Taken at: Essex Chambers 29, 81 Chancery Lane, London, UK, WC2A. 1DD Court Reporter: Lisa Barrett, Accredited Real-time Reporter DTI Court Reporting Solutions - New York 1-800-325-3376 www. deposition.com

10 ae 12 i 14 LS 16 ey 18 19 20 Zouk. 22 23 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page47 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 2 A PPEHARAN CE S: Appearing for the Plaintiff: MEREDITH L. SCHULTZ, ESQ. BOTES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 DAVID TURNER, ESQ. BOITES, SCHILLER & FLEXNER (UK) LLP 25 Old Broad Street London, UK EC2N 1HO Counsel for Defendant, Ghislaine Maxwell: LAURA A. MENNIGER, P.C. HADDON, MORGAN and FOREMAN, P.C. 150 EKast Tenth Avenue Denver, CO 80203 Counsel for Defendant, Ross Neil Sutherland Gow (witness) : RICHARD SPEARMAN, Q.C. PHILIP BARDEN, DEVONSHIRES SOLICITORS LLP 30\Finsbury Circus, London EHEC2M 7DT, UK BExaminer: ALLEN DYER, 4 Pump Court Temple, London, EC4Y 7AN DX 303 LDE DTI Court Reporting Solutions - New York 1-800-325-3376 www.deposition.com

im, a LZ, le 14 15 LG 17 1 Ll? a Ze 22 Zo 24 Zo 1-800=325=3357/6 Case 18-2868, Document 278, 08/09/2019, 2628230, Page48 of 648 ROSS NETL SUTHERLAND GOW - 11/18/2016 WITNESS INDE X Witness ROSS NEIL SUTHERLAND GOW (sworn) Examination by Ms. Schultz Examination by Ms. Menninger Re-examination by Ms. Schultz No. 3 BACH. LB dT of N.D E xX Description Consent Order before Master Fontaine Email from ross@acuityreputation.com to Ross@acuity.com, bec: Martin.robinsonemailonline.co.uk, P,Peachy@indepedent.co.uk, Nick.sommerland@mirror.co.uk, david. brown@thetimes.co.uk, Nick.alway@bbe.co.uk, Jo-anne.pugh@bbc.co.uk, dated 2 January 2015, Bates No. GM 00068 Email from James Ball to Ross Gow, dated 1 January 2015, Bates No. RG(UK) 000002 DTI Court Reporting Solutions - New York Page 3 Page LO 10 117 hg Page dae 13 30 www.deposition.com

10 ta 12 13 14 15 16 Ld 18 19 20 Au aL Ze 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page49 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 4 E; xX H I BIT INDE X No. Description Page 4. Email from Ross Gow to G Max, 35 cc Brian Basham, dated January 2, 2015, Bates No. GM 01043-44 5 Email from ross@acuityreputation.com, 37 to G Max, sent Friday, January 2, 2015, Fw: The Times - David Brown, Bates No. GM 01038-39 6 Email from ross@acuityreputation.com 38 to G Max, sent Friday, January 2, 2015, Subject: Agreed copy, Bates Nos. GM 01036-37 7 Email from ross@acuityreputation.com 40 to G Max, sent Friday, January 2, 2015, Subject:’/ Re: Agreed copy, Bates No. GM 01040-01041 8 Email from ross@acuityreputation.com , 42 dated Friday, January 2, 2015, To: G Max, Bates No. GM 01042 9 Email from ross@acuityreputation.com, 44 dated 2 January 2015, To: G Max gmaxl@ellmax.com, Cc: Philip Barden, philip.barden@devonshires.co.uk, Bates Nos. RG(UK) _00009 DTI Court Reporting Solutions - New York 1-800-325-3376 www.deposition.com

10 Li eZ 3 14 Ls 16 oe 18 ie 20 ZA 22 23 24 20 1=600=325-23376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page5O of 648 No. 10 Ld LZ 13 ROSS NEIL SUTHERLAND GOW - 11/18/2016 FX HIBIT INDE X Description Email from gmaxl@ellmax.com, sent: Saturday January 10, 2015, To Philip Barden; Ross Gow, Bates GM 01060-68 Email chain, latest in time from G Maxwell to J Jep, sent Sunday, January 11, 2015, Bates Nos. GM _01069-72 Email chain, latest in time from Ek Jeffrey jeevacation@gmail.com, dated Sunday, January Tif 2015. 7:15 a.m., to G Maxwell, Bates Nos. GM 01076-77 Email chain, latest in time from Jeffrey E jeevacation@gmail.com, sent Wednesday, January 21, 2015 4:47 p.m. To: G Maxwell, Bates Nos. GM 01088-90 DTI Court Reporting Solutions - New York Page 5 Page 50 54 60 65 www.deposition.com

10 alll 12 iis 14 5 16 L7 LS i 20 21 ZZ 23 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page51 of 648 No. 14 LS 16 17 18 io ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 6 EXHIBIT INDE X Description Page Email chain, latest in time from 68 Nick Sommerlad, dated 2 January 2015, 21:45, To ross@acuityreputation.com Bates Nos. RG(UK) 000004, one page Email from Ross Gow dated Saturday, yal 3 January 2015, To David Mercer, Bates Nos. RG (UK) 000005-08 Email string from Ross Gow to G Max; 73 Philip Barden, dated Tues, February 24, 2015, Bates Nos. GM 00577 - one page Email from G Maxwell to Ross Gow, 75 dated Thurs February 26, 2015, Bates Nos. GM 00578 Email Eon Ross Gow to G Maxwell, a7 dated Thursday, February 26, 2015, Bates Nos. GM 00579 Email from Ross Gow to G Max; 78 Philip Barden, dated Wednesday, April 8, 2015, Bates Nos. GM 00580 DTI Court Reporting Solutions - New York 1-800-325-3376 www.deposition.com

10 bed a 3 14 lL LG i 18 Lg 20 au 22 23 24 a5 Case 18-2868, Document 278, 08/09/2019, 2628230, Page52 of 648 No. 20 yaad 22 22 24 AD 26 ROSS NETL SUTHERLAND GOW - 11/18/2016 Page 7 iAH. Bir Lt NDE Xx Description Page Email from G Max to Ross Gow; 79 Philip Barden, dated Wednesday, May 6, 2015, Bates Nos. GM 0058384 Email chain, latest in time from 81 Ross Gow to G Maxwell; Philip Barden, dated Wednesday, May 6, 2015, Bates Nos. GM 00585-587 Email from Ross Gow to Scott Adam, 82 dated Wednesday, May 6, 24015, Bates No. GM 00589-590 Website print out Bates No. 82 GUIFFRE008453 Website printout, Bates Nos. 93 GUIFFRE008454-455 - two pages Email from Ross Gow to G Max, 100 Philip Barden, Bates Nos. GM 00594 Website screenshot printout of 109 Acuity Reputation - two pages DTI Court Reporting Solutions - New York 1-800-325-3376 www.deposition.com

10 ia: 12 13 14 15 16 1’7 18 19 ZU 21 22 23 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page53 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 8 PROCEEDINGS THE VIDEOGRAPHER: Here begins video card number 1, volume I, in the video deposition of Ross Gow. This is taken in the matter of Virgina Guiffre and Ross Gow. This is being heard in the High Court of Justice, Queen's Bench Division, Senior Master, claim number CR-21016-624. Today's date is November 18, 2016. The time on the video screen is 08:26 a.m., local time in London. The video operator today is Phillip Hill from DTI Court Reporting Solutions. The court reporter is Lisa Barrett from DTI Court Reporting Solutions. This video deposition is taking place at the Essex Chambers in London. I will now hand over the proceedings to the Examiner. Thank you, sir. MR. DYER: Would counsel or lawyers present, please identify themselves for the record, first? MS. SCHULTZ: I'm Meredith Schultz from Boise Schiller and Flexner LLP, appearing for the Plaintiff, Ms. Virginia Guiffre. With me is my colleague, David Turner, also from Boies, Schiller and Flexner LLP. MS. MENNINGER: I'm Laura Menninger from Haddon, Morgan and Foreman on behalf of Ghislaine DTI Court Reporting Solutions - New York 1-800-325-3376 www.deposition.com

10 11 12 3 14 15 16 17 18 19 20 21 22 ZS 24 25 1=800=325=3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page5b4 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 30 worse objection, oie Worse grounds for me. MR. DYER: I think questions of payment do not fall within the scope. BY MS. SCHULTZ: O; Okay. Are you currently retained by Ms. Maxwell for professional services. A. If I could go back to my previous answer, Ms. Maxwell is a project client, and it's on a day rate. If -- so, for the sake of argument between 2nd of January 2015 and the lst of February 2016 we were quite busy answering these incoming calls, so there was quite a lot of work at that point in time. Recently there's been no work. There's been no need because the press activity has died down, our function is somewhat redundant. G.. Can you estimate the last time that you worked on this account at your day rate? A. It would have been in 2015. Probably April, May, something like that. No invoices, no -- no payment in 2016 from my recollection. BY MS. SCHULTZ: Q. Mr. Gow, I'm going to hand you another document. (Exhibit 3 was marked for identification.) MS. SCHULTZ: Point of procedure: I have only three copies of these documents for each of the DTI Court Reporting Solutions - New York www.deposition.com 08; 08; 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08; 08: 08: 08: 08 08 08: 08: P0149 30:48 58:09 58:11

10 aot LZ ie 14 15 16 Ly 18 i 20 21 Zz 23 24 25 13003253376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page55 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 31 remaining, so... I've marked as Exhibit 3 RG(UK) 00002. Do you recognize this email? A. lL do: Oz Did you receive this email? A. I did, on the -- on New Year's Day 2015. Cu Did you contact Ms. Maxwell after receiving this email? A. I did. Oe Did you make any response to Mr. Ball in any form? A. i eae, O. Can you tell me what you -- what response you made? A. Well, the response to Mr. Ball was part of a series of responses having spoken to my client within 24 hours or so, we got back to Mr. Ball with an agreed statement which went out to a number of media. Q. When you say "agreed statement" can you tell me more about what you mean? Who agreed to the statement? A. I need to give you some context, if I may, about that statement. So, this is on New Year's Day. I was in France so the email time here of 21:46, in French time was 22:46, and I was getting up early the next DTI Court Reporting Solutions - New York www.deposition.com 08:58:14 UdiSorl5 08:58:47 08:58:48 08:58:49 06356750 UOs50%5/ 08:58:58 U5 +56%59 UStogt19 08:59:22 Us 50%22 UiotS9325 Ut 5 9226 UG ;Sot27 UG 59433 08:59:41 08:59:44 0075950 Ud359252 08:59:58 09:00:01 09:00:02 09:00:04 09:00:10

10 11 12 3 14 i 16 Ly 18 19 20 Zi 22 23 24 25 1=800=325+3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page56é of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 32 morning to drive my family back from the south of France to England, which is a 14-hour journey, door to door. So on the morning of the 2nd of January, bearing in mind that Ms. Maxwell, I think was in New York then, she was five hours behind, so there was quite a lot of, sort of time difference between the various countries here, I sent her an email, I believe, saying -- parsing this -- forwarding this email to her saying "How do you wish to proceed?" And then I was on the telephone -- I had two telephones in the car, I received in excess of 30 phone calls from various media outlets on the 2nd of January, all asking for information about how Ms. Maxwell was looking to respond to the latest court filings, which were filed on the 30th of December as I understand. And by close -- towards close of play on the 2nd, Pr ested an email forwarded by Ms. Maxwell, containing a draft statement which my understanding was the majority of which had been drafted by Mr. Barden with a header along the lines of "This is the agreed statement." At close of play on the 2nd. SO I -- I was -- I had gone under the Channel Tunnel and I was sitting on the other side and that email, which my understanding was that it had DTI Court Reporting Solutions - New York www.deposition.com 09: (SF Os Uo: 09; 09: Ug U9? 09: 09: 09: 09: 09: Ue Oo: Do: 09; 09: 02: 09; 09: oy. UF: 09% U9:

LQ eu UZ 15 14 io 16 17 18 Ly 20 Zz 22 23 24 25 1=6U0=32523576 Case 18-2868, Document 278, 08/09/2019, 2628230, Page5/ of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 33 been signed off by the client, effectively, was then sent out to a number of media, including Mr. Ball and various other UK newspapers. 0. Mr. Gow, when you say "end of play" and "close of play," are you referring to sending the email that's Exhibit 2? A. Yes, I am. MR. DYER: My understanding is that it went to people other than those listed? THE WITNESS: Yes, that is -MR. DYER: Just a sample. THE WITNESS: That 1s a sample. Everyone who effectively -- well, the detail on this, I was driving, so my eldest son in the back had my BlackBerry and was trying to capture “rit was a pretty chaotic day. Most people in the UK were on holiday. In fact, it was a holiday pasiend, our office was closed, my PA was on holiday, so my son was basically doing an internship in ene back of the car, downloading the names of the callers from various media outlets and -- so we had a list of those so when I got to the car park, at the end of the Eurotunnel thing in the UK, I had numerous names, so the email went out to a wide range of people. But the 30 or so calls I had is an aggregate number, so there might have been five calls from the BBC DTI Court Reporting Solutions - New York www.deposition.com uae02% uo Nas vor0as 09:02: 09:02: O92 uon02; 09:02: U90z: U93025 09:02: U9 102; U9 :02 09202: 3202: U9. 02: 09:02: 09:02: 09:02: 09:03: 09203; 09:03: 09:03: 09:03: 09:03:

10 uA 12 ie 14 15 Lb 17 i Lo 20 21 22 23 24 25 l#eU00=325=33.76 Case 18-2868, Document 278, 08/09/2019, 2628230, Page58 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 34 from different people so they -- the BBC would only write one story, there wouldn't be five versions of it, so 30 is an aggregate number. BY MS. SCHULTZ: O; Okay. Looking again at Exhibit 2, could you please review the individuals or email addresses of the -- listed in the "To" and "bec" portion? A. Yep. Q. Did you send this written statement to any other individuals or entities who are not listed in that portion? A. Within ae within 24 hours of this, yes, a wider range of people, definitely. This was the initial -- these are the most pressing ones, who said they were going to write a story whether they had -- if I could just explain a bit more Sant ext again in the world of PR. When you are in the field you're engaged and you've just -you've got to prioritize who you spoke to and whoever Shouts the loudest usually gets responded to first. So the reason there are two BBC people there for instance, is there's BBC broadcast radio, and BBC TV, and they were coming at -- from different angles for different stories, but there was a certain sense of urgency and immediacy. So the half a dozen DTI Court Reporting Solutions - New York www.deposition.com O90": Oo703% 09:03: 05703: 09303: v2e)3: 00303; 09:03: 09:03: O92 03% ug 034 u5705% 09:04: 09:04: 09:04; 09:04: 09:04: 09:04: 09:04: 09:04: 09:04: 09:04;

10 11 cz ae 14 i 16 i] 18 19 20 21 22 23 24 25 1=800=3252=3376 Case 18-2868, Document 278, 08/09/2019, 2628230, Page59 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 rPage..35 or so here were the ones that we prioritized to deal with that night because they were publishing the next day or -- or thereabouts, but for instance we also Spoke to the Daily Express. I can't remember the name of the gentleman there, or the lady, but I remember that was early the next morning when we got on to other channels. Q. So you sent this statement to additional individuals on January 3rd? A. Not just on January 3rd. I mean, as we had an agreed statement there, and I do recall there is a typo in this which is "Virginia" and "Victoria" -- there was a transposition there. So the original email went out with the typo because that was taken from the -- the statement that I believe Mr. Barden was broadly the architect of, but forwarded by Ms. Maxwell. So I just -- I took that as a verbatim statement and sent it out. I re-read it in the calm light of day the next morning. There was at least one typo in it so I changed that and reached out, again, to these people, updating the typo and sent 1t out to additional people. BY MS. SCHULTZ: Q. Mr. Gow, I'm going to hand you another document. I'm going to mark this as Exhibit 4. (Exhibit 4 was marked for identification. ) DTI Court Reporting Solutions - New York www.deposition.com 09:04:44 09:04:46 09:04:49 09:04:52 09:04:56 09:04:58 09:05:04 09:05:06 09:05:09 U9205+13 09:05:16 09:05:20 09:05:24 UD 05325 09505:35 09:05:42 09:05:45 09:05:50 U9 05752 U9205:5/ 09:06:07 09:06:09 09:06:15 09:06:17 09:06:26

Case 18-2868, Document 278, 08/09/2019, 2628230, Page60 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 36 1 BY MS. SCHULTZ: 09:06:28 2 ‘oF This 18 a document that is Bates labeled 09:06:31 3. GM 01043. 09:06:34 4 A. Thank you. 09:06:38 5 Q. The top email on this document says "From: Ross 09:06:59 6 Gow." Did you send this email? 09:07:02 7 A. I believe I did, yes. 09:07:07 8 O. Did you send it to Ms. Maxwell? 09:07:08 9 ie Yes. 09:07:09 10 Q. In the "To" field, when it says "G Max," do you 09:07:11 11 recognize that to be Ms. Maxwell's email address? 09<07:18 iZ A. Yes. 0901223 13 Oi In the second paragraph of this email it 09:07:37 14 states: | U7 07 39 Ls "Please advise how you wish to handle this." [As | 09:07:40 16 read] 09:07:43 Ly Did you receive a response from Ms. Maxwell? 09:07:43 18 A. Bearing in mind I was driving all that day, I 09:07:47 ite, can't recall what the exact response was but from memory, 09307152 20 it was along the lines of she would get back to me with D907 57 21 how she wished to proceed. 09:08:03 ZZ BY MS. SCHULTZ: 09:08:04 23 Q. Okay. 09:08:25 24 Mr. Gow, I'm going to hand you another | 09:08:26 25 document. I'm going to mark it as Exhibit 5. 09:08:27 DTI Court Reporting Solutions - New York 1-800~325-3376 www. deposition.com

10 ia: LZ L3 14 i 16 L’/ 18 ee 20 21 22 23 24 Ze Case 18-2868, Document 278, 08/09/2019, 2628230, Page61 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 122 had existing authorization to make statements on Ms. Maxwell's behalf due to the reauthorization letter; is that correct? A. I believe that from the 2nd of January 2015, I had an ongoing re-established authority to represent her, within the parameters of the 2011, 2015 press releases, there or thereabouts. MS. SCHULTZ: Mr. Dyer, I have no further questions. MR. DYER: Thank you. That concludes your deposition. THE WITNESS: Thank you, sit. MR. DYER: Thank you very much. THE VIDEOGRAPHER: Going off the record, the time ig 11:39. End of video card number 3, volume I, and end of the video deposition of Ross Gow. (Whereupon, the deposition concluded at 11:39 a.m.) Cattle / (f) Lisa Barrett, RPR, CRR, CRC, CSR Certified Real-time Court Reporter DTI Court Reporting Solutions - New York 1-800-325-3376 www.deposition.com ie 39 se Legos iil 11:39:14 Pies oel5 Lies 9120 Lissot2s Te 930 U3 9 700 ne es 11:39:38 hie 3o.39 11:39:40 11:39:41

Case 18-2868, Document 278, 08/09/2019, 2628230, Page62 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 123 Subscribed and sworn to before me this 20th day of November, 2016. JI DO Wo FPF W NO FB TQ A de also 14 LS 1G ae Le Lo 20 2A ZZ 25 24 25 DTI Court Reporting Solutions - New York 1-800-325-3376 www.deposition.com

He ak LZ L3 14 LS 6 iy ie ee 20 Zid: 22 23 24 ZO Case 18-2868, Document 278, 08/09/2019, 2628230, Page63 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 124 CERTIFICATE OF DEPONENT I, ROSS NEIL SUTHERLAND GOW, hereby certify that I have read the foregoing pages, numbered 1 through 122 of my deposition of testimony taken in these proceedings on this 18th day of November, 2016 and with the exception of the changes listed on the next. page and/or corrections, if any, find them to be a true and accurate transcription thereof. PEOUed. eae een oh oo enone es Name: ROSS NEIL SUTHERLAND GOW Date: bese ae eee doe ane oe 8 DTI Court Reporting Solutions - New York 1=800+325-=3376 www.deposition.com

Case 18-2868, Document 278, 08/09/2019, 2628230, Page64 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page: 125 il CERTIFICATE OF EXAMINER 2 I, ALLEN DYER, of 4 Pump Court 3 Temple, London, EC4Y 7AN DX 303 LDE have been 4 appointed as Examiner herein pursuant to an Order of 5 Master Fontaine dated 29 September 2016. It has been > 6 agreed by all parties herein that the evidence of the 7 witness, ROSS NEIL SUTHERLAND GOW, should be taken 8 down in shorthand and that the transcript of the said 9 notes of evidence should be deemed to be the 10 deposition of the said witness. i 12 I certify that, the oath having been duly 13 administered, the witness has been examined pursuant 14 to the said order. The pages of transcript annexed 15 hereto were furnished to me by DTI, Lisa Barrett, 16 Accredited Real-time Reporter, as containing the 17 transcript oR HS notes of the evidence of the witness 18 pursuant to the order. dip 20 21 22 23 24 25 DTI Court Reporting Solutions - New York 1-800-325-3376 www.deposition.com

10. A LZ Ls 14 LS 16 17 18 Lg 20 21 22 23 24 a2 Case 18-2868, Document 278, 08/09/2019, 2628230, Page65 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 126 CERTIFICATE OF DEPONENT I, Ross Neil Sutherland Gow, hereby certify that I have read the foregoing pages, numbered 1 chrough 122, of my video deposition of testimony taken in these proceedings on this 18th day of November, 2016 and, with the exception of the changes listed on the next page and/or corrections, if any, find them to be a true and accurate transcription thereof. DTI Court Reporting Solutions - New York 1-800-325-3376 www.deposition.com

10 11 LZ Ls 14° is 6 L7 18 19 20 21 22 Zo 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page66 of 648 ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page: -L27 CERTIFICATE OF COURT REPORTER I, Lisa M. Barrett, an Accredited Real-time Reporter, hereby certify that the testimony of the witness Ross Neil Sutherland Gow in the foregoing transcript, numbered pages 1 through 122, taken on this 18th day of November, 2016 was recorded by me in machine shorthand and was thereafter transcribed by me; and that the foregoing transcript is a true and accurate verbatim record of the said testimony. I further certify that I am not a relative, employee, counsel or financially involved with any of the parties to the within cause, nor am I an erilovee Or relative of any counsel for the parties, nor am I, in any way, interested in the outcome of the within Cause. PAGNeG:: gaeaesteuee yeudeseeeese uns sans os Name: Lisa M. Barrett, RPR, CRR, CRC, CSR Date: November 30th 2016 DTI Court Reporting Solutions - New York 1-800-325-3376 www.deposition.com

Case 18-2868, Document 278, 08/09/2019, 2628230, Page67 of 648 —-----—- Forwarded message ------—— From: James Ball <james.ball @theguardian.com> Date: 1 January 2015 at 21:46 Subject: URGENT — Ghislaine Maxwell To: ross @acuityreputation.com Dear Ross, I'm writing to you as you have in the past represented Ghislaine Maxwell. As you are no doubt aware, fresh allegations have been levelled against Ms Maxwell in new US court filings made in Florida on 30 December, which some outlets have already been reported. I would urgently seek any comment on behalf of your client, or notification of her new representation if you no longer act for her. Many thanks for your help, James oy <y RG(UK)_000002

Case 18-2868, Document 278, 08/09/2019, 2628230, Page68 of 648 From: Ross Gow <ross@acuityreputation.com> Sent: Friday, January 02, 2015 1:07 AM To: G Max a Brian Basham Subject: Fwd: URGENT ~ Ghislaine Maxwell Hi Ghislaine James Ball, investigative reporter for The Guardian, who reports on US stories, has made contact, as per below. Please advise how you wish to handle this. | am driving all day today, but can be contacted on +44 (0) 7778 755 251 Best Ross aeens-eee- Forwarded message ---------From: James Ball <james.ball(@theguardian.com> Date: Thursday, January 1, 2015 Subject: URGENT — Ghislaine Maxwell To: ross@acuityreputation.com Dear Ross, sjhislaine Maxwell. As you are no doubt aware, fresh in new US court filings made in Florida on 30 December, I'm writing to you as you have tn the past allegations have been levelled against which some outlets have already be | would urgently seek an longer act for her. Many thanks for your help, James ‘dames Ball Gpee'nt Projects Edituc > tb} 203 3335 293 > b44 7540 825 49) >a@juamesrbuk ? Visit theguardian.com. On your mobile and tablet, download the Guardian iPhone and Android apps thequardian.com/quardianapp and our tablet editions thequardian.com/editions. Save up to 57% by subscribing to the Guardian and Observer - choose the papers you want and get full digital access. Visit subscribe. thequardian.com PRIVILEGED GM_001027 EXHIBIT GM_01043 CONFIDENTIAL U}

Case 18-2868, Document 278, 08/09/2019, 2628230, Page69 of 648 This e-mail and all attachments are confidential and may also be privileged. If you are not the named recipient, please notify the sender and delete the e-mail and all attachments immediately. Do not disclose the contents to another person. You may not use the information for any purpose, or store, or copy, itin any way. Guardian News & Media Limited is not liable for any computer viruses or other material transmitted with or as part of this e-mail. You should employ virus checking software. Guardian News & Media Limited is a member of Guardian Media Group plc. Registered Office: PO Box 68164, Kings Place, 90 York Way, London, NiP 2AP. Registered in England Number 908396 Ross Gow Managing Partner ACUITY Reputation 23 Berkeley Square London WIJ 6HE +44 (0) 207 204 6110 +44 (0) 777 875 5251 mob +7 903 363 5393 Mocksa Mo6napnstit Www.acuityreputation.com The information contained in this e-mail and any attachments is confidential and may be privileged or otherwise protected from disclosure. It is intended solely for the attention and use of the named addressee(s). If you are not the intended recipient, dissemination, copying or use of this e-mail and any attachments in whole or in part is prohibited. If you have received the e-mail in error, please notify the sender and delete the e-mail and any attachments from your computer system. Whilst any attachments may have been checked for viruses, you should rely on your own virus checker and procedures. No responsibility is accepted by ACUITY Reputation Limited for loss or damage arising from the receipt or use of this e-mail. PRIVILEGED GM_001028 GM_01044 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page/O of 648 EXHIBIT

Case 18-2868, Document 278, 08/09/2019, 2628230, Page/1 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS V. Ghislaine Maxwell, Defendant. / PLAINTIFF’S RESPONSES AND OBJECTIONS TO DEFENDANT’S SECOND REQUEST FOR PRODUCTION AND DEFENDANT’S INTERROGATORIES, PLAINTIFF’S ANSWERS TO DEFENDANT’S REQUESTS FOR ADMISSION Pursuant to Federal Rules of Civil Procedure 26, 33, 34, Plaintiff hereby serves her responses and objections to Defendant’s Second Set of Discovery Requests and serves her Answers to Defendant’s Requests for Admission. GENERAL OBJECTIONS Defendant’s Discovery Requests violate Rule 33, Fed. R. Civ. P., which provides “a party may serve on any other party no more than 25 interrogatories, including all discrete subparts” — in that Defendant has served a total of 59 interrogatories in this case, including subparts, in violation of Rule 33. Ms. Giuffre objects to Defendant’s Second Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege, work product privilege, joint defense privilege, public interest privilege, and any other applicable privilege.

Case 18-2868, Document 278, 08/09/2019, 2628230, Page/2 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) on hundreds (if not thousands) of matters, and collectively have well over 100 years of combined practice experience. Accordingly, a request that each of these attorneys list al// communications with the media 1s facially overbroad. Additionally, Ms. Giuffre objects to this Interrogatory because a response would cause Ms. Giuffre the incredible and undue burden of having to catalogue literally hundreds of communications that she has already produced in this case. Moreover, Ms. Giuffre objects because this interrogatory calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Communications with the media regarding cases that bear no relation to the subject matter of this case, from decades in the past, are facially invalid and not calculated to lead to the discovery of admissible evidence. Ms. Guiuffre additionally objects to the extent that this interrogatory seeks the communications of her attorneys, any author, reporter, correspondent, columnist, writer, commentator, investigative journalist, photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any media organization or independent consultant as such interrogatory is overly broad and unduly burdensome. Furthermore, Ms. Giuffre is not obligated to produce anything currently in the possession of Defendant Maxwell or her attorneys. Notwithstanding such objections, Ms. Giuffre has already produced her responsive communications, which are found in documents Bates labelled GIUFFRE000001 to GIUFFRE007566. 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Count I of Your Complaint, including:

Case 18-2868, Document 278, 08/09/2019, 2628230, Page/73 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) a. the exact false statement; b. the date of its publication; c. the publishing entity and title of any publication containing the purportedly false Statement; d. the URL or internet address for any internet version of such publication; and the nature of the publication, whether in print, internet, broadcast or some other form of media. Response to Interrogatory No. 6: Ms. Giuffre objects because the information interrogatory above is in the possession of Defendant who has failed to comply with her production obligations in this matter, and has failed to comply with her production obligations with this very subject matter. See Document Request No. 17 from Ms. Giuffre’s Second Request for Production of Documents to Defendant Ghislaine Maxwell.’ Maxwell has not produced all “URL or Internet addresses for any internet version of such publication” that she directed her agent, Ross Gow, to send. ' Request No. 17 stated: Produce all documents concerning any statement made by You or on Your behalf to the press or any other group or individual, including draft statements, concerning Ms. Giuffre, by You, Ross Gow, or any other individual, from 2005 to the present, including the dates of any publications, and if published online, the Uniform Resource Identifier (URL) address. In response, Defendant stated: “Ms. Maxwell objects to this Request on the grounds that it is cumulative and duplicative. Ms. Maxwell also objects to this Request to the extent it calls for information that exists within the public domain, the internet or in public court records and which are equally available to both parties and can be obtained from some other source that 1s more convenient, less burdensome, and less expensive. Ms. Maxwell further objects to this Request to the extent it seeks documents or information protected by the attorney/client privilege, the work-product doctrine, or any other applicable privilege. Ms. Maxwell is not producing documents that are available in the public domain. Ms. Maxwell has been unable to locate any additional documents responsive to this Request.”

Case 18-2868, Document 278, 08/09/2019, 2628230, Page/4 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Ms. Giuffre further objects because the information requested above is in the possession of Defendant’s agent, who caused the false statements to be issued to various media outlets. Ms. Giuffre has not had the opportunity to depose Maxwell’s agent Ross Gow; therefore, this answer remains incomplete. Consequently, Ms. Giuffre reserves the right to modify and/or supplement her responses, as information is largely in the possession of the Defendant and her agent. Ms. Giuffre objects to this interrogatory in that it violates Rule 33 as its subparts, in combination with the other interrogatories, exceed the allowable twenty-five interrogatories. Ms. Giuffre objects to this request because it is in the public domain. Ms. Giuffre also objects in that it seeks information protected by the attorney-client/work product privilege, and any other applicable privilege stated in the General Objections. Notwithstanding such objections, Ms. Giuffre has already produced documents responsive to this request; Bates labelled GIUFFRE000001 to GIUFFRE007566, and supplements such responsive documents with the following list of publications. While the identification of an exhaustive responsive list would be unduly burdensome, in an effort to make a good faith effort towards compliance, Ms. Giuffre provides the following examples, which are incomplete based on the aforementioned reasons: Date Nature | Publishi | Statement/URL ng Entity Januar | Internet | Ross Jane Doe 3 is Virginia Roberts - so not a new individual. The allegations made by Gow Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are v2; not new and have been fully responded to and shown to be untrue. 2015 Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms. Roberts that Alan Dershowitz 1s involved in having sexual relations with her, which he denies. Ms. Roberts’s claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at

Case 18-2868, Document 278, 08/09/2019, 2628230, Page/5 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) mn Pe the repetition of such old defamatory claims. Januar | Internet | Telegrap | http://www.telegraph.co.uk/news/uknews/theroyalfamily/1 1323872/Princeh Andrew-denies-having-relations-with-sex-slave-girl. html V2. 2015 Januar | Internet | Express http://www.express.co.uk/news/world/550085/Ghislaine-Maxwell-Jeffrey-Epsteinnot-madam-paedophile-Florida-court-case-Prince-Andrew y 4, Januar | Internet | Daily http://www.dailymail.co.uk/news/article-2895366/Prince-Andrew-lobbiedMail government-easy-Jeffrey-Epstein-Palace-denies-claims-royal-tried-use-influencehelp-billionaire-paedophile-2008-police-probe html y 3, 2015 Januar | Internet | Huffingt | http://www.huffingtonpost.co.uk/2015/01/03/duke-of-york-sex-abuseon Post claims n_ 6409508 html y 3, Januar | Internet | Jewish http://www.jewishnews.co.uk/dershowitz-nothing-prince-andrews-sex-scandal/ News y 4, Online 2015 Januar | Internet | Bolton http://www.theboltonnews.co.uk/news/national/11700192.Palace denies Andrew _s News ex_case_claim/ y 2, Januar | Internet | NY http://www.nydailynews.com/news/world/alleged-madame-accused-supplyingDaily prince-andrew-article-1.2065505 News y 5, / 2015 Broadca St Internet | AOL UK | http://www.aol.co.uk/video/ghislaine-maxwell-declines-to-comment-on-princeandrew-allegations-5 18587500/ / Broadca St

Case 18-2868, Document 278, 08/09/2019, 2628230, Page/6 of 648 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 Telephone: (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 Telephone: (801) 585-5202 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 1, 2016, I electronically sent the foregoing document to the counsel below via e-mail. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10" Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: lmenninger@hmflaw.com 43

Case 18-2868, Document 278, 08/09/2019, 2628230, Page// of 648 EXHIBIT I

Case 18-2868, Document 278, 08/09/2019, 2628230, Page78 of 648 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. / PLAINTIFF’S SUPPLEMENTAL RESPONSES TO DEFENDANT’S INTERROGATORIES 6, 12 and 13 Pursuant to Federal Rules of Civil Procedure 26, 33, 34, Plaintiff hereby serves her supplemental responses to Defendant’s Interrogatories 6, 12 and 13. OBJECTIONS Plaintiff maintains and hereby incorporates by reference all applicable objections, including both general objections and specific objections to individual] interrogatories, in her prior responses and objections served on Defendant in these supplemental responses. Defendant’s Discovery Requests violate Rule 33, Fed. R. Civ. P., which provides “a party may serve on any other party no more than 25 interrogatories, including all discrete subparts” — in that Defendant has served a total of 59 interrogatories in this case, including subparts, in violation of Rule 33. Ms. Giuffre objects to Defendant’s Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege, work product privilege, and any other applicable privilege.

Case 18-2868, Document 278, 08/09/2019, 2628230, Page79 of 648 Jane Doe No. 102 v. Jeffrey Epstein, Case No. 09-80656-CIV-Marra/Johnson (Southern District of Florida). Accordingly, due to the undue burden of individually logging responsive, privileged documents related to Defendant’s overly-broad requests, Plaintiff has employed categorical logging of such privileged responsive documents pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a minor victim of sexual trafficking. Ms. Giuffre objects to the requests to the extent they are overly broad and unduly burdensome. Ms. Giuffre’s responses to Defendant's Second Set of Discovery Requests are being made after reasonable inquiry into the relevant facts, and are based only upon the information and documentation that is presently known to her. Ms. Giuffre reserves the right to modify and/or supplement her responses. Ms. Giuffre has produced documents and information in response to these Requests. Ms. Giuffre incorporates her above-listed general objections in the responses herein. SUPPLEMENTAL INTEROGATORY RESPONSES 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Court 1 of Your Complaint, including: a. the exact false statement; b. the date of its publication; e: the publishing entity and title of any publication containing the purportedly false statement; d. the URL or internet address for any internet version of such publication; and e. the nature of the publication, whether in print, internet, broadcast or some other form of media.

Case 18-2868, Document 278, 08/09/2019, 2628230, Page80 of 648 In addition to her previous response, Ms. Giuffre supplements the response to include: January 8, 2015 The Sun Internet https://www.thesun.co.uk/archives/news/6754/princeandrews-pal-ghislaine-groped-teengirls/?CMP=spklr-128508300-Editorial-TWITTERTheSunNewspaper-20150108-News Lz, Identify any Health Care Provider from whom You received any treatment for any physical, mental or emotional condition, including addiction to alcohol, prescription or illegal drugs, that You suffered from subsequent to the Alleged Defamation by Ghislaine Maxwell, including: a. the Health Care Provider’s name, address, and telephone number; b. the type of consultation, examination, or treatment provided; ro the dates You received consultation, examination, or treatment; d. whether such treatment was on an in-patient or out-patient basis; e. the medical expenses to date; ‘ whether health insurance or some other person or organization or entity has paid for the medical expenses; and g. for each such Health Care Provider, please execute the medical and mental health records release attached hereto as Exhibit A. Supplemental Response to Interrogatory No. 12: Ms. Giuffre objects to this interrogatory in that it is overbroad and not limited in scope to the medical information relating to the abuse she suffered from Defendant and Jeffrey Epstein. Pursuant to the Rules, if requested documents are not yielded in a “reasonable inquiry,” Ms. Giuffre is not obligated to expend all of her time and resources on a quest to gather medical files that are unknown to her or unaccessable after reasonable inquiry. See, e.g., Manessis v. New York City Dep't of Transp., No. 02 CIV. 359SASDF, 2002 WL 31115032, at #2 (S.D.N.Y. Sept. 24, 2002)

Case 18-2868, Document 278, 08/09/2019, 2628230, Page81 of 648 - Medscare Austraha provided health care insmance coverage and payment for services received in Australia from July 19, 2013 through the present? Ms Giuffre’s claims history for this period is detailed at GHEIPFREOO761% 7620 * Dr. Wah Wah San, Ceniral Coast Family Medicine, Unit 2, 17 Anzac Rd., Tuggereh 2259, O243S (8777, tel (O24 ISS-O840, treared Ms Gauflie on March 14, 2013, for panic attacks as described in the medical records produced at GIUFFRE005339-5341, and possrbly en September |]. 2013 for “Standard Consultation “” Those records have been requcsied and a release sent to the prewides, sve GTUEF REGUT625- 7628. * (CYS Pharmacy provided presenbed medications 1 Ms Gruffre as descnbed in the records produced al GREP REGGUSS ¢-0S8 45 Waloreens Pharmacy may have provided prescribed medications to Ms. Giuffre Those records have been requested and a release provudial 3 the pharmacy, cee GUT ERE GLE FH) = Dr. Timothy D. Hartwig, D.O. was identified in records produced by (VS pharmacy, Ms Giuf¥re has requestel thase records, see GHUIFPREOGS 346-8 148 ¢ Dr. James T. Nichols, M.D was identified in records moduced by CVS pharmacy. Ms Ciuilie has requested those seconds, sce GITER POSS 349.934] * Dr, Rogolfo Torres Jr, M.D. was wWonithied i revords produced by CVS pharmacy Ms Giutite has requested thase records, see GULP EREGO8 352-8354 Dated August 17,2016 Signed, ‘ ' \ _— % rs . * Virginia Giultie * Record from Medicare Australia ace generally Tinted to Fyears Ma Giuffre is cyntinuing w purcuc addivionat cords trom pater te daly 19, 2043 (arene bear ollious a Acstroba "Ms Gaufits hes now emuicd Ds. Wab Wab San and Di Wis San to be the same provider to the best of her knowledye She had previously listed both names, i an abundance of cuution, befors Iearnine that Or Wal San was ca: sente provider os Dr Walt Wah San

Case 18-2868, Document 278, 08/09/2019, 2628230, Page82 of 648 EXHIBIT J

Case 18-2868, Document 278, 08/09/2019, 2628230, Page83 of 648 JNITED STATES DISTRICT COURT “OUTHERN DISTRICT OF NEW YORK VIRGINIA L. GIUPFE=. hauimenit. v. 15-cv-07433-RWS GHISLAINE MAXWELL. Defendant. EAL Bn eN i sh LN Beare wine Declaration of Ghislaine Maxwe!: l. Ghislaine Maxwell, declare as follows: l. Lam the defendant in this action. 2. [have no control or authority over any media organizations, including those media organizations that published any part of a January 2015 statement issued on my behalf at the direction of my attomey, Philip Barden. 3. Neither I nor any agent acting on my behalf approved or participated in any activity of any media organization in its decision to publish or not to publish any part of the January 2015 statement. I declare under penalty of pequiry that the forego 15 true and correct. Executed on January bo , 2017.

Case 18-2868, Document 278, 08/09/2019, 2628230, Page84 of 648 EXHIBIT K

Case 18-2868, Document 278, 08/09/2019, 2628230, Page85 of 648 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Se X VIRGINIA L. GIUFFRE, Plaintiff, V. 15-cv-07433-RWS GHISLAINE MAXWELL, 3 Defendant. 3 ee ee 7 Declaration of Philip Barden I, Philip Barden, declare as follows: 1. Tama Solicitor of the Senior Courts of England & Wales based in London, England. 2. Jam submitting this Declaration in support of Ghislaine Maxwell’s motion for summary judgment in this action. 3. Jam not authorised to and do not waive Ms. Maxwell’s attorney-client privilege. 4. Ihave represented Ms. Maxwell since 2011 regarding the allegations made by Plaintiff Virginia Giuffre and as published in the United Kingdom. I continue to be retained in this regard. I am familiar generally with the subject matter of this action. 5. I first represented Ms. Maxwell in this matter over the weekend of 5" and 6" March 2011, about the time when various UK national newspapers, in hard copy and on line, published numerous and provocative allegations made by the Plaintiff Virginia Giuffre against Ms. Maxwell. The articles by Sharon Churcher were among those published in this time frame. 6. Iuinstructed British press agent Ross Gow to assist me in representing Ms. Maxwell.

Case 18-2868, Document 278, 08/09/2019, 2628230, Page86 of 648 7. I caused to be prepared a statement to respond to the articles that appeared in the British Press over the weekend—March 5 and 6, 2011, and thereafter. I directed Mr. Gow to distribute the statements to various media outlets that had published articles. 8. On December 30, 2014, Ms. Giuffre made numerous salacious and improper allegations against Ms. Maxwell in a joinder motion publicly filed in a civil case involving Jeffrey Epstein. Shortly afterward, the British media gained access to the motion and began inquiring about Ms. Maxwell’s response. 9. Icontinued to represent Ms. Maxwell at that time and I coordinated the response to the media. I again instructed Mr. Gow to assist me. 10. In liaison with Mr. Gow and my client, on January 2, 2015, I prepared a further statement denying the allegations, and I instructed Mr. Gow to transmit 1t via email to members of the British media who had made inquiry about plaintiff’s allegations about Ms. Maxwell. Attached as Exhibit Al is an email containing a true and correct copy of this statement. The statement was issued on my authority. Although it is possible others suggested or contributed content, I prepared the vast majority of the statement and ultimately approved and adopted all of the statement as my work. 11. As is evident from the timing and the typographical errors in the statement, I prepared the statement in haste. I was not in the office on 2"° J anuary 2015 as it was the Friday immediately after New Years day which is a public holiday. Most people took 2"° January off and many business closed that day. I don’t now recall where I was that day but I was hard to reach and that indicates I was out with my family. I therefore would have prepared the statement in a hurry. I recall that I wanted to get a statement out as a matter of urgency. 12. Irecall that immediately after Ms. Giuffre’s motion was filed, media representatives began contacting Mr. Gow and requesting Ms. Maxwell’s response to Ms. Giuffre’s allegations

Case 18-2868, Document 278, 08/09/2019, 2628230, Page8/ of 648 of criminal and other misconduct by Ms. Maxwell. I believed an immediate response was imperative, even though this was happening in the midst of the holidays in the United Kingdom. My communications with Mr. Gow and with Ms. Maxwell were sporadic, delayed and hurried because of my and their own holiday schedules. I worked while on vacation and on Friday, January 2, 2015, to ensure that the statement was issued as soon as possible after receiving the media inquiries. 13. I did not ask Ms. Maxwell to respond point by point to Ms. Giuffre’s factual allegations in the CVRA joinder motion. What we needed to do was issue an immediate denial and that necessarily had to be short and to the point. It should have been obvious to the media that Ms. Giuffre’s new and significantly more salacious allegations had no credibility because they differed so substantially from her previous allegations, when she had the opportunity and incentive to disclose all relevant facts about being a victim of alleged sexual abuse and sex trafficking at the hands of the rich and powerful. I prepared the January 2015 statement based on my knowledge of Ms. Giuffre’s past statements and her most recent statements in the joinder motion, and made the point to the media-recipients that she and her new statements, which differed so substantially from her former ones, were not credible—specifically, that the new allegations were patently false—1.e., “obvious lies.” 14. By way of example I recall that prior to the December 2014 filing of the joinder motion and the subsequent press reports that Ms. Guiffre clearly stated she had not had sex with Prince Andrew. Yet in her joinder motion she claimed she did have sex with Prince Andrew and that the sex occurred in what can only be described as a very small bathtub, too small for a man of Prince Andrew’s size to enjoy a bath in let alone sex. So as of December 2014 it was clear Ms. Guiffre had made polar opposite statements. She was either lying when she said they did not have sex or when she said they did. I made the inescapable inference that she is a liar, as clearly

Case 18-2868, Document 278, 08/09/2019, 2628230, Page88 of 648 she is, since both statements cannot as a matter of fact be true. When someone says she did not have sex and then says she did, in other words, there is an obvious lie. 15. Idid not intend the January 2015 statement as a traditional press release solely to disseminate information to the media. This is why I intentionally did not request that Mr. Gow or any other public relations specialist prepare or participate in preparing the statement. Instead, Mr. Gow served as my conduit to the media representatives who had requested a response to the joinder motion allegations and who I believed might republish those allegations. 16. My purpose in preparing and causing the statement to be disseminated to those media representatives was twofold. First, I wanted to mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff's false allegations. I believed these ends could be accomplished by suggesting to the media that, among other things, they should subject plaintiff's allegations to inquiry and scrutiny. For example, I noted that plaintiff's allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” 17. Second, I intended the January 2015 statement to be “a shot across the bow” of the media, which I believed had been unduly eager to publish plaintiffs allegations without conducting any inquiry of their own. This was the purpose of repeatedly stating that plaintiffs allegations were “defamatory.” In this sense, the statement was very much intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct. 18. Itis important to understand that any story involving a member of the Royal Family, especially a senior member such as Prince Andrew, gains huge media attention in the UK and a story alleging he had a sex with the Plaintiff caused a feeding frenzy for the press. I wanted the

Case 18-2868, Document 278, 08/09/2019, 2628230, Page89 of 648 press to stop and think before publishing, to cease and desist, and that if they continued then they faced higher damages for ignoring my clear warning. 19. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (italics supplied). The statement was intended to be a single, one-time-only, comprehensive response—quoted in full, if it was to be used—to plaintiff's December 30, 2014, allegations that would give the media Ms. Maxwell’s response. The purpose of the prefatory statement was to inform the media-recipients of this intent. 20. Selective and partial quotation and use of the statement would disserve my purposes. It was intended to address Plaintiff's behavior and allegations against Ms. Maxwell on a broad scale, that is to say, Plaintiff's history of making false allegations and innuendo to the media against Ms. Maxwell. This is why the statement references Plaintiff's “original allegations” and points out that her story “changes”—1.e. 1s embellished—over time including the allegations “now” that Professor Dershowitz allegedly had sexual relations with her. This is why I distinguished in the statement between Plaintiff's “original” allegations and her “new,” joindermotion allegations, which differed substantially from the original allegations. And this 1s why I wrote, “Each time the story is re told [sic] 1t changes with new salacious details about public figures and world leaders and now it is alleged by [Plaintiff] that Alan Derschowitz [sic] 1s involved in having sexual relations with her, which he denies.” (Emphasis supplied.) Having established the dramatic difference between Plaintiffs two sets of allegations, which suggested she was fabricating more and more-salacious allegations as she had more time to manufacture them, I added the third paragraph: “|Ms. Giuffre’s] claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory.” (Emphasis supplied.) I believed then, and believe now, that it was and remains a fair inference and conclusion that her claims

Case 18-2868, Document 278, 08/09/2019, 2628230, Page90 of 648 were and are “obvious lies.” As noted, her claims not to have slept with Prince Andrew and to have slept with Prince Andrew are a classic example of an obvious lie. One or other account 1s on the face of it a lie. 21. Asan example of her lack of credibility, the Plaintiff made allegations against Professor Dershowitz, which I understand she has now withdrawn. Professor Dershowitz has credibility because his story, insofar as I am familiar with it, has been consistent; Ms. Giuffre has no credibility because her story has shifted and changed. 22. Further the Plaintiff's account has become more salacious, for example, regarding Prince Andrew. The Plaintiff clearly has been seeking publicity for her story and it 1s clear to me that she understands retelling the same story doesn’t feed the media and generate publicity and so each time she appears to create new allegations to generate media interest. 23. Iunderstand the Plaintiff alleged in her Complaint in this action that the following statements are defamatory. She alleges it was defamatory in the first paragraph of the January 2015 statement to state that “the allegations made by [the Plaintiff] against [Ms.] Maxwell are untrue.” For the reasons stated above, it was and is my considered and firm opinion that, in fact, her allegations are untrue. She alleges it was defamatory to state in the same paragraph that the “original allegations” have been “shown to be untrue.” For the reasons stated above, 1t was and is my considered and firm opinion that, in fact, her allegations are untrue. Finally, she alleges that it was defamatory in the third paragraph to state that her claims are “obvious lies.” For the reasons stated above, it was and is my considered and firm opinion that, in fact, her claims are obvious lies. 24. Both Mr. Gow and I understood that once the January 2015 statement was sent to the media-representatives, we had no ability to control whether or how they would use the statement and we made no effort to control whether or how they would use the statement.

Case 18-2868, Document 278, 08/09/2019, 2628230, Page91 of 648 25. Itis my understanding that some of the media-recipients of the January 2015 statement did not publish any part of the statement. I am unaware of any media-recipient publishing the statement in full. 26. The issuance of the statement fully complied with my ethical obligations as a lawyer. Indeed it was duty in representing my client’s interests to ensure that a denial was immediately issued. I would have been remiss if I had sat back and not issued a denial, and the press had published that Ms. Maxwell had not responded to enquiries and had not denied the new allegations; the public might have taken the silence as an admission there was some truth in the allegations. 27. The content of the statement was entirely based on information I acquired in connection with my role as counsel for Ms. Maxwell. 28. At the time I directed the issuance of the statement, I was contemplating litigation against the press-recipients as an additional means to mitigate and prevent harm to Ms. Maxwell. Whilst the limitation period for a pure defamation claim has now expired, claims are still being considered for example for publishing a deliberate falsehood, conspiracy to inure and other tortious acts. 29. In any such UK defamation, or other related, action Ms. Giuffre would be a defendant or a witness. 30. I directed that the statement indicate Ms. Maxwell “strongly denie[d] the allegations of an unsavoury nature,” declare the allegations to be false, give the press-recipients notice that the publications of the allegations “are defamatory,” and inform them that Ms. Maxwell was “reserv|ing] her right to seek redress.”

Case 18-2868, Document 278, 08/09/2019, 2628230, Page92 of 648 I declare under penalty of perjury that the foregoing is true and correct. BD. Executed on January 6, 2017. Philip Bard

Case 18-2868, Document 278, 08/09/2019, 2628230, Page93 of 648 EXHIBIT L

| NO OO Hs O1 OY ~] CO WO 10 i i LS 14 1D L6G Ly LS eg 20 ZA. Ze Zs 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page94 of 648 UNITED STATES DLSTRICT COURT for the SUUTHERN DISTRICT OF ‘NEW YORK Civil Action No. 15-cv-07433-RWS VIRGINIA GIUPFPRE, Plaintiff, Vox GHISLAINE MAXWELL Defendant. VIDEO-DEPOSITION OF: TAREWN BY: REPORTED BY: DATE AND TIME: PACE. APPEARANCE OS JAMES MICHAEL AUSTRICH Defendant Karla Layfield, RMR Stenographic Court Reporter NOtary Public State of Florida at Large JUMe Zo, ZULOF, 9E0S aa. Owen & Associates Court Reporters 108 N. Magnolia Avenue, Suite 501 OcGala,. FPlorade Laura A. Menninger, Esquire HADDON, MORGAN & FOREMAN, PC 150 East 10th Avenue DWeNnVeYr, -COLOrado, sBUZ03 Attorney for Defendant Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, PILSTOS -«< LEHRMAN, Pik 425 Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 ATTOrhney For Plainti re Also Present: Kenneth Sarsony, Videographer Virginia Giuffre Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 i i LS 14 1D L6G Ly LS eg 20 ZA. 22 ZS 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page95 of 648 ae At ee oe De WITNESS: James Michael Austrich Direct Examination by Ms. Menninger Cross=-Exaemination by Mr. Edwards Redirect Examination by Ms. Menninger Recross-Examination by Mr. Edwards Reporter's Certificate Certificate of Oath Bie ee, AB 1 ei PLAINTIFF L. ‘Eilvone. logs DEFENDANT Le -EWOLOgEaon Zw PaSSpOrL 34 Cirtecion: Trading (Re oorL A School Records (Exhibits attached. ) Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com PAGE G2 oe A 143 146 147 TOG 26 24 38 LG

10 il 12 Le (14 ~—« 15 16 17 18 19 20 24 22 22 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page96 of 648 Broward and Miami a lot. a mm 1O Q Roberts? A I met her. But after Okay. Where did you go to high school? Robert Morgan. Which city is that in? I guess Miami. Okay. When did you graduate? ros. How old are you now? ans When is your birthday? Do you remember a woman by the name of Virginia Yes. And do you see her here in the room today? Yes. When was the last time that you saw her? Sixteen years ago. How did you meet Ms. Roberts? She was a friend of my sister's, and that's how What is your sister's name? (ohonetic}). Last name is spelled ut I still can't spell it. My step~sister. so long, she's basically my sister. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

bo NO i) uo cn oY ~~] Oo oO 10 11 Le ie 14 i 16 Lf 18 19 20 ou 22 25 24 Z3 Case 18-2868, Document 278, 08/09/2019, 2628230, Page97 of 648 O Okay. Where is Ms. A I believe Broward coun. Q How is it that she came to introduce you to Ms. Roberts?. A She brought her to the house. 0 And do you know how they were friends? a They met each other in rehab. What kind of rehab? om I'm not sure. I was living in Miami at the time, and I only came up once in a while to visit her. At the very end, when I moved back to Broward with my dad, that's when Q Do you know the name of the rehab program? A No. 0 And you do you know what the rehab program was for, drugs, alcohol? A I don't know. I guess, everything probably. 0 Do you recall approximately what year you met Ms. Roberts? A I believe around ‘98. QO How old were you at that time? A 1B. Q Do you know how old Ms. Roberts was? A | 15 or 16, I believe. Q Was she approximately your sister's age? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 i oY LS 14 iD LG Ly LS eg 20 ZA. Ze Zs 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page98 of 648 a working at the Taco Bell in Sunrise. Did I get that EVO 2 A Yeah, yeah. O Okay. Did Ms. Roberts come to work at the Taco Bell where you worked? A Not at that one in Sunrise. When we moved to Broward, she worked with me. I think it was another one Im Sunrise. Q Okay. So you're saying sometime later you and Ms. Roberts moved to Broward. Is that right? A Yes, we lived in an apartment. QO Where was that apartment? A Oakland Park, I believe. QO And when you moved to that apartment in Oakland Park, that's when she came to work with you at Taco Bell? A Les. O Do you know about how old you were when that happened? A It had to be around -- it wasn't long after meeting her. O Why don't you take a step back and tell me what you recall about meeting Ms. Roberts. A It was a long time ago. O I understand. A All I remember is my sister bringing her over Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO UO Hs O1 OY ~ CO WO 10 i oY LS 14 iD LG Ly LS eg 20 ZA. Ze Zs 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page99 of 648 TZ one day, we got to talking, we liked each other, and we Just got to know each other. O Was she in school at the time? A No. O Why not? A I'm not entirely sure. QO Was she done with this rehab program? A Yes, at the time. O Did she go back into it later? A Not that I know of. Q So your understanding is, she was not in school and not in the rehab program at the time that you met Ms. Roberts. Correct? A Not that I know of, no. QO Where was she living when you met Ms. Roberts? A She was staying with us -- or she came over, and then I guess she was staying with us for a little while, I believe. QO And who do you mean by "us"? A At my dad's house. iS Who else was living there besides yourself, your dad and your sister? A My step-mom, my other step-sister, my step-brother and their grandmother. It was a big house. QO How long do you recall Ms. Roberts living at Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 i oY LS 14 1D LG Ly LS eg 20 ZA. 22 ZS 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page100 of 648 LS that house with the family? A Q A Q No idea. Not long. Weeks, months, years? Weeks. Okay. You said that you spent some time getting to know Ms. Roberts when you first talked to her? A Q ago. QO parents. A Uini=hmim. Did she tell you anything about her childhood? If she did, I don't remember, it was so long Do you recall meeting her parents? Yes. Was that some time later? Yes. Tell me about when you remember meeting her I think that was -- all I remember -- really, all I remember 1s going to the house and meeting her Dearents, QO ago A QO I don't remember much from that time. Okay. I appreciate that this is all a long time Yeah. Did you and Ms. Roberts become a couple soon after you met her? A wes. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 i i LS 14 1D L6G Ly LS eg 20 ZA. Ze Zs 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page101 of 648 i Q A Q that home, A Q Was she dating anyone else at that time? No. Tell me where you -- did you both move out of your dad's home, together? Yes. And where did you go directly after that home? To the Oakland Park apartment. At the time you got the Oakland Park apartment, recall how old you were? I had to be 18 to get an apartment. Okay. And do you know how old Ms. Roberts was? LO. Is that a guess, or do you remember? That's a guess. Do you think you are about two years older than About. Maybe a little more. Okay. How long did you two live together at the Oakland Park apartment? A Less -- I know it wasn't a full year. I don't know exactly how long it was. I don't know how many months it was. Q A Did anyone else live there with you? Yes, a roommate. Who was that? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 i i LS 14 1D L6G Ly LS eg 20 ZA. Ze La 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page102 of 648 15 A Mario. Last name, I can't remember. I haven't seen him since that apartment. Q Was he a friend of yours or hers, or just someone else? A Taco: Bela; Q apart umMment, well? He was a friend of mine. He worked with me at And after you moved to this Oakland Park Ms. Roberts came to work at the Taco Bell as Yeah, with him and me. Do you recall where that Taco Bell was? By the Sawgrass Mall. How long did Ms. Roberts work at that Taco Bell? I don't remember. You were a manager at the time? Yes, me and my roommate. You were both managers? Yeah. Was she an official employee? Yes. she was on the payroll? Yes. And you were the manager? Um-hmm? And she paid -- she was paid for by Taco Bell? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO HS O1 OY ~] CO WO 10 i i LS 14 1D L6G Ly LS eg 20 ZA. Ze Zs 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page103 of 648 LG A Les. QO Was it is a franchise, if you know? A I know when I first started there, they were corporate, but then they were a franchise. They were bought out. But I'm not sure if when I got there they were a franchise or not. Q GO 14 Do you know if Ms. Roberts had any previous employment before she worked at Taco Bell? A I think by the apartment, she worked for KFC for a little while. MS. MENNINGER: Are you looking at Ms. Roberts? Lae WEENE Sos mir thanking. L-Can't remember. I remember something with KFC. They had one really close to us. I think she worked Ehere [Or a tiny, tony bat. 2m nor sure. MS. MENNINGER: Okay. BY MS. MENNINGER: © Before the Taco Bell? A Or she could've applied there. It's just in my head. She might have just applied there, and didn't get it, and that's why I brought her to Taco Bell. QO Okay. A Because we were both the night managers. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 i oY LS 14 iD LG Ly LS eg 20 ZA. Ze Zs 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page104 of 648 iy Q Okay. Got it. So for not a full year, the two of you worked together at a Taco bell near the Sawgrass Mills (as heard) and lived in an apartment in Oakland Park? A LES. MR. EDWARDS: Object to the form. BY MS. MENNINGER: O With Mario? A Yeah. o Did Mario live there the whole time? A Le Sis QO What caused you to stop living at the Oakland Park apartment? A IT don't remember exactly. But I know we moved out before, and Mario stayed in the apartment. QO Where did you move to? A Her parent's house. Q Did you move into the house or to someplace near the house? A I don't remember if we originally moved into the house. But I know they had a trailer in the back that we lived in. O How long did you live in the trailer in the back? A No idea. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 ime oY LS 14 iD LG Ly LS eg 20 ZA. Ze Las 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page105 of 648 lee, > tO > tO A Q INO-« Do you Know about what years this was? Not really. Do you know about how old you were? When, what? I'm just focused on the period of time in which you were living at her parent's house in the trailer. A I was probably 18 when we moved in there. O And you said you were only there for a couple of months? A Not that I remember. Like, it might have been a little longer. I'm not sure. O Were you engaged to Ms. Roberts? A Les. O When did you become engaged to her? A When we were living in Oakland Park. QO Tell me about the engagement. How did it come about? A Well, we fell in love, and -- I believe it was Valentine's Day when I proposed. Q A > tO Did you have a ring? Yes. Did she accept? Yes. How long were you engaged? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 i i LS 14 1D L6G Ly LS eg 20 ZA. Ze La 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page106 of 648 £0 A Q I'm not entirely sure. Do you remember an event where the engagement was broken off? A Q A When I left. Left where? When I left -- Royal Palm Beach, I guess, was Our aparlLMent. Q When you left that apartment, that's when the engagement was over in your mind? A Q > tO > tO > tO > tO > tO > tO > tO Yes. Were your families happy about the engagement? Yes. My mother was. My dad wasn't too happy. Have you ever been married since then? NOx Have you ever been engaged since then? NO Do you know what happened to the ring? Yes. Where is it? I have it. SALA Ae Yeah. It was my grandmother's. Did you get down on one knee? Yes, at the beach, I believe. When you were living in Oakland Park, in this Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO HS O1 OY ~] CO WO 10 i i LS 14 1D L6G Ly LS eg 20 ZA. Ze Zs 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page107 of 648 ZO Q So from about the ages you were 18 to 20 is when you were living together with Virginia? A Q Yeah. And between the time you met her at your dad's house and the time that you broke up, did you guys break up and get back together, or was it one consistent relationship, and then it had an end date? A QO apaLrLmen: A Beach. Lou bie. Yeah, one consistent relationship. Okay. You mentioned that you moved into an in Royal Palm Beach? Yeah, I believe that's where it was, Royal Palm Do you remember anything about the apartment? All I remember, it was on the third floor. And who got that apartment? iL. aa, Again, you were over 18 at that time? Yes. So you got the lease? Yes. Do you remember looking for the apartment? I believe so. And it wasn't the first apartment you rented, No. No, the one in Oakland Park was the first Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO UO Hs O1 OY ~ CO WO 10 i i LS 14 1D L6G Ly LS eg 20 ZA. Ze La 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page108 of 648 Z0 one I rented. QO Okay. MS. MENNINGER: I'm going to show you some photographs. If I could have you mark this. I guess we'll start again with, I guess we'll start again with Defendant's Exhibit -- I got one for you. Defendant's Exhibit 1 or A, whatever you put On gee THE COURT REPORTER: 1. MS. MENNINGER: Exhibit 1. (Defendant's Exhibit 1, photograph, was marked for identification.) BY MS. MENNINGER: QO Please take a look at this. There are two photographs stapled together. Does that look like the apartment that you lived in on the third floor? A It could be. I don't really remember it. QO The address on this is 368 Bent Oak. Does that Sound: about raghc? A Bent Oak sounds familiar. O You don't recognize the -- it may have been painted, for example? A Yeah. I mean, all I remember is being on the alain <6 ae eo 8 ae Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO UO Hs O1 OY ~ CO WO 10 i i LS 14 15 L6G Ly LS eg 20 ZA. Ze Zs 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page109 of 648 Za MS. MENNINGER: I'm going to show you another exhibit. Let me find it. We'll mark this Defendant's Exhibit 2. (Defendant's Exhibit 2, passport, was marked LOY 20enlit1eation.) BY MS. MENNINGER: O I know this is not terribly easy to read, but it's a passport application that has been previously identified in this case. And in the middle section, there's emergency contact information that says "James AUSeraern Do you see that? A LES. O ES “that, you? A eS. O And it says 368 Bent Oak Drive below that? A Ves: QO Does that refresh your memory as to the address, the apartment that you lived in in Royal Palm Beach? A Like I said, Bent Oak sounds very familiar, and I know it was Royal Palm Beach. So possibly it was that one. Q Okay. And how long do you think that you lived in this apartment? A I'm not entirely sure. Less than a year, that's Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 i oY LS 14 iD LG Ly LS eg 20 ZA. Ze La 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page110 of 648 38 MS. MENNINGER: I'm going to mark this exhibit as Defendant's Exhibit 3. (Defendant's Exhibit 3, Citation Tracking Report, was marked for identification.) BY MS. MENNINGER: QO I'm going to have you take a look at this. Actually, I apologize because I need you to turn back several pages to -- the lower right-hand corner has some page numbers that say G.M. And I need you to go to 781. A (Witness complies.) Q Could I have you take a look at the narrative section of that page. If you want to just read that paragraph. A "John Perkins," I don't even know that name. MS. MENNINGER: I guess you guys haven't kept ngewe hela MR. EDWARDS: He was scared that day. THE WITNESS: (cont'd) Plus, when I left there, I didn't really talk to anybody from up there. I remember somewhat of that. Yeah, I remember the cops telling me even though it was under my name, I couldn't go in. And I think later on then they got out so I could go back and get me stuff. I think I was going to see my animals. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 i i LS 14 15 L6G Ly LS eg 20 ZA. Ze La 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page111 of 648 oS BY MS. MENNINER: @ Yeah. I didn't know if reading this might cause you to remember some things. A IT somewhat remember that. I remember the cops coming and telling me I wasn't allowed to go in my own apartment that was under my name. Q Okay. So this is dated June 10th, of 2001. And it places you at 368 Bent Oak Drive, correct? A LES. QO Okay. Do you understand that to likely be where you were living with Ms. Roberts? A Yeah. But at the time I was already back in Broward. Q Okay. Do you know how long you had been back in Broward? A NOL a Clue; O And in this, it refers to Ms. Roberts as your ex-filancé, correct? A Les: Q So presumably the event you described where you had a fight and left had already occurred? A Leos MR. EDWARDS: FPOrm, THE WITNESS: I know I was already out of there. And that's why when I went back, that's Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 i i LS 14 15 L6G Li LS ry 20 ZA. Ze La 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page112 of 648 40 when the cops said I couldn't go in my own apartUmen Ll. BY MS. MENNINGER: Q So your recollection today is that you were returning to that apartment to either get things or check on pets? A LeSi. QO What pets do you recall having? A A dog and six cats and, I believe, ferrets and rabbits. One reason we got along so well is because we liked animals. QO And do you remember going back to the apartment to check on the pets and encountering Ms. Roberts and Tony? A Yeah. O Were you inside the apartment when you encountered them? A No, outside. O Did you understand them to be living in the apartment at that time? A Yess QO In the police report it says "Austrich stated his ex-fiance, Virginia Roberts, who also resides at the above-listed address, brought her friend to the apartment." Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 Ld. LZ LS 14 ins) L6G Ly LG eg 20 ZA. ZZ ZS 24 Ze Case 18-2868, Document 278, 08/09/2019, 2628230, Page113 of 648 ai A I believe that was Tony. O Okay. And at this time, the police are indicating that you both lived there. But that's not what you remember? A No. They wouldn't even let me -- all I remember -- I remember being outside the door and the cops wouldn't let me go in there because -- even though it was my apartment and my address was on the thing, I wasn't allowed in there. Because I'm pretty sure I wasn't living there. I just came back to get something. QO Do you know how long after you left you were coming back to get something? A I don't remember. O If you left your pets there, I guess, I'm just wondering whether you intended to go back and get your pets? A I couldn't because my dad didn't -- my dad didn't really take -- like, he didn't want all those animals. Because he already had three dogs and he wasn't a fan of cats. MR. EDWARDS: Or ferrets. A (cont'd) Or ferrets or rabbits. I think we had a gerbil, mice, rats, all kinds of stuff. I know we had pet store cages that we bought to keep them all in. Because when we lived in West Palm Beach it was like a Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 Ld. LZ LS 14 ins) L6G Ly LS eg 20 ZA. Ze Las 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page114 of 648 a2 little animal rescue for a while. O Did you get that stuff from the pet store where you both had worked? A Less O A discount, I hope? A I feel like every time I went to the pet store, I got a new animal. Still do the same thing. O Do you have pets today? A Oh, yeah. I have dogs. I have two dogs. We have six cats and three birds. O No reptiles? A No. No, I don't really like --QO Is that a different kind of pet owner? A Well, I had reptiles in West Palm Beach. They are too hard to take care of. Q Spiders? A No, I don't want to be -- I have enough spiders where I live. I don't need pet spiders. QO Okey, Ald, Vigne. Do you remember Tony punching you in the face? A I don't remember. QO You see that's what the police report says? A Yeah, yeah, yeah. He might have. I don't remember. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 Ld. uy LS 14 ins) LG Ly LG eg 20 ZA. A ZL 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page115 of 648 ao O And the police observed you to have minor swelling and a large red mark. Does that sound accurate? A From according to what it says, yeah. I don't really remember that. I remember being at the door and the cops coming and telling me I can't go in there. Once I read that, that's really all I remember. O Do you believe that whatever altercation you had took place within the apartment or outside the apartment? A In the doorway at the most. I never went inside that apartment when that was happening, not I remember. O Do you ever get to see those pets again? A Yes. I think later on, they both left for the day and let me go in and see my pets. O Now, this indicates that the police were there at about 9:20 in the evening, and you were there with Mr. Perkins. But you don't remember Mr. Perkins? A NO. if te would have. said “Josh” 2 think chet might be a name I remember. But John -- I know we had two friends up there. John could have been one of them, but I don't really remember. John Perkins. That's so weird. O The police report also indicates that Mr. Figueroa observed Perkins on the telephone and fled the scene prior to arrival. Do you remember that? A No. I don't remember "Perkins". As soon as I saw that name, I'm like "Who the hell is John Perkins?" Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 i oY LS 14 iD LG Ly LS eg 20 ZA. Ze La 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page116 of 648 ae QO All right. If you can turn to the next page. The police report continues that they made numerous attempts to contact you and Mr. Perkins, whoever he is -A Yeah. Q -- and Ms. Roberts at the residence or on the phone, but had not been able to do that? A If they called the residence, I wasn't living there. And I don't remember them ever trying to call me 1m - Broward. O Do you know if you had a cell phone? This was back in 'O1. I don't even know if I had a cellphone in Ode? A Yeah, I really couldn't tell ya’. Q Okay. So your best recollection, after reviewing this report, is that you had left on a previous date and came back on this date to see your pets? A Yeah, yeah. 6 And that you were ultimately able to get in and see the pets? A later On, yes. Q Okay. Like, the same day or -A Later on. I don't really remember how much longer --- how many days later, or something. Not too long. QO And when you came back at that later time, you Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 i i LS 14 1D L6G Ly LS eg 20 ZA. Ze Zs 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page117 of 648 nae, did not encounter Ms. Roberts? A No, nobody was in the house but my animals. @ And since that time you have not had any contact with Ms. Roberts? A No. Q Okay. What was your opinion of Tony? MR. EDWARDS: FOrm. THe. WLINE SS? Arn ada.0c. That's all I really remember. BY MS. MENNINGER: O Did you believe him to be using drugs? A Les QO Do you know what kind? A Whatever he could get. @ When Ms. Roberts started hanging out with Tony again, did you then believe her to be uSing drugs? A Leos MR. EDWARDS: HORM. BY Ms. MENNINGER: QO What caused you to have that belief? A Poe kon. MR. EDWARDS: Same objection. BY MS. MENNINGER: QO What. kinds of actions? A I don't remember. All I remember is that's what Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 Ld. uy LS 14 ins) LG Ly LS eg 20 ZA. Ze La 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page118 of 648 56 A DOEEY. O You're still under oath, do you remember? A Yes. Q Okay. So you were referring a little bit to the Eime: that. Ms. Roberts: worked for Jerr? A 168% © You knew him as Jeff or Jeffrey? A I remember Jeff. It could have been Jeffrey. Q Okay. Tell me what you recall about Ms. Roberts going to work for Jeff. A I don't remember much of it, really. All I remember is that she went to work for him. I know they went to some island. I know they traveled around. And he had a house in Palm Beach I think it was. O Did she tell you what she was doing for Jeff? A At the beginning, it was massage. That's what I was. EO. O By her? A Les4 © Okay. Did she seem excited about that job? A Yess O Was she getting paid more money? A LCS O Do you know how much? A No. A lot more. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO UO Hs O1 OY ~ CO WO 10 i i LS 14 1D L6G Ly LS eg 20 ZA. Ze Zs 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page119 of 648 68 Q So she hadn't come to you before that and said, "Hey, I'm having to do something other than massages"? A I don't remember. QO She may have; she may not have? A Yeah. I don't remember. O Well, why would you be fighting about it at the end? A Well, that's because she was messing with Tony, the idiot. QO SO 1che: Lagan, “= A I mean, that's what he -- the fight's what brought everything out. Q Okay. So she was messing with Tony, the idiot, and you guys got ina fight about her messing with Tony? A I think that's what it originally it was. Because she was supposed to come home, and I think she went over there instead. That's when I found out -that's when I found out about that, with the idiot. Then, I believe the other stuff came to light. I don't really remember. O As you sit here, you think that's when you were finding out about all of this at the same time? A I believe so, but I don't really remember. QO Do you know where Tony lived? A Somewhere around there, where our other Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 i oY LS 14 iD LG Ly LS eg 20 ZA. Ze La 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page120 of 648 TZ Q A 1010OT >. SO Q A here, and You had trouble figuring out what was the truth? Yeah. But I know for sure she was with the that's the main reason. Well, you saw her with him, right? Well, I found out that she was in town, but not that's when I found out. QO Okay. Not at home -- not at your home? A Yea. O When you believed yourself to be engaged? A LCS 4 Q Okay. She was not truthful with you about her whereabouts? MR. EDWARDS: Object to the form. Toe, WETNESS: Ves. BY MS.. MENNINGER: Q A Q And you confirmed that in some fashion? Yes. When another problem arose at the apartment, the police were called, correct? MR. EDWARDS: £Form. THE WITNESS: Other than that? BY MS. MENNINGER: Q A Q With Mr. Perkins? I don't -- all I remember is that one time. I just did a really bad question, so let me try Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO HS O1 OY ~] CO WO 10 i oY LS 14 iD LG Ly LS eg 20 ZA. Ze Zs 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page121 of 648 a about being forced to do things -A No. She might have told me some stuff, but what, I don't remember really. Who knows if it was the truth at the time anyway. O And you weren't doing drugs at that time? A I wouldn't say no. I know at the end, I was smoking a lot. And I might have been doing some other StCuLE: I'm not sure. Q Okay. Regardless, you would not have been comfortable believing your fiancé was having sex with other people? A No. OQ Did she, Ms. Roberts ever tell you that she was posing naked for photographs? A NO« O Would you have been okay with her posing naked fork PHOLOGLapAS 7 A NOx QO Did Ms. Roberts ever mention Ghislaine Maxwell, my client? A If she did, I don't remember the name. Like I said, I only remember Jeff. That name is all I really remember. O Because you don't remember Ms. Maxwell's name, I assume you don't remember Ms. Roberts telling you that Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs O1 OY ~] CO WO 10 Ld. LZ LS 14 ins) L6G Ly LS eg 20 ZA. Ze La 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page122 of 648 ie GE a Oe ea STATE OF FLORIDA COUNTY OF MARION ly Ket La cbayrield, RMR, Stenographic Coure Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing deposition of James Michael Austrich; that said witness was duly sworn to testify truthfully; and that the foregoing pages, numbered 1 through 145, inclusive, constitute a true and correct record of the testimony given by said witness to the best of my ability. IT FURTHER. CHRIIFY Chat 1 am Hoe a relative or employee or attorney or counsel of any of the parties hereto, nor a relative or employee of such attorney or counsel, nor am I financially interested in the action. WITNESS MY HAND this _... Gay Of June, Z20L6; av OCela, Marion County, Phorida. Karla Layfield, RMR Stenographic Court Reporter Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO HS O1 OY ~] CO WO 10 i i LS 14 1D L6G Ly LS eg 20 ZA. Ze La 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page123 of 648 Lad CERTIFICATE OF OATH STATE OF FLORIDA COUNTY OF MARION I, the undersigned authority, certify that James Michael Austrich personally appeared before me and was duly sworn -Om the 2ord day or Wune;, 2016. WITNESS MY HAND AND OFFICIAL SEAL this day Or Witenes. 2 ave Karla Layfield, RMR Notary Public State of Florida at Large My Commission No. FF942806 My Commission Expires 12/10/2019 __ Personally Known . PEOLeSssionalLly Known x ‘Produced: Tdentirication -or FDL Exp. 07/9/80 Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

Case 18-2868, Document 278, 08/09/2019, 2628230, Page124 of 648 EXHIBIT M

The text on this page is estimated to be only 32.90% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page125 of 648 UNITED STATE ir wht er — 3 EPARTMENT OF STATE APPLICATION FOR . tT [|_| REGISTRATION s (Type or print a8 captial letters in Give ¢ ok it. Wwivite areas ody) PRN ROS ME FEE EIGEN FUE EE EGRET E RE MN EE TE NT RET RT RN ETO EE ET ESE RL BR rer Bot att tte Ue yttet e 1. NAME [First anc Wii chcdien) % i ; it ; j ; t mai it Ae 7 LAST + ; f : ] :* int i j : j { 2 pes dt Wy ‘. 2 é ‘ + z - o ' 4 ; ‘ ; ; ee ae — —.- meets = anemsinms _— ~ I eT | ; a ‘ I 5 } ~ " Frug € i nouST 075 J Date | TT | (aaa . : | ; nn ee = 0 me en ee re me - 1 > f . ‘ ‘ , | | i. Pas | 5 E j ai i - . 4 I 5 ; i a : : j ; ‘ | c 3 at - - > . "eye t : Bip a” ‘ f } DATE OF BIRTH 6 SOCIAL SECURITY NUMBER 3. SEX &. PLACE OF BIRTH itty & States os itt re PSDERAL-" Be 3 ti Mas Ton ' ’ eter mesure tel r a . ; ; , .F' * | bt i 8 ne ne te nen rere ee oe 2 awd — aun : 2 Se ~~ . HMEMIHG i RE ADOLOR S$ EYE COLGA ’ y COUPA THON oy £SS DL Co ee SS ci res (3. PERPARHENT ADDRESS “ch? NOT LIST P.O. Box Ty. if PUL) ACCES NAME * i os wit . ‘ TF 7 Saal ‘ Fy | TAKS } MER Woh 1 PVE LISE : ; ; f ’ : 16. HAVE VOR EVER- BEEN ISSULD ALS PASSPORT? 1% Po tr } Rae zm a? NAME Ht ' rey ; howd Poss t we ana i ; ‘ [ ; ! [ ; r —~ bs er . were arvenrs a EN NS TY LS OE SO SE 8 8 EE FR FRED SE PR 8 hi ee — aenren se _— on pamenetyeneny ‘ P i ; ‘ 1% POO eee y Fe De & SLATE orerel NES er mophiaieinct: tue woe ve gee erent? whee @ pre > Veto st peels ofl x 20 OS4Spcert Ce innt : j fies rguactte Tha ttopete ‘itt gan Pods tered why the pre ‘ aake ny m4 Chante - m F548 64 : ; i : i“ RAE Mate eee Ms rer rarsravctenpatee ee — . 8 As ft ad be i ee “ temp ere oa ce Mone = mal i = . $8. ERERGENTCY CONTACT ‘ Ky Yay Sarey . s i 1AVEL: PLB ; i r ‘ eS s ; ‘ prs ' b . ‘ f ‘ a » 4 ‘ ? } ; ' ; ; ; } } ‘ - 2 ee ee ~ - sma * }. | , ' ; : i bf f ' ; 5 ; | | : | _ Bind | : ' . ; i ; ; | ; ; ‘<4 j i , " “4 ' fee (SON ADMINIS TERING O i 5 id ; } ; : ; 4 | | SEs wads Fe ae gy me pane afm ang inna ~*~ _— abt ws . = e i A a ' areet' s/t eehl Gusreitont 4 Signature it: ideetitvn thas Arvest | old & ‘atm yt evasial Cstazaredsigs epriaatins in ’ yHig i f bua . Appl j ‘i areatune g ; Lees 2 HE SECEP TANCE AGENT S Lise ; > } ‘Ws ie Bet Sete ¢ et liervecti thee lborw cw ' Co ee me ee ee ee ee ee ee tt o Ben = eeapets i FOIA: 6) ae ‘ eRe mk Mee mere Se ce ce em ome nem es et | ie atieeds OF haar wists mweéHin 2 os sHpko stew ‘ Se inne . . : ‘ : ied decsamieaentes 23. APPLICANT'S (IDENTIFYING DOCUMEN | | i . 4 FOR ISSUING DPHOCE USE ONLY (Applicant « evidenre of ctiterst fi t r i t HI Bo } ' ‘eur esd ; | ty ry ae a f ; : ' ; ‘? i Pi RT Ee EO cil i yp Sat phe te gn ge Ah ths ry ane 2 a a in i rage 4 rye met t a3 2 “4 ce’ Piet ase y ; : PUP OS 29. Sy rie INS PRE iE I PAGE 21 Fs inioiwad OME W tS 1E gy. B/ FOIA: (6X6) i i ' i i i i t ee ee ee) eet ee ee ee Ge ee ee ee ee ee ee ee ee ee eet ee T2Ee Tt) EeGerratact Baurciee ~ 20 Minites* GIUFFRE004721

Case 18-2868, Document 278, 08/09/2019, 2628230, Page126 of 648 EXHIBIT N

Case 18-Agrem Blanda, Court Repnontia gd & Yideop FAL 27 of 648 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS CONFIDENTIAL VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE May 3, 2016 VIRGINIA L. GIUFFRE, Plaintiff, V. GHISLAINE MAXWELL, Defendant. APPEARANCES : FAMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. By Brad Edwards, Esq. 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954.524.2820 brad@pathtojustice.com Appearing on behalf of the Plaintiff BOLIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. (For Portion) 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301-2211 Phone: 954.356.0011 smccawley@ébsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE 5/3/2016

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Coyrt Repontiag & Yideop JAC: 28 of 648 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, Esq. Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jJpagliuca@hmflaw.com Appearing on behalf of the Defendant Also Present: Brenda Rodriguez, Paralegal Nicholas F. Borgia, CLVS Videographer VIRGINIA GIUFFRE 5/3/2016

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blando, Coyrt Repontiag & Yideop FAC: 29 of 648 Pursuant to Notice and the Federal Rules of Civil Procedure, the VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE, called by Defendant, was taken on Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150 East 10th Avenue, Denver, Colorado, before Kelly A. Mackereth, Certified Shorthand Reporter, Registered Professional Reporter, Certified Realtime Reporter and Notary Public within Colorado. kK kK Kk Ke KK OK EXAMINATION PAGE MS. MENNINGER 8 PRODUCTION REQUEST(S): (None. ) VIRGINIA GIUFFRE 5/3/2016

Case 18-Agrem Blanda, Coyrt Repontiag & Yideop JAC: 30 of 648 INDEX OF EXHIBITS 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INITIAL DESCRIPTION REFERENCE Complaint and Demand for Jury 17 Trial re Jane Doe No. 102 v. Jeffrey Epstein Jane Doe #3 and Jane Doe #4's 21 Motion Pursuant to Rule 21 for Joinder in Action Declaration of Virginia L. 23 Giuffre re Jane Doe #1 and Jane Doe #2 vs. United States of America Declaration of Jane Doe 3 re Jane Doe #1 and Jane Doe #2 vs. United States of America Declaration of Virginia Giuffre re Bradley J. Edwards and Paul G. Cassell vs. Alan M. Dershowitz FBI documentation, date of entry i7o7is Document titled Telecon, Participants Jack Scarola, Brad Edwards, Virginia Roberts. Re Edwards adv. Epstein, 4/7/11, (23 pages of transcription) The Billionaire's Playboy Club, By Virginia Roberts Plaintiff's Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff re Giuffre v. Maxwell VIRGINIA GIUFFRE 5/3/2016 31 33 36 39 41 44

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Court Repnontiagd & Yideop FAC: 31 of 648 O ta wn Q wa 4 ty HF 4 O Z INITIAL REFERENCE Plaintiff's Supplemental 46 Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff Undated Declaration of Virginia 46 Giuffre re Plaintiff's Supplemental Response and Objections to Defendant's First Set of Discovery Requests served on March 22, 2016 Plaintiff's Second Amended 477 Supplemental Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff Mrs. Virginia Giuffre resume 67 Compilation of e-mails re Open 68 Position - Virginia Giuffre Virginia Lee Roberts passport 180 application Composite of e-mail strings 251 Compilation of e-mails between 259 Giuffre and Silva and others Compilation of e-mails between 265 Virginia Giuffre and Sandra White Compilation of e-mails between 269 Marianne Strong and Virginia Giuffre Compilation of e-mails between 276 Virginia Roberts and Jason Richards VIRGINIA GIUFFRE 5/3/2016

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blando, Coyrt Repontiag & Yideop FAL: 30 of 648 DESCRIPTION INITIAL REFERENCE Compilation of e-mails between 284 Sharon Churcher and Virginia Giuffre Compilation of e-mails among 287 Sharon Churcher, Michael Thomas, Virginia Giuffre and others Compilation of May 2011 e-mails 288 among Sharon Churcher, Virginia Giuffre, Paulo Silva and others Compilation of June 2011 e-mails 289 between Virginia Giuffre and Sharon Churcher PR Hub Statement on Behalf of 300 Ghislaine Maxwell article 1/2/15 e-mail from Ross Gow to 309 To Whom It May Concern VIRGINIA GIUFFRE 5/3/2016

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blando, Coyrt Repontiag & Yideop FAC: 33 of 648 January 19th, 2015? A At the very top of the page it says January 21st, 2015. QO The date it was filed. Is there a date Just above the signature block? A Oh, yes, sorry. Yes, there is. QO And what date -- what date was that? A The 19th day of January, 2015. QO Okay. And this document is something that you believe contains the truth, correct? A To the best of my knowledge at the time, yes. QO All right. Did something change between the time then and today that makes you believe that it's not all accurate? A Well, as you can see, in line 4 on page l, I wasn't aware of my dates. I was just doing the best to guesstimate when I actually met them. Since then I've been able to find out that through my Mar-a-Lago records that it was actually the summer of 2000, not the summer of 1999. QO Oh, I'm sorry. Are you back on page 1? A On the first page. Q Okay. A Yes. VIRGINIA GIUFFRE 5/3/2016 25

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Court Repnontiag & Yideop FAC: 34 of 648 QO And you're talking about line 4? A Line 4. Q Paragraph 4 or line 4? A Oh, sorry. Number 4, the paragraph number 4. Q Okay. And what part of paragraph 4 do you now believe to be untrue? A In approximately -MR. EDWARDS: Object to the form. You can answer. A In approximately 1999 when I was 15 years Old I met Ghislaine Maxwell. Q (BY MS. MENNINGER) Okay. A I now know that it was 2000, that I was 16 years old when I met Ghislaine Maxwell. Q So when you signed this document under penalty of perjury stating that it was true, you no longer believe that to be true, correct? A It was an honest mistake. We had no idea how to pinpoint without any kind of records or dates or anything like that. I was just going back chronologically through time. And that's the best time that I thought it was. And now I know the facts, so it's good to know. Q So you now believe that a document you VIRGINIA GIUFFRE 5/3/2016 26

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Court Repnontia gd & Yideop FAC: 35 of 648 filed under oath is no longer true, correct? MR. EDWARDS: Object to the form. A I wouldn't say that it wasn't true. I was just unaware of the times and the dates. QO (BY MS. MENNINGER) Again, is there more than one truth, Ms. Roberts? A No, there's no more than one truth. QO All right. So a document in which you Swore that you were 15 years old when you met Ms. Ghislaine Maxwell is an untrue statement, correct? MR. EDWARDS: Object to the form. A It's not that it's an untrue statement. It was a mistake. So it wasn't intentionally trying to say something that wasn't true. It was to my best knowledge that I thought it was 1999. And when I got my records from Mar-a-Lago I was able to find out that it was 2000. And this was entered before I found out the actual dates that I did work at Mar-a-Lago. OQ (BY MS. MENNINGER) Okay. So a document that you filed under oath -A Um-hum. QO -- is now, you believe to be untrue, correct? VIRGINIA GIUFFRE 5/3/2016 27

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blando, Coyrt Repontiag® & Yideop FAC: 36 of 648 MR. EDWARDS: Objection. Asked and answered. Q (BY MS. MENNINGER) You may answer. MR. EDWARDS: Answer again. A Again, I wouldn't say it's untrue. Untrue would mean that I would have lied. And I didn't lie. This was my best knowledge at the time. And I did my very best to try to pinpoint time periods going back such a long time ago. It wasn't until I found the facts that I worked at Mar-a-Lago in 2000 that I was able to figure that out. QO (BY MS. MENNINGER) And approximately when did you learn those facts about the dates you worked at Mar-a-Lago? A I would say it was mid-2015. QO Mid-2015 is the first time you became aware of the dates -A I don't know the exact -QO If you could just let me finish. A I'm sorry. QO That's all right. Approximately mid-2015 when you learned the true dates that you had worked at Mar-a-Lago? A That's correct. Sorry. VIRGINIA GIUFFRE 5/3/2016 28

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Court Repnontia gd 8 Yideop FAL: 37 of 648 a lot of the circumstances that I had been subjected to, I decided I wanted to get my GED. Q Okay. So you were going to an actual school to get your GED, that's what you're saying? A Yes. O And that school, whatever it was, where you were getting your GED was not Palm Beach High School, right? A No. QO And it -- whatever the school was where you were getting your GED took a summer break? A I believe so, yes. QO And that was in 2000? A Now that we know the right dates, yes. QO And that's when your dad helped you get a quote-ungquote summer job? A Yes. QO All right. And that summer job was Mar-a-Lago? A Yes. Q Okay. Now tell me how you sort of came into Mar-a-Lago for the first time? He asked you to come? They called you? What happened? A My dad was very liked there. So I think he talked to the people who were in HR. And then VIRGINIA GIUFFRE 5/3/2016 a7

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blando, Coyrt Repontiag & Yideop FAK: 38 of 648 mic higher up on your jacket, please? THE DEPONENT: Sure. THE VIDEOGRAPHER: Thank you. THE DEPONENT: Tell me if that's okay. Better? A Okay. Page 40? QO (BY MS. MENNINGER) Right. Do you see the first full paragraph on that page? A I do. QO The first line begins: I spent my sweet 16th birthday on his island in the Caribbean next to Little (sic) St. James Isle. He liked to call it Little St. Jeff's. His ego was enormous as his appetite for fornicating. Do you see that sentence? A I do. O That is not true, correct? You were not spending your sweet 16th birthday on Little St. James Isle, correct? A Based on my knowledge at the time that I wrote this manuscript, I thought I did spend my 16th birthday there. And so I put it down in there as that. Now I know that it wasn't my 16th birthday. Q Or your sweet 16th birthday? A Well, we -VIRGINIA GIUFFRE 5/3/2016 101

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Coyrt Repontiag & Videop JAC: 39 of 648 MR. EDWARDS: Object to the form. Harassing. QO (BY MS. MENNINGER) Was it your sweet 16th birthday? A Is it not custom to call your 16th birthday sweet? Have you never heard that saying before? O Was it your sweet 16th birthday, Ms. Giuffre? A AS we -MR. EDWARDS: She's answered the question. It's been asked and answered. MS. MENNINGER: She asked me a question, actually. You're not testifying here. QO (BY MS. MENNINGER) Was it your sweet 16th birthday? A As I thought, in the manuscript when I wrote it, I thought it was my sweet 16th birthday. Q Okay. Now that you know it wasn't, where did you spend your sweet 16th birthday? A Well, I don't know. QO Well, just give us your best guess. MR. EDWARDS: Objection. And she's not going to guess today. She's going to tell you the answers as she remembers them. VIRGINIA GIUFFRE 5/3/2016 102

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Court Repo ntiagd & Yideop FAL A0 of 648 A Again, I don't know. QO Do you recall any present you actually got on your sweet 16th birthday? A No, I don't. I don't know where I spent it, who I spent it with or what I got. I'm sorry. O How long did you work at Mar-a-Lago? A Best of my recollection, it was a summer job. I believe I started in June. And I think I only worked there approximately two weeks, two, three weeks. QO How many hours a week did you work? A I want to say it was a -- I want to say it's a full-time job. QO Do you recall it being a full-time job? A It was a summer job, but just thinking back, my dad used to bring me in and bring me home. So he worked full time, all day. So -- and I didn't lounge around Mar-a-Lago so, yes, I think it would have been a full-time job. QO And how much did you make per hour? A Approximately, I think I remember making $9 an hour. QO The bracelet and earrings you got for your birthday, some birthday, on Little -- or where was that birthday party, at Little St. James? VIRGINIA GIUFFRE 5/3/2016 104

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blando Coyrt Repontiag & Videop FA: 41 of 648 QO Which brother? A Sky. QO What about your other brother? A I think he had moved out by then. QO What forms of communication did you have? Just a home phone number, or what? A Yeah, there was a home phone. QO When do you recall ever getting a cell phone? A The first cell phone I ever got was the one that Ghislaine gave to me. Q So you never had -- your parents, did they have ones when you were working at Mar-a-Lago? A No, my dad used to -- like, we had phones in the spa and maintenance area and so on, so forth. And you could, so to speak, page people from around the courts. Q Okay. So tell me what you recall of the first conversation that you had with Ghislaine Maxwell. A I'm sitting there reading my book about massage therapy, as I'm working in the spa. And I'm getting my GE -- well, I was in the process of getting my GED before I went to my summer job. I decided that I would like to become a massage VIRGINIA GIUFFRE 5/3/2016 113

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Court Repnontia gd 8 Yideop FAC 42 of 648 A Yes. QO Who else was at home when you got home? A My mom, my dad and my brother. QO Which brother? A Sky. Q And anyone else who was there at the time? A I believe Michael might have been living with me at that time. So he might have been there. QO Do you recall if he was there when you got home? A I don't really remember. I remember what I did when I got home, that I basically made a beeline for the bathroom. O Let me ask you a question. Michael was living with you at that home, at your parents’ home at the time, is your best recollection today; is that right? A That's my best recollection, yes. O When you say living with you, were you guys staying in the same room? A Yes. O Were you engaged at that time to him? A That was a really weird relationship. He was a friend who looked after me, and he did propose to me and I did say yes. But my heart was never in VIRGINIA GIUFFRE 5/3/2016 127

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Handa Court Repo ntiag® & Videop FAC 43 of 648 its He was somebody that helped me off the streets so I felt compelled to say yes to him. Q Okay. So when he proposed to you and you Said yes, did that take place before you started working at Mar-a-Lago or after you started working at Mar-a-Lago? A Before. QO And so if he were living with your parents at that time, you were living in the same room; is that correct? A I believe so. Q And your parents understood him to be your fiance? A I don't think they agreed with it, but I think they understood it as that. I mean -Q I mean, you communicated to them that he had proposed and you had accepted? A Yeah, in not such a pretty way. I mean, they obviously weren't very happy about it. And it wasn't my true intentions to ever marry him. ) Okay. A But I did it to make him feel okay. I didn't want to be mean. O What did your mom say about your VIRGINIA GIUFFRE 5/3/2016 128

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Coyrt Repontiag & Yideop FAC: 44 of 648 know where it was when she said to go do this. QO (BY MS. MENNINGER) Okay. Where were you sent to have sex with the owner of a large hotel chain by Ghislaine Maxwell? MR. EDWARDS: Object to the form. A I believe that was one time in France. QO (BY MS. MENNINGER) Which time in France? A I believe it was around the same time that Naomi Campbell had a birthday party. O Where did you have sex with the owner of a large hotel chain in France around the time of Naomi Campbell's birthday party? A In his own cabana townhouse thing. It was part of a hotel, but I wouldn't call it a hotel. Jeffrey was staying there. Ghislaine was staying there. Emmy was staying there. I was staying there. This other guy was staying there. I don't know his name. I was instructed by Ghislaine to go and give him an erotic massage. Q She used the words erotic massage? A No, that's my word. The word massage is what they would use. That's their code word. QO Was she in the room when you gave this erotic massage to the owner of a large hotel chain? VIRGINIA GIUFFRE 5/3/2016 203

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Court Repnontiagd & Yideop FAC A5 of 648 A No, she was not in the room. She was in another cabana. O And other than telling you to go give the owner of this large hotel chain a massage, do you remember any other words she used to you to direct you in what you should do? A Not at the time, no. QO Where did -- where were you and where was Ms. Maxwell when she directed you to go have sex with Marvin Minsky? MR. EDWARDS: Object to the form. A I don't know. QO (BY MS. MENNINGER) Where did you go to have sex with Marvin Minsky? A I believe it was the U.S. Virgin Islands, Jeff's -- sorry, Jeffrey Epstein's island in the U.S. Virgin Islands. QO And when was that? A I don't know. O Do you have any time of year? A No. Q Do you know how old you were? A No. O Other than Glenn Dubin, Stephen Kaufmann, Prince Andrew, Jean Luc Brunel, Bill Richardson, VIRGINIA GIUFFRE 5/3/2016 204

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blande, Court Repontiagd & Yideop FAC AG of 648 another prince, the large hotel chain owner and Marvin Minsky, is there anyone else that Ghislaine Maxwell directed you to go have sex with? A I am definitely sure there is. But can I remember everybody's name? No. Q Okay. Can you remember anything else about them? A Look, I've given you what I know right now. I'm sorry. This is very hard for me and very frustrating to have to go over this. I don't -- I don't recall all of the people. There was a large amount of people that I was sent to. QO Do you have any notes of all these people that you were sent to? A No, I don't. Q Where are your notes? A I burned them. QO When did you burn them? A In a bonfire when I lived at Titusville because I was sick of going through this shit. O Did you have lawyers who were representing you at the time you built a bonfire and burned these notes? A I've been represented for a long time, but it was not under the instruction of my lawyers to do VIRGINIA GIUFFRE 5/3/2016 205

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Coyrt Repontiag & Videop FAC: 47 of 648 this. My husband and I were pretty spiritual people and we believed that these memories were worth burning. Q So you burned notes of the men with whom you had sex while you were represented by counsel in litigation, correct? MR. EDWARDS: Object to the form. A This wasn't anything that was a public document. This was my own private journal, and I didn't want it anymore. So we burned it. QO (BY MS. MENNINGER) When did you write that journal? A Just over time. I started writing it probably in, I don't know, I can't speculate, 2012, 2011. Q So you did not write this journal at the time it happened? A No. Q You started writing this journal approximately a decade after you claim you finished being sexually trafficked, correct? A Yes. O And you started writing a journal after you had a lawyer, correct? A Correct. VIRGINIA GIUFFRE 5/3/2016 206

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Court Repnontiag® & Yideop FAC A8 of 648 Q Including Mr. right here, correct? A QO A Q A Q Correct. Edwards, who is sitting What did that journal look like? It was green. And what else? It was just a spiral notebook. Okay. And what did you put into that green spiral notebook? A Bad memories. Things that I've gone through, lots of things, you know. I can't tell you. There was a lot of pages. It was over 300 pages in that book. O Did you ever show that book to your lawyers? A No. O Did you show that book to anyone? A My husband. QO Did you show it to anyone else besides your husband? A Q No. Did you tear Sharon Churcher? A talking about, out pages and give them to No, I wrote -- those pages that you're I wrote for her specifically. She VIRGINIA GIUFFRE 5/3/2016 207

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Court Repnontiagd 8 Yideop FAC 49 of 648 wanted to know about the Prince Andrew incident. Q So that's a different piece of paper? A Yeah, that's just random paper. Q So you had a green spiral notebook that you began sometime in 2011 or 2012 in which you wrote down your recollections about what had happened to you, and you burned that ina bonfire in 2013. Did I get that right? A You got that right. QO And do you have no other names of people to whom you claim Ghislaine Maxwell directed you to have sex, correct? A At this time, no. QO Is there any document that would refresh your recollection that you could look at? A If you have a document you'd like to show me, I would be glad to look at it and tell you the names I recognize off of that. O I'm just asking you if there's a document you know of that has this list of names in it? A Not in front of me, no. O Where is the original of the photograph that has been widely circulated in the press of you with Prince Andrew? A I probably still have it. It's not in my VIRGINIA GIUFFRE 5/3/2016 208

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Court Repnontiag® & Yideop FACi50 of 648 other terms of his probationary period? A supposed 0 A 0 with the A Like -0 the Mail A picture. picture. that for 0 from the A 0 No. He went to everything that he was to go to. Has he paid his fines? Yes, as far as I know. Describe for me the contract that you had Mail On Sunday? Could you be a little bit more specific? Have you had more than one contract with On Sunday? Well, there was one contract for the And that was to pay me 140,000 for the And then two stories were printed after the amount of 10,000 each. Is that the only money that you received Mail On Sunday? Correct. Did you receive any money for syndication of the photograph? A Q A means. Isn't that what the 140 was for? I'm asking you. Well, I don't really know what syndication Did you have a written contract with the VIRGINIA GIUFFRE 5/3/2016 247

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blande, Court Repnontiagd 8 Yideop FAC 51 of 648 Mail on Sunday? A Yes. O Where is that contract right now? A I don't know. I've moved that many times. I -- I lose paperwork wherever I go. O Is it possible it's in the boxes in Sydney? A I don't think I kept it, to be honest. QO Did you ever refer back to it after you Signed it? A I know I kept it for a short while, but I mean, like I said, I've moved countries twice in the last two years and three different houses. So the paper trail is lost. I don't know where it would be. QO Did you receive it via e-mail? A No. I received it -- Sharon Churcher handed it to me by paper. QO And you signed it? A I signed it. O And then did you make a copy of it? A No. QO You never had a copy of it? A Well, I had my own copy. I'm sure she has hers. O Do you recall there being a period of VIRGINIA GIUFFRE 5/3/2016 248

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-Agrem Blanda, Court Repnontia gd & Yideop FAL 52 of 648 STATE OF COLORADO) ) SS. REPORTER'S CERTIFICATE COUNTY OF DENVER ) I, Kelly A. Mackereth, do hereby certify that I am a Registered Professional Reporter and Notary Public within the State of Colorado; that previous to the commencement of the examination, the deponent was duly sworn to testify to the truth. I further certify that this deposition was taken in shorthand by me at the time and place herein set forth, that it was thereafter reduced to typewritten form, and that the foregoing constitutes a true and correct transcript. I further certify that I am not related to, employed by, nor of counsel for any of the parties or attorneys herein, nor otherwise interested in the result of the within action. In witness whereof, I have affixed my Signature this llth day of May, 2016. My commission expires April 21, 2019. Kelly A. Mackereth, CRR, RPR, CSR 216 - 16th Street, Suite 600 Denver, Colorado 80202 VIRGINIA GIUFFRE 5/3/2016 345

O LIGIH Xd 879 $0 EGTabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

May. 23. 2010 CA$&&8-2868, Document 278, 08/09/2019, 2628230, Pagel54ofeag f° 2 Page: PANEL: [234 SEDVe 123 70606 1 Document Name: untitled AO?/. ASSIGNMENT HISTORY Monday May 23, 2016 9:04 am ROBERTS, VIRGINIA IL SCHL: 3390 GR: YEAR: 16 10 SLs A ENTRY WITHDRAWAL P E CCD DATE OD CD DATE R PF SY CL DS SCHL DESC GR PRS ABS UNX Y — RO2 101201 . W26 030702 N__ 02 01 __ 3390 SURVIVORS 10 56°31 __—*Y ~ RO2 092001 WO2 101101 N02 O1 __ 2331 ROYAL PALM HIG 10 13 1 ~ BAL 081401 W32 092001 2 02 Al __—«-2192 WLLNGTN HS ADL 30 BAl 081600 W47 081301 Z Ol Al «2192 WLLNGTN HS ADL 30 CY _ EA1 062100 W47 081500 2 _ 00 Al __ 2192 WLLNGTN HS ADL 30s CY ~ £01 081699 WO3 081699 N00 01 __ 2331 ROYAL PALM HIG 10 ~ BOl 081998 WO2 060999 P 99 01 0581 FOREST HILL HI 09 155 25 _ Y ~ £01 082097 WOl 061098 R_ 98 01 2331 ROYAL PALM HIG 09 147 33 ¥ _ E01 082097 W22 082097 N__ 98 O1 2191 WELLINGTON HIG 09 ~ RO3 040797 WO2 061197 P _ 97 01 __ 1691 CRESTWOOD MID 08 40 5 ¥ ~ EOQ1 082294 DNE 082294 N95 01 __ 1703 ROYAL PINES sc 06 ~ BOL 082393 WO2 061094 P 94 01 1901 LOXAHATCHEE EL 05 167 13 __ ¥ B01 062592 WO1 061193 P 93 01 1901 LOXAHATCHEE EL 04 176 4. ¥ PF1=HELP 3=EXIT 5-REFRESH 7=BKWD 8=FWD 9=NEXT PAGE 12=ESCAPE PAGE FULL...CONTINUE. TERML: I1B5 GM_00888 Date: 5/23/2016 Time: 9:05:36 AM i

The text on this page is estimated to be only 32.45% accurate

WILNSQISNOO L86rv00Sy55NID NVIGOLSNO SGYOI3Y f gogz =i udV WAaIdOTS ALNNOI HoOvas Wid 3O LOWLSIO JOOHDS SHL LdIYOSNVUL WiIdiss0 daLOWCdd ATTWOIWTCWOV QALOWONd ATITWOIWaAawow D *LNMYSHY O *LNASAad-SAVG SWHAL YAWNNS 0 -LNYSAY O ‘LNASSYd-SaAWO SWUAL AAWNOAS b *LNHSHY 94T *‘LNASHYd-SAVd TWANNV £66T-Z266T 0 ‘LNASYHY 0 *LNASAUYD SAVC TIWONNV T66T-O66T o0°O oo'a ‘WHaL ‘LIGEHo oo“ ze 6ZbS‘'T =-WOD O0'S 98Eb'°T ‘Waa.L-aLvis 90°00 00°O A HOWAD HLUNOT OOTOOLTS £€ OD'LZ 6ZbS'T ?WND oOO'S 98CP T *WHaL-IOINLSiIa NudWd/*LLW duo OWld vauyv HILIL ASUYNOD #USANOD L Sid ALO vaio Sld ALO wad LIGdaO SSHO LOarcanas PO :-THAST GGWAD F661T-Z66T tHWHK WN *THAST AGWYD Té6ET-OG6T tue ‘WETS SHAOKD HEHOLVHYXOT TOGT ‘*IOOHDS 06 :LDTHLSId NaXdW.L SASENOD ON OGEE *IOOHOS OS ‘LOrlNLsta Ga.LONONd ATIWOINEGWOY 0 .INNSadyY 0 > LNASaadd-SAYG SWHEL YAWWOS 0 -LNASHY oO >LNESAXd-SAVG SHER NAWWOS 0 “SLNASHY O8T ‘LNASS&d-SAWO IWONNY Z66T-T656T ft >INASHY 0 *>LN@SZYd-SAVG TWONNW O066T-686T 00°0D aD'"0 ‘WAAL ‘LIag4s 00°4Z 6tbS‘T ‘WND aDo’S 98Zb' TT *WUAL-aALWLS 00°00 00°*O d AQWaD CuIHL O6co0ets € go'Lz 62hS*°T ‘WOO AD'S 99CP LT *-WHEL-LOTuLsta NUWS/" LLY GHD oOWla Va GTLIL SSYNOOD #HSHNOD L Sid ALO Wad SLld ALO Wd LIGgao Sao Loarains €O ‘THAS'T ATVHD Zé66L-T66T ‘4A WN ""IHAS'T 3QVAD OG6GT-68E6L :AWHA Wa'la SHACHD ATHOLYHYXO'T TO6T *IOOHDS OS :LOIYMLSsrag NEYVL SASHNOS ON O6EE *IOOHOS OS :‘ LOTMLSId #m arm ema en nn meee He == --s --- NOTIWWHOAN1 HSAMOD --------- --- ee ee ee we e eee eee e 6661/80/60 t LG661/'z/90 Z L66T/AT/ FO T ASOdt @ daH L86T/b2/ ro T SHISVAN L661/8T/t0 cf LS86T/b2/to T YWW LOGT/ 2/0 T IH B836T/LO/E0 + LR6T/EZ/*0 —€ 8éet/to/zo € E86L/20/TT I OLIOd L66T/62/90 E al, BHHT/L2/60 S LBET/PZ/tO bP 6§E6T/LZ/t0 £ bBéET/EC/TO f E861T/2Z0/TT T LL ALY #soa aivwa ascu aLvad asog ALYG ASOd aLVG asod Sd AL *aLVG NOLLIWAIdXS SIWDIAILYYD ANIOOVA -HLVG ‘'SNIWLS SANIOOWA ALVOLS1LYHO NOILYZINOWNI LNANYWHSd ‘SOLVLS NOTLYYINONWI Wo OLNSAWYOVS = 8OWIdGH IN@ava SLYadOd NNA'l I ‘NOILWVOIALYHA HLYIG LNA SLYAGON ANS 4 :xXdS mM =, ‘(A000 /AWYN) NVIGYwnD/LNaavd OO0CO000000 Far UNG ¢ INVYOIW *SWITW-G1I LNHUILS Id 9090Z0ZT ‘dI LNAGALS LOINLSiId 6Q0FEE ‘ld HOWE WTWd SH OLeEE ‘Td HAIHOLWHVXOT ‘ Ssuuday JAY SSSYONOD N OTET TA ARTHOWU 6962T ONI'TIVA OORT-ZTL (TSS) ‘I VINIOUIA ‘S.LHS8Ou *AWYN ‘Tyoa'T NIOOHOS UALUWHD SHOATAUNS OSEE *IOOHOS LNEAANO tT dowd HOWdY WIV OS *LOIWMLSIC LNANaNO | p/EQ * AL : OL -THAGT AadWAD SIctsLas -a'lid NOTIYWUOINT OLTHIWYNOWAA O6FE *TOOHDS HOWGE WTWd OS00000 :1OTMLSIa OL 8179 $0 GGTabed ‘0€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 42.33% accurate

WILNSQISNOO c86v00Sy5S5NID NVIGOLSND SGYOOSa B002 «oT ud¥ YOIMOTS ‘ALNNOOD HOVSS WiVd JO LOIWLSIG WOHOS JHL Id IMOSNVAL WIDId30 Ga.LOWOAd ATIVOLIWACYOV 0 ‘“ENISHY 0 *LNGSSHd-SAVG SWUEL SSWWNS S “LNUSHUY OF <*+LNASSdd-SAVG "IVONNVY £661T-966T oo°-Oo 00°90 (WHaL ‘LidgaHo 00°O 00°0 o OHD GNV WHO? WO Ta r/W OSOEOLTZ E AVIA IOOHOS AO ANA IW TI-a ADTALSIO NI GaTIOUNGT LON 00°0 GO*O o € IOS 8adWoOo C/W OOTZOOZ £ 0 “LNAHSaGY 0 ‘LNGSAUd-SAVO SWHAL SAHWWOS 00°0O 00°O a & HIWW ©/W OLOSOZT €£ 0 “LNISHY 0 *>LNESAYd -SAVd TYANNV 8H4T-L66T O9°O 00°O a £ SLYW ONWI C/W OLOTOOT £ 00°n o0°0 2 SHONATIVHD NAAL OFTO0SS Z o0° ET T2ZS56°T ‘WND OQOO°ET T£S3'T ‘WIL-SLYVLS 00°o 90°0 Vv c= WWWHd C/N OTO00PO Z DO" ET TZ2S8°T *‘WOD OO°ET T458'T *WIL-LOIULSIG NUvWa/ LLY duo Owls vadv ATLL ASHNOD #4S4NNOD L Sid ALO Wdi? Sld ALO Wd LIdadyo aSao Loacans 80 =TAAR SCWHO LGGT-966T 'HWAR 00-6 OD'L ?WHdL ‘ LIGaHYO “ITQGCIW GCOOMLSHUD T69T =“IOOHDS OS '.LOTHLsida 0S‘0 OS‘O v cf oOSs IOS Wds/HLYA OTETOOZ S 0s°0 0s5°0 q ar WW VI VWHHeOTW OLFOO0TT & AVWSA TJOOHOS dO GNS LV ZI-N DLOINLSIO NI Ga'IIOUNS LON Nava /‘iLv GUD Owla wadw AVLIL ASanoo #ASHNOD L 0 ‘LNSSHW 0 ‘INASSad-SAWGC SWYSL NAWWOS LIGAXS asa Lowrans 0 ‘INGSey oO -LNASSHd-SAVA TWONNW S6GT-P66T 60 ‘TAR S0VAD 8661-1661 tAWAA AYWNS ONIHOWHL YAHLO - ASH FEOK6 FIOOHDS OG ‘AOTALSIG 900°2z 6ZbS‘'T ‘WND O00°S 987° T *‘WURL-aALYIS 00°42 62bG‘°T ‘WHO OO'°S S8EP'T *WAAL-LOLNLsia 0S"0O 05°90 a f 15 POND LIND GTHOM OOEEOTES Z Skld ALO WdO Sid ALO vd5 0S°0 045°0 W Pf Os IOS VdS/HLYA OTETOO? Z 0S°O 0S°0O YW fa ad Lia Sddd OOETOST Z WN *TGAD'T SQWHD S6G61T-f661 *YWHA 0S°0O 0S‘O a ar WW WI WHHUD1lY OLEDOZT Z N3NWVL SASHYNOD ON OGEE *JOOHDS OS :LOIULSIAa 0S'O 0S‘O W cy xg T PNA OTELOOT Z 00°O OS‘O a OA SSANTITSM 8% NOLLIULNN SSt00S8 T CaALOWONd ATTIWOIWACYOV 00°'O OS‘O a cf Ta SHIGA.LS NVARHLTaVS OTFOOTZ T 0 “INGSHY *LNISHHd-SAVG SWUEL YSIWWNS oo°O OS‘O di ros TOS WdS/HLYa OTETOOZ T eT <LENASHY 497 ‘LNASSHd-SAVU 'IVONNY $66L-E66T 00°O O0S’O ‘ C ad SOTHOARY DAD OOPESOST T n0'O 0¢°O a ur tw WI WHASOTY OLEQOZT T O0'O oon (WHAL ‘Ltaayo 0S'0O 0S°0O a ra Na T DNA OTETOOT T GO'O 00°O d SqWaf HLAIIA OLLOOTS £ oo'O OS‘O d ra 4 T HSINVAS OFEBOLO T OO'O O0°'O d aaqwa HLAITA OTTOOTS £ Nuva / LLY dud OWld VWauv TLL ASHNND #ASANOD I. NAWH/* LLIN dup Owls wary AILIG FSANOS #9SUNOO L LIGHYO NSUYS LOCAAS LTdado ASAD LOArKOsS 60 :THAR1 JGVYO BE6T-LE6ET 2 HWAA GO ‘THAR S0QVWAD FPGEET-E6EGT “AWHA SIH WWOD HOWE WIWd TYAOU TEE? *JOOHOS OS ?‘LOTHLSIa ‘WET SSAOUD ASHOLIVHVXOT TO6T *IOOHOS 0S :LOLTaLlsia OO8tT-Z2T4A (19S) TI VINISNIA ‘SLYASON + AWYN ‘TWDA'T YOOHOS HOLYVWHD SHOATAHOS OGEE = TOOHDS LNawANS c¢ dpDVd HOWE WTWd OS *JOTHLSTIO NAAN ROOC/TE/EO fA ‘ mene JL SIlCtSLYS -y TI NOLINWHOANT daSunoo Ob6tt ‘IOOHOS HOVHH WIVd OSN0000 *LOTHLSIG - OL ‘ ¢ 8179 $0 9GTabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 41.65% accurate

WILNSQISNOO es6v00Sy55NID eae NVIGOLSNO SGNOOSY g002 = YdV WOIMOTS ‘ALNNOSD HOVaS Wivd 4O LOWLSIO WOKIS SRL Id IMOSNVYL TWIdlss0 MWA IOOHDS AO UNH IW ZT-M LOISLSIC NI CATIONNA LON 0 7LNESHY 0 ?INSSENd-SAWA SWART AAWHNS 9 ‘INaSHY 0 > LNASHYd-SAYO TVNNNY 0007-G6é6T 00°L2 6ceS'T *WND O0°S 98Zt' 1 WAS ALLS oo'L?e 6Zes't :WNO O0°S 98Zb'T *WUAL-LoIeLsid Bld ALO wad Sld ALO Wdd ATAVOIIWddY LON SOLWLS NOILLONOUd VN (RAST AMWHYD O00T-666L *YWSA 0 PINUSHW 0 ?LNASHNG-SAVC SWAAL ABWWNS NeWW.L SASHNOO ON OGEE *IOOHDS US *+SLOTALSTO 0 2LNASHY 0 ?LNSGHYd-SAWd IVNNNY c00Z-TO00Z GSLONONd ATIVOIWACWOV 00°L2 62S'°T *WHO 00'S 987? 1 ‘WHML-SLVLS 0 ‘LNSSdyY 0 > LNUSHAd-SAYG SWUHL ASWNNS 00°42 6ceS°T (MND DO'S 98ct Tl ‘WHNSL-LOIALSIA SZ <cGNESEGY SSL ?LNSESSexd-SAWC "IWONNY 666T-866T Sld ALO wd Sid ALO wd 00° 22% PLLS°"T *WND 00'6 LG8Z'T ‘WHSLL-aLwis co's OS‘E (WHaL ‘LIadsyo 00°22 PLLS°T *WOD 00°6 E582°T *Waua-LOLaLsra co°o oot a OA LPO-dXH AYOM OSITOLH L SLld ALD Wdd Sld ALO wap od°'0 os'o ~ 6h OA tT dXS WuXOM OT9LOESB T 0S5°O O5°0 a OA STIVWILNSSSH SOWIdHAOM OTEOOEB T OO°E NOL. ‘WHaL ‘LIGAYo 05°90 aS'O oO o WW HLYPl] MEWASNOD OLESOZT T 00°00 05°C a Cf HM LSIH (THOM OTEGOTE & 0s°0 05°00 @ L NG Tl ONE SSANISOA OFPTOOT T 00°O OS'O i CY os T ADOTOIW QTEOQ00E = 0s°0 05°0 Vv la b ANG HOS‘awoO'SUMad OFS00GO0O T 00°00 0S'O0 a AL YW Al WuasoOTY ORF00ZT & MW / LLY Gap owla wadv SILIL asunoo #asunoo 2 00°0 0OS'O do Lu NG ZONA OFFTOOT 2 LIGayYO asa Lowranas 600°0 05°0 @& fd WI TAS LWOW AITI-THLTVSH 00F0080 Z Ot <IHZAW'] RAVYD 2OOZ-THOZ *AWGA 00°0 0S'O0 a rata T KONAYA OTELOLO TOOHDS WHLYWHD SHOATASNS O6fFE *TOOHDS OS ‘LOTMLSTAd 00°90 05 0 BI Ta T ABQ HOS‘HWO‘SHed 0050050 Z 0oS*O OS'O > ca HM TSTH (THOM OTE6OTE T a1aqvOIlddw LON SOLVLS NOILOWONd 05°0 05°0 WY LPH os T ADOIOIAN OTEOOOZ T 0 -LNNSdy 60 ?LNASSHd-SAWO SWHHL YEWANS OS"U OS'O a 14 SSV1ID GA NAATUC OOLOOET T 0 ‘LNHSHY 0 DLNASTYI-SAWd IVANNY TOOZ-000@ VO'O OS'O 4a uf VW HI wuago Tw ose00ct t 0S°0 0S‘°O vw ca Na Z ONA OPELOOT T 00°42 67¥S*T *WAD 00°S 99Zb°C ‘WIAL-GLVLS 0S‘o OS‘O ao fa T HONGTYA OZELOLO T OO0°LZ 67*S°T *WND 00'S 98Z2b°T ‘WHAL-LOINLSIA 0S5°0 0S'°O a 1a T ADO HOS ‘HWO’SHNa O0S00S0 T Sld ALO Wadd Sld ALO wdd Nava/*Liv dup pwd vauv TILIL wsSdnod #asanco 1 LILGgao ISuO LOACANs WN <TSAS'] SYOWHO TOOT-O00Z *AWAA 60 “"IMAS'T SQWYD 6661-8667 *AveA NOYWL SasunoOO ON OGEE ‘TOOHOS OS ?IOTHESTO HOIH TILH LS®WOa T8S50 *IOOHOS OS *LOLaLSTa QOB8E-cIL (195) YT WINIDNIA 'SLYAAON *AWYN ‘TWOA'T NOOUDS WALYVHD SHOATAUNS O6EE *TOOHOS JNAMANO £ dowvd HOWSH WIVd OS ‘LOTALSTG LNaAANNO ) , dq Qsavda Tete SICTSELAS ‘aTI4 NOILYWHOANT 4SHNOD OF *"IOOHOS HOWSH WTYd OS00000 ‘LoOTYLsSTa OL 879 $0 /GTabed ‘0€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 35.51% accurate

NVIGO1SND SaGYNoOoaY * 8002 = Mdy YOIWO13 ‘ALNNOD HOV3E Wivd JO LOWLSIO IOOHDS SHL IdIYOSNVYL 1VIDI44O FERRE EE EE EEE EEE EEE AE HE EEEF EEE tHE eee the etn ay “aLvVd+ + -HaALYNOLS+ + + + ‘RA GHIAILaaD+ LEAF FEE HE RA AAE EEE FEES FEA E EEE HEE PEED EES SY -_>_ + + + REESE REFERRER ER ERE EO RET EEE REE ER v OO'LZ 62tS°T -HLVLS O0O°LS 62%S'°T *LOTaLsia * Sld ALO Wdd Sld ALO waD * sSLaW ANIA WeOdead FF TWNOILYWOOA AGOIONI S'IWLOL « « ‘ oo°stT 00°t2 00°6 ‘MAILWINWNNOD ‘'SLICHUD « * 00°O (35) aad waloawod ’ N ° LAW LNaWS A LOORY 0 ‘SYNOH ASIAWTS ALINAWWOD « OO°O (xs) asa : + os'9 00°6 00°2 (TH) SALLOATS * ZOOT/TO *SOTLIVWUHLYN * n0°O (SS) sarIon.s TwrIo0es * TOOZT/OT *SNOILYOINOWNOD * 00O°O (WI) SLaW SSVvODONW * SaSOdeNd NOILYNGWHD 4Od LSAL LNANSSHSSY GHSSWd HLYG «+ 00°O 0S°O (%4d) AOWNONWIT NOTHYUOI « * 00°o 0S°0 0S6°O (dé) GA TWOISAHG * tT7 -SSV1IO NI YAAWON 'TWILOL ‘YNWH SSWTD r os'o oso 0DO°O (WI) STITIUS LHOW BATT «= OL ‘A ILLNEOQNAd ‘ANVA SSWIO . ¥0S°0 ¥O0'E VO°O (dd) LYW ANTS Waodygad -« S93 S-NOLLISOd TWOTMAWON ‘HNWY SSWID # oS°0 /OA) /TI¥NOLLWOOA * c007/90/€0 -ALYA FZALLONAde -ANVH SSWID LOIALSIaG « 0s"o 0Ss‘*o 00°O (DW) JLNSWNYSACD UAW -« * os’*0 0s "O 00°0 (98) SOLWONODA * ‘OALea'IdNoo SSHAYDONd NT ‘NOT.LVNIWASLL * os"o 00°T 0S°O (HM) AYOLSIH aioM * LOO-dX8 WYOM OS9TOES *XSAWON + 00°T 00°T 00O°O (HV) ABOLSTH YSWV * -SOLYLS NOLLSATAWOS WWUDOUd ‘TYNOTLYWOOA a ost OO°E OS*T (OS) AONAIOS * ‘CaLa'ldWoo SSauoOdd NI *NOILLYNIWASL * OS ‘T oor OS'T (WW) SOILWWSHIWW ' 1 dX YHOM OTSTOES > USHWNON * 00°Z OO'R 00°2 (NA) HSTIDNA + “SOIVLS NOLLETdWOD WWHDOUd TWNOILWVOOA « ONINIWNSN OHGHEN SLYd O12 Vauv r :CALaATANOD SSHua90dd NI ‘NOLLYNIWHSLL + TW.LOL TWLOL WLOL LOCUS ' STWLINASSS BOW MdNIOM OTEOOES *NeaWON 7 7 SLIGHYD - - - - + -SOLWLS NOILLATAWOD WwuDvo0dd TYNOILWION +» C4VGONWLS HWA~b ‘NOILLdO NOLLYOGWUD « ‘(A LaIdWoo SSHa9Cdd NI *NOLLYNIWASLL + + SSANTTEM S% NOILIALON SSt00S8 *‘NaaWoON + HO0O0Z/LE/ED i400 SY * -SOIWLS NOLLATHWOD WWHSONd TWNOILLWOOA sanseee KRAYWW OS HAI LY JT OWN D seareue OOBT-ctTL (TIS) ‘l WINIDHIA “SLYSHON ‘GWYN Toa TTOOHOS HELAWHO SHOATANOS OGEE = TOOHDS ILNAMNND be Dvd HOVSE WIYd OS ‘LOTaLSId INA SQO0Z/TE/EO = { fae \ ST2TSLas ‘AMA AYUWWWNS NOILYWNGWAD O6€f | "ICOHODS HOWSH W1Yd 0S 00000 . ' £ “LOLELSIG - OL WILNSQISNOO y86v00Sy55NID 879 $0 BGTabed ‘0€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 38.85% accurate

“STWOS ONICWHD G2LVLS ONIGIDSHd AIELWIGHNWI AHL NI NMOHS FSOHL SY SHWS AHL WHaM SHQVHD AAHLO ITY ONW SLNIOd ALITWNO ‘P9-0 = 3 GNW ‘'PL-S9 = CG ‘’FB-GL = OD °SHaM 4 ONY ‘d ‘'D HOA SLNAIVAINON SOWeHD AHL ‘Sawa SSHHL ONTXNG IOONDS HDLH ONTYALINA SLNAGCNLS WOA ‘SHUWAHA 'IOOHOS L661-966T AHL HDNOYHL 886T-LE6T SHL Woua ‘LON p0°OQ 69 - 90 = 4 00°T ae. Th = 00°@ PS - bb = ww D0°E 6 - S8 = OH0° b OOT - 6 =- ¥ SLNI Cd INSTYAINGS savay SLNTOd INS TWATNOR aavad S.LNT Oct INATVAINOD wavy ALITWNG aawuyp ALITWNO ava ALITWOO waWwHD TOGT/1G/20 OL MOTUd ‘STWOS ONIAGWUS ooo 6S - 0 = oo'T 69 - O9 = 00'2Z 6L - OL = oO 00°€ 68 - O8 = 00°? OOT - 06 = W S.LNT Od LNS'TYATOOS wawan S.LINIOd IN#'TvAIOOR SAYND SLNIOd LNS'TVAINOS wavHp ALITWOO yaway KLITWNO aavep ALITWNO aawup To0c/TtO/LO SALLOgsag ‘ATIWOS ONIGWHD 866-466T WWHA JOOHOS GATLONada (SALWT AMINA AO SSHIGHWHDaAA) SLNEGALS IOOHDS HDIH Nod AINWOS ONTOWAD AIWIS SYWHA 'IOOHDS NGSMLAG NMWACHLIM SAVH OHM SINSGDLS ONILYOds4 BOT AINO aUsn evs (NOILWINGE TWNOLLYDOA AMYONOOGSLESCOd CUNY TWUSNAO LINGW) NOILVONGa LNSWdOTSANd AONOaWUOM BOs AINO GQHSN vse ONTAHHaaCedOod a TOOHOS UNNOU-aWaA LIM (SNOISSHS IOOHOS YAWANS 4O GVS.LSNT) amsna + ««s LNSWTTOANANON y HALAWNO 6 *S NOISSHSYALNI xX 9 SYS9M XIS O JO MVHR & £ waLaWNO 38 *® NOISSRSAUINI M *edS4NOO LYOHS YW ¢ SYN9M xXIS N S YRLSHWNTNG 1 ZumLawnO £4 *€ NOISSHSMYSINI A 2 NOISSHS VAWWNNS G ’ SHYSQM XIS W b YUSLSSWNINO 4H T HALAWNO 39 #¢ NOISSASHSINI Of Yt NOISSSS WAWWMOS € SYSHM XIS TT € WELSAWNINO 29 f UALSAWIAL d #l NOISSSSYAINI L ‘TWONNY §£ ¢ S4S3HM XIS wy & USLSAWININO © MALSAWIAL 3} NOISSAS © UALSHWNS ¢ Lt SHguM XIS Il MSLSHEWNINGO Tl YALSAWIML 8A WAWANS OXNIGWOD § T WALSAWHS +t NOLLINIASC wa0D NOLLINIJ#a@ aqoo NOLLINTASA Ado0D NOILINIASd Zao] NOILINIGHO aqdoo Wnt tne tenn cen nee ne eee ee ----------- SAdOo WHEL dO NOLLINIARC -----------~---++-++----------~-+--------OO8T-ZTi (T9S) I WINIONIA ‘'SLYSHON + AWYN ‘IVEDH' NOOHDS UHLAVHD SYOATAYNS O6ee ‘TOOHOS .Nein> = as S dDVd NOVA WIVd OS *LOTHLSTC Naan BNOC/TE/EO ‘RLV GaaWwdadd OT ‘THAGT dadvay SIctsSLas ‘Alida SLNAWWOO O6EE *"IOOHOS HOV WIWd OSOO000 -‘LOIUYLSIG - OL WILNSCIANOO S86v00Sy5SNI9 879 $0 6GTabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 36.28% accurate

TWILNSQISNOO 986v00Sy5S5NID ‘SHSUNOD LICAYO TTY SHQNIONT Vad IOTSISTO AHL ‘HHAHMOH "ZT - 6 SAAKHO NI NGYWL SSSHNOO NOC GaSVH SI LVYHL FOWUASAY WdD GELHDTAM V ONISN NWVIMOLVLOTYS aNnw AVINGIOLGLIVA TOOHDS HOTH AHL SCUWMY LOTULSIG TOOHOS ALNNOO HOWAE WIVd SHIL Wn ne nn nan nnn ne rene ete n eee eee e ei --8-- SLNANNOD Z66T-I66T Ad -------- = a NOTLOONALSNI WSaed {(TANTVINOO-FISS AMVLNAWATA) NOTLONALSNI OSH 4O/? ADWNONWI AWOH=a NOTLOOYLSNI SOVNSNY'T SAWOH"W “NOLLJ04LSNI Td LSIT 4SHYN00 NO SANIT ONIMOTION NO QATAIONdS ASUNOD wOd ALALILSaAns=. OLtevUe LOS AHd Oa aNs=$ IFELOO IQS ANT wOd aNse# OfbO00T HOAL OTS Yor ANS=e WON AdIT Od GOS ANLAYW DLOW'=0 IWOW adI'T 804d ANS AWAY OLOUL=0 AOQNATOS NOaA ANS AAVN OLONr=m HONTIOS WOA ANS Oa BIV DLOUL=A @DNAIIS YOd ANS GD LSD DLoul=wW OOCOOZT WudNOTW 3¥d wos ans=e OS€300Z OLSAHd JYNY 4Od aNS=L OT€Z00Z IOS NAD wOd ANS=9 CEESOZT II/OBESOZTT IT YW Os aNns~s OFSSOTT I WW HOA ANS*F OSGFTOOT IT/OPFTOOT I NX SOB HOA UNS=t OFFIOOLT I NA SNE wos ans=z BLYY TWOLLOVGd WOA ANS GH dWOD#T SL4¥W WOILIWad doe wos DWLOXC=0 SLAY OVdd 4YOd FOS WSTTWNHNOLA=S$ LWOW Sal YOd ANS OF AIV OLOAL=" “SASHNOD NOLLOALILSHOS TWNOTLYOOA ASUNOD AAYAAASNVAL=1L WYXS daTS Al GAQSvMY LIGH¥D=s ssausoud NI Sil ysunoo=d WI ALWLS WOud AGNISXa=M va Woua Fantoxa=x Wd NL ACWIONI=I LIQGYD ON=N SaONOH=H ee Uadvus HLNIN=6 INAWANTNOSY-AYIOHIS DIWECWoOW=u HALLO19 -YWIOHIS OIWACWOW= wees en nnn enn nnn - == 8 ~---~------ SOWIE ASUNOD GUNTAH ALWLS ------------------------------+----+-OOBT-ZTL (T9S) T WINIDULA ‘SLYXHOd fAWYN TYDST TOOHOS UMELAWHD SHOATANNS O6EE = IOOHDS LNAANND a 9 ddd HOWaAdH WTVd OS ‘LOTYLSIG LNA BO0C/TE/EO ‘ALVA GaaWdead OT “THAW. BUWHb SI2ZtsL~Lys ‘AWA SLNAWWOO OEE ?TOOHDS HOWAE WIVd OS00000 + LOIMLSIO = O« 879 $0 O9TAbed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 33.31% accurate

TWILNSQISNOO Z86v00Sy5S5NID 0000 dN STANS/SS 0000 SS ATANH/SS 0000 dN GODNaIOS 0000 SS HONEIOS PEOo dN AIS/soOed 65640 SS AIs/qoudd S800 dN SHauYdWOD TO80 SS SHAMINOD «4T V fl a66T/O07/tO 6O 0000 GD ASVNONW'I 000¢c a9 (4)dvaa LOU dO (.L)HIVW 0000 G5 JINGLOL WoL aWL oOo00z7/ST/90 OF 0000 AD dOVNONY'! 9tTO0 AD (L)avaa 0000 4a) (.L)HIWW 0000 ap LWELLOL 7 i HYL O0002/ST/90 OF OLTO 3D ADWNONY'T oo00c aD (L)avamu 0000 aD (1L)HIVW 0000 HD LYELOL WL WL O00Z2/9T/90 OF SIAL HdAL LNLNOO Ad AL adAL LN&LNOO Hd AL adAL LN&LNOO WHO4 WYN aLY¥a dup qaoas auoos LOAPHNS AHOOS AwooS LOH’aNS AAODS WAooOS ELOSCUNS WAST LSAL LSAL ‘NOTINWHOANT LSM. ~+--- +--+ --------------------- --~~----- NOLIWWHOANI SHI --------+-----------------+--+------------AQNYWHOdSad DWUWOY UCAYdWL ULNWODOG TNISSHOONSNN ATIWOINAGWOV SWUDCUd AALLVNAALIV TYNOTLYONGE SONVWAOdEAd OWUWOW CAYdWI GLNWnDOU TNHISSIOONSNN ATIWOINEGWOY SWUDO0Ud AALLWNAALTY TWNOT.A.WONds NMONVWHOAMNa OWOWVOY CAYMWIE GLNWODOd TNASSSHOOUSNA AVIVOCIWaACYOV SWUDCUd FJAILVNAILTY TWNOLLvondaa SHWOD.LNC SNOSWSY .LNAWSOV'Id WYXHDOUd NOTLINSATNd .Loodoud odeteeteetetetattedtateteletatetat ttt ttt NOT.LWAWHOANT WYHDOUd NOTLNSARYd LNOdCdd ~-----------------~--+---------.-86/TT/90 86/0/20 96/80/70 86/0/20 86/f0/zO agovld GNWY AZIGIDI1g CNNOGAWOH /'TIW.LLdSOR 66/80/90 66/TT/S0 66/TT/S0 66/TT/50 66/0T/S50 Taowid GNV AIAIOI19 CNNOGANOH / TWLIdSOH avd aL aLVd aLvd aLYd SAIVLS ALI TYWNOTLAIOXNA ‘IWS LNW Waa LAG SLaATHNOD 3 ‘THUUNAA LNAWSAOV Tad -STWSIG -HOW 1d HEy1a NOTLWN TWAS wnt ene eee nee n--------------- NOILVWYOANI WWuNOUd LNAGALS TWNOIMdHOXA ~---~---<+--------------+-+-----WWEDONd dada Z i ALITWNOIAROXA AUYWTHd c0OZ/TIT/SO *ALYd NOLLYNIVAd-au/NOILYNTYAS LNAANND 6661/TT/SO ‘Atv Nwid INSaNLS slieiatetetetaiataietaiaietaietetataeatetdeebieitateiett NOTIWWHOANI LNYODLS TWNOILdSOXS ----~-~-~---+------ ------‘GHIdILaID NOLLVNIWYXS HITWHH AMLNA ‘IOOHOS A :AMLNA "IOOHUS ‘NOLIYNIWYXS HL TWaH HST'IONS NX *‘AOVNONWT AWOH AAYWIdd HST'ONS NH ‘SDYNONWT SALLYN SALWLS GALINN Sh *HLYId dO AMLNNOO N007/SL/S0 ‘Alva AGAYNS SOVNPONWT AWOH STM *HOOD cO0OT/LO/EO + aLVO-TIWMYSUHKLIM OO8T-cT4A (195) 7 : TOOHOS SALAVWHOD SHYOAIAUNS OGEE *IOOHDOS LNaaNSD & ddvd HOWAH WTVd OS ?+LOISLSIG LNAAaND b : u SICTSLYS -W1La NOLIWNYUOANT @ AWMOOSELYOD OEE + TOOHDS HOWad Wiva OSO 10000 : LOIMLSTO - OL 879 $0 TOTAbed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 44.30% accurate

WILNSQISNOO ss6v00Sys55NI9 REE ER ERE ER ENR AeA ewe eee eee eee LIDIA DSNVAL, SO COND cece ee RR RENEE RRR ARERR ERE TERE ERAT 5c00 dN A1S/dodd 4690 SS AIS/woOud 0L00 dN HWOOA ZT WV Al T66T/9t/to zo £990 SS HYWOOA TO00 dN LYLONdwoo Leto SS JWINdWOO TS00 dN SHANAWOD 6$90 SS HHHNaWOD Too0 dN (1) HIWW £970 SS (L)HIVW 0900 dN {..) avaa E990 SS (L)GQWHa 2T Ww alo 66 T/9t/to Zo 9500 dN XE/SNwWSN ft v UL) Cbhb6t/s0/tU tO ZTL0 SS X8/a9vso FOO dN HOAW/dWoO 6490 SS HOWUW/dvo 0S00 dN SDVOONY'I 9690 SS HOVNONWI 9700 dN AIS/HOdd 6690 SS AIS/aoud S800 dN SHaYdWOD €£L0 SS SHWAdWOD FT Y BLO 266T/R0/FO £0 p000 SS ONTLINM 9000 SS SOdxXs 4M 5000 SS WHUVN um bd dwM €G66T/OT/ZO FO PEOO dN UIANa/SS 2690 SS UYIANa/SS 6600 dN GONATOS LOLO SS WONALOS #Z00 MN AIS/HOUd 6990 SS AIS/aoud ErOO dN QYOOA FTW alo €£661/62/£0 FO 9890 SS HYOOA C200 dN LV.LAdWOO £990 SS LWLAdWoD FL00 dN SHAUdWCO StL0 SS SHAAIWOO 2200 dN (LL) HLVW 8990 ss (L)HLYW 6400 dN (L)awa4a It4o0 SS (L)QWSa fT ¥ Hl €661/67/£0 bo T900 dN XH/aOvVSN ST & a1 P661/et/vO SO cb.0 SS XH /s5vson 8000 dN HOSW/dWoO $~90 SS HOSW/dYO 9Z00 dN ADYOONWI $690 SS FOWNOSNWI OTOO AN ATS/#ONd £390 SS AIS/aO0ud ZE00 dN SHRAdWOO FO40 SS AHATHdWOO ST d ALD 't66T/22/?0 SO O0L00 dN AIS/dOdd 9840 SS AITS/do0ud C000 dN wVOOA Lt d GLO é66T/St/rO 80 0000 $$ TWOOA 0000 dN LVLOdWOO D000 $S LWLd Oo ££00 dN dHeaddWoo O80 SS SHAed WOO 0000 dN (L)HIVW U000 SS (L)HLYW go000 dN (4) awaa 0000 SS (L)QWHa Lt a Glo L66T/ST/*O 680 Sd AL HdAL DINALNOO Ad Ad HdAL LNALNOO Ad AL AdAi LNELNOO WHOA AAVN ALW Cap AYOOS Zxa00S BOaeANS AsoOos SHOOS LOICHNs AaAOos HaOOoS LOAPHoS ‘WAMT LSA LSA *NOTLYVNUOANT LSA COBT-CTL (T9S) TT WINISHIA ‘SLSaqgOd ‘AWVN ‘TVYDaT TIOOHOS HE.LAWHO SHOATAMNS O6f£€ *TIOCHOS JNGAANO IO 8 HOoWd HOWE Wid OS ‘LOTULSTId LINN 8O0Z/TE/EO *HLVO Aeevdsdd OT *TSART SaVAD TetsLas -AIA NOLIWWUOANI LSAL O6ff *"IOOHOS HOWE WiIvd OSOO000 :‘LOTHLSIM - OL “o) 879 $0 c9Tabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

Case 18-2868, Document 278, 08/09/2019, 2628230, Page163 of 648 EXHIBIT P

10 Lid LZ 3 14 as 16 1'7 1 9 20 Za 22 23 24 25 Case 18-2868, Documen 78, 08/0 2018 2028030 pegelo4 of 648 c >» i Declare ony Figueroa UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, Vv. GHISLAINE MAXWELL, Defendant. VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume 1 of 2 Pages 1 - 157 Taken at the Instance of the Defendant DATE: Friday, June 24, 2016 TIME: Commenced: 8:59 a.m. Concluded: 2222 p.m: PLACE: Southern Reporting Company B. Paul Katz Professional Center (SunTrust Building) One Florida Park Drive South Suite 214 Palm Coast, Florida 32137 REPORTED BY: LEANNE W. FITZGERALD, FPR Florida Professional Reporter Court Reporter and Notary Public Southern Reporting Company (386)257-3663

10 Lik LZ 3 14 as 16 ad 1 9 20 Za 22 23 24 25 Case 18-2868, Documen 78, 08/0 2018 2028030 Fagel6s of 648 c >» i De odiene ony Figueroa APPEHARANCE OF COUNSEL ON BEHALF OF THE PLAINTIFF: BRADLEY J. EDWARDS, Esquire Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue Ft. Lauderdale, Florida 33301 954-524-2820 Brad@pathtojustice.com ON BEHALF OF THE DEFENDANT: LAURA A. MENNINGER, Esquire Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 3033631=7364 Lmenninger@hmflaw.com; Nsimmons@hmflaw.com Also appearing: Jenny Martin, Videographer from Abel Virginia Giuffre, Plaintiff Southern Reporting Company (386)257-3663

10 Lid 2 3 14 LD 16 1'7 1 9 20 ZA 22 23 24 25 Case 18-2868, Documen 78, 08/0 2018 2028030 Rage l66 of 648 c >» i De cdr e ony Figueroa INDEX VOLUME 1 (pages 1 - 157) TONY FIGUEROA Direct Examination by Ms. Menninger OATH OF REPORTER CERTIFICATE OF REPORTER VOLUME 2 (Pages 158 - 258) TONY FIGUEROA Cross-Examination by Mr. Edwards Redirect Examination by Ms. Menninger Recross-Examination by Mr. Edwards Further Direct Examination by Ms. Menninger OATH OF REPORTER CERTIFICATE OF REPORTER STIPULATION It is hereby stipulated and agreed by and between counsel present at this deposition and by the deponent that the witness review of this deposition would be waived. Southern Reporting Company (386)257-3663 156 LS} 162 Z10 243 Zoo Zo 7 250

10 Lid LZ 3 14 as 16 1'7 1 9 20 Ad 22 23 24 25 Case 18-2868, Document 2/8 08/0 2018 2028030 Fagel6 / of 648 eposition of Tony Figueroa INDEX OF EXHIBITS (MARKED BY THE DEFENDANT: ) Defendant's Exhibit 1 (Palm Beach County Sheriff's Reports Case Number 98041883) Defendant's Exhibit 2 (Greenacres Reports) Defendant's Exhibit 3 (Two Pictures of Apartment Building) Defendant's Exhibit 4 (Palm Beach County Sheriff's Reports Case Number 02075321) Defendant's Exhibit 5 (Royal Palm Beach Police Reports) Defendant's Exhibit 6 (Robert's School Records) (MARKED BY THE PLAINTIFF: ) Plaintiff's Exhibit 1 (Photos) Plainctitr Ss Exhibic. 2 (Passport) Southern Reporting Company (386)257-3663 42 71 dd 83 134 144 162 163

10 Lik LZ 3 14 as 16 1'7 1 9 20 Ad 22 23 24 25 Case 18-2868, Document 2/8 08/0 2018 2628030 Faget6s of 648 eposition of Tony Figueroa 23 BY MS. MENNINGER: Q And where did you go after Royal Palm Beach? A I believe it was South Area. I'm pretty sure it was South Area. Q Did you go to another school after that? A Yeah. I went to Gold Coast after that. Q Is that also in Royal Palm Beach? A No. That's -- South Area was in Lake Worth. Gold Coast is in West Palm. They were both alternative schools. Q Did you ever go to a Survivors Charter School? A Yes. I went there, too. Q When did you go there? A I'm not exactly sure of the date. But it was somewhere after either -- I'm pretty sure it was -- maybe -- I can't remember if it was Gold Coast first or Survivor. But one of the -- I'm trying to remember. I honestly don't remember which one came first. Q that's all righ. Can you describe for me Survivors Charter School? What is it like, or was it like? A I mean, like I said, it was an alternative Southern Reporting Company (386)257-3663

10 Lik LZ 3 14 as 16 1'7 1 9 20 Za 22 23 24 25 Case 18-2868, Document 2/8 08/0 2018 2028030. Fagel69 of 648 eposition of Tony Figuer 24 school. It was just pretty much a bunch of bad kids, you know, who have gotten kicked out. And it was pretty much like a last chance kind of school, you know what I mean? Q Does it look like a school? A Kind of. I mean, it had, like, a cafeteria, and then it had a whole bunch of, like, portables and stuff around there. And it was under -- it was, like, right near the Lake Worth. I remember there was, like, a bridge that went over the interstate right by it. But, I mean, it was just a little, you know, little crappy school. Q Was it during the day or at night? A It was during the day. e So regular school hours? A Yeah. Well, it was actually a little bit shorter hours. I can't remember exactly. But I know it was not like the full days. Because, I mean, at the alternative schools, it's obviously not up to regular high school standards. I mean, they just do pretty much stuff to get people to get out OF SCHOOL, Vou, Know; -S6.-.: Q Get the credits that you need? A Yeah. So that way they can finish high school and not drop out and whatnot, so... Southern Reporting Company (386)257-3663

10 Lik LZ 3 14 as 16 ad 16 9 20 Za 22 23 24 25 Case 18-2868, Document 2/8 08/0 2018 2628030 Faget 70 of 648 eposition of Tony Figueroa 25 Q You actually go there in the morning, though, and take classes? A Yeah. Q And get checked in at attendance? A Yeah. Q And then you may leave a little earlier than a regular school day? A Uh-huh (affirmative). Q All right. It's not a online program? A No, it was not online. QO When you were at Survivors Charter School, did you ever see Ms. Roberts there? A Was it Survivors? I don't remember if it was Survivors. Or was it -- because I'm pretty sure we were both -- was it -- I know we both went to one of the schools. I'm pretty Sure it was Survivors, maybe. Q Did you see her there? A Now, when we went to the school, like, we were together afterwards. But I don't remember exactly which one it was. I know it was one of those alternative schools that we went to, though. Q Okay. Did you -- was Wellington an alternative school? A No. Wellington is a -- is a real high Southern Reporting Company (386)257-3663

10 Lik LZ 3 14 as 16 1'7 1 9 20 Za 22 23 24 25 Case 18-2868, Document 278 08/0 2012 eoesan0 Pagel (1 of 648 Be eposition of Tony Figuer school, like a regular high school. Q Do you know if Wellington has an adult program? A They might. I mean, I really don't know. I'm not sure. Q Did you ever take night classes there? A No. Q So you believe when you reunited with Ms. Roberts in or around 2001, she had also gone to one of those alternative schools? A When I reunited with her, no. We ended up; Lake, trying oO: go. fanich senool. QO Tell me about that. A I mean, we just ended up going to one of those alternative schools and didn't even finish that. Q So you two had both left school, but went back together -A Yeah. QO -- to one of the alternative schools? A Yeah. Q And that may have been Survivors Charter School 2 A Yeah. I'm pretty sure it probably was. I'm pretty sure. Southern Reporting Company (386)257-3663

10 Lik LZ 3 14 as 16 1'7 1 9 20 Za 22 23 24 25 Case 18-2868, Document 278 08/0 2012 coe an0 Pagel (2 of 648 eposition of Tony Figuer 27 QO You both wanted to get your GEDs? A Yeah. QO Get better jobs? A Uh-huh (affirmative) . Q Things like -- that was the plan? A Yeah. QO But it did not work out? A Yeah. Q Do you know how long the two of you went to Survivors Charter School? A I honestly don't remember. Q Okay. You do have a recollection of going with her, though? A Yeah. Q Seeing her there? A Uh-huh (affirmative) . Q I'm trying to get a little bit of a time Frame on the time that you reunited with Ms. Roberts. I know you said you lived -- you remember being in an apartment with her in September of 2000 == 9/7/11/72001% right? A Yeah. Q Do you think you had been together with her for a while at that point? A It was probably, I'd say, like a month or Southern Reporting Company (386)257-3663

10 Lik LZ 3 14 as 16 1'7 1 9 20 Za 22 23 24 25 Case 18-2868, Document 2/8 08/0 2018 2028030. Faget /s of 648 eposition of Tony Figuer 28 so. Like, I'm pretty sure. Because it was not too long after I had moved in, so... Q And just to be clear, she already lived in the apartment? A Yeah. She lived in the apartment with her ex-boyfriend Michael and JJ. And I think there was somebody else. I don't remember who, though. Q All right. That's where she was living when you reunited with her? A Yeah. Q And then you moved in? A Yeah. OQ Did the other people move out? A Yeah. I kicked them out. Q How long did you live there with Ms. Roberts? A I think it was just till, like, the end of the lease, so it was probably maybe, like, five or Six months. I'm pretty sure. I don't know. I'm not exactly [sic] on the whole time frame. Q That's okay. I understand it was a while ago. A Yeah. Q Where did you two move from there? A I believe we either -- we went to her -Southern Reporting Company (386)257-3663

10 Lik LZ 3 14 as 16 1'7 1 9 20 21 22 23 24 25 Case 18-2868, Document 278 08/0 2012 eOeS Ar Tegel i4 of 648 eposition of Tony Figueroa 29 it was either her family's house or mine. It was either one of the two. And then we ended up getting another -- we were renting a house out in Loxahatchee also, eventually. But we also stayed in a little trailer behind her parents' house. Q When did your relationship with Ms. Roberts end the second time? A When she went to Thailand and -(Brief interruption.) A -- never heard from her again. THE COURT REPORTER: I'm sorry. Can you re-answer? A Yeah. When Jeffry sent her to Thailand. And then I never heard from her again until Freaking, like, two days ago. BY MS. MENNINGER: Q You heard from her two days ago? A Yeah. She had called me to apologize about, obviously, everything about me getting dragged into this mess. And we talked just pretty much about, you know, the way shit ended, and pretty much tried just -- her apologizing mainly about dragging me all into this and having to make me get -- you know, knowing how I have my family and stuff now. And that was pretty much it, so... Southern Reporting Company (386)257-3663

10 Lik LZ 3 14 as 16 1'7 1 9 20 Za 22 23 24 25 Case 18-2868, Document 2/8 08/0 2018 2628030 Faget 7s of 648 eposition of Tony Figueroa 37 QO Another instant connection. A Uh-huh (affirmative). Q From the time Ms. Roberts left to go to Thailand until today, have you seen her? A Nope. And to be honest, it still does not even feel real that she's sitting right there across from me. Q Well, you offered to get in touch with her a couple of times? A I know. But, like I said, it's just -- it still does not seem like this is actually happening. Like, she's -- I don't know. It's like talking to a ghost or seeing one. Q Does she look different now? A Yeah. QO How? A Just more mature, more older. Q When you were with Ms. Roberts the first time in '98 -A Uh-huh (affirmative). Q -- you believe that relationship lasted just a couple of weeks? A Yeah. I'm not exactly sure, but it was pretty brief. Southern Reporting Company (386)257-3663

10 Lik LZ 3 14 as 16 1'7 1 9 20 21 22 23 24 25 Case 18-2868, Document 2/8 08/0 2018 2028030 Raget 76 of 648 eposition of Tony Figueroa 125 A I believe so, yes. Q What did she tell you about that? A I -- I think that maybe he -- I mean, I don't know exactly. I don't really remember. I remember hearing about him, but I don't remember what she said about him. Q Did Ms. Roberts ever tell you that she had met Al Gore? A Not that I'm aware of. QO Did Ms. Roberts ever tell you that she had met a foreign president? A I'm not sure; I'm not sure. QO Did Ms. Roberts ever tell you she had met a prime minister? A I don't know. @) Did Ms. Roberts ever tell she had met a senator? A Not that I'm aware of. I mean, she's told me that she met a bunch of people before. And after it started becoming, like, an almost everyday thing about -- just hearing about famous people with Jeffrey and stuff like that, it's, like, I kind of didn't, like, tone it out, but I just -- it became normal, so I just stopped, like, listening to all the details, because I was not going to meet these Southern Reporting Company (386)257-3663

10 Lik LZ 3 14 as 16 1'7 1 9 20 Ad 22 23 24 25 Case 18-2868, Document 278 08/0 2012 coe a0 Pagel (7 of 648 eposition of Tony Figuer 126 people, you know what I mean? It's just, like, all sagall@ A gh wae Q Was she excited that she was meeting famous people? A Yeah. Q Was that a job perk? A Obviously. QO She talked about it a lot? A Yeah. Q To the point where you were drowning it out? A Well, that's what I'm saying. It was not like I was drowning it out. It's just I knew that she was with Jeffrey, and he was, obviously, well-connected with everybody. So it was not like, you know, a Special occasion, per se. You know, it was, but it's not like it was -- it was not very not rare so... QO Did she show you any photographs of herself with famous people? A NO’. Q Did you see a photograph of her with Prince Andrew -A YES. Q -- in her possession? Southern Reporting Company (386)257-3663

10 Lik LZ 3 14 as 16 1'7 1 9 20 Ad 22 23 24 25 Case 18-2868, Documen 78, 08/0 2018 2628030 pagel /s of 648 2 Me pasiion ¢ ony Figueroa 144 BY MS. MENNINGER: QO Mr. Figueroa, you mentioned that you and Ms. Roberts attempted to go to back to school while you were together -A Yes. QO -- to get your GED? A Yeah. Yes. Q And you believe that you went to the Survivors Charter School? A Yes: MS. MENNINGER: Okay. I'm going to mark Defendant's Exhibit 6. (Defendant's Exhibit 6 was marked for identification.) BY MS. MENNINGER: QO This 18S a school record for Ms. Roberts that lists the names of various schools. And -A So it was Survivors, obviously. That's the only one on that list that isn't -- or that's there that's on mine, as well. e Okay. A Other than the other ones, but... Q All right. So you recognize Survivors Charter School on Ms. Roberts' school records? A Yeah. That's what I'm saying. Since that Southern Reporting Company (386)257-3663

10 Lik LZ 3 14 as 16 1'7 1 9 20 Za 22 23 24 25 Case 18-2868, Document 2/8 08/0 2018 2028030 Faget 79 of 648 eposition of Tony Figueroa 145 1s the one on here, that's -- that's completely clear. I could not remember if it was that one or Gold Coast. Q Okay. There is an entry date for Ms. Roberts at Survivors Charter School of 10/12/2001, and a withdrawal on 3/7 of '02. Do you see that? A I mean, it's this; right? I mean, that's the top. Q The entry date of 10/12/01, withdrawal 3/7/02 at Survivors? A Okay. I did not know what those numbers -- I did not realize that that was a date. QO I understand. And I know you did not make this record. So I'm just wanting to know if that's consistent with your recollection, that you guys went to school in the fall of 2001 until the -A Yeah, that sounds about right. Q -- March of 2002. It sounds right? A Yeah. Q And you both went to school together? A Uh-huh (affirmative). Q In the mornings? A Yeah. Southern Reporting Company (386)257-3663

10 Lik LZ 3 14 as 16 1'7 1 9 20 Ad 22 23 24 25 Case 18-2868, Document 2/8 08/0 2018 2628030 Fae t80 of 648 eposition of Tony Figuer 146 Q And got out of school at some earlier time than a regular school day? A Yeah. Q Do you recall Ms. Roberts going to Royal Palm Beach High? Again, this is in the 2001 time frame. A I -- I don't recall. I really don't. Q Do you recall her, during the time you were with her, taking any night classes at Wellington High School? A I don't recall. Q Is it possible? A It's a possibility. MR. EDWARDS: Object to the form. BY MS. MENNINGER: Q Do you know whether Wellington has a night school program? A Like I said before, I don't know. They CCUG: Q You went there in ninth grade? A Yeah. It was during the day, though. I have no clue about night school. Q Got it. But you do have a memory about Survivors Charter School? Southern Reporting Company (386)257-3663

10 ii as 13 14 LS 16 177 18 LS 20 2. 22 Pe 24 25 Case 18-2868, Doc pen easattion of tony Migkeros Wohime Go. OF O48 156 CERTIFICATE OF OATH STATE OF FLORIDA ) ) COUNTY OF FLAGLER ) I, the undersigned authority, certify that TONY FIGUEROA personally appeared before me on June 24, 2016, and was duly sworn. WITNESS my hand and official seal this 5th day of July, 2016. freanelULeanne W. Fitzgerald Notary Public - State of Florida My Commission No. FF060921 Expires: February 8, 2018 Digital Certificate Authenticated By Symantec Southern Reporting Company (386)257-3663

Case 18-2868, Documen 78, 08/0 2018 2628030. Faget82 of 648 2 Me saciion ¢ ony Figueroa 157 CERTIFICATE OF REPORTER STATE OF FLORIDA ) COUNTY OF VOLUSIA ) 10 Lik LZ 3 14 as 16 1'7 1 9 20 Za 22 23 24 25 I, Leanne W. Fitzgerald, Court Reporter, do hereby certify that I was authorized to and did stenographically report the deposition of TONY FIGUEROA; and that the foregoing transcript is a true record of my stenographic notes. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. Dated this 5th day of July, 2016. Leanne W. Fitzgerald, FPR Florida Professional Reporter Digital Certificate Authenticated By Symantec Southern Reporting Company (386)257-3663

Case 18-2868, Document 278, 08/09/2019, 2628230, Page183 of 648 EXHIBIT Q

Case 18-Agte® Handa Sou bene 59D bo NIG6 Op FH 84 of 648 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS CONFIDENTIAL VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II November 14, 2016 VIRGINIA L. GIUFFRE, Plaineire, Vs GHISLAINE MAXWELL, Defendant. APPEARANCES : BOLES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE VOLUME II 11/14/2016 348

Case 18-Agte® Handa Sour bene sg D bo N546 Op FH 85 of 648 APPEARANCES : (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura Menninger, Esq. 10 La 12 13 14 iS 16 1'7 18 19 20 Zu 22 23 24 2) Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jJpagliuca@hmflaw.com Appearing on behalf of the Defendant Also Present: Ann Lundberg, Paralegal Maryvonne Tompkins, Videographer VIRGINIA GIUFFRE VOLUME II 11/14/2016 349

10 La 12 13 14 iS 16 1'7 18 19 20 Zu 22 23 24 2) Case 19-AgKe™ Blando, Court Repentiag & Videop INC: 36 of 648 Pursuant to Notice and the Federal Rules of Civil Procedure, the continued video deposition of VIRGINIA GIUFFRE, called by Defendant, was taken on Monday, November 14, 2016, commencing at 8:04 a.m., at 150 East 10th Avenue, Denver, Colorado, before Pamela J. Hansen, Registered Professional Reporter, Certified Realtime Reporter and Notary Public within Colorado. VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II BRXAMINATION PAGE By Ms. Menninger 354 VIRGINIA GIUFFRE VOLUME II 11/14/2016 350

10 La 12 13 14 iS 16 1'7 18 iS 20 Zak 22 23 24 2) Case 18-Agte® Handa Sou bene oH D bo N546 Op FH 87 of 648 DESCRIPTION Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit 1 10 LL 12 i 14 INDEX OF EXHIBITS (continued) INITIAL REFERENCE Settlement Agreement and General 555 Release List of names a 70 Photocopy of photograph 408 Photocopy of photograph, with 411 attachments Photocopy of photograph, with 417 attachments Photocopy of photograph, with 423 attachments statements a Ss History of education, with 462 attachment Application for Employment, 474 with attachment The Great Outdoors Community 481 Services Association, Inc. Termination Form, with attachments 7/6/2016 letter to Schultz 484 From Hayek, with attachments Patient Registration 490 Information, with attachments CVS Prescription Records 502 document, 7/29/2016, with attachment Affidavit of Custodian of 507 Records, Walgreen Company, with attachments VIRGINIA GIUFFRE VOLUME II 11/14/2016 351

10 i 12 13 14 iS 16 1'7 18 19 20 Zu 22 23 24 2) Case 19-AgKe™ Blande, Court Repo ntiag, & Videop ING: 89 of 648 DESCRIPTION Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit i> 16 1*7 18 19 20 INITIAL REFERENCE Patient Health Summary, Clifton 512 Beach Medical & Surgical, printed on 6/28/2016 Portions of deposition transcript 533 of Virginia Giuffre taken May 3, 2016 Amendment/Errata Sheet signed 540 May 31, 2016 by Virginia Giuffre Ad for Mar-a-Lago Club 548 The Mar-a-Lago Club, L.C. Sag Employment Policies, October 28, Lo9> Page from the Mar-a-Lago Club SOU Employment Policies, Revised LO 72001. VIRGINIA GIUFFRE VOLUME II 11/14/2016 352

10 La 12 13 14 iS 16 1'7 18 i ES 20 Za 22 23 24 2) Case 19-AgKe™ Blande, Court Repo ntiag, & Videop INC: 39 of 648 A Yes: Q And you believe the Neiman Marcus was located in which city? A Well, it's around Fort Lauderdale. I can't tell you exactly. Fort Lauderdale is so big, like Broward County? Is that the word for it? Q And what did you do at Neiman Marcus? A I worked in the changing rooms. Q And what did you do in the changing room? A I think I just like -- if I remember right, I just put clothes away that people left in there. Probably went out to get sizes, different sizes for women who wanted different sizes of the Same product. Q And where did you work after Neiman Marcus? A Taco Bell. Q Did you work at Southeast Employee Management Company? A I don't recognize that. I don't know if that's a payroll company or what it is. I don't know what Southeast -- what is it called? QO Southeast Employee Management Company. A No, I don't remember that. Q Did you ever work as a temp? VIRGINIA GIUFFRE VOLUME II 11/14/2016 470

10 La 12 13 14 iS 16 1'7 18 iS 20 Zak 22 23 24 Zp Case 19-AgKe™ Blande, Court Repo ntiag, & Videop INC: 90 of 648 A Not that I remember. Q Going to different offices and filling in? A No. Q Did you work for Oasis Outsourcing? A I don't -- I don't know if that's a payroll company or if that's an actual place, but that doesn't ring a bell. Q Did you -- do you know how much you got paid when you were working at places like Oasis Outsourcing? A Well, considering I don't know if I worked at Oasis Outsourcing, I wouldn't even know how much I got paid. Q Did you review your Social Security records? A Yes. Q You saw Oasis Outsourcing listed there? A Right, but like I said, it doesn't even ding a bell at all. Q Do you know how much money they said you made from them? MS. MCCAWLEY: Objection. If you want to Show her the documents, she can see what amount is listed and answer your questions, but if you're not going to show her the document, that's the best she VIRGINIA GIUFFRE VOLUME II 11/14/2016 471

10 La 12 13 14 iS 16 1'7 18 iS 20 Zak 22 23 24 2) Case 18-Agte® Handa Sour bene nH D bo N546 Op FH 91 of 648 don't know where I was living. Q Okay. Did you indicate whether you had gone to school? A Yes, I did. Q What did you indicate? A IT indicated that I attended Survivors Charter School for four years and had a high school diploma. Q And you graduated? A Well, I didn't. I just wanted to get a job, and I wanted it to look good, so I fluffed it up. Q So you wrote that down in your handwriting Om This application, Correct ? A i 1G. O And it was not true, correct? A Again, 1°M NOt proud of at. 1 ust. didn't have any other way of getting a job and I just thought if I put that down there, I might be considered. Q You indicated when you were younger you volunteered for six years at a riding clinic. What's the name of the riding clinic? A Vince Ramos. And I'm not too sure if it was six years, but I started off there quite young, VIRGINIA GIUFFRE VOLUME II 11/14/2016 475

10 La 12 13 14 iS 16 1'7 18 i ES 20 Zk 22 23 24 2) Case 19-AgKe™ Blande, Court Repentiag, & Videop INC: 99 of 648 a former employer is the Indigo Bar and Grill, GOrrece. A Yes. e Is that true? A No, it was not. Q On the page before that, it indicates you went to Royal Palm Beach High School. Is that in your handwriting? A Yes, it 1s. Q And it says you went for four years and you graduated? A Yes. Q In your handwriting? A Yes: eo Is that true? A No. Q This was an application you filled out in January OF 2014, Correct? A Correct. Q The page before that is your -- portion of your resume I think we have previously discussed, but just confirming, you did send that resume to this job application, correct? A E.-did. Q And you indicated you had worked at VIRGINIA GIUFFRE VOLUME II 11/14/2016 483

10 1k 12 13 14 LS 16 1'7 18 i ES 20 Zak 22 23 24 2) Case 19-AgKe™ Blanda, Court Repentiag, & Videop INC: 93 of 648 STATE OF COLORADO) ) SS. REPORTER'S CERTIFICATE COUNTY OF DENVER ) I, Pamela J. Hansen, do hereby certify that I am a Registered Professional Reporter and Notary Public within the State of Colorado; that previous to the commencement of the examination, the deponent was duly sworn to testify to the truth. I further certify that this deposition was taken in shorthand by me at the time and place herein set forth, that it was thereafter reduced to typewritten form, and that the foregoing constitutes a true and correct transcript. I further certify that I am not related to, employed by, nor of counsel for any of the parties or attorneys herein, nor otherwise interested in the result of the within action. In witness whereof, I have affixed my Signature this 23rd day of November, 2016. My commission expires September 3, 2018. Pamela J. Hansen, CRR, RPR, RMR 216 - 16th Street, Suite 600 Denver, Colorado 80202 VIRGINIA GIUFFRE VOLUME II 11/14/2016 563

Case 18-2868, Document 278, 08/09/2019, 2628230, Page194 of 648 EXHIBIT R

UUM A A Case 18-2868, Document 278, 08/09/2019, 2628230, Page195 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS SOCIAL SECURITY ADMINISTRATION OFFICE OF CENTRAL OPERATIONS 6100 WABASH AVENUE BALTIMORE MARYLAND 21215 Date: BOIES SCHILLER AND FLEXNER 401 E LAS OLAS BLVD STE 1200 FORT LAUDERDALE FL 33301-2211 We are sending the statement of earnings requested for: Number Holder's Name: VIRGINIA GIUFFRE social Security Number: Years Requested: 1998 THRU 2002; 2013 THRU 2015 Control Number: 16294125319 Remittance Number: 201610240012 Enclosure(s): Earnings Statement 10/25/2016 GIUFFRE009175 CONFIDENTIAL Ww een eter: fens NIT TZZ TAP EP eeorrzorocecanranzan

Case 18-2868, Document 278, 08/09/2019, 2628230, Page196 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS SOCIAL SECURITY ADMINISTRATION EARNINGS RECORD INFORMATION Date: 10/25/2016 Our records show the amount of earnings reported, not the amount of Social Security taxes that were paid. Wages were first covered under Social Security in 1937. Therefore, 1937 is the first year for which earnings may be shown on our records. Employers were required to report earnings semi-annually in Loar, and on a quarterly basis for the years from 1938 through 1977. Beginning with 1978, employers are required to report earnings annually. Our records do not show the exact date of employment (month and day) because we do not need this information to figure Social Security benefits. Employers do not give us this information. Each year, there is a maximum amount of earnings that is subject to Social Security taxes and is used to compute benefits. If a person earns more than this maximum amount, the earnings statement will usually show the maximum rather than the total earnings. Maximum benefits can be found on the SSA website. http: //www.ssa.gov/OACT/COLA/cbb. html Beginning in 1951, self-employed persons could also receive Social Security credit for their work. The maximum amounts of self-employment earnings that are subject to Social Security taxes and are used to compute benefits can also be found on the SSA website. http: //www.ssa.gov/OACT/COLA/cbb. html If you have any questions, you should call, write, or visit any Social Security office. If you visit or call, please bring this letter. It will help us answer questions. The toll free number to call is 1-800-772-1213 (for the deaf or hard of hearing, call our TTY number, 1-800-325-0778). GIUFFRE009176 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page197 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS FROM: SOCIAL SECURITY ADMINISTRATION OFFICE OF CENTRAL OPERATIONS 6100 WABASH AVENUE BALTIMORE MARYLAND 21215 NUMBER HOLDER NAME: VIRGINIA GIUFFRE YEARS REQUESTED: 1998 THRU 2002; 2013 THRU 2015 BOIES SCHILLER AND FLEXNER 401 E LAS OLAS BLVD STE 1200 FORT LAUDERDALE FL 33301 EMPLOYER NUMBER: P| KFC USA INC % PAYROLL DEPT 5200 COMMERCE CROSSING DR LOUISVILLE KY 40229-2182 YEAR 1ST QTR 2ND QTR 3RD OTR 4TH QTR TOTAL 1999 $140.70 EMPLOYER NUMBER: PUBLIX SUPER MARKETS INC PO BOX 32018 LAKELAND FL 33802-2018 YEAR 1ST QTR ZND QTR 3RD OTR 4TH QTR TOTAL 1999 $216.69 EMPLOYER NUMBER: ASCENSION CHILD CARE CENTER ASCENSION PEACE CHILD CARE CENTER 2701 N STATE ROAD 7 LAUD LAKES FL 33313-2731 YEAR 1ST QTR ZND QTR 3RD QTR 4TH QTR TOTAL 1999 $216.97 PAGE 1 GIUFFRE009177 CONFIDENTIAL WV d P20ISTH d IV 928TIN CX dAV LON sSZ0000ALdLDZ0606 000000000 OOLLSé LOSEE TESSBTZ969SE90 LO9Z00

Case 18-2868, Document 278, 08/09/2019, 2628230, Page198 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS x FOR SSN sy 326+ * * EMPLOYER NUMBER: a AVICULTURAL BREEDING & RESEARCH CENTER % ERNEST LAKS 14201 125TH AVE N WEST PALM BCH FL 33418-7945 YEAR IST QTR ZND QTR 3RD OTR 4TH QTR 2000 EMPLOYER NUMBER: [x SOUTHEAST EMPLOYEE MANAGEMENT COMPANY 2559 PALM DEER DR LOXAHATCHEE FL 33470-2563 YEAR 1ST QTR 2ND QTR 3RD QTR ATH QTR 2000 EMPLOYER NUMBER: Po MAR-A-LAGO CLUB LLC TRUMP DONALD J GEN PTR % TRUMP ORGANIZATION 1100 S OCEAN BLVD PALM BEACH FL 33480-5004 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH OTR 2000 EMPLOYER NUMBER: OASIS OUTSOURCING VI INC 2054 VISTA PKWY STE 300 WEST PALM BCH FL 33411-6742 YEAR 1ST QTR 2ND QTR 3RD OTR 4TH QTR 2000 EMPLOYER NUMBER: NEIMAN-MARCUS GROUP LLC % NEIMAN MARCUS GROUP LTD SOLE MBR 1201 ELM ST DALLAS TX 75270-2102 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR 2000 PAGE Zz TOTAL $99.48 TOTAL $3,212.44 TOTAL $1,866.50 TOTAL $2,037.60 TOTAL $1,440.79 GIUFFRE009178 CONFIDENTIAL

UT AAW WW Case 18-2868, Document 278, 08/09/2019, 2628230, Page199 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS EMPLOYER NUMBER: (a MANNINOS INC MANNINOS RESTAURANT 12793 B W FOREST HILL BLVD WEST PALM BEACH FL 33414-4749 YEAR 1ST OTR 2ND QTR 3RD QTR 4TH QTR 2001 EMPLOYER NUMBER: pe CCI OF ROYAL PALM INC % ROBERT FURR TTEE 2255 GLADES RD STE 337-W BOCA RATON FL 33431-7379 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR 2002 EMPLOYER NUMBER: ROADHOUSE GRILL INC ROBERT C FURR TTEE IN BANKRUPTCY 2255 GLADES RD STE 337W BOCA RATON FL 33431-7379 YEAR 1ST QTR 2ND QTR 3RD OTR 4TH OTR 2002 EMPLOYER NUMBER: MARC PINKWASSER DVM PA 13860 WELLINGTON TRCE STE 31 WELLINGTON FL 33414-8541 YEAR 1ST QTR ZND QTR SRD QTR 4TH OTR 2002 EMPLOYER NUMBER: [a GREAT OUTDOORS PREMIER RV-GOLF RESORT COMMUNITY SVC ASSOC INC 145 PLANTATION DR TITUSVILLE FL 32780-2528 YEAR 1ST QTR 2ND QTR 3RD OTR 4TH OTR 2014 PAGE 3 TOTAL $212.00 TOTAL $403.64 TOTAL $1,247.90 TOTAL $1,561.75 TOTAL $171.83 GIUFFRE009179 CONFIDENTIAL Torr et ONO « eree rar © TAI S°RON TATA F rirnsoTe Aneaneannan MITTAZTALEE TOR TZaRGeranTnazAn

Case 18-2868, Document 278, 08/09/2019, 2628230, Page200 of 648 SSA-1826 ITEMIZED STATEMENT OF EARNINGS kok —f ek * KKK KKK KK KKK KKK KK RK KERR ERE RRR EKER KEKE EERE KKKRKREKEKRRKRKKEKERERKEEKKKEKE kkkkk**K THERE ARE NO OTHER EARNINGS RECORDED UNDER THIS ****###%% kkkkeKKK SOCIAL SECURITY NUMBER FOR YEAR(S) REQUESTED tk kk a KKK He te KKK KK KKK KKK KKK KKK KKK KEK KEK KKK RK KERR KERR RRR KRRERERERERRKEKKEE PAGE 4 GIUFFRE009180 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page201 of 648 EXHIBITS

January 30, 2003 To Whom It May Concern, Skye Roberts has been a most valuable employee at The Mar-a-Lago Club since April of 2000. While employed as a maintenance crew team member, he has been responsible for maintaining the five championship red-clay tennis courts as well as keeping all of the individual air conditioning units working and in tip-top shape. It is my understanding that Skye is relocating to Colorado. Should he ever return to Florida, he would be eligible for re-hire. - ff er oe fe age fier ws geits 1% LE, BE a rae f 3 we Ge wag, Cg ye) PALM BEACH, FLORIDA 1100 South Ocean Boulevard, Palm Beach, Floricta 33480 (407)832-2600 Fax (407) $32-2669 i i i 5. 3 j MAR-A-LAGO-0001

Case 18-2868, Document 278, 08/09/2019, 2628230, Page203 of 648 TERMINATIONS LAST NAME FIRST NAME Box #1 Box #1 Box #4 Box #4 Box #1 Box #6 Box #3 Box #1 Box #4 Box #3 Box #4 Box #4 Box #6 Box #4 Box #3 Box #1 Box #4 Box #3 Box #4 Box #6 Box #3 Box #6 Box #4 Box #1 Box #1 Box #6 Box #6 Box #3 Box #6 Box #4 Box #3 Box #6 Box #4 Box #1 Box #3 Box #3 Box #6 Box #1 Box #3 Box #1 Box #1 Box #3 Box #3 Box #3 Box #1 Page 1 of 17 MAR-A-LAGO 0161

Case 18-2868, Document 278, 08/09/2019, 2628230, Page204 of 648 TERMINATIONS LAST NAME FIRST NAME Box #4 Box #3 Box #3 Box #3 Box #6 Box #3 Box #4 Box #3 Box #6 Box #3 Box #1 Box #4 Box #4 Box #4 Box #1 Box #6 Box #4 Box #6 Box #4 Box #1 Box #1 Box #6 Box #1 Box #1 Box #3 Box #1 Box #6 Box #6 Box #3 Box #1 Box #4 Box #1 Box #4 Box #1 Box #6 Box #3 Box #6 Box #4 Box #4 Box #1 Box #3 Box #4 Box #3 Box #1 Box #4 Page 2 of 17 MAR-A-LAGO 0162

Case 18-2868, Document 278, 08/09/2019, 2628230, Page205 of 648 TERMINATIONS LAST NAME FIRST NAME (Christina [Box #4 Kevin |Box#f Janet [Box #83 VALerie [Box #4 Deo [Box #3 Jeremy [Box #1 Ku [Box #4 Sandra [Box #6 Juan [Box #4 Angela [Box #1 Krystal [Box #4 Jean [Box #3 (Craig [Box #1 Rene [Box #1 Fresnel [Box #6 Syifida [Box #6 Vanette [Box #6 James [Box #1 Michael [Box #4 (Cora [Box #6 John [Box #3 Kimberly [Box #1 Trisha [Box #6 Tana [Box #3 (Connie [Box #4 Julius [Box #6 Joanne [Box #1 Yvette [Box #1 Barbara [Box #1 James [Box #4 Vera ‘(Box #1 Vero _—*(Box #1 Roberto [Box #3 Debra [Box #3 Rachael [Box #1 Emory [Box #1 Sonia [Box #6 Deborah __|Box #6 Barbara [Box #4 Tricia [Box #6 Lonjino [Box #6 [Israel [Box #6 Joshua [Box #4 Anamaria | Box #4 Meghan Box #6 Page 3 of 17 MAR-A-LAGO 0163

Case 18-2868, Document 278, 08/09/2019, 2628230, Page206 of 648 TERMINATIONS LAST NAME FIRST NAME | Box #4 Box #1 Box #6 Box #6 Box #4 Box #4 Box #1 Box #6 Box #3 Box #4 Box #1 Box #3 Box #1 Box #1 Box #3 Box #6 Box #4 Box #3 Box #1 Box #6 Box #1 Box #3 Box #1 Box #6 Box #6 Box #4 Box #6 Box #6 Box #4 Box #4 Box #4 Box #6 Box #6 Box #6 Box #1 Box #1 Box #3 Box #3 Box #4 Box #3 Box #6 Box #1 Box #4 Box #1 Box #1 Page 4 of 17 MAR-A-LAGO 0164

Case 18-2868, Document 278, 08/09/2019, 2628230, Page207 of 648 TERMINATIONS LAST NAME FIRST NAME Feal Feick Fein Fernandez Ferree Fesser Fidanovic igueroa Filippone inch inckenor ink lorentino Irat ischbach ischer iumara lores olmer Oss OX rancoeur ratus relich rey riday rith ritz rost Gacon Galla Galloway alloza Garcia Garcia-Douglas Garrido Gedeum Gell Gervais Getgood Gibeault Gillie Gividen Glass Goicochea Goldrich Box #4 Box #4 Box #1 Box #6 Box #3 Box #1 Box #6 Box #3 Box #4 Box #1 Box #4 Box #4 Box #4 Box #1 Box #3 Box #4 Box #3 Box #3 Box #1 Box #1 Box #6 Box #6 Box #3 Box #6 Box #4 Box #6 Box #1 Box #1 Box #1 Box #1 Box #1 Box #6 Box #3 Box #6 Box #6 Box #4 Box #3 Box #3 Box #6 Box #1 Box #1 Box #1 Box #1 Box #1 Box #6 Page 5 of 17 MAR-A-LAGO 0165

Case 18-2868, Document 278, 08/09/2019, 2628230, Page208 of 648 TERMINATIONS LAST NAME FIRST NAME Box #4 Box #3 Box #1 Box #1 Box #6 Box #4 Box #6 Box #1 Box #6 Box #4 Box #3 Box #4 Box #1 Box #1 Box #1 Box #3 Box #3 Box #1 Box #1 Box #1 Box #3 Box #1 Box #1 Box #1 Box #1 Box #3 Box #6 Box #3 Box #1 Box #3 Box #1 Box #6 Box #1 Box #1 Box #1 Box #6 Box #3 Box #6 Box #6 Box #3 Box #3 Box #3 Box #3 Box #4 Box #3 Page 6 of 17 MAR-A-LAGO 0166

Case 18-2868, Document 278, 08/09/2019, 2628230, Page209 of 648 TERMINATIONS LAST NAME FIRST NAME Kathleen | Homenuik Hong Hopkins nfante nsani rvine acob acobs acques acques aferali ames ankowski aramillo ean enkins esperson ohnansen ohnson Johnson Johnson ohnson Johnson Johnson Johnson Johnson ones Jones Box #3 Box #1 Box #6 Box #4 Box #3 Box #1 Box #6 Box #6 Box #6 Box #3 Box #1 Box #4 Box #4 Box #3 Box #4 Box #4 Box #6 Box #6 Box #4 Box #4 Box #3 Box #4 Box #3 Box #1 Box #1 Box #1 Box #6 Box #4 Box #6 Box #1 Box #1 Box #6 Box #4 Box #3 Box #6 Box #4 Box #4 Box #1 Box #1 Box #1 Box #1 Box #1 Box #6 Box #4 Box #3 Page 7 of 17 MAR-A-LAGO 0167

Case 18-2868, Document 278, 08/09/2019, 2628230, Page210 of 648 TERMINATIONS LAST NAME FIRST NAME Box #1 Box #4 Box #4 Box #1 Box #1 Box #4 Box #4 Box #1 Box #4 Box #1 Box #3 Box #3 Box #4 Box #4 Box #4 Box #4 Box #3 Box #6 Box #1 Box #1 Box #6 Box #4 Box #1 Box #1 Box #1 Box #4 Box #6 Box #3 Box #4 Box #1 Box #3 Box #6 Box #6 Box #4 Box #6 Box #1 Box #6 Box #1 Box #1 Box #3 Box #3 Box #1 jTara Box #4 Box #1 Box #6 Page 8 of 17 MAR-A-LAGO 0168

Case 18-2868, Document 278, 08/09/2019, 2628230, Page211 of 648 TERMINATIONS LAST NAME FIRST NAME Box #1 Box #1 Box #3 Box #6 Box #4 Box #3 Box #3 Box #6 Box #6 Box #3 Box #3 Box #3 Box #1 Box #4 Box #6 Box #6 Box #3 Box #7 Box #4 Box #4 Box #3 Box #1 Box #7 Box #3 Box #4 Box #1 Box #4 Box #1 Box #3 Box #7 Box #1 Box #7 Box #7 Box #4 Box #1 Box #3 Box #1 Box #7 Box #4 Box #1 Box #3 Box #1 Box #3 Box #3 Page 9 of 17 MAR-A-LAGO 0169

Case 18-2868, Document 278, 08/09/2019, 2628230, Page212 of 648 TERMINATIONS LAST NAME FIRST NAME Box #4 Box #1 Box #4 Box #3 Box #1 Box #4 Box #7 Box #3 Box #7 Box #3 Box #7 Box #1 Box #1 Box #4 Box #7 Box #3 Box #4 Box #4 Box #1 Box #7 Box #7 Box #3 Box #3 Box #7 Box #1 Box #7 Box #4 Box #4 Box #1 Box #1 Box #7 Box #4 Box #4 Box #4 Box #2 Box #7 Box #4 Box #3 Box #2 Box #7 Box #3 Box #7 Box #2 Page 10 of 17 MAR-A-LAGO 0170

Case 18-2868, Document 278, 08/09/2019, 2628230, Page213 of 648 TERMINATIONS LAST NAME FIRST NAME Chery! Cheryl Nakoneczny Narleski Nasie Natal Neira Nelsen Nelson Nemets Nieporte Noe Noel Nolan Northern Noufal O'Boyle Oconnor Oesterling Oldfield Oliver O'Neill O'Neill O'Neill Orozco Pagen Pagliaro Palomba Parker Parker Parkinson Pavelka Pesasico Box #2 Box #7 Box #3 Box #7 Box #4 Box #7 Box #4 Box #2 Box #7 Box #3 Box #3 Box #2 Box #3 Box #3 Box #4 Box #7 Box #7 Box #2 Box #7 Box #2 Box #7 Box #2 Box #7 Box #2 Box #4 Box #2 Box #2 Box #7 Box #3 Box #2 Box #4 Box #2 Box #3 Box #2 Box #4 Box #2 Box #2 Box #4 Box #7 Box #2 Box #4 Box #4 Box #4 Box #2 Box #4 Page 11 of 17 MAR-A-LAGO 0171

Case 18-2868, Document 278, 08/09/2019, 2628230, Page214 of 648 TERMINATIONS LAST NAME FIRST NAME Box #2 Box #2 Box #4 Box #7 Box #3 Box #7 Box #2 Box #7 Box #2 Box #2 Box #3 Box #4 Box #2 Box #3 Box #3 Box #4 Box #3 Box #7 Box #4 Box #2 Box #2 Box #3 Box #7 Box #4 Box #2 Box #2 Box #2 Box #3 Box #3 Box #2 Box #2 Box #2 Box #4 Box #2 Box #2 Box #7 Box #7 Box #7 Box #4 Box #7 Box #7 Box #2 Box #4 Box #7 Box #3 Page 12 of 17 MAR-A-LAGO 0172

Case 18-2868, Document 278, 08/09/2019, 2628230, Page215 of 648 TERMINATIONS LAST NAME FIRST NAME | Box #7 Box #4 Box #4 Box #4 Box #3 Box #7 Box #4 Box #3 Box #3 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #4 Box #2 Box #4 Box #2 Box #4 Box #4 Box #7 Box #2 Box #7 Box #7 Box #2 Box #2 Box #2 Box #2 Box #5 Box #2 Box #7 Box #2 Box #5 Box #2 Box #5 Box #5 Box #2 Box #2 Box #5 Box #2 Box #2 Box #7 Page 13 of 17 MAR-A-LAGO 0173

Case 18-2868, Document 278, 08/09/2019, 2628230, Page216 of 648 TERMINATIONS LAST NAME FIRST NAME Serpico Sevilla Shaw Shelhamer Shepherd Shields Shumate Shumpis Similien Simms Simpson Sineni Singerline Skinner Sluzenski Smith Smith Smith Smith Smith Smith Snyder Soler Soliman Sosa Southall Souza Staniszewski Stankunas Stanley Sta-Rosa Steinberg Steinhaus Steliga Stenger Stephans Stewart Strohminger Stuart Stuhr Sturtevant Box #5 Box #7 Box #7 Box #7 Box #2 Box #5 Box #7 Box #2 Box #7 Box #7 Box #2 Box #2 Box #2 Box #7 Box #5 Box #5 Box #2 Box #2 Box #2 Box #2 Box #7 Box #2 Box #2 Box #7 Box #2 Box #2 Box #2 Box #2 Box #2 Box #5 Box #7 Box #7 Box #2 Box #2 Box #2 Box #2 Box #5 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #5 Page 14 of 17 MAR-A-LAGO 0174

Case 18-2868, Document 278, 08/09/2019, 2628230, Page217 of 648 TERMINATIONS LAST NAME FIRST NAME Box #2 Box #2 Box #2 Box #2 Box #2 Box #7 Taylor Box #5 Tempfli Box #2 Thelemaque Box #5 Thibeault Box #7 Thiel Box #2 Thiel Box #2 Thomas Box #2 Thompson Box #2 Thompson Box #2 Tomer Box #2 Taylor Tempfi Thelemaque Thibeault Thiel Thiel Thomas Thompson ‘Thompson Tomer Box #5 Box #5 | Box #7 Box #7 Trevino Tsitsirides Tucker Uljic Umpierre Valdez Valdez Valenti Trevino Box #2 Tsitsirides Box #5 Tucker Box #7 Uljic Box #2 Umpierre Box #7 Valdez Box #2 Valdez Box #2 Valenti Box #2 Box #5 Box #2 Page 15 of 17 MAR-A-LAGO 0175

Case 18-2868, Document 278, 08/09/2019, 2628230, Page218 of 648 TERMINATIONS LAST NAME FIRST NAME Vaughn Velasquez Vidalis Voluck Vyskrebentsev Wahl Walker Walkowiak Wentworth Weslowski White Whitley Whitney Whittle Wilburn Williams Williams Williams Williams Williams Willoughby Box #2 Box #2 Box #5 Box #5 Box #7 Box #7 Box #2 Box #5 Box #7 Box #2 Box #7 Box #2 Box #2 Box #2 Box #5 Box #7 Box #7 Box #2 Box #2 Box #2 Box #2 Box #2 Box #7 Box #7 Box #2 Box #5 Box #2 Box #2 Box #2 Box #2 Box #7 Box #5 Box #2 Zervoulis Box #2 Zivkovic Box #2 Zorn Box #7 Box #2 Box #1 1998 terms Box #2 1998 & 1999 terms Box #3 1999 terms Box #4 2000 terms Box #5 2000 terms Box #6 2001 terms Page 16 of 17 MAR-A-LAGO 0176

Case 18-2868, Document 278, 08/09/2019, 2628230, Page219 of 648 TERMINATIONS LAST NAME FIRST NAME Box #7 2001 terms Page 17 of 17 MAR-A-LAGO 0177

Case 18-2868, Document 278, 08/09/2019, 2628230, Page220 of 648 EXHIBIT T

| NO OO ws Ol OY ~] OO LO 10 deal 12 13 14 ie 16 17 Lo iB, Zz) Ze Ze 23 24 Z9 Case 18-2868, Document 278, 08/09/2019, 2628230, Page221 of 648 UNITED STATES DISTRICT COURT for the Southern. Distric.. of New: York Cavid ACELOn NO. 1o—-cCv—-074s5s=RWo VIRGINIA GIUPERE, Pleaaencik by Was GHISLAINE MAXWELL, Defendant. VIDEO-DEPOSITION OE: TAKEN BY: REPORTED, BY: DATE AND TIME: PEACE: APPEARANCES: Plo PRESENT: Sky Roberts Defendant Karla Layfield, RMR SUENOGraph ic COuUre ReEpOorler NOEary Pubic State of Florida at Large May 20; 2ZULG?. S335 asl. Millhorn Law Firm 11294 North US Highway 301 Oxtord, Florida Laura A. Menninger, Esquire HADDON, MORGAN & FOREMAN, PC 150 East 10th Avenue Denver, Coloradce 3UzZ03 Attorney for Defendant Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, PISOlOs.-& LEHRMAN, Pi 425 Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 ActCOrmMey £Or PlLaincire Kenneth Sarcony, Videographer Owen & Associates Court Reporters P.O, Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO UO aa O1 OY ~ OO LO 10 deal 12 13 14 Lio 1G Ll 18 ig Zi Ze Ze 23 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page222 of 648 de AN DP i: 2s WITNESS > Sky Roberts Direct Examination by Ms. Menninger Cross-Examination by Mr. Edwards Redirect Examination by Ms. Menninger Recross-Examination by Mr. Edwards Reporter's Certificate Certificate of Oath B 2e da dL i oh Defendant's Exhibit Defendant's Exhibit Defendant's Exhibit Derendant's Exhibit Derendant's: Bxnibie Defendant's Exhibit Defendant's Exhibit Defendant's Exhibit Defendant's Exhibit iO OOo sO). Ci eS Go ND (Exhibits attached. ) Owen & Associates Court Reporters P.O, Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com PAGE L335 1359 141 143 144 Ze 48 pz 58 LLG 122 IZ SD LS

| NO UO ws Ol OY ~ CO LO 10 id 17 13 14 iS LG 17 Lo ng 20 ZA we Zo 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page223 of 648 ie O Do you remember there being a job posting that you felt like was appropriate for Virginia or did you just go out and talk to the woman who ran the spa area on your own? A I just talked to Angela. Q Okay. Do you recall whether this was intended tO. be- a tulhl=-tine aob? A I don't remember if it was full time or just summer jobs or, you know, during season. It was probably for a season because Mar-a-Lago is seasonal. I mean, I was there year round but a lot of people are seasonal, you know, because it's like snowbirds, you know, summertime comes and nobody wants to be down in south Florida. O What would you call the season, the seasonal aspect of Mar-a-Lago? What's the season? A Probably from September or October to, you know, maybe May, I guess. QO Is that the coolest time? A Times of the year, yes. QO And it's more guests that come during that period of time? A Yes. QO And is there more staff brought on during that period of time? Owen & Associates Court Reporters P.O, Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO Hs Ol OY ~ CO LO 10 Li 17 1 14 ie 16 17 Lo iB, 20 ZA we Zo 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page224 of 648 i A LES < QO You saw that happen every year that you were there? A Every year. QO And in the summer, it's relatively dead because eS SO: Ot? A Basically, it closed during the summer. That's when we would kind of work on everything and then make sure everything is up to snuff for the next year, you know. QO Do you remember what capacity Virginia was hired to work in, what her job title was, for example? A I don't know. I would have lunch with Virginia. That's about as much as I know about what she did. I was busy all the time. O I understand. A I didn't have time to go see what she was doing. I didn't really talk to Angela about what she had to do. I think that was her name, Angela. But it's kind of the name that sticks out. OQ We'll just use Angela. A We'll use that as the name. @ But we know it may not be Angela. A Le. May MOG: be. Q Just because we have to call her something, Owen & Associates Court Reporters P.O, Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO UO ws Ol OY ~] CO LO 10 Li 17 1 14 ie 16 17 Lo iB, 20 ZA we Zo 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page225 of 648 eS, A Where did I learn that? Q Uh=hionhs, A IT think Virginia had told me that there was a lady in the spa area named Ms. Maxwell. I don't know her. I couldn't tell you what she looked like. But just she said Ms. Maxwell said she can get me a job with Jeffrey Epstein who is a friend of Donald Trump, so I figured, well, he was a good guy or whatever, you know, and that she was going to learn massage therapy. O When did Virginia tell you this? A Oh, I can't tell you what date and time but I don't remember. O I understand. Did she tell you this while she was working at Mar-a-lhago. A Yes. I mean, after she had been there for a little bit, you know, and then she told me, yes, that she could possibly get this other job. QO Okay. A You know. QO SO she worked at Mar-a-Lago for a few months? MR. EDWARDS: Form. THE WITNESS: I have no idea. I don't know how long she worked there. I don't remember. BY MS. MENNINGER: Owen & Associates Court Reporters P.O, Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO UO ws Ol OY ~] CO LO 10 Li 17 1 14 ie 16 17 Lo ng 20 ZA we Zo 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page226 of 648 82 A Uh-huh. Yes. It's not to me. It'S up to her. I think that's the way I told her, you know. O Did you ever meet Jeffrey Epstein? A Once. O When was that? A I dropped Virginia off at the house once and he came out and I met him and seemed just fine to me. I mean, you can't tell people by looking at them. I mean, I know now from, you know, what I've read that he's not a good guy. But you can't tell. You know, you don't even know your neighbors sometimes, you know. QO Do you remember about when you dropped Virginia off at his house that you met him? A What do you mean? O Was it about the same time Virginia started working with him? A Yeah. @ Was it later? A I think it was about the time she started. Because I wanted to see where she was at, you know. And it was just a mansion down the street from, you know, Mar-a-Lago. So I didn't think twice about it. I didn't think nothing of it. He came out. He was very cordial, very nice. Owen & Associates Court Reporters P.O, Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO UO ws Ol OY ~] CO LO 10 Li 17 1 14 ie 16 17 Lo ng 20 ZA we Zo 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page227 of 648 83 O Do you remember any part of your conversation with him? A No. It was just that, you know how a parent has to meet -- you know, if my daughter is going to work somewhere, I just want to meet the guy and see what was going on, you know. But I don't remember any conversation, you know. I just remember meeting him and that was it and she walked into the house and -O All right. So you recall Mr. Epstein coming outside of his home and greeting you? A LES QO Were you invited into his home? A No. QO Did you ever go inside of his home? A No. Q Other than that one time you dropped her off there, do you ever remember going to that home? A No. I couldn't tell you where it was at. Q Okay. Did you meet anyone else while you were there at the home? A No. O Did you have a conversation with anyone else? A NOw QO Did you every call Virginia at that home? Owen & Associates Court Reporters P.O, Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO UO ws Ol OY ~] CO LO 10 Li 17 1 14 ie 16 17 Lo ng 20 ZA we Zo 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page228 of 648 85 massage therapy. QO All right. When she came home at night from working with Mr. Epstein, did she look distressed to you in any way? A Not that I remember. QO Okay. Did she report any complaints about her job with Mr. Epstein? A NOG “LO- Me. QO Okay. Did she report them to anyone else who then reported them to you? A NO QO Your wife, for example? A I have no idea. Like I said, if she did tell my wife, I never heard about it. QO Okay. Have you ever met Ms. Maxwell? A Not that I remember ever meeting her. OQ Do you Know what she looks like? A No. QO Did you ever meet anyone else who worked with Mr. Epstein? A INO»: QO Do you remember anyone else who worked for Mr. Epstein bringing your daughter home, for example? A NOw QO Did your daughter ever move into the home where Owen & Associates Court Reporters P.O, Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO ws Ol OY ~ OO LO 10 teal 12 13 14 iS LG 17 Lo ig Zi Ze Ze 23 24 Z9 Case 18-2868, Document 278, 08/09/2019, 2628230, Page229 of 648 LS CERTIFICATE SOTATE OF FLORIDA COUNTY OF MARION Ly Karla baytreld, RMR, Stvenoographic Court Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing deposition of Sky Roberts; that said witness was duly sworn to testify truthfully; and that the foregoing pages, numbered 1 through 142, inclusive, constitute a true and correct record of the testimony given by said witness to the best OF MY ably, L- BURTOER. CHRELFY (hat. 1 am nor a2 relative Or employee or attorney or counsel of any of the parties hereto, nor a relative or employee of such attorney or counsel, nor am I financially interested in the action. WITNESS MY HAND this day of May, 2016, -at Ocala, .Maraon--COuUmiyy,. Whoride.. Karla Layfield, RMR Stenographic Court Reporter Owen & Associates Court Reporters P.O, Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

| NO OO ws Ol OY ~] CO LO 10 deal 12 13 14 ie 16 17 Lo in Zz) Ze Ze 23 24 Z9 Case 18-2868, Document 278, 08/09/2019, 2628230, Page230 of 648 Lae CERTIFICATE OF OATH SOTATE OF FLORIDA COUNTY OF MARION IT, the undersigned authority, certify that Sky Roberts personally appeared before me and was duly sworn on the z0th day of May 2016. WITNESS MY HAND AND OFFICIAL SEAL. this day of May 2016. Karla Layfield, RMR NOtatryY. PubiaeG State Or Fiorida at. Large My Commission No. FF942806 My Commission Expires 12/10/2019 Personally Known Professionally Known Produced Identification of FDL Owen & Associates Court Reporters P.O, Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

Case 18-2868, Document 278, 08/09/2019, 2628230, Page231 of 648 EXHIBIT U

Case 18-2868, Document 278, 08/09/2019, 2628230, Page232 of 648 THE MAR -A-LAGO CLUB, L.C. | EMPLOYMENT POLICIES OCTOBER 28, 1995 min AGREN oie prone lo MAR-A-LAGO 0178

The text on this page is estimated to be only 32.47% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page233 of 648 TABLE OF CONTENTS Page ENT ROLUCTIONG c10t e255 te ebhae ecard aneeg ee eu nee abe aw kameaw& oe Z EQUAL EMPLOYMENT OPPORTUNITY.......... 0c. ccc ccc wee e cece cece eens 2 ORTENTATION. POLECY ig ocneaay sae ee é aegree setae ead bSedw he. e «Gram Cale 3 SEXUAL HARASSMENT. 1.0... ccc ccc cc ccc cette ec eee e ec ee eee 4 CERe OF PACT ei st aden eee mas aaeesedad eae enedes oe ouen ees 6 ENTRY AND EXIT OF CLUB GROUNDS/PREMISES...............cccc000e 7 PROOF OF AUTHORIZATION TO WORK. ......... 02.0 ccc cece esc c ccc eees 8 BECUR eteeeatoeeeeseatieee Gi eee ok bees Ge eeneaoeene Ga ened nek 9 As PIN ORIMA TL LOM se, dc. tue Gees oem a iet eee dy oot kee Sake cea ow ew Sia. 6. 9 B CONPIOBNT AAGLTY 23.09% .68600 b. 60k sb ed Gave b 4G SG Gree ees 9 Cc FACIL ELITE at nbd bae teeta eee eee ee eaeae ben 646 ee 6 oe 9 D GUESS! PRIVACY case te bet dads Gene oseu.secucdwawhe hese we 10 E UNAUTHORIZED AREAS 24044 ¢ e600 08a eee aseeeeedaeuibigas 11 F REPORTING CRIME: os 22d echo anes Oesuu bs ooo ew sees eee oes dd G MS Lea Cae Gs Oo oe Ge pd eS Se ees ao ga We Oa wee eee ee al SUBD NAMES. 65505 644 eacndedbSe neste eG ouwreseeoeesbsdscadasaesaws 12 SAPETY AND HEANTA, 0% 6-inbkwed bu cee See oe b wea Oe. OSS ed eels ome eK 13 WORKERS' COMPENSATION... 2.2... 0. cc ccc cc eee eee cee cece eee eee 15 EMERGENCY PROCEDURES 64.i see s0w ss ost bseeee seein deedeeecicuiac cess 16 USE OF CLUB'S COMPUTER SYSTEM AND SOFTWARE PROGRAMS........... 17 A. IS ire race arse oe. oad hs ls GG Gar awe See re are Gh ewe ow Se de 17 B. BEBCTRONTC MAL i 465ao Gee hd dae ww read oe ore we ee en 17 Ce VOICE MAG. weet sent dca e Sees oe tS a8 aoe Mere Be Gace ee... 18 D. RIGHT TO INSPECT............... eee TT Tee ee eee ee 18 DISCLOSURE OF EMPLOYEE INFORMATION............ ccc ccccccccecee 19 NO SOLICITATION/NO DISTRIBUTION.......... 0... cece cece ec cece eee 20 INSP BOCLIONSs 2uoa25 oon been ea deed awww ay hee eees eee eaeiet eek eu 21 INTERNAL INVESTIGATIONS ......... 0. ccc cece cc eee cece ce eee cease 21 OUTSIDE EMPLOYMENT i) 6440.06.04 840.0eeawdddod wae So oonw 4 eae e obs a 22 PROPERTY OF EMPLOVER: s44quea dias tacewaeeheabanen Gime eaacne ees 23 MAR-A-LAGO 0179

The text on this page is estimated to be only 42.26% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page234 of 648 EMPLOYEE APPRAISAL. ...... 0... ccc cece ccc eee cece cece ee ceeeeeees 24 TELEPHONE COURTESY PROCEDURES..........cc cece e cece ccc ceeeecees 25 EMPLOYEE ATTENDANCE AND TARDINESS..............ccceecccececees 27 LINEN ABUSE.... 0.0.0.0 c cece ccc ccc cece cece cece ee cceeeeeees 28 TIME REPORTING - SIGNING IN AND OUT ............ ccc ce ceeeceees 29 CHANGE OF ADDRESS OR STATUS....... 0... ccc cece ee cece cece neces 29 INITIAL EMPLOYMENT PERIOD .......... ccc ccc cece cece cece cceees 30 WORK HOURS, SALARY AND OVERTIME PREMIUMS ................e0- 31 A. WORK HOURS ....... ccc ccc ccc ccc cee cc cee cc cent ceeees 31 By. SALARY és.0¢-cuin neds wicdhace Oe adi ws'o-a6ld o-4 4d Slew Ses se ds ack 31 C. OVERTIME PREMIUMS ........... 0. cc cece cece cece eee ceee 31 EMPLOYEE BENEFITS AND PROGRAMS ........... cece eee ce ec ccceeces 33 VACATION LEAVE ...... 0... ccc ccc ccc cece cece cece cece cece ccenees 34 SICK. TIME POLICY -i¢ bcuk sds 44d Sad ha edaS es dw ener edesia ate wexe 36 HOLIDAYS AND HOLIDAY PAY ..........0ccccceecccccceeccccceeues 37 BEREAVEMENT LEAVE .......... ccc cece cece ccc cece nec e ee ceeeeeees 38 BURY DUTY tans oentcutoreusdecedsetasesbasadseasteannenienede 38 MIDDTARY GRAVE guosaadatcaye eases ewe tasse shee aewes age oececece 39 MATERNITY LEAVE OF ABSENCE ......... ccc ccc cc cc cc cceccecceeces 39 FAMILY MEDICAL AND PERSONAL LEAVE OF ABSENCE ................ 40 GRIEVANCE PROCEDURE ........ ccc ccc ccc cece e ccc e cece eeeceeeees 47 DISCIPLINARY ACTION ........ ccc ccc ccc ccc eee cee eee eeaes 49 UNIFORMS AND PERSONAL APPEARANCE ...........c cece cecceccceees 54 AIDS POLICY ........... eapeeseeoau Seecteueneteeeeseeeoueeee: 57 DRUG/ALCOHOL USE AND TESTING ........... cc cece cece cece eeeees 59 POLICY ON SMOKING ......... 0. ccc cc cece eee cece ccc eececceeae 61 MISCELLANEOUS ....... ccc ccc ccc ce cc cece cee ccc e eee e ee eeeeeees 62 A STAFF CAFETERIA .......... ccc cece cece cece cece eeeees 62 MAR-A-LAGO 0180

The text on this page is estimated to be only 43.49% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page235 of 648 B. HOCKERS ti6404ecnd¢ee0Gseeae eae tereakas eewdeceedex 62 c. PHONES, 2264064 sa6 be ant caw eaten eeocsed anes tenes 62 D. LOST AND FOUND ......... cc cc ccc ccc cc ccc cece cc cece 62 E. GL PLS: hdd. S 6.014 bb aS eg eae eee oe mee bea ae eae Se 62 F. RIGHT TO KNOW STATION .............cccccccccccccees 63 G EMPLOYEE ENTRANCE AND EXIT ............cccccccccees 63 IF YOU LEAVE EMPLOYMENT ............ cece ccc eee eee ne ee eeeeeas 64 A. RESIGNATION POLICY .............. ccc cece cece ec eees 64 B. DISMIESSAUS -i.c6 <6 4 di eee 4 RES ARS Ge OR HRS elo 64 Cc: WRITTEN WARNINGS ...........---ceceees ee ere 66 D. VACATION PAY: 4.05446.6 6405440646044 44664 05000440 440408 67 a RETIREMENT PLAN ..........-..ccccccccccccc cece ccccae 67 F. CLEARANCE PROCESS ........cc ceca ccc ccc cece ccceees 68 EMPLOYMENT HANDBOOK RECEIPT ............. cc ccc ccc ccc ccc ccc cee 69 MAR-A-LAGO 0181

Case 18-2868, Document 278, 08/09/2019, 2628230, Page236 of 648 MAR-A-LAGO 0182

Case 18-2868, Document 278, 08/09/2019, 2628230, Page237 of 648 INTRODUCTION MAR-A-LAGO 0183

Case 18-2868, Document 278, 08/09/2019, 2628230, Page238 of 648 The Mar-A-Lago Club, L.C. ("the Club") seeks to provide the quality of work which will develop the potential of each employee as well as the Club as a whole. In this regard, this policy and procedures manual is designed to acquaint each employee with the administrative and personnel practices of the Club. These guidelines provide a framework for the fair and equitable treatment of all employees regardless of location, department, manager or Supervisor. Each employee should be ffamiliar with the responsibilities and opportunities available to make work as rewarding as possible. These policies and procedures should be read carefully and clearly understood. Each department head, manager or supervisor will be able to answer, or obtain an answer, to any questions involving interpretation or clarification of these policies and procedures. Each employee is expected to apply these general policy and procedure guidelines conscientiously in a constructive and supportive manner. | The policies in this manual are only guidelines and the Club reserves the right to add to, subtract from, or change these provisions in any way, at any time, without being bound to the previously replaced or revised provisions. This handbook is not to be construed as an employment agreement or employment contract and the Club is under no obligation to provide the benefits set forth in this manual if it determines, at a subsequent time, that these benefits are to terminate. MAR-A-LAGO 0184

Case 18-2868, Document 278, 08/09/2019, 2628230, Page239 of 648 EQUAL EMPLOYMENT OPPORTUNITY The Club is an equal opportunity employer which is committed to prohibiting discrimination on the basis of race, color, sex, age, religion, national origin, sexual orientation, marital Status, or disability throughout the employment process, from selection through termination. The Club intends to provide a pleasant work environment that is healthful and comfortable and will not tolerate any form of employee harassment, either verbal, written, physical, or visual, based on race, color, religion, sex, national origin, age, disability or marital status. Harassment can take many forms. It may be, but is not limited to: words, signs, jokes, pranks, intimidation, physical contact, violence toward any employee by a fellow employee, a supervisor, or a person doing business with the Club. Harassment is not necessarily sexual in nature. All necessary steps will be taken to comply with existing federal, state and local fair employment laws and guidelines. MAR-A-LAGO 0185

Case 18-2868, Document 278, 08/09/2019, 2628230, Page240 of 648 ORIENTATION POLICY The first ninety days of employment are considered to be an orientation or probationary period during which you and the Club have an opportunity to know each other. Your performance will be evaluated during this time to access your potential for continued employment. Evaluations will continue as long as you are employed, but during the orientation period your supervisor may observe and evaluate your performance more closely and more frequently to ensure that you are learning your job. During this orientation period, employees may earn but may not use vacation or personal days, except with permission of the Club Manager's office. If the employment relationship is terminated during this ninety day period, you shall not be entitled to receive any payment for benefits, e.g., personal days, vacation days, or unemployment compensation. MAR-A-LAGO 0186

Case 18-2868, Document 278, 08/09/2019, 2628230, Page241 of 648 SEXUAL HARASSMENT The Club strictly prohibits any form of harassment in the workplace, including sexual harassment. Definition of Sexual Harassment: dL. Unwelcome sexual advances, requests for sexual favors, and other such verbal or physical conduct constitute sexual harassment under the following conditions: A. Submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment. B. Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual. C. Such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile or offensive work environment. 2% Conduct which falls into the definition of sexual harassment may include, but is not limited to: A. Unwelcome physical contact of a sexual nature such as patting, pinching or unnecessary touching. B. Overt or implied threats against an individual to induce him or her to perform sexual favors or to engage in an unwelcome sexual relationship. C; Verbal harassment or abuse of a sexual nature, including intimating by way of suggestion a desire for sexual relations or making jokes or remarks of a sexual nature to or in front of a person who finds them offensive. D. Use of sexually suggestive terms or gestures to describe a person's body, clothing, or sexual activities. E. Displaying or posting offensive sexually suggestive pictures or materials in the workplace. Recourse: MAR-A-LAGO 0187

Case 18-2868, Document 278, 08/09/2019, 2628230, Page242 of 648 If an employee feels that an incident of any form of harassment has occurred, the employee is encouraged to report the matter to the Club Manager's office. All such issues will be handled in strict confidence to the extent possible with minimum embarrassment to the involved parties. As in any grievance procedure, the facts of the situation will be reviewed objectively so that appropriate disciplinary action, including discharge, can be taken if misconduct has occurred. A timely resolution of each complaint is to be reached and communicated to the parties involved. Retaliation against any employee for filing a complaint or participating in an investigation is strictly prohibited. In the event an employee files a frivolous, malicious or false claim, appropriate sanctions for discipline of the complainant, including termination, may result. MAR-A-LAGO 0188

Case 18-2868, Document 278, 08/09/2019, 2628230, Page243 of 648 CARE OF FACILITIES The Club has made a large investment in equipment and facilities to provide each employee with the necessary resources to accomplish his/her duties. It is the responsibility of management and each employee to treat equipment and facilities with respect and care. Neatness and cleanliness are required to maintain these resources at a level at which the employee can and will be proud. Abuse of equipment and facilities will not be tolerated and may lead to disciplinary action including discharge. MAR-A-LAGO 0189

Case 18-2868, Document 278, 08/09/2019, 2628230, Page244 of 648 ENTRY AND EXIT OF CLUB GROUNDS/PREMISES All employees must enter and leave the Club at the Southern Boulevard gates unless otherwise directed by management. Employees may not enter the Club grounds/premises more than 30 minutes before the start of their scheduled shift, and employees must exit the Club grounds/premises directly after their shift ends, unless authorized by your department head. When conducting Club business off the premises of Mara-Lago, you must have approval of your department head or supervisor. | Employees may not patronize the Club facilities without prior written approval of their department head. If an employee needs to return to the property for any reason, the employee must contact their supervisor or a department head prior to their arrival. Security must be contacted in the event no supervisor is available. MAR-A-LAGO 0190

Case 18-2868, Document 278, 08/09/2019, 2628230, Page245 of 648 PROOF OF AUTHORIZATION TO WORK You must comply with government regulations by furnishing valid documentation of both your identity and your authorization to work. The Club Manager will advise you what documents are acceptable. If your immigration or work authorization status changes after you begin work so that you are no longer able to continue to work in the United States, you must advise your Supervisor and the Human Resources Manager. MAR-A-LAGO 0191

Case 18-2868, Document 278, 08/09/2019, 2628230, Page246 of 648 SECURITY A. INFORMATION All financial, contract, production, and administrative records and information of the Club and its members are confidential. Each employee is responsible for making certain that information under his/her control is appropriately safeguarded. An employee will not provide or disclose office or guest information to third parties unless it has been determined that the party has a legitimate right to know and the request has been approved by your Supervisor. Authorization by the Managing Director must be obtained before written contact is made of any member, client, purveyor, (current or prospective). Any uncertainties should be cleared with the Managing Director before such information is provided. B. CONFIDENTIALITY No employee shall, during the term of his/her employment or thereafter disclose to others or use, except as authorized by the Managing Director, any of the Club's confidential, technical, or other business information. "Confidential, technical or other business information" shall mean any information, including lists of the Club's vendors and customers, which the employee has used, learned or contributed during the course of his/her employment, regardless of whether 1t was written or in other tangible form that (i) is not generally available to the public; or (ii) gives one who uses it a competitive advantage over the Club. Cs FACILITIES Access to Club facilities will be limited to parties with a legitimate reason to be there. Employees are not permitted to have visitors on the premises unless special arrangements have been made by the employee's supervisor. Outside visitors will be greeted by Post One and escorted to their area of business. Each employee should feel comfortable in politely confronting an unknown individual who appears suspicious or in need of direction. : An essential element of the security procedures of the Mara-Lago Club is the key control process. As such, employees who have access to Club keys must recognize the importance of properly safeguarding the keys which have been entrusted to them. All employees should be aware that they may be subject to disciplinary action for any violation of the key control procedures. Guest room keys must never be left in your locker. MAR-A-LAGO 0192

Case 18-2868, Document 278, 08/09/2019, 2628230, Page247 of 648 In the event of a breach or threatened breach by the employee of provisions A, B or C of this section, the Club shall be entitled to an injunction restraining the employee from disclosing or using, in whole or in part, such information or from rendering any services to any person, Club, corporation, association, or other entity to whom such information, in whole or in part, has been disclosed or is threatened to be disclosed. Nothing herein shall be construed as prohibiting the Club from pursuing other remedies available to the Club for such breach or threatened breach, including the recovery of damages from the Club. D. GUEST PRIVACY Everyone enjoys privacy. Employees are prohibited from revealing any personal or business information about a Club member. Do not divulge names or room numbers of one guest to another. Do not let a person into any guest room without verifying with the front desk that the person is the guest registered to that room. All guest floors and areas are off limits to employees unless they are specifically assigned to perform work duties in these areas. Employees are not allowed to accept invitations from guests to join them in their room. At no time is an employee to ask a member for an autograph or to ask a member to socialize with them off duty. E. UNAUTHORIZED AREAS Employees may not enter areas of the building, especially guest floors, unless they have been assigned by a supervisor. Example: | Building Employees require work orders on guest floors. Food Service Employees require valid room service checks or authorized pick-up request before going on the guest floors. : | F. REPORTING CRIME The Security Department, with its able staff, attempts to control crime and provide a safe operation. Due to the enormity of the Club, they cannot be everywhere at once, and your help is needed. Follow these simple security measures: MAR-A-LAGO 0193

Case 18-2868, Document 278, 08/09/2019, 2628230, Page248 of 648 1) Notify Security (ext. 212) of any suspicious person. 2) If you are a witness to a crime, relate to the dispatcher as much specific detail as possible, including a description of the individual and the nature of the crime. G. MEDIA Because of the celebrated and historic nature of Mar-a-Lago and its significance to Palm Beach, Florida and the United States, we are contacted daily by the media (television, radio, newspapers, magazines, wire services). They want to know what is happening at the Club and they want comments for their articles or newcasts. It is important that no Club employee other than the Managing Director, Special Events Manager or Director of Membership comment to the press on the Club or it’s members. GUEST NAMES All guests are to be treated in a friendly, courteous, professional manner. Systems or procedures are used within each department to inform emplyees of our guests' names. We want you to use the guests' name at all times if possible. Be friendly to guests and call them by name; however, do not be too familiar with a guest by using his/her first name. MAR-A-LAGO 0194

Case 18-2868, Document 278, 08/09/2019, 2628230, Page249 of 648 SAFETY AND HEALTH The Club's goal is to provide a safe and healthy environment for employees. Each employee is expected to comply with all safety and health requirements whether it is established by management or by federal, state or local law. The Club does not expect any employee to take unnessary risks. Study the job assigned to you and learn the safety rules of your department. In everything you do, make sure that you have observed every reasonable safety precaution. Most Club accidents are simple and common, such as slips and falls, cuts, burns, sprains and strains. They are easy to prevent. Observation of the following general rules will prevent many employee accidents: De Report all injuries at once to your supervisor. 2. If you are not sure how to do a job safely, ask your department head. 3% Horseplay and practical jokes are prohibited. 4. Put equipment away after use. Don't block passages. Bu Broken chairs, loose and worn carpeting, missing lights and other equipment needing maintenance may cause accidents. Report these along with any other safety hazard at once to your department head. 6. Wear the right clothing for the job. Ts Show other employees the safe way to do the job. 8. If the ead seems too heavy to lift safely, get help. When lifting any load, follow the safe lifting practice listed below: a. Be sure you can handle it alone. If not get help. b. Face the load squarely. Cx Secure a firm footing with your feet properly spread. d. Bend your knees. e. Get a grip on the load. E Keep a straight back and lift by straightening your legs gradually not suddenly. MAR-A-LAGO 0195

Case 18-2868, Document 278, 08/09/2019, 2628230, Page250 of 648 g. Keep the load close to your body. h. Don't twist your body. 9. Do not carry a load so that it will block your vision Make sure you can see where you are going. 10. Avoid slippery, wet or greasy floors. Clean up wet or greasy spots as they occur. 11. Use a ladder to reach things that are up high. See that the ladder is firmly placed. While on the ladder, don't reach too high or too far to one side. 12. Place broken glasses, dishes, etc., in special receptacles designated for this purpose. 13. Do not operate equipment unless properly trained and specifically instructed to do so by your supervisor. All accidents occurring on the Club's premises or to Club employees, regardless of whether they result in an injury, must be reported immediately to your supervisor. The Club is required to report all work-related injuries as soon as possible. If you are too seriously injured to describe the facts surrounding the accident, it is the responsibility of the supervisor to supply the information to the Human Resources Manager. If a member has an accident, you should see that he or she is comfortable and then immediately notify your’ supervisor, department head, Managing Director and the Security Department. Any property damage due to accidents should be reported in the same manner. WORKERS' COMPENSATION We all do the best job we can to prevent accidents and injuries at home and at work. If you spot a safety hazard on the job, report it to your supervisor immediately. Workers' Compensation 1s provided by the company to pay an employee partial compensation if he or she loses time due to a work-related accident. In case you are injured: 1. Report the inujury immediately to your supervisor. 2. Following first-aid oor medical treatement, your supervisor will contact security to file an incident report and then notify the Human Resources Manager. MAR-A-LAGO 0196

Case 18-2868, Document 278, 08/09/2019, 2628230, Page251 of 648 36 The Human Resources Manager completes the Workers' Compensation Report and submits copies to the insurance carrier. When you lose work time because of an injury on the job, a medical certificate from your doctor or the Health Center must be submitted to the Human Resources Manager with a return to work date prior to return to work. Remember to report all injuries immediately, no matter how small they may be, to your supervisor. Though the injury may seem small at first, it may become serious later, and result in lost work time. MAR-A-LAGO 0197

Case 18-2868, Document 278, 08/09/2019, 2628230, Page252 of 648 EMERGENCY PROCEDURES: Adhere to the following procedures in emergency situations: A. FIRE -- In case of fire or smoke: STAY CALM 1. Pull fire alarm 2. Dial Security at Extension 212 and give location of fire, (closest room number, floor, type of fire or smoke), remain on the phone to give additional information as required. 3. When the fire department or Club fire brigade arrives, direct them to the location. Remember, most persons die from smoke and poisonous gases. Stay low to the ground if there is any smoke at all. If you encounter smoke or fire at lower levels, turn around and walk up to clearer air, or use another exit. 4. Be certain to follow instructions of the fire department and the Club fire brigade in order to ensure the safety of all guests and employees. B. BOMB SCARE OR WARNING You all know your own work areas, and are usually aware of any unfamiliar items. A bomb may be concealed in a length of pipe, small parcel, suitcase or paper bag. When a suspicious item is discovered DO NOT TOUCH and report immediately to: 1. Club operator - dial 300 - ee Security - dial 212 3 GUEST ILLNESS - Follow the same procedures as listed above. The most important thing to remember in an emergency is DO NOT PANIC! USE OF CLUB'S COMPUTER SYSTEM AND SOFTWARE PROGRAMS: A. GENERAL The Club has invested a large sum of money in its computer system and software programs. The information in the computer system represents much work by many employees and is an important component of the Club. In order to protect this valuable MAR-A-LAGO 0198

Case 18-2868, Document 278, 08/09/2019, 2628230, Page253 of 648 information, no employee is allowed to bring to work any computer games, hardware, programs or software which is not licensed and registered under the Club name, or install or otherwise use any such items unless they have been approved in advance, in writing, by the Managing Director. The reason for this is simple. Outside programs may contain viruses which can disrupt or destroy our computer system. Even if you are sure that the program you bring does not contain a virus, and that it would not damage our computer system, you are not to use any outside program without written advance approval. If software programs are not properly registered, there may be criminal and civil penalties for their use. In addition, the Club has noted that some computer programs also contain games or programs which are not related to the work of the Club. These programs are not to be played by any employee at any time during the work day. Only computer programs that are directly related to the work of the Club are to be used on Club computers. No employee is authorized to download or ‘remove any information from the Club's computer system without the expressed advance permission of the appropriate supervisor. (See the Club's policy on security.) B. ELECTRONIC MAIL During your workday, the electronic mail and other information systems are not to be used in a way that may be disruptive, offensive to others, or harmful to morale. Specifically, it is against Club policy to transmit E-mail communications that contain ethnic slurs, racial epithets, or anything that may be construed as harassment or offensive to others based on their race, national origin, sex, sexual orientation, age, disability, religious or political beliefs, is strictly prohibited and may constitute grounds for termination. Employees should use the information systems for Club business only. The E-mail system also should not be used to solicit others for commercial ventures, religious or political causes, outside organizations, or other personal matters unrelated to your job. For privacy reasons, employees should not attempt to gain access to another employee's personal file of E-Mail messages without the latter's express permission. Further, employees shall not use a code, access a file or retrieve any stored communication, other than where authorized, unless there has been prior clearance by an authorized Club representative. Management reserves the right to enter an employee's E-mail files on an "as needed" basis by authorized personnel to ensure the Club's legitimate business interest in the proper use of its property. System security features such as passwords and message MAR-A-LAGO 0199

Case 18-2868, Document 278, 08/09/2019, 2628230, Page254 of 648 delete functions do not neutralize the employer's ability to access any message at any time. Employees who use E-mail for private, non-job-related purposes do so at their own risk. By using the Club's equipment and E-mail systems, employees consent to have such E-mail use, messages and files monitored by authorized firm personnel. Cs VOICE MAIL The Club utilizes a voice mail system which allows employees, clients, etc. to leave voice messages. The Club reserves the right to monitor and review all messages left on the voice mail system at any time. All voice messages should be confined to business or work-related matters. D. RIGHT TO INSPECT No employee is to have an expectation of privacy with regard to any voice mail messages, E-mail or computer files, and the Club has the right to monitor and review these enecenoate and computer systems at any time. MAR-A-LAGO 0200

Case 18-2868, Document 278, 08/09/2019, 2628230, Page255 of 648 DISCLOSURE OF EMPLOYEE INFORMATION REFERENCE CHECKS All inquiries regarding a current or former employee of The Mar-a-Lago Club must be referred to the Human Resources Manager. Should an employee receive a written request for a reference, he/she should refer the request to the Human Resources Manager for handling. No Mar-a-Lago Club employee may issue a reference letter to any current or former employee without the permission of the Human Resources Manager or Managing Director. Under no circumstances should any Mar-a-Lago Club employee release any information about any current or former Mar-a-Lago Club employee over the telephone. All telephone inquiries regarding any current or former employee must be referred to the Human Resources Manager. In response to an outside request for information regarding a current or former Mar-a-Lago Club employee, the Human Resources Manager will furnish or verify only an employee’s name, dates of employment, job title and department. No other data or information regarding any current or former Club employee, or his/her employment witb Mar-a-Lago will be released unless the employee authorizes the Club to release such information in | writing or Mar-a-Lago is required by law to furnish any information. MAR-A-LAGO 0201

Case 18-2868, Document 278, 08/09/2019, 2628230, Page256 of 648 NO SOLICITATION/NO DISTRIBUTION Persons who are not employees of the Club are prohibited from soliciting our employees, distributing literature, or selling merchandise to our employees, on our premises at any time. The purpose of this rule is to prevent employees and customers from being disrupted or imposed upon by such activities and to maintain our operations at peak efficiency at all times. For similar reasons, solicitation and distribution of literature are prohibited during the working time of either the employee making the solicitation or distribution, or the targeted employee. The term "working time" does not include an employee's authorized lunch or rest periods, or other time when the employee 1s not required to be working. Distribution of literature is prohibited in work and customer areas at all times. The distribution of literature in such a manner as to cause litter on the Club's property is prohibited. Off-duty employees are not allowed to return to the interior or working areas of the Club's premises until the next scheduled work time. The Club maintains bulletin boards to communicate Club information to employees and to post notices required by law. These bulletin boards are for the posting of Club information and notices only, and only persons designated by the Managing Director may place notices on or take down material from the bulletin boards. The unauthorized posting of notices, photographs or other printed or written materials on bulletin boards or any other Club property is prohibited. MAR-A-LAGO 0202

Case 18-2868, Document 278, 08/09/2019, 2628230, Page25/7 of 648 INSPECTIONS The Club respects its employees' right to privacy. However, for security purposes, we maintain the right to inspect certain personal belongings. Each employee agrees, as a condition of continued employment, to allow management to inspect employee personal property on our premises. Any package brought into or taken out of our premises may be inspected. Our premises and equipment, including Club vehicles, lockers and desks, are subject to inspection at any time. Refusal to cooperate in an inspection or search will be considered a violation of your terms of hire and insubordination. INTERNAL INVESTIGATIONS From time to time The Mar-a-Lago Club may be required to conduct internal investigations pertaining to security, auditing or work-related matters. Employees are required to cooperate fully with and assist in these investigations if requested to do SO. Whenever necessary, in Management’s discretion, employees’ work areas (i.e., desks, file cabinets, etc.) and personal belongings (i.e., brief cases, handbags, etc.) may be subject to a search. Employees are required to cooperate. Management will generally try to obtain an employee’s consent before conducting a search of work areas or personal belongings, but may not always be able to do so. MAR-A-LAGO 0203

Case 18-2868, Document 278, 08/09/2019, 2628230, Page258 of 648 OUTSIDE EMPLOYMENT The Club does not object to your holding other jobs, provided that there is no conflict of interest and your job at the Club comes first. However, outside employment which interferes with your obligations to the Club is prohibited. In addition, no employee shall claim to be a Club representative in connection with any outside employment. Before accepting any supplementary job, it is mandatory that you notify your Supervisor and the Department Head to determine if there is a conflict of interest or if it would adversely affect your job performance at the Club. If the Club determines that a conflict of interest exists or acceptance would adversely affect your job performance, you shall not engage in outside employment. Failure to notify the Supervisor and the Department Head in advance of any outside employment will be grounds for immediate termination. Please note that if at any time your job at the Club suffers due to additional employment elsewhere, the Club reserves the right to ask you to give it up. Failure to comply with such a request will also be grounds for immediate termination. MAR-A-LAGO 0204

Case 18-2868, Document 278, 08/09/2019, 2628230, Page259 of 648 PROPERTY OF EMPLOYER Employees may not remove from the Club premises any Club property not belonging to the employee. Any other property that an employee removes from Club premises, must be accompanied by a Club Package Pass, signed by a department head or his/her designated supervisor. Upon termination of your employment, you must surrender to the Club any and all material including, but not limited to, drawings, manuals, reports, documents, lists of the Club's vendors and customers, and the like (including all copies thereof), that you have in your possession relating to the business of the Club, or its affiliates. You recognize that all such materials are the property of the Club solely and that you have no right, title, or other interests in or to such materials. MAR-A-LAGO 0205

Case 18-2868, Document 278, 08/09/2019, 2628230, Page260 of 648 EMPLOYEE APPRAISAL It is the objective of the Club to provide an atmosphere in which each employee can receive periodic, thorough appraisals of their performance and compensation. The Club uses the performance evaluation as a means to achieve these objectives. Each Manager, Supervisor and employee should be familiar with their role in contributing to the success of the appraisal system. TELEPHONE COURTESY PROCEDURES Telephone Calls - Personal calls are prohibited,except in an emergency, since it interferes with the flow of business. Telephone courtesy is an essential part of every employee's interaction with guests. All incoming calls should be answered according to the following mandatory procedures: a All calls are to be answered within three rings MAR-A-LAGO 0206

Case 18-2868, Document 278, 08/09/2019, 2628230, Page261 of 648 2. Answering a Department line: a. standard greeting (i.e., Good Morning/Afternoon/Evening) . b. Give the name of the department. oe Give your name. d. Offer assistance: "Good morning, Reception Desk. This is John. How may I help you?" a4 Answering another individual's line: a. Standard greeting. b. Identify whose office or department. es Give your name. . d. Offer assistance or to take a message: "Good afternoon, Mr. Smith's office. This is Mary. How my I help you?" ) 4. When placing a call on "hold:" a. Use the word "wait," not "hold." b. Always ask permission and wait for guest's response: "Are you able to wait?" 56 Returning to a call placed on "hold': a. Always thank the guest for waiting or apologize for the wait. b. Give your name. CG, Offer assistance: "Thank you for waiting, this is Mary. How may I help you?" 6. When transferring a call: a. Always announce the transfer of a call to the party receiving the call: "Mr. Smith, I am transferring Bob Jones to you." b. The caller should then be connected and an announcement of the connection made: "I have Mr. Smith on the line now. Go ahead, please." 7. When ending a conversation: a. Always say "thank you" or "you're welcome." b. Use the guest's name if possible. C. Let the caller know you are happy to be of service Or sorry you are unable to help. d. End the conversation with "good-bye" and hand up the receiver gently: "Thank you for calling, Mr. Smith. We're glad we could help. Good-bye." MAR-A-LAGO 0207

Case 18-2868, Document 278, 08/09/2019, 2628230, Page262 of 648 MAR-A-LAGO 0208

Case 18-2868, Document 278, 08/09/2019, 2628230, Page263 of 648 EMPLOYEE ATTENDANCE AND TARDINESS Your schedule is developed after considering the Club's | needs and flow of business. Your adherence to the schedule and flexibility concerning any necessary changes will help ensure our Club's success. Fach employee is required to work the hours normally scheduled for his or her assigned position. Employee's work schedules will be those hours authorized by their Supervisor to meet operaional requirements. If you are unable to report to work for any reason, you must notify your supervisor no later than Three (3) hours prior to your scheduled reporting time, stating your reason for lateness or absence, and when you expect to arrive at work. Check with your supervisor to see if additional notice time is required. In the event your supervisor is not available, you are to contact SECURITY Ext.212 or the Human Resources Manager. You must call in each day of your absence. Upon the third consecutive day of absence, a Health Care Provider's note will be required of the employee before returning to work. An employee who is absent for three consecutive days without proper notice to the Club may be considered to have voluntarily resigned his or her position with the Club. Failure to adhere to employee attendance policies results in time consuming arrangements and costly replacements and may lead to disciplinary action. Tardiness places an unfair burden upon your supervisors and co-workers. All efforts should be made to be at work according to schedule. Your supervisor is to be contacted if it is unavoidable for you to be late to work. Continued tardiness will result in disciplinary action, up to and including termination. MAR-A-LAGO 0209

Case 18-2868, Document 278, 08/09/2019, 2628230, Page264 of 648 LINEN ABUSE Linen abuse is considered to be any type of mishandling or misuse of linen, causing damage to the point that the linen would be unfit to place before a guest. The following are the most common abuse occurrences. Using linen as rags for cleaning. Leaving linen lying on the floor. Cleaning ashtrays with linen. Using napkins as food covers. Carrying linen on your person to be used as sweatbands, handkerchiefs, etc. Throwing rags or linen in the trash. Mixing rags with linen. UO ® WN Fe ~] OF Violation of these linen abuse standards may lead to disciplinary action. The replacement of lost or damaged linen is a costly process, and we need everyone's help in curtailing this enormous expense. MAR-A-LAGO 0210

Case 18-2868, Document 278, 08/09/2019, 2628230, Page265 of 648 TIME REPORTING - SIGNING IN AND OUT You must check in first at the guard post at the employee's entrance on Southern Boulevard, and then again upon your arrival at Post One. At the end of your shift you must check out at Post One and also at the guard post at the employees' exit on Southern Boulevard. When reporting in and out of work employees will be solely responsible for keeping their own hours worked by logging in and out at the timekeeping terminal. Pay is calculated for the actual hours worked by the actual entry of this information. Any deviations in the schedule including overtime can be done with the supervisors approval only. These deviations are indicated in writing at the end of the work week for presentation to payroll. Under no condition shall an employee enter for time other than his/her own. An employee who leaves the Club during his/her work schedule must first obtain their supervisor's permission. Failure to adhere to these procedures, will result in disciplinary action, up to and including termination of employment. NOTE:All Wait Staff employees must also sign in on the ‘‘DAILY SIGN IN SHEET’’ which will be located with your Captain. CHANGE OF ADDRESS OR STATUS - PERSONNEL RECORDS To keep necessary Club records up-to-date, it is extremely important that you notify the Human Resources Department of any changes in: Name and/or marital status. Address and/or telephone number. # of eligible dependents. W4 Deductions. m WD MAR-A-LAGO 0211

Case 18-2868, Document 278, 08/09/2019, 2628230, Page266 of 648 INITIAL EMPLOYMENT PERIOD Every new employee goes through an initial period of adjustment in order to learn about the Club and about his/her job. During this time, the employee will have an opportunity to find out if | he/she is suited to, and likes, his/her new position. Additionally, the initial employment period gives the employee’s supervisor a reasonable period of time to evaluate his/her performance. The initial employment period is 3 months. During this time, the new employee will be provided with training and guidance from his/her Supervisor. He/she may be discharged at any time during this period if his/her Supervisor concludes that he/she is not progressing or performing satisfactorily. Additionally, under appropriate ereeumeceneee: the initial employment may be extended. At the end of the initial employment period, the employee and his/her supervisor may discuss his/her performance. Provided his/her job performance is ‘‘satisfactory’’ at the end of the initial employment period, he/she will continue in our employment. EMPLOYEE CATEGORIES | * Full Time - Year Round Employee = Seasonal Employee WORK HOURS, SALARY AND OVERTIME PREMIUMS a. WORK HOURS The Club never shuts down from November 1 to Mother’s Day; for 24 hours a day, 7 days a week, it serves the diverse needs of our members. Therefore to ensure adequate coverage at all times, departments have arranged different schedules for their employees. MAR-A-LAGO 0212

Case 18-2868, Document 278, 08/09/2019, 2628230, Page267 of 648 SALARY The Club's policy regarding personnel is to offer competitive starting wages and to maintain a fair and equitable wage structure. Wage increases are given when appropriate based upon results of performance evaluations and/or employment status change. The work week at the Club begins on Monday and ends on Sunday. Scheduled paydays are as follows: Friday pay vouchers indicating deposit into your existing Great Western banking account will be issued. If there is a discrepancy in your paycheck, advise your department head immediately. Do not call or go to the payroll department. If your department head is not available, contact the Human Resources Manager and assistance will be provided. The Club is unable to make advances on employee paychecks. OVERTIME PREMIUMS alee Hourly and Salaried Employee (non-exempt) Hourly or salaried employees are eligible for overtime premium at one and one-half (1.5) times their base hourly rate under the following conditions: Overtime work has been specifically authorized by the direct Supervisor in advance or in writing after the fact. More than forty (40) hours are actually worked by that individual in one work week, not including sick time, vacation, holidays and time off for personal business and other non work time. The work week commences on Monday morning and ends Sunday at midnight. Zz Salaried Employee (exempt) A salaried exempt employee is not compensated directly for specific overtime hours worked. A salaried employee is paid to accomplish a specific job and his/her salary is based upon the fact that hours in excess of 40 per week may be necessary on occasion. Overtime is at the request of a supervisor or department MAR-A-LAGO 0213

Case 18-2868, Document 278, 08/09/2019, 2628230, Page268 of 648 head for emergency client business. The Supervisor must authorize overtime and sign the employee’s schedule signifying such authorization. EMPLOYEE BENEFITS AND PROGRAMS As a regular full time year round employee you will enjoy an excellent benefits package which is designed to help protect your health, and plan for your future. The Mar-a-Lago Club reserves the right to change any or all of these benefits at any time. - Group Health Insurance * Group Life Insurance * Group Dental Insurance * 401K - After one full year of continuous employment For information relating to the cost of such benefits, eligibility requirements, etc. please contact the Human Resources Manager. MAR-A-LAGO 0214

Case 18-2868, Document 278, 08/09/2019, 2628230, Page269 of 648 BEREAVEMENT LEAVE In the event of a death in an employee’s immediate family, the Club will allow a maximum of three (3) days off with pay for funeral related leave. Immediate family includes spouse, child, mother, father, brother, sister, grandparent, grandchild, aunt, uncle, daughter-in-law, son-in-law, mother-in-law, father-in-law, step-child, step-parent. When a death occurs, notify your supervisor at once with all of the details, including the family member who died and where the funeral will take place. The supervisor should notify the Human Resources Manager of the reason and length of the employee’s absence. JURY DUTY An employee summoned for jury duty will be compensated in the following manner only if he/she notifies his/her supervisor and provides him/her with a copy of the summons. During the jury leave, the employee will be paid the difference between jury compensation and the employee's regular pay for up to three days. Any day in which you are excused from jury service at a time when there are three (3) or more hours remaining in your daily scheduled shift, you will report for work. | NOTE: If the jury duty falls at a time when the employee cannot be away from work, the court may allow the employee to choose a more convenient time to serve if he/she makes a request in accordance with the court’s procedure. MAR-A-LAGO 0215

Case 18-2868, Document 278, 08/09/2019, 2628230, Page2/0 of 648 MILITARY LEAVE An employee who is a member of the United States Army, Navy, Air Force, Marines, Coast Guard, a member of the National Guard, a member of the Reserves or Public Health Service will, where a specified period of active or reserve duty is mandatory, be granted a leave of absence in accordance with applicable law. Upon receipt of orders for active or reserve duty, the employee should notify his/her supervisor, as well as the Human Resources Manager immediately and he/she must submit a copy of his/her orders to his/her supervisor and the Human Resources Manager. MATERNITY LEAVE OF ABSENCE Pregnancy, childbirth, and related medical conditions are temporary disabilities for the purpose of any health or temporary disability insurance or sick leave policy maintained by the Club. An employee who is pregnant, or has medical conditions related to pregnancy will be granted a leave of absence and will be eligible for the same leave benefits as received by employees suffering from illness or other temporary disabilities. FAMILY MEDICAL AND PERSONAL LEAVE OF ABSENCE MAR-A-LAGO 0216

Case 18-2868, Document 278, 08/09/2019, 2628230, Page2/1 of 648 As a result of the Federal Family and Medical Leave Act ("Act"), the Club provides an added benefit to each employee. Each employee will have up to 12 weeks of unpaid family leave during a "rolling" 12-month period month period for: (1) the birth and care of a newborn child; (2) adoption or foster care of a child; (3) to provide care to an employee's spouse, son, daughter or parent (or grandparent under certain circumstances) who has a serious health condition; and (4) the employee's own serious health condition which makes the employee unable to perform his/her job functions. Upon an employee's return from this leave, the Club guarantees that the employee will be placed in the same or equivalent position, absent grievous and substantial business reasons affecting the Club. This leave may be used during the rolling 12-month period even if the full 12 weeks have not been taken. Intermittent use of this leave or a reduced leave schedule may be allowed only where leave is taken for a sick family member, or for an employee's own serious health condition, when medically necessary. If you are not eligible for the 12 weeks unpaid leave, you may still be eligible to take-an unpaid leave of absence for medical reasons or a personal leave of absence at the discretion of the Club. As a result of the Act, it has been necessary to modify some provisions of our policies on sick days, short term disability and personal leaves of absence to comply with the Act. The information that follows is designed to address the great majority of situations that arise in a regular or routine manner. The federal Family Leave Law, however, is subject to on-going review process and interpretation by the courts, therefore, the statements made here can not possibly address every contingency that may arise in interpreting this new and broad Law. For these reasons, special situations will be reviewed on a case-by-case basis. Set forth below is the Club policy with regard to medical and personal leaves of absence, including provisions of Act. If you have any questions, please contact the Human Resources Manager who will be glad to answer your questions. A. 12 Week Family Medical Leave Purpose: | This policy allows an employee to request a family or regular medical leave of absence (LOA) because the employee has a serious health condition which makes the employee unable to perform the functions of the job position (this policy includes a serious health condition related to pregnancy) . MAR-A-LAGO 0217

Case 18-2868, Document 278, 08/09/2019, 2628230, Page2/2 of 648 Policy: All employees with a minimum of 12 months of service (and 1250 or more hours worked during the previous 12 months) at the time the family medical LOA begins, are eligible for up to 12 weeks of unpaid family medical LOA during a rolling 12-month period. Employees are eligible so long as the employee is certified to be unable to work during this LOA period. See Section D below for details on requesting this LOA. B. Regular Policy for those Not Eligible for Family Medical LOA (e.g. previously used Family LOA) All employees who are not eligible for the 12 week family medical LOA at the time the medical LOA begins (e.g., less than 12 months of service, less than 1250 hours worked, or insufficient time has passed since a previous LOA) are eligible for unpaid medical LOA normally not to exceed 10 days. See Section D below for details on requesting this LOA. C. Family and Personal LOA This policy allows an employee to request consideration for a family or personal LOA. I Policy (Family LOA): All employees with a minimum of 12 months of service and 1250 or more hours worked in the previous 12 months at the time the family LOA begins are eligible for up to 12 weeks of unpaid LOA during a rolling 12-month period for: * the birth or adoption (or foster care) of a child. * providing care to a family member who has a serious health condition (family member is defined as spouse, child, or parent). Please Note: A child is one who is under 18 years of age or if 18 years or older must be incapable of self-care because of mental or physical disability. 2. Policy (Personal LOA) Employees who are not eligible for the 12 weeks family LOA at the time the LOA begins (e.g., less than 1 year of service, less than 1250 hours worked, or insufficient time has passed since previous LOA) are eligible for a personal LOA without pay in the Club's sole discretion. MAR-A-LAGO 0218

Case 18-2868, Document 278, 08/09/2019, 2628230, Page273 of 648 Employees requiring additional time may be required to terminate employment and advise the Club of availability for future rehire. Request for non-family personal LOA may not be approved due to the effect on department operations and/or due to the individual's job performance. See Section D below for details on requesting this LOA. D. General Procedures for LOA La While on an approved family or other LOA, an employee does not accrue time toward sick leave, vacation days, merit review nor does he/she receive holiday pay. 2. Detailed Procedures: (a) A request for any medical LOA must be certified by the employee’s health care provider on the claim form supplied by the Human Resources Manager. (b) An employee requesting a medical LOA must provide the Human Resources Manager with sufficient medical evidence to support the condition that prevents the employee from performing the assigned job duties. This signed health care provider's statement must include effective date of the LOA, reason for the LOA and approximate date of return. If the medical evidence is deemed to be inconclusive, the Human Resources Manager may arrange for a medical examination (at the Club’s expense) to determine the extent of the employee’s condition. The Club may require periodic recertification. The duration of a medical LOA is determined by the period of time the employee has a serious health condition which makes the employee unable to perform the job efficiently and safely. (c) Reinstatement may not be guaranteed in management's discretion (employee will be notified prior to beginning the LOA) if the employee is a key salaried employee. (d) An employee who returns from a family medical or family LOA on or before the approved LOA has elapsed will be reinstated to his/her previous department and job. Otherwise, every effort will be made to place the returning employee into an equivalent position. However, for an employee returning from a LOA that has exceeded the allowed maximum calendar days, no MAR-A-LAGO 0219

Case 18-2868, Document 278, 08/09/2019, 2628230, Page2/74 of 648 guarantee of reinstatement can be made. In addition, no guarantee of reinstatement can be made for a regular medical or non-family personal LOA. However, if possible, the employee will be re-employed in accordance with the following priorities: * In his or her former job if available; * In a comparable job at the same (or higher grade) if available, and if the employee is qualified for that job (at the same salary or higher) ; * In a lower grade job, if available, and if the employee is qualified for that job. If reemployed, the employee will receive the same salary as he or she received immediately prior to the LOA unless such salary exceeds the maximum salary for the employee's grade upon reemployment, in which case the employee will be paid at that grade maximum; or * If no job is available at the termination of the LOA, the employee will be placed ona preferential hiring list at the Club's sole discretion in a position for which the employee is qualified. (e) A request for an LOA is expected to be submitted to the employee's supervisor and the Human Resources Manager at least 30 days prior to the effective date of the LOA (emergencies excepted). This request should include the effective date of — the LOA, reason for the LOA and approximate date of return. For a medical or family LOA, each employee will be required to use earned vacation, personal days and sick pay benefits at the beginning of the LOA. For a personal LOA, only earned vacation will be required to be used. (£) For each employee granted a family medical or family LOA, the Club will continue the group health insurance benefit coverage under which the employee was covered as of the last day worked. However, any premiums paid by the employee prior to the LOA must continue to be paid by the employee during the LOA. Payments are due at the same time as they would be made by payroll | deduction. If an employee fails to return to work after taking a family or medical LOA, the employee may be potentially liable for payment of health MAR-A-LAGO 0220

Case 18-2868, Document 278, 08/09/2019, 2628230, Page2/75 of 648 insurance premiums paid by the employer during the LOA. (g) An employee on an LOA must notify the Human Resources Manager of intent to return at least 7 days prior to the desired return date. Medical certification of ability to resume duties must be provided to the Human Resources Manager prior to returning to work. Failure to provide medical | certification may result in disciplinary action or termination. (h) An employee must contact the Human Resources Manager with a request for an LOA extension at least 14 days in advance of the scheduled return (emergencies excepted). Medical certification is required prior to the beginning of the extension for a medical LOA. (i) The Human Resources Manager will notify the appropriate Manager of the date of return of an employee returning from an approved LOA. (j) If an employee fails to return to work at the conclusion of an LOA, the LOA will be cancelled and employment will be discontinued as a voluntary termination with the effective date of termination the last day actually worked. (k) An employee requiring a medical or personal LOA who has not completed the initial probation period is not eligible for such a LOA and must terminate his/her employment. These employees may be ~ eligible for conversion of group medical insurance. At the Club's option this category of employee may be placed on a preferential hiring list. (1) Abuse of an LOA may result in termination of employment. (m) In any case in which a husband and wife are entitled to a LOA, the total days of family LOA to which both may be entitled may be limited to 12 weeks during any rolling 12-month period if the family LOA is taken for the birth, adoption (or foster care) of a child. (n) In addition, as an alternative to the LOA, the Club and each employee may mutually agree to alternate employment for the employee for the time during which the employee would otherwise be entitled to a LOA under Club policy. Such period of alternate employment will not cause a reduction MAR-A-LAGO 0221

Case 18-2868, Document 278, 08/09/2019, 2628230, Page2/6 of 648 in the period of the LOA to which the Club employee is otherwise entitled for their own serious illness. (o) The rolling 12-month period in which the 12 weeks of LOA entitlement occurs is a "rolling" 12-month period measured backwards from the date an employee uses a family or medical LOA. Exception Approval: Questions concerning this policy should be directed to the Human Resources Manager. GRIEVANCE PROCEDURE The Club recognizes that employees may have questions or problems concerning the Club's policies and procedures. In order to encourage employees to voice these concerns and try to solve the questions or problems that may arise, we have a formal problem solving procedure. Please follow these steps: Step 1: You should first request to meet with your immediate supervisor (the person you report to directly). The supervisor will listen and investigate the problem with the intention of finding an agreeable solution for those concerned. In order to facilitate a fair and timely solution, you must contact your supervisor within three days MAR-A-LAGO 0222

Case 18-2868, Document 278, 08/09/2019, 2628230, Page2/7 of 648 of the occurrence that created the question or problem. If you feel the problem is with your immediate supervisor, you may skip step 1 and start the grievance procedure with Step 2. Step 2: Request to meet with your Department Head. Your Department Head will review the problem (including any action taken by your immediate supervisor) and any other relevant facts involved in order to suggest a reasonable solution. In order to facilitate a fair and timely solution, you must contact your Department Head within three days of the occurrence that created the question or problem (if you skipped Step 1) or within two days of your supervisor's resolution (if you followed Step 1. If you are not satisfied with your Department Head's handling of the problem, you may proceed to Step 3. Step 3: Request to meet with the Managing Director, ora designated representative, will thoroughly investigate the problem, review Club policies, procedures, rules and regulations and will make a determination. In order to facilitate a fair and timely solution, you must contact the Managing Director within two days of your Department Head’s determination. The Managing Director, or his or her designee, may review the matter and offer a final decision. Time spent by an employee in discussing a complaint with management during normal working hours will be considered hours worked for pay purposes. When two or more employees have a common or similar complaint, the employees may select a spokesperson to represent the group. The final decision on the complaint submitted by several employees through a spokesperson will be binding on all members of the group. | If at any time you feel uncomfortable with this process, as it is outlined here, please feel free to contact the Managing Director to assist you before taking further action. Due to the serious nature of sexual harassment, such complaints should be referred immediately and directly to the Managing Director and Human Resources Manager. MAR-A-LAGO 0223

Case 18-2868, Document 278, 08/09/2019, 2628230, Page278 of 648 The Club will not tolerate any form of retaliation against employees who have used the Club's problem solving procedure. In the interest of creating a positive and enjoyable work environment, all employees shall be able to use this procedure without fear of retaliation. However, it is equally important to realize that the problem | solving procedure will not prevent the Club from taking disciplinary action, up to and including termination, against any individual under circumstances where the Club deems disciplinary action to be appropriate. MAR-A-LAGO 0224

‘Case 18-2868, Document 278, 08/09/2019, 2628230, Page279 of 648 © DISCIPLINARY ACTION A. GENERAL POLICY ADHERENCE Policies and procedures are necessary guidelines to provide a basis for fair and equitable treatment of each employee. In addition, these guidelines serve as the basis for a fair relationship between the employee and the Club. It is necessary that these guidelines be applied consistently to each employee regardless of location, department or manager. Then, and only then, can the Club establish the confidence that each employee will be treated consistently according to the administrative and operational guidelines. It is the responsibility of each officer, manager, supervisor and employee to contribute fully toward the achievement of this objective. B. DISCIPLINARY ACTIONS Violations of any of the established policies and procedures may result in disciplinary action including probation or discharge. The nature of the disciplinary action is contingent upon the facts and circumstances of the individual situation. The following employee actions are not all inclusive but, by way Of illustration only, are some of the events which could result in discipline including discharge. Thus, your department head may establish additional rules and regulations he or she feels are necessary for the orderly fulfillment of your department's responsibilities. These also must be followed. Other actions may also result in discipline including discharge. (It should be noted that the Club and each employee recognize that the employment relationship is for an indefinite period and may be terminated by either party at will.) By providing this list, the Club in no way restricts its legal discretion to terminate employment. a. Insubordination, refusal or inability to comply with reasonable instructions of supervisors or department heads. If your supervisor requests you to do something with which you disagree, always follow the instructions at the time and then discuss it later at an appropriate time and location. However, this excludes obedience to demands constituting discrimination, sexual harassment or illegal conduct. b. Interference or hindrance with shift schedules. Failure to work on a shift as scheduled or arranging your own shift replacement without the supervisor's permission. SC. Unauthorized use of Club telephone or property and/or guest facilities. d. Entering the Club more than 30 minutes before your shift begins or leaving the Club more than 30 minutes after the end of your shift without the permission of your department head or supervisor. Entering or MAR-A-LAGO 0225

Case 18-2868, Document 278, 08/09/2019, 2628230, Page280 of 648 gos RQ presence in areas within the Club premises without authorization or just cause. Presence on Club premises at anytime other than your assigned work shift unless specifically authorized by your department head in advance. An essential element of the security procedures of the Mar-a-Lago Club is the key control process. As such, | employees who have access to Club keys must recognize the importance of properly safeguarding the keys which have been entrusted to them. All employees should be aware that they may be subject to disciplinary action for any violation of the key control procedures. Guest room keys must never be left in your locker. Theft (unauthorized removal) or misappropriation (unauthorized storage, transfer, utilization or possession) of Club services (i.e., unauthorized telephone calls, laundry/valet, food and beverage), or guest, employer or Club property, including items found on the Club premises. All articles found on Club premises must be turned into the Lost and Found area at Security in the Timekeeper's area. Altering or falsifying a guest check or credit voucher or forging tips through guest checks. Refusal to comply with Club rules, policies or procedures. Poor job performance, including unsatisfactory attitude that detracts from job performance or the efficient operation of the Club. Violation of sexual harassment policy. Failure to report for duty without a bona fide excuse and proper notification to your supervisor. Failure to comply with established safety and health rules and safe work procedures or engaging in any conduct that creates a safety hazard. Failure to meet performance standards. Failure to follow grooming and appearance standards. Failure to report a workplace accident immediately. If you are injured on the job, you must immediately report this to your supervisor or Human Resources Manager. Falsely stating claims of injury. Disorderly conduct on the Club premises, including fighting, horseplay or other action that endangers others or Club property. Offensive or disruptive behavior, including threatening employees, using abusive or vulgar language, interfering with others in the performance of their duties, or acting in an immoral or indecent manner on Club property, or while off the Club premises in performance of Club duties. Destruction, misuse, or removal of Club property, a guest's property or another employee's property. Unauthorized disclosure, discussion, removal or use of Club confidential, information, trade secrets or other MAR-A-LAGO 0226

Case 18-2868, Document 278, 08/09/2019, 2628230, Page281 of 648 proprietary information (including information contained in personnel records). | Vv. Deliberate omission or falsification of information on employment application, time sheets, production or other Club records. Ww. Unauthorized distribution of literature, posting of notices or signs on Club, premises, fundraising, selling lottery tickets or merchandise, or soliciting donations or any other type of money raising on Club premises, unless specifically authorized by the Managing Director. x. Refusal to allow security checks and package inspections. y. Reading books, magazines, or newspapers while on duty, except where required in the line of duty. Z. Loitering, loafing or sleeping on duty. aa. Neglect of duty causing defective work. bb. Smoking anywhere on club property including 124 Woodbridge Rd. and 1094 Woodbridge Rd. cc. Reporting for duty under the influence of intoxicating liquor, marijuana and/or illegal drugs. dd. Bringing, consuming, possessing, providing, selling, or otherwise using intoxicating liquors, marijuana and/or illegal drugs on Club premises. ee. Dishonesty, including but not limited to intentionally not providing full and truthful information when requested by management. f£. Gambling on Club premises. gg. Bringing, discharging, and/or possessing unauthorized firearms or other weapons on Club property or while off Club Property in the performance of Club duties. hh. Giving or taking a bribe of any nature. ii. Being arrested and/or convicted of any crime which the Club believes is detrimental to the Club and/or its other employees. Jj. Theft, attempted theft, removal or unauthorized possession of the Club's property or property of other employees or customers. kk. Misappropriation of Club funds or failure to handle | funds in accordance with Club guidelines. li. Irregular attendance including excessive absenteeism, tardiness and/or unexcused absences. mm. Leaving work station or work without authorization or being in an unauthorized work area during your scheduled work period or on your days off, without your supervisor's specific authorization. nn. Interfering with or hindering of work schedules; failing to work on a scheduled shift; or arranging your own replacement on a shift without permission from a supervisor. 00. Failure to report to work after the expiration of a leave-of-absence or layoff. pp. Defrauding customers of the Club. qq. Embezzlement. MAR-A-LAGO 0227

Case 18-2868, Document 278, 08/09/2019, 2628230, Page282 of 648 rr. Disloyalty to the Club, including but not limited to, slandering the Club, or acting in such a manner that could damage the Club's reputation. ss. Moral turpitude. tt. Failure to wear assigned uniform. uu. Entering or leaving the property through any entrance or exit other than the designated employee entrance or exit. Punching in/out with another employee's I.D. Card or allowing another employee to punch in/out on your card. Unauthorized attendance at guest functions and/or in guest areas, or on the premises including guest rooms, dining rooms and lounges. No unauthorized social contact will be permitted at any time with Club guests. Discourteous or inappropriate conduct with guests/members. yy. Using guest elevators, escalators, restrooms or any guest facility except when specifically required by job functions or authorized by management. zz. Gum chewing, eating or drinking in any public area of the Club. aaa. Soliciting gratuities from guests or commenting on the amount of a gratuity. ; : , MAR-A-LAGO 0228

Case 18-2868, Document 278, 08/09/2019, 2628230, Page283 of 648 UNIFORMS AND PERSONAL APPEARANCE A. UNIFORMS Employees issued a uniform are responsible for turning their soiled uniform to the Laundry Department at the end of their shift and picking up a clean one for the next day of work. All employee uniforms are laundered by the Club at no charge to the employee. B. PERSONAL APPEARANCE Departure from conventional Club attire or personal grooming are not permitted, regardless of the nature of the job performed. (1) Every employee has some contact with the public and therefore represents the Club in appearance as well as by actions. The properly attired employee helps to create a favorable image for the Club. Accordingly, personal appearance shall be governed by the following standards: Good hygiene and grooming practices are required. A daily bath or shower is a necessity and all employees should report to work freshly bathed. Keep in mind you may be going from a hot kitchen to an air conditioned guest room. Body temperatures will change quickly and body odors are offensive. Remember, there is no substitute for good deodorant. Bad breath is also offensive and mouthwash should be used in addition to brushing teeth. Good hygiene and grooming practices are required. Fingernails, and hair must be clean and neatly trimmed at all times. Beards,goatees, and un-trimmed sideburns are not permitted. Mustaches must be neatly trimmed. Men's hair should not exceed collar length and must be conservatively styled. Visible body piercing is not permitted for men or women, nor ear jewelry for men. Hair must be neatly arranged and kept from covering eyes, and must be covered or restrained where required by health code. All employees must wear their nametags (to be provided) at all times while on duty. MAR-A-LAGO 0229

Case 18-2868, Document 278, 08/09/2019, 2628230, Page284 of 648 All employees are expected to report to work in clean, neatly pressed clothing, clean shoes and clean personal appearance. Female employees who are not required to wear a uniform may wear suits, dresses, skirts or slacks with blouses or sweaters. ‘‘Mini’’ skirts are not permissible. No blue jeans or jeans of any color are permitted. Denim outfits resembling blue jeans and jean skirts are also unacceptable. No strapless or backless garmets may be worn. Females must wear the proper undergarments, including a bra and a full or half slip where necessary, depending on the sheerness of the outer garment. Hose are required with skirts and dresses. Hose or socks are required with pants. Jewelry: For safety reasons, jewelry should be kept to a minimum. Acceptable jewelry for service employees is a wrist watch and a total of three | rings. Female service employees are allowed to wear one pair of small earrings (no larger than a dime). Non guest contact female employees are allowed to wear a maximum of two earrings in each ear. Tattoos: Exposed tatoos are not allowed on any public contact employees. FULL TIME YEAR ROUND EMPLOYEES - During the summer months when the Club is closed and there is no public contact you may see your Department Head as to ‘what is considered to be proper attire for your position. (2) Supervisors have the responsibility to decide when an employee's appearance is unacceptable. In the event of an unacceptable appearance, the Supervisor may request that the employee return home to change or take an appropriate corrective action. The employee generally shall not be compensated for any such time away from work, and repeated violations of this Policy will be cause for disciplinary action. MAR-A-LAGO 0230

Case 18-2868, Document 278, 08/09/2019, 2628230, Page285 of 648 AIDS POLICY The Club recognizes that Acquired Immune Deficiency Syndrome (AIDS), its related conditions such as AIDS Related Complex (ARC), and persons with seropositive test results pose significant and delicate issues for employees in the workplace. Accordingly, we have established the following guidelines for handling employee issues that arise when an employee is affected by this disease. (1) The Club is committed to maintaining a safe and healthy work environment for all employees. (2) Consistent with this commitment, the Club will treat AIDS the same as other illnesses in terms of all our employee policies and benefits, such as group health and disability benefits. (3) Based on the overwhelming preponderance of available medical and scientific opinion, including statements from the U.S. Public Health Service, Centers for Disease Control, there is no evidence that the AIDS virus is casually transmitted in ordinary social or occupational settings or conditions. Therefore, subject to changes in available medical information, it is the policy of the Club that employees with AIDS or any of its related conditions may continue to work and the Club will provide them with reasonable accommodation as long as they are medically able to perform the duties of their position. (4) Employees who are affected by AIDS or any other life-threatening illness will be treated with compassion and understanding in dealing with their personal crises. Co-workers will be expected to not refuse to work or withhold their services for fear of contracting AIDS by working with an AIDS affected person, and to not harass or otherwise discriminate against an AIDS-affected employee. (5) Recognizing the need for all employees to be able to be accurately informed about AIDS, upon request, the Club will make every effort to have information available regarding the facts about this disease, how it is transmitted and not transmitted and how best to contain it from spreading. Employees affected by AIDS or any of its related conditions or concerned about AIDS are encouraged to contact Human Resources Manager to discuss their concerns and to obtain additional information. (6) The Club will treat all medical information obtained from employees with AIDS or any of its related conditions confidentially as required by law. The Club reserves the right to change this policy or make appropriate revisions, additions, amendments or corrections. We will notify you of any substantive changes. MAR-A-LAGO 0231

Case 18-2868, Document 278, 08/09/2019, 2628230, Page286 of 648 If you have any questions about this policy or its interpretation or the information upon which it is based, please contact the Human Resources Manager. MAR-A-LAGO 0232

Case 18-2868, Document 278, 08/09/2019, 2628230, Page287 of 648 SUBSTANCE ABUSE POLICY Our Club strives to provide a safe work environment and encourages personal health. In regard to this, the Club considers the abuse of drugs or alcohol on the job to be an unsafe and counterproductive work practice. Quite simply, our goal is to maintain a work environment that is free from the effects of alcohol and drug abuse. While the Club has no intention of intruding into the private lives of its employees, the Club does expect employees to report for work in condition to perform their duties. It is, therefore, Club policy that an employee found with the presence of alcohol or illegal drugs in his/her system, in possession of, using, selling, trading, or offering for sale illegal drugs or alcohol during working hours, may be subject to disciplinary action up to and including discharge. (Club sponsored activities which may include the service of alcoholic beverages are not included in this provision.) Substance Abuse includes possession, use, purchase or sale of drugs or alcohol on Club premises. It also includes reporting to work under the influence of drugs or alcohol. Prescription drugs-prescribed by the employee's physician may be taken during work hours. The employee should notify the Supervisor if the use of-properly prescribed prescription drugs will affect the employee's work performance. Abuse of prescription drugs will not be tolerated. An employee reporting for work visibly impaired is unable to properly perform required duties and will not be allowed to work. MAR-A-LAGO 0233

Case 18-2868, Document 278, 08/09/2019, 2628230, Page288 of 648 POLICY ON SMOKING Smoking is prohibited by any staff employee of The Mar-aLago Club on any and all properties adjacent to or that of The Mar-a-Lago Club to include: 124 Woodbridge Road Palm Beach, FL 1094 Woodbridge Road Palm Beach, FL MAR-A-LAGO 0234

Case 18-2868, Document 278, 08/09/2019, 2628230, Page289 of 648 DRUG/ALCOHOL USE AND TESTING The Mar-a-Lago Club recognizes that employee drug abuse interferes with the Club’s level of production, as well as its competitive position in the marketplace, and can result in costs, delays, and tragedies associated with work-related accidents. As a condition to employment or continued employment, you must refrain from reporting to work or working with the presence of drugs or alcohol in your body. To address the problem of drug/alcohol abuse and to comply with Florida’s Workers’ Compensation Drug-Free Workplace Act (the Act) The Mar-a-Lago Club adopts the policies and procedures detailed below. This policy will be administered in accordance with all relevant laws (state and local), including the ADA, the Florida Civil Rights Act, the Workers’ Compensation Act, and in a nondiscriminatory fashion. To protect the health, safety, and welfare of all Mar-a-Lago Club employees, it is the Club’s policy that the unlawful manufacture, distribution, dispensation, possession, or use of controlled substance on any Club property is absolutely prohibited. Controlled substances include, but are not limited to, amphetamines, barbiturates, cocaine, heroin, morphine, PCP, marijuana, hashish, and any other controlled substance listed in Schedules I through V of Section 202 of the Controlled Substance Act, 21 U.S.C. € 812 or in the Florida Statute on controlled substances, except for medication prescribed by the employee’s physician. You are also prohibited from drinking alcohol during the business day. You are also prohibited from bringing alcoholic beverages onto the Club premises. Special care shall be taken during Company-sponsored social events for employees. In these cases, employees and guests below the legal age will not be allowed to drink alcoholic beverages. The amount of time alcohol is served will be limited as well as the quantity of the alcohol. If necessary, transportation will be arranged for someone if his or her driving ability seems to be impaired. The Mar-a-Lago Club will test for the presence of drugs under the following circumstances: 1) pre-employment testing, 2) reasonable suspicion testing (including post-accident incidents), and 3) follow-up testing. Such testing will be done in accordance with the Worker’s Compensation Drug Testing Program, which policy had been given to all employees or can be obtained from the Human Resources Manager. Refusal to submit to the test or having a confirmed, positive test result will result in immediate discipline, including termination. Any questions about this policy should be referred to the Human Resources Manager. MAR-A-LAGO 0235

Case 18-2868, Document 278, 08/09/2019, 2628230, Page290 of 648 Any violation of The Mar-a-Lago Club’‘s Drug/Alcohol Free Workplace Policy will result in appropriate discipline, up to and including termination. THIS POLICY REPRESENTS THE MAR-A-LAGO CLUB’S CURRENT POLICY FOR DEALING WITH A SERIOUS NATIONAL PROBLEM WHICH POSES A SAFETY THREAT TO THE WORKFORCE. THIS POLICY MAY BE CHANGED BY THE MARA-LAGO CLUB IN ITS DISCRETION. THIS POLICY IS NOT INTENDED TO CREATE A CONTRACT BETWEEN THE MAR-A-LAGO CLUB AND ANY EMPLOYEE. NOTHING IN THIS POLICY CHANGES THE CLUB’S ABILITY TO TERMINATE AN EMPLOYEE AT WILL, WITH OR WITHOUT CAUSE OR NOTICE. MISCELLANEOUS A. STAFF CAFETERIA For the purpose of control, the Cafeteria must remain for use of Club employees only. Any exceptions to this rule must be cleared by your department head in advance. In addition, all employees must adhere to the rules posted in the Cafeteria concerning its use. You are entitled to one meal per eight hour shift only. B. LOCKERS Those employees issued lockers are obligated to keep them clean and use them for storage of a change of clothing only. Lockers are not the areas for storage of valuables. Lockers are subject to inspection by management. Unauthorized materials such as alcoholic beverages, weapons, Club property and illegal drugs are prohibited. The Mar-a-Lago Club is not responsible for lost or stolen property. MAR-A-LAGO 0236

Case 18-2868, Document 278, 08/09/2019, 2628230, Page291 of 648 Cc; PHONES Employees on duty are not allowed to use the public phones in the lobbies or any guest areas. Phones are furnished outside the staff dining room for employee use. D. LOST AND FOUND ARTICLES You must turn in lost and found articles to your supervisor, the Security Department or a security officer at Post One. E. GIFTS Gifts from guests of the Club of a value exceeding $25.00 are not to be accepted by employees of The Mar-a Lago Club unless approved in writing by the Department Head. No employee shall accept any gift from any vendor. F. ‘*‘RIGHT TO KNOW STATION, The Occupational Safety Hazard Administration requires all employees be provided with information of all potentially hazardous substances used in the course of our daily business. The location of these documents (Material Safety Data Sheets) is in the staff dining room on the wall adjoining the Food and Beverage office. | G. EMPLOYEE ENTRANCE AND EXIT All employees required to log in and log out their daily time must enter and exit the building through the entrance on the east side of the house leading to Post One. MAR-A-LAGO 0237

Case 18-2868, Document 278, 08/09/2019, 2628230, Page292 of 648 TERMINATION PROCEDURES Clearance Process a. Clearance of locker. b. Return of uniform to Laundry. Ci. Nametag, locker key, any property keys, and uniform returned to Executive Office. d. Any outstanding accounts settled. NOTE: If you abandon your job without notice, your final paycheck will not be mailed until you have returned to the Club and completed the clearance process. MAR-A-LAGO 0238

Case 18-2868, Document 278, 08/09/2019, 2628230, Page293 of 648 IF YOU LEAVE EMPLOYMENT RESIGNATION POLICY When an employee decides to leave for any reason, his/her supervisor and the Human Resources Manager would like the opportunity to discuss the resignation before final action is taken. The Mar-a-Lago Club often finds during such a conversation that another alternative may be better. If, however, after full consideration the employee decides to leave, it is expected that the employee will provide the Club with a written two-week advance notice period (bear in mind that vacation days or personal days may not be included in the twoweek notice period). Generally, in order to qualify for payment of earned unused vacation, the employee must work throughout the notice period. If, as sometimes hapens, the employee’s supervisor believes it advisable for the employee to leave prior to the end of the employee’s two-weeks notice, the employee may be paid for the remainder of that period. Note: You are not entitled to be paid for any unused, accrued sick time. DISMISSALS Every Mar-a-Lago employee has the status of ‘‘employee-at-will’’, meaning that no one has a contractual right, express or implied, to remain in The Mar-a-Lago Club’s employ. The Club may terminate an employee’s employment, or an employee may terminate his/her employment, with or without cause, and with or without notice, at any time. No supervisor or other representative of the Club (except the owner) has the authority to enter into any agreement for employment for any specified period of time, or to make any agreement contrary to the above. | IMMEDIATE DISMISSALS - MISCONDUCT Any employee whose conduct, actions or performance violates or conflicts with the Club’s policies may be terminated immediately and without warning. The following are some examples of grounds for immediate dismissal of an employee: *Breach of trust or dishonesty *Conviction of a felony *Willful violation of an established policy or rule *Falsification of Club records *Gross negligence *Insubordination *Fighting or serious breach of acceptable behavior *Violation of the Alcohol or Drug Policy MAR-A-LAGO 0239

vT Case 18-2868, Document 278, 08/09/2019, 2628230, Page294 of 648 *Theft *Violation of the Club’s Conflict of Interest/Outside Employment Policy and/or Confidentiality Policy. This listing is not exhaustive. Should the employee be covered in our group health plan, all benefits will cease on the last day of the month in which the employee’s last day of employment falls. The employee will then have the option to continue coverage in accordance with COBRA regulations. In the event that the employee is asked to leave his/her employment with The Mar-a-Lago Club due to the above misconduct, the employee will not be entitled to any earned unused vacation benefits. Also, the employee will not be entitled to be paid for any unused accrued sick time. DISMISSALS - OTHER THAN IMMEDIATE TERMINATION All employees are expected to meet the Club’s standards of work performance. Work performance encompasses many factors, including attendance, punctuality, personal conduct, job proficiency and general compliance with the Club’s policies and procedures. If an employee does not meet these standards, the Club, may, under appropriate circumstances, take corrective action, up to and including dismissal. The intent of corrective action is to formally document problems while providing the employee with a reasonable time within which to improve performance. The process is designed to encourage development by providing employees with guidance in areas that need improvement such as poor work performance, attendance problems, personal conduct, general compliance with the Club’s policies and procedures and/or other disciplinary problems. Supervisors should use the procedure described below except in those cases which may require an employee’s immediate termination. WRITTEN WARNINGS: The supervisor should discuss the problem and present a written warning to the employee. This should clearly identify the problem and outline a course of corrective action within a specific time frame. The employee should clearly understand both the corrective action and the consequence (i.e., termination) if the problem is not corrected or recurs. The employee should acknowledge receipt of the warning and include any additional comments of their own before signing it. A record of the discussion and the employee’s comments should be placed in the employee’s personnel file. , MAR-A-LAGO 0240

Case 18-2868, Document 278, 08/09/2019, 2628230, Page295 of 648 POST RESIGNATION/TERMINATION PROCEDURES The Human Resources Manager is responsible for scheduling an exit interview with a terminating employee on the employee’s last day of employment and for arranging the return of Club property including: Club issued credit card Club manuals Office keys Beeper Two-way radio Any additional club-owned or issued property AUP WD? In order to receive a disbursement of any amounts due from the Retirement Plan, the employee is required to complete and sign a distribution form which can be obtained from the Human Resources Manager. Specific information will be provided at the exit interview. Employees may choose the continuation of medical benefits under COBRA. Specific information will be provided by the Human Resources Manager at the exit interview. Benefits (Life and Medical) end on the last day of the month in which the employee’s last day of employment falls. An employee has the option to continue Medical Benefits in accordance with The Consolidated Omnibus Budget Reconciliation Act (‘‘COBRA’’ ) regulations. | Employees leaving the Club must return office keys, club credit cards, etc., before their final paycheck can be issed. This final paycheck will be mailed during the next normal pay period. If there are unpaid obligations to the Club, the final paycheck will reflect the appropriate deductions. VACATION PAY Vacation pay is calculated in accordance with our vacation policy. If the employee took more vacation days than he/she was entitled to under the vacation policy, the time will be deducted from the employees final paycheck. RETIREMENT PLAN If an employee is in the retirement plan, information regarding this plan will be provided at the exit interview. MAR-A-LAGO 0241

Case 18-2868, Document 278, 08/09/2019, 2628230, Page296 of 648 EMPLOYEE HANDBOOK RECEIPT INSTRUCTIONS: PLEASE READ THIS PERSONNEL POLICIES AND PROCEDURES EMPLOYEE HANDBOOK CAREFULLY. IF YOU DO NOT UNDERSTAND ANY PORTION OF IT, ASK FOR AN EXPLANATION FROM THE CLUB MANAGER'S OFFICE. RETURN THIS SIGNED RECEIPT TO THE CLUB MANAGER'S OFFICE IMMEDIATELY AFTER YOU HAVE RECEIVED THIS MANUAL. PLEASE KEEP THE HANDBOOK FOR FUTURE REFERENCE. I received the Policy Manual of The Mar-ALago Club, L.C. on the date indicated below. I will carefully read the policies, procedures, and other information contained in the Manual and will ask the Club Manager's office for an explanation if I do not fully understand them. I agree as a condition of my employment to comply with the policies and procedures which exist now or which may come into existence in the future. I understand that if I do not comply with the policies and procedures, I may be subject to disciplinary action. I also understand that I or the Club may terminate employment at any time, for any reason. The Club reserves the right to modify or terminate any policies or procedures, in whole or in part, at any time, with or without notice. I understand that only the Managing Director is authorized to set policy or make any promises with respect to my employment. The language used in this Handbook is not intended to create, nor is it to be construed to constitute, a contract between the Club and any one or all of its employees. Date Employee's Name MAR-A-LAGO 0242

Case 18-2868, Document 278, 08/09/2019, 2628230, Page297 of 648 Employee's Signature 159816 MAR-A-LAGO 0243

Case 18-2868, Document 278, 08/09/2019, 2628230, Page298 of 648 EXHIBIT V

Case 18-2868, Document 278, 08/09/2019, 2628230, Page299 of 648 Vicki Yawnick: Please run the following this Saturday October 14 and Sunday October 15: THE MAR-A-LAGO CLUB Private Club in Palm Beach now seeking qualified individuals for the following seasonal positions: *Wait Staff * Asst. Food Server *Banquet Servers *P.M Sous Chef * Asst. Banquet Chef *Line Cooks *Pastry Cooks *Steward *Dishwashers *Housekeepers- | 1pm-3am *Houseperson — | 1 pm-3am *Valet — must have a clean driving record. *Salon Asst. *Nail Technician | *Make-Up Artist — Part Time *License Massage Therapist-must have experience in wet treatments. *Ksthetician *Spa Attendants — College students encourage to apply. Call Carol Ash, M-F, 9am-5pm, (561) 833-8767, ext. 313 or fax resume to (561) 832-2194. Drug/Smoke Free Workplace. EOE matin | epee MAR-A-LAGO 0086

Case 18-2868, Document 278, 08/09/2019, 2628230, Page300 of 648 EXHIBIT W

Case 18-2868, Document 278, 08/09/2019, 2628230, Page301 of 648 é awe _, -_ — Be Ple rat Seb MENT PRE-EMS_SYMENS QUESTIONNAIRE ~ _* s . - . ee ee ‘ ~~ PHONE tyr, PG ie 919 LS TT A Se Eee Me See: a EMPLOYMENT DESIRED | POSITION j DATE YOU CAN STAR | SALARY DESIREO f ia ¢ 7) 3 ; aa } Pa . a 2 iO ri . t f | ecePhorl /aonimad he Lo Rama: 2 | ——in.scpiands : Xt VES ARE YOU —7 ro einem YES | To | IF SO, MAY WE INQUIRE EMPLOYED? hb _ | OF YOUR PRESENT EMPLOYER? ENO EVER APPLIED TO 38 THIS COMPANY BEFORE? : Vo OF ed EDUCATION History een 4 LOCATION OF SCHOOL tare | GRAMMAR SCHOOL | | HIGH SCHOOL | Se ee | Tete t hte SUBJECTS STUDIED { ( fl | f aK : Y ot 6 eee = Serene emer Sante fr a ——— a ree wren com re a TRADE, BUSINESS OR | Ma ioe Na — A oh 3} | i * > SOLLEGE | | Diy Ries ] CORRESPONDENCE | | SCROOL GENERAL INFORMATION SUBJEC “S OF = SPECIAL STUCY: RESEARCH WORK OR SPECIAL TRAINING/SK.LLS WAeNS. Orman pees Lire: \ in nD _ i a en — \ ent nsec Te cA tir < SSO | AX Wine Ene. "Bask Chinse leas ONIN Greener U.S. MILITARY CR rosy Chere canine otaes iy NAVAL SERVICE —_—< REASON FOR LEAVING 4 _ xy TY “Cs Ny PCy ‘ he ee i ! es Ph NS y\OTe (v Las FOLLAS A Vv VAL Ver wee Cy ; | FROM Q } “7 f 2 Yet :; — b 4 ~ -_ ; yoicd aw \ C os Cy Com MUSE OTK aE Ye toy (V } sonal — sh £949 PT Ot Y A fy. J WVGSN ia C NOC \ Ov \Qe ) re 5 a ee ~ on os s r ir ; Ss wy v \ 4 ro oT. ~ em \ . od Caretakai-| Lom L&r co $> a c ONJINUED ON OTHER SIDE ams 9661 r Ea APPLICATION FOR EMPLOYMENT ~ aie 4 CONADENTIAL AGREN BLANDO REPORTING

Case 18-2868, Document 278, 08/09/2019, 2628230, Page302 of 648 REFERENCES GIVE BELOW THE NAMES OF THREE PEASCNS NOT AELATED TO YOU, WHOM YOU HAVE KNOWN AT LEAST ONE YEAR | NAME ; ADDRESS BUSINESS | NO a ‘\ Aas 3 aie “ , Buatroa-a Sang oe) tong | ; 4 ij ‘ me . ~ ae a » 1 = | orn Velo | od Aero J eset ATV CILLA AC a” ch > | OSs | f 2 AUTHORIZATION ~» “! certify that tne tacts contained in this application are true and complete to the best of my knowledge and ur derstand that. if empioyed, falsified statements on this application shall be grounds for dismissal. . | authorize investigation of al! statements contained herein and the references and employers listed above fo give you any and all information concerning my previous employment and any pertinent information they may have, personal or otherwise. and release the company from al: liability for any damage that may result from utilization of such information. also understand and agree that no representative of the company has any authority to enter into any agreement for employment for any specitied period of time, or to make any agreemen! contrary to the foregoing. unless it is in writing and signed by an authorized company representative. Tis waiver does not permit the release or use of disability-related or medical information in a manner pronib.ted by the Americans with Disabilities Act (ADA) and other relevant eral and state laws." DATE.) “sdba. OQ | SIGNATURE -* ya rr ey ele y | ° INTERVIEWED BY DATE ee To tS waco DO NOT WRITE BELOW THIS LINE REMARKS a \} Ye oe et | Lf WAN OW Cr TNT yore ry - ¢ nN . Ya sh ~. “e\D ale ce E> fy) GifNEe FE Oe Ay Gkstce, | , im Phedonce ieee... oo Ghee AN EE Fale to ottim OEE Ser ONE RE eee Ys pe oe LY ; ! we C1 _Civps> - sce eae o CX ' * ( \\ ut) ims i \. | NEATNESS | CHARACTER | | PERSONALITY ABILITY | i i / MIRED —TEOR “JPOSITION [WAL a ‘REPORT WAGES DEPT. APPROVED: 1. ee EMPLOYMENT MANAGES DEPAS” NENT HEAD em i GENERAL MANAGER T-\> apphcavon for employment it sold only for general use throughout the Uniteo States Adarns assumes no Tasponsiouity and “ercby disclaims any danitity for the mchusion in this ‘ora of any Guastions or requests for information upos wnich a violation of local. state and/or federal aw May be based. 1 is the user's responsibility to er-sure wnat this form's use con. es itt applicable laws, which change [rom time to time. GIUFFRE009202 CONFIDENTIAL ee a ny wetter te

Case 18-2868, Document 278, 08/09/2019, 2628230, Page303 of 648 Monday, November 7, 2016 1Quicken Data - All Accounts -~QuickReport by Description Date = —_—s Account 4/22/02 Courtyard Animal Hospital 9/6/02 Courtyard Animal Hospital 5/6/02 Courtyard Animal Hospital 5/20/02 Courtyard Animal Hospital 6/4/02 Courtyard Animal Hospital Total 8/12/69 - 1/29/03 Total inflows Total Outflows Net Total 8/12/69 through 1/29/03 Num — Payee Memo 1500 Virginia Roberts 1522 VOiDvirginia Roberts 1523 Virginia Roberts 1541 Virginia Roberts 1555 Virginia Roberts Page: 1 | Category Clr split R R split R split R split R GIUFFRE009203 CONFIDENTIAL 9S gy ALIN AN tN sg et DOD ee EEE ttle ene Le att notte vee oats

| Case 18-2868, Document 278, 08/09/2019, 2628230, Page304 of 648 Moriday, November 7, 2016 | | . | eae > | 1 Quicken Data - All Accounts _ | . —— QuickReport by Description 8/12/69 through 1/29/03 oe Amount -407.68 0.00 -380.35 -325.16 -156.08 “1,269.27 0.00 -1,269.27 -1,269.27 GIUFFRE00S204 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page305 of 648 Monday, November 7, 2016 | | Page: 1 | ~ 1Quicken Data - All Accounts : Category Detail Report 4/1/02 through 7/1/02 Date | Account Num | Payee Memo Category Cir “Amount income/Expenses Expenses Salary 4/22/02 Courtyard Animal Hospital. 1500 Virginia Roberts Salary a -507.50 2/6/02 Courtyard Animal Hospital 1523. Virginia Roberts Salary R -472.50 9/20/02 Courtyard Animal Hospital 1541 Virginia Roberts Salary RK 399.0 9 6/4/02 Courtyard Animal Hospital 1555 Virginia Roberts _ Salary R “182.00 Total Salary | _ -1,561.7 5 Taxes: Social | 4/22/02 Courtyard Animal Hospital 1500 Virginia Roberts | Taxes:Social security R- 38.82 3/6/02 Courtyard Animal Hospital 1523 Virginia Roberts Taxes:Social. security R 36.15 5/20/02 Courtyard Animal Hospital 1541 Virginia Roberts Taxes:Social security R 30.59 6/4/02 Courtyard Animal Hospital 1555 Virginia Roberts —sy. | Taxes:Social security R 13.92 Total Social security | | | 919.48 Witholdi | 4/22/02 Courtyard Animal Hospital 1500 Virginia Roberts _ Taxes:Witholding | R 61.00 5/6/02 Courtyard Animal Hospital 1523 Virginia Roberts Taxes: Witholding R 56.00 9/20/02 Courtyard Animal Hospital 1541 Virginia Roberts _ Taxes:Witholding R 44.00 6/4/02 Courtyard Animal Hospital 1555 Virginia Roberts — Taxes:Withalding R 12.00 Total Witholding | | <6 173.00 Total Taxes 3 | a 292.48 5/6/02 Courtyard Animal Hospital 1522 VOlDvirginia Roberts | | - | | R 2 0.00 : Total Expenses - Other : | a | a | 4 0,00. Total Expenses | | | | | e 269.27 i Total Income/Expenses . os | “1,269.27 0 | : GIUFFRE009205 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page306 of 648 Jenna {Withholding | Aprii 2002 Payroll Paycheck 1 {Paycheck 2 Paycheck 3 {Total social Security Social Security Social Security Social Security Withholding Ls Social Security Social Security Withholding Monthiy Totals Social Security Withholding Total Liability GIUFFRE00S206 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page307 of 648 May 2002 Payroll Paycheck 1__ [Paycheck 2 |Paycheck 3 {Total lies Social Security Sr SU, | S$ ae $l a | | _iWithholding _ | >_< | | as S al Social Security Withholding ion Social Security GQ Social Security Jenna = {Social Security | Withholding $56. a= Social Security | | | $ | $ Withholding ; Monthiy Totals | | Social Security $ @im <2: $ que Withholding $ @ $ qe Total Liability Soe GIUFFRE009207 _ CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page308 of 648 Jenna With re : $ ae fithhoiding . ‘ _ ¢ i Salary a a . Social Security $ QA x2Same June 2002 Payroll Paycheck 1 [Paycheck 2 [Paycheck 3 =P Salary Social Security | Salary {Social Security Salary : aocial Security aon enholding Salary social Security Salary Social Security beeo | a social Security | Withholding — é Monthly Totais Salary withholding $ Sec $ Qe feu Totai Ligbility ces 182.00 | 13.92 | GIUFFRE009208 CONFIDENTIAL — ee ENED EOIN bf Ihe MeV Mentgbibire woh ee EPubby bint aap see myttet se ge ttae tetas tet

The text on this page is estimated to be only 48.73% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page309 of 648 NIA LEE ROBERTS DRWVER LICENSE CLASSE SO —_—— : ae itis ; ear +4 WAVY | F wis wy Pyy¥ Hifi Wink ‘ : : | > j > : i . ‘4 4 +. ’ oe * ’ : i } , be 5 zi a ; ‘ . =e GIUFFRE009209 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page310 of 648 C3/Z29/ZEb, =—1 3512 3053333343 BLLEN SHAPPE Pen ws ul i ‘ i a i a a & Form W-4 (2001) q a ! uP Is é il 48 3 " a g 2 g Z 8 if Q 2 : ¢ g23 a i 5 # e ge H i be $72 oft : i if ie fie its : $ 5 ; i g 9 ¥ & 5 #3 i 3 : bcs 32 : i s Persons! Alowances Worksheet (Kea> A Enter "1" for yourself 'f no one else can cigim you as a dependent . ae ee | a @ You are single and nave only one ob; or .. btu for your recerds. | B Enter “1" @ You are married, have only one job, and your spouse coes not work; or * Your wages from a second job or your spouse's wages (or the total of both) are $1,000 or less. © Enter 1" tor your spouse. Bul, you Tay choose to erter -0- if you are married and have either a working spouse or ro, more than one job. (Entering -0- may help you avoid having too little tax withheld) . 2. a a a oe 2 ae \ DB Enter number of dependents {other than your spouse or yourself you will claim on your tax retum : : Enter, “1” it you will file as heed of household on your tax retum (age conditions under Mead of hoveshold above) Ente “1” if you have at least $1,500 of child or dependent care expenses for which you pian to cisim # credit (Nota: Do not include child support payments. See Pub. 808, Child and Depencent Care Expenses, for details} @ Child Tax Credit (including additional child tax credit): « Ht your total income will be between $16,000 and $50,000 ($23,000 and $63,000 If married), enter “1” for each siigible child. @ If your ictal income will be between $50,000 ang $80,000 ($63,000 and $115,000 Hf married), enter '1” If you have two 7 eiigibie Chuidren, enter “2” 1 you Nave three or four giigidle om/icren, or enter “3" # you have five or more eligible children. -G = H Add lines A ‘trough G and ervter total here. (Note: This may ba differant fron the number of exemetions you claim on your tex eur.) OH # If you plan to tamize of claim adjustments to income and want to reduce your withholding, sae the Deduotions end Adjustments Worksheet on page 2. a For accuracy, tea ¢ if you are single, have more than one job and your combined eamings from ali jobs axcasd $35.000. or if you worksh sets are married and have a working spouse or more than one jou and the combined earnings from al! jobs exceed that apoly. $60,000, see the Two-Barnar/Two-Job Worksheet on page 2 to evoid having too little tax withheld. @ if neither of the above situations hers and enter the number from ling H on line 6 of Form W-4 beiow. emece scenes ses +e wee meets Cut here and ge Farm W-4 to your employer. Keep the tap part for your records. OO ws er eavaserersesetyes Employee’s Withholding Allowance Certificate ee auiel Neveu Geoiee » For P sy Act and Pac ork Reduction Act Notice, see page 2. 2001 1 Tye oF print your fir name and miccie initial §=—«-_ Laat Name f jas L< ‘ 6 40.0 rf i 7 ee Mote: if rraerincl dud sepereied, OF sDOUs & 6 DonveriON! alan, Cwcl ty tor City of town, state, and ZIP cod 4 @ your last name ders fam thal on your sechal seow'tty card, Motes tetis Abe. 441g check here. You muet ool 1-R00-774-1243 for a new card. P Total number of allowances you are claiming (from line H above or from the applicable worksheet on page 2) Additional amount, If any, you want withheld from each paycheck = { aim exemption fromm withholding for 2001, and | certify thal | meet both of the following conditions for exemption: [ @ Last year | had e@ right to « retund of ell Federal income tax withheld because | had no tax Hablity and , @ This year | expect @ retund of all redera income tax withheld because | expect to have no tax /iability. M you Mest both conditions, write “Exempt” here , a ee Una ole of oxcun,| arty Wet | Wr ented @ he Mumber of tNnaNing asowences Goud On is cation or lam entitled to clalm oxamo( stata. Employee’ s signature | +~aowl— Cat No. 102200 GIUFFRE009210 CONFIDENTIAL . — Rt ET mee

Case 18-2868, Document 278, 08/09/2019, 2628230, Page311 of 648 | Courtyard Animal Hospital 13860-31 Wellington Trace — _ Wellington, FL 33414 | \ (561) 784-7387 7 | Ms. Roberts (jenna), It is obvious that you have a number of personal issues going on that need your immediate attention and keep you from being able to focus on and perform the material duties of your job here at Courtyard Animal Hospital. | In the short time you have been employed here, you have missed ‘multiple days, arrived late, called in sick multiple times, The reasoning you have given has shown that you are “distracted” at minimum. Between your “engine falling out of your car, your axle breaking off which your boyfriend ‘repaired it roadside’ and your landlord tossing all your furniture and clothing out in the front yard and setting it on fire’, it is clear that you have more pressing issues in your life to focus on. You have been _ unable to perform to an acceptable standard within our company. It is because of your inability to perform your duties here, be in attendan ce when scheduled and focus on the job requirements that we are forced to terminate your employment. | | r. Pinkwasser GIUFFRE009211 CONFIDENTIAL LE NORE oe BROOM I Ee OEE fee WNL Sal ML ollie HOt i Set ah

Case 18-2868, Document 278, 08/09/2019, 2628230, Page312 of 648 EXHIBIT Xx

Case 18-2868, Document 278, 08/09/2019, 2628230, Page313 of 648 = = ee ee oe ew ow ow oe oe oe oo as oe es es ee oo os os os g6 ow we ee ew ew ie es et a St ew ee we a ee ll ee ee er ee ee ee ee Oe SO ee Ew eee ee Soe ee Date: Time: 4/25/16 8:52:02 ROYAL PALM BEACH POLICE DEPARTMENT Offense Report Page: 1 Program: — ee yO GFR ee ee ee ee ey GeE GE GEE GE SES Gee Gre fet bee ee et eee eee ee ee ee ee ek ee ee ee te ee eo a Sas Soe Se cue See fee Day Of Week Occur From Date: Dept Class .. : Sunday 6/10/01 21:00 BURGLARY - Non-Vehicle Report Date Occur To Date Street Number : Qyy CLEeYvc. x Zone/divigsion Location Type Report Officer Case Status Dt : +e 4 + ee RRRKRRRKRRRRERE C A Case Number. : Case Status. : Investigator Case Number Investigator Assignment Date: KKKKKKKKKKKKKKKKKKEEK OF PEN GE State Class .: Attmpt/Committ : Forced Entry Structure Occup: KKKKKKERKEKKKEKKKKEERE State Class Statute/Ordin kkkkkkkkk OF F BEN S E Offense #: Name #.. Name Ho Offense #: 002 Name #...: Name #.. a> KREKKKKKKKKEKE SC Case Number Clty . « Home Phone No. Race .. . Ethnic Origin KeKRKKKKRKRKRKRKRKEK Case Number Street Number City . . County . : Business Phone Birth Country Oper Lic No. : Race: « «» .«— »« *& W ee es ee se : Assault Simple | ROYAL PALM BEACH, FL 33411 Zone One (1) (No of Okee) APARTMENT / CONDO Case Status WOOD, FRANK Supervisory Emp: 8/21/01 SE MANAGEMENT INFORM 1-01-002214 Dept Class .. : EXCEPTIONALLY CLEARED Case Status Dt : KACZOR, K. ***ASSTGNMENT HISTORY*** 1-01-002214 Dept Unit KACZOR, KENNETH Supervisor 6/19/01 REPORT # Burglary - Non-Vehicle Committed Statute/Ordin : : Yes Premises Enter Unoccupied REPORT # Attmpt/Committ Weapon Type . : OFFENSE 784.03 (1A) PRIMARY RELATIO Burglary - Non-Vehicle / / 810.02 (4B) 001 (SUSP) UNKNOWN, 001 (VICT) AUSTRICH, JAMES M. Assault Simple / / 784. 03 (1A) 001 (SUSP) UNKNOWN, 001 (VICT) AUSTRICH, JAMES M. USPERECT/ ARRESTEE INFO 1-01-002214 Prompt valid in: ROYAL PALM BEACH, FL 33411 561/000-0000 Business Phone : Unknown Sex ... +. 3 Hispanic INFORMATION Last Name ..=+°: ITNESS 1-01-002214 i a ROYAL PALM BEACH, FL 33411 6/10/01 21:25 6/10/01 21:05 EXCEPTIONALLY CLEARED HUGHES, THOMAS 6/17/01 RT LT ON FERRKHKEEKKER BURGLARY - Non-Vehicle 8/21/01 DETECTIVE ROBKIN, ROBERT LEER RKKEKEKEKEEEKEKEKRKEKE 810.02 (4B) 1 QD RREKKKERKREKKEKEREEE Committed Hands/Fists/Feet N SHI PP SG #exRKKKKKKE RMATION- #1 ** UNKNOWN , 561/000-0000 Unknown Bd if KKKKKKEKKEKKKEKREREERE PERKINS JR, JOHN MARTIN PALM BEACH Home Phone No. : nS Birth Date. . : : Unknown FL United States White Sex .... . : Male CERTIFIED TO BE A TRUE COPY SHAW. SHERIFF RIC L. BRAD M 00780

Case 18-2868, Document 278, 08/09/2019, 2628230, Page314 of 648 —_ — ee eee ee oe eee ee ee ee eee ee ee eee eee ees ees eee eee eee eee ee ee ee ee a a a a a es a aS ee eS Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 2 Time: 8:52:02 Offense Report Program: CMS301L — see See sere We pee ope ope cm ogee mre peeves pee emer meee eee ee ee et ee ee ee ee a ee ee ee oe ee ee ee oe ee ee 1-01-002214 (Continued) Ethnic Origin : WHITE KREEKKKKKKKKKKK VF T CT ITM TN PFPFORMA TION - # + KKEKEKKEKREKEKEKEKRKEEEE Case Number. : 1-01-002214 Prompt valid in: AUSTRICH, JAMES MICHAEL Street Number : 3 Sy Gl i | City... . . : ROYAL PALM BEACH, FL 33411 County o : PALM BEACH Home Phone No. Business Phone : 561/000-0000 Birth Date. . : Birth Country : Unknown Oper Lic Cntry : Unknown Race... : White Sex .. . . : Male Ethnic Origin : WHITE Victim Type . : Adult RREEEKEEEK OT HE R PERSON INFORMATION — £1 ¥#¥*kKKKKE Case Number. : 1-01-002214 Last Name . . : ROBERTS, VIRGINIA L Person Type . : OTHER PERSON Street Number : 368 BENT OAK DR City ; ROYAL PALM BEACH, FL 33411 County . : PALM BEACH Home Phone No. : Business Phone : 561/714-5252 Birth Date ..: Birth Country : Unknown Oper Lic ——s : Unknown Race... : White Sex ... : Female Ethnic Origin : WHITE Height... . : 506 Weight . . © wee KEKE KKKRKKRKKKEEE NA RRA TIVE # 1 KEKKEKEKEKREREKREREKRKRERKEEEEEEE Original Report Reported By: WOOD, FRANK T. 6/10/01 Entered By.: JARRETT, DAWN M. 6/21/01 ON SUNDAY, JUNE 10, 2001 AT APPROXIMATELY 2124 HOURS, I RESPONDED TO @a Sy Gl GN, ROYAL PALM BEACH, FLORIDA IN REFERENCE TO A BATTERY COMPLAINT. UPON MY ARRIVAL I MET WITH THE VICTIM JAMES MICHAEL AUSTRICH. QJ AUSTRICH STATED THAT HIS EX-FIANCE VIRGINIA ROBERTS, WHO ALSO RESIDES AT THE ABOVE LISTED ADDRESS, BROUGHT HER FRIEND ANTHONY TO THE APARTMENT. AUSTRICH AND UNKNOWN SUSPECT ANTHONY DIDN'T GET ALONG. THE SUSPECT THEN BECAME VERBALLY ABUSIVE TO AUSTRICH. AUSTRICH THEN TOLD ANTHONY TO LEAVE THE APARTMENT. ANTHONY THEN BECAME AGITATED AND AGAIN AUSTRICH TOLD HIM TO LEAVE. AUSTRICH'S FRIEND JOHN PERKINS WAS PRESENT DURING THE ALTERCATION AND STATED IN A SWORN WRITTEN STATEMENT THAT HE ALSO TOLD ANTHONY TO LEAVE THE APARTMENT. PERKINS WAS IN FEAR THAT AUSTRICH AND ANTHONY WERE GOING TO FIGHT. ANTHONY FINALLY LEFT THE APARTMENT. AUSTRICH GOT THE APARTMENT DOOR CLOSED ANTHONY THEN REOPENED THE DOOR AND ENTERED THE APARTMENT WITHOUT AUSTRICH'S PERMISSION, AND PUNCHED AUSTRICH ON THE LEFT SIDE OF HIS FACE WITH A CLOSED FIST CAUSING MINOR SWELLING AND A LARGE RED MARK. PERKINS THEN WENT TO THE TELEPHONE AND CALLED POLICE. ANTHONY OBSERVED PERKINS ON THE TELEPHONE AND FLED THE SCENE PRIOR TO MY ARRIVAL. AUSTRICH ALSO PROVIDED ME WITH A SWORN WRITTEN STATEMENT. I ASKED AUSTRICH IF HE NEEDED MEDICAL TREATMENT? AUSTRICH VERBALLY STATED THAT HE DID NOT NEED ANY MEDICAL TREATMENT. CERTIFIED TO BE A TRUE COPY RIC L. BRADSHAW, SHERIFF GM_00781

Case 18-2868, Document 278, 08/09/2019, 2628230, Page315 of 648 cm pews cme hme pamnas nea macs Aen Satan nau OG neg mma anh enh yy pity yn oveer SAND leh DenRA sO NE uti aki mh ly, nk GUN GER Oy pes mete healt a vy oe the Meek eet ee OS UR GT ae Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 3 Time: 8:52:02 Offense Report Program: CMS3011 yewh pwns ements eee remem ree meres ieee cence Smee nkey meee pm eta DS RE ey nent ine ta ae ap ke 1-01-002214 (Continued) KKKKEKEEKRKEEEKRERKEEKREKKEEEEEE NARRATIVE te RK RERKEEKEK KER EKER ERERKEEES SUPPLEMENT Reported By: WOOD, FRANK T. 6/16/01 Entered By.: JARRETT, DAWN M. 6/21/01 SINCE 6/10/01 NUMEROUS ATTEMPTS BY TELEPHONE AND IN PERSON HAVE BEEN MADE TO GET MORE SUSPECT INFORMATION. NOR JAMES AUSTRICH, JOHN PERKINS, AND OR VIRGINIA ROBERTS HAVE BEEN AT THE RESIDENCE OR ANSWERING MY TELEPHONE MESSAGES, AT THIS TIME I WISH CLASSIFY THIS CASE AS INACTIVE DUE TO SUSPECTS LACK OF COOPERATION. KEKEKKEEKKEERERERERKEKEKEKEKEK NA RRA TIV &E fo KKK KKEEKEEKRKEERREREREKERE SUPPLEMENT Reported By: KACZOR, KENNETH A. 8/14/01 Entered By.: KACZOR, KENNETH A. 8/14/01 Reviewed By: PERVENECKI, DAVID A. 8/21/01 I have attempted contact with the victim numerous times and have been | unsuccessful. Messages left with roommates have been ignored and the victim has refused to call me regarding this case. This case is exceptionally cleared due to the victim's lack of cooperation. kok ke kK kK Kk kK kK Kk OK Kk ek Ok eK ® *® REND OF REPORT * * *¥ F**K RK KR KR RK RK OK CERTIFIED TO BE A TRUE COPY RIC L. BRADSHAW, SHERIFF GM_00782

Case 18-2868, Document 278, 08/09/2019, 2628230, Page316 of 648 EXHIBIT Y

Se Set need OETS Number . a ’ a Sh COBALT Coase AMMONITE? Oe im Pe 1 Juvenile ae . 4, Request for Capias “™N Agency ORI Number Agency Name Agency Report Number ROYAL PALM BEACH POLICE DEPARTMENT | 8,6 |-}9,9,,3,0,4,6 ws apply. | .}2. Traffic Felony =_[ ] 4, Traffic Misdemeanor | 16. Other st, First, Middle) FIGUEROA ANTHONY —_ M ——— Charge Dasenien eee POSS. WITH INTENT TO SELL POSS OF MARIJUANA OVER 20 GRAMS se Oe OSS OF DRUG PARAPHERNALIA ree POSS OF CONTROLLED SUBSTANCE Victim's Name (Last, First, Mid ee | a of Birt [CHARGES[DEF | ADMIN. dle STATE OF FLORIDA —— | Local Address (Sireat, Apt, Number) (City) (State) VICTIM Business Address (Name, Street) (zip) The undersigned certifies and swears that The Person taken into custody ,., 04 committed the below acts in my presence. Cj was observed by. confessed to admitting to the below facts, On the _19TH day of _NOVEMBER ,, 99 Ki) pom. (Specifically include facts constituting cause for arrest.) THE ROYAL PALM BEACH POLICE DEPARTMENT WITH MUTUAL AID FROM TH WORTH POLICE DEPARTMENT, PERFORMED A SEARCH WARRANT AT ae PRESENT INSIDE THE RESIDENCE WAS ANTHONY FIGUEROZ -— ? . ALL OCCUPANTS WERE READ THEIR VILRANDA RIGEH BY C ‘eR HECKLER (#115), THE SEARCH OF THIS RESIDENCE REVEALED THE FOLLOWING: INSIDE ANTHONY FIGUEROA'S BEDROOM (NORTHWEST BEDROOM) WAS APPROX 106 GRAMS OF SUSPECT MARIJUANA HIDDEN INSIDE A CAMOUFLAGE BAG, NEXT HIS BED ON THE BOTTOM SHELVE OF A BOOK RACK. THIS SUSPECT MARIJUANA WAS INDIVIDUALLY WRAPPED IN PLASTIC 12 BAGS, PACKAGE FOR SALE. LOCATED IN ANOTHER BOOK SHELVE WAS A SMALL PILL BOX WHICH ACCORDING TO ANTHONY FIGUEROA WAS "X-TASY" OR wiMDMA, WHICH IS A CONTROLLED SUBSTANCE. THROUGHOUT ANTHONY FIGUEROA'S <|BEDROOM WERE NUMEROUS USED NOS CANISTERS, A GLASS SMOKING PIPE, A BLACK BOX 4|CONTAINING CRUSHED CIGARS INTERNALS, BALLOONS FOR "HUFFING", ALONG WITH 3|POSTERS THAT CONTAINED MARIJUANA PLANTS AND DRUG REFERENCES ALSO LOCATED <|[N THE BOOK SHELVE WERE PHOTOS NEGATIVES OF ANTHONY FIGUEROA SMOKING FROM A LARGE "BONG", WHEN LAKE WORTH POLICE ENTERED .» THEY DISCOVERED ANTHONY FIGUEROA INSIDE THE COMMON BATHROOM. A SEARCH OF THIS BATHROOM BY OFC. STRONG REVEALED A PLASTIC BAG CONTAINING 16 GMS OF SUSPECT MARIJUANA HIDDEN BETWEEN TWO TOWELS IN THE CLOSET. JUVENILE REFERRAL WAS ISSUED TO THE PARENT, NOTHING FURTHER. he/ehe has just and reasonable grounds to belleve, and does believe that who told. that he/she saw the arrested person commit the below acts. rl was found to have committed the below acts, resulting from my (described) investigation. e200 am. > Fs — z Ww = i t pom v) , OCs | a i AHI DEPUTY CLERK SWORN AND SUBSCRIBED BEFORE ME NOTARY PUBLIC / CLERK OF e / POLICE OFFICER 11-19-99 NAME OF OFFICER (PLEASE PRINT) DATE 1 1 -] 9.99 PAGE por DATE 1 ort DISTRIBUTION: | WHITE - Court Copy \ GREEN -Atate Attorney YELLOW--Agency PINK-Agency GOLDENROD™ ' = Ww & < D = = QO <

“ | 318 of 648 214 Besemanta ce: 08/09/2019, 2628230, Page E AFFIDA 3. Request for Warrant 7 4. Request for Capias 1 — DS Agency Name ney Report dumber 89% | ROYAL PALM BEACH POLICE DEPARTMENT | 8,6 |+!9,91/+13,0,4,.6 as apoly, | | 2. Traffic Felony 4. Traffic Misdemeanor | 16, Other Name (Last, First, Middle Atias Race mer wiw it Charge Description Charge Description Poss. marijuana over 20 gms. Poss. with intent to sell —o Poss. of Drug Paraphernalia soa Poss. of Controlled Substance (MDMA rat, Middle) Victim's Name (Last, F : a State Of Florida Ps 5 ge 4! Local Address (Street, Apt., Number) (City) (State} (zip) Business Address (Name, Street) {City) (State) 2.N, X | The undersigned certifies and swears that ha/she hes just and reasonable grounds to believe, and does believe The Person taken into custody ... C) committed the below acts in my presence. L] was observed by who told confessed to that he/she saw the arrested person commit the below acts. admitting to the below facts. bd was found to have committed the below acts, resulting from my (described) investigation, On the dayor April 2000, xx Lam. &) P.M. (Specifically include facts constituting cause for arrest.) HERE KKKRKKK EEE ANTENDED PROBABLE CAUSE KEKEEKEKKKRKKNKHE EEK On 04-13 -00, I received from Evidence Custodian Fanelli, one pill search warrant executed on 11-19-99 on Anthony Figueroa residen pill for the presence of MDMA, using a heroin test kit. The pill test turning the color black. It should be noted that on 11-19rights, he was interviewed and admitted that the pill inside the purple case was indeed ecstasy or MDMA. This pill has a "Batman" symbol imprinted on it. This pill was placed back into evidence. Based on this information, I believe probable cause now exists for the poss. of a controlled substance (MDMA). Note, all suspect marijuana seized at . tested positive for narcotic content. inside a purple pill case seized from the ce, The purpose of this was to test this one ed positive for the presence of MDMA by 1999, after Anthony Figueroa was read his Miranda T his amended probable cause was sent to 5/A Debra Colton for charge purposes. Nothing further. PROBABLE CAUSE STATEMENT DRIDA © PALM SEACH COUNTY wy certify that the foregoing |s a SIT dT Pog ay ea ax ie KP by 6 fet a 8 ae LFS a y of a Apa : .y% law. f Bee Be Oe LO, INO NG, eae EN mC) 7 ene een SOT 7 SIC rac = + AAD N R. Bs , Sa apy ore AEC BHEPUTY 04-17-2000 _/BoNE OF OFFICER (PLEASE PRINT) DATE 04-17-2000 a DATE , 1 or + a

‘eas . Case — Document 278, .08/09/2019, 2628230, Page319 of 648 IN THE CIRCUIT COURT OF THE FIFTEENTH oi CIRCUIT IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA CRIMINAL DIVISION STATE OF FLORIDA ORI Gdh AL casewo. OO-4 93 Ce HO ISSUEWARRANT = VS. | 25 = “yi . © 5 774 we | = fog ate INFORMATION FOR: One = 1) | POSSESSION OF SCHEDULE I SUBSTANCE ee: ~*~ 24 2) | POSSESSION OF MARIJUANA IN EXCESS OF 20 GRAMS Poe 2 py 3) | POSSESSION OF PARAPHERNALIA (PRODUCTION) TB XG 5 4) POSSESSION OF PARAPHERNALIA (USE) In the Name and by Authority of the State of Florida: BARRY E. KRISCHER, State Attomey for the Fifteenth Judicial Circuit, Palm Beach County, Florida, by and through his undersigned Assistant State Attorney, charges that ANTHONY LUIS FIGUEROA on or about November 19, 1999, in the County of Palm Beach and State of Florida, was unlawfully and knowingly in actual or constructive possession of a substance classified within Schedule I, Florida Statute 893,03 (4), commonly known as MDMA, a controlled substance, contrary to Florida Statute 893.13(6)(a). (3 DEG FEL) COUNT 2: Informant aforesaid, under oath, further information makes that ANTHONY LUIS FIGUEROA on or about November 19, 1999, in the County of Palm Beach and State of Florida, was unlawfully and knowingly in actual or constructive possession of more than 20 grams of a material, compound, mixture or preparation which contained cannabis, commonly known as marijuana, a controlled substance, contrary to Florida Statute 893,13(6){a). (3 DEG FEL) COUNT 3: Informant aforesaid, under oath, further information makes that ANTHONY LUIS FIGUEROA on or about November 19, 1999, in the County of Palm Beach and State of Florida, was unlawfully and knowingly in actual or constructive possession of bags, and/or a pill box, and/or a box, which was drug paraphernalia being used, intended for use, or designed for use in planting, propogating, cultivating, growing, harvesting, manufacturing, compounding, converting, producing, processing, preparing, testing, analyzing, packaging, repackaging, storing, containing or concealing a controlled substance, contrary to Florida Statute 893. 147(1)(a). (1 DEG MISD) COUNT 4: Informant aforesaid, under oath, further information makes that ANTHONY LUIS FIGUEROA on or about November 19, 1999, in the County of Palm Beach and State of Florida, was unlawfully and knowingly in actual or constructive possession of a pipe, and/or balloons, which was drug paraphernalia being used, intended for use, or designed for use in injecting, ingesting, inhaling, or otherwise introducing into the human body a controlled substance, contrary to Florida Statute 893. )(b}. (1 DEG MIS D) DEBRA COLTUN FL. BAR NO, 0561622 Assistant State Attorney Palm Beach County, Florida SA 00CJ001567A02 GM_Q4225 /

STATE OF FLORIDA Case _— 2/78, 08/09/2019, 2628230, Page320 of 648 COUNTY OF PALM BEACH Appeared before me, DEBRA COLTUN Assistant State Attorney for Palm Beach County, Florida, personally known to me, who, being first duly sworn, says that the allegations as set forth in the foregoing information are based upon facts that have been sworn to as true, and which, if true, would constitute the offense therein charged, that this prosecution is instituted in good faith, and certifies that testimony under oath has been received from the material witness or witnesses for t Se. Assistant State Attorney | | 1h, Swom to and subscribed to before me this oN day of April; 2000. Citation Nos. (if applicable) SA 00CJO01L567A02 Lin : NOTARY PUBLIC, State of Florida a3 4 Pasharikov rn y GoAASIAB EXPIRES het, ff fs, 2e PA, My COMMIS: fei re pprit 28, 2003 a Se ~ gen TH) TROY PAIN (NBURANGE, TN STATE OF FLORIDA = PALM BEACH COUNTY | hereby certify that the foregoing is a : Ely I i tryecony of the record in my office with trol Bae rota bis Cc" as required by f gm AT Tig 3 ee 2 By DEPUTY CLERK GM_01226

Case 18-2868, Document 278, 08/09/2019, 2628230, Page321 of 648 6. IN THE CIR@#r court oF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA SENTENCE (Probation Community Control Violator) (As to Count(s} | Defendant / Case Number OBTS Number ea a a i NOV-E288+#_$_—_—_— | WILKES GucRit | ~ ry GQUR The Def t, bfing personally before this Court, accompanied by the dbfendayoranntBbehey of record , t , and having been adjudicated guilty herein, and the Court having given the Defendant an opportunity to be heard and to offer matters in mitigation of sentence, and to show cause why defendant should not be sentenced as provided by law, and no cause being shown and the Court having placed the Defendant on probation/ community control and having subsequent! revoked the Defendant’s probation/community control for violation(s) of condition(s) : IT IS THE SENTENCE OF THE COURT that: The Defendant pay a fine of $ g pursuant to § , Fla. Stat., plus $ as the 5% surcharge (of the fine imposed) required by F.S. 960-25, which shall be deposited in the Crimes Compensation Trust Fund. The Defendant is hereby committed to the custody of the [ ] Department of Corrections [ ] Sheriff of Palm Beach County, Florida for a term of yer further ordered that the Defendant shall be allowed a total of ) days as credit for time incarderated prior to imposition of this sentence. It is further ordered that the composite term of all sentences imposed for the counts specified in the order shall run [ ] consecutive to M concurrent with (check one) the following: ] Any active sentefhce being served. : [ |] Specific sentences: | In the event the above sentence is to the Department of Corrections, the Sheriff of Palm Beach County Florida is hereby ordered and directed to deliver the Defendant to the Department of Corrections together. with a copy of the Judgment and Sentence, and any other documents specified by Florida Statue. The defendant in open court was advised of right to appeal from this Sentence by filing notice of appeal within thirty days from this date with the Clerk of the Court, and the Defendant's right to the assistance of counsel in taking said appeal at. the expense.alsthes site upon showing of indigency. a seer GENS, ae DONE | hereby certify that the foregoing . ; ! Na ey J. G Bou mC ii ach County, Florida this x ay | of , 16 x fe HE ye tH pay 2 3 p ARON R. BO (rev. 12/98) 6 fri 3, COMPTROLLER ) sO DEPUTY CLERK By CIRCUIT COURT JUDGE GM_01227 QR EDWARD A. GARRISON

- Case 18-286 ocument 278, 08/09/2019, 2628230, Page322 of 648 IN THE CIRCUIT COURT OMMBME ISTH JUDICIAL CIRCUIT OF FLORIDA, IN on. PALM BEACH COUNTY Nov-29-2888 82:45 a -ose UQ937CE AOU ww W ott Serta BO— 455611 Ins DOROTHY H, WILKEN, CLERK pp COUNTY, Ft. MOUSSA ReN emi eee wie ee STATE OF FLORIDA [ ) COMMUNITY CONTROL VIOLATOR PROBATION VIOLATOR The above Defgusiant; being person ly ‘before, this Court represented by _| Crt li As Y] / | | b —___.. (attorney) CIRCUIT & COUNTY COURTS eee el a Having been tried and found guilty of the Having entered a plea of guilty to the Having entered a plea of nolo following crime(s): following crime(s): contendere to the following crime(s): | ——— —+ a [ax SE STATUTE NUMBER(S) be adjudicated guilty, IT IS ORDERED THAT the Defendant ts hereby ADJUDICATED and no cause having been shown why the Defendant should not GUILTY of the above crime(s), [} and having been convicted or found guilty of, or having entered aplea of nolo contendere or guilty, regardless of adjudication, to attempts or offenses relating lo sexual battery (ch. 794), lewd and lascivious conduct (ch. 800), or murder (s. 782.04), aggravated battery (s. 784.045), carjacking (s. 812.133), or home invasion robbery (s. 812.135), or any other offense specified in. section 943.325, the defendant shall be required to submit blood specimens. {] and good cause being shown: IT IS ORDERED THAT ADJUDICATION OF GUILT BE WITHHELD. SENTENCE STAYED { ] The Court hereby stays and withholds im position of sentence as to countfs) and places the Defendant on [] Probation and/or { } Community Control under the supervision of the Dept. of Corrections (conditions of probation set forth in separate order), SENTENCE DEFERRED [] The Court hereby defers imposition of sentence until The Defendant in Open Court was advised of his right to appeal from the Judgment by filin _ following the date sentence is imposed or probation is ordered pursuant to this adjudication. of counsel in taking said appeal at the expense of the State upon showing of indigency. RED in Open Comm at Meat iP aeatie0U Ritm Beach County, Florida, this a day of e, ( re | ALOO { hereby certify thal thw foregoing is a & notice of appeal with the Clerk of Court within thirty days The defendant was also advised of his right to the assistance a ot Per, rays 5 * CIRCUIT COURT JUDGE ‘72 | GM_01228 | By DEPUTY CLERK EDWARD A. GARRISON

Case 18-2868, Document 278, 08/09/2019, 2628230, Page323 of 648 EXHIBIT Z

Case 18-2868, Document 278, 08/09/2019, 2628230, Page324 of 648 re em RR eee cereus eee Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: Z Time: 8:51:59 Offense Report Program: CMS301L Day Of Week .: Friday Report Date .: 8/03/01 23:43 Occur From Date: 8/03/01 20:00 Occur To Date : 8/03/01 23:42 Dept Class .. : THEFT/LARCENY Street Number : HIDDEN HARBOR, Qa CILy a x - : ROYAL PALM BEACH, FL 33411 zone/divigion : Zone Two (2) (So of Okee/E thr Wil) Location Type : APARTMENT/CONDO Case Status . : OPEN / NOT ACTIVE Report Officer : LLEWELLYN, CRAIG Supervisory Emp: MURPHY, THOMAS 8/06/01 Case Status Dt : 8/03/01 kkkkkeeeeeeR CASE MANAGEMENT INFORMATION #kkRHHKKRRKES Case Number. : 1-01-003008 Dept Class .. : THEFT/LARCENY Case Status . : OPEN / NOT ACTIVE Case Status Dt : 8/03/01 RKEEKKREKEKKEEKEKKREKKEKEE O F P EN SE REPORT # L KHER EKKREKREKEKEKKREKKEEE State Class .: Larceny - From Building Attmpt/Committ : Committed Statute/Ordin : 812.014(2C1) RREKEKKEKE PROPER T Y INFORMA TI.ION # L RREKEKEEKKKEKEKREKKKEEKE Category . .. : STOLEN UCR Prop Type : CURRENCY, NOTE, ETC. OUBHELEY « « « + 5 Description . : US CURRENCY Value ... . : 500.00 Property type : CURRENCY/NEGOTIABLE KHEKKKKKKEKKKEKK GSU SPECT /ARRESTEE INFORMATION - #1 ** Case Number . : 1-01-003008 Prompt valid in: UNKNOWN, City .. + : ROYAL PALM BEACH, FL 33411 Home Phone No. : 561/000-0000 Business Phone : 561/000-0000 Race .. : Unknown Sex ... . . : Unknown Ethnic origin : Hispanic KREKEEKKKKKKKEKE VT CT IM INFORMATION - és L KERR KKKRKEKEKKEKEKEKEKEKSE Case Number . : 1-01-003008 Prompt valid in: ROBERTS, VIRGINIA L Street Number : gy a a City .. . . . : ROYAL PALM BEACH, FL 33411 County : PALM BEACH Business Phone 561/714-5252 Birth Country : Unknown Race .. . : White Ethnic Origin : WHITE ——— Weight .... : 103 Victim Type . : Juvenile RRKEKKKKE O T HE R PERS ON INFORMATION — #1 ##¥kkkKKKS Case Number. : 1-01-003008 Last Name. . : FIGUBROA, ANTHONY IL Person Type . : OTHER PERSON Street Number : @S Bi Gla City .. . . . : ROYAL PALM BEACH, FL 33411 County... : PALM BEACH a a a: Business Phone : 561/000-0000 as. : Birth Country : Unknown Oper Lic Cntry : Unknown Race... . +: White Sex .... . : Male Ethnic origin : WHITE Juvenile .. . : ADULT RARRKEKKER QO T HE R PERSON INFORMATION - # 2 ##kkkKKKS Case Number. : 1-01-003008 Last Name. . : SWITZER, KYLE M ___ CERTIFIED TO BE A TRUE COPY RIC L. BRADSHAW, SHERIFF GM_00777

Case 18-2868, Document 278, 08/09/2019, 2628230, Page325 of 648 . as ae ft —= = —— oe ow oe a ee oe ee ee ee ee See pee oe oom oom am ay st 8 tee ee ees a ee ee es Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 2 Time: 8:51:59 Offense Report Program: CMS301L ee meee ere ee eee ye eer ee em ms es es ee oe ee ae ee a oe —— we a wT ow | oe eo oe a ee oF = oe a ae a ee ee oy ee a ae a eee 1-01-003008 (Continued) Person Type . : OTHER PERSON Street Number : 9 Gi City... . . : ROYAL PALM BEACH, FL 33411 County .. . . : PALM BEACH oe ee : eee Birth Date..: f-=_/sa Birth Country : Unknown Oper Lic No. : FL United States Race .. . . : White Sex .... . : Male Ethnic Origin : WHITE RRAEEERER OT HE R PERSON INFORMATION - # 3 *¥kk*kekex Case Number . =: 1-01-003008 Last Name . . : RIGEL, DUSTIN Person Type . : OTHER PERSON street Number : 3 Hy Hl City ... . . : LOXAHATCHEE, FL 33470 County... : PALM BEACH a i. Business Phone : 561/000-0000 na .=.6hC ln eee Birth Country : Unknown Oper Lic Cntry : Unknown Race... : White Sex .... . + Male Bthnic Origin : WHITE kKkERKKRKEK O T HER PERSON INFORMATION — # 4 ®kkkKkKKKX Case Number . : 1-01-003008 Last Name . . : JEFFERSON, CRAIG Person Type . Street Number City County ‘ Business Phone Birth Country Race .. Ethnic origin KkkkKKEKKK OC T H ER PERS OWN INFORMATION = # 5 B¥®ekKKKR Case Number 1-01-003008 Last Name URVIS, SCOTT Person Type. : Street Number =: City : County ~ 4 Business Phone Birth Country Race Ethnic Origin wkeKKKKEK O T HER PERS OWN INFORMATION — #£ 6 B¥¥*#X kX Case Number. : 1-01-003008 Last Name .. : RISDEN, RICHARD ARTHUR Person Type . : OTHER PERSON Street Number : i Ss is i City o = @ 2 ROYAL PALM BEACH, FL 33411 COUnEY «4 «. x : PALM BEACH Home Phone No.. : as Business Phone : 561/000-0000 Birth Date ..: g a Birth Country : Unknown Oper Lic No. . : 3 «FL United States Race .... . ¢: White Sex ... .. : Male _. SERTIFIED TOBE A TRUE COPY RIC Lt: BRADSHAW, SHERIFF GM_00778

Case 18-2868, Document 278, 08/09/2019, 2628230, Page326 of 648 —— re ee eee ee ge ee ee eee cee i ee gee yk a ca St So Ge Ge Geet Gee Gee Ge Ge See ee Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 3 Time: 8:51:59 Offense Report Program: CMS301L V———— rm eee er ee pm ee ee ee ey ee ee ee ee a ee ee 1-01-003008 (Continued) Ethnic Origin : WHITE Height... . : 511 Weight ... . : 160 | RRKKEKKEKKREKKEKRKREEEKKEKRRREKKEEE NARRATIVE + L FRR KKEKKREKREEKKEKEEKEKRKEEKEER Original Report Reported By: LLEWELLYN, CRAIG R. 8/03/01 Entered By.: JARRETT, DAWN M. 8/16/01 ON 080301 AT 2343 HOURS I WAS DISPATCHED TO 9 GN IN REFERENCE TO A SUSPICIOUS INCIDENT. UPON ARRIVAL I MADE CONTACT WITH VIRGINIA ROBERTS AND ANTHONY FIGUEROA THE RESIDENTS OF Ss Sy Gy. V. ROBERTS STATED THAT EARLIER IN THE EVENING SHE HAD SEVERAL PEOPLE VISITING HER AND A. FIGUEORA. VV. ROBERTS STATED THAT WHILE THE PEOPLE WHERE IN HER APARTMENT, ONE OF THEM WENT INTO HER BEDROOM AND REMOVED $500.00 CASH FROM HER WALLET. V. ROBERTS STATED THAT SHE DOES NOT KNOW WHICH OF HER VISITORS TOOK THE MONEY. A. FIGUEROA STATED THAT V. ROBERTS WALLET WAS LOCATED IN A POCKET OF A SHIRT WHICH WAS INSIDE THE CLOSET OF THE MASTER BEDROOM. A. FIGUEROA STATED THAT HE SPOKE TO ALL OF THE VISITORS ABOUT THE MISSING MONEY, AND THAT NO ONE ADMITTED TO TAKING IT. V. ROBERTS AND A. FIGUEROA STATED THAT SEVERAL OF THE VISITORS HAD ALREADY LEFT PRIOR TO MY ARRIVAL, AND THAT THEY COULD NOT PROVIDE NAME OR CONTACT INFORMATION FOR THOSE THAT ALREADY LEFT. I THEN MADE CONTACT WITH THE REMAINING VISITORS RICHARD RISDEN, SCOTT ORVIS, CRAIG JEFFERSON, DUSTIN RIGEL, AND KYLE SWITZER, A RESIDENT OF §§ GJ MM. ALL INDIVIDUALS STATED THAT THEY WERE NOT RESPONSIBLE FOR TAKING THE MONEY NOR DID ANY OF THEM KNOW WHO TOOK IT. I TOOK THE NECESSARY INFORMATION FROM V. ROBERTS AND A. FIGUEROA AND PROVIDED ME WITH A VICTIM'S RIGHTS SHEET THAT CONTAINED A CASE NUMBER. NO FURTHER SUSPECT INFORMATION AT TIME OF REPORT. kk kK kK Kk kK kK OK eK RK kK Ok OK K K * REND OF REPORT * * * *& *& KK RK RK RK kK KK KK RK CERTIFIED TO BE A TRUE Copy RIC L. BRADSHAW, SHERIFF GM_00779

Case 18-2868, Document 278, 08/09/2019, 2628230, Page327 of 648 EXHIBIT AA

OQS - Viewing 4zseaSiwebes, B¢haednt 278, 08/09/2019, 2628230, Page328 of 648 Page 1 of 2 PALM BEACH COUNTY SHERIFF'S OFFICE PAGE a: CASE NO. 02075321 OFFENSE REPORT CASE NO. 02075321 DISPOSITION: ZULU DIVISION: ROAD PATROL CIVIL MATTER * * * SIGNAL CODE: 66 CRIME CODE: NON CRIME CODE: CC CODE: 9566 06/02/02 SUNDAY ZONE: A81 GRID: 3C21 DEPUTY I.D.: 6933 NAME: WIKSE JOHN ASSIST: TIME D 2148 A 2159 C 2249 OCCURRED BETWEEN DATE: 06/02/02 , 2148 HOURS AND DATE: , 0000 HOURS EXCEPTION TYPE: INCIDENT LOCATION: 13475 N 24 a APT. NO.: CITY: LOXAHATCHEE STATE: FL ZIP: 33470 NO. OFFENSES: 00 NO. OFFENDERS: 00 NO. VEHICLES STOLEN: 0 NO. PREMISES ENTERED: 0 LOCATION: NO. VICTIMS: 00 NO. ARRESTED: 0O FORCED ENTRY: 0 NAME LIST: ROLE : PHILLIP E RATCLIFFE at OTHER VIRGINIA L ROBERTS 7 SEX: F RACE: W HT: 504 WT: 108 RESIDENTIAL ADDRESS: 155 SANTIAGO st BUSINESS PHONE: 561 000-0000 OMPLATNAN AN LION 3 isU ROA ON JUNE 2, 2002 AT 2148 HOURS, I WAS DISPATCHED TO 13475 24TH COURT, NORTH, LOXAHATCHEE, FLORIDA IN REFERENCE TO A REPORT OF A CIVIL DISPUTE. UPON ARRIVAL, I MET WITH WHITE FEMALE, VIRGINIA L. ROBERTS, DATE OF BIRTH GRAND WHITE MALE, ANTHONY L. FIGUEROA, DATE OF BIRTH ae. WHO WERE STANDING AT THE END OF THE DRIVEWAY ACCESS TO THE PROPERTY. THERE WAS A PILE OF PERSONAL EFFECTS (I.E. A LAMP, CLOTHING AND OTHER en ee ee ee en ne ee a ee ee ee ee ee eee ee ee eatin eed eel CERTIFIED Tf) RE A TRUE COPY ok. EX ADSHAW, SHERIFF GM_00748 http://oqs.pbso.org/index.cfm?fa=dspCase& fromrec=1&srhta=ael31b7ae6c7f{dbd-3DE78.... 4/22/2016

OQS - Viewing dase Sungber BWOdoAMdnt 278, 08/09/2019, 2628230, Page329 of 648 Page 2 of 2 a | PALM BEACH COUNTY SHERIFF'S OFFICE _ PAGE 2 CASE NO. 02075321 OFFENSE REPORT CASE NO. 02075321 DISPOSITION: ZULU MISCELLANEOUS ITEMS) NEXT TO THEM. VIRGINIA EXPLAINED THAT THEY HAD BEEN LIVING AT THE RESIDENCE FOR APPROXIMATELY FOUR MONTHS AND THAT THEY HAD MADE AN AGREEMENT WITH THE LANDLORD TO VACANT THE PROPERTY AS OF 060102. SHE CONCLUDED BY STATING THEY HAD TRANSPORTED ONE LOADED OF THEIR BELONGINGS AND HAD RETURNED FOR THE REMAINING ITEMS WHEN THEY FOUND THEM AT THE END OF THE DRIVEWAY IN DAMAGE CONDITION. ADDITIONALLY, THEY HAD LEFT A MATTRESS THAT WAS NOW BURNING ON THE PROPERTY. I WENT OUT TO THE PROPERTY AND MADE CONTACT WITH THE LANDLORD, A WHITE MALE, PHILLIP E. RADCLIFFE, III, DATE OF BIRTH. PHILLIP STATED THAT PRIOR TO LEAVING, ANTHONY AND VIRGINIA MADE STATEMENTS SUCH AS "YOU CAN KEEP THE REST YOU BASTARD!" THIS STATEMENT AS WELL AS OTHERS WERE WITNESS BY WHITE FEMALE, LORRI M. DESPAQUA, DATE OF BIRTH QM. PHILLIP STATED THAT THERE WAS A SUBSTANTIAL AMOUNT OF TIME SINCE THEIR DEPARTURE FROM PHILLIP. HE FELT THAT THEY HAD DISCARDED THE ITEMS SO HE PLACED THEM OUT FOR TRASH PICKUP. HE ALSO STATED THAT THE MATTRESS WAS COVERED IN CAT URINE SO HE BURNED IT FOR SANITARY PURPOSES. ALL PARTIES WERE ADVISED THAT AN INFORMATION REPORT WILL BE COMPLETED IN REGARD TO THE INCIDENT AND EXPLANATION OF CIVIL REMEDIES WERE GIVEN. IT SHOULD NE NOTED THAT VIRGINIA PRIOR TO LEAVING ADVISED ME THAT SHE WOULD PROVIDE ME WITH A LIST OF DAMAGE AND/OR RUIN ITEMS AS SOON AS POSSIBLE. D/S J. WIKSE/ID 6933/TRANS: 060502/BH DICT: 060302/1418 HRS. -—e wwe ew wr Ore Or RR Or Herr er Orr err reer rrr err ee wr re re errr ewe wr re wr oO wr ee re Oe re Or Oe wr ree er err ew ee re rrr em wr err er Kr ewe Tew KNEE RR Ree Neer Rr rere ee Re rr Re ree eer er eee rr er err err ew err rr em rr Re rer er Be errr ee rrr rrr re eee Rr Re ewe ewer ee wee __GERTIFIED TO BE A TRUE COPY RIC L. BRADSHAW, SHERIFF GM_00749 http://oqs.pbso.org/index.cfm?fa=dspCase& fromrec=1 &srhta=ae131b7ae6c7fdbd-3DE78... 4/22/2016

Case 18-2868, Document 278, 08/09/2019, 2628230, Page330 of 648 EAHIBIT BB

The text on this page is estimated to be only 34.14% accurate

seth = Ma. Ln a oy wes) o|= n| a} | 4 al] of u ts Drake a oe meenda hain leks anieenihenhieaeteemn aan hanes inae Reinaaenaaenneee dates ’ hem Wh? te Pe Le } | real | “A106 9}UD YyR454 9 - Pee irni : - - eet Cnet overt : 4/0997 |, 2 ives 7 9] BSS) OFS | —e n | Eg 93 /HOL BUrQeULES §,)2}lc4 | prsMJoy JUnoUNY | aol ateg se | 20S, ool] "Te Ww > Se yey] 098 oo. AWD ” n |Qz ay ie Ts WI! — ae ; 4\eyo9ad ‘wo’ *bL ee Sig & ‘samy wzies0S os Lwnew Leg, Gent in> 77 mate ra | JT} | OO oy ml ig LO) JOcUuniN Moly aass ‘sy '> bel Wary aes />p| PSL TT aoa Mame wo on | BL SY ‘DL 981. PIII WKOS loy| HH TOT argers ‘ox eID MACY TddIap Sal mews \ ‘Loca nol yuns ‘Sse '= sy d= 2 ~ abst] Cl I IBY UOYES | TTLap | yeuony S\veurssu0puy ‘ssoanoucw ON ‘squnpoocolg ‘sysruey | wifi '

The text on this page is estimated to be only 38.36% accurate

———=—— —_——_— 5 TF] Ww pa UPA JUNO Peas) 8 cS. 4 jayoy abe ‘OrU] Gus LUC} Spy} LO @LU Aq BPE SUGUIOZEYS OU) {OLY} AUS | ae DAA ntebawo> bewnuisn) 1 ANN IAA, HITT) VelLTI OWS O\Th Gate, h-& A yectrn at nary aD fey Was! No It) G21 ————————_ ——$— —$— 8 ——— Wiper Y 2 | 3g INS , é ay |L8 ANN : : hed Cx heed !ere ton [NS] ~ OAL] : £ nz ‘s100dL9. AS ‘Sond Sola S| ANG 19d ca ! sy (wo las =e FG} I. \\2 wwe hoz WD 'sy' WPlaL <8 — AWD = — Mews | Ise wolas U8) mins \/antsctaio ‘sy ‘wa !at Ig | MGR \ hwan 035d Sy! ws los) als Jtudw' oars azaog 'sY fia ! tas| 1B) Sed MAR TLS! tS! PAT DWT pS Su we las |TOQB a = y PAE pectaryel pa cad 5 Ao hw < |LOG fy. MATEY ITT AO BAS CARY aeerna orn? ‘sw 2 v2 EWWEL oa eel SonowdDy wovgts 'WO'PL al = Xa r it = SONONADE) ODE! rogers WP OS i <\-g5 i — i £ = woseleea| | et wont nw | abso, Lo —s toe fea) | WINS] Td | PTOObN] AbSWND! S a? | siuypuiry jo | SuOwessopug ‘s4ennoury™ on | umoi4 WIRY UCITRA USD] POW Ppuv 2 61 \ --Aj050)89 NEs41y BOUIN ‘saunp390ig ‘sysemoy wes 90 jeaiay 2 eahjsedog jo Swed Oly eayeyN WRIDMY eq | | | ease teo Serato thd MNP MONS PORES TEM

The text on this page is estimated to be only 40.63% accurate

SS BT FB) GF) |\P Avs ; | —jash 1A sand wooed he | Oat AS) ag | 1 |Cé Wan hb | 4 WS/oar hee | : ae __ar eh ay |e MIDS \ “<onwolop ————— ANE Wea IOAN qhoL & Honored emudd ‘at 2IQUHIRIL G17) lon (EES DL / AG AGB ONS, £78 13 '$End< a mrityfadigo TAS holy, Wa 2 TEV MIDE SS Gees AL ALEEPZIID PLS | Grew Gebity2 ssow'wWD ‘28 ES, ; AAAS WIDE LY Cc w9 fax |S Uy sekty —— shupue jo ~"As0BayeD WEAaIV equ | ILS\\ P| 7 ~, & jepoyy pus [7 %ot ayeyy WEI y eq wo4 — ey UOIROEHUAp) yeuniy ob jRAiy @ Sinjsecag jo Syne) swowesscpug ‘Ssszennouryy ON | UmOl-f ‘seunpeaoig ‘SCUEY wos | Sonn

The text on this page is estimated to be only 38.98% accurate

ths 112 BIEG OF POY pIBMAIOy JUNOUIY jo) o6e4 JL WITHA swiioy ering !ot| UB 7 Wp IAS | | — N { drgol hay ond ee mt 1 e NOLSIE a 2 > Nethzasnt | aes Bc) “WW IN Tes ere 9) of tole XS ewer lsaoe! pray? ae ln _ AGIs | woStTW (ats ong aL |S ax: | LHR Oly al) ol) fae A> , sGurpuey] jo ~“fucGeyen pesy sequin ye — Ning? '|A® “Tt Ww) lor | ie |e wo te [HIB], a 2=|¢7B ah oe a ao Ce \ NIWVHTTZ of YI Mi nlaxl%B| & } W's DL! = B. NUE _olsta| SjusuUss40puU ‘S4soAnaueyy OR | UMOr4 ————— “seunpa lag ‘sysemay | jf) | sapyy PALIY F Gnjzedag jo spud (3 GINTVLGS Bie "@Nu) Ou8 Woy 5)y) UD ew Aq epew epuaWisieys ou Jeu) Aye9 | AW | 49 rh ma % Foi AWD] rs awa) 30s] Dee0b 5 aac AYS| ——- AOS] aeterrteowts a FL 793, Pol Sal) Aad | Sl “Gd SAL S dL Add Ba Jad) aol o¢ aw JEW VOWED UDP japOy\ pur a5 yescuiy OyEW PRY agg

The text on this page is estimated to be only 39.26% accurate

—— ————— PR? Paro | aimeubys $,10lld 3 orl oJ } | LL G9] gas | ayeq 03 12101 1} ShL9 gl: as preNue4 JUNOUry ra AQT TS iS HN jena, eOu4 zz cM WS ‘Sr S¥E Gal _o79 Ce a. C6 CG vs | W9'sr |hbS|_ a> : Ty Ihe) tu — ioroeti _ ag 77 a wo seg | grt n S3UD77003W NI49? “DE Who 490. | IE +48 a Ga of nyoiay)|®bS Z1imets220 wy Ce Meisk oo 1 WO} SI) UO OW Aq EDEN SjUBLUD}Z}S GU) /EY! Ayn | IYNOD Looe = | tet nedsy2d HW ac 5 TZN fesnotgung awry tinier ci eos (ae | LEB L if _mgugd \ "awl 'pr| V6 ———— : 7 — con) 9 In or acjm|_| Sow | __ 97 nt A l a \ Soll 490 " "| des u ¢ Ww» fog) My I aS ~— lhe / ao ‘worst Sie oda| 30> x ya | gd spor) WO PEP) Fe ES ee os by \ \ INET A NIgC> WW > tT % alls i S$ (N u y | \ | vs a Lb eee aa 4) uofor NUE] te y ys | 2 sagid Ai goy) WO ar +S be ee | & \ SUYDINEIN ENAarlop AB) | 1d! Ga | ors TAL - Al L/S i yt lp L hepa 4227090 'Agisou and Le BF AnW 7EBOLN SSW | 5 ow Ol. wou4 coo tes Se r we ; ehiayyse7 jo spuewiess opug ‘sAoAnouryy ‘CN | UMOLI — Satie th nee wey Sg a "i ee re | se 1 ‘seunpoooig ‘syawuiey rifipg | Sew

The text on this page is estimated to be only 36.28% accurate

— ————— ~~ <— € | —/; ~O a | BLS vo Pua.) junowy Bo (Ro, stiey CR : — : - = ARR JO! 11 NHS 299. L IWI'DY LI : Tv Sb WV LNA OFS SRS Ta | __ pa aaitles So ryas mnan se | Mo - . ™ yi 2S > 4 a Isto SAGE aN Sapoel ae >| : 3 hil wwe ete Vatatt /W/soE — | | a PTT Td td) “" Ar SRE Rin FY Bidar net Rte IW Ree tN ‘ yy AV Mh : reSeee eh eee a ! ' Aly €, ‘ 919) ata Myemacs Aon ular Cl lo PI ki Wapyed PACH GW ) Raa ee Yomats rane t) — — ee : eee —— — 22W NOT YD Batata Wo /or/LY 20b CINUIPS I59L, | . —_d¥wroiete gut ‘N=itdd !or 5? | a b 22wagd7gaaztatd ‘or. al | b b | A) | da-rotd vos AW OL fe bI awl = 2 i Nek — midwest, ‘=o |b I 57 "a> — ea wal = 2S P%} VY Pel <A Bids 9 (ox WHO FL] Jay rt 2.) aris “Tad HW) 3 aL if) ar [bs HWO} ADPL|SIgoLN| GbSuNd) 92 | SGuypury jo a . ““MObeeD yesoay JOqUUITPY — S}USWeSsOpUZ ‘sionnouepy ‘ON | UMory aie t x : ; > HEN UORROY QUEL] jPPOY pus | @)\, Gl FeO4np 304g 'SHsBWeYy iG | sayy eApay BY OMyredeg jo sjujog YRouy ayeyy sadder tet

The text on this page is estimated to be only 37.87% accurate

ee ee ee “"AsoBayeD 1jl&4319 fe i == ie LO’ 2 | pueMOY juno jejo} eed th -~( ct | Ait ayotay - Eeyore aN “eh | 4 Gh 3 Carson Wi rin keer) Toa MAIS oC Sth ¥1\ visa eur gen fot Qs)" Ia gatt KIG IOAN) wale ERS NG ¢ z Wy FP onan Wats hot UM? | “T ——_ ———_—$S $ a * Td AOU wy a7) 9 QD) wit)’ 7] s&s angled MAA he 95 [C40 | (norttiw fdacga Yat at a WN a tb | sowiaetda Vat atd IW larlbt ——— 15 0 FUR awe ogeg? vriat LGR earn? 726 cA iar agg Ys wh 9!= II? TP ere ae Te T1OKNFZD TS Sey Atay eg LO? 220K fv \ (AOU! Satnd nwonge GhD "WD Fey \| 4s0p 4 wn nine a Ub San ‘Wand wer? Fa 'wo'la Ph sons 31919 Wo lor|@Ak now sfurpury jo syuewssiopug ‘Sioaneweyy | Ch | UMOLd sey, VOHEURLED aie a ab"! Jequinty ‘sounpoooig ‘syawuioy | 1/5/41) Sout jenuay ww Gnyedag jo s]u]0d HRY ByOyY WRT ag

The text on this page is estimated to be only 32.53% accurate

®12q Of pejoy Puzo jUNoLY (Ol Oheg § HARPSS AIaw dd ‘or ssp] | DN (\ AWW qDEZV I AUTiI> ‘st, hS\p VWZZHY ayteos 'wo'sTICSk wad [Sb W9' OL \S\; loc net RE lay {25 Donde tin aintodta’ GANOED | ino. hb Zi A FIA? S aon “oe Led (ep rt tassios SON aoe" Star Yer Se Ch VMStny ‘saci? fy dal ned WITAA? lor Lh t S ‘ r ° IMIS GES ERSTE RS Wa oe hb va ORE, RNA AAD? A HOST ey vaya “aart STIBBAIS ute 23C ke | SUPDAISSY ¢ WA woe a wWUpon jog ore) DONE AOSD ne ‘nos 3 al} rb yt TUBES TR 3.55 FLAT AT AVIS SNM OS Lh ENY KEINE Ww eae, ‘Ar | hls} TIAA I>. 7. f PATO TOM AD "I vp r build FGA Sraaot foe |b /\ ia »*DI) Kaen! ID '> . an}s LZ |. songwy eeu sot07 9! wo og: [Eb| and ey Ite" audterro woos ath j ef ihre here |. ATU woe Liv | Spiowes.0pug ‘susAnsuey ON | UMOLY Seunpevoadg ‘SE WeYy re Oy | SSytyy jeAay B oanpredeg jo sj] UI0g “NH AN} 61 UH0j Say) UO OW Ag opel sjuSWAyYyS ey} yOLA AjIPEN | }eRoOyy ouB SYey] YRsaly

The text on this page is estimated to be only 32.70% accurate

—— —— = — us —_— LS —_t- —— Se en / a ~ pe uNeuEieS 8.10); a78q 0} FOL “puro OS 5 S.10ljel ) PRAMIOY UNOWYy "enu] Que WO Sy) Uo elu Aq eprw sjusuisyels ey; Fey) Ayuso | joy ofey Hw t esan Haw Ing/aer lb af 3 # rey et UID? Bere taier> |b] | IA A490 \ ‘Engst lounog! 30 '>r A A cad | f L Sp s Sepwsrskiw Gnd. ‘aL 1S), sUewess0puy ‘sz9AnNBUeEW : . WBYY USB UEP] JEALAY 8 Ganj 4edaqg jo S)UI0g yesauy Shuipue jo "~fAsoheyey YeRisay j5qUNN ‘soinpocoig *syimwey | wo! sen)

The text on this page is estimated to be only 38.70% accurate

p}0p00 fe TWILN3SOIANOD | t TTT Ps 2 Elbe | €) Jes Hheasl €ihIb9 chs - es lle | Ui | | yy at pr be tc 1/\ TSA i a \ sr Vy ANAT Uap | -~As06a]89 ae | | wg ayeg OF /FIOL | dat! 9 5693"0) WAIT for wo lor bb) 39 yo10td wD ‘aL LBlo AGN GW ‘290 3b wot? SoaingotwWw NID? !a HSE 9d pottisnsy maustg eos [or mach ux “Wo Imac nes ‘ws ot SLEIAAMos IS8b hd sh i I7TGAT) Ades 'ot} (Sb 2s 8b ezoun 'w9'ox\ bLb W9 /oL SL squsuressopua ‘sa@AneuRW | “ON | UMNO ‘sompeaooig ‘SyeWweYy | HOW | Sau = ee Saat - —— eeepc tip lean A PU EUERS S10 Teg ” : Pe “aNu] GUB WD] SIL) UO elu Ag epew sjueweyeys ey) EU) AAO | LAW | meu FUROLUY 10) offay we Wolot ith Tad OF? ; VA i “" i 99 hwo > ite ?,, Ig eee , YUH Jor WWD Ee: | SAATTH CON Arles DALI AAT 7S)" 90 ast A Id o IIT $0d31| 9957 v\ Sa. 190 | wt 19d gol wt LD 59$71/ MO97|PSBOLN abSUy S Way VORNRIYIUOPY yhrQuiy ow jopoyy pua Lb L RHE WOsOTYy aug

The text on this page is estimated to be only 24.57% accurate

““As0BopeD esny 932g 9} feOL DieMUOY WUNOUY wy ebeg Ly AIw ANID ‘ele LdesTDNIW SII? ‘Ss soy MST IA s9d2P2 oly aga 72% GND nA ap Le heegs Sony ype Te Bley FILOGA SG I-QM Lio\ VID ENP 'NW lynaqe? ‘9X NIN WHICH toe. {NON angw vodre9" ‘aT | Sio\ we? Dr hic wg ls lor £10} | 7 v9 '9e wy supagoy, Jistin bS ANTANE + 449 DARL b Veotcandm SINSISDO AIF T ID > S734 NEBr ' 70Ar SSI Ww Ty OLSY “SN99Ws5 ctiinanie Src~eyade Ste . Ln ( PINTogizos PAG) L>¢ar) - > isf Osa ‘ Syp A3alsS -midawanwts WunWMng2> wetdtd bw ‘ot sHuipues jo JeqLUuIY sumeutys s20jd ~ S\er ao | WS aD IK TS) gob TN. jJapayy puP Lb BL SHE) WBLOI'Y a

The text on this page is estimated to be only 36.06% accurate

ne bis Sond aD aryeu f eS] eines 03 ining, Sy a — hseL.| Q | r =29bS | : 7 ——— | — fire PUBMUOY JUNOWIY ‘ONa] @4F LO} Spy) UO ew Aq apr sjvealalels au) yeUy Ame | ae . a Hee on a . 4 a = TZ. Se A ees tea} a ee :] — fe mnelnutones i we 8 US| Td | Rob N : chee w 07 t4ssue)| |_| ad IS] ' — ce HGTAINY IS ewe) 4 ° | oy 037) petiwanens oe AQS | GWA SAE VG STS ol event e —— ia DpHo AEMLGN VOD a7 : aI 1 Sa U7. yA h 4S Ue ESOS HUE A ie hen AD a. : a et] | 39S | IY |, .~ we | ‘ TL TIZEN 7A677 “yrKes0 wD TBE EO) oO AW? Ls | — ___ FIKOTO ‘NNW DARISEOE| i AWD oa i\ -Wereta ew wd6094 ‘Or 3 | t- = atta fate onesie “gn FE TC et} ql ww) ‘sy at le i wo'arball | i dd¢ AY oe ‘| 77 wlan B27, A. oy, fr + : _ MIVODerm® NWI 7 ie — | Ww SL ae | Tle FO LES Gan LG FA TED FS N wT ov 03 | : Pl “ADO fran y719 EN OES a SJdy1) oO7l i. baie E | >: - 0-Ki-e. or 5) af | 32 : Z ee Vee ee te re re YIL| Wwo r——— Fs elo] VW NTO Nt EN ma: : 4 . —hy z..a NITITPOY ., sat = as E — yn PHKMLEPH ‘oer : | \ “a = | EW VOREIYyNUEP} 3 ; 7 yey TS ; siujpury jo DY pikemiconia *eameined woh | Saiy jeapay @ sanjsedeqg jo Siiiod sep pue’™ c “Mohayeg yeauy aTaTN ree

The text on this page is estimated to be only 30.01% accurate

' =... ~~ olryeuiis s) SIEO O} 1FIOL ' JEUBIS Sj ld > (0) e6ey ‘OMUL QUE LUO) Su) UO OU AG epEWw SwoWepeYs Bly) yay Ayyeo | \\ * ATONG Mader <A 2199 ga! De SO} Es ond7Gd 29 , Isssy3 So 0RO ontrors ees. De [49 x3! $9) | >ueoLN aan CON at he he 8 Pike palsedes NAW ‘ot 1 |onBe ' ( es} Fae AT Tey fe BGL Awl? Wp i>} Aww |= AWW ‘DL shiuipye jo syUSWORIOpUy ‘SsOANoULcW Yin UoReoyyueD) JAPON HUR “faobejeg Yeisy JOQUITLY ‘Sounpososg ‘sysewiay yeruiy SMB YEU y

The text on this page is estimated to be only 35.91% accurate

- ——— Cae == es [ie Stee pa . a So ee sn na etm mc a a ion’ reTOU NE? Siw + 1 oss 1998 wy a. ot aot S| Haag ef a: IN F199 | 20) aut POL, Ae ft ; vi page= SSS port rc Tae ) LBObN| PLSD Gt ! ec AE PEYY UO EDAD, (BOON Pus z — | ~AanGayeg yesony YOIONY SHON PRAY 1equingy 879 $0 pyeabed ‘O€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD

The text on this page is estimated to be only 41.65% accurate

Ts %) — es ses ee | ‘ FL |e "OM Gre WUO} Sy) UO OW Aq epEW sjUsweyels ely jauy Aus 5 i ~ }—8a And L eS | ed SN | | =the | te: hs aes 1 SS ee ee ee ee Ad (a li Some | Ee wanes “Moke ws yesqy sEQWNIN 879 $0 Gyeabed ‘O€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 32.90% accurate

ee S Flu po ajed 0} /u}OL RRA XO AI RUURS 9d ee: se pre e |) ete mee wssomucina wena eonu own ng ie a +t} eet Isdo yalod (yar) Cen. TE DSWD |O7 aif | Sap SHB Y p01 = Naw | Mg? ) —} 4, >I Sars cieyen te gg) gp tA : Ae - | | fy ee leap? se 23: | ah 2 JE. 8] Eto <I | =i -C atend i i I 199% jem" 3 s\ Rs 2a an . a ee: ee ee fs bs ile news ‘o1pw9s E'S yo E/N WA 7 A 2S 910000 Yd IVILNACGISN@D +i . b IS) igs FESSb aera fall mes cate calnea Fi WNT -FA| ON ISLN] “LID " ee ee eee ane] DWSLAT Ld] EF oe opoW Pus | H1,5) ary way | aieg =k —_ ee Rete TTS eee ee ) Cine ae MET a he tee Peer arse =v, Rat ae oS = Roe ees , ’ > : ' hese 5 re. 879 $0 9vEeabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8ZZ JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 34.63% accurate

“29 . ; Be RSI ee] armen 2 Cons 4 [FS TOT ST sca ie = ere cere 7) °c ee ge ZL0000 Yd IVILNSGISNO ‘ — S| ae || 40 TP Tinea aS SRE Exe att [vane a es az 0s eR cage PRIOR OPA | UNA HB a jaarves Gnivnaztens RAO Woo eer | test eat ee | 4 ea = Ht eat} ) ye | Pe, [ok | 4) ev aa cr | roe th) res | Ree haat ot Sts | —4—L WOIATS 6 x ANT HILE US. : tt ae ! Lt he 3 Pe or | ite Cth ae 879 $0 /yeabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8ZZ JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 35.69% accurate

| Oo POLE—a; 959 270d OF HROL v rN 207) youve OINPBUOIG & 1014 1} her SS ar (OF e Se aed Bru) BIE WO) 3/4) UO ew AQ epeUi sEWEITS ay fe Aad | et ee Pl ae | te ot slo] eet oak e Lp wo fos “0 2 \. PDO G ee OPES Gea gee S [97 ph wae. Ono C3 POS RATE WIV") a | ND | AT TCO : ry ON - Systm NS nigh ff) - 008. ENDL Aa oO rida res ran rs % Wp sar sss NB a ' ne 879 $0 gsveabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD = - 7 - --o ~~ FS Ee oe eee =e eee Oe

The text on this page is estimated to be only 40.91% accurate

Penye SL PUA “Trypan 220 ( —_ “erul BIE at} uo ew Aq spew sjuelUuazEys ol} pay Apps | PAs VIS DY |PTPGA JPY Wethoy Sol TL jt} Pe | AT RS einer nro worse OY [ds] eel fn [2 "A40bej8D Wey Es a ae eet te z iv “ Oct dae ‘= oman ilien LdS 5% eS a Die: PEbKe\ noY7D ha ‘SL oN Y | Sst rig \ ugar (oh ant] eter ot Bek 5 wolas| | | Bo ee 3 : eh 8 lepoyy pus MEY WRAY 879 $0 6vEeabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 36.78% accurate

: pseu i. |} eae =a ‘ un . "sw uae Hi tel ae ae HINena a EME IQ) OFA Jesh rn ee 57 og SS oe Ras as ‘ee a ST — aS PRATRUTS| “BUSTS : fo sebsag 700 arr neDIGON aN oo) BSN Se Fe ae * - el Wp Hee cas Pe pains ANE a : AE] SIS Shi +++ — W sant 2am. lone a lune =| we] oe tT Ty Seger: ye a ; co aye Sink reese Maz) fe fe ee ae ie | aa | 0Z0000 Hd IWILNAGIANGO ti cons set a BROT AEH eS ne ee) CHSC ( : 3 eS TIAA ais. 2 Oe $<oer 2* lasagna omen S SV9 } oseabe L L 9 J O d OS ASTASTA 6 02/60/80 ‘8/2 JUBDWINIOG ‘8992 8

The text on this page is estimated to be only 36.16% accurate

*|=72t- | 9% ea ie ee __- — _ psevWog Wiouly 038q 4 feIOL “TIPU re Slips Seen "ONd] G1 LUO; SIL} UO Oud Aq GPE sjusWE}T]s OY; IL) AYjYOO | [say ta3f ELS | 21 | | 930, 938] onthe Niles airel-<e Pe ea asu | seo} | | IW be ll ee onniavadway so wofoehll | dO] wb) oo | oo |e woos | smb) 8d] | se 3S — “AsoBOlED yesaay JepOW PUB iB}: sy. Ob SEN YEnyy | aed h 879 $0 TGeabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD are ae

The text on this page is estimated to be only 38.37% accurate

ta fhis(¢e — RIT 9)eq 03 juyoy ‘er Q18 WLIO} SY} UD OU AG @pBUL SJVOWEVENS AU) Jog AsNIGS | er ___ Bg we Str 19) \ 39 yy tee BW 5) we | el Hl —FE Ss bat I lets dl oe | = a} el Tada ri ae & Pe el i oN td eee Vt as as eh | zz0000-4a TWuNadiiNop_| | Ih PA cal A c , ‘S *, maT | | sti [el] 879 $0 cGeabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 32.29% accurate

c] € S| CHIL! —aTal 930q 0} fez0L [ieee ES ee {igh Pen eee “OrU} Giz LC) SRA Uo ew Ag epeus syueLUayEys Ly yRLy Aj | ae AGO- SWAN Sag waeoon fetter | | tt awa Pei 2 Ree cul EN Sern MSyA' LD Saas seo I Tevet core ameratworesi | F83[ Saf] | — te Sierpleiaty Hertel (y HGF! oS sew |e 395, h\ en ) Noatg) Wye ‘of cacti Sean hoa) wag w ls Oo \ cvgoma munis wenaty AEM S| Gall Bln [| on | Da ANS ka nclty sre a Se ey ban-D = fopoy pur Bee ae Yexuty ea ee — < CS ey ees - . _— > ye ww ae Sr? -— 40" > : x 7 ’ has fr ‘? \ ,’ oT ™ £5 rate Fa > ~ » 8179 $0 EGeabed ‘OEZ8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD jens ___,> Saharan neds = += —s eee eee a —————— 2 —— 3 " ; SE ey Eee ee ee - ~ — -_- -*

The text on this page is estimated to be only 32.79% accurate

8J€q 0} 12301 5 ~ ee |B] bohL ee IRIS [AOEU ERS] pony | 0) "er || [ath | &Ayy! eiog 260g "BPU) UB LUO) STU) UO eu Aq BpRBL SWuSLUSIEIS 34) 1BYI ANEd | | f pba ae 5 ate + ae, RPE State . oF id at OCA aes ft Shes | hee Pe =e a = 4 | a ed ee: H Pf re ee 7 Jah | ae 12 Waa ay | STL | 4 Oe | 3) sh er AGL TO PAN qu as a a ee | H+ —4o-+-4 SLING AS POY | a WwW ee. SRT f el ee Sat ct see ) — |—| — 1s} —| A i pg ae i]. Se fA Ph TT AA te en — | = es te : ce a | 7c0000 YO IILNSCISNO a eee oy TWA) atts aw AS ree 71 ec NY | | | ie A A VRE Pee erste ee . ! Ltt ae 7 Sale lane ca aT Aslet waco Se ape “"AsaGoyg waaay BQN 54 | Sopyy way 8 pentaey wy eunysedog jo syu}0d | Sey) Wout | oj0g ~~ pe -> Sael ES oe _ = “ . — ~ . ne! eS Eee ae J > = eypresrre a ate = eee = Se. Plies Io) = +=, 2eerle Wir “oT * ims aa ee teens i 7 A050 t ‘ f _ . 879 $0 rGeabed ‘0EZ8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 36.95% accurate

Gii.% | =e & S(CnLLSS @3EC Of pezoy Ig PEAS Piles LJ - | er sh == | “ (Pie, abe. BM) Fe UO) SAY Lic OW Aq Opal s}UAUIEIEIS BY PELR AjICS | : | Kadmwg 1-4 ra Tat 197 hot sew hictagee Lrvavry loots ee ee " 2 | | PHD lar BH SenztoNDE WI! DET eel ak Sus {+a ae — a airy | ca __ erst G07 w5'ne| || FECT IST GOLA SIS] | nan EY ES Ge PH tc hiberrad me vareue | B70 | ES | ANY, OLN : T ae . . as Pe .! et } % oh Serta =e te oie 8179 $0 GGeabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8ZzZ JUBWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 39.53% accurate

918q 9} [BOL ll ct ™ | ich aT <T"ON 648 UG) 31.4 UO Blu Ag opeLy sjuRWA}EIS aly Teun Ajj200 | [SW] EPS CAFC RR hea wc Soe eal pe — Sea ea h 88 TP | = Teed g & “| ___AlenwD — ED BEES “WE Oe | BISA DHATT wma eontno enn het 4- ar (yay hoe ITY I "Hd eA Lh nM ors Fg Mer ona Te LINNOQ si- tes Zrmoose N+ ce tHe | | o7 Pha ee NOW T = ye se | tives gen aus #3 Pen yet Ne P| WY — Gj \ as) L | BS Seaighant 1AeZi Ye! ctegraICGN Mk L ty eee He 2a iat op ] os aca Hal ae See a 7A h min Magis t <b mos arioet) ONE AMES werent eneege| Ay Diane, Uy ¢ Waylays Bu ewig need caine seruriyn| | | 190 | aS ALI59} Btn Wang warthew Gy! we OT | L | |) he if ree be oi ’ rt ? ~% : ene eee 27 Ls Shad | eal iv be ee has. ve Pe de! Ree hae Ae oe bran tt iz o 92000074 IWLLNSGIANG@E iz. / 095| 770 WLIOG 7907 UV | 2 gqet | Ty £779 $a £.199C| LZ Pe7 * aaa fay MEOW i OL tsa a HH 7 C bi ° 2 Cr sHuipury jo $ 5 g = é : a : WIRY) UoYeDy)JUED) jepon pur | [Est Yeu bb SHOW WHINY | “Gjeg 8179 $0 9GEeabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 33.76% accurate

420000 YC IVILN3GIS Whh |e] e Stet ae ered 07 (BIOL Sea] yore ¢ Co ymmUOIS SOK elze |e es PaCS | D ‘ s Spee Oe Io | je) S64 ‘@rul B/E LO) Sty) UO SW Ag BPEW SjUeWaTEIS 6L) jBUT Ales | ae+'y’ f= if wy |__| dy! zy ult). AYA N tee HAS a (ap Quai loe |e] HH} ats <a 2 ! eS ip ] a 2 ee 9 ee ees Se. | Ge (MT NAS "CICps sh he el ry LS a Was Fe 0 pales ee TA Poway. me ayn tf Be PAT sam ot|py ty | Gol). SL re | Let ee |S 7} ed “ OE: fee fp fd Hyak WAL ENATAA gar?! Tete : Ne te Ad Spline $94 >—N0% Pict ress ses Bo sis I PTD | pene Hob sGulpue4 jo ““AaoBajyeg peaay JBGUINN _ [Be Ua LOUSY IIUBP, |SOOWY DUE jeayary y a jo S1uog yesoayy yey YRIUly ; 879 $0 /Geabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 40.45% accurate

S 7 a ol 4s ini Ar] i) SA \— f= «I vamp | iG |i eet dl Sey rr; te ta t® = ee at, ‘ Tot iD e heQeee “e AVA DY ety Zoe (th TaN ety : = % OEE eee + OG E170 = Pen ANG: oe aes ry — wv 820000 Yd IVILNACISNO + #2 Eas 4 —_— to SSO PVM “ee Linnadsdad dyn Iota STH I ete, > P. emp PNT dvd. ‘. i ‘ | Rta ak Or” reo 879 $0 gGeabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD

The text on this page is estimated to be only 34.82% accurate

‘yore u| ed he el ‘ ames Se sneak, ot ee | CP Eee stea ile |i) | Fee , Po ae E ah PS | tf | 5 ped , \ Ly . 620000 HG “IWILNAGIJNOS——-}——F¢ TE ee Ch . | pee — PAM] “PROT = 4 “hanGeyeg bye . TP ; Se rr en 879 $0 BGEeabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 40.04% accurate

V ee Pi 8 bee “7 -™~ 3 8 “MOI Dsmcr se eee : Fcc | ms | Bg seins it te i a PLCs rept aE el | 69 ba} a = a AWS rr mempereremeed Latha AKab . Wee earnest — Sify [eS Pare TE aw serAl OCHS Se sts yaa, — cl ‘cae dra nbk-dWel | 2 ere af | Seer hea j AS spOW pue bi SHEN WEAUIY 879 $0 O9Eabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 38.66% accurate

albb 1c % oO AALS] at 2186 0} (710, WIC ee—FAIRLSL Re earn aimeubis Sj0%. Tg ee eb b [Ed paint One "BTU @IE ULIO} SI} UO aus Ag OPeW SJUaWE}EIS BL) 94) Aj}129 | ae eS oe ita pS yh | == b eas wad a ‘4 *r ie ABLE Le “ath ai aft ‘wenearh eel] +h BEAR antiarr 3 "423 poe Ne ft EB _ Jered ar ot} ee th — Eg Tiger | 69 (a et eta Saat LE0000 Yd IVILNSGISNQO > + rh ee eee Le IAA | Yaad WTP UTE ““AaoBeye Weary one 8179 JO T9Eabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8ZZ JUaWNDO ‘898Z-8T aSeD ' , .

The text on this page is estimated to be only 47.16% accurate

z€0000 Ya WILNSCIANC | TH Ie et ag ae qe ere ae MM P|] le TV) Thy | TI (| ou ne A ple tae Be ad oo Be SS DOW DUE Sy WRAONY ea 879 $0 c9Eabed ‘OEZ8ZIZ ‘6T0Z/60/80 ‘8ZzZ JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 39.57% accurate

€£0000 YC TWILNACIANG Sara Kune ASIND lod Sind away ise ey 13 '9S (eal — gal Simo anny amads'5> m\_| aah SIM any eka ot jae" 1 ft 1 wa BER & =. IW 5 Fi 9 in : x . ; 879 $0 Egeabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8ZZ JUBWNDO ‘898Z-8T aSeD TR) [LAT eat “ON BIB WO) §/y} UO OW Aq epeLy siueWaErs EY) jeu) Aj[UaO | Tile rewa WAS IW 9S it t+ ay eet we NO ng ‘y _be ny t \ | NG ts. = 7 4 \ >) astro 2 japowW pur cc SBN emu aiag

The text on this page is estimated to be only 35.87% accurate

A LjWe. Pas i on 4 eeu UE IO OU Patoe > p SRL LSE pe tet Re | a $A Se ed "@ORL} G1B UO} S}Y} UO OU = SUWOVE}S O44} IBY) AjIOD | r= <a ; -p—-| ob st a ett : ts ea acs dw 3 2 ro Sire ers 45 2 ANTIND ee eat er cTa0Ll mn 2, pot! Tse | | | wd] awe Sey} Ea ae pk a Yr ot >| Isat | — oak} s+ | —+it—-her ae S ‘ares OY “OL ae | res a | MORSE IT SEKI DS sere 2 a || ee 7a f |—fte - ae Ret oy : Uz ot} +s | pe [AS Wail ie fee — {tie £0000 Hd IWILNAGISNOZ ite i . 879 $0 r9eabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD

The text on this page is estimated to be only 36.38% accurate

~The [qe [Als sll Sibl. [ee L bat al ‘enu] OF WO) BIL UO Sus Aq ope SpUOWIOVE]S OL OUI AYLU9O | pat | a4) Tau, ALN] s0tlo9 [oe Beef |= ts | Wd - PAS- OWI] VST] ed tt oir [[ | [> wr E 4 yy ee le A : re 77 CLA LACE LLL 9 ad ea as ee ee Es | [| | awd | sa | ACL gage | A sy a yt sy + wa | | BXD| bWa] watLy~| el907| SI Fel il dwd| wl adstinl Gayest | 5 Big — fiir wis | gwal Hate | eet] Si Se ee a ee teat : Af 2 ee Fe ee Jw, N| £9907 TAI a ee ee 7 Rac cre : Pad tip — tft oa | , yr, Bouts eee — ti ag Poe : op 29 - s+ + | 3 abd 10% oy F SE0000 YC TIWILNSGIAN@S'|’ | | | 1177 Pe Tid Dee et At} 9-9 danziny ii! — TN a : F iD aie Tl sat? E Ph OE EAN carte HN 8179 $0 G9Eabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 35.63% accurate

os | “tot a ws i, ‘} is © \ ao (feb acc ar ee | '. A. pata eb ee | ony] O28 WO} Sky LO EW Ag epew yueWEPES OU) YY) AGO | ‘Tv A, IN SM ETMST ERS ES ee Sat ats : — Man ie? \y.) “=o sy es wre nh} f ase eyy wo pe BIA YY SSlsgo vay BOA oe tid! | So ede > See SAUNA MMe © + ~ \y MM Td |>{obN] gus Su qy-Aw ae y 3 > \ 3 Rx 5 3 ~“ “ +5 —ae SM Ig, 5 aus te" ,"— co cm seo bf w!} + Y | et TSS : In—awa la dt LAN] eaaet| 97 744 af fe wy A m3-IWd| HdTL A] 6 299C/ $2 TT Whowastads ot AGS EEF YANN dd 2x ows THT T e790] tC SIA | VED wT eae e Le owe aL aginadew | uma Peat IAW Hanoy ese) Yessy sSujpue) yo ‘“AsoBayen yyesoy sequinty 879 $0 99Eabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8ZzZ JUaWNDO ‘898Z-8T aSeD oo

The text on this page is estimated to be only 34.62% accurate

TOBY [8D : “Oru GB LUG} 5I4j UO OW Aq spew SyusWayEyS EY) EY) AYE | : ow Se : a | : bs sa J i ae ey yl he ba et it an a j Ae i, w : net eh 3 =p eB magwo9\'5> 49!95 rel . 2 EMIS \ 40! s5 wolse hel : {er aL heerlen [patra ae a ee . ee A eee ake oot PA ~~ gi fa ~ —_ oO : = = wy) a1Es SI ai Al ab > djs } 2 Ms —— tar eee, —— —. >: Brice a5 a a ee Ree er Ny Re aaa cNeities peepee eer Sr prine aA Sie is.-8 2% 879 $0 /9Eabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8ZzZ JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 34.67% accurate

Sg "—b ee) TV [ele (Cymiacy ares | E ; iil 2a | ; Aru} G/B UueY Sry] UC OW Aq en ely epueWayEs eu) JEyy Ayes | : [ef AST sip = | — h F(t ee é s(t _ ee s[ e ete te a ae e |} se | 1 foe Oh sf E en! | =< a aaa BE aS fe eet SS Sra iy E a ee PFA) =] = eS) aS ae ae rs — BID | el et Sa at her ke Ne mee im te vA fs te ts Pi ik tot P oe on Pood wt» | 14 _ i T_T ot 80000 HC WUNQIINOST TP Se) 7, [399 t P P| ut] se ba A Nee Me Ps ' 5 % eae otk ~“As0Ga1BD YyBsD41y : | -«* -879 $0 g9eabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD

The text on this page is estimated to be only 38.04% accurate

e YZ & |9lstbll = eT E pesca 6€0000 Yd IVILNSGISNO ; F . | t | é. 1) £ | i ‘slosh imine e718 03 ;e10, LS) Siva] AMMAS Srp | gso7] G37 | on | ow [SI pT EY vt 20K, To lisiel| Le. PRS 4 ee fe os a es ee ak Pe et iE as hs a eT Ae EP eka OE p= ee ee | b HEA ; if at a im 1% bE ee c bs = [i] aeons ad A Pe ee b i Sef Be i iS dl eae sd a Lp) = Pee x a a ee NG PE PA ey AN ; : epoyy PUB | OORT ines oye Nem | we 3 | | 879 $0 69Eabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8ZZ JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 28.17% accurate

S97 by 2 ow ~ \ so "7 - a ; 4°-a7 Ce ee PNT) i Zz 3 é BTU) WE WO) sy] UO eu Ag ape Sjuawepaye OL) yeu) AyquEe | , ar { * rH EF SSSEESS IS ~ ee wey hh 7 ogg IY ee arte we kee Se th - wn SP Pa be | eee ~ eae / ae Fay ae 2 * : OAT en pte a" a YT the ete a a Seen he et 2 — om P = A: re Js age ee Td p ? 7f Q > » ~~ ~ . , “4 % " ca =” e — de ger | * Te rH ‘ ; 3 i 2 2 q & : 5 : A) oj 1s | v Se} TIS Ae) 5S 7 SS SL ra AGS |I B57 | wwess dan i> WOO ar - or . eS ee) zi er | Of | Uno. RY LO BOY UOPY jaPOWY pu meley yf | sayy) feALuY y Bamsedag 4o syuog yescuty ayeyl yey | eq Ley =o} Oly ST esih ilies & De 28s fd eB ain =p ee de Seas eae 3° ae alls Cs r ‘s ; - = 7 - . . aes ™ me —_ . eee, = i '?. =) en PRE on ee GP ) Aaa es rat . ach “+ 5 7 Dg eee Pe eee Se Th ns A a et eee ee el A 4 eT ~~ an he wr no” Frys y - (Pet 2 ee 7 we ; _ + = pegs FD . 2 a ” an er See A SAG ey 7 — . Teh eee ag Pam ae ao Po t= = Wes 3 ate aM: = iy a hkew — : ou 1 [8 ¥ & ee : 3 _ — eten yee oa a 7 hs I r ak ™ ae — 1 Stig Sele oe CFA, rebar sp Cote bg ect Ree Cts ae pee eo OMe Ag eel SRR ae eo ey Ram ae pron eens Spee angen, Shih y Ran bot ren ame Lap et YAR OAS! eda, oS ST PRR AE HY ME OMe wy i toe neg Nt ay ——- 7 ‘7 Hie ‘ — an Sa eon oe “oe ee ae tee ae Vise e 2 * Ayre peers .o : L ' 2 4 tant 7a y= atl — . ¢ * SS = < 879 $0 OLEabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD

The text on this page is estimated to be only 30.93% accurate

° are * > Ly0000 YC IVILNSCISN@pre * s :; fs ~. a 2 ee — ee Ee - . es ‘i rt ™ ‘ —SSES_____aaSS a as ye 7. 3: : ~ - - . a rs | ' NES fs ; —~ == “ > iS wW v OSM O) [~aro . mei” adem 9) OCG E [UTIL | | peaaries | ea wyoL edie rT ssh en a Th are 17 vied és ‘Lew tor fehl ae ee Pte] OTN AK AVA) APALTSUERS haaa AI HY WRI 2 id Wan WwwdS ATTITA WS) "OMA, QUE LUO SAA LO Gu Aq EpRW s}UOWOYE]s O43 JEU Aye | ce tleHatian> SeaAth\ Svrlr CSO wes rorctsog7y stn Lota hls een od Apes a ee eS Pe A hs ve ’ * ad ‘I i 7 es +4, 8) cal val | ES oO Sag) 2) 2 3% Ny U _ An we i) ‘ : VY) wD fy x x YU) f i AR . P A Pag teee ree | Os}. ol t od rl ee] vy] U0) ey SS ISS ill Pre 4 ’ m re iy Toe, ae a a eh at eo lade ewe “T° a ‘ : wa lar i = v Y W) gee eas vat ei ee bn” ad 4 2 J. “ = s —s stusn 224s G¢lor RC ae TTT | S| Var au — stl : ‘> an f " \ ee 879 $0 TLEabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 33.81% accurate

PIS] YE 149, - GUNEUBIS $40)1¢ PeBeuo, JUNO > (yoy obey 4 vi Wet dP>Ls “oe x Te : AWE 7-tTD 2 ray gH Gar O°" Spoons ata 7a tot 2 ag noe ane hea ~— ‘ — ‘SN4] SUB WHO) SA) UO elu Aq opm suEWoyEys ey) Jou, AyLIGD | re by | Ae lt uy 2am oak ma Nagios Sir pint 5. bah 3 \ PDA fs ATG IAAT [A = Sertiodk | els o Apa sinty "sere t Wied HENS 9) | AN | poteanmet (pigio oea ae ee ee eh LAITY SINE BIN aoe sa — ZN | Sx 99Y exisratn es Wd i) U a) ‘a sh i ‘ f LS ; ee a si ot te ar VN Fis al a * a >. * i i [S]_5| Spats 7 fone ao < 7s, a s | . rn ol : aera Geen ke a Ce a ee ~ re), mr ; : . ur iil d ch oS FT A ii LSS | ZP0000 YQ IWILNAGI4ANO — ae " it =| 5 : — 5 —. -? ’ . +, +>" = ssupuey jo “Asobeyeg Wesny ~ WINN 879 $0 cLEabed ‘O€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 32.74% accurate

er ee a mt 30M PINUS [NOMI . SD ) 5 "OrUy 818 WYO} S14) UO ew Aq epeUs sUELE}a}S OU} TOY) AypzEO | "CES Iaokeriues d vyyloroacn| | ass T ga\ | arb] Gpsr-5 [51 paw pteorssgraciavn wessyudn Mee | | JId | > [ on [ [rh | IAN ow foes) | [7a | Jad |VoRObN dit? 2 \ m Wrargvey oy GYM GIVIIWIN “op . iA $“Swuns ~StOHOM Lita A Sale “th ANY ; 73 AS & TAT it % SWi77— Sv Jie A + IT=> Cr I5 eT A - ONY W Hbac| — |e a. 1 =A Jive Mie Fai gis “On AEM LAinar | ae ) EONS SPIO SOY YSY a ALILENAD (os - Ovew ROL) woe) JA 5 0v DOIA sas Ko Aa! XP PILI OLD SIX ATT ates a TA I) AWS IND MMWTS ori Eh Se AFA) A ro AWD i if, NIH SWISS 4) OC VE m oy . © ‘OAT YM O AW €v0000 YC IVILNSGIAN if | f are 5 else. Pe ae ty = a! 3 = o yy - “ “ .. ae : = me — Segre el ete et ee ee mn ed tad , a % > * Ps a ote oo, a = © ee uy oe Y Be A or Hs at ene SA ae ae i Ra ape it = 3 z ty eae CE ms # ettcs pre tee oe ree reese Pie bs ra No eae "a3 ye ee Lae Me re oe Peedi ee 28 SF HRA pe Ne ee ate oe fe! ee ae i eee UR TL Sra ae Sa Cin oe ne oul A ete ve . r = t ma . < oe Tk §24-"+ +3 879 $0 ELeabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 38.97% accurate

ms) EN wijgqe |e SUS) Kees 018 03 1230, ——— MRO Pa 0 BY EMIGE Il eel) “Theg — pawodnmauy | | Oru} GJE LUO; BIY} UO OW Aq SPE S]UEWMAyE]S By Tey) YqIOO | A : hee tea . Va ae Ft TL We] q rm A ay ‘i ees |: PT Tt inh it f I elit eo | iH reais ee. st . Tt). if ta ital neg coker Ff ft Spb TAS ~ 547900 hi6S-s> 1 aa, SEP OI a eee | yv0000 YG rwunaauanbol — [fe Tih Srisnia> SDhgs Vag WW wo) - a S ee as pat av Pri H { "|e i A S treo {eStart — |e PAT] OAD | wa 879 $0 pLeabed ‘O€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD

The text on this page is estimated to be only 40.25% accurate

Bbr 5 "TF “VV @ mm *V td 978q 0} 18301 je a EPO rg “yrrareg InN ‘yg a 1 =. tbh i 4 lracowet AnkAe MbY > Wate Ny) | ra rs ani eye)! te wena lanrICLE IIL GD WAYUICS Sle tn 2 tal A Yood wh-ranNaewo’s a! vA Is) wa 2. pen! AD ‘gy “Wo = tet = et ends 410 Pk se lag| I aoe $0000 YC TVILNAGIANE BS ral wats by oz, MEN UNTEDYAUAFy jepoyj pue | ~ et jeauy B le jo Byujog URI PW Wemy | eg 879 $0 G/Eabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8ZzZ JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 35.61% accurate

é ~_-* | Rae ws weeg Uj (ejol AX aanqeulis § Oe YEU fete. Pa ree eer \D Es pt - pt ON Ge UO} S\yi UO Ol Aq Seu SjuOMIOJETS BYy BLY AjysE0 | tt ee Tae PSMENT SSW OS eo tt a | = al an See if : i= 4 ies Py | rsssoy sro a : E Sa ee eG Lee a : asi) gS | A433 | UA! Bey, Ws /sp Pe aa 3 - UN “ANE | SORE -tocecat A Se en +--+ + “4 t ice GE BS Pe \ | es O59 9p00007Ha TVLLNaaIqN@o_L | = [ZN oe oe a ae iro fe a Lt | ao 5 oe edujpumy jo ei tl _s Aaohaye yesony JeQuinyy ne icanrentiires 879 $0 9/Eabed ‘O€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 39.12% accurate

‘ : y7 ON ‘4 VESes, S OF A 21g 9% O04 a PEN ae JP ERTS] kata] “Paetone tM et ase a | Wr4oiwolAKs | $07 maeeee Sorina od ‘Wa WE a ee TMS | TNA orien ws woot pal |—38h St ee) aie ecumeet [SStH 290 € a IC 5] OT SISOEN| IE-CZLO] “Cr IT ~~ lspoyy pue HRW Wey | Sed 879 $0 //Eabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 31.27% accurate

* | ‘ — me pig pan a ‘OMU] G1E LUO) S)y) UO el Aq ope syaWe!D)s OF yey Ajpied | 2 e ee: rer wT Ue ae ee v Pod ES Te Let ee ae 1 . .” d ne ele = te ,, ’ ¥ yee eee, = é . rt > ‘ || I mM PLM sie | | | SSS [ST Tao HA Th SS at | on] |G aa ee eh Ss = p Ca pes f bt SST ES eT TY | SUS | Sd>] atbabal etsi-o] Aa C Wh 2 ./ ’ - — — - Ce Bo : ~Aobeye9 exoayy | Jecuiny sevcs tiasueade 4FOW UOROH YUE) es =e = ene yRUtY aenyemy | seq | ! SN THT TTT |__| re] " = od jo Wo TY 870000 Yd IVILNSGISNOS pod ay 3 J a Th i = ba ee ee she ee ie OR ee ee? eee ous an ee 7 ESE ae Tipe Ne Rae ae te Pa RE page ae Ee Oy ee LS ote rez Se ras : ease _ . * Te it hee et ihe . — NATE , STP ie . 1 SS aS Tags ay - s'— t ri j de Tt Pye 7; 2s 879 $0 gLeabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD im Fgh etn es

The text on this page is estimated to be only 34.45% accurate

os “SV tl Testes = e1eq ©} ye305 1 > j : > ‘ == . ‘ ¢ t fe } & aoe OShy Arba Juncuiy aia ae 5 . We TA dh a fe Hts} — B bat ee —+— Fie | oe +f } Eh re Le : ie ZT sd as ae yy anew \ 9 VL D/Wo/= pt et IMO w ONS &) SO owolot | te kan Or Ca gi) “ot ¢, 60000 Yd IVILN3CI4NO eet Seltitiaen ton ie cn eA PT ROT 879 $0 6LEabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 35.68% accurate

050000 Yd IVILNSGI4NO k sy oy >) \ ene al tus werd Us eeu TWA. v( SL HEUUIS iUI ed Ee PB F Yl "ON are UO5 SY} UO Ow Aq epaUL s}UGWO}E}S BY; {OY} AyD | alee at daly « [| » Jb pas ee 7 |» 19 | fe oe Steer ia ea Le = peat if A, | =] ay St ip : enn AA as | \ =a * Hr eee ee eee ez ET nant 2 ie orsg gf | Seni sk pa eg U Deel page fieh = ad S ; a et AV TS : PL MOND AGUS UNE ae aS naw arourieene x si “etooaen Cus 439 = Aestulacw Aaa 7 * ii LW Nal rs oy “* aL Te ‘ J a a x = sOuypus'} 40 879 $0 Ogeabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 36.41% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page381 of 648 — ni rots : : : ST ra Fare ats mT “f rey RINNE eg Te eee * Fare . 3 1S0000 YC IVILN3dI4 N i 8 —_ ~ __ +» - "4s ns? 4 —— art os f/f S VMPC [Ele oer ae S380 03 1702 PrD( RIMUBIS SOME aPC Re shen) Be] — rer PRD ag a...) “On] BR WO) SEN UO el Aq SpeUd SjUeLIE}EIS BL) jy AyQIA0 | Cn be Welt 7g er eo HSE | Lee aee ps ite +e =! Se fits ted eh eae ee = ete e (cis Ahad pa aw ce tae ee ee oe oq lee 7 As%wo!os LN. oy adie |.) oe Ps TT (ad | Wl & I8S) VDT) ses0KA] ELE Gg] Tite eet mw si | oly ~~ |» {Ss Er Bre 7 eae F | at a). [ t etcaal cacache =e 4 fees U eke | oe os enn ““KsoGayeg yesayy sBQWIN Gi jeapy g einysedag jo syulod ee ee

The text on this page is estimated to be only 39.09% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page382 of 648 Coss ee VY 23% BUNBUBIS 5,j0)14 Si] Sek] pecan Ye beg] ea h } be IPO, Abed ‘GNU} O18 LUO} S| UO SLU Aq Ope sjuswezE}s Sy) yey) AineO | oO #18 : ¥ t Ci tla se s + NSS ~9| S—9} SF —T 4 |W art inl ris | altel | PrN t z$0000 Yd TVLLNOLINO f ADIN AYP SPAIN A AUIWST VOW T Krew ts i ; eee pa Fa 5 —— S (Ms 4 Ls 3 ee | AINA) c f i ; : “haoGeyes yesoy | sequin : pony . ’ ee | —— Ses : a S TTT; PATA [| te) 3 Sy ia af,

The text on this page is estimated to be only 35.04% accurate

Page383 of 648 Case 18-2868,.Document 278, 08/09/2019-2628230, “tei e C b \hSd Lae 938Q 0} (e102 HON] jor WATLUOIS 810 lfed TWIG G [by ChB) S) mn nnoun Be a) on are wo} on Ue out Kg pew soe oe A282 i Ns od Se Me Ps Fy a |} ene J] fe | Phan fo hh | ps Re tL ae Ht a a ha is ee Bre a a Liq Jes | : ib te FN 7 Bt se i. ee ae Es eee ee fag | at ia [SC | azusg Aanan gy (nS W970 NS | €S50000 Yd TVILNAGIANG@®. r] 9G | SP Rese sen Rares yea ee | a Tr) HAIG 497 hon IIMS WWD 2B 1 | oe \A\

The text on this page is estimated to be only 42.90% accurate

Page384 of 648 Case 18-2868,Document2/78,-08/09/2019, 2628230 218q 0} JP10L BINBUEIG $Id 7 28 he = lb a ‘4 a Nese nae am WN 1S we Tot Vance olnies TE ows hovt7 Jad! sis' War Pol | Nae" ry 7 S, / FD 7 EWTIND Lyme tT INOS (J : S Pe seein a aS lard HhAc4s “CA ILS | al A= oA ol of 35] 5 Sate] IST Te 3 A x : Tey at — Pe anacens'ys oer | a5] 480]. Po | AN | eee ND ig wars! Shei] | AT | Gd) aLbob/V] 1C-(7eg] BY £2). Pg | Tico et rem ip —y <r | sat 7S0000 YC TWILNAGIANGE by x ie | he vpbeetruie Fane e St Tol ae eH As avsargyao AS <3 INGQWPS iF orl Tole 2 1 ee =

The text on this page is estimated to be only 31.66% accurate

ocument-248,08/09/2019, 2628230, Page385 of 648 C 2 PGES ee artery eIMIBUBIS 801d a[Sa [ee Sense) SEL er Tie TS ese ee ieaata ae pe pa abe | ie aah hg teh a ee ; |. pa eh aS Pe ih | P| 4a tL 3 of ty a or at ere an ae | bad ipl Sh et S| en KTPAS‘ai tb | 29d] A we ae 8 — 4 4A ___astwotar| tp [A DEY ee : HH — tee : EE gob] 7s gd | >So WEL gee 1% ay 7 ha Wah ye ae oT —H—8 ct ae ( es i lair a Py ap ez ' eo | lest Gy Dea st — ie zr $0000 Yd TVLLNAGIANOS a ae ee | ie | a9| O9S} ow | ow 3 at ne 7 a TT ere 1A Tod a Fabel iste a ag nee Pace 4 oye VYIOND | A wy weg > 1__St stwowtosiopt MIBW LO ESL RUay ‘seu | Sy patra. (PALNYy @ GuNyiEdoag jo <jUI8g wei tne bane

The text on this page is estimated to be only 35.76% accurate

Page386 of 648 Case 18-2868, Document-278, 08/09/2019, 2628230 ! ~yiyquy~ "FF (AF Loo eer : “A ere .. i) i(S=3|— 95 em D TE po es tee "OMUy GUE WO} Spy, UC Ow Aq opew sjUsUa}E]s ey JBL, Ajya0 | Set MW O47 | levee fon Ve fos Te = Mevarserl | dada} Bawol nn | (| 1s rivese|tly | Owe sem on ot | be Pots Aeon hp Fatal vey fb i ae plese SSA SOM) a TC — 1 aneusy-nwes| *) | FSM OUANT ae | Lee paugs|e | ORS SSeN] es aye htt ned y SY 2WUS i: EE es Pott tat ee ee sconod"ua Twunaauiiae st rrr tT SN Bast] «| fe pe | a 60 9a ES PT Bea — wae y eee s] SSeeEN TL : 288 | B98 SrEr7| when

The text on this page is estimated to be only 41.38% accurate

Case 18-2868, Document 278,08/09/2049, 2628230, Page387 of 648250000 YC IWILNSGIANGe 1. Ye) | “ "P 5 “= "ORUy JB WHO} Si UO alu Aq OPE sIUBWErEIS ey TELA AxysAo | : ae — — ae 4. 3° at on |: { MING B04 tye oe ‘A iv 2 <n > WO ot —_ —_ Ys S\ ; ol Fy Pad SAIS _ ~ — be rofl th aN EGEE a sz oe r . ee ed AM eta uM a kt ee 1g, SEMA CO | Hl MAINS tena weas-suen7s WOW HF LID) ~— FGA| ABLOWN | ILS\\- Dla Ot oe ee u mM Mat= 4 re “13 2 —_ EN —_—= | AY S- CUS valor M|—|[— aA3o) Masa) ar sep ainstianritgnelleon al bah |_| aad ‘seunpaood Nse ioe Heyy UORBIWUSD| yeaulty |RApUY BY OurtyAEdeg jo syujog

The text on this page is estimated to be only 33.36% accurate

Case 18-2868, Document-278, 08/09/2019, 2628230, Page38s8s of 648— wen “em , ae : Pale cfc [nre, Ae Tg | pecorino PU ts A) Bs] ele [= gene reunite mnnroaima ie Tie | aaeno aor enter] [ Sasn[ age[ uw [a Te Te ee _aerectin | ae So gam MS ee] | CSSD _ eure y we 4 ~ PTLV INN Ps em ee : PEW war ree pes] Stet > Sows a Poavo-72 wad winL7e el} | faa PO St Se as POL IF rr ce ELE | SENT EE-ST S Ba re] eee |™ ls oe} ——_—_seeamoaat a | | : —. ee || ee | ae : ioe fin » I ‘ reas io 0 i ik] pea \ - | S| laud HED ie ae Poe = a) (ae: 850000 Hd IVLLNAGIAN@O | eSB Haale seat Se . Faw) SINS a «LR

The text on this page is estimated to be only 40.64% accurate

___Case 18-2868, Document 278, 08/09/2019, 2628230, Page389 of 648 Bri cll\lele jaldhee ‘3089 o7eq 0F 1E}04 By] CTT [Rete] eesg | amare Da Bese IPs Peepers ora ros ou 4 ope ee wa A KLE ya: Se wey ayes] | didi] doo} ow | on [et PD [fat color taney groaty 2 Surge hh = OO) ea xe Be 2 Pe eee ss oy) | Sa pa “ TC || SOE aegis ances] O | Stas | | Sous 6 pe |Z ___aay sere 4k) ate te 7 SI] WYN Se IwYs eI \ h pe | ZO aie Yeon aD { oe TIA aes LC es a es SSrongce| | Od] ews] oo | ee “3 to pe rami wr es ceuae | COs] ADL ALeobN Wriu=s] Vr ae US ammnesens anielit a’ or a got Ep ee als ar if A] 6S0000 YO IVILNSGIANGee ran ea

The text on this page is estimated to be only 34.99% accurate

Case 18-2868, Document 278, 08/09/2019,2628230, Page390 of 648 . Wes iplad ph OY . oe Ff _, mye, obey yes!) : Ls : . , { ae ala ans BSS9 S| ee Se ‘OTU} @/a WO} SIW] UO SLU Ag apeW spusWayEs ou) JEU) Ajqi89 | mage | 9a T ase [ TT Bah oi SEN oT paste wtf a wero re 2nd Wud © OV GID 2A,S aATe a t vey Iu vl fire TW ATVI By ; SO YO GT NL Were an 31 $607! 1 MN ac> a) SAS a3 ; SS eae We 1 T4919 $99 Srna TUA $0994 WINE VEN WIM ia OMIM / 4S! or eH q eG 7 are AeA Gla Gg) oe PTUAS et IIE Q~ D> OATS 'azil> enki“ TID WD ho aa. ~> PETIA} Og ee Twas] a Ws # NY. py ee YA WP AIwely ; BSL (ha ae HES ‘en prnt a AF 7 me a | van OSA | aa dony | F AV, Lyctnggi sw pave iy (WYSE AOA DS GrMQd VPA jad OA Bo | a AyD dd Lio} iy 2035 ley ay ecraeinrsy Wh S| rend A wel ory WS! 2 De\} _ | | ero tnhes tastiv Wafriits wi i003 §loe ral draeoion ony : PER : WS | lent, h } 090000 YC IVILNSGISNGe Fal yaw GAM U/WES inv IM, O'> © Wa. nw! a plo WW pac p= snr “CE ‘ S ‘>L $< 7 su ws ; Shei) . “ Wee eas Sa tertiy 2 ; Ae oi Fae: ne Borns . > | er pa. oho Aiea al pees Peet) Wea ere Pode tee reo ee SP le teen es Wate ver ces Pte cose ee eB war +t * 4 . , , ¢ : . { ' Bs BOTT wre) ““As0Gayed edaajy J9QUITIN jopoy pue | ——6+HOW ito | 919g

The text on this page is estimated to be only 47.68% accurate

L || t. . ( bhiaS a : | ee @38q 9} 1930) PARA ke A! we ery} 818 UNO) SI) UO BL Aq epeW s;UEWOrETS OL FEY) AUG | ie ee Lame fi as CS aH A t2e@sdw wants edit el ww % WNUELIUT, WK Anne atch meth he hag es nw a ct = LW oY imp wWAtt) mute = — ut ope: VES AG PZ aa aka 492% a AS Yur oP EN] wns TA ay Law wou | are DE ay TAQ CERIN Ko ae OL alta on cl in| or} ole] TP AY 22) et 4 yoy 49 03a] Fill feel a TT 190000 YG IVILNAGIANC a a ee ya mg Aa HE Ne i. sm ee TTT — Oe yun | = iar | Case 18-2868, Document 278, 08/09/2019, 2628230, Page391 of 648 — —$—— re

The text on this page is estimated to be only 39.83% accurate

Case 18-2868, Document278, 08/09/2019,-2628230,Page392 of 648 — —wi ‘P| oh Thee a v vr" l= . TD) io i: i | SNA pee He “@NU} LR UO) S/U) UO aw Ag ePEW SWUSUWE!EIS Gy) Jeu) Aled | hs a LE Aes) SeVLN? aewom oaiiwe ha SE Bee Seger anton er PIE Wh 2 on Lis oN rales oe aa rg reac wigs ac Aine a 7G CRA PETVEL PAH AG we) 3 fe ai spat : e >] Tey sraeaile a mG rj Vea (wot at ae Ww rin el PA? 176 Bera NEWS) \ I WLEY tat AER 3 OSG exis XG. we Ae Pi De hou \ t+ ee | ANG | iinteanl Fy ARI Aol ss Se eee Enea Gstins eT loge tO TRY) NS Myr ohee DMN E NGA ‘oO TES yu PEL * meant 4 inst) > TNT A Cw ey = ~ vd ee TOMS ct aK a So | ee 790000 YC IVILNSCIIN@e A 7: tt zz 1 2 Sy Ba ee et — ~“Aobejeg yesoiy JOquNN TYEN UB | Sled

The text on this page is estimated to be only 38.54% accurate

Case 18-2868, Document 278, 08/09/2019,2628230, Page393 of 648 €90000 Yd TWILNAGIAN¢ ! : Ale [eo ea am an 4G fY Stsb| YL | a ODS : eae « B Olid ‘OFU} QJE WYO} S14) UO ew Ag ODL sOWEHEIS OY) pOL) AyjEO | Li BIag CS ae a ae a eRe alt B91 ww! dF Inv RL / doe | unalaees| Ts ym! | 39BS ee dl iv 5 i Hs a ql A ee) eee Eat Be UP IOWAS| COL-LEL-B] L\ AAyaIC 9V543 ey 5 aut haw FBO LNIMIELZEG! Bx, a a :

The text on this page is estimated to be only 34.34% accurate

Case 18-2868, Document 278,-08/09/2019 2628230, Page394 of 648 eRe eae PANO SRC ER es AT ’ a. 2 ae a = . Lj ane * . D 7.7 y90000 Yd IVILNACIANC ; ee a Tt ofits We ats este i} ‘ ee a. —, wv | Ott fy] hl CEA oma we rea, PRO) fr? | } orn sina GIN fee fh Chl Gea erway al is se re eo [he | arreeneee aes | ASS | Tot Te aseN eS TT =i corpo eseaeee) | | ssh [ssh fwolehN[ fe toe ee : ‘SwOTD PAPULOY OB eee 8 Teel BAGS, POE OG — tt Sy ett a rv § su Pee sae) Ae et mye + i|3 8 [2 i2 .2 ab “Sas : e-| Sey aN Ma aT KC TBA| — paul . Sa eq tat = Leas 2 RR Atw) oe AU Lt mar 4 ee TG ql P= Pie a oe ae | —AW3| SSB CEST cA eat de pete ES AEBON ATE CEG) sah

The text on this page is estimated to be only 36.67% accurate

, Page395 of 648 Case 18-2868, Document 278, 08/09/2019, 2628230 + r Bsr, fas > as ’ SMe ee py We Ete) Fe Po ee vs ’ > te. 7 = ‘ | pd td LS TIS UO) A a | . —— WTR Ree eee eae ee x TAR tae ee tf Pp ge eS ee Eee SSE os a Ais?) 1» ae rr => lag TEIKA WIAD bw sey | ‘ hice ase ' ee *“AsOBO}ED YEAINY sal SEC 02 [E104 | | PLBMIO4 UNO 7 je) abe | 3 ary 444 SUC (ya i Sap eiLMO AS ‘nity Pep V/\| ASIMS Qa Laver or sBhupue’) jo | sQuanny "SUS, SANE | oy _ Bahru sweet paw? Ueh /S: Le ir Re VT Is rr Se a - See mtn milf <a Geom, A us'wWo'wG “Df antastw pig TBLoBowaun Awe ler] —_ | r | Lo sia wh! ex7at ‘csy/arleel) De TL FR ODE el Zi eeatewy yf Loh non cid aa f ‘DE a sft ee TE ET res me BAAN FER sami y m7 WS is se! 2 #2, * | Ps i 2 ; le gr ant gy Sencar é ar = k= ss f a %, ay oy a 7 é \ * ’ =f 2Eei A>, I er \ a oe sweUssiopug 'sisanaiuy ; ‘sadnpaco)d *eyieuan | fis | San — Lelctwy tog [eM Ss 498 ael|_| ows rt 2 Try wp) Qty $id ‘Oru} OJP WO] Si UO BW Aq epBus sJUBLWSIEIS Gly Tey AjpLed | az \ ie = Poe hy ene Wael \ \ y | AOhAN Sys\\~*)| L Ade y\ 1 | AWA>W Add | nd 1VWNAD GOL Pict. IB? “x. eh a y STL Eom" Sesh ~ * \ tor OW FI ~ Oyet7 | {OAjy YF CANPedeg JO Sjulog BY LOPEOYHUBP| esaaiy yenoyy pu Bey Yes

The text on this page is estimated to be only 34.52% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page396 of 648 ee PSS | _™ FU t. mee J BF — a & PURAUOS JUncWY | io, B84 | ‘efuy 819 WO) SAN UO AW Ag epew syOWeTE}s OY yeya Apps | ee . YAGIOWS GS | OF T-LL- Gh) sol 20M L6 it ~poy neice: 2NCO hat) Tw Ivy | 7 LUL- OD ET a. ee ee Ty Teas Meigs eee eS SS oe ie OLS WS etauNn {LE box cP 4514 1/2 BSe, Wd | boon canes ae fa 690 | a. : SOP TIS 7H 1 a ae 97) yi. - STATA telat BO 1 7 the Sc. RATER Ee es Yar a pa = / by at ny pe a“ Sle true & Ge ee eet fe > easy ee aemweresr: ” fae set pts) Siege Tost Scr Te APTN o*.. 474 . &.' iF ‘us TSR EY ———— SS mt — if 1 pene, ' Vy : tom eT Figs» fw ‘WY Loser % % 3 nt x) fe = Fant 27 SWS et i | a ¥ w%, es oO] Wes . oy > T1A\\ | ea) wu) MOA YJ Baits s}UuSmesiofua ‘s4S NCU ‘ON | umoly > Ry UOTHOYUapy fPOW PUB : = j | Ax0B0329 yesoury | freq nN ‘sounped0d ‘syamueH | 1454 | seq) — renpay " eampredog jo SHyOd | wee POE } , SOU

The text on this page is estimated to be only 39.41% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page397 of 648 ps te eh roe by oe bl | ao! Tals coe ey. eR ts wae Sr ears. ofan oe ae ott 4 2) ; aE AR: Sone, Ee oe “Sst ope: 290000 YC IVILNSGISNOO 4, OA WOT) | ayAauiy ~"A4obewweg yesosy MW ——) Stl 5 @12@q) OF jeIOL ARG y - \" «Mo —- BNBUO|S sjOlle $5 €: pibMoy jurKcKUy SF) Li. ot He I ery ebed | ‘OfU] GIP UO} sity) UO BW Aq spew syeWoyEIs SY) WeUy Apso | , Tet y Le mJ Ln) w 2 lig ow Ta Wg TA PY GD ‘ote, “q7 AL SO) ASI (hv L\ ‘A i i Le \ = AG AIUD Ac'> ei | NSW aa \A ee [te “ae AG 1 aT EL) SOL NS Wi NS Hop FOL pe - AS WES "og bay | LI \Z \| He Sake) haw wiVK2IWISD AL f ‘ WILE Fog [947] | =e 4 | C Ww) od [hIRAGT 2 19 ad WOl b+ N| Lon-urt ae t = 20a | gs Ot MIESAP ss UN ek 7 TZ ary ay MHINALS leat 7Z- -ZL-GI Ts afiyoue’ jo ‘ON | UMoLy RW UOlPeor USP] | #OLUAN ‘sme ieee juGn Say [BAlAsy 2g BAN} ABdag jo synod mr werospy ae a . as

The text on this page is estimated to be only 34.79% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page398 of 648 |clide [c[sect 'Scild<’ [Sites she SOLA ie este ay x 5 ;. hail 50d 232q 0} 1HI04 = . =A; PIBMWUOS jUnoWY PITT a Fa aS . iy eee Ser. S "BNL) G0 UNO) 2/4) Uo ew Aq epew sjueWeyEys Buy yeys Ay@0 | ane ~ fear oh str : G'S Re AW> AIL 1k \\ | Rh seas ogy (oy SEE Peet tte ee 34 Dt eatery) ‘ps ‘199 ‘St “RAY NECN 5 EEL Wo" > A gh grains ie. Nase ray mat tr wee CRC] AIL +9. Ted | -~st a a! fa sla | es a POUT NAS Toa Cw gM eae rear’ TIVO, 5 rly § so! YC* Wild ye hie | TANCE TUES by PAINTS NI TA nae : Vor Pow Kirt “epey Ac. I agaey / War G9 rt MOLT ee OHENEI, LAF by ‘Ons 29 Mehler wi : CTS 7 Ce erg oe ns Soir be Unies FYI)" Beal hy oe - , A ty . ies i ; %% PAROS FRET Ee eee AROS Hee TN aR ohn res ae t ES. ais oe sa ete Cees ane Ses hoa 24 ae _ ae eee arth ti we a. e ‘ . as ; ‘ = ‘ IEA ary Hey <f — 7 ee CeaTS te Sx) Wf ‘t= 2 St ass PIN See CIR WE) ON kIE . bi = AS W/o a leer NS (oe - ee Pe cereesh a fen aehnes| N35] 2 Od | r 9¢ 890000 4d IVILNSQISNOO O} | - Ta git we —_———+} Se Toe ye? ——_——— , = as ‘Z =e ) H | 7 \ PERF, 29L | WT] SEe0bn wie-Ceu-g | Ce et Cig rw ast a ae Lf 2101! asf Li ae aa SSI.) arpopnl gpsi-9 zi y, nog o\| PUIW® |avend XT —pe + sGupue jo | SjloWwessopug Preinthers | “ON | UMO}- MCW LONeouURpy lapoW pue ae VD WEASYy JOQUMN tates, “ttt “sqeewey | jyCi4 | soapy) seaty 3B canjredeg po syUjog WRsouly BYE weiang eRG

The text on this page is estimated to be only 37.96% accurate

Case 18-2868, Document 278,08/09/2019, 2628230, Page399 of 648 690000 Yd IVILNSGISN w Wl >bilei® Ee 0] SYTIETS >Heebl Tat =< r S18q 0} PEIOL | ee AG va { j?} FY Wf SUE PLES 310s 21 —— Ss | wf rf ies! 2 MBG. juNOuUTYy B - Nap : eed "@MU} eve WO) 314) LO elu Aq epBW BIUALIGLE}S OUT EIN AYE | 4 wiv or 'ac'aet thd ah | SSE] ud i a At WS sna wwolwerrpresitet) | WAL | Add |areob A [aieoeE dF E AG GACt La tac JAA] | 4 gd | OoL i 4 a ie ossucigix S| | GALT stead z eu mA | eid | Ws sud, WN Baws ap‘ oo Le Pesce oon RUD an ESI we ; NT fnoshpene oa wNI797 '! or Le) We Lach e f r ~aliaote paps ——— LS se wy ly annvug aat rOe WEG (wz O)() > Qa COL. ene vf 6 Gf ee BBY _ aed _™ = , ‘ = eo ae ee oe a Pea. =f ~~. tf. o hs : ; $6) weal at [HOA ) SSTL I ht ASTL gol ' lp . , Aah] 8 Sol 6 LSE is aren 'FW | Letd | tod | n |b ei EN CNIAN IS oe PBN YO, 47 4D | "1 (= f Irioriny THAN) pa yaw NO Efe & | AL W |7SbobN] dbsi- 9] 5, EW epee RAPA ARES Ct MUI IC = BEE IY WD lace eqn GS eXN TD? O43 =~. J veg Bt | | Wo rr onsen ale PAIS | 9d. MK PAE DENG WoL Pusey oy % q c) Cer Tt > SOAK YD PSA ee EC , | | SASAL| AWD |ALeIo(V [AIG-L2L- | Vy, v FS % pases ~~) Le) his ieee — hj {i YHADH | Yad WaldaLy| ty te wi, oy yr ; wie | 1 T te e———4 sOupuey jo : eAnsus ‘OW | UMAOL4 | BA, UO}HEoyyueD | (Spo PU | oe F “faoliezey yesaiy JaQUITY oP. DO4d emiey | 594 SEIN jOApay *'Y Sanqyiedog jo syujog YR y BYEW UBL mE ee eer

The text on this page is estimated to be only 38.21% accurate

Case 18-2868, Document-278, 08/09/2019, 2628230, Page400 of 648 Fy ~~; See te OS el ay ere Sefer 4 Te TS oe sb ptne nats, - ‘ ts F . ny! TIS Ta Tien 2 ae en ty er SS Sener wey i at nae) ai - ° ‘ . " ‘ ‘ at; - 7 ‘ AS wt ow RTT CE ye oe omy SL ~ 7 w= : (14 Stee AS ae 020000 NG VILNSGI4NOD ot ee | PUBAUO-s jUNOWIy 1.7) >t) ha & =! Bitar ky 6519 @}8Q 0} 18191, ’ Pd pr] \4 Wb QO agen : c | 1% ¢ 5) SUSY ' i ST | jeiny abey Gil: \ 5 “OM} BAe UC) Sy) UO OLY Ag epEW S]uaLUEyele oY) |Buy Ayan | - arisiwwiar| | ANAL Ka 4 amewssmsiwilowystag Ist] | AUW Ad pa OU wn' Le yr 2), Stas WN ID!ge[bh rave OL NYE els SAIN ania aT wD! Se AIO | ds) 49| BIN PTAC ce (AS (Ah ‘WH DS I) See ah yc WNBA \> \A SLSTL | Bvt | vA | Y 4 GL} 9d | ALLObN] DYSi-4)| Fz (OSs IW © ASS SANG 2YLAION? aot bis wa wen Seloh rah, (b= TEhd ADS | \\ | i\ Te | AZYE | Ae] FLOM L7E-D] 2S — sSupus7 jo SPUMWOSOpUZ “s2GAneury ON | UMOW4 WEY LON ZOUUDP| . “(u0beeg yesqy raqKunny ‘sounpsda/d "SyBtloy | Wh | seu | = PEAVY 9 eunpedag 70 ssujog yauauty Oy WRLUY >

The text on this page is estimated to be only 38.97% accurate

Case 18-2868, Document 278, 08/09/2019,2628230,Page401 of 648 Tt, On P Vat NY SeHeUBIS Biot OPIIP PT BN} SUB UO) Siyj UO Bw Aq BpaW S}UsWE}E1a BY) }eLy Ajnias) ol ox Wf ce | Sf\ ——_ As ‘sr NC a SUZWWINS dsyw! ASE hs ih rit PHNNET a Ga my : wert ; ew e's A Ww ts | Sot = . ws 2 )‘ wl By i Fe ‘aL'wai' 3g} % WILT yd [ASN [aE] 1¢ Al. QNO fA! x6 age | AS) ef SOs) |aATbolwN | disit- 2 | call oo $30? cus AWW Ks wi 4 5 al wan d7 NC w |S yA a\ Tan) Ansty | -MAIN Ae OAD 2S tA \ {LA Sa habe INW «| eogu-CUl- ) Cy fsx IS A % C\ FF oe 2 MANNE ear riot 7 \ [PRR absent 7x UR 120000 YC “WILNSCIANGS oo _ rh §> WAT! AS ‘dh \\ y\ \ \ INL i | ae \ PP rake D WS Ce VA \ a e } Pes \ nee” _ Osiv vin ie Loy! ASWIbN| PACD _b gel Ba Ed a ae eect De OPT et *“As0Bajyes yeaoyy Joquuny Sian“ ‘Hpewey, — or eae secvetea a

The text on this page is estimated to be only 39.83% accurate

Case 18-2868,Document 278, 08/09/2019,2628230; Page402 of 648 Paty as et on, Or otter rei terse: aiettase ry We Me eS Seta terse near "ps toe testy 7: hi a En eos TTT AE Lee AS ¥ rs 5 + 15". "et a 9 a ae Be HY Ts “. bt ye Te aed TTP gam 4 TRCN ery =% \Sf = Nae = y 4 5 sh eae 6 WSs Ehae wy 3) 1p Te i er ; i ae ery oer. a oe TS yg tt ee a Mt i“ Sate r. 720000 Yd IWILNACIANGO sen em) ———— 3 gR2> Pret. PiRMIO.) JUNO mol efeg “ONJ] GIB UID) S/4] UO GW Aq OPE s} we Syl eu) Ayuse | ODS) =i. ei (gy! zi feet] ag ar epee WC} ON 6 wine! oe ail | AYLAgT \o/¥ © WyS\\- =) | s\ 4 [hv | ¥ Q: >). 4 wn! Sat ‘isl og 1S win wastrel MS 'WiN hwoOloe. wo yi WF =) 7 ae c Y—)'= tS “Wr WW MS hw (25 Sl SA Cad 1 Cuiioc] Se OL VEN SBI apeineniamea a sonlbeuens ‘ON _—o Asyromey | jugs Tyan a {1 a5) —sa0 AS UN | AVE HEY! UOPPBa ep} yeiosy jeaury y sane jO syjod eysyy erauqy

The text on this page is estimated to be only 40.37% accurate

Page403 of 648Case 18-2868, Document 278, -08/09/2019;-2628230 €Z0000 YG IVILNSCIINOOD AKITIDA| VEIT? farted WEY Sale e TLCS }s | BlkLLhb : ral a -Asobajeg easly IPRA LUl = Lay. a) MRO! jUncWY ped OF /¥IOL aes anDLs - = - Al AW LaAGi an >| ¢ _W/\f8e Wau 2 tant sSuypurzy 4c }@qUinN A sandals cw ASO ES yy FER A CAI" y AIO SSual bi Fits [N22 py 3000 95' 9S “wes ‘sil ye Hel } ato WlD A< view 'Gw'*=pte| be ys! wes ie ‘silt az] Lsp'wa' a cILee ATs! ww ig byeee +45 AS arias'cw gy! syuowessopeg Lasghuen ‘epmnead ‘gyacuoy wOa4 sol | “rope ‘ang G18 WO) Spuj UO aw Ag ape SjLOWWETE|s Gly yeu! Aye | el 437] ) \ Ky KddT| WIL AZ | wel 4 Sid __ Sar “oSr yh | APL HSE | Sod ALAM VANE EUG] &\ IGd wow fé *) ie at SA hAG\ aol | aDbobnN! gysi! i OL roy OTe. MER LOWZOYyHUeDy jepoy pue | L-fe jeaqsay 9 eanyreded jo Syujod WRI SHE [AEM weg

The text on this page is estimated to be only 35.30% accurate

-2868, Document 278, 08/09/2019, 2628230, Page404 of 648 _Case 18 Sh eb 7 ered OF FEIOL A: ey eve ' DH CeSn| ee) memos nou C/o WjOy eB aNA de WO) Sty} UO ew Ag epew spusWe;E]s BY TEL) Ajqad | a “= TMS | GAL [Ae NT TESTS ‘a9 AS Wrists {stl | Ast ss A a “1 GO et A TUS ates | « y “4 wo' errs ergy ws AST Sony & nest X -S win) SCAC aR at am $80 46 4B ale > TED Li 4 4 | or WN ROS une gh? DL" oe | t 7 ABS S\ ws R ee MS: wrt! a 4 A wz OF 7 RP tf) EAR EL/ yi BYPT Sb teeryentl , aati aR ie t) > e 9LN€ aa \ ond ca Cc’. Ug gvlS A: ‘L NF ) 7089 =) S& t.5 M47 \L oO jo Mie Hawi yo Sasnyvannt Warsy| | Rb SSO MST! garni! & ha S OG ee ee fal ‘ RS yore ees" Cond ‘a bas' uN fi Ihe IG d WL pus WT AMY eget lad | AST ‘gr se <u] | CETL gh as'wr SL bRe] Sesh. GL 18! nv! WO! aL wat] | tof ‘An AES Wat 'WOlZt Laz mn 95 | wes ASS WNSWlor Tie An Ae waligW 2S ZIT] VI ee" \ cr : WAR re 3 _reyopa varyeonouly Sud To £| hee ry ewe =" Wa SING TAS TH ia ace ‘a Meat] fF wi AUCH TU Ve ion us an OP. Pa Sac Utne we OL Ashe iS : ae —s , re - “A | al at ° c - | hoo T. —— sfujpue7 jo sqrewesioptty ‘slonnstieyy ‘ON | UMOI4 7 MEW VOWED HIUEP] et JaQUINN ‘saanpooolg ‘sameway wou | SSA reaAaay @ Ginqedag jo S}yOg yeEniy OME) fey | aHG of J . z “ 4" S5 > oP

The text on this page is estimated to be only 36.29% accurate

Case 18-2868, Document 278,-08/09/2019,-2628230,-Page405-of 648 “7 b 2 ae or coe A —— a ee: a ; : , UNBUB|S $40 |fed \ AT} €| ¢ fA Bt 1 Tite | yg 07 seyou HA piv a { *Z4 e| &. { ASL WRAO4 jUNOWY : ‘ y 13 i a ‘\s | ce a ayo) bee ‘Oru GAB LUG] s/f} UO EW AQ epRW spuOWeyRyS OUy }eU) Auras | AD IDM CALMLY at Dh a «tony for Feu _ = lars twiai foi $l ———" eee Nd SNaslas'WAISS RL : ea et 55) TEMA SIS gets aU Hid | : 7 \. bil | 7 Piao Q= Se ‘Chg usw Weaant ATS Ay ( CPO IF INT =D Leahy St ss Lda Sot sme ls epsyed dors) = M173 ' i\ ‘4 SN, N) J Cll. SZ0000 YQ IWILNSGISNO wo WS AE 2 AL! wl’ 2r e% = a was — Mae ae ae Bere, Vy , G e “a wa! ~ x ( i 3 pte) Se Dama _ rich] 14 ee 7 “ -(—7l-Q| 2 ak: ATT ES ZEPLNME cee] By, . —— —_— } EN ee SPLIT , we" FA) wh need myrid i i —— EY UONBUYRUAp] | JSPOW pur | ——L» ““"MOBSIED 1)8424(V Jaquuryy ills stl dae i = et a 'gounpodoug fsyseuney | 5

The text on this page is estimated to be only 43.38% accurate

al a ~ a —s -_ = — —_ e@ =< ay cc — AERIS ave ah rare = Ie at . * re . Tee 940000 YC IVILNSCIAN@c "= Case 18-2868, Document 278, 08/09/2019, 2628230, Page406 of 648 i aD Tq eyPD DA rr} Tr & |b{Ll%| Fits aoa a vy FRU s i, S45 i S| se “OMU) GJE W20) Sy] VO Bu AQ OPAL! sWaWO}e}s BY] PElY AILS | yw TS Boge ot! SOE Ox AY : ae ad hd ! pS at t 1S Wat wo woos Pell AI gzys St CT wl. Y rine Eh tebe FUE) ley ae % wes twa rm | DI ¢ 2 GC, | ah Pee = interaim EE ee a‘y| 2 yas APSE wd stwarns! WAT AS Sw oe] Me he ue Mes rt sSiypus’ | ““fLr08eyed yesoiry sGqha)

The text on this page is estimated to be only 35.08% accurate

: fe \ . Je O|elLb Eo ee ern. YY 4 ‘ead ob aes) | Lave D [Ly Pid t: Fuenuog junowy Ss 2 9) ls tayo, wey ‘eru} @/2 WO} S[Y} UO Bu Ag Epes SJUOWEYE}S Su ELE AyyAd | | fT eT A eo — eee eM w= Ol paw) aes. 44 FHM VTA \i-) WS BO DAA, REWIND HII WHIT Ary! PDT '99) nce. fw UAS orPAds ton oy a BURROW SMoial Q=) ‘OD ins Pey is Gy yn oe AS WV) WI ST UF yO : /\ 3 waiceriaw yanking wT 3 S Wo chevoany er) nz “i CIsnas2 CRW > <a 3 FS eRe WS H oureght, Lae 2h aimed ri FAAAY ‘aaa eT | “> AS A bid FS ate pen i ee —_dStwe pow Pt) Ab) | Ag Pea VAT IH Wir 400. ns MN OIL Naat. Lie. A © A SCT CHY YY i “AW aint 3 XS Gy ‘3X My f * a A timdcend ww let 210000 YC IVILNSGISNG Pest as WhIbWw] sie ah S| wuy VORESY Lap) jaPOy pur aa PRILY OMEyY Welly Case 18-2868, Document-278,08/09/2019;-2628230, Page407 of 648

The text on this page is estimated to be only 39.66% accurate

Lite d Pel | |‘ by) bee \ |. %. @jUq 0} je}01 VB ? ‘ purer, fail dl site doen ( : "Wy [ : aes PIBMIO4 [UIMIOLENY ‘ f jo) c60ng “SMU} Gs2 UO) SIL} UO au Ag GDLW SiUelUaLleTS ay) jeyl Aue | mM SSG SE au BROW DUG | aumtHBREW WEiy Spuey io JOGUINNY LIS VOTER REY Ymouy sf, 4 SqueWesOpUg a aed peasy YW Omueced jo s]ujod ““fUoGeey ywesru\7 tee ee) | nee : us . c e | SUS gf A= usd Anas] | 2 : CLD VALS A - thenvaw ®DE py Vaal IG!) AIT 0 ! AT WN WwW 9 ft ete whe 3 ATS Ey qo] eC op ‘YANO MWS Why a fp Gol] PS oeha, sheteD] A © SS Se at 1 =< =. ar OW | glib Why wa 'giu Sway! 2 <Iby4 “ST \4 \4 J} | : | eer oe, tga, — Ti S<- al ms es | HS) OO WN Wd 'wity 2S)" : eee oO Ly\ cs af o ae) ste |, co TS Ani | ON | | ¥ me OPEL. a a o | UNNU TION TOR cw oe Wig Ad! AMaleN] Poa] bz | a ; eo 7 GND SV ¥ Er nel ei a Oo | wa Sw Ms aS MP IN| PEMLNHIECTE SS 9 < Md + 1 Ss. } | ————_—— we ot = { | o = Phebe AL EAS HL SD] Sf 5 820000 Yd WINS Sy , Se a At ues CO i} i 4 ‘ é Cl ax)! joy! ‘ Ai Cot Pate | So Wd AS ‘Wal se ‘4 c = = . s we. Moy | sesso NIMC - =z D | Wid Stes! Xe wine ath AAT | pial NAM Cel hl ey — ) 9 oe $ S ‘Y, ol 1044 FIFE | 5 | O 1} O | ‘a’ co © CO F 00 = ® Vv) © O fa iat ToNiyTel

The text on this page is estimated to be only 37.24% accurate

08/09/2019, 2628230, Page409 of 648 620000 Yd IVILNAGISN __ Case 18-2868, Document 278, ee Sty Senate] _agegy sre pp) FPPC feel cI © th Lap CBs pBMUO, juNOWIY _ Xe Seta Shy VY T\ joy obey “SMU} GUG LUO) Sj UO OU Aq SPELU BpUeWalEIS Oly HIN) Ayia | orm pISAI~ OKT? “TOH IN WSS “Sr lFiay a Ee ii a NS "Wa" sea WA 'AS BODE bat gd vil Be sa5 SAL i lg tgerd20W wu hwy g pe Feel cel, i prTwronows arantyctsrmii 3 Ba: Re meh tesa V JO AS A bl , BUS ot AG. FL. Ble Se Hg TANY I aga’ sc FV Need) f HQ snd gg ys scr |. h ; | ON Nome wour a9 WT We) hell =} b= Uy fe) ae mt J \ *) etoL |S | ae As Ae PO DL Ob kel TOS y 1 | th | Tae N80 Wo" 7," Gal) Isl i “| A = Bate no . eee ————_ ¥RN uopeaytuep| lenoy pus | —o ea ——_ VED essay JOqINN 12Ap4y 9 Anjedeg jo syu0g | Wesoay exeyy YBLITy aie

The text on this page is estimated to be only 38.78% accurate

Case 18-2868, Document 278, 08/09/2019,2628230, Page410 of 648 PAY a aA he | v| & t [OKESb| TER 218g 0} = —— ©) ect 4 Lg \ e @ “u\BI5 Fe 7) PUBMIOY junauily ! | rt al ‘a be | 240 reek brtolhes Pertoony a SPUR JE WLIO) S14) UO aw Aq epeW syUBWaLEIs ONY JeLY Ayd9 | as ~*~ Fi \s A ic Yih qaatnayisw youunwy 7 Ay - +stL ) J) te | AS wn ae (ls ASTL wae. ISBT (Vv L\e- Te a = IMniLit Lil ues leat . fol (| SANCRON IS WD GO SL a qS i) ot aH OC | | A \\ .- | ee - WD pa ree) | > Sati | . 1 my OT INET 1 WS" we ARS. \V N ‘Wwe VE |B ~ 3 ails Dag /\ fo 410 Cel Vey WStyAte ant = 3 ae eae x GNAITEN' FS A to ) baegs! Athy Yen ”\ 1 AA WIl'XS goo} ; AG WHS AdaG AS iS WH FL (hlal |. ee: Ys"WY"SE [pel J \Alis «WAN Wg A6Tl | 193 A159 LIA | OIw|> Seeei= re om IWR? Did A BAIA PS Zz eu ae mee UA grin) Za Be! AN “ys siupue jo . iiasineciaonal Nesonnghers ‘ON | UOT. seqquingy ‘samparoig feyuusy | Bia | eonyy URW UOT ED LCP HRY jBpoW fue | Beh EY wey | alEq

The text on this page is estimated to be only 38.97% accurate

Page411 of 648 Case 18-2868, Document 278, 08/09/2019, 2628230, eo Pp beer eyey ss %3| IS Jo “ 4, yey elé Qos AL ENE yr "9 " S10} ‘OTU) OJE WUC} SY, UO our Aq spe SiuoWayEIs ey} JEU) ASO | _ DNS Gol | aaq | Bc \ x a : cao (Stl me] tT RE | rns a+ RT WIG: SAL] doh e | ey G53 | gpl t | Ss z— | CS] asin NEG won | is — ‘ RIMES CHCA Santas SOAS ORTON MAG! nv IG nserowts : i er 2 ia WN vwvtaspall | all cag] i |e r c a WA Wy fg hnit S| AL] DYISbN] GpSi-9O1a¢ : ES ie : = A iG STH | Gt 5 S84 tL] 6geL AN | # Te : 0 29 7 Se ASW (OS: cc A Te af | arIob NW [KELL | bY 7 Te rT a i Cy = \_|A “Z LIMA SID da gl rr BO AY Wn Portal Nh wey dose eww wy B Gar ea i | STL] (4 Tie i)! coped | Tow Sh Wn TON Se : th ———_—_- —— «9 Grito AW ov tT OH, oe a) "} Ast \ | wl AbIbN| DhAl~D] (ot . 7 a : ‘ £ Ss OL | twieuf | ae ehinpuer| yo ON | unos —sa 3 ~ “AOBOHED WRTY JOqUInNY igre es Gils | SOW) IeAMaY @ eunedag Jo stujod | wey parame ee ar

The text on this page is estimated to be only 21.95% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page412 of 648 SSS PS 8,)}0y4 eyeg 03 391 QUBAOS JUNO eioy ObBg 2 zi = Lf WOT ya Lk a3 | gk veou Z Zuo TS Ina oaVINe>) eee Pe Muarmcn swe S 297 Tet 19 aving-awwa [97'S cr ae ASW '9 _ 3 nents arpa day WSN ite {erp ts lea\ wAtZS it0 Gs Ea LGS D7 vail alas 'wa'ti'o ~ (> ar _ pom d2 BNET AS! wh tons vr a — ee ——— WN = tayo ons hte? _ “CSINdd aan 2 se MOUSe? So Ren PD He? seit nn i cua LeisetoowW SAWEYG y'> sf Poo" &pistGaX No ipag — a FANisIIw Go PIE Oe ede squawesiopug ‘ssonnoueyy ‘squnp2o04g ‘SEWER ae —_————<— Instructions — = ——_ —_—____ wn ld RI SS anu} ase UNO) Sy UO ow Aq apeU SpUSUUO}EIS OLY FEL AYO | 1 \ x] \\ oy IW | SW ta | ak AL ADE) Az, Od. - i tot kateb one POP AT AN ee eee TS OF . = —~ on om Le ER me pmet pens Dm Qt A berry Path AN vita uJ 7 ° er {tray nyanee baer eH eae ‘ , ed Le od : c ~ . % opr * - “ <= a — J RT CALLE wen mp renner ns pn LNCRRT ee aha 1a wer > Rr ry by vag 11g 9 : el ; shea oe ie) of ee ~ * a , eh) : " J ieee LE pie diial hot dahl iain! ~ aT Te dk ae Rh eh ae ae a < eodiyttenrah Seer d eee had SE meaner ne A ee een. eeipecas vata eh IT 135 creel cotaiel oe beet inte Se ete tae eae acti eras ae net liens tte -— ; . “rth ie ainay cat EMMETT ein seman veya. se: See eve SUL bere) by ity ee me Le Py

The text on this page is estimated to be only 27.38% accurate

snipe ae We nlm atid Sr Arg Ea yer ern and ery . =i epee S DI aes oe o PT ere ee ae \ ' te =~ $$ $< . subs ¢ | a fog 'a\ os e16q ©} e104 esnyeuBlg 3, 0|ld ! = > nB2 > S Shbh “her previo junowly i o | (epOy B5eg "ens, Que WO} S}y) UO eLU Ag opeUl SuAaWO|ERS OU FEU AIHED | s \} “4 Ms “ag! WO SoS |FSe ' h| Is (mc “pros £% Paste] ASE] e nt hunffantetievel Pil AD ist yf othe is his 7/2tigg oes] | C AAL | pO, _ ow nC rennet OMS ee US| | CSSTL | MALY al C8 voswiaaw Ary 597 ley pe ee mmf a L AGI ) rn c +e a i 2 FG enn eras ih cahd b oa f * ‘ Poet iin we a neereeeve et eee aad ava . Ape ents ed 21! -z21/g0'=2 sl: > ve = , = ‘A 1S ‘gotgrtl DW > e >rn0b 8) ; e ze - i = EEE eee 4 7 e a = ~ oO UA IS Wellwn ‘eal aE[el ABSA) | PIRI N| WELD PAGING -AVIFIL PHEW LG | 75 AF SIMIAYABIID FTP LUE) |} ge SB 2 aed G3YINODY MSV Su Fol 1s SHO sd Al ELMS SY f C eT IVOWILUaY 10td JO ufaToie - JG LapN| L8h-SA9 ec _f\ 86 ae teint ler x ! i 0 | ST lS ; rn it |_vt jez! Li r > < 2 KO (Vv Ki 7 ‘ =¢) As! sy let w/e Sg)" e _ Wie 2) es WES . “9 | “l We = ) s}usmiessopug ‘ssoAneueyy . EWN UOREIYRUEP] jepoyy pue | —#r cup PME) aa fsounpooolg ‘cyspueYy jeapuy °@ ouNyJEdeg Jo S}UloOd UBIOLY men wey}! orn Sst? eo = = a Case 18-2868, Document278, 08/09/2019, 2628230, Page413 of 648 ] sy OL Instructions

The text on this page is estimated to be only 44.20% accurate

Case 18-2868, Document-278, 08/09/2019, 2628230, Page414 of 648 cel c © 4 99 ol wae Gg OF IFIOL ERGY Pave a cree Spree Bhs RBAUOY JuNoWy QS” S04 I ag Ph ee er 7 y OM) GUE LUO) S]Y) LO ew Aq ape sproWE]RIs OY) EYL AINA | . a -} I tT Aq lenez Ns2YOW Etaun ‘ae| Pb\ d7c Lot a "1,0. oe pe hunenire Paley ee ata A > ob | LST) Uy 2Tbo}. | = ST | ‘ ZT. ones PS non iq 4 be tor" tp ABIAWAZ wT Paving ove S =. ee. a PESO OLN H)t, Ww oa XOAD ABD) 1h bacon ines mined Sees ho] | WG-72 | AOI Whe EY pay trmmgwiin mh WD) Wy _ADIAlS Ss) AAG CORO AOUT Iran \al cnar WD cob) Dah — pasty \. OH 437 a Ww) [aa | Wa 5D WO pal [Mode | SST! WS Leal | As |# [ASI 1| MIDS MOD | 3 es Mmo97| ol _ sal | ay | M7 | SSI aLylt My is VOM WIL Aron NOH UELS HTIN9 AV 4 “1Se tstL | Fao SXbob anirates | 19a SAE st 4 | te. “PASE | Bes a ir oE. SGd31) M99 SIsobN /H(¢-c7L-G >! Ww is St FL Pt UOT PAID UL aL sBupLE jo sywouessopirg ‘Ssaanoueyy | “oN | UNAOI, oe ! a ‘ eV LOWBoyUGpI BLOW pus | re ~*Assleyet yWesoay smeOuNy *Saunpscoig ‘sysewoy | jyfi4| sexy eALuy 8 Gnpedeq 4o SiUuTOd has SyPyy ae ard Instructions ne i tl —

The text on this page is estimated to be only 23.59% accurate

SS rt tn oc SR Finn wei 2]8G 08 J)04, y \ “GINIBUOG Sy) 4 Puno, junouy ‘ “AN O16 WO) Sil) UO aw Ag Opew sjueWweyEys et) BU) Aled | Dl hy eiyertat aa eh Ut 4 wae resdecdentdigyitidaddtouinmbaned Leakha tna lines tobiote dadetaled bic: c, - . = os ae TT . =A. os 3 Manny Mamie de hi oe Cont Nps mespeery a bea eet ad ete eT Biber AT le 2 Oke ne tie hal il bl Ris eA ee seed Sk eh ehh | plesk soe EB TG aie pr — ny" : fae ee | _ — (ery bey avon) Ue wld MORON Srwig nln +t Woseto} UNV? ert SOL (V | Mtg bE aue Lina sp ard yey) [71 Lyw737 arses) | Keel — “anvawerd WO Gace 3 eh \ Fr UNS WS) par Vase Tate] Ab | ABVABN DLS) VW Q Leen aes | |S TV PX ; ‘yolem Wits el onal em eteehadhe re oh mn PUT tee oe OO tye! a, ee we bey Na ey gata kn, tact aaa) 2p rs eee em aed en a bese INTO W/O) WY NE? Wed | 29a Bisley \t inte qd yy NE? OL! | wx AV, WOlbhN. AS C2 AS =P ax'70| A | i se not cpadant 15; AE os AMD) Ak | i (> snr Sei estavon bmn 7 asl. TSLL . = = IA 77 VBL Any : _ eee Secs ae ~ LET 990] 2rbobn wee J * MATES spIAN ZL 3 55% URS OREM Its 1 — ve pes gains ons nv Fer ONY Cet Z- OSS WOUL Nae > eS [See eee Wisner Ses en | y” re aa COG ‘2x. > WTR Aus AD henenys ee eee Gican> Tagw #4 ~ ginairee wW E206 Larry u> mv Te ETI A UPUON GEN INU OVO [Korea unyes enonetoagiul etoyn' 3 IRIN WOR RO\pUapy jEpOy, pue “Asohayey yesoay ROUN ‘saunpe dos ‘Ssysewey | YOi\4|) sony yesoay SHEN Yeon instructions

The text on this page is estimated to be only 27.47% accurate

FEC FF feiOL piemuc qunouty mo, ade Moy T) j TD -CaYYHOR wrt aM e Jord o> ea ae "Grete el bem Linn th tov gow Hid | Ho at | VADISI AMIS | HA —_—— er pt > ¥ 8 oUo- oud O25 Ww eAoW a = 4 tWIVEXS '9E. oslo WAS PE va w'Xs or ot wa ys! Ty wa'saPeD 1S ‘WN 4et | A 2 QvienD CRA ; Nia f ee C Bhi { “i Aw ‘YW wdeLlL DS Lj A FTES I sodA ame St sJuowOSJOpUY ‘SJOATIOUaLY "ON | UMOLS ‘saunposoid ‘syseuey | 1Hi4 | SOW Instructions ampubes S.tol4 Ra ac? ohiiet eta arr che ye mtn! 5 Leper —» G Gay | wits) e179] hy, et mand ‘ 5 s as * be weal pe oye Lieto todd ian pt Mea mans ata ee ae ee = Boat, Bie . 2 5 het daha Sn edt el oak ahh Prete mines 2 et ke ike aD ee es en yer oe DTT rae ere ee AM? AMT AMS 179 | NG LOL-9| TI vA gue [woIbna Cabra \c Waag Wada Odd gos] BMS] | ynF ZO Ga ae RY VOYPOYRLED LpesaU fy jBpoyy pure BYBW HRY 879 $0 9Tvabed ‘0EZ8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 34.41% accurate

SSS Se A ah my 800d @7eqg 2 191, pueMUo.4 JUNOUTY fu}, G12 LUO) Sf) UO BU Aq EPEUW S}UPWOIB}Ss GLB YEU) Ayes 7 oe jeyoy Sbeq ‘ i ee " . pee Ie PAS QEU WOOP agATIG? MBPS 716A raid ee Paes : “Slams Bp? 1ueel on) i= : : et — | 413803 Dn > PNt se fy , c : RS Een JIL TwiAsnen !D MSIL OyDIO 3 = ~ : > rrotts pew oTKSW OLS) “Sat dig Adon > § Ieeg7ihay| GSP ane? rnp d LNG S aatan? i 3 Be WolLs>s t q ' 3 | er yan tue ce: geet Fen Pew SU als Weibel Maha ga d 7 “ ersanteres a " Osa Fasc Fe . Steg pany Per 4 role ate 43 spent, Stk. 5 tay! Pers rece paomere set : ars eae ij aol a 1h b= Sat Ss AoW? 92°98 | Ae | ZN ! Se Fa “V7? bh : |B AT LIAL dons Std oLIhebl, PT AT (nasa gons wredd OLS QP OXAD yma | SIsobNn ate lzZ-A] 3), a5x | SXbobn] arsil-ol<z 1H 0d \h A Ve —<— \\ \\ ee MeLu-D] Ah, QO Fg jeapoW puR SHE eso sb ne | sjucuUSeSss0pUy ‘SAsAnOUEy ‘aegnel ' ‘sounpesolg ‘syseuley | G4 | Ser ~Kiobayeo WesaaAy f a , ; AL , yo i - ‘ r ‘ “* 8. ° yc ve kes ‘ Leia oe wnt Tm tee - ra eenspns a ‘are MPLS Rip POR A Sarre a 02 | Wenn MR oH See me ni Instructions _ i 879 $0 /Tvabed ‘0€Z8z9Z ‘6T0Z/60/80 ‘8ZZ JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 25.96% accurate

@18g 03 10] ep re GINYEUDIS 80H PPAAID.L UTD SGT Re es "BM) S26 LUO) S|y} UO au Aq spew syoWweyE}s ey ety) Aen | sew ea —— t [We Asoo 29S O18 EH E\-1 | ‘ 13 - 2 4tHO dry i > PADIS PA PA Foul | j ey SOL’ LiL) iN A —— — Fo St REDD KOM mor ~ dor arn al % Y N| ¥ hs! ) -S)| b he St | Py, aa! aBr te ISBObN H1¢-Czl- J} 7 n AUX ORY TEL IN inTiGS ANGST HaGd eoxJa ‘emwes ooxms 1900 fyaned ULaen OR La > | * M a an Am FIND Erp GLOW OAS We = : TE 27WU>'UsthId CHRIS Creaod Ais| 19d| elenowds| +59L-1S| F CME. | a IN FIGPL Mags” e '\? mL 7h VI 7} E-csS QNINEOUYL FP7a04 iia XL 71-78 rI- 7994 Cl- OSS IH g) fags , VE shuypury jo ‘oO : ABW UO RO FUSPy japoyy puw “"hsoGaje89 WEA sOCUINY Wi re Wessuyiy’ BYR) Ruy 879 $0 BTvabed ‘0€Z8zZ9Z ‘6T0Z/60/80 ‘8ZZ JUaWNDOG ‘898Z-8T aSeD tte Tl ieee alee CAINS bee — or Ty semahn a bee renin vie he we - ir Hay feesteset yy PEE NNT ete te os saok LT totalled heh Aelita oe ae Paty yee Ni foal oy Lh pipgundeih yeerhelnatt viertret eet ee tL ak Co Ce ny - et a, + Jartilearr net ’ d A Se ne eee eee Or bende’ ; Myo ea ee a LT hate eet Ped eee ete eas

The text on this page is estimated to be only 32.29% accurate

* SIMBubyps 8)Olld s7hq OF FPIOL RY pe | pyeMa04 wunowy }AOL Sed anu} a6 UO) Sty UO ew Aq SpE SjUWUC}EIS OY9 FOLA Ajqued | ©} &J —_ Hy Pit 30 aA 23 nl el Mikal el: Ain s Leth, : % q etl) DIbWN| BLSI-D| at mane | SSBoLN] pit-@ed} 92. S Menkes ay oles [ican oak Ra SS bIbN| Absu-9/ Sl Irag | sS5iL | arQoyN| HR-ALS Ee) [Si\ SciL) w9ibhN| Uoh-trtd) By jepow pus | ee ayer perce ” < as SES, Teh ———EEaES $ > * =. f = a , ie — © e = =~ ~~ . x F 1 sJUVMesVOpUg "SHoOANSUEY ‘ON | UMvol ‘seanpenoig ‘syseurey | juby4 | Sel Dee De Sah is irate re oe] 8 ere pe VO MIB) UOMEOINUER) LEsouty stuypue) jo IGQUINN SAVY WRIST y ‘ _— PTE RR ALO Aer By eid ae ee eee ® . : / nt har pete remy 4 “ Bem | Vy yn ey tmhans.ah arr inm pipe ietminte sper ep letered badld ANC bal pind re 2 ates al cit ote ald er ae ee eek Instructions 879 $0 6Tvabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD

The text on this page is estimated to be only 27.30% accurate

e389 0} Je) ; eanjpeublys 6 ,0}!¢ MeAwo4 juny J (rio, e6vg ‘enuy GIB WO} Shy UO Bw Aq ape SyUSWEyRys Ly) YEU] AsES | tdi | Act st ea | avy ri - a ated ‘ a0 Cae ee ae ee Vex we ay rm Ny vey oft t v eA, a ' el er re tees : : ' 3 ie ' ar OS itt i TTT (ay ‘ rho a hae strl pe Py runs > Ls ahs " ; te i ae May ; 3 = A a SS1L] BE&bI_N!). gbsi-O] 2 t — 4 A NV) filel2@e-g[ 9s <a , i SZ : es | =Qbsi-d} 3! YaATns |i siuipuey jo SiusUISSsJOpuUug ‘Sieansuey ‘ON JUMGI4 jAPUW Pue ~“hanGayeg yesy JOQLLITIN ‘semnpesoig ‘sysweYy | 54 | soln eo Ytoupy a wen A Pe tee » Pe me NCTE at sti Ae SNP cA A th ly : wt re . “rely Gere mi ~~ : Nai Ay Ge: ALUN TS NC cA PREM HI TA NR RN a 8 fe Instructions 879 $0 Ozvabed ‘0€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 39.30% accurate

ELTA QLIT : 3 pun ~. ran BINJELBIS S30|td ! a ’ ; (> | | 4] A | Trulpejocre =} > ! . cea | OPA! agGLJ>Sb9bN] adbsil-9/ 9 i |) BOA! don] FeobA] Me ULGg, - ft Tae | SEL % + = Ha a de 2 Z | | ee rt | LZ bape He bi =e ~ by ide ee s \s hy 3 ie + Ss le 4 os | Or 3%: » AMT | ATLILN] BvUsu-9/9z rae ND Sabo andzaUD bee M v4 u s\ 4 arternpy MDI VANES? Mota 4 3 r CI VHIMMEME — IKD7 : moN?- PAU zloy > Hs Ib D3 ~eew2xuy es - AIR PEALLW mDYD WOGSDIO DOL EDN ed Fe OH FAPIDUWP UrLOD OMP-APLT ~~ ee oy ” Tae oy 3 & yeletowrs| 97-7 al 9) ¢ y {stl «GPL il vt {\ | Ovi] fot 4a itt | Ses) Gal] arbobn| Gpsi-5) bz, (Bajay 8 Canjsaedog yo $zUjod EO f o OV | UWOL4 WSs | sem SJuUswessOpug “SsoanouLvpy MIE UTE yuep| ‘seinpesos ‘SyseLuieYy YROINY JSpoyy puz OVE Yesouiy Instructions 879 $0 Tzvabed ‘0€Z8z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD

The text on this page is estimated to be only 26.00% accurate

@72q 0} /e}0] “rH yao einyeubis S,J0lld PUEMIO{ IUINOUIY IC, obey ae OR oh EA 1 ree ee 6M) Ase WHO) Sil} UO BU Aq epRl sjuawWayEys OLg yeUy Ayo | “ay Lys 9 Bey a ey. * rie ies Wehr ENE ; ihe rete bet) = = Fett oe + = se ee Bs pes ~ > WEL Bots shee TAR is eee ty ho | ae “ee Shr Sa +. a —— it “<3 wee ei ‘ \ ~ 760000 28006 eee et ee eee et eee bray porte eye ie eet eet yy tee oo “. 4 oy ere Stee " ‘ a anes 4 ; rath leita shel Aad 2 i Ce " Se eet is er es oe ee ee ee a ene ee ” ri tact oa Li its bs, amt ’ : ' Sete teri rytitenter cris Sra alr aL Hemel sBurpury jo BUOCWPsJOpU ‘SJOANOUEW WEY UCTS Quan BpoW pue JaVUINY ‘saunpacol1g ‘ByAPWweY yeioury eye YRsury ° + 8 eT eT Re mR ° st ies ceil ‘ y rT . tobladepract swiss sidan tempeh ie Aine Instructions 879 $0 czvabed ‘0€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 28.19% accurate

| how 7 PuBAUO.4 JUNOUrY (eyo, OBR ‘ON O18 UNOS S[y] UO ew Aq pew s}ALLayE}S SU yeLN AjUBO | ca = bn? 19d 19g | DUbIbN| DLSI\Iw | giw wrens] ae- e-g | | Ted | VU EPOLN aes 40x a aM XG det olf Ab AL | ZEON) 9 pst-9 | FDA -wadr well Act i 9% L9A- AQ] &z i iy to i | iw a pe 1 ee BLS D| Sh, jopow pu | ere ————| sfhuipuey jo Laila bean SHE YOY | instructions 879 $0 Ezvabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8ZzZ JUaWNDO ‘898Z-8T aSeD ‘ - opi eh omen rrpeeahal hens we erent opr eancesey ren pean bee « A tee hee rye ed evcogels in ee tps r Ay ft aaedpacmnpl Says eq PEI Pe taba Rte ar Tease here hari ies p Pre Tact tas Sette d eNO Made Ue Tene . ‘ oa a . s - a att ‘ Fae 7 BAN oe) NS See ete tetera eters te toe as eo ee er LN ey oe ee ee nt ped ARNT Th eee een 5 Sete! yn ~ “ Se ii . Coe

The text on this page is estimated to be only 25.62% accurate

$i CLNI¢/¢ bos pelettiae Aq Aq “1 or TALIS NI oi merci t ( a Wet m~* s PMARIGS BH 17> * OwiPyGsd = 674 as owteW ds dgis of OLD) ‘see7H sd ren HOH APHIS I WD t-f “FDEP WAY OAs! VIETAIAY “AVIV AT corns Cs 8 shujpuey jo ' sjuUSWass0pUug ‘E1aAnouLEy ““Asobejyeg Wtsouy JeQwnN ‘sounpocosg ‘syseweYy instructions = my p rar” : qs" B40 “SPU} AFB LUO} BYE UO BW Ag BPE spSWwoyeys OU] JEU Ajo | 9 we is on fic b\ 50 fa 2SbILN!| AbSII-D iv 36390 bN Hli¢-lze-9g Be MT-LZL-9| J, I ) MIG [BIIANYS| DbSt-D | eave 19) ABOLN MeL] Ey YJB LORD AIUODY WRLOI\y eXPW UBIOY 879 $0 yzvabed ‘0€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD ‘ vaje Sc17y SKK) A tawp im yin Areren ary aameyvigs Py Reey » 1h re 8 em ry are OY ert pry & oh nie Peete rch id thesmamend tems ey bry eb , siptuexbeta ocean) ihm st ale P haent ryt. ae 4 t a6 : > oy HS a Ki ms : 7. > ts on * 2 = ae = os = 4 £ . of% be ps ts: re a oa Sd EPS eae UR) ther hy r Pa a)

The text on this page is estimated to be only 41.58% accurate

00 ra < S50] “tS? L | an ms *s “= ’ . a = 2 =e = — ~ — — ee ——— en na ni eB CFA ee ee " i an — ee ' . c 3 cl\ ¢ & od Cg ae L rr : “A b9 78g CO} pezog ome i ee = —+-—- = iy =S- % eL t 37.3 ee s ba | ; i — _ hobs PJBAUOZ puny fem OUNIEUENS $104; ; eas j p /\ (Fi0, abe, ~ : a de 9 2 ~) : ‘any o c + SHB UNOS SIU; UO BWW Aq apew SUSWE}BIS OY) youn Apes | ae oe dd DOA AYo “i SC | SOA; AVoLMTA Y = : T9g° aL ee 7 ay TTT es | | | is A] AI | | z | | | | T ni; re : = 2 > — (0000 “SG -FAAYEN ee 5 ee | | | | | — | | | \ | 14 aLS\\-5 1 vypo | SeWasrOpUy ‘ssanouey "ON | Uo SOINpS Ong ‘Samay Woy | samy EW VOURSY|Uapy WEY POW pe | OIG CE mY yuy | BEG

The text on this page is estimated to be only 39.71% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page426-of 648 ——_——___ eihg|s] FLT HhLTZi\a ILS (=a ] 7 2 5sB{9 pue™ f m0, vhty } 9 POLAAMW?F cnowmyu THO ‘6M OJP LUO) $/4) UO alu Aq opruy syuaWeye)S oy) FEY AYES | SSUXOgOA wae | x A Ln s iret Ay WIT tA . a gegicts . Ze hey Iwonined a3 | ~. NI ’ % IZ) , BA * eo 7 Lt 21 VAuWas AAS VOTOUT E : AsoGesgey yesory jos! del h ee | ae \s YI) 19d/2bobn| PbS-5 1 z, ay MIBW UOTPIg Hap WRiouly ae 7») vA | 1 sSujpury ja SqUsWeKOpUY ‘sza;AnNoURy “ON | UMOLZ | JAQULINY *‘seunpelzoig ‘Syaruloy W684 | samy jEALMY 9 Sinjsedag 10 spuod Instructions UIMBUTIG BOI at a te i == . : ae ; Ses

The text on this page is estimated to be only 29.31% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Moca of ee mpl Nara ra, ew hts anh Se RE Elz Pi kay era ee ee ER aes a Chih ’ We teed Pe : : ' een AE lets aiThs ey SCOOP EVM ate eels fis ath + . ~. : Bn! or entt 2°; onree 618q 07} /#}0] pIawdo4 yunowy eyo, oberg eSuipus jo “AanBeyed yeso4y— sOqUInpY Instructions SjUswosl0pug ‘sA9AneUuEW ‘seanpooosd ‘syrBWwAYy ~ tu _~ PORT EC ©.)0led "Nd G12 LO} Sit UO Sw Aq OPER SiUeWATEIS Bt yeUy Ayqued | it 1} S\ ty t+ Ce UC ay | BbSN-F| ane WWD| <1 Se VON) HIE-C7L-G OD a 7 LYY UORBOYAUEP] jepoy pus | “tr jenuay % cunqsedeg jo syujOg WeIOMy ayo yeuory | yo . —— ony moe'y ret rene Pen) my OTe tret =m oe) ewes tee ete De eter tone ; » es $2 i. + t+3 ; eae Fee " Up itt ss ie a | ts5 re ae $4 £7 . = zr _s —! . = Fie ii + 5 i = E : ; eS $ i 4 i, = : = “s na = : ee ; te Se Ts 1): ee i i il _ ae eed ‘ es es ee hoe

The text on this page is estimated to be only 33.37% accurate

slg sisg|g) Vt | 8 = \|e]< [AfreLs tisld mrela 9U 7 ed c] aha 184 abou 3 ope re Meg OF 1FjOL nein ne e2BUOIS S04 » "ONd} GJE LIC} S{\ UO OW Aq ape sjueWe}E}S Oly Jet} Aled | tt ; — ie me Gel] weg] uw [| nu g , LLaWD f yo \AA\| KV So035 mm Soo O59. Pa ented ———_- — ial Sey 079T",, i\ 1 394] ¢ . : > = , hapeceehd ye adiies Fullh¥ihidors © pakeree ded re by bon, a praia Laat” bene thant amas aye Ny iden = N A SGN UAW ALAG OL ee AT ane og eS Lore tee o_o 69979 0 AE Rr nen ry * ‘ p peek es a4 Pt) ahr. Sees Or rs ee = As > ioe Ae - Be = . - = La aa ast) Gall ——w | 1S r Re THF | = YE gal] i150) oz ob A keg ica 1909} bs Sho CV Tb ' eT A wo , ye EG Br ree Binet ih Os ements etn by 3 oe 4 i aang Ans a es es ee H ' ten ieee Ld ‘ otmperete has Pie Lae y'y ° 7 Ope eed are % Poet ee ee Ne ners Baird ete eines f earereied Win) Tale oe ee ff we] TOW! THD. ernst] PP al al at SW UOPPEOYNUSpY yeroaty jenny pue SyYe YY YR ““KavGeyen jpesosty faQuuny ee “a 3 en oe he Instructions — : , peat 879 $0 8zvabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 27.14% accurate

Gase 18-2868, Tht 14 TTL 2628230;Page429-of 648 Hs | NFR lhe te HN ARM” - steer drm ob sary act ( , erat ssi W + e i E ‘ e 2 ha LS aie Th panbeeg= ie Mreeds ee 81. ‘ bs i f . Pe Miarsrcer Oe ra Lu conase raha) eae a or) aaa , ta Vas Sete tee * Poppet elas A! ip hel) tay ea oui a Hh be © ; 7 ay = ys.) ue Slee) rans : . ’ An ? te Vy aT eS ae: ow 4 il tl F <— u + ra ejq, efe JG}OL BLES "ON4) B38 UO} 8/4y UO SW Ag epeWw sjUSsWoTE]s ay) yEUy Apia | » gl fliele Cs evea os wero EET Samus 2)0Kd _ 7 (9) fg) pees ws — kt | OBO | Sal AoUN) desi) a1 CLUS NHoS | POL | ZA |VOsESW/SLSW- 9 ey a SE Gah every PTT b== tl = a afore | | V1 I9g3| 7SBbNTHIC-L : 3 5 yy me Ub ; - Es ee oe aed DPZLbobN WwOs4 a0 Th squowassopuy ‘ssennoury | “on =| SIBYY LO|BOH UBD} jepow pue | =r yO jeAyy ZB Ginzyedeg jo sjujog Qe OW YI BIEg sGujpury jo “"AsoGeqen yesny Jequunn ‘seanpesoig ‘sysewey Instructions em Se ° a aie wee gh new ae + | ~ ponewsitiatencial seni ttsanmmarpomenhinisinsionrssnayar serie icra unin taaed Sevan i RP ip Ace nhetenta dyna eee ethan Ve Male eee tray Prd ian ener ee OC SS been Sh itinr aii sperms eoweh Naber 3 Hi yy Pras YBa bp pee ee be fn 6 Vig 8 Pare 9 ar 0 ly en dt OAT RAE PME SIE ADEN hrm eee NINERS Hee Votym de Ory 0 ~ re Rhine ou . “ss ~ . —_~ Pbs\-D| bz SNS a et Oe laid“ i.

The text on this page is estimated to be only 36.17% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page430 of 648 wi “| 4 ; oli twas ener 6 2s " 1 and aaa ae eh et Peart yds oe si Me Dye ee Ca eee etal mane ta yy PPA ed een i INT Go rete ss ie yrs ars o> PTL all . geet ty be renee MIT, ‘ T | 001000) 7a sare ; rages ehar aes «i batrsaeiemgpe etait eualinieconacsun it Siete) eee ee Dn EF asics eee omer ys rear a hy ee Ss 7 xu! fejrA os rt rt tnd Be RN ee OR age ne NES ‘ ' ir Y | anon YouTI? : ol — 222 bh SLO Ene Penuoy JUNOWYy 2320 ©} 72101 | ¢ § \scel SS AR OD ™ Su) TL ) wd US e 01, obey | ‘ONy) Bue Lud) SI UO ew Aq epew s}LeUIE;Dys Si) EYE Ajqiad | CJ | AY yyy Phe pues S| | oC \|A We / \\ V4 aay 7S [PbO N GoSi-D| fs Yd WI shujpus jo “As 06oyep Yesny SOQUNN japoyy pue | — e+ OB Yebuy eC] xubyy VORBOPNUep] Yyeouly “CN | UMOL4 Bid | SSuN 8

The text on this page is estimated to be only 36.12% accurate

‘uneubis sjond ee ee J) A | ST | oO "~ © © 5 oO a | orate i b= oi | | af oF Boi Tad DERN |AE Ct QnIa 9 SY WIGS Saenetaiemmnneteal ined a | Oo) o | fate = 1 a= So) wyssse wie 7 ae liga oF Ao Piso “Rees co OONUA COSld nz pSao 3 WAAL mrAirs eGujpus jo sequin DIAITD | V7 b ““AsoBeoyes 1pesoay HIB] UOTOWIUOP] yRudupy mW aS. mA ssvio 5 pue™ eyeyy youry | 9yeg mts" yd vb MS ibn eee ae dg Bett 1 pthoatew tad bek dt el et teeta Torey 2 Mey ores Cortef vs eet py —merTratis ei vs Ste eT eT i eee aren eerie oes ae en a See el ee een a SEAT OSU CT a Re Viglen piney nda ia 4 ee hte 4 ele 5 a Me hed tit —Case 18-2868, Document 278, 08/09/2019, 2628230, Page431 of 648 ~~ Instructions Peo © eae ae . AA te ee

The text on this page is estimated to be only 37.76% accurate

2628230, Page432 of 648 Case 18-2868, Document 278, 08/09/2019 ozy | shs| 4992 of WLVZ 9ES\9, SSH|S ILVE b |"We *i “ “A/ bh) cm *“ xe nile Bae MIPUCYD 1. £ 7 ? a6 RN dae ee dacs apse we na sae A a! ALP melee | IO te ler Saale abe wer vita J ‘ “ oe! ¥ z ‘ ee i . t! (ploy BHsy apsaide— Uae oe i ee ptt bee ‘OTU) OAS LWIO} SIL) UO OW Aq epB S]UBLWAyEYS GY) JEU AylGO | i \\ I Peel eee SiS ONT WUD - NOU Y Z AYd DOIU NoVN> NI01dd> GHIOUTS | Go't-LtL-9) St rae i “a 1 oS - r bli ——| sfujpury jo “"fa06oje5 e44y JEQWwNN HEN VORPU ep! POW Pus yesupy Bey WesOUty t Instructions

The text on this page is estimated to be only 39.31% accurate

—Case 18-2868, Document 278, 08/09/2049,-2628230,Page433 of 648 StS Seis My Wr) ties ti iil SaaS sph hal i boas HEE SRA tei aaa a a i SWUNG. ay -oens 4a ne 2 ON4y GIB WO Sj UO Glu Aq epeW spUaWETs}s ey) JeUy Apes | Co one by lent ae Fon Rive A534 | on cael OS SHhovsay sw3 | DEBOLN| Sysii rs W9\bb Sey et A Rall eer orm Mg Np akan ely | aN | Ohl aymeh rye Mena NAA mm le pete tpn games ha ey met . panes PaaS eew Ni aS Qw70 hh aoa SPL Wenres [Sbh ANSOOA rage “) ee ee ASTRAL rm CANWSR wr t- LZ S SILBWSSIOpUy ‘sseAneuEW ‘SSNpI904g ‘Syirwey AJMY @ Ganqsedeg jo sjujog Sara Ce ena eo neato N, |p ailahedtoisien ieaahaharareidiedhemmmemeetaches dake ied opm wh a te BO tt ee need ee reg PO , . SO eer ae! einem nee eee) me rooney

The text on this page is estimated to be only 32.80% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230, Page434 of 648 ’ . : eee = eee er ee = sear dina eosin Arwen abn dairy rata yma elena entinas Fiver e Sa ner Fe—Tme B-Sv ATE ne aver r = F9BlIds = “91 0 | | Q/ "Lhe |S] Fem ae | ™KaoBsyeo yey 5939 oe Jean = Instructions, L9b IBN, jUuNOWwYy | qth [BAI] nae qe | 7M Syeg FF 1219) NI get T are iV) /<\ PULTE VRSORS WOH ABBE A \ a ave wisia fejo, ebed Ansar" Zi 23) ‘| WICH = WON ID VAT Al oN US SM APY >. . ' uy wowsy Squewesiopuy “SIDANSULy) aa -- a i ee —— Pies ‘on ‘saunpoooid ‘sysewmey e San UMO-4 oL teapay @ sanypvedeag jo syupod —_—_ FT BIMBUELS 8,)0%ld . “Ons ae WO) Siu} UO ail Aq ape SqUGWayeIS ty) pely Aye | a7L | Od bstl |= ‘i bObN yA 4 oLS\-9 —¢ 1 IW JI W | Wkowts|/V-LTL-9 | 9% G2 |aSbobw| AbLsi\-9/ By 9d31| BSeROb IEW UOQeOY Uap] yeroury KIG-LTLD SYEYY YRS st Ww Tro TC ree ete yy tec = Ph wed ner per anaes tee Neo a a wy g Sol Siicarcrty en usenet ont) AY) : maar ere a eS etre ON ee eee a | per terri iis Sa ' rea SS - U +7 ner ycter ny Pieper Kay farires arb aete . (Ap ameter y ep Fa wey TY cy Sat ay pe r Y * ‘ ee | + oe eee — a veer Nery SO ree ae

The text on this page is estimated to be only 30.40% accurate

Case 18-2868, Document 278, 08/09/2019, 2628230,Page435 of 648 TT ae ee i J/¢79 |! 0s 07%Q 0} jBIOL — $s L = | Ay Ob 4 BINFEUBIG § Old $ “tbo! ' PutMubg junowy pew (nyo s6e, "OUL GJE UO) Sq UO ew Aq ope swaWwe;Zs ey) yetn Aynuse | igd " \\ \2 IZL| SobobM| Gbsi-Sy Ly 7 ah ae ailiee Cad lit PT ye. Se ad Miata eel late tu, eee a t Ye HDT ITTY Starebpaton Hs JarT eke bps Loner tt Aww met ome #4 J OD nm 5 Mrmr tae ‘ = bib eieiecate et ee ae! | Aa HS i ed i a nee eT TE TS hab Nn Man phones age aoe il a +¥— pee map mM an Imet WIL Stu = 2d Sige | AD _ovsnewonervow Dd I | TW 6 palynow ts! O7-ZL-Q! ey | a _ _ NM —— AON | | _F Zu. | : — BbS\\-7/ oe . ice = . aw? e i oT Sy — lg Wel , ft: i | if 13 i | 74g os ‘et ia ' aT i ‘ i bet ’ = ‘ . ny ie is it :* . a - aco fot A ots ams ere 1 + tha ; -, r ihe al dead behead ; aa Yee kT ey ee +e me ea Ah 79 IW "9S $i OW IZboL | ALSN-D Y —— = —— 2h) 2k SGiLpure) yo ssef> pu “3 S “«fs0504RD.qesO4 2s ' SJUeWMIeSIOpPUZ ‘S4eANIUBY] ‘ON | UMOI = oS ‘ iv ie £ yy uc 3 P eagle i E quuniy Seunposoi,g ‘syiuiey | G4 | Seayyy IFA}AY 2 Gunjedeg jo syulog “ Se eeu sent may

The text on this page is estimated to be only 33.76% accurate

ti 7 ; ¥ on , = einyoublg 930d =| | eyea or perog | ; 73 3 Fl paewucy wwnoWwy . {ite ‘ef @JB WO) sjyy UO ew Aq epew sjusWweye]s ey] yeUy Alquad | j i ty \ S i be gage Ww 42 Sil mss 9) Me bet = Ape Pied eh metal ae ett 2446) oor 17a) ght beara rveten tt me a sme - 7 - te < w eenth athens —were § Panehinnaeerethdiba sed oq nerve eet AIS DOr HUE I TTP OEMS Se Orr et ites ee Pek eat oe ad) ee ees: ws: » 3 Pps etm he Sah my sma a OH ee os >= ET? gee nd epee 4a ke gh patho Mate eee ee yal ae asta 99: ve errata \c-w vet ti ‘ ‘ “ar ' Se BO aks « aay : SY SS 7 FNS KITT pm, ; > <p—e+ - U epee | eo) ene te APRN RUN EE) HE Rm mm mime teh ae, +d tomy wen i= J J: Oe aT | O eA eet Date ee 1 at | Ad m0) M30 | weemvds ae 59d) ALg0¢ ! Way) vo oyuop) j@alwey @ qemyena jo Sjulogd | pesayy Dro Ce Qwes|,. " AAC i ON | UMNO w6y4] sony fr en er Ee gw Te ee ee + ee eh oe ee. Co te Te os +4" ISRO PLE axe yy YRLIFY Squewess0pug ‘S~cnneuryy ‘saunpedtolg “SyumOY sOujpue] jo JOU mie a Syne d os at x .

The text on this page is estimated to be only 31.25% accurate

HHH — at or EE _t ' ' } 4 WY ee {9 50 , " paewe. pinowly , ' — “3 ) mi C7 FSS | ae | | bf > pero, cGy "OPU} G22 WO) sf) UO Bu Aq BPRLU S)USWa}eIS OYL FEY! Ayes | = “a | siuppuey jo sjuowsssopug ‘ssenneuey Sa AR, LOPEDY UEP} ~“Aa0Go ed yesony 4equinyy ‘sOunpooosy ‘sysewu09y jeapay “g Sanyandag jo syuU1I04 YBa 879 $0 /Evabed ‘O€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD ‘ pd tet 1 At tert deme er ‘ prey 4 Serdend HS od Sacetret ey Nels ee + PFOA, De te Ary Only A rah Reet or rn NY TENG ve” t. " at t) = tte ‘? \ is oe riz itm | +2 . ¢ is i: P+ tt | ie | + i ~s »* ’ ’ it i2 1 tm | 4 ‘ te Fy3 2 Ee J F 7 | oa ; 1 ee eS > | : } z= “3 ! + dot ipa bate fanidl eA he Satis ee ae ele eae

Case 18-2868, Document 278, 08/09/2019, 2628230, Page438 of 648 EXHIBIT CC

Case 18-2868, Document 278, 08/09/2019, 2628230, Page439 of 648 Confidential Page 1 UNITED SIATES: DISTRACY Cour? SDVOUTERERN DioltRIcY OF NEW YORE CAoe NO. Jo=CV=O07453-RN5 —— — SS a a a a a oo a, a, a oo ol i oo? fe fo’. fe? ee? Ge See. fe ee fe? S| x VIRGINIA bk’. GLlUPPRE, PlAuntat ft, We GHISLAINE MAXWELL, Defendant. a a a a a a a a a ee xX June 3, 2016 230) 2a: C ON F I DEN T ITA L Deposition of DAVID RODGERS, pursuant tO NOtree, taken by Plarintatt, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Pubilte watlhan and for the State of Florida. MAGNA® LEGAL SERVICES

1 doe LZ Lo 14 is 16 17 1L-3 1 20 Zak AV ae 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page440 of 648 Confidential A P P EB A R AN C EC£EL 8S: BULBS. OCHIELbER «© FPLEXANER, DLiP ALTECOrneys FOr Plaintiis 401 East Las Olas Boulevard Fort Lauderdale, Florida 55.5 0 Ti) ale BRADLEY EDWARDS, EoQ. HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant 150 East 10th Avenue Denver, Colorado SOZ 0S [ol JEFFREY PAGLIUCA, ESQ. ALSO PRESENT: Sandy Perkins, Paralegal Boies Schiller & Flexner Ryan Kick, Videographer MAGNA® LEGAL SERVICES Page 2

The text on this page is estimated to be only 43.62% accurate

10 11 EZ 13 14 die) 16 17] 18 1 20 ZA 22 73 24 de®. EXaminetuton by Me. BxeamLoeit. ton by Ma. Further Examination by Mr. Deposition Exh ab i Plight Logs Deposition PHOS Deposition PIHOEO Deposition Photo Deposition PROTO Depos 1.T10n PROTO Deposition Photo Deposition Exhibit 8 Exhibit EXALbDLt Exhibit Bx hh abe Exhibit Bxthab2 et Case 18-2868, Document 278, 08/09/2019, 2628230, Page441 of 648 Confidential Confidential list DepoOSsdf2On- Exhibit. 8 Global Aviation offering BG) -S MAGNA® Page 3 I N DE X BOWL Os £4 Guan eee oe ee ew eS 2 PeCGiligGa -4 44 eeetwen teehee oes 209 BOWACOS «4.6.68 4.0% o.5& ee we Z| BE. « HF BB ft Ft ss Lo 2e@ eee ee we See eee ae ee ee oe se 6 2 Beeeteaeseeoaoueeuwreeee evs etea« ad 7 £25 Ae eter eeeeeecue ee eeseeeee 8 4 Ao eee eee eee eB See Re eee ee ee 85 Dy si tea oe eo & we 4) ee ee Ge Se ee 8 6 GC 262442 See eee oe oe eee ee se eS 8 7 ee ee ee ee ee ee ee ee ee 8 8 Seth ew eee ewneeweae eee bee eee 203 bath be w gute 6 4 bie eee eee eee eS 216 LEGAL SERVICES

10 ime ili 13 14 LS 16 Ly 18 1g 20 21 Ze. 23 24 A Case 18-2868, Document 278, 08/09/2019, 2628230, Page442 of 648 Confidential Page 6 DAVID RODGERS A. ee. ©. 4 Can you -- can you tell me -- I have been provided by your attorney a -- what has been represented to be a copy, a direct copy of that IOGOUOOK« And I'm going to mark this as Pilgtneacit Se, 1. tf JUS Want You to Contain that thas 1S an accurate copy of the original logbook that you brought to your deposi2tion today. A. ees MR. REINHART: Let him show it to you. BY MR. EDWARDS: oF There you go. (The referred-to document was marked by the court reporter for Identification as Deposition Exhibit 1.) MR. REINHART: It is not a copy of the entire book. It is the time period that was covered by the subpoena. I just want to make clear the book covers the time period outside the subpoena. MR. EDWARDS: OKAY « L wii) bet. Aim Cclearary thet, Of COUrSe, ‘COO. TE. We PINGS = Yes. it, 2S Logbook. LG as not 40 years, but it is my logbook. MAGNA® LEGAL SERVICES

10 ime ili 13 14 LS 16 Ly 18 1g 20 21 Ze. 23 24 A Case 18-2868, Document 278, 08/09/2019, 2628230, Page443 of 648 Confidential Page: / DAVID RODGERS BY MR. EDWARDS: OO. Oka ys You can keep this -- that down there -A. Okay. O-4 -- so we can keep track of the exhibits. A. Okay. or So does the copy that you just went through, 28 that. at @xact copy of. the. original logbook from the November 1995 date through, it looks like, September 2013? That period of time? A. Yess O.% Ones And what is this book? Wheat. 0 you call the book? A. It is called the standard pilot master EOrg, « or All right. And who made the various entries in the book? A. ey “Cl ab. O% When did you make -MR. PAGLIUCA: Brad, Can You Bang On Tor one second. MRs« EDWARDS. sure. MR. PAGLIUCA: You said September 2013, I LOW ont. MAGNA® LEGAL SERVICES

10 ime ili 13 14 LS 16 Ly 18 1g 20 21 Zz. 23 24 Zi Case 18-2868, Document 278, 08/09/2019, 2628230, Page444 of 648 Confidential Page 8 DAVID RODGERS MR. EDWARDS: That is what I have on the last page. MR. PAGLIUCA: My last page is 2008 on this copy, 093 Bates label. MR. REINHART: There's 108 pages to the exhibit. MR. PAGLIUCA: I'm missing the last 8 pages. That 1s why. Mow PHRKRINS = Do you want the last copy? What is your last page? MR. PAGLIUCA: Ninety-three is my last page. Theat js: why 1 only go through ")s.. MSs PERKINS So I will give you my '94 to the end. That should give you a complete. On, you're looking -- which one are you looking at, the new one or the old one? MR. EDWARDS: The one through '08. MR. PAGLIUCA: Okay. MR. EDWARDS: Okay. Are you ready, Jeff? MR. PAGLIUCA: Ves 4 BY MR. EDWARDS: Os A. When did you make each individual entry? It could have been on that date that it MAGNA® LEGAL SERVICES

10 ime ili 13 14 LS 16 Ly 18 1g 20 21 Ze. 23 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page445 of 648 Confidential Page 9 DAVID RODGERS Says . Tt could have been possibly a later date. Most likely, fairly close to that date. O. Okay. How did you make sure that the log entries that you were creating were accurate? A. Well, people get on the airplane and I see who the people are, and I put them down there. QO. Okay. So you are making the notation at Or around the time that you are making this observation -- the observations? A. COLTLTECGL « © « And you are recording the data accurately im your Logbook? A. As accurately as I can. on Okay x A. Lee « Os Can we just look at the first page of the exhibit? A. Un huh. O% And if you could walk me through, let's just take the first line. A. Ube hun. O In the top left corner, there is a date. A. COTrPreCL . Oe And 2 Seyse, "NOV '95.” is titat Vou MAGNA® LEGAL SERVICES

10 ime ili 13 14 LS 16 Ly 18 1g 20 21 Ze. 23 24 A Case 18-2868, Document 278, 08/09/2019, 2628230, Page446 of 648 Confidential Page 10 DAVID RODGERS indicating that this is November 1995? A. Les. Ox Okay. And the first line under that in the date column says 1/7. Is that November 1/7/th, Loo De A. Loe. oF Is that a notation. Chat you would have made on November 17th, 1995? A. 1 ees ©: 4 And the next column over under “aircraft make and model," there is a number there. What is that number? A. That's the model of aircraft we're flying. Lt"sS a G=LLS vB. Lt. 26 Gultstream, LIl=-B arrecrart. Os Okay; And then the next column over, alrcrart: tdentarication mark’? A. It is the registration number of the ya tee eee Mee 0% And what is the registration number? What does that mean? A. The number that is on the side of every aAlErCratt tO LdenHTITyYy what Country 2. bse from and Wiket. Dear Laeular agarpilane 2t 2S 2m that country. The N means United States. MAGNA® LEGAL SERVICES

10 ime ili 13 14 LS 16 Ly 18 1g 20 21 Ze. 23 24 A Case 18-2868, Document 278, 08/09/2019, 2628230, Page447 of 648 Confidential Page ll DAVID RODGERS 4 And is that number unigue to the aircraft? A. Less ©. So there is no other aircraft at the same time bearing the identification number in NYO8IJE? A. That's Correct. or Who picks the identification number? I understand N means United States. A. Rao Wt. QO. Who picks the 9YD0D8JE? A. It depends -- some aircraft, I mean, when you get them, they already have the number on there, and so that would be one way. Sometimes the manufacturer puts them on there. You can also request a certain number, if yOu SO Chose CoO do sc. Os Okay. The particular air -- these particular logs were produced ina -- as a consequence of a subpoena issued in the case of Virginia Roberts Giuffre versus Ghislaine Maxwell. A. Uis= a: 2 Ox Is that your understanding? A. Lee « O « And the period of time that we were produced -- I understand you have flown for 40 MAGNA® LEGAL SERVICES

10 ime ili 13 14 LS 16 Ly 18 1g 20 21 Ze. 23 24 A Case 18-2868, Document 278, 08/09/2019, 2628230, Page448 of 648 Confidential Page 12 DAVID RODGERS years. The period of time -- or that is evidenced by tiats Logbook aS '95 ~hrough 2UlS. Why was it that period of time that was Choos en.2 A. Because that is what the subpoena requested. Ox Okay. Is that when you started flying for Jeffrey Epstein? A. No. O.4 When did you start flying for Jeffrey Epstein? A. JuULy Or 1o5 2 4 or Okay. Do you have available today the entries going back as far as July 1991? A. if aon’ tc. Know. I have to look and see. hs O Ka ¥ « A. No. Because this is from 7/28 of '94. O's Okay « SO Uhbat partaculear logbook begins JULY Zeit; L994 2 A. ee 4 O% And were you privately flying for Jeffrey Epstein on November 17th, 1995? A. 1 es « or And is that Gulfstream that you described MAGNA® LEGAL SERVICES

10 dA LZ 13 14 i 16 17 Le Lg 20 2 i ae ye: 24 2 Case 18-2868, Document 278, 08/09/2019, 2628230, Page449 of 648 Confidential Page 13 DAVID RODGERS a Jeffrey Epstein owned or controlled airplane? A. Tt was -- let me think. This was 908 Juliet, Echo -- I believe it was owned by Hyperion Air, Inc., I believe. Os And is Hyperion Air, to your understanding, a company associated with Jeffrey BEpstein? A. As far as I know. I mean, I would assume SO, Due == O- Was Jeffrey Epstein your primary passenger -Ping oe eae = O's == 390%) “ERa, jada pula ne 2? Pi x Lee < O< And who was the individual that gave you direction as to what passengers to let on and off the airplane and where to fly, et cetera? A. Well, Jeffrey was usually -- I mean, almost always on the airplane, unless we were going to maintenance. And so when he got there, he would have the people with him. O, Oar ys SO Going back “oO: The aatrcreit identification mark, 9Y908JE, does the JE signify the initials of Jeffrey Epstein? MAGNA® LEGAL SERVICES

10 ime ili 13 14 LS 16 Ly 18 1g 20 21 Ze. 23 24 A Case 18-2868, Document 278, 08/09/2019, 2628230, Page450 of 648 Confidential Page 14 DAVID RODGERS A. I would @2assume so. CO Oka y-s A. But technically they are actually the phonetic letters that we uSe. But technically it is Juliet echo; it is not Jeffrey Epstein. As far as radio phraseology, we don't answer Jeffrey Epstein; we answer Juliet. O-% Okay. But the JE doesn't signify some JU UtSOLreCTLOnal code 2 A. No. O. It is -- it is chosen by the owner of the aALrera tt? A. Bag a: 4 RiGee « O's So as his pilot and as Jeffrey Epstein being the main passenger, you have presumed that JE SLOn Lives Bais oa cialis? A. IT would assume so. O's In fact, we will get to it later down the road, but the -- the other plane also bears the ending 2nitaals JH? IS that right? A. Ves And this N number that's on this airplane was eventually switched to another airplane. or To the Boeing? MAGNA® LEGAL SERVICES

10 ime ili 13 14 LS 16 Ly 18 20 21 Ze. 23 24 A Case 18-2868, Document 278, 08/09/2019, 2628230, Page451 of 648 Confidential DAVID RODGERS A. To the Boeing, correct. on OKAY. Page 15 So if we go back to this first entry, the Next Column Gays; “From -CMA<* A. 1 @S.. O « And what is that? A. COoLUMoOwe , “O14C 03 Pina. 28: Qn. a2Lrport. Code? A. Airport identifier. O And, again, that airport code is unique to a Darecicular alrporr? A. Correct. Co. The next is "To PBI"? A. Yess © « Where is that? A. West Palm Beach. on And flight number? The next column "Miles Flown." A. RaSh : or Thal 2S HOt Something that you log. A. EO Fics om You. kept prertty meticulous logs. SO the next column is fTlight log Flight number? MAGNA® LEGAL SERVICES says Or

10 ime ili 13 14 LS 16 Ly 18 1g 20 21 Ze. 23 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page452 of 648 Confidential Page 99 DAVID RODGERS QO. Okay. A. But I'm not even sure we still had it at Uhis poLnt in Cime. or Yeah. It shows up on the next page. We will get there. A. Does it? Okay < So then, yes, the answer is, yeah, we still had the airplane. But we wouldn't have used ies Mele,“ Os So is there any way of telling how Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, and Virginia were in the Virgin Islands on that, from December 14th, 2000 -MR. PAGLIUCA: ObFGeCue. LO Loundat2on. BY MR. EDWARDS: Os -- based on your knowledge or your logs or anything else? A. No, I wouldn't have any way of knowing. % Okay. A. Because the next flight that they are on waS like this Palm Beach one, January Loth. SO ti wouldn't have any idea. O x Okay. To your knowledge, did Jeffrey Epstein ever fly commercially? MAGNA® LEGAL SERVICES

10 ime ili 13 14 LS 16 Ly 18 1g 20 21 Ze. 23 24 A Case 18-2868, Document 278, 08/09/2019, 2628230, Page453 of 648 Confidential Page 100 DAVID RODGERS A. He probably has. Back then at this time, Cit GoLaGg to. Say probably mous But I know that he has flown commercially. But usually that would be like going to EHurope, maybe. QO. Okay. January IOLA Chrough the Zork, those flights, do you see that block that I'm talking about? A. ~ eS 4 O' » Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and then at times Shelly Lewis, do you see Lea tS A. Yes, ruqhr. on The 25th it lands in Teterboro. And the next day, on the 26th, leaves out of Teterboro with Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts. This time you wrote the whole name. A. Fe aly ae: Rights % So when you write the full name, does that Signify -- that's when you may have learned her last name? A. COLrreec ts Os And do you know how she -- how she got up to New Jersey or New York? MAGNA® LEGAL SERVICES

10 ime ili 13 14 LS 16 Ly 18 1g 20 21 Ze. 23 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page454 of 648 Confidential Page 103 DAVID RODGERS Boeing? A. Less O.. The Boeing, was that previously owned by The Limited or Les Wexner? A. IT'm not sure of the company name, OTE AC ie hay. BULL DrObabily, Yes. O« Some association with him? oe Some association, yes. QO. Do you know who flew the Gulfstream while you were doing the simulator? A. Well, it would have been Larry Visoski, I'm not sure who the first officer was. Os Do you know if any logs were kept of the passengers' names? A. While I was at school? O « Right, while you were at school. A. There probably were logs, but I don't know where they are. % Have you ever spoken with Larry about whether he kept names of passengers? A. I don't think he does. on Do you know where Larry Visoski flew the Gulfstream for the month that you were -A. NO: MAGNA® LEGAL SERVICES

10 ime ili 13 14 LS 16 Ly 18 1g 20 21 Ze. 23 24 A Case 18-2868, Document 278, 08/09/2019, 2628230, Page455 of 648 Confidential Page 107 DAVID RODGERS different, because one day is the Sth; one day is the oth. But we landed there like at 11:50 at Wioh Le « And then when we took off, it was, you know, the next day. QO. Okay. Got 1 And then where do you go the next day? A. We went from Stephenville to Paris-Le Bourget. 4 And who were the passengers going to Paris? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts. os And then what's the next flight? A. On the 8th, from Paris to -- I believe that: 2s. 24. Sas « or Granada, Spain? A. Gfranadd, Spain. COLTrecrt.. or OkaY x And who are the passengers on that Gila D2 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia Roberts, Alberto and Linda Pinto, one female, and Ricardo, it looks like Orieta. or And then what's the next flight? A. From there to Tangiers. From Granada to MAGNA® LEGAL SERVICES

10 a. IZ i 14 io) L6 17 15 19 20 Zk tA: 2 24 ZO Case 18-2868, Document 278, 08/09/2019, 2628230, Page456 of 648 Confidential Page 219 DAVID RODGERS CERTIFICATE OF GATH SIATE OF FLORIDA ) COUNTY. OF MIAMI S DADE ) I, the undersigned authority, certify that DAVID RODGERS personally appeared before me and was duly sworn. WITNESS my hand and official seal Chas och dey Of Wute, 2ZO01LG6. Kelli Ann Willis, RPR, CRR Notary Public, State of Florida COMMESS Lom FPRrOZSGZ91, EBxpares: 21620 + + + + + + + + + + + + + + +O «+ ~«+O~O+F CE Re LOA TE > PATE OF PlLORDTDA ) COUNTY OF MIAMI-DADE ) IT, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime Reporter do hereby certify that I was authorized to and did stenographically report the foregoing deposition of DAVID RODGERS; that a review of the transcript was not requested; and that Eihe Crenmecrape As a true record of my stenographic notes. I. FURTHER CERTIFY that © am not <a relative, employee, attorney, or counsel of any of the parties, nor am Ioarelative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 8th day of June, 2016. KEL ANN WilbiiS, Reh, RE MAGNA® LEGAL SERVICES

Case 18-2868, Document 278, 08/09/2019, 2628230, Page45/7 of 648 EKAHIBIT DD INTENTIONALLY LEFT BLANK

Case 18-2868, Document 278, 08/09/2019, 2628230, Page458 of 648 EKAHIBIT KE

Case 18-2868, Document 278, 08/09/2019, 2628230, Page459 of 648 SS i el Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 1 Time: 8:51:56 Citation Tracking Report Program: CMS307L Case Number. : 1-02-009702 Issued By . . : KLOEPPING, KURT 6/19/02 13:55 Entry Employee : STEPNOWSKI, DOROTHY 6/24/02 13:55 Zone/Division : Zone Two (2) (So of Okee/E thr Wil) District . . . : PATROL Street Name . : CRESTWOOD BL /SPARROW Last Name . . : ROBERTS, VIRGINIA LEE Street Number : Qa BRM RD City... . . : LOXAHATCHEE, FL 33470 Birth Date .. : Si Oper Lic No. . : Sx Race... . . : White Sex .... . : Female KkKEKKKkAeEE VY BH T CL BEB INFORMATION # L KR KKEKKEKEKEKEKKEEKEKEREERE Case Number. : 1-02-009702 License Number : G13BTQ FL Vehicle Year . : 1993 Make ... . . : PONTIAC Style .. . . : TWO DOOR Color - Top. : White Color - Bottom : White KKKKKKKEEK VT OLA TION INFORMATION # 1 KKK KKKEREKKKKKKKKSE Case Number .: 1-02-009702 Citation Number: 9702BOE5 Statute/Ordin : 316.189 1 ????? . . .. : NA kK KK kK ek ke eK kK RK Kk KO ® OK * *&® RND OF REPORT * * * * ® KK KR KR RK RK RK KK RK KK CERTIFIED TO BE A TRUE COPY RIC L. BRADSHAW, SHERIFF GM_00776

Case 18-2868, Document 278, 08/09/2019, 2628230, Page460 of 648 EAHIBIT FF

+é ‘PROBABLE CAUSE “pen OBTS Number 3. Request for Warrant 4. Request for Capias Agency OF! Number ol et rolral 9° Type: kas many a8 apply Agency Name PALM BEACH COUNTY SHERIFF" S OFFICE As. Falany Fs Misctameanor = . — 2. Trafic Felony 4. Traffic Misdemeanor ; — se LL us o ” Cnarge Description oO ~n— | (L= aige Description 1o ‘ The undersigned. certifies and swears that he/she. has just ae reasonablegrounds to believe, and doas believe that Ine above named Defendant commuted the The Parson taken inte custody ., L} committed the below acis in ” presenca.. a ae was observed L] coniessed to Nat he/she saw the arrested person commit the below acts. Fadmitting to the below facts. was found to have commited the below acts, resulting from sig ——) investigation On the +. day pf 20. at ss ld Ca. OC) Pom. (Specifically include facts constituting cause tor arrest.) or ‘ = . com} Soho Selvsaresny : f, we) fn SK AX OY S _ P £5 , ro ¢ Ocy DA a) a Fe ADIN < J o af —O- Xt y: ° . uF. oe Ta ees 7 owe Uyaleds i -}? ~ x ee : foes sve Ame “Warde St Os Cio et 4 r ~ file " ws ae as errr si fie, Onpu of Obu 0 6 ane ey: ou ALAS . Xe.) mo. oy : re m1 =a a a hy ar; vee eo ca Uae ns a ow Oakes 2 Bes oo rhs Aco). SWS Sane * : at *. thie ee ¢. vy s nore ow re ae) cre Te asia 43 se! 4°. Se Seti te! mse yo Wok Ag Bee are Re : Po a AON . d ‘ slat ; i y Seen ° * ’ os " ' , a? 8 * “ ey ‘ ’ wT ta re . “sy f 4 ¥ a3 et de SK tek = oe Sate brat ~fiky - 0% tuna a s'<3 ’, Rae Sey ys te woe ae ro SP NE Ea ts tae shah eee, yom . ony “ A . , . j 3 aan 4 ‘ , 7 Beat. “ete “mS fe .| Fi ah RO ods 7 , : . Ae Sh} is a x a | at , = h _/ tf 2 if sth th “tees e ; . e w 2 a . : F “8E ¥ if . : ee ‘ ° : aioe he SOA aa ATIVE gat Ohicw eo iprnay auc ele (ee c Herta GSE. a, rs oTaabe ie 3 » . iw: ta eras 7 AOMINIST GM. 0122" YELLOW — Agency - PINK — Aaency que a CUSTRIRLITION: WHITE — Cut Coo “ae “GREEN — Stata nema

The text on this page is estimated to be only 45.34% accurate

| "= 4 _ Case 18-286¢ pecutcient 218, 8409/2019, 2628230, Page462 of 648 =... OBTS Number: PROBABLE CAUSE AFI IDAVIT EE ENTA 4 Ren cans lt | Agency OR! Number Agency Name cad O,: “A BEACH COUNTY ae S 217i Se . 3 1. |: Misdemeanor 5, : . . Traftic Misdemeanor ‘yy ) Charge Description i The undersigned certifies and swears that he/ The Person takan into custody... . on hat he above named,Delendant nt commyted the folowing violationfot. law. L] committed the below acts in my presence. o CF confessed to admitting to the below os t 4 fal he/she saw the arrested person commit the below acts. — : : cts. . : : jas found to have commited the below acts, resulting from my et iranian On the i) day of Olam. O Pm. (Specifically include facts constituting causestor arrest.) a a Ke ca pling , sag ! et cae “ rol nae 7 BoD wen ik it~ ‘ —-™ih i Eid C+ er 2 feet, ae F Ps = aah a : 3 ae Attn, © Ls . } 2 a> We eo a " a oe: = oan red” os ’ se MR Coe a * St o& &: 4 +i = 5h 4 ad S30 = * =, se z aii o's). |. " ee aay ea a oe wT SS Ee POR TE eee th Wy et oe SS <e ig 4 as mene cale a a iat nied Piet ae Soeaccsck iabniapentec haan . . . Me a> aa | pe *s An Es ere, ee ee ray > ciaaete Hoe APES 7D NOTE Shae Ler era - " YY Y// tI LED. ican g sui ~O. ait is ete known io me ef i’ « vt <— cD fark bf Court, Of ore. 7.10) DISTRIBUTION. WHITE. — Court Coov GREFN .. Gare Srnrneu VELITAM & Baan, Bmiv .

Case a 278, 08/09/2019, 2628230, Page463 of 648 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA CRIMINAL DIVISION "W" (CGS) STATE OF FLORIDA CASE NO. 02CF012205A02 BOOKING NO. 2002343589 ¥S. fy »—— sy ONS ANTHONY LUIS ZAC FIGUEROA, 8 —. = / oo wrormarioWtQ] G | iy Al BO GRAND THEFT In the Name and by Authority of the State of Florida: BARRY E. KRISCHER, State Attorney for the Fifteenth Judicial Circuit, Palm Beach County, Florida, by and through his undersigned Assistant State Attomey, charges that ANTHONY LUIS ZAC FIGUEROA on or about August 11, 2002, in the County of Palm Beach and State of F lorida, did knowingly obtain or use, or endeavor to obtain or use video games of a value of $300.00 or more, which was the property of HOLLYWOOD VIDEO, or any other person not the defendant(s), with the intent to permanently or temporarily deprive HOLLYWOOD VIDEO or any other person not the defendant(s) of the property or benefit therefrom or to appropriate the property to the use of ANTHONY LUIS ZAC FIGUEROA or to the use of any person not entitled thereto, coptrary to Florida Statute 812.014(1) and (2)(c). (3 DEG FEL) : FL. BAR NO. 0928933 Assistant State Attorney STATE OF FLORIDA COUNTY OF PALM BEACH Appeared before me, JILL ESTEY RICHSTONE Assistant State Attomey for Palm Beach County, Florida, personally known to me, who, being first duly swom, says that the allegations as set forth in the foregoing information are based upon facts that have been sworn to as true, and which, if true, would constitute the offense therein charged, that this prosecution is instituted in good faith; and certifies that ny under oath has been testi received from the material witness or witnesses for the offe A Wiad Sworn to and subscribed to before me this 7 day of October, 2002. ua. STATE OF FLORIDA * PALM BEACK LOL — sae aoe | Heraby certify that the foregoing is a — Den jorolw, ri a Me true at af the sacord in my Office with en) | , EMT BAF ggctons. pry 25 eguved by VL pNOTARY PUBLIC, State of Florida JER/sw Ne se we 5 Day 20 ge : “Sey SHARON R. BO ttn, on ERE RE MPTROLLER se Pg, Ellon Jordan A i KR MY COMMISSION # C7974] EXPIRES " Se December 28, 2009 arts BONDED THRU TROY FalN INSURANCE Ine. DEPUTY CLERK GM_0120

9 yO” _ Case oy Kh ocument 278, 08/09/2019, “eo of 648 [N THE CRIMINAL DIVISION OF THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR PALM BEACH COUNTY TTT CASE NO. 02 0) Aa08 CF. AQ _ Div. Lr) @1/28/2@03 11:36:12 28638047647 OBTS NUMBER | OR BK 14728 PG 19736 alm Beach Cou STATE OF FLORIDA C] COMMUNITY paeeeny meine, Florida CONTROL | ; ae Ghar ect COUNTY eagie, STATE OF FLORID ae MIOLATOR We dHaNn « | heraby certify (nat the foregoing '5 4 v. Rea 0 see my office with [) PROBATION an a Tek: true copy of the record in eT EY edechins, pany 05 recpeye’ ©) J _ = | a Ay we DAY © Sa aan rr 2 ARON R. K RR & COMPTROLLER AO DEPUTY CLERK RACE Ss GENDER . .o2 =i & 2 SOM IR et tp a £ OO i ' OC ee eq rsee OY - : Y The above Defendant, being r rsonilly' Before this Court represented b i , CQ (attorney) [ ] Having been tried and found guilty of the following crime(s): Having entered a plea of guilty to Having entered a plea of nolo the following crime{s): contendere to the following cnime(s): i Ny TL OFFENSE STATUTE NUMBER(S) Ra DEGREE +, XI and no Cause having been shown why the Defendant should not be adjudicated guilty. IT [S ORDERED THAT the Defendant is..hereby. ADJUDICATED GUILTY of the above crime(s). be [ ] and having been convicted or found guilty of, or having entered a plea of nolo contendere or guilty.regardless of adjudication, to attempts or offenses relating to sexual battery (ch. 794). lewd and lascivious conduct (ch. 800), or murder (s. 782.04). aggravated battery (s. 784.045). burglary (s. 810.02). carjacking (s. 812.133), or home invasion robbery (s. 812.135). or any other offense specified in section 943.325. the defendant shal! be required to submit blood specimens. “ F re Pre - Ste DSL b le Stiri Bran = . He ek s D. ENTENCE { ] The Court hereby stays and withholds imposition of sentence as to count(s) and places the Defendant on STAYED [ J Probation and/or{ }] Community Control under the supervision of the Dept. of Corrections (conditions of probation set forth in separate order). SENTENCE DEFERRED [ ] The Court hereby defers imposition of sentence until The Defendant in Open Court was advised of his right to appeal from the Judgment by filing notice of appeal with the Clerk of Court within thirty days following the date sentence is imposed or probation is ordered pursuant to this adjudication. The defendant was also advised of his right to the assistance of counsel in taking said appeal at the expense of the State upon showing of indigency. DONE AND ORDERED in Open Court at Palm Beach County, Florida, this io day Ja UABA 4 . ie GM_01205 Cl OURT JUDGE

Case “oe 278,08/09/2019, “oOo of 648 PLEA IN THE CIRCUIT COURT OWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT THE FOL Name Ly Plea: Guilty “Guilty/Bde Case No. Charge f Lesser Dearee — rr ——— re 99 ee JAN. 15 2002 ie eOTHY Ft, a at Steep, Ch EP a ee ee Wil & out COUNTY ee —" PSI: Waived/Not Requi Z i “abe oiates | Ap, Case} ADJUDICATION: | Court’s Discretion [ ] lf the Defendant is convicted & KCiéfig or conspiracy to pofsess, sell or traffic in any controlled substance, the Court directs the Department of Motor Vehicles and Highway Safat Yefendant’s driver's license for two (2) years. If the Defendant is convicted of grand theft of a motor vehicle; ymmission of which a motor vehicle was used, the Court directs the Department of Motor Vehicles and Highway Ehse as mandated by jaw. The Clerk is directed to make the proper notifications. $ Fine $ Court Costs $ Drug Trust Fund $ Cost of Prosecution $ Public Defender Fees/Costs Incarceration: Days Months Years theft of motor vehicle parts; or, any (ony Safety to revoke the Defendant's driver's SENTENCE: PROBATION: ALL CONDITIONS OF RROBA\ at PROBATION IS SCHEDULED TO ane UNLESS STATED BELOW. STANDARD CONDITIONS OF PROBATION HAVE BEEN EXPLAINED BY DEFENSE COUNSEL. PECIAL CONDITIONS OF PROBATION: oe Ge Restitution r the accompanying order. [ check if ordered) 9) TCO. aD (3) Fine: 5s Court Costs: Drug Trust Fund: $ SO gel i) Cost of Prosecution $ S d Public Defender Fees/Costs C) Substance abuse evaluation and successful completion of recommended treatment f[ ordered) (enroll within 30 days) If in custody, release only to D) Random Drug Testing at Defendant's expense [__] (check if ordered) E) hours of community service at a rate of no less than hours per month F) Incarceration: Days Months Year with credit for time served; which is days. Ce | _y STHER COMMENTS OR CONDITIONS-———_ oe UND OE Sao PA A te ea De Paedh lol. aden 1D Uy Vi SENTEN N J LAK THE DEFENDANT. fio, a iit p SH AR OR IS ARRESTED ON NE BE Ia EB ARDS “ fret OT WIEENA In (Reveany Kb CHARGES, A CAPIA ULZ TLL wt Defendant < AY Te ey al Te) ‘a true cony POSE ANY nO 8 SENTENY iim fedactions, if H aS TE oe ed by AS KA 1 R. BOF : Attorne for] ine PTROL of tn iY Sp Rey Za aye UN Assistant State &t ERP EA 4 hin fer Ut thesttir,GM_ Defendant , E Date of Plee | oe ee ee = 4 Or Nt

Case 18-2868; Document 278, 08/09/2019, 2628230, Page466 of 648 In the Circuit Court of the Fifteenth J udicial Circuit In and For Palm Beach County, Florida Ne Case No. 2COlLZTZ2ZOL CE A+ 2 Division: vw STATE OF FLORIDA - _ FILED N mow LWis Zac Fi ULvt h wheat Srimiaal Department Defendant a Oo ORDER MODIFYING PROBATION. THIS cause has come before the Court on the Defendant's Violation of Probation. Upon consideration, it is hereby: ORDERED AND ADJUDGED that the Defendant’s Probation is modified as follows: Volar extended he Aga 0 Months wih whim 9 tw | + Hi denon 6 Av US oe QV oluoalion 4+ CynVimen ce Quine, yeeomimonded Lpeaterr + \e Defendant admits the Violation of Probation. x All Orginal terms and conditions to remain in effect. Oo Defendant is sentenced to days/months Palm Beach County Jail with credit for _. days. : DONE AND ORDERED this ww dayof BE ,200° 57 . i STATE OF FLORIDA * PALM BEACH COUNTY | hereby certify that the foregoing Is a true copy of the record in my office DEPUTY CLERK OM. 012074 9

" . Case’ 18-2868 gocument:278, 08/09/2019, 2628230, Page467 of 648 PROBABLE CAUSE AFFIDAVIT 1. Are =f Request for Warrant Juvenite "1. 2. N_T.A, 4. Request far Capias Z / a * Agency Name Agency Repon Number ' PALM BEACH COUNTY SHERIFF'S OFFICE e Type: Check oF many bs creed ramic mMeéanor oe ” Fipst., Middle Date of Girth CED Oy soa | NON) | ) QU YE ,\ The undersigned certifies and swears _ helshe has just and reasona d ii : ; is : The Person faken into custody .. ! n dle grounds to believe, and does believe that the above named Dsfendant committed the following violation af law, LJ committed the below acts in my presence.- . a BXvas observed ARRAA Ange lar CO confessed, to a hat he/she saw the arrested person commit the below acts. HBS admitting to the below facts... . was found to have commited the below acts. resulting from m (described) investigation: On the ~Oam 0 pm, (Specifically include facts constituting cause for arrest.) EY} OAS JEN Tor : EOL r Ors" i * 2A C On LES yn" * * a " ’ PAs noe i ApS AM AOA a t OD on ‘11. biienane 7 Cys TR SS MS hole 45 ¥3i 5 ‘ S Rea . . ‘ 1 , measen [esis io al zim & me, FAD Tey 4) : = = Mp. “YY Aifirrric BL Aer ry AN DO py 4, se we as, CaS os op ek of eae oo: eiee a, Laer) oy ag MIF re) ATS. inven ae Bi fg er oR A vie apie! . . ae \ tah 7 ; a yy . = roel a fae whe ian * heaton arab aves - ie aT - = - = a Fie tates: ANS a: Pye bt : : -- ~~. 7 ee eet ts os * Sa lpes make y i Mit im wiraae Pa *, A Peo’ . . , ib ‘Vg Vane oe MSc as: pth Ly: ; : " Ay ipso singe cer), wn is personaly ncn na fe ei has Fi, £2] —f J? 3 oT ; of Court, Officer (F.S.8; 147.10) wept 4 as DISTRIBUTION: WHITE = Court Copy GREEN — State Attorney YELLOW — Agency PINK — Ananes —— PASO # nana @EY nant

. Case 18-2864 @)ocument 278, 08/09/2019, 262823 Page468 of 648 O8TS Number > | PROBABLE CAUSE AFFIDAVIT 1. Arrear 3. Request for Warrant . 2.N.TA, , 4. Request for Capias =| Agency OA! Nusnber Misdemeanor Traffic Misdemeanor f \ } - The. undersigned certifies.and The Person taken Inia” aS aay NS that he/she has just and reasonable grounds to believe, and does.haijeve that the above gamed Ost *- t CJ) committed the belbw acts ‘i my presence, 7 Russ aoe Tne ‘A OA Cj confessed to .* , | admitting to hacaGeaee °° «°° Oe t he/she saw the arrested person commit the below acts. : . 9 ow acis. was found to have commitad the below acts. resulting from. my (deserved) Tivesigntr ae dant commuted the fellawing violation of sec On.the day of OA. M. L) P.M. (Specialy include facts constituting cause for arrest.) -— s ' a 7 n =“ . “its Sis * tre js . , e 4 as i" ai i+ ae : * .° -* > : , —~ . SUSTEY Sh zn £50 x ’ af win e * > eet 5) 5G ‘. . ey as ear storie” a a see — Egat ae . “aie * a aS LO aS af, ‘3. wr sy) = i a at: +: ‘ eo pe ym. Ph eres a ay Sere CN AAG, us ee ci Pans A Eni papas 29 |e Seiwa =: AS f i RNa ret 2 RS ats te UNE Re tic ae a Salts nd Kee —_ - & + oe ‘ah ee eC vie is: LS * Se Sas hag es REE 8 ot 3 Soke zi : SG Fey eee sy hho "is r a : ee es + a BRU : eet wae om a 2 , A om A, J * ‘a : . ofr: _ ; - art gees paring ae es + i aire Ais iz ul st 1 3 "OC prin ee: Ps | cy fis Oy tay 7, ze cs ‘? 8 . abel! Se ei “Fe : oie ee = pt oO . PA AL D can oS h Oy a cea Ag eset fc is a oie “ei “ante alt, Bey ‘ OU ay ROCA LOeA ge Hee STATE O FLORIDA -COUNZ OF PA) WwW , ‘ ; . a Fs ‘Yyy2 (4. f, é Naeting ore ry : i otim ee es Dm Nie o fig ihruhe ALIA of A RAL Coty x) yy NA ae 3 ae 4 A wenger es AL Subbu ji i r bie ‘pre BY aly AA z. . Abbe tl 3I 00 OPEL Loan; ee cae | ot, Offlcar @S.S. 117,10) Po Oa OME at dc ata ; * DISTRIBUTION: WHITE — Cau Garnw ROECCN = Erarn Aveacaa.. weit nar — eevee fanaa

- Case 18-284@—_Document 273) 08/09/2019, 2628230, Page469 of 648 PROBABLE CAUSE AFFIDAVIT +. Arre$t 3. Request for Warrant ; ' 2. N.T,A, 4. Request for Capi ZB eee Ba Agency Name > ce ws 7 ae 7 PALM BEACH COUNTY: SHERIFF’ S OFFICE 1, Felony 4 3, Misdemeanor : 5. Ordinance 2. Trafic Felony Tratic Misdemeanor 6. Other Type: _ SRE | rt tid ok pix eenos4e Llc a old < _ The ote cerifies-and swears that he/she The Pe en into custody has just and reasonabis grounds to believe, and does believe that the above named Hendant commited (he folldwing violation of: = oe O committed the below acts in my presence, ie was observant eV IOL +n 2) told { t ry fe q > * en conf U a = : Cra at he/she saw the arrested person commit the below acts... ng. Glow facts. as found to have commited the below acts, resulting from my (described) investigation. ul + /On the rs i a of OamM.O pm, (Specifically include facts constituting cause for arrest.) S15 Rete ey ae ORO 2! COOr Ws A Wa cA. ; “seek oe ae, . on ts Tie cid seat we eons 13 Ait YY Q + 5 Gta } a (at a - ° *. . - tx oF : = AC TREES 300) aa — aie . <Owy TAR ae ae On AL Pod PyDAY, Ao: AR | “7 ro i} pig aor ate = ou Pee : i | ACA REYNS eet if Py eiOshe lt Abs | . LD ROAC . PEGs s , ' - . ~*t <.F si: Ea ae Te Le i s tac -*% —_ ry A te . - ‘ * A A r gees 25 BA ihe . r ant a eGele ws SES Hn PA ee > 1 eames ~“- aire 7. * = ; tes Sor ge Sree phiaeelt ; =~ Pee ~ at RE EC o = e . n id, Cah ag ¥ "hy 7 ae 1 Sagi eye GN SS Tad SN i - on ve nS a et Ac ene ao ae oy oe Ree v, SAREE Ce Te BLE Tat, re St A-= ge ANE ess Ea ithe ag Fras 9 Need, vy ry Ao TRATIVE ‘Print nape ol Ae 5% oot A i py DEL lary ublic, Clerk gh@durt, Officer (FS. Fé t PRE & AAs BEY nai DISTRIGUTION; WHITE — Cour Copy GREEN — State Attorney - YELLOW — Agency . PINK = Agency ~*

Case “sy Document 278, 08/09/2019, “~o Page470 of 648 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA CRIMINAL DIVISION "W" (CGS) STATE OF FLORIDA CASE NO. 02CF012206A02 BOOKING NO. 2002343590 VS. ANTHONY LUIS ZAC FIGUEROA, W/M, we} a " ae’ es pS teed * “an law INFORMATION FOR: on aa ooh S z ir n'y ™ set Deg re ly f . ? = . omen joe a “3 . — ‘GRAND THEFT —_— In the Name and by Authority of the State of Florida: BARRY E. KRISCHER, State Attorney for the Fifteenth Judicial Circuit, Palm Beach County, Florida, by and through his undersigned Assistant State Attorney, charges that ANTHONY LUIS ZAC FIGUEROA on or about October 24, 2002, in the County of Palm Beach and State of Florida, did knowingly obtain or use, or endeavor to obtain or use video games of a value of $300.00 or mote, which was the property of HOLLYWOOD VIDEO, or any other person not the defendant(s), with the intent to permanently or.temporarily deprive HOLLYWOOD VIDEO or any other person not the defendant(s) of the property or benefit therefrom or to appropriate the property to the use of ANTHONY LUIS ZAC FIGUEROA or to the use of any person not entitled thereto, contrary to Florida Statute 812.014(1) and (2)(c). (3 DEG FEL) FL. BAR NO. 0928933 Assistant State Attorney STATE OF FLORIDA COUNTY OF PALM BEACH Appeared before me, JILL ESTEY RICHSTONE Assistant State Attorney for Palm Beach County, Florida, personally known to me, who, being first duly sworn, says that the allegations as set forth in the foregoing information are based upon facts that have been sworn to as true, and which, if true, would constitute the offense therein charged, that this prosecution is instituted in good faith, and certifies that testimony under oath has been received from the material witness or witnesses for the offense. ~ Sworn to and subscribed to before me this ae | day of October, 2002. om NOTARY PUBLIC, State of Kiohida JER/sw ahha STATE OF FLORIDA * PALM BEACH COUNTY cf “iS a m r ei Ellen Jord gi : thy ronan roan * me Pa i rt ” MARAIS IC) clions. & FPR Dac embes 28 sa — pay Ss ren 2 0 LRENDED THRU TROY FAIN INSURANCE. INC. “Rena SHARON R. BOCK rs lie OM PTRALLER ye = GM_012 ans | hereby certify that the foggy hs Beas cicue Copy of the record In Bay Gace » ACH) DEPUTY CLERK

95. | ay Case 18-2 Document 278, 08/09/2019, ““@ Page4/1 of 648 IN THE CRIMINAL DIVISION OF THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA. IN AND FOR PALM BEACH COUNTY MTT TT i wewOQO1AQOLCE ACQ ww Li) a @1/28/2003 ti:36:12 20030847649 OBTS NUMBER OR BK 1472@ PG 1937 Palm Beach County, Florida STATE OF FLORIDA [ COMMUNITY Dorothy H. Wilken, Clerk | CONTROL VIOLATOR VY. PROBATION VIOLATOR HOROTHY H. WILAEN, CLEP HE eS eTN chee taNOLe?r & or Tr. ae & COUNTY Cutis . The above Defendant, beine p (attorney) Having been tried and found guilty of MI Having entered a plea of guilty to Having entered a plea of nolo the following crime(s): the following crime(s): contendere to the following crime(s): OFFENSE STATUTE NUMBER(S) DEGREE and no cause having been shown why the Defendant should not be adjudicated guitty, IT iS ORDERED THAT : the Defendant ADJUDICATED GUILTY of the above crime(s). endant 1s hereby —=_— —! and having been convicted or found guilty of, or having entered a plea of nolo contendere or guilty.regardless of adjudication, to attempts or offenses relating to sexual battery (ch. 794), lewd and lascivious conduct (ch. 800), or murder (s. 782.04). aggravated battery (s. 784.045). burglary (s. 810.02). carjacking (s. 812.133), or home jnvasion robbery (s. 812.435), or any other offense specified in section 943,325, the defendant shall be required to submit blood specimens. Ray BCL seeped Tse Oellic stow: TORBDER+SSE FBT Tr Orr ot ° TEL iy SENTENCE { ] The Court hereby stays and withholds impositignw sentence as to count{s) and places the Defendant on STAYED [ ] Probation and/or[ ] Co rE Contrgl ynder the supervision of the Dept. of Corrections (conditions of probation set forth in separate ordegjp * ieenre, wht SENTENCE oyne OF Fag tt ar HY DEFERRED —[_} The Courthereb} de feasshifpsiion Y epee unyi Aa A ug GF Y: . fie Sates ih wf} The Defendant in Open Conifers t [enpeatAre: iling notice of appeal with the Clerk of Court within thirty days following the date senience.i} impose a bat fion. The defendant was also advised of his right to the assistance 1 [§ day of 200.43 _n

The text on this page is estimated to be only 43.90% accurate

SLZI owes? 18-2868, Document 278, 08/09/2019, 2628230, Page472 of 648 CS = <x FILED 07 JAH 23 PMI2: 3% I ‘IBOUFO UoTjegolg MoA JO JUSSUOD oY] SuLMNdes IsIT MOM Wives Jo suodvom Aue uMO Jo Aled ‘ssassod Jay}IoU []IM nox (>) ‘IDIVO Uoneqol INoA Jo JUasuoo oy} SuLINdoId ysI1F jnOYIIM sousprsal Mo Jo AJUNOD oy} DAI] JO yUSWIAC[dUId Io soUapIsoI MOA aSUPyO }0U ]]IM Nox (¢) ‘SOINIRIG. BPLOT J YIM souel[duroo ur pajduwoexe asimJoyjo ssaytm “uorstazodns INOA JO }SOO 9Y} PIeMO} ‘OBIeYoIMs %p B snjd ‘qjuow od QivT1og ALATA 00°0S $ Jo youre ay} epropy Jo sye1g oy} 0} Aed pIMnox —(Z) ‘asodind yey} _ IJ POplAosd wOJ oY} UO Jo0yJQ UoHeqoIg MOA 0} Yoder [nyYINN pue [Ny B OYCU [JIM NOA “pajoolIp se 10 YJUOUT Yoo Jo Aep WITT OU} Uey} 1d}e] JON (T) | UoT}eqoid JO SUOHTPUOS SULMOT{OF OY] YIM ATdutoo [eys nod yey Jap1O IOYYNY St 3] "9}21§ ST} JO SME] BY} JO suOIsIAOId 94} 0} yo9fqns aq 0} UoTsIAJedns Yons ‘SISOYJO SHI pue suoT}d91I0_ Jo yuounedeg __ 94} JO uotstaradns oY} F9pun COV AOSOCZI-20 HIIM LNAaalONOO SHLNOW (81 NHALHDIY JO potted e Joy uoneqoid uo pooxyd Aqeisy ore nod yey} pue ‘pjoyyyis Aqoaiay ore SouS}Uas JO UoT}Isodunt ay} yey} pospnfpe pur Pelspi1o SI }I “sIOJSIOY] ‘MON ‘ABT AQ pozuoyyne Ayeuad oy) Jayyns pynoys nos yeu} oimbal jou Op AJA190$ JO sIeJJOM dy} pue sonsnf Jo SpUS Sj] Jey} pue “ONpuod Jo osINOd [eUIUILIO B UT asedus 0} uiese Ajay] JOU oe NOA JY} UMNOD 94} JO UoTovJsyes oy} 0} Surmwodde yy] | JO AyIns aq 0} NOK saspnfpe Aqazsy umo0s ou} pue ‘asuajjo pres Idd. ONVYD "T INNO Jo esuagzo ayy. OL ALTIND GATd ‘SuTAvY NOA pure ‘our sr0Joq JUasoid Mou 8uI9q “‘VOURNDIAOVZ SIN ANOHLNY Wepuejep ayy “nod pue ‘au al0jaq preay 9q 0} Aep stm} uo SUIWOD Osned STY], 5 A x “ > yUepusToq =r OCOVAIIOCEI “CO “ON 8SBY) VOURNDISOVZ SINT ANOHINV coed Ayn} YoRag Wye jo NUg —-SA~S < pMNoD IMIND sy fp uy Vado ld JO ALVLS 54 NOILV@0Ud NO INVON@dad DNIOVId ONY Oo LTS JO LINAWodne —=___ €-ST 1201 un OTIPIM 40d

Case 18-2868, Document 278; 08/09/2019, 2628230, Page473 of 648 e ZacFigueroa, Anthony Case # 02-12206CFA02 (5) (6) (7) (8) (9) (10) (11) (12) You will live and remain at liberty without violating any law. A conviction in a court of law shall not be necessary in order for such a violation to constitute a violation of your probation. You will submit to Urinalysis, Breathalyzer or Blood tests, as directed by your Probation Officer or the Professional Staff of any treatment center where you may be receiving treatment, to determine the possible use of alcohol, drugs or controlled substances. You will make a good faith effort to obtain lawful employment and support any dependents to the best of your ability as directed by your Probation Officer. You will promptly and truthfully answer all inquiries directed to you by the Court or the Probation Officer, and allow the Officer to visit in your home, at your employment site, or elsewhere, and you will comply with all instructions he may give you. RESTITUTION TO: HOLLYWOOD VIDEO IN THE AMOUNT OF $1000.00 MINIMUM PAYMENT OF $55.56 PER MONTH — CRO FILED NO CONTACT WITH HOLLY VIDEO IN PALM BEACH CO. ENTER AND COMPLETE: THEFT ABATEMENT PROGRAM AUTOMATIC EARLY TERMINATION AFTER 12 MONTHS PROVIDED ALL CONDITIONS ARE SATISFIED You are hereby placed on notice that the Court may at any time rescind or modify any of the conditions of your probation, or may extend the period of probation as authorized by law, or may discharge you from further supervision; and that if you violate any of the conditions of your probation, you may be arrested and the Court may revoke your probation and impose any sentence which it might have imposed before placing you on probation. It is further ordered that when you have reported to the Probation Officer and have been instructed as to the conditions of probation you shall be released from custody if you are in custody and if you are at liberty on bond, the sureties thereon shall stand discharged from liability. GM_01214

. Case’ 18-2868, Document:278, 08/09/2019, 2628230, Page474 of 648 ZacFigueroa, Anthony Case # 02-12206CFA02 It is further ordered that the Clerk of this Court file this order in his office, record the same in the Minutes of the Court, and forthwith provide certified copies of same to the Probation Officer for his use in compliance with the requirements of law. DONE AND ORDERED IN OPEN COURT THIS 15TH DAY OF JANUARY, 2003. Signed this <2 day aay 2003. | Tacknowledos cane SS I acknowledge receipt of a certified copy of this order and that the conditions have been explained to me. Date: Probattoner Instructed by: Original: Court DC4-900A | Copies: Probationer/File JF 1/16/03 STATE OF FLORIDA * PALM BEACH COUNTY | hereby certify that the foregoing Is a 1h Rahat S . 2 a i ri te 4 + opy of the record in my office with ste Eat Seh RAs ctions, if ed by “lO A rary Sy i : ee” THR) DAY oo v \ ct A eee 2 OLLEF t B ‘e GM_01215

- Case "eo 2/8,'08/09/2019, 2628230, Page475 of 648 ) ) In the Circuit Court of the Fifteenth Judicial Circuit In and For Palm Beach County, Florida O°? Of 2U2NS ee He? Case No. Division: WwW STATE OF FLORIDA Ns \ vu Lay S Cac. [-s by LAO vo aa | il ieuir ee i oe jvcrliien Ges Defendant ORDER MODIFYING PROBATION ee THIS cause has come before the Court on th D He Silas 2 ; dousiderctomeis amas ¢ Defendant’s Violation of Probation. Upon ORDERED AND ADJUDGED that the Defendant's P obation is modified as tollows: Av = Ou. Cv olualion 4- Odin ka Owen 1¢ Commanded Lpeatpunr + \e Defendant admits. the wacleHion of Probation. x All Original terms and conditions to remain in effect. ' 0D . | | | —— 1S —— to days/months Palm Beach County Jail with credit ) | ays. | tity that the foregaing isa ic : “ sacord in My sae A) % aia ithe. aR ke y : NBR Ae BEI 116 Sah - ; “ 1 NS ON rR, ea Sak / ~ APPT OE ae) EL oS yy DN Ne 2 2 = B nD ‘Ae tr zs 2 2 a -\ MAY 2 4 2005 C 216 <> P< 45

“SZ / (2 8 Se 18-2863, Document 278, 08/09/2019, 2628230, Page476 of B49 SY Location of Offense (Business Name, Address) 2-¢ A) Oate af arrest : on“ a cA | Sex a W > Wika |. American Indian O- OnentatiAsian AS B+ Black Tatoos, Unique Physical Features (Locg OBTS Number a Pavoni Reload Rapon "wa ete tasat [p] seme 7 w pency OR) Numbe gency Name gency Heport Number tips 01 01-2. 0, 01 “Pam acacn county suenresornce Lo, 81D BLI).2BBZ.10 1 Js Fim Aisem. et oe = z Location of Arrest (inctudi . 1 . ———— —reeny ee mn DO Sw cece = ng Name of & < i Eye Color A OlIOY ome 7 Indication of: Xx Alcohot Influence Cj wae ' ala Drug intiuence i) DEFENOA Businass Addrass (Name, Street) (State) Sename ae eo Plage of Birth or Stata) # ‘ Date of Birth (Middie} — 1. Arrested _ 3. Felony — 2. At Large i 4. Misdemeanor CoDefendam Namw (Last. First, Middle} "L Parent Name {Last} (First) — Legal Custodian L— Other: Address (Street, Apt. Number) Residence Phone Sition 1. Handied/Processed within 2, TOT HRSVD¥S _N ‘i | Resse — ie . TG Ge The adove addrass w aided to keep ihe Juvanile Count lerk's J Yes, dy: (Name ° Property Crimea Description of Property Lo Yes TiNo Juvenile Br spense/ M. Manufactura/ CODE, VENILE-——~—~—~—CSCSYSCC-EF |] " R, I ' Type B. Barbiturate U. Unkn . Nia B, Buy D. Deliver Distribute Producey. ar C. Cocaine M. Marijuana z. Other P. Possess T. Traffic E. Use ms Cultivate A. Amphetamine — E, Heroin O. Opium/Deriy, .” tic at Charge Cescription Counts Pee er C ‘| Violation of ORD « 2 Af Fed he oY gl ¥ 1O,? 2,c,t{\* CHA Drug Activity! Drug Type Amount / Unit Offense # Warrant / Capias Number Bond ae 2 i A & wes ie Charge Description Courts | Domestic | Statute Violation Number Violation of ORD # TT A Violenc i s _, . LY rf . Drug Activity] Drug Tyg Amount / Unset Offense # Warrant / Capias Number Bond © IZQsz M2 O219 5838 Charge Description Counts t Statute Violation Number Violation of ORD # : lolen ( ) eee ee © Warrant / Capias Number Charge Oegscription ; .} Counts | Domestic | Statute Violation Number Rigs Ss Wu Violence & CY CN CHARGE et NsSy <2 a nes Cc N AGE Warrant ¢ Capias Number Location (Court, Room Number, Address) a, Sas ih ? zi Court Dates and Time CaP oe i am r J 3 | Moath Day Year Time AM, crt py OE 11 AGREE TO APPEAR AT THE TIME AND PLACE DESIGNATED TO ANSWER THE OFFENSE CHARGED OR TO PAY THE FINE SUBSCRIBED, | UNDERSTAND: THAT SHOULD | WILLEULLY (| FAIL TO APPEAR BEFORE THE COURT AS REQUIRED BY THIS NOTICE TO APPEAR, THAT | MAY BE HELD IN CONTEMPT OF COURT AND A WARAANT FOR.MY ARREST SHALL BE ISSUED = cn whe S Sd Signature of Defandant (or Juvenile and Parenw Custodian} Date Signed HOLD for other Agency Name: C3 Dangeérous L) Aesisted Artest CI Suicidat other: lake O6o Transporting Officer LD, # S260 (2) "By amé DISTRIBUTION: WHITE- COURT COPY GREEN-STATEATTORNEY YELLOW- AGENCY PINK-AGENCY GOLD - DEFENDANT ({N.T.A.'s ONLY) V. &/97 PBSO #148"F

Case 18-2843, Document 278, 08/09/2019, 2628230, Page477 of 648 OBTS Number PROBABLE CAUSE AFFIDAVIT 1. Arrest 3. Request for Warrant Juvenile ’ . 2,.NT.A 4. Requast for Capias 7 Pa Agency ORt Number Agency Name . Agency Aeport Number Fo 5 O10, 0, 0, 0] PALM BEACH COUNTY SHERIFF'S OFFICE | 0. 6 I. & ‘ ~ } | check aa mary F 1. Felony H 3. Misdemeanor 4 5. Ofdinance Special Notes: as apply 2. Traffic Fatony 4. Traffic Misdemeanor | 6 Other ame Alias Race Pett UV) lan C harge Description Address Source 7" Phone -: Occupation . ae ' f) 4 f =1.4 i . The undersigned certifies and swe. The Person taken into papa tag aS that he/she has just and reasonable Groukés to believe, 4nd does believe thal the above named Oetendant committed the following violation of law e ‘ - | | committed the below acts in my presence, A was observed by 4 ; tots told D/Ss baw Dusen C) confessed to that he/she saw the arrested ptrson commit the below acts. admitting to the below facts. | was found to have commited the below acts, resulting from my (described) invest On the 4 Sd of OtteahéeC — »O2ny $08 am Apu. ADMIN — Victim's Name (Last, First, Middie) PTS Ts fade rp Local Address [Street [victim __ [CHARGES oer, igation, (Specifically include facts constituting Cause for arrest.) EI Ww =|. SI < wo a » <x QO 2 is < 5 x ‘ 5 . Ss ™ 1) ny L ms faa < ‘ fe (c — > i SA => |) ~ ; Al vs TZ feat. LH Tene FL g Niece d 7 abt - - c gt ty fiA le ot 7 » se =~ = 5 Le ee ere ee 7 ve ~ fp: Crib rot é STATE OF FLORIDA | harnoy sectity that Une toregorny OLINTY OF PALM BEA tips scopy of the record in my office ane Ye eH ePY auired by Hw. f— > § ' “ Signgatire al ArrgstingAnivestigative Officer e The fore i. nsirumMaNnt Was Sworn to of alfiemed and subscnbed before me this 4 md os \ i) L mare At Acces A aBtigative Stfice 4 ; a tH Kh) A LIP KL Miotary Pub ic, Clérk & Du Pihticd (F.8.8. Ard fy V9 at/orProduced identitication. Type 7.1 iF a 4 B. ’ WK. | PRS #@ ews DO Aaina OISTRIBUTION;: WHITE — Court Copy ADMINISTRATIVE 7 | _ 2S GAEEN — State Mtarnev YOIIAW | bean. Dikew Risen

Case 18-2868, D#Prent 278, 08/09/2019, 2628230, é of 648 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION DS JASON VANDUSEN, 6142 CASE NO. 02CF012204A99 PALM BEACH COUNTY SHERIFFS OFFICE Booking No, 2002343586 Agency case number 02-128821 iva ong STATE OF FLORIDA : [tt Boop vs. | ve 7 ey we She 2] ANTHONY LUIS ZAC FIGUEROA, W/M, mF a pa NO FILE FOR: GRAND THEFT The State enters a no-file because the elements of the crime cannot be proven beyond a reasonable doubt. BARRY E. KRISCHER, STATE ATTORNEY DATE: October 28, 2002 By: JILL ESTEY RICHSTONE Assistant State Attorney FL. BAR NO. 0928933 JER/sw CLERK AND SHERIFF TO RESCIND NO CONTACT ORDER abate. STATE GF FLORIDA * PALM BEACH COUNTY Ee | haraby certify that the foregoing 1s a let ae TE trys-sepy of line tecord in my office with Pe q ‘aoce Clinns, i Any As tequires by la, oo So Hig a DEPUTY CLERK ey

OBTS Number Dagyunest.278 08/09/2019, 2628220, Page479 of 648 3. Request for VYarrant Juvernia | 4, Request for Capias | Agency Name Agency Report Number ROYAL PALM BEACH POLICE DEPARTMENT | 8,5 |-|0,0,,3,8,1,.2 igueréa, Anthony Luis Zac Race ax 02) Crarge Description Charge Description Grand Theft Auto — | Charge Description Adcress that ihe above namad Defendant committed the following violalion cf law Agency ORI Number Flo, 9, 0,2, 8 ADMIN 0,0 eee cae PJ 1. Felony _]3. Misdemeanor | 1S. Ordinance pecial Noles. a5 apply. | | 2. Traffic Felony | } 4. Traffic Misdemeanor Neme (Last, First, Middie Victim's Name (Last, First, Middle) igueroa, Richard Jr. Phone cusiness Address (Name, Sireet) [victim [CHARGES [OEF | The undersigned certifies and swears that he/she has just and reasonable grounds to believe, and does beiieve The Person taken into custody ... XX committed the below acts in my presence. L) was Observed by ho told a i confessed to that he/she saw the arrested person commit the below acts acmitting to the below facts. was found to have committed the below acts. resulting from my {describec) investigation. On the _ 22nd _ day of ___October 00 at 12:27 | X A.M. C] P.M. (Specifically include facts constituting cause for arrest.) I met with victim Richard Figueroa, Jr., who told me that he allowed his brother, Anthony, to use his 1986 Mazda ick-up truck to drive a friend home to Okeechobee Blvd. and Cherry Road at about 8pm, on 10/21/00. Richard told me that he has always been very specific about the times and use he allows his brother to use the truck, to the extent that he has told Anthony that if the truck were not brought back in the allotted time, he would call the police and report the truck stolen. For this trip, Anthony told Richard he would be back in 30 minutes. At about 1 ‘15pm, Anthony called Richard to say that the truck had a flat tire, and that he would be right home. Richard asked Ant ony where he was and Anthony would not say. At about 1 :22am, on 10/22/00, Richard called the police department to report the truck stolen. I explained the seriousness about reporting a vehicle stolen, to the extent that is covered on the stolen vehicle affidavit. Richard lilled-out this form and signed the same without any hesitation. Richard further stated that he had to be at work in the morning and was concerned since he needed the vehicle to get there. At about 01:55am, Officer T.E. Murphy located and stopped this vehicle, near Huntington Woods and Royal Palm Beach Boulevard. Driving was 2 nd Anthony was in the passenger's seat. 1 responded to this location where the two were sfill inside the vehicle. Both subjects were placed under arrest for Grand Theft Auto. Anthony Figueroa, since he first had possession of the vehicle, depriving the victim of the same, and Luckett, for being in actual physical control of the vehicle, also depriving the victim use of his vehicle. | PROBAGBLE CAUSE STATEMENT When the victim arrived to reclaim his vehicle, he ins detect any evidence of a flat tire or use of a Spare tire Luckett never had permission to drive his truck. pected the tires and believed that they were the original tires and could not - He further wrote me another written statement, indicating to me that Figueroa went to the County Jail and went to the Juvenile Assessment Center. Ow = wig 7 la. ~~ WO ac [) S% bina patos, | ti} ” ait “fea? ; Te ” & — J 5 \ ul gat Pu UT sedatek Bell foto swe Balt | 1s, aT Ab w SWORN AND SUBSCRIBED BEFORE ME 6 - Co, _ < SIGNATURE OF ARRESTING | INVESTIGATING OFFICER kK 2 NOTAPY PUBLIC PGLERK OF COURT / POLICE OFFICER Eli Shaivitz #70 = 10-22-00 NAME OF OFFICER (PLEASE PRINT) 2 DATE 10-22-00 DATE DISTRIBUTION; WHITE -- Court Copy GREEN -- State Attorney YELLOW-- Agency PINK -- Agency GOLDENRG

PERS ones ee 58 BARA 202g Pages ofc . ee 4. Requesi for Capias Agency ORI Number . Agency Name - Agency Report Number ROVAL PALM BEACH POLICE DEPARTMENT | a6 [-|0,0,,3,8,1,2 ali BS: Felony |_}3. Misdemeanor a pecial Notes os ancl, 2, Traffic Felony | | 4, Traffic Misdemeanor | 16. Other Name (Last, First, Midald Alias Race @x “lFiguerda, Anthony Luis Zac Wp | {2 | Charge Description Charge Description Grand Theft (Auto) i =~ Race Sax YerDa | has just and reasonable grounds to believe, and do¢s balieve that tha above named Oefendant committad tha following vidlation of law, fl]; Juvernis Ly ADMIN CHARGE Viclim's Name (Last, First, Middle} ' ) rn s q C 7 Acdres The undersigned certifies and swears that he/she The Person taken into Custody .. XX) committed the bejow acts in my presence. LJ was observed by confessed to that he/sne saw the arrested person commit the below acts. admitting to the below facts. 0d) was found to have committed the below acts, resulting from my (described) investigation ontne 22M gay¢___—«s O'Ctober 00 1:55 20 at ADDITIONAL PROBABLE CAUSE: At above date and time, I was southbound in the 1300 block of Royal Palm Beach Blvd. Mazda pickup truck driving north on Royal Palm Beach Blvd. Ofc. truck which matched this description. I caught up to the truck and saw that It had Florida tag number D61XWE. This was the tag number of the stolen truck. I stopped the truck in the [00 block of Sherwood Dr. I found V/M GS be the driver and Anthony Luis Zac Figueroa W/M to be the passenger, Anthony Figueroa is the brother of the owner and was the original suspect in the stolen car case. Both subjects were taken into custody, secured, and placed in my patrol unit. I transported the to the police station where they were turned over to Ofc. Eli Shaivitz, ———— ee __, WhO fold Speeches sain ee __ X ALM. CJ P.M. (Specifically include facts constituting cause for arrest.) when I observed a white and maroon I Shaivitz had earlier taken a stolen vehicle report on a PROBABLE CAUSE STATEMENT se gry A eaulipg 5y TPT Hy eA LA ol Tae Ae 2 BOCK ‘ 4 i\ ER) & COMPTROL cr’ if VUES foe wi] SWORN AND SUBSCRIBED BEFORE ME Ec ‘ = SIGNATURE OF ARRESTING / INVESTIGATING OFFICER z NOTARY PUBLIC / CLERK OF COURT/P FFICER T.E. Murphy #100 2 10-22-00 NAME OF OFFICER (PLEASE PRINT) i DATE 10-22-00 DATE : DISTRIBUTION: = WHITE -CourtCopy = GREEN -- Slate Attorney § YELLOW--Agency PINK--Agency GOLDENRGO™

Case “we 278; 08/09/2019, “eo of 648 JB | | Case No:: Q0-11425CF AO2. "rt T of FL vs. ANTHONY LUIS ZAC FIGUEROA Ss ee eee CS ———— a ee Charges: GRAND THEFT (MOTOR VEHICLE Arrest# 2000346620 Bond# PO7-00274775 Type SB-PN | $ 3,000 A/C Date Od = CX) fudge Lp Ae Crt Rep. Rca be CO ASA ade. x DC ys a nt es Deft- fPres | Not Pres. Def. Co, ~W\WS CS Cy al ) Esq /@ SY Not Pres. _ : of. Co, oO Before the Court for: {NS ~*> C | : {Granted ODenied 1 with / Without Prejudice Withdrawn (© Court Resdrves Ruling © Written O rder to Follow O Warrant O Ordered OF Recalled © O Bon tat $ -——. | Cl See Below OCIVAlIso Covers C1 Sp Cond CO) Bond Forf COR: Disch/ Revoked /Reinstated PQ Bon ( Disch Revoked /Reinstated J SOR: Disch / Revoked / Rein tates C) Bond Forf Vacated (© Previous Bond Reinstated, if Bondsmatragrees (7 State failed to file charges (] Released OR. CI Deft Indigent © pp Appt O) Hrgonly PD Pres | _ O) Court Appts Evaluation for: O Drug Farm (©) DOC Non-Secure Bed by © Pre-Plea (1 PSI ordered by/within _-_ ss lays C} wéinput from DJJ / Staffing DEFT ENTERED APLEA OF: O NOTGUILLTY GUILTY © NOCONTEST ( BEST INTEREST C) TO THE COURT As Charged-Cts ee ee Lesser Cts Lesser Charge C) Sw & Test CO) AdvofRts (1) Waived PSI LesserCts____ Lesser Charge C1) ADJ GUILTY as Charged as to Cts LesserCts CI FOUND GUILTY as Charged as to C Lesser Cts CO ADJ W/HELD as to Cts | Cl SENT W/HELD as to Cts . | | FOUND AND ADJUDICATED DELINQUENT as to Cts A _ O) Dispo Order a follow / Filed OC FOUND. & ADJ NOT GUILTY as to Cts’. | CT Dismiss A Nolle Prosse Cts ra. \ Prob / Comm Control: O] Revoked 1 Reinstated (J Modified © Term. Successfully / Unsuccessfully (I SEE ORDER ASSESSING COSTS (O) SEE REVERSE SIDE FOR INSTRUCTIONS REGARDING FURTHER HEARING ©) Stip/Found: (violent) Habitual Off. 775.084 OO Stip/Found: Sexual Offender / Sexual Predator Stip/Found: P.R.R. SENTENCE: PBCJ: Cts: | /DoCc: : Cts: PBCJ: __ Cts: , /Doc: | Cts: CO W/Credit for Days /Mos./ Yrs. (Deft Remanded .1) Deft to remain on same rel. status pending sent. Conc / Consec / Co-Term w/cases / cts: CI Execution of Sentence Stayed (J Sentence Suspended (J Time served as to Cts eS es ee O) Youthful Off © Habitualofe OO Min / Mand: as to Cts ae eet ee ee ee C1] ABOVE SENTENCE TO BE FOLLOWED By: © Probation © DrugOffProb © Comm.Control CHI CI I - See Page 2 pag, tt HOT PALM BoA : sate OF FLORIDA * FP a“ peal B. STATE , : nA tHe foregoing is a wt ae hy eer Ny as “A apy af the recor in i i a ag TEQuil at AM/PM. Set / Remains Say PRésde HERO TIP TROCE Rm at AM/PM ort CLE ; CI Deft sign | DI date LC] Def Co CO} ASA a DEPUTY CLE C} Bondsman O Prob O sail ODT CGAL Notified by mail by: _ on / fo (J County Courthouse C} Courtroom, Criminal Justice Bldg. Courtroom, Criminal Justice Complex 205 N. Dixie, West Palm Beach 38844 State Road 80, Belle Glade 3228 Gun Club Rd., West Palm Beach IF YOU ARE A PERSON WITH A DISABILITY WHO NEEDS ANY ACCOMMODATION IN ORDER TO PARTICIPATE IN THIS PROCEEDING, YOU ARE ENTITLED, AT NO COGT TO YOU, TO THE PROVISION OF CERTAIN ASSISTANCE. PLEASE CONTACT THE ADMINISTRATIVE OFFICE OF THE COURT - 205 NORTH DIXIE HIGHWAY, ROOM §.2500, WEST PHVA BI ¢@ A? 39401TELEPHONE (661) 355-2431, WITHIN 2 WORKING DAYS OR YOUR RECEIPT OF THIS NOTICE. IF YOU ARE HEARING IMPAIRED, CALL 1-800-955-8771; IF VOICE , 1-800-955-8770 Form 61]

Case 18-2868, Document 278, 08/09/2019, 2628230, Page482 of 648 EXHIBIT GG

Case 18-2868, Document 278, 08/09/2019, 2628230, Page483 of 648 Page 1 UND TED STATES: DISIRICY COURT HPOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS a ee a a a a a a! Sa a cc: oe! cco So? Ge, Se See cee! Gee ce ee Ge? oe) a a a a? — S—! a VIRGINIA L. GLUEFFERE, Plaintiff, es GHISLAINE MAXWELL, Defendant. SSS ee ee ee ee ~*~ June 21, 2016 9217 am. GON Ft Db EN Da a i Deposition of JOSEPH RECAREY, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA® LEGAL SERVICES

Ol WB W WN 10 eae io 2 14 Lo 16 Ly 18 Lg Za Zi ee 23 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page484 of 648 APPEARANCE 8B: BOIS SCHILLER & FLEXNER, LLP Attorneys for Plaintiff 401 East Las Olas Boulevard Fort Lauderdale, Florida Seoul Bx s BRADLEY EDWARDS, ESQ. HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant 150 East 10th Avenue Denver, Colorado 80203 Ne JEFFREY PAGLIUCA, ESQ. JONES FPUSTER JOHNSTON «& ocTUBBS, PsA. Attorneys for Deponent 505 South Flagler Drive Suite 1100 West Palm Beach, Florida 33401 Pa JOANNE O'CONNOR, ESQ. ALSO PRESENT: Sandy Perkins, Paralegal Boies Schiller & Flexner Ryan Kick, Videographer MAGNA® LEGAL SERVICES Page 2

The text on this page is estimated to be only 42.26% accurate

KO OO =] OY 11 IZ 13 14 LS 16 Lf 18 19 20 Zelk Ze 23 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page485 of 648 INDE X Examination bY Mr. EHOWerds eee ¢esae6 me dee Se ee Boom QoaetOu so Me. Seam? sevetoaueee ececeoné ex PxatitneretOn 7 Mir, PoCglited .hter es 664 ERR aS Further Exeaminecion, by MS: SCOUIEZ s44¢0H8de26 0% FULrENer Examination by Mr. Pagliuca. o« 024 eseeaes A XM 3H aL BL Es RDepoct toa Bxeotbte 42. scecdeece erase weeee eee eacse Palm Beach Police Department Incident Report DepOSMETOn, Behe. 2. nae eee eee ee eee ee eee ee AH. StTacement DeO@OstElOn Babak. © Sart secdcteuntseeeeuueeeneceus CD with video (retained by Boies) DESO stELOM BxAvoie 4. wees ose oe ele eee eee eee ee Search warrant return DepOet tO Bt. ©. suseeeeeeeewcbedceeescaesnus Property receipts DepestiLod Bente. b> suet eee see eee eewae daa eas Additional search warrant returns DEOOSTEVOR Stott 7 cece dat es tantedweresoeeenes Probably cause affidavit DEDOSLELOM oto © «es6eenet 6 toeeee ee eeaaeene es Trash pull return Depoewie wom Beate 9 seeeeestceeweeeeaeuseeuaaes Folder with evidence MAGNA® LEGAL SERVICES Page 3

The text on this page is estimated to be only 48.98% accurate

10 11 Ee Lo 14 lS) 16 7 18 Lg 20 Zk we Zo 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page486 of 648 DeSOs teen Eenibat. 10 64468 445 od oe 8 eee Lig Investigative report Deco Letom Pxaiiott. Uh vaatee eee oa eee Ooo ae ee ee 165 CD with audio recording (retained by Boies) Pest cin: Exot J “geht eschee cee heee ee bees eee il, Supplement to incident report DeoO MEO Peale UZ. nae h 44. oa eee Oe aD Ee eS Z59 Rule 26 disclosure DeOOsi21On Exaile Ws othe eceee cee hee eee hee eee ZEZ Vol. 2 of prior Recarey transcript DS0OSLELen PxeaiOL.. Us gebeueee es oboe See once ees 292 Vol. 1 of prior Recarey transcript xxx Exhibit 11 was used on two different exhibits. MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page487 of 648 Page 10 JOSEPH RECAREY - CONFIDENTIAL Q. Most of the events that we are going to discuss today occurred, at least the investigation that we're going to discuss today, occurred in 2005 and 2006. So can you just tell us what your position was with the Palm Beach Police Department at that time? A. I was a police detective. oO; And did you investigate a person by the name of Jeffrey Epstein? A. lire nikelen he FALd. ae WO ez What was your role in the investigation of Jeffrey Epstein? A. I was the lead detective once the case was turned over to me by Michelle Pagan. Oh Okay. And as the lead detective, did you review all of the history of the investigation up to the point it was turned over to you? MR. PAGLIUCA: Object to form and foundation. THe, WLINGSS: COPPSCE. BY MR. EDWARDS: oF And was that one of your jobs as the lead MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page488 of 648 Page ll JOSEPH RECARBEY - CONFIDENTIAL investigator over a case, is to acclimate yourself to the history of the case? MR. PAGLIUCA: Object to form and foundation. Toe WN Ses Yeo. BY MR. EDWARDS: oP Just so that the record is clear, will you just give a brief pause in case Mr. Pagliuca has an objection? A. PALL. gee Oe.2 oF SO they Can. @lso CapLlure your answer: A. Okay. or In reviewing the history of the case, did you review prior police reports, police reports prior to you becoming involved personally? A. iL did. or Okay. And I've handed you what is marked as. Plhaintirit’ Ss Exhibit: 1; (The referred-to document was marked by the court reporter for Identification as Deposition Exhibit 1.) BY MR. EDWARDS: 0. Do you recognize that? A. Yes. MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page489 of 648 Page 17/7 JOSEPH RECAREY - CONFIDENTIAL Police Department incident report as suspects? MS: -sCHULYZ: Ob)ecu To form and foundation. BY MR. PAGLIUCA: oF These people, right? A. At that time, yes. oF Well, and then are you aware -- were there any suspects added in any subsequent reports, to your knowledge? A. Not that I'm aware of. Ox In fact, you did not seek a probable cause warrant for any other suspects in this case, COLECCE. MS« SCHULTZ: ‘Ob ect to form and Foundation. THE WIINBSs? Thac*’sS correcc. BY MR. PAGLIUCA: O:. And Ms. Ghislaine Maxwell is not listed in any of your Palm Beach Police Department incident reports aS a suspect in this case, correct? MS. SCHULTZ: Object to form and FOundat10N.. TOE: WLENEoos -NOt == 060; NOL @s 2 SUuSpecl 1 This. Case, m0. MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page490 of 648 Page 180 JOSEPH RECAREY - CONFIDENTIAL Exhibit 1. Are you with me? A. Une=hun. On, Okay. Again, this was information that was obtained by Detective Pagan, correct? A. VOLrreceE.. O. And it's true, is it not, that this alleged victim never claimed to have been recruited by Ghislaine Maxwell; true? MS. SCHULTZ Ob ]ect to form and FOuUnCarLon.. THE WITNESS: COEreceE. BY MR. PAGLIUCA: oF And this individual, alleged victim No. l, never identified Ghislaine Maxwell as being at Mr. Epstein's house when she was there, correct? MS. SCHULTZ: Object to form and foundation. THE WITNESS: I don't believe so. BY MR. PAGLIUCA: Os You don't believe so -A. I don't believe so. On That she ever identified Ghislaine Maxwell as being in the house? A. Right. MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page491 of 648 Page 181 JOSEPH RECAREY - CONFIDENTIAL Q. Okay. She never -- this individual, victim No. 1, never claimed that Ghislaine Maxwell paid her any money, correct? A. COLEeeL, Q. And this individual No. 1 never claimed that Ms. Maxwell instructed her what to wear, correct? A. Rag iit ‘oF This individual never claimed that Ghislaine Maxwell told her how to act, correct? A. COEVSCL: OQ. This individual never claimed to have met Ghislaine Maxwell ever, correct? A. I don't believe so, no. Oi This individual never claimed to even have spoken to Ghislaine Maxwell ever, correct? A. I don't believe so, no. 0. And when you say "I don't believe so, no," that means my statement to you is correct; is that CLO e. MS« SCHULTZ: ObJeCe LO: Lorm,. Touncdarion. THE WITNESS: Well, you're saying "ever." I don't know if she's ever, ever spoken to - MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page492 of 648 Page 182 JOSEPH RECARBEY - CONFIDENTIAL BY MR. PAGLIUCA: 7 To Detective Pagan. A. Right. To my knowledge, I don't know, because Detective Pagan is the one who actually interviewed her. So I don't know to the answer of "ever." So not to my knowledge. Os Certainly, nothing in Exhibit 1, Narrative 1 reflects that this individual ever met or talked to or spoke to Ghislaine Maxwell, right? A. Right. Not to my knowledge. Os And, indeed, you would agree with me that 1f this individual claimed that Ms. Maxwell had something to do with the events listed in Narrative 1, you would have folded up on it, as the investigating detective, right? MS. SCHULTZ: Object to the form. THE WITNESS: Either myself or Detective Pagan would have. BY MR. PAGLIUCA: oF Sure. And when you got the case six months later, if there hadn't been follow-up, you would have followed up on it, right? MS. SCHULTZ: Object to form. THE VINES S= Correct. MAGNA® LEGAL SERVICES

[— — 4 £O: Oo S&S] OF Ol aS O60 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page493 of 648 Page 187 JOSEPH RECAREY - CONFIDENTIAL Q. Okay. The person alleged to have brought the alleged victim No. 1 to Mr. Epstein's house is this Hayley Robson individual, correct? A. Yeo; Q. Okay. Then with regard to alleged victim No. 2, then this individual did not claim to have been recruited by Ms. Maxwell, correct? Ms. SCHULTZ: Ob JECE. THE WITNESS: Who would be victim No. 2? BY MR. PAGLIUCA: Oe Well, you can either go to the second page of Exhibit 1 and we can just follow down the victim information, or you can go to the body of the report, whichever is easier for you. MS. SCHULTZ: Can you use the initials? MR. PAGLIUCA: Sure. I can call them 1 or AH or whatever you want to call them. That's fine with me. BY MR. PAGLIUCA: oF So I'll just say alleged victim AH never claimed to have been recruited by Ms. Maxwell, correct? A. VOLLeCE. oF And alleged victim AH did not claim to MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page494 of 648 Page 188 JOSEPH RECARBEY - CONFIDENTIAL have spoken to Ms: Maxwell Gver, Correct? MSs -sCHULTZ: Ob)]eEce To form, THE WITNESS: It's been a while since I read this report. BY MR. PAGLIUCA: QO. Sure. Is it fair to say, Detective, that this investigation occurred some 12 years ago, Glace A. Yeah. Well, yeah. Os And is it fair to say that you've conducted quite a few investigations over your career? Aus Leos oF All right. And it's fair to say that it would be impossible for you to remember all the details of this investigation as you sit here today, correct? A. COLPeCE, Of And you've been referring to Exhibit 1 frequently throughout this deposition, correct? Ais eos Q. And that's because you don't have any present memory of these details, correct? MSs DCHULTZ; -GbjJecr LO form, EPoundaricon. MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page495 of 648 Page 189 JOSEPH RECAREY - CONFIDENTIAL THE WITNESS: I have some recollection, but I'm not going to have exact dates and times off the top of my head. BY MR PAGLIUCA: Q. pure. A. You know, I spoke to over 33 girls regarding this case. So when you say an initial, it takes me a little while to go through the entire list. But to have specifics, I'm not going to be able to remember the exact specifics of -- of the PepOLrL: Q. I appreciate that. So we can take our time, but do you recall, did AH ever identify Ms. Maxwell has someone she spoke to? 7: I don't recall. Cy, You don't recall at all’? A. I don't recall that she had mentioned Ms. Maxwell. O-. And if she had, you would have put that in your report, correct? A. I believe so, yes, I would have. Ou Pal. 2 Oii Cx And so the absence of alleged victim AH MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page496 of 648 Page 190 JOSEPH RECAREY - CONFIDENTIAL referring to Ms. Maxwell means that she didn't, ie Gianc ae MS< SCHULTZ Ob)eCuU To form: THE WITNESS: Say the question one more time. BY MR. PAGLIUCA: Os. When we go through this report, and I've gone through it, if any of the alleged victims had identified Ms. Maxwell as someone that they spoke to at Mr. Epstein's house, you would have listed that in your report, right? MS. SCHULTZ: Obj ect. to form. THE WITNESS: I believe I would have, yes. BY MR. PAGLIUCA: 0. Veatis You tried to be thorough and accurate when you were writing your reports, right? As Less On, And, certainly, you've indicated on direct examination that the identity of people who were at the house was something that was important to your investigation, correct? A. Les oF And that's why you did trash pulls, right? MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page497 of 648 Page 191 JOSEPH RECARBEY - CONFIDENTIAL A. Tees Os And then you asked various individuals who was there when you went to Mr. Epstein's house, ie Giane ae A. Correct. QO. And you then, to the best of your ability, recorded those answers, I take it, as to who was there, right? Es Leos 0. And with regard to AH, she never said anything about Ghislaine Maxwell being at Mr. Epstein's house, did she? MS; SCHULTZ? Ob ]ect to form and FOUnCarLCn.. BY MR. PAGLIUCA? Cs TO Your A. I don't believe she did. Q. Okay. And if she did, it's likely that you would have recorded it, correct? A. Correct, and it would be on the -- it would be on the tape. 0. Right. She never claimed, AH, that Ms. Maxwell Deild ner; tight? MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page498 of 648 Page 192 JOSEPH RECARBEY - CONFIDENTIAL MSy sGHULTZ: Ob JecE To form: and foundation. THE WILINESS? COrrect.. BY MR. PAGLIUCA: Q. She never claimed that -- AH never claimed that Ms. Maxwell instructed her about what to wear, COLrrec.: MS. SCHULTZ: Ob ecu. to the orm. THE WITNESS: CoOrrecce. BY MR. PAGLIUCA: oF AH never claimed that Ms. Maxwell told her how to act at Mr. Epstein's house, correct? MSs. DCHULTZY Ob 7eCE To ToOrm., THE WEeENE So? COrrEeCeE. BY MR. PAGLIUCA: 0. AH never claimed to have met Ghislaine Maxwell anywhere, correct? MS< SCHULTZ: ObjeCc Lo form. THE WITNESS: I don't believe so, no. BY MR. PAGLIUCA: Os Okay. If we go on to individual alleged victim No. 3, AY, the same question: AY never identified Ms. Maxwell as someone she knew or interacted with in any fashion, correct? MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page499 of 648 Page 193 JOSEPH RECAREY - CONFIDENTIAL Ms} sGCHULTZ: Ob }ecE To form. THE. WITNE OSs NO. BY MR. PAGLIUCA: O. No, She did not? A. No, She did not. O% Okay. The same with individual No. 4, alleged victim FP: Again, FP never claimed to have met with Ms. Maxwell, correct? MS; SCHULTZ? Ob ]ect to form and FOuUnCarLon.. THE WITNESS: I don't believe so, no. BY MR. PAGLIUCA: Os Okay. And FP never identified Ms. Maxwell as someone being at Mr. Epstein's house, correct? MS. SCHULTZ: Object to form and Foundaclion:. BY MR. PAGLIUCA: 0. And if you need to look at your report -A. No, I don't -- I don't believe so. The only people that recalled Ghislaine at the house was == Sjoberg? A. Johanna Sjoberg. Who was over the age of 18, correct? MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page500 of 648 Page 194 JOSEPH RECAREY - CONFIDENTIAL MSy sGCHULTZ: Ob JecE To form and foundation. THE WITNESS: And Venero, Christina Vener. BY MR. PAGLIUCA: Os Who is an adult as well? MS. O'CONNOR: Object to form. THE. WLINE SS: Yes. BY MR. PAGLIUCA: O So out of your entire report, the only two people who ever said anything about Ms. Maxwell were Ms. Sjoberg, who I believe was 23 when you interviewed her? A. Right, but she was -MS: SCHULTZ: Obyect to form and FOoundalion:. THE WITNESS: She was -- she had worked there for quite some time, so you would have to back up, I think, a year or two. BY MR. PAGLIUCA: Oi She was an adult when she worked there? A. Right. She was over the age of 18, right, let's put it that way. oF And she was not listed by you as a victim MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page501 of 648 Page 195 JOSEPH RECAREY - CONFIDENTIAL as part of this case, right? A. Correct, because it was between two consenting adults. os Exact... And so that's Ms. Sjoberg, and then the other individual, I think you said Bolero; is that Eoin 2 A. Venero, Christina Venero. She's a -O. Adult masseuse, correct? A. Yes. I remember she had lots of tattoos. oF Tote, aie. But the 17 individuals that you listed in Exhibit 1, none of those individuals ever said the word -- the words "Ghislaine Maxwell" during the course of this investigation to you, correct? MS<« SCHULTZ: Ob }eec To: -rorm..and foundation. THE WITNESS: I don't believe so. It would be on the tapes if they did. BY MR. PAGLIUCA: Oi, Well, or it would be in your report, rue he. MS. SCHULTZ: Object to form and foundation. MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page502 of 648 Page 196 JOSEPH RECARBEY - CONFIDENTIAL THE WITNESS: Either in the report or on the tapes. BY MR. PAGLIUCA: Os That's an interesting point, so let's talk about that for a moment. This report, this Palm Beach Police Department incident report, Exhibit 1, is a summary of your investigation, correct? A. COEPSCE: Os And these recitations of your interviews are abbreviated summaries, correct? A. DOL EeCr. OQ; And so you're typing into this report parts of it but not every word verbatim into the LepOL cy COrrece. A. Is) Gite Oi, And, again, the originals of these tapes are somewhere with the FBI at this point, correct? MS. SCHULTZ: Object to form and Foundation: THE WITNESS: Correct. Or at the State Attorney's Office. BY MR. PAGLIUCA: O-. Are you aware of any of these originals MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page503 of 648 Page 203 JOSEPH RECAREY - CONFIDENTIAL That would be one. Probably victim JB would be another. I believe there was a victim ML, as well. O- Let me ask this question: As you sit here today, do you know who the subjects of the four counts that are referenced on the first page of Exhibit 7 are? A. If I went through the entire PC affidavit, I could -- I could tell you who. But I just named three. oF Okay. A. pO, Jake 2 Said, 1. Can co through 2c and tell you who exactly those four counts were for. 0. Okay. We are limited to four, though, FiCgnL? A. Four instances. MS. SCHULTZ: Object to form. BY MR. PAGLIUCA: 0. Right. And then throughout this entire 22-page, Palm Beach Police Department affidavit, Ms. Maxwell's name does not appear in here once, does it? MS. SCHULTZ: Object to form. THE WITNESS: I don't believe so, no. MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page504 of 648 Page 211 JOSEPH RECAREY - CONFIDENTIAL A. COLrrecE.. QO. And then Mr. Epstein is arrested and ends UO pleagince Guilry and all OF That, 21g? Mo« SCHULTZ: Obj)ecE te form. THE WITNESS: I think there was a non-prosecution agreement prepared between the Feds and some kind of agreement was made. But, yes, he did end up pleading guilty. BY MR. PAGLIUCA: O Ad 22 MC Now, based on the questions that were asked of you in the grand jury, it's fair to say that Ms. Maxwell was not a target of the grand jury's investigation, correct? MS: SCHULTZ: Obyect to form and FOoundalion:. THE WITNESS: Not based on the questions that the state was asking me, no, the state wasn't... BY MR. PAGLIUCA: Oi, In fact, it's fair to say that you never said Ms. Maxwell's name in the grand jury, right? MS. SCHULTZ: Object to form and foundation. MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page505 of 648 Page 212 JOSEPH RECAREY - CONFIDENTIAL THE WITNESS: No. Based on the questions that the state was asking, no. BY MR. PAGLIUCA: OQ. Were you aware of who was being issued Subpoenas by the grand jury? A. No. But it wasn't the actual subpoena from the grand jury; it came from the State Attorney's Office. Os At the direction of the grand jury, CaOuUGiy, Wergnie? MS« SCHULTZ: ‘Object to torm. and FOuUnCaELOn.. THE WITNESS: I don't know. Again, I don't know. BY MR. PAGLIUCA: C:. IT would like to talk a little bit about the surveillance that you initiated at Mr. Epstein's house, oKay? Can you tell me when the surveillance began? A. It would have started under Detective Pagan and gone through -Of The entire investigation? A. Pretty much trash pulls. We stopped the MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page506 of 648 Page 213 JOSEPH RECARBEY - CONFIDENTIAL actual physical surveillance sometime during the investigation. But it would have started under Pagal. Ov. Okay. Do you recall in what -- well, how was surveillance conducted, if you recall? A. I didn't conduct it personally, no. That would have been under plainclothes unit team. They would have sent out a vehicle and recorded vehicles coming and going and actual physical surveillance. oF So physical surveillance means eyes on the PLOper Ly, COLrrecEe: A. Regn t: Q. And eyes on the property by a police officer, correct? A. VOLLeCE, oF And that police officer would be charged with the obligation of recording the incomings and outgoings of people to the property, correct? A. VOLLeCE, oF Is there a log that's maintained during surveillance? A. I'm not sure who -- if there was a log or not. I know that they set up a vehicle with cameras facing -- facing Epstein's residence. MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page507 of 648 Page 214 JOSEPH RECAREY =: CONP IDENT LAL Q. And so these were video cameras? A. CORPS CE. Oh. And so whoever was coming and going, whenever -- an officer saw somebody coming or going, they would videotape that person; is that correct? A. Or they would just leave the video rolling, time lapse. QO. And did you have the opportunity to observe any of that video? A. I did observe a couple, but the person who actually set it up would review it and then submit a supplement to the report. Q. Okay. It's true that none of the video of the surveillance led to the identification of Ghislaine Maxwell as coming or leaving the house during the time of surveillance, correct? MS: SCHULTZ: -Ob)Jece. To: form and FOundat10n.. THE WITNESS: I don't know. I didn't see all of the video, so I can't -- I can't attest Lo Ear. BY MR. PAGLIUCA: OC: Okay. Did anybody report to you that Ms. Maxwell was seen coming or going? MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page508 of 648 Page 215 JOSEPH RECAREY - CONFIDENTIAL Mos SCAULEZ2 ObjveCe tO 2oOrm, LoOunde cic. THE. WLINESS? iL don't recall. BY MR. PAGLIUCA: oF If someone had reported to you that Ms. Maxwell was seen coming or going, you would have recorded it in your Palm Beach Police Department LnCLOei:. KepOrl, Exhibit NoO«~ tp COorrecr: MS. SCHULTZ: Objvecu. To form and FOunGa cao. THE WITNESS: I would have told the officer who was conducting the surveillance or reviewing the video to document it in the supplements. BY MR. PAGLIUCA: Q. And there is no documentation in the Supplement of Ms. Maxwell either coming or going from Mr. Epstein's house during this time frame, COrPPrect.: MS. SCHULTZ: Object to the form. THE WITNESS: I don't believe so. I don't -- I don't -- I don't believe so. BY MR. PAGLIUCA: 0%; And, again, so we're on the same page, when you say "I don't believe so," I interpret that MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZL Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page509 of 648 Page 241 JOSEPH RECAREY - CONFIDENTIAL THE WLINESS: COrrect. BY MR. PAGLIUCA: Q. And none of these individuals was employed aS a massage therapist at the time of their alleged involvement with Mr. Epstein, correct? A. COrreeL, oe Fach of these individuals, as I recall, claimed to have been paid directly by Mr. Epstein or Ms. Kellen, correct? MS«. SCHULTZ: Ob yect To orm. and foundation. THE WITNESS: COLreceE. BY MR. PAGLIUCA: OQ. Most often, these individuals, these 1/7 individuals, were paid directly by Mr. Epstein, correct? MS. SCHULTZ: Ob) Jece to: form and FOundat10n.. THE WITNESS: Mr. Epstein or Sarah Kellen. BY MR. PAGLIUCA: oF Okay. None of these individuals identify Ms. Maxwell as someone who was paying them money, correct? MS. SCHULTZ: Ob )jecc To: Form..and MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page510 of 648 Page 242 JOSEPH RECARBEY - CONFIDENTIAL foundation. THE WITNESS: I don't believe so, no. BY MR. PAGLIUCA: QO. And each of these individuals identified receiving cash, correct? MS: -sCHULTZ: Ob)4cU clo the form. Tne: WINE OO: COPPrECT. BY MR. PAGLIUCA: i: Bach of these individuals claimed varying amounts, generally between $200 and up to $1,000, COLESCL. MS. SCHULTZ: Ob ]ect. to form. THE WITNESS: COorrecce. BY MR. PAGLIUCA: 0: According to each of these individuals, Mr. Epstein, when the massage was over, would either hand them the money -- that happened according to these individuals, right? MS. SCHULTZ: Object to form. THE WITNESS: At times, yes. BY MR. PAGLIUCA: Ok. Or Mr. Epstein had laid out the money somewhere and directed them to where to go get it, correct? MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page511 of 648 Page 25/7 JOSEPH RECAREY - CONFIDENTIAL A. I don't believe clothing was seized. OO To your knowledge, did you seize any property belonging to Ghislaine Maxwell from the home? MS» sGHULTZ: Ob }ece to form: and foundation. THE WITNESS: I'm not sure. Not to my knowledge. BY. Mo< SCAULTA: Os Okay. No one ever came to you and said, Could you please return these items to Ms. Maxwell, COLrecE MSs SCHULTZ: Ob JeCE To ToOrm. THE; WETNESS: No. BY MS. SCaUiTA. oF All raght. You did that with Janush? A. Yes, OG: Nad DhOLOs and == oP But nothing like that ever happened with Ms. Maxwell, correct? MS: SCHULIZ¢ “ObjJGcC.. FO: LOrm. THE WOIEINESS: NO. BY MS. SCAU A. oF Ms. Maxwell was not present when you MAGNA® LEGAL SERVICES

[— — 4 £O: Oo S&S] OF Ol aS O60 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page512 of 648 Page 259 JOSEPH RECAREY - CONFIDENTIAL Q. Any way that you get contacted by a police officer, if they put it into your database, it will come up when you do the CAD search, correct? A. Right. Os And that's all that came up with regard to Ms. Maxwell, was her name was somewhere in the system. Do you know or not Know? MS« SCHULTZ: Ob vecu. TO form and Founda tac. THE WITNESS: I don't know. MR. PAGLIUCA: Okay. (The referred-to document was marked by the court reporter for Identification as Deposition Bxhibit 122) BY MR. PAGLIUCA: oF I have handed you what has been marked as Deposition Exhibit 12, which I will represent to you are the Plaintiff in this case, Ms. Giuffre's Rule 26 disclosure. I want to just go through very quickly and ask you if you know any of these individuals. So, let's start with No. 1, Virginia Giuffre. Have you ever met Virginia Giuffre? A. No. MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page513 of 648 Page 260 JOSEPH RECAREY - CONFIDENTIAL Q. Have you ever talked to her? A. Ti COm tk eect. oO. Do you know what information that she may have that's referenced below? Conducted is the Subject of this action. Do you have any knowledge Of Thar: MS. O'CONNOR? ObJeCcE fo: Form, THE WITNESS: No. BY MR. PAGLIUCA: oF Number 2, Ghislaine Maxwell, I'm going to come back to her. Number 3, Juan Alessi, you did interview Mr. Alessi, correct? As Teo oP I have seen a transcript of that interview, and I have seen Exhibit 2, which is a Lranscriapl. Or «he 1nterview With Ms. BE: | want to ask you a couple of questions about the transcription process. As I understand your testimony previously, the electronic recordings are sent somewhere, you don't know where, for transcription; is that right? MS. SCHULTZ: Object to form. THE WITNESS: I didn't request a MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page514 of 648 Page 274 JOSEPH RECAREY - CONFIDENTIAL different investigators Mr. Black uses ina particular calendar year, do you? MS SCHULTZ: Ob)eCU To form, THE WITNESS: No. BY MR. PAGLIUCA: OO And so you don't know whether Mr. Black's association with this law firm was in connection with Mr. Epstein's case or some other case, do you? MS. sCHULIZY Ob ;JeCc TO tOLm:, THE WITNESS: I worked this case, nothing -- nothing but this case for an entire year. This was my only case for a year. BY MR. PAGLIUCA: O. Okay. hat*s 20? A. Tf it walks like a duck. MS. SCHULTZ: Objection. BY MR. PAGLIUCA: 0: Okay. So we're finished with Dershowitz. Keep on going. A. Number 20, ODVLClSs]), ie Os Okay. And you've talked about her? A. Right. 0: And, again, she never discussed Ghislaine Maxwell with you, correct? MAGNA®© LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page515 of 648 Page 278 JOSEPH RECAREY - CONFIDENTIAL O:; Rights .60 You're 75. 6.0 1 Wank you == 2 want to take a moment and read what's under 7/5: "Detective Recarey was the chief investigator of the crimes committed at Jeffrey Epstein's Palm Beach mansion." Is that true? MSs -sCHULTZ: Ob Jece te form. Toe WEINER Sot Yes. BY MR. PAGLIUCA: oF "And has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct and interaction with underaged minors." Tell me everything that you believe you know about Ghislaine Maxwell's sexual trafficking COnCUCE. MSs: SCHULTZ: ODVeCE =O: LOrm, THE WiIEINESS: fT, Gon’. BY MR. PAGLIUCA: Q. So that's inaccurate, then? I mean, you have no knowledge about Ghislaine Maxwell sexually CrarrtlCcking. anybody, do you? MSs SCHULIZ¢ -ODJGCe. FO: LOrm. THE WITNESS: Not with -- not with the girls that I spoke with, no. MAGNA® LEGAL SERVICES

[— — <> AO: ©) =] Oo) Os [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page516 of 648 Page 279 JOSEPH RECAREY - CONFIDENTIAL BY MR. PAGLIUCA;: rP OO PF Oo Q. BUE that*S Your 2nvesti1catllon, Ti.gne? lg Be 4 Okay. IG Be Let's see. Seventy-six. Okay. And you've talked about her. Whatever happened to her, do you know? MSs. SCHULTZ: Ob JeCE to rtoOrm, BY MR. PAGLIUCA: ie A. ae CoOfrec.. A. Os with your again? > tO -P Ce. as one Of A. Haley Robson? No. She was never charged, as I understand it, VOLT eC. And after you spoke to her in connection investigation, did you ever speak to her NO 4 Okay. David Rogers, 7/. And you know him because he was identified the pilots for Mr. Epstein, right? Right. MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page517 of 648 Page 289 JOSEPH RECAREY - CONFIDENTIAL in your mind, Taght: Correct? MS. SCHULTZ: Object to the form. THE: WEINER So< Yes. BY MR. PAGLIUCA: Q. And you're a peace officer, obligated to arrest when a felony 1S committed in your presence, correct? A. COPPeC. 4 Oo: And the possession of child pornography is a felony, correct? A. COE PSCL: Oh And had you seen any child pornography in Mr. Epstein's house when you were there installing these cameras, you would have done something about Ley COLreCt? MS. SCHULTZ: Object for form. THE WITNESS: Right. BY MR. PAGLIUCA: Oo}: You wouldn't have just walked out and said, Nice pics, have a nice day, correct? A. VOLReCL. oF So is it fair to say the entire time you were in Epstein's house, whether it's 2002, 2003, you did not observe any child pornography, right? MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page518 of 648 Page 290 JOSEPH RECARBEY - CONFIDENTIAL MSs sCHULTZ: Ob }ece. to The form. THE WITNESS: Not in the areas I was in. BY MR. PAGLIUCA: Os You don't recall seeing any pictures of naked women, do you? MSs SCHULTZ: Ob Jece te form, THE WITNESS: Again, I was only confined to where that desk was. That's where I set up the camera, and then after it was set up, I left. BY MR. PAGLIUCA: QO. Okay. But, again, all I'm asking you is wherever you were, you didn't see any pictures of naked women? A. Right. No, I didn't see any. oF And at the time you recall that he had these surveillance cameras already installed; is that true? Other cameras, the clock cameras? MSs: SCHULTZ: ODVECE =O: ©oOrmm, THE WITNESS: I'm not sure if he had the cameras installed or not. I can't recall. BY MR. PAGLIUCA: Oo; Why would he need your cameras if he already had cameras? MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page519 of 648 Page 300 JOSEPH RECAREY - CONFIDENTIAL None of these alleged victims claimed to have ever traveled with Mr. Epstein, correct? MSs SCHULTZ: Ob Jecr te form, THE WITNESS: No. BY MR. PAGLIUCA: OO No, they did not? They did not travel With Mr. HpStein, raght? Mo« SCHULTZ: Ob)JeEcE toe form. THE WITNESS: I don't believe so, no. BY MR. PAGLIUCA: OO None of them reported that to you? A. Not reported, correct. Oo: None of them reported to you that they ever spent the night with Mr. Epstein, did they? MS. SCHULTZ: Object to form. THE WITNESS: I don't believe so. BY MR. PAGLIUCA: Q. None of them ever reported being trafficked by Mr. Epstein to other men, correct? MS« OCHULTZ; -ObjJecr LO Torm, Foundation. THE WITNESS: I don't believe so. BY MR. PAGLIUCA: 0: The only other men that any of these alleged victims -- the only man that any of these MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page520 of 648 Page 301 JOSEPH RECAREY - CONFIDENTIAL alleged victims ever claimed to have any contact with that was sexual in nature was Mr. Epstein, COLrrec.: MSs SCHULTZ: Object. to form and foundation. PHE. WEINBOo: Yes. BY MR. PAGLIUCA: Os Okay. None of these alleged victims ever claimed to have been sent to another location to have sex with another man, correct? MSs SCHULTZ: ObjJect to form: and FOuUnGaELOT. THE WITNESS: I don't believe so. BY MR. PAGLIUCA: On Meaning my statement is correct; is that rune? MSs SCHULTZ? sObjJeGCL. EO: LOrim. BY MR. PAGLIUCA: 0. I'm just trying to -A. Meaning I don't believe they've ever said that. I don't recall any of them ever saying... O.. Had they claimed that they were sent somewhere else to have sex with another man, you would have followed up on that, correct? MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page521 of 648 Page 302 JOSEPH RECAREY - CONFIDENTIAL Mo: cCHULTZs ObyeCcu. fo form. EAE. WEEN OSs “<CORrTSCT. BY MR. PAGLIUCA: OQ. And none of them ever claimed to have been sent to another location to give another man a Massage, Correct? MS< SCHULTZ: Ob)eCU: to form, THE WITNESS: No, not the victims. BY MR. PAGLIUCA: OQ. Rignt. what's who 1m talking abou. L belicve TE ¢:.d. Who is an adult, right? MSs. DBCHULTZY Ob 7eCcE to Torm., THE WETNESS! -RiOnE. BY MR. PAGLIUCA: Oh We covered this, I believe: None of them ever was on Mr. Epstein's airplane, correct? MS< SCHULTZ: ObjeC>G LO form. THE WITNESS: I believe one of the victims were, but not to a private island. I think they went -- they didn't go to a private island; they went to some other trip. BY MR. PAGLIUCA: oF I think maybe you're referring to AH, who MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page522 of 648 Page 303 JOSEPH RECAREY - CONFIDENTIAL went to New York but on a commercial flight. Does that jog your memory? BY MR. BY Mr. oF MSs SCHULTZ: Ob ]ecE toe Lorm. THE WITNESS: No. PAGLIUCA: Okay. Do you recall who it is? It would have been FP. Okay. Was on Mr. Epstein's airplane? MSs SCHULTZ: Obj7eCE to toOrm., THE WITNESS: I believe so. PAGLIUCA: Would that be reflected in Exhibit 1? MSs. SBCHULTZY Obj7eCE to Torm: THE WITNESS: But she flew alone. Lt wasn't like Epstein was there. She went someplace else, not to his private island, nothing to do with Epstein. It was something she wanted to do. And I think she flew on his plane, but it was, like, her by herself. BY MR. r>P OO PF Oo PAGLIUCA: Alone. Right. With a pilot? Right. MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page523 of 648 Page 304 JOSEPH RECARBEY - CONFIDENTIAL MSs sCGCHULTZ: Ob}ecE to form. BY MR. PAGLIUCA: oP None of the alleged victims in your investigation claimed to have gone to the Caribbean island of Little St. James, correct? MSs SCHULTZ: Ob ]Jece te form, tae WINE Sos NO. BY MR. PAGLIUCA: O% "No" meaning they never went there, Colrec.. MS« SDCHULTZ? ‘Objyectk to 7toOrm, THE WITNESS: Not that I'm aware of. BY MR. PAGLIUCA: QO. None of the alleged victims ever went to Mr. Epstein's New York residence, to your knowledge, COMleeCr MS. SCHULTZ: “ObjJGCE. FO. LOrm. THE WITNESS: Not that I'm aware of. BY MR. PAGLIUCA: ©. None of them ever reported that to you? MS: SCHULIZ: “ObjJGCE. EO: form. THE WOIINESS: No. BY MR. PAGLIUCA: oF Okay. And none of them ever claimed to MAGNA® LEGAL SERVICES

[— — 4 £O: CO SI OF Ol =e Go©6 UCDO [— L2 14 3 16 1] 16 eS, 20 Zak ZZ Ze 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page524 of 648 Page 305 JOSEPH RECARBEY - CONFIDENTIAL have been outside of the country with Mr. Epstein, ever, correct? MS< SCHULTZ ObD)ecU- co The orm. THE WITNESS: Not that I'm aware of. MR. PAGLIUCA: Can we go off for a second? Time check. THE VIDEOGRAPHER: Off the record at 4:13. (Thereupon, a recess was taken, after which the following proceedings were held:) THE VIDEOGRAPHER: On the record at 4:14. BY MR. PAGLIUCA: Os Can you take a look at Exhibit 4, please? A. Which one is 4? oF Four is the True Copy. That's what it Says at the top. Exhibit 4. Six pages. A. Less Os, Do you have that? A. Yes, Sir. OF There's yellow highlighting on the exhibit tEhau’sS in £ronk Cf Vou. Do you know how that got there? A. Ne. 0%. And there's a -- there are numbers, item numbers. Do you see that in the left column? MAGNA® LEGAL SERVICES

OO: sl) “OY so ae “Go ‘RO 10 ial 2 13 14 is 16 ey aI Lg 20 Zk Zz Ze 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page525 of 648 Page 365 CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, the undersigned authority, certify that JOSEPH RECAREY personally appeared before me and was duly sworn. WITNESS my hand and official seal this 24th day of June, 2016. KELL ANN WilLLIS, RPR;, GRR Notary Public, State of Florida My Commission No. EE911443 Expires: 2/16/16 +++teteet++et+et++t+t+t+ st MAGNA®© LEGAL SERVICES

CoO =) OY VU 10 11 LZ ils 14 ID 16 Ly 18 Lg Zu Zk Zz Ze 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page526 of 648 Page 366 Ch RT fF otc AT STATE OF FLORIDA ) Ss COUNTY OF MIAMI-DADE ) I, KELLI ANN WILLIS, a Registered Professional, Certified Realtime Reporter and Notary Public within and for The State of Florida, do hereby certify: That JOSEPH RECAREY, the witness whose deposition is hereinbefore set forth was duly Sworn by me and that such Deposition is a true record of the testimony given by the witness. I further certify that I am not related to any of the parties to this action by blood or marriage, and that I am in no way interested in the outcome of this matter. IN WITNESS WHEREOF, I have hereunto set my Nand this 24th day of June, Z0LC. KELLI ANN WiLbIS, RPR, CRR MAGNA® LEGAL SERVICES

Case 18-2868, Document 278, 08/09/2019, 2628230, Page527 of 648 EKAHIBIT HH

Case 18-2868, Document 278, 08/09/2019, 2628230, Page528 of 648 ase L:15-cv-07433-RWS Document 435-3 Filed 09/15/16 Page 2 of 6 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 EDWARDS, et al., Plaintiffs / Counterclaim Defendants, v. DERSHOWITZ, Defendant / Counterclaim Plaintiff. / AFFIDAVIT OF JUAN P. ALESSI REGARDING KNOWLEDGE OF ALAN M. DERSHOWITZ A. Introduction 1. My name is Juan P. Alessi. { make this declaration voluntarily and without compensation on personal knowledge concerning Alan Dershowitz and his visits at my former employer Jeffrey Epstein’s home in Palm Beach, Florida. 2. I worked for Mr. Epstein from January 1991 to December 2002 as a full-time employee performing maintenance services and then also became the manager for the home on 358 El Brillo Way in Palm Beach, Florida. 3. Since Mr. Epstein was investigated and arrested, [ have spoken with police, favesd gators, and attorneys concerning my time working for Mr. Epstein. 4. On September 8, 2009, I gave a deposition in the case captioned Jane Doe No. 2 v. Jeffrey Epstein, Case No. 08-CV-80119 in which I truthfully answered the questions posed by the attorneys. I also gave a sworn statement on November 21, 2005 to GM_01197

: DO /09/2019. 2628230, Page5S29 0f648 = ee Case 1:15-cv-07433-RWS Document 435-3 Filed 09/15/16 Page 3 of 6 Detective Joseph Recarey of the Palm Beach P.D. during their investigation of Mr. Epstein. 5. [have reviewed the statements that Bradley Edwards and Paul Cassell attribute to me in their papers in the cases against the Government and against Mr. Dershowitz. Because I do not believe they accurately reflect the statements I previously made, I submit this affidavit to have my statements accurately reflected and made clear on the record. B. Summary of My Knowledge of Massages at Mr. Epstein’s Palm Beach Home 6. AsI stated in my deposition, a massage was like a treat for all the guests at Mr. Epstein’s home. Mr. Epstein usually received his massages in his private suite, but guests would also be given massages in their respective rooms or by the pool area. 7, There were between fifty (50) to one hundred (100) masseuses — mostly women but also some men - who would come to give massages during this time. I provided names of masseuses in my deposition. 8. As I stated in my deposition, I was unaware of any masseuses being under the age of 18. I believed that the females’ age ranged from overage to maybe mid-forties. As I stated in my deposition, I received as a gift a massage from a male masseuse at Mr. Epstein’s home in Palm Beach. 9. In my deposition, I was asked about cleaning up after massages. I stated that when I cleaned Mr. Epstein’s bedroom suite, which included the bathroom of Ms, Maxwell, after massages, I would, on occasion, find vibrators and sex toys. I have specific recollection of finding these items in the sink of Ms. Maxwell’s bathroom. I did not State or imply that vibrators or sex toys were found after massages in other rooms used by guests because that was not the case. Guests having massages did not have 2 GM_01198

Case 18-2868, Document 278, 08/09/2019, 2628230, Page530 of 648 10. ti: 12. Case 1:15-cv-07433-RWS Document 435-3 Filed 09/15/16 Page 4 of 6 massages in Mr. Epstein’s private bedroom suite. This area was private and off-limits to guests, which I explained to the lawyers during my deposition. As I said in my deposition, massage tables were located in almost every room, including guest rooms and by the pool. I never found, and never heard anyone in the ause andi a vibrator or a sex toy in the same room where any guest, including Alan Dershowitz, had a massage. The following statement made by Virginia Roberts’s attorneys in a filing on January 21, 2015 is not accurate and is a misrepresentation of what I said in my deposition: “The private, upstairs room where Dershowitz got his ‘massages’ was one that contained a lot of vibrators - Maxwell had ‘a laundry basket . . . full of those toys’ in that room.” . Summary of My Interaction with Alan M. Dershowitz During the approximate thirteen years I worked for Mr. Epstein, I believe I saw Mr. Dershowitz visit Mr. Epstein’s Palm Beach home approximately four or five times a year. I recall driving him to the airport on multiple occasions. At the time, I understood that Mr. Dershowitz was a famous lawyer. His visits to the house would typically involve a group of intellectuals or business men in social, but professional type gatherings. . [can recall that Mr. Dershowitz had a massage on at least one occasion during a visit to Mr. Epstein’s home in Palm Beach (although I cannot recall that Mr. Dershowitz received a massage on more than one occasion). I do not recall Mr. Dershowitz being massaged by anyone who I thought was less than 18 years old. I have no reason to doubt Mr. Dershowitz’s statement that this massage was done by a woman named Olga who was in her forties. In fact, I do remember a masseuse named Olga that 3 GM_01199

_ TC Case 18-2868, Document 278, 08/09/2019 2628230, Pages31 of 648 Case 1:15-cv-07433-RWS Document 435-3 Filed 09/15/16 Page 5 of 6 lived in Palm Beach, though I do not know her last name. As I have said, I never saw Mr. Dershowitz around young girls. I have also explained that there were masseuses, both male and female, that were in their mid-forties. 14, [never saw Mr. Dershowitz do anything improper or be present while anyone else was being improper. 15. Before asking me about Jeffrey Epstein speaking to celebrities at the house, the attorney for “Jane Doe 102” asked me about Jean Luc Brunel, Mark Epstein, Daniel Estes, Matt Groening, and Leslie Wexner. I then listed Senator Mitchell, Prince Andrew, Princess Sarah Ferguson, Miss Yugoslavia, Miss Germany, Alan Dershowitz, Princess Diana’s secretary with her children, Mr. Trump, Mr. Robert Kennedy, Jr., Frederik Fekkai, and a couple Noble prize winners as celebrities that I had seen while working for Mr. Epstein. I also mentioned a reunion of Nobel prize winners that was held at the house, and that I met President Clinton at Mr. Epstein’s plane the last month that I was working for Mr. Epstein. C. Summary of My Interaction with Virginia Roberts 16. The first time I saw Virginia Roberts was at Mar-a-Lago where I believed she worked in the spa. I only recall seeing Virginia Roberts come to Mr. Epstein’s house during the last year that I worked for Mr. Epstein. During this time, I believe she visited Mr. Epstein’s home in Palm Beach two or three times a week. 17, I never saw any photographs of Virginia Roberts in Mr. Epstein’s house. I was shown a photo of Virginia Roberts during my deposition, and I recognized the woman in the photo as Virginia Roberts. 18. As I stated in my deposition, I am not sure whether Virginia Roberts came to the house when Prince Andrew was there. GM_01200

Case 18-2868, Document 278, 08/09/2019, 2628230, Page532 of 648 Case 1:15-cv-07433-RWS Document 435-3 Filed 09/15/16 Page 6 of 6 19. I was never asked by any attorneys if Virginia Roberts came to the house when Mr. Dershowitz was there. If I had been asked, I would have answered that I never saw Virginia Roberts at the house when Mr. Dershowitz was there. 20. The following statement made by Virginia Roberts’s attorneys and their own attorney in a filing on December 4, 2015 is not accurate and is a misrepresentation of what I said in my deposition: “Alessi was able to identify a photograph of Ms. Giuffre as someone who was at the mansion as the same time as Dershowitz.” 21. As far as I can recall, since I gave my deposition in 2009, I have never been asked by Brad Edwards or Paul Cassell about my knowledge regarding Virginia Roberts or Alan Dershowitz or about my 2009 deposition testimony. I understand that I am swearing or affirming under oath to the truthfulness of the claims made in this affidavit and that the punishment for knowingly making a false statement includes fines and/or imprisonment. Dated: January 13, 2016 STATE OF F021 04 COUNTY OF fPgup, OE Att Sworn to or affirmed and signed before me on A /te YVAN 13° 2 Os apne oll Rico, vd be providef Ass ol riven 's l'tCeunst. Ess / TARY PUBLIC or DEPUTY CLERK d A C4 Print, type, or stamp commissioned name of notary or clerk.] GM _ 01201

Case 18-2868, Document 278, 08/09/2019, 2628230, Page533 of 648 EKAHIBIT i

© co Co ~ oO) O1 — Go NO — ND Ad ND PR HBO YPO - = F&F FF FF F- = Oh hd S—dmm O1 & Go NO — © CO Co ~~] © O1 & Go NO —_ Case 18-2868, Document 278, 08/09/2019, 2628230, Page534 of 648 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, -VS- CONFIDENTIAL ALAN M. DERSHOWITZ, Defendant. VIDEOTAPED DEPOSITION OF VIRGINIA ROBERTS GIUFFRE Saturday, January 16, 2016 9:07 a.m. - 2:48 p.m. 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, Florida 33301 Reported By: Deborah A. Harris, Court Reporter Notary Public, State of Florida Phone - 305.651.0706 Job No. J0Q277789 CONFIDENTIAL GIUFFRE005093 CONFIDENTIAL

© co Co | oO) O1 a Go NO — ND RAO NO. RD RO — = = = = ee elle lf & Oo NO = © co CO ~“ ©) oO f Go NO — NO O1 Case 18-2868, Document 278, 08/09/2019, 2628230, Page535 of 648 APPEARANCES: On behalf of the Plaintiffs: Jack Scarola, Esquire SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 (561) 686-6300 On behalf of the Deponent: Sigrid McCawley, Esquire BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, Florida 33301 (954) 356-0011 On behalf of the Defendant: Mary Borja, Esquire WILEY REIN, LLP 1776 K Street NW Washington, DC 20006 (202) 719-7000 On behalf of the Defendant: Richard Simpson, Esquire WILEY REIN, LLP 1776 K Street NW Washington, DC 20006 (202) 719-7000 On behalf of the Defendant: Thomas E. Scott, Esquire COLE, SCOTT & KISSANE, P.A. 9150 South Dadeland Boulevard, 14th Floor Miami, Florida 33156 (305) 350-5300 On behalf of the Defendant: Kenneth A. Sweder, Esquire SWEDER & ROSS, LLP 131 Oliver Street. Boston, Massachusetts 02110 (617) 646-4466 CONFIDENTIAL GIUFFRE005094 CONFIDENTIAL

© co Co | Oo) O1 a Go NO — ND KAD ND RO NO YHOO - = F&F FF FF F- == hh S—d6U Sd O1 & Go NO — © CO CO ™] © O1 & Go NO —_ Case 18-2868, Document 278, 08/09/2019, 2628230, Page536 of 648 ALSO PRESENT Edward J. Pozzuoli, Special Master Robert Pacheco, Videographer Ryan Kick, Videographer Bradley J. Edwards Paul G. Cassell Alan M. Dershowitz Brittany N. Henderson, Esq. Meridith Schultz, Esquire I NDE X WITNESS DIRECT CROSS REDIRECT Virginia Roberts Giuffre By Ms. Borja 9 By Mr. Scarola 201 By Ms. Borja 204 EXHIBITS DEFENDANT VR EXHIBITS - Notice. - Disclosure list. - Order. - E-mail. Photo (Confidential ) - Article. - Daily Mail. - Daily Mail. - Declaration. FBI doc. OONO OR ON — i —s © 1 RECROSS FOR ID 6 26 99 92 100 124 155 168 170 187 REPORTER'S NOTE: Exhibit 5 marked confidential, sealed, and retained by the Special Master. CONFIDENTIAL GIUFFRE005095 CONFIDENTIAL

© co Co | Oo) O1 a Go NO — ND KAD ND RO NK HO =| = F- FF FF = =-r—hdU Srs—d6dUwEZ—hmU O1 & Go NO — © CO CO ~~] © O1 & Go NO —_ Case 18-2868, Document 278, 08/09/2019, 2628230, Page537 of 648 10 MR. SCAROLA: It is a minor discrepancy, but I think you read it as when she was a minor and it's while she was a minor. BY MS. BORJA: Q. While she was a minor. Do you see where I'm reading starting in the third line? A. Yes. Q. Is that allegation true? Ps Yes. Q. If you go to page 6 of the document, do you see the paragraph that's starts, Epstein also trafficked? A. Yes. Q. Is says Epstein also trafficked Jane Doe #3 for sexual purposes to many other powerful men including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known prime minister and other world leaders. Do you see that? A. Yes. Q. Is that allegation true? A. Yes. Q. The reference there to foreign presidents, do you see that? A. Yes. Q. You were sexually trafficked to foreign presidents? CONFIDENTIAL GIUFFRE005102 CONFIDENTIAL

a ND Ad ND RO RK HO =| = F- F&F FF = => hd S—d6UES—dmm O1 & Go NO — © CO CO ~~] © O1 & Go NO —_ © CO CO ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page538 of 648 11 A. No. Q. So that's not true, you were not sexually trafficked to foreign presidents? A. I don't know what foreign president you're talking about. Q. Have you ever been sexually trafficked to any foreign president? MS. MCCAWLEY: I'm going to allow you to ask that question, but with respect to specific identification of an individual we're not going to do that. At this point she has. MS. BORJA: Counsel, your objection has been made. No speaking objections, please. Let's move on. MS. MCCAWLEY: I can make my record, and my record is she's not going to be speaking with respect to individuals’ names that are named in generalities in this document. SPECIAL MASTER: Objection overruled. You can answer. A. I understand well-known prime ministers and other world leaders; as far as foreign presidents, I'm not too sure, I don't know. Q. Have you ever met any foreign presidents? A. Foreign presidents as in overseas? CONFIDENTIAL GIUFFRE005103 CONFIDENTIAL

a ND KRd ND RO NK HO - = FF FF FF = =-s—hdU S—dDUDUwZ—h O1 & Go NO — © CO CO ~~] © O1 a aS Go NO —_ © CO CO ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page539 of 648 12 Q. Sure, okay, overseas. A. No. Q. Have you ever met any foreign presidents from countries not overseas such as Canada or Mexico? A. No. Q. So you were not sexually trafficked to any foreign presidents; is that correct? A. As far as I know right now, yes. Q. It's correct that you were not sexually trafficked to them, right? A. You've asked me this three times and I'm telling you. Q. Okay. A well-known prime minister. Were you sexually trafficked to a well-known prime minister? A. Yes. Q. Who was that? MS. MCCAWLEY: I'm going to object to this line of questioning. This has to do with safety concerns for her. MS. BORJA: Counsel, this is under seal. You can answer. MS. MCCAWLEY: No, she's not going to answer. SPECIAL MASTER: Hang on one second. MS. MCCAWLEY: Let me make my objection. CONFIDENTIAL GIUFFRE005104 CONFIDENTIAL

a ND Ad ND RO RK HO =| = F- F&F FF = => hd S—d6UES—dmm O1 & Go NO — © CO CO ~~] © O1 & Go NO —_ © CO CO ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page540 of 648 15 SPECIAL MASTER: Okay. I can't twist her arm and force her so we'll deal with it. BY MS. BORJA: Q. Okay. Other world leaders, what other world leaders were you sexually trafficked to? MS. MCCAWLEY: We have the same objection. SPECIAL MASTER: And I would have the same ruling based upon the arguments. MS. MCCAWLEY: Let me just make my record. To the extent that there's a name of an individual that you can reveal that you do not feel would harm your physical safety, you're welcome to reveal them. Anybody else, you don't have to reveal at this time and we'll take that to Judge Lynch. A. Okay. Prince Andrew for one. Q. Other than Prince Andrew? A. There 1s another individual that I honestly do not know his name. Q. What country is he from? A. I'm not too sure, he spoke in a foreign -he did speak foreign tongue, he spoke English as well, but I'm not too sure where he was from. Q. How do you know he is world leader? A. I was introduced to him as a prince. CONFIDENTIAL GIUFFRE005107 CONFIDENTIAL

a > = —Go NO — © CO Co ~~ ©) on - Go NO mh, BS 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page541 of 648 Q. A. when I was with him. A. Q. trafficked to A. Q. A. Q. A. 16 Okay. Did he have security with him? I'm sure he did somewhere around, but not Did you see security? No. Did you -- where were you when you met him? On this occasion the South of France. Are there witnesses to you being sexually this prince? Yes. Name them. Jeffrey Epstein, Ghislaine Maxwell. Anyone else? There was a whole bunch of people in the room so of course. Q A Q. A Q A. their names. Q. A. Was this an orgy? No. Who else was in the room? I can't name them all, there was a lot. Name as many as you can name? I don't Know their names. I can't name They were present during sexual activity? They were present before the sexual activity and then I went to have sexual activity with him CONFIDENTIAL GIUFFRE005108 CONFIDENTIAL

a ND Rd ND RO RS HO =| = = F&F FF FF = hd S—d6UwES—dmS O1 & Go NO — © CO CO ~~] © O1 a aS Go NO —_ © CO CO ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page542 of 648 17 alone. Q. So he's the only witness to your sexual activity, the prince? A. On the instruction of Epstein and Ghislaine, yes. Q. Where in the South of France were you? A. I don't know. Q. Were you on a boat, were you in a house? A. We were at a like a cabana, not cabana, like a resort, but it was a big party. Q. Who was throwing the party? A. I don't Know. I was just brought there. Q. You also refer to powerful business executives. What powerful business executives were you sexually trafficked to? MS. MCCAWLEY: Again, to the extent you can reveal somebody without a safety concern you're welcome to do that. SPECIAL MASTER: Well, again -MS. MCCAWLEY: Right. I understand. SPECIAL MASTER: Same objection, same ruling. A. George Mitchell. Q. When were you sexually trafficked to George Mitchell? CONFIDENTIAL GIUFFRE005109 CONFIDENTIAL

a ND KAD ND RO LK HO - = F- FF FF =- =r —hdU Sr—d6UwES—hmm O1 & Go NO — © CO CO ~~] © O1 & Go NO —_ © CO CO ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page543 of 648 64 Q. Do you have the originals? A. Again, between the FBI and giving them to my lawyers and Sharon Churcher, the circulation, I'm not too sure if I have the originals. I know I have copies. So I'm not too sure if they're the originals. Q. The booklet that you gave pages from to Ms. Churcher where is that booklet? A. Burned. Q. When did you burn it? A. In, I think it was 2013. Me and my husband had a bonfire. Q. What did you put in the bonfire? A. Any kind of memories that I had written down about all the stuff going on. Q. Had you written anything about Professor Dershowitz? A. He could have been there, yes. Q. And you burned that? A. I wanted to burn my memories. I wanted to get rid of it. It was very painful stuff. Q. Other than what you had written down did you burn anything else? I don't mean the wood, when you talk about burning your memories, what were you burning? A. I was burning 11ke memories, thoughts, dreams that I had, just everything that was kind of CONFIDENTIAL GIUFFRE005156 CONFIDENTIAL

— ND Rd ND RO NK HO =| = = FF FF =- =-—hdDO Sr—d6Uw—E—DdDdmUD O1 & Go NO — © CO CO ~~] © O1 & Go NO —_ © cO Co ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page544 of 648 65 affiliated with the abuse I endured, and there was a lot of it in there. My husband is pretty spiritual so he said the best thing to do would be burn them. Q. Is there anything you decided to keep and not burn? A. Just the photographs. Q. Anything else that you can think of? A. Photographs, that's it. Q. Approximately when in 2013 was this bonfire? A. I don't Know what month it was. Q. Did you do it outside? A. Yeah, it was outside. I wasn't going to do 1t in my living room. Q. Did it feel good to be close to the fire because it was cold out or was it a summertime bonfire? A. I believe I had just bought my house in Titusville, Florida. I bought my house in, I think, I either got it October or November of 2013. It would have been around probably November. Q. Why did you decide to keep the photos? A. They're evidence. Q. Do you have any photographs of yourselves with Professor Dershowitz? A. No. CONFIDENTIAL GIUFFRE005157 CONFIDENTIAL

a ND Ad ND RO RK HO =| = F- F&F FF = => hd S—d6UES—dmm O1 & Go NO — © CO CO ~~] © O1 & Go NO —_ © cO Co ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page545 of 648 85 Beach, I've seen him in New York. So I mean, if we're going to pin point how many times I've seen him or the next time I saw him after that I don't know. Q. Then tell me -- let's do it this way, what was the most recent time that you recall having sex with Professor Dershowitz? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. Pe The first time I recall having sex with Professor Dershowitz was in New York. Q. My question was, the most recent time now. What's the most current, most recent memory of having sex with Professor Dershowitz? MS. MCCAWLEY: Objection. Just so I'm clear, you're going backward? MS. BORJA: Correct. MS. MCCAWLEY: The last time. A. The last time that I remember having sex with him? Okay. I believe it was on an airplane. Q. Where were you going? A. On, I believe it was Massachusetts. I don't know. It's very hard for me to remember exactly where we were going, what were the circumstances. Q. So that's the time you testified about earlier? CONFIDENTIAL GIUFFRE005177 CONFIDENTIAL

— ND KRd ND RO NK HO =| = FF FF FF =- =>—hdU Srs—d6Uw—EJ—hmO O1 & Go NO — © CO CO ~~] © O1 & Go NO —_ © CO Co ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page546 of 648 110 age of 30? Q. That were providing massages to Jeffrey Epstein? A. Just the male that was teaching me on the USVI and Sheridan, but she was also involved in sexual acts. She wasn't over the age of -- she could have been around 30, but she would have been over 30. Q. Did you keep a list of the masseuses who came to Epstein's properties? A. No. Q Did some of them come only once? A. Uh-huh. Q Are there some that came when you weren't there? A. I wasn't there, how am I to Know. Q. You don't know if any came as a masseuse while you were not at Jeffrey Epstein's property? MS. MCCAWLEY: Objection, asked and answered. A. I wasn't there so I couldn't have. Q. What's the sixth incident that you say happened where you were sexually trafficked to Professor Dershowitz? A. We've talked about New York, we talked about Palm Beach, New Mexico, U.S. Virgin Islands, talked CONFIDENTIAL GIUFFRE005202 CONFIDENTIAL

— ND RO RO meme mek NO = © co Co ™~" oO O1 os Oo NO = © co Co ~" oO) O1 os Oo NO NO Oo 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page547 of 648 about we took the airplane? Q. Yes. A. There was an instance in a car, but it was more -- 1t wasn't intercourse, it was more -MS. MCCAWLEY: Use a term you're comfortable with. A. More oral is the good term to use, oral sex. Q. Where were you? Where was his car, what city, what state, what jurisdiction? Where were you? A. This was in Massachusetts. It was a black limousine. Q. Who else was in the car other than yourself and Professor Dershowitz? A. Jeffrey Epstein and another young girl. Q. How many people participated in the sexual activity in the car? A. Including myself? Q. Uh-huh. A. Four. Q. Where was everybody in the car? A. Sitting down. Q. Were people -- was this a town car, was this a limousine? A. Like a long limousine. CONFIDENTIAL GIUFFRE005203 CONFIDENTIAL

a ND Rd ND RO RK HO =| = = F&F FF = =-s—hdU Srs—dDUrwJ) = O1 & Go NO — © CO CO ~~] © O1 & Go NO —_ © CO Co ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page548 of 648 112 Q. Where was the car going? A. To Mr. Dershowitz’ house. Q. Where was it coming from? A. An airport. Q. When was this? A. I don't Know. Q. What's your best recollection? A. It wasn't snowing. It wasn't hot. So I would like to say -- I'm trying to think of the trees around, but I don't Know, maybe spring. Q. Why were you going to Professor Dershowitz' house? A. Jeffrey and him were doing some business. They were doing something at his house. Nothing sexual happened at his house. Did you go in Professor Dershowitz’ house? Yes, I did. How long were you there? Not even twenty minutes, half an hour. Oo >» OD YF DN What did you do while you were in the house? A. I sat in, I don't know, a foyer with another girl and Jeffrey and Dershowitz went to a different part of the house. There was a desk there and we just sat, not sat, stood in the foyer. CONFIDENTIAL GIUFFRE005204 CONFIDENTIAL

a ND KRd ND RO NK HO =| = FF FF FF =- =>—hdU Srs—d6Uw—EJ—hmO O1 & Go NO — © CO CO ~~] © O1 & Go NO —_ © CO Co ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page549 of 648 113 Q Who was this other girl? A. I don't know who she is. Q. Had you ever met her before? A No. Q. When you were coming from the airport had you flown in? A. Yes, me and Jeffrey and the girl had flown in, Dershowitz had not. Q. How did he get into the limousine? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. BY MS. BORJA: Q. Where did he get into the limousine? A At the airport. Q. He was not on a flight with Mr. Epstein? A. Not on this occasion. Q Did you tell anybody about this incident in the car? A. Like anybody that I know personally? Q. Anybody in the world? MS. MCCAWLEY: Objection to the extent you relayed something to your lawyer. You can say that you told your lawyers but you can't discuss what you said. SPECIAL MASTER: Other than -CONFIDENTIAL GIUFFRE005205 CONFIDENTIAL

a ND KRd ND RO NK HO =| = FF FF FF =- =>—hdU Srs—d6Uw—EJ—hmO O1 & Go NO — © CO CO ~~] © O1 & Go NO —_ © CO CO ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page550 of 648 A Q. 114 No, I told my lawyers. Did you tell anybody about it closer in time to the event? A. no. Q. where did you A. Q A. Q you go? A. Like my boyfriend or something like that, After you left Professor Dershowitz's house go? Back to the airport. Where did you fly in from? I believe it was New York. When you went back to the airport where did I believe, see, that's the hard thing. I want to say either New York or Palm Beach. I'm no 100 percent sure. Q. So I understand the time frame, did you fly in on a private jet or commercial? A. Q. A. Q. Private. You flew out again on private? Yes. So the time frame is that you and Jeffrey were on the plane? MS. MCCAWLEY: Objection. Yes. MS. MCCAWLEY: Objection, mischaracterizes CONFIDENTIAL GIUFFRE005206 CONFIDENTIAL

a ND Rd ND RO KS HO =| = F- FF FF =- =-—hdU Sr—d6UwE—hmm O1 & Go NO — © CO CO ~~] © O1 & Go NO —_ © CO Co ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page551 of 648 115 the testimony. Go ahead. A. Yes, me and Jeffrey were on the plane together. Q. And the girl was on the plane? Ps Yes. Q. Anybody else? A. The pilots. Q. So the three of you took the flight, correct? A. Yes. Q. And you flew into an airport in Massachusetts? A Yes. Q. Then you took a limousine to the Professor's house and you were there for about ten minutes, is that right? MS. MCCAWLEY: Objection. Go ahead. A. About 20, 25 minutes. I didn't look at my watch. Q. A very brief period of time? A. Very brief. Q. And then you went back to the airport and you flew out? A. Yes. Q. And you flew back either to New York or to CONFIDENTIAL GIUFFRE005207 CONFIDENTIAL

a ND KAD ND RO KS HO | = F&F FF FF = = —hdO Sr—d6UwES—dmUM O1 & Go NO — © CO CO ~~] oO O1 & Go NO —_ © cO Co ~~] © O1 & Go NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page552 of 648 194 A Besides what's in these? Q. Did you ever look to see if you had any personal notes in your writing that pertain to Professor Dershowitz? A. Like from my old journal, the one that I burned? Q. From anywhere. Did you ever make an effort to look? A. Dershowitz could have been in my journal, he could have been. We're talking about an 85 page, if not more, you Know, things that I had written to get my story out of my head and into pages; and yes, Dershowitz could have been in there, but that's up in the clouds now, bonfire. Q. That's what you call your journals, what you burned, right? A. Yes. Q. And you wrote that journal in order to collect your thoughts? A. To get everything out of here and on to paper. Q. Have you made any other notes, though, since then to help you when you think of things? A. Yes, sometimes like I said, sometimes when I read my affidavits and stuff like that, you know, and I CONFIDENTIAL GIUFFRE005286 CONFIDENTIAL

a ND KRd ND RO NK HO =| = FF FF FF =- =>—hdU Srs—d6Uw—EJ—hmO O1 & Go NO — © CO CO ~~] © O1 & Go NO —_ © CO Co ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page553 of 648 195 think of something else like a description of something that I forget about, you know what I mean, then yeah, I'll go back and I'11 write it in the journal, you know, for instance, you know, what another girl would have looked like. Even though I can't identify her name or her age or anything like that, but I do remember 1ike flashes of blonde, little things like that, but nothing -- I don't have any more journals. Q. But those notes, they help your memory? A. Sometimes. I'm avery visual person. Q. And they help you with your affidavits? A. No, they don't help me with my affidavits, my affidavits are already done, I just go back and it helps my memory. It helps me bring stuff out. Q. What do you do with those notes? A. Nothing, literally nothing. They're in a notebook that if I need to write it down. I have a dream notebook as well where I'll just write down my dreams and stuff. I do nothing, no one is seeing it. Q. You read it? You keep it? A. Yeah, I Keep it. Q. Okay. Have you gone back and read that recently? A. No. Q. Okay. You continue to make entries into CONFIDENTIAL GIUFFRE005287 CONFIDENTIAL

— ND KAD ND RO NK HPO =| = FF FF FF = = hd S—d6dUES—dmM O1 & Go NO — © CO CO ~~] © O1 & Go NO —_ © CO CO ™] © O1 & Oo NO Case 18-2868, Document 278, 08/09/2019, 2628230, Page554 of 648 196 it? A. Not so much about Dershowitz. It's mostly like feelings, dreams, you know, past things that I've gone through. Like I said, not so much pertaining to Dershowitz himself. Q. And that's separate from your dream book? A. No, it's all in one. Q. Is it a spiral bound notebook? A. Yes, it's just a cheap, like, actually it's in my kid's closet. Q. At this point in time are you angry with Mr. Epstein? Ps Furious. Q. Are you angry with Professor Dershowitz? A. Absolutely. Q. Are you angry with famous politicians? Pe I'm angry with anybody who has it in their mind that they can hurt and abuse a minor child and continue to lie about getting away with it and that what they've done is okay and they can continue to harass victims, yes, I'm furious. Q. Are you angry with Professor Dershowitz for his role in representing Jeffrey Epstein in the criminal action? A. Do I think he played a big part getting him CONFIDENTIAL GIUFFRE005288 CONFIDENTIAL

oO Oo© oO N OO Oo FP OO DO — ND Rd ND ARO RK HO =| - - F F2 FSF = = hd hme non Ft Ww NON -|- FO OO Oo NN FDO OH FP | NO — Case 18-2868, Document 278, 08/09/2019, 2628230, Page555 of 648 213 CERTIFICATE O F OATH STATE OF FLORIDA, COUNTY OF DADE, I, Deborah A. Harris, the undersigned authority and Notary Public certify that VIRGINIA ROBERTS GIUFFRE personally appeared before me and was duly sworn on the 16th day of January, 2016. Sworn to before me this 20th day of January, 2016. Deborah A. Harris, Court Reporter Notary Public - State of Florida My Commission No. FF 246867 My Commission Expires: October 31, 2019 Job No. J0277789 GIUFFRE005305 CONFIDENTIAL

oO Oo FO N OO Oo FPF OO} DO — ND Ad ND RO RK HO =| = = FF FF F- = hd S—d6U—S—dmU non Rt Ww NON -|- FCO OO WO NN CFO Oo Fe | NO — Case 18-2868, Document 278, 08/09/2019, 2628230, Page556 of 648 214 REPORTER'S CERTIFICATE I, Deborah A. Harris, Florida Professional Court Reporter and Notary Public in and for the State of Florida at Large, do hereby certify that I was authorized to and did report said deposition in stenotype; and that the foregoing pages 1 through 216 are a true and correct transcription of my shorthand notes of said deposition. I further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out. I further certify that I am not an attorney or counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party connected with the action, nor am I financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter. DATED this 20th day of January, 2016. Deborah A. Harris, Court Reporter Job No. J0277789 GIUFFRE005306 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page557 of 648 EKAHIBIT JJ

Case 18-2868, Document 278, 08/09/2019, 2628230, Page558 of 648 BS Oh ze s7 = CoML Be RY -&. (Fu Ee NVE sk TOR) a oe 401 EAST LAS OLAS BOULEVARD * SUITE |1200* FORT LAUDERDALE. FL 3330/-22!|* PH 954 356.001! * FAX 954 356.0022 CONFIDENTIAL/SEALED DEPOSITION SPECIAL TREATMENT REQUIRED Sigrid S. McCawley, Esq. E-mail: smecawley@bsfllp.com February 10, 2016 VIA E-MAIL & FEDERAL EXPRESS Esquire Solutions PRODUCTION DEPARTMENT 101 Marietta Street Atlanta, Georgia 30303 errata(@esquiresolutions.com Re: Confidential/Sealed Deposition Transcript, Job No. J02777789 (Errata changes to be treated in same manner). To Whom It May Concern: Attached please find the errata changes for the Videotaped Deposition of Virginia Roberts Giuffre taken January 16, 2016. This transcript has been designated as Confidential and has been sealed by the Court. Please ensure that all materials including transcript, errata changes and video tape are treated accordingly. If you have any questions regarding the errata changes or treatment of confidential/sealed materials, please do not hesitate to contact me at (954) 356-0011. Sincerely, Sigrid S. M¢Cawley SSM:sp Enclosures WWW.BSFLLP.COM GIUFFRE005310 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page559 of 648 ) 4 3 Confidential/Sealed Transcript Pursuant to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Job No. J0277789 y 16 DEPOSITION ERRATA SHEET Assignment no: 30277789 4 Bradley J. Edwards and Paul G&G. Cassel) 5 6 ™“4 10 1] 1? VS. Sian M,. PpershowitzZ DECCARATTON UNDER PENALTY OF PERIURY t declare under penaity of perjury that I have read the eatire transeript of my videotaped deposition taken in the captioned matter or the same has been read to me, and the same 18 true and accurate, save and except for changes and/or corrections, if any. as indicated by me on the DFPOSITION ERRATA SHEET hereof, with the understanding that IL offer these changes as if still under oath. \ { " ANS oer Signed on the 1. o- - day of CELE E Se > \ J 20 {ho . ' / f | \ “ | | ” * es Ba A oT ee ase weapves ; | VIRGINIA ROGERTS GIUPFRE GIUFFRE005311 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page560 of 648 Confidential/Sealed Transcript Pursuant to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Job No. J0277789 DEPOSITION ERRATA SHEET Page No. 6 Line No, 17 Change to: “Yes, I signed the subpoena duces tecum.” Reason for change: Did not initially recognize the document Page No, 6 Line No, 20 Change to: “No. My lawyers worked with me to collect documents and my understanding is that we turned those documents over to Dershowitz’s counsel prior to the deposition.” Reason for change: Clarification of answer Page No. 9 Line No. 9 Chanve to: “Yes,” : Did not iniually recognize the document GO Reason for chang ———— eee ew ee ee Se ee ee ee eee ee ee ee KE eee Ke Ee EE ee ee eee ee Ee ee ee ee ee ee ee ee eS ee eS ee ee Se ee ee ee ee Page No. 1] Line No. | Chanve to: “Yes.” Reason for change: Misunderstood the question Page | | Line Nos. 4-5 Change to: “I’m confused. I don’t know what foreign president you're talking about.” Reason for change: Misunderstood the question a et tt eel Page No, 1] Line No. 23 Change to: “IT understand well-known prime ministers and other world leaders; as far as foreign presidents, I believe so.” Reason for change: Misunderstood the quesuion PageNo.120 ses =i Change to: “Yes, assuming South Ameriea is considered overseas.” Reason for change: Misunderstood the question Page No. 12 Line No, 8 Change to: “As far as I know right now, ves, | was.” GIUFFRE005312 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page561 of 648 Confidential/Sealed Transcript Pursuant to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Job No. J0277789 Reason for change: Misunderstood the question Ce ee oe OS DOS RAED RB i Sp ER ee RRSP IE ieee RA pata i i Miied ite ign woo mn~s ape le eealnosennackan Page No. 38 Line No. 1] Change to: “IH continue with the list here. Nadia Mareinkova I was not sent to her, but she was part of it with Jeff Epstein. Others on the list include Marvin Minsky and Tom Pritzker,” Reason for change: Clarification of answer ee ee ee me me ee ae ee ee ee ee OS Ee EO 8S OOS OO 8 SOS SESS SSS Se © 8 OSES O66 SSE SOO SE BESS OOO Hae Sea hen owbehasedneaeou Change to: “Off the top of my head, once, but i¢ could have been more.” Reason for change: Clarification of answer Page No. 38 Line No. 2] Change to: “I believe Tom was at Mexico. I may have also been with him in other places,” Reason for change: Clarification of answer SS SSS SS SSS SS SS © ee Oe eS OS Se 6 OS Oe Ce STE 8S SO EO OO 8 OOO See ee ee Se eS = oe ee Se Se SS ew ee be oweese eae oecmaeeeea= Page No. 4] Line No. 8 Change to; “Onan airplane and in a limo.” Reason for change: Clarification of answer Tee Oe SSS SSE SS SS SS FSS SE SS SSS SS SS SS SS Eee REO Oe SE eee Oe ee ee Se HS SE SOE EOE OO OEE SEE OO ME ewww wee woe ee ew ere eee aoeeee os Page No, 4] Line No. 10 Chanpe to: “One, each time.” Reason for change: Clarification of answer DODD DBS SS SO OS OS OS Se OS SSS SS 6 OO HO OSES SS SOE OE OO Se ew ewe e SS Ew SO See eS Sees eeg owe ewer sewers eeseéean Page No. 41 Line No. 12 Change to: “On airplane, blond, young.” Reason for change: Clarification of answer 2 NE OOS PLS SS ED OP APD UO Ce Oe SO OP ee a Oe Oe Ar te et 1 Oe PO OS es ee SS rw ee SS 2 SS COS SSS SSS DOS © EEE SSE ESOS MERAD Oe Owowsswaoesbowe Page No. 98 Line No. 16 Change to: “Ag sine ¢an see in that answer I’m not even sure. [t wasn’t six months, but between six months and a year which is why 'm saying nine months. [t was an assumption. tcouldshave been six weeks.” Reason for change: Clarification of answer ee ee Se 8 8 OOS 0 8 BSS OSE BOE SBS SS SS BOSS 6 SSS OS SSNS OESE4.55544S SEH 0S SON eS BECO ee ee eee ee ee ew ee GIUFFRE005313 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page562 of 648 Confidential/Sealed Transcript Pursuant to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Job No. J0277789 Page Noa, 190 Line No. 22 Change to: “No, other than maybe you showing it to me today. It's in my pile, It’s notin my pile, is it? [don’t know. I haven't seen it. I was served with the subpoena, and I signed for it, and I reviewed it at that time.” Reason for change: Clarification of answer — PLES SS OS SOO OS 8 OC PES SS OOS 6 SOO BO HK SS OS OS SSS © 6 USS S SEES DS Ome ee BeBe ee eee woeeoeweewesce -_——— ee eee eee ee ee eee eee Change to: “Why would I do—no. I did collect documents and gave them to my lawyers in response to this subpoena. And my understanding is those documents were produced.” Reason for change: Misunderstood the question OS SS 8 SS OS 0 SS SO 8 SE SSS ST SSS SSS ESO SSS SOSH We we SO eee Bee Ss SS SS SS Be 6 Oe ES OS OSES Ss TS SOS SSSSSESeSO ec eesseeeoueasenecsetossaos= Page 191 Line 20 Change to: “Yes, but I did not have any pictures of myself with Professor Dershowitz.” Reason for change: Misunderstood the question GIUFFRE005314 CONFIDENTIAL

Case 18-2868, Document 278, 08/09/2019, 2628230, Page563 of 648 EKAHIBIT KK

The text on this page is estimated to be only 39.97% accurate

wl =21(z(S ONILHOdSH OGNV 1d NSYOV oO ; cel PooRLTIALD ~ DOYS YIM poyowal [ “UW I3A0 U9}}08 JOAoU Sey oq] puke paf]P{ s1oM Suse} JayyO INOS YOIYM Ul JUSpI9IB IBD dILUOY B WOT OBR SIBOA UDADS ABME possed pey Ja1ysnep sty Moy Jo AlO}s B OTH ]fa} UO} OF dn yoeq MOpUIM O|PPMU ST} PayjOr pue VOTJeUTJsap INO JO UOLBOO] 94} JOANP ot} JARS Off LUI Stu ayey“URaTU BY pip YM JjasAw 0} posopuod | Aeme 1YySTY UT NOA O¥R) [IM | UTese OU O} OT] JoAOT NOA se BUO] SY ,, 9UO} SNOTIOS AIOA B UI padamsue pure pesned usy) poyyonyo oy pue YIM oy} WHY Plo} | ‘young Aue yt Auap 1, Uppnos pue Mo WYsNed Us0q PRY MOUY | “Tel] {QI} v JulI9g peu oq JUOM | {AT[BaI ““NOA oIe PJO MOH CQy eB ow BUT{[O} 9q plnos nod Yury} | ZaMs Nod ay, ‘parjdar AJAOS O}{ “SIL 1B USO}XIS SEM J (UY P]O} { puke ade AU poyse oH “Ul AIS 0} PosTjod | ‘JOSRUdd} BUOISPRdY 8 Yons Sulaq Inq ‘a7eIS o[qQLLI9} B UT SVM | WUUpe MOU Ue | OFT] UI 19yv] YOR BuLyoo’] “s10UTAue IU J}Je YOO] O} guoXue Jo Ayituey AU poou }, UPIP puke J[ISALU JO 91B9 94R) PjNoo | Wey} Suturejdxo sjoors oy Uo dn papud j MOY jNoge op}I1j @ pue oweU AUT WHEY BULA “Opisqins sy} UO SW jnoge NO punoy pey oy JY Saptsaq “jesAur 9oNPO.HUT O} paposoodd | ‘JUDLIDAB]SUS siy Aq paddesy soypng atom Ady) syueISTUIUL jesaryt fe ayom Ao) dulaq pure spiemad yeioueuly ayy fo Ayoleut oy) Ul Buideai UOY “SdATOSUUIDY} OJ SSUILULS JIDY] JO UOTOBAY B JLaUdq A[UO PjNOM soTNeeq OIBUISTIVYS JOYO AUB pure BURA SB YoNS ‘d[9}USI{D YOU Jadns s UOY JO} “SHOOSE pred ysry ay 9q 1YStt sisanbor sq} a1eZIq MOY JoWeU! OU “WAY} JO POYSe o1ISOP [eNXdS AIDAD [[LJ[NY O} POUT] 9IIM S]ITG OU} “JUSUUTRLO}US OT}OJO FO INOY Jad IdA0 pure QO'OOOLS WOY SoyMAUR Lay} BUTISOS 9]9}UAT[9 SATJOO[ES B O} B[QUIWAR A[UQ “YOU Joqn UllY SyYBW O} S}109S9 SB BUISN SEA OY je} [Ard aBesapun Jo BuNsisuod A]JSOU USLUOM BunoA JO BULI BUIYTeN JUBIBILULUL JeBaT]I UB A]Feod SBM SSoUISNq SIH “UNI 0} 9]2] 00} SEM 1t |YFNoy} | NO punog | tury ayy Ag “9pe.y JOAOSIOpUN UL 1OJ surisod AU sem AoudSe Surapout sty Jey] SEM YIM ULSOq 0} SUL []9} 1, UPIP OY RUA “BUOIM DOW 9G 1,UP]NOS | {IYSI ‘Vd 9] Ul [AIS JOYyJOUL SEM aJay} Pq LY} 9q } UP]NOD HI PADUTAUOD “aSvA JL LOU OHI] B [Boj OW BUIYRUE “JUSIOB YOOZ2) YOY) B UL ,O]]9H,, ples Ayatyod puv syxsoy9 Ti0q UO SW PEsshy SYS “SUS} 918] Jay Ul AJUO SEM AT[eOA JQ “BulVaM SBM Ys dnoyew jo peo; Aavoy dU) YIM SatjuaMy ApIvs JOY Ul oq pjnosd ays axT] payxoo, oy oyqndoay YooZ7) dy) WoL ;opow pasoddns v “vuR A SBA WIT] O} JXoU Ayneaq ou) ‘spuaraypi1s Auvui sty jo ouo suronponut Aq yyeam Sulzoo sry Suyuneyy “OL }09f19d,, popped ‘Aouase Suljapow jNyssaoons B JO JOUMO PUL uewssouisng e ‘asuiddy uoy se AjayeIpotuU JJAStUTY PEONPOAWUT off ‘QUOD 0} SIBdA AULT JOJ OW dEUS PINOM JY] POM v OJUL SOULIJUD ISILY ALU SPW | OUT] IVY] OFUT JOOJ Buag 193 plnoo 1 9s1OM YON MOY OZ1VO1 1 UPI | SALeU OS PU ‘OS 0} dIOYM OU YUM ING Yonb a19y] JO NO 433 0} ononb ysaiy Atu usaq 9A, pynoys TVIINACIINOD - jeuseyy poydo10a 1y8sAdoD F eet : rel roomdlanlo JE], “SOU STUOS [VI P[NOD 9M OS JED SIY OUT SUOD OF SLU Poles JO pue wuowoyioxs Surryo eB pacejdsip Ajjueysur aH “UY Wl; POOJ 10} AQUOW SUIOS 493 PNM | soul je Suidoy “Arsuny Ajjeod pue soy punole wo jou ‘ARMeLUNI & SEM | JEU) UY [[9} 07 Poplosp J Apurponoy “yyy 34) WHY FUL][9} Ul JUR}ISAg SBA | UIBDUOD SIOBUBIIS SIU} WO poxooys ,.cjesdn OS ZULZOO] 120.98 By} UO DUO]e BUIyIS SUIOP NOA dyI] [As 9H] JoOMS B YONS SI EY AA,, ‘poyse Ajpury oy pue ApuueMm atu po}eo13 SOpIWUS IBY |, “ABMUNA B Jo Zurddajs ysnf Jopoul v oy1] PSxOO] SYS SSarp YUIU pod AXO} B® Ul possalp pue [nyyneaq peop doip “Is spuoyq ‘Bunod BULLS BO} }XOU BUYS SEM oY “LIYs pore]joo B puk Slasnoy yde{q Ul pessolp ATBON “ajsuss Assays 31q B UJIM URW plo “SuIPjeq puke YdIOM AAvaY B [OADI O} pousdo Joop yorq dU], }SO] Ajssopadoy usaq pey j SOgM Gund ot} JO JUOAY Ut poddojs pure JOWIO 94} POWIN) OUISHOUT] YOISI]S YOR]|q v “PoUlsas II “aJaYMOU JO ING “qos 0} ueSaq pur saauy Aw ojur peay Au ynd | ‘ayeys JUSTO Aut JO JOUs Ul pajuroddesip qino Aqieou B UO UMOP BUTTS “stu djay pynod yey) WoYM Jo ouoU ‘asueyo queds Aue 10} a[doad Jo [nypury e payse pure dos snq jsorvou ay} 0} pox[eA j 14Btu oy} Jog ASuNY duos pey | OWI} ISIYY dy} UOSq OARY },UP[NOM J ‘ou J] ‘Woy AOUOW JOUUTp JOS 0} OGeULTT P{Nod ] Jet} uosied onoujeduia ue pULf 0} JNO Jos puL soho AL WO S1Bd] OY} podim ] ‘ajseM 0} SUIT) Ajuo pue 03 0} aJ0yMoU YIM “juIOd STy) 1 “Ayjoq Aut Burured sea yeu) Joduny oy} JOJ pue ‘mou sem ATeal | QUOTE MOY BUIZIRO] MOU papef Woy) Jo ]]@ Suideosa yo yuoua}19x9 oy] pue dn ydoio svoj AJ “JUSWTTOpURQe Ul SU UO SYOeQ JOY} PUN) MOU PRY ST 1OJ S194} 9q O} pasoddns sem OUM pl] AUL UL QUOKIDAS MOY PUP [IIS Sunod & se poiojunoous ] dSNge dy} UO SuNdsayjos WOIY INQ “9Z9O1q kas ysnoi ay} Aq poddiym-puim JUIOG WOIJ JOU ‘SIVd] JIM 19AO pazeys oIOM soXa AU “WOZUOY SY} O}UI jadsop [vj JsuNS oy) SUTYOIVM sINOY JOF aUTJaIOYS oY} UO BUNS “Ny JO [[NJ POM vB Woy Sulply pue pjo SIVOA UDOT] SPM | L6G] JO JoutUNS dU} UL YoRog JWI Je No SuIdwueVs jYsiU pry Aw 0} dn Sulluos sem jy] “QUILO SI QUO SIG} ‘]]9} 0} UMO Jay JO SITY Jo Aioys onbiun & sey J9yI990] PLIOM paseys sty} Ul uosiad a]3uis AIOAg O00 orrrn—— FT T]TICGBUY | [roydeyD -suonesndsur £40A Aur [fe a4e nod ‘Udapyrys Aw Jo |]e 03 pue Ae dyj Jo days AadAd OUT UL S2AITTA OYA BIGGoY PAO] oN} AU OY, ‘$y1aqgoy vlusara Ag qn]D Aoqhvld S,dNVUol ig 24. 879 $0 vgsgabed ‘OEZ8zZ9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVIENACLINOOD jeLagrpy poss WSHAdOD |

The text on this page is estimated to be only 42.91% accurate

GET FOOL ITO ‘JJOSUUTY Joy stu ydoy sAeMIL UOY 3NQ S2[3]U9T][9 snoLIeA 9y) UO BuIpuadap SodiByo dU} Pip Os pue sd1Id JUDIOJFIP B peY [sis AIaAq “OWOY JOY 94e} pue [113 sty asooyd pynom UsUT 9U} “qnyd & ye JO “Ayed B Je “IQUUTP JOJ JNO d19M OM JOYIBYM Ud], “a[qissod se Suyop pue uonuspe snoyeyny ysoudn dU) YIM 9]O}UIITO S,uOY Jools pue speutue Aped swi0d0q 0} ps}oodxo 310M 3M SIYSIU sy} YSNoiyL, “a[qissod se 91}}1] se SUBS pue ‘spsq suruUe} ‘Suiddoys ‘soruipo Jase] Jey ye sAep ano puads pynom 3 ‘axOds 10 ‘aye ‘MOM | SUIUJAIOAD BUIUIWA}Ap SEIId dy} puke UOY O} ANP ssINOd Jo “YyOnU 00} poyedaAds SABMTE JLY} SAO} PUL SHLYSIUIW JOUSISOP SULIVDAA “Ul Pasivl usaq pry | ofl] Adjunos ayduls oy} WoOIy AID Ie} B SBM J] “SOINSKOT] STY JfO BUIMOYS JO ABM SIY SVM JI MOUY | INQ ‘URJUNS UDAD UL UTe}JUIEU PjNod | OS Ajposoddns sem yt ‘Aep suo AM UI payse | Udy “puNOIe SAOIP oY STYM ssa[doj 08 0} padjoj 9q PjNOM | UMOP dO} 94) YIM 3/QASAUOD SI Ul UdAY “UDATS SOULYD AJAA9 JB BSLJUBAPR YOO} ay ‘UOY YIM skep Aw Suipusdg ‘a0vjd jsut SY} Ul BULINTTe OS W9dS }1 9pRUL JEU) SN JO} pojured UOY yey} UOISN]]I UB JO Wed B [je SEM J] ,.OJ1] AUT JO YONW OS Bul}}91991 Jap[O MOI 0} AjuO ‘URW O} URL WOJl puNnole possed ‘a)nj14ysSo1d B Sutsq JO WeaIp { Aep au0,, $, Aes pu’ JOYJOW JOY O} SIN} “oIN{N} pojuleyUN I9Yj} JO SUIRIIP pue sadoy yim [113 d]1]1] OU Inq ‘Joe poos e uo ynd Ajaytuyap 31 paAolua pue 9] A}sajl] Siy] 0} panpgns yey) SPS oy], “JW 10} ApJVap os Aed 0} pey | J0uo0 poysiultuIp Apyonb pasojpo sy SJAISIJ1] IY} JO JUSWIS}LOXS SY], “SYSe} SUIPRIZOp JSOW 9Y} OP 0} poyse UsYM UdAd ‘o{qissod sv jueT{dUIOD se aq 1d99x9 Op 0} 1RYM MOUY },UPIP | ‘SORYS JO POM kB OJUT UMOIUT “puey }SILJ LUDY) SUTWILI] US9Q OARY ] ,UP[NoYs AjoUljap pu “oojoq sjoew [eNxos 9894} JO ABO[OUIULIO} OY] PIVSY IOAOU PRY Puv PO SIVdA UDOHIY], SEM | “WSIUOPdY JO sjoVv SNOJOIPN] WAOJIed UdAd 4Nq UI urof 0} A[Uo 30u 0} pajoadxea sem | “SAO} YJIM UOTIRIJOUSd 00} X9S [BIO WO BuryyAIOA “yt 10} pred Zuryjes ydaoxe ‘Jayjo yoes Buljsojowl pue poyrojdxa Ajyenxas Sutaq wos SuryjAue aS 1, upp Ady} ‘soisejuRy poiedsod suoul JO DLS SY} OJ J]! SBA\ }I ‘QUILT OY) UI SYOL) IISY} JO [[B SUI SULYORD] S[uis 9q} YJIM SUOSSI] ALU SB P9JONPUOS SOM S9ITIO SNOSSEIING ‘Hi O¥L] SULYJOWOS Jo ASiposd yooso ue aq 0} dn au BuTUTe sIom AOYL, “UleSe Yoroq SY} JO IPNpIOS oy} JOJ SuIBuo] sem | S9ousLINIIO ABPAIOAD oY} SULINPUS YPM I]qVHOJWOOUN Os SurTaq S]IIS J9Y}O oy} Wo JposAw SuNeiedsg “Aep Atl Jo puooas A1dAd AUT SUITFOIJUOS WIY YIM UOY Wo AVMe 493 | Ppnhom MOY PUR OF | Pynom d19Y4M jNq Suideose Jo weap | “WoAJod payo}sip SIU} JO SOIISAP JLNXIS dU} O} JURATS B FUIOg ‘SYI9M OJUT powiM sAeq ‘spyousq Auvtu YIM aued pure o1se{d j,usem | A[UO **aIqseg odeUs9} oy) Jo Adoo UOqIed B ‘O0} OUI pajURM ay Jey Apoexd SUIWIOSOQ SBM J SfIIS 9Y) YIM suiddoys jo Aep & spleMmiaye pur ‘epuo]q Jo JUN) J9}431] YONU eB “Ppaojoo ney Aut jas ojul payoog ‘Apearye su 10} Jno pouueyd Aep sjoym AW pey aH ‘posseip jad OF 0} po} puke JouLed ssoursng siy 0} du psonpodu! “TWILLNACIINGS JeVatpy payojoig yysAdoy 8£1P00TeTANIO TWIINOLINOD [euoePY passpo2] WYBLAdO? [/| UOY “SUO} [HFYSN]Q & UT, SUIIOW-PpooH,, 1d90x9 Avs 0} JeYM BUIMOUY jou A]jeoi ‘Apog Awl JOA0 sjooys oy} deiMm 0} BuLARY yO WIdY} doe} 0} ISAO payor pue soko Aut pousdo | ‘A]pnoid powreyoxs off ,,jfedue api] UMO AUT S.dYg {sdaajs sys AVM 9} [OSuUe Ue SHI] YOO] USAD Ys },US30QZ,, ‘ABS UY Plesy | pu ST YIM B0joq IYSIU 9y} 01 dn jos ay sayfoone yeyM ULL JOYIO oY} BUTI[O} SEM VOY “oAvg] UOOS p,Ady} SuIdoy joInb padels isnf j SANZ JOYIO 9Y} BUIZIUSOIOI JOU JNq USUI dy} JO OM) LWOIJ DDIOA S$ UDOY MOU ] “INys soko Aus jdoy J UOIeSIOAUOD ID} UO UT SuIUaIsT] “doojse 9q [[HS 0} SuIpuajoid sem J 9J9YM Pq dU} J9A0 SUIPUB}s SBDIOA poysny 1e9Y P]Nood ] pue ‘sJOJoq YSU 9y} WO, opnu [[Ws sem Yory™ “Apog Aw polsrood A7pLyyUe] sjooys ues oy] “Ajssy) Os sem | pue ured Suidunyy Zuiziuose ue ul Suripunod sem peoy AU SUIWIOUL }xoU ay} dn BuLyeAA “KEP SIy] O} MOUY J, UOP {US | ‘AW saRs oy syeoNsdeULeYyd IDA9}eYM 0} ONP pure ‘Ang sig} YM Ixau usddey oj Bulod sem yey Bap! Ou pey | “‘Sunsnssip A]19}3N sem Si] “[][B Joye aq O} INO ji OpeUl S[J13 SY) SB UN se JOU SeM SIq} “AeMe jos 0} Ajunjioddo ue pey | jyUN solu Avjd 0} pey | Ing Jjashw 0} JYySNoY) | ..{purus Aut SO] | 9AVH,, ‘ALP OS [O9} SUL 9peU SpuRY STY “SUIALYS JO [kOPIO dud OY} YSNoIY) oui paxeods ueW SIy) d]1yM Uede opim sSo] Au YIM Suipueyg ‘s#oy Au noge Buryy[eI isnf}.usem oy MOUY },Upip | pue ‘Ape; Sunod dn ys Nod aavys o} savy I],[ 2988nq Arey ve 31,NO4,, alu pjo} ay ‘sadd pouspiM Sy 1OJoq poxYeU Pools | se ‘14S 9q 0} payey | WOOS 00} [TY “OUT JOAO []e as[a JOADTeYyM pue spuey sty yim dn pus 0} Sur03 sem oy MaUy ] MOU pue uel suIdBe SIU} 0} JposAul asodxd 0} SuIARY SuTeipimny os sem yy ‘dn sul ues] pur I9AO SLU YOO] 0} pozuRM oy ples oy sayjo[o AW ssaspuN oO} SumMuIUOZ "YW YSnoy) poisisisd pue ‘20R] SITY UO YOO] Snws ay} WO UOTOReI Aw Sulsolus Jey SPM 3H ‘]]e 18 WHY J94}0q 1, UPJNOM Jey} NG d[QeUOJWOSUN A]OWIII}x9 SUIaq JO uDIS & se suoioe AW aye} pnom ey suidoy ‘wiry wo Aeme peoy AW pouiny pue Ayan sada Au pasoyo | “urys Aw Sulyq “rys Aw Japun daaio 0} uedeq spuey SULIOYIYS SIY 19} | URW Ide] Siy} Aq PoJOUIOD MOU PuP {PM 94} jsurese dn ow Suryoeg ‘UlTYy 99Rj 0} punole yoeq pou pue do} JoyuNod dy) uo dno ay) ind | ‘siapso sty SurmoTyo] snl syiid oy} paMmoyems | “o1OW 11g OPI] Xejd1 0} OW djay prnom Ady) se YJOg WY) 94k} OJ UT SUIT]IL ‘syfid [Rao anyg [yews om) OW popuey puL JoleM YIM dno onseyd jyeus B polly pue de} oy} pousdo oy ‘][eYy sy} UMOP HOOIYIeq B 0} DUI YOO) pur puvy JO NO 103 UOYRSIOAUOD INO IOIJv SUO] JOU OUT 1OJ YOR sued UOY “QUI IO} $}991}S 9} 10 SIYI SEM HI ‘Aq 0} AT] | 1, UPfNos Ay “ysnous Addey uses sjit3 osoy) ye Ji SuLyury) “MoU Joy peay AWW Ul SulyUIY} jo AWM Ady] poypysnl | “spud sy} WoIy SUIAIOSqO sem | JeYM [OpOW puke Ay) 0} Bu103 sem | ‘SSOUdATJUDHNL YONS YIM OU OJ UDdyOdS plOM ATOAa 0} BuIuUs}st] SeM | ade SuNoA Au ye dseis pue Aq) 0} pjioM oy} JO YOOTNO MU B YONS IAA “ISI ye pusyosd wos uso 0} SuIMO]q purw ysnf sem jt] JO 8179 $0 G9Gabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD 5

The text on this page is estimated to be only 40.82% accurate

Le 1 POO RLLTATO ABM SIU] ‘Palfstyes ATSNOTOBATA TB Wsy} deoxy 0} SuLvodde osye 3nq SUTAT] Jo ABM a]Qe]da99B UB 341] PUNOS ATUO JOU } BULYRW “Jay NH] SW pojsosojUl A[UO WSVISNUIUD MOY] “UdATS 919M AY} STA]SOJT] 9Y] puv oxeU pynom Aoy) ADUOU! OU) ‘OWeS NOY) Ul SSUTY] OM] 0] UMOP sLURD {je Yon Ajjold 3] 00] o5e SuNOA & Je Ud9q pey Ady) dy1] ISN! ‘dey snoloSuep e OJUT PoINy Jutaq A[dwis sem | “[99J plnoys srs Aut puodagq [AS & eYM JOJ [LYWNeaq 00} “U9Y) SAL] [NJWNedq [oJ OW ope Ad] “00] WODSd UR SB SARY Pinos | sjoadsosd ay} Jo [fe YIM peoy Aur SUT] o1oMm Ady] se i SUITAIS pure SuUIYystug Suing Surye) diam Ay) “ey Atu ym surAeyd a[1yM MIA JO sjurod plata Tay] yyim ut dul 0} uesoq spd J9yIO .,.00} yoeq Woy) JUeM OM YUIY) Udy) oye om ApjuROdUIT JSOW Jnq 00} sn jURM Ady) JOADMOY Ov puv SLUOD 9M OS APIS 119y3 Aq s]Its [NJNNesq A[UO JURM Ady] “UOY JO spudiy Ayeam oy) Auedwosoe 3M ,, ‘[I@JOp Ul SIOW 9]}I] & ULe[dxa O} UO JUSM BULA “ADUO JO} DIDYMOWOS posuoyaq Ayjenjoe | dy1] ‘AJLIOIOS IldY} OJUT pojydodoe [99J OW SUIYRUL APJULISUI ‘ODSETT 119Y) OJUT Pue WIdY} YUM paq dy} OJUO sl paqqeis “[ye ye Suiyjou Ajaynjosqe SsuesM ‘jusI0R ory] B pue ey YOVyQ-3Ol YIM jas soyjouY “Aped Joquinys e& Je spd jooyos Appis OHI] JUSIUAIIOXd YIM UMOP pue dn dunf 0} uesaq [Je AOU L ‘Op 0} pred s19m Ady] JeYM Jo sinjoid Ayjoid B& jured 0} Sunduiayye ‘UOHRSIOAUOD dU) UL MdIA Jo JuLOd IID) uo puedxo 0} Addey uey} sow diam Ady], “pip Ady} JeyM Jnoqe suonsenb MAJ B WY] ASE O} Poploap | ‘JOU Jey) 10} Sury)Auv 10 suoissajoid HOY] INOGe Ye} 0} AYS palidds S113 SY] JO SUOU BOUTS ‘SALP MI] B JO} }YOvA B UO S}LIDI[O BSB] O SUO YIM BIS 07] INO BUIOS jNOQe BuULy[e} SEM [JIB SUO ‘SINOY MJ B UL SUIUTLIIOJUS 9q PynoM ADU} USUI SWIOS JNoQe A]pa}Ioxa sulyeods 10} Suiedaid ssom Ady} JYSIU sy) INOge SUINeYS WY) piesy | ‘uoTONpoO.UI AUL d10J9Q WO] UONRSIBAUOD Mdt) JO J1q v BuIYyD}eo IsNLP ‘o49y UO 1U9M ATO yeYM JO Sulpuejssopun ue aid WOD 0} Payleys | USM S.JeY} PUR 19}]9q d]1)I] B 194Y)JO YORS MOT 0} JO []e Sn Tuo] ‘s}USUOLU MO] B OJ LUOOI DU} 149] UOY “prp jsowye AdY] PUL -WIDY] SALT UOY dJI] 9Y} JO SJYSIPYsiY DY} 99s 0} SUI Surpensiad ye SUITE ‘P[IOM 3] UI d1vd OU YIM pog dy) UO AeMe SUTJEYS pure JOLT sy} JO JUOL UT dn-ayxRUl $.JdYIO YORd GUTO *XOS OJ USUI PsMoId PTO 0} SSIPOG HOY} GUITIJIS JOU SpILO]]Ig JO JUOIF sq} UO 9q P[NOYs OY Spd 94] JIOM Aa) ‘[NpNNvaq puv sijeUIsiIeYD “aft] JO [[NJ pue sys Suruunys |e oom AOU], JOTpVS OW IYINOG pey UOY $,9UO dy) O} ARTIWIS ‘SuINS-FH e ysnl UI MIM SIOGIO puv dSV9 SsdjorNd e YONs YIM SdIpog Sunod snonjdnqoa II] SUYRIADL apnu Aja}; wos 319M S]IIG Oy) “UOISsoIdLUT ISA] TuLyooys y "SUM | OUM SI .AQUg,, PUB MOU SUOSIUOS 9W099q 0} pajuRM | “JJaSAW 0} JURNOdLU JOSUO] OU SVM AJIJUOPI ATA ‘arourAue ouOAUR 0} BURU [eoI AU UOTUDLU 0} SUIALIOM UdAd JOU AVIJUSPI Mou AU OWWRDAQ J] “Jd}JBUL YY) JOJ UOY Aq Ul JYSNOIG dq 0} J9A9 IO WISY] GUOUIK 9UO JSATUNOA dy} SEM | BUIOG “SLU JO} YIM dn sured sys sweU TYLLNACIINOS jeuaitpy poywejolg yysiAdo4 [7 oe 1 POOTAAANID jyod & . Aqug,, se sis Jo dnois ay} 0) oW SUTONPOIUI oyIYM puey AW pyoy BUR A “S}9JUOD SITY puke UOY Aq popiaoid syiodssed asyey JopunN ssay ‘Yyo9ZO 9Y} WOIy B19M MOY} Jo [TY ‘setUaM) Apiea Jay} Ul d1aM UT OM) Joy}0 SY} PUL SUdd} d}L] 119} Ul 319M SPITS DOIY] “SOMNedg 91OXS O1OUI SAT 199 0} JUSTU}Tede OY} JO pUS JBYJO OY} Je [[eYy SUOT e UMOP UdyE] SEM | 1X9N ‘UII 0} peoy AWW UL JNO FUIWILIIOS SEM DSUSS UOUWIOS AU JL) SUIYJAIOAS YIM YO 9q 0} papuajoid | JUDUINZIL JOJ WIOOI OU YIM ,.9SINOD JO osfo asoyM “ATTIS OW UWM,, Paljdas Apyois uay} ay doojs pynom | soYyM WY poyse | UsYAA SW YUM IT SueYS oq [JIM NOA pue doy WOO AU SI SIY],, “‘POWIe[oxo usy) 2H [210y Ayounes & JO NO oJINS UOOWADUOY & OYI] PIYOO] }f[ “Sur[199 oy} UO SIOLIT puke sdajs dai} Aq JOO]J 9) JJO postes poq punol sJuURsId B SEM WOO 3) UT IWR, JO adeoseas ou} ul duryeos odeospue] ewesoued oy) Jo {EUS}Od 3Y} PIZIWIXLU JL} S{[BM JOLI9}X9 sSe{s YIM 9dIe] A,QRIOPISUOd SEM WOO SY], JOSO]O [[BwWS B OJUI W9Y) nd pue justuede su] Jo YOR dy} 32 WOOI 9Bse] & 0} Sdeq Suiddoys Aw YOO) oY ‘sse[s uo Suiddajs SBM | JI SB POYOO] }1 ASSOTS OS 919M IVY) SIOOTJ I[QIELU 9}IYM Puke “1OD9P You ‘MAIA Jepnoejoods oy} Aq AeMme UMO]Q SEM J “SOUDPISOI SIY BULIQVUA “IOQIVY MWe, & OUT Suipes] ospliq ode] e pue ouAeosig Ady Jo ISI 9Y) BULYOOPISAO JuSWIUede puvis Ss. UOY 0} YOVq SN YOO) JOAUP oy L, ‘Iasuoy AUB [IIS 3]WT] © Bulag wor dn days B1q B SEM YI pur AU Ul “aqoipieMm AU Jo ped & MOU SBM SOTAOTU JO Spe SUIZESEU Ul SULIVOM UdUIOM UMOID Uses ATO pey | SodsId SESUT] OHI] SU 0} poyxoo] JeYM pue STULIS-f Ade’T “YIM LILIS 0} SOTISSIIOU SIOU MJ B ou Ang 0} pey ay ples oH ‘splemiayje sosojs Ayjeioads o10w Jo ojdnos BUY ust} SAQ “S}O]INO pueiq sureu ye Bulddoys pue oosolyje SuIUIP SEM ] MOU pUR S}]99I]s 34} UO BUIAT] AQUOW JO} SuTssoq SeM | OSE INOY Ue Aj[UO JJOSAW FL SASTIOG USAD } UP[NOd | “GULYIOID UL Bd1OYS SJoYyeJpuRIH AW SEM JYSNoY) sys JeYM Je poyooys SEM JUR\SISSE SOEs OY] USA ‘WY A[asEq jy) SLIYS SUIOS puK Syx90IING Au Jo dsnd oy) SUIPBIADI SWOYs JyoInd Aur “o1y7e Jadoid JO Bap SIY UL SUI SSOIP 0} ‘OD SPI qd’ V'H 0} SUI YOO) oY SpsrwMIOYe pure ‘opisiayeM OU] UO 91B PUL JULINE}SII INO DAL} VO} JUDM OMA "MOU JO} ‘pres oY SUIYJAIOAD YIM Suge juam ysnl | sey os pousddey [[@ 11 ‘JOR 0} MOY JO Op Jo Aes 0} JeYM MOY 1, UPIP | “Ayame! ournjsos pue sasse[TuNs OHI] STeS 1OJ SWUd]T VIM S]]eIS O[I}1] pue ‘syuBINeysal ‘sdoys anbiyynog ayt] Aq pepunosins “19}8M oy} UO ezL{d v ye poddojs Iv9 oY], “S]IAD OM] JO IOSSIT 94) 9q PTNOM SI) JJOSATW PODUTAUOD | PUd ST{} U] ‘$]991]S 34} UO BUTAT] SEM II PILY MOY PoIapIsuod Os[e | Udy) puR ‘ABM 1eYI [Od} pynoo Ayjeas oy aaaljaq puke spJoM sry jdasoe 0} payueM ai Jo ued V ‘P[¥d poreos & JIOJWIOD PyNOM jUdIed Suid e sv yons Iiey AW poyo.s dy .cJoaaoy Aqeq Mau Alu aq [],NOA puke NOA JO 3129 94v) 0} BUDSUIOS ‘Appeq Mou INOA 9q ued | ‘payuem NOA J] ,,‘pres oy “o1i90 sem jesodoid }XOU SI} “WRaY B pey URW SIy} SUIAdITAq ‘Aud Aw wry dae3 pue AyjedwiAs 8179 $0 99Gabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TWILNATLINOSD [ELIE POIDSBO1, fF IYSIIAdOZ ||

The text on this page is estimated to be only 42.20% accurate

TFL FOORRTEIAID yoajiod v urejurvw io dnpaeds Jo UMOPMOTS 0} OW SULIOPIO “1 JO aynulU A1dad padpnl Suraq sem | pue ‘,.qol-mo]q Ssejo-}sIy,, B ][B PpNOmM oy yey UY SAIS O}] MOY OI ][9} pue YNOU AU UT syeyUds sty durjnd Ajenbsojod Aq JJOSlury FUIS|NPUT s1OJOQ sTId Jo JUSUTIOSSe Ue JuTajjo pue SAULIP stuoOs ow Suryeur Aq Leys SABMIL P[NOM UOY ‘sAem Snowea Aue Ul URS JOAO PUL JOAO POAT[DY ‘OUT JOJ DIVWUIYSIU SUILINIOONI B SABMIP SEM OLUIYSIN ‘AoyMasjo sw posinbal uoy ssojun s]qissod auoAJoA9 SuIploae Apjsow ing Suyured Jo yeusnof Au ul Sum “oZeIs sos1oy dy} SUIYVM 9dJ] B JopuN Sus owt AW pusds Joyjel P,] PUOAIBAD WO —-JpasAu d4v] OSI O} SuluUTZIg “Wd} WIM Op su speul Ady} s}IOfdxa sso1s3 OY) JOJ S]II3 ay} Jo [Je pue uoy osidsop 0} uedoq | A[suisudins JON "yyem oO} o/qe ysnl sem J QUIS SOSJOY JO SH9eq 94} UO dn SuImolsd ATedIseq ‘uoIssed AW seM BUIPTY ‘Aofua A]jBos ppnoo ; Buryjowos ‘Ayjeury -ysIy ye WYBNoy} |“ Uoaeay ul sem [ Jday alam sasioy ay] aay syoopped pure siojsenb jyeys awos ‘sadeyoo MJ B ‘OSNOY UIPLU B SEM SIOY J, “WOOIPSg oy} JO apisyno asl] feuosiod siy OJuI Sutéad },usemM jt pue ssodind Aw Mouy | Jey) S41] SsuLqy WY YSP 0} JOAdU SUIMOUY UOY 0} poduOjaq }k pounsse | puke Joye] sINoy AueW EPO] [eUdD Ul YOUR e ye BUIALUIY “o[qissod se sonwoyne oy} WO AWM IV] SB POARIS 3Y DINSUd O} YOO} HI JOADJVYM OP O} pey jsnf[ sy MON ‘g0uUd90UUI [NFYyINOA Aut Jo uorssoidwi dt} SUIAIS sABMIL SOTWOOY pue saxo anjq Au YIM ode AU URY) JodUNOA poyooy Ajjenioe J ‘SPS 19Y}0 9Y) IYI] YOO] Jopyo oy} JJo [[nd 1 uprp | ‘IUIBIJA, JO $]991}S SY} UO SUT JO JNO UOIIQIYXS UR Suryew Jjosuy uodn }YZnoIg pey oy d[qnoJ] Jo ouTLUpUR] e JVYM MOUY UOY “Juotujsede sry ye BUIAL] asnqe JO WADIA ajqissod ke se ji1d SuNOA AIOA B BULAJIJUSPI UOTIE}S aorjod jeoo] 9y) Je JUN suOSiod Buissiui dy) 0} diy snowAuoue ue psyodal SBY DUOSUIOS asNeddq ApiSA.QUNOD S$ ePlIO] 4 0} diy duo] & Surye} []e d1OM OM JY} ‘OUIL] B JOJ UdAD ‘A[] YS Ul paxoed sn Jo ][e [fa} 0} panurjuos oY AjWyed ‘duly 9g 0) SuIOS sem GulyjAJOAd Jey] Sn Suunsse Aq uedaq oy ‘UOIEN[S d1JUS Sy) }B pasnure Jyey soy} Sus suo ATUO oy} SVM | ‘AIPM oy] JUowWEde 94) ysnoiyy peoids yey) otued ay) [je Joye UMOP SpITG OtUvIy OY} Wyed 0} BuIA) SBM OY OLUT] Oy) UI pue dn poyxoed 313M OM 3DUQ “Ppolivos OS UOY dy] ue B Ud}}08 dA _Pynod JeYM SNoLNS seM puke AT[VOTJUeIZ PUNOIe YsNI 9UOATIAD BULYOIEM DIDY} JS Aj[VOIse | OS SUI 0} SUISUOTEG YONUI SAvY 1,UPIP | “ABME JYSII DARI] O} PRY [Je IM SB SOYJOTO OWOS pue SsuIsUO]aq JURWOd IT ino youd Ajuo 0} spils sn Suijja) juotupede siy ysnosy) posedures pue Avp-du0 siv9s B 103 UOY “OW YIM popes [ye 1 ATpnojd pue ‘owayos yooiod sty Ul YORIO 3[SUIS B YIM ULDOQ BHLJULAPL UMO SIY JO} Xs SuT[]as JO PjlomMIapuN 9uyj UT SIIdUID [1Ad STY JO BuT[qUINID oy] YsNoUs UDOS ‘Apeaie Mouy ay asnesaq Ajqeqoid “duoIM sem yeym ow YS UDAD ],UPIP OH “daays 0} Aem Oy} [fe JasAur SutAIo “soyoynjo YSN SY TVILLNACIINOD [eLIsIe Pooojo1g jyBuAdosy [] OF POORIALNIO ul Jno passed | se WedIp JURISIP B OJU] SMOLIOS Al SUIUIN) seM ay JYSNOY) dY SOIOA STY JO dU} poladue SY) TUISN WdY} MOT[EMS 0} SW GUIOIO J ‘sjid yurd 3014) WIM pauINjes pue psreoqdns Toole 9Y} OJUT JBM OY SOR] pourejs Jey AWW WO sdho AW UT Jtedsap Jo YOO] dy} Bulsas puke UMOp dU SUIART “WOOIPsq INO 0} apIsuT ow JYsNOIG pue sue diq sTy UI dn ow padooos uoy pue paads jo jsinq e YIM usdo poles Joop SuIpl|s oy], “Ou JO} 910}S UT SSUTY} JOYIO pey SITYRU JOYSIY e JO 9910} SWOS nq UO Sulod daay 0} suOIsIoap peq AURU 00} spel pey | 1YSNoY} | “[[e} 0} Jou UosRal Aue JO YUTY) 1, UpjNos | “Yop AJaA AW 0} 8p oy] JJo Suiddrys ysl usdd oO} QSO]O OS SUI YJLIUSq PUNOIS oy) Jv DULOO] Js pue Buljrel dy} JO adpa ou} JOAO sda] seq AW poyly | “Josuo] Aue sty} OyI] SAI] 1, UP[Noo | ‘sarpaseyy UMO S.dJT] AU SpIeMO} QUINU OS sUIedO | “BuIy AUP {99} 0) SuTURM LUO poyoejeg ‘yoroidde Ja1seo yONUI B paulisas Jo Jno Jos 0} SuUNYSY JO poy OS SEM | SSOLU poyZue} dy} ULY} JoY}eI JoJJO 0} pey Yeap Jey) Ssouyoesq a[dus dy) pue ‘Joisea YONU! powlses j[e WI ‘ospo ay} Joao Suiduinl JO 1YSNOY} 9Y} Ule}ID}Ud 0} URSOq pue poddedJ] Os Ja} | Bpisuy “sysay9 Aul UMOp yeaq AjqeyAoUl JourjoAo Alu SULYeW SpleMUMOP BUIP{OL) ‘soko Aut ul dni payjams $1e9] 3) ‘pomnpus Apearye pey | Ssaulpauo] _ pur Suusyjns Jo s1esA UdsWNO} dy} JOJ ssoupes AW UI JuTJeMq "QOUdIINIDO §_ ALP SY] PAlaqMIoUIdI USAS ATIWIe} AW JI palapuom pure \ pnoy ino Aepyyig Addey v JjosAw poystm | ‘sem JuouTpEde s UOY sioqm Sd1J0}S AUR SY} WIOI, UMOP TUTIOOT “adpo oy} 0} poxyem pue Auosjeq dU} 0} SIOOP sse]3 Sulpr[s 94} pousdo | YUP Joyjoue jjasAu SuNog ‘JYBNoY} | 9dUO JO} SpNI!JOS OWOS* 3 JOJ JUSSaId d]}II] UMO S,poH SEM JEU] pur “BUISq SLUT] OY} JO} ‘oll 10} }d9oxe Ads sem juowpede sy yj, jurod siy} 0} [QUN 9q 0) dn uMOIS pey | Id ay) Wo Aeme durtAys Ajaya[duios “1asuo] Aur J[9SAW MOUY UdAd } ,Uprp | ‘pssu Ataaad Aw JOj Bud 0} UOOAAP sty sJOMS OYM URW AJDdA 34} Aq porjddns Ajsnoisues Zulaq ‘Joyooye puke sjrounsovueyd Jo uoldO9U0D B UO papeo] AepyLiq Aut Sutpuods sem pure Jed ues Jey) IsNdNy UL UsdJINO} pour | ‘Apoq AU pasn dy Moy JO 1YsNoy) oy) 1e Joppnys [Ns | “OW pure OU JlosAU YIM pojsndstp ATUO SEM ] OUT O} PIP oy JEYM Joye ON “tUTY 0} SBUTY) UTR}IOD sO] PIp | Voy uoddey pynom yeyM ule[dxa pue UdNOU! AIQAd UO SW JOILISUT puv 9101 J9YoRD) oy} Ad 0} pexl] ay YSNoy) UsyO ‘Ur sem ay poow jeyM uo Uodn Surya |B “Apo Aw JO yout AJoAa Surdiysiom “urys AUI SSoseo puv 9[]U9G OS dq P]NOd ay sow) JOyIO LY ‘pojURM dy S}[Nsol oy) BuI}}09 Je Ssa[JUS[91 puke DuLaMmod13Ao0 00] SEM OY “SIOU! OU PTNOD | [UN pajsisol SABML J ‘PoyUBM oY JLYM AjOeXS WY ARs | JUN ULeSe IOAO PuUk JOAO 11 Op Udy} 11 AOfua pue Ay} O} OW {[9} pure SLU NY P[NOM dy SOUINSWOS “BSULUDAD OU} JOJ 3JO}S-UI pey dy SOIISOP MOU JeYM Suyregy “YIU AIDA JO pud oy) pessp sARmMye P]NoMm | 8179 $0 /9Gabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8ZzZ JUaWNDO ‘898Z-8T aSeD TWIN TCEINOO CUAL Pdy99}04,q 1YAIAdOD [5

The text on this page is estimated to be only 42.69% accurate

EFT FOORELINID TYILLNACLINOS Tri rooMRLLinip TVYULNAICLINOO [EMIoVeAY paso wyBuAdes 4 JELLY] PoI9jOl IYTIAdOD [] OT ‘A[poyeadas uvur Areas @ Aq pode DULG SB Pq SE 3q },UP[NOd ‘Aepo} SW JO} d10}S UT AL] JLYM SSO] 9B PjNod ] UO MOIY} OF SUIYJOTOS pUly 0} SIQMEIP ALU YSNOIY] SULIOYST “d10JOqQ JYSIU 9} WYaJ ] AISTUI Oy} OI, pajyelodsexa pue Aep xoU 9y) oUOTe []Ws dn OyOM J OFT] Aut ul Aep satjoueR de] UeY) JoWjeI Yeap Joy podsaq pue poy 0} poAvid | ,.do}s 19A9 71 [[IM UDYM,, [ROPJO SATSNge Sly Joye posnssip pue Wny Suldg JO ssul[soy AJA, “yep dy} Ul Sulqgos ‘s}adys 9y) ul paddeim poyeu ARy ] IYdiu Jey) ured oy) Suldeoss OU seM SIO], WY) Joye sunoy JOJ DFVME SEM | DUCT YJ97] “SU O} PIOM B SUIAKS UDAD JNOYIIM “]Jo| pue dn jos ysnf oy ‘Stuy puddas 94} OJ dINnseald YM Buysing siy uody), “OUUOD 0} SIVA oY] YSNosY] UO ATVI UBAD P[NOM puke Ps]RdY dq 0} JOAD d9dp 00} 913M Jd] Sy yey) sueds siy Aypenjudaq “Suiaq AI9Ad AUl dje]OIA A[d3ap 0} papsssoid PUe poq 94} 0} SUI IYSNOIG SY BIDYM Ile YSOIJ OY) JO [IYO sy} Wor sduing asoos pey | eds oy) Ul 19}eM JOY 343 WWOI duuep |]NS ‘s100p uiolpe yousI4 94] Bpisjno isnf{ sem YY “WOOIPdG 34} OF OF OF DUI Paled pur ye dy} JO INO dn ow paysid sem UOY se Ul SSULIedg AUT UTES 0} BUl[SBNYs SEM | Yjeq daap oy) UI padisuigns Jjey [US JUSW [NJ ul popoldxa AJJeuly dy USYM poipuny kB ISAO 103 ySNI | “SIy} JO pud dy) 0} SU PaidYy Ty A[UO PpoyUuNod | JOQUINU AIDAD SUIADITO BWdYyMAS]O s]ysnoy} Aut d30y QO} SWI} 94} GUISN JUNOS O} URT3Q puB SdAD AW POSOJd | "poayesy SIOU! WY Spel ATUO SAdITOQ | YOIYM ‘OUIT] SITY) WT MOY ATOPUTJOp sy puke UOTSsoId3e sty Aq ny AT[eo1 seM | “pIp JOAdU oY Inq ‘dojs pue AjId oye) plnom dy Suidoy sodd onjq Jsoppes dy} YUM LUTY O} dn payxoo] | se s0ey AW UMOP SUIWIVIIJS SIVI} PLY | “UOIS SIY OJUI SUL PIdIOJ pue Pedy dU] JO yOeQ oY) Aq dul poqqeis ay OS Jsonbai sty 0} SuIpuodsal UI MOTS 00} SEM | “4909 Auli uo sdij sno ynd,, su pjo} oy UsyM UMOP WdY) oye) puke sjued siy opun 0] Uvddq OH ‘[esnose siy jo Aeldsip 1a9e9 Ue YIM OUI Je UMOP BUL{OO] ‘qny AUI JOAO SUIPUR]S SEM UOY SEM JOY] “‘Sununep sem 19)eM 9y) SAOGE PoovJunsel | UJYM OW FUIPUNOUNs sseult oy) je asduNys isIy ATA “SAWP 9S9q] SUIJO SEM [ dn UMOID MOY JUDUIOLU B OJ JODIOJ A[ISU J PUe SAIPITYO pue A]TIS 9q P[Nnod | Yo} | USYM PdsstUl [| SAeP dU} OUI payup syqdnoy) AJ ‘S010A ATPUDLY & WoIJ Iesy 01 JsNlyaj 1 poos moy pue fy] ynoge Yury) 0} Uvdaq | se Jd}eM AlIed]s OY) OUI popr]d Apog AJ ‘suoTINedoId s.1YStU SY} S10J9q xv[9J 0} AI] pue eds dy) UI YEG B SALY O} PopIdap | OS Jnoge PUL NO 3q 0} POUIDSS dS{d SUOAIDAD PUB A]dWUd Payoo] soeid ay] [evo suoyd pepssu Ada pure Jaliq AW YIM ACME 103 |] Surdoy ‘uoyY YIM paseys ] Jey} WOO OY] OJUI potojUs | pootyouun Aeme poddiys pey | durjuly] “YONO} Ul Oq PJ WIY plo} puke sao] AW WY dAed | JODUO] OIG B JJO ppoy ued | A[SNOLAQO BuO] SIU} POATAINS pey | OL} Sy) UT sOURINSSe WIY SUIAID “Aematuos ul djay 0} BurAqy ysn{sem oy yysnoy] | “opqissod SB GUO] SB UO OW d3ay 03 vayd oyeJadsap Jo WOYs SuIyjoU oJ9M sUOUd 3y} JJO Jad 0} sidwaye stp “ATWoOYs ulese voy 0} Yeods pynom J ivy) a10U sy) UO Yd] J PUB PsdTJOU DuIog SEM sdUOSqe AU SSL UI \SNf LOYS UOeSISAUOD 34} 1d94 J ‘palqnop ATsnouas sem jnoqe syods ay ALLOOUIS 3194) UI jsny Aut ‘ABMP JUIS SEM | STUT] ISITJ SY} PlO SIVA USAID SEM |] USAID “OUI puIy pue AJ} 0} SIOJVSUSSAUT SJVATIA POITY UIAD PUL POLLIOM AIBA 3JOM Ad} WY} Bul pastwoid pue Ajsnosotunu way) Aq payed ussq pey off ‘Ioyjoue 0] 99vd BUO WOIY SUIOS DAI] SEM SUT) SIU} [[e 19]Je SW O} PUL UTEBe IS[9 DIOYMOWIOS AEME JUDS 3q isnt p J SUIMOUY ‘ot JURM 1, UPIp Ady} plesje 00} Sem JNq poos JOJ Woy) AUL YA 3q 0} pue ApItuey AW []ed 0} posuo] | MOY YM popssdo.d | ‘f° L uo sonssi Au duinp 0} UO BUIOLD “WOIJ 9dIJ YRSIQ 0} 9]qvUN SBM | Jey) 93Bd ul }day Bulag SHI] SEM JI “SSO[ISN SEM SIOYMOU JO I[PpIuUT 9yj UL Adesso 0} SutAy} ‘UNY JO Palji443} sem | MOY Puke UOY JO UY BUTI] “silepye JO o}e}s JUDIIND AUI JO UNY PIO} | “SW IO} SPIOM PULY JO] Ssoy eye SEM OY udYyM poyquinds Ayainjosqe | puev poyrey wiy 0} ayOds | UsyM 3010A Addey B aB10} 0} ydwi9}j8 AJA ‘UInjor AWW poqnop suo AI9A9 ‘spuds JO Aprumey AU 0} PIOM {SUIS B INOYIIM MOU SYJUOL 9dIY} APTRON “SATE [[US SEM | JORJ J3dYS dy} puke SUI WO IBDY 0} PAyxdOYS Os sem dy ,.{ABYO NOA sIy jeuuss poy Au yO ‘nod $_}J,, “UY UT ][IYo & pajeIpel sd1IOA AW JO punos sy] ‘pUdLy poos AU [{ed 0} auoyd ay} pasn puke SUIOO Sond JURBDEA SY] JO 9UO OJUI yOnUS | ‘psotjou 9q 0} dtuT) ASng jsed] dy) ‘ABP 94} JO S]PpIwW 94) UT “OU O} FP} O] YBNOUS dvd P[NOM Jey} JO YUTY} pnos [ Uosiad ATUO ay} sem ay pauaddey sry} Jo []e sOJaq JourIUNS oY) YsNo ys1j AIDA Au Bulag “diyspuary pooypyiys ev Jo uroy Sumuds sao]; Addnd SII} AU SEM OH “BJOJOQ SUIT] BUCT & JOqUINU SIY pozOWSU pey | ‘|[oOM OS ‘jJaM AIDA MOU ] PUB BSO]O OS B1OM OAK L WIY [ed TY]. ing “Aoeaid JO JNO sweU JUOM J WOYM ‘jsed 3y) WIOI spudty JOoYdS AW JO dU poyjeo ] Ajipejusu JUddSajOpe AU JO SUOSWIOS YIM JORJUOS BWIOS BUIPION ‘asiom youu aq pynos ‘aoustiadxa yeuosiod UMO AU WIJ MOU puL poieoy 7 ‘o1941 [VS §,dU0 dy} 10} ATAJEUNLIOJUN dIaYM ‘S}991]8 9Y} UO BUIAT] JOU JO 9d1Id 3) JOJ QOUDdIUSS [CUIOJD UL dyT] POUldas JeYM UO JUDM S]YSIU asa] “WY oyesJouDd Ajastooid 0} MOY UO SUI pojonjsUI puke WN}OdI IIOY} UT sjods-3 sAeY UdTU MOY JUL PO} dy ‘UY UO SAO} X98 SIT] BSN 0} BUIARY SUI O} SWS YT UOyM SOSNOXS OU PRY | INQ SITY JO sIISOp [eNxXs JOYJOUR YIM UTY JOIIPII 0} Ad} p[noM puke pdjsisol sAemye | Ing Ayjeue sul SuNeNouad udad Soulja wos ‘XOs SULINP LNY Su 39S 0} PoyAI] UOY ‘SAO] X9S UTIOIOJ JOYJO puke SOpIIp dSN P[NOM AdY} SOUITJOWOS “19]U99 SY} UL LUTY SULA[OADI JUDUTJOBUIII URIGSs] B YIM UY UlejJA]Ua Udy) dndyeUI JO speoy puke }1yINO Axos awos ul dn stu ssoip spd oy} Sulaey uM possold pynom ay Aplepusol SUNY) “dd1}0U s}UdWOUI & O} dn yo] asuduns e SABMTe SEM BUIUDAD dU} JO S91 SY ‘JUSLUT]dUIOD & ou DAS ATTEND" dy UOYM Jodes SEM ] uty Burseayd ul suOjo Auli JOJ POZIONlio Sulog ApuRJSUOS sem | WYAYI 8179 $0 ggGabed ‘OEZ8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 43.86% accurate

StL FOORELIAID cl poos oy] Jo SAep dU} WodJ OJOS JO 9SUAS IeI]IUIe] & PoyeIped }I ‘sse[s oY} ysnoryy sovy Au dn wiem uns 9y} Suljasj ‘JO spisul ABMe PdydO[ SEM | 1/90 Arvaip aq} ayTUN ‘apis}no Avp Auuns [IHNeIq & SVM jj] “SSUTPUNOUNs MOU ATU 99S 0} MOPUIM 9Y} JO INO PdxOO] | SUIMIOW 1XOU OY, | JYZTU yey} [Te IV Ul OTD JOAD OY J! MOUY UdAd },UOp | ‘dasjse sures dn popus | [TOULIMY [euoNOWs sAep oy} WIOIJ poysneyxXy “unoduMop suoyows Aw jo] pue Uede Suiljej sem ppOM aoym Aw SMO] dy} OJUO UMOP peoy Aw ynd | “soy punose days AW YOIEM O}] Pel] | MOUY ] oul savT UOY SumeEM ayy Joye pue SuryyAue yono} 0] piesye pog Alu UO jes | “ATIOYS YONG 9q PjNoM ay *}IVM O} SUI Plo} pure OJUI SUI PAMOYS dy “WOO AU dq PyNOM sy} OWI SUITIO] “ABMI[eY [WS 94) Ul SIOOP dU} JO 3UO pauado puL sIiejs OY] dn SU PayfEM dy] “9/qQeLOJWIOD [99} 0] SPRL JO BOUAPISaI Mau AU JO NO} BUILUOSIOM & USAID ISASU SBM | ‘asnoyuMmo} ped Jojayoeq siy OUI SUL pay pue 3eq Aw dn poyord syseyy ‘Siy] pasueie oy uayM sjlejop AW Jo [Je Ul poy Apeoye uoY sins SEM | ‘SUI JOJ SUL SUINSE UL I9YJOG USAD } ,UPIP Inq s1p1vYD sem seu SIY SLU pyo} a4 “Surdoy ysnf sem | ‘sAeMmAue },Up[nod dy MauUy | “sw doy 0} ABM SWOS JO} WY O} yeadde Uv JSOLUTe SEM I JOp[NOYs AW J9AO ISALIP IY} O} YOO] ISL] 9UO YAK ‘J[SSWIY O} PosoxOius dy SB Pasnlue Psuises pue umMop puke dn duu payoo] apf Jey] ye JOUMO MA3U B [{NS Ing ‘UOY dyI] ej Ajonbsaj}o1s Os },usem dy yNq JOOP 9Y} poloMsue ULU dUIP[eg JayjouY “SSOUPUTY JO LIOS SWOS YM NOA }¥91] P[NOM IBUMO }X9T Ino& sdoy Ayuo uvd nod se Jay] Jay wo poxoid Addnd e 9q 0) 1f9} 11 MOY MOU | MON “SLU PIM JOOP 34} Je payem pue Seq suo AW YIM JOOP UOT 34] 0] SW PIJOAT[AP JOAN 3Y[ “AWN SIU] GD 9) Ul sayMOLWOS ‘sayoRaq 34} UO JOU JNq “IWIeIAY Ul YOR SEM | “S3A3 UMO AW DADIIOG }, UP]NOd | ‘SSUIPUNOLINS IeI]Ue} BULSIS PoyTeyS | JUN “sINOY JO} SAOIP 3A, * -JaUIOS 9Y) punole jsni sem dIns UB] d1OLU SEM | Jey) Avp Autres e JOJ yseo Aw Sulposul siyounos AW Ul SOY & IYS | ‘SULAKS UD9Q PRY | S|[Iq Je]JOp peIpuny Jo peM ke pue sayjojo Att SULyR] AUD “UOSAJJ PaiSIM}) SITY JO SUDO} sv dtu JYsNog A[SULIeS OS dy JY} SYOOd Jo oIsnut ‘ArpaMaf ay) [Te eM 1, UPIP | “Id oy} 0} deq s[SuIS AW YOO} dy pue dtl poJayjo pey sy JY} SOINUIW SAT] OY) ULY] JOSUO] OU ‘pres uoYy se ysnf “Oop AU Je SULYIOUY OWILd JOAUP SY “WYSNoy} sy Os Jo ‘JySiu Jey] SU JO UIT spuRY SITY PoYysemM dP “SU! YIM dye} 0} SduTsUOTOq Ajuo AUL 9q 0} 319M AB9[D SpeU dy YOIYM ‘sayiOO Alu YORd O} SoNUIW SAL} peY | IU plo} puv Wool AW JO JNO STIS dy) JoYsN 0} YOR sed OY “SATTR S13} JO JNO }] Opeul savy 1,upynom Ayqeqoid | 10 ‘JjosAu 0} JyYsnoY} J “And s9yJOUR SeM }I MOUY ], UPIp dy yseoy yy “ABMe 1YSI SU Sem J MOUY OY ‘AJOAINIISUOD WOO Jey] LUO, PI]LIP Joquinu sues Sq} puNo} pur sijiq ouoydsya} JUseI 3} IB payoo] uoy os ‘dn passow JOasu sem yng ApIejNdoJ WOOI 9y) sn SU MEPS AYS ples OYM Jadaoy-asnoy 3Y] WOIJ SW UOTSSdJUOS SY} JeY) Wy) TWILNAGIINOD JBvaTeY] PIosjO1g WYBUAdOD Fj Pri Poor usAINio TT JO JJO SOS USYOIq dy} YSNOIY} INO pUly O} d[qQe SEM | {SUIYJAIOAD SO} pue sUOdUIOS ]]eO OF pey | AyM ‘sadengsur] Yysijsuq Isoq Moy} Ul ow SULySe pue SUIAIO 919M WY} JO []e S9AQ-poos 194} ABS O} UI SILO S[IIS OY], “SIOU! OU PdTfI19} ATUO 7 ‘URUT I9yJOUe ‘IOSULIJS JOYJOUL 0} ABME SU JUSS BUISG SEM [ MON ‘Pe SI} JI SSO] WIY UddS JOADU pey | 3g ANB so1U & SLM TOY IJYSNOY} ISAS | “Porjfi4s} pue SsoTy eVaig ‘ssuN] Aw BUIIIIUS Ue ISAT SY] UO SULYOYO “[[eM oy} UMOP PIs 1 ..g4Youg oul Suresy Sulyony NOA s1V “9¥1] P[NOM JSOUI SB 9dIU B JOU S.dY pivay 9A] ‘O} NOA PUds | ULUL IX9U 9} 0} 1991 9q 19}}9q NOA pue sul LOL ABM® Iej- Jey ‘ARML BUIOT Iv NOA,, ‘[]eM oy} Isulese stu suluuld yeoly) Aw Aq dn ow payoid oy ‘oweys ul uMop peoy Aw suiind pure ,.Al0s UL. ],, ‘Suldes yday J “Burnoys oy} jje usamjoq Mo Jos 0) 98euelu pynod ] Jey} ssouajuas [duns YIM poydos | “ode Aw jseo] ye seM OY Jey) SNOyeal UdAd OGARlU ‘ANS JoyjOUR 0} SULY]e) SEM | J9RJ 94} 12 Josdn 9q pynom dy JPY) PIOM WOW sem | ‘UOUTYYSOJd Jo ssodind 9y) JOJ syuBISiWIU JEDaI]t SUNNIOI[OS 10} JYSNRS BuI9q WY NOGe SULZUTY) USAD },USEM | {J93u0] Aue ol Joj Sn OU pey dy Jt OW YIM Op 9Y PyNoM JeYyAA “Noe YUIY} O} VSTO SUIYJOWOS SUI DART S]URI SIY SIUM WOO] oy} dn SuLed} SeM 9} ..g Mou NOA ym Op 0} pasoddns | tue Jey AA jJeY) MOUY NOA [13 prdnjs v yng Sulyjou ae NO, {JYsSNVd sw 499 0) SUIAT) NOA aly, ‘pourejdxs Je Sem IT YSNOUS UOOS ‘a[qISsod s¥ dI[qISIAUI SB dq 0} Poly SkVMIe PLY ] ‘Bopt OU pry | ‘MOY INQ ‘f° ], SULTS seM | LY) INO pUNOF savy Jsnul sy ABMB JYBI MOUY | “OW SPIVMO] SuISvs PUL PSLIO}SIP SEM DOR} SIH “9]Qno.] Big Ul SEM | BuIpooy INQ day },upjNOd | ‘OJBUIO} B sv pol “JOOP 9y} YsNoIY} Ul BUSING sued UOY “Wopaiog JO NO puNnore Bursuno] ysnf ‘uoousaye UO WOOIPaq INO UI SEM | UdYM Aj1[E9I 0} SWIED JV9y ISOBSIQ A "UleBe 1940 YORI 01 ay0ds JOAd 9M SUT) ISP] 94) 9q UDAD PjNOM sii) Ji JO yx9U uaddey pynos yeyM BuLMouy JOU p9Ad-A1v9} 393 YIOG P[NOM 3M PUR UONPSIOAUODS BY} JO ped 94q-poosd dy} SOS PyNOM Udy] “OSE BuO] 00} WOL AIOUWIOU JURISIP B }@ YSNL] PUL P]JOM JY) UT 91d OU YIM SPUSLY pyo syl] JeYO jsnf ppnoo am SOWTIMIOG ‘STU MOUY AT[VSI DIY} INO SUOSWIOS AI] [99f 0] Papsou | “yoom EY) SOUT] IOUT MOJ & CT PUDTIJ AUT PaT[ed | SOIOA sTYy Iesy 0} aJeIOdsoq “OPISUT OY} UO {OUI JEUONOWS dy} YIM ddoo 0} MOY MOUX | ABM ATUO 9) “]1e} 909 diNodeIoy) Opell-jjos AUT WO Joquinjs doap v OUI UST]e} Pey 71 MOY T s1OJaq pue souoydpesy Au uo ynd | “yrys AW SAOUISI }, UpIp | OS JJo WY ssid 0} 1NO SUM J ‘JUBIU JSe] porous! ApJURIe]q OS 919M doO}S 0} SOLID Aw Joye ing Yoo 9] SI Ul OU-OU BIg e sem UO do} LUTyIq B YIM 1YsNed 9q 0} OS SouT]-UB} paley UoY “Pj1om oy} 393I0} pue yood ay} Aq yno 9A] 0} pajuRM | ‘IsvfyvI1q AW JO} SYOHNS AlO[9O OM) BUIABH “JOyd osnoy ul-sAt] oy) Aq spew ‘ATU Apooy]q ® puv $_,uId0}AxO parfddns oy) Jo Maye YIM Aep AU BULLIES 879 $0 69Gabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVLLNACIINOD FEUMeY pos10.| WYsWAdOD 7]

The text on this page is estimated to be only 41.78% accurate

LET POOTAALANO VL ‘APISUSJUI SOJISOP USI IO} poey oy) Suljjoy pesy Au ul JoBsuoIs Mois A[UO | ‘Oanseoyd Ul JUDWITUYSUI Sty se Apog AU SUISN SpsoU GUIAJILIS UMO SITY Pds[Npul Jas oY STI ABME POYOO] | “SOAKdY 9IQUIODJOp Ul No pouKOW sy “JsNIY) [NJIo10J B YM OUI OUT Pd19]Ud SY SU GUNLPTUITUT SEM ]T ‘TROUW 1XdU STY SSRALI O} BUTITRM \svoq poloduNY B OAT] OU Je DUITIOZD ‘al Jo do} UO Ae] OY UOYM JayUIUp USAD [99j puv AZZIP OUI OPRLU SSO1WVeW AABM JY} WOI] SUOTIOW 3] “paq SIU JO {Ppl oy} Ul UMOP dW paysnd puke WioOIpa sIy OJU! sIieys oy} dn dU PI] SY ISNHOYUMO] SIY JV YOR 9OUO ‘puLysJOjog WOI BUIZISeJUR] SEM oy yeYyM ApORXd UO OB[Npul O} eM 1 UpPrNod ysnf ay ‘pasos UdAd pey qnyo ay} B1OjJoq SWIOY JW BULye] “UO 19}e] UNY 10FJ dJO}s ul AB] somnseayd yey SUIUISELUL SLU PIYoEM IpIeYyD se ysnoy) soysnf Aue ou Op 7, UpPIp 1] . “OISeW S Jl YOM PUL PfOYR 34k} ISN dy} SUID] pue speYD YIM Bulouep UdAD JNOgR Buryjod10j A]9}9[dWI0d “19A0 Yoo) Apog Aw Jo WyyAYI oy} pue pesy AW UI pose]g SISNW IY] “194}]990} 1OO]J DOULP dy) UO d1OM 3M PUL suiuulds sem peoy AW }1 MUX | S10Jaq PUL Y}OQ SN IOJ S]le}4909 Fuols poiops0 aipaeyD “doy uo parayjous AAeIs snoydunios & YM $30je}0d poysew pure yeojs YUM [Row Ajay & polaps0 | ‘UOY YIM Buldq s0uIS OUI} JSILY DY} OJ puv SNOLOL[OP seM POO} OY] “O]epsopney 14 UMOJUMOP UI SALIOIOYD IOH,, PI]9 J9MO} GUIA[OADI B SBM I] “BULUSAD 3} UT YDO]9,0 OUIU pUNOle je “qny]D puR JURINE}SOY ‘UO UT OM) STY 1v POALE OM ‘puUsTIF [IIS MOU STY UO Axas YOO] P.d IYSNOY] oy ssneseq ULOJIUN Jay ANq 0} SAY P,dY Jey) ssopeEM dU) YU Suryofl udaa “sajooy Je Youn] 10} NO pue yeu suiddoys dy} punose atu Suipesed padolua ay yey) Aep ey} pooijou | “Wiry 1OJ IVaM 0} SW IOF IYSnNog osye p,dy Basdsul] DY} Pdyquiasal ‘A[aSOTO JYBNOY) F YOIYM “s}yINO ActuuIys puke ‘sassaip [le] 909 Aur] atu yysnog dy “Apo Aw jo drysiouMo SIy poAoid AJUO OUI O} SBM OY SUIPRIdap sJOW oY] “ABM JeY) I PdyL] Ose dy UOY sylp IsNe “ANJWSOId BSvUdd] B PaiRjSOp Uddq SAY [[IM SB IYSIU | yorum “sO pred dy SdyJO]D dy] 9sSOOYd pyNoM dy papr1oap ay sdoys 34) IV ‘O] osOOYd ATSUTT[IM JOU P[NOM | SSUTY] AULW Op O} SAeY P[noOM ] PJOM Ysavy SI) Ul SALAINS O} yey) 95K GuNOA ev WO MOY | INQ ‘uIOd sty} Aq 0} dn payiog per ofr At SuIyAIOAd Jnoge ysnl puv ‘ud dsat] ‘JJOSALU poyey Aj[BOI [| “SO1IOJ PIL STY Ul URL & O} SdtISap TeNxas UO 9}0p A]OJVUOTIOIJ JL O} J1rd PjO ISA UDOLNO] eB GULYSE Spddu pue S}UBM JO JS MoU AfodTAwoo B YM URUT AUI[VOM A]OUIDI]X JOYIOUR SEM SIU] “PUTUT siy ur juads [jam Aauowi jug SuIyjOU sem J “JNO O8 0} Apeal pue passaip JJOSAW 393 0} PAMOT[L SEM ] PUL PAXeLI[D OY aIOJoq BuO] ISP] },UPIP 1 A]popyuey_] “SuoisssArod paluawop sty OU! dav pue sdauy AW O} [J AJ ] "JYSIU Jse] JOOP OU} IV IU PIJddIG SY PUODSS SY) WIOI] JUDWIOW SI} SUIPROIP SEM | ING ‘9}qissod se yornb se YIM SUOP puk ISAO SII} 399 0] OP 0} pey | 7eUM MaUy TVILNACIINOS JEUIITY payoojolg WySwAdoy () Ort POOraALINIO EL ] ‘sdd] AW UddMI9q UL fO9f 0] SPIEMUMOP PaNUTJUOD puUR s]svdIq |]eWUS Aw poddno spuey ysnol ‘adiv] siy Udy] “Soqoyies pue yoou AW SUTAOT] ‘soAmno jnjyINoA Aut punole dn spuey siy suruunNs ‘aw pooseiquia 9H “usdo OpIM SULIv ‘UOTOOTIP AU! UL SAO 0} papsdoaid MOU JNq 99Bj STY UO YOO} AZBI]S B YM SUI SUTYSIVM [[S SEM OY “SW puke ABMIOOP dU] UsEMIEqG SULPUL)S UBL OU} JB POYOO] puL Jjo JJasAW POUp | “sJOW AUP JOLIIW Uy) Ul JJOSISY IZIUTOIOI UDAD 1, UPIP IVY} j41d JoInb e& 0} Ajteuosied Surosjno Aw wor ABMe SULAYS ‘9q 0} P3sn | OYM WO] Iv} OS BUT][LJ SEM J TOMO} Aut duiqqeis Ayyoinb pue sjooney aq} Jjo suru) 0} uoTjua}e Au pouin} pue pou juelydwoo e& Suippe sjrlus yornb e wiy saed pue.dn poxooy | | “sTy JO jeoy Pd]][B9-OS SIU} JOAO pd}loxs aq 0} posoddns sem | JI se ‘JY dTUO} JoYyIE90} Ayed pynom 3m pure s}jijjno qnjd owos Joy Surddoys atu aye} 0] Suiod sem oy ples aH “aeplopney] LJ Ul poumo oy jueinejsol pue qnjo suos jnoqe UO a[qUIeI WHY Jeoy APYSI[S pjnod | peoy AU J9AO UMOP BUTJVI9qQ 19]vM JU) uddMIJOG “UOY dl] BurppAue sem ay JI St Jey} ‘“souepoduu ou Jo sem Avs 0} pey | eum Muy | [fe Joye ‘Buryyey oy} ye Op uy jo] pue uny Je Suryoo] POPIOAR J JNM BUI} 3] JOpUN posIOWqns DUIPUR]s SU JO SUOIIBAIASqO dye} 0} ponuyuods pue do} Aj1ueA dy} JO apis ay] uO jes ysnf off IO} OF Sjiid SuNOA Jey} AQUOUL OY} WY SyVW J ,Up;NOM Jey) onpold posewep & u90q 9A p[NOM | Jeay ul ‘sAeMAUR DUIYJAUR pres dAvY },Up;NOM oY Jey) Jaye] SuIZ1jeay “OW JNoge s1JeYD pjo} pey oy os]9 JeyM BULISPUOM “SWeU S$ UOY JO UONUSU ay} Je UMOP poyooy] ysnf |] “pajuEM dy JaAdjzeyM YIM Suoye 08 0} Jdadx9 sty} JO No ABM OU Pky |] SUIMOUY dtu puL JOMOUS OU] Ul J[ISAW! OSUTI STU BUTQOIe AA ‘UIRLINS oY} pousdo oy se ,.pIes uoY Se [NJINIQ se aie A]]VdI NOA,, “991 BY} YBiq 0} ds1pAVYyS 1oJ Aem Asva UB SEM JJ TYSNoY} | ,jeordA],, “osea UM UL pay[eM dIpIJeyD usym Joop dY}] UO YOOUY & USAD JON “JOMOYS B dARY pu dn poues]d Jod 0} paploop 1 doajse [ys sem o1jJeys pownsse ysnf |] os Jaoinb sem asnoy sq] a Z taydey ‘pouaddey peq Ayjeoi SUItJAUR dIOJaq SadUe]SUUNIIID 9s9q) INO JJISALU 493 0} YISUdIJs 94} ALY P]noM | 1eYy) adoy StuOs JlSSAW AIS 0} pey isu! | ‘Mou [OUD AW Jo jno sem Uoddey 0} SUIOS sem IOARILYL AA “ABM JeY}] SUIOSTIUINII JO JNO JJISAW YOOYS | JYSNoY}) WeyI YAK “soe]d JSIIJ SY] Ul POSIX9 UDAD IOAN PRY JI] LY] YULY) O} [eauNs pouisas jt Aq OW surissed satu prey AURUU 00} YAK “MOU dU0d BUC] 00} 19M SALP dS04, | "USUI O} DARTS B SEM | DIOJaq pure ‘JjasAw 191Je YOO] O} pey ] a10jJag ‘A[Twey AU YIM S]YBI 34} Jo [je aloJag ‘uMOp apisdn pawn) aj1] AW [][@ S10JOq Oq 0} pasn pey JI MOY PSdSIUILIDI [ ‘pooypyiys Aw Jo syed 8r9 Jo OLGabed ‘OE€Z8Z9Z “6TOZ/60/80 ‘822 JUaWINDO ‘898Z-8T Based TVLINTOLINOO jeuaAryy pono) wysAdey [|

The text on this page is estimated to be only 41.62% accurate

GFT FOORRTLANID o1 sjuased AW payjeo ‘puay Alu ‘f° y “SYJUOUW INO] Se] ay} 10} ABME PAaMojs dU PRY UOY WoyM LPO] “VjpedQ Wo AVM YU} [[e PAMOT[o} Suloq sem ] }BY} atu pouloyuT Ady) pue asnoy S,oteYyD Je Sem | INO puNo] Ady} MOY yse 0} a[qe sem | “WiTY oO} Aeyd 0} pey | Wed | JeYM puke poyxlOM ssouIsnq S.UOY MOY S]Uade dy} Plo} puv UMOP Jes | SINOY Maj }XdU 94} JOAO _ “AMTTGRT] B yons Suiaqg 1oJ SAVMAUP OU {]}Y AOA] ISOW P,dY MOUY | USO} SUVS dy} ye yng pousaddey Ajyeas jVyM sjusse 3} PjO} | Jl Op pjnom uoy yeym JO PAIVOS OS SEM | “SYJUOW XIS SP] dy} 10J S]NoqesayM sus AU yNoge JU PAMAIAIOJUI SJUDTY [LIOPIy OY] a19yM UOHRIS sd1]Og AjuNOD piemolg 0} USALIP SEM PUR ILD dU] JO JeasyoeQ dy} OJUI poddiys | ‘poysnopuey PUB BUIWIBIIOS [JS BPOIoA sd1[Od B JO POOY Yj J9AO JUADq SBM J1[IVYD JO S_UOISIA se] AW pUe dSBOIIE]S SY] UMOP SW Pd] SJUase 9Y f ‘Olu YIM yeulnol pue “seq dnoyxew ‘JeaMmsspun AU SUIUIE]UOD OKs j[ews Surye) AjUG ‘sous pLuo0Y asay} Oo} Suisuojaq ArowsuI AIZAd AU puiyaq dava] 0} payuem | ‘UIeSe*-49A0 OfIT AW BUTLIeIS “ay sey AISA OY} JO} ISNOYUMO] S,d1]JeYD Jo Ino pay sem | S]]Iq Je][Op pospuny say Aw poy yey) StyouNIOS 9y} YM ung 149 e ut dn sey Aw Sung YO][S Jo sderos S41] SIOW SEM TI [Te IV BuTyjo]S Appsey ‘syseosq AW MOTAq IsNf [Jaz Wey) do} durysyew Aut) & pue ULYSIUIW on]q dI[]eJOW Be Sem YIM dn awloo pynos ] ISOq OU, “‘WiYys-} Be pue suval jo sted yeuuou e ayI] “JUddep Jey SuryjAue SUIARY JON ‘UO SoYIO[d sUIOS Ind 0} MIOOIYJLQ oY} 0} JI9SAA Pasnox | “OUI JO pesye Av] RUM JNOGe SNOAIU AIDA OSTR SBM INQ PdAdIOI sem | SAVM AULT OS UI PUR ‘ISAO MOU SBM SYJUOW XIS JSP] IY} JOJ 0} Patuojsndde 9UIOD pey } Jl] ay) MaUy | “Adpajmouyoe 0} Fuljso} ppo ue sem }] ‘OW BuO] B Ul pPaMmoys Uddq pRY | ADUddOP ISI] SY] “Passosp 193 pjNnoo | Os sjaays peq ayy yim dn paisao0o ured 0} ow SuIMOT]e Pog Jo no sw padjay pue purty AISA [je alam Ady) ING Wd) JO [][e 0} pouwdwOd [BUS OS Jfaj | Sjudde pouuojiun Aur os o19Mm a19u, “‘Sulusddey sem jeym dAdIjaq },Up[Noo pue UOISNJUOS [BJO] Ul SBA | ‘TuLABS SEM dY JeY] SEM I JVYM JNO 9yxVW ) ,UP[Nod ] INQ dW 4e PaTjad Surlaq syeasy] OW Iesy pynod | ,,jNOA pur [IM oyM MOUY NOA SuryyAue Aes nod J],, SVM [[SA WY psevsy | SUI] Ise] 94) pue SUIUIBAIOS SEM dT] SPIs]no AVM dT} Jo [Te ssunz sty Jo do} oy) Je Sururesos UII AaY Pjnods | ‘syoys Jo Jed & UY PUTF O} WOO dy} O} UI YoRG SWIOD 0} pey udde IayIOUY ‘passaip jos O} pnoye UdAd },USeM 3Y spnu A[9}9;dtUO9 [TS “WOO ay) Wo atpreYyD posseip Ady) se payoyem pure Apoqg poyeu Aw SuULIaAO9 syaays AW YIM pag ul dn yws | “WY pajyno pue 100]f 94} 0} WIY MOIY) Pue dIpPTBVYD poeqqeid Us dy} JO ddI} SAOLU O} YOOYS yon 00} ul‘, peay Nod uO spuey ANOA YIM UMOP 99 ple B SI STYI |G, PoNoYys YoR]q Ul UdLU dy} JO SUO UDdU} ING ‘00 SUOIM BUOP PRY dy PUudsTy SSOUISN B YUM I{QNO.1] JO PUY SWOS UI Ud9dq 9A, P[NOd atyIeYD IYsNoY} | Ajpides os Suruaddey sem yeym pudsyaid wos UdAd J ,UP[NOS | “}SI Je TWILNAGLINOD JELIOEY poyseIOIy IYBUAdOD GF SP POOMALANIO ST ZUIUDIYSLJ OS SEM J] “UO SJOTUDY pue sUND oBIR] pey Jead AseqIpIUM yoryq |@ Ul possorp udaw oY, “343H [IMs sem au uO dud sry pue 1941230) poq ul SUI] [JUS 19M | puk dI[IeYD “We XxIS JNOge 1e JOOP WooIpaq ay Ysnory) Busing ydriqe ue YIM SUTUIOUI ]X9U dy} Sted oNosaI Alu ‘sJaAvid Jaroas AUt 0} BUIUS}SI] IU STOYM 9} DJ9y} SBM [Osu ULIPIUNS Alu JI SY "Ulese UOY JOJ dn sty} pamaos | JI papesy SEM | S194 M SJVY} MAU J “SOYSIP [dO] SY} UL PUNOJ S[JI3 JO IST] 94} OF ppe 0} uosiad BuIssiw JayjOUR oq 1,Up[noM | Jvy) padeid ysnf ] {poos 10j JO pasodsip 9q 0} WIY OJUI SW SUIN) PUR SU SpUl} S]UBLLIOJUI payDoUUOS -OS-19A9 $,UOY JO 9uO0 plNomA {O03 | Pjnom osayM jnq ‘Suideosa jo sjysiu jo Auvtu jySnoy} | “osps uo ApjuRysuod Jnq “daajs ssajjsoi B JO jno-pue -Ul JJLIP pjnom pull poxIOM-I3A0 Aw Apjenjusay “daajs ssa] yonul ayyeasq A[psey Poo | payooypo os j[9J | Surpyus os sem oul uo dis sty jnq Aep JY] JO PUODSS UDATS AIDAD JL WLIY ULe}IOJUS 0} SARY O] YSNOUS peq SeM J] ‘sdd] pue SULIL Siy UddMJOq PoUIMpa}UI ApOog payeu AW YM daajs 0} JJO SuNpiup s10Jaq IDJUNOOUS {ENXIS JoLiq B dALY O} POY] SABMTE DY “O} PIBMIOJ YOO] 0} ult] Sununep & YA, “AWOY O38 0} Apeos SUM dYf ples spsVYD ‘sinoy Om} jnNoge JOIJe PUL SYULIP DIOW MOJ B BUIARY O[IYM & JOJ paouep aA “S}ysnoy} Suissed ynoqe SuisIaauod A][BUOIsedD_Q) “Sulouep sjdood suryoyem a]IyM B IOj es jsf 9M Udy) puL YIM L1e}S O} YULIP SOAR] SI aTom GOLyM ‘SB9] POO! PULISI-SUO| JULI OM} YIM Jeg SY} WO potinjal ot[TeyD “IoOp JUOIJ 9} 9SN OF SAVY 1, UPIP om ATHION] ‘UT SUTLUOD BuO] d[IW B psyxOoo] YoryM JOOP dy} INO aut] e OARY PIP qnjd ay] “‘punoie [je syuaurtjdwos JO ][DJ sem arpeYyD pue qnjd ay) Moe payloxa Os paulaas yOq Ady "SO]]OY INO ples pue pussy siy YM dn jow 9AM *,S,90f BURNTT,, pajjeo sem qnjo dy] ‘WYSIu yey) Sutusdo puess siy sem jI puke poyounr] ysnf pusiy SIY qhjd & 0} papeay om Jo}e’] “OUOTe YOUN J0J yno pue Aep yey} Burddoys JUOM 9A “1YSIU JayIO ASAD WOT] JUDIOFJIP OU SVM 1YSiu Ise] A “SU SS1Y 0} Al] UDAD JO WO}]0q Aut uo de} Aut e at Surars Aq AYs 00} JOU “10]4SneppuRIS sTY 3q 0} ysnoue 3unoAd 13 B IOAO podesp sue STY YUM SI[qnd UI 9q 0} [eUWLOU Sem IJ se ABME JeYD 0} ONUTUOD IsNf p,Asy | “Apueo ada JUDOSaTOpe JO Sd10Y49 SI] JB POPUdJJO poidds 0} SUT PSONpoOsUI oy USUI dq} JO auou “Youn oj sioupIed ssouIsng JO SpudLy sty GuUNIOW SouINatuOs ‘suIddoys sutos Op spue.lid sTY UTI puke UOOWOIJe-pIlU ssNOY dy) SAEZ] Plnom 3/4 “Avp 9} JO} s][ed ssauIsng s1y spew otpeYyD spiym dn-ayeu Aut uo ynd prnom | puke passoip pue poomoys jad dn ayeM 0} sem SuTNOI edIdA] INC "SuOISSNOJadal [2UONOWS 34} JO “presye 00} ‘Aiowstu AW JO Jno JoyNJ wy Surysnd snyy “sAeMAue ySII eB JO youu 00} SBM J] “UIRSR [| [{2d 0] SdUBYD SU] JOD UDAD IJSADU | “SpJBMUO JYSIU puodses 9y} Woy paq sly ul daajs aw Bulyeul udAd ‘apis sly sAva] 0} pnoye IDA0U “[]eO UOYIA S,dt[JBYD ye dq 0} payoodxa sem | SOM OM] }XOU BY L 879 $0 TLGabed ‘0€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVIINTCIINOOD yeudepy parsaqoag yyswAdos [:

The text on this page is estimated to be only 41.27% accurate

PT FOORELINIO : TVILLNACLINOO © Os TPOOMAANIO TVLINACTIINOO JeLiaryy polsjorg WYyBUAdoD GC [LUTE popooios,| WsUAdo? (3 8T 0} ABMP 1UdS SBM | Jl BY] peg] AW 0} Je9[9 A[SNOIAQO 1 Opeul puke s}Iq omy Aw gym ut jdeay] | premio} uosossns Joy JO sty ind pynoo suodue MOjog “o1J9y WO 0} OF P[Nom | sJ9YM Oj Po] SBM UOISSNOSIp }XOU 3Y J, ‘QJl] Ul UO J9}e] SOIPSSeI) INO j[Bjoq SUOISIDOp peq INO Wy} SPJOM YPM Ue} SABM JOYIO UI SulAes A[dutg “[eouesd UI a}dood pure ‘yom ‘sioujied Jo no jdad0v 0} Sul[[iMm o1e 9M JeYM SauIOINq UdY} JINN INO OJUI SosSauTsueI] HL Jl UDAD IJ1] INO UL SWINSUIOS JNO SaUO9 [JB Ji Aa}e] JO JOUOOS Suizipeod uy) Joye ued OY} YIM [kop Jou pue jodie dU} JopunN }1 YsNig JoyjyeI pjnom Ady} OI] UL UMOUY P,] SUOAIOAD OY] “OATe SBM y MOUY 07 Addey Isnf{ sem sy “Sury[e} dojs 0} Su Poyxse Sp1OM Ul 9OOYO 19}}J9q JO YOR] SIY JOJ pue SuLIKvOY sem oY JeYM AdI{Aq J ,UP[Nos peq AW ‘dAels xos Siy se our jdoy pure juowede sty 0} YOR ou YOO} 3 Udy ‘sIoyjo Auvw Suowe ‘mez odes A10jNIe]s SY] poye[OlA UOY pue Jour poSe-lapun ue SBM | SUIOQ ‘OU JOJ WTY [J9} 0} SAY pyNom Ady} Jo “]]9} 0] d0/0Y9 OU pey | pres Ady) OyM JoyIey Au 0} Aousnol Au 9]eI-d4 0} WOO! UOT}ESO.LIDJUI BY} OJUL YOR J9Y4}9B0} SN JO Y}OQ Po] SN spiseq Surpueys MOU S]UdSe OY] “UleSe sjudIed Au pajuloddesip pey | pes pur uiese BUNOA {99} OU opew jI Avs 0} SALY | pue Aep yey} yHuUN AIO peg Aw Mes JOA9U | ‘peRdy sty yooys jsnf oy puke 19AO YOO) OWeYs puke Josue pedjsul jnq SW pjoy Oo} no suue sty duljnd poyejdwojuos a} “aut JO SPISUT pay[ysul ay SPUNOM SUIAIZIOJUN pue JUdIUOPURGe OU} JOJ payey Mou jnq Appeg jJkO 0} pasn aduo | URL 3} O} ABS P]NOM | POM dy} Ul BYM sUIseUL } Up[Noo | saypuevy sueys 9y) Suiddiy “ury Jo 1YsIs oy} ye yeas Aw Jo jpop Ajzeou | ‘uonoomp Aw ul Sulyjem Joyjey Au 99s 0} punore unds ] USYM ITVYO SOLO STULS 9Y} Ul J[JASAW GUIpIIM) [[HS SM J Joe] SINOH € Joydey,y “UOIINIOS B Puly 0} ZuLAK isnt Jo peajsul 00} JLUpR Joye pjnom suoAue uey} sow yontu os suoddey nt pue ‘Jussouul Aue OS 1Oj 94¥J DIVUNJIOFUN PUL PRS Y ‘SOATOSUIOY) SUUTIOIA O]dood IoYyJO syxVU 0} UO O8 IO SOAT] ITDY] JO SOI OY} IOJ WIOIA V Sutog dojs J9Ad 0} DfQe },UoIe AJOIIOS Aq POZIUINIOIA UddQ SARY JY} S]IG sou! Joy AAJeUMIOJUN yng Aepo} Joy Joj sadoy jsoysty oy OARY ATUO ULD] “SOUBISTUMNOIIO OLIP-UN Sq} UT PUSLI plo 1eah sao} Aww ynd oj pey AT[eMUSAD Jey) Joyjowpueis dJulose JOY 0} pyiyo pjo Jeak Ino} Joy OARS pue YWLOp sTY Joye spremuMOPp poyesids 398194 JOIPpe SUIOIOY & SUIOg JOJO JOH “ApURISUT WY SULT{Ly “UTeIq SI YSNOIY] YSIVIs JO]]NG sy} YOO) sdueYd JO oye Aq pue SpudLY JoIppe SIy JO STUOS YIM daTNOY uLIssny Avid 0} poploop pue oryun! suloIsyYy B UD9q PRY OYM JOY J B pey “JOY JOSIOJ JOAOU I,J [IS pes AIOA 3UO ‘sovjd ysay Oy) Ul Woy) UNyY ATTentUs oym ajdoad 94} se soinqiye awes 94) Suneodos dn papus Ady) afi} aToyM Lt IID} JUIUVI] JO PULY SIU} O} ponpqns Sutaq 0} pasn Os dJOM S}IIS ay} JO JUIOS “JOoTSOU pue ddIOF BIQuUOSeoIUN Yons 0} pojoalqns aq 0} SARY plNnoys g[USANf B UDAD JO P]IYD ON ‘S}90Ns 9Y} UO yoeq dn popua shemye | AYM S$ JEU], “OW saves AdY) SOUOWIOW oY) pue sooetd oso) poyey | “TRUITUTIO JUDIOIA B OYI] Payeol} oJOM PUP LOI] B POJOPISUOS SBM WOO dT} Ul UOSIOd AIDAD “YOOM B SOUN] MI B OAL] 9q P[NOS SEM YOIYM ‘TYsy B SBM 9I9U} udyM ‘dJ9Y} SuOOq },UPIP Jey} [IIS Ays “Jonb & sIoM NOA {1 JOU 1, UPIP I] ‘TYSLpUNs ou ‘TTR Jo Js1OM puke soyoIeas-diqjs oy} Udy} pue Aesds soddad dU} SUED JNO Ud} SPIeI JUSTOIA YIM popes JUloq S]IIs YSNOI oy} UsEMJOq S}YBIJ JULJSUOD SOM OLU JOF 91O}S UI AB] MOUY | LYM ‘sooeyd osou} JO polevos Os oq 0} SU JOJ UOSeoI YsNf Jo Ajua]d sem JID], “P]O SIBvdA UdAdZTO Aq ,.a]puey 0} a]qQevun pue [O1}U0D JO 3NO SBM ]J,, pres J9yJOLW AU JEU) JOJIRJ I9OYS dy} 10} soov[d Jo puly 9soy) Ul 9DUDDSa[Ope AU Jo Jo] B Juads Jo 0} BUIARP “OUI JOJ 2103S Ul Av] Jey) SooEld [nJpeosp 9y} Jo UONedionUe [Njway Ul palopuod | ‘901440 3Y} USYJIM SUOIBSISAUOS SUIWULOI 94} 0} SULUDIS1] pue WOpPssog JO JNO BUI[IIM] SEM | IBY SULATOADI OY} Ul YoRQ BUIIS ‘IOVBUI STY} Ul 9d10Y9 OU pkey | Inq ‘OWOY [{ed Oo} ssovjd JO JSOOIU 9} ION ‘“ALI[IOBJ UMOPYIO] Poyesado 91kJS SUIOS O} YOR SW HP} 0} UOISIAIP syuanburap aylusAnf ay} wolf aUOSUIOS 9q P[NOM j1 paunsse ] 9q pjnom auoatwos Jey) OYM Jo UIBLSOUL) “dn ow yoid 0} aUOSLUOS IO} SUIJIEM SEM | S[IYM YSOP $F, 19d JO SY} JO uO 1v UIs O} PlO} pue GM ISAO SEM MOIAIOUT OY} JOYL WOO] UOTVGOLIOIUT SU} JO JNO UdyzR} SEM | “SUIR S d1[JeYD Wool OW ponosal pey yeu) sjusse |’ gq’ sues oy} Jo suo Aq JojR] SuvoA Auew yjeap pue yuourysiund sty Jo plo} sem | A[[eJUSproUlOD “99Ud} UNS AY]SUd] B JOF UOSTId Iv9ak Puoddas Siy BUIAIOS ISB PO JO Psip oY USYM SONUSASS-PILU SLY Ul SPM ay wiry yysnes [ gy oy) owl) au) Ag ‘sossouIsngq [esq]! pue s]eUITIIdaI]I Auew Suiuund pue ‘uonnjyysolid 10} uswoMmM SuTroros ‘ajiydopad B Zulsq JOJ aJqejuNosoe pyay ATjeuy sem ay “LWel 0} YOR pajlpes}xo puke BIARISOSNA Ul paysoLie WI sABY O} 9/qQe 49M ADY} UMOP LUTY YORI} 0} 912 SIOM [GT Oy) Ua ATTEMuUdAd ‘wy JsuTese dn nd sodseyo ssopjuNos AURU OS peYy UOY °O} UO MOU 3IOM SP9J SU] JY} 9[9]USI[O patusajsa STY JO UOHLZHOIOSIP 9Y} UONUSU 0} OU “JuotTYsTUNd [eda] proae 0} AUNOD ay} poposap A]aIVIPOWIUW! Pue JSOLIV $ SI[LJBYD INoge Ino puUlj 0} s[qe MOYSUOS SEM UOY “AID AIDAO UI SOAO JO Jed B BUIARY SYN] “9]qQNoN UI 91, NOA Udy oSeURApe Ue oq UBD NOA JO} SUTYIOM 9[dood poyool Aueul os SUIARH “SE ]Y] “WTY Yyo}eo pynos Aay) Ji ‘oun} Buoy] AIOA & JOJ ABM WWTY yNd 0} UOY UO YsnoUs pey | _ 4 ay} ‘djoy AW ynoyIA JO YIM ‘MOU MOU | “UOT OS JOJ sn Sulyoey) u3s0q pey Ady} Jey} YOOYS yons ul sem J ‘9090p JO JOR Bulwd sf] Jo sreMeuN Ajayajduiod “uonesiaauod AIDA9 BuIpsJOoaI pue soul] suoyd ayy Suiddey 319M [Gy Oy} ‘Udy 9OUIS JOA puke UONRSISAUOD QUOYM JsAIJ INO Joye 879 $0 c/Gabed ‘0€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD

The text on this page is estimated to be only 42.60% accurate

eS LFOORIATAID O¢ pue ‘111ys e ‘suvol Jo ted ev JjasAu Jysnog pue aryounsos Aww wor AouoW dy] 400} { *xd]duios Suiddoys Asnq e sem dojs Isiyy Aw Os ‘sjued 1ryeVyy PUL LITYS oNyq & YM voIe OY} Ul UONdUOsap AUI JO QUODTIOS JO} BUTAOO] aq pjnom sdoo au], “S8tJO[O asay] JO NO 493 ISAT 0} pey J ‘JOA QUOD ] ,USeEM ] MOU ] OS 91OJaq SOUT] AURUL SIU) SUOP pRY | “ddIJ YROIg SW BUTI] ays AW JO Je]JOS SY} Je 910} ySNf ay 3Nq SOs ]]e JO SyO] Apog OUI ow ind pjnom Ady} “a1ojoq Ud}103 pey | $,dU0 Poulel] I9YIO SY] JO SWOS 31} ‘9]33n.ys eB Jo yontu dn ynd use },uUpIp oy “Wiys Aut Aq out yysnes Aju yng SU Je INO paqqeisd sue SI} “J99QJUNJOA dy) Jsed poysnd pue ‘J{asAUL PyO} | 08 3M 313U,, ‘JI SBM SY} ‘JOOP AU YOTUN 0} Opis oy) PUNOIe awed oY pue dojs 8 0) payjnd seo oy] ‘oul pudTjaq 07 s}dui9yje snosouMy s1y SuoUsI ‘peaysul yoinb ydoy | Os ‘asuayjeys e ing BulyAUR Se UNIY 99S }.UP]NOd | 3Nq UOHPSIDAUOD JURSROTd SyeUL OF POL] UBT YSTURdS pow [feuis sy} “OAUIP d11JUD 9Y} WiY O} pIOM & pies },UpeY | pue JO] Surysed oy} Ul POA aM ‘SOURISLUNDIIO Siy} UL dU djoy 0} Surod duty) A[UO sy} sem pey | Ysus]s -JOUUT SU] “Vi Surop Ayyenjoe 0} dn poy yey) UONedionUe dy) 0} JUSIOJJIp Yo} purut AW ul yno pt Surdejg “Joy Wny Aue ow Aled },up]Nos sso] Awl jun Sutuuns Qjeydse oy} yy Udy} ‘papoou ji no Aem Aw 3[9311M pue did psouauadxaul $ 19d}UNJOA 94} YSNOIY) Sd1eq 0} sem URI AJA] *O]NOI SULAOO] SOQ JY} INO poynods | pue uNI Oo} sAeM Jo AjUsTd pey | 9 Pyo} synoqeaiayM AU ‘ddJO $10J}DOP 9y) 01 108 9AM “odedso AWW UI SIQRIOAR] aq pynom Aepo} syl] SUIPIOJ ‘uN IYSIIQ sy] OJUI Poy] puk WOO] sITe}I[OS d}IYM 9Y) WOT TYSNoIg sem | ‘OW JOT ABMe}OS JD9JJOd oY} SEM HI puke AVUNUIWUOS dy} WO] I99JUNJOA B 9q P]NOM JOALIP AJA] “SISATeUR OSROSIP pue Snip JOf Udy4e} SUN pue pooyq AW 39d OB 0} JUDS BUIOG SEM | ‘HI YOO} | UNI 0} MES | DOURYS ISA SUL +}, UPIp Jamey Au AjoyeuNJOJUN yng ules Ie ay} JO pud AW pyay | d[}qM APUWII}9 UR OI] POLUDOS O94 YOR SUIOg ‘JUBAIOSQO puke jaInb sulog ysnf “iay yim ABM SUIIY JO INO pode}s | Inq ‘OUI Jo 9dHOU Yon sxe} -], Upp sys aioyi usoq A[snoradid pey | UayM A[LAON “JUS}UI sNorotypew DOLL YIM S$ dUO I[LSPIY OY] OZIUOHEJUL O} JUBM S[IID SuOMs Oy] opeut ATU YIU AA “OSIOM UWIdY} JUDO] ATUO p,oYs ‘UMOP JIS Wd} Ja] 0} SQOS II9Y} YSnoiy} 194 posdsoq Ady) UdYM UDAD pUP ‘OY} ayeTTHUNY Apoijqnd pue dn way} puvis p,sys ‘sansst ised 10 JUuSUTeSIpold Joy} YIM adoo 0} ydnous SUO]S JOU 319M OYM S]IIS UO Buryoid ApjuK}suOD “seUNYsIu sulzuose ue Udy} AVIS WUD NOA SYLUE P, SYS “OAI] 1, UPIP sys Jey] SoJeuNIIOJUN dy} JO DUO dJoM NOA PIqioj-poyH pue nod ojey AT[ead JO NOA OyT] AT[B9I JOYS 0} posn sys pue UA[SAq potueu ‘psend apeuray ‘youtq-edou suo sem D194 | ‘op 01 gol e pey Ady) pue Wd}sAs 94) UI Joquinu J9yjoOUR Isnf sem | ‘aoRyd JSJLJ 9Y} Ul posed uaas ajdoad asauj Jo Aue Jr se pue , mou Aep Aue 9u03 aq pinom | usym juIOd sy] sem Jey M,, “OUT YM Yeads 0} ul JsIdOpoIsAyd eB jySnoig Ady) uayM udad a]doad asay} 0} uOTeUR]dxs’AuR PoMo | dT] [99] },UPIp | ‘OwUTBdI Sul[Up 1W9yy Ul aedionsed 07 SulpjiMuN pue AVUWWOJUOD 879 $0 ELGabed ‘O€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVILNSCRINOSD [euaep] prraoly pyFuAdoy ZCT POOMRLLANIO TVILINSCLINOO JCLINIeY payoojogg WYyTUAdey |: 61 I1dy) 0} SuIoalqgo 10} WOO! 9314 OY] UT SINOY pusds pyNnom | ‘sayorRes -diys jueseajdun Aw Suuinp punoy pey suo ou Jey) yseo AeMe poMmo}js AU YIM pay styounsos ey Aut pue ‘uuojtun sy) Jo pied se poptaoid SEM JEU} JO}VIMS ONT 4} SEM PeY [ WOJWIOS A[UO dU], ‘UO JIS O} Tey e& USAD 10 1910} OU ‘BULIOOT] 9}9IDUOD YIM UWLOOL seq B *,. UOOY SYA OYLL,, poyyeo Aoyl yey ul dn poyxso] sAep AU jo jsow Sutpusds Ayyroey siy} Ut Aq JUoM yoom Y ‘oduryo e JO; oJ1y AW SurAolus ATpeNjoe “poq s[qeuoyJWod B UI SIOYMOUIOS JJOSALW SUIDEU puke SARP 19}}0q JO SurlUvoIpAep oq prnom | ‘duridaojs 9q 0) posoddns pure paq ul je slam 3M USYM JYBIU PY “00} 9194) SIR} MOU JO JO] B MOU SEM aIOY} pug ysed ay] WO SpUdLJ [IIB Au JO AURUL OS ples , “yOeq SWOD ISOYS,, B O¥I] SEM J “Ulede JO! 0} Aytungioddo yyB1 oy) 10} Yoseas 0) UeBdq | DIOJOq YOM OY} pep AU 9AIS 0} 3u103 sem | ‘SABMAUL 0} SUOT]UDJUL OU peY | Ng “UIese UvI | OSBd UI dU Jynopuey O} pey Aayy Allows 94} 0} yORG ABM OY} UO Jed 9dI;Od Oy} U] | “OS HUINdo 00} YOO] 1, UPIp dy 3Nq “1 URW oY adoy A]UO pNod | ‘ow puNoTe 19}43) sue sty Suizoonbs pue peoy sty SUIPPON *,.9U0S W,| puke yeom-JUO,, WILY PopulUol pue ny JSe] 9UO WY OARS | ‘WOW UNI peY | Ailoes yse] Oy} O} YOR OUI DAL} 0} SIDOYJO 9Y) Id] By D10J9q pue ‘ul oAvs | “SuluUNI d90y JO} }da0xa ‘Op prnoo [ SulyJou 9q Pynom aJ9y} puke pojuUBM oY dJOYMAUR SUI pUds pjnod dy uRIpsIeNs [eso] Aw Sulog “od10y9 Ou peRyY | ‘UIese JOA nq ‘pIOM STY O} UY ppoy pue Joy J AW ysNI] PfNod | Ji onsun ]{Hs sem | yng ‘YIM [BSP P[NOd J Yoo Y JOOYSS 0} OF 0} puv Avjs 0} IU OJ soKTd Be Puls 0} Ai} 0] YOM kb UBY} JosUO] Aue Oye) JOU P[NOM sy yey} ssiULOId SIDOUIS B opew sy yng *AjpLOBF OY] OJUL YOVQ ot Ind 0} Jn sd10Y9 OU PRY oY pies pep AJA] ‘09 pjNOd | ds]d DIOYMOUIOS 9q 0} PeY dJOY] 1Nq £00} Jey) YIM SUIT SEM | SULOY JB YOR SUL ULM } ,UPIP oYS UdYM OS “}I JO [OI]UOS UT SBM SYS se Buoy sv joy sem IJt] AJAY ‘S}OONS Oy} UO BUIATT A[JUDOOI O} SW Pd] yey SI Yorum ‘pouosud ui pue suole o10y} Sut BULARD] Joy pulyoq SIOOp YOO] OWN 9BIL] oY} Ssoy7O 0} dn poLuNy puR opIsut stu poJoYsn sys ‘spsend AJOSNW Mj B pue sprvOgdijo Suipyoy suuoyiuN ul sfdoad yim surpjing ON] [{e} SI} OUI poyyeM 9M PKdISU] “UOTIIOJUL Ue JOJ 10]D0P-dA9 UB O} STI SUISULIG SEM SYS SUI PO} pue SUT 0} Por] AT[NJored Os JOA oYs Wopy ATU MARS | SUIT} ISL] OUT, “UO Je) JOU Inq ATO}R] SOUT] JO JO] Be JNOge postdins ud0q pRY | “AZVIO JOY SAOIP pue I[AjSOJI] JOY POUs]VoIY] UOSVII SUIOS JOF | “SOAT] IIDY} OJUT YOVQ dU BuUIBULIQ SuIsedTNs UdAd JOJ [Jay 9}fl] Sly SuLjzVu SEM OYS PUP SUIOY dUIOD 0} SW JULM } UPIP WIOPy AU ‘SMoU peq 9} SUI plo} puv spuey sty ul peay siy ind ay “wy 0} MOA Aut opeul | vay Qd10A AUI JO 9U0} SY} UL SSOUSNOLIAS DY} Pleay Puke 9UOS SBM | SUIT) 9Y) ul dn uMOIS pry | stead AURLU OU) MES dy OJI] ALU UT SUIT) ISILJ OY) OJ pu SUL JB POHOO] 3fj “SJO9I]S 9Y} UO SWI OU UI Pkap 9q Pjnos | MOoUy prnom DY [Je 10} pue dull] sty) poos 10} rvoddesip pjnom | ‘ulede ou 99s I9AoU pinom oy ‘urese Ysnay Aw padesog oy Ji pue AypIoey] UMOPYOO] Joyjoue

The text on this page is estimated to be only 41.83% accurate

f¢ POOR TSIAIO cc | Jf poyse Udy) ays ‘Burpeals so so1oyo Aw je ponsijul A][eo1 Sem OYs IPI [[etus Suryeu isnl azaMm aM ISI We SULAST[AG A[UQ “SUIpRal SeM | YOO st} Ul POJSd19]UT SIO SVM SYS 1Nq ,.{,OS-PUB-OS WO] [OPOU SNOMe} ay} JeT]} SEM IO LHOOI SAIPR] 3Y} S.d19YM YII,, ‘UOTIsoNb [e1ousd B sem JT potunsse [ ‘awl payoevoidde jussoe ysipsugq Jodoid eB ym ayods OYA SaT}IIY) 33R] JOY Ul UBLIOM SuLyxOo] A[DAO] Y “UNS LPLIO]Y oq) JO YJWUeM 9q] UL Syood AU peal pue uondacal s eds ay) Aq dprsino us p,[ Asnq 1, UdtaM | Ji OS “WOO 19490] Oy) ur A[auo] Ayasd 393 plnos ji pue Aepsony Joinb ve uo UOOUIAYe duO UI poling asou Alu pey | Jey] SyOog AWO}VUR dSOU] JO 9UO SRM J} ‘ysideiayi B IWWOdAaq 0} PAUIWIO]Op SEM [| (pojsaiajur ysif uey) d10WW SBM | “adeSseLU 0} popuodsal Apoqg oy) AVM dy) dW O} Surzewe sem J} “Yonoy Sureoy ospdutis @ yYsnosy) 19}}9q 9} JO} yyeay pue Sulaqg-[jam $_uosiad B yoajye uBd NOA MOY pue Apog URLUNY 34) jo AWojeuR 3y) INOgGe SOO AUBL PSIPNJs | “S19Y] JUEPUDJY WIOOI-19490] B SBM | A[UO ‘MOU JO} PayxIOM | BUO dy} SyI] VdS SNOLINXxN] B OJUT AEM AU SUDYIOM puke ‘Jsidessy] ISeSseU & DUIWIODENq UO 13S MOU SEM SNdOo} AJA] “SSIAIS JSOWIGN 3) YIM PdIBI]] SEM 3][dJUdT[O AIOAD puke YoeRd ABM 9) Ul jNq ajAjJS Ul SUIZOO A[UO JOU “SSBID P]IOM SVM PdyxJOM | d0yM eds oy] “SUMOOL]LG INdpuRIG dy) PUR SBuULIS9 Payole plos dy} Je oMe IJOOYS ul Sem [| , yorog weg Jo jamoy,, 34} Se UMOUY $1 JI SNOWRJ puke Yo oy] 10J qnyo Yoroq & OUT Opel UOIsSUBLU B pUe ‘sUdpies poInoruRUT ‘sadeospury [eotdoy jo sare ysny Aq popunouns ‘yorog weg UI qnyjo AUNOS dATSNIOXx9 sdumniy, pjeuog ‘ode ]-y-seyy ye peq Aw yum gol 1swumns vB 409 pue C'a'D Jo ewojdip uoneonps jeisuad Aut s1imboe 0} JOOYDS OF 0} Poploep | "49B1) JYUSLI 34} UO dU Jad pue dn SLU ysOOg O} papsouU pey | Jey} Bd) Jo dno joRxd ay) SBM I PUB IBA 7eY) Udd}JIJ PousN) | “OwWOoY 103 ISI | UY SEM JI [RULIOU MOY dLILZIQ SBM J] “194}950} yor sooId A[MOJS 0} uvddq JJI] PUB IOUIO YORS YIM SdItjJ-uog puke Ss. OGY pey om, ‘ulese Apiwey AU YIM BUIdQ PIAOC] | “BUIYJOU ULY} 19}}9q SBM SIU} JSedT] 7e Ng JOOP 1xdU Sd0¢ IBVIDAR 9} 9 0} DUIOS IOASU 919M IAQ “ST AT[VOI OW] SNOIOdId MOY SZT[L91 0} IOBUO] USAD SUI YOO) I pue susyjJo1qg AW YIM JNO Sulsuvy jsnf jSo] pey | SUIT SY) possi pey | out) yont Moy Aq pousppes SBM puP UIVse AIO 0} payleys | ‘WYsH OS ow posdny pue Joop yoeq oy} YSNo1y) ueI IOYyIOIg 3]IT AJAY “SBOT Je OUTOY ALIS O} STU Poyse sys Inq 19A0 193 0] JOSue Jo jO] B pey [[NS 9ys pue synoqeos9yM Au JO YORU MOUY 0} JUCM J] UPIP 3YS “SoAl] INO PoJdd]Je ISITE SORYD 9Y] SOUIS SUIT) ISILJ SY] 1OJ SSUL[IdJF INO POJVPIOSUOS puR S1vd} INO YSNOIY) JUSWUSSEI puk Yysindue Ino Aeme paysem am pue Ald 0} poyreis Ylog om ApoeIPSWIW] ‘pueisIopuNn p[nos sys A]TUO Je) SSOUP]OS-dUO]S IVI[IWILJ B YIM YOO] J9y poyoyeu [ Inq ‘Sunjs des ay] “d0vyz 3} Ul prey ai paddeys Ajpjoo sys poneYy Joy ul Sulpjeo] Sada Joy pajuinbs pue yeas Joy wor dn pooys syg “is9q B SULABY Puke Sd}]91V919 TULYOUIS YOeQINO J3dY PULJ SUID OF SLU IO} POEM TVILNSCHNOO jCLIoIwAy poyoajo1g WsuAdo? [5 Ps POORRLTINIO Le SYS peajsul ‘ON “paylunsl suldsjjo sO] BUC] Joy YI] JOOP JOA ay} 10 31W3 SY} JB SW JOO}, UPIP WO AU BSINOS JE “SOYJO dy} MOU SBM }1 pue PoAOWdl d19M paq puL ssUISUO[Aq PO AU “SIOUIAUB WOO] B dARY UdAd } UPIP | “asnoy oy} paykaoual pue poysiuInyos sjusied AJAY “JUSIOTJIP pdxOo] BUIYJAIOAS PUL STN] SUC] B UT SLUT] ISITJ OY} JOJ ssnoy Att Je poate | ‘Joyjow Aw JUOIZUOS 0] SUIOY Sl 9A} ue SOU IOJ ISI} Btu ynd 0} poploap sy sJoYy]ey AW se jnq pueqsny Joy se ul wy Ind sy] uoTsod JeyM Surmouy ‘uoytsodoid Aw JB PoAOLIao }, USVM SH “Pood 10} uUMO At UO puk dA9 UR JO YUITG BURY) Jayoinb Aem AU UO dq [[IM | PUOddS 9UO IO} P9Ud}BIIY} I9J ] Ji nq “wd B IDAO UI SUIT} JSITJ OY} 1OF IOY YWM yeods pynods | Os ssnoy dy) 0} dU BULIG pue dn dur yoid sWOd 0} WIY PO} | “Joly snep poo]q puke ysalJ UMO Jay Jo SPddU dy} BOJOq s]UBM UMO JOY Ind O} Ay[IGe Jay Je poseIINO OS SBM | * 9Y) JO NO NOA jas 0} sioded dt} UBIS 0} JOOP] INOA BOUIAUODS 0} SUIAN) ysl sem | ‘ode INOA SiasBUdI] 103 sey OyM UOSIod Pood v s,ays “YWM Avys 0} APoqouos NOA punoy] | ‘sABP MJ B UT INO NOA Buyjesd sem J, SUI PO} 9y puv Aes O} SUIAI] SBM BY yeYM 0} Ud}SI] 0} poddojs | “poos 10} Jo1Yysnep sry yso} Jsnf oy ‘Mou Addey SI oy odoy | pure oul 0} astwiold siy Sulyesiq JO} WY YURY) AT[BOI|seoIeS 0} pouem | ‘pud JoYyJO dy) UO dUT ABSY 0} postiduns A[sjatdwuios paromsue ped Awl ‘syuoied Aul [jeo 0] suoydAed & asn 0} sem J9}U99 Suiddoys oy} SuIARd] a10J39q doys yse] AJA “JUOM | S19YM [NJoIed oq 0} pey | MOUY | Os ‘ol JO} Suryoivas ajdoad fo 30] & SALY P[NOM | ‘urese AeMeUNI v SEM | PSTJLIOU BULDG SOONG SY} MOU PUR ‘dU JOJ INOYOO] 94} UO s}NOdS S,UOY YUM ‘MOU O89 | P[NOM s19YM NQ ISP] Jv 9dIj “UILS ISAO [[B SNOA,eIap SEM 1] “sqof J1dy} SuLop ysnf s19M Ady} “TOYO Wy) SpIeMO} JduI9}U0d OU Pjsy | pure JUaprlout sAlsojdxe aulos Joye Ysne] v savy O} presye you ‘skns s01u AyaId Ayjenjoe oom Ady} ‘Ore}IJOS Ul SARS ow SUIP[OY pue sw DULUIeTSOI } UoaM Ady} Ud AA ‘OJ ATMS SIY WOT JYSIOY poppe oy} sem 419) pue YOou Siy JO INO Zuls[nq soposnwi payoalur prosays siy yyM jt OJ dn apeut jNq pling Jay[eus B pey 309g Ans jse] OY], “AdpIeY eB pauMo AyayTUITOp OYM SUOSOS dT] PoYOo] oy pur ‘oyorjsnul & pue [tejAuod vB YM UPL SIq JOyJOUR SBM UYOS “JOyoeQoul] SAISUSJop ..S UTYd[OG MWweRITA,, B IO} P2|QNOp 9A pynos oyM uRUT You]|q ddI1e] e “WIG SBM sIDY I], ‘Woy) Aq WOOI O}UIYM dU} 0} UMOP passeip Sulog au AW JO Jo] eB JUads | se ‘][9M [BIJ Spreng dy} MOUY 0} 10d | “JOSOp 0} souRYd }xoU AU MeS | [UN AIe}I[OS OJUL Passo} Udy} ‘dZIS AU SOUT) -INOJ USUI |NYSOIOF Aq YO] [NJUIed swos OUI pousjsey puv podvlds soddad Suraq Joye ssrejje JO sJe]s [eINIG B Ul SuIpUs soUjoOS o[8Sr.Ys Jdnige uv YM URS9q [[e SUOTSINOX9 Jsed APA] “QUII] SLY) ASeo OS 9q 0} HI BuNOddxa },usemM | ING AUI[IORJ BY} JO NO Burnes jNoge s}qnop sey },UPIP | “SaJJoo Jo dno vB puke JnuYsNOp psdi ayejosoy9 B Jad 0} s]nUysNog uryuNcC sem do}s }xdU AW pue dSINSSIP JO] J9]BOMS B 879 $0 pLGabed ‘0€Z8z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD TWILINATIINOD JELOUAR poqosjou,] FYFUAdOD [J

The text on this page is estimated to be only 41.28% accurate

LETPOOMRLTANMD v2 uo dn y3sry uono] Jo qoyq Be daoy 0} du plo} pue dy eB st OARD SYS ‘poxeyjol BUIdg UO UONLIUIDUOD OSOj UTY SACU },UPIP II OS ‘UOTO] dIOUL BUTE Udy UdAd ‘AdIJo¢ UO puey suo doayx SABM]L 0} SU PlO} SUB{STYH J9}1NqG Apog YoU Ul Wdy} pasoye] Us ‘Apog poyeu $,Alajjar YOOYS JOU pjnom SSOUP[OS 3Y} OS JNJVM ULEM UVM Spuey AU PsyseM PUe JINS PIMOT[OJ | “Ony} JWOD SWIRdIP ALU OHBUI Al[BaI pynos siqy oy1] gol ve ‘[njodoy AIDA sem J *,I JO} [aM pred Burjjo3 pure ppioM sy] BULSes ‘osnasseJA] SUT{JOABI] S,AdIJJoL JUOIAq PJNOM J] SqARL UdY} JYBIUO} pOOs PIP | JI ‘Ppws] 1OBXd JOY MOT[OJ pure Joy WO UOSSI] B SB Sty} }BdI1,, OJ URYSIYH Aq poddoid seM | “9A “Jo JU9M S]jOq WIE]R OU ‘SzISIA eds puk SaSeSSEW IO} PSBU IIOY) SB YI[eayY Joy} Jo snorosuos puke ojdoed asiu Alaa 39q 0} poseodde surysiyy pue wiy qog ‘JO SLMAQ 0} DUODLUOS 941} YOO] JOU PIP URW SIY] “oSvd ye ow duTyNd AJIDAD]O SPOIMSUB JY , SONIPLUWIOJ JO} pou ON,, ‘Adajor UY [[eo snl 0} paljdai pue , dinseald sity sem 1],, ‘POULIYyje OH “SUIYJOWOS JO SWeU SITY dZ1USOdAI1 0} pasoddns | ji sev ‘wy 10} poounouod ays se ulsysdy Aaiyjor SEM O}j ‘]RAOIdde sIy JO UONOU SNOLAQO Ue ‘QURISIYD O} o]IWUS B OARS pue J9AO StU payxoo] ay ‘uUOLIsod spreMUMOP Sly WO Je dn BuryooT] ‘souRjuienboe siy ayxeul 0} popossoid | pue 19yJO ydeVd 0} sn psonpoljul SURISIYD WS] 3q 0} SULOS SEM SIU] Poyeay-ajoyM SAaljoq 0} SunUEM ‘satuayos aqissod jo s}ysnoy) Aw Aeme paysnig Apyxotnb | Os asojeq auop IOAOU pey | SUIYJOUIOS sem BSeSsRA] ‘J[OSAW plo} | ,,‘STU) Jo] posedoid 9q 0} pey J,, “J JO 1ojUdO dU) Ul d[qQR} aBesseuI sstonbn) ay} Jo doje UMOP d9Rj SUIAL] URL POYLU dy) SBM WOO S14} INOGE PleMAME YOrI}s yey) Suiy) AjUO oY], “JOSO]D B 9q JSNUL PouINsse | YSIYM ‘IOOP Poso]o [TBs B puke suoIO] pue ‘sdeos ‘s}UdLUJUTO ‘s]I0 JO ABI UB YIM WOOI dy] JO IYBL SY] O} UISR B JDAO JOMIUI aBIE] B SEM DY] “WOO! pojadivs ALiaqing ay] JO Ud AIDA OY} JE LOO] WRdS poyVWO]Ne-Jfos puke J9MOYs Posojoua ssej3 B pur s]jeM a]qieu pey jt ‘S.eds $.03e]-B-1e|, pPouUMOUdI 3U] 0} 1 poseduos Ajoyiuiyap 9a pynoo | Ainxny ui Surddiug “wiool ssesseul & OUT SN po] YoY “pag ay} punole wIn}-—F) B Pip 9M ‘WOOL JO s[/PpIW sy) UI Poq dZIG BUry aU} 998 [[VS p[nod | Ng WTOOIP) SY} UT POUWIp sJ9M S}YsT] dU] “Opis puUeY ISU OY} O} SU Psl SYS PUL SSBdITEIS dy} JO PUD OY} Jv HOF @ SEM SID] “UOTRSIOAUOS d]dtIIs ayeUT 0} SurAy] jsnf sAemye se Aseod ASW9 SBM }I JOY PlO} | puke sem y10M je Aep AU MOY SW poyse sue[sIyH “O[TWIS JIDY) SuVIM A[UO SIM S]ILS SSO] JO SLUOS JBY} 9d1JOU UDA }, UPIp | Tuay) Je YAMS 0} JOU SUTA “UdMIOM [LYTNED pue spits BuNOA Buikejdsip sojoyd jo spn e BurAejdsip soyqe} [Jey uspoom AyIsua] ajdnoo & pue ‘Jorjapueys jejsAso puss e Aq Surssed ‘woos odessewl oY} 0} uO panunuos sA4 ‘UOTHSOd usdo sy) JOJ AMR MOYs BUIAT “991 SB [OOD Jourswop pue sArasor Aw yddy [ “ MOYS 1,UPIp | 1Ng ‘snOAIAU OS SBM | “SuIeys dy} dn suR]sSIyH MOT]JOJ 0} URSSq PUR pep AUT O} Aq PIES J Jey) YIM os ‘yeatue Au Surjiem pure sireysdn sem ssoq ay] pres sys “Apjueseajd JoA9 TVILNACIANOD (PUojeY poyoojo1y JYTUAdOD GJ 9$T POOTAAANIO oc OS pIp ays yoy ‘pep Aur 0} 9Aq-poos Aes puke UONLSIOAUOD aU} PUD O} {{9] P[noo noA ‘ALINY UL SBM SYS “PpoyYIOM om dI9YM OF"]-L-IEJA JNOgGe pue JOj paxJOmM sys WOYM jnoqge Ajjauq axods Ady], “‘Syaayo oy} UO YO SN possiy pue ou SUISULIG 10} WY poxURY) puke puey Siayjel AU yOoYs 9YS “MOU JO} ‘jueSayjo pue sodoid Aron SuiwWses Mey yoR]q Woys Joy “ojlwus UUeM B UJIM poxyeM oYS SIIe]s dy}. UMOK] “SYM OYs puk “‘puodsss Aue ABM JOY UO 3q PJNOM |[OMXBIA ‘STA SB AIUD OY} UL RM O} SN BUrTId} | Pue ayy AW JOJ SIOOP Sy} pousdo oy Puke [LL] SdeSseU B IO} [[OMXPIA] “SJA| JOU 0} dJ9Y SEM J UNITY pO} | “WIOJIUN JOTIN [eNsed v UI passoip URWOTUAS JOpjo ue Aq pajoas3 s19M 3M 19}k] SJUSWIOPY “SWIYD JOOP dy} But | pue JOOP JUOL ST]} 0} OU POHTEM IT] “}SOq Oy) OWI PoysTM pue ozsonbs Jiq e OU SARS OF] YON] SUL YSIM 0} pep AW payse pue soULYO sIy} JNoge payioxo OS SEM | ‘SIOOP USpoOM AAvay YM UOTsuRLU yUId odIe] Be dUTUOYIA ABMOALIP LIOYS & OUT paT[nd aq “TRISODIOJUT YOvog Weg sy} uo . “ABA OIG [q,, JO W0}}0q OY) 0} UMOP LU oAOIp pep AW ‘urd SATy punole iy | p taydey "JUR]ISOY aq 0] UOSBdI AUB MES SN JO Joypou ‘Jamns01d & URY) J9YyyeI JOINJINU & JO SIOUI SB JJO SUBS OYM STLIY] 912] Joy ul Ape] & SEM jI JL) SuUISag “AdesOY) aSesseUl UI UONe]Ipss90V Au 393 03 Aytunqioddo [njzopuom vB 9q ppNod siqj IYSsNoY) 0g IAA “SMOU SY} JO WIY Plo} pue SUDIOM SVM pep AU dJOYM S}INOD STUUD} BY} 0} JOAO POYsN | “YAOM JOY JOAO OWOD O} 9[qQe WE | JI Joy [[Bd [fIM ] Joy plo} pue ssouppe osnoy 9y} pue Joquinu auoyd Joy poydoooe | *yOOq AUI UI SUOTIDES SNOLIBA ay) JO Jno Bulddod sajou AXIS oY} WO pasoyjed aYS ples oYgs }BY) JoUIRa] O1yseIsNYjUS ue 4 nd Ys se puk OJ SuLyOO} SEM oy JeYM JO} eJoNb ay} yy pue euOosIad A1d9y9 B pRY | 1YsNOY) ouejsIyH ‘AYSNPUl dy) Ul SUTUTeI] 1S9q DY) OUI 1993 P[NOA oy YSnoUs ow poy] dy Jl WU) Burdes souajodwuosut jo Jeay At Aq [[¥ 1@ POLWOM Ul9as },UpIp SYS “MOTAIOUI Ue Jdulo}}e UdAd 0} YSnoUd [fom Apog sy] MOUY },UpIp ] 40Y pjo} ‘pnoy yno Suryqury} ‘uortsodoid js1f Joy pourpsap | ‘Wi1Yy 0} ow ONPOIJUT 0} POJOJJO OYS ‘ois UW] “vay JOY JO ssaupUry JOY JO yno psop poos ev atu Sulop ysng jsidesoy) osesseW v JOJ BUTYOOT seM oy Jey) puey -JJO MOUX SYS pue JOJ p9yxIOM ys Jey) ANS YOU SITY) noe j1q B WYd 0} UO JDM pue vo} eB pajdasoR oS “yIOM JB SOTINP pojonsjsur AWW 919M BSO0q} SB ‘OSRIDAD JOY JO pjoo B JdY posojjo pue yys Aw uo sejoweu Au 0} Sunuiod euuay si oweu AW JOY Plo} | “[JomxXePY Loqoy ‘Uo00dA} Jodedsmou peoeissip pue ueUISsoUIsNg JUOUIWIOId 9}R] OY) JO JoIYBNep ay) seM ays yEY} NO PULZ JO] P[NOM | “][OMXBJAY OURISTYH Se Jjasioy poonposjul dYyg ‘Adesay) adessew soyoevid 0} dao] pynom | Aep suo jnq Apnjs 0) uesoq JOA JOU pey puke YOO oy} Surpeos A[UO sem | pajeys | “Opis oy} UO aBesseu pip 8179 $0 G/Gabed ‘0€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TWILNACIINOD JEUDICIAY psysojo4 YBUAdOD []

The text on this page is estimated to be only 41.95% accurate

6ST FOORRLLINIO TVILNYCRHINOD 8ST POO LINIO “TVELNACLINOS JELaILY posajo1g jySuAdoD [CLUINCY posapod | YysuAdoy Fy 9c pey | SSOTOYD dy} OF UMOP dUIed ][e I SUIPULISJOpUN 9A JOU “UI Poaq] | PLOM ydts 94} WO AVM SULUUNI OU SEM JIS) SUL SUIOULAUOD SUOYOILJUI I1dy} poyeodal A]UO WY) YIM ooUdTIedxe YWoOYs AW UI poiajUNOsUS pey | Ud oY] ‘OUTIU SuTIOUTI Io] Spoou pue sJUeA ALO) ATUO 0} ponpqns A[o1a]d woo oq pynom | 9ZIs Ul AUT) OS 1ND SBM | [HUN spoYs 0} J]9S-JOUUL Au donpal YySusTs pue Jomod YIM $,dUo oy} BUIN] SARM]Y *[O1]UOD Jo asuas Aul payoajje yey st asoddns | uo ose Apivs ue WOIY J[OSAUWI UI Joraq dU} UDAIS JON “Bulddoo dn papus | ssnqe sy} Jo [fe Noy dFI] YSNOIY) Jo3 oul podjay oA pynom UTY UI YoTyM ‘poasasop | 13dsol oY} J[osAW BuIAIS pue dn Suipuris Jo peojsul poyueM ys JO oy ABM IJOADJLYM UL Sul osn pur sas WiOIy AWIOYINE JO IaMOd 9} DAL] OS[9 BUOAIAD 39] | ‘yusuUTOddesip JO [JNJ SBM JL “YW SIy} UO SW) WOYS AW Ul powes] pey | yeyM S.JeY} IN “Jno UN} OF MalAIO]UT AU poyoadxa | MOY JOU ATa}ULOp sem SIq} SB ‘JYBiu Jey) Burw0s day sosudins oy], “Sty} MOU yng puRYysJOJaq WOIJ SBLSSLUI PION] [1 94} JINpua 0} FulAey Ysnous Sulp}}I]JOq JI },UseM “aso SUODULOS JO JJO SIU} YSE P[NOM BUOSULOS PoISpfIMoq SBM | “]]aM Se dyes SIY OJUI JOUOIIPUOD pue OOdUILYsS ay} adesseW 0} pey J 9194) dojs },UPIp I ‘90 0} do} wiosy Apo sly Ysem 0} OUI pdyse pue deos Jo Ieq be ou popueY dy 0} SuIOS sem oy JYSNOY) | 941] “wWRINS WuRM 94) JopuN wry Urol oO} su BUYS JO PRIJSU “SOUDIOJJIP SINJes9dwW9} oY} WoL] Pjoo puke payeu poo}s ] SB 10}BM dU} YBIUWIAapUN poo}s pu spleMjno de} pousny of] “SEM JOMOYS 24} DJOYM SN SPIsoq JOOP Sse[s 1XOU OY) 0} JUSM OM BUNS 94) IOV ‘yod s aayors} oy} ‘[Idnd sry se possowo | pure 10}UdU ATU SLURIAG dH ‘,.SUOSSA],, P3[]Bd-Os SsIy YSNosY] pue sjuNodIe YURQ ID} UL SUOI [IG AJUO YJIM 9]9}UDI]9 JOJ JOSIAPR [BloURUTJ a}I[9 Ue 0} JOSssajoid sselo-d]ppilu B Bulag WIJ SUOTT[IG JO SIIdUIS UB JfasuIY opeUl ay MOY JO AlO}S SIY SW SUIJaL “YsNoyY uvw uss yJOIUI pue JBAd1[9 AIBA B IHL] PAPUNOS 3]] WY} O41] 0] paulsas ay ‘1aYyORd) AW 9WIOSS UWLY 19] | ‘O89 SIy BuLulejsaJUa ‘SUOSSD] SIY O} PoUdj}sl] | sdVy Sutuing Aut SuNseyq SEM LEBSIS JU] PUR ‘SULXO} SAIPOQ INO JNO SUBIMS 919M 9M STI AA ‘pojuvm a]doad osoy} }eyM ATIOBXS OUOP PRY | Joye MOU JOMO} OU} UT SUIMOIY} Ul JUTOd ay} 9q pynom jyeyM ‘Apealye Jey 00} sUOS peY J pomnsy | ‘yids Atu Suipeisap ssousnonusyjold sty JO 13}}eW 3y] JO JORJ OY] SULIOUTI ‘Wi Jo ATOISTY OY] puw eUNRS v JO S]TJ9USBq YIesY OY) INoge UO s[quUeI WTY O} poualsi | ‘poydoooe puv jeuuou [je sem HI 3x1] ‘pousddey ysnf yeym jnoge p1oM & SUIARS JOU UIST} QIU pue Ja9F STY QeIT 0} OU Poyse oF] ‘possoip jos 08 0} WOOL dy) Yd] DURISIYH se ‘pajuenbe sayyNy 303 0} Aosyor ysnf YIM WUOOI UIL3}S SY} OJUL UIHR] SBM | “YIM ISAO PUR OUOP [[e SBM HI UO AA "au ayesjouad plod oY OS LUIY Sul[pppess “Aoijjor uo payexy oq 0} 9[quI1 941 UO dn Zurquuys Aq UOISSOS BSRSSEU SY} SPN[IUOD O} DUI P9JOoIIP A[UO dURISIYD ‘pesysul ‘ou ‘dojs 0} pojyueM | Jl JO O]qeIOJULOD SEM | FI yse 0} poddojs sana Apogon *,,mou [QUN Joy dn paured usaq | SAeY Jey, Se ‘WyBnou) | []e Joye ,.oW JO} $}O5 JL se poosd se oq Ajqeqoid pynom siyj pue [je ye SuryyAue YOM 9q ISAd 0} FUIOS },USEM ]J,, J[aSAW PfO} | YOryM “siBdy AU pUIYdq Ply | PYdjSUT OS S{pUueY A][EUOTOLUS 0} SU JOF YoNTU 00} TTP SEM JI SUT YUIS A}]BOI OY} JO[ UOAD } UPRY | “MOTQ SUIPeASOp [eITUT ot) Woy YOOUS Ul []NS sem | “S3O] AU UddMJ9q SPO] S}LOTTSpP oY} SUI|pUoJ ARIS pueL sonued AW SAO 0} SUT} SII] UTeSe OW PUIYsq poaow sys “AjsuIZTTeyUe} Apog sly Suoje sjseoq Joy poqqnd oys oprym Aq[eso AJoyJor UO UMOp O38 0} oul poydwioid usy) ‘way Jo Tog posnseayd Ayusioyyns pey | Joye pue sajddiu siy Suryory Aq je]s 0} SUI pojonsjsul oYs “Wepew Aul se SUNY ‘Jay 3ne] Sty Ul powof oueysiyy pure ‘pres Aodyor ,.S anyued [1s 9y1}1] SIVOM [IS SYS 91ND MOF ,, NOP J9Y}O YOR 0} PolOYsiUS udAa Ady] “YINOA juosedde Aul Jo so1J0u aye} YIOG pynoo Ady os ‘sonued edy-sAo] Aur UO Buidsoy JUSUIOUT B OJ ‘ased IpIM sdoj AW UMOp LIDS AW pls ayg “WOsTUN Zuiulewios Awl Jo aooid [euly Oy} SUIAOUIOI “WTYS 93tYM 9])11] AU O} UMOP PoAOUL SpULY JOY IXON JJYS pue poo woy) suryew onsuoj 4oy YM Woy) Suises) pue Zuryor ‘soyddiu Aw ssosoe sdy Jay paaow ays spuey 19y ul way) Suiddng ‘swosog Au Sulpeoaol ‘vig AW poaowias puke ossnoyq Aw pauoynqun sys “sn Surpoyem JIM pooyueW Sly dYO.S 0} popieys Aodpjor [IA “OU SSOIPUN ATMOS 0} URTOQ oYs A]NSseYy ButAjdos Jo yUIY) USA 0] souRYd B peY | WOJOg “poyseosq oueq oi pulYysq poojs Mou Ajsulsiidins OUM “SURISIYD JO JJO SUOTIOOIIP 1XOU SY) MOT[OJ 0} SUINTEM JI DIOS! 0} pols} | ‘UOT}OOIO Ue YIM Jjeswury JUasotd 0} osva djoTdtUO9 sIYy ye poxooys A]Qiposoul sem J NG pooyuew siy Jo ssuvsivadde 9y) ye poyooys },UseM ] OS ‘stud siy SUI MOYS 0} URTU ISIT] OY} 1,USeM OH “JOS opnu ajojdwuos SI aSOdxd 0} OPIS JUOIJ SIY OJUO JOAO paTfOI puke _S]IIs AyysNeu oI] ‘WO SJL, ‘petdes uy} oy ,soovejd Buoim ay} ul sAemye jsnf ‘113 poos B Ayjead tu. f ‘JOU UI_| OU, PolOMSuUR | ‘OATSUSJOp J[eY pue [nyAeyd jyey pue ‘SIy JO o[IWS AIM yey} YY , Jars-AyySNe,, Bow poyjed Aodjor “duryyAue Jl pourey19jus Joyies ‘sjuswaqeys Au Aq je 18 pajjedde wiaes },UpIp Aayy sem Bury) Auunj ay | “Ajsouoy posamsue jods ay] uo jnd Suleg yorym ‘suonsonb oso yim atu paqoid Ayuo Ady] sduUaJsTx9 ;eUUOU B JO YONW pe] 1,upey | ie) Jno punoy Ao) UoyAA “dJ1] SuNOA Aww Jo soouatiadxa IOAJEP SY] UMOP Poy UOTRSIZAUOD dy} 910J3q TUO] Oy¥) }, UPTp 11 puv ysed Aud jnoqge suorsanb Jo syos [je ow Furyse ueZoq Ady) ‘oue[siyH SuIMmoy]o} SAOOIS & JO HQ B }0T | DOUG “dIJ JOJ SIU} JO [Je SUTUIBD] SBM J SAATIOG 1, UP[Nod | puke poyiom Apog dy} MOY SUT|SOJO]UT OS SseM }] ‘UOTJRONpS 9) SurAofus pue soy YM dn Surdsoy sem | []Nd 4, upip sey soy siq pur 0} [nJores Suraq pue Ajddns poojq s,Apog dy} s}eudAnf[91 0] soyo.s premdn Ul SOATeO SIY dn poojq oy} BUIYsSNY “SOfOs SITY JO SoydIe pue Sjoay STY YIM URZdq OM ‘J99} SIY YIM SUIS “UONOW AISAS JOY SULJOTWUL “ouRTSIyH yum Apog s Aaiyjor 8uniyds pue Apog sy} jnoge pajyeonps Suiaq sem ] ‘YIM UIBdq 0} [RoI JOJ PotUdes [Te SIU], “AoIJor 0} sANdnIsIp ssoj sem pue d10UWI JO youq Suiod daoy 0} Suraey wos ow poyusaoid 71 Os uuwssoj Aww 879 $0 9/Gabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 42.38% accurate

LOT FOORTLIAIO 82 UW PlO} IND AW UL DUITIJOMIOS “1OJ [BI] UO SBM | JeYM ApIeXO MOY OYs SUL P[O} JLY) Sovj JOY UO D]LUIS AOD & peY oY IsIdeioy] odesseW S_AdIJJor SWI099q 0} [LT JUSTUAOTdIIS Ue UO SeM J JOY po} pue sv sul MSU ajdoad Jsoul yey ST YOIYM ,.eUUdS,, SB J[OSAW PooNpoljUl J "JURISISSY [BUOSIOg S ,OURISTYH *, AUIUIT,, Se JJOSISY PooNpoUT sys puke [NIqQsIjOp powses judooe ysisuq surpeodde pure s.ado onjq SUTYSOYS JOH “19 910J9q ylomusded jo punow 34} wool dn poouerls yey) ey Joy ur syesds puolq YIM JIS BuNOA Suryooy jueseajd ve sem slay] “USsYyoITy Oy) OJUI UNLY MO[OJ O} POYSC PUL SJUSWIOLU M9J B UL UMOP oq P[NOM sURISIYH IW PIO} pue ulese Joop dy) palomsue URNS "{JOqIOOpP 94} SuIsUL s1OJaq Ajorxue SU} JO SUIOS a]eYXd puke YeOIG AU UI MeIP O} YsNoud BuO] Ing asned SJUSWOW B SUIAIS “UIVSE SIOOP USPOOM JBIJL] 9SOU) SJOJog SUIPURIS SEM | 11 MOUY | d10Joq pue Ayyomnb Aeme paddijs uooussye oy} JO S31 SUL, ‘poojsjJapun | spisul UMOPp ddap puke 194]19 UOSBaI OTYNSdeIOY) B 1OF 1, USEM I PUR SUT OSN O} PoyUBM Ady} AYM A]JORXS MOUY sys SW p[o} ssensuR] Apog 19y JNq “SsP1OM UL jI ples JOAdU SYS ‘osessewW e& WLIOJIed OQ} J413 PlO-JVdA-Udd]JIJ POuIeIJUN UB 3SOYS PJIOM sy) UT SsJsidesisy} Jo 1s3q dy] JO JSdq SY} P1ojje pynos oyM 9s] doad asoyl yey} pondsujUI pue posstidins Sem pudsuy AW “d1{ Joyjoue ‘Adesay} oSessew SurApnys Aj[eIoyo MOU sem ] Addey os sem | MOY [ALS DUO P]O} ING MOTAIOJUT WOT]dx9 Avu O} S[Te}Op dy} JO BuO OU O} ANOS | ‘YORUIO}S AUT UI 9IULDNq S}OUY oy) poysmnsuLsip SIOU! SY} JOT INOY Y) 193k] BY) jng ‘OWIOd 00} UOOMISe sy} UI pesye Aey yeYM JO YUTY) O} JOU pley SUTAN Aep yey) OSeT Y-IeJ Je FIOM 0} USM | “IOJJNS O} ponuyUod J ssoudodxo sy} YSNO1Y} SUOSSd] psey soft] Alu Suruses] “SAeMAUB JIOSAU POADI[IG UDAD JO }, UP]NOM Ajqeqoid | ysnous Ajpes USWdAdTYOR JOJ SuIoORo dos JOAd 0} PIU] SWI JO ysni ou si o1aq “AjMoys dn ajiy 19y {ING pue s5eM JsouOY ue BuIWIeS je prey paylom jsnf ays Jl UMO JOY UO IT OyRU AjyeEMde pyNod ays AId yeY) |[2] Pjnom { 1x9U pue sJayj UI dn sBuly} SWOS dyeYS Isa} 0} pesy AW 0} YORUIS PleY POO & YIM Les p.[ “Ofl] AW UE SLUT] SI) DSOOYS P[NoM | J[ASAUL JSS OAD OF SLUT] UL YORG Od P[NOD | J] “9UO JYBII 9Y} Suisooyo sem | SuTyUII ‘JOYOUR IOJ O[AJSOFI] TuTYDOYS OUO SUIpeI] SVM | “UTLTL soos 34} UO daays JJASAW SUID] JOAD URY) JayeI pynoo | Aem Aue 1 OyeUl O} PeY { J[OSAU [Jd] 0] PONUIUOS | Se BUTYIOM SEM SADT{9Q 0} JJOSAUI PIDIOJ ] SOT] SY} JO SSOUSATIODJJO SY] ‘UMOP SUIOS SEM | PLOI 34) Woe] 0} ABM Joyjour Isnf sem 1 ssand | .“syyed ds10M UdAd UMOP O38 SJOYIO ‘saaISapP Joy Aed 0} soipog s19y} Sursn pue raddiuyjs e Surmosaq Aq adaTjoo Ysnoy) SOA[OSUISU] 199 S]IIT SUIS ‘19Z993 PO YOU siq} 0} Apog AW urTesIeg 0} PeY | JL IVYM OG,, JOSALU PjO} | “J1] BJBUNIIOJ & Pue JOIIED JeIIT & O} JOON) AU oq p[NnoMm j1 ‘UBTIOM FUNOA & SAI] SUTAUIY) WeJs puv JoseUsa) ALU B SUIaq wo dn dajs 0} pey | posd9Ns 0} JopiO UT JJOSAU SUIOUTAUOZ "ose SUJUOLU AjUO LUOLJ Jd1} USYOIG PRY } If] BLURS 94} UI poddeijUs 3q 0} jNOGY TVILLNICLINOS [cua poissjqug wyBuAdo5 CG O9T POOMMAANIO Lc "$19y}0 JO oInsvajd [eNxds dy) JO} posn AjUO [00} poyseMUIeIQ & oq P[NOM [ Y8nous uoos jnq ‘JOA 11 MOUY USAD } UPIP | pue pauofsues Durloq sem OJ] AJA “OUTIL puke oyesS STY OJ ‘pory | “ABYO SeM BUIYIAISAD JI SLU Poyse oy JO] SuLzed ay} Ul Jed STY JO NO 403 9M JIOJOg “ped Aut YUM xOM 0} diy STOYM ot} JOJ JoInb sem J ‘syYsnoy) AW wo AIOWSW Ss AepIojsoA ysnd 0} SulAT) ‘peoye Aep su) NOgGe SNOIXUR SUI[OOJ SYOML J SUILIOW JXOU OY] “Ayiqeioupna Aut Jo uoyeyojdxe ue Aejdai yoers ‘ouerjsiyH pue Adijpjor 0} J[OSAUL DAIS 0} PRY | SJUSUTOLU dU} JO SyORqyseyy 0} ABME YIP 01 AjUO SaAo AU BUISO]O “O0} s]qissodull AjIvoU SEM IYB1U Jey] dsa]s 0} BUIAI], “SW JO OPISUI PUL SU ISAO [[e PUL OL UI SpURY ITIU) JOO} |[S Pynod | ‘djay 1,upip J 1Nq “JYB1u Oy) JO ssoulyy sy) ABme YseM p[NoM jI JI Se JOMOYS ay} ul AJPISL JJoSAUl paqqndds | ‘SUOTeIIWUIT pue dinje}s AU JO [11d B 10j S]93 }1 SB Pood se dq pnom sIy) JjasAu Sutpulwiss Aq puodsal Ajjeyuau 0} AjuO SIU} UIA YSNOIY) OF A[[edI PjNod | JI J[SsAUI SULysSe “JUSTO B IOFJ JOLIN DY} OJUT Poseys pue IOMOYS & SARY 07 WIOOIYIEQ BY} 0} JJSSAUWI PasNdxo | “UO WYSned duo OU Jnq SdAd AU UI SWeYS Jo JULY & ABME DAIG JYSIU | plese UONPSIOAUOD JL} JO no 303 Aypyoinb | JaxIOM prey ve 9q oF Ajfiqe AW pojusutjduroo pue 10J SULDIOM sem | OY pouonsanb Apoqon “peoye di] yey) Adeiay) o8esseur ul syoodsoid sinjny dy) pue psaisoal pey | Apog ou) jNOge SUOSSd] OY} JO WAY) Burjj[o) A[UO ‘S, yO} Au YIM JoomsS puke ojduis yi ydoy J yeatue Aw Sunedionue sismM sjuoted AU SWOY 103 | USA, | AO} OTP] MOU STY se JJOSAlu opessop 0} Savy 1, UPIP | B19y) ATUD “OSe]-Y-JeP] 18 O9eM S$, YIOM ojoym Aur Apieau sem ji JeY) poysne] oy ‘puey AW UI Woy) Suloeyd “sojou dsi1d OM) NO YOO} puke yOR}S 9UO paqqess d] “spuesnoy) ay} Aq juNOD 0] spueq Joqqni YIM poyereddas s]Iq Je]]Op poipuny MouU-puejq JO SyxdR}s SUI[RdAdI “Seq sy} pauddo oH “HJOM JOYE SUT] SWS ‘MOLIOWIO) UTRBR OUI 39S 0} PAYSE SYS “00} ped] PjNod siy} soy SMOUY OYM PUR 3] Ajs AWW Psy] | Ajjeoi Ady) ‘ysideloy) asessew e dq 0} Tel]UdJOd yeoId peY | JY) ot 1]9} 0} uedsoq pure Seq ou} WY possed ays ‘UMOP US Adlffor 19] 0} WEY oy) Woy POAOU dys Udy AA “Seq [OJJNp 1oyIVa] YoRTq sty SuIppoy ysop e je Sunys SEM SUPISIYD JOY SIeJSUMOP OUT 1YSNOIQ dy [UN possoip j03 YIOG om IS[IYM JUSTIS poureulas ysnl | “soeyd yoo) ysnl yey) SJUDAD S$, GUIUDAD dINUd oY} WoOlj posseequid-jyjey pue Aes AT][eO1 01 JRYM Ons jou Jornb Surdsoyx ‘s aA40 AU JOpun wo dn-syxewW oy) podim pue Jjo JasAW pop | °00} yoes) 94) UMOP J9}e] OWed Jey} A[SuIstdins Jou Jnq “[[3M Se WIY SSoIP 0} SUI YSe 0} UY poyoodxo Ajieou | “Poup sem oy [QUN [eMmo} ALN GM oy) yy Apog sity uMOp poyed ApjuRlpdiuod | SfIYM BUIZIOIJ 19Y) IVS | Sv ISIY jjestury Sunjnd ures y “uMop uly yed pue suo Jod 0} dtu poyse puv I9MOYsS ay) opis}no ysnf yors payeay 3y} UO aJdM S[aMO} dy} 9 Pjo} AdJor ‘Inos Aqoa AU yOojun 0] SPJOM JUS 9} pue JUSWIASeINODUD SUIOS papaau | ‘JJoSAU JOJ Opeul 879 $0 //Gabed ‘0€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVIENTCLINOO feuMEA porsoiosy 1YBUAdOD [)j

The text on this page is estimated to be only 44.05% accurate

COT FOORRLLINID Of “UOOUIIYR JX9U SY) YOR 9q 0} ATUO ‘SWOY SU SAOIP UsY] oH “pred jos Ajyeuiou | YONW MOY BUTYSe UdAd JNOYIIM P3MO SeM | JUNOW JoRxd 24} INO YOO) puke ysap s, Aayjor 0} JuOM OH “Aed Aud JO} UY Yse O} pey ] ples pue dooyse sem Aasjjor Jey] URN PjO} pue SITe}]s UMOP YOR PoyeM J ‘days day 0} SUIOS Sem MOU PUR SN UddMJOqQ ITejJe SJLUIUL pue sBesseul dy) Jaye o1F1eyloy sem oy sv ‘aul Aed 0} ueNys YS OF 0} SUI PO} 3H ‘ysonboi AISAD 0} Ul BUIAIS ‘UNY O} J[aSATU Jo UOYNqIjUOS AU Ul poseo|d AIdA Poses oY pue UIRSE J9MOYS 34} YIM dn poysiuy oA “SOIISSp UsyOds sry Jo [je wy JuRIS 0] pojyoadxa sem | PUL PUd dt} 0} JOS HI [YUN “Bulop aq Pynoys | asja yeyM UO SUIJUSTU WOOD UITY YIM ‘Ou IYsNe} pey ourysTyH yeym suyesdoay ‘uiese I9AO [JB SNOA, Bf ap SBM I] “JUIMIULELIOJUD STY JOJ SUITIEM poq oSesseW 34} Ul UMOPSoR} payeu SulAey Adios Jo audds [eotdA} oY) YIM UIOO sBesseul dU] 0} JOOp ay} peuado | se sduapiyuO0s Aur yiydn 0} SutAy Yydnoy) ] 189q 34} J0j adoy pynom | “wry Suiseayd ul uONesI]Go Aw Surpjoydn OJUL J{OSAUI PRd| 0} SUIOS SEM T MOY JO JD9d x9 0} JeYM MOUY 1, UPIpP ] IN ‘WOsWOd v JO SulyyAue SVM SURISIYD Jey} JON “UMO ALU UO aq O} SWM | SNOAIOU MOY JO SIBMP BOW IW peu! [je Weoy Sues pides Au Jo pny) ayy 105 jda0xa Ssoul[s JO punos oy) puke ‘uspjos poseodde woo1paq S, Adijjar palajud | Se Spul[q PaTvIoUOd dy} YSNOIY) SuNYSI]{ Jo speys oy} Jo suoleAlasqgo Aw ‘siadaoyasnoy oy) Aq pasn A]]U9901 S}UdSIBJop Sulues[d IU] [JAWS Pjnoo | ‘pesodxa Sulsq soaiou seq AW WOIJ pousjysoy 919M sosuas Aul JO }]e Ji se pure ‘siieys oy} dn Aem AU dxLUI O} PONUNUOD | ‘sostuoid uayolq pue sdiysuoneyiad usoTIOj JO UONSaT[oOo sty Buore spIs aso} JO auO0 dh pus pynom | Ji J[9SAU! O} porspuom | {S,o}0yd asay} UI Sind AuBUI Os d19y} sem AYM OG "}X9U Oy) JO pl 399 pue Aep ou] JO} uo AY pynos ay Suryjojo jo adaid v dyT] SIS sn poyeos} Aoajor “UMO SIY JO A[LuTR} B SUIARY JO UMOP BUIT}JOS 19A9 Jo sjoodsold OU YAK “SAPP Jopsey uses pey dy JL SB d0vj SIY UMOP UMBIP SOUT] SYSTIOjOvIVYS pue vey AdId AUTYS YIM sory Ajieo siy ut ueLU SUTZe Ue SBA SH ‘Je YOO] O} YONWI sem Adlfjor SyT] JOU §,}1 ‘OJOM O49) S]UIS AURW MOY BAdI{9q },UP[NOD | “‘UOTSUBLA STY puNnole Avydsip uo sid ssajdo) pue opnu-jyey jo wo1jd9]/09 siy ul ydersojoyd yors UI JUS JUdJAJJIP B PIoNOU J SJOU dy) PUNOIe poyOO] | s10W 9Y) SuToyou ‘1ON9P 94} JO SOW Ul FuIyxe) ‘OUI STYy) JfosAu Aq sIeys 9y) dn poyxyeM J ¢ 1aydey) ‘yuo popuadap jeu Au se ‘ow yYysne} pey sys yeyM PpoJoquisulal ] SNs SyLU! OS *O} Puazje O} ssouIsng pey sys se Aepo} UMO AU UO 3q P]NOM | al plo} dYg ‘poreadde sys Jey) spuodes oY} UI [eJUOWIeJOd Wa} pue TVILNACLINOS jelaqeyy poysjoig ywysuddoy Z91 POOTALAMO 62 poAouur pouisas 1ouRaUIAp Joy se ‘gol sy} UO oTIYM SULTULIp puke Buea uddq Avy },Upfnoys | sqAew dy] Surpooy ‘yeas Aw wos paduinl | ‘aA9 Jay UI YOO] sSUd]U! plod B YIM puUlYysq Wo sw poyoeoidde auvystyH s10jaq ZuO] 1, USEM J] “UIeSe YOM 0} JUIM | S10JOq UOT]eUSAN{9I SY JOJ [NJoyess sem pue paydasor | “Iayeyd & UO JINJJ SWOS puke YULIP PjOo B SU Polafjo OP “OURISIYD 10} poyrem | se UlVse USYOITY 9U3 0} SUT JYSNoIQ ueNyL “Q0R] ,S]I1S Biq,, Aur uo ynd pure AjIWETLd Jey} JO JNO JjasAW YOoys | “yse} AUI 0} SUO]e OU DARI] JOU puR yoeq WIN} ATUSppNs 0} WATY JOJ Sue ‘AREMOALIP SUC] SY} UMOP DAOIP dy SB SARM B Pur IWS & UITY SALS | “UILSB [IIS STII] STY OHI] YONU OS JOAd BuIyOo] “Yons] S1q sty Jo yno poddoy [ SB [JOM SU paysim oy “Hey OUR UL Suiem Aqjuorjed a19M SomnyNA dy} o1aym ‘urese AeA O][1G [A 0} 19A0 OW WYSsNOIG peg AW pue Aep oy} JOj YIOM paysiul | “W9Y] MPS |] SWI] YOO SJOW JJISAW OpRIdop 9 BULyBW pue dul O} BULA] JOJ Jfass9y MOIOS OF 0} J9Y BUI]{9} JO peoysul “ABpo} Wd) YIM BuId9UI 0} PIVMIOJ PIYOO] | 194 Plo} | pue 19A0 YOO} apis juerfdwuos SY], “UrIeSe YOM JO JJO JOB | USYM IOAO DUIOD O} OW BuLyse sue[styH SBM } A[ZUISTIGINS “YIOM Je [[Bd B PIATIIOI | UOOWID}E SUIMO]OJ 9Y |, ‘ouoy yorq JO ow doip uens savy pue ow Aed 0} SII2JSUMOP ]U9M []B OA UY} Puv ]XdU JOMOYS B pey [{v 9A °O} BseUOY AW Aed prey | 9u0 Ajuo 94) },useM Ad Jor Jey} SLU GUIMOYS “WUOOI WRD}S 9U} Ul 19M IM SIUM SUIT} SIU] JO9J JOY SBSSELU O} SW Payse sy ‘UOT}eSISAUOS IO} SN YIM UT Burulofl suL[sIyLH dull} SI} “ULOOI-LUBd}S OTISI[ENITI JY} JOJ JUOM OM SPIEMIDIFY “AT[LIO WISLSIO WIY OAV SUT dABY O} PoyUeM 3Y SUIT} SIU} PUB SUOISSSS INO O} pus dy} SAPMIE SEM XRLUI[D S AdLJJOL “9ULOSSOIY} DIIJUS SY} INOYSNOIY] OP OF JVYM SUI BUI[[O} SLU ISAO [O1]UOD 9Y] SuLABY POAQ] SYS oyI] 198 PIp sins ays nq Apued-dA9 SIY JO dyes SU} JO} SIY] SUIOP SBM OYS JI MOUY }, UPIp | “JOJO YORd YONO) pue ss1y | pue Jay payoyear SY S[IYM SUIO] SIY dyOIS 0} UMOP SpuRY SIy poAoW Adijor s[IyM spuey Jay YM Apog Aw SUISsoIVd SBM SYS JJO do} Jay pey suR[siyH pure poxevu Ajoya[dulod sem | SJUDWIOUL UY AA “‘PUIYSq WOl] SUI SssipuN O} payers SUPISIYD pue sinseojd ul pourowi Adyjor “ss1y B Woy) dard puke sojddiu sty uo sdiy Aw ynd 0} at Sur[]9} ‘IOSUOT PUOSSS 9UO IOJ JJOSLUTY UTe}UOS d1eP 1, UP[NOd o]7 “ysoyO sty O} dn outed om USY) puke s[amoq oy} IdnisIp JOU 0} UOTOW JENIN SstMYOOTO Buresids e ul spuey Aut Surysnd yoewo}s sty 0} dn Aem dy} [Te OFeSseU O} MOY SLU MOYs 0} ponuyUOd sys pure. Apog Sly JO JUOI dy} 0} } pew A[BuIsidins om OUT} SIU} ‘UIede ABM OU) SUIPeS] SULISTYH YIM odessewl e AdIJJOr DART | “GUOIM WOT Jey}, usemM [ ‘sourwood $.jYSIU Sv] JORUS-d1 0} SABY P[NOM | 3194 WOO papeoip Sues 94} 0} dn sU ped] P[NOM yey} ssedeI]s SUIPUIM 9} O} 9sNOY oe] AJDAISUD}X9 SY) YSNOIY} po] seM [ “OdesseUT SITY JOJ ApeoI sem AdIjjor OW pjo} pue poreodde sueystyr 910j9q JUSWOUI B JO BuIJEYo A[UO d1OM 3A, I[]J 0} jnoqe sem | uOTIsod DUIS UY} IO} Poel) U99q peyY [JIS SUNOA B SUIT} SIL] 9} },USeM ST} 879 $0 BLGabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TILNACIINOOD jeuaey, poyroiorg wsuAdoy 7

The text on this page is estimated to be only 41.65% accurate

SOT FOORLEIAIO TVLLNGCLINOS POT Poor asAANIO — TVWLLNSCEINOOD JEL] P2199}01g JYBUAdOD [1 JEIsaIVIAL PAI99}IOS JYBUAUOD 1) cc asoul UlIM MOUY JoAou noX yng ‘qol 94) 103 | ounsse ATUO pynod | WYysTUO} Surjoe som Ady) AVM 3} WOT pue [ey JUsWAO[dUIS AU JIM Op 0} SUIYISWOS PLY JI MOUY | “MOIIOUWIO] NOQe Y[e} 0} SUIYJOWIOS SALY [Te Pam pies yng ‘AeMe JYBI WOdID}UT 94) UO URNS Po][eo puke WesTqold ou pres AD], Poly Sem pue SUIUIOW dy) Ul YIOM pey |] Se swWOY SW But prnos ueNE UdYM Poyse ] WOjoq IIYM & JO} USYDITY SY) Ul NO Suny Te 3A, ‘goed Aw MOUY ] OUNSUI Aq PUB AYDILISIY S[GISIAU! SIU] SBM 919] JI SB “‘payorye 993 0} JOU YSNOUd Pdasosal jnq spsou Id} 0} SUISI|GO SABMIR “[99} JO JOB O] MOY SINS } USEM | ‘SOUNLIOJ M9} JO [Je ISO] Ajrues Jay sOJaq 00} poulo}snoov SEM dys {AISOJI] YSIAR] Oy} saijddns oy pue 9}se} Jetjnoed SIY JO} SJIIS OY] Ul SBULIG SYS “WdY) JO OM) 4) USdMJoq JUSWIOs URE JeENXIS B IA] OUI SEM J] ‘Psq Sues 94) UI Jdojs USA JO SpuRY Ploy JOAIU pue passly A[aueI Ady “sJouped se soajoswsy) popsedol JoAou 494 ng diysuoneyjas ayeurnjur Ajuado ue yons pey Adljjor pure ourpstyH AyM PUR\SIOPUN } UP]NOd | “ULTdq [2 SIG] SOUTS WOU) YIM [RapJO sfOyM 94} ‘Su JO} S.UeZIQ OS ]]B sem jI {je ye pouaddey pey Suryjou syIT “sJUsWMYssIjaI IUIOS JOJ USYOITY 9Y}] O} SITRJSUMOP JUIM PUL POSSdIpP 103 [fe SAA “SJUSWOW UIYJIM IOAO SBM UOISSIS BY) PUB ‘XBUII]D OF JJasuuTY JYSNOIQ sy “WYsIoOp YONU UT POOYURUL Siy SULYONS ‘poyojyem pue yoeq pre] AdI]jor spTyM Jayjo yovs uo Avdasoj Jo sjoe uviqsa] SuIMIOJIEd | pue sueysiyyH “Awury YIM Worssas $, Apo} YSIUL] O} poq S,AdIJJof OUI SN ps] oUBTSTYH Jamoys dU] JPY “SdIpog ay} poysem om sv sotqqng deos YIM polsyye] surloq a40M AD) BIYM JapunN pooys yjoOq AdIfJor PUB SURTSIYH 1eYy) spesyJomoys OM] JJOA\ OY], “JaMOyYs oy} OJUL peoy 0} Apes som Ad} [LUN osesseul 94) YUM ponuyuos | pue Aulwg "1994 1104] ye [IES SuNOA e& YIM YoRa ‘youdg aqiew siqy Jo do} uo Sujis ouesiyH pure Adijjof SEM 9194} OS ‘}IQ B OW PATA uleajs padeosa pur 11k JO 4SINQ POS dU} Jsed] TY “OSIMIOYIO OW BUTTS} aJam syousul Aul ing ‘ye Wed}s eB JOJ sn ULOL OJ UL SLURD Ady} JI SB psyoe AU] PUL DULISIYD “UdUIOM PdyLU OM] [B9AOI 0} pousdo ATUSPpNs Wool 24} 0} JOOp oy} Udy dn jeay 0} JIe}s AT[eOI O} SUTUUTS9q SBM | “‘Pd}Ioxo SB SOIM} SUT SUTYRUI 99RJ INOA Ul LUKD}S JO GUTMOTG JULISUOD OY} pue SUOHOT JO SIO JNOYM WOO] WRd}S SY] Ul OSvSSeUT O} YISUII}S SOW! JO] B YOO} I] “SSATeO sTY 07 dn AVM dy} [[e PodesseUl | 199J STY JO S9TOS OU} UI SOYOIB PUB S30} ‘saTyUR ‘sjady SIY YIM SuNIeIS “9OUO IOJ SadessEU JO XS UBY} SSUTY) JOYIO JNOGK SUI YIM SUISISAUOS PUL SAT]UD}L SIOUI JOT & SUTSG I9}0v1BYO JO JNO Surjse sem 3H “IOYIO YoRs 0} oy ]od Suisq isnf ‘punole Sulsuno] sem Aep sty Moy Addjar poyse | pue “yom ye Aep inod sem MOY OAT] SBury} a[duus Noge jjo payivjs UOYRSISAUODS ING ‘oSesseul sty AIOjjor BUIAIS UBS P[NOd | IVY} OS UO JIS O} PoJONSUI SEM | BJOYM JT YJBouIapuN days B peY PUR LOO] 9] JO PIS JOYS WO JUSM RY] 9[QIeW JO yno SPRL OS]E [JBM dy] JO INO Zurwos youaq & sem o19q,] “S}of UT [ING S_f[eM Te g]qIel oy} tWoIZ UT INod 0} URS9q WIeS}s SY} PUR SUO}]ING Maj B paysnd DY PUL WIOOI WIRD}S 94) OJUI JUSM SAA “[[9M SB SSaIPUN 0} URZAq | OS ‘UIOOI UIBd]S dU} UI UOTSSIS INO DOUSTIUIOD 0} PI]UBM sy SUI} SIYT “A[S]VIPSUITUt. SAOWSI O} URS9Q OY YOIYM “LITYS}VOMS PILAIV]] & pue sjuRdjeams jo sed v Suueom sem dH “dq 0} DITNe S sITUOTTIIQ [eoIdA} ANOA y9adx9 P. nod yeYM ZULILIM },USEM Ff “SW ISITJ SY) JOJ SdYJO[D Ul WIY dures o8ueNs sem yj ‘oouvIvsdde siy spew Adljjor¢ SIOJOq SOINUIW SIOWW USI] poos & sem i] ‘paq 3} JO pUS 94} UO S[sMO} Pop]o} ApJeou oy} dn ssoul 0} JOU [Nyolvo sem puP d[qQe) OdesseUl dn spew Apeol[e oY} UO UMOP Jes J ‘Aydurs sem jt A[SUISLICINS WOO] BSeSSEW DY} 0} JOOP 3y} pousdo | usYy AA “WIOOI S AdIJJOL 0} [[BY oy} UMOP papRsYy pue osind Aw ul payeo skemye | yey) Avids Apog sy} yyim JjasAul podesds pue poyse oys yeyM pip | ‘Ayoys ow Sunjsodxe aq [],9Y 9J9YM WOO] aSESSEW SY} 0} ABMI[EY SY} UMOP JOY MOJO] O} Pue “SJOYOUWS JO ]]SUIS ay) poyey Aoyyor se ‘ATysnosoy) spuey AW Yysem 0} SUI pajonjsuT suURTSIYH ‘ARME SUIPCYD JO SONU UdDIFIJ Hoge Joy “suIppnq sem diysuonejol OBURI}S BJO PULY DULOS OY]] [99} O} Popeys 1 puke SPUdTJ Syl] poyeyo SN JO 9dIY} [[V “SAUI] S[QISIAUI SSO} SSOIO },UP[NOM | JY} PoyxT] ays pue souepunog Au MoUuy | ‘ABS ISP OY} OARY 0} 91GB SEM Ys SB SUC] SB “}1 OI] 0} pauses ays jnq “Jay 0} YOR I BuIAIS Apoqotwuos 0} posn sem ouRysIyyH YUIY} 1, UOp | ‘Y8noo siayours Adsel & YIM Ape] Plo ue uk} JoyoOUIs -UOU psouslIodx9-Ul UL 9q J9tIVI P[NOM | SutAes Ws} 0} Youq j sais 0} 9[qe Udy} SEM | ‘OW Je UN; oyod puke YSneJ 0} sn Jo [Te OF Jayxe9I1qGQ991 ue sem }] ‘doudtedxo-ul AW ynoge syol pue ysne] 0} uRdaq S[IIs oy) ‘QYOUS JO UOIRIEYUL SY} WO] YSNOd O} Poyie}s | USYM OS “U9 0} YOO} Ajai JOADU yNQ “Spud AU JO DUO JO JUOIJ UI [OOD YOO] 0} BulAy] Sapisaq ‘9J0JOq YONW Sd}}0Ie319 POYOUIS },UPeY | “QUO SUI PoJajJO Udy) PUP 00} dn 9u0 jt] sueysiyd ‘ayj0I7e310 eB UO SulJjnd puke sUIZeSeUI B SUIPPdl OpIsjno Apeaye sem Aw oJayM Auooyeq & pey 3] ‘podejs Afsow Aurmy s04m WOO jsand MOA B 0} aU YOO} ays Aolyor 0} dn yYysreNs ou Suryey Jo pedaysu] “poout JayOq YON & Ul 3q 0} porvodde suR[siyH UOOUIDe SI], “pud dU} UT HT YOM 9q Te Pinom i JyasAur Surjor daoy o} pey ysnf{] Surog Suruoseas AjUO AY] ‘s0aId Aq soaid jyasAur Aeme oye Jey] OWRYS JO sJUgWOUI oy) BuTARTdal ‘s}YysNoT) JO POO]] ITQeIIASUT 9} IYSIF pynom | Wsu ye sods Aww Sulso[D ‘sow Aue [Jam daojs UDAd }, UP]NOd | “Woospsg AW O} JYSIeNSs Surpesy s1o0jaq peq pue woyy 0} ..1H,, Aes Alpouq p.] ‘swoyY jos | UaYyM S}YySIU ISO|] "JSEJ Ul YUIS O} SUIZIERS [Je SEM 1 ING SULOP SEM | JLYM dAdI[9q 3, UPjNod | ‘SONIAHOR Yiu aye] snonuays s, Aojor YM dn day 0} SurAey pue BUIYIOM JO YOOM dy) Wolf poysneyxo AypeorsAyd pue Ajyejuotu sem | ‘Spunpy [J JO S}SAq} [eNXxas JO AtUWI_ JURISISSe JOY pu [JomxeY “sy Aq poutol UdSYO “Spoou STY []e [fJ{NJ 0} powoois Suisq A[snonunuos pue sadesseu yim Aoayjar Surpraoid ‘quynos Ayrep B sem Yoo SUIMO][O} OY 879 $0 6LGabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUBWNDOG ‘898Z-8T aSeD

The text on this page is estimated to be only 41.11% accurate

LOT FOORELIAID VE “ORB Y-V-ARJA] SuTTLD ynoqe AUIOM O} JOU SUI PfO} oY ‘UOTSURW Ss AdI]Jor ye jfo au paddosp peg Aw Surusow yxdu Oy} y1OM 0} StU SUIALIP JO peojsu] ‘SUILUODSq SEM | OUM JJOSAlU 0} SuLIApuOM os Yd] oYs ‘AVS P[Nod sys SuIyIOU YUM ‘UIOOIYILG dy} JO INO Suryoeg ‘Wt pozipeor Mou jsnf{ sys puv ‘ose duly Zuo] & ISO] SEM JOIYSNeLp JOH “wy ddI 109 [| UY JOR]UOS UT d30y pynom puv s014] aqAeu ‘sydomM 9/dn0d 1x9uU Sy} JOJ ABME 3q P]NOM | yey] MOU Jay Buiyyay Ajduuis sem | “Joy SULySe USAD J ,USEM | JNq ‘deyd snoAsou & ILM SOTAOLU BY] 07 B}ep & UO OF 0} JO 9DURP JOOYS-Ys1Y B 0} OF 0} SjudIEd Jay) 0} dn Sulyons 3q pynom spss Jsou usa VY “O' AN 0} JyO durwow }X9U OY} SULARA] DOM IAQ “Buryoed jes OS 0} PRY | Joy PjO} | ‘00} DIU O} SEM I SB DULYOOYS Se] PUR “WLIS P[NOM SITY} JO [Te UdYM payse ayg "WL oye} 0} pey | pue “Ayiunqoddo suiyayi] @ Ul 9UO B SBM STUY} JEU] “SN SOULAUOD 9S1MI9YIO O} JJOSALW PUB IDY [[9} 0} PeY | Sdtj Jo younq B SEM I 1d90x9 “poos OS papuNos {je }] “SUIWIeS] 9q P.[ Spet} dy} [fe Jo }SOUI puk JO9U Pynod | a]doad ay} “Bulsas aq p.| Sa0Rid ay} ‘Sues 9q P,] AQUOUL BY} NOGe Jay PjO} | “Ul BULAI] 9q UOOS PjNoM | d]Ajsafl] SNo1oOWR]s JY} O} SPIS 19Y}O OY) SULUONUSW JON “}YSIU Jey) JdI[Jed UsATS Uddq PRY [ Jey) youd Ou) JOY BurTjas ULID YSIS v JOY poysey | pue UOTOSIIP Joy UI JOUOOUUL Ld) payjeq sada anjq AW ‘sem | se 9]qeuoissoidu se ‘snyy ‘a]qnoy ui sem ] Uay ‘pey SABMTL S,dYS Jey} DDIOA JO UO} UI9}s JY} posn syg ,.gAdessy} OSSSEUU UI IOUdTIOdXd OU YIM PUR S[eHUSpsJO OU Sey OYM “FITS Plo IVsA UddIJIJ BV YIM JURM d]dNOd Japjo Ue SOP AT}OVXS JeYM “BIUISITA ,, “S9Ad JO UL YOO] dT SOY & YM LOOP AUL Je POYdOUY 9YS *YI9M Jse] OY} Ud9q pey | d¥1] ‘Wooipagq AU! Udy) JOMOYS 3} 0} Suipesy ‘suoAue 0} duryeads PIOAB 0} DouURYD B pRY | WOJdq “JYS1u Jey} SW paisuI0D WOW AY ‘UNYM [BNXS AIBA S, AdIJJof Ajsyes 0} paylojdxa Sula fyey & pue INOY }x9U SY} JOJ ‘s}UsWaIINbal sty JO Sulu0013 jeNsN oy} OJUL paouKApe JYSiU SY] “oTqeionbuooun Os suses BuNOA OS UdYM 3eY) PJJOM S14} Ul }1 oyeW Pur UMO AW UO JNO Od | Pynod udy) A[UO pue sjetUspolo AUI UIeS P[NOM | Ap UO [UN SdlIsap [eNxas sty 0] JUBAIAS STY 9q P[NOM [ INO UO dI9Y WIJ MOUY pu Jdzjo sty pajydsooe ] JO Mo 3 YI{L} 0} 9UO OU PRY | ‘YIM sy) SUIMOTY UO OU YM pure ‘soyxe} HT IVYM JO}JLW OU P3999NS O} SOAT[ INO UT OP O} 3ABY 9M JeYM Op [je OM JlosAUl pjo} ysnf ] peoy Aw UT [Jam SB []2d UOHO9q I9y} Je 9q 0} SULARY JO SSOUT[OAL] OY} SUITE UT ATUO P{NOD | GUT[SABI) 3q 0} PO}OXa SPM ] Y8noy) UdAd ‘soHd I9Y) OJ SUISNUIe UY] dIOW 9q 0} peYy UOT}OvII ATA] “Udy ‘ayora} sIy AU YIM O8e OUT] BUC] B paydso0R pey | uonou ev sem Jazjo 0] Apog e Ajuo Aq punog Ayneaq Jo jjays Ajduia UB ULY] OW! SUIYJOU 919M Sd]BLUd} JY) BAP! SUT “SW) SY} Je BuIIOJWIOD pauses dseid sly OJUI pMd] 9q 0} Ajl[iqesau[NA AU ‘OUI SATS 0} Prey 1, USEM JOJJO MpuBIT sty JO UOTR}IdUID} SY] “UONeXeIOI JO J1q B 1OJ SowLL TWILNACLINOS jeuoeA] porsoiorg wWpsuAdor |) 991 POOMMAANIO ao "1S ap] ised isn pueyst papnypoos Be paumo oY] slay “UvaqqueD aj} 0} JJO Suljas oq 1X9U P]NOM puke ‘AN Ul UOISURUT JsadIe] OY) OSTe ‘URE YURI] Jo apis sea Jaddn oy} ui souspIsel sty 0} Surpesy iss yof ajeatid sty UT J9Y}9B0) YOVag We SUIARS] 9q P[NO aM MOLIOWOT “Aep B Sault] M3j B dq P[NOo ples UdAd dy YOryM ‘adessewu Jod sie[jop OOTF suruses 9q ppnods ] qof yuormno Aut ye Inoy Jad ssepfop 6¢ pred Suroq uey JoyIeY ‘souL}da00"R AUL YPM SUOTL SUVS FLY) SOLUNXN] 3Y} JO [[e WIM dW popensiad ssyNy Udy} 9] “ASNdsseul BulpJoaes) JUsURWIOd SIy SUI0D9q PUe OBE']-L-IE| ye gof Aw yinb ysnf pynoys | yey) “JusuId.UNOUUL SIYy spel Udy} AdIJJOL “‘sAemAue Asnq Os sea Jautiuns yey} Apferoodsa “jjo SLU] OUI 198 0} 9/Qe 9q J, UPjnoM puke gol 1aWUINS B ATUO SEM O8E]-Y-IeI ye got Aw jNg sINJUSAPR UL 9¥I] PSOPUNOS JI PUB dJOJaq YIOA MON PdJISIA IDAOU PRY | WIdY} plo} y “URWEYyURY JO AjIO SIq dy} 3as OF OJ O¥I] | PNOM MOY OU PIYSe dY PUL SUI O} UOTJUDR Hoy) pauiny Adjjjor pue suv[siy "SYDOM MIJ }XOU DY} JOJ SuL]d Joavd) INOGe UOHeSIDAUOD SUIOSUO JOY) UO UT pauajsi] | SY S83] pure jJooJ SIU ASeSSELU 0} UBSdq PUR AdI{Jor MO[3q yes | MOU Aq SUINOI 3y) O} Pasy) “SuIy[e) 34) Op Wey] Ja] pue WOOL luRd}s dy} 0} 1OOP ay} pousdo snl | ‘aye O} UOISIDSP JeYM JNOge pasnjuod OS "UMO d1ay} JO sdiyspsey POMOPUS MOUY | YOIYM UMO AU UO } OxeUL O} SUIAI] MOU UIOIJ sIBdA Auevw Aep duo jo yoodsoid dy) yim Aeme xem JO ‘Ayrunyoddo Joy spesoul AW oped) pur Jojo say) pardacov Joyjia | ‘Aep S1q @ sem Aepo} Mouy J ‘Jovem daap our BulsuN]d sem | JI Se YJeoiq dssp & SUT[eYXd | aOJaq JOLIUW 9Y} UI YOO] ISB] SUO BUIARH “ulseg sjqieU ay} UOdn pooeyid | YOIUM ‘aiid yeou B Ul Wy} Pap]ojJ pure WOJIUN AW JO INO psssoJpUN | “UIdY} uIol 0) OUT BUTTIEME LUOOI Wes}s oy} Ul Apeaie Jam Ady ‘poyedionue Ajdaap 3ulaq Sem [BALIe AU SISYM WOO! dy} 0} YSNOIY) pue aseosie}s Burpesds series ayy dn ax1y Aw uesoq | ‘Wool adesseUl dy} UI Sireysdn DUI JOJ SUNIEM IdM [JOMXRIJAL “SPY pur ulojsdy “IPL SW Pjo} ay JOOp oY] polomsue uenr udyM swy SIyy “ALosty AW Jo [Id B 0} UdAId PRY Ady} SoUvYO SUINOJI] B UL OUO dy) 10J UONBID0Idde jsodaap Au pey Ady} JI se ]29} 0} Way) poyuem | pure joadsol Jo udIs v sem AyTeNnjound surpueyssJopun ‘DIP SABMIL | SB ‘UOOUIDI JXOU 9} SUT] UO Ss AdIpJor 1 BUIALUY "WI POAdTjaq ATjemusAd | [HUN YBnous suoy JpasAw 0} Burd] dooy sem op 0} pey | [[V oWnNuesur oy} ur Aouowl pood Suryeul pue sty} Jo yno uorssayoid v SUIATONSI SBM | Jey} sdoy oy) YIM S}YsNoY) dsOY} psyieq | ‘ulese I9AO PUL JOAO PKdY AU Ul JUDAS 91NUS SY} UO SUTSSSIGII JYSIU SY} JO Sol ay} juads uayy ‘sinoy Jo aydnoo ze ysnf 10} OOPS-00T$ USoMIDG dIOYyMAUL BUIYVU SEM J JE) ORF OY} JOJ [[e SuryjAejd justAsJasqns Mou M9y} Suloq pue Apog AW dunytuqns podkofua | dy!] 19k ue UO Ind O} pRY | “MOT OS YUIS JJ9SAUW 39] P[Nod | MOY UO PosNzUOd [[S IYSIu Jey) sWOY JUdM | | “Igyeom dU} Syt] adueYyd uvO sdiysiouyed pue sdiyspusyy sayy “ajdoad jo sadAy 879 $0 OsGebed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVIENACLINOS OMIIVAY PIyIIOF | WTWATOD | |

The text on this page is estimated to be only 39.12% accurate

68T FOOT AAAMD SE Wg Ul 9UO 94} UY] JO{}BWUIS PUR “SSoULVdIP 3Y) JUSDOR 0} dfqIeW YoV[q Ul SEM UOO] SY], UlOO] WUed]s pUe }9]10} “IaMoyYs UlO[pe Usado ou) OJ WOO] dy) YSNoIY] WY MOT[OF 0} StU poUoOydaq AdIJJos pUe “SsoUIDAep sy} 07 isnlpe 0} SdA9 ATU JOJ PUODIS B YOO) J] ‘sode yIep dy} 0} SUIT} UL yOuq poddays pey OM AI] Poyxoo] Jy] Joquieyo SuyUNep JoyjouY ‘WOO! WT] ATWIp SIY} OUI POx[eM IAA “991 B O} AoUpor Wy “WYSnoy) | ‘ayenbope MOY *,.Ued,, poy 3808 9])]1] AUIOY dy} JO onje}s URBEd ozUOIQ B Aq BuIssed ‘WHI] Uspjos pue pos jeAos & Ul pajodues [fey BuO] e UMOP PoyeM oAQ [IND SOU ayi A[UTKIIIS Ng “asnoy 941 Ul IT] AJUO BU} },USeM J] ‘dO} Oy} Je SoYyoIe 9y} Moysnosy) SINd s1eYyose YIM oNbUe ssesg JO INO Speul seM J] ‘JOOYSS oy) UWA SUBS JV] [VUIBLIO §_]I DAI] POYOO] YI] OUL “SUIT Oy) 0} SUT Surmoys ADAJOL PUL “SLIRISUMOP BULOT SURISIYH “19Y4IIGO}] [Je SOO STY JO] IAA, ‘Ppoxeal aq 0} SuTj9edxa sem ay MOY ATISIIDId DU P]O} IBY] YOO] B SWI SABZ OYs ‘s19Y JO ULB AIM Jey] YIM PUR PUIMUN O} SLL} SUIOS 9SN P]NOd dy 341] POYOO] sy posse sys ‘sinoy a]dnoo & Ul yOeq 9q P.dy PUB WOOI SBeSSLLU SU} 0} SLU MOYS 0} BUIOS sem OY SUR|SIYD PjO} OH “OW UOTBXe{dI UMO SIY JO 9WOS PopadouU puke ye} [Jeuis YsnNoud pey Adyar DIOJOq JOD9pP pipudjds dy) INoge d10WU S}JUSOU! MOJ B10} sxOdS ]]B SAA “9OVJ SIY UO YOO] PleY 9} WO] dS]o sIDYMOWIOS AJSUULOP SVM PULL SLY ING []ed sUOYd dy) WOT] PSTLLIOM W9dS },UPIP 9H] “SIIVYOULIE BY] JO 9UO UO ]L9S B YOO) pue sdaId oJURUI OY] 0} }xOU SUTIIS DIM IM DIOYM KJOS 9} O}] ISAO poyfeM pue dn suoyd oy} Suny Adsyyor "][eM OU} UO Btu v OAL] OUI 0} payoo] ‘aA0 pojeoystydosun ue Oo} yoryM Ss, Arjsadey Ainjuso ,.£ | 94) JO 9UO Jnoge AlO\sTY ay} at BurT[A} *J[9SIOY 11 JUSUTT|AULOD 0} 99U9]UDS-PIU JJO SLU IND oYs USYM ‘s}USWUIOpe J9yJO M9} & pue Soijsode} Suryoo] [IAd-plu 34} UO Jay payusuT|dwos | PIP Ht FY} SADTIDG 0] SUOAIBAD PdJURM ays ‘I9Yy 0} pasuoTeq A]JeNIOe JL JO 9UOU YBNOY] udAd ‘JeO]F 0} PSAOT ays ‘osnoy ay} jnoqe SULY[R] SBM SYS MUX J] “DAN 0} diay Au jo re} OS JysNOY) | YM OW poyse OYS ‘Ul SLURS BURISTYD ‘Udy LULY JOF SUIEM ][NS SEM | “JO []e Aq papulyq sem | ‘ot punose Ajnvaq ou] Jo [[e UT Surye) SurAofus oytnb sem | ‘PUI 1 Uptp | pue oy] ssautsng papunos yey) [jeo suoyd v opew oz] “OJIT SITY UT SUOAIOAD OJeTNdTULUI 0} AOUOW pue ‘YIeom “IaMod SITY 9SN 0} PoxT] 9H “YUL sy) sem YOINYS siy ysnoylye “eweyq eq oy) pue AdlpJof YIM DUO UDAD ‘19YJO YOR puNoIe ULL Ue YIM JO ‘puey Ss, AdIpjor SUIARYS IOyIIE SoINS [AOI pue yeotyOd sfqeziusoooI YIM solNjold sus OS[e d1OM S94] “poysyes wiy duidsoy Ul pore] | Jl Spt soy] Jo suo 0] }xau pooeydai AjIsea 9q plNod | Zulsassns ‘sainjord snoroeyes ul sursod ustuoOM BuNOA ‘s}sonbuods nyNesg s,AdIpjor JO WOW pajyuneyy yey) oueid pueIS 94} 0} JXOU SITEYOULIL OM) YIM VJOS B pu dddId BTJURU B SEM D19Y T, "NO PUL OJ SWIOD PjNOM | SABM 13YIO UI SOWISWOS JO “OIMRION] SITY YIM SINOY SUWIOLU ATID BY} UL PIOJLUOd SEM Puke ddd[s 0} Prey }I puNoJ Ud}JO TVILNACIINGS [euaweypy pyooioig yySuAdoy D SOT POOTUAANIO Se a] SB ‘pedal O} PdAo] 9H $YOOg Jo sMoOI Jo doy uO smo Aq dn usyv} 919M sooeds [JBM SUIUIVUIdI 3) pue ‘s[[eA PojBAd]9 9Y] Jo sLied polaAod UMO ILI} JO S9U0JS SNOLATOSE] PO} ey} Saadesp yuslouy “‘qIyxs wnasnw e DYI[ SOW PIyxOo] HW YSNOY} UdAd “Sd1JJo Sty OUT USM | pue AdIfor s19yM ]OA9] 1X3 9} OJUT PSAIN Jey) aseoitEys Surdaoms Sty} 0} WILD | Udy], "poyeoo] Osye 19M [VY BULUIP pue UdYOTY JOULINOS SIy dJOYM “TOOL ISI dy} YSnosy) peoids sayl} djquew posojos jaureiey “soejed siy Jo 1opusjds 3} 1e pousjsijs s.oAd AJA “SOUSNJUI [|e JO JSOUL PUR INOUIRTS “YIBOM JO wyvol e O7UT Sdajs d]QI9M0D ay} dn poyemM | ‘SN SUTOOPIOAO BIOUIRD B YUM WOId]UI UB SBA 3194] SIOOP UdPOOM BuIyOo] AARSY 9U] spIsaq pue ‘adueIUS SY} SpPIsINO sojAoGIEsd OSOUTYD ISIE] OM) 913M JOY T, ‘YJIS SNOTIDISAU & SB WY JOj I IYSNOg JOJUDW pue pUsLy 1s9aq $_AdIJor ‘IOUXO AA SO’] [WUN ‘ode sesh Aueul s.A0qg JOJ [OOYIS avalg B 9q 0} pasn J] “90uaTNdo JO sdt10}s JY SIO ‘uRWeYULPY Ul OMIOY JsoTIL] Oy) SEM DOUOPISII Jo sovld jediouud sip ‘ueyequey jo opis jseq Joddy) oy) Ul poalue 3M “AIBA, puke UYOL SE UMOUY 19M LILJA] puv ULNE UdAY “SOWLU UBDLISULY OJUL JFVIS [eINI[NS-1yj/NW SITY JO SOU 94} Ud}OYS 0} Poy] AoLJor “WusdIap JEJUDLIO SIY JO BUIYJOWOS JOJ poudOYsS Ajayi] JSOW SEM SWeU SIH ‘sn JOU Of-Of JOAUIP 94} “duysiy steal S,AdsIo¢ MON 3e ]RALUe INO uody) 9 1aydey,) “WHY O} 1} SULATS UL SeHSOY 1, Upynom | “SuIYyJoUOS pojuRM oy UdyYM OS ‘MOU spuRyY STY UI SeM dIN{Ny AY] “UY SuIBesseul pej}s pue y1OM 0} 199 O] SUL pdJonjSUI puke yeas PoUIfOoI dy} JO do} UO J994 DIRQ SIYy payser AdIJoLr usyM UMOP y9eq JYSNOIg AjJURISUL SEM PUL UIGed dy} 0} JORG SUED | UdYM YSIY [esInjeu & UO SEM | ‘JJO 9x¥} BY} JO MOIA DAO S_PIiq & YIM YORAM SU 13] pue yidy909 34} 0} dn sw JYysnojg sy Sulj[Yy) 9JOW }1 9yVUW O} pue soko AW UL JUSWIOZEUIe OY} MPS AdIJOL Jd]10] Sururofpe ue YM yoeq ou] UI USYDITy & SEM Dd] PUR SOYSIUTT UTeIS poom poysIjod YM Joyjes] od19q JSOUIF 9U} UI POdOTSAUd dI3M S]LIS SY] “9q P[NOM JI POUISeTUT | Se YSTART se SEM J] UIQRS URW SU) OJUT poy IVY) SsedITeJs SY] Ie SN pojoois oP] “osea ye [99} NOA apeUl APJULJSUT jy) IIMs sISOUIS AISA & Jhq ‘sdoj AYU] BuO] pue drey Adis Autys pey oy “Joyid urew sty sem Aue ‘jof youlq s, Aosper uo popseog [je OM SI9YM JEW Ik} dy) UO SN PoyIODsa sia [puLY sdeddN] sy) pur Hodiry sevaAug ,soyoseog Wyed 0} | pue sueysiyy ‘Aojor SAOIp uene “99UDNOUUI AU JO ISL] DY} PIP OS ‘03 Ja] oy Udy “JJl[o daojs & JO 9BISA SY} UO SeM | d4I] Sulpay “AYSN pep Aw possny | “Jd|Je PIYOO] UeY) DOW dq [[IM JoyYPNep siy yey) WY dINsse pue spuLy sty SAeYS 0} JOY] AW YIM JOU 0} SPISINO Durw0d usad Aaddjor “ABMOALIP 9} Ul SpIsno sddq-poos INO pres 9AM “SU JOJ JI JO IV 94R) P.sy 879 $0 Tegabed ‘0€Z8z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD TVILNTOIINOO (eLiayeL payoajorg wy FWAdoY [J

The text on this page is estimated to be only 43.15% accurate

TZT POOL SE § AdIJo¢ 0] UINIOI P[NOM |[ ‘SSUIWNO AW O} PILMIOJ ISOU! Payooy | “oury B JB OS 10 NOY Ue ATUO IOJ AITO BY} 0} NO BULINIUSA “9q P.] PIRES sURISTYH SP ‘][@O UO SEM J SABP MJ }XOU SY *[O1UOS I19y) UI Jodsap ow soe]d 0} Jay Joy ABM B sf sem }I [Te Jae popsou UDAD J ,USEM ] OS “WIOOI AT 0} SUI PASSIUIsIp ays pue ‘AjISOIOUSS 1OY 1OJ JOY poyxuLyY) | °,.NOA pulf sAemMye ULI OA OS ‘MOIIOUIO] SUOU {[39 B NOA 499 [[IM 9M\,, UONPSIDAUOD ST} O} UOISN{OUOD JOYS &B YM UORURTdxd AUT JJO ynd oY “A]SNOLIas Woy) YIM qof Aw dye} },UPIP | JULY) O} Wid) JURA 7, UPIP | “AITIND Suljooy ‘ozisdorode O} poyeys | ,AdJJor JO} [Jeo UO sJe NOA ‘sown [ye ye ae NOA sJOyM MOUY O} P9du dAK,, “,, Ape] DuNOA Suo] OS 9u0S us0q SARY },UP[NoyYs noA,, JU PAp[OOS dULISIYH ‘passiul sem pur s, AdIpJor 0} YOeG poyfoNs | “Avy UO PAMdYO SARY [JAM SP IYI | POOF Jey} Vd 0} pure d}e |] YM Suryoiem Jaadu “[43 Auurys Aypemnjyeu & sem | “Joyo yeuosiod s Asjor Aq poAlos auisind AyyRdY dy} payey AT]BoI | “YoOns 10 S_peyes njo) pue vadyorys § Adljaf 0] yORG SuIOD SEM | SULIOPISUOD puk ‘pey JOAd pey | 1S9q dy) sem jt ‘ezzid 1uoladdad jo dorjs juers e@ Aofus 0) JJo Suiddojs s10J0q 10U jNgG S,Adapjor 0} yorq Suryyem uevdsq | YSNp UY O} poyie}s 1 UO A, ‘uvyyjodoatu snoiedes siq) SuUo;dxo uNy YONU OO} Buravy sem [ (00) pauuryd pey | se Suiddoys yonw op },upip | “‘uonus}e Aw yYysNed Jey} JopuoM AldAd JO SOJOYd BuryR) JJO sem | pue vowed sjqesodsip v Ang 0} sem dojs jst APY ‘OJI] JO SyTeM 3 [Te JO spsnq pue opsny sy} yim Asnq Os soevjd & poutseUult I9AduU pey | “IOpusjds ul yorq pojeed urese SOUO d1aM Sado AJA] “AVA ALU UO S}YSIS [RDO] OY} 99S puv HIeY [eIJUI_ jsed s}ysij ay} MOTOF IsNf p.| IYsNOY) | “YSU JO Yo] ‘uIn] OF AeM YOIYM Bap! OU pey | “ONUIAY UIE UO J99I]S ZL JO PUD BY] 0} 303 | USYA\ “YSOP JO PLOj SIy} Suipuads y1e}s 0} a9e]d v JO} SuUTYOO] “D A'N JO S}991}s 94} IY Udy “UO dn-ayeu Aut ynd pue Suiddoys ,.Ajt5,, JoJ possoip jad 0} sureysdn ued | "JL D1] 0} POwssas dy Ing “ABM JayjO AUB UL JOB O} PpO dq PjNOM HI ‘oIBUIUI AT[BUOT]OUIS AT[BOI JOADU 913M IM DOUIS ‘Yd9YO JU} Ul SSLY B WUTY SAIS puR JYyS yap ul [eonbs ow Suryeul ‘SOULS JUS 34) [jnd Moy Isnf MOU 7 “STIG JeT[OP OOTF popueq sy} Jo }NO d[punq &. dU popuey jsnl ay] sl SUIAIS SeM OY YON MOY JUNOD },UPIP oH addy S8tg au) 07 dij jsay InOA SI yt 9UIS Aep dy} JOJ GUISOS1YSIS dWIOS Op OF Plnoys NoOA iYSnouj | SpIsul poydo] Sulog JO peajsut os “Aep DY} JO JSOUL JOJ DDIYJO 139YJO AU Jv JNO 9q |], ],, AdUOU JO [[nJ deq jayjnp sty pousdo ay pure jjvo ouoyd eB Surpus jsf sem oY SOY “ASIP STY O} J9AO pay]eM J “J9}Ud 0} DUT JOJ paypeo Adajor pue Joop sele ApYy sys oy) ie poy7o0uy J “SSIUI O} prey JO PULY SEM jI “OTQNO]) OU YIM DOJO SITY OJ YoRq JJOSAW JOS | ING “UNIS JUSIOUL SITY} UT ISO] 399 0} SuIOS SVM | PalLIOM SBM J] “UL pdq}1Es Burjos jsnf sem | ‘JfasAul 0} JYsNOY) | ,,APBdIPY,, “MOU SOO SIY Ul DUI 99S 0} PoJUBM AdIJJaf MOUY OW BUIIO] Pleulosnoy ke sem JI pue paq ay) 0} }x9u suOYdsya} 94) UO pozznq LUODIO}UI OY} ‘ATSTLIE By) O}UI TVILLNACIINGS JPWITEW P9901 1 BUADOD [] OL1 FOOTUAANID Le SUIZEC “UOTSINEp IIMs oUO UOdnN poaseg sduLYS Ppnod sty yornb Moy ynoqe SULYUIY) “puNose SULyOo] Av] pue peq ios oy} OJUI paduinl | ‘porsasal joe 0} SARY O} punose ouoAue Suravy jou ‘Aep Sul]feiqjus AW Aq poyiox| “SSOUSNOTOSUOD AU JO OF 1d] | PUR Jd] PRY | IYSIS Jo iq Ise] SY} PosdAod A[JBULT SUI BULIOTJO SEAM OY S[AJSOJT] S_AOIJOL WOIZ 19}}1[3 9YI JO []V "SMOJIId pUR IOWOJWIOD poloyieVd} 9s003 YIM ‘poq pezis dupy edny B pur A‘] B SEM IOUT “OINJVOj Sv [eM UTE dy} UO ASade} o1199 JOYJOUR pey pue jured pjosd ut pou sem WOO] sy] ‘“owos Aq ul padejs u39q pey Ino pulj pynom Joye] pur ‘Ay[eAOI Joy YJ WOO B SVM J] “SSUIPUNOLNS AW JO DOUdOIJIUSLUL OY} UI YOO) soo AU pure [[ey Suo] 94} UMOP poyyeM | ‘asnoy sjenbape uv Jo dZIs dU} “JJO] DATSSRU STY} O} JOOP at] pousdo | “WOOl AW 0} SUOTIEIIP SIY YOO) pue jJf1] dy} UO ¢ JoquUNU py J ‘POPSoU UdYAM SUI JORJUOS URS OY YOIYM Ul WOdIAU! Ue PRY jt ‘Ys 9} UO SUO ISI DY} SEM WOO AU PUR [OAD] ]X9U 9Y} O} OF Stu Pjo} pue JJl] OY} 01 SU poxTeM S]{ ‘JONPUODS O} SsaUISNG sUIOS peY dy SUI Pjo} oy puL JOMOYS B UJIM POPNOUO) AQ “JUSTUYORe JOAsU “AQUOW YIM UONeIOoIdde SITY PAMOYS df] “Y[2} MOTTId ooms JO ‘sossIy sBUINUT ON “OUOp sem gol AU puv YyVdIq JO SOAVdY JOPNO] 0} JYSNOIG UOOS 919M SUBOLU JOS SIP] “Sjadped MOU SIY Sulssoid sem 9Y PUL SALIP 189} B JOJ JNO IBD MOU B SEM J J] Se ‘poluem sy JY YIM PdUIIOUOD A[UO SBM SY “SIOBUL] SIY YjIM SOpIsul Au Sunjeqoued ‘ysay Sunod Au padois spuey sry Joysew Aw Suisvaid ITTY A “YOM JSP] OY} JOAO TYRE] Ud9q pey | JY poyerjiul pue oinjsod dy} YOO} | ‘JaA Udyods splOM ON ‘PpooyURU 19919 sty UO jnd Oo} pueYy AU paqqeis pure ‘1dA0 pouiny dy dyeds siy 0} 108 | USY AA “TUTYy odesselu 0} SUISN SEM | SAXONS dy} JO AfaunsSI9] Oy} pue JUdWOLU JO ssoujoNb oy) ayerooidde 0} paulsas sy SB ‘POOL Siy jNOge JYsI SVM | SUI P}O} S}OUT)SUI AW ‘Apog siy dn Aem Aww Suryeut ‘syusuisAow Moys Au AOfua wury 3uIq}9] ‘\UO]IS POUTeWdI | OS ‘JeYO spl yyIM poyiydn oq 0] Spooul asoy) jo oUuO UL}, USE dU []91 P[NOd 1 “9dUaTIS ay} [lJ OF uUeTOq saruOYydWAS [RdISSETO POXIW JO UOIJD9] [09 B pue Avy] jy | ‘INO Jas 919M SUOT]O] PUP S[LO 94} fo [je aay ‘yoINy [TBM ayy uo JaAe]d G7} OY) UO WIN) 0} SLU Plo} Puv psq dy} UO UMOP AP] 9H “WOOL SY} JO S[PpPIW oY] UL poq odeSseUl O} papeay dM Udq) ‘passoipun Avs 0} SUI poyse sy “opnu [JS YJOQ JJO pop Jamo} pue jno 109 JAA ‘Pog dy) UO adeSseUU sIYy JOJ Apeos SEM 9Y Pres ay “soyNuUTLU dIOTU MOJ B UIYJIM puUv SOATBD STY 0} dn poxIOM | ‘UONBIASTTE JO Vapt SITY SEA SIY} ‘UI polod Wed}s DY) SB [[BM SY} JSUILSR YOEQ POUT[OOI puke POU B.YyyIM aU }W UMOP poxoo] oF ‘porysnes uewi sty} dooy 0} ware uo AyJUeIsUOD aq 0} pey | Sulmouy ‘JOurSuI JO NO Joo} sty poqqeas | ‘poysiuatdoai Sutsq $I MOL} POOTG INOA UdYM SdeSSLU & BULINP JBI SEM YDIYM “ULYS INOA WO SUIXO}] 9Y} BJ9/dap PyNOM wvd]s dU} IVY} OUT SUIYILd] ‘UBd[D BUI[99} PSAO| OH IS1lj WIOOI LURS]S SY] OJUI AdJor POMOT{O} | pue PassoIpuN Yyjog 9M “MOU 0} SUILIOD SEA | URI SIU} 0} OPIS UdaSUN JOYJOUY “} 0} [9df AIDYO]IM UMO S.JI PRY I yng ‘yoReog 879 $0 cggabed ‘0€Z8z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aseD TVILNICTANOD [CLINT pornos, YsUAdoN |}

The text on this page is estimated to be only 41.77% accurate

ELT POOTMAINID OV ‘QIN] SIT WOT adedsa P[Nod I9Y DAI] OUOSWOS UDA JOU puke ‘9a]) Aduow § Adljor JO Speys sy} ASPuN [Te sJoM 9M “]]K ]E ples JeY T°, Jt OP 0} BUIALY StU JJO sunssaid aq) soye) 1,, A[duus porjdel ays gp[nom siouyed jeULOU dyT] SnNoyvol SuIyo3 pue drysuone[ol snowesouoOU UOWUWIOS B BUIABY JO PRdJSUI “LUTY JO} PIP sys JkYM pIp ays AyM ‘oURTSTYH poyse suo ] Arsuny Suro8 wo Joryo Sulareys ATTenxas Ino Jo syedde ay} daay 0} S]IIS OIOUI Ul SUISULIG Ul BURISIYD pople osye | Inq “][2d UOydeq SIy 0} UT ] p[nom Ajuo JON ‘sodjoy ayy] Apuey sty auiooaq pey | SYJUOJAL UITPI A, ‘Op 0} pajoodxs sem | 1eYM OJUl JYSISUI ysnoud out sAv3 ‘ATPIO}NG Bulyeoy e& yl] [41S 0} LIS WOT WIT yeses Bulyoyem ‘HOeG Buliq 0} 9)se} JOULISIP S,AdIJJof¢ 0] WIOJSNdDB 0} DUO OU SBM ajay) ySnoyry “sjs dn suiryoid ul sodos oy] swt MoyYs 0} duIOd sem YRIeS pur “SUIUTeS JNO? []B SEM JYSIUO} ‘PoyIAUT sem YRLeg AYM puR JYSIUO} jno sures am AYM MOUY | US) pue Jsonbol @ UeY} JopsO UB JO sIOW SBM Ve ..g BUIUDAD OY} IOJ YORQ Bulg 0) SUISOI9}UT OUOAUR SI 3194} JI das pue SJdYy qnyjo iYSiu dy} WY OM NOA },UOp AYAA,, ‘] puke YeIeS O} pres ay “s}oOI}s Oy} ySnosy) WU UT We ZuT]]oNs 9]dnoo oBes9Av oy} poyxOoo] wy pue SURISIYH alyAA “AWed Jouurp JO JUDAS SWOS SEM I SSazUN “Usty ysed Jno poAens Ajoies Adijor pue wid ysed sem jt WYysNoy} | ppo “[jouNs e IOy 03 0} SOUIBE }S 0] JOAO AL] B YOO) [Te 9M D19YJ IYSIU Ise] SY} UDG “Woy plnoo dy dSap [NjIsny spqvulseun AOA AdIJo¢ SULATS ‘JUSUWIOU 3Y} 0} paJOAap SEM SYS ‘pudsyosd 0d 0} prey },USeM JT ‘J pue Jay “Aodljjor yim Siaqtueys JWALId YJ UT SUIT) O} STIRS I VAY pure ‘UMO} UT sem OY USYM WY 0} WAY) SULMDAIOP puv JustUdeUS JOY OJUI Sp Sunod Surmnsd01d ye jsaq sty Jo duo sem ays yey} AjaeALd atu po} Adjjor ‘sayol Auuny pue euosiad [009 Joy YIM asea ye ow Buyyjnd UdAd ‘pIp sys JeYM Je POO SEM BY “XAS IOJ uy Sunune} ‘jood SurmuwiMs oy) punose oyjeg pure opuu dins oyx1[ ssuryy Op pjnom ays “wily UO poystar] sys uOUs}}e yduwod Joy YIM JusTedde OS JOAd 1 SuLyeu ‘tay paplAoid ay dfAjsojl] OYJ 0} powoysnsoe A[SNOLAqo Sem ays ‘y"’] Ul gol Suyoe uve 308 Jay djay 07 Burda A[pssoddns sem ay pue ‘pey | wojaq Aaljjor UMOUY pey sys ‘dunjeu AyYoaYo & pey Ys pajuiy }8Y] Sd9AD UMOIQ Bq pue IIeY OpuoTq Yse suo] peYy aYyg “Yeses poweu ‘roluas All sivoA MdJ eB [IIS Ayoid e 0} poonpoNul sem JT “DAN 0} Yorq SUIAT] 1OJOq SABP MO} & JO sn UTOL 0} PURIST SY] 0) INO SUIAT] sem [ITB ev ‘Aepyy.iiq Au Jaye skep maj Y “Ysnoy} Ajryeod pes v ur Suryol Jyey ATUO SEM SUS , Ul OU oped) O} DALY P, ADIT] UOOS pu ‘d}Sk} S AdIJJOL OJ P[O 00} BuIjad UOOS 9q P_],, ‘ples pue sorpueds jo Avie AU jNO MoIq | Joye ayol B OPRUl SURISIYD “UOpUO'T OI dn-dyxelU JOUSISAP JO UOI]D9]]OD MOU B pue avo Aepy iq & UdAIS SBM | “‘BUNRSIUIOJ JOJ a]Nadde sty se snouwloUS Sv SEM O39 SI *.S JJOf IS SPIT,, H [Jed O1 POyl] oY ,.d]S] SOweRG 1S,, 0} }XOU UBIGqHeD dy] Ul puR[st sIy UO AepyUig ,,9] Jooms Aut yuads | ‘snorssuos Sulyyeq B NOUIIM SUOSLUOS BUIODIq 0} 9]qGe 9q PU INOY }xOU Oy) UIYyIM pousddey TVILNACGIANOD Jeu] pops1ely 1ySuAdoD O ZL1POOMALANIO 6€ yeYM 19310] pur syjid maj e aye} prnom | ‘soe Sulpessep wwiojiod 0} pey | UdYyM OS “SOOO 9] G19} JOAO JORULTG SB pojoR Os] }1 ING Ajoixue yyim day i pip ATuo jou *,.xeuey,, poyfed j9[qe) Ajotxue Suta}][e-pulu v 10} uondioseld B YIM $,10}90P dy] JO JNO pay[em | ‘oUt UONsanDb },upynom ays Os ‘AJa}e] BuNIOS udeq pey | Soydepvoy dWoOs Jo} yuoWUIOdde s_101}90p B OUI SALW O} WIOJY AW poyse | ‘YOvog wyeg 0} xorg 103 om VOY ‘AJOIXUL YONUI OO} SW SsNed 0} FSUIUUIZEq oJOM peey AU UI Sapeg SY “UDdAIS SUIOG SEM [ soutunjroddo ay} Jj [njayess oq 0} J[asAwW Supa} sem ow Jo yed Jayjoue puv ‘SUIIYM [BNXS STY 0} JUSTAJOSQnNS OS 9q 0} JJaSAW apLIdap 0} SUIARY Jo} wy Suey oul Jo Weg ‘porduwios j ‘sAemje sy “sup pajuReM ay yeyM A]JOVX9 MOUY 0} dU Bulyd9dxo ‘paq odie] sly UO UMOp AB] OY pur UOIsUeU -OB1e] Sty Ul YO] ISaysiYy 94} 01 dn ow YOO! 9H “WY O} JO} poos sem ] 72yM Apoexs ow Moys 0} pajsissod oy peoysul ‘y[e} snoiadid Ino wo4y dn POYIOM OS JING ‘UOURSISAUOS J9YJOUL 0} UO AOU PUR YIM IDAO 9q 0} SIU} ZuNUeM ‘pays pue peppou jsnf ] ‘s}o]sul AjANd spuolq puke sad9o onjq YILM “1OOP 1X9U [IIS dy} OAL] Poyxoo] Jey} JoyYsnep $,duOAIDAD pojueM 9G Ayjeoiseg ‘soinynsoid Jo ‘sigsn Snip ou ‘so1yjos Jo ‘s,Bursaid Jo sooner} YJIM SIZ ON ‘UO puke UO JUaM jsI] OY], “URL JURT{{IIq posoddns e yons 10} Suryury) Jo ARM populll MOLIVU AIDA B “PULY SY O} JUIOJJIP SuiyjAue JSUIVSE JSIOVI SEM OY ‘SPITS URITIOWY-UROLIJY OU ATATLUTJOP jg “WILY Aq pajdaooe aq 0} snoa3s03 Ajanbrun oq 0} pey Asy} pies ay ‘uondeorsed ONSTUTANRYS AIOA B ‘S]ITS JBINI[ND-1[NW OUT 1 USEM OT] JO} SUTLFOO]T se dy S[II3 Jo pury Jey Jo sopod oy} [edAol 0} poyeys oy “JustUseIse AW YIM po}oxa ATJURISUI SEM JY [[9} P[NOD NOA ‘Od B II DAIS pjnom | yey} WUIY pjo} | ‘Joyseu At aseajdsip 0) SuueM JOU INg ‘Op P]Nod J Buryjawos ay} punos }, uptp ‘Apoq Jay JO} pasJopua aq 0} A[UO ‘ouO]e UOSdI DUO JO} S[AIB dn Suryord nq ‘[413 Ays e sem | JeU} JON ‘odoy daey AyUO pynoo | “sed Aw wo ured yon 00} YIM Inq ‘s[eUepeld aBessew 919M sjoodsoid Aw “ol YM Zulop sem ay JeYM ApJOVXS S_JLY) UISS 9A ,P[NOM | SLU} 94] J DAILU OS }, USEM J Jf, JSILF OU JOO DUIOD SI OP 0} SARY Ast} [PY “Way djay P{Noo ssoq INOA ‘ppiOM puRgsny Yo 10 ‘Sulpopotu “Burjoe at} Ul syoeJUOD STy YIM pur syIts [nNyWNesq ‘SuNOA Jo] 91se} e sey OYM ITBUOT[IG-H[ NW B JOJ YIOM NOA Woy} [[9} pnom J ‘wot Buq 0} Aouow Atu pue way} Q01]Ud 0} WURYS INOA 9sN p[nom | NOA 919M | J],, ‘UOSSa] JO PUTY JoyjouR oO} dn pying & ul ples oy , [[9AA,, G29d8uRNS 9)9;dUIOD B 0} BuIY} B YONs asodold Ajyemjoe duo Soop MOY WIY poyse | ‘J pue Adljjor yy sjoe yenxas pur JeNXas-1q Ul aBeSud 0} ADUOW YUM popensiod JoyLINy 9q 01 s,AdTJoy 0} YOeG PUIOd 0} Way) 9dUIAUOD pu spd ANoId JOJ YOO] pynom | Fi “suryewu sem | AQUOW dU} 9]QNOp dye Ppnod | ‘oul Joy UOTsodold Mou ¥B PRY Aaljor ‘yorag Wyed 0} YoRG Surlpesy oq 0} 919M 9M JIOJoq ALP 94} UC ‘sounjuoape AU 0} JJO 9q P,[ “AW YJIM POYSIUL] Sem OY USYM PUR SIIISSp [VILX9S SIY O} pudi}e O} UOTSURLU 879 $0 Eggabed ‘OEZ8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TWILNTCIINOSD jeLiayeyy poy104,[ IBAdog 7]

The text on this page is estimated to be only 40.89% accurate

CLT FOORELINID . “TWILNACGTIINOS PLT POOTALINIO TVILLNTCIINOD [ela parss1osg wypsiAdog P jersey, popojosgy WyTWAdaD [| | cV LY jeai3 sem J] ‘YINOW Aw punose Bur-sn3uo} Aut Yor 0} poou yueySUOd dy] SPA 913y} Udy] pue pUNoIe sem yey} Auny SuryyAue jod 0) SuueM jnoge WIY YIM payol UdAd puke OW ABS HI SBUT{SJ SIIOYdNs 9} squosap 0] POL] | “UlOUIL] USAD P[NOd duo Buljsaj SuIzeue JSOU! SY) SEM FI YYsNOY) | pue ‘oo} Ajayey] ASejsoo UL Suljqqep Uuds0q pey | WIY pjo) |] UdYM Ss yey] “OSESSELU OU) SULINP UMOP DOR] Pojeis oY ,JedIT YOO] MOUY NOA spits oy) INQ “][9Y Sy! SuPj{oo] puke JNO Sungyjs [je oq pynom ssnip uo uosiod eB WYSNOY} | ,, ‘soussoId sTy Ul I Noge yeads way) Suresy posn Aoy) ssp Jo sodA} JUsIJOJJIP ay} Noge suoNsenb Suryse poweys AdIpjor “UY JOOW O} UI JYsNOIq pey | Sys Ayred oy} ‘spusty AW JO SUIOS JNOGe UOTVSIDAUOD B dUIARY d19M 3A “UOOUWIJe 3UO LUTY 0} SUTATS Sem | Besse Be SULINp pYUN ‘Jord i day ] Os puswjAog be SUIARY SUI UT Adl[Jor We]e 0} JUBM 3, Upip | “pustjAog puoses Aut SB pOpseGo1 | IVUOIT{IQ-L[NUL Sty) YIM ABME OF SUI JO] P[Noo OYM UeUI B ‘POAIOSOP | JBYM JOS | puv ‘YIOM O} SUIARY JOU PUe dPlI say B ‘payueM oY JRYM 108 OH ‘[9dJ SN 9peUl SJOIJJe 3Y] SUOIJOWIS ByRJ WOI] peppnq YOIYM ‘JOURUIOI POoNpU-STp & JOM SAA “OU PUY O} DJOYM Pue SUIOP SEM ] JBYA ‘UMO}] UL YOR SBM | UWIY PauOyUSW 9A. pynom Asay} puke 9[9110 ysty-so1unf ino WO] Sp1I3 Sy) O} UdYOdS 9A .PINOM sy SUTYUILY UdAd JOU ‘out Suryovosdde uo juajU! Os SBM OY Jl OUI JNOe d1ed YsNW 9Y “WYysNoY} [| JOOMS MO} “PJOS Sem | ‘UdIO OS AIDA3 LOOp Au ye Suryaouy yday isn SY OW JO PlOYe 198 19A9 0} J]QuUN SBM 9Y INQ UMO}] UT YOR SBM | Plvdy pey aq aul po} sy usymM pure ‘Ysnoy) sadd UMOIQ BIq PjO SWS dy] PeYy 9H ‘soud’T oedny ino Suyooys pue soyjoyo Addoid suresm dn pouevslo sem oy MOU ‘OdAj JOYDIOI FULYOO] PIBY SY) 9q 0} posn 9H “WY USES PRY J SUIT) }SB] OY] WOT YONW OSs posuvyd pey oH [RAL SIY JO Sxd9M OMY UIYYIM ‘Apjasoas “juaupiede AW OJUI SUIAOUW USA “OJl] AW OJUT YOVG POULIO})S (7° | ‘PUIMPIIYA @ UT pue © [11d 100p MOA Jomsue AT]BUY NOX -poy AJ] YO,, “sjuozed Argue Aul 0} YORQ OUI PdlOAT[Sp Udy) “AemeUNI B SEM | INO SUIPULJ SUIDINOSAI SUIOS PIP Ady) [OOYSS ul },useM | AYM pauonsanb pure sinoy [ooyss Sulnp soywoyjne Aq dn poysid sem | pHUL) Wysiu oy Aejs pue ysnosy) dunf prnos | puke MOpUIM Siy UO YOOUy 0} ples ay [jepysiu yy ‘wool sry ur Aeme usppiy ow ydoy oy “duryjou sjusred sry DULI[9} “SAep MO] B JO] 9SNOY STY ye Avys SUT Jd} PeYy oY puke ABeMEUTL B SEM ] UY MPS | SUNY SE] OUL ‘fp ‘PUSTJ pooypyiyo puke ysnso ystp-so1une AU SEM }] “UIESE VOY JDAD 0} SuLdIONUR },USeM | BUO SEM Add BY) JO DDIOA SUL §.JI Si OUA,, JOOP poso]d oy} PUIYSq WOI] Poyse | “dOVJ IeIpIWIe} 9DU0 94} 9ZIUTODOI J UpIp pue sjoydead ay) Ysno1Yy) poyxoo] | ‘Yorog wyeg ul QIOM OM TIM UOCOUIOe AZe] OU JOOP JUDTULTEde AU O} OTIeD YDOUY VY ‘QuOp 303 0} Gof eB isnf jou UONOWS OU poMoOYs Jey) pue pusLyAoq AW ][@9 pfnoo | sUODTOS ‘O} DTUOY SUL0d 0} DUOSUIOS popsou | “SurAyess jou sem 1 ‘ATTeNxaS 0} pusne 0} Ado pey | YFnoyyye ‘ouoye sem | o[TyM Aep suo SuryoWos poziyfeal | “ayt] AW TIM Surop ATTeNoe sem | WY jnoge AUIY) 0} AdIjor Worl ARME PLY 9A, P|NOM | SOU) dy} UOISN]]ISIP 0} euenfiew pue ‘proe ‘stjid Aseysoo Suisn Ayjenjusad ‘prey surAyed sem ] ‘Jaiseu Aut 0} JURAIAS BUIARId },USeEM | UdYAA “UOISSIUTUIOD Asvo se Udy} AMPS jsnf ] ‘spudliy AU SUISULIG UDAd SEM | ‘MOT OS podoo}s | pur a]IyM B 10} Surssiwl uom yvoy Aw ayy Au ut jutod sry} yy 00} Addyjor youl ued Adu} JI SULYSE UDAD Wy) JO sulos ‘js1des9y} oSesseU B duIDq A[UO JNOQE WOU] PJO} | SOI] ay) 9AdTI9Q 1, UPIp SpustAy AP “Wt SuIAO] pue oF Aw au0AUR UeY} AQUOU SIOU ZULYRUI PUB SOTAOJ] UT jNOQK pivsy AjUO pey j Boloury ul soovjd Aueul os Busses ‘AIUNOD oY) PuNOIe SUIAT} SEA\ | “SdNUp YIM pojusuodxe OyM sia JOOYDS WO $}9e]UO0S pPjo yA dn suyjsaw USAD ‘SOUI} JO WIRdIP & [je SEM JI DAL] MOF MW “xBUBK BY} 0} BuIA] B YOO) ‘| ‘J[JP@SAUL PO} | SOT] ay} JO JJOSAW GULOUIAUODS JOYJINJ YON|Y ‘Sadesseu 10J su pojueM ATUO A[pasoddns oyM Jayejpuesis AU aq 0} YsNoua plo Ue B YUM punose Sulpjoaes) SuLop Ajpeal sem | JY MoU [[P Ady] SULYUIY) DUOAIOAD DDBJ }, UP]NOd ysnf |] “WWdy] 99S 0} poou v AjpieY SBM 9IAq] “OD AN ul JuaUede poystuiny ysnjd ev se [JOM se YoRog wyeg [eAoy ul jusuede ue ol Sunusl Ado PIM pue Joyjosoye Apiwue.y Avo wor J[oSAW poouejsIp | SWOY Je ApOJOJJ “SOILIS OY} UTYYIM “WY YI DOYMAIOAD ou Surye) Addey sem Aoyyor se ‘Jappey oy} Buiquurpo AjMOjs SEM | "XOS IOJ S}9e]UOS SARY SABA\TL P|NOM Y “UI P9Ar] SY §,A}ID OY} JO 9uUOAUR UI 9JaM JY Ji OS ‘quam OY IOASIOYM UY YIM Jdoy oy Aleip Yorlq a]}1] B ul SjuauAed pue SOWUBU JO S[IVJOP SJUAD 9Y) SUIPPe d1OJ9q SARI] O} SN JOJ IBM Udy) PjNoM IP Joy SuIsuLq 1OJ OUI O} OOPS Pue [4G MoU dy) 1OJ OOTY JO JUdWIARd B YM SuIpuq ‘dAJSqO 0} WIY JOJ SUNIOXS SIOU! OY] [BU sunjpeu ‘s[JIs Sn UO pasn dq prom SAO} xos ‘suOIsed9O WOITdx9 UG “payojem oy ofTyM SuNeqinjseus isnf Jo “sn SUL[PUOJ WIY YIM SOUITJSTUOS $}OB 91}0I9 WojJiod prnom om payuemM oy Jey UO SuIpusdop JO J9y}0 Yors BuIssry LR]S 0} SN ][9} Pfnom ay ‘AYs Bulag JOADN “WY YIM podeys | sivoA Aut dU} Ul UMOP POUT) IOADU SEM SH ‘PdJURM dy OS[9 JOAD JBYA\ OP PyNos pue ayood siy ul way) pey sy Mouy Adjor USY) “JVY} 0} posse Ady} JI pue BuIYy}O[O INO dAOLUAI 0} StURd SUOTIONSuU! SIy [HUN WY SuIdessewu OJUI [IS B ZUIPRoy OW pue poxeu Apeole 3]qQe) odessew sy} Jo do} uo Ad Jor YA Jno wRys ATSOW pynom Ady], “YONUW poiojjip Ajases SuOTSSas dU “Ul dU Mau B IYSNOI | SUIT} YORI IOAO []B YRS pjnom AyoseJary JO UTLYS dU} QUITTS 0} SUIAI) S[IID JO 9]9A9 OY] SNY) pur s[itd Joy} 0JU0 JE} 97e19}191 0} Gof AU MOU SBM I OU POUIe) pey suRISIYy ayy] sn L taydey 879 $0 vegebed ‘OEZ8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD |

The text on this page is estimated to be only 41.51% accurate

LLEPOORETIAID bY ‘O} SU pajyonssul pey Adipjar se Jay odesseul 0} URSoq | pur spqeyoyiuo0s S10 JOY axe pu AJ} 0} SMOTIId a4) poIsn{[pe | poq oy} UO UMOP SUIAT "SIY JO aNnSevdTJOo AU][VIM B O} JJO PSILIVU SEM PUP d]SP] SI] JO} pjO 0} Ua}05 pvry }ey) Ised sty wUlolJ sodeInojus AueU s Adljjor JO 5u0 pue [OPO JOULIOJ B SVM SYS JYSIS SNHOIPUOM PUR sNoTNoRITU B SVM JI YSNOUS Ajosuess pure ‘A}TUIOeU JO SdTeIS 1Oje] SY} UT ISY 99s 0} SUTVUTOSRJ sem }] “Ud9S IOAD pey | Apo JuvUSoId PoYeU JSIIJ SY] [RSAdI 0} PossoIpuN sys puke WOOIPdg Jo}svJAy dU} OUI JUSM JT PUR BAY UsyM Yep 193 0} Buluursaq ysnf sem }] “UI OF [99J AJWIJ 191Z09 B PRY ynq soru A][eoI [[Ns “Sunoadxa SBM | D0e;d YSIAR] 9U} WO AJO Jej B SEM PT JUSWIede JOY] Ul Poarue | usu A “Avadoid SAisud}xo $_5]0Y JURID OY] JO SpIs [eUSpIsol oy) UO Way} punoj pue UdAIS SBM | SSOIPpe 9} 0} XB} B YOO) | ud USAVS PUNO jy ‘uoyeyndal sty Suripjoydn ul Aqyiqisuodsal Jo 9)se} JSuly ALU Pu SPUSLY SIy O} INO oUt JUSS oY GIOJOq UOTeIedoId Jo jI1q \sey AW sem }] ‘jposuny Aoyjor OJ Op | sxt] ISN “poyueM sy JoAsyeym ATJORXd YM Ud]F eA] 0} AdJor AQ Payovod ZuIdg SVM | SOLOA JO 9U0} poziseyduo ue uy] ‘got noy-InO} eB 3g 0} SULOS SeM }I DOUIS ‘OPeSSeU S_,Ud[H Joy Ad19ua AU JO [[B SABS O} PUR P9qqn 3q 0} s}URBM sYs dJOYM AUT Jay a8esseul snp ‘gol siyj oye] | poysisul AosjJor¢ Inq Aqeq uoqun sy} UO SULOp SUOIM AUK JOUJUL O] JUBM ] UPIP pue [aM Jey] Apo sy] MOU },UpIp Ajjvol | Suiog ‘jueusoid sem oys plesy | UsyM pawioduod oyInb sem | “ABM dq) UO 9U0 YIM o[dNoOs polueU ve oJom ASU] “BAY PUL Ud]{H 199 0} JIOYM SSOIPPR SY] PUL SUOTONSUI SUIOS UDATS SEM | SOLU ISI JOY) Ploy ATO "SJUDT{O JAAD SIT} AU SUNDOL dq PINOM | dJoyM ‘S JayxVIIg OY ‘WYsTUo} yorsg Weg Ul [dJ0OY SAISN[OXS SY} O} BULOS 9q PjNOM | PRojsUy “ow pasiiduns ay ing ‘asnoy SI 0} JOAO SUIOD 0} [[vd [eNsN oy] Sem HI JYsNOY} | ‘Addjjor Wol [ye suoyd ke poatooal | usyM JUSUTLeEde AU Je SEM | “AYM Jno ond y 0] Su] SW 9k} 1,UPIp I] “OUI YIM UOISSaS BULLEN I9yJOUR Op 0} yoRq POWAUL SBM JYS SOY AA “SULLIOW SULMOTIOJ OY) Ul JjosIOY JOJ ul ysidesayy JU} peyxoog pue Suiod sem Suluies AW MOY BUNySe SeM BYS “I9}e] S]JUSUIOW sURISIYH Aq poutol 1am OM SK SOULYD OY] JOD IOASU | Ing ‘owes Advioyy, adesseyy dy} Noe Used] 0} SUIOD S,dYs JeYM JNoge suolsonb jeuosiad Moj B JOY HSV 0} poyueM | ‘UNMS B JOJ UTede possospUnN | pue Joy a[TyM s]jvo ouoyd moj ve SulyeU Aoajjor YWAA ‘dip [009 eB JoJ Jood. sy Aq jno wy Urol 0} Aoryor AQ PoIAUT YJOG 3JOM 9M UD] SILIJOP OOTF [ensn Aw pred sem | pur ‘Jom se oul ures) 0} Surdjoy Joj poipuny jeuowyippe UB SIRT[OP OOES Pled sem SYS UOISSdS SY] JO pus 31 1y “S[euoIssayord a13aM Ad} YBNOY} UBAS SySe}] SuIpessap yons Jsonbos 0} s[s}USI{O JO PUly SITY} joadxa 0] uoIssajoid adessew oy} Ul [BULIOU SBM STY} JI JJoSAw } UONSoNb 0} URSAQ | PUK ADOYS Jo d1RJS B YONS SEM }I ISI JV YW SASI[9q 1 ,UP[NOD | ‘Ayleuosiod Jay 0} apis Joyiep yon & pue Apog apnu [njIyNeaq Jdy [VSADI O} WHOJTUN 3}1Y4M JOY TVLENACTINOO JCUaeP] porssjo1y FYSUAdOD [2 LT rOOmMATANID cv BSUIAOUWAI JSIdes9Y} SY} YM SUd0S WIOd SuTAR]d-a]O1 B JO JNO BulYyjatUOS OAT] Poyxoo] 3] “Jsanbal sty ul aepISoY 1, UPIP 94S “WaIp]IYyo OM} JO IayOUW B 10} Apog onopyye ue pey pue Jey spuoy]q ApIno qyIM S.Q¢ Ava Joy UI uvtuom Ajjaid B [MS SEM aYs ‘BIIO}LIO oFe [eNSN SITY sAOgE SeM 9Ys YSNOY} USA ‘JYsNoy) | otueYs OU pey OF “UIYS JOY SAOWAI MOU 0} s}stdesoy) dy} JO oUO yse AdlJor IVdYy 0} PoyooYs sem | UdYM ‘UOISSIS 91} JO sul yound oyj yoyem 0} ainsvayd uMO S,AdIJor 10} SBM ]] 9SINOD Jo SsoyuN OSESSLUL B JOJ YSE O} OULTSTY IO} O1eI SLM HI SULOQ ‘Jensn se jusIdise/ oy} Adljor YIM ‘UOISSOS SULUIEL] JOYJOUR JO d|PPIU 94) UT SBM |. ‘UleSB UOIPOIIP B peYy pue Soyosn| ayi Jo yno dn JjosAw poyoid pey | SyI] Woy | “SurAes oJoMm Adyj yey pue Apog dy} Noge suds YONU Os SpeU [[e II “SSUTYORS} Ilo] JO OMB UT SBM ] 00} 9]9}U91[9 UMO IIOY} YIM JNq syeyUspso YIM ATUO JOU ‘sisIdesayy OBESSEU BUIYIOM [P91 JO a]dNOd e& 0} oI poonpoMu! Adipjor ‘adua\sIssod AUI JO Syd0M JO a]dnoo kB UIYAA “Opis sty Aq owt dooy 0} ued J9\seUu sty Jo ped jye sem jt ynq “Asnowoes wiy yy gol Aut duly] sem | yey} WHY O} JURIW }1 JYSNOY} | “SsoUdAIIASse AU Pox] oy Pue uldaq 0} Bulod SPM SUlUTeI) [B31 AU USYM “BULUDAD BY} 1OJ IFO] | 91OJOQ AoIJOL Poyse | ‘[BALAINS JO d01nos Au sv URL B UO SUIPUddap WOIJ 9d1J DUI JAS AT[ENJUSAD P[NOM yey] uoTedns00 ue pojuRM | ‘J{OSAUW JO] poyueM AT[Pal | YM JOU S_jey) jnq ‘ofly AU UT UST OM] IM Asnq JosAw pey | OS “uOTSsodu BUOIM ayy Aoyjor SAl3 0} Jou purul AW Wo qyINd Jo syysnoyj sy} adim 0} pey Ayyomnb | nq s[qi119} OS TOF | ‘CL Noge ow sinus sy] SurUIYy], “ow Jo OpIsul sinsevojd YM opoydxe wry jo] pue 91qe} 9Y) JO do} uo UY pajppedis ] }sonbal siy uody) ‘sovjd si Oy) Ut 9194] USA A][VOI SEM | UOSROI A]uo ay} ‘pey sAemye jt AWM OWS 9} Ul POpNjouGd SUIUSAD 9} 9SINOd JO ‘oyor}eoy YUM JoJUNOSUS ;eUOSIOd UMO SIY peY P,dY Jl J[SSAW 0} PoJOPUOM | pue Aem yeu yeods wiry presy | USM pousyRsy-sip y1q o]NI] B Ng ‘Jorfol YIM Ud}ITUS Sem | ..69q 0} NOA JOodxo | pynom AyM ‘snouredouow SI P]JJOM SIU} UI BUO OU ‘JOU dSINOD JO {SNOLIs NOA d1V,, “PNOT No Ysney] oO} pourys of] , ANS sty} 99s 0} payejs | Jf papurul nOA JI SULISPUOM Sem | puke UNY YIM uss savy | NOA YIM BSUTT[OALT] UdEq ] ,UOARY | US AA ‘ATO}LT 40] B Jno Suiduey usaq savy aM pure ysed Aut WOIZ DUOdWOS JO peY J,, durAvs Aq ponunuos | ‘1943030 ssurg) jnoqe dn sutusdo a4aM AYM I]9M,, “SUO] OS JOJ WIY WO YI 9y} Idoy | IVY) ISIOM UdAD YOO] pyNnom JI Udy “19}7e] IY) JOU JOYIeI P,| Jae] UY] J9U00S JNO SWIOS 0} puNog seM jI DUIS “fT NOK qILY BY) LUTY [[2} pue JoyNy Iq B 1 Yysnd plnos | WYSNoY) | Os ‘JayI990] ysNe] Pood v SUTARY JOM 9M SE WHY SUI{JO} SEM | BUIYAIOAS YIM ABXO POUl9aS oY pue dJOJaq paduatadxa Joaou pey Addjor sBury) jnoge uoiyesioauoo uodo ue yons Surry 8179 $0 GEsabed ‘0€Z8z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TWHLLNACLINOO JELIAZEYA) POISON WYBUAOY £

The text on this page is estimated to be only 43.06% accurate

OLTFOORRELTIAIO . TVILNACIINODS SLT roOMAALINIO TWLENATCLINOO Jeo ep porss1os| WySwAdoy jeLuaqey poyaaosy wSwAdoD () ov v ind 01 sum AyySus] SUIOS seM SIO], “yseO] ye padoy | ‘ayTTYMe JO] syoo poo 19y ur yOeq ou Ind ppnom 31 1YySnoy} | ‘jaredde ueipuy sero] tow Aur yonu Moy Suimouy pue Ayrurey AW JOJ YdeQ BULIG 0} Sd}qeID9T]O9 Aytu Maye dn suryord ow WA ‘YSnoy) diy prpuoyds e [Ng “setroyes j1B [voo0] pue ‘Surddoys onbijnog ‘suINasnNUI oy!] SJOTU SBM J} SUISAS }YSIS USM OM UDYM OS ‘ANS JO PUY PROI JJO JsOUT dy} J, USeM AdIJor ‘Suldas JYySIs pue Suiddoys jo 1q e Joy onbienbnqyy ul sjoyxJewW UeIPUT dy} O01 1UaM 3M ‘YOULL DY} UO S11) INO Sulpusds Ayoinsio] Jo Skep May BADLY ‘puel usado pue ie Uvd]d YsSo1j oY] Ul NO OWI) SuIpUdds 0} PIREMIOJ SULYOOT SEM J SSI[IYIOUON “SJLODIOAO OIJULBIS SSOU} Ul Jd{[BWIS UDAd payxoo] sures ayed Au ‘ae OY} Ul YSU [JUS “TYySIpop e sAVM]B SEM DORIL 34 ByUvS Buidsul-ome siy ie sINOY Moz ev ATUO UI SUTALUY ‘pouueld SB ‘SUIUIOLU SUTMOT[OF SU} Jd] [Je | pue Aww ‘oueysiyH ‘Adjor "reo ysaty Aw pyosAw Ang 0] noqe puv YyS¥d JO SpeoO] SUIARS SBM | SB JBOD SEM }I “WIY YIM Sd] punol ssay) 0} pasn sem | “DAN 01 Udy] puke SpuvMIJO]e SsoUTSNg SLUOS JOT WT] OF dojs 11d & SULYBU 9q OSE [JIM OM SB ‘SYIOM MO] B IOJ YOR,,, Ul MOIY) 9Y _juauiede Au 0} yoeqg 19d | Se UOOS Se poyoeRd 4935 [],] JEOID,, IOIOA AW Ul []4142 YIM Pdullvjoow | “asIOY B JO YORQ dy} UO Suid OJI] AW JO SoLOWOW ySaq dy) JO swios yuloduid Ajsouoy pjnos pue ‘pooypyiyo Aw souls JOP asioy psouaiodxs ue uddq DAY | SOPH ley Auew Aw Sulnp ul DP] 0} PIAOT | IVY) Je YSU pue sdojUleJUNOW PoJOAOD MOUS 34) pey []HS }I PUL IOJUIM PjOd AIDA B JO pUd 9} 0} dn SUITIOS sem J] “UIeLId} Udo oY) Ul Spl B JO} OF puke SdsIOY [NYNNedq SLY JO suo UO dn s[ppeRs pure sa[qeis 94} 0] UMOP SdxI1q penb dy} JO SUO 9yk} P[NoOM | dW] UMO AU UG ‘POAl] Spuvy youel pue siadaoyosnoy oY} D9YM sosv}O9 afl] pue ‘sas1oy Jo [NJ sojqeys “yor pue uose}s oy UMO S.]F YIM UMO} STI] SIY SEM [BIL JO SIWIOAR] AJ] “19}JVUW 1, UP|NOM ]I OS “Jnoge poled ay SSuty) dy) 1, UdIOM SSOY] MOUX 9M JNg ‘T[1y ddajs e dn OF 0} SUIAT] 10 Sey 0] Suro3 J9A0 duo Surddy JoF popjods JOS usjjo | pue yeses ‘soyrq penb dy} UO SUIT] JB913 B PRY | “SUISeLUT ATUO PjNOd | soURSeARIVXS JO SCULLY aU} [je pue ‘wAS ‘jood 1ooput ue sey 3] “ALodoid Jo saloe QOS‘, SATSUd} x9 SIY PIYOO] ISAO JY} [IY B JO do} UO d]}Svd GUTYOO] URSUBLID}IPS|] YSIAR] B pey dH “SoUdpIsal sTYy JO [JV JO s}TOARJ AU SEM }T BUIOG YOUR Sit Jv ou Sulpusds padolus | “UONLUNSSp JUdIOJJIP B O} spRdY sy sJOJaq Jayyeom jS9q OY} UO ALVT JOTIA SIY YIM SYddYO oY ples 90U0 Aalfjar “JUSsWOW 94) jo ands 94) ut Suraevsy poaoy Aoy] ‘IYs1uo0} Apeos pue poyxord aq 0} poou P.[ Puke SUIWIOU 94} UT ODIXdJAY MON ‘94 BIULS Ul YOURI STY JOJ SuIARI] aq Pjnom oM SLU plo} oY sle}s oy} dn juoM OM UDYM “YsNOY) sUYY PoWses dy A¥Po} Ng pooul siy 1VdM O} SARY [[B PjNOM dM Udy) PUL SUOIM BUIYIOWIOS SEM O19} SSOIUN “FIOM SITY YITM UOT 00} YOO) J9AdU OH “aSessew SIY WY SAIS P]NOD | Os SsouIsng Sly Ystul 0} AdIor OJ SuIEM SVM J Spaq asuno] pods a1yM pue onjq sysop [ood 94} Jo 9U0 UO jNO BULA Sv ‘ABMY POEM OY SB JVOIT SI UMOP adeiz ojclnd ev Suimoly) ‘soyyo ay} 0} yOeg popesy oY d10Jaq ‘Ud yoINb v SUI SARS OT] “OU YIM pasedid uy} SIOW 919M S$ JUST[D ATU YJOQ JUSPIJUOS aqinb wile | pue sul Jo poyse SuIyyAIOAS PIp | UY PIO} | “osoJoq IYySIU DY} [JOM JUOM SUIYJAIOAD Jl OUI YSe 0} sued 9Y yng ‘adr1jyo Jood apts}jo ST] WO] ssouIsng SuNONpUOS ATJsoW sem Adljjor “WHIMS B Pue Youn] 1431] v 1OJ UMOP es puL poysonbal se wd] 1e s19y] awed | “SjoJUST]O Mou AL YUM SJUSAD S}YBIU JSe] JO spivjop AIOS oy Surjoodxs oq P, Ady) [Jam 00} [[P BUIMOUY “UOISSdS SBVSSEW B OSINOD JO PUL WIMS B ‘YOUN] 1OJ UOOWA Ye jyeY} UOISURLU S$, AdJJJOf 0} JOAO SUIOD 0} BUIWIOW 1X9U OU] Po[[Bd SBM | | “Addey wry dooy 0} SUOT]EIJSUOWDp AU UI poseayd JoyNy oq ppnom oym AdljJar 0} yorq 03 P[noo | MOu pur 919M Soljnp Aul jeYyM jd9909B 0} peY | Jey] sem yey) MOU pure Ajyoinb os popus osye pey ii ‘poyes [fe pey }! s41{ IsNE “oJOY} JuSds au Aw Joy ow Aed Ajjenjoe 0} 9u0 oy) oq pjnom Aaljjor yYsNoy) usAd dij o31e] ve ow pied oy pue possoip pue dn jo3 yjoq am “poxeLuijo pey oy UdY AY “SN Spisoq WOO! 9} Ul Jdays UdIPyIyS pue afIM JUuBUBoId SsIY apryM SIU} JO ]]B SULOP S]QeLIOJWOD OS SVM JEY] URW SITY} YJIM SSINODIOIUL BUTARY sem | ‘APMP UNI puke PUlW AW OSURYd PpNOd | SJOJOq puw UI SUIWIOD idoy¥ sysanbal oy} ‘parjdwos | Usy AK “WIYs AW YIM Surjieys say}O[o AW Jyo dye} 0} ou paysanbol oy ‘SUI SAY OY} Pip Ad’Jor oy] ISNf pue qof Aut 0} OPIs 134} dy} UIZSq 0} Apeos SVM OY USYM MOUY OUI JO] OY UOISsas oy} Jo pus oy} 10; Buredaid Aypeyuopy “YIOM Je pley [TVS sem | 219y} U9}}03 pey [ Joye SInoY IMO] ApIVaN “sAoi1ddesip 0} Woy) UBM } UPIP | “S]UdI]O JOA }S11} AW BUIDQ SITY) puv Io9IvO B OARY 0} poJURM |] YOR SU PjoY ey} 39] } UP[NOM | ING JOOLJ sy} UO ssessvUl O} SNONUSIIS SIOW YONUW JL PUNOJ | ‘dn pus 0} 3ULO3 sem SIy) oIOyYM MOU Apeole | ‘poopul Ays jou sem oy MOYS 0} SSOUIDBVd SIy WIOI] puB o[IUIS AYIOYO B YIM por[dwoo op ‘oSesseU SY} UISAq 0} JOAO [[OJ 0} WIY poyse | ‘pooyuRW SUIMOIS IDA pue posodxe siy YIM oul Bure} spreMjUOI BuIA] “oSvssew oy} Jo uoRsedoid ul UMOp dijs 0) uRSaq oY se No pooRid Apeolye pey oy Jey} punolsd oy} UO SMI MOIY} B SEM SIO] “ALP OY} Ul WIY 99S 1 ,UP[NOd | SB ..{aull asNndxq,, JNO []BO 0} peY | S19YM UIOOI SBUNOT OU} UI OW JOJ SUTPTEME UDTH puNo} J pue UdIPIIYyo Suidasjs dy} 10j JNO pou} usoq pey sIYyS s.jUouede sy] | "JUDITD IoYyJO AU pUuly 0} JUdM pUP “19 GINYSIP 0} 30U JF Se ATJUDT 1OOP dy] Posojo | “}I JO pus dy} y@ JYST] 9Y} INO Winj 0} oul Suryse ‘doo[s 0} OF 0} JOAO Po{[O1 pue sdessew dy} JO pud oy ye Addey AIOA sum SYS PIeS SYS “SIY] JO 1YSIS AIDA 3Y) }8 JJOSAUWI 0} 99918 Jnq djoy },upjNod jnq Joy SAdIJO1 0} PyNod | JS9q AIDA ay} Sulop ysonbal Joy Ul 931]qo 0} BUIAN) sem | ‘ABM yey) Ng ABM JOY}O Aue 3ulMOUY JON “ABM [NXOS -UOU B UI ‘S}SBdIq SUT][OMS JOY osESseU 0] OUI poyse UdAa sys Apog SpNu JdYy YIM ased je OS ‘A[MO|S pue ATIOS 879 JO 9gGebed ‘O€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWINDOg ‘898Z-8T BSeD ©

The text on this page is estimated to be only 42.75% accurate

181 FOORRTAITO TVILNACIINOD O81 POOTAAANID TVILNACLINOOD JeuoyeEP] pojsaiosy yy SAdo7 [1] Jeuayey) paroojoy,| 1YssAdOD [2 Sv UdYM PUL SoYyoNO) IdY) WIOIJ ULOT sul FuTYBUI SIN] Yoo) YIOG ASYL, "JUDAD UTRLU SIYy 0} dn pring oy} SuTYyo}EM SIM POOYUeU Sty BUTYAOI)S Avydaioj yeorpoyjour sty 01 dn sem Adjor JY] 99S pnod | ‘spremdn souels [RUOISLD9O UB WIOI.J “UOTIDOIIP AT UI YOO] suRISTYH Mes sys USYM 9Nd JOY YOO} ory “dutty sues ay) ye AWW Aq po[pUuo} SUlog SeM | S}SedIq JOY OJUT peay Att Surysng ‘syeod [[euls om} pue sins ysrpis Au SuTpeIAdI ‘onyye Atu UOWNQUN oO} ssp ALU YSNoY] siosuy Joy Surprys ‘atu Jo do} uo Jjasiay payenyis pue Aalpja¢ Wolf SSOIDB YONOD 19YJO SY} 0} SU poy pue dn dU poojs sys Adid Joy Suyuny ssouol v oy] ow Suryovoiddy “feodde sry Joy stuosog ajdtue Surdejdsip yys Jdy posaooun pue Aeme Suiqqni [[NS JOO} S$ AdIJJof Je SUIS SVM | SISYM BJOS dy} O} YORG poyyem ous “Avydsip SUIPIIOId § 1 MOYS 0} Ya9d SMOPUIM 9Y} YSNOIY) UOOW dy} JO UOTI9]JOI SY} UO PdTjdi Jey] JYs!] @ Ul SSOIPUN Ady PSYdTEM 9M SB WOO! SNOIQSUd} dU} Ul Dues sem usaios A’ Aidtus sy} woly UONeUTLUNT]I an]q 9 ‘pog 0) 1U9M SY d10j9q DOU 9OUO saBin s, Addo AJSRS O}] SN osn puke ‘ayejOLA “o]epNdiueuw 0} paas0id pynom pu J]ISI9Y S[BUBIS 9Y} PSAI9991 PRY SYS MSU} ] PUL LUDO dy} 0} JOOP dy} 9SO/9 0} dn 09 SuL[SIYH pds[JOl pey S}Ips1o dU} Jay ‘Sduty ye djvos sty udAd pue ‘spuRyY JO J99J SIy SuIqqnd 100/f dU] UO US 0} polinbals oq |[DS pynom | ‘sinoY OM] JOAO JOJ UO JUSM Wy dU} JI UdAd ‘aSesseu v osINbas pue su} UdAIS Aue ye puey SIy 19A0 ssed Jo dn jooj v doyd jsf ppnom off “SBM JI OWT] ISA9 JBYM JO 319M 9M DBM 19}}eU OU ‘ANP IOF [Ped UO SABMTL DOM IAA “ULF OU] YSNoI) Sursesseut daay ysnf pue 1Y43IU JeYY STAOUW OY) SULINP JOO} B quIS YJOG 0} du pue Aug payse Aayjor pynom sAemye oy Se ySNf “19Y}990} JNO Suey pue SWUOOI SJAOLU PIJLIO] SNOLIVA SIY JO SUO Ul Us [Je P[NOM aM asBd ]e SEM JUOAIDAD JEU} SJYBIU JSOW “OULUSIS INSTENIL & SEM J] ‘SIAOUW Pasedjal AJMOU B YDJBM O} LUOOL SIAOUW 9Y) OJUL JUIM PUP STRUT INO 9]¥ [[B IAA “OULU Yl] OF padjay Yyotym ‘JoUUIp ye SjLiids poos ut powises ApoqAIoAy ‘IOUUIP 10} UMOP SUOD 0} LUODIDJUL OY} UO FFRd 94} JOS | UdYM PoTHeRIs sem | ‘qny oy) UI d9aqs 0} Aemv Suiddrs Ayreon “}1 Jo ssoupnzoovad ay) dn yeos 0} Sunuem snl ‘puey ye JUDTUOTU yoINb oy] UO SuIsnsoj pue sojqnoy AW INoge SuIyosI10} “s{jId xeueyX Aw Jo om) paddod pure 193eM SurwMes}s 9y] UT Woy) Bunind Adyar UO Pasn | S[IO dY} JO SUIOS JNO 403 | “WOOIYeQ AW UT Qn) JURTS B Ul JfosAt PUIMUN pu xPjdI 0} SuluemM ysnl ‘poow Ayoysuejouw & ul sem | ABpo} JNq ‘SNOITQUSAPL SUTTISUIOS IO S3{QeRIS SY} 0] UMOP OF PjNnomM | ATTensn syT] ‘payURM | JOAS JeYM OP O39 pjnod | ‘deu e JO} JJO pue poses WIY YA ‘JI Jim OP pynoos | YM pue Apog AW IO} posn Sulsq 0} Yoeq SBM | ‘SJUDUTTJUDS DY) O19M OS “JOAO SEM BBLSSEU OY] USYM PUR oSTeId STY JW PIde[J SVM | “SHOOT 19Y} 10 DDULULIOJIOd [enxas vO} Spreso1 UeY] AEM JayjO Aue Ul SIS JUD UT|AUIOS 0} LUTY SAI, 1, uUSeM 1 Aes ATJSoUOY plnos J luly UMOUY pey | SUT] 94) Ul IN ‘SpIIS 9} [Te 0} sd1U ABS P.dY SUTYJOWIOS LY isnf{ sem jt MOU ONS IW] “poutedun Suloqg oSessveul B SULINp UITY asvald pynos yey} Aueut }, USeM S19] OU! PjO} puke [90 ppnos Aaiyar “JoA [eUOTssajold & },USEM | YSNOT] USAD PUR “YOM JSOT 9} Papsou Jey] svoIe dy] Spuey Au WIM ATUO 998 plnom | Sado AU asoIo IsNf plod J “UoTssayoid AW UI BUTUIE) OJUT [NOS pue JsvoYy At ind | ‘osesseU ay) JO SUIUUIS|q OY) BurAolus sAVMIY “SurLds oy) Ul Spue[POOM JO OL popuUlUtal YOTYM “s}UDIS AdvIYJEWOIL 1OYJO JO JOPUSAR] ATISOW ISN O} SW Pdy!] 9H “Spio pue ‘syYysj ‘orsnul ay} poredaid | apy Wem UTTY d99dy4 0} [2MO} USI JOYyOUR paqqeis | 19jUS0 dy) Ul pog asesseW oB1R] SY} UO SIseYydtus oy} duUIOR|d ‘sasnoy JOYIO SIY Ul ULY} WOO! Jo|[VWUS SEM I] ‘WOO! odesse SulUIO[pe §, WAZ dU) OU SIOOP YOUdIA OY) YSno1y) pue sdajs sy) dn payyem oA, ‘yeyy JO J4YSNOY) AIDA OY) ev Durysne’y woos sun Aue JOU Jnq ‘Aep duO Saiqeq UMO AU DARY O} DAO] P[NOM | ‘patjdas | .,os sdoy J, ‘Ssoug]jues Aul ye wiepsoR AjJUR}SUOD PjNOM dy *, ABPSUIOS 191{JOLU BUTS 8 SYVW I],NOA ‘JOUTJSUL [BUID}BWW AIDA B BABY NOA MOUY NOA,, “payorujsul Ajsnoradid se Sulqqns JO pedjsul ULyS SIY Sulped “WITY PdiIp [9Mo0} pue IOMOYS 9} JO JNO 493 O} WILY 10} APBOI S[9MO} 9} 109 | “SSOUJSOMS JOBYS AW Jo NO WY JO Bed SuLyR] SEM | AULY) WIY SuIpaj ‘WsuoUURL [NJtaayo B YIM ysonbal siy pauwojiod j ‘posodured pue painjinu oq 0} paou siy 0} pasn sem | ‘atu 0} AIBUIPIOUN SUTYJOU SBM }] “ISMOYS 9Y] Ul WY Yysem JUIOD O} SUI Payse pue 19}JvOIDy) ATOYsS Qny eds oy) Wo dn 405 Oo} ‘SUIPES] SEM | SFI] POPIS-aTqnop sy] WOI posnjuos SUNOS SLM | SBA JT IDAD TRY JNgQ “JOA JJO WOM } ,UpeY Al[aaou AUT yORJ JY} 10 ‘Bulog SULT} JY] JOJ SOOYS dy} PaT[lJ Jey) Joo AW SEM I OGARJ ‘S|IIG I9YJO SITY poyeod) SY MOY WOI JUDIIJJIP SBM Jey) SU YIM o7eYs 0} URTdq DY SPIS JdIJOS JURSIJIUSIS B SEM SID} INQ ‘sn UZBMJoq PUOg ;Ny}oa8dsa1 jenjnu e Jo pury Aue savy JOA 9M PIP SUBdU Ie} OU AG “UMOUY JdA9 D,] URI JSOYoU SBM oY IBY} Surdq ‘WY JOJ 393 0} }eYM SULMOUY J9A9 JOU ynoge suryol yids eB se ow 410J 103 pey sy ddR, YOU pue SduLea asionbiny SY) LO} UY poyuRy) | pue yWqPsnoq pey | SYIVUY-AOIUY Oy} JO 9tUOS pue wnasnuw dy} Jo sy0ds 9AQ ‘S}Of s.eds 94} OJUI POUI[OSI SY [IM JO9J SIY poqqns | eds ay) Ul oSessew dy) BuIIVIG “sd1ys In[q puke spnojd Jo surpias poelosap & yyeatopun eds oy ul dn unem 0} poyuRM Adar ysut.j “eds pure JaMoys ‘Jood poyesy JOOPUT Uk ST S104] WAS PUL WOO] 9deSSEU 9Y} ised ysnf sireysuMOp JYSIeIS papesy oA ‘Ut SuIAe]s SEM |] WOOL a}IsTNDx9 dy} 0} SBeq AW SULIQ 0} JOY POxSe pUk JOOP JUOJ 4) WB SN poyooid OYM spreulssnoy Aueut dy} JO 9UO 0} Surddoys Jo sseq Aur saves SY UOTOU Jey} YJIM pue sadesseul SUIXe[oI SNOW At JO SUO O} PIBMIOJ SULYOO] SEM 9Y yey} SUI plo) Adljjor pue ‘UO SsoIO] SIY pling 0} JYSNOQ sy PUR] dAISseUT DY} [[Bd 0} asoyo AdA[Jor UIVU SU] *,.YOURY 0.1107, 0} YOR JOT. 9A, "YONU JY} Udy) 99S 0) SAPY UDSAD } UPIP | Jey) A[[eioodssa ayey yon OS 0} UO ZUIPfOY Ul asn Aue das } UPIP | UONOOJIP JUSIOJJIP & Ul Sulpesy opty AU YA “[ pue SH]OJ AU UddMJOq SSPLIG dy) JOpUN I9]eM 9]}}1| 879 $0 /8Gabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 42.36% accurate

C81 FOOD TVLLNACLINOD 78T POOTAAINIS TVIENSCLINOOD jeuatpy] powororg 1YySUAdO> G [ruse poysajosy WySAdoy [) OS 0} payoadxa | ‘sAemye SB ‘TXON “OJT] [EUIOU & JO JRYMOUIOS Poy SUIARY [IIS B YM Ayperoodsa sem | OYM JO potuKYse seM | A][esOW “(YyoNs se) soUeLUOI PUL YIOM JO} PIP | LYM [IS & [[9} plnoM | s1OJoq AjolxuR JOd SABMIL ] Ja}9q JOTIO YoRd MOUY 0} BuIIj99 JO UOTJSIBAUODS OY) 0} UOTNQIyUOS AW NO YSIp Oo} WIN} AW sem jI Ud] ‘sdrysuoneyel souL\sIp Buoy Ul SUTADTIAq JOU ABME IV] 00} 9Bd]{OO & JOJ BULARZ] SEM OY OSNvSOGq PUaLAO Joy Yo] A]JUdNNI PRY SYS Pue ‘JUd99e JOY Ul 19] [[MS MIP JO Iq & PRY ays se soje}s UJOYINOS dy} WO AT[PUITLIIO SEM SYS “O10Jdq 1YSIu 9y} Wo SulAyed JO YSU pley sy} JJO Surdoojs [Ns sem OYM PUdTJ 1S9q Joy YIM diy peol e UO SBA\ SYS JVY] INO PUNO] | 104}990} JNO Durduey JO MOY JXoU 3Y} JOAO “Jo}VeW jey) JO ospni{ oy} 3q UY Jd] 0} YSNoud Ajjoid sem sys MOYAUR jNQ 938k} S$ ADIJJOL JOJ SaIfared 007 jI1q B isnt sem ays agdAepy ‘“WIY JOJ OSLIdINs B Se UO JOze] JOJOY Ino ye ADIJor JOOUI OF YORG Ady Buljtaui dn popud | ‘oq 0} dn paulen ussq pey | SB ,,]]Bo-U0,, Bulag SABMye ING ‘Aja}IB] MOU 0} 9WIOD pRY | suOTIEIDOdxO jElNOS ay} WOT] JOrol B ONRUSLeYS puke pozids un seM oYS Se “[IIS SIq} ow pey | Addey os sem | 1943930} 199.38 Opis B UMOP poxoNp aM se Ae Jay JO S9YO] Md} VOL BULIATJO “oLyD doIosVd BIWIOJITeD [eo1dA} INOA sem dYS Ng jeY] SyI] SUIYJOWIOS 10 BUL] SBA IL YUIY] | “Ppajoadxoun Os SBM I SB ‘gu Sadvosa oweu Jay ‘sod anjq pure ULYS SAILO ‘sdssod] SUTYSUNS USpjoOs YIM SUD} JIB] JOY Ul SISYMOULOS SEM SYS “diy peol ev uO YBno1Y) Bulssed SBM OYM [IIS v JOUI UDAD puk dJOdY} PUL 9194 BUIYIOI[D JO s}iq swos dn poyoid pue ‘umo} AzZ09 anbsainjoid ay] JO sjoo1]s OY) pour] yey} sonbynoq Aueul dy} punole poyyem | “AQUOLU JO puly Jeu} YIM Op 0} Ajuayd pul pynoo suevau Aw jo 13 e pue Aep oy} Joy uNy savy O83 O} yYsnous jsnf SPM JI PleS OH ‘S1L|JOP pospuny SAL OUL SAT OH ‘ld XISs puNose WOOI ay} Ul yoRg Jooul O) Suruueld s1ojoq Avp pood ev uly poysim pure ‘ysonbai sry dao 0} podijqo ueY) a10W SBA | “UNTY YIM Sunsow Aep [fe dy} durpuaye JO peajsul Suiddoys 08 0) Asuow awos ow dAed AdIJJo¢ Puv dOUdIOJUOD SY} 910J9q ISeJYVIIQ BuUWIOUL A[IBS uv JO] JUSM OM BUIWIOLU 1X3U 9Y 7 JOY OY) JB YORQ SIAOUI B FuIyoeM SPIVMIOIe PUL JOUUIP 1OJ JURINE]SOI BO} SUIOS ‘yyStu yeu) Aoapyor YIM No Zuny | “JOyIsF0} s19Mm om AVM oy) Isnf Addey UTy dooy 0} potuisas ]] ‘pey om JYM Ue] OW pojuLM | UOTssaIduT dy} WY SUIAIS Joao ‘Apeolpe o1om OM JeYM URY) sIOU! A]S}BUITUT aWi099q 0} WY UO dInssold jnd JOAdU | YONUI OS SUI Poy!] 9y AYM s_jey) YUIY) | “Wool UMO ATU O} YOR OF SABM[L P[NOM J] UOISSAS JYSIU dye] B Joye udaa ‘auoje Suidad[s poy] 9H ‘Spaq JUdIOJJIP ul Surdasjs ynq ‘sou [fe ye uado sioop dy} Suldady ‘stool SUIUIO[pe 109 BAA “SUIOOI INO OJUI popes PUL MOLIOWIO] SULIOLU 94} OJ SOBPLg USAIS 9IOM 9M [9]OY 9Y] Je PAALue OM UY AA Jae] Ulayy YIM dn jaour ppnom 9M sI9yM “cy ACN 0} yORQ IYSIY [BIOIDWULUOD B YOJeD OF AULA Puke sURISIYH SuIARa] ‘sty JO diy ssouisngq e JOJ BIUIOJVD Ul JaUIeD O} JJO Suipesy ‘19}e] sAep OM] YO] | Pue Adyor 6v ‘pey Apeolye om yeYM uvy} Wy Wo sJOlW Yon Joodxa J ,UpjNoos ] ‘Pay yIog OM Sa] Ajsazi] OY) Pue JoyjJO yoro wo AeMe juods out] Yon Os ‘JOA SJoulIed JO SpULY aSOU} },UdIOM SAA “JOOMS BULYJAUR JO (Ss. NOA -3A0'T-],, OU pur 3Aq-poos Aska UR YIM POPUD UOTJESISAUOD YL *,,[00D,, }I powsep ing sjqeidaoor A[UO JOU se 99U0 UY 0} 1 nd A;UaNbo]s Os pey | se .uep-iamo,, Aw yim ayAysoj1] Aw paydssoe yey) And @ Sursooys Joy Ayyeuod Aur sem SI] ‘9AIOS JOJ JOS pue dn posoyng 3q UOOS PTNOM | “QWT} SY} [Je OAL SEM YOTM ACME SBM T UdYM OU JNOge BuTyUIY) sABMTL SUM dY MOY PUL SU BUISSIW SEM SY YONUI MOY SIU []9} 0} UO BuI0s sploM S]e} SIY YIM SW 9Y}00S 0} SuNdwaye Avs prnom ay ,,Aqeq ALIOM },U0q,, "STY} JO [Je YSnosy) YINOA Aw 0} JUSWYOeHe sUOs JUIPsou “Os Op 0} J[aSAW ZULIG },Upjnod ysnf | Jey} “PIP | UeY} Jo0q MoU dy Inq ‘UdyeoIY) ATUsdo pynom | “Nod YIM 3 GUIPUD 0} BSO]O OS We J,, 00} STUOY ATIOS PjNom | SASSOLU SNONSPSIP dU] SuiuONUdW OSTY ,“ABME UW] a[TyM Sorted onuesis aso} MOI) pure SBnIp JOj NOA JOJ puryaq savoq | AQUOU 9Y} BuIsN oul JO Yoo] NO A,, WIY []J9} 0} UO BuLIMUSA JJOSAW 0} }YSNOY) | SulUDAS Surxejal AW JO} YONUI OS ‘Osnoy s,JUoIEd SIY OF YOR “NO WIY YOLy 0} pousyesly) pue suoyd ay} JOA0 wiry ye dn moyq | “yo oIMNyIUIMy Aut MOIY} S9WTYSWIOS 0} SARY UDAD PJNOM | peq OS i Suiysey) uy] pue Ayed oj soejd & se asnoy AW BUISN 19A0 BUIWIOD SPUdLY SIy JO YOIS OS SEM | “SLUT] yeOID B DULARY dJoM Ad} OAT] papunos suo A9Ad puk WIY pulysq Suijnoys ojdoad pur Burduind oisnul sem ody] “Yyooads siy Suiunjs puke sp1om siy Buyesuoys sdoyo sly JJO popunos Apeolye dH] ‘SUOTL Ul GUIALIS 9q 0} SW IOJ poyuol pey Aodyjor ustuyiede oy] Suruvsut ©, Aqeq sovyd Ino }y,, dw pjo} DY SEM OY SIOYM POYSe | UY AA “S2SIOU PUNOISYORQ dy} SAOge [| Jvsy Ajpaey pynos | suoyd oy} Jo pua Jayjo dy) UE “dn payord Ayeuyy oy uaym IDAINN9I 9y} dn Buey 0} jNOQGeR seM | SB puke NO Buel AjAvou suOYd YL g toydey. “Opty AWW Ul USL ayy [je Aq poyuroddesip Ajpeq Suloq 0} posn Sunjos Sem | SB [IBAR OU 0} 9q PINOM II Ng “OpIs [NJYIMOA AU 0} VONSDUUOD B JO JOS SWIOS UTEJUTRTU O} papssu | ‘SdTI]{IQeJoU[NA YIM [JIG AjjoI1d & UBY] SIOUI SB OUI MES OYM 3194} JNO SUOSWOS peY | AI] [99J O} SW IOJ JULIO OS SBM I] “BOUdTOpUOD JO} [L, Poy[eo | ‘WYStu oy} JOJ ssdjrenb sjesedas UMO INO O} Sunedaq “‘SuO] Ise] JOAOU Pnod Ady) seM UB PjO UL YIM Buldq Jo oe]URAPL AJUO SU} “JYSIU DY) JOJ SoId1OUD Jse] SIY POWOXd Adler a10joq passed saynuiw AjUOM] “soUdT[NpuUl UOJURM JOY OJUT SUIAIS pue sdo} pouodo Joy usamjeq sem peoy AW [JUN “spreMuUMOPp sl pasdin SYS ‘19 0} DweS 94} OP 9M J]LNUISU! P[NOM ays OO} Apeol sem aURISTyH 8179 Jo gggebed ‘0€Z78zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWINDOG ‘gggZ-8T eased

The text on this page is estimated to be only 42.07% accurate

S8T FOORRLLINID cs ‘dn oyetu ATituBy UMO SIY UO pase ][e SEM }I SUI PO} JH] “ULOIZ SIDJORIEYS siy 108 dy oJ9Y4M 0} MOYS dy) SUTWLIIO JO} OPI [VNIUT STY WOT, SuMAIAS Wy SuLyse ‘Uej YONIJS Jeys v OAT] pojoe pue MOYS STY BUIYDIEM PSAO{ | Se ‘Da}1OX9 OS SEM | “SN YIM Opt & Suryo}wo sem MOYS A’ .S,uosduits ayq],, dy} Jo Jaonposd ay} Surus0INH Ney “JOWSTA pajoodxoun uv sem sued oy} UQ ‘soJasuy So7] JO} JJO JOO} pue disse syeAtid 9Y} 0} USALIP a19M OM aye Apoys “Aqivau syxoO1 dy} uo JOYO YORI Je Bulyseq AljnyAeyd speas ay} SUIYDIEM “ARQ S_JJLYM SY] BUIYOO] ISAO Sjayseqpesiq JopMoyYs lURId INO Q}B OM PUP IYSIU ]se| posoddns pey | S¥ UOOUISTL ]XOU SY} JNO JUAM SAA ‘$p10901 SIY UI UMOP }I apelu pay]] A][eaI oy souo sy} AjUO jnq A}IO AIDAD UL JOU SY $}OKJUOD 9Y} JO YOO ORIG 94171] SNOWRJUL siy UL} SUQUM aquinu suoyd puke suieu 194 UMOP YOO} PUR DUTY MdY} JOF UOAIOAD 0} DABS OY SIL][OP poipuNy OM) [ensn oy} J9y pred oy SpIeMId]pY ‘SIG JO [je WIOIJ SWIOD O} Y2] SOMOWIDUW J]QIIO} SY) SuizijeoJ Jou uss) sjqeuorssosd ut ‘dunod BO} SUIONUS DWDYOS SIy BuLyew SspuwMa [eloueULy AUBU ZuIplaoid uoI9s909 SITY YIM OWI 3Y) Je Peq 00} [99} 1, UPIpP | “Spusiy ysnf UB] SIO SUIODA|G SN YdIEM PUL Pd[PUO] dq 0} S}sonbal [NFsny Sty YIM uodisiaAsad sty BuIA} VIZ SpleMidye WsInNOd JO pue AdIJor UO aBesseU dy) YSNosy) 19y pa] | ‘sisoo jje ye Addey wry daoy 01 sem Altyiqrsuodsal Ajuo Aut Jey) MOUY | WIY MOYS 0} DIOM SJIOJJO AJAY “JOOP 1X9U [IIs 9} SB JUDDOUUI puek JaaMs Suryooy onb od sty Apex seM [IIS SIG], “S}90I$ dy} JJO asnqe Jo swd}I] & MOI, popeisop ‘slojoq WY oO} 1YSNoIq pey ] S]413 J9YJO dy) OyI] JOU SEM SYS PUR ‘sod SIY UT [[9M SUOP pey | “Ad Jor JO} jusUOU pnold B sem J] ‘90ed MO]S-I9A9 UR Je APO SulUdIsi]s J3Y UMOP UNI Sa]qqng ay} 3uI}I9] Jfasiay poonposul pue dn poojs ays uayM Jed 0} IBD WOOL} JUIM ULI SIH “ONSUUI BULINTTe Ue YIM WHY ye SULyOO] qn) Aut ul sajqqngq deos jo JuNOWe ¥SI14} B UI SuIgjeQ [ars opnu [NyyNesq B [BVdAdI 0} JOOP WOOIYIeG AW pousdo | S19YM WOO] dy} OUI SUTBD 3Y ‘ye SULYOO] 9q P[NOM dy IVY) SEM 71 JEYM O} UL BUIALIS JON “YOINd [ear WIOOI AU UL SUIYJOWUOS JL YOO] B SABY O} WY PSpasu | BY) WIY PO} | SW 10; JNO paTfeo sf USM puUL ott ]NOYIIM JOMOYS STY poystuLy Aoiyor “Apooysod ued Alu payesayo1o sys dJoyM WOOIYIeG SY} OJUT Joy 19] | “WIY ostidins OQ} vapt Alu Jay Plo} |] pue pouueyd pey 9M se ‘oly UO jsnf Joop s,WOOI Aw uo Apaimb awes yoouy au, “SuryyAue jnoge uo jay 0} Jou SUTAN ‘oynuiwi eB oq ysnf p.] Jey} payeysuros | “WYUSUye Sem BulyJAIOAS f1 OU poyse puve ppo sem 1y8noy} sy yorum yoInb [ees [[eo suoyd ve oyeUt oO} pey isn ] ‘oynuru e Ul WIY UIOf p.] Wty Po} | Os ‘adessvul B JOJ UMOP o[}es pue I9MOYS B BABY OF O} payURM dH “Jsond astdins ino 10} sur Ul IsNf [a}04 dU} 0} YORQ JOS pue LIVYM dU} O} 1X9U SEM Jey} Jd 0} Jods ayInb & punoj ysnf aA ‘passaip jos AyyoInb pue Susarejs sem oy pres oy usyM Ayony SEM | POXB[I1 AIO SBM SY USYM ISUUIP JO} JOOP sy} JNO WHY duLsys/) JAIYS]LOMS B puv sjuedjeoMs JO d11WIB [BULIOU STy UO Ind puR JIYSs pose]joo TVIJ.NACIINOD JeusBYY psyoo107 7 1yBuAdoD ( P8t rOORMALANID TS pue suval sty JjO 97k} 0] poyURM o}] “YT JOF Yo] 9M B1OJ9q MOLOWO} JNO IE YOOYS P.dM SOIU DIOM JOYIVM oY} Fi ples aH ,Snonduimios Ajaynjosqe P9[[SUIs ]1 PUK JOPMOYS WIS AUIVIIO YIM Pa] lf SJoyseqpeoiq YIM punole BULYEM S[BSOT OULOS MPS | “MOLIOWIO) JILYM S_UBTLIDYSTZ 94} IY 07 savy P.2M,, WHY O} peuoyue | OUT ponjudA | sade] ay} Jo WIY Surya], ‘o8e sinoy A[UO SBUTARIO aJv[OOOYD AU poT[ YNZ pey yey doys oy} wroyy OSPI SPeUI [LOO] SWIOS YOR WIY IYSNOIG USAD | PUL JUls—S ]YSIS puR Zurddoys jo Aep yeo1d B SEM | WY Pjo} | ‘AalU0d 0} astidins pojoodxoun siy pue Aefe Suravy ynoge Aod Sulog “Aep oy} 10j 0) dn 308 | yeYM BuLyse Joyes “ZUOT puke BULIOG SEM I BuLAes “]1 NOQe YON HPL} OF JULM 4 UPIP d}] ‘sem Ap SIY MOY WY poyse | pue poq 94} UO UMOP Jes aH “UNITY IOJ ore] AIDA SEM YOIYM ‘dd1TJO 9yj 3B Ap YDnol & pey oy oAI] SULzZOo] ‘peoye 1yB1u oy} 10j Suiddaid suop sem | Joye BuO] JOU JOOP oy} YSnoIy) poyyem AdIJor “WUIY 9deSSeUL O} PI]UBM OYM WOO ATE UT [IS [NJWNeAG o3uRI}S B pUlj 0} pastuiduns oq puke UI YjeM p[Nod oY pue [1d MoU B YIM JOe]UOD jenxas pey sy s10joq poy!] Aouyor se ‘Jyo Sutues[o oq pynom ji13 ay} OS 11 uejd pynom | 14sn0y} | “1Ys1u0} osessew sty JOJ WOO AUT UI YIeq PUL SIO 9u} dn jas 0} Sut) ay} YOO) | Os ‘Jo yOeq sem Apogou ‘aq P,| paysanbel se wid 490]9,0 xIS 0} JoWeNb & puNoe Je (9}0Y SY} 0} YOR 103 | UdY AK ‘Pey MOU OM SSIYOUNLU dy} JOF JO1[91 DULOS 193 0} onbYNOG sdspHy opewowioYy B OJUI paTfoujs aM pue soysnq dy} UI poreys om Ael puodas ay} Jo yng sy} MaIY) sy *, Adar 0} NOA sonpoNUL [IM | pue 1Y4s1U0} Uaaas ysed Jey punose ye o104) 9g “asidins e oq 0} Surod o1,noA ‘Aparnb wool Au uo yOouy,, ‘puy Aw YM posvayd sow oq pynom Aayyjor “Yysnoy} | “JVaH "JXOU POYSe YS {,JYSIUO} JOO OM [[VYS UIT} JVYM “UY [[9M,, “99 sly Jjey UeY) JoBUNOA S]IIS YIM Oq 0} SOYL] Jey) URLU PjO Yor e ysnf ueY] dIGeINSKAW dIOW 9]})1] B PuNOS WY ayxeVU Oo} SuIAT] *, wIY 0} jeadde alan pieyory e JO d10Ul 403 S.9H,,, ‘Pordol | ,.JJe Ie Jou'"Ou" ON, ,,,, §..9Y SI ‘A[BN pue ivy ‘O¥I] JOU S.d},, OW poyse pue ]ysnoy) swos 1 VARS Ys UaYM JUSWIOU B JOJ UOISNI]ISIP 0} pawisas opnyziyye soijosed Io}y “Aguoul ay} Aq yorq udye} A]Pes 919M SOW ‘]IIS oy} UO SuIpusdap pue ‘jJeYy} ayI] soUa}UaS ZuIyooYs & Jaye ssUOdsSaI B OJ HEM SVM OP PINOd | [Vy *. ffs} adessewu dy} isnf ULY) SIOUI JOJ Sse SOUITIOWIOS puke YsNO) spNU aq Oj} sn dyI| SOOp o}j,, “UI JowW pey | SUN ISI SY} SBM | SB POYooYs se oq }, UP[NOM Ady} OS Op 0} pey yng “Jsour ay} poyey | yey) Wed oy) oUIvD UsY) puke ADUOUL 9Y} BSN Pod ays pres ays ATpa}oodxouy) ‘UOISses oy) SUTINP AYSLIF 9q 0] UMOUTY SBM dy JOY SUIWIEM pue ABM OY) SUIPRd] OU YyIM SdesseLU INOY-OM] B JOF SILT[OP poupuNy OM] JOY AI P,dy JOY PO} ] “JoRUOD & SL punode daey 0} [hyasn pue osessew v Jo} Aouow poos pred pue you Alea SEM SU JLY] SEM YOIYM YINI] dy] JO BWOS JOY Plo} | OS “BulAy yue}q ywiod 9q PjNOM | MOUY pue JZ SuNOA v Jo 9]Se} 9Y} JO} JOY pue |vap! punos Adlpjor ayeut 0} Sulaey puv suoynsoanb sow Auew os ym paqoid aq 879 $0 68Gebed ‘OEZ8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD TWLLNICLINOD fOMoIePY porss101g WYSUAdOD

The text on this page is estimated to be only 40.26% accurate

L8T POOR TLIO vS OM Ode ay} 0} ABM 3} UD ‘DO’ A‘N 0} JORG SuIUDAD Jey) SUIARZT 3q 0) Ajuo ‘AduOW JNOgGe ¥Ie} 0} a1dY} INO ABM 9Y} [Te MAYy 9“ “Jesodod oy) 0} JUDSUOD UI SUOAIOAD YIM “SONUTU SAY Pose] SUNDOUI SY, *,.SdATT INO JO $,Aeq,, JO J990npord dy} SB [JOM Se JUSSe S_LIPEN YIM Jou O} pey aM d104M ‘Yy"'] Ul OIpmis uOTONpod ev 0} yUaM | pue eIPeN ‘AdyJor Uo Joye] "1910 YOVd 0} 9)R[91 0} UOSPOI — ~pey OM Ng SPUSLY POO SWIedIdq IDAD 9M JLY} JOU PUB 00} PatUO}sNdde YJOQ SOM OM OPNILAIOS JO Jl] JEIIWIS BY} 1O0J Joy UO AyId YOO) | WoJJ oe A]jemoe ays aiayM INO punoy | s9UO “yYsNol) UONNEdwWod JoAdU SBM 3YS yey} 38 108 Pood vB uo Suljnd pue 99189 Suse Jay Suidaoy Jo ayes ay) JO} ‘O0} JOY JUdS dy aso) pue Adyar 0} Apog 19y pus] O} Surj[iM ‘sysonbar pajuswep siy Sulf[iy]Ny Ul sem | SB [NJWNp se isnf sem evipeny “UONeNousd jo $s jsniuy sAoajor Aq panpqns Suisq sem [IIS JoyIO SU} 9[IYM J9YyjO YoRa UO SJOR ULIGSO] Ul OBeSUDd 0} PONUIUOS 9M JITYM OS JO SOINUIW UddIJI} poosd & JO} PanuljUOd SIY] “YWOJ pue yxdeq “[IId J9yjO ay} 0} dems AyUO 0] JoYIO 94) JO INO siudd yOaIO sIYy SULyzR} “SN JO WOW dy} YM VSINODII}UL SABY 0} payieys pue Jasuoy Aue juredsos doay },upfnos ay ‘oinseajd YIM 3U0 J9Y10 a4] OP INO puke Al] SN SuUIydeM MOIS JUSWIS}IOX9 SIY SUIS ABMP 1YS1eYs SAO} paprAoid ay} YIM J9y}O YORd Sul[puo] pue suissty WE}S 0} SN pa}oN.sUl A]IILIPSWW SY “poem adesselW IST{eNIL OU SEM S19} SB SWI SI] Poyyeg sem | [OM SoyNp Aw SuImouy “UO SuIOs sem WwYyM ATOVX9 SUIMOUY SUOAIOAD SUIARY popessop Os I]9J | pue Je Ysne] 00} sueOIS JO UROUT B Yd}e9 0} Suldoy ATqeqold ‘jomnb jueM sn puTYyaq WoO 94} AJUSPpNs “JOOP 94) INYS dys se jno ABM JOY UO Bul[ssIs sem pue Sho} feuossod Jay JO UOIWDadTTO9 B ayinb yno yySnoIg yeses “souo aoud JOYS 3y} jou pue sAo} Aejd say ydoy pey yesres aJoyM poyse oy usyM JuoIedde sem 0} dn 303 pynom om podoy pey ay JOrYOSIU YM “IOYIOSO) S]IIG BLIOARJ OM) Sy JO UOTONPOIUI SY) Sujedioiyue sem IH “WOOIPSG Joy OVI | pue BIDEN MOYS O} YRILS poyURM AdJJo¢ “S[IB MOU I9YIO dy} JO BU BuIsoOYo JO peajsuy] “pacdouur 00} BuNjs3 s1OJoq Jey} JO YONW Os AjUO a]pueY pynos AOI Jo¢ “OUO 1XOU SY} DAO je} O} SUIAN [AIG AIDA “IOpNo] pue Jopnoj SUI}N98 19x UONLSIOAUOD SY} SIIYM S}INISIQ pUR ddJJOO SUIOS PRY [Pe IM “90e]d JSIJ SY} Ul SUIOD 0} WIS} Poslayjo pey Yeses sonrunyoddo dy} Jo} Suidoy ‘soajasway) sonpoUl 0} poysns spits oy} [Te se “JooMs NOA 1, UdIe ‘Pays pue YeIKS Je Paxoo] AddJJo¢ “WO, SSOOYO 0} Spits JUSIAFIP MO} B OABY PjNoo Adljjar OS WdY) PAyAU! pey sys puke WOO BUIAT] S.YeIeS Ul S}IIG IDYIO ATT NOE SIdM DOU] “OPISUI WOIJ GUIWIOS SODIOA SaTBUI9} SUIWLIIOS A]PI}TIXS JO UOTOUNUOS dt} JesY pynos noA “Joop Jay ysno1y} SUT[LM UDAD dIOJag “ULM BUOAUR PjNOd asjo Jey “Aep & 991M} YOJOd Joy iyeouropun padde] saaem oy} “AYM 99S 0} Ule[d SEM JI PUR 11 PSAOT dys Inq “LONRPOUIUIODIE JO SAX] S1Y JOJ [[eWIs 00} “YOeVYys Woo1psq-suo AUT] & SEM yy ‘AYM 99S P[nos NOK day} 10S 3M UdYM PUR HSIA 0} owed AdIJor SU }SIL] OU] SEM SIU] “YOuog nqiyeyy UO Joy JO} pajuds AdJor yey) jusuede TVILNACIINOS jeuagrpy payssiosg wysUAdOD D 981 POOMAAINIO cg S$ YeIes 0} Yor 1UOM [Te OAK JULIOdWUT [90] WY dyVU ppnoo oyM suodue pur uonuaye SUNOp dy} poaoj 9H “uOrUIdoO s AaIjor JO} poyxse ATpaytoxo pue ‘Su1uioUr sty) soy ABM IIOy} UO 1Y8N0qg pey Ady} s,ooYyD AtwwIr jo med Mau IIdy} SN pamoys pure Ieyd ev Jno porjnd yJoq Asay TL ‘Aep ou} Jo simoy Ajrea oy} ul Apeosye spuey url sseq surddoys ‘ayqei oy) poyseoidde yeles pue sys “suOJoq JOUI JOAD peY | S[IId [NJNeaq JSOUT OY} JO oUO rey Ag ‘saXo onjq SULydoOYs pu SOUO} ULYS SAI[O YIM ayouTUg SuruunNys B SEM SYS “Joyeosloy) A[WOYS Poa Ady} dJOJaq 3] qe} SY] Je paxseUlsl Aypnoid os ay se ‘Adaya Jo doy oy) yim ‘ssoyoe suiidse pouiny JOpowWl URIARTSOSN A & Sem oYS pur ulJolg LIPeN sem omeU JOY “JOA JOU },upey | spud s Aoyjor JO suo Joyjoue YIM sn sulUIOl aq P[NOM “I3]]9y Yeses pies of] “WSeJxeoIg 0} No yUdM | puke AdIJJor BUIWIOLU YX9U SY] ‘preAyorq Jay se adedspury] suesd0 Dy} JO MAIA Suldsams B YIM ROU] BIURS JO S9YdEdq 94} UO PIAl] MOU PUP [aPOUt [NJssadons eB Us0q pey ays sieok 1o3UNOA JOY UT "[[Op sIqIeg [eo1dAjoaI9}s v “saAd aNyq YIM apuojyq jje} e Sem dys °,.punose dsox 0} Ysnous 991U [[S SBM yNq ‘a}Se} AW IO} PjO 0} 103 9YS,, JO} apod s_AaIor ‘spuslfpid pjO siy JO uo YM SUIARIS D1OM 9A “SSOUISNG JJOU! JO} ulRGe 9A JJO 919M OM OS ‘SdseIs siY ul pain, Suidaay sem oY SpitS oy} JO 9uO JO} OIpMs uOLONpold ke Iv Sud B pey Adljjor "JOU 0} sInseojd B sem OYM “WR 01 BAgQ-pooy Buldes ‘Moy oy) UIyyM YT Asnq ul poAle om puke WOYs ATU SEM JYSILY dy], “soyorag S$. VT SUINIY SJOJoq sindIped ve BUNIJ9B yNOgR UKIPstOd sq} 0} d¥Of B OPeU UDSAD PUR JJO }I poysne] | Se oNssT UL JOSUO] OU 99M 499} STY d1M1S93 9dIU B YONS SEM HI PUv ‘jy DAO] Afa}NJosqe p, Ady] MOU | “}1 0} 1x9 SOWBU J9Y} pue .SUIUS0IH Pej WIOI ue Jsojeois Aw O],, 9ONb ay} ul yy 0} d]qv SEM SY SUIMBIP 9ZIS p-Y 3U} O} IXON ‘OS JO SIvaK Ud} JSed dU} JBAO Jauuip Suunp oposids uv Suissiu jou A]WwWey sy) JO suRy any dy} ‘pep pue JdYy}OIQ INT] AW! 0] INO WY) SxBU P[NOM oy JI poyse | “Weg pur JoWOH ‘SIOOVILYO SOAR] OM) AU JO BSBdJOTIQ SIy WOI Joded yuR{Q Uo sayojays yoinb OM} Ul MBIP 0} YSNOUS pULy SEM Hel S9OIAJOS At JO} WIN}OI UY | ‘ISI WOY}) ULd][O 0} SuNndUID}e d1OJOq JOU ING aHesseUl 100} popeolp SITY IO} powmel pue 19jeM Advos ULIEM UT YJO][D YSeM & PosulI pue suLTd sy} JO YOR If} 01 JUSM | “BOI ue pey J Udy “‘YSnoy) | sty) Jdwioye | prnoo AeM OU ‘OUI JOF 9yB9 OY} UO BUTI [Bl SY) SEM Jey} MOU ‘S901 AJBIMS STY JO SAOTADIO 9Y} USIMIEqG pospoam y90s Jo saoaid I9AOYO] JO S[[eq ALN] 94) SeM o19y) Udy) pue YSNoly} FuNINd sopqnoy pey 9A p[MoM MeESUTeYO B YIM SUOSWOS USAd Jey} S]IeUSO} AJSNIO MOTI[OA peYy 9H “Wdy} YONO} 0} suraey Jo JysNoY) 94} ye dn mary} Ajreau | ‘Jooy S1y JO odeys oy] Mes ] Udy jnq WUsI]O B UMOP powty JOADU | “IYSIYE WOYS OY} JO UONeINp 94) NOYsNoIYy osesseLu jOOJ & WIJ Oars | YU) poysisul Aoyjar UsYM “UONRSIDAUOS INO SuTAOlUS SBM | "yeoIy) Seg punole pury SISWOH JO SoUddS UOS puk Jayjey AZBIO 94} JNOYITM ING 879 $0 O6Sebed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVLLNICLINOD fous] paysojosy 14 3Adoy Fy

The text on this page is estimated to be only 41.95% accurate

6O8T POORRTLINTO TVILNACEINOS 881 POOMMLINIO TWLLNACLINOS : poUAEPY paomMosg pyFUAdos [] JCUMCYY poroapod gy, WyBuAdOD (7 9S . cs AW UIe]UOD O} B]qe Bulag jou dn Suipuy “ow Suisyjog sem eYyM Noe yeads pynoo | Os d01U 3q O} GutAd) Jsnf 10 SNOLIOS SBM OY JI SINS },USEM | * Adiaud dane3au uo ssed pynoo nod ‘Aisue 91,nod uayM [dood odesseul 0] poos JOU $,}i MOU NOA,, pies pue yt UO dn poxsid Aoijar usyM “pootu Jaqwos Aiu wo joinb Aida ZuIdg OBeSSeUI 9Y] Poyie]s | “Ul PoyeM | udyM a/qQv) SdeSseUl dy} UO SULA] Apealye sem AdsJjor “19]e] NOY ue Jey e sue]suMOp uene SuNsout ‘uo dn-ayeur Aur ind pue passosp 103 “yonoo ay) uo Surxe[ai wo dn jos | Ajsuispnin “inoy ue ul osessew e 941] pjnom Adljjar ples pue popes suejsiyH usym ud salty noge [HWUL) “Aep ]]e pay[es Ud9q },UPeY | SDUIS xe][391 0} JJO Aep oy} SARY P.] JYSNoOY}) | ‘SsouRJSTUNIIO Aut 0) Suysnl[pe Aypeyuow ‘f° YM Suryeods jou [[Hs sem | Joyeyl sAeq ‘yda00v 0} panutUod | Sat] ay} JO JJaSAT PaoUtAUOd | “sAep [OOYOS AW UI pualyj jsoq AW 9q 0} posn oY puke “OO} STUOY SWS O} puNoIe fT SUIARY Poaoy | ‘UOTENIs Aw 3d990e puke UMOP [OOD 0} SUT] 9WOS Papesu ] Ng ‘SARY },UP]NOd |] 1VYM pajyueM | ‘YSU sem oH {,.0p 0} WI yOodxa NoA PIp 1eUM “URUT P[O Jey YIM PUR SUTT] OY] [[B 9UOD 31,NOX,, “WIY sAoge oO} Jamsue 0} Appep Jeans eB pey | ddpo;MOUy dU) UY SUIAIS diysuoneyjel siyy Poles pey | IOUS UO pues 0} Bd] B OARY Al[e91},UPIP | ., Splepueys INOA Jay3iy pue AWUSIp SWOS SARY }SEd] Je “YOROg Weg [eAOY UL INJS JsOsBIq dy} YM Suldaays nod no Burpuy Ajuo ‘syyuow Joy AVM INOA Sutked ud9q SARY J,, “f'], YIM Suoye osnoy Aw Jo no soy MoIyy | ‘Apog J9y4 JaA09 0} SJaoys ayy MoU AU ATUO YIM Opn [[NS ‘OU YORNe 0} ode JO yy B ul dn 403 pue yyiM punole BUIMdIOS SBM dys AND 9U} JO JUOI UI 9]1qQe} SY} UO SP1kd JOY O41] 1, UPIP SYS "] pure fF], Ud9MJOq UOMENIIS pojeosy 9y) Wyvd pue yNoW Jay uado 0} pats) ays USYM JY} OZI]VGIOA 0} AYS },uUSeM ] pue ‘sasvasip ajqeumnsaid Jay yim Suoye SANs Jo [Ie] JOY GUII}jeOS ‘JIMO] UMO} OY] SBM SYS pur ‘satped Je punole 19y Suloas Wo] [113 QY} peziusooal | ‘ssoujduroid YIM 19y JJO 103 fT ‘oIOWAUR QUOTR ] UdIaM Ady] posiyjou Ady} usy AA “[UIS Joyjoue Jo do} uo ¢” | [29Ad1 0} QoUyIOOp Au pousrny ATMO]S pue d194} YORQ poyieys | “SBM WOOIP|q AW sIByM jusuiede Aul JO yORQ 3Y) WiOd, SUIWIOD SASIOU SLOS pivoy | UsYyM asp 9} JO JNO YULIP B 139 0} }UdM | “[]BO PyNOd ouRTSIYH JO AdIjor IAAIUBYM JO} a]qissacov aq 0} pip sAvmye | se adieyo uo auoud [190 Aw nd pue Jooy dy) UO asBdyiNs AW Jas | OUTOY Je SEM SUOAUR BuUIYUIY] JON “osnoy Jainb BO} UL poy]eM pue JusUIede Alu 0} JOOP dy] YSno1Yy) SAoy Aw ind | ‘SUIPUL] Joye [14M & IOJ DSNOY SIY JB poxejol pey om I9]JV SIAAOUW dU} O} INO SU PayAUl Ado SB SUIUDAS OU} UL 9] 9UTOY 1038 | ‘SABP SOW INO} JOIN} & 10} SUIALI] JOU “YORog Ue 0} yORQ Surjas 0} piemioj SULYOO] isnf sem | Sy} JO [Je Wo yeoq e SuNueM “10j podoy | se UOTUNAL [NJSsiyq BP}, USeM }T puke “> A'N Ul AWWW pUe sueISTyD JOU OM ‘aq 0] dtu poyUReM ay JUNpPNIs 1939 oy) SutAvyd pue juedrorpied BUTTJIM Joyjoue Aq poov] dal Sursq JO ysT v ye AtURsUOD ‘ANYSI] popesy ] OS “SUTYIOU 10} 9q Ud9q []B 9A, P[NOM JT [[9q SIy) JO [[e Ysnosy} JfasAw Buiind saye dn aes | Ji ‘pyiom sty} ut doap souy Apeosye sem | WYsnoy} J "I9BUC] I{TUM v JOJ yOINb ou yday YyoIyM ‘feuorssojod B WO] UOSSa] & OU BULAIZ [JS UdJO OS IOAD “I99ILD SBESSELU OY} SLM SUT] ‘“SIY JO oNsea]JOO [NYSsaoons & YPM ISVLULIW Ul JUDUISADIYOR UL IO “S9OUBUT] “I99IVO dy} Ul paytjouaq sey YIM SUONRIOI [eNxos pey sey oY [113 AIOAD JeY) OW Plo} soul AdIjor “STY] O41] o[dood JOj {STxa JOU PIP S[RIOUI ssoy] dIOJaq JOAD UR} dIOW Avp ye} MUX | ‘P[IOM 94} Ul yooIj3s AIDA JO Jo YNOA dy) SulINdO1d SUIR]|IA 9S9U} JO JUSWDINI[e OY} WOT oJes st [41s Ayjoid ON | "UYM UY JOR} O} OITWS & 9}L}WT 0} ING 9dIOYS OU pRY ] oanjoid o1jiioy & 9 SuuIed ‘peoy SiY Ul IOAO [VALUG Joy JO SOWOWOW ay} poxeydol oy sv Appis pue Sulysne] sem oP] “SolISOp [eNXdS SIy aB1;qO 0} U99} AJaleq B aSN 0} MO] Se doOjs pynos oy Jey) peyooYs “say JOAO JOY 393 0} JOARAIPUA STY NOge Sviq Aajjar 0} Sulusjst] ssopyooads soy} JES | “OPNALAIOS JO jt] JOY POUDUILIOS 0} JO JOY JUS puke 9Aq-poos IIIS Aqeq Jay possty ays Os ‘ounyOJ poosd A[iwej dy} BULI 0} JJO PoLUeU 9q OQ} [11d BUNOA & JO} PPO },USEM JI SUIO}SNS JOY U] “HI BYU O} SJI] Ul SaouRYS pue UOTILONpd jsaq 9Y) DATION RIPEN JY} A[[euosJod j1 0} 9s pynom sys ‘OY YIM OF VIPEN J] OYS JI JOYJOW S_eIPEN Sujal oyjourdays SuLeo ‘[EUIDJLUU B AI] POWIIS SYS “[OOYOS SISNUI B Jv SULIT} SII] BY) JO} VIPEN poyoroidde surjsiyyH usy AA “JoYysnep uMO JOY IsTe1 0} AJessooou sud OY} DALY }, UPIP 9S ‘ANUNOD P]IOM PIIG} B UI SUIAT] puv Jqop Jo JuNOWe SNOPUSUIO]) B Ul JOYJOU $,VIPEN SULARD] ‘AeMe passed ApJUdOI PRY JOyIeJ JO} “Ud9}ITY) powiny ysnf 19deUd9} B AOIOU SEM BYS UdYM OSB S1edA DALY ‘Joy 103 ay aJeyM pulysq AIOJSLY 94} SU ]]A} 0} poye}s UdY] DY “JUSLUDILIS Aw ye Surysney .. NOA YIM SULOP SI ays JeEYM MOU OJ SUISOS puke ‘Auuny ‘OATOVIY SI 9US,, ‘pardal | “yoeq AeM 3y} UO Joy JO 1ysNoY) pey ] 124M OUI payse oy USM Ivay O} payuRM oY JeYM prIes | ING pnoye Yury} UdAd O} passeLieqWis 9q pjnom ojdoad jsout MaUy | Jey} dt 0} eT[TYdoped JO S}OV SNOTOKTD} SIY JO IMIS JrUIpe O} pnold Os “UTY JOJ SUTY} JO pury [> pur SsTy B JO NIOW “RIPEN JO JYSNOY) | JeYM SW poyse Asior “OJey InoY yeod A[rep 34} yYsNo1Y} StU} UO 9194} 199 0} POYST JOU PUB 9]qQeIIOJUIOD 3q pinom dry ay “yorq yoo 0} Jol ayeatid e pey aM ssoupoos yueYT, “yoeq 14S Suo] 9y} YSnosy) Suidsajs 0} preMOJ Suryoo] sem | “Adaojs au SULYBW Sem SIOdIM P]SIYSPUIM 9y) JO WYVAYI OU) pu 1xe} a4) Jo doyoos dy} Uo INoduMop jo punos ayy “UreL AABdY 9} UT Jodiung o} Jodtunq Poul] [[S Sem ABMIOIJ OY} PUB UI SATIP 0} SOUR] UBADS “POO| [ed1 3q 0} PolopIsuod | yeyM Jed AdIJor MBS | SLUT} ATUO pure JsITy dy} “axeYsy|IU BIJIUBA puke JOdINqosooYd v 103 PUL IOUIP Buryoo] sonsy v ye poddojs 6 1a}deyD 879 $0 TEGabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD =

The text on this page is estimated to be only 40.84% accurate

Lol FOOL TVELNICIINOS 061 POORRLTANID TWELNACIINOO JEUOTEAL p9199j01q iyBuAdoy [7] - [RWAYCTAL payonod, |UBUAdoY 7] 8S “UOLBULIOJUL SITY OSINU 3) SARS PUL S]{[Iq [BOIPSUI dy} [[e JO Ivo oye) dy ivy] paysisuad AdIjJor ‘OUI poIda0d [[HS soUBINSUT s}UsIUd ALU Po}sisul | ysnoyyye pue siy) Joy Aed pynom oy yse 0} Ul oWUeS oSINU Y ‘UTed dSUd]UT dy} Opisqns Oo} our djay 0} UOTIOOfUT UR UdAIS sem | ‘AUOSe YONTU OS UT pue SUIPUIOA A]QL{[OIJUOSUN SEM | BUNSS) LIPS! JOJ UI poysny “UoHIpuos peq B yons ult ALINIG OS SBM ]I SB ‘IOQLUOLUSI } UBD | “IRUIS JUNOJY Jo yeyidsoHY [IH XOUUa] 1394119 0] SN SAOIP SH “OUI JOJ SUNIEM SEM Of-OF OYM Jed dy) 0} UMOP OUI pajsisse pue dn jad ou podjoy oym prewesnoy dyi Sea 11 “JuIOd Jey 1B UL Sem | 3]e1S SIYdONsSeE}LdO oY) MES BY USU A | “puey je uoNeNis oY) poreoy Ady} ‘UO TeOM [| ape skemye | Mauyx AdY] SUONRSIOAUOD SNOTADId INO WOIJ puke OW YUM ULOPUOD B JOM IDADU 9Y SUISOS PUR MOU JSJOM 9} SuNosdsns sJoM AY JL, “SuljeuLLLIOUT BuryjAue AVS pynod | 3JOJOq $10}DOpP 9y} 0} JO98 0} Papsou Ady) pue yysned wy) Suyjos ul Ay yiqely] B ATUO SBM | OZIfROI | MON ‘SW YIM jeVIdsOY dy} 0} OUT YIM oWIed Ady} “WUSY] UMOUY pey | SUIS SUI) Js dy} 10} SW yNOge pales Aj[eas Ady} Buryury] “AOUSSIOWS UR SEM I ey] WI 0} SUISSd.1}S “JOAd] Au O} dn Aziny 0} WY PpoO} pu SUT) OY} 1B DIJO sly UL SBM OYM AdlJJor Po];Vo Udy) SURISIYH “SuUOIM SBM JeYM 99S 0} dn URI OYM SURISIYH Sulyjeo ul syeyISoY }.UPIp ayy |{jeq eB Ul psTpiNy JOO] oy) 0} yorq [jey OF AjUO UMOP sUOU ou) pouUR]S pue AjoyeIpowUt [eydsoy 8 0} 03 0} Popsou | JOY PfO} | “MWOdI3}UI sy} UO pleWosnoy sy) paT[eo pue asuoyd oy} yovsl 01 a]qv sem | AjsSnooueynutts SurAio pue dn Sulmolyy JO SOABSY 3} USOMJOQ UT “Ul SeM | Uled Jo JUNOLUe SIP oY) UO sNdOj A[UO pjnoo | ‘Uo SuIOS sem yey BOP OU pRY | “SUIIVOM sem | sjuRd OU) P2YOUdIP JEU} SUTE]S PdJ dU} Ul PdIDAOD SEM J “POOTG Pue Jeams UMO AU jo jood eB ul JfasAUl puly 0] SJdOYS 971YM SAISUddx9 OY} yor pond | “deu pepasu-yonu Au Woy dn SULyBAA ‘PO][Bd USAd JO SINOY JOJ SW UO YD9Y9 01 dn sured Apogon ‘d] 14M B 1OJ UMOP SI] 0} Papsou pue YOUN] JO} poo}j Jjo awos aqAevu VUBI]y oy} Jaye []I AISA SuIpsoJ SBM | Jey) Jodsayasnoy sy} PJO} | “SUD ISA BY} JOJZ DUI[IOP 0} PRY | ‘WOO adesseW OY) Ul AdIZJor Jao 0] UMOP poTed Sem | USYM puK YoeUIO)s AU UI SdUIeIO osUaUT BUTARY Sem | ‘OURTd dt} JJO SuINIAS SUIS STU) sTqRIUNOOUN 9) JOF uTede O[IQ dn MOIY} 0} J9{10} BY} 0} SUIT} UT SN} ByRIO 0} ‘Ajosnfoid SunesMs ‘WOOT AW 0} [VY SU} UMOP PUP JO}JBADIS OY] JO JNO Poystu | “UMOP SUIOD peq kB ysnf SBM ]f SULUTY) “OL YIM SUOIM SBM 1eYM BUIMOU JON ‘a}e}S 9[QWJOY B UI [JWS sem | ‘Aep Jxou oy] Adjar 1390 0} D°A’N O} INO Maj] Ua A “Ud4SAS PdVOIxXO}UI dy} JO NO UMOP BuLIVIM SSNIP JO SuOTSsNdJodsl OY} WOIJ J9A0DAI 0} oW0Y ABM JIDU} SUIPUI] 919M d]dood se sIoqunu UI paypuIMp A]MO]S WIOOI SY] Se JYBIU Jey} doa]s 0) 109 APOGON “ouop pres [je SeM opeleyo siy] uaym dn puoa [ye prnom om oJOyM pure of1] INOGe SUOTFRSIOAUOD yidap ul SUIARY [Be DJOM OM “SPUOWRIP YOR]Q 9111] OUT payeyip LS SoA9 INO YIM PJeYy SUIOS [IHS []v WOM OM SUILIOW dy} JO SINOY 33M dy} UT ‘ou O} dn Suryoo] jooyss ys1y wo sss9d Au Jo |e yiM Apeosye dn umoi3 os 1ng SUNOA OS SEM J SIOY SULZUTTD ‘TOMS pesy Be oW sAes AJIPUTJOP I] ‘OU SITLUPe SUd9} MOT[OJ AU OpeUl “IOJ S}ORJUOS Tp) [[P Pey f° L yey} JoYoo]R Jo souepuNge? ue se [[9M Sev dx09 puL ‘Asvjsoo ‘sd14] OYI] SSNIp Jo JUSTUVOSsSe UR YIM somed prim Aut Ayddns prnoo | jeq} Aouow yonw OS SULYRIY “UMOP Bul[quim) dUIvd S]]BM USPPIqJOJ Ino usyM SUOT OO} ISP] 1, UPIP Hi Ing ‘Jadivo oy} Ul SojOY JUdAdId 0} SuIAI] Spisino O39 O} a[NJ AW }1 Opeul | OS peodjsul junrq paysids v jo synd v savy 0} Suluosord “uL0d JEU} JV JOYOUIS [Vd B },USEM | “UOTIOIS S$ JOYOLUS SY] 9UIBI9q 1BY} Yovaq dy} pue food dy} Sulyoosiaao Auosjeq & pey WOOI dy], “SuLIe]q sem oIsNU Suiduind dy} pue susa} Jo pooy eB yum dn pay Apyoinb wood jajoy aq], “YIM uiddq 0} spud Jo dnold |jeus B AJUO SUIJIAUI ‘YoRog BIDATY Ul pue]s] JaZulg UO puaysem yey) Ayied J9}0Y B MIU} | OS ‘Soop JoseUsa} AUR d¥I] xPdJ 0} payuem pue dij snolaoid Atu wor AdUOW JO speo] ape ysnf pey | Y9em 9Y) Ul J9ze] uty ULOf O} SU IOJ JYSILJ [RIOISWIUIOS B UO OHO | -7F OUR OSULUL P[NOM SdIJJO SIY 1B JULISISSE SITY DJOJ9q JJO SAeP Ma] B APY OF OW PJO} puke > A‘N 0} YOR Burd sem AdlJor PLOM YSIS siyj ul auOAIOAS Aq pojdaooe JONpUOS [BULIOU JO SEM BUIADI[Oq O1UI Poy SuUIdq SEM | P[JOM 34} JO SIVME DOU JNG JONeU VY) JO} apr] AW OJUT YOR pue Justupede Aut Oj}Ut yorgq tury 19] J oul) 3Iq dn pomoios oY PUL IN[S UMO} ds] SVM Ys Jey} Ol YIM SuIssIBe ‘Ulese Joy 99S JOADU P[NOM sy jy) postwMold pue ins sty popeold ay ‘urede yno Wy poxd1y | oseo UT JsMf URATUIU Joy Ul SIIe}sUMOP SUIPIVM WOU! Siy ‘OJ9q) 103 | UDYM 1OOP JUSIUede ALU SpIs]NO SeM fL "ysInsue ul asde[joo 0} Sunuem owoy juss Suloq d10Jaq SONNp jenxes AU! pay]y{Ny pue ssesseul oy} poysiuly | “sossayoid 99a[[09 B dq 0} pasn A]UO pue Yo 108 dy SJOJOq SARP PO oy} oI] “yrdnd dU} SU pue 1oyoRa} oy) SutAeyd-3]01 Poao] [[NS 9H “JOJUSU AU O} PoUd)si] snl] Jl OULZ 3q P,] OUI Pjo} PY “Ulede JoOAa ‘oorApR diysuoyRyal Joyo Aue JO} WY 0} SUIOD JDADU PZNHOM J “PsUd}Y SITUS JOv O} FULARY JOR] UL INQ ‘ssuodsal sty Aq pouoppes JoyLing },useM | OXI] pusjoid 0} pey | odvsseu dU) JO Jopureulel oy], poywudur ATpeoyoues ov ust sn Aem oy} isnl S JI ‘UMOP Jd] 9q JOAOU I], NOA puL [Nye Oq 0} URTU B JOSdxO IOADN ‘dy SUO SITY} YIM Jord JO JOT B NOA SARS 0} SUIOS w,] AGM ST YOTYM opts INOA UO WJ, SWIOD 0} SsIVdA AURLE JO} SW YIM Yyonjs Jomsue STH {,.SABeMAUR UO NOA dIv SpIs 9SOYM,, d1NjSOd poyVdy YS] & Ul pordel | °,,WIY JsulEse yy) ploy 1,Ued NOA ‘Soop ppIOM sy) UI And AIDA JeyM Bulop A[UO SVM dY ‘SNOL9S NOA dIV,, _POISIXd JOAD Sdiqsuonejol snowesouoU! Jey) UOT]OU Au jo yoodsoid Aida 94) Je poysnel oY pes}sul jnq ou s[OSUOd 0} SuIOd SEM SY SUIYUIY) PUOdSS ¥B JO} pasned A]SIOOUIS Pu SdeSSeU SITY WO punose pouiny ay “dI] @ YONs Ul SULAT; WOIJ UdXOIG YeRdY 9[})1] B “siv9q Ul UMOP 901g puR fC] YUM pousddey yeym wy Pjo} | soyjZAny Aue UONOUWS 879 $0 c6gabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 43.07% accurate

col PoontaAno 09 DUO] B Joye ods soi B JOJ JUIOd oseq poosd vB ysnf sem Y “JeY) oy] SuryjAue Jo punose Sursunog Aue op 1, UpIp 3H “OOP 9y) JJO SJoJoW poIpuNy suo ynoge sulodwiey] 13}2M SY} 0} JNO WIMS 0} YOROQ SY} 0} UMOP Yoeq JOM pure BIA URW OY) 3B YOeQ YOUN] pey 9M SpleMIOYY “SOyONS dNOdeI3y} opjuod AW puke SOABM 9} JO PUNOS 9} 0} INO pouOIp oy se ‘osesseW ve SABY 0} SOdRId SIOAL] S Adore JO DUO SBM }] “OHPS S19}VM 9} UO INY-14N B JOpPUN IFeSSeLU [BdI B JOJ YOVIQ dy} 0} UMOP LUTY YOO} | Aep 3xdU SUL, ‘ysnous suop pey | JYsNoY) | ‘9dvj SITY UO STILUS 94} Aq puke ‘J03 I Se Pood se s.jey} YUIY) WIY 39] | “J JO JNO JuRTSeARIyXS SulyyAue JO Avjdosoy Aue oyeW 0} SuNUeM JON ‘WIY YUM ISINOdIOUI BulARY YSnosy) Jos ATYoInb pure ‘pey skemye ] SB JSOuIBS ALU ODRSSPLU OY} ABT | ‘OSESSEW OY) BULINp posseiequs BUI[IOJ WIY JUSADI 0} WO}}0Q 31eq SIY I9AOD 0} [9MO} B Gund “91qe} 94} UO UMOP 99dRj JI] PUB SS3IPUN O} P99U PSY WIY pjo} | “O} posn u90q pry | JeYM UY) JOAYS JO] & Pue SITY) 0} PaOysNdoeR Jou AjsNoIAqo ‘BUBQBD SU] Ul JOS | UDYM POSSoIP [[NS SEM SY “SulyJAue [99} 0} JOU 9OIJ 9q P[NOM | PUB “OUIM Pdl SY} YIM POXIUW $}9[qQe} SY) JO SJDIJJO SY} YM “19}k] sojnurtu AjuaM] ‘pres pey | SB OD 0} Apeos sem | ‘OS JO SoyNUTW AVUSM} UI BURQED SIY Ul SW JO9W O} nq JOUUIP Jaye dn udysalj 0} pojuRM | WIY BUI[[9}] “XBUBX MO} B UMOP O} WOO AW 0} UBM | *S,BURQed dU} JO SUO Ul poqg osesseuu e& dn jos SUOSTUOS SARY 2SKd]d 0} IYSIU LY} SN GUIAIOS U99q pey ey Ayjey Jodsoyasnoy dy) poyse | “I YONO} suoye yo] ‘Apoqg poyeu SIY 99S 0} SARY P.] JUDWOW dy) SUIPRSIP “JOJJO SIY YIM pol[|dwod AjoamMs pue uMOp duIM pol sJOW podins | ‘Aayjor wos noge Sulesy usaq sey sy SODPSSELU [NJIYDI[IP 9} JO UO DAIDIOI P[NOdD ay JI payse dy “Jno 1ySnNo01q SBM JJOSSOp USY AA “OIXSIOUR -9q BUURM B OW BUIT[2d ‘sso] AuUTys AW JOJ OW Je poxod oy pur Jey posno} sty JO uNj opel | “JOTUUNY 19d 0} PawWisas SY ‘19}P] 9]1]0Q SUIM Pdi JOYJOUR PUR POAIOS SBM IJ9UUIP dtu} oy} Ag yysIu AzZI9Iq 9Yy} UO dn SW ULIEM 0} POUI9Is 31 Pue 9]qQe} 94) UO parjddns SUIM Pdl 34} YURIP YIOG 3AQ ‘SUOAUP PpuUNOIe seM JURTIOdWT SUOCSWOS usYyM o}ENbINS AW yNOgGe PdlJOM 9q 0} SARY },UP[NOM Ady} poaosdu pey SUSLIOUURW AWW JB 4} MON 389 pue pooj Aw 4nd A[9}1;0d 0} MOY StU MOUS 0} popssd0ijd pue spuey JOY Ul JJIUy PUR YJOJ OY) YOO) oURISIYH “sjqey poyeonstydosun At jo uny suryew ‘pojedde os o1am Ady} oj1Uy pure 4JOJ B YUM JO PUR JLVIW JNd SW UD9S peY SURISIYH pue ADIJJOF SWI} ISITJ OY ‘dey Aw ur ynd 0} urydeu Aw suipjoj Ajoqyod ‘wy 0} yx9u Jes | pure o]/qQe} OY} JO pesy SY} 3 JeS BY “BPULIOA SpIS}NO sy} UO JOUUIP JOJ wd XxIS je JOW YIOG IAQ “PpuRYysIOjSq dn uvdI[D pue yOedUN 0} SWI] DALY P[NOd aM OS POAIIS 39q P[NOM JOUUIP SWI} JVYM 99S 0} VIIA UIBW SY} 0} YOR 105 9M "JJOSAW 9q 1, UP[Nod ysnf 4 ‘931;0d 9q pynod | pue Aayjor Aq ol JO poysadxo sem JeYyM JNq SUIYyAUB JODULIIS SIY} POMO | JI SB [99J} } .UPIp | ‘Sn 0} payeodde yey) sinjeu JOyJOW S}YSIS 94) JUDWI]dWOS TVILNACIINOSD [eae] po92}01g1YTUAdOD [) 761 POOTULTAIO 6S 0} SOPIS9q 19YJO YOVS 0} PIOM B BUIABS JOU ‘aIdY} Yes YSN pue JFI]9 B 38 1BS OM “PpURISI dy} JO Sued poyonojunN dy} Jo syead snourejuNOW 934} WOIf SUIYRIYIVIIG DIOM SUOTL SJYSIS SY] “UO UOTdIIDSaI1d SY} JO pes}sul YSlY [esINjeU & OW SARD JL} SUIYJOWOS SuUIOp “Ney AW soo] Suis] pue ABM dy} SUIpes] ‘syjed AAInd [jews oy} puNose splJ ay41q penb snoinjusape ue UO WIY YOO) pue poyse pey Adijjor se pUNOIe WIY PoMoys | “/pusyxsom OY} JO} UOTDO] puke AURdWOd SITY YIM poyySI[ap A[SNOIAQO ‘SpJOM YUM JJISWITY JOAO Sulddiy) sem ay JI Se payxOO] dy pue soduejuleNboe INO Spell 9M “UO SAL Ud]JO sURISIYH pue Aoyjor se iaydooray Jo peosjsur yeog Aq poate pure odie ay} wo dn wy peyoid siodsayasnoy 34} JO SUO UdYM WIY poses | pue Ajoyesedas poale oA “WIY ynoge YOO] ISIUSIOS pew B pue Jey sym YM URW 9I}}1] AysINd B sem UdYyda}S “SIY 1, USEM }I GUIMOUY Jey) URY} JOYJO QUOU yng BseIWBOSIW AW JO SMU 9Y} UOdN SdRIQIIS WIBM B SU PolajjO Jsea] JB pey OM ‘adq -poos |, possy pue ‘josedde purest yim oseoyins AW poxded | “jUdT[S ISI Aw pey | oy] Addey wry dao4 0} stu pyo} oy SWIY YIM Xas SARY O01 PooU OY} BUIZI[RQIOA USAD AdIJJOF NOY AA ‘PoyuRM oy JOADUSYM JSeSSeUU B O} WIY SURO) PUR LUIY YIM SUIUIP ‘pue]s! oy} punose wy SUIMOYS WIY ym skep om) Sutpuads oq pinom | “ uoydais poweu ‘sossajoig pleAley BST OH JUSTO MOU B JIS O} PULISI SITY 0} BUIOS 9q pjnom |] ow Plo} oy ‘sysids Aw usyyst] 0} Sud) sem Aospjor JI SB “19}B] SOM OM], "SMOIIOS AW JV91] 0} UOTJBOIPSU JIS JO SWUOJ []B SuIsn ‘uoIssoidap eB OjuI Jodaap |[9} ATUO | pue ‘syoom a]dnOd vB JO} JSoI 0} SWOY YORQ SWI USS OY PROISUI ‘][B Jv GUIIOJWOS } USEM AdIJJor “GUIYJOWOS JNOQGe UOI}BSIOAUOD aeAlid B savy 0} Aemy[ey ASng 9} JO SpIs 9y} 0} SUOTR 10}90p 9Y} 400} oyM Jyjasury Aayyor Aq dn poydid sem | ‘eoy AW Ul jo] AVATISUaS JO S}Iq ISB] SY} SUIUTRIP SEM djI] AW UT p9dd9ONs 0} Ado S41] US pepsou ] SULADT[AQ JO 9[DAD BULUNIIOI SIY] “JO JNO YedIQ 0} pojuRM | Jey} PjIOM B OJUL SW BUISSLIP SVM JeY) S[AJSOJI] SNONSESIP AW JO} Psd puke uOTOWS Au® 4NO 4d] | SOJOQ UILJIND BY} 9SOJD 0} 1OJDOP SY} JO} poyteM | ‘dAISU doop B WY pue jSvj Ul YUNS SMU OY], “dJ9/AwWOd SEM SOTIOIQIUL SNOUSARIIUI JO 981nOd AW SB UOOS Sv SWOY OF 0} SUT 9q pjnoys | ‘Aoueusold jo soseys AjJeo Ul polueosiw pey | st pjo} Apunyq ysnf oy ‘Jo yuIY) pynos UBL S31J0}S JOIIOY ISIOM SY} BuUIDas ATJURISUOD pue gos sIy Woy ATSNOIAgO WIY InNoge YOO] pouspsey eB pue “Ney Yep YM UL [][2} B SEM OH "Ssouy]! AW 0} UOISN]IUOS 9} JO SW WIOJUI 0} A]JJOYS UT9q pjnom 1090p 9Y} SW pO} UsY_] “SUIS [BIA AW poydoyo pure sjreyos Aw ysnosy) POHOO] OYM 9SINU SY} UI PoT]ed | “19}}9q BPI] B DUI[S9J ING UO JUSM JEYM [[B We SUIMOUY JON “WOO JUDIOJJIP B UI DUO TL SBM | ‘9}e}S poonNpu! AW WOJf SYOME | USYAA “OW SAOQE JOAOY puR pNnoy Os yeads ‘ydInb OS SAOUW 0} PSWI99S SW PUNOIL DUIPUL}S SUOAISAS pure J9]/qQe} DULYULIYS oY} pomoyyems ysnf OYM pUR[JOPUO AA UL SITY SAI] Yaz | [UN Aeme PO[PUIMP SUOAIZAS PUL BUIYJAIOAD “UL POYOLy JOlpos uled oy) Us AK 879 $0 E6Gabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUBWNDO ‘898Z-8T aSeD TWLINGTCIAINOO [BNO P9399jO4,] BY SGAdaD |!

The text on this page is estimated to be only 41.82% accurate

S61 FOORLLANO TVILNAICIINOD P61 POORRALINID TVLENSCLINOD JeayePy poyoajo1g WYSUAdOD JCLaB po9d0sy WysAdo’ [2 co? Aqyiqe Joy Adijor Surmoys Apog dh popind AW I9AO SULIOOUS pu pUeY Joy JO YOR dy} WO MO]Q prey & YUM ddRJ AW SsOIOR ou BUIVIIY Aq UOISsos AIOAS JJO YSU O} SAO] P[NOM sys usy], SAO} pue sdiym Jo JunoWe d[GeJUNOULINSUT UL YIM SU STPUOJ pynom oyM ssonstw AW se dude Jay YUM uayo YoessyuT OM SN Suryouem Jo [eodde oy) oyur Sunzey ATpinsqe sem Adljjor Wy} SEM MOUY J [[V “S9eTd IsIT] SY} UT SY} OFT Joy 309 yeYM Japuom yng djay },Upynos | pue ‘oul yse 0} 919M NOA Ji AZBIO Afoynposqe sem ays ‘ured Surziuose ul yuatuysiund Jay 0} ponpqns Ady) [Wun SOAIUy Caeys dp] YIM Jouped xas Joy SuNino AyyenjUsAd puke ‘suNWY sulddiym ‘adepuoqd pdao] ays *X1JBUIWIOp & J[aSJoYy palopisuos eusy ‘WS JO pom oy} OJUI UONONpPONUI ysIY AW JdYe JVOS Puke SSdTYILdIQ JO] SEM] “WUONONPss Jo joe SUNLUIWOP B Ul Apoq AU JO YOU AIOAD JOAO OY} JOY BUIYOIEM PozI[e}UL}] BUIOG SEM oY SB POOUURLU 19919 SIY DAONS 0} payleys oH “ounjeu ysour Aw uodn souessAjap JO MOY UL 3]RIJSOYIIO O} 19Y JOJ SuIMILDA SEM BY DOB] SITY UO YOO] 9} LUOLJ PUP SPIBMUO JUSWOUI AIDA Jey} WOT “UJIM 0} UMOP Udyods SuIaq 0} pasn }, USEM SY VY} SU} SULIDOUTWIOP B YONS UL Op O} WY popueWiuOS pey sys se d/qQv] SdesseU dy} UO UMOP su dA] 0} JOY JO} soedS & OpRU oY LUOO] 3} JO JOWIOD SY} Ul YONOD [[BWIS dy) 0} IOAO BULAOJ, ‘SsouoNbsa}013 JO aouvpunge jeoisAyd & Ul [eSNO1e PasedJOUL Siy SOUNOUUP O} JOAO Pony pure dja/dwi0d Suldg ivau ds9yMOU I8esseUI dy} poddojys ApjuR}e[q B}] ‘90R]d ISI] 94} UT SUI USAD pey OM UOSLII AIDA SY] JO UL}S TY} ‘19YIO YORd SUISSTy Hels 0) Sn SuNsanbo Apeale sem pue Joduo] Aue [esnole siy ulejuod yOu pyNnos oy {NUN ayo.s AisAa yum dn suidasy ‘syooing pue s39] siy dn saow AsoAd AU POY dYS ‘psoosoe siy uodn ‘Apo dy} JNOge JOY MOYs 0} UIdSQ JOY 0] pey [ pue paq adessetu dy} 03 SAOUT O} pojUeM Adar “uNY Sulodwued A]JENP IdM S]IIT BSLUID}] OMY JLY) JOVJ DY} PSAoy Ayoynposqe AdIjjor ‘yam seve Apog Siy Bulysem peasy joexd AU UL POMOT[OJ SYS pue }xX9oU JoMOYsS SY] 01 JUDM |[e OM UO AA ‘00] LUTY aBesseur O71 URZAq puke [Jam SUOTONISU dy} YOO) vusy “AyjeoruyIAYL JOO} SIY JO sayose ay} Supjo.s pue SOOIID [[BLUS UT BUIQQNI LIRJS PUL JOO] JOYIO SITY Dye] 0} DY SUTT[9} ‘SoNp SJURAIAS B YSNOIY) dy YpeM 0} OW poyoadxe Aoljjor s1oqM “IOMOYS Ued}S B pey [[v UloysNd Jo yNO ATsitj om ‘OOURIBOdde BULYOO] [VASIPOU S41 JO} 71 jnd 0] pasn ] sv ,.uOssuNG] SIL ],, JO “W001 SdRSSLUT SY} 0} 105 9M TOYA, ‘UdDSIIOJUN OS PSlUd9S SFY) JO []B UdYM SAeP 3y} JO SU PAPUTLUDI JUDTIA}TOXS YONs ul HW Jnoqe yeods asjo suOSTIOS Butsesy jnq si0luAUR SUI O} INOPULIT Os patudas Josuo] OU pH ‘TTeEYy AJBA9 ul possed 3M JPY} LOdap puv YIOMTIL JUdSOId DY] UO BUNUSUIWOD “19UI09 AIOAS JB IMP [10] UI SVM OYS UOISUBLU Je[NORJOOds SsIy yYsNoIy) ABM INO opelu OM SY "YSNOUS ponSI4Ul PoUIdIs dY UOSBSI DUIOS JO} jNgQ “SI EY} ISIM SOO] ‘yejnoejoods SulyAue JO INOYOUY ]e10} & BUIDq JOU “Aep SIy} odesseUI § AdIJor Ul SLU Susisse oq 0} SEM eUSyY JUSIWOZeUTe UMO AUT OL, 19 ‘NO SUlOd P[NOM YIN) 9y} Jey} SUI JO 19}]eW B AJUO SBM 3] “AUedUIOD SIY Ul dq 0} JOYyJOUe IO ABMAOS Ul JJO 1YdNO aq 0] pouldds pur ‘SUTYJSWIOS PaslWIOId sem QUOAISAY “STIQIYX9 Jv 1S9aq 9Y) pue > A'N Ul SUINaSNUW OY) ][e OY} Ul YIOM JOY SARY P,dY J9Yy BULA} “Ise UB SP P]IOM dy} Joy SuIstwold ‘yom Joy SurAnq sem oy yey) AJOL WO] 19}¥] INO punoj | “Apoq Joy JO} oBueYOXO Ul Jay 0} SuUIJJo sem oy SUM }1 LYM PdJOPUOM | PUR s]qeddOU A][PPO SEM SSSUBSO]S dI9Yj SB “JOW pey Aoyj ueds out) WoYs dy) Ul 1943090) Jdoys Apealye pey Ady} JVY} SUI 0} jusiedde sem }{ “OpuN [[e} 0} SpIIS sty poxl] oY yey} AIOS9\vS JUSTAIOSqNS OY} OJUT HJ OYs ‘YONW Os Joy pox] Aoljor AYM puvjsJopun ust} p{noos | pue Joy noge euossed ATqqngq e pey ays “AeTdsip uO sem Ylompe UMO JOY JO STUOS SIOYM ATOT[eS Ae Uv 1v JOY JOU pey AdIjor ‘eUdy SEM SWLU JOY ‘JUdOp URISY JO °0] ol poonpoyU! ATyeULIOU peYy AdIjjor spIs sno0o3103 peop doip 9dAj0919}s UOUWIOS dy} 0} SULYOO] [eNsNuN sem sys “UY YIM sons & pey oY pue OU! IOJ SUITIEM SEM OY BOYM DOJO STY O} JUSM J “UH pospo,mouyoe Adljor WTY MeS | SUN Se] SY) UY] J9}}0q YON BULYOO'T JYSIYNO ied solu ev JJosAu Ang 03 0} psojye yonut Ayjo1d prnos ] dn poaes siejyjop puesnoy} u90iJ1} JOAO pey | Jey) MOU pur ‘ou SUC} B IO} JOFeUdd] AJDAD SOAIS IVD B WIOPSdIJ 9Y} JOJ Bujiem usoq pey | ‘Yyowol AU UIYUIM ATTBUL SEM IO} BULARS UD9q PRY [ Jed yey] BsNvdAq Jeo1d SEM yorym ‘sAep OM) JO} opeul ATjeNnsn pey | JeYyM uey) sow dn poxy sem | OT t0;deqD ‘PUDYOOM FULUILJIIJUD UB O} JNO BNFEdI[OO SIYy SUIJBII) JOJ OU PaMmo oy Aouour ou) dn oul xij prnom Aolpjor a10yM “AN O} ABp 3x9u 94) YATE] IOYIOUL YOI9 0} pjo} aq 0} AjUO ‘YoRog Weg Ul YOuq pode | “AppNyyxuey} ‘SUOI}OSIIP a]eiedas Ul JJo ATpaLuny yjoq “ocure ay} ul [RUTLUIO} 9Y} WO1} $,dhq-poos no pies am se 911[0d 00} 9q 0} SUIALY WOLJ JUL POAks yor “Suryoed pur jsvejyeaiq uey) 19Yy}0 SuIyjAue JOJ sUIT] OU Pe OM puUL SPWOUL 1S WOI IST e SuUIYyoed YJOG dJaM 9M BUIMIOUI JxoU oY], ‘paq 0} SuIOS slojoq poysiulj sem oy UsYM A’ OY) JJO UiNy pue sJOWIAI oy) 9SN 0} MOY WIY PoMmoys | ‘AdJor 0} YowQ 11 oyLUI pynos yey) Aem Aue ul wuy pojuroddesip 1, upey | podoy ysnf ] ‘yi onde 3, upip | dul Oo} sem ysonbos }ey) se JeI[noed sy “WOOl svAT] S, AdIpJor UT SALAOTU SuTYOIeM dn Avs 0} powuem snf of{ ‘pdqg 0} JUdM | SIOJOq SBBSSEUL IOYJOUL OHI] P.dYy JI Poyse | ‘QUIM Pol pue XBURX JO [12] 4909 poxIw AW puv JOUUIP Jaye YSU yey], “UO 1oje} deu v savy 0} BURQKD SIYy 0} JUDM OY AT[PTIQUSA “Soqed Jimy Sunes pue souizeseul Suipeal jood ay) Aq jusds om UOOUIOYe SY} JO 1S91 OY, ‘YJVOUIOPUN SUIULUIMS YST] YOIEM pue YSOUI dU) YSNnosy} 99s pynos NOA sem ‘YSNOY) Ht jNoge [OOD AT]ea1 SEM Jey AA “LUIS 879 $0 rEgebed ‘OEZ8zZ9Z ‘6T0Z/60/80 ‘8Zz JUBWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 42.64% accurate

LOTPOORRTAINIO TVLLNACIINOD 961 POORAATANID TYLLNACIINOSD [suo prooesy 1YyBWAdoD 9 [evairyy porsajos| IYBLAdoD v9 IUIOBN [opoul-Jadns pours ‘Aped Aepyysig s ,ouvpsiyH pue Aoljor JO PUD} ISO]D B IOJ DOURI O} TULOD 919M OM “Pojloxo OSs sem j ‘HOdssed ISIIJ AUI JOJ 919M ‘DUE []3} 0} psdd01d prnom oy se “WIY 0} SULIq 0} pey ] souryord ayy (07 SAY },UPpTNOM | puke ‘UOTSedd0O [eIDOdSs B UO I IkaM 0} HRM } UP[NOd | ‘aplyys AJoAa Aur WIM ABMS pUB YSOOMS P{NOM Jey} SI9AP] OM} PRY 1eY} SSaIp on]q AAR Jopynoys dy} JO JURSoIO UR ‘Aep dU} JO} spuly Aw wy pomoys j “Aouow Suiddoys pure ‘jstjAysuey pouMmoual & YyoNs 0} OW Suspuas 10J .NOA-yuRYI,, daNeOoIdde ue YIM pada fj *,.ue} SUIMOTS InoA sjIns ‘apuoyq SOU DUO 9A .NOA ‘HEY INOA YM OUOP 9A NOA JeyM DAI] [,, “OYJO 9y} OJUI Suu []vo AdIJor pIedy | 19}e] JUOWOW Y “PUddIS kB JOJ JRIS B DALY O} SU PjO} PUe SW UWOIJ LUDY] YOO) sys “JOJ JOM S]OYspesy dy} WeYyM OW BUITI3} JOU [[NS ]eAlWe AU Joy SuTEM Sem jURISISSe S Adiffor JIOYM IdIJJO dy} OJUT So}OYd OM) AUT YOO) puke payse Ady} se PIp | ‘Adjar Jo} 113 eB se pasodxa Ajjenxas Sutaq s}oys Apog jjnj ut Sursod 0] pasn aol sem | “WYSnNoy} | Sonbas plioA, ‘SOYJO uURWeYURY] S, Ayo 0} UMOJUMOP WY} Bulg udy} sojoyd G'] OM) JOJ Woy] Yse pue 910)S Suldojsaap-ojoyd & 0} OF 0} Posu | SW PO} PUR SUI pajjed suRISIYH “ou JO} d10}s ut astuduns Joyjoue 4oA4 pey 9} "[NyNVIDQ OJ | ‘UBUIOM BUNOA be YM [413 Bunod ev poorjdai pey | 9x1] Surypooj a19y} JO Jno poxyem | ‘AyyeAoI ayl] posoduied aq 0} “duizewe sem }] “YOO] MoU B JO] .1eyay Opes, JSI[A}S A}11GQ9]99 JO UOTRS AJNedQ SAISHIOXd dy} 0} JUSS Bulg Jo do} UO ‘ssoip ASSB]O B PUTS O} UREYURPY UMOJUMOP UI SuIddoys OF 0} sIe]jop puesnoy} Boul dAes AdIjor UsyM Aep 1xoU oY) posidins JayyIny sem | "SSOID 0} JOU SOUL] JEYM MOUY OYM 9SOY} JOJ SEM NH pue Surdeld siam OM OWS OY} S.JeY) INQ pIeY I Udye} 9A, P]NOM dyg "SMOU SABP19}SOA D1] POpIVISIP aq Ppnod nod Sulusem Aue INOY}IM }xXouU dU} pue A[qeiJOJWOd sIY JO JOxUR{q 94} JopuN yes NOA Aep auo ‘Aaayor YL SPM }1 MOY S.JBY} INQ ‘aTIYML pue 9dU0 YIM dn Yo}ed O} PUSLIJIIS & 94IT ‘puaLy e& se iay doayx 0} Ayiunyoddo ay} 34k} Jo 9Aq-poos Aes 0} 103 UDA Jaaau | ‘Asnoyeal 10 ssoulsuryo oy1] 1, Upip oy pue ABuljd 00} SuIW039q SBAA JUS PIkS 9H *..ISI] JL]NF91,, siy Jo JfO JOY JO pl Buljyjosd jnoge Suryury) Apeole Sem ay pies AdIpjor “OSN O} WIY JOJ JOO} & Js! SEM OYS JeY] JOB] 9U} 103 1, UpIp sys ‘tuTY YIM Sdiq} Suo] UO YBNOIQ 308 1,upTp sys AYM Aorpors pue st SuruorTjsanb Joy YIM pur ‘UO JUSM OWT) SB JUS[OIA 91OU UdAa SUINDT SBA SYS “SUI[IOJ SEM | IVYM AdIJJor [[9}] 0} pey | PUL WOOIPs oy} ul asnqe ay} Jo YSnous pey A[jeuy | doJoq J9Suo] YONW OO} },USeM I] ‘19Y}290}) posinpud 9M SUMOP 94) PuUk Sdn dU} JO [[B JO} ‘BUDY Jad10} JOASU [JIM | ‘PUSLIE JVOIT B USSG SA PjNOM SYS WIS JSUVST Joy IC} OU FI Uae] Suizeue uve savy pip ATpear ay “UOTeIIO Jay ye jjosAw YoRqe Udye} SEM ] 90k] ATU SSOIOR SUIMO]G Ney Suo] AW JO spueNs sy) YIM YW Surdeys ‘Aelo Jo JNO JOYSpeoy Aul Jo aseul ue poydnos sys “993I1d UMO AIDA JOY Pans dys WayM . Jy JO lunasny uRW;OdOISW,, S$, AN UF UIqiyxe ue Jay 108 ay ‘ainjsad Jay Aq paaoul A]SNOIAGG [IIS & MOYS LUTY UZI9S he IOAO pey J uoNRIDoIdde jsour oy} seM J] “JUOWAed JOY se Ysed Jo peM [Pus B Joy pepuey oy ‘Jojjo 0} pey Aoajjor Suiyy Ajuo oy} ‘opryyess punoyoid STY YIM Joy poyst][aquio pue Ajasnjoid 19y poyxuey} oy s1ojoq punole JOY PIPJIM) PUL PUNOIS oY} WIOIJ 1OY PSYl] 3H “YUM TY payuasoid pey oYs opmyrusew puels sty} Jo SurpjAue Suyjosdxo jou sem nq Jayjo90} sn jo Sunured jjeuss ev yonsuod 0} 19 poyse Asnoracid pey aq se 1419 Joy Aq popunojse Os sem oH “Poy AdILos Wwe Jo pury yeym Apoexo s.yey) UMOUY dA, P]NOM ays jNq ‘I JO SSOUPMd] OY} SOpIsog *YIOM Jo soaId Sulzetue ue SEM }] ‘S]IIIY) S,Adijor JO opis Joyep oy) Aensod Apysaj1ad 0} poyerjsayoso0 Ajjnjored AJOA {Is sem oinjoid oy} OpusNUUT [eNx9s YIM I3qj0 yors ZUIIOOS a19M OM YSNOUIY “JOYyJO yoro Suloevy uoyIsod sued pue BuIA B UL opnu BuIA] | pue Joy Jo Suyured [10 }OOJ-xIs Aq JOO} xIS B YM Aolyjor posuidins sys “AN 0} 9eq diy oseisAe suQ ‘diyspusly sdueys INO UO [[O} S.}1 BUTE] SEM SIOQUILYS OBESSEW 94} Ul 9OURULWLOP 94} nq spusLy se Apaind 19y}0 yoRe poxl] Aypeor 9M ‘pies | xT] “ezZzZId 9] A}s J) A'N Aseaid jo aoaid juris & OJ SOAjaSINO Sued} spleMIJ9JL “19Y}950} SUIMAISNUI LE PUL {LOTIO}STY [CIOADS JISIA JO ,.LIDdQ 94} JO WolURYd,, YOIEM 0} 91]L9Y} 9Y} 0} OF 91] SBUIY) UNJ PIP 9M S}S919}UL JB{IUWIIS JO JO] & Buraey “9jqQusedg Jey [[e 1 9peul OO} sSuiy) yeuLIou Sutog ‘deus 0} ZUIOS SEM SUI JO OpIsSUT A}ISOWLUL OY} SIOJOq SUIT} JO Jo}JeUT B ATUO SEM } nq dAd puUl[q SIY 0} SPUdL POO Sv SSOIOR SUOD UdIJO P]NOd | puke sys ‘Auedwoo sty ul sjqeoorjdai Sulog SARMIR ‘P[NOd ays ey) TUTYJAIOAD UTY SAIS },UP[NOS |] YUTY) 0} AojJor JUeM 1 UpIp Ist | ‘JAI WS JO speieyo SIU} JJO POY pjnos | Zuo] MOY Ns },USeM |] “SSUTBOQ 9]qQeJeaquN puke xdS JUDTOIA JO UILWOP SWOSIIN}O} & UT BSOO| JO] URWIPEUT B SEM OYs 1YSNOY} | MOYS IO} [PY “UswYsriund Joy SUIATAINS Jo AVM JDYJOUR Isl SEM }I OU O} jNq 9UO 19Y4}0 9Y} NJVUTWOP 0} SUIALIS YO ‘sn UsIMJOq AI[BAL BY} PIAO] AdIJof¢ “UOTJOIOSIP pojsiM) Joy je Bulog sABMje SU JO peojsul [jim AW ye Joy SuLyew ‘Jay UO sorqe} dy} SuLuIN) SW JO OURUDIS 9]qQeIDIpoidun ue a310j ou Suidjay “ysnoyj apis Joyos Aw FuNKdipess ye POOS sem 3yS ‘adesn Aut 10J no YoId 0} P9yI9x9 SEM SYS SUO ‘SUOTIOI[JJe JOY P[IM 0} SUOTISOd SUTSTLUOIAUIOS ISO 94} CUDSY BUTIOJJO “1oY}930} Joo} pue spuvy Aw Jpno oj ouids Aw Jo yorq oy} UMOP Ped] JeY) Ie]]OD poppnys Joye] YORIq & SEM DUO dILIOAR] STH “[eU9}eU asepuog pure sAo} xas ‘s}JJNO AXds JO YOM SIeT[Op JO spuesnoy} yorq UY SULIQ PINOM 9M UMOJUMOP S310}S Kas APSOS PUNOISI9pUN dU} JO [je 12 1ayj030) Surddoys no sn Surpuss ‘9° AN 0} INO sdiyj satsus}xe Aut SurMmp OUI JO} 9U0 pey dy dsovId SWIeS OY} Je JUSUUEde UL JOY SUNUDI UDAD [BIDITJO uv BUSY Opeul sy SYIUOLU UTYIM JEU} YON Os dn Sursted sn psaoy] off "alope 0} pouldas ay YOY ‘WY 0} 4[e) Aqeq ul Suryeods usd pue A[SUuIAo| siuad siy Suryors Aoljor YIM o}ewW UT ApIopus} aq puke Usppns ay} Jo |e ayisoddo Os 9q pjNOd BUS °90JO} SW9I}X9 19Y O} JOPUDLINS SI9YJO SyxBLU O} 8179 $0 G6gebed ‘O€Z8Z9Z ‘6102/60/80 822 JUaWINDOd “898Z-8T BSeD

The text on this page is estimated to be only 40.71% accurate

661 FOORRLLANID TVILNACIINOS 861 FOORALINIO TVLINACTLINOD Jeusyepy poyss1es J 1yBuAdog | , [vuayepl p9yoajosg WYTAdoOg || 99 dy} 0} payeoy yorum ssoup Aw poddizun pue ou purysq dn sures ay se Suipusosapuos sem asuodsoas Aw 0} 9]YONYS stp “soe Issy oy} Ul Susu INO Joy posuvsle AoIjor Ud WI Joy ope Apeosje sem uorssoidut Aw Jey] UdATS ‘YSNoT) pulw ur pey sy JeYM ATX JON “WOWUIe}OIUS s}ysIU SY} JO pus oy) 0} oyeuyy ev you pure ysidesoy) ev ATTeN}OR Sem | UOTssoidul OY} UY SAIS 0} payuRM J ‘19YI9T0} SWI} ISI] INO Burlaq ‘possoIpun Bu}O3 seM dy O[IYM PUNOIL FUIWIN | “919Y} USAD SEM J UOSBSI AIOA dy} 01 YSU Sula ‘avid Sly Ul PUODIS B 91ISBM O} JUBM 1 UPIP | “JOANP dU} JOAO 11 peaids pure paq sty JO pus dy) Je atid pepyoy APeau sy} Woy dn poyoid pey | yey) [907 9y} Jo do} UO AR] Puk SSoIPUN O} WUTY YSe 0} pey | UY ut oy YNOA JO SjIq BUIWIEUIDI OY} JOJ MOYS 0} }f9] Jey UMOIQ A]INO JO SJUBULUD SUT[SPLS YIM URW BUIP[Rq “YWOYS SIq} JO UOISIA OU} pie JYSIUU JI JI SB DUO} J9]JOS B O} WOOIP|q Sty Ut S}YSI] YSUQ 9Yy} powUp | "SSOUNILP OY] OJUI JOZuLIIS Sy} YIM JJO popesy pue suoTONIJsUL pooyssgpuN AW JO UOTBULTFe wuIYy dAed | “s}sanboal SIy JO NO ssny v ape I9AdSU | ING 9}R] Sty} dn Aejs pnoo Asyjar poulsewl JOADU 9A, P]NOM | a7e] OS Suldq “JyYsNoY | ppo ose jnq sureU SITY JO 9UL popurwios oy AyjnpyuRY) ‘yOrY YIM poysiuy sem | Jaye WOO siy Oo} YoRq JUIOD O} SLU PjO} Addjor “SuLUdAd yooJJod .JSOW]e,, UL UIT 0} AdeSSseU S JYSiu B 1OJ JNO SLU UO] 0} JULeNb }I Mes dy “ADIZJor IedU $9dvI}00 34} JO dUO JB BULARIS *_ UONI,, PAl[ed BOLIOUTY UI UIBYS ddIe] SWUOS JO JBUMO [JOY OY] SEM OH “UILSL SUIJOOUI INO JO SOINUTU ATF JSITJ OY} Ul oWeU STYy J9QUIDIUSI UDAD ],Upynoo | Inq ‘poonpoul useq Apeolye pey om ApjuorIedde pue ‘189 94) Ul jsand B pey oA, “SUIUDAS [[e SuloURp puke BULULIP dy} uloly APprs sem | YSU 9Y) JOJ Jed1}91 0} IVD SY} UT yOeQ 103 OM SUIT] ayy Aq puv 1WORN Oo} ,,Aepyyig Addey,, sues pMoOdO oIUD 3} “Yseq unj Be Sem Jy “UMOP TIvYy AW Jd] 0} ponutjuOd puUe JOOLJ 9OUep 94} 0} YORQ juam | ‘ABM JSB9] 94) Ul SW oseYd },UpIp | pue YIM BurOURp Udeq ATyenjoe pey | Jey) sould e& sem j1 Jey) Avo Aww ul Jodsiym Apjornb 0} Joao pours] AdApjor “SSejB 19YyJOUR IOJ d[qe} DY] 0} YOeq sd At JO 9UO UG “dU Jo 941] OY] OJ OWIBU SIY JOqWdLUdI },UPppnos | sudedweYs Ajqqngq oy} Wol; djoy dy} JO [Te WIM pue yysTu yyy souLd BuNoA & YM psouep | ‘SUINY pj1oOmM ay) Aem oy} ysnf aq ysntu yt qt Jo Suydosooe [[v ose Ady) pue s[doad asayy 0} dn SyOo] SUOAIDAD JI IYSNOY] | “JISSAW 0} Jsvay] Je “aTquWOUjeF 9IOW Ajayey Surat] sem | ABM OY) opetu ATIVsU POM S_,Aepo} JO poulsaysa ATYSIY JU} puke payeonsiydos jsour dy} posJopisuos s19M Jey} o[doed pepurway|] SITY pue sondvajjoo s Aoyjor JO Aueul os Aq popunosins sursg “Auvduoo siy ul stu SAvYy O} pnoid WIY spew | Mouy ] sea] VY “Y8noy) poos jaoj ou spew j] ‘ooR[d ysITJ SY} Ul STK p, Ady} WYyBnoy) udsae oy AYM MOU 7, UOP | “LUdY} Jo jno Sulmnod Asuow yontu os pey ajdoad asoyy, *s,opad MOT]aJ Sy 0} osnossew SUNOA Josed Sty JJO MOUS 0} apise du SuL[Nd ‘MOU SUOSWIOS 0} SUI O} PONPOIUI p,dY Udo OS AlQAq “udy} pue Mou AJBAN DUBedWIeYD JO sse{d JoYyJOU qeId 0} A]UO ‘sem S9 SY SIOYM [GLI SY} 0} YoRq SULUIOD ‘JOO soULp sy} poyxIOm ApURAONG [ se poyojem pue xoeq Wes Aoyjor “SUIAZZIP stIBI9q PUNOIR Wd} POMO]]OJ Je} USUI YOTI oY} pue [SPOUT Joie [apoU Oo} poonporUT SUIog “01 US9q IA9 pey T Yyseq AepyUIG AjLIQ9]99 ISIIZ SY} SBM JI OUIOD 0} Ajsed ay} JOJ JUSUIS}1IOXS [99] nq dyay 3, upynood | ‘yseq Aepyyigq ureur sy) ye souRIesdde INO SALW 0} IGOR A 9Y} OT ApeNJUsAs om UdYM BUTUDAD 9Y} NOYsNOIY} sjUsUTI[du0d AURU BUIAINNOY “BIVOSVU OY} UO PoJdAk] PUR spUeIS Ajnd Maye UMOP BUI] A[UO “di[9 poisiMy eB UI Mey Buoy Aw dn ydams | ‘SSOIp Yj Ul PoyeoLf | JI SV [99} SLU opelU puke [eUOTJBsUaS AjayNjosqe SEM I] “ssoould & ayI] SuUI[ooy pue UMOS [eq Mou ALU BULIBIM PdAO] | "SABI SUNS JSIIJ S.1BdA DY) JO SLUOS UI YROS 0} food sy} 0} UMOP popeay {Te dM dIOJOQ WOOI SIY Ul OBesseU v ADTJJof SACD | PUL [9}OY SY} 0} YORq JUSM IA\ “JUDAS S _JYSIUO] JO peoye Ayed o10Jaq Sy} JOJ SUT) 9} Je ,,SUID9S Jo PULY,, SEM SYS MOTAF BJO JYORA & PROIQK SN }IAUT 0} UI Ot) YSNOUd Jos DYS INq dSIOAUOD Ife 0} SN JO} Ased }1 SYBU 1, UPIP YoryM ‘Suey pue spuay ‘sjuRSISSe JO ONnZea] & Aq popuNo.wins SEM SYS “NS IIOY} Ul POMOT[OJ pue poonposjui sem | usy) pue “Aepyytig Addey e Joy poysim pue syxsoyo Joy possty Adlyjor pue auvystys ‘oxo! AJOAd Joy 1v Ysne] puke pom AlaAa Joy JO JJO Buvy 0) powises ouoAI9A9 pure ‘Auunj ‘oyadious sem BUsHeYyo JO} ‘[NyyNeeg AjZuruunjs pur [[e] OS SBM SYS “LUNI S]IMSLUIMS dy) IOAO 08 0} LEYS lurul punose deim ev pue do} 1ULyig Haq & ‘s0uRI UayjNos punole Bunnys oye [eoidd} ou} SulIvom sem sys ‘TJoqdtues 1w0eN JO9U 0} 103 ISI] | DOM S.JVY], ‘suoIed snjoodsold Jo MOPf JUBISUOD 9t} JO} ABM SYVUI O} JARI] 0} POyYse oq P_NOA “I9}eM Oy] SUIMOTZ UONdLUNSUOD joyooye oy} Surdooy JOU INOA JI pue sJe]JOp pospuny OM} punole $}soo ousedwieyo jo sse[s deayo v soy “qnid yoeog HIN snourejul 94} Jo Surusdo pues dy} Je YOUN] O} JNO jUDM 9M Aep }xoU OY |, “Snowy pue you puodaq dy} JO spunois Surdwioys onNsTUOpsy oy} sem jf “sJojIed Aynevaq pue sdoys onbynog YUM pout] D13M $]99MS 9U0}S3]Qqoo a]A}s PJO YL ‘[910Y ou} SpisuT siojeNb svJedas UI pods | pue Aug o]1yM ‘spunosd dy} uO yJed oy) UO ‘sadE}}00 ayeALd 94} JO 9UO UI BUIAvYs DJOM URISTYH pue Aoljjor “yewIpue] sAlssold wl ue sem ,.zadoly, 1S oq opuseg e’],, “‘URdURLIOIPSP] 9Y} Jo sdURBaI9 OT} JO [[e Uy ‘yeoy Ul ssop Surdsey oy] punole Woy) SUIMOT[OJ dJOM Uo oy} pue JI OJUT pappoquia [aqe] JOUSISOp JO Pury 9UIOS YIM pepueksq sdo} TUDyIG Ul PASSdIP dIOM USWIOM Ppodyoo] NoA aJayM AIOAD pure Jayjyeom Burids [NYMNeAG SBM J] “IE JO JUOI Oy) UO oq ATaitUIZop pjnom Zadoiy, 3g ‘psvojsod B pey yeulyjeH J] “oul wisy nos ul Zodo1L 4G Suloq uoTyeulsap [euly INO Udy} pue seg ‘UOPUO’T 0} Sulod Jsuly [Udy ApIwS UI IO] AMM "yyy Surppedde oy} toy yasAw ydo}0I1d 0} dn ynd pey | S[JeM oAISNyo oy} puodaq 29S 0} SW IOJ JOpIey WI spew AjUO jy] “pplom dy} SuoNsqgoys pue sored oppeis0s Zulpusye sem SUILU 9AI] PuNoIsyoeq B YM 998 AU [IIS JY ‘JUDTID]IOXS YIM PodOl-JOAO Os sem | “[JoqdueD 8179 J0 96Gebed ‘OE78Z9Z ‘6102/60/80 822 JUaWINDOd “898Z-8T BSeD

The text on this page is estimated to be only 42.33% accurate

1lOZFOORELINTO 89 YUM [IS B OUISRUM } UPfNOd | ‘UONeoUsd pue Avjdo1oj Jo sjow UeIgsoy Ul SIDAO] SB JORUdOI | PUR JOY Jey} poyesysul oymM Addjyjor sem yf “SUNOOU “4SII INO BULINP SALUT] [RIDASS YIM JOY post[go | YoY ‘osesseul v poyueM OYS JI Joy 0} Dope O} PjO}] Sem | USYM JSoNs B SEM LUIPURXITY JY} Jed]o JI spew AdIJfor *S WWOIIIJUT SJJNULLS OY} UO JOT] SN Bulsesy JO ino SyOTy Jay JO3 ays ‘ySnoy} [IAoposep v [fUS ‘JoTId oarssoudun ue ATPEIMOR SEM OYS ‘HL [je SVM FH JQ ‘Ile sy} Ul LYSUTJe sn yas 0} JNO sem oURISIyH “NRdISNOD Your JoJo] Axo JoJeMIOpUN pue YUL} eqNds oY} JO 1OJUDATI 9Y} 0] Jo]ySuep puvsd oy ‘nvajsnoD eupuexajy dn poyoid om osoymM uYos 1S O] | pue Aarjor Map pue sue so1V9RId aTIOS 193 0} pojUeM pu sSUdDI] s jojId 1yjdooijay Joy poureiqo Ajjuade1 ysnf pey sueysiyH “pues! oy 1V ‘IOY Oy} pip sAvmye | Se ‘No puly 0} pes sem jj “UONSIPpe Jo ayoy yor][q 9y} OJUT Jodsep puke Jodsap Suryuls SEM SYS JVY) d]IyYM & Ul QUO SaduRjUIeENboe Woy Sursesy A[UO “pjiom Buljoe Oyj Ul $jOR]UOD puk JUSLEde Joy ySO] SYS ‘UONUSHe d1jqnd Ado BUTSOD JSOW[E PUL BILJIOM JOY SULYSU “Sup [esaj}I UB YIM sIops0q [RUOIJVULOJUI PISSOID SYS UdYM IL] OO} HI YOO} YRIES “oNOdIeU [eso] B SUID aqqnod wiy ssned },UP]NOM |v JO JSOU! pue [eoTNs.eULeYd sem P asNed9q PULW }, UpIp sy YyoTyM ‘xeuex Aut 10J Jd99x0 ‘sdiyy Aue Uo sn YIM Suoye Wd} JYSNOIG JADU | SB BUC] SL O[TYM B Ul 9OUO SSTUP Ur pojqqep | 3ey} PULL} UPIP dH “YOO Ss, Addjor ul ABMIO] OU PRY SOYSIM SLY 4O SOATOSMDY} Joj yadsoal OU YIM SIPPY “OF JOY 19] 0} INQ Ssd1OYO OU peY dy pres 9H ‘UOO1U}eq SY} UL A]SSO[9IVO JNO }Jd]| 9UIBIOD Jo YseR}s B Puno] Ady} pue WOO Joy SUIURaTO d19M SIodsayasnoy dy} UdyM puP SAep a]dnoo ke IO} spudsy sTy Jo suo UJIM PUR]SI SIY 0} JUSS Ud9q PRY ays Jey) SWI Plo} AdIJJor USYM popunNojse SEM | “BUIYJAWOS JO JINY Ud}}08 pey sys SuryUIY) “osIOM 9y} SuNdodx7 ‘Jay jNoge SMU PRq JULOS peY sy PIkS SH “JOY USS JSe] pey 9M JOUIS a[IYM B UddQ PRY HU SULUONUSW ‘sn SUNSSUL 9g P[NOM YRIeS J] poyse | Pure DAN Ya] aM Jaye purest dy} 0) JUaM AQ “SSOUdSO]{D AU pue S$, AdIJJor Aq pauszeosy} 1[9J 9ys Ji sour] ye Suopuom ‘Aep Addey e ou poysim Ayuo oueyjstyH ‘Aoijjor Wo ssurses puoweip jo sed e pue dn-oyew SIOW USAIS SEM | SLUT] LIOYS B YONS UT PoT[oaey pey | Jey} suO|wUNsop d1]0X9 JO Suras B poye[NUNdde peyY pue IOTUUWINS Jeq} UddJUSADS PoUINy | ‘jnoqe seM AIO}S IY] yeYM JJosAuI 0} SuUOpuoM jsed yem sy) payojem pue 4oeq Wes | a]IyM Aq ssed pjJom oy] Jo sol oy) SuNjoyT “Ael B UO poyynd pue dISNU d1e[q 0919} ATU 0} POUDJST] | OTTYM SOABM 9Y] YoHEM pur ied AUI UI JIS 0} YOROG YOMOYRT O} UMOP JOY SAUP 0} SAO] Plnom | “WOpsaly Jo ayse) pue Aol pue opsid ysny Au sem oy “ul ynd wa}sAs punos SAISSoIdtu UB PRY A[dJVIPSUILUL pu ‘pos ALIOYO Ul BIOxeG s3poq & 103 ] ‘489 AW JO} YIU no Aed 0} 9]qQv seM | “Ia[Jos oyeALId B YSNoIY] “epuoly 0} yoRq 103 | se uOOS se BuIddoys Jed OF 0} JJO JOS puv JUNOUL sNoIOUNS v pied sem | “S7() 9U) OJUI YOeQ JYSITJ INO poousWWOS puv diy mo TVILNACIINGOD ELOY] poysojo1g py BiuAdoy 1) ooTFOOTRAANIO £9 Jo puo je} oy) dn poddeim om Aep 1xou oy] “WOY) JO SULIe oy) UO poos YOO] 0} sauossoooe ysnf{oJ9M | pue Aunug ‘saouevjurenboe pjo yim dn JYSNed suvjstyH pue Aojjor apy JoyyeoMm Auuns oy} ul suryeos ‘suiddoy yyoe x Aep oyj quads omy “ureSe JjosAw Oy! OJ pey | out} oy Aq UOOUIAYye plu seM ji soruuns Jo Jied e puryog a1qIssod se jsoq se Jaaoduey AW UIL}JUOS 0} BUIAT] “9dJJOO B JO PRdJSUL o[v JOSUTS B PUR s}a]qQe} ayoepeoy OM} YOO) | SUIMIOU }X9U OY] “OUI} OU UL IYSI] Be OF] NO SeM ay ATpNpAxULY) pue ‘dooyse {ja} oy se 399} SIy qns isnf 0} SW poyse off “TY SIU Jey] odesseUt sty Addjjor SAI3 0} PRY [VS | NG Pol) OS SeM | PUR d}R] OS SEM J] “WUIY O} JO] B JULSU I Jey). Ou Pjo} pue Sny ev JO} Soyo SIY OJUL OUI pay[nd oy “op Pinom JoyeF puesis Busvo & oyI'] ,.{OUOT o19M | Ji “NOA Jaye YOO] pynom OFUM ,, YIM popuodsal | pue Joyjo oy} 1d9008 3, UpIp | AyM au payse OH Wy Biu yey} Aosyjor YIM ysnJyj Jo JO] & poysiqeyss | ‘apd pred dulyjos UNY JOF YIOM UIOI O} SUI PosajfO OY MOY UDAD }Y{sIU Jey) pousddey pey Jey} Bui} ASAD JO WY} P[O} | “I9}VeU OY} SEM JeYM JU Poyse AY} US AA “UleSe IDAZ ANF JLY] 99S 0} PIJUBM J9A9 JOADU | JLUY “SYOOG B SuIpeal sov[dosy Sy} JO JUOIJ Buys 919M OYM ‘OURTSIYH pue Adjjjor Pjo} pue JOOP dy} YBnoIy) poysns | adey09 $ ,Adsjor 0} 103 | USY AM ‘JOOP 93¥}}09 sIy NO SurAuNyY pue possoip 303 Ayyonb suiyjas Apearye SPM | DOJOq INOY ue Jey e Jo Ays useq A[UO pey I] ‘SONULUL d]QIL.LIS) OM} UBY) JoSUO] OU Suse] golfmojq e& YIM dn way jnys Apyornb | pure ‘ayy AU UT YONWIYS JOYIO AIDAD WIOJJ JUDIOJJIP OU Ua0dq peY OYM ‘UO SY} O41] soared o[puey 0} MOY AT}OVXS MOTY 0} POPU | JY} OAIOU OY] OW OARS HT 1YS1U Jey) YUNIp pey | oudeduieyo oy} Jo [Je JOY “JeUlUL P[IM poroduny B oy] soyued Au JJo 1v9) 0} TuIA Apo Aw ye Burysiavs pyim Apowuay xo Buros sem oy ‘MOU sINsoduios Aue yoRG SUIPOH ‘Apealye 0} powsojsnooe JSBO]| JB SEM | IVY} OUO 9} YIM BUIYONS JJO Jo}J0qQ SEM | Pue [Jam 00} [JB Soseo asay} MOUY | ‘o]Ajsop1] podaytatid eB JO AQUOUI JO SIdJZO SIY Jo Aue Aq ul poiny Surag 1,usem | ‘JOIP! yuNIp e Isnf sem oy Buimouy ,,j/noA sked Aadjjor Joaojyeym o]diy ‘ou ‘ayqnop no Aed [IM | pue ow YIM Ae}s DUIOD ‘9JOJOq SITY} 241] 19} JOAou aay | ‘dU 0} NO Op NOA JeYyM AO] I,, OMI] SSuly} Surdes sem oH “Jus duros SuLloyepyp JoyJoue OUT suoTOe.SIP — AW JO UO AJOAS BUIUIN] UdARdY YUOADS UI sem oy A[quuoNsonbuy) SPL] pure dj1M Sy yNoge WIY BULASe UdAS YOO , JJO-WIN),, S1f} Ul SYOII OY} JO TIe BuISN SEM | “OU O} SUIAIZ SEM OY SYOO] OY] pue SuLyeiu sem oy suryIeoIq AAvOY 9Y) WOY purur siy ut SurAeldas sauroyos poyoarod juoredde oy) ULY) JOYIO dIdYMAS]S SJYSNHOY) Sty Puds 0} TurAd} sem | Se ssopjulod sem UY YIM UOTBsJOAUOD JUIeNb Tulyepy “osesselu B JOJ UMOP 1] 0} UTY Jos 0} pue oul Jo JJO spuvy sty 303 0} SurAT Aem Aut noe juom ysnl ] “Sulsas WOIJ SOAd SIY BULOPUIY O19M SoyjO[D Aw AJUNOG Uspply dy} das 0} poyuEM isnfoH .WJo no nod day [],] ‘Ouooms os9y ‘sty] Sulwam osesseul B SAID 0} OOdxd AT]e9I } UBD NOA,, BuLAeS SEM SY SB JOO]Z 9Y} JO WO0}}0q 879 $0 /6Gabed ‘0€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TWILLNTCLINOD [CLIOEYY porssyod.| USUATO’) |}

The text on this page is estimated to be only 42.20% accurate

cOCFOORLETAID OL ‘OQLIG 0} B19M SIS pd[qnos dy} se Asvo se jou A[qeqold ‘siy Jo iejynsol B },USEM SYS JNq ‘UOTSULYY S, Ad] Jor ye YORsg lwyeg Ul sour) ajeIvdas S1OIU MJ B IOY Jour] ‘sAeM poyled je om D194M LIPURXdTY 0} 9Aq-poos pres om puke yodiry s.uyor 1S 0} Ja}d0oT;ay SU} Ul [ye sN poajyoyId sueysiyH UOOUIOIJL SUIMO][O] OY “ASIYSNe] UI SUI} STY) “IOUUTIP JOAO UTeDe AIO}S SNOPUd.LIOY INO po[ed91 9M Poxe[sl sJOUW Youlu pue dn pousysoly ‘deu BU] & JOT SP9q UMO INO UI S3IPOg pons1yej no posdeyjoo jje pue pueysi SY} 0} JORG 103 9AM “JOYIIO ATyoINb Os SAOUI Jay UddS JOADU PRY | se ‘auTeU Jay ysuf sem }i ‘1ayeM OU} JO INO Jad 0} SUIAIINDS AT]BOULIY SN Jo [Je Je UN 340d 0] paploap puk puvyssojog Jo dd1]0U B BULye} A[dIeQ UDAD JlISIOY Jo JBSY BY} YOO} BuLISIYH “d}e]s poswds & YONs UI SIVA Ud] JOYyJOUR pase pey ‘SY O41] POYOO] pue sjooys JouSISAp sty se ayed sem Adlpfor ‘Pueysi Ss, AdIfJor 0} yORG popesy 9m UdYyM jsayo AW JO ]NO SuyRag [WS sem Jey) Wesy Ault A[UO },USBA JI MOUY | PUR YILOP payesyo pey 9M OHI] OF [[e OM “AZUOJJ SUIPIJ II9Y} O}] NUSTL SY} UO 9q 0} UOOS IIM OM JLY] ISVSSOW 1Vd]9 B JUSS Sulsq pue AJO}9} SUIPSOIQ JI9Y} UI 319M 9M JEU} UO 19}2] INO PUNO} 9M SN JOJ AYONTUL] “SATTE STY} JO JNO 493 0} Wwyeo Aes 0} pey | J[9SAwW Plo} ysnl | ‘AID JO WedIDS 0) YOOYS YONW OO} UI SEM ] OURISIUD pue AdIpZor 10];B MOT[O}J 0} 1X9U DY} 919M OYUM BLIPURXI[Y pue AWWA PUlYydsg poyiEM | SB ISIOM dy] GUISE VO 94} UO Jaz 0} IPIND 9Y} JO pesye UO jse] SY} SEM J PULY STI] SUIQQqeIH ‘pesyowUeYy IY} ‘SyIYS JO P9djq SAISSOITFe SIOW PUL BUIAJTLIO] SY} se soloods JOUIISIPUL SY) SZIUTOSII PfNOd 9M YSNOUd UOOS PUR JoTeSd]9 SUIeDAq SMOPRYS JURIS BSOULsyxseys Aq Wede Wo} Suljjos sem JOY}IOU NG 9de UII AJOAO} AIDA B JOU “YIP O} BSRYLIOWIY Pue UIeIG INO Ul JAaSsoA Pooyq e dod pjnoo am a10jaq pauses Ajsnotaaid osam 9M Se JO yoInb 0} dn 03 0} JOU SJvd J3y SuIpjoy Aq sn Sulpulwio ‘spremdn Surpuaose pejs 0} [eusis OY) SN DART DYS Se dDUO IO] POUdIYSLY poyoo] Ajjenjoe sue[sIyH “Jasojo pue 1osojo Suuesdde payejs sourjsip AyINUI dy) WI SulyANy] Ss. Mopeys UdYM SSAI]SIP JO SWHIIOS SUIWLE] SLY 12d 0} JOJVM 9y) JOPUN IL} OO} []L SI3M SAA PIP oy ANON] pue DuOIM JUIM BUIYIJSWOS dS¥d UT Isnf Jeog 9y) UO PoAvjs Pue SN YIM Oued ‘URTUDSNOY dy} ‘sayy ‘eUpueKXsTy ym dn posed SUM |] pue ‘AWUI pur sULTSIYD ‘“1941930} spiny oy} pue Adijor sem I] "PUNOIL WIMS 0} Bes potisep d[9]UST[O Po10q SIY SJVIADT]L O} INQ YIM IVIPIWWeZ 3, USEM OY Ples oping sno yey) SUO ‘UI BQNdS 0} Sd10Y9 & d}IND 3q 0} PstUsas J] “MOT9q UMOP PuUNoIe pue Ul SIMJUDA O} SJ991 JO LIDAR B YIM JoyeM UddO UO PojeNjIs IM IA\ JOO SUBDDO By} JO SUOIZSI JOyIep dy) OJUI ATMOS JUdDSap INO BuluUIsaq sIOIVM anyq enbe [e}sAId ay} OJUL JeOg By) JO YOR ay} JJo poduinl am pue sited OJul dn sn porppng oy “ojes Sem JYSNOU] JOJONIJSUI BQNdS dy} IVY) soR]d poosd & punoj om Alyeul “sjods ajqeiisop Aueul OS WOIy ABME 139A 0} PeY 3M SB SUC] OS 4OO) I] ‘Snosoduep Ajjenbs se 9q pynod ji seM }1 SB [NpNNeIq “TVILNACIINOS Jeuapy poyssjosg yysuAdoy [| ZTOTPOOTAAANIO 69 SB 99S P]NOd NOA jnq saovid Aueu Os ye dojs 0} poyueEM 9M Se AvydsIp UO SEM JJI] OUTIL JO ABIL [edIdos} ay} Pue PoUdjst[s Jo]VM Jed]O SY {SINOY SIOU Mj & IL pus}xo jou AYM ‘oov]d JSIT{ 3] Ul STU] OP 0} JOT B JO [Joy ev pred Sunnjes sem oY Jey} ABS P[NOM dy SSINOD JO “sIa}eM BS9yI puNoIe T[aM AeA STY MO] oY Jey} WUTY sINsse 0} Yotnb sem JOJUSUT SY] pue ISI] Je SUIDUTAUOD Jo uiq & papsou Aajor “Jeoqg Aq SUOTILIO] SNOISUINU Jayj}O S10[dx9 0} ]{@ SN JO} paploop suvsiyH sOjoq BuO] dye) 1, UPIP I] “dJ9Y] pue soy Ys B puke pddMeds }Nq 99S 0} YONW jou YUM ApYoInb posog 103 9A “PuUeySI sTY punoge syed Jayes dy} SAIp eqnas 0} Aep }x9U Bu} NO 9UIOD 0} JOJONIYSUI BEqnds swes dy} poy Adar YY] Duy JeoIS e YONs pey [Je 9M "SOUII} [JB 1OJ peoy AW ul Aled 0} SOINJUDApe dSOY] JO sINjoId eJUSTI JUsUeLLIAd B SUIPjOH “ul DAP} O} JUDIS years B YONS SEM J] “YSIJ JO Sardads [ed0] 9y) JO AJOURA YOU dU} JO AURUI & PISNOY Jey} [PIOD POJOJOO JUSOIJIUSeLU 9) Pure ‘sUIYyoIN vos jo Auew ‘pinbs asse] e punoj pue JooJ Suipunolins oy} posojdxs oq “ul DAL} 0} SIYSIS SuULYIUd dy} ATUO “OO} UD)ST] 0} SIDIOA ON “BdBsJINS SI9]VM OY} YRoudq SuLIL[IYXd OS SVM Jf “JBJEMIOPUN JJLIUNWUIOD O} STeUSIS puey [eNsIA Se [JIM SB S}O]D POOTG ISNed 0} JOU SB JOOTJ ULID9O dU} 0} A]MOJS pudsosap 0} MOY o¥1] Sd sIOW pue IvaB oy} 9sN 0} MOY UI SUOSSd] MO} B UDAIS PUR SOREL “}S UI JOJONASUL eqnds v Aq JOUI dIdM 3M SUIWIOU }XOU SUL “dIOJOq Udds JOAOU pey dy UKaqqUe sTy Jo syed alojdxo 0} JURM ADIJJOr SPL ‘Jsonsd v se Id]VM dU} JO JIAO] & YONS SUIARH "SOLIDJSALU S_.]1 pUR ULIDO 9} JOJ Joodsar punojmou B pey | ‘UOTNeS YIM papassoid puke psoy I13dy} YOO) |] soudLIEdx9 BUIWILD] ICY} JOP “UMS B JOJF INO JIM IIOYS 9Y} JO JYBIS SSO] 0} JOAOU PuUe ‘SOUT [Te IV SUIOD oI aM DIOYM MOUY SUODUIOS 49] [[e JO JSIY 0} oURISIY pue Adljor paruom e Aq papuewllidas s19M OM SI3DYM PUrTSI oY} 0} YOR sn jYysnoJq pue dn sn poyoid Ady [| MOIA T9y} UI sn yysNed Ady} uoym Aep dy} JO} SUIS} INO JeOQ B UO SAND SOS JO} 7}, UdIOM HI Ji ‘a0y} NO pouMoOup ABOU 9M Jey) AlI[IqIssod kB JsOWW]R SEM J] “epr] URBDO. BUOYS SY} JSUILSE SYRIIQ DUTYL) “I9YIO Yoo JO Syoeq OY} UO SUIT YOO) 3/4 "JUdLIND dy] Aq BIS 0} INO POTUKD dIBM PUL UOT}VdO] INO 0} UOTUSe SutAed JOU IB} OS JNO WIEMS 3M DDUQK “JOJO 0} pey UKdQqHeD dU} Je} ULS9O JO jOod Jeaqo [e}SAIO SY] Ul BUIUIWIMS OF 9M UdYCO “JOY]OSO} JNO Suey pynom ] pue Joy ‘punore SUOAISAS 0} SoBesseU BUIAIS Asnq },USeM | USY AA, ‘QOBJINS SISTEM dU} YJeoULopUN SUIyAIOAD ‘uOISsed JOY JNOge SuLy]e} POAo] pue “PIs JUdDOP [ROI B SEM SYS “[[aM Ajpeos Suoye j03 Ajjenjoe o~4 “Joyjoue Jo AVM SWOS Ul ADO[OTEY SULILP UL PSAJOAUL WWdU} JO [[e ‘sdays}Oo] s, Aj Wey JOY UI POMOTJO} pey sys “sJeyqey puv df1] suLeUI OUI UOTFRIO[dxa snonuNUOD Joy 0} ASUOUW pajyeuop pey dy Ivy) Adar YSNOIYI INO puNOs Jaye] | ING “‘spiepurys SAdIJJor JO SUIYJOWOS 0} JjISI9y SUUdMO] Ss}oodsojd Ysiy yons 879 $0 g6Gabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVELNACIINOD [PLIOIUIAY PoTsojod,[ JYsuAdOD ||

The text on this page is estimated to be only 37.95% accurate

sOTFOORLTANIO . TVILNACIINOD Proc rOORATANIO TWLENACIINOOD feuazgeyA] poyooiosy iy suAdoy (1 TUSICIA P9199I01,] BYAFA [7] CL "$}991)S ot) Ul SulAeyd ussIppIyo Sunod jo dnoss e Aq ponsijul suleg dn popus | 1Nq SjoxIVU o8e]{LA OY) UL SuIddOYs SWIOS Op puke LOLI S10Xxd Jo sojoyd aye} 0) Jsnf Ajyureur ‘UOOUIOYe SUO ][][OI}S & Dk} 0} POpIodp | “SOYSIM s Adljjor pue JURpUs]]Y d0R] eg 9} JO SOIApe oy) JsUIeSY "]YSIU AIOAD sulusddey sispinul d1egieg Jo psesy OA pure “ssdo] 91ed pynos suo ou pue SUISSIU OB sn! ppnod ajdood ‘s}391)s dy] poul] sIessd9g ‘ajqqenbs uayoWs Ayoaod yons jo AjId & Ul POAT] Ady] USYM STEM dS9y)] pUulyaq INapueIS Os SAlf{ Ady} pjnod moy polopuom | jng [NJNNedqg pue onbiun Aqjesio0jsty s13M soared sy] “SSATASLUSY] Ud9Mj9q SuLIodsIyM pue spreOgdI{s dy) O}UI sajou Sulpqqios ‘A[parzmy punose poxjem Ady |, ‘Sdouspisel dy} ye sn jou S JOUSISAP JOLAJUI feUOSsIOd S, AdILJor “WIdY} UT POAT] yey) Ay[eAOI Ady} Joo PUL SO[jSVD ULDDOIOJA SUIPUNOLNS SUMO} SY} d10[dxd 0} 1USM J[e OAK "UMOP SUO Jey) 13] JOAaU 3YS ‘JUDAS WIOPULI SLUOS JB WiODIYJEQ 3Yy) UE GOfMO{G B AZUOO[D 33103F) UdAIS pey sys jnq “sssoud UMOIO XdU OY] SEM OYS AUIY) P,NOA dd10A JOY Ul JUSLUD}IDX9 puke dn pying sy} jjB YIM ‘SmdauU JO UOISO[Axd Uv YIM [IIS;OOYdS B se Appis Y9Vq SLULD SYS 9OUQ “SIOAO] SNOLLA JOY YIM SNOAZapUal Joy INOge SLI 0} PAAO] BYS SOUS “USW JO 9)S¥} JUSDAI JOY Ul sIOW SEM 1 JY] YOVQ poyod | UdYM SI] 1, UPIP SYS JJassoy dUO aye} 0} O]qeuN jnq ayxof poos ve jo 10jeS1JSuI By] SAeM{Y “JOp[o Aue jd3 | BIOJOq pueqsny a]qeims Be puy iysiur 7 usdo y1 daay pynoys | sqAew yey) poxol suvjsiyH ‘sIoenb AU Ul s]QeUOJUIOD JJISWTY dye O} poueM ADYUOUI JayjoUeR asvo ul ysnf ou ystu ye Jefe jt Sava] O01 JOU paueM ay ‘pouado |] Ns SEM MOPUIM 9] PodOU JoURdIO OY] ‘UsuT] peq Aut dn Suluesjo juepuayle UR PRY 9M PUe ASAP 1UOI] dy] OF []ed JUTR|dLUOD B JO sdT}0U S]UBWIOW B UIUJI AA ‘asuadxa Auli 3e USNR] poos e ajinb pey jje Ady) pue ulool suruolpe Aw oyul Aultuy pue sueysiyy ‘Aaiyar payyeo | Jodues Addey BION ‘peg Aur JO aypprut Alda ay) Ul OOd AayxUOU Jo ajid B YIM pajeo13 SUM | [HUN JaJJO pynoys soejed ;eoLIOJSIY SNOUNXN] B BY) sdURTBARIyXO JO 11q pajoadxd AI3A9 YIM BUIZOO SBM }] ‘WOO! 34} 0} 105 OM USN AA ‘OSIOM IO podes Bulag JO ys }8 9q 10 IVP JOY OSNOY OY} SAL] O} JOU PUL STIOTL $}90I}S 9U] YTBM JOU 0} pousEM SUID Sd[LUISJ ‘OUIT} OY} Ie OzTSOY AISA []US 19M SHTYSINO pue AjI9 SUL ‘STIANON [TA JO osey[IA oy) UI YezuUT] [q Poyyeo Jorsuey ur jojoy JeIS ATF ATUO 3Y} PUL YLUIPUL] STIOJSTY OY] 1e POAT oAq ‘Suiddoy sayjseo SIOU JO] ROLY “Josue | O} Opi ouRyd WoYs e ATUO Sem }] “SUOTSURUI AUB STY JO dUO 1e djedT[daI 0} AdIJJor JOJ apJsed URDDOIOJ SUTpUNo}se JSYJOUR 39S 0} SUIOS “UOOWWD]Je 9Y} 1OJ UTedS UI PoAeys ATUO any “Adaaqs pue payeo[q Suijaoy ureds 10} Yo] OM 19}e] S}URSsIOID Aue pue sAeq "WUIY B Je S{IeJOP OINUIW yse] SuIsueYo “YIOM L19Y) NOR $ JappIng sy} ssesJeYy pue [IejJop AIOAS jnoge ssnj 0} pol] AdaJor “SUIOO] [Je SBM J] MOY 9S 0} JUaM 9M PUR ‘paysiqinjal Bulag yey peoidAy “WJopOw eB Sem J] JUS Ede SLizg SUIWOS puke dn SIY PdyISIA OST 3A, TZ "YOURI SIY JOJ 9,7 BJULS 0} YORQ JUIS DALY O} Satsade] Mou dos YSN pue ‘epio]4 ul yusuIede Aw 0} YOeQ JUAS }I PLY PUP LOS paleyjeay ssood poyjo[o Ala} SIYM & OW YSN Adlpjor Lid V SY “UOOWD]e SULMOTOJ dy} sonbijnog saisnjoxe 9]}11] Joyjo Aue pue ‘usIne’y] ydjey ‘n2q ‘jaueys ye Suiddoys yno JUdM SN JO IMO] [[Y “SMOLOS S$ JOYJO yoRS yO} pueL 0] Pd]qopul s9M 3M JeYM MIU YjJOG 9M Inq SaIppnq se sso]d AT]eAI Jo I3ASU 3M “JOMOL fapiq dn jy oq} GULYOOPOAO sJOM OM OTIGM OWUTIYTIU Je doyoos dy} UO sJeYs 0} Ael e INO JyUDNOIG sys ‘sINOY Moy B ysnf UT s}OR]UOD MOU OYARU O} AlT]IGe poyis Joy YJIM pue UIOOI B paleYs | pue AWW ‘asA]q .sdweyy ou} MOTA B YIM [9]OY puvls vB UT podejs [Te OAK “SINOY INOJ AJUIM) JX9U BY) JO} Be] Jol posroyyNs [Je om IaYyM DoueLy ‘seg 0} diy} sued Buoy & JOF Yd] us) ‘yoom & JOJ 3 eye Ul YouR sy ie podeys APs oAQ “AOUIO YeyNuepy Q]RIGO[IO WY MLS UdAd JOASU | ‘SABMAUP UPU SNOIST[OI & SBM OY JEL ION “JUDdSap YsIMore JO SI OY SB ‘UOISZd9O SY} 9}LIQ9T90 }, USOp OYM ‘ACN ul Aodyor ya SABprOY sed A MON OY} pue SeUSIIYD JUAds | ‘Sulop A[peo1 sem | {[e SI ured Jo yaxuRIG ve JapUN Suyesoyyns ‘sy[id Aw YIM -— Wd) poyoyueyq | ay Aq ow ssed uorssoidop pue Ajorxue Aw JO suds dy) BUIND] IsNE ZOpNILAJaS JOJ aFuBYOXO Ul OJ B Padyyo Bulag | },useMm “Sululejdwos 3q pinoys { YUIY) },UPIP J “SU JOJ 399 IAD [[IM 1 SB Pood SB Suisq se siy} Suiydasoe ysnf ynq ‘ji OUI Bulxear A][eod 1aAau ‘AdaJor YIM d][ASajt] AU O} paulojysndoe AISA FULLIODA| SEM J] SHOO] FIZYINOA Aru JO SSOUT[SAL] SY] JOJ PolOpe puke posn Juldq Apjua}sisuoyd ‘yt nd Ayuanboja OS 0} Poxl] oy se ‘OJIN AU JO “fpasuMlY AdILJo¢ WOLF SduIyded] AIOA oy], “Aoljjor JO} WOJJo pue onbruyso} ssn 0} saey pynom | ABM oy) JOU ynq OUI] pOOs B LUD] MOUS 0} SEM | "JUD]UOD PoIsap AJOAD O} JOU JNq UleJIOJUS 0] sem oovjd AW MoUy OS]e | Sayeloosse s, AdIJJor 0} JUSTUSSNUWIL Ue SY : "asesselu JO Ud & Jsn{ URY] SIOU JO] & JOJ O} poonpoIjul SuUlaq 9SiN0d Jo ‘d]9}UdI[9 JO sl] AW 0} poppe auiedsaq Jey) Ajatoos YsIY ay} JO SaINSIZ ayqeztusooas dy} JO aulos A[UO aq plnom Ady] “Jaqwiswieal JasUO] OU URS SUI JO 41] 94} [[e JOJ Ng peuoljUsW oq P]NOM sUleU S_.OYM JSUSIOS BUIUUIM OZ -[AQON JsuTWOId JayjoUR PUR [JIA] Bd1O9F) JOJeUasS [NJJaMod kb 10} OUI] SITY] ING NUSW Jonbueg sy} UO Jnd OsyR sem Apog AW Jey) ssuLIOyeS [enjoo|[N}UL SsOoy} SuLinp sem jy “Ajalo0s Ay eom s,Aepo} ul ajdood SNOWILJUI USAD PUL POWI9NS)SO JSOUI St] JO SWOS YUM YOO Youyq oI] SITY BUY “SPUIWW JO [NJIOMOd puke JURL [14g JSOLU OU) YIM J[osuY puNnoLNs Oo] SOY] ADIJJOr “SISMUSTOS PSUTLE[ODe ATIPIM PUL SOITEUOTIJIG PIWI0}$9 J9y}O0 yim Apso ‘sored JsuUIp SNOWeA SUIpus}Y “Adore YIM SAOUI JUR]SUOD B@ UO SeM | JVOA Suissed Apyornb oy) JO Jopurewmiss oy} nNoYysnoIyY |, | TT t9dey5 879 $0 66G9bed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘822 JUSLUNIOG ‘B98C-8T 9SeD

The text on this page is estimated to be only 41.24% accurate

LOCPOORRETAINIO VL 0} JUSTUOUI b JOJ pasned ays ..d[quiasusa Mau B Joy Surddoys Sulos 31,94, WUSBISNYIUS SULDUIAUOD & YIM popuodsoal oYs “PIP | Udy *, SUIOP 9M Je JY M,, JOY Ase 0} ond AU JO] FuTeEM sem ays ,, Aepo} NOA JO] jno pouuryd Aep d1q & SARY 9M “YOUNG JOJ OWT) A[IV3U PUR BUIWIOW 94} UT 4909.0 Ud} SI 1 JOR] OY) SapIsog,, “AjIvd os oyeMe sem dys AYM 0} se UONRURTdx9 UB JOJ JO}JNUI 0} 9[Qe SVM | PUR JoquINys doop AU WIOIJ ISAO PsT[OI ] se poq Aw UO UMOP jes OY “SulUsddey seM 3Iq Buryjyowos Ad] eIPSWwUI MOU | PUB 9IOJOQ SI4) O4I] SuUIyJAUR SUOP JSASU PRY sys “YSIUNS YSIIG 9} Ul J9] 0} SIO]]NYS Ss, MOPUIM dy] pouddo pue . peoy Adoojs dn-oye AA,, SUIABS JOOP posojo AW YSnoI1Y) papeied sys Aem ay) Aq poow Adiiys B UL SEM [[9} P[NOd | OymM suRySIyYH Aq dn usyom sem J SUIMIOW }X9U 9UL ‘daa]s papssu yonu pue doop e oJUl Sulpjey dJOJaq Ye B peY pue sjd[qe} Suidsays AW Yoo} | ‘oulut Ajjetoadsa “suoisnyjap s,auoAur [1ods | pynoys Aym “yuom ] MaYMAIOAS S9OBJ MOU SUNSOW pur ‘ppJOM dy) Sul]JIAey SASUOW yeoIdSULYLW SBM | PUILU PIDUIAUOD $,dUOAIDAD UT {9q Ady} },Upynoys Aym pue “Wdy] JO [[v “alu Jo pnoid os papunos Asay], Way) JOj yYSnog | ey) BOTY WOlJ JJNJs [kqI [OOD SWOS peyY | pue PRoIge s[aAeiy AW JNOGe WY} }][9) 0] 109 {| [Jam Se SIdYyJOIG AW O} 4[e} 0} SUOYd 34) UO dW nd WoW AW pue ow WIOLf voy Oo} Addey Ay]jeas popunos Ady], ‘SuryJomM Asnq oo} sAemye “Iva Sty} uOsess ARPI]OY 9Y} JO] |]e Je 9WOY Uddq },UPeY | 9OUIS dU) YM dn yojeo puke oop, Avs 0] ssnoy syusied Aut {peo 0} AJIOQT] 3y) YOO} | ‘IO JOJ SuyIeM sem AdIfJor 9IOYM 1d 9} OQ] ‘SUIBISUMOP JJO PIYsiyM YS PIeS PIOM JOYyJOUR JNO AA “Sey 49! JUDddaI JYI JO jJe wool poi ysnl ‘yyeoy poos oynposqe ul sem | Jey} JOY poinsse ] Ing sem A][VUIOU SYS UY) d]LIOPISUOD SIOW ‘WOO AU 0] SW paMoys dYS SB payse aueysiyH ¢{,..AvxO INOA ains nod aly,, ‘dats papssu swos uo dn yoied 0} syjid maj & Sulye} oq PfNOM JoUJeI | “SUIUDAS yeY) IOUUIP 10J Jno Su1od poulpoap Aypeonesoyode | ‘Ajoyouejsauw jig e Suryoo] pue SU[IARL SY) [fe WOI paysneyXs Os SEM | SUIO9S Jng Way) YIM Fuojye ou PO}AUL PUK JOUUIP JOJ INO Buios a1om Ady Z ‘9ouasdid sj o} WueYyd onbiun 8 poppe AJUO $}901]s 9UOJS3]qQqOd puke iI Jo UOT UT qnd [eoTIO}sTY dy) pue Jajov1eyo pey Ivy) 9sNOYUMO] AJO9DYO B SBM II JYSNoY) | “d9eTd s suelsIyH JB pue AjId OU} JO voy OY] Ul dI9M 9M DOJO SALIP BuO] AIOA B ]USEM IY yIOM Wolf, ALPI[OY YIOM-XIS & JOJ A[IUUIL] JISTA 0} AqIeoU apIsAijUNOS [BIN IY] Ul UMOJSUTOY J9Y 0} OF O} SN Suave] “odure oy) je .9Ag -poon,, pres AU “Joy 1OJ 11S & Se paysiqunjol pue JYysnog ApUd.OI pey ADLJOf JLY [k.JUID S_UOPUOTT UI 9SNOY UMO}] S,dURISIYH 0] SN dye) pyjnom }BY] 4SALIp eB Ag poyooi3 pure Wodury [JU] MOIYIVdH 9y) Je papuey oA, OS] LOY uedsYy AW JO UBIS ony] B ‘IIS Jo puly ezzid puke Jadinqasaayo ke Jo SJOLU B W,] “SOYSIP UBIDIOJ JOJ ABI}S OJ UO JOU “UILDE POO} yeulIoU Bune 0} PABMIOJ BUIYOO] SVM | CLI} INO JO UOIJEULJSOP [BUT SY) JOJ YO] OM Ud AA ‘TYILLNACIINOS |CUoIeAy poise10.,.] yySUAdOD o0crOOMIAANIO cz ‘SUT[IY) pue snosasuep Ajjenbs sev yng snoinjyusape pure ung ‘suidues oy1] }Iq B SVM HI UOTVZITIAIO UI9]SOM JO SILUNXN] 3Y) O} YOVQ Gujesd O} PleMIOJ BUTYOO] }, USBM | Je) ABS 0} JON “YORog wyeg ut uourede Aw 0} Juas SARY O} SJOYULY] [BIOLIOes Maj v GutAng dn popus | “joes Ul SuTpyeryjus pue [eUOTIEONPS Os SVM }I IFSNOY} | “INO possol3 Sues pue jsuNo} e ayI] Surmuinbs Jo peajsul ‘jsds9yUI YM ayt] JO AVM JUdTOUR dy) BuIjs9dsal PUL SINJ[ND JUSIOJJIP OY} Ul PO}SOIOJUL SIOU SVM | “SOOTJIIOVS SNOITI[OI JO 98N 94} JOJ S_.JeWIUL SNOLVA Jo sadaid Apog puke sapeyq dueys s.41 UO POUIV}S WIOIA JSP] S.}1 JO poo sy) YM AluOdvomM se yons ‘sonbyue Jeijnoed JSOUW SY) MBS PUR S][RIS S_JOxIVW oY} JO AURW O]UI poxyeEmM ] ‘OWOY Payyeo S$ .JaSeIIIA [BOO] dy) SIDYM SONsdys 94) pure syiaids }LAd Jyo UJEM 0} SB SOUIOY S,d[doad JoAO ARMIOOP PSYOUdIP pooyq dy} JOAO Suny que] JO ssayz ay} JO Sainjdid YOO) puke sursas}YIS 0} JOS | ‘AWOY SulIq 0} SJOYUL] SwWOs AN SUIT] SIq) pue UleSe sjoyreW onbiunN [edo] oy) Jo siNyjNd 34} 998 O8 P.] JYSNOY} | sUOCTP [Je sem | USYAA “deu e savy 0} 0eR7ed OU) 0} JUDM OY SSesseW UOOWIDe S. AdIfJor Joe pue dn ssury) dem 0} siouSIsap jo wes} s Adore yim Aep SULMOTIOJ 94) YOUN{ 07 JNO JUIM IAA “ased e019 YIM oINsed|d jenxas UMO Si JO 9SN dy) JOsJ 1N]4SNep S,ueW JOyJOUR jRa}s AjSnoJaWMNU P[nos oyM suOsWOS Woy J99dxd | PIP weym ulese udy], ‘soOwAUe uRWINY 9q 1,Up;nom | ‘A1jUNOD P]IOM -pJIY) B JO UdIPTIYO AT[eIoadsa “JJo Jassoy dU} JOJ UOIssedtu0d savy JOU 0} pue seM |[ AVON] MOY SZITRdI 0} Ng ‘31 00} 9SO[O BUIYJAUL JO JJO [JOM SBM | LY) JOU “]I SADTTOQ 1, UP]NOD | {SUIY] poos B LY) 1, USB AA “IVOA B IOJ ATILUR] ILD) 19}J9YS Puv psdj 0} Asuow Ysnous yum sjusied 119y} dn jas pey | Sul plo} oY “A[ssayoseo os Aouow Aw ABM SAIS P.[ SADIJOG }, UP]NOd oY Pue poop poos Atu jo UO Ide] AdIor pjo} | ‘Aououl oy) sjuased asay} moys A]pnoid 0} swoy paysns Kay) arojaq JIUSANOS [VUOSIOd B SB SWIOY 9x2} O} JJOSAIU JOJ SW PUe Spry dy] Jo OLOYd e poddeus 19Aq-Jossed y ‘Adudlind §'f) Ul SIV[JOP puesnoY} OM) I9AO Wat} SULAIS ‘asInd Aut Jo s}Uaj}UOd ay} yNo Ajdwuid 0} payjaduios sem | ‘BUO] OS 1OJ d]A\SoJI] SUIpeIsop AUT O} POWO}SNDDe OS Ud9q PRY | SAI] IVY) OAT] BUIAT] O} potuojsnooe s19M Ad) ING ISAO AIOJS JSOppeS dy) Prvay snl pey | WYsNoY) ] pue sjuosed pue [ooyds Iraq} jnoge su po} Ady] “SOAT[ UdYyOIYS Ayaaod Tay) Aq possyjoq 9q JO 9dTJOU O} WId9S J ,UPIP Ady] “d19Y IFT] JNOQe Way) YSB O} Po}So1d]Ul SVM | PUR YSI[Suq SuIpnypoul ‘sadendueyl JUdIOIJIP 991) yeads 0) a[qe som Aa] ‘sphy UdST{AIUT “19901]S 9} JO O[PPTW SU} UI IBYIO Yoed 0} SUTYDIY oJ9M Ady) UBD Aydtus ue sem AO} A]UO 319Y] pu ‘UO ID]R| JNO PUNO] | sIOyJOIg “SAOQ d[}}I] OAK} BS9U) JV ONTTJUI YIM UWOdDIOAO SEM J ‘Ajdtua juaM 1991)S oy} pue ABMe poysemM Spry JO apt) 94) Udy AA “MOYaUIOS no day pynod | paysim pur [ye way} JO} pes yay | pue usspyryo AaZuny ‘ood 34} Aq Udx2] JOAO SBM [ POO} puke AQUOW JOJ 3daq 0} URTOq puR SUI 0} dn sured WDY) JO UddIFIy NOge ‘Way} SUIYDJEM PsoIOU SEM |] USUAK 879 $0 COQEHed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8ZzZ JUBWNDO ‘898Z-8T aSeD TWIENFCLNOS JEUoeAy po199j01,[ 1YTUAdaY

The text on this page is estimated to be only 38.25% accurate

G6OTFOOM LIND “TWILNAGDIINOS s07POOTAAANIO © TVILNACIINOD JeuaIey porssiosy 1SUAdeD Fy JeLaeAL pHoMNosy 1YBUAdOD [ gL ystjsuq sem Jay Aq Jysne} sem | se puke SW sdONpoIUT 0} papssdoid SULISIYH IY ‘puvy sty yOous Aoijjor pue dn poo}js yjog oA “SUNY 19M | puke ADdIJO¢ SdYM O} [[eY 94) UMOP TY Psy syg “Jed ay] Ul WINjaI SITY JOj EM PjNnomM OYM pens Y} pue WIY pojyoo1d SURISIYH “SUIUDAD 9U} Ul YIO[I,O XIS Jaye Isnt JOOP dU) Je dtUTeD YOouUY oy “ajdnoo Areulploeyxa SIU) JO INO WYSIU ATeutpso Joyjoue jsnf ‘ojes sNOAIOU SNOTAqO Aw je ury Suryod oseva ye powses yjoq AsyL ‘posajsew AyIses SABMIP pey SUBISIYD SUO JNQ dAdIYIE O} YOO] prvy AIOA B ‘BUI OURS St} 1e [eNsSed pure juesaja SUTyYOO'] ‘s1dsnol} Fury 9soo] Jo Jed so1u B pue jo[Suls yooudjiny AjOOM 314M PoY-143y & SULIVOM “SALLIL 0} 19M MOIPUY SOUL DOJO SOINUIU ALJ SIIVISUMOP SLED BURISIYH YIOMYIO]O SAI] "SN UISMI9Q SUONVIII]{2 AUB PIOAR 0} “MIUH | yey) MOUY J9y BuUg}9] JOU Inq ‘UO Udy} WO JYSIY JUDIOJJIP & UI JOY We Yoo] jng djay 1, Up[Nod | “SMOLIOS YONS poINpus J9A9 peY UBWIOM SNOLOBAIA pur ‘poqidids ‘aosjored siy] possand JOASU SARY P[NOM | “JOYJOW Ss sUeISIYH 0} POLLIRLU [TJS IS|UM IJIM PUGDIS B YOO) UDAD PUR JOZIURUIOM B PoWsap SEM OYM JOUIE UMO I9Y SVM JE “JOY O} JEUONUSAUODUN Uses }, UPIP S,dU0 [eso] UB) JASUNOA Ul 9}sk} SI UDAD Pue PUNOIe UBLIOM AURUI OS dAeY O}] pddu IeIjNded STY DULISIYH OF “SUIS IDAD B[QuIIOJWOD paAejs sey sys 3194] $ ji pue ‘Surm sry JopuN Joy Yoo) pue Iledsap Jo sayouss oy} Woy dn JOY poyoid dH “9}eIS peq AIDA B UL PUR “aTGejOSUOSUI SEM SYS PSIp Joye] Jay USM JY} SU JO} 0} UO JUOM ADIJJOL [GG] Ul SpuLjs] AleueD oy} SUISTNIO JSTIGM ‘(PIGS SOAR STY 1O1Je poued) suRSIyD Ape] sy) “WYyoeA SIl| WIOLJ SUISSTUI 9q O] PUNO] sem oY Jaye ULdDQ DULY 94) UI SuNnLoY punoj sem Apog s ysqoy ‘jnsoul surysiqnd pue jusurespied JO Isquiaypy Peulsajso uv s9UGH ‘SsdA0j{CUId JO spuRSsNoY} JO soinyny 9y} SuruINI ‘s}qap [eloUuevUy STY J99UI 0} Spunj UOISsUed ssoAOTdwA sIY WOIF spad90.d SuISN ud9q pey [JOMxXeJA] Heqoy Jey) posidsuey ft pus sq} Ul pue soI9]UI }soq Sso1uedwiod siy JOJ JNO SuLyoo] 9q 0} Jou WY pospnf yey) sonuoOYne BUILIOAOS JO UOTJUANe 9Yy} payee SSuleap eloueuly yesoanbs SIY Pue ‘s}qop [eOIWLOUONSE poIdiuo0s jjam xe “urdu Surysiqnd sry SUTJOILIJSUOD ISTIYM “IOAMMOP “ABM OY} SuOTL YSopIN] Jlodny Jo sayxly sy} JSUILSR S}IM STY SULID}JUNOS “JOLY ATIeq oy} Woy) Suowe ‘siadedsmou Ysg [e1aaes posinboe [omxe_y ‘Oull] UT “AueULIDy pordnss0 wody syoog sWUSTOS Burysifqnd uodn ying AT[eHNIUL Ssoutsngq & YST]qeIse 0} $]oe}U09 AWLP SIYy SUISN SUIYsI{qud OUT JUIM [JAMxXR|] LOqOY punojmau B IBM 3) IOI “Pll SY} UE $}Oe]UOD JO JO] B OPLLU puL SON Maj B STURU SI pasueyo oy ‘ue Sunod & se Ay Yysiig oy) ulof 0} BUI93].4 “6¢6] UI UOISVAUI IZEN Uodn poy][Iy Sulsq A][IWIey SIY JO JSOW ‘eLFEAOT[SOYOIZAD UI JUSDOP YsIMde 100d JO UOG SEM JOUIL | JOY “soe S, AdIJay 0} Se Anuoiedde ‘puevjsguq ur sem Alojsiy Ss, ApIWwey Joy JuouTWOId MOY pszi]eal ISABU | ‘JO pnoid 9q pynoo dys Lied dy) ‘pooUplIYyS s,suRsiyH Jo yensod B SEM JI JEY] SUI []9} 0] popsdd0id 9910A poysny & Ul pue sinjoid 9y) Sc OUT JUSWUBYIUD ATL JO ddTJOU YOO} Adlpjar “AIOJSIY NOYSNOIY) ,.SddI1q JUNP] YSI[SUy,, SNOLWOJOU 9Y} DAI] XOJ JO 9WeS & SuUIseYD SsjUNY dy} puL spunoy Sununy osye som o19y], ‘podeldsip owioy [nyynevaq & YIM pure] Jo aoard ad1v] & UO paprsal Jey) puod e SUTYOOTIIAO YOU eB UO SUIS ATILUey Buryoo] Addey & payedsnqji i [lejop ais Ul “YOMUP JO sd01d BuIjso19}UI UP SEM }] “SUIOR] SEM ] JU} [[eM OY] OJUO poyured [eINU dy] Jv poteys | “Ive aU} Ul SsoUT[s A[UO ‘JUd[Is SeM WOOL oY “Apeol SuTI}OS YsIuy O} suRIsIyH JO} SUIIEM “SITBJSUMOP WOOI ASUNO] 9U} Ul BUNS 19M | pue Ado ‘JOOI 94} YSNoIY) juoM Ajorxue AW PUR PO[SALIUN SUIUDAD OY) BIOJOq XBURK Maj e IAP} 0} BaP! Pood B aq Pj} IYSNOY) | “JO UB SEM OPIs}NO 9y} UO ]o0d Aw! dasy 0} SUIAI] jng “YOM SNOAIOU B SVM | Aped JOS pey | atu) ay} Ag “yOajsed Ajoynjosqe ~* Apearye cue []e OM JeYM BuUljsej JaAou ‘oInjord yey) OF! J 1,uop isnf pue jussaida1 0] posoddns st Ayrulurway yeyM JO sprvo0g]|iq d1UOSI 9Soy} 3ds NOA Udy) puke U99]UdAOs INOA USYyM JURM },UOp ysl nod s8ury} a1, Ady, ‘sooejd payuemun ut ey Apo pue sapyxooIj “joaz 3iq ‘MOUH NOA ‘prwemyAME I9J | ‘(POOYURWOM OJUL SosuRYS Apog sy) durinp 9q Uk S]IIS SuNOA Jsou SY “eIOdO Ue 0} JOU qnjd e Je Surlouep SuIOS sem [| [ASA Pjo} | “INO poyord pey | Sassoup poyeoysiydos Surjoo] 1oepjO OM) JayjO oy} UY} Ja1yeI dnois ade pue a[Ajs Aul 9JOW 30] B poses ] “Wioyed B OJUL pasaploiquia sasioy YM sullUdp Jo Ned Sul[zzep pue 3o}-1urw yUId 3} UO poploap | ‘1o}e] J[OSAW YIM sojegep [eJUSW Aue pure $}1J}]NO 9914] [Iv uO SUIAN Jay “Apa 193 0) aeds snoy s{dnoo v [{Ns YIM ssnoyuMo} JAY O} JORG 103 SAA ‘OIL USSOYD INO JUdWI{dWOS 0} Seqpuey 9910 B 10} S,Aaging sem Aep dy} 10J dojs Ise] ANG “9901y) INO paxsid | ‘WWyINO Ue UO aploap 0} 9[qQRUN pure [eALUe S$ ,d9ULIg oy) SuNedionue ‘pousjysioy Ajuo Ajorxue Aw Jowoys Mold Aep 94) Sy ‘Ioyjoue sem ..NOA IO} ped] P[NOd sTy} DdyM SMOUY OYM,, “YIM 3 paj[ysul ays sjoo} deayo ay} JO 9UO SBM ,.dsIOY peap e S.jueM Apoqgou ‘o1ja9I19Ud puke Ajqqnq INOA 9a.1Ns OYLJA,, SUIUSAD UL ULY) SIOW IO} ysed] je “AoURLOdWUI JO SUIYJOWIOS SBM | UOISSOIAU SINDSGO 9Y} SW SUIALS ‘UO PUR UO JUaM Aj[BAOI SPIeMO} SaTNp Auk IO} att aredaid 0} syye} dad 19}7 ‘uOpuOTT UI LUO, BsOOYd 0} sdoys IOUSISOp JO souR] AULU SY} OJ Joyeosoy) APUOYS Ia] | pue sueysiyyH ‘OUI IO} 10}8 UT ART payoodxo | yeYM JO JYSNOTY} dU} Ie9q 2 UTIT 0} d[qQe SEM PUR ‘passassod Ady) sonteNnb Pood dy} URY} JOYyjeI SOURdIJIUTIS I13y] JOJ a[doad Sulsas 0} powWojsnsoe sJOW UMOIS pey ] Inq uONezesl pes & SI 1] AlTIQe suljoe poyis AW YUM Potulefoxs | .j MOM’ "JRUAM,, “JUIUISHOXS JO UOISSOICWI UL DAIS 0} “WOY) YIM OUI} AU UT SUOISBI90 AURLU UO dSN O} pey J 9U0 ‘YOo] pastiduns DHRJ V YIM JOY JL POxOo] | “MoIpUY Joy]O1g JosunoA s sapiVyD “YO, Jo o4Nq 9y) sem oY SUI Pjo} sys UsYyM pojuloddesip sem | ‘suolyeIBUNs JaBSuNOA dy} JO 9UO 9q PjnoMm jt BuIdOH *,.SUsUdAD SIU] PUR]|SU JO 9oUuL & YIM Surouep O83 OF ,, dudjUds Joy SuNsjdwod s1ojoq “osuodsns 9y)} pying 879 $0 TO9Eebed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 40.41% accurate

EI crOORRLLINID Bz djay 1,Uppnoo | pue oul Joy ysIYy vB ApO}UIJOp sem Jey], ‘soyore AW SUTYOT] pue soo} Aut Suissaes ‘joy Au Ayrernorased “Apog sunod Aul surmsope sem oq] Av[daioy Jovus91 0} ponuUOS JOG 9M sIDYM “I9}VM JOY 3U} O]UI ZUISIDUIGNS d1JOJ9q JaYyIO YoRe payono} pur possty sy ‘90ued JayoInb yonur & jv WY ssoipuN 0} URdoq UsY} “SUIYo]em pue SUNIEM SEM dq SIDYM 0} JOAO JUIM J SB JI JO PUOIIS AISAS PSAO] I}{ “SWO O} JUSWIOW dy} JOARS 0} SUNT) WY SUIAID ‘adard Aq aoard ‘Suryiopo At yo dis 0} uedaq Ajjenpeis | ‘Sanonpas joe pue Ay) 0} ssouyngyynod Aw JO jsaq 3y} OP O} BUIAIL [lO Yyeq JOPUdARy] dy} Ul poINod | ‘sdjOU [RIOT JO JUSOS dy} BUTAOT ‘sdeos puke SUOIO] ‘S]IO O1I}BUIOIe OIDM UISEG 94} UD “WOOL [jews sy} dn LUBD}S 0} URB9Qq J9}BM BYJ WOIJ Jdy dy} pue qn) sy} Joy sde} sy) UO pauINy | "SOOUSPISII $_AdJof JO IZIS SY} 1LdU SISYMOU PUL WOO! 3U] JO s[ppiwW 3} Ul qmjYyIe [AJS URLIOJOIA UTR{IDIOd YIM IOO]J Pd]1] d[qIVUI 9SI0q B SEM 3] ‘soda Aut ul Ajuedsip 94) SuUIMOYS WOIJ IY SI] 94) SUYSEL yt] ATWIp sem WOO] dy, -}X9U O} UIY Pa] | SYM WOOIYyIeQ 94) SeM APTs 9Y} 0} 1XON ‘BULUDAD SULWIOI B UO FILQLUS O} JNOGL SIDAO} Bunod uo Sursodutl siaseuse, alam Ady} Jl Se Appis Aeme poypem Aoy “saiqynp [eAOJ JO OS UMO ALU 0} SU BUIARI] “13Y}9S0} SIIe]sUMOP PosiIodsIp dUBISIYD pue AdIJar I10Jaq JOsUO] YONU UO JASUL] 1,UPIP UOTJESIOAUOD au, ‘dwWOd O} sak AURLU UL DOR[Vq WeYysuLyong sy} Jo} ASIZAO.UOD YONU asNed PjNoM jeY} duo ‘194}950} sn Jo ooyd e deus Aaljjar savy 0} d[qe SBM | PUR SOINUIUT MdJ B IOJ [TRY oyy Ul poNeyo [Je 9“ “ApNys oy} Ul d19M | pue AdYjor s19yM sireysdn wry yysno1q pue uly jot sue[sIyH "JBO dY] Ul SPIS]NO eM O} SuTAejs “JOOP 34} 0} IY pex[eM spends siy ‘SSNOYUMO} 94} 0] JOT 9M USYAA “JY SIUC) IvJ Os “OWI JeoId B SUIARY SEM pue alu poxly Ajyeos oy yey} alu ppo} Ady, ‘urry pozijop! | Jey} uoTssoidurt dy) payuem oy yeyM ApjoeXd Wy BUIAIS Jey OS ‘ssouysty [eAOI SIYy uIeJa}Ud 0} s}duloye Aw ev possoldu powises Aoljjor pue aueSIyy “oases S1y) Ul P9ddxXo Osye JNQ JO9LU DALY ATUO JOU 0} SARY PyNoOM | SUOT}e}OOd x9 yeYyM BULMOUY ‘OSNOYUMO} dy} 0} JORG SulyjOS JNoge sNoLxuUe Os sem | ‘Isanbal ny snoy) payyeo Os sty YIM porjduwos 3nq sovyd Ss sueRysiyH JB YOR JOOW 0} Sh JO [Te 10J posuvsie usdq Apeolye pey jf IVY) SUIMOTA JOU ‘QUOT 9q P]NOd 9M PIS sy DISYM 9U99s JoJoINb Be OJUO YIVquia 0} Apval pue yeoms uM Sulddup sem ssauysry [eAOI sty ‘IOOTJ 3) pdyx9 Ayjeuly om saxtur Surduind s. fq oy} 0} Surysews stayed Jo Moy ue Jayy "pip skemye ay} se: osuodxo AW Je SUIYSNL] SW] Pood & BUIARY 31am OYM ouURISTYH pue Addjjor 0] JUSLUISSIIEQLUS JO SsdURTS SUNOOYS pue JOO] S0UeP dy} UO Sulysney] nq doy },up[Nnos pue uses JOA9 pey | Joduep snospriy A[qIpa1oUl JSOLU 3] SWEM 9H “JOBSeMS SIy NoOgeE YOR psyelejol | Jt ol] BJO YONu 00] PUNOS P]NoM HI ‘S9AOW 3]QIIS} pue oIIWSs peq & YIM URW SUISe Ue 0} Ajdar 0} Moy SulMmoUyY A][edI JOU 9]39I9 ysnf ppnom | “yoou Aw suIssly pure seo AWW OJUI SSuTyjOU JoOMsS SuLINdsiyM seM oy “OI[qnd UI sem dy 7eq) TVILNACILINGS JEL] paoajorg wsuAdog OI ZPOORAAANIO LL yoRy dy} Wo Aeme Ays 0} Jou ‘Apog AW JO S9AIND 34} SsOIOR spuey STY SUIAOJ ‘UOTUAIIe JsodN Ss SOUTIg 94} pey [ Baym “IOO]Z BURP PopMOIO 9} 0} AEM INO OpeW pUk Sdsse]d INO POUMOP 3A “[OYOO]R YUIP OAD AdAJor yey) BuImouy Apeosye ‘sn JO ySoJ oY} 1OJ [leyyOoo v pue Aatpjof JO} iayeM Burpyeds WIM yorq dulvd oH “SYUUP [Ie sn quid Of Jeq dt} 0} USM MOIPUY PUL UN] savy ds]o DUOAISAS SUIYIEM SUIUDAD oY} puads oO} IOOTF OULpP SY} SULOVJ INQ J9UIOS oY} UT Jess AWdWo d]qLITBAR JSIT] dt} PUNO} SEM dY JY} HOAONUI [eloos oy} Bureq Adljof “IOO[J 9ouUep 9y} 114 0} UI JOM [Jv OM J]IYM optsino poyiem splens Ss .MoIpuy ‘pousdo Js SIOOP $,}1 BOUIS SIVdA OS 1O AjIOJ SV] OY} JOJ UD9S 9q O} SNOW] PUL YOTI 9Y} JOJ ppIoM SY} Ul SJUNLY DAISNIOXS JSOUW! dU} JO 9UO pue “qnjo}4sIU ATUO Ss JaquioU B ‘ dwely,, payjeo qnpoigzin & 0} }xou dn payjnd apq “xeyoJ 0} Jolsee HI punoj | pue ‘ojAys Aur dJOW Yon seM BULOS dI9M aM 99R]d 1X9U SY], “]USWIOLW usAId Aue ye yno j]Ids 1, upjnoM ssausnoAsou Aw yey} suidoy “payoayjoo pur “[00d ‘wyeo poulewial | pedjsuy “WIY JO} OqUIIG B OXI] JOR 0} PleMyAME Yd} 9A plnom jz ‘ApuRzelq Adar JOJ yey} Op UdAd },UPIP | Inq ‘uayxods piom AIOAD SIy UO 9JOP puL s}udMT{dUIODS YIM UNTY Joye[J Oo} pasoddns sem ] poeurepio-sid SuIUdAd UP “I9DY}O YORd 0} 1x9U AdlJJar pue suRisIyH pue IOUUIP JO} IOULIG SY) 0} }XSU Pyeas SBM J] “SN PUTYSQ BUIMO]{[OJ JOALIP SIY pue spiend om} Sty ‘MOIPUY YUM SN JOJ ALP 9SO]O B SEM JUBINESOI YL, ‘OSVURULL PfNOd | [ye SBM “UOTOOIIP AU UI SdouRTS JUR]SUOS Ss, MoIpUY qm dn Suidsay pue “} JOJ pa]jvo UoTsed90 oy) UDYM BSurysney] snl ‘duruUTs9q oy} UI UONesIaAUod YON dyxLUI O} prey Hi Sulpuy sem | “soiunf Aw sso say ATuUO Si Joyysnep JSOP[2 SIY SUIT} JU} Je OLU OF UMOUAUN ‘|e ye Ysne] e A[pey “JOY YM Suope SuIpyonYo way} Jo [ev “sig Om poyiM-AOMb Joy Ul MOY} 0} BU ISI] OY} SABE ‘paysney sys ,,UOOsS UI NOA sped} 0} SARY 0} BUIOS ov OM ssong ],, ‘1asuno< JO} passed savy pynoo | Zuryury) ‘posudins sem ays “pjo SIVdA USd]UDAAS SBM | ‘AT]ODIION passons MoIpuy Udy AA ¢,,Sl BUUEL YUITY nod Op pjo Moy,” “awes Buisson aiJOAvy Joy podeyd sys ‘oo1 sy} yeo1qG oO ‘aq 0) dn Suysow sig) paddy pey Aoyyor pue ouelsiy dn-pying ay} A]qeqoid ‘auoowios Y}IM JNO JYSIU B DIOJOq UdEq I9A9 peY | UY} SNOAIOU 3JOU SBM | “OU UO pain WySIVOds oy} UDY) pu SUTUDAD Jey) SulOULp pue JOUUIP JOJ JNO Way} UIO! oO} pey Ady) Jsand SuNOA siy} jnoge sJOW MOU 0] pojuem MOIPUY “oolqns I9}Y4S9I] YONUT vO} Pan) UONesIOAUOD oY [ ‘sauo0 Juno ay} 0} AyjeduiAs oy} Suiayjo pue ‘way Jo A[ysig Suryeods Ajuo ‘AYys1] popessy Aoapjor pue surysiyH ‘pouonustu sJom siajysnep STy USY AA “JOY JOAO 495 WUlYy Surdjoy Jo AeM Itoy] SBM I ‘Op Spudly poos se pue uo Zullasul] [[NS spunom ysadj IWIOS oom o1ay} JUoIedde SBM J] “JOWJOUL JO UOSKdI DUO IOJ JOY SULIOpULIS UT SUIN) SULAR} [[B BOM Ady) WOYM ‘dIZIO4 SJIM-X PIIOAIP ApJUSOOI SY JO [JOM MOU uR]SIYH ‘WI JO Spunos oy) Ag ‘JEYOIYS I]Pl GUISIOAUOD JTIYM S}INOSIQ puke Bd} SOS IO} SOSUNO] SY} UO UMOP JWS IB IAA “YOOYS dy} UO pass1y y}OG 9M ‘ULOJSND 879 $0 zogaebed ‘0EZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVILLNACTINOD Jeo wy posses 1ySizAdory |

The text on this page is estimated to be only 42.38% accurate

ELCPOOTATAAIO 08 B yong ‘ioJUsUT AU ‘O} dN YOO] 0} SUOSUIOS 9q 0} WIY BULISpPIsUOd MOU JOJ apts Ss, Aaajor Aq payyas sem | ‘Jjas onqy Au SuNeUitsosopuy "WW JoJ Aed pynos oyM UO A[UO dT} SEM | PUB STU} JO []e 10} pied aq 0} do1id oy) MoUy | ATUO ‘Jo UtesIp stdood ysout yey) A1O}S Ssadons SOY O} SPeI v ‘OJT] SUNULYOUD SIY) SUTAT] SEM | POASTIOG SU MOU 1eY} DUOAIDAY {SARY | P[NOD MOH ‘JNO Jad sw dyjay 0} Alessadou S{OO} 9y} sARY 1, UPIP [[S | Ng AIDARIS SSPID ISI JO LWWIOJ 947eZ1q SIY) WOIJ sdedsa 0} pojuem | MOU { “OVUL JJOSAW Sup pey | soy dsap sty} saoge QUII[D IAD O} uoT}eLIdse puke SBUI[I9J 94} O} QUINU JUTWIODIG SBM | ‘9dBIQUID S, ADIfJor JO qudtudesjUd SY) UT SUT] YONU OS SuUIpUadS ‘s}991]s SU} JJO YINOA d[qQvuioujNA SY} YUM pajyenjejul sulodaq 0} UOISISAIOd pojsiM} sIy JO uONENbs djduiis B SEM JI BY) PIusVIdjUN SUOSSI] }U9D9I SIY WOI, puRsispun UBD | MOU INq ‘WIY OJ peq Ia} uUdA9 pue UOSIOd B se UTLY BUIDaS JO pRoysuI yey] JO} wry duyUeM SUOAIZAS pu ADUOW YONU OS SUIARY YIM Op 0} SUINJOUIOS PRY Ji SUT] Sy} We YYSNOY] | “Sem AUBUT YIM SAC] Jey) puNoj ay Inq sJqtssod sem JoueEd SNOWRSOUOW SUO YIM SAO] JY} SAdTIDG 1, UPIP 94 SW Pfo} oY pure JYSTY “ssJAY PUY pu UMOP d]}}0S PynomM 3y JYSBNOY] I9A9 9Y Jl UNLY PaYSe | USYM UI O} PIS dy 9dUG “WINJSI UI WedY S$ QUOIUIOS 9AI9I9I IO DAO] DAIS O} JIISULTY MOT][L 1, UP[NOD SY SW O} UOSROI UMOUAUN SWOS 104 ‘SOAd $ AdIJJOl UI PINsqe oq ppNoMm SUOT}OU I}URWOI Aw Mmouy | ‘Ueoy Atu Jo sd1A019 daap e UT AWMP POXDOT SUIOQ SdJISOpP JSOU JOUUT AWW ITAA ‘PSUOTSTAUD ATUUEM Sem SUIT 0} OWN WO WYdNO) Sulssed 94) 1ng sayejyAej INSI[IAOU Ul JNOge ped A[UO PNod | BuIyJOWOS “MOU JOJ Weatp B ATUO SBM JDUD}SIXS SOAO] SN] JO UOTSaddNs 9y) YSNOY ‘diyspuaiy sujal] & pue ‘sue siq ul Ajajes ‘aA0] SULINpUS Ue SW MOYS pinom yey) ueLU SuUOS & YM SUIUUIS9Q MSU B SUIUISEUI ‘SUIRoIpAep AW UL JSO] 399 UI]O P]NOM | WeIy Jv SURWOI B [JS “USWESNUIL di qvaov|dal s SuodtUOS SUI9Q UPY) Jt] JO INO 9IOW IO} pousesA A|CUulis [| “P]JOM [eoIBeul BO} ABME JLU 9k} PUR 9SIOY d}IYM SIY UO ALU 0] SUOSWOS JO} BUIIEM SEM | SAI] },USEM JI “UIYIM WWOIy Say;qnod) Aw IZJOYJSOUL-J[9S 0} [[e JO Jsour pue o8e Aut ‘uTede GUNOA [99J 0} JeY) OAT] potted | ‘peoiqe ssoustiadxe AW Jnoge josIOJ O} JdWoye sy} JO} SuIWTE “OUII] poos B spudaly payjeo os Aw Sulnoys Aq joyooye pur sid surddod jnq Suryjou oul pousvs Asuowu Aut duyjind ‘our styy [Jom AjTOwWosx9 pred SBM | “JO}UNODUS 9141}U3999 AU J IPONYD,[O poos v Gulary ‘UOoIssasqo Ayinb s.maIpuy YM pepyon ayinb sem ay jeu) Aes ysnf sjoy pue }O0j AU UO UOTIJEXIJ PIIOM S,ddULIg BY} noe AdIjor¢ YUM Ysney] e savy PIp | yBnoy | ‘jeaoidde jo pou v yWM yovq poids Ayduns se ysnf | ‘woy) usamjoq passnosip Apesije sem saed | OURULIOLIOd AW Jo UOTJENILAS oY) yey) Apeaye Surmouy “Addey puay sty Surdaay ul [[oM PIp | Jey) WY SNoY} [ Ji Ajduus poyse ysnf oy ‘oound oy} YIM WYysIU syeWTJUI AW UO psusddey [[@ HW MOY JO S[leJop WIIG 9y] MOUY 0} JUBM } UpIpP AdIJJor¢ “SPUIW OyT] TVILNUCIINOS [EUMTYY popos101] JYBWAdOD [| ZI 7rOORTIINID 64 JO sid0d MOTI} SITY BJBPIUIUL puke sdUdNJUI 0} j4ld TuNOA ke Jo suolssoidut d]qevioujna dy} Suisn jo Ayyiqedes siy Suraoid sayin ‘ouAue Je INO pud| P[nos sy jey) JUDWOSNLUUe ;eUOSIOd SIY se apis SI 1B 9W Guidsay Jo |eos SIy OUI Jodsap dul Sumy pue AduOW Jo WINS BI}Xd UP YIM sdUESTIp AW BUIPIEMOY “OUT POOS & YONS ‘SdULg SY} ‘PUSTJ SI SuUIMOYS IO} su Yue 0} poyuemM oY YoRog wyeg ul uoIsueU S AdTJor 0} YOeq JOS OM USU AA [_— ZI AajdeyD “SUITIZAUB OP 0} PajsneYyXd 00} 3q PjnomM | pue sWOY SUI SALIP P[Nom JyJeIs S,AOIfJor JO SuO YIYM UT “YYStU JeYy Joy] [YUN WY 998 }, Up[nom | ‘s}UsWIOSUBIIE SY} [ODOURS pue YOeq (| [ed 0} pey y ABUISIp | YON YVAA “WTY YM diy AW JOJ out} Sues Oy} Je SW Aed pynod sy pur aoejd sly ye You OBeSSEU B OHI] PY OW Plo} AdIfJor “UOTJESISAUOD dIUS AW 0} Sulud}si] Ud9q P,dy Fi Sy “OuoYd dy} JJo 103 | usyM poyuToddesip A]ANOS SVM | ‘SARP MOF XO 9Y} JOJ OpNgtalos JO apt] AW WOI Aeme Sutyjod 2Q 0} O1}B}S99 OS “UMO} UT YOeq seM | Jey) pue d910A AU Jeay 0} Addey OS SEM OY ‘SSJNUTW AJUDM) UTYJIM D194} 9q p,oy ‘S_AdIJJor 0} YORQ Sulo’d Jo peojsul Lode 9y) 18 OUI JOOW P,dy Ji 99s 0} suOYd [J99 Alu WO tL poyeo puke [IOS Ino UO popuR] om Udy Addey Os sem | “Y'S'f) 9Y) 0} SUIOY Adurnol Zuo] INO Opnjouod 0} $d}ejS 9Y) 1OF Ia] | pue “sueysiyH “Aodjjor ‘sIeaA 998U99) AUT JO JOQUISUI3I 0} MOLIOS YIM po] SOW SW yng Suryjou pey | ‘osl] AW Ul 19}R] “poyiaaun sem oinjoid jeol 4} USYAA “UMOP po] Buloq ATOATeU SEM | PROJ dy} UMOP ssadjoy }]9} Puv pues JO UIRIS BING Sem |] Oda]1AIId pue ‘Iomod ‘yyeom Aq I941850} UMOIY} PUIMPIIGM OU} UT “OJOUTAUB [BOI USAD SEA LUBOIP OY} Jey) suns IOSUO] OU SEM | [IIS SUTeS OY) JOTUO] OU jnq Poy 99UO IIS GUNOA & WeIIp [BOLINs B UleLISOSe 0} SUTAY] [JUG “OsNUI B ING URY] WOW SuTyJAUR 9q IOADU Pinom | yey) Ul Furyurs ATPeur sem 7I “UITY YIM ssed 0} sO soUdTISdx9 DY} 99S 0} SEM | SB PSADIJOI SY “AVUISIP JO sdul[soz UMO ALU O} OLU SUTARD] “ASBISID UT SING sq] ‘JUOWYIee jeUOT]IOWS Jeol AUP JNOYIM pue 1d}e] S}USWOJA] “JT AU JO SdINUTUI UD} JS9SUO] dy} JO} SIOQquIRYy Spo AW 0} PdIIJO1 PUB PfOS SY] WO JJO pop 3M OS SIU JO JSOJ BY} DALY O} payueM ysnf ay s1aym Jurod oy} 0} du punom uly 39d 0} prey },USeM J] “OOUD}UDS SUIS SY} Ul JO9J Pue ONTUO} AU SAJOAUL PjNoM yeu} souO AjTeIoodsa “SOYSTIO} OUIOIIXS YIM OUT] B MOIp [ ‘BUdY YIM SooUdLIOd x9 JUSDeL AU YSNoly |, “YoeRq JUSUeOI} SLURS OY) 199dx9d },.UPIP ay podoy | ‘ydsne] yng 879 40 E09aHed ‘OEZ8ZIZ ‘6T0Z/60/80 ‘8Zz JUaWINDOG ‘898Z-8T aseD TVLENTOLINGD JELayepy poyoajor WSUAdOD [7

The text on this page is estimated to be only 41.64% accurate

ST TPOOMAAANATIO i TVILNAGIMNOS PI ZPOOTALINID TWIENACL NOOO [PLIOIEAY PI}909104,] 343Adoy [3 JLUSJEPA] PISO] wswAdo> (] c8 BULARIO SBM | INQ ‘papuNos }I URY) JOpJeYy YONW SBM J] "] pue fy Jaypoys | pue paaj 0} gof |ead B JOJ YOO] Pue SBnIp ay} JJO 199 0} pool} SEM | pueL ual aaisuadxe Aw Sulded paddojs Aarpjor “1YsNOY) JOAd 9A,p[NoOM | ueY} UOTISUBI] JapseY BJO ZOW SLA\ JI] SIOBLUSI] OBLIAR UB O} YOEQ BULOD | ET 4ajdeyZD “OW 0} ples dy SUIY) IS] 9Y} SBM LUMO] Ul UL] SUIT) }xOU NOA [[Bd T],[ ,, ‘YONUI OS BSuULYIOM LOI] YRIIG B Popssu | 9¥1] P9xOO] PUL MOU OBE UN} SUIOS JOW ISIE PRY OY [11d OWES OU} },USEM ] SUI PjO} ay ‘duiuaddey sem Jey WY pouonsanb | usyAA “Gof e JoJ Buryoo] pue AQUOLU JO JNO SBM | ‘9Dd1JOU SJUDWOLU B PRY | s1OJaq pue Ud}jO Se puNole atu Buidaay ur sAisuayoidde Asijjap apewl STU] “JSOYS pue sUI]}STeEM Auurys Aw wod papnijoid souog AW pur suidssjs jou Wolf Woy} \JBvaulapuUN SajojIo yep pey sodo AJA] “OUO 9x1] SUTYOO] },USeM J] MOU pue d1owAue pjo 1eak Udd}UDAIS B OI] [99J 1, UPIP [JPY SB ons | “SyOo] Aw osye yng Aeme Suljpurmp Ayiypejusur Aw sem Alu 30U ‘sq{Id puke 9409 Uo Bul9q JO ayeys oOYdnas ay} ul Jadsep SulyUTg “OJUL PayIp pey | Silepye JO aye}s DAISNE SY} a[puBYy PJNOd | Syl] YOO] 0} Ajipiqe Aw pue yieds Aw jsoy pey | ‘SSOUPRS 19}]N OJUT PAYSIULLUIP PRY JI] UO YOOTINO AW “syJUOW SATjONIVSOp Jo [181] & PAMOT[OJ S]YSTU 9] puK s}ysIU OJUT posso1dold SAeBp dy} SY “OTULID Oy) ABME YSeM 19}eM dU} 39] [| ‘AwWOdaq pry | IeYM polweYse pue jusOYge Sul[soy “aw payono} dy asaym Apog Aw paqqnios ] ‘1ajzeM Jo Avids ysiey 94) Jopun Jomoys DY} JO JOO] 94} UO BUTIS JOMOYS JayIOUR JO} WOOI AU 0} YOR 193 0] JIRA J, UP]Nod | pajonpuos AjYysnoloyj sem osesse ul Sty JdIJV “JO919q} sjuawasnue 10 Apog AW Ue] Joyo SuiyjAUe IO] popssu iaJ | USyYM QUI] B JaquI9UId1 },UP]NOd | ‘UOIsssidep JO JoquIN]s AUI OJUT Joy,INy AUIS 0} SBM JUBAD SI) WOIJ P9ALap |] Bury) A[UO dy} ‘Ou JOJ SI} UT sInsesyd ou sem aay snl Ajuo jnq ‘sjsonboi Aposes siy poi Any y “MOY pue UTY YONO} 0} SUI pajuRM dy BOY poyeoIpul os} “GUIULIOY sem Apoq sty jesnoie ay} Aq UMOYS BUIAG D19M SOIISOp [VOI STY “AdeSSVUI JOO] B yNoOgGe §$9] aIBD p[nods sy MoUy J SAA9 STY UT YOo] oy} Ag “Joo SIY poqqnd | syTyM Jas B OAR) OY Paysassns | soyM YOusg 9] qIVUI 9Y} 0} UOTU|}}e STY WIN 0} pay pue dn Surypy wesys oy) 0) UoUae AW pouin | ppoysuogs sry Jo No BurpyeyH ‘aoy} aut doy Adsjor JO} opnyraras Al Jng ‘ulede SUI YONoy spuey Sy SUl[99} apiy pue UNI Oo} pojURM | “JOOT{ 9Y} 0} DINE STY SUIMOIY) ‘paqoJsip pue pea] AW pamoyjoj MoIPUY ‘J[OSAUI SsoIpUN 0} URdaq PUL WOO] WILd}S 94} UO POTN] | “JOMOYS dy) PUIZ 0} YSNoUs seM WOOI ay} punose Aem Aul SUIMOUY Inq ‘ssauxJep dy} 0} Jsnf[pe 0} Sako AU 1OJ SOINUILE MIJ B YOO) }] WOOL LIP 9Y} OJUL SulojU_ “JOUOY Jo ysond AW MOU sem ay ji se ‘sAemAue ABM dy} Po | IN ,JJeIs,, S$, AdIJJa¢ YIM SJoyUNO DUS T8 SnOIAaId Wo sem JL aJoyM MOUY Apeosye dy OINS UL] “WOOI adessew s1izjsdn dy} 0} MOIPUY MOYS 0} poyse SEM | Puk JoWe] Saxo! epnsio Auey| ‘Apuy Apuery toy Aeme Aes 1, UP[NOD SITS UOISsoIdUT oy} SUTATS “OYysdeuUs dy} 10} SoUy JOYIO SITY UO HS JULOD 0} ‘sJURISISSe [PUOSIOd PoT[Vd-os s_Aal]Jar JO suo JoyjouR “euURYyOor 408 UDAD PUR BUIDDS d1ILZIq SY) JO sAMpoid v aye} 0} poyUeM oUIRISTYD “AeMe passid AO | ‘ase SIy Ul Ope [OP & YIM Jseoiq Aww poddno MOIPUY UdYM puR ‘sainjso3 pmo] Joy] Aq poureyiojus aq 0} pusjaid sem Op 00} pey | [Je ‘Porlsep Aoui vOTJORII 3Y} Wt} 9AIT 0} Asva SEM J] “OSO] O} d10W BZuryjou pey | ‘so] Buoy AyUsip Aww Jo ise] Sy} YIM “punoe papeied 9g 0} DUI payuRM Ady} MOY AT]ORXO MoUY J Auod MoYs B O¥IT “de] sIY UO UMOP al BUNUS B1OJIq I9AOHOO] POOD & WY SAID 0} PUNO’ SU PSTIIA) pue uo SulSuno] sem dy LjOS JUSPRISP 3] O} SU Pa] dURISIYD “SALIP 489} B JO} 11 92} 0} JNOGe seM oy pue Ae|dsip UO Jed MoU AuTYs B OyI] UMOP pue dn oul poxoo] ay sv ‘a0vj siy 19A0 poddejs ulis Asaayo snouojou yey) pey Molpuy so0ulg “Apnjs 94} 0} UMOp paljeo sem | AYM jSBa] Je IO 10} a10y sem oy eyM Mouy Apeolye | yng wed Aw uo pouseM-did Jo pajyoodxa OU AjaUIJOC] J{9SU Popesadl 9ovj IBIIWe] B puk SIOOP UspPOOM AAKay dy} Uado payoRso | “SIOOP pasojd puryeq uoNedioyue YM SuIpEM a19M sons osiiduns sty pue Adore DI9YM IOO[] DY} 0} UMOP AU YOO} }I puL JOJLAI]S 9Y} OPISUL 3DUO dUO JOqLUNU UI payouNd | ‘soMoixuR sWOsIVa} AW 0} quINdONs 0} s]TeM aSoy) puTyog Ased 00} ‘oJaYyMes]9 s}ydnoy) Aw sAow 0) pey | pue ourds Aw dn poaow [IYO poo y ‘sAow AJoAo AW SuryoyeEM ‘gu UO SoX9 JO SIIVd [BIDADS PRY | JI SB ‘OW IOAO YseM Buljaaj o1199 ue pey | [yey oy} uMop Aem Aur Suryey] “WOOI oSessew oy} 9q 0} 1YsNOY) SBM JEYM IO ‘UOCSSuNp 9} 0} SUIPRSY sJOJDQq SSaUISN poysiulfUuN SWIOS dn 91) pynod dy Os JSIlf S19Y} WHY JOSIU UDIJO PjNoM | ‘]]ed ppo ue JON ‘Apnys S AdIJor Ul WI] JOSU 0} JsONDII PUR JOAO SLUOD ADIOA S dURISIYH piesy | pue AjuejUSWOU pezzng WOSI9}UI 9y) pajorpaid | sy ‘oyej AW pajdacor isnf ] ‘yeoiq S}USIUOU B JO} StUOY JAS SUIOg A[soIBOS ‘SIaquIRYS pousisse Aw Savoy 0} posoyjog Aypsey | “JoSeU AW YIM BUTeOUIO} Ul SOUdLINGDO ONST[LN}L JoOUe 10} Urese poUOUTLUNS SeM | 910Joq BUOT 9q 1, UP[NOM I SUIMOUY “00} powojsnooe uk} d1JOU sem | LY} UOYLTOSSpP 94) JO Popuruwd] SEM J WOO] [IAd-prtu poyesooop ApuRseary xa Au punole BUIYOOT {IOLJOS JO UOTSIA B JVYAA “PUNOIe SUTVVOT] S eT[I1qQuIN [e}USTIO Q]NI] pue Wy Jo sacaid YIM s]1e14909 dis pue [ood [ooo ke Aq JoyJams ued [ 294M UNS 9Y} Ul BUTID}SITG SABP BPLOT JOY SU 9AIDH “SIOOPUT PsYdOT Sulog UOISsoidap AW 0} ppe A[UO PNOM jf ‘aJat{} SIOJUIM PJOS SY] poyey [ ‘UIeSe oJ1] JO ULC] SUIOS SAY 0} Jvadde soa posed dy) Sule ‘saAvo] peop oy) Aeme MOjg Ap}UOd 0} UNOq SpuIM JO}UIM YsieYy 94) puke FIO A MON JO $}99NS UIZOIJ OY) JJO 991 94) AeMe poyjour sAep sulids Auung “Aepo} pusysiduioo Ayjny 0} ayoe [[Os | 2u0 Si yi GjasAtu uty apeq payeoijdwos 879 40 pogebed ‘0EZ8zZ9Z ‘6102/60/80 ‘BZZ JUBLNDO “898Z-8T BSeD

The text on this page is estimated to be only 42.56% accurate

LI CrOORRETLIAID V8 ino poysund | ‘Jyo sAep aydnoo v savy O} SW SUT][9) pue yorq Aw sumed ‘YONUTYDS IVY} ULY) 19}19q JO] B OP P[NOd | SW PO} UdAD pue BUTS] IP Aur spremo} onayyedurds sem oy Apsutsuding “yUoprour sty} J9A0 gol AUL 9SO] 0} PIOJJR }, UPTNOd | ‘Ajnp uo JoBeULU oq) 0} SulUTe[dxs sos Op PUR JUBINLISSI dy} JO YOeQ ay) 0} OF O} PRY | “JWOM 1OJ OSIOM BUIYOO] pue [OO}sIeg B UI poduInys SUI JOJ SUOTe pojieM f°] SB pajiasap sem Ieq 34] ‘“owoy Wy DULIQ 0} AjIVd SAvd] 0} peYy | SSOq AW pO} puke WIY JOJ Sasnoxa spew [|S ] INQ dW passeeQUd sy IVY) Oprsul Sulummy sem | YSnoyIe “suoissnojodal S.JUSIU au} JJo daa[s pue swWoY 03 0} popssu OYM JOIP! YUNIp & SB JJo WIY poysne] ysnf | “AUOAIDAS JO UOJ UI Peg YOO] 9 oyxeU O} Jduoye sty UI UO PUR}S O} PUNOIT 10 SeIg OU SULARH “SUTUDAD Jey} YIYs UO Joseuew AU YUM SuIdagjs JO OW SUISNIIV PaLe}s sy USYM dOvJ STY JJO Sem 9Y MOUY { “OU! YIM IYSIY e yoId 0} poyE}s puK SUTFIOM Sem | dJOYM JUBINL}SaI JY} OJUL paluO}s ay sasediues poonpul Sup siy Jo suo uC de} 190q ay) Aq Ja}UNOS ayy UO {Mog diy oy} Ul sdy s}YySiu Aw nd pue uoide Aw dn Suey o} Jeq dy} 01 JUaM | UdYyM Aep }xdU dy] JOJ APRd19q O} S3]qQe} SY) JNO SuNjos pue eose Aw dn suiuesls paysiuyy ysnf pey | [OMUod JO MOYS JOyJOUB YIM polei]ejoi oy ‘jyS1u SuO YIYs Asnq & Jay “UMOP sw SuULq pur Al} 0} ABM B payedtuayuod ay J[aSAU LO} [[9M Op dU 90s pue Aq pues 0} 91qQeUL) ‘voy AjdwWo siy Ul Yo] omMeu UR UINY JO S}Iq 94} MOYS pauKM [Ys dy Vy) SASI[OG O} SuNURM LUTY PNY plnom VY BuryJAuK Wolf UI papusjop pue apis sty Aq YonIs [Hs | Sulmouy Inq sAvm Ssiy Aq UMOP yoRQ IYSNOIg 9q },UP[NOd | Bulzi[esl “JyosAU UT osUBYO Oy) payey 9H “Xl IXOU SIU LWIY 393 pnom 71 VY) MOUY OY JI PLY PO 4294 DAly B Wid’, APURd Jo soaId v feojs Ajqeqoid pynom pur J9YIOIq SIY pue J9]SIS Sty ‘S}UaIed SIY ULOIZ 9[O}S UDAD OH “JO sNQyYoOTg ROO] B Wo sowed xOQX 40 7S PU S.A SP pldnjs se udA9d ‘SBurY} [eo}s 0} Suyduraye SOUL] [RIDAAS JYSNvO Uddq PRY puke Joly} UMOUY & SEM fT “YI YM ode 1,UpIp | pue Aduow Aq Suideiss sem ay MOY MoUy | PULYIOM JOU [[S ‘jySnou} | ‘suomneossid Aressaoou Oy) Surye} ysnf “Aeme swojl poyswoys Alu dJ0}s pue jods [voo] & Ww 90edS B INO Jal 0} paploap | “SWoa} aatsuodxa pur Arjamoal Att jdoy | soy [Noes AIA 9q 0} pey | “sdnp Auvtt 0} pojorppe ATpeq [[Ws Bulag ¢ [| ‘sooord usyosq oy) dn yord 0} poy OM pue SARMAUL POUMO JDA9 OY [Je SEM YOIYM “oov[d AU! 0} YOeq SoyIO0[O SIY POAOW 3H “AI[PAO] SLM JYSNOY} | JEU Puke }INS JO INO PIP | SuLYyJOWOS SEA JQ ‘A[PSTeSY-dTOYM SpeUl J UOTSTOOP B JOU SEM OT] AU! OJUL YOR WHY BULL “SplwemuMop jesids tury Suryojem uo Ayd Yoo) pue uy psaoy [{Hs OUI JO Weg “SWOdDNq PRY ay JeYM pure J[OSWIIY 0} SUIOP Sem oY JeYM 99S 0} WY Suyuem ysnf ‘pynom pudidy poos ke se WY O} SUL} PSL) | “Oprisul ULLY JO] 0} INQ dd1OYO OU PRY | OL] WoF [ SIOQUSIOU AW SuULIVOS pue pew Buiod ‘xajduioo Juawpede AW UMOp poUedIoOS dH “JYSIU yey) SuLyous SEM SY SNIP JO Id10Y9 JOADJVYM WO] POpO}sip A][eJUSW ATSNOLAGY TYILNACLTINGS evap porsooig wy SuAdog GO 9TZrOOdAAANIO €8 “A Suryoyem suf owoy je Bumps sem | aTYM SUTUDAS dU d0RTd AW I9A0 SWIOD P.dy JYySNoY} fl “You owed oy pun ‘Addey Ayjeoi sem ] PU JAS} JO} NO SUTAIOM dq 0} potisas SuIMAIOA “OW JO} sAtoadsiad OJUI SII] JO aNTRA [edi ay} Ind 0} pautsss ATTeoI Jno Aep ul Aep ssury} a[duris oy) 18 J][MWUS 0} d1qQe SUIOg MOU puke Jo Yon Os passtiu Apealye ] Jey} Aeuanol sal] JO S[IVlap [[eUIS “AdOUdI99 [NJ NVI Itay} Jo Wede dq 0} 103 | Pu SYdOM MO} L UL ULWIOM BSUIZEWe UP O} POIILLU SUT}]OS SBM JayIOIg Japyo A “ulese soily UOG PUR SIOUUIP 1YySiu Ajiuej 0} SuIOS sem ] ‘ouer-Arepy “Sop Aw asinoo Jo pu ‘siayjo1q puv syusred Alu “yIOM SBM UO d}VIJUDOUOD 0} PRY | [fe 00} MOU sINyoId SY] JO INO (LY “OULISIYH 1o Aaljjofr Wolf p1OM B JOU pue Aq 9UOS pey SYJUOW saiy) ALIVAN “aTOY FEY) Pry[yf yey) JOY sem yj YSnous AuUNY puv Ud}SI] 0} SUOSIUOS SPM pooU AT[PAI | [JB “B1OJOq peYy OUOAUP UY} SOLU POO}sJapuN OyM uoLURdUOD [eAO] AUT SBM SYS “SUOTJBSISAUOD Po] lf Jeo} Auew JO JUNI dy} 910g OYSs pUe AepP B SHTBM [VIBAIS OJ JUSM IAA “PUSLY JSoq AW SuUIvDNq SYS A[JUL]SUI PUL SUT YIM SUIOY JOY YOO) | “sop eB UPY} Ivaq UMOIG Aqeq & po[quiasol S1OU Jey} ANY JO 9]punq eB puke MOYD-MOYD asoueder B sem YS ‘Yyoood Aliny & YIM SAC] Ul [[9} PUB d1O}s od [BOO] By) Je dojs yng dyoy 1,uppnos ] Surusasd uo Surddoys AJooo1d oY} BuIOp yNO STIG AA "J[asAww JO} SUIAL] puke day SVM] “JUdUTAOLUDd JO Bd1NOS A[UO Alu oUIRO|Sq AY}]BOY pure jy SurAeys uo snooy Atu Suidaoy pue asinoo esod kB ul SuT[OIUy ‘dn joe Att pouvsyo pue judas At YIM dn jday J] “a1OJ9q JOAaU SyT] Payesaqy] 12] | ‘Syuored siy yA SAT] 0} YOR JusUTAIVde ATU JO JNO WWHIY SULyNy Aq uly 0} Jeaypo Alaa yuIOd yey) BulyR| ‘UOepessop pur asnqe Jo WO} Jayjoue jdaoov 0} YON 00} YSno1y) su08 pey [ “Pjlom dAISNIa SIy puocaq SUIYUIY) PUL SPISUI BUIMOIS SEM | JOR} AY) OH1[ 1, UPIP 9Hj je ye suryjyAue SUIpOO} WOIF Wy dooy 0} SHUp poloOsse JO [1B] 49OO yensn sty Suraey JOU pajyensnyy AyoyN survsaq oy pue sppiq Aed djoy 0} YIOM IO} YOO] 0} pasnjol af “Slow AeMe ow poysnd A[UO Jey} LUTY 0} SOPIS MBS | pure jeoisAyd swiedeq S}YSI,4 “‘UONRI[INUODII PUOA|Q SBM Jey} ABM ¥B Ul 19}]RJ 0} uedaq | pue fc], UsaMjoq dIYsuOlElal OY], “SITUS 0} MOY PolaquIsUIdI | SJOWW 9) “UI payse) | SIOU ay} PUe You 19d 1, UP[NOd | yey Jo yon OS PassItu | ‘PMOIO JodUNOA B PUNOIL 9q O} J[9J HT MOY JO dul PopUTWA i jnq siduiaye soy) Aq YoRQe Udye} JOAD SBM | Je] JOU puk ‘ow OJUO SUINTY adv AW SA0Q pey | SUI] BuO] & UL SUNN) JSITJ OY} JOY “YO9M OY} Jo pula oy} ye sdij ou} yds [ye p,om a90urs Addey sJoyxIOM-O09 AU OpeUl WITY UT YOM ‘jYySiu dy} JO} Sd1j SOU OY} SPE Jey) SsomEM oY} Surmodeq Addey way) Zurdsay pue d[IWs SIOUIOJSND SuLyVW Jv Pood sem | ‘JuRsea]d pue Ases 9q 0} SoNNp Aw punoy pue gol Mau Aut je Spudiy OWOS spew | “OUT SUO] B Ul Uddq PRY | UeY} JoIddey sem | ‘Addjor JO} DurysOmM JO soy ajdnoo v Ul opeu pey | ADUOW dU} OJ BSO]d SULLOD },UPIP SsoIeM B sev gol SUI}-[[ NJ B SULYIOM JO} SoseM S.YOeM B YSNOY) udAq “ABM apqissod AJOAS UI S14} 879 $0 Go9ebed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUBWNDO ‘898Z-8T aSeD TVILNACLINOD [eae] porso1eag sy TWAdes |:

The text on this page is estimated to be only 42.17% accurate

GT TFOORELANMO | T¥ELLNSCMNOO 8TZPOOMITANIO TWILNACTLINOD jELaIe poisaiol1g ysAdeg GC jeLoIw] PoIs1OI[ WYSUAUOZ [! 98 “SIY} SUOP 9ARY 1, UP[Noys | oqAelu yey) ALIOM 0} uRd3q | ‘J9JJO PjNod dy UOTNTOS }eYM pue yoRQ puodsol 0} JeyM 9}e[dWI9]U09 0} STUY] STY SuULR] AO} YORQ Sty UY) DOW Yo}eIOS 0} SABY P[nom ] WINjAI UT YOY “PrjOsS & OW SuIOp sem dy Sedo Siy U] ‘doy sty papsou ] puke SdIPNis asessew AW SUMUNUOS ‘WIY JOJ YIOM 0} YORQ STUOS 0} SU Pd]UEM OH JOA] STU O} POxOM II SWI} SIU} INQ IWeUNS) & polapIsuos dq Pjnom uo sity} pue AVM Aue Ul SOARM Ope SPS UOYM pojey Ajjeuusou Adlyyor “]]e I pres uid Ajs siy “ulese souo 1ojUewW Aur se WY Suljqeug ,.gOp | op uM ,, UY ye dn poyoo] pue sovy Aw podim | ,.s,qnoy Ul pue ¥1OM JO INO Wy MoU ‘T[TYdN Os SUIOS Ud0q Sey BUIYIAIOAD USYM atu 0} Suiudddey si siy) dAdifoq },ued suf ],, "Syooyo ATU UMOP SUIP{OLY MOU SIO} 34} POIOAOD pue spuey Alu OjU soRy AW Nd | ,.jOP pjnom JOA 10 PIP JDADU | SUIYJOUIOS 10} PIOIOI B OARY O} JURM } ,UOP | “Ul SUIOD 0} duu juRM []WS Ady] jng suoYd oy) 19A0 pousddey yeym Wy) pjo} | ‘Aouow DY) NOK UL SOD O} SW SULYse {Od OY} Woy [Jeo suOYd & PdAledo1 |,, euieIp o1da AW Ysiuly OJ UO JUdM | 9OUSLINOUOD UI pesy AW SUIPPON .gdW AIA UMOP NOA dep wy 39] NOA op AyM ‘JyasmnoA 10} J9}9q OP uvd nNOA MOUY | jNOA JOJ pOod Ou Si dy “eUUdL JOTPI Sty) YM Sulop NOA oIe JEYAA,, POLULL]OXS JY [ROPIO S1IWUd 94} JO sINjdId AedjO w ADIJOr BUIATD | “Ou UO AJd]OS SUR] dU} Bund ‘auosd oom Sdyy ay) ‘Id9] pey | 199Fe JEU) Surpeys yodai sorjod v oy1J 0} pey oy poulem prey Joseuew AW sy ‘poAojdusa Ajiddey Os sem | 194M JUBINGISOI OU] 1B posned A[SSaTPOJJo (7 ] Jey) [leary yusoos AJA “NOQe LUTY ][O} 0) JURIONOI seM TJ SUIY] DUO SBM 919} ING ‘SuIyJAIOAD JO apisdn oy) Jeay 0} Addey A]jeor sem OPH “SU} SIY) SSNHP oy) Noy UM ‘youq o]Ilus Aw! 109 | [je JO JSOW jNq Spud MoU JO Sjo] SuLyeuw ‘JUBINE|SO1 Be BuLjOM pure ‘edOA ‘Sop Au dyHI'] “YVWUIQ 9y} WOI SOS DALY JY] SSUIY] POOS Oy} NOG WIY [[9} 0} ONUTJUOS OW O} POUd]SI] 9H " glosu suyeodal uo yday ysnf apoAo OY] PUB UMOP SOD PrNOM | [UN “DuryJAISAd YIM dn doay 0} ajqissod 11 Suryeur ‘surydiopud Jo MOTAVAO UB YIM SMOLIOS Aw poovydai sourummejoydue 3urddod pue oyoo oy] ssury) dunsous “S]JLQ@AIND S$ dfI] JO [Je YM Sureop pue Addey sem | daotjoq 0} BUIAT pue YSIy oq 0} papasu | ‘a10lMAUe YSNOUd Pood } USeEM xB[oI 0} Ael eB BUIYOUIS ISN “SdOULISGNS FULI}][e-PUILU YIM Woy) duysyxue;q Aq sUOTIOUIS Aw yyim podoo pur ay1yMme 10} passoidop A[jeod 4038 |,, “YIN o1MUS OY) WHY pjo1 pue yeoiq daap eB 400} | sv osned $.jUdTUOW B SEM JIOY] ,,gorowAue SSIUp UO NOA d1V,, MOU O} SuUURM SSBYD 9Y) O} JYSIVNS 1nd oY ‘Qd1JJo sajdroutid ay} Ul SUNS 3/QNoI) Ul P]IYS & OI] IOJ | “UADIS SISA SUOISSOIAXS SIY PUL 199}S DAI] SEM 9OVJ STH “UIA JOAO PUR sUOP SUTNSOW S14} Jad 0) SuljueM ysnf Apeorye ‘oy1jod pue yzoys sem Apdod AJA, ..NOA yURY ] ‘SSA,, SUIOS OyI] P,| JI poyse pue sseys poinod Apvoije ue Woy JajeM Jo dis & YOO] OH “WY WOI] SSOIOR JVOS B DARBY 0} SU! PO} pue ysop S8 Sty PuIyag yeas B YOO) AdIyor “WIA 2 ‘oOTJJO S AdIJJor SBM YOTYM “vueqeo Spisjood ay} Spisui 919M 9M BOUG “Ja]NdUIOd oY) 01 YONG UONUD}e J9y4 Jnd usu} ‘Aem AU SABM YSIIG B 9AvT puv ApyoInb dn psouey[s oyg ‘[[vo ouoyd ZuIpuNos JuRJOdUT JOY qINysIp Oo} SuNUA 4OU ‘,OT[aH,, @ paouAs-diy pue aAeM yoinb e yy Jay jsed popeoy om pure ‘Aeme SUTIOM sap Jay “ods [ENS Joy Je SLM SULISTYH “SPISUI ST Poy puke 1OOP dU} Je SW Pojools 9] "JJOSALU JO SIV SYP] 0} OP O} PRY [ JeUM SI SIU} POOUIAUOD UDAD SEM pUk UOTENIS Aw OJ UOTNOS yoInb ev MBS | ‘pooy A199018 JO} s}Usied Aw JyO ABuOW MOIIOG 0} SUIALY pu Urese QOUO SORYO Ul JI] ATW YAAK “WILY 10} YIOM 0} YORQ SUIOd 0} Apeol puR dn pouesjo sem j Ji no Surpuy yo Aem sry isnf sem Aqpear yt “dn yoyeo 0} pur Youn, SWOS JOJ UOISURW YORdg UW[Rg SIY O} JOAO OWI d}LAUI 0} ][VO B OL SAIS 0} poploop AdIJJor “OOIOA IeIpIWey @ WO [eo suOYd estdins eB sem JI peoysuUr “tIY 9q 01 1 pojoodxo | SuluIOW suo AjIva Suvi oUOYd ay} Us4 AM ‘MOU JOJ “SUIPIY UI sem OY “fT Wo Susy ROM possed yoom OY] ? ‘plvog SUIMeIP sy] 0} yoRq SBA | “SATAINS UBAP JO ‘Jeo “uo Aed 0) AdUOW OU YIM puke WOdY dn dy¥e@M 1,UP[NOd | WedIp peq & Ul SBM | OYI] I9J | Poyowss 9q 0} o]qQe JOU SBA PUP IYSIU JSe] 919Y} Jdo]s 1,upey oy osiidins ou Oj pue osnoy sjussed Sof L jetp 0} urede dn 41 yord 0} AJUO IDA19001 SY] UMOP PaUTUIR]s | “QUOp 9q P[Noo yey} Suryiou ‘Ad! puv LWOYs d19M saBojode sip °..4910Joq Olu Wo sua;qoid Aue pey USAd JOADU 9A NOA pUk [L9]S USAd } ,UpIp | Aouout Joy yayood Aw woy nod Burked u,] YSnoy) usaq,, powurejoxe | ,Ayyornb OS UMOP opisdn Un) SBUIY} PIP MOY “SULIvdY SEM | IVYM SAdITOq }, UP]NOd | ..AdUOW SuUISSIWW 94} JOJ YOdaI sorjod v S]IJ puke OS NOA ja] 0} INQ d010Y9 OU dAzy J,, ‘Ssodem AW Jo NO ADUOW JSO] SY) 94} 0} LuIY payse pue SSOUIIS $s, pudyAog Aw ynoqge Joseuew Aww Oj ulejdxs 0} poi} | pue MOU QUI JO} IBD]O 00} [Je SBM J] “TYSIU yse_ yUdUJIede AW OJ YOR SWIOD OF JUBM UdAD 1, UpIp ay AYM S.JeY] “} YOO) oy pue ssnup s10WI puny 0} Ajiunjioddo UB MES OY “IOSVULL dU} YIM Yfe} O} [MOQ dy dy] jnoge suLyUIyy UDAD JOU Jeq OY) Je WHY Yo] | UOYUAA ‘fE Youurojs Aur ul JOUy 9/qILI9] B JO3 | pue ApURISUT SW IT] JOMSUB SY] ©, SUISSTU S$ .Jf MOU ‘O1OY) UT SIeT{OP Aji] pue porpuny e& ISAO SBA 919} PUL IYSIU Jse] Yo] pey Nod Jaye Ajdwia sem Jef dy oy, suonesnooe siy poureydxo pue so10a Au ur ApJsoues dT} IvdY Plnoo sy pur lq & Poul[ed pey Uo} STH ,,{,AOUOTU JeYM “jnNoqe BUIyye} NOA due JeYAA,, ‘YOeq WY poyse pue ‘Mou oyeMe Ajajo;duto9 ‘poq ul dn yes | “si AOUOW OY} DJOYM BUTYSE Puk OU Je GuTUIBOIOS PUd JaYIO dU} UO ‘PayIOM | SIdYM JULINE}SOI SY} WOOL JadevURLU OU) peY | ‘[jeo suoyd Suryloye ue Aq dn uayom Sem | SUIWIOUL JXOU OY] “IYI ],USEM SULYJSWOS yey} SU UO UMEP 194 } UPIP Hi dn poaaal os Sulog “jYSIuo} wWIYy puNnose 9q 0} JUBM SUOTP Jd] LLY JO YSIS dy} PURyS },UP[NOD | “OS OP 0} pasi{qo ueY) SIO SEM | ‘OSsnoy S.jUdIed siy Jv JJO paddosp 9q 0} poyse puke jainb Ajppo SBM SY YSIU 9Y} JO ISO1 OY} 104 “MO} UI ( [| YIM Jeo AU 0] papeoy pue 879 $0 909aeHed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 39.99% accurate

17POORRTLINIO 88 SEM I YSnNoy} Aosyjar ‘YSnosry) AVM BLOM 3} SuIysne’y ‘usapyyo isn alam Ady} ‘PULy ISIOM 9Y) JO aquiq B sem s}oodsoid Jo3IVD BUI[Spow pue ‘SeSIA ‘AOUOL JO SINS [eNSN 3Y} WY) DULIOJO ‘sjusied J9y) Wo ‘soURI ‘SIIB Ul WAY) JYSNog jounrg MOY UW {Jd} O} UO JUSM 3H “MOT PuNojold jy} 0} UNY JYSNOIQ Isny SITY MOY JO UTeSe WT] pUe SUN SUI PO} dy se SOVJ SIY UO YOO] IU} [[BOOJ | USYM ISNSSIP JO SUI[IOJ ST]} DYBYS 1, UL [[NS | ‘JJOSAU 0} JYSNOY} | {SNOLISS NOA ae ‘PpO IVdA SAJOM) Y “S]SEIIG JUDISIXS -UOU puke UOISSI dIGnd M9y) UT YJMOIZ Jey JO JUNOW {yews sy} Aq SuNoA A]]eai aiam Ady} [[9} pynos noA Moy pue sJoMm Ady} 31ND MOY SysaM JO 9S1INOD JX3U SY} J9AO UILBV ISAO puk IOAO BUIALI ddI ‘JUDAS SINUS OY} NOE Po}IOXxa OS seM 3H “AT{VIO JFO IY poysiuly pue wiy posessew [je Aoy] Moy SU BUL[[A} SUL YIM SJUDAD DAIJCLOSap oy] podeydal of “JU) Je SIO}SIS ‘spIId Pjo read dajamy ‘d014] Suydsooe adu0 ‘jounsg wor jussoid Aepyjiq sty jnoge passeiq ArdJor Ng YIOQ JO SI }1 9UO YOIYM MOU },UOp | ‘Ysnous YoIs JO yBnous pridnjg “noqe Muy J BY) SUO Jsed] Je “MOT SUID IIe ue WY 0} AdTJJor JOJ [QuNIG JO JUSUIURdWIODOR 9Y} Ul BUC] 94e} 1, UPIP I] yey) Op pjnom | uay) ‘Addey Aasjar daay 0} siyj Jo [je SUlOp JURSTH IVY) Ji pue 3}1] YIM UO 498 0} OP O} pey 9M JeYM OP O} peyY [[! 9M PSOUIAUOD SEM | peoy Au ul jnq ‘dj1] Jo oseys AWW Ul OBeJURAPE UR [ed P[NOM | JeYM ApOVxXS JON ‘JJO Surysof J9uIOS & UI URW B AG PSAIaSgO BUIDQ S}IYM “JOO Yoes uo Avjdaioj pue SuULyRUtoaoy] Jo sjoe Auvwl SUIULIOJOId Je JOOXS 0} poJoodxa dJOM OM SONTUO} JUDIIJJIP ur Suppvods “19yj0 YOR puejsJopuN UDAd }, UP]Noo 3M Jhq YSnoud prey sem Sioduens 9}9[duloo Gulag “JIosunNoAd pue ose Aw suid AUBU YIM PoQIyUIUN 3q 0} SUIARY JURSU YOIYM ‘SsouapIsel AUR SITY JO SU0 4B UO JUdNM Jey) SUOTIEIO;Axd SNSTUOpsy 94} Jo AURM B Ul dye}-]LWed 0) SARY P[NOM | “YORyapis jUouRULIAd Ss, Aadpjor Suiog ‘SdIpog [Ny4Nnesq pue syxoo] [NyYNOA Ino ‘ouoTe Bury) suo 104 pasn Zulaq o19M [je OM ‘S9dUdAAJJIPUL JeIN}[ND INO JO ayods om adensue] WeYyM ‘WLOIy BWLD 9M AUNOD JLYM JO SSo[pIeSd1 “PUS OY} Ul SWS OY} DIOM jJ@ S|ALs sn ‘sSay 19y}) UddAK\JOq AL] JBYM SI YOM ATUO 9J9y) Woy) dupes} Aq soouvury ul dn-dajs e Jr1d & SUIAID “Jey Ul sozuedWITYS o1Jeqieq B SB SIOUULU POZITIALO YON se pey Ad} SIOOP pasos pulyoq puv Aeyd Y[EOM PoIJIUSIP dy] MOY JO UOISSOIdU Ue SUIJSS SUOTIUSJUI 9OIU OS JOU {IM adooad soru ATTeos ayI] poses Jeym JOM sso] “Aydessoulod usao pue ‘soinjoid opnu *AUOLI JOJ SSIPOG INDY) SUI[[9S Way] JOF YOM O} WDT} SUIDIOJ ‘JUdI JOJ TOY) 9dIVYO prnom joung pue AoIjor “Wies} 5y) o}Inb aiom Ady ‘uReYUr] ‘IS 99 J [OE UO xojdwoo juoutpede s_JayjoIq SITY JB Way] Bursnoy AdIJJor Pu SII SPOSISAO-dSCIOPUN IO} SESIA IVUINTISATII IY] SULUTBIGO [JOUNIG “JOJO YORS JO SOURISISSE OY} YA “WIOIfJ SSOOYS 0} WY Joy de} uo sid yo Ajddns pey mou Aoiyor winjos uy “Auedwoo sjounig O}UI SIB{[OP UOI]IUI 9UO Pd]SdAUI Sy puUR sjed ssojo swWedEq Ajs}eUIN ‘TVILNACIINOD feuany] poyosjosy wYyBUAdoD Oz POOTALANIO £8 Adjjor pue wiy AYM SI YOTYM ‘JOS ay JeYM SI PajyueM oY JEU AA “HSe} B JO YONU OO} SULLUODSG SEM Poq SIY Ul Wdy) SUNIOS JUROLU JEU) Ft “YULIP dU} Ul []Id B BUIMOIY} UDAD SOWNIWOS “OJI] Ul SAUTY) IDUL dU] JO [[B Wot} asimioid pynom dy ‘AauOUW Jo sjuNOUe OBIE] puke eOLIOWY JO SajeyArey UUM Sspesy 119y) Sul “olquday Jo1AOS JOWIO{ 394) pue eoLowy ynos ul sqnyy Worf ATJsow widy} sindoid pynoM sy “Aouou JOJ BuryjAue jnoge jsnf op 0} Suy[iM pue soujuNos usyos AWsAod Ul SUIAY sornesq SArTeU ‘BUNOA JO YOIVSS UI PJIOM SY} SUILULOI IOJ UMOUY SBM “UdZ1}I9 youaly & ‘[ounig ‘sjopotu Suttuoodn pure SunoAd joj yUase oul} Buoy] VY ‘JOUNIG ON’]-UkdL ‘JUSUSSAUI SSOUISNg puke PUdLIy Mou SITY UMOP yi ynd | ‘Auedwoo s,Adjjog ul 90U9IINI90 Uso ue sjinb 0} sj1yMe pue 90u0 WoI popuedxs sjYysiu JopliM pue SAO} Mou ‘s]13 JoSunoA 0} [eadde SIY PUL SISQUINU Ul J9BIL] 109 S[IIS JOYJO YIM SOTGIO dU], ‘Poesealoul Ajuo 1 SuryjAue JI ‘pozey Jaaou xas 10} 9]0dde s1y Joplo SuyIeS sem oy sy ‘Aejd 0) ou pojuem oy 9/01 Aue ul JjosAl SuIsedus siy Jo alisap jenxas AISAD 0} JUDIAIOSQNs A[oIT]US SUIS | “dIOJaq URY}) J9}}9q JOAd JO Jo] OM oJayM dn poyoid ay ‘apis siy Aq yoRQ [41d SJUOARJ sTy pey AdIpjor pue jusunsedaq d01]0g dy} WOIy yoRG Pedy JOAdU | posIWiold sem SY | pl taydeyy ‘IQAD UPY} MOU SOW WIY O} palqapul SuIjosy UTY 0} JJ9SAW PaMmo | MOU jnq dd1;od ay) pue AsuOW Noge pdadljol payIom pey syuids Aw usyysuq 0} Jus} STH *,.qyM Wop I Jopisuos ‘uoTeNys AYOS INOA JNoge SULYUTY] NOA jURM },UOP | SUNJULSU 9Y} UY,, “MOIIOWO} YOEG SLUOD 0} SU Poyse pue SJeTJOp paspuny OM} JeNsn 34} du pred dy ‘suivisdn adessetu 91}019 UL YIM BULUDAD dU} SUIpNouOd ‘UWIMS B PUR YOUN] SWOS JO} apIspood 3y} 0} Jno JUSM pue dn Bulyojeo poyvoy-}ys1] SIOUL SWIOS PIP 3AM *,,][SWS peg B dy1] sw punoue ssuey jsnl eiueig, {Ys MOY | ,, ‘pol[dos ] 00) Suoye Surysne Ty ‘poouwl JoquIOS AU JO JST] oYVW 0} SUIAY pue SuIpyonNyO sem sy MON _eisdo deos 31q aUO SI St] INOA “ouT) WOYs B YONs UT NOA 0} uaddey ued YONI MOY JNOge YoYsS Ul SOW UW] SOUT] 9q OL ‘Noe ALIOM 0} SJOW SUIYJOU dq {IM dy) LOY) YIM yeods | Joye pue ‘suoieuop Ie][Op puesnoy) poipuny Jepndes wy) oars | ‘uouedsg so1[og AjyuNoD yorog wed du} ym Aqperodsa suondouuod Jo jo] B 403 savy | “jay JO} SUI 0} 9UIOD 9A, NOA pe]s W.] “ATTeEMoe sy1soddo dy} 931ND,, oeyyedwAs pue posiidins poyoo] dH ,, S14} JO [Je yA NOA 0} SWOD SAkY } UPpHoys ] -' Alos Os wie | “eBes Au 0} USJSI] NOA Sulyeur pue nod 0} ssoul eB Yons O41] YOO] ISNULI J,, WY O} pres | UCP oSeWeEp Auk JORMA O} SUIAIT ‘OU 0] YSOP SY] SsOIOe Wd} passed ay ‘xOq 94} JO NO Sanssi] Maj B Surg 879 JO L099Hed ‘OEZBZ9Z ‘6TOZ/60/80 ‘8ZZ JUaWINDO ‘898zZ-8T Based TVYILNSOLINOO JELIDIEY porosios,| IysuAday 7

The text on this page is estimated to be only 39.71% accurate

EZTZFOOTUIAMO 06 -IQUUI 1S9}BIIS AU SUILSQ S3UIT) JO JSOpsEY OU} Je UT Paaposge sem | BUTISEj yey) dsei3 oO], “sULYs Udplod & OJUL SJVUTUIN]|E PFROM 31 JYST] UreLS. Ul pue SoU0} aSIoq puL UseIS ATYVIVO pUR STITY BUT[[OI $.9,J eJURS ay) Jo adeospur| dU} SuIvDaq UOOS d110AR} AW ng Ae[dstp UO UOTJOUS puke SIO[OS JUBIQIA PoAo] J ‘ina UdAd pure ajdood 0} sjeumTUR ‘soUddS JoyeMIapUN WO; “SoJO}UT soXd ou JySNvVd JY] [HFNNeSg BuryjAue jured prnom J ‘Jaded uo Mes | S9BvUII OY} 9}v9INII OF POA] | “Ystug AW YIM Ajneaq Bueosd Aq yomnb jnos Awl opeut I ‘aultu Jo aunsed jeors y “‘Juled 0} SurjsoajUi SUIyJOWOS JO] YOIvds BY} UO SEM J JUIed [10 Jo aSeOd [[eUIS B puke YOOGYd}Oys Aut ‘JayVM JO 91}}0q B JNq BSUIYIOU YIM saiov JO S_paipuNy pojsaod YSIyM yours $s Aadifjar uo pur] ay} Sulsojdxa jno sem | UOOUaye 9UCQ “Auedtu09 umo Alu Jo apnyyos 9y} SurAofus pue ‘sosioy SuIpy ‘syply ay) BurMeOI skep Aut puads p,| ‘yjsva UO UDARDY JO DdI[S [JEWS B SUID POIOPISUOD | MOUY OY JeYM ‘SABP MOJ B 1OJ YOURI SITY O} ABME OUI PUdS PjNOM oy ‘UIeSe SU PKOPISAO 0} JUBM } UpIP Adore Jl SB [fe } WI Yeosq & UI AID OT, ‘210J9Q PRY | SAL] SOALM OYLU O} BUURM JOADU ‘yainb yday | Ing ‘yey) JO] yYSnous poos },useM ysnl | Jl JopuOM OW OxBUWI p(nom puv yyoueg s,Aoyjar JO} pasn },UaJaM Jey) sjoyuaT{O Aue Buipjes },USEM | MOY SU UO UMEP O} SUTR}S SEM J] °,JOA UMOP Poulin} UI9q JOAOU PRY 9Y,, [{aM UY MOUY OYM 9SOY} BUI[[9} ‘ULede SWI) ue 9UTI} posu SEY dy SUSYOS Y “UO OS pUk s}1yINO ‘SAO} BY} SOD P[NoM Uay} “ajqe pue ZuIT[IM ‘pajuem oy 9J9YM SN pey sy USA “[VUR IO S}skoIq ‘PUISEA ITOY) dyI] soovyd Jo ayeatid Jsow IY} Ur ‘ATaJVUTJUT TOY] BuTyono} “yeods 0} OS ‘[[F] 94} JOJ Ul O8 pynom ay Udy) poyeU ApJUoNbasuod puke ajqepojUOS S]IB |NYINvIQ 193 0} PayeI]SOYOIO BIOM YOIYM JO ISO] “AdIJOL Aq dn jas asinod Jo “19y) pue oI9Y JUdI{D Ppo ay} aUIOD Pynom UsYy ‘gol yey) JOJ ueU B poLajoid SYS ‘UOUIWIOD SB },USEM I JN [[S JOY OdeSSEUI O} SUI 9SN SOWTIJSWIOS P[NOM sURISIYD “Aep B DDIM] JBAO BUIOQ SOUIIJOIWOS ,.S}JOUSq YM, OSLSSLU NOY-OM) B JO] SUI Suisn I poaoy AdIJJor pue “(13 [[eus ev Yons Zu1dq JO] OP pynoo | YM ul popunojse suom Aue ‘Apoq v uo Ajdde 0} TWBuans JO 9ouNo AJ9Ad Suis] “YOM Je SLM | UBYM ABIOUD PasNdo] & IIOM spuey Att ‘qe AU ji SUIATS SABMIe ‘SosesseUl ATU OJUI Joysued) II 998 pnos dy OU [][9} pynom pue espa; Mouy Jo} uorssed AW jnoge SuLKaY pojldxe 103 pjnom ay ‘tury passoidur sXemye Addjor UO SOAOUI Mau AUT BUTAIT, "SOSINIOXO BUNLIDOSSE YIM YOOQYIOM & OJUI UOTRUNOJUI dj] Jajsuey pue tool Au 0} yoeq Alny plnom | ajo[dar09 sem UOTSsaS dU} Jaye puke oul 0} UMOP possed pJOM AJOAD OJUO BUIPTOY ‘suOTssas BuIUILI) AU 0} PIBMIOJ POYOO] | “YOay9 ul ou yday ATUO O} Poy O} LUBOIP SiY} SUI Bulais Aq pure }I JO} SuryjAue Op plnom | peq Os JUSIOLNS -J]9S 9q 0) pajyueM | MOU d}j “Sap Suuodsoid yA yNpe BuNOA e Bulaq O} saiiqisuodsal ou yyiM JaBeuss} v Bulg Je yOeq Buryoo! Woy ou Buldsoy ‘3ut] 0} auIT] Woy AdesJay) asesseul ul Bulurey Jadoid udsArs sem [NS | TWILNAIGIINOS jus] paajorg wy SAdOD GO Z77POOMMAANID 68 ‘VL JO Jooid BuryyeM 13M STIS Joyo Auew OS pue jpasdy ‘sosou S,ApOqAIOAd YJBOUJOPUN JYSLI POystxo []S nq o8v own Suo] e& paystjoqe ATpasoddns sem AISAeyTS ara AIUNOS e& Ul pue ‘seq OU YIM [Tel eB UT paat] | SI Aes ued | [[y ‘[esodstp Jueystio9 sty ye AO} [euosiod eB savy 0} WY 10y Aseo 11 spew jsnf 1 JURTTdUIOD Os “pojURM sy UdYM pajueM oy JoaoTOYyM Bulog Jo Aypiqedeo Aw 0} umop }1 ynd sAemye [JIM | pus oY} UT ssans | “SA0] YIM Op 0} Suryjou pey Ajoyuyep yt “Aoyor 0} [e1oods 10 jUeWOdUI Os SUI OpelU JeYM MOLY AAI IDADU ]],] “SEM [ Jl ‘IOAR] ABS | P[NOYs 10 “UOISed9O BIq B SEM }I PUR INO pouURO] 9q O} peY Ajaaes Aoajor 0} BurBuojeq Ajjeuossod | “Ajayeunjus [Ad [NJrNesq Be MOU 0} 3u19}03 ye JOYS & pey 19A9U 9A _pjnoMm } JO} Surked uey) Joyo OyM Ut Je] Suse osoy} aJZZepoq pue wueyd oj saey pnom am ‘yse} B Duyoydwuos ATUO ‘YIM JUaM Ady) WIOYM UT Qd10Y9 B pey [JIS ON “Joye]d @ uo spieyy909 oom Ady} oy1] punose wy) ssed pue sjiid duNoA Jo JUudW}OSse Oyj JNO ZULIQ P[NOM dY SOOMDPISAI SNOLILA J9YIO SIY JO PuR]sI Sly 0} ssouRjUTENboE poidura) Ajisvo SuriAuy “pur Jo 9384s [Ny HId sTy 0} UMOP POD sy JeU} [[e SeIP 0) SEM SATJOUI 101I9}[N SULAIUUOD Sty ‘ssuLs Jo Aueul B [jd 0} AjTIqe 3) yim AouOUI 0} }xOU Bury) ATUO sy} Bulag [LeUTY{de{q “][e II JO 19JUS9 94} Je SBM OP “9fOI19 OY] UT doy SY MOY SI SIOARJ JO} SITs Burpes pue ‘owes Siy} ut a[doad yy 3tI 94) Jo [je Mouy AoLjor “St }1 ABM OY} POM siqy jdasoe OQ} SUIARY UONeZI]eOI SuIWIEle Ue OJINd ‘pip Adyar Se quuNy} JO sjN1 sues ay} Aq poaly WOYM Jo JSOU * SOTILUOT[[I1q Potlaa}so Joy}O PUL ‘SaT}Iqo[99 SNOW] ‘WUOWIeTLIVd JO SIOQUIOW SNOLILA YIM SUIS PUR “SIdTOIBJUOD ‘soured JOUUIP 31199799 SIY JO [[e ‘UIRBE WIY YIIM BayMAIOAD 1U9M | ‘JJop ulejaosod yeuosiad siy Jsowye pure [je 0} ajqeuisap ‘duryeads juanboja sIy 2q 0} pey | MON ‘Jsed ay} Jo [113 & sem JoseUdd} O7}}1] A}JOUS B BUIOg "SBM JEU] JEYUM JO oinsun sem | jnq ‘asa Suryjouos 10} dn ow Sururey ‘uonisod mau afoyM B OU] ul SULIDYSN seM oY “BuUdAd oy} JOJ DIV AU asOOY) atu Buidjay JO SUONRINSUOS BUIUdYM YI}99) Je]/NBo1 1OJ S}sijUap 0} UW SUIPUdS ‘POOF Yoo] oul djay 0} suoNsassns Jajjo pynom pue ojur durdojoaop SEM | URIOM [NyWNeAQ & LYM alu Surpa} }doy oY “Adsjjor JO apisjno ayr] AU swede Wy Suldaay pue spoq SUIUUe} UT SUOTSSaS IE[NBIY “dI0JOq JOADU OAT] J[SSAW Jaye BUTYOO] 0} YOO) Mou | ‘osl] AU JO Sasde]Ss PlweMyAML dU} JO INQ “a10Joq JOADU OHI] SuTWOssoyq sem Apog Au puke ULTUOM ZuNOA & ZUIO OJUI BUIMOIZ SBM J ‘YOTAOp!Is 9SLudd} Siy JOSUo] OU SEM ] ‘UoIsed90 at} 0} SuIstIy ‘ssourddey Ayjod sty pue tay punose paaloAsl sem oft] Au ‘Auedaoo s_Aaujor ur juads J syjuoul Jo afdnoo yxou oy], "SWROY IIOY] Pd}Ol yey) UOISIOAIOd oY) JO Sollsap ay) Aystyes 0) **-osodind suo 107 sAeM JO AJOLIVA B UI papeIdap “PajefOIA ‘pasnsiw s19M Jey) YJed II9Y} UT dSOY} JO [IV1} SAYONIJSap B PaMO][O} Wd} JO OA} OY} PUIYSY “SOAd SIY UL JYSNOG 9q 1, UPf{NOd Jey} SUO OU JO Buiyjou’ oly JO SAEM [Te poonpos Aouow Ajisea Moy JRL] Ajaynjosqe 879 $0 g09gabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TWILNIJCLINOS JELMOIEWY Poloo1esy WYBLAdOD | |

The text on this page is estimated to be only 41.03% accurate

€tCFOORRLTIATD Z6 IM PUP ISAO [TB dW Buryyxo1) ulsaq 0} stu UO peduNnf puke pajnoys sueRsTyH gi Mauy I, qyeap Alu poyxey puke YONOD 94} O1UO ][aJ | “UdITY Woy JUdOS B JOBUdAI O} LYS Au UT 4st Aut SuNjnd ‘out Jo No 393 0} GUIAY SSUIY] SUIOS YUIY J, ‘Ured Ur YOvUTO}s AWW Geis 0} popusjoid pure oivys Yeap pajyesodsexa ue y1Og wWdy} 9Avd puke ssdo AW poyuInds | .UueISIyH SUIYIOIUOS OJUO 9q JYSTU NOA Yur} J,, “SIIq OMI STY YM ut duinf o} pey AdLJor Udy} “Sn Jo OM} DY] UZBMIOqQ JOJURQ A[pUdIJ ysNye ,JoURTd Jayjoue WOLf 9UO dy} SIV NOA jeY} YUIY) O} PUd} P]NOM J SINOA axl] JOTUNY Jo ssuas B UUM,, ‘SNOSs A[OSUdJUI SBM SYS ‘SoWeD puke UNJ OU SEM I . YIOM,, 0} JWT] OWED JL UdYM INQ ‘19Y4}9B0} OYO! eB YORIO 07 B1qQv Ssa]oYJOUOU JayjoUR JUO SplVMO} SHoINedid SABMIe ING J3Y}O YORd Aq poUsjesJY} JOAaU ‘dUO ppo uv sem diysuoneyal ng “ow Jsed unj jensn Joy ‘ow 3e uN poxod duesiyy ‘Ajpajyoodxq ..{ualje ue se Jjo ssed ays pynos ‘Aoiyjor yUIYy) NOA Op yeYyM ‘youRI dy} UO QUOTe OUT} yey} [[e pue NOA ye YOO] ues | {peqoid pue pajonpqe },uolom nod MOU NOA Op MOHY,, “ABM JY} UT ‘SN JO OM) 94} PILIUDIJIP Jey) SplepuL}s [VIOW JO 90UD}SIx9-UOU JOY A[UO AT[Bd1 SEM }I Spuids 9044 JO J1Q Ss Bulag YO ‘ABM Jey} Ut JETIWIS SIOM OAK “POMITOXS SUPISIUL) , SOINUDAPR JSaq dU} BUIARY SABMIL INOA,, “BBOS UdI[e 9} UST) pUuk SSIUJAPIM IY} Ul [BAIAINS JO 9/2) AU J9AO YsNL] Pood & pey sURTSTYy pue ‘Aaijjor “YJOA MON 0} 03 | US AK £199 | pIp poyoods moy ‘surmow dU} Ul JoSAtu Je poysne] [ pue foros e SVM JY SIU 9y} YsNOIY) SULATT ‘MOOIpsg AU Ul SUISq UdITL UL 99S 0} BUNISAXS J[LY ‘IOLOJUWIOS 34} JO SSOIASIO UddoO ]][RUIs 3q) ySnoiy} Suryeed ‘Surwry pue surssoj yystu Aw yuads | ysru yey) UO s}YBt] dy} pue A | 94} UO Bulaesy “JO;d YO1y} Oy} UI pedoysaus JoYyUNy suedaq pue ezzid Ayounso “jung AW UMOPp PoYysUNU | ‘dJOYMOU JO S[PPIW 3y) UI yours & UO dUO]e Bulag payey AJUSPpNS | “BOIe SJOUIOI B BUIJISIA “SEM | D¥I] ‘AIIM YOIYM ‘SBUIOQ [BLSILIOJeN XO Woy suoyoNpae ajdood jnoqe AJo}s ani] B UO pase SEM 1] “YSU Jey) OU JO JoNOq 9Y} 103 NOI ude jnJpeosp S.QO86] ®WOS ‘poyoood ezzid ay) arya Wioodod oy) UO payouUNuU pue s1AOU eB uo ynd | ‘wioodod pue sezzid uszolj ous puno} | ‘Anued pue sspLy 94} SUIPILY “YOVUS JYGIU-d}e] & PUT O}] USYDITY 9Y} 0} INO 43s puke pUIM puOodas Alu }ysneo pey | suoyd ay) dn duisuepzy 1WYStupoos pres usy) aM “AeMe Syeaig [JeUIs ssat) poyerooidde ] yonw Moy MOUY WIY SUI] “Yoom JeoId 8 JOJ syuReY) AueW AdT]Jor SUIATD “MoU oY ATUO “SUOT MOY JO} “YIOX MON Ul Addpfof J99UU O} ‘}xoU Jaye Aep dy} WOdITy [euOHeUsS}U] onbionbngqly 3} 0} USALIP 9q P[NOM | “Aep se] AU Sem MOLIOWIO) JLY] SW PopuUTUal PY ‘yuids snoinjusape pur AysolNs AW pape sy joey U] “Wsy) Sulye) sem ] 8) ult}, UPIp aH NO yBaIZ AT[eIO} 07 Surlosd si sys ‘sjovjiye [eo YoRrq JOY JYDNOIQ | $998 SYS [TUN Je AA,, SUBIPU] YIIM SAOT UT SBM OYM “WOT AUl 1Oj 13 B ysNf o1aM AD} OY) Po} puke ysonbol sty posps, Mouyxoe | . puey Aut umo Apa}BWI]N pynos justUISAO03 dy) SUBS Jey) puke UONRALIaSOId [BOLIOISIY 10} YSIS B 9WIOD9q PyNod “TWLENACTINOD jeuajep] poysnoig wyBsAdoy |] pczroomMasINoO 16 yt ‘Ayrodosd At uo Jynjs 94} punoy nod aiaym Inoqge SuryyAue Aes },uop noA ;nyased aq ysnf ‘s ofqond ueipuy pjo oy) punoj nod Ji Su) BuO] Be 9U03 ud9q 9A,ISNU NOXZ,, ‘pastidins punos jou prp nq passosdun sem dEy “WLM AUI UO PoJOAOOSIp pry J IWYUM WIY {3} O} a[qe AT[eULy SBM | Je} YIM pue SOURSINU dINJNY B SUING IU JO ATIOM SITY PoTJstyes | *,dU YIM 9UOSTWOS dye} 0} asttuold J s10;dxd 0} JURM | OUT] }XOU OY] pue UOSso] AW poled] ary | Aes Apjsouoy ued | ‘uiese yey SUIOp 9q 3,U0M | ‘Aarpyor ALIOM },U0q] ,, parvo ay Ji Se puNos }! Oye O} peY jnq ‘AyITIQeI] B Suriu0daq DUI NOG PaLLom ysnf sem oy pud dU) UT ‘puNoy pey | JeYyM UNTY Surya} UO pajsisiad | ‘SJUBULUSI UPIPUT 94} 0} YORQ BUIOH “sem ] DJOYM SUIMOU SUOAUR JNOYJIM BUC] OS OJ 9U0B BuIaq JOJ IW Popjods ay pue sZurpuly Aut Jo wry 3urjja} Aq Wry JOVNSIP 0} Poi) | IOIOA SIY UT JaBUe JO 90} B JUI99}Eq , BUIUDAD SIY} YJeM INOA WO Yoeq 9WOS },UpeYy NOA OW ]]9} 0} SUI payyeo spew oy} JO 9u0 ‘JYysIUO}) pouoddey yeyM,, 9ouURIeoddesip AU JO powlaye useq pey oym Adljjor WOdy [72d B SBM I “SURI suoyd oy} dasyse suljyjey sem | se puke iYs1U yey] pojsneyxea Ajsnonusdjs poq 0} }UdM | “SOINJUSAPE [eNsn AW JO 9UO JOF JNO Udaq 9A,jSNU ] Surwinsse “JouurIp 10; dn pomoys 3, Upey | Joye splewasnoy dy} 919M OS PUP PUD 94} UI POADI{I1 OS “UOISSIU B SEM UOISURW $ AdIJJor JO UOLJDOIIP dy} Ul pue yyed ay} 0} yorq ABM AW PUlJ 0} SINOY 3d1Y] JOAO OW BULYR “eazy YUM paljijod sem J MOU INQ d1JOJaq Pasnjuod puke sO] SEM | ‘ysayo ATW JO yNo A]JeoU yeaq pResYy AU SUTYeUI puke YOOuU AU JO YOR OY} UO sUTLY dy) SUTUDIYSIOY “suinip Jes AW UI psoyos pure Jopnoy poryljdtue Ayuo Auose JO sulealos S41 “IaYJOUR IOJ JOUUIP 9UIODOq JeLUTUe JOOd OWOS play f UdYM Po]}IeIS SEM | “IBAO Bd1M] Japjnog Suryooy sJerpiwej e Aq Susssed Joye Mou ATs Suljaay “Aemyyed ay} 0} yorq AWM ALU pul} 07 JY] Aue JNOYIIM JU BUIABD] S]{IY 9} ojUI Jodoap YuNs pey UNS dy} POZI]RdI USAd | BJOJoq puk sJOY 99UaSsa OU JO SOM SUIT] “UMO ITO} JO SOje} SUL]]O} YAOMIL YIM S[MOQ UsyoIg AUB jo syed pure ‘sjisuajn ‘speaymoue Jo sodoid aI¥1 P3}d9[[O9 | “9}IS S1LI0}STY 9} BUIPUNONS Spyoyy oy) punole Suo{dxs9 sO! SWIOS OP 0} Paprloap | SSUIPUT] AU jNOgGR Pd}IOXY “} JO pis Oo} OJUT poydjo sudIsop ULIpUy] pey i Jey) pajou pue ;mog AvqO B JO Jey OyT] poxoo] yeym dn poyord ] ‘Yool pue Avyo jo jno ope ojgand pjo ue Jo sjuvuWal U) Oy] SULOO] ‘ayqqms jo apid B 0} oUTeD | YORI JJO BUNJUP JO INOY UL JNoge JOY —— jAep Aue S puryuewny uey) YIeIM S,dItYeN JOyOPY 99vJ JOYILI P[NOM J SOT 103 JO IR} 00} JUdM | J pousddey 9a ppnom Jey pull AW p9I9]Ud UBAP JOABU pue oinjeu puodas Au SBM OLU O} MOU TUIYIAIOAD BULO[AxXy “SSOWOpTIM dy} OJUI puR YORI} OY) JJO po]|quinjs | USYM S}YSIS SJJasap dU] Ul BUryR} pue jeoy oy} SusAOfua seM | °O} poou | stUNAUR 9184} BUIAQ “}1 99S 0} ajqe we | soko Aw Suisoyd ‘Aepo} SI [[NS 11 s19yM Wey Auli ui daay 0} aw 1oj Joded uo Suyjynd pue Aj1uaI9s yey) Jo sd01d B Buryey 41] “JUDTUDADIYOR 879 $0 G09abed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVLINACIINOO JELIDITYY P9y99IO1,[ WYBUAdOD ©)

The text on this page is estimated to be only 42.01% accurate

LECPOOTALIAD v6 pred pue yysnoqg 13 JayjouR ‘asnoyUMo) MoU $ dURISTYH Je Suiddoys “Aep Aw ynoqe uo yudM pue purl ALU JO ydeq BY} OF AJOUIOW! oy) Ind | |e Ie SUNpAUL MBS IOADU | IAT] SUIpusjold ‘poyes}[IpUur Capra oy} dsap moy Yury} UdAD 0} JUBM J UPI |] ‘Satiyiqedes s Addo Je poystuojse ulese sem | “TH SULARS SB [JOM Sv ADUOW BULA YIM poumNsuods JaAq ‘asuodxa suo je {[e waysks AjLINIaS B ‘}1 JOJ Pay[Vd UOTSed90 OT] USYM pue spusty sjtydopad SIY JO [Je YIM deYs 0} uJod saJj “JYSNoY) Adar BUOJS 9UO YIM Sp4iqg OM) J} “YOVQPoay OAPIA aul JO [Je YOO|NAO A]Suysnssip 0} sem gof ssoym ‘ysap ay) iv Ans ysiueds asaqo ue 0} axods Aoijorg “Suiusddey Ajyenjor sem yng Aj}Iqgissod B ULY] SJOU MOU SEM SIOPIIIOS SIY OPIsul poyojyem Buldg SAOW AJOAO Alu JO SBulpaaz Aw yey) uo usy) wo Mauy A]USppns | sosdtui[3 joys pue 1099p oy) WOd Inq UONedO] 19exo Ue JUIOduId 0] prey 1 puNo} | Os Sursueyo AjjuRJsSuOd s19M SaseUl OY |, “PoZtusSoOda1 peYy | UOISULLU 913 JO SWIOOI SNOLIVA BUIMOYS SUdIOS |[BWIS “BUIYJSUIOS JO ppo Ajuamy3 ‘sudaros Auy Jo ABue ue SPA JJ9Y} pure ody SSAUUI]S B 3]O}S | USYM 39S PjNod | JBYAA “UOISURW SIY ULYJIM BSeq ALINDOS SIIJUS UB SBM JOOP JayjOUR BUIdq dq ISNWI SITY) SATJOINIS MOY BUIMOUY ‘SUWI] BY} JO JSOW uMop peay AW jday { pajsixd }I MOUY UDAD JOASBU | SIVA SOIY] Ul Jey} JOdIOSIP OS ‘WIOOI B OJUI PI] SEM | SB YOOYS ul SEM | “JOOP uspprty Joyjoue sem IOOp juoly ayy Ag yno ABM INO sem 1YSNOY) | IY AA “WOO AJLINIIS dy} ‘dojs pid Sw JO} SAL} PUL BVI B OSPR OM “LIDLUBD BY} UO STOIUOS 34} Jno SuLNSy sup SseM YS IJd}Je UOOS “WIIDUOD JOyJOUR SEM TI JO INO Jad pinom Aay] asn yeYyM ‘pslojje p[nos you oy} yeym Jo Aeydsip oynutur e ATU SBM 11 Ng “}ysnoy} | AO} Mau jNyoMod vB 93INd “ssolppe Ue Jo JosuT yornb 9u1 YM UoTRI0} Aue ul uossod Aue dn yord 0} pasn sem 1 MOY SN Pjo} SYS “UdSIOS JVLJ YOUI-3AJOM) B YIM VIOUS OIIT[OIeVS B “Ul JapIO UL PIAladal ysnf pey dug ‘d9qJO Jay Ul “I9Y Yo] pey 9M sISYM JURISIYH punoj 9A "919Y} JO JNO 499 0} Ajorxue AW Pjnom os ‘passaisoid days yoea sy ‘uMOp ABM O11JUS 94} NOA Je BuLIL)s ‘o1BY} BOM SIO[OD dy} JO [Je ‘jazey ‘useis ‘anytg ‘uMOIg ‘days AlaAd INCA PaMoy][OJ yey} SoA Jo ed B UJIM SURED YOO) NOA days yore ym Suoye Aemy[ey sy} UMOp sulpesids ‘paxoaodd a] Ajsaji] SIY WIsTUOpeY JO opis JoyxIep oy) sulussoidos JT JO ]]e ‘ueg pod ueSed oy) Jo sounjdynos pue ‘sdunuted jeastpout JUSJOIA ‘Sjadied pal poojg 9y} “Iod9p Jo soI0Y9 sty Aq Jno padasJo Os SEM | "I payey | IITYM oseolIe}s USPprY oy) BUTYe) POao] off “Jolpve Joy pestwold pey dy SB 9SHOYUMO}) S_,dURISTYH das 03 0} Apvds Jo 0} SIIe]ISUMOP SUIOS SOM JAA PAPNIUOD sem oSesseUl 9} Joy “pyay Apo sry 1ey} SdSS9.1}S 94} YOoTUN 0} SABA BY} JOAODSIP Spuey AW j9] PUL Ss[IO SHeWOIe Ul WI pasoyiey | Isidesoy) peor yeNjoe ue oyI] [90} ou Suryew “oars 0] sasesseul SIOAR AJA “OUNSdeIOYy) Apoind sem 9UO SIU} OU ‘sIIeJsSUMOP pajuem Apeolye oy JeyM 303 oY Bulods MOU SUI WO yeNnxes SuryAue JUBM } UPIp 94 MOU | ‘OISNUL [BdISSE]D O} DUIUDISI] O]TYM OBesse ® YIM Spaau SIYy papnyouod pure YWeq WeRa}s “19 MOYsS B Oy WIY pautol | TVILNACIINOS JeLUaZPY Possioig wWBuAdoD Q 977POOTUAAMD c6 _ ST tojdeyD “AQUOUW PUL XOS SI “]]e WIdY} JO 9]qQI41I9} Ajsnopus.uOY JsOW dy} JO S}uaUOLU [NJINBIG YONS aJvOsd Uvd JY} Ji] Ul SSuIYy) OM) oY] “AduUOUT Jo JUNOWL a]qejunooun ue’"jaaMS pue s]duuis ‘sjuBM ays JVYM SjoS ays pue spd JO Jaquinu ajqejunooun ue *s}uRM dq] JLYM sjoB oy “ssoursnq [njyoodsal B OI] VOU ‘auo ajeuoissed B JOU ING Way) UIB9MIJOq BUIMO]J BAO} OLUJaP B S_dJ9Y} “OARY OM) BSOY] drysuONKos adueNs AIDA YW “adesseul SIY JIM poysiuy sem oy UdyM SUOTBAOUAI BsNOYUMO} MAU JOY JB YOO] B DARBY SWIOD O} WY JOJ ySe 0} WY pojuRM sys soy Jsnf dn uy parsing pey sys 1YysNoy} sueysiyy “uo yoRQ soyjojd AU Buin “soso sirejsuMmOp § OUPISIYD Ul dJOM 3M JY} SUIS UIRBe Passoip 193 0} pey | ,,,AeM ay} peo Apes InoA uayM ‘wes]qgold ON,, “soUdIPsqo pouled pawoysnsoe Aw yyim Aydas prnom | peojsur ,.xejai ysnf 0} sao] pynom pure JjasAw poi Ajjenjoe w,] ‘syuey} ON,, ABs 0} 201049 94} peY | JI SB ‘Jsonbol e uey) JUSWIAILIS B JO DIOW SEM J ,.gJeU} Joye dn poussoo] 3q 0} posu | ‘adessew pue yyeq ureays & JO} Suiejsdn ow YM dn sw0d NOA J ,uop Ay M,, Sanda dy} 19}3N 0} a]qQe Suryoo] ysnf yojoNs B JOJ YORQ sty SuIyose usd ATs B YUM paLinouos Aayjor . “UN SUM Je ],, “SPYONYS III OAMSIPUIA B BUIATS ‘spuvy Joy YIM YNOUI JOY JO Sopis 9y} padim puke ‘passosp AqyHy [js “dn yes ouRISIYH “oinseoyd us pojdnio pey Aoijjos pue s9ye] soynurtu AyuoM |, ‘Apueo oA Jo a0ard juerjdwos e@ sem ] ‘Bury) suo 10} a19y} sem | diysuoiuedwos JO} punose },usem | ‘AO} pasn ke OAL] [99J QUOSTIOS Oye 0} ABM [NJOWLYS Y ‘poyuRM Aoy) AVM Aue Ul Way) asnure 0} sAvy pure jOds oy} UO jnd aq pjnod | 9d1}0U S JUDO & UdAD }noyIM ‘yey oyI]T Isnf puy “pojuem Ady} yeYM YIOQ Way} dAId 0} UOI}ISOd xojdwioo eB ul yonod dy} UO Apog AW JOANSURLU O} peY | “Urs AW O4UI Ajdoop sdiy Jay Suissoid spremumop Surpesy soyddiu pouspsey Aw JaA0 siosulj Joy poysniq pue spury Joy ut wioy) poddno ays ‘siseaiq Aw YIM BUILIE}S POAC] SYS 91eq SEM | 9DUG “OU SSOIPUN O} Po}eys aUBISTYH ‘syURM poyoarod sty 01UT SATB 0} pey J UOTdoI SIQnd sty OUI pesy Atu Surysng “YJOM JO} OUI] SEM JI MOU ‘paddo}s Jo}Ysue] OY) JO [[Y “PpooyueWw joaJa SIY BUITROASI SjuURdeOMs SIY UMOP poT[nd puk UO sI3M 9M YONOD dy} OF JOAO owed Adlpjor “I9y}090) SurAejd sn Jo OM} oy} JB UO pouITy BuIpeyH “qred relndoed @ way) OPLUL JLY} Sd}VIADP OM) DSO} 0} Opts }dmsJOo puk SNsTUOpsy of} A[UO SBM JI JOARI] puke ‘AT YoeM “IOUUIP 189 OHI] SOWIE] [LULIOU O} JeLIWIS JoY}O90} SUIYJAIOAD PIP 9AM “A[IwRy poxoydiod A]jeol sty} Jo yede [je alam aM SAI] [Of OW Opew yey) SOW) UNJ SSOY) SEM J “Ja}Y4dNe] OJUT JNO dxO1IqQ [je 879 $0 OT9aHed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD TWILNICLINOOD JEVIJLY) PAAOL] wPsAdOy 6]

The text on this page is estimated to be only 40.51% accurate

6CTFOOFRELANIO TVILNSCIINOD 8tZPOOAAAANIO TVILNACIINOS Jeusepy poorer 34SAdOD JEUAILPL PAII9IOL JYBUAdOD || 96 SdINjsad puUvY YSNOIU) SBA\ SJLOTUNWIWIOS plnods om ABM AJUO dU ‘Jopunyq osny v Os[e SEM Wd} JO []2 JO INO YsiPsuYq oyods Jey) [IIs ATUO sy) SuIOg ‘T[OM SB JOGO YORS YIM SBUITUI [Te WIM 3M 910JOq SUOT 9q }, UP_NOM nw Mauy Apealye | asneseq o}jod jsnf ue) sIOW 9q 0} PRY J “JUdJOJJIP sem SI) INQ UNF JO Iq & SUTARY PUI } UpIp | pue STIs JO speIeYS JURISUOD S14} 0} P9SN OS SVM | “YORdQ dT} WIOLJ SN Yo}VM O} PuR] Alp UO pode}s udtU dy) ‘ouTfodtueI] 197eM 94} UO podtunl pue punole srys Jol ay) poses S]IIS sn TIAA ‘SUOdsId}eEM JOOPINO SWIOS PIP 3M Jooys OJOYd 9} 19IYVV ‘JI POao] poundg pure Aoyor sow oy} saedo0AoId SIOW SY} ING “}I JO} payjed JOYS dy) Ji SN JOAO pode]d s1qQe] psjjou eB OI] ‘Suryjou 0} }x9u ul poydeisojoyd Sursg 9OM 9AK “PpojuRM Ady) s1oyMAUL jnoge isn{ podeldsip puv pues ojul Snp ‘syoouurey “syo01 OJUO pajoysn d19M SIIB SN JO []Y JOOUS Axds BIO} PUNOID ye JD9JJOod Sy} Se pUR;SI oY) Bulsn sojoyd Suljopou! 9yv} 0} ui UMOY J9ydeIsojoyd & Bulaey oOsje sem ADIJJOL PUL JULI) SLY) S[OPOU UBISSNY “S[IId [NJyNeIDQ JO oB3eINOJUS jensn sy ysnf ‘9oue}1Oduil JO duo OU ‘JOUNIG YIM IOAO SUIWIOD Sjsand Maj & SUOIAXS SEM DY JBU] poduNouUR AdljfJar JSeJyxOIG JOJ 9[qQe) 94] punoly “MOU JO} SEM I ABM 94} YSNE Si sty) ‘sem Aono! ddd siy) YSNoIY) 393 0} JyosAtu Suly[9} dooy 0} pey | [[e pue sui J9AO ploy s Adyar AQ punog [js sem | ‘MOU JYSiI IOV, UPIp JsOW payuReM | JeYM ABA JAY {adOoOINS plo Apooi3 & O} O8vLIIeW ev “SuIUTeI JO 11g jeuly AW JO} Surpjjes dn pus | pynom 1G {)SOW UY popsau | UsyM 3194) 9q SABMTE puv ‘ayvuorssed os ‘pury oq ay pyno~A “dul 0} [eIDads sUODWIOS YIM JUSdsS sAep Jaiddey 9q 0] SUIOS IAD 91OY) SEM SJOJBM S94) SSO1OR JI PalOpuomM puke ULdIO dy] 0} NO payoo, | ‘JoInb yuam YT sy ‘[ards Woys snoqinjess e pue ozaanbs 1y8) B YIM WIdY} JO OM) 9] poxURY] | ‘osVo dnoyeUW 1OUSISOp Jayjoue dtu 1YysNog suR]|SIUy pue SSULUeS pojsnious puowrKip pue omyddes jo lied jngijnesg @ dul sae Adore “BURGeD ULE SY} YJeoUOpUN SpIs]No pouado | }ey) sjuasoid Jo ajdnoo e Jad pip | ING LOS Aue JO UOTRIQ3]99 B 10 deo OU SEM J1OY |, “AUILU pue SURISIUD ‘AdIpJor YAM YONOS 94} UO , AND du} puke xog,, Suryojem pur JouUIp jornb ev SurAey “puejst sy} uo Aepyyiq Aut juads | ‘Apeosye suop } ,upey | dul 9jzzepoq prnom jey) suTyjou ‘SUI JO} 910}S UT SdsLdins sJOW OU d19M DIO] °ZzezzId pue opyJeds sy JO [Je SO] peYy UId]YSI9 ZUIUINY pu IdUION OY} puNore sem AVpyLTG AW "dq 0} dn oul poy pey sUrUIeI] $ OJI] ATU JLYM ST SI) J[ISAW PO} | JQ o3e GUNOA v YONs Je dyeLOpuN 0} 9/01 B JO JYSIOdS B PUR dINSSoId JO 10] B SBM jf “SOIISOP STY JO [JB WIY JURIST 0} SNONIQWI SUIWUDOS ‘J]eq SY} UO 3q 0} peY | UONedwWos YONUL OS UUAA “GOL Sui & SEM SU JO poouU UT PUR PoTJsyes WY Buidsay ‘ssauisnq Busjov puke SULOpOLU Sy} Ul 19eIUOD Pood A][eS1 B JOY Buliajyo Aq ADuUOUI YOIND swWIOS dyVUI 0} Dd¥RId SIy 0} YDeq JOY SAU pue ose Au punose jis AjO1d B J99W PyNom | UOISed90 UO Os ‘ayedde sy []Y S6 0} S{IIS YSNoud JDAU SEM DIO], [JOM SE WTY 0} SPAT SULIq 0} ST Suryse [JMS Sem dy Jey} SADI[Oq 3, UP{NOd | ‘dojssOOp STy 1v YB sem poyURM IOAD OY [Je ‘SABP SS9y} PROAQE YON [ALI] 1, UPIP oY JopuoM ON “punose SEM USWOM JO Waiey STY USYM poT[IJ[NJ sem SolIsop ISOW JOUUT STy JO aUu0 AIDA] ‘POD W9y} 3q pynom sy UeY) ‘Adyar SAT] USUI JOJ Yes UO USdAPoq] 9IOM 919T} J] (00) Jey) JO SIVME ][L 9IOM OM PUL WIY JO payIom pounig DOUIS WIS9UO0D Ul oy) SuUloq Aojor “JodwiyM puke UBOLI AIDAa I19q} Uo SuNnop ‘UOUS}e JsOWdN I9Y) Woy) SULAIS S[11d OS 10 UdAVS ‘JoUTIg pue Adljjor 10} AZUSIJ [[B JO} IdIJ BOQ P]NOM I S}YStU sWIOS “WAay} Jo OM} 94} UddM19qQ SHIB AUBLU OS “AINIUDO OY} JO JUSUID}E}S PoyeBlulsalopun SY} 9q PINOM 71 “YdoM dy} JO ABPAIAD 1OJ [IIS DUO JUNOD 0} 919M J Jp [esodsip 194) 1e Sj4Is JO oouepuNqe ue peYy AdY} MOL} SNOIOTIA B ye pue MOU SdH! Siy Jo {Je Ie AdAJor JO} SpIIS siy SuIpUas “Jaye [je 38 aw Burdyay 1, useM shep asoyj oinjord ayy ul sAemye [aUNIg SulAey "WO, BUIUUT U99q 9A, PyNoys | BuiyjAIsa9 0} Sado Aw pulyq pynom }PY} Sup & SEM Y “OQ 0} JOS}! PO|LOAII DOULISLUNDIID OY) JVYM 19}}8W ou ‘puey 12 uONeNyIs Aue YPM [eOp 0} YsNoud oul xe[d1 puke SUd;qQo1d AU dJeTIQUYyaI “Yoeq Surmoy wos souowsw Au dojs pynom oui SY} Ie IO} | 3eY} UQeY pjo ue ‘xeuRyX ay) UO Ydeq 4038 | ‘S[Jid odeUda) pu UdSLIOM SUNOA SNOLIVA YIM oJNEdde jenxas SUIPURWOP-I9AO STY YIM dn dao 0) “pueyjsi S1y 0} ATUIVU “SUOISUBLU S,AdTJJar JL SUOISINDXS JURJIQIOXS JO XN{JUT JURJSUOD B SLA SYJUOT MdJ 1X9U 3} JO 3SINOD 9Y] JOAQ ‘UIvSe POpssu 9q 0} SuTTeM Jsn{ purysq POMO]JO} | ‘PUIW AW UI SASLLUT PsOYysd dy} JOAO peoy AW SuLyeys “s}usAo § uoOUIaye Apes ay] BurAvyda, ]pUs ‘ow 0} \dodxq “apis jsey Jaddy sy) Jo S}OO.NS OY} SuPONS We ul We poyxleM Ady} ‘Aep dy] 10} 9]dnoo Ayeurp10 ue se jjo Suissed Ajiseq ‘sdoys suryoo; onbynog jusJojjip a]dnoo e ye sojduivs juled awos ye YOO] puk SUTe}IND JNO ydId O} JJO dJoM 9M JOze] ANOY ue INOGY ‘SUONAOUdI SULOSUO S}i JO A}JUR]SUOS ayOds puk yYsSOp yIOM B ui jnd Apeouye ays ‘V1 Jo your AI9A9 SuLysijos ‘UMO JOY AT[eUy ‘oluOY SINjN} JOY Ul J[Is19y Powope sys “uBWOM Auk Jos Arenjoues v “ye JO FIOM B APB SBAA }I POYSIULJ SUIOG #1 NOYIWM USAT “O[Quussud AIOAD JOY] 104 osvIoj}s Jo AjUaTd puv WOOITIeQ SNOLINXN] ‘WIOOI SUISSoIp B YIM sJoTdtuo| “OSNOY B [[VUIS B JO 9ZIS SY} JOSO[D B ‘SIOUOWWLUIOD SN 0} 10 9QOIPIEM Ul YJEM IYNY JOY O} JT SPR NOA 9d9UO FF YOM JNQ 001 FSI kB Jo j1q B sem Sdays AjaydUI JO syYysipy 9014) dn O83 0} SulAey usy) odeys peq ul sem asnoy dJOYM sU J “JOYS ATP4seY d1OM SIIL}S OY} ‘OSN UI JOU SAA 1OJBADTA oY} pue yeo1Y) AW psyxdoyd UMOP WO} SUIDq S[{eM 3Y} WOT SNP oy J "JYsnoy) | poyns [Jom AIA ‘PURLIOPUOAA Ul DDI] YW Woy syevsy JO usonb oy} dy1] “OWaY] ay] SBAK S100 PJOg pue SIOO]J POIOYIOYD "JUSWID}RIS P]Og Be YUM .ANVWISIHD,, JNO WedIS 0} sdR]d 9} payueM oY ‘SABA SB ‘Pet SJOpyIng au) BUIALIP ‘o0R|d dU} JOAO [[e SosURYS popsdsu Jno pajuiod sy “Adrpjor Aq 104 879 $0 TT9abed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 40.43% accurate

Tecroor RELA 86 Burava] AJUO ‘ples p1OM a/SuIs B NOY UleZe JJO SBM OY UsY], poo} Anq wy djay 0} Ajpasoddns ‘syonq Maj B JOJ Joy Boq 0} puke daajs Buoy Be savy ‘2d 0} SuUIYJOWIOS J93 0} Aq poddojys AjUO ay “MOU SY¥aOM JO 9{dNod B I3AO0 SPM SWOY UdAq PRY SY SUH Se] SUT, “MOU WOT SABp 3q P[NOd yey) nq ‘SULOY 103 SY USUM SBESSOU 9} UO ssed P,dYSs SUI P{O} WOP] SI} ‘pasnevo SY S3]qnod] dy) INOge JOSIOJ OF B]Qe sem | ‘OSpPlq oY) JapuN Jo}eM YSnous UILA, “WY 1Oj Jods JaaMs B pey | ssuodxo AU Je puke Sso[syJOUON ‘YUSIY 1X9U SITY WY 499 0} jst pNOM I MSY OY JI SILT[OP SATf JOJ Jt [[9S pUB I9}sBO} OT} [eas pynoM 3H ‘SBULY} SNOTAQO Ssaq ‘[Vd}s P[NOM oY JeYM UT I9AV]O dIOW 9q 0} AN} ysnf pnom oy ‘UIY O} UOSSs] B BUIdQg IVY) JO PdJSU] “SI9Y) SAT] 0} POMOTTP SBM dy BOWAUR WO] WOl] [Vd1S 1,UPIP dy se SUC] SY “Ode OUT) BuO] B DAOJ JI9Y) Wes 0} SurAy) dn aaeZ ay Os ‘uty Jo A]peq os yYyBnoy) syucred sty MOY WIIY Wny Apes 0} pasn y] “O[AISOJT] UT 9OTOYO Sf], Jo daosdde jou pip ays Jey) judredde j1 opeul ays “yt Jo tUNoIA [euOsJoed v Bulag “Sulyesys puv Suijeoys Jo sAeM SIY 0} PUI[G JON “ISAO Sout] AuBlU ddBj STY 0} JBY3 BUIARS UDAD ‘UOS JOY UI MBS | FRY MOUY },UpIp snl oYS “BUNdd]]OO paaoy dys AQqoy d.UeZIq B SALUNOS JOY}O WOT SuRd ,RIOD,, JORG Joy BULIQ 0} pasn UdAd | ‘OU 0} puly SABMTE SEM DUS “PUd JOYIO 94} UO 9d10A AU Jeay 0} posudains ainb papunos pue suoyd ay) polomsue Woy SI} “Ulese CL [{e9 0} payjaduros sem | UMO AU JO JI] FRIOOS B DABY O} SUIT} OTH] YOns yim AjaeuNYOJUN pue sud WOS 0} JULLIOdU 9q 0} SUISUO] SEM | ‘PUSL p]O uv ]jed 0} paploap j diysuoruedwios swios Joy Ajouo’7y usuede Aut 0} JORG alu SAOIP ueNs ‘Yoeag Weg OJUL YOR MOT] OM UOY AM, —— oo, OT 1a}deyD ‘JO J[ASAWI DOULAUOD 0} DALY P]NOM | SO] JU} PUL AW O} PjO} d19M 1eY) Sait ay} Aq painssves Ayuo “ured puke uoydsdap JO SABOM Pajsue) B SEM Yedy AP “SW JOJ ABMe JY] JO []e 3ye) pynom sid ayy [ye ye Wg JaAdU SBM |] PoYsIM pey | Sty] JO} punose SurAejs IO} JJosAU SuILUL] ‘APVUI PRY | SdYLISTU IY) SATTIOJ UdY] Ppnod | ured 94} jO ye ABM YSEM XLULX SY] SUID] ‘Teopso uv YONs Jayye PUIMUN O} SOU} ISO} popsou | ‘daajse [aj Ayjenjusas pue FUIpeoI SUIOS PIP | ‘No JJ9sAW 9.111 0} BUIAT, “JBdY IY] LOI, BuLIO}}OMs []NS seM | do} yuR) & pue sonued Al UI pdq oY} punole SUISUNOT ‘SpIsur yoRq OF O} YSnouUs psdoijjNns SBM ] BJOJOQ JNO UNI 19}VM JOY BY) JO] ] “JoyeM Turysn jo Avids oy} WOT YUM ay] Japun JaZuog] Aejs 0) aud padesnoous A[UO I] “JY stjUOOTU AY] JO UOIDITJO1 9Y) UI SOAIND ,soIpog AW Jo JJo Sulpjey sjajdosp 94) YOT] 9Z991q IOS dU} [9af P[Nos | ‘punose AVM AU 99s 0} SW IOJ JUST] YSnous Poys 0} SIv}s puke UOOW dU) AjUO AYS JYSIU OY} JO YRo[D yep yoy} B Jopuy) ‘pipuajds skemje SEM JOMOYS SpIs]No ue “BUIUDAS dy} 10} SuloJ Jo Aep TVILNACERINGS . [Cae pooajo1g wSuAdoy [1] ofzPooTUdINIo L6 joy B JO ISprut oy} UT dn Buruesyo seM | JOMIOY AA “JOOTJ 9} UO Way) poovyd PUL JOMOYS dPIS]NO dy} 0} JOOP yoRQ dy] pausdo | SaLja{10} puke jaMo} Aw Suiedeig “Jomoys & 10} umop poddinys puv ue ouy 0} YOUMS otf ITY ] ‘Joop ay} pousdo | se Ie warm jo ys e Aq potuodyom sem | eURqed AT Zuinseyd ‘uonorpypye ue [Ws o19M URIggURD oY} JO Soinjelodus) YSIY sty OSk SINOY 19S peY UNS dy} YSNoOUIY ‘JSed] Je MOU JOJ **‘odvad Je pue sUOTe Ayjeuy ‘sprexyno aeyxo daop e& poysis pue yyeoig e MoJp | ‘ulewop Alu polajus | se uoos sy “ANY & Ul JJO 9]))NdS 0} Pld) J sv ea} OM] UMO ALU IoAO Bulddiy AjIedU poAlas sem Jlossap Joye eUegedD AU O} YOR 1YsIeIS BUIPBdP] “OUOZ WOJUIOD UMO ATL OUI YORQ 19d 0} BUO] SUI 94k} 1 UPIP I] ‘Aep uo Ul JEU} JO S[pueY Pjnod | UBY) SIO SEM 9dUO “JJOSAUT PjO}] .poH yueyL,, “WULY YIM SaTNesg jYSI9 OY) Furze) pue SULUIOW dy} Ul ApIeO JJO SEM joumMg Se “JayJO YoRs 0} 9Aqpoos puke jYySiupoos Burces je A[jeuly o19aM 3M STROUI MDY} YSIULF 0} QUOAIOAD JO} SINOY SAI] powses Jey “9TqQISsod Se 919 WOT ABME IP] SB [9d} 0} poyURM | SUBedWeYd sy) UO BuIddis IOYyIeY poo} 10} spy0dde Aw yso] pey | ‘AISuNy UdAad },useM | “WIOpa10q JO jNo YO} AW YIM 3 JO JUOI ul 9JeTd OY} Je Huryoyesog “xvuvyx AUI JO a0uRISISSE 9Y) YIM doays daop & OJUL A[quIJOJ WON AUIS pue ps}eoI9 pUR]SI dU} SOSIOU d]]Uad ay) 0} Aeme Surddyys “poq 9/qQeIJOJWOd JuRIs AUI Ul UMOP APT OB PfNOd | [HUN SoyNuTUT oy] UMOP SUTJUNOD seM | ‘poposu UdYM UOTddIIp $_.d|doad ur Surjrwus pue Apjoinb Suyyig “ol sem doy) Udy) pue a]qQei dy} pUNoOIe jonbovs s11jUd OY) JB PasNwe BUIOq d19M 9/Qe} dy) JO pud Joyo dy} UO AWW pur su]sIyD “Joyo yore yy syunWwdryo apy Asng oyx1] poyeyo spIIs oy) pue “Sulureaq $099 IO} YIM SdAjasWIdy} apisoq dom [ouNIg pur Adlpjo¢ SB PIVMAMP IIOUI 3q },UP[NOd J] "J9YI9BO} JOUUIP JV9 O} UO POAOUI [JB 3M puk UO JUOM OJT] JY) SVM JEYL “JOAO |]! SEA JL [UN puTU AI Ul dS]9 BIayYMaWOS }U9M pure saka Aut pasold jsnf | [auntg 0} pnoy ino Surysney] Aoijjor Woy awed }1 ons Ayoid pue asjNaip udw dy} JO UO 1edY P[Nod | ,.pasnuie Wd) doay 0} SABY 0} Pd9U B IOADU S919} OS YSI[suUq Yeods udAd J ,UOP Ad} SI zed Jsoq OU ,, 194930} SOATOSWDY) DULyONs “sostusd Noy} punoie spuey ITO} YIM IYO v Ul Su US ‘sn Surpoyem pounrg pue Adlfjar sas ppnos ] OUI IOAO SUISSOIO SOIPOG UsEMJoq UI SOSdUTITS OY) YSNOIYL, ‘STY} I9AO0 SZISLIUL} P[NOd Ua MOY MOUY ApSouoy },UOP | ‘SOBYS J99YS SVM J] “SPITS AURUT OS YIM d1OJaq SIY} AI] TuIpJAuR ouOp SULARY JOADU “SNOLII[IP SEM ] ‘siosury pure sdry ‘sonsuo} ‘spuey 3y) YM Apog AW o3eAes 01 uesoq pue dul possoupun Ady) SusyyAue FurAes ynoyyiAy “Op 0} YM Apoexd MOUY Apeol[e Sj113 ay} se “ody SPJOM JOJ poou OU SEM dJOYy YY “BURgeO S, AdIffor ‘pue]s! dy} JO Wed JoyjOUR O}UI POIOYSN UWS SIOM 9M YORAQ dj} UO YOUN] Joye pauinsse Ajsnosaid pey | sev puke pojyurenboe jod 01 saq Aw pip | : Godby OM pip 879 $0 cT9abed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TWILNACLINOD [CLIOITY pore, | YBUAdeD [J

The text on this page is estimated to be only 42.59% accurate

teZrOORELINID TVILNAGIINOD TETPOOAUAANIO TVLLNACIANOO [Bua pojsoielg 1YBAdo?) 4 [PLATA poysaqjoay HT VIAdOD [] OOT ‘Aep S11Ud ATU SULLUNSUOD ‘UOTJOI]JUI SSaTpUS UB dIOM S}YSNOY) sy] Ladessoul Aut uo ssed UdAd STYONTY Pig {e[qnoy Aue ul ay Ss] {as[o FUOSUIOS 0] UO Paaowl ay seY {dnyeosq Jse] INO WO) PRU [[Ns SI ay ssnedaq SUTT[ED JOU SY S] {YO oY ST” ULI) Wedjs & Oy] peoy AU YSNoIY) poys S]YSNoOy) UOTIIU Y “poyyeo},upey oy AYM pure fy sem Aep yey 1ysnoy} ysuly Aw ‘Apres siyy dn Bujod 0} pasn jou jod 9dJjJOd 9y} 0} SULIOSBRIS "$]SO9 [[B 18 IST] MOpUImM Aue BUIPIOAR ‘SsouxIep JO o1njeaso eB we | daajs ] USYAA “WOOI BUIAT Atu O}UI SuTMedq UNS a4) Jo SABI Aq SUTUIOW }xOU 94) dn udyom seM | ‘paq 0} JUaM | WOJaq ysew oA9 Aut uo jnd 0} Buljjes104 “gL, Buteg y1 pue smou oy) UO JOpINU Jayjoue Jo Ivay 0} Surjdadxa jyey “AL Suryoyem vjos AW UO Jno BUIYseIO dn papus | “19419 Ased }.usem daojse SUL[e4 “SSOIISIP YIM USYOLys 1, USBM | JVY) JJOSAtu 0} AUdpP 1, UpyNod | ‘[7eo suoyd ou [NS YM Aq possed pue duuvod YOo]O,0 daly UdYM pue sed 491) YOO] dy) UO SO]NUIW 9q} BUIYIIEM YOON, O IAL [NUN poem | “YOM JO SUT] STY Ul SIOUULU JO} WOO] Ou Si aay) se ‘auoyd ay} dn Suny sy .,2aAq-poos pue syueYy],, SutAes oul JO J[pprw sy} uy .. Poyyvo NOA way []9) {{,] ‘YOO[D,O0 SALJ punose sJay yorq aq PyNoys sy ‘dULY S.d}{ {SUIYJOWIOS JO WO] SIY NOA ov JVYM,, “SUIIOUOD AW JW PAdyIuS SYOWY ,.gIYSsU]e oy St “Wy jnoge powwoM Ajjpeos we pue jJJMS OUIOS pIvdy 9A, ] ‘f' L Puy pynoo | aoYyM OW [[9} ppnos nod suidoy SEM ],, 9U0] AIP & YIM Palamsue oF] ..gJUBM NOA jf ST Jey ‘ore NOA oyM MOUY | ‘YRdd YO,, “Jaquunu siy Sulaey o[dood ynoge sem oy prouesed MOY SUIMOUY SBM J OYA JO WIY pulWal 0} BUTAN sem] ,Sotued Moy B Je SUIT) JO a[dnood vB JOW aM ‘xO S fT “eUUdS SI ‘YORY -YQ- 1H,, “su JSAlj OY} Jaye auoyd oy} pousmsue Apun[q WoYM s1yd}ry SEM I] ..ZYeOA,, “Ajoyerpowmunt soejd s_s1yoiry [jo 0) suoyd oy} dn Suny pue sw jo juod ul Joded Jo a001d yuryq e uo Jaqiunu auoyd oy} UMop palqquos | Apyornb snoreyy YIM UOT}eSIOAUOD dU} pus 0} Sunue~y “yop Siy O} A[oJeUyN SuIpes] £00} pip wepy Ajjuanbasuod ssp uo payooy 103 f°, UoyM OS luepYy pynom os usy} Jamo], [apt ou) Jo poduinf cy jt ‘mopeys sty Suryorwmtut ‘days}ooy AIsAa Sf] Ul pomoyjo} wepy 1941950} spud oseYys prnom Ady} Udy} USAd puke ITY Ayioqnd [Nun spquiedosul 319M OM) 3Y} ‘POOYPTIYS souls f°], YIM Spuatij }Sagq ‘yOo]q SuoiM dy] UO BUIAI] Wg 3q 0} pousddey isnf oym pry jooms kb SEM UIepYy , peep S.sy MOU pure sUCTe Wepy JUSS SIYdITY OS “AIOAT[OP 9U} LO} S d1yoqry ye dn Wing O} JOQUIDWAI UdAD 1 ,UPIp ay dn payony Os sem f°], Aog nod ‘dn mous },upip szarddns jensn Jay} uoyM snoroidsns jog oym sAn3 yoRtq OM} Aq PLdY 9Y) UL JOYS 109 9}, “S]USWIA}e]S SITY JNOQe SAT}ISUAS UBY} SS] SEM SNOILIA ,. TUIYJOWWOS JO YOO! B JOpuN ‘[113 udaq NOA savy aioym ‘Mauy Nod yYSnoy} | ‘sdeus yO,, ..gpousddey jeym ‘peop si wepy yeu) Avs ysnf no< piq,, Jadsiym v& no 19}jnNUI ATUO PyNod | suONesay[e sty Aq 66 UMOIY} Aj[e}0O} SPM | . WWepy JOU ‘MOU SNSIOU! 94} UL SUTAT S.Jeq) WATY Us9q DA P[NOYS II pue {NJ SIy S.j1 JY} OW WO wiY [[9} Wed NOA “UY JO} oIOy} aq 0} dn Surmoys J0U JO] st ay Yo}IQ BULONy B VYM MOUY WY 49] UD NOA St Jrosned ZMYsT[NG wWepy oy) ynoge SIy} S],, “SUItJaWOs JO} WIY yse 0} Savy UOTE 19] ANB SIU} [[eo O} SUIARY poy |, WY Noge pow0M Ayyeos w.] ‘f° L, JO ppoye 393 | yey) yUeWoduTT AI9A $.q1 “oseayd Joquinu 94} 103 isnf ] uvd ‘snoIePl SYULY]L ON,, “WY Ul Pd}sosajUl oq JOAdU P{NOM pue JoAdU pjNod | Jey} Sures jou ysnf 10 Jury oY} BuIyEs J9AdU ‘JUdtUspNl JO asuas Jassa] AW! 0} [vadde 0] Ay) 0} anuUOd Ajssojall) pjnom oym seq SZEIIS B SEA SOIR] ,.JURM NOA JOAd}VYM NOA Jad ued | pue sov[d Aut 0} IOAO DWIOZ {JOJ SIYOITY [Jed 0} JURM NOA Op JeYM,, “OW poyse oy snoiVjAl Spud] Sf] JO OU WO JOQUNU S_d1Y4d}1Y TUIUIeIGQO “UONduNnsse ayes B SUM SABA JOYJO UI SIYOITY O} Palqopul GUIdq UNTY JO POOYT[SA!] 9Y) OS yiqey Bmp siy JO JjaswTy poddns 0] ssouRULy SY) SABY J ,UPIP |, Mauy | ‘PIIYO JOOMS SAIPOQSWIOS SOUO SEM SABT[AQ O} SBM JI SB PIBY SB OYM ‘sIaseuse) soy} SuIsn Aq ADUOW SIy Spe dy “WIY aAO” SIDYIO aq} JO spueld 94) puke Spuels AjIp siy UNI 0} SJooNSs YORog Weg [¥90] 94} JJO Spry BuIs() “souRjUTeNboe snosesuep & WY ope saoeyd |e Ul SIVS BUIARFY “SOALUY PUR SUN 0} SSNIp JSOW WOIJ SUIJAIOAS POLL Of] “SULALIY) SEA SSOUISNQ SITY Pue URLUSSSUISNQ & SEM SF 'S}991]S 94) OJUO JNO Way) SULIN} Udy) pue SSMp Siy UO PdYOOY WY} J93 0} A[UO SJUDI]O JUSUTUTWI 0} ANZ a01U & Syl] pojoe pur []aM possoip 9H ‘suoTIsodold Suridse YM pers adatjoo Addaid asexoae INOA SAI] POYXOO] 9Y pesjsuy “Jo[vop Jo aryunt no Bunyjs [eoidA} & 9x1] YOO] 1, UPIP 9H “WY [[ed 0} pasn suOoAI9Ao se ‘YOry-d1yoyry “eare INO UI SIO[VIp 9YOD 1S9331q SY} JO UO YIM SEM 9H ‘JYUBLI SVM BUOAIOAS }LY) INO pousNy }I pue YIM }.usem oy podoy pey | Uosiod jse] oy) Sem payyeo | uOSIad yse| SY “SN punose 3q 0} JUeM Ady) pip Udy} AUO “Wed oy) sypuey pynod pue ‘yaued ay) payor ‘wed 94) poyooy [je aM Sv Guo] SY “UOTJETOOSSe Aq Spud] AJUO 919M DUT) OY} JB SpUudldy AW Paispisuod | Jey) 9jdoed jsouw “jods 94} UO je poysne] yonw Ayoid sem | “MOU 13A9 UBY} SIOUI YOR sity Savy 0) s[doad spoat puke satuawwos op [Je 9M ayI] ‘aseyd peq e YSnosy) Sulos Ajqeqoid jsnfs,ay ‘ouly oq pynom f° Jey) WWIY puly 0} SUTAT) o[IYM 00} ayods pry | QUOAIDAD PjO} | ‘WTY BuIpUdjop [NS 1YysU 1, us1am Ay) podoy A]19.199S duI Jo wed e puke sem PUT] Jsoq AWW payoojye A[peq Moy Je3Y 0} pley SEM J] ,“AOYMOWOS JJO S903 puL }I Soso] Jsnf oy UTTY IO] SuryyAue J03 },UOp 9M J] ‘S}O3 OY YSIY JXOU OY) SI JNOGe soIvd oY [[e pue ‘o1OTUAUP And dwes dU} JOU S.9H,, ‘SulOp sem oY Peg MOY JO SUI PjO} Spud] }S9q SIY JO 9UGQ “AaSNoY S_s1YdIrY ‘ojqissod soe]d IsIOM SY} Puke UOTO9.IIP Wes 94} UT SIOBUTZ dy} pojutod oO} ayods | SUOAIOA “WY Wo plesy pey ouodue JI 99S 0} spudtyy [enyntu Jo ajdnoo & punole pal[ed ust) | ‘sAVMmAUP yoooo yonu Ayjaid sam YoIyM ‘suoldunsse UMO IIdy} 07 s}usred sly 879 $0 ET9AaHed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUBWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 42.51% accurate

secroo RELIAD TVILLNACIINOD JeNore PY PAsajory WYsuAdog cOT AUB dIODS 0} JOU WY] poyse puke MOUY | JY) SPUSTJ STY JO mo] & payyfeo ] dn ey, ueajo pue Aqj 0] SW] opYT @ OW OARS YOTYM “AI[BAOI SUIUTeLIOIUS SYI9M 9[dN0d }xdU dy] JOJ YORog Wyeg UI sem Adore AT[NFYUeY] ‘Quoye WId90U0N AT sem WIG SuTdjay Jo AytyjIqisuodsal QU} SAY WF 1 PIip JO poaly f Jl paseo Ayjeoi oym uosisd ATUO sy) Bulag ‘g001d SUO UT SIIVISUMOP SUTATIIe UMO S.}T UO Yd e sem yy ‘SORTd AW 0} yorq WIY SAOIP pue yxONI] AU OJUI SITS JO SIYRI[J so7y) UMOP pue J9A0 saw Auew dn wy pedysy | ‘Wysiom sry Jo Ayofew sy) sUTALIVS pue yoou AW punole wie siy Suing “Ulese JOOLJ 9Y} 0} UMOP BUTT[RJ d10J9q punose Suljquinjs pue yonos sy} tol dn GuNjsd sem dPf “OW YIM SWI0d 0} UNTY SuIsoNbss sp1oMm AU UO SNdOJ 0} B]Qe SBM SY MOU JSBI] IV ‘pasnjuod sul jv Pdyoo] pue dn yes oH “‘poyuem pey [ UOIORAI 9Y} JOS | Ng Junjs joins WU | Pue PJVY SdvJ SIy poyYoRUls | uIEse SUL OBJ O} IDAO YoRG wiy Suyjoy ‘peoisdyd 393 0} pey | Mauy | asuodsal OU YIM PUR I9AO SOUT} Moy B JpOSAW SuNeadal ‘YyOnod ay} JJO Jad 0} WITY Je porsysn | .j MON ‘pL dq 195,, 11q @ 1 Jo Ino deus pue snolas sem | MOUY p,oy OS dd10A AW pasiel puke MOU WIY JOAO poo}s | “yeuTUe AJjNTJ e sIIM I JL SB yoOnos ay) Suyjed “19A0 Bulpjoi pue Burjssisd Aq Ajdai ATUO plnos ay asnevdaq BulARS USAD SEM | JLYM PUR}SIOpUN UdAD PjNOd dy Yuly} },UOp 1 .gdn passat os Suiop nod aie yeyM “poos Os Yoo] 1,uop nox “Aepo} dn nod yoid 0} SuIwiod sem | J9QquIsUISI ‘euUar sit Appnq Ady ‘f° ],, ‘peop ‘ulepy oyI] dn papus sy pue as1oM USA9d 103 SAUTY) dIOJOq wry djay 0} poyuem pue Ajid yoo) J surjooy Ayesyun pue AuULys Os WIY SUI9DS JSASN “UNY JO IYBIS AISA 9Y) Je JOO[J Sy) 0) poddosp savy ysnuU Mel AJ “YOOYS 19})N UI SBM |] PUR SYJUOW UI WILY 1e YOO] ySIy AP] “Ul SEM al aJeJS [NJpeoIp dy} WOIZ SPM | OYM MOUY UdAd } Upp ATqeqold ay “990Ry siy ssoloe peoids a]tuls JURID B YIM SW pospaymouyoe oy ,,019)"*'ASH,, ‘yonoo Ay & UO INO Bunds sjoH-y & Ul fT pUNOJ puke WOO SUIAT] JY} 0} YOR dy} 0} pay]em | “asnoy AqIp ay) Ysnosy) sdajs Aw Suriputyy “OIOYMAIIAD PuNOIv BuIA] SIOUIVIUOS SUIdIpstu pue sdoq JaJUNOD 3y) uO SasuTAS YIM Quy [eWdsoy e Al] PSyOo] I UdYdINTY 9y} YSnoIy) Suissed ‘f L JO} Buryoo] ySnosy} smnjusa 0} JyasAw Aq sw Suraesy ‘ABMB PdyleM Pure JOOP 94} pousdo sys “sw SuIsadxs sem f°] I9Y Pfor pue ssouayrjod Aw paurejurew | ..{jueM nod op yey MA,, elu Je paqqnus pue 1dUI9}U09 YIM UMOP 3UI PayxOO] ayg “Ul SEM YS 9}e]S d]QIUA) JO sinjord [[QF 94) sJO;dtuO9 0} YJNOW Joy JO JNO Suny ajosesI9 & puke seoie syeaud J9Y JOAOD O} UO JITYS POS & puke eJq Joy ATUO pey sYS “Stup pley swOs UO 20vJ J9Y JJO poxOO] ays pue ssoul e puke jo Sums sem ley youTq of 19y ‘saA0 JOY WOIJ UMOP SUIPSaTq JouT[aA9 YIM JOOP 9y) polomsue [Id SuNOA 8 B10Jaq SOUII] M9J B JOOP dy) UO A[PNO] You 0} pey J “Iej SI} J! apeUl UDAD | JeY) J[aSAU YM poysiuojse ojInb ‘suo $ sIYOTY PuNoJ | Ise IV “OU DAOQE S}YBI] JUSOSSIONTJ Sy) JO SUIIDHOIJ oIpesods sy} wo |NOYJIP SEM JoquNu JUN 31) PUL 0} BuIA] pue s[TeM Uy) 94) YsNosy) PetroonyAAAIO TOT BUILULVSIOS SdIQuq IBY P[NOd | ‘s[lysou AW pa] “uo eurseu Aw JO JSJOM SY} 0} ATUO “BUINIOI SuIWJOWOS Jo yoUa\s JUSduNd oy} pue STEM st} uo ured u9d019 Jo Sulpsod SY) POJOAOD I}YJLIH “YOIpf JOLOY & JO JNO suaos B DYT] POYOO] aseoIIe}s OY} JO SIOpII0S 9y} dn SuryfeAA “pr0OM e BurAes yOU UMOP peoy Au ynd |] pue ysny usm sysoyo Aut A[SnosueNwIs ssp PpoldjjO pue uo iy SUING “BulajUd seM | SYIOTQ BU} spisjno poo}s a[doad JO pMOIO Y “SHUN JO FOOT S,d1YdIFY JO JUOIZ UT 19}jNd oy} UO poyJed pue X9[duI0D dy} 0} doURTWUS dy} Je Soyes UddoO dy} YSNOIY) JYSIeNS SAOIP | “OJUI SN payjnd ADU} UOTOAIIP JUSIOJJIP OY} pue sIeay euossod uMO JNO Aq pajesedas A[UO ‘skem AURUI OS UI IRTIWIS aJoMm om ‘o[doad asoy) Jo suo dSuowe Sulog ‘O} poquinoons sey UOTJEZIIAIO INO JeYM UY) OIOW SuIyJAUR dAdIYOR 0] a]qe Bulag JOAu JO ssoussajadoy 94) Sundsdooe jsnf ‘WI ynoge SuiyjAue Op 0} 3uUeM ApOqou pUe YOO] NOA sJoYMAIOAS JANY YONUW OS YIM Ut SAT] OM P]JOM pes Y “prnod |] se AOrnb sv diay} JO Jno 39S 0} SUNULM $}99,}8 ay} YSnoly) Suipsads sem | ‘QUOOWOS PNY O} JNO puK AIdue snl 4O ‘s1e9 ‘AQUOUW SUIPUBLIOp UOdeaM kB YIM SOOTYSA & 0} dn Surysns speooj ay) jo spodas Aue ‘udas dq 0} s]UBM YONI] SO1U B UL [113 dIYM BUC] B soR;d B JOU S ji “Bare oY) JO A1OJSiy BY} [Jam OO} [je Surmouy *x9]dwoo juawyede S SIYOY PULZ 0} ButAN] sjoods YSNoI ay} YSNoIY} saoip A[SNOAJIU J Yon AW 0} SJOOP dy} SULyAOO] pue smopuim Aw dn Suljyjoy ‘vole umojUMOP sayoeag Wye ou} JO syed Sulzzep Os JOU dy} JO SsauT[IN 9y} ojUT ABM AU apeUl pue UUITY JJO SSoIpPpe dy) 103 | ‘saynqupe poyejdwou0s-}]1 sty Jo SST} B OYLU }.UPIP | [JOM O} [[e Wiy Sulmouy ‘axl] PuNOs O} JNO Ft SUTyeW SBM JY JYM ST YOIYM JJaSAtu O} JOAR] & UY) JsONbal B JO dJOW SeM | | . dn dtu yord au0d 0} JuBM NOA ssazuN aoR]d S$ .a1ydjry ye UMOJUMOP UL] “Jayey pWUN dy} 108 0} 9]Qv 9q 1,U0M | IN| ,, “Ajo dy) uo dn aw Burye} ul ajelisoy 1, UPIp 94] ,.) 1H OY! [90J NOA JOAOUDYM JOAO OUIOD OJ UBM NOA Ji MOU sWIOY W,],, SWd[qold siy 10} Jappnoys AW pus] O} Sul|IM UB] SIOUI SBM | 18) MOUWY 0} WIY poyueM | SNOTAGO Sem J] ,.4dUTIJOWIOS JO dn jaour URD OM OS UMO} UI NOA dIY ‘suo oy} JOAO I NOGe Ape} 0} ULM J UOP | ,, porjdor dy “INO pUlf 0} SUIOS seM | JNQ ospo;Mouy At puCAdG 919M SUOSOL yey JO} “porvos popunos f°], {uO BuTOS si yey “NOA JnNoqe PolOM 03 | pue wepy 0} pousddey Sulyj}stwos Jey) snoIePAy WOIJ psesy J,, If JOAO SSOU 8 9q P.dY SUIAUTY) ‘Wepy o} pousddey ieyM Suryse jnoge ajeorjap 9q 0] savy pjnom J Mouy] ,.gdn s.jeyM “Suryjowos 10 Josdn oJoM NOA BUIARS }I JO} YS OW 9Avd pue AepIa}saA SUI JOJ GUIYOO] osnoy siy poy[es NOA OUI PfO} SIYOITY “OUTy LW] “YeOA,, *,O][OH,, surAes sed jos wry Sumo] ynoyUM ut podunly] ..{yysuye nod ose “Nod ynoge poi0M Os Useq dARY | ‘payjeo NOA poy yueyL,, PUd J9qJO SY) UO SdIOA SIy pIesy J] USYM SLU J9AO 1daMS Joli ‘UOOUISe SY} Ul Jaye] aUOYd [Joo Aw payjeo ay Ayyeuly [Uy] 879 $0 pT9abed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVILNACLINGOD [eLIage Ay poyoojou,] WYBLAdaY [1

The text on this page is estimated to be only 40.40% accurate

Le 7POORLLAAT vot O}] [NJoureys 00} 19M Ady) peasy AW UY “9]}}2q 0} DUOTL SUT d1OM ADU, “SOIPIIQVIIU[NA AUL 39S O} YHNOUS SSO[d SPISUT SUOAUR Jo] JOADU | ‘Pel] A]ISvd | , OUI] []B SBM J],, “SBM SUIUSAS AU MOY PdySe puke JOOP oy} Je OW pojoois OF ‘JYSTU Jey) poos punose swod pey oy osudins Aut 0} ynq “f |, ID}JB YOO] O} Bavy 0} Suroodxs sem | Jusupede Aw 0} you 103 | USy A | “sjuased AUI ‘OW JOJ [BWLIOU Se dJT{ STU] poydoooe pue sovid ysij OY) UT JJOSAW JOF PUD} 0} SUL pouopURge OYM a[dood AJOA OY} Je Powe sem ases AJA “YOeUo}s Aww ul pid daap e O}UI Jolsoj Jasue aul jay AjUO pue yorq sievoq AW yOR pyeay | Out) SIU, “S9eTd ysIYy 34} Ul at paxly Aoayor AyM Jo yoOnur Aqeqoid ‘ye poos ueY Jayjoq sem | SINQUYe UB SUILIDG dS]9d SUODULIOS Oq 0} BUIPUd}olg “JOYIOSOIe J[SSAW 10] BUIYJOWIOS Gulag jNOge SuIJasIOJ “OUOAIOAD 0} SUTYJAIOASD SUIOG PUNOIL PSAJOADI BOUdISIXS BJOYM Aw “SuryjAIIAI JO post} OS Sem J “SuLAP pue SULAL] UIDMJ9Q JOUdIOJJIP 34} UOYSanb 0} Suruuiseq A]Jeal seM | pue dl wioly Aeme Burddiys sem apt AJAY S90} AU JB POydT] J9}eM 3Y) Baym pues dy} JO 9Bpd ay} 0] UMOP PayTEM | “SOJ 9y) OUI JOOP 943 JO no Surddays Ayjenpeis JyO says AW YOO} | yoveq Aquesu ¥v JO UOJ] UT Yona) AW SUTyIeEg ‘SUOT}OUTD AUL Jd}{IJ 0} AtUT] SWOS popsau | “I9YIIa JUOUTIEde AU 0} yorg 3ulj393 00} pleMIO] YOO] 0} YONUW JON “OJ pey |{ uUeY) Jasuo] JUSMIOW B 9194} dq 0] ]UBM } ,UpPIP | “ssoujdwoid YM ABMOALIP S,AdIJor JO JNO PasIoAdl pue duisua ay} dn payejs | UONLUSI oY} OUT SADY OY) BuiyNg ‘asuodxo [vioul UMO INO JB SOUITJOUIOS UdAD ATA}BUNLTOJUN s{]Iq Aed pue eo 0} popsou I] SAq “[[9M poojsiopun | “Avs 0} pomoyye sem oY JeYM UL) SIOW 9U PO} pue d[}U93 o19M Sad SIH “BLIRA] “OJIM SIY pue URN; 0} o}]Od SAeMIe SBM | SB ‘JYSIUPOOS pres pue WIY poyueY) | ISAO WY] popuey pue su JO} OM] INO YOO) dH ‘S][Iq Je]]Op pospuny dswd jo sojpung sjqeyuNOULNsUI play sAemye yey) Seq [ajynp siy sem YJeoWepuN pue ysap s,AdJAJor 0} JUIM 9} ‘SULOY WAY) SALIP USAD SOUIISUIOS PUL SUOISSAS 9} JOY _S[4i3 ayy, dn xy 0} savy udqjO pynom uenr ysonbai jensnun ue },USeM J] ‘jYSiu sy} JO} daojs 0} su0d pey Adsjor yyy WITY BUI[[a} SuIUdAs OY} JOJ OU Aed 0} udyo}ty SU] UT IHS sem OM ‘URL PoySe pue SITRJSUMOP JUdM | ‘s194jO pasneos ay ured jeym Suimouy yysIu Je Ased daoqjs pynos dse19 snojsuow eb AjUGQ “daajs s.14sIU pood & JOJ WOOIPs STY 0} Pditjo1 oy D0Joq PO]OYSeM ULIVM JOM kB YIM S[e}IUas SITY JO JJO Uswes poids sty dn UBd]O OJ dU pouINbal apy “dq A[[edJ ppnod ay Suneruuimnyes moy jo Avjdsip SNOJOSIA & SEM J] JEU} SAT] Oposids uv 19yye Avs 0} JeYM Jo oINs OU ‘yonb paces | SUIUDAD dy} JO JOPUIVWAI 94) JOY “SARIS xos [eUOSIOd UMO SIY SEM | PIVOG SISYD9Y9 B UO 9990Id UME & S¥I] “SW PoyUeM oY DIB9YM ysnf{ ow pey oy “sSulpaay AWW papseSoisip Aosyjor AVM 3} UT Ploy },up;Nos ] UOpyas ATUO SBA\ }} “JUSUTJV9I] JO PUTY SIY] 9x) PNod | SAep Iso] ‘poxeUulljo ay [Wun sonnp Alu Jo [[@ YsNosYy} Sulysas “jt JO ajnurw AISAd payey | IY) TWLENAQEHINOOD jCuaqepy power. wydwAday ¢| 9ETPOOTTAAND €OT. soko AUI Ul YOO] ay} toy UONBAIaSgoO Aseo ue sem }1 ‘Avydaso} aq) Sup wiry ye dn 8uryoo'T 00} }1 SulmMOoUy WoO psoueyUs AdJoUs S1y Inq “yYd1UO} SpueuWlep s1oul Aue JINpus O} JURM 4} UPIP | Jey) MOUY oY Pip AjUO ION ‘Thos uMOp WOM AU WOI SBulSuoy [enxos sty posmboe pue wy 0} Surais SEM | JEU) SBVSSLU POYStUIZUN dy} WoIf JOAO SuluINy Aq odvun ArejUustUOWW Joug SIY PaUINI SY PUODIS B JOJ PUSLT [eNJOR Ue 9x1] BULLUSES SOUT Y | "'YSNOY} JJOSAW JOJ JNO PUL} 0} pey | ONT} Inq SUTTIYS o19M SPIOM STF], Ulese NOA pny [IM ay ‘}1 JO} POM AW BAK} Ng “svoy ye Aj[BAO] ANOA oITLUpe | ,, J9yLNF YON 00} UOURSISAUOD STU} d4R} 0} SuUNUEM JOU ‘YIBWOI STY Je YOR poysne] [ .JO} ole Spustly poos yeyM S.jeUL,, “JS1OM STY ye UMOP Jsnl oUTUT JO pus poos & pue Bulag ueWINY & [[1}S Sem dy ‘ATUSIOJJIP IoF Wesy Au NG ‘cj osueyo 0} 3uNduiaye UsAd JOJ pidnys sem | SUIMOTY 00} WIY Paadsljeq [ SULA UDAD Ul aSN OU SaduRYd JOADU ADY] OU JST] puke WIY syx1] 9[doad MOUY | ‘We ] UY} PUdTIJ 19}}0q YONW e 91,NOX,, ‘pordos puke poysiuojse poyxooy oH , djoy Au spoou pue Mou jYyS14 9J1] sty ul soRjd peq [eal B ULS.oy ‘YeaA,, “]]aM OS ou MOUY oy Jey AUUNY OSs SBM I] ,.NOA J UdIe [| YIM xorg no X,, “AeMe YW SIeNS soe] AU SsoIde peaids d10M | BUTWATIp ay) }NO poyoid ay SAeP JO 9SINOd }X9U 3} JOAO AdIJJaf 99S 0} JUSM | USY AA LI tajydeyy ‘DAIS 1 UPjNOd | Suryjowos JO poou Ul Yonw 00} ‘pudtyAog B sem oY URY) MOU IYSL Aqeq B dyI] DIOU SEM SH ‘SUIYJOULOS 94¥ ay SINS OyRUL Pue Aep B 9dU0 JOMOYS & dALY 0} paq JO INO WHY 9dJ0j 0} SARY P[NOM | “WIsYy) JO sJOW Jos 0} dn BuLyEM Ajuo ‘daajs 0} yorq o8 pynom dy pue syjid sso} JO Maj v “xeuRK ATI SEM my diay pynom yey) Suryy A[UO sy], [TBAB OU YIM Jnq SARP MOJ }XOU dt} I9AO BulOR] SUM OY S[PMPIPYIIM 9} Spisqns 0} Burdoy syOuUs 0} UNY 10} BuRNIeW SUTOS 1YHNOG J °S}9dI}S OY) JSUIeSe oINeq SITY SUNYS ssojdjay OS }[2J | ING sure;qoid pue uted sry Jo [fe Apowiss 0} pajyuem jsnl ] “‘UOHOIppe STY pooy UnY dyoy 0} }0U astuoid pue Ajoyt[od aoevy AW O} SI] IS¥d] IV 0} YSNOUS 9dIU BBM sioyjo pue cy YM ow Au SUSeM Sem | SU SUTT[SI Olu Ie paysne] Wisy) JO aWOS ‘sn Jo AueUT OS Padid0d SBnIp ay} 910J9q PdISIxd BOUO JEU) Ie sn uddMjoq diyspusiy dy) JO WdY) SUIPUIUWII “YJeop JO YUlIG 3y} UO Sem SY W9y) Jo [Je Surya) pue Woy) yim Suipesyd ‘osoul Aue uy Joj sénup 8179 $0 GT9AHed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVILNICEINOO [EHOCIAL Polso1O4 fp WYTWAdO? | |

The text on this page is estimated to be only 42.21% accurate

6LCFOORLTANIO TVILNACMIINGS SETPOOMUATMOD TVLINTCiINOOD JEaIeP] powojorg pyIuAdoD G JEUAIEY paqsojoay wsuAdoy Gg 901 nod noge MOY AdJas,, PoywIS DURTSTYH .,dUO B d4P} [],] ‘SOA,, “sould AUL JO papuilwal udeq pey | “UaY) YIM poliod yse[ ay] Joye puv Aynp jo - 1RO ay) puodaq yuaM | ‘ssand | punoe ou dooy 0} uoseas Joyjoue ‘Led Aw Burdvjid SABMIY ,.{SUIIOWIOS JO vd} B OqARW ‘SuryyAue sAnv noA jas J ues ‘sXemAue Suiystuy isnf sem T,, YOO] JSOq dy} JJO SAIS } UPIP OUT] ous SY} BW UONLSISAUOD B SUTUIL]UIeIU pue Poo} SuLMoyd ‘a]doad Jo JuoIT Ul sTIOTe Suljea payey | ,“NOA Jdtu19JUI Sn 13] 1, UOp ‘jest INOA Ysiul puke UMOP 1g ‘poo3 ‘poon,, yIOq WWay] 1OJ PasaMsuP sURISIYH pue Way} poyoos | ..{NO0A ae MOL ‘sknF 1H ,, “S¥2049 dy] UO YI10q WAY) possty pue yeos Aw WO dn 103 ] ‘UMOP poo] Jo 911g Alu UMOP BUIYxOYD “sueysiyH pue Aoijor sem Sultuooul pue uado Sunms sioop udyoy1y ay) eau Aur ysnosy) ABM JTBH ‘uoIsvooo Aue je ASvoun SuOAUR BULYRLU JOAOU “LUST]eUOISsazold [enseds B YONS YIM II OP P[NOM puke S[LILU INO SN SAIIS O] BABY P[NOM 3H “Yoraq Jo jood ay) punose payeu ye}s UdAd SOWIJIWIOS ‘ssajdo} punose Sulouesd 3q PINOM S]113 Sn suOIsedd0 AUBUI UO UdYM 9dIJOU YOO} USAD IOAOU pure tury inoge jeadde jsauoy ue pey sp ‘payey ] Mouy oY YOIYM “Ppoojseas SULYOOS SEM Jy JAADUNYM JO “JsanbaJ uodn ezzid 4s3q 3y} SW oyeUu 0} pasn df] ‘Njo) pue synoidsuedg yim pal[tf 1,USeM Jt USYM “BUTIOOS SI P3AO] | (peyxood pey ‘Joyo s,Aaijor ‘WePY Jey] SIZAOJa] BWUOS Puno} pue ospiiy oy} pouado | “sem UdYyoITy ou} 994M 0] UMOP YOR Poy[eM j Auduny 1g & Dulas “asdy} 1, USEM OY PUB dYJO S_AdIJJor O} BSVOIIL]S oy) dn payee | ‘Aldtua poyxoo] sovid oy} 4.7L UO UoIsURUT S,AdIJJaf O} 105 OM USL AA ‘[[99 UOStId }xOU AW JO} JJO popeoy 9M PUL dU JOJ JOOP Yorq dy pouado ayy “JUdWIOL dy} 10J SsoUjoIND oy} Paajoid | se oul JO} JO}}0q sem }[ ‘sAemAue ysi]sug JO poos yey) yeads Ay[eos pjnoo oy YULYy) },U0p ] UOTBSIDAUOD SUJedOId1901 Aue 0} SUIPPOU “]]e Je YONW ples JOASU 9H ‘OUI JO} adeSsny] Aww dn payoid pue [eUIWd} [BALI dy} Je OW JOU OF-OF ‘BULJOOJ SEM | Aj{ledy ay} JO Suds Aue apry oj dn -ayew Aw dn payono) | auejd ay} Jjo Surjjos sJ0jag “YM ponsejd sem | Aja1xue dy] 0} UOTORAI [RoIsAUd ke ‘UIeSe WINYS O} URdOq YORIUO\s AW UT jId — daop yeyu_y “‘ulese yno Ja5 JaAad plnoM | MOY MOUY J, UPIP | “DANSO[OUD ILOY} O]UT StU pain] Jey SJOJepoid dy} 0} UINOIA Buryfey Aq poddenugq ‘Jayjoue 0] advo aUO OI] SUIATZ SEM | SAT] IO} popuey] ouesd ay] se yO, May Jo A} SY} SUTYOOTIOAG 0} SUT JUdS SY SIOSURIIS Oso} ULY] BUIOJWIOD SIOU SEM OY ABM Pd]SIM] SLUOS UT puR [OUOD $,AdIJJar JO SJUSWOUTFUOS dU} 0] P9sNn SEM J ISLIP JY “POAdT[Ol [JS SeM | ‘URW SUT[JOIIUOS JayJOUR 494 0} yorq o8 0} pey | Ysnoy] UaA_ “SUTUSAD OY] UT ode vIpIeNyH eT ye sale 0} UOOUIOIL JL] SABI] O} SU JOJ POYOO IYSIYf & pey | “OINBUDAPR }xOU Aw uo Ul ou [ly 01 Aep puodas dy} UO SurWOW 94} UI AjJeo oUOYM [99 AW UO SUI pal[ed YO A MON Wo sjuRjsisse s AdIJa¢ JO suo A[[NpyueY J, “QIBWWIYSIU BUIAI] B SEM }i OW OL “SalsejuRy jeuOsiod J1dy} JO JUDWUJOeUDII B NG BUIYIOU $.]i WY} Of “UOSEal B 9q 0} pooU ], UPIP a1dy] ‘sd}SuOLU aSaU O} puke PLJOM sIYy} UI JYBnoY} | Ng J9Y}ed0} SOL dq 0} SUOSKAI ISI at} JON “Gol J9yJOUR JsNI Sem SY STU O} PUk [ITD JatjoUueR ysnf sem | unyY 0} ‘poreys om AOBUIIUT OY} UL UOISsed Jo YOR] oy] SEM 9194} UdY | “S90} AU Ud9MI9qQ UI POY] USAS PUL JaoJ AU PSAO] 9H “Woy} JO dUO ZUI9q SOUTIg 94} ‘Ud BdULIIS SSdT]} JO SaIISAp [LNXas oT} SUTJSOU ASBd 1, USM I] “JYSNOY) | BOY Inq oJoyMAUe ‘UIese ABME MOT] [HUN sINOY 34] UMOP SUUNOD sem | SB OUI JOJ A[MOTS Aq podseIP slut] OTL], [Te eB Mes UdAd ATPILY OM JEU] SprensApog o[dnoo & puke ‘sn JOJ SIOUUIP INO payoos osye OM splet Jo a]dnoo e aaes Ajdwua Ajo}9]d wos sem UOIsueU OY ‘|BapsO dy} YIM adod oO} a[qe sem | XBURKX Apval -I9Aa Alu Jo djay ayy yim AT[HJyUey) puv poyeoi[duroo ssoy ABMe SUIT] Aw opew wy Aq poinsseai Suiag ‘sqof ajdnoo e 103 Surdyjdde uaao “yeaI3 Zulop sem oH “Suisdejay noge sjysnoy) Aue pey },upey ay Surdoy ysnl jnq Seu e 9q 0} SutjueM jou ‘Aep v SdLUT] M3j B [| UO BuLyoayo Ul pares ] 1, USBM ay INQ ‘ua0U09 AJUO AW dq 0} SEM OY SAEP JO 9[dNOd }x9U 94} 10,4 ‘SUIPLI yoRqosIOY Wy 94e} ATdulls 10 oBesseUl OOo UB SULINp Apo AU UY MO}SdQ O} SULARY JULI Jey} JayJoYM ‘Ajssorpus WIY Ule}ID}Ua 0} sem gol A “SAep Jo a]dNnod 1xdU dy} JOAO 9104S UL AR] JVYM BUIPeoIpP -Apeasye ‘aw owes oy} ye sado Aw SUI[[OI youq wy posdny | “pudiy Plo ue Oy] SUI poj9o13 pur Isiem AW punoie sue sty poddeim 3H “}YSIS BeYM pure ‘Mmalpuy soullg SSOUYSIY sty seM }] “UleBe 9OUO OUI pajaoI3 ULI ASSOYS PJO SUBS 1LY} ,.O]]OH,, Je Zurpueys SEM dy Jey} JJoYSyooq dy} WIJ punole pousn} sy se sez AL JJO YOO] au} odiM } ,UpyNoo | “ow JO} SUIIEM d19T) Apeolye sem json AWW UOISURTT aq] ye PaAtue om UST A, “OPISAUNOS dy) jNOGe PSA] | JVYM S.jJVY] PUlU 1, UPIP | ING JLOMS PUL LIP dyT] Popes yey} Yous) YOM 3iq ve us dn ow yoid 0} awed spuey yours 9} Jo 9G “WodsTe oy} ye poalue | UsYyM Aep ot} JO s[ppiu dy} SEM ]] “SPoodU JOY} 0} JURI[dLUOD 9q 0} JNg 9d10Y9 OU pey | puke suUOAUR aq P[noo yt Mouy | SB JeJ sy “suONsanb yse oj a0e]d Aw },useM “SEM yeY} WOYM JO SINS JOU “B1J9Y}] SUOSWOS ]39UU O} SEM | JY} aut pyo} AjUO SULISIYD ‘94 BIUS UT aq 0} Pouoydaq ‘UIeSe 9UOS SEM | Jo}e] SABP OM L ‘I9Yj93O} UO YOR AT[RLIOYJO 9M pue JYSIU ey) JDYJad0] paq SUIS 94} UT days SAA “YORQ SAO] AW POUINjoI | puw out O} pres oy ,.“NOA DAC] J,, “SUN} BUOT B UI SUIT} ISITJ OY} JOJ WY Possry pue sny dJooUls e& UNTY JARS J TOA JO pnodld Os We | “OU 0} SIONLW Jey) [2 S.jey} pure mou durAy 91, NOA JS¥9] IV [| assed st suo ON,, ‘odoy tury sArs 0} AY ATUO prnod ] ‘ploy yNo WHY sson3-puosas 0} | SEM OYM JN [IJ O} WY JOJ pauses SPISUT UOWOSP STH ‘[]aM 00} [][e WIY MOU | Ng ‘YTe] SUIOUTAUIOD B SEM I .19119q 103 0) BuIOS oe ssusy) sTWOId | {pe YW WOIy ABM JOS 0} ST WHY 0} dn 31 ayew uvo | AeM ATUO 94} pue dUI JO ssNedeq Peap SI Wepy “MOU adueyo 0} Surosd [ye $_jey} sstwOId | nq “SUTAT] & 10} SBP S|fos pue sfeays oym aryunf @ Wy ZNOA prnos Moy ‘qJOWAUe stu JO YONW yuUIY] 1, UOp nod Mouy J] ,, [olds sty ueBaq ay d}qe} WOO! BUIUIP oy} Je UMOP OW SUT ‘sAQMAURP SS[O SULYJOWOS JNOgGe yje} 0} pajyuBM 9H “SAeMAUR NOE HIP} 879 $0 gT9ebed ‘OE78~Z9C 6T0Z/60/80 ‘822 JUSaWINDO ‘898Z-8T BSeD

The text on this page is estimated to be only 41.16% accurate

IP7roomMTAIAIO 80T JOJO 3} UO BUO JT} ‘SW SHI] 99M NOA ssouN ‘ITJAPT WId9S P[NOd ST[A}sofT] SIq] AURW OL “SOTYS SSO[PNO]d Jo JoxUR]Q oN[q dy) Jopun podeid pue ‘yueIp ‘aqe OA “S JOf 1S OMIT Uo uoouIae Azey [eotdA} sy) sem pouleyojus Udy} SuIdsay punose yoy 0} uswomM SuNOA [NJHUdjd pue sjsonsd SUTVISIA jo Avie JuRISUOD Y “9J9q] SABp 10 A[SUISedIOUT sy} JO SAep ssopJUNOd juods 3M PULISI SIT JO 9SN SOU 9Y} BUTYL] “JeSA SY} JO SUIT} SHIOAR] AW Sem SI4] “duds JO sopeYs [Nj1O]OS 3y} powossoyq Jey) SAep AuUNS suryovordde ayy 10; ABM Buryeul ABME Pope] SPUIM 19]UIM ADT OUT, | “oAq uo dis [113 du 49] pey | SuluotUsw jou ‘o} dn 403 | }eYM pue sem Aep Alu MOY OW payse AdlJor UdYM OpIsul dy) UO popitus pue YsIYy peoy Aw Play J JO] BY pay] ayimb | “yjBuds JouUI pue opiid Jo Sulpjooy Mou & SEM J ‘payoidas pey | Jeu] SUOIM pey | SUIYJOUIOS 9UOP peyY | J91Fe 00} posn sem | AJOEXUB JO [ANY JeIIWeJ 94} 1, USEM JL SW SITY] ING UTede YORUWO}s Aut Jo pid dy} Ul Suljaay aqeiuapun ue pey | 1991}S ,,7L OJUO JOUIOD SY} SUIUIN] “SLUOD 0} SAPIIS JOBE] JO IoUepuNge BUIMOIS e Ul daqs [;eUIS e sem doysyxoog 1eYy] BulAvay] ,jAV9 3y) Ul YON] POON,, ‘ples pue Jopynoys AU IOAO 99UL|S JSP] DUO YIM PUNO Ie pousny | syoog AW JO} durAed pue JYSIUpOOS Jay BUIppig ,.“NOA JOOW O} DIU A]]BII SEM JI ING “Jyo oq JSNUI ],, AuOTe UOSIad SUO UO SABY PNOD | Jodo 94) puv pUueY Je ddIOYO B pey | SUIZIPES1 YUM Pdyaeys Jey) spl] Atu UI JUIOd Suluiny v Jo sulUUIsdq 34) SUM ]] ‘SUOP 3q },Upynosd isn J9q se Yons [ud AUNOS JOOMS e SUTYSTUE} WHY JO JYSNOY) AJOA OY} PUR JOY YIM OP PlNOM dy jeyM Apoexs dUIMOUY "IVd O} Jka WOI peords usd ATS sIy das Apvole pynoo | Joy suijsow uodn J0R] SIY UO YOO] ay Burursewul AJUG “SYOO, AdeTq 9]I1] $, AdYJor JO suo ul UMOp BUIOS Joy OND od ay) Wy A[AIULOp pynom ays ‘Ns sseysinoy Jay payuswijduios Jey) ssoup Aamo TJ WOys ay} Aq poziseydurs s1aM sA9] SUO] JI} ‘ULYS SHYM YOS pur ley pol AaYS YUM [IID Ayjaid e sem ays ‘AeM 9) JO ows Aed J9y Surdjsy ‘AJID DY] O} AOU! O} UOISIONP Big 19y UI poyoddns pue Addey aq 0} Jay pojuem ysnf Ady) ‘tuay) 1edu Jay SULARY JOU LUOIJ SpISy “SWIedIpP UMO JOY SsulYyst[durosov ray Jo Sodoy Ul spisANUNOS 9} UOJ, SAO O} UOTSIDEP SIq Jay Ul SAILIOddns Osye 319M Ing ‘s19Y SUIOg IdY poyey sjusred Joy ‘syyUOU OAM} ISP] OU} JO} AYO OY} Ul Bulag ATUO 91DY pUNOIe WOI 1,USeM 94S ‘IOYJOUR SUO YIM YRads 0} Ased IT PUNO} 9M BUIPLSI JO SDTIOYS $,194IO YORI UI S}SS13JUI JE[ILWUIS pue SunNod yJog Aeme SuIeyD “Aqievsu Suissospsrey JO} JOOYSS & 1B JUSpys B sem SYS SABMAURP ‘JLY) SAI] SUIYIOWOS 10 SETA JO SLOFRA SEM SLURU ISP “I9t] 0] JJSSAUL pSONpONuI IsyyNy J pue MOU BULIZSIS YIOG VIOM IAA , YSNOUD [NJoIed JOU UW,] JI 199} OM) UMO ALU ISAO diay pue yoo & UI dsOU AW YM dn paddeim os 303 | ‘Sulod sem ] oIOYM Je BUIYOO] 1,USeM J] ‘V[Nej AU SEM jI ‘OU SON,, “OxeISTLU AW JOF Burzisojode SeM ays ..ASLUN]D OS UW, [ ‘AJIOS,, “UMODP SBM J] O]SI2 OUIRS OY] UMOP BUT{OO] [413 B OJUL padung | ‘sxOOg Furyoo] SuNsosajzul Jo Syoeq oy} BuIpesl TVILNAGLINGS JEuoyeY payoojo1g WYyZUAdOD [1] orcrooTyasANIO LOT Sul) AW YOO) |] OS ALiny Aue UL}, USB | ‘SO]IT} P[O JO JUSW}IOSSE IIDY) }B ISMOIQ 0} doysyoog Pjo ue OVW poy]eM | ‘doys j1d ysey] OuUO GuLyey ‘s AOIJor 07 yORq AVM AW OpeUl | pue possi Bulog NOY Aq poddiys Aep sy} JO ISO “H JO [[w wos AVME 9d 0} Ysnoud Ivy Osye jg su popsau sy UsYyM IO} AdIpJof 0} YOeq Jods 0} Ysnous asojo Bulog “aydde Siq oy] Ul ayy SuIISEd SILIOARY B SBM YOO Pood kB JO JodedsMou dU} SUIPedI SACOYS S3dJJOO 1 JNO GUISUBH ‘JI] JO SHUM JUSIOJJIp [[2 YUM poyeUlUe “UIDY} JO T[e PI[[Lf IQIA SISGIOUD SUILS 9Y} INQ JUSIDJJIP | SOM JOOS AIOAq “AUD 3} JO syed SLUII99 SY] Psaoy J ‘Adevsoy) Surddoys SUIOS OP 07 INO BULINIUDA “YIO A MON Ul SABP MOJ 1X9U OY] JUSdS | _ : ST to;duy,) "YON OS SIU pouea JY) pasa lAld pojjeo-os dy] JO Spoou ARBjNA ausdsqo 9yj SUT[Y[NJ SeM J] "YIOM JO SAep o]dnood v 10J aye pynos ade Sunod Atu ye ApoqAure yysnoy] ] YM UR) DOW ‘df BIULS UT OUT] AUT JOJ SIL]JOp puesnou) B 0} 9SO]O USAID SEM | “PIP dy JOADIOYM JUSM Jey] BQ I]JJNP SNOWLJUI dy} SUeD NO pure sd1JJO s, AdIJor 0} dn poinjusa [Tw 3A4 “Spolqns JoYyIO 0} UO Pd] UOTJESISAUOS OY} PUL JOY JOJ Bd} S DULISTYH poysIUy | ‘91194 SUIpIog oy} 0} punole BuIUIN | “sul poyuauTTdiuos Aayyjor JJM AT[Vo1 pip NOA “poon,, ‘JUDJUOD YOUNS YPM SUT ISAO P3yOo] YyIOQ Ady) s}ussed pnoid OM} OAIT ‘oe d Isl OY} UT JO atu poureyn pey Ady) yey s,31 ‘sAeMAUB YIN) dy} MoUy Apeolye Ady) ynq Bury) SJOUM JU) J9AO Y9JF pey | BUSNSsIp MOY JO YINI} 94} JOU “IedY O} pajueEM Aouy yey S.J] 2194) au s1y Aofud 0] Sululsas Ajyeor Aep yors sow a[dnoo jsea] ve aBesseUul & pey oH ‘sasesseul Jo Ajusyd wy saves | WsINOd jo pue ‘jood oy) ul SurumuiMs yUOM OM “LUN ‘ALodold oy) punoye ysnl Ie O} DIIYMOU ‘SUIPLE YORGISIOY WAY YOO} J,, J9YI990) PIp om JEYM WIIdY] [[9} 0} UO JUIM | , SST] B OW DABS OY JOJO YDS 0} 9Aq-pOosd pies 9M UdYM pue diy) oy) BuLINp poxe]s1 posses oY ‘oUt poos A][eol e pey oY AUIY) ], SUNvd US9q PLY | SISYM IJOUNOS oy) YORdun 0} pojseys | Us} JO YIOq UWA 19k]U09 9Ad SUIPTOAR puv vd} Jo dnd Joy Sulsedoid Asng Surdsoy “00} BUILIOJOI SEM SYS LYM AT}OeXS SUIMOUY “YSN 0} SU JO} UOIJOVOI [RINJeU B SPM J] ..g20ULg otf) YyIM YOuRT oy] SEM MOH, ‘UONeSIDAUOD 94} Poyeys suesiyy,,”°OS,, Jelnoed Surjoe som Ady) JYSNoY? J ‘WdY) 9dvJ 0} punole BUIWIN | “dyed dAOjs JOY 9} JOAO UL Ind pue UdYyd}Ty OY) PuNoIe [JIM 00} [je Aem Atu Sulmouy ‘pieogdnd yj Wo 91}}94 por AUTYS 94) NO 1035 | "Youdq UdYOITY ou} JW SJOO}S 94} UO 1943930} UMOP Jes AdY} pue _J]NJ [[S Wy pue aye ysufom ‘syUeY} ON,, “PoJoMsue ay pue UIVGe poyse | ..{NOA IJoJ Jad ued | SuryAUe 879 $0 /T9Aabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVILNACLINOD [Bust poosjoly WysuUAdoD £]

The text on this page is estimated to be only 39.12% accurate

CPTPOOMLLANID OTT "SUOIIOIIP JUSIOLJIP UMO INO UI Paio}jVOS PUR S]BILU INO poysiuy [[e A, “Wsy) Jo Aue UsEMJOq AJSOPOl OU SBM d1d4) ‘sJUSWIWIOD Asseiq pue sayxod [nyAeyd YM wry JO OPIS Jay}I9 UO spIIS oy) SuIsedT, "JNO sUI0D 0} apis AYooYy9 sayeooaoId yusiedde sty Joy Asvd }I Ope JYSIU 94) WOIy soUaSge Ss ,AILT[IP “Jim S [II "YIOA MON WOT SUIISIA 313M OYM S]ITT A[SAO] OM) YIM [TG Sem sn WIOI} 3]QR} 9Y] SSOOR BUNS "| pue ourysyy ‘AWW SEM apts Io] 94] UO ‘skeme SPB ‘]Te J1 JO pray ay} je Addpjor sem SIOY | “9[qQe) JOUIP oy} Je Sues sn Jo Moje A[uO “yons se Apied Biq & },USeM SIY] “OfAISOJIE SIY WIJ JOU INQ 3414) SiY WIOIf posal ay Jjasury pue sim sIy suynerprumy Ajoyqnd “3 dAOId 0} ule}S DY} PRY pue Sd; yUR SIY PUNO SIOSNON SIy YIM JYsNVo sem DY ISNVIDG JOPRI] PJJIOM & Se IJO1 SI] WO) PISSIWSIP 3q 0} PJJOM 34} UI juopisaid A]UO ay) SI 9H “UOUT]D [[1g “A]UO pue suo 9y) “Sulaq sduRIesdde jsonZ JUBdIJIUSIS JoyJOUR pey puRysI dy) UO Ayed JoUUIp BIq }xoU OY], ‘uBaqqlue) oy} WIOL] S]JOYSBdS JO UOI}D9][O9 puke SainjusA Suiddoys AU WOIJ JUSWIPOSSe UB UJIM polly Apeosyje sem YoryM “juow ede AW 0} yor powueM | SutyjAue ynoge ysnf podsuey pynoo | asnvdaq ed ysaq 94} sem Jol oJvALId v UO yor SulA]y “A19Y} PUY P[NOD UO SYOBUY YOU IIIT] 9} [[e Poao] | PUB UMO P[NOD [AIS QUO SIULAIG JO JUNOLUL UB IOASU SBM dIOY} JNG UOTYSe] JO P[JOM dU} UT JajZjo 0} Yonta pey uRdqquesy dy) 1eY} JON “Surddoys JO 11q & JOJ JfaSAW asndxa pjnom | s[1YMe dq 0} SUIOS seM dy MOT J J] Apjoo1s09 suoyd ay} SuLaMmsur jou oy] pidms SuIyJoWOs 10} saAo]duis Jood swos uo UMOP BULWIOD JO sUOYd DY] UO WITY 0} SUTUDIST] 9) UI JIS 0} SLU JOJ BuLIOg OS SEM I] “DOJO dy] UI YIOM OWOS OP 0} Ado JO} PUuR{SI SUYOL 1S 0} OF 0} DARY P,dM SOWIOSWOS *A]ID oy] JO oSpaIp 94} 0} yOvq 399 0} Duiaey sJoJaq Jusds 319M SYI9M MAJ ]X3U 94} MOY si Ainxny] jo dey ay} ur dn q1 SulAt] pue uns oy} Ul SuLyeos ‘pulysq yensn 9y) SN FULABD} ‘SAOJISIA DY] JO ISOW JO} 9AG-PpoOs SEM BUIWIOW 1X9U 94], ‘pueysi SI] 0} SJsand SUIPSIA 94) Jo AUBUT Aq UOTJBSIOAUOD 9]qQB) PUR SNSLIUI yontu ev Suryieds ‘tool aduno] $,dsnoy UIeLU dU) SPISUL JJO pamoys ADIJJOF JVYI We JO YIOM URVIOMUUT UR STURDAq 9Tq¥I SY] UIOY YIM PIP 9M ]LYM JQ Spuly Burzewe Ino ul ATUO JOU PassodUI! USAD SEM 3Y AddpJor 0111 payuasaid am udsy AA “YOM Jo 9d0I1d GuTjsarajul ue pue Aye JO Wd} UB ONS SVM }I ‘UOTJVOIO INO UT PapUNojse YOG d19M OM JT BuNs[dwo0s uody) “Aep $.aje1id dy} Jo vd 94} Woy 19] Soootd Suiurewas 9yy JO INO J/qeI DIBSOW B AdIPJOL OPRLU 9M “LUDY) SUIARS Puv SUIS} SUIIDIT[OO jo sivoX omy Apleau Jaypy Pus 3y} UL} YUIOM sem JL INQ ‘Aep [je Surssip WOJJ SUP IBOS 94] Ud] PUB YSNOIY) SuIyoiess 9q pynom aM saysnq sy} WoL sayojesos Aue BuLinpugq ‘sn Joy yoopsod sem jI aduaTPeYyo & BUIAO] y}0Q ‘YSnoy} Ased ],USEM | “9134) Pue JOY SUIOD P[O SUTOS PUL] 0} Ysnous TVIENATIANOD JEUMEPY popes ySwAdog G 7FTPOOMUAANIO 601 Ayony SujjoS A][EUOTSeI90 UDAD pueR ‘a]k JO So]}}0q WOOF Sse]s PoyseUls 10 sayejd uayo1g ApISOU SEM }{ ‘OSE SoLINjUSD puTYoq Ifo] Pey s.ayerid JEU) SJURUIAI SY} JO SodaTd JsO] JO} SUTYSIVS PULIS! 94} puNore s}noqe yyem AOlus pynom 3A “J9YI9dO} JSoJOVUl Jey] Poreys | pue sueysiyH ‘SOHIOAR] AW JO 9UO SUID S][SYS “SHUTY) PpO BUT}OS{[OI PaAgy | “Quo Aq duo SoINseed] MOU AU JOAO JUOM | “Seq SyseId & OVUT s][ayseas ATU no SurAjydwyq WYS1u0} Suryye} ssoyurod sow Aue Joy dn },usem | “asno[q— dn pains Auli opisul sjjoysees Au SurAqies eueqes Aut 0} yoeq Aem Au UO WIdy} sed paxyeM | Se }ORJUOD 9A9 OYBU! O} JOU BULAIT, “UO poxIEqws sey ays sooevjd pure a]dood jo sars0js pyim Joy Surpe dal ‘ajqe) oy} ye 19] s}sond SUIUIeUId oy} SulUTeLajUS dn oq [[NS 0} sUR[SIYH yeuue Aysed jsnJ} jNg Pog 0} JJO qu0s pey Adljjor USA “SBURQED Id} O} Poljo1 oUuOS Buoy ud9q peY PMOIO [LUIS 94} Jo AWWOfewW SsNoY UlEW dy} OJ YOR SUIBD | OUT) ay} AG ‘JUSUIOUI B JO} pjioM aiuUd oy) Wor psreoddesip Ajjenioe | yet} SUISBUII P[NOd | ‘Ul SO] 399 0} SOIUURIO puB SyOOU AUBU OG “pur{si dt} JO apnyiyos ay) ul Ajludsas oy) poAofus | “Aem oy} duO[e pues oy] Ul poppaqul s]joys eos dn poysem oy} Sunponid uoysesp sjisoddo 94} ul payyem I ‘Tv pue Aoyjor us9Mj9q UOHRSIOAUOD 94} JdN.9} UL OF SUNURM JON "00} [JOI]S B 94k} PUB 3]qe} Sy] PUNOIL 1eYO d{pl 9Y} Woy ABME YRIIG 0} PIploop | USYM BUIUSAS SY} UT WIEM [LS SBM IOyJBOM sy | “Adjor PUdysomM dy} JO JSOY SY} YIM YORoq dy} 0} UMOP YPM B DALY O} SPIs S,dJIM SITY Jo] AJUO 9H “OS 1YsNoY} | IsB9] 3B JO ‘ATJUNOD B SUIUUN SpleMO} UOTOADP SLURS SY} SALY P[NOD SOUO PSO] SI] SpeMo} uoissed pue UOTJOASP YON Jey) MOYS PjNOd Jey] oUOAUY ‘9}0A AU pey Ajoyulep oy pue 1e9X Jey] UOTSE]9 JeUopIsold ev Joy dn sem dH “dJ0q} souo ATUO oy} d49aM Ady] Way} 0} ‘arayMasy]o ARIS $,349 S.[Y¥ PIP sdU0 jou ‘UdUIOM [TYWNe|Sg Sunod way) jo Auewl pur yYyS1u yey) SuUNISIA sjsona AUBUW 94} SUOULY “UI9Y} UdAMJOqg UOIJRSIOAUOS oJLUIIJUT UB SuIARY sada S J3YJOUR 9UO OJUI BUIZLS 9[Qe} JOUUIP Sy) Jv I3YIO YOR 0} JxOU Jes AD], “YOIEM 0} JOOMS OS SEM j1 ‘AJIM SIY UO POP |Y UOTUS}e JO JUNOW 9y} Aq ABME UMO]G SBM | “URAQQIIeD 94) UL AeMe SpudsysoM AUBUT 3SOY} JO 9UO SULINP sJIM AOAC] SITY PUR DOH [VY JOU | US] “AlUeUINY UT SprepuR}s JO jSOysIY OY) SALY 1, UPIp | ‘SuIpuRys sem | WOYM WO Woy} Sulses JOU JNg 00} dn paxoo] AuvU OYM P]JOM INO UI ssoy) Aq pepunoNs ‘OUR }SILJ IDI QUOTE 49] DDUdTIOd xd O.1UD SU} J9G1O} IOUOOS P[NOM S JOWIOYZ]Y Onp ATOYI] JSOUW OYM SUdZI}ID JOIUDS SIIYeLIOG SSO} JOF yno 1YsIU 9/SUIS B UY} SIOW SuryOU o19M Aa} pozijeal Asy) usym pojutoddesip dq 0} ATUO ‘Ud WOpuURI YIM Sjoe Jenxas ul UONedIoed Jasvoul aay) Joy ysuf s100p uado Jo asprjyqjnur & pastuold 319M JXOU OY) JUSM PUB ABP DUO SIRS OYM SIF IOYIO dy} SBIIOYAA “SO1ISOP [vNXSS JO dqeIUNOWANSUI s Aoijar ATUO 0} puaye 0} pojoadxe Ajjsow sem | “Jou sAem dLUWOS Ul pue ow Joy A[ayeuNYO, “U9013 OS },USBM SSPIS OY] DIDYM SOU} 94) JO apis 879 JO 8T9aHed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘822 JUSWINDOd ‘B98¢-8T 9SeD TWILNSCLINOD PoUaIePY Pos, MYINAOD [7]

The text on this page is estimated to be only 41.74% accurate

SFCPOORRELINID CLL JO pue sievo STY PUTYSQ UDAd “S90 STY USdMJOq UT ‘UMOP puke dn ‘Apoq SIY Qnsos pjnom pure spnsdvos YIM JOO] & posoyyey | “WIY YIM palamoys ] JaaouayM pip sAemye | SY Jey) 1e oINyeay ppo ue [Ns yng “opnu pue uvd]d SuIaq YIOG Paaoy Jey) ueW e OJ BIMRdJ S[QISSa90N ATJOoJIOd SEM }] ‘WOO 3Y} JO SIPPILU ST} UT YSU IGSI[AYS sseps & YJVsWspuN pasojpoua JaMOYS Sse[s B PRY oY ‘JOO do} s1TJUS 9Y] SEM YOTYM “ULOOIP|q STY U] “JOMOYS B JOJ WY UIOl O} SW poyse pue poq sy} Wo dn 409 Ado ‘JUSWOLU B JOJ SHOT] [NIIP Siy 1OJ [Jaf udAd | AYM Surlssons -puooas 43] 9q ppnom | pue Aeme opej A[¥OIND pjnom UOTSIA Jey) ING saha Sly pulyog A}MIOUIS BY} POAdIjaq | BNUIW JoLq B JOT 9qARIY “‘P}IOM SIy} UL pojuBmM dy SUOAUR PUe BUIYJAUR UMO PjNOd sy Jey) MOU O} poy"UBM dy SSUO SY} Bula] UO Jo 303 Adyar ‘diy OSS ue uLY} SIOW SUIYION ‘Aeydsip OJ Jno yo] SuryjAejd UOWMWOS eB URY} SJOW OU 9y]| payess] SUINq SEM | PUBYSIOJAQG PUODSS SY) PUL JUSUOU! SUO dT]USB PUB PUTY OS 9q P[Noo dy MOY d1JeZIg SBA 3] “OW O) URLUNY JSOW]e powsss AjJeau oy pue sada § J9Y4}O YORS O}UL Payoo] Jsnf om JUSWLOW B 1OF ‘ooRJ AW PoyOIs A]}99MS puv siva AW pulysg oR Hi Ind ay 41 0} J90d PyNod | sJOJog ‘savy Alu Jo JUOLJ UL [JJ AVY JO pueIjs B Ud) “JUSTUA}e}S oN.) A}JSOW puke sNoJOWNY sy 18 paysney] | ‘Out 0} }XdU Pdq Sy} UO UMOP Yeq Jes oY SB poy yonyo Adspjor Gg SULd93]S UW] SYM SIe][OP UOL]]IW B SYeUI 0} SUIOS | We OS]o MOY ‘Ul BuUIuIOd AQUOW SU} [JIM JOYIOU pue Sdojs JOASU ¥IOM Jey} INOGe ALIOS,, | ‘SUI 0} UOTMOYR sty Surunjo1 pue JOOP dU} JO NO ULTY BUINS] SIOJ9q SISPIO SIOW Modj & JNO paypsny PUL YOM OJUL YORG SNIO}J SITY POWN} dy URTY 0} YoRg BUIOH “puodes B aye} AJUO PyNOM SIY} d194) Avs ysnf 07 SUT PjO} puke SU O} YORQ pousNy Adlyjar pue ‘passoJp pue dn 4a3 out 901}0u 0} YOM 194) UI dn paddeim 00} 319M Ady) BULYUIY) SIDAOD Sy} YJROWISpUN Woy pesy Aw poyxsod ] ‘AjyoInb UMOp S$9j}OU SUOS pay}sof ay s]IYM SUOP aq 0} Papsou JeyM URTV {[9} 0} poyeys Aodyor “uu JO JUOI, UL YSU ‘ATOYeIpoUIUT ssouIsNq JNOQR SSISAUOD 0} URZIQ Ad) OPISUI URTY SUIS] puke JOOP WOOIPaq 9q} SulusdgQ ‘wyeo Ajd}9{dw10d JOOP 3} PoJoMSUR PUR SUTO] SIY PUNOIL [aMO} e poddeim pue dn 308 Aayjor “uoistujul poyoodxoun oy} Woy adey ATI palaaoo pur ‘*, ASsng,, SPIOM UMO STY JO JO[OD SUES SY) JO WIY papulwial }I asneosq ul ddaqs 0} asOYd ay ddUdIEJoId 10]O9 SY] SI YOY “sjooys poq yuld s Assyyor ul dn yjasAw poddeim | ‘uepy “pusyy poos s, Aarjor Aq 100p 94} 18 yoouy B Aq paidrusajur sam om ‘Apog Atu ojut osewsyid IeB[NA § AdIJor JO UOISSas jIOT]dx9 ue JoyPYy “AdIjor puv wiy usdMHjOq diysuone[ai SSouIsng SUIOO] B JO] SBIQ B SEM [NyNNeIq pue SuNOA dU} 10} 94Se] S,uBTY “SAPP 98d} SIOW PUL JOU ‘UOTSURW UReYURIL s AdljJof PUR PULISI dy) puNnose Suisuey uses pey | “Joyjesy owes SI JO plig B ‘AO}DI[OS [euOSJod pu SsdUeUL UT SNBedT[OS siy ‘ZjIMOYSIIC] ue] y ‘uBeyUR JO apis yseq Joddy oy} Ul pauMo dy Sd1JJO 94} SSSUDATJUDNE SIY JO SHOO] 94) Woy [JOM SuruuN sem ssouisng s ,Adlpjor 879 $0 6T9aHed ‘OEZ8ZIZ ‘6T0Z/60/80 ‘8Zz JUBWNDO ‘898Z-8T aSeD TVILLNACIINOS jeLorepy paioajoig wyBuAdog [) PrTPOOTeAANIO TVLENSCIINOOD JEU] pa1sajo1y yqBuAdoy (7 Ltt "PdsSO]d USdq I9AST 9A. P[NOM Ady} LY} SOUIT] MOF & PUNOIL OF O} SUITOJI] UO UT Jalid YSNOUsS dAeyY P,} pue uado p[noo sayespoory ou} ‘pip | Jr “Weoy Aw ur Ajid Joy WOO ON *3LY) OYI] YUIG) J[OsAW Burj] Aposes ‘YSNOY) Posstul aq 0} 901d U99q SA.PyNOM J ‘UMO Au JO ATIWR] & NOTIN 9q 0] 99UD]STXO PRS B ][HS Jnq AreuIpoUN ZUIIAUL 1, USEM }I OU 0} Os SAEMAUR STIOY 0} ASO] ou Jday sey ISAOU UMOP Pd] Sey SJI] AW! PeOl SY { “diysuoNey{als Pojolsjsas INO 0} JUS}x9 oY} SVM JVY} puke SUIOP SBM | MOY MOUY Woy} JO] 0} OTIYM B UT DdUO [[PO Aur 10j ytem isnf prnom Asay} Josuo] Aue way) surpsou jou yyeam JO pylom dy) Ul payeonps pue dn uMmols [je sem | speoy siuoled Aw uy “[]e Je sAep 9soy} ff, 10 Sop Aw ‘AjIuey AW Sulses uso Ajaseq “youog Wye 0} yorq 3ulod A[PJeY “HJOA MON UI SJOY) DOM OM “UBSQQHIL OU} UL}, UdIOM OM Ji Ajayeunyojuy ‘sose3 pue sourny opeul URW JO SPNO{O NOYIIAM STAs on]q JO S9BB9 INOYIM S9dJ1} 1OJ 9SN dy} MBS JOSUO] OU OYM 9SOU] JOJ Bul]]aMp B SEM J] ‘WIOpe O} dINjJeU JO Yd] SUIyJOU SBM dO} “YIOA MON UL YOR | ‘SdUISsa]q $,sinjyeu JO 9A] puoj AU JO OW pUIlaI SABMjE P[OM Jey) UBIDO ASsOjS YORTG 9) ul Ays BuIddOMS IeYS YU} JO UOIJOS]JOI 9Y} JO PUIM 9Y} WOIJ ssaivo afdwis B jNoge Suryjowos skemyje sem 319} JOJ A][Bd1 [| UOT Jey MOY Jo}eW ON “WOY) OUT SULILIS SUI} UI SO] 1983 P[NOd | JoJo 9} JopuLY 01 S}YysT Ay10 31q OU YIM SJOYMOU JO SIPPIW 9} UI S19Y INO JYSLIG OS UMOYS S.1R}S dT, “SUdARdY dy) 0} dn poyxoo] pue sey AWW YBnoI1g] MOTQ 9Z901q 9) IF J ‘oseoriejs Sutyeads 100p}no oy) dn Aem AW SUTARYY “WOO! Sy 0} SIOOP 34} pesojo Apeamb pure uonjo] sy} Jo uvsjo spuey Aw podim J Apjuas Sutsous SEM dq 9OUQ ‘I JSoNboal 07 WHY JOF WeM SAMI PJNOM | II BULAJJO JOAOU ‘VI payey | POH Inq i Yse O} wy JOF yeNsnun },useM jf “BABd] P]NOd | a10foq doajse [[a} dy Joye OS JO SOINUIW AJUSM) SAT] WLM O} LW PojJUeM UdAd oy “dooyse [pep Wy SuyoeM J]IGM J99J SIY BSeSSPU PUL SI9AOD dy} Jopun yoral 0} pey | Udy] “LWUIY 107 SMoOTTId sTY Jn pue sjayxueTq oy) Jopun wy yon} 0} ow pajueMm oH ‘Jsonbos s10WI suo pey Adljor “WySsiupoos Aes ppnos ] d40JOgq “asI] poyeorjduros Aw fo Ayes oy} YOR j93 0} B]qQe 9q P[noM | pue poy[y[ny oq sonnp Aur pjnom usy) ATUO “II payuem oy MOT ATOBXE SUIMOUY ‘JeIS WO J7}I] STY SY] JOW O} peY | PSUS UNITY SYBUI 0} “SAqIA asoy) uo dn yord wry 39] 3, Upynod | Ing odoy Aw sem ayqissod sev yornb se YJIM SUOP puke JOAO Ht SUINIOyH “golf [nypeoip ev ‘sAep osay) sem diysuoneyal mo |e s,yeyy Inq ‘qof Aw pip | ‘A[[e4JO Wy UO WOJoId 0} SUI payse pue qn 94] JO aspea oy} uO dn jes ay juTersos Aue SULMOYS JOAN “ATYOInb yYsTu dU} pus 0} payueM ay “SATO PUL JOdj SIY YM SUTIEIS “Qn) oy) Ul asesseU dU} UeZAaq | S]IYM Pog BWOJaq YIeQ JOY B SARY O} PoJULM aH] “BUIUDAD SY} JOJ S191 0} JUD]UOD POLUdES ][Ig ‘ULE J9Yy}O PpuNole spits jHpHNeIq OM) UJIM SSOUIEP dU} OJUI BUI[[ONS “oIayMosyja Auedulos pul 0} JouoY Jo ysan3 INO ZuLAva] “Buyouts Noe je} 01 9O1JJO Jay) 0} JUOM ALU pue sur[siyy pue paq sOjJaq oSessew Sulusas sty pajuem Adlfjor

The text on this page is estimated to be only 40.32% accurate

LECFOURRELIAID vit jou ore NoA pue Adios Jey) SUTVLIS 1OVIUOD B UDIS 0} SAY P[HOM NoA Ajueyoduit SOW pue ‘aq 0} NOA pojuRM AdIpJor USYM puke sIOYM P|IYyO dU} YUM [Sav] 0} SAvY plnom NoA jng,, Tim yUSWIS0I9e-o1d INO Jo sus} dU} YSIUTJ O} ponuyUos sys UsY], ‘We 9y) YOO) ApIesu | SIOJJO ISIT IT9y) 1e poysiuolsy ,jJuNOdNe Yue $,AdIJor Woy soueMOTTe ATYUOW AYsy eB SARY pinom no **"pue ,, SUIUOAIDG 9JOM S[JOIWNIpP oy} JI Se pue .yIOA MON JO YoRag WyRg JOYS ul 991049 INOA Jo uOIsUeW e JOJ Aed pjnom Aaayor "nod djay 0} soluukU YDOIO SY} puNore saRy PjNOM no 4,, SUOD 34} dIOJOq sold dy} YIM SUIS |BOp 9) JO PUD SsaUIsNgq sy} YIM ssyono} SUIYsIUY dU) OpeUul sURISIYH ‘YM puodsal 0} Suly}Aue JO YUIY) USADd P[Nod [ o.40J9q pure uolIsodoid pajyoadxaun Ajaja;dwos 3y) WoI yOoYs 19970 UJ “SOBJ O} OUI IOJ LUIWUD]IP MOU O[OYM k Po}edIO sy Jey) SAI] IsNl puy . NOA ueYy YIM UB) Pjiyo eB dARY Joe P.J asja Apoqou JO YUL) Pynod | pue ueUuIOM SuNOA [njooess sinjew eB OJUI podopsasp sey oyM pd Auunj Apopysipop & Je NOX “sAdI][9q | SUI) SUS 9y} ‘nod jnoqe Suiy) stues ayy Ajjeorseq sAvs ApogdAisAq °0} NOA psonpout SAvY | SPpUdIIJ oy} SuOure JyasinoA JOJ ouleu B SULADIYIR Ud9q SARY no& ‘a]Aysayt] Aut Jo Suroesquis 3no& Joy uoNeid91dde Aw Mouy nod sdoy ],, suiAes dinjeu Aw asieid 0} ponuljUos af “Je BUINOD 319M SUOTUS}UL s1y yeyM dseisd 0} Surly] ‘pasned oy sui AlsAd poppou jsnl | OeUsOS 3}0YM dU} Aq poloplImag ., pivdol ul USIY yey) poy | sompenb ‘sAep ssoy) a[doed SuOWe PUI] 0} o1¥I SI SASTT9q | Jey) AJ[BAO] puke UONOASP JO puly dU} SUI UMOYS dARY NOK sILdA MJ SET SY) JOAO 1eY] NOA JIS} [Te JO SAY 0} JURM [,, “OJOJOq WIY UI Udds }, UPeY | AJIBOUIS JO PUTY UTRJISO & YM OUI Je PayxOo] pue yoeg Aw UO pueyY STY jnd puke sw OF }x9U Jes ADdIPJor way) YM Juods dun} AU JO ][B Ul $JUDAd JO JUIOd Suny ysossiq oY “IIe oy) Ul SULINS GUIYJOWIOS Jd} | PUB FUIJIS SEM | 194M O} JOSO[D pa}OOds YIOG Ady, { ‘JUSIPJOds oy] UL UIRSe sdUO0 StU GUTOR] “OW Je PoYOO] suRISIyYH uUsy) pue DULTSIYH JW payoo] Adjfor JEU} 1B DDUDTIS PpO Ue ‘JUSTUOL & IOF SOUDTIS Ul D19Y) JS DAA “ALJ OO} BYOL dy) de) JOASU P.oM BuIMOUY Ajqeqold ‘qr purw OQ} 99S ] UPIP oY ING Loy jv UILA 9] JO} 1Oa[qus AYoNO} AISA Y “ISpyo SUNOS St AT[eO1 sy Jey ung Suryod ‘sem Aolpjor ponsiyey Moy poysney 3M pue JOP SY} UO Way] 0] }XOU UMOP IRs | ‘oULISIYH 0} 9UO SuIpuRY pue opisyxorq 8, Ad1jjor punose [oMo} ev SulddesAA “OWN Wes OY} Je S[OMO} MO} B SN GUIQqeis ‘Yousg 99eI1O}S 9Y) Ul 31 pooeid pue Jess [oxIOUS AW JjO YOO] | ‘SQlUI] SUIOSE STY WOXOIOAO 0} YSNOUS sem ULII0 9} UI WIS INOY ue J[ey oy} AdIpJor 0} ING ‘YOOP 94) JO SNIPE 9Yy} UIYJIM SJOo1 MOTLRYS 9Y} PUNOIL [IxIOUS BUIJBIOBIAU! UB SEM ]] SU OT, “Wia] pulyoq AT\Se] pomoT]O} ] Usy) pue dn suo }x9OU OU] SEM SURISIYH “YyyeoIG siy DuTYyd}e9 UMOP yes oy se Aypides SuLARaY Sem JSayo SIH “YOOP 9y) JO doy sy} 0} sdays INO} }xou ayy dn paqunyjs pue dajs jsily sIoppey] dy} 0} dn Jjasunry poyynd Asaypyor ‘uBOgqeD sy} Ul UOOUIOYe AUUNS SU UOISN[OUOD Uappns ke O} SUED [Te IT TVILLNACISNOOD Jeuaiwp] poss1o1g wypBAdoy FC SPTPOORLEINIO elt ‘PIP JOA | UB] LTY 0} SIO JO] B JURdTH | SUIADITAG OJUI OUI psoNpas JoyINy sy sjuswAOlus yenxas POHOIsIp sly JO} pasn Sulaq []US seM | YSnoYIe pue slowAue uonoejsnes PojSIM} SITY JO} SIS JO SOOINOS DjLUIOI[E PUI] O} SU SULIBY}OG UdAZ 1,USWM 3} “SAeP 9S9U} Pdxe]dI SIOW SUI 99S 0} ssaueses sry Aolus nq djay 1,up[nod | “00} pleMIOJ P3yYOO] | WY} SAep JouUINS BuO] Jo Suiuuisaq QU} PSOUSUIWOD BY} SYUOLU JOLUIVM OU} OUI Po] SS9USAT}UDN SIF 6] tajydeyy "Itejye JO PULy MOU INO Ul ponsIUl sem | UOISsosdUUI OU} WY BULAIS “IOURDWIOp Sulsed siy poyosjew pue sjdwisyye sity posowny | OS ,SSOq,, AU [[S SEM 9Y SSJDYJOUON “WUTY YIM UdEdq peY | SIV9A 9Y} JOAO uddS pue YsnoIy) uddq peY | [[e Joye ssueyo 0} oseuN pley e [[S ‘sseoA AUBUL DU} JOAO Ids JO NO oadsal 0} SULOD O} PRY | JOALIP SARIS P[Od dUC}s DY} 0} JUDIOJJIP ‘JJaSULLY JO APIs JOIyOS B MOYS 0} BULA) AAULJOp seM OH ‘Jed YIYS YOuS [eNULUI B OALIP 0} MOY IW YOR} 0} Pol) USAD dy Pue ApYysn wiry oJUo Surpyoy ‘sty Jo Yor dy] UO JIS 0} SW poLayaid ay ‘ayxIq UMO ALU OP} 0} SU payuRM JadUO] OU oY SuUTyIG penb jUOM om USY AA ‘pus SIy Surtuosaq A]JBULy sem | JYSNOU) | ‘AALTS Xas sIy jSNf},useM ] JEU} UOHOU jeuTsUO AW Jo uONdadsed Aw Jaye 0} ABM Sly SWUe9Nq LUT} aItUSd Oy) SuLINp JooJ SIy odessew 0} SulAey Jo pesjsul usoodod jo yoxonq B JOAO dn Surssnus syysiu s1AOU pue soajasino Aq ABMP SpUudyooOM BSULINP YOuRI Siy UO SUIPL YORgasO} “QUOTe WIY YIM Surop 0} patuojsnooe sem { SSUIY) poyoAsod yensn ou) Isnf jou pue ‘ouoye “194}930} sSuty] OP pjnom om Youe 94} 1V “yensn ueY} B10 JO] B ‘SABP 9Say} 194950) aU] Jo Sdeay Suipuads som 3M ‘Q1OUI UdA9 9 SUIsNJUOS punoge aww unds AjayaTdwwo9 snl 41 sty] OyT] poyoe oy UAyM ‘ysea] & UO Op & UeY) sIOW SurgAue oyI] payee Bulag 0} posn j,USeM | “OTTYM B JO} SU YIM INO Suey 0} BuNUeM ysnf UdAd ‘aoRTd Spud eB O} OY] pur sOo1JO 9U} “WIY YIM SISYMAIOAD DUT YOO} 9Y ‘ABP dy} JO JS3I 94) 104 UOTISABSNS 19}OeIVYS STY JO NO ATTIC} JOyOUR SBA YOIYM OO} OU YSeM O} pajyuRM ATTeTYOe 9Yy UNY Surysem poystul} SEM | USUAA “WIE @ Oy] Suioe pue ‘ow ye syorio Auuny Suryeul ‘ABp 18Y} pOOW poyweaylYysl] B YOns ul SEM AdIJJOL “SUTWIOW Jey} IdI[IV9 ySeJAVIIQ Joy a10Jaq poddod pey | xeuex poeddod Apeogye ay} Jo do} uo [POLINS BOUL UIAD [99] JUSWOU! oY] SUIYVW “SUIpUR]S 919M OM SIOYM O1U] SSUI[IOD SSRIS SY} YSNOIY] UMOYS ]YysUNS oY { “Boe s[e}IUas SIY asInOd 879 $0 Ozgabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD THLINGICEINOD JEUMEPY POSMOSY W[FUAdoy 7

The text on this page is estimated to be only 42.11% accurate

GFEFOORLTLID 9TL A[qeqoig “ji Sutmoys J3A9 A]PVaI yoy Samed sys NOA Buljjo} JO ABM Joy isnt sem poyoAoid sinsul 19y Japurys JO JOAo| oy} UO SuIpusdsag 1 ydoaae 0} SUI0D pey | pure Aem Joy Jsnf sem J] “yORQ ow possny puv puodseas Jatiq B JOJ URLINY BUIdg JO UOTSSoId WI ysdq Jay OU SARS OS ,“SABMAUL YOn{-poos jnq vapt s Adlppar [je Sem I “WL GUM Op 0} SUTY) B OARY 1,UPIp ],, Popuodsal sys 9U0) []NP & UT ‘JUSTUDTIOXS JO WIseISNUS AU oIVYs } UPIP dy ,,jyoNUI OS NOA yURYL “SANZ NOA Jo SdIU OS SI SIYL,, “JOY PO} pue Sny 3Iq B Jdy SAV pue de] s,Aoajor Woy dn jos | ‘Mouy Apealye ays SLU PjO} SdBj I9Y UO YOO] dy} PUL JO}L] SONUIW Mo] BV Ul OWIKD sURISIYH "IL JO PUODIS B 9]SBM 0} FuIOS },usVM |] puv swUNoys1] Aw Jo Ajrunyoddo SY} SEM ]] “SOULS SITY} JB PI}LOXd SIOW 9q 1, UP[NOd | pue ABME SLUTOFI] B O¥I] papunos Adsjjor¢ Wo 9U03 sysom 1YSTg “[HJIOpuoM uUeY) sIOU PopuNos ds]d BuryJAIOA ‘yeJ UleLZ9OUN S_JOdULI]S & OPlOop O} SuUIAeY JO ][NT dy) SOpisog ‘sanBeI]{O9 Powsa)so siy JO UO JO WIY UJIM JOO 01 S’() 94} 0} J9A0 JUSS 9q PjNOM sys Udy) [eAoIdde Jo vonb sepnonied § AdIJof JOU BUS JeY} POPloop | J] “OWT Jjossoy Suyjas aq pynom sys yeym Mouy AlTUO ays fi “OUTJOFT] B Jo AjwuNjIOddo ue s10J Suidoy [ts [vd0}] B SUM OYS pouNnsse jsnf | OS SWLU DUIPUNOS URISY UR peYy dYS ‘“SUIAR}s SEM | MOYM .JaIOH Ssaoulg,, 94) Je dn ynd Suieq osye sem OYM f1I3 B YM dn JdaUI 0} SEM | “919Y} JOAO SEM | S[IYM OP 0} SUI JOJ JUSWUTISSE UB PRY UdAD dH] ‘AP B SINOY IYSIO JOAO YOam B SAepP SAL SOSSE[D BuIpusye dq P[NOM ] d1OJOq UT 9qV9S 0} SABP Moj B SABY ATUO P[NOM | *, JOOYIS asessve WLI, J8 SSe]o & Ul OU poyjolus Apeolje pey oy pue ysnsny JO pud ay) 18 yAedap 0} seM | “OU JOJ AreIOUTAI DINUS Ue JNO pouURTd pey aH ‘POLdWY JO Sa1OYs dU} TY OF SUIY) Big 1xOU OU) SeM JI ApJUsIedde ‘OSBSSELU IVY] POAC] 3Y YONW MOY puR ‘so[Npoyds s,,OOYIS oy] ‘dulAv}s 3g P,| VIY4M JO S[leJap 3Y] SW SAIS 0} UO JUSM 3} “JOJO INopuess sty poyeooidde | MOUY WIY 19] 0} [[aM PIP] ,,jyonw os nod yuey}“survoip ysoplim AW pUuodAag SI SIU} “ABS 0} JEYM MOUY },UOP | ‘MOM,, ‘Pip JOAd Ajored | Yorum ‘sdij siy UO Ssiy Biq v SuNUeTd ‘yOOu sty punose sue AW Mo1Y) | pue dn yi] soA3 AP “Qube 0} OW JOF 9]BOIJIISO ISIE B PUL YE}s & SEM 71 JN UT Pd}soJoqUI SEM | OBeSSseU JO ad Ay OY} ATJOVxO JOU ‘paqURM | JLYM 493 SU 99s 0} S]duI9}e STY je poysuojsy .,IsIdvs9y y, asesseyy ey poyiyenb v Bulaq 1OJ DVOTJIIOI B DAIODOI |], MOA SyBOmM JYSIo UIYIIM pur aBesseyy ley ONUSUNe WIRd] 0} puRTIeyy Oo} Aeme BuIO3 dB NOA “jt Jo BUIAIJOSAp ULY} d10tU JB NOA puR SUO] OS JOFJ SITY) payURM savy NOA YONU MOY MOUY J,, SW [][3) 0] poposooid oy pue JUsWsoUNOUUe sIy JO Suluuisog oy} Ajuo sey ,, AVpo} Aepyuig Addey’**][e JO JSAI4,, “MOU SUI JB BUTYOO] SUM OY ABM OY] Je poysney | .~EIeuM,, “QOUDTIS SU} JO SSOUASI) 9Y) UT PyIng uOHedIoynUe ou} SUINZ] SEM pue SU []97 0} Sig A][VoI SUTYJaWIOS peY sy OHI] ‘sORF SIY UO YOO] AUUTY B peYy dy WY OJUO SW Buly[Ng “de] SIY UO jIS SUIOD 0} SUI PoJOYsn sy SB ..dU YIM UMOP JIS PUR I13Y JOAO DUIOD,, “O]ILUS Biq B WU BuyuRIs sym JfO Sasseys TYILINACIINOOD jeLage) PoysaqOLY PY BUAdaD Fy 8rePOOTALANID Stl ZuIpeal siy Surye} ou ye dn poyYOo] oy Sap Sty 0} ISAO BUTTE “SOIOA JO DUO} ASOIND B UI POHSe | ,,(,00)] dn VYd JeYM “O][9H,,, “APISUT StU TOAI9q WIY prvsy puv sd1jyo s Adsjo¢ 0} 100p sele ApYsI[s sy) UO paxoouy | “SUI JOJ 910}S UT pey oy JeYM jou Ajoyuryep ‘Aljamof Jo soo1d 10 Aguow Surddoys [ensn oy) Suyodadxa SIOUT SEM | INQ JUdSoId AepyIIG AU YM Op O} SUTYJOWIOS PRY 11 MOU ] SUIBJSUMOP SION 0} dJISap sIy Sunjeydiusjuos Apeolyy JjssAu 0} JYsNoy) | Alp spieu AU Jo] 0} BULL JOOJIOg “SOINUIW Ud} UL SdYZJO STY UT WHY JOOU 0} SUI YS¥ 0} JJOSWITY SuIT[eo AoIpJor SVM I] ‘LUODIDJUI OY} UO pazznq Ajuappns sem | Udy S]ieuso) Au Sutjuied sem | WOOL AU Jo punoidyoeq dU] UL dIe]Q JoUURYS S.A LJ O} SulUd}st] Pog AW UO BUNS ‘ouvlstyH pure Adio UVM YIOA MON Ul SEM |] punose poyjos Avp Iq AU UsYy A, —“poos 1OF FI] Sty} Out podden 403 pue Japjo Aue 103 | alojaq sayeoif1}I199 Aul 303 0] SPM PoUeM | |] W “JOA Jey} USJOUIU GUILIN] SEM | PUL ~ABMB Yoom B ApUO SeM ABpy ig AP ‘[esodoid 194} Jo UOTJUSU JOyJOUR JOU pure ‘pynom A]{EWIOU 1 SB UO UBM BUTYJAIOAS SYSOM MJ YXIU OY} JOAO “Apog Aur jo syed 1dpud} BU} SULYSTALI 0} SOATISWISU} JV91) OF WY} SUIMOT]e “SuryyAue jnoge ysnf 0} poos3e 9A, P[NOM | UI SEM | 9]RIS OY) JO SJDOJJo [[Ny oy} WO. *“ATAWIOD 0} DUI JO} plvy },USeEM ]T SUIUDAS Jeu) Joey AYOuNeI 0} AIa3y9 WO] PSU SPOOU! 119y} Udy pue Hi Suidin3 sem | ‘Jysiu yey} susedureys ay) Surddis 1. useM | “YOOp dy} Wioly YOR 103 9M SOUIS HOI SUTOTNS ud0q pey | Ajorxue Jo s}JUNOWMIL YSIY 94} YIM 3dod UdAd OF XBULYX Jo asesop oy} s]qnop udye} pey OYM oul JO} JdooxY “9/qQe) JOUUIp sy] punoe poow A1d9y9 B UI YIOg d1aM Ady} JYBIU JeY) dJeIG9199 0} UOSKOI YON] “SOYSIM JOY) Pol[F NJ pel] | Sooes JI9Y} UO SUOISSOId Xd DY} LUOIJ 1NG PNoOy INO Aes ow IedYy USAd O} AZBIO SEM i. J0y}e30) Aqeq Be Suraey ynoge xUIy) [[e ]],oM 19K ]xou Udy) AYIeay }o3 puv siy} Joy asedaid 0} du] SUIOS SARY PUR OSeSsEL UI S3}BOTIIOS AU 103 OUI JO] ‘JEYM MOUY NOA,, Way} po} | uoNINjur s.jnd Aw dn Suryons pue sovy AU UO J[IWUS 199k UL BUINN, “UMOP LUD) Jd] ISAOU P,] IVY} BUT[IIJ dy} Woy} SAIS pue Bulpaoy A] sem | JeYM puoddg OS O} peyY | ‘YyJVoIG JUSTIS B UT YOO) pue AjSnoArou Jey AW Ysnosy) puey ATW PoHOIIs | ., MOUY },Uop isn] ‘MOM “104 SPTY BUIALY NOR JYSNOY} UdAD AT[OI JOAOU pue SUNOA Ajjeol W,] UBdTU | ‘S,ANS MOUY ),UOP | ,, “SU POARS Jey) UOT}OvAI JUBISUT UB SBM HI INQ ‘Aqeq B UOTE 13] IU JOJ 910}S UI PRY SIOJSUOLI 989} yeym Muy ATUO POH ‘Aqeq 100d Aue 0} Jey) OP | ppnoo | ABM ON “amsue AU MOU Apealye | pue AVME JYDIVIIS JJO JUSM S][OG WIR[e [BUIOJPUI AIA ‘a]doad asayi yIM osnqe puv IPN}IAIOS JO sJI] BO} WIdY) JopusLNs pue pooyjq Ut YSa]f UMO AUT 0} S}YSL OY} ysinbulfas 0} SAY AT[BOISeq P[NOM ] Jey} Suisevsy jou aul YM ABMe JOS ppnos sys J1 se “ApyOINb oJay} us suo }SB] JY] MOI] JO PULy yg ,-NOA JO OM] dy) USOMJ3q INO BUT][LJ B JO JUDAD dy} Ur Apoysnod s, AdIjJor Ul SuOjaq pynomM pjiyo uy} yey} pue snowesouow 879 $0 Tzgabed ‘0€Z8z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVYLLNACRINGO [eMart poysejoa,| wyBUAda’) [5

The text on this page is estimated to be only 43.72% accurate

[etroOMELINID 8TT pajadivo pou pjos pue pas oy) dn Aem Aw Suryeyy ‘ojuoid uo dn yoye9 0] pey sys Jey} Y1OM Joded atuos 10J youq Avls 0} PeY SYS “SOLO SIY ul Aadspjar JOaW O} PIJONYSUI SBM | DIJO S,SURISIYH JO NO 403 | USYAA ‘Q49Y}] TSULAKIS 9Q P[NOM dYS sojep yeYM pue UI SBM 3YS WOO] dy) ‘Suysaui oq 0} pasoddis sem | [Als oy] JO sUeU OU} osye Sem 9194], ‘SABM JAYJO UL OPIS FULL JOY POMOYS SYS “ples | dxI'] “OW dAvS YS }Sl| 94} UO SFULY] SLUOS SUOWL 319M SUOTJSO] UOIUN WIdjsom puke SJoquInu AQuasJoud ‘s}, UOG puk SOG ‘UNS 94} JOopUN sUIZSeWI PlNod | Bury AIaA9 Jo} ou paddaid puv yaom Jey] 1S9q-_pIp SYS JeYM PIP sueRysiyH “yes1q Aw A]jeulj “jnoqe tuevaip pue jnoge y[e} NOGe YUIY] Pynod | [je sem J] “Jjas swosauo] Au Aq [[B UOBUNSOp 310x9 Uk O} Jo Suyjol aq p,] UoYM Yoo }XOU [QUN PVM } UpfNos ysnf | pue yIOA MON O} IWS UWoOYs e& A]TUO sem J] ) 07 ta}deyD “}[{2Y BuO] S[EUIWId) oY} UMOP poJoYjANy ] SB JUSS AW JO NO Poysiuva oy pue oBplq AeI-x 9Y] JOpUN SSTy ISP] SUC “Wily JOJ py | SFuraojy Bururewss Aw OJUI AIS O} Pey J pue sulArO SUI pRYy oY pud dU} U] “JaYy}O YoRs WO] AVM SUIT} SITY] Je YOOT 07 SABM ousttundo uny darts 0) Sundae ‘AepAIoAd Wy jpeo 0} AY) p,] WY pyo} ] ‘AIO WIY Bulsas Suryzeoiqyivsay JSOW]L SEM JI I9YI9IO} SUI] UI POo}s 9M se pue sojed Ajlinoas oy] Aq 08 0) pamolye sem oy JUIOd JSoqJINJ 9Y) 0} 3 YIM payyem OH wel Ul odie oy) “YIJAL 0} SW YIM qed B 1YsNeO [ ], ‘auoAue JO WHY YIM [Bop 0} dAey J, UPyNOM pue JJo sem | Ap }xXOU OY} ‘JasAW Pjo} | J9}}eW }, UPIp J] “WUIY PULYydsq JOOP dy} potuWeE|s pue MoOTid e dn poxsid sy pue VW 4OJ dn },useM | WY Plo} | JJO oq P,sy 19}99q Oy} ‘JeU) PSZI[eoI SY I9UOOS dy] pue 1OSUo] Aue LUIY JOJ JY) OHI] [99J 1, UPIP | “AyTeNxos ow JOJ Suryjou PIp yf ‘opisyoeq Aur Suiduiny AIp pue SsdUurYyJOU J9OMS YIM IOTARYOq SIY WIddPd1 0} PI) pue 1YSIU yeY} Jo}e] poq oyu 3doI0 [J “sUTULIP UONLIQI]I9 Jo dduIq AW WIOI JOAODOI AT[NJ 0} JYSIU yey} S91 SY] papsou [ pue SuIMIOW! 9Y} UT OW JO] p9xOO IYSI[J [RIOIOMIWIOD B SBM BIDY ‘diy [euly AW 9q P[NOM Sty) JY] YOR MON O} INO MOLE | SIOJOq 14 SIU oy) Mouy Apeolye dys axI] sem yt ‘SOAS AWW UT dn SUTT[OMS 319M JY) S1ed) oY} UO yor poyoyds | “Sny Fiq v IOY BUIAID JOY Poao] J YON MOY JOY po} pue Suo] 9q 1, UPNoOM | Jay SuIsiwoId Sem | “pip sAVMy]e | Jey] SUIYIO[O JO JUNOLUL SNOpUduOY dy) Buryoed sem | 9[IYM OsedyINS AU Popeotieg sys Y[eM BUC] dy} WOT yoRG 103 om UUM “PULYSq DUTARS] Poyey [| suo ATUO dy] sem sue ATeJAY “SUOT dq 0} SLUT) SUIOS SU OAIZ PUR UONENIISs oy) UMOP Leo O} FEM eB JO} 19y YOO) pue pes] oy) uo Sop Aw jnd jsnf] os swy TWILNACMIINOS Jews] powojorg yyTAdog [1 oszPoomaAANIoO LYy UI jUIOd siq} Je Op JO Aes P[NOd | SuryjoU sem s19q] ‘UMOP Xo]{dUIOD sINUS dy} SurjNoys ‘sIOOp puv sy[eM dy) Bug ‘juousrede Aut J9A0 [Je wanzyuel dn uMoid & SUIMOI] ‘][ 1B OW YIM ddISe } UPIP 9H “BUO] OS JOJ UOT SUM | O[IYM Suruaddey SuryJowos Jo YSt1 OY} ULM } UPIp | plod SUIALP SIY| SUIMOULY puke Fury} VY} JOJ oouvsnsur uo AouoW yontu 00} pred | [ye ye ‘yon. AU SALIP 0} JOU SEM dY JN ‘OUOS sem | TIM JUOUTTEde At 4B AvYS IY Suljjo] YSNOUS juddNp Furoqg sem | JYSNOY) | OS Ulese poJapusl 3q Jaaau Ajqeqoid pynoo yey) ysNyy ‘sn UddMJOq ISNI] UdYOIg JO JUNOWE osny [US SBA S19dY ] “WIdY) JO 9UO SEM SIU] Pue JJBSAUI IOJ SFUIY] BUTOS OP 0] popdou | peziyeoi Apeosye pey | sivoA Sunod At ul jnq oJe}s a[qviaulNa B yons Je UTTY SAVI] 0} BUIALY O¥1] 1, UPIP [| pue poos Bulusloo sem oy DAI] Wdas 0} Burpseys ysnf seM OY “WHY NOYM puRzeYy] ul Ayed dojys-uou B SARY O} WIY SUIAL] aw JO Bap! 3y) payey OH *},USeM f°] ‘atu Joy Addey A][Bo1 SPM OYM JUOAIIAS JO ING “s1adseUsd} SuLNys Asdiy Apeore Jo dno1s B oO} SAeM JUdIayIp Auewu ul yey) uTe}dxo 0} Bulaey Jo Julod oy} JJasAu SARS ‘SARMAUB P[NOM | WY) Pjo} | yng ‘ojdood Surpreuis s9jnd wos eB uO BuIjIS NOge SulyUIy) 9q 0} UNF YONW 00} SulAey Asnq 00} 9q 0} BSuios sem ] ‘Wy48nou) | 1YSU yea “yonoy ut doox 0} plo} puv ssouppe jrews spusLy AW JO ][e 0} SSI] SY} USAID SEM | “ARG S,A}eq IG UO URWYS] Ue UMOIP O} YSnoud udyxUIUIpP pey | YeeM sy} JO pud oy) Aq pue Aqred JoyjOUR sem ]YydIU _ AIOAG “JUIM | 91OJOQ YIM dn yo}ed 0} SpusLy pood Maj B pey OS]P | ‘sompunqoddo yysy ay} 10} Surdoy jsnf{ sem | no pouueyd Suryjou pey | ‘aw JO} poy oinjnjy AW JEM MOU } ,UPIP | ING j[SLWUOS O} OpRdop 94} UI WOT} SSILU PyHOM | YonUT MOY PUL Y}OG Wd} Peaoy] A]]VoI | yONwW MOY sIsyIOIQ AW 0} poziseydus dA, P[NOM | Wd} JO Auk 99S P]NOM | SUIT} IS] SY} 9q P[NOM Ji UMOUY AjUO P.[ J] “Way Joquiswol 0} Aem yeors & ‘puNoIe Woy} JO ][e YM J9y}930} Jo38 [hjJapuom v sem yy “Aed 0} OARY PjnoM | MouUy A[UO | JY} JSOO B Je StuvdIpP Aw JO asinod dy} Apn}s 0} pred summed pue susa} AW Ul pyloM ay} punore Buijs Jol seM | 919} “UMOP ou po] pey Aowinof Suoy Aw s}oadsoid dy] 18 payxoys powises Aypiwey Aw ul suOAIaAq ‘ounpedop Aw jo Dulysim [[2& 9Y] JO} WSTA 0} UMOP SUIRD UOAD OJIM STY PUL JOTOIG IPO AW “ABMB DWT] SUOT B YONs Jaye AptUeJ AU 998 0} JBOIT SEM J] “J[OsAtu Aq [eB diay ysI1J AU UO SBdSIDAO YO] | V1OJOq ATW] AW BUTPISIA SpuNOs oy} oyeLU pue dia} Zuo] OY) JOJ youd 0) YOM B IOAO III] B JOJ SULOY JUIS SEM | “spuelliop IT9Y} 1B [20xd 0} Jsdq AIOA AUT ZUIOp pue sem | say Inq AyUnjoddo 94} USAID JI ULVGE IDAO UISOYD 9A, P[NOM J] SIOAO[ALWWd JO SdIOYD JOBX9 OY] JON ‘00] SNP [LJUSW II9Y) SUIZL)] WO 9OUDdIOFJIP aq} Ss yeym AVM JeorsAyd Jayj0 AIDAd Ul papeisap ud9q peY | “IYsnoy) | sAeMAuR J9}JBUI JT PIp YAM ‘uoIuIdo Jo SxS MOY} JO} pjnoM | Mouy Ady} ‘WY YIM 3013 ] UPIP | Jl uaaq ‘skem Aysinb 19y} JO Mo} B puRysJOpuN 0} ud}09 peyY | ‘Woy YM juads tur) sy} JO []e Joye Inq 9]dood sues }sOul O} OSUaS SxBW },US9OP 879 $0 czgabed ‘O€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVILINATCTLINOOD OHA possjoa,| wsAdoy 2]

The text on this page is estimated to be only 42.19% accurate

es ZroORLLANID TVILLNACIINOSD ZSTPOONAAANIO © TWLINACLINOS [ela] posjoig yysuAdog GO [VLIoPY poyon0s,f WYSAdOD | OZL nod YURY) ‘9sINOd JBOIT B YONS S.}] ,, 0} SULALLIB 9q P[nom J SuIWODSUIOY UIR]I99 DY) JO AjI[LOI OY} puke UOOS WO SYBMP 0} ALY | WRIIP oY} JO OU SUIPUITUDY “YORtuoys AU Ul JOUY Jere poystm) & ynd ssousoses sty _ UJUOW JXOU SOYSIULTJ SsINOD INOA SB OOS S¥ SUO ISI] ATW IOJ YIOR MON 0} YOR IYHIVIIS SUIOD 0) PoyOog NOA 405 9a,J “NOA WO odvssew rey], JSIIF ATW 49S O} JEM 7, UBD ],, YIOA MON O} JORG sMIedap Aw Suyedioryue sem Adljjar poysiuly asinoo Aw [UN YS] SWI sy} UMOP SuTUNOD ‘sseio UI UOISSaIZOId puK synoqeoloyM ALU MOUY WY} SUINS] sUB[SIYH pue Adijjor YIM UL YOOYo pur ul [feo oO} pey | Apounnoy “ysed Aj ysnf 0} pauses J] oSesseyy rey, Sud] OJUT yRoYy AW SuNynd pue umo AW UO OTA 3]qQiporioul ue yons SulaepH ‘Aq au possed Ayyornb ur yuOW si oy yf [JOM SB} WIOLf SUIJOUIOS Sululed osye SBM | Udy} DUaTIOd xd a]qeyesIJOJUN ue AT]UNODS OY) JO JNO OUI) ISIL] JOY ayeul djay pynos | JI pue jars soiu Ayjeas e sem ays shyg ‘sAemAue WY} JO Om] pey | ‘ULOOl AWW UI pad B Jay poidjjo pue Yt ynoge JYyZNoY} | OS ‘Jaspnq [JEWS 19y JO JNO YONUL OO} BUIWIOIA [[B SEM JI ‘UOT}RPOWWOIIB J9y JO do} uo yooyos 10} Aed usy) yysiu Arana Ayred 0) AQuOW Jo yNo SuruuNs sem ays ‘jajoy Aw ye aw YM Avjs 0} JOY BuNiAul dn popus usaa | AT[enjusay ‘OPIPYBu iw -Bulveyy dy] Jo sjods joy dy) punose Joy Suimoys poap poos e& Fulop sem | dl] 9p Pudtay JOY Surwoosgq os aft] AO Sulpjsng ay) 40 [ye Aq YOuge udsye} aI] B SBM OYS Jey] OsSpo;mouydse 0} ASK SEM }I OS JIL IVY} AOJ J[OS]I UISUODSIAA, JO $3}BIS OY) SUIALD] SUI] ISITE ISP] “JUS90v 1NoO UMBIP BuO] B puke sada Sop Addnd umolgq S1q WWM [IS SULOO] uiejd B SEM SYS “UISUODSIAA LOL [JIS suO ATUO YIM SPUSLI] opeul pey | Ssejo a11jUd dy] JO NG ‘sayoeoidde siy Jo 1919 199}s puke INO dUO Jods 0} 9]qQe 9q O} LUSY] JO ILUNAsI] B YUM Yeop Apeslye pey | ‘WIs0U0d AW JO 9UOU aIOM SFvQazZeaS Jy] Jed JSOUI SY} IO} NG ‘SOANOW JOLIO}[N YM W3y) JO SWOS “Way) Jo Maj eB ayINb YIM Spusiy opeul | yey} sstudins ev },uSeM }1 So[eW JO [JN ssejo e ul AsOpy ‘SUOTLSUOWOP YIM SIBYIO dy) JONUYsUI day oO} SUI FuISN SEM JOYOeD) IY] SSL] OY] Jo pesye Apeolje pue sJedA MdJ 1S] 9U} JOAO WOLL SSBssetU Ul sdUaIIad xd AWW JO A}l[IGIPssd oy] SULMOYS “UdAd Jod SIDYOVI] BY) [IIS poosd jeor ve sem | AVp oy] BulING “00} posn jos AToUTop Pinos | uonnedol ev sem JYySIu AIDA0°** AVpyyig AW sem 31 OyT] UO SulAUeS pue Aem Att Suoye §, WAY S,qnyd AOA JO }¥aq OY} O} IYSIU [[e Surouep ‘qusedtueyo jo soyoq Suiddog jjYys sem | pue UNy Jo JOT B 9q 0} SuIOs SEM PURTILY | MUX J 919) JOS | PUOSIS OY} WOT “WYSIU JOAO Spudty }soq otueoeq ojdoad pue SurusJow ay) Jo sinoY 99M OU] [HUN UO pases soiied oy “syiids years yons ul sem pue Ajsojj OS Pdal] OUOAIZAq “SyORUY -YOIUY PuR “BZUIYIO[S ‘SITUDANOS JO JUSTUIIOSSE UL SULIOJJO S]feIs YIM Poul] 313M $]dd1}S SY] “OIOJOQ Ud9q JOAD pey J VIOYMOU dyI] SEM J “AWIO Sulpsny 34} Jo s}ods JOY OY} PULJ PUB SIDI9ARI] MO[[IJ Maj Be YM pojulyenbe JyasAu DYVUI O} SUOT OW OAL} 1, UPIP II ‘pspuR] | PUODSS SY) PojIe}S SUOILIQS[I9 AW jjl@W-Sueyd sud |] siay osned0q 1]}OJUOS INOA JNO MOI] 6TT ‘yyo ojdood Auew ‘Aueut ‘Auew Aed 0) ASUOUW JO JO] B 103 $,dY asnedaq []B S}JOdI}S OY} JJO siojYySNep Ino smooid pue A[ddJ1j puNoIe FEM 0} pamoyye ose AdIJJor SAI] SHoAIOd se Buoj SB JO UOOS dT} AUR SUISURYS 99S },UOPp | puke sn dJOJoq satInjueo Auvlu JO} Ud9dq SPY UONZTIAIO INO AVM OU} SI AfoJBUNWOJUN ynq ‘opnyiAsas JO INO SUODUIOS 0} Fuozoq pyNoys [119 ON “JOY OJ ALIOS Jooz Inq djoy } UP[NOD [JS | SpILG JO JSOOIU DY) },USEM BYS YSNOY} UdAG “UWITY 0} BsO]d OS du jday Jey) SUIEYD dy} JJ 0} dS]9 SUOSMOS pLY AdIpJor “BUO] 00} ABM IOJ d1OM | JeY) SUTRYD OY) WoIJ JO oJoy WOIy AeMme Jey “Jel sINJUDApPK Jayjoue UO JJO dq O} SUI} AU SEM II 19YJOSO) SUOISSOS Maj B Joy “Soho AUT Ul BUIUIELIOIUS JNg SUIYIOU SEM WSedIO poyR] eB SulINp uoNouny Apog AlaAad JOY INO WedIDS puke UOTONpas JO JOR ue UO Ind Joy SuTYyd}VM Os dAOId 0} d1JOW SUIYIOU pey | ‘Apis saAtWOdWIOD Joy AuUNs oJiNb sem JL ou O] “SOUT MO} B BUIY) UMO JOY OP PU ISAO SAK] OF Pod] oYS SB OSeSseU OY) SuluNp peo] AU MOJO} O} JOY Po) Aatjjor UdYM IOW USAS SW pasidsap BIPEN ‘JO W. Surysturyy JO apis s019 oy) pue Aoyyjor SurBesseut ut sonbiuyoas AU JO 3UWIOS I3y MOYS 0} Yse} AW SBM J SABP JO ASINOD 1X3U 9} IBAC ‘Tay oyly 07 gol Aury,usem 1 sABMAUP P[NOM 3UO OU jNq dt yse 0} SEM BUOAUE JI YDTIQ RoI Y “UONDIAaIIP JgyjJOuR UL JJO PRdY ATUO 0} JJO SW QNUS P[NOM sys ‘INO poyRIs [Je am ABM dU] ‘piom AISAd sty JJO SurBuey Asnq },UseM oyS IO JUSWIOLU ST} JOJ ABMe SEM JY Ud AA “99S 01 AdIJJor JOJ MOYs kv ‘Jey Jsnf sem YF yNQ AytuOsIUN JO MOYS JoLIG B JOJ passny dM ‘Jf 1vOq Ppuv ULIS 0} ySoq Alu SUIOp sem | ‘oureu AU Joy SUT][9}] pue SyddYO Sy) UO JOY SUISSTy “ORI d ISI OY) Ul OW JO} poled A]]ead JOADU PRY MSUY PUe IOJ SSul[s0J SJBLUTJUL PRY JoAdU ] QUODUWOS JOAO SSOUIA}IQ SAvY | Pynoys AyM “fjasAw O} JYSNOY) | WHY 104 poor) ‘Wiy dy!] sUOsUOS JJO payoodxs sem siy] MoU ApBodye aw Jo Wed B Osye yng paoeidal A[Isea OS BUIIg ‘94k] O} MO] B JO JIq B SBM }] ‘Puodeas UO IO} JOY JJO SoAd SIYy SULYR) Ajoleg “Aeme oq P[NOM | aTIYM osnasselw pure JULISISSE MOU SIY SB JOY poonpowul 1ayyINy Adios “SOAjostusy) spidno 9} ING dUO OU WIOI] MOLI YONIJs SAO] & JO UITJOIA B SB UDIITWS se Jnoqe isnf poyoo] Aodjjor pue PAOYUTOIL] PIPEN SEM LULU JOP JOS] poyesoid JUIIOB Y99ZD YIU) & ‘SUI 0} J[SSIOY POONPOIUT SYS UST AA “WIAIP JOM § Jossajold aBaT]Oo pO dy} SAI] PexOo] sys ‘asvavoyo ojdure snomdnyjoa Joy Suyeoadl ‘asnolq UMOP pouoyNg sym Joy J9AO JoyoR! yins Suryoleiu B pue YIys AdI3 1YST LOYS & YIM [JP] O] Possop seM oYS pue stul09d 0} SSOUTYSOY9 Jay JO S]UTY YIM WIY Je SUTYseY SBM dPIUIS BIq JOP] OUy ZUTYOO] [euoIssojold e& ul dn pajsim) Jey Spuoyg YIM [AIG [JB] B SBM OYS ‘Iopjnoys $s, Adljor JOAO SUIPUR]S SOR] IeYIUIeJUN ue SEM MBS | BUIY) ISI dy) SIOOP AAvay JeTpIWey asoy) SulusdG ‘yyBnoy) pey ] Os 10 ‘AjIsosDUDS jUddOI STY JO} 31 BuNoadxa aq prnom dy ‘1Jo] | 0Joq dn Suryons Jofew suos oj JjasAur posedaid | asevoseys 879 $0 Ezgabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUBWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 41.85% accurate

SecPOORELIND col Sem | ‘JUBINEJSOI OU} Je IWeYS Aw yO Surzind pue 100p 9y) Surpyoy ‘opts JOOMS SIY 99S 0} Puby J, USEM JL A[S}VIPOWIW] “WUIY PRdI 0} AsBs Sem J] “UOT jeJUaptooe Ue ][B Sem SARNS PUR BUTMURYO BUISg “WITY JO IYZIS ISITJ OY) 1e OJ | WY) AVM IY] JOdJ SUL SYVU PTNOD OYM JOJO OU SEM dJ9Y] MOT [ pue QOJOq JOUL JOAI PRY | LY} WY Syl] SUO OU SEM SIOY] “I POAT] SY YUIY) | puv uous}? poprarpun Aw pey oy Mouy oY “JUeINe}so1 9Y} UI UOSIEd IBt}O AJUO 94} Ud9q SALY [JOM SB JTS Sy SU COL “9x09 JO S,uvd OM] PUR ezzId 1osadad fo did B 19A0 199}9q JOY4IO YORd MOUZ 0} 309 9M AT[eENPRIH ‘PIM AJDINFOSGe SU SAOIP JVU} JUDN9B aIssny Jsojnd oy) pey oy suoysonb Aw Jo Avie SY} YORG poramsur oY UdYAA “POAO] | Jey} OSNOU puke 4d Jo owed v ‘OW UlOIZ ABME JOLIN) SUIAOU Aq aseyd STY Panuljuod oY sp WOYs sq} UO UNITY O} JASO]O Puk JBSO]O SdduUy AW BUIOOSS “dIQGOoY 0} }XOU 4eS | sins ape | a1dy} AVM 3Y) UO YN}-yN} Oy) UY “AOdUR.YS SuT[eodde sy} 0} UMOUY JJOSAW DyVUI O} [LOS AW ji OPW | “YORVUS JYSIU 9jR] & IOJ SUIARIS SEM | MyM [30H SSsoutg dy} JO jUOZ ul ULO! ezzid oy) 0} peoy F[e om Jey} pajsasans | ‘Ys dy) WoIy dn pdAadi Ud 3y} JO [Je pue WYSE 94) IOV [[e JO UoTeUIOse] yg dINjOsqe ay} puke poo] ay} ‘yeams oy} “pjojun Yyouem 0} SuLINTTe Ajyenbd sv sem jt 1Nq Yd dy) poynI USWIdABD OY} USYM SAEP dy) JO JNO 9udds SATII B SuIyoVM dxT] SEM }] “JOJ Buleg sJom Ady) WOYM UO Sulpuadap uoneulwussip 10 Woddns 1194} Ja}Y4SY Joye SULOJJO Sul ou] Ul SIOJYSIY SY) JB SUIWIEDIOS “YIOZOq BUIOS 19M US SY} pue poyE)s IYSY dy p WY YUM UOHRSIDAUOS Aue JOJ YIOM SUL SuLyeU ‘199 0} prey poked AjAOO By pedysuy “MOU UWI BULAIZ sem | SOAO OY} 38 dunf pynom yey) sdop surdsey Jo AyMofew oy) yt] SUNIL },USEM SY USYM OUI Pd}So19}Ul JoYyWNy df uONSe.NIe JO Jomod sty 0} UMBIP A][BOTJOUSeW SBM J] OT] WY ffO Sado AW dxv) },UP]NO |] “yoIeM O} SUINSIQUI SEM URW TING ATpeoTjeTyIe S14} 90) 0} do} WOl] “WY Je Sulse]s dtu 1yYBNvo JsIlj JasueISs owWospuey si} 7} JUDLUOLU BU) 1B SBM JI puke Ssejo asesseu ALU WIOIZ SANS Sy] JO QUO dulxog mOopeys AyjnyAvyd sum OY SOURISIP ASOD B WO, UY SULYOIE MA ‘a10Joq MOUY O} QUOD I9AD pey ] 9x1] FUTPIOU sem oy ‘peas O} pasn | sayeyAMej oy) jo saded ay) Jo no jy Surddais ‘pmoso oy) JO INO pues wry spew ey} AIRATYS pue WUSLIOUULTU JO adeyoed SITUS SY} SEM }1 IYBIS ]SITJ 1B SNOTAGO sem Jey) peodde Suiapjows siy isnf},usem j] jt Surddojs ou sem ss9y) pue dey] Ati OUI JORIS JUS [[aJ AUTSOG “Ulede SUIKS 9Y} 9q JOADU PlNnom ] puke pIp 31 Inq Udy) pue diay) Ys usddey 0} 941] AW JO SUI) BuIzewe SOU! dy} BuNosadxa } usvM | “9fl] AU JO 1S9I 9Y} JOJ SW SAO] ppnom BY) URLU SY) UO SdAd prey | JUOWOU JsIT] OY} sem JI pousddey yt usYy TL “SUIYDIEM BIIM OM JBY] SJUSUIVUINOG] BULXOGYOIy Oy} JO} SuruIey a19M yey] sAnd jo dnoid J9yjoue YM dn Suyjsatu Jom YIM JNO Zursuey DOM IM JLY) SPUdLIF OY] “WOIy YOeM 0} 3OdS & PUT] 0} AJ] OJ SAOYS puke TVILNACIINOD [Cua] payoaiosy ySuAdoD OH PST POORAAANID Té1 ysnd sem }I BUdIe SY} SPISUT JOS [ BDUO PUR P[sY SUIOg SEM JYBI sy 9IOYM JO91]S SY} POUL] PMOIO SAISSELU SUT, “WOY) YM HI YdVM O} BuOlL sn popAul Ady} UOYM UNJ SAI] PopuNos jf “JUdWBUINO} BUIXOgyOTy ley -AenyA] & d10Jaq SXULIP suIOs JOJ dn Suyjoow som Ady], “SJOds SULYULIP 91LOAR INO JO dUO Je SdJBW SSPIO INO JO MJ B OJUL ULI OM UDYM OP O} BUIYJOLUOS IO} BUTYOO] Pur [Ly 0} PAssoip 319M IAA “UMO} OY) UY 0} INO popesy pudLy [IIB AW pub OW dJOJOq vIeoseU AU UO nd puke syasoyo AW poysnyq | ‘OU0D 0} JI] Mou AU JO SuLUUIdOq SY} 0} Aep ISIIF 9y} 9q Pynom YSU SIY] JOU OM JULJSUI OY) WIJ MOU pinom pue 0} pasuojaq Apeolye esy AU URW oY) “OJ yURDUT SABMIE SEM ] URW dy) YIM SpITJoo Ay[eotWsOd 0} ynoge sem [NOs AJA AU IYSIU sTy) SEM J] ‘aTqeidaoor sem Sutaatjoq 0} dn yysNoIg sem | d]AIsoFI] poaurojsnsoe dy} 0} LOYsS JJasAul pjos 1, upey | Jey) pue Aep oUO JUdIOJJIP 9q []B pjnom }1 1eY} SIRIS OY) YJVoUSQ SuIAID Jes | JYSIU Jey) UMOUY pey | Ys | "JYS1IUO} [HUN ‘Mou O3e BuO] NOge Ud}OSIOJ SEM SUIW JO UONRIOAU! SIU], (JOA POUIBRULI UDAD DARY P[NOd | UeY] JossIQ YONW SuIyWOS ‘SAQ] O} JUBSTU SBM | IVY} PLOM OpiM SI) UI APOQOWOS seEM 319) yey) Aytiqissod ay} sem suoAevid Aust ul osne[o AyUO APY “pood Joy Aeme 0} pjnom ured Au jo [je Joy Avid pynom | pyJOM [Indo Siy} WOT, 9 ISAL]9p 0} UY BUISSIg “OJ DUOTL IYSIJ 0} [[VUIs 00} IO} [ Je) oT}eq ssojodoy B yons Apearye sem ajly snolsaid AJAY “YJeop sem IO] WY poyse | [TV ‘siaAvid AU IBdYy 0} POH JO} pad | sv 1941930} APYysy possoid spuey Au YM MOPUIM WOOIpsg AW WO SIevjs sues 9SOY} 0} dn SuUTyOO] 1es | Jey) pltyo sunoA e [[QS sem ] UOYM MOU OBB OUT) DUO] AIOA B SEM J] “SUL IOJ SIV}S SY} UT Ud}IIM ApRoye sem 1YSIU SI) ‘Ajssaporeo Aeme Sumeyo sJoy) JES OM SB STIS SN .O} sUMOUYSQuN ysnou) ‘Aepuns 99e19Ae ue ysnf UO JOIN WOOIY}eQ Oy) JO JUOIZ Ul APLdI SUIIIS BDULUSAS ABBISAR UL SBM }| Tz 4a;deyD “OFT] UMO ALU JO PRI] II} DAL) OF POOD Os Jd} JI [AES JaUUT AW OSOO] BUI}}9] “DdIJ YEOIG puv jno 193 0} DouRYOD se] AUT SEM SIU} i Mes T APM oyu ‘punoisAeld Aw sem AjLO JURIGIA OY) PUB UI SO] 199 0} ss0R{d Jo ozeUl B SEM TRJA-SURY) “OWI JO QINQUDAPe MOU B SBM JYBIU AIOAT “OJOJO JAD uvy) Jopsey Aved 07 sty Aw sem 7] “3704) INO []HS sem | op1YM Siids Aw uo Jodmep e ynd yey} 39] 07 SulOd j,useM | ‘WY O} YORG BuIos Jo jysnoy} OY} SUNVH “JOM SB [99JF WY SALUT Pynom 71 Jey) [TOMS PkSY dy} PoAo] oy pue sw 10} sUOp pey oy Jeym pojelsoidde J yonw Moy MOU UY 49] O} peY | ,.jj2JOY JOAO SU) Sulzewe ue yons SurlAey wie | jastsedxo Jo eae MOU ALU DAO] 0} SUIOS DIB NOA “SIY) UII] O} 9194 SW Surpuss JO} YONwW OS 879 $0 yzgabed ‘O€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TYLINGICLINOD JRA, popsajouy suddog Fy

The text on this page is estimated to be only 41.22% accurate

LETFOUMELINIO TVILNACGHNOO 9$croorUrAINIO TWHILNACIINOD jeuseyy poposjosg yyBuAdo [) [Ea poys9101,7 1YSAdO’D || vel ay jnq 9du9}USs AU YSIUT} USAD P[NOd J sOJaq JOOP sy] JNO aq 1, Up[NoM dy 1YsNOY) Jey} SU UO PoOUMEP JOAOU 1 PU YIU] oy] WY Plo} pey ] 1ey} MoU ott Jo UONdadIad SIY 19} 0} ABS P[NOS J 3S[9 SUIYIOU YIM IOOY dt) 01 UMOP PdHxOO] | ,.ALIOS OS Wie | “MOU JOJ SAVY OM JLYM UY} SNOTAS SIOWAUL Jad 1, UBD SN UdEMI9q BuTUSddeY SUIY) SIy] MOUY O} poo NOA yng ‘19y]990} yUads ALY 9M SAPP MOIJ [NJJOpuOM eB YONS Jo1ye sty] Jo [[B Aes 0} ALIOS OS Wie | ‘JsITy LUTY SUN INd 9q 0} SUI JDOdx9 0] SUIOS Si 93s JO PUL [ 3eyp Ans sity ‘nod axl Appeos | se YONW se pure ‘gol Aur s,j1 ‘asta UOSOS 0] yoeq Sulos we | ‘mouy Apearye nod se ‘owoy yorg,, ‘s}ysnoy} Aw jadxa 0} papsou | Jey) Suruado joRxd ay) OWI SALT PUR Sore}S [NIYSNOY} OS J9A9 SIY YIM Sulsned pue surpyxoou Au Suiss1y Apjuss “ourpsiem Au punose suue Suos siy poddeim pure ow purysq dn payyem s1qqoy Ajorxue AU pasuas ay JLSYy “OWlOY YOR Pd] J IVY} aJI[ SY} JOJ snolas 00} ‘MOU SNOLIOS BuII}O8 SEM If “LU JOJ WeIpP B oq ATUO PfNoOd siyy MoUy | pue peoy Aw ysnolyy odedtuel 07 uedoq syysnoy) Ay ‘sdo} snourejunoul Aq pepunouns Adijea B ut A}19 OY} SULYOO[ISAO SBM 3] “AUOOTeq 9} quam | se Apog Aw punoie poddeim [NS 0M sjaoys poq 94} ATU “[[TYyO S, SUIUJOUL 9} JO SSOUYSIAF BY} [9dJ PUIOD 0} SU BUIOIJUS “SMOPUIM SWOO! Aw Jo S_.yeod ay) y8noiy) A]MO]s Os 0} URdOq osIIUNsS yUId puke oSURIO OY} UDYM SUL S194}O YORD Ul GUIAR] [[YS B9M IAM SAO] OI] d1OJaq psousiJad xd JOAOU pry | JeYM OUI SAIS P[NOM URU SIy} MOU ] Heay AUI JO SUIdALD }SOdd9p 9} UT “IOyJOUR SUO IOJ UOTssed s}qeiuspuN Uk YONS SuLeYsS SdAd $_JOYIO YRS OJUI SULYOO] WYStIu [ye yuods pey om ‘sn usaMmjoqg SJ9OdYS pdq dy} ING SurYyOU YIM 1341990} JYSIU PJIY}] INO UO | "sassy SulUlolpe AUBLU YUM SBUIYJOU JOOMS INO JeodoJ puke spleMIOYe Joy}od0] UMOP AB] Jayyerysnl p.dy “duo dyAI] SUNOS OW JURM } UPIP oY JY} Pue oARjs B J9SUO] OU SEM | OUI FuI[I9) ‘JI posnjos ay ‘spreMsi9 ye s[eyiued sty UBTS 0} yJopoysem ULIVM B 10J dn 493 0} Aayjor Aq pajyonsysul AJOUTNOL U99q pey | se xas ioe 0] UMOP UdAq “aJOJaq paosuoLiodxe pey | Suryjou oy] ULBBE SEM JUL 0} SAO] Spel dy ABM dU} ‘YONO} 19pus} pue spsoM sty Aq powuvyouy “UIIY JOJ s]quyieae ULY)} SJOW WOOT AU SUTYLUT “UISUODST A, 0} yorq Sursedap uoos sem pusiypsis AP SAeMAUB UMO Sty Je JoAaU sem dy SuIIAS “OUI ITM [O}0Y AUT 7 AIS DUTOD 0} WTY poyse | AYM ST YSTY AA “ass SUIIAUR JNOQe d1L9 O} WOOI [9}0Y AT UT J3yIO YoRe UI podojaaua oo] ‘sn 398 JOA pjnom Apoqou ‘[OoYdS Ul },USEM | PUe S}UOWeUINO] ey] -Aenyy JO} SUIUTLI] },USEM OY Udy AA “ABpr[oYy Weolp sty] UO Aeme SBM | OTT puodas JOYJOUR LWIY NOYIM 9qQ 0} Jedq 1,UP]NOd | ‘osI] apoym Aw wNY UMOUY PRY | DAI] SEM j[ “SUUOY Je OS JOdJ OU OPW Puke Ul dU YOO] dH "O0} POLUIO}SNIIE } USEM | IVY} SAO] PULY B YUM SW Pausope ay “puryaq 9}1] JEU} SARI] PUL JJOSALU JO SSOUIYIOM 94} 99S 0] SW SUISeIMODUY “OWT} SLURS JY] Je AJES OS JNq [jes PUR JoSedUI OS [90] SU BULFLUW ‘OU puNnole SULIE TUOIS Sty paddeim ay se UOISsedWOS pur YWIeM SIY SUI dABS ecl AyUO peajsul ‘usWspnf OU OU posJojjo a} “WUoTUYsTUNd paarasap pey | DAI] UOJ PeY | ‘OJOq IDA9 yey) 9y1] ASouoYy suoAuR 0} AdIpJor YIM sIvdA Au jnoqe uoyods pey | SW} ISI] 94} SUIOG PUL BUOIM SEM MOU J JU} OF] Au jnoge ZutyyAIOAD 10J UOdN UMOP poyxOo] pure pespni aq 0} BunuL Mm | ‘BSUINJAIOAD JSOWTe JodueIS STU} [[9} 0] poou oy} pel | sdpo;Mouy AU puoAd UOSeBal aTUOS IO, “]]2 ye Ayjoid yey) 1, usemM AIO}S WAIT S,OJ1] AWW Jey) SUOTIESIDAUOD [NJBUIUeIU pue doap Auew ysnory) no pulj 0} 103 sy ATjensed ‘puny ysnyy Ayoy sjusied @ WO UI Sunuos AQUOW pry Ivy) [18 soURUDJUIeW-YsIY poiods B dq 0} BUIOS SEM | 14BNOY) AT[BOeWO Ne sy dU JO UOTSSSIC UI YSINF SIH] jl 0} poreduos sovyed jeAol & St STU} “SULAR}S W,| WOYM 99s PjNoys No A,, "J2}0Y 9) JO 1099p ysod dy} JO 9d1}0U YOO} 94 WoO! Au Oo} dn JOeAaTa BY} ul Soioys Aueut oy} dn ABM OU} [fe BUIpIWIG “IOXUIS puR UT] ‘Yoo passeus sem | MoUy Apvalye 3]4 “MOU [OOD 198 puke AT} 0} OU JO} paou OU SBM JOY J, ‘yTeoY AIDA AUL JO 9dUdSSO AIDA SY} PoyBAtdes MOYSTUOS nq 1YysIU 4sP| you A[UO pey | JOdULIIS d}9TCUWIOD SIY} SEM JUSWIOW JY} JOJ YO] SVM 18} [je pue Aeme pope pplom agus ojoym dy], “MOU SUI JO JUOIJ UL BuIpurys SUT] OS I9AQ BULYOO] SBM dy 91dy} ‘Suoy Aep je JO JYSnoy} oy} sutureyojua dojs },upjnos | uossad A19A dy] sem Aqqoy {2}0Y SY} Ul SU JOJ SuUIIE A jit Jo Jooid Suryyem AW Si 9H “MOU I UL SADI[9q Inq djay },upynoo | ‘uesy ie doop o1URWIOI ony} & INQ *,.JYPIS JSILJ JW 9AO’T,, JO 9OUDISIXS 3} Ul POAdijoq OYM UOSIad B J[ASAU SULIDPISUOD IOAN “UOTOBIYe jUR}SUI UL YONs Sem I Jey} SVM SIOU USAd JNO aw UNds jeyM pue ‘ABM SIU) [9dJf OUI OYVU P[NOD Jey} OUOAUL SSOIOW SUWIOS JOAO | PRY JOAdU pue usw YUM soudIOd xo UT oseYs ey Au URY) SIOW pey | JY} MOU 9Ys PIP dp] ING ‘aJOJoq INO ja] UDSQ JOADU PRY | YUIY] pynom ou youu ysnf oy QUOAUR Jey} OUI BUI[[9] ssouYsIpis AW ye SuIysne] sem oY “dJOJOq IYsIU ay} jnoge dn ynys },Up[Nod | pue ;OOYSS Joye prp AjjeNsn am sev JaYyIO30} yorq YNI-yN} & JOS | pue puUdLyId APY ‘O1OJOQ SIY} SAI] Asya 9UOAUB JO s}ySnoy} jue}SUOd dy} pue YOVUWO}s AW UT SoTIN}ING JO SutuNys OY} }[9J JOAd 1 ,UpeY | “JOY YIN jOexs sy} WO IV} },USeM JI pur JOJONUSUT PO dy} IW YoRQ poprws | , AjjeMoe pjIOM 9y} JO do} uG,, ‘[Jan BUI[IIJ SEM | Jl OW poyse pue souLWUOJIed AUI UI BOUSIOIJIP & PsdT}OU JOYOed} OY} USAD UOOUIAYe 1VY} Ssv[D JO INO poyxleM | SY “Ulese JYSTU yey} SIQGOY BUINS 9q P,] USYM JNOGL Po}IOXd 00} “prp A][EULIOU | S¥I] DILIJUSOUOD 0} 9/qQe JOU jNq [eNsn se ssejd Alu popusyye | Ap }xouU OY], “QA0] JO Hid doop e O}UT Tule 9OIJ SEM ] SUIU pnojs UO ZuNRO]y “Wood Aw oj dn AvM AW Buns | ‘JYSIs JO No Ajjeuly sea oy Udy pue Aeme poy]eM OY SB POYdjM | SIOOP BUIAJOAII S_fo40Y 94} YSNOIY] SUE “SEM OL JUSIOJJIP puv JUaJaTfIp J[aswry DAOId 0} poyURM SY ‘JVY} 1OJ 941]0d 00} seM oY ‘ON “JeYI dy] SuryyAue JO JYUSIUPOOS Ssiy OU SUM DIOL, ‘UIese dn yoo 0} SUR[d Ope am sIOYyM J210y AUT 0} JOdN]S DY} SSOIDR OW PoyjEM ay ezzid Joy “Ud}} IWS Apeaye 879 $0 Gzgabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz2 JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 42.60% accurate

os TPOORILINIO 9cl Ajdai jeuty pue A[UO sty pue UL YUNS SMU dy} 0} UONORII STY J3}e] Spuodes MOB ATUL] “WHY SUIS} Sem | Bury AIDAS Jnoge WYSNoY) sy JeyM wy yse 0} pey | osuodsal aUIOS J93 0} PUR PIM UNI 0} UIZ3dq s}ydNOY) AW spew puNosS Jo s0uUasqe SU], 193990) Juads p,dM SAP MI] SUIZEU ISL] 9U} ISAO UY YIM SAO] Ul ATPRW UdaT[ej pey | MOY pue siqqoy inoge wTyY {>} O}] UO JUSM | ‘SOUSTIS STGRIIOJWOSUN dU} SUIPPL UOTVSISATOD SWOS OxeU 0} SuLAT] “pus 13430 dy} UO BdUdTIS B AjUO UdAIS SEM ATd3I ON ,,h)1 SASTIOG NOA ued jPaWiew Buyja9 W.J,, INO poweoios Ayyeury | ‘sous; suoyd oy) ysnoiy} juswiay19xe Aw uo ssed AjsnoiseUos 0} SUIAI] ‘JUIod 9y} 0} 199 pue dn Almny 0} ou pojuem jsnf ay Jng Sulpuejsispun oq prnom oy podoy | ‘yuiod siyj yyun dn ow Joy suop sey oy SuTyIAISAS pajerooidde pey | yonuw MOY WM Sutuursag “jaids posedaid Aw wiry saved pue Ayyemusad odeino0d Aut dn pasaysnu | nq yynou! AW JO NO SUWI09 0} SPIOM dy) JO AUB Jas P]noo | s1ojaq Buisned ‘Buu pay) dyj uo suoyd dy) dn payoid sp “soso jeuosiad $s, Adijjor 0} paudjsuel] sem { YIOA MIN UL SOLJJO sty BUILD ‘wy JO yonu 00} Suryse Apeolye sem | MOU SW JO ed I9yj0 3Y) ING UOTOOIP s,ayy AW Ul adueYS USppNs dy} pue sw Joy Addey syqVI] B Sea] Ie 9q P,sy Suidoy sem OW JO Lv jl Op puke pesye Os 0} pey snl | “ulede ISAS WHY O} WINS] 0} J3A9U “WHY SULARS] SVM [ ‘POO 10} 11 JO JNO 3993 0] sOURYS sUO AU SBM SIU] PUB WEY YIM ISASIO} ISE[ 1, UP]NOd | ‘Jt Noe OF 0} ABM 9d1U OU SEM SIOY ‘][B9 07 jNOGe SEM | OYM ULTU ST} 0} ABs PpNom | JeYyM SuNeidursjuo) ‘SSo1]SIp Ul paq AU UO Jes | esodold sty Jaye yaom eB Apoexo ‘sAep USAIG ‘JO W0}}0q IU} YORI ISADU PNod | Jey) SBulids daop jo urejuNoj e& dy] OOM Sd] sly ‘youanb 0) sjqeun sem | IsJIG) B Oy] ‘Azedo ou SUIALIp WY Jo Ysnous 99 0} 37Qe ISA3U SEM | JOO]J BOURp dy} UO dn yesy Wy SUIyo}eM pue WOOL [3}0Y Sy} 0} J9eq 103 3M 39UO WIY OP 0} JEM },UPjNod |] ssury) dy) JO eB pasadsiym | “Aq 1ySiu YoRs Jaquiswial 0} ZUIYJSUOS IOYJO YORI 3AIB 0} ]NO 313M 9M ‘SINO SEM JOO] IOURP dy) “JYySIS UI JayJO YyoRs YIM AJUO ‘Sqnyo JUdIazFIP AUB JB IOO]Z DoURp 34} UO SuruUTds Speedy Ino Suipuas pue WOOL [a}0Yy ATU UdaMjOq SUIT] INO Burpusds yYysIu AIdAd SuNeIQs[39 Ajavd uoowAsuoy Ino porteys oA, “Ysnoy) pueyssojeq yoom omNUS SY} SUIJLIGSTIO 910J9q JON ‘AUOWII9D9 SY} P[OY P[NOM 3M dIdYM SPI9Op © 0} SAY }XOU PjnoOM om ‘Aep SIG 3} JO] Ie9M 0} SUIOS 319M 9M JEUM UO Papas 3M Jd}FY “SSoIp SUIPPoM [eNjOe Ue SB I JOUNSIP 0) YSnoUsS suo] jNq URI] [[eWSs B YIM UMOS BuIssnyY INST AreJUSWIT[dWI0d & ‘ssoUysojs d[Auils B POUOISIAUD | IBIM O} OAT] P[NOM J SSIP JO PULYy sy) SUISeUIT 0} BuIsE)S ‘SUIOD JOASU PynomM jYysnoY} | Jey) Aep dU} posnjord pue soAs AW Pposo]d | ds[9 dulyyAue ue) [JOp UIejao1od onbyue ue sx] SIOW SULyOO] ‘ul dn au ssazp 0) SurAy d19M ADU) S[]LIJ pue soe] OY} JO [Je Je BUI[TSIH ‘OU JO JUOIJ UL Qep YORWIS 1431 SEM SY JOY PUR 00} powojsnsoe Sem | JEYM UL] 19}}9q BUIYIOWOS UL SAdI[OG 0} PRY []NS | “JNO TVLLNACIINOS JeLiayepy pojsojoig yyswAdoz [) ss7pooTNAINIO Scl -YIOM 0} BULye) SEM | 9IQUIeS 94} 10 Suidoy ysnf JjasAw 0} y1 Aspuod uayyo P[Nom | Z[e91 9q HI pyNos’*syOo] sty purysq UONvIOpe Yong "UOTaIIP AUI UI BUIIE}S SOAD IOPUD} STY YOJed 0} ATUO JUSUTOU B JO} ABME YOO] P[Nom | UdyR} sJUDWOINseoW BUIARY puke SdLIqe] yno Suryord Asnq sem 1 SITY AA ‘SSOIp SUIPpoM WedIp UMO AW SUIUSISOp UNJ SAeY puk UDISp 0} dJ9y} Sem | “yeALUe Aw Sunosadxs aq Apvalje s19M OM SOSSOI]SUTSS JeJoAos Aq 00} popu} SEM puUv 910] D1IqeJ SY} OJUI Pay[eM | “USA YdoM STU} ‘MOU Pde 199 0} PayUeM SH “ARPOWOS POLUelU 495 0} JURA ysnf}.UpIp dH *d10}s Ul ostidins JoyjOUR pey oy “[esodold s1y Joye s}ysiu Mj} B INQ ‘SNOAZIPUdI S}eUOISsed $_JYSIU IDYJOUR JO} LUGO [a}0Y dy} 0} JORG SUL dye} O} Bulpiem siqqoy Aul oq pom jooyss Joye AepAIsAq “UY NOYJIM WOO] J2}0Y 9Y} BUIARS] SATOAUT PyNoOm YoY 19}]eUW Jey) OJ SuryAue Op Jo ‘Jed “YUTY) USAd 0} d[qeuUN puL 4995 AU JO Jdams Os ‘OIOJOq SIU} SAI] PIAO] oJ | pey JOAdNy “3ua) Sty) osuUas yeoIsAyd DIOL B UI SPIOM SIY Po}eI9}I91 pure poq sy} 0} yoeq SUI YOO) pue Sue duos sty ul dn au poyxord oy Ajda1 Aw ul Apjsauses oy} yA, 3s9yo Aw Jo yno IYys1 duinf 0} Suiod sem 11 143no0Y}) | pnoy os Buesg sem Yeoy AJA] “YSU sem ay MOU | MOYDUIOS jnq JaZues sja,dtuos & 9AdT[9q 0} D]QuUIeS B SeM }I PUL Yjed zBLWEyUN UB UMOP SAO] pur djl] B SW BuLOJJO sem dy Jey) SEM JaSuUeIS SIY] UMOUY pey | poised Jorg oy) UlOl] MOUY | [[V IW[snoy) | Os 10°‘ puey ul pury quam A]OIBI Jey) SBUTY) JUDIOJJIP OM) O1v Jt SUNOS puv juRM NOA yeYM SUIMOUY Ing Uoepelsop pue osnqe Jo swyofl] & IZAO poInpus pey | 1ey} SSOUL[SUO] PUL SULIDJJNS dy) JO [[e WO, UOVOVA & OHI] 1J9J urAes sem oy JeY} BUIYIAIOAS PUL WAY SAdI]9Q 0} SUIUCAA “SUIULSU SIOW PJOM oy} SAID P|NOM Japnoy jt sures Ji se “UY Je JOMSUB 9Y} Paynoys JsOUye | ..jS9A,, pies [| wy ye dn yorq Buryoo’] ‘Sulyje} dy) Jo [je op yesy Aut joy | “Jomsue dU} YSNOIY) NUIT JJOSALU BUI] USAD JNOYM PUP jeU] Joye sovy AW O4UI ]{2} spuey AJ ,.gou Aue sseajd nod [iM “euudy,, uoNsanb sty payeodal pue puodsss Joyjoure Jo} pasned ay yyS1 NOA yea} SAVMjeR [IM | pure Nod JO} 9UO ATUO dy} UTE | Jey} MOUY | “WILY 0} YOeq OS },uOp osvatg “Addey nod SULLWI Jl] AW JO Sa Sy] pusds oO} JUeM puL no€ YIM SAG] Ul We ] ‘euudr ,, ulese posodoid pue sauy duo UO O03 ay UOT}soNnb oy) Suyvodoy “UO JUdM JY SV PUNOJOId SIOUI PUL SOUT JOT S}UdTUID}RIS STH OW Ale “SIy} Op ued Nod ‘Aylodoid s,Apoqou ino 4,, ‘sovy Aw uO UOIsnjuoS JO YOO] & YIM UTY poyse ] ..gJeUM,, INoge dure) Ayyenjor sem oy yeyM pusysid wos 0} pley 1 puNo} | 1Nq ples pey sy JeYyM plesy | , vIpesSNY UI SWIOY AU 0} YORQ OUI MOT[OJ puke puvy AUI dye] “MOU }I JO JNO JOLHH “ISAO JONUOS OU sey SYS Jey) BWLD B Ul }SO[ A[D}9;dWOd SI OYM [JIS [NJNNeDq B “OU JO JUOI} UT S19 JYSL je SULyOO] we [ WYM 99s },UOp NOA Jey) st waqoid inoA ***39s NO, ,, “Ysndo IoWUINs & YIM spusty ysnf uey] dI0W SIOM 3M SAdIJ9q SUI SALUT 0} S]IOJJO SIY YIM OW OS1IdINs 0} ponuUuOS 879 $0 9zgabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUBWNDOG ‘898Z-8T aSeD TVILENATCLINOD JELoIe, paysojoiy WySUAdoD 5 |

The text on this page is estimated to be only 41.10% accurate

19TFOOMAANO 8cl ‘OpISUIvJUNOW SNopusuay 3y} dn poyry A[MO[S IJ9M SAA “UTY JOF 17e}S99 UBY) SIOLU SLA\ SY UOTSIOSP SI UL JIMS SEM dIQqGoY MaUY dy 99UG ,,jUst} SIU} OP OF S]a] Ud} IYSULY,, “WeUI Isoq STY plo} 9Y ,.“T4IS sty] YIM aq 01 UJOQ SBA J,, ‘SOA pres | pue posodoid ay jueysul oy) purw sty dn spew Apvodye dfy ‘Wi JO plom e vay },Up[nom siqqoy AW jnq ‘mouy A[psey ay [JIS B O} pole 499 Jou pur siyy Wo Aeme YTEM O} DOUBLY Jse{ ay} BuIA noge yooeds suvtu jsaq ay) WY SAed BIOJSq S}UdIOU ATUO OYM “Pulau }Soq SIy Udy} puke sIayvods AjuO ysi[suq sn 10j yosads AuOWIsI99 SyUO|] ISIPpNg dy} d7e]SueI] O} pany sIqqoY IY} Ja}o1d19}UT UR POMOTOJ sn pulyog “194}930} 141] AYS 9y} OJUI poxjem 9M puke pukYy AW YOO) dH ‘Wdt} SULAdSIYM JSOW][E PIWJOJ YINOU SITY Jey) SPIOM ISI] SIY sJOM ,,j[NEHNeDqG “OS YOO] NOA,, ssayyosads sul 3J0Jaq POO}s SY UTRJUNOU 9Y} JO WI0}}0q du} ye 9q 0} puegsny AULjJOWW | USYM pure JJOSAUI 13}}0q dn 41 JUIRaIp SAY }, UPjNod | ‘sIaMOTZ Zurlppng sjdind pure MoTIA [Jews pue YyWeIIq Ss ,Aqeq jo dn opeut siamopj Jo [IdA & ji punose Buiddeim jouy e oyuT dn sey Buoy Aui pon Aay) jouedde Suippom ay} Jo []e YyIiA\ PVOGI9AO O83 0} SUTUM }OU ‘ysoq 38 Aproyduus Suysonboy ‘ajt] GUS s]OYM J19y} nNoge sMeaIp [113 AIAD JEY] UOISedDO [e1Oads Aul JO} [NJINeAQ Os [90j SW SuLyeU Gol yeois B PIp UO]RS dy} 1B OR} puR Ivy AW SUIOp 919M OYM SoIpe] IY] “sUISSIp pue dnoyeui Suippom -o1d AU JOJ SULWIOU Jey} SULTOT]NEDG SY} 0} OF 0} PRY | ‘puegsny Ajivau Atu 0} ABM 9y} [Te ow Aled yoRuoys AW Ul SOTPfIA}ING 9y} SuUINd] JOOP dy) INO pesuNtd | se JjasAw 0} JYSNOY}] | ‘O08 ] dE] “ssAqe ssayutojjoq e OUT Sursunqd sem | OL oJ | ‘UOsiod JUaIasfip B MOU SBM | OSE 490M B A[UO JOLNUI OWS dy} Ul SUIYOO'T “‘powsew A][RIDJO BOM IA DIOJOq BUTI} Se] 94) IOJ 9AQ-pood s1Qqoy passhy | PUOddS 9Y) WO} PaT]Y) SBM | JUDWID}IOXS YUM PsAOL9AKG “SoUO BULyOO] jusdap jo dred e Jjasuniy pur pue Aq) 0} UIeSe JJO SEM OY OU O} YORQ ssaip Awl Jjo poddosp ay Joye os ‘ins sy} YIM OF 0} S9OYS YOR]q PULy 0} ajqe ud0q 1, UpeyY []US 3H “UL Jsaq S.sIqqoYy Se SUIPPeM 9y} 10J sn sulurOl dq 0} Suid sem dH “YOOI9,0 udads ye AQqoy] [9}0y SY] Ul WUIY Jou Bi[eyASNY WIOLJ LUIY YIM SUIT[OARI] SVM Jey] SAP [OOYIS YSIY WOT PUL 3S9q SIP] ‘gjdura y, 1dazd 10g 3e Aep SIq INO JOJ SOSSoIP puL SjINs SUIPpaMm pasojie} ino dn yord 0} Ajsesd pag Jo Jno pue dn sem siqqoy ‘SUIMIOW }x9U OY] ‘[BO1 P3dPUl SEM SU SULISJJO SEM dT JEU} DAO] 9Y} DAdI[aq pue SPIOM SIY JS) 0} JURM OUI OpeUl A}TIB9UTS S]eUOISSedWIOD puke SUIpUR\sJapun UB YONs YIM dul }B poyxoo] soda Ayjoid siy ABM sy] “SuOIM OS SeM | yNQ ‘skem AUBLU OS UT [OO] B YONs SuTaq seM | WYSNOY) | Sf1] 9FOYM AU STY) OHI] SUIYJOUUOS JO} SULYSIAA “1 JOJ BULYSE USAD JNOYIIM Popssu | yeYM MIU ay moy SuIzeUY ‘ul daa Ayyensn pynom s}YysNoY) dy} pue NO jUIM s}Y3I| SY] USYM USAS SUI JOJ S19} SEM 3Y IVY) MOUY IU SUTIN] “WITY O} JasO]o UI Ajquas aul payind apy “osly AU Ul BIOJOq JSAD UBY)] SUIOY Je DIOU SBM | 9¥]] JJ JOASU PRY |] “Weay Suyeaq siy Jo WinIp dy) 0} Suruaysr] ysays sty Jo do} uo peay Aw pre] | ‘WYysiu yey) sue sty UT Op 0} Asko sem doajse BUt]]ey TVLINATIINOD JewarepAy poses wsuddog Oj O9TFOORRLLINIO LCI ‘OAO'T SFT] UL YS SnoToaid JsOLU ay] SBM ‘OZT[RdI 0} SUIOD OST pey ] YOryM ‘Buryjo wos OU! Suryou SurusNy “Ul SUIAT 0} polojsnooce ud0q [][! SABY 9M BIS GUINU 3} U! SABp 9saq} ayNgqizye O1BI B 313M SAA “SOUIT] JSOYFN0O} Ino ye SN UdAD"*“]SITJ Ye Plp suoAUL UII 1, UOp J ‘WYSNoy} |{ ‘Ysnous Wey “Buoy AI9A ysv] 00} J payoodxa Apoqou Jey) paride Ajduuis ysnf oy “Wysy e dn ynd j,upey Aayi Aym Joye] sieaX Auew peq Auli poyse | usy A, “Apusueunod ‘eryensny 0} dulaow SBM J] JJO 11 do} 00) pur 3997)S 9Y} UO ANB }XdU dy) Woy MOUY },UPIP Ady} Jey) UU USTIOIOJ B SuUIATeEW sem JoyYysnep Ajuo Ilay) duLIapIsuod ‘[]2M }1 YOO} syusred AJA] “V1q SUO SN WISOSIP 1, UPIp yey} JNg soprs JOUI9 JO ssaquiow Aue Aq po}e1go]I9 1, USEM JUSWs0.UNOUUe INO W9Yy) YM dIBYS 0} SuUIppaM INO 1OJOq JYBIU BY} SOIIWeJ INO JO Jsasojo ay} SULT[eD ‘Iasuo] Aue aploins Surusjeoiy) },USEM SYS 1S¥d| Je JNq YoNs se Zulssajq B },USEM J] ,.jNOA 9q PynoM jt ‘OIQGOy “SIy] se AzZeIO se GuryjoWOS Op 0} ApoqgAur aq 0} SUIO’ sem }1 J],, (POYTIS oYs “puIUT Siy asuUeYS 0} BULAN AJSSO]JUS[O1 19}JB PUS 9Y} Ul “SMU 3} O} JOBII P.SYS MOY dU Pjo} sy UdYyM Op oy} UO Yonu Ayaid sem a] ,,jjJa}}ewW JY) JOF S$ asja APOGAIIAI JJO pure SOAT] JIOY} Ul BWILIP OY} JO JJO SALIY] SBOAA “} JO PUOSIS AIBAB 9AOT J[,2YS ‘y3noy) ALIOM },U0d “UdIp[iyd [euLou Bursies gol 9jqQLUa} & YOns SULOp JOJ J{PSs9y [[Py 0} Fulod says MOY Noe aq |] ,J1 Udy) SuOTIOR ysy]as ALU YIM Joy BULLY W,] MOY ynoge eses e 9q [I ISIE “Avs [], ays wey A}IVxO MOUY J ‘SIT YOIeAA jJayOW ueypIorg Aw [eo J [UN jem [eo ouoyd prey e SUM JEU) YUIY] NOX, Jays] Ul Ysns sw opeul syUStUWIOD }xOU STY syitids Aw qiy 0} no skemyy . 31} WOYs B yons ul Sulusddey si yey) Sury}AIaAa pusysiduio0s 0} SusAy) sn W,| pue JUIaqsIp Os [ye ysnf s.3] “AyUNOS JOYOUR 0} SAO Big B YONS BULyR) pue OO} posn WI,[ YM Wo ABME o3unid o8ny e yons Burye} Arvos os ysnl s.j1 sson3 |,, 00} Mou SuLysne| SOUL OUI 403 3H ..{BuUlAIO NOA aJe AYM Udy], 910A Suryol jyey & UL oul payse oy pue WY punose sue Au poddeim | ,,jalu pultjaq afl] Wy] FO j[@ Suraea] pue nod si ynoge aed | [[e WOurAUe J9}eW }, USSOP J], 1BY} WY [[9} 0] poseueUr | sqos Ate YSnosy) SuIpyUsS ,.gyny’*[[a% Os O83 1,UpIp JL Je 1 ONLI T,, “Syooyo AW wo sies) Suypey oy} podim pur Ayyejusta dn jjasAu Surjeaq sem | dJ9YM PIq 9Y) 0} JBAO Pays apy “SsouJaqtuos AU 2y}00s 0} O19Y AU SUILD UT ‘aSJOY o}IYM B UO LYysIUy AW SHIT | "QUI UO PRY dy Ploy au} Burses 194 Jou uMOP AddjJor J9] pey | peq Moy jsed 3as },upnoo | pue JjosAwu Joy a1] Addey Mou e jo UMEP dU} Je SUIPURIS SUM | DID “UI POOL] 0} URS9q Siva} DY} Udy) pue sjoY yep pue doap & UMOP BUI[[e} SVM | OH]] 19} J INS YUM powjsyMJaA_ "s]yBnoy} AW pasojUd Jey) SUIYY JST 9y} Sem _.{ouOp ysnf] savy JY M,, asuodsas Suryooys sy} wioy pezAjesed 0} Sem | “00} YOR Jamsue 0} 3U0} [RIP ay} Jo OYdS UR AJUO BUIARST “JOATSO0I QUOYd UMOPp paUuUueys DY JUIWIILIS JOY) YAK ,.jQf!] POOS B aaRvy ,, SEM QUOD O} SIBdA AUBUI [YUN 879 $0 /zgabed ‘O€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aseD TVILLNTCIINOOD [EMAIVAL PASNCsY UWTWAdOD | |

The text on this page is estimated to be only 41.63% accurate

LCOTPFOOFRELINTO 0€T OS ‘URS JAYJO YORd JO SUUIL dU} O} YoRQ JYSteIs JUSM PuUe JULINE}SO1 jROO] BIB JOUUIp JoINd vB a}B SAA “SOSSTY SusTul] pue ‘soyonoy Suiziyejury ‘[RSNOIL JO SPIOM S LOTJOUL SUO SOPISdg ds]o SUIYJAUL JNoge JYsNOoY} oM a10jaq Aq passed pey sINOY 00} SAO] OpeUl Uddq JOAD AT[VOI pey | oJ] Au UT SUIT) ISITZ a4} ApQqeiuspun sem qt pue AT[RoIsAYyd SAO] INO poyeultunsuos OM dI9YM 0} ABM 3) pay syejod asol oY], “Roy jURID ev Jo sdeys ou) UI poq INO UO ddL]d 0} SdSOI PJ JO SUID}S SU} JJO sjejod oy} Yotd 0} Jjosuy WIOOIS ay} UBY] Layo SuOU Aq SUOTJONIJSUI USAID OSTR 310M AdY} 9UOT SIOM om aflyM Wool Aw dn Suipy siouRajs oy} Sopisag ‘ostduns Jooms Joyjour JoA payeoaal ay [uN wy Jo Jo sod AW BULL] 9OUO JOADU YSU SITY punole pozaanbs Ayiyst 19M Sue AJ [je pue ssarp Ajnod ‘pjoysoly) oy) I9AO SU Palued pue syns JaJ0Y INO as1OJoq ABMTTeY oy) UI dn sw psyxoid dy jars BunoA e& se peas pey | S[Saou 9duewo0l sy] UI AJeUOjsNd sy "UO JOABOPUD O} SEY SAO] 913 JeYM JO Sulpesy jnjJomod oy) YIM siBdS Aw puout Ayidipusias Avy 0} AJUO USW pO payisAiod Aposis Jo areys ivy Aw yyiM juads pey | siead AUR 9] J9AO MOUY O} SULOD peY | AISARTS JO Spunog dy) Wolf payesaqly sem | ‘puny uMO Aw Jo Juswdesyus Ue SUIDd]J JO Surjaay BONUApL ayy 0} payejai aBeieW Jo Aep uMO Au Poalsoiod pey |] Moy pue Avme Ay Way) SuIyIIVM JO IOUKAD{9I OY] 00} SWIOD AyPeULY PRY SUL MOU | WOpsdsy SOAJASWISY) BuUNULIS SaTys on[q dy} OJUL JUdDap JeuLy 194} YOO, Ady} pue uddo pesids 0} uedsq SPJIQ OY} UO STUIM 94) SY ‘SOJLJ UMO INO SPINSp 0} Sd.AF WD) 19] 0} JOOP S,adevd 94) pousdo | sUTW se [Jam SB THOPsaI INDY] SUIZIFOQWAS “au Joy ATTeIOOdSo ‘oINJso3 3]QIpasoUs —- UR YoNs sem J] “S2AOP posed Jo sseayal ay} ‘sn YM dye} 07 UOTNIPe.Y JSB] DUO UDAIZ JOM OM PUR SU PUTYAaq USWIOM Tey] SULLURSIOS dU} 0} SPIYOIO [NJIOJOO YUM PdXILU SBIOY TUIPpom dIYM S$ puRpley] Jo yonbnoq pasuele Aw Moly) | “Uns SULARY JO JNO s}YysTU AURU INO JO SLUOS UO 43 pey | spd yeooy ay} ysnf azoMm OYM ‘oAqpoos Ajred Jepigq sy) SUISSTY ‘194}980) SuOWOp Jsed S_.J9Y4JO YoRs Sulpeq JO Sutuursaq dy) Isnf pu’ 19Yyj19B0} SJ1] MOU V JO JUSUIOOUSWILUOD SY] SEM HI ‘OO} SN IO} JO] B pajudsaidd.s J] “SOM Puke JSed UddMJ9Q UOIUN 39y)} SUIAJIUSIS 1179q Aylaqly o1foqurAs Id] JO JUOIZ UL WIOOIS pue Sprig 94) YIM OJOYd kB DAL} P[Nod oy Jl poyse oy Sil] 94) UMOP JUsDSep INO UOdy ‘sn poldew jey} YUOP] 94} 00} USAd ‘sn O} ATUO yOU ynq [eIDads Os sem ABP ING *39US]STXO SuIAjsyes puv as[duuis est 31 YM JO} Of] AU Jo SAep Sururewol ay) Aofus 0} $1 Op 0} JURM | [Je MOU pue SUNT] AU JOJ pj1OM [eI oY] Ul soUdTIEdxd YSnoud pey | ‘pay pey | sJl] 9y) JOWe nq OSe sIVOA AULW [JOM SB OU 0} SA_PfNoM jI pue JsOW 0} Fu0g spunos Ajqeqoid 31 Mouy | ‘Aq sn apes sAVp oy) Suid] Yosod JUOLy dy} UO PjO MOIS pu JoOYI090) Spry MOj B ISIVI O} LUIY SAI] SUOSLUOS YIM dq O} ULY) dJI] JO JNO sIOW Buryjou SUIUBM “STU JOFJ I SVM STU} “TUTY 0} Pres | 1VYy) POM AIOAS JUROU J ‘yjeoig yeu AW MoIQ | [HUN WY AyUO pue Wy SULAO} O} SuIaQg d1QUd ALU dJBOIPSp PyNoOM | MOY puR pUNOI oI] sJOyM TYILLNACISNOD JELsIeJA, P9199101, IYTIAdOD g cocroor LM 621 Aut posueyo pey oy yonui Moy WHY {[9) 0} uRSoq | UdyM YJNOW AH JO }NO psTquissy Ajoeq SploM Au JSeF OS SUNS SBM JeOSY ALU pue ;[TYUMOP BUIPUDOSSP SJOOY SosS1OY UOI|[IU BJO PUNOS sy} SULLOPUNL] d19M SIVd ATA ‘yedY AU WO] SpIOM posiedaid posoVs dy} 919M BY} SMOA OY} WIY SARS pure uleSe SUL OJUI YORQ SpuLY SIY YOO) | JusLUSSeLIVquIs AW ye Sullss19 ISTIYM Spysdo AU YFVOWIOpUN Surpey vIBOSLU SY) DULCIAY “o[/qeyasdi0jun JUS UOLU SI} Opeul sy sv SoAd AlU LOL UMOP POURS UIEdE QOUO SIVIT, “SJIBIOJ IOASU IEdQ OY) OSNKdOq ‘1e3aq SY} SAT] 9q 0} puke 00} POWO}SNIO’ OS SEM | JY] POM dy} Ul ALAM 94) {[B WOIT dtu Joqjays “pied 3M Op Wap [WUN AT[EUOTIPUOSUN SUI SAO] O} 319M SMOA SIT] “IOJ YSe OAD P[NOd |] ULY] SOW PUL STH OJ GUINJAISAS BUIPIAOIY “IYIO YOVS O} SAO] JO SMOA INO 931991 0} JOds JoopJOd OT] puNOJ pey om MOU OM ‘TeyA-SueyD JO AID OY) BULYOO] JOAO OPIS JII[D B Jo aspa oy] I9AO BuIsueYy AUooyeq dy} 0} o[duia} dy} Jo JUIOd JsaySiy oy} 0) dn Sulzer, “[Iejop AOAd 0] UMOP }oojJod “YsnNoY) SUIPPoM [kdI INO SEM SIYT “SSNOYLINOS Oy} JO] UNI B OyBW 0] SAvY P.dM pULISUOY SIY 0} YOeG 109 OM UDYM SUIULOTU ‘ssUIPpoM poljise9 oziusosa1 ATUO eIpeNsSNY JO SMe] OY) DUIMOUY s}Jvsy INO UI A]JELOIFFO 1SBd] 1B SUSQOY “SIAL W “AJA, Swvd9q A]TeIOYJo pue sjdwisy jdav) tog] Jo AsidaI SUIPpaM JsIyppNg 94) Ul SOWeU INO PoUSIS 3M ‘194}930} UOTUN INO Jo APLADSUO] 94} 0} SuUIURIUI JoyJOUR SUNUsssIdo1 QUO Yord ‘S]a]9OvIQ [EJUSWIOVS USADS Puke Ja}vM JO YseTds & YIM YUOLW 94) WO} BUISS9/q & YIM PoJUlOUe 919M | PUR dIQqGOY YOY ‘odendsue] UMO INO UI SN JO} pojesuel) puev ‘souLvpIONL JeNSIOUL I19Y} 0} SUIPLOIOR SUIO}SNS }SIUPpNg Oy} Ul oUOp seM AUOUIIIIO OY] “O[duId} OY) 3v UOSI JuUSULULIOd B SUIvIAG OM ‘ST]EA SNOTSI{II 9S9Y} PUITJOG UdSS Ud9q JOADU pkey JYSIS & YonS ‘J11Je SUIPPOM WIOISOM [BUOIIPRI] SULIVOM SUOAUR A[UTEION PUR 9194) PSV UddQ JOAS PRY SIOUSIDIOJ JOYIO OU “UOOIS puke spiluq Suissed oy) jo sojoyd yoo) pue poddojs a] duts, otf] 0) SIOJISIA AURW OY | “99S 0} [][P 10] SUIMO|S seM ssoulddey AW pue petp Aof jo suevay Ajj ‘opduusy Ajoy juatouR dU} OJUL PSdURAPe 9M Je SN ISAO popRoseKd JOMOYS UNS Y “S9AOgR SpOH 9} WO] SUTYIOJ poos Aq pojeolS 919M OM SHRLULD Sy) JO INO SujoyH 7Z J9}deyD “QOVJ POUTEJS 1Bd} AU IOAO [Te USM AJOIXUL OY] BUIASTJOI ,.jNOA SAO] [SW IOJ 9UO ATUO 94} 31,NOA,, yaeq porjdes pue spuey Au pozoanbs oy ,,{3uluaddey Aypeos siyy st ‘Ayon] Os we ],, ‘sie9} sjqeddojsun yum dn popjom | ‘ulese sur je Sursels A[surope wIy Suryoyeo pue Alauses oy} JJO Soko Au SuLyR] j}! 0} SUIY) JSASOTO 9Y) JO UdARdY 0} PalLued Zulaq dy¥lj sem ji ‘OJ Tuljpey pue JodesosAys Apypes SU} P9ISAO9 Jey] SseIS ASsOw JO Jaded udeI3 jeJOY sy} Aq pepuNo.ins 879 $0 gzgabed ‘OEZ8Z9Z ‘6T0Z/60/80 ‘8Zz JUBWNDO ‘898Z-8T aSeD TVHLIENACIINOO JELIOZE] powssjo1.[ IysUAdOD GG

The text on this page is estimated to be only 42.29% accurate

S9TFOORLLANALID cel B SUIDQ JO RIP! BY} PSAO] | [AIG B JOTUO] OU ‘OSES YONS YIM IBLE JO SPUNO dy} O} YOO) | SB “INIYJIP 1, USEM OU UL URWOM dU} PUL] O} SUTAIT "Sn Us9MjOq AIISTWOYS SUOIS dy} sas AJISVS P]NOd sUOAUR JOYIOUL 3UO WO] Iv} 00} GulAeI}s JoAdU SdA9 poyeandes Jno yA, ‘douURLUOI oye}AURI INO Aq yORQe Udy} Bulsq Ul SWS dY} PUOAIDAD 4NQ ‘SIO[SALI} A[JSOUW “SLIOS []B JO SPUSL OpEW 9A “JOYIO yors Suraq A[JSOUI ~**pUeTSI JY} UO SulyjAIOAS PaJSAoOoOsIp om SAep AuUNS 34} JO Jay Buvsisijq sy) Ul SAO] SuLyeu pue JYSIU sy} JO SINOY 99M 9} ov Surueg ‘pojuiwnboe jod Apjodoid 0} slosuvsys Om) JOT AWM [eopt Ue }L SULYRIA] “SYDOM XIS }XOU 9Y} OJ SBury oy1[ dh WI paal, 9A “YSNous uesyo ‘Jam “""uBOTO pue ‘ULeM AuuUns ‘dq pynoys Aepryoy eB MOY JO kop AW SEM HW ‘sordoy oy} Ul UONeXeIdI JO 11q B AT[VUTJ JOJ INES YOY ul SUIALIYy €7 taydeyy ‘sAep [je Jo uooutAouoy Ino JO SAep JSitf Jy] UT SsayayyeuoU soUdLIOd Xd SULeOpUs UR [YS nq apry O} SuryjOU pey om YSnoyyye ‘ouoye Saat] Ino YUM Suldeoso 10] [NPYULY] DIM IAA “P2JUBM 9M JI SYIUOU! dd14} J9YJOUR JO] poosd sn Suryew ‘spiodssed ino paduueys pue sn pasesjoi Ady) asunoo Jo Suryjou suiputy ‘JOUJLYM IO SSnIp JoJ aBvGIN] ANO YSNOIY) poseultuns sI9yIO s]IYM JUIOdUNS ye Sn pyoy sjeIOYJO dy] ‘yoeq pue Jop10g 9y) Surssoio juods OM DUI] WOYS dy} 0] ANP YSU & SN SULIOPISUOD “puLTIeY] OJUI yOvg oSessed INO Zulelsap 1aj3ua9 yodssed dy) 0} yoeQ [J1y UMOP YORq BUIPesY som aM ..j MOU OFT 0} SLU] $.}1 BIQqoy ABAQ'YNA,,”'-OSJOM USAD SEM JEU) sABM SlUOS Uf ‘pouad Jay uo 1ayO00Y & SB JJO jI Bulssed j! YIM Sul] PowWses WOOI dy} 0] sn pamoys OYM Ape] dy} ‘SMOUY OYM JNQ JUdAS SNOpUaOY B40 JOR UL ATGissod UdAd PUR YI] JO SWOJIdS oY] YSN sem STy) Inq ‘aWOY 18 J[OSAUL OHBUI |], | USY] JOMOYsS B puk Pog URIID B JO souNxny o[duts JY} SUL SAIS JNQ qous OU LUP | ‘UOISsoiduUT Jey) YM ULY SBM | “IES Jo od A} YOVGINO UL U99q IOABU SAY J JOR] OY) SUTAUSP JOU SEM | LY) JON ‘SNOTos SEM J] MOUY 9 9dIOA AU UI U0} OY} WOT] puke puRgsny Mou AU Po} ] ..jABM ON,, ‘JOBUO] JUDIIOW J]TUIS B JOJ 9JOY DUTAR]S UDAD JO JYSNOT) 34} 18 SULIVS] MOU SEM J ‘I poruRdui099dv Jey} YOUS}S 9Y] PUL UIOOI dy} JO 1YSIs sind ay} Je BUIIUIOA A[IVIN “UIOIA ssoTdjay Jood swos Woll poo[q YM Pouleys SEM poq oY) pue yede U0} 919M SJOOYS paq SY] “Ul Pey[Dy A}]BIIG U99qQ PLY SUOSLUOS SHI] POYOO] Jey} WOO 94) 0} dn pamoys a1oM IM “AOI JOLIOY B JO INO 9UddS B SHI] SEM JI [3}OY OU) Je BULATIIE AT[eUl "suoIoR A[SUIWI9OS OS JOU UI SOLUTJOWOS JNQ SAO] JOYyIO youd JO SUOTUDJUI ON] ay} JoyJOUR sUO O} BUIAOId A[ssapUNOD “19y4}930} SAO] dJeuOIssed spew 9M SB YOU sv IsNf 1YySNO} OM ye) JURLOdUI pure jeinjyeu AjuO sem J] ‘SpuNnOM PjO WO SULIZAODOI ][YS ING SUOTUDUI TVILNACGIINOOD JEMaIEAY p21d9}aI 4 1yBiWAdoy (] P9TPOOTAAINIO Tel YSU sy} YM YIOQ ajdood ulogqnis puke SuOIs peoy OM] “MOTI[OJ Ayjuanbasqns 0} sjOyjuood [eJLUI SIOUL AURUT YIM POLE Ul AT[LOLJO O1dM 3M MOU PUL 9}EG9P ISI] INO SBM JT OS DUNKS JNOQe ]]B 91, Ady} puL UBTIOIS ST OY JJO I do} 0} Puke SUT SdIOJ 0} GUTAI SEM FEY] OPIS BULB SITY isnf sem IT MOU J ,.jABP [[e Ud}ed },USALY NOA ‘BUIYJOUTOS Jeo pue AI} OF SAvY NOX “SUI O} SUT] SHOOT {Jou AYM,, JO ISINGINO YNOW pnoy sity WM o1jqnd spew sem ing Je9j9 yuIod Aur ayeu Apjornb 0) SuiAy 9010a paysny B UT PoyINOW | ,,jJVY) JO }, UBD ],, 11 Woy] USAD O} JJosAW Bulsq },Upj;noo isnf{ ] “MOIA Ied]O & UL [Te SN O} 1! BUTATOS WY) JO dO} UO POO} SIy pue jseOo} Au ynd 0) papsssoid Jayny Udy) pue suo payoussp pnw snotasid oq} SB peq SE JOO] 1, UPIpP Jey} J3}BM JO JOHONG JoyJOUR UI BSULI Udy} pue IoyeM Ap JO [[Ny yong AIP v ul saqyeyd owos dip 19juNO9 oy} pulysq Apr] SY} MBS | USYL “JYSNOY] | Joses SuiyJoutos “wel pue Jsvo} sos JO} Sul]}es ‘VYySnoy} | SULep*““YSIP pOOJLas JO PULY SUIOS PdioPsO SY PBOI DY) JO apis ay} uO dojs 0) 3uIpioag ‘SuryjAue jnoge ysnf jsosip pjnoo ay uew pessns B yons Suleq puke dij dy) JO UOTJBINP d11}Ud dy) UdTeS },UPeY 9M JOYe AisZuny 3uN193 Sem dIQqoY ‘}YSIs yey) Jaye jusIedde owedsq suOeUTSep Ul 9d1OYO STYy JO s}qnop AJA] “[9}0Y JNO 0} ABM 9y} UO WHY Aq passed am SB SUINTEM SOM OM JIOYM ABMYJed 3y} UO JOppe]q SI BSKO]O1 O} Poploap —-yeyy AOg duo YyIM ‘sjaa71s ALP dy] YSno1y) Ue USIP[IYS poyxeN “atu 0} poureydxa useq pry ji MOY ApjOexa },USeM SoIdoy oY} UI UOOWASUOY AUL JV} PUT] 0} ATUO Opts J9yIO OY} O} 11 O¥eW prp om ATqvasijequy) ‘QUI JOJ PLJOM 9} PUNOIL YOI] 0} PUTY OS SEM SIQQOY Jey) ssedsn] AUL JO SS3OX9 OY} SUOTE 19] IYBIOM INO s[puRry AjoJeq PfNOd I O¥1] Poyxoo| yey) }eOQ vuRURQ LUT{S B UI Ulel JO INOduMOp AALsY JUdDO B WOOL] JOAL BUIPOO] & SSOJO 0} pey Udy) aM ‘yled Ud}¥9q DY) JJO SINOY IYBIO SOYJO SIA paiouue AJOWI3I]X9 3) YSNOIY) JOS OM USY AA ‘SORT JO UONeU UIO}] JEM 9) UI SBLI[IA & O} pueypieyy JO Japsog oy] puodaq Aousnol ino JO} snq papMolo dy} pourol pue SULWIOW ay) UL Apied Yd] OA “OU JOJ 910}S UT PRY oY ostidins isyjour “194}930] puodsq pue puvypleyy asojdxo 0} sn 104 Areiaur}! uooOWASUOY & YOO O} PaydUyY JOS 9M DIOJOq Jjosuly Aq Juase JSLINO} B POUSIA pey sIqqoy “uNnJ Jo odAj JoyJOuK dAey 0} PaJUBM aM MON "JOYyJO yoa JO puoj Afa}VUOTIIIJJV OS d[dNOd & 99S O} STU U99q 9A,JSNUI JI UOTOKAI IT3Y} UIOIf ‘OINjIpPUdsdxd INO Jv YSN] poos & pey [oJOY oy} JO JJvIs osUS dU} ‘SJaMo} pue sjooys Ysol Jsonbal 0} sopisog ‘Aqqo] [9}0Y4 Mou SY] UI SITEJSUMOP UL SUTYIIYS SOUIS OUT} ISAT] SY} JOJ SOV] INO poMoys ATTBUT aM UdYM 1d}v] SACP SOI], ‘P1OOV UALO INO JO SUl[]JOMp JoyjouR Ul d01ds DAO] Ino Bulnutuos “yvads 0} OS [01]U0D JO sOBopIAJid [eoueULy $s, AdIJJor JO Aue JOPUN JaBUO] OU ‘[OJOH SSOOULIY OY} YO] OM SUILIOW SUIMOT[OJ OY] ‘SIOAO] SULUIOSSO][G OM} USOMIOG Oq P[hoYs } JeYM snl ‘onadIous pue SunoA ‘Azelo SEA J] “JOJ MOYS 0} DALY P[Noys ,.potuad uoOWADUOY,, dy) JeYM JO AvIdsIp [Bopl 9y) SEM HI JOYyJOUR SUO YIM BAO] ul A[punojoid 879 $0 6zgabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TILNACIINOS [PUNY Po199401,f 1YSAdOg | |

The text on this page is estimated to be only 42.77% accurate

LOTPOOTAAAMO VET yodne sng sy} y8nosy) Bunjoq Ajsnonrpedxg ‘ouetd Suredap Au 0} 193 0} JLULULID] SLiOdIe Oy) YSNOIY) UNI O} SWI) YON SU BUTARD] },USeM SYS }Nq DARI] 0} 9dIJ MOU SBM J JOO) pue sjuatnsop Aw yoeQ oul Sulpuep] ‘pey ATpeol ] [[8 St STU} [[aM ‘Joosd pojuRM sys JI ‘podopaasp wWisy} SUulyJo9 soUTS osund Aw Ul SUIALIVD pue JOY pomoys | Jey) Aep sulppom dy} Jo sojoyd oy} uodn OIWIS B POHOeIO AT[BULJ SYS SB IVY} S41] SUIYJOWOS JO UOTSIJOI UI JSOIOJUI UOUILIOD B paseYys savy JsNnwW sYg “AUOWDIN9 JSIUPpNg & UL PdlLUeU 493 0} poyueM 3M SJoI[aq spueqsny AW Jo osnedoq A]UO sem jt ‘ATTesO] oIOY} AvqS 0} BITeAsNYy Ul [eae Au Uodn ssnoyyNod & YSNOIY} d}ed1J1JI99 OSeLUeW JB39] & Ulk}GO 0} dAeY PjNoOM | Jey} aIeMe Apeoiye sem Inq Jo4 Joy MoYs O} DUO SARY J .UPIP | JEU) JOY 0} SUIUIE[AxY “SoJBdIJ 1199 JO PRdISUI S}Jo]9NBIQ UDAOM UDAIS pue ojcduid) JSIUppng & Ul PSLUeW DOM OM JY] BUIOIS [je 1 Aypiqiposs sa1oys Aw djoy 4, Uptp Siy_L ,.GUY) SBT VION OSB WI InoA aw Moys NOA ukd palueU 103 Isnf savy NOA J] ,, Jooid owos pojuem DYS “OF 49] SBA | DIOJOQ polaMmsue dq 0} pey UOTSONb sJOU 9UD “MOU JOIPIOA Aysey B OYVUI O} pey dys apis AU UO OUT] ATUO YU “yoysueg 0} SUOTL YOeq SUI PUDS 10 RTTRIJsSNY UI puRgsny AU OD 0} UOTSSIMIEd JU URIS P[NOAM SYS JOU JO JOYyJOYM BUIPLOOp “JUSWIOW ke 10} 194 PjO} pey | SuryJAIOAd JnNoge Yury) OF pey 94g “Mou JYySTF AW syeU UdAD 0} SULOS SEA | JL INS },useM | UOTeUR|dxd sIWUS AW YSNoIYy) SuIAID “sJ90y} J9A0 [BARI] O} SUOTUDIUT AU JOY plo} pue AjoorU UT 9Aez ySnI | [[e Ie USA 1O 3B) OXI] SuryAue Avs 0} d[qv dq 0} UOTISOd OU UI SEM |] SUIMOUY {own dy} []e $19491] ABM-SUO0 YUM [dARI] O]doOd 1, UOP ‘JOY O} sem JI SSouTSNG yEYM PolopuoM | JJaSAu OF, .gSWoqoy “SJ “949y} 103 NOA sdu0 sueyd INOA aie A[JoeXd JY AA “BSIA OU YIM RI[BISNY 0} pdyoog Joyo] Aem ouo e AJUO SABY NOA MOU PUP SYJUOU 9d1Y) JO} puepiey] Ul UsNqQ sAeY NOA,, ‘payoo] oys se wus se papunos Ajdol 13ay “JOY spremo} AyIsourtue Aue }UIe1}Sso1 0} SutAyy ‘Ajaytjod Joy poyse | ..gdsuo0IM BulyOWOs ouop | sAeY ‘{noge SI S1Y] JLYM dtu [[9} Bsed[d NOA uKD,, “‘SulyJoWos 10} uoTeuR]dxs UB JOY SAIS O} OW OJ BuljleMm SEM YS OW O} PIOM B BUIAKS JON ‘sn UddM19q Ul YSOp 9y] UO sjusUINDOp AU podetd oYS ‘soA9 Jay UT YOO] UIs}s B YIM OU TOI] SSOIOe UMOP Jes puR dJOJOq WOIJ SpleNs oy) WIM ULOOI Oy] poio}ud WIOJIUN Ud0I9 B UT UalUOM paluRedy-odIZ] B Jo} S,aINUIT ZSUOIM auop | pey yeyM “Jed AU UO UOTSNJUODS JO [fOYSqtuog [L}0}] B SEM SIU] “MOU 9SIOM UDAD SUR Ing djay 1,UpjNod | syysnoy} Aw YIM auoje pur zosAtu Aq oul Sulaero’T ‘suorisinbul [ea9)sAy Awl Jo Je Sumousi ‘AzZuday ul punose posoyeos snl [je Aoy} uo Suro’ sem JEYM IU ][9} P[NOM SUO ON “PdjVGO.LI]UI 9q O} SIIVYD 991) PU YSOp B IO} ng woos Ajdtus ue OUT dW JYSNOIG pue SUL dy} Aq SWI YOO} OYM splens OM] IOAO payed Udy) ay ‘Sulyxury) our jod 0} yYsNoud Sug] ing UOTeSIaAUOD jalig Y ‘adensue] Jayjoue Ul sem 3 DOUTS [[9} },UP]NOd | Inq sJoLIodns SITY 0} [Jeo auOYd Bayt] popuNos yoIyM Apayerpowu suoyd oy) UO 109 pue TVILNSCIINOS [eLINey Poyoojosy JyBuAdoy GQ 99700 AND cok IDAO JIM POYOO] J9dYJo sy], ‘UORUUIOJUT pajsonbol oy} JOAO papuey | pue ‘soumy) Jo Auew ouop pey | snl “jysnoy} | woyqoid ON ‘Joyxon Surjedep AU 99S 0} poyse A[[euOTIppe oy yodssed Aw SulurejgQ ‘JS901JJO stuojsnd dU} 0} S}USTINIOP SUI[OARI) PUe UOTeIe[SOp pousdIs AUI ISAO Surpuey S[]TYO OY} 103 | ‘OJI[ INOA JOAO UDIS A[SUTTPIM 0} JYSNOY] e JeYM jnq ‘ynoge AUOM 0} SuryjAue pey | YI ION “Ayjeuod ojeuIT]N oy) se YIwop YIM SOSIVYO DOV} Pue pojso.ue oq PpnoOM om ‘AluOdeomM JO sdtup Aue SulALes DIOM OM JI IBY) SN POWIOJUL JOY] JUSTIOJLIS UOTJBIL[OOP B PopuLY s19M OM JJO 103 0} pomoyye sem Jasuossed Aue oJ0Joq pue popuey sued oy) Joyy ‘soulddiyiyg dy} ul souejd osueyos 0} pey | [yun 14S oy} Jo Ayolew oy} Suidoojs ‘om Buiod sem diy oy p, ‘SWUe SULAO] spueqsny AW 0} youq 193 0} IBM J, UP[Nod | ou JO peoye Aousnol au} JO S}YSNOY) oY} ATUO YIM UO Yd}OI]S 0} PSWS JYSI]J OY} UO UOTJeINpP oy) jo sinoy Ayysug] oyL, ‘sourddiplyd dy} 0} 19A0 do}s e 9xBUW O} BABY Pjnom ] Ng Jay}0 Yoed JO NOY SWS 9} UTYIIM POALUe Jey IYSILY Surpuodsass09 B punoj pey om Ayayeunqio4 “Apoyeredos erpeysny ul suipuey oq pynom om JUROUL WY UIOl 0} SU JO} IJO] S}B9S S]qQe[IZAv OU Puke Poy,OO-d1d sem J94914 S d1GqGOyY 20UTs ‘soueyd oyesedes ur JJO oOM OM BUIWIOW yxoU OU) Ape "POARS OOM am ‘ABP SUIMOTIOJ Oy} WOdu1e 9y} 0} Lx¥} eB JOJ Aed pure [a}soy sioyoedyouNq B ye JYSIU 9y} JOJ WoO] dvoyo ATjeOI & yUdI 0} AouOW Ysnous ysnl YA “OIOM | PUR dIQqOY Pajejseaop MoY Mes Ady] UOYM JYeq PuRsNoy} OM} JNOQE SN ACT OYM PUPISI 9Y} UO WOSaI oY) TWO oJdoad solu AT]eoI SUOS UM Spud speul pey om ATION] “J9}j0q UOTRTYIS OY} Oye OF SurAN soXd posi) Siy pue yorq AW paqqns siqqoy ‘Aeme 1Yysi1 poyorued | “djoy 10) [[Wo 0} SUO OU YIM puke SUILIOLU SU} UT YOO]9,0 OA} Je BYOIG Ajajoyduiog ‘1oJ dn ou SulUIey Usoq pey AdJor IJt] OYJ JJO ey },USeM ]I SB Jsoq MOUY Pinom | ‘QUOaTIOS JOJ peg Jey} dq A][RdI P[Nod ssulyY} ‘Jorfoqsip pue ysnssip UI SPedy INO YOOYS | pue sIQqoY “JOWIO}sNd SuLNy[e JxOu OY) JOJ Suyiem gino 94} UO UMOP Ydeq Jes OYs se ysed UO poy[eM snl UBL dy) JOAO SOLU) Aue jyosiay Suneadar .jyeq say AjuQ jAssnd ‘Assng’**y909 ON j400',, jno SuuLyiq eulsea Joy SuryoeUs URTOq puK Ue sTY JJO durduey slew -oYs & YIM JOAq-Jassed eb 0} WIS Joy dn payi] Uontaynu Jo yor] snoraqo ue WOIJ JOAO poyouny pue AUMBPIOS ‘SOIJUSADS-PIW JOY UT SUTYOO] Apey B ISIOM SIOLUI SYVUI OO} JNq SVM JI Sk YSNOUS SuTUaIYyS sem Yoysueg Jo A}ID 9Y) UI papueNs “SuIssiu sem Hi UI Spied pue AQuOW INO Jo [[e UM JoT[eM S_,s1qqoy pue ssind Ait pozipeas AT[eWIUI om yey BO} SUTUIOD SOyRIQ SSN 94} JO puNos dy} 0} dn oyOM 9M UOYM PUR SPL GUO] SY} UO daojse [oJ yIOG SAA “SMOTII SB 194}0 Yoo jsulede dn Suruvsy sqeyojywos 105 A][BULy pue SIAOUI Be PayojEM OM J94IO YoRd O} Avs 0} YONTU os skemye yim Aeme SuIeYyD ‘BpesNy 0} No AT 0} Wodiry yoysueg 0} ABM INO UO YdROD SPL 0} PRY 9M [HUN UOOWASUOY INO Jo UONeINp DY} JO} SSI[q sem IBeVLURY] “SIQqoy OA puegsny ev Oo} Sursuojaq pue sim 879 $0 OEegabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVLINTCLINOOD JELapePy powajosy WySUAdOy [5

The text on this page is estimated to be only 43.32% accurate

OVTPFOORLLANIO 9ET | ‘ynoqe ye} 0] poyuRM sjUdse 3} yeYM AT]ORXS JNO PUL] O} JOOP oy] pausdo | “spreMjNO Surjeyxo A[MOJs pue yyealq doap ev Sulyey “oul isn oq 00} Suto’ SEM SUIYIAIAAS ALIOM 00} JOU 3Nq ‘JOA JNOGe SBM STU} JeYM sp! OU PeYy ] wary pyo} | ‘payzznd Suryooy s10y) Sulpueys wry Mes pue osind Aw qeid 0} 1 YSNoIY] pays | uosyM puke sul 0} SuLyye} oIOY Sulop oom Aoy] eyM JNO dINBIf 0} SUTAI] JOOP 3M} JO APIS J9Y}O dy}. UO SulpuRys sem sIQqoY . puosas suo 9q jsul |],] “opisul st osind Aw ‘jt quis pue o¢ 0] SARY [IM [,, WIY Pp]O} | pue Sut] sty) UOSoNb oy) poyse Juase JUdIOJJIP V ..CaSea[d UONROY UIP! SUIOS 998 OM Ae, Poyse usAo Ady} Udy) QOUSPISAI JO 3}¥IS SNOLASId pue swieU AW POWAYUOS | ..{89I"1S PsyUuy) dy) ur AJuNOD yoRag wyeg Wloly AT[BULFIO puke SLLSqOY BIUIGITA “S|A] 198] Ul av NOA JL NOA yse ISU 9M URD,, ‘OIVAU ul yeods 0} SULyse JOOP JO SMB]-UL INOA JB SULYIOUH S]UISe [LIOP] 9914} 19d NOA Jey] [fews suryjAue 1O Jay¥O1} SuLyied & ISAO 4OU S$. JI JO YOO] sy) WoO Jig SuIyJowWos Jo}j JjasAu Suredaid Ajjejusul se {Jam se ‘pies |] ,.AeYO,, “oyeAUd Ul W9q} YIM yeods ABW | LY} OS SPis}]NO SUIWOS ATjeNnjoR PUTUT},UP{NOM | JI poyse Juose uvduauiy oy f ‘ROLWOUTY WoIy juase |g’ J 9UO YIM Blyeysny JO SJUdZe |RIOPS} OM} PUL SIOd.IJJO dood ATTeNnjoe }, UsIOM Ady TL "y[ 2] 0} SPISUT SLUOD O} WY} JajJO 0} JOOP dy} pausdo | UdYM PdLLIOM UDAd }, USE PUR IsITJ ye AOI Jor YIM Op 0} SuIyJAUe PLY jf YUTY) UDdAd J UPIP | “Inoge [Te sem STU} yeyM JNO pul} O} soIqeq oY) YUM AkjS 0} MET UT JOJO AW poyse | .,jSoqoy BIUISILA JO OWeU dy) Aq NOA JOJ SULYSe JOOP 3Y} 1k $ LOdTJJO sotjod SOI) dv SJOY) BUUDS,, JNO poyNyq oy pue ‘o]qQe} ou) 38 SAO PO YJUOW SAL} PUR SYJUOLL UddJIUIU AW BUIPSIJ SEM J S419 M “WIOOI BUIUIP 9Y} OUT Burwos AjyoInb yoeq poysni 3p] ‘}t JOMSue 0} YONOD dy] UO AT SUIyoEM woj dn jo3 Mey Ul Ady RJ AW pue JOOP JUOIJ OY) UO YOOUY & SEM DIOL ‘uOOUIoYe ureyd Jayjour ysnf uo ssnoy Aqiesu oy) ye SMeI-Ul AW SUTPISIA JNO dam OM UdYM ALP UO TRY UappNs & O} SWS SJI] [NJSSI[q ING “SUO] OS JOIJZe SUI JUNLY pUe YOR SOD 0} AT[ENJUDAD OFT] ised At poyoodxa sn Jo Jay}ieu se ‘yoeq pue siosuLM ay) YSnosy) uoTUN INO JO spuog sy} SuNNd ‘1ayjOUR SO JOJ 9q 0} SALY SAA “YOOI PIpOS ATU SI s1qqoy pue uoTepuNo; AW SI BdeIILU INO 9]BY JO PedISUT SAO] GYM JeaY Au Sulpeay pue ‘uoowAsuoy Ino Jo Aep jsv] OY) Ouls ‘speonnsoeueyd Aue Jo Jjo A[a}a]dulog ‘puryoq Yo] ured oy) JO [[e puke sieos oY) YIM ~- [VIP OJ OP P[Nos | Fury AIOAD SUIOp sem | S}sJeTYyOAsd pue sojasunos Auvut ysnosy) djay Suryses 08 ny dy} Jo [[e 19] OF YsNous suo] Ajieou },usem sivad Sunod Aw ul paousuadxa pey | WeYyM jnq spunom ye speay SUIT} RY) Avs AdY f ‘NO Jjas}i OS 0} uLG9q A[MOJS sey oJ1] Pue UTeBe s|IUUS 0] JAQUIDW9I 0} MOY SUI padjay dH “sn Jo OM] dy} JOJ JOays9d ysnf st yey J3}JVW OU ING SMB]J SII INOUIM SUOD ] USSOP PUR YOM PIeY JO JO] B USAR} “TVILLNACIINOD (eLioyepy powoiorg sydAdog j{) s9zrood dando Set Sey }[ “Soinpus osewseW pouIUWajap AIDAd Jey) SMO] PUR SYSIY UOWILUOS SY) poleys savy | pure s1iqqoy ‘10yj}990} JUsds 9m OpPedap Ie9U 9} I9ACO 7 pc tajydeyy ‘Jaye] opeoap eB AjAVdU SARY IJOADU | PuUe ‘SI Jey) DuLyeods Ajjeojasosy) ‘Od UNIT 19] JOADU Pyhom JT MouUy |] yonw os UNY possiu jsnf | ‘O}t] Jeap Joy wy 0JUO SuIpjoy Wy punose sso] pue sue Aww poddeim | ‘suue sry our A[payoxo duinf 0} Aemuns oy} dn Aem 9y] []@ uel pue SoyeS OY} YJeouIOpUN poyonp | “JOSUO] PUOdOS B ]1VM J ,UP[NOd jsnf | “sajed 9y) puryaq ABMuNI 9y} UMOP Sulyyem puegsny Aw Mes | ApjenjudAy “Sut JSI1J 34} JO} syussed sty YM poluedwosor jos SuiAolua sem | ‘MOoyAUe SUI 1OYIOQ }, UPIP I[ “SWIO}SNd JO jno Jos OF WIY JOF SuNrem ysnf sem yng o8v sade papur] pey sued s.siqqoy MoUy | pleog S[eAiLe oy} Supe A ‘pueyley f Ul O]LYM JOY YUM SULALY SIQQOY PsBSYIOAO | SUOT]ESIBAUOD oY} UI popunos sys passols MOY porVdw0d oU Joou AT[BULY O} PdAdl[or Pawioes Ad} J9}J9q J3ayIO YOVd MOU 0} SUINJOd JO SUOT]ESIOAUOS JOUQ SIOW MJ B ISAO IDYIOTO} Suiysney] osessny JO souepunge ue SUIALIED SpUuoTg SuNOA ‘oj10d & OJ INO YOO] 0} WY) P[O} dH “UONdOSap paylejop S.aiqqoy uloyy Aseo sem ou GulziusoSo1 Surdes ‘poysney Mey] Ul Joyyey AAT G10} YOOT 0} TUoyM MouUy Ao] MOY Wo) poyse | ‘sourddryiyg ou) Ut Odie snorAdid oy) Je sIeOS OY) PUR PURTIeY], WJ ISAO YSIEF oy} OAL] SSuIYy) Aue yNOge payeyo [je 9M OALUY 0} OURTd Ss _sIQqoY JO} SUIIEM OTITY AA “MP] Ul-19]4SNep MOU I1DY} JOJ sYIS pey UdAd Ady} SIOMO]J PUL SUOOT[eG OWOS SUI BUIPURH{ “OUNI} JSITJ OY} JOJ OWI SUNOS SMeT-UL AU Sem J], Af IU} INO OUI pue BIYeISNY 0} NOA PsWosjam OyM SOUO SLY SY} 9q 0} pojURM SAA ‘S]USIeEd S.sIQqGoY sv 3M ,, ‘PIES Udy) Me] ul-JoyJoW Mou AW “499U AW puNose sue 1194} poddeim pue soweu IsIy 1d} dw DARTS Ady] UOSanb sy] Je SUIPPON ,.Geuusr nod s1y,, “swe AW poyse pure sul 0} dn poxyem siosuvI]s JOpyo OM) USYM UI JOJ 310}s UI OSsUdINS JoyJOUR SEM dU] ‘USAPY AU 9q 0} SUIO’ SEM STU) ‘poyURM I9A9 | [[@ SPM STU} MOUY | Weoy AU Ul ‘puRp[sWOY MoU AUT UL 00} PIVMIO} BUTYOO] dq 0} YONUI OS PkY | ‘OUIT) ISI] OY} 1OJ [IOS MoU B OJUO puke sued dU} JJO poyxpem | Sdojs ISI SY] JO 9ONOU YOO) | SUII] ISL] OY) JOJ papur] ] SV ‘oll YJeaUag YLed pol SY} 99S P[NOd | MOPUTM OY} INO dUTZOOT "UOOS UIede LUTY YIM yorq 9q 0) AWM AU UO SBM | JEU} POAdI[OI SN! SEM | “WY BUISSTUI sem | YON MOY Pur sIQQGoY Jesp AW 07 YOR JUDM S}YGNOY) AW Jess AW UI papas SEM | SOUO PUR SWI) JO YOIUY OY} Ul OURTd AW AYSNeS |} OAL] IO pey AdY} Jl SUL ULIApUODS 0} Jamod YSnous pey OYM Soulddiyiyg sy} Jo speroyjo dy} YIM JaJUNOOUS SNOTAsId oy] Woy SuIdumnd jjWs sem ouljeusipe ALU 879 $0 Tegabed ‘0€Z8z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDOG ‘898Z-8T aSeD TVILLNACULINOO Jeary payaazo.,, IySUAdeD

The text on this page is estimated to be only 42.86% accurate

HLTPOOTMAAANIO Bel Jasuoy Aue Aq HS 0} d{qe SUING JON “MOU SBUTYJSUIOS OP O} peyY | ‘SYN plo oules 9y} 0} dn Ajsnolaqgo sem oy pue O8e Sug] OS ul sem | UOTTISOd oURS AISA OY) Ul SIG 19410 JOJ SUIDDUOD At paxleds A]JURISUT J] “YIeg [eNUID Ul JOYIOSO} [JOS v SUIAPY MOIPUY 9ULIg pue wiTy Jo sioded oy} UI MES | AdIJJOC UO AIOJS JOYJOUL SEA DIO} JOBUO] YONW ION “SUOTIITJe poyoasrod SI] SULIOJJNS ][Ns sjoos oY) Woody ssid SuNOA asoy) djay 0} suryjAue Op 0} 31qB Suisq ou Aq 1eS ][e OM JIIYM SR] INO Ul SUIYSNe] soUd]OSUI JO MOYS Plog sem i ‘ulaysAs satsnf s1[qnd oy) JOJ ajoRyoads ke OSye yng 39s 0} sWd1A Auew siy Ajuo jou JOJ popusjur Aeydsip dijqnd ev som YI Jt Sy ‘910j9q SUO] Spd Joyo AURUI OS pue sul YIM pey oy AWM AISA BU] “YIOA MON JO $JOAIJs Oy) SuIpesed “yey] UDAD JI *“I9SBUd9] SUIYOO] [NJyINOA AJ9A v puNnole suue sIy YUM AdIfor JO ounyoid B 99S 0} JOS | peajysul ‘ON {S1e9A AUBU 1OJ JUSWIOUTJUOD UL PdyxdO] PIp | ARAN OU) JOJJNS pue ][INS SIy SS9JUOD TITY JdY 0} 199 UDAD | PIP IG 00} 9 JUSS OY S1OYIO dy} JO WY YM Jsed AW BUIAIOI JO Sounjoid YM peoy AW S][J pjoyosnoy suidooys dy} Jo IDUdTIS DY} Pue S}1Y SSOUAIep UdYM de] | soeuysiu AuRW oY} NOYSNOIY) dINpud J[ YS pue poinpuos pey | ured yonw MOY WOU} [[9} pue Aine Jo Juo.Z UI dn puejs 0) dOURYS 3Y) 103 IOAOU | ‘Spunom pjo yeoy 0} ySnous Jou sem wy JsuIese yinsmey AW SuIUUT A, “saeod Aue OS JO} aul jddy pey sy OYM JUSUIUILLDJUD S$ DUOAISAS OF JYSIPJOdS oY} Ul pUe PosseLIEqUIO [D9J Pjnom oy Ssuidoy WIY UO so7pqe} ot} Win} 0} SOTO Oy} pey | ‘uIN} AUT sem 1 MON ‘OS BUOT OS OU JNOgGe JUDTIO}eIS SUIPLIDOP B OFLU O} POI] JEY) ULL & O} JUDLUIDILIS B OYPUI 0} Sed] je JINSME] OY] YIM paod01d 0] dsOYd | ‘posnge Ajjenxas pue A|;eUOTJOWD SUIS JO SIO}JVLU SY) Ul OSTB ING AdIJJo¢ SPIEMO} JINSME] & JO SULIO} Sy} ul AJUO JOU SUI PsyosuNOS AdY) SPUSLIY ULIS} SUO] SAI] “AjpNJJopuom os UI poyeo} 0} OyOdS | JY) ULITY 9Y) Je USWIOM OM) OY] “WedY posojyjeq AW WIO1J SUOTISOND poJOMSUBUN OY) YO9S 0} OP 0} PRY [ UO Jn UOISIDOp 3Iq B SEM SU JO} PaplAold jins WADIA 3Y] UO SIOAME] OY} [Jed 0} SuIPIIOG “Sutd} pue Yoty} Oy) JO [Je Ysnosy) usdq sey oy 91943 pu Jsed SUT]UOUIO) AW JO SMOLIOS 94) SUIPUSU UI OYLUI | JY) DDLOYD AUDAD pUTYyog oq SABMIV []IM SY JY) lu SuJO} ‘sty} [[e JO SurMUISOq OY) WoOIJ SuIpuL}sJopuN Os sem 3H ‘UMOp oprsdn ]]e 1 UN 0} JnOGe ysnf{ sem pue SoAT] Jooms ATdUIIS INO sndejd 0} yoeq SUIOD sey jsed pojqnoy Aw jnq ALIOS OS sem J MOY UY []>} 0} uesoq | ‘ASojode uv qm Suey ‘pouoddey Ayjemoe yeym wry [[9} 0} 31qe SEM | Puk popisqus sqos AW [HUN ow pyoy ysnf oy “ysinsue yons YIM sue sly OJUl SuIsde][od “yx]e} 0) Apes sem | pue Jo}ey SJUSWOW MI Y ‘SUONOWS AU o[IdUI0D 0} JUSWOLU 3eY) OW SAIS O} WIY PSdUIAUOD SOAD AU UL SSOUT[S OY} ING OW PUlYysg PoMoOT]OJ S1QqoyY “pjo} useq ysnf pey | UONeWOJUI OY) ssodold puR jJyosAW osodwOD 0} SJNUIW B PajyuBM | DI9yM PBA Yq OY} 0} JNO JUNM PUR OSNoY 3} TYISNAGIINOOD [elayey poroszoryg wystuAdoy [] OLTPOOMATNIO Lel JO YOR dy} O} poysns | ‘UO Sulos sem jeyM puegsny AUT [[9} 0} sploMm 9} PUL} UDA },UP[NOd | SW PUIYsq JOOP oy} SUISO[D “‘popyong ATjenjoe sso] AU dJOJOq JJASAW ASNdX9 O} PRY | ‘OW ISAO 0} I SUIPURY MOU SEM OFM jud3e ou} WoLy yIomioded Jo s[pung oy} Burye], “YOIs Joo ou Suryeur mou sem YORUO}S AW UI SUTWINYS AJOTxUe OY} puke yeom OF soouy AU JOJ | ‘SABP OBIT[OO OI} UIOIJ SPUSTIJ P[O S,JOAMPT STY OSTe o1oM AOU) J9}e] NO puNo] | Ysnous A]JUSTUSAUOD puP ‘sn IOJ PoprAold oy SIOAME] 2y} WIM WIY ans 0} uONdo ay} pey om Jey) sem UledIeg vod Jey) Jo Wed dSIOM SIOWEW OYeU OT "WOoge SUuIYyJAUL OP 0} 93] 00} [[B DOM 9M PIO} INQ UNJOIA & SUING JO UOTIJESIJNOU SIy) popuLY sIOM OM PROISUT “JOU ILL JO} powuOjul UdAd JO oSpnf pue Aunf eB JO JUOIZ Ul DDIOA B SARY O} POMO]]L }, UdIOM OM ‘SN SAIOS pue J99}0I1d 0} BIDY} A[Posal[e sus FeUONN suo AIOA SU} POA] “SUITJOIA Sn JO AUB 1OJ POAIOS Uddq peYy sousnf ON "UOIPIOOIVOUI Ul SUT] SIy SULATaS O]IYM SOUT] AJUDADS APIVOU 0} BUIJUNODOR ‘UITY JISIA 0} POMOT]P [[YS oI9M SIZ OY} OUITIYSIU Je UDA ‘UONNQLUjaI JO JUNS SuIYysne] siy Suyjnd sem oy O]IYM 9194] soUO AyUO 94} 9q 1, UP;NOM Aayj ‘[]aM OO} [TB Aojor SuIMouyx pue ‘udayjoy Yyeres pue PACU VIPEN ‘Ode sIBdA Ud} JOAO WO SOALIS XOS [BUISIIO Sty YA 9q 0} AJUO YoRog Weg Ul UOISURUL YSIAR] SIY JO JUDUIOUTZUOS DY} 0} PoOLYsoy “Aep dy] SuLNp poseayjoi sem oy SULWIOUL dU} Ul pue OUO][e BULUDAD SU} UT Jey} 9q SIvq PULYsq SYyJUOW Uda}YdIA PdoUdJUIS UY} JO SA[IM) ATUO BUTAIOS UDAD YIM ACME SUTIN “S[Iis JOUIW BY} JO OM) ATUO JOJ oTTYdopoed po1ojsid9I v WUTY poweu yey) sosreyo 01 SUNUSUOD UlesIeq eold B pojURIS sem oy INOS Ul ABp B Suiddoays 19A9 NOYWUM PUR S_dSUdTJO [RIOPd} S, AdIJJof JO SUIIJOIA SB polueU UdEOq PRY Sd USZOP & UY} SIOPY “UOIINITSOId JO UOTJEUSIYOS puke Ul 9deTUd 0} SIOUTLU Jo yuswoinsoid Joy Ayins popesjd ulsysdy Addyyor “SOOT wOE SUNS UO ‘yeods 0} OS ,.Sd9q OY] PU SPJIg 34},, pPUdYoIdWOd UDAd 0} ysnoud pyjo Ajaleg d1aMm OYM SIIB UO UOISIdAIOd JO $19e SNOIDOI]e SIY I0J 1ysneo Ajpeuy sem Adore “CUIJDIA PolUp! ue Julog Jo uONedyyOU eB SLU BULALS SEM BPO], JO JOLISIP OU} IO} SOYJO S$, ADUIONY Saqvig powUuy su] “ssopyooods Jo WOYs Suryjou au Ya] OsuOdsal 1X9U STF] “JOAO OI] SATUS AL PoHe}s PeY | SOUTS SLUT) ISILF OY) JOJ WIOY] YIM Noge Ye} oUOTP 19] NOGe UI) 0} YSnous [Nyowuvys sem I] ,,.99UO WIY MOLY PIp | ‘SoA Jngq “ouruT Jo ayeyIyje ue 1osuo] OU soy pue Ode SW) GUO] v SeM J],, pres pue uoNsonb dy} JO UONRULYJe Ul poppou | ‘Noge JoS1Oj 0} SurA sem | 3eU} OFT] Sed B WOdjJ sIV9A AURUT UT [OJ 1, UpeY | IVY) JOUY JeI[IWL] & UI poysuR) YORWO}S AW Uappns 94} Jo [[y “Ulojsdq Aojor “A JO oweu oy} Aq oyeljyye UB UMOUY IOAd peyY | JI OW poyse jose oes yey) UO, ‘Joded Jo yous poydejs e ino Surye} dn yt pouodo pure Joo yosod ay} Jo osvosoriq eB du poyord yuase suQ “jUIod oy} 0} 1YSrIeIys JUOM Ady} ‘Ja0I19 PuL JOO OU SEM Moy] “sourys yoinb e& je pooyyns d49m ADU} INQ WISY} 0} JOAO JI PuRY 0} BUIOD Sem | ‘JoTTeM AW WOIJ SsuddT] SIOAUIP UuRITeENSNy AW Jno Suing 879 $0 cegabed ‘O€Z8Z9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD TVILELNACLINOD [LLIAIePY Poros10) | IBUAdOD [|

The text on this page is estimated to be only 43.33% accurate

CLEFOORRELAALD TWILNACLINOO eLePOOMUIAINIO TWILNACLINOOD jee] porsjosy WySLAdOD | JELOIC) Poyoos,| IYTUAdOD | | OrT 6€1 S}1IQOY BIUIBALA AQ PIJVAYSN][[] PUL UIA pug oyL ‘nos puke zWIds AU JO JOLARS AIOA 3Y} SI} aSNedAq ‘3AO] UI JOl[9q S]IIs AI9Ad Joy dn pues | ‘][e Jo sow ing “UMOP WAY} Spyoy Jey) asnqe oy) JO Ino Jod 0} BFQvUN puke JUdUIDAR[SUS ul paddey [[Ws s]ui3 ay) [je 104 “soursvedde sptsjno a1, Aay] puodaq 92s 1, UOP OYM S]IIB [NJYNeaq ay} Jo |[e JOJ “9J1] JO INO DIOW O} PoyyUs 9q 0} WIBSIP I{QRADIYOLUN UP $_}1 JO 19}]9q DAIOSAp 1, UOP Ady} JULY] Puv S}99I]S 94) UO [[YS se OYA SOUO dU} ‘spits sn Jo [[e JOJ ‘sn oj dn pues mou J ‘03k SUC] Pip s1Qqoy SAI] VOU aU JO] dn pOOj}s BUOSWOS Jey} BAdT[Oq 0} papseu | OXI] ysNe “URD sUOAUP UL} ‘P]JOM INO Jo sjoxood daap ayy UT yey} sjuesA} oy} ysulese dn puvys ued ‘oul ay1] ‘VPLIO]J JO SJSaNs ayy JJO IIs QWOS JJ “W 94e) pue dn pues si op 0} aaey NOA j[e “URM NOA Jey S_JeY} JLSINOA St UOOU dy} Jey] SdUSTIBdxS UMO AU WIZ NOA ]]9} 0} BOY UL] ‘Joyjoue JO spuey dy} JB Polajjns 19A0 sey OYM UOSIed A19A9 ING suOHoIUl S, AdIjar Jo ysnf JOU “SLUTJOIA I9YIO 3Y} JOJ sues BY} 9q Pynod }I YSIM ATUO | ‘Rady AW Jo aptsul sao] 94) poAoNsop Ajiesau yey) Sopsdnuys SY} WIOIJ 9d1J MOU WE | AT[NJxuURYy, “uiyM Ajdsop pappaqui Apealye OJIM SILOS SY} US] pure dJe] 00} SEM JI [NUN SUS IDABU JY] aNdsal dy) Jo} Suem pur Aw jo ino Sulod ajty Aut Jo yOntu Oo} Juads | ‘gas 0} o1[qnd ay} JO} [IaAuN 0} pouaddey os | Jey} Joyjado) poseys ] pue Mapuy soUlIg Jey) IYSIU ysITJ OY) SuIMOYsS sojoyd ay Jo asvayjal JY} UONUDU 0} JON “AZUDIJ OUT JSIOI[Gnd s, AdIJjar JUSS | [Jeo auoyd auo YUM BIpaUl Jo adins e Aq Aeme dams ‘sorsnfl 10} sarso pasodstyM AU UT} JEY 0} BUION SI PjJOM 9Yy) MOU PUR SdIOA B dAeY OP | “dn yeads oj Ajyqe dy} pue sd10A JoUUT AW UT JOI}Sq ay) “YISUaNs Atu atURdaq ofl] ALU UT UO J9qL] [HUN Sug] ye paypley pey | uOsssy JopIVY sy], “JI [[9} 0} Apvol tue | MOU puke UIRISNS P[NOd | 39eINOD JO Iq AISAD DALJAp 0} pey J opise sueys Aw Suing ‘noge yeads usa 0} SBA JI [HJawWRYs MOY 191}eUI OU AJOys AW 119} 0) pey | ‘ABA OWS Ul JNO dyay 0} 3]qQe Buloqg jo adpojmouy oy) YM 879 $0 cegabed ‘OEZ8Z9IZ ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD :

The text on this page is estimated to be only 35.06% accurate

PL7FOORAANID TVYLENSCIINOD JEUNE poyooqos YS WAdOD [y Tvl 879 $0 vegabed ‘0€Z8zZ9Z ‘6T0Z/60/80 ‘8Zz JUaWNDO ‘898Z-8T aSeD »

Case 18-2868, Document 278, 08/09/2019, 2628230, Page635 of 648 EAHIBIT LL

a Case 18-2868, DOCURHIEL RS BR ONCORP ORATION Page636 of 648 In compliance with Chapter 617, F.S., (Not for Profit) ARTICLEI NAME. ae ; che ani ot the corp auonehellbe: Victims Refuse Silence, Inc. ARTICLE IT __ PRINCIPAL OFFICE Principal street address: Mailing address, if different is: 425 North Andrews Ave. Suite 2 Fort Lauderdale, FL 33301 ARTICLE IT PURPOSE ; er . ,.. Victims Refuse Silence, Inc. is organized exclusively for charitable and The purpose for which the corporation is organized is: educational purposes including, for such purposes, the making of distributions to organizations that qualify as exempt organizations under section 501(c)(3) of the Internal Revenue Code, or the corresponding section of any future federal tax code. The corporation is organized to provide assistance to victims of sexual abuse as well as victims of human trafficking. Upon the dissolution of Victims Refuse Silence, Inc., assets shall be distributed for one or more exempt purpose within the meaning of section 501(c)(3) of the Internal Revenue Code, or corresponding section of any future federal tax code, or shall be distributed to the federal government, or to a state or local government, for a public purpose. ARTICLE IV | MANNER OF ELECTION __The manner in which the directors are elected and appointed: The manner in which the directors are elected or appointed is provided in the bylaws of the Corporation. ARTICLE V INITIAL OFFICERS AND/OR DIRECTORS Name and Title: Virginia Roberts, Director Name and Title: imi; me oe, | CO J Address 429 North Andrews Ave. Address: es ee a ‘ ay CTF Suite 2 7 = Fort Lauderdale, FL 33301 wis a Tri) PS Name and Title: bradley J. Edwards, Director and Title: on Suite 2 Fort Lauderdale, FL 33301 Suite 2 Address: Address:

Case 18-2868, Document 278, 08/09/2019, 2628230, Page637 of 648 Name and Title: , Name and Title: Address Address: ac, Name and Title: | Name and Title: Address Address: ARTICLE VI_ REGISTERED AGENT The name and Florida street address (P.O. Box NOT acceptable) of the registered agent is: ade 425 North Andrews Ave., Suite 2 po oe alleen mnie on 2 2 7 Fort Lauderdale, FL 33301 ryt a Te me gy) iF] ARTICLE VIT___ INCORPORATOR sO — 3 The name and address of the Incorporator is: . ORS 425 North Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 Address: Having been named as registered agent to accept service of process for the above stated corporation at the piace designated in this certificate, | am familiar with and accept the-eppotnime as registered agent and agree to act in this capacity Required Signature of Reptsrered Agent Date I submit this document and affirm that the facts stated herein are true. [ am aware that any false information submitted in a document to the Department of State constitutes a third degree felony as provided for in 8.817.155, F.S. mai QAIQ QOL Ls IZ WA Required Signature of Incorporator Date

2015 FLORIDA NOTEOR PROM CORPORATION AMENDED ANNURESZ90, Page6ss Gipg REPORT DOCUMENT# N14000011657 Entity Name: VICTIMS REFUSE SILENCE, INC. Current Principal Place of Business: 425 NORTH ANDREWS AVE., SUITE 2 FORT LAUDERDALE, FL 33301 Current Mailing Address: 425 NORTH ANDREWS AVE., SUITE 2 FORT LAUDERDALE, FL 33301 FE! Number: 47-2627774 Name and Address of Current Registered Agent: EDWARDS, BRADLEY J 425 NORTH ANDREWS AVE., SUITE 2 FORT LAUDERDALE, FL 33301 US Apr 22, 2015 Secretary of State CC7801725405 Certificate of Status Desired: Yes The above named entity submits this statement for the purpose of changing its registered office or registered agent, or both, in the State of Florida. SIGNATURE: Electronic Signature of Registered Agent Officer/Director Detail : Title PRESIDENT, DIRECTOR Name GIUFFRE, VIRGINIA L Address 425 NORTH ANDREWS AVE., SUITE 2 City-State-Zip: FORT LAUDERDALE FL 33301 Title SECRETARY, DIRECTOR Name HENDERSON, BRITTANY N Address 425 NORTH ANDREWS AVE., SUITE 2 City-State-Zip: FORT LAUDERDALE FL 33301 City-State-Zip: VP, DIRECTOR GARVIN, MARGARET A Date 425 NORTH ANDREWS AVE., SUITE 2 FORT LAUDERDALE FL 33301 | hereby certify that the information indicated on this report or supplemental report is true and accurate and that my electronic signature shall have the same legal effect as if made under oath; that | am an officer or director of the corporation or the receiver or trustee empowered to execute this report as required by Chapter 617, Florida Statutes; and that my name appears above, or on an attachment with all other like empowered . SIGNATURE: BRITTANY N HENDERSON Electronic Signature of Signing Officer/Director Detail DIRECTOR 04/22/2015 Date

Case 18-2868, Document 278, 08/09/2019, 2628230, Page639 of 648 EK AHIBIT MM

Case 18-2868, Document 278, 08/09/2019, 2628230, Page640 of 648 UNTIED STATES DISTRICT -COURT DOUTHERN DISTRICT OF NEW YORK CEASE -NO< 15-cv-07433-RWS VIRGINIA bL.. GIUPPRE, PlaincCict & -vsGHISLAINE MAXWELL, Defendant. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Thursday, September 8, 20106 Oro] Ont. = 10250 ei. VIDEOTAPED DEPOSITION OF BRITTANY HENDERSON Taken before Rinat Katz, Reporter, a Notary Public £Or the Seate of Florida. a. large, pursuan. to Notice of Taking Deposition filed in the abovestyled cause. MAGNA®© LEGAL SERVICES

LQ il LZ iS 14 LS IG I] 18 19 20 wah ZZ 23 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page641 of 648 APPEARANCES : On. Behalf of the Plaintitt: BOF JS, SCHILLER © FLEANER,. P.A. 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, Florida 33301 smccawley@é@bsflilp.com Iie SIGRID MCCAWLEY, ESQUIRE On Behalf of the Plaintiff and Victims Refuse SL wenee, JMC. = FARMER JAFFE WEILSSING EDWARDS FISTO LEHRMAN 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Brad@pathtojustice.com pee BRADGEY WJ. —BHDWARDS, ESOULRE On Behalf of the Defendant: HADDON, MORGAN & FOREMAN 150 East 10th Avenue Denver, Colorado 80203 (303) S3l—7504 Jpagliuca@hmflaw.com Die JEFFREY PAGHIUCA.. BOOULRE Also Present: Ryan Kick, Videographer MAGNA®© LEGAL SERVICES

ea Gs By sS CO w7 Oo 10 11 12 2 14 Lo 16 1] IL he 20 ZA A Zo 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page642 of 648 INDEX OF PROCEHEDINGS VIDEO DEPOSITION OF BRITTANY HENDERSON Direct Examination by Mr. Pagliuca Certificate of Oath Certificate of Reporter Witness Letter Errata Sheet DEFENDANT'S EXHIBITS NUMBER DESCRIPTION Exhibit, 1 Amended NOD ES bre, Z Motion to Quash Composite Esha bre 3 Bates Stamped O1 - 064 Exhibit 4 Bates Stamped 064 - O91 Bocistioase. 2 AreLeCles Of Incorporation Exhibit 6 Bank Statements ExoUbit 7 2015 Annual Report Exhibit 8 2016 Annual Report (Exhibits Retained by the Court Reporter) MAGNA®© LEGAL SERVICES Page 3 PAGE 13 74 gs 76 PAGE 14 20 ae Se 6 41 62 62

10 i LZ LS 14 I kG iy, 16 Ls 20 21 ZZ Zo 24 ZS Case 18-2868, Document 278, 08/09/2019, 2628230, Page643 of 648 Page 1/7 she has continued to try and promote Victims Refuse Silence at every possible chance she gets with -- the story she told me was that someone had come to her door, knocked on the door, selling something or talking about something totally different, and she explained what our mission was and tried to get them to, then, go and spread the word for victims of human trafficking, as well. QO And this would be in Australia this conversation occurred? A Correct. Q Okay. To your knowledge, is VRS incorporated in any fashion in the country of Australia? A LE 2S: 19GC.. Q To your knowledge, does VRS have any website presence in Australia? A I believe that the internet works everywhere, so I would say yes, because, if you Google Victims Refuse Silence, we do have a website. So I would imagine that that's something that would come up in Australia. Q Okay. Other than the somebody knocking at her door, that conversation, did she report to you anything else that she has done on behalf of Victims Refuse Silence in the last year, let's say? MAGNA®© LEGAL SERVICES

10 i LZ LS 14 I kG iy, 16 Ls 20 21 ZZ Zo 24 ZS Case 18-2868, Document 278, 08/09/2019, 2628230, Page644 of 648 Page 18 MR. EDWARDS: Ob7eCcuion. == THE WITNESS: During this telephone CONVerSallon == BY MR. PAGLIUCA: Yes. == OF Ii) general? During this telephone conversation? PrP IO PF wo She did explain that, when she goes to her kids' schools and when she is out, she tries to promote the organization, as well, and just talk to people, and general awareness and understanding to raise -- for issues of human trafficking, yes. O And did she report anything else to you during this phone conversation? A During this particular conversation? QO Less A NO « Q Okay. Then, you indicated that you reviewed your file for all the paperwork, and we'll talk about the documents produced in this case in a moment. Can you tell me, other than what has been produced as part of the response to subpoena issued to VRS, what other documents are in the file that you reviewed? A I have saved every piece of mail that has MAGNA®© LEGAL SERVICES

10 11 eZ 13 14 ks iG 17 18 Lg 20 Zi ZZ Ze 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page645 of 648 Page 27 "oublication,™" would be the Facebook page; correct? A In addition to the website, yes. QO Okay. Number 11, documents relating to all appearances. As I understand it, there are no documents that exist that comply with this request; correct? A Correct; to my knowledge. QO Do you know, has anybody on behalf of VRS made a public appearance on behalf of VRS? A I believe that there was a scheduled appearance, yes, one. O And when was that? A I honestly don't know when that took place. I would imagine in the beginning of 2015. @ And do you know who was scheduled to appear in the beginning of 2015? A Ms. Giuffre. QO And do you know where she was scheduled to appear? A I believe in New York with ABC. @ And that would have also been with Mr. Fdwards and Ms. McCawley; is that correct? A I believe so, yes. QO And in fact, she did go to ABC and give a taped interview, correct? MAGNA®© LEGAL SERVICES

10 i LZ LS 14 I kG iy, IL Lo 20 21 ZZ Zo 24 Ze Case 18-2868, Document 278, 08/09/2019, 2628230, Page646 of 648 Page 28 MS<« MCCAWLEY: “Object1onTHE WITNESS: It's my understanding, yes. BY MR. PAGLIUCA: Q Okay. Is it your understanding that that was on behalf of VRS? A I do not believe her appearance there was made on behalf of VRS, but I do believe that -- I know that she wanted to promote the charity, so that we could start helping people and that she could start Gerecing Mer Mission Out toO- The public. Q Okay. Number 12, all contacts received by VRS through its website, or otherwise, to schedule -- I think it should say "an event," and "and event." There are none of those, as I understand it? A No, that 1S not correct. We produced a -yes, we did produce something to you. I'm not sure what the Bates Stamp number is, but it was a contact received by another victim of sexual assault who had reached out to the organization. O An ‘emewl, d. thank. tos 1n December Of. Z015, maybe; is that what you're referring to? A I believe -- I'm not sure of the date. I guess. O We'll look at it. And that would be the only contact received by VRS; is that correct? MAGNA®© LEGAL SERVICES

OO” ss] «Oy, OF aa WwW WN 10 dd IZ LS 14 iD 16 1] IL he 20 ZA A Zo 24 25 Case 18-2868, Document 278, 08/09/2019, 2628230, Page647 of 648 Page 7/2 CH RT EF Lt © & T EB -OF OATH OLTATE OF FLORIDA COUNTY OF BROWARD I, Rinat Katz, Reporter, Notary Public, State of Florida, certify that BRITTANY HENDERSON personally appeared before me on the 8th day of September, 2016, and was duly sworn. Signed this 22nd day of September, 2016. Rinat Katz, Reporter Notary Public; State of Florida Commission No.: FF4576 COMMLSSLOnN Expires; O04-03=—2Z017 MAGNA®© LEGAL SERVICES

HS Ov Ol I il ll LZ iL 14 iL 16 iy 18 Lg a0 Za ZZ ZS 24 Zo Case 18-2868, Document 278, 08/09/2019, 2628230, Page648 of 648 Page 73 CHRTIFILCATE. OF REPORTER STATE OF FLORIDA COUNTY OF BROWARD I, Rinat Katz, Reporter, certify that I was authorized to and did report the deposition of BRITTANY HENDERSON, that a review of the transcript was requested; and that the transcript 1s a true and correct record of my stenographic NOEeS. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the aCe LOM, Dated this 22nd day of September, 2016. Rinat Katz, Reporter MAGNA®© LEGAL SERVICES

Selected docket entries for case 18—2868 Generated: 08/09/2019 10:17:16 Document Description Docket Text 08/09/2019 |279 UNSEALED SUMMARY 2 JUNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 5 of 13 , pursuant to the Court's decision dated DOCKETED July 3, 2019, DOCKETED. [2628231] [18-2868] 08/09/2019 |280 UNSEALED SUMMARY UNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 6 of 13 , pursuant to the Court's decision dated DOCKETED July 3, 2019, DOCKETED. [2628232] [18-2868] 08/09/2019 |281 UNSEALED SUMMARY UNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 7 of 13 , pursuant to the Court's decision dated DOCKETED July 3, 2019, DOCKETED. [2628234] [18-2868] JUDGMENT RECORD, appendix 8 of 13 , pursuant to the Court's decision dated DOCKETED July 3, 2019, DOCKETED. [2628236] [18-2868] 08/09/2019 (282 UNSEALED SUMMARY UNSEALED SUMMARY JUDGMENT RECORD,

Case 18-2868, Document 279, 08/09/2019, 2628231, Pagel of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Bg ag ee xX VIRGINIA L. GIUFFRE, Plaintiff, V. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. Sao a eee ee XK Reply Brief in Support of Defendant’s Motion for Summary Judgment Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10" Avenue Denver, CO 80203 303.831.7364

Case 18-2868, Document 279, 08/09/2019, 2628231, Page2 of 37 TABLE OF CONTENTS PRE TTVETINAR Y SEAT VN ss sbictmentcrtemcatonsimeaaantanntnaianemdansan tata ausundntannenaiannmaansanmtanaunes I PT IIT aces deteeet cae cecce erecta eectbcatencae case ceccunncee aewiceicamoncecuencescuassescienne a ceeneeecue eee: 2 I. Ms. Maxwell is not liable for republications of the January 2015 statement. .............. 2 A. Plaintiff's argument against summary judgment is substantially groundless. 2 B. New York state and federal courts have rejected liability for republication BaseGsOil 1OLCSCCAOMILY. acsascsusnsetecsacemnastansscespacssndaniansaorbacssiatateusueeenneiansanesaans 5 C. Plaintiffs purported application of the Geraci rule is misleading and wrong. Sasrhcess dic acicencaueicate ea sioetosateieatansdaerectttcamrnt ae auiseauteratemedeaeanteensansieanianneenteaneeadauneedanseans 6 D. Subjecting Ms. Maxwell to liability for the media’s republication of excerpts they unilaterally selected 1s particularly Unfair. .............cccccccccccccceceeeeeeeeeeeeeeees 9 E. Mr. Barden’s declaration 1s perfectly proper.............ccccccccsssseeseeccceeeeeeaeeeeeeees 1] F. Plaintiff effectively has confessed Arguments I.B. and I.C. of the IV MS iO NCU ass ana cse scents en eecanstacetunaaaceeean ares cteacataeseecaas seeeeeeceanneentee: 12 II. The January 2015 statement is constitutionally protected Opinion. ............. cc eeeeeeeeeee 12 Il. The pre-litigation privilege bars this action. ..........cccccccssssssseccceeeeeseeeeseeeceeeeeeeaaaeeeeeees 20 A. The privilege applies to the January 2015 statement. .............cceeeceeeceeeeeeeees 20 B. Malice is irrelevant to the pre-litigation privilege. .......... cc eeeeeeccccceeeeeeeeeeeeeees 21 IV. Ms. Maxwell’s January 4, 2015, statement 1s nonactionable. ................cccccccceeeeeeeeeees 25 V. Summary judgment is warranted because plaintiff cannot establish falsity or actual malice by clear and CONVINCING CVICENCE. ...........ccecccccccccceeseeeeseeeceeceeeeaseeesseeeeeeeeeeeaaaas 25 IN ISIN, rs seecis sec seers once stapes aataaracs nestar eseace fonts teoceosadaaace nase temnatienonsunee seonasusncesasendas: 30 Ce FT oR ar rs ns crncts sree ceps tata sera neha encis rane tempat ea aes nattaencin casas 32

Case 18-2868, Document 279, 08/09/2019, 2628231, Page3 of 37 TABLE OF AUTHORITIES Cases Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). oo... eeccccccsssseccccaeeeeceeeaeeeeees 9 Blair v. Inside Ed. Prods., 7 F. Supp. 3d 348, 358 & n.6 (S.D.N.Y. 2014)... eee 25 Cerasani v. Sony Corp., 991 F. Supp. 343, 351 (S.D.N.Y. 1998)... eccccccccsesseeeeeees 3,4 Chambers v. Wells Fargo Bank, N.A., No. CV 15-6976 (JBS/JS), 2016 WL 3533998, at PS IN Noe DUIS 2 Oi KO) inaais nodes aeacwadautane dau aeasasouequadedawosssaguessntagis sasaqnearaiseian weiaasaadle: 2, 20 China Med. Techs., Inc., 539 B.R. 643, 658 (S.D.N.Y. 2015) oo... cecccceseccceeeceeenees 12 Cowan v. City of Mount Vernon, 95 F. Supp. 3d 624, 645-46 (S.D.N.Y. 2015) ......... 13,25 Croy v. A.O. Fox Mem’! Hosp., 68 F. Supp. 2d 136, 144 (N.D.N.Y. 1999) oo. 3 Dalbec v. Gentleman’s Companion, Inc., 828 F.2d 921, 927 (2d Cir. 1987) ...... eee 25 Davis v. Boeheim, 22 N.E.3d 999 (N.Y. 2014) oo ceccccecceseccessscesscsencseessueseeness 14,18 Davis v. Costa-Gavras (“Davis IP’), 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984) ....... 2,3,4,6 Davis v. Costa-Gavras (“Davis IT’), 595 F. Supp. 982, 988 (S.D.N.Y. 1984) oo... 3 Dibella v. Hopkins, No. 01 CIV. 11779 (DC), 2002 WL 31427362, at *2 (S.D.N.Y. Oct. OO) OO Vases oases sacs 2c cc sneeen spacsescon case acenstscsosseeyadoane se aaa asese aoe: 20 DiBella vy. Hopkins, 403 F.3d 102, 111 (2d Cir.2005) occ. cecccccccccesseeecceeeeaneeeeeeees 25 Egiazaryan v. Zalmayev (“Egiazaryan I’), No. 11 CIV. 2670 PKC, 2011 WL 6097136, at BO IN a Yes 15. 2 OL) sensconaeesousaes ten yewe ences gos naw seesiene sss doses wssaes gasses eee ees se 3 Egiazaryan v. Zalmayev (“Egiazaryan IT’), 880 F. Supp. 2d 494, 501 (S.D.N.Y. 2012) secede asec tari tea taeiseat sate ei meri datesatha ae uciesinens Cent ceiemmcianeteatieei nantes debemee: sanenanansnessaice: 3,4,5 Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906) oo... ees ceeccceeecsceeecceeecseeseseesesens 2,4 Front, Inc. v. Khalil, 28 N.E.3d 15, 16 (N.Y. 2015) wo. cecsscetrereeees 2, 20,21,22,24,25 Geraci v. Probst, 938 N.E.2d 917, 921 (N.Y. 2010)... ccc eeecceeeeeeeee 2,3,5,0,8, 10,13 ll

Case 18-2868, Document 279, 08/09/2019, 2628231, Page4 of 37 Green v. Cosby, 138 F. Supp. 3d 114 (D. Mass. 2015)... ecccececccceeseeesseseeeeeeeesnanees 14 Hawkins v. Harris, 661 A.2d 284, 289-91 (N.J. 1995) oo. ccccccesecceesccceecsseeceeeness 2, 20 Hickman v. Taylor, 329 U.S. 495, 510-11 (1947) oo. ccccccccsseccccceeeecceeeeeeceeeeneeeeeeeas 12 Hoffman v. Landers, 537 N.Y .S.2d 228, 231 (2d Dep’t 1989) oo... cece cccssssssseeeeeeeeeees 5 Immuno AG v. Moor-Jankowski, 567 N.E.2d 1270, 1274 (N.Y. 1991) oo cc eeeees 13 Karaduman v. Newsday, Inc., 416 N.E.2d 557, 560 (N.Y. 1980)... eccccccceseseceeeeeeeeeeeees 3 Karedes v. Ackerley Grp., Inc., 423 F.3d 107, 114 (2d Cir. 2005) oo... ecccccccsssseeeeeees 26 Law Firm of Daniel P. Foster, P.C. v. Turner Broad. Sys., 844 F.2d 955, 959 (2d Cir. WS seis ecactece aia terse scene aceeacieatrce cia aes barca aadic aes eacinsns saat ss iananeaebaneeseaaasansesaanes 15, 28, 29 Levy v. Smith, 18 N.Y.S.3d 438, 439 (2d Dep’t 2015)... cece ssssnnnnrccccceeeeeeeeeeesssseeens 5 Liberman v. Gelstein, 605 N.E.2d 344, 349 (N.Y. 1992) ooo eccccccscccesecsceeceeeeeseeees 22 National Puerto Rican Day Parade, Inc. v. Casa Pubs. (“NPR”), 914 N.Y.S.2d 120, 12223 (1% Dep't 2010) ..cccecccccccccssccsscsccscsscscsscsccscsscscssssessssesscsusscssssessssesecsussessssseesseseeen 5 Oilman v..VGns: JOOP .2d.970 W)C, Cir, 1984 ) ncicssssnssassedasiadpeienssnestiincnadansastocmssaanesiesee. 13 Phila. Newspapers v. Hepps, 475 U.S. 767, 773 (1986). ......cccccccccssssssecceccceesseeceesseeseseeees 26 Porky Prods. v. Nippon Exp. U.S.A., 1 F.Supp.2d 227, 234 (S.D.N.Y. 1997)... 2 Rand vy. New York Times Co., 430 N.Y.S.2d 271, 275 (1" Dep’t 1980) oo... eeeeeeeee 9,10 Rinaldi v. Viking Penguin, Inc., 420 N.E.2d 377, 382 (N.Y. 1981)... eccccee eee ee 2,351 Rinaldi v. Viking Penguin, Inc., 425 N.Y.S.2d 101, 104 (1% Dep’t 1980)... eee. 3 Rizzuto v. Nexxus Prod. Co., 641 F. Supp. 473, 481 (S.D.N.Y. 1986), aff'd, 810 F.2d OM AC 1 SO) crs asec ca esac ressnsa des aancnss cassia daiaracndansingenassacngassiucedageeadnasaenucuaecnsans: 16 schoepjlin Vc. Copey, 56 Ns SO2'(N. YA 90D) wresscdsncecoeesveinats seein vicdeenonatvenenntecersiadbavecntint 3,5 Steinhilber v. Alphonse, 501 N.E.2d 550 (N.Y. 1986)... eeccccccseecceeeeeeeceeeeeeees 11,13,16 il

Case 18-2868, Document 279, 08/09/2019, 2628231, Paged of 37 Sweeney v. Prisoners’ Legal Servs. of N.Y., 538 N.Y.S.2d 370, 371-72 (3d Dep’t 1989). Saphira ae ces eB cesetncar tad eanariectm aren ateeasieantnamapttenanateaetenscasdeeeeianesteenscueatetenscaeteetaneeeme eee 19 Telephone Sys. Int’l v. Cecil, No. 02 CV 9315(GBD), 2003 WL 22232908, at *2 COIN Vi Sele 27s 2 OO) erseaenserasanensacinags naraicer ssaussesasenasassiotagsuaraisessseawie asasndeadedese as 16, 30 Travelers Indem. Co. v. Northrop Grumman Corp., No. 12 CIV. 3040 KBF, 2013 WL OOD 97 ie GINS Vg 2 2D) te ec saeteeahinigi es ea es ae 12 United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). oo... eccccceseeeceeeeeeeeees 25 Rules Federal Rute or Civil Procedure 1200 )( 6) sacsisciesasucncvissavevoovdendciecasacaiasasnviiedarsesenbestenbedasavnons 5 Treatises Sack on Defamation § 2.7.2, at 2-113 to -114 (4' ed. 2016) ...cccececccscsssesesecesesescseesseeeeeeees 4

Case 18-2868, Document 279, 08/09/2019, 2628231, Page6 of 37 PRELIMINARY STATEMENT Before the Court reaches the question whether plaintiff can prove falsity and actual malice, it should decide three questions of law, one that narrows considerably the legal issues and two that dispose of the case entirely. 1. Itis undisputed Ms. Maxwell, through her agents, sent to various mediarepresentatives—and to no one else—the January 2015 statement. It is undisputed she had no control over any of the media that decided to republish excerpts from the statement. On these facts, under black letter New York law, she is not responsible for these republications. Plaintiff's contrary argument relies on a “foreseeability” doctrine the New York Court of Appeals has specifically rejected. Summary judgment should enter in favor of Ms. Maxwell as to any republication. 2. Under the New York Constitution, whether a statement is constitutionally nonactionable opinion depends upon, among other things, an examination of the full context of the communication and consideration of the setting surrounding it. The January 2015 statement, making no reference to specific allegations, explains why the author believes plaintiff s allegations are “obvious lies”: “Each time the story is re told [sic] it changes with new salacious details... .” It 1s an expression of a venerable opinion: when a person falsely cries wolf previously, others are free to opine she 1s telling falsehoods now. This is nonactionable opinion. 3. Under New York law, a statement made pertinent to good faith anticipated litigation 1s nonactionable. The statement was sent exclusively to the media representatives, and contained a clear message: the media should not republish plaintiffs “obvious lies,” else Ms. Maxwell would sue them. Such a statement is nonactionable. If the Court reaches the question of falsity and actual malice, the Rule 56 record establishes plaintiff cannot prove falsity and actual malice by clear and convincing evidence. l

Case 18-2868, Document 279, 08/09/2019, 2628231, Page/7 of 37 ARGUMENT I. Ms. Maxwell is not liable for republications of the January 2015 statement. Under black letter New York law, liability for republication of an allegedly defamatory statement “must be based on real authority to influence the final product.” Davis v. CostaGavras, 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984). “[W |here a defendant ‘had no actual part in composing or publishing,’ he cannot be held liable.” Jd. (citing Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906)); accord Geraci v. Probst, 938 N.E.2d 917, 921 (N.Y. 2010). “[C/onclusive evidence of lack of actual authority [1s] sufficiently dispositive that the [trial court] ‘ha[s] no option but to dismiss the case ....’” Id. (emphasis supplied; quoting Rinaldi v. Viking Penguin, Inc., 420 N.E.2d 377, 382 (N.Y. 1981)). It is undisputed Ms. Maxwell and her agents had no ability to control and did not control whether or how the media-recipients would use the statement. Doc. 542-7, Ex.J {[§[ 2-3; id., Ex.K q 24. Unsurprisingly, plaintiff has offered no evidence of such control. A fortiori this Court ““ha[s] no option but to dismiss the case,” id. (internal quotations omitted), to the extent it is founded upon the media’s republication of the statement. A. Plaintiff’s argument against summary judgment is substantially groundless. A legal argument is frivolous if it is presented contrary to a “long line of authorities” and >! of the underlying substantive law. Plaintiff Giuffre’s argument the “fundamental principles Opposing summary judgment as to republication is frivolous. The New York Court of Appeals in Geraci followed a long line of New York cases holding that a defamation defendant is not liable for republication of his allegedly defamatory statement unless he had “actual authority” to control the decision to republish: “Our ‘Porky Prods. v. Nippon Exp. U.S.A., 1 F.Supp.2d 227, 234 (S.D.N.Y. 1997), aff'd, 152 F.3d 920 (2d Cir. 1998).

Case 18-2868, Document 279, 08/09/2019, 2628231, Pages of 37 republication liability standard has been consistent for more than one hundred years.” See Geraci, 938 N.E.2d at 921 (footnote omitted). Indeed, the Geraci court observed, the New York Court of Appeals in Schoepflin v. Coffey,” a case decided in 1900, held: “It is too well settled to be now questioned that one who... prints and publishes a libel[] is not responsible for its voluntary and unjustifiable repetition, without his authority or request, by others over whom he has no control and who thereby make themselves liable to the person injured, and that such repetition cannot be considered in law a necessary, natural and probable consequence of the original slander or libel.” 938 N.E.2d at 921 (emphasis supplied; quoting Schoepflin, 56 N.E. at 504). The cases in which this Court and its sister courts in this Circuit assiduously have followed this line of New York cases are legion.” The Second Circuit was in the vanguard.” *56 N.E. 502 (N.Y. 1900). *See Egiazaryan v. Zalmayev, 880 F. Supp. 2d 494, 501 (S.D.N.Y. 2012) (“[t]he original publisher is not liable for republication where he had ‘nothing to do with the decision to [republish] and [he] had no control over it.’”’) (quoting Rinaldi v. Viking Penguin, Inc., 425 N.Y.S.2d 101, 104 (1 Dep’t 1980), aff'd, 420 N.E.2d 377 (N.Y. 1981)); Egiazaryan v. Zalmayev, No. 11 CIV. 2670 PKC, 2011 WL 6097136, at *5 (S.D.N.Y. Dec. 7, 2011) (same); Davis v. Costa-Gavras, 595 F. Supp. 982, 988 (S.D.N.Y. 1984) (“Under New York law, liability for a subsequent republication must be based on real authority to influence the final product, not upon evidence of acquiescence or peripheral involvement in the republication process.”); Davis, 580 F. Supp. at 1094 (original publisher not liable for injuries caused by the republication “absent a showing that they approved or participated in some other manner in the activities of the third party republisher’’’) (quoting Karaduman v. Newsday, Inc., 416 N.E.2d 557, 560 (N.Y. 1980)); Croy v. A.O. Fox Mem’l Hosp., 68 F. Supp. 2d 136, 144 (N.D.N.Y. 1999) (“The original author of a document may not be held personally liable for injuries arising from its subsequent republication absent a showing that the original author approved or participated in some other manner in the activities of the third-party republisher.”) (citations omitted); Cerasani v. Sony Corp., 991 F. Supp. 343, 351 (S.D.N.Y. 1998) (“a libel plaintiff must allege that the party had authority or control over, or somehow ratified or approved, the republication”’). “See Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906) (affirming directed verdict in favor of managing editor: “when it appears affirmatively that he was not on duty [upon receipt of libelous matter and its republication], and could not have had any actual part in composing or publishing, we think he cannot be held liable without disregarding the settled rule of law by which no man is bound for the tortious act of another over whom he has not a master’s power of control’) (emphasis supplied), guoted with approval in Davis I, 580 F. Supp. at 1096; Cerasani, 991 F. Supp. at 351.

Case 18-2868, Document 279, 08/09/2019, 2628231, Page9 of 37 In the face of this uninterrupted line of New York state (and federal) cases dating back to the nineteenth century powerfully establishing a bright line rule regarding republication liability, plaintiff Giuffre manages what amounts to a—frivolous—murmur of opposition. She claims there are “[t]wo standards” in New York law: one “older,” and one “more modern.” Resp. 28. The “older” standard, plaintiff says, is represented by the legion of cases we have cited. The “more modern formulation”—where can it be found? Why, in one place: a treatise on defamation. /d. (citing Sack on Defamation § 2.7.2, at 2-113 to -114 Ce ed. 2016)). It surely is frivolous to argue that a treatise creates a republication-liability standard that 1s separate from, “more modern” than, and supersedes the New York Court of Appeals’ 2010 decision in Geraci and this Court’s 2012 decision in Egiazaryan. Trying to build on this start, plaintiff argues, “New York appellate courts have repeatedly held than an individual is liable for the media publishing that individual’s defamatory press release.” Resp. 28 (emphasis supplied). Even if we accept plaintiff's mischaracterization of the January 2015 statement as a “press release,” her argument still would be meritless. To begin with, when plaintiff says the New York appellate courts have “repeatedly” supported her claimed rule of law, she means... twice. And an examination of those two cases reveals she is quite wrong and, worse, has advanced a seriously misleading argument. Neither case involved, as here, a motion for summary judgment. In both cases, the New York appellate division affirmed the denial of a motion to dismiss under the state’s equivalent of Federal Rule of Civil Procedure 12(b)(6). See Levy v. Smith, 18 N.Y.S.3d 438, 439 (2d Dep’t 2015); National Puerto Rican Day Parade, Inc. v. Casa Pubs. (“NPR”), 914 N.Y.S.2d 120, 122-23 (1" Dep’t 2010). > As discussed in This Reply, at 16-19, the January 2015 statement would be a strange “press release,” as it threatened to sue the very press to which it was “releasing” information.

Case 18-2868, Document 279, 08/09/2019, 2628231, Page10 of 37 This argument, too, 1s frivolous. Despite plaintiff's baseless claim there is an “old” formulation and a “more modern” formulation of republication-liability law in New York, both cases she cites applied the same “old” standard used by the New York Court of Appeals in Geraci, by this Court in the two Egiazaryan cases, and by us in our Memorandum of Law in support of Ms. Maxwell’s motion for summary judgment. See Levy, 18 N.Y.S.3d at 439 (citing Geraci and Schoepflin); NPR, 914 N.Y.S.2d at 594-95 (citing Hoffman v. Landers, 537 N.Y.S.2d 228, 231 (2d Dep’t 1989) (citing Schoepflin)). Both the courts in Levy and NPR applied the Geraci standard and the 12(b)(6) standards, e.g., assuming the pleaded facts were true. They concluded it was possible to infer from the complaints’ allegations that the defendant caused the republications. Accordingly, they denied the motions to dismiss. See Levy, 18 N.Y.S.2d at 439; NPR, 914 N.Y.S.2d at 123. It was improper for plaintiff to cite these cases without disclosing they are 12(b)(6) cases in which the courts applied the Geraci republication rule and inferred facts from the pleaded allegations. B. New York state and federal courts have rejected liability for republication based on “foreseeability.” Plaintiff cites section 576 of the Restatement (Second) of Torts for the proposition that if republication was foreseeable, then the defendant is the cause of any special damages from the republication. This argument is frivolous. As an initial matter, plaintiff has pleaded no special damages. See Doc.1; Doc.23 at 23; Doc.37 at 17. Regardless, the New York Court of Appeals in Geraci rejected the Restatement’s foreseeability doctrine. See 938 N.E.2d at 921-22 (noting that section 576’s foreseeability standard “is not nearly as broad as plaintiff... suggest[s]” and “[t]hat we did not endorse sucha broad [Restatement] standard of foreseeability in Karaduman is evident from our decision the following year in Rinaldi’) (emphasis supplied).

Case 18-2868, Document 279, 08/09/2019, 2628231, Page11 of 37 While trying to distinguish this Court’s decision in Davis, plaintiff fails to disclose that Davis itself—decided 26 years before Geraci—also rejected plaintiff's foreseeability argument. The Davis plaintiffs, like plaintiff Giuffre here, also asserted republication liability, despite defendant’s lack of participation, on the ground “he could reasonably have foreseen that republication would occur.” 580 F.Supp. at 1096. This Court, relying on Karaduman, was unpersuaded: The New York Court of Appeals “has not applied the foreseeability standard suggested by plaintiffs in prior libel cases in which such a standard would have been relevant, if not controlling.” Jd. This Court noted: The jurisdictions that have adopted a foreseeability standard “have refused to hold responsible a defendant with no control or influence over the entity that actually republished the statement.” /d. Plaintiffs failure to disclose this Court’s holdings in Davis is a notable lapse in candor. C. Plaintiff’s purported application of the Geraci rule is misleading and wrong. Plaintiff eventually purports to apply the “old” standard, that is to say, the controlling law in the state of New York. She argues Ms. Maxwell “authorized” the January 2015 statement, 99 66 “paid money to her publicist to convince media outlets to publish it,” “request[ed]” its 99 66 publication, “made a deliberate decision to publish her press release,” “actively participated” in “the decision to publish her press release,” was “active” in “influencing the media to publish” the statement, and “approved of” and “pushed for’ the publication of the statement. Resp. 30-31. These argument-manufactured facts have no record support. In applying the controlling law, plaintiff wittingly makes a mess of it. She disingenuously suggests any help Ms. Maxwell gave to help her lawyer prepare the January 2015 statement and her signing-off on it are the equivalent of requesting, authorizing and controlling its republication. That isn’t the law. The “authority” required for republication liability is the “actual authority .. . to decide upon or implement” the republication. 580 F.Supp. at 1095 6

Case 18-2868, Document 279, 08/09/2019, 2628231, Page12 of 37 (emphasis supplied; citing Rinaldi, 420 N.E.2d at 382). Judge Sofaer studied Rinaldi’s holding, and noted republication liability must be based on a “decision” by the defendant to republish and must focus on “real authority to influence the final product, not upon evidence of acquiescence or peripheral involvement in the republication process.” Id. at 1096 (emphasis supplied). Accordingly, Judge Sofaer held, when there is “conclusive evidence of lack of actual authority” this is “dispositive” of republication liability and the trial court “‘ha[s] no option but to dismiss the case against the [defendant].” /d. (emphasis supplied; quoting Rinaldi, 420 N.E.2d at 382). There is no evidence Ms. Maxwell “paid money to her publicist to convince” the media to publish her statement; this 1s why plaintiff cites no evidence to support that assertion. See Resp. 30. Mr. Gow’s email containing the statement says nothing to “convince” the media to publish the statement. See Doc.542-6, Ex.F. There is no evidence Ms. Maxwell was “active” in “influencing the media to publish” it; nor is there any evidence she “pushed for” or “requested” its publication; this is why plaintiff cites no evidence to support these assertions. See id. 31. Indeed, plaintiff has zero evidence Ms. Maxwell or her agents ever did anything to urge or request any media to publish the statement. Mr. Gow presented the January 2015 statement via email to six to thirty media representatives; it was not sent to anyone else; in the email he told the journalists he was presenting a “quotable statement” “on behalf of’ Ms. Maxwell and “{njo further communication will be provided.” Doc.542-6, Ex.F. It is undisputed Ms. Maxwell and her agents had no control over the media that republished portions of the statement. Doc.542-7, 542-7, Ex.J J¥ 2-3; id., Ex.K { 24. Plaintiff argues “a jury” should decide whether Ms. Maxwell “authorized or intended” the statement to be republished, or “approved of, and even participated, in” its republication. Resp. 30-31. All plaintiffs want to get to “a jury.” The summary-judgment question is whether they deserve to. Plaintiff has offered no evidence to put before a jury on the dispositive Geraci 7

Case 18-2868, Document 279, 08/09/2019, 2628231, Page13 of 37 question: whether Ms. Maxwell affirmatively authorized or requested a person or entity “over whom [s]he has .. . control,” 938 N.E.2d at 921. The only new argument plaintiff makes in her entreaty to see “a jury” is that she should be permitted to prove Ms. Maxwell’s “complicity.” As with her other factually bereft arguments, the complicity argument awaits plaintiffs introduction of facts to support it. Having failed to do so, plaintiff cannot avoid summary judgment. Plaintiff labors in vain to turn the Barden Declaration into “disputed issues of fact.” For there to be a disputed factual issue, plaintiff would need to introduce evidence disputing his sworn statements. She has not done so. In any event, the Barden Declaration is all but irrelevant to the central, dispositive republication question: whether Ms. Maxwell is liable for the media’s republication of her statement, where they did so without her authority or request and where she and her agents had “no control’ over the media. On this question we cited to the Barden Declaration for one evidentiary fact: Messrs. Barden and Gow had no control over the media.’ See Doc.542-7, Ex.K J 24, cited in Memo. of Law 14.° Plaintiff has offered no admissible evidence disputing this fact. ‘'T]here is no issue for trial unless there 1s sufficient evidence favoring the nonmoving party for a jury to return a verdict for that party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). It is one thing to argue in conclusory fashion, as plaintiff does, that “a jury” should decide a factual question. It is quite another to identify evidence in the Rule 56 record that raises a genuine question of material fact, which plaintiff does not do. Summary judgment is warranted. °Geraci, 938 N.E.2d at 921. "As discussed in Argument LD., below, we cited more plenarily to the Barden Declaration in connection with a different point—the particular unfairness of subjecting Ms. Maxwell to liability when the media selectively quoted portions of the January 15 statement. “In the Memorandum, we erroneously cited to { 24 of Exhibit J; we intended to cite to q 24 of Exhibit K (Doc.542-1, Ex.K), which is Mr. Barden’s declaration.

Case 18-2868, Document 279, 08/09/2019, 2628231, Page14 of 37 D. Subjecting Ms. Maxwell to liability for the media’s republication of excerpts they unilaterally selected is particularly unfair. It is undisputed that no one ever republished in toto the January 2015 statement and that various media unilaterally selected portions of the statement to republish. We said on page 14 of our Memorandum that the media’s “selective, partial republication of the statement 1s more problematic yet” (emphasis altered). That 1s to say, as improper as it is to hold a publisher of a statement liable for republications over which she had no control, worse 1s it to make her liable for selective, partial republications of her statement. We relied on the holding in Rand v. New York Times Co., 430 N.Y.S.2d 271, 275 (1* Dep’t 1980), that a publisher cannot be charged with a republisher’s “editing and excerpting of her statement.” Memo. of Law 14. Plaintiff argues that our position is “absurd on its face” because “[i]t would mean ...a defamer could send to the media a long attack on a victim with one irrelevant sentence and, when the media quite predictably cut that sentence, escape liability.” Resp. 32. This argument has two erroneous assumptions. One is that the “defamer” can “escape liability.” Not true. An original publisher remains liable for her defamation. We are concerned here with republication. The second wrong assumption 1s that the original publisher must always remain liable for any republication. Geraci rejects that view: Under New York law “each person who repeats the defamatory statement is responsible for the resulting damages.” 938 N.E.2d at 921. The effort by plaintiff to distinguish Rand is meritless. She argues the media’s republication of the January 2015 statement actually was not a republication at all, just an original publication. Resp. 32. That argument is “absurd on its face,” id., since there is no dispute Ms. Maxwell did not control the media’s decision to republish (excerpts from) the statement. Plaintiff next argues the media did not “edit|]” or “tak[e] . . . quote[s] out of context.” Jd. Plaintiff could not be more wrong. As she concedes, all republications of the statement by the

Case 18-2868, Document 279, 08/09/2019, 2628231, Page15 of 37 media were Selective, partial republications of the statement. Any such selective, partial republication by definition took those excerpts “out of context.” This is so because Mr. Gow informed the media in his email that he was providing “a quotable statement,” Doc.542-6, Ex.F, not a statement “from which you, the media, are free to excerpt as you please.” More importantly, as Mr. Barden explained, selectively excerpting the statement substantially altered his message. See id., Ex.K {| 20. For example, when he said in the third paragraph that plaintiffs claims are “obvious lies,” it followed two paragraphs in which he explained why it was obvious the new claims are lies. See id., Ex.K {J 19-22. Excerpting and republishing only the “obvious lies” phrase—as plaintiff did in her complaint—certainly gives the reader a different understanding than if the media had republished the entire statement. As Rand held: A defendant cannot be liable for the republication of derogatory but constitutionally protected opinion “when the foundation upon which that opinion is based is omitted. The defamatory remark should be read against the background of its issuance.” 430 N.Y.S.2d at 275 (internal quotations omitted). Plaintiff argues: “A jury could reasonably conclude that [Ms. Maxwell’s] statement that Ms. Giuffre’s claims of child sexual abuse are ‘obvious lies’ is not a rhetorical device, nor hyperbole, but a literal and particular affirmation that [plaintiff] lied.”’ Resp. 33 (emphasis supplied). We italicize plaintiffs rhetorical sleight of hand. As plaintiff knows, nowhere did the January 2015 statement specify which of plaintiff’s countless allegations are “obvious lies.” Indeed, this is the problem with plaintiff's case: since the statement specified no particular allegations as obvious lies, plaintiff believes she 1s entitled to “prove” the truth of every allegation she ever has made about her alleged experience as a “sex slave.’ What Mr. Barden’s declaration makes clear is he deliberately made no reference to any specific allegation by plaintiff. He had a bigger target: plaintiff's credibility. He used the statement to show plaintiff's 10

Case 18-2868, Document 279, 08/09/2019, 2628231, Page16 of 37 behavior is that of a liar, 1.e., one who increasingly embellishes her story, and her allegations become more and more outlandish, so that by January 2015 she was claiming to have had sex with a well respected Harvard law professor, Alan Dershowitz. See Doc.542-7, Ex.K JJ 19-22. Contrary to plaintiff's argument, “even apparent statements of fact may assume the character of statements of opinion, and thus be privileged, when made in public debate . . . or other circumstances in which an audience may anticipate the use of epithets, fiery rhetoric or hyperbole.” Steinhilber v. Alphonse, 501 N.E.2d 550, 556 (N.Y. 1986) (internal quotations and brackets omitted). That was the case here. Plaintiff falsely—and, as Judge Marra held, “unnecessar[ily]””—alleged in lurid detail that Ms. Maxwell had sexually abused her. The six to thirty journalists would have anticipated a “fiery” denial of the allegations. Regardless, the statement overall was constitutionally protected opinion grounded on facts disclosed to the journalists: plaintiff's increasingly outlandish and inconsistent stories, her newly embellished allegations, and her increasingly lurid and salacious enhancements of her earlier allegations. E. Mr. Barden’s declaration is perfectly proper. Plaintiff makes a plethora of complaints about Mr. Barden’s declarations. None has any merit. She objects to Mr. Barden’s declaration of his intent and purposes for preparing the January 2015 statement because, she says, this implicates the attorney-client privilege. That is untrue. His intent and purposes are by definition not attorney-client communications and do not implicate such communications; they are attorney work product,” which he is free to disclose.’ "Doc.542-5, Ex.E, at 5. '’Travelers Indem. Co. v. Northrop Grumman Corp., No. 12 CIV. 3040 KBF, 2013 WL 3055437, at *3 (S.D.N.Y. Apr. 22, 2013) (identifying work product as including defense counsel’s “mental impressions, thought processes and strategies connected with [the] defense’’) . 'l See In re China Med. Techs., Inc., 539 B.R. 643, 658 (S.D.N.Y. 2015) 11

Case 18-2868, Document 279, 08/09/2019, 2628231, Page17 of 37 She objects he 1s “non-deposed.” But Mr. Barden was the third-listed potential witness in our Rule 26(a)(1)(A) disclosure, served on plaintiff a year ago; the disclosure said he “has knowledge concerning press statements by .. . Defendant in 2011-2015 at issue in this matter.” Plaintiff was free to depose him; that she chose not to was her own tactical decision. Finally, plaintiff argues “there are factual disputes” regarding the declaration. But plaintiff identified no such factual disputes relating to the declaration. A party opposing summary judgment cannot create a dispute by arguing, which is all plaintiff does. See Resp. 35-38. F. Plaintiff effectively has confessed Arguments I.B. and I.C. of the Memorandum. Argument I.B. of the Memorandum contends the First Amendment bars liability for republication by media organizations of the January 2015 statement. See Memo. of Law 16-17. Argument I.C. contends that under Geraci plaintiff is barred from introducing into evidence any of the media organizations’ republication of the January 2015 statement. See id. at 17-18. Plaintiff offers no resistance to these arguments. We respectfully request that the Court consider these arguments confessed. See, e.g., Cowan v. City of Mount Vernon, 95 F. Supp. 3d 624, 64546 (S.D.N.Y. 2015) (citing cases). II. The January 2015 statement is constitutionally protected opinion. In deciding whether a statement is opinion the New York Constitution requires application of “the widely used four-part Ollman'"”! formula,” Immuno AG v. Moor-Jankowski, 567 N.E.2d 1270, 1274 (N.Y. 1991). See id. at 1274, 1277-78, 1280-82 (noting Steinhilber’s adoption of formula). We addressed each of the four Ol/man factors. The plaintiff avoids this analysis, choosing merely to block-quote large portions of this Court’s Rule 12(b)(6) order. That '*Menninger Decl. EXHIBIT NN, at 2. 'SOllman v. Evans, 750 F.2d 970 (D.C. Cir. 1984). 12

Case 18-2868, Document 279, 08/09/2019, 2628231, Page18 of 37 is a mistake. Immuno AG 1s the seminal case prescribing the analysis to be used in a summaryjudgment proceeding for assessing whether under the New York Constitution a statement 1s absolutely protected as opinion. Instead of addressing the four factors, plaintiff simply relies on this Court’s 12(b)(6) order. The Court’s order does not control. In deciding the Rule 12(b)(6) motion, the Court assumed the complaint’s allegations were true and drew all reasonable inferences in plaintiffs favor. In this proceeding, plaintiff is not entitled either to the assumption or the inferences. The opinion-versus-fact question will be controlled by the Rule 56 record. Relying on the Court’s order, plaintiff argues that the question whether the three allegedly defamatory sentences are opinion or fact is controlled by Davis v. Boeheim, 22 N.E.3d 999 (N.Y. 2014), and Green v. Cosby, 138 F. Supp. 3d 114 (D. Mass. 2015). See Resp. 38. Davis was an appeal from a 12(b)(6) dismissal. This procedural posture was critical to its decision: [D]efendants argue that because a reader could interpret the statement as pure opinion, the statement is as a consequence, nonactionable and was properly dismissed [pursuant to a pre-answer motion]. However, on a motion to dismiss we consider whether any reading of the complaint supports the defamation claim. Thus, although it may well be that the challenged statements are subject to defendants’ interpretation, the motion to dismiss must be denied if the communication at issue, taking the words in their ordinary meaning and in context, is also susceptible to a defamatory connotation. We find this complaint to meet this minimum pleading requirement. Davis, 22 N.E.3d at 1006-07 (internal quotations, brackets, ellipsis and citations omitted). Green was a decision on the defendant’s motion to dismiss. The case was decided under California and Florida defamation law. See 138 F. Supp. 3d at 124, 130, 136-37. The court made it clear the 12(b)(6) procedural posture was critical to its decision: “At this stage of the litigation, the court’s concern is whether any fact contained in or implied by an allegedly defamatory statement is susceptible to being proved true or false; if so capable, Defendant cannot avoid application of defamation law by claiming the statement expresses only opinion.” /d. at 130. 13

Case 18-2868, Document 279, 08/09/2019, 2628231, Page19 of 37 In the case at bar, application of the four Steinhilber factors on the Rule 56 record compels a different conclusion. The complaint alleges three sentences in the January 2015 statement are defamatory: in the first paragraph of the statement, plaintiff Giuffre’s allegations are “untrue”; in the same paragraph, the “original allegations” have been “shown to be untrue’; and in the third paragraph, plaintiff’s “claims are obvious lies.”'* Doc.1 30. Factor 1: Indefiniteness and ambiguity. On the face of the complaint in a 12(b)(6) proceeding, the words “untrue” and “obvious lies” might be susceptible of “a specific and readily understood factual meaning,” Doc.37 at 9. This is especially true if it is taken out of context, e.g., extracted from the statement. But this approach is forbidden. See, e.g., Law Firm of Daniel P. Foster, P.C. v. Turner Broad. Sys., 844 F.2d 955, 959 (2d Cir. 1988). The first sentence—“|t]he allegations made by [plaintiff] against [Ms. Maxwell] are untrue’ —is indefinite and ambiguous because it 1s wholly unclear which “allegations” are being referenced. The second sentence—“|t]he original allegations . .. have been fully responded to and shown to be untrue’”—also is indefinite and ambiguous for the same reason. Additionally, it is unclear what are the “original” allegations. It is unclear what is meant by “shown to be untrue.”” What one person may believe is a fact shown to be untrue, another person may believe is a fact not (sufficiently) shown to be untrue. The existence of God, climate change and existence of widespread voter fraud in the election are examples of this. The third sentence— “Ms. Maxwell testified in her deposition that she “know[s]” plaintiff is a “liar.” This testimony, plaintiff argues, “contradict|s]” our contention that the three allegedly defamatory sentences in the July 2015 statement are opinion. Resp. 39-40. Plaintiffs argument is a nonsequitur. Ms. Maxwell’s 2016 deposition testimony in which she disclosed all the reasons she believes plaintiff has uttered a plethora of false allegations is irrelevant to whether the three sentences in the July 2015 statement, prepared by Mr. Barden to respond to the joint-motion allegations, are opinions. 14

Case 18-2868, Document 279, 08/09/2019, 2628231, Page20 of 37 “Tplaintiff’s] claims are obvious lies”—also is indefinite and ambiguous. An “obvious lie” to one person is not an “obvious lie” to another. Factor 2: Capable of being characterized as true or false. On the 12(b)(6) record, the Court held the three statements “are capable of being proven true or false.” Doc.37 at 9. As a general question of law, one person’s statement that another person’s allegations are “untrue” or are “obvious lies” is not necessarily capable of being proved true or false—regardless of the subject matter of the opined “untruths” or “lies.” See Rizzuto v. Nexxus Prod. Co., 641 F. Supp. 473, 481 (S.D.N.Y. 1986), aff'd, 810 F.2d 1161 (2d Cir. 1986); Telephone Sys. Int’l v. Cecil, No. 02 CV 9315(GBD), 2003 WL 22232908, at *2 (S.D.N.Y. Sept. 29, 2003); Memo. of Law 35 (citing cases). As Steinhilber observed, “even apparent statements of fact may assume the character of statements of opinion, and thus be privileged.” 501 N.E.2d at 556. At least two of plaintiff's CVRA allegations cannot be proven true or false (only two such allegations are needed in order to render the January 15 statement an opinion). We have identified two such allegations in the joinder motion: that Ms. Maxwell “appreciated the immunity granted” to Epstein, and that she “act[ed] as a ‘madame’ for Epstein.” Memo. of Law 22. Plaintiff does not dispute this. The result is that the January 15 statement’s assertion that plaintiff's “allegations” and “claims” in the joint motion are “untrue” or “obvious lies” is by definition an opinion. It cannot be proven true or false whether Ms. Maxwell “appreciated” Epstein’s immunity or whether she “acted as a madame.” Indeed, it seems quite obvious that the joinder-motion allegations about “appreciation” and “madame” are themselves opinion. In the statement, Mr. Barden on behalf of Ms. Maxwell also says plaintiff’s “original allegations .. . have been fully responded to and shown to be untrue.” Doc.542-6, Ex.F. This cannot be proven true or false. The “full response” to the original allegations is a reference to the “Statement on Behalf of Ghislaine Maxwell” issued March 9, 2011, 1n response to plaintiff s 15

Case 18-2868, Document 279, 08/09/2019, 2628231, Page21 of 37 allegations contained in media stories, including the Churcher articles. See Doc.542-3, Ex.C. Whether the 2011 statement “fully” responded to the original allegations and whether it “showed” the original allegations to be untrue are pure (argumentative) opinion. “[O]bvious lies” on its face is an opinion. The “obviousness” of a lie simply cannot be proven true or false. Factor 3: The full context of the statement. Three contextual facts are revealed by the Rule 56 record. One, the email transmitting the statement to the media-representatives—along with the third-person references to Ms. Maxwell—told them Ms. Maxwell did not prepare the statement: “Please find attached a quotable statement on behalf of Ms. Maxwell.” Doc.542-6, Ex.F (emphasis supplied). It is undisputed that in fact Mr. Barden prepared the bulk of it and ultimately approved and adopted as his work all of it. Doc.542-7, Ex.K J 10. Two, Mr. Barden’s statement issued on behalf of his client would not be a traditional press release solely to disseminate information to the media; this is why he did not request Mr. Gow or any other public relations specialist to prepare or participate in preparing the statement. /d., Ex.K J 15. The statement was a broad-brush communique to the media about plaintiff and her new allegations; it was not to be a “point by point” rebuttal of each new allegation. /d., Ex.K J 13. The logic and approach to preparing the statement were simple: compare plaintiff’s prior allegations and conduct in telling her story with her current allegations and conduct. See generally id., Ex.K J 13. When he wrote the statement, he knew of plaintiff’s 2011 allegation that she had not had sex with Prince Andrew and he knew of her CVRA allegation that she did have sex with him. /d., Ex.K { 14. Also within his knowledge was the story she had told Churcher before March 201 1—a story that was far less provocative and salacious than the one she included in the joinder motion. See id., Ex.K J 5; compare Docs.542-1 & 542-2, Exs.A & B (Churcher articles published March 2011) with Doc.542-4, Ex.D (plaintiffs joinder motion containing dramatically different and more lurid and salacious allegations). 16

Case 18-2868, Document 279, 08/09/2019, 2628231, Page22 of 37 Mr. Barden’s approach provides critical context to explaining how the statement builds a logical argument that the new allegations are false. It first notes plaintiffs “original allegations”; then it points out how the story changed and was embellished over time, “now” with allegations that plaintiff had sex with a prominent and highly respected Harvard law professor (“Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders ....”). The argument builds up to the opinion in the third paragraph: “|Plaintiff’s] claims are obvious lies and should be treated as such... .” Doc.542-6, Ex.F. See generally id., Ex.K ql 13-22. This third paragraph—and the threat in the fourth paragraph to sue the media for republication of plaintiff's falsehoods—confirms what is plain from the statement itself: it was not a traditional press release. Three, the statement was intended to respond (via denial) to the media-recipients’ requests for a reply to the new CVRA joinder-motion allegations. /d. J 8, 10, 16. But more than that, it was intended to be “a shot across the bow” of the media. /d. { 17. The logical argument was created to (a) persuade the media-recipients that they needed to “subject plaintiff’ s allegations to inquiry and scrutiny”; (b) explain to the media-recipients how it was “obvious” that plaintiff “had no credibility” because of her shifting story and increasingly lurid and salacious allegations as time went on, many of which (e.g., the allegations of sex with Prince Andrew and Professor Dershowitz) on their face appear far-fetched,” and (c) warn the mediaSince the CVRA joinder motion, there has emerged a substantial amount of evidence— some from plaintiff's own pen—that plaintiffs allegations about having been “forced” to have sex with prominent individuals are falsehoods. A telling example is a series of emails between plaintiff and reporter Churcher when plaintiff was working on negotiating a book deal about her alleged experiences and Churcher was trying to help her. On May 10, 2011, plaintiff tells Churcher she cannot remember whom she had told Churcher she had had sex with. Churcher responds responds, “Don’t forget Alan Dershowitz,” which Churcher says 1s a “good name for [plaintiff's] pitch” to her literary agent. It 1s clear neither Churcher nor plaintiff believed plaintiff (footnote cont'd on next page) 17

Case 18-2868, Document 279, 08/09/2019, 2628231, Page23 of 37 recipients that they republished plaintiff's obvious falsehoods against Ms. Maxwell at their legal peril. See id. J 13, 16, 17, 20. As the New York Court of Appeals observed, the context of a statement often is the “key consideration” in fact vs. opinion cases. Davis, 22 N.E.3d at 1006. So it is here. As Davis suggested, the three challenged statements are “subject to [Ms. Maxwell’s] interpretation,” id. at 1007; accord Sweeney v. Prisoners’ Legal Servs. of N.Y., 538 N.Y.S.2d 370, 371-72 (3d Dep’t 1989). The context of the January 2015 statement makes clear that the characterization of plaintiff's allegations and claims as “untrue” or “obvious lies” are ultimate opinions— conclusions—drawn from disclosed facts. Factor 4: The broader setting surrounding the statement, including conventions that might signal to readers that the statement likely is opinion and not fact. It 1s undisputed that the January 2015 statement was sent exclusively to more than six and fewer than thirty media representatives, each of whom expressly had requested from Mr. Gow that he provide them with Ms. Maxwell’s reply to the new joint-motion allegations. Doc.542-7, Ex.K {J 8, 10. As was obvious from the statement, it was not a traditional press release, as such a release does not explain—lawyer-like—why new allegations when measured against previous allegations lack credibility. Nor does a traditional release threaten to sue the media to whom the release is sent. The media representatives upon receiving the January 2015 statement would have understood it was presenting an (opinionated) argument that plaintiff was not credible because of her had had sex with Professor Dershowitz, since (a) Churcher suggests that he would be a “good name” to “pitch” because of his prominence (“he [represented] Claus von Bulow and a movie was made about that case...title was Reversal of Fortune’), and (b) Churcher states, “We all suspect [Professor Dershowitz] is a pedo[phile] and tho no proof of that, you probably met him when he was hanging put w [Epstein].”” Menninger Decl., EXHIBIT.OO, at Giuffre004096-97 (emphasis supplied). 18

Case 18-2868, Document 279, 08/09/2019, 2628231, Page24 of 37 inconsistent and shifting sex abuse story and her increasingly lurid allegations against more and more prominent individuals. And they would have understood that these characteristics of a storyteller undermine her credibility and ergo the credibility of her new allegations. In its 12(b)(6) order the Court said the three sentences have the effect of denying plaintiff's story but “they also clearly constitute fact to the reader.” The ruling is affected in two ways by the Rule 56 record. Based on the foregoing discussion of the evidence, the three sentences clearly constitute (argumentative) opinions of Mr. Barden on behalf of Ms. Maxwell. Though the Court did not discuss who is “the reader,” this is important in Steinhilber Factor 4.” Under settled defamation-opinion law, an allegedly defamatory statement is to be viewed “from the perspective of the audience to whom it is addressed.” Dibella v. Hopkins, No. O01 CIV. 11779 (DC), 2002 WL 31427362, at *2 (S.D.N.Y. Oct. 30, 2002). Here, “the reader” 1s six to thirty journalists. They could not have read the July 2015 statement—or the three allegedly defamatory sentences—the same way it was read by these journalists’ audience, 1.e., the general public. This is because, as plaintiff implicitly concedes, these journalists only republished excerpts—and not the entirety of the statement, which would have given context to the three sentences. It is axiomatic that an out-of-context republication of the three sentences—without the rest of the statement—would deprive the reader of the logic and reasoning behind the opinionated conclusion that plaintiff was making “untrue” allegations and telling “obvious lies.” 19

Case 18-2868, Document 279, 08/09/2019, 2628231, Page25 of 37 II. The pre-litigation privilege bars this action. A. The privilege applies to the January 2015 statement. Statements pertinent to a good faith anticipated litigation made by attorneys (or their agents under their direction'®) before the commencement of litigation are privileged and “no cause of action for defamation can be based on those statements,” Front, Inc. v. Khalil, 28 N.E.3d 15, 16 (N.Y. 2015). The facts that must be established, therefore, are (a) a statement, (b) that is pertinent to a good faith anticipated litigation, and (c) by attorneys or their agents under their direction. We did this. See Memo. of Law 6-8, 33-38; Doc.542-7, Ex.K {J 8-30. For example, Mr. Barden (a) drafted the vast majority of the January 2015 statement and approved and adopted all of it, (b) directed Mr. Gow to send it to the media representatives who had requested Ms. Maxwell’s reply to plaintiffs joint-motion allegations, (c) in the statement threatened legal action again these media representatives, and (d) at the time of the statement “was contemplating litigation against the press-recipients.” /d., Ex.K {J 10, 16-17, 28, 30. Plaintiff argues without citation to authority: Ms. Maxwell herself did not testify she intended to sue; she hasn’t offered any witnesses to testify she intended to bring a lawsuit; she didn’t in fact sue; and—this one is a non-sequitur—the statement was an “attempt[] to continue to conceal her criminal acts.” Resp. 41-42. These arguments fail. The privilege exists without regard to whether Ms. Maxwell testifies she “intended” to sue, whether she has “witnesses” to say she intended to sue, or whether she “in fact” sued. It refers to “anticipated” litigation, not “suaranteed” litigation. Indeed, the point of the pre-litigation privilege is to promote communications that avoid litigation. See Khalil, 28 N.E.3d at 19 (“When litigation is '©See Chambers v. Wells Fargo Bank, N.A., No. CV 15-6976 (JBS/JS), 2016 WL 3533998, at *8 (D.N.J. June 28, 2016); see generally Hawkins v. Harris, 661 A.2d 284, 289-91 (N.J. 1995). 20

Case 18-2868, Document 279, 08/09/2019, 2628231, Page26 of 37 anticipated, attorneys and parties should be free to communicate in order to reduce or avoid the need to actually commence litigation.”). It applies when there 1s a good faith basis to anticipate litigation. Mr. Barden, Ms. Maxwell’s lawyer who drafted and caused the statement to be sent out, actually was anticipating litigation. Doc.542-7, Ex.K J 28. The argument that the statement was an attempt to “conceal” Ms. Maxwell’s “criminal acts” is fatuous. It would be hard to post facto “conceal” alleged criminal acts that plaintiff luridly and salaciously described in an earlier public filing, 1.e., in the CVRA case, in which the United States government was the defendant. Citing no record evidence, plaintiff argues, “The record evidence shows [Mr. Barden] did not make the [January 2015] statement.” Resp. 42. That argument is easily disposed of by Mr. Barden’s uncontested testimony. See Doc.542-7, Ex.K {ff 10-13, 15-17, 20, 26-28, 30. B. Malice is irrelevant to the pre-litigation privilege. Citing the New York Court of Appeals’ decision in Khalil, we pointed out that malice is not relevant to the pre-litigation privilege. Memo. of Law 34-35. To prevail on the pre-litigation privilege the defendant need only establish one element: the allegedly defamatory statement at issue was “pertinent to a good faith anticipated litigation.’” Jd. (quoting Khalil, 28 N.E.3d at 16). Plaintiff disputes this and, without discussing Khalil or citing authorities, simply argues the pre-litigation privilege is “foreclosed . . . because [Ms. Maxwell] acted with malice.” Resp. 43. As suggested by her inability to find any law to support her, plaintiff is wrong. Under general New York defamation law, “[t]he shield provided by a qualified privilege may be dissolved” if plaintiff in rebuttal can show that the defendant “spoke with ‘“malice.’” Liberman v. Gelstein, 605 N.E.2d 344, 349 (N.Y. 1992); accord Khalil, 28 N.E.3d at 19. “Malice” means two things: spite or ill will, and knowledge of falsity or reckless disregard of falsity. Liberman, 605 N.E.2d at 349. Plaintiff relies on this general qualified-privilege law. 21

Case 18-2868, Document 279, 08/09/2019, 2628231, Page27 of 37 The problem for plaintiff is that in Khalil the New York Court of Appeals held this general rule does not apply to the pre-litigation privilege. Khalil worked for a company named Front. After eight years, he resigned and began working for “EOC,” one of Front’s competitors. Front’s lawyer Kimmel sent a demand letter to Khalil alleging he had committed criminal, tortious and ethical misconduct. Kimmel sent another demand letter to EOC and others stating Khalil had conspired with EOC to breach his fiduciary duty to Front. Six months later, Front sued Khalil. Khalil brought a third-party claim against Kimmel for libel per se. The trial court dismissed the lawsuit, ruling that the letters were “absolutely privileged” under the litigation privilege “and that it therefore did not need to reach the question of malice.” 28 N.E.3d at 17 (internal quotations omitted). The Appellate Division affirmed, holding that the litigation privilege absolutely protected the letter “because they were issued 1n the context of prospective litigation.” /d. at 18 Ganternal quotations omitted). The Court of Appeals affirmed, but altered the law on the litigation privilege. It observed, ‘Although it is well-settled that statements made in the course of litigation are entitled to absolute privilege, this Court has not directly addressed whether statements made by an attorney on behalf of his or her client in connection with prospective litigation are privileged.” Id. (emphasis supplied). Some Appellate Division departments had held the absolute privilege applies to statements made in connection with prospective litigation, but other departments had held such statements were entitled only to a qualified privilege. Jd. The answer to whether pre-litigation statements should be absolute or qualified, the Court of Appeals held, is driven by the rationale for protecting pre-litigation statements: When litigation is anticipated, attorneys and parties should be free to communicate in order to reduce or avoid the need to actually commence litigation. Attorneys often send cease and desist letters to avoid litigation. ... Communication during this pre-litigation phase should be encouraged and not chilled by the possibility of being the basis for a defamation suit. 22

Case 18-2868, Document 279, 08/09/2019, 2628231, Page28 of 37 Id. at 19. However, the court recognized that “extending privileged status to communication made prior to anticipated litigation has the potential to be abused”; extending an absolute privilege to this context, the court said, “would be problematic and unnecessary.” Jd. The court held it would recognize only a qualified privilege for pre-litigation communications. /d. Crucially to the case at bar, the court held that the traditional privilegerebuttal malice was inapplicable to the pre-litigation privilege: Rather than applying the general malice standard to this pre-litigation stage, the privilege should only be applied to statements pertinent to a good faith anticipated litigation. This requirement ensures that privilege does not protect attorneys who are seeking to bully, harass, or intimidate their client’s adversaries by threatening baseless litigation or by asserting wholly unmeritorious claims, unsupported in law and fact, in violation of counsel’s ethical obligations. Therefore, we hold that statements made prior to the commencement of an anticipated litigation are privileged, and that the privilege is lost where a defendant proves that the statements were not pertinent to a good faith anticipated litigation. Id. (emphasis supplied). Accordingly, the only question is whether the January 2015 statement Mr. Barden caused to be issued to the six to thirty journalists was “pertinent to a good faith anticipated litigation.” The undisputed evidence establishes that the answer is yes. Mr. Barden anticipated litigation. ’” 9918 He “fully complied with [his] ethical obligation as a lawyer.” '” He was hardly “bully[ing], harass[ing], or intimidat[ing]” the six to thirty journalists, since he caused a press agent, Mr. '’See Doc.542-7, Ex.K J 28 (“At the time I directed the issuance of the statement, I was contemplating litigation against the press-recipients .. . .”’); id. | 17 (statement was intended as “a shot across the bow’”; “the statement was very much intended as a cease and desist letter to the media-recipients, letting [them] understand the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct’); Doc.542-6, Ex.F (“Maxwell . . . reserves her right to seek redress’). 'SNoc.542-7, Ex.K J 26. 23

Case 18-2868, Document 279, 08/09/2019, 2628231, Page29 of 37 Gow, to issue the statement,'” and he believed he had an affirmative duty in representing Ms. Maxwell to prepare the statement and cause it to be delivered to the journalists.” Plaintiff argues that when Mr. Barden issued the January 2015 statement on Ms. Maxwell’s behalf, he had only “‘wholly unmeritorious claims, unsupported in law and fact, in violation of counsel’s ethical obligations’” and did not have ““good faith anticipated litigation.’” Resp. 46 (quoting Khalil, 28 N.E.3d at 19; italics omitted). Plaintiff's rationale? Because she was telling the truth and so the media would only be reporting the truth. /d. That is a nonsensical, frivolous argument. Whether Mr. Barden, who represents Ms. Maxwell, had a meritorious or good faith basis for anticipating defamation litigation has nothing to do with whether the media believed plaintiff was telling the truth, and surely not whether the plaintiff believed or said she was telling the truth. Based on his knowledge of plaintiff's history, Mr. Barden in good faith believed that plaintiff had been making false allegations for years and that the falsity of the allegations “should have been obvious to the media.” Doc.542-7, Ex.K J 13; see id. JJ 14, 16-17, 20-23, 26-28, 30. Accordingly, at the time he caused the statement to issue, Mr. Barden had a good-faith basis to anticipate litigation against any of the media that republished plaintiff's false allegations. It hardly matters for purposes of the pre-litigation privilege whether the media republished or did not republish plaintiffs allegations or whether Mr. Barden ultimately did or did not sue any of the media for any republication. As the Khalil court recognized, “[a]ttorneys often send cease and desist letters to avoid litigation,” 28 N.E.3d at 19, and such letters have a The Khalil court admonished attorneys to “exercise caution when corresponding with unrepresented potential parties who may be particularly susceptible to harassment and unequipped to respond properly even to appropriate communications from an attorney.” Khalil, 28 N.E.3d at 19 n.2. "See Doc.542-7, Ex.K J 26. 24

Case 18-2868, Document 279, 08/09/2019, 2628231, Page30 of 37 valid purpose protected by the pre-litigation privilege. Mr. Barden testified that the January 2015 statement in fact served as a cease and desist letter. See Doc.542-7, Ex.K J 17. IV. Ms. Maxwell’s January 4, 2015, statement is nonactionable. Plaintiff did not respond to our argument that Ms. Maxwell’s January 4, 2015, statement to a reporter is nonactionable. See Memo. of Law 38-39. We respectfully submit plaintiff has confessed this point. See Cowan, 95 F. Supp. 3d at 645-46. V. Summary judgment is warranted because plaintiff cannot establish falsity or actual malice by clear and convincing evidence. Plaintiff is a public figure. See Memo. of Law 16-17, 49-54. Therefore, she must prove falsity and actual malice. Under New York law, a public-figure defamation plaintiff must go beyond the federal constitutional minimum and prove falsity by clear and convincing evidence. Blair v. Inside Ed. Prods., 7 F. Supp. 3d 348, 358 & n.6 (S.D.N.Y. 2014) (citing DiBella v. Hopkins, 403 F.3d 102, 111 (2d Cir.2005)). She must also prove actual malice by clear and convincing evidence. Karedes v. Ackerley Grp., Inc., 423 F.3d 107, 114 (2d Cir. 2005) (quoting Phila. Newspapers v. Hepps, 475 U.S. 767, 773 (1986)). Clear and convincing evidence 1s evidence that “produces in the mind of the trier of fact a firm belief or conviction as to the truth of the allegations sought to be established, evidence so clear, direct and weighty and convincing as to enable the factfinder to come to a clear conviction, without hesitancy, of the truth of the precise facts in issue.” Blair, 7 F. Supp. 3d. at 358 (internal quotations and brackets omitted). Plaintiff must prove by clear and convincing evidence (a) the material falsity of three sentences in the context of the January 2015 statement, and (b) Ms. Maxwell’s actual malice, 1.e., knowledge of the falsity of the three sentences or reckless disregard of whether they were false. The three sentences are: in the first paragraph of the statement, plaintiff’s allegations are 25

Case 18-2868, Document 279, 08/09/2019, 2628231, Page31 of 37 “untrue’’; in the same paragraph, the “original allegations” have been “shown to be untrue’; and in the third paragraph, plaintiff's “claims are obvious lies.””’ Doc.1 {[ 30. Plaintiff cannot prove the falsity of the three sentences, let alone actual malice. If the Rule 56 record establishes that two of plaintiff's CVRA joinder-motion allegations are false and two of her “original” allegations are false, this defamation action collapses on itself. This is because the statement does not specify how many of plaintiff's allegations are false; it certainly does not say “all” plaintiff’s allegations are false. It uses the plural of “allegation.” The plural of allegation literally means “more than one.” See Memo. of Law 21. Sentence No. 1. Since the sentence does not specify any particular allegation and since plaintiff made a plethora of allegations against Ms. Maxwell, plaintiff would be required to prove the truth of every one of the plethora of allegations and that Ms. Maxwell knew each one of the allegations was true. Conversely, if there are at least two allegations that plaintiff cannot prove to be true or if there was good reason for Ms. Maxwell to believe at least two of the allegations to be false, then summary judgment should enter against plaintiff. There are at least two allegations by plaintiff against Ms. Maxwell that are untrue. In the CVRA joinder motion, plaintiff alleged that in plaintiffs first encounter with Mr. Epstein, Ms. Maxwell took her to Mr. Epstein’s bedroom for a massage that Mr. Epstein and Ms. Maxwell “turned . . . into a sexual encounter,” Doc.542-4, Ex.D, at 3. This allegation contradicted her allegation in the Sharon Churcher article that a woman other than Ms. Maxwell “Ms. Maxwell said in her deposition she “know[s]” plaintiff is a “liar.” This testimony, plaintiff argues, “contradict[s]” our contention that the three sentences in the January 2015 statement are opinion. Resp. 39-40. Plaintiff’s argument 1s a non-sequitur. Ms. Maxwell’s 2016 deposition testimony in which she disclosed all the reasons she believes plaintiff has uttered a plethora of false allegations is wholly irrelevant to whether the three sentences in the January 2015 statement, prepared by Mr. Barden to respond to the joint-motion allegations, are opinions. 26

Case 18-2868, Document 279, 08/09/2019, 2628231, Page32 of 37 took her to Mr. Epstein’s bedroom; during the massage that woman gave instructions to plaintiff, and the massage “quickly developed into a sexual encounter.”’ Doc.542-1, Ex.A, at 4. A second allegation pertaining to plaintiff's entire story about Ms. Maxwell’s introduction of plaintiff to Prince Andrew is untrue. In the joinder motion, plaintiff alleged Ms. Maxwell served an “important . . . role” in “Epstein’s sexual abuse ring,” namely, connecting Mr. Epstein to “powerful individuals” who would sexually abuse plaintiff. Jd., Ex.D, at 5. Plaintiff alleged that in this role Ms. Maxwell introduced plaintiff to Prince Andrew, and she was “forced to have sexual relations with this Prince in three separate geographical locations,” including Ms. Maxwell’s London apartment. /d., Ex.D, at 5. These allegations directly contradicted her earlier allegations in the 2011 Churcher article that (a) there never was “any sexual contact between [plaintiff] and [Prince] Andrew,” and (b) Prince Andrew did not know “Epstein paid her to have sex with [Epstein’s] friends.” /d., Ex.A, at 6. Mr. Barden on behalf of Ms. Maxwell said in the first sentence that plaintiff s “‘allegations’”—plural—against Ms. Maxwell are “untrue.” We have just established through plaintiff's own contradictory words that 1t would be fair to characterize at least two of her allegations to be untrue. Having spent significant time with Ms. Churcher in 2011 and having substantial incentive to disclose all important details of her “sex abuse” story, see Menninger Decl. EXHIBIT OO, plaintiff in 2011 presented a story that exculpated Ms. Maxwell and Prince Andrew of the very misconduct that in 2015—after securing a lawyer and seeing her story as a profit vehicle—she inculpated them for. In the face of her contradictory allegations, plaintiff cannot possibly prove by clear and convincing evidence that all her joinder-motion allegations are true, or that when Ms. Maxwell said they were untrue, she knew each one of the allegations was true or that she recklessly disregarded whether each one was true. 2d

Case 18-2868, Document 279, 08/09/2019, 2628231, Page33 of 37 Under New York law, a defendant’s allegedly defamatory statement is held “to a standard of substantial, not literal, accuracy.” Law Firm of Daniel P. Foster, 844 F.2d at 959. Here, Ms. Maxwell’s first sentence literally 1s true: more than one of plaintiff's allegations are “untrue.” Accordingly, there is no defamation. Sentence No. 2. The second sentence at issue in this action states, “The original allegations are not new and have been fully responded to and shown to be untrue.” Plaintiff alleges the sentence is defamatory to the extent it asserts the original allegations were “shown to be untrue.” Doc.1 § 30. Plaintiff cannot prove this statement’s falsity. It is a matter of pure opinion whether any given allegation was “shown” to be untrue. Some people require more proof than others to conclude that a fact has been “shown to be untrue.” We discussed above various examples of this, e.g., climate change. Here, Ms. Maxwell via Mr. Barden in March 2011 issued a statement denying plaintiff’s Churcher-story allegations as “‘all entirely false.” Doc.542-3, Ex.C. Plaintiff did not respond to this statement, let alone claim it was defamatory. Her non-response reasonably could be seen as a concession that Ms. Maxwell’s denial was righteous. See Doc.542-7, Ex.K (Mr. Barden: “I would have been remiss if I had sat back and not issued a denial, and the press had published that Ms. Maxwell had not responded to enquiries and had not denied the new allegations; the public might have taken the silence as an admission there was some truth in the in allegations.’’). Regardless, we easily can show two of plaintiffs original allegations are untrue. Many of plaintiff's original allegations are contained in the two Churcher articles, Docs.542-1 & 542-2, Exs.A & B. The articles contained numerous allegations by plaintiff relating to her alleged sexual abuse. In her deposition, plaintiff was shown Deposition Exhibit 7, a collection of some of her allegations in the articles. Plaintiff placed checkmarks by those allegations she admitted— over the course of 20 pages of testimony—were not true. See Menninger Decl. EXHIBIT PP, at 28

Case 18-2868, Document 279, 08/09/2019, 2628231, Page34 of 37 435:7-455:6 & Depo. Ex.7. These include her claims that: (1) she was 17 when she flew to the Caribbean with Mr. Epstein and Ms. Maxwell “went to pick up Bill in a huge black helicopter,” referring to former President Bill Clinton; (2) her conversation with Mr. Clinton about Ms. Maxwell’s pilot skills; and (3) Donald Trump was a “good friend” of Mr. Epstein’s and “flirted with me”’. Plaintiff's admissions on the falsity of her original allegations are fatal to her defamation claim as to the second sentence. The eleven admittedly false “original allegations” axiomatically would warrant the second sentence. Plaintiff has no possible way to prove the second sentence is false. Indeed, like Ms. Maxwell’s first sentence, the second sentence literally is true: more than one of plaintiff's original allegations are untrue. A statement that literally is true cannot be defamatory as a matter of law. See Law Firm of Daniel P. Foster, 844 F.2d at 959. Sentence No. 3. Defamation as to the third sentence is foreclosed. To begin with, as discussed above, whether plaintiff has uttered “obvious lies” is a matter of opinion: in the face of plaintiff's gratuitous and lurid allegations of Ms. Maxwell’s years-long participation at the center of a child sex-trafficking ring, for the journalists-recipients of the July 2015 statement the phrase was an anticipated “epithet|], fiery rhetoric or hyperbole,” Steinhilber, 501 N.E.2d at 556 (internal quotations omitted); see Tel. Sys. Int’l, 2003 WL 22232908, at *2 (observing Court’s previous holding in Rizzuto that defendants’ use of phrases “conned,” “rip off’ and “lying” in advertisements were not actionable as libel and were “rhetorical hyperbole, a vigorous epithet used by those who considered themselves unfairly treated and sought to bring what they alleged were the true facts to the readers”) (internal quotations omitted). Even if arguendo the third sentence—plaintiff’s “claims are obvious lies’ —cannot be considered opinion, the Rule 56 record forecloses a defamation claim. The sentence does not specify which of plaintiff's “claims,” 1.e., allegations, are obvious lies. It could refer to the 29

Case 18-2868, Document 279, 08/09/2019, 2628231, Page35 of 37 “original” claims; the “new,” CVRA claims; the claims against Ms. Maxwell; the claims against anyone, including Professor Dershowitz, who was mentioned in the preceding sentence; or any two or more of all the claims plaintiff ever had made about her alleged experiences as the alleged victim of a child sex-trafficking ring. Regardless of what is being referred to, there is no defamation. As demonstrated in the discussion above of the first and second sentences, the Rule 56 record establishes that at least two of plaintiff's “original” allegations are untrue, at least two of her CVRA allegations are untrue, at least two of her allegations against Ms. Maxwell are untrue, at least two of her allegations against anyone (e.g., Ms. Maxwell, Prince Andrew or Professor Dershowitz) are untrue, and at least two of her allegations about her alleged sex-trafficking experiences are untrue. Moreover, the untruthfulness—the falsity—of the allegations certainly is “obvious.” After all, plaintiff herself admitted under oath that a multitude of her original allegations are untrue, and she implicitly admitted some of her CVRA allegations are untrue because they were contradicted by her original allegations. CONCLUSION The Court should grant summary judgment in favor of Ms. Maxwell. February 10, 2017. 30

Case 18-2868, Document 279, 08/09/2019, 2628231, Page36 of 37 Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice pending) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10'" Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 Imenninger@hmflaw.com Attorneys for Defendant Ghislaine Maxwell 31

Case 18-2868, Document 279, 08/09/2019, 2628231, Page37 of 37 CERTIFICATE OF SERVICE I certify that on February 10, 2017, I electronically served this Reply Brief in Support of Defendant’s Motion for Summary Judgment via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley @bsfllp.com mschultz @bsfllp.com Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad @ pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp @ law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@ aol.com s/ Nicole Simmons Nicole Simmons a7

Case 18-2868, Document 280, 08/09/2019, 2628232, Page1 of 74 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS V. Ghislaine Maxwell, Defendant. PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT Sigrid McCawley BOIES, SCHILLER & FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011

Case 18-2868, Document 280, 08/09/2019, 2628232, Page2 of 74 TABLE OF CONTENTS Page I. PRELIMINARY STATEMENT .....ccccsecssesssessuessecssecsucssecssecsueesecssecsuecsecsuecauessecsseeaueeseeeseeee | TI. = UNDISPUTED FACTS ....csccccsssssscssesssecsssccucssecsssccusssucssscsusssucsuscsusesecsueceusssecsavesuseuecsnvceaenees 4 A. It is an Undisputed Fact That Multiple Witnesses Deposed in This Case Have Testified That Defendant Operated as Convicted Pedophile Jeffrey Epstein’s POU OU IISA 10 BG uaa eta os css seer oh eat gs sees osenasenadetenaasuaeedea ach durede: 4 l. It is an undisputed fact that Joanna Sjoberg testified Defendant lured her from her school to have sex with Epstein under the guise of hiring her Or a JOD ANSWEerNe PHONES x casicedsccensetwnvecccdensaacscazveredsdetvececavbedconmenness 4 It is an undisputed fact that Tony Figueroa testified that Defendant would call him to bring over underage girls and that Defendant and Epstein would have threesomes with Ms. Giuffre.................ccccccceeeeeeeeeeeeees 6 It is an undisputed fact that Rinaldo Rizzo testified that Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein. ..............ccccccccssssseeeeececeeeeeaeeeeees 8 It 1s an undisputed fact that Lyn Miller testified that she believed Defendant became Ms. Giuffre’s “new mama”’...............cssseeeeessseeeeeeeeeeeeeees 9 It is an undisputed Fact that Detective Joseph Recarey testified that he sought to investigate Defendant in relation to his investigation of Ty Te Se AIM dee earsarsastecs gap cicasoeesee a eocne sete suaeata ae santaiaeeesr saunter easaaeneaneceannmeecte 9 It is an undisputed fact that Pilot David Rodgers testified that he flew Defendant and Ms. Giuffre at least 23 times on Epstein’s jet, the “Lolita Express” and that “GM” on the flight logs Stands for Ghislaine IY AWW UN arpa srsnetgaassenaauaa st saaea ene suaaenatoasiasndsecs sao ssieuan sade sdoesee ese seaee stot 10 It is an undisputed fact that Sarah Kellen, Nadia Marcinkova, and Jeffrey Epstein invoked the fifth amendment when asked about Defendant trafficking girls for Jeffery Epstein. ............ cc eeecceeeeeeeesnreeees 10 It is an undisputed fact that Juan Alessi testified that Defendant was one of the people who procured some of the over 100 girls he witnessed visit Epstein, and that he had to clean Defendant’s sex toys. ... 11 It is an undisputed fact that Defendant 1s unable to garner a single witness throughout discovery who can testify that she did not act as the procurer of underage girls and young women for Jeffrey Epstein. ........... 12

Case 18-2868, Document 280, 08/09/2019, 2628232, Page3 of 74 B. Documentary Evidence also Shows that Defendant Trafficked Ms. Giuffre and Procured her for Sex with Convicted Pedophile Jeffrey Epstein while She Was MG cesar senna cscs cae eet tn esse asa encase wegen cantata eesantaess 2 l. SM US IU MT IS asa caesarean enero ee oss sceeea cesses 12 Zz. OT TG #TP TO GO AUG as osssceiadiscesitegotiay easel tees saeeeunecesaeuetasseeaiete ree oaeeaenioreteaseaeene: 13 2. The Victim Identification Letter...............cccccsssssccccccceeeceeceeeeesesseeeesssssnaaeees 15 4. New York Presbyterian Hospital Records...........cccccccccccccccceceeeeeeeeeeeeeeeeeees 15 5. Judith Lightfoot Psychological Records................ccccccceesseessssssssessessseseeeens 16 6. INNS SAS BAS seis ares gee eensceuaies cat eseeceaoe sees qanenetedee vane iatieaeueraeesatuee ee esentinsss 17 de TTS TO VAC Ke TOON sa saesateset cose eciecaieran dt nnctssseeiuansadoceeanecectepen Cgneciscemuns daduuscanaie 22 8. Sex Slave Amazon.com Book Receipt ................ccssseeseeeeeeceecceeeeeeeeeeeeeeaaees 23 9, Thailand Folder with Defendant’s Phone Numbet......................:s00eseeeeeees 24 10. ‘It is undisputed fact that the FBI report and the Churcher emails reference Ms. Giuffre’s accounts of sexual activity with Prince Andrew that she made in 2011, contrary to Defendant’s argument that Ms. Giuffre never made such claims until 2014.00.00... eeeeeeeeeeeeeeeeees 25 C. Defendant Has Produced No Documents Whatsoever That Tend to Show That She Did Not Procure Underage Girls For Jeffrey Epstein...........0.cccccccccccececsseeeeees 26 II. PMS NR ac pe cence ecstatic ees eee Zi TT AR GIN cc taoe ets annus 0s ase dcwanencaon ne cceianaveas wee saeesenniencssnanadchant wares deoenean: DI A. Defendant is Liable for the Publication of the Defamatory Statement and PAA SSS TOT WS MWA ANON gies sceceecace sae dooacie -ccstaunene to aecemeceseaaaetaoueu cesnaumne oorciincnsees Zh l, Under New York Law, Defendant is liable for the media’s publication OR MCT Cae Tele AS Gu. a cas cet escae tatiana cetesgdetieeaaee stereos eerie seeeeesetesvasestces: 28 2. Defendant is liable for the media’s publication of the defamatory BSF AUC TING FA yx pecosnisssacareletieneite nnotn sien c etiansinn aerraainiaonsGisouiieiaahed Lapion sien uininacinolaninnseounenecioteenen ts 32 B. Material Issues of Fact Preclude Summary Judgment....................cccceeessesseeeeeseeees 34 b., The Barden Declaration presents disputed issues of fact. ..............ccccccceees 34 ll

VI. VU. VIL. Case 18-2868, Document 280, 08/09/2019, 2628232, Page4 of 74 a. The Barden Declaration 1s a deceptive back-door attempt to inject Barden’s advice without providing discovery of all ALLOPNE y COMMA CAN ONS 52ers cetsacrsnonieeocametiauabtieneealecan cates 34 b. Defendant’s summary judgment argument requires factual findings regarding Barden’s intent, thereby precluding SUMMALY JUCGMENL. 20... cccccecceceeceeeeceeeeeececeeceeceeceeeeeeeeeeeeeeeees 35 C. There are factual disputes regarding Barden’s Declaration........... 36 U, Defendant’s Defamatory Statement Was Not Opinion as a Matter of Law.......... 38 D. The Pre-Litigation Privilege Does Not Apply to Defendant’s Press Release ....... 40 l. Defendant fails to make a showing that the pre-litigation privilege EMI PONS cysts acs rcetsmcivse gee rctetscctn occ tounge vo oasee aoe oeeseaaiea eet 40 Zi Defendant is foreclosed from using the pre-litigation privilege because SITS AG Gh Vy TU ANC agentes cts soca satea sic tesa ean es eect gueen stone aeeeeceaeat 43 3. Defendant cannot invoke the pre-litigation privilege because she has no “meritorious claim” for “good faith” litigation, ...........ceecccceceeeeeeeeeeee 46 DEFENDANT HAS NOT - AND CANNOT - SHOW THAT HER DEFAMATORY DA PE NMIBIN TG IS SUS TN tet RE cee sees ed eccrte tccnveti wens aveusenasteenenemdseutontewieers 47 PLAINTIFF DOES NOT NEED TO ESTABLISH MALICE FOR HER DEFAMATION CLAIM, BUT IN THE EVENT THE COURT RULES OTHERWISE, THERE IS MORE THAN SUFFICIENT RECORD EVIDENCE FOR A REASONABLE JURY TO DETERMINE DEFENDANT ACTED WITH dP MMM IN vane eet tec atasereesart tas bcace gence seen eet ae saeemiecaiestacsateessecetaseaesaveteseeste: 49 THE COURT NEED NOT REACH THE ISSUE, AT THIS TIME, OF WHETHER MS. GIUFFRE IS A LIMITED PURPOSE PUBLIC FIGURE... ee eeeeeeeeee 51 THE JANUARY 2015 STATEMENT WAS NOT “SUBSTANTIALLY TRUE,” AND MS. GIUFFRE HAS PRODUCED CLEAR AND CONVINCING EVIDENCE OO eM asec ae cps eae se ego coe te nae sere one acces ce sgeeacesensenecene ecco: 55 A. When Ms. Giuffre Initially Described Her Encounters With Defendant and Epstein, She Mistakenly Believed the First Encounter Occurred During the a see set gers sate scene ee nese ee rates anenseie edocs ocean Gasees sane eaenaceno es oy B. Defendant’s January 2015 Statement Claiming as “Untrue” and an “Obvious Lie” the Allegation That She Regularly Participated in Epstein’s Sexual Exploitation of Minors and That the Government Knows Such Fact is Not Substantially True But Instead Completely False. ....... cc eeeeeessseeeeeeeeeeeeeees 58 il

IX. Case 18-2868, Document 280, 08/09/2019, 2628232, Paged of 74 Cc. Defendant’s January 2015 Statement Claiming as “Untrue” or an “Obvious Lie” That Maxwell and Epstein Converted Ms. Giuffre Into a Sexual Slave is INO EU steam AN TS cts actge scan vegeta se ceces eee ence esa ere eee 60 D. Any Statement of Misdirection Regarding Professor Alan Dershowitz 1s Nothing More Than an Irrelevant Distraction to The Facts of This Case and Matters Not on the Defense of Whether Defendant’s Statement Was SUT Sed UN MNS ey asersecct oatcesvereeeieieeehasane eas heaeecei ete aces tees 61 E. Contrary to Defendant’s Position, There is a Genuine Issue of Material Fact as to Whether She Created or Distributed Child Pornography, or Whether the Government Was Aware Of Same. ............cccssssssssccccccceceeecceseseeseeeeessnnaaeeeeeeeeeeeeeees 62 F, Defendant Did Act as a “Madame” For Epstein to Traffic Ms. Giuffre to The ISTO TVG ARAN Ss eacgoe cesta sacs gsc ersc a nee cotetes ante nee ete eae aed nce naamemenes soueeoes 63 ON IN acre ew eer sce wasps 65

The text on this page is estimated to be only 41.27% accurate

Case 18-2868, Document 280, 08/09/2019, 2628232, Page6é of 74 TABLE OF AUTHORITIES Page Cases Baiul v. Disson, OO as hae res esetencseenecet castor bn poaeds a tence suntan saanseide oases eeennceple: 50 Black v. Green Harbour Homeowners’ Ass’n, Inc., UD I OF 8 INN 2) lesen ester reece cect acece ences een vaconterntensenseeceees 43 Block v. First Blood Associates, 691. Suppe685 (Sweet, J.) (SD. N.Y. 1988) sescisssisssnweasanadaneweontenooniacetsvaieaacanssdeunewands 41, 42, 43 Brady v. Town of Colchester, A cs eerie ones oreesdons bce estes sae eadeiee goatee verdes toes soeesdee cesses tees DF Chambers v. TRM Copy Ctrs. Corp., AS E3029 (20 Cit, 1994 ) a: scosssscinadsasinasdasisonsnais nncntvenaedenekessnadiasswsdasas paced banaed eoaipaennstacswassaasnaersuensess 50 Contemporary Mission, Inc. v. N.Y. Times Co., OE ZO 2 Serene tee centcaesna sede cnsteewsoeiassaisanieta aescesdianscswaanssiainanieanseeeseasiansacest 51 Da Silva v. Time Inc., OS I UD i MOF CIN Ys 9) erect ata ea vavareres aaa re seseurereanfecedanaesnewesn/oancesaresseraaatesnsiusencantes 47 Davis v. Costa-Gavras, DOU Ey Ug OD IN Yo TO 5) icacserpreaets crea sects cess vacsenees nace sy eesuenne cette acta aseenaenameeee 3] De Sole v. Knoedler Gallery, LLC, Loo Fe SUPPe 30018 (5S, DNs Y 20 1D) accnsesuasavetnsacnsacsusssvntacasbtasusketotmnacandesusdivetacasbnestactaveamiesane: 50 Eliah v. Ucatan Corp., MED Te, UO SO IN 5 TT) ase aectraseteet se eceescsaetes aes ea cesete i aameensceesa es vanee eaueateriaaceeaces 29 Flomenhaft v. Finkelstein, I27 A.D30 634. 8:N.Y.9,5¢-161.(N.Y2:-App. DIV, ZOU) swrsceseensaternstnadetevesaderniensereniademonadevn 42 Frechtman v. Gutterman, UD FD DMOZ IN oa) orca ce ctecns steers saieoacen cca seduce tonne ssctesvdnaeoasenncaneneneess 42 Friedman v. Meyers, AS2 2G 55 QGC it, 197 3) vesnssntacsndondesacasneissscedcenvesiestacandendesincssachesssieadenassateenocesiesawaszaiensenauerosss 36 Front v. Khalil, NG Vg 2 OA eaates cacaeses cas datstee ste sescessacesceaness aussrasienstunecaeedacelcac mos inusseeeicaseeneiausaane passim

The text on this page is estimated to be only 43.15% accurate

Case 18-2868, Document 280, 08/09/2019, 2628232, Page? of 74 Gerts v. Robert Welch, Inc., PEN Me 2 rate ries scenes fut au aecs Sart ee aaem Seek es baecien ba ek nae anaes eee eee dasa one: 49, 54 Giuffre v. Maxwell, TOE Ue AT ls ZO Oy arses erdeesceasoxsaceesen ears ueesceceennsaceertoeneeeisaee passim Greenberg v. CBS Inc., OP PO Oi NN ec ereceo eran nancivs sc wanlansa codes nocteceeoen unig nseninuandaousancos 54 Harte-Hanks Commc'ns, Inc. v. Connaughton, 491 U.S. 657, 109 S. Ct. 2678, 105 L. Ed. 2d 562 (1989) o.oo ecccccccccssssccccecessssssessssssscccceees 49 HB vy. Monroe Woodbury Cent. School Dist., 2012 WL 4477552 (S.D.N.Y. Sept. 27, 2012) coc cccccccccccsssssssssssnnnnneeeeeeeeeeeeeeesessseeesessssnaaees 34 Herbert v. Lando, SO Me os BIN Yo Osc rectes ceca caiss candice sdeamiceeses chdadecaeicassadeice deamneedes teadecaes a1 Hutchinson v. Proxmire, AAD. bil. 99S. Ct. 26075, 08 Te BG 204i C1979). ccncccwnrasscancetnnscannaiavesuxbacseenneaasasercanswaneanues 53 Inre “Agent Orange” Prod. Liab. Litig., ET Me se 2 VC i OS) rsa ores ee acest te ens nosccreree ceo aera enon daeneneee eee aent aetna een yneeeeenenaes Zl Karaduman v. Newsday, Inc., CEO IN eZ CEO) cha eteectenee di tains lacdanenadaasmetereunsaneaseanlacsastbecaanamaganeuesaualentasiaaiasasuscauvantes 31 Kirk v. Heppt, 2 TSU 2 SN YS eater asa cts aon oe ces satwes aos ease etene convene aatwensen seasons 42 Lerman vy. Flynt Distrib. Co., Te WD 2 C ie, Oa) cote sece temo ene ecioceine aca tenae oon eatseausnnt osanaasarnsny cosseatteusentaouces: yh 52 Levy v. Smith, Wie INV SNe Vc ICO, OL) ae ieee precstiecniceststinh ara qctge dso seed eaten ai ewtaesest ie 28 Lopez v. Univision Communications, Inc., 45 F. Supp.2d 348 (S.D.N.Y. 1999) oo cccccccccccccceccsaeseeeececceeeesaesseeeeeceeeeseaaeeeeeeeceseeesaaaeeees 48 Mitre Sports Int’l Ltd. v. Home Box Office, Inc., De Te UOC An CIN eV 0 UO) a sto soared eeu yates ind cana see neuh aswel ica auanaine ada suoyausaeest 3,417,953 National Puerto Rican Day Parade, Inc. v. Casa Publications, Inc., O14 IN: Y.5:20 120.79: A.D .36¢592 (N.Y ALD; MDE pt. ZOU) ccesscesrorsiessishesmacwecstanitemetocsoneteanes 29 Nehls v. Hillsdale Coll., NO Ng Ie 2 be ID IAC OO asa ecco ars atecteces esses cscteminr eestsees a stan totes cesses 51 V1

The text on this page is estimated to be only 45.12% accurate

Case 18-2868, Document 280, 08/09/2019, 2628232, Pages of 74 Net Jets Aviation, Inc. vy. LHC Commc’ns, LLC, D7 Os OS 2d 0 6) ca ptestias Seraces atpcise arsed paseo sceres dose pa aan Gerad asenaaee te Gowen anes beac Geneteacentas New York Times Co. v. Sullivan, 376 U.S. 254, 84S. Ct. 710, 11 L.Ed.2d 686 (1964) oo... ceeccsscceecccccccceeeeeeeeeaeseseeeseeeeeees Pacenza v. IBM Corp., Oe PO eZ) race ccrpcsted da serine cers tre seston nccenwenee davai cenu nasa now sanceuoenncasvaaaceest Patrick v. Le Fevre, TNS Me 2 N50 OM sate teres rater covet sino oes ou cae seis ea ee eects Petrus v Smith, 91 A.D.2d 1190 (N.Y.A.D.,1983) ooo ceeccsssseecccccccceceeeeeeccsaaaaeesssseeeeeceecccceeeeeeeessaaaaaaensseeeees Philadelphia Newspapers, Inc. v. Hepps, TD: Nis. TO GN) BO) eeesics secede vesg ad te cesar segs sa cad cuee ce saeticesseeossesgedss dan yaueicesdatticesdeewsseuetsicedeeee: Rand v. New York Times Co., ASO NY 3.262 71. IS A.D2ZG417 (N, VALD, 1980) scviscasncasiessssdesennmeacttsncebonvecnnosiaiastasasameeanes Rubens v. Mason, OTE NS Ze Cs 2 OY ae ccsect ecto ensues gees ucuniasuanecestusentn sacs yasenseesnacvasces tases aoesee aan sueeneds Sexter & Warmflash, P.C. v. Margrabe, OO dG BOS CNG eer DED E2007) eicchetacceastannunsanstaieasiaosa:dischmeacatanunsauaneieabianiascoustesnetts Stern v. Cosby, a Fe Us 2G Mp) sehr etre eres umn ene tent sauces aenecucossenedeub sae: 2 Swan Brewery Co. Ltd. v. U.S. Trust Co. of New York, i Sp a a enero senses piensa dado aioenceen deantaeesnnaaesseiaosadabuaieeadenenneteioemaneamsas Rules TC B15 aspect egestas ee ea insde este gcse cc secesateain casauste wea cosediec pce eh aeieceteyteneacieeseetee Other Authorities Merriam-Webster (11" ed. 2006) .....ccscssscecececscsssssessscscsescecececsescsvavevsusesecececseacarevavevevsesecececees 60, RESTATEMENT (SECOND) OF TORTS: 9:5 /6(1977 ) ccssistssractsachesstetssaxdeaclessustsioectesctaasdetsiametedcewcaseas SACK ON DEFAMATION § 2.7.2 at 2-113 to 2-114 (4th ed. 2016) oo. cccssseeeseeeeeees Vil

Case 18-2868, Document 280, 08/09/2019, 2628232, Page9 of 74 I. PRELIMINARY STATEMENT There can be no question that disputed issues of material facts preclude granting summary judgment when, in a one-count defamation case, Defendant presents the Court with a 68-page memorandum of law, a 16-page statement of purported facts, and approximately 700 pages of exhibits. The sheer scope of Defendant’s response, if anything, conclusively demonstrates that volumes of disputed facts surround the core question of whether Defendant abused Ms. Giuffre. Indeed, Defendant acknowledges a dispute between the parties as to whether she abused Ms. Giuffre. See, e.g., Motion for Summary Judgment at 1; Motion to Dismiss at 1. This Court already said that this disputed factual question 1s central to this case: Either Plaintiff is telling the truth about her story and Defendant’s involvement, or defendant is telling the truth and she was not involved in the trafficking and ultimate abuse of Plaintiff. The answer depends on facts. Defendant’s statements are therefore actionable as defamation. Whether they ultimately prove to meet the standards of defamation (including but not limited to falsity) is a matter for the fact-finder. Order Denying Defendant’s Motion to Dismiss at 10. While this fact remains in dispute, summary judgment is foreclosed. But even turning to Defendant’s claims, the avalanche of aspersions she casts upon Ms. Giuffre and her counsel should not distract the Court from the fact that the instant motion cannot come within sight of meeting the standard for an award of summary judgment. The most glaring and emblematic example of the Defendant’s far-fetched claims appears in her attempt to move away from her defamatory statement by arguing that it was her attorney and not her, who issued the defamatory statement for the press to publish, though she is forced to admit the statement was made on her behalf. This is an untenable position to take at trial, and an impossible argument to advance at the summary judgment stage, as both the testamentary and documentary evidence positively refute that argument. Defendant incorrectly asks this Court to make a factual

Case 18-2868, Document 280, 08/09/2019, 2628232, Page10 of 74 finding that her defamatory press release was actually a legal opinion, issued not by her, but by her lawyer, to the media, despite documentary evidence showing otherwise. Defendant also argues that she has proven the truth of her statement calling Ms. Giuffre a liar with respect to the statements Ms. Giuffre made about Defendant. To the contrary, voluminous evidence, both documentary and testimonial from numerous witnesses, corroborate Ms. Giuffre’s account of Defendant’s involvement in the sexual abuse and trafficking of Ms. Giuffre. Just to briefly highlight a few, Johanna Sjoberg, testified that Defendant recruited her under the guise of a legitimate assistant position, but asked her to perform sexual massages for Epstein, and punished her when she didn’t cause Epstein to orgasm.’ Tony Figueroa testified that Defendant contacted him to recruit high school-aged girls for Epstein, and also testified that Maxwell and Epstein participated in multiple threesomes with Virginia Giuffre. Even more shockingly, the butler for Defendant’s close friend witnessed, first-hand, a fifteen-year-old Swedish girl crying and shaking because Defendant was attempting to force her to have sex with Epstein and she refused. This is a fraction of the testimony that will be elicited at trial about Defendant’s involvement in the sexual abuse and trafficking of Ms. Giuffre. Defendant’s primary argument in support of her contention that she did not abuse and traffic Ms. Giuffre as a minor child is that employment records show that Ms. Giuffre was either sixteen or seventeen when Defendant recruited her from her job at Mar-a-Lago for sex with Epstein, not fifteen-years-old as Plaintiff originally thought. Call this the “yes-I’m-a-sextrafficker-but-only-of-sixteen-year-old-girls” defense. Defendant does not explain why sexual abuse of a fifteen year old differs in any material way from sexual abuse of a sixteen or seventeen year old. All instances involve a minor child, who cannot consent, and who 1s 'See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 8:5-10; 13:1-3; 12:17-14:3; 15:1-5; 32:9-16; 34:5-35:1; 36:2-1.

Case 18-2868, Document 280, 08/09/2019, 2628232, Page11 of 74 protected by federal and state laws. The fact remains that Defendant recruited Ms. Giuffre while she was a minor child for sexual purposes and then proceeded to take her all over the world on convicted pedophile Jeffrey Epstein’s private jet, the “Lolita Express,”” as well as to his various residences, and even to her own London house. Flight logs even reveal twenty-three flights that Defendant shared with Ms. Giuffre — although Defendant claims she is unable to remember even a single one of those flights. Inconsequential details that Ms. Giuffre may have originally remembered incorrectly do not render her substantive claims of abuse by Defendant false, much less deliberate “lies.” At most, these minor inaccuracies, 1n the context of a child suffering from a troubled childhood and sexual abuse, create nothing more than a fact question on whether Defendant’s statement that Ms. Giuffre lied when she accused Defendant of abuse is “substantially true,” thereby precluding summary judgment. See Mitre Sports Int’! Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 255 (S.D.N.Y. 2014) (“Because determining whether COI is substantially true would require this court to decide disputed facts ... summary judgment is not appropriate’). Defendant has tried to spin these inconsequential mistakes of memory into talismanic significance and evidence of some form of bad-faith litigation, but this claim fails under the weight of the evidence. As the Court knows, the clear weight of the evidence establishes Defendant’s heavy and extensive involvement in both Jeffrey Epstein’s sex trafficking ring and in recruiting Ms. Giuffre, living with her and Jeffrey Epstein in the same homes while Ms. Giuffre was a minor, and traveling with Ms. Giuffre and Jeffrey Epstein — including 23 documented flights. Even the house staff testified that Defendant and Ms. Giuffre were regularly * See, e.g.: “All aboard the ‘Lolita Express’: Flight logs reveal the many trips Bill Clinton and Alan Dershowitz took on pedophile Jeffrey Epstein’s private jet with anonymous women” at The Daily Mail, http://www.dailymail.co.uk/news/article-2922773/Newly-released-flight-logs-reveal-time-trips-Bill-ClintonHarvard-law-professor-Alan-Dershowitz-took-pedophile-Jeffrey-Epstein-s-Lolita-Express-private-jet-anonymous women.html.

Case 18-2868, Document 280, 08/09/2019, 2628232, Page12 of 74 together. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 103:4-9 (“Q. After that day, do you recall that she started coming to the house more frequently. A. Yes, she did. Q. In fact, did she start coming to the house approximately three times a week? A. Yes, probably.”’). It 1s also undisputed that witnesses deposed in this case have testified about Defendant’s role as a procurer of underage girls and young women for Jeffrey Epstein. At the very least, a trier of fact should determine whether the evidence establishes whether or not Ms. Giuffre’s claims of Defendant being involved in her trafficking and abuse are true. Defendant’s summary judgment motion should be denied in its entirety. II. UNDISPUTED FACTS The record evidence in this case shows that Defendant shared a household with convicted pedophile Jeffrey Epstein for many years. While there, she actively took part in recruiting underage girls and young women for sex with Epstein, as well as scheduling the girls to come over, and maintaining a list of the girls and their phone numbers. Ms. Giuffre was indisputably a minor when Defendant recruited her to have sex with convicted pedophile Jeffrey Epstein. Thereafter, Ms. Giuffre flew on Epstein’s private jets — the — Lolita Express” — with Defendant at least 23 times. A. It is an Undisputed Fact That Multiple Witnesses Deposed in This Case Have Testified That Defendant Operated as Convicted Pedophile Jeffrey Epstein’s Procurer of Underage Girls. 1. It is an undisputed fact that Joanna Sjoberg testified Defendant lured her from her school to have sex with Epstein under the guise of hiring her for a job answering phones. Ms. Sjoberg’s account of her experiences with Defendant are chillingly similar. As with Ms. Giuffre, Defendant, a perfect stranger, approached Ms. Sjoberg while trolling Ms. Sjoberg’s school grounds. She lured Ms. Sjoberg into her and Epstein’s home under the guise of a legitimate job of answering phones, a pretext that lasted only a day. A young college student, 4

Case 18-2868, Document 280, 08/09/2019, 2628232, Page13 of 74 nearly 2,000 miles from home, Defendant soon instructed Ms. Sjoberg to massage Epstein, and made it clear that Sjoberg’s purpose was to bring Epstein to orgasm during these massages so that Defendant did not have to do it. Q. And when did you first meet Ms. Maxwell? A. 2001. March probably. End of February/beginning of March. Q. And how did you meet her? A. She approached me while I was on campus at Palm Beach Atlantic College. ok 2K OK Q. And how long did you work in that position answering phones and doing -A. Just that one day. ok 2K OK Q. And what happened that second time you came to the house? A. At that point, I met Emmy Taylor, and she took me up to Jeffrey’s bathroom and he was present. And her and I both massaged Jeffrey. She was showing me how to massage. And then she -- he took -- he got off the table, she got on the table. She took off her clothes, got on the table, and then he was showing me moves that he liked. And then I took my clothes off. They asked me to get on the table so I could feel it. Then they both massaged me. ok 2K OK Q. Who did Emmy work for? 2 A. Ghislaine. 3 Q. Did Maxwell ever refer to Emmy by any particular term? 5 A. She called her her slave. ok 2K OK Q. Did Jeffrey ever tell you why he received so many massages from so many different girls? A. He explained to me that, in his opinion, he needed to have three orgasms a day. It was biological, like eating. ok 2K ok Q. Was there anything you were supposed to do in order to get the camera? THE WITNESS: I did not know that there were expectations of me to get the camera until after. She [Defendant] had purchased the camera for me, and I was over there giving Jeffrey a massage. I did not know that she was in possession of the camera until later. She told me -called me after I had left and said, I have the camera for you, but you cannot receive it yet because you came here and didn’t finish your job and I had to finish it for you. Q. And did you -- what did you understand her to mean? A. She was implying that I did not get Jeffrey off, and so she had to do it. Q. And when you say “get Jeffrey off,” do you mean bring him to orgasm? A. Yes. ok 2K ok Q. Based on what you knew, did Maxwell know that the type of massages Jeffrey was getting typically involved sexual acts? THE WITNESS: Yes. Q. What was Maxwell’s main job with respect to Jeffrey?

Case 18-2868, Document 280, 08/09/2019, 2628232, Page14 of 74 THE WITNESS: Well, beyond companionship, her job, as it related to me, was to find other girls that would perform massages for him and herself.” Ms. Sjoberg also testified about sexual acts that occurred with her, Prince Andrew, and Ms. Giuffre, when she and Defendant were staying at Epstein’s Manhattan mansion: Q. Tell me how it came to be that there was a picture taken. THE WITNESS: I just remember someone suggesting a photo, and they told us to go get on the couch. And so Andrew and Virginia sat on the couch, and they put the puppet, the puppet on her lap. And so then I sat on Andrew’s lap, and I believe on my own volition, and they took the puppet’s hands and put it on Virginia’s breast, and so Andrew put his on mine.” Ms. Sjoberg’s testimony corroborates Ms. Giuffre’s account of how Defendant recruited her (and others) under a ruse of a legitimate job in order to bring them into the household to have sex with Epstein. Ms. Sjoberg’s testimony also corroborates Ms. Giuffre’s account of being lent out to Prince Andrew by Defendant, as even the interaction Ms. Sjoberg witnessed included a sexual act: Prince Andrew using a puppet to touch Ms. Giuffre’s breast while using a hand to touch Ms. Sjoberg’s breast. 2. It is an undisputed fact that Tony Figueroa testified that Defendant would call him to bring over underage girls and that Defendant and Epstein would have threesomes with Ms. Giuffre.” Tony Figueroa testified that Plaintiff told him about threesomes Ms. Giuffre had with Defendant and Epstein which included the use of strap-ons: Q. Okay. And tell me everything that you remember about what Ms. Roberts said about being intimate with Ms. Maxwell and Mr. Epstein at the same time. A. I remember her talking about, like, strap-ons and stuff like that. But, I mean, like I said, all the details are not really that clear. But I remember her talking about, like, how __ they would always be using and stuff like that. Q. She and Ms. Maxwell and Mr. Epstein would use strap-ons? A. Uh-huh (affirmative). oK OK OK * See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 8:5-10; 13:1-3; 12:17-14:3; 15:1-5; 32:9-16; 34:5-35:1; 36:2-15. * See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 82:23-83:9. > Defendant attempts to discredit Figueroa’s damaging testimony by repeatedly mentioning that he has been convicted for a drug-related offense. Unsurprisingly, in this attack, Defendant does not mention that she has a DUI conviction. See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 390:13-15. (April 22, 2016). 6

Case 18-2868, Document 280, 08/09/2019, 2628232, Page15 of 74 Q. Other than sex with the Prince, is there anyone else that Jeffrey wanted Ms. Roberts to have sex with that she relayed to you? A. Mainly, like I said, just Ms. Maxwell and all the other girls. Q. Ms. Maxwell wanted -- Jeffrey wanted Virginia to have sex with Ms. Maxwell? A. And him, yeah. Q. And did she tell you whether she had ever done that? A. Yeah. She said that she did. *K 3K ok Q. And what did she describe having happened? A. I believe I already told you that. With the strap-ons and dildos and everything.° On eeeeerrrr—CsSE Figueroa also testified that Defendant called him to ask if he had found any other girls for Epstein, thereby acting as procurer of girls for Epstein: Q. [|W ]hen Ghislaine Maxwell would call you during the time that you were living with Virginia, she would ask you what, specifically? A. Just if I had found any other girls just to bring to Jeffrey. Q. Okay. A. Pretty much every time there was a conversation with any of them, it was either asking Virginia where she was at, or asking her to get girls, or asking me to get girls. ok 2K OK Q. Okay. Well, tell me. When did Ms. Maxwell ask you to bring a girl? A. Never in person. It was, like, literally, like, on the phone maybe, like, once or twice. Q All right. Did Ms. Maxwell call you frequently? A. No. Q. All right. How many times do you think Ms. Maxwell called you, at all? A. I'd just say that probably a just a few, a couple of times. Maybe once or twice. Q. One or two -A. The majority of the time it was pretty much his assistant. Q. How do you know Ms. Maxwell’s voice? A. Because she sounds British. Q. So someone with a British accent called you once or twice and asked for -A. Well, she told me who she was. Q. Okay. And what did she say when she called you and asked you to bring girls? A. She just said, “Hi. This is Ghislaine. Jeffrey was wondering if you had anybody that could come over.” ° See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103. ’ See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 55:19-58:23 (July 22, 2016). * See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 200:6-18; 228:23-229:21. 7

Case 18-2868, Document 280, 08/09/2019, 2628232, Page16 of 74 3. It is an undisputed fact that Rinaldo Rizzo testified that Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein. Rinaldo Rizzo was the house manager for one of Defendant’s close friends, Eva Dubin. Mr. Rizzo testified - through tears — how, while working at Dubin’s house, he observed Defendant bring a 15 year old Swedish girl to Dubin’s house. In distress, the 15 year old girl tearfully explained to him that Defendant tried to force her to have sex with Epstein through threats and stealing her passport: Q. How old was this girl? A. 15 years old. *K 3K ok Q. Describe for me what the girl looked like, including her demeanor and anything else you remember about her when she walks into the kitchen. A. Very attractive, beautiful young girl. Makeup, very put together, casual dress. But she seemed to be upset, maybe distraught, and she was shaking, and as she sat down, she sat down and sat 1n the stool exactly the way the girls that I mentioned to you sat at Jeffrey’s house, with no expression and with their head down. But we could tell that she was very nervous. Q. What do you mean by distraught and shaking, what do you mean by that? A. Shaking, I mean literally quivering. *K 3K ok Q. What did she say? A. She proceeds to tell my wife and I that, and this 1s not -- this 1s blurting out, not a conversation like I’m having a casual conversation. That quickly, I was on an island, I was on the island and there was Ghislaine, there was Sarah, she said they asked me for sex, I said no. And she is just rambling, and I’m like what, and she said -- I asked her, I said what? And she says yes, I was on the island, I don’t know how I got from the island to here. Last afternoon or in the afternoon I was on the island and now I’m here. And I said do you have a -- this is not making any sense to me, and I said this is nuts, do you have a passport, do you have a phone? And she says no, and she says Ghislaine took my passport. And I said what, and she says Sarah took her passport and her phone and gave it to Ghislaine Maxwell, and at that point she said that she was threatened. And I said threatened, she says yes, I was threatened by Ghislaine not to discuss this. And I’m just shocked. So the conversation, and she is just rambling on and on, again, like I said, how she got here, she doesn’t know how she got here. Again, I asked her, did you contact your parents and she says no. At that point, she says I’m not supposed to talk about this. I said, but I said: How did you get here. I don’t understand. We were totally lost for words. And she said that before she got there, she was threatened again by Jeffrey and Ghislaine not to talk about what I had mentioned earlier, about -- again, the word she used was sex. Q. And during this time that you’re saying she is rambling, is her demeanor continues to be what you described it?

Case 18-2868, Document 280, 08/09/2019, 2628232, Page17 of 74 A. Yes. Q. Was she in fear? A. Yes. Q. You could tell? A. Yes. A. She was shaking uncontrollably.” 4. It is an undisputed fact that Lyn Miller testified that she believed Defendant became Ms. Giuffre’s “new mama”. Lyn Miller is Ms. Giuffre’s mother. She testified that when Ms. Giuffre started living with Defendant, Defendant became Ms. Giuffre’s “new momma.””” Incredulously, Defendant testified that she barely remembered Ms. Giuffre."' 5. It is an undisputed Fact that Detective Joseph Recarey testified that he sought to investigate Defendant in relation to his investigation of Jeffrey Epstein. Detective Recarey led the Palm Beach Police’s investigation of Epstein. He testified that Defendant procured girls for Epstein, and that he sought to question her in relation to his investigation, but could not contact her due to the interference of Epstein’s lawyer: Q. A cross-reference of Jeffrey Epstein’s residence revealed which affiliated names? A. It revealed Nadia Marcinkova, Ghislane Maxwell, Mark Epstein. Also, the crossreference, any previous reports from the residence as well. Q. During your investigation, did you learn of any involvement that Nadia Marcinkova had with any of the activities you were investigating? *K 3K Q. The other name that is on here as a cross-reference is Ghislane Maxwell. Did you speak with Ghislane Maxwell? A. I did not. Q. Did you ever attempt to speak with Ghislane Maxwell? A. I wanted to speak with everyone related to this home, including Ms. Maxwell. My contact was through Gus, Attorney Gus Fronstin, at the time, who initially had told me that he would make everyone available for an interview. And subsequent conversations later, no one was available for interview and everybody had an attorney, and I was not going to be able to speak with them. Q. Okay. During your investigation, what did you learn in terms of Ghislane Maxwell’s involvement, if any? ” See McCawley Dec. at Exhibit 14, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52:6-7; 52:25-53:17; 55:23-58:5 '° See McCawley Dec. at Exhibit 12, Lynn Miller’s May 24, 2016 Dep. Tr. at 115. '' See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 77:25-78:15 (April 22, 2016). 9

Case 18-2868, Document 280, 08/09/2019, 2628232, Page18 of 74 THE WITNESS: Ms. Maxwell, during her research, was found to be Epstein’s long-time friend. During the interviews, Ms. Maxwell was involved in seeking girls to perform massages and work at Epstein’s home.'” 6. It is an undisputed fact that Pilot David Rodgers testified that he flew Defendant and Ms. Giuffre at least 23 times on Epstein’s jet, the “Lolita Express” and that “GM” on the flight logs Stands for Ghislaine Maxwell. Notably, at Defendant’s deposition, Defendant refused to admit that she flew with Ms. Giuffre, and denied that she appeared on Epstein’s pilot’s flight logs.” However, David Rodgers, Epstein pilot, testified that the passenger listed on his flight logs bearing the initials — GM — was, in fact, Ghislaine Maxwell, and that he was the pilot on at least 23 flights in which Defendant flew with Plaintiff.'* The dates of those flights show that Ms. Giuffre was an underage child on many of them when she flew with Defendant.’ 7. It is an undisputed fact that Sarah Kellen, Nadia Marcinkova, and Jeffrey Epstein invoked the Fifth Amendment when asked about Defendant trafficking girls for Jeffery Epstein. Both Sarah Kellen and Nadia Marcinkova lived with Jeffrey Epstein for many years. They both invoked the Fifth Amendment when asked about Defendant’s participation in recruiting underage girls for sex with Epstein. Marcinkova testified as follows: Q. Did Ghislaine Maxwell work as a recruiter of young girls for Jeffrey Epstein when you met her? A. Same answer. [Invocation of Fifth Amendment] *K 3K ok Q. Have you observed Ghislaine Maxwell and Jeffrey Epstein convert what started as a massage with these young girls into something sexual? A. Same answer.’° '? See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 27:10-17; 28:21-29:20. 'S See McCawley Dec. at Exhibit 11, Maxwell’s April 22, 2016 Dep. Tr. at 78-79, 144. '* See McCawley Decl. at Exhibit 41, Rodgers Dep. Ex. 1, GIUFFRE 007055-007161 (flight records evidencing Defendant (GM) flying with Ms. Giuffre). '> See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36; see also Exhibit 41, Rodgers Dep. Ex. 1 at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589. '® See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 12:11-15. 10

Case 18-2868, Document 280, 08/09/2019, 2628232, Page19 of 74 Kellen testified as follows: Q. Did Ghislaine Maxwell work as a recruiter for young girls for Jeffrey Epstein when you met her? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege... *K 2K OK Q. Isn’t it true that Ghislaine Maxwell would recruit underage girls for sex and sex acts with Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege . . .'’ Similarly, Jeffrey Epstein invoked the Fifth Amendment when asked about Defendant’s involvement in procuring underage girls for sex with him. Q. Maxwell was one of the main women whom you used to procure underage girls for sexual activities, true? THE WITNESS: Fifth. ok 2K OK Q. Maxwell was a primary co-conspirator 1n your sexual abuse scheme, true? THE WITNESS: Fifth. Q. Maxwell was a primary co-conspirator 1n your sex trafficking scheme, true? THE WITNESS: Fifth. Q. Maxwell herself regularly participated in your sexual exploitation of minors, true? THE WITNESS: Fifth."* 8. It is an undisputed fact that Juan Alessi testified that Defendant was one of the people who procured some of the over 100 girls he witnessed visit Epstein, and that he had to clean Defendant’s sex toys. Juan Alessi was Epstein’s house manager. He testified as follows: Q. And over the course of that 10-year period of time while Ms. Maxwell was at the house, do you have an approximation as to the number of different females — females that you were told were massage therapists that came to house? A. I cannot give you a number, but I would say probably over 100 in my stay there. *K OK K Q. I don’t think I asked the right — the question that I was looking to ask, so let me go back. Did you go out looking for the girls — A. No. Q. — to bring — A. Never Q. — as the massage therapists? A. Never. Q. Who did? '’ See McCawley Dec. at Exhibit 8, Kellen Dep. Tr. at 15:13-18; 20:12-16. 'S See McCawley Dec. at Exhibit 3, Epstein Dep. Tr. at 116:10-15; 117:18-118:10. 11

Case 18-2868, Document 280, 08/09/2019, 2628232, Page20 of 74 A. Ms. Maxwell, Mr. Epstein and their friends, because their friend relay to other friends they knew a massage therapist and they would send to the house. So it was referrals. ok 2K OK Q. Did you have occasion to clean up after the massages? A. Yes. Q. Okay. And that is after both a massage for Jeffrey Epstein, as well as clean up after a massage that Ghislaine Maxwell may have received? A. Yes. Q. And on occasion, after -- in cleaning up after a massage of Jeffrey Epstein or Ghislaine Maxwell, did you have occasion to find vibrators or sex toys that would be left out? A. yes, I did.” 9. It is an undisputed fact that Defendant was unable to garner a single witness throughout discovery who can testify that she did not act as the procurer of underage girls and young women for Jeffrey Epstein. Defendant has not been able to procure a single witness - not one — to testify that Defendant did not procure girls for sex with Epstein or participate in the sex. Even one of her own witnesses, Tony Figueroa, testified that she both procured girls and participated in the sex. Another one of Defendant’s witnesses, Ms. Giuffre’s mother, named Defendant as Ms. Giuffre’s “new mamma.” Indeed, those who knew her well, who spent considerable time with her in Epstein’s shared household, like Juan Alessi, Alfredo Rodriguez and Joanna Sjoberg, have testified that she was Epstein’s procuress. Others who lived with her — Jeffrey Epstein, Nadia Marcinkova, and Sarah Kellen — invoked the Fifth Amendment so as not to answer questions on the same. No one has testified to the contrary. B. Documentary Evidence also Shows that Defendant Trafficked Ms. Giuffre and Procured her for Sex with Convicted Pedophile Jeffrey Epstein while She Was Underage. 1. The Flight Logs Defendant has never offered a legal explanation for what she was doing with, and why she was traveling with, a minor child on 21 flights while she was a child, including 6 international flights, aboard a convicted pedophile’s private jet all over the world. Her motion for ' See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28:6-15; 30:51-25; 52:9-22. 12

Case 18-2868, Document 280, 08/09/2019, 2628232, Page21 of 74 summary judgment — as well as all previous briefing papers — are absolutely silent on those damning documents. 2: The Photographs Throughout a mountain of briefing and, and even in her own deposition testimony, Defendant never offered an explanation regarding Ms. Giuffre’s photographs of her, Defendant, and Epstein. She never offered a legal explanation for why Prince Andrew was photographed with his hand around Ms. Giuffre’s bare waist while she was a minor child, while posing with Defendant, inside Defendant’s house in London. This particular photograph corroborates Ms. Giuffre’s claims, and there is no other reasonable explanation why an American child should be in the company of adults not her kin, in the London house owned by the girlfriend of a now20 convicted sex offender. Ms. Giuffre also produced pictures of herself taken when she was in New York with Defendant and Epstein, and from a trip to Europe with Defendant and Epstein:7! °° See McCawley Dec at Exhibit 42, GIUFFRE007167, Prince Andrew and Defendant Photo. *I See McCawley Dec at Exhibit 42, GIUFFRE007182 - 007166. 13

Case 18-2868, Document 280, 08/09/2019, 2628232, Page22 of 74 And, Ms. Giuffre has produced a number of pictures of herself taken at the Zorro Ranch, Epstein’s New Mexico Ranch, two of which are below.” Finally, among other nude photos, which included full nudes of Defendant, Ms. Giuffre produced images of females that the Palm Beach Police confiscated during the execution of the *° See McCawley Dec at Exhibit 42, GIUFFRE007175; 007173. 14

Case 18-2868, Document 280, 08/09/2019, 2628232, Page23 of 74 watrant, including one photograph revealing the bare bottom of a girl who appears to be prepubescent (Ms. Giuffre will only submit its redacted form): ~° 3. The Victim Identification Letter In 2008, the United States Attorney’s office for the Southern District of Florida identified Ms. Giuffre as a protected “victim” of Jeffrey Epstein’s sex abuse. The U.S. Attorney mailed Ms. Giuffre a notice of her rights as a crime victim under the CVRA.”” Re: Jeffrey Epstein/ _ NOTIFICATION OF IDEN 7 M Dear By virtue of this letter, the United States Attomey’s Office for the Souther District of Florida provides you with the following notice because you are an identified victim of a federal offense. 4. New York Presbyterian Hospital Records Ms. Giuffre has provided extensive medical records in this case, including medical records from the time when Defendant was sexually abusing and trafficking her. Ms. Giuffre produced records supporting her claim of being sexually abused in New York resulting in both *> See McCawley Dec at Exhibit 44, GIUFFRE007584. ** See McCawley Dec. at Exhibit 30, GIUFFRE 002216-002218, Victim Notification Letter. 15

Case 18-2868, Document 280, 08/09/2019, 2628232, Page24 of 74 Defendant and Epstein taking Plaintiff to New York Presbyterian Hospital in New York while she was a minor.” The dates on the hospital records show she was seventeen years old. 5. Judith Lightfoot Psychological Records As the Court is aware, Defendant propounded wildly overbroad requests for production concerning the past eighteen years of Ms. Giuffre’s medical history. Defendant repeatedly and vehemently argued to the Court that it was essential to procure every page of these records in a fanfare of unnecessary motion practice. See, e.g., Defendant’s Motion to Compel (DE 75); Defendant’s Motion for Sanctions at 10 (“Ms. Maxwell has been severely prejudiced by Plaintiffs failure to provide the required identifying information and documents from her health care providers.”). Ms. Giuffre and her counsel took on the considerable burden and significant expense of retrieving and producing over 250 pages of medical records from over 20 providers, spanning two continents and nearly two decades. Now that those records have been collected, Defendant’s 68 page motion makes no reference to a single medical record produced by Ms. Giuffre, nor a single provider, nor a single treatment, nor or a single medication prescribed. After Defendant’s repeated motion practice stressing the essentiality of these records, this may surprise the Court. But not Ms. Giuffre. Defendant’s requests unearthed documents that are highly unfavorable to Defendant that corroborate Ms. Giuffre’s claims against her. Years before this cause of action arose, Ms. Giuffre sought counseling from a psychologist for the trauma she continued to experience after being abused by Defendant and Epstein. A 2011 psychological treatment record, written by her treating psychologist, unambiguously describes Defendant as Ms. Giuffre’s abuser: 5 See McCawley Dec at Exhibit 33, GIUFFRE003259-003290. 16

Case 18-2868, Document 280, 08/09/2019, 2628232, Page25 of 74 ...[Ms. Giuffre] was approached by Ghislaine Maxwell who said she could help her get a job as a massage therapist .. . seemed respectable . .. was shown how to massage, etc., Geoff [sic] Epstein. Told to undress and perform sexual acts on person. Miss Maxwell promised her $200 a job.”° Therefore, years before Defendant defamed her, Ms. Giuffre confided in her treating psychologist that Maxwell recruited her for sex with Epstein. 6. Message Pads Detective Recarey, the lead investigator of the criminal investigation into Epstein and his associates’ sex crimes, recovered carbon copies of hand-written messages taken by various staff, including Defendant, at Epstein’s Palm Beach residence.”’ These were collected both from trash pulls from the residence and during the execution of the search warrant where the pads were found laying out in the open in the residence.”* The search warrant was executed in 2005 and the message pads collected include messages recorded in 2004 and 2005. Numerous witnesses have described that these copies of collected messages accurately reflect those taken by various staff at the Palm Beach Epstein mansion between 2004 and 2005.7” The messages raise a question of fact as to Maxwell’s involvement in the sexual abuse of minors and are relevant to refute Maxwell’s denial of any involvement with Epstein during relevant time periods, and, accordingly her denial of knowledge of certain events. While there were hundreds of these messages recovered during the investigation, this small sample demonstrates the undeniable reality that there exists a genuine issue of material fact with respect to Defendant’s involvement in and knowledge of the activities described by Giuffre which Maxwell has said we “untrue” and “obvious lies.” 26 see MeCawley Dec. at Exhibit 38, Lightfoot Records, GIUFFRE005437. *! See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 45:13-25; 97:9-98:8. °8 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 25:12-21; 40:5-15; 41:16-23; 42:14-43:10; 45:13-25; see also search warrant video showing the pads openly displayed on the desk. *” See McCawley Dec. at Exhibit 21, 1, 16, 11, Rodriguez Dep. Tr. at 73:19-74:12; Alessi Dep. Tr. at 141:18-21; Sjoberg Dep. Tr. at 64:1-6; Maxwell Dep. Tr. at 147:23-148:3; 148:19-149:14. 17

Case 18-2868, Document 280, 08/09/2019, 2628232, Page26 of 74 This sampling reveals that Maxwell, “GM,” took messages at the residence, including from underage girls who were calling to schedule a time to come over to see Epstein. This demonstrates that Maxwell was at Epstein’s Palm Beach mansion in 2004 and 2005, incidentally a time period she has denied being around the house in her deposition. See supra GIUFFRE001412; 001435; 001449. The messages also reveal that multiple “girls” were leaving messages that were being taken and memorialized and left out in the open for anyone to see. Certain messages also make clear that a number of these “girls” were in school. In addition to taking messages herself (and the staff working under her direction taking these relevant messages), staff employees were taking and leaving messages for Defendant. This is evidence that Maxwell was in the house at relevant times, including times that she has now testified under oath that she was not there. Other messages demonstrate Epstein and Maxwell’s friends, including Jean Luc Brunel, leaving messages relating to underage females. The following is a small sampling of such messages: IMPORTANT MESSAGE IMPORTANT a Tae aplleer aero aE, cm = MOBILE ~ TELEPHONED | | PLEASE CALL 4 ~. WANTS TO SEE YOU RETURNED YOUR CALL WANTS TO SEE You RETUR ANED YOUR CALI CALL RETUANED YOUR CALL | GIUFFRE001412 (SAO001092) GIUFFRE001427 (SAO01456) GIUFFRE001388 (SAO001067) 18

Case 18-2868, Document 280, 08/09/2019, 2628232, Page27 of 74 IMPORTANT MESSAGE ron VK EMSTEIN SaNen GIUFFRE001432 (SA001461) GIUFFRE001456 (SAO2832) IMPORTANT MESSAGE —<—" FOR___ Se - fo AM bare —t ofa var Li) CPt ————— eg Ie eg SA001455 i \ “SSepemecsst | SEINE D acme a eL GIUFFRE001426 (SAO01455) IMPORTANT MESSAGE —_— freucrnonco |] ruease-cau caw To se6 YOU | — | wa caLLAGAN = WANTS TO SEE YOU RUSH RETURNED YOURCALL| | SPECIALATTENTION |_| Lor fou Avo teach: vou GIUFFRE001563 (SAO3008) IMPORTANT MESSAGE ron____Hy “¥. oo GIUFFRE001423 (SA001452) 19 IMPORTANT MESSAGE FOR ef ices, mae — te 2: |\_@m5 : ZN CAMETOSEEYOU | | IMPORTANT MESSAGE FOR se L DATE Fmermoneo | [ReAse oan CAME TO SEE YOU WILLCALLAGAN =| | “ian ferueveo voun ca] [sreciacarveNiON | Sore Y Lewes.’ Coo to Vol x cacy) Loclees {bd shou eve cw Luclo Fees a SOE writin Cahisteune — _. LD, SA02830 GIUFFRE001454 (SA002830)

Case 18-2868, Document 280, 08/09/2019, 2628232, Page28 of 74 The following are descriptions of a sampling of messages pads”” that create a genuine dispute of material fact: One message pad reflects ae. who 1s identified in the Palm Beach Police Report as a minor, contacting Jeffrey Epstein for “work” explaining that she does not have any money. The term “work” was often used by members of Jeffrey Epstein’s sexual trafficking ring to refer to sexual massages. (See GIUFFRE05660 (“She stated she was called by Sara for her to return to work for Epstein. stated ‘work’ is the term used by Sarah to provide the massage in underwear.”). Giuffre 001462: July 5th no year to JE from po ”I need work. I mean I don’t have money. Do you have some work for me?” Other message pads reflect ii who was a minor, calling and leaving a message at the Palm Beach mansion that she has recruited another girl for Jeffrey Epstein. The second message demonstrates that Jeffrey Epstein required different girls to be scheduled every day of the week. The third shows an offer to have two minor girls come to the home at the same time to provide sexual massages. These type of messages indicate the lack of secrecy of the fact that multiple young females were visiting every day and at least raises a question of fact whether Maxwell was knowledgeable and involved as Giuffre has said, or whether Giuffre was lying and Maxwell was not at all involved or aware of this activity, as Defendant would attempt to have the world believe. Giuffre 001428 — undated Jeffrey Fron — “Has girl for tonight” ;Giuffre 001432 (pictured above)— 7/9/04 — Mr. Epstein From Pd — is available on Tuesday no one for tomorrow”; GIUFFRE 001433 /1/17/04 — Mr. Epstein from — “Me and can come tomorrow any time or alone” ; Giuffre — 001452 — undated Jeffrey from pO “Has girl for tonight.” Other message pads demonstrate that there was a pattern and practice of using young females to recruit additional young females to provide sexual massages on a daily basis. Giuffre 001413 (pictured above)— JE from “N” — ‘ hasn’t confirmed ii for 11:00 yet, so she is keeping on hold in case doesn’t call back; Giuffre 001448 -8/20/05 JE from confirmed _ at 4 pm. Who is scheduled for morning? I believe wants to work.” This message pad reflects that a friend of Jeffrey Epstein is sending him a sixteen year old Russian girl for purposes of sex. Giuffre 001563 (pictured above)- 6/1/05 For Jeffrey From Jean Luc “He has a teacher for you to teach you how to speak Russian. She is 2X8 years old not blonde. Lessons are free and you can have your Ist today if you call.” This message pad directly refutes Maxwell’s sworn testimony that she was not present during the year 2005 at Jeffrey Epstein’s Palm Beach mansion because this shows P| leaving a message for Jeffrey at the Palm Beach home that she was going to work out *° See McCawley Dec. at Exhibit 28. 20

Case 18-2868, Document 280, 08/09/2019, 2628232, Page29 of 74 with the Defendant on September 10, 2005. The police were only able to retrieve a fraction of these message pads during their trash pull but even in the few they recovered, it shows Maxwell was regularly at the Palm Beach home during the time period she claimed she was not. To the contrary, she was both sending and receiving messages and messages, like this one, reflect her presence at the mansion. Giuffre 001412 — 9/10/05 (during the year Maxwell says she was never around) JE from P| — “T went to Sarah and made her water bottle and I went to work out with GM.” These message pads further corroborate that Defendant lied in her testimony and she was in fact in regular contact with Jeffrey Epstein during the years 2004 and 2005. For example, the message from “Larry” demonstrates that Defendant 1s at the Palm Beach mansion so frequently that people, including Epstein’s main pilot Larry Visosk1, are leaving messages for Maxwell at the Palm Beach house. Giuffre 001435 7/25/04 — Mr. Epstein from Ms. Maxwell — “tell him to call me”; Giuffre — 001449 — 8/22/05 — JE from GM; Giuffre — 001453 — 4/25/04 for Ms. Maxwell From Larry “returning your call’; This message pad shows that Defendant was clearly actively involved in Jeffrey Epstein’s life and the activities at his Palm Beach mansion. Giuffre — 001454 — undated Jeffrey From Ghislaine — “Would be helpful to have come to Palm Beach today to stay here and help train new staff with Ghislaine.” This message pad clearly reflects an underage female (noted by the police redaction of the name) leaving a message asking if she can come to the house at a later time because she needs to “stay in school.” Giuffre 001417 (pictured above)— Jeffrey 2/28/05 Redacted name “She is wondering if 2:30 is o.k. She needs to stay in school.” This message pad reflects a message from who was under the age of eighteen at the time she was going over to Jeffrey Epstein’s home to provide sexual massages according to the Palm Beach Investigative Report. Giuffre 001421 3/4/05 to Jeffrey from “It is o.k. for to stop by and drop something?” These message pads reflect the pattern of underage girls (noted by the police redaction of the name on the message pad) calling the Palm Beach mansion to leave a message about sending a “female” over to provide a sexual massage. Giuffre 001423 11/08/04 To Mr. JE — redacted from — “I have a female for him” Giuffre 001426 (pictured above) — 1/09/05 JE To JE from Redacted — “I have a female for him.” This message pad reflects the pattern and practice of having young girls bring other young girls to the house to perform sexual massages. Indeed the — reflected in this message pad corresponds in name to the ff that Tony Figueroa testified he initially brought to Jeffrey Epstein during the time period that the Defendant was requesting that Tony find some young females to bring to Jeffrey Epstein’s home. See Figueroa at 184185. The Palm Beach Police Report reflects that * ” and _ also brought seventeen year old to the home to perform sexual massages. See GIUFFRE 05641. P| thereafter recruited a number of other young girls to perform sexual 21

Case 18-2868, Document 280, 08/09/2019, 2628232, Page30 of 74 massages as reflected in the Palm Beach Police Report. Giuffre 001427 (pictured above) — 1/2/03 — JE from “Wants to know if she should bring her friend | with tonight.” e This message pad reflects multiple sexual massages being scheduled for the same day which corroborates Virginia GIUFFRE, as Johanna Sjorberg’s testimony that Jeffrey Epstein required that he have multiple orgasms in a day which occurred during these sexual massages. Giuffre 001449 (pictured above) — 9/03/05 JE from — “T left message for to confirm for 11:00 a.m. and for 4:30 p.m.” e This message pad shows a friend of Jeffrey Epstein’s discussing with him how he had sex with an 18 year old who had also been with Jeffrey Epstein. Giuffre — 001456 (pictured above)— undated JE from Jean Luc — “He just did a good one — 18 years — she spoke to me and said “I love Jeffrey.” Law enforcement was able to confirm identities of underage victims through the use of the names and telephone numbers in these message pads: Q. The next line down is what I wanted to focus on, April 5th, 2005. This trash pull, what evidence is yielded from this particular trash pull? THE WITNESS: The trash pull indicated that there were several messages with written items on it. There was a message from HR indicating that there would be an 11:00 appointment. There were other individuals that had called during that day. Q. And when you would -- when you would see females’ names and telephone numbers, would you take those telephone numbers and match it to -- to a person? THE WITNESS: We would do our best to identify who that person was. Q. And is that one way in which you discovered the identities of some of the other what soon came to be known as victims? THE WITNESS: Correct. *K 3K ok Q. Did you find names of other witnesses and people that you knew to have been associated with the house in those message pads? THE WITNESS: Yes. Q. And so what was the evidentiary value to you of the message pads collected from Jeffrey Epstein’s home in the search warrant? THE WITNESS: It was very important to corroborate what the victims had already told me as to calling in and for work.”’ 7. The Black Book Palm Beach Police confiscated an extensive lists of contacts with their phone numbers form Defendant and Epstein’s residence.*” Ghislaine Maxwell maintained a contact list in an *! See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 42:14-43:17; 78:25:-79:15. 22

Case 18-2868, Document 280, 08/09/2019, 2628232, Page31 of 74 approximately 100-page-long hard copy, which was openly available to other house employees. It consisted primarily of telephone numbers, addresses, or email addresses for various personal friends, associates, employees, or personal or business connections of Epstein or Defendant. Prior to being terminated by Defendant, the Palm Beach house butler Alfredo Rodriguez printed a copy of this document and ultimately provided it to the FBI. This document reflects the numerous phone numbers of Defendant, Epstein as well as staff phone numbers. Additionally, and importantly, there are several sections entitled “Massage” alongside a geographical designation with names of females and corresponding telephone numbers. These numbers included those of underage females (with no training in massage therapy ) — including po PG identified during the criminal investigation of Epstein. This document is an authentic reflection of the people who were associated with Epstein, Defendant, and the management of their properties, and the knowledge each had of the contents of the document. 8. Sex Slave Amazon.com Book Receipt Detective Recarey authenticated an Amazon.com receipt that the Palm Beach Police collected from Jeffrey Epstein’s trash. The books he ordered are titled: (1) SM 101: A Realistic Introduction, Wiseman, Jay; (2) SlaveCraft: Roadmaps for Erotic Servitude — Principles, Skills and Tools by Guy Baldwin; and (3) Training with Miss Abernathy: A Workbook for Erotic Slaves and Their Owners, by Christina Abernathy, as shown below: ** See McCawley Dec. at Exhibit 45, Phone List, Public Records Request No.: 16-268 at 2282 — 2288. 23

Case 18-2868, Document 280, 08/09/2019, 2628232, Page32 of 74 ‘amazon< com, Smaner L et, KY 40513 Jeffrey Epstein - ; 358 El Brillo Way \ Pakn Beach, Florida 33450 “ | USA ; an “ship Address, :.".,. “4 Jeffrey’ Epstein aps ; Jeffrey Epstein tne Oe 358 El sa : -358 ElBrilloWay 2 Beady masts Palm Beach, Flo orida 33480 si « USA eo sord57708//~ af next/24962%5 SORTExtFastTract: ae . Pigs. , ‘Item Price < Total. : . are e t a IN THIS SHIPMENT = Deen : wit. J SM 101: A fen Introduction “3 ees au Wiseman, Jay ~ nae erback: cee Co28 *):, ne PAT hy., ae cas 5 s sages pes Sate VIB He paneer de ‘Slavecratt ‘sous Erotic ie eortade-—Prinipe skits and, To's eg Bog $15.95 hs. Heh: Baldy y-== {Pa seas a OE ei. * ay Be vale ‘es fe ‘ ; - acs i ls a Denes Miss Abemaihy: 4 Workbook for Epic Siaves sand Theeg RE Aberna ei Chdatina’ i Papers nb as BNR RAF ret Rey. : a fe ae +e 4s “+e coe Rega Met ty ate Oe ees Peers SA tht tee e age wage NRA Eglin ae ee (ogee Ge VG Tee ibithegs aot EN ae th. ve . mae Page This disturbing 2005 purchase corroborate Ms. Giuffre’s account of being sexually exploited by Defendant and Epstein — not to mention the dozens of underage girls in the Palm Beach Police Report. Additionally, Defendant testified that she was not with Jeffrey Epstein in 2005 and 2006 when he was ordering books on how to use sex slaves; however, record evidence contradicts that testimony. 9. Thailand Folder with Defendant’s Phone Number Defendant also was integral in arranging to have Virginia go to Thailand. While Epstein had paid for a massage therapy session in Thailand, there was a catch. Defendant told Virginia she had to meet young girls in Thailand and bring her back to the U.S. for Epstein and Defendant. Indeed, on the travel records and tickets Defendant gave to Virginia, Defendant wrote on the back the name of the girl Virginia was supposed to meet, and she was also instructed to check in frequently with Defendant as it was further signified by the words “Call Ms. Maxwell (917) pe !? on Virginia’s travel documents. In this case, Virginia also produced the hard copy records from her hotel stay in Thailand paid for by Epstein. See McCawley Dec. at Exhibit 32, 43, GIUFFRE 003191-003192; GIUFFRE 00741 1-007432. 24

Case 18-2868, Document 280, 08/09/2019, 2628232, Page33 of 74 HS. paki NRAINIA ROBERTS 10. It is undisputed fact that the FBI report and the Churcher emails reference Ms. Giuffre’s accounts of sexual activity with Prince Andrew that she made in 2011, contrary to Defendant’s argument that Ms. Giuffre never made such claims until 2014. Based on the FBI’s Interview of Ms. Giuffre in 2011, they wrote a report reflecting Ms. ‘ aR Giuffre’s claims concerning her sexual encounters with Prince Andrew: GIUFFRE and. w ent shopping and purchased makeu clothing, anda > nes The items were purchased with GIUFFRE an 1 feetenee instructed GIUFFRE to get ready. When GIUFFRE came down after poy __When STOFFEE came dows after getting ready, she was introduced toh | = GIUFFRE traveled to CLUB TRAMP; ————__| GIUFFRE tayed at CLUB TRAMP for an hour or hour and a half and drank a couple of cocktails before returning to GIUFFRE had not received any direction After returning to requested to take a photograph of her advised that she still had the original photograph in her possession and would provide it to the interviewing agents. GIUFFRE proceeded with Approximately two months later, GIUFFRE met GIUFFRE recalled] SS GIUFFRE recalled joking about trading GIUFFRE in because she was getting too old. °° See McCawley Dec. at Exhibit 31, GIUFFRE001235-1246, FBI Redacted 302. 25

Case 18-2868, Document 280, 08/09/2019, 2628232, Page34 of 74 Additionally, 2011 correspondence with Sharon Churcher shows that Ms. Giuffre disclosed her sexual encounters with Prince Andrew, but Churcher had to check with the publisher’s lawyers “on how much can be published,” From: Sharon.Churcher@mailonsunday.co.uk Sent: Friday, 18 February 2011 7:25 AM To: Virginia Giuffre Hi there Have been up all night writing. Won't have an opinion from our lawyer on how much can be published until London wakes up. The lawyers wanted internal FBI documents but | think the Justice Dept letter is all you have from the feds??? Anyway can | give you a call early afternoon? Maybe have a late lunch? S See McCawley Dec. at Exhibit 34, GIUFFRE003678. Accordingly, there 1s documentary evidence that refutes Defendant’s meritless argument that Ms. Giuffre did not allege she had sex with Prince Andrew until 2014. To the contrary, two sources, including the FBI, show Ms. Giuffre made these claims in 2011. C. Defendant Has Produced No Documents Whatsoever That Tend to Show That She Did Not Procure Underage Girls For Jeffrey Epstein. Defendant has produced no documents that even tend to show that she did not procure underage girls for sex with Epstein, and no documents that tend to show that she did not participate in the abuse. Indeed, Defendant refused to produce any documents dated prior to 2009, which includes the 2000-2002 period during which she abused Ms. Giuffre. Against this backdrop of an avalanche of evidence showing the Defendant sexually trafficked Ms. Giuffre, summary judgment on any of the issues advanced by Defen dant is inappropriate. While we discuss the particulars of the individual claims below, the larger picture is important too. Ms. Giuffre will prove at trial that Epstein and Defendant sexually trafficked her. And yet, when Ms. Gtuffre had the courage to come forward and expose what Defendant had done to world — in a Court pleading trying to hold Epstein accountable — Defendant 26

Case 18-2868, Document 280, 08/09/2019, 2628232, Page35 of 74 responded by calling her a liar in a press release intended for worldwide publication. Such heinous conduct is not a mere “opinion,” but rather is defamation executed deliberately and with actual malice. The jury should hear all of the evidence and then render its verdict on Ms. Giuffre’s complaint. HI. LEGAL STANDARD Rule 56 of the Federal Rules of Civil Procedure provides that a motion for summary judgment may be granted only when “there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” The Second Circuit has repeatedly held that “‘all ambiguities and inferences to be drawn from the underlying facts should be resolved in favor of the party opposing the motion, and all doubts as to the existence of a genuine issue for trial should be resolved against the moving party.” Swan Brewery Co. Ltd. v. U.S. Trust Co. of New York, 832 F. Supp. 714, 717 (S.D.N.Y. 1993) (Sweet, J.), citing Brady v. Town of Colchester, 863 F.2d 205, 210 (2d Cir. 1988) (internal quotations omitted). In other words, in deciding a motion for summary judgment, the court must construe the evidence in the light most favorable to the non-moving party and draw all reasonable inferences in the non-moving party’s favor. In re “Agent Orange” Prod. Liab. Litig., 517 F.3d 76, 87 (2d Cir. 2008). Stern v. Cosby, 645 F. Supp. 2d 258, 269 (S.D.N.Y.2009). Summary judgment should be denied “if the evidence is such that a reasonable jury could return a verdict” in favor of the non-moving party. See Net Jets Aviation, Inc. v. LHC Commc’ns, LLC, 537 F.3d 168, 178-79 (2d Cir. 2008). IV. LEGAL ARGUMENT A. Defendant is Liable for the Publication of the Defamatory Statement and Damages for Its Publication Defendant’s lead argument is that, when she issued a press release attacking Ms. Giuffre to members of the media, she somehow is not responsible when the media quickly published her Dy

Case 18-2868, Document 280, 08/09/2019, 2628232, Page36 of 74 attacks. If accepted, this remarkable claim would eviscerate defamation law, as it would permit a defamer to send defamatory statements to the media and then stand back and watch — immune from liability — when (as in this case) the defamatory statements are published around the world. This absurd position is not the law, particularly given that the Defendant released a statement to media asking them to “[p]lease find attached a quotable statement on behalf of Ms. Maxwell.” To make her claim seem plausible, Defendant cites older cases, some dating back as far as 1906. This presents a distorted picture of the case law on these issues. As a leading authority on defamation explains with regard to liability for republication by another of statement by a defendant: “Two standards have evolved. The older one is that the person making the defamatory statement is liable for republication only if it occurs with his or her express or implied authorization of consent. The more modern formulation adds responsibility for all republication that can reasonably be anticipated or that is the ‘natural and probable consequence’ of the publication.”” SACK ON DEFAMATION § 2.7.2 at 2-113 to 2-114 (4th ed. 2016). In this case, however, the nuances of the applicable legal standards make little difference because Defendant so clearly authorized — indeed, desired and did everything possible to obtain — publication of her defamatory statements attacking Ms. Giuffre. 1. Under New York Law, Defendant is liable for the media’s publication of her press release. Given the obvious purposes of defamation law, New York law unsurprisingly assigns liability to individuals for the media’s publication of press releases. Indeed, New York appellate courts have repeatedly held that an individual is liable for the media publishing that individual’s defamatory press release. See Levy v. Smith, 18 N.Y.S.3d 438, 439, 132 A.D.3sd 961, 962—63 (N.Y.A.D. 2 Dept. 2015) (Generally, [o|ne who makes a defamatory statement is not responsible for its recommunication without his authority or request by another over whom he 28

Case 18-2868, Document 280, 08/09/2019, 2628232, Page3/ of 74 has no control... Here, however . . . the appellant intended and authorized the republication of the allegedly defamatory content of the press releases in the news articles’’); National Puerto Rican Day Parade, Inc. v. Casa Publications, Inc., 914 N.Y.S.2d 120, 123, 79 A.D.3d 592, 595 (N.Y.A.D. 1 Dept. 2010) (affirming the refusal to dismiss defamation counts against a defendant who “submitted an open letter that was published in [a] newspaper, and that [the defendant] paid to have the open letter published,” and finding that the defendant “authorized [the newspaper] to recommunicate his statements.) See also RESTATEMENT (SECOND) OF TORTS § 576 (1977) (“The publication of a libel or slander is a legal cause of any special harm resulting from its repetition by a third person if. . . the repetition was authorized or intended by the original defamer, or... the repetition was reasonably to be expected.”)** Defendant deliberately sent her defamatory statement to major news media publishers for worldwide circulation because Defendant wanted the public at large to believe that Ms. Giuffre was lying about her abuse. Defendant even hired a public relations media specialist to ensure the media would publish her statement. Her efforts succeeded: her public relations agent instructed dozens of media outlets to publish her “quotable” defamatory statement and they did. Despite this deliberate campaign to widely publicize her defamatory statement, Defendant now disclaims any responsibility for the media publishing her press release. If we understand Defendant’s position correctly, because she somehow lacked “control” over what major newspapers and other media finally put in their stories, she escapes liability for defamation. This nonsensical position would let a defamer send a false and defamatory letter to major media, and then, when they published the accusation, escape any liability. Such an “Cf, Eliah v. Ucatan Corp., 433 F. Supp. 309, 312-13 (W.D.N.Y. 1977) (“The alleged multistate publication of plaintiff's photograph without her consent thus gives rise to a single cause of action. ... However, evidence of the multistate publication of the magazine and the number of copies sold would be competent and pertinent to a showing of damages, if any, suffered by plaintiff.”’) 29

Case 18-2868, Document 280, 08/09/2019, 2628232, Page38 of 74 argument is not only an affront to logic, but it is contrary to prevailing New York case law, cited above. Perhaps even more important, in the context of the pending summary judgment motion, it would require Defendant to convince the jury that she did not “authorize or intend” for the major media to publish her press release. Obviously the disputed facts on this point are legion, and summary judgment is accordingly inappropriate. Even the cases Defendant cites contradict her argument. She first cites Geraci v. Probst, in which a defendant sent a letter to the Board of Fire Commissioners, and, years later, a newspaper published the letter. The court held that the defendant was not liable for that belated publication, “made years later without his knowledge or participation.” /d., at 340. By contrast, Defendant not only authorized the defamatory statement, but paid money to her publicist to convince media outlets to publish it promptly — actions taken with both her knowledge and consent. Defendant’s statement was thus not published “without [her] authority or request,” as in Geraci, but by her express authority and by her express request. Defendant’s publicist’s testimony and the documents produced by Defendant’s publicist unambiguously establish that the media published her press release with Defendant’s authority and by her request: Q. When you sent that email were you acting pursuant to Ms. Maxwell’s retention of your services? A. Yes, I was *K 3K ok Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know where the rest of this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine, Pll go with this.” It is my understanding that this is the agreed statement because the subject of the second one is “Urgent, this is the statement” so I take that as an instruction to send it out, as a positive command: “This is the statement.” *> See McCawley Dec. at Exhibit 6, Ross Gow Dep. Tr. at 14:15-17; 44:6-45:13 (emphasis added). 30

Case 18-2868, Document 280, 08/09/2019, 2628232, Page39 of 74 Similarly, another case cited by Defendant, Davis v. Costa-Gavras, involved a libel claim against a book author who wrote an account of the 1972 military coup in Chile. Years later, the plaintiff attempted to ascribe defamation liability to a third-party publishing house’s decision to republish the book in paperback form and a third-party filmmaker who released a movie based on the book. The Court held that a “party who is ‘innocent of all complicity’ in the publication of a libel cannot be held accountable . . . [but that] a deliberate decision to republish or active participation in implementing the republication resurrects the liability.” 580 F. Supp. 1082, 1094 (S.D.N.Y. 1984). Here, Defendant made a deliberate decision to publish her press release, and actively participated in that process. At the very least, the jury must make a determination of whether Defendant was “innocent of all complicity” for a libelous statement contained in her press release. Finally, Defendant cites Karaduman v. Newsday, Inc., 416 N.E.2d 557 (1980), which held that reporters of a series of articles on narcotics trade “cannot be held personally liable for injuries arising from its subsequent republication in book form absent a showing that they approved or participated in some other manner 1n the activities of the third-party republisher.” Id., 416 N.E.2d at 559-560. Again, the jury could reasonably find that Defendant both approved of, and even participated in, the media’s publication of her press release. Indeed, it is hard to understand how any jury could find anything else. Defendant was obviously “active” in influencing the media to publish her defamatory press release, she both “approved” of and pushed for the publication of the press release. Accordingly, she is liable for its publication.”° °° On page 14 of her motion, Defendant makes wholly contradictory statements. In back-to-back sentences, she tells the Court that (1) she has no control over whether the media published the statement she sent to the media (with instructions to publish it by an influential publicist); (2) her public relations representative gave instructions to the media on how to publish it (in full); and (3) her public relations representative “made no effort to control” how the media would publish it. Indeed, the best evidence of Defendant’s control over the press is the fact dozens of media outlets obeyed her directive to publish her defamatory statement. 31

Case 18-2868, Document 280, 08/09/2019, 2628232, Page40 of 74 Therefore, disclaiming responsibility for the media’s publication of a statement (for which she hired a publicist for the purpose of influencing the media to publish that statement) is contrary to both prevailing case law, and the cases cited by Defendant. 2. Defendant is liable for the media’s publication of the defamatory statement. After arguing, contrary to New York law, that she is not liable for the media’s publication of her own press release, Defendant next argues that she is not liable for the media’s publications of the defamatory statement contained within her press release 1f the media chose to make even the tiniest of editorial changes. If we understand Defendant’s argument correctly, any omission of any language from a press release is somehow a “selective, partial” publication for which she escapes liability. Mot. at 14. Once again, this claim is absurd on its face. It would mean that a defamer could send to the media a long attack on a victim with one irrelevant sentence and, when the media quite predictably cut that sentence, escape liability for the attack. Moreover, even on its face, the claim presents a Jury question of what changes would be, in context, viewed as “selective” or “partial” publications — something that only a jury could determine after hearing all of the evidence. In support of this meritless argument, Defendant cites Rand v. New York Times Co., for the proposition that a defendant cannot be liable for a publisher’s “editing and excerpting of her statement.” 430 N.Y.S.2d 271, 274, 75 A.D.2d 417, 422 (N.Y.A.D. 1980). This argument fails for several reasons. First, there is no “republication” by the media as a matter of law. Defendant issued a defamatory statement to the press, and its publication (as Defendant intended) is not a “republication” under the law, as discussed above. Second, there was no “editing” or paraphrasing or taking the quote out of context of the core defamatory statement in the press release: that Ms. Giuffre 1s a liar. The “obvious lies” passage 1s the heart of the message a2

Case 18-2868, Document 280, 08/09/2019, 2628232, Page41 of 74 Defendant sent to the press: that Ms. Giuffre was lying about her past sexual abuse. Even in isolation, Defendant’s quote stating that Ms. Giuffre’s claims are “obvious lies” does not distort or misrepresent the message Defendant intended to convey to the public that Ms. Giuffre was lying about her claims. As this Court explained in denying Defendant’s Motion to Dismiss, this case “involves statements that explicitly claim the sexual assault allegations are false.” Giuffre v. Maxwell, 165 F. Supp. 3d 147, 152 (S.D.N.Y. 2016). Furthermore, the facts at issue here make the Rand holding inapposite. In Rand, a newspaper paraphrased and “sanitized” defendant’s words. No such changing, sanitizing, or paraphrasing occurred in the instant case: the media quoted Defendant’s statement accurately. Further, the phrase at issue in Rand was that certain people “screwed” another person. The speaker/newspaper used the term “screwed” in reference to a record label’s dealings with a performing artist, and not did not mean “screwed” in the literal sense, but as “rhetorical hyperbole, and as such, 1s not to be taken literally.” Jd. By contrast, there is no hyperbole in Defendant’s defamatory statement, and it was never distorted or paraphrased by any publication known to Ms. Giuffre. A jury could reasonable conclude that Defendant’s statement that Ms. Giuffre’s claims of child sexual abuse are “obvious lies” 1s not a rhetorical device, nor hyperbole, but a literal and particular affirmation that Ms. Giuffre lied. Accordingly, there is no support in the factual record that the media reporting that Defendant stated that Ms. Giuffre’s claims of childhood sexual abuse are “obvious lies” 1s a distortion of Defendant’s message or hyperbole. Even a cursory review of the press release would lead to that conclusion. Moreover, to the extent that there is any dispute that Defendant’s statement had a different meaning outside of the context of the remainder of the press release, 33

Case 18-2868, Document 280, 08/09/2019, 2628232, Page42 of 74 such a determination of meaning and interpretation is a question of fact for the jury to decide, and 1s inappropriate for a determination upon summary judgment. B. Material Issues of Fact Preclude Summary Judgment. 1. The Barden Declaration presents disputed issues of fact. The primary basis of Defendant’s motion for summary judgment is her attorney’s selfserving, post hoc affidavit wherein he sets forth his alleged “intent” with regard Defendant’s defamatory statement.’’ Ms. Giuffre disputes Defendant’s attorney’s alleged and unproven “intent” (not to mention Defendant’s “intent’’), not only because Defendant refuses to turn over her attorney’s communications, but also because questions of intent are questions of fact to be determined by a trier of fact. Furthermore, ample record evidence contradicts the claimed “intent.” a. The Barden Declaration is a deceptive back-door attempt to inject Barden’s advice without providing discovery of all attorney communications. In her brief, Defendant discloses her attorney’s alleged legal strategy and alleged legal advice; however, she deliberately states that her attorney “intended,” instead of her attorney “advised,” when discussing her attorney’s legal strategy and advice, using that phrase at least 37 9939 ce 3940 Ce : 38 ; ; 41 times, and using phrases such as Barden’s “beliefs, purposes, goals,” and °’ The Barden declaration is problematic for other reasons as well. In addition to Defendant’s over-length, 68-page motion and among Defendant’s 654 pages of exhibits lies an eight-page attorney affidavit that proffers legal conclusions and arguments. This exhibit is yet another improper attempt to circumvent this Court’s rules on page limits. See Pacenza v. IBM Corp., 363 F. App'x 128, 130 (2d Cir. 2010) (affirming lower court decision to strike “documents submitted . . . in support of his summary judgment motion [that] included legal conclusions and arguments” because those “extraneous arguments constituted an attempt... to circumvent page-limit requirements submitted to the court.’’); cf’ HB v. Monroe Woodbury Cent. School Dist., 2012 WL 4477552, at *6 (S.D.N.Y. Sept. 27, 2012) (“The device of incorporating an affirmation into a brief by reference, as Plaintiffs have done here, in order to evade the twenty-five page limit, rather obviously defeats the purpose of the rule’). The court should disregard the Barden Declaration for that reason alone *§ MSJ at 7 (three times), 8 (three), 15 (four), 16, 25 (five), 26, 33, 35 (two), 36 (three); Statement of Facts at 6 (two), 7 (five); Decl. of Philip Barden at 4 (four), 5 (three). *’ MSJ at 25, 35; Statement of Facts at 7 (two); Decl. of Philip Barden at 3, 4 (three), 5 (two). “© MSJ at 8, 25, 35; Statement of Facts at 7 (three); Decl. of Philip Barden at 4 (two), 5 (three). 34

Case 18-2868, Document 280, 08/09/2019, 2628232, Page43 of 74 ‘“contemplations” 25 other times. All the while Defendant has claimed a privilege as to her communications with Barden. Defendant attempts to convince the Court that she only granted Gow permission to publish the defamatory statement as part of “Mr. Barden’s deliberated and carefully crafted” (MSJ at 16) legal strategy and advice. Yet, she still refused to turn over her communications with Barden under the auspices of attorney-client privilege.*” Such gamesmanship should not be permitted. If the Court were to consider the Barden Declaration (which it shouldn’t), it would be ruling on a less than complete record because, based on this Declaration, it is necessary that Defendant disclose all communications with him and possibly others. Ms. Giuffre doesn’t have those communications, the court doesn’t have those communications; therefore, Defendant is asking for summary judgment on an incomplete record. The Court should also not consider the Barden Declaration because it will be inadmissible as unduly prejudicial. It 1s a self-serving declaration by a non-deposed witness made without turning over the documents that are relevant to the declaration. See, e.g., Rubens v. Mason, 387 F.3d 183, 185 (2d Cir. 2004) (“We find that the District Court predicated its grant of summary judgment as to liability on an affidavit from the arbitrator who presided over the underlying arbitration, the probative value of which was substantially outweighed by the danger of unfair prejudice. The affidavit, therefore should not have been admitted. We therefore vacate the grant of summary judgment to the defendants on liability and remand to the District Court.’’). b. Detendant’s summary judgment argument requires factual findings regarding Barden’s intent, thereby precluding summary judgment. Even were the Court to consider this Declaration and representations therein — which it should not — the declaration itself demonstrates that the Court would have to make factual *! MSJ at 27. *° See McCawley Dec. at Exhibit 22, Defendant’s Privilege Log. 35

Case 18-2868, Document 280, 08/09/2019, 2628232, Page44 of 74 finding as to what Mr. Barden’s intent really was. Finding about intent are inappropriate at the summary judgment stage, as this Court and the Second Circuit have recognized. This Court has explained, “if it is necessary to resolve inferences regarding intent, summary judgment is not appropriate.” Id. (Sweet, J.) (emphasis added), citing Patrick v. Le Fevre, 745 F.2d 153, 159 (2d Cir. 1984); Friedman v. Meyers, 482 F.2d 435, 439 (2d Cir. 1973) (other citations omitted). C. There are factual disputes regarding Barden’s Declaration. Finally, there are material disputes over the statements in the Barden Declaration because they are directly refuted by record evidence. For example, the instant motion and the Barden Declaration describe the press release merely as a document expressing “his [Mr. Bardent’s] opinion — in the form of a legal argument —as a lawyer would be,” as opposed to a press release for dissemination by the media to the public. Record evidence refutes this claim, as (1) the press release was sent to journalists, not media publishers or in-house counsel; (2) the press release instructed the journalists to publish the defamatory statement (“Please find attached a quotable statement on behalf of Ms. Maxwell’’); (3) 1t was issued by a publicist on Defendant’s behalf and not by an attorney, without any reference to attorneys or laws — indeed, Gow testified that Barden was unavailable to approve the statement; and (4) Gow testified that he issued the statement only after he understood Defendant to have “signed off” it, an understanding he CG formed based on Defendant’s “positive command” to him: “This 1s the agreed statement.” Q. When you sent that email were you acting pursuant to Ms. Maxwell’s retention of your services? A. Yes, I was. *K 2K OK Q. When you say “agreed statement” can you tell me more about what you mean? Who agreed to the statement? A. I need to give you some context, if I may, about that statement. So, this 1s on New Year’s Day. I was in France so the email time here of 21:46, in French time was 22:46, and I was getting up early the next morning to drive my family back from the south of France to England, which is a 14-hour journey, door to door. So on the morning of th” 2nd of January, 36

Case 18-2868, Document 280, 08/09/2019, 2628232, Page45 of 74 bearing in mind that Ms. Maxwell, I think was in New York then, she was five hours behind, so there was quite a lot of, sort of time difference between the various countries here, I sent her an email, I believe, saying - parsing this-- forwarding this email to her saying “How do you wish to proceed?” And then I was on the telephone-- I had two telephones in the car, I received in excess of 30 phone calls from various media outlets on th® 2nd of January, all asking for information about how Ms. Maxwell was looking to respond to the latest court filings, which were filed on the 30th of December as I understand. And by close-- towards close of play on the 2nd, I received an email forwarded by Ms. Maxwell, containing a draft statement which my understanding was the majority of which had been drafted by Mr. Barden with a header along the lines of “This is the agreed statement.”: At close of play on th® 2nd. So—I was—I had gone under the Channel Tunnel and I was sitting on the other side and that email, which my understanding was that it had been signed off by the client, effectively, was then sent out to a number of media, including Mr. Ball and various other UK newspapers. Q. Mr. Gow, when you say “end of play” and “close of play,” are you referring to sending the email that is Exhibit 2? A. Yes, lam ok 2K ok Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know where the rest of this email chain is? A. My understanding of this 1s: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine, Pll go with this.” It is my understanding that this is the agreed statement because the subject of the second one is “Urgent, this is the statement” so I take that as an instruction to send it out, as a positive command: “This is the statement.” Accordingly, record evidence shows that the press release was intended as press release, and not as a “legal argument.” Record evidence also establishes that Defendant circulated the press release to Barden and Gow, and then gave a “positive command” to Gow to publish it. Additionally, there is no indicia that the press release is a legal opinion. To the contrary, it was issued by, and specifically attributed to, a woman who has personal knowledge of whether Ms. Giuffre’s claims of sexual abuse are true, and she states that Ms. Giuffre is a liar.” At the very least, all of these factual issues must be considered by a jury. *° See McCawley Dec. at Exhibit 6, Ross Gow Dep. Tr. at 14:15-17; 31:19-33:7; 44:6-45:13 (emphasis added). “ Unsurprisingly, Defendant cites no case law to support her argument that her attorney’s alleged influence in preparing the statement Defendant issued to the media somehow shields her from liability. 7

Case 18-2868, Document 280, 08/09/2019, 2628232, Page46 of 74 Another example is that Defendant states that “Gow served only as Mr. Barden’s conduit to the media” (MTD at 25), and “Mr. Barden was directing the January 2-15 statement to a discrete number of media representatives.” Barden wasn’t directing anything — he wasn’t even in the loop when Defendant decided to publish the statement - and the documents prove it. Indeed, the press release itself states that it 1s “on behalf of Ms. Maxwell,” not Barden, and it was Defendant who gave the “positive command” to Gow to publish it. These are just a couple of examples, among many, of the purported facts asserted in Defendant’s motion and Barden’s Declaration that are directly refuted by facts in the record. Finally, neither the media nor the general public could have known that the statement should be attributed to Barden. His name was nowhere in it, nor is there any reference to counsel. Defendant’s argument that the “context” is the media knowing Barden’s intent or involvement is unsupported by the record. The significant factual disputes about Barden, alone, prevent summary judgment. C, Defendant’s Defamatory Statement Was Not Opinion as a Matter of Law. As this Court previously held, correctly, Defendant stating that Ms. Giuffre’s claims of sexual assault are lies 1s not an expression of opinion: “First, statements that Giuffre’s claims ‘against [Defendant] are untrue,’ have been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning: that Giuffre is not telling the truth about her history of sexual abuse and Defendant’s role, and that some verifiable investigation has occurred and come to a definitive conclusion proving that fact. Second, these statements (as they themselves allege), are capable of being proven true or false, and therefore constitute actionable fact and not opinion. Third, in their full context, while Defendant’s statements have the effect of generally denying Plaintiffs story, they also clearly constitute fact to the reader.” Giuffre v. Maxwell, 165 F. Supp. 3d 147, 152 (S.D.N.Y. 2016). This Court further explained: “Plaintiff cannot be making claims shown to be untrue that are obvious lies without being a liar. Furthermore, to suggest an individual is not telling the truth 38

Case 18-2868, Document 280, 08/09/2019, 2628232, Page4/7 of 74 about her history of having been sexually assaulted as a minor constitutes more than a general denial, it alleges something deeply disturbing about the character of an individual willing to be publicly dishonest about such a reprehensible crime. Defendant’s statements clearly imply that the denials are based on facts separate and contradictory to those that Plaintiff has alleged.” /d. Defendant argues that somehow the “context” of the entire statement “tested against the understanding of the average reader” should be the press release as a whole being read only by journalists. This is an unreasonable construct because the ultimate audience for a press release is the public. Indeed, the purpose of a press release is to reach readers. Unsurprisingly, Defendant cites no case that holds that journalists might somehow believe statements of fact are opinion while others do not. This Court has previously covered this ground when it clearly stated: Sexual assault of a minor is a clear-cut issue; either transgression occurred or it did not. Either Maxwell was involved or she was not. The issue is not a matter of opinion, and there cannot be differing understandings of the same facts that justify diametrically opposed opinion as to whether Defendant was involved in Plaintiff’ s abuse as Plaintiff has claimed. Either Plaintiff is telling the truth about her story and Defendant’s involvement, or Defendant is telling the truth and she was not involved in the trafficking and ultimate abuse of Plaintiff. Giuffre v. Maxwell, 165 F. Supp.at 152 (S.D.N.Y. 2016). The same conclusion applies now. At the motion to dismiss stage, Defendant had not yet produced the statement she issued to the press. That statement is now in evidence, so there is no ambiguity as to what defendant released to the press. The absurdity of Defendant characterizing his statements calling Ms. Giuffre a liar as mere “opinion” is revealed by the fact that Defendant was the one who was sexually trafficking and otherwise abusing Ms. Giuffre. No reasonable person in any context would construe that as Defendant’s mere “opinion” on the subject, since Defendant knew she was abusing Ms. Giuffre. Indeed, this argument is contradicted by Defendant’s own deposition testimony: 39

Case 18-2868, Document 280, 08/09/2019, 2628232, Page48 of 74 Q. Do you believe Jeffrey Epstein sexually abused minors? A. I can only testify to what I know. I know that Virginia is a liar and I know what She testified is a lie. So I can only testify to what I know to be a falsehood and half those falsehoods are enormous and so I can only categorically deny everything she has said and that is the only thing I can talk about because I have no knowledge of anything else. See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. (April 17, 2016) at 174:6-19. Defendant slyly contends in her motion that “Mr. Barden’s “arguments” in the press release 999 constitute “pure opinion,’” attempting to disclaim any involvement in making the defamatory statement. However, it is not Mr. Barden’s statement, nor his opinion, that it at issue here. At issue here is Defendant’s statement — a statement attributable to her, that she approved, whose publication she “command[ed],” and for which she hired a public relations representative to disseminate to at least 30 journalists for publication. While Mr. Barden could possibly have had his own opinion as to whether or not his client abused Ms. Giuffre, Defendant cannot express an opinion on a binary, yes/no subject where she knows the truth. As this Court previously articulated, “statements that Giuffre’s claims ‘against [defendant] are untrue,’ have been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning.” Giuffre v. Maxwell, 165 F. Supp. 3d at 152. Again, at the very least, the jury must pass on such 1SSUES. D. The Pre-Litigation Privilege Does Not Apply to Defendant’s Press Release 1. Defendant fails to make a showing that the pre-litigation privilege applies. Defendant’s next argument seeks refuge in the pre-litigation privilege. If we understand the argument correctly, Defendant seems to be saying that because she was contemplating an (unspecified and never-filed) lawsuit involving the British Press, she somehow had a “green light” to make whatever defamatory statements she wanted about Ms. Giuffre. To prove such a 40

Case 18-2868, Document 280, 08/09/2019, 2628232, Page49 of 74 remarkably claim, Defendant relies on caselaw involving such mundane topics as “cease and desist” letters sent to opposing parties and the like. Obviously such arguments have no application to the press release that Defendant sent out, worldwide, attacking Ms. Giuffre’s veracity. The problems with the Defendant’s argument are legion. For starters, there is no record evidence — not even Defendant’s own testimony — suggesting that she was contemplating litigation against Ms. Giuffre, or that her press release was related to contemplated litigation against Ms. Giuffre. Tellingly, the only “evidence” Defendant cites of any alleged contemplated litigation is the self-serving, post hoc, partial waiver of attorney-client privilege found in the Barden Declaration. As discussed above, that Declaration fails to establish that there was good faith anticipated litigation between her and Ms. Giuffre, particularly when evidence in the record contradicts such assertions. At the very least, it is a matter of fact for the jury to decide. In another case in which a defendant attempted to claim pre-litigation privilege applied to statements made to the press, this Court denied summary judgment, and held, “[t]o prevail on a qualified privilege defense [defendant] must show that his claim of privilege does not raise triable issues of fact that would defeat it.” Block v. First Blood Associates, 691 F. Supp. 685, 699-700 (Sweet, J.) (S.D.N.Y. 1988) (denying summary judgment on the pre-litigation qualified privilege affirmative defense because there was “a genuine issue as to malice and appropriate purpose’). Defendant’s claim here likewise fails. First, Defendant’s testimony makes no mention of any contemplated lawsuit — much less, any contemplated lawsuit against Ms. Giuffre. Second, Defendant has offered no witnesses who will testify that she intended to bring any law suit. Third, she did not, in fact, bring any such lawsuit. The only “evidence” is a post hoc Declaration written by her attorney. Finally, 1t must be 41

Case 18-2868, Document 280, 08/09/2019, 2628232, Page50O of 74 remembered, as explained at length above, the Defendant had sexually trafficking Defendant and was attempting to continue to conceal her criminal acts. Whether her statements had an “appropriate purpose,” Block 691 F. Supp. at 699-700 (Sweet, J.) — or were, rather, efforts by a criminal organization to silence its victims — 1s obviously contested. Accordingly, obvious issues of fact exist as to whether or not Defendant contemplated litigation. Distorting reality, Defendant further argues: “Statements pertinent to a good faith anticipated litigation made by attorneys (or their agents under their direction) before the commencement of litigation are privileged.” (MSJ at 33). The record evidence shows that Defendant’s attorney did not make the defamatory statement. Further, Defendant’s attorney’s agents did not make the defamatory statement. Defendant did. And, there was no statement made by anyone “before the commencement of litigation” because /itigation never commenced. Accordingly, the cases Defendant cites where attorneys are making statements (or where clients are making statements to their attorneys regarding judicial proceedings including malpractice) are wholly inapposite as detailed below.” 45 e Front v. Khalil, 24 N.Y .3d 713, 720 (2015) - statement made by attorney. e Flomenhaft v. Finkelstein, 127 A.D.3d 634, 637 n.2, 8 N.Y.S.3d 161 (N.Y. App. Div. 2015) - did not even address pre-litigation privilege, and said that Front, Inc. was not relevant to the case. e Kirk v. Heppt, 532 F. Supp. 2d 586, 593 (S.D.N.Y. 2008) - the communication at issue was made by an attorney’s client to the attorney’s malpractice carrier concerning the client’s justiciable controversy against the attorney over which the clients actually sued. e Petrus v Smith, 91 A.D.2d 1190 (N.Y.A.D.,1983) - the court held: “[r]emarks of attorney to Surrogate are cloaked with absolute immunity as statements made in course of judicial proceedings — Attorney’s gratuitous opinion outside courthouse calling plaintiff liar . . . is not similarly immune.” (This case undermines the false argument Defendant tries to make). e Klien - contrary to dicta quoted by Defendant from the Klein case, there were no communications made “between litigating parties or their attorneys,” just a press release Defendant instructed her press agent to disseminate to the media. e Frechtman v. Gutterman, 115 A.D.3d 102, 103, 979 N.Y.S.2d 58, 61 (2014) - the communication at issue was a letter sent by a client to his attorney terminating the representation for malpractice. e Sexter & Warmflash, P.C. v. Margrabe, 38 A.D.3d 163 (N.Y.A.D. 1 Dept. 2007) - privilege applied to letter client sent discharging law firm as the client’s attorneys as statements relating to a judicial proceeding and law firm sued for defamation. 42

Case 18-2868, Document 280, 08/09/2019, 2628232, Page51 of 74 Similarly, in Black v. Green Harbour Homeowners’ Ass’n, Inc., 19 A.D.3d 962, 963, 798 N.Y.S.2d 753, 754 (2005), cited by Defendant, the Court held a privilege applied to a letter sent by a home owner’s association board of directors to the association’s members informing them of the status of litigation to which the association was a party, and to the association’s letter to the state attorney general sent to discharge it’s duties to the association. In this case, litigation was actually pending, the communication was sent by a party to that litigation as part of its duties, and the communication itself concerned the litigation. Defendant’s press release fits none of those descriptions. Unsurprisingly, Defendant cites to no case in which a Court has held that this or any qualified privilege extends to internationally disseminated press releases defaming a non-party to the purported “anticipated” litigation. Regardless of whether or not Barden had a hand in drafting the statement (another disputed issue of fact for the jury), Defendant issued the statement, instructed that it be published, and the statement she issued was attributed to her, and not to her attorney (or his agents). Accordingly, all the case law Defendant cites about an attorney making a statement (or a client making a statement to their attorney or malpractice carrier) is inapposite. 2. Defendant is foreclosed from using the pre-litigation privilege because she acted with malice. In any event, because Defendant acted with malice, she cannot avail herself of the prelitigation privilege. As this Court has explained denying Defendant’s motion to dismiss, ““*There is no qualified privilege under New York law when such statements are spoken with malice, knowledge of their falsity, or reckless disregard for their truth.’” Giuffre v. Maxwell, 165 F. Supp. 3d at 155 (citing Block, 691 F. Supp. at 699 (Sweet, J.) (S.D.N.Y. 1988). There 1s ample record evidence that Defendant acted with malice in issuing the press release, thereby making the litigation privilege inapplicable. See Block, 691 F. Supp. at 700 (Sweet, J.) (“Here, sufficient 43

Case 18-2868, Document 280, 08/09/2019, 2628232, Page52 of 74 evidence has been adduced to support the inference that [defendant] acted with malice, and may not, therefore, claim a qualified privilege under New York law . . . a genuine issue as to malice and appropriate purpose has properly been raised and is sufficient to preclude summary judgment.”’). For example, Ms. Sjoberg testified that Defendant recruited her for sex with Epstein, thus corroborating Ms. Giuffre’s own account of Defendant’s involvement in abusing her with Epstein. For another example, Jeffrey Epstein’s pilot testified that Defendant flew with Ms. Giuffre on at least 23 flights, thus corroborating Ms. Giuffre’s claims against Defendant. See McCawley Dec. at Exhibit 15, Rodgers Dep. Tr., at 34:3-10. For another example, Tony Figueroa testified that Defendant asked him for assistance in recruiting girls for Epstein — more testimony that corroborates Ms. Giuffre’s claims against Defendant. Defendant’s statements that Ms. Giuffre was lying and her claims of sexual abuse were “obvious lies” were not pertinent to a good faith anticipated litigation but, instead, they were made for an inappropriate purpose — 1.e., to bully, harass, intimidate, and ultimately silence Ms. Giuffre. As the record evidence shows, Defendant knew the statements were false because Defendant engaged in and facilitated the sexual abuse of this minor child, therefore, they were made for the inappropriate purpose of “bullying,” “harassment,” and “intimidation.” See Front v. Khalil, 24 N.Y .3d 713, 720 (2015). Simply put, Defendant sexually trafficked Ms. Giuffre — and then tried to silence Ms. Giuffre to keep her crimes secret — circumstances that prevent her from using privileges designed to shield legitimate legal disputes from court interference. New York case law fully confirms that pre-litigation qualified privilege does not apply to this case. Historically, statements made in the course of litigation were entitled to privilege from defamations claims “so that those discharging a public function may speak freely to zealously represent their clients without fear of reprisal or financial hazard.” Jd. at 718. A 2015 New York 44

Case 18-2868, Document 280, 08/09/2019, 2628232, Page53 of 74 Court of Appeals case somewhat extended this privilege by holding that statements made by attorneys prior to the commencement of the litigation are protected by a qualified privilege if those statements are pertinent to a good faith anticipated litigation. /d. at 718. (“Although it is well settled that statements made in the course of litigation are entitled to absolute privilege, the Court has not directly addressed whether statements made by an attorney on behalf of his or her client in connection with prospective litigation are privileged”. . . “to advance the goals of encouraging communication prior to the commencement of litigation” . . . “we hold that statements made prior to the commencement of an anticipated litigation are privileged, and that the privilege is lost where a defendant proves that the statements were not pertinent to a good faith anticipated litigation.’’). The Court of Appeals’ reason for allowing this qualified privilege could not be more clear: “When litigation is anticipated, attorneys and parties should be free to communicate in order to reduce or avoid the need to actually commence litigation. Attorneys often send cease and desist letters to avoid litigation. Applying privilege to such preliminary communication encourages potential defendants to negotiate with potential plaintiffs in order to prevent costly and time consuming judicial intervention.” /d. at 719-20. Under this rationale, the Khalil court found that an attorney’s letters to the potential defendant were privileged because they were sent “in an attempt to avoid litigation by requesting, among other things, that Khalil return the alleged stolen proprietary information and cease and desist his use of that information.” Jd. at 720. Here, quite unlike Khalil, the Defendant’s statements were (1) made by a non-attorney (Defendant through Gow); (2) concerning a non-party to any alleged anticipated litigation; (3) knowingly false statements; and (4) contained in a press release directed at, and disseminated to, 45

Case 18-2868, Document 280, 08/09/2019, 2628232, Page54 of 74 the public at large. Defendant’s statements cannot be considered “pertinent to a good faith anticipated litigation,” such that the qualified privilege should apply. Finally, though it strains credulity to even entertain the prospect, if Defendant could make even colorable showings on these basic issues, it would remain an issue of fact for the jury to determine whether or not Defendant’s press release, calling Ms. Giuffre’s sex abuse claims “obvious lies,” was any type of “cease-and-desist” statement or a statement that acted to “reduce or avoid” or resolve any “anticipated” litigation. Summary judgment is obviously inappropriate here as well. 3. Defendant cannot invoke the pre-litigation privilege because she has no “meritorious claim” for “good faith” litigation. Finally, Defendant cannot prevail in asserting this qualified privilege because, in order to invoke this privilege, she must have “meritorious claims” for “good faith anticipated litigation.” Khalil specifically states that for the qualified privilege to apply, the statements must be made “pertinent to a good faith anticipated litigation,” and it does not protect attorneys . . . asserting wholly unmeritorious claims, unsupported in law and fact, in violation of counsel’s ethical obligations.” Khalil, 24 N.Y.3d at 718, 720 (emphasis added). Defendant has neither “meritorious claims” nor “good faith anticipated litigation.” Defendant cannot have a “meritorious claim” for “good faith anticipated litigation” against the press (or Ms. Giuffre) because Ms. Giuffre’s reports of her sexual abuse are true, Defendant knows that they are true, and Defendant made a knowingly false statement when she called Ms. Giuffre a liar. Under these circumstances, Defendant has no “meritorious” claim to make in “good faith” relating to either Ms. Giuffre’s statements or their coverage 1n the press, thereby making her defamatory statements wholly outside the protection of this qualified privilege. At the very least, the issue of 46

Case 18-2868, Document 280, 08/09/2019, 2628232, Page55 of 74 whether Defendant has meritorious claims against the press on the grounds that she did not abuse Ms. Giuffre is a question of fact for the jury to decide. V. DEFENDANT HAS NOT - AND CANNOT - SHOW THAT HER DEFAMATORY STATEMENT IS SUBSTANTIALLY TRUE Defendant next claims that her press release calling Ms. Giuffre a liar about her past sex abuse was somehow “substantially true.” Here again, this 1s a highly disputed claim. On its face, to determine what is “substantially” true or not requires extensive fact finding, such as whether Defendant recruited Ms. Giuffre as a minor child for sex with Defendant’s live-in boyfriend and convicted pedophile, Jeffrey Epstein. Accordingly, summary judgment is not appropriate. See Mitre Sports Intern. Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 255 (S.D.N.Y.2014) (denying summary judgment because it would require the Court to decide disputed facts to determine whether the statement at issue was substantially true); Da Silva v. Time Inc., 908 F. Supp. 184, 187 (S.D.N.Y. 1995) (denying motion for summary judgment because there was a genuine issue of material act as to whether defamatory photo and caption were not true, stating “l1]n the instant case Da Silva’s contention that she was a reformed prostitute at the time of photography and publication provides a rational basis upon which a fact-finder could conclude that the photograph was not substantially true’). Additionally, Defendant has remarkably not submitted any evidence that she did not recruit Ms. Giuffre for sex with Epstein. Nor has Defendant offered any evidence that her role in Epstein’s household was not to recruit girls and young women for Jeffrey Epstein. Accordingly, summary judgment is inappropriate. See Stern v. Cosby, 645 F. Supp. 2d 258, 277 (S.D.N.Y. 2009) (because defendant had “not submitted any evidence to show that Statement 11 1s substantially true, her motion for summary judgment as to Statement 11 is denied”’). 47

Case 18-2868, Document 280, 08/09/2019, 2628232, Page56 of 74 Further, much of the purported evidence upon which Defendant relies to allege the truth of her defamatory statement is merely hearsay, including inadmissible hearsay statements made by Alan Dershowitz, who Defendant did not depose in this case (and whom Ms. Giuffre has not had an opportunity to cross examine). Hearsay cannot establish the truth of a defamatory statement as a matter of law at summary judgment. Lopez v. Univision Communications, Inc., 45 F. Supp.2d 348, 359 (S.D.N.Y.1999) (denying summary judgment and holding “defendants’ evidence as to what they were told by representatives of NYU and Kean College, to the extent offered for the truth of the matters asserted, is inadmissible hearsay and an insufficient basis upon which to grant summary judgment of dismissal on the ground that the statements were substantially true.’’). Finally, many of the facts upon which Defendant bases her argument that her defamatory statement was true are wholly tangential to the claims against her by Ms. Giuffre and the defamatory statement. For example, Defendant supports her contention that she did not recruit Ms. Giuffre for sex with Epstein based on the fact that Ms. Giuffre lived independently of her parents before meeting Epstein and Ms. Maxwell. (Of course, a child outside the supervision of her parents makes it much more likely she would be recruited by Defendant into sex trafficking, but that is for the jury to decide.) That fact does not go to whether or not Defendant’s statement calling Ms. Giuffre a liar is true, because Ms. Giuffre never made any claims relating to where she lived prior to meeting Defendant. Moreover, it is immaterial with whom she was living: the fundamental and overarching fact remains that Defendant recruited Ms. Giuffre for sex with Epstein when she was a minor child. Defendant next proffers Ms. Giuffre’s limited high school enrollment and short-term jobs that she held as evidence that she and Epstein did not abuse her. The logic of this position is 48

Case 18-2868, Document 280, 08/09/2019, 2628232, Page5/ of 74 unclear. The fact that Ms. Giuffre worked at Taco Bell for a few days hardly establishes she was not abused by Defendant and Epstein. Indeed, if anything its shows the vulnerability of Ms. Giuffre to enticements that a billionaire and his wealthy and powerful girlfriend could offer. In any event, what to make of such fact is something for the jury to consider. They are irrelevant for the same reason as above: Ms. Giuffre never made any claims about her studies or her prior employment. Indeed, neither Ms. Giuffre’s statement about being recruited by Defendant as a child, nor Defendant’s refutation even mentions Ms. Giuffre’s lack of schooling or lack of a stable home as a child. Purported facts that have nothing to do with Ms. Giuffre’s claims of sexual abuse against Defendant, and nothing to do with Defendant calling Ms. Giuffre a liar for such claims, do not establish the “substantial truth” of Defendant’s statement. Tellingly, Defendant cites to no analogous case in any jurisdiction that even suggests otherwise. VI. PLAINTIFF DOES NOT NEED TO ESTABLISH MALICE FOR HER DEFAMATION CLAIM, BUT IN THE EVENT THE COURT RULES OTHERWISE, THERE IS MORE THAN SUFFICIENT RECORD EVIDENCE FOR A REASONABLE JURY TO DETERMINE DEFENDANT ACTED WITH ACTUAL MALICE Defendant’s next (and, again, quite remarkable) argument is that Ms. Giuffre somehow will be unable to establish actual malice in this case. One would think that a sex trafficker calling one of her victims a liar would be a quintessential example of actual malice. Defendant’s spurious case citations and misplaced argument do not detract from this core fact. Though Defendant does not mention the legal standard for actual malice until she 1s 48 pages into her 68-page brief,”° the legal definition of actual malice, as defined by the United “© Though perhaps a scrivener’s error, Defendant errantly cites to two Supreme Court cases — Gerts v. Robert Welch, Inc., 418 U.S. 323 (1974) and Philadelphia Newspapers, Inc. v. Hepps, 475 U.S. 767 (1986) — that arose out of the laws of Illinois and Pennsylvania, respectively, to support a proposition concerning New York law. Defendant also cites to Harte-Hanks Commc'ns, Inc. v. Connaughton, 491 U.S. 657, 109 S. Ct. 2678, 105 L. Ed. 2d 562 (1989), wherein the ruling was not at summary judgment, and the plaintiff in the defamation case was a judicial candidate in a public election. 49

Case 18-2868, Document 280, 08/09/2019, 2628232, Page5s of 74 States Supreme Court, and reiterated by the Second Circuit, should be the light by which all of Defendant’s purported “facts” and argument should be viewed. “Actual malice” means that the statement was published with “knowledge that the statement was ‘false or with reckless disregard of whether it was false or not.’” Baiul v. Disson, 607 F. App'x 18, 20 (2d Cir. 2015), quoting New York Times Co. v. Sullivan, 376 U.S. 254, 280, 84 S. Ct. 710, 11 L.Ed.2d 686 (1964). Defendant argues that Ms. Giuffre is a limited purpose public figure. While Ms. Giuffre disputes that claim, the issue is entirely irrelevant here because Ms. Giuffre will prove at trial, with overwhelming evidence, that Defendant made her statement calling Ms. Giuffre a liar with malice, fully knowing — as a sex trafficker — that 1t was false. Put another way, Defendant knew that Ms. Giuffre was telling the truth when she described how Defendant recruited her for sex as an underage girl and then sexually trafficked her with her boyfriend Jeffrey Epstein. The Second Circuit instructs that, “[o]n a motion for summary judgment, a court cannot try issues of fact; 1t can only determine whether there are issues to be tried. If, as to the issue on which summary judgment is sought, there is any evidence in the record from any source from which a reasonable inference could be drawn in favor of the nonmoving party, summary judgment is improper.” Chambers v. TRM Copy Ctrs. Corp., 43 F.3d 29, 37 (2d Cir. 1994) (internal citations and quotations omitted). “As the moving party, Defendants have the burden of demonstrating an absence of clear and convincing evidence substantiating Plaintiffs’ claims.” De Sole v. Knoedler Gallery, LLC, 139 F. Supp. 3d 618, 640 (S.D.N.Y. 2015) (citing Chambers). Defendant fails to meet her burden of demonstrating an absence of clear and convincing evidence substantiating Ms. Giuffre’s claims that Defendant acted with actual malice. Ms. Giuffre will easily be able to meet any trial burden of clear and convincing evidence of actual 50

Case 18-2868, Document 280, 08/09/2019, 2628232, Page59 of 74 malice. Tellingly, Defendant does not even attempt to address the documentary evidence, nor the testimonial evidence showing she was a recruiter of girls for Epstein. As shown above, far beyond showing that a reasonable inference could be drawn in her favor, which is all that is required at this point to defeat Defendant’s motion, Ms. Giuffre will easily be able to meet her trial burden of clear and convincing evidence of actual malice. Of course, a plaintiff need only show “actual malice” on the part of a defendant if that plaintiff is a public figure or a limited public figure, which Ms. Giuffre is not, as explained infra. VI. THE COURT NEED NOT REACH THE ISSUE, AT THIS TIME, OF WHETHER MS. GIUFFRE IS A LIMITED PURPOSE PUBLIC FIGURE For the reasons just explained, Ms. Giuffre will easily be able to prove actual malice at the trial in this case. Defendant argues that Ms. Giuffre “is a public figure who must prove actual malice.” MSJ at 49. Given the overwhelming proof of the second part of that statement, the Court need not spend its time considering the first. If the Court wishes to nonetheless consider the issue at this time, it 1s not appropriate for disposition at the summary judgment stage of this case. The defendant bears the burden of demonstrating that the plaintiff is a limited purpose public figure. See Lerman v. Flynt Distrib. Co., 745 F.2d 123, 136—37 (2d Cir. 1984). Defendant correctly articulates the legal test for a finding that a plaintiff 1s a limited purpose public figure, but glosses over the fact that all prongs of the test must be met in order for a court to make that finding. See, e.g., Contemporary Mission, Inc. v. N.Y. Times Co., 842 F.2d 612, 617 (2d Cir. 1988) (“[T]his court set forth a four part test for determining whether someone is a limited purpose public figure” (emphasis added)); Herbert v. Lando, 596 F. Supp. 1178, 1186 (S.D.N.Y. 1984) (“The Second Circuit recently summarized the criteria’ (emphasis added)), aff'd in part, rev’d in part, 781 F.2d 298 (2d Cir. 1986); cf. Nehls v. Hillsdale Coll., 178 F. Supp. 2d 771, 778 (E.D. Mich. 2001) (finding plaintiff 51

Case 18-2868, Document 280, 08/09/2019, 2628232, Page60 of 74 was not a limited public figure for failing one element of the Lerman test and thus denying defendant’s motion for summary judgment) (“The defendant has proven all of the elements but the third ...”), aff'd, 65 F. App’x 984 (6th Cir. 2003). Of course, proof that Ms. Giuffre (or anyone else) is a limited purpose public figure requires proof of a set of facts from which Ms. Giuffre believes Defendant has not shown in satisfaction of the four-part test. Significantly —this Court should pause here to note that the details of Jane Doe 3’s sexual exploitation and abuse, as anonymously set forth in her CVRA joinder motion, caused the Defendant to identify, with certainty, Jane Doe 3 as Ms. Giuffre. Yet, at her deposition, Defendant claimed to “barely remember her at all.””’ Defendant’s ability to immediately and positively identify the anonymous individual making claims of sexual abuse, if anything, shows that Defendant was intimately aware of Ms. Giuffre’s sexual exploitation. And, to be sure, Ms. Giuffre never asked to be sexually abused or trafficked by Defendant or convicted pedophile Jeffrey Epstein when she was a child — legally, she did not even have the capacity to consent. Defendant cannot recruit a minor child for sexual exploitation and then, afterwards, argue that her victim injected herself into the public controversy when coming forward about the abuse she suffered. Moreover, Defendant has not made a sufficient showing that Ms. Giuffre has “regular” and “continuing” access to the news media. The policy rationale behind this prong is that public figures generally enjoy significant access to the media. One reporter wrote some articles on Ms. Giuffre in 2011. Thereafter, it was not until 2015, that Ms. Giuffre spoke to someone in the news media about these issues, and that interview was granted after Defendant’s defamatory remarks. Such limited contacts precludes a finding that Ms. Giuffre is a limited public figure. See * See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 44:23-45:4 (July 22, 2016) (“Q. You do remember Virginia, about that time back in the 2000s, giving Mr. Epstein massages? A. I barely remember her at all.’’). 52

Case 18-2868, Document 280, 08/09/2019, 2628232, Page61 of 74 Hutchinson v. Proxmire, 443 U.S. 111, 99 S. Ct. 2675, 61 L.Ed.2d 411 (1979) (finding plaintiff maintained no regular and continuing access to the media and thus was not a public figure). It is also unclear how Defendant plans to show that Ms. Giuffre “successfully invited public attention to her views.” To be sure, Ms. Giuffre decided to start “Victims Refuse Silence,” a not-for-profit organization whose mission 1s “to change the landscape of the war on sexual abuse and human trafficking. Our goal is to undertake an instrumental role in helping survivors break the silence associated with sexual abuse. To fulfill this mission, we aim to enhance the > The website lists the National Trafficking Hotline, lives of women who have been victimized.’ and provides a state-by-state resources for local organizations where victims can seek help. Unsurprisingly, Defendant cites no cases that hold that maintaining a website makes one a public figure. See Mitre Sports Int’l Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 252 (S.D.N.Y. 2014) (finding plaintiff was not a limited public figure and denying defendant’s motion for summary judgment) (“corporate policy denouncing child labor on its website ... dof[es] not show that Mitre ... aimed to influence the public’s views on the controversy”). More important, Defendant does not explain how Ms. Giuffre was using the website to influence public views on whether she had been abused by Defendant — the subject at issue in this lawsuit. Interestingly, Defendant has spent $ 17,875”’ on an expert witness to tell the Court and the jury that hardly anyone searches on the internet using search terms such as “victims refuse silence sex slave.” One of Defendant’s six briefs raising Daubert issues specifically argues that Dr. Anderson’s estimates on the cost of remediating Ms. Giuffre’s online reputation are improper because Dr. Anderson included nearly unused search phrases when evaluating internet content. Kent’s rebuttal report states: “. . . there seems no reason to believe that such a person would use *Shttp://www.victimsrefusesilence.org/our-mission. ” See McCawley Dec. at Exhibit 9, Kent Dep. Tr. at 25:16-26:6. 53

Case 18-2868, Document 280, 08/09/2019, 2628232, Page62 of 74 this term . . . Indeed, these are terms unlikely to be used by anyone unfamiliar with this litigation. ... Why, for instance, would it be necessary to push down offending Web pages in the results that the search engines provide for the term victim’s refuse silence sex slave, when this term 1s likely never used...” See McCawley Dec. at Exhibit 25, Kent Report at 10, 33. Defendant cannot argue to the Court that Ms. Giuffre has “successfully” invited public attention to her views through her VRS website while simultaneously filing a Daubert motion that argues that search terms such as “victims refuse silence sex slave” are “likely never used,” thus making the website unsuccessful in inviting public attention. In any event, Defendant has failed to set forth with precision the allegedly undisputed fact — and supporting evidence — she uses to support her argument. Moreover, “[ilt 1s preferable to reduce the public figure question to a more meaningful context by looking to the nature and extent of an individual’s participation in the particular controversy giving rise to the defamation.” Greenberg v. CBS Inc., 69 A.D.2d 693, 704, 419 N.Y.S.2d 988, 995 (1979) (emphasis added), citing Gertz v. Robert Welch, Inc., 418 U.S. 323, 345, 352, 94S. Ct. 2997, 41 L.Ed.2d 789. The context here is highly significant. Ms. Giuffre never chose to participate in Defendant and Epstein’s underage sex ring, a “controversy” that gave rise to Defendant’s defamation. In arguing that Ms. Giuffre thrust herself into the public spotlight, Defendant conveniently leaves out the fact that it is by her doing that Ms. Guuffre 1s in this controversy in the first place. No minor child willingly becomes a participant in sexual abuse, and it is perverse for the abuser to argue that her victim deliberately became a subject of public attention when speaking out about that abuse for the purpose of advancing justice and helping other victims. 54

Case 18-2868, Document 280, 08/09/2019, 2628232, Page63 of 74 For all these reasons, the Court should simply decline to decide the public figure issue at this juncture. But if 1t chooses to reach the issue, it should reyect Defendant’s unsupported argument. VIM. THE JANUARY 2015 STATEMENT WAS NOT “SUBSTANTIALLY TRUE,” AND MS. GIUFFRE HAS PRODUCED CLEAR AND CONVINCING EVIDENCE OF ITS FALSITY As a final argument, Defendant argues that her January 2015 statement was “substantially true.” Given that the statement argues that Ms. Giuffre lied when she said she was sexually trafficked by Defendant, the reader of Defendant’s motion might reasonably expect to see some evidence presented showing that Defendant was not a sex trafficker. Instead, the reader 1s treated to technical quibbles. For example, the lead argument to show the “substantial” truth of Defendant’s statement is the argument that Ms. Giuffre was not fifteen years old, but all of sixteen or seventeen years old when she was trafficked. As the Court knows (and can take judicial notice of), Florida law makes age eighteen the age of consent. Accordingly, it is no moment that Ms. Giuffre may have been mistaken about the exact year the sex trafficking started. Call this the “yes-I’m-a-sex-trafficker-but-only-of-sixteen-year-old-girls” defense. To even describe the defense is to show how meritless it is. More broadly, at issue are the statements Ms. Giuffre made regarding Defendant’s involvement in, and knowledge of, the sexual abuse and sex trafficking of Ms. Giuffre (and other minor girls) through a recruitment scheme executed by Defendant and Jeffrey Epstein. In response to those various statements, Defendant publicly claimed that, “the allegations made by (Ms. Giuffre) against Ghislaine Maxwell are untrue.” Defendant continued that Ms. Giuffre’s “claims are obvious lies and should be treated as such....”” Defendant, through her statement 55

Case 18-2868, Document 280, 08/09/2019, 2628232, Page64 of 74 intended to convey that Ms. Giuffre was lying about everything she had said against Defendant — “the allegations.” In sum and essence, those statements made by Ms. Giuffre about which Defendant released a public statement to exclaim were “untrue” and “obvious lies” were: (1) That Defendant approached Ms. Giuffre while Ms. Giuffre was an underage minor working at the Mar-a-Lago Country Club, and recruited the then-minor Ms. Giuffre to go to the house of Jeffrey Epstein under the pretense of providing a massage to Jeffrey Epstein for money; (2) That Ms. Giuffre followed Defendant’s instructions, and was driven to Jeffrey Epstein’s house, where she was greeted by Defendant and later introduced to Jeffrey Epstein; (3) That Ms. Giuffre was lead upstairs to be introduced to Jeffrey Epstein in his bedroom, and that while there Defendant demonstrated how Ms. Guiuffre should provide a massage to Jeffrey Epstein; (4) That Defendant and Epstein converted the massage into a sexual experience, requesting that Ms. Giuffre remove her clothing, after which time a sexual encounter was had; (5) That Defendant and Epstein expressed approval for Ms. Giuffre, and offered her money in exchange for this erotic massage turned full sexual encounter; (6) That Defendant and Epstein offered Ms. Giuffre the promise of money and a better life in exchange for Ms. Giuffre acting sexually compliant and subservient to their demands; (7) That Ms. Giuffre, after that first encounter, was repeatedly requested to service Epstein and/or Defendant sexually and/or others; (8) That Ms. Giuffre was taken on Epstein’s private planes on numerous occasions and trafficked nationally and internationally for the purpose of servicing Epstein and others, including Defendant, sexually; (9) That Defendant was Epstein’s primary manager of the recruitment and training of females who Epstein paid for sexual purposes; (10) That Defendant participated in sexual encounters with females, including Ms. Guuffre; and (11) That Ms. Giuffre and other recruited females were encouraged by Defendant and Epstein to bring other young females to Epstein for the purpose of servicing him sexually. 56

Case 18-2868, Document 280, 08/09/2019, 2628232, Page65 of 74 Defendant, by way of her January 2015 statement, declared that Ms. Giuffre lied about each and every one of these allegations regarding Defendant. In fact, Defendant clarified further this position in her deposition when she said repeatedly that everything Ms. Giuffre said about Defendant was totally false.”° The clarification in her deposition is identical in intention to the reasonable interpretation of her statement that Defendant made publicly, which has formed the basis of this defamation action—that Ms. Giuffre was lying about everything she said about Defendant, and that Defendant was not at all involved in the activity she was accused of engaging in. While her public statement could not have been more clear, as her deposition testimony further underscored, Defendant intended the world to believe that nothing Ms. Giuffre said about Defendant was true, and that Defendant was not at all involved with any of the things she was accused of, Defendant has decided in this motion to minutely dissect the nuance of Ms. Giuffre’s various statements to cause the Court to reach a far-fetched conclusion that Defendant’s insidiously false statement was somehow “substantially true.” Ironically, this repositioning amounts to nothing more than an admission by Defendant of the defamatory nature of her statement. A. When Ms. Giuffre Initially Described Her Encounters With Defendant and Epstein, She Mistakenly Believed the First Encounter Occurred During the Year 1999. Discovery has resulted in the production of records, including Ms. Giuffre’s employment records from Mar-a-Lago, which she did not possess at the time she was recounting her interactions with Defendant. Those records establish that the initial encounter wherein Defendant recruited Ms. Giuffre occurred during the year 2000 and not during 1999. Ms. Giuffre was *° See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 135:3-4; 178:15-178:24; 179:20-180:7; 228:7229:10. a7,

Case 18-2868, Document 280, 08/09/2019, 2628232, Page66 of 74 sixteen years old before August 9, 2000, and turned seventeen on that date. It is unclear from the limited records available whether Defendant approached and recruited Ms. Giuffre before or just after Ms. Giuffre’s 17th birthday. However, what has now been established through numerous witnesses is that Defendant approached and recruited a minor child for the purposes of enticing that minor over to the house of Jeffrey Epstein, a currently-registered sex offender.”’ The exact lure of Ms. Giuffre by Defendant - enticement of being paid money to give a billionaire a massage at his mansion - was used by Epstein and his many associates and employees to recruit dozens and dozens of other underage girls. There is no doubt that the crux of Ms. Giuffre’s statement on this point is that Defendant recruited her when she was only a minor child unable to consent to sex, not precisely how far under the age of consent she was. Defendant’s public claim that Ms. Giuffre’s account of this approach, and recruiting element, was “untrue” and “obvious lies” is not “substantially true,” but is itself an obvious lie — as Ms. Giuffre will prove to the jury at trial. B. Defendant’s January 2015 Statement Claiming as “Untrue” and an “Obvious Lie” the Allegation That She Regularly Participated in Epstein’s Sexual Exploitation of Minors and That the Government Knows Such Fact is Not Substantially True But Instead Completely False. Defendant next argues that she “accurately denied that [she] ‘regularly participate[d] in Epstein’s sexual exploitation on minors’ and that ‘the Government knows such fact.’” MSJ at 58. It 1s not clear whether Defendant is nitpicking this statement by contesting whether she “regularly” participated in Epstein’s sexual exploitation or whether she did participate, but the Government was unaware of the extent of her involvement. Call this the “yes-I’m-a-sextrafficker-but-only-on-Tuesdays-and-Thursdays” defense — here again, to simply recount the claim is to see its absurdity. >! See McCawley Dec. at Exhibit 1, 5, Alessi Dep. Tr. at 94:24-95:2; Giuffre Dep. Tr. at 111:12-111:21; 116:19ii 58

Case 18-2868, Document 280, 08/09/2019, 2628232, Page6/ of 74 Contrary to Defendant’s misleading, cherry-picked fragments of information she has chosen to use to support her point, there is an abundance of evidence clearly linking Defendant to Epstein’s sexual exploitation of minors. As the Court is aware, numerous message pads were recovered from Epstein’s home indicating Defendant’s involvement in and knowledge of Epstein’s illegal exploitation. °* Additionally, numerous employees and others have testified about Defendant’s high-ranking position in the hierarchal structure of the sexual exploitation scheme. >> In fact, multiple individuals, in addition to the Ms. Giuffre, have testified about Maxwell’s involvement in the exploitation of minors, including Ms. Giuffre.”* Defendant also argues that one government investigator, Palm Beach, Florida, Detective Recarey, may not have been aware of her involvement in the sex trafficking. Defendant fails to cite another passage in Detective Recarey’s deposition, where he noted that he was aware of Defendant’s involvement with Epstein and the sexual exploitation of children.”’ But even assuming Recarey was unaware (which Ms. Giuffre strongly disputes), Defendant would have, at most, a “yes-I’m-a-sex-trafficker-but-I-successfully-hid-it-from-one-of-the-cops”’ defense — again, not a likely claim. More broadly, Ms. Giuffre’s statement about what the “Government” knew about sex trafficking was made in pleadings filed in a federal Court case attacking the decision of the U.S. Attorney’s Office for the Southern District of Florida to offer Jeffrey Epstein immunity from prosecution for federal sex trafficking crimes. Accordingly, to present an even arguable claim for summary judgment, Defendant would have to show that the U.S. Attorney’s Office (and its ** See, e.g., McCawley Dec at Exhibit 28 (message pad excerpts), GIUFFRE 001412, 001418, 001435, 001446, 001449, 001453, 001454. *°See McCawley Dec. at Exhibit 21, 1, Rodriguez Dep. Tr. at 169:1-169:4; Alessi Dep. Tr. at 23:11-23:20; 34:1935:3; 98:5-98:12; 104:15-104:23. »* See McCawley Dec. at Exhibit 16, 4, Sjoberg Dep. Tr. at 13; Figueroa Dep. Tr. at 96-97; 103; 200:6-18; 228:23229721. »° See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 29:16-29:20; 45:13-25; 83:3-83:15. 59

Case 18-2868, Document 280, 08/09/2019, 2628232, Page68 of 74 investigators from the FBI) did not know about Defendant’s sex trafficking. This proof would need to include, for example, evidence that the FBI did not learn about Defendant’s sex trafficking when (among other things) Ms. Giuffre told FBI agents about it when she met with them in Australia in 2011. Here again, Defendant has no evidence to even begin making such a showing. Cc. Defendant’s January 2015 Statement Claiming as “Untrue” or an “Obvious Lie” That Maxwell and Epstein Converted Ms. Giuffre Into a Sexual Slave is Not Substantially True. Defendant next argues that she accurately disputed Ms. Giuffre’s statement that Defendant held her as a “sex slave.” Relying on dictionary definitions of “slave” that define the term to refer to a “confined” person who is the “legal property” of another (MSJ at 59, citing Merriam-Webster, etc.), Defendant claims Ms. Giuffre was not confined or the property of Defendant. Call this the “yes-I’m-a-sex-trafficker-but-I-didn’t-use-chains” defense. And, once again, to even describe the defense is to refute it. Defendant does not explain why the jury would be required to use the held-in-chains definition of “slave” in evaluating her statement. Merriam-Webster (1 1" ed. 2006) also defines “slave” as “one that is completely subservient to a dominating influence” — a definition that fits Ms. Giuffre’s circumstances to a tee. As Ms. Giuffre has explained in detail, she was recruited as a minor child by Defendant, who then dominated her and used for sexual purposes. That testimony alone creates a genuine issue of fact on this point. From the context of all of Ms. Giuffre’s statements about Defendant, Ms. Giuffre has never said or implied that she was physically placed in a cage. Instead, she has described the vast disparity of power and the influence of Defendant and Epstein, the fear of disobedience, the typical locations of the abuse being in a private plane, in huge mansion manned with Epstein employed servants, a private island, or some inescapable place abroad in the presence of 60

Case 18-2868, Document 280, 08/09/2019, 2628232, Page69 of 74 Defendant, in addition to the continued — and fraudulent — promise of a better future, as those things that kept her retained in a situation of sexual servitude. While not physical chained, Ms. Giuffre was groomed as minor and trained, and these factors became her invisible chains. Indeed, as Ms. Giuffre’s expert on sex trafficking, Professor Coonan, has explained: Popular understandings of the term “sex slave” might still connote images of violent pimps, white slavery, or of victims chained to a bed in a brothel in the minds of some people. To call Ms. Giuffre a victim of sex trafficking would however very accurately convey the reality that she along with a great many other victims of contemporary forms of slavery are often exploited by the “invisible chains” of fraud and psychological coercion. See McCawley Dec. at Exhibit 23, Coonan Expert Report at 20. If the Court takes as true, which it must for the purpose of this motion, that Ms. Giuffre was trafficked and used exclusively for sexual purposes by Defendant and Epstein, then the Court must also reach the conclusion at this stage that Maxwell’s assertion — that Ms. Giuffre’s description of being a sex slave is “untrue” or “obvious lies” — is not substantially true. There undoubtedly remains a genuine issue of material fact on this point, and in fact, Defendant’s position taken in this motion is tantamount to an admission of the truth of Plaintiff's statement about Defendant on this point. D. Any Statement of Misdirection Regarding Professor Alan Dershowitz is Nothing More Than an Irrelevant Distraction to The Facts of This Case and Matters Not on the Defense of Whether Defendant’s Statement Was Substantially True. Defendant next contends that she accurately recounted that Alan Dershowitz had denied having sex with Ms. Giuffre. MSJ at 60. Call this the “yes-I’m-a-sex-trafficker-but-she-was-nottrafficked-to-the-professor” defense. While it 1s accurate that Ms. Giuffre made allegations against Professor Dershowitz, those allegations are not at issue 1n this case. Defendant, in her defamatory statement, claimed that “the allegations made by [Ms. Giuffre] against Ghislaine Maxwell are untrue.” See McCawley Dec. at Exhibit 26, GM_ 00068. In her deposition, 61

Case 18-2868, Document 280, 08/09/2019, 2628232, Page/0O of 74 Defendant maintained the position that she “cannot speculate on what anybody else did or didn’t do.” See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 180:3-180:4. In fact, regarding Ms. Giuffre’s claims about others, Defendant unequivocally stated, “I_can only testify to what she said about me, which was 1000 percent false.” See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 228:10-228:12. Defendant Maxwell makes additional misstatements about Dershowitz’s production in a defamation action filed against him in her desperate attempt to have Dershowitz to jump aboard and help bail out her sinking canoe. While Ms. Giuffre can — and, if necessary, will — refute Dershowitz’s claim he was not a beneficiary of Epstein and Defendant’s sex trafficking, that is not relevant at this stage. Whatever may or may not have happened with Dershowitz (and Ms. Giuffre’s sworn statements that he sexually abused her is alone enough to create disputed facts on the issue of whether Defendant’s statements about him were “substantially true’’) has no bearing whatsoever on the truth or falsity of the statements Ms. Giuffre made about Defendant. This case 1s not about whether Ms. Giuffre has ever made untruthful allegations against anyone, which she contends she has not, but about whether her allegations about Defendant 99 66 were true, or whether those specific allegations were “untrue,” “obvious lies” as Defendant publicly proclaimed. These issues are disputed and must go to the jury. E. Contrary to Defendant’s Position, There is a Genuine Issue of Material Fact as to Whether She Created or Distributed Child Pornography, or Whether the Government Was Aware of Same. Defendant next argues that she did not create child pornography and that the Government knew this. Call this the “until-you-find-the-photos-I’m-innocent” defense. Of course, as noted earlier, Defendant’s claim requires that she show that “the Government” — in context, the FBI and the U.S. Attorney’s Office for the Southern District of Florida — “knew” that she had no 62

Case 18-2868, Document 280, 08/09/2019, 2628232, Page/1 of 74 child pornography. Yet Defendant has offered no such evidence — much less evidence so powerful as to warrant summary judgment on this point. This point is disputed from the simple fact that Ms. Giuffre herself testified that Defendant took many photograph of her naked. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 232:3-9; 233:7-9. This is consistent with the Palm Beach butler’s, Alfredo Rodriguez’s, testimony that he personally saw photos of naked children on Defendant’s computer. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 150:10-17; 306:1-306:24. Another housekeeper, Juan Alessi also saw photos of young nude females on Defendant’s computer, although he wasn’t sure whether to consider it pornography. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 175:5-175:24. Finally, Detective Recarey found a collage of nude photos of young females in Epstein’s closet, and turned the photos over to the FBI and U.S. Attorney’s office.°° While the U.S. Attorney’s office will not share the photos obtained from Recarey’s investigation, it is thus undisputed that the government possesses photos of nude, young females confiscated from Epstein’s Palm Beach mansion. Indeed, the police video disclosed through a FOIA request shows naked images of women throughout the house, including a full nude of the Defendant.’’ At a minimum, there is a clear genuine issue of material fact in this regard. F. Defendant Did Act as a “Madame” For Epstein to Traffic Ms. Giuffre to The Rich and Famous. Defendant next argues that she did not act as a “Madame” for Epstein. MSJ at 63. The gist of the argument seems to be that Defendant believes trafficking one girl to Epstein does not a Madame make. Call this the “yes-I-was-Virginia’s-Madame-but-no-one-else’s” defense. This argument fails linguistically on the very dictionary definitions that Defendant cites elsewhere — °° See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 73:19-73:24; 74:2-74:7. >’ See McCawley Dec. at Exhibit 44, FOLIA CD GIUFFRE 007584. 63

Case 18-2868, Document 280, 08/09/2019, 2628232, Page/2 of 74 but not here. See Merriam-Webster (1 1" ed. 2006) (defining “madam” as “the female head of a house of prostitution’). Once again, Defendant conceals the relevant facts on this issue. First, multiple witnesses have testified to Defendant’s recruiting, maintaining, harboring, and trafficking girls for Epstein.°® In fact, Defendant herself was unable to deny procuring Ms. Giuffre for Epstein.” While Defendant has attempted to fumble her way through explaining some plausible reason for bringing a sixteen or seventeen year old to Epstein, her explanations are, to put it blandly, unpersuasive. As with other issues, the jury will have to decide who to believe. One of the individuals Ms. Giuffre was trafficked to was Prince Andrew — trafficking that took place in Defendant’s own townhouse in London. There exist flight logs evidencing Ms. Giuffre flying to London alongside Defendant and Epstein on Epstein’s private plane, and a photo of Ms. Giuffre, Defendant, and the Prince, without Defendant ever offering a legal reasonable explanation for that photo being taken, or for traveling with a year old girl overseas. Defendant begins to meander somewhat aimlessly on this point, shifting Plaintiffs burden to substantiate Plaintiffs claim that Defendant was Epstein’s Madame, which is a point at issue, into whether or not Plaintiff has conclusively proven the identities and accurate job titles of the other men to whom Plaintiff was lent for sex by Epstein. No matter how hard Defendant tries to reframe this case, drag other people in, or split hairs, she is unable to contest the facts — facts showing she was more than a Madame but a full-fledged sex trafficker. Ms. Giuffre told the truth when she said that Defendant recruited her as a minor, under the pretense of giving a *8 See McCawley Dec. at Exhibit 16, 1, 18, 2, Sjoberg Dep. Tr. at 13; Alessi Dep. Tr. at 34; GIUFFRE000105 at 5758; GIUFFRE000241-242 at p. 212-213; Austrich Dep. Tr. at 34-35, 100-101, 127-128; Alessi Dep. Tr. at 34:1935:3; 98:5-98:12; 104:15-104:23. *” See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 214:14-215:3. 64

Case 18-2868, Document 280, 08/09/2019, 2628232, Page/3 of 74 massage, and converted her into a traveling sex slave, consistent with Defendant and Epstein’s pattern and practice. As the Court astutely acknowledged early on, “at the center of this case is the veracity of a contextual world of facts more broad than the allegedly defamatory statements . . . either transgression occurred or it did not. Either Maxwell was involved or she was not.” If Defendant was involved, then her January 2015 statement was defamatory. Ms. Giuffre will prove to the jury, through overwhelming evidence, her prior allegations about Defendant’s involvement. The Court should give Ms. Giuffre that opportunity, and deny Defendant’s motion for summary judgment. IX. CONCLUSION For the foregoing reasons, this Court should deny Defendant’s motion for summary judgment in all respects. Dated: January 31, 2017 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 65

Case 18-2868, Document 280, 08/09/2019, 2628232, Page/4 of 74 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-5202 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 31, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document 1s being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECEF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10" Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com jpaghuca@hmflaw.com /s/ Sigrid S. McCawley Sigrid S. McCawley °° This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 66

Case 18-2868, Document 281, 08/09/2019, 2628234, Pagel of 66 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS V. Ghislaine Maxwell, Defendant. / SOUTHERN DISTRICT OF NEW YORK LOCAL RULE 56.1 PLAINTIFF’S STATEMENT OF CONTESTED FACTS AND PLAINTIFF’S UNDISPUTED FACTS DEFENDANT’S PURPORTED FACTS l. Ms. Maxwell’s response to publications of Ms. Giuffre’s false allegations: the March 2011 statement. In early 2011 Ms. Giuffre in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. In the articles, Ms. Giuffre made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, Ms. Giuffre suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS Ms. Giuffre denies that the allegations she made against Ms. Maxwell are false. Furthermore, Ms. Giuffre did give an interview to journalist, Sharon Churcher, in which Ms. Giuffre accurately and truthfully described Defendant Maxwell's role as someone who recruited or facilitated the recruitment of young females for Jeffrey Epstein. See McCawley Dec. at Exhibit 34, GIUFFRE003678. Ms. Giuffre was also interviewed by the FBI in 2011 and she discussed Defendant’s involvement in the sexual abuse. See McCawley Dec. at Exhibit 31, FBI Redacted 302, FIUFFRE001235-1246. Those statements were not "false and defamatory," but instead truthful and accurate.

Case 18-2868, Document 281, 08/09/2019, 2628234, Page2 of 66 DEFENDANT’S PURPORTED FACTS 2 In the articles, Ms. Giuffre alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre does not contest this fact, but believes that it is irrelevant. DEFENDANT’S PURPORTED FACTS . In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies that Mr. Barden, “issued a statement.” Instead it appears to have the contact as Ross Gow and a reference to Devonshire Solicitors. DEFENDANT’S PURPORTED FACTS 4. The statement read in full: Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 2011 London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. It is unacceptable that letters sent by Ms. Maxwell’s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms. Maxwell is now proceeding to take legal action against those newspapers. ‘‘T understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and | ask that they stop,” said Ghislaine Maxwell. “A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said.

Case 18-2868, Document 281, 08/09/2019, 2628234, Page3 of 66 Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-25 1 Email: ross@acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: +44-203-008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com GIUFF! MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS F001067-68 The document speaks for itself although it is unclear if the original included the italics that are inserted by the Defendant above. DEFENDANT’S PURPORTED FACTS 5. Ms. Giuffre’s gratuitous and “lurid” accusations in an unrelated action. In 2008 two alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against the United States government purporting to challenge Epstein’s plea agreement. They alleged the government violated their CVRA rights by entering into the agreement. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS While we would stipulate to the statement in this paragraph starting with the words “In 2008” , we do not stipulate to the opening sentence fragment Maxwell places in bold. DEFENDANT’S PURPORTED FACTS 6. Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action, claiming she, too, had her CVRA rights violated by the government. On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS Agreed. DEFENDANT’S PURPORTED FACTS 7. The issue presented in her joinder motion was narrow: whether she should be permitted to join the CVRA action as a party under Federal Rule of Civil Procedure 21, specifically, whether she was a “known victim[] of Mr. Epstein and the Government owed them CVRA duties.” Yet, “the bulk of the [motion] consists of copious factual details that [Ms. Giuffre] and [her co-movant] ‘would prove . . . if allowed to join.’” Ms.

Case 18-2868, Document 281, 08/09/2019, 2628234, Page4 of 66 Giuffre gratuitously included provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual trafficking. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS Ms. Giuffre denies that the issues presented in here joinder motion were narrow. The issues presented by the joinder motion and related pleadings were multiple and complex, requiring numerous details about Ms. Giuffre’s sexual abuse and the perpetrators of her abuse. In a pleading explaining why the motion was filed, Ms. Giuffre’s lawyers specifically listed nine separate reasons why Jane Doe 3’s allegations that Dershowitz had sexually abused her were relevant to the case and appropriately included in the relevant filings: l. To establish that Jane Doe 3 had been sexually abused by Jeffrey Epstein and his co-conspirators (including co-conspirator Alan Dershowitz), which would make her a “victim” of a broad sex trafficking conspiracy covered by the federal Crime Victims’ Rights Act, 18 U.S.C. § 3771, and therefore entitled to participate in the case; 2. To support then-pending discovery requests that asked specifically for information related to contacts by Dershowitz with the Government on behalf of Jeffrey Epstein; 3. To support the victims’ allegation that the Government had a motive for failing to afford victims with their rights in the criminal process — specifically, pressure from Dershowitz and other members of Epstein’s legal defense team to keep the parameters of the non-prosecution agreement (NPA) secret to prevent Jane Doe 3 and other victims from objecting to and blocking judicial approval of the agreement; 4. To establish the breadth of the NPA’s provision extending immunity to “any potential co-conspirators of Epstein” and the scope of the remedy that the victims (including not only Jane Doe 3 but also other similarly-situated minor victims who had been sexually abused by Dershowitz) might be able to obtain for violations of their rights; 5. To provide part of the factual context for the scope of the “interface” between the victims, the Government, and Epstein’s defense team — an interface that was relevant under Judge Marra’s previous ruling that the Government was entitled to raise “a fact-sensitive equitable defense which must be considered in the factual context of the entire interface between Epstein, the relevant prosecutorial authorities and the federal offense victims .. .”;

Case 18-2868, Document 281, 08/09/2019, 2628234, Page5d of 66 6. To prove the applicability of the “crime/fraud/misconduct” exception to the attorney-client privilege that was being raised by the Government in opposition to the victims’ motion for production of numerous documents; 7. To bolster the victims’ argument that their right “to be treated with fairness,” 18 U.S.C. § 3771(a)(8), had been violated through the Government’s secret negotiations with one of their abusers; 8. To provide notice and lay out the parameters of potential witness testimony for any subsequent proceedings or trial — 1.e., the scope of the testimony that Jane Doe 3 was expected to provide in support of Jane Doe | and Jane Doe 2, the already-recognized Ms. Giuffre in the action; and 9. To support Jane Doe 3’s argument for equitable estoppel to toll the sixyear statute of limitations being raised by the Government in opposition to her motion to join — 1.e., that the statute was tolled while she was in hiding in Australia due to the danger posed by Epstein and his powerful friends, including prominent lawyer Alan Dershowitz. Jane Does #1 and #2 v. United States, No. 9:08-cv-80736, DE 291 at 18-26 & n.17 (S.D. Fla. 2015). Ms. Giuffre’s lawyers had attempted to obtain a stipulation from the Government on point #1 above (“victim” status), but the Government had declined. Judge Marra’s ruling concluded that certain allegations were not necessary “at this juncture in the proceedings.” DE 324 at 5. Judge Marra specifically added, however, that “Jane Doe 3 is free to reassert these factual details through proper evidentiary proof, should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a matter presented for the Court’s consideration.” DE 324 at 6. The CVRA litigation continues and no trial has been held as of the filing of this brief. As such, the extent to which these factual details will be used at trial has not yet been determined. See Docket Sheet, Jane Does #1 and #2 v. U.S., No. 9:08-cv-80736. DEFENDANT’S PURPORTED FACTS 8. At the time they filed the motion, Ms. Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA action. While they deliberately filed the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly.

Case 18-2868, Document 281, 08/09/2019, 2628234, Page6 of 66 MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS a As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several individuals, and she offers details about the type of sex acts performed and where they took place.” The court ruled that “these lurid details are unnecessary”: “The factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent . . ., especially considering that these details involve nonparties who are not related to the respondent Government.” Accordingly, “[t]hese unnecessary details shall be stricken.” Jd. The court then struck all Ms. Giuffre’s factual allegations relating to her alleged sexual activities and her allegations of misconduct by non-parties. The court said the striking of the “lurid details” was a sanction for Ms. Giuffre’s improper inclusion of them in the motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 10. The district court found not only that the “lurid details” were unnecessary but also that the entire joinder motion was “entirely unnecessary.” Ms. Giuffre and her lawyers knew the motion with all its “lurid details” was unnecessary because the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. The court denied Ms. Giuffre’s joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 11. One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion, Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein: =» Ms. Maxwell “approached” Ms. Giuffre in 1999 when Ms. Giuffre was “fifteen years old” to recruit her into the scheme. » Ms. Maxwell was “one of the main women” Epstein used to “procure under-aged girls for sexual activities.” =» Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme.

Case 18-2868, Document 281, 08/09/2019, 2628234, Page? of 66 =» She “persuaded” Ms. Giuffre to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.” =» At the mansion, when Ms. Giuffre began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.” = Epstein “with the assistance of’ Ms. Maxwell “converted [Ms. Giuffre] into...a ‘sex Slave.’” Jd. Ms. Giuffre was a “sex slave” from “about 1999 through 2002.” » Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.” =» Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.” » Ms. Maxwell “participat[ed] in the sexual abuse of | Ms. Giuffre] and others.” =» Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [Ms. Giuffre].” /d. She shared the photos with Epstein. = As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect[ed]” Epstein with “powerful individuals” so that Epstein could traffic Ms. Giuffre to these persons. » Ms. Giuffre was “forced to have sexual relations” with Prince Andrew in » “TMs. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” Ms. Giuffre’s = sex with Prince Andrew “by acting as a ‘madame’ for Epstein.” » Ms. Maxwell “assist[ed] in internationally trafficking” Ms. Giuffre and “numerous other young girls for sexual purposes.” » Ms. Giuffre was “forced” to watch Epstein, Ms. Maxwell and others “engage in illegal sexual acts with dozens of underage girls.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. Ms. Giuffre contests the reference to “lurid details”. Moreover, the testimony from numerous witnesses corroborates the statements Ms. Giuffre made in her joinder motion. See below. e See McCawley Dec. at Exhibit 16, Sjoberg’s May 18, 2016 Dep. Tr. at 8-9, 13, 33-35, 142-143 e See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103 e See McCawley Dec. at Exhibit 14, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52-60 e See McCawley Dec. at Exhibit 12, Lynn Miller’s May 24, 2016 Dep. Tr. at 115 e See McCawley Dec. at Exhibit 13, Joseph Recarey’s June 21, 2016 Dep. Tr. at 29-30

Case 18-2868, Document 281, 08/09/2019, 2628234, Pages of 66 See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36 Exhibit 2 Excerpted Rodgers Dep. Ex. 1 at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589 See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 12:11-15; etc. See McCawley Dec. at Exhibit 8, Kellen Dep. Tr. at 15:13-18; 20:12-16; etc. Epstein Dep. Tr. at 116:10-15; 117:18-118:10; etc. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28, 52-54 See McCawley Dec. at Exhibit 30, U.S. Attorney Victim Notification Letter GIUFFRE002216-002218 See McCawley Dec. at Exhibit 33, July 2001 New York Presbyterian Hospital Records GIUFFRE003258-003290 J See McCawley Dec. at Exhibit 38, Judith Lightfoot psychological records GIUFFRE00543 1-005438 See McCawley Dec. at Exhibit 28, Message Pad evidencing Defendant arranging to have underage girls and young women come to Epstein’s home GIUFFRE001386-001571 See McCawley Dec. at Exhibit 29, Black Book in which Defendant and other household staff maintained a roster of underage girls including Se ae. who were minors at the time the Palm Beach Police’s Investigation of Jeffrey Epstein GIUFFRE001573-00669 See McCawley Dec. at Exhibit 40, Sex Slave books Epstein ordered from Amazon.com at GIUFFRE006581 See McCawley Dec. at Exhibit 32, the folder Defendant sent to Thailand with Ms. Giuffre bearing Defendant’s phone number GIUFFRE003 191-003 192

Case 18-2868, Document 281, 08/09/2019, 2628234, Page9 of 66 e See McCawley Dec. at Exhibit 39, the Palm Beach Police Report showing that Epstein used women and girls to collect underage girls for his abuse GIUFFRE005614-005700 e See McCawley Dec. at Exhibit 41, Epstein’s Flight Logs showing that Defendant flew with Ms. Giuffre 23 times GIUFFRE007055-007161 DEFENDANT’S PURPORTED FACTS 12. In the joinder motion, Ms. Giuffre also alleged she was “forced” to have sex with Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and “many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Response to Point #7 and 11, above. DEFENDANT’S PURPORTED FACTS 13. Ms. Guiuffre said after serving for four years as a “sex slave,” she “managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed that Ms. Giuffre made this statement and has since discovered evidence that indicates she was mistaken on the exact timeframe of her abuse and was with Defendant and Jeffrey Epstein from the years 2000 — 2002. DEFENDANT’S PURPORTED FACTS 14. Ms. Giuffre suggested the government was part of Epstein’s “conspiracy” when it “secretly” negotiated a non-prosecution agreement with Epstein precluding federal prosecution of Epstein and his “co-conspirators.” The government’s secrecy, Ms. Giuffre alleged, was motivated by its fear that Ms. Giuffre would raise “powerful objections” to the agreement that would have “shed tremendous public light on Epstein and other powerful individuals. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre did not suggest that the Government was part of Epstein's conspiracy to commit sex offenses. The CVRA case deals with whether the Government failed in their responsibilities to the victims to inform the victims that the Government was working out a NPA,

Case 18-2868, Document 281, 08/09/2019, 2628234, Page10 of 66 and it is Ms. Giuffre's belief that the Government did fail to so inform the victims, and intentionally did not inform the victims because the expected serious objection from many of the victims might prevent the Government from finalizing a NPA with Epstein. See McCawley Dec. at Exhibit 50, Joinder Motion (GIUFFRE00319-00333). DEFENDANT’S PURPORTED FACTS 15. Notably, the other “Jane Doe” who joined Ms. Giuffre’s motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of Ms. Giuffre’s allegations. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS This is untrue. The other Jane Doe could corroborate many of Ms. Giuffre's allegations based on a similar pattern of abuse that she suffered by Epstein. She did not know Ms. Giuffre though. ae. who was deposed in this case, and who was a minor, corroborates the same pattern of abuse. See McCawley Dec. at Exhibit 7, a Dep. Tr. at 54:25-57:5. DEFENDANT’S PURPORTED FACTS 16. — Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, Ms. Giuffre told Ms. Churcher of virtually none of the details she described in the joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This 1s untrue. Furthermore, Defendant does not offer any citation or evidence on this point. Defendant's statement here is knowingly false. Having read the articles and taken Ms. Giuffre's deposition, Defendant knows that Ms. Giuffre did reveal details in 2011 consistent with those in the joinder motion. See McCawley Dec. at Exhibit 31, GIUFFRE003678, FBI Redacted 302, GIUFFRE001235-1246. DEFENDANT’S PURPORTED FACTS Li Ms. Maxwell’s response to Ms. Giuffre’s “lurid” accusations: the January 2015 statement. As Ms. Giuffre and her lawyers expected, before District Judge Marra in the 10

Case 18-2868, Document 281, 08/09/2019, 2628234, Page11 of 66 CVRA action could strike the “lurid details” of Ms. Giuffre’s allegations in the joinder motion, members of the media obtained copies of the motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 18. At Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing “a quotable statement on behalf of Ms. Maxwell.” The email was sent to more than 6 and probably less than 30 media representatives. It was not sent to non-media representatives. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS Defendant falsely claims that “[a]t Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing ‘a quotable statement on behalf of Ms. Maxwell.’” This is a blatant falsehood about the document that is at the heart of this litigation. Record evidence shows that Gow sent that email at Defendant’s direction, not at Mr. Barden’s direction. Indeed, on the evening before his deposition, Mr. Gow produced an email exchange he had with Defendant in which Defendant directs Mr. Gow to send the press statement. It is as follows: From: G Maxwell <GMax1@elimax.com> Date: Fri, 2 Jan 2015 20:14:53 +0000 To: Ross Gow<ross@acuityreputation.com> Cc: Philip Barden<philip.barden@devonshires.co.uk> Subject: FW: URGENT - this is the statement Jane Doe 3 is Virginia Roberts so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschwitz is involved in having sexual relations with her, which he denies Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. 11

Case 18-2868, Document 281, 08/09/2019, 2628234, Page12 of 66 Chronologically, this email comes at the end of various other email exchanges between Defendant and Gow that discuss issuing a press release. The subject line of this email that Defendant wrote to Gow states “URGENT -— this is the statement,” thereby instructing Gow to release this statement to the press. Shortly after Defendant sent this email to Gow directing him to release the statement, Gow distributed the statement to multiple media outlets. Neither Defendant nor Gow have produced any email in which Barden directed Gow to issue this press release (nor can they). Despite sending it herself, and despite it being responsive to six court-ordered search terms, Defendant failed to produce this email. Her press agent, Gow, produced this the evening before his deposition on November 17, 2016. At the deposition, Mr. Gow authenticated this email and confirmed that Defendant authorized the statement: Q. When you sent that email were you acting pursuant to Ms. Maxwell's retention of your services? A. Yes, I was. *K 3K ok (Exhibit 9 was marked for identification. ) Q. This also appears to be an email chain with you and Ms. Maxwell; is that correct? A. It does appear to be so. Q. Did you send the top email of the chain that says "Okay, G, going with this"? A. I did. Q. And did you receive from Ms. Maxwell, the bottom email of that chain? A. I believe so. Well, I believe -- yes, yeah, it was forwarded from Ms. Maxwell, yes. MR. DYER: Sorry, I don't quite understand that answer. THE WITNESS: I misspoke that. I did receive it from Ms. Maxwell. MR. DYER: Okay. Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know where the rest of this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point 1n time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine, Ill go with this.” It is my understanding that this is the agreed statement because the subject of the second one is “Urgent, this is the statement” so I take that as an instruction to send it out, as a positive command: “This is the statement.” 12

Case 18-2868, Document 281, 08/09/2019, 2628234, Page13 of 66 See McCawley Decl. at Exhibit 6, November 18, 2016, Ross Gow Dep. Tr. at 14:15-17; 44:645:13. Together, the email and Gow’s testimony unequivocally establish that Defendant — not Barden — directed and “command]ed]’”’ Gow to publish the defamatory statement. Accordingly, the first sentence of Defendant’s Paragraph 18 is false. The second sentence — “This email was sent to more than 6 and probably less than 30 media representatives” — omits the fact that not only did Gow admit to emailing the statement to the press, but he also read it to over 30 media representatives over the phone: Q. Do you recall ever reading the statement to the press or the media over the phone’? A. It's very possible that I would have done so, yes. See McCawley Decl. at Exhibit 6, Gow Dep. Tr. at 66:2-25. Q. Do you -- do you remember discussing that with The Guardian? A. No, I don't. I'm not saying I didn't but I can't recall. You have to bear in mind, if you'd be so kind, that I've been speaking to over 30 journalists and media outlets about this, and I can't recall every single -- the detail of every single conversation. See McCawley Decl. at Exhibit 6, Gow Dep. Tr. at 64:8-14 (emphasis added). Thus, the second sentence of Defendant’s Paragraph 18 is also false. DEFENDANT’S PURPORTED FACTS 19. Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. These representatives were selected based on their request—after the joinder motion was filed—for a response from Ms. Maxwell to Ms. Giuffre’s allegations in the motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre agrees to the first sentence. The second sentence is a false. Accordingly, there is no record evidence that Gow (or anyone else) “selected” journalists “for a response,” or that there was any selection process whatsoever. To the contrary, Gow testified that anyone who inquired received a reference to the January 2015 defamatory response: 13

Case 18-2868, Document 281, 08/09/2019, 2628234, Page14 of 66 Q. To the extent you can recall or could estimate, how many other emails do you believe you sent bearing that statement that's in Exhibit 2? A. I really can't remember but certainly more than six and probably less than 30, somewhere in between. Any time there was an incoming query it was either dealt with on the telephone by referring them back to the two statements of March 2011 and January 2015 or someone would email them the statement. So no one was left unanswered, broadly, is the -- is where we were. But I can't remember every single person we reached out to. See McCawley Dec at Exhibit 6 Gow Dep. Tr. at 67:15-68:1 (emphasis added). DEFENDANT’S PURPORTED FACTS 20. The email to the media members read: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms. Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 1s Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] 1t changes with new salacious details about public figures and world leaders and now it 1s alleged by Ms. Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms. Roberts claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT'S FACTS 14

Case 18-2868, Document 281, 08/09/2019, 2628234, Page15 of 66 While Defendant cropped the body text of the email that was sent to news media representatives, she completely omitted the headings and metadata. Ms. Giuffre has put an image of the email below in Ms. Giuffre’s Paragraph. See GM_00068. From: <rass@acuityreputation,com> Date: 2 January 2015 at 20:38 Subject: Ghislaine Maxwell To: Rossacuity Gow <ro i tion.com> boc: martin.robinson@mailonii P._Peachey@independent.co_uk, nick.sommerlad@ mirror.co.uk, david brown @thetimes.co.uk, nick.alway@ bbc.co.uk, jo-anne, pugh@ bbc.co.uk To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 «Vigil Roberts - so not a new individual, The allegations made by Victoyla Roberts against Ghislaine Maxwell are untrue. The original allegations are not newWand have been fully responded to and shown to be untrue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschowitz is involved in having sexual relations with her, which he denies, Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. Sent from my BlackBerry® wireless device DEFENDANT’S PURPORTED FACTS 15

Case 18-2868, Document 281, 08/09/2019, 2628234, Page16 of 66 21. Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional press release solely to disseminate information to the media. So he intentionally did not pass it through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Defendant states: “Mr. Barden, who prepared the statement, did not intend it as a traditional press release solely to dissemination information to the media.” Ms. Giuffre contests this statement, and all statements regarding Mr. Barden’s beliefs and purposes, and the like. Further, as stated in detail in Ms. Giuffre’s Opposition Defendant’s Motion for Summary Judgment, this Court should not even consider the Barden Declaration. Additionally, there is absolutely no record evidence of Barden’s intent and the Court should not consider it. The next sentence states, “So he intentionally did not pass it [the press release] through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation.” Again, there 1s zero record evidence to support any assertion of Barden’s intent. To the extent that this sentence claims that Barden did not give the statement to Gow, Ms. Giuffre does not dispute it; as described above, Defendant gave the statement to Gow with instructions to publish it. See McCawley Dec. at Exhibit 48, RG(UK) 000009, imaged in full at paragraph 81, supra. To the extent that this sentence claims that the statement did not pass “through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation,” Ms. Giuffre disputes that statement. Record documentary evidence and testimony establish that this statement was disseminated through a public relations firm, namely, Ross Gow’s firm, Acuity Reputation. See McCawley Dec. at Exhibit 6, Gow Dep. Tr. at 109:4-6 (“Q. Approximately how long have you been providing such services? A. Acuity was set up in 2010.”). DEFENDANT’S PURPORTED FACTS 16

Case 18-2868, Document 281, 08/09/2019, 2628234, Page17 of 66 22, The January 2015 statement served two purposes. First, Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of Ms. Giuffre’s false allegations. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject Ms. Giuffre’s allegations to inquiry and scrutiny. For example, he noted in the statement that Ms. Giuffre’s allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicized as news.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre objects to this paragraph 1n its entirety. She disputes that the January 2015 statement “served two purposes,” as this statement is wholly unsupported by the record, which Defendant again neglects to cite. Ms. Giuffre also contests the second sentence in which Defendant claims that “Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of Ms. Giuffre’s false allegations.” First, Ms. Giuffre disputes any statement of Barden’s intent as explained above. Second, Ms. Giuffre disputes that there was any “republication” by the press as a matter of law, as explained in her memorandum of law opposing summary judgment, as the press did not “republish” the press statement under New York law. Third, Ms. Giuffre disputes that her allegations are “false,” and cites to the following non-exhaustive sampling of evidence to corroborate her allegations against Defendant: e See McCawley Dec. at Exhibit 16, Syjoberg’s May 18, 2016 Dep. Tr. at 8-9, 13, 33-35, 142-143 e See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103 e See McCawley Dec. at Exhibit 14, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52-60 e See McCawley Dec. at Exhibit 12, Lynn Miller’s May 24, 2016 Dep. Tr. at 115 e See McCawley Dec. at Exhibit 13, Joseph Recarey’s June 21, 2016 Dep. Tr. at 29-30 e See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36 17

Case 18-2868, Document 281, 08/09/2019, 2628234, Page18 of 66 Exhibit 2 Excerpted Rodgers Dep. Ex. 1 at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589 See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 12:11-15; etc. See McCawley Dec. at Exhibit 8, Kellen Dep. Tr. at 15:13-18; 20:12-16; etc. Epstein Dep. Tr. at 116:10-15; 117:18-118:10; etc. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28, 52-54 See McCawley Dec. at Exhibit 42, Photographs including GIUFFRE007162-007182. See McCawley Dec. at Exhibit 30, U.S. Attorney Victim Notification Letter GIUFFRE002216-002218 See McCawley Dec. at Exhibit 33, July 2001 New York Presbyterian Hospital Records GIUFFRE003258-003290 See McCawley Dec. at Exhibit 38, Judith Lightfoot psychological records GIUFFRE00543 1-005438 See McCawley Dec. at Exhibit 28, Message Pad evidencing Defendant arranging to have underage girls and young women come to Epstein’s home GIUFFRE001386-001571 See McCawley Dec. at Exhibit 29, Black Book in which Defendant and other household staff maintained a roster of underage girls including a. who were minors at the time the Palm Beach Police’s Investigation of Jeffrey Epstein GIUFFRE001573-00669 See McCawley Dec. at Exhibit 40, Sex Slave books Epstein ordered from Amazon.com at GIUFFRE006581 See McCawley Dec. at Exhibit 32, the folder Defendant sent to Thailand with Ms. Giuffre bearing Defendant’s phone number GIUFFRE003 191-003 192 18

Case 18-2868, Document 281, 08/09/2019, 2628234, Page19 of 66 e See McCawley Dec. at Exhibit 39, the Palm Beach Police Report showing that Epstein used women and girls to collect underage girls for his abuse GIUFFRE005614-005700 e See McCawley Dec. at Exhibit 41, Epstein’s Flight Logs showing that Defendant flew with Ms. Giuffre 23 times GIUFFRE007055-007161 Next, Defendant states, ““He [Barden] believed these ends could be accomplished by suggesting to the media that, among other things, they should subject Ms. Giuffre’s allegations to inquiry and scrutiny.” Ms. Giuffre disputes any statement as to Barden’s “belief” (supra). Ms. Giuffre disputes that the harm to Defendant’s reputation could be mitigated by the media’s inquiry into and scrutiny of Ms. Giuffre’s allegations, because a deeper inquiry would only reveal additional evidence corroborating Ms. Giuffre’s allegations, such as the evidence put forth in Ms. Giuffre’s opposition memorandum of law and detailed in the bulleted citations, supra. Defendant then states, “For example, he [Barden] noted 1n the statement that Ms. Giuffre’s allegations changed dramatically over time, suggesting that they are ‘obvious lies’ and therefore should not be ‘publicized as news.’” First, Ms. Giuffre disputes that Barden noted anything in the statement, as that is unsubstantiated by the record evidence. Not to do Defendant’s work for her, but the closest evidence Defendant has for such a statement 1s testimony from the Gow deposition wherein Gow speculates that Barden “had a hand in” drafting the press statement, an opinion which may or may not be based on first-hand knowledge. See McCawley Dec. at Exhibit 6, Gow Dep. Tr. at 45:14-17 (Q. Okay. A. And I say, “Thanks, Philip” because I’m aware of the fact that he had a hand, a considerable hand in the drafting.”’) This is wholly insufficient to show who drafted the passages quoted by Defendant above. Regardless of those passages’ original author, it is ultimately Defendant who “noted” anything because it is her statement and she directed that it be sent to the media and public. 19

Case 18-2868, Document 281, 08/09/2019, 2628234, Page20 of 66 Second, Ms. Giuffre disputes that her allegations have changed over time, “dramatically” or otherwise. Third, Ms. Giuffre disputes that the press release “suggest[ed]” that her allegations are “obvious lies,” because Defendant’s press release affirmatively, unambiguously stated that her allegations are “obvious lies” — there is no subtlety, suggestion, or statement of opinion here. See Giuffre v. Maxwell, 165 F. Supp.3d 147, 152 (S.D.N.Y. 2016) (“. . . these statements (as they themselves allege), are capable of being proven true or false, and therefore constitute actionable fact and not opinion.” DEFENDANT’S PURPORTED FACTS 2S Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish Ms. Giuffre’s allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that Ms. Giuffre’s allegations were “defamatory.” In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of Ms. Giuffre’s obviously false allegations and the legal indefensibility of their own conduct. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This paragraph is another purported statement of Defendant’s counsel’s “intent.” Defendant states: “Second, Mr. Barden intended the January 2015 statement to be a ‘shot across the bow’ of the media, which he believed had been unduly eager to publish Ms. Giuffre’s’ allegations without conducting any inquiry of their own.” Not only does Defendant once again refer to Mr. Barden’s intent, but she also mischaracterizes the statement as a “‘shot across the bow” of the media. The press release did not threaten or give warning to the media in any way whatsoever. See McCawley Dec. at Exhibit 26, GM_ 00068, full image copied in Ms. Giuffre’s Paragraph 18, supra. Next, Ms. Giuffre disputes the sentence, “Accordingly, in the statement he repeatedly noted that Ms. Giuffre’s allegations were ‘defamatory.’” Barden did not “note” anything in the statement, nor does Defendant cite to any record evidence that he does. Furthermore, Ms. Giuffre 20

Case 18-2868, Document 281, 08/09/2019, 2628234, Page21 of 66 denies that any of her allegations are defamatory 1n the slightest, as they are all true and substantiated by record evidence (supra). Ms. Giuffre also disputes the sentence, “In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of Ms. Giuffre’s obviously false allegations and the legal indefensibility of their own conduct.” First, Ms. Giuffre objects to any statement of Barden’s intent, as articulated above. Second, Defendant’s conventional press release was in no way any type of “cease and desist letter.” There 1s no record evidence in support of this claim, and Defendant unsurprisingly cites to none. Third, Ms. Giuffre disputes that any media-recipients would be given to understand “the seriousness with which Ms. Maxwell considered the publication of Ms. Giuffre’s obviously false allegations and the legal indefensibility of their own conduct” by Defendant’s self-serving press release, as that is unsupported by the record. Finally, Ms. Giuffre rejects that her allegations are "obviously false,” a claim which is completely unsupported by record evidence. DEFENDANT’S PURPORTED FACTS 24. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms. Maxwell” (emphasis supplied). The statement was intended to be a single, one-timeonly, comprehensive response—quoted in full—to Ms. Giuffre’s December 30, 2014, allegations that would give the media Ms. Maxwell’s response. The purpose of the prefatory statement was to inform the media-recipients of this intent. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT'S FACTS 21

Case 18-2868, Document 281, 08/09/2019, 2628234, Page22 of 66 Ms. Giuffre disputes that any part of Defendant’s press release is “consistent with those two [of Barden’s] purposes.” Indeed, Ms. Giuffre disputes this and any statement relating to Barden’s “purposes,” as explained above. Next, Ms. Giuffre disputes that, “The statement was intended to be a single, one-timeonly, comprehensive response — quoted in full — to Ms. Giuffre’s December 30, 2014, allegations that would give the media Ms. Maxwell’s response.” First, Ms. Giuffre disputes this and any statement relating to Barden’s “intent” as explained above. Second, Ms. Giuffre disputes that anyone intended the press release to be a one-time-only, comprehensive response. The record evidence says otherwise: Gow repeatedly issued this statement via email and over the phone for months on end. Next, Defendant states, ““The purpose of the prefatory statement was to inform the mediarecipients of this intent.” First, Ms. Giuffre disputes this and any statement relating to Barden’s purpose as explained above. Second, Ms. Giuffre disputes that the press release was to inform the media of anything. Defendant issued a press release, instructed them to publish it (by telling them it was “quotable’”’), see McCawley Dec. at Exhibit 48, RG(UK)_ 000009 (supra), and hired a press agent to feed it to the press: Q. Did Ms. Maxwell retain the services of you or your firm? A. Yes, she did. ok 2K OK Q. Is it your belief that that agreement was in effect on January 2nd, 2015? A. Yes. Q. Do you recall the terms of that agreement? A. Well, it was a re-establishment of an existing agreement so if we go back to the original agreement, it was to provide public relations services to Ms. Maxwell in the matter of Giuffre and her activities. 22

Case 18-2868, Document 281, 08/09/2019, 2628234, Page23 of 66 See McCawley Dec. at Exhibit 6 Gow Dep. Tr. at 12:19-21; 13:9-16. The record evidence shows that Defendant’s intent was for the press to publish her press release: any other interpretation is not only contrary to logic, but unsupported by the record. DEFENDANT’S PURPORTED FACTS 2: Ms. Giuffre’s activities to bring light to the rights of victims of sexual abuse. Ms. Giuffre has engaged in numerous activities to bring attention to herself, to the prosecution and punishment of wealthy individuals such as Epstein, and to her claimed interest of bringing light to the rights of victims of sexual abuse. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed to the portion of Defendant’s assertion in bold font. Ms. Giuffre has not engaged in activities to bring attention to herself, rather she has taken action to aid in the prosecution of her abusers, and she seeks to bring light to the rights of victims of sexual abuse. DEFENDANT’S PURPORTED FACTS 26. Ms. Giuffre created an organization, Victims Refuse Silence, Inc., a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre created Victims Refuse Silence, Inc., 1n order to help other sexually trafficked victims find the resources they need to recover and heal. See www.victimsrefusesilence.org. DEFENDANT’S PURPORTED FACTS 27, The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse.” Toward this end, Ms. Giuffre has “dedicated her professional life to helping victims of sex trafficking.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT'S FACTS Agreed. 23

Case 18-2868, Document 281, 08/09/2019, 2628234, Page24 of 66 DEFENDANT’S PURPORTED FACTS 28. Ms. Giuffre repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT'S FACTS Denied. Ms. Giuffre was approached by numerous media outlets and refused to speak to most of them. Media organizations sought her out; she did not seek them out. See McCawley Dec. at Exhibit 35, GIUFFRE003690, email from Sharon Churcher seeking to interview Ms. Giuffre. DEFENDANT’S PURPORTED FACTS 29. On December 30, 2014, Ms. Giuffre publicly filed an “entirely unnecessary” joinder motion laden with “unnecessary,” “lurid details” about being “sexually abused” as a “minor victim|[]’’ by wealthy and famous men and being “trafficked” all around the world as a “sex slave.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Paragraph 7, supra, listing multiple reasons why details were, 1n fact, necessary. DEFENDANT’S PURPORTED FACTS 30. The Ms. Giuffre’s alleged purpose in filing the joinder motion was to “vindicate” her rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution agreement” with Epstein, “shed tremendous public light” on Epstein and “other powerful individuals” that would undermine the agreement, and support the CVRA Ms. Giuffre’s’ request for documents that would show how Epstein “used his powerful political and social connections to secure a favorable plea deal” and the government’s “motive” to aid Epstein and his “co-conspirators.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS See Ms. Giuffre’s Paragraph 7, supra, listing multiple purposes of Ms. Giuffre’s lawyers’ filing of the motion. 24

Case 18-2868, Document 281, 08/09/2019, 2628234, Page25 of 66 DEFENDANT’S PURPORTED FACTS 31. Ms. Gtuffre has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s alleged “sex scheme.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS See Ms. Gtuffre’s Paragraph 52, infra, explaining that the context of this statement is misleading. DEFENDANT’S PURPORTED FACTS 32. Republication alleged by Ms. Giuffre. Ms. Giuftre was required by Interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were “‘published globally, including within the Southern District of New York,’” as Ms. Gtuftfre alleged in Paragraph 9 of Count I of her complaint. In response, Ms. Giuffre identified the January 2015 statement and nine instances in which various news media published portions of the January 2015 statement in news articles or broadcast stories. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre objects to this paragraph in its entirety, starting with the bolded heading (“Republication alleged by Ms. Giuffre’’). There is no “republication” as a matter of law in this case, as explained in Ms. Giuffre’s memorandum of law. Accordingly, Ms. Giuffre is not and has not alleged republication. As noted in her objection that, it is Defendant who possesses the knowledge as to where the defamatory statements were published; unsurprisingly, Defendant failed to comply with Ms. Giuffre’s discovery requests on the same. As Defendant already knows, Ms. Giuffre provided a sampling of Defendant’s defamatory statements published by the news media, as “identification of an exhaustive responsive list would be unduly burdensome.” This, of course, 1s because Defendant caused her statement to be published in an enormous number of media outlets. Ms. Giuffre’s full response to Interrogatory No. 6 is below. As the Court can see, these nine instances were a good-faith effort to provide some samples (as it would be virtually impossible to provide all of them), below. Ms. 25

Case 18-2868, Document 281, 08/09/2019, 2628234, Page26 of 66 Giuffre has also put forth an exhaustive expert report and expert testimony from Jim Jansen regarding the dissemination of Defendant’s defamatory press release. Ms. Giuffre objects because the information interrogatory above is in the possession of Defendant who has failed to comply with her production obligations in this matter, and has failed to comply with her production obligations with this very subject matter. See Document Request No. 17 from Ms. Giuffre’s Second Request for Production of Documents to Defendant Ghislaine Maxwell. Maxwell has not produced all “URL or Internet addresses for any internet version of such publication” that she directed her agent, Ross Gow, to send. Ms. Giuffre further objects because the information requested above 1s in the possession of Defendant’s agent, who caused the false statements to be issued to various media outlets. Ms. Giuffre has not had the opportunity to depose Maxwell’s agent Ross Gow; therefore, this answer remains incomplete. Consequently, Ms. Giuffre reserves the right to modify and/or supplement her responses, as information is largely in the possession of the Defendant and her agent. Ms. Giuffre objects to this interrogatory in that it violates Rule 33 as its subparts, in combination with the other interrogatories, exceed the allowable twenty-five interrogatories. Ms. Giuffre objects to this request because it is in the public domain. Ms. Giuffre also objects in that 1t seeks information protected by the attorney-client/work product privilege, and any other applicable privilege stated in the General Objections. Notwithstanding such objections, Ms. Giuffre has already produced documents supplements such responsive documents with the following list of publications. While the identification of an exhaustive responsive list would be unduly burdensome, in an effort to make a good faith effort towards compliance, Ms. Giuffre provides the following examples, which are incomplete based on the aforementioned reasons: 26

Case 18-2868, Document 281, 08/09/2019, 2628234, Page27 of 66 January 2, 2015 January 3, 2015 January 3, 2015 January 3, 2015 January 4, 2015 January 4, 2015 January 5, 2015 January 5, 2015 Bolton News Telegraph Huffington Post 24 Jane Doe 3 1s Virginia Roberts - so not anew individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story 1s re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms. Roberts that Alan Dershowitz is involved in having sexual relations with her, which he denies. Ms. Roberts's claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old -/werw. theboltonnews.co.uk/news’'national’11/00192 Palace denies Andrew sex case claim’ tos! www _ butfinetonpost.co.uk/?015/01/03/duke-ofywork-sex-abuse-claims n 6409508 html ~//yoww_express.co_uk) news! world’530085,/GhislaineMaxwell-Jeffreyv-Epstein-not-madam-paedophile-F loridacourt-case-Prince-Andrew www nyvdalyvnews.com news'world’‘allegedmadame-accused-supplying-prince-andrew-article

Case 18-2868, Document 281, 08/09/2019, 2628234, Page28 of 66 DEFENDANT’S PURPORTED FACTS 33. In none of the nine instances was there any publication of the entire January 2015 statement. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS While there may be certain publications who did not print every word of Defendant’s lengthy press release, most publications quoted the most salient, to-the-point parts of Defendant’s statement that call Ms. Giuffre a liar. In each of the nine articles listed above, the defamatory statement, as articulated by the Complaint and as identified by the Court as actionable, is published. See Giuffre v. Maxwell, 165 F. Supp.3d 147, 152 (S.D.N.Y. 2016) (“statements that Giuffre’s claims ‘against [Defendant] are untrue,’ have been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning: that Giuffre is not telling the truth about her history of sexual abuse and Defendant’s role, and that some verifiable investigation has occurred and come to a definitive conclusion proving that fact. Second, these statements (as they themselves allege), are capable of being proven true or false, and therefore constitute actionable fact and not opinion’). Ms. Giuffre also put forth extensive evidence of the mass distribution of Defendant’s defamatory statement to over 66 million viewers through her expert witness Jim Jansen. See McCawley Dec. at Exhibit 24, Expert Report of Jim Jansen. DEFENDANT’S PURPORTED FACTS 34. Ms. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in Ms. Giuffre’s response to Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015 statement. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre disputes this statement in its entirety, as it is completely devoid of record evidence. In fact, the record establishes the contrary. First, Defendant hired Gow because his 28

Case 18-2868, Document 281, 08/09/2019, 2628234, Page29 of 66 position allowed him to influence the press to publish her defamatory statement. A sampling of Gow’s testimony establishes just that: ublic >OPOPZOD Oe Did Ms. Maxwell retain the services of you or your firm? Yes, she did. Is it your belief that that agreement was in effect on January 2nd, 2015” Yes. Do you recall the terms of that agreement? Well, it was a re-establishment of an existing agreement so if we go back to the original agreement, it was to provide public relations services to Ms. Maxwell in the matter of Giuffre and her activities. You can answer -- to the extent that anything you testify to is not protected by a privilege. Ms. Roberts first came to my attention on or around March 2011 when I was into a meeting with Philip Barden and Ms. Maxwell at Devonshires law office, she had made -- Ms. Giuffre had made extremely unpleasant allegations about Maxwell's private life. We were -- Acuity Reputation, my firm was called in to protect Ms. Maxwell's reputation, and to set the record straight. That was -- and work commenced on or around March of 2011. Does this document fairly depict pages from your -- from Acuity Reputation's website? It does. Do you see where it says "We manage reputation and forge opinion through relations, strategic communications and high level networking"? I do. Is that a true statement? Say it again. Sorry. Is that a true statement? It is, yes. I wrote that statement. Okay. Do you see where your website claims that your company has "excellent relationships with the media"? I do. Is that a true statement? 29

Case 18-2868, Document 281, 08/09/2019, 2628234, Page30 of 66 A. That is true, yeah. Q. Is it correct that you advertise your “excellent relationships with the media" because your services often include giving communications to the media on behalf of your clients? A. Yes. See McCawley Dec. at Exhibit 6 Gow Dep. Tr. at 13:9-16; 15:18-16:3; 109:12-22; 110:16-21; 111:3-7. In addition to testimonial evidence, the proof 1s also in the result. By using Gow to issue her press release, Defendant caused her statement to be published by numerous major news organizations with wide readership all over the globe. Accordingly, the record evidence shows that Ms. Maxwell, through her agent, had immense control and authority over the media, convincing major news outlets to publish her words based on nothing more than a single email from Gow. DEFENDANT’S PURPORTED FACTS 35. Ms. Giuffre’s defamation action against Ms. Maxwell. Eight years after Epstein’s guilty plea, Ms. Giuffre brought this action, repeating many of the allegations she made in her CVRA joinder motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Agreed, but noting that the defamation cause of action against Defendant did not accrue until Defendant defamed her in January of 2015, the same year Ms. Giuffre filed suit against Defendant for defamation. DEFENDANT’S PURPORTED FACTS 36. The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (b) That the allegations have been “shown to be untrue.” (c) That Giuffre’s “claims are obvious lies.” 30

Case 18-2868, Document 281, 08/09/2019, 2628234, Page31 of 66 MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS Agreed. However, in discovery, Defendant was finally forced to produce the complete press release she issued. See McCawley Dec. at Exhibit 26, GIUFFRE00068. DEFENDANT’S PURPORTED FACTS 37. Ms. Giuffre lived independently from her parents with her fiancé long before meeting Epstein or Ms. Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999, Ms. Giuffre moved in with the family of a fellow patient. There she met, and became engaged to, her friend’s brother, James Michael Austrich. She and Austrich thereafter rented an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs in that area. Later, they stayed briefly with Ms. Giuffre’s parents in the Palm Beach/ Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. Although Ms. Giuffre agreed to marry Austrich, she never had any intention of doing so. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre did not voluntarily live independently from her parents with her fiancé, rather Ms. Giuffre was a troubled minor child who was not truly engaged prior to meeting Defendant and Epstein. Where Ms. Giuffre lived, and who she lived with, are not relevant to the issues being decided in this action. Again, this is merely a transparent distraction from the case that is actually at issue, and is being used for the sole purpose of inserting conjecture in an effort to distract the Court and ultimately the jury. Although Austrich testified that he proposed to Ms. Giuffre on Valentine’s Day, see Austrich at p. 19, Ms. Giuffre was a troubled teen who could not realistically be considered a fiancé in the true sense of the word, nor was she of legal age to marry. In fact, as accurately described by Defendant, Ms. Giuffre never had any intention of marrying Austrich. Giuffre Dep. Tr. at 127:22-128:21. Given that Ms. Giuffre was a child with limited legal capacity at this point, and that she did not have any intention of marrying Austrich, a reasonable person could not assert that Ms. Giuffre was engaged. 31

Case 18-2868, Document 281, 08/09/2019, 2628234, Page32 of 66 DEFENDANT’S PURPORTED FACTS 38. Ms. Giuffre re-enrolled in high school from June 21, 2000 until March 7, 2002. After finishing the 9th grade school year at Forest Hills High School on June 9, 1999, Ms. Giuffre re-enrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on August 14, 2001. On September 20, 2001, Ms. Giuffre then enrolled at Royal Palm Beach High School. A few weeks later, on October 12, 2001, she matriculated at Survivors Charter School. Id. Survivor’s Charter School was an alternative school designed to assist students who had been unsuccessful at more traditional schools. Ms. Giuffre remained enrolled at Survivor’s Charter School until March 7, 2002. She was present 56 days and absent 13 days during her time there. Id. Ms. Giuffre never received her high school diploma or GED. Ms. Giuffre and Figueroa went “back to school” together at Survivor’s Charter School. The school day there lasted from morning until early afternoon. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies this statement. Either Defendant is blatantly misleading this Court or Defendant simply does not understand how to interpret Ms. Giuffre’s school records. The record produced by Defendant (GM0888) 1s specifically titled “A0O7. Assignment History,” which reflects semester start and end dates per each 180 day school year, not dates that Ms. Giuffre physically enrolled or withdrew from school. See McCawley Dec. at Exhibit 27, GM0888. PANEL: A07. ASSIGNMENT HISTORY YEAR: 16 T7234 Monday May 23, 2016 9:04 am STDT: 12870606 ROBERTS, VIRGINIA L SCHL: 3390 GR: 10 ST: I A ENTRY WITHDRAWAL P BF CCD DATE OD CD DATE R PF SY CL DS SCHL DESC GR PRS ABS UNX Y RO2 101201 . W26 030702 N _ 02 01 __ 3390 SURVIVORS 10 56°31 =a ~ RO2 092001 WO2 101101 N 02 01 — 2331 ROYAL PALM HIG 10 13 1 _ ~ BAL 081401 | W32 092001 2 02 Al 2192 WLLNGTN HS ADL 30 | ~ BAl 081600 W47 081301 Z 01 Al _ 2192 WLLNGTN HS ADL 30 i CY EA1 062100 | W47 081500 2 00 Al (2192 WLLNGTN HS ADL 30 (CY ~ B01 081699 WO3 081699 N. 00 01 2331 ROYAL PALM HIG 10 | ~ BOl 081998 WO2 060999 P 99 01 0581 FOREST HILL HI 09 155 25 Y ~ £01 082097 wW0l 061098 R_ 98 01 2331 ROYAL PALM HIG 09 147 33 Y¥ ~ E01 082097 W22 082097 N98 01 2191 WELLINGTON HIG 09 ~ RO3 040797 WO2 061197 P _--«-97: 01 __ 1691 CRESTWOOD MID 08 40 5 ¥ ~ BOl 082294 | DNE 082294 N95 01 _ 1703 ROYAL PINES SC 06 ~ BOl 082393 WO2 061094 P 94 01 1901 LOXAHATCHEE EL 05 167 13 ¥ ~ B01 082592 wWO1l 061193 P 9301 1901 LOXAHATCHEE EL 04 176 4 Y 32

Case 18-2868, Document 281, 08/09/2019, 2628234, Page33 of 66 While “Grade 30” indicates adult education, Ms. Giuffre’s attendance records indicate that she was not present in school between 6/21/00-09/20/01 (see withdrawal codes W32 and W47). WITHDRAWAL CODES: ADULT STUDENTS e W726 - Any student who withdraws from school to enter the adult education program prior to completion of graduation requirements. e W532 - Any adult student who left the class/program to enter another training program. e W47 - Any adult student who is procedurally withdrawn at the end of the term or school year who will continue in the class/program the next term or school year. ://www.fldoe.org/core/fileparse.php/886 1/urlt/0094063-appendb.pdf More importantly, Ms. Giuffre’s school transcripts clearly indicate “NO COURSES TAKEN?” for the 1999-2000 and 2000-2001 school years. (See McCawley Dec. at Exhibit 27, GM_00893.) Ms. Gtuffre’s attempt to work and resume school at Survivor’s Charter School as a 10" grader in the 2001-2002 school year was limited to a portion of the school year (10/20/0103/07/02), and further substantiates Ms. Giuffre’s testimony that she attempted to get away from Epstein’s abuse, along with the following testimony by Figueroa: Q: Was there a period of time between 2001 and when she left in 2002 here she was not working for Jeffrey? Yes. What period of time was that? It was pretty much, like, when she was actually working as a server. Like, basically because we were trying to not have her go back there. Like, she did not want to go back there. And we were trying to just work without needing his money, you know.” > OD & See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 92-93 Q: So the thing that Virginia was tired of ... What was it that Virginia was trying to get away from and stop with respect to working at Jeffrey Epstein's house? A: To stop being used and abused. See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 248 33

Case 18-2868, Document 281, 08/09/2019, 2628234, Page34 of 66 Even still, if the records are correct, which Ms. Giuffre does not concede, the records indicate that Ms. Giuffre’s attendance was poor, with 69 days present and 32 days absent out ofa required 180 day school year and that she was not enrolled at the end of the school year (emphasis added). DISTRICT: 50 SCHOOL: 3390 NO COURSES TAKEN YEAR: 1999-Z000 GRADE LEVEL: WA GPA OTY PTS GPA OTY PIs DISTRICT-TERM: 1.42686 58.006 CUM: 1.5429 27.00 STATH-'TERM: 1.4266 5.00 COM: 1.5429 27.00 1999-2000 ANNGAL DAYS- PRESENT: Q ABSENT: 5 SUMMER TERMS DAYS- PRESENT: 0 ABSENT: 0 PROMOTION STATUS NOT APPLICABLE : 50 SCHOOL: 3390 NO COURSES TAKEN YEAR: 2000-2001 GRADE LEVEL: Ma GPA QTY PTS GPA QTY PTS DISTRLICT-TERM: 1.4286 5.00 COM: 1.5422 27.00 STATE-TERM: 1.42686 5.00 COM: 1.5429 27.00 2000-2001 ANNUAL DAYS~-PRESENT - 0 ABSENT: 0 SUMMER TERMS DAYS-PRESENT: 0D ABSENT: 0 PROMOTICN STATUS NOT APPLICABLE DISTRICT: 502 SCHOCL: 3330 SURVIVORS CHARTER SCHOOL YEAR: 2001-2002 GRADE LEVEL: 10 SURJECT CRSEG AO CREDIT yT COURSR# CXXIRSE TITLE AREA FLAG R CH ATT. L 050053¢ PERS,CAR,SCH DEY 4 EL Cc 2N 0.50 G.5D 1 1001440 BUS ENG I EN J B 2WN 6.50 0.56 1 1205370 CONSUMER MATH WA OC c #%WNWoO.50 0.50 1 8300310 WORKPLACE ESSENTIAL VO B £8 0.50 9.50 1 $301619 WORK EXP 1 Vo F 2N 0.50 0.00 1 83301656 WORK EBXP-OJT YO F ZN 1.00 0.00 CREDTT, TERM: 3.50 2.00 GPA QTY PTs GPA QTY PTS DISTRICT-TERM: 1.4266 5.00 CUM: 1.5429 27.00 STATH-TERM: 1,4286 5,00 CUM: 1.5423 27.00 29001-2002 ANNUAL DAYS-PRESENT: 69 ABSENT: 32 SUMMER TERMS DAYS-PRESENT: Oo ABSENT: 0 NOT ENROLLED IN DISTRICT K-12 AT BSD OF SCHOOL YEAR 34

Case 18-2868, Document 281, 08/09/2019, 2628234, Page35 of 66 See McCawley Dec. at Exhibit 27, GM_00893. Ms. Giuffre’s obvious gap in her school attendance, her presence verified by Epstein’s pilot on flight logs, and an abundence of witness testimony all corroborate her story that she was that Ms. Giuffre was flying domestic and internationally with Epstein at least 32 times between 12/11/00-07/28/01 and 06/2 1/02-08/21/02 (Defendant traveling with Ms. Giuffre on 23 of the flights). See McCawley Dec. at Exhibits 15 and 41, Pilot, David Rodgers’ Dep. Tr. 96:12-166; Rodger’s Dep. Ex. 1 (Ms. Giuffre flight dates: 12/11/00; 12/14/00 (GIUFFRE007095); 01/26/01; 01/27/01; 01/30/01 (GIUFFRE007096); 03/05/01: 03/06/01; 03/08/01 x’s 2; 03/09/01; 03/11/01 x’s 2 (GIUFFRE007097); 03/27/01; 03/29/01; 03/31/01 (GIUFFRE007098); 04/09/01 x’s 2; 04/11/01; 04/16/01; 05/03/01; 05/05/01 (GIUFFRE007099); 05/14/01(GIUFFRE007100); 06/03/01 06/05/01; 07/04/01; 07/08/01; 07/11/01 (GIUFFRE007101); 07/16/01; 07/28/01; (GIUFFRE007102); 06/21/02 (GIUFFRE007111); 08/18/02; 08/21/02 (GIUFFRE007112); See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 104: 9-14 (Q: Do you know how long Virginia had been coming over to the house before she started traveling on an airplane with Ghislaine and Jeffrey? THE WITNESS: Not too long. I don't think it was too long after that); See McCawley Dec. at Exhibit 37, GIUFFRE004721 (passport application). DEFENDANT’S PURPORTED FACTS 39. During the year 2000, Ms. Giuffre worked at numerous jobs. In 2000, while living with her fiancé, Ms. Giuffre held five different jobs: at Aviculture Breeding and Research Center, Southeast Employee Management Company, The Club at Mar-a-Lago, Oasis Outsourcing, and Neiman Marcus. Her taxable earnings that year totaled nearly $9,000. Ms. Giuffre cannot now recall either the Southeast Employee Management Company or the Oasis Outsourcing jobs. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT'S FACTS 35

Case 18-2868, Document 281, 08/09/2019, 2628234, Page36 of 66 Ms. Giuffre disputes this statement. During 2000, Ms. Giuffre shared an apartment with her then boyfriend, James Michael Austrich and his friend, Mario. See McCawley Dec. at Exhibit 2, Austrich Dep. Tr. at p. 92. Although Austrich testified that he proposed to Ms. Giuffre on Valentine’s Day, see Austrich at p. 19, Ms. Giuffre was a troubled teen who could not realistically be considered a fiancé in the true sense of the word nor was she of legal age to marry. While Ms. Giuffre held various jobs in 2000, “[SSA] records do not show the exact date of employment (month and day) because [they] do not need this information to figure Social Security benefits.” See McCawley Dec. at Exhibit 46, GIUFFRE009176). The reason that Ms. Giuffre cannot recall two companies listed on her SSA records (Southeast Employee Management Company or Oasis Outsourcing) 1s simply because they were not her employers. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 470-472. Had Defendant bothered to run a simple google search, she could have ruled them out as being payroll and benefit administration companies. See http://www.oasisadvantage.com/west-palm-beach-peo; http://www.progressiveemployer.com/; http://www.businesswire.com/news/home/2006050100615 1/en/Progressive-Employer-Services Purchases-Southeast-Employee-Management. Ms. Giuffre has testified that she believes she worked at Taco Bell, at an aviary, then Mar-a-Lago (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at p. 53, 470). Austrich also testified that Ms. Giuffre worked with him at Taco Bell, as well as a pet store for “over a month” before working at Mar-a-Lago (See McCawley Dec. at Exhibit 5, Austrich Dep. Tr. at p. 16, 30, 98). Neither Taco Bell nor the pet store are listed on Ms. Giuffre’s SSA records because they were most likely paid through payroll companies. See McCawley Dec. at Exhibit 46, GIUFFRE009178. Ms. Giuffre also testified that she volunteered at an aviary where they 36

Case 18-2868, Document 281, 08/09/2019, 2628234, Page37 of 66 eventually put her on their payroll, but paid her very little. Giuffre Dep. Tr. at p. 52; Aviculture Breeding and Research Center taxable earnings for 2000 is $99.48, See McCawley Dec. at Exhibit 46, GIUFFRE009178. DEFENDANT’S PURPORTED FACTS 40. Ms. Giuffre’s employment at the Mar-a-Lago spa began in fall 2000. Ms. Giuffre’s father, Sky Roberts, was hired as a maintenance worker at the The Mar-a-Lago Club in Palm Beach, Florida, beginning on April 11, 2000. Mr. Roberts worked there year-round for approximately 3 years. After working there for a period of time, Mr. Roberts became acquainted with the head of the spa area and recommended Ms. Giuffre for a job there. Mar-a-Lago closes every Mother’s Day and reopens on November 1. Most of employees Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club is open, 1.e., between November 1 and Mother’s Day. Ms. Giuffre was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT'S FACTS Ms. Giuffre disputes this statement. Defendant cannot simply infer Ms. Giuffre’s employment history and claim it to be undisputed. The Mar-a-Lago Club produced 177 pages of records in response to Defendant’s subpoena. However, not one page indicated Ms. Giuffre’s actual dates of employment, nor whether she was a full-time or seasonal employee. In fact, the only significant record produced was a single, vague chart entry indicating that Ms. Giuffre was terminated in 2000. MAR-A-LAGO 0173, 0176. TERMINATIONS Box #1 LAST NAME FIRST NAME Box #2 Box #3 Box #5 Box #6 1998 terms 1998 & 1999 terms 1999 terms 2000 terms 2000 terms 2001 terms MAR-A-LAGO 0176 MAR-A-LAGO 0173 eh,

Case 18-2868, Document 281, 08/09/2019, 2628234, Page38 of 66 Job postings and job descriptions produced by Mar-a-Lago from 2002 and later are irrelevant to Ms. Giuffre’s employment because they are from after she worked there. Ms. Giuffre testified that Mar-a-Lago was a summer job. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. 56, 550. In fact, her father, Sky Roberts, testified that he referred his daughter for employment, and she did not get the job through a posting (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 72); he drove his daughter to and from work consistent with his full time schedule (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 74); he believes the spa — like the kitchen/dining room - was open to local guests in the summer (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. 138-139); and that his daughter was not attending school when she worked at Mar-a-Lago (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. 134). In addition, Juan Alessi testified that it was “Summer” when Defendant approached Ms. Giuffre at Mar-a-Lago because he specifically remembered “that day I was sweating like hell in the -- in the car, waiting for Ms. Maxwell to come out of the massage.” See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 94:24-95:2. DEFENDANT’S PURPORTED FACTS 41. Ms. Giuffre represented herself as a masseuse for Jeffrey Epstein. While working at the Mar-a-Lago spa and reading a library book about massage, Ms. Giuffre met Ms. Maxwell. Ms. Giuffre thereafter told her father that she got a job working for Jeffrey Epstein as a masseuse. Ms. Giuffre’s father took her to Epstein’s house on one occasion around that time, and Epstein came outside and introduced himself to Mr. Roberts. Ms. Giuffre commenced employment as a traveling masseuse for Mr. Epstein. Ms. Giuffre was excited about her job as a masseuse, about traveling with him and about meeting famous people. Ms. Giuffre represented that she was employed as a masseuse beginning in January 2001. Ms. Giuffre never mentioned Ms. Maxwell to her then-fiance, Austrich. Ms. Giuffre’s father never met Ms. Maxwell. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS Ms. Giuffre denies Defendant’s false and factually unsupported narrative. In Florida, a person cannot work as a masseuse unless she is “at least 18 years of age or has received a high 38

Case 18-2868, Document 281, 08/09/2019, 2628234, Page39 of 66 school diploma or high school equivalency diploma.” Fla. Stat. § 480.041. Ms. Giuffre was a minor child, under the age of 18, when she was working at Mar-a-Lago as a spa attendant. Giuffre Dep. Tr. at 61:9-61:24. She was approached by Defendant, who told her she could make money as a masseuse, a profession in which Ms. Giuffre had no experience. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12. (Sky Roberts, Ms. Giuffre father, verified Ms. Giuffre’s account that Defendant recruited his daughter to “learn massage therapy.” See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 80:7-19; 84:18 85:1). Ms. Giuffre’s father drove her to Jeffrey Epstein’s house, the address of which was given to her by Defendant. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 117:20-118:1. Ms. Giuffre was lead into the house, and was instructed by Defendant on how to give a massage, during which Epstein and Defendant turned the massage into a sexual encounter, and offered Ms. Giuffre money and a better life to be compliant in the sexual demands of Defendant and Epstein. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18. The minor Ms. Giuffre then began travelling with Defendant and Epstein on private planes and servicing people sexually for money—working not as a legitimate masseuse, but in a position of sexual servitude. See McCawley Dec. at Exhibits 5, 1, Giuffre Dep. Tr. at 193:22-194:16; 201:24; 204:24:205:5; Alessi Dep. Tr. at 104:9-104:14. Epstein’s house manager, Juan Alessi, described Defendant’s methodical routine of how she prepared a list of places ahead of time, then drove to each place for the purpose of recruiting girls to massage Epstein. See McCawley Dec. at Exhibit 18, Alessi Dep. Tr. at 34; GIUFFRE000105 at 57-58; GIUFFRE000241-242 at p. 212-213. Alessi also stated that on multiple occasions he drove Defendant to pre-planned places while she recruited girls for 39

Case 18-2868, Document 281, 08/09/2019, 2628234, Page40 of 66 massage. /d. He furthered testified that he witnessed Ms. Giuffre at Epstein’s house on the very same day that he witnessed Defendant recruit Ms. Giuffre from Mar-a-Lago. See McCawley Dec. at Exhibit 18, Alessi Dep. Tr. at 96-98; GIUFFRE000102-103 at p. 48-49. Johanna Sjoberg, through her sworn testimony, demonstrated that Defendant recruited her in a similar fashion by driving to the college campus where she attended school and approached her to work at Epstein’s home answering phones. See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 8-9. Sjoberg testified that she answered phones for one day before Defendant propositioned her to rub feet for $100.00 an hour. See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 13. The following day, Sjoberg was paired with Defendant’s assistant, Emmy Taylor, who provided her with massage training on Epstein. Sjoberg at 13-15. Ms. Giuffre’s then-boyfriend, Austrich, testified that he could not recall the name of the person who recruited Ms. Giuffre. However, he did say that she was recruited by someone to work for Epstein as a massage therapist, but that Ms. Giuffre did not have any experience. See McCawley Dec. at Exhibit 2, Austrich Dep. Tr. at 34-35, 100-101, 127-128. Neither Ms. Giuffre nor Sjoberg were licensed or trained in massage, but were invited soon after being recruited to travel with Epstein on his private plane to massage him. See McCawley Dec. at Exhibit 16, Giuffre Dep. Tr. at 16-17; Sjoberg Dep. Tr. at 13-15; Austrich Dep. Tr. at 109-110; Alessi Dep. Tr. at 104. DEFENDANT’S PURPORTED FACTS 42. Ms. Giuffre resumed her relationship with convicted felon Anthony Figueroa. In spring 2001, while living with Austrich, Ms. Giuffre lied to and cheated on him with her high school boyfriend, Anthony Figueroa. Ms. Giuffre and Austrich thereafter broke up, and Figueroa moved into the Bent Oak apartment with Ms. Giuffre. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa in Ms. Giuffre’s presence punched Austrich in the face. Figueroa and Ms. Giuffre fled the scene before police arrived. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS 40

Case 18-2868, Document 281, 08/09/2019, 2628234, Page41 of 66 This entire statement 1s wholly irrelevant to the case being tried, and is improperly being inserted to tarnish the record. Ms. Giuffre’s dating history as a young teen bears no relation to the allegations made within Ms. Giuffre’s complaint against Defendant. As previously stated, Defendant is attempting to muddy the record with nonsensical teen drama in an effort to detract from her salacious sexual abuse of a minor child. Such statements bear no relation to the issues presented through her motion for summary judgment, and should be given weight reflecting the same. As specifically set forth in Ms. Giuffre’s objections to designated testimony, the alleged information would be excluded by multiple rules of evidence, and contested by Ms. Giuffre. See McCawley Dec. at Exhibit 5, Virginia Dep. Tr., passim. Moreover, it was the Defendant who solicited Anthony Figueroa to recruit high school aged girls for Epstein. See McCawley Dec. at Exhibit 4 Figueroa Tr. at 200 and 228-229. DEFENDANT’S PURPORTED FACTS 43. Ms. Giuffre freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at age 17, while living in the same apartment, Ms. Giuffre and Figueroa hosted a party with a number of guests. During the party, according to Ms. Giuffre, someone entered Ms. Giuffre’s room and stole $500 from her shirt pocket. Ms. Giuffre contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a “sex slave.” A second time, in June 2002, Ms. Giuffre contacted the police to report that her former landlord had left her belongings by the roadside and had lit her mattress on fire. Again, Ms. Giuffre met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a “sex slave.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This statement is misleading in several respects and irrelevant. The fact that Ms. Giuffre did contact police on two occasions for two specific purposes and did not take that opportunity to also inform the police of everything else that was going on in her life at the time is immaterial. Defendant implies that anytime someone calls the police for one thing they should tell the police 41

Case 18-2868, Document 281, 08/09/2019, 2628234, Page42 of 66 about every other crime regardless of the relevance to the crime to which the police responded and regardless to the threat to herself should she report on these powerful people. Moreover, as Professor Coonan explained: Popular understandings of the term “sex slave” might still connote images of violent pimps, white slavery, or of victims chained to a bed in a brothel in the minds of some people. To call Ms. Giuffre a victim of sex trafficking would however very accurately convey the reality that she along with a great many other victims of contemporary forms of slavery are often exploited by the “invisible chains” of fraud and psychological coercion. See McCawley Dec. at Exhibit 23, Coonan Expert Report at 20. Ms. Giuffre specifically testified that she was fearful of Defendant and Epstein, and, accordingly, she would not have reporter her abusers. She also knew that Epstein had control over the Palm Beach Police. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 240:3-241:2. DEFENDANT’S PURPORTED FACTS 44. From August 2001 until September 2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel unaccompanied by Ms. Giuffre. Flight logs maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips away from Florida that Epstein and Maxwell took, unaccompanied by Ms. Giuffre, between August 2001 and September 2002. Rodgers maintained a log of all flights on which Epstein and Maxwell traveled with him. Epstein additionally traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial flights. For substantially all of thirteen months of the twenty-two months (from November 2000 until September 2002) that Ms. Giuffre lived in Palm Beach and knew Epstein, Epstein was traveling outside of Florida unaccompanied by Ms. Guiuffre. During this same period of time, Ms. Giuffre was employed at various jobs, enrolled in school, and living with her boyfriend. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS The flight logs produced in this matter provide substantive evidence of Ms. Giuffre’s travel while in the control of Defendant and Epstein, but are clearly incomplete. Moreover, Ms. Giuffre also was flown by Defendant on commercial flights. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 155:5-11. Ms. Giuffre disputes Defendant’s statement to the contrary, as reliance upon incomplete records to prove that Ms. Giuffre was not in fact in the presence of 42

Case 18-2868, Document 281, 08/09/2019, 2628234, Page43 of 66 Defendant and Epstein 1s insufficient. Ms. Giuffre incorporates additional details contained in Response #38 and #46 herein. Ms. Giuffre’s obvious gap in her school records, her presence verified by Epstein’s pilot on flight logs, and witness testimony, corroborate her story that she was traveling with Defendant and Epstein. In fact, flight logs and pilot testimony clearly prove that Ms. Giuffre was flying domestic and internationally with Epstein at least 32 times between 12/11/00-07/28/01 and 06/2 1/02-08/21/02 (Defendant traveling with Ms. Giuffre on 23 of the flights). As Defendant acknowledges in her own statement #44, flight records are incomplete. There were several pilots and co-pilots that flew Epstein and Maxwell (Lawrence “Larry” Visoski, David (Dave) Rodgers, Bill Hammond, Pete Rathgeb, Gary Roxburgh, and Bill Murphy) in multiple aircrafts (JEGE, Inc. Aircraft # N908JE — Type B-727-31, and Hyperion Aur, Inc. Aircraft # N909JE — Type G-1159B). Yet, only one pilot, David Rodger’s produced flight records. See McCawley Dec. at Exhibit 41, David Rodger’s Flight Log, GIUFFRE007055- GIUFFRE007161. In addition, many of the girls recruited by Defendant routinely traveled on commercial flights for the purposes of providing massages to Epstein or guests at Epstein’s New York, New Mexico, or U.S. Virgin Island homes. See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 27. As thoroughly depicted below, Ms. Giuffre’s passport application, travel records and witness testimony clearly demonstrate flight logs are incomplete because only one pilot kept a log, and Ms. Giuffre also flew commercially while she worked for Defendant and Epstein. For example, on December 11, 2000, while underage, Ms. Giuffre appears on Rodger’s flight log (flight #1433) traveling with Epstein, Maxwell and Emmy Taylor from PBI (Palm Beach, FL) to TEB (Teterboro, NJ) then on December 14, 2001 (#1434) continues traveling with Epstein and 43

Case 18-2868, Document 281, 08/09/2019, 2628234, Page44 of 66 Maxwell to TIST (U.S. Virgin Islands); however, there is no flight records of Ms. Giuffre’s return to Palm Beach. See McCawley Dec. at Exhibit 15, see McCawley Dec. at Exhibit 41, Rodger’s Dep. Ex. 1 at GIUFFRE007095; see also Rodger’s Dep. Tr. 96-98 (“Q: And do you know how Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, and Virginia get off of St. Thomas or leave the island? A: No. I do not. Probably a charter, I'm guessing.”’). {| 4 | PBI : | TER JE GM, EF, VIRIAL | eas) PBS | WwNteAs <emrepaa On January 12, 2001, at Defendant’s directive, Ms. Giuffre applied for a Passport to travel with them internationally. See McCawley Dec. at Exhibit 37, GIUFFRE004721, passport application listing travel plans to London; flight logs subsequently lists Ms. Giuffre traveling to London with Defendant, Epstein and others). ESeececteennai Miser esse Meaalecoini cee Brn cersciepelctioiastavctioeorsoarrcaeceiiatbasvibieaiyin ode £ eee 3 %. : Wesovecerito Tetnomicndh : AT LEELA LLL ALLIED EN DLS NLAGLO RLS DALAL EDA LID LELLDILA SPN NPL ALLE PLANS DPLIID)\ SEB) LVPN ESS ISIS ASN SIGIR ELI PAY OO ait si ca ND fee RNS SME eNURCIDNO PION A AS DRA DTRMRECK EOL ANCOSKA i i LE MO OCR TE OE OEE WR he iene Gat yas alte pW PURE ARNE tom j gE i Ga 4 teem. Poin Let Galt Ey HEE REREE 1G he: GLEE GS TRy ‘ Ci ee ts “ ‘sls el nse Bhatti ce reine’ On January 26, 2001, while underage, Ms. Giuffre appears on Rodger’s flight log (flight #1444) traveling with Epstein, Maxwell and Emmy Taylor from TEB (Teterboro, NJ) to PBI (Palm Beach, FL); however, there is no flight record indicating how Ms. Giuffre got to New York. On January 27, 2001 (#1445) continues traveling with Epstein, Maxwell and Emmy Taylor from PBI (Palm Beach) to TIST (U.S. Virgin Islands) returning from TIST (U.S. Virgin 44 = CB | TE, Gen, AY, Uirepmpp Gittins Ge oy ess —_ vt ; sa Bx | ea RGPSSEITOY F o7s h x Tcrs

Case 18-2868, Document 281, 08/09/2019, 2628234, Page45 of 66 Islands) four days later on January 30, 2001. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007096; Rodger’s Dep. Tr. at 100-102. | mt FA 4y wa } oS Ieee TF LL YE? Obl os | m (Tope Tis SE, GM, EF, VRER, VERCINIA Robacss: \ Ye Ae Uuby ae eR. LNA a ei CIP VOUT PETE SaREMSON . \ “A LAPy Le B72 cesta, A SOSLS \4 “ 34 Tops BN Mh P -tN¢ ee fe ee Fe oder 44] _ i [mee y GIIS46 ORT | PB # wus] SE, GM; ST VRC IPED RokxeH Sol] \ oe TIST PBX jug! S4,GM, CT, Virarie Robeess rc EM VE aASD «Ss Aa 2 7 A eS > On March 5, 2001 Ms. Giuffre, Maxwell, Epstein, Emmy Taylor traveled together internationally (flight #1464) leaving PBI (West Palm Beach) to CYJT (Stephenville, Canada); then on March 6, 2001 (#1465) they continued on to LFPB (Paris, France) with a layover for three days. On March 8, 2001, other passengers, including one unidentified female, joined them on flights # 1466-1467 (from LFPB (Paris, France) - LGGR (Granada, Spain) eventually landing in EGGW (London, England) on March 11, 2001, where she was then introduced to and lent out to Prince Andrew. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007097; Rodger’s Dep. Tr. at 104-114. Teer reeremeeamrna rn n a — | lz i Flown | No. Mia yan - ets "h ' ] Ti a “ff pew | | x a RGIPIDE : TASTING ans = es = Men | hl Si Gstke CN BMG cw 5 no Te GRAMS sat oie oN He eet FiRobanes. feo ser pa. oe “5: a e\yeor Rye hae tai 0~WeOp “2 it aN Pons ery : aon Tae aes (SHO, eins ca Pech <A RYTT PH, a . At ie Fou aDue Se eed Tem iar nd ore ; +L Ge (c- 5 Ldereee pGeV ST, UIMCLATA RoR © ee TR Am an cae SoU eae ee / Us aM fel? oo Sauk, PL0cA7 Lp oR PANG A [a |e pee lenty | he Peery a M eager | RGR |__ liao VR Re a |. oe BGK CB 4g 3S/OM ST, VR 3 iid fw Va otf newer A aw - ei i. = oS ee 45

Case 18-2868, Document 281, 08/09/2019, 2628234, Page46 of 66 See also photo of Ms. Giuffre, Maxwell and Prince Andrew in London. GIUFFRE007167; see also Figueroa Dep. Tr. at 251. Ms. Giuffre, Epstein, Maxwell, and Taylor remained in London for three days until departing on March 11, 2001 (#1469), stopping in BGR (Bangor, Maine) before departing (#1470) back to TEB (Teterboro, NJ); however, there is no flight record of Ms. Giuffre’s return to Palm Beach. See Rodger’s Dep. Ex. | at GIUFFRE007097; Rodger’s Dep. Tr. at 104-114. ~y = : Hes | _h ung Ye, CEN, 5 Cones, GANT RET SL feo jen i hte BK ARNT ATR 2h sae [Per OTC BQN Corts Pe oe ag ORLED, PBy eh uate em, At On March 27, 2001, while underage, Ms. Giuffre, Maxwell, Epstein, Emmy Taylor, two unidentified females and others traveled together (#1478) from PBI (Palm Beach) to TEB (Teterboro, NJ); then three days later, on March 29, 2001, continued on (#1479) to SAF (Santa Fe, NM), returning to PBI (Palm Beach, FL) with Nadia Bjorlin (#1480) on March 31, 2001. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007098; Rodger’s Dep. Tr. at 119-125. 46

Case 18-2868, Document 281, 08/09/2019, 2628234, Page4/7 of 66 A few glaring examples of how Ms. Giuffre’s travel records are incomplete is that Ms. Giuffre traveled from ADS (Addison, Texas) on May 3, 2001 (#1501) to SAT (San Antonio, Texas); then departs SAT (San Antonio, Texas) on May 5, 2001 (#1502) to PBF (Pine Bluff, AR) but there is no record produced that explains how Ms. Giuffre arrived in Addison, Texas or how she returned to Palm Beach from Pine Bluff, AR. Although Epstein’s plane appears to have to originated from Palm Beach on April 23, 2001, Ms. Giuffre’s name doesn’t not appear on the log. See Rodger’s Dep. Ex. | at GIUFFRE007099; Rodger’s Dep. Tr. at 130-132 (“Q: Do you know how Virginia Roberts got to Addison, Texas? A: No. ... Q: Went to Addison and picked up Virginia Roberts? A: It looks like it.’’). Another prime example of how incomplete Ms. Giuffre’s travel records are is on on May 14, 2001. While Ms. Giuffre appears on flight #1506 with Epstein, Maxwell, Emmy Taylor and others (including one unidentified female) from TIST (U.S. Virgin Islands) to TEB (Teterboro, NJ), there is no record produced explaining how Ms. Giuffre arrived to the U.S. Virgin Islands or where she stayed when she landed in New York. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007100; Rodger’s Dep. Tr. at 132-133 (“Q: What were the other possible avenues back in those days for Jeffrey Epstein, Ghislaine Maxwell to travel to the Virgin Islands? A: They could have done a charter, possibly.”) Ud. at 134-135 “Q: All right. So at some point in time, between May 7th and May 14th — A: Uh-huh. Q: -- somebody flies the Gulfstream to the Virgin Islands. A: Correct. Q: And who would that be? A: Larry Visoski and I don't know who the other person would have been.”’); /d. at 136 (“Q. Do you know where Virginia Roberts went during that time after she landed in Teterboro on the 14th? A. I do not.”) JAI@ 540 [N4O¢s¢ [vesv [yee | tse fP4s M61, BE VR 1 emote 47

Case 18-2868, Document 281, 08/09/2019, 2628234, Page48 of 66 On June 3, 2001, Ms. Giuffre travels from PBI (Palm Beach) to TIST (U.S. Virgin Islands) on flight #1510 for three days; then, on June 5, 2001, continues on flight #1511 to TEB (Teterboro, NJ); however, there is no record of Ms. Giuffre returning to Palm Beach. See Rodger’s Dep. Ex. 1 at GIUFFRE007101; Rodger’s Dep. Tr. at 136-137. - ssciloeiaehrenaes LA (= “1540 Notre | | = Vi vA TEs. rys9 asf ou [oo fiat osm) ol oo Ltt Ss | a LFS | LPH QS! — M eee a {_al yA rosr_| e6e— | ; : 5| ee | een ee We Shatin CE : aye Ct ee ieee tee Then, on July 4, 2001, Ms. Giuffre reappears on flight #1524 with Epstein and an unidentified female leaving TIST (U.S. Virgin Islands) to return to PBI (Palm Beach); however, there is no flight record that reflects how Ms. Giuffre got to the U.S. Virgin Islands. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007101; Rodger’s Dep. Tr. at 138-139 (“Q. And do you know how Virginia Roberts got to the Virgin Islands? A: No. Q. Is there any -- is it possible that the Cessna took her or the Boeing took her? Or any other aircraft that is owned by Jeffrey? A: No, I would -- if I had to guess, I would guess the airlines.”’) Again, on July 8, 2001, Ms. Giuffre appears on flight #1525 with Epstein, Maxwell, Emmy Taylor and others including an unidentified female departing PBI (Palm Beach) to TEB 48

Case 18-2868, Document 281, 08/09/2019, 2628234, Page49 of 66 (Teteboro, NJ). Four days later, on July 11, 2001, Ms. Giuffre, Epstein and Maxwell continue on (#1526) to CPS (Cahokia-St. Louis, Illinois) which was a stop due to a mechanical delay on the way to Sante Fe, NM; however, there is no flight record that reflects how Ms. Giuffre returned home to Palm Beach. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. | at GIUFFRE007101; Rodger’s Dep. Tr. 139-141 (“Q: And then three days later, you leave out of Teterboro to CPS? A: Yes. Q: Where is that? A: That is St. Louis, actually it 1s Cahokia, Illinois, across the river from St. Louis. Q. Who are your passengers? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia Roberts. We were actually en route to Santa Fe. We had a mechanical problem. We had to go into there for maintenance.”’) On July 16, 2001, Ms. Giuffre appears on flight #1528 with Epstein, Maxwell and Emmy Taylor from SAF (Santa Fe, NM) to TEB (Teteboro, NJ); however, Ms. Giuffre’s flight to Santa Fe, NM is missing from the records. In addition, on July 28, 2001, Ms. Giuffre reappears on the flight log (#1531) returning with Epstein from TIST (U.S. Virgin Islands) to PBI (Palm Beach); however, there is no record of Ms. Giuffre’s flight to the U.S. Virgin Islands. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007102; Rodger’s Dep. Tr.142. a | i %, # mR “EET [ema [ease SOE eet sr “i te 3 j\E9,GM, VR =F ; ne oh - ] ; Hao ey 23 yi \s %.| De, Seder Lawes | 2% _ si <>} | Te, VILE EM ROBERTS On June 21, 2002, Ms. Giuffre appears on flight #1570 with Epstein, Maxwell, Sarah Kellen, Cindy Lopez and Jean Luc Brunel from PBI (Palm Beach, FL) to MYEF (George Town, Bahamas); however, there is no record of Ms. Giuffre returning to Palm Beach. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007111; Rodger’s Dep. Tr. 161-162 (“Q: 49

Case 18-2868, Document 281, 08/09/2019, 2628234, Page5O of 66 Virginia Roberts was taken to the Bahamas. Do you know where she went from there? A. I do not.’’) a va 7 it ee e | ace fear iG sense — 4 ReRSRe fee | RP TP OE SEYEMSY, CENOT LOPED PE : red PE {| rena GM SK elses t lise Briers “abit PBC | hey ePesspe FEE AYE’ eel Moraes. yee _| ‘Toc ? . | (GE | _lts73| 3S Gr. , Lee ee ers oo Z| VA * TER _ Lepe Tien REPSSEI pow | ones | TE [GSAS aeame [POE CTROY | lla enn er: ebco yt 1584 eG, ) FEMALE 7 PLS | haa eemet ot * ij * ie (Te) St) > em be |C-\12XP AEC |i | 2oGe3 [averse Haw Loree. 1G | B“121-318 foure (e| « Tres 3 {1 Gist (nacase ee — eek —| a ecese gerraeeereanet z ‘\o| VK \ ae PBL | Acq 9VaRbraP ROBEAT, | Faron er On August 17, 2002, Ms. Giuffre appears on flight #1589 with Epstein, Maxwell, Sarah Kellen, Cindy Lopez and others from SAF (Santa Fe, NM) to TEB (Teterboro, NJ); Ms. Giuffre returns to PBI (Palm Beach, FL) on August 18, 2002 with Epstein and one unidentified female (#1590). See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007112; Rodger’s Dep. Tr. 165 (“Q: Do you know how Virginia Roberts got to Santa Fe? A: No.”) 50

Case 18-2868, Document 281, 08/09/2019, 2628234, Page51 of 66 From September 29, 2002 through October 19, 2002, Defendant and Epstein sent Ms. Giuffre on a commercial flight to Thailand for massage training and provided her with all accommodations. See McCawley Dec. at Exhibit 43, Giuffre00741 1-Giuffre007432. DEFENDANT’S PURPORTED FACTS 45. Ms. Giuffre and Figueroa shared a vehicle during 2001 and 2002. Ms. Giuffre and Figueroa shared a ’93 white Pontiac in 2001 and 2002. Ms. Giuffre freely traveled around the Palm Beach area in that vehicle. In August 2002, Ms. Giuffre acquired a Dodge Dakota pickup truck from her father. Figueroa used that vehicle in a series of crimes before and after Ms. Giuffre left for Thailand. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS Ms. Giuffre and Tony Figueroa did not share a vehicle during 2001 and 2002. Instead, Figueroa borrowed Ms. Giuffre’s car while she was traveling with Defendant and Epstein. Figueroa testified that he “got to take the car, because she was going somewhere else in the world and did not need it, so...”” Figueroa Dep. Tr. At 89-90. In fact, Ms. Giuffre was frequently traveling with Defendant and Epstein. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 9-14 (stating that Virginia started traveling on an airplane with Ghislaine and Jeffrey “not too long” after she started going over to the house). Figueroa further testified that Virginia “would normally go about two weeks out of every month” with Epstein. Figueroa Dep. Tr. at 90. He further stated, “Pretty much every time I took her there, it was always to his mansion. I picked her up one time -- maybe it was a couple of times --from the jet stream place. But pretty much every single time it was at the hou- -- at the mansion.” /d. Moreover, Ms. Giuffre testified she purchased a car from the $10,000 payment she received from Epstein after she was forced to have sex with Prince Andres in London at Defendant’s home when Ms. Giuffre was a minor. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 120:1-20. 51

Case 18-2868, Document 281, 08/09/2019, 2628234, Page52 of 66 DEFENDANT’S PURPORTED FACTS 46. Ms. Giuffre held a number of jobs in 2001 and 2002. During 2001 and 2002, Ms. Giuffre was gainfully employed at several jobs. She worked as a waitress at Mannino’s Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at Roadhouse Grill. She also was employed at Courtyard Animal Hospital (aka Marc Pinkwasser DVM). MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS This statement is laughable. Ms. Giuffre was hardly gainfully employed during a time period in which she was trying to escape from the grip Epstein and Maxwell had on Ms. Giuffre. While Social Security provides that she earned nominal amounts of earning statements for 2001 and 2002, the records do not indicate the month or quarter of the year’s work. See McCawley Dec. at Exhibit 46, GIUFFRE009176. For a brief period, Ms. Giuffre attempted to go back to school to earn her GED, and tried unsuccessfully to hold down waitressing jobs. See McCawley Dec. at Exhibit 27, GIUFFRE009179. For example, in 2001, Ms. Giuffre earned $212.00 as a waitress working “briefly” at Mannino’s Restaurant. (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 472). In 2002, Ms. Giuffre earned $403.64 at CCI of Royal Palm Beach working there (TGI Fridays) for a “short time period.” (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 473). Then, Ms. Giuffre worked at Roadhouse grill until about March 2002 earning $1,247.90 (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 474). EMPLOYER NUMBER: 65-0241353 MANNINOS INC MANNINOS RESTAURANT 12793 B W FOREST HILL BLVD WEST PALM BEACH FL 33414-4749 YEAR 1ST OTR 2ND QTR 3RD QTR 4TH QTR TOTAL 2001 $212.00 a2

Case 18-2868, Document 281, 08/09/2019, 2628234, Page53 of 66 EMPLOYER NUMBER: 06-1587035 CCI OF ROYAL PALM INC % ROBERT FURR TTEE 2255 GLADES RD STE 337-W BOCA RATON FL 33431-7379 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 2002 $403.64 EMPLOYER NUMBER: 65-0367604 ROADHOUSE GRILL INC ROBERT C FURR TTEE IN BANKRUPTCY 2255 GLADES RD STE 337W BOCA RATON FL 33431-7379 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 2002 $1,247.90 EMPLOYER NUMBER: 65-0915938 MARC PINKWASSER DVM PA 13860 WELLINGTON TRCE STE 31 WELLINGTON FL 33414-8541 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL 2002 $1,561.75 , GIUFFRE009179.© According to Dr. Pinkwasser’s records, Ms. Giuffre’s also received payroll checks for weeks ending 04/22/02-06/04/02 earning a total of $1,561.75. (See McCawley Dec. at Exhibit 47, GIUFFRE009203). 4/22/02 Courtyard Animal Hospital! 5/6/02 Courtyard Animal Hospital 9/6/02 Courtyard Animal Hospital 2/20/02 Courtyard Animal Hospital 6/4/02 Courtyard Animal Hospital Not long after Ms. Giuffre losing her job at Courtyard Animal Hospital, GIUFFRE00009211, flight records show that Ms. Giuffre was soon back under Epstein’s control traveling with Maxwell to the Bahamas, Santa Fe, New Mexico then New York, see McCawley Dec. at Exhibit 47, GIUFFRE007111-GIUFFRE007112. DEFENDANT’S PURPORTED FACTS 47. In September 2002, Ms. Giuffre traveled to Thailand to receive massage training and while there, met her future husband and eloped with him. Ms. Giuffre traveled 53

Case 18-2868, Document 281, 08/09/2019, 2628234, Page54 of 66 to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove her to the airport. While there, she initially contacted Figueroa frequently, incurring a phone bill of $4,000. She met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until two days before Mr. Figueroa’s deposition in this matter in May 2016. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS Ms. Guiuffre did travel to Thailand to receive massage training in September 2002. However, Defendant has inaccurately told only part of the story. Defendant has conveniently left out certain key facts, which includes the fact that Ms. Giuffre was given an assignment from Defendant and Epstein that she had to recruit another underage girl from Thailand, and bring that young girl back to Epstein. See McCawley Dec. at Exhibit 43, GIUFFRE 003191. The document Ms. Giuffre was give directs her to “call Ms. Maxwell.” See McCawley Dec. at Exhibit 32, G(UFFRE003191. It is not disputed by Defendant or Epstein, that Ms. Giuffre was expected to return to Epstein and Maxwell upon completion of her massage training and assignment. It is undisputed by Ms. Giuffre that she did not return to Defendant and Epstein, but instead escaped clear across the world to Australia where she remained in hiding from Defendant and Epstein for several years. DEFENDANT’S PURPORTED FACTS 48. Detective Recarey’s investigation of Epstein failed to uncover any evidence that Ms. Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. Joseph Recarey served as the lead detective from the Palm Beach Police Department charged with investigating Jeffrey Epstein. That investigation commenced in 2005. Recarey worked only on the Epstein case for an entire year. He reviewed previous officers’ reports and interviews, conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance footage of the Epstein home, participated in and had knowledge of the search warrant executed on the Epstein home, and testified regarding the case before the Florida state grand jury against Epstein. Detective Recarey’s investigation revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect by the government. None of Epstein’s alleged victims said they had seen Ms. Maxwell at Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her, nor told what to wear or how to act by her. Indeed, none of Epstein’s alleged victims ever reported to the government they had met or spoken to Ms. Maxwell. Maxwell was not 54

Case 18-2868, Document 281, 08/09/2019, 2628234, Page55 of 66 seen coming or going from the house during the law enforcement surveillance of Epstein’s home. The arrest warrant did not mention Ms. Maxwell and her name was never mentioned before the grand jury. No property belonging to Maxwell, including “sex toys” or “child pornography,” was seized from Epstein’s home during execution of the search warrant. Detective Recarey, when asked to describe “everything that you believe you know about Ghislaine Maxwell’s sexual trafficking conduct,” replied, “I don’t.”” He confirmed he has no knowledge about Ms. Maxwell sexually trafficking anybody. Detective Recarey also has no knowledge of Ms. Giuffre’s conduct that 1s subject of this lawsuit. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS This statement is false. Detective Recarey knew that Maxwell was involved in the illegal sexual activities at Epstein's house. He wanted to speak to her, but Maxwell did not return his calls. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 28:23-29:10. Detective Recarey concluded that Defendant’s role was to procure girls for Epstein. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 29:16-29:20. In the execution of the search warrant, stationary was found in the home bearing Maxwell's name, and notes were written by house staff to Maxwell. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 45:13-25; Jd. at 83:3-83:15; see also Message Pads, GIUFFRE 001412, 001418, 001435, 001446, 001449, 001453, 001454. A key piece of evidence in the investigation were message pads uncovered in trash pulls, and from inside the residence during the search warrant. Those message pads revealed numerous calls left at the house for Maxwell, indicating she was staying in the house during the days when Epstein was engaging in illegal sex acts with minors. Additionally, a walk through video taken during the execution of the search warrant revealed photos of topless females at the home, and there was even a photograph of Maxwell naked hanging in the home. The house staff who were deposed 1n the civil cases each testified to Maxwell being the boss in charge of everyone in the house. See McCawley Dec. at Exhibits 1, 55

Case 18-2868, Document 281, 08/09/2019, 2628234, Page56 of 66 19, 21, Banasiak Dep. Tr. at 8:21-9:16; 14:20-15:6; Alessi Dep. Tr. at 23:11-23:20; Rodriguez Dep. Tr. at 169:1-169:4. Rodriguez, the house butler from 2004 through 2005, a time period that revealed daily sexual abuse of underage females, testified that Maxwell kept a list of the local girls who were giving massages at her desk, and that Maxwell kept nude photos of girls on her computer. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 238:4-238:22; 302:19-303:10; 306:1306:24. Recarey testified that when the search warrant was executed, the house had been sanitized and the computers removed from the home. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 72:25-73:15. Banaziak testified that the computers were removed by Adriana Ross, another employee who answered to Maxwell. See McCawley Dec. at Exhibit 19, Banaziak Dep. Tr. at 54:7-22. The record is replete with testimony demonstrating that Maxwell recruited Virginia, and recruited other females, who in turn recruited other females, all who were sexually abuse by Epstein; meaning, it is undisputed that Maxwell started the top of the pyramid of local Palm Beach girls who were all eventually identified as victims. See, e.g., McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 34:19-35:3; 98:5-98:12; 104:15-104:23. The co-conspirator who maintained direct contact with the many underage victims was Sarah Kellen, whose sole responsibility was to schedule underage girls to visit Epstein for sex. Sarah reported directly to Maxwell. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 26:10-26:20. On the day when the search watrant was executed, the house maid, Ruboyo was scheduled to report to the house that day at 8 am; however, she received a call from Maxwell telling her not to go. See McCawley Dec. at Exhibit 20, Rabuyo Dep. Tr. at 81:20-82:25. Maxwell orchestrated and ran the entire sex 56

Case 18-2868, Document 281, 08/09/2019, 2628234, Page5/ of 66 trafficking scheme from a high level, and insulated herself from most of the underage girls who were being paid for sex. Tony Figueroa, Ms. Giuffre's ex-boyfriend, did testify that Maxwell personally requested that he find and bring girls to Epstein for sex once Ms. Gtuffre had escaped, and that when he brought the girls Maxwell interacted with them. See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 200:6-18; 228:23-229:21. Rodriguez testified unequivocally that Maxwell was "the boss" and that she knew everything that was going on. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. 169:1-169:4. DEFENDANT’S PURPORTED FACTS 49. No nude photograph of Ms. Giuffre was displayed in Epstein’s home. Epstein’s housekeeper, Juan Alessi, “never saw any photographs of Virginia Roberts in Mr. Epstein’s house.” Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS This is false. Nude photographs were displayed throughout Epstein’s home. Furthermore, Alfredo Rodriguez testified to Maxwell having pornography on her computer. Rodriguez Dep. Tr. 150:10-17; 306:1-306:24. He also testified to there being a collage of nude photos in Epstein's closet. Jd. 253:14-254:18. That collage was eventually taken into evidence by Detective Recarey, who testified to that fact in his deposition. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 73:19-73:24. And those photos are still in the possession of the FBI or US Attorney's Office. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 74:2-74:7. Numerous other people have testified about nude photographs being on display in the home including Ronaldo Rizzo, who visited the home on numerous occasions and who was reprimanded by Maxwell herself for looking at the nude photos. See McCawley Dec. at Exhibit 14, Rizzo Dep. Tr. at 25:19-26:20. Additionally, the search warrant video, taken at a time when 57

Case 18-2868, Document 281, 08/09/2019, 2628234, Page58 of 66 the house had already been sanitized, revealed photographs of nudity displayed, including a photograph of Maxwell herself in the nude. See McCawley Dec. at Exhibit 44, Search Warrant Video attached to the Deposition of Recarey. Johanna Sjorberg testified that the Defendant bought her a camera for the specific purpose of her taking nude photos of herself. See McCawley Dec. at Exhibit 16 Sjoberg Tr. at 150. Finally, Virginia Giuffre testified that there was a nude photograph of her at the house. See McCawley Dec. at Exhibit 5 Virginia Giuffre Tr. at 232 and 333. DEFENDANT’S PURPORTED FACTS 50. Ms. Giuffre intentionally destroyed her “journal” and “dream journal” regarding her “memories” of this case in 2013 while represented by counsel. Ms. Giuffre drafted a “journal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents in her possession. /d. Ms. Giuffre also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. To date, Ms. Giuffre cannot locate the “dream journal.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS The dream journal contained memories of Ms. Giuffre’s dreams. While Ms. Giuffre has looked for this journal, which is wholly irrelevant to this case, she has been unable to locate it. Ms. Giuffre also wrote in a personal journal some of her experiences with Maxwell and Epstein, which were harmful and painful. In an effort to relieve herself of those past painful experiences, Ms. Giuffre followed the advice of a therapist, and burned the journal as a form of cathartic release at a time when she was under no obligation to maintain the personal memorialization of personal and painful experiences. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 205:13206:10. 58

Case 18-2868, Document 281, 08/09/2019, 2628234, Page59 of 66 DEFENDANT’S PURPORTED FACTS S1. Ms. Giuffre publicly peddled her story beginning in 2011. Ms. Giuffre granted journalist Sharon Churcher extensive interviews that resulted in seven (7) widely distributed articles from March 2011 through January 2015. Churcher regularly communicated with Ms. Giuffre and her “attorneys or other agents” from “early 2011” to “the present day.” Ms. Giuffre received approximately $160,000 for her stories and pictures that were published by many news organizations. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Defendant's statement misrepresents history. In 2011, Ms. Giuffre was still in hiding from Epstein and Maxwell in Australia. Ms. Giuffre was not looking to sell anything or even speak with anyone about what had happened to her in her previous life from which she dramatically escaped. Journalist, Sharon Churcher, located Ms. Giuffre and impressed the importance of Ms. Giuffre standing up to those who had harmed her and speak with Federal authorities, which Ms. Gtuffre did in 2011. See McCawley Dec. at Exhibit 31, Redacted 302 GIUFFRE001235-01246. In addition, Churcher impressed the importance of bringing the abuse of Defendant and Epstein to public light to prevent their continued abuse of others. See McCawley Dec. at Exhibit 35, Giuffre003690. After much deliberation, Ms. Giuffre agreed to be interviewed by Churcher, and was compensated for sharing her story, which came at a heavy price of being publicly scrutinized. DEFENDANT’S PURPORTED FACTS a2: Ms. Giuffre drafted a 144-page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, Ms. Giuffre drafted a book manuscript which purported to document Ms. Giuffre’s experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. Ms. Giuffre communicated with literary agents, ghost writers and potential independent publishers in an effort to get her book published. She generated marketing materials and circulated those along with book chapters to numerous individuals associated with publishing and the media. 59

Case 18-2868, Document 281, 08/09/2019, 2628234, Page60 of 66 MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Defendant’s characterization of these activities are out of context and thus misleading. In 2008, Ms. Giuffre received a Victim Notification Letter from the United States Attorney’s office for the Southern District of Florida, see McCawley Dec. at Exhibit 30, GIUFFRE0010202, regarding her sexual victimization by Epstein. Thereafter, in 2011, she sought psychological counseling from a psychologist for the trauma she endured. Also that year, journalist Sharon Churcher sought her out, and traveled half way around the globe to interview her on painful subjects. Ms. Giuffre was interviewed by the FBI in 2011. See McCawley Dec. at Exhibit 31, FBI Redacted 302 GIUFFRE01235-1246. She was also getting psychological help. See McCawley Dec. at Exhibit 38, Lightfoot Records, GIUFFRE00543 1-005438. In that situation, Ms. Giuffre began to draft a fictionalized account of what happened to her. It was against this backdrop of her trauma being unearthed, her steps to seek psychological counseling for it, that she drafted this manuscript. Doing so was an act of empowerment and a way of reframing and taking control over the narrative of her past abuse that haunts her. “Writing ‘I’? has been an emancipatory project for women.” Perreault, Jeanne, ‘““AUTOGRAPHY/ TRANSFORMATION/ ASYMMETRY,” Women, Autobiography, Theory A Reader edited by Sidonie Smith & Julia Watson. Indeed, scholars have written that the act of engaging in autobiography or even accounts loosely based on autobiography, is a process of taking control of one’s own natrative and one’s own self: “Thus a specific recitation of identity involves the inclusion of certain identity contents and the exclusion of others; the incorporation of certain narrative itineraries and internationalities, the silencing of others; the adoption of certain autobiographical voices, the muting of others.” Smith, Sidonie, PERFORMATIVITY, 60

Case 18-2868, Document 281, 08/09/2019, 2628234, Page61 of 66 AUTOBIOGRAPHICAL PRACTICE, RESISTANCE, Women, Autobiography, Theory A Reader edited by Sidonie Smith & Julia Watson. Indeed, even a cursory look at the manuscript penned by Ms. Giuffre informs the reader that she is trying to put forth a more palatable and more empowering narrative to over-write that powerlessness she felt when being abused by Defendant and Epstein. While Ms. Giuffre explored trying to publish her story to empower other individuals who were subject to abuse, she ultimately decided not to publish it. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. 249:1618; 250:19-251:3. DEFENDANT’S PURPORTED FACTS >. Ms. Giuffre’s publicly filed “lurid” CVRA pleadings initiated a media frenzy and generated highly publicized litigation between her lawyers and Alan Dershowitz. On December 30, 2014, Ms. Giuffre, through counsel, publicly filed a joinder motion that contained her “lurid allegations” about Ms. Maxwell and many others, including Alan Dershowitz, Prince Andrew, Jean-Luc Brunel. The joinder motion was followed by a “corrected” motion and two further declarations in January and February 2015, which repeated many of Ms. Giuffre’s claims. These CVRA pleadings generated a media maelstrom and spawned highly publicized litigation between Ms. Giuffre’s lawyers, Edwards and Cassell, and Alan Dershowitz. After Ms. Giuffre publicly alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called Ms. Giuffre a liar and accused her lawyers of unethical conduct. In response, attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT'S FACTS See Ms. Giuffre’s Paragraph 7, supra, explaining why the allegations were necessary and appropriate for multiple reasons. Ms. Giuffre disputes Defendant’s false characterization of these events, and, indeed, the media attention was caused by Defendant’s issuing her defamatory press release. 61

Case 18-2868, Document 281, 08/09/2019, 2628234, Page62 of 66 DEFENDANT’S PURPORTED FACTS 54. Ms. Giuffre formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, Ms. Giuffre, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to Ms. Giuffre, the purpose of the organization is to promote Ms. Giuffre’s professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Ms. Giuffre attempts to promote Victims Refuse Silence at every opportunity. For example, Ms. Guiuffre participated in an interview in New York with ABC to promote the charity and to get her mission out to the public. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre did not form the non-profit Victims Refuse Silence to "speak out on a public controversy," but instead to simply help survivors of sexual abuse and sexual trafficking. In order to provide assistance to victims, Ms. Giuffre attempted to talk about the non-profit’s mission when she had the opportunity to do so. See www.victimsrefusesilece.org. MS. GIUFFRE’S STATEMENT OF UNDISPUTED FACTS 55. Virginia Roberts was born August 9, 1983. See McCawley Dec. at Exhibit 51, Driver’s License GIUFFRE009209. 56. Virginia Roberts turned 18 on August 9, 2001. 57. In 2000, Virginia's father Sky Roberts worked at the Mar-a-Lago. See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 72, 74. 58. Sky Roberts got Virginia a job at Mar-a-Lago in 2000, either months before or just after Virginia's 17th birthday. See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 72, 74; Giuffre Dep. Tr. at 25:19-25:21; 28:10-28:12. 59. The only year in which Virginia was employed at Mar-a-Lago was 2000. See McCawley Dec. at Exhibit 49, MAR-A-LAGO 0173, 0176. 62

Case 18-2868, Document 281, 08/09/2019, 2628234, Page63 of 66 60. Virginia worked at Mar-a-Lago as a spa bathroom attendant. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 61:9-61:24; Austrich Dep. Tr. at 100:3-12. 61. Virginia was not a masseuse at Mar-a-Lago as she had no massage experience. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12; Austrich Dep. Tr. at 34-35, 100-101, 127-128; Figueroa Dep. Tr. at 82:10-15; 168:24-169:1; Sky Roberts Dep. Tr. at 80:7-19; 84:18 -85:1. 62. Maxwell approached Virginia at Mar-a-Lago, and recruited her to come to Jeffrey Epstein's house. See McCawley Dec. at Exhibits 1, 5, and 17, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12; Alessi Dep. Tr. at 94:24-95:2; Sky Roberts Dep. Tr. at 80:7-19; 84:18 -85:1. 63. At the time Maxwell recruited Virginia to Jeffrey Epstein's house, Virginia was either 16 or 17 years old, depending on whether this occurred just before or just after Virginia's birthday. See McCawley Dec. at Exhibit 49, MAR-A-LAGO 0173, 0176. 64. Virginia followed Maxwell's instructions and reported to Jeffrey Epstein's house on the night of the day when Maxwell approached Virginia at Mar-a-Lago. See McCawley Dec. at Exhibits 5 and 18, Guuffre Dep. Tr. at 117:20-118:1; Alessi Dep. Tr. at 96-98; GIUFFRE000102-103 at p. 48-49. 65. Maxwell told Virginia at Mar-a-Lago that Virginia could get paid for giving a massage to Jeffrey Epstein. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12. 66. | When Virginia arrived at Epstein's house, she was taken upstairs to Epstein's bedroom, and instructed by Maxwell and Epstein how to give Epstein a massage. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18; Epstein Dep. Tr. at 74:3-14. 63

Case 18-2868, Document 281, 08/09/2019, 2628234, Page64 of 66 67. Epstein and Maxwell turned the massage into a sexual encounter. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18. 68. Virginia was not a professional masseuse, and was not old enough to be a masseuse in Florida even though Maxwell testified she only hired professional masseuses. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 61:9-61:24, 111:12-111:21, 116:19-117:12; Fla. Stat. § 480.041; Maxwell Dep. Tr. at 23:21-24:9; 31:6-18; 41:7-13; 220:13-221:2; 225:23226:20; 248:5-16; 310:6-17; 383:2-18. 69. Maxwell and Epstein promised Virginia money and a better life in exchange for complying with their sexual demands. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18. 70. Maxwell had sex with Virginia and other females. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 138:17-139:16; Maxwell 07-22-2016 Dep. Tr. at 86:25-87:9; 91:15-91:21. 71. ‘Virginia was trafficked nationally and internationally for sexual purposes. See McCawley Dec. at Exhibits 5, 1, 41? GIUFFRE007055-007161 (Flight Logs); Giuffre Dep. Tr. at 193:22-194:16; 201:24; 204:24:205:5; Alessi Dep. Tr. at 104:9-104:14; Andrew Photo GIUFFRE007167; Spain Photo GIUFFRE007166. dz. Maxwell recruited other non-professionals under the guise of being a masseuse, but in reality only recruited girls for sexual purposes. See McCawley Dec. at Exhibits 5, 16, 4, 1, 18 Giuffre Dep. Tr. at 198:20-199:3; Sjoberg Dep. Tr. at 13-15; Figueroa Dep. Tr. at 88:12-22; Alessi Dep. Tr. at 34; GIUFFRE000105 at 57-58; GIUFFRE000241-242 at p. 212-213. 73. Maxwell was the boss of others whose job it was to recruit minor females for Epstein for sex, such as Sarah Kellen. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 26:10-26:20. 64

Case 18-2868, Document 281, 08/09/2019, 2628234, Page65 of 66 74. Maxwell was a recruiter of underage girls and other young females for Epstein for sex, and was the boss in charge of those females. See McCawley Dec. at Exhibits 16, 4, 21, and 1, Sjoberg Dep. Tr. 8-9, 13-15, 27; Figueroa Dep. Figueroa Dep. Tr. at 200:6-18; 228:23-229:21; Rodriguez Dep. Tr. 169:1-169:4; Alessi Dep. Tr. at 104:15-104:23. Dated: January 31, 2017 By: 23:11-23:20; 34:19-35:3; 98:5-98:12; Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-5202! ' This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 65

Case 18-2868, Document 281, 08/09/2019, 2628234, Page66 of 66 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 31, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10" Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com jpaghuca@hmflaw.com /s/ Sigrid S. McCawley Sigrid S. McCawley 66

Case 18-2868, Document 282, 08/09/2019, 2628236, Pagel of 8 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS V. Ghislaine Maxwell, Defendant. i DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT AND UNDISPUTED FACTS I, Sigrid McCawley, declare that the below is true and correct to the best of my knowledge as follows: l. I am a Partner with the law firm of Boies, Schiller & Flexner LLP and duly licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my Application to Appear Pro Hac Vice. 2: I respectfully submit this Declaration in Support of Plaintiff's Response to Defendant’s Motion for Summary Judgment and Undisputed Facts. 3 Attached hereto as Sealed Exhibit | are true and correct copies of Excerpts from June 1, 2016 Depositions of Juan Alessi. 4. Attached here to as Sealed Exhibit 2 is a true and correct copy of Excerpts from June 23, 2016, Deposition of James Austrich. 5. Attached hereto as Sealed Exhibit 3 is a true and correct copy of Excerpts from September 9, 2016, Deposition of Jeffrey Epstein. 6. Attached hereto as Sealed Exhibit 4 is a true and correct copy of Excerpts from June 24, 2016, Deposition of Tony Figueroa (Volumes I and II).

Case 18-2868, Document 282, 08/09/2019, 2628236, Page2 of 8 i Attached hereto as Sealed Composite Exhibit 5 are true and correct copies of Excerpts from May 3, 2016 and November 14, 2016, Deposition of Virginia Giuffre. 8. Attached hereto as Sealed Exhibit 6 is a true and correct copy of Excerpts from November 18, 2016, Deposition of Ross Gow. 9, Attached hereto as Sealed Exhibit 7 is a true and correct copy of Excerpts from June 20, 2016, Deposition (iii. 10. Attached hereto as Sealed Exhibit 8 is a true and correct copy of Excerpts from January 25, 2017, Deposition of Sarah Kellen. 11. Attached hereto as Sealed Exhibit 9 is a true and correct copy of Excerpts from November 29, 2016, Deposition of Peter Kent. 12, Attached hereto as Sealed Exhibit 10 is a true and correct copy of Excerpts from January 17, 2017, Deposition of Nadia Marcinko. 13. Attached hereto as Sealed Composite Exhibit 11 are true and correct copies of Excerpts from April 22, 2016 and July 22, 2016, Depositions of Ghislaine Maxwell. 14. Attached hereto as Sealed Exhibit 12 is a true and correct copy of Excerpts from May 24, 2016, Deposition of Lynne Trudy Miller 15. Attached hereto as Sealed Exhibit 13 is a true and correct copy of Excerpts from June 21, 2016, Deposition Joseph Recarey. 16. Attached hereto as Sealed Exhibit 14 is a true and correct copy of Excerpts from June 10, 2016, Deposition of Rinaldo Rizzo. 17. Attached hereto as Sealed Exhibit 15 is a true and correct copy of Excerpts from June 3, 2016, Deposition of David Rodgers. 18. Attached hereto as Sealed Exhibit 16 is a true and correct copy of Excerpts from May 18, 2016, Deposition of Johanna Sjoberg.

Case 18-2868, Document 282, 08/09/2019, 2628236, Page3 of 8 19. Attached hereto as Sealed Exhibit 17 is a true and correct copy of Excerpts from May 20, 2016, Deposition of Sky Roberts. 20. Attached hereto as Sealed Composite Exhibit 18 are true and correct copies of Excerpts from September 8, 2009, Depositions of Juan Alessi (GIUFFRE000102-000103; GIUFFRE000105; GIUFFRE000241-000242). 21. Attached hereto as Sealed Exhibit 19 is a true and correct copy of Excerpts from February 16, 2010, Deposition of Janusz Banasiak (GIUFFRE00443 1-004432; GIUFFRE004437-004438; GIUFFRE004477). 22. Attached hereto as Sealed Exhibit 20 is a true and correct copy of Excerpts from October 20, 2009, Deposition of Louella Rabuyo (GIUFFRE004386). 23. Attached hereto as Sealed Composite Exhibit 21 is a true and correct copy of Excerpts from July 29, 2009 and August 7, 2009, Deposition of Alfredo Rodriguez (GIUFFRE000936-000937; GIUFFRE000942; GIUFFRE000953-000954; GIUFFRE000974; GIUFFRE000978; GIUFFRE000996; GIUFFRE000999-001000; GIUFFRE001003). 24. Attached hereto as Sealed Exhibit 22 is a true and correct copy of August 1, 2016, Defendant’s Privilege Log. 2D: Attached hereto as Sealed Exhibit 23 is a true and correct copy of September 15, 2016, Expert Report of Professor Terry Coonan. 26. Attached hereto as Sealed Exhibit 24 is a true and correct copy of September 15, 2016, Expert Report of Doctor Bernard Jansen. 27. Attached hereto as Sealed Exhibit 25 is a true and correct copy of November 28, 2016, Expert Report of Peter Kent 28. Attached hereto as Sealed Exhibit 26 1s a true and correct copy of January 2, 2015, Email Correspondence (GM_00068).

Case 18-2868, Document 282, 08/09/2019, 2628236, Page4 of 8 29. Attached hereto as Sealed Exhibit 27 is a true and correct copy of Excerpts of Palm Beach School County Records (GM_00888-00898). 30. Attached hereto as Sealed Exhibit 28 1s a true and correct copy of Excerpts of Message Pads (GIUFFRE001388; GIUFFRE001409; GIUFFRE001412-4213; GIUFFRE001417-18, GIUFFRE001421; GIUFFRE001423; GIUFFRE001426-1428; GIUFFRE001432-1433; GIUFFRE001435; GIUFFRE001446; GIUFFRE001448-1449; GIUFFRE001452-1454; GIUFFRE001456; GIUFFRE001462; GIUFFRE001474; GIUFFRE001563). 31. Attached here to as Sealed Exhibit 29 is a true and correct copy of Epstein’s Black Book (GIUFFRE001573-GIUFFRE001669). a2: Attached hereto as Sealed Exhibit 30 is a true and correct copy of September 3, 2008, U.S. Attorney Victim Notification Letter (GIUFFRE002216-002218). a) Attached hereto as Sealed Exhibit 31 is a true and correct copy of July 5, 2013, Federal Bureau of Investigation Interview (GIUFFRE001235-001246). 34. Attached hereto as Sealed Exhibit 32 is a true and correct copy of Handwritten Note from Defendant. (GIUFFRE003191-003192). 35. Attached hereto as Sealed Exhibit 33 is a true and correct copy of July 2001 New York Presbyterian Hospital Records (GIUFFRE003258-003290). 36. Attached hereto as Sealed Exhibit 34 is a true and correct copy of a February 17, 2011, Email Correspondence to Sharon Churcher (GIUFFRE003678). a1: Attached hereto as Sealed Exhibit 35 is a true and correct copy of February 13, 2011, Email Correspondence to Sharon Churcher (GIUFFRE003690). 38. | Attached hereto as Sealed Exhibit 36 is a true and correct copy of February 25, 2011, Email Correspondence to Sharon Churcher (GIUFFRE003731).) 39. Attached hereto as Exhibit 37 1s a true and correct copy of a Passport Application

Case 18-2868, Document 282, 08/09/2019, 2628236, Paged of 8 (GIUFFRE004721). 40. Attached hereto as Sealed Exhibit 38 is a true and correct copy of Judith Lightfoot Psychological Records (GIUFFRE00543 1-005438). 4]. Attached hereto as Sealed Exhibit 39 is a true and correct copy of July 25, 2006, Palm Beach Police Department Incident Report (GIUFFRE005614-005700). 42. Attached hereto as Sealed Exhibit 40 1s a true and correct copy of an Amazon Receipt (GIUFFRE006581). 43. Attached hereto as Sealed Exhibit 41 is a true and correct copy of David Rodger’s June 3, 2016, Deposition Exhibit 1, Flight Log, (GIUFFRE007055-007161). 44. Attached hereto as Sealed Exhibit 42 are true and correct copies of Photographs (GIUFFRE007 162-7182). 45. Attached hereto as Sealed Exhibit 43 is a true and correct copy of Travel Documents to Thailand (GIUFFRE00741 1-GIUFFRE007432). 46. Attached hereto as Sealed Exhibit 44 1s a true and correct copy of Walkthrough Video CD (GIUFFRE007584). 47. Attached hereto as Sealed Exhibit 45 is a true and correct copy of West Palm Beach Contact List (GIUFFRE007834-GIUFFRE007847). 48. Attached hereto as Sealed Exhibit 46 is a true and correct copy of October 23, 2016, Social Security Administration records (GIUFFRE009176-GIUFFRE009179). 49. Attached hereto as Sealed Exhibit 47 is a true and correct copy of November 7, 2016, Employment Records from Courtyard Animal Hospital (GIUFFRE009203). 50. Attached hereto as Sealed Exhibit 48 is a true and correct copy of January 2, 2015, Email Correspondence (RG (UK) 000009). a1, Attached hereto as Sealed Exhibit 49 are true and correct copies of Termination

Case 18-2868, Document 282, 08/09/2019, 2628236, Page6 of 8 Documents (MAR-A-LAGO 0173 & MAR-A-LAGO 0176). az: Attached hereto as Sealed Exhibit 50 1s a true and correct copy of January 2, 2015, Joinder Motion (GIUFFRE000319-000333). a>: Attached hereto as Sealed Exhibit 51 is a true and correect copy of Virginia Roberts Driver License (GIUFFRE009209), I declare under penalty of perjury that the foregoing 1s true and correct. /s/ Sigrid McCawley Sigrid McCawley, Esq.

Case 18-2868, Document 282, 08/09/2019, 2628236, Page/7 of 8 Dated: January 31, 2017. Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-5202! ' This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation.

Case 18-2868, Document 282, 08/09/2019, 2628236, Pages of 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 31st day of January, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10" Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com jpaghuca@hmflaw.com /s/ Sigrid McCawley Sigrid McCawley

EXHIBIT | (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page2 of 883 Page l UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS SS ee xX VIRGINIA L. GIUFFRE, Plaintiff, V. GHISLAINE MAXWELL, Defendant. ee xX June 1, 2016 9:12 a.m. CONFIODENTIAL Deposition of JOHN ALESSI, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Florida Q. A. Q. man name A. Q. for Mr. A. I cannot 1990/'91 for him. Q. correct? A. Q. A. December Q. A. Document 283, 08/09/2019, 2628241, Page3 of 883 Page 9 JOHN ALESSI You're ready to start, correct? Yes. Can you tell us your current address? RE Boynton Beach, 33472. And your date of birth? eS And was there a time when you worked for a d Jeffrey Epstein? Yes. And can you tell us when you began working Epstein? I began working for Mr. Epstein part-time. exactly tell you the date, but it was , probably. I worked a total of 13 years Okay. So you began in 1990 part-time, Right. And you stopped working for him when? I stopped working for him on 3list, 2001. I was out -- yes, 2001. Okay. The end of 2001. I left the last day of MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page4 of 883 Page 10 JOHN ALESSI the year. Q. Okay. I know that it's been a long time. A It's been a long time. or I know. So I'm going to ask that you refer to the statement that you provided to the police November 21st, 2005, and please go to page 5. I just want you to start reading at line 2 and 3, and tell me if that refreshes your recollection as to your time or duration of employment. Bis You're right. It was 2002, then. 2002. QO. So sometime in 1990, you were a part-time employee? A. Uh-huh. QO. And you worked until December 31st, 2002; is that right? A. Yes. Q. Okay. And is it also correct that you began full-time employment with Mr. Epstein on January lst, 1991, as stated in that report? Piss Yes. Q. Prior to 1990, who did you work for? as Prior to 1990, I had a company, a maintenance company, myself, my own company, Alessi Maintenance. And before that, I worked for another MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page5d of 883 Page ll JOHN ALESSI family, the Radi family in Palm Beach. Q. Did you ever work for a man named Les Wexner? A. I did some work for him in his mother's house. Q. Where was that? Pes Palm Beach. What year? Before -- before I came to work for Jeffrey. Q. Is that who recommended that you work for Jeffrey Epstein? A. I guess so. Q. Okay. When you started with Jeffrey Epstein, what were your job duties? As I was doing maintenance. I was doing building and rebuilding and maintenance work basically. Because he just bought the house at that time. And because of Mr. Wechsler knowing me, they recommend me to go to the house and take a look at the house. And we start tearing the house down, basically, at the beginning of my job. Q. Did you assist in the teardown? A. Yes. Q. Okay. So your job duties then was that of a maintenance? MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page6é of 883 Page 12 JOHN ALESSI x. Maintenance, building. Q. Got it. And did you meet Mr. Epstein when you were -- in 1990? A. Yes, I met him. Q. Okay. And in 1991, who made the decision for you to become a full-time employee? A. Jeffrey. Q. And as a full-time employee initially, what was your job? As IT was basically maintenance, the same thing as I was doing with -- I was exclusively working for him. I was full-time working for him as maintenance, because the house was still on renovation, and he wanted me there. Q. Okay. And how was your relationship with Mr. Epstein back then, 1991? Be Great. No problem. QO. It was good? Ax It was good. QO. Did he have a girlfriend back then, in 1991? MR. PAGLIUSCA: Object to the form and foundation. MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page? of 883 Page 13 JOHN ALESSI You can answer the question. Occasionally, I'll need to object for the record in case we need to have a discussion about this with the judge. And so that's just me preserving those objections. THE WITNESS: Yes, he had a girlfriend. Her name was Dr. Andersson, Eva Andersson. And she was there just for a few months after I came to the house. BY MR. EDWARDS: QO. And how was your relationship with Dr. Andersson? Be Fine. Q. Okay. And at the time when Mr. Epstein was -- at the time when Dr. Andersson was Jeffrey Epstein's girlfriend, did you see any other female companions around the house? Be Eventually -- they have a lot of guests, too. They did have guests coming in. But I can't remember exactly who. It's a socialite. So they have friends. Q. At the time when Dr. Andersson was Mr. Epstein's girlfriend, was Mr. Epstein getting massages? MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Pages of 883 Page 14 JOHN ALESSI MR. PAGLIUSCA: Object to the form and foundation. THE WITNESS: I think so. I was not involved in the house, inside of the house that much. But they always got massages. Always. BY MR. EDWARDS: QO. Okay. I'm talking about the time period when Dr. Andersson was there. A. Yes, they got massages. Q. Okay. So do you remember other female visitors when Dr. Andersson was Mr. Epstein's girlfriend? As I don't remember. I remember people being there, visitors, but I cannot remember that far. Q. Okay. After -- did there come a point in time when Dr. Andersson was no longer Mr. Epstein's girlfriend? Bs Right. Q. Yes? Piss Yes. Q. And did he -- did he have a new girlfriend? MR. PAGLIUSCA: Object to form and foundation. MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page9 of 883 Page 23 JOHN ALESSI QO. Ald. 2ight. Who was in charge of the Palm Beach house? A. I was. QO. Ald. right. Who was your direct supervisor? A. Mr. Epstein. He would deal with me directly, or if he was not available, Ms. Maxwell. Q. Okay. I want you to go to Exhibit 3 and page -- page 179, line 8. and the the Ms. the A. Line 8, "QUESTION: And then Maxwell came she took over you as your immediate supervisor? Yes. That's correct. Yes. She became Supervisor not only for this house, but for all homes. QO. Okay. So your immediate supervisor was Maxwell? ae Ms. Maxwell. But if Mr. Epstein was at house, I would never go to Ms. Maxwell; I would go to him directly, or he would come to me. end Ms. Q. Okay. At some point in time towards the of your tenure, did you come to resent Maxwell? MR. PAGLIUSCA: Object to the form and foundation. MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page10 of 883 Page 28 JOHN ALESSI Q. And where did the massage therapists -where did they come from? As Most, they came from Palm Beach. Palm Beach County. QO. And over the course of that 10-year period of time while Ms. Maxwell was at the house, do you have an approximation as to the number of different females -- females that you were told were massage therapists that came to the house? MR. PAGLIUSCA: Object to form and foundation. THE WITNESS: I cannot give you a number, but I would say probably over 100 in my stay there. BY MR. EDWARDS: Q. And many of the times would the females come only one time and not return? MR. PAGLIUSCA: Object to form and foundation. BY MR. EDWARDS: QO. Let me ask that a different way. Were there times when some of these females that would come to the house, and you were told that they were massage therapists, would come MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page11 of 883 Page 30 1 JOHN ALESSI 2 BY MR. EDWARDS: 3 Q. Okay. And who would find the massage 4 therapist to bring to the house? 5 A. They would call me in my office, and they 6 would say, Get me a massage at 10:00 with this 7 person. 8 I have a list of the massage therapists, a 9 Rolodex, or a card, and I would call them for the 10 specific time they want a massage. And I would do 11 that. 12 QO. I don't think I asked the right -- the 13 question that I was looking to ask, so let me go 14 back. 15 Did you go out looking for the girls -16 A. No. 17 Q. -- to bring -18 A. Never. 19 Q. -- as the massage therapists? 20 A. Never. 21 OO; Who did? 22 Bs Ms. Maxwell, Mr. Epstein and their 23 friends, because their friends relayed to other 24 friends they knew a massage therapist and they would 25 send to the house. So it was referrals. MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page12 of 883 Page 34 JOHN ALESSI foundation. Hold on. That misstates what is happening in this deposition, because the word "recruit" was introduced by the lawyers in this deposition. So I object to your characterization of the testimony. BY MR. EDWARDS: Q. I'll read for you the question and the answer. The question was: "QUESTION: When did that role get transferred from you to Ms. Maxwell, the role of looking after girls or calling the girls? "ANSWER: I didn't look after -- out for girls. Ms. Maxwell was the one that recruit. I remember one occasion or two occasions she would say to me, John, give me a list of all the spas in Palm Beach County, and I will drive her from one to the other to PGA in Boca; and she would go in and drop credit cards -- not credit cards but business cards, and she would come out. And then we'd go to -- she will recruit the girls. Was never, never done by me or Mr. Epstein or anyone else that I know of." Is that truthful testimony? A. It is truthful; however, I think MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page13 of 883 Page 35 JOHN ALESSI “recruiting, for myself, for my point of view, is hiring immediately and recruit the person. I think she was looking for massage therapists. She was looking for the best kind. She went -- and you're right, I went one time with her, or twice maybe, to different spas and different clubs, great clubs, I mean, in Boca, in Fort Lauderdale, in -- in Palm Beach. She was looking for the best massage therapists available. How she find these girls, I don't know. I just drove there. I just was the driver. I never was involved with any of the offerings or negotiations or meeting these girls. Never. Q. Okay. Ms. Maxwell was the one that would meet the girls? A. Yeah. Q. Okay. Did you ever check any of the IDs for any of these girls? as I was not -- that was not in my everyday things to do. It was not. Q. That was just not part of your job? ae That was not my job. Q. Did Ms. Maxwell take photographs while she was at the Palm Beach house? MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page14 of 883 Page 52 JOHN ALESSI MR. PAGLIUSCA: Object to form and foundation. THE WITNESS: Himself. Himself. BY MR. EDWARDS: Q. And you do not know the ages of the various massagists, right? A. No. Q. Did you have occasion to clean up after the massages? Be Yes. oF Okay. And that is after both a massage for Jeffrey Epstein, as well as clean up after a massage that Ghislaine Maxwell may have received? ae Yes. QO. And on occasion, after -- in cleaning up after a massage of Jeffrey Epstein or Ghislaine Maxwell, did you have occasion to find vibrators or sex toys that would be left out? MR. PAGLIUSCA: Object to form and foundation. THE WITNESS: Yes, I did. BY MR. EDWARDS: Q. Can you describe the types of vibrators or sex toys that you found left out after a massage MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page15 of 883 Page 53 JOHN ALESSI that Jeffrey Epstein had just received or Ghislaine Maxwell had just received? MR. PAGLIUSCA: Object to form and foundation. THE WITNESS: It was probably two to three times, I would say. It was not all the time. I would find things like a dildo, it's called a double. I hate to say it because these ladies. But I find these things, put my gloves on, took it out and rinse it, and put it in Ms. Maxwell's closet. BY MR. EDWARDS: QO. Why would you put the dildo or sex toy in Ms. Maxwell's closet? Ps Because I knew that's where they were kept. Q. How did you know that the sex toys were kept in Ms. Maxwell's closet? ie Because I know where everything was in that house. Every single room, every single thing, it was a place, it was placed by me, by the cleaning lady or my wife. Every -- everything that happened in that house, I knew it. Q. Who showed you where the dildo or sex toys MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page16 of 883 Page 54 JOHN ALESSI were kept in the house the first time? MR. PAGLIUSCA: Object to form and foundation. THE WITNESS: Nobody. Nobody show me. BY MR. EDWARDS: Q. You just saw it? x. I saw it. Q. So you knew where to put it back? ie Yeah. We had to open the closet, clean the closet, put the clothes in place, put the shoes in place, put everything in place. So it was a matter of tidying things up. Q. Did you ever find any costumes? Pus I saw one shiny black costume, but I didn't even know -Q. Where did you see it? ‘ The same place. A Q. In Ms. Maxwell's closet? A 0 : Yes. ‘ And where was Ms. Maxwell's closet in the house? as In the house? It was in the opposite side of his bathroom. It was her bathroom in the master bedroom. It was in the middle. So it was on the MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page1/7 of 883 Page 94 JOHN ALESSI BY MR. EDWARDS: Q. That demonstrates that she was, I believe, terminated from her employment in 2000. My question to you is: Do you remember what time of year or what month it would have been, whether spring, summer, fall, winter; January, February, December? Bis Of what year? Q. Of 2000, that you would have gone to the Mar-a-Lago? A. It wasn't 2000. MR. PAGLIUSCA: Object to form and foundation. BY MR. EDWARDS: Q. Okay. Do you think it was a different year that you went to Mar-a-Lago? A Yes. Q. Okay. What year do you believe that you went to the Mar-a-Lago to pick Virginia up? Pus I think it was 2000 and -- I think it was the summer of 2002. Q. Okay. As Summer, because I remember that day that I was Sweating like hell in the -- in the car, waiting MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page18 of 883 Page 95 JOHN ALESSI for Ms. Maxwell to come out of the massage. QO. Okay. So what month of the summer do you remember it being? A. I think in June, July, maybe, 2001. Q. 2000 and what? A. 2001. OQ. June, July, 2001, that's when you believe that it was? A. Yes. Q. Okay. And do you remember the month -A. No, sorry. Sorry. Not 2001. We left in December 31st. It was 2000 -- the last year that I was working for Jeffrey, when I met Virginia. Q. Your recollection, as you sit here today -A. It was 2002. Q. -- is that it was June or July of 2002 -As 2002. Q. -- when you met Virginia Roberts at the Mar-a-Lago? Ax My recollection. Q. Okay. And other than the fact that you were sweating, what else tells you what month that it was that you remember meeting her at the MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page19 of 883 Page 96 JOHN ALESSI Mar-a-Lago? A. It was -- I know it was summer of 2002, and she spoke to -- far away. I wasn't -- I was in the driveway, and she was far away talking to Virginia. She spoke to her maybe five minutes. QO. Okay. a And she came to the car, and we went home. In the afternoon, about 4:00 or 5:00 in the afternoon, the same day, Virginia came to the house. Q. Who brought her to the house? A. I don't know. She came to the back door, I remember. And she was dressed differently. She came to the house. Q. When you first arrived to the Mar-a-Lago with -- are you driving the car and Ms. Maxwell is in the passenger seat? Piss Yes. QO. And could you see Virginia Roberts from the car? Piss Yes. QO. Where was she sitting or standing? How far away from the car? Ai. She was standing right in front of the driveway. This is the Mar-a-Lago, the house, and MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page20 of 883 Page 97 JOHN ALESSI here is the spa, and the driveway that's here. I was parked this way, and I would see her with Ms. Maxwell, talking. Q. Did you -A. I could not hear what they were saying, but I did see it. QO. Did you park the car or did you stop right there and -Es I parked the car because we are not allowed to go into Mar-a-Lago. Q. Okay. Let me finish my question. Did you park the car in a parking space in the parking lot or did you just stop on the side of the road and Ms. Maxwell got out? Be Mar-a-Lago has a -- has a long wide driveway, and on the right of the driveway is -- is the parking spots like this or something. And I parked in one of those spaces. And waiting for her, IT think it was over an hour that I wait for her. Q. Okay. So did you watch her first talk to -a No. At the end. Right at the end, before -- when she was leaving. Q. So Ms. Maxwell gets out of the car. And MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page21 of 883 Page 98 JOHN ALESSI when you're pulling up to the Mar-a-Lago, could you see Virginia Roberts then? A. No. No. Q. So after you wait an hour, Ms. Maxwell is coming out? A. And then she saw Virginia and she stopped -- she went to her, she talked to her, she came back to the car. Q. And prior to that day, you had never seen Virginia at the house? A. Never. Never. Q. Okay. Did Ms. Maxwell tell you that Virginia's father worked at the Mar-a-Lago? Ais I don't think so. I think it was -- I think we find out later, after the -- she says, My father works -- I think it was from Virginia, that She says her father works at Mar-a-Lago. It is information from her. I don't think it was Ms. Maxwell that told me anything. She don't have to -- she don't have to talk to me. I mean, Ms. Maxwell will not go and talk to me about this -these people's family. I don't know. She never did. Q. Okay. I only have to go by what I have. MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page22 of 883 Page 103 JOHN ALESSI I don't remember that day, how she got home. I don't know. I can't remember. QO. After that day, do you recall that she started coming to the house more frequently? A. Yes, she did. Q. In fact, did she start coming to the house approximately three times a week? Bis Yes, probably. Q. And at times, would you go pick her up? ae Yes. This happened maybe twice, three times. QO. And at times, would you take her home? As Yes. QO. And did there come a point in time where Virginia starting bringing other girls with her? MR. PAGLIUSCA: Object to form and foundation. THE WITNESS: That was maybe two weeks before we left. I saw her bringing some friends with her to the house. And I cannot remember how many times, but I was at the end of our stay. BY MR. EDWARDS: Q. At the end of her [Sic] stay, you saw when MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page23 of 883 Page 104 JOHN ALESSI she would come over to the house, she would bring certain friends who were girls -MR. PAGLIUSCA: Object to form and foundation. BY MR. EDWARDS: QO. -- to the house, right? a Yes, females, yes. QO. Do you know how long Virginia had been coming over to the house before she started traveling on an airplane with Ghislaine and Jeffrey? MR. PAGLIUSCA: Object to foundation. THE WITNESS: Not too long. I don't think it was too long after that. BY MR. EDWARDS: Q. Would you drive her to the airport with them? is Occasionally, I think so, yes. I would drive everybody to the airport. My wife would drive the chefs, the service people, the luggage to Jet Aviation. Q. Is that where Mr. Epstein kept his plane, Jet Aviation? Ais Yes. QO. At some point did Ghislaine Maxwell become MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page24 of 883 Page 141 JOHN ALESSI MR. PAGLIUSCA: Seven. MR. EDWARDS: Seven? (The referred-to document was marked by the court reporter for Identification as Deposition Exhibit 7.) MR. EDWARDS: I apologize, Jeff. I just can't find a copy right now. MR. PAGLIUSCA: T have it. MR. EDWARDS: OkKay. BY MR. EDWARDS: QO. So this is a composite exhibit. It is four pages. The first one that you're looking at Should be -- do you have SAO 01456? MR. PAGLIUSCA: Yes. MR. EDWARDS: OKay. BY MR. EDWARDS: Q. Does the format of this look familiar to you? A. Yes. It looks like the books that we used to have that has -- the message books. Q. How would that work? How would that process work? As Somebody called, you write it down, and you take the -- you leave the copy in the -- in the MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page25 of 883 Page 175 JOHN ALESSI many things? A. Yes, she did. QO. Interesting buildings? A. No. She -- she liked -- she had a dog, and she took a lot of photographs of her dog. And us. And she took photographs of the cars and the house. Everything inside. She had an album full of photographs of people, young girls, girls. And I remember that she had. Like a hobby. Q. Right. You never saw any pictures that were very upsetting to you, though, correct? A. No. No. Q. Okay. And the pictures that you saw were sort of -- would you describe them as being artistic kind of pictures? MR. EDWARDS: Objection, counsel testifying. THE WITNESS: I think so. I don't think they were pornographic. I don't think it was any vaginal or things, you know, female parts showing. It was some girls were topless, taking the sun. It was a beautiful house, it was a beautiful setting, so she took a lot of MAGNA®S

OF WN FE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page26 of 883 Page 236 JOHN ALESSI CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, the undersigned authority, certify that JOHN ALESSI personally appeared before me and was duly sworn. WITNESS my hand and official seal this lst day of June, 2016. Kelli Ann Willis, RPR, CRR Notary Public, State of Florida Commission FF928291, Expires 2-16-20 +++ + ¢+ 4+ 4+ 4+ 4+ 4+ 4+ 4+ 4+ 4+ 4+ 4+ 4+ 4 CERTIFICATE STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime Reporter do hereby certify that I was authorized to and did stenographically report the foregoing deposition of JOHN ALESSI; that a review of the transcript was not requested; and that the transcript is a true record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am Ia relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this lst day of June, 2016. KELLI ANN WILLIS, RPR, CRR MAGNA®S

EXHIBIT 2 (Filed Under Seal)

4 NO OJ HS Ol OY ~ CO WO 10 a eZ Ales, 14 iS 16 ey ile Kg Zz) Zadk Ze Zo 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page28 of 883 UNTTED. STATES. DISTRICT. COURT for the SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS VIRGINIA -GIUPFRE, Piven ara» VS. GHISLAINE MAXWELL Defendant. VLDEO=DEPOSLTION OF: EE RTI. aes REPORTED: Bx DATE: 2vN iD TLE JAMES MICHARL AUSTRICH Defendant Karla Layfield, RMR Stenographic Court Reporter Notary Pub Lac State of Florida at Large JUme Zor 26s O20S oe thz PLACE: Owen & Associates Court Reporters 108 N. Magnolia Avenue, Suite 501 Ocala, Florida APPEARANCES: Laura A. Menninger, Esquire HADDON, MORGAN & FOREMAN, PC 150 East 10th Avenue Denver, oOlorado 20205 Attorney for Defendant Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, FISTOS & LEHRMAN, PL 425 Andrews Avenue, Suite 2 Port: beuderdale, Phorida 33301 ALeOrney Lor Plaancla. Also Present: Kenneth Sarsony, Videographer VirTGinue GluEtre Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OJ HS Ol OY ~ CO WO 10 Ti eZ Ales 14 sie 16 ey ike ig Z0 Zod Ze 20 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page29 of 883 16 A Less Q Was it is a franchise, if you know? A I know when I first started there, they were corporate, but then they were a franchise. They were bought out. But I'm not sure if when I got there they were a franchise or not. @ Got it. Do you know if Ms. Roberts had any previous employment before she worked at Taco Bell? A I think by the apartment, she worked for KFC for a little while. MS. MENNINGER: Are you looking at Ms. Roberts? THE WLINE So? Lm thinking, J. can’r remember. I remember something with KFC. They had one really close to us. I think she worked there for a tiny, tiny bit. I'm not sure. MS. MENNINGER: £OKay. BY MS. MENNINGER: O Betore: tne: Taco Beall’? A Or she could've applied there. It's just in my head. She might have just applied there, and didn't get it, and that's why I brought her to Taco Bell. e Okay. A Because we were both the night managers. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OJ HS Ol OY ~l CO WO 10 Ti eZ Ales 14 sie 16 7 18 ig Zz) Zadk Ze Zo 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page30 of 883 tO D> 1O A Q Lg NOs. Do you Know about what years this was? Not really. Do you know about how old you were? When, what? I'm just focused on the period of time in which you were living at her parent's house in the trailer. A I was probably 18 when we moved in there. Q And you said you were only there for a couple of months? A Not that I remember. Like, it might have been a little longer. I'm not sure. QO Were you engaged to Ms. Roberts? A Les QO When did you become engaged to her? A When we were living in Oakland Park. Q Tell me about the engagement. How did it come about? A Well, we fell in love, and -- I believe it was Valentine's Day when I proposed. Q A 1O > 1O Did you have a ring? Veo. Did she accept? Yes. How long were you engaged? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OJ HS Ol OY ~ CO WO 10 Ti ie i 14 i 16 ey ike ig Z0 Zod Ze Zo 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page31 of 883 30 A Yes -- well, for a while. I mean, I know at the end, I wasn't working anywhere. Q Why weren't you working? A I don't remember the exact reason. Q Had you quit? A I believe so. I know the pet store let me go for walking on to the other side talking to somebody. But I don't remember why I left Dunkin' Donuts. Q Do you believe that you were fired from Dunkin' DOnILes 2 A No. That pet store was the only time anybody ever fired me. Q Thac-Wikl StLek 1m your brain, A Yeah. QO At the time that you left the pet store, was Ms. Roberts still working there? A ees QO And how long do you recall her working there? A NOt kong. QO IT hate to do this to you, but what does "not long" mean to you, weeks, months, days? A Over a month. That's really all I can Say. Maybe over a month before she went to work at the Mer=e=lago: Or Dona.La Trump's Country -ClLupQO Did she leave the pet store to go work at Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

}4 NO GJ HS Ol OY ~ CO WO 10 Ti eZ Ales 14 sie 16 ey ike ig Z0 Zod Ze aS 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page32 of 883 34 BY MS. MENNINGER: QO Did you know her friend by the name of Tony Figueroa? A Somewhat. QO Tell me what you remember about Tony Figueroa. A Other than him being an idiot, not much. Q Did you have any interactions with Mr. Figueroa? A Very little. Q When do you recall seeing him, like, in what city, I mean? A Up in West Palm Beach. QO Did he come over to your apartment? A I believe so. Q Did you believe them to be having a relationship? A At the very end when I left, yes. QO Was that one of the reasons for your leaving? A One of them. O What were the others? A Well, after I found out about that, that's when I heard about all the other stuff that was happening. Q A What did you hear about all the other stuff? Well, I mean, after she went to work for Mar-a-Lago then she was, I guess, recruited to go work for Jeffs omething. I don't remember his last name. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO GJ HS Ol OY ~ CO WO 10 Ti ie i 14 i 16 ey 18 ig Z0 el Le Zo 24 LS Case 18-2868, Document 283, 08/09/2019, 2628241, Page33 of 883 0 QO Is that what she told you "she was recruited"? A Yeah. Well, she didn't use those words. But I don't know why else anybody would take -- like, they hired her over there as a massage therapist, but she didn't have any experience. QO pc Marea LegG == A At Mar-a-Lago, yes. Then all of a sudden one day, she was working for Jeff, whatever his name was. QO Let me just take a step back. You found out towards the end of your relationship with Ms. Roberts that she was then having a relationship with Mr. Figueroa. Is tet rion: A L don't. know 11 120 -was.a rebationship,. But, yes. Q Enough to cause you to think you didn't want to be engaged anymore? A Lees Q Did you and Ms. Roberts have a fight at that time? A VeG« Q What do you remember about the fight? What do you 2~ecall? A I don't recall. I remember us having a fight and then leaving not too long afterwards. Q You referred to finding out all this other stuff Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OJ HS Ol OY ~ CO WO 10 a eZ Ales, 14 iS 16 ey 18 Lg Zz) Zod Ze Zo 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page34 of 883 go 7. Q When you got the apartment in Oakland Park, you COL, 2c WLU Virginia? A Well, yeah. She was living with us -- and Mario. MS. MENNINGER: All right. I think that's all I have. MR. EDWARDS: Okay. THE VIDEOGRAPHER: We're going off the record. “Ias concludes disc one, volume one oF the video-deposition of James Michael Austrich. We're going off the record. The time is apOrOximealely Lil:z0. a.m. (Break taken.) THE VIDEOGRAPHER: We're back on the record with disc two, volume one, of the videodeposition of James Michael Austrich. And the time 1s approximately 11:23 a.m. Thank you. CROSS-EXAMINATION BY MR. EDWARDS: QO Mr. Austrich, as you know, my name is Brad Edwards, and I represent Virginia. A Vea. QO I'm going to ask you some follow-up questions to the questions that you were asked previously. Aled See ice Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OJ HS Ol OY ~ CO WO 10 I. i AKG 14 i” 16 ey ike ig Z0 Zod Ze aS 24 ves) Case 18-2868, Document 283, 08/09/2019, 2628241, Page35 of 883 98 how long we lived there. Q Okay. At some point in time, though, while you're living on her parent's property, it becomes 1999? A Yeah, I believe. Q Okay. And so when you started living at her parent's property, you're 18, she's 15, but at some point in time you turn 19 and she turned 16? A Les: Q Okay. And at some other point in time, she leaves the job at the pet store? A Pet store, yeah. Q And goes to work at the Mar-a-Lago? A Yes. At Donald Trump's country club, yeah. QO Okeye Donalo. Trumo* Ss country club a6 Called the Mar=a=Lago MS. MENNINGER: Objection. THE WITNESS: Yeah, that's what I always remember it as. Yes. BY MR. EDWARDS: Q ice e) elo wemmianine | ge MS. MENNINGER: Objection, leading. I do get a chance to object. Leading. BY MR. EDWARDS: Q When you used the term "Mar-a-Lago" and used the ’ term "Donald Trump's country club," are we talking about Owen & Associates Court Reporters P«O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OJ HS Ol OY ~ CO WO 10 ial i AS 14 i 16 7 ie ig Z0 Zod Ze aS 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page36 of 883 10.0 A But if she had to get clean for her job, she would have gotten clean for the job. Q Okay. Do you remember her being hired as a bathroom attendant there, a Locker room attendant? A Now that you're saying that, some kind of attendant sounds familiar. But I don't really remember. All I remember is for the massage. As a -- I don't remember exactly what she got hired for at Donald Trump's place. But I just remember the masseuse thing. But as you're saying "the attendant," the attendant sounds familiar because I doubt her father would hire her as a massage therapist without knowing anything. QO So you had known her for some period of time before she gets this job at the Mar-a-Lago, right? A Ragit, QO Did she have any massage therapy training whatsoever? A No. QO Ever given a massage to anyone? A Not that I remember. QO Ever given a massage to you? A Not until she was already doing the massage stuff. But, no, I don't remember any kind of massage training or even like an inkling for it. Q Okay. Then when she goes to work for Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OO HS O1 OY ~ CO WO 10 I. i AS 14 i 16 ey 18 ig Z0 Zod Ze Zo 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page3/7 of 883 LoL Mar-a-Lago, you don't remember, I think is the words you used, whether she worked there for weeks or months? A Ves O You don't remember? A No, not at all. Q And at the time when she gets the job at the Mar-a-Lago, do you remember where you were working, if anywhere? A No. I mean, I think at that time, I was working at one of the places. But I don't really remember where. Q And then, and I believe that you used this word, correct me if I'm wrong, she's recruited to work for Jeff? A Yes. Q And do you remember her telling you that it was an assistant or somebody associated with Jeff that recruited her to work with Jeff? MS. MENNINGER: Objection, leading. THE WITNESS: I don't remember. MS. MENNINGER: Misstates the testimony. THe WITNESS: .Orry. I don't remember. All I remember was that somebody got her from there to Jeff. MR. EDWARDS: GOU te. BY MR. EDWARDS: Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OJ HS Ol OY ~ CO WO 10 ial i AS 14 i 16 ey 18 ig Z0 el Le Zo 24 Ls Case 18-2868, Document 283, 08/09/2019, 2628241, Page38 of 883 LOD O Then there's months; November, December. A So this is the year 2000, and these are the months? MS. MENNINGER: Objection to this entire line of questioning. The witness has no foundation for talking about this particular document. BY MR. EDWARDS: QO Okay. So do you know how long that -- as you sit here today, do you remember how long Virginia had been going over to Jeff's house before she started traveling on an airplane with him? MS. MENNINGER: Objection, foundation. THE WITNESS: No. BY MR. EDWARDS: QO It could be months, it could be a year? MS. MENNINGER: Objection, foundation. THE WITNESS : Tome ws: aoe ile “ae. ee Orr: think she was there for very long without doing traveling. BY MR. EDWARDS: Q But in your mind, you can't tell me how long "Very Long” Ls A No, I mean, I don't. Q Okay. And is there anything that would tell you the year or the month in which you remember Virginia first Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OO HS Ol OD ~l CO WO 10 Ti eZ Ales 14 sie 16 ey ike ig Z0 Zod Ze aS 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page39 of 883 LG going over to Jeff's house? A Not really. Q There's nothing I could really show you in this world that would remind you right now? A No. Q Okay. Before going over to work with Jeff, did Virginia have any massage experience? A NOx, 0 When -- I think you said with respect to "bringing other girls, that sounds familiar," what other girls do you remember her bringing? Do you remember their names? A I don't remember names. MS. MENNINGER: Objection, foundation. BY MR. EDWARDS: Q Did you ever drive any of the other girls over to Jeff's house? A i, some. Laake SO. Q Okay. How many times did you to to Jeff's house? A A few times. Like, I think I went -- I think I dropped her off and somebody always brought her back. I don't really remember picking her up too much. QO Okay. And in the beginning, she was telling you that she was performing massages? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OJ HS Ol OY ~ CO WO 10 I. i AS 14 i 16 ey 18 ig Z0 Zadk Ze Zo 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page40 of 883 ZF A Yeah, something like that. Q Do you know what time of year? A No. QO Do you know whether the spa at Mar-a-Lago closes during the summers? MR. EDWARDS: Form. THE WITNESS: No, I have no idea. BY MS. MBENNINGER: Q You don't know how she got the job with Jeff? A No. I know somebody -- somebody -- like, thet’s why 1. said “recruited” == that’s the only word. 1 can think of -- that worked for Jeff. Q Why do you use the word "recruited"? A Because that's the only word -- I don't know, football or everything. That's the only word I can think of, you recruit somebody. O Hared Her? A Yeah, I guess. It was -- it was just a very fast Thing. QO You don't know who that person was? A No. Q You don't Know what she said to that person? A No. QO You don't know what that person said to her? A Nope. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OJ HS Ol OY ~ CO WO 10 dea i AS 14 i 16 7 ie ig Z0 Zod Ze aS 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page41 of 883 128 Q Do you remember her coming home and saying "I GOL a JOD with Jere”? A I remember she said she got a job with Jeff. Q Did she tell about that job? A I think it was -- I think at the time it was for massage therapy, like, she was going to be a masseuse. O And she was excited about it? A Yeah. © She wasn't sad about it? A Not that I remember. But I really don't remember much from back then. Q She wasn't crying when she came home and said "I JUS GOU..a Job Wiech: Jerr,” 2ilohe? A No. Q You're guessing that you -- she got the job with Jeff before you moved into the Bent Oak apartment, but you don't know. Correct? MR. EDWARDS: Form THE WITNESS: ves. But I would think we would have had to have had the money by then. So that was the only time she was making real good money. BY MS. MENNINGER: Q And do you know how much that apartment cost? A I know it was expensive. Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OO HS Ol OY ~ CO WO 10 ial i AS 14 i 16 ey ice ig Z0 Zadk Ze Zo 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page42 of 883 146 CoE oR TL. Ft CATE STATE OF FLORIDA COUNTY OF MARION I, Karla Layfield, RMR, Stenographic Court Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing deposition of James Michael Austrich; that said witness was duly sworn to testify truthfully; and that the foregoing pages, numbered 1 through 145, inclusive, constitute a true and correct record of the testimony given by said witness to the best of my ability. I FURTHER CERTIFY that I am not a relative or employee or attorney or counsel of any of the parties hereto, nor a relative or employee of such attorney or counsel, nor am I financially interested in the action. WITNESS MY HAND this | day of June, 2016, at Ocala, Marion, County, Florida. Karla Layfield, RMR Stenographic Court Reporter Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

EXHIBIT 3 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page44 of 883 Page l IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS VIRGINIA L. GIUFFRE, Plaintiff, -againstGHISLAINE MAXWELL, Defendant. 250 N. Australian Avenue, Suite 1400 West Palm Beach, Florida 33401 Friday, September 9, 2016 8:35 a.m. - 2:08 p.m. CONFITIODENTI.IAL VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Taken before Darline M. West, Registered Professional Reporter, Notary Public in and for the State of Florida At Large, pursuant to Notice of Taking Deposition filed by the Plaintiff in the above cause. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page45 of 883 Page 74 J. Epstein - Confidential BY MR. CASSELL: or Isn't it true that Maxwell led Virginia up to your Palm Beach mansion massage room the first time you met her? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: QO. You saw Maxwell bringing Virginia up to your room, true, sir? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Isn't it true that it was standard operating procedure for Maxwell to bring underage girls up to your room? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Isn't it true that it was standard operating procedure for Maxwell to bring underage girls up to your room for you to sexually abuse? MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page46 of 883 Page 116 J. Epstein - Confidential THE WITNESS: Fifth. BY MR. CASSELL: QO. In 2000, Virginia was approached by Maxwell, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Maxwell was one of the main women whom you used to procure underage girls for sexual activities, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. It was your understanding that Maxwell met Virginia at the Mar-a-Lago Club in Palm Beach in 2000, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. In 2000, you were a member of the Mar-a-Lago Club, true? MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page4/7 of 883 Page 117 J. Epstein - Confidential MR. PAGLIUCA: Object to form. THE WITNESS: Fifth. BY MR. CASSELL: Q. In 2000, Ms. Maxwell had access to the Mar-a-Lago Club, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. The reason Maxwell had access to the Mar-a-Lago Club in 2000 was because of your connections to the club, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: O; Maxwell was a primary co-conspirator in your sexual abuse scheme, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: QO. Maxwell was a primary co-conspirator in your sex trafficking scheme, true? MAGNA®S

10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page48 of 883 Page 118 J. Epstein - Confidential MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Maxwell herself regularly participated in your sexual exploitation of minors, true? MR. PAGLIUCA: Object to form and found. THE WITNESS: Fifth. BY MR. CASSELL: Q. In 2000, Maxwell herself regularly participated in your sexual exploitation of minors, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: QO. Maxwell herself regularly participated in your sexual exploitation of Virginia, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Did Maxwell participate in your sexual MAGNA®S

mo OO Oo N WB Oo FE W DO NO NO NO NO NO FP FP FP FY FP FP FF FF FF F&F mn FPF Ww NO F 8D OO WO NI WD OO FSF WW NO F&F Case 18-2868, Document 283, 08/09/2019, 2628241, Page49 of 883 Page 376 REPORTER'S CERTIFICATE STATE OF FLORIDA COUNTY OF PALM BEACH I, DARLINE MARIE WEST, RPR, certify that I was authorized to and did stenographically report the foregoing deposition; and that the transcript is a true record thereof. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties’ attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 13th day of September 2016. DARLINE MARIE WEST, RPR MAGNA®S

EXHIBIT 4 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page51 of 883 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, Vv. GHISLAINE MAXWELL, Defendant. VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume 1 of 2 Pages 1 - 15/7 Taken at the Instance of the Defendant DATE: Friday, June 24, 2016 TIME: Commenced: 8:59 a.m. Concluded: 1:22 p.m. PLACE: Southern Reporting Company B. Paul Katz Professional Center (SunTrust Building) One Florida Park Drive South Suite 214 Palm Coast, Florida 32137 REPORTED BY: LEANNE W. FITZGERALD, FPR Florida Professional Reporter Court Reporter and Notary Public southern Reporting Company www.southernreporting.com - (386)25/7-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page52 of 883 82 QO Right? A Yeah. QO And she travelled the world? A Uh-huh (affirmative). Yes. QO Did JJ say there was anything weird about her job? A No. MR. EDWARDS: Object to the form. BY MS. MENNINGER: Q Did you know whether she had any massage training? A I did not. Like I said, the past three -three or four years before then, I had no contact with her whatsoever. So I had no clue what she was certified in or had done with her life. QO Okay. I would like to take about a fiveor ten-minute break, if that's okay with you. A That's fine. THE VIDEOGRAPHER: The time is 10:13. We are off the record. The time is 10:27. We are back on the record. MS. MENNINGER: All right. I would like to mark as an exhibit now Defendant's Exhibit 4. Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page53 of 883 88 certain times and stuff. And it would just -- you know, it just did not make sense to me that it it was just a masseuse, you know. Like I said, he's a billionaire. You can afford another masseuse. Why do you need her, you know. QO Do you know whether he -(Brief interruption. ) A Let me turn this down. Q sorry. A I'm sorry. (Briefly off the record. ) Q Do you know whether he had other masseuses at the time? A I -- I really don't know. All I know is he would have Virginia, obviously, go out and look for other girls, also, to bring back, as well. QO And how do you know that? A Because she had explained to me that sometimes when she would go out on trips that her and Ms. Maxwell and stuff would go out to, like, clubs and stuff and just try and pick up girls to bring back, so... QO That's what Virginia told you? A Yes. Q All right. Did any of your information -Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page54 of 883 89 (Brief interruption. ) A I thought I muted it. QO Did any of your information come from anywhere other than Virginia? A No. MR. EDWARDS: Object to the form. A Like I said, I did not talk -- I did not really speak to any of them other than, you know, hi, how's it going and stuff like that, until I had actually met Jeffrey. And then he was the only one I ever really spoke with. I had met Ms. Maxwell a couple of times, but it was never, like, you know, actual conversations, so... BY MS. MENNINGER: QO All right. Well, let me -- when did you meet Jeffrey? A I'd probably say -- probably a few months after I had moved in with her. Q Okay. And how did you come to meet Jeffrey? A Dropping her off over at his mansion. QO And did you drop her off using her car? A Yes. QO And so she just asked you: Can you take me over there? Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page55 of 883 90 A Yeah. O And did she tell you where to go? A Yeah. She told where he lived and everything. And then obviously I got to take the car, because she was going somewhere else in the world and did not need it, so... QO You were dropping her off for a multi-day trip? A Yeah. She would normally go about two weeks out of every month, so... QO Two weeks straight? A Yeah. It was two weeks home and two weeks gone, basically. QO Did you always take her to his house, Ores« A Yeah. Pretty much every time I took her there, it was always to his mansion. I picked her up one time -- maybe it was a couple of times -from the jet stream place. But pretty much every Single time it was at the hou- -- at the mansion. (Brief interruption. ) Q Okay. So you're -- is that your phone? I'm -A No, it is. I thought I muted it. QO That's okay. Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page56 of 883 92 talking like that, so... QO Okay. Where did your first conversation with Jeffrey take place? A I'm pretty sure it was in the kitchen or the living room. QO Inside the house? A Yeah, it was inside the house. I've never seen him anywhere else other than in the mansion or getting off the jet. Q So you were allowed to go inside the house -A Yeah. Q -- with Ms. Roberts? A Yeah. But I never went upstairs. I've only been in the kitchen, the living room, and by the pool. QO How many times would you estimate that you had been over to the house? A I mean, at least once every two weeks to drop her off, you know. O Was there a period of time between 2001 and when she left in 2002 where she was not working for Jeffrey? A Yes. QO What period of time was that? Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page5/ of 883 93 A It was pretty much, like, when she was actually working as a server. Like, basically because we were trying to not have her go back there. Like, she did not want to go back there. And we were trying to just work without needing his money, you know. QO All right. And if I can re-call up that Exhibit 2, can you see from here when about she was working aS a server? A March 4th, ‘02. Q Do you Know about how long she worked there? A I do not. I'm not sure. QO Days? Weeks? Months? Anything? A I really have no clue. Q Okay. How old was Ms. Roberts in 2002, if you know? A I'd probably say, like, 18 or so, maybe. QO If her birthday is in ‘83 -A Oh, if it's in ‘83, then I'd say -because I was born in ‘82, so a year younger than me would be... 18, 19? A Yeah, somewhere around there. MR. EDWARDS: Object to the form. Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page58 of 883 96 QO I guess my guestion is: Did she ever tell you that she had started as a regular masseuse for him and then transitioned to something other than a masseuse? A No. She never said that it transitioned. But she ended up explaining to me what had happened before, So... QO What has -- what is that? A That her and Ms. Maxwell and Jeffrey would obviously be doing stuff, all three of them together. Like I said, that they would all go out to clubs to pick up girls and try and find them to bring back for Jeffrey. And then she told me about how, like I said, her and Ms. Maxwell and Jeffrey were all intimate together on multiple occasions. QO When did she tell you this? I'm not exactly sure on the dates. Was it while you were still together? Yes. Did you -- had you met Ms. Maxwell? Yeah, I had met her a couple of times. When did you meet Ms. Maxwell? Pr Oo FP OO FP OO P Dates, I'm unsure of. But it was pretty much, like I said, at Jeffrey's house in the kitchen. Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page59 of 883 97 QO Was it earlier in the time you were with Met, Ol s< A It was about -- I'd say about six months or so. I don't know. I'm not exactly positive. QO All right. So at the time you met Ms. Maxwell, had Ms. Roberts already told you that she had been intimate? A No. She had told me about that, I believe, after I had max- -- after I had already met her. Q Okay. And tell me everything that you remember about what Ms. Roberts said about being intimate with Ms. Maxwell and Mr. Epstein at the same time. A I remember her talking about, like, strap-ons and stuff like that. But, I mean, like I said, all the details are not really that clear. But I remember her talking about, like, how they would always be using and stuff like that. Q She and Ms. Maxwell and Mr Epstein would used strap-ons? A Uh-huh (affirmative). QO How did you feel about that? A I just -- obviously not happy about it. QO What did you say? Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page60O of 883 103 A I did not. O When the FBI interviewed you, did you mention this to them? A I mentioned -- anything they asked me, I did not hold anything back. Q Okay. Do you recall specifically talking about sex with the Prince? A I -- I don't recall talking to them about that, but, I mean, it's -- it could be possible. O Other than sex with the Prince, is there anyone else that Jeffrey wanted Ms. Roberts to have sex with that she relayed to you? A Mainly, like I said, just Ms. Maxwell and all the other girls. QO Ms. Maxwell wanted -- Jeffrey wanted Virginia to have sex with Ms. Maxwell? A And him, yeah. O And did she tell you whether she had ever done that? A Yeah. She said that she did. QO And when did she tell you that? A I'm not sure on the date. QO And what did she describe having happened? A I believe I already told you that. With the strap-ons and dildos and everything. Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page61 of 883 157 CERTIFICATE OF REPORTER STATE OF FLORIDA ) COUNTY OF VOLUSIA ) I, Leanne W. Fitzgerald, Court Reporter, do hereby certify that I was authorized to and did stenographically report the deposition of TONY FIGUEROA; and that the foregoing transcript is a true record of my stenographic notes. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. Dated this 5th day of July, 2016. Leanne W. Fitzgerald, FPR Florida Professional Reporter Digital Certificate Authenticated By Symantec Southern Reporting Company www.Southernreporting.com - (386)257-3663

Case 18-2868, Document 283, 08/09/2019, 2628241, Page62 of 883 158 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, Vv. GHISLAINE MAXWELL, Defendant. VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume 2 of 2 Pages 158 - 258 Taken at the Instance of the Defendant DATE: Friday, June 24, 2016 TIME: Commenced: 8:59 a.m. Concluded: 1:22 p.m. PLACE: Southern Reporting Company B. Paul Katz Professional Center (SunTrust Building) One Florida Park Drive South Suite 214 Palm Coast, Florida 32137 REPORTED BY: LEANNE W. FITZGERALD, FPR Florida Professional Reporter Court Reporter and Notary Public southern Reporting Company www.southernreporting.com - (386)25/7-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page63 of 883 A Q 168 Yes. All right. And that belief was based on Virginia telling you that? A And JJ and Michael. Q Okay. So you had heard from some other people, and then later -A Yeah. Before she had come back to the apartment, they said that she was a masseuse for this guy. And then when she came back, she told me. QO All right. Once you started dating her again -- I'm sorry. Prior to dating her. Go back to the first time you were dating her. Did she have money? A No. O All right. Was she able to afford her own place? A No. Q Was she doing massages, at all? A No O All right. Fast forward to the second time when you get back together with her sometime in 2001. A Uh-huh (affirmative). Q Did she appear to you to have any massage training? Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page64 of 883 A Q 169 No. As a seventeen-year-old at that time, was she able to afford things? MS. MENNINGER: Objection. Form. Foundation. BY MR. EDWARDS: O Did she have money -A She had money. QO -- while working with Jeff? And was the money in the form of cash? A Yes. QO And did she always have cash? A Yes. QO And how was the apartment paid for? MS. MENNINGER: Objection. Form. Foundation. A Cash. BY MR. EDWARDS: O And did you see how she was paying for the apartment? A I did not watch her pay the bill, but... Q Okay. When you would go to dinner, who would pay? A Just whoever. MS. MENNINGER: Objection. Form. Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page65 of 883 200 MS. MENNINGER: Objection. Form. Foundation. A For Jeffrey. BY MR. EDWARDS: Q All right. Let me fix this. Ghislaine -when Ghislaine Maxwell would call you during the time that you were living with Virginia, she would ask you what, specifically? MS. MENNINGER: Objection. Form. Foundation. A Just if I had found any other girls just to bring to Jeffrey. BY MR. EDWARDS: Q Okay. A Pretty much every time there was a conversation with any of them, it was either asking Virginia where she was at, or asking her to get girls, or asking me to get girls. QO All right. Let's go to that second category you just identified, which is asking Virginia to get girls. How many times were you ina room where specifically Ghislaine Maxwell would ask Virginia to bring girls? A None that I can recall. Q Okay. How many times -- when you say they Southern Reporting Company www.Southernreporting.com - (386)257-3663

Case 18-2868, Document 283, 08/09/2019, 2628241, Page66 of 883 228 1 went with Virginia, and you dropped her off; and 2 some occasions you went inside? 3 A Yeah. 4 QO And some of the occasions you went inside, 5 you hung out by the pool? 6 A Yes. 7 Q Or in the kitchen with the chef? 8 A Yeah. 9 QO All right. And in the total of all the 10 times that you went inside the house, you saw 11 Ms. Maxwell -- I think you got up to six times? 12 A Yeah, about five or six times. 13 QO All right. Total? 14 A Total. 15 QO That's not five or six times where -16 A That was period, all together. 17 QO -- you brought girls? 18 A No. All together, period. 19 O All right. I thought you said when I was 20 asking you guestions that Ms. Maxwell never asked 21 you to bring girls. 22 A I don't remember saying that. 23 QO Okay. Well, tell me. When did 24 Ms. Maxwell ask you to bring a girl? 25 A Never in person. It was, like, literally, Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page6/ of 883 229 like, on the phone maybe, like, once or twice. O All right. Did Ms. Maxwell call you frequently? A No. QO All right. How many times do you think Ms. Maxwell called you, at all? A I'd just say that probably a just a few, a couple of times. Maybe once or twice. QO One or two -A The majority of the time it was pretty much his assistant. QO How do you know Ms. Maxwell's voice? A Because she sounds British. Q So someone with a British accent called you once or twice and asked for -A Well, she told me who she was. Q Okay. And what did she say when she called you and asked you to bring girls? A She just said, "Hi. This is Ghislaine. Jeffrey was wondering if you had anybody that could come over." Q Okay. When did that happen? A I'm not exactly sure on the time frame. Q Was it after the Roadhouse Grill or before? Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page68 of 883 248 Q So the thing that Virginia was tired of -just so that the record is clear -- well, I'll let you answer in your words. Just be clear. What was it that Virginia was trying to get away from and stop with respect to working at Jeffrey Epstein's house? MS. MENNINGER: Objection. Form, foundation -- as to Virginia's thought processes. A To stop being used and abused. BY MS. MENNINGER: QO How do you know that? MS. MENNINGER: Objection. Form. Foundation. A Due to all the things that I have come to -- that have been brought to light, and in the experiences that I've had, and the conversations that I have had with her. Like, it just all adds up to that, so... BY MS. MENNINGER: QO When Virginia was wanting to get out, did she ever express that it was the times of work that she was trying to get away from? A No. Q Okay. What was she specifically Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 ZZ 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page69 of 883 251 QO Was she getting paid as much as she was getting paid to work for Jeff Epstein? A Definitely not. QO She no longer had cash all around? A Nope. QO You mentioned that there was -- you had several conversations with Virginia when she was discussing them wanting -- or I think the word you used was force, but later we tried to clarify that, but them forcing her to have sex with Prince Andrew. Do you remember that? A Yeah. Q And that you expressed that you were worried for her safety if she were to decline that? A Yes. QO What about your conversation with Virginia on that particular occasion made you worried for Virginia's safety? A Just the way she was talking to me. Like, she just sounded scared. QO And what -- what -- try to dig back and remember what exactly she was saying and how she was Saying it, if you could just describe that for us. A She said that she went to go in -- I remember at one time she was talking to me about how Southern Reporting Company www.Southernreporting.com - (386)257-3663

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page/O of 883 258 CERTIFICATE OF REPORTER STATE OF FLORIDA ) COUNTY OF VOLUSIA ) I, Leanne W. Fitzgerald, Court Reporter, do hereby certify that I was authorized to and did stenographically report the deposition of TONY FIGUEROA; and that the foregoing transcript is a true record of my stenographic notes. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. Dated this 5th day of July, 2016. Leanne W. Fitzgerald, FPR Florida Professional Reporter Digital Certificate Authenticated By Symantec Southern Reporting Company www.Southernreporting.com - (386)257-3663

EXHIBIT 5 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page72 of 883 GIUFFRE VS. MAXWELL Deposition VIRGINIA GIUFFRE 05/03/2016 Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017

Case 18-2868, Document 283, 08/09/2019, 2628241, Page/3 of 883 Agren Blando Court Reporting & Video, Inc. IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS CONFIDENTIAL VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE May 3, 2016 VIRGINIA L. GIUFFRE, Plasnecice., Vv. GHISLAINE MAXWELL, Defendant. APPEARANCES: FAMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. By Brad Edwards, Esq. 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954.524.2820 brad@pathtojustice.com Appearing on behalf of the Plaintiff BOLIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. (For Portion) 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301-2211 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE 5/3/2016

Case 18-2868, Document 283, 08/09/2019, 2628241, Page/4 of 883 Agren Blando Court Reporting & Video, Inc. APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, Esq. 10 TI LZ 13 14 lr: 16 dy 18 ig ZU 21 22 Zo 24 25 Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jJpagliuca@hmflaw.com Appearing on behalf of the Defendant Also Present: Brenda Rodriguez, Paralegal Nicholas F. Borgia, CLVS Videographer VIRGINIA GIUFFRE 5/3/2016

10 ila LZ 13 14 a 16 9, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page/5 of 883 Agren Blando Court Reporting & Video, Inc. you don't. Do you have any reason to believe that any of your previous sworn statements that you have made are not true? A NOs MR. EDWARDS: I just object and ask that if we're going to ask the witness questions about any of her statements in whole or in part that the witness be allowed to see the statement, review the statement and then answer your questions. O (BY MS. MENNINGER) You may answer the question. A Can you reask the question? I'm sorry. Q Do you have any reason to believe that any of your prior sworn statements are untrue? A I have no reason to believe that my prior Statements are untrue. Q Has anyone told you to say something that was not true in connection with this case? A No, ma'am. Q All right. I'd like to start with a lawsuit that you filed under the caption Jane Doe versus Jeffrey Epstein. Do you recall that lawsuit? A I believe so. VIRGINIA GIUFFRE 5/3/2016 16

10 ia LZ 13 14 a 16 3, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page/6 of 883 Agren Blando Court Reporting & Video, Inc. (Exhibit 1 marked.) QO (BY MS. MENNINGER) I'm going to show you an exhibit that we are marking as Defendant's Poca. J. MR. EDWARDS: Can I see that for a second? I'd just like to make an objection on the record for the misidentification of this document. While there was a lawsuit filed under the style of Jane Doe versus Jeffrey Epstein, Jane Doe was not Virginia Giuffre. And the lawsuit that's now being handed to this witness is Jane Doe 102 versus Jeffrey Epstein. Is that the document we're talking about? MS. MENNINGER: Counsel, if you have an objection, you should state the basis for your objection in a non-leading, non-suggestive manner. If you have any other record to make, you can do so ina pleading filed with the Court. MR. EDWARDS: Sure. My objection is you've misrepresented what you've handed the witness. I want to make sure that the witness is holding what you actually want her to be holding as opposed to the lawsuit you said that you were going to hand her. Thecus 120. MS. MENNINGER: Counsel, I will ask the VIRGINIA GIUFFRE 5/3/2016 17

10 ila LZ 13 14 a 16 Le , 18 ie, 20 Zi. 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page// of 883 Agren Blando Court Reporting & Video, Inc. January 19th, 2015? A At the very top of the page it says January 21st, 2015. OQ The date it was filed. Is there a date just above the signature block? A Oh, yes, sorry. Yes, there is. QO And what date -- what date was that? A The 19th day of January, 2015. Q Okay. And this document is something that you believe contains the truth, correct? A To the best of my knowledge at the time, yes. Q All right. Did something change between the time then and today that makes you believe that it's not all accurate? A Well, aS you can see, in line 4 on page 1, I wasn't aware of my dates. I was just doing the best to guesstimate when I actually met them. Since then I've been able to find out that through my Mar-a-Lago records that it was actually the summer of 2000, not the summer of 1999. Q Oh, I'm sorry. Are you back on page 1? A On the first page. QO Okay. A Yes: VIRGINIA GIUFFRE 5/3/2016 25

10 Te 12 Ls 14 ale: 16 9, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page/78 of 883 Agren Blando Court Reporting & Video, Inc. MR. EDWARDS: Objection. Asked and answered. QO (BY MS. MENNINGER) You may answer. MR. EDWARDS: Answer again. A Again, I wouldn't say it's untrue. Untrue would mean that I would have lied. And I didn't lie. This was my best knowledge at the time. And I did my very best to try to pinpoint time periods going back such a long time ago. It wasn't until I found the facts that I worked at Mar-a-Lago in 2000 that I was able to Figure that out. Q (BY MS. MENNINGER) And approximately when did you learn those facts about the dates you worked at Mar-a-Lago? A I would say it was mid-2015. Q Mid-2015 is the first time you became aware of the dates -A I don't know the exact -Q If you could just let me finish. A I'm sorry. Q That's all right. Approximately mid-2015 when you learned the true dates that you had worked at Mar-a-Lago? A That" S:COrrece. Sorry. VIRGINIA GIUFFRE 5/3/2016 28

10 ila LZ 13 14 a 16 3, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page/79 of 883 Agren Blando Court Reporting & Video, Inc. MR. EDWARDS: Object to the form. A Uhm, I don't know, to be honest. O (BY MS. MENNINGER) And in what order did Taco Bell, Publix and Mar-a-Lago go, and the aviary, sorry? A Oh, I would have to guess. Do you want me to guess? QO Sure. A Um, I would say Publix. And then, I think that's when I helped my boyfriend out at Taco Bell and then I think the aviary. QO And where was the Taco Bell? A I was living in Fort Lauder -- I think it was Fort Lauderdale. Don't quote me on that, but somewhere in Florida, Broward County, something like that. Q And who were you living with at that time? A Michael. His name is James, but Michael. Q So you were living with Michael when you worked at the Taco Bell, right? A Yes, I was living with him. Q And you worked with Michael when you worked at the Publix, correct? A No. Q Okay. So Publix came after Taco Bell or VIRGINIA GIUFFRE 5/3/2016 53

10 i: LZ Ls 14 a 16 3, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page8s0 of 883 Agren Blando Court Reporting & Video, Inc. Q Whatever address you were living at, at the time you started at Mar-a-Lago. A Ps so oxahatchee, Florida aoe O Q How is it that you came to work at Mar-a-lLago? A My dad 1S a maintenance manager or supervisor, I don't know what you call it. But he worked in the maintenance department, mostly on tennis courts, working on the air conditioning, helping set up for functions. And he got me a summer job there. Q Okay. And you said you were on a break? A Yes. Q What were you on a break from? A I think like -- this is going back so long now, but I was attempting to get my GED. And it, summer came, so school stops during the summertime here in America, and I got a summer job. Q All right. And where were you in school? A I don't actually know the name of the place. It's -- yeah, I know. O A GED place? A Yeah, it was, like, I was previously in Royal Palm Beach High School, but, I mean, because of VIRGINIA GIUFFRE 5/3/2016 56

10 ila LZ 13 14 a 16 3, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page81 of 883 Agren Blando Court Reporting & Video, Inc. Q Okay. If I can direct your attention back to Defendant's Exhibit 12 at page 15. And under the heading Response to Interrogatory Number 9, do you see that where it says -A Yes. Q -- Ms. Joffrey (pronouncing) -- Giuffre, excuse me, responds as follows? A Yes: Q Okay. It Says you worked as a locker room attendant for the spa area, correct? A Les; Q And it says records produced in this case identify the date of employment as 2000, correct? A Yes. Q What records that were produced in this case cause you to believe that the employment began im ZOO? A Uhm, is this going back to another question that I'm not allowed to answer? O No. A I have seen the documents, and I know that my employment now was in 2000. Q What documents did you see that caused you to make that answer? A The Mar-a-Lago employment documents. VIRGINIA GIUFFRE 5/3/2016 67

10 ia LZ 13 14 a 16 3, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page82 of 883 Agren Blando Court Reporting & Video, Inc. masseuses had their own uniforms. QO What did the masseuses! uniform look like? A I don't remember. OQ No recollection at all? A None whatsoever. O Color? A No, sorry. I remember mine. Q Okay. How did it come to pass that you were no longer working at Mar-a-Lago in two to three weeks? A I was approached by Ghislaine Maxwell. Q Okay. And how long had you been working at Mar-a-Lago when you were approached by Ghislaine Maxwell? A Roughly two to three weeks. Q Okay. Where in the spa were you when you were approached by Ghislaine Maxwell? A Just outside the locker room, sitting where the other girl that works there usually sits. She was away from the desk. I was reading a book on massage therapy. QO Was that indoors or outdoors? A Outdoors. Q Okay. And what -- were you in the sun or in the shade? VIRGINIA GIUFFRE 5/3/2016 7717

10 ila LZ 13 14 a 16 3, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page83 of 883 Agren Blando Court Reporting & Video, Inc. wanted to aim for something higher than being a locker room attendant one day. And. Yeah. QO What was the name of the massage therapist that you were speaking with? A Oh, I have no idea. Q Can you give me any physical description of any of them? A Um, there was one who had blonde short hair. There was -- I would say there's probably about four massage therapists that work in there. So, I mean, I don't remember all of them. Q Okay. What time of day was it? MR. EDWARDS: Object to the form. A Afternoon. O (BY MS. MENNINGER) How late? A Anywhere between 2 to 4. Q And what time did you get off of work? A I believe I got off at 5. Q And what was the rest of your conversation with Ms. Maxwell? I'm sorry, I don't think you finished. A Thank you. Well, she noticed I was reading the massage book. And I started to have chitchat with her just about, you know, the body and the anatomy and how I was interested in it. And she VIRGINIA GIUFFRE 5/3/2016 116

10 ila LZ 13 14 a 16 dL, 18 i 20 Zi. 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page84 of 883 Agren Blando Court Reporting & Video, Inc. told me that she knew somebody who was looking for a traveling masseuse. And I said, Well, I don't have any accreditations. This is the first book I've ever read. She goes, That's okay. I know somebody. We Can train you. We can get you educated. You know, we can help you along the way if you pass the interview. If the guy likes you, then, you Know, it will work out for you. You'll travel. You'll make good money. You'll be educated, and you'll finally get accredited one day. O Okay. A She finished off by, you know, giving me her number. And I told her I'd have to ask my dad. And I called my dad. I ran over, actually, to see my dad, talked to him. He said it would be okay. I used the phone from Mar-a-Lago to call her and tell her that I was allowed to come over. And she said, Great. Meet me here at -- I don't remember the exact address, but it was El Brillo Way in Palm Beach -- after you get off. And my dad drove me. Q Did you write down her add -- the address that she gave? VIRGINIA GIUFFRE 5/3/2016 117

10 ila LZ 13 14 a 16 9, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page85 of 883 Agren Blando Court Reporting & Video, Inc. A Yes. Q Did you write down her phone number? A Yes: Q So did you go run and talk to your dad while she was still there? A No, I believe she left. And she told me to ask my dad and then to give her a phone call. Q Okay. Did she ask you your age when she had that conversation with you? A No, She did not. Q Did you tell her your age? A No, I did not. Q And so somewhere you wrote down a phone number to call her back at? A Um-hum. Q All right. And where did you write that down? A Probably just a piece of paper lying around the desk. Q Okay. But you don't remember? A I mean, no, I don't have that piece of paper anymore, so no. Q Okay. And did you write down an address? A Yes. Q And what number do you think you called? VIRGINIA GIUFFRE 5/3/2016 118

10 ia LZ 13 14 a 16 3, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page8s6 of 883 Agren Blando Court Reporting & Video, Inc. Q When did you get your first car? A After my trip to London to meet Prince Andrew. Q Okay. What kind of car did you get? A A Dodge Dakota. Q And did you purchase that yourself? A Yes, I did. QO And how much did it cost? A I don't remember off the top of my head how much it cost. Q Who did you buy it from? A My dad helped me bargain with it. I don't remember where we bought it from. Q And was the title put in your name or your dad's name? A I think the title was put in my name. I think. I mean, my dad was with me. I've never registered a car or anything like that before. So -Q So that was your first time? A Yes. QO Memorable, right? A Yes. QO When you got there, a butler or someone answered the door, is that what you said? A No, Ghislaine answered the door. VIRGINIA GIUFFRE 5/3/2016 270

10 ila LZ 13 14 a 16 3, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page8/ of 883 Agren Blando Court Reporting & Video, Inc. A Yes. Q Who else was at home when you got home? A My mom, my dad and my brother. O Which brother? A Sky. Q And anyone else who was there at the time? A I believe Michael might have been living with me at that time. So he might have been there. Q Do you recall if he was there when you got home? A I don't really remember. I remember what I did when I got home, that I basically made a beeline for the bathroom. Q Let me ask you a question. Michael was living with you at that home, at your parents' home at the time, is your best recollection today; is that PLont? A That's my best recollection, yes. Q When you say living with you, were you guys staying in the same room? A Yes. © Were you engaged at that time to him? A That was a really weird relationship. He was a friend who looked after me, and he did propose to me and I did say yes. But my heart was never in VIRGINIA GIUFFRE 5/3/2016 O77

10 ia LZ 13 14 a 16 3, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page88 of 883 Agren Blando Court Reporting & Video, Inc. te He was somebody that helped me off the streets so I felt compelled to say yes to him. Q Okay. So when he proposed to you and you said yes, did that take place before you started working at Mar-a-Lago or after you started working at Mar-a-Lago? A Before. Q And so if he were living with your parents at that time, you were living in the same room; is that... COrrect? A I believe so. Q And your parents understood him to be your Fiance? A I don't think they agreed with it, but I think they understood it as that. I mean -Q I mean, you communicated to them that he had proposed and you had accepted? A Yeah, in not such a pretty way. I mean, they obviously weren't very happy about it. And it wasn't my true intentions to ever marry him. QO Okay. A But I did it to make him feel okay. I didn't want to be mean. Q What did your mom say about your VIRGINIA GIUFFRE 5/3/2016 28

10 ia LZ 13 14 a 16 3, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page89 of 883 Agren Blando Court Reporting & Video, Inc. A I believe Juan Alessi was pretty much within ear distance. Q Could you see him? A Yes. Q Okay. A Like I said, in ear distance, when I mean ear distance like hearing, in the hearing vicinity. And it was in the same time that she was asking him to drop me off at home. Q Okay. When you were driving home the First night with Juan Alessi, did you have any conversation with him? A No. I had told him my address. It was a very guiet ride. Q Did you ride in the front or the back? A The front. Q It 1S your contention that, Ghislaine Maxwell had sex with underage girls virtually every day when I was around her, correct? A Yes. Q All right. With whom did Ghislaine Maxwell have sex in your presence? A Well, there's a lot of girls that were involved. We weren't on a first name basis with each other. I wouldn't be able to give you lists of names VIRGINIA GIUFFRE 5/3/2016 138

10 ia LZ 13 14 a 16 3, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page90 of 883 Agren Blando Court Reporting & Video, Inc. of girls. It was continuous. Q It was continuous. Name one girl that Ghislaine Maxwell had sex with in your presence. A Emmy Taylor. I mean, that's a name that I know well because Emmy was always around. I'm trying to think of her name, sorry. Sarah. Her name used to be Sarah Kellen. I think she's changed it now that she's married. ee (ONO lsic) == 1 Cant pronounce her last name properly, but it's around those lines. There were a lot of other girls that I honestly can't remember their names. I'm sorry. I wish I could help out more because I really would like to provide more witnesses for this, but I can't remember a lot of girls' names. Q So those are the three names of females that you observed Ghislaine Maxwell have sex with -MR. EDWARDS: Object to the form. Mischaracterizes testimony. O (BY MS. MENNINGER) -- 1s that what I understand your answer to be? MR. EDWARDS: Objection. Mischaracterizes her testimony. A Those are -- those are some three of the VIRGINIA GIUFFRE 5/3/2016 7139

10 ila LZ 13 14 a 16 9, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page91 of 883 Agren Blando Court Reporting & Video, Inc. O More than 20? A I would say more than 20. O More than 50? A IT don't think more than 50, but -Q Did -A I don't have an exact number. I mean, 1£ -- I think if you look at the flight logs, you know, that helps, but then they're not fully complete. We only have flight logs to one plane and then there's a time I was flown commercially into the island. Q Um-hum. A So it's really hard for me to gauge a number . Q Okay. Do you have any photographs of yourself on the island? A I know I used to, but they would be left in that apartment. Q What other locations did you participate in sexual contact with Ghislaine Maxwell, other than the island? A Everywhere. New York, Palm Beach. QO Where in New York? A The mansion, Jeffrey's mansion. Q Okay. Anywhere else in New York? VIRGINIA GIUFFRE 5/3/2016 155

10 ia LZ 13 14 a 16 3, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page92 of 883 Agren Blando Court Reporting & Video, Inc. think I met Prince Andrew in 2001. And Glenn Dubin and Stephen Kaufmann were, like I said, the first people I was sent out to after my training. So lI don't know. I'm not going to give you an exact time 1f I don't know it. Q I asked you the relative order. A And I"m. trying bo Give you 10. QO And where does Alan Dershowitz fit into that group of people? A Same. I can't tell you piece by piece by piece who -- I know Glenn Dubin was first. O Okay. A And I know Stephen Kaufmann was one of the first I was sent to. Alan Dershowitz could have been between there. Between, sorry, between Glenn and Stephen. The first time I was with Alan Dershowitz was in New York, so I wasn't actually sent to him. It actually happened at one of Jeffrey's residences. (Ms. McCawley left the deposition.) A So it's very hard for me to chronologically give you each person individually. O (BY MS. MENNINGER) Okay. Name the other politically connected and financially powerful people that Ghislaine Maxwell told you to go have sex with? A Again, I'm going to tell you "they" VIRGINIA GIUFFRE 5/3/2016 193

10 i 12 Ls 14 ale: 16 7, 18 ie, 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page93 of 883 Agren Blando Court Reporting & Video, Inc. because that's how it went. They instructed me to go to George Mitchell, Jean Luc Brunel, Bill Richardson, another prince that I don't know his name. A guy that owns a hotel, a really large hotel chain, I can't remember which hotel it was. Marvin Minsky. There was, you know, another foreign president, I can't remember his name. He was Spanish. There's a whole bunch of them that I just -- it's hard for me to remember all of them. You know, I was told to do something by these people constantly, told to -- my whole life revolved around just pleasing these men and keeping Ghislaine and Jeffrey happy. Their whole entire lives revolved around sex. They call massages sex. They call modeling sex. They call -Q I asked you the names for people. Are you going to tell me any other names or is that all of them? A I'm trying to think. That's the answer I'm trying to give to you. It's that it's so hard to just keep naming and naming and naming. QO All right. A A lot of times I would be introduced to them. I didn't know -VIRGINIA GIUFFRE 5/3/2016 194

10 Tel 12 Ls 14 ale: 16 dL, 18 i 20 21 22 Z5 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page94 of 883 Agren Blando Court Reporting & Video, Inc. many times you want me to keep answering this question. Both told me to do this, okay? They both sent me to these people. How many times do you want me to answer ene. QO (BY MS. MENNINGER) I think you're answering a different question so that's why I'm going to ask you again. I am not asking you anything about a time when Jeffrey and Ghislaine together told you to go do something. I'm asking you to name a Single time during which Ghislaine Maxwell acting alone directed you to go have sex with another person? MR. EDWARDS: Objection. Asked and answered. Harassing. Argumentative. A I've given you the names of the people that Ghislaine instructed me to go have sexual relations with. I am not discluding (sic) the fact that Jeffrey also told me. Ghislaine told me from her mouth to do these things. Jeffrey told me from his mouth to do these things with these people. Ghislaine instructed me to do the things that I did with Jeffrey Epstein on the very first meeting that I had with him. She brought me there under the preclusion (sic) that I VIRGINIA GIUFFRE 5/3/2016 198

10 ia LZ 13 14 a 16 3, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page95 of 883 Agren Blando Court Reporting & Video, Inc. was going to be trained as a masseuse and that she instructed me to take off my clothes and to give oral sex to Jeffrey Epstein. O (BY MS. MENNINGER) Excuse me. I've asked you for the names. A I've just given you a name. Jeffrey Epstein is a big name. Q All right. A She instructed me on that one. Q So you're saying -MR. EDWARDS: The witness is finishing her answer right now. She's in the process of explaining one of the people Ghislaine told her to have sex with. Q (BY MS. MENNINGER) So you're saying Ghislaine Maxwell directed you to have sex with Jeffrey Epstein? A COLbeCG. Q Ghislaine Maxwell directed you to have sex with Glenn Dubin? A COLL ece. © What words did Ghislaine Maxwell tell you to go have sex with Glenn Dubin? A It was the same all the time, all right? They want me to go provide these men with a massage. VIRGINIA GIUFFRE 5/3/2016 199

10 ia LZ 13 14 a 16 9, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page96 of 883 Agren Blando Court Reporting & Video, Inc. A When it happened? QO When Ghislaine Maxwell used the words, Go give a massage to Bill Richardson, where were you? MR. EDWARDS: Object to the form. Mischaracterizes her testimony. A IT can't tell you where we were. I know where I was sent to. I don't know where we were when she told me to do that. QO (BY MS. MENNINGER) Where were you sent EO == A New Mexico. Q -- by Ghislaine Maxwell? MR. EDWARDS: Object to the form. Mischaracterizes her testimony again. A Are you smiling at me because -O (BY MS. MENNINGER) No, I'm asking you to answer the question. A I have answered the question. I was sent to New Mexico. Q Okay. Where were you sent from? A I already answered that. I don't know where I was sent from. QO Okay. A I was flying everywhere with these people. Q Where were you sent by Ghislaine Maxwell VIRGINIA GIUFFRE 5/3/2016 201

10 ia LZ 13 14 a 16 9, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page9/7 of 883 Agren Blando Court Reporting & Video, Inc. A No, she was not in the room. She was in another cabana. Q And other than telling you to go give the owner of this large hotel chain a massage, do you remember any other words she used to you to direct you in what you should do? A Not at the time, no. Q Where did -- where were you and where was Ms. Maxwell when she directed you to go have sex with Marvin Minsky? MR. EDWARDS: Object to the form. A I don't know. O (BY MS. MENNINGER) Where did you go to have sex with Marvin Minsky? A I believe it was the U.S. Virgin Islands, Jeff's -- sorry, Jeffrey Epstein's island in the U.S. Virgin Islands. O And when was that? A I don't know. Q Do you have any time of year? A No. Q Do you Know how old you were? A No. O Other than Glenn Dubin, Stephen Kaufmann, Prince Andrew, Jean Luc Brunel, Bill Richardson, VIRGINIA GIUFFRE 5/3/2016 204

10 TI LZ 13 14 lr: 16 9, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page98 of 883 Agren Blando Court Reporting & Video, Inc. another prince, the large hotel chain owner and Marvin Minsky, is there anyone else that Ghislaine Maxwell directed you to go have sex with? A I am definitely sure there is. But can I remember everybody's name? No. Q Okay. Can you remember anything else about them? A Look, I've given you what I know right now. I'm sorry. This is very hard for me and very Frustrating to have to go over this. I don't -- I don't recall all of the people. There was a large amount of people that I was sent to. Q Do you have any notes of all these people that you were sent to? A No, I don't. Q Where are your notes? A I burned them. Q When did you burn them? A In a bonfire when I lived at Titusville because I was sick of going through this shit. Q Did you have lawyers who were representing you at the time you built a bonfire and burned these notes? A I've been represented for a long time, but it was not under the instruction of my lawyers to do VIRGINIA GIUFFRE 5/3/2016 205

10 ila LZ 13 14 a 16 3, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page99 of 883 Agren Blando Court Reporting & Video, Inc. this. My husband and I were pretty spiritual people and we believed that these memories were worth bur ding. Q So you burned notes of the men with whom you had sex while you were represented by counsel in litigation, correct? MR. EDWARDS: Object to the form. A This wasn't anything that was a public document. This was my own private journal, and I didn't want it anymore. So we burned it. O (BY MS. MENNINGER) When did you write that journal? A Just over time. I Started writing it probably in, I don't know, I can't speculate, 2012, 2011. Q So you did not write this journal at the time it happened? A ING < Q You started writing this journal approximately a decade after you claim you finished being sexually trafficked, correct? A Yes. Q And you started writing a journal after you had a lawyer, correct? A COmT CCE. VIRGINIA GIUFFRE 5/3/2016 206

10 ia LZ 13 14 a 16 3, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page100 of 883 Agren Blando Court Reporting & Video, Inc. THE VIDEOGRAPHER: We're back on the reCOrd. au 255, OQ (BY MS. MENNINGER) Do you have any photographs of yourself either nude or in a sexually compromising position that you claim were taken by Ghislaine Maxwell? A I do not have any of those in my evidence. But if you ask Ghislaine Maxwell, she would have plenty. Q Do you have any in your storage boxes in Sydney? A No. Q Do you know whether your attorneys have any such photographs that you claim were taken by Ghislaine Maxwell? A IN@< Q You don't know or they don't have them? A I don't know. And I don't think they have them. If they had them, they would have told me. You Should ask your client. She's got plenty of Chem. Q What type of camera did Ghislaine Maxwell use? A It was a black camera. And it hada, I don't know the types and names of them, but the lens VIRGINIA GIUFFRE 5/3/2016 237

10 TI LZ 13 14 lr: 16 dL, 18 i 20 Zi. 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page101 of 883 Agren Blando Court Reporting & Video, Inc. that goes out. Q Was it digital or single reflex? A Again, I don't know types of cameras. I mean, I use my phone for using a camera. So it's a black camera and it had a lens that you could put out Further or bring back. Q Did you ask her to take any photographs of you? A No. She asked to take photographs of me. Q Was it a film or a digital camera? A I never saw how she printed them out. Q What's the first time you told anybody that you had been sexually trafficked? MR. EDWARDS: Form. A Tony Figueroa, my ex-boyfriend, knew some of the stuff that was happening, though I did not go in great detail to him, being that he's my boyfriend. And then the first person I really opened up to about everything was my husband. Q (BY MS. MENNINGER) Did you tell Tony Figueroa that you were forced to have sex with Jeffrey Epstein? A Ves: Q Did you tell Tony Figueroa you were forced to have sex with Ghislaine Maxwell? VIRGINIA GIUFFRE 5/3/2016 233

10 ia LZ 13 14 a 16 dL, 18 i 20 21 22 Z5 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page102 of 883 Agren Blando Court Reporting & Video, Inc. any interactions with law enforcement? A Yes. OQ When? A When I tried to break away from Jeffrey and Ghislaine, I started making myself unavailable. And I got a job at Road House Grill. And Tony used to come pick me up in the afternoons, at nighttime, and he'd sit at the bar. And there's this big cup that's Gout: Lips an 1c. I was in the back room. And I had to -First you have to sign out and you have to take off your aprons, put your aprons away. And there's a whole bunch of cleaning up stuff you have to do. In that time period, Tony grabbed money From a cup that had money in it. That was for the bartenders for their tips. My boss called me the next day. He told me that I had stolen the money, which I hadn't. And I came back and I returned the money after I confronted Tony about it. Gave the money back to him and he said, I'm sorry, but it's just law that I have to call the police. So he called the police. And knowing that Jeffrey has got the Palm Beach Police Department in his pocket, I went to Jeffrey Epstein and I told him what had happened. VIRGINIA GIUFFRE 5/3/2016 IAN

10 TI LZ 13 14 lr: 16 7, 18 ie, 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page103 of 883 Agren Blando Court Reporting & Video, Inc. And Jeffrey said, Don't worry about it. Let me take care of it for you. Q Okay. I'm sorry. When did you have interaction with law enforcement, then? A What year? Q Did you speak with a law enforcement officer? A I don't believe I spoke to them. Jeffrey handled everything. Q Okay. And you said that you had finished your shift at -- this is at the Road House Grill, COLTSCE. A VOLELeCE. Q You had finished your shift? A Yeah, it was the end of the shift. Q Okay. And you had cleaned up and were checking out, correct? A Yeah, it's a completely separate part of the -- it's like back of the house. Do you know what that means, like in waitering terms? Q (Anda calang.) A Yeah, back of the house. Q And what was -- who was this boss that you spoke to? A IT can't remember his name. VIRGINIA GIUFFRE 5/3/2016 Oe |

10 ila LZ 13 14 a 16 Le , 18 ie, 20 Zi. 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page104 of 883 Agren Blando Court Reporting & Video, Inc. exclusivity? A Yes. Q What was that period? A I believe it was like a three-month period or something. Q Okay. And what other terms of the contract, do you recall? A I couldn't talk to any other news publication about the story. QO Anything else? A Not that I know of. Q Were you happy when the period was up? A Well, I mean, at that time I wanted to write about my story. So I guess, yes, I was happy when that period was up. Q And you were actively writing a book at that time, Gorrect ? A My manuscript. I've never published it. Q You were writing the manuscript at the time of your period of exclusivity with Sharon Churcher, COLrrece? A Those three months were just craziness. I think I started after that. Q You think you started writing the book after the 90 days were up? VIRGINIA GIUFFRE 5/3/2016 2AI

10 ia LZ 13 14 a 16 3, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page105 of 883 Agren Blando Court Reporting & Video, Inc. A Yeah. Q And then you attempted to sell that manuscript, correct? A I didn't attempt to sell it. I went to other publications, like, what do you call them? People -- I'm trying to think of the name of the word. People who publish books, not like a newspaper or anything. And I inquired about what they thought of my manuscript and if they thought it was, you know, a good story. And, yeah. Q So you sent the manuscript to these people For the purposes of trying to publish the book, correct? A Some people, yes. Q And you were trying to get money from the book publication, correct? A Well, I wasn't going to sell it to them for free. Q But you were unsuccessful in finding someone to publish it, correct? A Well, I was always on the fence with it. I wasn't too sure if I wanted to or didn't want to. I was more seeking judgment based upon these people who have done this plenty and plenty of times. Still to this day, I mean, I've had people VIRGINIA GIUFFRE 5/3/2016 250

10 ia LZ 13 14 a 16 3, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page106 of 883 Agren Blando Court Reporting & Video, Inc. who have been interested in it and I still don't know 1f I want to do it yet. I mean, I think there's a lot more that can go into it, you know. Q You were actively sending the manuscript to people for purposes of having them reach a deal With you. and publish iC, correct? A No deal was ever talked about. What we talked about was the possibility of publishing it, is it publishing-worthy, would I need to get a ghostwriter. You know, this is the first time I've ever written a manuscript so I didn't know what I was doing. Q Okay. You contacted Jarred Weisfeld, COLLecE. A COLELeCe.. Q I'm going to mark a document as Defendant's Exhibit 16. It 1S a composite exhibit. (Exhibit 16 marked.) MR. EDWARDS: Thank you. Q (BY MS. MENNINGER) I'm not going to ask you to read every single page of this, but if you look at the first page. A Um-hum. Q Can you tell what this is in terms of what type of document? VIRGINIA GIUFFRE 5/3/2016 257

10 ia LZ 13 14 a 16 3, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page107 of 883 Agren Blando Court Reporting & Video, Inc. calm the anxiety and everything down. Q Before you met Jeffrey Epstein, had you used any drugs? A PULe; Yes. Q Which drugs had you used prior to meeting Jeffrey Epstein? A I smoked pot. I've taken Ecstasy. QO Cocaine? A Yeah, I would have snorted cocaine, um-hum. Q Did you ever abuse alcohol before meeting Jeffrey Epstein? A No, I was -- I wasn't even of age to be able to buy it. I mean, if there was alcohol at parties I would have drank it, but I wouldn't say I abused it. Q Okay. Were there ever occasions upon which you were observed to be drunk by other people, prior to meeting Jeffrey Epstein? A If you're drinking, the possibility of getting drunk is always there. I don't -- I can't recall exact situation where that was the case, DUE: == Q Were you diagnosed as a drug addict prior to meeting Jeffrey Epstein? VIRGINIA GIUFFRE 5/3/2016 333

10 ia LZ 13 14 a 16 9, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page108 of 883 Agren Blando Court Reporting & Video, Inc. AGREN BLANDO COURT REPORTING & VIDEO, INC. 216 - 16th Street, Suite 600 Denver, Colorado 80202 4450 Arapahoe Avenue, Suite 100 Boulder, Colorado 80303 May 11, 2016 Sigrid S. McCawley, Esq. BOLIES, SCHILLER & FLEXNER LLP 401 Fast Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301-2211 Re: Videotaped Deposition of VIRGINIA GIUFFRE Giuffre v. Maxwell Case No. 15-cv-07433-RWS The aforementioned deposition is ready for reading and signing. Please attend to this matter by Following BOTH of the items indicated below: Call 303-296-0017 and arrange with us to read and sign the deposition in our office. XXX Have the deponent read your copy and sign the signature page and amendment sheets, if applicable; the signature page is attached. Read the enclosed copy of the deposition and Sign the signature page and amendment sheets, 1£ applicable; the signature page is attached. XXX WITHIN 30 DAYS OF THE DATE OF THIS LETTER By due to a trial date of Please be sure the original signature page and amendment sheets, if any, are SIGNED BEFORE A NOTARY PUBLIC and returned to Agren Blando for filing with the original deposition. A copy of these changes Should also be forwarded to counsel of record. Thank you. AGREN BLANDO COURT REPORTING & VIDEO, INC. cc: All Counsel VIRGINIA GIUFFRE 5/3/2016 346

Case 18-2868, Document 283, 08/09/2019, 2628241, Page109 of 883 GIUFFRE VS. MAXWELL Deposition VIRGINIA GIUFFRE VOLUME II 11/14/2016 Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017

Case 18-2868, Document 283, 08/09/2019, 2628241, Page110 of 883 Agren Blando Court Reporting & Video, Inc. IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS CONFIDENTIAL VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II November 14, 2016 VIRGINIA L. GIUFFRE, Plaintiff, Vs GHISLAINE MAXWELL, Defendant. APPEARANCES: BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIlUFFRE VOLIUME [TIT 11/14/7016 348

Case 18-2868, Document 283, 08/09/2019, 2628241, Page111 of 883 Agren Blando Court Reporting & Video, Inc. APPEARANCES : (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura Menninger, Esq. Jeffrey S. Pagliuca, Esq. 10 ia LZ 13 14 a 16 dy 18 ig ZU 21 22 Zo 24 25 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jJpagliuca@hmflaw.com Appearing on behalf of the Defendant Also Present: Ann Lundberg, Paralegal Maryvonne Tompkins, Videographer VIRGINIA GIlUFFRE VOLIUME [TIT 11/14/7016 349

10 ia LZ 13 14 a 16 9, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page112 of 883 Agren Blando Court Reporting & Video, Inc. A Yes. Q And you believe the Neiman Marcus was located in which city? A Well, it's around Fort Lauderdale. I can't tell you exactly. Fort Lauderdale is so big, like Broward County? Is that the word for it? Q And what did you do at Neiman Marcus? A I worked in the changing rooms. Q And what did you do in the changing room? A I think I just like -- if I remember right, I just put clothes away that people left in there. Probably went out to get sizes, different sizes for women who wanted different sizes of the Same product. Q And where did you work after Neiman Marcus: A Taco: Be Li... Q Did you work at Southeast Employee Management Company? A I don't recognize that. I don't know if that's a payroll company or what it is. I don't know what Southeast -- what is it called? Q Southeast Employee Management Company. A No, I don't remember that. Q Did you ever work as a temp? VIRGINIA GIlUFFRE VOILIUME [TIT 11/14/7016 470

10 ia LZ 13 14 a 16 3, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page113 of 883 Agren Blando Court Reporting & Video, Inc. A Not that I remember. Q Going to different offices and filling in? A No. Q Did you work for Oasis Outsourcing? A I don't -- I don't know if that's a payroll company or if that's an actual place, but that doesn't ring a bell. Q Did you -- do you know how much you got paid when you were working at places like Oasis Outsourcing? A Well, considering I don't know if I worked at Oasis Outsourcing, I wouldn't even know how much I got paid. Q Did you review your Social Security records? A Yes. Q You saw Oasis Outsourcing listed there? A Right, but like I said, it doesn't even ding a bell at all. Q Do you know how much money they said you made from them? MS. MCCAWLEY: Objection. If you want to show her the documents, she can see what amount is listed and answer your questions, but if you're not going to show her the document, that's the best she VIRGINIA GIlUFFRE VOLIUME [TI 11/14/7016 471

10 ia LZ 13 14 a 16 3, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page114 of 883 Agren Blando Court Reporting & Video, Inc. can do. A Yeah, if you could. I'm happy to answer your guestions. I want to be helpful, so... QO (BY MS. MENNINGER) Great. Well, do you remember how much money you made from Oasis Outsourcing? A Like I said, I don't even remember working For Oasis Outsourcing, or what it is, so I couldn't tell you. Q Do you remember how much money you were making per hour at Neiman Marcus? A No, not off the top of my head. Q Do you know how many months you worked there? A Not long. I'd probably say -- I mean, I don't know. I'm not going to guess. But around the three-month mark would be my -- I don't know the exact anSwer. Q Do you remember any of your coworkers? A INO Q Did you work at Mannino's? A Briefly, yes. O What is Mannino's? A A cute little Italian restaurant in Wellington. VIRGINIA GIlFFRE VOLIUME [TI 11/14/7016 47)

10 Tc LZ 13 14 a 16 3, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page115 of 883 Agren Blando Court Reporting & Video, Inc. Q And what did you do at Mannino's? A I did waitressing. Q And how much did you make? A Oh, I don't know. IT don't remember. Q Did you work at TGI Fridays? A Again, very Shortly. Short time period, and I was a waitress again. Q And how much did you make there? A I have no idea. Q Did you get fired? A No. Q Why did you leave? A I was -- that's around the time period that I was approached by -- I can't remember his name, but he owned a veterinary clinic or he was a vet, one of the two, and he offered me to come work For him. Q When you were working at TG -- TGI Fridays, were you also working at the Roadhouse Grill? A No. QO Those were not at the same time? A I don't know. I don't think so. Maybe consecutively like after each other. Q Do you recall working at the Roadhouse VIRGINIA GIlFFRE VOLIUME [TI 11/14/7016 473

10 ia LZ 13 14 a 16 9, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page116 of 883 Agren Blando Court Reporting & Video, Inc. Grae A Yes: © And why did you leave there? A We all know that the thing that went down there. Tony picked me up and took some money out of a jar, and then I went to go give it back to the guy, thinking that it would be all right, and it wasn't. So I got fired, I think. Q Sure. Okay. I show you some -- are we on i MR. PAGLIUCA: Yes, 9. O (BY MS. MENNINGER) I'd like to show you Defendant's Exhibit 9. (Exhibit 9 marked.) THE DEPONENT: Thank you. Q (BY MS. MENNINGER) Do you recognize your handwriting on this document? A Les. Q Did you fill out an application for employment -A Leo. QO -- on March 26th of 2002? A Yes. Q And where were you living at that time? A I've put down my parents' address, but I VIRGINIA GIlFFRE VOLIUME [TI 11/14/7016 474

10 ia LZ 13 14 a 16 dL. 18 i 20 Zi. 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page117 of 883 Agren Blando Court Reporting & Video, Inc. and seasonal employee, correct? A COrrect . Q And your dad was a full-time year-round employee, right? A Yes. QO He worked there all the time. A Yes. Q And your job was a seasonal employment. A Well, as far as I know -MS. MCCAWLEY: Objection. A -- ~T was hired for the summer, so... O (BY MS. MENNINGER) Right. Okay. So the work hours, in the next paragraph, what -- what is that -- can you just read that bottom paragraph for us? A "The Club never shuts down from November 1st to Mother's Day; for 24 hours a day, 7 days a week, it serves the diverse needs of our members. Therefore to ensure the adequate coverage at all times, departments have arranged different schedules for their employees." Q Okay. I'm going to show you Defendant's Exhibit 20. A Close this one? QO Yeah. VIRGINIA GIlFFRE VOILIME [TIT 11/14/7016 550

10 Tel 12 Ls 14 ale: 16 3, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page118 of 883 Agren Blando Court Reporting & Video, Inc. STATE OF COLORADO) ) SS. REPORTER'S CERTIFICATE COUNTY OF DENVER ) I, Pamela J. Hansen, do hereby certify that I am a Registered Professional Reporter and Notary Public within the State of Colorado; that previous to the commencement of the examination, the deponent was duly sworn to testify to the truth. I further certify that this deposition was taken in shorthand by me at the time and place herein set forth, that it was thereafter reduced to typewritten form, and that the foregoing constitutes a true and correct transcript. I further certify that I am not related to, employed by, nor of counsel for any of the parties or attorneys herein, nor otherwise interested in the result of the within action. In witness whereof, I have affixed my Signature this 23rd day of November, 2016. My commission expires September 3, 2018. Pamela J. Hansen, CRR, RPR, RMR 216 - 16th Street, Suite 600 Denver, Colorado 80202 VIRGINIA GIlUFFRE VOLIUME [TIT 11/14/7016 563

EXHIBIT 6 (Filed Under Seal)

10 Ea 12 13 14 Ais, 16 Li Ls 19 20 21 Ze Zo 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page120 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 IN THE HIGH COURT OF JUSTICE QUEEN'S BENCH DIVISION Claim No. CR 2016 624 BETWEEN : VIRGINIA L. GIUFFRE Applicant, and ROSS GOW, Respondent. AND: UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintifé€, Case No. 15 cv 07433 RWS V. Ghislaine Maxwell, Defendant. ee ee ee ee ae ee Friday, November 18, 2016 AT: 8:27 a.m. Taken at: Essex Chambers 29, 81 Chancery Lane, London, UK, WC2A 1DD Court Reporter: Lisa Barrett, Accredited Real time Reporter DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com

10 La 12 L3 14 LS 16 17 18 Ly 20 ZA ZZ Z3 24 Z0 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page121 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 12 A. No, I have not. oF When you met her last night, did she assist you in preparation for this deposition? A. No. Qi Did she tell you anything about this case? A. No. O. Do you know Ghislaine Maxwell? A. I do know Ms. Maxwell, yes. O. How did you meet her? A. I met her in the offices of Devonshires law firm on or around March 2011. Q. So your first meeting was in person? A First meeting was in person, yes. oF Had you spoken to her prior to that? A I believe that the very first engagement was -I was introduced to her by my chairman Brian Basham but I believe the first words we had were in the Devonshire law office. oy Did Ms. Maxwell retain the services of you or your firm? A. Yes, she did. Q And was that in March of 2011? A. It was. Os Do you have a written agreement? A We did have a written agreement but I can no DTI Court Reporting Solutions New York www.deposition.com 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08:

ay La 12 3 14 Le 16 17 18 Ly 20 ZA ZZ Z3 24 Z0 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page122 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 13 longer locate that agreement. O. Was that agreement ever renewed? A. It was renewed, I believe on or around the beginning of January 2015, potentially the 2nd of January via email. 0. Was the agreement revised when it was renewed? A. It wasn't revised. It was a straightforward re-establishment of the original agreement. O.. Is it your belief that that agreement was in effect on January 2nd, 2015? A. Yes: Q. Do you recall the terms of that agreement? A. Well, it was a re-establishment of an existing agreement so if we go back to the original agreement, it was to provide public relations services to Ms. Maxwell in the matter of Guiffre and her activities. MS. SCHULTZ: I'm marking as Exhibit 2, a document labeled GM 00068. (Exhibit 2 was marked for identification) MR. DYER: Why don't you start making a pile of them, Mr. Gow, because it may be that later on you'll be asked to go back to them. THE WITNESS: Yes, sir. MR. DYER: You don't have copies for me of these documents? DTI Court Reporting Solutions New York www.deposition.com 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08:

eg Lal 12 L3 14 Le 16 17 18 Ly 20 ZA ZZ Z3 24 Zo 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page123 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 14 MS. SCHULTZ: I do not have any more copies on that. MR. DYER: No, no, no, it's much more important that ... just for the purpose of following things, it's easier. BY MS... SCHULTZ: i. Is ross@acuityreputation.com your email address? A. It 1S, my business email, yes. 0. Did you send the email depicted in this document? A. Yes, I did. O. Did you send it on January 2nd, 2015? A. I believe I did. Q. When you sent that email were you acting pursuant to Ms. Maxwell's retention of your services? A. Yes, I was. oF Could you please tell me everything you know about Virginia Roberts Guiffre. MS. MENNINGER: Objection, foundation and form. MR. DYER: You may answer. BY Mow SCHULTZ: Or You testified earlier that you were retained -MR. DYER: Are you withdrawing that question? BY MS. SCHULTZ: DTI Court Reporting Solutions New York www.deposition.com 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08:

ay La 12 3 14 Le 16 17 18 Ly 20 ZA ZZ Z3 24 Zo 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page124 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 15 0. No, I'm not, I'm not. Please -- I am withdrawing that question. MR. DYER: Alright. MS. SCHULTZ: I am withdrawing that question. BY MS. SCHULTZ: oF You testified previously that you were retained to handle matters relating to Virginia Roberts Guiffre; is ‘Chat Correct? A. VOLTECE, O:. Okay. So you are aware of who Ms. Roberts Guiffre 1s? A. I am. oP Okay. Please tell me everything you know about Virginia Roberts Guiffre, please. MS. MENNINGER: Objection, foundation, form, and may call for privileged materials. BY MS. SCHULTZ: oF You can answer -- to the extent that anything you testify to is not protected by a privilege. A. Ms. Roberts first came to my attention on or around March 2011 when I was called into a meeting with Philip Barden and Ms. Maxwell at Devonshires law office, that she had made -- Ms. Guiffre had made extremely unpleasant allegations about Ms. Maxwell's private life. We were -- Acuity Reputation, my firm DTI Court Reporting Solutions New York www.deposition.com 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08:

ie Ld EZ 13 14 LS 6 177 18 de 20 ZI. ZZ 22 24 25 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page125 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 16 was called in to protect Ms. Maxwell's reputation, and to set the record straight. That was -- and that work commenced on or around March of 2011. 6. What do you mean by "set the record straight"? A. Ms. Guiffre's allegations about Ms. Maxwell were, we believe, and to this day continue to believe, untrue, defamatory, and fantastical. And with Devonshires' lawyers, we set about putting out -crafting a statement which would put Ms. Maxwell's point of view across that Ms. Guiffre's allegations were untrue and, frankly, abhorrent. O.. What advice did you give Miss Maxwell as part of your retention? A. It 18 Standard procedure in cases where it's understood that a party may be defaming one's client that one puts out a statement correcting those allegations and providing a clearer picture of where the truth lies. So 1t was very much our counsel that Ms. Maxwell put out a statement, vehemently denying the allegations. Q. When you testified that Ms. Guiffre, I'm going to refer to her by just her married name, came to your attention at that March 2011 meeting at Devonshires with Mr. Barden and Ms. Maxwell, correct, and you learned about her at that meeting; is that correct? A. COrlLeEC... DTI Court Reporting Solutions New York www.deposition.com 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08 08 08 08 08 08 08 08 08 08 +38: 38: 38: 38: ao. 39: 398 39: be 39:

eg Lal 12 L'3 14 Le 16 177 18 i 20 ZA ZZ Z3 24 Zo 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page126 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 31 remaining, So... I've marked as Exhibit 3 RG(UK) 00002. Do you recognize this email? A. I C0. Qi Did you receive this email? A. I did, on the -- on New Year's Day 2015. i. Did you contact Ms. Maxwell after receiving this email? A. Eis. Q. Did you make any response to Mr. Ball in any form? A. I did. iO. Can you tell me what you -- what response you made? ie Well, the response to Mr. Ball was part of a series of responses having spoken to my client within 24 hours or so, we got back to Mr. Ball with an agreed statement which went out to a number of media. Q. When you say "agreed statement" can you tell me more about what you mean? Who agreed to the statement? A. I need to give you some context, if I may, about that statement. So, this is on New Year's Day. I was in France so the email time here of 21:46, in French time was 22:46, and I was getting up early the next DTI Court Reporting Solutions New York www.deposition.com 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 08: 09: 09: 09: 09:

10 i LZ eS 14 1S LG Ly 18 ie, Ziv) ZL Ze Zo 24 Zo 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page127 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 32 morning to drive my family back from the south of France to England, which is a 14-hour journey, door to door. So on the morning of the 2nd of January, bearing in mind that Ms. Maxwell, I think was in New York then, she was five hours behind, so there was quite a lot of, sort of time difference between the various countries here, I sent her an email, I believe, Saying -- parsing this -- forwarding this email to her saying "How do you wish to proceed?" And then I was on the telephone -- I had two telephones in the car, I received in excess of 30 phone calls from various media outlets on the 2nd of January, all asking for information about how Ms. Maxwell was looking to respond to the latest court filings, which were filed on the 30th of December as I understand. And by close -- towards close of play on the 2nd, I received an email forwarded by Ms. Maxwell, containing a draft statement which my understanding was the majority of which had been drafted by Mr. Barden with a header along the lines of "This 1s the agreed statement." At close of play on the 2nd. So I -- I was -- I had gone under the Channel Tunnel and I was sitting on the other side and that email, which my understanding was that it had DTI Court Reporting Solutions New York www.deposition.com 09: oe 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: oe 09: 09: 09: 09: 00: 00: 00 00 00 00: 00% 00: 00: 00 00: 00: 01: OnE. Oebs oe ia 01: 01: O14 Q1 01 Ql: 01: 01: 14 17 “77 :26 :28 30 35 38 41 °45 50 54 00 04 10 13 16 33 36 39 :44 :48 50 54 a

Le Li EZ 13 14 LS 6 Ly 18 Lo 20 Zk 22 23 24 25 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page128 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 33 been signed off by the client, effectively, was then sent out to a number of media, including Mr. Ball and various other UK newspapers. o. Mr. Gow, when you say "end of play" and "close of play," are you referring to sending the email that's Pete: 2. A. Yes, I am. MR. DYER: My understanding is that it went to people other than those listed? THE WITNESS: Yes, that is -MR. DYER: Just a sample. THE WITNESS: That 1s a sample. Everyone who effectively -- well, the detail on this, I was driving, so my eldest son in the back had my BlackBerry and was trying to capture -- it was a pretty chaotic day. Most people in the UK were on holiday. In fact, 1t was a holiday weekend, our office was closed, my PA was on holiday, so my son was basically doing an internship in the back of the car, downloading the names of the callers from various media outlets and -- so we had a list of those so when I got to the car park, at the end of the Eurotunnel thing in the UK, I had numerous names, so the email went out to a wide range of people. But the 30 or so calls I had is an aggregate number, so there might have been five calls from the BBC DTI Court Reporting Solutions New York www.deposition.com 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: “24 229 :30 +34 “35 a :4() 43 48 ‘02 “(5 09 14 aay

ay La 12 L3 14 LS 16 17 18 Ly 20 ZA ZZ Z3 24 Zo 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page129 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 44 10 more seconds. MS. SCHULTZ: Understood, and I apologize. MR. SPEARMAN: This is what, Exhibit 9? MR. DYER: Yes. MS. SCHULTZ: Yes. (Exhibit 9 was marked for identification.) Be Mo. DpCoULIA: 0, This also appears to be an email chain with you and Ms. Maxwell; is that correct? A. It does appear to be so. 0, Did you send the top email of the chain that says "Okay, G, going with this"? A. 7, Oa: oF And did you receive from Ms. Maxwell, the bottom email of that chain? As I believe so. Well, I believe -- yes, yeah, it was forwarded from Ms. Maxwell, yes. MR. DYER: Sorry, I don't quite understand that answer. THE WITNESS: I misspoke that. I did receive it from Ms. Maxwell. MR. DYER: Okay. BY MS. SCHULTZ: Q. The subject line does have "FW" which to me indicates it's a forward. Do you know where the rest of DTI Court Reporting Solutions New York www.deposition.com 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09:

Case 18-2868, Document 283, 08/09/2019, 2628241, Page130 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 45 1 this email chain 1s? 09:20:45 Z A. My understanding of this is: It was a holiday 09:20:49 3 in the UK, but Mr. Barden was not necessarily accessible, 09:20:54 4 at some point in time, so this had been sent to him 09:20:59 5 originally by Ms. Maxwell, and because he was 09:21903 6 unavailable, she forwarded it to me for immediate action. 09:21:07 7 I therefore respond, "Okay, Ghislaine, I'll go with 09:21:14 8 this." 09:21:19 9 It is my understanding that this is 09:21:20 10 the agreed statement because the subject of the second | 09:21:22 11 one is "Urgent, this is the statement" so I take that 09:21:24 12 as an instruction to send it out, as a positive 09:21:27 13 command: "This 1s the statement." 09:21:30 14 Q. Okay. UO Zs3 3 Ls A. And I say, "Thanks, Philip" because I'm aware 09:21:33 16 of the fact that he had a hand, a considerable hand in 09:21:37 17 the drafting. 09:21:40 18 e., Okay. Could I ask you to please refer back to 09:21:41 19 Exhibit 2. Looking also at Exhibit 9, Exhibit 9 appears 09:21:47 20 to have five sentences in it. Do you agree that those 223 21 same five sentences are part of the communication that is 09:22:10 22 borne in Exhibit 2? 09s22¢13 23 A. Sorry, could you say that again. I'm just 09:22:18 24 following what your -- 09:22:20 25 Q. It was a bad question. Let me try that again. 00322421 DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com

10 Lal 12 L3 14 LS 16 17 18 Ly 20 ZA ZZ Za 24 Zo 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page131 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 64 Q. Okay. Have you ever communicated anything regarding Ms. Guiffre's criminal allegations to the press or the media? A. As part of a wider conversation about her unsavory allegations about Ms. Maxwell, it's possible that I might have done, but I can't recall the detail, I'm afraid. O. Do you -- do you remember discussing that with The Guardian? A. No, I don't. I'm not saying I didn't but I can't recall. You have to bear in mind, if you'd be so kind, that I've been speaking to over 30 journalists and media outlets about this, and I can't recall every single -- the detail of every single conversation. Or Earlier you testified with regard to Exhibit 2 that in the days following sending that email, you also communicated with other press and media outlets. Do you recall today any of the other press and media outlets you communicated with, in addition to those listed at the top of that email? A. The Guardian, The Sun, from the top of my memory, but in addition to -- in addition to emails there would have been telephone calls and I'm -- there may not be a transcript of those calls, these are emails inter alia, others, and I can't recall every single email that DTI Court Reporting Solutions New York www.deposition.com 09: 09: 09: 09: Cee 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09:

10 et LZ 1 14 Le LG Ly 18 Ly 20 Zi 22 23 24 25 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page132 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 66 from John Swain? A. I believe I did. O. That's all the questions I have about that document. A. Thank you. Oi. Regarding communications you made after sending the email in Exhibit 2, I believe, and please correct me 1f I'm wrong, you testified that you received 30 or more calls that were -- that you would classify as press inguiries regarding Ms. Guiffre; is that correct? A. Les: Q. Do you recall emailing the statement to other entities beyond what is on the list on Exhibit 2? A. Yes, I think I answered that previously. Yes, I mean there is a far -- I said inter alia, so there is a wider range of people that I would have emailed it to in response to incoming queries -Q. Do: you == A BUG... == Q. DOLLY. A. I can't remember every single one. Q Do you recall ever reading the statement to the press or the media over the phone? A. It's very possible that I would have done so, yes. DTI Court Reporting Solutions New York www.deposition.com 09: 09: 09: UD 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: 09: Uo. 09: 09: 09:

Le Li EZ 13 14 LS 6 177 18 de 20 ZI. ZZ Wi 24 25 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page133 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 67 MR. DYER: Do you mean Exhibit 2? MS. SCHULTZ: Yes. Exhibit 2. THE WITNESS: To be clear, Exhibit 2 was the base document. MS. SCHULTZ: Uh-hmm. THE WITNESS: In addition to the 2011 March statement. Those were the two working documents that were always referred to, both of which -- well, the first one was in a public domain and was on record on the Devonshires -- on -- with Devonshires name at the top on PR Newswire which is a global delivery service. So that was easily accessible by people. And the second one was the -- further to the 2nd of January 2015. BY- MS. SCHULZ: oF To the extent you can recall or could estimate, how many other emails do you believe you sent bearing that statement that's in Exhibit 2? A. I really can't remember but certainly more than six and probably less than 30, Somewhere in between. Any time there was an incoming query 1t was either dealt with on the telephone by referring them back to the two statements of March 2011 and January 2015 or someone would email them the statement. So no one was left unanswered, broadly, is the -- 18 where we were. But I can't remember every DTI Court Reporting Solutions New York www.deposition.com 09: 10: 10: 10 10: 10: Ls is Ls 10: 1 1) 1): 1: 10: 10 10 10 10 10 10 10 10 10 10 ey ‘00: ge ‘00: ‘00: ‘00: ys “tL os 1s

10 i 12 L3 14 LS 16 17 18 Ly 20 ZA ZZ Z3 24 Zo 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page134 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 68 Single person we reached out to. oF Okay. So is it your testimony that you reached out to individuals who did not first contact you? A. No. We were in response mode. Oi. Okay. A. There was enough to do responding to incoming queries, I wouldn't have been making more work, to be honest. O. Alright. MR. DYER: So journalists paid no attention to your "No further communication will be provided on the Maller.” A. No -- that's quite correct, sir, and there probably was a -- it's regarded as tweaking their tales. BY MS. SCHULTZ: Q. Mr. Gow, I'm handing you what I've marked as Exhibit 14. The Bates number is RG(UK) 000004. I'll give you a moment to look at it. (Exhibit 14 was marked for identification. ) BY Ms. SCHULTZ: oF Thank you. Toward the top of the page there is a passage that reads: "Apologies, should read Virgina Roberts all the way through." [As read] DTI Court Reporting Solutions New York www.deposition.com i) 10: ie 10: Ie 108 10: 10: as 10: 10: Iie 10: 10: 10: 10: 10: iG 10: 10: 10: ie 10 Ie ‘42 -44 47 :48

ay La 12 3 14 Le 16 17 18 Ly 20 ZA ZZ Z3 24 Zo 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page135 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 109 servicing ultra high net worth clients, individuals, corporates, governments and NGOs, managing their media relations and protecting their reputation. On Approximately how long have you been providing such services? A. Acuity was set up in 2010. (Exhibit 26 was marked for identification.) BY MS. SCHULTZ: O. I'm going to hand you what I've marked as Exhibit 26. A. Thank you. Q. Does this document fairly depict pages from your -- from Acuity Reputation's website? Rs It does. Or Do you see where it says "We manage reputation and forge opinion through public relations, strategic communications and high level networking"? A. TOs. Q Is that a true statement? A. Say 1t again. Sorry. OO Is that a true statement? A It is, yes. I wrote that statement. MR. DYER: Sorry, you read it or you wrote it? THE WITNESS: I wrote it, so I do recognize it. BY MS. SCHULTZ: DTI Court Reporting Solutions New York www.deposition.com ie 11: Lis 1a 11: Lis 1s Lis ine. 11: Lis Tis Lis 13 Lis Lis ine 11: 11: rs ie 18 Lis

10 et LZ 1 14 Le 16 ky 18 Ly 20 21 22 23 24 Zo 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page136 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 110 or Is it correct that public relations and strategic communications are things that you personally do as part of your professional activities? A. I personally -- I'm involved in public relations and strategic communications, yes. O:. Is it correct that the media is the intended recipient of this strategic communications. A. It's -- the -- it's a larger ground than just the media. There may be lobbyists, government think tanks, focus groups, government departments. 0. Would it be fair to say that the media is often the intended recipient of strategic communications? A. It 18 a frequent recipient. oO. Referent recipient? A. But not the sole recipient. O:, Okay. Do you see where your website claims that your company has "excellent relationships with the media"? A. TOO Is that a true statement? A. That is true, yeah. MR. DYER: Except Mr. Syson. THE WITNESS: Except Mr. Syson, Sir. MS. SCHULTZ: Of course. THE WITNESS: And representatives of the Daily DTI Court Reporting Solutions New York www.deposition.com Ls 11: Lhe 1s 11: Ls Le 11: Ls iis 11: Lis Is 13 13 Lis 11: Lh 11: 11: ie 1a 13 Lis

ey Lal 12 L3 14 LS 16 17 18 Ly 20 ZA ZZ Z3 24 Zo 1. ‘600: 325 3375 Case 18-2868, Document 283, 08/09/2019, 2628241, Page137 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 11d Mirror. BY. Ms... SCHULTZ: OO. Is it correct that you advertise your "excellent relationships with the media" because your services often include giving communications to the media on behalf of your clients? A. Ves. MS. SCHULTZ: That's all I have for right now. MR. DYER: I just wanted to ask you one question about Exhibit 25. This was the email from the New York Daily News to you which you sent on to Ms. Maxwell and Mr. Barden. THE WITNESS: Yes. MR. DYER: Do you recollect whether you were asked to make any statement in response to this matter, the issue of proceedings in September of last year? THE WITNESS: I don't, sir. It's always been the case that Mr. Barden and I were encouraging Ms. Maxwell to make a statement, but she was very reluctant to do so. MR. DYER: Right. I think you've got him to accept that up until some time March, April, May, he may have spoken to Mr. Syson. And that was the last statement that there's any evidence of him making about this matter. But on the evidence, as I understand it, DTI Court Reporting Solutions New York www.deposition.com Ls 11: Lis 1a 11: iis 1 Lis Lbs iis 11: Li Lis Ie 13 13 11: Lis Li 11: 11: Fie ie 18 Lis

eC ie LZ i 14 ies 16 Ly 18 i 20 ZA. Ze 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page138 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 127 CERTIFICATE OF COURT REPORTER I, Lisa M. Barrett, an Accredited Real-time Reporter, hereby certify that the testimony of the witness Ross Neil Sutherland Gow in the foregoing transcript, numbered pages 1 through 122, taken on this 18th day of November, 2016 was recorded by me in machine shorthand and was thereafter transcribed by me; and that the foregoing transcript 1S a true and accurate verbatim record of the said testimony. I further certify that I am not a relative, employee, counsel or financially involved with any of the parties to the within cause, nor am I an employee or relative of any counsel for the parties, nor am I, in any way, interested in the outcome of the within Cause. DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com

EXHIBIT 7 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page140 of 883 Page l UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS aces en mem? is ie) ml + noi Gm) ms iG SG X VIRGINIA L. GIUFFRE, Plaintiff, Ve GHISLAINE MAXWELL, Defendant. ceed GS Z| dS SG Sd xX June 20, 2016 9:12 a.m. CONFIODENTI.IATL Deposition of x pursuant to notice, taken by Plaintiff, at the offices of Podhurst Orseck, 25 West Flagler Street, Suite 800, Miami, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page141 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 54 ME — CONFIDENTIAL. BY MR. EDWARDS: Q. When you got to his house, you were requested to give a massage? MR. PAGLIUCA: Object to foundation and form. THE WITNESS: I don't exactly remember. I don't remember if I was asked in the kitchen. I don't remember if -- I don't remember. BY MR. EDWARDS: Q. Massage was part of the game, though? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: I don't remember. I'm sorry. BY MR. EDWARDS: Q. But even during this deposition today, we have described at times you giving him a massage? ie Yes. You're asking about my first encounter, though. Q. Sorry, I'm just trying to sum up the whole thing. A. Okay. Q. Was massage part of the lure to get you specifically to his house? VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page142 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 55 ee — CONFIDENTIAL As Yes. MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. And at the time, you are 15, 16 or 17 years old? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Yes. BY MR. EDWARDS: Q. No massage experience? A. No. Q. You were told to bring other girls to his house? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: After a while, yes. BY MR. EDWARDS: Q. These massages were turned sexual by Jeffrey, as opposed to by anyone else? Pin Jeffrey took my clothes off without my consent the first time I met him. Q. The massages were scheduled by people working for Jeffrey? VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page143 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 56 ee — CONFIDENTIAL As I don't recall. MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. Jeffrey Epstein, during these massages, would use sex toys or have sex toys used? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Well, at that point, it's no longer a massage. Something else is going on. But, yes, he would take out adult toys and different things. BY MR. EDWARDS: Q. While you were a teenager, Jeffrey Epstein asked you to live with him? A. Yes. He wanted me to be emancipated. Q. Jeffrey Epstein encouraged girl-on-girl Sex? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Yes. BY MR. EDWARDS: Q. And after you cooperated with the police, you were intimidated by people working for Jeffrey VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page144 of 883 ‘io CO N WD Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 5/7 ME = CONFIDENTIAL. Epstein? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Yes. MR. EDWARDS: All right. I don't have anything further for you. I apologize that we even had to go through this, all right? THE WITNESS: Okay. EXAMINATION BY MR. PAGLIUCA: Q. Ms. MM, by name is Jeff Pagluica. I live in Denver, Colorado. And, like you, I don't want to be here today either, okay? I would rather be in Denver. I just want to -- as I understand it, and I'm not trying to get into any of your treatment over the last, let's say, 10 years, because I don't know how long it's been, but as I understand what you and your lawyer have said here today, you have been involved in some number of years of therapy, in which the purpose -- part of the purpose of the therapy has been to forget all of these events that Mr. Edwards was asking you questions about; is that correct? VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page145 of 883 OB WN F 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 71 ME = CONFIDENTIAL CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, the undersigned authority, certify that A, pecsonally appeared before me and was duly sworn. WITNESS my hand and official seal this 23rd day of June, 2016. Kelli Ann Willis, RPR, CRR Notary Public, State of Florida Commission FF928291, Expires 2-16-20 +++ ++ 4+ 4+ 4+ 4+ 4+ 4+ 4+ 4+ 4+ 4+ 4+ 4+ 4 CERTIFICATE STATE OF FLORIDA _ ) COUNTY OF MIAMI-DADE ) I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime Reporter do hereby certify that I was authorized to and did stenographically report the foregoing deposition of IN that a review of the transcript was not requested; and that the transcript is a true record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 23rd day of June, 2016. KELLI ANN WILLIS, RPR, CRR VMAGNA®S

EXHIBIT 8 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page147 of 883 Page l UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA L. GIUFFRE, Plaintiff, V. CASE NO.:15-CV-07433-RWS GHISLAINE MAXWELL, Defendants. January 25, 2017 9:05 a.m. - 12:44 p.m. 401 E. Las Olas Boulevard Fort Lauderdale, Florida *kxkx CONFIDENTIAL ¥*** VIDEOTAPE DEPOSITION OF SARAH KELLEN Taken on behalf of the before Michael J. D'Amato, RMR, Notary Public in and for the State of Florida at Large, pursuant to Notice of Taking Deposition in the above cause. Job # 293966 MAGNA®S

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page148 of 883 Page 15 decline to answer. Q. Who introduced you to Ghislaine Maxwell? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. Q. When you met Ghislaine Maxwell was she working for Jeffrey Epstein? Pe On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. Q. Did Ghislaine Maxwell work as a recruiter for young girls for Jeffrey Epstein when you met her? Ds On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. Q. I'm defining young girls to mean females the ages 12 to 23. Do you understand that? ae On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. Q. Didn't Ghislaine Maxwell approach you to MAGNA®S

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page149 of 883 Page 20 girls for sex with Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. Q. Did you assist Ghislaine Maxwell in procuring underage girls for sex with Jeffrey Epstein? A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. QO. Isn't it true that Ghislaine Maxwell would recruit underage girls for sex and sex acts with Jeffrey Epstein? Ds On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. Q. Did Ghislaine Maxwell give you information on what underage girls she had contact information for? Dis On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege which I understand protect the innocent and therefore I must unfortunately decline to answer. Q. Did Ghislaine Maxwell teach you to offer these MAGNA®S

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page150 of 883 Page 199 CERTIFICATE OF COURT REPORTER IT, MICHAEL J. D'AMATO, a Registered Merit Reporter and Notary Public in and for the State of Florida at Large, do HEREBY CERTIFY that I was authorized to and did stenographically report the deposition of SARAH KELLEN; that a review of the transcript was requested; and that the foregoing transcript, pages from 1 to 197, is a true and accurate record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 27th day of January 2017. MICHAEL J. D'AMATO, Registered Merit Reporter MAGNA®S

EXHIBIT 9 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page152 of 883 Page l IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS VIDEOTAPE DEPOSITION OF: PETER KENT November 29, 2016 VIRGINIA L. GIUFFRE, Plaintiff, V. GHISLAINE MAXWELL, Defendant. PURSUANT TO SUBPOENA AND NOTICE, the videotape deposition of PETER KENT was taken on behalf of the Plaintiff at 150 East 10th Avenue, Denver, Colorado 80230, on November 29, 2016, at 9:00 a.m., before Sandra L. Bray, Registered Diplomate Reporter, Certified Realtime Reporter, and Notary Public within Colorado. MAGNA LEGAL SERVICES (866) 624-6221 MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page153 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 25 MS. McCAWLEY: I'm just asking about his retention, which I believe is discoverable under Rule 26. Q. (BY MS. McCAWLEY) Do you recall whether you were retained to perform work for one expert or two experts? THE DEPONENT: Am I allowed to answer this? MR. PAGLIUCA: Yes. A. I actually don't recall. Q. (BY MS. McCAWLEY) Do you know whether you were provided with one report or two reports when you initially were retained? Be I believe I was provided with both the reports at the same time. QO. Let me turn to about halfway back. So it's going to be -- there's markings on the bottom. It says PK-0O05. Bus Yes. QO. And it indicates an amount there, an invoice. Is this one of your invoices? A. Yes. QO. It indicates an amount of $17,875? Ps Yes. Q. Is that the total amount you've been MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page154 of 883 10 11 12 13 14 is 16 17 18 19 20 21 22 23 24 25 Page 26 paid, with the exception of what we paid you for your testimony here today, in this matter? As I think so. What date was this? QO. It looks like it's dated October 29th, 2016. Be Oh, yes. In that case, yes. Q. Have you performed any work after that date that you've been paid for? a Only in preparation for this deposition. Q. Have you been paid for that work? A. No. Q. No. Have you invoiced that work yet? A. No. Q. All right. And then I'm going to turn you to the next page -- please don't put it away yet -- which appear to be invoices. Be Time sheets. QO. Time sheets? You tell me. A It's a time sheet. QO. Is this typically how you record your time when you're doing expert work? A. Yes. QO. And this indicates -- the first entry is on 9/28/2016. Is that when you commenced work on this matter? MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page155 of 883 Page 162 REPORTER'S CERTIFICATE STATE OF COLORADO ) ) ss. CITY AND COUNTY OF DENVER _) I, SANDRA L. BRAY, Registered Diplomate Reporter, Certified Realtime Reporter, and Notary Public ID 20084001729, State of Colorado, do hereby certify that previous to the commencement of the examination, the said PETER KENT was duly sworn by me to testify to the truth in relations to the matters in controversy between the parties hereto; that the said deposition was taken in machine shorthand by me at the time and place aforesaid and was thereafter reduced to typewritten form; that the foregoing is a true transcript of the guestions asked, testimony given, and proceedings had. I further certify that I am not employed by, related to, nor of counsel for any of the parties herein nor otherwise interested in the outcome of this litigation. IN WITNESS WHEREOF, I have affixed my Signature this 8th of December, 2016. My commission expires January 16, 2020. X Reading and Signing was requested. Reading and Signing was waived. Reading and Signing is not required. MAGNA®S

EXHIBIT 10 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page157 of 883 Page l UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK oy ee eee ee a ae eae a VIRGINIA L. GIUFFRE, Plaintiff, Case No.: 15-cv-07433-RWS -againstGHISLAINE MAXWELL, Defendant. CON FIODENTIAL Videotaped oral deposition of NADIA MARCINKO, taken pursuant to notice, was held at the law offices of BOIES SCHILLER & FLEXNER, LLP, 575 Lexington Avenue, New York, New York commencing January 17, 2017, 1:04 p.m., before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page158 of 883 Page 10 1 N. Marcinko - Confidential 2 reside, a dwelling that is paid for by either 3 Jeffrey Epstein or Ghislaine Maxwell? 4 A. same answer. 5 Q. Do you know Jeffrey Epstein? 6 A. Same answer. 7 QO. Do you know Ghislaine Maxwell? 8 Ps Same answer. 9 Q. How Old were you when you met 10 either Jeffrey Epstein or Ghislaine Maxwell? 11 A. Same answer. 12 QO. Who introduced to you Ghislaine 13 Maxwell? 14 A. Same answer. 15 QO. When you met Ghislaine Maxwell, was 16 she working for Jeffrey Epstein? 17 A. Same answer. 18 Q. Did Ghislaine Maxwell work as a 19 recruiter of young girls for Jeffrey Epstein 20 when you met her? 21 A. Same answer. 22 Q. Did Ghislaine Maxwell instruct you 23 to recruit young girls for Jeffrey Epstein? 24 A. Same answer. 25 QO. Did Ghislaine Maxwell encourage MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page159 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 12 N. Marcinko - Confidential Ghislaine Maxwell? A. same answer. QO. Have you observed Ghislaine Maxwell and Jeffrey Epstein offering these young girls money, education or other things of value during the massage to get that young girl to return to Jeffrey Epstein for sexual purposes? A. same answer. QO. Have you observed Ghislaine Maxwell and Jeffrey Epstein convert what started as a massage with these young girls into something sexual? A. same answer. oF Have you understood when I talk about young girls, I'm talking about girls between the age range of 13 and 23 years old? A. same answer. Q. Have you observed that when Ghislaine Maxwell and Jeffrey Epstein used the term, massage, it always includes sex? A. same answer. QO. Was massage a word used by Ghislaine Maxwell to lure girls into sex with MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page160 of 883 O1 11 12 13 14 15 16 17 18 19 20 rat 22 23 24 25 Page 96 CERTIFICATE I HEREBY CERTIFY that the witness, NADIA MARCINKO, was duly the deposition testimony gi Sworn by me and that Registered Professional Reporter Dated: January (The foregoing this transcript does not reproduction of the same under the direct control 17, 2017 certification of apply to any by any means, unless and/or supervision of the certifying reporter.) MAGNA®S

EXHIBIT 11 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page162 of 883 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK — — LS SS a C—- — i — — —— — << ac lo. ms, cme °/iamme xX VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendants. ee a a rr — a —— X * * CONF IDENTIAL* * Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 MAGNA® Page l

Case 18-2868, Document 283, 08/09/2019, 2628241, Page163 of 883 Page 23 1 G Maxwell - Confidential 2 QO. T'm not talking about friends. I'm 3 talking about individuals -4 MR. PAGLIUCA: I'm going to object 5 to you interrupting the witness who was 6 answering your question. The question 7 was, have you ever seen anyone, female 8 under the age of 18 at the house and 9 that's the question she was answering. 10 If you want to strike that guestion and 11 ask another question, feel free, but let 12 the witness respond, please. 13 MS. McCAWLEY: I will do that. 14 QO. Have you ever observed a female 15 under the age of 18 at Jeffrey Epstein's home 16 that was not a friend, a child -- one of your 17 friend's children? 18 A. Again, I can't testify to that 19 because I have no idea what you are talking 20 about. 21 Oz You have no idea what I'm talking 22 about in the sense you never observed a 23 female under the age of 18 at Jeffrey 24 Epstein's home that was not one of your 25 friend's children, is that correct? MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page164 of 883 Page 24 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 Ps How would I possibly know how 5 someone is when they are at his house. You 6 are asking me to do that. I cannot possibly 7 testify to that. As far as I'm concerned, 8 everyone who came to his house was an adult 9 professional person. 10 Q. Are you familiar with the police 11 report that was issued in respect to the 12 investigation in this matter? 13 MR. PAGLIUCA: Object to the form 14 and foundation. 15 Q. Are you familiar with the police 16 report that was used in this matter, the 17 investigation of Jeffrey Epstein, has been 18 produced as a document in this matter? 19 Bs IT have seen a police report. 20 (Maxwell Exhibit 1, police report, 21 marked for identification. ) 22 QO. The police report that you have in 23 front of you, can you turn to page 28 of that 24 report, the numbers are on the top right-hand 25 corner. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page165 of 883 Page 31 1 G Maxwell - Confidential 2 -- just another one of Virginia's many 3 fictitious lies and stories to make this a 4 Salacious event to get interest and press. 5 It's absolute rubbish. 6 Q. Were you in charge of hiring 7 individuals to provide massages for Jeffrey 8 Epstein? 9 A. My job included hiring many people. 10 There were six homes. As I sit here, I hired 11 assistants, I hired architects, I hired 12 decorators, I hired cooks, I hired cleaners, 13 I hired gardeners, I hired pool people, I 14 hired pilots, I hired all sorts of people. 15 In the course and a very small part 16 of my job was from from time to time to find 17 adult professional massage therapists for 18 Jeffrey. 19 Q. When you say adult professional 20 massage therapists, where did you find these 21 massage therapists? 22 ae From time to time I would visit 23 professional spas, I would receive a massage 24 and if the massage was good I would ask that 25 man or woman if they did home visits. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page166 of 883 Page 41 1 G Maxwell - Confidential 2 Os Did you hire her? 3 Ps First of all, I don't hire girls 4 like that, so let's be clear, I already 5 testified to that, and I have no idea what 6 you are referring to. 7 Q. When you say girls like that, what 8 do you mean? 9 A. I hire people who are professional 10 at the house. You are asking if I hired 11 somebody to do what, I don't know what you 12 are talking about. I hired people to work in 13 the homes. 14 QO. What was Nadia Marcinkova doing? 15 MR. PAGLIUCA: Object to the form 16 and foundation. 17 a I have no idea what Nadia 18 Marcinkova was doing. I didn't hire her and 19 I don't know what you are referring to. 20 Q. You met Nadia Marcinkova? 21 ae I testified I did. 22 QO. Did she work for Jeffrey Epstein? 23 ae I have no idea what she did. 24 Q. Have you flown on planes with Nadia 25 Marcinkova? MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page167 of 883 Page 7/ 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I don't know what that means, 5 masseuse obligation, I don't know what you 6 are referring to. Would you like to ask the 7 question properly? 8 Q. I think it was proper. I will ask 9 it again. 10 Did you ever assist in getting 11 Virginia Roberts a cell phone to use during 12 the time that she worked for Jeffrey Epstein? 13 A I have no recollection of doing 14 anything of that nature. 15 Q. Did you ever tell Virginia that you 16 wanted her to have a cell phone so that she 17 could be on call regularly? 18 A. IT have no recollection of that 19 conversation. 20 QO. How often would Virginia come over 21 to the house in Palm Beach to give massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 Fiz Ask the question again, please. 25 Q. How often did Virginia Roberts come MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page168 of 883 Page 78 1 G Maxwell - Confidential 2 over to the house in Palm Beach to give 3 massages? 4 Ais It's important to understand that I 5 wasn't with Jeffrey all the time. In fact, I 6 was only in the house less than half the 7 time, so I cannot testify to when I wasn't in 8 the house how often she came when I wasn't 9 there. 10 What I can say is that I barely 11 would remember her, if not for all of this 12 rubbish, I probably wouldn't remember her at 13 all, except she did come from time to time 14 but I don't recollect her coming as often as i she portrayed herself. 16 Q. How many times a day on an average 17 day would Jeffrey Epstein get a massage? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. When I was at the house and when I 21 was there with him, he received a massage, on 22 average, about once a day. 23 Q. Just once? 24 A. Yes. 25 Q. Were there days when he received MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page169 of 883 Page 79 1 G Maxwell - Confidential 2 four or five? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. When I was present at the house, I 6 never saw something like that. 7 QO. Do you know if Virginia was 8 required to be on call at all times to come 9 to the house if Jeffrey wanted her there? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I have no idea of the arrangements 13 that Virginia made with Jeffrey. 14 Q. When Virginia was in New York, 15 would Virginia sleep at Jeffrey's mansion in 16 New York? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 Bs I don't recollect her being in New 20 York and I have no idea where she slept. 21 QO. You don't ever remember seeing 22 Virginia Roberts in New York? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 Pes I would barely recollect her at MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page170 of 883 Page 135 1 G Maxwell - Confidential 2 him at any of those homes? 3 Ps Again, Virginia is absolutely 4 totally lying. This is a subject of 5 defamation about Virginia and the lies she 6 has told and one of lies she told was that 7 President Clinton was on the island where I 8 was present. Absolutely 1000 percent that is 9 a flat out total fabrication and lie. 10 Q. You did fly on planes, Jeffrey 11 Epstein's planes with President Clinton, is 12 that correct? 13 Bs I have flown, yes. 14 QO. Would it be fair to say that 15 President Clinton and Jeffrey are friends? 16 Px I wouldn't be able to characterize 17 it like that, no. 18 Q. Are they acquaintances? 19 A. I wouldn't categorize it. 20 Q. He just allowed him to use his 21 plane? 22 Bs I couldn't categorize Jeffrey's 23 relationship. 24 Q. When you were on the plane with 25 Jeffrey and President Clinton, did you MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page171 of 883 Page 144 1 G Maxwell - Confidential 2 building that you would have seen when you 3 were on the trip in Europe? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I can't possibly answer that. 7 Q. Do you recall Virginia ever taking 8 pictures? 9 A. I barely recall Virginia, period. 10 Q. Do you recall her ever taking 11 pictures? 12 A. No, I don't. 13 Q. I'm going to direct your attention, 14 still within the flight logs to -- starting 15 on the next page from where you just were 16 which is going to be 000747. And the date at 17 the top says 2001, you will see March and I'm 18 directing your attention down towards the 19 middle to the bottom where you will see the 20 numbers 27, 29 and 3l. 21 As Uh-huh. 22 Q. And we've got actually I'm going to 23 direct your attention to the one that starts 24 with TEB for Teterboro to SAF for Santa Fe 25 and the one below it Santa Fe to Palm Beach MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page172 of 883 Page 147 1 G Maxwell - Confidential 2 her but you would have to ask Jeffrey what he 3 brought her on the trip for. 4 QO. But she would travel with him when 5 there was a work trip like this? 6 A. I can't -- I'm seeing that she is 7 on this flight but I have no idea what she is 8 doing, he invited her, it would not be my 9 job. 10 Q. What about Nadia Bjorlin, would she 11 regularly travel with Jeffrey on flights? 12 A. I have no idea, you would have to 13 look through the flight logs. I have no 14 idea. 15 Q. Your recollection is -- what is 16 your recollection, do you recollect Nadia 17 traveling often on flights with Jeffrey? 18 A. Absolutely not. No, not at all. I 19 don't recollect her actually on the flight at 20 all. 21 Q. I think you can set that aside for 22 the moment. 23 (Maxwell Exhibit 9, message pad 24 pages, marked for identification. ) 25 Q. We will mark as Exhibit 9 these MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page173 of 883 Page 148 1 G Maxwell - Confidential 2 excerpts from -- we will identify what they 3 are but from the message pads. 4 Did you want to correct anything? 5 Pes I want to make an addendum. 6 Would you mind rereading the last 7 question back to me? 8 (Record read.) 9 A. I also just want to say that at 10 this point I cannot recollect flying to 11 parties. Jeffrey went for work so -- was 12 this in Santa Fe, this flight as well. 13 Q. The flight we were looking at, yes 14 but it was to Santa Fe -15 ae I don't recall going to any parties 16 in Santa Fe at any time but certainly flying 17 to Santa Fe for a party seems highly 18 improbable. 19 QO. So I'm going to direct your 20 attention to the document that I set before 21 you which is Bates number SAO 01456 and it 22 has different Bates numbers because it's a 23 smaller version of the larger production. 24 These are the pages I will be asking about. 25 In the time that you were working MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page174 of 883 Page 149 1 G Maxwell - Confidential 2 with Jeffrey in Palm Beach, do you recall a 3 process for taking, anybody at the house 4 taking messages when incoming phone calls 5 came in? 6 Bis You are supposed to take a message 7 and receive the message and write the message 8 down. Who was the message was for, what time 9 it was taken and who took it and what the 10 message was, obviously. 11 QO. Does what's in front of you look 12 familiar with respect to the message pads 13 that you would have used at the house? 14 A. It is familiar. 15 Q. I'm going to direct your attention 16 to the second page of it? 17 MR. PAGLIUCA: These all have SAO 18 numbers on them or Bates ranges and I 19 don't see any of your Bates ranges on 20 these. I know you have produced message 21 pads but those have your Bates range 22 numbers on them and I'm wondering if 23 these are different documents. 24 MS. McCAWLEY: It's the same, just 25 ours have the Bates underneath them. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page175 of 883 Page 174 1 G Maxwell - Confidential 2 believe. Do you believe -3 Pug I can only testify -4 QO. Let me finish the question so the 5 record is clear. 6 Do you believe Jeffrey Epstein 7 sexually abused minors? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 Q. You can answer. 11 ae I can only testify to what I know. 12 I know that Virginia is a liar and I know 13 what she testified is a lie. So I can only 14 testify to what I know to be a falsehood and 15 half those falsehoods are enormous and so I 16 can only categorically deny everything she 17 has said and that is the only thing I can 18 talk about because I have no knowledge of 19 anything else. 20 Q. I'm not asking about Virginia. I'm 21 asking whether you believe that Jeffrey 22 Epstein sexually abused minors? 23 as Again, I repeat, I can only go on 24 what I know and what I know is a falsehood 25 based on what Virginia said. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page176 of 883 Page 178 1 G Maxwell - Confidential 2 What I'm asking you is whether you 3 believe Jeffrey Epstein abused minors? 4 MR. PAGLIUCA: I object to the form 5 and you made your record, she answered 6 the question. A fair reading of her 7 answer is she doesn't have a belief 8 because she doesn't have any personal 9 knowledge. 10 MS. McCAWLEY: Now you are 11 testifying for the witness. Let her 12 answer the question. 13 MR. PAGLIUCA: It's a fair answer 14 to the question. 15 Pus Again, I testified my only personal 16 knowledge concerns Virginia and everything 17 Virginia has said is an absolute lie, which 18 1s why we are here in this room. If you are 19 asking me to testify about things I have no 20 knowledge of other than the police report 21 that you showed me, I am not in a position to 22 make a statement based on that because you 23 are asking me to speculate and I cannot 24 speculate. 25 Q. I'm asking you about your belief. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page177 of 883 Page 179 1 G Maxwell - Confidential 2 I'm not asking you to speculate at all. I'm 3 asking what you believe. 4 Ais You are asking me to speculate and 5 I won't speculate. 6 Q. T'm not asking you to speculate. 7 I'm asking what you believe. 8 MR. PAGLIUCA: She answered the 9 question and we can move on. 10 MS. McCAWLEY: She hasn't answered 11 the question. 12 MR. PAGLIUCA: We are not going to 13 engage in this debate. She answered the 14 question. If you want to mark it and 15 move to compel an answer to the 16 question, have at it. Okay. 17 QO. Ms. Maxwell, is it your belief that 18 Jeffrey Epstein interacted sexually with 19 minors? 20 A. Again, you are asking me the same 21 type of question exactly but with different 22 language. Again, my only knowledge of 23 somebody who claims these things that I have 24 personal knowledge of is Virginia. Virginia 25 1s an absolute liar and everything she has MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page178 of 883 Page 180 1 G Maxwell - Confidential 2 Said is a lie. Therefore, based on those 3 lies I cannot speculate on what anybody else 4 did or didn't do because if Virginia is the 5 example of what that story is and everything 6 she said is false, so everything that leads 7 from that is false. 8 Q. So the 30 other minor children in 9 the police report are also telling lies about 10 being sexually abused during massages with 11 Mr. Epstein? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. Counsel, can you 14 show me in these police reports who the 15 30 minors are? 16 MS. McCAWLEY: I'm asking my 17 question. 18 MR. PAGLIUCA: You are making a 19 representation about numbers, you are 20 making a representation on the record 21 about what people said or didn't say. 22 We have no knowledge about that. These 23 are all redacted records so these are 24 bad questions. They don't lead to any 25 admissible evidence. It is only being MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page179 of 883 Page 214 1 G Maxwell - Confidential 2 Poe I'm carrying on. 3 Q. I'm sorry. I thought you were 4 done. 5 A. Please. Her statement also that 6 she was driven by her father to Palm Beach. 7 She was driven by her mother, as a matter of 8 fact. Her whole entire characterization of 9 the first meeting with Jeffrey, as I was 10 outside speaking to her mother. 11 QO. Let me stop you there, so we don't 12 get too far ahead. Let me make sure I 13 understand your testimony. 14 The first, in the first piece when 15 you were talking, I believe you said and 16 correct me if I'm wrong, that her 17 characterization of the first meeting at 18 Mar-a-Lago was an obvious lie. 19 What part of that meeting was an 20 obvious lie? 21 Aus By her own testimony, all her 22 various many different descriptions of what 23 she was or wasn't or where she was or wasn't, 24 they have all changed. She was either front 25 of house or bathroom attendant. I don't know MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page180 of 883 Page 215 1 G Maxwell - Confidential 2 what she was, so just by her own words, one 3 doesn't know what's true and what isn't true. 4 QO. Are you saying what position she 5 said she was working in, is that what you are 6 considering the obvious lie? 7 A. I said inconsistency within her own 8 statement from everything, so in the 9 beginning it starts off with different 10 statements. 11 QO. Then I believe you said the second 12 piece was that she was driven by her father? 13 A. I said she was driven by her 14 mother. 15 Q. That's the obvious lie? 16 A. It's an obvious lie to me. 17 Q. You said why don't you state it in 18 your own words but the characterization of 19 how she was with Jeffrey, what about that is 20 an obvious lie? 21 A. I was standing outside talking to 22 her mother so the entire story is a 23 fabrication. 24 QO. Did she not have sex with Jeffrey 25 Epstein during that first massage? MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page181 of 883 Page 220 1 G Maxwell - Confidential 2 up to the room and start a massage? 3 A. He would not. 4 QO. So the young girls in the police 5 report who say they came over and were led up 6 to the room on the first day, would they be 7 wrong about that? 8 MR. PAGLIUCA: Objection to form 9 and foundation. 10 A. I can't comment what happened when 11 I was not at the house. I can only comment 12 when I was at the house. 13 QO. Was there ever a time where a woman 14 came to the house for the first time to give 15 a massage and Jeffrey had the massage that 16 day? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. Can we talk about adult 20 professional masseuses, please? 21 Oz I'm asking, whether adult or 22 underage? 23 re I'm not interested in talking about 24 underage. I can only testify to what I know, Zo professional masseuses, adult, I cannot MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page182 of 883 Page 221 1 G Maxwell - Confidential 2 testify to anything else. 3 Q. Why can't you testify to an 4 underage girl that came over and was led up 5 to the room for a massage? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. The police records you are 9 referring to? 10 QO. You are saying that didn't happen. 11 You're saying I can only testify to adults 12 that came for an interview and were led up to 13 the room. Why can't you testify to whether 14 an underage girl was brought in for an 15 interview and led up -16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 Q. Go ahead. 19 A. Can you reask the question. 20 Q. Why can't you testify as to an 21 underage girl who came over for an interview 22 and then was then led up to the room for the 23 massage? 24 Fiz You've mangled your entire 25 question. Can you please reask that in a way MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page183 of 883 Page 225 1 G Maxwell - Confidential 2 present at the home when a girl under the age 3 of 18 came over for the purposes of giving a 4 massage? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 Q. You can answer. 8 Pes You can be a professional masseuse 9 at 17 in Florida, so as far as I am aware, a 10 professional masseuse showed up for a 11 massage. There is nothing inappropriate or 12 incorrect about that and your 13 mischaracterization of it, I think is 14 unfortunate. 15 Q. How many teenagers did he have that 16 were professional masseuses that worked in 17 his home? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 QO. How many? 21 A. First of all, I am not aware of 22 teenagers who worked in his home. 23 Q. You are aware of Virginia Roberts 24 and you've stated she was 17 and she worked 25 for him, correct? MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page184 of 883 Page 226 1 G Maxwell - Confidential 2 A. No. I did not state that at all, 3 you are mischaracterizing my words and what I 4 Said. 5 What I said was that we can all 6 agree and I think at this point there is not 7 one person in this room, however much you 8 would like her to be younger, to say she was 9 not 17 because that has been a very offensive 10 thing that you have all done. So she was 17. 11 At 17 you are allowed to be a professional 12 masseuse and as far as I'm concerned, she was 13 a professional masseuse. There is nothing 14 inappropriate or incorrect about her coming 15 at that time to give a massage. Her entire 16 characterization of her first time at the 17 house was to me an obvious lie, given it was 18 impossible for her entire story to take place 19 given I was speaking to her mother the entire 20 she was at the house. 21 Q. So it was impossible that day, that 22 first day she came and you were speaking to 23 the mother, for Virginia Roberts to have had 24 sex with Jeffrey Epstein during the time that 25 you were outside with her mother? MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page185 of 883 Page 228 1 G Maxwell - Confidential 2 absolutely 1000 percent that she did not have 3 any type of sexual relations as described by 4 you in your court papers that took place 5 because those allegedly according to her lies 6 involved some aspect of me. 7 As I was standing outside with her 8 mother the entire time, her entire story is a 9 lie. Therefore, to ask me what she did or 10 didn't do during that time, I can only 11 testify to what she said about me, which was 12 1000 percent false. 13 QO. So let's not take the first time, 14 let's take the next time she comes. 15 A. No no, how can do you that, when 16 the basis of this entire horrible story that 17 you have put out is based on this first 18 appalling story that was written, repeated, 19 multiply by the press that lied about her 20 age, lied about the first time she came, lied 21 about and characterized the entire first 22 time. I have been so absolutely appalled by 23 her story and appalled by the entire 24 characterization of it and I apologize 25 Sincerely for my banging at the table MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page186 of 883 Page 229 1 G Maxwell - Confidential 2 earlier, I hope you accept my apology. It's 3 borne out of years of feeling the pressure of 4 this entire lie that she has perpetrated from 5 our first time and whilst I recognize that 6 was -- I hope you forgive me sincerely 7 because it was just the length of time that 8 that terrible story has been told and retold 9 and rehashed when I know it to be 100 percent 10 false. 11 QO. So not the first time she came, but 12 the second time she came or the third time or 13 any time she came, did you ever participate 14 in a massage with her in Jeffrey Epstein's 15 room? 16 A. IT have never participated at any 17 time with Virginia in a massage with Jeffrey. 18 Q. Have you ever participated at any 19 time with Virginia in any kind of sexual 20 contact or sexual touching with Jeffrey and 21 Virginia? 22 Bis I have not. 23 QO. So we were going through the list 24 of obvious lies and you were talking about 25 the first time which I believe we have MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page187 of 883 Page 248 1 G Maxwell - Confidential 2 of 18? 3 Ps I think we can establish what adult 4 would be. 5 Q. You never interviewed or I know you 6 don't want to use the word hired, whatever 7 your role was, you brought in an exercise 8 instructor that was under the age of 18 to 9 work at the house? 10 MR. PAGLIUCA: Object to the form 11 and foundation. 12 A. IT have already testified that what 13 I was responsible for was to find people who 14 had competencies in whatever area I was 15 looking for. The competencies I was looking 16 for were professional and adult. 17 Q. So there was no exercise instructor 18 that worked at the Palm Beach house or the 19 New York house or the New Mexico house or the 20 USVI under the age of 18? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 re I can only testify to when I was at 24 the house. 25 QO. Yes. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page188 of 883 Page 310 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 Ax That's not how I would characterize 5 that. 6 QO. How would you characterize it? 7 A. I have testified that I'm 8 responsible for finding professional people 9 to work in the homes, age appropriate adult 10 people, so from pool attendants, to 11 gardeners, to chefs, to housekeepers, to 12 butlers, to chauffeurs and one of the 13 functions was to be able to answer the 14 telephones and in the context of finding i someone to answer the telephones, I did look 16 to try to find appropriate people to answer 17 the phones. 18 Q. So did you find Johanna for 19 purposes of that role? 20 ae So in the course of looking for 21 somebody to answer phones at the house, 22 Johanna was one of the people who said that 23 she was willing to answer phones. 24 QO. Did you approach her at her school 25 campus? MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page189 of 883 Page 383 1 G Maxwell - Confidential 2 Q. List all of the girls you met and 3 brought to Jeffrey Epstein's home for the 4 purposes of employment that were under the 5 age of 18? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I've already characterized my job 9 was to find people, adults, professional 10 people to do the jobs I listed before; pool 11 person, secretary, house person, chef, pilot, 12 architect. 13 Q. I'm asking about individuals under 14 the age of 18, not adult persons, people 15 under the age of 18. 16 A. I looked for people or tried to 17 find people to fill professional jobs in 18 professional situations. 19 Q. So Virginia Roberts was under the 20 age of 18, correct? 21 Ds I think we've established that 22 Virginia was 17. 23 Q. Is she the -- sorry, go ahead. 24 Is she the only individual that you 25 met for purposes of hiring someone for MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page190 of 883 Page 390 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 Bis If you want to ask Jeffrey 5 questions about me, you would have to ask 6 him. 7 Q. Have you ever been involved in any 8 illegal activity in your lifetime? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 Bis IT can't think of anything I have 12 done that is illegal. 13 Q. Have you ever been arrested? 14 Bis IT have a DUI in the U.K. a long 15 time ago. 16 Q. Is that the only arrest you have on 17 your record? 18 A. Yes. 19 QO. I will mark as Maxwell 22 this 20 email? 21 (Maxwell Exhibit 22, email, marked 22 for identification. ) 23 Q. This is dated January 21, 2015. 24 It's from Jeffrey Epstein to you, forwarding 25 the Guardian and I would like you to look at MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page191 of 883 Page 416 1 2 CERTIFICATE 3 4 5 I HEREBY CERTIFY that the witness, 6 GHISLAINE MAXWELL, was duly sworn by me and 7 that the deposition is a true record of the 8 testimony given by the witness. 9 10 11 fesit ragif, Registered Professional Reporter AZ Dated: April 22, 2016 13 14 i (The foregoing certification of 16 this transcript does not apply to any 1] reproduction of the same by any means, unless 18 under the direct control and/or supervision 19 of the certifying reporter.) 20 21 72 23 24 25 MAGNA®©

Case 18-2868, Document 283, 08/09/2019, 2628241, Page192 of 883 Confidential Page l UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK mmm mm mmm me eE*EK VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. mmm mmm mmm me =*EXK **CONFIDENTIAL** Continued Videotaped Deposition of GHISLAINE MAXWELL, the Defendant herein, taken pursuant to subpoena, was held at the law offices of Boies, Schiller & Flexner, LLP, 575 Lexington Avenue, New York, New York, commencing July 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page193 of 883 Confidential Page 44 1 G. Maxwell - Confidential 2 thought. I really don't recall her, so it's 3 hard for me to testify what I thought about 4 her age at the time. 5 Q. Was Virginia, in the period of 6 around 2000, the youngest person that, as you ~] understood it, was giving Mr. Epstein 8 massages? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 Bis Again, I can't testify to her age, 12 but everybody else that I can recall seemed 13 to be again, like I would say, adults. 14 QO. You didn't think Virginia was an 15 adult, did you? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. Like I said, I don't recall her. I 19 don't recall thinking about -- my memory is 20 of adults giving Jeffrey massages, and as I 21 don't really remember Virginia around that 22 time, I don't know what I think. 23 QO. You do remember Virginia, about 24 that time back in the 2000S, giving 25 Mr. Epstein massages? MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page194 of 883 Confidential Page 45 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 As I barely remember her at all. 5 Q. Whether you barely remember her or 6 not, you do remember that back in the period ~] around 2000, Virginia was giving Mr. Epstein 8 massages, right? 9 MR. PAGLIUCA: Objection to form 10 and foundation. 11 Ais Only in the most general terms. It 12 would be somebody who would give him a 13 massage, and that's it. 14 QO. During the period of time back in 15 the period around 2000, when you knew that 16 Virginia was somebody who would give 17 Mr. Epstein a massage, was she somebody who 18 you considered an adult? 19 MR. PAGLIUCA: Objection to form 20 and foundation. 21 A. I didn't consider her at all 22 because she is not somebody that I really 23 interacted with. 24 Q. It iS your testimony that Virginia 25 was not somebody that you interacted with, is MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page195 of 883 Confidential Page 55 G. Maxwell - Confidential Epstein's home in Palm Beach? MR. PAGLIUCA: Objection to form and foundation. BEER f—: BRR RRR RRR Eee 3 Bee ew ee Til MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page196 of 883 Confidential Page 56 1 G. Maxwell - Confidential - ?: i i a: i ee 5 i C—O 7 ACI i eee ——— a z= 11 i Ce a CC = C—O eee 16 C—O a eee eee a eee eee C—O oe Cee Fe see a: MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page197 of 883 Confidential Page 57 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 A. a i ee — eee eee 8 MR. PAGLIUCA: Objection to form 9 and foundation. 10 ee Eee eee se 14 i see Cee eee a ll a C—O C—O 27212 CC a EE a a a ee MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page198 of 883 Confidential Page 58 1 Za nm #HeMeiteHi i -— -_— 20 21 Maxwell - Confidential Q MR. PAGLIUCA: Objection to form and foundation. MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page199 of 883 Confidential Page 86 1 G. Maxwell - Confidential 2 and foundation. 3 Pia No. 4 0 ee ee a 8 MR. PAGLIUCA: Objection to form 9 and foundation. 10 Bz I don't know. 11 C—O a = a C—O ee ee C—O 17 MR. PAGLIUCA: Objection to form 18 and foundation. Asked and answered. 19 Aw No. 20 QO. Were they ever in the Virgin 21 Islands? 22 MR. PAGLIUCA: Objection to form 23 and foundation. 24 A. No. 25 Oe MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page200 of 883 Confidential Page 8/7 1 ee ee errr ee i C—O i 0 —O ee Daa eee i C—O a 0 —O eee ee a EOE a ee = C—O a C—O — Oe ae a _ a C—O aaa aa Bee 24 MR. PAGLIUCA: Objection to form 25 and foundation. MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page201 of 883 Confidential Page 91 1 G. Maxwell - Confidential 2 it to something in the case. 3 MR. BOIES: I think it's tied, but 4 if you instruct her not to answer, it 5 goes into the -6 MR. PAGLIUCA: Meat grinder. 7 BY MR. BOIES: a ee eee C—O Ce a Oe 14 A. Can you repeat the question? 15 a ee ee ee EC 20 MR. PAGLIUCA: Same objection. 21 A. No. 22 O. a 24 MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page202 of 883 Confidential Page 19/7 1 Fs CERTIFICATE a 4 5 IT HEREBY CERTIFY that GHISLAINE 6 MAXWELL, was duly sworn by me and that the 7 deposition is a true record of the testimony 8 given by the witness. 9 10 oo Lbahe ” 11 ee ae Fal’ in, Registered Professional Reporter 12 Dated: July 22, 2016 13 14 1 Bs (The foregoing certification of 16 this transcript does not apply to any 17 reproduction of the same by any means, unless 18 under the direct control and/or supervision 19 of the certifying reporter.) 20 21 22 ao 24 25 MAGNA®S

EXHIBIT 12 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page204 of 883 GIUFFRE VS. MAXWELL Deposition LYNN TRUDE MILLER 05/24/2016 Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017

Case 18-2868, Document 283, 08/09/2019, 2628241, Page205 of 883 Agren Blando Court Reporting & Video, Inc. IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS CONFIDENTIAL VIDEOTAPED DEPOSITION OF LYNN TRUDE MILLER May 24, 2016 VIRGINIA L. GIUFFRE, Plasnecice., Vv. GHISLAINE MAXWELL, Defendant. APPEARANCES: S.J. QUINNEY COLLEGE OF LAW, UNIVERSITY OF UTAH By Paul G. Cassell, Esq. 383 S. University Street Salt Lake City, UT 84112 Phone: 6012.5385.5202 Cassellp@law.utah.edu Appearing on behalf of the Plaintiff HUTCHINSON BLACK AND COOK, LLC By John Clune, Esq. 921 Walnut Street Suite 200 Boulder, CO 80302 Phone: 303.442.6514 clune@hbcboulder.com Appearing on behalf of the Deponent LYNN TRUDE MTI IER 5/24/7016

Case 18-2868, Document 283, 08/09/2019, 2628241, Page206 of 883 Agren Blando Court Reporting & Video, Inc. APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, Esq. 10 ia LZ 13 14 a 16 dy 18 ig ZU 21 22 Zo 24 25 Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jJpagliuca@hmflaw.com Appearing on behalf of the Defendant Also Present: Maryvonne Tompkins, Videographer LYNN TRUDE MTI IER 5/24/7016

10 ia LZ 13 14 a 16 3, 18 i 20 Zi. 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page207 of 883 Agren Blando Court Reporting & Video, Inc. A Because I wasn't told any different. Q Do you know where any -- any source of that information came from? Was it Sky? A It came from Sky. Q Okay. And what do you recall him telling you about when Virginia stopped working at Mar-a-Lago? A She was in a discussion with Mrs. Maxwell to educate her and take her under her wing and be her new momma. That's what I heard. Q Okay. And who told you that? A Sky. Q Okay. And do you remember when Sky told you that? A I don't remember. Q Okay. Did you learn anything else about that, other than what you just said? A ING < Q Okay. Do you know where she went to work after Mar-a-Lago? A I think she went with Mrs. Maxwell. Q But do you know where, physically? A Physically, Sky and I dropped her off one day at Mrs. Maxwell's. I did not speak with Mrs. Maxwell. I didn't have anything to say to her. LYNN TRUDE MTI IER 5/24/7016 1715

10 Tel 12 Ls 14 ale: 16 3, 18 i 20 Zi 22 25 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page208 of 883 Agren Blando Court Reporting & Video, Inc. STATE OF COLORADO) ) ss. REPORTER'S CERTIFICATE COUNTY OF DENVER ) I, Kelly A. Mackereth, do hereby certify that I am a Registered Professional Reporter and Notary Public within the State of Colorado; that previous to the commencement of the examination, the deponent was duly sworn to testify to the truth. I further certify that this deposition was taken in shorthand by me at the time and place herein set forth, that it was thereafter reduced to typewritten form, and that the foregoing constitutes a true and correct transcript. I further certify that I am not related to, employed by, nor of counsel for any of the parties or attorneys herein, nor otherwise interested in the result of the within action. In witness whereof, I have affixed my Signature this 31st day of May, 2016. My commission expires April 21, 2019. Kelly A. Mackereth, CRR, RPR, CSR 216 - 16th Street, Suite 600 Denver, Colorado 80202 LYNN TRUDE MTI IER 5/24/7016 176

EXHIBIT 13 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page210 of 883 Page l UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS aces en mem? is ie) ml + noi Gm) ms iG SG X VIRGINIA L. GIUFFRE, Plaintiff, Ve GHISLAINE MAXWELL, Defendant. ceed GS Z| dS SG Sd xX June 21, 2016 9:17 a.m. CONFIODENTI.IAL Deposition of JOSEPH RECAREY, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page211 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 25 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: QO. All right. Was SG a licensed massage therapist? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: No. BY MR. EDWARDS: Q. And at 14 years old, are you permitted to be a licensed massage therapist? Bo Not to my knowledge. Q. After speaking with SG and understanding her account of what took place at Jeffrey Epstein's home, what -- what happened next in the investigation? A. At some point the investigation was turned over to me for follow-up. I know there was trash pulled that was done prior to -- and surveillance that was done prior to the case being turned over to me; and trash pulls being an investigative technique to acquire intelligence, information and evidence. Q. Okay. If we go to page 17, at the top, and, first of all, I will ask you from memory, do you remember if I identified Jeffrey Epstein in a photo lineup? VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page212 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 27 JOSEPH RECAREY -—- CONFIDENTIAL "a cross-reference"? Pe Uh-huh. Q. How iS a cross-reference performed? What does that mean? A. When -- when something is cross-referenced, they -- they jot down license plate numbers. They conduct their background into the individuals; photographs, computer research. Q. A cross-reference of Jeffrey Epstein's residence revealed which affiliated names? A. It revealed Nadia Marcinkova, Ghislane Maxwell, Mark Epstein. Also, the cross-reference, any previous reports from the residence as well. Q. During your investigation, did you learn of any involvement that Nadia Marcinkova had with any of the activities you were investigating? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Yes. BY MR. EDWARDS: Q. And what involvement did you learn of Nadia Marcinkova? MR. PAGLIUCA: Object to form and foundation. VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page213 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 28 JOSEPH RECAREY - CONFIDENTIAL THE WITNESS: Nadia was involved sexually with one of the victims at Epstein's request. BY MR. EDWARDS: Q. Okay. Do you remember which victim you're remembering right now? A. AH. Q. Okay. If it indicates in the report that she was also sexually involved with other victims, is that possible as well? Bos Yes. MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. Okay. The one that you remember in your mind is AH? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Correct. BY MR. EDWARDS: Q. The other name that is on here as a cross-reference is Ghislane Maxwell. Did you speak with Ghislane Maxwell? A. I did not. Q. Did you ever attempt to speak with VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page214 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 29 JOSEPH RECAREY -—- CONFIDENTIAL Ghislane Maxwell? Piz I wanted to speak with everyone related to this home, including Ms. Maxwell. My contact was through Gus, Attorney Gus Fronstin, at the time, who initially had told me that he would make everyone available for an interview. And subsequent conversations later, no one was available for interview and everybody had an attorney, and I was not going to be able to speak with them. Q. Okay. During your investigation, what did you learn in terms of Ghislane Maxwell's involvement, if any? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Ms. Maxwell, during her research, was found to be Epstein's long-time friend. During the interviews, Ms. Maxwell was involved in seeking girls to perform massages and work at Epstein's home. MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. Did you interview -- how many girls did you interview that were sought to give or that VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page215 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 30 JOSEPH RECAREY - CONFIDENTIAL actually gave massages at Epstein's home? MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. Approximately. MR. PAGLIUCA: Same objection. THE WITNESS: I would say approximately 30; 30, 33. BY MR. EDWARDS: Q. And of the 30, 33 or so girls, how many had massage experience? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: I believe two of them may have been -- two of them. BY MR. EDWARDS: Q. Okay. And as we go through this report, you may remember the names? A. Correct. Let me correct myself. I believe only one had. Q. And was that -- was that one of similar age to the other girls? MR. PAGLIUCA: Object to form and foundation. VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page216 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 40 JOSEPH RECAREY - CONFIDENTIAL foundation. THE WITNESS: Yes, I did. BY MR. EDWARDS: Q. And were trash pulls done at the property of Jeffrey Epstein? De. Yes. Q. What is the purpose of a trash pull, and what is a trash pull? A. A trash pull is when property is discarded, such as trash, we coordinate with the Sanitation department to collect the trash, once it leaves the property, and it's put into an empty well of the trash truck. We acquire the bags, and we sift through the contents of the trash. Q. Did you or another detective from the unit observe each step of the trash pull to make sure that you had a good chain of custody of the evidence? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Yes. The members of the OCTAN unit at that time did. BY MR. EDWARDS: Q. Okay. And what is that process? VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page217 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 41 JOSEPH RECAREY -—- CONFIDENTIAL As The process -MR. PAGLIUCA: Object to form and foundation. THE WITNESS: The process is when the -once you coordinate a trash pull with the Sanitation supervisor, you meet with the Sanitation worker and ensure that either the can that he's going to place in the well is completely empty and you physically observe him collect the trash and place it into the empty container. And then you follow him to a disclosed area, and we retrieve the bags and you sift through the trash. BY MR. EDWARDS: Q. Okay. What were you looking for in terms of evidentiary value from these trash pulls? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: We were looking for any -any form of identification. You were looking for -- to gather any kind of intelligence and/or evidence. BY MR. EDWARDS: Q. Okay. If we go to page 20 of the report, VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page218 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 42 JOSEPH RECAREY -—- CONFIDENTIAL I guess I'll start with where it says on 4/4/2005, I just want to ask you, was a voice mail message taken into evidence from HR to SG? A. Yes. Q. Okay. And the purpose of that evidence is to corroborate what? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: It was actually a phone call from HR to SG confirming an appointment to go work at Epstein's residence. BY MR. EDWARDS: Q. The next line down is what I wanted to focus on, April 5th, 2005. This trash pull, what evidence is yielded from this particular trash pull? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: The trash pull indicated that there were several messages with written items on it. There was a message from HR indicating that there would be an 11:00 appointment. There were other individuals that had called during that day. VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page219 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 43 JOSEPH RECAREY - CONFIDENTIAL BY MR. EDWARDS: Q. And when you would -- when you would see females' names and telephone numbers, would you take those telephone numbers and match it to -- toa person? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: We would do our best to identify who that person was. BY MR. EDWARDS: QO. And is that one way in which you discovered the identities of some of the other what soon came to be known as victims? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Correct. BY MR. EDWARDS: Q. Okay. There's the second paragraph from the bottom, it starts, "Detective Leigh provided trash from 4/06, 4/07/2005." Do you see that? A. Yes. Q. And what is the purpose of the indication that "the following information was retrieved: Jet VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page220 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 45 JOSEPH RECAREY -—- CONFIDENTIAL BY MR. EDWARDS: Q. And then some of the remaining messages, "Johanna, work Sunday at 4 p.m.; A, Monday after school; left message for Courtney W and NT," are these individuals that you later learned were underaged girls that had been to Jeffrey Epstein's home? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: That's correct. BY MR. EDWARDS: Q. What types of documents do you remember retrieving from the trash pulls from Jeffrey Epstein's home? Aw There waS numerous items. It was a lot of handwritten notes on different -- different pads of paper. Some of the pads had names on it, whether it was Epstein, whether it was Ghislane Maxwell, whether it was -- there were phone messages. When I say "phone messages," I mean, you know, the kind that come in a book. They are carbon copied, so the yellow copy always stays with the book, but the white copy is torn off. So there was always a carbon copy of the actual phone message. VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page221 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 72 JOSEPH RECAREY -—- CONFIDENTIAL THE WITNESS: Correct. BY MR. EDWARDS: Q. And let me go back to the beginning six pages of that exhibit, No. 4. MR. PAGLIUCA: Why don't we just make a copy of it now if we're going to ask guestions about it? I'm not trying to -MR. EDWARDS: Yes, I know. It's just the first six pages. (A discussion was held off the record, after which the following proceedings were held: ) THE VIDEOGRAPHER: On the record at 10:32. BY MR. EDWARDS: Q. And what were some of the items that were found in -- well, are the documents that you're holding, 1 through 6, an accurate reflection of the items that were found in Jeffrey Epstein's home during the search warrant execution? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Yes. BY MR. EDWARDS: QO. And I believe that you described that some VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page222 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 73 JOSEPH RECAREY -—- CONFIDENTIAL of the -- that the house appeared to be -- I don't remember the word you used -- sanitized, for lack of a better word? MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: QO. How did you know that? A. The computers had been removed from the home. Q. How did you know the computers were removed? As Based on -- based on the dangling wires left behind, the monitors left, but the actual CPU of it wasS missing. When you went into the bedroom of Jeffrey Epstein, everything was removed from the -- the shelves, from the armoire. Q. Did you find nude photographs of girls? A. Yes. Q. All right. And what did you do with that evidence? A. That was collected and placed into our crime scene unit. QO. And where is that evidence today? VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page223 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 74 JOSEPH RECAREY -—- CONFIDENTIAL As Any evidence that was not returned to its rightful owner was turned over to the FBI. Q. And evidence which would be nude photographs of girls would be evidence not turned back over to Epstein? A. Correct. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Some of the items that were collected were later found to be personal items of the houseman, Janush. I recall reviewing his personal photographs on -- on a micro SD card for, like, photos of him and his wife or girlfriend at the time. BY MR. EDWARDS: Q. And the underaged girls that you had spoken with during your investigation, had they described seeing photographs of naked girls in the house? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Yes, they did. BY MR. EDWARDS: QO. That's something that ran consistent with VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page224 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 78 JOSEPH RECAREY -—- CONFIDENTIAL BY MR. EDWARDS: Q. Okay. Also reflected are the property receipts? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Correct. BY MR. EDWARDS: QO. All right. And where were those taken from, in terms of whose property is that? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: This would have been taken from the home of Jeffrey Epstein. BY MR. EDWARDS: QO. And in reviewing that evidence, were you able to substantiate or corroborate certain victims' accounts of their allegations of having been at the house? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Correct. BY MR. EDWARDS: Q. Did you find names of other witnesses and VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page225 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 79 JOSEPH RECAREY - CONFIDENTIAL people that you knew to have been associated with the house in those message pads? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Yes. BY MR. EDWARDS: Q. And so what was the evidentiary value to you of the message pads collected from Jeffrey Epstein's home in the search warrant? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: It was very important to corroborate what the victims had already told me as to calling in and for work. BY MR. EDWARDS: Q. Okay. And did you learn the identities of some of the other individuals associated with Jeffrey Epstein through the review of that particular evidence? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Correct. BY MR. EDWARDS: Q. Okay. And what did you do with that VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page226 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 83 JOSEPH RECAREY -—- CONFIDENTIAL BY MR. EDWARDS: Q. In these messages, did you see messages that were taken by Ghislane Maxwell or left for Ghislane Maxwell? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: I do recall seeing messages utilizing her pad, her stationery. BY MR. EDWARDS: Q. Okay. Do you remember messages specifically that Ms. Maxwell, she is home, or calls for Ms. Maxwell, or indicating that the person taking the message iS GM? Do you remember those? As Yes. MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: O. And did that give you further reason to want to speak to Ghislane Maxwell? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Correct. I wanted to speak with everyone in the home and everyone associated with Jeffrey Epstein. VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page227 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 97 JOSEPH RECAREY - CONFIDENTIAL anything that's found that has any kind of identifiers, any kind of names, phone numbers, anything that could be used to identify further victims and/or to corroborate what the information we already obtained, that information would be kept. Q. Okay. As Be followed up on. Q. You testified earlier about certain pieces of paper that had Ghislane Maxwell's name on it that were obtained. Are the documents that are listed, the first one, two, three, four pages of Exhibit 8, some of the documents that you're referring to? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: That is correct. BY MR. EDWARDS: Q. And if we go through this stack of documents, if you could just review them and tell me if these are some of the items obtained through the trash pulls at Jeffrey Epstein's home? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: That is correct. This is -VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page228 of 883 ‘io CO N HW Oo FSF WW NO FF NM NON NO NO NO NYO HB BP BP BP BP BP BP BP Be Om £ Ww NH FE CO OO DO IN WD UO BF W NY fF OO Page 98 JOSEPH RECAREY - CONFIDENTIAL these items were collected in the trash pull. BY MR. EDWARDS: Q. Okay. And these are items that you felt had some evidentiary value? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Yes. BY MR. EDWARDS: Q. Were there other items within the trash that were discarded as not having any apparent evidentiary value? Bos Correct. There was stuff like food trash we're not going to keep. You know, an apple core. None of that's going to be kept. Q. Okay. And when you took this stuff into evidence, how was it maintained? A. It was placed in a-- ina sealed container, a sealed Ziploc, and placed into evidence. Q. And then was that file later transferred to the State Attorney's Office or the FBI? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: It was collected by the FBI. VMAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page229 of 883 ‘io CO N NW OU 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 366 CERTIFICATE STATE OF FLORIDA ) Ss COUNTY OF MIAMI-DADE ) I, KELLI ANN WILLIS, a Registered Professional, Certified Realtime Reporter and Notary Public within and for The State of Florida, do hereby certify: That JOSEPH RECAREY, the witness whose deposition is hereinbefore set forth was duly sworn by me and that such Deposition is a true record of the testimony given by the witness. I further certify that I am not related to any of the parties to this action by blood Or marriage, and that I am in no way interested in the outcome of this matter. IN WITNESS WHEREOF, I have hereunto set my hand this 24th day of June, 2016. KELLI ANN WILLIS, RPR, CRR VMAGNA®S

EXHIBIT 14 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page231 of 883 Page l UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Se | VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. **CONFIDENTIAL** Videotaped deposition of RINALDO RIZZO, taken pursuant to subpoena, was held at the law offices of Boies Schiller & Flexner, 333 Main Street, Armonk, New York, commencing June 10, 2016, 10:06 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page232 of 883 Page 25 1 R. Rizzo - Confidential 2 even Nadia. And what I found very repulsive, 3 out of the ordinary, was Nadia was wearing a 4 Swimsuit that was very revealing and 5 basically, her bottom basically went up her 6 butt, revealing all of her buttocks. So 7 again, in the context not very appropriate 8 for the situation. 9 Q. Could you tell the relationship of 10 age between the three girls that you have 11 described and Nadia, for instance? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 A. Nadia seemed to be a bit older, I 15 would say. 16 oF How does this end, or is there, 17 what do you do next? How does this meeting 18 that you've just described break up? 19 As I asked to excuse myself and asked 20 where the bathroom was, so I'm pointed inside 21 the house, to go inside the house to the 22 bathroom. 23 I walk in there, and I walk, as I'm 24 walking to the bathroom, what caught my eye, Zo and I had to take a double lock, there were MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page233 of 883 Page 26 1 R. Rizzo - Confidential 2 pictures of naked women, half-dressed girls. 3 So I went to the bathroom, again, from 4 someone, myself working in private service, I 5 always know in houses there are cameras, so 6 again, I was very reluctant to stare, because 7 you never know when you are on camera. 8 So I used the bathroom, and I came 9 out, and you know, curiosity got the best of 10 me, and I leaned over and started looking at 11 these pictures for a brief minute, and it was 12 just so coincidental that as I did that, Ms. 13 Maxwell enters, and she immediately says to 14 me that Jeffrey would like for me to rejoin 15 the party immediately. 16 oF How many pictures of nude females 17 did you see in Jeffrey Epstein's home? 18 MR. PAGLIUCA: Object to the form 19 and foundation. 20 A. I can't recall the exact number. 21 QO. Can you describe the pictures that 22 you saw in terms of what the people, what the 23 people or person within the picture was 24 wearing, what the age range would be of the 25 person that's in the photograph, any poses, MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page234 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 52 R. Rizzo - Confidential Q. Did you learn whether your perception was correct? MR. PAGLIUCA: Same objection. Ax It was younger. Yes, I did. QO. How Old was this girl? is 15 years old. Q. What happens next when Ghislaine Maxwell and Jeffrey Epstein and a 15-year-old girl walk into Eva Anderson's home? MR. PAGLIUCA: Object to the form. Foundation. A. They proceed into the dining room area, which is across from the living room area. I go into the kitchen and I hear a conversation start. Very muffled, I could not hear any particulars about the conversation whatsoever. My wife and I are in the kitchen preparing the evening meal. Eva brings the young girl into the kitchen. In the kitchen, there is an island with three barstools. Eva instructs the young girl to sit to the furthest barstool on the right. Os Describe for me what the girl MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page235 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 53 R. Rizzo - Confidential looked like, including her demeanor and anything else you remember about her when she walks into the kitchen. Ax Very attractive, beautiful young girl. Makeup, very put together, casual dress. But she seemed to be upset, maybe distraught, and she was shaking, and as she Sat down, she sat down and sat in the stool exactly the way the girls that I mentioned to you sat at Jeffrey's house, with no expression and with their head down. But we could tell that she was very nervous. QO. What do you mean by distraught and Shaking, what do you mean by that? As Shaking, I mean literally quivering. Q. What happens next? A. We were, again, the absurdity, never introduced. Like you would walk into a room and say this is -- so my wife and I are in the kitchen and this young girl is sitting there. It was a very uncomfortable moment. IT look at my wife. And so I want to ease the moment, and so I introduced myself and I MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page236 of 883 Page 54 1 R. Rizzo - Confidential 2 introduced my wife, and she doesn't really 3 respond. 4 And I asked her, are you okay? And 5 she doesn't really respond. Nothing verbal, 6 no cues, her head is still down. I ask her 7 if she would like some water, tissue, 8 anything, and she basically doesn't respond. 9 Q. You ask her for a tissue? 10 A. If she would like a tissue or some 11 water at the time. 12 QO. Was she crying at the time? 13 Ps My perception, she was on the verge 14 of crying. And I'm trying to loosen the 15 Situation every way I know how, so the only 16 way I knew how, and I thought maybe this will 17 comfort her, I said oh, by the way, do you 18 work for Jeffrey. 19 And she says that, I guess kind of 20 made her feel comfortable, because maybe it 21 was that comment or my persistence, and she 22 Said yes. So I said, what do you do? And 23 she says I'm Jeffrey's executive assistant, 24 personal assistant. Which, from looking at 25 her, just didn't seem to suit. MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page237 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 55 R. Rizzo - Confidential And I blurted out: You're his executive personal assistant? What do you do? And she says I was hired as his executive personal assistant. I schedule his appointments. And I'm shocked, and I blurt out: You seem quite young, how did you get a job? How old are you? And she says to me, point blank: I'm 15 years old. And I said to her: You're 15 years Old and you have a position like that? At that point she just breaks down hysterically, so I feel like I just said something wrong, and she will not stop crying. My wife and I were at a loss for words, and I keep on trying to console her, and nothing I was Saying, are you all right, do you need a tissue, do you need water, consoles her. And then ina state of shock, she just lets it rip, and what she told me was Just unbelievable. QO. What did she say? MR. PAGLIUCA: Object to the form and foundation. MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page238 of 883 Page 56 1 R. Rizzo - Confidential 2 Pix She proceeds to tell my wife and I 3 that, and this is not -- this is blurting 4 out, not a conversation like I'm having a 5 casual conversation. That guickly, I was on 6 an island, I was on the island and there was 7 Ghislaine, there was Sarah, she said they 8 asked me for sex, I Said no. 9 And she is just rambling, and I'm 10 like what, and she said -- I asked her, I 11 Said what? And she says yes, I was on the 12 island, I don't know how I got from the 13 island to here. Last afternoon or in the 14 afternoon I was on the island and now I'm 15 here. And I said do you have a -- this is 16 not making any sense to me, and I said this 17 is nuts, do you have a passport, do you have 18 a phone? 19 And she says no, and she says 20 Ghislaine took my passport. And I said what, 21 and she says Sarah took her passport and her 22 phone and gave it to Ghislaine Maxwell, and 23 at that point she said that she was 24 threatened. And I said threatened, she says 25 yes, I was threatened by Ghislaine not to MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page239 of 883 Page 5/7 1 R. Rizzo - Confidential 2 discuss this. 3 And I'm just shocked. So the 4 conversation, and she is just rambling on and 5 on, again, like I said, how she got here, she 6 doesn't know how she got here. Again, I 7 asked her, did you contact your parents and 8 she says no. 9 At that point, she says I'm not 10 Supposed to talk about this. I said, but I 11 Said: How did you get here. I don't 12 understand. We were totally lost for words. 13 And she said that before she got 14 there, she was threatened again by Jeffrey 15 and Ghislaine not to talk about what I had 16 mentioned earlier, about -- again, the word 17 she used was sex. 18 Q. And during this time that you're 19 Saying she is rambling, is her demeanor 20 continues to be what you described it? 21 A. Yes. 22 Oils Was she in fear? 23 Poe Yes. 24 MR. PAGLIUCA: Object to the form 25 and foundation. MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page240 of 883 Page 58 1 R. Rizzo - Confidential 2 Q. You could tell? 3 Pig Yes. 4 MR. PAGLIUCA: Same objection. 5 Piz She was shaking uncontrollably. 6 Q. What happens with this 15-year-old 7 girl next? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 As As she is trying to explain, and 11 I'm asking questions because I'm as feared as 12 she is at this point. We hear people 13 approach and she just shuts up. 14 QO. What happens next? 15 As Eva comes in and tells her that she 16 will be working for Eva in the city. 17 Q. As what? 18 A. As a nanny. 19 QO. Did you see this girl again? 20 Poe Yes. 21 Q. And when? 22 As On a flight maybe a month or so to 23 Sweden. 24 QO. What was the purpose of the flight? 25 Po We were going to Sweden for the MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page241 of 883 Page 59 1 R. Rizzo - Confidential 2 Summer. 3 Q. Who was on the flight? 4 A The Dubin family. 5 Q. As well as this girl? 6 A. Yes. 7 Q. What happens? 8 As One thing that I forgot to mention 9 is during our initial conversation, I asked 10 her what her name was a she said her name —s 12 Q. What happened with yy? 13 Rs We flew to Sweden, we stopped at an 14 airport that we didn't usually stop at and 15 she got off the plane. 16 Q. Just so that I make sure I 17 understand, who it was that she says asked 18 her for sex on the island, who was that? 19 MR. PAGLIUCA: Object to the form. 20 Foundation. 21 a She didn't specify who asked for 22 sex. She said that they asked for sex. 23 Immediately after that she put Ghislaine and 24 Sarah into the conversation. 25 Q. Taking her passport? MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page242 of 883 Page 60 1 R. Rizzo - Confidential 2 Psi yes. 3 Q. From -- are there any other 4 incidents or occurrences that you observed 5 personally with Jeffrey Epstein and Ghislaine 6 Maxwell? 7 MR. PAGLIUCA: Object to the form 8 and foundation. 9 A. Not that I can recall. 10 QO. This last event that you described, 11 what's the timeframe when that occurred? 12 A. Late 2004, 2005. 13 Q. When did you resign your employment 14 from the Dubin family? 15 As I think roughly October. 16 oF Of what year? 17 Pi 2005. 18 Q. Why? 19 Ris My wife and I had discussed these 20 incidents, and this last one was just, we 21 couldn't deal with it. 22 QO. When you left your employment with 23 the Dubin family, did you have a job? 24 Pixs When we finally left, I stayed on 25 three months after my resignation, I had a MAGNA®S

Case 18-2868, Document 283, 08/09/2019, 2628241, Page243 of 883 Page 141 1 2 CERTIFICATE 3 4 5 I HEREBY CERTIFY that RINALDO 6 RIZZO, was duly sworn by me and that the 7 deposition is a true record of the testimony 8 given by the witness. 9 10 11 : Registered Professional Reporter 12 Dated: June 10, 2016 13 14 15 (The foregoing certification of 16 this transcript does not apply to any 17 reproduction of the same by any means, unless 18 under the direct control and/or supervision 19 of the certifying reporter.) 20 21 22 23 24 25 MAGNA®S

EXHIBIT 15 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page245 of 883 Confidential Page l UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ‘aces cam am <em> = Cm“ COS. ZG <= }°. G C,<s V' C)S- CR "S C Re. UG eeme G- Cem femeS )) me em > imeem * Ge: Se X VIRGINIA L. GIUFFRE, Plaintiff, Ve GHISLAINE MAXWELL, Defendant. ai) coc? cs: can): c/s cnn? cn a ca? one? ac) can Cc? occ; ca: [a sac Go“ car cic; Gum /amas/;CGmes:. (ume) ‘Guo’, Gan’ Gums: (mee; Somme “One “comme xX June 3, 2016 9:07 a.m. C ON F I DEN T IAL Deposition of DAVID RODGERS, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page246 of 883 Confidential Page 18 DAVID RODGERS flyer person, then you would reduce it to an initial? MR. PAGLIUCA: Object to form and foundation. MR. REINHART: You can answer the question. You can answer the question, if you can answer the question. You are allowed to answer the question, if you understand the question. BY MR. EDWARDS: Q. I'm trying to understand your testimony. Is it, if you came to know that person -Bs Uh-huh. Q. -- as a fregquent flyer passenger, you would begin to reduce that person's name to an initial at some point? MR. PAGLIUCA: Same objection. THE WITNESS: Well, we don't really have a frequent flyer program that we do, so to speak. A lot of times I would do it because if you would write out everybody's name there is not enough space, you know, to get everybody's name in that little square there. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page247 of 883 Confidential Page 34 DAVID RODGERS Os -- is that right? And is that -- is Ghislaine Maxwell somebody that through the years 1995 through 2013 was somebody who flew very frequently? Pix What were the years again? Q. The years of this book, 1995 -Ps IT wouldn't say through 2013. But, yes, '95 through 2000 sometime. Probably, I would have to go back and -- well, you can see in there. Q. We will get to it. A. There will be a point where you don't see her much. But to say it went through 2013 would not be accurate. Q. Let's do it this way: The person that you have reflected on numerous notations -A. Yes. Q. -- through here as GM -A. Yes. Q. -- just by the initials, are we able to safely know that that is Ghislaine Maxwell? A. Yes. MR. PAGLIUCA: Object to form and foundation. MR. EDWARDS: Court reporter, did you get MAGNA®

10 iL 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page248 of 883 Confidential Page 35 DAVID RODGERS the answer? THE REPORTER: Yes. The answer came before the objection. BY MR. EDWARDS: Q. So on the next flight, the next day, from Palm Beach to SAF. Is SAF Santa Fe? A. Yes. QO. And it indicates JE and GM. Are we able to then know that those passengers on that flight were Jeffrey Epstein and Ghislaine Maxwell? A. Yes. MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: OQ“ And where would you land at SAF? Is that an airport? Ax It 1S an airport. Ox Is it a private airport? A. No. It's -- airlines go in there. O-« Did Jeffrey Epstein also have a landing strip at his property in New Mexico? Ax He did at one time. OQ“ What would that -- do you remember what MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page249 of 883 Confidential Page 36 DAVID RODGERS that code would be? ae I don't believe there was a code. QO. All right. Were there times that you landed either the Gulfstream or the Boeing -A No Q No MR. REINHART: Let him finish the question before you answer. THE WITNESS: Oh, I'm sorry. BY MR. EDWARDS: Q. Sure. We are doing fine so far. But the court reporter is taking down all of our questions and all of our answers. We are communicating well. Bes Okay. Q. But when I go to read this back, we may not get that. As Okay. Go ahead. Q. So were there times where you landed one of Jeffrey Epstein's planes on his private landing strip at the New Mexico property? Pics Yes. But not the Gulfstream and not the Boeing. on What plane did you land on his property? Bos The Cessna 421. And probably a MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page250 of 883 Confidential Page 96 DAVID RODGERS 9:00, so it is 20 to 11:00 here. BY MR. EDWARDS: Q. So I want to go to page 41, and down to December 9th. sorry. December 11. Bos Okay. Q. Palm Beach to Teterboro. Ps Yeah. Q. And who are the passengers? Bix Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia. Q. And this appears to be the first time that Virginia's name appears in the log? A. Right. Q. Is there a -- is there a reason why the first time -- I notice that the first time on some of the other passengers, you use a first and last name. Is there any reason why you didn't use her first and last name? Be I probably didn't know her last name. Q. Just didn't catch it. A. Yes. Q. Okay. It was not that somebody told you not to use the last name? Bes No. No. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page251 of 883 Confidential Page 97 DAVID RODGERS Q. So that flight goes from Palm Beach to Teterboro. Can you remember whether that's the first time that you flew on a plane with Virginia Roberts? MR. PAGLIUCA: Object to -THE WITNESS: I believe it is. MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. Do you remember the flight? A. No. O The next flight three days later goes from Teterboro to Virgin Islands with Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, and Virginia; is that right? A. Yes. O% And below that, it says, "Reposition." What does that mean? A We were taking the airplane with no passengers to go into maintenance, or an OPS2 inspection. Q. Okay. This is -- this is the same Gulfstream, is that right? Bes Yes. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page252 of 883 Confidential Page 98 DAVID RODGERS Q. How many passengers would that Gulfstream allow? As Twelve passengers, I believe. Q. And do you know how Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, and Virginia get off of St. Thomas or leave the island? Da No. I do not. Probably a charter, I'm guessing. Q. If -- who would fly the -- well, is there any other plane that Jeffrey Epstein was able to access back then that was a private plane? MR. PAGLIUCA: Object to foundation. THE WITNESS: No. At that point in time we don't have the Boeing yet. BY MR. EDWARDS: Q. So how many airplanes did Jeffrey Epstein back then? A. Well, we -- I don't know if we had the 421 then. We may or may not have. But it wouldn't -you know, you wouldn't be flying the 421 down to St. Thomas with Jeffrey. It is too long of a flight. QO. The Cessna? A. The Cessna 421, correct. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page253 of 883 Confidential Page 99 DAVID RODGERS Q. Okay. As But I'm not even sure we still had it at this point in time. Q. Yeah. It shows up on the next page. We will get there. Bis Does it? Okay. So then, yes, the answer is, yeah, we still had the airplane. But we wouldn't have used that. Q. So is there any way of telling how Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, and Virginia were in the Virgin Islands on that, from December 14th, 2000 -MR. PAGLIUCA: Object to foundation. BY MR. EDWARDS: Q. -- based on your knowledge or your logs or anything else? Riz No, I wouldn't have any way of knowing. Q. Okay. Aus Because the next flight that they are on was like this Palm Beach one, January 16th. so tL wouldn't have any idea. on Okay. To your knowledge, did Jeffrey Epstein ever fly commercially? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page254 of 883 Confidential Page 100 DAVID RODGERS A. He probably has. Back then at this time, I'm going to say probably not. But I know that he has flown commercially. But usually that would be like going to Europe, maybe. Q. Okay. January 16th through the 25th, those flights, do you see that block that I'm talking about? A. Yes. Os Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and then at times Shelly Lewis, do you see that? Bs Yes, Yignre.« Q. The 25th it lands in Teterboro. And the next day, on the 26th, leaves out of Teterboro with Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts. This time you wrote the whole name. Ais Right. Right. O's So when you write the full name, does that Signify -- that's when you may have learned her last name? A. Correct. Q. And do you know how she -- how she got up to New Jersey or New York? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page255 of 883 Confidential Page 101 DAVID RODGERS Bix I do not. I would guess the airlines. Q. At this point in time, did you know what her -- what her relationship was with Jeffrey Epstein or Ghislaine Maxwell? MR. PAGLIUCA: Object to form. THE WITNESS: No. BY MR. EDWARDS: Q. Did you -- was she a masseuse? MR. PAGLIUCA: Object to foundation. THE WITNESS: I -- I'm not sure what she was. BY MR. EDWARDS: Q. Did you form any -- any belief that she was a friend or a business associate or anything? MR. PAGLIUCA: Object to foundation. THE WITNESS: Well, I mean, we had a lot of people on the airplane. And Virginia was just another one of those passengers. BY MR. EDWARDS: Q. Okay. So on the 26th, flies to Palm Beach. And then -- and then I guess the 27th -A. Right. Q. -- leaves from Palm Beach to the Virgin Islands - MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page256 of 883 Confidential Page 102 DAVID RODGERS A. Yes. Q. -- with Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts, right? A. Yes. Q. And on the 30th, you fly it back. That's still the Gulfstream, right? A. Yes. Oi From the Virgin Islands to Palm Beach with the same four passengers, correct? A. Yes. Q. And that's Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts? A. Correct. Q. And then what happens to that plane, the Gulfstream, for the next month, from February lst through March 5th? Pes Well, I don't know what happened to it, but I'm -- from, looks like February 17th, I'm going to school to get a type rating on the Boeing. And I'm gone for about three weeks. Q. So this is when you're doing a simulator on the Boeing? A. COFTect. Q. And getting your certification to fly the MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page25/7 of 883 Confidential Page 103 DAVID RODGERS Boeing? A. Yes. Q. The Boeing, was that previously owned by The Limited or Les Wexner? Bos I'm not sure of the company name, officially. But probably, yes. Q. Some association with him? Fis Some association, yes. Q. Do you know who flew the Gulfstream while you were doing the simulator? A. Well, it would have been Larry Visoski, I'm not sure who the first officer was. Q. Do you know if any logs were kept of the passengers’ names? Pew. While I was at school? Q. Right, while you were at school. Ais There probably were logs, but I don't know where they are. Q. Have you ever spoken with Larry about whether he kept names of passengers? Bice I don't think he does. Q. Do you know where Larry Visoski flew the Gulfstream for the month that you were -A. No. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page258 of 883 Confidential Page 104 DAVID RODGERS Q. Sorry. Just let me finish my question. I know I was getting it out slow. -- but for the month that you were training on the Boeing? A. No. Q. All right. So the last flight that you took in the Gulfstream before you began, before you flew the Cessna for a day, I guess, right, from Santa Fe to DFW -Rea Right. Q. -- February 3rd -A. Yes. Q. And that's the Cessna with 908GM tail A. Yes. Q. The last flight that you flew on the Gulfstream was the flight back from St. Thomas with Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts, right? Rus Uh-huh. Q. And then the next time that you're on the plane is -- on the Gulfstream is when? A. It looks like March the 5th. 0. And who are the passengers on that flight? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page259 of 883 Confidential Page 105 DAVID RODGERS Where is it going to? Pix Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia Roberts. Q. And then there's notation of Gary Roxborough? A. Yes. Q. Do you know why that is? As Yeah. He was the first officer. Q. Why did he become the first officer? Bes Because Larry was probably in training for the Boeing. or Okay. You took -- you alternated? A. Right. We didn't go at the same time. Q. All right. Then the Gulfstream has the Same aircraft make and model. That's the same Gulfstream airplane, right? A. Yess Q. But the aircraft identification mark A. Correct. QO. -- on March 5th, 2001. A. Correct. om And it changes to N -- it changes from NI9YO8JE to NOOQJE. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page260 of 883 Confidential Page 106 DAVID RODGERS A. Yes. Q. Why was that? A. Because the N9YO8JE went to the Boeing. That was going to be on the Boeing now. Q. And the new number for N9YOOQJE was transferred to the Gulfstream? A. Correct. QO. And where does that first flight on the 5th go? Aes From Palm Beach to Stephenville up in Newfoundland for a fuel stop. Q. Okay. And then how do you know it is a fuel stop? Pic Because we are going to Paris, and so we have to stop there for fuel. Q. Okay. I know how -- I know how you would know that. But is there any indication on any of the numbers that go off to the right that would tell me that it's a fuel stop as opposed to -A. No. Q. No? Okay. All right. So there's no way after today's deposition I can look at any of the numbers; it's not going to tell me what it was for? Pos No. No. And it's -- obviously it looks MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page261 of 883 Confidential Page 107 DAVID RODGERS different, because one day is the 5th; one day is the 6th. But we landed there like at 11:50 at night. And then when we took off, it was, you know, the next day. Q. Okay. Got it. And then where do you go the next day? Ps We went from Stephenville to Paris-Le Bourget. Q. And who were the passengers going to Paris? A. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts. Q. And then what's the next flight? A. On the 8th, from Paris to -- I believe that is in Spain. Q. Granada, Spain? Ris Granada, Spain. COrTrrece. Q. Okay. And who are the passengers on that trip? Pris Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia Roberts, Alberto and Linda Pinto, one female, and Ricardo, it looks like Orieta. on And then what's the next flight? A. From there to Tangiers. From Granada to MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page262 of 883 Confidential Page 108 DAVID RODGERS Tangiers. Q. When you landed -- sorry to go back -when you landed in -- what did we say LEGR was? A. Granada, Spain. Q. Where did -- where did you stay? Where do you stay on those trips? Ps We didn't stay. We left the same day, I believe. Q. Okay. What if we go back to one flight to LFPB? A. Uh-huh. LFPB. om That's Paris? Bs Yeah. We stayed in Paris. Q. And do -Aw We stayed there. Q. Do you know -- do you stay at the same location where Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and Virginia Roberts stay? A. No. Q. Where do you stay while you are in Paris? Aw Hotel. Q. Where do they say? MR. PAGLIUCA: Object to foundation. THE WITNESS: He has a place there, in MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page263 of 883 Confidential Page 109 DAVID RODGERS Paris. BY MR. EDWARDS: Q. Okay. Jeffrey Epstein has a home or a house in Paris? Be Right. Q. Okay. Have you been to it? A. Yes, I believe I have. Q. Have you ever stayed there? A. No. Q. And getting to and from the airport, were you ever in the car riding to or from the airport in Paris with Jeffrey Epstein? A. No. Q. So going down to the 9th, then, where is that flight? as That is from Tangiers to London Luton ALE pOrt« Or And is Luton Airport, is that a major airport? A. For general aviation it is. There is airline service in there, but it is not a huge one, for sure. QO. Who were the passengers? Pos Jeffrey Epstein, Ghislaine Maxwell, Emmy MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page264 of 883 Tayler, Q. Confidential Page 110 DAVID RODGERS and Virginia Roberts. And am I reading this correctly that the next flight is two days later, on the 11th? A. QO. A. Q. Yes. And where does the flight on the 11th go? From Luton to Bangor, Maine. All right. While in London, do you know what Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, A. Q. A. Q. and Virginia Roberts did? No, I do not. Do you know who they saw? No, I do not. After the flight to Maine, where is the next flight? day. A. Maine is from Bangor to Teterboro the same Q. Okay. A « So that was a fuel stop. MR. EDWARDS: All right. We are at a good time to stop. The videographer has to change tapes. THE WITNESS: Okay. MR. EDWARDS: So we why don't we take a five-minute break. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page265 of 883 Confidential Page 111 DAVID RODGERS THE WITNESS: Okay. THE VIDEOGRAPHER: Off the record at 10257. (Thereupon, a recess was taken, after which the following proceedings were held: ) THE VIDEOGRAPHER: This is the beginning of Disk 2. On the record at 11:12. BY MR. EDWARDS: Q. Sure. If we go back to page 41, December 7th, 2000. MR. PAGLIUCA: Give us a Bates page, please. MR. EDWARDS: Right, 41. For the remainder, when I say "page, I'm really just referring to the Bates number. BY MR. EDWARDS: Q. So page 41, December 7th, 2000. A. Okay. QO. Do you see that? Where was that flight going from and to? A. Luton to -- Luton -- that's going into Marham Air Force Base. Q. Do you remember why you would have flown into the Air Force base? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page266 of 883 Confidential Page 112 DAVID RODGERS Pes We flew in there to drop the passengers off. And then these passengers that were on there, we dropped them off. And then -- let's see. We repositioned. I don't remember. We dropped passengers off, and we had to leave, I believe. Q. Okay. That was -oe We weren't allowed to stay there. Q. That was Tom Pritzker? A. Yes. Q. And then did you also drop off Jeffrey Epstein, Ghislaine Maxwell, Kelly Spamm? A. Yes. Q. Okay. A. I believe everyone got off the airplane there. Oz And where did you reposition to? A. It says, "Positioned in Norwich, England." I guess it's Norwich. Q. Sandringham, that is what it says right above that. What is that? Ais Sandringham. I believe Sandringham is the estate that the gueen has -0. Okay. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page267 of 883 Confidential Page 113 DAVID RODGERS Bes -- near there. Q. All right. And the flight on December 9th -Ris Uh-huh. Q. That's Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Kelly Spamm? Bs Righe« Q. And then what did you write in the parenthesis under that? as "Blowing snow on runway." Tt was a great weird phenomenon that happened that night. om And then you're leaving out of that Sandringham Airport; is that right? Bis We are -- which one are you on? Q. On the 9th. Avs On the 9th -O% The first entry on the 9th. Bs The 9th, we're leaving, looks like Norwich, England, I believe, EGSH, and we go to Gander, Newfoundland -Q. Okay? Aas -- for a fuel stop. QO. I think before we took a break that we were on page 43. MAGNA®

10 iL 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page268 of 883 Confidential Page 114 DAVID RODGERS Poa Uh-huh. Q. And the flight that began in Palm Beach, before going to Paris and Belgium, Tangier, I think you told me, it ended up in Maine -A. COTIECL. Q. -- on March 11th, 2001. Bx Right. Q. Or, sorry, it ended up in Teterboro. A. Teterboro. Q. Okay. And then on the 15th, you fly from -- on the Gulfstream out of Teterboro to ISP. Do you know where that is? A. Islip, New York. Q. Okay. And Virginia Roberts was on the flight that landed in Teterboro on the 11th, correct? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Yes. BY MR. EDWARDS: Ox But leaving out of Teterboro, she's not one of the passengers on the flight. A. No. Q. Any idea where she went? MAGNA®

10 iL 12 13 14 15 16 17 18 19 20 21 22 Z3 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page269 of 883 Confidential Page 115 DAVID RODGERS A. No. QO. Okay. MR. PAGLIUCA: Are you referring to Bates 0041, the l1ith through 14th? Is that what you're talking about? MR. EDWARDS: Forty-three. MR. PAGLIUCA: Forty-three. MR. EDWARDS: March 11th and March 15th, 2001. MR. REINHART: If it will help there, the flight numbers column, like the fifth or sixth column over, are sequentially numbered and unigue numbers. So if you want to just say "flight 1468" -MR. EDWARDS: Okay. MR. REINHART: -- that might help everybody -MR. EDWARDS: Right. MR. REINHART: -- follow along. MR. EDWARDS: Okay. Thanks, Bruce. MR. REINHART: Uh-huh. BY MR. EDWARDS: om So the flight now that I'm talking about that leaves out of Teterboro on the 15th, flight MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page270 of 883 Confidential Page 116 DAVID RODGERS No 1471 -Ps Right. Q. -- the passengers appear to be Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, Alexia Wallert and Banu Cukuglu? A. I think so. Ox Do you remember Banu? A. I definitely remember that. It was a hard name to spell. Yeah. Sort of, I guess. I mean, if she walked in right now, I probably wouldn't recognize her. QO. Well, it has been since 2001, so -Pie Yeah, I know. Q. Okay. So then the next flight is 1472. Where is that? Where is that going? Bi % From Islip to Lake City, Florida. or All right. And the passengers, again, are who? Pants Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, Alexia Wallert and Banu Cukuglu, whatever her name is. om Did you know what relationship she had, if at all, with Jeffrey Epstein? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page271 of 883 Confidential Page 117 DAVID RODGERS A. No. No. Os Do you remember an Ed Tuttle? A. Yes. QO And who was he? Pe I believe Ed was a, probably in construction. IT think he may have been around before the Jeffrey -- well, let me think. Q. If we skip down to March 16th, I see his name. So I don't know if that's going to help you. Dis I believe -- I believe Ed Tuttle was like maybe an architect, or somewhere in the construction, real estate side, I believe. Q. A. Q. Okay. So flight No. 1477 -Uh-huh. -- from LaGuardia to Palm Beach, is that Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Joe Pagano, A. Q. Eva Dubin? Yes. Celina Dubin? Yes. Jordan Dubin? Right. Maya Dubin and two nannies? Yes. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page2/2 of 883 Confidential Page 118 DAVID RODGERS QO. And Alexia Wallert? Is that what that is? A. I would assume so, yes, AW. Q. That is sort of what we talked about in the beginning, where Alexia Wallert appears in full name at the top -Pics Raqhe« Q. -- and it's AW, AW, AW. As And there's no room to write her name out there -Q. Right. Bi -- so she's AW. Q. Okay. And then the next flight, the 27th, leaves out of Palm Beach. Who are our passengers on that flight and where's it going? 1478 is the flight. Ris Yeah. Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia Roberts, two females, Banu, and that's it. QO. And do you know, in New York, when that plane lands in Teterboro, where do you stay when the plane is up there? Pi It is 2001. At an apartment there. Q. Did you have your own apartment? A. Yes. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page273 of 883 Confidential Page 119 DAVID RODGERS Q. Or did you stay at one of Jeffrey Epstein's apartments? A. No. It was his apartment, Jeffrey's apartment. QO. Was that one of the apartments at 301 East 66th Street? A. Yes. Q. And did any of the other passengers from that flight, that 1478, did any of them stay at any of those apartments? Bs Yeah. Emmy would have. Virginia probably did. Q. Did you see Virginia stay at the apartment? Bove I don't know. Q. When you were in New York and you left from the airport, did you ride in the same car with Virginia? A Not usually. I mean, I don't know if we ever did. It's possible we did. Q. Do you know whether Virginia Roberts stayed at Jeffrey Epstein's townhouse or whether Virginia Roberts stayed at the apartments? MR. PAGLIUCA: Object to form. MAGNA®

10 iL 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page274 of 883 Confidential Page 120 DAVID RODGERS THE WITNESS: I don't know for sure. BY MR. EDWARDS Q. Can you recollect riding in a car with her, or can you recollect whether she got in a car with anyone else? MR. PAGLIUCA: Object to form. THE WITNESS: I can't. MR. EDWARDS: Okay. MR. REINHART: I'm sorry. Are you asking about that specific trip or -MR. EDWARDS: sorry. BY MR. EDWARDS: Q. I mean that specific trip. A. No. I can't. O« How about in general at any time? A. No. I don't recall. I mean, I can recall, I would ride sometimes with Emmy, with Adam I remember them being in the car. But, again, that was unusual. Usually it would just be Larry and myself. But on occasion, you know, somebody might ride with us. O-% When you would stay at the apartment in New York on East 66th Street, would it always be in MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page275 of 883 Confidential Page 121 DAVID RODGERS the same apartment? A. Yes. om All right. There are multiple apartments owned by Jeffrey Epstein? A. At that time, it was the same apartment. Q. Okay. Have you stayed in other apartments Since that time? A. Yes. Q. All at that East 66th Street location? Dis Yes. I really don't -- I don't have an apartment there now. We haven't gone there since probably 2008. QO. How about Banu? Would she have stayed at 301 East 66th Street? MR. PAGLIUCA: Object to foundation. THE WITNESS: Most likely. BY MR. EDWARDS O' Why do you say that? A Well, if she's on the plane with us on multiple trips, then most likely she probably stayed there. Q. Have you been to Jeffrey Epstein's townhouse as 9 East 71st Street? Bes Yes. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page276 of 883 Confidential Page 122 DAVID RODGERS Q. And it's a pretty big place, right? Pix Pretty big. Os And it has numerous bedrooms? A. Yes. QO. Any reason why Banu would not have been staying there? MR. PAGLIUCA: Object to foundation. THE WITNESS: I don't know. BY MR. EDWARDS Q. I'm just trying to get to, is there a reason why you believe that Banu would have, I think you said, probably have stayed at the apartment versus the townhouse? Bes Well, I only say that because Emmy, you know, stayed there. Q. Stayed where? Ais At the -- at our apartments. O'. Okay. As I'm pretty sure Adam, yeah, Adam stayed there at the time. So most of the people that were regulars on the flight, they would stay there in the apartments. Q. Okay. But do you remember Virginia or Banu staying in the apartments? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page2/7 of 883 Confidential Page 123 DAVID RODGERS A. I do not specifically. Q. Okay. The next flight on the next day, 1479, is flying from Teterboro to Santa Fe; is that iG i 2 A. Yes. Q. And who are those passengers? Ds Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, Virginia Roberts, Banu, Marvin Minsky, Henry Jarecki. Q. Do you remember Marvin and Henry? A. I remember Henry. I don't really remember Marvin. Q. Okay. And then two days later -- again, where would you have stayed if you landed in Santa Fe on March 29th, 2001? Avs Probably would have stayed at the ranch. Q. At the Zorro Ranch? A. Yes. Q. All right. Did the other passengers that were on the plane, Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, Virginia Roberts, Banu -I'm not evening going to try her last name -Pe Right. O-% -- Marvin Minsky and Henry Jarecki also MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page278 of 883 Confidential Page 124 DAVID RODGERS have stayed at the ranch? MR. PAGLIUCA: Object to foundation. THE WITNESS: I'm going to say most likely they did. BY MR. EDWARDS Q. Was there any other location in Santa Fe where you are aware passengers would have stayed? As Not that I'm aware of. Q. If you were all going to the same place, is that an occasion where you would all ride in the same vehicle from the airport to the ranch? MR. PAGLIUCA: Object to foundation. THE WITNESS: I don't know. BY MR. EDWARDS Q. You would still right in separate vehicles? Bi % Right. Because it takes us about an hour to finish up at the airport. Q. And then the 3lst, so two days? Bw Let me go back to that one -Q. sure. Ais -- and say, it is possible. IT think Adam has ridden with us before. So I couldn't swear that one way or the other. But he has probably ridden MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page279 of 883 Confidential Page 125 DAVID RODGERS with us before to the airport; to or from the airport. om Two days later, flight No. 1408 out of Santa Fe to Palm Beach, who were the passengers there? Bis Jeffrey Epstein, Ghislaine Maxwell, Prince Andrew, Virginia Roberts, Nadia Bjorlin, Henry Jarecki, Marvin Minsky. Q. Do you remember when you were at the ranch Nadia Bjorlin arriving? Pi I would assume that she airlined in there. or Do you remember her at the ranch? Did she perform for you or anything? Di No. I don't remember her at the ranch. I mean, I'm sure she was there. I just don't remember. O'. Okay. Do you remember a person named Heather Mann? She's found on flight 1438 next to Lydia. Aw Heather Mann, not really. Q. Okay. The next flight, on page 45, is 1488. The flight number. April 9th, 2001. Bos Right. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page280 of 883 Confidential Page 126 DAVID RODGERS Q. Where does that flight take off from and where does it go? A. Palm Beach to Atlantic City. Q. Who is on that flight? Pe. Jeffrey Epstein, Emmy Tayler, Virginia Roberts, Banu and Johanna. Q. Do you remember Johanna Sjoberg? ae I don't. Q. On that same day, you take a flight to Teterboro? Bix Right. on Did you go to the casinos at all that day? A. I don't think so. Q. Would that be something that you would do with them? Or you would stay back? Bis No. We would stay at the airport. Oz All right. And then two days later, on the 11th, flight 1490, the plane flies out of Teterboro. For that two-day period of time, the night of the 9th and the night of the 10th, would you have stayed at the apartment? MR. PAGLIUCA: Object to foundation. MR. EDWARDS: In New York. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page281 of 883 Confidential Page 127 DAVID RODGERS THE WITNESS: I would say, yes. BY MR. EDWARDS: O- All right. Do you know where Virginia and Banu and Johanna stayed? Ps No idea. Q. You can't recollect whether they were -you can't recollect seeing them at the apartments? MR. PAGLIUCA: Object to foundation. THE WITNESS: No. BY MR. EDWARDS: Q. ALL Vagnt. Then on the lith, you leave from Teterboro and go to where? Ass St. Thomas. Q. That is flight 1490. And on that flight, Jeffrey Epstein, Ghislaine Maxwell, Prince Andrew, Banu, Virginia Roberts and Johanna? A. Yes. Q. And that is -- that is a flight -- how does -- how did those passengers get from -- does Jeffrey Epstein have a place in St. Thomas? MR. PAGLIUCA: Object to form. THE WITNESS: Well, yes. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page282 of 883 Confidential Page 128 DAVID RODGERS BY MR. EDWARDS: Ox Where is that? A. In St. Thomas, he has an office. in. Sv. Thomas. Q. Where does he stay in the Virgin Islands? Pi On Little St. James. Q. And how do the passengers get from St. Thomas to Little St. James? Bis Most likely, helicopter. Q. How many people does the helicopter fit? A. We didn't own a helicopter then. Probably -- probably 5. It depends, because they had different helicopters. I'm not sure which one they used that day. Q. What is the duration of the flight from St. Thomas to Little St. James? Bi % About six minutes. Or What is the duration of a boat trip from Little St. James to St. Thomas? Pints Probably about, let's say, 15 to 20 minutes. But you are on the east side of the island and the airport is almost to the west side of the island. Q. So you have to almost circle the island? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page283 of 883 Confidential Page 129 DAVID RODGERS A. To get from the island by boat, to get to -- there's land there and take a car, it is probably -- it is probably close to an hour, 45 Minutes for sure. QO. Are there passenger manifests that are kept for the helicopters? MR. PAGLIUCA: Object to foundation. THE WITNESS: I'm not sure. I'm not sure. BY MR. EDWARDS: Q. Back in this time, in around April of 2001, did Jeffrey Epstein have a helicopter yet? Bs No, he did not have a helicopter. Q. At that time? A. Correct. Q. And so do you remember the name of the company or corporation that they rented or transported? Bs I don't. It was the only -- helicopter service there in St. Thomas is no longer there. Q. Okay. Bs Air Center Helicopter. Q. Was there a particular person at Air Center Helicopter that you ever coordinated with? Bos We would, like, call a dispatcher. Or you MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page284 of 883 Confidential Page 130 DAVID RODGERS know, whoever picked up the phone, we would call them. O- All right. So 1491 is a flight from St. Thomas to Palm Beach; is that right? A. Yes. Q. And Gwendolyn Beck is now on that flight? A. Yes. Q. Do you remember that flight at all, 1491? A. Not really. Q. Anything about it stick out in your mind? A. No. Q. All right. The next flight that -- do you remember a female name Kelly Bovina? Pie I remember the name, but I don't remember her. Q. Was she an actress as well, do you remember that? Bs I don't recall. Q. The next flight I want to direct your attention is 1501, May 3rd, 2001. Aw Okay. Q. What is that airport, ADS? A. Addison, Texas. San Antonio, Texas. 0. And who are the passengers on that? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page285 of 883 Confidential Page 131 DAVID RODGERS Rs Jeffrey Epstein, Virginia Roberts. Q. Do you know how Virginia Roberts got to Addison, Texas? A. No. Q. Was that flight -- was the purpose of that flight only to pick up Virginia Roberts? MR. PAGLIUCA: Object to form and foundation. BY MR. EDWARDS: Q. Can you tell by your logs? A. Not really. Let's see. We -- no, I don't know. Q. The flight previous on the 3rd flies in from where? Where is that? Bex Little Rock. Q. Arkansas? A. Correct. O-. So the only passenger on that flight from Little Rock, Arkansas, to Addison, Texas, flight 1500, is Jeffrey Epstein, right? Bice Right. Q. And then you land in Addison before going to Santa Fe? Pos That is actually San Antonio, I believe. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page286 of 883 Confidential Page 132 DAVID RODGERS Yes. That is San Antonio, SAT. Os How long is the flight from Addison to San Antonio? Ais IT would be guessing, probably an hour. Q. Do you know what the purpose was for landing -Re Well, you know, I can tell you. It is 9/10s. Fifty-four minutes. Q. Do you know what the purpose was to be to land in Addison, Texas, before arriving in San Antonio? Pos I do not. But it appears that we spent the night in San -- oh, I see what you are saying. No, I don't know. That I went to Addison probably the same day. Q. Went to Addison and picked up Virginia Roberts? Bs It looks like it. Q. And then in San Antonio, two days later, who are your passengers on that flight, 1502? Bice Jeffrey Epstein, Virginia Roberts. Q. Where do you fly? As From San Antonio to Palm Beach. Q. And in May, on May 14th, 2001, flight MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page287 of 883 Confidential Page 133 DAVID RODGERS 1506, where is that flight leaving from? Piz St. Thomas. om And going where? Ais Teterboro. Q. And who are your passengers? Pics Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Banu, Virginia Roberts and one female. Q. And, again, do you remember who the one female would have been with Virginia Roberts? A. No. Q. Can you tell by this how any of those individuals that were on that flight leaving from the Virgin Islands to Teterboro got to the Virgin Islands? A. No. Q. What were the other possible avenues back in those days for Jeffrey Epstein, Ghislaine Maxwell to travel to the Virgin Islands? As They could have done a charter, possibly. Q. Okay. Was there ever a time when, it looks like that is the -- that is the Gulfstream that you fly out of the Virgin Islands to Teterboro, correct? A. COrTrect. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page288 of 883 Confidential Page 134 DAVID RODGERS Q. Was there ever a time you were flying the Gulfstream and -- well, let's go back a little bit. As Okay. Q. On May 7th, at the top. Pe Right. QO. Flight 1503, that is the Gulfstream traveling from Palm Beach to CHO? A. That is Charlottesville, I believe, Virginia. Q. And then on that same day from Charlottesville to Teterboro? A. Correct. Q. So when does the Gulfstream get from Teterboro to St. Thomas? A. Hmm, I don't know. Because it appears that I'm on vacation at that time. So I don't know. Q. How did you get to St. Thomas for the 14th to fly? ae Airline. Q. All right. So at some point in time, between May 7th and May 14th -As Uh-huh. Q. -- somebody flies the Gulfstream to the Virgin Islands. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page289 of 883 Confidential Page 135 DAVID RODGERS A. Correct. O's And who would that be? MR. PAGLIUCA: Object to foundation. THE WITNESS: Larry Visoski and I don't know who the other person would have been. BY MR. EDWARDS: Q. When you pick up passengers in the Virgin Islands and you are taking them to Teterboro, do you speak with Larry Visoski about when he arrived in the Virgin Islands? A. Yeah. Yeah. We would coordinate that. I mean, usually we would go down there together. We would ride in the same airline down. Q. In this particular case, you were on vacation? A. Well, that is true. However, most likely he airlined home once he got to St. Thomas. And then most likely, we drove ina car to Miami and road the same airline down there. Q. That was something that you customarily did? A. Yes. Q. Okay. So then you have -- we have no way of knowing then who the passengers that flew to the MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page290 of 883 Confidential Page 136 DAVID RODGERS Virgin Islands would have been, if there were any in addition to those that left? A. No. QO. ALL Page. You fly into Teterboro on flight 1506 on May 14th, 2001, and fly out in the Gulfstream on the 24th, 10 days later; is that PG t.2 A. Yes. Q. And your passengers, 10 days later flying to Palm Beach are Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Adam Perry Lang and a female. Bos Right. Q. Do you know where Virginia Roberts went during that time after she landed in Teterboro on the 14th? As I do not. Oz Page 47, I'm going to go to flight No. 1510. June 3rd, 2001. Who is on that flight? A. Jeffrey Epstein, Virginia Roberts, Banu. Q. And you are flying from Palm Beach to St. Thomas again? Bs St. Thomas, yes. QO. And then from St. Thomas to Teterboro two MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page291 of 883 Confidential Page 137 DAVID RODGERS days later, on June 5th? ae Jeffrey Epstein, Virginia Roberts, and Banu. QO. ALL Page. And then where is the next flight on the 8th? A. On the 8th, from Teterboro to Montreal. QO. Do you know what -- so Virginia Roberts and Banu were not on the flight on the 8th, right? A. That's correct. Q. Okay. Do you remember the flight on the 8th with Naomi Campbell, Rebecca White, Ana Malova? Pos Sort of. But not really. Q. Okay. Do you remember who Rebecca White 1S-2 A. No. Q. Do you remember how old Rebecca White was? A. No. Q. The next flight I want to direct your attention to is on the 15th of June, flight 1516. Rus Uh-huh. Q. Passengers: Jeffrey Epstein, Ghislaine Maxwell, and then does that say Sheridan? A. Yes. 0. Do you remember a passenger named Sheridan MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page292 of 883 Confidential Page 138 DAVID RODGERS Gibson? Ax Possibly. Q. And then it says, Caroline. Do you know who Caroline is? Aix I do not. QO And then one female? A. Yeah, I don't know who the female is. Q Okay. On the 28th, there is a flight 152334 As Uh-huh. Q. From -- is that Portugal to St. Thomas? A. No. It is the Azores. Os LPAZ? Ais Yes. It was a fuel stop. QO. To St. Thomas? A. Right. Q. And then on that flight is Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler and Ed Tuttle, right? A. Yes. Q. Six days later, leaving on July 4th from St. Thomas, who are your passengers? Bs Jeffrey Epstein, Prince Andrew, Virginia Roberts, one female. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page293 of 883 Confidential Page 139 DAVID RODGERS Q. And do you know how Virginia Roberts got to the Virgin Islands? A. No. Q. Is there any -- is it possible that the Cessna took her or the Boeing took her? Or any other aircraft that is owned by Jeffrey? MR. PAGLIUCA: Object to foundation. THE WITNESS: No, I would -- if I had to guess, I would guess the airlines. BY MR. EDWARDS: Q. Okay. Bs Well, I know it wasn't the Boeing, because the Boeing is not in operation at that point in time. We hadn't flown it. I mean, it hadn't had any passengers on board yet. That is like in August of 2001. Oz Okay. And the Cessna, did you take that from Florida to the Virgin Islands? A It has been to the Virgin Islands, but I don't think we ever took any passengers down there. Q. Okay. All right. The next flight is L525 x Bis Okay. 0. On July 8th, 2001. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page294 of 883 Confidential Page 140 DAVID RODGERS Pos Okay. O's That leaves out of Palm Beach? As Okay. Q. Where do you go on that? Box Teterboro. And who are your passengers? PP 10 Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Prince Andrew, Virginia Roberts, Sheridan Gibson, maybe Sheridan Gibson-Beaute, I guess, and one female. Q. And then three days later, you leave out of Teterboro to CPS? Pes Yes. QO. Where is that? A. That is St. Louis, actually it is Cahokia, Tllinois, across the river from St. Louis. Os Who are your passengers? Bs Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Virginia Roberts. We were actually en route to Santa Fe. We had a mechanical problem. We had to go into there for maintenance. Q. Do you remember having a mechanical problem or is the log just refreshing your memory? Pos No, I remember because that was the only MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page295 of 883 Confidential Page 141 DAVID RODGERS time we landed at Cahokia with passengers on board. Q. What was the problem? A. We had a -- we had a static line that had cracked and it was causing our altimeters to not agree. And then we went to the alternate system, things got really worse because it was stopped up with a mud dauber somewhere in the system. That is why I remember that flight. O% When you landed in St. Louis did the passengers get off the plane? A. Yes. And then they airlined -- I believe they airlined. They could have taken a charter, I don't recall. But I know they didn't leave with us. Q. All right. And the passengers that got off the plane would have been Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler and Virginia Roberts? A. Yes. Q. And then on the 16th, those five days later, those same passengers leave Santa Fe? Pos Right. Q. And go back to Teterboro? A. Correct. on When Jeffrey Epstein would go to his townhouse in New York, would you always fly into MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page296 of 883 Confidential Page 142 DAVID RODGERS Teterboro? Ps Most of the time. It would depend on the airplane, too. Like the Boeing, you are not allowed to take it into Teterboro. Q. So while you had the Gulfstream, it seemed like Teterboro? A. Yeah, it is -- I mean, occasionally there would be a LaGuardia in there, but not really often. Q. So on the 16th, you fly in to Teterboro. And then six days later, it looks like, flight No. 15 -- oh, wait. Fob. 3 eG. So flight No. 1528, you fly into Teterboro, Jeffrey Epstein, Emmy Tayler, Ghislaine Maxwell and Virginia Roberts. Do you see that? A. Yes. Q. Then the next flight I have listed is 1573.0: Do you know where 1529 is? As No, other than I'm gone for some reason. I wasn't on that flight. Let's see. July, approximately. I see I went on vacation. Q. Okay. And the 23rd, there is a flight from Palm Beach to St. Thomas with Jeffrey Epstein, MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page297 of 883 Confidential Page 143 DAVID RODGERS Shelly Lewis. Do you see that? A. Yes. Q. Five days later, the flight that leaves St. Thomas does not have Shelly Lewis; is that right? A. Correct. Ox And then you fly to Palm Beach? A. Yes. Q. And who are your passengers at that time? A Jeffrey Epstein, Virginia Roberts, yes. QO. When you had the mechanical problem, do you remember any of the passengers being scared or frightened? Pic No. Not really. I mean, they didn't really know that we had a problem. We just informed them that we couldn't continue on to Santa Fe. O% Okay. And August 7th, 2001, flight 2? A « Uh-huh. Q. Is that the first flight that the Boeing makes with passengers? A. Correct. Q. And that is Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Prince Andrew and two females. Do you remember who the two females were on the MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page298 of 883 Confidential Page 144 DAVID RODGERS first passenger flight of the Boeing? Biz I do not. O And then on the 7th -- at that flight flew from Los Angeles to Albuquerque, correct? Bow Uh-huh. Q. On the 14th, you were flying the Cessna that has the 908GM tag. Fis COFTECE. Right. Q. And then the next entry with passengers is on the 16th. And you are flying the Boeing again, right? A. Yes. Q. All raght. Do you know who flew the Boeing for flight 3, 4 and 5? A. For 3, 4 and 5, no. Oh, yes. I know it wasn't me. I do remember that now. I went on vacation. And it was a contract guy that flew for us while I was gone. Q. Do you remember a passenger named Alexander Dixon? A. Alexander Dixon, no. Q. Flight No. 11 on the Boeing? As Uh-huh. Q. Now, the Boeing has the tag 908JE? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page299 of 883 Confidential Page 145 DAVID RODGERS A. Correct. om That is what you were explaining in the beginning, correct? A. Correct. Q. So September 3rd, the Boeing flies from St. Thomas to HPN? A. Yes, White Plains, New York. Q. And your passengers? Bix Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Adam Perry Lane, Banu, Sarah Kellen, Alexander Dixon. or Do you remember Sarah Kellen? A. Yes. Q. And do you remember what -- is that your first time meeting Sarah Kellen, when she appears? ve I don't think so. I thought she was on an earlier flight. Let's see. But it could be. La could be, I'm not sure. Os Do you know how Sarah Kellen got to St. Thomas to be leaving St. Thomas with you? A. No. Q. Do you know what her relationship was, if any, with Jeffrey Epstein? Bos She was -- Sarah was sort of taking over MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page300 of 883 Confidential Page 146 DAVID RODGERS Emmy's position. Like an assistant to Ghislaine. Q. Ald Pragqhe. Page 53. January 15th, 2002. As Okay. Q. There is a flight from Bedford, Massachusetts; is that right? A. Yess. Q. To where is that going? Ais White Plains. Q. And it's Jeffrey Epstein and Jessica. A. YES. Q. Do you remember who Jessica is? Pox I do not. Q. From White Plains, who are the passengers going to St. Thomas? A. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Prince Andrew, Cindy Lopez, Johanna and one female. Q. Do you remember Cindy Lopez? A. Yes. Q. And what did she do? A. I don't know what she did, but I do remember Cindy Lopez. Q. Was she somebody that you believed to be a masseuse? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page301 of 883 Confidential Page 147 DAVID RODGERS A. I'm not sure what her position was. It is possible. om All right. February 9th, 2002, flight 57 on the Boeing. Bos Okay. Q. From Miami to White Plains. A. Yes. Q. Your passengers include Bill Clinton, four Secret Service. Did the Secret Service ask that you not identify them by name? A. No. Q. Any reason that you didn't identify them Bove Didn't know their name. QO. Two males, one female. Ais Right. Q. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen and Prince Andrew. A. COTVFeECTs. Q. Was that your first time meeting Bill Clinton? A. Yes. Q. At that point, did you have any MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page302 of 883 Confidential Page 148 DAVID RODGERS understanding of what was the relationship between Jeffrey Epstein and Bill Clinton or Ghislaine Maxwell and Bill Clinton? A. No, I didn't have any idea. Q. Had you seen any pictures, prior to that time, of Bill Clinton in any of Jeffrey Epstein's planes or homes? Aus Not him I'm aware of. Q. Have you ever seen a picture of Bill Clinton in Jeffrey Epstein's plane? Pi fs In his plane? I don't think so. om Have you ever seen one in his homes? Ps Not that I can recall. Q. Okay. A Oh, wait, wait. Back up. A picture of Bill Clinton in the plane? Do you mean the picture is on the wall in the airplane or a picture taken of Bill Clinton on the plane? Q. A picture of Bill Clinton on the wall of the airplane. Avs T have a picture of me and actually the crew with Bill Clinton on the plane, but it is not on the wall of the airplane. O-% And when was the picture of you with Bill MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page303 of 883 Confidential Page 149 DAVID RODGERS Clinton taken? Pus I think it was the first flight. Q. The flight that we just looked at? A. Yes. Q. To the best of your knowledge, is that the first time that Bill Clinton flew with Jeffrey Epstein or Ghislaine Maxwell? A. To the best of my knowledge. It was the first time that we had flown him. Q. Okay. On flight No. 72, which is page 54, March 10th. Pos Okay. Q. The Boeing flies from St. Thomas to JFK; is that right? A. Yes. Q. Is there any way of knowing when the Boeing got to St. Thomas by these logs? Bs Yes, it got there on the 28th. Because it is trip No. 71 above it. Oh, wait. Oh. Wait. State the question again. Q. Yes, exactly. Do we know how or when the Boeing got to St. Thomas? It is leaving out of St. Thomas on flight 72, but flight 71 seems to me to land in Palm MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page304 of 883 Confidential Page 150 DAVID RODGERS Beach. A. Correct. O- So I'm just missing the kind of connection there. Fes Yes. Me, too. Q. Okay. A. Yeah, I don't have an answer for that. Q. Okay. Would somebody else have flown the Boeing, while you were doing this simulator, the 6th and 7th and 8th? A. It is possible. on That is one possible conclusion, based upon what we have here? Pit That is probably what happened. Q. Okay. So then March 10th -- sorry. March 10th, you fly to JFK, right? A. Yes. QO. March 4th, from JFK to Palm Beach. March the 17th, from Palm Beach back to JFK. And then March 19th, 2002, you fly from JFK to -- where is that? Pas Luton, London. 0. And who are your passengers? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page305 of 883 Confidential Page 151 DAVID RODGERS ae Bid, Clinatvon. Doug Band. Three Secret Service, Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen. Q. And the next day -- or, sorry, two days later. Do you know where those passengers stayed in London? Bs I have to think about this one second. No, in fact, I don't think they did. Because we didn't spend the night there. We went there. IT got to the hotel. As soon as I got to the hotel, I got word from Secret Service that President Clinton wanted to leave that night, so we left that night. So we made it to the hotel, the crew did, but we were there not that long. Two or three hours, four hours, maybe. Q. Do you remember why he wanted to leave that night? Ps No. No, because when we went there, we thought we were going to be there for like probably at least a couple of nights. But it didn't turn out -- we didn't even spend one night there. Q. Okay. So does this probably mean that you got there late at night on the 19th, the early MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page306 of 883 Confidential Page 152 DAVID RODGERS morning on the 21st? Bs We took off the 19th. So when we land there, it is really the 20th. And probably when we took off there, it is like after midnight or thereabouts. Q. And that is when you fly back to JFK? Pus Back to JFK, yes. Q. And you went there with three Secret Service and came back with 10? A. Yes. Q. How did that happen? Pox Well, there was an advance party waiting for us when we got there and then when we came back, they just flew back with us. Q. What was the events that you were traveling to London for? Pes I'm not sure. I would imagine, he was probably giving a speech. Q. Okay. And you came back with Bill Clinton, Doug Band? Ax Yes. Q. Who was Doug Band? A. Doug was Bill Clinton's, he's an attorney, and he was like his right-hand guy, really, as far MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page307 of 883 Confidential Page 153 DAVID RODGERS as doing anything. Q. Okay. And you also flew back with Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen and Naomi Campbell? A. Yes. Q. How did it happen that Naomi Campbell joined the plane to come home? Fis I don't know. The same way she joined it before I guess in Montreal. I don't know how she was there. And one male, too. It looks like. Q. ALL Paght . The next page is page 56, flight 96. As Okay. Q. Sorry. Let's back up to 94. When the Boeing takes off from JFK, do you know sometime during that trip that you are going to be picking up President Clinton? Ais I think so. Let me see. We went to Paris. Yes, oh, yes. We knew that was going to be a long trip. Q. Okay. Pos So we knew at that point in time. I'm almost certain that we knew. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page308 of 883 Confidential Page 154 DAVID RODGERS Q. What did you know about that trip? Pus We knew that was going to be a long trip because we were going to go around the world. So when we departed, it was a about a week later, as I recall, that we picked up Clinton. We left JFK on the 1lith, a little less than a week. Half a week later, we picked up Clinton and from there, we went to -- Hong Kong. Q. So you fly in to -- on the 20th, flight 99, Jeffrey Epstein, Ghislaine Maxwell, and Sarah Kellen. Bos Right. Q. You fly in to a Naval air base in Japan? A. COTVreCT. Ox How were you given access to stay in the Naval air base? MR. PAGLIUCA: Object to foundation. THE WITNESS: The airplane, you mean? BY MR. EDWARDS: Q. Yes. It looks like it is there two days. That is why -As I guess because we were picking up President Clinton. Q. And do you know where Jeffrey Epstein, MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page309 of 883 Confidential Page 155 DAVID RODGERS Ghislaine Maxwell and Sarah Kellen stayed? Bz I do not. Q. Was there a room for them on the Naval air base? Pox No, I don't think -- nobody stayed at the Naval air base. Q. ALL Paght.s And then on the 22nd, you leave the Naval air base with -- who is that on that filaont 2 A. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, President Bill Clinton, Mike, Doug Band, Janis and Jessica. Q. You flew into the Naval air base with Jeffrey Epstein? Pow Plus six other passengers. Q. Okay. Are those secret service? Ris Most likely. O%. You flew in to the Naval air base with Jeffrey Epstein, Ghislaine Maxwell and Sarah Kellen only, right? Bice Right. Q. And nobody stayed on the Naval air base? A. No. Q. And you are there to pick up Bill Clinton? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page310 of 883 Confidential Page 156 DAVID RODGERS A. Yes. Q. And you pick up Bill Clinton and six passengers plus Mike? A. COLTTeCct. Q. Doug Band, who you have already explained who that is with relation to Bill Clinton, and Janis and Jessica. A. Yes. Q. Do you know who they are? A. Yes. Q. Who are Janis and Jessica? Bs Secret Service. Q. How do you remember that? Piss Well, there is probably 8, 8 or 9 Secret Service people there, two of them were women. The other 7 -- and it was just easier to remember the two women's names than the 7 other guys' names. Or This entry on January 22nd, 2002, Jessica, is that the same or a different Jessica from -Bi On which one? Q. Sure. Sorry. May 22nd. I think I butchered the date before. Pe Right. Q. May 22nd, 2002. Is that the same Jessica MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page311 of 883 Confidential Page 15/7 DAVID RODGERS as January 15th, 2002, flying with Jeffrey Epstein? A. January 15th. MR. REINHART: Flight 48. BY MR. EDWARDS: QO. A. Right. It is flight 48. IT'm don't think -- no, I they wouldn't be the same Jessica, no. QO. Clinton, A. Q. A. Q. Okay. After you pick up President Bill where did you fly? We went to Hong Kong. Do you know what the purpose was? I believe he was giving a speech. All right. And then from there, where did That would be Shenzhen, Japan -- or China. Okay. And do you remember the purpose Speech. And then where did you fly? Singapore. Again, another speech? Another speech. During the course of these days, where did President Bill Clinton sleep? MAGNA®

10 iL 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page312 of 883 Confidential Page 158 DAVID RODGERS Poa I guess at a hotel somewhere. I'm not sure. Q. Did he stay at the same place as Jeffrey Epstein, Ghislaine Maxwell and Sarah Kellen? MR. PAGLIUCA: Foundation. THE WITNESS: I don't know. BY MR. EDWARDS: Q. All right. Were meals served on the plane? A. Something was served, but I don't know if you would call it a meal. Probably. I'm sure we had catering and stuff. I just don't recall. Q. That was just typical back then to have meals, especially for the President, right? A. Normally we do not. And we probably did have catering back then, but I don't recall. O« Okay. Where did you fly from Singapore? Fix Singapore, VTBD, I don't know. You have your cheat sheet over there? O« VTBD, mine says Thailand. Aix I was going to guess Thailand. Then from Thailand, I think we went to -O« My cheat sheet says Brunei? Fis Exactly. You don't want to go there. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page313 of 883 Confidential Page 159 DAVID RODGERS Q. You don't? A. No. Q. Okay. Was the purpose a speech at each location to the best of your knowledge? Pox To the best of my knowledge, it was. Q. All TFughe. Do you know why it was that Jeffrey Epstein and Ghislaine Maxwell and Sarah Kellen accompanied him? A. No. Q. And then did you leave? MR. REINHART: Did you answer that question? THE REPORTER: He said no. MR. REINHART: IT didn't hear it. BY MR. EDWARDS: Q. Did you leave President Bill Clinton and Doug Band and the Secret Service in Brunei? Bis Hmm. It is possible. What is WRR? Q. Not found. Sorry. Avs Not good. Q. That is the only entry in here that is not found. But the next one, VCBI says Sri Lanka? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page314 of 883 Confidential Page 160 DAVID RODGERS A. Okay. Then if that says Sri Lanka, then, yes, we probably did leave Clinton in Brunei, I think. And I think we went from there down to Bali. We went to Bali without -Q. Without Bill Clinton? A. Yes. Q. What was the purpose of the trip to Bali? A. Just to get away. Q And then to Sri Lanka? as Sri Lanka was just a fuel stop on the way to Paris. Two fuel stops. Q. That's in Dubai? A. Yes. Q. And then you get to Paris? A. Correct. QO. And then you fly back to London? A. Yess Yes. O's All right. Do you remember the purpose of the trip to London? A. Yes. Q. What was that? Aas We had to have our APU changed on the airplane. It quit working in Paris. And we landed there. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page315 of 883 Confidential Page 161 DAVID RODGERS Q. Aik: Daeg ihes The next page, page 57, June 21st. Flight 1570. Where is that flight leaving from? Bis Palm Beach to the Bahamas. Q. And who is on the flight from Palm Beach to the Bahamas? Da Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Cindy Lopez, Jean-Luc Brunel, Virginia Roberts. Q. AAA Bight. And that is on June 21st? A. Yes. Q. All right. And then there is a couple of entries that say "reposition. Pics Right. Q. That is flying back to Palm Beach and then back down to the Bahamas? Pi Correct . Yeah, we left them there. And we flew the airplane home. Q. And then did you leave out of the Bahamas on the 23rd. A. Yes. Q. Up to Teterboro. And who are your passengers on flight 1573? MAGNA®

10 iL 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page316 of 883 Confidential Page 162 DAVID RODGERS Pos Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Cindy Lopez, Juliana Borres, I guess, Jean-Luc Brunel, Melissa Stahl. Q. A Virginia Roberts was taken to the Bahamas. Do you know where she went from there? Ps I do not. Q. Do you remember a Frederic Fekkai? Rw What is the name again? QO. Fekkai, F-E-K-K-A-I. Frederic Fekkai? A. First name? QO. Fred. A. Fred. QO. Hairdresser? A. The last name sounds familiar. Q. All right. He's on a flight No. 116 on the Boeing. Rx Uh-huh. Q. June 27th? Bx Okay. I see. Ox And there are -- it looks like a bunch of passengers. Do you remember Daralyn Priest? Fix No. Where is she? Ox Middle column. Aix Daralyn. Oh, yes, I see her. Right. aL MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page317 of 883 Confidential Page 163 DAVID RODGERS don't remember her. Q. Do you remember that flight? A. To Paris. Not really. It was a big flight. We had a lot of people on it, which was unusual, going to Paris. No, I don't. Or. You don't remember it. A. No. Q. So you don't remember the purpose of the £laont 2? A. No. Q. July 2002, it is page 58. Go to flight 120. As Okay. Q. LF? Ps That is Nice. Q. And where do you go? Pes Tangiers. Q. And then from Tangiers to? Ae To another place in Morocco. Marrakesh. I think it is Marrakesh. I could be wrong on that one. It is definitely Morocco. Q. From there, is that where you pick up Bill Clinton? A. Let's see. GMME would be Rabat, the MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page318 of 883 Confidential Page 164 DAVID RODGERS capital of Morocco, I believe. Q. Did you know before this flight that you at some point would be picking up Bill Clinton? A. I think we did, yes. QO. Who was on the flight with Bill Clinton? Pics Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Prince Andrew, Cindy Lopez, President Clinton, Doug Band, Mike, with Secret Service and 8 Secret Service people. So probably 9 Secret Service people. Q. So Mike is a person that is also -- that is? Bs He's Secret Service, yes. That is just what I recall. He was the lead guy of the Secret Service. Q. Where do you take Bill Clinton? Ais We went to the Azores for a fuel stop and then we went to JFK. Kennedy, New York. Q. Then on August 5th, in the Gulfstream, on flight 1586, you leave from Teterboro and go to Santa Fe; is that correct? A. Correct. on On that flight, you have Jeffrey Epstein -- sorry, Jeffrey Epstein, Sarah Kellen and MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page319 of 883 Confidential Page 165 DAVID RODGERS two females? A. Yes. Os Do you know who those two females were? A. No. QO. How long does the plane, the Gulfstream, stay in Santa Fe? A. Let's see. 1586, Gulfstream. I don't really know, because apparently, we had 1586 and the next one I see is 1589. So it flew three places, but I wasn't on that trip. Q. 1587 and 1588 are missing, right? Bs That is what I'm saying. Q. Because you are not on it? Pics I'm not on the trip. Q. And 1589? Ais Uh-huh. Q. Leaving out of Santa Fe, who are the passengers? Rs Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Cindy Lopez, Virginia Roberts, Dan Moran, Eduardo, Alfred, Margarita and Nick Simmons. Q. Do you know how Virginia Roberts got to Santa Fe? A. No. MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page320 of 883 Confidential Page 166 DAVID RODGERS Q. Is there any way to get to Santa Fe from, say, Florida -- well, strike that. MR. PAGLIUCA: Bus, train, car. BY MR. EDWARDS: Q. Did you ever know Virginia Roberts to take a train? ee Not that I'm aware. Q. Did you ever know her to take a bus? MR. REINHART: To go to New Mexico? THE WITNESS: Not that I'm aware. Maybe she has, but I don't know about it. BY MR. EDWARDS: Q. Okay. IT have a picture of her on horseback at the ranch, so who Knows. Let's see. August 17th, sorry, August 18th. Ais Okay. 0's From Teterboro to Palm Beach? Bx Right. Q. Who are your passengers? Bice Jeffrey Epstein, Virginia Roberts, one female. Q. All right. Do you remember who that female was? MAGNA®

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page321 of 883 Confidential Page 219 DAVID RODGERS CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, the undersigned authority, certify that DAVID RODGERS personally appeared before me and was duly sworn. WITNESS my hand and official seal this 8th day of June, 2016. Kelli Ann Willis, RPR, CRR Notary Public, State of Florida Commission FF928291, Expires 2-16-20 + + + + + + + + + + + + + + + + + + CERTIFICATE STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime Reporter do hereby certify that I was authorized to and did stenographically report the foregoing deposition of DAVID RODGERS; that a review of the transcript was not regquested; and that the transcript is a true record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 8th day of June, 2016. KELLI ANN WILLIS, RPR, CRR MAGNA®

EXHIBIT 16 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page323 of 883 Page l UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS SS ee xX VIRGINIA L. GIUFFRE, Plaintiff, V. GHISLAINE MAXWELL, Defendant. SS xX May 18, 2016 9:04 a.m. CONFIDENTIAL Deposition of JOHANNA SJOBERG, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page324 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 8 Q. Okay. Great. All right. Do you know a female by the name of Ghislaine Maxwell? ae Yes. QO. And when did you first meet Ms. Maxwell? A. 2001. March probably. End of February/beginning of March. QO. And how did you meet her? A. She approached me while I was on campus at Palm Beach Atlantic College. QO. And what happened when she approached you? A. She asked me if I could tell her how to find someone that would come and work at her house. She wanted to know if there was, like, a bulletin board or something that she could post, that she was looking for someone to hire. QO. And what did you discuss with her? A. I told her where she could go to -- you know, to put up a listing. And then she asked me if I knew anyone that would be interested in working for her. Q. Did she describe what that work was going to be? Pe She explained that she lived in Palm Beach and didn't want butlers because they're too stuffy. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page325 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 9 And so she just liked to hire girls to work at the house, answer phones, get drinks, do the job a butler would do. QO. And did she tell you what she would pay for that kind of a job? A. At that moment, no, but later in the day, yes. Q. And what did she say? Bes Twenty dollars an hour. QO. Was there anybody else with Ms. Maxwell when you met her? Bs There was another woman with her. I don't recall her or what she looks like or how old she was. Q. And what happened next? ae And then she asked me if I would be interested in working for her. And she told me that she was -- I could trust her and that I could jump in her car and go check out the house at that moment if I wanted. And so I said, Sure, let's do it, and went to her home with her. Q. And where was that home? Pus In Palm Beach. Q. And did she describe that home as being MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page326 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 12 magazines. She and I went -- she wanted to take me shopping to Worth Avenue, but it was a Sunday and Nieman Marcus was closed, so we went back to, like, a little book store. And I remember she bought, I think, five pairs of reading glasses because she thought Jeffrey would like them. He had them all over the house. On every table there was reading glasses. And that's about it. It was a pretty Simple day. QO. Were you paid that day for that work? A. Yes. QO. And how much were you paid? Do you remember? As I don't remember how many hours I was there -- I was there. She paid me cash. Q. So Maxwell paid you? Ay Yes. Q. And then was she the one who trained you with what -- with respect to what you were supposed to do during the day, directed you to, like you Said, go to -ae I believe she was the one that was kind of showing me around. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page327 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 13 QO. And how long did you work in that position answering phones and doing -Bis Just that one day. Q. Just that one day. And did your duties change? A. Well, the next time she called me, she asked me if I wanted to come over and make $100 an hour rubbing feet. QO. And what did you think of that offer? A. I thought it was fantastic. QO. And did you come over to the house for that purpose? A. Yes. QO. And when you came over to the house, was Maxwell present? Ay I don't recall. Q. And what happened that second time you came to the house? Be At that point, I met Emmy Taylor, and she took me up to Jeffrey's bathroom and he was present. And her and I both massaged Jeffrey. She was showing me how to massage. And then she -- he took -- he got off the table, she got on the table. She took off her clothes, got on the table, and then he was showing MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page328 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 14 me moves that he liked. And then I took my clothes off. They asked me to get on the table so I could feel it. Then they both massaged me. Q. So it was more than a foot massage at that point? A. Yeah, it was mostly, like, legs and back. Q. Was everybody in the room without clothes on? Bis When they were on the massage table, yes. Q. Did they -- when they got off the massage table to perform the massage, did they dress or did -A. Yes. Q. They dressed. And do you recall who paid you for that first day that you did the massages? A. I don't recall. Q. Do you recall whether Maxwell was at the house during that first day when you were doing the massage with Emmy and Jeffrey? MS. MENNINGER: Objection, asked and answered. BY MS. McCAWLEY: Q. You can answer. A. I don't recall. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page329 of 883 Page 15 1 QO. Who did Emmy work for? 2 A. Ghislaine. 3 Q. Did Maxwell ever refer to Emmy by any 4 particular term? 5 A. She called her her slave. 6 QO. You said your job duties changed. Did you 7 start to travel as part of your job with Jeffrey and 8 Ghislaine? 9 A. Yes. The next time they called me, they 10 asked me to go to New York. 11 Q. And did you -- do you recall when that was 12 approximately? 13 Bis That was Easter of 2001. 14 QO. And do you recall who was on the plane 15 with you for that trip? 16 MS. MENNINGER: Objection, leading, form. 17 MS. McCAWLEY: Actually, I'm going to stop 18 really quickly and I'm going to ask for the 19 next exhibit, please. 20 MS. MENNINGER: ‘This is 3? 21 MS. McCAWLEY: Yes. I'm going to mark 22 this as Exhibit 3 for purposes of the 23 deposition. 24 25 MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page330 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 27 leading. THE WITNESS: Jeffrey Epstein; Ghislaine Maxwell; AP and PK are the two women I do not recall; Virginia Roberts; and myself. BY MS. McCAWLEY: Q. Do you recall how you flew back from the location in the US Virgin Islands? Pe They put me on a commercial flight. I wanted to be home in time for Easter. Q. When you say "they," do you recall who made those arrangements for you? A. It could have been Ghislaine. Q. Did you -- do you recall performing massages while you were in the US Virgin Islands? ae Yes. QO. Who was involved in -- was there more than one? ae Yes. I massaged Ghislaine at one point. And I massaged Jeffrey, Virginia and I, both, on the beach. Q. Were you dressed during the massage that was on the beach? Ae Yes. Bikinis probably, most likely. QO. Do you recall what Virginia was wearing? ie. I believe she was wearing a bathing suit, MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page331 of 883 Page 32 1 to object and then you can still answer. No 2 one iS going to stop you from answering. I 3 just need to get the objection on the record, 4 in the same way she needs to be able to talk 5 before you. My apologies. I'm not trying to 6 cut you off, but I am supposed to get it in 7 before you answer. 8 BY MS. McCAWLEY: 9 Q. Did Jeffrey ever tell you why he received 10 sO many massages from so many different girls? 11 MS. MENNINGER: Objection, hearsay. 12 BY MS. McCAWLEY: 13 Q. You can answer. 14 A. He explained to me that, in his opinion, 15 he needed to have three orgasms a day. It was 16 biological, like eating. 17 Q. And what was your reaction to that 18 statement? 19 A. I thought it was a little crazy. 20 Q. And what did -- do you recall what -- when 21 you observed the other females giving massages, do 22 you recall what they would dress like? Did they 23 wear scrubs or did they typically wear normal 24 clothes? 25 A. Normal clothes. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page332 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 33 MS. MENNINGER: Objection, leading. BY MS. McCAWLEY: Q. Do you believe that from your observations, Maxwell and Epstein were boyfriend and girlfriend? A. Initially, yes. Q. Did Maxwell ever share with you whether it bothered her that Jeffrey had so many girls around? MS. MENNINGER: Objection, leading, hearsay. THE WITNESS: No. Actually, the opposite. BY MS. McCAWLEY: QO. What did she say? A. She let me know that she was -- she would not be able to please him as much as he needed and that is why there were other girls around. Q. Did there ever come a time -- did you ever take a photography class in school? ae Yes. Q. And did there ever come a time when Maxwell offered to buy you a camera? Ax Yes. MS. MENNINGER: Objection, leading. BY MS. McCAWLEY: Q. Did Maxwell ever offer to buy you a MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page333 of 883 Page 34 1 camera? 2 MS. MENNINGER: Objection, leading. 3 THE WITNESS: Yes. 4 BY MS. McCAWLEY: 5 Q. Was there anything you were supposed to do 6 in order to get the camera? 7 MS. MENNINGER: Objection, leading. 8 THE WITNESS: I did not know that there 9 were expectations of me to get the camera until 10 after. She had purchased the camera for me, 11 and I was over there giving Jeffrey a massage. 12 I did not know that she was in possession of 13 the camera until later. 14 She told me -- called me after I had left 15 and said, I have the camera for you, but you 16 cannot receive it yet because you came here and 17 didn't finish your job and I had to finish it 18 for you. 19 BY MS. McCAWLEY: 20 Q. And did you -- what did you understand her 21 to mean? 22 A. She was implying that I did not get 23 Jeffrey off, and so she had to do it. 24 QO. And when you say "get Jeffrey off," do you 25 mean bring him to orgasm? MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page334 of 883 Page 35 1 A. Yes. 2 Q. Did Ghislaine ever describe to you what 3 types of girls Jeffrey liked? 4 Bis Model types. 5 Q. Did Ghislaine ever talk to you about how 6 you Should act around Jeffrey? 7 As She just had a conversation with me that I 8 should always act grateful. 9 Q. Did Jeffrey ever tell you that he took a 10 girl's virginity? 11 Be He did not tell me. He told a friend of 12 mine. 13 Q. And what do you recall about that? 14 MS. MENNINGER: Objection, hearsay, 15 foundation. 16 THE WITNESS: He wanted to have a friend 17 of mine come out who was cardio-kickboxer 18 instructor. She was a physical trainer. 19 And so I brought her over to the house, 20 and he told my friend Rachel that -- he said, 21 You see that girl over there laying by the 22 pool? She was 19. And he said, I just took 23 her virginity. And my friend Rachel was 24 mortified. 25 MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page335 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 36 BY MS. McCAWLEY: Q. Based on what you knew, did Maxwell know that the type of massages Jeffrey was getting typically involved sexual acts? MS. MENNINGER: Objection, foundation, leading. THE WITNESS: Yes. BY MS. McCAWLEY: QO. What was Maxwell's main job with respect to Jeffrey? MS. MENNINGER: Objection, foundation. THE WITNESS: Well, beyond companionship, her job, as it related to me, was to find other girls that would perform massages for him and herself. BY MS. McCAWLEY: Q. Did Maxwell ever refer to the girls ina particular way? ae At one point when we were in the islands, we were all watching a movie and she called us her children. QO. Did anybody respond to that? A. I don't recall. QO. Did she ever refer to herself as a mother? A. Yes, like a mother hen. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page336 of 883 Page 64 1 QO. Do you remember anything notable about the 2 phone calls? 3 Piva I just remember I always had to say, He's 4 unavailable, can I take a message? 5 Q. And where did you take a message? 6 Bis On a little notepad next to the phone. 7 Q. Do you recall any small children calling 8 the house that day? 9 A. No. 10 Q. Were you speaking to anyone about their 11 school experience or anything like that? 12 A. No. 13 Q. Did you take any messages for famous 14 people? 15 A. They could have been famous and I would 16 have been clueless. 17 QO. Did you take messages at any other point 18 during the time that you worked with Jeffrey? 19 A. No. 20 Q. And you said you remember at the end of 21 that day being paid by Ghislaine? 22 A. Yes. 23 Q. And you were paid for doing the errands 24 and answering phones and whatever else you did? 25 A. Yes. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page337 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 82 QO. When you came upstairs, where was Virginia Sitting? Pus I don't remember. Q. Do you remember what she was wearing? A. No. oF She was already there when you got back from sightseeing? A. Yes. QO. Tell me what happened with the caricature. A Ghislaine asked me to come to a closet. She just said, Come with me. We went to a closet and grabbed the puppet, the puppet of Prince Andrew. And I knew it was Prince Andrew because I had recognized him as a person. I didn't know who he was. And so when I saw the tag that said Prince Andrew, then it clicked. I'm like, that's who it is. And we went down -- back down to the living room, and she brought it in. It was just funny because -- he thought it was funny because it was him. Q. Tell me how it came to be that there was a picture taken. MS. McCAWLEY: Objection. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page338 of 883 Page 83 1 THE WITNESS: I just remember someone 2 Suggesting a photo, and they told us to go get 3 on the couch. And so Andrew and Virginia sat 4 on the couch, and they put the puppet, the 5 puppet on her lap. 6 And so then I sat on Andrew's lap, and I 7 believe on my own volition, and they took the 8 puppet's hands and put it on Virginia's breast, 9 and so Andrew put his on mine. 10 BY MS. MENNINGER: 11 QO. And this was done in a joking manner? 12 MS. McCAWLEY: Objection. 13 THE WITNESS: Yes. 14 BY MS. MENNINGER: i Q. Do you recall a photo being taken of that 16 event? 17 A. Yes. 18 Q. You've never seen the photo? 19 A. No. 20 Q. You don't know whose camera it was? 21 A. No. 22 Q. Virginia was sitting on the couch next to 23 Andrew, not ina big leather armchair? 24 Fis Maybe. I'm just trying to remember how I 25 remember it. MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page339 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 142 exposed her bra, and she grabbed it and pulled it down. Q. Anything else? A. That was the conversation that he had told her that he had taken this girl's virginity, the girl by the pool. Q. Okay. Did Maxwell ever say to you that it takes the pressure off of her to have other girls around? A. She implied that, yes. QO. In what way? As Sexually. Q. And earlier Laura asked you, I believe, if Maxwell ever asked you to perform any sexual acts, and I believe your testimony was no, but then you also previously stated that during the camera incident that Maxwell had talked to you about not finishing the job. Did you understand "not finishing the job" meaning bringing Jeffrey to orgasm? MS. MENNINGER: Objection, leading, form. BY MS. McCAWLEY: Q. I'm sorry, Johanna, let me correct that question. What did you understand Maxwell to mean MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page340 of 883 10 11 12 13 14 i> 16 17 18 19 20 21 22 23 24 25 Page 143 when she said you hadn't finished the job, with respect to the camera? MS. MENNINGER: Objection, leading, form. THE WITNESS: She implied that I had not brought him to orgasm. BY MS. McCAWLEY: Q. So is it fair to say that Maxwell expected you to perform sexual acts when you were massaging Jeffrey? MS. MENNINGER: Objection, leading, form, foundation. THE WITNESS: I can answer? Yes, I took that conversation to mean that is what was expected of me. BY MS. McCAWLEY: QO. And then you mentioned, I believe, when you were testifying earlier that Jeffrey told you a story about sex on the plane. What was that about? MS. MENNINGER: Objection, hearsay. THE WITNESS: He told me one time Emmy was sleeping on the plane, and they were getting ready to land. And he went and woke her up, and she thought that meant he wanted a blow job, so she started to unzip his pants, and he said, No, no, no, you just have to be awake for MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page341 of 883 Page 150 1 A. No. 2 Q. Was it in the context of anything? 3 A. About the camera that she had bought for 4 me. 5 Q. What did she say in relationship to the 6 camera that she bought for you and taking 7 photographs of you? 8 Pe Just that Jeffrey would like to have some 9 photos of me, and she asked me to take photos of 10 myself. 11 QO. What did you say? 12 A. I don't remember saying no, but I never 13 ended up following through. I think I tried once. 14 QO. This was the pre-selfie era, correct? 15 Pius Exactly. 16 Q. I want to go back to this: You testified 17 to two things just now with Sigrid that you said 18 were implied to you. 19 Be Okay. 20 Q. The first one was it would take pressure 21 off of Maxwell to have more girls around? 22 As Right. 23 Q. What exactly did Maxwell say to you that 24 led you to believe that was her implication? 25 A. She said she doesn't have the time or MAGNA®

Case 18-2868, Document 283, 08/09/2019, 2628241, Page342 of 883 Page 160 1 2 CERTIFICATE 3 STATE OF FLORIDA ) : ss 4 COUNTY OF MIAMI-DADE ) 5 I, KELLI ANN WILLIS, a Registered 6 Professional, Certified Realtime Reporter and 7 Notary Public within and for The State of 8 Florida, do hereby certify: 9 That JOHANNA SJOBERG, the witness whose 10 deposition is hereinbefore set forth was duly 11 sworn by me and that such Deposition is a true 12 record of the testimony given by the witness. 13 I further certify that I am not related 14 to any of the parties to this action by blood i or marriage, and that I am in no way interested 16 in the outcome of this matter. 17 IN WITNESS WHEREOF, I have hereunto set 18 my hand this 18th day of May, 2016. 19 20 KELLI ANN WILLIS, RPR, CRR 21 22 23 24 25 MAGNA®

EXHIBIT 17 (Filed Under Seal)

}4 NO GO HS Ol OV ~l CO WO 10 a eZ Ales, 14 iS 16 ey 18 Lg Zz) Zadk Ze Zo 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page344 of 883 UNITED: SIATEo DISTRICT COURT for the Southern District of New York Civil Action No. 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, Vex GHISLAINE MAXWELL, Defendant. VIEDEO=DEPOSLTION OF: TAKEN BY: REPORTED: Bx DATE: 2vN iD TLE PLACE APPEARANCES: ALSO PRESENT: DKyY RObDEETS Defendant Karla Layfield, RMR Stenographic Court Reporter Notary Pub Lac State of Florida at Large May 205. 206? 6235: 2:1. Millhorn Law Firm LiZoo Noruh Us: Hrghiwey. 3071 OxTord, Plorida Laura A. Menninger, Esquire HADDON, MORGAN & FOREMAN, PC 150 East 10th Avenue Denver, COLOreado 20203 Attorney for Defendant Brad Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, FISTOS & LEHRMAN, PL 425 Andrews Avenue, Suite 2 Port: beuderdale, Phorida 33301 ALeOrney Lor Plaancla. Kenneth Sarcony, Videographer Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

}4 NO OJ HS Ol OY ~ CO WO 10 I. i AS 14 i 16 ey ike ig Z0 Zod Ze aS 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page345 of 883 72 Q Do you remember there being a job posting that you felt like was appropriate for Virginia or did you just go out and talk to the woman who ran the spa area on your own? A I just talked to Angela. Q Okay. Do you recall whether this was intended to be a full-time job? A I don't remember if it was full time or just summer jobs or, you know, during season. It was probably for a season because Mar-a-Lago 1s seasonal. I mean, I was there year round but a lot of people are seasonal, you know, because it's like snowbirds, you know, summertime comes and nobody wants to be down in south Florida. QO What would you call the season, the seasonal aspect of Mar-a-Lago? What's the season? A Probably from September or October to, you know, maybe May, I guess. O Is that the coolest time? A Times of the year, yes. Q And it's more guests that come during that period of time? A VCS. Q And is there more staff brought on during that period of time? Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

}4 NO OJ HS O1 OY ~ CO WO 10 ie EY 9 14 i 16 ey 18 ig Z0 Zod Le aes 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page346 of 883 74 we'll call her Angela. A We've got to call her something, but, you know, I didn't really Know what her job title was, but I was glad that they would give her a job. O Ragin. A You know, and that, you know, I was hoping she would be happy; that way she could, you know, go back and forth to work with me. She didn't have to drive or NOt Mino: Q Did you drive to and from work with her? A Yes. Pretty sure I did, yeah. QO Do you remember her hours being relatively the same aS yours? A I'm pretty sure they were. Yes. Q Do you recall her being in school at the same time? A No, I don't recall. I don't remember if she was iim. School. Or WoL: O Is it possible it was over, say, winter break oe. == A I don't remember. I'm sorry. This is so long ago. I mean, some things stick in my mind but some things I just don't remember. Q Do you remember whether Virginia wore a uniform? A Yes, I think she did. Yeah. I think everybody Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

}4 NO GJ HS Ol OY ~ CO WO 10 I. i AS 14 i 16 ey ike ig Z0 Zod Ze aS 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page347 of 883 8 Q Q So you don't know if it was a couple days or a couple weeks or a couple months or a couple years? ANVEhANG 2 thar == A Well, it wasn't a couple years. It might have been two weeks to two months. I don't know. It wasn't a whole long time, you know. QO Where were you when Virginia told you she might be going to try to get this other job? A Probably at work. She might have told me, like, at lunch or whatever. I don't remember. That was so many years ago. I just remember she said Ms. Maxwell was going to, you know, get her a job with Jeffrey Epstein and learn massage therapy. And I thought, well, that's great, you know, because learning new jobs is all about life, you know. You've got to learn each -- you Know, I've learned a lot of different things over my lifetime so it's good to learn every new job you can because that can help you later in life and that's what I think I told her. QO Okay. So the best you can recall today is you had a conversation with her sometime at lunch perhaps at Mar-a-Lago where she told you she was going to try to get another job? A Yes... And -- Lhought thal was a. good. Thing. QO Do you know now that you recall that, what Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

}4 NO OJ HS Ol OY ~ CO WO 10 I. i AS 14 i 16 ey 18 ig Z0 Zod Le aes 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page348 of 883 84 A NOs QO Did she ever call you from that home? A Not that I know of. Q Was this when she was still living at home with you on Rackley Road? A 12Ss Eo. QO Not Rackley Drive. A Rackley Road. QO Do you know whether Michael was living with you at Rackley Road at the time or not? A I don't think so. I don't remember. I didn't care for Michael. Of course, what parent cares for your daughter's boyfriend. Q Why didn't you care for Michael? A I didn't think anybody was good enough for my daughter but that's just me. QO I suspect you're right about all fathers. Do you remember her telling you anything about what her job with Mr. Epstein was going to be or was? A She said it was going to be massage therapy. Q Okay. Did she tell you she was getting some tiem tig: A VES: Q Did she tell you about the training? A No. She just said she was being trained in Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OO HS Ol OY ~ CO WO 10 ie EY 9 14 i 16 ey 18 ig Z0 Zadk Ze Zo 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page349 of 883 oo massage therapy. Q All right. When she came home at night from working with Mr. Epstein, did she look distressed to you in any way? A Not that I remember. Q Okay. Did she report any complaints about her job with Mr. Epstein? A Not to me. QO Okay. Did she report them to anyone else who then reported them to you? A NOx QO Your wife, for example? A I have no idea. Like I said, if she did tell my wife, I never heard about it. QO Okay. Have you ever met Ms. Maxwell? A Not that I remember ever meeting her. Q Do you know what she looks like? A No. Q Did you ever meet anyone else who worked with Mr. Epstein? A No. QO Do you remember anyone else who worked for Mr. Epstein bringing your daughter home, for example? A NO« Q Did your daughter ever move into the home where Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

}4 NO OO HS Ol OY ~ CO WO 10 dea. i AS 14 i 16 ey ike ig Z0 Zod Ze aS 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page350 of 883 134 Q Okay. But your hours, if I understood you right, were approximately 7:00 a.m. to 3:00 p.m.? A Less QO And Tuesday through Saturday? A Yeon © Those hours would be the same time as somebody her age would have been in high school? A Les: Q Okay. So does that -- does that give an indication to you that the short period of time she was working was during the summer when there was not school? A It seems to be that way. QO Okay. A I mean, to me, yeah. QO It could have been a summer job? A Yes, it could have been. QO Okay. You would not have, as a father, had her working somewhere instead of going to school? A Noy. 1 weoulan’ v. Q And the day that Virginia came and spoke to you about meeting someone named Ms. Maxwell who was offering her another job, do you remember the conversation that you had with Virginia on that day? A No, not really. I just remember Virginia saying that, you know, she met Ms. Maxwell at the spa and that Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

}4 NO OO HS O1 OY ~ CO WO 10 I. i AS 14 i 16 ey ike ig Z0 Zod Le Zo 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page351 of 883 130 Q And there it describes her job at Mar-a-Lago as lasting from August 2000 to September of 2001. Do you see that? A Mes .s QO Does that refresh your memory about how long she was working there? MR. EDWARDS: Form. THE WEENE SS? ohe- didnt work Tiel Lond. MS. MENNINGER: Okay. THE WITNESS: Like I say, it was more, like, a couple of weeks. It wasn't -BY MS. MENNINGER: Q Well, earlier you testified it, might have been a couple of months? A Well, you know, for me, two weeks, two months, I mean, I don't even remember how long I worked at Mar-a-Lago. I told you I worked there six years and according to them, it was, like, three years. Seemed like S1xX. Q Well, earlier you testified that Mar-a-Lago was more of a seasonal place, correct? A Yes, well, it 1S seasonal. But I mean, they could be open up the spa area during the summer too because I'm sure a lot of people in Palm Beach come to get massages and things like that. I mean, you know, the only Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

4 NO OJ HS Ol OY ~ CO WO 10 Ie. i AKG 14 i” 16 ey ike ig Z0 Zod Ze 20 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page352 of 883 ioe part they close off is where the chefs and all that, where they didn't do any more big events and stuff. QO Okay. A But I think the kitchen was still open. I mean, they had a dining room. Q So if she didn't work there that long August 2000 -- even though August is in the summer -- it would not be unusual in your mind? A No. Q Okay. So she could have started working in August of 2000, correct? A She could have, yeah. Q And while you don't think she worked all the way until September of 2001 -A No. Q -- that would be consistent with your recollection of it being more seasonal in the fall, september -MR. EDWARDS: Object to the form. THE WITNE Sos Yes. BY MS. MENNINGER: QO So if she worked in the fall, September, October, something like that, that seems likes that accords with your memory, correct? MR. EDWARDS: Object to the form. Owen & Associates Court Reporters P«O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

}4 NO OO HS Ol OY ~ CO WO 10 ial i AS 14 i 16 ey ice ig Z0 Zadk Ze Zo 24 La Case 18-2868, Document 283, 08/09/2019, 2628241, Page353 of 883 143 CHART tric aA tT & STATE OF FLORIDA COUNTY OF MARION I, Karla Layfield, RMR, Stenographic Court Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing deposition of Sky Roberts; that said witness was duly sworn to testify truthfully; and that the foregoing pages, numbered 1 through 142, inclusive, constitute a true and correct record of the testimony given by said witness to the best OF My abibacy.. I FURTHER CERTIFY that I am not a relative or employee or attorney or counsel of any of the parties hereto, nor a relative or employee of such attorney or counsel, nor am I financially interested in the action. WITNESS MY HAND this day Of May, 2016, at Ocala, Marion, County, Florida. Karla Layfield, RMR Stenographic Court Reporter Owen & Associates Court Reporters P.O. Box 157, Ocala, Florida 352.624.2258 * owenassocs@aol.com

EXHIBIT 18 (Filed Under Seal)

10 La Ie fs 14 3 16 Lt 18 Lo 20 Case 18-2868, Document 283, 08/09/2019, 2628241, Page355 of 883 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08-CV-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, -“VsPlaintiff, JEFFREY EPS TEEN, Defendant. Page 1} Related cases: 08-80232, 08-80380, 98-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JUAN ALESSI VOLUME I Tuesday, September 8, 2009 10:12 a.m. - 3:45 p.m. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33401 Reported By: Sandra W. Townsend, FPR Notary Public, State of Florida PROSE COURT REPORTING AGENCY West Palm Beach Office APPEARANCES: On behalf of the Plaintiffs: RICHARD WILLITS, ESQUIRE RICHARD H. WILLITS, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 Phone: 561.582.7600 reelrhw@hotmail.com STUART MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 Phone: 305.931.2200 ssm@sexabuseattorney.com ahorowitz@sexabuseattorney.com WILLIAM J. BERGER, ESQUIRE ROTHSTEIN ROSENFELDT ADLER 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 33301 Phone: 954.522.3456 bedwards@rra-law.com KATHERINE W. EZELL, ESQUIRE PODHURST ORSECK, P.A. 25 West Flagler Street, Suite 800 Miami, Florida 33130 Phone: 305.358.2800 rjosefsberg@podhurst.com kezell@podhurst.com ADAM J. LANGINO, ESQUIRE LEOPOLD KUVIN 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 Phone: 561.515.1400 skuvin@leopoldkuvin.com kA Wo ow dS Oo j11 jis 14 15 6 117 ji8 19 20 2k 122 123 24 25 On behalf of the Defendant: ROBERT J. CRITTON, ESQUIRE BURMAN, CRITTON & LUTTIER 315 North Flagler Drive, Suite 400 West Palm Beach, Florida 33401 Phone: 561.842.2820 rerit@bclclaw.com mpike@bclclaw.com Page 2 | mm G NW ow oa Oo 11 j13 14 ji5 16 jl 7 18 ji 9 I20 21 Page 4 EXHIBITS NUMBER Exhibit number | Exhibit number 2 Exhibit number 3 Exhibit number 4 Exhibit number 5 DESCRIPTION PAGE Photographs 45 Transcript 130 Incident Report 137 Incorporation Papers 149 Incorporation Papers 150 Electronically signed by Sandra Townsend (401-377-676-2895) Electronicaliv sianed by Sandra Townsend (401-377-676-2895) (561) 832-7500 1 (Pages 1 to 4) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 76ef564a-daitc-ddee-8J7ac-479898cc

Case 18-2868, Document 283, 08/09/2019, 2628241, Page356 of 883 Page 47) nana 1 MS. EZELL: I'm going to ask -- I don't know a THE WITNESS: Could have been. But, you know z whether you've still been serially designating ; 2 I am not -- I don't think I am a very good judge of 3 Exhibits or whether we're doing them separately for} 3 ages. If you ask me how old you are, I really A deposition. | 4 couldn't tell you. 5 MR. CRITTON: I think we cannot trust that 5 MR. CRITTON: Kathy thinks she's 25. 6 people will do them serially. I'd do them with 6 MS. EZELL: In my dreams. ' each one. q THE WITNESS: Now, again, | must tell you, I 8 MS. EZELL: Then would you mark this, please,| 8 was never told to check any i.d.s on any of the 9 as Exhibit 1 to this deposition. |} 9 people who work at the house. 10 And I'm just going to state on the record that 10 BY MS. EZELL: Le I will keep that original. We will not attach it Ti Q. Iunderstand that. And, so, I think I'm just i2 to the deposition. L2 trying to establish that you didn't consider it part of a2 (Exhibit number | was marked for |} 13 your job description to worry about or consider the 14 identification purposes and retained by Counsel for the} 14 ages -a5 Plaintiffs.) |} 15 A. No. 16 THE WITNESS: Yes, that’s -- 16 Q. -- of the young women that came there? i] BY MS. EZELL: 17 A. Absolutely not. Absolutely not. 18 Q. Can you identify that -- the young woman in 18 Q. And, so, you never really focused on that or 12 those pictures? 19 particularly thought about it if they seemed young? 20 A. Yes. 20 MR. CRITTON: Form. 21 Q. Who is it? 27 THE WITNESS: I don't -- I didn't see that 22 A. That's V. -- V. Now that you says R., that 22 many young girls, you know, young, underage girls 23 is V.R. definite, a hundred percent. | 23 at the house. I never saw except the two girls 24 MR. CRITTON: Let me just note my objection, | 24 that I mentioned that I think it was underage was 25 as I did in A. Rod's deposition or Mr. Rodriguez's : N. for sure because she was still in high school. Page 46 : Page 48 And she -- she had dinner with her mother, a couple times with her mother. And she become an actress. She's an actress and she has done movies. And he help her in her career. That's the only girl that I knew she was young because she was going to high school and | pick her up from high school sometimes. But she was not a massage therapist. She will go for dinner. And they will go for the movies and she sang sometimes because she was a singer. So she sung at the house. Beautiful girl. Very talented. That's the only girl that I know that it was -- I would says, underage. BY MS. EZELL: Q. Okay. Did -- who told you that V.R. was a massage therapist? A. Nobody. Q. Did you assume that she was a massage therapist because you were told she was coming to give massage? A. No. I assumed she was a massage therapy deposition, that I know you're going to confiscate Exhibit number 1. I think it's inappropriate. I think I should be allowed to have a copy of Exhibits that are being used in deposition. But I'll file a motion with the Court so we don't get into a pulling match over your Exhibits. MR. BERGER: I would ask that the court reporter initial that. MS. EZELL: Sure. Oh, you did? MR. WILLITS: She marked it. MR. BERGER: Did she put her initials or did she just put a number or a letter? MR. CRITTON: She's nodding that she did everything that she usually does, which means, initials, date and number. MR. MERMELSTEIN: You can talk. MR. WILLITS: But when you talk, use your initials. BY MS. EZELL: : Q. How old did you think V.R. was at the time she began coming to Mr. Epstein's home? because I was -- I drove Ms. Maxwell to Mar-a-lago, A. She could have been 17, 18, 19. | Donald Trump's residence. And I wait in the car while Q. Could she have also been 15? | Ms. Maxwell got a -- I think it was a facial or massage. MR. CRITTON: F is girl, V Oo OrATIn Oe WD FE oO Onn OP WN KE eee CO pail oe) en ee ee oe oo oO OID OB WD EF NNN FB BE BE eB Be NF OW OANA OO BWDNE NO GO 12 (Pages 45 to 48) (SOL) 834-7500 PROSE COURT REPORTING AGENCY, INC. (S61) G@2az—- 7306 Electronically signed by Sandra Townsend (401-377-676-2895) Electronicaliv signed by Sandra Townsend (401-377-676-2895) 76ef564a-daitc-ddee-8J7ac-479898cc'

oO oOoOn~7n oe WN EF MS WM he Ne wee Pe FF PEF ee ee CT EB OSs eS ee we OF Be & NS FE © oO Own DW oO SP WN FF MBM NM NM DM NM FP FP FP rR RP FP rR Fr FEF FEF OP WwW NY rF Ow OH D OO SFP WH FF © (eG ) Case 18-2868, Document 283, 08/09/2019, 2628241, Page357 of 883 Page 49 | walking down from the main lobby towards the spa of | Mar-a-lago. And I was driving Ms. Maxwell up, up the | ramp. It's a little ramp there. : And Ms. Maxwell says, stop. And she went and | talked to -- she went inside. | And that afternoon around 5:00 [saw V.came. | She came to the house already, so she was there already. That was the first day I knew. And then she would com¢ regularly. Q. Did you ever meet any of V.'s family? A. No. I think she was -- one time I think her father drove her there. And I met -- I don't know if it was the boyfriend or husband or -- but he had to wait, make him wait outside while she was at the house. Q. Do you know the name or recognize the name Tony Santiago? A. I think it was him. Q. That was her -A. I know he had an old beat-up car, Camaro or Mustang. I know it was very old car that] makehim | wait on the street one time. I make him come out of the | driveway because we have to move some cars around. | Q. Did there ever come a time when Tony Santiago | was welcome in the kitchen? A. Ithink he came once in the kitchen, but ow OF FP WN F Page 50 | Ms. Maxwell told me to get him out. Q. Did she tell you why? A. No. She didn't -- I guess she didn't want to become, you know, everybody -- because some of these people came with their husbands and they wait outside. And I guess she didn't want this to become a norm for everybody to bring their companions while they have -they will do a massage for her. Q. During the time you were there, did you ever know of Tony Santiago bringing any other girls to Mr. Epstein? A. No. [knew that sometimes I saw V. bring other girls with her, not Tony Santiago. Q. Do you remember the names of any of those girls -A. No, I don't. Q. -- that V. brought? A. That was at the end of my stay there. No. That was a very -- at the very end of the last month of my stay. Q. Did you give -- | don't believe I asked you, but if 1 did, forgive me. Did you give us an approximate year in which you were taking Ms. Maxwell tg Mar-a-lago and saw V.R. for the first time? | A. That was at the at the end of my stay 632-7900 Electronically signed by Sandra Townsend (401-377-676-2895) Electronicaliv signed by Sandra Townsend (401-377-676-2895) PROSE COURT REPORTING AGENCY, Page S1Lf there. So I would says, between three months maybe before I left. And I think I left at the end of the year, so it could have been -- I remember it was a very hard day because I had to wait in the sun outside in a convertible and I was dying, waiting for an hour for Ms. Maxwell. I think it was in the summer of 2002. Q. Andif 1] remember correctly, you left in November or December of 2002? A. Yes. Q. So that might have been perhaps July or August of 2002? A. Uh-huh. Q. And, so, as I understand it, you only saw V.R. come to that house during the last three months of your time at Mr. Epstein's? A. Yes. Q. Do you have any -- any sense or can you approximate how many times she came? A. I cannot give you a number, but I would says, two, three times a week. Q. You mentioned that sometimes you would have to call these massage therapists in the middle of the night. Did you ever have to call V. for Mr. Epstein in the middle of the night? MR. CRITTON: Form. Page 52 THE WITNESS: No. No. BY MS. EZELL: Q. Did there come a time while you were there that V.R. stayed in the house? MR. CRITTON: Form. THE WITNESS: I don't think so. I cannot remember. No. BY MS. EZELL: Q. How many bedrooms were there upstairs? A. One, two, three -- one, two, three, four -four -- so that would be five, five bedrooms. Q. Five. And, so, would one have been Mr. Epstein's bedroom? A. Yes. His quarters was big, huge quarters. Q. Sort of a suite? A. Yeah. And he has -- this is the room. His bathroom was here and her bathroom was here. The mai room was here. And we have -- it was two sets of doors before -- two sets of double doors before you can go into the suite. There was one on top of the stairway and one in the middle of the hallway. And then you walk into the -- into the suite. Q. Okay. And you -- you just put a red eight by 11 folder in front of you? A. Yeah. 13 (Pages 49 to 52) Li. (961) Goz- 7506 76ef564a-daitc-ddee-8J7ac-479898cc'

Oo OnxA AD OO SP WN EF Ss NN DP NN PE Pr SE ES Ee eS Fe om OH FEF GS Dp OH etm woh FE ory naar Wh F&F (eG ) Case 18-2868, Document 283, 08/09/2019, 2628241, Page358 of 883 noe 8 A. Yes. Before she was married, yeah. They split up and she went her own way. Q. Did she marry a Glen Dubin (phonetics)? A. That's correct. And Mr. Dubin used to come to | the house, too. Q. Do you know, was Sarah Kellen ever one of the | massage therapists before she became an assistant? A. I don't know if she was a massage therapist. I don't remember setting up a massage table for her. I | think she was an assistant. And she would call -- at the end of my stay, I was -- tried to pull aside from my | obligations and Sarah was doing all the phone calls and| all the arrangement and all the looking out for these girls for the -- for massage therapists. They were constantly. Q. When did that role get transferred from you to Ms. Maxwell, the role of looking after girls and calling | the girls? A. I didn't look after -- out for girls. Ms. Maxwell was the one that recruit -- I remember one occasion or two occasions she would says to me, John, | give me a list of all the spas in Palm Beach County. And I will drive her from one to the other one to PGA | and Boca. And she will go in, drop credit cards -- not | credit cards, but business cards, and she come out. And Page 58 | then we go to -- she will recruit the girls. Was never -- never done by me or Mr. Epstein or anybody else, that I know. I don't know about Sarah because Sarah was there at the last, last -- probably last weeks of my stay there. So I cannot say anything about Sarah. Q. Was there any point in time -- well, let me ask you this way: Did -- you said sometimes you woul d call the girls to come -A. Uh-huh. Q. -- to give them massage. And sometimes Ms. Maxwell would? A. Yeah. Q. Did there come a time when she took that over : entirely from you -. No. . -- or that continued -. That's continued. . -- until you left? . Yeah. . Do you remember, is Jeffrey Epstein godfather | to one of the Dubin children? A. I don't know if he godfather. I don't remember that. But he was very fond to these children, | the child 632-7900 Electronically signed by Sandra Townsend (401-377-676-2895) Electronicaliv signed by Sandra Townsend (401-377-676-2895) wmoeaons! DO & WON FE NNNNNNRFP FPR FFP EE BE eB BE oO BWNEF OHM DATA OO BWNHE O moon onanorwtb Wwhnrd F&F NNNN FE EE BE Be eB WNHEF OW MOAATHD OB WNHE © PROSE COURT REPORTING AGENCY, LNC. Page S59, Q. And they called him uncle, you said? A. They called him uncle. Q. Did you ever learn what Tony Santiago did for a living? A. No. Q. Have you had any occasion to see him since the time you left Mr. Epstein's employ? A. No. Q. And you don't -- do you have any idea where he is? A. Ihave no idea. I remember an incident, one time the -- I went to pick her up at Royal Palm Beach and she was crying and I went and knock at the door an she was crying. And she says, well, -- I think it was Tony or -- because she used to live with these other guys, too. There were two guys and her or two couples. I don't know the arrangements there. But I remember that she told me the -- Tony or her boyfriend had got mad and ripped the furniture, he cut the furniture in pieces and he even broke the screens. Because I was when I went into to knock the door, the screen was all ripped up like it was cut. And she told me that he got mad at -- I don't know what happened. I never saw him in there. Q. Did she tell you he had hit her or beaten her Page 60 at all? MR. CRITTON: Is the she, V., V.R.? MS. EZELL: Yes. Thank you. BY MS. EZELL: Q. Did you ever see during the time you were there photographs of V. in the house, the Epstein house V.R. in the Epstein house? A. I don't think so. I don't think so. Q. Did you ever see photographs of V.R. in Ms. Maxwell's albums? A. No. Q. At the time you were employed by Mr. Epstein, were there any hidden cameras? A. No. Q. You do know that he installed some after you left, correct? MR. CRITTON: Correct. THE WITNESS: I don't know. BY MS, EZELL;: Q. Wasn't there a camera involved in the incident that -- the incident in which you took money from Mr. Epstein? A. Yeah. Yes. But I don't know if he install it or not. That's what he told me. Ok 15 (Pages 57 to 60) (961) Goz- 7506 76ef564a-daitc-ddee-8J7ac-479898cc'

Case 18-2868, Document 283, 08/09/2019, 2628241, Page359 of 883 Page 77 | Page 79} ni Q. What kind of costume? - CERTIFICATE OF OATH 2 A. I don't know. It was a black, shiny costume. 2 STATE OF FLORIDA 3 T never sauciton her: 3 COUNTY OF PALM BEACH 4 Q. Was it leather? ? 2 A. No. I think it was like a vinyl. But we were : ‘ f ' hj p ‘ ff . 6 I, the undersigned authority, certify that Yety TUBSY APOUL TOUCHING may OF a an _ We just... 7 JUAN ALESSI personally appeared before me and was du 7 MS. EZELL: No other questions. Thank you, 9 sworn on the 8th day of September, 2009. 8 sir. 9 g THE WITNESS: You're welcome. 10 Dated this 19th day of September, 2009. 10 MR. LANGINO: I shouldn't have more than a “ ii half hour's worth of questions, if everybody is 2 12 okay to power through. 13 MR. BERGER: I probably have a half hour to an . : " Eiagpeak” =e MR. LANGINO: Okay. Sandra W. Townsend, Court Reporter 16 MR. BERGER: Unless you cover what I cover. | 16 Notary Public - State of Florida ad MR. MERMELSTEIN: I could say the same thing, My Commission Expires: 6/26/12 18 so probably less than that. | 17 My Commission No.: DD 793913 Le MR. LANGINO: So I guess my question ts -- | is 20 MR. BERGER: I think we ought to take a break. | 12 & MR. LANGINO: That was my question. | a 22 MR. BERGER: We're going to take a break. | 55 23 Do you have any problem with that? | 23 24 THE WITNESS: No. Whatever you guys want to | 94 25 do. | 25 Page 78 | Page 80 | a CERTTIFICA LE - (Lunch recess.) 2 STATE OF FLORIDA 2 (Continued to Volume II.) 3 COUNTY OF PALM BEACH 4 3 5 I, Sandra W. Townsend, Court Reporter and a Notary Public in and for the State of Florida at Large, 5 6 do hereby certify that the aforementioned witness was by me first duly sworn to testify the whole truth; that I 6 7 was authorized to and did report said deposition in "] stenotype; and that the foregoing pages numbered 1 to 8 78, inclusive, are a true and correct transcription of 8 my shorthand notes of said deposition. 2 9 I further certify that said deposition was 10 10 taken at the time and place hereinabove set forth and 11 that the taking of said deposition was commenced and Ei. completed as hereinabove set out. 2 12 I further certify that I am not attorney or 13 counsel of any of the parties, nor am | a relative or 13 employee of any attorney or counsel of party connected LA with the action, nor am I financially interested in the 14 action. ke Ol fond or The foregoing certification of this transcript 16 does not apply to any reproduction of the same by any 16 means unless under the direct control and/or direction Li of the certifying reporter. 18 17 18 i Dated this 19th day of September, 2009. 2 Le 20 ZL oo 4 Sandra W. Townsend, Court Reporter Zid 24 Lond 20 (Pages 77 to 8Q) (SOL) 834-7500 PROSE COURT REPORTING AGENCY, INC. (S61) G@2az—- (7a06 Electronically signed by Sandra Townsend (401-377-676-2895) Electronicaliv signed by Sandra Townsend (401-377-676-2895) 76ef564a-daitc-ddee-8J7ac-479898cc'

: i 1 ee La LZ 13 14 Le 16 Lt 18 ————— 20 21 22 22 24 Za 3 eats: Case 18-2868, Document 283, 08/09/2019, 2628241, Page360 of 883 Page 212 Os -- would be the young one? : A. Yeah. Q. You stated that Ms. Maxwell was very hard on you and you got blamed for everything, and that you -you liked the job and you liked Mr. Epstein, but you didn't like working for Mrs. Maxwell? A. That's Cerrecc. 2, Can you tell me why, other than that she blamed you for everything? A. She came from a very wealthy family and she was -- just my opinion; I give my personal opinion -that she was rotten spoiled and she tried to drive the house like a palace and not a home. IT was -- I discussed it with her, many, many times we have discussions. And sometimes I even refuse to do her orders, knowing that I was going to be backed up by Mr. Epstein or do the right thing, my thinking of running the house should be. But we never had a good —aiatinaakin at all feae tie bapiaaine, T Gane think so. But I was -- have to be her driver and she will go and shop all over the malls and I will have to go behind her, pay for at and bring the bags to the car. Next day or the same day she will do shopping and buy and say, John, go to this store and get it. It was a lot of work. Tt was a lot that she created and (S61) 832-7500 PROSE COURT REPORTING AGENCY, INC. (oOl); 832-7506 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de

ree 11 LZ 13 14 Mee 16 sla 18 i: ae 20 Zeck. oll foe 24 Zo (ool) 832-7500 PROSE COURT REPORTING AGENCY, INC. Case 18-2868, Document 283, 08/09/2019, 2628241, Page361 of 883 Page 213 most of this jobs that she created. : QO. And one of those things you also had to do with her was to take her to different spas? Pos Yes . And there she would recruit young women to come and do massages? A. Because she was English. And she didn't know the area too much as well as I knew. So she -- she says, John, make a list of all the massage -- the spas in the area from Jupiter to Boca Raton. And we went to all the main spas. And then we went to the schools for massage therapists, and all the massage parlors, and massage, the small massage. So I make a list from the telephone book and we would go from one to the another one. I would wait in the car and she goes in. And sometime she took a couple minutes and walk out with cards, business cards. And that -- she aa a banat eh teetare emotes And from then, she pick up the girls and that was the end of it. I never did any recruiting and I never really saw him doing it. td You really never saw? A. Never saw Mr. Epstein recruiting anybody. MS. EZELL: All right. I have no other (S61) 832-TS06 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) 3afc3ca0-c86e-4b9f-8d01 -baZ0bcae87de

EXHIBIT 19 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page363 of 883 Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO:502008CA028051XXXXMB AB Plaintiff, JEFFREY EPSTEIN AND SARAH KELLEN, Defendants. DEPOSITION OF JANUSZ BANASTAK Tuesday, February 16, 2010 10:09 - 2:30 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1317 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. = (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004424

Case 18-2868, Document 283, 08/09/2019, 2628241, Page364 of 883 Page 8 i QO. What family was that? 2 A. It's, it was an older house in New York. I 3 worked there for seven years, no, five years before I 4 get the job in the Seagram company. So, I guess I had 2S some experience to continue. 6 Q. Do you remember the name of the family 7 that you worked with for seven years in New York? 8 A. Frank, Frank. 9 Q. His name is something Frank, F-r-a-n-k? 10 A. Yes. 11 Q. Do you remember the first name? 12 ae Fredrick. 13 Q. And were your duties as house manager for 14 Fredrick Frank similar to your duties as house 15 manager for Jeffrey Epstein? 16 A. Yes, yes. 17 QO. And when you started in 2005 when you 18 heard that there was a job position with Jeffrey 19 Epstein, did you interview for that position? 20 Bs Yes. 21 O's Who did you interview with? 22 A. First I got interviewed with Ghislaine 23 Maxwell. 24 QO. And that's G—h-i-s-l-a-i-n-e, Maxwell? 25 A. Right, right. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051 -976-2934) Electronically signed by cynthia hopkins (601-051 -976-2934) Electronically signed by cynthia hopkins (601-051 -976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004431

10 11 12 cS 14 LS 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page365 of 883 Q. A. Q. manager A. Q. A. Q. Page 9 Where did that interview take place? In New York. And it was for the position as house in the Palm Beach house, correct? Right. That's at 358 Albrillo way? Correct. Why were you interviewed in New York, if you know? A. with my in 2005 Jeffrey A. Q. Because at that time I was living in New York friends and so -Where did the interview take place in New In her house on 65th Street. Whose house, do you know? Ghislaine Maxwell. So, Ghislaine Maxwell interviewed you back at her house in New York for a position at Epstein's house in Palm Beach? Right. And what did the interview consist of? What did she ask you? A. She asked me basic questions, you know, what's my previous employer, how long I work for them and basically she was checking my resume. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004432

Case 18-2868, Document 283, 08/09/2019, 2628241, Page366 of 883 Page 14 i Q. Okay. So, I assume then that your wife 2 that you are separated from I guess at the time, she 3 didn't come down to Palm Beach? 4 A. No, no. 5 Q. And this is somebody who still lives 6 somewhere other than Florida? 7 A. Correct. 8 Q. So, you came down in February 2005 and 9 began working. What did you, what did you first 10 start doing for Jeffrey Epstein? 11 Pic First I doing? I don't remember nothing 12 Special. 13 Q. Okay. Well, were you working -- I will 14 rephrase it. Were you working only for Jeffrey 15 Epstein or were you working also for Ghislaine 16 Maxwell, the other person who interviewed you, or Ly anybody else in the house? 18 Ps I guess only for him because she was visiting 19 a few times house, but I am employed by him. 20 Q. Okay. What was your understanding at that 21 time as to the relationship between Ghislaine 22 Maxwell and Jeffrey Epstein? 23 A They were like partners in business. 24 Q. Okay. What business was that, if you 25 know? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004437

Case 18-2868, Document 283, 08/09/2019, 2628241, Page367 of 883 Page 15 il ae I don't know what kind of business but she was 2 the one who organized I would say employment with this 3 organization. So, whatever I need, if I have some kind 4 of problem, I contact her. She was the one who decided 5 what I have to answer my problems with, what I was 6 Supposed to do. 7 Q. How many times did you have problems where 8 you had to go through her? 9 Pus Well, not big problems. Just a question of 10 what certain, how to do certain things. For example, 11 what kind of flowers I have to buy, what kind of things 12 he likes, what time I supposed to serve him coffee in 13 the mornings, sort of organizing things. 14 QO. Those are things that you wouldn't ask 5 Jeffrey Epstein directly? 16 Pa No, no. He doesn't like those things to ask 7 him directly. He would like to prefer either through 18 his assistant or like I say, Ghislaine Maxwell. 19 QO. Is that still the same today? 20 Pee Yes, still the same. Unless, something happen 21 that I need to, nobody is around and I need to urgently 22 contact him, I go to him directly. 23 Q. So, for the most part if you have a 24 question or at least -- let's go back to 2005, you 25 had a question about what needed to be done in the (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004438

Case 18-2868, Document 283, 08/09/2019, 2628241, Page368 of 883 Page 54 i A. (Witness shakes head. ) 2 QO. And I'm sorry. 3 A. No. 4 Q. I understood you when you shook your head. 5 A I realize what you told me but I am sorry. 6 Q. I told you it was easy to forget. 7 Do you remember who it was that personally 8 removed the computers and equipment from the 9 property? Was it Mr. Epstein, was it a lawyer, was 10 it, do you remember? 11 A. It was Adriana. 12 Q. All right. And I am of the understanding 13 that there were several computers that were removed 14 from the house, correct? 15 MR. GOLDBERGER: Form. 16 THE WITNESS: Yes, three of them. 17 BY MR. EDWARDS: 18 QO. Three? And to your knowledge Adriana 19 removed all of them? 20 Ps She show up one day with gentleman. I don't 21 remember his name. And she told me that they are moving 22 out those computers. 23 Q. And where were the computers? Which rooms 24 were the computers in that were removed by Adriana 25 and this gentleman you're describing? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004477

Case 18-2868, Document 283, 08/09/2019, 2628241, Page369 of 883 Page 191 1 CERTIFICATE OF OATH 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 6 I, the undersigned authority, certify that 7 JANUSZ BANASIAK personally appeared before me 8 and was duly sworn on the 16th day of February, 9 2010. 10 11 Dated this 28th day of February, 2010. 1Z 13 14 15 16 Cynthia Hopkins, RPR, FPR wd 17 Notary Public - State of Florida My Commission Expires: February 25, 2011 18 My Commission No.: DD 643788 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004614

Case 18-2868, Document 283, 08/09/2019, 2628241, Page370 of 883 Page 192 1 CERTIFICATE 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 I, Cynthia Hopkins, Registered Professional Reporter, Florida Professional Reporter and Notary 6 Public in and for the State of Florida at large, do hereby certify that I was authorized to and did 7 report said deposition in stenotype; and that the foregoing pages are a true and correct transcription 8 of my shorthand notes of said deposition. 9 I further certify that said deposition was taken at the time and place hereinabove set forth 10 and that the taking of said deposition was commenced and completed as hereinabove set out. 11 I further certify that I am not attorney or 12 counsel of any of the parties, nor am Ia relative or employee of any attorney or counsel of party 13 connected with the action, nor am I financially interested in the action. 14 The foregoing certification of this transcript 15 does not apply to any reproduction of the same by any means unless under the direct control and/or 16 direction of the certifying reporter. 17 Dated this 28th day of February, 2010. 18 19 20 21 ) : iat “LS Cynthia Hopkins, RPR, FPR 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004615

EXHIBIT 20 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page3/72 of 883 Condensed Transcript IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION LM. Plaintiff, VS. CASE No. 502008CA028051XXXXMB AB JEFFREY EPSTEIN, : Defendant. Prt Od Pd Pd Pmt a Pat Pt Pn Pat Pd Pp Fp Font Ft Cat Fra Coat Ft Fat Ot Ot DEPOSITION OF LOUELLA RABUYO VOLUME I October, 20, 2009 10:10 a.m. 515 N. Flagler Drive Suite 200-P West Palm Beach, Florida 33401 Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard an Alexander Gallo Company ES ! | IRE : Palm Beach Gardens, FL 33410 www. esquiresolutions.com GIUFFRE004386

Case 18-2868, Document 283, 08/09/2019, 2628241, Page373 of 883 Louella Rabuyo - Volume I October 20, 2009 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE No.502008CA028051XXXXMB AB 1 APPEARANCES: On behalf of the Defendant: ROBERT D. CRITTON, JR., ESQUIRE Plaintiff, 4 BURMAN CRITTON LUTTIER & COLEMAN, LLP “vs- 303 Banyan Boulevard, Suite 400 5 West Palm Beach, Florida 33401 JEFFREY EPSTEIN, Phone: 561.842.2820 Defendant. 7 On behalf of Plaintiff L.M.: , 8 BRADLEY J. EDWARDS, ESQUIRE DEPOSITION eS oe RABUYO CARA L. HOLMES, ESQUIRE ao 9 ROTHSTEIN ROSENFELDT ADLER Tuesday, October, 20, 2009 401 €. Las Olas Boulevard, Suite 1650. 10:10 - 3:30 p.m. 10 Fort Lauderdale, Florida 33394 Phone: 954.522.3456 515 N. Flagler Drive, Suite 200-P West Palm Beach, Florida 33401 On behalf of the Witness: 13 BRUCE E. REINHART, ESQUIRE LAW OFFICE OF BRUCE E. REINHART Reported By: 14 250 S. Australian Avenue, Suite 1400 Ter eee Neate es ee West Palm Beach, Florida 33401 Notary Public, State of Florida 15 Phone: 561.202.6360 West Palm Beach Office Job #118991 On behalf of Defendants/Jane Does 2 - 8: 18 STUART S. MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 19 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 20 Phone: 305.931.2200 . ai On behalf of Plaintiff in related Case No. 08-80811 22 JACK HILL, ESQUIRE (Partially via speakerphone) SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY 23 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: 561.686.6300 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08-CV-801 19-CIV-MARRA/JOHNSON JANE DOE NO. 2, WITNESS: DIRECT CROSS REDIRECT RECROSS Plaintiff, 6 -VS7 JEFFREY EPSTEIN, Defendant. LOUELLA RABUYO BY MR. EDWARDS: 5 190 BY MR. MERMELSTEIN: 135 208 10 BY MR. HILL: 156 BY MR. CRITTON: 173 Related cases: 08-80232, 08-80380, 98-80381, 08-80994, 10 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 DEPOSITION OF LOUELLA RABUYO 13 VOLUME | 14 EXHIBITS Tuesday, October 20, 2009 15 10:10 - 3:30 p.m. 515 N. Flagler Drive, Suite 200-P 17 NUMBER DESCRIPTION PAGE 18 DEFENDANT'S EX. 1 COPIES, COMPOSITE PHOTOGRAPHS 103 19 DEFENDANT'S EX. 2 COMPOSITE PHONE MESSAGE BOOK 147 20 DEFENDANT'S EX. 3 COPY OF PHOTOGRAPH 162 West Palm Beach, Florida 33401 21 Reported By: Teresa Whalen, RPR, FPR 22 Notary Public, State of Florida West Palm Beach Office Job #118991 23 Phone: 800.330.6952 561.659.4155 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 an Alexander Gallo Company www.esquiresolutions.com GIUFFRE004388

Case 18-2868, Document 283, 08/09/2019, 2628241, Page374 of 883 Louella Rabuyo - Volume I | _ October 20, 2009 81 83 A When | came back to report, that's how | 1 1 Q_ So are we talking about the day the police 2 learned. 2 went to Jeffrey Epstein's house you did not go in the 3 Q_ Elaborate on that for me. What do you mean, 3 morning, but you went after lunch and the police had 4 when you came back to report that's how | learned? 4 already left? 5 A | reported in the afternoon, and then that's 5 A Oh. No. When i went there nobody was there, 6 how | learned that the police came. | 6 no policemen were around. 7 Q_ Allright. And when were you -- you're now 7 Q Who was at the house then? 8 saying you came back to report and you learned that the 8 A Janusz, and Douglas, the architect. 9 police had already come to the house, right? 9 Q_ Schoettle? 10 A Yes, sir. | 10 A Yes. La Q_ Prior to that occasion, when was the previous 11 Q_ And did you have a discussion with them? 12 time that you were at the house? 12 A No. . 13 A The day before. 13 Q How did you know the police had been to the 14 Q Okay. And the day before you left your shift 14 house? 15 __ at roughly five o'clock? 15 A Janusz told me. 16 A |cannot remember. | usually leave 5:00 or 16 Q When? 17 ~—s- 5:30. 17 A When | arrive. 18 Q_ But sometime late in the afternoon? 18 Q_ That's what | was asking you when | said did 19 A Yes. 20 Q_ And as of that time, the day before the search 21 _ warrant was issued, you had seen no police officers in 22 or around the house? 23 A No. Q_ And then the next day you reported to the job at what time? 19 you have a discussion with them, meaning Janusz and 20 Douglas. ot A Okay. Being because them -- with Janusz only. a2 Q_ What did he say? 23 A He said the police came and, what's this, took 24 away some stuff. 25 Q_ Didhesa y what they took? 84 He said pictures. Did he tell you which pictures? No, sir. Aside from pictures, what else did the police A The next day? L 2 3 4 5 _ take, as Janusz told you? 6 7 8 9 1 2 Q_ The next day. 3 A | report in the afternoon. 4 Q_ Was there a reason why you reported in the 5 afternoon? 6 7 8 2 OY Oo >} A_ He did not elaborate. Q. Allright. Prior to the police going to the house and taking pictures, do you remember seeing 3 pictures around Mr. Epstein's house? 10 A Yes. 11 Q Do you remember seeing pictures of naked or 12 nude females around Mr. Epstein's house? 13 A Not around, in his closet. 14 Qin Mr. Epstein's closet you would see -15 describe what you would see related to females in 16 __ pictures. 17 A Some have topless. 18 Q Is this a big closet? 19 A No. Not really big, it's just this big, not 20 ~=so big. 21 Q Okay. Were these pictures that could be seen 22 by -- strike that. 23 Do you know of any other pictures of females 24 that were confiscated by the police that did not come from Mr. Epstein's closet? A Ms. Maxwell called me. Q_ When did she call you? A During that day, she said Louella, you can report in the afternoon. 10 Q_ She called you early in the morning? ti A Not early. | 12 Q_ Normally you would report to the house between 13 eight and nine o'clock, right? 14 A Yés, sir. iS Q_ So in order for you not to arrive at the 16 house, she had to have called you before eight or 17 nine o'clock, right? 18 A Yes. 19 Q. Okay. So approximately what time does 20 Ms. Maxwell call you to tell you you can report to the 21 house later on that day? 22 A_ |cannot remember really the time. 23 Q_ Okay. What time did you actually report to 24 the house? A After lunch, about -- maybe after lunch. Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 E IRE . 4440 PGA Boulevard Palm Beach Gardens, FL 33410 an Alexander Gallo Company www.esquiresolutions.com GIUFFRE004408

Case 18-2868, Document 283, 08/09/2019, 2628241, Page375 of 883 Louella Rabuyo - Volume I Oo oT HN NF WD PP PH Ww Nr Oo 129 STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that LOUELLA RABUYO personally appeared before me on the 20th of October, 2009, and was duly sworn. Dated this 30th day of October, 2009. Teresa Whalen, RPR, FPR Notary Public - State of Florida. My Commission Expires: 4/25/11 My Commission No.: DD 644533 Job # 118991 | £30 CERTIFICATE STATE OF FLORIDA . COUNTY OF PALM BEACH |, Teresa Whalen, Registered Professional Reporter and Notary Public in and for the State of Florida at Large, do hereby certify that the aforementioned witness was by me first duly sworn to testify the whole truth; that | was authorized to . and did report said deposition in stenotype; and that the foregoing pages are a true and correct transcription of my shorthand notes of said deposition. | further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out. | further certify that ! am not attorney or counsel of any of the parties, nor am | a relative or employee of any attorney or counsel of party connected with the action, nor am ! financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter. Dated this 30th day of October, 2009. Teresa Whalen, RPR, FPR Job # 118991 ESQUIRE an Alexander Gallo Company October 20, 2009 Toll Free: 866.709.8777 Facsimile: 561.394.2621 ; Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com GIUFFRE004420

EXHIBIT 21 (Filed Under Seal)

THA mS Ww Nh BU ee i2 13 14 LS i 7 18 Le Case 18-2868, Document 283, 08/09/2019, 2628241, Page377 of 883 Page 1 UNITED STATES DISTRICT COURT 3 SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Case No: O8-CV-80119 Plaintiff, Vs JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, Case NO: 08-CV-80232 Pisin ioe, Vs JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, Case No: 08-CV-80380 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. oe ee JANE DOE NO. 5, Case No: 08-CV-80381 Sao 1 i Vs JEFFREY EPSTEIN, Defendant. Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000247

Case 18-2868, Document 283, 08/09/2019, 2628241, Page378 of 883 1 JANE DOE NO. 4, Case No: O8-CV-80904 VIDEQTAPED 2 Plaintiff, DEPOSITION 3 VS of 4 JEFFREY EPSTEIN, ALFREDO RODRIGUEZ 5 Defendant. taken on behalf of the Plaintiffs pursuant to a Re-Notice of Taking Deposition (Duces Tecum) oe JANE DOE NO. 7, Case No. 08-CV-80993 Plaintiff, APPEARANCES: ES wON Oi ie V5 MERMELSTEIN & HOROWITZ, P.A, b? BY: STUART MERMELSTEIN, ESQ. JEFFREY EPSTEIN, 18205 Biscayne Boulevard f 13 Suite 22718 . Defendant, Miarni, Florida 33160 > on % oa ee aaey nat 14 Attorney for Jane Doe 2, 3, 4, 5, fad 6, and 7. 13 Plaintiff, 14 Vs mee 16 ROTHSTEIN ROSENFELDT ADLER : Pp . oe 7 BY: BRAD J. EDWARDS, ESQ., and | 1? CARA HOLMES, ESQ. ees bee nent te SE Eres ae Las Olas City Centre : 18 Suite 1650 ANE SOE, “ase Mo: O8-LY@ . : meee 401 East Las Clas Boulevard Maintitt 19 Fort Lauderdale, Florida 33301 Attorney for Jane Doe and E.W. And L.M. WS PODHURST ORSECK 22 BY: KATHERINE W. EZELL 25 West Flagler Street 23 Suite 800 Miami, Florida 33130 Attorney for Jane Doe 101 and 102. JEFFREY EPSTEIN, Defendartt. 22 state 1 JANE DOE NO. TL, Case No: 08-CV-80469 2 Plaintiff, APPEARANCES: 3 Vs é 3 LEOPOLD-KUVIN 4 JEFFREY EPSTEIN, ADAM }. LANGINO, ESO. 2 Defendant. 4 2925 PGA Boulevard er eee | Suite 2700 5 Palm Beach Gardens, Florida 33410 JANE DOE NO. 101, Case No: 09-CV-80591 Attorney for 8.8. 7 RICHARD WILLITS, ESQ. 2790 10th Avenue Narth Plaintiff, ’ 8 Suite 404 5 Lake Worth, Florida 33461 g Attorney for C.M.A. JEFFREY EPSTEIN, BURMAN, CRITTON, LUTTIER & il COLEMAN, LLP Defendant. ee rn eee BY: ROBERT CRITTON, ESQ. 12 JANE DOE NO. 102, Case No: 09-CV-80656 1? cts itl Flagler Drive 13 Plaintiff uite 4 14 Vs —s 13 West Palm Beach, Florida 33401 15 JEFFREY EPSTEIN Attorney for Jeffrey Epsteirt. Defendant. Tee ALSO PRESENT: JOE LANGSAM, VIDEOGRAPHER 1031 Ives Dairy Road Suite 228 21 North Miami, Florida July 29, 2009 11:00 a.m. to 5:30 p.m. 2 (Pages 2 to 5) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000248

Case 18-2868, Document 283, 08/09/2019, 2628241, Page379 of 883 Page 8 INDEX OF EXAMINATION 1 Doe right here on the copy you gave me. I'm 2 missing which Jane Doe this is. WIT nae pees eee 3 They're all different case numbers. Do ALEREDO RODRIGUEZ 4 you want me to go through each case number? 5 MR. CRITTON: I'm going to note my (By Mr. Mermelstein) 12 6 objection. Obviously if this deposition 7 gets played -- not obviously, I'm going to a sd 8 object to the litany of each one so I don't (By Mr. Langino) 260 9 know how we can separate it out. Maybe if 10 and when at the time of trial and depending Li on how the Court determines what comes In 12 and what doesn't with regard to the a EXHIBITS ENE oe 13 consolidated aspects of this. I have no i2 1 Message pad 7? 14 great idea other than just saying Jane Doe 2 Documents 115 15 versus Epstein, et al, or something like 16 that, or Jane Doe, et al. l/ MS. EZELL: Couldn't we just say and 18 those cases which have been consolidated 19 with it for Discovery purposes? 20 MR, EDWARDS: Although there is cases 21 here that have cross noticed this from state 22 court that haven't been consolidated so that 23 may not work. You may have to read them 24 all, if it works out your way that will just get edited out, at least he will have read Page 9 |: Page ? 1 Deposition taken before MICHELLE PAYNE, Court 1 that caption, every caption. Right? Is 2 Reporter and Notary Public in and for the State of 2 there a better suggestion? 3 Florida at Large, in the above cause. a MR. CRITTON: No. There may be a better 4 --- 4 suggestion if he starts this is such and 5 THE VIDEOGRAPHER: This is the case of 5 such day, it's the deposition of Mr. 6 Jane Doe No. 2, plaintiff, versus Jeffrey 6 Rodriquez in the case such and such, and we 7 Epstein, defendant. Jane Doe No. 3, 7 can almost fill it in depending on which 8 plaintiff, versus Jeffrey Epstein, 8 tape it goes, how it fills in, at least 9 defendant. Jane Doe No. 4, plaintiff, 9 we'll have the context of the first and 10 versus Jeffrey Epstein, defendant. And Jane 10 depending on whether the Judge reads it in Li Doe No. 5, plaintiff, versus Jeffrey 1 from a consolidated or they all come 2 Epstein, defendant. Jane Doe No. 6, 1? related, I have no great idea. 13 plaintiff, versus Jeffrey Epstein, 13 MR. EDWARDS: I was thinking if he read 14 defendant. Jane Doe No. 7, plaintiff, 14 every one of them and it was the seventh in line then you just would edit if so you would only read that one. versus Jeffrey Epstein, defendant. CMA, oe versus Jeffrey Epstein, THE VIDEOGRAPHER: On page number three Jeffrey Eacteli et al, defendant. hae ae 13 Doe -- is there a shorter thing that we can there is something missing on the top here. 20 do here? It's also missing this one right 20 Do you want me to read each case number Zi here. 21 separately? 22 MR. MERMELSTEIN: Do we have a problem | 22 MR. MERMELSTEIN: I don't think it's 23 with saying Jane Doe 2 and the Epstein and 23 necessary. 24 related cases? 24 MR. EDWARDS: I don't think it's THE VIDEOGRAPHER: I'm missing this Jane necessary either. 3 (Pages 6 to 9) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000249

Case 18-2868, Document 283, 08/09/2019, 2628241, Page380 of 883 the architect, any lawyer. . bela, WNC A. Bella was the assistant comptroller. Page 26 Page 27 Page 28 | 1 with a copy. 1 A. Yes. Sometimes very short notice but, 2 Q. Were you the only one who was allowed to 2 yes, Il was. 3 answer the phone? 3 Q. So that varied? 4 A. Yes. 4 A. Yes. 5 Q. I'm sorry, what would you do -- 5 Q. Who would give you that notice? 6 A. I would leave it on the counter next to 6 A. Mrs. Maxwell or Sarah or Larry, the 7. the kitchen so when I find that piece all crumbled 7 pilot. 8 I knew that Mr. Epstein saw the message, so we 8 Q. And then you would drive to pick them up 9 communicated like that. 9 at the airport? 10 Q. Now, you mentioned Mr. Epstein would give | 10 A. Yes. 11 you instructions during the course of the day. il Q. And who traveled with him? 12 A. Through his assistant. 12 A. The three pilots and some quests. I Q. And his assistant was whom? 13 Q. What do you mean by guests? 14 A. Sarah Kellen. 14 A. He will have some friends from Harvard, 15 Q. But you didn't view her as your 15 he will have -- well, very important people that, 16 supervisor? 16 you know, friends, acquaintances from New York or 17 A. She take orders from Mrs. Maxwell but she 17 Europe because I was just told the number of 18 will tell me, Alfredo, we need to buy this, we 18 people was coming on the plane. 19 need to do this, and so and so was coming. I 19 Q. Were there people who were employed by 20 couldn't talk directly to Mr. Epstein. 20 him who came regularly? 21 Q. Okay. So any communications from Mr. 21 A. Yes. 22 Epstein always came through Ms. Kellen? 22 Q. And who would they be? 23 A. Or from the office in New York. Lesley, 25 A. Like I said, they were the pilots, Larry 24 his secretary, or somebody else, the comptroller, 24 Bisosky, George, and I don't remember the flight engineer, and he will have two girlfriends. Page 29 Q. Lawyer, what kind of instructions would 1 Q. The pilot would have two girlfriends? 2 you get from lawyers? 2 A. Mr. Epstein. This is all people coming ‘ A. We used to have a lot of time, for 3 in the plane together. 4 instance, the dock construction, you need to have 4 Q. Right. What do you mean by girlfriends? 5 a lot of permits in Palm Beach so they were there 5 A. Friends, you know, that he was always 6 for that reason. 6 having friends that he will befriend in New York, 7 Q. Okay. Now, so you would interact with 7 Idon't know, or some other places. 8 the staff from New York and that would include I 8 But I was just told -- my concern was how 9 think you said Lesley? 9 many people I have to feed, how many cars do I 10 A. Lesley, Bella. 10 need to transport these people from the airport to i] Q. What was Lesley's position? 11 the house, and to arrange accommodations in the 12 A. Lesley is the secretary, secretary to Mr. 12 house. 13 Epstein. 13 Q. What about Sarah Kellen, did she travel 14 Q. Okay. Is that Lesley Groff? 14 swith him? 15 A. I believe it was, I don't remember the 15 A. Yes. 16 last name. Q. So she was on the plane? " MR. CRITTON: Form. 19 Q. Anyone else that you dealt with in New 19 BY MR. MERMELSTEIN: 20 York? 20 Q. And Ms. Maxwell? Zi A. Doug Shadow was the architect and he used | 21 MR. CRITTON: Form. 22 to come to the house in a regular basis because we | 22 THE WITNESS: No, she will have different 23 used to have a lot of projects going on. 23 plane. 24 Q. Okay. Would you get advance notice when | 24 BY MR. MERMELSTEIN: Mr. Epstein was going to arrive In Palm Beach? Q. Okay. | — 8 (Pages 26 to 29) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000254

Case 18-2868, Document 283, 08/09/2019, 2628241, Page381 of 883 Page 72 | in cash as opposed to check? A. Not him. I will drive anybody else but MR. CRITTON: Form, he would rather eat at home. THE WITNESS: I was told to pay them Q. So you would drive house guests to cash, sir. restaurants? BY MR. MERMELSTEIN: A. Yes. Q. And when you did that you would -- didn't you stay with the car or did you eat with them? A. No, I will stay with the car. Q. So who did you tip? 10 A. If you want to park in front of the 11 restaurant you got to tip the valet otherwise 12 you're taking one of the spots. 13 Sometimes I used to take -- I'm sorry. 14 Aviation, you know, you need to go to aviation and 15 help those guys move your cars around, you need -- | 16 they carry luggage, so I used to tip those too. Q. Simply you were told and didn't ask why? A. No. Q. Do you recall telling the detective who interviewed you for the police that you thought of 10 yourself as a human ATM machine? 11 MR. CRITTON: Form. 12 THE WITNESS: Yes. 13. BY MR. MERMELSTEIN: 14 Q. You recall saying that? iS MR. CRITTON: Form. 16 THE WITNESS: Because I always had cash wooo “J oF in -& La Bo oe Ww co ~ oa in & lo Bae 17 in my pocket. 17 Q. That would be when you picked up or 18 BY MR. MERMELSTEIN: 18 dropped off Mr. Epstein, Correct? 19 Q. And why was there always cash in your 19 A. Yes. 20 pocket? 20 MR. MERMELSTEIN: We'll mark this as an 21 A. That was part of my job to have, you 21 exhibit, composite exhibit. 22 know, for emergencies or paying somebody cash. 22 (Composite Exhibit 1 was marked for 23 Q. Okay. What kind of emergencies? 23 Identification. ) 24 A. It's hard to say. I was supposed to put 24 MR. CRITTON: Just out of curiosity, on cash on each Mercedes Benz on each ashtray. The | 25 depositions are we going to use instead of Page 71 Page 73 1 idea behind this is you get stranded nobody accept 1 doing plaintiff and defendant designations 2 credit card or check you have cash. Z do you just want to run them one, two, 5 Q. How much did you leave in the ashtray? 3 three, four? 4 A. 300. 4 MR. MERMELSTEIN: That's fine with me as 5 Q. And did you ever have to replenish that a long as we remember where we left off. 6 money? 6 MR. CRITTON: Well, are we going to do it 7 A. Yes. 7 consecutive with all of the depositions? 8 Q. Because the Mercedes was stranded? 8 I'm okay with that if someone can keep track 9 A. No, because when Mr. Epstein will leave I 9 of that. 10 have to collect that money because I will send the | 10 MR. EDWARDS: I've had that go wrong 11 cars to the car wash so to avoid that money being 11 before, especially when we have some parties 12 stolen we used to keep track, you know, when to Fd who aren't here, such as Mr. Garcia, he's 13 retrieve that money and then when he's coming put j 13 going to join depositions, we have to start 14 it back there again. 14 at 27 or whatever. Q. So you use cash for that purpose and you iS MR. CRITTON: For each deposition one also use cash to pay the masseuses, Correct? if A. Yes. 18 Q. Did you use cash for any other purpose? 19 A. Car wash for the guy who used to came to 20 the house and wash all the cars. Tipping 21 sometimes for getting a good spot in the 22 restaurant you have to have cash, something like 23 that. 24 Q. Okay. Would you drive Mr. Epstein to a 25 restaurant? through whatever without necessarily giving ST a wld Or CETeTMean®htt: BY MR. MERMELSTEIN: 19 Q. Mr. Rodriguez, I've marked as Exhibit 1a 20 composite document which includes four per page of 21 what appear to be message slips. 22 First of all let me ask you, let me 23 direct your attention to the first page of this 24 exhibit. And the upper left message has initials 25 atthe bottom. Is that correct? 19 (Pages 70 to 73) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000265

Case 18-2868, Document 283, 08/09/2019, 2628241, Page382 of 883 Page 74 Page /6 1 A. Yes. 1 and he told you he owned a modeling agency? Fa Q. Are those your initials? 2 A. Yes, sir. 3 A. Yes, 3 Q. Anything else he told you? 4 Q. And was it the household policy to 4 A. He spoke, you know, five, six languages, 5 initial messages when they were taken? 5 always speaking Spanish, Italian. 6 A. Yes. 6 Q. Did the girls who were -- you know, who 7 Q. Okay. You were instructed to do that? 7 travelled with Mr. Epstein, were they from his 8 A, Yes. 8 agency? 9 Q. Who instructed you to do that? 9 MR. CRITTON: Form. 10 A. Ms. Maxwell. There was a manual, sir, in 10 THE WITNESS: I don't know, sir. 11 BY MR. MERMELSTEIN: 12 Q. You didn't discuss that? 11 the house, we had to follow the instructions of 12 the manual. 13 Q. There was -- okay. 13 A, No. 14 A. Estate manager, household manager for all | 14 Q. Let's look at the message next to it. 15 the houses, so I will abide to that, you know, so iS MR. CRITTON: Still on page one? 16 I take message with my initial, the time, who 16 MR. MERMELSTEIN: Still on page one. 17 BY MR. MERMELSTEIN: 18 Q. It appears the one under it is to the 19 same person. Is that correct? Who is that? 20 A, Alicia. 21 Q. Who is Alicia? 22 A. I don't know, sir. Please tell Jeffrey 23 that I called so I just wrote the name. 24 Q. Now, some of these messages if you look 25 through appears to be a different handwriting and 17 called. 18 Q. So there were all sorts of policies and 19 procedures in this manual? 20 A. Yes. 21 Q. Who wrote it? 22 A. It was the estate manager for ail the 23 properties and so I was -24 Q. Who was the estate manager for all the properties? Page /5 Page 7/7 j A. Inever met him, sir, he was fired before 2 Icame along. 3 Q. But you don't remember his name? 4 A. No, sir. e Q. And you remember one of the things that 6 ; 8 9 1 there is no signature on the bottom. 2 A. That's not mine, I don't know who's that 3. is, Sir. 4 Q. I thought you said earlier you were the 5 one who was responsible for taking messages. 6 7 8 9 A. Exactly, yes, I was, sir. Q. But there were other people who took messages as well? A. Maybe this is after or before my time, said in this manual was that every message has to be signed? A. Yes. Q. I'm not necessarily going to go through 10 every single message. Let me go back to the one 11 onthe upper left on the first page. It's from 12 Jean-Luc. Is that correct? Yes, sir. Who is Jean-Luc? He had modeling agency. How do you know that? 10 Sir. i Q. Okay. Because there is no date on it. 12 A. Iused to put my dates and I know I used 13. to do that all the time, but you know. 14 Q. These style of message pads. It was a pad. Correct? OPFPOPOPO,Y He gave me nis card, Sir. o. cts roid fa 18 Was he a frequent guest at the house? that it's like duplicate? ig Yes, sir. A. Exactly, the original stays with the 20 Did he stay over? 20 spiral. Zi. A. Sometimes he will stay, sometimes I will 21 Q. Okay. So there was a spiral notebook? 22 drive him to Miami. 22 A. Exactly. 23 Q. Do you recall his last name? 23 Q. And you would write the message on the 24 A. No, sir. Q. And so you had a conversation with him 24 top copy and then you would take that out and put 25 it on the counter in the kitchen? 20 (Pages 74 to 77) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000266

Case 18-2868, Document 283, 08/09/2019, 2628241, Page383 of 883 Page 150 Page 152 1 Q. You had a laptop? 1 Q. The girls who came to the house for 2 A. No, it was desktop. 2 massages, did you ever call a cab to bring any of 3 Q. Okay. So you had your own desktop in the 3. the girls home? 4 staff house? 4 A. Probably on a few occasions. 5 A. Yeah. Exactly. 5 Q. So is it your understanding that they 6 Q. And you don't know what was -- what was 6 would have arrived by cab as well? 7 the files in that computer versus on the other 7 MR. CRITTON: Form. 8 computers? 8 THE WITNESS: Yes. 9 A. No, Sir. 9 BY MR. MERMELSTEIN: 10 Q, Did you ever see any pornography on any 10 Q. And how would that come about, were you 11 given instructions to call a cab by anyone? 12 A. No, I would call the cab, the taxi. 13 Q. How did you know a cab needed to be 11 of the computers? 12 A. No, sir. 13 Q. Are you sure about that? 14 A. Parnography as in sexual acts, no. 14 called? 15 Q. Pornography as in naked people, men or 15 A. Because Sarah would tell me can you get 16 women. 16 mea taxi. 17 A. Yeah, there were some. at Q. So when the girl was finished what she 18 was doing Sarah would come to you and say -19 A. She would call me. 20 MR. CRITTON: Form. 21 BY MR. MERMELSTEIN: 22 Q. She would call you? 2s A. Yes. 24 Q. Okay. You would be in the guest house at 25 the time? 18 Q. Okay. And describe to me what that was. 19 A. They were like models. 20 Q. And where were those in the computer? I 21 mean, how did you access that? 22 A. They were in the files and some of it 23 in -- you mean which file they were, what was your 24 question? Q. Where were they in the computer? There Page 151 Page 153 A. Yes. Q. Do you recall having to do that often? A. No, not very often, sir. Q. Did Mr. Epstein keep photograph equipment were downloaded files on computer? 1 2 3 4 5 in the house? 6 Z 8 9 i 2 A. They were downloaded, yes. 3 MR. CRITTON: Form. 4 BY MR. MERMELSTEIN: 5 Q. Okay. There were photographs of naked 6 7 8 9 A. I don't remember seeing it. Q. Do you recall seeing any video equipment? A. No, sir, Q. Do you recall any video or photograph 10 equipment in the master bedroom? women? A. Models. Q. And why do you say models? A. Because it was like a catalog so you have 10 models, you know. Te Q. And what was your understanding as a li A. No, Sir. 12 source of these photos? ig Q. The models that you saw on the computer, is A. I don't know, sir. It was just a 13. did you recognize any of them as having been at 14. the house? 15 A. No. Q. us a mm stayed at the house, did 14 curiosity on myself and it was -- it was none of 15 my business but, you know, I just happen to see them cnere, ese girls appear very young MR. CRITTON: Form. 6 you: ig THE WITNESS: No, sir. They were young 19 Q. Many of them? 20 but not underage. 20 MR. CRITTON: Form. 21 BY MR. MERMELSTEIN: Zi THE WITNESS: Some of them. 22 BY MR, MERMELSTEIN: 23 Q. Would any of them not speak any English? 24 A. No. a5 Q. They all spoke English? 22 Q. Is there anything in particular that 23. makes you draw that conclusion? 24 A. Because they are developed, you know, It's hard to say, sir, you Know. 39 (Pages 150 to 153) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000285

wo co~ om in & to Ne Case 18-2868, Document 283, 08/09/2019, 2628241, Page384 of 883 Page 166 written down anywhere? A. No. Q. It's my understanding that C. and T. either came to his house alone to visit with Mr. Epstein or brought other girls in their age group to Mr. Epstein. Were you familiar with that type of recruitment process of girls bringing other girls? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. Can you tell me more about what you know about girls bringing other girls that are relatively the same age to come to Jeffrey Epstein's house and to use your words, have a good time? MR, CRITTON: Form. THE WITNESS: It's hard to know who they knew. But I think that was -- they feel better themselves when they're in a group than going by themselves, but I don't know somebody recruiting. BY MR. EDWARDS: Q. Okay. And you've talked about, at least referred to yourself I believe to the police and Page 16/7 as well today as a human ATM machine. Right? MR. CRITTON: Form. THE WITNESS: Something like that. I was supposed to carry cash at all times. BY MR. EDWARDS: Q. One of the primary reasons why you carried cash was to pay the girls in this age group of C. and T. for whatever happened at the house. Right? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. That's a fair statement. MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Right? ay. ee example, would bring sanieban else to the house, did you pay C. as well as whomever she brought to the house, pay them both? A. No, I pay only one person. Q. Okay. My understanding, and tell me if this is wrong or you can corroborate this, is that Mr. Epstein would pay the girl that was actually performing whatever was happening in the room -Oo ~J mun eb WW Be Page 168 for now we'll call it a massage -- as well as anybody who brought that person over to the house, they would both get paid cash. Are you familiar with that? MR. CRITTON: Form. THE WITNESS: No. BY MR. EDWARDS: Q. If C. brought another girl over to the house and C. stayed downstairs but this other gir! went upstairs with Mr. Epstein, which one would you pay? A. I don't know because I was told who to pay. Q. And Sarah Kellen always told you? A. Sarah told me pay so and so. So if we were going to ask anybody else about the exact method in terms of who would get paid and for what, who would the people be? I mean, other than Mr. Epstein who else could we ask | these questions? Sarah. Sarah Kellen? Yes. She would know this? Yes, Page 169 What about Ghislaine Maxwell? MR. CRITTON: Form. THE WITNESS: You're talking about the boss. I don't know. BY MR. EDWARDS: Q. To your knowledge was Ghislaine Maxwell aware of these girls that are in the age group of C. and T. coming to Jeffrey Epstein's house to have a good time? MR. CRITTON: Form. THE WITNESS: I have to say something. Mrs, Maxwell called me and told me not to ever discuss or contact her again in a threaten way. BY MR. EDWARDS: Q. When was this? the friends for a ib Gd she told me e this, but, you know, I feel intimidated and so I want to keep her out. Q. What exactly did she say? First of all, was this a telephone cail? A. Yes, she was in New York. Q. She called you on your cell phone? A. Yes. 43 (Pages 166 to 169) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miam! Beach, FL 33141 NON PARTY (VR) 000289

oo ™/ ch Un -B La Pu ore Case 18-2868, Document 283, 08/09/2019, 2628241, Page385 of 883 Page 238 Cab Company? A. West Palm Beach Taxi. No, it's not Yellow. Could be Yellow, but I don't know. Q. Would Mr. Epstein have the names or the list? A. Probably. MR. CRITTON: Form. BY MR. EDWARDS: Q. Anybody else? A. Sarah. Q. Sarah would have? A. Yes. Q. In addition to Mr. Epstein obviously knowing who's coming to and from the house, would Sarah also be familiar with the names of the girls and who they were? A. Yes. Q. In addition to Sarah and Mr. Epstein would Ghislaine Maxwell be familiar with the names of some of these girls? MR. CRITTON: Form. THE WITNESS: ‘Yes. BY MR. EDWARDS: Q. Are these names kept in a database in a computer system? A. Could be. MR. CRITTON: I'm sorry, did you say could be? THE WITNESS: Yeah. MR. CRITTON: Move to strike as speculation. BY MR. EDWARDS: Q. When you say could be, why do you say that? A. Because there were too many and they were very organized and there is nothing you write on a piece of paper. Q. When you say they were very organized, are we talking -A. Mr. Epstein and Sarah. Q. Anybody else beside Mr. Epstein and g scheduling to coordinate the times these girls would come to the house? A. I'm sorry, anybody else you say? Q. Right, aside from Saran. A. No, no. Q. And do you know what role, if any, Nadia Marcenacova ever played in any of what would go on behind the bedroom door with Mr. Epstein? 1 co ~J oh in hk la A oe Page 240 A. Nadia was the number one girlfriend for Mr. Epstein. Very sweet girl, and she was always -- she would come over to the house but different girls with her all the time. Q. Okay. But Nadia, that’s somebody who lives in New York? A. Nadia, I believe, yes, her address is in New York. Q. So how often would she stay at 358 El Brillo? A. Very often. Q. Usually every time when Mr. Epstein was there? A. Yes. Q. And she would for the most time fly on the plane with Mr. Epstein? A. Yes. Q. And it would be her and Mr. Epstein and oftentimes some other girls? A. Exactly. Q. Where some points I think earlier when Mr. Mermelstein was asking you questions where there was some confusion was we're talking about two different sets of girls, the girls that would come over and be labelled masseuses from the Palm | Page 241 | Beach area, and the girls that would fly on the plane with Mr. Epstein and Ms. Marcenacova. So, what I'm asking you is what, if any, involvement did Nadia Marcenacova have with the girls that would arrive and be labeled as masseuses behind closed doors with Mr. Epstein? MR. CRITTON: Form. THE WITNESS: He was the second -- the first role was Sarah and she was always -Nadia is a very shy person so she will be in the background. BY MR, EDWARDS: Q. Did you ever know of Nadia Marcenacova to engage in -- to be in the room with Mr. Epstein while any of these young girls were up there? wi sept hedile BY MR, EST EIN: Q. How often do you remember Nadia and Mr. Epstein being in the room with any of these young girls? A. Iwould say most of the time. Q. Nadia would go up there too? A. Yeah. Q. Did you ever believe that Nadia was 61 (Pages 238 to 241) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000307

Case 18-2868, Document 283, 08/09/2019, 2628241, Page386 of 883 Page 250 i Q. Would you know the name if I said it? 2 A. Yeah, 3 Q. Bill Riley? 4 A. Yes. 5 Q. Okay. Have you ever spoken with an 6 investigator Paul Lavery? 7 A. Could be, I'm not sure. 8 Q. Okay. So Bill Riley came by your house 9 personally? 10 A. Yes. 11 Q. And how long did you meet with him? i2 A. Five minutes. He gave me his card, he 13. gave me Mr. Critton telephone number, he said 14 don't talk to Mr. Goldberger. 15 QO. Did he tell you why you should call Mr. 16 Critton? Ly A. No. I assume that he was not on the case 18 anymore, but I didn't ask questions but -19 Q. You assumed that who wasn't on the case 20 anymore? re A. Mr. Goldberger, Jack Goldberger. 22 Q. Okay. But what I'm asking you, I guess, 23 is did this investigator, Mr. Riley, tell you why 24 it was important for you to call any attorney that's associated with Mr. Epstein, why was that Page 251 important? A. He didn't say that. He didn't say that. He just said that get in touch and that's it. Because I said what am I going to do, because | said I thought this was -- you know, but I didn't know I was going to be subpoena. And like I said in the beginning of this deposition, I don't have an attorney so I don't have money, first of ail, to pay for an attorney. First of all, I don't think I'm in trouble, but every time you hear high powered lawyers you feel intimidated so I said, listen, what am I going to do, and that was my basic question. Q. Okay. So then you spoke with somebody at Mr. Critton's office and arranged to meet with him Pelee down with his assistant, the three of us. Q. So it was Mr. Critton, yourself, and somebody else? A. Yes, Q. And you sat down for another two hour period of time? A. Yes. Q. And what did you go over in that meeting? Page 252 1 A. We discuss -- he asked me a lot of 2 questions, obviously he didn't know a lot of 3. things about the case, and I told him who I was, 4 what I did in the house. 5 Q. He told you he didn't know a lot about 6 the case? 7 A. No, no, no. He asked me questions about 8 sol got the feeling that Mr. Critton didn't know 9 as much as other lawyers. 10 Q. Okay. Did you tell him what you told us li here today? 12 A. Wo. He asked me tell the truth, you 13. know, just go over there, you know, he advise me 14 like you're on your own, Alfredo, just tell the 15 truth, you know. He didn't give me any advice. 16 He paid for my gas. Thank you very much. 17 And that's it, you know. 18 The main thing I wanted to have a lawyer 19 on my side but then I keep going to the first 20 instance when my wife told me you don't need a 21 lawyer, and I'm here today to say that, I'm here, 22 I'm speaking the truth. 23 Q. Okay. You mentioned there were five or 24 six computers in the house? A. Yes, Page 253 i Q. And do you know what happened to the 2 computers? 3 A. No. 4 Q. You don't know where they are? a A. (Shakes head.) 6 Q. Nobody has told you? Z A. No. 3 8 Q. You also mentioned there were photographs 9 in the house? | 10 A. Inthe computers in the files. 11 Q. Okay. But there were also still 12. photographs around the house? | A, Oh yes, yes. 14 Q. Some of the girls have made the allegation that there were photographs of them pues in the harass ca Aaa remember seeing that? one frame with Sab i5 pictures, small pictures. MR. CRITTON: Repeat the question back. BY MR. EDWARDS: Q. Okay. Some of the girls that have lawsuits against Mr. Epstein with allegations similar to the allegations that C. and T. have made, which is that they were underage when Mr. 64 (Pages 250 to 253) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000310

wc ~~ min A tl A Fe Case 18-2868, Document 283, 08/09/2019, 2628241, Page387 of 883 Page 254 Epstein was engaging in sex or sex acts with them, also say that they have seen pictures of themselves in frames in Mr. Epstein's house naked. A. In his closet. Q. Other than the picture -- and these are girls who are making the allegation that they were underage and there were pictures of them nude in his house. A. I didn't see pictures of C. there. Q. I'm not talking about C. I'm saying other girls that were underage or have made allegations that they have seen pictures of themselves in Mr, Epstein's house, MR. CRITTON: Form. BY MR. EDWARDS: Q. Where would those photos have been, or did you see them? A. Yes, I see them inside his closet. Q. It's one mosaic? A. Yes, one mosaic. Q. Other than there did you see any of these pictures of young girls nude anywhere else in the house? MR. CRITTON: Form. THE WITNESS: Nude with an art, yes, but Page 255 not pornography. You know, I saw them, they were all over the place. For instance, in the back only showing part of the rear, you know. BY MR. EDWARDS: Q. But the photographs that I'm concerned with -A. Not frontal pictures. Q. The photographs I'm concerned with are photographs of these West Palm Beach girls that were labeled as masseuses that are being displayed around the house anywhere in some state of undress. MR. CRITTON: Form. THE WITNESS: No, I don't remember that. BY MR. EDWARDS: co DRay. a photograph that you remember of young girls nude was in a mosaic that is in his closet? A. Yes. Q. Nothing that you remember that was on display? A. Downstairs, yes, but they were not these girls, they were somebody else. Q. Okay. Do you know who was -- who were in woo“ oi tn Ba Go Mm Re Page 256 those photos? A. One was a Columbian lady and one was -one from Spain, beautiful girls, that, you Know, but they were not -- not the ones the girls we're talking about here. Q. Okay. When you were hired were you hired by Mr, Epstein or were you hired by one of his companies? A. Mrs. Maxwell. Q. So it was -- was it a company owned by Mrs. Maxwell? A. Not directly. My paycheck was Jeffrey Epstein. I mean, I was hired by Mr. Epstein but -Q. Okay. I just understood you to say you were hired by Mrs. Maxwell. A. Exactly, she told me you're hired but you're going to get paid by Mr. Epstein. Q. And he wrote you personal checks? A. No. The checks that came from New York, Jeffrey Epstein Companies. Q. It was out of his company? A. Yes. Q. Which company; do you know? A. 456 Madison Avenue. It's next to the New Page 257 York Palace now. Q. The name of the company is 456 Madison Avenue? A. No, no, it's -- I got it on the tip of my tongue. Something like Caribbean or island something investments, something like that. If you call Lesley, her secretary, sne will tell you exactly. Because they answer the phone like that, you know. Q. What's Lesley's number? A. Lesley, I don’t have it. I can find out for you. Q. Do you think you could get Lesiey's number for us? A. Yes. It's in Manhattan. Q. Does she work for this company in MR. CRITTON: Form. THE WITNESS: Manhattan, yes. BY MR. EDWARDS: Q. If the check was issued did Jeffrey Epstein actually sign it himself? A. No, it came through the comptroller. Q. Who was the comptroller? A. Bella was the assistant comptroller and 65 (Pages 254 to 257) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000311

Case 18-2868, Document 283, 08/09/2019, 2628241, Page388 of 883 Page 266 Page 268 1 BY MR. LANGINO: 1 THE STATE OF FLORIDA, ) 2 Q. Are you currently in fear of Mr. Epstein? 2 COUNTY OF DADE. ) 3 A. Not at this particular moment but it's 3 4 something I have to be worry about, yes. ‘ | . 5 Q. Are you personally afraid of criminal 3 I, the undersigned authority, certify 6 prosecution? 6 that ALFREDO RODRIGUEZ personally appeared before | 7 A. No. 7 meonthe 29th day of July, 2009 and was duly 8 Q. Do you believe that you did anything : ans ‘ ae aise, no. 10 WITNESS my hand and official seal this il MR, LANGINO: I have no further Li 31st day of July, 2009. 12 questions. Thank you. 13 MR. CRITTON: We're going to break in 14 about 15 minutes. Do you want to start and 15 go for 15 minutes or do you want to -- it's MICHELLE PAYNE, Court Reporter ao eee Notary Public - State of Florida 17 MS. EZELL: I'll start. 18 MR. WILLITS: When are we going to quit, 19 folks? 20 MR. CRITTON: In 15 minutes. 21 THE VIDEOGRAPHER: Might as wel! change 22 tapes. 23 MR. EDWARDS: Bob has to get back so 24 we've agreed we're going to come back some other time. Page 26/7 1 MR. WILLITS: Why don't we just stop now? 2 MS. EZELL: Okay. 3 MR. EDWARDS: Rather than you start. 4 MS. EZELL: Yeah, I won't get very far. 5 MR. EDWARDS: Sorry to do this with you, 6 7 8 9 CERTIFICATE The State Of Florida, } 3 ©6County Of Dade. ) 5 I, MICHELLE PAYNE, Court Reporter and Notary Public in and for the State of Florida at 6 large, do hereby certify that | was authorized to and did stenographically report the videotaped 7 deposition of ALFREDO RODRIGUEZ; that a review of the transcript was requested; and that the 8 foregoing pages, numbered from 1 to 269, inclusive, are a true and correct transcription of 9 my stenographic notes of said deposition. 10 i further certify that said videotaped deposition was taken at the time and place 11 hereinabove set forth and that the taking of said videotaped deposition was commenced and completed 12 as hereinabove set out, 13 I further certify that I am not an attorney or counsel of any of the parties, nor am 14 La relative or employee of any attorney or counsel of party connected with the action, nor am 1 financially interested in the action. 2 foregoing Centiica transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter. DATED this 31st day of July, 2009. we didn't finish. MR. CRITTON: So we're stopped? MR. EDWARDS: We're stopped. THE VIDEOGRAPHER: Off the record. 10 (Thereupon, the videotaped deposition was 11 adjourned at 5:30 p.m.) 12 - «> rd ttt 68 (Pages 266 to 269) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000314

Case 18-2868, Document 283, 08/09/2019, 2628241, Page389 of 883 Page 270 | 1 UNITED STATES DISTRICT COURT | SOUTHERN DISTRICT OF FLORIDA 2 3 JANE DOE NO. 2, CASE NO: 08-CV-80119 4 Plaintiff, 5 Vs. 6 JEFFREY EPSTEIN, 7 Defendant. / 8 JANE DOE NO. 3, CASE NO: 0O8-CV-80232 9 PLlLaLnet £, | 10 on ~i } Vs. CONDENSED Li JEFFREY EPSTEIN, | de Defendant. 13 / 5 JANE DOE NO. 4, CASE NO: 0O8-CV-80380 1.5 Plaintiff, { 16 Vs. | 17 JEFFREY EPSTEIN, 18 Defendant. / 19 JANE DOE NO. 5, CASE NO: O8-CV-80381 20 Plaintiff, 2. | VS ; 22 JEFFREY EPSTEIN, Z2 Defendant. 24 / 25 PTS eae NT rere ennpocennanermuamnnn caesarean ater TT Ce ee en hake ee ee cae ORO i ono ttm nen ua th Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000315

ts b ww AG an 10 tl 12 14 15 16 17 20 21 22 23 24 25 i Dt WW Ro ee oO 10 tH 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Fn se I cg RUSE a dhs PN Eas STAR i Eee te Dh AL a, et allan lected ape dd lend Patina bieRe 1 eI EBd ta. amg thee danse aetna ncidln.n + inte as tate taaiienahaas alah. tate ana ie act eels ninalaacelnsuniit, iecaaae cae auh Giealnekss. 5. salad taneetese Rex aba tees ihe ulaaaieath deeded land oa Seatac on. aoaedecsaneean ean. delet nsath cc REI SE A 7.4, cama aces aes eats pasealdaia d dae cies aman Case 18-2868, Document 283, 08/09/2019, 2628241, Page390 of 883 JANE DOE NO. 6, CASE NO: 08-CV-80994 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. sitcaiciecsemna aecarscsccaih JANE DOE NO. 7, CASE NO: 08-CV-80993 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. C.M.A., CASE NO: 08-CV-80811 Plaintiff, Vs, JEFFREY EPSTEIN, Defendant. wccnancenuell JANE DOE, CASE NO: 08-CV-80893 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. IT, CASE NO: 08-CV-80469 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. (ene prtdiaecleeceistaede ticles JANE DOE NO. 101 CASE NO: 08-CV-80591 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 102, CASE NO: 08-CV-80656 Plaintiff, Vs. JEFFREY EPSTEIN Defendant. ieshi iene aeciataieneee Page 271 Page 272 B.B., Page 273 | IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO, 502008CA037319XXXXMB AB Plaintiff, Vs. JEFFREY EPSTEIN. Defendant. eames 1031 Ives Dairy Road Suite 228 North Miami, Florida August 7, 2009 1:15 p.m. to 5:30 p.m. CONTINUED VIDEOTAPED DEPOSITION of ALFREDO RODRIGUEZ taken on behalf of the Plaintiffs pursuant to a Re-Notice of Taking Continued Videotaped Deposition (Duces Tecum) ~~ MERMELSTEIN & HOROWITZ, P.A. BY: ADAM HOROWITZ, ESO. 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 Attorney for Jane Doe 2, 3, 4, 5, 6, and 7. ROTHSTEIN ROSENFELDT ADLER BY: BRAD J. EDWARDS, ESQ., and CARA HOLMES, ESQ. Las Olas City Centre Suite 1650 401 East Las Olas Boulevard Fort Lauderdale, Florida 33301 Attorney for Jane Doe and E.W. And LL.M. PODHURST ORSECK BY: KATHERINE W. EZELL, ESQ. 25 West Flagler Street Suite 800 Miami, Florida 33130 Attomey for Jane Doe 101 and 102. LEOPOLD-KUVIN BY: ADAM J. LANGINO, ESQ, 2925 PGA Boulevard Suite 200 Palm Beach Gardens, Florida 33410 Attorney for B.B. een 2 (Pages 271 to 274) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000316

oO COM OF On op Go Bo oF Case 18-2868, Document 283, 08/09/2019, 2628241, Page391 of 883 Page 299 A. I don't remember, Ma'am. He came from New Albany, Ohio. Q. From New -A. New Albany, Ohio. Q. New Albany, Ohio. Did he have his own business? A. No, he worked for Mr. Epstein. He will maintain all the computers. Q. Was he there everyday? A. No, ma‘am. Q. Do you know whether at that time Mr. Epstein had an office in Palm Beach? A. Not outside the house, no. Q. Do you have any knowledge of whether or not the video equipment was -- and I don't know the technical term, forgive me, but was it the kind of equipment that would record for a certain amount of time and then record over that film? A. Idon't know, MR. CRITTON: Form. BY MS. BZELLS Q. You don't know? A. No, ma‘am. MR. CRITTON: Just for clarification, I may have misunderstood, but I thought he Page 300 said he didn't even know the video equipment existed until he read the FBI report. MS. EZELL: He said he didn't know that it was upstairs and downstairs, I believe. MR. CRITTON: I thought he said he didn't know that it even existed. MS. EZELL: I may be wrong. BY MS. EZELL: Q. Did you know it existed before you read the FBI report? A. No, ma‘am. Q. I'm sorry, then I was wrong. How did you know then that the young technician from Ohio maintained the computers and the video equipment? A. Because we used to request -- there were always problems with the computers so he came to the house and he was the programmer. It was very sophisticated. MR. CRITTON: Form to the last question, move to strike the answer as nonresponsive. BY MS. EZELL: Q. How did you know then that he maintained the video equipment as well? A. Because he was in charge of computers, WOnN AM DWN bonne ce stba Deeliiaeiptstuipt >in Seasilthve Radicals Mia DnaDnsibe dca ainiateratian neliaset tails > Bets nie a sahidae Re ID. toape Dettligty int istn thatch Tha ninaneinaahiin i shan cianeitesThspan i deed besaaninhateriney aebaeilG ae Page 301 video, even phones. Q. Would he also repair the televisions if they needed work? A. No. Q. No. Did you have any kind of intercom system in the house? A. Yes, ma'am. Q. And what kind of system was that? A. It was standard office equipment, Lucid Technologies maybe, but it was an intercom like we | using right now. MS. EZELL: Just let the record reflect that the witness pointed to the telephone on the table that has a speaker phone. THE WITNESS: Yes, ma’am. BY MS. EZELL: Q. And did you use that in your work? A. Yes, ma'’am. Q. And what did you use it for? A. Mr. Epstein used to page me when he needed me. Q. Did you have one of those phones in the kitchen? A. Yes, ma'am. Q. And was there one out in the staff house Page 302 as well? ; A. Yes, ma‘am, Q. Do you know where others were in the house? A. Probably have like 15 phones. We used to have three in the staff house, one in the cabana, two in the master bedroom, one in each room, kitchen, dining room, Mrs. Maxwell's office, the garage. Q. Where was Mrs. Maxwell's office? A. Under the stairs next to the kitchen. Q. Can you give me some idea of what size space that was? A. It was probably -- we change the floor. Twelve by five, something like that. Q. And was the computer equipment in that space: A. Yes, ma’am. Q. Do you know whether Ms. Maxweil kept the ; names and telephone numbers of the girls who came} to do massages? A. Yes, ma'am. ; MR. CRITTON: Form. BY MS. EZELL: Q. Do you know that because you saw the I 9 (Pages 299 to 302) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000323

1 CO NE oO OF Dh G3 BO rs bed lak alla i ake Nant Nats Nine Psa nie Anglin Case 18-2868, Document 283, 08/09/2019, 2628241, Page392 of 883 Page 303 names and phone numbers? MR, CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. Do you know if she kept pictures of the girls on the computer? A. Yes, she did. Q. And you know that as well because you happen to see them? A. Yes, ma‘am, MR, CRITTON: Form to the last two questions. BY MS. EZELL: Q. Were they similar to the pictures that Ms. Kellen had on her computer? MR. CRITTON: Form. THE WITNESS: Yes, ma‘am. BY MS. EZELL: Q. Did the pictures that they kept there look like pictures that were posed? A. They were more casual. Q. Did they look as though the person being photographed knew that they were being photographed? MR. CRITTON: Form. Page 304 THE WITNESS: No, ma'am. BY MS. EZELL: Q. And what can you tell me about that, what lead you to draw that conclusion? A. They were probably taken in parties in big reception or banquet. MR. CRITTON: Let me offer as a suggestion, not that you have to accept or that you would, you're using the term young girls generically, he has probably seen many, many young girls, there was no -you've used it interchangeably with just young girls versus young girls who may have come to -- purported to give a massage and, therefore, that may be a different answer, so that's part of my form objection. Ao Okayy thank you: BY MS. EZELL: Q. When I asked you about Ms. Kellen whether she had a list of the girls and telephone numbers, I think I asked about those girls that came to give massages, but let me go back and just ask it that way. Did you notice that Ms. Kellen had a list of the girls that came to give massages on her Licsanustimphc ah casccdis aieaagttuasnt-danean taaaaie Psothken kebaaadhnn aren honapadcbenkaeed daleeclammed Wan HH Bh WN oo. aa ain wes caecum Ae Ba ihe Nn ree aed Sai eta anced ik ci te he Eat ta ih elite Ac Rake Zin Za sh Ales lnrRinnt ab pede aetna Nees Oh is nad ated Leica Raed wakes EHC computer? MR. CRITTON: Form. THE WITNESS: Yes, ma‘am. BY MS. EZELL: Q. And did she generally have phone numbers for those girls? A. Yes, ma'am. Q. And were they generally pictures of the girls? MR. CRITTON: Form. THE WITNESS: No, ma‘am. BY MS. EZELL: Q. And did Ms. Maxwell have a list of the girls who came to give massages? MR. CRITTON: Form. THE WITNESS: Yes, ma’am. BY MS. EZELL: Q. Did she have telephone numbers generally? A. Yes, ma‘am. MR. CRITTON: Form. BY MS. EZELL: Q. Were there pictures on her computer of the girls who came to give massages? MR. CRITTON: Form. BY MS. EZELL? Page 306 |; Q. Ms. Maxwell I'm talking about. A. Yes, ma'am. Q. And were those pictures the more casual ones that you described when I asked whether or not the subject looked as though she knew she was ? being photographed? MR. CRITTON: Form. THE WITNESS: I'm sorry, can you repeat? BY MS. EZELL: Q. Yeah. The pictures of the young girls who came to the house to give massages that were on Ms. Maxwell's computer, did they appear to have been taken when the girls knew they were being photographed? MR. CRITTON: Form. BY MS. EZELL: Q. I believe you said they were more casual pictures. A. Yes, ma'am. Q. Did you notice any nude photographs in those pictures? A. Yes, ma'am. MR. CRITTON: Form for the last question. Bk Ra SE ANS Ae HESS ABEL SIE, PEI Ba Litas tig PG PDR aac cn tie ia 10 (Pages 303 to 306) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000324

LPS dee had Pd eo pe) eee ee : ete Pape soecSe Shak Sa cane easels it PAP A Case 18-2868, Document 283, 08/09/2019, 2628241, Page393 of 883 Page 471 THE STATE OF FLORIDA, ) COUNTY OF DADE. ) I, the undersigned authority, certify that ALFREDO RODRIGUEZ personally appeared before me on the 7th day of August, 2009 and was duly sworn. WITNESS my hand and official seal this 18th day of August, 2009. MICHELLE PAYNE, Court Reporter Notary Public - State of Florida Page 472 CERTIFICATE The State Of Florida, } County Of Dade. } I, MICHELLE PAYNE, Court Reporter and Notary Public in and for the State of Florida at large, do hereby certify that | was authorized to and did stenographically report the deposition of ALFREDO RODRIGUEZ; that a review of the transcript was not requested; and that the foregoing pages, numbered frorn 270 to 472, inclusive, are 2 tue and correct transcription of my stenographic notes of said deposition. I further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of sad deposition was commenced and completed as hereinabove set out. I further certify that i am not an attomey or counsel of any of the parties, nor am 1 a relative or emiployee of any attorney or counsel of party connected with the action, nor am ] financially interested in the action, 2 Toregaihg Cermincsnon oF oT transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter. DATED this 18th day of August, 2009. MICHELLE PAYNE, Court Reporter SS daa natn hoe rsa st as tA Rigel Paar 52 (Pages 471 to 472) fetid tei 35 ASA hin itn De taclbnictahdoealel wk. hale Dh ch aS Al A 9a EGE Lg SIRO ty SAA AD ae Hes MB a Freie Dan es; 2 5 gaa Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000366

EXHIBIT 22 (Filed Under Seal)

The text on this page is estimated to be only 34.57% accurate

SOTAPe [P52] 21 woNeoTUMUMUO; STAPe [VS2] ol woTeoTUMUMUO SOTApPe [Sz] :o1 woyeoTUMUMO SOTAPe [Se] 31 uoTeoTUMUMO SOTAPe [eS2] 31 woTeoTUMUMUO; SOTAPe [Se] 31 woTeoTUNUMUO) SOAPe [P32] :o1 UOT LITUNUIUIO,) SOTAPe [P52] 21 woyeoTUMUMO SOTApPe [Se] :o1 woyeoTMUMO; SOTApPe [Sz] :o1 woNeoTUMUMO; SOTApPe [Sz] :o1 woyeoTUMUMUO SOTAPe [ee] 31 woyeoTUMUMO SOTApPe [Sz] 1 uOTeOTUMNUMUO) Loardos wus] 0%) 8SOl /quesy / Aeuloyy SsOY [JoEMXePY SUTRTSTYH ‘bsq ‘uepieg dig Ei} seats Peas | ese 8SOl 8SOl ws) | Peexey SSol OT 1O'STt0c / Kauoyy / juesy pet ‘bsq ‘uepreg dymyd ae -F-- - 60° 10°S107Z [sol MOL) SSOY ‘Dsq “ZjIMoYysIoq uepy evol yaoTE ae 8cOl justT 9COT / yesy AsuIOyy [PMXeY SUrelsty MOL) SSO “O0cOT STTREIN-H cO 10’ ST0¢ 610! elol dIHSNOILV Tada "MET AN Pure MET Ope.10[OD ‘MET YSILIGg 0} JUENS.ANd po}.lassE 3.18 SaSaTIALId SULMOTOJ 9} ‘7°97 BIN [vIO'T 19g.== OI0Z ‘TI JSnSNy Jo sv pepueuly So7T sSaT1ALig S,JJaMxey, VUILISIYD SMA eerloArcT JJamxvyy “a aaffnry YIOK MAN JO PLYSIG Ways aq] 104 LINOD JILYSIC $2383g payuy €88 $0 G6eabed ‘TyZ8zZ9Z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD

The text on this page is estimated to be only 30.95% accurate

uopieg Ijtyd JO worsarIp OU} Je [[JOMXVIN oure[sIyD) Aq posedoid yUSUINIOG JUSUIOISV JSOIOJUT UOWIWO;) yonpoid yom AdUIONY yonpoid yom AdUIONY WUOUUYOeNe YIM OSIALg WTD KDUIONY,, PO[OqR] SIOqUIO AM UlIe/Y WOJJ ASeSsoUl SUIPIVMIO DOIAPe [VSI] :d1 UOT}BOTUNUWUWOZ) DOIAPe [VSI] :d1 UOT}BOTUNUWUIWO,) DOIAPe [VSI] :d1 UOT}BOTUNUWUWOT) DOIAPe [VSI] :01 UOT}BOTUNUWIWO,) DOIAPe [VSI] :01 UOT}BOTUNUWIWO,) DOIAPe [VSI] :01 UOT}BOTUNUWUIWOZ) DOIAPe [VSI] :01 UOT}BOTUNUWUWO,) Jd] D/ADUIONY JUDUIIOISV SO1OJUT UOWIUOZ) 0} sonied 10j shauIony yonpolg yio AA Aousony AUIONYV pue Aduso}e Jo JUOSV SO19]UT UOWUWOZ) SO19]UT UOWUOZ) SO19]UT UOWIWOZ) jUSTTO / Kourony / WIsV qa|TD / Aous1ony SO19]UT UOWWOZ) 1SO19]UT UOWIUOZ) SO19]UT UOWUOZ) C Pt 90'10°S10Z _ JOSUTUUDJT BINT ‘ayApuy Used jUOUUYOKIIe Uy UreYyo cc OT STOC eine’T ‘ayApuy used jrew-q | - [ZO SIOZ by JOSUIUUDI JosuIuUsjy eine’T ‘eliog Arepy JOSUIUUD| BINT ‘UPUdIO.F 3» URSIOJ ‘UOppeH Jo JuasV [l2Mxey] OUrRISIYD uloysdy Aowyor [[2MxeJ] OUrPISIYD [JOMxXPIT sure[sIyD “ bsq ‘uepreg did [laMxey] oUrISIYD ‘bsq ‘SIOqUIOM UIE] uloysdy Aowyor [l2MxeJ] oUrISIYD C JOSUIUUDI eine’T ‘eliog Arey s[Teuwl-q SNOLIv A. "Co JOSUIUUDJY BNL] ‘UBUDIO 29 UPSIO/Y ‘uoppeH Jo juasy s|Teul-q SNOLIe A, CG uraysdy Aoyjor | sosed / a 77 VO S107 17 [[omxey] OUTe[STYH 6601 SIRIN-A | -ITTOSTOZ urlaysdy Aoyor -P80I SIRI-A | - IT LO'STO7 61 MOD) SSOY “8801 TRA-A | = ITTOSTO? ST a EL 10'S10Z fe ‘bsq ‘uopieg diy a EL 10'S10Z OI ELOI [[OMxXvYY OUTRTSTYH -L9OI 1 saa ET TO'STOZ “CT E801 LV TO'STO7 utosdgq Aotyor -6SOI sTIeIN-a | - IE 1O'S107 OC ‘bsq ‘uopseg dim vi €88 $0 96Eabed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUBWNDOG ‘898Z-8T aSeD

The text on this page is estimated to be only 42.00% accurate

uopieg IytYd JO UONSeIIp OY} 1e [[JOMXP/] oure[SIyt) Aq poredaid quoUNs0q Wd] D/ADUIONY Ec LO STOC ‘OC €88 $0 /6Eabed ‘TyZ8zZ9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD

EXHIBIT 23 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page399 of 883 Expert Report of Professor Terry Coonan, J.D. Pursuant to Federal Rule of Civil Procedure 26(a)(2)(B) Giuffre v. Maxwell Case No. 15-cv-07433-RWS

Case 18-2868, Document 283, 08/09/2019, 2628241, Page400 of 883 international commercial dimensions of the sex trafficking scheme recounted by Ms. Giuffre. It is both factually and legally correct to characterize what Ms. Giuffre experienced as victimization in a sex trafficking conspiracy. Conclusion 4 Virginia Roberts Giuffre’s account appears credible and consistent in its most salient parts with the testimony of other witnesses and with contemporary trends in US. sex trafficking. The description of exploitation recounted by Ms. Giuffre, while not the most common sex trafficking scenario (many cases involve even more brutal forms of pimp-driven prostitution) nonetheless is quite consistent with larger patterns of commercial sexual exploitation. The conspiracy in this case was premised upon the exploitation of minors and young women who seem to have had certain identifiable vulnerabilities that rendered them prone to exploitation. The criminal scheme that emerges from the depositions and police reports involved a very calculated pattern of recruiting, grooming, and an attempt to “normalize” the repeated exploitation of its victims. While the accounts of witnesses vary in some of their details, the essential elements of a sex trafficking conspiracy clearly emerge when viewed in the totality of the circumstances that are recounted in the case record. Ms. Giuffre refers to herself at times as a “sex slave.” This is not factually incorrect, given her experiences, though current U.S. law might prefer to characterize her as a victim of sex trafficking. Popular understandings of the term “sex slave” might still connote images of violent pimps, white slavery, or of victims chained to a bed in a brothel in the minds of some people. To call Ms. Giuffre a victim of sex trafficking would however very accurately convey the reality that she along with a great many other victims of contemporary forms of slavery are often exploited by the “invisible chains” of fraud and psychological coercion. 20

EXHIBIT 24 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page402 of 883 Expert Witness Report of Dr. Bernard J. Jansen Professor College of Information Sciences and Technology The Pennsylvania State University Regarding the case of: Virginia Giuffre Vv. Ghislaine Maxwell (U.S. District Court for the Southern District of New York) 9 September 2016

Case 18-2868, Document 283, 08/09/2019, 2628241, Page403 of 883 I. INTRODUCTION 1. I have been retained by the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. to provide expert analysis and opinion on behalf of Ms. Virginia Giuffre in VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15cv-07433, which is pending in the United States District Court Southern District of New York. HI. QUALIFICATIONS 2 I am a tenured, full professor at the College of Information Sciences and Technology at The Pennsylvania State University, University Park, Pennsylvania, where I have been employed since 2001. I am the Director of the Information Searching and Learning Laboratory at the College of Information Sciences and Technology at The Pennsylvania State University. I am also a principal scientist at the Qatar Computing Research Institute. I was a Senior Fellow at the Pew Internet & American Life Project, which is part of the Pew Research Center, from 2010 through 2012. I was also a University Expert at the National Ground Intelligence Center from 2011 through 2014. Prior to my employment at The Pennsylvania State University, I was a Lecturer in the Computer Science Program at the University of Maryland (Asian Division) for 1 year. Before that I was an Assistant Professor and Lecturer in the Department of Electrical Engineering and Computer Science at the United States Military Academy, a.k.a. West Point, for 3 years. 3. In addition to my academic credentials, my professional experience includes 20 years of practice in the U.S. military, working primarily in a variety of technology-related and leadership positions. 4. I have authored approximately 250 academic publications, focusing on the areas of Web data, digital analytics, Web analytics, Web searching, Web search engines, social media analytics, and related areas. Approximately 200 of my publications address aspects of search 2

Case 18-2868, Document 283, 08/09/2019, 2628241, Page404 of 883 analytics, Web analytics, online advertising, search engines, or Web searching. My recent research work focuses on online news analytics, which 1s the investigation of the online qualitative and quantitative attributes of news stories, along with other digital content. I am also the editor-in-chief of the academic journal Information Processing and Management, and I was previously the editorin-chief for 5 years of the academic journal, Internet Research. I have authored, co-authored, or co-edited four books, including Web Search: Public Searching of the Web (2007), Understanding User — Web Interactions via Web Analytics (2009) and Understanding Sponsored Search (2011). A copy of my complete curriculum vitae, which includes a list of all publications I have authored in the past 10 years, 1s attached as Appendix A. 5. My fields of professional expertise include web analytics, search engines, web searching, social media, online advertising, and related areas. In the course of my academic career, I have worked with a variety of search engines and information searching applications in order to understand user searching behavior on the Web and other environments. For example, as part of my Master’s program in computer science, I designed and coded a text-based search engine. For my Doctorate program in computer science, I developed a program interface for Web search engines and implemented it on the Gigabyte search engine. In subsequent research, I have worked with the Microsoft Internet Information Services (IIS) and Verity commercial searching systems. 6. Concerning user searching behaviors on the Web using web analytics, I have worked directly with real-user searching data from several search engines, including AOL, Alta Vista, Dogpile, Excite, and MSN Live. I’ve also analyzed web data of visitor traffic and other attributes from a variety of websites and social media platforms. I’ve analyzed real-user data from online search marketing campaigns and user referral traffic to websites. I have conduct research and teaching concerning aspects of websites and social media platforms, including keyword

Case 18-2868, Document 283, 08/09/2019, 2628241, Page405 of 883 advertising. I’ve developed web analytics models and processes for analysis of business goals, and I have used web analytics data and commercial tools in both my research and teaching. I’ve also conducted other research on user searching and related online behaviors. I have advised governmental agencies and companies in consulting and expert witnessing matters. A list of cases in which I have testified as an expert in deposition or trial in the past four years is attached as Appendix B. I am being compensated for my work on this case at the rate of $300 per hour. Hl. ASSIGNMENT AND MATERIALS CONSIDERED iT In providing my expert opinion, I have been asked to respond to the following question: 8. What is the dissemination of the statements from Ms. Maxwell referring to Ms. Giuffre’s declarations as “untrue” and “lies” from when the statements were made on 2 January 2015 to the date that I filed this report? 9, For brevity, I refer to references to the statements denoting Ms. Giuuffre’s declarations as “untrue” and “lies”, any related accounts referring to those original statements, or similar statements from Ms. Maxwell or her representatives referring to Ms. Giuffre as the statements made against Ms. Giuffre, the statements from Ms. Maxwell’s message, or the message from Mr. Gow’. 10. My analysis is based on my experience, training, knowledge, and education and is formed through the application of that experience, training, knowledge, and education in the principles of web data collection, web analytics, web search, search engines, web sites, web traffic analysis, and related market analysis. 11. The materials that I considered 1n preparing this report are listed in Appendix C. See, para. 30 and 32, Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-cv-07433. 4

Case 18-2868, Document 283, 08/09/2019, 2628241, Page406 of 883 IV. SUMMARY OF OPINIONS 12. Based on my research and analysis in connection with this assignment, which is described in more detail in the body of this report, along with my own experience, training, knowledge, and education as stated below, I have reached the following opinion: 13. The statements made against Ms. Giuffre have been disseminated to at least 115 online media or other sites in 178 separate stories or articles with a combined 66,909,965 potential unique visitors since 2 January 2015 to the date that I filed this report, inclusive. 14. This is a conservative estimate, and it is more likely than not, the statements made by Ms. Maxwell against Ms. Giuffre have received wider dissemination due to factors such as: a. I used a set of online websites to measure dissemination, and it is reasonable that I have not located all references to the statements made against Ms. Giuffre on every website by the time of the submission of this report. b. I examined only online sources referencing the statements made against Ms. Giuffre and not print or broadcast media dissemination of the statements made against Ms. Giuffre. C. I have not attempted to measure face-to-face dissemination of articles containing the statements against Ms. Giuffre. d. I do not have access to certain online sources where articles containing the statements against Ms. Giuffre may have been disseminated (e.g., email messages, personal social media messages, articles behind firewalls, etc.). e. There are possibly sites that have hosted the statements made against Ms. Giuffre that I could not locate or where the statements have been removed.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page407 of 883 f. There are sites that hosted the articles containing the statements made against Ms. Giuffre where the visitor data is not accessible or where I could not confirm the number of visitors. g. I did not consider the dissemination via social media platforms of articles containing the statements made against Ms. Giuffre. h. Many sites published multiple articles on multiple days that contained or referenced the statements made against Ms. Giuffre; however, I did not include these multiple publication dates in calculating unique daily visitors. 1. I did not include unique daily visitors to articles that link from that article to one or more of the articles containing the statements made against Ms. Giuffre. J. Finally, I did not include the counts of those who may have been searching and seen the statements made against Ms. Giuffre in the search results listing. V. BACKGROUND WEB ANALYTICS FOR TRAFFIC ANALYSIS 15, In the course of forming this opinion, I implemented numerous web analytics and related techniques commonly used in the industry. In order to more clearly discuss these techniques, I define the following terms: ® Direct Traffic: visitors to a website that come from entering a website link into a browser location bar (e.g., not coming via a link on another website). e Dissemination: the act of spreading or the circulation of information or articles. e Domain: a specific Internet website that are administered as a unit and defined by an Internet Protocol (IP) address.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page408 of 883 ® Reach: the percentage or number of people who visit a website out of the total targeted population. e Referral Traffic: visitors to a site that come from websites other than search engines. e Repeat Visits: visitor traffic to a website in a given period that just includes multiple visits from the same set of IP addresses (1.e., IP addresses with more than one visit); provides a count of the people who have visited a site more than once in a given period. An individual is usually defined by a combination of IP address and browser within a given period but can also be defined by more sophisticated methods. e Search Engine: a program and associated hardware and processes that allows people to find information on the Web, typically via the submission of queries consisting of terms. e Search Traffic: visitors to a site that come from search engines rather than from other websites or via direct navigation. ® Search: a submission of a query to a search engine, usually in the form of terms forming a query. @ Share: sharing of an article or webpage typically via some social media platform. e Social Media: content that 1s shared via a social networking website. ® Unique Visits: visitor traffic to a website within a given period that includes only the first visit (1.e., subsequent visits are ignored), which excludes repeat visits; provides a count of the individuals who have visited a site in a given period.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page409 of 883 e Unique Daily Visitors: visitor traffic to a website who visits a site at least once 1n a given 24-hour period. Each visitor, to the site, is counted once during the reporting period, which means it excludes repeat visits; provides a count of the individuals who have visited a site on a given day. e Visits: a count of all the traffic to a website in a given period, including both unique and repeat visits. e Web Analytics: the measurement, collection, analysis and reporting of web data. VI. METHODOLOGY 16. I was asked to determine the dissemination of articles containing the statements made against Ms. Giuffre. 17. In forming my opinion, I utilized accepted web analytics and related methodologies in developing my assessment. 18. To that end, I employed various publicly available online analytic services, as well as some subscription-based services in conducting my research, including: e Alexa: an online service that provides web traffic data and analysis. e Compete: an online service that provides web traffic data and analysis. e Google Keyword Tool: an online service that provides the number of searches for a given set of keywords in a given month on the Google search engine. e Google Trends: an online service that shows how often a particular term 1s relatively searched on the Google search engine in a given period. e SimiliarWeb: an online service that provides web traffic data and analysis. e SpyFu: an online service providing search data and analytics, including for both paid (1.e., advertisements) and organic (1.e., natural or algorithmic) channels. e W3Snoop: an online service that provides web traffic data and analysis.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page410 of 883 19. These tools offer a variety of data and analysis services, and they are frequently utilized by industry professionals in the search engine optimization, web analytics, and search engine marketing fields for market, customer, and competitive analysis. Furthermore, where possible, I did my own assessments, as outlined below, in order to validate the data and analysis results. 20. I also utilized search engines, primarily Google and Bing, to assess the dissemination of articles containing the statements made against Ms. Giuffre. DN. Whenever possible, I used multiple data sources, which 1s a data verification technique known as triangulation”, where one uses multiple and disparate sources for analysis and then compare the results from the separate analysis. If the results are similar, it reinforces the conclusion that the overall data analysis 1s valid. 22; In all of my assessments, I have used the most conservative numbers, meaning that I use the smallest value in arriving at the dissemination of articles containing the statements made against Ms. Giuffre. If I had not employed this conservative estimate, the number of potential dissemination of the articles containing the statements made against Ms. Giuffre would be 102,740,816 (1.e., more than 102 million) daily unique visitors. 23. In situations where I believed that I could not adequately verify the number of individuals or did not have confidence in the numbers in those situations, I did not include those numbers in the calculation of daily unique visitors. 24: My analysis 1s based on my experience, training, knowledge, and education and is formed through the application of that experience, training, knowledge, and education in the e Triangulation (social science) http://en.wikipedia.org/wiki/Triangulation %28social_science%29 9

Case 18-2868, Document 283, 08/09/2019, 2628241, Page411 of 883 principles of web data collection, web analytics, web search, search engines, web sites, and related areas. VII. DISSEMINATION OF THE STATEMENTS MADE AGAINST MS. GIUFFRE 2D: My opinion 1s that articles containing the statements made against Ms. Giuffre have been disseminated to at least 115 online media and others sites in 178 separate stories or articles with a combine 66,909,965 unique daily visitors. 26. This is a conservative estimate, and it is more likely than not, the statements have received wider dissemination due to factors such as: a. I used a set of online websites (115) to calculate the dissemination of articles, and it 1s reasonable that I have not located all references to the statements made against Ms. Giuffre by the time of the submission of this report. So, there may be more sites with articles containing the statements made against Ms. Giuffre that are not included in my calculations. b. My focus of analysis was the online dissemination of the statements made against Ms. Giuffre. Therefore, I examined only online sources and not dissemination of the statements made against Ms. Giuffre via print or broadcast media. It is reasonable to assume that the statements made against Ms. Giuffre were disseminated via these other channels. C. I have not attempted to measure face-to-face dissemination of the statements made against Ms. Giuffre. Therefore, these sources of dissemination are not included in the count of daily unique visitors. d. I did not have access to certain online sources where the statements against Ms. Giuffre may have been disseminated (e.g., email messages, social media messages, 10

Case 18-2868, Document 283, 08/09/2019, 2628241, Page412 of 883 articles behind firewalls, etc.). Therefore, these sources are not included in the count of daily unique visitors. e. There may be sites that have hosted articles containing the statements made against Ms. Giuffre where the articles have been removed. Therefore, I did not include these sites in my calculation of the unique daily visitors. f. There are sites where the visitor data is not accessible or where I could not reasonably check the number of visitors. In these cases, even though I had confirmed the site had posted one or more articles containing the statements made against Ms. Giuffre, I did not include these sites in my calculation of the unique daily visitors. g. I did not consider the dissemination via social media platforms of articles containing the statements made against Ms. Giuffre. h. Many sites published multiple articles on multiple days that contain or reference the statements made against Ms. Giuffre; however, I did not use these multiple articles from the same site with different publication dates in my calculations in determining the number of daily unique visitors who have been exposed to the articles containing the statements made against Ms. Giuffre. i: I did not include articles that link to one or more of the articles containing the statements made against Ms. Giuffre. Unless the article directly referenced the statements made against Ms. Giuffre, I did not include it in my analysis. 1. Finally, I did not include people who may been searching and may have seen the statements made against Ms. Giuffre in the search results, without needing to visit the actual articles posted on the websites. 11

Case 18-2868, Document 283, 08/09/2019, 2628241, Page413 of 883 VIL. METHODOLOGY TO DETERMINE THE DISSEMINATION OF THE STATEMENTS MADE AGAINST MS. GIUFFRE 27. [have been informed that the statements made against Ms. Giuffre were originally contained in an email message from Mr. Ross Gow’, of Acuity Reputation, acting on behalf of Ms. Maxwell, that was sent on 2 January 2015 at 8:38 pm‘ to, based on the email addresses”, people at The Mail Online®, The Independent’, The Mirror®, The Times’, and the BBC'®. The email message from Mr. Gow contained the statements made against Ms. Giuffre. A screen shot of the email message is shown in Figure 1. 28. Figure 1: Email message from Mr. Ross Gow containing the statements made against Ms. Giuffre. 3 GM_00068 (Gow E-Mail) * IT am assuming, based on the location of Mr. Gow’s company, Acuity Reputation, that this is date-time stamp for the United Kingdom. > Note: For some reason, the contact at the Mail Online is on the cc: line, while the other recipients are in the to: line. Also, the email message is sent to two recipients at the BBC. ° https://en.wikipedia.org/wiki/Mail Online ’ https://en.wikipedia.org/wiki/The Independent * https://en.wikipedia.org/wiki/Daily Mirror ” https://en.wikipedia.org/wiki/The_ Times ' https://en.wikipedia.org/wiki/BBC_ News 12

Case 18-2868, Document 283, 08/09/2019, 2628241, Page414 of 883 From: <ross@acuityreputation.com> Date: 2 January 2015 at 20:38 Subject: Ghislaine Maxwell To: Rossacuity Gow <ross@acuityreputation.com> bec: martin. robinson@mailonline.co.uk, P.Peachey@independent.co.uk, nick.sommerlad@mirror.co.uk, david.brown@thetimes.co.uk, nick.alway@bbc.co.uk, jo-anne pugh@bbc.co.uk To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts - so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschowitz is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. Sent from my BlackBerry® wireless device 29. [have been informed that the statements made against Ms. Giuffre were confirmed by Ms. Maxwell in a news article and video!! aired on 5 January 2015, which I have established by reviewing the video referenced in the news article’. '' GIUFFRE001120 "2 http://www.nydailynews.com/news/world/alleged-madame-accused-supplying-prince-andrew-article-1.2065505 13

Case 18-2868, Document 283, 08/09/2019, 2628241, Page415 of 883 30. Additionally, on 8 January 2015, agents reportedly acting on behalf of Ms. Maxwell made statements that the allegations against her were a “web of lies and deceit’, which are similar to the statements made against Ms. Giuffre in the message from Mr. Gow. 31. Similarly, on 1 February 2015, like statements were quoted as “These allegations are untrue and defamatory”! , which are similar to the statements made against Ms. Giuffre in the message from Mr. Gow. 32, Based on my investigation and research, news stories, articles, and postings containing direct reference to or quotes from the statements made against Ms. Giuffre appeared the same day (1.e., 2 January 2015) as the email from Mr. Gow, with several news organizations and other sites publishing other articles containing direct reference to or quotes from the statements made against Ms. Giuffre in the immediately following days. News articles containing direct reference to or quotes of the statements made against Ms. Giuffre have continued to appear in news articles and other postings nearly up to the date that I submitted this report. 33. A timeline of events relating to the dissemination of the statements made against Ms. Giuffre is shown in Figure 2. 34. Figure 2: Timeline of events relating to the dissemination of the statements made against Ms. Giuffre from 2 January 2015 onwards. 13 https://www.thesun.co.uk/archives/news/6754/prince-andrews-pal-ghislaine-groped-teen-girls/ 4 http://www.mirror.co.uk/news/uk-news/prince-andrews-pal-ghislaine-maxwell-5081971 14

Case 18-2868, Document 283, 08/09/2019, 2628241, Page416 of 883 Duringthe month of January, considerable news coverage with articles referencing the statements made against Ms. Giuffre appearing ina variety of news outlets, including The Daily Ms. Maxwell confirms the statements made against Ms. Mail, the New York Daily News, and Page Six. Giuffre ina New Daily News video on 5 January 2015 The first news articles referencing the statements made against Ms. Giuffre appear on 2 January 2015 statements made against Ms. Giuffre appearingina variety of news outlets from February through April, | | I I | | ! Continued news coverage with articles referencing the | | | | including The Guardian and BBC. | | er Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr 2015 2015 2015 2015 2015 2015 £2015 2015 £2015 #42015 °#4«.2015 2015 2016 2016 2016 ” 2016 = statements. made against Ms. Giuffre from February through April., including Reuters, Yahoo!News, and AOL Duringthe month of January, extensive news coverage with articles referencing the statements made against Ms. Giuffre appearing News. inavariety of news outlets, including The Daily Mail, the Huffington Post, the International | | | | | Continued news coverage with articles referencing the | | | | Independent, The Mirror, The Times, and the BBC on 2 January 2015 at &:38 pm. Duringthe month of September, considerable news coverage with articles referencing the Business time, The Mirror, The Guardian, The statements made against Ms. Giuffre appearing Daily Record, The Express, The Irish Times, the ina variety of news outlets, including The Daily New York Daily News, The New Zealand Herald, Mail, The Mirror, the New York Daily News, The Telegraph, The Daily Beast, Radar Online, am < ec £ Oo fe = am oo Li] 8 | 4 = oO WW oO 4 m = = a i ui at ui c a Bo ol am Td Li] E Wl 4! ec am E uw 4 oa aa Wi wm = et Bo ec = i] 4 c o Wd a E a ua a = am wi = oO a _ = Newsday, and Page Six. and Page Six. 2). Concerning the procedure employed in determining the dissemination of the statements made against Ms. Giuffre, nearly every major news site!> that I investigated, along with other specific news sites in the United States, the United Kingdom, Canada, and Australia, as well as other countries, have carried some aspects of the overall story related to Ms. Giuffre and/or Ms. Maxwell, or other parties involved. 36. In fact, there are tens of thousands of news articles and postings concerning the general story from news outlets worldwide, with combined potential viewership in the multimillions, as searches on the major search engines, such as Google and Bing, show. 'S Including the largest online news sites, such as Yahoo! News, Google News, Huffington Post, CNN, NY Times, Fox News, NBC News, Daily Mail, Washington Post, The Guardian, Wall Street Journal, ABC News, BBC News, USA Today, LA Times (see http://www.ebizmba.com/articles/news-websites) 15

Case 18-2868, Document 283, 08/09/2019, 2628241, Page417 of 883 37. However, I was not interested in news articles that just discussed the story in general or other aspects of the story. Also, I was not interested in those articles where Ms. Maxwell or those acting on her behalf, such as Mr. Gow, would just generally deny the allegations in the complaint’®. I was specifically interested in only those articles that referenced directly or quoted the statements made against Ms. Giuffre in the 2 January 2015 email message from Mr. Gow, Ms. Maxwell’s subsequent confirmation of the statements, or similar statements as those in the message from Mr. Gow. Naturally, this narrow focus 1s a smaller subset of news articles than are the articles addressing the overall story. 38. To isolate these articles of interest, I generated a series of 10 queries!’ that specifically targeted news articles from the case that addressed the statements made against Ms. Maxwell (e.g., Ghislaine Maxwell obvious lies) to retrieve a set of articles that directly related to the statements made against Ms. Giuffre'®. I employed a modified snowball technique’, starting with one seed query, adding and modifying terms, until I was not retrieving new results. I also located some articles via navigating from the set of retrieved articles. 39. I set the search range date from 2 January 2015 onward, so articles prior to that date were not included in the search results. For each article used in my analysis, I also verified the date that the article was published to ensure it was published on or after 2 January 2015 and that the articles directly referenced in some way the statements made against Ms. Giuffre. 40. An example of a search engine results page in response to one of these queries 1s shown in Figure 3. ‘© Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-cv-07433. '! Ghislaine Maxwell obvious lies, Ghislaine Maxwell Roberts obvious lies cnn, Ghislaine Maxwell Virginia Roberts, Giuffre Maxwell obvious lies, new york daily news alleged madam andrews, Prince Andrew Maxwell Roberts, Prince Andrew obvious lies, prince andrew's sex slave scandal who is maxwell, Ross Gow obvious lies, sex slave obvious lies. 'S Tn addition to the queries, I located some articles via direction navigation. ' https://en.wikipedia.org/wiki/Snowball_ sampling 16

Case 18-2868, Document 283, 08/09/2019, 2628241, Page418 of 883 4). Figure 3: Google News search results for the search Ghislaine Maxwell obvious lies with a date delimiter beginning on 2 January 2015. Google Ghislaine Maxwell obvious lies § cy All Images News Videos Shopping More ~ search tools All news Jan 2, 2015 — Today sorted by relevance Clear Socialite wants defamation lawsuit by 'sex slave’ tossed 1 New York Daily News - Jan 15, 2016 Ghislaine Maxwell's lawyers are pushing to dismiss a defamation i lawsuit brought ... of being pimped out to Epstein were “shown to be untrue” and “obvious lies. Sex-Trafficking Denials Aren't Libel, Brit Says Courthouse News Service - Jan 14, 2016 Ghislaine Maxwell denies calling Virginia Roberts a liar Daily Mail - Jan 15, 2016 Lawyers for British Socialite Accused of Pimping 'Sex Slave’ To ... Jewish Business News - Jan 15, 2016 Alleged Epstein madam denies calling teen ‘sex slave’ a liar Highly Cited - Page Six - Jan 14, 2016 Explore in depth (8 more articles) ) Jeffrey Epstein sex slave accuser sues Brit socialite New York Daily News - Sep 21, 2015 Ghislaine Maxwell, after walking out the side door of her E65St. townhouse in ... cites statements by Maxwell's spokesman calling Giuffre's claims “obvious lies.”. 42. I then personally verified that each article, by reviewing each article, used in my analysis directly referenced in some way the statements made against Ms. Giuffre. 43. So, articles relating to the overall story that did not mention Ms. Maxwell’s statements made against Ms. Giuffre were not included in the analysis. Articles relating to the overall story that referred to Ms. Maxwell simply denying the charges were not included. 44. [also personally performed a site search”? of the top 15 online media sites worldwide?! of articles related to the case, and I reviewed the results to identify if any of these °° https://www.google.com/advanced_ search *! Yahoo! News, Google News, Huffington Post, CNN, NY Times, Fox News, NBC News, Daily Mail, Washington Post, The Guardian, Wall Street Journal, ABC News, BBC News, USA Today, LA Times (see http://www.ebizmba.com/articles/news-websites) 17

Case 18-2868, Document 283, 08/09/2019, 2628241, Page419 of 883 articles referred to the statements against Ms. Giuffre. I also did the same for many countryspecific news sites in the United States, the United Kingdom, Canada, and Australia. 45. In the end, I had a set of 178 online news and other articles from 2 January 2105 to the date that I filed this report that specifically referenced the statements made against Ms. Giuffre to conduct my analysis, as outlined below. 46. Each of these 178 online articles was posted online. The 178 online articles were distributed among 115 unique domain websites (1.e., some websites posted multiple articles that contain the statements made against Ms. Giuffre). These 115 domains are: http://beforeitsnews.com http://boltonbnp. blogspot.com http://businessnewsusa.org http://dukefmduluth.com http://dukefmfargo.com http://home.bt.com http://jewishbusinessnews.com http://jewishnews.timesofisrael.com http://kdal610.com http://kfgo.com http://motivatornews.com http://mrharrywales.tumblr.com http://muhammad-ali-ben-marcus.blogspot.com http://news.sky.com http://news.trust.org http://newsbite.it http://newstoday.club http://normanfinkelstein.com http://onewayempire.com http://pagesix.com http://planetinvestigations.com http://softwaresuites.ne http://thisviral.com http://townhall.com http://ugandansatheart.blogspot.com http://uk.reuters.com http://whatiswrongwiththispicture2012.blogspot.com http://whbl.com http://whtc.com 18

Case 18-2868, Document 283, 08/09/2019, 2628241, Page420 of 883 http://wibqam.com http://wifc.com http://wincountry.com http://wkzo.com http://worlddailynews.info http://wsau.com http://wtaq.com http://wtvbam.com http://www.anorak.co.uk http://www.aol.co.uk http://www. asianimage.co.uk http://www.bailiwickexpress.com http://www.bannednews.net http://www.bbc.com http://www. belfasttelegraph.co.uk http://www.bournemouthecho.co.uk http://www.businessinsider.com http://www.business-standard.com http://www.capitalbay.news http://www.clactonandfrintongazette.co.uk http://www.courthousenews.com http://www.dailylife.com.au http://www.dailymail.co.uk http://www.dailyrecord.co.uk http://www.darkpolitricks.com http://www.dudleynews.co.uk http://www.eveningtimes.co.uk http://www.express.co.uk http://www.faceiraq.com http://www. ghanagrio.com http://www.ghanareview.com http://www. govtslaves.info http://www.headlines-news.com http://www. huffingtonpost.co.uk http://www.ibtimes.co.uk http://www.independent.ie http://www. infiniteunknown.net http://www.1iol.co.za http://www. irishexaminer.com http://www. irishmirror.ie http://www. irishtimes.com http://www.itv.com http://www.lancashiretelegraph.co.uk http://www.lse.co.uk 19

Case 18-2868, Document 283, 08/09/2019, 2628241, Page421 of 883 http://www.mgtowhq.com http://www.mitror.co.uk http://www.msn.com http://www.nationalenquirer.com http://www.newindianexpress.com http://www.newscopia.com http://www.newsday.com http://www.newsgrio.com http://www. nigeriadailynews.news http://www.nydailynews.com http://www.nzherald.co.nz http://www.oneworldofnations.com http://www.oxfordmail.co.uk http://www.pressreader.com http://www.reuters.com http://www.scmp.com http://www.scotsman.com http://www.somersetlive.co.uk http://www.srnnews.com http://www.swindonadvertiser.co.uk http://www.telegraph.co.uk http://www.theargus.co.uk http://www.theboltonnews.co.uk http://www.thedailybeast.com http://www.thetelegraphandargus.co.uk http://www.thetruthseeker.co.uk http://www.twimovies.news http://www.westernmorningnews.co.uk http://www. wirralglobe.co.uk http://www. yorkpress.co.uk http://www. yorkshirepost.co.uk https://blairzhit.wordpress.com https://bol.bna.com https://ca.news.yahoo.com https://circusbuoy.wordpress.com https://quartetbooks.wordpress.com https://thetruth24.info https://www.eveningtelegraph.co.uk https://www.theguardian.com https://www.thesun.co.uk https://www.yahoo.com http://ferddyjay.blogspot.com 20

Case 18-2868, Document 283, 08/09/2019, 2628241, Page422 of 883 47. As seen from the list of domains that have published articles or stories containing references to the statement made against Ms. Giuffre, many of these domains are those of major news organizations or sources, including AOL News, BBC, Huffington Post, International Business Times, Irish Times, MSN News, National Enquirer, New York Daily News, New Zealand Herald, Page Six, Radar Online, Reuters, The Daily Beast, The Daily Mail, The Express, The Guardian, The Mirror, The Sun, The Telegraph, Yahoo! News, etc. 48. I then used a variety of web analytics traffic services and other sources to get the unique daily visitor traffic for each of these domains. I used multiple services when available to verify the unique daily visitor traffic for each of these domains, as these traffic services may use different techniques to arrive at their traffic numbers. 49. In cases of conflicting unique daily visitor traffic numbers, I utilized the most conservative (1.e., smallest) number. 50. In cases where I determined I could not get unique daily visitor traffic numbers or the unique daily visitor traffic were not reliable, in my opinion, I did not include the unique daily visitor traffic numbers for that domain in the numbers. This usually occurred for the sites with a smaller number of daily visitors or sites with an extremely large number of daily visitors. S1. Unique daily visitors measure 1s an industry standard web analytics metric for measuring people that visit a website in a given day, also known as unique audience”. It is generally averaged out over multiple days with a given period, such as week or month, as there are normal daily fluctuations. 52: Table 1 shows the unique daily visitor traffic for the listed domains that posted articles or stories referencing the statements made against Ms. Giuffre and the associated unique *? http://digitalmeasurement.nielsen.com/files/metrics-guidelines.pdf 21

Case 18-2868, Document 283, 08/09/2019, 2628241, Page423 of 883 daily visitor traffic for each of those domains, along with number of articles containing the statements made against Ms. Giuffre posted on that site. a, Table 1: Domains that published articles or stories containing the statements made against Ms. Giuffre with the domain’s number of unique daily visitors and the number of articles containing the statements made against Ms. Giuffre published on that domain from 2 January 2015 to the date that I filed this report”’. Domain Unique | Number of No. Domain Visitor Traffic Articles Dail Published |_1| http://beforeitsnewscom 938,333 PO __2 | http://boltonbnp.blogspot.com® | __3 | http://businessnewsusaorg* | 4 | http://dukefmduluthcom® 0 (—s [http:/dukefinfargo.com’—S—SST 3S | 6 | http://homebtcom 800,000 | 8 | htip:7jewishnews.timesofisraelcom? «(| id | 9 | http:/Akdal6l0.com ST to http//kfeocom —SSSOS—S—SSSSSCS ~SS—S~ST.600 Si 11 [http:/motivatomewscom? ———S—S—S—S—SOS—C | 12 | http:/mrharrywales.tumblrcom® PT http://muhammad-ali-ben-marcus.blogspot.com* es —ee—tiL 15 [http:/inews.trustorg® ——SCS~—S—S~—SsSss—‘ | 16 |http/newsbiteit® _17 | http:/newstoday.club* | 18 | http:/normanfinkelsteincom | BT __19 | http//onewayempirecom® 21 [http:/planetinvestigationscom® —S~S—S 22 [hitp-softwaresuitesne™—————SSCS~SSSC 23 [httpthisviralcom®@ _——S—SS | 3S | 24 | http://townhallcom 2386667] | 25 | http://ugandansatheartblogspotcom® | 26 http//ukreuterscom ———SSOS~S~SSSCSCS~—wS SPC ee) http://whatiswrongwiththispicture2012.blogspot.com* 23 Note: Some outlets, I was able to get self-reported visitor numbers, such as the https://www.theguardian.com. De

The text on this page is estimated to be only 39.09% accurate

Case 18-2868, Document 283, 08/09/2019, 2628241, Page424 of 883 Domain Unique | Number of No. Domain Visitor Traffic Articles Jail Published 30 [http:/wibgamcom®™ ———SSOSCS~SSOSCOCC 31 [hitpywifecom——SSOS—~—SSSSSS~=O 32 [hitp:/awincountrycom ——SSSS~—SOB | 33 [hitp:/wkzocom ———SSOS—SSSSSSSCC SSB | 34 | http://worlddailynewsimfor —‘([) 35 [hitp:/wsancom —SCSC~—SC—SSSSCSCS~tSB PS 36 [hipwageom® SSOS—~—SSSSSS 37 [http:/iwivbameom® SCS 38 [http:/www.anorakeouk SSS 40 [http://wwwaasianimagecouk ———S~SCSSSS~«diOB PC a1 [ http://www.bailiwickexpress.com ——S—S~SSSCS~iCSS | a2 [hitp:/www.bannednewsne® SCS 43 [hitp:/www.bbecom SS 12,950,000 a4 [http:/iwww.belfasttelegrapheouk® Ss 45 [ http://www.bourmemouthecho.couk® Si | 46 [http:/www.businessinsidercom ——S~wSS~«S«8GST | a7 [http:/www.business-standardcom?’ S| a8 [hitp:/www.capitalbaynews* ———SCSOSCSCSCSCSCSC—C 49 [ http://www. clactonandfrintongazettecouk ———*([| S| 51 [http:/www.dailylifecomau SY SSS~—«RO.00| 52 [http://www.dailymailcouk ———S—S~d—SS~i 76,667 SO 54 [ http://www. darkpoliticks.con®™ S| 55 | http://www.dudleynews.couk® Si | 56 [http://www.eveningtimescouk ———~«dY~—S—S~S~S SST PSC 57 [hitp:/iwww.express.couk ———S~S~S~S~SSS~«i BGT 58 [hitp://www.faceiragcom® ———S—~—SCS [59 [hitp://www.ghanagriocom’ SS 60 [hitp://www.ghanareviewcom? SCS SSS 61 [http:/www.eovislavesinfo® SCS SSCS 62 [http://www-headlines-newscom®™ —~—S | 65 [http://www.independenti® SSCs) 66 [hitp://www.infiniteunknownnet SY SSS—BS PC 67 [hitpswwwioleoza—SSCS~STSS~—i SGPC 23

The text on this page is estimated to be only 38.29% accurate

Case 18-2868, Document 283, 08/09/2019, 2628241, Page425 of 883 Domain Unique | Number of No. Domain Visitor Traffic Articles Dail Published | 68 | http:/www.irishexaminercom* CEC | 69 | hitpyiwwwirishmirorie | 100,000 3 | 70 | http:/www.irishtimescom —CiLC (823333 __72 | http:/Awww.lancashiretelegraphcouk® | | 73 | http//wwwisecouk —C—“‘LSC‘#‘ZWOOOP 74 |hitp/iwww.mgtowhgcom* | 75 | bttp:/www.mirror.couk —CiL:CSC*3«» 860,000] 10S [76 [hitp:/wwwamsncom? | | 77 | http:/Awww.nationalenquirercom ss —CidECCCSC~i‘iCOO YF | 78 | http:/www.newindianexpresscom* | | 79 | http:/www.newscopiacom* | | 80 | http:/www.newsdaycom —‘LCSC( S825 | 81 | http:/www.newsgriocom ——“—‘“;éi‘irSC“‘(SSCd‘SSO | 83 | http://www.nydailynewscom —‘LCSCSSCi2« 00,000 | 84 | http:/www.nzheraldconz —C‘LC(“(‘(SSC‘“*C‘éBGSOGTZ JF [85 | hitp:/www oneworldofvations cou? [Js] 6 | iinwwostinies os | 88 | http//wwwreuterscom —‘LCS CC 3863,333 a | 90 | http:/www.scotsman.com CSC 25393 [91 [hitp://www.somersetlivecouk® ———S—~—~—C— | 92 | http:/www.smnews.com* si [94 [hitp:/iwww.telegrapheouk ———S=~S~SSSC*~«CSiSOGT Cd [96 [http://www.theboltonnewscouk ———S~SSSCS~*~«OCT SSC [98 [hitp://www.thetelegraphandarguscouk ——=«dCSCi‘“‘*‘*éwCCT*YSOSC*‘“‘(CS [99 [http://www.thetruthseeker.couk ——S—S~S~S SSCS STC 100 [hitp:/www.twimoviesnews™———SS—~—SsSC—S 101 [ hitp://www.westermmomingnewscouk® ——S—S<d| Sf 102 [hitp://www.wiralglobecouk® ———S=~—~—SsSS | 103 | http:/www.yorkpresscouk* | 104 [http://www.yorkshireposteouk® —————S—S—~—SCS 105 | https://blairzhit. wordpress.com’ ——S—S—SCSY 3S 106 [https:/bolbnacom® —SSOSC~—SS SC 107 [hitps://eanewsyahoocom’ ———S—S=~—SsS—SsSSSC Pd 24

Case 18-2868, Document 283, 08/09/2019, 2628241, Page426 of 883 Domain Unique | Number of Domain Visitor Traffic Articles Dail Published | 108 | https://circusbuoy.wordpress.com* Sl ll | 109 | https://quartetbooks.wordpress.com* En 7110 | https:7thetruth24.info" —— 7111 [ htips://www.eveningtclegrapheouk® ——S—S—~dS 7112 [https://www.theguardiancom —__——S—S~SSS—S~« TG CSC~* 7113 [ https://www.thesun.couk SOS SS~«ii 9 GTP "114 [https:/www.yahoocon® SSCS 7115 | http:/ferddyjay.blogspoteom®™ SCS Sd Pot C‘“‘(CC*dSC(C~«SIN-DGS | * - Unique daily visitor traffic not available P Unique daily visitor traffic not verifiable 54. — ILused each domain’s unique daily visitor count to calculate the dissemination of the articles containing the statements against Ms. Giuffre to various websites and potentially to visitors to that site (1.e., as visitors to the news sites, these individuals could have been exposed to the articles containing the statements made against Ms. Giuffre), using the unique daily visitor number only once for each domain, regardless whether that domain published more than one article referring to the statements made against Ms. Guiuffre. IX. RESULTS FOR ANALYSIS OF THE DISSEMINATION OF THE STATEMENTS MADE AGAINST MS. GIUFFRE 55. Based on my analysis as outlined above, my opinion is that the statements against Ms. Giuffre have been disseminated to at least 115 online media and other sites with 178 stories or articles with a combined 66,909,965 (more than 66 million) unique daily visitors traffic. 56. I note that for many of the 178 articles containing the statements made against Ms. Giuffre, one could get gist of the story of the article directly from the article headline. I point this out as it is well known that people skim online news sites”*, so titles such as these *4 See for example: Aikat, D. News on the web: usage trends of an on-line newspaper. Convergence: The International Journal of Research into New Media Technologies 4, 4 (Dec. 1998), 94-110. 25

Case 18-2868, Document 283, 08/09/2019, 2628241, Page427 of 883 would have substantial impact on visitors to that site. Examples of such articles headlines (examples of actual headlines from the 178 articles) are: e British socialite to face Epstein accuser's defamation lawsuit e Alleged Epstein madam denies calling teen ‘sex slave’ a liar e Sex-Trafficking Denials Aren't Libel, Brit Says e U.S. woman who claimed she was forced to have sex with Prince Andrew sues British socialite for denying that she recruited her to be a sex slave e British 'madam' accused of recruiting teenage ‘sex slave' Virginia Roberts for Prince Andrew's friend Jeffrey Epstein denies calling her a liar e Ghislaine Maxwell denies calling Virginia Roberts a liar e Bill Clinton Pedophile Sex Scandal: Socialite Denies Calling ENQUIRER Source A Liar, Woman files defamation suit against British publishing magnate e Jeffrey Epstein sex slave accuser sues Brit socialite for defamation e Lawyers for British socialite accused of pimping ‘sex slave' to Jeffrey Epstein push to dismiss defamation lawsuit. ee This is a conservative estimate, and more likely than not, articles containing the statements made against Ms. Giuffre have been disseminated to more individuals. X. WHY THE ESTIMATE IS LOW 58. This (66,909,965 individual unique daily traffic) is a conservative estimate, and it is more likely than not, the statements have received wider dissemination due to factors such as: a. Although I spend considerable effort to locate published articles that contained the statements made against Ms. Giuffre, it is reasonable to assume that I have not located all such articles by the time of the submission of this report. So, there are possibly more 26

Case 18-2868, Document 283, 08/09/2019, 2628241, Page428 of 883 sites with articles containing the statements made against Ms. Giuffre that are not included in my calculations, which would increase the dissemination of the articles. b. The focus of my analysis was the dissemination of online articles containing the statements made against Ms. Giuffre, and I examined only online sources and not print or broadcast media. Many of the media outlets that I did identify have consider print distribution’, which are not included in my calculations, for example, such as: e The Sun (print circulation) 1,741,838 e Daily Mail (print circulation) 1,562,361 e The Daily Telegraph (print circulation) 472,936 e The Times (print circulation) 402,752 e The Guardian (print circulation) 161,152 C. In my analysis, I did not attempt to measure face-to-face dissemination that may have occurred after individuals may have read articles containing the statements made against Ms. Giuffre, which would increase the count. d. Naturally, I could not access certain online sources where the statements made against Ms. Giuffre may have been disseminated (e.g., email messages, social media messages, articles behind firewalls, etc.). Therefore, these numbers are not included in my calculations. e. Also, there are possibly sites that have hosted articles containing the statements made against Ms. Giuffre where the articles have been removed. Therefore, they are not included in my calculations. es www.theguardian.com/media/2016/mar/17/independent-mirror-express-and-star-suffer-sharp-fall-in-traffic Zi

Case 18-2868, Document 283, 08/09/2019, 2628241, Page429 of 883 f. For sites where one or more of the articles containing the statements made against Ms. Giuffre are posted but where I could not locate or not determine reliable daily unique visitor traffic, I have not included these sites in my calculations. There are 59 (of the 115 sites, 51.3%) where I could not get or not get verifiable traffic data. For example, the traffic numbers for the MSN News (Microsoft) and Yahoo! News are not separated by news and other services, such as search, so I did not include these in the number of people to which the articles containing the statements made against were disseminated. g. I did not include the dissemination of the articles containing the statements made against Ms. Giuffre directly to social media platforms. However, many of the articles containing the statements made against Ms. Giuffre do include counts of the number of times that individuals shared the article to a social media networks, as shown in Table 2. 1. Table 2: Number of social media shares by published article containing the statements made against Ms. Giuffre. [Shares[ Date [——~—~—SDomam SSS 1600 4000 130 15 6436 55 56 i813 560 24 54 198 198 28

Case 18-2868, Document 283, 08/09/2019, 2628241, Page430 of 883 /Shares| Date | Domain, 177 193 105 192 7 1052 | 96 | S-Jan-15 | http://www.nydailynews.com 256 http://www.dailyrecord.co.uk (33,758f ll. As shown in Table 2, the articles containing the statements made against Ms. Giuffre have been shared 33,758 times, mostly on Facebook. 111. Given that the median number of Facebook ‘friends’ is 200*°, this equates to a possible 6,751,600 individuals, in addition to the 33,758 individuals who originally shared °° http://www.pewresearch. org/fact-tank/2014/02/03/6-new-facts-about-facebook/ 29

Case 18-2868, Document 283, 08/09/2019, 2628241, Page431 of 883 the articles, to which the articles containing the statements made against Ms. Giuffre could have been disseminated, assuming these individuals are all unique and have not already read one of the articles. IV. However, I did not include these social media shares 1n my calculations. V. Since news article viewing follows a power law7’ distribution’®, there is no direct linear ratio of number of social media shares to readership. There is published research that does report average of views of an article on a news website and also average social media shares’. In a direct calculation with numbers from this article’, 23 articles views per social media share, using 33,758 social media shares, this would be 776,434 article views. However, this ratio would vary by website, number of daily unique visitors, type of news article, time for accumulating shares, and possibly other factors. Plus, this number would not account for the people receiving the social media share that viewed the title, post, and snippet but did not click on the share to view the article on the website, thereby undercounting views of the articles. V1. Also, given the topical nature of the underlying news story, one could expect lower social media sharing but higher article viewing, as people will tend to read articles on such topics privately but not share on social media*!. So, I would expect the social media number itself to be an undercount. h. I did not include articles that link to one of the articles containing the statements made against Ms. Giuffre in my calculations of dissemination. Unless the article °7 https://en.wikipedia.org/wiki/Power_law °8 See for example, Tatar, A., de Amorim, M. D., Fdida, S., & Antoniadis, P. (2014). A survey on predicting the popularity of web content. Journal of Internet Services and Applications, 5(1), 1. *? See for example, Castillo, C., El-Haddad, M., Pfeffer, J., & Stempeck, M. (2014, February). Characterizing the life cycle of online news stories using social media reactions. In Proceedings of the 17th ACM conference on Computer supported cooperative work & social computing (pp. 211223). ACM. *° Castillo, C., El-Haddad, M., Pfeffer, J., & Stempeck, M. (2014, February). Characterizing the life cycle of online news stories using social media reactions. In Proceedings of the 17th ACM conference on Computer supported cooperative work & social computing (pp. 211-223). ACM. >! See for example, Agarwal, D., Chen, B. C., and Wang, X. Multi-faceted ranking of news articles using post-read actions. In Proc. of CIKM, ACM (2012), 694-703. 30

Case 18-2868, Document 283, 08/09/2019, 2628241, Page432 of 883 directly mentioned the statements made against Ms. Giuftre, I did not include that article in my calculations. So, unless the linking article actually mentioned, referenced, or quoted the statements made against Ms. Giuffre, I did not include it in the calculations. 1. Many sites published multiple articles on multiple days that quoted or referenced the statements made against Ms. Giuffre; however, I did not use these multiple publication dates from the same site in my calculations of unique visitor traffic. If a domain published only one article containing the statements against Ms. Giuffre, then I directly used the unique daily visitors number. If a domain published multiple articles concerning the statements against Ms. Giuffre, I did not count the traffic for the subsequent articles containing the statements made against Ms. Giuffre, even though research shows that repeat traffic to websites is generally only about 30%°’, meaning that 70% of the traffic would be unique. However, I was not comfortable using this figure given the natural of these sites, which might have higher repeat visitors day-to-day. Therefore, I did not include the unique visitors to multiple articles in my calculations. J. Finally, I did not include the count of people who may been searching and may have seen the statements made against Ms. Giuffre in the search results, without needing to visit the actual articles, as shown in Figure 4. k. Figure 4: Example of search results with the statements made against Ms. Giuffre appearing in the result snippets, requiring no need to visit the articles themselves. *? Teevan, J., Adar, E., Jones, R. and Potts, M. (2006). History repeats itself: repeat queries in Yahoo's logs. In Proceedings of the 29th annual international ACM SIGIR conference on Research and development in information retrieval (SIGIR '06). ACM, New York, NY, USA, 703-704. 31

Case 18-2868, Document 283, 08/09/2019, 2628241, Page433 of 883 € C86 https://www.google.com/#q=Ghislaine+Maxwell+obvio Google Ghislaine Maxwell obvious lies 4 Ea) All images News Videos Shopping More + Search tools More images for Ghislaine Maxwell obvious lies Ghislaine Maxwell denies calling Virginia Roberts a liar | Daily Mail .. www ca co.uk/../Bntish-madam-accused- eee teenage-sex-sla... ¥ Datly Mail » Jan 15, 2016 - Ghislaine Max ade ae ese of recruiting Virginia Roberts as ... of Saying Roberts’ allegations weg ‘untrue’ and ‘obvious lies’ Ghislaine Maxwell still has connections despite link to Prince Andrew ... www.dailymail.co.uk/.../Ghislaine-Maxwell-s-link-sex-scandal-cour-papers... ¥ Daily Mail * lan GO te ; er ell stands accused of ‘procuring’ girls, including ... Ms Maxwell has called her claims ‘obvious lies’, while the Prince has put out British socialite to face Epstein accuser's defamation lawsuit | Reuters www.reuters.com/article/us-maxwell-defamation-lawsurt-idUSKCNOW34ZN * Reuters * Mar 1, 2016 socialite Ghislaine ell of def i for calling her allegations lies been "shown to be untrue.” and that n@r "claims are obvious lies Ghislaine Maxwell denies being a madam for paedophile Jeffrey ... ees co.uk >» News > World » Daily Express ell's original response to the lies and Gefamatory (The woman's) claims are obvious lies andBhould be treated as such and Jeffrey Epstein sex slave accuser sues Brit socialite - NY Daily News www nydailynews.com/. hetrey- epstein-sex-slave-accuser-sue.. * New York Daily News * sep 21, 2015 - She says Ghis - ncounters with the New York __ by Maxwell's spokesman calling Gaufre's claims “obvious lies Socialite wants defamation lawsuit by 'sex slave’ tossed - NY Daily News XI. ACCURACY OF THE —_TRAFFIC NUMBERS AND —_ ADDITIONAL VERIFICATION 32

Case 18-2868, Document 283, 08/09/2019, 2628241, Page434 of 883 59. Concerning the accuracy of the analysis, the number of domains where the statements made against Ms. Giuffre have been disseminated 1s reliable, as this 1s straightforward to verify (1.e., the article is either posted on a site or it is not). If anything, this is an undercount, as some domains, for example, may have removed such articles, making them no longer available. There are possibly articles containing the statements that I have not been able to locate by the time that I submitted this report. 60. Concerning traffic numbers for domains, a unique visitor is typically identified by an identifier stored 1n a text file, which is based on an individual computer’s browser, although more sophisticated methods are also being used. In locating traffic numbers for the domains, I used multiple services when available and attempted to verify via other sources. In case with varying traffic data, I utilized the most conservative (1.e., smallest) number available. 61. I also verified findings from my analysis via other methods and my own experience and training. For example, there are periods of increased publishing of articles containing the statements made against Ms. Giuffre and related stories. One would expect, increases in associated searching during these periods. Using the Google Keyword Tool, which provides search volume for search queries by month, I examined search volume from January 2015 to the date that I filed this report. There was an 54,518% increase in search volume for the keywords Virginia Giuffre Virginia Roberts Ghislaine Maxwell in January 2015, relative to the prior 7 months, in the US, and a 44,822% increase for the United Kingdom (UK) in January 2015, relative to the prior 7 months. This is in line with the increase 1n posting of articles during the same month*. So, one sees the expected increase in searching for key terms based on the increase posting of articles. 33 Note: I use the US and the UK as sample countries since there are aspect of the story that relate to each country. 33

Case 18-2868, Document 283, 08/09/2019, 2628241, Page435 of 883 62. Figure 5 shows increase in searching volume in January 2015 for the US and UK relative to the previous 7 months. 63. Figure 5: Increase in search volume in January 2015 for the US and UK relative to the previous 7 months for the keyphrase Virginia Giuffre Virginia Roberts Ghislaine Maxwell. 561 Average Searching Volume (June - Searching Volume (January 2015) Average Searching Volume (June - Searching Volume (January 2015) December 2014) XII SUMMARY 64. The statements made against Ms. Giuffre have been disseminated to at least 115 online media or other sites in 178 separate stories or articles with a combined 66,909,965 individual unique visitors from 2 January 2015 to the date that I filed this report, inclusive. More likely than not, this is a conservative estimate. 65. Right to Amend: Although I have had access to materials publicly available pertaining to claims in this dispute, I have not been able to review all the material by the deadline for completion of this report. I reserve the right to review and rely on any such material, including at the time of trial. I also reserve the right to issue a supplemental or an amended report if my review of such material results in any significant change or addition to my opinion. 34

Case 18-2868, Document 283, 08/09/2019, 2628241, Page436 of 883 Respectfully submitted, DATED: 09 September 2016 By Dr. Bernard J. Jansen Professor College of Information Sciences and Technology The Pennsylvania State University University Park, PA, 16802 Phone: 434-249-8687 Email: jjansen@acm.orq URL: http://ist.psu.edu/faculty pages/jjansen/ 35

Case 18-2868, Document 283, 08/09/2019, 2628241, Page437 of 883 Appendix A Curriculum Vitae Full Professor College of Information Sciences and Technology The Pennsylvania State University University Park, Pennsylvania 16802, USA Voice: +1-434-249-8687 Fax: 814-865-6426 Email: jjansen@acm.org LinkedIn: www.linkedin.com/in/jjansen/ Blog: http://jimjansen.blogspot.com/ Principal Scientist, Social Computing Group, Qatar Computing Research Institute (QCRI), Hamad Bin Khalifa University, Doha, Qatar Affiliate Appointment, Department of Computer Science and Engineering, The Pennsylvania State University Affiliate Appointment, Department of Industrial and Manufacturing Engineering, The Pennsylvania State University Director, Information Searching and Learning Laboratory, College of Information Sciences and Technology (ISL?), The Pennsylvania State University Current Advisory Boards e The Pennsylvania Technical Assistance Program (PennTAP) (http://penntap.psu.edu/) e CLAK Impressions (http://www.linkedin.com/company/clak-impressions) e = Innoblue (http://www .linkedin.com/company/innoblue) Research Research Goal: Increase the effectiveness and efficiency for accomplishing information tasks by improving the interaction among people, information, and technology Research Interests: | study the uses and affordances of the Web for information searching and ecommerce, with a focus on interactions among the person, information, and technology. Current active research areas are Web searching, information retrieval, keyword advertising, online marketing, and online social networking within the ecommerce domain. e Sponsored search and keyword advertising e Social media as an information source e Information searching and Web information retrieval Short Bio: Jim has authored or co-authored 250 or so research publications, with articles appearing in a multi-disciplinary and extremely wide range of journals and conferences. He is author of the book, Understanding Sponsored Search: A Coverage of the Core Elements of Keyword 36

Case 18-2868, Document 283, 08/09/2019, 2628241, Page438 of 883 Research Advertising (Cambridge University Press), author of the book Understanding User - Web Interactions Via Web Analytics, co-author of the book, Web Search: Public Searching of the Web, and co-editor of the book Handbook of Research on Weblog Analysis. Jim is a full professor with the College of Information Sciences and Technology at The Pennsylvania State University and a Principal Scientist in the social computing group of the Qatar Computing Research Institute, Hamad bin Khalifa University. He is a graduate of West Point and has a PhD in computer science from Texas A&M University, along with master degrees from Texas A&M (computer science) and Troy State (international relations). Jim is editor-in-chief of the journal, Information Processing & Management (Elsevier), a member of the editorial boards of seven international journals, former editor-in-chief of the journal, Internet Research (Emerald), and he has served on the research committee for the Search Engine Marketing Professional Organization (SEMPO). He has received several awards and honors, including an ACM Research Award and six application development awards, along with other writing, publishing, research, teaching, and leadership honors. He has served as a Senior Fellow at the Pew Research Center with the Pew Internet and American Life Project and a university expert with the National Ground Intelligence Center. He is a Principle Scientist at the Qatar Computing Research Institute. He has done several consulting projects (log analysis, statistical analysis) and expert witnesses cases (patent litigation, civil litigation, and class action suits) in the areas of keyword advertising, web analytics, co-registration, domain parking, webpage access, webpage history, and online advertising click fraud. Education Ph.D. Computer Science, August 1999 - May 1996 Texas A&M University, College Station, Texas 77843 Dissertation: A Software Agent for Performance Improvement of an Existing Information Retrieval System Advisor: Dr. Udo Pooch M.CS. Computer Science, May 1996 - June 1994 Texas A&M University, College Station, Texas 77843 Research Area: Network Performance and Monitoring M.S. International Relations, August 1994 - June 1992 Troy State University, European Division Research Thesis: National Competitive Advantage B.S. Computer Science, May 1985 - June 1981 United States Military Academy, West Point, New York 10996 Engineering Sequence: Electrical Engineering 37

Case 18-2868, Document 283, 08/09/2019, 2628241, Page439 of 883 Academic Appointments Current - 2014 Current - 2015 2014 - 2011 2014 - 2009 2012 - 2010 2009 - 2003 2003 - 2001 2000 - 1999 1999 - 1998 1998 - 1996 Full Professor, College of Information Sciences and Technology, The Pennsylvania State University, University Park, PA, 16802, USA. Principal Scientist, Qatar Computing Research Institute (QCRI), Hamad Bin Khalifa University, Doha, Qatar University Researcher, National Ground Intelligence Center, 2055 Boulders Road, Charlottesville, VA 22911 Associate Professor, College of Information Sciences and Technology, The Pennsylvania State University, University Park, PA, 16802, USA. Senior Fellow, Pew Internet and American Life Project, Pew Research Center, 1615 L Street, NW Suite 700 Washington, DC 20036 Assistant Professor, College of Information Sciences and Technology, The Pennsylvania State University, University Park, PA, 16802, USA. (Previously, School of Information Sciences and Technology) Instructor, School of Information Sciences and Technology, The Pennsylvania State University, University Park, PA, 16802, USA Lecturer, Computer Science Program, University of Maryland (Asian Division), Seoul, 104-022, Republic of Korea Assistant Professor, Department of Electrical Engineering and Computer Science, United States Military Academy, West Point, New York, 10996 Lecturer, Department of Electrical Engineering and Computer Science, United States Military Academy, West Point, New York, 10996, USA. Honors and Awards 2016 2016 President's Award for Engagement with Students, The Pennsylvania State University, University Park, Pennsylvania. 2015 Best Paper: Liu, Z. and Jansen, B. J. (2015) Subjective versus Objective Questions: Perception of Question Subjectivity in Social Q&A. 2015 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP15). Washington DC, p. 131-140. 31 Mar.-3 Apr. 2011 Teaching and Learning with Technology Fellow at Penn State (May 2011 — May 2012). Teaching research fellowship to develop subject-based learning apps that leverage cellular technology, the contextual (location-aware) attributes of mobile technology, and social media. See tlt.its.psu.edu/201 1/07/24/jim-jansen/ 38

Case 18-2868, Document 283, 08/09/2019, 2628241, Page440 of 883 Honors and Awards 2011 2010 2008 2008 2007 2004 2003 2003 2002 2002 Paper Award: The article, The Seventeen Theoretical Constructs of Information Searching and Information Retrieval, published in Journal of the American Society for Information Science and Technology selected as John Wiley Best JASIST Paper Award 2011 (see http://www.asis.org/awards/jasis_paper.html). Emerald Literati Network 2010 Award for Excellence for Outstanding Reviewer for the journal Internet Research (http://info.emeraldinsight.com/authors/literati/index.htm) Best Paper, Jansen, B. J., Zhang, M., and Schultz, C. (2008) The Effect of Brand on the Evaluation of IT System Performance. Proceedings of the Southern Association for Information Systems Conference, Richmond, VA, USA 13-15 March 2008 Presented with a Google Faculty Research Award ($50,000) Article selected as Highly Commended Winner at the Emerald Literati Network Awards for Excellence 2007. Spink, A. and Jansen, B. J. (2006) Searching multiple federate content Web collections, Online Information Review. 30(5), 485-495. Worldwide press coverage for book Web Search: Public Searching of the Web, coauthored with Dr. Amanda Spink. Including AP, Yahoo! News, CNN, MSN, and numerous other television, radio, Web, and print outlets. Worldwide press coverage and interviews 6/30/2003-7/3/2003 reference article: Jansen, B. J., and Spink, A. (2003) An analysis of Web pages retrieved and viewed, IC’03: Internet Computing: Web Mining Session, Las Vegas, 4-6 June, 2003. Including: BBC, Irish Radio, Washington Times, Psychology Today, and several U.S. radio stations. ISI Most Highly Cited Articles in Field of Web Searching for the manuscript Jansen, B. J., Spink, A., and Saracevic, T. (2000) Real Life, Real Users, and Real Needs: A Study and Analysis of User Queries on the Web, |Information Processing & Management. 38(2), 207-227. The article was identified in May 2003 by ISI Essential Science Indicators to be one of the most cited papers in the research area of Web Searching Behavior. Highly Commended Article invited for journal publication. Jansen, B. J. (2002) Towards Implementing a Cognitive Model of Searching, Proceedings of the ELearning 2002 Conference (Web Track), Montreal, Canada. 15-19 October. Two Crystal Awards of Excellence for outstanding software development in the communications field. 39

Case 18-2868, Document 283, 08/09/2019, 2628241, Page441 of 883 Honors and Awards 2002 2002 2002 2002 2001 2000 1998 1997 1992 1992 Books Worldwide press coverage and interviews 3/31/02- 4/5/02 reference article: Spink, A., Jansen, B. J., Wolfram, D., and Saracevic, T. (2002). From e-sex to e-commerce: Web search changes, IEEE Computer, 35(3), 133-135. Including: Associated Press, BBC, CBC, MSNBC, Wall Street Journal, New York Times, PC World, CNN, Chinese People’s Daily, Toronto Star, US News and World Report, San Francisco Chronicle, The Independent (UK), Business Week, Washington Post, Financial Times (UK), Information Week, Web, TV, newspaper (200+) and magazine media. Award of Distinction for interactive Web site development. Two Awards of Excellence for exceptional multimedia application development. US Army War College Team of the Year for outstanding contributions as team manager. U.S. Army Visual Information Award for multimedia development. Highly Commended Award by MCB Publishers, for: Spink, A., Bateman, J., and Jansen, B. J. (1999) Searching the Web: A survey of Excite users, Journal of Internet Research: Electronic Networking Applications and Policy, 9(2), 117-128. Top Paper Award for: Spink, A., Bateman, J., and Jansen, B. J. (1998) Users’ searching behavior on the Excite Web search engine, 1999 World Conference on the WWW and Internet, Orlando, Florida. ACM Student Research Award for: Jansen, B. J. (1997) Simulated Annealing for Query Results Ranking, Computer Science Education Conference, San Jose, CA. 28 — 30 February. Writing and Research Award, U.S. Marine Corps University. Research Award from U.S. Army Trainer Journal Jansen, B. J. (2011). Understanding Sponsored Search: Coverage of the Core Elements of Keyword Advertising. Cambridge University Press: Cambridge, UK. Jansen, B. J. (2009) Understanding User — Web Interactions via Web Analytics. MorganClaypool Lecture Series. Marchionini, G. (Ed). Morgan-Claypool: San Rafael, CA. Jansen, B. J., Spink, A., and Taksa, |. Editors. (2009) Handbook of Research on Web Log Analysis, Hershey, PA: Idea Group Publishing. 40

Case 18-2868, Document 283, 08/09/2019, 2628241, Page442 of 883 Books Spink, A., and Jansen, B. J. (2004) Web Search: Public Searching of the Web, Dordrecht: Kluwer Academic Publishers. Parts of Books Jansen, B. J. (2016) Log Analysis. Research Methods in Library and Information Science. Libraries Unlimited. Mukherjee, P, Kozlek, B., Gyorke, A., Camplese, C. and Jansen, B. J. (2014) Leveraging Mobile Technology to Enhance Both Competition and Cooperation in an Undergraduate STEM Course. Innovative Practices in Teaching Information Sciences and Technoloay: Experience Reports and Reflections. p. 167-178. New York: Springer. Reddy, M. C., Jansen, B. J., Spence, P. R. (2010) Collaborative Information Behavior: Exploring Collaboration and Coordination During Information Seeking and Retrieval Activities. Foster, J. (Ed.), Collaborative Information Behavior: User Engagement and Communication Sharing. p. 73 - 88. Hershey, PA: IGI. Booth, D., and Jansen, B. J. (2009) A review of methodologies for analyzing Websites. In B. J. Jansen, A. Spink & |. Taksa (Eds.), Handbook of Web Log Analysis. p. 143-164. Hershey, PA: IGI. Jansen, B. J. (2009) The methodology of search log analysis. In B. J. Jansen, A. Spink & I. Taksa (Eds.), Handbook of Web log analysis. p. 100-123. Hershey, PA: IGI. Jansen, B. J., Taksa, |., and Spink, A. (2009) Research and methodological foundations of transaction log analysis. |n B. J. Jansen, A. Spink & |. Taksa (Eds.), Handbook of Web Log Analysis. p. 1-17. Hershey, PA: IGI. Rainie, L., and Jansen, B. J. (2009) Surveys as a complementary method to Web log analysis. In B. J. Jansen, A. Spink & |. Taksa (Eds.), Handbook of Web Log Analysis. p. 3964. Hershey, PA: IGI. Taksa, |., Spink, A., and Jansen, B. J. (2009) A review of methods in presented in the handbook of weblog analysis. In B. J. Jansen, A. Spink & |. Taksa (Eds.), Handbook of Web Log Analysis. p. -358. Hershey, PA: IGI. Zhang, M., and Jansen, B. J. (2009) Using action-object pairs as a conceptual framework for transaction log analysis. In B. J. Jansen, A. Spink & Taksa, I. (Eds.), Handbook of Web Log Analysis. p. 416-435. Hershey, PA: IGI. Jansen, B. J. and Spink, A. (2008) Logfile analysis. In International Encyclopedia of Communication. Editors: Robin Mansell. Oxford: Blackwell Press. 6. p. 2730-2734. Al

Case 18-2868, Document 283, 08/09/2019, 2628241, Page443 of 883 Parts of Books Jansen, B. J. and Spink, A. (2008) How to Define Searching Sessions on Web Search Engines. In Lecture Notes in Artificial Intelligence, LNAI 4198, Advances in Web Mining and Web Usage Analysis. Editors: Olfa Nasraoui, Osmar Zaiane, Myra Spiliopoulou, Bamshad Mobasher, Philip Yu, Brij Masand. p. 92 — 109. Berlin Heidelberg: Springer-Verlag. Jansen, B. J., Berkheiser, W, Spink, A., and Pedersen, J. (2007) How people search for governmental information on the Web. In: Encyclopedia of Digital Government. Editors: AriVeikko Anttiroiko and Matti Malkia. p. 933-939. Hershey, PA: Idea Group Publishing. Wolfe, R., Jansen, B. J., and Spink, A. (2006) Semantics and the medical Web: A review of barriers and breakthroughs in effective healthcare query. In: Advances in Electronic Business. Vol. Il. Editors: E. Liand D.C. Timon. p. 267-279. Hershey, PA: Idea Group Publishing. Jansen, K. J., Corley, K. G., and Jansen, B. J. (2006) E-Survey methodology: A review, issues, and implications. In Encyclopedia of Electronic Surveys and Measurements (EESM)U. Editors: Jason D. Baker and Robert Woods. p. 1-8. Hershey, PA: Idea Group Publishing. Jansen, B. J. and Spink, A. (2004) An analysis of documents viewing patterns of Web search engine users, In Web Mining: Applications and Techniques. Editor: Anthony Scime. p. 339-354. Hershey, PA: Idea Group Publishing. Jansen, B. J. (2004) The use of query operators and their effect on the results of Web search engines, In |lssues of Human Computer Interaction. Editor: Dr. Anabela Sarmento. p. 50-72. Hershey, PA: Idea Group Publishing. Refereed Journal Articles Coughlin, D. and Jansen, B. J. (2016) Modeling Journal Bibliometrics to Predict Downloads and Inform Purchase Decisions at University Research Libraries. Journal of the Association for Information Science and Technology. Liu, Z., and Jansen, B. J. (2016) ASK: A Taxonomy of Information Seeking Posts in Social Question and Answering. Journal of the Association for Information Science and Technology. Liu, Z., and Jansen, B. J. (2016) Understanding and Predicting Question Subjectivity in Social Question and Answering. IEEE Transactions on Computational Social Systems. 3(1), 32-41. Ortiz-Cordova, A. and Jansen, B. J. (2016) Associating Searching on Search Engines to Subsequent Searching on Sites. International Journal of Information Systems in the Service Sector. 8(2), 30-43. 42

Case 18-2868, Document 283, 08/09/2019, 2628241, Page444 of 883 Refereed Journal Articles Coughlin, D., Campbell, M., and Jansen, B. J. (2015) A Web Analytics Approach for Appraising Electronic Resources in Academic Libraries. Journal of the Association for Information Science and Technology. 67(3), 518-534. Ortiz-Cordova, A., Yang, Y., and Jansen, B. J. (2015) External to Internal Search: Associating Searching on Search Engines with Searching on Sites. Information Processing & Management. 51(5), 718-736. Mukherjee, P, Kozlek, B., Jansen, B. J., Gyorke, A., and Camplese, C. (2014) Designing a Mobile and Socially Networked Learning Assistant for a University-level Keyword Advertising Course. MERLOT Journal of Online Learning and Teaching. 10(3), 351-373. Yang, Y., Qin, R., Zhang, J., Zeng, D., and Jansen, B. J. (2014) Budget Planning for Coupled Campaigns in Sponsored Search. \International Journal of Electronic Commerce. 18(3), 39Mukherjee, P. and Jansen, B. J. (2014) Performance Analysis of Keyword Advertising Campaign Using Gender-Brand Effect of Search Queries. Electronic Commerce Research and Applications. 13(2), 139-149. Jansen, B. J., Liu, Z., and Simon, Z. (2013) The Effect of Ad Rank on Performance of Keyword Advertising Campaigns. Journal of the American Society for Information Science and Technology. 64(10), 2115-2132. Jansen, B. J., Moore, K., and Carman, S. (2013) Evaluating The Performance of Demographic Targeting Using Gender in Keyword Advertising. Information Processing & Management. 49(1), 286-302. Jansen, B. J., Zhang, L, and Mattila, A. S. (2012) Investigating Brand Knowledge of Web Search Engines: User Reactions to Search Engine Logos. Electronic Commerce Research. 12(4), 429-454. Zhang, L, Jansen, B. J., Mattila, A. S. (2012) A Branding Model for Web Search Engines. International Journal of Internet Marketing and Advertising. 7(3), 195 — 216. Ortiz-Cordova, A. and Jansen, B. J. (2012) Classifying Web Search Queries in Order to Identify High Revenue Generating Customers. Journal of the American Society for Information Science and Technology. 63(7), 1426 — 1441. Zhang, M., Jansen, B. J., and Chowdhury, A. (2011) /nfluence of Business Engagement in Online Word-of-mouth Communication on Twitter: A Path Analysis. Electronic Markets: The International Journal on Networked Business. 21(3), 161-175. Jansen, B. J., Sobel, K., and Zhang, M. (2011) The Brand Effect of Key Phrases and Advertisements in Sponsored Search. International Journal of Electronic Commerce. 6(1), 77106. 43

JASIST Best Paper Highly Cited Case 18-2868, Document 283, 08/09/2019, 2628241, Page445 of 883 Refereed Journal Articles Jansen, B. J., Liu, Z., Weaver, C., Campbell, G. and Gregg, M. (2011) Real Time Search on the Web: Queries, Topics, and Economic Value. \nformation Processing & Management. 47(4), 491-506. Jansen, B. J., Sobel, K. and Cook, G. (2011) Classifying Ecommerce Information Sharing Behaviour by Youths on Social Networking Sites. Journal of Information Science. 37(2), 120136. Jansen, B. J. and Schuster, S. (2011) Bidding on the Buying Funnel for Sponsored Search Campaigns. Journal of Electronic Commerce Research. 12(1), 1-18. Kuthuria, A., Jansen, B. J., Hafernik, C. (2010) K-means Clustering to Determine User Intent of Web Queries. Journal of Internet Research: Electronic Networking Applications and Policy. 20(5), 563-581. Rosso, M. A. and Jansen, B. J. (2010) Brand Names as Keywords in Sponsored Search Advertising. Communications of the Association for Information Systems. 27(1), Article 6. Available at: http://aisel.aisnet.org/cais/vol27/iss1/6 Jansen, B. J., and Rieh, S. (2010) The Seventeen Theoretical Constructs of Information Searching and Information Retrieval. Journal of the American Society for Information Science and Technology. 61(8), 1517-1534. Jansen, B. J., Tapia, A. H., and Spink, A. (2010) Searching for salvation: An analysis of US religious searching on the World Wide Web, Religion. 40(1), 39-52. Jansen, B. J., Zhang, M, Sobel, K, and Chowdury, A. (2009) Twitter Power: Tweets as Electronic Word of Mouth. Journal of the American Society for Information Science and Technology. 60(11), 2169-2188. Recognized as one of the top 10 most highly cited papers in JASIST published since 2001 http://www.asis.org/Bulletin/Aug-12/AugSep12_Bar-llan.html Jansen, B. J., Booth, D. and Smith, B. (2009) Using the taxonomy of cognitive learning to model online searching. Information Processing & Management. 45(6), 643-663. Tjondronegoro, D., Spink, A., and Jansen, B. J. (2009) A Study and Comparison of Multimedia Web Searching: 1997-2006. Journal of the American Society for Information Science and Technology. 60(9), 1756-1768. Jansen, B. J., Zhang, M., and Schultz, C. (2009). Search engine brand and the effect on user perception of searching performance. Journal of the American Society for Information Science and Technology. 60(8), 1572-1595. Flaherty, T. B., Jansen, B. J., Hofacker, C., and Murphy, J. (2009). /nsights on the Google Online Marketing Challenge and Its Successful Classroom Implementation. Journal of Online Learning and Teaching, 5(2), 446-457.

Highly Cited Case 18-2868, Document 283, 08/09/2019, 2628241, Page446 of 883 Refereed Journal Articles Jansen, B. J., Booth, D. L., and Spink, A. (2009). Patterns of query modification during Web searching. Journal _of the American Society for Information Science and Technology. 60(7), 1358-1371. Jansen, B. J., Flaherty, T.B., Baeza-Yates, R., Hunter, L., Kitts, B., and Murphy, J. (2009). The Components and Impact of Sponsored Search. IEEE Computer. 42(5) 98-101. Rosso, M., McClelland, M. K., Jansen, B. J., and Fleming, S. W. (2009) Using Google AdWords in the MBA MIS Course. Journal of Information System Education. 20(1), 41-50. Zhang, Y., Jansen, B. J., and Spink, A. (2009) Identification of factors predicting clickthrough in Web searching using neural network analysis. Journal of the American Society for Information Science and Technology. 60(3), 557-570. Zhang, Y., Jansen, B. J., and Spink, A. (2009) Time Series Analysis of a Web Search Engine Transaction Log, \Information Processing & Management. 45(2), 230-245. Jansen, B. J. and Spink, A. (2009) Investigating Customer Click through Behavior with Integrated Sponsored and Non-Sponsored Results, International Journal of Internet Marketing and Advertisement, 5(1/2), 74-94. Jansen, B. J., Ciamacca, C., and Spink, A. (2008) An Analysis of travel searching on the Web, Journal of Information Technology and Tourism. 10(2), 101-118. Jansen, B. J. and Mullen, T. (2008) Sponsored search: An overview of the concept, history, and technology, International Journal of Electronic Business. 6(2), 114 — 131. Spink, A., and Jansen, B. J. (2008) Trends in searching for business and e-commerce information on Web search engines, |International Journal of Electronic Commerce. 9(2), 154161. Jansen, B. J., Booth, D., and Spink, A. (2008) Determining the informational, navigational, and transactional intent of Web queries, Information Processing & Management. 44(3), 12511266. The most cited article in IP&M published since 2008 (http:/Awww.journals.elsevier.com/information-processing-and-management/most-citedarticles/) Jansen, B. J. (2008) Searching for digital Images on the Web, Journal of Documentation. 64(1), 81-101. Jansen, B. J. and Eastman, C. (2008) Limitations of advanced searching techniques on Web search engines, Journal of Electronic Resources in Law Librarianship. 1(1), 55-81. 45

Highly Cited Case 18-2868, Document 283, 08/09/2019, 2628241, Page447 of 883 Refereed Journal Articles Reddy, M. C. and Jansen, B. J. (2008) A model for understanding collaborative information behavior in context: A study of two healthcare teams, \|nformation Processing & Management. 44 (1), 256-273. One of the Top 25 most cited articles in IP&M published since 2008 (http:/Awww.journals.elsevier.com/information-processing-and-management/most-citedarticles/) Jansen, B. J., Zhang, M., and Spink, A. (2007) Patterns and transitions of query reformulation during Web searching, |International Journal of Web Information Systems. 3(4), 328-340. Jansen, B. J., Brown, A., and Resnick, M. (2007) Factors relating to the decision to click-on a sponsored link, Decision Support Systems. 44(1), 46-59. Jansen, B. J. and Spink, A. (2007) Sponsored search: Is money a motivator for providing relevant results?, IEEE Computer. 40(8), 50-55. Jansen, B. J. (2007) Click fraud. IEEE Computer. 40(7), 85-86. Jansen, B. J. (2007) The comparative effectiveness of sponsored and non-sponsored results for Web ecommerce queries, ACM Transactions on the Web. 1(1), Article 3. Jansen, B. J., Spink, A., Blakely, C., and Koshman, S. (2007) Defining a session on Web search engines, Journal of the American Society for Information Science and Technology. 98(6), 862-877. Jansen, B. J., Spink, A., and Koshman, S. (2007) Web searcher interactions with the Dogpile.com meta-search engine, Journal of the American Society for Information Science and Technology. 58(5), 744-755. Jansen, B. J., Mullen, T., Spink, A., and Pederson, J. (2006) Automated gathering of Web information: An in-depth examination of agents interacting with search engines, ACM Transactions on Internet Technology. 6(4), 442-464. Jansen, B. J. and Resnick, M. (2006) An examination of searcher’s perceptions of nonsponsored and sponsored links during ecommerce Web searching, Journal of the American society for Information Science and Technology. 57(14), 1949-1961. Koshman, S. Spink, A., Jansen, B. J., Park, M., and Fields, C. (2006) Web Searching on the Vivisimo search engine, Journal of the American Society for Information Science and Technology. 57(14), 1875-1887. Spink, A., Jansen, B. J., Blakely, C., and Koshman, S. (2006) Overlap among major search engines, Journal of Internet Research: Electronic Networking Applications and Policy. 16(4), 419-426. 46

Paper Award Most Accessed Case 18-2868, Document 283, 08/09/2019, 2628241, Page448 of 883 Refereed Journal Articles Jansen, B. J. (2006) Search log analysis: What is it; what's been done; how to do it, Library and Information Science Research, 28(3), 407-432. Spink, A., and Jansen, B. J. (2006) Searching multiple federate content Web collections, Online Information Review. 30(5), 485-495. Spink, A., Partridge, H., and Jansen, B. J. (2006) Sexual/pornographic Web searching: Trends analysis, First Monday. 11(9). http://www.firstmonday.org/issues/issue1 1_9/spink/index.html. Jansen, B. J. (2006) Paid search, IEEE Computer. 39(7), 88-90. Spink, A., Jansen, B. J., Blakely, C., and Koshman, S. (2006) A study of results overlap and uniqueness among major Web search engines, Information Processing & Management. 42(5), 1379-1391. Jansen, B. J. (2006) Using temporal patterns of interactions to design effective automated searching assistance systems, Communications of the ACM. 49(4), 72-74. Jansen, B. J. and Molina, P. (2006) The effectiveness of Web search engines for retrieving relevant ecommerce links, Information Processing & Management. 42(4), 1075-1098. Jansen, B. J. and McNeese, M. D. (2005) Evaluating the effectiveness of and patterns of interactions with automated assistance in IR systems, Journal of the American Society for Information Science and Technology. 56(14), 1480-1503. Jansen, B. J. and Spink, A. (2005) How are we searching the World Wide Web?: An analysis of nine search engine transaction logs, \Information Processing & Management. 42(1), 248263. Routinely listed as one of the most downloaded articles published in IP&M (http://www.journals.elsevier.com/information-processing-and-management/mostdownloaded-articles/) Spink, A., Park, M., Jansen, B. J., and Pedersen, J. (2005) Multitasking during Web search sessions, Information Processing & Management. 42(1), 264-275. Jansen, B. J., Jansen, K. J., and Spink, A. (2005) Using the Web to /ook for work: Implications for online job seeking and recruiting, Journal of Internet Research: Electronic Networking Applications and Policy. 15(1), 49-66. Jansen, B. J., Spink, A, and Pederson, J. (2005) Trend analysis of AltaVista Web searching, Journal of the American Society for Information Science and Technology. 56(6), 559-570. Jansen, B. J. (2005) Seeking and implementing automated assistance during the search process, Information Processing & Management. 41(4), 909-928. 47

Highly Cited Highly Cited Case 18-2868, Document 283, 08/09/2019, 2628241, Page449 of 883 Refereed Journal Articles Jansen, B. J., Spink, A., and Pederson, J. (2005) The effect of specialized multimedia collections on Web searching, Journal of Web Engineering. 3(3/4), 182-199. Spink, A. and Jansen, B. J. (2005) A study of Web search trends, Webology. 1(2), Article 4, Available at: http://www.webology.ir/2004/v1n2/a4.html. Jansen, B. J. and Spink, A. (2004) An analysis of Web searching by European Alltheweb.com users, Information Processing & Management. 41(2), 361-381. Spink, A., Jansen, B. J., and Pedersen, J. (2004) Searching for people on Web search engines, Journal of Documentation. 60, (3), 266-278. Spink, A., Yang, Y., Jansen, B. J., Nvkanen, P., Ozmutlu, S., and Ozmutlu, C. (2004) Medical and health Web searching: an exploratory study, Health Information and Libraries Journal. 21(1), 44-51. Jansen, B. J. and Pooch, U. (2004) /mproving IR system performance using software integration, Journal of Internet Research: Electronic Networking Applications and Policy. 14(1), 19-33. Spink, A., Koricich, A., and Jansen, B. J. (2004) Sexual searching on Web search engines, Cyber-psychology and Behavior. 7(1), 65-72. Eastman, C. and Jansen, B. J. (2003) Coverage, relevance, and ranking: the impact of query operators on Web search engine results, ACM Transactions on Information Systems. 21(4), 383-411. Spink, A., Jansen, B. J., Wolfram, D., and Saracevic, T. (2002) From e-sex to e-commerce: Web search changes, IEEE Computer. 35(3), 107-111. Wolfram, D., Spink, A., Jansen, B. J., and Saracevic, T. (2001) Vox populi: The public searching of the Web, Journal of the American Society for Information Science and Technology. 52(12), 1073-1074. Jansen, B. J. and Pooch, U. (2001) Web user studies: A review and framework for future work, Journal of the American Society for Information Science and Technology. 52(3), 235246. Recognized as one of the top 10 most highly cited papers in JASIST published since 2001 http://www.asis.org/Bulletin/Aug-12/AugSep12_Bar-llan.html Spink, A., Wolfram, D., Jansen, B. J., and Saracevic, T. (2001). Searching of the Web: the public and their queries, Journal of the American Society for Information Science and Technology. 52(3), 226-234. Recognized as the most highly cited paper in JASIST published since 2001 http://www.asis.org/Bulletin/Aug-12/AugSep12_Bar-llan.html 48

ISI Paper Award Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page450 of 883 Refereed Journal Articles Brown, G., Fisher, M., Stoll, N., Beeksma, D., Black, M., Taylor, R., Choe, S., Williams, A., Bryant, W., and Jansen, B. J. (2000) Leveraging a Y2K evaluation to improve information systems architecture, Communications of the ACM. 43(10), 90-97. Jansen, B. J., Spink, A., and Saracevic, T. (2000) Real life, real users, and real needs: A study and analysis of user queries on the Web, Information Processing & Management. 36(2), 207-227. Jansen, B. J., Goodrum, A., and Spink, A. (2000) Searching for multimedia: video, audio, and image Web queries, World Wide Web Journal. 3(4), 249-254. Spink, A., Jansen, B. J., and Ozmutlu, C. (2000) Use of query reformulation and relevance feedback by Web users, Journal of Internet Research: Electronic Networking Applications and Policy. 10(4), 317-328. Schmoyer, T. and Jansen, B. J. (2000) An adaptive hypermedia system for improving an organization's customer support, WebNet Journal. 2(4), 30-35. Jansen, B. J. (2000) An investigation into the use of simple queries on Web IR systems, Information Research: An Electronic Journal. 6(1). http://informationr.net/ir/6-1/paper8 7 .html Spink, A., Bateman, J., and Jansen, B. J. (1999) Searching the Web: A survey of Excite users, Journal of Internet Research: Electronic Networking Applications and Policy. 9(2). 117128. Spink, A., Bateman, J., and Jansen, B. J. (1998) Searching heterogeneous collections on the Web: Behavior of Excite users, Information Research: An Electronic Journal. 5(2). http://informationr.net/ir/4-2/paper53.html Jansen, B. J. (1997) Using an intelligent agent to enhance the performance of an information retrieval engine, First Monday. 2(3). http://www.firstmonday.dk/issues/issue2_3/jansen/index.html Book Reviews Jansen, B. J. (2008) Book review: Making Sense of Data: A Practical Guide to Exploratory Data Analysis and Data Mining by Glenn J. Myatt. Wiley. 2007 pages 280. $74.95. Information Processing & Management. 44(2), 978-979. Jansen, B. J. (2007) Book review: The Long Tail: Why the Future of Business is Selling Less or More. By Chris Anderson. Hyperion: New York. 2006. $24.95 ISBN: 1-4013-0237-8. Information Processing & Management. 43(4), 1147-1148. 49

Case 18-2868, Document 283, 08/09/2019, 2628241, Page451 of 883 Book Reviews Jansen, B. J. (2007) Book review: The Craft of Research, 2nd edition (Chicago Guides to Writing, Editing, and Publishing) (Paperback) by Wayne C. Booth, Joseph M. Williams, Gregory G. Colomb. Paperback: 336 pages. University of Chicago Press; 2nd edition. ISBN: 0226065685. Information Processing & Management. 43(3), 827-828. Jansen, B. J. (2007) Book review: Effective Expert Witnessing, Fourth Edition, by Jack V. Matson, Suha F. Daou, and Jeffrey G. Soper. 160 pages. CRC. ISBN: 0849313015. $99.95. Information Processing & Management. 43(3), 830-831. Jansen, B. J. (2007) Book review: Messages, Meanings and Symbols: The Communication of Information. By Charles T. Meadow. Lanham, MD: Scarecrow Press, 2006. 264 pp. $40.00 (paper). ISBN 0-8108-5271-3. Library and Information Science Research. 29(2), 303-304. Jansen, B. J. (2006) Book review: The Search: How Google and Its Rivals Rewrote the Rules of Business and Transformed our Culture. by John Battelle. Penguin Group. 311 pages. Cost: $25.95. ISBN: 1591840880. Information Processing & Management. 42(5), 1399-1401. Jansen, B. J. (2006) Book review: Theories of Information Science Behavior. 2005, Edited by Karen E. Fisher, Sanda Erdelez, and Lynn (Ed.) McKechnie. ASIST Monograph Series. Information Today, Inc. Medford, New Jersey. 431 pages. Cost: $49.50. Information Processing & Management. 42(5), 1392-1395. Jansen, B. J. (2005) Book review: Mining the Web: Discovering Knowledge from Hypertext Data. 2002. Soumen Chakrabarti. Morgan-Kaufmann Publishers, 352 pages. Cost: $54.95. ISBN: 1-55860-754-4. Information Processing & Management. 42(1), 317-318. Non-refereed Articles Jansen, B. J., Chowdhury, A., and Cook, G. (2010) The Ubiquitous and Increasingly Significant Status Message. Interactions. May/June, 15-17. Jansen, B. J., Hudson, K., Hunter, L., Liu, F., and Murphy, J. (2008) The Google Online Marketing Challenge: Real-World Learning with Real Clients, Real Money, and Real Advertising Campaigns, Journal of Interactive Advertising. 9(1), http://www.jiad.org/article109 Jansen, B. J. (2008) Sponsored search, |International Journal of Electronic Business. 6(2), 112-113. Edmonds, A., Hawkey, K., Jansen, B. J., Kellar, M., and Turnbull, D. (2007) Editorial for Special Issue on Logging Traces of Web, Journal of Web Engineering. 6(3), 193-195. Jansen, B. J. (2006) Paid search as an information seeking paradigm, Bulletin of the American Society for Information Science and Technology. 32(2), 7-8. Spink, A., Ozmutlu, S., OZmutlu, H. C., and Jansen, B. J. (2002) U.S. versus European Web searching trends, SIGIR Forum. 32(1), 30-37. 50

Case 18-2868, Document 283, 08/09/2019, 2628241, Page452 of 883 Non-refereed Articles Jansen, B. J., Riedt, R., and Turner, J. (2002) Hitting the moving technology target, SIGNAL: International Journal of AFCEA. 56(80), 65. Schmoyer, T. and Jansen, B. J. (2001) Personalized computer interaction improves customer service, SIGNAL: International Journal of AFCEA. 55(9), 63-65. Jansen, B. J. and Spink, A. (2000) Methodological approach in discovering user search patterns through Web log analysis, Bulletin of the American Society for Information Science and Technology. 27(1), 15-17. Jansen, B. J., Spink, A., Bateman, J., and Saracevic, T. (1998) Real life information retrieval: A study of user queries on the Web, SIGIR Forum. 32(1), 5-17. 128. Crow, D. and Jansen, B. J. (1998) Seminal works in computer human interaction, SIGCHI Bulletin. 30(3), 24-28. Jansen, B. J. (1998) The graphical user interface: An introduction, SIGCHI Bulletin. 30(2), 22-26. Manuscripts Accepted for Publication Liu, Z., and Jansen, B. J. (forthcoming) Predicting the Response Rate in Social Question and Answering on Sino Weibo. |Information Processing & Management. Liu, Z., and Jansen, B. J. (forthcoming) /dentifying the Desire to Help: Predicting User Willingness for Knowledge Sharing in Social Question and Answer. Information Processing & Management. Manuscripts Submitted for Publication Mukherjee, P. and Jansen, B. J. (under review) Brand Conversing and Brand Searching: A Temporal Analysis of Social Media and Search Concerning Super Bowl 2015 Commercials. Internet Research. Refereed Conference Proceedings Brown, A., Lush, B., and Jansen, B. J. (under review) Pixel Efficiency Analysis: A Methodology for Quantitative Web Analytics for Academic Library and Other Non-commercial Websites. The First International Conference on Information Systems and Applications (ICISA2016), Manama, Kingdom of Bahrain. 17-18 Nov. a1

Case 18-2868, Document 283, 08/09/2019, 2628241, Page453 of 883 Refereed Conference Proceedings Kwak, H., An, J. and Jansen, B. J. (2017) Automatic Generation of Personas Using YouTube Social Media Data. Hawaii International Conference on System Sciences (HICSS-50). Waikoloa, Hawaii. 4-7 January. Gao, Y., Reddy, M., and Jansen, B. J. (2017) ShopWithMe!: Collaborative Information Searching and Shopping for Online Retail. Hawaii International Conference on System Sciences (HICSS-50). Waikoloa, Hawaii. 4-7 January. Whitman, A. and Jansen, B. J. (2016) Commercial Consequences of Amazon's Community Forums: The Case of the Kindle. The Second International Workshop on Online Social Networks Technologies (OSNT-2016), 13th ACS/IEEE International Conference on Computer Systems and Applications AICCSA 2016. 29 November - 2 December. An, J., Kwak, H. and Jansen, B. J. (2016) Validating Social Media Data for Automatic Persona Generation. The Second International Workshop on Online Social Networks Technologies (OSNT-2016), 13th ACS/IEEE International Conference on Computer Systems and Applications AICCSA 2016. 29 November - 2 December. Das, A., Das, S.S., Ziegelmayer, J.L., Jansen, B. J. (2016) Attention Allocation and Choice: An Eye-Tracking Study. Annual Meeting of the Society for Judgment and Decision Making (SJDM2016). Boston, Massachusetts, 18-21 November. Brown, A., Lush, B., and Jansen, B. J. (2016) Pixel Efficiency Analysis: A Quantitative Web Analytics Approach. 2016 Annual Meeting of the Association for Information Science and Technology, Copenhagen, Denmark, 14-18 Oct. Mukherjee, P. and Jansen, B. J. (2016) Formality Identification in Social Media Dialogue. 2016 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP16). Washington DC p. 375-380. 21 June-1 July. Wong, J.S., Pursel, B., Divinsky, A., and Jansen, B. J. (2016) An Analysis of Cognitive Learning Context in MOOC Forum Messages. ACM Conference on Human Factors in Computing Systems (CHI2016), San Jose, CA, USA, 7-12 May. Gao, Y, Reddy, M., and Jansen, B. J. (2016) Shopping as Searching: Collaborative Web Search in the Ecommerce Domain. ACM Conference on Human Factors in Computing Systems (CHI2016), San Jose, CA, USA, 7-12 May. Mukherjee, P. and Jansen, B. J. (2016) Second Screen Interaction Analysis for IRL Events: Phase-Category Investigation of the Super Bowl 2015 Social Soundtrack. The 7" International Conference on Information and Communication Systems (ICICS 2016). Irbid, Jordan. 5-7 April. Mukherjee, P. and Jansen, B. J. (2015) Correlation of Brand Mentions in Social Media and Web Searching Before and After Real Life Events: Phase Analysis of Social Media and Search Data for Super Bowl 2015 Commercials. International Workshop on Event Analytics Using Social Media Data, IEEE International Conference on Data Mining (ICDM2015) Atlantic City, New Jersey. 14-17 Nov., p. 21-26. a2

Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page454 of 883 Refereed Conference Proceedings Wong, J.S., Pursel, B., Divinsky, A. and Jansen, B. J. (2015) Analyzing MOOC Discussion Forum Messages to Identify Cognitive Learning Exchanges. 2015 Annual Meeting of the Association for Information Science & Technology. St. Louis, Mo. 6-10 Nov. Liu, Z., and Jansen, B. J. (2015) Analysis of Question and Answering Behavior in Question Routing Services. 21* International Conference on Collaboration and Technology (CRIWG 2015). Yerevan, Armenia. 22 — 25 Sept., p.72-85. Liu, Z., and Jansen, B. J. (2015) A Taxonomy for Classifying Questions Asked in Social Question and Answering. ACM CHI Conference on Human Factors in Computing (CHI 2015), Seoul, South Korea, 18-23 Apr. Coughlin, D. and Jansen, B. J. (2015) Predicting Downloads of Academic Articles To Inform Online Content Management. 6" International Conference on Information and Communication Systems (ICICS2015). Amman, Jordan. 8-9 Apr. Wong, J.S., Pursel, B., Divinsky, A. and Jansen, B. J. (2015). An Analysis of MOOC Discussion Forum Interactions from the Most Active Users. 2015 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP15). Washington DC, p. 452-457. 31 Mar.-3 Apr. Liu, Z., and Jansen, B. J. (2015) Subjective versus Objective Questions: Perception of Question Subjectivity in Social Q&A. 2015 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP15). Washington DC p. 131-140. 31 Mar.-3 Apr. Mukherjee, P. and Jansen, B. J. (2015) Analyzing Second Screen Based Social Soundtrack of TV Viewers from Diverse Cultural Settings. 2015 International Conference on Social Computing, Behavioral-Cultural Modeling, and Prediction (SBP15). Washington DC p. 375380. 31 Mar.-3 Apr. Ortiz-Cordova, A. and Jansen, B. J. (2015) The Relationship Between Searching on Search Engines and Searching on Sites. International Conference on Information Systems and Technologies (ICIST’2015). Istanbul, Turkey. 21-23 March. Mukherjee, P. and Jansen, B. J. (2015) Evaluating Pattern for Group Interactions using Second Screens. In Computing, Networking and Communications Workshop (CNC), 2015 International Conference on Computing, Networking and Communications, Anaheim, CA. 1619 Feb. Mukherjee, P. and Jansen, B. J. (2015) Evaluating Classification Schemes for Second Screen Interactions, 2015 International Conference on Computing, Networking and Communications, Anaheim, CA. 16-19 Feb. Mukherjee, P., Wong, J.S., and Jansen, B. J. (2014) Patterns of Social Media Conversations Using Second Screens. The Sixth ASE International Conference on Social Computing (SocialCom 2014). Stanford, CA. 27-31 May. 53

Case 18-2868, Document 283, 08/09/2019, 2628241, Page455 of 883 Refereed Conference Proceedings Liu, Z., and Jansen, B. J. (2014) Predicting Potential Responders in Social Q&A Based on non-QA Features. ACM CHI Conference on Human Factors in Computing (CHI 2014), p. 2131-2136. Toronto, Canada. 26 April - 1 May. Ortiz-Cordova, A. and Jansen, B. J. (2014) Linking External and Internal Search: Investigating the Site Searching Patterns of Referred Searchers. ACM CHI Conference on Human Factors in Computing Systems (CHI 2014), p. 1345-1350. Toronto, Canada. 26 April 1 May. Mukherjee, P. and Jansen, B. J. (2014) Significance of Second Screen Interaction during Television Viewing. The 2013 International Conference on Social Computing, BehavioralCultural Modeling, and Prediction (SBP), Washington DC. 2-4 April. Coughlin, D. M., Campbell, M. C., and Jansen, B. J. (2013) Measuring the Value of Library Content Collections. 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Mukherjee, P. and Jansen, B. J. (2013) Gender-Brand Effect of Search Queries on Sponsored Search Performance. 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Ortiz-Cordova, A. and Jansen, B. J. (2013) Site-Searching Strategies of Searchers Referred from Search Engines. 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Liu, Z. and Jansen, B. J. (2013) Question and Answering Made Interactive: An Exploration of Interactions in Social Q&A. Proceedings of the International Conference on Social Intelligence and Technology 2013 (SOCIETY 2013), p. 1-10. State College, Pennsylvania USA, 8 -9 May. Hafernik, C. and Jansen, B. J. (2013) Understanding the specificity of web search queries. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2013), p. 1845-1850. Paris France, 27 April — 2 May. Mukherjee, P. and Jansen, B. J. (2013) The gender-brand effect of key phrases on user clicks in sponsored search. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI 2013), p. 1845-1850. Paris France, 27 April — 2 May. Liu, Z. and Jansen, B. J. (2013) Analysis of Factors Influencing the Response Rate in Social Question and Answering. 16th ACM Conference on Computer Supported Cooperative Work and Social Computing (CSCW 2013), p. 1263-1274. 23-27 February. San Antonio, Texas. Liu, Z. and Jansen, B. J. (2012) Almighty Twitter, What Are People Asking For?. 75th Annual Meeting of the American Society for Information Science and Technology (ASIST 2012), p.110. 26-30 October. Baltimore, MD. 54

Case 18-2868, Document 283, 08/09/2019, 2628241, Page456 of 883 Refereed Conference Proceedings Carman, S., Strong, R., Chandra, A.., Oh, S., Spangler, S., Anderson, L., and Jansen, B. J. (2012) Predictive Value of Comments in the Service Engagement Process. 75th Annual Meeting of the American Society for Information Science and Technology (ASIST 2012). 2630 October. Baltimore, MD. Purao, S., Storey, V., Maass, W., Jansen, B. J., and Reddy, M. (2012) An Integrated Conceptual Model to Incorporate Information Tasks in Workflow Models. 31st International Conference on Conceptual Modeling (ER 2012). 15-18 October. Florence, Italy. Hafernik, C.T., Cheng, B., Francis, P. and Jansen, B. J. (2011) Mapping User Search Queries to Product Categories. 74th Annual Meeting of the American Society for Information Science and Technology (ASIST 2011). 9-13 October. New Orleans, LA. Jansen, B. J., Liu, Z. and Simon, Z. (2011) Investigating the Effect of Results Ranking in Sponsored Search. 4th Annual Meeting of the American Society for Information Science and Technology (ASIST 2011). 9-13 October. New Orleans, LA. Tapia, A., Bajpai, K., Jansen, B. J., Yen, J., Giles, C., and Mitra, P. (2011) Seeking the Trustworthy Tweet: Can Microblogged Data Fit the Information Needs of Disaster Response and Humanitarian Relief Organizations. Proceedings of the 8th International Conference on Information Systems for Crisis Response and Management (ISCRAM 2011), 8-11 May, Lisbon, Portugal. Caragea, C., McNeese, N., Jaiswal, A., Traylor, G., Kim, H.W., Mitra, P., Wu, D., Tapia, A.H., Giles, L., Jansen, B. J., and Yen, J. (2011) Classifying Text Messages for the Haiti Earthquake. Proceedings of the 8th International Conference on Information Systems for Crisis Response and Management (ISCRAM 2011), 8-11 May, Lisbon, Portugal. Jansen, B. J. Sobel, K. and Cook, G. (2011) Being Networked and Being Engaged: The Impact of Social Networking on eCommerce Information Behavior. Proceedings of the iConference 2011, 8-11 February, Seattle, WA, USA. Jansen, B. J. and Booth, D. (2010) Classifying Web Queries by Topic and User Intent. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2010), p. 4285-4290. Atlanta, GA, 10 — 15 April. Jansen, B. J. Sobel, K. and Cook, G. (2010) Gen X and Y's Attitudes on Using Social Media Platforms for Opinion Sharing. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2010), p. 3853-3858. Atlanta, GA, 10 — 15 April. Jansen, B. J., Campbell, G. and Gregg, M. (2010) Rea/ Time Search User Behavior. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2010), p. 3961-3966. Atlanta, GA, 10 — 15 April. Jansen, B. J. and Solomon, L. (2010) Gender Demographic Targeting in Sponsored Search. Proceedings of the ACM Conference on Human Factors in Computing Systems (CHI2010), p. 831-840. Atlanta, GA, 10 — 15 April. a

Best Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page457 of 883 Refereed Conference Proceedings Jansen, B. J., Zhang, M., Booth, B. Park, D., Zhang, Y., Kathuria, A. and Bonner, P. (2009) To What Degree Can Log Data Profile a Web Searcher? Proceedings of the American Society for Information Science and Technology 2009 Annual Meeting. Vancouver, British Columbia. 6-11 November. Srivatsan, V. R., Purao, S., Jansen, B. J., and He, J. (2009) Systems Developers Define their Own Information Needs. 15th Americas Conference on Information Systems. San Francisco, California. 06-09 August. Jansen, B. J., Zhang, M, Sobel, K, and Chowdhury, A (2009) Micro-blogging as Online Word of Mouth Branding. ACM Conference on Computer Human Interaction (CHI2009). p. 38593864. Boston, Massachusetts. 4 - 9 April. Jansen, B. J., Booth, D. and Spink, A (2009) Predicting Query Reformulation During Web Searching. ACM Conference on Computer Human Interaction (CHI2009). p. 3907-3912. Boston, Massachusetts. 4 - 9 April. Zhang, M. and Jansen, B. J. (2009) Influences of Mood on Information Seeking Behavior. ACM Conference on Computer Human Interaction (CHI2009. p. 3395-3400. Boston, Massachusetts. 4 - 9 April. Spink, A. and Jansen, B. J. (2008) The 8th International We-B (Working For E-Business) Conference 2008. Melbourne, Australia. 28 — 30 November. Reddy, M., Jansen, B. J., and Krishnappa, R. (2008) The Role of Communication in Collaborative Information Searching. 2008 Annual Meeting of the American Society for Information Science and Technology. 24-29 October Columbus, Ohio. Jansen, B. J., Zhang, M., and Schultz, C. (2008) The Effect of Brand on the Evaluation of IT System Performance. Proceedings of the Southern Association for Information Systems Conference, Richmond, VA, USA 13-15 March 2008. Tjondronegoro, D., Spink, A., & Jansen, B. J. (2007) Multimedia Searching on the Dogpile Web Meta-Search Engine. ADCS 2007: Australian Document Computing Symposium. Melbourne, Australia. 10 December. Spink, A., and Jansen, B. J. (2007) Commerce Related Web Search: Current Trends, The 18™ Australasian Conference on Information Systems. Toowoomba, Australia. 5-7 December. Zhang, Y. and Jansen, B. J. (2007) An Analysis of Searchers’ Perceptions of Sponsored and Non-Sponsored Links Using Nested Design, 2007 Annual Meeting of the American Society for Information Science and Technology. Milwaukee, Wisconsin, 18-25 October. Jansen, B. J. (2007) Investigating the Relevance of Sponsored Results, The 30" Annual International ACM Special Interest Group on Information Retrieval. Conference (SIGIR), p. 859 — 860, Amsterdam, the Netherlands. 23-27 July. 56

Case 18-2868, Document 283, 08/09/2019, 2628241, Page458 of 883 Refereed Conference Proceedings Jansen, B. J., Smith, B., and Booth, D. (2007) Viewing Online Search Within a Learning Paradigm, The 30" Annual International ACM Special Interest Group on Information Retrieval. Conference (SIGIR), p. 859 — 860. Amsterdam, the Netherlands. 23-27 July. Jansen, B. J., Zhang, M., and Zhang, Y. (2007) Brand Awareness and the Evaluation of Search Results, 16th International World Wide Web Conference (WWW2007), p. 1139 — 1140. Banff, Canada. 8-12 May. Jansen, B. J., Smith, B., and Booth, D. (2007) Understanding Web Search via a Learning Paradigm, 16th International World Wide Web Conference (WWW 2007), p. 1207 — 1208. Banff, Canada. 8-12 May. Jansen, B. J., Booth, D., and Spink, A. (2007) Determining the User Intent of Web Search Engine Queries, 16th International World Wide Web Conference (WWW2007), p. 1149 — 1150. Banff, Canada. 8-12 May. Jansen, B. J., Zhang, M., and Zhang, Y. (2007) The Effect of Brand Awareness on the Evaluation of Search Engine Results, Conference on Human Factors in Computing Systems (SIGCHI), Work-in-Progress, p. 2471 — 2476. San Jose, California. 28 April - 3 May. Spink, A., and Jansen, B. J. (2006) Changing Web search trends from 1997 to 2006, Information Online 2007: 13th Exhibition and Conference. Sydney, Australia. 30 January — 1 February. Yan, S., Giles, C. and Jansen, B. J. (2006) Formal Definitions of Web Information Search, American Society for Information Science & Technology 2006 Annual Meeting, p. 1-10. Austin, Texas. 3 - 8 November. Zhang, M., Jansen, B. J., and Spink, A. (2006) /nformation Searching Tactics of Web Searchers, American Society for Information Science & Technology 2006 Annual Meeting. Austin, Texas, p. 1-10. 3 - 8 November. Koshman, S. Spink, A., Jansen, B. J., Blakely, C., and Weber, J. (2006) Metasearch Result Visualization: An Exploratory Study, 2006 Annual Conference of the Canadian Association for Information Science, p. 1-10. Toronto, Canada. 1-3 June. http://cais-acsi.ca/proceedings/2006/koshman_2006.pdf Jansen, B. J., Spink, A., Blakely, C., and Koshman, S. (2006) /nvestigating Usage of the Vivisimo Clustering Search Engine Interface, The Twelfth Australasian World Wide Web Conference (AUSWEB 06). Noosa Lakes, Australia. 1 -5 July. http://ausweb.scu.edu.au/aw06/papers/refereed/spink/index.html Spink, A., Jansen, B. J., Blakely, C., and Koshman, S. (2006) Overlap Among Major Web Search Engines, IEEE Information Technology: New Generations (ITNG) 2006. p. 370 — 374. Las Vegas, NV. 10 — 12 April. 57

Case 18-2868, Document 283, 08/09/2019, 2628241, Page459 of 883 Refereed Conference Proceedings Jansen, B. J., Spink, A., Blakely, C., and Koshman, S. (2005) Web Searcher Interactions with Multiple Federate Content Collections, Proceedings of the 10th Australasian Document Computing Symposium. Sydney, Australia. 12 December. Jansen, B. J., Koshman, S., and Spink A. (2005) An Analysis of Repeat Users of Vivisimo.com, American Society for Information Science & Technology 2005 Annual Meeting. Charlotte, North Carolina. 28 October — 2 November. Doran, S. G., de Ycaza, S., Eastman, C. and Jansen, B. J. (2005) Finding Nutrition Information on the Web: Coverage vs. Authority, American Society for Information Science & Technology 2005 Annual Meeting. Charlotte, North Carolina. 28 October — 2 November. Spink, A., Koshman, S. and Jansen, B. J. (2005) Tracking Web Search Trends from 1997 to 2005, Internet Research 6.0: Internet Generations Association of Internet Researchers. Chicago, IL. 5 — 9 October. Resnick, M, and Jansen, B. J. (2005) An Empirical Study of Paid Search in Product Search and Purchase, The Human Factors and Ergonomics Society 49th Annual Meeting. p. 14291433. Orlando, Florida. 26-30 September. Sharma, H. and Jansen, B. J. (2005) Automated Evaluation of Search Engine Performance via Implicit User Feedback, The 28th Annual International ACM SIGIR Conference on Research and Development in Information Retrieval. p. 649-650. Salvador, Brazil. 15-19 August. Morgan, A., Jansen, B. J., and Trauth, E. (2005) Exploring Individual User Attitudes Towards Performance with Web Search Engines: An Extension Study, Proceedings of the Eleventh Americas Conference on Information Systems. p. 2317 — 2324. Omaha, Nebraska. 11-14 August. Koshman, S. Spink, A., and Jansen, B. J. (2005) Using Clusters on the Vivisimo Web Search Engine, HCI International 2005. p. 742-747. Las Vegas, Nevada. 22-25 July. Sengupta, S. and Jansen, B. J. (2005) Designing a Value Based Search Engine Using Evolutionary Strategies, IEEE 6th International Conference on Information Technology, Coding and Computing, p. 800-805. Las Vegas, Nevada. 11-13 April. Spink, A., Koshman, S., Park, M., Field, C. and Jansen, B. J. (2005) Multitasking Web Search on Vivisimo.com. IEEE 6th International Conference on Information Technology, Coding and Computing. p. 486-490. Las Vegas, Nevada, 11-13 April. Eastman, C. and Jansen, B. J. (2004) The Appropriate (and Inappropriate) Use of Query Operators and Their Effect on Web Search Engine Results, American Society for Information Science & Technology 2004 Annual Meeting, p. 274-279. Providence, Rhode Island. 13-18 November. 58

Case 18-2868, Document 283, 08/09/2019, 2628241, Page460 of 883 Refereed Conference Proceedings Spink, A., Park, M., Jansen, B. J., and Pederson, J. (2004) Information Task Switching and Multitasking Web Search, Proceedings of the American Society for Information Science & Technology 2004 Annual Meeting, p. 213-217. Providence, Rhode Island. 13-18 November. Jansen, B. J. and McNeese, M. D. (2004) Investigating Automated Assistance and Implicit Feedback for Searching Systems, Proceedings of the American Society for Information Science & Technology 2004 Annual Meeting, p. 280-286. Providence, Rhode Island. 13-18 November. Jansen, B. J. and McNeese, M. D. (2004) Evaluating the Effectiveness of Automated Assistance for Web Searching, Proceedings of the Human Factors and Ergonomics Society 48th Annual Meeting, p. 1518-1522. New Orleans, Louisiana. 20-24 September. Spink, A., Park, M., Jansen, B. J., and Pederson, J. (2004) Multitasking Web Search on AltaVista, Proceedings of the IEEE 5th International Conference on Information Technology, Coding and Computing, p. 309-313. Las Vegas, Nevada. 5-7 April. Jansen, B. J., Spink, A., and Pederson, J. (2003) An Analysis of Multimedia Searching on AltaVista, Proceedings of the 5th ACM SIG Multimedia International Workshop on Multimedia Information Retrieval, p.186-192. Berkeley, California. Jansen, B. J. (2003) Designing Automated Help Using Searcher System Dialogues, Proceedings of the 2003 IEEE International Conference on Systems, Man & Cybernetics, p. 144-749. Washington, D.C. 5-8 October. Jansen, B. J., Spink, A., and Pederson, J. (2003) Web Search Agents: What Are They Doing Out There? Proceedings of the 2003 IEEE International Conference on Systems, Man & Cybernetics, p. 1410-1416. Washington, D.C. 5-8 October. Jansen, B. J., Spink, A., and Pederson, J. (2003) Monsters at the Gates: When Softbots Visit Web Search Engines, Proceedings of the 4" International Conference on Internet Computing, Lap. p. 620-626. Vegas, Nevada. 23-26 June. Spink, A., Abbas, M., and Jansen, B. J. (2003) Accessing E-commerce Web Information: Implications for Bridging the Digital Divide, The 2003 Canadian Association for Information Science Conference, p. 2173-221. Halifax, CA. 28 May-1 June. Jansen, B. J. and Spink, A. (2003) An Analysis of Web Information Seeking and Use: Documents Retrieved Versus Documents Viewed, Proceedings of the 4” International Conference on Internet Computing, p. 65-69. Las Vegas, Nevada, 23-26 June. Jansen, B. J. (2003) Operators Not Needed? The Impact of Query Structure on Web Searching Results, Information Resource Management Association International Conference, p. 814-817. Philadelphia, PA, 18-21 May. Duran, S., Eastman, C., and Jansen, B. J. (2003) Nutritional Information on the Web: An Analysis of Information Sought and Information Provided, |nformation Resource Management Association International Conference, p. 106-108. Philadelphia, PA. 18-21 May. 59

Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page461 of 883 Refereed Conference Proceedings Jansen, B. J. and Spink, A. (2003) Retrieving and Viewing Web Documents, The 2003 National Online Meeting, p. 55-57. New York, New York, 6-8 May 2003. Jansen, B. J. and Eastman, C. (2003) The Effects of Search Engines and Query Operators on Top Ranked Results, The IEEE 4th International Conference on Information Technology, Coding and Computing, p. 135-139. Las Vegas, Nevada, 28-30 April. Jansen, B. J. and Kroner, G. (2003) The Impact of Automated Assistance on the Information Retrieval Process, The ACM SIGCHI 2003 Conference on Human Factors in Computing Systems, p. 1004-1006. Fort Lauderdale, Florida, 5-10 April. Jansen, B. J. (2002) Towards Implementing a Cognitive Model of Searching, Proceedings of the E-Learning 2002 Conference (Web Track), p. 493-521. Montreal, Canada, 15-19 October. Jansen, B. J. (2002) A Preliminary Mapping of Web Queries Using Existing Image Query Schemes, Proceedings of the E-Learning 2002 Conference (Web Track), p. 485-492. Montreal, Canada, 15-19 October. Jansen, B. J., Spink, A., and Pfaff, A. (2000) Linguistic Aspects of Web Queries, Proceedings of the Annual Meeting of the American Society of Information Science, p. 169-176. Chicago, IL. 13-16 November. Jansen, B. J., Spink, A., Goodrum, A., and Pfaff, A. (2000) Web Query Structure: Implications for IR System Design, Proceedings of the 4" World Multiconference on Systems, Cybernetics and Informatics, p. 50-55. Orlando, FL. 23-26 July. Jansen, B. J. (1999) A Software Agent for Performance Improvement of Existing Information Retrieval Systems, Proceedings of the 1999 International ACM Conference on Intelligent User Interfaces, p. 122-123. Los Angeles, CA. 5-8 January. Smith, T. L., Ruocco, A., and Jansen, B. J. (1999) Digital Video in Education, Proceedings of the ACM Computer Science Education Conference, p. 122-126. New Orleans, LA. 21-25 February. Jansen, B. J., Spink, A., and Saracevic, T. (1999) The Use of Relevance Feedback on the Web: Implications for Web IR System Design, 1999 World Conference on the WWW and Internet, Honolulu, Hawaii. 24-30 October. Jansen, B. J. and Pooch, U. (1999) A Software Agent for Performance Improvement of an Existing Information Retrieval Engine, 5" International Conference on Information Systems Analysis and Synthesis, p. 58-60. Orlando, Florida. 31 July-4 August. Adams, W. J., Jansen, B. J., and Smith, T. L. (1999) Planning, Building, and Using a Distributed Digital Library, Third International Conference on Concepts in Library and Information Science, p. 10-18. Dubrovnik, Croatia. 23-26 May. 60

Paper Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page462 of 883 Refereed Conference Proceedings Smith, T. L., Wolfe, D., and Jansen, B. J. (1999) Digital Video in a Twenty-First Century Classroom, Proceedings of the Information Resources Management Association Conference, Hershey, PA. 16-19 May. Adams, W. J. and Jansen, B. J. (1998) Distributed Digital Library architecture: The Key to Success for Distance Learning, Proceedings of the IEEE Conference on Research Issues in Data Engineering, p. 2-8. Orlando, Florida. 23-24 February. Spink, A., Chang, C., Goz, A., and Jansen, B. J. (1998) User' Interactions with the Excite Web Search Engine: A Query Reformulation and Relevance Feedback Analysis, Proceedings of the Canadian Association of Information Science Conference, p. 342-354. Vancouver, Canada. 5 —10 June. Jansen, B. J., Spink, A., and Saracevic, T. (1998) Searchers, the Subjects They Search, and Sufficiency: A Study of a Large Sample of Excite Searches, Proceedings of the 1998 World Conference on the WWW and Internet, Orlando, Florida. Spink, A., Bateman, J., and Jansen, B. J. (1998) Users’ Searching Behavior on the Excite Web Search Engine, 1998 World Conference on the WWW and Internet, Orlando, Florida, November. Howard, R. and Jansen, B. J. (1998) A proxy server experiment: an indication of the changing nature of the Web, Proceedings of the Seventh International Conference on Computer Communications and Networks, p. 646-649. Lafayette, Louisiana. 12-15 November. Adams, W. J., Jansen, B. J., and Zoller, R. (1998) Usability Measurements in an Undergraduate Programming Course, Software Engineering Conference, Las Vegas, Nevada. Jansen, B. J., Spink, A., and Saracevic, T. (1998) Failure analysis in Query Construction: Data and Analysis from a Large Sample of Web Queries, Proceedings of the 3° ACM Conference on Digital Libraries, p. 289-290. Pittsburgh, PA. 23-26 July. Spink, A., Bateman, J., and Jansen, B. J. (1998) User's Searching Behavior on the EXCITE Web Search Engine, Proceedings of the 19th National Online Meeting, p. 375-386. New York, NY. 12-14 May 1997. Adams, W. J., Howard, R., and Jansen, B. J. (1998) Distributed Digital Libraries: The Key to Success for Distance Learning, Computers and Technology in Education, 1 -5 May. Cancun, Mexico. Jansen, B. J. (1997) An Information Retrieval Application for Simulated Annealing, Proceedings of the 2nd ACM Conference on Digital Libraries, p. 259-260. Philadelphia, PA. 25-28 July. Jansen, B. J. (1997) Simulated Annealing for Query Results Ranking, Computer Science Education Conference, San Jose, CA. 28 — 30 February. 61

Case 18-2868, Document 283, 08/09/2019, 2628241, Page463 of 883 Refereed Conference Proceedings Spink, A., Burkett, L., Spaid, N., Bateman, J., and Jansen, B. J. (1997) Why Users Search the World Wide Web (WWW): The EXCITE Study, First Internet Librarian Conference, Monterey, CA. 16-18 November. Adams, W. J. and Jansen, B. J. (1997) /nformation Technology and the Classroom of the Future, Proceedings of the Society for Information Technology in Education Conference, Orlando, Florida. 7 May. Hamilton, J. A. and Jansen, B. J. (1997) Tactical Network Simulation in the US Army, Simulation Multi-Conference, Atlanta, Georgia. January. Jansen, B. J. and Hamilton, J. A. (1997) Modeling and Simulating an Army Information Support Structure, Simulation Multi-Conference, Atlanta, Georgia. January. Papers Presented at Technical and Professional Meetings An, J., Cho, H.Y., Kwak, H., and Jansen, B. J. (2016) Towards Automatic Persona Generation Using Social Media. The Third International Symposium on Social Networks Analysis, Management and Security (SNAMS 2016), The 4th International Conference on Future Internet of Things and Cloud. 22-24 August. Mukherjee, P. and Jansen, B. J. (2016) The Changing Nature of Viewership: Formality of Social Media Conversations. Workshop on Following user pathways: Using cross platform and mixed methods analysis in social media studies. ACM Conference on Human Factors in Computing Systems (CHI2016), San Jose, CA, USA, 7-12 May. Kwon, S., Abbar, S. and Jansen, B. J. (2016) /dentifying Virality Attributes of Arabic Language News Articles. Qatar Foundation Annual Research Conference 2016 (ARC'16), Doha, Qatar. 22 March. An, J., Kwan, H., Cho, H., Hassen, M.Z., and Jansen, B. J. (2016) Efforts Towards Automatically Generating Personas in Real-time Using Actual User Data. Qatar Foundation Annual Research Conference 2016 (ARC'16), Doha, Qatar. 22 March. Mukherjee, P. and Jansen, B. J. (2015) Correlation of Brand Mentions in Social Media and Web Searching Before and After Real Life Events: Phase Analysis of Social Media and Search Data for Super Bowl 2015 Commercials. 1st International Workshop on Event Analytics using Social Media Data at The IEEE International Conference on Data Mining series (ICDM 2015), Atlantic City, New Jersey, USA, 14 Nov. Mukherjee, P. and Jansen, B. J. (2015) Analyzing the Social Soundtrack From Second Screens Before, During, and After Real-life Events. The First International Workshop on Online Social Networks Technologies, 2015 IEEE Jordan Conference on Applied Electrical Engineering and Computing Technologies (AEECT), Dead Sea, Jordan. 3-5 Nov. 62

Case 18-2868, Document 283, 08/09/2019, 2628241, Page464 of 883 Papers Presented at Technical and Professional Meetings Jansen, B. J., Wong, J. S., Jablokow, K.W., Divinsky, A., Liu, Z., and Pursel, B. (2014) Classifying MOOC Discussion Forum Posts as Information Seeking Interactions and Levels of Cognitive Learning. Workshop on Learning at Scale at ACM CHI Conference on Human Factors in Computing Systems, (CHI 2014), Toronto, CA. 26 April - 1 May. Liu, Z. and Jansen, B. J. (2012) Factors Influencing the Response Rate in Social Question and Answering Behavior. Workshop on Social Media Question Asking at 16th ACM Conference on Computer Supported Cooperative Work and Social Computing (CSCW 2073). 23-27 February. San Antonio, Texas. Jansen, B. J. (2012) Gender Demographic Targeting in Sponsored Search. INFORMS International 2012. 24-27 June. Beijing, China. Jansen, B. J. (2012) Using Mobile Apps to Enhance Classroom Learning. Teaching and Learning with Technology, University Park, PA, 24 March Rosso, M. and Jansen, B. J. (2010) Smart Marketing or Bait & Switch? Competitors’ Brands as Keywords in Online Advertising. 4th Workshop on Information Credibility on the Web (WICOW 2010). World Wide Web Conference (WWW 2010), Raleigh, NC. 26-30 April. Jansen, B. J. (2009) System Controlled Assistance for Improving Search Performance. Human-Computer Interaction and Information Retrieval. Workshop. Washington, DC. 23 October. Jansen, B. J., Zhang, M, Sobel, K, and Chowdury, A, (2009) The Commercial Impact of Social Mediating Technologies: Micro-blogging as Online Word-of-Mouth Branding. ACM Conference on Computer Human Interaction (CHI2009). Boston, Massachusetts. 4 - 9 April. Neale, L., Hunter, L., Jansen, B. J., Murphy, J. (2008) The Google Online Marketing Challenge: A Global Teaching and Learning Initiative. 2008 Society for Marketing Advances Annual Conference. 4-9 November. St Petersburg, Florida. Jansen, B. J., Rosso, M., Russell, D., and Detlor, B. (2008) The Google Online Marketing Challenge: A Multi-Disciplinary Global Teaching and Learning Initiative Using Sponsored Search. 2008 Annual Meeting of the American Society for Information Science and Technology. 24-29 October Columbus, Ohio. Jansen, B. J. (2008). Viewing Searching Systems as Learning Systems. Second Workshop on Human-Computer Interaction and Information Retrieval. 23 October. Redmond, Washington. Murphy, J., Canhoto, A., Hofacker, C., Hunter, L., Jansen, B. J., and Voorhees, C. (2008) The Google Online Marketing Challenge: A Global Teaching and Learning Initiative. 2008 American Marketing Association Summer Marketing Educators' Conference. 8-11 August. San Diego, California. 63

Case 18-2868, Document 283, 08/09/2019, 2628241, Page465 of 883 Papers Presented at Technical and Professional Meetings Reddy, M. and Jansen, B. J. (2008) Learning about Potential Users of Collaborative Information Retrieval Systems. Workshop on Collaborative Information Retrieval, Joint Conference on Digital Libraries (JCDL 2008). 19 June. Pittsburgh, Pennsylvania. Jansen, B. J., Bhavnani, S., Murray, G. C., Spink, A. and Wolfram, D. (2007) Web Log Analysis Panel, 2007 Annual Meeting of the American Society for Information Science and Technology. Milwaukee, Wisconsin. 18-25 October. Spink, A. and Jansen, B. J. (2007) Web Research - Results from Large-Scale Web Data Analysis, ARC Research Network Enterprise Information Infrastructure Workshop on Data From the Field. Sydney, Australia. 24th May. Jansen, B. J. and Spink, A. (2007) The Effect on Click-through of Combining Sponsored and Non-Sponsored Search Engine Results in a Single Listing, 16th International World Wide Web Conference (WWW2007) Workshop on Sponsored Search Auctions. Banff, Canada. 812 May. Paper: http://opim.wharton.upenn.edu/ssa3/pdf/submission_96.pdf Jansen, B. J. (2007) Preserving the Collective Expressions of the Human Consciences, 16th International World Wide Web Conference (WWW2007) Workshop on Query Log Analysis: Social and Technical Challenges. Banff, Canada. 8-12 May. Paper: http:/\www2007.org/workshops/paper_58.pdf Slides: http://querylogs2007.webir.org/slides/JimJansenQL200/7.pdf Jansen, B. J., Smith, B., and Booth, D. (2007) Learning as a Paradigm for Understanding Exploratory Search, Conference on Human Factors in Computing Systems (SIGCHI ), Workshop on Exploratory Search Interfaces. San Jose, California. 28 April - 3 May. Spink, A., Alvarado-Albertorio, F., and Jansen, B. J. (2007) Web Search Behavior: What is Normative ?, Society of Australasian Social Psychologists (SASP) Conference. Brisbane, Australia. 12 — 15 April. Jansen, B. J. and Spink, A. (2006) Characteristics of searching on Web meta-search engines, American Society for Information Science and Technology: Human Computer Interaction Workshop. Austin, TX. 3-9 November. Jansen, B. J. (2006) /mplications of Trust of Sponsored Links for E-commerce Web Searching, 6th Annual SIG-USE Research Symposium. American Society for Information Science and Technology (ASIS&T) Annual Conference. Austin, TX. 4 November. Spink, A. and Jansen, B. J. (2006) Web Searching: Trends and Impacts, Oxford Internet Institute International Symposium. Journal of Information, Communication, Society: 10th Anniversary International Symposium. University of York, UK. 20 — 22 September. http://www.york.ac.uk/res/siru/icsspinketal.htm 64

Case 18-2868, Document 283, 08/09/2019, 2628241, Page466 of 883 Papers Presented at Technical and Professional Meetings Jansen, B. J., Spink, A., Kathura, V., and Koshman, S. (2006) How to Define Searching Sessions on Web Search Engines, Workshop on Web Mining and Web Usage Analysis. The 12th ACM SIGKDD International Conference on Knowledge Discovery and Data Mining (KDD 2006). Philadelphia, Pennsylvania. 20-23 August. Jansen, B. J. (2006) Adversarial Information Retrieval Aspects of Sponsored Search, Second International Workshop on Adversarial Information Retrieval on the Web (AlRWeb 2006). The 29th Annual International ACM SIGIR Conference on Research & Development on Information Retrieval (SIGIR2006). Seattle, Washington. 6-11 August. Jansen, B. J., Ramadoss, R. Zhang, M., and Zang, N. (2006) Wrapper: An Application for Evaluating Exploratory Searching Outside of the Lab, SIGIR 2006 Workshop on Evaluating Exploratory Search Systems. The 29th Annual International ACM SIGIR Conference on Research & Development on Information Retrieval (SIGIR2006). Seattle, Washington. 6-11 August. Buzikashvili, N. and Jansen, B. J. (2006) Limits of the Web Log Analysis Artifacts, Workshop on Logging Traces of Web Activity: The Mechanics of Data Collection, The Fifteenth International World Wide Web Conference (WWW 2006). Edinburgh, Scotland. 22-26 May. Jansen, B. J. (2006) The Wrapper: An Open Source Application for Logging User — System Interactions during Searching Studies, Workshop on Logging Traces of Web Activity: The Mechanics of Data Collection. The Fifteenth International World Wide Web Conference (WWW 2006). Edinburgh, Scotland. 22-26 May. Jansen, B. J., Rieh, S.Y., Spink, A., Wang, P., and Wolfram, D. (2005) Panel Presentation: Internet Usage Transaction Log Studies: The Next Generation, American Society for Information Science & Technology 2005 Annual Meeting. Charlotte, North Carolina. 28 October — 2 November. Toms, E.L., Jansen, B. J., and Muresan, G. (2005) Panel Presentation: Evaluating Success in Search Systems, American Society for Information Science & Technology 2005 Annual Meeting. Charlotte, North Carolina. 28 October — 2 November. Jansen, B. J. (2005) A Multi-Disciplinary, Multi-Level, and Multi-Spectrum View of Interaction, The First Conference of the i-School Community: Bridging Disciplines to Confront Grand Challenges. 28-30 September 2005, State College, PA. Jansen, B. J. and Resnick, M. (2005) Examining Searcher Perceptions of and Interactions with Sponsored Results, Workshop on Sponsored Search Auctions, The Sixth ACM Conference on Electronic Commerce (EC’'05). Vancouver, Canada. 5-8 June. Jansen, B. J. (2005) Automated Searching Assistance for Exploratory Search, Seminar on Exploratory Search Interfaces at the University of Maryland sponsored by the HumanComputer Interaction (HCI) Lab. College Park, Maryland. 2 June. 65

Case 18-2868, Document 283, 08/09/2019, 2628241, Page467 of 883 Papers Presented at Technical and Professional Meetings Shingle, A. Jansen, B. J., and Spink, A. (2005) Television Advertising of Prescription Drugs: A Study of Its Effect on Consumer Web Searching, IEEE 6th International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada, 11-13 April, 2005. Jansen, B. J., Spink, A., and Pederson, J. (2004) An Analysis of Multimedia Searching on AltaVista, Presentation at Workshop on User Searching, World Wide Web Conference, New York, New York, 18 May 2004. De Ycaza, S., Doran, S., Eastman, C., and Jansen, B. J. (2003) Nutritional Information on the Web: An Analysis of Information Sought and Information Provided, South Carolina Nutrition Research Summit, Columbia, SC. 17 October 2004. Jansen, B. J. (1998) An Analysis of User Queries on the Web: The Implications for the Design of Military Information Retrieval Systems, Fifth Annual US Army Research Laboratory and United States Military Academy Technical Symposium, West Point, New York. Jansen, B. J. (1997) Simulated Annealing in Information Retrieval, Fifth Annual US Army Research Laboratory and United States Military Academy Technical Symposium, West Point, New York. Adams, W. J. and Jansen, B. J. (1997) /ntegrating Usability Design Principles into an Existing Engineering Curriculum, The American Society for Engineering Education National Conference, Milwaukee, Wisconsin. Jansen, B. J. and Adams, W. L. (1997) Integrating User Centered Design into an Introductory Engineering Course, American Society for Engineering Education Zone 1 Meeting, West Point, New York. scholarly Reports Jansen, B. J. (2011) The civic and community engagement of religiously active Americans. Pew Internet & American Life Project, Pew Research Center. 13 December. http://pewinternet.org/Reports/201 1/Social-side-of-religious.aspx Jansen, B. J. (2010) 65% of Internet Users Have Paid for Online Content. Pew Internet & American Life Project, Pew Research Center. 30 December. http://www.pewinternet.org/Reports/2010/Paying-for-Content.aspx Jansen, B. J. (2010) Use of the internet by higher income households. Pew Internet & American Life Project, Pew Research Center. 24 November. http://www.pewinternet.org/Reports/2010/Better-off-households.aspx Jansen, B. J. (2010) Online Product Research. Pew Internet & American Life Project, Pew Research Center. 29 September. http://pewinternet.org/Reports/2010/Online-Product-Research.aspx 66

Case 18-2868, Document 283, 08/09/2019, 2628241, Page468 of 883 Funded Projects, Grants, Commissions, and Contracts 2015 - 2014 Title: Web Analytics for a Research University Library Granting Agency: Penn State, University Library Total Amount: $19,717 Role: Principal Investigator 2015 - 2013 Title: Exploring Scholarly Discourse in MOOC Discussion Forums Granting Agency: Penn State, Center for Online Innovation in Learning Total Amount: $30,383 Role: Principal Investigator 2014 - 2010 Title: Broadband to Support SMEs in Pennsylvania Granting Agency: Commonwealth of Pennsylvania Total Amount: $500,000 Role: Faculty Investigator ($70,000) 2014 - 2010 Title: Semantic CiteSeerX Granting Agency: National Science Foundation Total Amount: $1,100,000 Role: Principal Investigator ($130,000) 2011 - 2008 Title: Affective and Cognitive Factors Affecting the Evaluation of Search Engines by Users Granting Agency: Google Amount: $50,000 Role: Principal Investigator 2011 - 2009 Title: Using Keyword Advertising for Economic and Workforce Development Granting Agency: The Pennsylvania State University Amount: $25,000 Role: Principal Investigator 2011 - 2010 Title: Toolkits for Deployable Best Practices Granting Agency: Office of Naval Research STTR Phase Il Total Amount: $750,000 Role: Principal Investigator ($87,500) 2011 - 2010 Title: RAPID: Text Message-based Infrastructure for Emergency Response Granting Agency: National Science Foundation Total Amount: $75,000 Role: Principal Investigator ($15,000) 67

Case 18-2868, Document 283, 08/09/2019, 2628241, Page469 of 883 Funded Projects, Grants, Commissions, and Contracts 2009 - 2008 2009 - 2007 2009 - 2006 2008 - 2005 2009 - 2007 2009 - 2008 2007 - 2006 2005 - 2004 Title: Toolkits for Deployable Best Practices Granting Agency: Office of Naval Research STTR Phase | Total Amount: $100.000 Role: Principal Investigator ($15,000) Title: REU Supplement for CRI: Collaborative: Next Generation CiteSeer Granting Agency: National Science Foundation Amount: $12,000 Role: Co-Principal Investigator ($12,000). Title: Synchronized Interactions Among Users, Systems, and Information Granting Agency: Air Force Research Lab Amount: $463,000 Role: Principal Investigator ($463,000). Title: The Next Generation CiteSeer Granting Agency: National Science Foundation Amount: approximately $1,444,984 Role: Co-principal Investigator with Dr. Lee Giles, Dr. Susan Gauch, and Dr. Jack Carroll ($48,701) Title: Triggers in Collaborative Information Searching Granting Agency: National Science Foundation Amount: $76,000 Role: Co-principal Investigator with Dr. Madhu Reddy ($18,119) Title: REU Supplement for Triggers in Collaborative Information Searching Granting Agency: National Science Foundation Amount: $12,000 Role: Co-principal Investigator with Dr. Madhu Reddy ($6,000) Title: REU Supplement for CRI: Collaborative: Next Generation CiteSeer Granting Agency: National Science Foundation Amount: $9,000 Role: Co-Principal Investigator ($9,000). Title: Design of Tools for Information Seeking, Management, and Analysis for a Lessons Learned Knowledge System Granting Agency: US Marine Corps Research University Amount: $500,000 Role: Co-Principal Investigator ($83,957) 68

Case 18-2868, Document 283, 08/09/2019, 2628241, Page470 of 883 Funded Projects, Grants, Commissions, and Contracts 2005 Title: Knowledge Management Granting Agency: US. Department of Defense, Defense Threat Reduction Agency (DTRA) Amount: $625,832 Role: Co-Principal Investigator ($18,439). 2006 - 2005 Title: REU Supplement for CRI: Collaborative: Next Generation CiteSeer Granting Agency: National Science Foundation Amount: $6,000 Role: Co-Principal Investigator ($6,000). 1998 -1996 Title: The use of software agents in information retrieval. Granting Agency: Army Research Laboratory Amount: $68,000 Role: Principal Investigator ($68,000) 1998 Title: Information Searching on Web Search Engines Granting Agency: Army Research Laboratory Amount: $5,000 Role: Principal Investigator ($5,000) 1997 Title: Software agents for information retrieval. Granting Agency: Army Research Laboratory Amount: $5,000 Role: Principal Investigator ($5,000) Software Developed Software Development: Client-side Application for Automated Searching: that automates searching tactics via user implicit feedback. Software Development: Application for Real-time Evaluation of Search Engine Performance: that automates the evaluation of Web search engines. Teaching At The Pennsylvania State University (current — 2002), | have taught a variety of information technology-related courses, including the undergraduate capstone project leadership course, the introductory freshman course, online marketing, graduate seminar course, and a graduate course on human information interaction. Additionally, | have mentored students in a variety of independent studies and have been on several course development committees. At The Pennsylvania State University (current — 2002): 69

Case 18-2868, Document 283, 08/09/2019, 2628241, Page471 of 883 Teaching e Committee Lead, curriculum development team for a college-level executive masters program. e Committee Lead, curriculum development committee for re-design of the undergraduate senior — level capstone course. e Committee Member, curriculum development team for re-design of the undergraduate freshmen level introductory course. e Committee Member, curriculum development team for the establishment of a university-wide Business Analytics minor e Faculty Lead, development team for the establishment of a university-wide professional library certification program e Committee Member, curriculum development team for the establishment of a college Entrepreneurship minor e Course Development: (1) undergraduate capstone course in IT project management, (2) graduate course in information searching, (3) undergraduate course in keyword advertising, (4) graduate course in web analytics, (5) undergraduate course in entrepreneurship technology 2015 — Mentor for one team in the Google Final 15 in The Google Online Marketing Challenge for 2014. The team was in the top fifteen from 4,000 teams from around the world (top 0.4%). Mentor for team in the Google Non-profit Challenge for 2014. The teams were the top more than 4,000 teams from around the world (top 0.4%). 2014 — Mentor for three teams in the Global Final 15 in The Google Online Marketing Challenge for 2013. The teams were in the top fifteen from 4,000 teams from around the world (top 0.4%). Mentor for two teams in the Google Media Marketing Challenge for 2013. The teams were the top more than 4,000 teams from around the world (top 0.4%). 2013 — Mentor for one team in the Global Final 15 in The Google Online Marketing Challenge for 2012. The team was in the top fifteen from more than 4,000 teams from around the world (top 0.4%). 2012 — Mentor for three teams in the Global Final 15 in The Google Online Marketing Challenge for 2011. The three teams were in the top fifteen from 4,000 teams from around the world (top 0.4%). 2010 — Mentor for two teams in the Global Final 15 in The Google Online Marketing Challenge for 2009. The two teams were in the top fifteen from 3,000+ teams from around the world (top 0.5%). Had eight other teams get honorable mention by placing in the Top 100 Global Teams and five other teams place in the Top 10% of all teams. 70

Case 18-2868, Document 283, 08/09/2019, 2628241, Page472 of 883 Teaching 2010 — Mentor for two student teams that took 1*' and 3™ in the Penn State IdeaPitch Competition, which is a university wide Penn State entrepreneurship competition. 2009 — Mentor for three teams in the Global Final 15 in The Google Online Marketing Challenge for 2009. The three teams were in the top fifteen from 2,107 teams from around the world. Had seven other teams get honorable mention by placing in the top 50 teams in the Americas region. 2009 - Schreyer Honors College Teaching Grant Recipient for developing multi-disciplinary keyword advertising, marketing, and technology course. 2008 — Mentor for the winning team in the Americas region in The Google Online Marketing Challenge for 2008. One of the top four teams from 1,620 teams from around the world. Won a trip to the GooglePlex with the students, plus the students all won laptops. Had two other teams get honorable mention by placing in the top 50 teams in the Americas region. 2008 — Selected as Faculty Marshall by Student Marshall of Computer Science and Engineering Department, College of Engineering, The Pennsylvania State University as faculty member who had the biggest impact on student's academic career 2008 — Professor of the Year nominee for College of Information Sciences and Technology, The Pennsylvania State University, 16802 2003 Selected as Faculty Marshall by Student Marshall of School of Information Sciences and Technology, The Pennsylvania State University as faculty member who had the biggest impact on student’s academic career Guest lecturer for a month (2000) at the Korean Military Academy in Seoul, Republic of Korea. At the University of Maryland (Asian Division) (2000 — 1999), taught courses on Web/Internet and multimedia design. At the United States Military Academy (1999 — 1996), | taught several computer sciencerelated courses including introductory programming, advanced programming, microcomputing, and databases. Also, mentored students in a variety of independent studies. As executive officer for the department (1999 — mid 1997), was responsible for course scheduling, instructor assignments, classroom allocation, student counseling, as well as many other duties concerning the day-to-day operation of the department. 71

Case 18-2868, Document 283, 08/09/2019, 2628241, Page473 of 883 Membership on Degree Committees The Pennsylvania State University College of Information Sciences and Technology Chair or Co-Chair Partha Mukherjee (Committee Chair) (PhD degree expected in 2016) Alex Brown (Committee Chair) (M.S. degree expected in 2016) Zhe Liu (Committee Chair) (PhD degree conferred in 2014) Dan Coughlin (Committee Chair) (PhD degree conferred in 2014) Carolyn Hafernik (Committee Chair) (M.S. degree conferred in 2013) Adan Ortiz-Cordova (Committee Chair) (M.S. degree conferred in 2013) Jian-Syuan Wong (Committee Chair [until 2016]) (PhD degree expected in 2018) Steve Carmen (Committee Chair [until 2013]) (M.S. degree conferred in 2013) Kathleen Moore (Committee Chair [until 2012]) (PhD degree expected in 2015) Mimi Zhang (Committee Chair) (PhD degree conferred in 2010) Mike Hills (Committee Chair) (PhD degree conferred in 2010) Hyun-Woo Kim (Committee Co-Chair) (M.S. degree conferred in 2010) Young Shin Kim (Committee Co-Chair) (M.S. degree conferred in 2010) Committee Member Eric McMillan (Committee Member) (PhD degree expected in 2017) Nathan McNeese (Committee Member) (PhD degree conferred in 2014) Patricia Spence (Committee Member) (PhD degree conferred in 2013) Arvind Karunakaran (Committee Member) (M.S. degree conferred in 2011) Yusuf Raza (Committee Member) (M.S. degree conferred in 2009) Sharoda Paul (Committee Member) (PhD degree conferred in 2009) Allison Morgan (Committee Member) (PhD degree conferred in 2008) Mithu Bhattacharya (Candidacy Committee Member, 2005) Scott Robertson (Candidacy Committee Chair, 2004) The Pennsylvania State University Workforce Education and Development Program, College of Education John Dolan (Committee Co-Chair [until 2012]) (PhD degree expected in 2013) The Pennsylvania State University School of Hospitality and Management Lu Zhang (Committee Co-Chair) (M.S. degree conferred in 2009) The Pennsylvania State University Department of Industrial and Manufacturing Engineering Himanshu Sharma (Committee Chair) (M.S. degree conferred in 2005) Sourav Sengupta (Committee Chair) (M.S. degree conferred in 2005) Ying Zhang (Committee Chair) (M.S. degree conferred in 2008) The Pennsylvania State University Department of Electrical Engineering Vijay Mohan (Committee Co-Chair) (M.S. degree conferred in 2009) Dheepak Ramaswamy (Committee Co-Chair) (M.S. degree conferred in 2009) Ashish Kathuria (Committee Chair) (M.S. degree conferred in 2007) a

Case 18-2868, Document 283, 08/09/2019, 2628241, Page474 of 883 Membership on Degree Committees The Pennsylvania State University Department of Computer Science and Engineering Yanjun Gao (Committee co-Chair) (PhD degree expected in 2018) Chandrika Gopalakrishna (Committee Chair) (M.S. degree conferred in 2008) The University of Pittsburgh School of Information Sciences Department of Library and Information Science Zhen Yue (Committee Member) (Ph.D. degree conferred in 2014) Minsoo Park (Committee Member) (Ph.D. degree conferred in 2008) Rutgers, the State University of New Jersey School of Communication, Information and Library Studies Yuelin Lee (Committee Member) (Ph.D. degree conferred in 2008) The Pennsylvania State University Schreyer Honors College, thesis advising Megan Krause (B.S. degree expected 2107) Allie Whitman (B.S. degree expected 2106) Adan Ortiz-Cordova (B.S. degree conferred 2011) Bradley Shively (B.S. degree conferred 2010) Kate Sobel (B.S. degree conferred 2010) Steven Troxell (B.S. degree conferred in 2008) Steven Clancy (B.S. degree conferred in 2007) Paulo Molina (B.S. degree conferred in 2004) Chris Catalano (B.S. degree conferred in 2004) Andy Shingle (B.S. degree conferred in 2004) Supervision of Other Undergraduate Research Student Degree Major University Role Arielle Amchin BS Marketing Penn State Research Mentor Arun Das BS CS Brown University Research Mentor Manisha BS MIS Carnegie Mellon Qatar paeanuds ics Dareddy Satyajit BS CS Bharati Vidyapeeth Narayanan University Research Mentor Will Berkheiser BS IST Penn State Work Study Mentor http://studentaid.psu.edu/typesof-aid/work-study-andemployment/work-study/about Pat Bonner BS IST Penn State Research Mentor Danielle Booth BS IST Penn State Research Mentor Anna Brown BS IST Penn State Research Mentor Nicole Butera BS Chemistry Penn State Women in Science and Engineering Research 73

Case 18-2868, Document 283, 08/09/2019, 2628241, Page475 of 883 Supervision of Other Undergraduate Research Student Chris Ciamacca Karen Lee Dana Kracow Daehee Park Melissa Reizner Mitchell Rukat Paul Rinaldi Simone Schuster Laura Solomon Meng Ting Sun Pete Smith Megan Tan Courtney Weaver Degree BS Professional Service Editorial Boards Current — 2016 Current — 2016 Current — 2012 Current — 2011 Current — 2009 Current — 2009 Current — 2006 Current — 2006 Current — 2004 2016 — 2011 2011 - 2004 Major IST IST Advertising Advertising Accounting IST Marketing IST University Penn State Penn State Penn State Penn State Penn State Penn State Penn State Penn State Penn State Penn State Penn State Penn State Penn State Role (WISER) Mentor http://pa.spacegrant.org/wiser Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Research Mentor Editor-in-chief, Information Processing & Management (Elsevier) Editorial Board Member, Information Discovery and Delivery Editorial Advisory Board Member, Social Networks Editorial Advisory Board Member, International Journal of Electronic Business Editorial Advisory Board Member, Journal of the American Society for Information Science and Technology Editorial Advisory Board Member, Future Internet Editorial Panel, International Journal of Internet Science Editorial Advisory Board Member, Information Research Editorial Advisory Board Member, Information Processing & Management Editor-in-chief, Internet Research (Emerald) Editorial Advisory Board Member, Journal of Internet Research 74

Case 18-2868, Document 283, 08/09/2019, 2628241, Page476 of 883 Professional Service Editorial Boards 2010 - 2004 Editorial Advisory Board Member, Library and Information Science Journal 2008 - 2004 Associate Editor (Book Reviews), Information Processing & Management 1996 -—1998 Student Editor, SIG Computer Human Interaction SIGCHI Bulletin Professional Service Tenure Letters 2016 2016 2015 2013 2013 2012 2012 2012 2010 2009 External Tenure Letter Writer for faculty member of School of Business, McMaster University External Tenure Letter Writer for faculty member of Department of Library and Information Science, The Catholic University of America External Tenure Letter Writer for faculty member of School of Communication and Information, Rutgers University External Tenure Letter Writer for faculty member of College of Information Science and Technology, Drexel University External Tenure Letter Writer for faculty member of Graduate School of Management, University of Haifa External Tenure Letter Writer for faculty member of Faculty of Social Sciences, Barllan University External Tenure Letter Writer for faculty member of Henry B. Tippie College of Business, The University of lowa External Tenure Letter Writer for faculty member of School of Business, North Carolina Central University External Tenure Letter Writer for faculty member of School of Business Administration, Bar Ilan University, Israel External Tenure Letter Writer for faculty member of Computer Information Systems Department, Bentley University 75

Reviewer Award Case 18-2868, Document 283, 08/09/2019, 2628241, Page477 of 883 Professional Service Ad hoc Reviewing 2016 2015 2014 2013 2012 2011 2010 2009 Reviewer, IEEE Systems, Man and Cybernetics, Computers in Human Behavior, International Journal of Human Computer Interaction, Cornell Hospitality Review Reviewer, Transactions on Intelligent Systems and Technology, Journal of Organizational Computing and Electronic Commerce, European Journal of Marketing, Journal of Information Management, Transactions on Management Information systems Reviewer, MIS Quarterly, Journal of Organizational Computing and Electronic Commerce, Computers in Human Behavior, Journal of Documentation, IEEE Systems, Man and Cybernetics, Tourism Management Reviewer, Technological Forecasting & Social Change, IEEE Systems, Man and Cybernetics, International Journal of Electronic Commerce. ACM Transactions on the Web, Journal of Interactive Marketing, Journal of Electronic Commerce Research (2x Research (2x), Electronic Commerce Research, Communications of the Association for Information systems, Transactions on Computer-Human Interaction, Information Research, Information and Management Reviewer, Electronic Commerce Research, International Journal of Information Management, Journal of Information Science, Communication Research, International Journal of Internet Science, Journal of Organizational Computing and Electronic Commerce, Social Science Computer Review, Information Research, MIS Quarterly, Journal of Organizational Computing and Electronic Commerce, Library and Information Science, IEEE Transactions on Multimedia, Advances in HumanComputer Interaction (2x), Journal of Theoretical and Applied Electronic Commerce Research (3x), ACM Transactions on Computer-Human Interaction Reviewer, IEEE Transactions on Multimedia, Information Technology and People, Journal of Computer-Mediated Communication (2x), Sage Publishing, Electronic Commerce Research, International Journal of Electronic Commerce, Journal of Interactive Marketing (2x), ACM Transactions on the Web, ACM Transactions on Computer-Human Interaction Reviewer, International Journal of Information Management (2x), ACM Transactions on the Web, Social Science Computing Review, MIS Quarterly, International Journal of Human-Computer Studies, PLoS One, Information Research, Netherlands Organisation for Scientific Research, Computing Surveys, Information Sciences, Future Internet, International Information and Library Review, International Journal of Internet Science, Behaviour & Information Technology, Journal of Media Economics 2010 Reviewer, Internet Research Reviewer, The Computer Journal, ACM Transactions on the Web, International Journal of Electronic Commerce, Data & Knowledge Engineering Journal, ACM Transactions on Information Systems 76

Case 18-2868, Document 283, 08/09/2019, 2628241, Page478 of 883 Professional Service Ad hoc Reviewing 2008 2007 2006 2005 2005 2004 2003 2002 2001 1999 1998 Reviewer, Journal of the Academy of Marketing Science, ACM Transactions on the Web, ACM Transactions on Information Systems, Decision Support Systems, New Media & Society, IEEE Internet Computing, Journal of Service Science and Management, IEEE Transactions on Professional Communication, International Journal of Knowledge Management Studies Reviewer, Simulation Modelling Practice and Theory, ACM Transactions on Information Systems Reviewer, Journal of Information Science, ACM Transactions on Information Systems Reviewer, Journal of Medical Internet Research, ACM Transactions on Information systems Reviewer, IEEE Systems. Man and Cybernetics Journal, Computer Networks Journal Reviewer, Information Retrieval, Information Processing & Management, Journal of Web Engineering, Journal of Library & Information Science Research Reviewer, IEEE Proceedings-Software, Information Processing & Management Reviewer, Journal of Informing Science, Information Processing & Management, The World Wide Web Journal Reviewer, International Journal of Human Computer Studies, Information Processing & Management Reviewer, Information Processing & Management Reviewer, Computer Science Education Journal, Information Processing & Management Professional Service Grant Reviewing 2015 2014 2013 2012 Reviewer, Qatar Research Program, Qatar Foundation Reviewer, grant panelist for National Science Foundation, CISE Research Infrastructure (CRI) program February 2014. Reviewer for grant proposal for Reviewer, American Association for the Advancement of Science (AAAS) Research Competitiveness Program Grant Proposal for funding through the Maine Technology Institute's Development Awards Reviewer, Army Research Lab Grant Proposal 77

Case 18-2868, Document 283, 08/09/2019, 2628241, Page479 of 883 Professional Service Grant Reviewing 2011 2011 2010 2010 2008 2007 2007 2004 Reviewer, National Science Foundation Grant Proposal Reviewer, American Association for the Advancement of Science (AAAS) Research Competitiveness Program Grant Proposal for funding through the Maine Technology Institute's Development Awards Reviewer, Standard Research Grants program of the Social Sciences and Humanities Research Council of Canada (SSHRC) Grant Proposal Reviewer for grant proposal for Reviewer, American Association for the Advancement of Science (AAAS) Research Competitiveness Program Grant Proposal for funding through the Maine Technology Institute's Development Awards Reviewer, Israel Science Foundation Grant Proposal Reviewer, Air Force Office of Scientific Research Grant Proposal Reviewer, Israel Science Foundation Grant Proposal Grant Reviewer, Arts and Humanities Research Board Grant Proposal, Whitefairs, Lewins Mead, Bristol, UK, BS1 2AE Professional Service Other 2016 2016 — 2015 2014 2012 2012 Special Issue on Computational Advertising, IEEE Intelligent Systems. Guest Editors: Yanwu Yang, Huazhong University of Science and Technology, China; Yinghui Yang, University of California, Davis, US; Bernard J. Jansen, Qatar Computing Research Institute, HBKU; Mounia Lalmas, Yahoo Labs, UK. 2007 Academic Panelist for The Google Online Marketing Challenge (http:/Awww.google.com/onlinechallenge/). Based on registrations from more than 100 countries and more than 11,000 student teams, the Challenge may be the largest, worldwide educational course ever done. External Examiner for Spanish PhD thesis (Universitat Pompeu Fabra Barcelona) 2013 Faculty Advisor for the Penn State Digital Marketing Association External Examiner for Australian PhD thesis (Queensland University of Technology) 2011 Member, Research Committee, Search Engine Marketing Professional Organization (SEMPO) 78

Case 18-2868, Document 283, 08/09/2019, 2628241, Page480 of 883 Professional Service Other 2011 — 2009 Chair of the American Society for Information Science and Technology (ASIST) Information Science Education Committee 2010 Reviewer, Cambridge University Press book proposal 2010 Reviewer, Cambridge University Press book proposal 2010 External Examiner for Australian PhD thesis (University of Sydney) 2009 — 2006 Chair of the American Society for Information Science and Technology (ASIST) Information Science Education Committee Dissertation Jury 2008 External Examiner for Australian PhD thesis (The University of New South Wales) 2008 External Examiner for Australian PhD thesis (The University of New South Wales) 2008 Guest Editor, International Journal of Electronic Business (IJEB). Special Issue on Sponsored Search 2007 External Examiner for Australian PhD thesis (Monash University) 2007 Guest Editor, with Andy Edmond, Kirstie Hawkey, Melanie Kellar, and Don Turnbull. Journal of Web Engineering. Special Issue on Logging Traces of Web Activity 2006 Guest Editor, Bulletin of the American Society for Information Science and Technology. Special Issue on Paid Search, January 2006 1995 -1994 President, Computer Science Graduate Students Association, Texas A&M University, College Station, Texas. Professional Service Conference Activities 2016 Chair, Program Committee, The Second International Workshop on Online Social Networks Technologies (OSNT-2016), 13th ACS/IEEE International Conference on Computer Systems and Applications AICCSA 2016. 29 November - 2 December. 2016 Chair, Program Committee, The Third International Workshop on Social Networks Analysis, Management and Security (SNAMS - 2016), The 4th International Conference on Future Internet of Things and Cloud (FiCloud-2016), Vienna, Austria. 22-24 August. 2016 Reviewer, Papers and Posters, 79th Annual Meeting of the American Society for Information Science and Technology (ASIST 2016). Copenhagen, Denmark. 14-18 October. oo

Case 18-2868, Document 283, 08/09/2019, 2628241, Page481 of 883 Professional Service Conference Activities 2015 2015 2015 2014 2014 2014 2013 2013 2013 2013 2013 2012 2011 2011 2011 Program Committee, 7" International Joint Conference on Knowledge Discovery, Knowledge Engineering and Knowledge Management, Lisbon, Portugal. 12-14 Nov. Meta-Reviewer, Papers and Posters, 78th Annual Meeting of the American Society for Information Science and Technology (ASIST 2015). St. Louis, Mo. 6-10 November. Reviewer, ACM CHI Conference on Human Factors in Computing Systems, Seoul, South Korea. 18-23 April. Reviewer, Papers and Posters, 77th Annual Meeting of the American Society for Information Science and Technology (ASIST 2014). Montreal, Canada. 31 October - 4 November. Program Committee: 3% International Information Systems for Crisis Response and Management Conference (ISCRAM 2014), State College, PA. May 2014. Reviewer, ACM CHI Conference on Human Factors in Computing Systems, Toronto, Canada. 26 April — 1 May. Reviewer, Papers, 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Reviewer, Posters, 76th Annual Meeting of the American Society for Information Science and Technology (ASIST 2013). Montreal, Canada. 1-6 November. Reviewer, 22™ International World Wide Web Conference (WWW 2013). 13-17", May, Rio de Janeiro, Brazil. Program Committee: European Conference on Information Retrieval (ECIR 2013) Workshop on Group Membership and Search (GRUMPS), 24 March, Moscow, Russia Program Committee: Sixth ACM WSDM Conference on Web Search and Data Mining Workshop on Web Search Click Data, 4-8 February, Rome, Italy. Program Committee: Fourth Information Interaction in Context Conference (IIIX 2012), Nijmegen, the Netherlands, 21-24 August 2012. Session Track Chair, 74" Annual Meeting of the American Society for Information Science and Technology (ASIST 2011). 9-13 October. New Orleans, LA. Program Committee, iConference. Toronto, Canada, 7-10 February. Program Committee: 33 European Conference on Information Retrieval (ECIR 2011), Best Paper Committee, Dublin, Ireland, 19-21 April 2011 80

Case 18-2868, Document 283, 08/09/2019, 2628241, Page482 of 883 Professional Service Conference Activities 2011 2011 2011 2011 2010 2010 2010 2010 2009 2009 2009 2009 2009 2009 2008 Program Committee: 33 European Conference on Information Retrieval (ECIR 2011), Workshop on Information Retrieval Over Query Sessions, Dublin, Ireland, 19-21 April 2011. Program Committee: 12" ACM Conference on Electronic Commerce (EC11). San Jose, CA. 5-9 June. Program Committee: Conference on Multilingual and Multimodal Information Access Evaluation (CLEF 2011). Amsterdam, the Netherlands, 19-22 September 2011. Program Committee: 33 European Conference on Information Retrieval (ECIR 2011). Dublin, Ireland. 18-21 April. Program Committee, American Society for Information Science and Technology Annual Meeting 2010. Pittsburgh, PA. 22-27 October. Program Committee: Conference on Multilingual and Multimodal Information Access Evaluation (CLEF 2010). Padua, Italy, 20-23 September. Program Committee: LREC 2010 Workshop on Web Logs and Question Answering (WLQA2010). Malta, 22 May. Program Committee: 32° European Conference on Information Retrieval (ECIR 2010). Keynes, UK. 28-31 March. Program Committee: Web Information and Data Management. 19" International Conference on Information and Knowledge Management (CIKM 2009). Hong Kong. 6 November. Program Committee: Workshop on the Analysis of System Logs. 22"? ACM Symposium on Operating Systems Principles. Big Sky, MT.14 October. Program Committee: Collaborative Information Behavior. GROUP 2000. Sanibel Island, Florida. 10 May. Program Committee: Qualitative and Quantitative Methods in Libraries International Conference (QQML2009). Chania, Crete, Greece, 26-29 May. Program Committee: 31% European Conference on Information Retrieval (ECIR 2009). Toulouse, France. 6-9 April. Reviewer, ACM Conference on Computer Human Interaction 2009 (CHI 2009), Boston, MA, 4 — 9 April. Reviewer, 18" Conference on Information and Knowledge Management (CIKM 2008). Napa Valley, California. 26-30 October. 81

Case 18-2868, Document 283, 08/09/2019, 2628241, Page483 of 883 Professional Service Conference Activities 2008 2008 2008 2008 2007 2007 2007 2007 2007 2007 2007 2007 2006 2006 2006 Program Committee: Workshop on Human-Computer Interaction and Information Retrieval (HCIR 2008). Redmond, Washington.23 October. Program Committee: 1° Information Interaction in Context Symposium (liiX 2008). London, United Kingdom. 14-17 October. Program Committee: 2008 Ad Auctions Workshop. ACM Conference on Electronic Commerce in Chicago, IL. 8-9 July. Reviewer, Southern Association for Information Systems Conference (SAIC 2008), Richmond, VA, USA 13-15 March. Program Committee, IEEE International Conference on Intelligence and Security Informatics 2007 (ISI 2007), New Brunswick, New Jersey. 23-24 May, 2007 Reviewer, Graphics Interface 2007, Montréal, Canada, 28 — 30 May 2007. Reviewer, American Society for Information Science and Technology Annual Meeting 2007. Milwaukee, Wisconsin. 18-25 October. Program Committee, 8" World Congress on the Management of eBusiness. Toronto, Canada. 11-13 July. Program Committee, WWW/'07 Workshop on Query Log Analysis: Social and Technological Challenges. World Wide Web 2007, Banff, Alberta, Canada. 8 May. Program Committee, WWW’'07 Workshop on Sponsored Search. World Wide Web 2007, Banff, Alberta, Canada. 8 May. Program Committee, Chi'07 Workshop on Exploratory Search and HCI: Designing and Evaluating Interfaces to Support Exploratory Search Interaction. ACM CHI2005, Conference on Human Factors in Computing Systems (CHI’07), San Jose, CA. 29 April 2007. Program Committee, IEEE Intelligence and Security Informatics Conference (ISI 2007), New Brunswick, NJ. 23 — 24 May, 2007. Program Committee: 2006 Research Symposium of the Special Interest Group on Human-Computer Interaction. American Society for Information Science and Technology. Austin, Texas. 5 November 5, 2006 Reviewer, Hawaii International Conference on System Sciences 2007. Waikoloa, Big Island, Hawaii. 3-6 January, 2007. Program Committee: IEEE Information Technology: New Generations (ITNG) 2006, Las Vegas, NV. 16 -19 April 2007. 82

Case 18-2868, Document 283, 08/09/2019, 2628241, Page484 of 883 Professional Service Conference Activities 2006 2006 2006 2006 2006 2006 2006 2006 2006- 2002 2006 2005 2005 2004 2004 1998 1998 Reviewer for SIGIR 2006 Workshop on Evaluating Exploratory Search Systems. The 29" Annual International ACM SIGIR Conference on Research & Development on Information Retrieval (SIGIR2006). 6-11 August. Seattle, Washington. Program Committee: 4" International Conference on Information Technology: New Generations, 16-19 April, 2007, Las Vegas, Nevada. Program Committee: 1*' Information Interaction in Context Symposium (liiX symposium). Copenhagen, Denmark. 18-20 October 2006. Program Committee: IEEE Information Technology: New Generations (ITNG) 2006, Las Vegas, NV. 10 — 12 April 2006. Reviewer, The Fourth Annual Pre-ICIS Workshop on HCI Research in MIS, International Conference on Information Systems, 2005. Reviewer, Human Factors and Ergonomics Society 49" Annual Meeting, 2005. Program Committee: IEEE 6" International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada. 5-7 April 2005. Program Committee: the 5" International Conference on Conceptions of Library and Information Science, Glasgow, Scotland, 6-9 June 2005. Reviewer, ACM SIGIR International Conference on Information Retrieval. Session Track Co-chair, Web Searching Sessions (Three tracks), the IEEE 5™ International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada. 4-6 April 2005. Program Committee, IEEE 6" International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada. 5-7 April, 2005. Program Committee, the 5" International Conference on Conceptions of Library and Information Science, Glasgow, Scotland, 6-9 June 2005. Session Track Co-chair, Web Searching Sessions (Three tracks), the IEEE 5" International Conference on Information Technology, Coding and Computing. Las Vegas, Nevada. 5-7 April, 2004. Reviewer, ACM CHI2005, Conference on Human Factors in Computing Systems Session Moderator, New Engineering Educators Conference, June 1998, Seattle, Washington. Co-organizer for ACM Computer Science Education Research Competition, February 1998, Atlanta, Georgia. 83

Keynote Keynote Keynote Case 18-2868, Document 283, 08/09/2019, 2628241, Page485 of 883 Professional Service Conference Activities 1998 Reviewer, New Engineering Educators Conference 1998 Reviewer, American Society for Engineering Education National Conference 1997 Session Moderator for American Society for Engineering Education National Conference, June 1997, Milwaukee, Wisconsin. Advisory Boards Current - 2012 CLAK Impressions http://www.linkedin.com/company/clak-impressions Current - 2010 The Pennsylvania Technical Assistance Program (PennTAP), http://penntap.psu.edu/action-council/ Current - 2010 Innoblue, http://innoblue.org/ 2016 - 2007 Global Academic Panel, Google Online Marketing Challenge, http://www.google.com/onlinechallenge/discover/judging-panel.html 2012 - 2010 Chief Marketing Officer (CMO Council) Advisory Board for research initiative, Localize to Optimize Sales Channel Effectiveness 2012 - 2010 Jabbit Board of Advisors, http://www.jabbit.com/ Invited Talks (Selected) Keynote, 2016 Sixth National Doctoral Forum of Information Science, 7-18 July 2016, Tianjin, China. http://jimjansen.blogspot.ga/2016/07/keynote-speaker-at-2016-sixth-national.html Keynote, The /th International IEEE on Information and Communication Systems (ICICS 2016), 5-7 April, Irbid, Jordan. Keynote, The 10th International ACM Conference on Ubiquitous Information Management and Communication (IMCOM 2016), 4-6 January, Danang, Vietnam. http://jimjansen.blogspot.ga/2015/12/imcom-2016-keynote-transformed-role-of.html Presentation, Sungkyunkwan University (Sowan Campus), 23 April 2015, Seoul, South Korea. http://jimjansen.blogspot.com/2015/04/visit-to-department-of-interaction.html Presentation, National Research University Higher School of Economics, 10 March 2014, St. Petersburg, Russia http://jimjansen.blogspot.com/2014/03/presentation-at-national-research.html 84

Keynote Keynote Case 18-2868, Document 283, 08/09/2019, 2628241, Page486 of 883 Invited Talks (Selected) Presentation, Yandex, 11 March 2014, St. Petersburg Russia. http://jimjansen.blogspot.com/2014/03/visit-to-yandex-headquarters-in-st.html Presentation, Sungkyunkwan University (Sowan Campus), 20-21 June 2013, Seoul, South Korea. http://jimjansen.blogspot.com/2013/06/research-workshop-discussion-on-web.html Presentation, Library and Information Science Department and College of Information and Media, Duksung Women’s College, 19 June 2013, Seoul, South Korea. http://jimjansen.blogspot.com/201 3/06/theoretical-constructs-of-searching-and.html Presentation, Library and Information Science Department, College of Liberal Arts, Sungkyunkwan University, 18 June 2013, Seoul, South Korea. http://jimjansen.blogspot.com/2013/06/keyword-advertising-research. html Presentation, Qatar Computer Research Institute, 24-29 April 2013, Doha, Qatar. http://jimjansen.blogspot.com/2013/04/research-presentation-to-folks-at-qatar.html Presentation, Department of Decision Sciences, College of Business and Public Administration, Old Dominion University, 14-15 April 2013, Norfolk, VA. http://jimjansen.blogspot.com/2013/04/keyword-advertising-presentation-to.html Presentation, Google Online Marketing Challenge Workshop, The University of Illinois at Urbana—Champaign, 11 March 2013. http://jimjansen.blogspot.com/2013/03/gomc-presentation-to-students-at.html Presentation, Casual Living Conference 2012, 22-24 February 2012, Sarasota, FL. http://accentsandfurnishings.com/conferences/casuallivingconference/2012/index.html Keynote, The Direct Marketing Association of Washington (DMAVW) Professor Institute. 3-4 January 2012, Washington. DC. http://www.dmawef.org/Professors_Page/Professors_Page.html Presentation, Advance 2011: Rediscovering the Customer. 20-22 September 2011, San Diego, CA. http://www. idanalytics.com/advance201 1/ Webinar, Web Analytics Webinar for the American Society for Information Science and Technology, 17 June 2011. http://asist.org/Conferences/webinars/201 1/web-analytics.html Keynote, Buying and Selling eContent 2011. 28 March 2011, Scottsdale, AR. http:/Awww.buysell-econtent.com/201 1/Speakers/JimJansen.aspx Presentation, Evri (semantic news aggregation company). 10 February 2011, Seattle, WA http://jimjansen.blogspot.com/201 1/02/visit-to-evri-semantic-news-aggregation.html Presentation, IMPAQT (search engine marketing agency). 10 November 2010, Pittsburgh, PA. http://jimjansen.blogspot.com/201 0/1 1/visit-to-search-engine-marketing.html 85

Keynote Case 18-2868, Document 283, 08/09/2019, 2628241, Page487 of 883 Invited Talks (Selected) Presentation, Yahoo! Research Lab. 9 November 2010, New York, New York. http://jimjansen.blogspot.com/2010/1 1/visit-to-yahoo-research-labs-new-york.html Presentation, School of Communication and Information, Rutgers University. 8 November 2010, New Brunswick, NJ. University-wide Presentation, Ryerson University, 18 October 2009, Toronto, Canada. Presentation, Query Log Analysis: From Research to Best Practice 2009/ 27-28 May. London, UK. Funded by European Union project on Evaluation, Best Practices and Collaboration for Multilingual Information Access. http://ir.shef.ac.uk/cloughie/qlaw2009/index.html Presentation, Query Log Analysis: From Research to Best Practice 2009/ 27-28 May. London, UK. Funded by European Union project on Evaluation, Best Practices and Collaboration for Multilingual Information Access. http://ir.shef.ac.uk/cloughie/qlaw2009/index.html Presentation, Google. 30 October 2008. Mountain View, CA. Presentation, IMPAQT (search engine marketing agency). 28 October 2008, Pittsburgh, PA. http://jimjansen.blogspot.com/2008/10/visit-to-sem-impaqt.html Presentation, Mahalo (a human power search engine). 6 July 2008, Los Angeles, CA. http://jimjansen.blogspot.com/2008/07/mahalo-human-power-search-engine.html Presentation, Pepperjam (search engine marketing agency). 24 June 2008, Wilkes-Barre, PA. http://jimjansen.blogspot.com/2008/06/visit-to-pepperjam.html Presentation, School of Communication and Information, Rutgers University. 2 September 2005, New Brunswick, NJ. Presentation, College of Information, University of North Texas, 15 June 1998. Denton, TX Membership in Professional Societies American Society for Information Science and Technology (ASIST) Armed Forces Communications and Electronics Association (AFCEA) Association for Computing Machinery (ACM) The Institute of Electrical and Electronics Engineers (IEEE) Societies: Computer Society 86

Case 18-2868, Document 283, 08/09/2019, 2628241, Page488 of 883 Professional Experience Numerous consulting projects and expert witnessing (class action suits, patent ligation, and civil ligation) US Army Officer (2002 — 1985): Held various command and staff positions of progressively increasing responsibility. Responsible for vision articulation, planning, directing, and day-today management of organizations ranging in size from 10 to over 200 personnel. Served in numerous locations in the United States, Europe, Central America, and the Far East as a communication officer. Responsible for the planning and installation of various types of communication systems including radio, telephone, computer and other digital networks. Served with the 8" U.S. Army Y2K Operational Evaluation Team validating critical information management systems. Responsible for the long term planning, developing, and budgeting of communication systems of all types for the U.S. Forces stationed on the Korean Peninsula. Responsible for a 22-person division that develops photographic, graphical, audio-visual and multimedia material for the U.S. Army War College. Security Clearance TS-SCI: Cleared for Top Secret information and granted access to Sensitive Compartmental Information based on a single scope background investigation by the Defense Security Service, Office of Personnel Management on 17 March 2011. 87

Case 18-2868, Document 283, 08/09/2019, 2628241, Page489 of 883 Appendix B Testimony Cases Deliverables | Retained b 2016 | Testimony Plaintiff ERIN ANDREWS, Plaintiff, vs MARRIOTT Deposition INTERNATIONAL, INC., a Delaware Corporation, WESTEND HOTEL PARTNERS, LLC dba NASHVILLE MARRIOTT AT VANDERBILT UNIVERSITY, a Delaware Limited Liability Company, and MICHAEL DAVID BARRETT, an individual, Defendants. CASE NO. 11C4831, which 1s pending in the Circuit Court for Davidson County Tennessee at Nashville. Law Firm: Greene Broillet & Wheeler LLP 2015 | Deposition Plaintiff ENCORE MEDIA METRICS, LLC fka SPUR DIGITAL L.P., dba SPUR INTERACTIVE and STEVE LATHAM VS ADOMETRY, INC. fka CLICK FORENSICS, INC. Cause 2012-44351 / Court: 281. (The District Court of Travis County, Texas.) Law Firm: Watts & Guerra LLP and DiNovo Price Ellwanger & Hardy LLP 2014 | Deposition Defendant M.B. AS NEXT FRIEND OF J.B., A MINOR Plaintiffs, V. CAMP STEWART FOR BOYS, INC., AMERICAN INSTITUTE FOR FOREIGN STUDY, INC. D/B/A CAMP AMERICA, AND SCOTT ASH JAMES ZIRUS Defendant. NO. 5:12-CV-1133 (Western District of Texas) Law Firm: Rymer, Moore, Jackson, & Echols PC 2014 | Testimony, Defendant REAL LOCAL PAGE PARTNERS, LLC, Deposition Claimant, v. PAYMENT ALLIANCE INTERNATIONAL, INC., Respondent & PAYMENT ALLIANCE INTERNATIONAL, INC. Counter-Claimant, v. REAL LOCAL PAGE PARTNERS, LLC, Counter-Respondent. CASE NO. 32 147 Y 0021413. AMERICAN ARBITRATION ASSOCIATION, MIAMI, FLORIDA Law Firm: Kirkland & Ellis LLP 2013 | Deposition Plaintiff CABLE WHOLESALE.COM, INC. v. SF CABLE, INC. Case No. CV 11-2966 EMC (Northern District of California) Law Firm: Law Offices of James G. Schwartz P.C. 88

Case 18-2868, Document 283, 08/09/2019, 2628241, Page490 of 883 Appendix C Documents Referenced Web Services Alexa www.alexa.com/ e Bing Search Engine https://www.bing.com/ e Compete https://www.compete.com/ e Google Keyword Tool https://adwords.google.com/KeywordPlanner e Google Search Engine www.google.com/ e Google Trends https://www.google.com/trends/ e Microsoft Bing Keyword Tool www.bing.com/toolbox/keywords e Million Short https://millionshort.com/ e SimiliarWeb www.similarweb.com/ e SpyFu www.spyfu.com/ e W3Snoop http://www.w3snoop.com/ Documents e Agarwal, D., Chen, B. C., and Wang, X. Multi-faceted ranking of news articles using post-read actions. In Proc. of CIKM, ACM (2012), 694-703. e Aikat, D. News on the web: usage trends of an on-line newspaper. Convergence: The International Journal of Research into New Media Technologies 4, 4 (Dec. 1998), 94110. e BBC News https://en.wikipedia.org/wiki/BBC_News e Castillo, C., El-Haddad, M., Pfeffer, J., & Stempeck, M. (2014, February). Characterizing the life cycle of online news stories using social media reactions. In Proceedings of the 17th ACM conference on Computer supported cooperative work & social computing (pp. 211-223). ACM. e Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-cv-07433 e Daily Mirror https://en.wikipedia.org/wiki/Daily Mirror e GIUFFRE001120 e GM _ 00068 (Gow E-Mail) e http://digitalmeasurement.nielsen.com/files/metrics-guidelines.pdf e = http://www.ebizmba.com/articles/news-websites e = http://www.mirror.co.uk/news/uk-news/prince-andrews-pal-ghislaine-maxwell-508 1971 e = http://www.nydailynews.com/news/world/alleged-madame-accused-supplying-princeandrew-article-1.2065505 http://www.pewresearch. org/fact-tank/20 1 4/02/03/6-new-facts-about-facebook/ https://www.google.com/advanced_ search https://www.thesun.co.uk/archives/news/6754/prince-andrews-pal-ghislaine-groped-teengirls/ Mail Online https://en.wikipedia.org/wiki/Mail_ Online Power Law https://en.wikipedia.org/wiki/Power_ law Snowball sampling https://en.wikipedia.org/wiki/Snowball_ sampling 89

Case 18-2868, Document 283, 08/09/2019, 2628241, Page491 of 883 Tatar, A., de Amorim, M. D., Fdida, S., & Antoniadis, P. (2014). A survey on predicting the popularity of web content. Journal of Internet Services and Applications, 5(1), 1. Teevan, J., Adar, E., Jones, R. and Potts, M. (2006). History repeats itself: repeat queries in Yahoo's logs. In Proceedings of the 29th annual international ACM SIGIR conference on Research and development in information retrieval (SIGIR '06). ACM, New York, NY, USA, 703-704. The Independent https://en.wikipedia.org/wiki/The_ Independent The Times https://en.wikipedia.org/wiki/The_ Times Triangulation (social science) http://en.wikipedia.org/wiki/Triangulation “%28social_science%29 www.theguardian.com/media/2016/mar/17/independent-mirror-express-and-star-suffer-s harp-fall-in-traffic 90

EXHIBIT 25 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page493 of 883 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA L. GIUFFRE. Plaintiff, 15-cv-07433-RWS V. GHISLAINE MAXWELL Defendants EXPERT REPORT OF PETER KENT OCTOBER 28", 2016 Expert Report of Peter Kent Virginia L. Giuffre v. Ghislaine Maxwell

Case 18-2868, Document 283, 08/09/2019, 2628241, Page494 of 883 Slave, Virginia Roberts Lies, Virginia Giuffre Lies, Virginia Roberts Giuffre Lies, Virginia Roberts Untrue, Virginia Giuffre Untrue, Virginia Roberts Giuffre Untrue, Virginia Roberts Liar, Virginia Giuffre Liar, Virginia Roberts Giuffre Liar, Virginia Roberts Ross Gow, Virginia Giuffre Ross Gow, Virginia Roberts Giuffre Ross Gow, Virginia Roberts Ross dishonest, Virginia Giuffre Ross dishonest, Virginia Roberts Giuffre dishonest, victims refuse silence sex slave a2, However, nowhere in his report does Mr. Anderson explain why these 26 search terms are important, beyond the fact that, he claims incorrectly, searching the major search engines with these phrases results in links to Web pages that contain allegedly defamatory material. However, this is true of literally thousands of different search phrases it’s a simple task to create search terms to match particular pages but he never explains why these particular 26 phrases are relevant. 33. As I explain below in detail, Mr. Anderson’s testimony is unreliable because it is not based on sufficient facts or data, nor is it the product of reliable principles and methods. Rather, it is seriously flawed in a number of ways. 1. Mr. Anderson’s Choice of Search Terms Is Arbitrary 34. Mr. Anderson, in his report, provides a list of 26 search terms (Page 7) that appear to have been chosen in an arbitrary manner; furthermore, Mr. Anderson does not explain how these search terms are relevant to this case. Most of the examples are rarely 1f ever searched upon, and return few, if any, relevant results (that is, links to pages that discuss or recount Defendant’s alleged defamatory statements). 35. Search terms are only relevant to this case if a searcher, wishing to find information about Plaintiff, would type the terms into a search engine. Mr. Anderson does not explain why such a person would type, for instance, the term victims refuse silence sex slave; in fact there seems no reason to believe that such a person would use this term. Why would someone wanting to research information about Plaintiff use the term virginia roberts lies, or virginia roberts ross gow? Mr. Anderson does not suggest any reason that somebody should use such terms. Indeed, these are terms unlikely to be used by anyone unfamiliar with this litigation or the fact that Defendant had denied Plaintiff's original allegations. These are not terms likely to be used by Mr. Anderson’s “casual searcher” (“I conducted an investigation to determine the Expert Report of Peter Kent Virginia L. Giuffre v. Ghislaine Maxwell 10

Case 18-2868, Document 283, 08/09/2019, 2628241, Page495 of 883 106. However, this 3-step process (create pages, place them on Web sites, create links to the pages) 1s not very efficient, regardless of the fact that it is common in the ORM business. One should keep in mind that the primary goal of any business is maximizing profits, not efficiency. The 3-step process may be inefficient, but it has the advantage of increasing the income of ORM firms; rather than merely creating links, they can also charge for the creation and placement of Web pages. There 1s, however, an alternative strategy that some ORM firms in fact do use, as I describe later in this report. Zs The Problems With Mr. Anderson’s Strategy 107. Mr. Anderson’s strategy is unnecessarily expensive and complicated, for a number of reasons: e Mr. Anderson exaggerates the number of Web pages (780) that must be pushed down in the search results e Placing new Web pages on quality Web sites will be very difficult, and unnecessary e Pushing the new Web pages up in the search results will be very difficult a) Mr. Anderson Exaggerates the Number of Web Pages (780) That Must Be Pushed Down In The Search Results 108. Mr. Anderson has stated that 780 Web pages must be pushed down in the search results; he takes his 26 search phrases, and multiplies by 30 results (in theory 10 results per search-result page, over three pages, in order to push the “offending” pages down to the fourth page, though in some cases, in particular on Google, there may actually be fewer results on the first page, perhaps 8 or 9.) This is wrong for various reasons. Most of the Search Terms Will be Used Infrequently If Ever 109. As noted earlier, most of Mr. Anderson’s 26 search terms are infrequently if ever employed by searchers. Why, for instance, would it be necessary to push down offending Web pages in the results that the search engines provide for the term victims refuse silence sex slave, when this term is likely never used (and furthermore, that the search results contain no Expert Report of Peter Kent Virginia L. Giuffre v. Ghislaine Maxwell 33

EXHIBIT 26 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page497 of 883 From: <ross@acuityreputation.com> Date: 2 January 2015 at 20:38 Subject: Ghislaine Maxwell To: Rossacuity Gow <ross@acuityreputation.com> bcc: martin.robinson@mailonline.co.uk P.Peachey@independent.co.uk, nick.sommerlad@mirror.co.uk david.brown@thetimes.co.uk, nick.alway@ bbc.co.uk, jo-anne.pugh@bbc.co.uk i f To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts - so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschowitz is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. Sent from my BlackBerry® wireless device GM_ 00068

EXHIBIT 27 (Filed Under Seal)

May. 23. 2016 CaS@ 48-2868, Document 283, 08/09/2019, 2628241, Page4o9 of883 ': 2 Page: 1 Document Name: untitled PANEL: AO7. ASSIGNMENT HISTORY YEAR: 16 T234 Monday May 23, 2016 9:04 am stot: MM «Roberts, VIRGINIA L SCHL; 3390 GR: 10 ST; I A ENTRY WITHDRAWAL P E C CD DATE OD CD DATE R PF SY CL DS SCHL DESC GR PRS ABS UNX Y _ RO2 101201 -_ W26 030702 N_ 02 01 __ 3390 SURVIVORS 10 56°31 = ~ RO2 092001 _ WO2 101101 N02 01 _ 2331 ROYAL PALM HIG 10 13 1 ~ BA 081401 W32 092001 Z 02 Al 2192 WLLNGTN HS ADL 30 | _ FAl 081600 __ W47 081301 Z__ 01 AL 2192 WLLNGTN HS ADL 30 0 _ FA1 062100 W47 081500 Z _ 00 Al _ 2192 WLLNGTN HS ADL 30 YY ~ E01 081699 _ WO3 081699 N00 01 __ 2331 ROYAL PALM HIG 10 ~ BO1 081998 W0O2 060999 P 99 01 0581 FOREST HILL HI 09 155 25 Y _ B01 082097 WO1 061098 R_ 98 01 23312 ROYAL PALM HIG 09 147 33 ¥ ~ E01 082097 _ W22 082097 N_ 98 01 2191 WELLINGTON HIG 09 ~ RO3 040797 WO2 061197 P _ 97 01 _ 1691 CRESTWOOD MID 08 40 5 ¥ ~ BOl 082294 DNE 082294 N”~ 95 01 _ 1703 ROYAL PINES SC 06 ~ BO1 082393 _ WO2 061094 P _ 94 01 _ 1901 LOXAHATCHEE EL 05 167 13 ¥ ~ B01 082592 WO1 061193 P __ 93 01 1901 LOXAHATCHEE EL 04176 4 ¥ PF1=HELP 3=EXIT 5=REFRESH 7=BKWD 8=FWD 9=NEXT PAGE 12=ESCAPE PAGE FULL...CONTINUE. TERML: I1B5 GM_00888 Date: 5/23/2016 Time: 9:05:36 AM

The text on this page is estimated to be only 41.28% accurate

€6800 WO HTAWOL Tad LON SOLYLIS NOLLOWOUd 0 ‘LNTSGY 0 7 LAXSHHd-SAVU SWaaL ADINNS o ‘INHSSsyY O LNGSHYd-SAWO TWONNY 900Z-666T oo°ce 67ST *MOD OO°S S9ct°l *WHAL-eIVLS 00°L2 67S" *WdD 90'S 982° T -NYAL-LITaLsid Sld ALO ¥Wd9 Sld ALO Wid MWEZK TOOHOS JO GNE LY TI-M LJONALSTA AI ASTTOUNZ LON WN *THAR1 BIWHSD 0007-666T * avait 0 1 INSSdY 0 i LNSSaaad-SkVd SWHSL ESWADS NEIWL SISBHOD ON O6EE *ICOHOS OS *LoTrassid Zt ‘'ZNcdy 69 ‘INaSauad-SAVO TWONNY 7002-T002 Ga LOWOSd ATIVOLWACWOY 00°LZE 6Z*S°T ‘WOD oO°S 982) L *WeaL-SLVLS ° (-INSSsw 0 i INSsaaa-SAWG SWHHL YaWoINs oo’LZ 6zZtGc*T -amnD o0°S 99Zb'l *WaaL-IOLuYLsida SZ ‘dNaSdY SST ‘ILNUSSad-SsAvd TWONNY 6661T-366T $id ALG Wad §ld ALD Wd) 00°72 6TiS"T *MND n0°6 LSGSz°T ‘WasLl-Givils 0O°Z OS"E ‘WSSL ‘“LIGaa 00°2z STiS°T ‘HOD d0°'6 2S32°T *Waal-LoOTaLs1da no*o OO'L NZ a OA If0-dxXH WHOM OS9LOEE T Sid ALO vdeo SLd A310 Ya 00°G OS'O NZ GA On Tt dX “HOM OTILOES T os'a OS‘O XZ d OA TWLILNHSSA BOWIEWAOM GTECOES T BOE 00°L ‘WAHL *LIGHYD os'd 0S ON& O 2 Yh HLVW HBANENOCO OLCSOZT T 0O-G OS'O NZ A LH BA ISIH THOM OTCEOTZ Z 0S°O OS‘ON Z a C NS I DNA SAG OFFTOOT T 00°O OS'O0 AZ A Ia os Tt od OTCOONZ Z as°0 OS‘O NZ D T % ASQ HOS’HWO’SWad OESDOSO T 0O°O OS ONZ A uw «OWA aq-t STY O9LO0OLT Z Neive/ ‘LLY MW O Bw OW Way TILL. HSunoo H#ASHHOD L O0'O OS'O NG a Ca Wa Z ONT OFELOOT © Lilasw> ovr 9 a88) Loarens 00°0 OS'O NZ ad C8 Wl XS CHOW ATI-THLIVEH O0f00S0 ¢ Ol *IHARTI gSawaD to0o0e-TOOt ‘aAvVEA 90°O OS'O NZ a mm a L HONBAA OZETOLO Zz TOORIS UXLUVHO SMOATAUNS O6EC *TOOHOS O09 *ELOTGLSIO 00°O0 OS'O NZ a TH T aga HOS'swO’Suad oNsdoSsO Z os°;oO DS ONZ OD ca 8A LSTH GIUOM OTEGOTZ T STQWOTIdayY LON SHLYLS ROTIONONd OS'D OS'O NZ W ca o¢6 L OW OTEcoGZ T 0 -INSSTY dG :INHSSUA-SKWI SNYAL MAWWNS OS*0 OS'O N Z a Ti SSWIO Ga AHALYG OOLCOCET 1 Qo [LWwasey oO - LNHSRAA-SAUG THONNY ToOe-oGnc GO°O OS'O NZ A A WH a-T SITY OSC0G7ZT T : os°0 OS°O NZ ¥ fa Na Zz ON OPETOOT T 00° LZ 62S ‘T -WOD O'S O99Zb°Il *WHaL-SLWis OoS‘;a OS'O NZ OD ca Ta lL HONTMA OZETOLO T on"Lz G2ts‘T *WOD 00'S 98Z6b°T <MARL-JOTersiIa OsS'8 OS*ONZ FF Ta T Aga HOS’ avo ‘Sdd oosoosd T Sid ALO Wdd Sid ALO wdO nava/‘LIY N O a owlaA Way SULLIL ZSUnOD #aSxMOD L lIaga> oF ») SSM Loxurans WN <IHAS] AawuS 1007-0002 ‘HWA 60 ‘75AR'3 BCWAD 666T-866T ‘AWA NDIVL SUSe€Q0O ON OS6tE *TOOHDS OS -LOTaLSIG HOITH TILH LSaaoa Ie8s0 *TooHOS OS ‘LorMisid TOOHDS BZEIAWHO SHOALAMNS OGEE *TOOHDS .Neraand € Fd TIOOHOS HOWE WIWd OS ‘LOLaISIC LNaaanD 5 > Tee oo SLETSLuUs ‘mrs NOLIYWHOURI HES4N0D OGLE *IOOHDS LOTMLSIG TOOHOS end ‘ered “9S00000 :IDTULSIGA - AL €88 $0 COSEHed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUaWNDO ‘898Z-8T aSeD

EXHIBIT 28 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page502 of 883 ee Se ee rR em ee RA © Ee EE ee emer meee ce ae ceeeee seen eee : et | eee : a SIGNED_ : , on : SIGNED ne ‘ Ld enty) —— : é IMPORTANT MESSAGE IMPORTANT MESSAGE : 7 FOR hone oD EY mm . ” AM. e eZ DATE OS aye SB 3 ‘fF = M ‘ “ OF 5 iz aaa ae ra MOBILE “ TELEPHONED | | PLEASE CALL TELEPHONED {J | PLEASE CALL | CAMETOSEEYOU | || WILLCALLAGAIN CAMETOSEEYOU | |/WILLCALLAGAIN, | |] © WANTS TO SEE YOU |__| RUSH -— WANTSTOSEEYOU|. [RUSH || RETURNED YOUR CL| | SPECLALATTENTION | revunNeD vous cut] —[specuuarrennon ||] = ay fe: DATE Ze as PHONE/ MOBILE i Teepioneo | ~ Presse cau ICAMETOSEE YOU | |fwitcaiLacain | | wars To seevou | —Jrusa | rerurneo vouncauc| —[srcoimcATewTn | MESSAGE —_. . 42 16 Ppow7e Ue rake PCr SS FOO S ay LP SA ool re LOE. i : IMPORTANT MESSAGE FOR © . : G4 0 at Pig ‘eo c “a DATE _ fe Efe _ TIME M Gean LUC OF PHONE) oes dP ny? tose E °C LAFF CSF Hf TeicpuoneD | [Puente | cane TO SEEVOU | [wuLcaacan |_| wants Tose vou} [rush | neTurNeD oun call] — [SPECALATTENTON | MESSAGE PLE AIC | MESSAGE 14 apm Ae. Cell ¢2 LO eK GIUFFRE00 1388

The text on this page is estimated to be only 49.35% accurate

wae, Case 18-2868, Document 283, 08/09/2019, 2628241, Page503 of 883 Pg =| | IMPORTANT MESSAGE | | IMPORTANT MESSAGE | | e | | I sc ctir 6 =“ aie B : cs pxre__I/4/os” rime_2 2 $0 ew eB [u—— os PHONE/ | PHONE/ = | MOBILE ——_____ MOBILE : LG 4 Ca XZ rm cave To see YoU | [wu cacan | « es “ SETA CECE AB | [wnrsroseevoo | —|rusns wanrs To sezvou | ruse | i | [estmeotorcxr| “fereoucaremoe[ |] | fretmenvomoat| Jarecacarmmon ||] MESSAGE ee : MESSAGE tactics atin aananRaRemennis : : ae 3 urn Ln. | : SS eet — i SIGNED : _ Av signeD_OS fee IMPORTANT MESSAGE _ J. Eyscte, : AM. pate L/L JOS re 2 OF By 4 . Mf ‘7 ‘1 ‘4 ‘se 44 " ‘5 4 3 a <1 | 4 4 it “ss ‘i . ‘ . %% * SCs i M ! ? ae See -v OF _ : PHONE * : a ea NOR iia acne ia ee Ear: | | [Feerione> __DxJruseo |_| reuernoned | vfreasecan | |} 4 | fewetoseevou | [wurcucacan | _ came To seevou | [wuLcauacan |_|} | |fwanmstoseevou | fruss i wareToscevou| [ruse | dt [RETURNED YOUR GALL| | SPEGIALATTENTION 4 RETURNED YOUR CALL] | SPECIALATTENTION | | MESSAGE ic : Shoul T schedule OUyY 7 ove else € | SAQ01089 SIGNED_— = GIUFFREOO 1409

Case 18-2868, Document 283, 08/09/2019, 2628241, Page504 of 883 IMPORTANT MESSAGE IMPORTANT MESSAGE FOR A.M. I ES iain pnipeeierineiomiinnhiig 6 Sin casiaiieietiieii nies M or__ AIDA PHONE/ MOBILE } —— et et i -_ «= MOBILE fraierrionc | XJrunseca | came TO SeEYOU |~ [WiLCALLAGAN | i m WANTS TO SEE YoU | ‘RUSH RETURNED YOUR CALL} || SPECIAL ATTENTION <== [PENSECAL } WILL CALL AGAIN P Ww RETURNED YOURCALL| jj SPECIAL ATTENTION MESSAGE The UNFIV)SHE D Zhe = war eens BEL ty A tideels ov J\re Broke u Flower § (OS A+ 30 SIGNED TELEPHONED me eae Tose vou | i = WANTS TO SEE YOU o- “7 _ Lette aud T weap Wor att with CST. 2 ee ret ee Fr te eee om —_ ee + IMPORTANT MESSAGE FOR A.M. | DUR OE ceanesctannesrceiei iii: 1k A ic hscamnatohenis Oe les doughs PHONE/ MOBILE [Yruzase ca | wm cau AGA a “o WANTS TO SEE YOU RUSH RETURNED YOUR CALL + SPECIAL ATTENTION — is i> Oi e50 Se: 525 er Ope, byes tse- dann takse cee . "4, . : d . a's ou es » oP ee e*otp tate Here tate tg te © Sete « "eg" ° date hana atnieln atmo de dae tebateta inn bahebedsdedae b bt § : : =< 7 aae © e 4 . ‘ [ a *e Me Be ® > Pa Pate Be da Me . eet fate TELEPHONED By [cae TO SEE VOU |_| ine ow ee a secs: o *,* Seep eet they [riEAseoaL : CAME TO SEE YOU oWu cALLAGAN |_| “— « SO Ty RE & ey eee ee | RUSH | SPECIAL ATTENTION WANTS TO SEE YOU — RETURNED YOUR CALL MESSAGE She ae 4ETDC ESA GOS She ie with / 1: bes Shfuntt6e of [7:30 = + 6688 eee ow oe &, - wee © tte BEEEEISILEL SELL ELE LELEEEE * ° $ ? az ot te SAO01092 “= —_— SIGNED__ py. o*e ty fats Oe Oats Fa Oe Op ae tg te Het Hy He eg tae et Ft i ee ee oe ee *5 O5@ eS ee eee nS eS US UC EE CCC ES : GIUFFREOO 14 12

“+ MESSAGE Case 18-2868, Document 283, 08/09/2019, 2628241, Page505 of 883 " 3 aetna | PHONE/ MOBILE TELEPHONED | PLEASE CALL Bd euroser6r | fwacea ein | wars 70 8 vou | fuss | evuRweo vouncu]| —[epecal ATeiOn | F -_ I creel gps ree er di idorlaneneneeeinemaniangeeniletin 1 TELEPHONED PLEASE CALL CAME TO SEE YOU | WILL CALL AGAIN = WANTS TO SEE YOU |__| RUSH p 4 acuenvouncai| —[seecuraiemon [1 SIGNED — i , a | DATE M or PHONE/ MOBILE TELEPHONED IMPORTANT MESSAGE ec cet TIME [Treas ca A.M. P.M. SEPP EOP OOOO CECE CEC CUT CVE UT cane To see VOU | [wee cauracan | — wavrsToscevou| rush |_| TURNED oun cau] —[ercomarrenion | || * MM osu coulwwed | Oy\\GG Yel so : S\ye \oS eeDtuc : & s CM 0 in case :Pe e mutt c olk Leduc. : SIGNED : IMPORTANT MESSAGE | | : CAME TO SEE YOU WANTS TO SEE YOU MESSAGE SIGNED Ip | i/ Dea 'gity wtf / 9 SA001093 WILL CALL AGAIN SPECIAL ATTENTION SELVES ee eae eee ees "9% " g*s'ctere's ‘er yey , *e% Ps “4 CLO COCR RETR ECE CLT CE CC CEE GIUFFREOO 1413

Case 18-2868, Document 283, 08/09/2019, 2628241, Page506 of 883 _» | [IMPORTANT MESSAGE]| | [IMPORTANT MESSAGE : oR C : | : . ewe & = _— -_ pare SIS OF te (PIS BT: | pare LE EL SF tye FOR si _ |: Iu Geon Zuc ne MES. SIG AwWS ; x hee 4 ee PR ee eer F Wau CALLAGAN |_| mused am SPECIAL ATTENTION TELEPHONED | [eicionco | ruaseo Yi [came To scevOU |_| 4 — CAMETOSEEYOU. | |witcaiLacan | ff | franrstosee vou] —[rusw || | |RETURNEDYOURCALL| || SPECIALATTENTION | || : gee : +16 (S$ frowre | RETURNED YOUR CALL | : | | | sieneD___ + | atel | sienep__) “| COP ee IMPORTANT MESSAGE | | } FOR é c : f 92 ' 2) AM. I | pated LO Sf OS TWME fe Je Pht “fs eer ie a ncaa aan aie ited aerial etait i OF : | OF 1 PHONE/ ~ ee ; | PHONE/ MOBILE ‘ MOBILE | PLEASE CALL | WILL CALL AGAIN ross) | SPECIAL ATTENTION TELEPHONED sg. CAME TO SEE YOU f[teerHoned | fueasecau || jJoamero see vou | |wurcaitacan | |] j[wantstoseevou | [rush |_| = wants TO See You | [ReTuawedvourcax[ [sreciarrention [ |} | all CLs ee , ms message te (8 LOM d pute} | MESSAG os ; hs a _ : =e El SA001446 aN : = @ SS. SIGNED fe Be es GIUFFRE00 1417

cs bbe — = ~ ey sof Sip} ; [> | [reiernoneo | [rerse oun | | TELEPHONED | | PLEASE CALL Pd | [zcrumneovoun curl —JsreoataTemen | — Case 18-2868, Document 283, 08/09/2019, 2628241, Page507 of 883 came ro sec vou | [wit cauacan |_| wants Toseevoo | [russ _——~+ds + RETURNED YOUR CALL| __j| SPECIAL ATTENTION oH = See IMPORTANT MESSAGE | | OF PHONE! MOBILE cae To see vou_| |wucau.acan |_| fwantsToseevou| [ruse | MESSAGE ie SL Sl Nn f } | siGNED__{- rd | WANTS TO SEE YOU RETURNED YOUR CALL v | | TELEPHONED | | PLEASE CALL a ;;CAMETOSEEYOU | {WILL CALL AGAIN || WANTS TOSEE YoU | [RUSH 4 1 , ST RETURNED YOUR CALL] {SPECIALATTENTION | [I i MESSAGE SA.001450 GIUFFRE001421

we wr wre ele yw <. “ vw “Pe “/. wW.- “ws We oo wa @ ww “| Ma) Mel bl ta), @). Wy a) ‘Q). &) GY. GG} 1G): Gt. i {ay (>. a> SC1184 10/01 Case 18-2868, Document 283, 08/09/2019, 2628241, Page508 of 883 TELEPHONED | PLEASE CALL ; 4 CAME TO SEE YOU |WLCALLAGAIN =| | waANTsToscEYOu| |RUSH sss RETURNED YOURCALL| | SPECIALATTENTION | | MESSAGE i nna Th = ON a ciceciinriit ent oe 1184 TELEPHONED Rm PLEASE CALL CAME TO SEE YOU i WILL CALL AGAIN SIGNED vac AM. TIME . ,*14 SPR MM aoe : ce . a, ome a a TELEPHONED poms — CAME TO SEE Yo SIGNED / STANT MESSAGE FOR LJ Le es Om eae he Sent : \ Alf \ 3 ee r =" PLM. uC Ae DY CR Hoe Piha 3 TELEPHONED CAME TO SEE Yoy he —, WANTS TO SEE you SIGNED GIUFFRE00 1423

’ —_ ms - Ke eee ae ~ ———_——— —_————-§ tS Ce Se Go Pee Be a's wtp o Se © tb G0 ogee Sat) ont-@ Se-ene aes © am YVUURVOU4ELEUEBGY: En GE GEA TH We EA AE A A 3 @) GS) Sl wi Oooo a7o® a) ~ ry r a) @) @ @) @ 4) @ So @2@ 044 SC1184 10/01 Case 18-2868, Document 283, 08/09/2019, 2628241, Page509 of 883 IMPORTANT MESSAGE IMPORTANT MESSAGE t = ad ji 4 FOR 2 >} =~ FOR DATE : M TELEPHONED | PLEASE CALL :__| TELEPHONED | | PLEASE CALL — ICAME TO SEE YOU | — ||W&LL CALL AGAIN CAMETOSEEYOU | | WANTS TO SEE YOU |__| RUSH WANTS TO SEE YOU 4 RUSH -| SPECIAL ATTENTION RETURNED YOUR CALL} —|SPECIALATTENTION | | RETURNED YOUR CALL AG atte MESSAGE Oe ee i ee IMPORTANT MESSAGE mm FOR scsiiasiaeidgpieia neh ik a EN sais A.M. DATE ___| J 2 NF iS Time “O80 PM oo _ TELEPHONED = PLEASE CALL CAME TO SEE YOU yt WiLL GALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL P Jreasecan caweTosee OU | [wis cauLaaan | WANTS TO SEE YOU | RUSH bw RETURNED YOURCALL| || SPECIALATTENTION | | TELEPHONED eg i SA001455 Ree at Se ee / i aeeeteeneres a» IN a Nn eaten TI GIUFFREOO1426 a \ s —t. 7 ns < —* } ; ’ —+-y——--- ———— SIGNED____.

-_ a) dh B@M*eeseP@OMO a Go OoOagdoouvdovovsIoow ‘ HONDO OO OO SCi184 10/01 )@ Case 18-2868, Document 283, 08/09/2019, 2628241, Page510 of 883 IMPORTANT MESSAGE 4 fame FOR irre antl eb ieee PHONE/ MOBILE | TELEPHONED | | PLEASE CALL oi CAME TO SEE YOU . 4 WILL CALL AGAIN WANTS TO SEE YOU i RUSH RETURNED YOUR CALL | SPECIAL ATTENTION —e i i i 2. Ps, 2 ‘ ff —— ae: SIGNED : , : —— 1134 =a FOR oh i a A.M TIME 47-5 EM. ie ag. BOs 2 i ff: +. ? : ' a) eee DATE Mi TELEPHONED |] PLEASE CALL eave 10 S660 | [wt causa a WANTS TO SEE YOU RETURNED YOUR CALL SPECIAL ATTENTION CI¢ieaicn at ‘ = 171R4 IMPORTANT MESSAGE 7" PHONE/ MOBILE TELEPHONED _X]] PLEASE CALL Ft WANTS TO SEE YOU | RUSH RETURNED YOUR CALL] || SPECIAL ATTENTION MESSAGE -_ SIGNED__i_ FOR = 7 Fs ~ ; a A.M. DATE ie 6 te TIME PM, Se M Ean taneak OO cscs Satan PHONE/ MOBILE ——— a CAMETOSEE YOU | | WILLCALLAGAIN | | [rans to sez vou | [ruse] | [Reto voor car] — MESSAGE | SPECIAL ATTENTION SAO01477 GIUFFRE001449

a | i e oF er ‘ . a ‘ we . 7 i ; ‘ ‘ wat as a A F y PB = TEEEETTE a ae ae Ode \dSbEGO fed yt ‘ by ‘ @ TUCEOITOOP EE Case 18-2868, Document 283, 08/09/2019, 2628241, Page511 of 883 IMPORTANT MESSAGE FOR_{ & . 3 guc, &M, pare CL2/ oI /O > TIMER NI py 1 CAME TO SEE YOU Wl WILL CALL AGAIN el WANTS TO SEE YOU p | RUSH a Jrerumen oon cur] [oreo rarion | — or U | IMPORTANT MESSAGE , eo 2 ‘ CFL: FOR DATE _— TIME ; M OF SIGNED_ A.M. IMPORTANT MESSAGE We POI ci tie scene fe r f - ‘ A.M. OLFO 2 £O 5 APM. | is roar DATE TIME 22. 307 — M TELEPHONED al PLEASE CALL CAME TO SEE YOU | WILL CALL AGAIN i | ro] WANTS TOSEE YOU | || RUSH f = Ds RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE a sein te “7 f IMPORTANT MESSAGE fe Te FOR sancnuhincimiatcaiah f a a. DATE _@inveet Timed 9s PM. M ‘TELEPHONED CAME TO SEE YOU [Arsssecns led] WILL CALL AGAIN _~ WANTS TO SEE YOU Fy RUSH | RETURNED YOUR CALL | | SPECIAL ATTENTION i fh wep ( of / tes ; MESSAGE Al fig MO © LK O6W Ty ” (E SHE Stuuep KEIM | i a ) | \ SA001456 GIUFFRE00 142’

‘ a 49 AB NS PPPs FF FFF FFU OW CF EU 0 0 UO UO UO OO UO Ow a @ @ a ay w op ep ay av Case 18-2868, Document 283, 08/09/2019, 2628241, Page512 of 883 Vem of hDowKR y | IMPORTANT MESSAGE IMPORTANT MESSAGE ron. Jeter cw wn Hh. Cee Prt? * ‘ a J f ~ = - -s e" , 7 oe fT > : pm AM. | ‘ é Zs f Ss ‘ . -* AT A FeLi heres ceitacereremmnenn CORN eermicencnenspil es 4 . d ; iz ese.) " f Bp es f 6%: be ryt ‘ E / Y jen : “4 2 $e Mit: TELEPHONED | PLEASE CALL owner see YoU] — [was cans wars Toscevou | [uss 1 RETURNED YOUR CALL] | SPECIALATTENTION | | | MESSAGE St rr rt a SIGNED IMPORTANT MESSAGE \ , s FoR wat ri 6 CL, ) i. ah, Pee 73 a i S eae | * IMPORTANT MESSAGE FOR [WUL CALLAGARN wants To seevou| [muss erweo Youn CALL] t " LAST Ra GB Se JSS 7S} ? e oe Say ‘ i sD J— [pesconn eee fuss ha acca TELEPHONED. CAME TO SEE YOU WANTS TO SEE YOU RETURNED YOUR CALL , MESSAGE.‘ JT? Thei tHtvenfer F-7 -. oar 7 ref" Aj ae a Fite gets ho if, Ger Sy 73 , ‘ fa , Zr 7? o fi oe So ca Pca seg ead Nag Pe Neches - SAO01457 — re 2 . SIGNED__ 1184 SIGNED 4184 GIUFFRE001428

VVDKKHOKBADY et: 4 2 s-3 2 FFF EV FVTHHH IO WP = ef > ia Ww We WG We We We le Ge te io is ¢ up ( SU1184 10/01 \ ~ %, Case 18-2868, Document 283, 08/09/2019, 2628241, Page513 of 883 IMPORTANT MESSAGE IMPORTANT MESSAGE SERA bn con Cf FPETE FOR + | a DATE UF i tUf Gi¢ & 2 L 22 Adm | PM TIME “= _ RM. DATE M OF | | PLEASE CALL | WILL CALL AGAIN [nut cautacan fru ‘PLEASE CALL WILL CALL AGAIN RUSH SPECIAL ATTENTION TELEPHONED lw] CAME TO SEE YOU | | a CAME TO SEE YOU | | WANTS TO SEE YOU RETURNED YOUA CALL WANTS TO SEE YOU RETURNED YOUR CALL MESSAGE | | SPECIAL ATTENTION i f MESSAGE PL CALL < : : ‘ _ ° Ss s ‘ ‘ o~ SIGNED SIGNED IMPORTANT MESSAGE IMPORTANT MESSAGE FOR Sher iCia i FOR AVE, CrST be Be “i. i ; j “> ALM. 7 P Th Freel A UR css emesis SOR fi 7 LEC M 7 a [PuEnSecan |] [WL CALLAGANN [usa [seco arrenrion | ic ae freczpnoneo | cawe To sEEvOU |_| wants To See vou | | RETURNED YOUR CALL] TELEPHONED } {/] PLEASE CALL CAMETOSEEYOU | | WILLCALLAGAIN | | WANTS TO SEE YOU | [RUSH Sa RETURNED YOURCALL| || SPECIALATTENTION |__| ne kee MESSAGE ve F xf 7 fi ee “i ‘Bh i . ( ' “ -. eA Of Oe! PHURASE, RAT «3 UG AVATLADLE ON TUESDAY ff. Mt. GNSS Fee TemceRRty SA001461 ra r ne be a ROR ccaetccnninnl iso & SIGNEN & GIUFFREO01432

SHEVOVYUUUEDHOUUDBYUBOODIVYUOVIEY UR Por Pweeo oO | - _t Bw . 2 wp ®& IMPORTANT MESSAGE MESSAGE ae PHONE/ MOBILE feupionc’ | resem 1 CAME TO SEE YOU | WILL CALL AGAIN | WANTS TO SEE YOU | ‘|| RUSH RETURNED YOUR CALL] | SPECIALATTENTION | | MESSAGE SIGNED IMPORTANT MESSAGE TELEPHONED CAME TO SEE YOU WILLCALLAGAIN = | CAME TO SEE YOU | WILL CALLAGAIN WANTSTO SEE YOU | | RUSH WANTS TO SEE YOU | | RUSH RETURNED YOUR CALL] | SPECIALATTENTION:| | SIGNEN ee Case 18-2868, Document 283, 08/09/2019, 2628241, Page514 of 883 IMPORTANT MESSAGE ron Ade UH -4 is i , C5 Abbe DATE ASS See in > BY. P.M. M OF MOBILE CAME TO SEE YOU i) WILL CALL AGAIN — WANTS TO SEE YOU -_ RUSH RETURNED YOUR CALL —— SPECIAL ATTENTION bed Ka I aber tret i teri iemrenieeienintrericremms im : IMPORTANT MESSAGE - « or - nr “a > te ‘ - 3 SAKA fe MR ESSTEIN EPSTEIN i FOR ALR AIT f a a fy ot rime_©& “4 pM. PLEASE CALL it TELEPHONED | | PLEASE CALL ~ | f = RETURNED YOUR CALL — SPECIAL ATTENTION cS at tA ni oD RR. CHAN MESSAGE WAS IN A CAR Afglidtiat CN Hee toAY -'f 11RA SIGN ie i 1184 GIUFFRE00 1433

* vet, 4 &% VBBSBRESSSSHFHOVCOVVYvV VK Vo vUYVVVVYVVYVVYVYVVYVYUY UY a SC 1184 1001 ay ts 4 w Case 18-2868, Document 283, 08/09/2019, 2628241, Page515 of 883 IMPORTANT MESSAGE IMPORTANT MESSAGE FOR we ll < — fé 7 ¥ i FOR Fis tv KAR tv 6 47 tc? Ds ~ ‘ -~. —_ ; ‘ wo 5 i fd pate f/f I 3 i O44 M _ ; etl y ye we * ‘ 1?) > ~~! . —- to ; ~K PHONE! MOBILE TELEPHONED + {Resse CALL CAME TO SEE YOU pw CALL AGAIN z|_ eset | RETURNED YOUR CALL RET MESSAGE. MESSAGE ___ \ fi Ales e iSea SIGNED IMPORTANT MESSAGE fetes eS oz “ ron at 1 <r boos oe VLA oh PHONE/ MOBILE MOBILE eas | eed omenened| fas precarariemoy || ‘ TELEPHONED CAME TO SEE YOU | DY oe message. & LS CALL SA001464 SIGNED. GIUFFRE00 1435

he es ‘ . . ero ee > eo om = ot ° PVPOUYND VSO IANMOOHOOHOHHORESBEVWBVYEBASEEEUvivOo SCIt184 10/01 “a ww, Case 18-2868, Document 283, 08/09/2019, 2628241, Page516 of 883 IMPORTANT MESSAGE | | IMPORTANT MESSAGE ee a DPS et etn Ses Sesh eee —_ ee i Z _ A.M - ¢ ° . 7 e = td -~ on - oA. * ? ”* . ? f ‘ ‘ DATE __<¢> fe" A/S TIME <3: T> pM. p pate __ Aas ees Drie 4c. 72’ PM , ? ~~ PHONE/ MOBILE nde ta NS feieowoneo | ofruenseoan | awe To see vou | [wat cansaan | = * es | PLEASE CALL | WILL CALL AGAIN | RUSH WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION eT MESSAGE MESSAGE __* fe 3 sais &: eae SIGNED i , — 1184 SIGNED am 1184 ~ee IMPORTANT MESSAGE r IMPORTANT MESSAGE FOR a oe Pio EE tes eens aces F octy ~-— Se pry ’ =“, = yt a4 DATE _Wfe é Le 42. TiME__7#- 7 6M, M =a. fl AF¢T OF PHONE/ PHONE/ MOBILE MOBILE [rascal fweccauasan | I) es | 3 SPECIAL ATTENTION Teemronco | Jreasecan |_| ewer Tone Twanrs roseevou | [RusH | Sx[srecatarrenion | ' 5 WANTS TO SEE YOU RETURNED YOUR CALL 1 | SA001476 > | f SIGNED ; 1184 GIUFFRE00 1448

-_ a) dh B@M*eeseP@OMO a Go OoOagdoouvdovovsIoow a a HOODOO OB: SCi184 10/01 )@ Case 18-2868, Document 283, 08/09/2019, 2628241, Page517 of 883 IMPORTANT MESSAGE rer x FOR ee 5} C3 irr etieheS eociiab ab eee PHONE/ MOBILE | TELEPHONED | | PLEASE CALL oi CAME TO SEE YOU , 4 WILL CALL AGAIN WANTS TO SEE YOU i RUSH RETURNED YOUR CALL | SPECIAL ATTENTION —e i i i 2. Ps, 2 ‘ ff e —— ae: SIGNED : , : —— 1134 =a FOR oh i a A.M TIME 4-5 RM. ae ag AOS 2 i fi 2. ; ‘ ' oe DATE Mi TELEPHONED |] PLEASE CALL eave 10 S660 | [wt causa a WANTS TO SEE YOU RETURNED YOUR CALL SPECIAL ATTENTION CI¢ieaicn at ‘ = 171R4 IMPORTANT MESSAGE 7" Peis eecsitechincinetece PHONE/ MOBILE TELEPHONED _X]] PLEASE CALL Ft WANTS TO SEE YOU | RUSH RETURNED YOUR CALL] || SPECIAL ATTENTION MESSAGE -_ SIGNED__i_ FOR = 7 Fs ~ ; a A.M. DATE ie 6 te TIME PM, Se M Ean taneak OO cscs Satan PHONE/ MOBILE ——— a CAMETOSEE YOU | | WILLCALLAGAIN | | [rans to sez vou | [ruse] | [Reto voor car] — MESSAGE | SPECIAL ATTENTION SAO01477 GIUFFRE001449

ic 3 HOOOSOIVS ddd ad dDVODIDS “=e —e’ ote me «= Case 18-2868, Document 283, 08/09/2019, 2628241, Page518 of 883 — IMPORTANT MESSAGE FOR Af. Eger trv DATE LBS @ [Oe f rive 2: 29 ouah ue. Mark €psfeiv OF | PHONE/ MOBILE __ feueroned | [neneoan | CAMETOSEEYOU | |WILLCALLAGAN |_| WANTS TO SEE YOU P RUSH IMPORTANT MESSAGE | PLEASE CALL I WILL CALL AGAIN ZN | RUSH SPECIAL ATTENTION CAME TO SEE YOU WANTS TO SEE YOU ee RETURNED YOUR CALL }RETURNED YOUR CALL SPECIAL ATTENTION | | | MESSAGE a SIGNED i a le IMPORTANT MESSAGE ‘ © ~ FOR #4’ “& ELS Fe 004 CORP fp fy DATE eee TIME fk Carle {$074 —, 4 A E 27 Aus i TELEPHONED , ' _JPCAME TO SEE YOU TELEPHONED | PLEASE CALL i. | CAME TO SEE YOU | WILL CALL AGAIN wis TOSEEVOU| fru | RETURNED YOUR CALC| [SPECIAL ATTENTION | be tf U message “2/4 Be 44a, 15 file JAF TGeS Wun fee Ter ° * “; $0 F147 CIEL OSE LYUGITAY | G41. To 100 Fr | PLEASE CALL | WILL CALL AGAIN WANTS TO SEE YOU | | t + RETURNED YOUR CALL ” oS Ont teleetie case « ts _ Rr ie SIGNED GIUFFRE001452

Case 18-2868, Document 283, 08/09/2019, 2628241, Page519 of 883 Try @ IMPORTANT MESSAGE FOR ree , A.M. CTF te ceenpeeenentinrens PE OL. em M OF PHONE/ MOBILE _ Emec | fwacautaaan | a = | rue | SPECIAL ATTENTION OSdOddo0d rr vrr' OO0d SIGNED ode SHES RLOSSTSSOOTS ye ' { : 4 | , } SPECIAL ATTENTION IMPORTANT MESSAGE cep SOUS SILKE It ~ ff, pe “a er <e é ; QO } pate I SLE _ te) SS oR uZIRAY OF PHONE/ MOBILE TELEPHONED = PLEASE CALL CAME TO SEE YOU | WILL CALL AGAIN | RUSH WANTS TO SEE YOU RETURNED YOUR CALL] | SPECIALATTENTION COLAO L9G SIGNED | IMPORTANT MESSAGE 4223, £.7°*, Fs PEL OS age TOE E an dD VES 1 | MOB TELEPHONED | | PLEASE CALL DS CAMETOSEEYOU | |lWiLLCALLAGAN | | wanrsroseevou | —Jausa | acTurneD your ca] forcomn enon | a SAO02829 SIGNED GIUFFRE00 1453

! a VSTTESdDVOddd' b0H600006 ann pe pe pp peg pm mn SS SO Mhies uJ beLG ‘an PeSeSSSSSy Case 18-2868, Document 283, 08/09/2019, 2628241, Page520 of 883 IMPORTANT MESSAGE ) IMPORTANT MESSAGE py. tron MS, MAXWELL om — . pare JA] a5 jo4 rime 6:55 _ PM.) ius i 4 , Colm LL foik PLEASE CALL rs CAMETOSEE YOU | |WILLCALLAGAIN | | WANTS TO SEEYOU | _—_‘|/ RUSH yy RETURNED YOURCALL| | SPECIALATTENTION |__| MESSAGE 5 r ss G DATE K 40 / YG TIME _2@ TELEPHONED CAMETOSEEYOU | | WILL CALL AGAIN WANTS TO SEEYOU | —‘|/ RUSH || RETURNED YOURCALL} | SPECIALATTENTION | | message. KETURNIN YouR Ca&tL _ TELEPHONED a | er eee — - er 8 8 eee TT SO SIGNED IMPORTANT MESSAGE i ah a AM. A.M, DATE a nes TIME PM, DATE epee ean a P.M. fF YPLEASE CALL Pw cau acan [fre [~[ereol ArTENTION TELEPHONED CAME TO SEE YOU WANTS.TO SEE YOU RETURNED YOUR CALL WANTS TO SEE YOU ty RETURNED YOUR CALL || SPECIAL ATTENTION MESSAGE © 1 Palen Beach Yoclacy to she | neve al) LAO KeauN AOL ‘ f <h SA02830 a SRI -cpiaetcnecimeniaeecidiees -. i | SIGNED ee BRE 1 eae rr 7) ee a * GIUFFRE00 1454

- e * ; ‘ , * oe s ao Case 18-2868, Document 283, 08/09/2019, 2628241, Page521 of 883 TELEPHONED | | PLEASE CALL CAME TO SEE YOU | WILL CALL AGAIN WANTS TO SEE YOU | —‘| RUSH RETURNED YOUR CALL] —_} SPECIAL ATTENTION ee 7 ee ae AL BE ET «- ( OAT NOLS — “Row ( olf Pur € ge Si CATSAN: a ee ee | SIGNED UCrAN IMPORTANT MESSAGE vk. ! : | DATE TIME oO. M \ / OF PHONE/ MOBILE CAME TO SEE YOU WANTS TO SEE YOU RETURNED YOUR CALL EASE CALL [PLEASE CALL | WILL CALL AGAIN | SPECIAL ATTENTION ; ' ; IMPORTANT MESSAGE ron JIVE Fe £ fx / IN Pett - :; - C) & TIME td oy OF PHONE/ MOBILE TELEPHONED CAME TO SEE YOU WANTS TO SEE YOU RETURNED YOUR CALL MESSAGE PLEASE CALL WILL CALL AGAIN RUSH SPECIAL ATTENTION ow rd Td 1 & NI cs cart erase aerate 2 IMPORTANT MESSAGE ron_Ch aia AIS DATE v 4PM mx Oo Ondo (} J OF , [+ A A PHONE/ | * ote Wey Mine BoB So be TELEPHONED | [reAsecal came To see vou | [wi caLLacan | _ “9 - Pa WANTS TO SEE YOU | RUSH | RETURNED YOUR CALL} — | SPECIAL ATTENTION MESSAGE__-_} SA02832 GIUFFREOO 1456

SooNSTTTT TTT D ove a) 96 00 @ ie pooooen w ve jt Sw Se gk ee EE FE Sgt 8. Lee -2- - = te Oy ES SR EE CO ee ee ee er ee es . ’ ‘out rrr - tie Sobbe: Case 18-2868, Document 283, 08/09/2019, 2628241, Page522 of 883 IMPORTANT MESSAGE con___ LA/E -§ 2 LESH - AM. ~-9° pM. DATE TIME SAA EEO. M OF PHONE/ EEE ni irr Taicpaoneo | Jrencecan cave To sec vOU | JvnucnLaaan | a a = Pr WANTS T0 SEE YOU RETURNED YOUR CALL SPECIAL ATTENTION | | | | IMPORTANT MESSAGE inca tie ET sie ie a rrevernoned | [reAsecan |_| [Game Tose: You | |wuLcaLacan |_| WANTS TO SEE YOU | ‘|| RUSH vaste Blcal RETURNED YOURCALL| |/SPECIALATTENTION | | MESSAGE SIGNED. IMPORTANT MESSAGE M OF PHONE/ MOBILE [memons [ofrmscou | [CAME TO SEEYOU | |wuLcaLLacan |_| wants To seevou| [muse |_| RETURNED YOUR Gat] —[sPECiALATTENTION | MESSAGE SIGNED Teerroneo [| [reasecar | < CAME TO SEE YOU | WILL CALL AGAIN WANTSTOSEEYOU} j/RUSH ~ | | RETURNED YOUR CALL| |/SPECIALATTENTION | | SA02838 SIGNED GIUFFREO0 1462

TIT Tr rye Dt oe i> & & beROES tr . . = ** Sb: ee SY BG SbSbboSERS wa T!IAd FOI : 5 -y : Ls P P Me a 1 Case 18-2868, Document 283, 08/09/2019, 2628241, Page523 of 883 7 sa AA DY AE LN PHONE? 7” f MOBILE: —~ TELEPHONED Yj : CAME TO SEE YOU [PLEASE CALL | | WILL CALL AGAIN = wants To see vou | ~PaUSr I aeTurweD wun call] — MESSAGE | | SPECIAL ATTENTION IMPORTANT MESSAGE | CT: fretgPrONeoy 4, J cPRtease ga | + mee seclvol MFT Fd calc aan a | warrgroscevou| [rush SIGNED retumen von cu] —Jsrecaavemon | |) ne A che ill See You FOR TIME ] ae DATE a : e 4 + ‘ M OF LEPHONED CAME TO SEE YOU WANTS TO SEE YOU RETURNED YOUR CALL | PLEAS jraee t I WILL CALL AGAIN Fy 4 ‘ | RUSH |SPECIALATTENTION | [f Eee erat Q Sc . TQS lA Oh a favck ‘ih ON 11 OOK i> UN PLEASE CALL WILL CALL AGAIN RUSH SPECIAL ATTENTION i F SAO02850 atk GIUFFRE00 1474

Case 18-2868, Document 283, 08/09/2019, 2628241, Page524 of 883 [dq |resscoat |] CANETOSEEYOU | |wucaacan | |] wanTsTOSeEVOU | [russ | ‘|i erumeD vouncaur| —[seecmcaTenron |_|] or You t% tea Lo! Y ots Aor! to serak YUssian, | 1 Sher Is xo ove of yn ; ZA Critde .~<LSS0°18 Ctre 7 : rCE WA of VOlr (4p : Dive + play 1 At) : | foie | : ? as 1184 | | LIMPORTANT MESSAGE | |_| S[Agpacccan came TOseevoU |~JwhicaaGan | |] wanrsTopee¥ou | [us | dC retuned Youn cn] [srccmcarrennion | |] MESSAGE : poe tIC DOS A Teather | : TELEPHONED — CAME TO SEE YOU [PLEASE CALL WILL CALL AGAIN ReTuREDvoUuRCAL| —Jsrecu_arrevrion | Jf ‘MESSAGE She called ,; | 4 Ou AOU ct vc or | Ag bo pore. SAc © ; 4 A =f A ei ft > AM. ; re 247 eth : : | | | frecesnoneo | y Jnenseomn eee ae RETURNED YOUR CALL| | SPECIALATTENTION | |i MESSAGE 4 Shé peal -Peardin a SA03008 GIUFFREO01563

EXHIBIT 29 (Filed Under Seal)

EXHIBIT 30 (Filed Under Seal)

PAD eral IN i? F United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (S61) 820-877] Facsimile: (S61) 820-8777 September 3, 2008 VIA COURIER Ms. Virginia Roberts c/o Asst Legal Attache Matthew Witt United States Embassy Sydney Australia Re: Jeffrey Epstein/Virginia Roberts: NOTIFICATION OF IDENTIFIED VICTIM Dear Ms. Roberts: By virtue of this letter, the United States Attorney’s Office for the Southern District of Florida provides you with the following notice because you are an identified victim of a federal offense. On June 30, 2008, Jeffrey Epstein (hereinafter referred to as ““Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution). in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf009381IAXAXMB) and was sentenced to a term of twelve months’ imprisonment to be followed by an additional six months’ imprisonment, followed by twelve months of Community Control] 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions, including the following: | 1. An independent Special Master was assigned the task of selecting an attorney representative to represent the victims, including you, in connection with civil actions between the victims and Mr, Epstein. The

: fy sey = Ferm a ar ta! EE Me a - ‘ ’ . Sede bch Bo ete © ea : a Dyke gts laacenlaeg dah lar tt 206 RBI eR ati UE Meg SOLA a EEG tae Eire LIE Na NOEL ses “Ua ERR BA RE AS cB eves anecesttanngn chaos pees stevie catenin tp ascnbe np tip Ske LSE BRAG AL ABT SG ERENT IND EARNEST A REMMI EEE Ie MAGMA A MAIL AP SE A IE cre Case 18-2868, Document 283, 08/09/2019, 2628241, Page528 of 883 & . ‘“ ~ : a3 MS. VIRGINIA ROBERTS «* NOTIFICATION OF IDENTIFIED VICTIM SEPTEMBER 3, 2008 PAGE 2 OF 3 Special Master selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., ahighly-respected and experienced attorney. You are not obligated to use Mr. Josefsberg as-your civil attorney, but, as explained in greater detail below, Mr, Josefsberg’s services will be provided atno | cost to you because Mr. Epstein is obligated to pay the costs and fees of the attorney-representative, Also, Mr, Epstein and his attorneys can only contact you via Mr. Josefsberg, assuming that you would like Mr. Josefsberg to serve as your attorficy, Z If you elect to file suit against Mr, Epstein pursuant to Title 18, United States Code, Section 2255, Mr. Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Mr. Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between you and Mr. Epstein, so long as you elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any. other claim for damages, whether pursuant to state, federal, or common _law. Notwithstanding this waiver, Epstein’s agreement with the United States, his waivers and failure to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability. 3 As stated above, Mr. Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. This provision, however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if after consideration of potential settlements, you and Mr. Josefsberg elect to file a contested lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other contested remedy, the obligation to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those contained in Section 2255, shall cease. Please contact either myself at ann.marie.c.villafana@usdoj.goy, or Justice Department Victim- Witness Specialist Twiler Smith at Twiler. Smith@ic.fbi.gov with a good telephone number and/or e-mail address, so that we may provide Mr. J osefsberg with a timely means of communicating with you. If you would like to contact Mr. J osefsberg Ae 3 a , te nas thee SRN EARL i

Sink cate. SE Case 18-2868, Document 283, 08/09/2019, 2628241, Page529 of 883 Ms. VIRGINIA ROBERTS NOTIFICATION OF IDENTIFIED VICTIM SEPTEMBER 3, 2008 PAGE 3 OF 3 directly, he can be reached at +1 305 358-2800. If you have already selected other counsel to represent you, or if you do so in the future, and you decide to file a claim against Jeffrey Epstein, Mr, Epstein’s attorney, Jack Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. In addition, there has been litigation between the United States and two other victims regarding the disclosure of the entire agreement between the United States and Mr. Epstein. Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney to represent you, that attorney can review the Court’s order in the matter of Inre Jane Does 1 and 2, United States District Court for the Southern District of Florida Court File No. 0880736-CIV-MARRA. Please understand that neither the U.S. Attorney’s Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation. Thank you for all of your assistance during the course of the federal and state investigations and please accept the heartfelt regards of myself and Special Agents Kuyrkendall, Slater, and Richards for your health and well-being. Sincerely, R, Alexander Acosta United States Attorney NM YY , " A. Marie Villafafia Assistant United States Attorney By: ce: Robert Josefsberg, Esq. Jack Goldberger, Esq.

EXHIBIT 31 (Filed Under Seal)

-1 of 12- & Case 18-2868, Document 283, 08/09/2019 26280 41, Page531 of Soa ah sgyunces 0 Date of entry 07/05/2013 FD-302 (Rev. 5-8-10) VIRGINIA L. GIUFFRE, maiden name ROBERTS, date of wep Social Security Account Number}iehMeliei United States Citizen an Australian Permanent Resident, residence New South Wales, Australia, 2261 was interviewed at the United States Consulate in Sydney, Australia. GIUFFRE was advised of the identity of the interviewing agents and purpose of the interview. Present during the interview was Federal Bureau of Investigation Special agent{ and via telephone, Assistant ae United States Attorney GIUFFRE provided the following information: California to parents date of birth GIUFFRE was born in Sacramento, currently resides in date of birth Cn currently resides in GIUFFRE moved to Palm Beach County, Florida with her parents when she was four years old and returned to California at age 11. She returned to Florida at age 13 and was placed in a rehabilitation or foster care facility in West Palm Beach, Florida. GIUFFRE ran away from the rehabilitation facility when she was approximately 14 years old, and while living on the streets in Miami, Florida, she met b6 b7C was training GIUFFRE to be an escort gave GIUFFRE a life off of the streets which made her feel Investigation on 03/17/2011 g Sydney, Australia (In Person) b7C by This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; It and its contents are not to be distributed outside your agency.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page532 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-302 of Virginia L. Giuffre (on 6493/17/2011 pa, 2 Of 12 like she was locked into the relationship[ gave GIUFFRE pharmaceutical drugs toward the end of their relationship. b6 b7C GIUFFRE's relationship with[ ended while she was at a private ranch near Ocala, Florida. GIUFFRE telephonically contacted a childhood ene | from a telephone at the ranch. GIUFFRE b6é knew from elementary school and called him at the home telephone bic of his eet ae told she was very lonely, an sked her why she did not leave GIUFFRE's telephone conversation with the recreational vehicle (RV) GIUFFRE was staying in at the ranch strike her her belongings and told her she was going to live with another man. GIUFFRE bé felt that she was sent to ut did not know the b7C specifics of the arrangement. GIUFFRE engaged in sexual activity with who was described as a white male GIUFFRE stated GIUFFRE stayed with[ —__funu for approximately one or two weeks before the police located her and returned her to her parents. GIUFFRE was interviewed by a male detective. GIUFFRE's parents were still married at the time and lived near Florida. GIUFFRE believed there was an FBI investigation related to She never saw| _—sjagain after In approximately June 1998 or 1999, GIUFFRE began working at Donald Trump's Mar-A-Lago Club in Palm Beach, Florida. GIUFFRE's father was able to help her gain employment as a baby sitter and later as a locker room attendant at the club. GIUFFRE started studying for her GED and wanted to become a massage therapist. In August, GIUFFRE was reading an anatomy/massage book and was approached by bé b7C | fand help her get her masseuse accreditation} ss—s—‘“s_ GIUFFRE consulted her father about the opportunity and at approximately 9:00 p.m. the same day, her father drove her to a residence xf

Case 18-2868, Document 283, 08/09/2019, 2628241, Page533 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-302 of Virginia L. Giuffre (on 03/17/2011 page 3 Of 12 | sY Florida.[ | spoke with GIUFFRE's father and told him it was a wonderful opportunity for GIUFFRE. GIUFFRE met also known as GIUFFRE was led upstairs instructed GIUFFRE to wash her hands prior to beginning the massage. The massage bega emonstrated massage techniques to GIUFFRE. During the course of the massage) fquestiioned GIUFFRE about her past, including her time as a runaway. GIUFFRE was also asked if she took birth control. GIUFFRE was given instruction and began kissing At the conclusion, _ instructed GIUFFRE to obtain two warm wash clothes. One wash cloth was used to clean second was to help him relax. GIUFFRE describe and GIUFFRE then moved to the steam room and shower where GIUFFRE massaged with soap and a loofah in the shower. At the conclusion of the shower, GIUFFRE went downstairs and Arrangements were made for GIUFFRE to return to the house the following day after work. GIUFFRE's cellular phone number was given t b6 b7C b6é b7C b6 b7C b6 b7C b6 b7C b6 bDrc

Case 18-2868, Document 283, 08/09/2019, 2628241, Page534 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-302 of Virginia L. Giuffre (on 93/17/2011 pase 4 Of 12 The same routine and pattern of massages and sexual activity between and GIUFFRE continued for between one and two weeks. At b6 b7C offered GIUFFRE the option to quit her job at Mar-A-Lago and travel There was also discussion of GIUFFRE receiving massage training. GIUFFRE was to be paid $200.00 per day for travel and $200.00 per hour for massages. in her relationshi b6 b7C and was introduced as assistant. GIUFFRE soon began traveling{ ror the initial six months, GIUFFRE ta. "saaeial the United States and Caribbean, b6 including California, New York City, New Mexico, and various business b7C trips. During those trips, Six to nine months after GIUFFRE began working for GIUFFRE was introduced t in b6 b7C at the time. GIUFFRE met the couple at a condominium next to the NU GIUFFRE cleaned paid cash paid GIUFFRE GIUFFRE was 16 years old at the time GIUFFRE advisedf ———~—sSCSsfinttrcoducced her to the drug Xanax. She explained that Xanax helped her escape from reality but allowed her to b6 still function normally. Xanax helped her go forward with what she was ae doing wit and others. Her habit went from two pills per day up to eight pills per day. GIUFFRE's second client was an academic of some sort described as an older American male sent GIUFFRE from Miami International Airport to b6 by commercial airline. GIUFFRE was picked up at the b7C airport by and then taken to the island by boat. GIUFFRE

Case 18-2868, Document 283, 08/09/2019, 2628241, Page535 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-3020f Virginia L. Giuffre oO, (On «=«93/17/2011 page 5 Of 12 pointed out tha instructed GIUFFRE to entertain the ee client and wanted to ride jet skis and participate in other island activities GIUFFRE spent two days on the island with the client. GIUFFRE assumes the client also traveled commercially. During the following several months, GIUFFRE traveled internationally Prior to her traveling abroad Ssisted GIUFFRE in getting her passport. GIUFFRE got passport photographs of herself and ° oe he remaining paperwork was taken care of by GIUFFRE traveled to Paris, France, the South of France, London, England, Africa, and Spain. While in Paris, GIUFFRE recalled staying at a hotel overlooking the Champs-Elysees. While traveling ps GLU FRE traveled on Pfs black plane. During the international travel times, GIUFFRE would} Rarely a day would pass| provided them t contacted GIUFFRE through b6 sss sn wanted to talk to CIUFFRE abou] SSS” p7C offered GIUFFRE a contract. GIUFFRE agreed to the contract for her story and was paid $140,000 for the story, $10,000 when the article was printed, and another $10,000 to be wired into GIUFFRE's account in May 2011. The contract prevented GIUFFRE from talking to any other press for a specified period. GIUFFRE advised that she ith detailed informatio b7C > “ss b7C

Case 18-2868, Document 283, 08/09/2019, 2628241, Page536 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FDA age 16, GIUPPRE met SoU ERE believed she and] [were approximately the same age. GIUFFRE and GIUFFRE would dress GIUFFRE, though[ _| explained GIUFFRE provided an GIUFFRE described ____eturere sav] when _she arrived at rors had|_S—S—S—C—SOCSCSCCOCOCOCF GIUFFRE said that day was a low stage in her relationship because she could not believe] C—“‘(CSCOCOCOCS 302 of Virginia L. Giuffre ‘on 03/17/2011 page 6 OF 12 b6 b7C b6 b7C b6 b7C b6 b7C b6 b7C b6 b7C

Case 18-2868, Document 283, 08/09/2019, 2628241, Page537 of 883 FD-302a (Rev. 05-08-18) 31E-MM-108062 Continuation of FD-302 of Virginia L. Giuffre | (On «=683/17/2011 page 07 Of 12 GIUFFRE believed the girls may have been b6 but b7C GIUFFRE was not certain of involvement. GIUFFRE had a b6 b7C GIUFFRE described some of the unique interior areas off sid b6é b7C Cid Which GIUFFRE referred to] hich was ee GIUFFRE stayed. While in New York, GIUFFRE also stayed at an apartment on 66th street GIUFFRE was aware of additional bé apartments in the same building. According to the b7c apartment building on 66th street was owned by IUFFRE advised that she had a photograph of the interior of the 66th Street apartment among other photos GIUFFRE advised that some of her photographs that were provided to her Civil attorneys by her family were not returned. One of the missing photos depicted GIUFFRE wearing a pink dress while seated on a quad bike. LNU wa Female that formerly lived in bé b7C

Case 18-2868, Document 283, 08/09/2019, 2628241, Page538 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-302 of Virginia L. Giuffre Oi. US7ii7 2011 8 of 12 , Page LNU and GIUFFRE went shopping together and purchased clothing and sex b6 b7C b6 b7C GIUFFRE used a cellular telephone She believed it was a New York City number but could not recall the number. GIUFFRE and GIUFFRE could only remember faces not their names. GIUFFRE did not but she did try unsuccessfully to get GIUFFRE recalled but she could b6 not recall the wording. NU. b7c GIUFFRE advised GIUFFRE traveled) to a self-help conference at a hotel in New Orleans, Louisiana. The hotel was near the Hard Rock Café in New . Orleans. GIUFFRE traveled the world including the USVI, New York, Santa Fe, Palm Beach, France, Africa, Spain and the United Kingdom. ——t b6 GIUFFRE recalled visiting b7C Alhambra Castle in Spain. GIUFFRE eventually traveled to the United Kingdom and

Case 18-2868, Document 283, 08/09/2019, 2628241, Page5d39 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-302 of Virginia L. Giuffre /On G3/7772011 , Page 9 of 12 while there] approached GIUFFRE in a very excited manner and told her they had to go shopping to pick out a dress because GIUFFRE would be b6 GIUFFRE and| went shopping and purchased makeu Burberry bag. The items were purchased with clothing, anda GIUFFRE b6 b7C instructed GIUFFRE to get ready. When GIUFFRE came down after getting ready, she was introduced to GIUFFRE traveled to CLUB TRAMP| ~~ ~—~———_—sUJYX.: GIUFFRE Stayed at CLUB TRAMP for an hour or hour and a half and drank a couple of cocktails before returning to GIUFFRE had not received any direction After returning to to take a photograph of her advised that she still had the original photograph in her possession and would provide it to the interviewing agents. GIUFFRE proceeded with requested GIUFFRE recalled joking about trading GIUFFRE in because she was getting too old.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page540 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-302 of Virginia L. Giuffre On 03/17/2011 GIUFFRE recalled meeting GIUFFRE was using Xanax heavily at the time, and her recollection was not clear. She remembered there were many models on the island that did not speak English along with a mod eling person who had an unknown accent. id not have a problem with GIUFFRE using prescription drugs. was described by GIUFFRE as a (TRUE NAME UNKNOWN)[ | a ranch employee A eet GIUFFRE could not recall his name. She did have a photograph of tne ranch employee. GIUFFRE met numerous famous people academics oliticians, and celebrities. GIUFFRE received many gifts] i fincluding jewelry, watches, bags, shoes, make up, clothin and home furnishings. GIUFFRE left all of the items behind when she traveled to Thailian receive massage training. In August 2002, GIUFFRE traveled by commercial airline to Bangkok, Thailand and began her massage training at International Training Massage School (ITM) where she received-ber ms the Princess Hotel in Thailand but never did. GIUFFRE met her future husband,|| | during her visit to Thailand. GIUFFRE contacted slid him she had fallen in love with someone. age certification. She stayed at elephonically and page 10 Of 12 b6 b7C b7C b6 b7C b6 b7C b6 b7C b6

Case 18-2868, Document 283, 08/09/2019, 2628241, Page541 of 883 FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-302 of Virginia L. Giuffre On 93/17/2011 page 11 of 12 GIUFFRE had not heard from GIUFFRE received a stated he was an b6 telephone call from During that call b7C FBI agent. He was trying to determine what she knew about . She did not tel anything about her knowledge of She also received another telephone call from a person that indicated he was an FBI agent. She did not tell that individual anything either. She also received a call from an attorney that was trying to determine if she had spoken with anyone or was willing to speak to anyone she explained that she was receiving telephone calls from people whom she did not know and that she was uncomfortable telling them anything over the telephone. One or two weeks later, an unknown attorne b6 b7C GIUFFRE was uSing a cellular telephone belonging to her husband. She nor her husband could recall the telephone number but advised that the carrier was OPTUS telephone company. GIUFFRE reviewed a series of photographs of individuals and identified the following: LNU, akal | b6 b7C [| -- +d Page 3, number 2f | Page 4, number 3,{ funu . 8 Page 1, number 2, Page 2, number 1, Page 2, number Page 4, number Page 4, number GIUFFRE advised that the following were familiar to her, but she could not recall their names or her association to them: #

Case 18-2868, Document 283, 08/09/2019, 2628241, Page542 of 883 FD-302a (Rev. 05-08-10} 31E-MM-108062 Continuation of FD-302 of Virginia L. Giuffre (On «03/17/2011 page 12 Of 12 Page 1, number 4 Page 2, numbers 7 and 8 Page 3, number 8 Page 4, number 1 Page 5, numbers 5 and 8 The images reviewed by GIUFFRE were placed ina 1A envelope of the case file. When questioned about United States Customs and Border (CBP) Patrol records of her entries into the United States, GIUFFRE advised that _her Januar 2001 record was the return from her London, England trip The April 2001 CBP b6 record was her return to the United States b7c GIUFFRE could not recall her travel from March and May 2001 CPB records. GIUFFRE advised that her United States Passport was turned over to the United States Consulate in Sydney, Australia. traveled to GIUFFRE's residence where she provided 20 photographs and her b7C ITM massage school certification. FD-597 Receipts for Property were executed for the items and a copy was provided to GIUFFRE. It is noted that the receipts were dated based on the United States Eastern Standard Time Zone date. The photographs, certification and original FD-597s were placed in a 1A envelopes of case file.

EXHIBIT 32 (Filed Under Seal)

The text on this page is estimated to be only 38.77% accurate

ae iis Hite wpa ant pari ny eae SRR ee ee = a an oan See + ae Cpe

The text on this page is estimated to be only 27.07% accurate

ope SRO SIN : = A : we reese: er va .

EXHIBIT 33 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page547 of 883 armer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. December 30, 2014 New York Presbyterian Hospital Weill Comwell Medical Center Medical Records 525 East 68 Street New York, NY 10065 RE: Request for MEDICAL RECORDS wii BILLING Oar Client/Your Patient : Date of Birth : wn Dates Requested : anuary 1, ee 31, 2000 | eeslilll Our File Number 4 To Whom It May Concern: This is a follow up to our otiginal December 1, 2014 request for medical records (a copy of same is attached far your convenience). Attached, please find a copy of the Refused/Returned Notice for your convenience. Pursuant to same, please be advised that we would like ALL records from August 9, |983—present. If that is too general/broad, please limit the search to January 1, 1998 to December 31, 2000. Please contact us if the reproduction costs exceed $50.00. Please contact us if you have any questions or wish to discuss this matter further. We look forward to your prompt compliance with this request. Very truly yours, _FARMER, JAFFE, WEISSING, WEISSING, EDWARDS, FISTOS & LEHRMAN, P. L. — ADwee. Amy W. Dishowitz, Paratega] For Bradley J. Edwards, Esq. BJE: awd Enclosures ee FCEIVE JAN 0 6 2015 ¥: ¥s see tecereeerwres-* -¢444e8% 425 North Andrews Avenue, Suite 2, Fort Lauderdale, Florida 33301 954.524.2820 office 954. 524,2822 fax GIUFFRE003258 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page548 of 883 armer, Jalte, Weissing, Edwards, Fistos & Lehrman, P.L. Can Tam a Clute ATT personal wi purty Arosgil Gearh Gormmestinl Utigadion es ' AAT December 39, 2014 New York Presbyterian Hospital Weill Cornwell Medica] Center Medical Records 52,5 East 68 Street New York, NY 10065 RE: Request for MEDICAL RECORDS and BILLING ra Our Client/Your Patient : Date of Birth : na Dates Requested i anuary 1, L298 — er 31, 2000 Our File Number To Whom It May Concern: This is a follow up to our original December 1, 2014 request for medical records (a copy of same is attached for your convenience). Attached, please find a copy of the Refused/Returned Notice for your convenience. Pursvant to same, please be advised that we would hike ALL records from August 9, [983 — present. If that is too general/broad, please limit the search to January 1, 1998 to December 31, 20. Please contact us if you have any questions or wish to discuss this matter further. We look forward to your prompt compliance with this request. Very truly yours, —_ FARMER. JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Amy W. Dishowitz, Paralegal — For Bradley J. Edwards, Esq. BJE: awd Enclosures . . — Pe cae JAN 0 6 2015 425 North Andrews Avenue, Suite 2, Fort Lauderdale, Florida 33301 "954.524.2820 office 954.524.2822 fax “ — = (ma GIUFFRE003259 CONFIDENTIAL

The text on this page is estimated to be only 42.04% accurate

Case 18-2868, Document 283, 08/09/2019, 2628241, Page549 of 883 I 215-2: <20290. 0671 recor NEWY ORK-PRESBYTERIAN HOSPITAL os New York Weill Corel] Medical Center CO Orr OO 8 eee ee (Ee A NURSING DOCUMENTATION aR RT: SHEET EMERGE! DEPARTMENT TRIAGE ASSESSMENA/DOCUMENTATION RECORD! m 7 ge eee | iene ica eit, Fee, ong a £2 Respiratory O) Seteurss (J Unis on RT TE ee - a s = tmer * 5, -#°® TIRGINIA L. Chiet Conmpisins: Brief Azsoxamantitx of presenting Compats: IC) [AA gen a LaA YB ae mre w ‘ ar Why NAL PAD. WE mo "ol fete Kas? * faa) pagent) S321] ena a 37) x HOPI Se Lissebhere beset oes skimpoee teenth? 3s soo E% Be me oe Osos ae Fe de dl def hehe” Ade, ree GA Oita OY of tig sl Ligegditeos : Perry eet ss pecetavoncteres. vonsey® Snes te 2 Ric - rerreys: trict tivtie 4 S Sr igeeuse hey Eyes . aay ereeees Page + 01-08-2015 21:16:54 GIUFFRE003260 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page550 of 883 Ee NrwYoOrK-PRESBYTERIAN HOSPITAL New York Weill Cornell Medical Center WARES EMERGENCY DEPART MENT PHYBICIAN’S RECORD & DISCHARGE cee a 6 oy |w- ae id DATE ANO TIME OF VinrT “a OE STOR ee 7 ME eee. ut wo. cr W leJT FL. ew, Zftojeo! J : ru an ue o~2. ) if ae carne READ THE PROVIDED Dd) WELD CARE 4G INSTRUCTIONS REGARDING (ZATION inf TAB-O742 FOR = i RETURN TO EMERGENCY DEFATIMENT FOR PERSISTENT. 2" WORGENING, OF NEW s1 OF NEW SYLPTOMS, INCLUDING: : ao Ars ey i Page 2 01-06-2015 21:16:54 oe ee GIUFFRE00326 1 CONFIDENTIAL

The text on this page is estimated to be only 43.25% accurate

Case 18-2868, Document 283, 08/09/2019, 2628241, Page551 of 883 Type: EMERGENCY DEFT REGORD NrwYork-PReEsBgyreRtan Hosprrar, New York Weil! Cornell Medical Center A a i & EMERGENCY NOTES, Continnatio floboots te a, EMERGENCY DEPARTMENT focal a NO PLATE, PRINT NAME, 2x atti HISTORY NO. dk welfere a tide ©, rene act CS hae, recing Sf) Def chlren te Awta aS x Oe ‘Ge Btey GOT oa were) Ts AL F Cher Pe ln hah) om x Slidt— j ctlhe | gy ie zé —— * n ? a V7) yy pepe et Se ye a S : ‘ - _——t ' ‘oo a: 7 ee eee al sti . i 7 cabhoeres. rather beam Werte, , friar, Sertee — ‘iene RECORD Page 3 _01-05-2015 21:18:54 GIUFFRE003262 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page552 of 883 Doc Type: EMERGENCY DEFT RECORD NrewYORE-PREsByYTERIAN HOSPITAL New York Weill Cornell Medical Center cE g& EMERGENCY NOTES, Continuation EMERGENCY DEPARTMENT “ a all a D : RA Ca ~ atte le In gp, SS | AAD A sim bo Ts (ef-s LR THE DK 4 Ps et - = : i es 5 : CAT " A re Bo osc aieseys i SA- _ 2 ae Em ah L pa a 2s Co yt CIOL CL KO a {- Fem © At Foe a ELA a cy | f Ore fA Of-06-2015 27:16:54 GIUFFRE003263 CONFIDENTIAL

The text on this page is estimated to be only 47.61% accurate

Case 18-2868, Document 283, 08/09/2019, 2628241, Page553 of 883 NewYork-Prespyrerian Hosprrar New York Weill Cornel Medical Center @ In EMERGENCY NURSING FLOW SHEET EMERGENCY ee IT NO PLATE, PRINT NAME. SEX AND SEO ICAL REUDE D NG, HURSE | INITIALS i Sty eee eek ON. mr = ¢ 74 Cf LL Sa tis teh a fe Abd gv ay VON A 7 - : Ea — A CL TRYL eS te Mot Or ky t hi 47 Vi et, PMAACe Autih—-t ode OP ‘SE cla a? Le} tt a ne tor, Co 3. 5 anc ea Fer & . ee ee rept se PR ah! slate __}o a CO) Cord, ing. CG BUG FS -oid Gua 2 eT FIT 0 ABG 01-06-2015 2171654 GIUFFRE003264

Case 18-2868, Document 283, 08/09/2019, 2628241, Page554 of 883 I 2.1 y20:esscacency vert nzcoro NEwYoOrK-PRESBYTERIAN HosprraL New York Weill Cornell Medical Center botacte MU A «46185 ® EMERGENCY NOTES, Continuation EMERGENCY DEPARTMENT ee tae Sn bduratihe rie LAA yf Maunbia ppvertet, es pr. a we eS zi Dice ae ee aaie3 ieee) vn ! BS ee 01-06-2015 21716:54 ee od by DINGO! 1 GIUFFRE003265 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page555 of 883 eee NEWYOoORK- PRESBYTERIAN HOSPITAL New York Weill Cornell Medical Center fire fe 45104 ___ PROGRESS NOTES _ a) SRP ye ana an 44 ee. et ee ee OCS OLS 7 gisteeys: ed by DINGO11 Page % GIUFFRE003266 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page556 of 883 DocType: LAB REPORTS 525 Hast 68th Street, New York, N.¥.10021 M. Desmond Burke, M.D., Laboratory Director CLIZNT INFORMATION: EMOND, STEPAREN D MD 525 East 58th Street New Yor!: _N¥_ 106210500 Client#: 00000 ~ NsW YORK HOSPITAL Coll Date: 07/09/2002 Recvd Date! 07/09/2001 Rpt Date: O7/19/2001 Coll Time: 1911 Recvd Time; 192] Rpt Times 0438 FINAL Bn TEST NAME _ABNORMAL NORMA REFERENCE UNITS COMPLETE BLOOD COUNT WSC g.2 3.4-11.2. K/ub RBC 4.23 }.680-5.20 M/uL HGS 13,2 11.7-16.0 g/dl ECT 38.2 35.0-47.0 | $ MeV 30.3 821.0-100.0 fi MCH Bisa _27,0-34.0 pg MCHC 24.6 _32,0-36.0 g/d RoW 12.6 (12.0-14.0 3S PLATELET 12 0 150.0-450.0 K/uL MPY 10.4 6,.0-12.9 £L AUTOMATED DIFFERENTIAL NEUT & 83.4 H 45.0-75.0 8 LYMPH %& 8.1L 20.0-50.9 & MONO + 7.6 Z.6-11.0 % mos % 0.5 G.0-5.0 & BASO % 0.4 0.0-1.0 4 NEUT_ ABS 6.8 H Z2.1-4.39 K/uL_ LYMPH 4BS O.7 Lb 1.4-2.5 K/ul MONO ABS 0.4 0.2-0.9 K/ul EOS ABS 0.0 6.0-0.3 Kful 3.0 0.0-0 1 K/h ‘Page 1 01-06-2015 21:17:11 GIUFFRE003267 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page557 of 883 DocT ype: LAB REPORTS L=LOW, H=HIGH Page: a fFONTINOBD OUTPATIENT RE2ORI Page 2 01-06-2015 24217511 GIUFFRE003268 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page558 of 883 Patient Name: DocType: LAB REPORTS ROBERTS, VIRGINIA L. Coll Date; Cory ro) Sed eee ames ect Se T sw 67/09/2001 TEST NAME RODTIINE CHEMILGTRY AMYLASE OUTPATIENT REPCR'! Raps ed by DINGOT4 Recvd Date: Recvd Time: ABNORMAL CLIENT INFORMATION; HMOND, STEPEEN 0 MD 525 Fast 68th Street New York Client: NEW 07/09/2001 1921 FINAL NORMAL Page 3 CONFIDENTIAL 00009 YORK HOSPITAL Rpt Date: Rpt Time: 67/10/2001) 0433 REFERENCE UNTTS U/L ry Page: CONTINUED 01-06-2015 21:17:11 GIUFFRE003269

Case 18-2868, Document 283, 08/09/2019, 2628241, Page559 of 883 DacT ype: LAB REPORTS Patient Name: ROBERTS, VIRGINIA L. CLIENT INFORMATION: BMOND, STEPHEN D MD 525 East 68th Street Med Rec #: Date of Birth: New York NY 109210000 RegFill Client#: OG006 NEW YORK HOSPITAL Coll Date: 07/09/2001 Recvd 07/09/2601 Rpt Date: 07/10/2001 Coll Time: eek Recvd Time: 191] Rpt Time: 0433 CANCELLED TESTS PROCEDURE DRAWN DATE — REASON BASIC METABOL PANEL 07769/01 Order Entry Error Page: a Ra: ed by DINSO11 END OF CHART 01-06-2015 27717711 GIUFFRE003270 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page560 of 883 ES ron: 525 East 68th Street, New York, N.¥,10021 M. Desmond Burke, M.D., Laboratory Director ee ieee —— CLIENT INFORMATION: EMOND, STEPHEN D MD 525 East 68th Street New York NY 100210000 Client: 00000 Patient Name: 4 Req#: ___—s Chien 00000 a NEW YORK HOSPITAL oll Date: 07/09/2001 Recvd Date: 07/03/2001 Rpt Date: 07/10/2601 Coll Time: 1855 Rkecvd Time: 1913 Rpt Time: 0439 FINAL TEST NAME ABNORMAL NORMAL REFERENCE UNITS MACROSCOPIC URINALYSIS. COLGR DK YELLO YELLOW APPEARANCE S LEAR CULEBAR PROIBIN 30* NEGATIVE BLOOD NEGATIVE NEGATIVE GLUCOSE NEGATIVE —_—swNEGATIVE KETONES TRACE* NEGATIVE pH 1.0 4.8-8.0 BILIRUBIN NEGATIVE NEGATIVE SP GRAVITY 1.025 1.005~1.030 NITRATE NEGATIVE NEGATIVE LEUKOCYTE £S87ER NEGATIVE NEGATIVE MICROSCOPIC URINALYSIS OTE SEE NOTE RBC/HFE Q-~2 0-2 WEC/HPF Onz a= RENAL EPITH NEGAISVE NEGATIVE NOTE (09/06/2000 -- Current) THIS URINE HAS BEEN EXAMINED FOR WBC, RSC, CASTS, CRYSTALS AND EPITHELIAL CELLS. ANY OF THESE ELEMENTS NOT REPORTED WAS NOT FOUND. Page 5 01-06-2015 21:17:11 GIUFFRE003271 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page561 of 883 ccT ype: LAB REPORTS *=ABNORMAL, I=FOOUTKROTE Page: a ENO OF CHART Peer ed by DINGO Page 6 04-06-2015 21:17:11 GIUFFRE003272 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page562 of 883 DocType: LAB REPORTS 525 East 68th Street, New York, N.Y.10021 M. Desmond Burke, M.0., Laboratory Director CLIENT INFORMATION: Patient Name+ ROBERTS, VIRGINIA L. EMOND, STEPHEN D MD 525 East 68th Street Rew York Client#: 00000 _ NEW YORK ROSPITAL N¥ 1002100600 Cali Date: 07/09/2001 Recvd Date: 67/09/2001 Rot Gate: 07/10/2001 Coil Time: 1915 Recvd Time: 1925 Rpt Time: 6438 TEST NAME ABNORMAL NORMAL REEERENCE UNITS ROUTINE CHEMISTRY, _GLOCOSE 135 70-105 mg/dL UREA NITROGEN 8 5-25 mg/dL CREATININE 0,8 6.35-1.5 mg/aL SODIDM 133-147 mmol /1L FOTASSIUM 3.6 mmo d/l CHKLORIDS 103 94-110 mmol/L coe 21 6 22-32 mmol/L ANION GAP is B9-27 URIC ACID 3.2 (2.5-7.5 mg/dL CALCIUM 3.0 8.5-10.5 mg/dL PHOSPHORUS 3.2 2.2-4.2 mg/dL PROTEIN, TOTAL od 5, 5-6 3/dh ALBUMIN 3.9-5.0 g/dL GLOBULIN 27.4 4 1.8+3.2 g/ab BILIRUBIN TOT 0.7 $.c-1.3 mg/dh BILIRUSIN DIR < g.1-0.4 mg/dL BILIRUBIN IND 55 0.1-0.8 mg/dL _CROLESTEROL 130 = < 200 mg/dl MAGNESIUM 6 1.5-1.9 mEq/L AST. 20 0-45 U/L ALT 13 0-45 U/L CHOLESTEROL (03/17/1999 Current "A ed by DINGO11 Page 7 01-06-2045 21:17:11 CONFIDENTIAL GIUFFRE003273

Case 18-2868, Document 283, 08/09/2019, 2628241, Page563 of 883 Type: LAB REPORTS DESIRABLE: 200 mg/dL BORDERLINE EIGH: 206-232 mo/dL HIGH: ze/40 mg/dL L=LOW, H=HIGH, f=FOOTNOTE Page: 1 CONTINUED OUTPATIENT REPORT Page 8 CONFIDENTIAL 01-06-2015 21:17:11 GIUFFRE003274

Case 18-2868, Document 283, 08/09/2019, 2628241, Page564 of 883 M. Desmond Burke, M.D., Laboratory Director CLIENT INFORMATION: EMOND, STEPHEN D MD 525 East 68th Street New York NY 1OG219000 Client#: o0006 NEW YORK HOSPITAL Patient Name: ROBERTS, VIRGINIA L. Coil Date: 07/09/2001 Recvd Date: 07/05/2001 Ret Bate: 67/10/2001 Coll Time: 1935 ___Reevd Time: 1925 Rot Time; 0433 FINAL _ TEST NAME _ABNORMAL NORMAL REFERENCE UNITS ROUTINE CHEMISTRY io 182 80-225 ofl _ALKALINE PHOS 76 30-110 U/L CORONARY RISK _CHOLESTEROL 230 < 200 mg/dL DESIRABLE: <200 mg/dL RORDERLINE HIGH: 200-239 mg/dl _BIGH : >=240 mg/db mia ed by DINGOT Page 3 05-06-2015 21:17:11 GIUFFRE003275 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page565 of 883 Typa: LAB REPORTS Page: 2 END OF CHART Page 10° 01-06-2015 21:17:11 GIUFFRE003276 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page566 of 883 25 Bast. 68th Etxreet, New York, N.Y.100271 M, Desmond Burke, M.D., Laboratory Pirector es CLIENT INFORMATION: Patient Name: ROBERTS, VIRGINIA L. EMOND, STEPHEN BD MD 225 East 68th street Wew York NY 100210000 eat: Client#: O0000 NEW YORK HOSPITAL Coll Date: 07/09/2001 Recwd Date: O7/09/2001 Rpt Date: 07/10/2001 Col. Time: 1934 Recvd Time: 1934 Rpt Time: 0438 FikAls 7 TEST NAME _ABNORMAL NORMAL REFERENCE GNITS SENDSUT COLTORES BLOOD GROUP AND TYPE PROCEDURE ; ABO RH wv | ry (> My 07/09/2002 1534 ANTIBODY SCREEN AND WORKUP PROCEDURE: ABSC INT 07/09/2001 1934 NOTIMMZD SoS od by DINSOT Page 11 01-06-2015 21:17:11 eh elt GIUFFRE003277 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page567 of 883 DocType: LAB REPORTS Page: i END OF CHART SPARGEE) vad by DINGOTt Page 12 01-08-2015 21:17:11 GIUFFRE003278 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page568 of 883 DocType: LAB REPORTS: eet, New York, N.¥.1¢02] M.D0., Laboratory Director Se5 East 68th Str M. Desmond Burke, CLIENT INFORMATION: Patient Name: ROBERIS, VIRGINIA L. EMOND, STEPHEN D MD 525 Bast 68th Street New York NY 100216000 Client#:s 00000 __NEW YORK SOSPITAL Coll Date; 07/09/2001 Recvd Date: 07/10/200) Ret Dates 07/11/2001 Coll Time: 0941 Recva Timer O94] Rot Time: 0452 FINAL ~ TEST NAME ABNORMAL NORMAL REFERENCES UNITS _GC-CAHLAMYDTA CHLAMYDIA-GC BY AMPLIFICATION CHLA SWAB SOURC CERVIX CHLA SWAB NEGAT LVE NEGATIVS GC SWAB SOURCE CERVIX GC SWAB NEGATIVE NEGATIVE rages Jl END OF CHART teat 00 by DINGO: Page 13 0f-06-2015 21:17:11 CONFIDENTIAL GIUFFRE003279

Case 18-2868, Document 283, 08/09/2019, 2628241, Page569 of 883 ooType LAB REPORTS 525 Bast 68th Street, New York, N.¥-.i00c1 M. Desmond Burke, M.D., Laboratory Director CLIENT INFORMATION: Patient Name: ROBERTS, VIRGINIA L. EMOND, STEPHEN O MD 525 Bast S8th Street New York Ny 1002710000 Client#: GO000 _ — “~—_ EW YORK” AOSP ITAL coll Gate: 07/09/2001 Recvd Date: 07/10/2001 Rpt Date: O7/i1/2001 Coll Time: 1929 Recvd Timer O941 Ret Time: 0452 _ PARTIAL TEST RAME ABNORMAL NORMAL REFERENCE ONITS GENITAL: CULTURE-SCREEN _ SO GOLLECTED: 07/09/01 1929 RECEIVED: 07/10/01 6941 STARTED: 07/10/01 0941 GENITAL CULTURE SOURCE :CERVIX FREETEXT SOURCE: ~~ STAINS & PREPS --O7/10/2001 1342 be MANY GRAM POSITIVE BACILLI CONSISTENT WITH LACTOSACILL MODERATE EPITHELIAL CELLS UF rt 9 tt cy = MODERATE W Page: 1 END OF CHART CONFIDENTIAL Pape 14 01-06-2015 21:17:11 GIUFFRE003280

Case 18-2868, Document 283, 08/09/2019, 2628241, Page570 of 883 Doc Typa: LAB REPORTS G@th Street, New York, W.Y.1002i 525 East M., Desinend Burke, M.D., Laboratory Director CLIENT INPORMATION: EMCND, STEPHEN D MD 25 East 68th Street New York N¥ i00210600 neat: ~~ Clientd: 60000 NEW YORK HOSPITAL Coll Date: 07/09/2001 Recvd Date: a7/10/2001 Rpt Date: 67/12/2001 €oll Time: 1929 Recvd Time: 0941 Rot Time: 532 PARTIAL ABNORMAL NORMAL REFERENCE UNITS TEST NAME GENITAL 1 CULTURE-SCREEN CENTTAL CULTURE COLLECIED: 07/09/01 1929 SOURCE : CERVIX RECEIVED/ 07/10/01 0941 PREETEXT SOURCE: STARTED: 07/10/01 0941 ee i ACCESSIONf: C1-MB-01-045532 +s STAINS & PREPS 07/10/2001 2342 MANY GRAM POSITIVE BACILLI CONSISTENT WITH LACTOSACILLI MODERATE EPITISELIAL CELLS MODERATE Whe SHEN =72.PRKELIMINARY REPORT -—- wee 07/11/2001 2037 MODERATE GRAM POSITIVE BACILLI CONSISTENT WITH LACTOBECiLLT CULTURE BEING RELD FOR FURTHER EVALUATION Piles ed by DINGOT Page 15 01-06-2015 21717211 GIUFFRE003281 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page571 of 883 DacT ype: LAS REPORTS Pads: sal END OF CHART Det Races ed by DINSOT Page 16 01-08-2015 24:17:11 GIUFFRE003282 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page572 of 883 45 Eas Street, New York, N.¥Y.idd Ease 2 M. Desmond Burke, M.D., Laboratory Direct 1 or CLIENT INFORMATION: EMOND, SIEPHEN C MD 525 Bast 68th Street New York Clients; 00000 ———— NEW YORK HOSPITAL NY 100210000 Coll Date: 07/09/2061 Recvd Date: 07/10/2001 Rpt Date: 07/12/2001 Coll Tame: 1655 Recvd Time: 1102 Rpt Time: 0532 FINAL 7 TEST NAME _ABNORMAL NORMAL REFERENCE _UNITS GRINE CULTURE , COLLECTED: 07/09/01 1855 URINE CULTURE SOURCE sURINE CLEAN CATCH RECEIVED: 07/10/01 1102 FREETEXI SOURCE: STARTED: 07/10/01 1102 ACCESSION#: 01-mB-01-0468573 ~~ FIWAL REPORT 07/11/2001 1323 NO GROWTH (<1,900 CFU/ML) PAG : . END OF CHART tee ed by DINBOTY Page 17 _ 01-08-2015 21:17:11 GIUFFRE003283 CONFIDENTIAL 0G ee ee ee a es - .

Case 18-2868, Document 283, 08/09/2019, 2628241, Page5/73 of 883 Dac Type; LAB REPORTS 525 Hast 68th Street, New York, N.¥.10021 M. Desmond Burke, M.D., Laboratory Director CLIENT INFORMATION: EMOND, STEPREN New York Client#: NEW 07/10/2003 0941 07/09/2002 1929 Recvd Date: Reovd Time: Coll Date: Coll Time; _ PARTIAL ABNORMAL _ NORMAL, TEST NAME GENITAL: CULTURE- SCREEN DO MD 525 Bast 68th Street NY 100210000 00009 YORK HOSPITAL Rpt Date: 07/13/2001 Rpt Time: 0541 [REFERENCE UNITS GENITAL CULTURE SOURCE :CERVIxX FREETEXT SOURCE: - = he — + CELLS MOCERATE BFITHELIAL MODERATE WBC SEBN PRELIMINARY REPORT 07/41/2003 MODERATE GRAM POSITIVE BACYLLI CONSISTENT WITH LACTICBAC ILLIA _COLIURE BEING HELD FOR FORTHER EVALUATION O7/2e/2001 1h COLLECTED: 37/09/01 192% RECBIVED: 27/10/01 0941 STARTED: 07/10/01 0941 01-MB-01-045532 o Renenee Roe ) tad ~J 1130 MODERATE GRAM POSITIVE BACILLI CGNSISTENS WITH LACTOBACILLI CULTURE BEING HELD FOR FURTHER EVALUATION BEE ed by DINGO Page 18° CONFIDENTIAL 01-06-2075 21517711 GIUFFRE003234

Case 18-2868, Document 283, 08/09/2019, 2628241, Page574 of 883 220°: Page: ak END OF CEART eR 2d by DINGO Page 19 01-08-2015 21:17:11 GIUFFRE003285 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page575 of 883 peType: LAG REPORTS 525 Bast 68th Street, New York, N,Y.10021 M. Desmond Burke, M.D., Laboratory Director CLIENT INFORMATION: EMOND, STEPHEN D MD 525 East $6th Street New York N¥ 100210000 Client?#: 00000 NEW YORK HOSPITAL Fatient Name: ROBERTS, VIRGINIA L. Coll Date: 07/09/2901 Recavd Date; 07/10/2061 Rpt Date: 07/14/2001 Coll Time: 1929 Recvd Time: O94. Rpt Time: 046351 | FINAL TEST NAME ABNORMAL NORMAL REFERENCE UNITS GEN- TAL: CULTURE~SCREER | eee GENITAL CULTURE COLLECTED: 07/09/01 1929 SOURCE : CERVIX RECEIVED: OF/10/601 0941 FREETEXT SOURCE: GITARTEN: 67/19/02 6941 ACCESSICN# = 01-MB-01-0455352 =f ax atene STAINS & PREPS O7/1072002 1342 MANY GRAM POSITIVE BACILLI CONSISTENT WITH LACTOBACILLI MODERATE EPITHZLIAL CELLS MODERATE WAC SEEN =-- PRELIMINARY REPORT 07/11/2002 1037 MODERATE GRAM POSITIVE BACILLI CONSISTENT WITH LACTOBACILLI CULTURE BEING HELD FOR FURTHER EVALUATION 07/12/2001 1130 MCDERATE SRAM POSITIVE BACILLI CONSISTENT WITH Ee jm LACTOBAC Tt, CULTURE BEING SBLD FOR FURTHER EVALUATICN . FINAL REPORT OFf1LS/ 2001 Lil? CONSISTENT WITH Pagé 20 01-06-2015 21217711 CONFIDENTIAL GIUFFRE003286

Case 18-2868, Document 283, 08/09/2019, 2628241, Page576 of 883 DocTypa: LAB REPORTS LACTOBACILLII NO NEISSERIA _GONORRHEAZ ISOLATED Pace! 24 END OF CHART beaer se od by DINGO1t Page 21 01-08-2015 24:17:11 GIUFFRE003287 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page577 of 883 oc Type: ORDERS NrwYoORK-PRESBYTERIAN HOSPITAL New York Weill Comell Medical meg a DIAGNOSTIC PROCEDURE ORDERFORM. ieee Lata caakn Ue PeaeliG Ra NAT nis Ba igosalere ok 400 compiete Clinica! Oxta Saction Sign crdarform. | (Zz) Gast Cher: a i GasiGes is ee Eu Drake Punexct Time, Chtk (nitive CH Vout Aren: Gal ine Cari and provi cenets) ard yma(s] test(e) wik ba dane, Link Cierk. Wie the Dale and Thine, ax provided by text essa, onto this lotrn. @) Unt Clerk: Follew ourent procedure for pasting ord a writ ara! pic fore 1+ ERA Gey ie) “RADIOLOGY ~ | PRIORITY 1,2 ora| = Fax TO BE DORE Beet et [feet TT | CXR tt LI He So 5} _ RN: Verity order and sian on designated line. 8 sorter Redieea? DO ek tes form. Phors-qea io request cham. Give yetow copy to)” P teciostes Prep. Is required. C detcsiios WEITTEN SORBENT te Ber niteed CLINICAL DATA Fi Peditia Pat "ton Plaiatit Ractciogy PF Gam spi to 60738 C Consent Obtained a tego! (J Respiratory Precautions ars : fic ry — re By CO Wound/Skin Precautions .., Finical etary... pT Ce See ee Og et OU 1 “9.7 . ’ Tr ° . —, remy — * . . « . 8 * - * 5. Ror Contrast Stsdips: BA) Crest Ae Crna Re SST 5 Code YAY Beeper # Date Sopot) Tine w= = kar ie} Attending MD a yy AN Page 1 91-06-2015 21:17:22 GIUFFRE003288 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page578 of 883 Many of the Radiology examinations require that the pation be siacaal for the jeceitie that is being ordered. We hava incluciact a brief description of the most common pritedures, HOWEVER, ai! exams. are included In the Manual of Laboratory, X-Ray, and Special Procedures and are contained in the Ancillary Services section In this reanual, The procedure in the manual comains a trlef description, indications, contraindications, patient praps and special instructions. Please call Pediatric Radiology x62554 for modified preps for pediatic cases. NOTE: SEQUENCING of exams is critical when ordering multiple exame. Sarium studies generally : shouid be done after other diagnosis procedures. See Manual for more compiete information or discuss with Radiologist so as nat to delay patient care. G.I. Sertes Prep: N.P.O. from Midnight day before study, Suspend all medication except essential, Antispasmodics should be ciscontinued 24 hours before procedure. . Aftercare: mild laxative and fluids. Barium Enema Prep: Clear Suicds 24 hours prior to study, © ” 60 ml magneskim citrate by mouth at 6 PM day before study... ' 4 disacodyl tablets (ulcoked by mouth at 10 PM the night before exam. 1 bisacodyl suppositery motning of exam. Nothing by mouth efter midnight. L¥.P. (intravenous Pyelogram): Prep: 10 ounces of magnesium olirate at 6 PM evening before exam, Nothing by mouth after midnight —C.T. {Head & Body} Prep: Cigar fluids 4 hours prior to study. Contrast injection requires the patient be NPO for at least 4 hours prior to study. Pailents must be cooperative and able fo hold theif breath for Body CT's. Aftercare: Patiants receiving contrast should be hydrated, MRI CONTRAINDICATIONS: (> Patlants over 300 Ibs. @) Patlants with PACEMAKERS CANNOT BE DONE, &) Patients with metal surgical clips and other prosthetic devices should consult wilh the Radiologist bafore ordering MRt's. @) Claustrophobia and inability to remaln stil are alse contraindication and sedation may be required, SEE MANUAL FOR COMPLETE DETAILS. Soncgrams PELVIC/OBSTETRICAL: Requires full bladder, Patient should crink water and maintain a full bladder. ABDOMINAL/AORTIC RENAL: Clear fiquid diet for 24 hours prior to exam, Nuclear Medicine - SPECIAL CONSIDERATIONS: 1. To obtain an. ee Lgera.ns pry oa manta oy ae tor up . one hour in supine position. A | 7 mien 2 Fer biliary, meokors, cardia, and aky sudies waace saciation, the paeert must be fasting for a minimum of 3. Radioactive iodine is used for thyroid uptake and scanning. Do not schadule test if any of tha following drugs or foods have been ingested within minimal time linvits Incticated: Iodine Compound {Lugol's Potassium jodids, Kelp); 1-2 weeks Seafood, Ovaitine, vitamin pills, Orande, Cambid: 3-5 days Diodrast, Hypaque (i.¢., VP's anc arteriograms): 1-2 weeks Priodax. Telepaque, sic. (ls. gallbladder serie): 3-6 months Upicdal (.e., branchoprams): at least 6 months Ank-hyrold cruge (.4., Propyaiowsch oer 7 days. If in preparation for urgent radioiodine treatment, consultation Is ac Thyroid substance (.6., Guclecaias Geren Testi 4 weske Tri-iodathyronine (Cyiomel): 10-42 days. if special ciroumsiancas requirs evaluation despite the above indications {contraindications) Nuclear Medicina physician consultation advised. ate ‘ed by DINGOT 1 Page 2 01-08-2015 21:17:22 oe : oe | aa GIUFFRE003289 CONFIDENTIAL

The text on this page is estimated to be only 33.40% accurate

Case 18-2868, Document 283, 08/09/2019, 2628241, Page579 of 883 es ORDERS nt ie ee ee ee ee NewYork-PRESBYTERIAN Hosprrat ae be PIR New York Weill Corneil Medicai Center # hz CE RE TIRGINIA L. ST = PHYSICIAN'S ORDERS 1 EMERGENCY DEPARTMENT IF NOPLATE, PRINT NAME, SEX AND MEDICAL RECOAD ND. a, A if ni aly Saati Allergies: 4 ‘VitefSigns: == Routine Oaqihour LlqtSminutes _ Activity: Routine ss OBerest ie —_ CJ Other: We... Oo Heptock arate se i ON Wound/Skin ae: DB Foley Catheter geist detect PTPTT ee a ie ee Arnylase ~~. - —_—k > °.4e ——_ ~~ re ae as ESA : oats lavel Tox. Seraen ee aeeee, dea ade es AG Serum HCG rm ~~“ ow HO —~— ee non eer oe 2 7 Be Ties ties GROG MM ete PIV EIAN >Cone GREP eye) re ee” Hy Pu on nan eos! bf CE-E-E tre aa weer 0 | ely ee ee ewer eee: ree oer Se = tenes et a cl He the nt ee ee ee Leu. Le efi Cr; fe f2 Sethe ~ ~s o opens. FCs am Btn Se aa oe ay Le @) nw rr al ot . ee . PySiOaae SIGNATU NE Nan PICKED Ur By wee am . beg x iN in se -. nea eww adie aes = ire phe e TUS 7acue = S erste meee esr 8 Oe ee ee eee “ema ae Sow 1-4 Me et —_ a ek te) el ed ee ——~nedews's «+ eee an debe «64 « pe ones oti wattinn eee eae PHYS PNAS URE i aD CODE yrs DATE TIME J J et ON un v ‘ ‘ PS oD Oe fF - = . oom t8 sa. -—-e wet « a - - —s ee ee . ms =a ee a -*. : . je * “ UO HE FSO TM tL ha A Tap jaa PS KX eA a’ ry File v7 ye PT) Soe SdGhs (AC, “= Doneinh . sien mans 01-06:2015 21:17:22 ay TRMe GIUFFRE003290 CONFIDENTIAL

EXHIBIT 34 (Filed Under Seal)

To: _ Sharon. Chureher@mallonsupday,co.uki Shara Chur BMALONSUNEAY £P-UBL, 581 of 883 Sent: Thur 2/17/2011 9:44:51 PM Importance: Normal Subject: RE: Received: Thur 2/17/2011 9:44:51 PM Not a problem but we have to continue — rest of the interview at my house being that the children are not feeling well, you have got thi only document s pertaining to my case. Look forward to seeing you this afternoon . Jenna From: Sharon.Churcher@mailonsunday.co.uk Sent: Friday, 18 February 2011 7:25 AM To: Virginia Giuffre Hi there Have been up all night writing. Won't have an opinion from our lawyer on how much can be published until London wakes up. The lawyers wanted internal FBI documents but | think the Justice Dept letter is all you have from the feds??? Anyway can | give you a call early afternoon? Maybe have a late lunch’? S This e-mail and any attached files are intended for the named addressee only. It contains information, which may be confidential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then delet it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any attachments to it for viruses as we can take no responsibility for any computer vir which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent abuse of these facilities. Associated Newspapers Ltd. Registered Office: Northcliffe House, 2 Derry St, Kensington, London, W8 5TT. Registered No 84121 England.

EXHIBIT 35 (Filed Under Seal)

Tor Sharon. Churcher Gara sae oa ST ROBOT EOP YSL e583 of 883 Sent: Sun 2/13/2011 4:29:38 AM Importance: Normal Subject: RE: Agreements etc Received: Sun 2/13/2011 4:29:38 AM Hi Sharon, my address is ee me back for the directions from gosford and my hubby will lead the we from there. ----- Original Message----From: Sharon.Churcher@mailonsunday.co.uk Sent: Saturday, 12 February 2011 2:10 AM To: Virginia Giuffre Subject: Agreements etc Hi there, Thank you again for your email. We totally understand your concerns. Please don't worry about anything. Whatever happens, we are bound by confidentiality unless you consent to an article in a formal contract signed by you. Since | will be in the air by the time you wake up, can you email our Assistant Editor Sian James -- sian.james@mailonsunday.co.uk -- your lawyer's information please? Sian will arrange to get him whatever assurances he requires. We really want to make this work and of course we want to protect you. We'll be really grateful if your lawyer will provide us his cell phone number as we'd like to sort this all out asap. Meaning we would like to talk to him Saturday EST. | will give you a call from Sydney. Fingers crossed we get over this last hurdle! Best regards, Sharon This e-mail and any attached files are intended for the named addressee only. It contains information, which may be confidential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then delet it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any attachments to it for viruses as we can take no responsibility for any computer vir which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent abuse of these facilities. Associated Newspapers Ltd. Registered Office: Northcliffe House, 2 Derry St, Kensington, London, W8 5TT. Registered No 84121 England.

EXHIBIT 36 (Filed Under Seal)

FUT eer a eee BSciment 283, Us USO1e, SbOSe FT Pagesss of 883 Sent: Fri 2/25/2011 10:12:25 PM Importance: Normal Subject: RE: Re: Received: Fri 2/25/2011 10:12:25 PM The flight logs didn't come through properly,could you please resend them? Thanks- Jenna ----- Original Message----From: Sharon.Churcher@mailonsunday.co.uk Sent: Saturday, 26 February 2011 7:56 AM To: Virginia Giuffre Subject: Re: Can u look at the flight logs | just sent and see if any ring a bell re Virgin Is/Andrew orgy please? S XO |------------ > |From: | |------------> DP nanan nn nn nnn nnn nn nn nnn nnn nnn nnn nn nnn nn nnn nn nnn nnn nnn nnn nn nnn ccna nn nnn ncaa nen anna nanan naan nnn ana ann nn nan ne nanann nna nenannnnaneneaae| DP nnn nn nn nn nnn nn nnn nn nnn nnn nnn nnn nnn nn nnn nnn nnn nnn nnn nnn nn nnn nnn nnn nnn nnn nnn nn nn nnn nn nn nnn nnn nnn nn nnn nn nnn nn nnn nn nnn nnn nnn nn cane |-- a > |To: | |------------> D nnn nn nnn nn nn nnn nnn nn nnn nnn nnn nnn nnn nn nn nnn nn nn nnn nnn nn nn nn nnn nn nnn nnn nnn nnn nnn nnn nn nn nnn nn nn nnn nn nnn nnn nnnnan| |Sharon Churcher P nanan nanan nnn n nn nnn nn nnn nnn nnn nnn nn nnn nnn nnn nnn nnn nnn nnn nnn nn nnn nnn nnn nnn nn nnn nnn nn nn nen nnn ne nnn nnn naan naan nnn nnnnnnnnnnnnnnnnnan| |------------ > |Date: | |------------> DP nan nn nnn anna nn nnn nnn nnn nn nn nn nn nnn nn nnn nn nnn nnn nnn nn nnn nnn nn nnn nnn nnn nn nnn nnn nn nnn nnn nn nn nnn nnn anne nnn nn nanan nann nn nnnnnnnnnnnnnnnnnae| (25/02/2011 20:54 GMT DP nnn nn nn nanan nnn nnn nnn nnn nnn nnn nnn nnn nn nnn nnn nnn nnn nnn nnn nn nnn nn nnn nnn nnn nnn nn nn nnn nn nn nnn nnn nnn nn nn nnn nn nnn nnn nnn nnn ncn nnn nn nccnne| wees ee > [Subject: | |------------> DP nnn nanan nn nanan nnn nn nn nnn nn nnn nnn nn nnn nn nnn nn nnn nn nn nnn nnn nnn nn nn nnn nnn nnn nnn nnn nn nnn canna nn nn nnn nn nanan nanan nnn nnnnennnnnnnnnnnnnnce| IRE: P nanan nnn nnn nnn nnn nn nnn nn nnn nnn nnn nnn nn nnn nn nnn nnn nnn nn nn nnn nnn nn nnn nn nnn nnn nn nnn nn nn nn nn nnn nnn nn nnn nnn nnn nn nn nnn nn nn nnnnnnnnnnnnnan| Hi shazza, | am hoping it all goes well this a.m, please let me know when you know something. As far as other publications go, | am happy for your company to decide as long as | am not made out to be a vixen...you know my taste...he..he..! Talk to you soon buddy! =) Jenna ----- Original Message----From: Sharon.Churcher@mailonsunday.co.uk Sent: Saturday, 26 February 2011 6:46 AM To: Virginia Giuffre So far it is all looking good. Waiting for a comment from Andrew. Will let you know as soon as we get it. Are there any publications to whom you do not want the piece syndicated? (You get 50 per cent of the proceeds).

im Case 18-2868, Document 283, 08/09/2019, 2628241, Page586 of 883 This e-mail and any attached files are intended for the named addressee only. It contains information, which may be confidential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then delete it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any attachments to it for viruses as we can take no responsibility for any computer virus which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent abuse of these facilities. Associated Newspapers Ltd. Registered Office: Northcliffe House, 2 Derry St, Kensington, London, W8 5TT. Registered No 84121 England. This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email This e-mail and any attached files are intended for the named addressee only. It contains information, which may be confidential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then delet it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any attachments to it for viruses as we can take no responsibility for any computer vir which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent abuse of these facilities. Associated Newspapers Ltd. Registered Office: Northcliffe House, 2 Derry St, Kensington, London, W8 5TT. Registered No 84121 England.

EXHIBIT 37 (Filed Under Seal)

The text on this page is estimated to be only 32.97% accurate

Case 18-2868, Document 283, 08/09/2019, 2628241, Page588 of 883 UNITED STATES. DEPARTMENT OF STATE a : EP APPLICATION FoR [| | PASSPORT [|] REGISTRATION a (Type or print a8 captial letters in tive of black ink in. wiete areas only) a RRR Peet mates ee es i : 444 -ee | APSE EH PU. ¥ 3 ; | ~— : ’ : (venemmans 4 ran tb TO. STREET./ RED ¢ OR £0. BOX i 7 . ' ’ t | fi od , - | : ; ; ’ ; perereeiareprerraclirtati tactnataicii pil futetincacieae lente Rcmejeatenial ZIP CODE mA “ ~ COUNTRY / IN CARE OF GI applicable] be ee Tt EE " , f } i f i ; ee dovtceienllasiliine teen Mice aieiln 2 et peers 5 HATE OF Sin TH Phecs NE fy OO ¥r Date _ §, SOCIAL SECURITY NI eT EREL- Fas MBER Personal Information } 5 }2 oT? LP TiN E $y 44 i) nd a : ib fA S tL. PACES NAME = few a - hiee ket B . ; ry : : . itt MAVE ¥IHE EVER fo +} i 5 J Ih} meee r ' a pe bE oo eee ’ » ; hii MART ; f Fd ory : Mek cn Naa . Sati FEE | BARS ; ‘ |? GEEHER WAMES YOR PAVE tISEi } 4 > ' - . - : ‘ — ek ~ 18. HAVE YOU EVER BEEN ([SSULD ALS PASSPORT? TT, PAs t J hes LAN cy pe 74), 38 nh s4 FF og : F F ; Pr: 5 $5 ; i eee ¥T ee ‘ ‘4 . ’ j j , | reo ™ , | Lp ef) ro + OSS oe can aageebenaae aetna hacimabieniniabiieecadnteiaitdnnntamaninnineet rele enn ean tin eaten rience apie ' ° i Ke The 1S. POSSE RE FO CTE @ SLE ore rt AHEM ert meechieipincer: Fue we roe Seer? Whee «| = vate sievtioaty “ald ESasper! cetant } i ; ' pid Oredaste The Stayer. cet gan aes ttt why te prevenve Pastor Raf et oretanied > Poe DSP .64 : : ee sues cache aentensiansen eboocachseensincechasntseeaeoane naa mecencnseat ones spas scaceneieieliamUnGancan aes mconisal | i : . $8. ERERGENC Y CONTACT > R--y Vay. tar j ‘ ne. =e PAARL PLA j . F ¥El PLAN ; t ‘ : ' i : oper sma? rent g bag tat. twets si wail i ‘ : b =F ‘ } ‘ 1 % . a 3 ; ; | ‘ ' i : 4 ; | | : i ‘ | | | ‘ f : ; a > - “— * N ADMINISTERING 0 i i r ; a | : ‘ ; ’ { , Bree . . ‘ . soap eaten ~~ Pea eG pened lc my paemnbibe » ar 3 fs A A ' | arent at seni: tpi Sieiatieee if: echaetietvinies prey has | re t cd bniasscaspasianete esi en wea Le, ee tee oe aR NOt CoE 5 Apphcent's Signature age 13 ae olden 1? OFM SECEPTANCE AGENT &S Lise ; ; | ys a Set ei é eilrervecti thee bouw aw 7 Se eee ee ee ; = 7? ¥ r : F : i I i | FOLA: (6X6 ' bed : i *, ' ts } ce eee em ee me ce cee cee ee ome ee es et ‘ } Shhatieeds OF Haya either Gd 16 2 ont epnkc wea ; i one a . eo ante . a . é eitedreink sianhetuies ty ! i23 APPLICANTS (DENTE YING DOCUMEN ' ~ i ; *, mit tt ; 1 if te F | | 7 | . ; : i . sal. sssrcenen oa = : 4 4 ft) ‘* S28 i t Su . rf + FR 7 ri Pest. r rent ADS wiv evidenrte wt tevaevyatt 9 ornament OR ED A RO On es ee hone hi i } f! E r r i i i tf t : HS t Hw { . ; a ; ‘2 re th) | FOTA: (6){6) a, ry . i : ; ‘ SE cied beiebaciesak tacks naeei tetas att nae ae 1 ‘ 7 “4 ' i i i ¢ a rr ata rnin lreA eae einabibmasnaneirininembarpapeiehite be sestoiip Mane " on - » ws i Page 1 POM OS 3. tt yo tetee HANES) 8 SESS foe tt BA . — oe IN PAE ot Poin Appowed OME NO. 1405-004 (Exp. a7 91/2007) Eatenated Burden - 20 Minutes’ GIUFFRE004721

EXHIBIT 38 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page590 of 883 ‘ / i j ‘ s 7 - . #7 once os ‘ } NV = - . A ‘ \ C “ \ 4 * \ ( ? \ \ . % ‘ ‘ \ \ ; ZX —— D0 A ; -_ - MO, \. WA PHONE NUMBERS: c} (A) (Ww) c\-: Zo ‘ — = —-- atc AGE: (XS ooo: ATE HEALTH INS. FAMILY BACKGROUND/HISTORY SINGLE (Not io arelationship) SINGLE (In a relationship) - NAME AGE Fiew long Description of partner DF FACTO RELATIONSHIP? « NAME AGE How leagy_ Descrioton of partner _ a = CHILDREN OF RELATIONSHIP: SNS DAUGHTERS: te ie oa aera ni MARRIED: Name “Aco yes AGE: Ve “2 iow tong c A Lo Description of spouse 7 ‘ On tia a 2 : ~~ Description of shared relationship: (nor a CHILDREN: pavarrens:————$ [i PREVIOUS MARRIAGES/SIGNIFICANT RELATIONSHIPS AM A l. NAME | HOW LONG Reason relationship finished CHILDREN: a * . Soe Ed ‘ ‘ \ \ - om . , ‘ re E _— _ re 7 REFERRAL SOURCE % c.aods LH. MOYORAL | GIUFFRE005433 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page591 of 883 STORY Mm _ awk FAMILY HISTORY: ee, © at ee "3 w= ns toes MOTHER: AGE __<' HEALTH . ™ GS eee Seale erin, nee Aor a. MARITAL STATUS: MARRIED: SEPARATED? DIVORCET: REMARNED: a New partner nn FeO | ¥ Relationship with Mother: Self. sincuiciininsit DESCRIPTION OF MOTHER. CARINGILOVING.-— NURTURING -—-- POSITIVE - ea SUPPORTIVE —- SENSTITVE — DOMINANT —— NEGATIVE — CONTROLLING -— "YF hy ‘ei st w% ae Ag\ aN ENVIRONMENTAL /GENERATIONAL FACTORS:—————___—_—_-”""""_ _ * 5 , tts MANIPULATIVE —- DEPENDENT --— SUBSTANCE ABUSE. ee DESCRIPTION OF RELATIONSHIP: ee an CLOSE—- ¥ERY CLOSE ——- STRAINED Lf - DISTANT ——NON EXISTENT “S— cs SS aes — FATHER: AGE c2 HEALTH MARITAL STATUS: MARRIED —— SEPARATED -— DIVORCED —— REMARRIED ——— NEW PARTNER st lepepelitseeiasmaeh apne tacereremmet tei lsneh eonnmwewe SURE SEA i DESCRIPTION OF FATHER CARING—LOVING-—AURIURING-——-POSTITVE SUPPORTIVE _-SENSITIVE---- DOMINANT-—---NEGATIVE-----CONTROLLING— MANTPULATIVE——-DEPENDENT-——SUBSTANCE ABUSE————_-——--------->ENVIRONMENTAL/GENERA TIONAL PACTORS: meetesesesenmnnsncnens DESCAMTION OF RELATIONSHIP: CLOSE——VERY CLOSE-—STRAINED DISTANT. xo EXISTENTS> - seosatna SIBLINGS - = imei dealieanaiiaii . egass Ve Boss _ eK Co GBROTHERS Sar ns SISTERS & 2D Neo sch-cigensepmsentnccenmnanaseneendsesane Single (Married/de facto/Separated/Divorced/Chifdren RELATIONSHIP: VERY CLOSE ---- CLOSE -------DISTANT——NON EXISTENT——-——DESCRIPTION OF FAMILY RELATIONSHIP: VERY CLOSE -—--CLOSE —-—-—-DISTANT--GIUFFRE005434 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page592 of 883 CHILDAOOD/ADOLESCENT HISTORY | ads DESCRIPTION OF SELF AS A CHILID BRIGHT----HAPPY—-OUTGOING—-LEADER—}- . talar Bineaecsfopermines: AR CRD.E). COMPLIANT. ——LONER—UNILAPPY—HIGH ACHIEVER—-TROUBLED————-———— DESCRITTION OF SELF AS A TEENAGER: BRICI iT --HAPPY-—OUTGOING—LEADER— COMPLIANT——LONER-----UNHAPPY----HIGH ACIIIEVER -— | ROUBLED-——__—_———— RELATIONSHIP WITH PEERS) EACHERS ———-2-—— oo EDUCATIONAL HISTORY Schcol leaving year a HSC Tertiary studissTJnivernity { - Y ViMOSPAR. 2 oc. scesvcses see seoeeceee sar teesee nee peesseenenasassaeneanaen orecemenes EMPLOYMENT I > Present position —_ 7 | Company _ Length of time es ames Reagan eam Ss see rs Fre va Ssh : el —— == _————_—_—_—_—_——— MEDICAL & PSYCHOLOGICAL HISTORY (ADULT) ' + Ai: ‘ . Na on " Significant Uinessesoperations'treatment : wih Wh No a ey PRESENT GENERAL HEALTH _ Coxon -\ MEDICATION Substance abuse: Alcohol fac. ¢49 Nicotine - __ Other drug taking wy Vis PREGNANCY HISTORY: Number of orepnancies 17) + /-* 4 ofA V a . - sais: a, as 4‘ Miscarriaces titer >. u | 1 an vai a N ' AN, % Tecininations See eae eee ee (Effect! reasonable! bad/still affected by decision) ANXIETIESICONCERNS/FEARS _ GIUFFRE005435 CONFIDENTIAL

The text on this page is estimated to be only 47.00% accurate

Case 18-2868, Document 283, 08/09/2019, 2628241, Page593 of 883 PHOBLAS = eee eee DESCRIPTION OF PRESENT PROBLEM a aera a "* TIME OF ONSET/SYMFTOMS __ a= a SLEEM PATTERNS: Good/fally asleco easily’ ressonable’pogr/dilficulty staying aslecp! Awakens through aight! unable to wo tack to sleep AWAKENS FEELING: Gooudltired/down/ Morning perso” Night person Awareness of mental diserdes in family unis/orivin _ ema MEMORY: Goed/reasenable‘geor — = ia SUICTOAL THOUGHTS; Thoughts only/senouscomemplation Altte:npts and manner Intervention : EPILEPSY - YES/NO 22 apace RELAXATION/INTERESTS (Hobbies recreational interests) Waikingccokingythearre’ music'cinemia/sportbush walking/ecallwoedwork Siar with oz = pariner 2 Ls = = > al - = . % : = | —:) S; we | oe” = . 7 -— ' 4 ‘ Pieces Seles rete ON) = = . ———— ———— / i SS a Tose af life a 1. > t4- 4, 4 a ¢ _ = . ‘om, ‘ = C . = ee sas ——— ei — =, = “s, i. Ne ee + \ ee oy oe 4 1. s Lin i x ‘oy 1 Ye ES - FO = = —+ ———<—<—— ~~ (C_ess.,/ oe ee eee sell'Ks.-nan-j-c Jw. Pan eoet oo uremel J ciminished in - roe feclaming in. dvsiues Acknowledged — vaiidatioa— recognition - —ws. — nce - sif.) EYPNOSIS SUGGESTED ooo... ccc. .Expianation'deseription of Hypnosis/Pamphiet ........... HYPNOTIC FORMAT: ,..... Relaxation response/counting 1-20/Tdeomotor/eye catelepsy/ HOW RECEPTIVE 1 23456789 10 APPROPRIATE FOR FUTURE WORK TREATMENT PLAN/POCUS: * & S ae 4 *: te + . ws Y. 3 Sigsies __ ' iL’ AD * Poe ' *, 7 fh . te . . i a id %, hy, ae at WA, é i 1 GIUFFRE005436 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page594 of 883 ai \ . i ‘Ss wowed APhASe A rn ROOD 1 . GIUFFRE005437 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page595 of 883 —_=—.. i ma / yl a, 7 * z= a a a 6 tS GIUFFRE005438 CONFIDENTIAL

EXHIBIT 39 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page597 of 883 7 ame:- 8:47:53 . Incident Report - te: 7/25/06 PALM BEACH ‘POLICE DEPARTMENT Page: ees 1z, —— or ooo eer ee eee Ow wee e eZ ee eT ee wee eee Mee Pe eS een ee Hee ee ewe ee oe oo —_— — ee ee me te Case No. . . SPECIAL NOTES Occur To Date Day Of Week eee City = «. < Location Type : DO NOT RELEASE 1-05-000368 Occur From Date: 1/27/05 0000 Report Date >: Thursday, 358 EL BRILLO WY : PALM BEACH, FL : RESIDENCE-SINGLE FAMILY Beat Assignment: Dept Class Case Status Supervisory Dt.: Map Reference =: Report Officer DETECTIVE BUREAU SEXUAL BATTERY : OPEN / ACTIVE © Case Status Dt : TRYLCH, JEFFREY 3/14/05 Entry Date : OREGERO, LAURA 4/06/05 Names? Property? .. 3 Vehicles? Offenses? . : Narrative? Related Cases? KEKKKEKAKE VY E HI CLE INFORMATION # Case number 1-05-000368 Category... State Veh TYPE SOME a « « w #63 Model ... : Make .. Model Name Style .. Color - Bottom VIN . . Disposition insured by . . Vehicle locked Date recovered Street number Clty. Recovery code Be On Look Out?: Permit Number Color - Top License #Stolen value Insured Keys in car Lein holder 0/00/00 Recovery value : NCIC number tkkkkKKKE DER SON REPORTING INF o Case Number Street Number City = Birth Date/Age Jccupation Home Phone No. BEM « + Weight 1-05-000368 Name .. Employer? ee Oper Lic No. . : ae Race. ....:3: ;: Female Height .. 0 Other Phone ‘Nbr: kkk kKKKKKKEKEKE SU SPECT/ARRESTEE INFO ~ase Number Street Number city. . Birth Date Employer? Sper Lic No. Sex ° ° Minimum Weight . R | : ome Phone No. other Phone Nbr: 1-05-000368 Prompt valid in: OYAL PALM BEACH, FL 334121460 Maximum Age . : Occupation .. : Race : Female Minimum Height : 0 Maximum Height : 1/27/05 0000 3/14/05 1600 10 PAGAN, MICHELE 3/14/05 0 L FERRER KEKKEEKKEKEKEEKEKKEKE - # lL RKKKKKKEKEK White 0 RMATION- ¢€1 ** ROBSON, HALEY 18 White GIUFFRE005614 CONFIDENTIAL eee

Case 18-2868, Document 283, 08/09/2019, 2628241, Page598 of 883 re Oe EO Er a eT EE ll a a a a Errata eres eee ee ——— ee eee 8:47:53 Case No. Maximum Weight Aliases? ; Hair Color . Hair Style . Glasses Facial Hair Teeth Hat ‘ Shirt Shoes. Body Marks #2 Body Marks #4 Arrest Case No.: KEKKKEKKKKEREE SUS PECT/ARRESTEE Case Number Street Number CLEY « « Birth Date Employer? Oper Lic No. Other Phone Nbr: Sex 2 8 ; Minimum Weight Maximum Weight Aliases? .. Hair Color . Hair Style . Glasses ... Facial Hair . Teeth Hat : «ae = Sait * « « « = Shoes. Body Marks #2 Body Marks #4 Arrest Case No. KkkkkRKREKKKKEEE Case Number Street Number C1e¢. . ; Birth Date Employer? Oper Lic No. PALM BEACH POLICE DEPARTMENT Incident Report 7 —_—orrrrr rr reer eee ae re er re ee ee eee ere oe er eer rrr er ee ee ew ewe Se Ke ew ew eK SC ew EK Ke eK KF Be ew ew eS we ee ee ew ew ww we ee eee ee oe 1-05-000368 0 : 1-05-000368 358 EL BRILLO WY Misc. ID# .. MO/Crime Spec? Hair Length Eye Color Complexion Butla’ = « « « * Speech ....: Coat ....«a8 Pants. Body Marks #1 Body Marks #3 Status Additional UCR? : Prompt valid in: : PALM BEACH, FL 000033480 es Maximum Age ° +. oe ee « ee aa ee es * *e se se t* es tf ee ee se Other Phone Nbr: : Male Sex .... Minimum Weight Maximum Weight Aliases? . Hair Color. . Hair Style 561/000-0000 Female 0 0 USPECT/ARRESTEBRE 1-05-000368 358 EL BRILLO WY Occupation Home Phone No. Race .. Minimum Height Maximum Height Misc. ID# .. MO/Crime Spec? Hair Length Eye Color Complexion. . Buil@ .» . «x Speech ... te a a. Be Pants . - Body Marks #1 Body Marks #3 Status Additional UCR? : INFO Prompt valid in: PALM BEACH, FL 000033480 0 0 Maximum Age Occupation Home Phone No. Race . Minimum Height Maximum Height Misc. ID# .., MO/Crime Spec? Hair Length Eye Color INFO : White Page: Program: CMS3 ot (Continued) STILL SUSPECT RMATION - #2 *¥* KSBLLEN, SARAH LYNNELLE 25 PERSONAL ASST/EPSTEIN 561/000-0000 0 0 STILL SUSPECT # 3 ** i RMATION EPSTEIN, JEFFREY | 7 52 | : White | 0 0 GIUFFRE005615 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page599 of 883 . — eee ee ee eee ee et _—-—— | ee eee ee ee ee ee —— eS ewe eS OS Se ee ee ee ee ee ee ts es ee ee i ee _— — ‘Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 3 Time: 8:47:53 Incident Report: Program: CMS301L Case No. 1-05-000368 (Continued) Glasses ; Complexion Facial Hair . Build Teeth. .... 3: Speech Fac «© © «@ © a 8 Coat Shirt ; Pants .. Shoes Body. Marks #1 Body Marks £2 : Body Marks #3 : : Status ... . : STILL SUSPECT Body Marks #4 Arrest Case No.: Additional UCR?: kKkkk&kkkkkkkekke Y TCTIM INFORMATION = #£ lL KEXRKEKEKEKEEKKKEREES Case Number .: 1-05-000368 Prompt valid in: Street Number City. . : Birth Date/Age Employer? ; Occupation . . : STUDENT Oper Lic No. . : Home Phone No. Race... .. : White Sex .... . : Female Height ....: 0 Weight... . 0 Misc. ID# ..=: Be On Look Sut? : Other Phone Nbr: Victim Type . : JUVENILE Residency Type Residency Sts File Charges Can Identify Victim Sobriety: Injury Extent : Injury Type 1 : Injury Type 2 Hospital ID . Med Treatment Phys First Name: Phys Last Name kkKKEKKKEKKEKE VICTIM INFORMATION = # Q ¥EXRKEKERKHERKKEKREKRKE Case Number . : 1-05-000368 Prompt valid in: pO Street Number CLEy:,- . . : PALM BEACH, FL 000033480 Birth Date/Age : NM 1° Employer? . . Cecupaticn «.. Oper Lic No... Home Phone No. : 561/000-0000 Race... . . : White Sex .... . 3, Female Height ....: 0 Weight ... : O° Misc. ID# ..: Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . : ADULT Residency Type Residency Sts File Charges . Can Identify .: Victim Sobriety: Injury Extent : Injury Type 1 Injury Type 2 Hospital ID Med Treatment Phys First Name: Phys Last Name Kk KKKKkKKkKKKKKE VY T CTIM INFORMATION = KREKEKKKKKKEEEKEKEK + Case Number. 1-05-000368 Prompt valid i —, Street Number : , FL 000033480 — : eae: Employer? City .. Birth Date/Age GIUFFRE005616 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page600 of 883 _—-—=— See ee eee ee eS me ee ee eee mene ee ee ee es ee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 4 Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 | (Continued) Occupation... : Oper Lic No. . : Home Phone No. : 561/000-0000 Race... . . : White Sex .. .. .- : Female Height ....: 0 Weight... : 0 Misc. ID# ..: Be On Look Out? : Other Phone Nbr: 561/000-0000 Victim Type . : JUVENILE Residency Type Residency Sts: File Charges Can Identify . : Victim Sobriety: Injury Extent : Injury Type 1 Injury Type 2 : Hospital ID Med Treatment : Phys First Name: Phys Last Name : REEKKKEKKEEKEEKE YT CT IM I NP OR MATION - + A REKRKKKKKHKKRKKKEKKKEKEK Case Number. : 1-05-000368 Prompt valid in: Street Number =:. CLC «3 : PALM BEACH, FL 000033480 Birth Date/Age : 7 Employer? ..: Occupation » 3 Oper Lic No. . : Home Phone No. : 561/000-0000 Race ..... : White Sex ..... . : Female Height ....+: 9 Weight... 0 Misc. ID# . : Be On Look Out? : . Other Phone Nbr: 561/000-0000 Victim Type . : JUVENILE Residency Type : Residency Sts: File Charges . : Can Identify . : Victim Sobriety: Injury Extent : Injury Type 1 Injury Type 2 : Hospital ID Med Treatment =: Phys First Name: Phys Last Name RREKKKKKKKKEKK VY T CT IM INFORMATION Case Number . : 1-05-000368 Prompt valid in: Street Number =: City .. : , FL 000033480 Birth Date/Age : 18 Employer? . : Oper Lic No. Occupation. . KEKKKEKKEKKKKKKKEREKKEK Home Phone No. : 561/000-0000 Race ... . . : White Sex ....- . : Female Height :« «ue 2D | Weight ....: 0 Misc. ID# . Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . : ADULT Residency Type : Residency Sts: File Charges Can Identify : Victim Sobriety: Injury Extent : injury Type 1 Injury Type 2 : Hospital ID Med Treatment =: Phys First Name: Phys Last Name KEKKKKAKKEEKKER VY TCT IM INFORMA TION -— # 6 BEKKERHAKEKEEKEAKKE Case Number. : 1-05-000368 Prompt valid in: GIUFFRE005617 CONFIDENTIAL Bee oy rE ETER ¢ EE ence mete ttl thr th ————— te i ee a ee en, ee <a ee FL A a LN ee pe gk eee fee

Case 18-2868, Document 283, 08/09/2019, 2628241, Page601 of 883 "ewe ewe ew eee ewe ere ere ee were Vr Se Se TFT VBS ST TW Fe egw BMF ew ewe eee wee ee ee SB eee eww ee | ww ew ew ee oe oe ow oe -—-— «=. Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: Time: 8:47:53 Incident Report Program: cms3011, Case No. .. . : 1-05-000368 (Continued) Street Number City . . + PALM BEACH, FL 000033480 Birth ‘Date/Age : | 16 Employer? Occupation. . : Oper Lic No. Home Phone No. : 561/000-0000 Race .... . : White Sex .. .. . : Female Height ....: 0 Weight . i: .: 0 Misc. ID# .. : Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . : JUVENILE Residency Type . Residency Sts =: File Charges Can Identify. : Victim Sobriety: Injury Extent : Injury Type l : Injury Type 2 : Hospital ID Med Treatment =: Phys First Name: Phys Last Name kkkkaKKKKEEKKEKE VY T CT IM INFORMATION Case Number. : 1-05-000368 Prompt valid in: Street Number ALM BEACH, FL 000033480 Cle... - 3; B Birth Date/Age : NN: 7 Employer? 1 ao ll Occupation. . : Oper Lic No. Home Phone No. : 561/000-0000 Race ... . ..: White Sex .... .- : Female Height ....: 0 Weight .. 0 Misc. ID# ..: Be On Look out?: Other Phone Nbr: 561/000-0000 Victim Type . : JUVENILE Residency Type Residency Sts : File Charges Can Identify . : Victim Sobriety: Injury Extent =: Injury Type 1 Injury Type 2 : Hospital ID Med Treatment : Phys First Name: Phys Last Name KAKRKEKKHKEKKEKE VICTIM INPORMATI.ION - GS KKKKKKKKKKKK RK KKK Case Number . : 1-05-000368 Prompt valid i ——— street Number aity . : FL 000033480 3irth Date/Age : 6 Employer? Jecupation ..: Oper Lic No. iome Phone No. : 561/000-0000 Race .... . : White sex . ... . : Female Height ....: 0 ljeight .. 0 Misc. ID# ..>: 3e On Look Out? : Other Phone Nbr: 561/000-0000 fictim Type . : JUVENILE Residency Type ‘esidency Sts : File Charges ‘an Identify . : Victim Sobriety: nhjury Extent : Injury Type 1 njury Type 2 : Hospital ID ed Treatment : Phys First Name: hys Last Name KRKEEKKKAREKREEEK YT EY. = M I NFO RMA TION - + Q BREE KRKKREEKKKERKEKEKEKE GIUFFRE005618 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page602 of 883 ee eee eee ee we ee ese eee eee eee ee ee ee ee = oo = Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 6 Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 ! Case Number . : 1-05-000368 Prompt valid in: Street Number. : City .. : PALM BEACH, FL 000033480 Birth Date/Age : 7 Employer? Occupation .. : Oper Lic No. ., Home Phone No. : 561/000-0000 Race .. . . : White Sex .... . : Female Height 0 Weight... .: 0 Misc. ID# .. Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . : JUVENILE Residency Type Residency Sts : File Charges .. | Can Identify . : Victim Sobriety: | Injury Extent : Injury Type 1 : Injury Type 2 : Hospital ID . : Med Treatment =: Phys First Name: Phys Last Name KHKKEKEEKREKKEE VY T CTIM I NFOR MATION on # LO FXRKEKKKKKKRKEKEKKEE Case Number... _: .1-05-000368 Prompt valid in: Street Number =: City... . . : PALM BEACH, FL 000033480 | Birth Date/Age : a7 Employer? .. : | Occupation. . : Oper Lic No. . : Home Phone No. : 561/000-0000 Race .... .: White Sex .... . : Female Height ....: 0 | Weight... : O Misc. ID ‘ Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . : JUVENILE Residency Type : Residency Sts =: ! . File Charges .: Can Identify . : Victim Sobriety: Injury Extent. : Injury Type l Injury Type 2 : Hospital ID Med Treatment =: Phys First Name: Phys Last Name : KEKEAKKEEKEAEEEEK VT CT ITM INFORM A TI ON - # LL EX KKREKKEKEKREKEE KEKE Case Number. : 1-05-000368 Prompt valid in: Street Number =: Cley . : » FL 000033480 Birth Date/Age a: Employer? .. : 7 Occupation . . : Oper Lic No. . : Home Phone No. : 561/000-0000 Race... . . : White | Sex ... . +. : Female Height : 6 Watght . » « = # 0 . Mise. ID# . : Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . : ADULT Residency Type Residency Sts: . File Charges . : Can Identify . : Victim Sobriety: Injury Extent : Injury Type 1 Injury Type 2 : Hospital ID .: Med Treatment =: Phys First Name: GIUFFRE005619 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page603 of 883 inn rr te i ee ee et et eee PALM BEACH POLICE DEPARTMENT incident Report Page: 7 Program: CMS301L —— ee eee eee ie eee hn ee — See ee et eee ee Date: 7/25/06 Time: 8:47:53 Case No... Phys Last Name Kk KKK KKK Y Case Number Street Number C2EF + a 2 Birth Date/Age Occupation. . Home Phone No. BQX . « «- » Weight ... . Be On Look Out? : Victim Type .~— Residency Sts =: Can Identify . : Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : KREKKEEREKRKERER VY Case Number Street Number : City. . Birth Date/Age Occupation . Home Phone No. BGM . « 2 « Weight .... Be On Look Gute: Victim Type .: Residency Sts : Can Identify Injury Extent : Injury Type 2 Med Treatment : Phys Last Name . se *. ** KKKKKKKKKEKKEKKEK VY Case Number Street Number Cru 4 -« Birth Date /Age Occupation Home Phone No. : Pom « « « * =» & Weight... . Be On Look out?: Victim Type. : Residency Sts : Can Identify : Injury Extent -1-05-000368 Lon 2 & 1-05-000368 PALM BEACH, FL 000033480 18 Employer? Oper Lic No. 561/000-0000 Race ...%. Female Height sek « & O 0 Misc. ID# . Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 Hospital ID Phys First Name: ADULT INFORMATION Prompt valid in: PALM BEACH, FL 000033480 16 Employer? Oper Lic No. 561/000-0000 Race .... Female 0 Misc. ID# .. Other Phone Nbr: Residency Type : ‘File Charges . : Victim Sobriety: Injury Type 1 Hospital ID . : Phys First Name: JUVENILE INFORMATION Prompt valid in: Ltt 2S 1-05-000368 nie: FL 000033480 16 Employer? Oper Lic No. 561/000-0000 Race .... Female Height ree wo Oe 0 Misc. ID# ..: Other Phone Nbr: JUVENILE Residency Type File Charges Victim Sobriety: Injury Type 1 : White White Height ....: 0 White (Continued) ITNFORMATION - LQ KEEKKKKKEKKREEKEKEKE Prompt valid in: 561/000-0000 " a 561/000-0000 | 14 KKK KKKAKEEKEEKREREEE | 561/000-0000 GIUFFRE005620 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page604 of 883 osoasvera wee rrr oreo er one erw were oer ororrncrorer- oer ae ean | eS eS a ee ee ee es owe 8 ee ee ee oe oe ee ee Se oe oe ee oe 8 ee we iw ow oe ow wee we ee oe oe Page: 8 Program: CMS301L PALM BEACH POLICE DEPARTMENT Incident Report — eee eee ee ee ee ee ee ee ee ee ee ee =——_— eS See ee ee eet ee eee ee 7 Date: 7/25/06 Time: 8:47:53 Case No. Injury Type ‘2 Med Treatment Phys Last Name RKRRKKEKKEKRAREE Case Number Street Number ob = ‘ Birth Date/Age Occupation. . Home Phone No. Sex : = = « Weight ... Be On Look panes Victim Type . Residency Sts. Can Identify Injury Extent Injury Type 2 Med Treatment Phys Last Name thre kkkkkkkkkk VY Case Number. Street Number Cer es Birth Date/Age Occupation . Home Phone No. Sex . Weight Be On Look Out?: Victim Type .. Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name KKEKRKKRKKREKRERE Case Number . Street Number Clee « s Birth Date/Age Occupation. . Home Phone No. sex . « Weight . VIictT-iIM B . m . V : 1-05-000368 Be On Look Cut? : Victim Type . Residency Sts 1-05-000368 (Continued) Hospital ID . Phys First Name: INFORMATION - # Prompt valid in: / RKKRKKKKKK KKK KKK KEE White 0 1-05-000368 PALM BEACH, FL 000033480 19 Employer? Oper Lic No. . 561/000-0000 Race .....: Female Height .. : 0 Misc. ID# . Other Phone Nbr: Residency Type : File Charges : Victim Sobriety: Injury Type 1 =: Hospital ID .=: Phys First Name: 561/000-0000 ADULT INFORMATION Prompt valid in: LGati a 1-05-000368 - KEKKEKKKKRKKKEKKEKKR KEKE PALM BEACH, FL 000033480 7 Employer? Oper Lic No. RAGG 5. <6. & a « White Female Height ....: 0 0 = Misc. ID# .. .': Other Phone Nbr: 561/000-0000 -Residency Type File Charges Victim Sobriety: Injury Type 1 Hospital ID Phys First Name: 561/000-0000 JUVENILE INFORMATION: Prompt valid in: rcrtil Sa | LT KERR RKKKKKEKRKKKEEKREKE PALM BEACH, FL 000033480 16 Employer? .. : Oper Lic No. : 561/000-0000 Race .... : White Female Height cE - aha = 0 Misc. ID# . : Other Phone Nbr: 561/000-0000 JUVENILE Residency Type File Charges GIUFFRE005621 CONFIDENTIAL A Oe eRe os Semcon werE tA ONS ba deters! OdFem ues ane :deow y-wsinn-tes tones tes eae

Case 18-2868, Document 283, 08/09/2019, 2628241, Page605 of 883 ee em meme em rm eee ee ee ee = <_ — —— Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: S Time: 8:47:53 Incident Report Program: CMS30iL le ceded ee ee ee Case No. 1-05-000368 Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name KKKKKKK*KEK O TT HER PERS OWN Case Number Street Number 1~05-000368 CLEV..« 2 ° Birth Date/Age 14 Occupation STUDENT Home Phone No. SON .« 6 8 el remale Weight .. ; O Other Phone “Nbr: KKKREKEEKE O TT HE R PERSON (Continued) Victim Sobriety: Injury Type 1 : Hospital ID : Phys First Name: INFORMA = kkk kk kk 7 WEST PALM BEACH, FL 33411 Employer? Oper Lic No. : Race .... . : White : O -Height Person Type OTHER PERSON INFORMATION =- # DB ¥¥#¥k&eeee% Case Number 1-05-000368 Last Name . . : MARCINKOVA, NADA | Street Number : 358 EL BRILLO WY City .. , FL 000033480 | Birth Date/Age. ed; . Employer? .. : Occupation Oper Lic No. | Home Phone No. Race .... . : White : Sex .... . : Female Height ... . : 510 Weight ....: 0 Person Type OTHER PERSON | Other Phone Nbr: kkKkkkKEKE OTHER PERSON Case Number 1-05-000368 Street Number INFORMATION - # 3B ¥e#tkKkKKK cast None. . CLeEY . . : ROYAL PALM BEACH, FL 33411 Birth Date/Age FO 35 Employer? Occupation . Oper Lic No. . : | Home Phone No. Race... . . : White | Sex .-..... ¥ Female Height .. .-. : 0 Weight .... 0 Person Type. OTHER PERSON Other Phone Nbr: kkhkkxezeee OT HER PERSON Case Number Street Number yo Birth Date/Age Occupation Home Phone No. Sex .... . : Male Weight... « « = & 4 Other Phone Nbr: 1-05~-000368 a KKKKKKKEK OT HER PERS ON Case Number 1-05-000368 INFORMA ~ kaeKKK KEKE Employer? .. : Oper Lic No. . : Race .... . : White Height ....: 0 Person Type OTHER PERSON | INFORMATION - # 5 thkkeetex | Last Name GIUFFRE005622 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page606 of 883 -_——o—ororr rrr er ee er re ee ee eer er err rr eee eee me ee eee eee ee eee eee ee ee ea a ee _—— Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 10 Time: 8:47:53 Incident Report Program: CMS301L Case No. . : 1-05-000368 (Continued) Street Number cLey : Birth Date/Age : 0/00/0000 0 Employer? Occupation . . : FAMILY THERAPIST Oper Lic No. Home Phone No. : 561/000-0000 Race ..... : White Sex ... . . : Female Height ....: 0 ; Weight . . : O Person Type . : OTHER PERSON Other Phone br: 561/000-0000 ***EMPLOYER INFORMATION*** Case Number. :. 1-05-000368 Employer Name : PBC DIVISON OF YOUTH AFFAIRS Address. ; 4200 N AUSTRALIAN AV City/State/Zip : WEST PALM BEACH, FL 33407 Phone Number . : 561/840-4540 RkkkKKEKE O T HER PERSON INFORMATION -— # 6 ¥e®ekxKEe Case Number. : 1-05-000368 Last Name : Street Number =: CLey. « . : WELLINGTON, FL 33414 Biseh Date/Age : 16 Employer? Occupation . . : STUDENT Oper Lic No. Home Phone No. : Race ... .. : White sex ...- . ?: Male Height ....: 0 WEZGHt.< .« »« +0 Person Type . : OTHER PERSON Other Phone Nbr: ***EMPLOYER INFORMATION*** Case Number . : 1-05-000368 Employer Name : SUMMIT CHRISTIAN SCHOOL Address... : 4900 SUMMIT BV City/State/Zip : WEST PALM BEACH, FL 33415 Phone Number : ERReREEEE O T HE R PERSON INFORMATION <-~--# 7 ¥ke ee KKKX Case Number. : 1-05-000368 Last Name .. : Street Number Cat. « : Birth Date /Age : 0/00/0000 O Employer? . Occupation : Oper Lic No. : Home Phone No. Race .... . : White Sex ....-. . 3: Maie Height ....: 9 Weight .. » 2 Person Type . : OTHER PERSON Other Phone ‘Nbr: kkkkKKERE OTHER PERSON INFORMAT RELKEE HEE Case Number . : 1-05-000368 Last Name .. Street Number cacy. Birth Date/Age Employer? Occupation Oper Lic No. Home Phone No. Race . = «2 Sex ... .. : Female Height ....: 0 GIUFFRE005623 CONFIDENTIAL C008 OS RSE Chek eaten 2h eee eyes Hye oy Phas Ae os, we quedmee —ae vaunted 9 tmap ob Ore eee ae te Aen bes Peps meek Pe Oe RET A 1s ERE ae BSE here eS eee tne “wane wom

Case 18-2868, Document 283, 08/09/2019, 2628241, Page607 of 883 mmm mre mr re ee eee terme eee eee ee _——_— — = a = “—~—— — — ~_—— — —« “~—— — — — «= as > 2 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: La Time: 8:47:53 Incident Report Program: CMS301L Case No. .. 1-05-000368 (Continued) WetGnE «» « « «© § 0 Person Type . : OTHER PERSON Other Phone Nbr: kKkeKKKKKE O THER PERSON INFORMA — & + k* & Case Number. : 1-05-000368 Last Name ..: Street Number CIEY « = *« « ww 8 Birth Date/Age | 16 Employer? .. ¢Occupation ..: Oper Lic No. . Ta Home Phone No. : 561/000-0000 Race ..... 3: ite Sex .. .. «+ : Female ROLGOE « + » « $ 0 Weight .. 0 Person Type . : OTHER PERSON Other Phone Nbr: 561/000-0000 KKKRKKKKKKAKKKKRKKEKKAEREKKKKEK NARR ATIVE # L ERK REKKKRKEKEKEKKEKKRKEKKEK KKK KKK Original Report LO Reported By: PAGAN, MICHELE D. 9/20/05 Entered By.: OREGERO, LAURA D. 9/20/05 On 03/14/2005, I received a call from not wish to identify herself (later identified as She stated that her fourteen year old step daughter (later identified as possibly may have been molested in Palm Beach by a wealthy man. According t , She learned of the possible molestation by a third party. “sne explained that she had received a call from the mother of her stepdaughter's friend. The mother claimed to have overheard a conversation between her daughter and a male friend; they were talking about a. The conversation was about how had met with a 45-year-old man and had sex with him and was paid for it. I advised -.. I would like to meet with her to obtain a more detailed statement and facts. | Stated she did not know what to do and had to discuss the matter with her husband. At this point id not provide me with a call back number or any other information. She stated that she would contact me once she had spoken with her husband and s mother. On 03/14/2005 received a call from Mr. & Mr They stated it was all right tos ix daughter via cell phone (i i. 393 ver mother had been made aware of the case. They agreed to meet me at the police department later this date. came to the Palm Beach Police Department where they advised me that they believed their fourteen year old daughter may have had some type of sexual relationship with an older male who resided in Palm Beach. Neither knew the suspect's name or address. Both stated that their daughter did not talk to them about the incident, nor would she admit to it. es entified his daughter as w/f, DOB resides with her biological mother at ieee eeemeiniaimennadaammtias Gis a twin, On melee 0 Mr. CS «companied by his wite J GIUFFRE005624 CONFIDENTIAL 4 A i ee wee a sow gO + - ’ - ms ——o "+ renee a oe ee Fy OF ES eect cor somes, te 8 an

Date: Time: Case later that night after midnight It was call fron aa i iis she learne was the girl that got into the fight with Case 18-2868, Document 283, 08/09/2019, 2628241, Page608 of 883 re eet re rrr tre re ret rere eye eee Ge eee ee ee ee ee a ee ee 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 12 8:47:53 Incident Report rogram: CMS3 011 No. . . .:: 1-05-000368 (Continued) her sister §MMresides with mr. Both and are school, whicn is an currently attending involuntary admitte facility. ae Ocoye at the facility during the week and comes home on the weekend. ccording to | she was admitted to the school because of disciplinary problems that recently escalated. The facility also coordinates with the families to provide one on one as well as family counseling. aoe, to Mrs. a she believes the incident occurred on aybeb ey. 2005. A friend of 9s, named Haley. picked her up at their housé and left. They believe Haley initiated the relationship with the older gentleman, though they do not have any proof. Haley lives close by with her mother. further explained that was introduced to Haley by a. boy ein.) (goes to plays baseball). Mrs. continued that on Sunday, Haley picked up and drove to Palm Beach where they met the man. Supposedly, the man has a lot of money and often has young girls come over to his house. Haley offers these girls a way to make fast cash. The man starts with a If he likes them, he keeps them around and does more. The ave any information on Haley other than she lives on the last house on right side (north side). aw ! —_ Mrs. talked of a conversation that she had with tne mother | ee a former friend of s. She found it strange that they were no 1tonger friends until she received the call from her mother telling her of the conversation she overheard between nd a boy named 005. told me of an incident that occurred on got into a fight at school ‘ Assistant Principal, found over "$300.00;4 3: purses. gave different explanations for the large sum of money. Initially the school administration thought it was drug related but then dismissed the | claim. Since that day, did not return to school; she ran away Thursday, 02/10th or Friday 02/11 and returned to her mother's house Mrs. The fight was instigated when 9 accused of being a prostitute. ae .. who has legal joint custody of his daughter signed the affidavit of prosecution indicating he prosecute against the inappropriate sexual behavior with his fourteen-year-old daughter. ae - t he had no objections with our agency speaking 3 his daughter. about the incident. Mr. a stated that s mother is aware o gations and also was willing to cooperate. According to Mrs. she does not believe her daughter had any additional contact with the suspect as she was with Mr. GIUFFRE005625 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page609 of 883 i ee eee ee ee eee ee ne eee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 13 Time: 8:47:53 Incident Report Program: CMS301L 1-05-000368 (Continued) Case No. ... : her mother and then placed into iii I contacted the School Board Police whe provided me the information West Palm Beach, Florida. Checking the school board records for there was no | disciplinary record found. I was advised if no disciplinary action | was taken fora fight, such as an expulsion or detention, the incident may not have been recorded. This was at the discretion of the individual school security and principal. 03/15/2005, I called the Palm Beach County Sheriff's Office and left a message for PBSP Sgt. Chris Keen, Child Abuse Unit. went to : he white > 1 en Also present was therapist. During an audiotaped intervj oke with about the allegations that were made. initially denied 7 anything had happened, only admitting to going with Haley (later identified as Haley Robson) to Palm Beach to pick up money Robson was owed. identified Haley Robson as the cousin of her former boyfriend She ultimately admitted to knowing that Robson worked for a wealthy man and possibly did sexual favors for him. She also admitted that Robson had offered her an opportunity to make money . GI § Gentified Robson's boss‘as a. white male naméd "Jeff" who | alin’ Beach (later positively identified as Jeffrey Epstein). , xplained that she was first approached by Robson to go with : f£'s house, when they were at im s house. According to she was not su ‘ot Bet was going on with Robson but 05 On “ST own wwe chy 7 agreed to go with her. boyfriend) gry when | he heard Robson inviting to accompany. believed state es it was to pick up money the man owed Robson. told her that she would pick her up at her house on Sunday. of the exact dates but knew it was a Sunday. —— to a Robson along with an unkn ibly Hispanic female, picked her up at her father's house _ ae her | father that they were going shopping. It was later confirmed by : | hat. Robson picked his daughter up. According to Mr. Robson drove: anpick, up truck: Robson drove 21 ons with the unknown female to Palm Beach. the way there, a conversation occurred between Robson and oe: Robson told MMMMehat if Jeff asked her age, she ‘should: say she was eighteen.’ ‘ ecalled that Jeff's house was on a dead.end street. All three girls walked up a drivewa ast what appeared to be a small guard/security room. recalled a male approaching them asking what they wanted. opson stated they were there to see Jeff. The male allowed them to continue walking up to the house. GIUFFRE005626 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page610 of 883 — ee eee ee eee ee eee eee ees ee ee ese ee ele ee ee ee en Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 14 Time: 8:47:53 Incident Report Program: CMS301L Case No... . : 1-05-000368 (Continued) stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly after, Epstein and 4 woman, described as white: with. blond. hair entered en. jelieved: the woman was “Epstein's:AssiStant:. added that the woman did not seem friendly and ke a responses short and direct. Epstein introduced himself to Jeff. ot the impression that Epstein and Robson's rriend knew each other. lescribed Epstein as being. approximately forty-five: years” old;*“a*Iong “face? and bushy eyébrows, with graying hair. Robson and Epstein left the kitchen leaving QM and Robson's friend alone in the kitchen. They returned a short time hey all spoke briefly in the kitchen. While speaking to me, | became upset and started to cry. stated the woman instructed her to follow her upstairs, which she did. According to the woman led her to a room that had a massage table in it. ‘The woman started to fix up the room, putting the covers on the table and taking lotions out. She then told — ae Epstein would be up in a second. left the ee and soon after, Epstein walked in and told to take o lothes. As an. telling me what had happened, she Teekae away from me,- and with a pointed finger, repeatedly pressed it into her thigh. ed he was stern when he told her to take off her clothes. said she did not know what to do as she was the only one there. rook off her shirt leaving her bra in, dressed in a. towe O er t take off everything. tated she remove er pants leaving her thong panties on. Epstein then instructed her to give him a massage pointing to a speci ion for her to use. Epstein laid on the table, face down. As © give Epstein the massage, he told her to get on bis back, ee she straddled herself on Epstein's back. ated he DOS S were touching pstein s bare buttocks... As was giving Epstein the massage, e turned around, and wacked of later explained that wacking off was masturbating). stated she was di y Epstein's actions but did not say anything. According :< ll Epstein told her that =. "had a really hot body." Epstein excuse himself and went to athroom where she be asturbated again. Epstein pecacnes to the room and told ie he was done and gave her three hundred dollars. They went back down stairs where they met Robson. Epstein said good-bye and they left. Robson how. did it go and asked what did she a <-. asked old Robson that ae asked for a massage, Robson When stated "I know." | stated they then went shopping. eS Robson also got paid, but that she did not know why since she was confident that Robson did not do anything. Spee coscribed Epstein's house as a two story pink house with a Cadillac Escalade parked in the driveway. There were gates leading into the property. From the kitchen, ecalled walking up a flight of stairs, lined with photographs, to a room. Upon entering GIUFFRE005627 CONFIDENTIAL ee ES ee wet ee ys vy ee ee - = =0

Case 18-2868, Document 283, 08/09/2019, 2628241, Page611 of 883 NS ee ee eee ee ee ee, ee ee ee emcee eee eee ese Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: a5 4 Time: 8:47:53 Incident Report Program: CMS301L | _—_— ee mm em me me ee mee ee ee ee Case No. .. . : 1-05-000368 Continued) ! the room there was a large bathroom to the right. ee a : hot pink and green sofa in the room. There was a door on each side of | the sofa. Neo iad there being a mural of a naked woman. in the room, as well as several photographs of naked women on a shelf. eee states Epstein did not change in front of her but did take ° is towel, exposing himself. — ee Epstein being hairy especially on his chest in also had a hairline that continued to his buttocks. admitted to seeing his penis. [I aske if she knew what being circumcised meant and she stated no. then said that she thought Epstein was on steroids because he was a "really built guy and his wee wee was very tiny." would explain that when she stated "wee wee" she meant pénis. stated Epstein exposed himself when he took his towel off, placing it on the floor as he laid down on the table. ! Po said Epstein was specific in his i to her on how to massage, telling her to go clockwise, -etc. recalled that Epstein got up from the table and went to the Datnroom where she heard him making, what she believed to be sexual type of noises. (moaning) He then returned to the room where he again laid down on the table. Epstein then turned over and inetictes cc massage his boobs. As she did this, Epstein continued to make moaning noises. resumed massaging his chest area. [RMMvas now standing on the ground. Epstein turned to his side, and with the towel on the | ground started to rub his penis in an up and down motion. | stated Epstein held on to the a - back as she massaged his | chest, back and shoulder area. recalled Epstein ejaculating 7 because he had to use the towel to wipe himself as he got off the table. [BBBMMalso recalled Epstein having a noticeable freckle on his chest. Epstein then left the room and ae ..: dressed. She went back downstairs where she met Haley and: the unknown white female. admitted to getting paid three liars in cash from Before they left, Epstein asked to leave her phone number. As they were leaving the ho asked what had happened and how much she was paid. | aes Haley seemed upset or jealous when she told her that she received three hundred dollars. Haley stated received only two hundred dollars that day. stated that she believed Haley was paid two hundred dollars for bringing her. —a lle Ole Robson told that if they do this every Saturday, they could be rich; agreed. They then went shoppi h she is not sure where. Possibly at TJ Maxx or Marshall's. ‘res she ! never saw Robson again as she got into a fight at school. She had not spoken with Robson either as her mother took away her cell phone. if she was aware of any video equipment while she was She stated no. I asked in the room. GIUFFRE005628 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page612 of 883 re me ee me mee ey a me em tee me eee eee —_——_— oy —Date: 7/25/06 PALM BEACH POLICE DEPARTMENT | Page: 16 Time: 8:47:53 Incident Report Program: CMS3 011 Case No. .. . : 1-05-000368 : (Continued) stated she was afraid that Robson would retaliate against her or her family if she ever went to the police regarding the incident. stated that her father's vehicle was recently vandalized. admitted to tellin what had happened with Epstein. According to became angry t, punching a hole in the wall. guessed that it was ho told ana now there were rumors in school about and what she did with Epstein. | about the incident, I then talked to po Sl lying. We talked about the color sweater she was wearing. denied having sexual intercourse with Epstein. She denied touching his penis. [yy again admitted to observing Epstein masturbate. | — a a -:--<< to cooperating with the police department in p phone call to Robson in a controlled setting Ms. willingness to cooperate with this investigation. Copies of this and advised her of the families' as well as 's interview were placed into evidence. I made contact with mother of I advised her briefly of my investigation. She was aware of the incident and stated that she overheard a portion of that her daughter was having with a boy named that it was her opinion that both girls liked recalled hearing her daughter calling a whore. admitted that she did not listen to the entire conversation but did confront her daughter about it later. told her mother that something to the effect that had slept with an older man for money. a state e would not object to me speaking with her daughter. It was s belief that everyone in the school have aaa this because of the fight that her daughter and had gotten into. I reminded MMMM that this was an ongoing investigation and requested she not discuss the fact that I had contacted her. She agreed. ion stated On 03/16/2005, PBSO Sgt. Chris Keen left a message that he was returning my call. I spoke with Keen and discussed the case with him and inquired if he had any open allegations or cases. where the suspect resided in Palm Beach. Keen stated he was unaware of any. Keen offered any assistance if needed. Keen stated it was his experience that due to the age of the parties involved, it would be difficult to interview them and: expect the investigation to remain confidential. Because of the time delay, there was no need for the victim to be taken to a medical facility for a physical for the purpose of obtaining evidence. There was also no need to take her to CPT as she was already in a juvenile facility, with an assigned therapist, in ~ which coordinating a day and time to obtain a statement could be made. On 03/17/2005, I queried Jeffery Epstein on the internet and obtained GIUFFRE005629 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page613 of 883 i ie i a ee ee ee ee a ee eee ee ee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 17 Time: 8:47:53 Incident Report Program: CMS301L Case No... . 1-05-000368 . (Continued) a photo of Epstein to be used in a photo line up. I met with at which time she viewed the photo line up. She i lately recognized Epstein and pointed to him (Position #5). mu = -5 the photo line up under Epstein's picture. This signed line up was placed into evidence. or the purpose of On 03/18/2005, I met with ae... her regi placing a controlled call to Haley Robson. spoke with Robson and asked if she could arrange another meeting with.Jeff. Robson stated that she would have to-call him and make the arrangements. A copy of this conversation was placed into evidence. and rege acee and was left the state to visit wit er aunt and 1s scheduled to return to Florida on 03/27/2005 03/19/2005, I spoke with advised that uncle. 03/21/2005, I coordinated with PB BSF Unit and OCVAN to initiate surveillance on 358 El Brillo. 03/21/2005, Coordinated with Det. Lee regarding trash pulls from 358 El Brillo. On this same date I —— schedule an appointment to speak with . She stated the school guidance counselor was reluctant to have police presence at the school. I assured her that I would respond to the school in civilian clothes and an unmarked vehicle. I c2..ed me back and advised that I did not need to make an appointment to see ived a return phone call from ES t I cui be attending the family therapy sessions with I received messages from i. I conducted a computer query on Epstein. The results of this query indicated the most recent driver's license on file for Epstein was for the state of Florida, which had expired. A cross reference of Epstein s residence, 358 El Brillo, Palm Beach, revealed the following affiliated names: Nada Marcinkova, w/f, dob a Mark L. Epstein, w/m dob & Ghislaine N. Maxwell, uk/f, dob MM. A computer query for both returned no history. On 03/23/2005, I spoke with MM c11 phone wk T requested _ that she not discuss the incident with anyone including her daughter as I did not want the investigation compromised. I was told at this time, _that 9 and have not been getting along due to the fact that GE 2: decided to continue living with her father. On 29/2005, I placed telephone calls to both the and residences requesting to speak with them regarding the GIUFFRE005630 CONFIDENTIAL - re ede Sees webet f Aen es. bee al << reer nr Wet i ee

Case 18-2868, Document 283, 08/09/2019, 2628241, Page614 of 883 ee ee ene meee eee eee ee ee ee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 18 Time: 8:47:53 | Incident Report Program: CMS3011L Case No. .. . : 1-05-000368 Continued) investigation. I received return phone calls from Mrs. Mrs. and advised them that I would be contacting , | s family therapist to coordinate a time to meet with This Was at the request of: both —and Mrs. s strict classroom and therapy schedule be disrupted as little as possible. [I = updated them to the investigation thus far. Both. and MEEEINSt ated — had no objection to my meeting with | In i eaking with : she identified the cell phone number of a e phone assigned to yy os. had no ebjacti oe and provided consent to giving it to the polis department for the use of placing controlled phone calls from stated the phone had been taken away from Pe part = her punishment for not doing well in school. According to a MMMsed to be an excellent student, but in the past two months has become irritable, verbally abusive to the family and has ' cent behavior is the stated they are going tated her dauc run away. opposite o a €¢ normally is. through family therapy sessions with the school but none of this had come up. Arrangements were made for Det. Captain Gudger to retrieve the cell phone from at her place of employment. I co ed i a =: requested to speak with Ms. Upon speaking with Ms. she advised me that she was in the middle of therapy sessions and would call me back once the sessions were completed. Ms. §MMstated the sessions should be concluded by 7:00 PM. At approximately 8:00PM I had called Ms. at which time I left a message on her voice mail requesting a return phone call. I spoke with Ms. and advised her that I did not meet with her daughter and tha wou. again attempt to coordinate a time with the counselor so as not to disrupt {Mb school s had no objections meer’ after speaking with vs. lino z e da call from Ms. I explained the situation requested a time to meet with GE reviewed advised that Gould be available after 3:00PM. I met with » a: I reminded of her conversation with Robson. During this time initiated a conversation with me in which she admitted that she was not telling me everything that ed during the time she was alone with Epstein. According to while she and Epstein were alone ‘on the secon pstein used a purple vibrator to massage her vaginal area. il: there was n ation as the vibrator was on top o er underwear. I if Epstein ever asked her age and she stated he had. stated she told him she was eighteen. When Epstein asked what school she was in, §MMIresponded she was in the grade at Wellington. During the course of this incident, stated Epstein told her that Haley had worked for him for years. schedule and We then continued with the controlled call to Robson. At approximately 3, from her cell phone, made a call to Robson s home, | . Robson was not home. ee told GIUFFRE005631 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page615 of 883 mee ee ee mmm rm me mm ee eee meee cree mre eee ee ee cs a= a= « Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 19 Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Continued) that Haley rking a double and could be reached on her cell phone, W/F, Haley Robson is employed at The Olive Garden Restaurant, located on Forest Hills Blvd in Wellington. bson. During the conversation between Haley Robson and Robson aske what happened, stating that she had heard rumors that was going to press charges. Robson asked if they, meaning s, knew about Jeffery. Robson claimed t 's father had found out about Jeffrey. told Robson that t parents) did not know anything about Epstein. Robson told| that Epstein needed someone to work tomorrow and asked if she w le. Robson stated she would call Epstein and then call back. During the course of these conversations with she would at times appear to be articulate and well spoken. She would then start to act in an immature manner, by looking around, not paying attention, drawing on a paper. would offer me a high five whenever she claimed to have told me the truth in the details of the afternoon at Epstein's house. ee sit in the chair, with her knees propped up to her chest as she admitted that she did not tell me the all the details of her encounter with Epstein.during our aa mS As a means Of positive reinforcement I would high five On 03/31/2005, subpoen -Mobile Wireless and Cingular Wireless, (Robson and phone numbers) were drafted. On 04/01/2005, I met with members of PB BSF Unit for the purpose of conducting surveillance on 358 El Brillo. Cross-reference supplement. On 04/01/2005, I met with Det. Krauel of the Palm Beach Police Department who provided me a copy of the concealed weapons permit for Mr. Epstein. It revealed Epstein had a valid permit. There was no current photo attached to the renewal notice. On this same date I queried various different web sites for a possible identification of the purple item retrieved from the trash pull from 358 El Brillo. The item was similar in description as the one described by pe and used by Epstein. I made contact with Spicygear.com and spoke with the owner John. I emailed a photograph of the item for his opinion. He identified the items as a Jelly Anal Wand of some sort. The item is easily available at sex shops in South Florida. 04/06/2005, I conducted business queries into Epstein utilizing the internet. I located articles relating to financial reports. There was no local history. On 04/01/2005 - 04/03/2005, with the assistance of BSF, there was GIUFFRE005632 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page616 of 883 re me reer rere te ce Eee te ete acter GRIN emma cee cee ee eee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 20 Time: 8:47:53 Incident Report Program: CMS301L Case No. .-. . : 1-05-000368 (Continued) continued surveillance on the property. il messages, dated 03/31 A female identifying up to take her to A copy of this was of 2 On 04/04/2005, I obtained a co and 04/01 from Haley Robson to herself as Haley states that she could pick Epstein's house for an eleven o clock appointment. placed into evidence. On 04/05/2005, a trash pull was conducted at 358 El Brillo by Det. Lee and me. There were several messages written on various forms of papers. There was a message from Haley, indicating 1:00. The following was additional information obtained from etrieved from 358 El Brillo: Jean Luc_¢:; : Davi llen Friday 5:30PM Haley; a message receipt dated —_ 1:05She is looking to speak to you .; ; On 04/06/2005, If a requests to SA Mighdolls office for ! tein, Robson _ and hone records. a numbers & c On 04/06/2005, I called a MM and spoke with Principal He confirmed that they had a student by the name of He requested a written request prior to releasing any additional information. On this same _date I faxed a requ Por student and parent information on advised that due to this being an open investigation he was not to discuss the matter with anyone. On 04/08/2005, I receiv following information: Parents name: Det. Lee provided me with trash obtained from 358 El Brillo for 04/06 04/07/05. The following information was retrieved: Jet Aviation Sent i nerery, indicating a departure date of 04/05/2005 at 4:00 PM with an arrival in New York City of 6:15PM. Flight crew captain David Rodgers, co-captain, Larry Visoski, flight engineer Larry Morrison. Call sign N908JE; a note stating Bye J. thank you hand written notes & messages 11-Glenn, 12:30 chicken, 3 September B & J, Big Screen x8, work Sunday @ y after school?; left message for ! GE works 4-9 Monday and Tuesday, Leaves school @ here tomorrow @ 10:30 Am; Mrs. Business There was no trash for 04/08/05. ae received the results of a subpoena request from Bellsouth for ‘The results only provided subscriber information. I contacted Alice Grant Investigative Subpoena Compliance Center who Stated the request was not complete and the results would be sent to GIUFFRE005633 CONFIDENTIAL ee en

Case 18-2868, Document 283, 08/09/2019, 2628241, Page617 of 883 rm rm rere cree rr rr a terre eae ee ee eee Se eee eee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: | 21 Time: 8:47:53 Incident Report | onan CMS301L Case No. 1-05-000368 (Continued) me as soon as the query was finished. Cross-referencing the names ae: - : well as phone numbers, which were obt rom message notes via i trash pulls, I identified the before mentioned individuals as being are ac eone at 358 El Brillo. a : ~ ¢ EEE bo: MN O06 F1 bot ove egal age of consent. | On 05/03/2005, I spoke with and updated her on the investigation. tate a was doing well in the school. Her contact witn the outside is Limited as they do not have access to the phones. comes home on the weekends and she is not allowed to go anywhere alone. On 05/11/2005, I made arrangements to meet with nn ond On Thursday, 05/12/05, I spoke with regarding the case. They will be moving to GA in July 2 ey Wi be very busy over | the next few weeks but would be available via phone. Will coordinate a date to meet to discuss the matter further. During this week I conducted surveillance at Epstein s residence and at the airport, but there was nothing to indicate that Epstein was in town. Due to conflicting appointments, rescheduled until 06/02/2005, to meet with Ms. I also spoke with a ana updated her to the investigation. On 06/02/2005, I met ee and that she could be ee ell provide me with her new contact information. I also received a message oe Attempted call back but the line was busy. TE: =< e is ia: to June 14, 2005, I received information that Epstein's plane was at 3 Jet Aviation. I spoke with Det. Lee regarding surveillance. T called the Olive Garden and asked for Haley Robson. I was advised | she was not working today. This would indicate that Robson was still employed there. I faxed subpoena requests to SA Mighdolls office for (Phone numbers . The original billing information. On 07/07/2005, On 07/20/2005, conducted a trash pull arranged by Ofc. Lee. Inside there were misc. papers with phone numbers and names. There were GIUFFRE005634 CONFIDENTIAL

Date: Time: ~—_—— — — Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page618 of 883 rr tm mre me ce ee eet eee ese ees ee = — — oe 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 22 8:47:53 Incident Report Program: CMS301L No. . . . : 1-05-000368 (Continued) misc. female hygiene products in the trash. Based on a prior Auto Track report done on 358 El Brillo, a possible subject residing at the residence is Nada Marcinkova. Marcinkova fit the description provided by officers who had conducted surveillance in the area of a female seen entering and leaving the residence. On 07/21/05, I received the Duces Tecum dated 07/18/05, which was clerked by ASO On 07/26/2005, I received the results of Bell South Subpoena. On 08/04/05, I received DHL Express from T mobile with the results of the query. who confirmed cnt was still living out of state. hat all was going well. I left a message or iii .. On 08/08/2005, I received the results of Cingular cell phone subpoena. During the week of 09/08/2005, I checked 358 El Brillo and the Palm Beach International Airport but there was no direct indication that Epstein was in town. On 09/08/2005, I reviewed the case notes of this file, as the case will be turned over to Det. Recarey. On 09/11/2005, while on patrol, I conducted a check at Epstein's residence and found that it still had the hurricane shutters on. On a drive by the Palm Beach International Airport later that afternoon, I did not observe Epstein's plane. On 09/14/2005, I conducted a check at the Palm Beach International Airport but did not see Epstein s plane. On 09/19/2005, I spoke wi i keep her updated and _to find out if there was any change of address or phone I was told no. I left a message for at in order to provide her with Detective Kecarey s information. KEKKEKEKKKKREREKREEEKKEKEKKEKER NARRATIVE: FD HKKKEKKEKKEKKEKKKKEKKKKKKEES NA Reported By: RECAREY, JOSEPH 9/21/05 Entered By.: ALTOMARO, NICKIE A. 9/21/05 On September 19, 2005, I met with Officer Pagan and received the information pertaining to this case. Members of the Burglary: Strike Force had previously been conducting surveillance on both Epstein and Robson. Officer Munyan was assigned to monitor the Epstein home and Sgt Sorge and Officer Minot were assigned to monitor Robson. Both teams provided a surveillance log that will be placed into the GIUFFRE005635 CONFIDENTIAL Sk et mend ets) md + ae ee ee tte eee eR ee te + oe ’ A od ey ad A ee oy ems sll lh ee emi a eS ————eEeEeEeEE °

‘Date: Time: Case kkRKE NA kk KKK NA Case 18-2868, Document 283, 08/09/2019, 2628241, Page619 of 883 re cre re cee cre cme mee meee se eee eee ee 7/25/06 PALM BEACH POLICE DEPARTMENT . Page: 23 8:47:53 Incident Report | Program: CMS301L No. . . . : 1-05-000368 | . (Continued) attachment file. Det. Dawson was assigned to relieve Officer Munyan at 4:00 pm; he informed me that at approximately 8:00 pm, Epstein had left for the airport and his private jet was sitting on the tarmac. Epstein's. private vehicle drove to the jet and unloaded packages into the jet. It appeared that Epstein left the county at this time. Surveillance will continue to determine when Epstein will return. Inv Continues. KKKKKAKKKKKKKKKKKEKKEER NARRATIV E Ho > KRKKKKEKKKKKKKEKRKKKE KKK Reported By: PARKINSON, GREGORY A. 9/23/05 Entered By.: ALTOMARO, NICKIE A. 9/23/05 On Friday, September 23, 2005 at approximately 1:45 p.m., I began to copy a tape micro cassette, under case number 05-368 and property number 05-243, tape number 1. I placed the tape in the telex copy-et, series 2 machine and began to go through the copying process. Approximately 1/2 through the tape, the tape wrapped around the spindle and became locked and stretched the tape. I examined it and determined that it was in the best interest to leave it as it is as a prior copy had been made and turned over to Sergeant Frick. I immediately took the tape to Sergeant Frick and allowed him to examine it and then obtained the copy from him and Detective Recarey and brought the copy of the tape down and made a copy for him based on that. The tape was placed back in the original container and is retained in the evidence bag under the previously mentioned property number of 05-243. It is not advisable to attempt to copy this tape as further damage could result to the recorded material and there is an existing copy anyway. KEKEKEKEKKEKEKREEERREREKRKEEE NA R R A T IVE # QL KERKKKEKKKEKKKKKKKKKRK RRR KEE Reported By: PARKINSON, GREGORY A. ~ 9/26/05 Entered By.: ALTOMARO, NICKIE A. 9/26/05 On 3-24-05 at 11:00 pm, a copy of tape 2 (case number 05-294) had been made for Det. Pagan by Evidence Specialist Annette Badger. ‘The copy was turned over to Detective Recarey. On Friday, 09-23-05 at approimately 2:15 pm, I was in the process of reproducing audio tapes (micro and standard) to standard size when it was discovered, in the test review process, that tape number 2 was blank. I notified Sgt. Frick and Det. Recarey. I was informed that they had a prior copy and I could use it to make a master tape. I did so and when reviewing and signing the evidence sheet, I noticed Evidence Specialist Badger had written "#2 is blank." I obtained that copy from Det. Recarey and made a new copy on a standard size tape. The new copy was placed in the evidence bag under GIUFFRE005636 CONFIDENTIAL ee ae COU EEE get Steam ee ee be be Se hee eee eet etme gi Ae

Case 18-2868, Document 283, 08/09/2019, 2628241, Page620 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 24 Time: 8:47:53 Incident Report Program: CMS301L Case No. ... : 1-05-000368 (Continued) property number 05-294 with the blank tape. . KKKKEKEKEEEKEEKEKEEREKRREEREEEEEE NA RRA TIVE # 5 HAKKKEKKEKKRKEKEKKKKKKERRKREES NA Reported By: RECAREY, JOSEPH 9/26/05 Entered By.: ALTOMARO, NICKIE A. 9/28/05 Copies of the tapes that were submitted into evidence were requested. Additionally, trash pulls were started on September 21, 2005. Sgt. Szarszewski made telephone contact with Tony Higgins, Supervisor of the Sanitation Department, and requested that trash be’ collected at the Epstein House located at 358 El Brillo in Palm Beach. Sgt Szarszewski met with Sanitation worker, Jeff Williams and observed him enter the property at 358 El Brillo. Shortly thereafter, Williams exited the property and placed the three white trash bags in the empty well in the rear of the truck. Williams then drove away where he met with Sgt. Szarszewski who removed the bags from the well and placed them into one large black trash bag. The bag was returned to the Police’ Station where I, was waiting for him. Upon his arrival, we inspected the bags where several notes and papers were found. These notes contained names oe a with times. Additionally, there was a note from and to Jeffrey Epstein on a notepad, which stated, "For a good time > en ." Also, there was another telephone n er on the note lso found was a written note, which stated, can not come at 7 p.m. tomorrow because of soccer. These items were written on notepads that contain Jeffrey Epstein on the bottom of the notes. These items were. placed into evidence for future follow up. I requested subpoenas for subscribe the and Other notes Pee e telephone numbers listed ona ll The cellular telephones are both assigned to Cingular Cellular Service. were found within the trash on Jeffrey Epstein pad, paper contained telephone numbers. One note had" with written on it. This cellular number _is assigned to Cingular Cellular Service. Amother sheet had written a is assigned to Bell South Telecommunications. The subpoenas were picked up and submitted to Cingular and Bell South Telecommunication for subscriber information. On September 22, 2005, I was informed by Sgt. Szarszewski that there would be no trash pick up as it was recycle pick up day. A request for copies of the micro and standard size cassettes were requested © from crime scene to familiarize myself with the interviews conducted. On September 23, 2005, the tapes were received and I began to become familiar with the interviews that were conducted. Det. Krauel had met with Town of Palm Beach Sanitation worker, Jeff Williams and observed him enter the property of 358 El. Brillo. Shortly thereafter, Williams exited the property and placed the three white trash bags in the empty well in the rear of the truck. Williams then drove away where he met with Det. Krauel who removed the bags from the well and placed them into one large black trash bag. The bag was returned to the Police Station where I was waiting for him. Upon his arrival, we inspected GIUFFRE005637 CONFIDENTIAL ee ete VE Siew chet ge | san db ee ll TR A Rll Qe ete eee ee ES ae ree sabes ~ 1 ue,

Date: Time: Case KKK NA Case 18-2868, Document 283, 08/09/2019, 2628241, Page621 of 883 i re ere i i i i ei ei ee ee a hn a 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 25 8:47:53 Incident Report _ Program: CMS301L No. . . . : 1-05-000368 (Continued) the bags where several notes and papers were found. The notes will be inspected for future use. The items collected were placed into evidence. It became evident that some of the recordings were recorded with background noise and some interference. The calls most affected were the control phone calls from the victim to the suspect Haley Robson. I obtained the graphic equalizer and discovered that the calls are able to be legible with the use of the equalizer by lowering the background noise and increasing voice gain. I also learned that a tape was broken during the coping of the tape. I returned the copy of the tape marked Property Number 05-243 to have it recopied to have an original in evidence and a working copy with the file. — Upon researching the file, it was discovered that the suspect, Haley Robson's cellular -* eS: incorrectly. The suspect telephone number was and the original request was for a I requested the information through Cingular Cellular Service from February 2005 through the present. The purpose was to have a record of Robson making calls to victim, Jeffrey Epstein and the frequency of calls. The request was submitted to the State Attorney's. Office. Investigation Continues.... KKK KKEKKEKEREAEEKEREESE N A RRA 7 7 V E # 6 KEKE KKK KEKE Reported By: KRAUEL, CURTIS D. 10/06/05 Entered By.: ALTOMARO, NICKIE A. 10/06/05 On or about September 23, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. Williams had been previously notified to assist in trash pulls at the residence of Jeffrey Epstein, 358 El Brillo, Palm Beach, Florida. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the back of an empty sanitation truck. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 4 white in color plastic bags and each contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about September 26, 2005 at approximately 0900 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jessie Jones. Jones had been previously notified to assist in trash pulls at the residence of Jeffrey Epstein, 358 El Brillo, Palm Beach, Florida. I observed Jones enter the driveway of 358 El Brillo, where no trash was located within the receptacles. I left the area without incident GIUFFRE005638 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page622 of 883 eee ree eee mee ese yee em ie ime ey gee ee ee ee ae — — — eee eo a oe oe Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 26 Time: 8:47:53 Incident Report Program:. CMS301L Case No. . . : 1-05-000368 . (Continued) and notified Det. Recarey to that affect. On or about September 27, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jesse Jones. I observed Jones enter the driveway of 358 El Brillo and remove one plastic bag of trash and place it in the back of an empty Sanitation truck. “ I then followed Jones to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 1 white in color plastic bag which contained correspondence for 358 El Brillo. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Monday October 3, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the. back of an empty sanitation truck. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 7 white in color plastic bags with a red tie and 1 black in color bag which contained 2 white in color plastic bags with a red tie. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. Inside of one of the white in color bags, I located a broken piece of a hard plastic or clear acrylic stick, which was shaped with small ridges. This device is commonly used as a sexual toy which is inserted into the vagina or anus for stimulation. This item, along with all documents of evidentiary value were removed and turned over to Det. Recarey for Follow-up. On or about Tuesday October 4, 2005 at approximately 0928 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams enter the driveway of 358.El Brillo and remove several plastic bags of trash and place the contents into the side well of the sanitation truck. This side of the truck is separate from the rear of the truck and does not come into contact with other trash. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 2 white in color plastic bags which were tied at the top. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Wednesday October 5, 2005 at approximately 0928 hours, I GIUFFRE005639 CONFIDENTIAL Santee ee ee ee minim nee. Le PO Ne ee ewere Smranbetigeeettat, Abe seen af fiaskeeieet

_—_———— Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page623 of 883 i i i i i i i i eee ee ee ee ee 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 27 8:47:53 Incident Report Program: CMS301L No. . . . : 1-05-000368 (Continued) responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the bed of the sanitation truck. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents, with the assistance of Det. Recarey. There were a total of 2 bags, one of which was white in color and tied in a knot at the top, and the other was a black in color bag, which contained two white in color trash bags along with loose debris. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and. turned over to Det. Recarey for follow-up. KKKKKKKEKKEKKEKAKKRAKHEEEEKKEEEK NARRATIVE HT ERR EK RKREREREKREKE KEKE KEE KEEEKE NA Reported By: RECAREY, JOSEPH 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/07/05 I met with Det. Krauel and requested further assistance to maintain trash collections at Epstein's residence at 358 El Brillo Road. On October 3, 2005, at approximately 10:30 am, I was contacted by Sgt. Frick to respond to the’ Palm Beach Police Station. Det. Krauel had observed Jeff Epstein riding his bicycle on South County Road. Upon my arrival, I met icv ia advised, as Epstein was currently in Town; we interview as to her involvement with Epstein and the girls that are brought to his house. As we were to interview in the county, (outside of our jurisdiction), I contacted the ate torney s Office Investigation Division, and made contact with Assistant Supervisor Investigator Carlos Ortiz. I requested assistance to interview as the interview may occur in the county. Supervisor Ortiz assigned Investigator Mike Waites to assist us at the location and interview of —— Det. Dicks had responded to the address of d viewed her s vehicle a red Plymouth Neon vehicle parked in the driveway. i, TS :: parked in the driveway of Jy n Loxahatchee gt Frick and I responded to 120th Ave and awaited the arrival of Investigator Mike Waites. Upon his arrival, he was briefed that should she wish to be interviewed within her home he would be needed. However, should gree to return to the police station for further questioning, he would not be need . Frick and I knocked on the door and met with =; told that we were investigatin laim involving Jeffrey Epstein of El Brillo in Palm Beach. nil. . asked if she wanted to accompany us back to the police station for further. questioning. She was also told that at the conclusion of the interview she would be returned home. She agreed and wished to change her clothes prior to accompanying us back to the police station. At the conclusion of her changing clothes, she advised she was ready to go. I thanked Inv. Waites and advised she was going to voluntarily return to the police station. GIUFFRE005640 CONFIDENTIAL ae — A ls Wi Pm tet See © eee E es Amen. emmendei>: sib | ees bE Etec pad — mI hEE

Date: Time: —_——_— Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page624 of 883 7/25/06 PALM BEACH POLI CE DEPARTMENT Page: 28 8:47:53 Incident Report Program: CMS301L No. .. . : 1-05-000368 (Continued) Upon ae - entry in the unmarked Detective vehicle, I placed a tape recorder within the vehicle to record any conversations within the vehicle. During the ride back to the police station, dvised she is attending Palm Beach Community College at the Palm Beach Gardens Campus and is majoring in journalism. Upon our arrival at the police station, MM was brou he | interview room in the Detective Bureau. I explained to that I appreciated her willingness to assist us and informed her that should ! she desire to leave at any time she may do so. I further) lained the interview room door is only closed for privacy. tated she understood. During the taped sworn_j Lew, as asked how she came in contact with Epstein. tated back when she turned 17 years of age she was approached a Iriend in the Canopy Beach Resort in Rivera Beach. me «2: aske she wanted to make money. She was told she would have to provide a massage and should make $200.00. thought about the offer and agreed to meet with Jeffrey. Unknown last name) and §§(0nknown last name) picked her up and she was taken to Epstein's house. Upon her arrival | at the house, she was introduced to Epstein in the’ kitchen of the house. She was also.introduced to a white female known to her as Sara. She was led upstairs to the main bedroom known to her as Jeff Epstein s bedroom. Sara arranged the massage table and covered the | table with a sheet. She brought out the massage oils and laid them next to the massage bed. Sara then left the room and informed her Jeff would be in a minute. Jeff entered the bedroom wearing only a tow lay on the table onto his stomach a d massage oil to rub on him. During the massage, stated, He tried SO ee Ne eet eh ge oo ’ - ow cor ile to touch me and I stopped him. I asked how he tried to touch her. He qd iso sta grabbed her buttocks and she felt uncomfortable. Epstein has a vibrator, which is large and white in color. told Epstein, I'll massage you but I don't want to be toucheca. stated she ee naked. At the conclusion of the massage, Epstein paid $200.00 for the massage. He explained, I know you re not comfortable, but I'll u. if you bring some girls, He told her the younger the better. stated she once tried to bring a 23-year-old female and Epstein stated that the female was too cm 6 he asked how many girls she brought in total to Epstein. e six that she can remember. tated she brough and the victim in this case. I asked RR nich one was the youngest. | dvised the victim was the youngest. stated every girl she brought knew what to expect when they arrived. They were told they would provide a 1 massage, possibly naked, and some touching. - I asked her if the victim | Was aware. She stated every girl she brought knew what to expect. She explained she knew the victim wanted to make money. She approached the victim and explained about going to work for Jeff. The GIUFFRE005641 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page625 of 883 mere rm mre ema meee terre etme teem creme eee eee ere ese ces ee es Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: ag Time: 8:47:53 Incident Report Program: CMS301L Case No. ., . : 1-05-000368 , (Continued) victim agreed and arrangements were made to bring the vic | Epstein's house on a w tated that she and (later identified as picked up the victim at the victim s house. They traveled to Epstein's House and entered through the kitchen door. They met with the house chef and Epstein s assistant Sara. The victim was introduced to Epstein while they were in the kitchen area. Sara led the victim upstairs and Epstein went upstairs. When_the massage was over, the victim returned to the kitchen area. tated she was paid $200.00 for bring the victim to Epstein's. stated the victim told her she was paid $300.00 for the massage. Back in the vehicle, §MMMlasked the victim what happened. The victim told her about the massage and then they went shopping. (§M—MJstated the victim was the last person she brought to Epstein. She further stated that she had changed her cellular number to avoid being contacted by Sara. She continued that when Epstein announces to his —. .. that he is traveling to Palm Béach, Sara would contact O arrange girls for Epstein. Sarah, later identified as Sarah Kellen Date of Birth had told i ae Jeff likes to have his fun with the girls. tated that once her parents discovered that she was visiting = E they disapproved of the encounters with him and she stopped. wie fr che: stated that Sara still tries to call the house sae leaves messages. With assistance of we were abl nese meres, ant DOB DOB 987, 1988. aieeces, Sgt Frick entered the room and explained that based on her own statements, she had implicated herself with bringing underage girls to Epstein's house. 2 aware of what she had stated and wished to assist further in hopes to receive a lesser charge. eerarcrt provided cellular telephone numbers for the girls she had mentioned previously.. Additionally, she rovided possible addresses and areas in which they lived. As as being taken home in the vehicle, a tape recorder was placed within the vehicle to record any ations within the vehicle. During the drive back to her home, ade the comment I m like a Heidi Fliess. (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. atchee, Florida in ana speak with We met with Mrs. ens Ee - Mother) at the front door. We explained the ongoing investigation and felt that may have additional information as we had information that she had worked for Jeff. Mrs. GS jt eoduced us to her husband and allowed us en he home We sat _in the dinning room and met eee” 988. As she was under the age of eighteen, Mrs. je we would be speaking with her. She expressed, 1£ her daug she wanted to assist. As we interviewed she denied having any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff s Sgt Frick and I went to GIUFFRE005642 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page626 of 883 ———S— oer oe KF ae Kr eee er ee eS er er er oe ee ee em rm mm cm me meme ee mm mee eee eee es es Date: 7/25/06 PALM BEACH POLICE DEPARTMENT | Page: 30 Time: 8:47:53 Incident Report Program: CMS301L Case No. 1-05~-000368 (Continued) House with Haley Robson approximately eight months ago and sat in the kitchen with the house chef but nothing happened. As the parents were present during the interview, we felt that | was withholding information from us. She made several comments as to she has put the entire incident behind her. I left my direct telephone number and advised should she wish to speak with me again to telephone me. Sgt Frick and I thanked Mrs. a her time and left the area. She stated she would ask her again after_w s to what happened at Epstein s house. I informed her that ad my telephone number and hopefully she would call. a Sqt Frick and I then attempted contact with a. Loxahatchee. We met with | her daughter. [§MMwas at the Wellington Mall not home. We explained the ongoing investigation and felt a have additional information as we had information that she had worked for Jeff. We left our phone numbers and asked her to telephone me upon her daughter's return. We then left the area. On October 4, 2005, at approxi :05 am, Sgt Frick had retrieved a voice mail message from She stated she had spoken with her daughter en. as to what occurred at Jeff s house. I. contacted who stated her daughter was in the shower at the moment and would be traveling back to Orlando to attend College. I informed her I would be en route to her home in Det. Dawson and I drove to the home and met_wi and During a sworn taped statement, stated she was taken to the house by Haley Robson. She was to she could make money working f - She was told she would have to provide a massage to Jeff. ii: 2:3 upon her arrival to the house she was brought to the kitchen area by Robson. They met with the house chef and Haley stayed in the kitchen. She was introduced to Sara, Jeff's assistant and was brought upstairs to the mater bedroom. Sara prepared the room and massage table for a massage. Epstein entered the room and she provided a massage. po stated she kept her clothes on during the massage. She stated sometime during the_massage Epstein grabbed her buttocks and pulled her close to him. [said she was wierded out by the incident involving Jeff. At the conclusion of the massage, she was paid $200.00 for the massage. I asked if she has any formal training in massages to which she replied no. I asked her if Robson received any monies for taking her to perform the _ stated Robson also received money for taking h re, stated she went with Robson and another girl, to Je s house once. | stated she waited in the kitchen with Robson, while as taken upstairs by Sara. stated she only did the massage once, as she was wierded out by tne whole experience. At the conclusion of the interview and the tape was stopped, I was informed that Sara had attempted to eaach Cis cell phone. A voice mail message on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as Sara who requested her to call her back reference the GIUFFRE005643 CONFIDENTIAL

Time: Case kk tek ke NA Case 18-2868, Document 283, 08/09/2019, 2628241, Page627 of 883 — emer mcr te cece cme eee ee crm rere ree eee ees cess 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 31 8:47:53 Incident Report Program: CMS301L No. .. . : 1-05-000368 (Cont inued) police questioning. This voice mail message was recorded onto a micro cassette. rovided the incoming telephone number as stated she ntly told about the police investigation because lil 2c called her to tell her about how she just received a rental car from Jeff Epstein. had called her to tell her that she was given Silver Nissan Sentra, to utilize to visit family and visit JefE. aske er What was going on att use that the police would be asking questions. mule aren then called Jeff and Sara and asked what was going on reference the ongoing police investigation. According iim Sara has since then been trying to contact her to ask about the police questions. . I instructe ot to contact Sara and do not provide any more information to as she would notify Jeff Epstein and Sara what was transpiring. Investigation Continues... KEKKKKKKKKKKKEKKKKKKKEKEK NBR RRATIVE HG KEKE RKEKKEKERKEKR KKK EEE Reported By: LEE, LA'MONT 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/07/05 On March 30, 2005, I was asked by Sgt. Daniel Szarszewski to begin conducting surveillance and trash pulls reference Detective Pagan conducting a criminal investigation involving Jeffrey Epstein. I was advised that Epstein was possibly engaging in sexual contact with young females. On March 30, 2005, I made contact with Town of Palm Beach Sanitation Office Supervisor Tony Higgins and requested trash pulls for 358 El Brillo Way to begin on March 31, 2005. On March 31, 2005 at 9:20 a.m., I responded to the area of 358 El Brillo Way and met with Town of Palm Beach sanitation employee, Jeffrey Williams. I observed Williams enter the driveway of 358 El Brillo Way, collect the trash bags from Epstein's property and place the contents into an empty sanitation truck. I followed Williams to a nearby area, were he turned over seventeen white plastic trash bags, which were collected from Epstein's property. : I took the trash bags to the sanitation department were I sifted through its contents. I collected mail correspondence from Armani Exchange addressed to Nada Marcinkova, Jeffrey E. Epstein notepaper with ee ea ter eane nine = dédreceed te J.E dated 03/29/05 at 8:15 p.m. reference U.S Airways boarding pass copy for passenger, Janusz Banasiak, Montgomery County, Maryland Health Department food service ID RE <0: Janusz Banasiak and Ghislaine Maxwell notepaper with names and phone numbers. Photocopies of the trash collected were attached with the supplement. Detective Pagan was advised of the contents that were collected for evidentiary value. GIUFFRE005644 CONFIDENTIAL hil. as w a

Case 18-2868, Document 283, 08/09/2019, 2628241, Page628 of 883 ee ee meee ee ee ee —— eee eee ee ee ee ee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 32 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . + 1-05-000368 (Continued) On March 31, 2005, Sgt. Daniel Szarszewski requested that I set up a Slee ae Be es surveillance vehicle on-El Brillo Way and conduct video surveillance of the front exterior of Epstein's residence. At 3:00 p.m., I set up a surveillance vehicle equipped with a video monitoring device. The surveillance vehicle was parked on El Brillo Way approximately fifty feet east of Epstein's driveway. The purpose of the video surveillance was to gather investigative intelligence by monitoring and recording all vehicle and pedestrian traffic entering and leaving Epstein's property. The video surveillance tapes were changed daily with a new Maxell T-~160 VHS tape. Video surveillance was established for Epstein s from March 31, 2005 through April 05, 2005. On April 05, 2005, video surveillance was concluded. I reviewed the video tapes and advised Detective Pagan the surveillance videos yielded no evidentiary value. On April O01, 2005 at 9:30 a.m., I responded to the area of 358 El Brillo Way to meet with Town of Palm Beach sanitation employee, Jessie Jones. While parked in the area of 358 El Brillo Way waiting to collect Epstein s trash, I observed a white female, who I recognized as Nada Marcinkova from her Florida driver's license photograph. I made no contact with Marcinkova. While parked in the area, I also | observed Epstein s GMC Yukon truck leave the property as well as other vehicles arrive and park across the street from the property. The occupants of these vehicles appeared to be housekeepers, maintenance men, and gardeners. At 9:38 a.m., I met with Town of Palm Beach sanitation employee, Jessie Jones. I observed Jones enter the driveway of 358 El Brillo Way and collect the trash from Epstein s property. I followed Jessie to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. I collected mail correspondences addressed to Jeffrey Epstein, automotive records and personal documents for Janusz Banasiak and Beata Banasiak as well as Jeffrey 1 en with the names and.appointment times for d No last names or other personal information was written on the notepaper. While sifting through Epstein s trash, I also collected a three-inch purple finger size object, which had a broken end. The object appeared to be a broke piece from a sexual toy similar to a (Cyclone Vibrator) possibly used for rectal gratification. The sexual object was photographed for Detective Pagan, packaged in a biohazard evidence bag (possible body fluids) and secured as investigative evidence. All items collected from Epstein s trash were turned over to Detective Pagan for evidentiary purposes. On April 05, 2005 at 9:18 a.m., I met with Town of Palm Beach Sanitation employee, Jessie Jones. I observed Jones enter the driveway of 358 El Brillo Way and collect the trash from Epstein s property. I followed Jessie to a predetermined area at which time I GIUFFRE005645 CONFIDENTIAL PN note IY el hee ane ph emit Ne AOE ee het heel ee ey le ee ee ee ee een = ee a

Case 18-2868, Document 283, 08/09/2019, 2628241, Page629 of 883 mre mae ame me meme mm memes ee cement ments mmm meee: cs SS recy ey amy, se eet ee cee eet Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 33 Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Continued) collected the trash bags from the sanitation truck. I- transported the trash bags to the sanitation department, where I sifted through its contents. I collected mail correspondences addressed to Jeffrey Epstein as well as notepaper (Important Message) with names and telephone numbers. The following are items collected from Epstein s trash. aper blank piece of white black paper black paper David MSN Hotmai The following items were documented for Detective Pagan s investigation for evidentiary purposes. On April 06, 08, 11, 12, 13, 15, 2005, at approximately 9:30 a.m, I met with Town of Palm Beach sanitation employees. I observed the employee enter the driveway of 358 El Brillo Way and collect the trash from Epstein's property. I followed the employee to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. All of the documents collected from Epstein's trash during my assistance were turned over to Detective Pagan for evidentiary purposes. On June 14, 2005, Detective Michelle Pagan contacted me and advised that the airplane belonging to Jeffrey Epstein of 358 El Brillo Way was parked at the Palm Beach International Airport. Detective Pagan requested that I begin trash pulls for the purpose of gathering evidence and intelligence. I made contact with Town of Palm Beach Sanitation Office Supervisor Tony Higgins and requested trash pulls for 358 El Brillo Way to begin om June 15, 2005. On June 15, 2005, I met with a sanitation employee. I observed the employee enter the driveway of 358 El Brillo Way and collect the trash from Epstein s property. I followed the employee to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. The trash yielded negative results and no evidence was collected. No further trash was collected throughout the week due to the fact that Epstein s security gates remained closed throughout the week; therefore, the sanitation employees were unable to gain access onto the property for collection of the trash. GIUFFRE005646 CONFIDENTIAL

— oo oe oe Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page630 of 883 ee ee ee ce = Ewa B= aS aw eOGane waoeees Bene Saw Be SS SOS ows owe ee ee ea eee oO ~e 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 34 3:47:53 Incident Report Program: CMS301L No. . . . : 1-05-000368 (Continued) All evidence and intelligence gathered by this officer has been turned over to the detective bureau and no further action has been taken by this officer. End of supplement. KRREEEKKKKEEKEKEKKEKKKEKKKRKEKKKEKEKE NW ARRAT IVE # GQ KKEKKEKREKKKKRKKKKRKKKKEKEKKEEES NA Reported By: RECAREY, JOSEPH 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/10/05 On October 4, 2005, I made telephone contact with who had left several messages on voice mail. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not- want to speak of this incident in front of her mother. At approximately 15:48 pm, I made telephone contact with i During a taped recorded statement, stated the following: Approximately a year ago, when she was sixteen years of age, Robson took her to Jeff's house twice. The first time she went, Haley Robson drove to the house. They entered through the kitchen area where she was introduced to Sara and Jeff. She was taken upstairs to a bedroom by Sara who set the room up with a massage bed and brought out the oils to use. Jeff then entered the g a towel. ‘He lay on the table and picked out a lotion cor liana rub on him. At one point during the massage, he tried to remove her shirt at int she became very upset and discontinued the massage. sc: —e 3 Jeffrey had a verbal eee at which time she left without being paid. She met with Hal on who was sitting in the kitchen and told : : advised she received no money for that day. also Said that Haley Robson had told her if she was uncomfortable with. what was going on, to let him know and he'll stop. She knew that the more you do the more you are paid. Several weeks later, MMM advised she agreed to be taken a second time by Haley Robson. Once they arrived at the residence, Haley sat in the kitchen and Sara took her upstairs to the master bedroom again. Sara set the room up with a massage bed and brought out the oils to use. Jeff then entered the room wearing a towel. He lay on the table and picked out a lotion for a rub on him. At one point during the massage, he tried to touch her buttocks. As was wearing tight jeans and had a tight belt on Jeff was unable to touch her buttocks. Jeff then rolled ck during the massage; he attempted to touch her breasts. hen became upset again and told him she didn't want to be touched. iscontinued the massage and was paid $200.00. then went downstairs where Haley Robson was waiting for her. She told Robson she w leave. 2:6 she never ret e. a stated she 1s aware that her —— ae a e house and had a problem with Jeff. She provided a telephone number GIUFFRE005647 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page631 of 883 -—— —— — ee ee eee re rec me rere meee ees es Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 35 Time: 8:47:53 Incident Report Program: CMS301L Case No. ... : 1-05-000368 (Continued) for MM. «=the interview was concluded and the micro cassettes were turn in as evidence. On Octob researched the incoming telephone numbe a message. The telephone number, was assigned to ATT/Cingular Cellular service. I prepared a subpoena had left request and faxed the request to the State Attorney s Office. Information requested was subscriber information as well as all incoming and outgoing calls for the months of September and October 2005. I later researched I nd discovered she resides in Royal Palm Beach. Det. Dawson and I Beach and met with at ber residence in Royal Palm Beach. e....-- to speak with us in the kitchen area. During a sworn tape a eee ene, ee stated the following: On or about November 2004, she was approached by Haley Robson and asked if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. Robson picked her up and drove her to a house in Palm Beach. She was brought into the kitc house. She further stated that — ee went with them. They were brought into the kitchen where she was introduced to Jeff and other females. stated she was introduced to a helper of Jeff; the female was described as white female (unknown name), with blond hair. She stated that the assistant was familiar with Robson. The. assist up the massage table and put out lotions to be used. She cold (alse would available ina minute. Jeff entered the room wearing only a towel. Jeff lay on the massage table and picked a lotion to rub on his thighs and back. GENE cur the: stated that during the massage Jeff asked her e her clothes. She complied and removed her pants and blouse. an didn't remember if she had removed her bra but feels that she did. was certain that she stayed in her thong underwear. continued the massage and at one point she straddled _ him to massage his back, which touched his buttocks with hers. as instructed to return_to the ground at which time Jeff turne Oo have his chest rubbed. it was at this time she is sure he was masturbating. id not want to look at his penis area because she was rtable. Jeff removed a large white vibrator and turned 1G Of. ee. ces he began rubbing the vibrator over her thong underwear on her vaginal area. Shortly thereafter, Jeff ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked PE now Old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, | was paid either §350.00 or $400.00. She stated she wasn't sure, s it was close to $400.00. At the conclusion of the take ec she never returned to provide a massage for Jeff. She advised she was ashamed and uncomfortable with the situation. GIUFFRE005648 CONFIDENTIAL ee Os Se TA, AM tls Sil pone eee cd be © a

Case 18-2868, Document 283, 08/09/2019, 2628241, Page632 of 883 _—_—— FS = Ser eae ee ee ee ee ee ee eee eee eee eee eee eee es ee eee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 36 Time: 8:47:53 Incident Report Program: CMS30iL = ee ee ieee meee mee me eee eee me es ee ee Case No. . . . : 1-05-000368 . Continued Det. Dawson and I then left the area and responded to the High School where Robson and all the above-mentioned girls ha attended. I met with School Police Officer, Off Williams. I ined I was looking for a previo o attended iy High School. I inquired about I further explained that I was working a case in which most of the girls I have interviewed are either witnesses or victims and felt that ay be one..as well. Officer Williams researched his previous st ecords and found She attended the same year and graduated in the sam e other girls. I was provided the last known address of At approximate : n and I met with her leaidance, Wey. Royal Palm Beach. As only seventeen years of age, I had notified her mother, Mrs. a that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. Ie the possibility of_her being either a witness or victim. Mrs. dvised she wanted O cooperate and consented to the interview. During a sworn taped ‘eet stated the following: at the age of sixteen, during the month o September 2004, she was approached by Haley Robson for a chance to make money. a: friends with the friends of Robson and knew the e as at same people. had been previously told by her frj what Robson did for J Robson called a person known to as Sara and scheduled the appointment. Robson pie oe and drove her to Palm Beach to a street called Brill6 Way. “Tney drove to the end of the street and entered a large driveway. They entered the kitchen area of the house and met with Jeff. as introduced to Jeff. Robson led ees to the main bedroom area and set up the room with a massage table and set out the oils. Robson dimmed the lights and turned on soft music. Robson exited the room and Jeff entered the room wearing only a towel. Jeff picked oils and instructed her to rub his legs, under his buttocks, back and chest area. Jeff asked her to get comfortable. dvised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposin elly area. During the massage, Jeff removed his towel. As rubbed his chest area, Jeff attempted to reach down her pants h the buttocks area, :. ie unable to due to the tightness of the jeans and a tight belt. dvised Jeff began to masturbate as she rubbed his chest. oaned as she rubbed his chest. She observed he was continuing to ma e and attempted to reach up her tank top and touch her breasts. ulled back and Jeff stopped. However, he kept masturbating until he climaxed. He cleaned himself with the towel he was previously wearing. I asked if she knew the difference between circumcised and not oj ised. She explained she knew and advised Jeff was circumcised. - S paid $200.00 for the massage and left the area. She met witn Ropson who was waiting in the kitchen area and left the house. GE hen explained she never provided anot me eif. She did however, go to the house with Robson and as they GIUFFRE005649 CONFIDENTIAL - - 9+ 20 egos —— pom OO I A ae we ete ae oe Oe he ee hee ater i oe ey ee SY OR Hh me

Case 18-2868, Document 283, 08/09/2019, 2628241, Page633 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 37 Time: 8:47:53 Incident Report Program: CMS3011L Case No. . . . : 1-05-000368 (Continued) 3 took. another friend of Robson's. GR cvised she was present when ent to work for Jeff. She advised she er and Sat in the kitchen area wi n to wait co i advised that while they waited for th chet prepared lun ch for them, as it was almost lunchtime. As was finished with the massage, they left the area. I asked if Robson e 1d what would be expected of her when she provided a massage. oo yes, Robson told her that a massage would be expected possibly naked and possibly some touching involved. has no formal-training in providing massages. Pa... about a third and last time she went to Jeff's house. Robson drove another girl, who is friend, to Jeff's house. Stated she knew that Robson hada made. money providing girls for Jeff and she wanted to do the s them in the kitchen a e house and introduced Robson and Sara took upstairs to the main bedroom. advised she doesn t know what happened as did not spea out what happened in the room. sai cad $100 Robson for going with her to Jeff s house and shoe 2: unable to remember telephone number. The interview was concluded and we left the area. Investigation Continues... RRKKKKKKEAKAEKKKKKRKKAKKKKKKEEE NOD RR ATIVE H LQ KARR KEKKEKKEEEKEKKEKKKKKKRKKEE NA Reported By: RECAREY, JOSEPH 10/09/05 Entered By.: ALTOMARO, NICKIE A. 10/10/05 On October 6, 2005, Det. Dawson and I went to Lynn University located in Boca Raton. We met with Dean of Students, Paul Turner. I explained to Mr. Turner that we were investigating a crime within the Town of Palm Beach and felt that a student, — may have | information. Turner confirmed i a student and currently | on the soccer team for Lynn University. he was in computer class at the time of our arrival. Turner sent a security guard to locate in class ee | her to the office. .Mr. Turner allowed us to interview in an empty conference room. At 11:45 am I met with and explained to her why we there to interview her. She advised she was aware of the ongoing | igation. stated she had previously spoken with yam ! ho told her she was interviewed by detectives. During a sworn taped statement, ed she knew that Haley Robson worked for Jeff in Palm Beach. advised she has been there many times for massages. | d her if she had fo training in providing massages, a she did not. dvised she was told what was expected of her by providing massages and would have to remove clothing but if she felt ortable just to say so and Jeff would stop pushing the issue. began providing massages and advised She kept her clothes on. She considered Jeff a pervert who kept GIUFFRE005650 CONFIDENTIAL

Date: Time: ~~ — =< = Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page634 of 883 i ln er ee ee ee ee 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 38 8:47:53 Incident Report Program: CMS301L No. . . . : 1-05-000368 (Continued) pushing to go further and further. xplained she would keep telling him she had a boyfriend and that it would not be right to her boyfriend. It wasn t until recently admitted to removing her and staying in her thong underwear to provide a massage. xplained Jeff wanted to be rubbed on his back and recently he began turning over to have her rub his chest as’he mastu He would try to touch her breasts as she rubbed his chest. tated, Jeff would try to get away with more and more on each massage. inally, Robson drove her to the house for the original massage. left Sara her cell phone number and every time Jeff would come into town, Sara would call her for an appointment. Each time she went, Sara would meet her at the kitchen doo She would bring her upstairs and prepare the massage table. SN sina Jeff would ask her questions about herself. He knew sh soccer player and would be attending Lynn University. I asked if he knew her real age, stated Jeff didn t care. The most recent massage she provided was on October 1, 2005. During the massage she asked Jeff if she could borrow one of his vehicles to visit her family and boyfriend in Orlando. Jeff had told she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as .J bed her buttocks and caressed the buttocks cheeks. I — TF she was wearing undergarments to which she replied her thong underwear. Once he tried to touch her breasts she would pull away: from him an ld stop. was asked if he ever used a vibrator on her. was aware of the vibrator but advised she never -would allow him to use the vibrator on her. She described the vibrator as a large white vibrator with a huge head.on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. (MMMMkdvised she had been doing the massage for approximately two years, which meant she would have started doing massages for Jeff at the age of sixteen. GE stated she was contacted by Sara on October 3, 2005. Sara had informed her that Jeff had rented her a new Nissan Sentra and she should come by the house t it. up. Sara informed she would have the car for a month. stated Jeff knew her car was not working properly and had missed appointments in the past because of her car being inoperable. xplained the car is currently parked next to Field. I asked her j ook any one to the house. explained she took a friend of hers who has returned to Orlando to attend college. I asked she ever allowed another female in the room. dvised no one was brought into the room with her. At the conclusion of the interview, Det. Dawson and I went to the Gym area and located the Silver Nissan Sentra bearing Florida tag X98-APM. The vehicle is registered to Dollar rent a car out of the Palm Beach International Airport. tact was made with po the victim's mother, at I explained to her that I was following up on this case and provided a complete update on the case. Investigation Continues. GIUFFRE005651 CONFIDENTIAL ee enna

Case 18-2868, Document 283, 08/09/2019, 2628241, Page635 of 883 i asaeoe oem eee eae ee eee a ee ae eS eS aS SV Se eB GB e2 eee we @ 2 — es ewe Se Ss eZ ee SSB ew Se Se wew OX Ze eee eenw eS = eo aes Sw Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 33 Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Continued) KEEREEKEKKRKEKEKEKKEERRKRRRKRKREES NAR RAT T VE # LL EERE ER KRKKKEKKKKEKKKKKKEEEKSE NA Reported By: RECAREY, JOSEPH | 10/21/05 Entered By.: ALTOMARO, NICKIE A. 10/21/05 On October 1 oximately 2:30 p.m., I made telephone contact with During a taped conversation, as told of an ongoing investigation _j ich I felt she had information pertaining to Jeffrey Epstein. "Mili is ines she met Ep wap JuSt sixteen years of age. She was approached -y iia iend who also had previously gone to Epstein's house. for as working at the Wellington Mall when told her that she would have to provide massages. advi she was approached. sage to Epstein and she would have to perform this massage naked. ge Sought about the offer and stated she could make $200.00 for inutes of work. She agreed to perform the _ massage and et the appointment for her that same day. rem was a weekend as she only worked at the mall on the weekends. took her to the house where she was introduced to Sara, Jeff assistant. Sara took her upstairs to a master bedroom. explained that as she was walking up the stairs she observed several AM ert of naked women along the walls and tables of the house. further explained that she was brought into the bedroom where ara prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. Epstein entered the room and oo a Epstein lay on the table: and told her to get comfortable. ould member if he was naked or if he entered the room with a towel. tated she provided the massage rect. fi — her panties. She continued rubbing his legs, thighs and feet. dvised he turned over onto his back. She continued to rub his legs with the oils. Epstein touched her breasts and began to masturbate. Ia if she knew what circumcised and un-circumcised meant. tated circumcised ji the penis has no foreskin and the head o e penis is visible. fii said Epstein is circumcised. egan to cry on the telephone an stated she had been to his house hundreds of times over a two-year period. uae. =. -; to have made thousands of dollars during her visits. stated she could not remember how many times exactly she went to Epstein's home but said it was a lot. became more upset, crying hysterically and stated she was paid and instructed to have sex with Epstein's assistant, Nada Marcinkova by. Epstein. Epstein continued to watch them have sex and masturbated himself as they had sex with each other. She further stated that things escalated further and further. Epstein used toys such as vibrators, rubber penises and strap-on penises on Additionally, ee ee he performed oral sex on her numerous times. She claimed he (Epstein) put his fingers inside her vagina while he masturbated in an attempt to make her climax. could not continue and wanted some time to regain her composure. I explained tol] to take her time. After taking several minutes to regain her composure I GIUFFRE005652 CONFIDENTIAL ee a teen ROY en _i ee ee ne

ei eee ee en ee ee ee ee ee ee eee eee ee Date: Time: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: . 40 8347:53 tneident: Report Program: CMS301L No. . . . : 1-05-000368 (Continued) Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page636 of 883 explained that I would travel to meet with her in person as I felt she had additional information to provide t with Sgt. Frick and explained the importance to meet with n person. Sgt. Frick agreed and made arraignments for Det. Dawson and I to meet with in Jacksonville, Florida. Det. Dawson and I met with at O05, at 4:10 p.m. qd her’ fri Jacksonville, Florida. ted to have support. I explained to her that I did not have a tated she she wanted (EP resent during the int wanted her present. I explained that as as present she was not allowed to comment or_ask any questions during the interview. She was only there to comfort ]MMMbhould the interview upset her. During a sworn taped statement <p ained how everything began. She said she was brought through the kitchen area where she met Sara ror & t time. She was led to the master bedroom, Epstein s coon. (iillexc 23:3 that as she was walking up the stairs she observed several photographs of naked women along the walls and tables of the house. a cor ther explained that she was brought into the. bedroom, where Sara prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. xplained she remembered the steam room area, which contained two large showers. . Epstein entered the room from the steam room area and introduced self. Epstein lay on the table and told her to get comfortable. removed her skirt and kept her shirt on. She could not remember 1c ne was naked or if he entered th with a towel. Epstein then instructed her to remove her shirt. oved her shirt and remembered she was not wearing a bra. tated she provided the Massage wearing aa panties. She continued rubbing his legs, thighs and feet. dvised he turned over onto his back. She continued to rub his legs with the oils. Epstein touched her breasts and began to masturbate. Epstein ejaculate meant the massage was over. At the conclusion of the massage 00.00. They walk ether downstairs where Sara and ere waiting. state eceived an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town. «<0. ined. that she continued to go to Epstein s house and became a regular at the house. She could not provide an exact number but claimed she had been their hundreds of times. She claimed sexual activities did not occur every time she was th There were times she went to dinners and parties with Epstein. xplained that things began to escalate more than the massage. . The encounters imcluded bringing in his assistant, Nada Marcinkova. xplained Epstein had purchased her from her family in Yugoslavia. Epstein bragged he her into the United States to be his Yugoslavian sex arave MEE ocised he was naked in the bedroom, she entered and removed her clothing. Marcinkova d the room from the steam room area already naked. He instructe to perform oral sex on in present for roblem as long as GIUFFRE005653 CONFIDENTIAL PB Ales ates coches camamsccamms pammay ee Ree ete ety et ae

Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page637 of 883 mae ee — =— ee ——_—-_— — Oe ee eee eee ee ee eR i ee eee ed 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 41 8:47:53 Incident Report Program: CMS301L Ferree rere ere tere rrr remem germ errr reer rere erm reer eee No. . = 05 — 368 (Continued) Marcinkova MEE or isca to perform that act. Epstein offered her an additional 0 for her to perform oral sex on Marcinkova for greed to perform the oral sex for the additional ained that Epstein would masturbate while he watched them perform sexual acts. Things continued to escalate by purchasing sex toys. GE = ated she had massagers, vibrators and strap on rubber penises used on her. Each time — # was introduced additional were produced and offered for Oo allow the acts to happen. a. adamant : that she performs all these acts but there was an understanding Epstein that no vaginal penetration would occur with his penis. explained that Epstein's penis was deformed. xplained that his penis was oval shaped. She claimed when Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head portion. She called it egg-shaped. GE ont inved that ‘ee encounters with Marcinkova, Epstein and k herself her became a ritual. ould arrive at the house nai. upstairs, where Marcinkova and Epstein were wai ould remove her clothing and join them on the bed. xplained inkova and she would begin by kissing and touching each other. explained sex toys were brought into the bed by either Epstein or Marcinkova and they would begin using the toys on. each other. Epstein would perform oral sex person depending who was on top during the intercourse. xplanation revealed they were in a missionary position. ee cviced one day, ae unable to state and exact date when Z S incident occurred), she came to the house after Sara had informed her that Epstein had arrived. She arrived at the house and went upstairs to the master bedroom. (§Mhdvised she immediately removed her clothing, as Nada Marcinkova and Epstein were already naked in the bedroom. lained that Nada Marcinkova and she had a sexual encounter to include kissing, touching and oral sex. emembered that she climaxed and was removing her self from the massage table. asked for a sheet of paper and drew the massage table in the an and where Epstein, Marcinkova and she were. Epstein turned on to her _ on the massage bed and inserted his penis into ina. stated Epstein began to pump his penis in her vagina. ecame upset over this. She said her head was being held against the bed forcibly, as he continued to pump inside her. She screamed no, and Epstein stopped. She told him that she did not want to have his penis inside of her. Epstein apologized for his actions and subsequently paid her a thousand d for that visit. Additionally, shortly thereafter, Epstein on 2005 Doge Neon, blue in color for her personal use. dvised there were times that she was so sore when she left Epstei se. advised she was ripped, torn, in her vagina area. fi ssi ccc she had difficulty walking to the car after leaving the house because she was so sore. WEEN =Gvised that other GIUFFRE005654 CONFIDENTIAL OE Re 6 a a me ey A emesis eben te oa | A ete ee ete ees ee Oe RN ats ey eee ty Weed rie Bop awe-B acee ee ee comieemmen teens ammccmse di .

Case 18-2868, Document 283, 08/09/2019, 2628241, Page638 of 883 a eee ie ee ee ee ee ee ee ee ee eee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 42 Time: 8:47:53 Incident Report Program: CMS301L Case No. ... : 1-05-000368— | (Continued) than that one time, when Epstein inserted his penis inside her vagina, there was no other penile intercourse. GE 3 ovidea names of girls that she knew of that have gone to Epetein's house. (MMMMMprovided the nane of MEMMMEMMMMMMand fecla she still a be iis 2 to the house to massage Epstein. According to is still sucking his dick." When asked if she had been recently contacted by anyone of the house, vised she received an email from Sara, from et, which is her email account. The email was just Ow are you doing type of email. There had aie left the a hello, contact from the house. The interview was concluded and area. The tapes and drawing were submitted into evidence. Investigation continues... FI III IOI NARRATIVE HD ERE KKKKKKEKKEREKKEEREKRKEKKEE NA Reported By: RECAREY, JOSEPH 11/01/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 12, 2005, Det. Dawson and I traveled to the Orlando area and made telephone contact with greed to meet with us as we were in the Orlando area. ovided directions to her apartment. Det. Dawson and I met with who stated, during a aped statement that nothing happened between her and Epstein. alli nervous during the interview. I assured_her that I had spoken with other people who advised differently. stated she only went a couple of times and provided a massage to Epstein. was brought to the stein house in March of 2005. roug work. as no formal training in providing massages. tated she provided a massage, fully for $200.00. As I sensed hesitancy in her answers, I asked —f she had been contacted by anyone from the house. Stated she was interviewed already by an investigator for Epstein. met with her on October 8, 2005, at a Roadhouse in Orlando. He identified himself as Paul andj ut the police investigation his telephone number or additional contact. rovided no additional intormation, as it appeared her responses were almost scripted. We left the area and returned to Palm Beach Police Department. He Based on the information acquired during the interviews, a search warrant was prepared for entry at the Epstein home. On October 18, 2005, I met with Judge Laura Johnson who reviewed the warrant request. She found there was sufficient probable cause and signed the warrant request. On October 20, 2005, at approximately 9:36 am, members of the Palm Beach Police Investigations Unit executed the search warrant at 358 El Brillo in Palm Beach. Members of the Investigations Unit included Capt Gudger, Sgt Frick, Det. Dicks, Det. Dawson, Det. Melnichok, Det. Sandman, Det. Krauel, the crime scene unit and myself. GIUFFRE005655 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page639 of 883 —— ee “~—— — — — — — oe ee = ere me emery ree ree mee ee eee es ee eee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 43 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) As we entered onto the property, we encountered the house manager, Janusz Banasiak who was in the guest portion of the house. The guesthouse section had open doors and no forced entry was made. I made contact with Banasiak, Date of birth Fl DL and informed him of the search warrant for the premises. The members of the Police Department entered the residence and announced we had a search warrant. A safety search was done and members exited the home. I read the search warrant to Banasiak as Mgr Parkinson videotaped the search warrant execution. Several interior d were located on the property. I spoke with Mark Zeff, of DE... York. Mr. Zeff stated he is the designer for Mr. Epstein's. homes. He advised he was contacted in March of 2005 to do a complete overhaul on the house. He advised he was on the phone with Mr. Epstein when officers announced the search warrant. Mr. Epstein was then made aware of the search warrant. Mr. Zeff advised, his contact with Epstein is strictly business and he has never ee with any girls except for his assistants, Sara or Nada, I then interviewed Daniel Estes, of ae .. New York. Mr. Estes stated he has worked for Zeff for seven years. He advised he personally worked on the New York and Palm Beach home for Mr. Epstein. He has previously met with Sara and Adrianna, Epstein's assistants in New York and in Florida. Estes stated they travel with Epstein everywhere he goes. I interviewed Zara Bailey of es Jersey. Bailey stated she just arrive rom Scotland and has worked with Zeff for only one month. She stated she has never met Epstein and has not seen him. The interview was then concluded. I then spoke with Douglas Schoettle es... York City. Schoettle stated he has been Epstein's Architect for seven years. He further stated he deals with Epstein's assistants and Speaks with Epstein on the phone. Schoettle stated he mainly speaks with Sara Kellen, Epstein s main assistant, who travels with Epstein. Schoettle stated he only has contact. with Epstein when his services are needed. At approximately 10:30 am, I was informed that the videotaping was concluded. I entered the residence and located two covert (hidden) cameras. The first camera was a covert wall clock in the garage area. I traced the wire behind the clock and removed the RCA wire and unplugged the camera. The other covert camera was located within a desk clock beside Epstein's desk. I traced the wire behind the clock and unplugged the RCA wire. I could not locate another camera. I then began with the search of the residence for the specified evidence. My search consisted of the second floor. Det. Krauel and I began in the master bedroom area where several items were located. They were GIUFFRE005656 CONFIDENTIAL Se ey eR aha oe wate ih ts ltt ne ew So

Case 18-2868, Document 283, 08/09/2019, 2628241, Page640 of 883 - ff — ee — ee a ee ee ee mmm me mm es eee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 44 Time: 8:47:53 Incident Report Program: CMS301L Case No. . . . : 1-05-000368 (Continued) marked to be retrieved by the evidence custodian. In the master desk with Epstein's notepad : stein we located a high 1 transcript from igh School for Also in the room, was tne dresser /armoire where we Located a bottle of peach flavored Joy Jelly (Sexual Lubricant). Additionally, there were several photographs of young naked teenage girls within the closet, which was consistent with what the witnesses said. The massage table was also located within the master bedroom. Video tapes were located beside the television, which were also collected. An itemized list of the property and locations was prepared on the _property receipts. At approximately 2:55 pm, the house was secured; — the exit of the residence was videotaped. Upon our exit of the property, I encountered Atty. Guy Fronstein who advised he was representing Mr. Epstein. He provided a business card and provided his assistance with the investigation. Due to Hurricane Wilma, which struck South Florida causing massive power outages, the courthouse was closed due to the lack of power. I was previously told that the Chief Judge had extended the filing deadlines due to the hurricane and the Courthouse being closed. On October 27, and 28, 2005 the courthouse was closed and I could not file the search warrant and inventory at the clerk's office. On October 31,.2005, I responded to the courthouse and filed the paperwork. along with an order to seal, signed by Judge Johnson, to deny any release of any paperwork on this case. INV CONTINUES. . KK KERR REE EERE REE RRR R REKEK NARRATIVE HLF RE KKKKEKKEKKKEEKEKKEKKKKKKK NA Reported By: PARKINSON, GREGORY A. 10/20/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 20, 2005, at approximately 8:30.a.m., Thursday morning, I was advised by Captain Gudger that a search warrant would be executed and that I was to assemble the Crime Scene Investigative Team and stand by the south side of the building ready to go. I designated Evidence Specialist Annette Badger to handle the inventory return, the documentation of the property receipts and the collection and bagging of the evidence at the scene. I further instructed CSI Kim Pavlik, ID # 8807, to accompany us and perform the role of photographing the scene and the items that may be taken into custody by the affiant, Detective Joseph Recarey, ID # 7915. My responsibility was to go through from the reading of the warrant to the final exit from the residence and perform a video recording of the reading of the warrant, the initial walk through of the residence showing the current condition and then finally a walk through of the residence at the time of the police exit. We started out towards the residence, which was located at 358 El Brillo and arrived at approximately 9:33 a.m. The search was conducted, items were collected by Evidence Specialists Badger, GIUFFRE005657 CONFIDENTIAL 6 Ce ee eenecientey Hf. eee eer “pum or rene Adie Octet ao ete B= 4 oy

———-— — Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page641 of 883 mm Smee meme ee tee ee meee we ee eee ee 7/25/06 PALM BEACH POLICE DEPARTMENT Page: /45 8:47:53 Incident Report Program: CMS301L No. . . . : 1-05-000368 (Continued) photographed by CSI Pavlik and then videotaped by myself. The search was concluded at approximately 3:05 p.m. whereupon Detective Recarey and I were the last two officers in the house. Upon securing the residence we met with the gentleman who identified himself to Detective Recarey as the lawyer for the defendant and he was informed that the residence was secured and that copies of the inventory return had been left on the first floor table of the personal assistant's office. Detective Recarey and I returned to Police Headquarters and secured for the day. KKKKKKKKKKKKEKKKKRRKKKKKKKEKKEK NARRATI v E HLL RR EREHERKKREKKKEKKEKKEKEKERES NA Reported By: DAWSON, MICHAEL C. 11/07/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 20, 2005, I assisted Defective Recarey in the execution of a search warrant at 358 El Brillo Way, Palm Beach, Florida, 33480. Upon the announcement of the search warrant, immediate contact was made with three white males who came out of the house or surrounding structures. Those males were identified as Janusz Banasiak, Daniel Estes, and Mark Zeff. As other members of the police department cleared the home, I kept watch over these three males. Once the house was cleared, those males were turned over to Detective Recarey. Detective Dicks and I were assigned to assist in the search of the main house, the cabana and the servant's quarters. We started in the garage. All areas of the garage were searched to include four vehicles. These vehicles were three black Mercedes Benz cars registered to Jeffrey Epstein. The fourth vehicle was a Harley Davidson motorcycle, green in color, registered to Jeffrey Epstein. Nothing was recovered from the garage. A towel closet and pantry located off the kitchen were searched and yielded negative results. The kitchen was searched and taken into evidence was a phone message book that was located near a house phone. North of the kitchen was an office room which contained a computer. The room had a closet that contained a locked gun locker. The combination was entered by Banasiak in the presence of Sgt. Frick and the safe was opened. Items were taken from the room. See the completed property receipt for a detailed list. A green bathroom located on the first floor was searched and nothing was taken. A closet located just west of the green bathroom was searched. ‘Two massage tables were located in the closet along with a photo of a nude GIUFFRE005658 CONFIDENTIAL 2 eee ket eee aE OO Om lin ek aE. 4 emmtee e rentREihs = Rhee tones wings

Case 18-2868, Document 283, 08/09/2019, 2628241, Page642 of 883 ria ee ee Date: Time: 7/25/06 - PALM BEACH POLICE DEPARTMENT Page: 46 8:47:53 Incident Report Program: CMS301L No. . . . : 1-05-000368 (Continued) Case female from the waist up. See the property receipt for details. I searched two bedrooms and their adjoining bathrooms, which were located on the second floor on the East side of the house. In the Northeast bedroom closet I found adult sex toys called Twin Torpedoes. KREKKKEKKEEEKKREKKEEKEKEKREKEKREKEKKEE NW RRATIVE NA pean two months ago, she was approached by a girl, Soap made in the shape of a penis and vagina were also found in these upstaixr bedrooms. See the property receipt for details. I searched the pool cabana located on the South side of the pool. Photos were taken from the wall. See the property receipt for details. I- assisted in the search of Banasiak's living quarters. Numerous CD s along with a message book was seized. See the property receipt for details. On November 1, 2005, I was contacted by Atty. Gus Fronstin, who advised he was willing to assist with the investigation. Atty. Fronstin advised he would try to have his client, Jeffrey Epstein available to be interviewed. I explained I would be interested in conducting an interview with his client as well as other employees that are employed within the house. Atty. Fronstin advised he would return my call once he received confirmation on the interviews. On November 6, 2005, I attempted contact with a -- her residence. I left a business card for her to return my call. Upon returni he lice department, I had received a telephone call from I returned her cali ot spoke with She made arrangements to resp tion to provide an interview. At approximately 3:30 pm, she arrived’ at the Palm Beach Police Station with her boyfriend. Her boyfriend was allowed to sit in the lobby area while Ms. was interviewed. I took Ms ae... the Detective Bureau Interview room. I closed the door for privacy and explained to her that I appreciated her coming to the police station for the interview. During the sworn taped statement, she advised she was at Jeffrey Epstein s house o who was dating her roommate, to make some quick money. acivised she was in need to make some quick cash to make the rent that She agreed to go to the house. She had been told by ne ee the massage would have to be done in her underwear. She advised §MMMSrove with her and brought her into the house. The walked into the kitchen area and took the stairs upstairs. a further stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room wearing only a towel and FE LS RR KRKEKKEKKKREKKKEKKEKKKEKKEKEK Reported By: RECAREY, JOSEPH 11/08/05 Entered By.: ALTOMARO, NICKIE A. | - 11/08/05 GIUFFRE005659 CONFIDENTIAL ‘ ' Fe ee 0 ON, 6 td ete maton + pe sib. ona ~

Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page643 of 883 ——— ee —as SE we ew ew ewe ee er EO eee ae OR KO wa eK Ww hae ae ew een hee Wr ae ee ewe eK we ee ee ee ew ww ee ee ee 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 47 8:47:53 Incident Report Program: CMS30iL No. .. . : 1-05-000368 (Continued introduced himself as Jeff. GT acvised- she recalled she and removed their clothing down to their panties, Epstein lay on his stoma and they provided a massage on his legs and feet area. I asked if she had any formal massage training and she replied no. advised she was “pa panties she wore were the boy shorts lace panties. She and ontinued the massage until the last ten minutes of the massage, Epstein, told MMto leave the ! room so that MMMMcould finish the massage. | | ot dressed and Epstein turned over onto his back. Epstein then | removed the towel, which had been around his waist. Epstein laid ! there naked and requested that Mjrub his chest area. stated ion. this, Epstein, began masturbating as she rubbed his chest. tated he pulled down her boy short panties and he © produced a large white vibrator with a large head. She stated it was within a drawer_in his master bathroom. He rubbed the vibrator on her vagina area. dvised he never penetrated her vagina with the vibrator. He continue er vagina with the vibrator as he continued to masturbate. tated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previousiy and went into the shower area ot dressed and ; met with in the kitchen area. stein came into the kitchen an provided 200.00 for bringin and paid $200.00 — | as told to leave her telephone ! Mr oviced for providing the massage. number with Sarah, his assistant for future contact. her cellular telephone number for future contact. §MMlwas asked if she was recently contacted about this investigation by anyone from the Epstein organization. She replied she was called but it was for work. She stated she was called by Sarah for her to return to work for Epstein. tat is the term used by Sarah to provide the massage in underwear. advised she declined, as she was not comfortable in providing that type of work. The interview was concluded and the videotape was placed into evidence. wT OPE 66S Reed meee ome Investigation Continues.. REEKKKKKEKEKKEKEEEEREEKEKEKEEKER NBRRRA TIVE: HG ERR KEKEKKEKEK EKER NA’ Reported By: RECAREY, JOSEPH 11/10/05 | Entered By.: ALTOMARO, NICKIE A. 11/10/05 On November 7, 2005, I made telephone contact with ae... advised she would be able to meet with me at her home. Det.- Sandman an to her home in Royal Palm B ade contact with During a sworn taped statement, stated she met Jeffrey Epstein through Haley Robson. Robson wou.a approach females who wished to work for him. stated she was asked to work for him but declined. explained that work means give massages. She was asked ormal training in providing massages to which she said no. said she accompanied Robson and other females GIUFFRE005660 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page644 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 48 Time: 8:47:53 Incident Report Program: CMS301L Case No. ...:. : 1-05-000368 | i112 ci ) who were taken to Epstein s house to provide massages. further stated she had been to the house approximatel the past year. She accompanied Robson with the 14-year-old victim, and Bach time the girls were taken over, they were previously the would have to provide a massage, possibly naked. It was also told that or 5 times in should Epstein require them to do anything extra were not comfortable just to tell him and he would stop. stated Robson received $200.00 for each girl she brought massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, the victim, as she stated she was fifteen years old at the most; she looked really young. mei... stated each time she went to the house, she sat in the kitchen and waited with Robson until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. The interview was concluded and the tape was turned into evidence. Investigation Continues.. REKKKKKKKKKKKKKKEKEKAKKEEKEE NARRATIVE HLT RRR EK KEKEKKEKKRKEKKEKEEKEKERKKEE NA Reported By: RECAREY, JOSEPH 11/10/05 Entered By.: ALTOMARO, NICKIE A. 11/10/05 Det. Dawson and I attempted contact with in Royal Palm Beach. I left my business card at her front door. Ms returned my call and arranged a meeting with me at the Palm Beach Police Department for November 8, 2005. At approximately 2:00pm, arrived at the Palm Beach Police Department. She was brought into the interview room and the door was closed for privacy. She was told that I appreciated her coming to the police station for | questioning regarding an on going investigation. She was told that I was investigating a crime involving Jeffrey Epstein and knew, based on the investigation, that she had rs with him in the past. During a sworn taped statement, stated she had met Epstein approximately two years ago. She was ixrst introduced to Epstein by Haley Robson. Robson approached her about working for Epstein and providing a massage to him for $200.00. The arrangements were made and as Robson coul day the arrangements were made, lso attended (INE ch took | School and was familiar with Epstein. recalled she was brought there and entered through the back kitchen door. She had met with an assistant Sarah and another assistant Adrianna. Sarah brought her upstairs as she observed several photographs of naked females throughout the house. stated stein came in the room, wearing only a towel, and laid on the table. tated he picked out the oils he wanted he d requested she remove her clothing to provide the massage. Tl stated that on the first massage she provided she did not remove her GIUFFRE005661 CONFIDENTIAL . Ee tee Ga ry atid orem teen ame oe = ie lh ee ee S480 cep Bee wre mmmeens

Case 18-2868, Document 283, 08/09/2019, 2628241, Page645 of 883 ee eters eee mee eee eee cee eG eee ee eee eee eee eee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 49 Time: 8:47:53 Incident Report Program: CMS301L Case No. ... : 1-05-000368 (Continued) clothing. ee 8509 she had returned several times after that.. Each time she returned more things happened. — that the same thing would happen. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He would masturbate as she provided a massage. CEE cc she was unsure if he climaxed as he masturbated under the towel. Additionally she never looked blow his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and: stayed in her thong panties. On occasion, Epstein would use a massager/vibrator, which she described as white in color with a larg her. Every time she provided a massage he would masturb added she has no formal training in providing a cnasturha brought two females during h stated she brought a girl named High School. s g brought. Additionally, was given $200.00 for taking her in the very beginning. The interview was concluded and the tape was placed into evidence. Investigation continues... KKKKKKKARKKKKKEKKEKEKHRKEEREEKEKE NARRATIVE: HQ KKK KEKE KEK ERKKKHEEKE EK KERR NA Reported By: RECAREY, JOSEPH 11/13/05 Entered By.: ALTOMARO, NICKIE A. 11/14/05 mber 8, 2005, I made telephone contact vith W/F, a at her residence. SRNR esponded to the police station for an interview reference an ongoing investigation. At approximately 2:30 pm, she arrived at the Palm Beach Police Station and was brought into the interview room for the interview. The door was closed for privacy and she was told that I apprecj er cooperation in this case. During a sworn taped statement, stated she had met Jeffrey Epstein 1: an _ year -. She was approached by a subject known to her as | ad asked her if she wanted to make money providi Epstein. (§—MMhad heard that several girls from High School were doing thi making money. She agreed and was taken to the house b had introduced her to Sarah and Epstein and brought her upstairs to a master bedroom and Master bathroom where a massage table was prepared and the proper oils wer out. QM left the room and waited downstairs for tated Epstein entered the room wearing a ad she provided a massage wearing only her thong panties. eniiiil 3 i scc Epstein had masturbated every time she provided a Massage. She stated Epstein continued to masturbate until he climaxed; once that occurred the massage was over. She felt the whole Situation was weird but she adyi she was paid $200.00 for providing the massage. She also stated received $200.00 for bring ae: Epstein. ete she had gone a total of 15 times to his residence to rewveee a Massage and things had escalated from just providing a GIUFFRE005662 CONFIDENTIAL TF i! bee bs odoyyee y nt ~ o eee a ee ee — SS ale eet) rete) shemeet =

Case 18-2868, Document 283, 08/09/2019, 2628241, Page646 of 883 me rrr re cc me eters ee eee eae ae Gee ets eee — eee eee ee Date: 7/25/06 . PALM BEACH POLICE DEPARTMENT Page: 50 Time: 8:47:53 Incident Report Program: CMS301L Case No. ... : 1-05-000368 (Continued) massage. Epstein began touching her on her buttocks and grabbed her. closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breast with his hands as she provided the massage. stated on one occasion, he offered extra monies to have vaginal ourse. . She stated this all occurred on the massage table. eubiiie. cc Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein on ee from her vagina and climaxed onto the massage table eceived $350.00 for her massage. I asked her if she had any formal training in providing massages Mocated she did not. GE cntinuea to state on one other occasion, Epstein introduced his ant, Nada, into the massage. Nada was brought into room with ee: provide a massage. Epstein had them kiss and fondle each other around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein introduced the large white vibrator/massager during the massage. Epstein stroked the vibrator/massager on vagina as she provided the massage. tated the last time she spoke with anyone at the was with Sarah during the weekend of October 2 or 3, 2005. stated she had brought two people to the Epstein house. : She provided the names of d (unknown las ould noted ad been previously identified as and had been previously interviewed. The interview was concluded and the videotape was placed into evidence via the locker system. On November 9, 2005, Sgt Frick and I traveled to a: Boynton Beach, Florida in hopes to interview Juan Alessi, the Oormer houseman of Epstein's home. As.no one was home, a busi eft for him to return my call. We then traveled to in Miami in hopes to interview Alfredo Rodriguez, a rormer house man of Epstein. We did not locate them at home. I left a business card for him to return my call. We then traveled to Lynn University and met with D tudents, Mr. Turner. We requested to speak with [RR as re interviewed, as she still was in possession of the rental car that Epstein had acquired for her. stated that Sarah, Epstein's assistant, had called her on her cellular telephone and informed her that rental was extended for her. Sarah stated she had paid a additional $625.00 for her to keep the rental an extra month. was asked if she had any additi ntact with either Epstein or anyone from his Sant el she did not, other than the telephone call informing her that she could keep the car for an extra month. | SERS not provide any additional information. On November 10, 2005, at approximately 9:47 am, Alfredo Rodriguez had telephoned reference my business card found on his door. Rodriguez stated the had worked with Epstein for approximately six months after GIUFFRE005663 CONFIDENTIAL — © Ot eterno. + eee

Case 18-2868, Document 283, 08/09/2019, 2628241, Page647 of 883 i i I ee i ie ee ee eee ee ee ee ee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: Si Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Continued) the previous houseman left. Rodriguez stated that it was his responsibility to keep the identity of the masseuses private. Mr. Epstein had a- massage in the morning and one in the afternoon. Mr. Rodriguez stated he would rather speak about this in private. He advised he would come to the police station to speak with me. Rodriguez stated he would return my call on Monday, November 14, 2005. I then made telephone contact with Juan Alessi. He advised he found my card on his door and wanted to know what I needed to speak with him about. I explained to Alessi that I was conducting an investigation on his former employer, Mr. Epstein. Alessi stated he would return my call shortly as he was in the middle of a project at his home. received a telephone call from Attorney Donald Morrell from | Mr. Morrell stated he represented Mr. Alessi and did not want me speaking with his client. I then made telephone contact with the State Attorney s Office and confirmed that subpoenas would be issued to the former employees to assist in the investigation. I then made telephone contact with Attorney Guy Fronstin, attorney for Mr. Epstein. I explained to’Mr. Fronstin that I would like to speak with Mr. Epstein. He stated Mr. Epstein is not in residence in Florida at this time and would check with him to ascertain if he could be here by Wednesday November 16, 2005 for an interview. Mr. Fronstin stated he would return my call should Mr. Epstein decide to come in to the police station for an interview. Investigation continues. KEKKREKKEKKKKKKEKKRKKKEKRERRERE NARRATIVE HQ KERR KKKREKEK KK EKEEKEKEREKE NA Reported By: RECAREY, JOSEPH 11/15/05 Entered By.: ALTOMARO, NICKIE A. 11/16/05 win 14, 2005, Det. Sandman and I traveled to in Loxahatchee, Florida and spoke with She was told of the ongoing investigation involving Epstein. advised she had gone to the house on several occasions. During a sworn taped statement, she advised she star xi one year ago and was brought by Siiliiiiiiaianiiaiiiiaiiia’ —_ stated i brought her into the house and she was introduced to a girl named Sarah. Once sh Sarah brought her upstairs into a master bedroom bathroom. | ee she met Jeffrey in the bathroom. He lay on the t e@ and picked the massage oils. She provided the massage, as he lay naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. st ad only been at the house approximately five or Six times. aid each time she went to the house she was notified by Sarah, Epstein's assistant, that Epstein was in town and would like her to work. stated she returned to the house and was again led upstairs by Sarah. She provided the massage, clothed. GIUFFRE005664 CONFIDENTIAL

_—— — = << Date: Time: _—— — =— EE sv ated on the last time she went to provide a — she Case 18-2868, Document 283, 08/09/2019, 2628241, Page648 of 883 ee mr mcm eee ieee Grrr mre cee ees ee te 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 52 8:47:53 Incident Report Program: CMS301L No. . . . : 1-05-000368 Continued) advised it wasn't really weird until later on. asked if she ever removed her clothing to provide a massage. stated it was not until the third time she went that she removea ner clothing. [RBBB stated she was notified by Sarah that Epstein wanted her to come to work. She arrived at the house and was led upstairs by Sarah. She started proyid: € massage when Epstein asked her to remove her clothing. removed her pants, shirt and bra. She stayed in her thong p d continued rubbing. Epstein. stein turned over onto his back and she rubbed his chest area, stated ‘was masturbating himself as she providing the massage. stated she believed he climaxed based on his breathing. She tew either the climax or the fact that he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. was notified by Sarah to come to the house and work. stated she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last. time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel as he entered the room to lie on the table. | stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was ina hur stated her boyfriend was in the car waiting for her. urther. stated that Epstein got upset, as she wasn't enjoying the massage. ‘She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. I asked her if she had any contact with Epstein's organization, she stated she received $200.00 from Western Union in Royal Palm Beach and Okeechobee Blvd as a Christmas gift. sed she had no formal training in provide any massages. lso stated she was sixteen years old when she first went to Epstein's house. At an ci, 4:22 pm, I made telephone contact i i= at She agreed to meet with me at a public place. suggested she come to the police station for an interview: ae not want to meet at the police station. I recommended we meet at the Palm Beach Gardens Mall in the food court area. She agreed and an appointment was made for November 15, 2005 at 5:00 pm at the food COurt. Investigations Continue. REKKKKKKRKKKKKKKKKEKKEKEREEEKE NRRRAT IVE Ho DQ REKKRKEKKKEKKEKKKEKKKKKKREKEK NA Reported By: SANDMAN, JENNIFER R. 11/16/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 On 10/20/2005, I assisted executing a search warrant at 358 El Brillo Way in the Town of Palm Beach, Palm Beach County Florida under the direction of affiant Detective Joe Recarey. GIUFFRE005665 CONFIDENTIAL S6at fete owe soe Snatien iinet Te ee SL EE TN RL NE Pome. #8 1 cet Oba Oe rs NR ee oes ee oe ee

Case 18-2868, Document 283, 08/09/2019, 2628241, Page649 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: aa Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Continued) Detective Melnichok and I searched the pantry room that is west next to the kitchen. . This room had all white cabinets with a dark) grey and black counter top. We did not find anything in this roon. We searched the yellow and blue room that is west next to the pantry room. This room had a very large statue of man with a bow. Taken into evidence from this room were nine photographs in frames of various women. We searched the main entrance foyer that is to the north of the yellow and blue room. This room contained two bamboo chairs and ottomans with cushions. It also contained a round table with numerous books. We searched another blue room that is west of the foyer. This room had a stereo system and book shelves that were from the floor to the ceiling. Taken into evidence from this room were eight photographs in frames of various women and/or Epstein, the owner of the residence. We searched the room to the west of the blue room that has Sliding glass doors that lead out to the pool. In this room in a dresser were two DVD's and two VCR tapes. These items were taken into evidence. We searched a 2004 black Chevy Suburban_bearing Florida tag X99-EGL, registered to Jeffrey Epstein DOB — which was located on the east side of the driveway facing south. I found a Thrifty rental agreement between the passenger seat and the middle co The name on the rental aqreement w= Shanna Sjoberg from en The phone number on the — a rented was a white The vehicle was rented on 9/25/05 at 17:58 hours and was returned on 9/26/05 at (16: 52 hours. The last four-numbers of the credit card used are Detective Melnichok found a piece of paper in the middle console that said I used the cash in here to fill up the tank and was signed by Johanna. I searched the 2005 black Cadillac Escalade ESV bearing Florida tag Q29-9GT, registered to Jeffrey Epstein dob QM which was located on the west side of the driveway facing south. I did not find anything in this vehicle. > All of the items that were taken into evidence were photographed in the place they were located and then turned over to crime scene. REEKKKEEKKEKKKKKKKKKKKKEREKEKE NARRATIVE HDL BEEK KKKKKKEKEKEKKERKEREREER NA Reported By: RECAREY, JOSEPH 11/17/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 GIUFFRE005666 CONFIDENTIAL ee ee ee ee orate

Case 18-2868, Document 283, 08/09/2019, 2628241, Page650 of 883 ee eee ee ee ee _—_—oeoeoroerorer rr rrr ee SS eee ee ee ee eee eee es Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 54 Time: 8:47:53 Incident Report Program: CMS301iL Case No. . .. : 1-05-000368 (Continued) ember 15, 2005, Det. Sandman and ee Royal Palm Beach. We met with : seventeen-year old juvenile who was not in scnooiL this day due toa cold from which she was suffering. as told that I needed to speak with her in reference to an ongoing investigation involving a subject she would know as Jeffrey Epstein. Prior to speaking with her, I explained that because of the fact that she is a minor, I needed to speak with her p Speaking with her. She telephoned her father, Mr. on his cell phone and explained to him that Det. Sandman and I were there to speak with her. I spoke with Mr. es <: the telephone and informed him I needed co his daughter in reference to an ongoing investigation. Mrs advised he had no problem with us speaking with his daughter. During a sworn taped statement, RE 5 ated she met Jeffrey Epstein over en. was sixteen years of age and was approached by who informed her that she could make monies med her providing a massage to Epstein for $200.00. that she would have to provide this: massage topless. e the arrange Epsteij is assistants and took to the house. a | Oe she entered through a glass door that led into a kitchen took her upstairs, to a master bedroom and master bathroom. She recalled the bathroom had a large pink couch, sauna and matching shower. Epstein entered into the room wearing only a towel. rn removed their clothing remaining only in thong underwear. She further stated that Epstein lay on his chest on the ae _——, selected which oils to use for the massage. Both iii REN ov iced the massage on his legs, back and 2 —_ fore minutes into the massage, Epstein turned over onto_his back = requeste Stairs in the kitchen 4 eee tructed to finish t As got dressed, starting rubbing his chet left the room, and Epste asturbating himself as rubbed Epstein s chest. stated he continued masturbating © until he climaxed on the towel he was wearing. When asked if he had removed the towel she. stated he turned the towel around so that the opening would allow him to expose hi After he cleaned himself off with the towel, he instructed age was done and to get dressed and met with him downstairs. got dressed and met with Epstein in the — She was paid 5200. 00 do providing the massage. stated she was aware chat (MM: 20 received monies for the same thing. econd time she went to the house she was again approached by sked if she wanted to return to the house to provide r massage; MMMM agreed and t ments were made by for her to return to the house. stated drove her to the house and knocked on the same glass door that leads to the kitchen area. They were allowed entry into the house by one of the staff members. NE ec her upstairs to the master bedroom and GIUFFRE005667 CONFIDENTIAL bree “e PS ale ot . oer ett Per. 8td.. <a -nenke so.

Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page651 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: Soa 8:47:53 Incident Report Program: CMS301L No. . .. : 1-05-000368 (Continued) master bathroom area. (i left pe this time to dot alone. Epstein entered the room again wearing only a —— began removing her clothing as she did the last time she was e house. Epstein instructed her to get naked. He lay on the table on his stomach as began massaging his legs and back. As HEMI finished with stein's back and legs, Epstein then turned over onto his back. ed to rub his chest and he began masturbating himself. As rubbed his chest, Epstein leaned over and produced a massager/vibrator. He turned it on and began S vagina and masturbating himself at the same time. stated she continued to rub his chest as this was occurring. She described the vibrator/massager as large, grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vib her vaginal area and concentrated on masturbating himself. ane... he climax e towel again and informed_her that the massage was done. ee dressed and met with who was waiting in the kitchen area. She received $200.00 for e massage. aid she nev ad to the house and had no desire to return to the house. ae: asked if she received any formal_massage training. sSne advised she had no formal training. a was asked if Epstein knew her real age. stated he knew as he asked her questions about herself_and high school. He was aware she attended and is still attending EE: <1, School. The interview was concluded. I suggested SAE inform her parents of what occurred at the Epstein house. tated she would tell her father as he was unaware this had occurred. I left my business card for any questions they may have. We left the area and returned to the police station. The tape was placed into evidence. Investigation Continues. KREKKKARAKKKKKKKKKKEKKRKKKREKKEE NARRATIVE DD REKKKKKEKKKREKEKEKEKKEKEKEEKKEE NA Reported By: RECAREY, JOSEPH 11/17/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 she had been at the Epstein house over fifty times. She On November 15, 2005, Officer Munyan and I responded to the Palm Beach Gardens Mall food court section to meet ie At a p.m., arrived and met with us at the food courte. provided a sworn taped statement in which she stated to Epstein's. house when she turned eighteen years old. asked if she knew of the on-going investigation. Stated she Was aware there was an investigation as she had been told by other Girls that were interviewed. Additionally, she has had several telephone conversations with Epstein's assistants as to what had been going on during the investigation. I asked [how she was introduced to Epstein. MMs atea she did not want to disclose who brought her to the house but she would GIUFFRE005668 CONFIDENTIAL nen Rameiiiedeeeien dt taedee ite a i i i ee ee,

—_—_— — — Date: Time: Case much she was paid each time she went to Epstein s residence. Case 18-2868, Document 283, 08/09/2019, 2628241, Page652 of 883 rr eee ee ee ee ee 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 56 8:47:53 Incident Report Program: CMS301L No. .. . : 1-05-000368 (Continued) respon other questions. When I asked her what happened at the chacigg | Pier) everything happened. It all began with the massages. Each time she went more things happened. She would massage Epstein and he would masturbate and climax. She stated things escalated from there. She provided oral sex on Epstein and he provided oral sex on her. She stated he would also use a | mMassager/vibrator on her vagina to stimulate her as she massaged him. He i uced his assistant Nadia or Nada to have vaginal intercourse with a She stated Nada or Nadia would utilize a strap-on (synthetic penis) to have intercourse with her. She was told to masturbate herself as Epstein and Nada had sexual intercourse. All this was done at Epstein's direction. could not provide exact dates as she had been to the house so many times. stated Epstein inserted his fingers in her vagina to stimulate her as she massaged him. When I asked her if there had been any vaginal intercourse with Epstein, she stated she did not have sex with him. She did admit having sex with Nada, his assistant. stated not every time she went involved sexual favors. Sometimes she would just talk with him and get paid. I asked_her how stated she got paid $300.00 every time she went to the house. She was told to bring other girls to him to provide massages. declined stating that she does what she does and did not want to introduce anyone else to do what she does. [MMstated she had never received any formal training in providing massages. I showed a photo line up in which Nada Marcinkova was placed in position six. She reviewed the six photographs and immediately identified Nada Marcinkova as the person with whom she had intercourse. Additionally, it was the same person she watched have intercourse with Epstein. She signed the photo line-up under Nada Marcinkova s photo as the person she identified. We then left the mall and returned to the police station. THe photo line up and tape were placed in to evidence. Investigation Continues... REKKKKHREKKEEEKEKEERKEKKEKER NARRATIVE H D> REKKKEKKERKEKEKKEKKEKEKEKKEEKEK NA Reported By: RECAREY, JOSEPH 11/29/05 Entered By.: ALTOMARO, NICKIE A. 12/01/05 On November 17, 2005, I received a phone message from Atty. Guy Fronstin who advised to call his cellular phone reference his client Jeffrey Epstein. I telephoned his cell phone and left a message for him to return my call. I did not receive a call back on-Thursday, November 17, 2005. On Friday, November 18 2005, I retrieved another voice mail from my work phone from Mr. Fronstin advising he would not produce his client Jeffrey Epstein for any statement. Fronstin stated he had spoken with ASA Lana Belohlavek and expressed Mr. Epstein has a passion for massages. I called ASA Lana Belohlavek and confirmed that GIUFFRE005669 CONFIDENTIAL 2 ee Sn 1 eS Reet ee eee Pe te rly Bes ee ae

Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page653 of 883 ee eee eee 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 57 8:47:53 Incident Report Program: CMS301L No. . . . : 1-05-000368 (Continued) Fronstin had telephoned her reference this case. Although nothing was discussed, Mr. Fronstin did advise her that Epstein is very passionate about massages. I also spoke with ASA Daliah Weiss reference the previous employees, Juan and Maria Alessi. She advised that they had been served through a subpoena process server. They were both scheduled to appear on Monday November 21, 2005 at 12:00 p.m. On November 21, 2005, I met with ASA Weiss, Atty. Donnie Murrell and Juan and Maria Alessi at the State Attorney Office. ASA Weiss had requested a court reporter to be present to take the statement of the Alessi s. I spoke with Maria Alessi, in the presence of her attorney, Donnie Murrell. She advised she had worked for Epstein for eight years, from the period of 1994 through 2002. She advised she had never had any direct conversations with him. She stated it was her husband who spoke directly with Epstein. Her work consisted of doing house cleaning, ‘shopping and other preparations when Epstein would arrive in town. Alessi stated the preparations consisted of preparing the house and bathrooms for his arrival. She advised she did view several masseuses that arrived at the house. She advised that two or three girls would come during a day and provide the massages. The girls that arrived looked young in age. Mrs. Alessi did not know any o£ the girls personally and were always different. She was told that when Epstein was in residence he did not want to encounter the Alessis during his stay in Palm Beach. I then spoke with Mr. Alessi in the presence of his attorney, Donnie Murreil. Mr. Alessi stated that he was employed for eleven years with Mr. Epstein. He originally was hired as a part time employee and then moved up into a full time position. His duties included everything. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. He remembered dealing with his girlfriend, Ms. Maxwell originally and then dealt with Epstein directly. I asked Mr. Alessi about massages that occurred within the home. Mr. Alessi stated Mr. Epstein had up to three massages a day. Each masseuse that visited the house was different. Alessi‘ stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years. of age at the most. The massages would occur in Epstein's bedroom or bathroom. There were times he recalled that he would set up the massage tables either in Epstein s bedroom or in his bathroom. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. Alessi was never privy to what went on during the GIUFFRE005670 CONFIDENTIAL 2s ls ee Antenne oe ee tne 2 eT, 6 ee Oe! 6 eee oh a epee ot me Fe ee a ae ee eee be Oe BO ee ee ee

Case 18-2868, Document 283, 08/09/2019, 2628241, Page654 of 883 ce ce me i ee eee ee ee eee ee es Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 58 Time; 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Continued) massages. He was asked if he remembered any names of the girls that massaged Epstein. He tried to remember and was unable to provide any exact names of any girls. Alessi was asked about any contact with anyone from the Epstein organization. Alessi said he did speak with Mr. Epstein shortly after my initial contact with him to find out what was going on. Alessi also stated that approximately on November 11, 2005, he was contacted by a private investigator from the Law Office of Roy Black. The investigator had called him to meet with him to ascertain what he was going to tell the police. Alessi stated they met at the Carrabba s Restaurant in Boynton Beach and discussed the same questions I was asking him. I informed Mr. Alessi and Mr. Morrell that as this is an ongoing investigation and anything we discuss should be confidential. They both acknowledged the fact that the information would be kept confidential. It should be noted that a court reporter was present during the interviews and would be providing a copy of the statements to me when they become available. On November 21, 2005, I received a voice mail from Mr. Fronstin who advised he would not be making Mr. Epstein available for any statements. He did have some words that he wanted to relay on behalf of Mr. Epstein. I telephoned his office and left a message for him to return my call. On November 29, 2005, I received a call back from Mr. Fronstin who left a voice mail after hours on November 28, 2005, advising he would return my call during normal business hours to speak with me reference the case on November 29, 2005. RREEKKKKKKEKKEKERKEKKEEEEREEKEKE NARRATIVE HDA REKAEKEKE KEKE KEKREKEKEKRERERE NA Reported By: RECAREY, JOSEPH 11/29/05 Entered By.: ALTOMARO, NICKIE A. 12/01/05 On November 29, 2005, at approximately 2:30 p.m. I received a telephone call on the department issued cell phone. Mr. Fronstin stated he was calling to relay information that Mr. Epstein wished he could relay. Mr. Fronstin stated that he would not allow Mr. Epstein to speak with me at this time. He further stated that Mr. Epstein is very passionate about massages. He continued that Mr. Epstein had allegedly donated over $100,000 to the Ballet of Florida for massages. The massages are therapeutic and spiritually sound for him that is why he has had many massages. Mr. Fronstin stated he appreciated the way the investigation has not been leaked out into the media. [I explained to Mr. Fronstin that it is as important to protect the innocent if the allegations are not substantiated. Mr. Fronstin was told of the allegations that the private investigators assigned to the case have been portraying themselves as police officers. . Additionally, I explained that my cell phone had been. called by the private ‘investigators. Mr. Fronstin advised he was not aware of that and advised they were under the direction of Attorney Roy Black in GIUFFRE005671 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page655 of 883 eee eee mmr ere ee eect ee meee ee ee ese eee eee es Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 55 Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Continued) Miami. Mr. Fronstin further stated Epstein had originally called mr. Dershorwitz in Boston, who recommended Roy Black in Miami, who asked Mr. Fronstin to assist. I informed him that if and when any charges would be presented I would notify him. The call was then terminated. Investigation continues. KEKRKKKKKEKKEKEKKEKKEEKEEEKERER NARRATOIVEA D5 RHEE EKEKKEKKKEKEKEREKKKES NA Reported By: RECAREY, JOSEPH 12/15/05 Entered By.: ALTOMARO, NICKIE A. . 12/16/05 A review of the telephone message books, which were obtained during the search warrant, was conducted in which various messages from different dates were made to Jeffrey Epstein. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages was time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the body of the messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken by Sarah for Jeffrey Epstein. Based on the context of the body of the messages, I requested subpoenas for subscriber information on the telephone numbers and the time frame involved. Copies of the messages were made for evidentiary purposes. I obtained QE 3ch school yearbooks for 2005, 2004 and 2003. I first reviewed the 2005 yearbook and loca girls I had spoken with. Additionally, I located Based on the corrected name spelling, I was able to locate her to her residence in Loxahatchee. On December 8, 2005, De responded to aS a IT locate e her home. She advised she is attending High and is participating in the early release program so she can maintain her part time job. As she is still a minor, I left my business card to have her mother return my call to request an interview with her daughter. We then left the area. I aiso had Seer researched the telephone number for IE ana telephone number A subpoena had been issued for the information on The telephone number was registered to A ery of aE ae a er of ad is currently residing at est Palm Beach. Det. Caristo and I attempted contact with with negative results. I left my business card on her front door requesting she return my call. We then responded to IT also attempted contact with with negative results. I left my business card for him to return my call. GIUFFRE005672 CONFIDENTIAL 4 Oe a. eee acts o eyere: 8 1 Rl hee p+ se tree te re rt i rere ae wee ‘ete i ee eS meals wien = + ya te

Date: Time: Case 18-2868, Document 283, 08/09/2019, 2628241, Page656 of 883 seme ee recreate rm gree rr eee Er te teem rer yt rey GH se cs et ee 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 60 8:47:53 Incident. Report Program: CMS301L No. . . . : 1-05-000368 (Continued) 2005, I received a telephone call from s mother, who was made aware of the on going investigation in Palm Beach. advised she was told of everything that occurred at Epstein's house involving Epstein and his staff. She advised she would allow me to question her dau — about cellular telephone number to schedule an what occurred and would cooperate with the investigation. provided me wit appointment for an official interview. I telephoned her cellular telephone and made a tentative appointment for Monday, December 12, 2005. I_then received a telephone call from , Lather of Po who stated he found the business card on his door. I explained that I was conducting an investigation and needed to speak with Bhs she m information that could assist in the investigation. Mr. tated that his daughter no longer resides with him and has he iler in another trailer park. He advised he would tell her to call me. On December 12, 2005, with schedules, arrangements due to Li were made to meet — Tuesday, December 13, 2005 at 5:00 pm. On December awson and I traveled ‘to eins During a sworn taped that when she was sixteen years was Loxahatchee and met with statement, stated taken to Epstein's house to provide a massage stated it was before Christmas last year when her and asked if she needed to make money for she did and agreed to provide a massage for money. arrangement ke o the house and drove to the house to "work." tated she could not remember the street name but would be able to drive to the street. They drove to the last house on the street and pulled in the last house on left side. They walked up the driveway and entered through a side gate which led to a kitchen door. Milibicccribe on the door and were encountered by an employee who escribed as a "Spanish looking lady." They informed her that they were expecte were then encountered by a white female with long blond hair. was unable to remember the name of the white female with biond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there wOuld be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom_and bathroom. The massage table was already set up in the bathroom.| escribed the bathroom as a large spacious bathroom with a steam room and shower beside it with a sink to the Fa-Ge . as introduced to Jeff who was on the phone when she a Was wearing a white towel and lay on his stomach so that ay massage his feet and calves. tarted the massage with the massage oil Jeff chose and rubbed his feet and calves. Jeff got off the phone and requested she massage his back as well. (RRRMMMJbegan rubbing his back and got to the small of his back. During the rubbing of his back Jeff asked her to get comfortable. He GIUFFRE005673 CONFIDENTIAL a ee ee . ee Ae RL FI Eh AIR ne ee lle lh

—— -— Date: Time: —_—— awe Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page657 of 883 we me ere ree et te ete ee meee rrr ee er ee ee ee ee a 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 61 8:47:53 Incident Report Program: CMS301L No. . . . : 1-05-000368 (Continued) requested she remove her pants and shirt. _ removed her shirt and pulled her pants off. stayed in her bra and thong panties. As she finished the. small : back, Jeff then turned onto his back. He instructed she rub his chest and pinch his nipples. As she to rub his chest, Jeff asked occ rn. remembered telling him she attended — School. Jeff.asked her if she was sexually active. Before a answer, he also asked what sexual positions does she enjoy. KKK NA tated she was shy didn't like talking about those things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front. (NE -Leinec the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. aid "no, I don't like that." Epstein oved his towel and lay on the bed naked exposing his penis :> lll He began touching his penis and masturbated as he touched her breasts. xplained Jeff then touched her vagina area by rubbin ina with his fingers on the outside of her thong panties. ensed up and stated Jeff was aware that she was uncomfortabie. stated that Jeff told her , "Relax, I'm not going inside." She Turchner explained Jeff commented to her how beautiful and sexy she was. Jeff then moved panties to one side and now was stroking her ics, "Jef£ commented how hard my clit was." He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina. Jeff removed his fingers from within her vagina and apologized for putting his fingers inside her. Dur} time he kept his hand on her vagina area rubbing her vagqj stated he rubbed her real hard as he was masturbating. Said ne climaxed onto the towel he had been previously wearing and got up from the table. Jeff told her there was $200.00 dollars for her on the dresser within the master bathroom. Jeff als er that there was an additional $100.00 that was to be given co lll = bringing her there to massage him. Jeff told her to leave her telephone number with his assistant as he wanted to see her again. Jeff stated his assistant would contact her to work again soon. is her if she ever received any formal massage training to which stated she did cae cates it was the only time she ever went to work for Jeff and kne happened to her was wrong. She stated she no longer speaks to because she was upset that took her there. She further stated that she had never been contacted for any additional work. The interview was terminated and we left the area. Investigation Continues... KHKKKKKKKEKREKKKRKEKEEKEEE NARRATIVE: fH QO FHKKEKRKREKKERKEKEKEKEEKREKKES Reported By: DICKS, ALLEN C. 12/18/05 Entered By.: ALTOMARO, NICKIE A. 12/19/05 GIUFFRE005674 CONFIDENTIAL Ee ee eet

"~~ _— — | Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page658 of 883 eee weeweer wee ee a2 e2 ete ae Se BO O@ 2 FF Se we SF ese ZF ese Se rere vwuenwew eee 22 ew WO eS ese VF oO Maeq2aeaoa “2°24 7/25/06 PALM BEACH POLICE DEPARTMENT : Page: 62 8:47:53 Incident Report Program: CMS301L No. .. . : 1-05-000368 (Continued) On 102005 at approx 0930hrs I assisted with the execution of a search warrant at 358 El Brillo Ave, Palm Beach. Initially I was assigned to enter the residence and conduct a sweep of the premises for safety purposes. I then accompanied CSEU tech Pavlik while she photographed the exterior of the house. Once this was complete I was assigned to search certain areas of the house with Det. Dawson as part of the search warrant. We began in the garage, searching three Mercedes Benz vehicles, a Harley Davidson motorcycle and adjacent closets in the garage. Nothing of evidentiary value was located. | We then searched two closets off the kitchen area on the east Side. These can best be described as pantry or storage closets. Nothing of evidentiary value was obtained. A small office with adjoining bath was then searched. In the bath area I located a phone message book with recent messages. This item was seized as evidence. Please note this bath and shower area are not used as designed but are storage areas containing a variety of items to include a gun safe in the shower and assorted household items. We then searched a bath area and closet at the base of the main stairs in the foyer. Inside the closet two massage tables were located as well as partial nude female photographs. These items were later seized as evidence. Nothing of evidentiary value was noted in the bathroom. We then searched two bedrooms upstairs on the east side of the residence. Located in the bath room of the south bedroom was penis shaped soap. Located in the bedroom of the northern bedroom was penis and vagina shaped soap as well as an adult sex toy. These items were seized as evidence. We then searched the pool cabana located in the south west corner. of the property. Several photographs of nude females were seized as evidence. I was then assigned to stand by with a person I believe. was Douglas Schoettle. Mr. Schoettle was in the residence at the beginning of the search warrant. He was present during the warrant service and subsequent search. I stood by with him until the search was completed and I departed the residence. I had no conversation with him regarding the reason for our presence. -Regarding seized evidence, all items were photographed in place and then collected by CSEU personnel. This concludes my involvement in this case. GIUFFRE005675 CONFIDENTIAL - —T St ctee meee com <a ony Ramee mer ale rt ge es ethereal ee. ek Estee whe MARIN ee phe 9 idewiee Cerin dttn sd) wiht ttoke Apmnt i talabice. aie -g tom = 5 weed sO

Case 18-2868, Document 283, 08/09/2019, 2628241, Page659 of 883 . ——_— a ee et ee ee ee me ee am cee ee me ee se yy) ee Se eae ce eee ee a ae Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 63 Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Continued) RRKKKKKKHEKKKKKERKHAEKEKEEKEKEEE NARRATIVE HDT RRRKREKKKEKKKEKERERKRK KEKE KEKE NA Reported By: KRAUEL, CURTIS D. 12/21/05 .Entered By.: ALTOMARO, NICKIE A. 12/21/05 On Thursday, October 20, 2005 at approximately 0936 hours, I assisted in the execution of a search warrant located at 358 El Brillo Way, Palm Beach, Florida, residence of Jeffrey Epstein. I was instructed by Case Agent Det. Joseph Recarey, to secure all computer and media related material from the residence. Upon my arrival I was directed by Det. Recarey to a room designated as the Kitchen Staff Office. I observed a, Silver in color, CPU with the left side cover removed, exposing the CPU s hardware sitting on floor next to a glass type desk. The CPU had no discernable identifiers or features indicating a make or model. This CPU was powered off with the power cord not plugged in. The keyboard and mouse were atop the CPU. It should be noted that the CPU was not connected to a monitor, printer, or other media device, On the back Panel of the CPU, I observed an A/V card with RCA jacks attached. This type of hardware would allow audio and video to be downloaded onto the CPU s hard disk. The ends of the RCA jacks were unattached at the time of the search and no external camera was located within this room. The CPU was located on the right side of a desk that held a flat panel LCD screen. The desk also held another keyboard and mouse, indicative of a second computer; Rowever, no other computer was found. It appeared as though a second computer had been recently removed as the cables ends from the monitor, keyboard and mouse were in the same area. A further search of the room revealed no media storage devices, i.e. CD s, Floppy Disks, Zip Disks, etc. This type of media is commonly stored in an area where computers are placed, yet no media was found. After completing a search of this room, I secured the CPU and turned all items over to the Evidence Custodian for future forensic analysis via a property receipt. I was then directed by Det. Recarey to a room designated as the Garden Room, where I observed a wooden desk facing west. The desk held a flat screen LCD monitor, keyboard, mouse, media card reader and printer; however, no CPU was located. All of the cables were removed from an area where a computer had once been. A search of the desk area revealed no signs of any media devices. Det. Recarey directed me to a third location designated as the Cabana room, which is detached from the residence and located just south of the pool. In the South East corner of the room, I observed an office type setting, with an L-shaped desk holding a flat screen LCD monitor, keyboard, mouse and printer; however, no CPU was-located. All of the cables were removed from an area where a computer had once been. A search of the desk area revealed no signs of any media devices. GIUFFRE005676 CONFIDENTIAL tate mame man mee Se 8 mig ey ite le tees at aeeedlh senihenw mene om + Or) hem ee ee - terre eee we

—— eS Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page660 of 883 -_——— ess ww we ww Se ew Ss Ss ee ee ee rr er ee Or ee ee ee ae oe ee ee ee ee we ee oe ee ee ee ee ee ee ee ee we ee ee ee a ae oe oe oe Oe ee ee es 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 64 8:47:53 Incident Report ._ Program: CMS301L No. .. . : 1-05-000368 (Continued) Det. Recarey directed me to a second detached structure located on the South East corner of the property. This area of this structure was assigned with single letters to identify a particular part of the room. In the office area, designated as Room B, I observed a powered on Dell Dimension 2350, attached to an LCD flat panel monitor. The screen displayed an open Microsoft Internet Explorer browser with URL address of http://home.bellsouth.net/. I observed no other active windows in the Start panel window and photographed screen. The power cord was removed from the back of the Dell CPU and I disconnected the cable modem to prevent remote access. At that time, the Dell CPU, marked with Serial. Number 6WTVN21, was secured and turned over the evidence custodian for future forensic analysis via property receipt. I also located several media related items within Room B, which were recorded onto a property receipt and turned over the Evidence Custodians. I then responded to a Bedroom designated as Room F, where I observed a white in color CPU marked Premio. The Premio CPU was in a computer desk which held a white CRT monitor, both of which were powered on. The CRT monitor displayed a message from Norton Antivirus software, warning of an expired subscription. I observed no other active windows in the Start panel window and photographed screen. I removed the power cable from the back of the Premio CPU and shutdown all other ‘media. The Premio CPU, marked with Serial Number 2000091078, was secured and turned over the evidence custodian for future forensic analysis via property receipt. I also located several media related items within Room F, which were recorded onto a property receipt and turned over the Evidence Custodians. This concluded my participation in the search of the residence. RKKKKKKKKKEKKKKEKKKERKEKEEKEKEK NARRA TI V BE of QQ KEKE EKKEKEKKKEKKKKKE KKK NA Reported By: RECAREY, JOSEPH 12/21/05 Entered By.: ALTOMARO, NICKIE A. 12/21/05 On December 20, 2005, I contacted ASA Daliah Weiss in an attempt to subpoena the Epstein former houseman, Alfredo Rodriguez: Rodriguez, who resides in Miami, had eluded the process servers previously and was not served the investigative subpoena. A telephone message was left as she is not available during the week of 12/19/2005. I made contact with State Attorney Inv Theresa Wyatt and requested the same via telephone message. I then researched the victim's SG cellular telephone subpoena data which had been received from a previous subpoena request. I analyzed the records which depict several calls from Haley Robson: The telephone calls start on February 6, 2005 at 12:49 pm.; the same day which the victim and the victim's father stated the incident occurred at Epstein s irst incoming call was from Robson's residence at The second incoming call from Robson's GIUFFRE005677 CONFIDENTIAL Le ee er oo hat ceo temas samy, se ee

Case 18-2868, Document 283, 08/09/2019, 2628241, Page661 of 883 —_—_— =e ee OF FT Fe SE TF SSE Se eww SE SI eS Se Se ew FS SS See ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee oe oe ee ae a eee oe oe a Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 65 Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 The telephone calls revealed Lavery had telephone contact with iii CUR ine: just acter t actemred to interview em, Or just prior. ackground was conducted on Lavery i i ee I ee ——_ = (Continued) cellular phone occurred at 1:02 pm. The call durations were one minute or less. The time frame was within thirteen minutes apart. It should be noted that Robson s residence was in close proximity to the victim's. The next call occurred at 5:50 pm when the victim telephoned Robson s residence. Several calls were made after the above mentioned calls both incoming and outgoing to Robson. Further analysis showed no telephone calls to either Robson's cellular telephone or Robson's residence were registered prior to February 6, 2005. I also conducted an analysis on the telephone calls from The subscriber information confirmed that the number is registered to Paul A Lavery from Hialeah, Florida. The address was crossed referenced to the Office of Kiraly and Riley Private Investigators. I researched the web page www.rileykiraly.com which also showed various cases in which they assisted. I also located another web site under www.coralspringssparklandrotary.org in which Mr. Riley attended a Miami Rotary meeting and confirmed Atty. Roy Black is among his clientele. Additionall which revealed he holds a current Private Investigator License. A criminal arrest record revealed he had been previously arrested for possession of cocaine and solicitation of prostitution. I also researched the girls using www.myspace.com. This web site is a new social networking service that allows members to create unique personal profiles online in order to find and communicate with old and new friends. The site allows one to establish your own myspace.com page and decorate the page any way one wishes. I found the followin Rob eople have myspace sites: I received a Cingular Wireless packet which contained a CD which contained the results of the subpoena request for verbatim calls on An analysis will be conducted in the near future on the phone numbers called. Investigation Continues. KKEKEKKKRKEKKKKAKAKEKEKKEKKEKERK NA RRA T-IVE fo QQ KKK EKKKEKEKKEK EK KEKEKEREKEEE NA Reported By: RECAREY, JOSEPH 12/27/05 Entered By.: ALTOMARO, NICKIE A. 12/29/05 Upon doing research on the message red in the search Warrant, I located the identity of as registered to seventeen years old and is attending the GIUFFRE005678 CONFIDENTIAL

Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page662 of 883 ee er ee me cree re eee rem ee eee 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 66 8:47:53 eee Report Program: CMS301L No. . . : 1-05-000368 (Continued) responded to 1801 Palm Bea evard, also known as the Palm 11. I located che MMIII ccna ion. I located inside the foundation and intormed her that I was investigating a case against Jeffrey Epstein and knew she had been at the house. MN scarted to cry and advised she had put that part of her life behind her. I explained that although she is seventeen years old I needed to inform her parents that she would be interviewed. She provided her home telephone number. I attempted contact and left voice mail messages at the house to speak with her parents. Det. Caristo and I then located ae ... her residence located at mn West Palm Beach. I-attempted to interview her FS C;ssCisT about Jeffrey Epstein. She advised she is so in love with Jeff Epstein and would do anything for him. She further explained that she would not speak with us about him either negative or positive. She asked us to leave her property. I informed her that although she did not wish to speak with us, I had sufficient information at this point in the investigation to know she was at Epstein's house and provided girls to Epstein to work. I also explained that prior to at her residence I had telephone contact with h who was told she would be interviewed. y seventeen years old and as a juvenile, parental notification would be required. We then leff the area and returned to the police station. the police station, I left another telephone message for parents. I began ana ah Kellen's Cellular telephone. The telephone number is assigned to Sarah Kellen and the financially respons @ party is Jeffrey Epstein of 457 Madison Ave. in New York City, New York. The time frame which was subpoenaed was September 2005, through October 2005. There were eighty seven pages of calls made either to the cell phone or from the cell phone. The local (561) numbers were analyzed. A spread sheet was prepared and placed into the attachment file of who was called. The unknown numbers were researched using FoneFinder.com and subpoenas were requested to determine subscriber information. This was done to identify additional victims or witnesses. The analysis revealed that Kellen had called the victim/witnesses frequently when Epstein was in the Town of Palm Beach to "work." This confirms what the girls interviewed had previously stated. Kellen would notify them when Epstein was in town and their willingness to "work." The CD was placed into evidence. Investigation Continues. KKKEKKEKKKEKEAKKKEAKERAKEKEEER NARRATIVE HQ BRK EKHR KHER KKREKEKKKKEKEKER NA Reported By: RECAREY, JOSEPH 1/03/06 Entered By.: ALTOMARO, NICKIE A. 1/03/06 On December 29, 2005, I received a facsimile from National Compliance GIUFFRE005679 CONFIDENTIAL —~ eines oa ee ene pp ERES 8 hae WOVE CORR. eee oo tee + a et ll ele ctype oe —* Ne ee RS he od ihe ected e Sree mete se di etd meets

Case 18-2868, Document 283, 08/09/2019, 2628241, Page663 of 883 = a= a Ge oe ee tee emer es ety ere mem ey eee ee ee a ee ne Ge es Se es Ge Me ae Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 67 Time: 8:47:53 Incident Report | Program: CMS301L merece ee eee ee ee ee ee ee eee ee ee Case No. .. . : 1-05-000368 inued) Center from Cingular Wireless for telephone number - This was the in, number for Haley Robson during the time frame. when the victim, was brought to the Epstein house to "work." An analysis of the phone records, of all incoming and outgoing calls, ! showed that on February 6, 2005, the day. the victim, was brought ; to the house, Robson first called Sarah Kellen, Epstein's assistant, at t 12:50 pm (EST). The next call was made to Epstein's : house in Palm Beach, at 12:52 pm (EST). The following call was made to the victin at 1:01 pm (EST) and at 1:02 pm (EST). This confirms the information provided by the victim and victim's father. I photo copied the records and enlarged the page 8 of 10 to show the calls made by Robson on February 6, 2005. To this date, I have not heard cron [ie parents. [I | will attempt to establish contact wititmei uucaug cue evening hours. } I received a package from Atty. Guy Fronstin,; which was hand delivered at the police station. Within the package, was a letter | from Alan Dershowitz, and two www.myspace.com profiles. The profiles were that of and ne MySpace.com is a social ! networking service that allows members to create unique personal profiles online in order to find and communicate with old and new friends. This package was in response to a previous meeting in which Mr. Dershowitz called to assist in the investigation in providing any additional witnesses such as house employees who have been reluctant to speak with law enforcement. I reviewed the profiles Mr. Dershowitz enclosed. her blog to be a still attends High School, sends and receives messages from friend : some profanity. Upon reviewing her friends' comments section from : Myspace, most of her good friends sent messages to establish contact and invite her to go out. | I then reviewed s web blog whic ided by Mr Dershowitz. Ms. her blog to be ! " Her blog states that her interests include music, theater and weed (Marijuana). I reviewed her packet in which MMMdeclares her love for her live-in | a She also describes using marijuana with her boyfriend P| The letter Mr. Dershowitz sent advised he was looking into the allegation that one of the private investigators used by the private attorneys of Epstein, attempted to impersonate or state that they were police officers from Palm Beach z advised that the i investigators used to interview had "quite a distinct speech impediment", did not claim to be nor did they impersonate themselves as a police officer. This package was sent to both ASA Lana Belohlavic and ASA Daliah Weiss at the State Attorney's Office. I made telephone contact with ASA Weiss to confirm she received the package and request an interview with Sarah Kellen, Nada Marcinkova, and Janusz Banasiak. She advised she would assist in attempting to GIUFFRE005680 CONFIDENTIAL

Date: Time: Case KEKKKKKEEEEKEEEKKKKKKKKEKREEEE NARRATIVE NA Case 18-2868, Document 283, 08/09/2019, 2628241, Page664 of 883 ee me meee ctr cece Ee mets ee — — ee ee ee 7/25/06 PALM BEACH POLICE DEPARTMENT | Page: 68 8:47:53 Incident Report | Program: CMS301L No. . . . : 1-05-000368 (Continued) contact Mr. Dershowitz. On January 3, 2006, I received a telephone call from ASA Weiss who informed me that she made telephone contact with Mr. Dershowitz. She had requested the employees be available the week of January 3, 2006.” Mr. Dershowitz informed her that the assistants are out of the country and would require additional time to locate them and make them available. Investigation Continues. ZL EKER KERR EEKEKEKEKEKEEKRE KEKE EKE Reported By: MINOT, LORI S. 1/03/06 Entered By.: ALTOMARO, NICKIE A. 1/03/06 On Thursday, 03/31/05, I started conducting surveillance at 358 El Brillo. At this point I observed at 1155 hours, a_Tan Altima bearing FL tag MMMM n Roadway, bearing FL tag | in drive, Tan Honda Civic bearing FL tag in Roadway, Black Chevy Suburban in driveway and a Black i in driveway. At 1325 Hours I observed Tan Honda Civic in roadway, Black. Chevy Suburban in driveway, Black Caddy Escalade in drive and a White Kia car bearing FL eng At 1615 hours I observed a Tan Honda Civic, Aine ; 7 roadway, Black Chevy Suburban in drive, Black Caddy Escalade in driveway and a White Kia car ae roadway . On Friday, 04/01/05, I continued surveillance at 358 El _Brillo. At 1130 hours I observed a Tan Honda Civic bearing FL tag in roadway, Black Caddy Escalade in driveway and a Tan unknown: make/model bearing FL ta n roadway, At 1227 hours, I observed a Tan Honda Civic oadway, Black Caddy Escalade in driveway and a Black Chevy SUV Located behind the Escalade. At 1345 hours, I observed a Tan Honda Civic QRMMIn roadway and a Black Chevy SUV in driveway. At 1558 hours, I observed a Tan Honda Civic Pe roadway, Black Chevy SUV in driveway, Black Caddy Escalade in driveway and a dark unknown model/make car parked in garage. illo. At On Saturday, 04/02/05, I continued surveillance at 3 0713 hours, I observed a Red Explorer bearing FL cas a roadway and a Black calade in driveway. At 0814 hours, served a Red explorer MMMM coaavay, Black Caddy Escalade in driveway and a At 0952 hours, I observed a Red Explorer Tan Honda Civic in roadway, Black Caddy Escalade in driveway, Tan Honda Civic in roadway and also a Grey unknown make/model with a B.M in trunk retrieving landscaping tools. At 1155 hours, I observed a Grey Camaro bearing FL tag parking in the roadway in front of 358 El Brillo. A W/F, blond hair, teens to early 20's, thin and tall wearing a white tank top and short blue jean shorts, exited the vehicle and w to the rear of the house... also observed a Red Explorer in roadway, Tan Honda Civic a in roadway and a Black Caddy Escalade in driveway. At 1310 hours, I GIUFFRE005681 CONFIDENTIAL tt nate EY LEE de. le eens le eee ee derite dares ee. © ee Or ey ms nate Be bien ot qepeemene! 5... et CO TT es tee neeree hae rune

Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page665 of 883 ese ewe eee eee ee eee ee ewe eS Oe ee ee ee ee ee Se ew 68 eee ee oe ew ee i eee i es es ee ee es 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 69 8:47:53 Incident Report Program: CMS301L ——= Fe ee eee wee ew ST See eS ee ee eee ee SS Se ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee ee oe ee a a ae ae oe fe oe oe ee oe oe ob oe No. ; . . : 1-05-000368 (Continued) observed a Red Explorer W/F driver le e area, Tan subcompact on roadway and a Red Neon bearing FL tag Then observed 3 W/Fs, approximately 16 to 18 years of age jogging. All 3 females ran into the driveway. There were 2 with blond hair and one brown hair. On Sunday, 04/03/05, I continued surveillance at 358 El Brillo. At 0719 hours I observed a Tan Honda Civic Jin roadway and a Black Caddy Escalade. At 0934 hours, I observed a Tan Honda Civic n roadway and a Black Caddy Escalade_in driveway. At 1057 hours I observed only the Tan Honda Civic On Tuesday, 04/05/05, I continued su at 358 El Brillo. At 1052 hours, I observed a Red lorer n roadway, a Green Explorer, bearing FL tag in roadway, a Grey Altima bearing FL cag in roadway, White Ford Truck as: . roadway, Black Mercedes in driveway being washed by a B/M and.an unknown dark car parked in the garage. At 1059 hours a Blue Chevy Suburban drove to the house of 358 El Brillo and = (2 the driveway. At 1119 hours, I observed the White Fort Truck leave the area and the drive was the pool man. At 1126 hours, I observed a Grey unknown make/model car park in roadway. W/M got out of the car and walked to a house on the south side of El Brillo. At 1406 hours, I observed a Red Explorer parked on roadway and a large white box truck parked behind the surveillance suburban. KREKKEEKRKEEEKRKEEEERKEEEKERRKRKEKKER NA RR RATIVE # 3D BREE KKEKKEKKKKKEKRKRKKEKKEEE NA Reported By: BATES, MICHAEL J. 1/03/06 Entered By.: ALTOMARO, NICKIE A. 1/03/06 On 03/31/05, at approximately 1500 hours while conducting surveillance at 358 El Brillo, I observed a Black Cadillac Escalade, unknown tag, a Black Chevrolet Suburban, unknown tag, a Black Mercedes S600 FL tag GS parked in the east driveway next to the 3-car garage. There was a Tan Honda Civic FL tag oarked on the street in front of the residence. At approximately 1700 hours, I observed the Black Suburban, Black Escalade, Black Mercedes and Tan Honda Civic parked in the same place. At 1750 hours, there was no change in vehicles. At 1840 hours, I observed the Black Escalade, Black and Black Mercedes along with a Silver Hyundai Accent FL ta all parked in the east driveway and a Red Ford Explorer FL parked on the street in front of the residence. At 2000 hours, I observed the Black Escalade, Black Suburban parked in the ease driveway and the Red Explorer and Tan Civic parked on the street. On Friday, 04/01/05 at approximately 1700 hours, I observed the Black GIUFFRE005682 CONFIDENTIAL i ee a. omy

Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page666 of 883 aan = @ wee ew wesw ews woeowe ase S- S aee eee ee ee lO ee ee Se leer ler eee er ee eee eee ee ee ee eS ST ae eee eee ee eee eee ee ee oe 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 70 8:47:53 | Incident Report Program: CMS3011L No. . . . : 1-05-000368 7 (Continued) Escalade and Black Suburban parked in the east driveway and the Tan Honda Civic parked on the street in front of the residence. At 1820 hours, I observed the Suburban and Civic in the same place and a Gold Chevrolet Camaro FL tag (RM parked on the street in front of the residence. At 2250 there was no change. At 2330, I observed the Black Escalade parked in the driveway and the Red Explorer parked on the street in front of the residence. On Saturday, 04/02/05 at approximately 1700 hours, I observed a Black Escalade, unknown tag, parked in the driveway and a Tan Honda Civic FL tag arked in the street in front of the residence. At 1805 hours the Escal Civic were in the same position and the Black Mercedes FL ta was also parked in the east driveway. At 1920 hours the Escalade and Civic were the only vehicles and both were in the same position. At 2030 hours and 2145 hours there were no vehicles observed. At 2115 hours, observed a Black Mercedes, 4-door parked in the east driveway FL tag At 2300 hours, 2350 hours and 0045 hours, the Black Mercedes was the only vehicle observed. KREKKKKEKEEKEKKKKEEEKEEEKEEKEKE NA RRA TIVE # 33> KKEEKKKEKEKEKKEKKEKKEKKEEKKEKEE NA Reported By: RECAREY, JOSEPH 1/05/06 Entered By.: ALTOMARO, NICKIE A. 1/05/06 I made contact with Mr. father of ; who was told that I wished to interview his daughter. ; stated he was aware and had spoken with his daughter about e- ) incident. He stated that his daughter had previously told hi she was hired to model lingerie at a Palm Beach mansion. Mr. stated he knew nothing else about what she did when she went to "work." Mr. advised he would cooperate with the investigation and make his daughter view, MMM scatec sie I asked if she was available for an interview,. stated she was not at home at the mom T informed him I. wou make contact with her at a later time. SO his interest in the resolution in this matter | as he stated this information has affected his daughter emotionally. On January 4, 2005, I acquired the subpoenas from the State Attorney's Office for Cingular Wireless, Metro PCS, Verizon, Bell South Telecommunications and Sprint for the unknown telephone numbers from Sarah Kellen's cellular telephone. The subpoenas were sent to the respective telephone carriers for subscriber information. I received a telephone call from State Attorney's Office, who informed me that the former houseman for Jeffrey Epstein, Alfredo Rodriguez, was present at the State Attorney's Office for an interview. Rodriguez was issued an investigative subpoena for an interview on the on-goings at Epstein's house during his employ. I responded to the State Attorney's Office and encountered Mr. Rodriguez waiting in the lobby. I brought Mr. Rodriguez to the interview room. GIUFFRE005683 CONFIDENTIAL ee teeta amie alien eee ee ee Se ee ee Te ew Ree wee: tee) fre tee on NS A ee het Sb dee nee —— ee eee ee

Date: Time: —— Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page667 of 883 ce eer mm mre me eee rer emer mem tee ee ee ee 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 71 8:47: 53 Incident Report er CMS3 01L No. .. . : 1-05-000368 (Continued) During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months. He was referred by associates and his employment lasted the months of November 2004 through May 2005. His responsibilities as house manager included being the butler, chauffer, chef, houseman, run errands for Mr. Epstein and provide for Epstein's guests. Rodriguez advised he had very limited contact with Mr. Epstein. If Rodriguez needed to relay a message to Mr. Epstein, he would have to notify Epstein's secretary "Leslie" in New York City, who would then notify Epstein's personal assistant, Sarah, who would relay the message to Epstein. Rodriguez stated Epstein did not want to see or hear the staff when he was in residence. I asked Rodriguez if Epstein received many guests during his stay in Palm Beach. Rodriguez advised he had many guests. I asked specifically about masseuses coming to the house. Rodriguez stated he would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either Sarah or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen area and offer them something to drink or eat. They would then be encountered by either: Sarah or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. He advised he didn't ask their ages but felt they were very young. Rodriguez stated they ate like his own daughter who is in high school. Rodriguez stated they would eat tons of cereal and drink milk all the time. Rodriguez stated the girls that. would come appeared to be too young to be masseuses. He st er Epstein's direction, he delivered a dozen roses to High School for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the . massages: He felt there was a lot more going on than just massages. He would clean Mr. Epstein's bedroom after the alleged massages and would discover massager/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's bed. Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, so that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez referred himself as a "human ATM machine" and was ordered by Epstein to maintain a minimum balance of $2,000 dollars on him at all times. When a girl would come by the house and Mr. Epstein was either not in residence or ‘was not at home at the time, Rodriguez was to provide the girl (masseuse) several hundred dollars for their time and to notify Epstein the amount they were given. Epstein also ordered Rodriguez to GIUFFRE005684 CONFIDENTIAL ~ mee, one 1a ke ee OF eee me ee tet

Date: Time: Case KEKEKEKEKRKEEKKKKEKEKRKEKEKKEKEKEERE NTR R RAT IVE NA Case 18-2868, Document 283, 08/09/2019, 2628241, Page668 of 883 i et i i I i i eee en 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 72 8:47:53 Incident Report Program: CMS301L No. . . - : 1-05-000368 (Continued) purchase agave gifts and provide them as tips to the girls. I asked what kind of gifts: Rodriguez stated he purchased IPODS, jewelry, anything the girls would want. Rodriguez stated the amount of girls that came to the house was approximately fif girls knew each other and all seemed to know =: iil: School who Mr. Epstein was. When asked to identify these girls, Rodriguez stated he could not at the moment but knew he wrote their names down on a journal he kept during his employ with Mr. Epstein. He kept a journal in the event he needed to explain either to Mr. Epstein or his assistants what was done at the house or who visited the house as he stated he was in-charge of Mr. Epstein's personal security while in Palm Beach. I informed him I would need to view this journal to which-he stated he would research the book and contact me to provide the book. The interview was concluded and left the area. I returned back to the police station where the micro cassette was placed into evidence. At approximately 7:20 pm, I was notified Rodriguez located the journal and would call me on January 5, 2005 to provide the journal. Investigation Continuesaa FA REKKKEKREKKEKHEKKEKKEEREKREERKES Reported By: RECAREY, JOSEPH ~ 1/09/06 Entered By.: ALTOMARO, NICKIE A. 1/10/06 On January 5, 2006, I attempted to meet with Alfredo Rodriguez to recover the folder or journal in which he kept the notes that were given to him during his employ with Mr. Jeffrey Epstein. He kept this folder to justify what he did during his employ should the need arise to justify what occurred with the monies he had to keep or any questions as to the petty cash he withdrew from the household account from the bank. At approximately 10:00 pm, I attempted contact with Mr. Rodriguez and discovered he was assisting his wife at her place of employment and would not be able to meet with me. Mr. Rodriguez stated he would meet with me on January 6, 2006, in Broward County, in the morning hours. On January 6, 2006, at approximately 9:00 am, I received a telephone call from Mr. Rodriguez who advised he had the file in hand and would be traveling northbound to meet with me in Broward County. At 10:50 am, I met with Alfredo Rodriguez at the parking lot of Bank of America in Boca Raton on Yamato Road and Military Trail (known as the Polo Center). Rodriguez produced a green folder which contained documents, a note with Mr. Ep with direction to deliver a bucket of roses to igh School ——— er a so in that same note was direction high school drama to rent a car for ee direction to extend the rental contract. I returned to the Palm Beach Police Station and placed the folder into evidence. . I received a fax from Verizon from the subpoena request sent on GIUFFRE005685 CONFIDENTIAL Oe ne nN he a a RI Hem pets se eee ee ey ee,

Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page669 of 883 i i i eee, ee ne eee 7/25/06 PALM BEACH POLICE DEPARTMENT Page: va | 8:47:53 Incident Report Program: CMS301L | No. . . . : 1-05-000368 (Continued) | 01-04- 06, for telephone number The phone number is ; isa registered to Dr Perry Bard, from West chiropractor and has an office located in West Palm Beach. The cellular number is Dr Bard's personal cellular number. On January 9, 2006, Det. Caristo and I traveled to n Palm Beach Gardens in an attempt to locate Johanna Sjoberg, who had | been previously seen on the property and identified through her Florida Drivers License and Florida license Plate. A business card was left for her to return my call. We then traveled to the Foundation and locate agre oO speak with us and in a private room within the school provided us a taped statement. During the statement, dvised that when she was fifteen or sixteen Y °° ilies was taken to Jeffrey Epstein's house by her associate, tated this occurred late May 2004 or early June 2004. She was told she could model lingerie for money for a wealthy Palm Beacher. She remembered they traveled by yellow cab from their residence in West Palm Beach to Epstein's house. She remembered encountering Epstein at the front door during the evening hours. ee Oe ee = ~ He introduced himself and brought them into the kitchen so that the | chef could prepare brought fi for them to eat. After having a meal, | and Epstein brought upstairs to a master bedroom which had a large bathroom. She observed a large style shower, sauna and there was a large massage bed also in the bathroom. Epstein entered a room within the bathroom and came out wearing o 1: : said they would provide a massage on his feet. ee why they | are doing this. MN old her this was part of ine and told her to rub his legs and calves. Epstein had told | 1 comfortable. continued rubbing Epstein's calv Epstein's direc ft the room leaving by herself. Epstein told o get comfortable her blouse and pants and stayed in her panties. stated she was not wearing a bra. She believed she was wearing thong panties. Epstein turned over onto his back and began touching her. Epstein touched her breasts and began touching her in her vagina area Epstein instructed her to rub his chest and rub his nipples. stated the touching consisted over the panties on the first t stroked her vagina but stayed on top of the panties. During the first massage, she stated Epstein was stroking her and began. masturbating himself at the same time. He put his hands under the towel and appeared as to masturbate himself however she never saw his penis. She continued rubbing his chest until he grabbed her and pulled her closer to him. He appeared to have climaxed because after he pulled her closer to him the massage was over. Epstein had told her that there was two hundred dollars for her on the dresser. He told her that she could not ae happened at the house or bad things could happen. tated she went to Epstein's house three GIUFFRE005686 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page670 of 883 -_aaceewew wwe Fe Se SF eee ee KO Oe ee OO ee er re er ee wee ee er ee ee ee OO Se ee ee ee ee ee ee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page Time: 8:47:53 Incident Report _ Prograr Case No. .. . : 1-05-000368 (Continued) or four times total. ae «:: very scared and felt very nervous. | She knew because of Epstein's money he was powerful. After the 3 Massage, Epstein ordered his houseman at the time to drive the girls : home. The employee was to drop off the girls at their house and watch them go inside their house. could not remember who the houseman was. She stated Epstein | ana Mis assistant Sarah would call her at her father's house to 7 arrange for her to come and "work." She advise she returned to the house, Epstein would do the same thing. tated it was a routine with Epstein.. She would rub his feet and caives. -He would then turn over and begin to touch her on her vagina area. The only difference was that it was done without panties. Epstein's fingers would stroke her vagina area as he would masturbate and finally climax and the massage would be over. She was paid $200.00 each time she went. Each time she went she was reminded not to speak of what | happened at the house and that she would be contacted again. She began to purposely miss the calls when either Sarah or Epstein would call her. She once brought a friend, unkno name, to work for Epstein. She was paid $200. Or inging stated she no longer retuned to work for Epstein... She also stated wanted to notify the police of what happened at the house. ini: she was scared of what could have happened to her or er family if she notified authorities. On January 10, 2006, I received the results from the subpoena from BellSouth Telecommunications for telephone number The —ee 1. e father in Palm Beach Gardens. I also received t stern Union which confirmed the money order sent to from Jeffrey Epstein in New York City. The "wire" was sent by Jeffrey Epstein of 457 Madison Ave in New York City on December 23, 2004 at 12:05 pm. The amount of $222.00 was charged to Epstein's credit card so that could receive $200.00 in Royal Palm Beach. The twenty-two Ollars was for processing and local fees to send_the money via Western Union. A copy of the check presented to as also attached to the receipt of the wire. This confirmed what advised she received as a Christmas bonus from Epstein. a AE ee mm oe a eee poe ee ~ 700 ee CAR Senge Ment © ee gy er es eel Investigation continues. KEKKKKKKKRKKKKKKKKARKKRRAEKEE NARRATIVE HFS RRR KKEKKEEKEKREEEKREKEEKKEKREE NA Reported By: RECAREY, JOSEPH 1/10/06 Entered By.: ALTOMARO, NICKIE A. 1/10/06 I received and reviewed the Cingular Wireless results from the subpoena requests for subscriber information for telephone numbers The first number, is assigned to Janusz Banasiak in care of Jeffrey Epstein of 457 Madison Ave in New York City. Banasiak is the current houseman/house manager for 358 El Brillo Way in Palm Beach, Fl 33480. 7 The second number, a is assigned to Christina Venero of | GIUFFRE005687 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page671 of 883 =O eee Kt ew ew ae KO we were eT ewe ewe ee ST ee eee ee ee ae ee ee ee ee ee oe oe ee oe we ee oe ee ee oe ee ee ee ee ee ee oe Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 75 Time: 8:47:53 Incident Report Program: CMS3011L Case: No 1-05-000368 (Continued} West Palm Beach. Research conducted on Venero revealed she is a licensed Massag ist with a Florida conditional/active license =< | Venero had been previously arrested for battery / unwanted tcUthiiighmand DUI. Requests for copies of the reports involving the arrests were reque Palm Beach County Sheriff's Office. The last number is assigned to Thomas Rofrano of EMM Palm Beach Gardens. Research on Mr. Rofrano, revealed that he is a Florida Chiropractic Physician. Vehicles that were previously documented on the property while surveillance was being conducted were res I determined a tan Chevrolet Camaro, bearing Florida License [alll was seen on the property in which a young white female wa tering the Epstein property. Research revealed that the vehicle is ‘ as two daughters, ls currently residing in esiding with her father in Lake revealed she was recently involved in a traffic stop in Lake Clarke Shores in May 19, 2005. A request to discover any information from the stop was requested. I spoke with ASA Daliah Weiss who informed me that Janusz Banasiak will be available for an interview tomorrow at the State Attorney's Office in West Palm Beach at 1:30 pm. I informed her that I would be at her office for the interview. KKKKEKKKKEKKEKKEKKKEKEKEKKEKER NRRRAT IVE Ho 3G KEKE KRKEKKREKEKKKKKEKEEHKEKKSE NA Reported By: RECAREY, JOSEPH 1/23/06 Entered By.: ALTOMARO, NICKIE A. 1/23/06 006, Det. Caristo and I met with Johanna Sjoherg at n Palm Beach Gardens. Sjoberg was identified as a licensed massage therapist who had previously been seen on Epstein's property when physical surveillance was done. Sjoberg was told of the on going investigation and I felt she may have information pertaining to the case. During a sworn taped statement, Sjoberg stated she met Epstein three years ago when Ghaline Maxwell approached her while she was attending Palm Beach Atlantic College to work around Epstein's house. Maxwell had told her that they needed some girls to work at the house to answer phones and run errands. Sjoberg accepted the job and began working at Epstein's house on El Brillo in Palm Beach. Sjoberg stated it was a part time job during the time she went to Palm Beach Atlantic College. She continued going to Epstein's house and would be notified when Epstein would travel to Palm Beach. Sjoberg advised she would be notified by Maxwell, Epstein or Sarah, his assistant, when he would travel to Palm Beach. Sjoberg stated she began providing massages to Epstein before she became a massage therapist. She continued giving massages not only to Epstein but to Nadia Marcinkova, and Sarah, his assistant. Sjoberg was asked about what occurred during the massages. Sjoberg stated as she was twenty GIUFFRE005688 CONFIDENTIAL

Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page672 of 883 Se eS ee ee ee ee 7/25/06 PALM BEACH POLICE DEPARTMENT , Page: 76 8:47:53 Incident Report Program: CMS301L No. . . . : 1-05-000368 (Continued) three years old when she met Epstein, anything that happened was between two consenting adults. I explained to her that she was not in any trouble however as part of this investigation, I needed to ask certain questions. Sjoberg stated that there were times that Epstein would ask her to perform during the massage. He would instruct her. to rub his nipples as he masturbated himself. Sjoberg stated she felt "grossed" about the behavior but as she was getting paid, she just continued. Sjoberg also advised she would on occasion perform the massages naked. Epstein would on occasion, utilize the vibrator/massager on her vagina area when she performed the massages. Sjoberg explained that Epstein never exposed himself to her as he maintained himself covered under the towel he would be wearing. When Epstein would masturbate he would be covered. I asked if Sjoberg ever received any gifts, or any gratuities from Epstein. Sjoberg advised aside from being paid well, she advised Epstein took care of her tuition from Palm Beach Atlantic College. She received a rental car for a week when her scooter broke down. Additionally she received other gifts from Epstein. Epstein also recommended her to another client who resides at Breakers Row in Palm Beach. The client she was referred to was "Glenn" unknown last name, and his wife, who she provided a massages to. The statement was concluded and placed into evidence upon our return to the Palm Beach Police Department. While at the police station, I researched Florida tag «25 ch was also previously seen on the property when there was physical surveillance being done at the property. The vehicle is registered to and the EE Lake Worth, i ee hz vehicle revealed that his daughter, had been driving the vehicle and was cited for unlawful speed in Lake Clark Shores. The vehicle is a tan, Che et Camaro, 2-door. I researched ate of birth, 987, resides at pace page called In her web page, shows various photos of photographed at a beach. An interview is forthcoming. A review of the video disks which was extracted at the Palm Beach County Sheriff's Office Computer Crime Unit revealed that only one. hidden camera was functional at the time. Several images of Epstein working at his office were seen. Additional footage of Sarah Kellen and Nadia Marcinkova was seen. There was other footage of females seen. The identity of the females is unknown at this time, until such time as I meet with certain females to show the video footage to confirm if, in fact, it is them on the video. At this time it appears that and Haley Robson are seen sitting with Epstein beside his desk in the evening hours. Due to poor lighting, a direct confirmation cannot be made at this time. Inv. Continues. GIUFFRE005689 CONFIDENTIAL ee —_——— —— re ress: Se eae te ener nee ee ee eee | We Haye reeke es Kame. bt et tere ee heme oe sdeisn

Case 18-2868, Document 283, 08/09/2019, 2628241, Page673 of 883 meme cee meee cere eres ee e e et Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 77 Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Cont inued) KEKE KREREEEREEEKEKEEKEX NRRRAT IVE i ZF KEKE EKEKEKKEKKERKEKKKKEKEKEEEES NA Reported By: RECAREY, JOSEPH 1/30/06 Entered By.: ALTOMARO, NICKIE A. 1/30/06 On Janua 25, 2006, Det Carist and met with year, when’ she was seventeen through her former room mate Epstein at the time. and once cohabitated together when they modeled. explaine called her on her telephone and advised her that she was in Palm Beach and requested to see her. made arrangements to it t Epstein's house. 3a arrived and met Epstein and and MMMM went to the Palm Beach Mall together and went shopping. advised that 9 and she had received money from Epstein to go to the mall. They visited Victoria's Secret and purchased undergarments from the store utilizing monies given by Epstein. advised she purchased one item and MEN Purchase various items. The money used to purchase the items was the money given by Epstein. Se I conte shopping and having a day together. a stated lained how she and Epstein have been datin ach other and he has been paying all of her bills. ladaad Miotaad they met in New York and had been dating ever since. They later returned to Epsteip! me and encountered Epstein. He had a brief conversation veh Bo her modeling career. He knew of her modeling career from He requested to see her modeling io and explained that he cou her with modeling jobs. ad her book with her to show and showed the book to — He commented negatively abou er photographs and portfolio. ded to stated last e, she met Jeffrey Epstein Mas allegedly dating felt uncomfortable with the comments made as she had been working with other professional modeling companies who had offered her work from her photographs. stein requested to see what was purchased at the mall. ee ee out the undergarments which were purchased. She immediately showed Epstein different il Epstein then requested to view what urchased. as reluctant to show the outfit however since it was Epstein's money that purchased the he pulled it out of the bag. Epstein asked her to try it on. looked at ho told her "yeah, try it on." Feeling compelieda to try the undergarment outfit on; she went to another room and put on the bra and panty set. She walked out to the living room where they were sitting, and modeled the suit. She then went back into the other room and cha ck into her clothes. | returned into the room ial would be going home. scheduled another day for to return for massages with her. tated within that same week, she returned to meet with Fe and have a massage. ad told her that she would be unable to stay with her as she wou e going on a bike ride with Epstein. explained she could stay at the house and take advantage of the massage. GIUFFRE005690 CONFIDENTIAL Se ht ee te ee ee ey

Case 18-2868, Document 283, 08/09/2019, 2628241, Page674 of 883 crt cme Teta rm mm ree cme et ee ee ee ee ee ee Me tee ee nes ee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 78 Time: 8:47:53 Incident Report Program: CMS301L Case No. ... : 1-05-000368 (Continued) stated she met with an unknown herapist and had the table already set up in a guest room. emoved her clothing, leaving her panties on, and wrapped herself with a towel for the massage. —_— remembered that the door to the guest room was closed but not locked. As the therapist was working her back, the door was opened by Epstein and entered into the room. [EBB was trying to conceal herself as Epstein was talking to her about hi ractic session. Epstein told ]MM—Mkurn over onto her back. ne eventually turned over exposing her breasts to Epstein as he applied pressure on_her shoulder and her waist. tated Epstein "popped" her back. emoved her se he table, got dressed and left the house further state ad attempted to call her several occasions t her back to Epstein's house to vaich i 'm busy." dvised she has not had contact with either effrey Epstein. It should be noted that her mother, as present during the interview. The interview was concluded and we thanked them her for their time. REKKKEKKKKKRKEKEKREKERKEEKKEEEEKEE NA RR ATIVE # 3G FERRER KKKKKEKKKKKEKRKEKEKKEKEE NA Reported By: RECAREY, JOSEPH 1/31/06 Entered By.: ALTOMARO, NICKIE A. 1/31/06 on 006, I madé telephone contact with Christina Venero, at Venero is a licensed massage therapist who had frequented the home of Jeffrey Epstein. Ms. Venero has been unable to meet with me in Paim Beach County, and because she lives and works in Port St Lucie, a telephone interview was conducted. I explained to Ms. Venero that there was an on going investigation involving Jeffrey Epstein. Venero stated she knows Epstein and has been employed by him for approximately three years. Epstein has paid Venero to perform Swedish Massages (Deep Tissue) on him and other guests. Venero explained that approximately three year ago she met Ghislaine Maxwell and Jeffrey Epstein through a mutual friend. Epstein and Maxwell were looking for a Massage therapist. Venero stated since that time, she is notified when Epstein is coming to Palm Beach. Venero stated she comes to his house and provides the massage or massages. Venero explained she has also massaged his guests and assistants. Venero continued that she is paid $100.00 and hour for the massage. I asked Venero if anything occurred during the massage that would have made her feel uncomfortable. Venero stated she only provided massages and that was it. She never was approached for anything else. .I asked if Epstein ever asked her to rub his chest she stated she would not rub his chest as that is not part of her massage. Venero explained that she was not Epstein's type. The girls she would see at Epstein's house were very thin, beautiful and without tattoos. Venero explained she has several tattoos that are visible. Maxwell and Epstein have commented negatively about her tattoos previously when she has provided massages. GIUFFRE005691 CONFIDENTIAL . (etemiges me 54 CSA Gale cme treed mamalies satemel ns bat! <<

Case 18-2868, Document 283, 08/09/2019, 2628241, Page675 of 883 ~~ —_— —- ——_—F— eo Fr wer oe EK HT ee ee eT SE ew eS eee ee eee ae eS SE SE ew oe Oe ee ee ee ee ee ee ee ee ee eee oe ee ae ee ee ee ee ee ee ee 6. on Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 79 Time: 8:47:53 Incident Report Program: CMS30iL Case No. .. . : 1-05-000368 (Continued) Venero stated she only provided massages for Epstein and his associates and nothing happened during those massages. Venero stated as she does Swedish style massages, the patient is usually sore after the massages. I thanked her for her assistance and the interview was concluded at this time. I received a facsimile from T-Mobile Cellular service on telephone number EE which is assigned to David Rodgers, pilot for Mr. Epstein, who resides in Lake Worth. Rodgers' telephone number was dialed on several occasions by Sarah Kellen. A background: on Rodgers indicated he has a valid FAA pilot license First Class for the - Southern FAA Region. Rodgers has another historical FAA license for Airline Transport Pilot. | Investigation Continues. KKK KK KKK KKEKKKEEEEKKKEKKKKKK N A R eA TT Ft V E # ZQ REKEKEKEEKEKEKKEKKKK KKK NA Reported By: RECAREY, JOSEPH 2/14/06 Entered By.: ALTOMARO,; NICKIE A. 2/16/06 ry 3, 2006, I had made arrangements to meet with t the Palm Beach Police Station. t approximately 1:00pm, and her friend, arrived at the police station. During an interview with she stated she met Epstein when she turned eighteen ye d was brought to Epstein's house to provide a massage. She advised this occurred on May of 2005. She advised Haley Robson had informed her if she wanted to provide a massage for $200.00. — reed and was brought to Epstein's house to provide a massage. stated she had been to the house on many occasions during the massage sessions. also stat she would remove her clothing to provide the massage on Epstein. dvised Epstein would pay her $300.00 to rub his back, legs and chest. During the massages, Epstein would masturbate himself as she rubbed his chest. I asked her if Epstein ever touched her breasts during the massages. Pea. " IT asked her if Epstein ever touched or massaged fer vagina stated he had on several occasions. I asked her netrated her with either his penis or any other objects. tated that during a massage he inserted his fingers in her vagina as she massaged him. She stated this occurred one time only. Rc ocad the massage would be over when Epstein would climax onto a towel. I asked if she had_any formal massage training to which she replied that she did not. a then asked if she ever brought anyone to the house to "work." ated she brought two people to the house. She advi ceived money for bringing people to the house to "work." stated she brought a gi her friend as still waiting for lobby of the police station. I —i cooperation and escorted her to the lobby. and in the er time and her or I asked Ms MMR f I could speak with her about this investigation. I GIUFFRE005692 CONFIDENTIAL ore eee eee - ut ee on rent tal ere eg ty

Case 18-2868, Document 283, 08/09/2019, 2628241, Page676 of 883 =~—V— = we eS Ee ee Oe Ce we eS SF FSF SF eer eee ee ee ee ae oe -aSe near ewrwreew ew ew ese eS SS SP See ee ee ee ee eee ee ee a ee ee ee oe ee oe Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 80 Time: 8:47:53 Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Continued) brought her to the interview room and explained to her that I was conducting an investigation on Jeffrey Epstein and felt she may have oo re investigation. Ms [identified herself as d resides in Wellington, Florida. She advised approximately a year ago she was brought to Epstein's house to provide a massage for money. Stell tated she needed to make money and felt it was a quick way to make some money. stated she was brought. to the house by nd was introduced to Epstein and his assistant. She was brought to his main bathroom and provj massage. I asked her if she provided the massage naked. she did. She rubbed Epstein's legs, back and chest. Ia Epstein touched her during the massage. She advised he did not, however he did masturbate himself as she rubbed his chest. Once he climax massage was over. She was paid her money and left the area. advised it occurréd one time and she never returned to Epstein's house. The interview was concluded and was escorted to the lobby. ed if nd attempted to contact a occasions. I calle d spoke with Ms. ho advised she would speak with me in Deerfield Beach where she resides. Due to a scheduling conflict, we were unable to meet. I informed her I would contact her to schedule another appointment to speak with her about this investigation. I have attempted to meet with her and make telephone contact with negative results. On February 13, 2006, I met with David Rodgers 2t in Lake Worth. Rodgers was identified as Epstein's pilot. I spoke with Rodgers who advised he has been employed with Epstein since 1991. He flies both planes for Epstein depending where he wants to fly to. Rodgers was asked about passengers in the plane he flies. Rodgers stated unless Epstein flew to his island off of St Thomas, there would be no way of knowing who the passengers were. I ment] nt flight to Ohio, where Rodgers flew to Ohio to pick up Rodgers d he recalled flying on several occasions and did vemenber aa Rodgers stated once he is in the cockpit, he does not know who the passengers are. When he prepares the passenger manifests, he lists Epstein and his assistants he knows by name, Sarah and Adrianna. Rodgers stated he would list either female or male passengers on the manifests only to keep a count on the passengers. Mrs. Rodgers came into the living room and recommended that her husband consult with an attorney. Mr. Rodgers agreed he would speak with the family attorney to inform him of this questioning. I explained to Mr. Rodgers that he was not the suspect in this investigation and ceased all questions. Based on the fact Rodgers could not advise who passengers were in the plane, I then left the area. i ae temrbed. bo kocal cae AI As: Wellington. I left my business card for her to return my call. February 14, 2006, at 12:06 pm, I received a call back from Ms. a I located a telephone number for GIUFFRE005693 CONFIDENTIAL ee ee ee - ~ tae bck ey ep tere weet fe -

Case 18-2868, Document 283, 08/09/2019, 2628241, Page677 of 883 — ee me ee ee eee eee me mee ee eee ee eee ee i ie a ee ee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page:. 81 Time: 8:47:53 Incident Report Program: CMS301L -=sewe oe Se SH Owe SO OO we EO Oe Nw SE CTF ST Ow SE SE Sei ew SE SE eT ee eS ee eee ew ew ew Se ee ee Se ee ae ee eee eT ee Se ee Se ee ee ee ee ee eet ee ee -= — Case No. ... : - a. a (Continued) on my voice mail. Ms left her telephone number for a return — I left her a message to return call. Investigation Continues... KKK EER REE REE KKK RR KR RK NARRATIVE Ht AQ KEKE KKEEEEKKKKKKKEKEKEKREKEE NA Reported By: RECAREY, JOSEPH 2/21/06 Entered By.: ALTOMARO, NICKIE A. 2/22/06 On February 15, 2006, I made telephone contact with 30 provided dir ions to where 7 could locate her. .Det Caristo and I responded carat: L k to meet with GE Upon my arrival, I met with in the parking lot directly behind MAACO Auto Painting. She was advised I was there to speak with her about an ongoing investigation that concerned Jeffrey Epstein in Palm Beach. mn tea she knows Epstein very well and did not want to speak with me about Mr. Epstein. She was very fond of Epstein and did not want to speak with me about anything concerning Jeffrey Epstein. I explained to her that she was seen at the house and I would like to speak with her. She stated she knew there was an investigation and that I had spoken with other people and therefore I should know what happened at Epstein's house. GREEN ended the conversation and walked back into her boyfriends business, Blanton Automotive. Det Caristo and I left the area and returned to the police station. Investigation continues. KKEKKKKKKKEKKKEKEEKEEEKEEEERKR NRRRA TIVE: HAL BERK KKEKEK KKK EKKEEKEEKREERER NA Reported By: RECAREY, JOSEPH 4/10/06 Entered By.: ALTOMARO, NICKIE A. - 4/10/06 A Grand Jury Session was requested during the month of February 2006, in which all the girls that had been interviewed would have been called to testify before the Grand Jury to seek an indictment against Jeffrey Epstein. Due to subsequent meetings with the State Attorney's Office and Defense Attorney Alan Dershowitz the Grand Jury was postponed until a later time. Dershowitz had provided a package of material on the main victims in this case in which they appear on myspace.com and speak about alcohol use and some marijuana use. The State Attorney's Office wanted time to review the material. I requested additional subpoenas from the State Attorney's Office in which I requested information from Dollar Rent a Car and Jet Aviation. The information requested from Dollar Rent a Car was for the rented vehicle by Alfredo Rodriguez while under the employ of Epstein for one of the victims. The other subpoena requested was for Jet Aviation for dates and times when Epstein's planes were in Palm Beach County. I continued to research other names that were acquired either from interviews or intelligence gathered during the investigation. I GIUFFRE005694 CONFIDENTIAL Jo AS AOE Sh eee ee tt eee ee ee . encase 28 <on Sons: ted pees 4 menor s+ Or © A ieee ete oe ee wan ws corse on

Case 18-2868, Document 283, 08/09/2019, 2628241, Page678 of 883 —-«-es ewawaws— aoe eases wee weer ew Se STF TF Se SF SF Se Sw KF eB ew eS ww NZX ew ewe ew Bee Se ee ewe SE Oe ew ee eee ee eee ee es eee ee eee ee ee Date: Time: 7/25/06 PALM BEACH POLICE DEPARTMENT ‘Page: 82 8:47:53 Incident Report Program: CMS301L i re ec ee i ee ee Case No. : oyal Palm Beach. During the i ie occced it made her 1-05-000368 in Royal Palm Beach I respo stated she knew I would be speaking with her. st introduced to Epstein when she turnec cigiteci she was sure of her age as it was her senior year in High School. She advised she was brought there to make money and was told she would have to provide a massage to this Palm Beach guy. She remembered she met Epstein and his assistant . Sarah in the kitchen area. She stated she was taken by one of her friends, She stated she went upstairs with Sarah whil got ready for the massage. He exited his bathroom naked and und. Epstein asked her if being naked offended he le. Epstein then put on a tated she rubbed his back and MadSPpayo GL ining or experience. towel and lay on the table. feet. She stated she had no stated during the massage, Epstein attempted to touch her | buttocks. pulled away as he touched her buttocks. She told KRKEKKKEKKEKKEKEKKKKKKEKRKEKRAKEERE NARRATIVE NA him again she was uncomfortable with him touching her.. Epstein then cut the massage short and became upset.with her. Epstein $200.00 for the massage and told her to leave the house. ime she went wit 3 med to the house. She did advise of 3 es however she waited in the car for s she did not want to go into the house. lusion o Ss visit with Epstein they left the area. stated she had heard from other girls that have gone to the house that Epstein now required them to do the massage naked and allow him to touch them in their private areas for monies. The interview was concluded as MMM did not have any other information to provide. I then learned from the original victim, = the defense attorney had learned of her identity. I spoke with th ather of the victim, who stated there has been a private investigator on his house photographing his family and chasing visitors who come to the house. | This vehicle is registered He provided a Florida-License of to Ivan Robles of West Palm Beach. Robles is a private investigator intern who is licensed by the state. I informed the State Attorney's Office of the above information. I received the Grand Jury subpoenas to be delivered to three victims for a Grand Jury session to be held on April 18, through April 20, 2006. Investigation continues. The Grand Jury Subpoenas were personally served to the individuals they were issued to. On April 5, 2006, at approximately 7:30 p.m., I personally served the parents of 2° had informed me that the private investigators were still photographing the family. On April # AD BREKKEEKREEKEKKEKEREKKKEEKKEKKE Reported By: RECAREY, JOSEPH 4/14/06 Entered By.: ALTOMARO, NICKIE A. 4/18/06 GIUFFRE005695 CONFIDENTIAL - SO ee es ee et yt Nl adhe tee Hie esmeme tomentose’ a htt ole oe ES Be 4 treet nines ae Pb Met ao) eee «eres ae

——— ee ee ee Case 18-2868, Document 283, 08/09/2019, 2628241, Page679 of 883 —_— ee ee ee re mere ee re remem ee ee ee Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 83 Time: 8:47:53 | : Incident Report Program: CMS301L Case No. .. . : 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I served t her Royal Palm Beach. The subpoena was given to her mother, “ee in I learned through one of the victims MM hat she was personally contacted through a_source that has maintained contact with Epstein. The source assured MMshe would receive monetary compensation for her assistance in not cooperating with law enforcement. AH also stated she was told, "Those who help him wi compensated and those who hurt him will be dealt with." I told that tampering with a witness/victim is an arrestable offense and very serious. I asked her who approached her during this encounter .[BBBMM originally was reluctant to provide the name of the person who approached her to offer her not to testify because she felt they were still friends. On April 11, 2006, Det Dawson and I traveled to Tallahassee, Florida and met with the victim, Hii ae W/F, Een, as the person who approached her in Royal Palm Beach while she was home during Spring Break in March 2006. ae stated she did not want to pursue the intimidation charges on as concerned that the defense attorney was given a copy of the report as in things she had told me in confidence were repeated to her. by Prior to our departure, the victim was given a copy of her subpoena for the Grand Jury which was scheduled to commence April 18, 2006. Upon our return from Tallahassee, I notified the State Attorney's Office of what was told to me. I also notified them that the subpoenas were delivered to the witnesses and they would be calling for arrangements for the date and time needed for the Grand Jury. I spoke with ASA Weiss and informed her of the possible intimidation by the defense. On April 13, and April 14, 2006 I attempted contact on several occasions with ASA Weiss and ASA Belohlavic.to ascertain when the victims needed to report for Grand Jury testimony. Messages were left on their voicemail. On April 17, 2006, during the hours of 9:00 am and 11:30 am, I again left messages for ASA Weiss and ASA Belohlavic for either of them to return my call as I had not heard from the State Attorney's Office as to the time and date of the Grand Jury. At approximately 12:30 pm, I went to the State Attorney's Office and located ASA Weiss and ASA Belohlavic in their offices. I entered ASA Belohlavic's office who informed me that she was going to return my call. She explained that an offer was made to the defense, Atty Guy Fronstin and Atty Alan Dershowitz. The offer is 1 count of Agg Assault with intent to commit a felony, five years probation, with adjudication withheld. Epstein would have to submit to psychiatric/sexual evaluation and no unsupervised visits with minors. When asked. about the all the other victims, ohlavic stated that was the only offer made as to one victim, ASA Belohlavic cell phone rang and went to voice mail. She checked her voice mail and played the message on speaker. The caller identified himself as GIUFFRE005696 CONFIDENTIAL Ot A eet ae eee a ces SOR) AT FLERE bee ae eee Fe hs ref en tee ow ' Se ree ere

——— oe Date: Time: Case Case 18-2868, Document 283, 08/09/2019, 2628241, Page680 of 883 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 84 8:47:53 Incident Report | : Program: CMS301L ia i i el ae naeeeee eT Bee eee eae es Seen TS SSeS SSS SSS FF SO SSS ESOS Se See | | No. . . 2 1-05-000368 (Continued) Atty Guy Fronstin and acknowledged the deal made between them. Fronstin stated in the message, he spoke with his client, Jeffrey Epstein, and agreed to the deal. Fronstin asked to call off the grand jury as they would accept this deal. Belohlavic stated a probable cause would be needed to book Epstein in the county jail and would let me know as to when it would be needed. I explained my disapproval of the deal and not being consulted prior to the deal being offered. However I expressed that was only my opinion and the final approval would come from the Chief of Police. She explained to have Chief Reiter call Barry Krisher about the deal. I left the area and returned to the police station where I briefed the Chief about the deal offered. I checked my voice mail messages and discovered a message from Qa stepmother for the victim| She was calling because the State Attorney's Office still had not returned any of her calls as to when they are needed for this case. I then called ASA Belohlavic's office and left messages for her to call the victims on this case and explained to them what the State Attorney's Office had done. On April 17, 2006, at approximately 4:30 pm, State Attorney Investigator Tim Valentine called to officially notify me »of the cancellation of the Grand Jury. He requested I contact the victims that had been served to appear, to notify them of the cancellation. [I advised Valentine that as this Grand Jury session was called based on the State Attorney's Office decision to have the victims heard by the Grand Jury that I felt it was the States Attorney's Office responsibility to contact the victims and advise them of the reason they were no longer needed. KKKKEKEEKKEKEKEKEAKEKKEKEEKEEERK NARRATIVE HAF RERKKRKKKKEKEEKEKKKKKKKKKES NA Reported By: RECAREY, JOSEPH 5/04/06 Entered By.: ALTOMARO, NICKIE A. | 5/04/06 As I had not received any contact from anyone at the State Attorney's Office, on May 1, 2006, I prepared three arrest warrant requests and submitted them to the State Attorney's Office. The packages were delivered to the Crimes against Children Unit in care of ASA Lana Belohlavek. Jeffrey Epstein's arrest warrant was requested for 4 counts of Unlawful Sexual activity with certain minors and one count of Lewd and Lascivious Molestation. Sarah Kellen, Epstein's assistant's, arrest warrant request was for 4 counts of Principal in the 1st degree Unlawful Sexual activity with certain minors and one count of Principal in the ist degree Lewd and Lascivious Molestation. Haley Robson's arrest warrant request was for Lewd and Lascivious Acts on a victim under 16 years of age. The receipt of delivery was signed and brought back to the records division at the police department. On May 3, 2006, at approximately 2:54 pm, I received a telephone call from ASA Daliah Weiss on my cellular telephone. ASA Weiss advised she GIUFFRE005697 CONFIDENTIAL omen oy Gy <8) ee cmentutecbinles mmr eerie Se ee he tin ete AA) meh - ~

Case 18-2868, Document 283, 08/09/2019, 2628241, Page681 of 883 wes ee ane ew ewe ee OO ewe ew eB Mw MW eA ee we Se SB www ewww ew ww ew ew ew ew ew ew we ee eM ewe Me ew eww BO EM wee ee ee oe eee eee Date: 7/25/06 — PALM BEACH POLICE DEPARTMENT Page: 85 Time: 8:47:53 Incident Report Program: CMS301L Case No. .:. . : 1-05-000368 (Cont inued) has been taken off the Jeffrey Epstein case because her husband is employed with Attorney Jack Goldberger. Attorney Goldberger is the attorney of record for Jeffrey Epstein. His previous attorney, Guy Fronstin, has been fired from representation. ASA Lana Belohlavek has been assigned the case. ASA Weiss stated she can no longer speak about the Epstein case with me. I thanked her for her telephone call. ASA Weiss further stated that ASA Belohlavek would be calling me. KKKKKKKEKKEKKKRKKKEKKKKKKKEKEE NDRRAT IVE HAL RKEKKKKEKEEKKKKEKKEK KR RKKK NA Reported By: RECAREY, JOSEPH 5/15/06 : Entered By.: ALTOMARO, NICKIE A. 5/15/06 On May 10, 2006, information was received that Epstein's associate, Leslie Wexner, The Limited Inc, CEO's, plane had arrived in West Palm Beach, PBIA. The plane, a Gulfstream 4 bearing a N9O0LS registration, was on the tarmac at Galaxy Aviation. As Epstein had recently acquired the services of a new attorney, and the fact that Epstein's © house is currently under remodeling, it was believed that Epstein may be in Palm Beach. I conducted physical surveillance at the residence, 358 El Brillo Way. I observed a large construction crew conducting remodeling at the house. The contractor, David Norr, was observed driving a Ford Explorer, white in color. The vehicle has a Florida registration of F30QQF. Norr left Epstein's house and traveled north on County Road. Det Caristo and I. conducted surveillance on Norr. Norr traveled to several construction sites and checked on certain jobs. Surveillance was discontinued on Norr and Det Caristo and I traveled ta-Galaxy Aviation. I observed the white plane with a blue stripe along the body and tail of the plane; the tail number was visible on the bottom of the tail, closer to the body of the plane. We maintained visual surveillance on the plane until 4:57 p.m., when a Caravan of Cadillac Escalades drove onto the tarmac. We observed several people exit the vehicles and discovered that they were part of the executive team for Limited Inc. . The executives were in Palm Beach County for an executive meeting for the day. They arrived in Palm Beach County on May 9, 2006 at 9:30 pm and were scheduled to leave on the 10th at 5:00 pm. On May 12, 2006, I met with ASA Lana Belohlavek at the State Attorney's Office. She explained that her boss, Barry Krischer, was requesting this case be taken to the Grand Jury again. I explained to her I had requested arrest warrants for Jeffrey Epstein, Sarah Kellen, and Haley Robson. I asked that she either issue the warrants or direct file, as so much time has elapsed since the original request to the Grand Jury. I explained that the Palm Beach Police Department had concluded the case in December .of 2005 and has been waiting for the case to go forward. Belohlavek stated the original offer was again offered to the new defense attorney. She was waiting for their answer by Friday May 19, 2006. She stated she would advise me of the answer. KKKKKKKKKKKEKEKEEKEEREEKEREKE NDPRPRA TIVE: HAR RRR KHEKRKEKEKEKEKKEKKEEKKEKEKKEES NA Reported By: RECAREY, JOSEPH 6/05/06 GIUFFRE005698 CONFIDENTIAL remnant nt neat emresinratialp ee ST ae hw] OSE se ee eRe ree

Case 18-2868, Document 283, 08/09/2019, 2628241, Page682 of 883 —— = -—=—ee ewe oe ee SE Keer ee ew ew er Se HOT eK KK oO ew ewe eB eee ee ee eK SK ee eS SK Sr eS SS SK Ce eS eee ee eS eS eS See ee — — Date: 7/25/06 PALM BEACH POLICE DEPARTMENT. Page: 86 Time: 8:47:53 - Incident Report Program: CMS301L Case No. 1-05-000368 (Continued) Entered By.: ALTOMARO, NICKIE A. 6/06/06 On May 22, 2006, I received several phone calls throughout the day Mr. from Mr. ho stated he had been followed aggressively by a private investigator. Mr. tated that as he drove to and from work and running errands throughout the county, the same vehicle was behind him running other vehicles off the road in an attempt not to lose sight of a cle. I explained to him as Mr. Epstein had retained new legal council it was possible it would be new private investigators following him to observe his daily activities. I also explained to him that there was a meeting scheduled with ASA Lana Belohlavek and Attorney Jack Goldberger at Mr. Krischer's office scheduled on June 1, 2006 at 9:00 am. I attempted to call ASA Lana Belohlavek to inform her of the private investigators following Mr. f§fhowever; she was on her vacation during the week of May 22 through May 30 2006. On May 23, 2006, I received other phone calis from Mr. and Mrs.[—ihho advised they were able to acquire the private investigators license | plate information. The subj following them was again iving very aggressively and caused Mrs. o run off the road. Mrs. the vehicle is a green Chevy Monte Carlo bearing Florida tag | The vehicle is registered to Zachary Bechard of Jupiter Florida. Bechard is employed with Candor Investigations from Jupiter, Florida. Bechard is a licensed Private Investigator in the State of Florida. Since the discovery of the threat made against one of the victims in this case I requested subpoenas for all calls made to and received from uring the month of March 2006 for her cell phone and home phone. ‘had confirmed with Florida State University the exact dates of Spring Break for 2006. The Spring Break was from March 4, 2006 through March 12, 2006. I received a subpoena from Sprint/Nextel with all calls made during the month of March 2006. I reviewed the 989 calls made and ieee = the month of March 2006. I observed on March 7, 2006, ade and received thirty five calls during that day. Date Time Seconds In/Out ‘To/From 7-Mar-06 11:03 AM 492 Outbound 561XXXX 7-Mar-06 11:16 AM 6 Inbound 561XxXxXx "-Mar-06 11:22 AM 887.2 Inbound 56 1XxXxXx ‘Mar-06 11:37 AM 48 Outbound YVar-06 11:39 AM 28.2 Tnbound ar-06 12:02 PM 72a Inbound table reflects the date of the calls, time of day (EST), duration GIUFFRE005699 CONFIDENTIAL Se SE LT SIT wt ent oeeee ber aoe -~ HO Ae cectiatin neato meeting fH lectern ee ab He 1 Nhe he enh toe ee | we een 8 ba ee entitle’ | ower nets 2 Serer re Rh ee ote a ee ee

Case 18-2868, Document 283, 08/09/2019, 2628241, Page683 of 883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 37 Time: 8:47:53 Incident Report Program: CMS301L Case No... . : 1-05-000368 (Continued) from MEBs phone. On March 7, 2006, at 11:03 an, made a call to the victim hich lasted 492 seconds (8 minutes and 2 seconds). The victim then returned the call at 11:16 am.which lasted 6 seconds. The victim then made contact with BBM at 11:22 am for 877.2 seconds (14 minutes and 6 seconds). These sequences of calls were consistent with what the victim had described to me on the date of th intimidation. Immediately after speaking with the victim, a Call to Sarah Kellen, Epstein's assistant, which lasts for forty-eight seconds. A call is then immediately received, a telephone number registered to a Corporation affiliated with Jeffrey Epstein located at 457 Madison Ave in New York. An extensive computer check revealed 457 Madison Ave is a business address in which Epstein has his corporations assigned to. Epstein had corporation attorney, Darren Indyke, register the businesses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group >y ia to this same address. of call in seconds, inbound or outbound calls and a: to or akes Finally, a third call is received by at 12:02 pm from the same - corporate number which lasts 12 minu 1 second. It should be noted that there is no further contact with either the victim during the month of March or April of 2006. I also noted that there was no further contact with Sarah Kellen or Jeffrey Epstein during the remainder of the month of March or April 2006. On June 1, 2006, ASA Lana Belohlavek telephoned me to inform me of the meeting that occurred with Atty. Jack Goldberger and her reference this case. She advised she would make her determination on whether tofile on this case or not by Monday June 5, 2006. © Inv Continues. KKKKKKKKEKEKKEKKKKKEAKKKREKEAKEKE NAD RRATIVE AG HERKRK EKER ER KKEK KEKE KEES NA Reported By: RECAREY, JOSEPH 7/12/06 Entered By.: ALTOMARO, NICKIE A. 7/12/06 On June 29, 2006, I had spoken to ASA Lana Belohlavic who informed me that the case would be sent to the Grand Jury for charges. She informed me that the grand jury would convene on July 19, 2006 to hear the Epstein case. Belohlavic stated State Attorney Barry Krisher made the determination to go the Grand Jury to hear the case. On July 12, 2006, I spoke with Mrs .[hother of the victim, Mi who inquired about the status of the case. I explained to her that I was told we would be going to the Grand Jury during the week of July 19, 2006. She stated she had not been contacted as of yet by the State Attorney's Office for any information. I provided her with the telephone numbers to the State Attorney's Office. Investigation continues... kk ek ek ke Ke Ok ke ke RK eK eK eK RK * * REND OF REPORT * * * &K kK kK RK KK KKK KEK GIUFFRE005700 CONFIDENTIAL et 8 | ete eee ste “emedinendenteageas -comare ay o feds am -a. - ere » EN Et TE A Ac AN ee a fee Ae Se ie aeeeeie pee 9 igetnainng mw ethene rmdetis fm

EXHIBIT 40 (Filed Under Seal)

The text on this page is estimated to be only 38.27% accurate

TIWILNAGISANOOS b8s900Su4ssnIdS ca ° UNURLQG AE LULL ER Se TXEXCL ATTOA ‘ped 10 XO PRON /SP'61-1160/06 '61~ZI60/€ZCIEHE/ MOU / PPI LASETXALLYOS//- €-/B0LESPINA 9: 1 . r "rel she i atl, , yah ae oe ee " ts Sh, aie "s a fA : : o 4 " ‘ ae wwf Sarr nS a ie ‘ . iuidotioze D anod eateTd os ayaindius Siu : J rh inne we Bs v anp ever | VA ‘ ' car * , a! we Me : ae vi dome 7. th b ‘Te °3 ans, : oi ek ome @, ; reba PReb ah ah wd iS Pos soi ir sont 34014 16} pA a ae Suri peal 1 dick weoteematar ath Gist at aa iene ae ne tye! jureSe 3 suis ae ‘ syueyy : zoe Teh ozeuy We Suiddoys 20} =i tik. as e}00g" pure STFA. rye siidisting——apmiaiig anor 16} . “ oa | “xetpuae satentyt a “fog Honponyy SHS V ‘LOL WS _ LNYWaTHS SIHL NI ee Apeaa ij 2apso. moh | ae ane shee (ddd 0) 2M. hep drt = aid (Ard e suoRDINSa2 13t}6 puriyar my e.zoyskep™.. 80 ee =: prey aint oe feui@izo yo pauadoum wy = 98 Setpnpouy.” | of wt 4 (SP980Sb wediar-t01 T3PIO) S000 7% saqutgid353 Soe er edd sa ab, ma 4 Pes LSEXYLIOS ezcaehe/xou/- €-/socesPaat | foe! 3 TT ogpee epuory ipeag ujeg’ | . W . ah age hosoe-mof /woovozeue mmm / /dyy | ie oH aed : eet 11 ee weg LOY PZ — BIOU ySnut pure ‘saduarajaid °*. 5 HR, maysdet haxgya : -e ; , M rea 1a gcc idk saype“s8umjas yuautAed pure ssorppe aa oe i ee a ee a Aoayse[ | avOAuT juts utid osye ues nox "Mo2ymox | * * ee 2 puent inoae voReUosUT patreyap 104 - . ! +3 2. as | vsn ren ‘ . ‘ ts a, , OSFCE EPHOTY “ipeag Lope —— : : ‘ on a Aum og Tr Sse ee 2 2 ve - uyaysdy Aaayyaf LIGOP AS ‘U0y3urxay Po par saatayy ose ‘woouozeule ee “hee | ; oo ot, 2 Woa‘wozeuny, | y . ‘ my AE mt py ay ey St E88 $0 GEgabed ‘TrZ8z9z ‘6T0Z/60/80 ‘E8zZ JUBWNDO ‘898Z-8T aSeD

EXHIBIT 41 (Filed Under Seal)

The text on this page is estimated to be only 39.29% accurate

——————— en =~ = é = = . a . —— ee eee ee ee ee re i _- a Ss tx . - = -- “« _ - . = ' = : : ale a7) wk as ayeg 03 een soln | 5 | BSS) St aE | PrAso.) juno in| — hh | [hl ny, obey vee yee oe a - in " ‘ | i. iL | 2 agi A | QO Gs rooo00 Sa Tey te | ra fod A S raat aaers 'sy '> | c TWOT) Wes DL ral} — 9 ic TAACIS Vere i: | a CON en Poa nam We or UBL ml | Yc sy ‘gx |e | _ Plagty weer /ow “ 1 | MOGI zQeOS ‘ox: & \ GSridw & 'ridamy zaG8CS 'ox GT we ow DF WO | h aIowam> mane‘ CY TddIep saw We) i aa mows \ ‘hove won of und “Se ls ii su BS Re as | aan j i TR | ehuypury jo | SpUeUBIOpUY ‘SzeAmOUTyY | “ON | UNOIY YAR WY UNPENG RUA epoy pav | SY,5t *“As0H jeg yeso4/¥ JOON ‘sounpecolg ‘syueusey | wifils| Sony IPALUY B BiNnwede JO syuPEYg wesouny eyeyy RIOUty - EC) tH €88 $0 /g9abed ‘TyZ8z9Z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007055 CONFIDENTIAL

The text on this page is estimated to be only 38.01% accurate

1 ee ee ol em tet HOt IY NS ARS Syl le hy " oil « ' : : —— << Hf 9) &S ~~ As0bayeg Wey T_T Asta = | oe wit 5 —-s O— Ti | ues 83d > ') pubMuOg nOUY poy aieg 9 EIT rebakwor Lawinwsehy] Ub yridao>* pin) aD ‘SX veo! at] TB age lena las: |* hdd GX he ort £ tng tated mas 'somdus" A ‘ sy!wo's| NO ot ‘ey WOl pg) lB var aazey PII 'sy WY DL) SO DGS | ley ‘wor | OS rea \antsetanta 64 ‘wo '25| NS -) os ‘sh wo ar |B RAS NY TIM Set Ape cary) INAED Sw 2) +o) Aw EY INOS AOR ADH _ eT MO tees ‘sacl > “SW ‘anne? Aw dtu Te asaog 'si ‘Wo ‘9S wee /\ Sone WAVES MOVOUS wo fat 5 | ™ tf] *@ SaNADe) Wop As ‘WwW 9/ox tO) = =a abs D 7{\; COS wovelea| | | 7 DS S / [_———$$__——— ioe hea| | WINS) TOd | PLGOLN] AbSWD| S j = ) a YARY UOLEIURUSDY | jepow pue | 5! may yRowy i sBujpury jo | sywowesaopug ‘s4eanouryy | Le sBOQWNN ‘gaanpooesg ‘syeuoy | yf] Sey jEnlaly BF Ganysedeg so Sy4I0g guissty | €88 $0 sggabed ‘TyZ8zZ9Z ‘6T0Z/60/80 “E8zZ JUaWNDOG ‘898Z-8T aSeD GIUFFRE007056 CONFIDENTIAL

The text on this page is estimated to be only 41.55% accurate

—~— —_ — —~As0bo329 WeUiy \ < ery ~ revere ' 9" Cade 4 re t: _ : ; ‘ p - “2 ’ . / ’ GIUFFRE007057 CONFIDENTIAL eS SS rg ere — a) SF) \P $8 qs ~ piBMiG TuNOWY hi mio, abey . \. Se cps SE WO? We | i ee a ad Fee st a oC —_—_— ao AIM =a MWS | eyuiolag || GkiMDD T ee =° = 18d) LOD oH) won| 7 iN Vsvelan IO dAsvadiga ' ‘voor 2 _ PIE LOA YSYIALOA wate _wontyd got gaqwdd “ FEC AMS rw ‘srl Hower eandd ‘2 a Doane Wn ge erased ‘2s eee —_444 ie us Seat Gar 3's sarceetane agra’ | en ert hats ALMUGZOID 7. ALi se Ct new | (qaatv? sig! wd ‘2h | ES, ddd & "WD 'AL = EO) wo fox | Of — L — wey, voVPonep) jraidy @ Sunjsndag JO SyNVel | yWeaty syuews vopuy ig, Aneunyy ‘sounpecorg ‘syseusy sins Sout €88 $0 689gabed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8zZ JUBWNDO ‘898Z-8T aSeD ‘Onu] que WO) SL) UO ew Ag epeld BULGES Buy PeLy AyqUaS |

The text on this page is estimated to be only 36.66% accurate

7 . . ) S, BUGS 810d ( s “8TU) G8 LUO) 5/4) Uo eu Ag epeL eyuawaieys oy peu) Ameo} MANGA ‘Aang ?} and ‘WA! af NILSIBDES al 4 1 $80 __ Neweter2 Jud 'Wolsy ' si ee. 1% ‘| aera! wor] Bh, 3S | 25806 eb Ad Sven XTxkeo>yil | > NOS | ywotariow TS C71 | Pae aeage RRR! | aL Te NAN | ewer sore neceny one} | LO SO | TANT posats vos nase ence te| | dA La [LF a | LG ney papi SjuoUaSs40puUy ‘SsoAnouERy e WADI SH ee J0yy UOgEDY USD} poy) puw aes " ‘Soanpecedd ‘symeuey | ibys | seN jeapuy F singredeg jo s}wE8d weruly even yesny | Geo €88 $0 O69abed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUBWUNDO ‘898Z-8T aSeD GIUFFRE007058 CONFIDENTIAL

The text on this page is estimated to be only 40.76% accurate

—_—_ —- = — ‘OFLU OJB LUO} SIY) UO OU Aq opel SIUSWUOLE}S Gy JE BYy Aye | _ _ | _ ————— “atv (~ auinmeubys $)°%d ee ei, e| oreg 0} 12201. | | eb : = “paamuoy nowy | wd ‘Sor peat Waar [pbs WD __w9' 2s aaa a Sy9977005W ynina? ‘2 a Jal of ae a —— \ |p rsnotse2a wd Sate oa As AM S19) NOW (2S 5 |888) ~~ = AOASYIG NW NNWIID NOS ae LES mgu9 | rw a 1 | os a ee —<|S50| Fe aN i . a ic: ox 499 ee ee. ee ws —— V4 _ wed wd! ‘2k I NF eee + SNA are ‘un a 7K) -|¢ i AQ | 4 nee g oe (ge \O8| ___ 14d A Sat AAW | PEROLN| BbLSNOLS ol Wwol4 a ad —__—_——_——— HOY UOVROEAUAPY jepow Pu ye ~As08 ea iv “— ST eeeag ened | sith A eS jeapay % Oanyacdag Jo £)t1Od yOu qo VEO | “Id ~f206ejeQ 1e404 ~ €88 $0 T69gabed ‘TyZ8zZ9Z ‘6T0Z/60/80 “E8Z JUBWNDO ‘898Z-8T aSeD GIUFFRE007059 CONFIDENTIAL

The text on this page is estimated to be only 40.64% accurate

ego _ PUBMUO.4 JUNO iPro, ebng | VL eR mE nerubys 40H S14} UO Sly Aq epew sete Eys OL Te ty Ayes | 4\w> aL aah SS dal Igidl mt iT — 1a ‘a | ~~ To VOU MWS 239 LD IW sae NTA UII 'G ; MAS yt, of None y "214205 CE Tk ere GAS sneer Cn) an Seog Js dgars 29 PL aa oS te ee aed & gaan : atest A paca see yeah FAY U Mes mH VAST ACL yw wee sae iW iil ae: 4). IIS 'KYemMaLs ING I> NOIDIY S (rAMAS GA 2 ‘vw at : a ONIN MS een iC HH YU See rox 80 22W NOT YD Bras | Lb a; ray mato) ao MAS —_tvwresoie gut Riddd /ar |S da-AdIid You HW ob ett _mWries \ ‘> L|@b! Ap ee ee z, . _ wigtd (wig | ‘Sr A seg Lig “fat aWoT a te : ar lbs} | WWol gal JILlBOLN| Abs SpiminecOpER S20nnoucyy se *S@4NPO00ig ‘SHIP tioy yoausy ¥ Omysrdag jo syujog we * WS i» | 3 i | "rl an : 66 . “APOBOED yrsoay BPY VOR EI QUEP| yrioany €88 $0 c6gabed ‘TyzZ8z9Z ‘6T0Z/60/80 “E8z JUaWNDO ‘898Z-8T aSeD GIUFFRE007060 CONFIDENTIAL

The text on this page is estimated to be only 34.70% accurate

— — — —— —— : 7 == ae = = a ee t - | Te | —— ee ty L— vy Sz sunyouiys S01h4 F Ic} yey SS ry Hp . 4, _ L999) or > DueNVOS qUNOtMy \ — ee rl BEL 5. 7 t + . o - TENS OU} au Aye | = — ; | Sc % ey abe. Oru} ase WUOy SU) UO Cw Ag apelu sjusueTET yay Ail [ : > UG ‘ | : pe ge eno caeteerlt ee Hy vA Aston eryns-ry) ~ YPM S06 rT V1 nie See aa ve Fray ima IE OC © C byes YE SENS, aay WenoNTM SV) utlta athe : . | pe “4 As AU 4 ve - PAT)” Tis : aos yeah orca ols —_ Tag ASHI yy " Doaaeh PA aso Vo Wis) 2. Ss Pid NTT la —¢\ xg rene =) O25 Ina SU) Ncigh Wa UN, Ht iNOW VOD ANE? See loveas? eee ee Ub] ei WAG 2 tO ; = | \ fonowdtdw feasga Boras a ator te 7 aunngty2 Vxtatd ‘WD layiotl _ —_ ADO KYOUND 7 ab fi oan AUZE? a 3 x Toa see 5 at wpe ras ay avn ee ch SAD STUA > hos Wola STDS ID API, RM iyaated> gindd Civcrg Tt WWo's | wolar ttt = : wants E2u tS Al ‘ yy | top (ZV \ ar2isd> PNA SivaG TU Ww? 2) pees SD Ns Ga YG erg 3S iz lomwnG AGTe? J7S0 7 ot i __-|__-22wnd OS . AOL Aging mnenanf Qh WWD 5] AN oY Ub, \ ‘LEGO (WAIBAd AHAVIA GND WI! a - . 9 z , aly | ona. 310019 ‘Wo farlOll aa) “ ; Al C J wes yaByy UO!PEy ler jepoyy Pus 4b “i : : ‘ssoaneueyy ON | UMOl4 , , a ae : —_———|_ ftupusy;o | as = a deg 40 334Jod ymony BHA Way | Slee eT ‘soun ui yond | Sen jeniuy Fy sanpedoed so 33%] “1D pues 4 =-AsoBeyep ie oaty JEQUUNN poooig 'S4sv i €88 $0 c69abed ‘TyZ8Z9Z ‘6T0Z/60/80 ‘E8Z JUBWNDO ‘898Z-8T aSeD GIUFFRE007061 CONFIDENTIAL

The text on this page is estimated to be only 35.03% accurate

21e8q Oo} 1er0L : pun, JUNO : Dp =) | - ap 9] Iso} Gey "ONU] GIB tO) SIYy UO OlU Ag epew SyusuiayEys ey] yeu Aj)LEX | = = f{ ae ft 1 SA ANPSE Maw) ‘oe FFb PNA) AW} " — i | jj myAY etl auigo> “aco Pob | WD VW | _ o i 1G | PAY oti 'wo's> cles y Dd gal | © — | wi/or 5b gDl| ds EE | € W9'or}'st DAS AWS — 7 : vigor lOOk AYS| Idd = _ seein es | Ci Co 2M ACE TED QL 4040! peng id, 3x bh] A¢ OS. r | 21% \ haNnvTd AV ALR T SS Weed CF an ADL ————— —— JF aT ferAT At ers Sdn CFSE yer ar] BAL IG 800000 a0 THHHINSGISNO = de NASTY SF OES GWIAD lar Lhb | TYd oll. __ Bree SEE. a C ‘nerencs UntrnS Gnd enh na They aa t ys . - NOW Oh AIRRD Airich vcr ptt ae | tne oot thes 1ad| a — | F. bd = > | \ | $v eI ISY J / ‘ # \ hi f | JA wt Grin G MCU’ Fae SUS We rit — eae 7 um oy onda tg go> aus ol ———. pean at ce = =~ & po TIAN SF ETN TTT —_—— —. ~ aNatect eaten ago ed Ww Yn)! >F- ‘ e " PIAA Ass FROM SIA —— — {| sil < brs td os HonAdIIw yndaqa ‘=f ADL. — & PMS sh 29g wrcortona wa'lar|™mb | __ gd —_— ~~ ae La {\ |. wongwy yozgy 20079! WO og HER gal WNL E -.|(/ la Ai neraeotacios (GE sabi — FF oA | owewe 22014 auders wo 'as7| 2b 7 PAL \\ my He - { Idd | etsob Ul | AoA ‘w'5 <b (0d. i wa | sGulpueyo S)¥ewesuopug * SE | ON | UNOS a ( i = IEA UOeay Uap; POY, pues p61 AJOBOLED WEI JEU ‘squnpoooig ‘gyseuogy | wiBiEy | SopEy jealazy 8 Ounpredag jo syuog YEO Heyy MBs Che ao €88 40 rEgebed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007062 CONFIDENTIAL

The text on this page is estimated to be only 39.49% accurate

28 Lb POL _ ap| Lb OD9) | os t esa ‘atv faq! 2e Ab BOL ‘AV . | | , AS 5 a 2 pubsucy yunOWy | ) _ i || |B L& b b Pio, afiAy | ‘SfU} G18 LO} SIL) Uo BW Ag epEw sjuBWwaTEys eU; . i) —_! S| Ys Moos Lb} | M997 | ” hy G | Syg3S79dIW wed /or|PLb 7 Jal | 7 — ¢| Bk _ _aftty | 18d _ n> 20 vA us) =x Bb -_ 19d a 600000. (og tee EN, QoL | BLL LLL. - Nis Eu oe Niall: MSY J c is y : % = ; 4 TAS bred NAPALI MD aia Gi rears Ab] WwW? read ni mioa'o¢| 5A | AC “PIG | lee gl D4 z% send sta —\ 0 . LS. ...rtrTE —-~ - a Mu NI”? yatdsd (UD ‘Qe Cb 2 Os. Hd bs —_ raw nd od Ze YS GIO wD 28 NTp 1 _ *e | Or! . * — | / \ (mor ced W200 lenny ane" W 5°. 2 r Nb - ; “7 Sy Ld i} — spyp72dtw #wI19> ‘os |bSb} | ay a Pod agy vo r Sa SOUT) aoa . . — MAFDIND VW WeIGTSOdTS see asp] g g | ly OW T 43D yi StosrattIw Yarn > ‘ot LSb * SIO 3 8d! . are hb sjuewessopug ‘ss0Anoury _ OY, UCR POPU Py ‘sounpocoig ‘sysmuey | Loy | sopyy jeAMAY B @anyiedag jo 67410 yesy sfurpus jo JOCLUM NY -As060189 YRAD4/9 €88 $0 G6gabed ‘TyZ8zZ9Z ‘6T0Z/60/80 “E8Z JUBWNDO ‘898Z-8T aSeD poy pur GHB WLAN TY ——__.......... i — —almal ii AA OO! omectis 22% (9S eve on eres. | Repay: : oO le vEu} 370 WW ”) ( =f) fy ie - uh IL } X., *, fr } rn | 0 “ Ih ait WD o US At 14 A\USo | PW L-G GIUFFRE007063 CONFIDENTIAL

The text on this page is estimated to be only 43.10% accurate

rat et Es = pukewud-4 UNnouty Se +} Rhee ete maoruna ane tuomsnn —_— -_ | | wo'ss|thh |. t2d ea uM aa log Hob} | J9L Mw? “4 — Ff |_| __weaeerti’gc| HH | AW] td0| — ££ | | | geunge, ee 4 le ae lag|%bb A Dd AW | ae lwD ‘ao ish ask. pane act wAdS ‘Ws /oy FIGIIO sides ‘aL! lob — - ops 9 Sh = UtOUN Ww ‘ox Lb — WO lag | St 4% - ~endah oo AL LIAS ee = - ae} Lb ‘t US | — 99514) “55ST M957 BOL Fags s al. Gs -| - } yaey] VOROYQUEpy | (RAY B CuNpedeg jo SpUyOd | ypunay + AsOH ORD WRAY | €88 $0 969aHed ‘TYZ8Z9Z ‘6T0Z/60/80 “E8Z JUBWNDOG ‘898Z-8T aSeD GIUFFRE007064 CONFIDENTIAL

The text on this page is estimated to be only 41.26% accurate

, | b| CooL 2 O9ed OF IP}OL a — OY 7 eiueutie syoqd CLI REET panies : - 9) bE | +h $} | "RR bed ‘enu] Ose Wun) RIL) UO BL Aq Spe SUSWELeyS Guy YEUY AYES | augpw dfw dodo ‘of rcol YD 3 AA iA | s s|} Saggy 2909w easing?! DS “rH ANW 49) eo Oe > (ULL S9d> 2) biel Aed | 9P7L] , f were Sh gee is “= * ' ; ror ich “Cues mayer Pent | BION got 3 UY S LUGS aT | TS MIN TVD 'gna WP? es gf 2F Lio\ US aindw aeeiere oS a ; =e Te fl GJLSWH | b : es \ Listy LS | oh Wy - |S 1 S\ “A WTANER + 349 PATIL bh |= BVUrd q\ VEoTs annum INDI Ane TaWs>S sI4 ne BOMA “sdntasay CTY \ 'an999> Mwts Lurene rose yarie Youn lat | Pa Gan raat DIM) 1 5Std4y LS List Osa ! SN Uw “305 - DIT AWS : Muni ng2s>? wedra 'wo ‘ory al Ss Ted TETRIS a _[ | | Vy yotata ‘srlobb/® | sags AW) | 7 | tT Se TW ats ened wo Selhb] [aad = } SSujpuey jo S]Uewess0puy ‘Ssvenneuryy on | unoy ——_— Le ““AioGoye> yesony JoquNnnN ‘sounpooosg ‘exreuisyy | 24544 | seqiyy feApay 'B eanqiedag jo syupOg BY VOQEYUSD) : watsouly stip pue™ jepoyy pur Lp % exe yey | erg €88 $0 /69abed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8zZ JUBWNDO ‘898Z-8T aSeD GIUFFRE007065 CONFIDENTIAL

The text on this page is estimated to be only 40.21% accurate

€¢ | hSsoL. S18 03 FeIOL PUBWAIOY JUMOULAY (210) efeq A 1 NAW DAS foe ATH ’ = v y\ Ww og [LEN rc] A \ VAT £88 Jo g69abed , ator Jag! ta eee geslocnansy w ered Wi Ni CIANOO Widta ‘anew BMISEOU [at ZEQ hd | AWD 39 * GOOADA SUW EA AD | Vy PAPE s Wextagos soos ScOl OAL. WW. 4 4 | WL dont » anals Re be, it 7A + W2 V/\ net sry (SPIT AWD cna ~The pre \ wow YoiLertt ‘ar [eM Poly euperise syuowossopurg ‘eisanouBy | “oN | uN. WOW UOROYRUSP) [POW pur =hseRayng Wjesoay JeQuaniyy ‘Saunpa doig ‘Syreudy | weg | Say peApey B Gsnjsedeg jo swuied | yRupy AWRY URES MoT £9990) Pte uN 30> “£4704 nie au ~ r ’ INAAGdD ‘ax Sea 4 Suga ‘0c Ves ur ot aa 3 FV heed trite send ae $Gid E 5 ae = neo | nad OS S 4 te UT DZ Pte? ‘Yatetu ‘wD ‘ar fe" Ags | FT Wd “A new adse7e ‘grieel] | fW? | ami z= ad we (95 ofp | eh 2 & Dh A A a4 =r rors aunyouBss Sjoji4 ) "aMu| Gus W20f Spy) UO eeu Aq eprul spuaWweTeys By) Jey) Aja | —> G A | JDObVI abso) fh. W996 N | Sey Onss3aD fae 1 | OZ [Fe [ce wosrlboyy | IS3 wor] SA ASAD, POT ow no wo! 2c t29\ NW Pa abs Nw Vv | yA ‘TVC829¢ 6102/60/80 E82 JUSWINDO ‘898Z-8T BSeD Sh yA un | fe | A a enn = al | Ts : . + | eee feng soa ego 9 a) | Nwot, ods7 GIUFFRE007066 CONFIDENTIAL

The text on this page is estimated to be only 29.41% accurate

aingeubts sjOd - (5 | "OA BG LID) SfuQ UO Ou Ag Soe B)UDtLapS Ory) pat Ayes | 83°C 9F IF 191 puewudg JuNnoWwy jajo| abe ENN | « atfang nedger!¢s179! Gases j f 30 Le WS) for | L2 'WS lar Ply | QD oNgokd 2 gs mehW entrap pied PLC FAL OV. ACL As0d RO | WHO ll 19d | FSeObN] 9 vS119)/ ie — oct] 18d \th-o pee stecbainteesiananmhemph TAS SLA HADYT| Lee el aii : waLsaves Ann foe|U™ LONVAD Lads hodo ‘bo 'w9 ‘or aro" | gywoy 1/69 wy Paco! AaneA awa Jo0 rol dt ‘yataay dng'wany) ‘sp UQlor Br Ths+ bw? Ws lot Mv Lwwa ‘ox [OF oT a | E citer lmee eBupues jo a , UY UOP EY Map jepoyy pur | Lh & i yoreny HOY YOUU mq 7 “ALOBOIED YUsOAY JOQUUTIN | €88 $0 669abed ‘TyZ8Z9Z ‘6T0Z/60/80 ‘E8Z JUBWNDO ‘898Z-8T aSeD GIUFFRE007067 CONFIDENTIAL

t ) RR RMP ~ ™ “GMi} GIB LOS SY) LO OW Aq OPEL SyOWOTEIS OYp JELy Ayes | | ULE Lie) GUS | Saco ED i 710000 YO IVILNSGISNO eae €88 $0 OOLabed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUBNDO ‘898Z-8T aSeD GIUFFRE007068 CONFIDENTIAL

The text on this page is estimated to be only 34.88% accurate

ee a an) |__| A nia ipso ec a en C1 —_ pape ELM 4} 324 onal - te ix a || =» <laeale eo | OFL mg ee ean u ests a €88 $0 TOLabed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8zZ JUBWNDO ‘898Z-8T aSeD ig oN re WSN VOREOYNLOD] BPOW OUP wy jeapey 7 mL 20 SyUjog yeuiny ee BRAY GIUFFRE007069 CONFIDENTIAL

The text on this page is estimated to be only 37.33% accurate

= S Wie ye aed 03 1e}0L o FRA ' wh wa HBUUIS 4d [TP fete RY pans oD . senna eeemmmennamion 2 Ce a dh 4 i) nso | | X00 NP | tN me | A AN Gd} ot 1 a ee a eee || se an M a —}— BH oat! Pur ooa Yoni iS OM] Fee) wT ae | dues SSG 72! JLB “ “en Yas pyod> ei He / SOUI2 & a, & {Ie ae — | | | ___t e | | -e | || ‘it gm] {| igt |. St 910000 YC IWILNSGIAN@D eit Ca suq{ SOS) tS 2 | [ee | Yi =e SUS| 19d | ASSOLN] ovsS]n\ ee | She | Sed estes aldeet UNT-FAITAK- GN VISLN| “TLID] & Ss —} gl | S/S “Lt _onssa Z| | an ON eee et : oa sande (oman va | onan | oh " ~“u08eIeD WeIouTy joquiny + pep oda (tema sary “january B oanjznded jo siw08d SN YURay | seg €88 40 zoLabed ‘TyZ8zZ9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007070 CONFIDENTIAL

The text on this page is estimated to be only 32.53% accurate

ORT POTS 890} ) — 4-1 Z Ze Cho | 9d 2a NE UHOF SI UO OU AG OTB SROLIOAEIS UN TOU) AyBIED | eee ae Uewos eayltea Gor) DY. [el WW G Pag " nas aT . fennes "WOR eee paemk ctouet el] | ONT PONT, 2 | anions Gasoline Rae ae Sm | TAI os ware Eel! Oa srewai ete) | GOL AMO Lem aw nw {al ner! nena ng) [TC Bppeiahs cueeh EET Th gal] ‘ oe iif ra FP $ : 53 : | te VIAL Ae A LICDS: re BIRLA FEA 2 hanGsad wos smarticny. DUIEH ond MAMYQwWsa WOHMIS sey WITH Ur LN DAs =e AMADA Maal Avsane IW? ©. = VINIENN St PK WU UNSERIVS Sno AoAbo| | / ZL0000 Yd IVILNAGISANO tr i SLE & | J he! i | 7) £2 ALiszegs snvd Wwa/pe [Sev Ce as ze AaoBayeg weroHy Se 3 es | CHEW WEAHIY Er) €88 $0 €OLabed ‘TyZ8Z9Z ‘6T0Z/60/80 ‘E8Z JUBWNDO ‘898Z-8T aSeD GIUFFRE007071 CONFIDENTIAL

The text on this page is estimated to be only 32.40% accurate

eae Pe onion SPU} GUE WO) SIX) UO ew Aq epall sweweLES oy) [EUR AlNiad | ain | eek | ed nfgeee “3 Pat} a at || fee tering pace ee (wa ls eee SUS | rdval it peo snd LW SH | I Add SS see eal | oa | tt rsett. ot a ic? || — | NYT AdNEW Sy HS ee re aR Ee SN) stl Lee” IVY, ‘at : mun ‘Sa VN VW A\ Te TY : : us 3 eb, j=} esl een tad 3\ 810000 Hd IWILNSGISNOo eA ; a oh *h \Zh? t=} noes (Zh DY Cl p__|i| Kise) aaieheis Spot | Tos] 809 [Seon oT u no aT ere Poa ad ewe | Oil | S04, Feaay y ounpredeg jo sued | ymmuy or een Healy SABY\ WRAY weO €88 40 vOLabed ‘TyzZ8zZ9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007072 CONFIDENTIAL

The text on this page is estimated to be only 41.25% accurate

“repay 2° “eru) 82 WO} SILA UC Ow Ad Spew sjueWazEy Oy; RY: Ajysa— | woIDY [PPV SP Welly Te 7GAL c ea ee ee ee oe LEGON AUNoH Cy — OF8) a oe gal ez 610000 YG IVILNSd FIN fa €88 $0 GOLabed ‘TyZ8Z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007073 CONFIDENTIAL

The text on this page is estimated to be only 39.92% accurate

o7g 5} /PIOL Bee cia ee ee Se aie ; tte Bi] ott oc ee oat AS {swt} aw ~. Swi ee wg eo +f a oa ee eer rae eerie + SD FAG Cort mas UD | Pet SOO’ 020000 YG TVILNSGIIN@S r €88 $0 90/abed ‘TyZ8Z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD m“" | NL PAM TS TRS Pw | nf b mmm TMS "@ruy 828 WIC SI\\) UO Buu AQ ape S}UEWAYETs OU} JEN AyLed | Sieons | ee ee a ~ SbSNDSe ‘4 GIUFFRE007074 CONFIDENTIAL

The text on this page is estimated to be only 39.11% accurate

S| SNL 299g OF reek “UV TIP (| yar or we eis i tat felons EB msn } : oa ag) ee “Oru GJE WIO} SH UO OW AQ OPEL syLOWOFEYe OY ELA AED | J 414) pe a SM or.| 133 bb | a a3 BAT es ETAT Pe : | jt te TT : : ee a aS cA PAN AIUD TAL PAY | Soh] OM \\ — bo] | JP. | | time eect a) Epon | PAA ef iy) _{ ___a 1 A a | We faba ef ae : corel cee le hl i | i) US gel a [So a tg y n_[S 1z0000 Ya Twunagiaon _/| 1 .\| ————resacar sare 7 v_| a i | —-t-—-fde AN oth Lt DSSBOLN| ULSI |< VU TD) PPO Hoy ae — aad ee “-As0Be12D yeAy quinn €88 $0 /OLabed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUaWUNDOG ‘898Z-8T aSeD GIUFFRE007075 CONFIDENTIAL

The text on this page is estimated to be only 40.33% accurate

Ue [hi/StC l/r. eyeq 0 mor a ah) | eo TP a sm wt wd Torley] Fbeayeg PNA Se leu] MOTIOD Yo HTT Sagas) Gl DAISoBe4 ANky [Oo Ary Mang fie\sy havoy WY Ady ay ‘edoyivene edd ‘vA ‘aL ey 7 weap} aa 7 ~ marae cL oh Lt p iL : F | 220000 Yd IWILNAGISNOS ie sai =: Sat SN | ow iE i) 23 3 a" : H (poy pun cyst SHOW Ymony BEQ { a a ee ‘ = yo €88 0 g0Labed ‘TyZ8Z9Z ‘6T0Z/60/80 ‘E8Z JUaWNDO ‘898Z-8T aSeD GIUFFRE007076 CONFIDENTIAL

The text on this page is estimated to be only 34.89% accurate

cle |§! wel |S eyed 0} pepo J fee! eae ) |} ae oa ae a 0K ope a a 0 IWAKORN | O\thD VOL bf to Stor v3 2h —|— ok AWD] ‘\ Werte ya ree) WGI ' LD | WD! et Ww? +2 Leen Be) <I a F aS roa ay wel ull | eal] Feat tee Fmemeag aw | GALT FDS| on aus oe [sal] TLimagsyad dard fs |MN dj gay | ariel ao) th Tan kary wagy xD SER Oo | 9 . creeenn rus vena GEMS! Sal! OB] | INS et YRROE | Sa WH REET Tesi = ean os por eAwiy @ anna sO SyLIOd €88 $0 602abed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD _—* + a " 1 ; = oe ; = eC Se EY : Aw . : 2 Use ** — Ne Tse ye é . > GIUFFRE007077 CONFIDENTIAL

The text on this page is estimated to be only 38.40% accurate

“tT t % hoht a 81Eq 9} BIOL ee 2 a Co c Lt hd | _If ee Lh | wis 9 [tk FS oe et ee Ft WI los [| sol] tol) on oe ie i To Waar a [| It fe ain Awa Tar Pay | age | || UG SLAIIC ‘9S ea | {i a “a ed: — |_—| -—'5 | {te oF HOS q ST Oy es a a CA Bio> % GO|! \itigA ROS Te PONT e530 FN RWS [PL yz0000 Yd IWILNSGISNOD || ‘Kiz | A) TASHA Vaal [ROOT ne pe sCuipue jo ! Sanouny Sm] eanAy wewmmedeg 10 eyed aN — wrote _ — ““hsaGOwWD 1849417 vequaIN ‘ 24 so) AY ocnceat een tae Jo ByAOg wG |} e. | 1) . €88 $0 OTLabed ‘TyZ8z9Z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007078 CONFIDENTIAL

The text on this page is estimated to be only 37.58% accurate

RRR sos “BTU OU UO) SI) UC ew Aq epHLL sJUoWUEIEPS og yeLR AjILIED | Pal SUS : __ es ap| 4 | H AQ 's peu Kevin) st s fy i s: i) APSIDA POTENT wey tay | 57 . grr roan sarbace “haat caf YG Chg ron seca! | Sa EG | reponse io ilugeg| how j one Boas) Vv. aU wi Ko DOE, a= Wt [| et TH#D fr2éMgES / F- iy | Ctaeet SAPAMIUY ES J7 2IUBAYI YY ~ FZ ‘ls | Ar cre "Tr | Sma SS yb 1 | Ad b4 AW. . the S + Le We | ‘Lt? I, Si. re ’ _ - yey ” fe es C ~ Es th TTS po Ly eee Meret ot a str OP eS eer ee ote ee ra - =* ie eX: ET I Se es ee tase > Teorey eel ee USS in Ar. of tau | entra SUBWAY GOW RSYRUaD = Uke [Pa(4y P eanpedag jo syujog welany ore yey "s Je aie 4 + Phe etl A S ’ Pa €88 $0 TTLabed ‘TyzZ8z9z ‘6T0Z/60/80 “E8z JUaWNDO ‘898Z-8T aSeD Y hy | > % SP | awa oT Hd saa fy | ; GIUFFRE007079 CONFIDENTIAL

The text on this page is estimated to be only 34.97% accurate

Op 03 peOy | PRG JUROUNYy je1a) efe4 _ 099 KI LenIo SI? “woe — - AMM D> OMIA | MND IMYND het bi dL, (hares sof ny 4 PrP GIS ded Loox TH, ae. ae te | vse aaa ke BAO Nt TE ? a | i MYO) 5149303 Sx woos poaae 7%, PWAAt AD VS VT ons yal 4 aR GA RS SS _ \ . : ; ne dsah CGN — _ rT A ne ra AA : 5 f 4 Sore ra __ Aad ri i adhe RAN “Linn wartingV > Wotet We Pt __ ofr fe efes ~rf/ fd wd PPM A , (A aed of e5-26e ) a Y td SF -2t¢ Yf ip | AY geet ee pare Se Fe ul A i“ Coes ee ea! CATES eRe Layee F . ; ‘ S | S 920000 UC IWILNAGING@D 21 / | é efi | | 2 ‘39 ett aa La a cee pee SRI] PANS TTY err te TSM E Sip Sg MSU ARSRE Hy Ek. age SURES oe 1 is = iF a €88 0 ZTLabed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8z JUaWNDO ‘898Z-8T aSeD ae a oe AYS — ast fa 65) 7753000) mel W : Tara peter es is ot aes Sud APWES TALseY iteiee menue a | eer . i WojGAs Sf Swen = 4 AFOTIOLS ON Poh AAD ee ORR RS $,10}l< ; mv myers ee ss C199 Re ate ; GIUFFRE007080 CONFIDENTIAL

The text on this page is estimated to be only 37.94% accurate

£20000 HQ IWILNSCISNOO _| | efee [eft aa | ema . \ 5 et) ee ee or 08 oj 9 uo us Ky ope stuns 4 AAD ts ie in|} dvr. ti TD. Ayid ae i. ae oe SIh WROTE Moles et wok gf bh j We rai] im fault TraKtd a ODA" NALS UT >! Mya é Xd 20h pe . ‘ ae “a . Se ‘ a ¥ 1 a : ‘ E 3 Ve F | 2s i< : Ng : a We) Kea gre J] 4 ir Sp anf ies wa JW TaN [NO [ar WEY LOUIE EP) “—fuobayeg yey yoy 1 EE M fayyreus a | 8s | 999 enary 8 21 jo SyUYOg €88 $0 ETLabed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007081 CONFIDENTIAL

The text on this page is estimated to be only 37.60% accurate

>| bS 4% h| bos ates 91%q OF e704, 4 a Pe ee ey BAC Te. | es ao ps7 pen | | Old wfA=T ge i tb peods-2 ‘por 'tovby)1 ay! | | Lee UNL SW) + Ssartnas ado eta fated OWd!} = 4c re | Lecco ire as Y ned ae = ase Bons ie Cia ) $ - | 870000 YQ TWILNAGIANO >= | le = mat ree Bean | ¥ i SSupurr jo = - \ f j €88 40 pTLabed ‘TyzZ8z9z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD pees teneel 7 Le - ew . ———.- . ri + $s . oe SS et oreo e5errorore e *¢.? —=— — _ oi —_——* ex = ts, ea i ' ' b i = GIUFFRE007082 CONFIDENTIAL

The text on this page is estimated to be only 37.22% accurate

620000 YO IWILNAGIANC “srw “oe sas, bt 4 UP einpaufig $794 eee 3 yaoi Tedd bare cams eee h@ M , Aa oy } ’ As Bear Bong ann eo alan HO] | aL arb OLE] Cs W) Woo DINKINS AE HL G Uiwerdentideits ' 3D 'wolag Lau | eaeg ays | | tw ss) en erss €88 $0 GTLabed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8Z JUaWNDO ‘898Z-8T aSeD est + a — oe er re ee . ———— nat “ =_ GIUFFRE007083 CONFIDENTIAL

The text on this page is estimated to be only 31.71% accurate

me fa ee 8 <item — “YL . 4 5h thSL} pABMaD-S JUNO. MO | ° } \ | Bcc I{ 9 a eon meni aa RS EO [5S 7 lamas ‘ot ety | ao | tt ete P45 mcs enh: eee | Tt He Earn ee ety | caw aoe |] gwd ARKH aria oem] | deur nhik -dWe 44: isin Seogaea | —|—d ct yey bntaash LPI rot Ne} 4 aS 0€0000° Yd IWILNACIINE 17 bcc PA! Pa ees ca Fe tat aa ESV | alata) So F ‘ ry . Pen a RUUD ZA EA) | VAM) | ne UIC y oe "i sfupue) jo | ‘SusAnour ‘ON ‘ie} ——_— WFYI nee } “Ksohoyeo yeicay OCU ‘SOanpoodag ‘sysetuoy | yyy | sayy dE oe see Oe Ne se RE eRe ON Pere ge Bp eee ey SEE ERE Se ae TO fee OEE PE Eek, oT, eRe same eae an nn ATT eee we ere €88 $0 9TLabed ‘TyzZ8z9Z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007084 CONFIDENTIAL

The text on this page is estimated to be only 37.38% accurate

L€0000 Yd om t+ a [oA ay tk ie a) a) PL TWILNSQIAN (0 aye : ut r ; a 3 9 z : 2}8q 07 (#10, = pMUMIO4 junoWwY ac : YN”) “rake SWE 9 he DAN aes 2 Ler Wet ar <a _AaTIDS Bet | ta: apse] gS » 17 a a m 4 = YS [285 [AAA | aTEND Re 2s UOWeoysLapy vemy | Oyr yy YROY €88 $0 /TLabed ‘TyzZ8z9z ‘6T0Z/60/80 “E8z JUaWNDO ‘898Z-8T aSeD , GIUFFRE007085 CONFIDENTIAL

The text on this page is estimated to be only 38.78% accurate

+ mesons « te Lo | et SY V9 PY as = we J oe a) cr a rey i 4 J y - ; *) =. =- ay ee ies - ae ie owe 2 Peis : ' | | | ! j a AID STO | I. rs ZE0000 YC IILNSGIAN ney Cree nnenrry Tera : ! L i a oe ee Ale Re \3 3 €88 $0 BTLabed ‘TyZ8z9Z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD j 49d |ALZOLN | SLSW SD) [Se mS [| [Re GIUFFRE007086 CONFIDENTIAL

The text on this page is estimated to be only 35.36% accurate

e cri a 5 LD L274 vows we ssi “oy 7 we eM BME [Bac ee PALA) [| ths | t/a —}— t+ WiLen raw MAD LOW OS -—H [tr Bee Fitaw al ASIND AGnY "ON GIB LUO) $/4) UO BU Aq ep suWEyEre ey) JaUy AIqUOO | e AUS) 9F e re 19'S ial oak Sea = é Sim onng dads '5D [asl , : ey ‘4 se €£0000 Yd IVILNACISAN@ ? | 4) 29 Ppoyy pue i OYE Beauty be €88 $0 6TLabed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUBWNDO ‘898Z-8T aSeD GIUFFRE007087 CONFIDENTIAL

The text on this page is estimated to be only 37.42% accurate

: ML Jo jt ean <4: 18k Utell] Rs STL eae Wh ae pH ATS IW Chord 5 ra *yyey lege] Bet | baa : a a weeu VE (e19L alt. x97 YIOMed AA IATL tas SS SWoted APU S So74 re MEAL ons ®jors” FP 2lbl 00 AO WD AAIIND © oayenyig £108) Soany NI OF | “Ieetortiy7 hoamoyow 370 MTOM TEL ‘SO2d 7203S sainy 1102 AAs VIN wr I ah aviet's TH do so wha FE RS NT SF TFT LI SI ERENT SEE PP eee ' ivy) OD ve0000 YC IWILNSGIANO Fer ga? an €88 $0 OzLabed ‘TyZ8z9Z ‘6T0Z/60/80 “E8Z JUaWUNDO ‘898Z-8T aSeD <7 oz Pathan os a a eas dW ( wo pee gwd soba Sas ssi asm ouSItd| Sz BrEAUO, IMCUUNY OO pa be - , *t EW LOPRAYUaTY USANIY GIUFFRE007088 CONFIDENTIAL

The text on this page is estimated to be only 43.83% accurate

> y sh qe [hfoott| ees anion , ete YD | b 4 | fob | ‘efu} O78 WO BLA UO ews Ag OpBLY sjuOWS]E}s Oy) Jeu) AjfLi9d | a Hee weary wow mew) || SG) a gotl27 [Cu buat ter orto 87 ae/47fy sh | | bWd -2h3- dW) 8p =] er a St oto eat 5 ¢ yore ae aed pve tt ee ALA il . t+] : = fat SE0000 HO IVILNSGISNO2'|' | | PE bbe 2 ao ee 28 . ee A Sowet 2394) oe fi Ty eee +9 €88 $0 TzLabed ‘TyzZ8z9z ‘6102/60/80 “E8z JUaWNDO ‘898Z-8T aSeD GIUFFRE007089 CONFIDENTIAL

The text on this page is estimated to be only 31.06% accurate

a Ct Sia re aaeeeehcascenadl “ath, 1 [h oH eee prawns juNOWy rte 1s a > zr Pw COMET guys, Sets , mei : bak wv Se | RRP yey) aan A LS PWT -|+-—--- Pe Ti &} “ =e Uke ao ow _ = hTULAA YA) Aaa TS hgoyuy Bon =z Bee ews Sarde & der PAYS Mita & MA MAD Coypre yer ee eit Bote oe Sy ‘ . f 9€0000 YC IVILNSAQISN PSMA | ate hb Fi VAP, TUS | pinmur rene 0 e847 ween ee €88 40 czlabed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8Z JUaWNDO ‘898Z-8T aSeD MOT L. CIT hn oe eT Sr dwdl adtLn| ¢7907% & | a yi | wx} ——— WEN UOITEAYpLEp) epayy pur 2 “one SON iMApay 9 _ 5° SpUOg yeuauny enjeyy wexnry hx Ive TH eon = oe Tu] CL WO} BY) UO GLU Jig spew sjuaUSPERS o4y PY) AyyED | GIUFFRE007090 CONFIDENTIAL

The text on this page is estimated to be only 31.38% accurate

TOME) FFD ‘ONU] O78 LUO) SIY) UO OW Aq ope SyusWOTEYS OY yey) AumIeD | aoe a a et rae at arg4¢7329\ '6.> wast Ent] | : MIS 4059 wo! se. hel Bd E en : tt ee 2€0000 YC TWILNSGIAN a D eeala | 7g © Ve a a ee | y\ 3 g2 Wb MTA shs nora 2h 19d) ee atten dace MN TMone A Th ¢ ae e | j] Fie | fi” | OPE] FID | 2A F . mbiniionen peisay s6ujpuey jo Jequuny -~* ee : Seok rae ; i eae a pap Se oe ies Sees Se ea y - ok ed - a. a — _ er r= r _— mn . AQ se = AN a i —_— e chat. ee ~ = , : ms ‘ioe een he eon 6 : Poa SP ha aes “4 Ke 7 . = coe a? io Ss 7 > TP te e oot =. A: i- Ao ek. ee a Mp a el = : ved fret *Are FSS re Ee Rr od eee Se ~ 7 | a LAR = es PT 5 : e's a ~ ae = * aT TSN RES = Sap See ge FM, Tt a oe : - =e - on Ee Srp e " . iy eet iege Otel eS AS a es) eee es : ¢0e" . €88 40 EzLabed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8Z JUaWNDO ‘898Z-8T aSeD GIUFFRE007091 CONFIDENTIAL

The text on this page is estimated to be only 36.22% accurate

fo) lee macy Be ME > Oru} G7E UNC) BI) LC OW Aq apBUt sUewa;Ers a4) peng AyiED | \lG Niort ‘ANS h ohods You aes hatte | IMB AMY ow Te “ugeng now eodetseiges| |_| aL] ASEpemRaWas|— if rmiWeye/oruas wy lao matt | JUS| Sol) kad Samay AATIAY lett} stat | Fns7 Lara $/of me | S88 — BOL y F Srl : me Wesley | POM!) de] on _| n_ | el IA w9'or|S%ll | SV9D | wO5D7| u |e ANT wove [5937 951 PAT lpn feel | aT 33W9) fee pA wofer|Fe | Xwwol oat] EY et Pt 1| ast g¢0000 4d TWILNSOLAN Ht SA : b lescrtl eee ep s €88 40 pzlabed ‘TyzZ8z9z ‘6102/60/80 “E8z JUaWNDOG ‘898Z-8T aSeD GIUFFRE007092 CONFIDENTIAL

The text on this page is estimated to be only 36.10% accurate

)| TA ig/s¢bl {ee9 ered 03 12202 a | @imRubyg $)0%g Vt €. : jb) Se8L Se5¢ | premwoy munowy ? eet enero eel ee ee ee ee mel —f-eson| set + L\ ee ee 2 SimT AI2AS ‘ret | ggo7 pf UY fj ANTON BON opel [saan] eT i 7 LT BI PY PASI ga} gab Tae cia] | dal | 83 | ft tt ble “el ret ee ft se nara 3 WS ott} seat eet Te | TA eas ota wasy orl Pp] UT UE A lossw YH) ol REY I Hr LA YLWVID AVYBEL BS at | Sa] ANAT Pict pas pat WW 9 ssa —| a 2, yeh oe G t i a ee 6£0000 Ya TWILNAGIANOO pt ae } ij tt ie | Pt IR tty eT aT REND POC Ba ““fsoGeyey yeiony €88 $0 Gz/abed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8Z JUaWNDO ‘898Z-8T aSeD GIUFFRE007093 CONFIDENTIAL

The text on this page is estimated to be only 31.47% accurate

—————- = ° a SEBU “ees eisS | be Pre | AN Br . eh | : ele | Yi 6 ee IA zi ete SeE hh | A : i ey Pee, - P a ea ‘yr ee SUP tee ‘ " OO ee hg Re om 4 , » “ 0v0000 HG IVILNSGI4N© wiv 8 ; ‘ey = v S A*aa wht US YC) ie ae D| C\\ . ‘OTU) Be WHO) Sy) UO ew AQ ape SjUsWOTEYe GUY yeL AyeLiac | “0 oo, : 7 ee j San AMS '35 elem | seg [oak Sa eet OB a se Lvols| Ol gl Wupra|pae [ow [nse »\ ae son a ee meg ees SPS Vt ok des Psi ace ee | tt a LY. t s FH Pea E sCupusy jO ON } Wade} RYN UONBANVEpy jepon jue | Et “As0G0i85 yesay seCRunN wb ‘corn poayy 3 ee #2 SyUIOg Yaouy ep yay |; eq a3 ae abi2i = — eye 4 ote eit a x =. om . ear ros re Peet aoe? er ¥ ae r ere ieee ye aay e Lae ae Py oe Lie ~T S oe Ps PRT eye oe Eee pa mers yee pee ee Pn ULAR (OE ©. 3 e ECT Saga Shaye Baye OO Besa Ban er aR Rene eNtoge es tees i €88 $0 9z/abed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUBWNDO ‘898Z-8T aSeD GIUFFRE007094 CONFIDENTIAL

The text on this page is estimated to be only 29.73% accurate

iS) 9a (eyror ae POT Sn era "OM Je LUO) BIA} LO OU Aq BPRUN s]UOLOYES 94; YeUY AyqIED | ik 5 /\ ie tot rns oe re = : Set —— = Ee) air aie ik us D ae | rs ‘se y a - . a. 4 - AP ie hit git > flees heh) ee Tae i eae ‘ , = f a . ’ . s . oor me a . ’" * ve tia rt Pe ee te eee ‘| . . oe a _ tS fie . 1y0000 Yd WILNACIANG@D- 7 €88 $0 /z/abed ‘TyZ8z9Z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD mien eae] | Fea] 89 T sy [shes GIUFFRE007095 CONFIDENTIAL

The text on this page is estimated to be only 36.11% accurate

7IeU 41 VOL Boo de Ces) gt — ro pes a C ee fos" hE al! a a bP <> 7 sebaotest( 1619 es a Now pokey OE na ot WI99KN sh IMG DIvtovin (Lp'wy' ol SEH GINIDYIn > AED) 3S) 3 Be Os SOs ‘sty a GrPS PIS OTA oA WHO) BAD UO eu Ag apm EKIeOpRIS OY) (BYt AyLied | Teagan err iy wresed ic Gal a RR : i tt plbhes sol hs joe de= Bo nga Wn i-+—2" i » {hl aR et, RON Sat ¥ | op aa roy" 058 mn i %\ HABA (ee ATHENS WI BTA — Serva Wauss> es CY ous | AS alow VOOM IS | aot =U ~ “yg! Ut _ _ ary a aet eae Rey aa St AT He beet eae Sart wd GaN BY x) Tes IN Su/ neodw Tc $1S0s1v aneser> ig] || MOS sN°S Pad sno see —/ | ae - p TT ey, caer Te Patna Smears a oo ies Go a "of ’ ; SAT ANDES Nol Seo? damon a FAL STRAT] dy ae 2 Jal ZP0000 HG TVILNAGI4NO were €88 $0 8zZabed ‘TyZ8zZ9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD OR Gyre eta y t GIUFFRE007096 CONFIDENTIAL

The text on this page is estimated to be only 33.07% accurate

rE | ; euTPOUEYS 9.204 ? “OfU) BIB UNO BY) UO OW Aq epew sUEWOaIs ys TEL AyWeO | 3 ae 2 Bence aust TF Sheltie =F Bl actle \ WE ‘orton d anu ee A At ANdaD wast uO pA (Slag nd TTT i ‘ . - cee co Tere PRT Te ae 1 ¢ eS eee e ity ta So) mee ee ee FETE eet Pha yy Fe a Se et ee ees KA te = * > * ; ys, Fare FGI YA Nola eat VIF Chee WS 2! woe S| ae Ak CYWIOM GIVI 9VIN (65 olor Ah! eS Ps 'Griaresg - WARM Avs _ INIA IND VALS “Gyryinr ~SHOMOU Lisiys ST VIN & LMA pos 2570 Wt yD a ist | fyacetes rms asa. fon Lis 43 a ois arenier tian et tt Spaye YUM) ya AETSNOD Kony -anvw MALY ele i tT aa £ ‘ . . r Lo POIAD 0 ~"AaoBaqen yeroyy aun e AEE ene Ne €88 $0 6zLabed ‘TyZ8zZ9Z ‘6T0Z/60/80 “E8Z JUBWNDO ‘898Z-8T aSeD GIUFFRE007097 CONFIDENTIAL

The text on this page is estimated to be only 26.66% accurate

* eI SUB! SN? O18 93 FEO) = aanqaubls 9,9014 PUBAUOY JUNOLIW , "ONL GFE WO} BI) UO OWL Aq Op SLeUIAyRYS my) EY) AyBIEO | commen ee ser » | _1< ao a \ ? ee 7 "| TE i. rn) ae Eo r Ps c rere ee ST a rr ees oe ent Ts Pet o ret . . ° - . . wee ’ ’ . | ' To * ! ) os i bch aad FRc SS ay ' 2 TTT S| Clea oo ; b yyo000 Yd nwuNaaLNeD ~~AsoGeye9 ypesoapy Aaah feapuy gy aunyedag jo spuog ah P . el z ~ ~ eo [ na #4 Aree —" rT Ss ows) a, ee Sw . is eee ee . > ToT 7 ~b, oe eo re SS ar = - ey) Be ite . bMS e aah te Se 5 — a ed “AAT Sern. + w ne Eh Tes Tr, ene = ~s. me = ' ‘ > 7 +eP, el at Sebo Mery Re. ° se 477-3 . Set ey Ba ot 5 Set oe Oe pals Sharh ff 5p 2 a aos Sr Oe whe ozeten ree: Be ASE ae tae ae ir tes pate ed grees PA FoR eae RR Reh ee ETH g ree Bae te nl Pee a x ' -“ <4 . ra a ‘ ‘ r : *. 4 . CoP 4 - 5 = 2 ; oe mo rs. panther te eet 2 ihe yelse Cte et | re es Ss erat se +heTH SP Sar ee th, €88 $0 Og abed ‘TyZ8Z9Z ‘6T0Z/60/80 ‘E8Z JUaWNDOG ‘898Z-8T aSeD GIUFFRE007098 CONFIDENTIAL

The text on this page is estimated to be only 38.16% accurate

wa, mais @28Q 0} 18304 PaenO4 [UNOuly “V, Stl iae n| ae at etal} sa hb | SA een agin] | YS 10'S eps’ TAPZYEME Ans A inh ‘Wolfs Shh TWA herpes! a" AGU PY IATKICLEA TSI9C 9D WE ee E es meyer 'Ag?¥n ee A Sv0000 YG WILNAGISNOD| | | [\ "Tenor eS. en 79) Lf _ = JN | Sedans G95 Sel snoss yyow als RR FAD para add {+88 -+YS Sar LS BaP ee W5 Gb SRE 519 ao 3 aa ag, 3 ray OINILELS >H\¢) a] se cy ry Wn nus ani ; (t ce aT : Cl |» " YI ae ~ oe i ory) on | lO sad arba) = -9|b | ES | Ebay wT apsieD ae O0W ur et CHE Yesy aeQ €88 $0 Tezabed ‘TyZ8z9Z ‘6T0Z/60/80 “E8zZ JUaWNDOG ‘898Z-8T aSeD GIUFFRE007099 CONFIDENTIAL

The text on this page is estimated to be only 37.89% accurate

a 4 eet fl 5 weg Uy Pe7OL 6 POUR Es Fe eae p | pee ae a a DAWA Gls ; . te hid! to Cha ALSIU A | ASLay eared A Sty ag07 THIS swe SSH Miser ay NgtGd /\ /\ | Deke Ht ISSHIY Westar Poca TT) ae ogee 7aww3 YY '6D W9!> Agd : or CSSA BASTVA “iS — : nN PRS EON i Watba Tae Toe Taw \ UAly LD woleel a 22 a hi ens 7 Wearebor wtmn9 39 y—yorer reo \ 740 cinanssa %, twaniiphetie ovens ao ees 2 VRA~8; AEE TS pt rer oSex300 004 = ll ak bob . a ; ' ewe te : : ‘SOINPADOy| “sHaewmy | ip | saiyy PVA ley ont od TIRS! de] Late amar ta “f 3 a > FTE One mere re VAD NISSA 9ev Aalanep> ted 94 ~ eA Ar ALLE wn PADI WO y on] —_| Alald ACSI Bla I faat hatene> $6931 > dni wet ne n > ieIivIId 9 $)D- det Pudignos = _____ Boysen wns 49! Zura | oaly SS 970000 YC TWLLNSGIANG: 8 —_ | o} — oi MN S ct ac ? ea J & SIN Ss — ""M08syeg yelony seQquinyy ee Se a €88 40 zeLabed ‘TyzZ8z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007100 CONFIDENTIAL

The text on this page is estimated to be only 29.26% accurate

—— ; V1 UM d ¢ 1 CBTS ot HD oqmg 94 (904 Rave a oe woe ra : ene pees cot 2 PF ku ore [ASU aK! ak Sista) Yelan !acf¥ oy erat ' P ae Le W ah ies ee Pe oAny)* zie “TA ee ee pa A ANT a = ee ‘ ? 9 Cae oul ny ft tte ee Te, ; Ter r f Sh ae Re 2 | 7a |e ‘AsoGaleD yHioany AR TUT Oe Se Ie EDS Me Te ee eae ee hae re et Tee se . a ee Se Ss , ; tore . e ‘ . ‘ | = é k \d . ESA ye Ce 5 > ee eT : =, 7" a ars cl Seon a he oS se — i. Me os < = A Thee rn 38 erase er SpA IF ae eth Re er ee Mee ARE Bee me Ry oe oy by See LR ate ee Ree ne pra ae Mga get cn foe ot 7 , Met rae . i. re - , ot e. “ t > : a Ww _-* “> a. ih Ore (Ty we a8 ee > a] Pre ee a ane ess ohne “* 42 O° 18s ‘ dS ee ae OF Ee vo. Fe €88 $0 cELabed ‘TyZ8zZ9Z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD a ve ; oo 1 ipbgac™| 90] Gal atLebN] sI-S |e 4) byl | 128d, O91 SIGEN) [e-taLO| ee See Ta . ~ . 4 ‘ At re ae ee . wt + Y ear) an is iF "paw a wey . : ee . oa ee eet > + : so GIUFFRE007101 CONFIDENTIAL

The text on this page is estimated to be only 30.75% accurate

9] | | O] O77 a ZS bi 5 BSS oo y PTL eek %. v= mp seer mt 3 * | eB, FFU ws Sg Ag wvace 77> | {| |) 688 | Sg) ONS RMP ps pa ATOM Vg WD lor est | Fond de lee > |eey bk Lt Se Pw, ee e 8/0000 Yd IVILNACISNOS —4i— ke ea atest 7 at EG . “AsoBayeg yWesoury " €88 40 vezabed ‘TvzZ8z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD es ni yy 1 -™- ashe ~er ee Sone aes tC] prio ( VAYEULTS S,)O|}ef Bol SNe Cea ee pronnorwy pk wusmanimsworesoni met samafoe or ae Bg ee ne fe ; h| i. GIUFFRE007102 CONFIDENTIAL

The text on this page is estimated to be only 35.53% accurate

. SUIDAWMGU A any jet] Inuwas t 4s Woe yt a OTT KAS W2 loe| VEL | ORY | pimsAn wud Soar} VE | Aad | pane TULL AD 9) >t PERE ERED FET PEL ERT RSE AT YT ANUial op '¢>/. Th — HJ Loe A> waloy| NW] XY Ne he | | $2 'Wd’ari aN i - M/A lism Gi later ence a3 AG fe . ol | l lasts hoger 47> 4g = Woe} 1} | ft +a ‘salwO/oL = t aneus \ ng WD wo/s a ee paar aie ad Purges Ty rte - Lg ee ry Oe oy cat ¢ 6r0000 Yd TVILN3GIJNO tp Ht (Ws sts %) a 7, eT 493 : eet ud vs . sh Wak eens nda FS ' Ienuuy % Ginzieded Jo syuy0g Se €88 $0 Gesabed ‘TyzZ8z9z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD see GIUFFRE007103 CONFIDENTIAL

The text on this page is estimated to be only 34.61% accurate

ar tree | oo S ery pe e 1D) Syn Sie Us eae, =a \A eu EUURS 8\(Ullek oer freee “BL ee Maple : ns i —upapeemeiiainee: ee a7 Se | eter eh VEVENED SRO dm on, ong | ate ee (oi La [nl oy! ~9! f pl rn it 0S0000 Yd IVILNSGISNO | _ Te) [ah Pee: syrceas oar Ykreastlus FAD ~crsszaaw Haw m1 UMO/4 WBA Uopenyeapy aes z Shee athe, ee eee ar ae S et. eng ie ts eer ae ee hd _ 5 ee wckade = @ SB Oe ae et eT OP TL esi te ete Bs = Tr LENS aes Yeahs i 7 ' ; vhs =e , ’ ET oe a = €88 $0 9E/abed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007104 CONFIDENTIAL

The text on this page is estimated to be only 32.48% accurate

of “th\ y { : : "] : _, : roe a t : <6 . 7 “OFL) BU LO} SKN UO BL Aq @PRUI SiLELUEIEIS BL) 14} A\NIA0 | ars | ae Ea — AS win ‘98 a re H+ — Be feel | yay wa | & : ___Aswoms ise] | typ saaTf ne Astwoice Ce OA] Fens | TT * o5[ SBT eee \€- ae al TH a 150000 Yd WILNAGIIN E : | [oe | aspen 8 | r f i Oo ‘4 : ; tee | | Ae Tas “eot asta ObLS\- =) | FTA [peared peor , SS rae foe SRY Oley RUEpY E ; AsaGoyes ypcso.y soquinny wyGkes | SONA jenay 2 os yo Sjulod yRinyy eT mer me ete ee ee genes ee — PE PRO RS > RS FT OR PII TT OEE RTT “see FE Pe ahewe et po em €88 JO /E/abed ‘TyZ8z9Z ‘6T0Z/60/80 “E8Z JUaWNDO ‘898Z-8T aSeD GIUFFRE007105 CONFIDENTIAL

The text on this page is estimated to be only 36.79% accurate

zS0000 Ya TWUNSGLANE bISbne toss ©78q 0} pepOL [VWeshS | S813) parson =e rein qe | AL wo Ta ATER ST [aoe WO! ar cat} aT Nd dW y\ 3 volof |L8 Ad OW] __390[aEvObAT] Bus) cl | ana ea BIH 148d | veg | = LCANVYON LF. See 4 Saal Le BvyO7 IyWOZ 7 C'gQo Y= Bete Rot m5 Syn L A a caveats ot. INDSIA ae SOB, SPOWA tid AODWES VOW 7 "MAU TLY ee NBA Larabee ra (Le OC. owez] wf | ; AUS nN encnacewsren sina] | FES | errevapab |S hy eeslss = ae we ee | ome Be alien | SN jEapay F fs JO spajog Rony NERA RADU TY . re eal Tea ches t, €88 $0 gezabed ‘TyZ8zZ9Z ‘6T0Z/60/80 ‘E8z JUaWNDO ‘898Z-8T aSeD GIUFFRE007106 CONFIDENTIAL

The text on this page is estimated to be only 36.62% accurate

| ey Ch} FS bilhsd| 2719 938q OF (9j0) YOK) joe UINQUULIE, & kOe iC “tA GE |e Sone! Las DIBAUCS WNOUTY | ni a78 wg on vO ow a apes spleen on 201 Aveo €s0000 Ya WILNAGIANGe | e Ta a aN oe. oa ce 6 atl al dh ae €88 $0 6ELabed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007107 CONFIDENTIAL

The text on this page is estimated to be only 32.41% accurate

7SO0000 YC pay) CVI & Dd} | So] 0] [7 Mh » S UL za cw L boys? Jay! AL Ga ve [oe eaennnt ont cnet GTYLS / 3 ol att aie =! wd a J ] 5 aver S a arty | CREO IAS : munca Ts - hope 2 i a || amet 7 | eit | A b 1) 7, C) ger €88 40 Opabed ‘TyzZ8z9z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD “2 enews syoug i > “BTU BP UO} SIA UO ew Aq OPEw syUOUIETE]S eyp jwLN Ayres | GIUFFRE007108 CONFIDENTIAL

The text on this page is estimated to be only 30.49% accurate

pe tl on oe wo} ag uP ou Kg ope suas HN UNS [StS [swam bre) ) enees tins | P 1 eps SE : eh Rit ES (Oa sy L ems Saas KTPAS ‘ari Tb af bl ere Ee en Ts ae rere er me = ¥ ‘ + ' ss0000 Yd TwuNalNG a ei ot wa | edt ssl on - a fo0u pee es ee ees 420% 1 “ON | UO y UB LOG EAyELBP| poy puB uy ‘aA reaguy yD rhe 40 S304 weusuny SY PRY lens: | + * ‘ €88 40 TyLabed ‘Tyz8z9z ‘6102/60/80 “E8z JUaWNDO ‘898Z-8T aSeD Ren sere etl mrvasmaitariibeintatln sha ees ea pee GIUFFRE007109 CONFIDENTIAL

The text on this page is estimated to be only 40.07% accurate

9S0000 Ya JVI LNAGIAN®9. rosttend? al ON SIS a531 ot oe Pa va ND "OTU} SJE LUND) SyLA UC BUY Aq BPE sysOUS}R}S OL) RLY) AyISD | eTSMAS] ML MVISD|MBHD) wane Ls Tall [apo] dat [a AS‘W9'96 Se ase 8 a €88 40 cyLabed ‘TyzZ8z9Z ‘6T0Z/60/80 “E8zZ JUaWUNDO ‘898Z-8T aSeD GIUFFRE007110 CONFIDENTIAL

The text on this page is estimated to be only 37.99% accurate

ZS0000 Yd TIVILN3SdI4S E} 4H Oy Tae: h mS: mney aaa PRUE | RRO? \ by : a a wink Sons “27 0 11, 319, UO OUI Aa Ope sUaLienEyS eu 19 AyUDD | r i ITT : he nem : x < Nad? Ene os, TyaS ate i oat vy WAG ea tE apy tte casa sj | an =| NN 4 f — a os Fae o8l on) BE ASW LF PUD car New Alter mp fed MITA RIIA ene Atl Rereg 4/7 (TIT) Ade! Aswolse weieiadel EL VEIUD AMA 1925 -$46- C73 AW ae. a F ‘ ' in ee es ee rea PE rae ee hee See "-—": Ae iD oes: . —_-s . “7? (€-L2-¢ 4G eg, z 34 a3 mare SENSES BN UogEayRUBD| Easy TEP NA | e " ‘ Atle tere eye pte S . ~ ’ ‘ . 4 G BALA B a jo S\ujod Nee a Le mo] (9 €88 40 EpLabed ‘TyzZ8z9z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007111 CONFIDENTIAL

The text on this page is estimated to be only 34.78% accurate

Ey FOvie [inc aes t ere “MUI \TD ES [i [ehh |. 5) or SO ‘anu} OG LNO} S1y} UO Sus Aq BpBUl s~UeWweTETS Bun yet Ajnied | . at A ywo?| ‘aorhewraysiacel] | Gdsn| AIL) ow | ST . || ple | 4S 2 east — Sey SENT SE . ye} senor 2M S MeeF) | ASA AALS U 4 tte | mews | enor u¥egeryn oh eA | 8d | \ a Oe ae 3 a cits , E Sf aa er a 4 SS) eee eee 4 ——t- © : _ 92 | os TS . = {| so “1 vow 9D s sz a “MGwr3t \3 . oY 2 S| BIS | bums stl ij tN T ae gs0000 4d es ay ES sh pao oes A; | Pa . 2%)’. ~ ) ~ i aa s — eit ~“haoBoyen yosoay €88 40 pyLabed ‘TyzZ8z9z ‘6T0Z/60/80 “E8z JUBWNDO ‘898Z-8T aSeD GIUFFRE007112 CONFIDENTIAL

The text on this page is estimated to be only 39.05% accurate

BRC [ele thes] A253] wea esas ORI _ AE a ae . i A ma ee ors ave ees nese aa =o) tot \ bey ATS OTA Tus ef lus Ye oo s FS 650000 YG TWILNSGI-INGt . | yer (OF é QgsoJ} oo mL Ape [GIST] gs 1] Moobalwewwg sjuswedsepua “Sagan "ON | Uwe ~via €88 40 GpLabed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8z JUaWNDO ‘898Z-8T aSeD GIUFFRE007113 CONFIDENTIAL

The text on this page is estimated to be only 37.14% accurate

: ass . . al aed UT a se P ip cee pe oe a, CT See ip | eae sseneernomee germ nmenren tin i maybe | S97 SeaT Tw ie Sea [elf , ae } : ete fate T14- ~ ei vv Mia: toe sIw IN Kak - & t/Fwe =) ob hs | i, ‘Spa » l BUA 7 MO act 9 SAS a wR PS ee 90 Sao) Sin gt03 SWAT D TW 0n! NIN yiow cob AS bao [ON PAA FT 12 9 Jan *38%5 Te Papin TAKS 23D TONS gett dnaK WD shen Tato a Savor are te My 8 SAGO DS NANA te |S} 5] oben 7 ET Atnowtaw wg oe ty anand her ta yordy (wor A fe DS Hamp I + = BAF 7 TIE sit 5) ahs 85 Ser al rid wil of BN Lf | mu a3 id uty | zeigt) 2 has! 4 4AWE a i . sos ni Hofnd dbs Ww POON Y 45/50 balla . LT WSs XSW a SF lon) 817 | 090000 Yd TWILNSGIIN@e es - " .s LS ro TS tat eee. avs det abil carele we na H , . . , UORROURUGD| jOpoW pue yee SiPIN YEOSY aaa €88 40 9pLabed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007114 CONFIDENTIAL

The text on this page is estimated to be only 44.00% accurate

' . . > @78q Of /8}0L rere be VA Lt [| Slee [Pl bhbS| Lied mel, OD RS | ° reed | + a rT. (esl 972 ond) O16 UNO} Si UO ous Aq @pULY sjUELLEYEYS aU) JB) A200 | usw teases b Nosigs. “AS! fog]. ; to : Pow | SAS MO 78 Manne 8 edi} 35 ww Dis Tras A ! Tn ct] tes ( ” “te ve PIE C et wre an rete b te amt i Bn ee er ‘ | xvouucreaiaw nddnty Xe ae Ye a at on EW THIS AS A> Far] FT| qh lyfe m7 ni 2e! KE ee uN oe wy 4s-5 “> Ms ‘Aruceo yt wy DU NW: rf ast oi L90000 Ha TWILNAGISNC a iA Ww | | | zk €88 40 /pLabed ‘TyzZ8z9Z ‘6T0Z/60/80 “E8z JUBWNDO ‘898Z-8T aSeD GIUFFRE007115 CONFIDENTIAL

The text on this page is estimated to be only 38.38% accurate

790000 YC IWILNACIINGe). % Bey ae ee a ds | eu b F|DRe Ste] UE gos wo} 9 0 Ou Aa FU ROU ea A TT [a WN [Yel Satuiwe sewn gariiwe Set [awe] age [| fy | A WAIK aeFAO feet Ul 2 AG ‘gos “ha Ft Se a J ‘ie oO fe apt eas a aS > Coe ected est 28 rere Ag y a3 ee AW ‘ ae MFA Laid LE nehtctens sf “et AinighAlad I) Vevere TD seg OA ere Ag 85. - yh = = * \ ae TT ie 5} Slo ll ctl in| bok Apri fqn IE ERD AS!ve ok: et ANG chan ade? oa BAY oy lar ee a} a E395 yess ar Ree < AY oe inate Pel 4 ol 3 ie f feniway ‘gy angsedeg sO SptOg €88 40 8yLabed ‘TyzZ8z9Z ‘6T0Z/60/80 ‘E8Z JUaWNDOG ‘898Z-8T aSeD GIUFFRE007116 CONFIDENTIAL

The text on this page is estimated to be only 44.57% accurate

8 mou A Mk || fa %s t ce {| man sbea | me Beg seperate Oe Ee a ee y 79 +e | ee " |9 3 Lt fq | | ewaw] _ “tsd JF cea 2 ee eet on | % +— ate ee aN apes | i : ms || 4s z €90000 NG TWILNIGIANGEee || |S = | LF BES -UTL-9| 1. 4 S a : Mita : St lt esi | Sab x9 SEQoLNIHIELZL-G| BS _— -€88 40 6yLabed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8z JUBWNDO ‘898Z-8T aSeD GIUFFRE007117 CONFIDENTIAL

The text on this page is estimated to be only 42.67% accurate

nn E: ~~! @ ‘ITU vw t. a eh YE I, - ee y CM NOUMD Savi 2G Uae 1Lb] GES] ewcaiwy | PTS O\ ptis || [ile |c, ad ia Sie i By eae els Pf. UUs pSctvetsesbl) | ASL | Cot1 | ARSLN | aczE-O TT Fp hE Tt raregay mee huaes| | | oth | CSTLiws|bhN] ow [tl 2 ee i a i ee ee ,0@ha| | Ee ee ee Be ee rom df 8 ao} t+ {+4 - ee eee L a cary eae on tk Pain ots eal || ML Sere) eterno] dd RN 3 Ty anf Lessiwosel | Sed] dT] Xs lor See DL Rese Pete & | ay rae =e ne ae | Laas >Sy [7 “Sees s0v 27 a “xe! sent | < { © gd ui | iq | y90000-4d IWILNadIJNOo{ || |) mA ore seit { i Cat LRT VR andy TY ENOT f oases yamay SAW LOS BOY RL] | jPnoyy pue | ——B+essai SHEE WBA ag €88 $0 OGLabed ‘TyZ8z9Z ‘6T0Z/60/80 “E8Z JUBWNDO ‘898Z-8T aSeD GIUFFRE007118 CONFIDENTIAL

The text on this page is estimated to be only 35.14% accurate

s90000 Ya TWILNAGIINGO ~ a 2 \, rk D L, h | B : lei eed | : o /\ ee os Bee é a sr ff _ QImoyw fy se AC play =f. Cha e | tl Wt |e seth F & NG \/\| —— vv wom qn F Tt | Al] canruy owas) He ; ~ al Q % 7 - I PINWAH fue OG loy|P* ‘ | jae [< STM 2A! us'wo'lwd ae] a. eeeong wath Shs SOM Wid BE. mi Wi?“ danvve Tee) DE: i ‘une gd aad AL | a —— ee. a ie |S % . __ NAG uty fg a | | = 2 of a at es IBLo Drosha ASW Aw or e {——_—1 [Oe 1 se | La sto twylpel 5 Le Ih lal j lo¥ eI : to /\ 2370f fr cyl 2s 74 ee | || t WilsSOti MeL TA a y Vv | f \ SewiIv idol “wn VOTE htc) “PS 73t" Ze Ms iL | eet Nat "6a eh I nuztitest! Oo Sones Avda > gtr Ohoe ath MDA POTD hws ust | i | supe jo tee *“hsnBazey yesoyy JAqUINAY oF t= a a sSonaflen 'SIAEPOINd “syd weH. wo sary iGAjy 8 OINnwedeg 50 SjulOg €88 $0 TGabed ‘TyZ8z9z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD ' I¢| c ’ SM, Sal’ SHOE 8 [MNCL OO per, Ke ry ne _ SIMBUOIS S10 \| a ©, - 5) Cat ty Loy plenuo,g punodiy s ‘OMs| O2B WO] SAR Uo Bw Aq epsw sjuslwejsys ey jeyi Ayes | {| ALbObLN| JB VOTFOYBUBP] | Wesany | japory Pur BYE HEALY \ \4 hn} ye a a v4 \ | AL} N| | Qysh- *) LL n | % ee bt rey PLY x il ry 7 AW s UO\bhNT Lsh-i 9] bh NW . Re v\ »* of GIUFFRE007119 CONFIDENTIAL

The text on this page is estimated to be only 39.95% accurate

ita) pPsBaio_ anew | OL lWeo'sslatabn ‘LE fa h/ hy Fide Fo . I IILDT j Pov? Stati) Soiiend "irs yi ac, - ak eA _andwe er CAND) wes Se GA.) WLS wen fog fT AStwolaciet __ Ww 'as!ae |S > 3 ed {sj on ADA wi pe |NC a 990000 YC IVILNSGIAN@ aaa) Is’ w9 WO LaAeTh, we S, d _ = U : a WA 3 A. 4 IG "a Li pind FesT sa = fom 2av7 Os ck RL iar) A an —__—,1___ ial , fe. —— | | wou} nS a > uD Kd | ! bead MIT IAN | am i Asi y abuypurry jo s,udWesiopEs ‘aadancsinny ‘on | umopy ; Pe <= f408oED YeLOUIY 1eqUEN | sempedesg ‘syewuoy | E11] sou)| = FBAHAY "P Sanyzedag jo SIujod _ eT J €88 $0 cG/abed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDOG ‘898Z-8T aSeD } ,; } SY UGIOWS C Spl coy teert ~>oynee 2NCO | | iw 4 vw I ey 7 | 3 y | Seer fT Add | B97 ) < WSN LS | ZS | “cyt. fave, eel “eruy Ofe WWOj S/W] UO Al AQ epetu SUOWWATe|s OYy YBLy Aged | ASA N | 14 aT YY LORTRTIEWUAPY | gesoy | OD aL Oh \ | sy | @bS-§) ie "A a DLs NIMC @ FMOWY Pub eeeyy WROsy OK GIUFFRE007120 CONFIDENTIAL

The text on this page is estimated to be only 40.31% accurate

490000 YC IWILNSGISNOO me a/Stulee [seve ~ Ube Tsspii WD tS = t amt: me YS | OCU. — be ra SFU] Gue LO} SHYh UO BLU Aq SPRUF STUBLUOLEIS ouy ey] Ajiuee | ea d wT S = Sa | oh 4) : arg KAY AyD) ALD a > ee Wore cae aa 3 f aon = Berar) nO AS OL S NAS rr 7°. e | 9 NS fh LE fog: e "ASW Lyles: 1) a a n | 4 4 Wd % dddV 4 — | NOW 3 iw aIGION | [SRR teeter REET ja, NAM 19 W9) bHNT Loh bh LAG] z PWILISS Wty E/T] gate Ory Fre wth doo sj" Ons. tat de} UA Wy sR} — SWiuKD - Petey fF by » ye a EN ’ ¥4 A fis th-7/ Rb git wi hacen vas fT-(2L-Y] FE it ss ‘on | uMoEy [—— —_——__‘seimpagoig sy sew y yEys | eonpy jeapuy »g sinzedag jo syuj0d tt, erae VHT) | erg fi ~Aaoheqeg essay aDuPueay Jo | JSCLLNY | EW LoIpeo UEP epoypue | Yagil yesosy PW YuRDYY | syng €88 $0 EGlabed ‘TyZ8z9Z ‘6T0Z/60/80 “E8zZ JUaWNDOG ‘898Z-8T aSeD “ROPOT VT GIUFFRE007121 CONFIDENTIAL

The text on this page is estimated to be only 42.55% accurate

28ST [C{saxt) a aH STILE e S| LU hb a e ——— Bai 2 2380 9} EVOL ET “Ai ce cs Wn std, Aa feuChL, ates 8M} BIB UNO) 3)y) UO Bw Ag epeU SWoWELEZS Bj BY! AfiLed ; Ter . i 239 EPI | | a 371 votand sts ‘£99 bye a1 4 ¢ vf 3) ler ee mane : TS elon ty meyer tae | go’ eS TRIE Tee IPE by UNITS = Ta 6 OTS 5 rong! CTI! WD“ ool asf gP ac tN gs AS su 3 \O = IM or 7 ef | = MOY UOyeoyyueD) | epoyy pue | se seALry Y Ganyiedog jo syulog yoy | SHC UROyy | alg _— ste Stoandbeys | €88 40 rGLabed ‘TyZ8z9Z ‘6T0Z/60/80 “E8zZ JUBWNDO ‘898Z-8T aSeD GIUFFRE007122 CONFIDENTIAL

The text on this page is estimated to be only 37.27% accurate

se Vl SUI € | . »| It b| ~ HL PEC OF FEIOL | pete Te jeje, eBeg wh OL'AG arth | Add ws] __ ied ADS US ‘sazinva winged vi tL of (Wnt es BE GCL oe | AI (ye QL Ley fox sud WA pa wo'os-’ a *oe|" PST COGN PAT Gawd -6a noch pene in? Agr’ uns! = ¢ werrisat wa hoard ant M1 7 Oe we PATS 2 wo. g (oy baal i RST EF SOLENT LF egy thy eee fe Ss Pas + 7, rere , = Pe! to 4 ct KEES ya ee ia \etart -* a SISOS S t i nae eS 3iker7 mots) 49) alt! oF [HRY ae SAC! ual => 2Ef a Gainer papas SA ‘GA. weg A Pee Aaa | \ i thpagn@ Tn) <htcluAt’ $6! Oe. ae eRATeE LIL, PO orig oa) a a aA| 690000 YC IVILNAGISNG ate eer ) Create Fe Tr ER, ‘Ww We "WEG QUIN 30 rt ENT Ki PN A 7 oF 410 = a j2 ~ wal * > UH / ae a \y “> SETA | ($e e ‘. > ’ Betty Tals gt ue | t | fl |e iG HD) Yatihd dds xy) | } OL wae | — sfiuspue4 jo ‘ON | UMO[4 F "“AOBSIED YEAONY | sTUINN USM | Sey) FOAPAY g aMyaedog yo spuog | t bs tP. €88 $0 GG/abed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8z JUaWNDO ‘898Z-8T aSeD HY UEOYRLeND) | youony | V4 jBpoyy buy Soy YWSeuiy pee — Ope u "9 \- SH IULITS HOt i SU 1€ © u Sab! orn, BIENMUO.) JuNOLTY . ‘@rU} Bye UO) SRY) UO Olu AQ OPEW BWUSUUaTEIS OY) JBL) ARO | —_—— "leq GIUFFRE007123 CONFIDENTIAL

The text on this page is estimated to be only 35.44% accurate

020000 YG IWILNSGIANOD || | OF POT) oe * i¢7 ST € oe s(t | This pawico4 juNoUIY ’ . a ~osu-s¢ {Eyal ebed Oru) Bie LUCY spy) UO OW Ag epeW SyUeWeayelE oy) (Su) Appin | ‘ c= i pray 4 - alee a Zi 77) eee PEA a te . ‘ £ “> bi es ahes — | | | : | ‘ ~_ pny "oun glory 6% A ys WINS! sane bh ~ jeu | | nls | 7 > a Pe svarrey +F j | ; —~ : “ | Pf lA th teneneasu went] | % f % -) W159 | . +. a i fas ‘ot win 8 aie RST | ’ 1 anys WA'SOA Thi | HC - Ou. Win 9 “ox: wai J | ky ian tos\erangd > AU se inet ? Laat “Erp oe ee eS as 9s wast fh EON ROT pT Asobeyeg ypeiay eSuypues jo sacRLinyy A, f ate SpUDUISEIOpUy ‘edAnour yy ‘saunpecddSMARLOY rs WOW Voy yWop| WEED Iy jODOWy pare SyRYE RDU = fn *, €88 $0 9G/abed ‘TyZ8zZ9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDOG ‘898Z-8T aSeD GIUFFRE007124 CONFIDENTIAL

The text on this page is estimated to be only 37.89% accurate

4S > |j5qg oF /S)}oL | 9CEF | ost eh Rae sya TP ed | “1. BeyVTl le [INChb) SB PIBAUOS junoWY | jay afey | | M' nAtvhse> Sue Lor tC] yori nar ‘1G og 9 SF | AT Syauwas dyavalas ‘ot hs 7a | a Idd CW) Eh aint me | c 1A \ we ew soe ws'a> tg arleo 33 | qe | NAV Ip OL! ASW UG > — LSIL bi | S| C “3 — AS Win g>qt ar — Tad] By 1] UC An . (OL Wino HEL be |__| ge | ISN for ASW | aw Sere TSR TTA ene TRE ESN Chigg set *? =: ns ta Se TUREE She Stee AE bee 9 HE lie 0} 9 af) Ae, ee Eas bi Po ‘ ~ ‘ os n 4 aia) wipe “Mia? = s “ VAMC he yer? waits A '3S 95 WAI as ‘a 120000 HO WILNSGISNGSD ~ ae | ki yp |S APR | lo Ni d | 5 “* Pir. a ; a t “ | Sead | Seal [arpopn| | ET ar + ie 3 a? | <a . x } Ny} SFB UUO) Sj) UO ew Aq BPEW SiLaWELEIe By) LEU) Ajmiae ; ; “4 3 5 es \A Eu 3 g 3 ys | “A \y\ — AS \\ { ry 1 \ AIL | _ 39d | QI [als-Cz-g! 1 $80 | ASbebN| DESI] & ABS: a y 1 \ sf LGd |ASHlaN UE-L-G) | 1% ObS\\-*) |g a 4 1 Qh SJB wi fs ze { 8 = Ls * ——— “, yy : | oO \ hae D CO ge! cB et | rm ™ \ see OS 'Sinifae +09 AD\ , LINAS | xD bard WE Xf 5 .. alae : ~~ £ a ji 19 T camer’ sfujpue4 jo SUC OROpHg sieAtoury ON | uvoy $1. as at ae . = 4 5 WIRY UO BES yp UEpy apoy puy | 8} a AsoBajeg jpesouy JOqunN ‘seanparolg *‘Syswusay | Sey] coy feajuy B wnjiedeg jo syui0g Wesosny ayEys it aire nets - a wy hy ™ A €88 $0 /G/abed ‘TyZ8zZ9Z ‘6T0Z/60/80 “E8Z JUaWNDO ‘898Z-8T aSeD GIUFFRE007125 CONFIDENTIAL

The text on this page is estimated to be only 38.69% accurate

K eee le |bL-AI| stile | IMPAJO- junotiy SL 15s EN Peer re rte eee Fk | 7 3. UL | aA dd | onlin is Tye pL aearigt Lola joa ath et Ts | [a | _| van Le - ~ . aa . \ | 4 . . ° y . | > * ae ’ ‘ . > ‘ $ } + ‘, . >. ¢ ‘ = ‘¢ 5 - = = EA Aetna ah a f & a =| a! , ; - 4 " , ¢ ! \ - ‘ et > “Es ca Pa _ ———— = . - e —= 4 * ae ° = ‘ > OOO f: CENTS r ' : um AY %, Q IN Fry: oe d e Lt as » ag _ Eo | t 4 wal eric ‘Ww! |e ho Ww | 1A . re _2S' wel wnl asthe r i a “ AS WIN wotgr EM 1 a Wee eat ITEC VIGTID Pweyyit) shupurry jo 3 Vinson wen “Kaobayeg yesouy Joquira ‘sony: J0ig ts yiewey WEY UOREO UEP) yey €88 $0 gGlabed ‘TyZ8zZ9Z ‘6T0Z/60/80 “E8Z JUBWNDO ‘898Z-8T aSeD pL 9a 01 ROL ——— hb Bb DR I iss. ee ‘q? 4 si Ladle pore, 8g ON] GUE WO} S/T UO BW Aq OPE sy \. A Sr UL Lt wmeudss esate ays Sui Yeu) Ase | joPO pus | —— Gt SRY) YUyY | FRG GIUFFRE007126 CONFIDENTIAL

The text on this page is estimated to be only 41.47% accurate

& TiS h| puis, ojeq 02 JWI! "ary pa?) Pe yo “wm s Lh Ted | . ruBNJOd nowy ‘anuj G28 LUO St) UO Blu Ag BpeW SyUSWAIE]S Oly yeu) Aye | ys! ws ‘sid 'ay eZ tw A SILL AS WS ‘wal't 9s fill MM aaa ee 7X EL S2 AELZED| bi 1G Be ALY = oN +) att rst ‘A oy _| \\ ; | 14 | nM loys! 72 14 — w | XS SS )% rh |_¢ a AC c yin WAI} | iL} 54 s \ ak As ‘WN SE puull ow me bee | ‘ashok N| SSN -9| Vt ID ‘SOs nM ist €20000 YG IWILNAGISNOO 75 aILIUbDN! GYE_Si-D f= N | 2 oS 2 ’ AIDA, Veatin? avid yt 4 «Asofeyeg PeADLy Se |i OY ORO ELAR japoyy NUE SON jenuy 9 eanyedeg jo Syujod yeuasty | eHeYY URDU t sFaapurry 70 1OQLunin) €88 $0 6GZabed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUaWNDO ‘898Z-8T aSeD GIUFFRE007127 CONFIDENTIAL

The text on this page is estimated to be only 38.75% accurate

bybt-*} @2eG OF FE104, Cele —_ %2 cia! a LEMOS JUNOUy “Pot err ' +5 4 C/4| mcg 0504 ary ave wy Spy] UO ew Aq epew Sjusweyejs sup yelp Ajqso | | ms we Pa ee ee “aa _¥S fn (48 ts [oot 4 is ee! = a wa hye ira. Mires Tie ’ O . 4 \ | | % a wo! ‘Seen CEU AS Tiny COD SL Nt: | v\ eB e? % win WO ACT ATERO hea ae ETS IVT ; a fs r NAcniwt oe WN os vu gh? 3) : __ eT a = > rr > z ] | | = s “At ys watsr fee | WL] Te 5] PX OUNIMG-UCL BS] ” SoAv 74 / mmf ie Ay J | RC Ke i ed i Fo wR? TA) BRR ELS - yt | tae me RAE | eg SEE Lahi=441 8 Tt TN oe SY CI TE GUESS ee Cou an 3 a . moan aX, art ore Lc J. ‘esvon mates _gameenel LNG IG i wi (oO es ee AL AG! MN Ze Ibe rds - | ° 4 PREVI NWS — NOTIN Hogigd arc (coe o I. Yel LELKA 3305 (2 LAs Ty> =U —altas'wa let ee Gt as! Vin" Wf ol Wel Chas! vein !w Of=l sz] SINR "2D Sal ASN swior | ANG Wage | | AN N ¥ A~I aft waAligwi 9S SQU CtorprivA | vs — ; = nies ‘| * a TAG . soneprenstion ‘ ’ 720000 3d IWILNSCISNOOD Ay’: ot feyens ary annudvint ‘Sul | nae Dae ASL | 4 vA Ic. | i Gane Tren s eyo HPO aS ” 1 Q} : Wa aN gre Fay! ee WE] FHS 4 | o« [at wo ROE Wy ULE al | Wo oi POE ash E sf Td sce tt W | 11 AF ; “I Wa tert FAY Healy | AVE Ute ‘| i | . — ay Seg F ~ Fi ot wos poo <. th I | at 9 beaver Lik eee saa = MiRYE UOW22 REP] poy, pus | <i AobeeD WeLoKI | JaHLNN eee aha | SI] = euaty e eurasediod Jo med ony ee) eC ra a tp <. > a €88 $0 O9/abed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUBWUNDO ‘898Z-8T aSeD Teh £3 % a99S cant 290 THA GIUFFRE007128 CONFIDENTIAL

The text on this page is estimated to be only 38.91% accurate

S37%g OF (FOL MRM jUNOWy L; (210) Bee @ru) G28 WO} SI} UO BW Aq PEW spUCWOTE}s ey yeu) Apia | 4I VG iA! "ST UKLY = yA O\ UL an 2S avy "BE Roy | mer Te i AvT <! 3A. | 4 My / sf ai! ~ NS haley 'g Nl — _DAfastas! WNISL AK I 1 qemadig YY? eee Ze | | : ees) | ZL asco d3d “ft SOL (L\ | ok a | I 4 Says N yt | 0 | «SAG wt Ka QQ=7 ‘TNO pot Ty “a i i e — : . “t = | Seog yn MIRAI ec es is i | Ry oo “= e | L | me sAPt iyegn se eortacnie ae Paks | re | fn 2 U (WN 0 < s bs SI *) aan wr tap Pelt L e aL oh LObN] SbS- 9]? | | Tie etl a eo r | - aT a6 Cif | yest Woibh | LO el A ie | | aoe “i ot (EC | Lio | fg 19 o nw mi. ol iy | | Pins snwsy nl 'wes's AL‘ DE PEL &. 5 BY, i ele. . oe or ue bt | | pee} — “Qy | LOA | Shick N 1d LCi. < 9S | het. | ain “| | gs ‘ Ce ¢Z0000 Ya TWLLNOLINOS Z| SAE: o£ - | : =e | | wd 5 far yup '2 2ril | ‘ SAL JST sh t ‘1 we J ae EY ae a “bee _% 53 Le | _ | pS Ea = j aI AAO ae ) or Gs eit 7 é Ae ; CPA | FE fats a rae Shuypusy jo syuawiesiopud neatiposens ‘ON | UAOLY —_ ee wey VOW Usp] | jopoyW pues ——aL | {4080 FD UOLDAIY WeQUnN | ‘geanpedtug ‘syseuneyy | sub.) 99144 easy @ Bangeedag 7O SyUyOY yoaaty ana yey | sag >. €88 $0 T9/abed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUBWNDO ‘898Z-8T aSeD GIUFFRE007129 CONFIDENTIAL

The text on this page is estimated to be only 38.06% accurate

| Lome bl &lO%b ae 38g 03 /Z}OL AOR Y yi “io yy sai teases : tAfeye [A eee] ESA] ewer nncu eee ti ss st p= /L| aetna | “OMY @FE WO} S14) YO OW Aq DpeLUy SyaOIe|s OY IY AjmIGO | a 7 de Efe] | TOs] GL : | ; | At oystw'wo'wo'se fey | spl | SOd) | C iE de Te! aaa ra oe a E Ht e it — bs Ho oT iG sl] W5IbhN ALES z | ' 7. fo - f N fe . a TST won aoa r {iy Hee S| eo |_ae ae A etl r tp 4 3 warrennseh Win Blo "4 O My seen “9.190 AS re 1 2YIMNoe? eT | jae | a “A Pf} jh wi HIWaAS' WATAS wil |e 920000 Yd IWILNSCISNG< i : ie "|" SRN WBay €88 40 c9/abed ‘TyZ8zZ9Z ‘6T0Z/60/80 “E8zZ JUBWNDOG ‘898Z-8T aSeD GIUFFRE007130 CONFIDENTIAL

The text on this page is estimated to be only 38.73% accurate

Mea Rie Oililb ove 08 fore Hy vp JID : eal iy: : cS S Salis Hi e .\ ke Lb FLO; Prenvos wRoWwy | : = Be . | : yi reyoy 05%¢ “Aru} AUP LUO} 3/4) UO atts Aq GPE GOWSPE}s Oly OLY Ajed | ; =) 149L4 a Wey fst _ ye fe WHLa URS RATIT. J Ee \ 3957 1) .- peeves sad ‘oh | ann’ WII 9771 OF an? }' FOSS ‘ony hS Gn yos « eh ep VA a MACCIAW YNEDyU V VW 7s eS] P| YD ctrl ge IQ [HCE A PAA Yyod UAW X oe ai si 1% BER Te, uno WO Ss + rs FAAID “ AN a | WS wa bwin § ne We =a | Savi OVE 2K: Tad a lw. be ens WN gn wa! eet 5h or 4 | % A-evs ad, kabel 3P: wa'ss|i ( _ |g oe ‘Ant OIE O OR WN tot 48s Ss$i it [Ne ; VAN eine cere lof —_ ARS | a 1 - i Ww 6! wie |W Shy tA. \{ mo} NG “> ee oe r 2 220000 YC IVILNACISNG rs ; os SERLAMIE GL ay A oe — B)EQ EW WOPEIATUGp) HRIOUY ““AsoGayeD 1BADNTY OquAN BRE YEIOA|y €88 40 €9/abed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUBWNDO ‘898Z-8T aSeD GIUFFRE007131 CONFIDENTIAL

The text on this page is estimated to be only 38.31% accurate

beet Aly 1g oF (wie A A "| Prvery rm pa fae eee i) = wR | bee lie C oT Litt bas PiBMIO.| JUNOLiTY . s |: tt. tes, 285g ae “SSG SE ka = . SOY A-beRWG be | i = eae MhirnNisn4 —Bhanvow KX > Lb | uw fo ac MS | Tbh RY eS | | | oF . | sah dalla TE ars wey Pe | | (ge /\ IND AS Wi "> ASL |SYroeshal dhet-* | | : cm ‘alles wd mage! Ww or HSI ‘4 | a (. | > < te ccsimn % ho WH' wo! \ar ' \al iy ‘>t f Att | | ee Be ei ee. iy re, 7 =—— a= Coy | - ; 4 Ta on Why a5. b+ be rad ob VA cine ne pe py Tia. tees | ‘th & | AT untea Tia we ytd | a8 Lato epNT € . | so re — w AAS DEN pen x, ‘ a oi Po, \ ” Bess wr | iT i . af / ‘ -. Pt, Sas «= |_| VAS Os wa 4 | a “ Wa | ¢ | a ar eae i ap Ne ne toe 8/0000 Ha TMUN3GIANO} | Ww d Cry yey LOS) Ute won StG . A : \ OL dtua . —_—- —_—— ——| sfupury jo | SqUCWOROpU ‘Sag anowepy ‘ON | UML — en WOKS YROTy OHO PUB a ““(uobeyen yesouy bOCLUTINY —— Jac a WS | Sony | [shay 7 Wnyede” JO sU1/0d ymouy aye I estaly “eq ea ee -—— Ce C—O re “ie ‘ €88 40 p9/abed ‘TyZ8z9Z ‘6T0Z/60/80 “E8Z JUaWNDO ‘898Z-8T aSeD GIUFFRE007132 CONFIDENTIAL

The text on this page is estimated to be only 34.44% accurate

eT] he SI wv S Cap E9031 ~ Tens EBD e oO AY , Ye IED venmenns evucd mat _ STB9 fx AK? } ( Bey | \, cl a tH fat "ag ~@ et " PUBMIG4 PUNO | “s 9 " | ry Sh | MW T\ < Pry ofing "eMU) v8 LLLo) SLy UO ol Ag epelu EjUeWepas oy) pay Ape | siaxsn PAE I~ ORT ae gow mE =a 9 o WY WOO SE Ata 49d = SI ad 1 — Sth iz IS" wd aaa Toistl Anwy ow | \ Mt n [ae a a5"90 Fb AAW] | ~ WO 7 Ba Bel a3 90 Tal MGs] gral} ee ‘— mM WN Sea] | ab] tad \/ | NT la XgerdroWd Cush ww Wg Ce ba\| tad | | gal A \ DP atacnae Mi le 7 WY HO aS >t PL 30S ee ao ag ult OIATAE Sr DIAL ccmealh = ' : =a : = WAN 2 Obl £19) VON) ISL “GO'AS ALMA A AQ ANIL 9d AS AT - ‘ rad Vf ‘4 ft hen Soot is (vit <i — ,—f}— — 640000 Yd TILNAALING It Ww ai ‘i IAQ : 09 at ae i /\ At é Wi ‘Bd ‘Wy TRS" Ga squsWASIOpUR esdhnousin ‘oospecoort ‘syautuey SHuppurry jo | JOG WIE) VORLOYUEP} ————————$— a jopoyy pus | —— fe feALUY F UNjEdeg po syUyO | Ry ' EXE WROY etd ““fuobeyeg yesyy juOq4 Soul €88 $0 G9/abed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUBWNDO ‘898Z-8T aSeD GIGU-S] Spe GIUFFRE007133 CONFIDENTIAL

The text on this page is estimated to be only 35.54% accurate

- byl CUcKRx hr rr} e180 0) ———— 3 | ud % [Sb] “Sega —— a?) Al Foi mnns oe A lo c TAB | a DRMIOW JunaUIYy % } (2/0, ade, Nw LAW SAID AO AS reer] EZ whey ony SUE ULI) 84) UO OW AQ EPBW SiUBWAPETS OYy Jey) Aya | ss | ai POA : : | ‘a Wa wale pga of AS Wa SE rc | se | | a 7. +— oe NVC ASOL AS +90 z inna ieeeencon Seer A ; al S soe i 3 iv i 7 ? NT ry | ¥?) S| VAD DRUTPO _ aries s AT WN WY ES er = AY WAT ee = = | 4\ | AT WS ‘Wa 38 tA] | a /\ Ftd ance SUS'WA' SE des 4 7 a ee AS 9c" SE wal A Some EIT YS wu" 20 (Fal, 080000 4d TWLLNSCIINGS ica ASW ~ [aE : is WAN Wa 7 a e KI WN WS = | m [- PR ne 7 CAO CE aL TETAS Sat a = ae mh * ri mI) mel lel * - Pr ‘ o a snuppuey jo Usmieciopey “suoan vad -— IIE £. - Mobo) yey gun |’ _ sae conghin ou. vi ‘ane leapiay y eanysedog jo smog eS? | «nee — 2 » ~*~ : €88 $0 99/abed ‘TyZ8Z9Z ‘6T0Z/60/80 ‘E8zZ JUBWNDO ‘898Z-8T aSeD GIUFFRE007134 CONFIDENTIAL

The text on this page is estimated to be only 38.84% accurate

| RE? Be iD Se" 5)0%d ~ f t?| by >| KO ob L699) | vIwy Vy [ePOL ec} = € Q) oSAb dein: a} pueMuo.4 JUNOWY qe [T/L ade RP d "OFU] OIE WIC) Sy, Lid Gly Aq spew syuoWsyE)s ey; eu) Apes | ; | IV as'Wrl ati a fs ‘ \|A? i ATONE 4309 -F RUET TOA : Sl Ne ae C i G aD TA eR pe Wl PUAN? Ohet GOSS esl Tadaet d> 7 an LORITLEE SNES Sd YOLIZAS'ANKII | —__ ae UN 25 Fal x3 WA Wi fqn RIKEN GRE INGOT AT Ss prey ey a G D5: ghopud Are 4 . yt AN INSTA eee "Se. = i Ax? [eran al yTeL! ASI win ' 2S. x Metal Shds. “Oy wy! oS os Hel | “CETMAKGIAS wy GRSt] Galo a | IZ/\ [A LZ timo S750 wg ha) SS AbD AV AY Wi ola? F456 2 aT wa! s duely gf Wy 1 e- me y Ci]. / >» Ager wee topeiete te a 180000 Yd IWILNAGISNOO Jasa-to OW TOY, Ast * =f ) by N j D Lah { wi) & swuewessopuy wgisteoude ‘ON | uo -—— ——————<— ‘vormeceegveten witty! soapy 1eAPAY BF CAnysedsg jo syujod | o > 4, 239T7AA) BRITTD | weary ‘““AsobeyeD Wey WEY UCSOYUEPY YRazy jepoyy pun | ——or SHeTY Yeisiny seg €88 $0 /9/abed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUaWNDO ‘898Z-8T aSeD GIUFFRE007135 CONFIDENTIAL

The text on this page is estimated to be only 26.22% accurate

oy¥q 0} 18701 puBAUOJ YUNOLLY emi ettd | : Pulse Oats |] BOSHAIDNG ED _f Wer neaanses 077 Ae, | T\ ap svieg-owea (97'AS'ZT 2 je, e AS ‘wn ! —< i Av pee ES NIZE a IER rOLLes EN xetes s os { £) UDGNAATS <7 a7lys ln ae 28 {au ale vu ——— _— 4\> APS PHD “CSINOKSI AS Oe , oh \ enn es kuO? iz ystmoeseyad WS iY (teesillelens a . 1 at fom, < wal ens 20/Qnit yard | ar hen gatgor 'WN toss — | Aaa T wits mame syUSwoess0pug ‘gioanoueya ‘geunpaz0ad “sewed | WoRd | S5l/h1 Instructions — Ww wi ui fol Sl ot = a \ 7, wv . ‘@nuy BNE LLC) Sey) UO Ew Aq SPeU SPUBWOLCIS OY) {ALY AYIAO | \% ; ee de DUS | SEWHPN OVS Dl Kc HVT jEPOIN pus | “= exeyy YeRuy €88 $0 g9/abed ‘TyZ8zZ9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD ee es a + . va tog ; eye 1 . ane a) Aneta HEINEY TERN We ay LE PIRATE EVE 5 op Nant aoe vee ‘ yp VERNA 4 RTE Weary eferten fr M ~~ *, A 3 Laverne! oe heen Eee tens ee een ete ee OF tort eae - o , rs brvodsoaee ~ ; ey : oT - mae ad D Te aie eee tet ~ Te ee Er oe] , yeni ie See dete SRT To : . es Bet as ed Shain a en Cea Dts beac iccnasa eerie cnaatnn ieee Port Pee ee an . ‘ “ wane ie eit oa . . GIUFFRE007136 CONFIDENTIAL

The text on this page is estimated to be only 26.58% accurate

= Ula] SCNT. 2 SL. aie [Ae - Sie 218q } revy | 5 eb Hes ra e701 B5eg Xs Ga'wOl sf is Ys Vinee __istfas ‘ints ZI wi 'o7'96 ‘03 AS SS '97! tH foe) 08% fat ere LS ae 45 97 et pel Le 21 zt’ga‘9 c SLS IS" way Bees %! Fea suswessopug ‘SioANOUrH "ON | UMOI‘goanpacosg ‘syseuey | Y5\ij| Se Instructions eanyeuSiS 8)0}!4 > "ANN sue WO} SAY) LO elu Ag opeUl SaWOIAS O44 Jeyy AHed | 92 PIRI iN) HIE-L2LD I DEN MIEC7L-G] LA \ 4 ON shay ALN) DbS-D! Zz, hi + PW UOREDgRUepy RID eyeyy yesoury €88 $0 69/abed ‘TyZ8zZ9Z ‘6T0Z/60/80 “E8Z JUaWNDO ‘898Z-8T aSeD geryantern oem MAL ly LE OE = ree we Se 8 er re RETA. Op wy * ttn eee om -—. ° Pesto Uae ary wh / bentley ies ; J dey Bib elb aba wid wa, rere yams Pach audanosstatulen nie A ‘ prige riers aw teh ateial Ania eee SSS ae eben: Cg ee ee hare ee Dee Ee eke eb eed ot Sea PRE LPI ELE HE NS PIES 28 AN pp eee T) LMG hr kell eh ew 4 te ahead erye som, Lat eynipteennemaetinnigg | bs Denne Lgtieeannah <i at vein sf gman rte eR soe Senta aiie ie | “> nad ears ray ¥ : 7 * yr - . Ais taf See et ale een eranen ct oit ae Cae a ae ee eee er ses , ‘ ee ea , i lt eat | . etae Pie wheter GIUFFRE007137 CONFIDENTIAL

The text on this page is estimated to be only 28.41% accurate

e720 ©} 1e}OL PEAYOS juNOWy MOL afte ahi AORU I ynv Nivaewy OF wv ‘Sr | Wb) PARE oe a ISD | iW denrnur PrN oti > re: W- | iad wa wh ae parent HOA Sika’ A | ) ABHnovIT. HID ING dnya St aby P| UGLY) | me D feel | — | KISUNS SY “adad7 vd! ea) S51 hes r Sry a Uh 99 DA = KOON Y 1S $5 IY gyno WerteOn W-9| ‘ol send anBA yi) |b) WS) [rat ao7c LST. DOA _ way | eS AMID DE LAT | ESRD GzTAae oer 5 EK aif om Ssx yt 19a 13 stkapusy jo peCLLN IN SJUSwaSIOpUA ‘Sssansuey “ON iat : ‘Smnpslolg ‘SysewoyY | ywhii4| Say Instructions jes StL EN ; MIVA x EN > RL 37 PALLY y Canpedeg jo syuTeg > bangp pee “BTU) UE WO) Sf) UO BW Ag SpeUl SjUOWEL EPS SY} JEYI ANAC | ISTL ‘ i” | w7L|20boN] 9 bSiI-S be A iL \} \1 CT C2 am ay ve NCR Uy “te AQ dred | , | ABT) Fas | i PAOD 55 | 6997| sol ft f wMZ! 1st ASL Vds] aor A997] DESObNIHI(t-LtL-G| j, ov uno —| NEW WORRY UEPt Rory epOwW pus | ae Syeyy yap | eg €88 40 OLabed ‘TyZ8z9Z ‘6T0Z/60/80 “E8zZ JUaWNDOG ‘898Z-8T aSeD 43nf Prw poem aa be ~~ “- - . . 2 pgs rts ~—_“ tad tly ORS ates 6 i oi A 2 ee + ars a5 r on, w + pes —— Valea 4 ans dit ate ta De eee eens poi pray bw bears ae OO ee eT ns ane Tear tool GIUFFRE007138 CONFIDENTIAL

The text on this page is estimated to be only 27.81% accurate

77G OF [FIOL paawo4 puncuy oWOND UA TES ¢ | Gditovew oomad'wrltes Worse \ | apes Liner 5p ar WH) [eee \ Cymer ayes [Weel gro" woe ‘re ate Srpe > \ | oR ni ngous OK Vosindae se) Mel Ssti | ama] Seebn) i iIntew 7? wi AY? Wows Ida | aes}. SNPWAY “WP Wy NE? Od ye NS lotvizrles| Pb re w v “ en _ - ek ; “ery rt / fe yw Cc 2s A “ FINDA essary hs f : eI arate ore penep! arsanet 251 Ph , wf S55N 5 har <r WA XN tres WIN =, % 2 | 9A MS & ? G / “WP FILIE? Hid WN ICM MYALSH TZ NOSdWOML ygrny | Ord OSS "indi n> pd OPW Auer Wy poreID INKS kaet PIKSN YM}agswI-Ames cdot] |S D PNeraatopew otAgnl lot ay Eng SIT Us GIST SIoUA ; AG Lerntiels DONG} enonSowd te iis LA ' ee ag a As es Aisye w m0 2% “7 ay PETE GUGNG GYIME GAO (ch) (N Koreawnres ent toug GtouN DO ’ ep = x sGujpusy yo SUSE S4OpUg ‘SiOANeUE PY "e ne 7 WEF) WONBO usp) instructions €88 $0 TLLabed ‘TyZ8z9Z ‘6T0Z/60/80 “E8zZ JUaWNDO ‘898Z-8T aSeD Meta] Fave 7 Loot A \G Ee A Ae BLSI\-9! QI at | wt- (2 git, eas n ibe? VK J ESII-D 75 OPN YEUCUTY NRO td 2 rem 2, ne vas Pte aii 15 a re hep'ottn ye Sees ee evr ere Lele Lats aubed oon ria end Snir ys Ave ed rare we tact fe Tint aD ot ee tens Nee Hes eenytinraas a8 we GIUFFRE007139 CONFIDENTIAL

The text on this page is estimated to be only 34.66% accurate

De 2720 93 [EIOL : eunqaubig © 20%¢ a sbi END > -579 J ea ae mo al ais pint ou ames a Mere ag — row | TANT AS Al 12. SASBAAY | | r SEED N| absitd| oe ae oe Len Fs i AX heya avipy i SS WIV ASSL Whmeak We! vin in righ ball assaf Sena] , IF oe Aayt Youd NAgL (FLIAKOPD WRLIVM PUA pwn ; ie stiapury jo SJuUswWeSOpUy ‘SseANOUSYE ‘ON | UMOES MIR LSTEOyNUSp| | FPS pus fuobeye) WeAaAIY yOQ.UNN ‘gompooosg ‘syswuroy | yb | SOW URI | Bye yey ug instructions _—_-__—— €88 40 21 abed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007140 CONFIDENTIAL

The text on this page is estimated to be only 37.82% accurate

; a a — eunqeubeg 870th ar d783 ova or revo, | | KO Ps [Perm OMG.) PMOL i" Y ~~ | |CSh/bebel|s Lie se lHbe ae ey, sbeq ofu) O78 LUO) SfiA UO Sul Ag epeU s]UaLUA}EYS OLA JY) Ajii8o 7 = 's = ? TAG : pe Aa BOP 2 ary er) im J Ud | | Ly é Oe oe Storeaio Sa | iad ber j2LiY TyAonan aH ens t Lens . ja ig F # OS Oy es 5 " i pow ROW OS SQitang7 2 Lon? Tas | 4g 4 | teeerridy |\OSPDNED PAD TENE F es one mye e A : _WU! | Weyl sp 30 4\w ace eit, | | f U d —— = F a =s| ¥__ | ea Tee pot aw Is Sw ene mt Oe LAS VAAL laynatog og byucrnts) 2 Le Ls t 3 é < aoe — SG SIAL dad “pvt tlasT a A tdd oiear AOTLG LOY olny EyyArteYD aNtTav2 es oe a aon Tan CSG GALL Isto? IO aGA| | OX see RETR Tad ” wy oy? “oy it oe! aD wt Oo? =n tats a. be ar po NV eT om . d |: W/V AI dons ad ol hebh, ae | S| TTA (sxas22 0008S evtdd OL S2bI) SOXH) | IATAaAd LN | BN? | aM? | L | Coty. | m7 SES NleteCZl-d ou Istl, gst [ptbbn] apsii-ol<c anv “Hd | ee »s TG “144 od | Sil] yA V\ 9% a | LAV MISTI | VIET) PAUL) | ; eh scan woipnnmnieie enow pun | 8b orks SOuIDUE | YO syuowesiopug ‘SisAnsuey) Op | UO} yay enreyy yeasiy aE -faobazeg HEAT soquinny |, ‘somnpevosd ‘syaeuiey | Od | SPLV Instructions a ae eel €88 0 EL abed ‘TyZ8z9Z ‘6T0Z/60/80 “E8zZ JUaWNDOG ‘898Z-8T aSeD GIUFFRE007141 CONFIDENTIAL

The text on this page is estimated to be only 32.61% accurate

@38G 01 12101 a “SSYEUDIS 510d if DBO. JUNO : | j FIO, eGe, "9Pu} Ge LUO) Si} UO sl Aq epew spuoWSzE]s OY) Tey) Ayan | ee ee ee lhe iW | dL. 7 ; ic; ary | Sel | etl | SELORNT ousi-9/ oe ens, 3 - ew2¥do 259 | ow Iw f* rT he rss FA PIP Fo t—eaw] IW Jaws “OT LUD EZ __ [toh YIwi> Lstl ly a Te tht |S J __ « | | | 19h | — 17. a ———Ta = a “freer WI vo fr | "nA — _— wb ot 308 ROA ee OF OA OMeT ar yy ater bate Paki ut oA = ad rn , ELA op ator STMT ee Saleeeesoere Eee ~ xAP . Pirate ede, beacioe 7 ty Upsala a ep eae arare smn inn ne Me be VA A 5h I NTA NN" REIDD RH mae ~ Lenssen > ty 4 - LSh mz oO / ’ 9N Its aM HFS | ‘Retid asats “aimtes coves 1400 'yondd ucts EPPS 2 IOP Oa ISWFD CnPTLElLOY ofay me Ten —— 7 ad + NWEI aM o>! UslId cH Medd UALS he cit Vfl 7h L —— AW oa) vag 2g * EY LoOpecypueDy auzy sSujpuoy jo "08a 2D weuaiy JOquiny yessuyy C c IG ee LH3-1-4| ¢ CHP Wey IEg - eta opm 7 ns ete at op oper Carina A Ph ; ‘ . . ipScdlion 3 * ° es CII DATO LE I 4 ON eR Es ete y es sal be be det lt aot ed eee Mee ey t rw ae ed a ed i ee = €88 40 pL Labed ‘Tyz8z9z ‘6T0Z/60/80 ‘E8zZ JUBWNDOG ‘898Z-8T aSeD GIUFFRE007142 CONFIDENTIAL

The text on this page is estimated to be only 26.62% accurate

a ¢ a r STAM | Padi pre7stY : = sCugpuey jo ~AsoGoieg Wey iaquurny lnatructions £88 JO G//abed ‘TrvZ8Z9Z ejtqg 7 (POL plEauc4 junowy i210) sbed Ce . EBON HII F \ | gaz) asSSobN|AltL-w2ee 18h | SS bIbN| Absu-D/| amp) Lott | BLQO_YN] Hie-L2b-d {S74} | SStL) w9lbhN| Uvh-iHe =r HEYY OREO] RUOPY yoPOV pus ' i i uUsuIeslO 'SIGANOURWY ON | WaNOi4 ” — peapay @ eanjaedeg Jo s3)6q emily SHB WRIST *‘sounpe vos “SOWIE ‘6T02/60/80 €8z JUBWINDOd “898Z-8T BSeD > Py ae ee sane Bre ‘ Pee by Abn rt ay pabeiedbelaeael . ‘ ‘ ' we - Aa eT ee eee ee i niambuatires ou jee umemsitoeiioa uh caasiae nha hd nail vier thteniog bo dicpirboendhShetinaaales t rere . She LF aponned oe hanes saat jee len Nab op aah Ais ok) . . i sess aneneA Sovt cts a eT setae POT er ea , ee aE ee el en eee ene ee a aren at iL ee Mee a On ee ee GIUFFRE007143 CONFIDENTIAL

The text on this page is estimated to be only 26.36% accurate

87BQ 0} /ePOL | WATS “Egy | Cael et —palondtlint~ AoyId 47D m7? Fi 4eDUg ___ Pro BGT WOSIRY Wao] insiruciions BINPWUBIS 6,404 O79 | S5tl Seth S21 (cf} | OPL T Sst ae DLSIIKD| 2. Hel2e-9) 9S : Tn [Se ae) a PbAbN| — Vbsi-5] B,, ae $SI L [sz fepoyy pue oortpy UIP €88 40 9//abed ‘TyZ8z9Z ‘6T0Z/60/80 “E8zZ JUBUNDO ‘898Z-8T aSeD ‘e y perv nerT " : Se Sabet ie al) Stee ' i ineh ines wt A mw eh acne, 5 Reena erento i fl cee niet sownrut > oh arpevetpiew 7 ‘ ov ~ i adel A. nie ipa Ne ee 8s AE Re ae Se tert vatetalt eran ter GIUFFRE007144 CONFIDENTIAL

The text on this page is estimated to be only 32.59% accurate

—~opp 7 Yr a 7 ‘ONU] Sue WwUOy $y] UO eu Aq epeW S]UGUEPEIS BLY [euy AyipI@o | 9 DAT | - DON] PERILNT ATE VEG 7 eee | a | a lA BOL, "aaz | aT LibN A 2U9 w2 ages be Sf ye wh ty SIW | iw] Ye Lotow rs | SStL | Gal! r Sali. Isth) . go % (etl | S21 | vf bob PTH] VAATED peo - aia —| ~siuppuey yo : ————| MIBIA GOW BO)p I (uoboye5 ey J0QUITIN ; aan Instructions €88 40 JJ /abed ‘TyzZ8z9Z ‘6T0Z/60/80 “E8Z JUBWNDO ‘898Z-8T aSeD \ 92 ODLPSU\-D | Az 4 9\ n {Cb n | STZ Al I jepoy fue |—or ONE YRolly Sieg) ae ous ee . ‘ hx sia Haar silty vibienent eaepinalablors ie kere irate ated | raat jay ; bee reese se ete antes e e went ’ ri heinerictemate hed Ld aad : GIUFFRE007145 CONFIDENTIAL

The text on this page is estimated to be only 26.42% accurate

e1eg 0} /HIOL PJEMIO, PUNO jRjo, 9ERg sGtmpury jo fuobepyes yey saquuny Instructions PRY rT o mi } “AN G8 ULUO) SA! UO BLU Aq SpPta) SUeWayEYS SU YEU AgLIOS | PUTT | 94371 | ONL | ag 71. Si LG Jv | O7k, (EBLN hS\\-*D| 8% . POPY LoOgBoYyQuEDp, japoyy Pue | yerury envy yesoury €88 40 BL /abed ‘TyZ8z9Z ‘6T0Z/60/80 “E8Z JUaWNDO ‘898Z-8T aSeD a heheh nner pegemnbitn's fey pe i A ri", i ns eh ph bin taco join a Tat re wenn A het £m Av abate Sivirlaie hat ot at bea et "2 fee ve he stale mo embeteyie Stoticeeherreceshiey -tetnreseetlon- neat hides icebert Nee ae nae Dbanerirebee eer ae ee 0 ty ee SA)appiw fee y es rd leerwenne eal oils oc eS ‘ ' Dhara. re ety De yr peanrene nar tc nas iene Dai wasnee se yD pk th Veh aNPO i . , , PA aren tag saint inte OTN ADIT TY CS ey de a ee Te Se ed ge aoe eR LL oe ees tk rit an on pds rely tice b ’ pincers eri ort ee GIUFFRE007146 CONFIDENTIAL

The text on this page is estimated to be only 28.28% accurate

ce CC | 5 | Sh | tea, beg SN 628 WLIO Sfy] UO Sw Aq ePeLU SYUSLLAPEYS OL YOY) AMUSO | NT AN Pe, Rie F Art be AAD IDES HIN AoE WG i Da pd -vordz ys Acid et “a | | = —Td drm, ant” 90 : StL Bx SON rae GeIKg = —} ie a : 2a" ul MeO, 1% 419) | n I AV | | JF 5S71[ w9lbhn! Lsh- Lig|¢ Nv / SSL! gol (ito | PRE <i eal | tstl| r {| AV ‘* f\ OAL! ae ? Vit A Am L£4>| 9331 ma A yee 9d at VIN F ie —_—— * pRpy VOREOYRUED| ™KoboseD WRsaTy soqQunN ‘204 i yay awyy yey | 8eO be Rafe ALIVE ont eR artnet retrnbeneeey inn dnd wu tia eee eet dot th eed eo opt ete ne rind weber’) [Pw Atte = SY or) aren Aare jo Aor hegre CAA RNC INresin an eer rnb myths ehcips iptebebrch gate ine wy Tear nee We Chet st ; ee = Peter me in ee oa " “ OT se ee eet a ee et eee ae tet Le ee ee pee ene een) a al eee te eae * N “ RA LPO ELAN AT NG OPE DOPE CD Ue Het Rr i peice mi eparmoemit nm mae Vitor: mt Nienineh Ports i Cendetny, (aaa ‘ ‘ ‘ " Pink reir pit SAM ry A bis ety ee ox cre (ng ? i resets tees rrneres Sac ne er tear aT Aa ape wae eaten toe a instructions — €88 $0 6L2abed ‘TyZ8z9Z ‘6T0Z/60/80 “E8zZ JUBWNDOG ‘898Z-8T aSeD GIUFFRE007147 CONFIDENTIAL

The text on this page is estimated to be only 26.44% accurate

Bs: 8 EL\ € € Los cee a oveg 03 jej04, | ) BEIRUT 60H led See 8 eo ¢ 1% ath) RD St “ / 7 : “ANU) GR Wao) BY UO Ouu Ag PRU syLeKUesepS OU YELY AjHIGS | uO \ 9 a AON] BbLSII-9| 2%, SSGOLN| AIt- Ged! Hh, 1h = me BUN MLS) a97- EL-8] S. TH |_PELMN| SbSI-D Es Bhi patentee hen pete tebe b Or RRO heal nee btn gym ahbe parol aS beatae : ~ - Cir il ern} verry , os SMP Ss od 9 er eo . a er . DIBION! Kie-cze-g) Co fa emmy joa AO 6b o8 hp eee tte trary Pee nth wwe: ‘ te ee hl ‘i ° Ys" Aaa iaametinte inte toy 2 nhiains raurieaaensinget hey Ming teihlibt bys salyinatrninerh sebalehlivtenrdtt! Medtebiie tes rang cpm «phys teens fey cr ie —s \ Lee Se be ie ea) pS ed eal Ae el ales te fm Aaah rasan are sane wy Pyare hn) Adeep e POT bate Te ee ee aod “2d Wietdeo WLpor FAD) IHN dnwyem vty lava qx) TH avezas AVy- rd Pd »" ; aie 7 = , Busouiea T-o D> TH! & ts } WO 7-/°Z/ a 420 WED: | & ; wLeL-§ Pd 7Ie3 Che Lis ‘ owihayoo DS “ad 74 soe! Setoiir aga ool 3) aeicadie zi ! Hy S i pO Ae I] I> op GrerWAd CSsu) | : St 41 > Ssdec Rivonia esas leer tn’ sonia.» | W309 BHAITANTLS ObSII-9 | e abs t Pals = ea a SoM a ape dont gh) ttre: : sepaiie po hve a acand meses pdetocts] = ee ee eee ee eee ee) bow AS od Le eT PLZObN| tHit-L7L-9 t. * “e a az —.. . Sn — ln an <- i ; < = > ; mt | a} te < E d ~~ f eo LIU! aar7d pwede * ! er ———— SspusWweSz0pUY ‘ciaAnaUuDyYy OEY UOGEOp UEP] re i ““haoGoqe: Wesnuy *seanpooolg “syseuseng | yy) Saqyy Wei instructions €88 $0 O8/abed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8zZ JUaWNDOG ‘898Z-8T aSeD GIUFFRE007148 CONFIDENTIAL

The text on this page is estimated to be only 27.15% accurate

got Be C Hage — ac e eye el E ee * 3 i é: + eine = i ~ — iS = - pai N | VATS | RAT Y) ———— ol su “Aeobeze9 wesoy bur SWSMOs OPER ‘saonnoueyy | N J UMoOL4 = Teunpes FOid ‘Syrmussy | athe. eteoba Sune Ob: bs uy + . c aT f her rt hens ieee wt thither mentary » eek a eay ant = a= os aim bee ape eee eee, ee waa Sears ms o ‘ ae “ : ee ee a Yap OPEV N th aA alr andl Sat) Nira Mlle ip te beds benbakieed . a ras r . ; a ee beiodianthite. eiadpudanelnr edd cantatas sean Rie wrpncyvenhditetdarn be oreaomeen eae Me Sidecar Hh A cael oi , = ino ieee : vas : q - : r r oye este Yer 4 tlre 1 - , o seagroriy yee giiempaisiens Fy TE Air wt eente meil ie wiie 5. — : ‘ : 2 bidok eae ce ee " poe then. heb eyes 11 fo 4 “393 2 BSESbN aBsTI- [sl vwuxoc €88 $0 T8Labed ‘TyzZ8z9Z ‘6T0Z/60/80 ‘E8z JUaWNDO ‘898Z-8T aSeD GIUFFRE007149 CONFIDENTIAL

The text on this page is estimated to be only 26.15% accurate

salhgis| YLXe ALTZICl FLVe } ‘ : ' - + ene uy me are ‘ $6. newt #4): Pa Sra , et ma PT tie rif ws + er? Ey | See ie re eet , ‘ mo, obey | AD vay eve ERAS aa | ae Ld "BIMY SJE uO) 8/4) UO alu Aq apr szUMMUayE)S OYy JEW AjuCD | SSW MLENWTS | are Leb ‘v - . (EU ers Sey ints ape AE Sh _ Sikogoy wae . VLA! 9 —— ies | 2 oxen 40 5 1p MOT) nvr a | Lad! K 5: *) o[z aS eis NI IW OWES wus 5 SGu|Mrr jo ‘ | ; : Joquiny . ‘ : WRN UOYRIYyRUDp; | : jeapay Fy cinyaedeg jo Sjujog yRiouty j Wey ‘ means hr . - 7 a “~~ . La rn trees wei FAR ra igmn neha bia a ‘ x < - ~ Aha ee mee nb hg Rad bet racers Lhe pet * na fey HI a yiven ee pe prrernne Y Cd beat PY pteylemrrey 17 . ay ees va a Pr eer <r iryt pitied 4. hae ” €88 40 cgsabed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD aa aoe par : rte thes ¢ ahaa teh ahs a et Vee Aye ecetigy “ thee Dad pee ot ek bas eee hp cite tr eT ee aetna / wer Bot bo OF Fe Pr re Sree GIUFFRE007150 CONFIDENTIAL

The text on this page is estimated to be only 47.77% accurate

Ec\ 8 SL 3 3 ahIA eumeubig 800 ©3Uq 0} [PION ea, sGeg “Aful Que LO} SIL] UO Sw AQ OPRW SIUEWATEYS OYyp EUS ApQUOD | U7) AT } er] tC Asty 1g i" a a “a Nee Ce Pe ee a ist} ddd) stool SST Le a ; gt #10w1S/ op t-[cL-G bt a eak| pes 8 WEY UOPED|AVSP] poy pur | sGugpur) jo S]Howeosi0pLy ‘srcAnoUnYy UWEaury BYB YEO BBQ JOCUUNN *‘soanpooosd ‘sysOUlO instructions at eaten tins Sra ee €88 $0 EgZabed ‘TyZ8zZ9Z ‘6T0Z/60/80 ‘E8Z JUaWNDO ‘898Z-8T aSeD GIUFFRE007151 CONFIDENTIAL

The text on this page is estimated to be only 38.98% accurate

S9tG OF 1Fj}0L , Selle Faia Sts esnjyzuQis $2014 9 WS] Ssxs8 eo hh han ive 5 | 8) shy! 9 Radia pamey E fe 14/9 ae: . e i h a ALaw> = | @9L) Uy a | ru tt ee fe f el | gy — a | —_| I] |¢9 “lemmas, gow? way [DG | m9: as __ Co | NANI AVS 5088 mt ea i ese Mo9T __ + | —3 aw KZ L _4 ml | mw99T| 399 —<<$< a tT | fr AA a ; com —_— a xunwgiay ob O7LUPNLA | oo a997 : Rn eo ec NT ed anaant sanee eae ; D7L| &¢ _ Le MAN Sst NN “iat — — sGupueyyjo SsWeasiopug ‘sieaneuEy ‘Dy | LAO “« 'N AsvGayep ana Jey ‘seunpazoig ‘Sx4BuIey — tit. Sony SRY LOR EY GUS py ys feabay 9 Gan} sedag jo sjujog Instructions Tr sled Si Ne ae ne pee AT he ee a een ae at Ces ha ee SIS eo { ! €88 40 rgzabed ‘TyzZ8z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007152 CONFIDENTIAL

The text on this page is estimated to be only 40.21% accurate

fe ; 830G 3 pejoy F ) GIN UGS S04 — ei a uno | tte BL a 3 2 =< “Oru) Bre UOy Spy UO ow Ag epew sjuaWaIE}e oY) you Apa | Bret? 3 , En DIL AMUN) desi] a — SLURS =, ao — Ad | LOSS SW SbES-9 1 ai x 29 gt | 5 | yr NT ey oa) .? ee 7 PLEVON| OSi-D be fx * “Rai Iga} Idd) PSBIN| HIe-CeL-g) on [Sse Oa SEbebN] BtsirD : ewTt . SDUIPUET JO SyUOWSSI0PUG ‘sucANeURy “ON | UML — = : ~Eyy UO|JPOYRUOpy jepoyy Due | tr f1080169 wealy JeqUngy ‘SOmmpodosd ‘syseuey | 5). , Son peApuy 2 oumaedeg J9 S{UIOg a yesol|'y OPW Yeuy | BIE ' Instructions €88 $0 G8/abed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007153 CONFIDENTIAL

The text on this page is estimated to be only 27.57% accurate

ee i | aaa ae b hsbs\ + Bobs puemuo-g JUNOWy “Farts ee ae TANCE — a te P et re Cre . Whe es ye yess " gepbeshey i eeem Sz Hench pms pence er err te S31 SRL EM RS RIP ep NS RRND AE PM RTS eRe PR ESPNU LP ye Mt wl oct = iw & A is | Yous? anwidul . h- sGuypus" jo syuewessopug ‘sseAneuey “AaoBeyep Yesly | OQ ‘seunpecoig ‘sysewuey | jij | So Instructions ‘OnU} ale LUO; SIU) UO ew Ag epew spuBWiejEys ap yeu) Ayes | Wdaw 3st 350 SSTLISEZTLN 44959C-S ysEyy VOPROPAUEP| OPOW Pus yey eB WR €88 0 98/abed ‘TyZ8Z9Z ‘6T0Z/60/80 ‘E8zZ JUBWNDO ‘898Z-8T aSeD ney ae . pene pee ci at a ay tow Le tpt rely Home aon eve ver rete tire ¢ a ; 5 Zt Fa 49 if ie ea te a a ij ry : . £38 , eg See Ee ote a ae Lge ae. ‘ ays er et ee apne bho dt hia wih. pipes Ae Sek 7) Tere . Lape imino ~otter es ¥ ee GIUFFRE007154 CONFIDENTIAL

The text on this page is estimated to be only 38.01% accurate

eS sl me SC | 1 oh s | PAID rT] “Asobeieg URZOAY | 1OQUIN ‘sesnpecoig ‘Syzeiuey WB | sayy | | “9 re ok OSE | — AOD DD anoge sy aweS “OfU] ave UNO) SRA US OW Aq OPE swroWaIRRS yy puKyE AVIS | (3 mami sod 2 ; tear ot OR 1 Oh MR OARS AC ere Ae) PEO latee er nt . ml reer ¢ ae v t “LOWEN GRD GUS I Bo cb awd ENA “POOOD MATA IO nihoeSst F-00209 “Arh v\ N92 | gL N71 WUSSTD 2 ile 7 54 | 9271 n > te Sy Ee = Denes te te tl OS UAL | _t Nh a? : ™~, SIT got | 1S - OL | wo “ON | UMS (eAY 9 Gingiedeg jo syujog —————— | efiypue jo syuowess0pug ‘ssonnoueyg | j it Jnstructions a te ee ee . Sete TE SSeS: 3 : et | Sid anea at ae pos yh see Rh a a i 5 ee ee Seta. €88 $0 /8/abed ‘TyzZ8z9Z ‘6T0Z/60/80 “E8z JUaWNDO ‘898Z-8T aSeD ~ G3 |wlneuds| weizegd) ol HIBYyY VOL POY)WWOP| a\ rt @\ Ve DPE Se a inh Rl nals Y has aT phe Dat od eee hte PTT TORRE, «eet tne fre CO een nk pen peer errs. tov “rw en wid ea PREM Hid | 6 Pye ce, Tie AL aR phe ete se aie be . re ehrod 4 Apiole iv cer) mec reta ne yruoapy GIUFFRE007155 CONFIDENTIAL

The text on this page is estimated to be only 39.47% accurate

— ) UMwubs $04 oe aru} Ove WO} S/Uy YO Ow Ag OPEL SILeWayEIS Ou) FEU AyLeO | rg Ws KeFD FO C o trie BOD Sv Tae G7 + ZJo- 7Aes AA Aga POS HE EO Lee $ PANS . 3 GX VorT wied-nnods Fa 7 Vzél ev > inal MOP EVP | WOH? | aeeese4) ———— ea 5 sthujpurry po Sspuawesz0puyg ‘sasaneury . NEY UORE Sep! eae ""Aa08oyen Fs>41y J0qWIrY youoiry Instructions €88 $0 ggsabed ‘TyZ8zZ9Z ‘6T0Z/60/80 “E8zZ JUBWNDO ‘898Z-8T aSeD GIUFFRE007156 CONFIDENTIAL

The text on this page is estimated to be only 34.20% accurate

€ [s| Svboi ~ bo TLR} = 5 £ 9 ni — “it Ab * [Zoupee STUD pwA7e) GP Se TR MA OOD yes & fi oL® =4 pivnce 900 inv (sae Brea bn AE MAD 5 9¥de¥ sw _ M20 Ja fag) 5 \\ ee ERM DRC ay ae fe a Sid eae man ey ae LHnomwnd isms wenn ANSON GVEA RIU ne Zed > ” A PSN 3 e AD> 2 E) ASU Gd da, he Saas crea nen OTs ee oa <td ery Rit OL LENS Ag ai — IR BOP yA uETy 1f4pa4y y Ganysedeg jo syujog | uesouly sOugaues jo RS Uewssopuy ‘cussnous “ ce “i ON | ume AsoBoyeg Yescoury JOTWUNY “SO/NPSI044 ‘Sysrway weit A InsttuctionSs ©. eters saith odeenemn mre mast €88 $0 682abed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8zZ JUaWNDOG ‘898Z-8T aSeD ores ON O73 usOj S}uj UO Guu Aq OP RU! S]UBLIETVIS Oy yey) AynsBO | Doh] Ge i Sl 14 B\ no ror "i 9\ —— A % DZL/Sl bob) ALS] eee Tr “eT 4 © 199 | DRONE eg) 4, " St HOLT NAT ET cote 02 Le ® Ao 1190 }opo,j pua | =—— er SHBWY YEU y #1FG aarUBubpy o70%4 epevens ree tere cr eee vs a one eee =e = we paneer aap Mepis tenho Rie Abn, dae se ee Ra ep baa tie tel Shain andes an Any Ae teehee Nhe a ne bina kine bh cee noah i + — eee ene eee AO Prony NYS pen eatnmnry! Mahe prin . oF PVT e PFE Renn, Sutihas bade odrald tidunseed ween stort, ant Serre S Sag Se ee Ee eA Ses OND enna etnies eed Ade a tee ee eee ea ve d eens Wy AL beh re banat + Peftrpekapacs eke GIUFFRE007157 CONFIDENTIAL

The text on this page is estimated to be only 28.29% accurate

9) 9°9\ : |9| tLba 3954 eyed OF 1e1OR G| Oc S| try ZIL9 wm _] UNeALty | mr bh = fey), a0e¢ eT vm AN 1 Bl ee " PR BINFBUHS 3K : “Oru vB UNO) SI UO au Aq epew epusWayeys ayy yey) Ayes | o% Ye \@ ec | | ade: 11 | h SIO] ‘4 LW yobinnids| WT-LTL-G) | 9% AL | aLbol DO bSi\-D oy QlQob i | H1¢-1L tho “ey a. EY] UOPEOY ZIP] poy pa | tH yeoy SRA WI | aed €88 $0 O6Labed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8Z JUaWNDOG ‘898Z-8T aSeD at aposk. moe Nahata ieee nls pars py poe Ve pe Shah y fe +) * 4 > 5 f r ; é >. 138 : F £ } . Sep tty ea, o pee nw ht wa ets a oh aT SEP beet 8 ey an anLBy mw heme ee net ayy et ; _ +m eer, x ye ere r: so erm et wh ‘re pe ail oe ed atl ro oO eye! i i lpnrla fu 8 CE aaa alee a oat © Marin GIUFFRE007158 CONFIDENTIAL

The text on this page is estimated to be only 41.11% accurate

Se bs / c 7) 9 toa% & : Tel! “ott ‘ae ———- — - _- = — Pe te i me i re EE dis Eve Ree we ee en ee a= ganna SMG OF 1B}04 et 1 | / RINE Sos =f PutMDY JUNO >. | ‘fl eyo] ate. | ' i “OMY G/B WO) Sag UO aw Aq ope SwAWopEs ex) yeur Ajtuas | | “een ath 4 ie a “a } a a 1 ———— AaeS | = flee || it I, — w TL —$s97 Heath MeCeg) 3, i Balsa kirbe eas at) Rae cane eree ney Im hy miele tl mortal | aay Te = = baa aise Ione ney: ee oe wage ott ad wT he ee ont iyow SPU 28 78 ol v hat ht wv ao” * rer : . ‘ rn Tv ' PE RR VEILS 9 at eet ee, idl nastahhecnieniatentederddl acnet ee ed sinha a pepe ph dobied bnslibaadd ahd uJ zw Seis at ae e Si = _ rg, 891.) DSinb PbS\\- 9) 92 WF Se —— = Let Ly —<<__ — as WUT) WO WaTG .. Fe Oy] | a o ay 99. SEEN suet et — supe jo wou “haoBeyeg ayesoaiy | eles ee ORT | ON uncut |— | RY UoRBaywE tie SMNPSIOY ‘SyBWaY | jh) | soppy {PALUY Y oanyzedeg jo ua | aan Zip Pe | oie 7 one sayy e1eC) .lnstructions Si = aie, PE Lot ele Li RS fe RNE €88 $0 T6Zabed ‘TyZ8z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007159 CONFIDENTIAL

The text on this page is estimated to be only 33.67% accurate

ooo eunywub)s 9 . BIB! ILOOWY , : ; B}O] OST "eTU} G78 WO Syy) UO Bw Aq epelw spueeyers Gu) peu) Append | -_ somew = he et een analy See niin Aah ne ne ek ONES i Soe ke 18 ye A erp ee a) ee a te Poe = ap ores £4 noes "LAWNS 1h "Sp eas eee __waraaset ~SonwTaD AAD WIRY UOLROR OLY BPO pu | = yesauy exeyy BEAUTY €88 $0 c6Labed ‘TyZ8Z9Z ‘6T0Z/60/80 ‘E8zZ JUaWNDO ‘898Z-8T aSeD GIUFFRE007160 CONFIDENTIAL

The text on this page is estimated to be only 27.57% accurate

39\ [<}o [hl hel 5 BYE oh eee oye 0} peyoy 359) ft jeyoy Oe} | ag Premio.) JUNO esses 6H ga31 | dst 4 e asl | -ssti} \e LSsL Ssjuewsss0pug ‘ssenneury ‘sounpooosg ‘Ssxysrwo4y Se a , es t ty ale ’ AIL | g@w_L' adsl) oss. OSSXL sti? ted) arbaby OL LUD ad a aera EY VOREQYEPVEPE jepoyy pus €88 $0 €6Zabed ‘TyZ8Z9Z ‘6T0Z/60/80 “E8zZ JUBWNDOG ‘898Z-8T aSeD = et te 7 enh eat My Pi Fen hee ee ee the te Se Eee Tee abs a eh ORAL POOR Ie Pt Pam phate nebe P ae mmeet mg yet vs ATR et Dart dd pee hy ae at epee 7 7 - uae A371 * “ r. ; i “ sac denn) Me peeing Adda u TRAE wl Lebel) Pie Ewe OF Ctr AAU oT Aah i Oe str MAND Oo 2d Me Ce te . S , 7 9m nm en che en 6g TN ran ee ee ere te “eee WD Lad GP Se SSE ee ary) eee } 3% : 3 gr ¥ td Fd ® My) hire GIUFFRE007161 CONFIDENTIAL

EXHIBIT 42 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page795 of 883 GIUFFRE007162 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page796 of 883 PU ee eae scan scan0001 scan0003 scan0004 scan0005 scan0006 scanQ00 / scan0008 scan0009 scan0010 scanQQO11 scan001?2 scan0013 scan0014 scanO0O15 scan0016 scan001/7 scan0Q018 scan0019 GIUFFRE007163 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page797 of 883 GIUFFRE007164 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page798 of 883 GIUFFRE007165 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page799 of 883 (ei eet MI nl GIUFFRE007166 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page8s00 of 883 GIUFFRE007167 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page801 of 883 GIUFFRE007168 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page802 of 883 GIUFFRE007169 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page803 of 883 GIUFFRE007170 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page804 of 883 . Se GIUFFRE007171 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page805 of 883 GIUFFRE007172 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page806 of 883 GIUFFRE007173 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page807 of 883 GIUFFRE007174 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page808 of 883 GIUFFRE007175 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page809 of 883 GIUFFRE007176 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page810 of 883 GIUFFRE007177 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page811 of 883 GIUFFRE007178 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page812 of 883 GIUFFRE007179 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page813 of 883 GIUFFRE007180 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page814 of 883 GIUFFRE007181 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page815 of 883 GIUFFRE007182 CONFIDENTIAL

EXHIBIT 43 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page817 of 883 foo ov essen FAY 8. séfa 9. AFosten! 60100 Ins. (068) 261033-8 uns 283044 e ROOM SERVICE SOTAL FiikCkss Oh ayy, Me “4 ¥ 4 : NAVOUTISAIININ GO 14 2827 PERSONS A WAITER NO. | O62 3 ROOM-B/F food 820 00 TEL 9231 CHK 20% ~~ 4 VAT PA bA Lo viet eles a SERV:C% 2D. oO 4 COFE/TEA/MILK 320,00 T FOOD TOTAL 20 a) a VAT 7% 24.64 { 346 bA SERVICE 32.00 TOTAL DUE Sree .64 923 923/ROBERTS HOTEL GUEST 376 264 HCC RECTEVABLE 021009-02-00278 TIN 310 1 64770 2 RD 3014 22 000232 wwe CHECK CLOSED 06: 13AN-—-3 re t c1 Ww a) PAID—CHARGES NAME: ROOM NO. ; “hw Wun V\ oii, tet ADDRESS :— SIGNATURE 1 a 5 eam —_ GIUFFRE007413 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page818 of 883 112 0, Haars n.FwnaTw 8. oi 8. aati 50100 ns, (063) 261033-6 uring 281044 9 ROOM SERVICE ROYAL PRINCESS Cutanc Mas “| y a ; NAVUGUNITAINUN 50 14 2827 PERSONS TABLE NO. |_ CHECK NO. “ AZ WAITER NO. Ob N¢ 32106 DETAILS AMOUNTS 5 ROOM-BYF fo NAO -O6 Ne ne a v TEL 923/71 CHK Dane S57 4 eT Bay ae SERMCE A. Oo 2 FRENCH FRIES U8 0G T FOOD TOTAL 140 00 OjAL 4b. mal ese Bade 7 Ay SERY ICE 44.00 TOTAL DUE 29 347 923 923/ROBERTS HOTEL GUEST 125 4? HCC RECIEVABLE 024010-02-007410 TIN 310 4 51770 2 RO M44 22 O00232 —~——-5 CHECK QLOSED 06: 2594-—-i a“ J J PAID—CHARGES ¢ / | NAME :— i SAU ROOM NO. ©& f. Vx ,_ .C, NO, yf ADDRESS :— 7 | SIGNATURE of al GIUFFRE007414 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page819 of 883 2. Wadena 0. tiles &. 1Foalyni 50100 Tus. (063) 281033-6 urine 281044 ROOM SERVICE ROYAL PRINCESS Cutranc Mar al ¥ “A , VSMUOGUNITAINUN 50 14 2827 CHECK NO, ma | LP Ine satin DETAILS AMOUNTS Fig @_/d0 SRO TRL 4/64 OK 417 GST 4 OCT ' 2 Sey. pt WOO ee /.., /9. 0 1 F RICE PORK CHIC 190.00 7 yal. y 2/0. FOOD TOTAL 130 .00 _ VAT 72 10.04 (fe) 3. 0/ SERVICE 3.00 os TOTAL DUE |= 4.55% Lo % 923 9723/ROBERTS oS HOTEL GUEST 153.04 ACC RECIEVABLE 9241013-02-00435 TIN 310 1 61770 2 RD 314 22 00232 ~~~) CHECK CLOSED fie: 4AN-—-PAID—CHARGES NAMES *] nes Vg ogrm nh LS ADDRESS :— a “*BNATURE GIUFFRE007415 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page820 of 883 12 0, FAM A>. A 8. soy ¥. Meal 50100 Ins. (063) 281093-6 urns 281044 ROOM SERVICE ROYAL PRINCESS = y 4 NSVOUNITAUNUN 5O 14 2827 Crrane Ma PPS, No CHECK NO. WAITER NO. ae No 32129 DETAILS AMOUNTS TEL 4/69 CHK 436 GST 4 00 vr Sev wf % _____MocT'02 oétogay ,, Jad 1 FRIED SPRING RO 420.09 T vat 7 pe 2 1 F RICE PORK CHIC 130.00 T 2 5 FOOD TOTAL 50.00 re . VAT 7 19.35 [cj £9 -2 SERVICE 25.00 TOTAL ME ee OS , 923 , 923/ROSERTS HOTEL GUEST 294 25 HCC RECTEVRELE 0241014-02-04e4 TIN 3410 1 64770 2 RL 214 22 OIN232 ~-—— CHECK CLOSET 06: 98AN—-(PRID-CHARGES eis gh \pndctonmee GES WH Arr”~ RA .C, NO. — ADDRESS :—_ SIGNATURE GIUFFRE007416 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page821 of 883 a =z ‘ 112 8. Fina asrannrw v. ies v. sli 50100 Ins. (053) 261033-6 uWne 281044 se ca Swimming Fool Crians Ma TVBOUNISAUNUN SO 14 2827 pis NO. CHECK NO, eo =623621 AMOUNTS rn le ee TEL 44": RHE 624 GST t ABOCT ‘02 02: 23P4 1 WATER evel) T BEYR. TOTAL eo fl VAT TH 1.93 SERY ICE a ell) TOTAL DUE 3.45 923 e3/ROBERTS ROTEL GUEST 29.43 RCC RECIEVABLE 24016-f12-i0630 TIN 3 40 1 61770 2 RDF wid 22 Vso ~-~-13 CHECK “LOSE 92: FM-—--ND) PAID—CHARGES -. NAME. :— ROOM NO. ADDRESS :— | errr st osesennenecsenyeesnnnssemhiisissamere~eemaie SIGNATURE \ GIUFFRE007417 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page822 of 883 112 0, Franny aang 0. fos 9. 1oslyni 60100 Tns. (063) 261033-8 un 281044 @ ROOM SERVICE ROYAL PRINCESS Cxianc Mau 4 y A NAVGUNITAHUNUN 50 14 2827 ¥ . TEL 92373 HK 14° ry 9 a % a : 16007 92 622 9a “s ah come 2 FRIED SPRING RL 46.40 T OOD "ITAL 24i; 0 Fe R348 Foon °378 so SERVICE 24 00 TOTAL DUE 2S2 .45 $23 32:3/RORERTS HOTEL GUEST Zod 43 4fc RECTEVQBLE 3 g24018-02-90597 Tit 32104 51770 2 RI 3014 22 90232 memes CHECK CLOSED 3&5 29n—--PAID—CHARGES$, N — | ROOM NO. \ 9K rs ‘a ALLY T Ale Hid ADDRESS :¢ SIGNATURE \_ i | ne re | \; WA AA He JS... Le}. 4 GIUFFRE007418 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page823 of 883 1120, Hana Fsaaw 6. tits 9. Foslya 50100 Ins. (053) 281033~-6 unny 281044 ROOM SERVICE ROYAL PRINCESS Crane Mar a » 4, ; VHOMGUAITAIUNAUN 50 14 3827 WAITER NO. TEL 9223/4 CHK 14? 7 aT 3 LBOCT 02 073 3700 _-s Oe tt ttm SS rn ee ——— om eee ee A te te ti ee sine 3 FAMILY SREAKFAST = vay U0 FOOD ~OTAL 730 40 VAT tre Bil OE SERVICE 72 TOTAL BYE PLS .06 923 923/ROBER TS HOTEL GUEST 335.06 HCC RECIEVABLE GALeEd2-106E07 fIh 310 1 si77l 2 RTH 5614 22 900232 rome CHECK CLOSEB 98: 008}1—~- ADDRESS :¢ SIGNATURE GIUFFRE007419 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page824 of 883 120.* — . a,anaw 0. tiles ©. 1Faalni 50100 Ins. (063) 282033-6 uvn¥ 281044 @ ROOM SERVICE ROYAL PRINCESS Cuianc Mar “4 Py 4 ; NBUIUANISHIAUN 50 14 92827 CHECK NO. N® 32161 TEL 92374 CHE 153 IST TOCT'J2 WS05AM 4 TOST/DNIS-CRESS*. si tT FOOD TOTAL BO 00 VAT 7 2, 1é SERV ICE 6 i} TOTAL QUE 24 .16 923 323/ROBE?TS HOTEL SUEST 94.46 ACC RECIEVABLE §024y17-112-0067% TIN; = - 3. 10 4 61770 3 eB = 5044 22 000232 --——5 CHECK OLOSER 08: i5AN—~-~ PAID—CHARGES “) NAME :— 1 / ! ROOM NO. mapacn. : ro NO x 1 \ rn 6.G. NO. ADDRESS :— SIGNATURE Miu Cao GIUFFRE007420 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page825 of 883 12 0 u adienaiy 8. 109 9. Seslyai 50100 Ins. (063) 281033-6 uns 281044 ROOM SERVICE NEIVOUNITAUNYN bo 14 9897 CHECK NO, N° 32162 DETAILS . ROON-9-6 (BL 82371 CHK 152 jal fl LOC G2 39:5354 oe ee hs ee et eh em ee a ta ———w _ SS A tee es Oe Re gee ee ow ome 4 COFE."ER- MILK St FOOD “FQ. VAT fx 38 SERV ICE 3.00 TOTAL DUE S¢+ 16 ALS/RDBER FS HUTEL GUEST 94 45 HCC RECTEVABLE 24047 ~-)2-00679 TIN S78 & SiS 2 w Tit Mid 22 OG232 vere ClECe CLOSED 39: 06QN——-P AIO-CHARGES | NAME iT ) ROOM N | IVA mpl] Ak 4B cc. Es | ADDRESS :~— | SIGNATURE | 7} I STM ate _ | / GIUFFRE007421 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page826 of 883 11. a. Fane a.Frenaw o. tiles s. Foslyni 50100 Ins. (063) 281033-6 urns 281044 @ ROOM SERVICE ROYAL PRINCESS Curana Mar a v 4 TAUHUMIIMIUNIN 660 14 2827 WAITER NO. PERSONS | TABLE NO. | CHECK NO. a23 |N° 32160 DETAILS AMOUNTS z RUN F TSL 923/ CHE 2460 ij5" 2 rv net "2 7s syn ~ FRES!: “PUTS ) 00 < OR GR TS JUICE LEO fi) 90d Ti: To » oll: AE eH 2 SERY ICE Ze 3H TOTAL DUE 28S .a23 43 F237 PNGER TS HOTE_ i -E'S- We D2 HELO REC TEVASLE Ds LPie-006?e i [hi * ‘aid 2 fe 5044 x OY E32 | wom CHECK CLOSES 18 Cdn wae > pe eet K | ROOM NO. < c.c. NO. fs = ADDRESS : si SIGNATURE GIUFFRE007422 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page827 of 883 a ‘ 112 0, Snr a. Franny 0. ties ¥. eslyni 0100 Tns. (063) 281033-8 uring 281044 ROOM SERVICE ROYAL PRINCESS Cutang Mas 4 4 VEUIWUANIIMuiAWN 6O 14 2887 WAITER NO, PERSONS | TABLE NO. | CHECK NO. ) 44 A? N° 32171 DETAILS AMOUNTS > BOON-@ = wr a4 , Am bento sok THK Fick: ‘BOLT M2 yrs ve te ee’ - ke ’ aia iene meee: ae meee tes ere ican eats ~ on ITS ts ti ct FE, Pere thi FOOD oH df yer A. Y * AE Ph meee “ ,)r~ ‘ A SERVICE 23s «fit IUTR_ Jue 2349 .25 do 323/ UBER TS HOTEL GUESS: 3g 35 wh RECIEVABL: bsalid-J2-1075¢ “Th 540454779 7 , atid 22 geigh: > 4 -———§ CHECK SLOSED 98:526N-—— PAID—CHARGES, yf NAME: / | Ao (nivecr ROOM NO. GQ %) & oe C.C. NO. ADDRESS :— SIGNATURE GIUFFRE007423 CONFIDENTIAL

The text on this page is estimated to be only 46.34% accurate

Case 18-2868, Document 283, 08/09/2019, 2628241, Page828 of 883 AMY asa d. tiles v. esl 50100 Ins. (063) 281033-6 urns 281044 ROOM SERVICE NZIVOUNISAUNYN 6O 14 2697 CHECK NO. N@ 32172 DETAILS , ~~ “ > 4 4 tof He ifs ne Ta? 4 * oo Sa Oo tes wat -_ > res Ite a oe 2 FOSTADNIS AP 3584 Pe Ey + lt er oe: . my imi iva om eu MOOR TT . 2 IC J, “35 . a MOTE! . “6 ““™ 106 . hv, t= 3 S ~ = sen LS 2-907'92 ~ at oL77E : : a ee ; if, d¢ J2tde. : “LOSES — Sejgo4———PAID-CHARGES SIGNATURE GIUFFRE007424 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page829 of 883 A = , @ ‘if. PAN A. SwAAIY B. Os v. MOLY 50100 Ins. (053) 281093-6 wan 281044 ,, : : @ ~ , ~~—*" ROYAL PRINCESS Cxtanc Mai neweunraAnaen 60 14 2Aa7 WAITER NO. | PERSONS | TABLE NO. |_ CHECK NO. Pray) | a \N9 263581 DETAILS AMOUNTS . MS-BUF L4G WK SRST 4 LEGCT HZ IAs Tray CB... OG 3 FOGLE TOTS. 1 VAT Fe Say SERY ie 2f 9) TOTO! DLE aS . 4h res HATE, GUEST 735.40 ACC RECTEVABLE J2:f15-f2-(0755 TIN 3.194 5L77t 2 «[h SQis 22 NS32 --——{ CHECK QLOSED 18: 504N—- PAID—CHARGES NAME :- a ROOM NO. WAG KdwG VES cc. no. ADDRESS :— i SIGNATURE | J | Of \ A YY UN GIUFFRE007425 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page830 of 883 112 ®, Hiayw A.TinaW 8. 109 8. Helm! 50200 IMs. (053) 281033-6 nYiny 281044 se Oe Swimming Foot Cmanc Mar ~ - 4 VSMGUNITAMIUAUN 56 14 SBE7 PERSONS {| TABLE NO. | CHECK NO. AMOUNTS if POOL-OM, TEL 4/69 CHE as GST 2 LFOCT G2 Z2NSPH EL TT AT A RS et Ut at deat — ee i SINGHA BEER -S 140.90 = T 4 SOFT DRINKS 30 0) BEVE. TOTAL Lei 09 VAT 7% 12 2 SERVICE 16.00 TOTAL WE 2S . Se My 307 /BROWNLIE-Mi7i HOTEL GUEST 1e8 .32 ACC RECIEVABLE §2)17-02-09695 TIN 3104 51770 2 Rit 14 22 M232 ~~~~12 CHECK SLOSED 12: 44PN——-PAID—CHARGES fu ec RE c.c. NO. ADDRESS :— SIGNATURE M tw ly hue GIUFFRE007426 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page831 of 883 wn- SP AAUNDRY = Bk. No. 38 avi, 01699 — cnn amMwWuTY an ant aad ® oyu a ian a Guest fies AMG int Fae Coane GENTLEMEN me count Count LADIES : aunud 70 | jlo! [ |: _ 1 hia ee GousnsJacket | ee Mee |e a eo a eee ee Pa | alee nDATIN ia usmsuna aatavanadeay Total Amount } bg 5 Regular Service 7% Government Tax | id to be returned 10% Av3Ms | oh 1) vinselaw (ofiudiutnns 50%) ; ; | 10% Service Charge pb. 4 Express (50% Surcharge) ae veh \ io oh lew 1% Fame | g 6. > C) stlidosdoch OO um To Hold _ — sanTanitfu/TOTAL ug 2, 40 %a/Name CALE eiyétaufinuufiss Special | ructions, alas 5 i wMIELAaDHEN/Room Laundry Mark: PINK = CASHIER, YELLOW = ACCOUNT, WHITE = GUEST Jufluasianfiynufuvta/ Your Departure Date & Time GIUFFRE007427 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page832 of 883 Viwnieda Viuwa dite (uw) Milsusysasa viuewe oalus 112 O.2WAAaIU H.trAAry wevUsed a yLFOMT 3 10 161770 2 at Buslual a eee ROYAL PRINCESS 4 a 5 0 T MINI BAR LIST CaunaMar —CNO.. BEVERAGES AVAILABLE IN YOUR REFRIGERATOR bevn NAME 000... .ccceccecesessssssesestveseeescceseec cc. ROOM NO. Ee aes 4-1-4 ? PAR UNIT PRICE | CONSUMP- TOTAL STOCK TION BAHT Singha Beer (Small) [2 | inte Soda Water Coca-Cola Mineral Water ae Cot Brandy VS.O.P 20 cl. g | t No o a. _+ lw oO g aD © @ ge i it We refill your refrigerator daily and bill the consumption Girectly to your Hotel account. And drinks will be charged fully when the bottle is open. PLEASE DO NOT PAY CASH Guest's signature | ‘é cai tr vmresneemistbetecastedalacdee,.. Retilled by. ebisaeiareaN Front Office Cashier GIUFFRE007428 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page833 of 883 uivnsods UT wes duia (ney) oe e wrnlivusuroda USurew Baalvsl Ser ara ane 0 Se Lai ras 112 OP ane" B.A eatea widen ROYAL PRINCESS MINI BAR LIST ———— NO. 4 1 6 { 8 BEVERAGES AVAILABLE IN YOUR REFRIGERATOR INA UNIT PRICE | CONSUMP- TOTAL TION BAHT CONTENTS STOCK | Singha Beer (Small) Heineken Beer a —" Soda Water Coca-Cola Mineral Water Brandy V.S.0.P 20 cl. Scotch Whisky 20 cl. Thai Whisky uw So Vodka 20 cl. Chocolate Bar Potatoes Snack = all Complimenta -_ Prices are inclusive of service charge and VAT We refill your refrigerator daily and bill the consumption directly to your Hotel account. And drinks will be charged fully when the bottle is open, PLEASE DO NOT PAY CASH GIUFFRE007429 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page834 of 883 ultima UFurte dia (uy) mriisauswsets Uiuwe oclew 112 Oe NAeW 2S HRW tanutedrgoms 3 10 161770 2 Aides eidoalyal MINI BAR LIST ee NO. 4 1 8 5 4 BEVERAGES AVAILABLE IN YOUR REFRIGERATOR bet 0) CONTENTS UNIT PRICE | CONSUMP- TOTAL TION BAHT Singha Beer (Small) Heineken Beer STOCK 3 e a ae ond S o Soda Water Coca-Cola Mineral Water ow randy V.S.0.P. 20 cl. Scotch Whisky 20 cl. Vodka 20 cl. —_ yo | A so cS Chocolate Bar Potatoes Snack PL bl b i & (\ ee Prices are inclusive of service charge and VAT 0 TOTAL We refill your refrigerator daily and bill the consumption directly to your Hotel account. And drinks will be charged fully when the bottle is open. PLEASE DO NOT PAY CASH Te isaac idetanereneincensiaanelbeese ei So Front Office Cashier GIUFFRE007430 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page835 of 883 vidwsada Uiuine site Cunmy) we Marlsauswade Ve uss ealya tamevimagitom”d 3 to 161770 2 112 O.Wienaqw adoern|ary aifey eidealua ROYAL PRINCE MINI BAR LIST ee NO. 41858 BEVERAGES AVAILABLE IN YOUR REFRIGERATOR is fl — « WE I te viceessarsatcins eo. ROOM NO. ABD ome BE-¥ 7 CONTENTS UNIT PRICE | CONSUMP- TOTAL TION BAHT Singha Beer (Small) Heineken Beer 2 § = R Coca-Cola Mineral Water Brandy V.S.0.P 20 di, N © a ~~ if Chocolate Bar 2 Prices are inclusive of service charge and VAT gk tom} 12¢ We refill your refrigerator daily and bill the jon direct! And drinks will be charged fully when the oe cot oo PLEASE DO NOT PAY CASH GUOSTS SHQTMALIIE -......saarsssesannnnrsensssecserstesnneees-ssreesersssnsarrtoresteteeeesnteticsssscoose PO eich sacsiaton og asin io seb pepsi adiecan cesta Front Office Cashier GIUFFRE007431 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page836 of 883 uivnnda vues sie (ums) it sata a oalnal @ tasuseviaaifomé 3 10 s¢1770 2 11 _ ee one ROYAL PRINCESS 41943 MINI BAR LIST a Oté«WNV BEVERAGES AVAILABLE IN YOUR REFRIGERATOR [LN (\ UNIT PRICE | CONSUMP- TOTAL TION BAHT : TTT ET ET OREO EP Peers ee eR Eee EEE Pere ew eS CONTENTS PAR STOCK 2 Singha Beer (Small) Heineken Beer ead — oO —> > o 2 Soda Water Coca-Cola Mineral Water 16) Oo 2 Brandy V.S.0.P. 20 d. Scotch Whisky 20 cl. Thai Whisky Vodka 20 cl. eel Ww So Chocolate Bar Potatoes Snack is Prices are inclusive of service charge and VAT {\ AL 60 We refill your refrigerator daily and bill the consumption directly to your Hotel account, And drinks will be charged fully when the bottle is open. PLEASE DO NOT PAY CASH a i ake lea ne ee IPN ON vinnie pis acted pistincdninan aodgetbav ed vacbastivicenéeasiccec: Front Office Cashier GIUFFRE007432 CONFIDENTIAL

EXHIBIT 44 (Filed Under Seal)

The text on this page is estimated to be only 45.80% accurate

z Se x TYME) Bes WS oe oo aos Bis <i EOLA 584 Y as J Se Fie PST Case 18-2868, Document 283, 08/09/2019, 2628241, Page838 of 883

EXHIBIT 45 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page840 of 883 VEHICLES (561) 309-6415 Rear (561) 379-9390 t ws oe (561) 758-1672 Rear (561) 818-8867 Front Licence: EOSPRU —> Lic. U9D~ L& ‘9 Mercedes Benz 600 1997 Black Licence: G14KCT Mercedes Benz 600 Conv 1998 Silver ce Licence: RAS85L = Licence: WGE53R VY Crysler Mini Van 1996 White Licence: WGE52R ( wm >V Cobra Grand 1993 Green (561) 686-3707 1998 Gold ” Mrs Epstein “ 900 Southern Boulevard West Palm Beach, FL 33405 Tel: (561) 835-9374 (561) 346-7141 (561) 371-1686 (561) 308-5700 Tel: (561) 471-7600 Oil change every 3 000 miles Mercedes Benz of Palm Beach 4000 Okeechobee Boulevard West Palm Beach, FL 33409 Att: Shawn Adison Tel: (561) 689-6363 F* ‘nt tJekKK CEIe4 to REA contrat 7 Dover 4G Ve Roger Dean Chevrolet 2235 Okeechobee Boulevard West Palm Beach, FL 33409 Tel: (561) 683-8100 Nestor Auto Repairs 2600 Florida Avenue West Palm Beach, FL 33401 Tel: (561) 835-0809 Nestor Auto Repairs 2600 Florida Avenue West Palm Beach, FL 33401 Tel: (561) 835-0809 Volvo Palm Beach 5544 Okeechobee Boulevard West Palm Beach, FL 33417 Registration, insurance and yearly inspection papers to be kept in the glove compartment of each vehicle Spare keys are kept in the key box in the office Page 2296 02/11/2015 Public Records Request No.: 16-268 GIUFFRE007834

Case 18-2868, Document 283, 08/09/2019, 2628241, Page841 of 883 Muvico Parisian City Place 545 Hibiscus Street West Palm Beach, FL 33401 Tel: (561) 833-0400 GROCERY STORES a Sor of Bishop Water Co Tel: (561) 582-1367 _. 9° Egrbottled water (large and small) cw To ” e 2 Carmine Giardini's 2401 PGA Boulevard, Suite 172 |Fish, meat, gourmet foods Palm Beach Gardens, FL 33410 Tel: (561) 775-0105 C'est Si Bon 280 Sunset Avenue Gourmet foods Palm Beach, FL 33480 Tel: (561) 659-6503 Publix Super Market 265 Sunset Avenue General, cleaning, toiletries Palm Beach, FL 33480 Tel: (561) 655-4120 Wild Oats 7735 South Dixie Highway West Palm Beach, FL 33405 Tel: (561) 585-8800 Greens Pharmacy 151 North County Road Palm Beach, FL 33480 Tel: (561) 832-4443 Lewis Pharmacy 235 South County Road Palm Beach, FL 33480 561) 655-7867 02/11/2015 Page 2297 Public Records Request No.: 16-268 GIUFFRE007835

Case 18-2868, Document 283, 08/09/2019, 2628241, Page842 of 883 UTILITIES City of West Palm Beach 226 Cypress Lane Palm Springs, FL 33461 Tel: (561) 965-5770 Electricity Florida Power and Light General Mailing Facility Miami, FL 33188-0001 Tel: (561) 697-8000 Florida Gas Company 401 South Dixie Highway West Palm Beach, FL 33401 Tel: (561) 832-0872 City of West Palm Beach 226 Cypress Lane Paim Springs, FL 33461 Tel: (561) 965-5770 Trash Removal City of West Palm Beach 226 Cypress Lane Palm Springs, FL 33461 Tel: (561) 965-577 Telephone 2921 N Australian Avenue West Palm Beach, FL 33407 Tel: (561) 881-8118 Bell South Tel: (561) 780-2611 02/11/2015 Page 2298 Water shut-off for entire property is located next to the mailbox on the sidewalk. Daily (Monday -Friday) Wecy caldos\\ hors Liat: ee) Public Records Request No.: 16-268 GIUFFRE007836

Case 18-2868, Document 283, 08/09/2019, 2628241, Page843 of 883 Foster Plumbing General plumbing repairs 2800 Westgate Avenue West Palm Beack, FL 33409 Tel: (561) 686-1721 Roto Rooter Blocked drains 6600 NW 12th Avenue, Suite 213 Fort Lauderdale, FL 33309 Tel: (561) 832-1495 Hackl Pools Monday and Thursday at 10:30am 1331 Central Terrace Clean pool, filter, a Lake Worth, FL 33460 ‘ Wr dhelle Tel: (561) 588-7493 ye (KM F County Wide Tree Service First Monday in May and November Tel: (561) 371-5786 STORAGE Storage USA 5580 Okeechobee Boulevard 10 ft x 20 ft unit available West Palm Beach, FL 33417 Tel: (561) 683-9955 VEHICLES Car Detailing George ~ C1249 Cak SERV CCS S SS. g 724 Sw 49 Ay ' / i : Biya ae Boynton Beed, FA SSFZZ 2 02/11/2015 Page 2299 Public Records Request No.: 16-268 GIUFFRE007837

Case 18-2868, Document 283, 08/09/2019, 2628241, Page844 of 883 MAIL & DELIVERY SERVICES 1-800-463-3339 Account No: aaa Drop-off box is next to Palm Beach National Bank on Worth Avenue Post Office 401 South County Road West Palm Beach, FL Tel: (561) 832-0697 MAINTENANCE Cassidy Air Conditioning Monthly service contract aie Par hte 501 Fern Street First Monday of every ee ere. West Palm Beach, FL (ok\ oe Techn - 2! Tel: (561) 833-6331 io 2N Air Conditioning Cable Service ~?|Merry Rugs Tel: (561) 588-8588 Bob EA \ New SEYWCe American Awning Company 537 Pine Terrace West Palm Beach, FL 33405 Tel: (561) 832-7123 Adelphia Cable 1401 North Point Parkway West Palm Beach, FL 33407 Tel: (561) 478-8300 Wall to wall Stanley Steamers Tel: (561) 586-5700 Loose rugs Palm Beach consultants: 02/11/2015 Page 2300 Public Records Request No.- 16-268 GIUFFRE007838

Case 18-2868, Document 283, 08/09/2019, 2628241, Page845 of 883 TRAVEL Larry Visoski Dave Rodgers Larry Morrison Mr Epstein’s planes Jet Aviation (561) 233-7241 Procedure for leaving cars at the airport: Leave car at Jet Aviation landing strip Leave the keys in the car Advise Jet Aviation Tail #909JE or Tail #908JE They will tag and pull car to plane upon arrival Ms Maxwell's plane 1-888-835-9782 Contract No: Air4 .. - (7 Tail # ...TA ) te Ss Always a Beech Jet or Hawker Commercial Airlines Air France 1-800-237-2747 American 1-800-433-7300 British Airways 1-800-247-9297 Continental 1-800-525-0280 Delta 1-800-221-1212 South African Airways 1-800-722-9675 United 1-800-241-6522 US Air 1-800-428-4322 — Carles Rrale Vendy men (561) 02/11/2015 Page 2301 Public Records Request No.: 16-268 GIUFFRE007839

Case 18-2868, Document 283, 08/09/2019, 2628241, Page846 of 883 BANKING Household Banking Account |Palm Beach National Bank 125 Worth Avenue Palm Beach, FL 33480 Tel: (561) 653-5594 “2 Cole wi2k SD art wor Nun ~ Ben Lenn ~ —eonom Account No: [i Send to Eric Gany for reconciliation $1,000 Petty Cash Float BICYCLES Palm Beach Bicycle Trail Shop 223 Sunrise Avenue I: (561) 659-4583 Mongoose Crossway 450 Raleigh Aluminium 300 Mercedes Benz Cignal Sports Bike Schwinn World Huffy Santa Fe Raleigh Sport Scott Boston BOOKSTORES Bicycles Palm Beach, FL 33480 Te Newspapers Publix Super Market 265 Sunset Avenue Te Palm Beach, FL 33480 1; (561) 655-4120 Main Street News 255 Royal Poinciana Way Magazines Te Palm Beach, FL 33480 I: (561) 833-4027 CLEANING SERVICE Francis Peadon House Cleaning Services The Breakers Comedy Corner 02/11/2015 One South County Road Palm Beach, FL 33480 : (561) 655-6611 2000 South Dixie Highway West Palm Beach, FL 33401 Tel: (561) 833-1812 1100 South Ocean Boulevard Palm Beach, FL 33480 Tel: (561) 832-2600 Page 2302 Every Tuesday and Wednesday 8:00am - 4:00pm (Francis and Pastora Peadon) Renew Car park stickers every September Public Records Request No.: 16-268 GIUFFRE007840

Case 18-2868, Document 283, 08/09/2019, 2628241, Page847 of 883 -_ i ; = - 4 6 Dam Co, Spsiom fly (15 <- 3am Energy Efficient Electric Tel: (561) 655-7211 Exterminator Palm Beach Exterminating Contact is Ken First Monday of every month at 10:30am Tel: (561) 689-0808 Also use for termite tent Garden Service Alan Stopek Trace Wellington, FL 33414 Jerome Pierre Part-time help. Billed through Alan Stopek. In residence: Daily from 6.30am Not in residence: Mon - Fri from 2pm - 5pm Also maintains Mrs Epstein's property on Saturday mornings. The Doorsmith 4160 NW First Avenue Boca Raton, FL 33431 561) 391-7768 Jom Back door gate switch - above garage door controls. When open, round red light is on. Reich Metal Fabricators Tel: (561) 585-3173 ‘ John’ Front door gate switch - in telephone outlet above the kitchen telephone Dolphin Sprinkler Inc Tel: (561) 844-8082 Sarot Arrange through Alan Stopek Academy Services Landscape Spraying Tel: (561) 478-4629 Wilson Rowan Locksmiths 625 South Dixie Highway West Palm Beach, FL 33401 Locksmith 561) 655-3637 Paine | Ie GIUFFRE007841

The text on this page is estimated to be only 47.78% accurate

Cee , f _ C Nobu \ of sin roo’ pe Sen! \ ¥ Kd i V\ an 2 Nee fr Bho old Toll Ren pra OK gk hs Dory + ) \ ats pwr a poe : —= s Ku oF O ii hem a: 1 2hé he ( ae oe Weer ad ae lel) — Lowry (He ZL se bi i. ee Nediel Ome ( — 1B Rede f a Fey ( 7) . 14 Vy {303 GIUFFRE007842

Case 18-2868, Document 283, 08/09/2019, 2628241, Page849 of 883 Address / Telephone Sheet Sere hs E Mal’ # 358 El Brillo Way, Palm Beach FI, 33480 Name Address Telephone/Fax Mr. Jeffrey Epstein (NYSG LLC ) Offic Les\ > 457, Madison Avenue 4" Floor — bd New York, NY 10021. Email An (Se isc 44) Ms. Ghislaine Maxwell Email Gis Fac Accountants Eric mai! ‘EMA PANNA (Sk-Rer. & Yra\\ yeutche ’ . ew)?” e bella Klein-Accountan Email (Petty Cosh Rey. Assistants Leslie Groff (JE Sec) Email Cecelia Helan Kim Email Michele-Compes- Email Property Keith Blumberg Email Engineer c 1) | 212 Richard Barnett Computers OO Mark Lumberg 1" aSGyvice Residences of Mr. Jeffrey Epsicin 9 East 71™ Street, New York NY 10021 Mr. Jeffrey Epstein Ms. Ghislaine Maxwell Staff House Manager Jojo House Manger Lynn Staff Phone Chef Brent Tindall 02/11/2015 Page 2305 Public Records Request No.: 16-268 GIUFFRE007843

Case 18-2868, Document 283, 08/09/2019, 2628241, Page850 of 883 Palm Beach Contractors General Plumbing Customer Service representative Electrical Reel Power Inc Cates Samco Systems A IY] TFN Amy 561 585 2591 Lenny (electrician) 561 706 0827 561 719 4832 Sam (owner) Service gate switch: above garage door controls, when round light is on Front gate switch: just above the telephone outlet kitchen area Garage doors The Door Smith Inc Telephones Southern Bell (repairs) Internal Phone system ( NEC) Repair and Programming Alarm System Benham Industries Inc Locksmith Wilson & Rowan A/C Maintenance John C Cassidy Handyman Carlos ape) avid 4 on thw Landscape Alan Stopeck - Pest Control Palm Beach Exterminator Irrigation Dolphin Sprinkle Pool Heating National Pool Service Pool Maintenance Hack Pool Service Tree Trimming Country Wide Trees Carpet Cleaners Stanley Steamers Merry Rug AY Sus, . 02/11/2015 St Keith Kelly 561 780 2355 561 881 8118 Keith 854 491 4112 561 655 3637 24 hr service Kim 561 844 8082 561 478 4696 When needed 561 585 8866 Monday/ Thursday 561 588 7493 Twice, swummer/winter 561 371 5786 wall to wall 561 586 5700 area rug 561 588 8588 Page 2306 Public Records Request No.: 16-268 GIUFFRE007844

Case 18-2868, Document 283, 08/09/2019, 2628241, Page851 of 883 j. qoVv post OFF 1c £ Cable Adelphia cable Bottled Water. Bishop water company Upholsterer Frank Jennes Gas Gas Energy Inc (Joe Di Giovanni) all gas repairs) Laundry equipment May Tag Painter Sam Storage Storage USA 5580, Okeechobee Blvd Unit 6218 Grocery & General Household items General Grocery Publix 265, Sunset Ave Courmet food C’ est si bon 289, Sunset Blvd Cable TV Avion water Contact Lenny Carmines 2401 PGA Blvd Take 95 North to PGA Blvd Too Jays Gravelox/ Nova sliced salmon Green Pharmacy 151., N County Road Flowers Extra tough Flowers Hardware Home Depot Sewell Hardware 528, Clematis Street Newspapers Main Street News 255, Royal Poinciana Way ffice 401, South County Road, Car Detailing George Taxi Service/Limo Dan Tischen FedEx # 114420816 (Monday & Thursday) Recycling Every Thursday 6AM to 5PM Trash collection M-F once a day Early Morning Cars Mercedes of Palm Beach Chevrolet Auto Repairs Gray Sunoco 340 South County Nestor Auto 2600, Florida Avenue GasolincGray Sunoco Ae MUERICHO sHOTIKRS 02/11/2015 Page 2307 <Z)- E67 O2Q% ) 215°8 7 Vy ed | 561 468-8300 Ui 8479 | 1. S2E1 055/09 C 561582 1367 561 963 0505 1800 622 4729 561 683 5835 561 655 4120 561 659 6503 561 775 9233 561 655 6545 561 832 4443 561 835 8000 561 832 0783 561 832 7171 561 833 4027 561 832 0697 1800 463 3339 561 689 6393 561 683 8100 561 655 6645 561 835 0809 se) Nd - 4 $82 Public Records Request No.: 16-268 GIUFFRE007845

Case 18-2868, Document 283, 08/09/2019, 2628241, Page852 of 883 ‘ -—-—— Mater kK NTEL =k om ur Daw piesa — fe t (une A G | V OOd -plic w/ OPsTeIN Kaus tom woll. {IND YaSrxe dr > Co eV | 02/11/2015 Page 2308 Public Records Request No.: 16-268 GIUFFRE007846

Case 18-2868, Document 283, 08/09/2019, 2628241, Page853 of 883 —wywnt$ be FeLi +o yo © someting pave -n * —eliq 2:1 Pm —elia 355 em \2:3o a has © Q For your can you please coll hee. \ 10oz20Pm = JPan lve — GL ye Signed Neiman Nereus Galo” 4 33.07 farmer as - ae . be here @ (330 0m mee —n Ulialor l00fm Jeon Wwe — Four senso ME oo4+ ~ (G|elos~ Go = 6 )u i oe — TOndyAworid.com Tranns: 02/11/2015 Page 2309 Public Records Request No.: 16-268 GIUFFRE007847

EXHIBIT 46 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page855 of 883 SSA-1826 ITEMIZED STATEMENT OF EARNINGS SOCIAL SECURITY ADMINISTRATION EARNINGS RECORD INFORMATION Date: 10/25/2016 Our records show the amount of earnings reported, not the amount of Social Security taxes that were paid. Wages were first covered under Social Security in 1937. Therefore, 1937 is the first year for which earnings may be shown on our records. Employers were required to report earnings semi-annually in 1937, and on a quarterly basis for the years from 1938 through 1977. Beginning with 1978, employers are required to report earnings annually. Our records do not show the exact date of employment (month and day) because we do not need this information to figure Social Security benefits. Employers do not give us this information. Each year, there is a maximum amount of earnings that is subject to Social Security taxes and is used to compute benefits. If a person earns more than this maximum amount, the earnings statement will usually show the maximum rather than the total earnings. Maximum benefits can be found on the SSA website. http://www.ssa.gov/OACT/COLA/cbb. html Beginning in 1951, self-employed persons could also receive Social Security credit for their work. The maximum amounts of self-employment earnings that are subject to Social Security taxes and are used to compute benefits can also be found on the SSA website. http: //www.ssa.gov/OACT/COLA/cbb. html If you have any questions, you should call, write, or visit any Social Security office. If you visit or call, please bring this letter. It will help us answer questions. The toll free number to call is 1-800-772-1213 (for the deaf or hard of hearing, call our TTY number, 1-800-325-0778). GIUFFRE009176 CONFIDENTIAL

Case 18-2868, Document 283, 08/09/2019, 2628241, Page856 of 883 SSA-1826 ITEMIZED STATEMENT OF EARNINGS * FOR SSN XXX-Xx-( x ok x FROM: SOCIAL SECURITY ADMINISTRATION OFFICE OF CENTRAL OPERATIONS 6100 WABASH AVENUE BALTIMORE MARYLAND 21215 NUMBER HOLDER NAME: VIRGINIA GIUFFRE YEARS REQUESTED: 1998 THRU 2002; 2013 THRU 2015 BOIES SCHILLER AND FLEXNER 401 E LAS OLAS BLVD STE 1200 FORT LAUDERDALE FL 33301 EMPLOYER NUMBER: (a KFC USA INC % PAYROLL DEPT 5200 COMMERCE CROSSING DR LOUISVILLE KY 40229-2182 YEAR 1ST QTR 2ND OTR 3RD QTR 4TH OTR TOTAL 1999 $140.70 EMPLOYER NUMBER: came gp PUBLIX SUPER MARKE N PO BOX 32018 LAKELAND FL 33802-2018 YEAR 1ST QTR ZND QTR 3RD OTR 4TH OTR TOTAL 1999 $216.69 EMPLOYER NUMBER: ASCENSION CHILD CARE CENTER ASCENSION PEACE CHILD CARE CENTER 2701 N STATE ROAD 7 LAUD LAKES FL 33313-2731 YEAR 1ST OTR 2ND QTR 3RD QTR 4TH QTR TOTAL 1999 $216.97 PAGE 1 GIUFFRE009177 CONFIDENTIAL WV d P20 19TH SAV 928TING TX ddVLON+SZ0000ALdLO2080+ 000000000 OOTTEZ LOSES TE S98 L29699F90 109200

Case 18-2868, Document 283, 08/09/2019, 2628241, Page85/7 of 883 SSA-1826 ITEMIZED STATEMENT OF EARNINGS +++ "FOR SSN A «+ * EMPLOYER NUMBER: AVICULTURAL BREEDING & RESEARCH CENTER % ERNEST LAKS 14201 125TH AVE N WEST PALM BCH FL 33418-7945 YEAR 1ST OTR 2ND QTR 3RD QTR 4TH QTR 2000 EMPLOYER NUMBER: SOUTHEAST EMPLOYEE MANAGEMENT COMPANY 2559 PALM DEER DR LOXAHATCHEE FL 33470-2563 YEAR 1ST OTR 2ND OTR 3RD QTR ATH QTR 2000 EMPLOYER NUMBER: MAR=-A=LAGO CLUB LLC TRUMP DONALD J GEN PTR % TRUMP ORGANIZATION 1100 S OCEAN BLVD PALM BEACH FL 33480-5004 YEAR 1ST QTR 2ND OTR 3RD QTR 4TH QTR 2000 EMPLOYER NUMBER: a OASIS OUTSOURCING VI INC 2054 VISTA PKWY STE 300 WEST PALM BCH FL 33411-6742 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR 2000 EMPLOYER NUMBER: om arom NEIMAN-MARCUS GROUP LLC % NEIMAN MARCUS GROUP LTD SOLE MBR 1201 ELM ST DALLAS TX 75270-2102 YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR 2000 PAGE 2 TOTAL $99.48 TOTAL $3,212.44 TOTAL $1,866.50 TOTAL $2,037.60 TOTAL $1,440.79 GIUFFRE009178 CONFIDENTIAL

MU A A A WW A Case 18-2868, Document 283, 08/09/2019, 2628241, Page858 of 883 SSA-1826 ITEMIZED STATEMENT OF EARNINGS EMPLOYER NUMBER: (ay MANNINOS INC MANNINOS RESTAURANT 12793 B W FOREST HILL BLVD WEST PALM BEACH FL 33414-4749 YEAR 1ST OTR ZND OTR 2001 EMPLOYER NUMBER: CCI OF ROYAL PALM INC % ROBERT FURR TTEE 2255 GLADES RD STE 337-W BOCA RATON FL 33431-7379 YEAR 1ST QTR ZND OTR 2002 EMPLOYER NUMBER: (a ROADHOUSE GRILL INC ROBERT C FURR TTEE IN BANKRUPTCY 2255 GLADES RD STE 337W BOCA RATON FL 33431-7379 YEAR isT QTR ZND QTR 2002 EMPLOYER NUMBER: MARC PINKWASSER DVM PA 13860 WELLINGTON TRCE STE 31 WELLINGTON FL 33414-8541 YEAR 1ST QTR ZND OTR 2002 EMPLOYER NUMBER: GREAT OUTDOORS PREMIER RV-GOLF RESORT COMMUNITY SVC ASSOC INC 145 PLANTATION DR TITUSVILLE FL 32780-2528 YEAR 1ST QTR 2ND QTR 2014 3RD OTR 4TH QTR TOTAL $212.00 3RD QTR 4TH QTR TOTAL $403.64 3RD QTR 4TH QTR TOTAL $1,247.90 3RD QTR 4TH QTR TOTAL $1,561.75 3RD OTR 4TH OTR TOTAL $171.83 PAGE 3 GIUFFRE009179 CONFIDENTIAL e+ bhanee renee © FT ee Meee we TAILS DP RINTHNTAT F TUS ey © ter nAnnnnenn MITTAZTALCLE Teeae I zoKkocrontnaznn

EXHIBIT 47 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page8s60 of 883 Monday, November 7, 2016 Page: 1 1 Quicken Data - All Accounts QuickReport by Description 8/12/69 through 1/29/03 Date Account Num Payee Memo Category Cir 4/22/02 Courtyard Animal Hospital 1500 Virginia Roberts split R 9/6/02 Courtyard Animal Hospital 1522 VOIDvirginia Roberts R 9/6/02 Courtyard Animal Hospital 1523 Virginia Roberts split R 9/20/02 Courtyard Animal Hospital 1541 Virginia Roberts split R 6/4/02 Courtyard Animal Hospital 1555 Virginia Roberts split R Total 8/12/69 - 1/29/03 Total Inflows Total Outflows Net Total GIUFFRE009203 CONFIDENTIAL

EXHIBIT 48 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page862 of 883 wa eeen rans Forwarded message ------—-From: <ross @acuityreputation.com> Date: 2 Janmary 2015 at 20:29 Subject; Re: URGENT - this is the statement To: G Max <gmax! @ellmax.com> Cc: Philip Barden <philip.barden @devonshires.co.uk> OK G going with this, thanks Philip. Sent from my BlackBerry® wireless device From: Date: Fri, 2 Jan 2015 20:14:53 +0000 To: Ross Gow<ross@acuityreputation.com> Ce: Philip Barden<phitip. barden@devonshires.co.uk> Subject: FW: URGENT - this is the statement Jane Doe 3 Is Virginia Roberts so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschwitz is involved in having sexual relations with her, which he denies Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. ; 3 EXHIBIT 7 Ss RG(UK)_000009

EXHIBIT 49 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page864 of 883 TERMINATIONS LAST NAME FIRST NAME Box #7 Box #4 Box #4 Box #4 Box #3 Box #7 Box #4 Box #3 Box #3 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #2 Box #4 Box #2 Box #4 Box #2 Box #4 Box #4 Box #7 Box #2 Box #7 Box #7 Box #2 Box #2 Box #2 Box #2 Box #5 Box #2 Box #7 Box #2 Box #5 Box #2 Box #5 Box #5 Box #2 Box #2 Box #5 Box #2 Box #2 Box #7 Page 13 of 17 MAR-A-LAGO 0173

Case 18-2868, Document 283, 08/09/2019, 2628241, Page865 of 883 TERMINATIONS LAST NAME FIRST NAME Vaughn Velasquez Vidalis Voluck Vyskrebentsev Wahl Walker Walkowiak Wentworth Weslowski White Whitley Whitney Williams Williams Willoughby Box #2 Box #2 Box #5 Box #5 Box #7 Box #7 Box #2 Box #5 Box #7 Box #2 Box #7 Box #2 Box #2 Box #2 Box #5 Box #7 Box #7 Box #2 Box #2 Box #2 Box #2 Box #2 Box #7 Box #7 Box #2 Box #5 Box #2 Box #2 Box #2 Box #2 Box #7 Box #5 Box #2 Zervoulis Box #2 Zivkovic Box #2 Zom Box #7 Box #2 Box #1 1998 terms Box #2 1998 & 1999 terms Box #3 1999 terms Box #4 2000 terms Box #5 2000 terms Box #6 2001 terms Page 16 of 17 MAR-A-LAGO 0176

EXHIBIT 50 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page867 of 883 EXHIBIT12

Case 18-2868, Document 283, 08/09/2019, 2628241, Page868 of 883 Case 9:08-cv-80736-KAM Document 280 Entered_on FLSD Docket 01/02/2015 Page 1 of 14 Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 ve UNITED STATES JANE DOE #3 AND JANE DOE #4’s CORRECTED MOTION PURSUANT TO RULE 21 FOR JOINDER IN ACTION COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”), by and through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21 to join this action, on the condition that they not re-litigate any issues already litigated by Jane Doe #1 and Jane Doe #2 (also referred to as “the current victims’). The new victims have suffered the same violations of their rights under the Crime Victims’ Rights Act (CVRA) as the current victims. Accordingly, they desire to join in this action to vindicate their rights as well. Because the new victims will not re-litigate any issues previously litigated by the current victims (and because they are represented by the same legal counsel as the current victims), the ‘Government will not be prejudiced if the Court grants the motion. The Court may “at any time”’ add new parties to the action, Fed. R. Civ. P. 21. Accordingly, the Court should grant the motion. ! FACTUAL BACKGROUND way of pseudonym for the same reasons that Jane Doe #1 and Jane Doe #2 proceeded in this fashion. Counsel for the new victims have made their true identities known to the Government.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page869 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 2 of 14 As the Court is aware, more than six years ago, Jane Doe #1 filed the present action against the Government, alleging a violation of her rights under the CVRA, 18 U.S.C. § 3771. DEI. She alleged that Jeffrey Epstein had sexually abused her and that the United States hac entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her rights. At the first court hearing on the case, the Court allowed Jane Doe #2 to also join the action. Both Jane Doe #1 and Jane Doe #2 specifically argued that the government had failed to protect their CVRA rights (inter alia) to confer, to reasonable notice, and to be treated with fairness. In response, the Government argued that the CVRA rights did not apply to Jane Doe #1 and Jane Doe #2 because no federal charges had ever been filed against Jeffrey Epstein. concluded that the CVRA extended rights to Jane Doe #1 and Jane Doe #2 even though federal charges were never filed. DE 189. The Court explained that because the NPA barred prosecution of crimes committed against them by Epstein, they had “standing” to assert violations of the CVRA rights. Jd. The Court deferred ruling on whether the two victims would now wish to join this action. The new victims joining at this stage will not cause any delay and their joinder in this case is the most expeditious manner in which to pursue their rights. Because the background regarding their abuse is relevant to the Court’s assessment of whether to allow them to join, their circumstances are recounted here briefly. Jane Doe #3’s Circumstances

Case 18-2868, Document 283, 08/09/2019, 2628241, Page870 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 3 of 14 As with Jane Doe #1 and Jane Doe #2, Jane Doe #3 was repeatedly sexually abused by

Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 5 of 14

Case 18-2868, Document 283, 08/09/2019, 2628241, Page873 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 6 of 14 The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it of Jane Doe #3’s relationship to Epstein would have revealed the fact that she had been trafficked throughout the United States and internationally for sexual purposes. Nonetheless, the Government secretly negotiated a non-prosecution agreement with Epstein precluding any Federal prosecution in the Southern District of Florida of Epstein and his co-conspirators. As with Jane Doe #1, and Jane Doe #2, the Government concealed the non-prosecution agreement from Jane Doe #3 — all in violation of her rights under the CVRA — to avoid Jane Doe #3 from raising powerful objections to the NPA that would have shed tremendous public light on Epstein

Case 18-2868, Document 283, 08/09/2019, 2628241, Page874 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 7 of 14 and other powerful individuals and that would likely have been prevented it from being concluded in the secretive manner in which it was. Jane Doe #4’s Circumstances Ree) oes eee a ee eee eee she has CVRA claims similar to those advanced by Jane Doe #1 and Jane Doe #2, based on the following: As with the other Jane Does, Jane Doe #4 was repeatedly sexually abused by Epstein, In old child, was told by another one of Epstein’s underage minor sex abuse victims, that she could make $300 cash by giving an old man a massage on Palm Beach. An acquaintance of Jane Doe #4 (also a minor sexual abuse victim of Epstein) telephoned Epstein and scheduled Jane Doe #4 to go to Epstein’s house to give him a massage. During that call, Epstein himself got on the phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to his mansion in Palm Beach. Jane Doe #4 then went to Epstein’s mansion and was escorted upstairs to Epstein’s large bathroom by one of Epstein’s assistants. Shortly thereafter Jeffrey Epstein emerged and lay face down on the table and told Jane Doe #4 to start massaging him. Epstein asked Jane Doe #3 her age and she told him she had recently turned sixteen. Epstein subsequently committed illegal sexual acts against Jane Doe #4 on many occasions. Epstein used a means of interstate communication (i.e., a cell phone) to arrange for these sexual encounters. Epstein also frequently travelled in interstate commerce (i.e., on his personal jet) for purposes of illegally sexually abusing Jane Doe #4. 7

Case 18-2868, Document 283, 08/09/2019, 2628241, Page875 of 883 Case 9:08-cv-80736-KAM Document 280. Entered on FLSD Docket 01/02/2015 Page 8 of 14 The acts Epstein committed against Jane Doe #4, constituted numerous federal sex Investigation (FBI and U.S. Attorney’s Office for the Southern District of Florida were pursuing in 2007. So far as Jane Doe #4 is aware, the U.S. Attorney’s Office made no serious effort to locate her. Instead, after identifying approximately forty separate underage sexually abused victims, and apparently preparing a 53-page federal indictment and with full awareness of the existence of many victims like Jane Doe #4 — unidentified and not interviewed — it entered into a non-prosecution agreement barring prosecution of Epstein’s federal crimes against these victims. This is contrary to the Government’s normal approach in prosecuting federal sex offenses. It ¥ pp p g also violated Jane Doe #4’s rights under the CVRA, including the fact that she had a “reasonable” right to confer with the U.S. Attorney’s Office before they entered into an agreement with a sex offender barring prosecution of him for the crimes he committed against her. 18 U.S.C. § 3771 (a)(5). MOTION FOR JOINDER Jane Doe #3 and Jane Doe #4 now both move to join this action filed by Jane Doe #1 and Jane Doe #2, pursuant to Rule 21 of the Federal Rules of Civil Procedure. Rule 21 provides that “fo]n motion or on its own, the court may at any time, on just terms, add... a party.” Rule 21] “srants the court broad discretion to permit a change in the parties at any stage of a litigation.” Ford y. Air Line Pilots Ass'n Int’l, 268 F. Supp. 2d 271, 295 (E.D.N.Y. 2003) (internal quotation omitted). The new victims should be allowed to join the current victims in this action under Rule ais

Case 18-2868, Document 283, 08/09/2019, 2628241, Page876 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 9 of 14 the same way as it violated the rights of the other victims. The new victims’ participation in this case is important because it appears that the Government intends to raise a factual defense that somehow it did keep Jane Doe #1 and Jane Doe #2 properly informed of what was happening in the criminal prosecution. Of course, if four victims all testify consistently that they were not properly informed by the Government (as we believe they will), that provides a stronger case for a CVRA violation. In addition, Jane Doe #3 and Jane Doe #4’s participation is relevant to a defense the Court has allowed the Government to raise. The Court has previously ruled that the victims’ request for rescission of the NPA “implicates a fact-sensitive equitable defense which must be considered in the historical factual context of the entire interface between Epstein, the relevant prosecutorial authorities and the federal offense victims — including an assessment of the allegation of a deliberate conspiracy between Epstein and federal prosecutors to keep the victims in the dark on the pendency of negotiations between Epstein and federal authorities until well after the fact and presentation of the non-prosecution agreement to them as a fait accompli.” DE 189 at 12 n.6 (emphasis added). Jane Doe #3’s and Jane Doe #4’s participation in this case_will help to show what the “entire interface” was between the Government and the victims and thus to respond to the Government’s estoppel arguments as well as other defenses that it appears to be preparing to raise. See, e.g., DE 62 (52-page response from the Government to the victim’s summary judgment motion, raising numerous factually-based and other arguments against the victim’s position).

Case 18-2868, Document 283, 08/09/2019, 2628241, Page877 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 10 of 14 victims have responded by explaining haw these documents are relevant, including explaining how these documents might bear on the way in which Epstein used his powerful political and social connections to secure a favorable plea deal, as well as provide proof of the Government’s motive to deliberately fail to investigate certain aspects of the victims’ claims in an effort to maintain the secrecy of the facts and resolve the case without the victims’ knowledge. See, e.g., DE 266 at 6-10. Jane Doe #3 and Jane Doe #4’s participation will help prove the relevancy of these requests, as well as the need for those requests. One clear example is Request for Production No. 8, which seeks documents regarding Epstein’s lobbying efforts to persuade the Government to give him a more favorable plea arrangement and/or non-prosecution agreement, including efforts on his behalf by Prince Andrew and former Harvard Law Professor Alan Dershowitz. Jane Doe #1 and Jane Doe #2 have alleged these materials are needed to prove their allegations that, after Epstein signed the non-prosecution agreement, his performance was delayed while he used his significant social and political connections to lobby the Justice Department to obtain a more favorable plea deal. See, e.g,, DE 225 at 7-8 (discussing DE 48 at 16-18). Jane Doe #3 has directly person knowledge of Epstein’s connection with some of these powerful people and thus how Epstein might have used them to secure favorable treatment. Adding two new victims to this case will not delay any of the proceedings. They will simply join in motions that the current victims were going to file in any event. For example, the 10

Case 18-2868, Document 283, 08/09/2019, 2628241, Page878 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 11 of 14 anticipate filing after discovery has been completed. Nor will adding the new victims prejudice the United States. As the court is aware, this Court is still in its initial discovery stage. The Court is currently considering whether to reject the Government’s assertion of privilege over documents regarding the case. See DE 265 (victims’ reassertion of objections to the Government privilege claims). The new victims do not seek any additional discovery beyond that previously sought by the current victims.” Accordingly, the United States will not be prejudiced or burdened by adding them to this case. The CVRA does not contain any statute of limitations for filing an action to enforce rights under the statute. Accordingly, were the Court to deny this motion, the result might be that the new victims would then be forced to file a separate suit raising their claims, which would then possibly proceed on a separate litigation track. Rather than require duplicative litigation, the Court should simply grant their motion to join. Jane Doe #1 and Jane Doe #2 support the joinder motion. Counsel for the victims have discussed this motion with the Government at length in an effort to avoid any need to file a substantive pleading on the issue. Counsel for the victims asked the Government during the summer for its position on joinder. The Government, however, took the matter under advisement for months. Ultimately, after several inquiries from victims counsel, the Government indicated without explanation that it opposes this motion. Counsel for the victims has requested a meeting with the Government on this issue, which will hopefully occur in Doe #3 and Jane Doe #4 have asked the Government to provide them with the record of their statements that they provided to the FBI. These FBI 302’s should be only a few pages long. 1]

Case 18-2868, Document 283, 08/09/2019, 2628241, Page879 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 12 of 14 appropriate to delay filing this motion and accordingly file it at this time. Because the on the motion.

Case 18-2868, Document 283, 08/09/2019, 2628241, Page880 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 13 of 14 CONCLUSION Jane Doe #3 and Jane Doe #4 should be allowed to join this action, pursuant to Rule 21 that they not re-litigate any issues previously litigated by Jane Doe #1 and Jane Doe #2. A proposed order to that effect is attached to this pleading. DATED: January 2, 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mail: brad@pathtojustice.com And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah" 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu Attorneys for Jane Doe #1 and Jane Doe #2 I This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah 13

Case 18-2868, Document 283, 08/09/2019, 2628241, Page881 of 883 Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 14 of 14 CERTIFICATE OF SERVICE the Court’s CM/ECF system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 F-mail: Dexter. Lee@usdoj.gov E-mail: ann.marie.c.villafana@usdoj.gov Attorneys for the Government

EXHIBIT 51 (Filed Under Seal)

Case 18-2868, Document 283, 08/09/2019, 2628241, Page883 of 883 MW COCIAL SEC apy SECe, Le 255 GIUFFRE009209 CONFIDENTIAL

Selected docket entries for case 18—2868 Generated: 08/09/2019 10:07:40 Document Description Docket Text 08/09/2019 (284 UNSEALED SUMMARY 2 |UNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 10 of 13 , pursuant to the Court's decision dated DOCKETED July 3, 2019, DOCKETED. [2628244] [18-2868] 08/09/2019 |285 UNSEALED SUMMARY 40 JUNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 11 of 13 , pursuant to the Court's decision dated DOCKETED July 3, 2019, DOCKETED. [2628246] [18-2868] 08/09/2019 |286 UNSEALED SUMMARY 44 UNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 12 of 13 , pursuant to the Court's decision dated DOCKETED July 3, 2019, DOCKETED. [2628248] [18-2868] 08/09/2019 |287 UNSEALED SUMMARY UNSEALED SUMMARY JUDGMENT RECORD, JUDGMENT RECORD, appendix 13 of 13 , pursuant to the Court's decision dated DOCKETED July 3, 2019, DOCKETED. [2628251] [18-2868]

Case 18-2868, Document 284, 08/09/2019, 2628244, Pagel of 38 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA L. GIUFFRE, Plaintiff, V. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. Defendant’s Reply to Plaintiff’s Statement of Contested Facts and Plaintiff’s “Undisputed Facts” Pursuant to Local Civil Rule 56.1 Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN AND FOREMAN, P.C. 150 East 10 Avenue Denver, CO 80203 303.831.7364

Case 18-2868, Document 284, 08/09/2019, 2628244, Page2 of 38 Pursuant to Rule 56.1 of the Local Civil Rules of this Court, defendant Ghislaine Maxwell submits this Reply to Plaintiff’s Statement of Contested Facts and Plaintiff’s Undisputed Facts (“Response’’), Doc. 586-1. INTRODUCTION Plaintiff's Response fails under both the Federal Rules of Evidence and the Local Civil Rules of Procedure. First, Plaintiff largely failed to provide any “citation to evidence which would be admissible” to challenge Defendant’s Statement of Material Undisputed Facts and therefore Ms. Maxwell’s undisputed facts should be deemed admitted. Second, rather than set forth “additional material facts as to which it is contended that there exists a genuine issue to be tried” (Local Civil Rule 56.1(b)), Plaintiff instead set forth her own purportedly “undisputed facts.” Because Plaintiff did not cross-move for summary judgment, her supposedly “undisputed facts” are not permitted by the Rules and should be stricken. I. Ms. Maxwell’s reply in support of statement of undisputed facts. 1. Undisputed Fact 1: In early 2011 plaintiff in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. In the articles, plaintiff made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, plaintiff suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. Exs. A and B. a. Reply: Plaintiff cites no admissible evidence to contest these undisputed facts. McCawley Ex.34 (GIUFFRE368) is an email from Sharon Churcher to Plaintiff. It is Ms. Churcher’s hearsay and therefore inadmissible. In any event, it does not speak to the 1

Case 18-2868, Document 284, 08/09/2019, 2628244, Page3 of 38 contents of Plaintiff's interviews with Churcher. McCawley Decl. Ex. 31 is an FBI interview, also inadmissible hearsay, which again does not describe Plaintiff’s interviews in news articles. In the absence of contrary evidence, Undisputed Fact | should be deemed admitted. 2. Undisputed Fact 2: In the articles, plaintiff alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” Exs. A-B at 5. a. Reply: Plaintiff does not contest these facts and they therefore should be deemed admitted. 3. Undisputed Fact 3: In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.” Ex.C. a. Reply: Plaintiff “denies” that Mr. Barden “issued a statement,” but offers no admissible evidence to refute this point. Further, she acknowledges that the Statement was issued “By Devonshires Solicitors,” Mr. Barden’s law firm. 4. Undisputed Fact 4: The statement read in full: Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 2011 London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. It is unacceptable that letters sent by Ms Maxwell’s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers.

Case 18-2868, Document 284, 08/09/2019, 2628244, Page4 of 38 “‘T understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop,” said Ghislaine Maxwell. “A number of newspapers have shown a complete lack of accuracy 1n their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-25 | Email: ross @ acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: +44-203008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com Ex.C. a. Reply: Plaintiff does dispute the contents of the 2011 statement and therefore it should be deemed admitted. 5. Undisputed Fact 5: Plaintiffs gratuitous and “lurid” accusations in an unrelated action. In 2008 two alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against the United States government purporting to challenge Epstein’s plea agreement. They alleged the government violated their CVRA rights by entering into the agreement. Ex.D, at 2. a. Reply: Plaintiff “stipulates” to the facts contained in paragraph 5 and therefore they should be deemed admitted. 6. Undisputed Fact 6: Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action, claiming she, too, had her CVRA rights violated by the government. On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. Ex.D at 1, 9. a. Reply: Plaintiff “agreed” to this paragraph.

Case 18-2868, Document 284, 08/09/2019, 2628244, Paged of 38 7. Undisputed Fact 7: The issue presented in her joinder motion was narrow: whether she should be permitted to join the CVRA action as a party under Federal Rule of Civil Procedure 21, specifically, whether she was a “known victim[] of Mr. Epstein and the Government owed them CVRA duties.” Yet, “the bulk of the [motion] consists of copious factual details that [plaintiff] and [her co-movant] ‘would prove . . . if allowed to join.’” Ms. Giuffre gratuitously included provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual trafficking. Ex.E, at 5. a. Reply: Plaintiff does not dispute that Judge Marra made the findings detailed in Undisputed Fact 7. Further, she admits that the Government refused to stipulate that she “had been sexually abused by Jeffrey Epstein and his co-conspirators (including coconspirator Alan Dershowitz), which would make her a ‘victim’ of a broad sex trafficking conspiracy.” Although she now submits there were other reasons for inclusion of such lurid details, those reasons were rejected by Judge Marra. As she does not offer any admissible evidence to contradict the findings made by Judge Marra, this “fact,” specifically Judge Marra’s findings, should be deemed admitted. In any event, we request under Fed. R. Evid. 201(c)(2) that the Court take judicial notice of the contents of Judge Marra’s ruling and order. 8. Undisputed Fact 8: At the time they filed the motion, Ms. Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA action. While they deliberately filed the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. Ex.D, at 1 & n.1.

Case 18-2868, Document 284, 08/09/2019, 2628244, Page6 of 38 a. Reply: Plaintiff offers no admissible evidence to refute these facts and they therefore should be deemed admitted. Specifically, she does not offer any evidence to dispute that she knew the media had been following Epstein and the CVRA action, nor does she dispute that her attorneys made no attempt to file the motion under seal, rather filing it publicly. The facts are thus admitted. 9. Undisputed Fact 9: As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several individuals, and she offers details about the type of sex acts performed and where they took place.” The court ruled that “these lurid details are unnecessary’: “The factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent . . ., especially considering that these details involve non-parties who are not related to the respondent Government.” Accordingly, “[t|hese unnecessary details shall be stricken.” Jd. The court then struck all Ms. Giuffre’s factual allegations relating to her alleged sexual activities and her allegations of misconduct by nonparties. The court said the striking of the “lurid details” was a sanction for Ms. Giuffre’s improper inclusion of them in the motion. Ex.E at 5-7. a. Reply: Plaintiff offers no admissible evidence to refute these facts and they therefore should be deemed admitted. See Reply to Undisputed Fact 7, supra. In any event, we request under Fed. R. Evid. 201(c)(2) that the Court take judicial notice of the contents of Judge Marra’s ruling and order. 10. Undisputed Fact 10: The district court found not only that the “lurid details” were unnecessary but also that the entire joinder motion was “entirely unnecessary.” Ms. Giuffre and her lawyers knew the motion with all its “lurid details” was unnecessary because the motion

Case 18-2868, Document 284, 08/09/2019, 2628244, Page/7 of 38 itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. The court denied plaintiffs joinder motion. /d. at 7-10. a. Reply: Plaintiff offers no admissible evidence to refute these facts and they therefore should be deemed admitted. See Reply to Undisputed Fact 7, supra. 11. Undisputed Fact 11: One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion, Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein: Ms. Maxwell “approached” plaintiff in 1999 when plaintiff was “fifteen years old” to recruit her into the scheme. Ms. Maxwell was “one of the main women” Epstein used to “procure underaged girls for sexual activities.” Ms. Maxwell was a “primary co-conspirator’ with Epstein in his scheme. She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.” At the mansion, when plaintiff began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.” Epstein “with the assistance of’ Ms. Maxwell “converted [plaintiff] into...a ‘sex Slave.’” Jd. Plaintiff was a “sex slave” from “about 1999 through 2002.” Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.” Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.” Ms. Maxwell “participat[ed] in the sexual abuse of [plaintiff] and others.” Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [plaintiff].” Jd. She shared the photos with Epstein.

Case 18-2868, Document 284, 08/09/2019, 2628244, Pages of 38 e As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect|ed]” Epstein with “powerful individuals” so that Epstein could traffick plaintiff to these persons. e Plaintiff was “forced to have sexual relations” with Prince Andrew in “TMs. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” plaintiff’ s sex with Prince Andrew “by acting as a ‘madame’ for Epstein.” e Ms. Maxwell “assist[ed] in internationally trafficking” plaintiff and “numerous other young girls for sexual purposes.” e Plaintiff was “forced” to watch Epstein, Ms. Maxwell and others “engage in illegal sexual acts with dozens of underage girls.” Id. at 3-6. a. Reply: Plaintiff offers no admissible evidence to refute the facts actually stated in the paragraph, 1.e., that the “lurid” details (as coined by Judge Marra) were included in her CVRA Joinder Motion. Plaintiff claims to offer “admissible evidence” to “corroborate the statements [she] made in the joinder motion.” Setting aside for the moment that most of the cited documents are inadmissible hearsay, as addressed later, such evidence should be disregarded because none of the offered documents speak to fact that these “lurid” details were actually included in the joinder motion, as a simple reading of Ex.D reveals. Because Plaintiff does not refute that point, the fact that the details were in the Joinder Motion should be deemed admitted. In any event, we request under Fed. R. Evid. 201(c)(2) that the Court take judicial notice of the contents of plaintiff's CVRA joinder motion. 12. Undisputed Fact 12: In the joinder motion, plaintiff also alleged she was “forced” to have sex with Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and “many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.” Id. at 4-6.

Case 18-2868, Document 284, 08/09/2019, 2628244, Page9 of 38 a. Reply: Again, Plaintiff offers no evidence that these “lurid details” were included in the Joinder Motion, as indeed they were, and thus the fact that they were should be deemed admitted. 13. Undisputed Fact 13: Plaintiff said after serving for four years as a “sex slave,” she “managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.” Id.at 3 a. Reply: Plaintiff does not dispute that she made this statement in her joinder motion and it is admitted. 14. Undisputed Fact 14: Plaintiff suggested the government was part of Epstein’s “conspiracy” when it “secretly” negotiated a non-prosecution agreement with Eptstein precluding federal prosecution of Epstein and his “co-conspirators.” The government’s secrecy, plaintiff alleged, was motivated by its fear that plaintiff would raise “powerful objections” to the agreement that would have “shed tremendous public light on Epstein and other powerful individuals. [d. at 6-7. a. Reply: Plaintiff does not contest the quoted contents of the joinder motion, but rather offers argument regarding Plaintiff's purported “belief.” Plaintiff did not submit an affidavit attesting to such “belief” and therefore no admissible evidence was cited or offered. The facts should therefore be deemed admitted. 15. Undisputed Fact 15: Notably, the other “Jane Doe” who joined plaintiff's motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of plaintiffs allegations. Jd. at 7-8. a. Reply: Plaintiff states the facts are “untrue” but offers no admissible evidence to support that statement. She has no affidavit or other statement from “the other ‘Jane

Case 18-2868, Document 284, 08/09/2019, 2628244, Page10 of 38 Doe’ (who was represented by Plaintiffs counsel, and therefore had the ability to furnish such an affidavit). Indeed, Plaintiff acknowledges that the “other Jane Doe” “does not know Ms. Giuffre.” These facts must be deemed admitted. x, who is NOT the other Jane Doe, is irrelevant to the undisputed fact asserted. She also offers no corroboration of the ‘same pattern of abuse,’ and in fact does not “remember” any such facts, as already briefed. See Doc. 567 at 12-14. 16. Undisputed Fact 16: Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, plaintiff told Ms. Churcher of virtually none of the details she described in the joinder motion. Exs. A-B. a. Reply: Plaintiff's protestation aside, the Churcher articles (attached to Ms. Churcher’s sworn affidavit filed in this case at Doc. 216 and 216-1 through 216-8) fail to include the vast majority of details included in Plaintiff's CVRA joinder motion, as any side-by-side comparison will reveal. Plaintiffs simple facile response 1s that she “did reveal details in 2011 consistent with those in the joinder motion.” She offers no admissible evidence of these details she “revealed” to Ms. Churcher, instead citing to a heavily redacted interview she purportedly gave to the FBI, not Ms. Churcher. The purported FBI report is itself hearsay, not to mention, redacted and prepared years after any supposed interview of Plaintiff. McCawley Decl. Ex.31. Because Plaintiff offers no admissible evidence to contradict the discrepancies between the Churcher articles and the joinder motion, these facts should be deemed admitted. 17. Undisputed Fact 17: Ms. Maxwell’s response to plaintiff’s “lurid” accusations: the January 2015 statement. As plaintiff and her lawyers expected, before District Judge Marra in the CVRA action could strike the “lurid details” of plaintiff's allegations in the joinder

Case 18-2868, Document 284, 08/09/2019, 2628244, Page11 of 38 motion, members of the media obtained copies of the motion. Ex.G at 31:2-36:4 & Depo. Exs. 3-4, a. Reply: Plaintiff cites no contrary evidence and therefore the facts should be deemed admitted. 18. Undisputed Fact 18: At Mr. Barden’s direction, on January 2, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing “a quotable statement on behalf of Ms Maxwell.” Ex.F; Ex.G, at 33:8-23. The email was sent to more than 6 and probably less than 30 media representatives. See Ex.G, at 33:8-34:3. It was not sent to nonmedia representatives. See id. at 31:2-35:21. a. Reply: Plaintiff disputes as “blatant falsehood,” without admissible evidence, that it was Mr. Barden who directed that the January 2 email be sent to media organizations. She then goes on to quote the very section of Mr. Gow’s deposition in which he surmises (but does not know, indicated by his statement it was his “understanding”’) that 1t was something that had been sent to Maxwell by Barden. Indeed, Mr. Barden clears up this confusion in his Declaration, in which he unequivocally swore, 10. In liaison with Mr. Gow and my client, on January 2, 2015, | prepared a further statement denying the allegations, and | instructed Mr. Gow to transmit it via email to members of the Bntish media who had made inquiry about plaintiff's allegations about Ms, Maxwell. Attached as Exhibit Al is an email containing a true and correct copy of this statement. The statement was issued on my authority. Although it is possible others suggested or contributed content, | prepared the vast majority of the statement and ultimately approved and adopted all of the statement as my work. 10

Case 18-2868, Document 284, 08/09/2019, 2628244, Page12 of 38 Ex.K { 10. Mr. Gow’s surmise as to how the statement was “forwarded to him” and by whom does not controvert the sworn testimony of Mr. Barden himself. Again, without admissible evidence to the contrary, the facts must be deemed admitted. With regard to the number of media representatives to whom he sent the email, Mr. Gow testified it was between 6 and 30. Ex.G at 33-34. His further testimony, offered by Plaintiff, that he spoke to “over 30 journalists” does not contradict that statement. Nowhere does Plaintiff offer testimony that he read the statement to over 30 journalists. Instead, Mr. Gow acknowledged it was “very possible” that he had “ever read[] the statement to press or media over the phone,” not that he read it to “over 30 journalists.” Plaintiff's selective cutting and pasting undercuts her so called evidence that the facts in Paragraph 18 are “false,” and thus they ought be deemed admissible. 19. Undisputed Fact 19: Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. These representatives were selected based on their request—after the joinder motion was filed—for a response from Ms. Maxwell to plaintiff's allegations in the motion. See, e.g., Ex.G, at 30:23-35:21 & Depo.Ex.3. a. Reply: While Plaintiff decries the second sentence as “false,” her cited evidence contradicts her conclusion. Mr. Gow testified that “any time there was an incoming query it was either dealt with on the telephone by referring them back to the two statements...or someone would email them the statement. So no one was left unanswered.” McCawley Decl., Ex.6 at 67. As his testimony makes clear, Mr. Gow sent 1]

Case 18-2868, Document 284, 08/09/2019, 2628244, Page13 of 38 the statement to those journalists who made inquiry; he did not sent it to anyone who did not. Based on the admissible evidence, this fact remains undisputed. 20. Undisputed Fact 20: The email to the media members read: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. Ex.F. a. Reply: Plaintiff does not dispute the contents of the email and therefore it should be deemed admitted. 21. Undisputed Fact 21: Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional press release solely to disseminate information to the media. So he intentionally did not pass it through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation. Ex.K ff 10,15. 12

Case 18-2868, Document 284, 08/09/2019, 2628244, Page14 of 38 a. Reply: Plaintiff makes two responses. As to the first sentence, she asserts without evidentiary support that “the Court should not consider” the Barden Declaration. This argument is frivolous for the reasons given on pages 8, 11-12, 18-19 of the Reply Brief in Support of Motion for Summary Judgment. It 1s a Declaration provided by an attorney with knowledge of the facts, Mr. Barden, disclosed by Defendant in her Rule 26 witnesses, whom Plaintiff chose not to depose. As to the second sentence, Plaintiff offers two pieces of evidence which she argues dispute the facts in question; they do not. That Mr. Gow forwarded the statement, prepared by Mr. Barden, to the media 1s not disputed. Rather, as Mr. Barden asserted in his declaration, and Plaintiff failed to cite contradictory evidence, he was the one who prepared the vast majority of the statement and instructed Mr. Gow to transmit it via email to members of the British media. Ex.K {J 10. He likewise avers that he “did not intend the January 2015 statement as a traditional press release solely to disseminate information to the media [and] this is why I intentionally did not request that Mr. Gow or any other public relations specialist prepare or participate in preparing the statement.” Jd. at J 15. Plaintiff fails to contradict Mr. Barden’s sworn Statement. 22. Undisputed Fact 22: The January 2015 statement served two purposes. First, Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff's false allegations. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject plaintiff's allegations to inquiry and scrutiny. For example, he noted in the statement that plaintiff's allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” Jd. J 11. 13

Case 18-2868, Document 284, 08/09/2019, 2628244, Page15 of 38 a. Reply: This paragraph, eliciting Mr. Barden’s intent, is uncontroverted by Plaintiff. She fails to cite any contradictory admissible evidence, instead making legal arguments. Her arguments are not admissible evidence (e.g., “it is her statement and she directed that it be sent to the media and public,” lacks any citation to record evidence). Plaintiff's list of evidence she contends “corroborates” Plaintiffs claims should be ignored as they do not pertain to Mr. Barden’s purposes in drafting the January 2 statement. 23. Undisputed Fact 23: Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish plaintiffs allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that plaintiff's allegations were “defamatory.” In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff’ s obviously false allegations and the legal indefensibility of their own conduct. /d. { 17. a. Reply: Again, Plaintiff “disputes” Mr. Barden’s intent without citation to record evidence. Plaintiff claims that Barden did not “note” anything in the statement, but the statement itself contains the phrase: “Ms. Roberts claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory. ”’ Plaintiff's unsupported arguments should be ignored and these facts pertaining to Mr. Barden’s intent deemed admitted. 24. Undisputed Fact 24: Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (emphasis supplied). The statement was intended to be a single, one14

Case 18-2868, Document 284, 08/09/2019, 2628244, Page16 of 38 time-only, comprehensive response—quoted in full—to plaintiff's December 30, 2014, allegations that would give the media Ms. Maxwell’s response. /d. {| 18. The purpose of the prefatory statement was to inform the media-recipients of this intent. /d. a. Reply: Plaintiff again “disputes” any statement related to Mr. Barden’s purpose or intent, but offers no evidence contradicting his purpose or intent. She simply points out that Ms. Maxwell retained Mr. Gow in early 2015, and that he works for a public relations firm, which is non-responsive to the fact at issue, 1.e., Mr. Barden’s intent with respect to language included in the statement. No one has contested that it was Mr. Gow who actually forwarded the statement to select members of the media who had requested a response. The fact set forth should be deemed admitted. 25. Undisputed Fact 25: Plaintiffs activities to bring light to the rights of victims of sexual abuse. Plaintiff has engaged in numerous activities to bring attention to herself, to the prosecution and punishment of wealthy individuals such as Epstein, and to her claimed interest of bringing light to the nghts of victims of sexual abuse. a. Reply: Plaintiff offers no evidence to dispute the facts cited and so they should be deemed admitted. 26. Undisputed Fact 26: Plaintiff created an organization, Victims Refuse Silence, Inc., a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. Doc. 1 (Complaint), {QJ 24-25. a. Reply: Plaintiff does not dispute this statement. 27. Undisputed Fact 27: The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by 15

Case 18-2868, Document 284, 08/09/2019, 2628244, Page17 of 38 victims of sexual abuse.” Toward this end, plaintiff has “dedicated her professional life to helping victims of sex trafficking.” Id. a. Reply: Plaintiff “agrees.” 28. Undisputed Fact 28: Plaintiff repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. This Reply Statement at {{] 51-54 (citing inter alia Doc. 216 J{ 2-11 and referenced exhibits, Doc. 261-1 to 216-8; Exs. N, KK, LL, MM). a. Reply: Plaintiff “denies” this contention, points to an email from Sharon Churcher seeking to interview her, and asserts that it was the media that sought her out. The weight of evidence, cited by Defendant at paragraphs 51-54, in addition to Plaintiffs own documents, belie this assertion. She through her attorneys sought out a videotaped interview with ABC News, she sent her “book manuscript” to publishers and literary agents, and expressed anticipation and frustration that her “exclusive contract” with The Mail prevented her for a period of time from marketing her book. See, e.g., EXHIBIT QQ at GIUFFRE003959. Te: sharon churchershaon.churchangimailonsunday.co.uk] From Virginia Cautire Sent: Pri 52072079 2:20:09 AM importa nce - Norma Subject: How ya doing?? Recewed: Fri §20V2011 2:20009 AM Hi Banddy, I hope you are stopping to smell the daffodils once in a while and having a good day!! Tam 50 excited today because | ca go Sign with an agent as my contract is finished with "Mail On Sunday"... YEAH!! Sandra and I have been working really hard to get me ready for my trip to the U.S in a few weeks and I was wondering if | could use your advice again. She has got an INTL agent who is interested in speaking with me and I don't want to say “Yes* to the first bite because I'm not su what to look for in an agent. What could you recommend that [ do? T will send Jarred and [rene (your recommended agen a copy of the synopsis and sample chapters but how do | choose the right one for "The Story"? Do you know anyone else that might be interested in this as well? Ef so, i am keen on speaking with anyone who might be. 1am sooooeooo excited about this and will keep you updated with the progressing events. When I am in New York we have to meet up for some city shopping and take the kids to Central Park to see the Zoo, given there will be no masturbating kangaroo’s for you to make friends with, but who know's? | am looking forward to showing Robbie around and he's got some family out there well we have to catch up with. Such busy times, but I'm loving it!! Anyways I hope your taking care and catch me up on : your fun times!! ‘Take care, Jenna 16

Case 18-2868, Document 284, 08/09/2019, 2628244, Page18 of 38 Plaintiff has disputed none of these activities she freely engaged in for years, and thus these facts should be deemed admitted. 29. Undisputed Fact 29: On December 30, 2014, plaintiff publicly filed an “entirely unnecessary” joinder motion laden with “unnecessary,” “lurid details” about being “sexually abused” as a “minor victim[]” by wealthy and famous men and being “trafficked” all around the world as a “sex slave.” Ex.J | 24; Ex.K {J 2-3. a. Reply: Plaintiff argues that her “lurid details” were necessary legally. Judge Marra, however, has already held that they were not and her legal arguments, unsupported by any actual evidence in this case, cannot serve to controvert his findings as quoted. 30. Undisputed Fact 30: The plaintiffs alleged purpose 1n filing the joinder motion was to “vindicate” her rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution agreement” with Epstein, “shed tremendous public light’ on Epstein and “other powerful individuals” that would undermine the agreement, and support the CVRA plaintiffs’ request for documents that would show how Epstein “used his powerful political and social connections to secure a favorable plea deal” and the government’s “motive” to aid Epstein and his “co-conspirators.” Ex.D, at 1, 6-7, 10 (emphasis supplied). a. Reply: Plaintiff fails to offer any evidence to controvert the contents of her CVRA Joinder Motion and thus, the fact should be deemed admitted. 31. Undisputed Fact 31: Plaintiff has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s alleged “sex scheme.” Ex.KK. 17

Case 18-2868, Document 284, 08/09/2019, 2628244, Page19 of 38 a. Reply: Plaintiff directs the Court to her response to paragraph 52 and suggests the factual statement is misleading. She, however, offers no contradictory admissible evidence and thus the fact should be deemed admitted. 32. Undisputed Fact 32: Republication alleged by plaintiff. Plaintiff was required by Interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were ““oublished globally, including within the Southern District of New York,’” as plaintiff alleged in Paragraph 9 of Count I of her complaint. In response, plaintiff identified the January 2015 statement and nine instances in which various news media published portions of the January 2015 statement in news articles or broadcast stories. Ex.H, at 7-8; Ex.I, at 4. a. Reply: Her argument aside, Plaintiff offers no admissible evidence to controvert the interrogatory request and her response, which was limited to “nine instances” in which the press published “portions of the January 2015 statement.” For example, Plaintiff does not point to a single news story that published the entirety of the January 2015 statement. In the absence of contrary evidence, the fact should be deemed admitted. 33. Undisputed Fact 33: In none of the nine instances was there any publication of the entire January 2015 statement. Ex.H, at 7-8; Ex.I, at 4. a. Reply: Plaintiff does not and cannot point to any of the nine publications she disclosed, or any other publication, that published the entire January 2015 statement, and this fact thus must be deemed admitted. 34. Undisputed Fact 34: Ms. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in plaintiff's response to 18

Case 18-2868, Document 284, 08/09/2019, 2628244, Page20 of 38 Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015 statement. Ex.J 24; Ex.K JJ 2-3. a. Reply: Plaintiffs proffered evidence, testimony from Mr. Gow, fails to support her argument and fails to controvert the Barden Declaration as cited by the defendant. Nothing in the testimony establishes, as Plaintiff argues, that “Defendant hired Gow because his position allowed him to influence the press to publish her defamatory statement.” The testimony is irrelevant to the factual point. The Gow testimony at most relates to why Ms. Maxwell engaged Mr. Gow. It does not bear on the factual point, 1.e., that Ms. Maxwell, Mr. Gow or Mr. Barden did not exercise any control or authority over the media in the media’s republication of portions of the statement. On this point plaintiff has failed to introduce any contrary evidence. Accordingly, the fact should be deemed admitted. 35. Undisputed Fact 35: Plaintiff’s defamation action against Ms. Maxwell. Eight years after Epstein’s guilty plea, plaintiff brought this action, repeating many of the allegations she made in her CVRA joinder motion. Doc. 1, { 9. a. Reply: Plaintiff “agrees.” 36. Undisputed Fact 36: The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (b) That the allegations have been “shown to be untrue.” (c) That Giuffre’s “claims are obvious lies.” Doc. 1 J 30 (boldface and underscoring omitted). (a) Reply: Plaintiff “agreed.” 19

Case 18-2868, Document 284, 08/09/2019, 2628244, Page21 of 38 37. Undisputed Fact 37: Plaintiff lived independently from her parents with her fiancé long before meeting Epstein or Ms. Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999, plaintiff moved in with the family of a fellow patient. Ex.L at 7-8, 12-14. There she met, and became engaged to, her friend’s brother, James Michael Austrich. Id. and at 19. She and Austrich thereafter rented an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs in that area. /d. at 11, 13-17. Later, they stayed briefly with plaintiff's parents in the Palm Beach/ Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. /d. at 17, 19, 25-27. Although plaintiff agreed to marry Austrich, she never had any intention of doing so. Ex.N at 127-128. a. Reply: Plaintiff offers argument, without an affidavit or any other contradictory evidence, regarding whether Plaintiff “voluntarily live[d] independently” or whether a “reasonable person” could assert she was “engaged.” Mr. Austrich and Plaintiff agreed that they were engaged and testified accordingly, as cited. In the absence of admissible evidence to the contrary, the facts as described by her fiancé in his deposition should be deemed admitted. 38. Undisputed Fact 38: Plaintiff re-enrolled in high school from June 21, 2000 until March 7, 2002. After finishing the gin grade school year at Forest Hills High School on June 9, 1999, plaintiff re-enrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on August 14, 2001. Ex.O. On September 20, 2001, Plaintiff then enrolled at Royal Palm Beach High School. Jd. A few weeks later, on October 12, 2001, she matriculated at Survivors Charter School. Jd. Survivor’s Charter School was an alternative school designed to assist students who had been unsuccessful at more traditional schools. Ex.P at 23-24. Plaintiff 20

Case 18-2868, Document 284, 08/09/2019, 2628244, Page22 of 38 remained enrolled at Survivor’s Charter School until March 7, 2002. Ex.O. She was present 56 days and absent 13 days during her time there. /d. Plaintiff never received her high school diploma or GED. Ex.Q at 475, 483. Plaintiff and Figueroa went “back to school” together at Survivor’s Charter School. Ex.P at 23-27. The school day there lasted from morning until early afternoon. Jd. at 23-27, 144-146. a. Reply: Plaintiff argues, again without evidentiary support, that the “codes” on the school records indicate “semester start and end dates” rather than dates Plaintiff was in school. Her mis-reading of the records is apparent from their face. One column is labelled “Entry date,” and the next “Withdrawal Date.” Neither say “semester start date” or “semester end” date. Moreover, the “codes” simply prove the point: Plaintiff “entered” school (codes EO! and EA1) on the designated “entry date” and withdrew (either prior to completion, to enter another training program, or who “will continue in the class/program the next term or school year’) on the dates designated “withdrawal.” The school records display entry and withdrawal dates for Wellington High School Adult Program, from June 21, 2000 — August 15, 2000, from August 16, 2000 — August 13, 2001, and from August 14, 2001- September 20, 2001 and then an entry, that same day, September 20, 2001 at Survivor’s Charter School. Plaintiff would have one believe that the records show a school on Plaintiff's official transcript that she never went to, Wellington High School Adult Program, that indicates she withdrew the very day she concededly entered Survivor’s Charter School. Her intentional misreading of the record is yet another attempt to obfuscate Plaintiff's lack of memory regarding where and when she went to school, just like she failed to remember 8 jobs she held in 2000 whereas she claimed to have had one. The test 1s admissible evidence to the contrary, and Plaintiff 21

Case 18-2868, Document 284, 08/09/2019, 2628244, Page23 of 38 offers none. The flight logs (which show trips in early 2001) do not contradict the evidence because they are during the period of time she was enrolled in “Adult High School,” a place where night classes were taught and where one might circumstantially infer, careful attendance records were not kept. 39. Undisputed Fact 39: During the year 2000, plaintiff worked at numerous jobs. In 2000, while living with her fiancé, plaintiff held five different jobs: at Aviculture Breeding and Research Center, Southeast Employee Management Company, The Club at Mar-a-Lago, Oasis Outsourcing, and Neiman Marcus. Ex.R. Her taxable earnings that year totaled nearly $9,000. Jd. Plaintiff cannot now recall either the Southeast Employee Management Company or the Oasis Outsourcing jobs. Ex.Q at 470-471. a. Reply: Plaintiff does not dispute the facts as presented, merely argues regarding their significance. The Social Security Administration records detail the five jobs at which she worked in 2000; the month and day of the jobs are irrelevant for purposes of this recitation of facts. Likewise, Plaintiff does not dispute the taxable earnings she made that year, or that she does not “remember” the jobs associated with Southeast Employee Management Company or Oasis Outsourcing (whether they were payroll or not), where she made $3,212 and $2,037 that year. She also “forgot” about her job at Neiman Marcus, where she made $1,440 in 2000, until she was confronted with the SSA records. McCawley Dec. Ex.5 at 53, 470. 40. Undisputed Fact 40: Plaintiff's employment at the Mar-a-Lago spa began in fall 2000. Plaintiffs father, Sky Roberts, was hired as a maintenance worker at the The Mar-aLago Club in Palm Beach, Florida, beginning on April 11, 2000. Ex.S. Mr. Roberts worked there year-round for approximately 3 years. /d.; Ex.T at 72-73. After working there for a period 22

Case 18-2868, Document 284, 08/09/2019, 2628244, Page24 of 38 of time, Mr. Roberts became acquainted with the head of the spa area and recommended plaintiff for a job there. Jd. at 72. Mar-a-Lago closes every Mother’s Day and reopens on November 1. Ex.U at Mar-a-Lago0212. Most of employees Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club is open, 1.e., between November | and Mother’s Day. Ex.T at 72-73; Ex.U at Mar-a-Lago0212; Ex.V. Plaintiff was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17. a. Reply: Plaintiffs response is misleading. First, she does not dispute that Mr. Roberts, her father began working at Mar-a-Lago in April 2000, nor that he worked there for some time, became acquainted with the head of the spa area and recommended his daughter for a job. Second, Plaintiff contends that “job postings and job descriptions” “from 2002 and later are irrelevant.” There are no such “job postings” cited. Rather, the job posting cited was from October 2000, the same time that Plaintiff was hired. Compare Ex.V (posting for “Saturday October 14 and Sunday October 15’) with calendar for year 2000, showing Saturday and Sundays in October corresponding to those dates. Finally, Plaintiff points to her own “recollection” as contrary proof. Her “recollection” about when she worked at Mar-a-Lago has shifted dramatically over time. First, she claimed it was 1998. See Jane Doe 102 complaint. Then, it was 1999. See Doc. 1, Complaint in this matter. Now, in this response she has changed her answer to 2000. Her vague recollections about what year have been off base, no credit should be given to her newfound recollection of which month she worked there. In any event, she presents no admissible credible evidence to contradict Mar-a-Lago’s own records. Ex.U 23

Case 18-2868, Document 284, 08/09/2019, 2628244, Page25 of 38 at Mar-a-Lago0212 (spa not open from Mother’s Day until November 1). Even Plaintiff's father, a longtime employee of Mar-a-lago admitted that the place “closed down” in the summer. Ex.T at 72-73. Plaintiff simply is not credible in her testimony that she recalls it being a “summer job,” and the fact that she did not work at the spa until at least November 2000 at the age of 17 should be deemed admitted. 41. Undisputed Fact 41: Plaintiff represented herself as a masseuse for Jeffrey Epstein. While working at the Mar-a-Lago spa and reading a library book about massage, plaintiff met Ms. Maxwell. Plaintiff thereafter told her father that she got a job working for Jeffrey Epstein as a masseuse. Ex.T at 79. Plaintiff's father took her to Epstein’s house on one occasion around that time, and Epstein came outside and introduced himself to Mr. Roberts. /d. at 82-83. Plaintiff commenced employment as a traveling masseuse for Mr. Epstein. Plaintiff was excited about her job as a masseuse, about traveling with him and about meeting famous people. Ex.L at 56; Ex.P at 126. Plaintiff represented that she was employed as a masseuse beginning in January 2001. Ex.M; Ex.N. Plaintiff never mentioned Ms. Maxwell to her thenfiancé, Austrich. Ex.L at 74. Plaintiff’s father never met Ms. Maxwell. Ex.T at 85. a. Reply: Plaintiff does not actually refute any of the facts set forth above, but rather spends her time discussing different facts. Plaintiffs father testified to what she told him, that she “was going to learn massage therapy.” Ex.T at 79. She does not contest her father’s testimony that Mr. Epstein came out of the house and greeted her father and that her father never met Ms. Maxwell. See Reply to Undisputed Fact 41. Whether someone can receive a “massage license” under Florida law without a high school equivalency diploma is of no moment. Plaintiff does not dispute she represented 24

Case 18-2868, Document 284, 08/09/2019, 2628244, Page26 of 38 herself as a masseuse to others, in her own handwriting, beginning in January 2001. Exs. M and N. These facts should be deemed admitted. 42. Undisputed Fact 42: Plaintiff resumed her relationship with convicted felon Anthony Figueroa. In spring 2001, while living with Austrich, plaintiff lied to and cheated on him with her high school boyfriend, Anthony Figueroa. Ex.L at 68, 72. Plaintiff and Austrich thereafter broke up, and Figueroa moved into the Bent Oak apartment with plaintiff. Ex.L at 20; Ex.P at 28. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa in Plaintiff's presence punched Austrich 1n the face. Ex.X; Ex.L at 3845. Figueroa and plaintiff fled the scene before police arrived. Ex.X. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance. Ex.Y. a. Reply: Plaintiff argues relevance regarding these facts, but contests none of them. They should be deemed admitted. Plaintiffs lies, cheating, and association with a convicted felon and known drug abuser all are relevant in this defamation case concerning her reputation, purported damage to such reputation, and whether she was a known liar, as the January 2015 statement contends. 43. Undisputed Fact 43: Plaintiff freely and voluntarily contacted the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex Slave.” In August 2001 at age 17, while living in the same apartment, plaintiff and Figueroa hosted a party with a number of guests. Ex.Z. During the party, according to plaintiff, someone entered plaintiffs room and stole $500 from her shirt pocket. Jd. Plaintiff contacted the police. She met and spoke with police officers regarding the incident and filed a report. She did not disclose to the officer that she was a “sex slave.” A second time, in June 2002, plaintiff contacted the police to report that her former landlord had left her belongings by the roadside and 25

Case 18-2868, Document 284, 08/09/2019, 2628244, Page27 of 38 had lit her mattress on fire. Ex.AA. Again, plaintiff met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a “sex slave.” Id. a. Reply: Plaintiff, again, presents no admissible evidence to contradict these facts, instead arguing their relevance. They should be deemed admitted. 44. From August 2001 until September 2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel unaccompanied by Plaintiff. Flight logs maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips away from Florida that Epstein and Maxwell took, unaccompanied by Plaintiff, between August 2001 and September 2002. Ex.BB. Rodgers maintained a log of all flights on which Epstein and Maxwell traveled with him. Ex.CC at 6-15. Epstein additionally traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial flights. /d. at 99-100, 103. For substantially all of thirteen months of the twenty-two months (from November 2000 until September 2002) that Plaintiff lived in Palm Beach and knew Epstein, Epstein was traveling outside of Florida unaccompanied by Plaintiff. Ex.BB. During this same period of time, Plaintiff was employed at various jobs, enrolled in school, and living with her boyfriend. a. Reply: Plaintiff goes to great lengths to dispute facts other than those presented as Undisputed Fact 44. Her voluminous, repetitive recitation of the flights that Plaintiff was on do nothing to demonstrate the 13 months of flights from July 2001 until August 2002 that Epstein and Maxwell were on without Plaintiff, as reflected in the logs. Her assertions regarding the other flights that she took, commercial or on another plane, do nothing to establish all of the many flights she was not on during 13 of the 22 month period during which Epstein and Maxwell were away from Palm Beach. Plaintiff does 26

Case 18-2868, Document 284, 08/09/2019, 2628244, Page28 of 38 not dispute that Epstein and Maxwell were on the flights without her. The facts as presented by Defendant should be deemed admitted. 45. Undisputed Fact 45: Plaintiff and Figueroa shared a vehicle during 2001 and 2002. Plaintiff and Figueroa shared a ’93 white Pontiac in 2001 and 2002. Ex.P at 67; Ex.EE. Plaintiff freely traveled around the Palm Beach area in that vehicle. /d. In August 2002, Plaintiff acquired a Dodge Dakota pickup truck from her father. Ex.P at 67-68. Figueroa used that vehicle in a series of crimes before and after Plaintiff left for Thailand. /d.; Ex.FF. a. Reply: Again, the Response has nothing to do with the facts stated. As Plaintiff concedes, she and Mr. Figueroa had one car that they both used. In fact, they traveled to and from school together. Ex.P at 67-68. She also does not dispute that she traveled freely around the Palm Beach area in that vehicle, or that “her car” was used in a series of thefts while she was in Thailand. All should be deemed admitted. 46. Undisputed Fact 46: Plaintiff held a number of jobs in 2001 and 2002. During 2001 and 2002, plaintiff was gainfully employed at several jobs. She worked as a waitress at Mannino’s Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at Roadhouse Grill. Ex.R. She also was employed at Courtyard Animal Hospital (aka Marc Pinkwasser DVM). Id.; Ex.W. a. Reply: Plaintiff admits all of the facts set forth above, aside from the use of the word “gainfully.” They should be deemed admitted. 47. Undisputed Fact 47: In September 2002, Plaintiff traveled to Thailand to receive massage training and while there, met her future husband and eloped with him. Plaintiff traveled to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove her to the airport. While there, she initially contacted Figueroa frequently, 2d

Case 18-2868, Document 284, 08/09/2019, 2628244, Page29 of 38 incurring a phone bill of $4,000. Ex.P at 35. She met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until two days before Mr. Figueroa’s deposition in this matter in May 2016. Id. at 29, 37. a. Reply: Again, Plaintiff does not refute the facts set forth, she simply offers her own interpretation of those facts. In the absence of any contrary evidence, they should be deemed admitted. 48. Undisputed Fact 48: Detective Recarey’s investigation of Epstein failed to uncover any evidence that Ms. Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. Joseph Recarey served as the lead detective from the Palm Beach Police Department charged with investigating Jeffrey Epstein. Ex.GG at 10. That investigation commenced in 2005. /d. Recarey worked only on the Epstein case for an entire year. /d. at 274. He reviewed previous officers’ reports and interviews, conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance footage of the Epstein home, participated in and had knowledge of the search warrant executed on the Epstein home, and testified regarding the case before the Florida state grand jury against Epstein. Jd. at 212-215. Detective Recarey’s investigation revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect by the government. /d. at 10-11, 180-82, 187-96, 241-42, 278. None of Epstein’s alleged victims said they had seen Ms. Maxwell at Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her, nor told what to wear or how to act by her. /d. Indeed, none of Epstein’s alleged victims ever reported to the government they had met or spoken to Ms. Maxwell. Maxwell was not seen coming or going from the house during the law enforcement surveillance of Epstein’s home. /d. at 214-215. The arrest warrant did not mention Ms. Maxwell 28

Case 18-2868, Document 284, 08/09/2019, 2628244, Page30 of 38 and her name was never mentioned before the grand jury. /d. at 203, 211. No property belonging to Maxwell, including “sex toys” or “child pornography,” was seized from Epstein’s home during execution of the search warrant. /d. at 257. Detective Recarey, when asked to describe “everything that you believe you know about Ghislaine Maxwell’s sexual trafficking conduct,” replied, “I don’t.” Jd. at 278. He confirmed he has no knowledge about Ms. Maxwell sexually trafficking anybody. Id. at 278-79. Detective Recarey also has no knowledge of Plaintiff's conduct that is subject of this lawsuit. /d. at 259-260. a. Reply: Plaintiff offers several misleading “contrary” facts, none of which actually address the facts presented herein, namely whether Ms. Maxwell was ever mentioned by any of Epstein’s alleged victims, whether she was the target of their investigation, and whether any of her property was seized from Epstein’s home. Plaintiff cites to numerous inadmissible pieces of evidence on facts other than those. Mr. Rodriguez, a convicted felon for obstructing justice related to the Epstein case, is dead and his deposition testimony is the subject of a motion in limine because Ms. Maxwell has never had the opportunity to cross examine him. Doc. 567 at 14. Ms. Rabuyo likewise is not a witness who has been deposed in this case, and therefore her “testimony” is not admissible against Ms. Maxwell. The message pads are not authenticated by anyone, as will be the subject of a forthcoming motion in limine. And there is not one shred of evidence that any child pornography, as opposed to a topless photo of a very adult Ms. Maxwell, were ever found in Epstein’s home. The facts should be deemed admitted, as those proferred by Defendant are based on admissible evidence. 49. Undisputed Fact 49: No nude photograph of Plaintiff was displayed in Epstein’s home. Epstein’s housekeeper, Juan Alessi, “never saw any photographs of Virginia 29

Case 18-2868, Document 284, 08/09/2019, 2628244, Page31 of 38 Roberts in Mr. Epstein’s house.” Ex.HH at 7 17. Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. Ex.GG at 289-90. a. Reply: Plaintiff offered no evidence that a nude photograph of her was displayed in Epstein’s home. All of the testimony she submits has nothing to do with a nude photograph of herself. The fact should be deemed admitted. 50. Undisputed Fact 50: Plaintiff intentionally destroyed her “journal” and “dream journal” regarding her “memories” of this case in 2013 while represented by counsel. Plaintiff drafted a “journal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with Epstein. Ex.II at 6465, 194; Ex.N at 205-08. In 2013, she and her husband created a bonfire in her backyard in Florida and burned the journal together with other documents in her possession. /d. Plaintiff also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. Ex.II at 194-96. To date, Plaintiff cannot locate the “dream journal.” Id. a. Reply: Plaintiff offers no contrary admissible regarding her destruction of her journal and it should be deemed admitted. 51. Undisputed Fact 51: Plaintiff publicly peddled her story beginning in 2011. Plaintiff granted journalist Sharon Churcher extensive interviews that resulted in seven (7) widely distributed articles from March 2011 through January 2015. Doc. 216 {ff 2-11 and referenced exhibits; Doc. 261-1 to 216-8, incorporated by reference. Churcher regularly communicated with plaintiff and her “attorneys or other agents” from “early 2011” to “the present day.” Plaintiff received approximately $160,000 for her stories and pictures that were published by many news organizations. Ex.N at 247-248. 30

Case 18-2868, Document 284, 08/09/2019, 2628244, Page32 of 38 a. Reply: Plaintiff offers no evidence to contradict the facts asserted and they should therefore be deemed admitted. Plaintiff's unsupported spin of those facts should be stricken. 52. Undisputed Fact 52: Plaintiff drafted a 144-page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, plaintiff drafted a book manuscript which purported to document plaintiff's experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. Ex.KK. Plaintiff communicated with literary agents, ghost writers and potential independent publishers in an effort to get her book published. She generated marketing materials and circulated those along with book chapters to numerous individuals associated with publishing and the media. a. Reply: Plaintiff cites inadmissible evidence, and attorney argument, in contradiction of these facts. They should be ignored. The “Victim Notification Letter’ is inadmissible hearsay. The psychologist records likewise are inadmissible hearsay. The FBI interview is inadmissible hearsay. Plaintiffs counsel then flatly misrepresents to the Court her own client’s characterization of the book manuscript, calling it a “fictionalized account.” Plaintiff, contradicting her counsel, testified that the book manuscript 1s “99% 99 true. Q Is there anything -- well, first of all, did you author that entire manuscript? A Yes, I did. Q Did anyone else author part of that manuscript? A Do you mean did anyone else write this with me? Q Right. A No. Q That's all your writing? 31

Case 18-2868, Document 284, 08/09/2019, 2628244, Page33 of 38 A This is my writing. Q Okay. To the best of your recollection as you sit here right now, is there anything in that manuscript about Ghislaine Maxwell that 1s untrue? A I don't believe so. Like I said, there is a lot of stuff that I actually have left out of here. Q Um-hum. A. So there is a lot more information I could put in there. But as far as Ghislaine Maxwell goes, I would like to say that there is 99.9 percent of it would be to the correct knowledge. Q All right. Is there anything that you -- and I understand you're doing this from memory. Is there anything that you recall, as you're sitting here today, about Ghislaine Maxwell that is contained in that manuscript, that is not true? A You know, I haven't read this in a very long time. I don't believe that there's anything in here about Ghislaine Maxwell that is not true. EXHIBIT RR at 42-43 (emphasis added). Plaintiff clearly now would like to spin the book manuscript as “fictionalized” because she is well aware that the “facts” presented by her in that manuscript are contradicted by many other documentary and testimonial records. Yet she offers no admissible evidence that Plaintiff intended the manuscript to be fictional. Citations to social scientists who have not testified in this case and whose work has not even be cited by any expert in this case is wholly improper and should be stricken. 53. Undisputed Fact 53: Plaintiff’s publicly filed “lurid” CVRA pleadings initiated a media frenzy and generated highly publicized litigation between her lawyers and Alan Dershowitz. On December 30, 2014, plaintiff, through counsel, publicly filed a joinder motion that contained her “lurid allegations” about Ms. Maxwell and many others, including Alan Dershowitz, Prince Andrew, Jean-Luc Brunel. The joinder motion was followed by a “corrected” motion (Ex.D) and two further declarations in January and February 2015, which repeated many of plaintiff's claims. These CVRA pleadings generated a media maelstrom and spawned highly publicized litigation between plaintiff's lawyers, Edwards and Cassell, and Alan a2

Case 18-2868, Document 284, 08/09/2019, 2628244, Page34 of 38 Dershowitz. After plaintiff publicly alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called plaintiff a liar and accused her lawyers of unethical conduct. In response, attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. Doc. 363 at 363-1 through 363-14. a. Reply: Plaintiff offers no contrary facts and so they should be deemed admitted. 54. Undisputed Fact 54: Plaintiff formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, plaintiff, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to plaintiff, the purpose of the organization is to promote plaintiff's professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Ex.LL. Plaintiff attempts to promote Victims Refuse Silence at every opportunity. Ex.MM at 17-18. For example, plaintiff participated in an interview in New York with ABC to promote the charity and to get her mission out to the public. /d. at 28. a. Reply: Plaintiff offers no contrary evidence and the facts should be deemed admitted. II. The Court should strike plaintiff's statement of “undisputed facts.” The summary-judgment procedure is well established. When the summary-judgment nonmovant bears the burden of proof at trial, as in the case at bar, the movant may show a prima facie entitlement to summary judgment in one of two ways: (1) the movant may point to evidence that negates the non-movant’s claims, or (2) the movant may identify those portions of its opponent’s evidence that demonstrate the absence of a genuine issue of material fact. 33

Case 18-2868, Document 284, 08/09/2019, 2628244, Page35 of 38 Salahuddin v. Goord, 467 F.3d 263, 272-73 (2d Cir. 2006). If the movant makes this showing in either manner, the burden shifts to the nonmovant to identify record evidence creating a genuine issue of material fact. /d. at 273. Local Civil Rule 56.1(a) carries out this summary-judgment procedure by requiring the summary-judgment movant to set forth “material facts as to which she contends there is no genuine issue to be tried.” Subsection (b) of the rule requires the party opposing summary judgment to set forth a “statement of additional material facts as to which it is contended that there exists a genuine issue to be tried” (emphasis supplied). Ms. Maxwell has moved for summary judgment; plaintiff has not. As movant, Ms. Maxwell is required under Local Civil Rule 56.1 to enumerate the facts she 1s asserting as undisputed; as the party opposing summary judgment, plaintiff 1s permitted—if she can—to introduce admissible evidence creating a genuine issue of material fact. See Fed. R. Civ. P. 56(c)(1). Plaintiff is confused. Plaintiff believes she—the party opposing summary judgment— must enumerate facts she 1s asserting as undisputed, and so she has submitted her own Rule 56.1 statement of “undisputed facts.” That gets the summary-judgment procedure exactly backwards. Plaintiffs “undisputed facts” are irrelevant. Plaintiff cannot avoid summary judgment by proposing “undisputed facts’; she may only do so by creating a genuine issue of material fact as to Ms. Maxwell’s statement of undisputed facts. Accordingly, this Court should strike plaintiff’ s statement of “undisputed facts.” Although Ms. Maxwell as the summary-judgment movant has no duty to respond to plaintiff's alleged “undisputed facts,” we hasten to add that Ms. Maxwell in fact opposes and disputes most of plaintiff’s alleged “undisputed facts.” For example, Defendant’s Undisputed 34

Case 18-2868, Document 284, 08/09/2019, 2628244, Page36 of 38 Fact 40 includes the statement, “Ms. Giuffre was hired as a ‘seasonal’ spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17.” Yet, Plaintiff sets forth as her own “Undisputed Fact 58” that “Virginia [got] job at Mar-a-Lago in 2000, either months before or just after [her] 17" birthday.” Plaintiff has done nothing more than set forth her “dispute” with Defendant’s Undisputed Fact 40 as her own “undisputed fact.” It makes no sense. See also Plaintiff's “Undisputed Fact” 63. The other alleged undisputed facts are simply Plaintiff’s assertion of her deposition testimony, and hearsay of her statements to other witnesses, couched as “Undisputed Facts.” Ms. Maxwell strenuously disputes almost all of the alleged “undisputed facts” claiming that she engaged in any sexual acts, misconduct or communications with plaintiff or others; indeed, over the course of two days and thirteen hours of deposition Ms. Maxwell disputed all such allegations. Because none of Plaintiff's “undisputed facts” have anything to do with the issues raised by Defendant’s Motion for Summary Judgment, Ms. Maxwell moves to strike plaintiff’ s statement of “undisputed facts.” Conclusion For the foregoing reasons, Ms. Maxwell requests that the Court deem her Undisputed Facts admitted, and that the Court strike plaintiff's statement of “undisputed facts.” 35

Case 18-2868, Document 284, 08/09/2019, 2628244, Page37 of 38 Dated: February 10, 2017 Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10" Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 Imenninger@hmflaw.com Attorneys for Ghislaine Maxwell 36

Case 18-2868, Document 284, 08/09/2019, 2628244, Page38 of 38 CERTIFICATE OF SERVICE I certify that on February 10, 2017, I electronically served this Defendant's Reply to Plaintiff's Statement of Contested Facts and Plaintiff's “Undisputed Facts” Pursuant to Local Civil Rule 56.]_via ECF on the following: Sigrid S. McCawley Meredith Schultz Boies, Schiller & Flexner, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley @bsfllp.com mschultz @bsfllp.com Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad @ pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp @ law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@ aol.com /s/ Nicole Simmons Nicole Simmons 37

Case 18-2868, Document 285, 08/09/2019, 2628246, Pagel of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ee ce re XK VIRGINIA L. GIUFFRE, 3 Plaintiff, V. : 15-cv-07433-RWS GHISLAINE MAXWELL, : Defendant. eee XK Declaration of Laura A. Menninger in Support of Defendant’s Reply in Support of Motion for Summary Judgment I, Laura A. Menninger, declare as follows: 1. Jam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell’s Reply in Support of Motion for Summary J udgment.' 2. In Defendant’s Memorandum of Law in Support of Motion for Summary Judgment (filed Jan. 9, 2017), I included numbered paragraphs corresponding to undisputed facts from the movant’s perspective as contemplated by Local Civil Rule 56.1(a), together with the citation to admissible evidence as required by Fed. R. Civ. P. 56(c). See Doc. 541, passim. ‘At trial, defendant intends to produce either the custodian of record relevant to any disputed document or a certification in compliance with either Fed. R. Evid. P. 803 and/or 902. See Fed. R. Civ. P. 56(c). Apart from deposition testimony, the majority of non-deposition documents herein were either produced by plaintiff or obtained with releases signed by plaintiff.

Case 18-2868, Document 285, 08/09/2019, 2628246, Page2 of 4 3. On January 9, 2017, I also prepared and served on the Court and counsel, under seal, Defendant’s Statement of Material Undisputed Facts Pursuant to Local Civil Rule 56.1 (“Statement”). Those paragraphs mirror the numbered paragraphs contained within the Memorandum of Law, minus the citations to the evidentiary record. The Statement was filed with the Court in hard-copy and placed in the vault (see Doc.543). 4. Through a clerical oversight, a redacted version of the Statement was not appended to the filed ECF version of the Notice of Motion for Summary Judgment (Doc. 537). However, as noted in the previous two paragraphs, Ms. Maxwell enumerated all undisputed facts in accordance with Local Civil Rule 56.1(a) in: e Ms. Maxwell’s Memorandum of Law in Support of Motion for Summary Judgment (Doc.541); and e the Local Rule 56.1 Statement served on the the Court and counsel and filed in hard copy with the Court. 5. Attached as Exhibit NN (filed under seal) is a true and correct copy of Defendant, Ghislaine Maxwell’s Initial Disclosure Pursuant to Fed. R. Civ. P. 26, served February 24, 2016. 6. Attached as Exhibit OO (filed under seal) is a true and correct copy of an email correspondence from Plaintiff to Sharon Churcher, dated May 12, 2011, Bates stamped GIUFFRE004096-7; 004028-30. 7. Attached as Exhibit PP (filed under seal) are true and correct copies of excerpts from the November 14, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective Order.

Case 18-2868, Document 285, 08/09/2019, 2628246, Pages of 4 8. Attached as Exhibit QQ (filed under seal) is a true and correct copy of an email correspondence from Plaintiff to Sharon Churcher, dated May 12, 2011, Bates stamped GIUFFRE003959. 9. Attached as Exhibits RR (filed under seal) are true and correct copies of excerpts from the May 3, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective Order. I declare under penalty of perjury that the foregoing is true and correct. Executed on February 10, 2017. s/ Laura A. Menninger Laura A. Menninger

Case 18-2868, Document 285, 08/09/2019, 2628246, Page4 of 4 CERTIFICATE OF SERVICE I certify that on February 10, 2017, I electronically served this Declaration of Laura A. Menninger in Support of Defendant's Reply to Her Motion for Summary Judgment via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley @bsfllp.com mschultz @bsfllp.com Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad @ pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp @ law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@ aol.com /s/ Nicole Simmons Nicole Simmons

Case 18-2868, Document 286, 08/09/2019, 2628248, Pagel of 55 EKAHIBIT NN

Case 18-2868, Document 286, 08/09/2019, 2628248, Page2 of 55 United States District Court Southern District Of New York Virginia L. Giuffre, Plaintiff, v. 3 15-cv-07433-RWS Ghislaine Maxwell, | Defendant. DEFENDANT GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(a)(1)(A) DISCLOSURES Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following disclosures: I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH PARTICULARITY IN THE PLEADINGS 1. Ghislaine Maxwell c/o Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10" Ave. Denver, CO 80203 303-831-7364 LMenninger@ HMFLaw.com Ms. Maxwell is the Defendant and may have knowledge concerning matters at issue, including the events of 1999-2002 and the publication of statements in the press in 2011-2015. 2. Virginia Lee Roberts Giuffre c/o Sigrid S. McCawley, Esq. Boies, Schiller & Flexner LLP 401 East Las Olas Boulevard, Suite 1200

Case 18-2868, Document 286, 08/09/2019, 2628248, Page3 of 55 Miami, Florida 33301 (954) 356-0011 smccawley @bsfllp.com Ms. Giuffre is the Plaintiff and has knowledge concerning the matters at issue in her Complaint, including the events of 1996-2015 and the publication of statements in the press in 2011-2015. 3. Philip Barden Devonshires Solicitors LLP 30. Finsbury Circus London, United Kingdom EC2M 7DT DX: 33856 Finsbury Square (020) 7628-7576 Philip.Barden @ devonshires.co.uk Mr. Barden has knowledge concerning press statements by Plaintiff and Defendant in 2011-2015 at issue in this matter. 4. Paul Cassell College of Law, University of Utah 383 South University Street Salt Lake City, UT 84112 801-585-5202 paul.cassell @law.utah.edu Mr. Cassell has knowledge concerning press statements by Plaintiff, Plaintiffs court pleadings, and Plaintiff’s sworn testimony. 5. Alan Dershowitz c/o Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 (202) 719-7000 Mr. Dershowitz has knowledge concerning Plaintiff's false statements to the press, in court pleadings, and in sworn testimony, at issue in this matter. 6. Bradley Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Ft. Lauderdale, FL 33301 (954) 524-2820 brad @ pathtojustice.com

Case 18-2868, Document 286, 08/09/2019, 2628248, Page4 of 55 Dated: February 24, 2016. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10" Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 Imenninger@hmflaw.com Attorney for Ghislaine Maxwell CERTIFICATE OF SERVICE I certify that on February 24, 2016, I electronically served this DEFENDANT Sigrid S. McCawley BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley @bsfllp.com GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(A)(1) DISCLOSURES via e-mail on the following: s/ Laura A. Menninger Laura A. Menninger

Case 18-2868, Document 286, 08/09/2019, 2628248, Page5d of 55 EXHIBIT OO

The text on this page is estimated to be only 46.98% accurate

To: Sharon. chart AGrehhhatohatincy CHR Shon tuulehahapaehoneureayeouKp? PAGES OF SS From: Virginia Giuffre Sent: Thu 5/42/2014 2:21:43 AM Importance: Normal Subject: Re: Good News!! Received: Thur $/12/204 + 2:21:43 AM Thanks again Shazza, I'm bringing down the house with this book!!! xoxo Jenna --~ Ou Wed, LI/S/1L, Sharon.Churcher@mailonsunday.co.uk <Sharon. Churcheremailonsunday.couk> wrote: Prom: Sbaron.Churcher@:mailonsunday .co.uk <Sharon.Churcher@ mailonsunday .co.uk> Subject: Re: Good News!! To: “Virginia Giuffre" < Received: Wednesday, 11 May, 2011, 4.17 PM Don't forget Alan Dershowitz. JE’s buddy and lawyer..good name for your pitch as he repped Claus von Bulow and a movie was made about that case...title was Reversal of Fortune. We all suspect Alan is a pedo and tho no proof of that, you probably met him when he was hanging put w JE ” ee ee re ee re Oe re ee ey ee ee ee ee ee ee ee ae ee ee ee ee ee ee me eee <n mcm me mm em mam man me et em eS Pewee arene wwe n ener nea e ee ee NN eee el ae fe a oN eee eRe ee ene ete ene | | mmm mw n> To: | | enn neon eee nn > Ss cesar esse pasa ato a tp cs cote aes ca a emt edadedn eos aeeevtmrara dacnnedaloe omens | [Sharon Churcher ?0 Oo ———E——————— | | Date |------------ a LO ED eR AE A il a Nae att ih a ee ee a ek OE NS A NT Rk HE et tt en ee md Se Se ee eh a ee ee ee ee ee ee ee ee ee tt rte rt ee te eet ee ere ee ee eee ee we ee nen nena ~~e| (10/05/2011 23:00 GDI Subject: | | --wrmnnnnnnn> LL A 8 Ns a a I ee ae Se LA A HA a me ee ee ee ee ee ee eee ae oa won === --------—--~+-----| \Good News!! *. ee ee ES LES we OF OE mE Oe AE Ht A ee ih he on ee LL eT EE TRE EO SN a lS OO Oe NO Oe ae | | -------------~------ ee en ee ee es we ee ee a ee ee ee we oe oe ee ewe ee --—| [Ht Sharon, | | \Hcllo gorgeous, I hope this message comes to you on a bright, sunny day!!! \f took your advice about what to offer Sandra and she accepted. Were | drawing up a contract through hor agent right now and getting busy to meet } Copynight Protected Mater! CONFIDENTIAL CTLUFFREMNAIGG

Case 18-2868, Document 286, 08/09/2019, 2628248, Page7 of 55 Imy deadline. Just wondering 1f you have any information on you from when | lyou and I were doing interviews about the JE story. [ wanted to put the | Jnames of some of these assholes, oops, | meant to say, pedo's, that {4 Jscnt me to. With everything going on my brain fecls like mush and i would lbe a great deal of kelp! | |Having fun sweetic? | | | Thanks, | [Jenna | Vhis emai has been scanned hy the MessageLabs Emat! Security System. For more information please visit ind www messaeclaks comemail This e-mail and any attached files are intended for the named addressee onty. it contains information, which may be confidential and icgally privileged and also protected by copyright. Unless you are the named addressee (or authortsed to receive for the addressee} you may not copy or use it, or disclose it to anyone else. If you recetved it in error please noaly the sender nmmediaicly and then delete 11 from your system, Please be advised that the views and opmmons expressed in this c-mail may not reflect the views and opinions of Associated Newspapers Limited or any of Its subsiciary companies. We make every effort to keep our network free from viruses. However, you do need to cheek this c-matl and any attachments to it for viruscs as we can take no responsibility for any computer virus which may be transferred by way of this e-mail. Use of dus or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent abuse of these tacilitics. Associated Newspapers Ltd. Registered Office: Northcliffe House, 2 Derry St, Kensington, London, W8 STT. Registered No 84121 England. | Copyright Protected Material CONFIDENTIAL CHLIFFREMN4007

To: Sharon AuPRGr Race CRerkr SAGA ae, OSIA2/ 2019, 2628248, Pages of 55 From: Virginia Giuffre Sent: Wed 6/8/2011 41:19:55 PM Importance: Normal Subject: Re: Virginia Roderts Received: Wed 6/8/2041 11:19:55 PM Ei Buddy, You are absolutely nghi..nail biting ts an understatement of the century!!! We didn't have any trouble with spiders or anything like that yesterday, if was more my daughter that gave everyone a spook! She wandered off when I turned my back to look at homemade jam and found her outside in the bush chasing the roo's!! My own miniature Tarzan!!! My fingers aud toes are crossed and I'm thinking positive!!! Much Love, Jenna --- On Wed, 8/6/11, Sharon Charcher <Sharen. Churcheraimailonsunday.co.uk> wrote: Mrom: Sharon Churcher <Sharon.Churche r@mailonsunday.co.uk> Subject: Re: Virginia Roberts To: nm Reecived: Wednesday, § Junc, 2011, 11:59 AM ‘ ° \ 4e%de = * or ; =: = j ee : oon « . ‘es a 4h " “+s L,x' % See ~ *o 4 es ~ Poke owe -*. a : *~ Root. You lucky tamngs -- bai did vou have to duck uncer spider webs? They were strung between trees when | wenl. . 4 ran ists + qt woaoviiy. ' ** oS ¥i1: ra ~ .3 ”. f roytypey ‘yet 5 ee: “oO 4. sei @ fo ose ' ey-is. -j- i ; is . J eu : a a) =. .% + ws RO Jari: As a nalloeing Saul OUT Someminer be 1s TREY Gie Ogeut. Pe wes Kev te sco It wincli is good. Uf he docsn't ceo dor it, there +h . siVerean: tev2ae UWikean seek ce ° yi? are ouhers. Divereni iasies. When did you send t! bia eit XUOu Krom: Viroinia Ginftte Seat: Wednesday, June 08, 201 1 07:27 AM To. Sharon Churcher Subject: Re: Virginia Roberts Dearest Shazza. Once again you have really outdone yourselh. MANY, MANY, THANKS!!! [took the kids to the Australian Walkabout Park today and enjoyed the scenic watks and many kangaroos. Rob and I hac good chuckle about our adventures at the Reptile Park with you and Mike ...good times!!! Have vou heard from Mike? I hope he ts weil and if you ever speak, tcll him I sent a BIG helio. {really appreciate everything you have helped with, as a triend you have gone beyond the call of duty!!! I hope we hear back from Jarred soon!! xoxoxo Jenna --~ On Wed, 8/6/11, Sharon Churcher <Sharon. Churcher(@imailonsuaday.co.uk> wrote: From: Sharon Churcher <Sharoa.Churcher@mailonsunday.co.uk> Subject: Virginia Roberts To: “jarred halperin agent (garred@abioctiv Ce: "Virginia Grutfre” < Received: Wednesday, 8 June, 2013, 2:31 AM tt ecnt.com)"” <jarred@ohjectiveent.cam> | Copyright Protected Maternal CONFIDENTIAL. CTUFFREDO4028

Case 18-2868, Document 286, 08/09/2019, 2628248, Page9 of 55 Hi Jarred Hopefully you have Virginia’s book pitch by new. she has some amazing names which she can share with you in confidence and [ think she also has a human interest Story that could appeal to the Oprah/female set as well as the Wall Streeters who follow Epstein — a hedge fund king. Here are a few of our stories about Virginia, plus some examples of the massive US and other international media pickup. Vanity Fair are daing a piece | believe in their August issue. The FBI have reapened the Epstein case due to Virginia’s revelations. | also am attaching a fink to a NY Magazine profile of Epstein.....written before his world combusted. The FBI believe he was essentially running a private — and mobile -- brothel for some of the world’s richest and most influential men. He got off the first lime round after retaining Kenneth Starr (who witchhunted Bill Clinton) and Alan Dershowitz (von Bulow's appeal lawyer, who inspired the movie Reversal of Fortune). The US Justice Deot is investigating corruption allegations against at least one prosecutor involved in the case. Best regards, Sharon Raous ERERGS avr sult, te, Date SiG! re yele! b3- 126 TOSRTF rinoc ge AD yeireiyy. at: ith 4 2 BE ‘3 ele eRe PET Ge of erigapset fie hf Britons fC aes SEP tere HAD U AAW caty igi! oo ul news /arias 13834508 Sinton. 13 year-old mgsseise-} met iwvicg-ciging-Eosteing-oird bird nl ka tts Oo SL cei inaws/ii manne tanioery mogui lent me out Baty ire QySa Mei xeunyy J nitouvoiegs wlace voice communaninsge edad 1 Gt viraiia robert obec nou (gltoadiras feroes conmvantcia/Garxgt! 2)P Sov (This ane, in Forbes Magazine, seems to require subscribing but you get the gist) http://www. telegraph. co.uk/news/uknews/theroyalfamily/8362690/Prince-Andrew. html nate Moana Davis ere oh COM Bu/newe/ na. pruice-a- paadoon laa thie, 6ax-cinva toery/story-BG fre ys 1 22n0 1 F7 S984 nitp://nymag.cam/nymetro/news/people/n_ 79 12/ This e-matl and any attached files are intended tor the named addressee only It contains information, which may be confidential and icgally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then delete it from your svstem. Please be advised that the views and opinions expressed in this c-mail may not reflect the views and opinions of Associated Newspapers |.imited or any of iis subsidiary companics, We make every effort to keep our network free from viruses. However, you do need to check this c-mail and any attachments to it fur viruses as we cap take uo responsibility for any computer virus which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent abuse of these facilities. Associated Newspapers Lid. Registered Office: Northclitfe House, 2 Derry St, Kensington, London, W8 STT. Registered No 84121 England. This ema has been scanned hy the MessageLabs Email Security System. For more information picase visit http://www. messagelabs.com/cmait This emai has been scanned by the MessageLabs Email Security System. | Coryrizht Prolcted Material CONFIDENTIAL CTUPFRENN A029

Case 18-2868, Document 286, 08/09/2019 For more information please visit http://www messagclabs.com/email 2628248, Page10 of 55 This c-mail and any attached files are intended for the named addressee only. It contains informanon, which may be confidential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disclose it to anyone else, If you received it in error please notify, the sender immediately and then delete it from vour system. Please be advised that the views and opinions expressed in tk e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of tis subsidiary companies. We make every effort to keep our network free from viruses. [lowever, you do need to check this e-mail and any attachments it for Viruses as we can take no responsibility for any computer virus which may be transferred by way of this e-matl. Use this or any othcr c-mail facility signitics consent tu any interception we might lawfully carry out to prevent abuse of thes< facilities. Associated Newspapers Ltd. Registered Office: Northcliffe House, 2 Derry St, Kensington, London, W8 STT. Registered No 84121 England. i Copyright Protecled Material CONFIDENTIAL CILIFFREN04030

Case 18-2868, Document 286, 08/09/2019, 2628248, Page11 of 55 EAHIBIT PP

Case 194aren Bande Cougt Repgoting S Video, TAC.19 of 55 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil ACLTON NO. Lo=Cy—-07455-RW5 CONFIDENTIAL VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II November 14, 2016 VIRGINIA L. GIUFFRE, Plaintiff, V. GHISLAINE MAXWELL, Defendant. APPEARANCES 3 BOLES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, Fl. 35301 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE VOLUME II 11/14/2016 348

Case 194aren Blande Cougt Repgnting S Video, TAC=7 3 of 55 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura Menninger, Esq. 10 ia LZ 3 14 Rs) 16 Ia IE s i Zz) Zi 22 23 24 Zo JELLvey Su. Pagliuca;, HS. 150 East 10th Avenue Denver, CO: 6c0Z03 Phone: 303.831.7364 Imenninger@éhmflaw.com jJpagliuca@hmflaw.com Appearing on behalf of the Defendant Also Present: Ann Lundberg, Paralegal Maryvonne Tompkins, Videographer VIRGINIA GIUFFRE VOLUME II 11/14/2016 349

10 aa LZ is: 14 Rs) 16 Ia IE s i Zz) Zi 22 23 24 Zo Case 194gen Blando Couct Repgoting &; Video, FAG=1 4 of 55 Pursuant to Notice and the Federal Rules of Civil Procedure, the continued video deposition of VIRGINIA GIUFFRE, called by Defendant, was taken on Monday, November 14, 2016, commencing at 8:04 a.m., at 150 Hast 10th Avenue, Denver, Colorado, before Pamela J. Hansen, Registered Professional Reporter, Certified Realtime Reporter and Notary Public within Colorado. kK kK kK kK kK wk 1 N D Bx VIDEO -DEPOSLTLON: OF VIRGINIA GLUE RE, VOLUME, Jet EXAMINATION PAGE By Ms. Menninger S24 VIRGINIA GIUFFRE VOLUME II 11/14/2016 350

10 ah at LZ is: 14 Rs) 16 17] LG Ly Z0 Zl ZF 22 24 Zo Case 194aren Bande Cougt Repgnting S Video, PAC.15 of 55 Dion Le LILON B xh bit Exh birt Poca ice Exhibit Ea eae Bx habit Boch baet Exhibit Exhibit Exh ict BX Bx habit Boh bet Bx hab are il 10 da 12 is 14 INDEX OF EXHIBITS (continued) INITIAL REF BRENCE settlement Agreement and General 2S Release List of names 3770 PROLOCODpY OF DHOLOCrapn 408 PHOULOCODY OF DphOLOCGraDh, wWwiEh 411 attachments PHOUTOCODY OF DhOLOOraDn;,. wach 417) attachments PHOLOCODY Of PHhOLCOdraph, with 423 attachments Statements 437 History of education, with 462 attachment Application for Employment, 4‘74 with attachment The Great Outdoors Community 4381 Services Association, Inc. Termination Form, with attachments 17072016 Letter to Schulz 484 from Hayek, with attachments Patient Registration 490 Information, with attachments CVS Prescription Records 202 Gocument, 7729072016, With attachment AFTadavyvitl Of CUSLOO lan. OF 07 Records, Walgreen Company, with attachments VIRGINIA GIUFFRE VOLUME II 11/14/2016 351

10 ia LZ 3 14 Rs) 16 Ia IE s i Zz) Zi 22 23 24 Zo Case 194aren Hlande Couct Repgoting S-Video, TAC=1 6 of 55 DESC R LE TLON Bx ha bee Bx habe Exh ict Exhibit Ea eae Bxha bat Lo LG i ils 19 20 INITIAL REF RRENCE Patient Health Summary, Clifton SEZ Beach Medical & Surgical, printed on 6/28/2016 Portions of deposition transcript 35 of Virginia Giuffre taken May 3; ZULG Amendment/Errata Sheet signed 540 May 31, 2016 by Virginia Giuffre Ad for Mar-a-Lago Club 548 The Mar=-a—lago Ciub;, L.C. 549 Employment Policies, October 28, ie cs: Page from the Mar-a-Lago Club ao Employment Policies, Revised LO 7 2001 VIRGINIA GIUFFRE VOLUME II 11/14/2016 352

10 ia LZ 3 14 Rs) 16 17] LG Ly Z0 Zk ZF Zo 24 Zo Case 194gren Blando Cougt Repgoting &; Video, F961 7 of 55 didn't see them take pictures of the backs of them. I'm not too sure who. Q You don't remember sending to them a photograph that included this wood around another DoOLOGrapn? A No. Q Okay. You have mentioned a journalist by the name of Sharon Churcher. A Yes. O You are aware that Sharon Churcher published news stories about you? A Tee: MS. MCCAWMEY: Ob ]6Cc10r. Go ahead. QO (BY MS. MENNINGER) Is anything that you have read in Sharon Churcher's news stories about you eee Ue © A I think Sharon did print some things that I think she elaborated or maybe misheard. But, I mean, if you have a specific document to show me, I'd love to look at it and read it and tell you what I think. O Is there anything, as you sit here today, that you know of that Sharon Churcher printed about you that 1s. not. true? VIRGINIA GIUFFRE VOLUME II 11/14/2016 435

10 aa LZ is: 14 Rs) 16 1] LG Ly Z0 Zl ZF 22 24 Zo Case 194aren Bande Cougt Repgnting S Video, IAC.1 9 of 55 A Not off the top of my head. If you show me, like, a news clipping article or something, I can definitely read it for you. O Is there anything that you know of that Sharon Churcher has printed about Ghislaine Maxwell that 1s not true? A NO, NOL OfT =—= MO, NOt OLE Lhe “top Of my head. O Is there anything that you recall saying to Sharon Churcher that she then printed something different than what you had said to her? A Yeah, I've read stuff. I mean, I just -IT can't remember what, but I read something that I think was, Oh, she got that wrong. I can't remember an exact example off the top of my head. © Did you ever complain to Sharon Churcher about things that she got wrong? A I didn't see a point. I might have, but I —-- I didn't see a point really because it's already printed, you Know. QO You had a fairly voluminous set of communications with Sharon Churcher by e-mail, COErPeECE? MS=« MCCAWLEY? Ob JeCC10n; A Voluminous, like a lot of them? VIRGINIA GIUFFRE VOLUME II 11/14/2016 436

10 ia LZ 3 14 Rs) 16 17] LS Ly Z0 Zi Ze ZS 24 Zo Case 194aren Bande Cougt Repgnting S-Video, TAC.1 9 of 55 O (BY MS. MENNINGER) eS A eS. O And during any of those communications, do you know whether she printed things about you after you had any of those communications? MS. MCCAWLEY® “ObJect1On. A I don't know. I know a lot of stuff was printed, and I never really stopped to read who printed the article, or wrote the article, I should SaVYe DOETY: © (BY MS. MENNINGER) Okay. I'll show you Defendant's Exhibit 7. (Exhibit 7 marked.) THE DEPONENT: Thank you. @ (BY MS. MENNINGER) T'll let you read through the statements on the first page there, and if there is anything that is not absolutely true, just put a check by it and we'll come back to it. A It's not very clear how she wrote it. "I Flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill ina huge black helicopter that Jeffrey had bought her." That wasn't an eyewitness statement. Like, I didn't see her do it. Ghislaine was the one who told me about that; that she's the one who flew VIRGINIA GIUFFRE VOLUME II 11/14/2016 437

10 aa LZ is: 14 Rs) 16 17] LS Ly Z0 ai Ze 22 24 Zo Case 194aren Bande Cougt Repgnting S Video, IAC.90 of 55 Ba.. O Ald: Cvohte LE You Just want TO: Puc. a check by it, then we'll just come back and talk about each one. A Okay. Q Just to move things along. A Okay. I have made three checkmarks. O All right. MS. MCCAWLEY?: And Fo 7use == berore you continue, I just want to identify for the record, Since this doesn't have any identifiers on it, are you representing that these are statements from Sharon Churcher? MS. MENNINGER: I'm not representing anything. I'm asking the witness questions about these statements. I asked her is anything on here not true. That's all I asked her. O (BY MS. MENNINGER) So which ones did you put checkmarks by, Ms. Giuffre? A I'd have been -—-- I'm sorry. "I'd have been about 17 at the time. I flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her." Q Okay. And what else did you put a check VIRGINIA GIUFFRE VOLUME II 11/14/2016 438

10 ah at LZ is: 14 Rs) 16 17] LG Ly Z0 Zak ZF LZ 24 Zo Case 194aren Bande Cougt Repgnting S-Video, IAC.97 of 55 lye A "T used to get frightened flying with her but Bill had the Secret Service with him and I remember him talking about what a good job" -SOrrey =— "0b. She did.” Q Okay. And what else did you put a check by? A "Donald Trump was also a good friend of Jeffrey's. He didn't partake in any sex with any of us but he flirted with me. He'd laugh and tell Jeffrey, 'you've got the life.'" QO Other than the three you've just mentioned -A Yeah. O =“ SVelLy CMG -Clec On: Deere 22 eboolurel, accurate? MS. MCCAWLEY? -Ob Jecru10n:. A Yes. Well, to the best of my recollection, yes. O (BY MS. MENNINGER) All right. What is inaccurate about, "I'd have been about 17 at the time. I flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill ina huge black helicopter that Jeffrey had bought her"? A Because it makes it kind of sound like an VIRGINIA GIUFFRE VOLUME II 11/14/2016 439

10 aa LZ is: 14 Rs) 16 17] LG Ly Z0 Zk ZF Zo 24 Zo Case 194aren Hlande Cougt Repgnting 8 Video, IAC.99 of 55 eyewitness thing. Q Okay. Did you say that statement to Sharon Churcher? A IT said to Sharon that Ghislaine told me that she flew Bill in the heli- -- the black helicopter that Jeffrey bought her, and I just wanted to clarify that I didn't actually see her do that. I heard from Ghislaine that she did that. O You heard that from Ghislaine, and then you reported to Sharon Churcher that you had heard that from Ghislaine. A GCErCcC.: MS. MCCAWMEY: Ob J6Cc1 or. A I heard a lot of things from Ghislaine that sounded too true —-- too outrageous to be true, but you never knew what to believe, so... O (BY MS. MENNINGER) Okay. And after Sharon Churcher printed what she said you said, did you complain to her that it was inaccurate? A I might have verbally with her, but again, I didn't see a point in making a hissy over it because what was done was done. She had already printed. OQ What was inaccurate about, "I used to get frightened flying with her but Bill" said -- "had the VIRGINIA GIUFFRE VOLUME II 11/14/2016 440

10 ila LZ is: 14 Rs) 16 17] LS Ly Z0 Za ZF LZ 24 Zo Case 194aren Hlande Cougt Repgnting S-Video, IAC.93 of 55 Secret Service with him and I remember him talking about what a good job she did"? A I just don't remember saying that to her. I don't remember saying I remember him talking about what a good job she did. O Ald “agnt.. A I just don't remember that at all. Q Okay. And I guess, just to be clear, my questions wasn't do you remember saying this to Sharon Churcher; my question is, is that statement accurale? MS. MCCAWLEY: Well, objection. oO (BY MS. MENNINGER) Did you used to get frightened flying with her? A Ves 4 Q Okay. Did Bill have the Secret Service with him? A They were there, but not like on the -not where we were eating. O Do you remember Bill talking about what a good job she did? A I don't remember that. Q So what 1S inaccurate about that ScCatvenenu A I just -- it's inaccurate because I don't VIRGINIA GIUFFRE VOLUME II 11/14/2016 441

10 aa LZ is: 14 Rs) 16 17] LG Ly Z0 Zak ZF LZ 24 Zo Case 194gren Blando Cougt Repgoting & Video, FA6.94 of 55 remember him talking about what a good job she did. I don't remember that. Q Does it inaccurately suggest that Bill had the Secret Service with him on a helicopter? MS... MCCAWLE Ys Ob 7yeCeELOn. A Well, not being an eyewitness to it, I wouldn't be able to tell you. I can't tell you what I don't know. O (BY MS. MENNINGER) And do you believe you said that statement to Sharon Churcher? A I mean, Sharon and I talked a lot, and if she misheard me or just wrote it in the way that she thought she should, I have no control over that. So Lie Wot OC Sure. QO Dad: She 2eCcord your anvervuews? A Some of them. Some of them she didn’t. J mean, we, like -—- we, like, met for like a week, and we spent a lot of time together, and then even after that we just continued, like, kind of a friendship. QO All right. What's inaccurate about the last statement on that page? A "Donald Trump was also a good friend of Jeffrey's." That part 1s true. "He didn't partake in any" of -—- "any sex with any of us but he flirted with me." It's true VIRGINIA GIUFFRE VOLUME II 11/14/2016 442

10 aa LZ is: 14 Rs) 16 1] LG Ly Z0 Zl ZF 22 24 Zo Case 194aren Bande Cougt Repgnting S-Video, IAC.95 of 55 that he didn't partake in any sex with us, and but it's not true that he flirted with me. Donald Trump never flirted with me. Then the next sentence is, "He'd laugh and tell Jeffrey, ‘you've got the life.'" I never said that to her. O When you say, "he didn't partake in any sex with any of us," who is "us"? A Girls, Jase. == Q How do you know who Donald Trump -- Trump had sex with? A Oh, I didn't physically see him have sex with any of the girls, so I can't say who he had sex with in his whole life or not, but I just know it wasn't with me when I was with other girls. @ And who were the other girls that you were with in Donald Trump's presence? A None. There -—- I worked for Donald Trump, and I've met him probably a few times. O When have you met him? A At Mar-a-Lago. My dad and him, I wouldn't say they were friends, but my dad knew him and they would talk all the time —-- well, not all the time but when they saw each other. QO Have you ever been in Donald Trump and VIRGINIA GIUFFRE VOLUME II 11/14/2016 443

10 ia LZ 3 14 Rs) 16 1] LG Ly Z0 Za ZF Za 24 Zo Case 194aren Blande Cougt Repgnting & Video, IAC.96 of 55 Jeffrey Epstein's presence with one another? A INO O What is the basis for your statement that Donald Trump is a good friend of Jeffrey's? A Jeffrey told me that Donald Trump is a good friend of his. QO But you never observed them together? A No, not that I can actually remember. I mean, not off the top of my head, no. O When did Donald Trump flirt with you? A He didn't. That's what's inaccurate. O Did you ever see Donald Trump at Jeffrey's home ? A Not that I can remember. O On his island? A No, not that I can remember. O In New Mexico? A No, not that I can remember. © In New York? A Not that I can remember. QO Ald: Cvonte LE You Could cUurn, ‘TO: the second page and read through those. Let me know if any of those are inaccurate. Just put a check by them and then we'll come back. A Okay. VIRGINIA GIUFFRE VOLUME II 11/14/2016 444

10 aa LZ is: 14 Rs) 16 17] LS Ly Z0 ai Ze 22 24 Zo Case 194gren Blando Cougt Repgoting &; Video, FN6297 of 55 MS. MCCAWLEYs “-Berore you Go; Virginia, I'm going to object to the use of the second page of this document. There's no time frame on it. There's no source reference to it, so it's entirely unclear where this has Come. trom. O (BY MS. MENNINGER) Okay. Are you done? A Yes Q Okay. What's the first one you've put a check by? A "The hammock photo was all over the houses," in parentheses. And Bill Clinton and -- I'm sorry, "Bill Clinton and Andrew," in parentheses, "had to have seen it." "All over the houses" is not my statement and an exaggeration. They did have that picture in the houses. And I believe, if I remember the conversation correctly, she asked, Could have Bill Clinton and Andrew seen the picture? And I said, Yes, it's possible that they could have seen it. S50, L Mean, 20S Just. that. —— 20'S ‘nor that it's totally inaccurate. I just think it's like journalist writing, had to have seen it. It doesn't mean they saw it. I just think that if it was in Front of them, they would have seen it. O 5O She CTObLd you Chat. == you tola ner Thar VIRGINIA GIUFFRE VOLUME II 11/14/2016 445

10 aa LZ is: 14 Rs) 16 17] LG Ly Z0 Zk ZF Zo 24 Zo Case 194aren Blande Couct Repgnting S Video, IAC.98 of 55 the photograph was in the houses -- houses? A Yes. I know he had it in New York on his desk. I know he had it in Palm Beach. I know he had it in the Caribbean. And I don't know if he had it in New Mexico. I can't remember New Mexico. Maybe. O Where in Palm Beach was the photograph? A The massage room. O Was that -- you did not say that they -it was all over the houses? A Correct. All over the houses would imply that it's everywhere in the house, so... QO You did not say that Andrew and Clinton had to have seen the photograph? A Correct. I -- it was more of a, if they were in front of it, they would have seen it, kind of a thing. I'm not saying it right. But it wasn't, like, had to have seen it. QO All right. What's the next statement that VOU, PUL a Check by z A I'm sorry, excuse me. My kids shared a beautiful cough with me again. "T spent four years as a millionaire's personal masseuse." QO What 1S inaccurate about that statement? A We now know, according to the timelines VIRGINIA GIUFFRE VOLUME II 11/14/2016 446

10 aa LZ is: 14 Rs) 16 17] LG Ly Z0 Zak ZF LZ 24 Zo Case 194aren Hlande Cougt Repgnting S-Video, IAC.99 of 55 that Mar-a-Lago was able to provide for us, that it was not four years. QO How many years was it? A More Iike 2-77, 4 thank; 14 -*m e1gnt, oO1 two. I'm sorry, I'm really bad at math. But yes, the two period. O What's the next statement that you have put a check by? A "T was a pedophile's dream." I think she Look that out Of GCOnTEGx. and: made that her own litele headline. O Did you say that to her? A I said something along the line like, I -the -—- the pedos loved me because I would do everything that they wanted for them. But do I think that -- yeah, I -- I know she made that line up herself, the pedos -- pedophile's dream. O What's the next one you put a check by? A I put a question mark next to the next one. It says, "Three years later she was reunited with her family." I don't know what that pertains to. I don't know what timeline that means. O Was there a period of three years where you were not with your family? A There's been longer periods than that VIRGINIA GIUFFRE VOLUME II 11/14/2016 447

10 aa LZ is: 14 Rs) 16 17] LG Ly Z0 Zak ZF LZ 24 Zo Case 194aren Hlande Cougt Repgnting & Video, FA6.30 of 55 that -- when I wasn't with my family. That's what I mean, I don't understand where that comes from. "Three years later she was reunited with her family." O Prior to 2002, was there a period of three years where you were not with your family? A NO. Q Okay. Did you Say to Sharon Churcher, three years later, she was reunited with her family? A That's what I don't understand. I don't even know what that time periods pertains to. O Do you recall saying that to Sharon Churcher? A IOs O What's the next one you put a check by? A "After about two years he started to ask me to entertain his friends." O What's wrong with that statement? A It wasn't two years. I don't know where sine. Cou that. Lrom, Q Okay. How long was it? A Like, I can't give you an exact time period, but it wasn't right in the beginning. It was after my training, or so to speak training. So, I mean, my best guesstimate would be anywhere between Fete io; 24156 Mombine. VIRGINIA GIUFFRE VOLUME II 11/14/2016 448

10 aa LZ is: 14 Rs) 16 17] LG Ly Z0 Zak ZF LZ 24 Zo Case 194aren Hlande Cougt Repgoting S-Video, IAC.3) of 55 Q SO. You dud Mot say Co Sharon Churcher, "After about two years he asked me to entertain his friends"? A COLTEC Ls QO What's the next one you put a check by? A That's it. That's all I put a checkmark NeXe. ‘LOx Q so the rest of these are absolutely accurale: A Nothing a journalist writes is absolutely accurate, but it's -—- it sounds accurate, yes. O Do you recall Jeffrey Epstein saying to you, "I've got a good friend and I need you to fly to the island to entertain him, massage him and make him feel how you make me feel"? MS. MCCAWLEY: Objection. Go ahead. A I do remember him saying that, and I think that's more of a general- -- generalization for all the times that I was sent to the -- where is this -the island to entertain people. And that would be a quote that she made but from my words saying that's what he said to me when I had to go be with these people that he sent me to. O (BY MS. MENNINGER) Did you say that VIRGINIA GIUFFRE VOLUME II 11/14/2016 449

10 ia LZ 3 14 Rs) 16 17] LG Ly Z0 Zak ZF LZ 24 Zo Case 194aren Blande Cougt Repgnting S-Video, IAC.39 of 55 sentence to her? MS. MCCAWLEYS Ob jJeCc1.0n. A I -- I can't remember. Like I said, I think it's more of a generalization. QO (BY MS. MENNINGER) Did you meet Al Gore? A Les. O Did you meet Heidi Klum? A Ves: O Did you meet Naomi Campbell? A Yes. QO Did you go on a six-week trip with Epstein Lo 2uOk? A Yeah. Yes. Sorry. QO When in 2001 did you go on a six-week trip with him? A I don't remember exactly when it was, but it's that -- it's the one where we went to Tangier, Morocco, England. I can't remember where else we Wellies 2 rance. QO Did the FBI tell you that Epstein had hidden cameras watching you the entire time, even when you were in the bathroom? A Yes. O Did the FBI tell you "Everything he did was illegal because I was under age"? VIRGINIA GIUFFRE VOLUME II 11/14/2016 450

10 aa LZ is: 14 Rs) 16 17] LG Ly Z0 Zak ZF LZ 24 Zo Case 194aren Hlande Cougt Repgnting S-Video, IAC.33 of 55 A eS. O Who in the FBI told you that? A Whichever agent I was talking to. O Which agent were you talking to? A IT can't remember. I Know I was talking to Jason Richards, and there was a girl, I think -—- I want -—-- I want to say her name was Christina Pryor, just off the top of my head. And then I think there was two other agents actually at the consulate building. I don't remember their names. Very hazy. O When was this conversation with the FBI? A After Sharon printed the articles, the first articles that came out. I don't know how many she printed, but when the first articles came out, after that the FBI contacted me. QO And was the statement that the FBI told you “Everything he did was illegal because I was under age," in response to you telling them that you were age 15 when you met Jeffrey? MS. MCCAWLEY?S ODbJeCULON. A Well, that was the closest proximity I had EO GO. Or Or. O (BY MS. MENNINGER) OKay « A So, yes. Although I still was under age, I mean, even if I was 16 and 17. VIRGINIA GIUFFRE VOLUME II 11/14/2016 451

10 aa LZ is: 14 Rs) 16 17] LG Ly Z0 Za Ze Za 24 Zo Case 194gren Blando Cougt Repgoting &; Video, FA6.31 of 55 Q Okay. And then if you could do the last page, same way; a check by anything that's not absolutely accurate. MS. MCCAWLEY: Okay. I'm going to object to this as the last page has no identifier of time or source on it. A Okay. I'm ready. O (BY MS. MENNINGER) All right. Which ones are inaccurate? A The first one is, "Virginia got a part-time job as a changing room assistant." Iwas a full-time person there. Sorry. Q OKays <50-C1d You Say Chat: tO Sharon? A Again, I don't remember that exact conversation, but I know it was a full-time job, and —-- I mean, full-time as in the, you know, the 9 to 5 or whatever hours it was, so it wasn't part-time. I don't remember the exact conversation that we had. O Okay. What's the next thing you put a check by? A I put a question mark next to, "Another lady led me into Jeffrey's bedroom. The lady walked me straight through into the massage room." I have no idea what circumstance that VIRGINIA GIUFFRE VOLUME II 11/14/2016 452

10 ia LZ 3 14 Rs) 16 17] LG Ly Z0 Zak ZF LZ 24 Zo Case 194aren Bande Cougt Repgnting S-Video, TAC.35 of 55 pertains to. Again, I don't know what that means. I don't even know what other lady she's talking about. Ow @ e Q SO you don't recall Saying that TO Sharon Churcher? A Correct. I don't even know what it means. Q Okay. What's the next one you have a check by? A "Afterwards, she was given two $100 bills and told to return the next day. That was the beginning of the four years she spent with Epstein." QO All right. What's wrong about that SCalLemene 2 A Well, again, I just want to say that the four years was inaccurate based upon memory and not an actual timeline that we were able to get. O Did you say that to Sharon Churcher, that it was four years? A I don't know if I said that to her or -oh, yeah, did I tell her it was four years? Yes, I did, 1m sorry . Q Okay. What else did you put a check by? A Well, this one is a question mark again. "Radar online has obtained excluSive diary entries of a Teen Sex Slave." VIRGINIA GIUFFRE VOLUME II 11/14/2016 453

10 aa LZ is: 14 Rs) 16 17] LG Ly Z0 Zak ZF LZ 24 Zo Case 194aren Blande Cougt Repgnting S Video, IAC.36 of 55 It wasn't really a diary. It was, like, I don't Know how many pages of something that I wrote, and Sharon used it, so... O Did you tell Sharon it was your diary ere. A She knew it wasn't a diary entry. No. O Okay. Were you a teen sex slave? A Ves: QO What's the next one you have a checkmark lye A "T also saw Prince Andrew at a Ranch in New Mexico." O Did you tell that to Sharon Churcher’? A No. And I think it's a mistake. Maybe she meant somewhere else, but because we had been talking about so much, maybe she just put New Mexico. IT don't think Sharon intentionally lied on any of these. I just —-- I think we talked so much over a period of a week, and then after that we had phone conversations, and so on and so forth, that some of the information just got misheard or mishandled, or whatever. O And what was printed was inaccurate? A Was that printed? I don't -- I don't remember reading that in the papers, but if it was VIRGINIA GIUFFRE VOLUME II 11/14/2016 454

10 aa LZ is: 14 Rs) 16 17] LG Ly Z0 Zak ZF LZ 24 Zo Case 194gren Blande Cougt Repgoting &; Video, $96.37 of 55 printed it's inaccurate. O Do you recall reading any of the ones that you put a checkmark by in the papers? A There's been so much printed, it's hard for me to remember. I mean, yes, it does sound like stuff I read before. O When you spoke with Sharon Churcher, you agreed to waive your anonymity, right? A T “Gas. O Why did you agree to do that? A I felt it was time for me to tell my story. I felt it was a good time for me to come forward. I had done so much healing, and I thought that it would be good for other people to hear what's going on, how it's happening, how vulnerable other girls can be and not even know the damage that it causes later in life. And I just thought it would be the right thing to do to come forward. O You authorized her to publish your name? A i Cac. O And your photograph? A Tess O tn Zo A I think that was the year, yes. Q You posed for photographs with her, VIRGINIA GIUFFRE VOLUME II 11/14/2016 455

10 ia LZ 3 14 Rs) 16 17] 18 i Zz) Zi 22 23 24 Zo Case 194aren Hlande Cougt Repgrting S-Video, IAC.39 of 55 I, VIRGINIA GIUFFRE, do hereby certify that I have read the foregoing transcript and that the Same and accompanying amendment sheets, if any, constitute a true and complete record of my testimony. Signature of Deponent ( ) No amendments ( ) Amendments attached Acknowledged before me this day Or ef 0 Notary Public: My Commission Expires: seal: PJH VIRGINIA GIUFFRE VOLUME II 11/14/2016 562

10 ial 12 3 14 io 16 1] LG Ly Z0 Zl ZF 22 24 Zo Case 194aren Hlande Cougt Repgnting S-Video, TAC.39 of 55 STATE OF COLORADO) ) Sos REPORTER © CHRIIEIECATE COUNTY OF DENVER ) I, Pamela J. Hansen, do hereby certify that IT am a Registered Professional Reporter and Notary Public within the State of Colorado; that previous to the commencement of the examination, the deponent was duly sworn to testify to the truth. I further certify that this deposition was taken in shorthand by me at the time and place herein set forth, that it was thereafter reduced to typewritten form, and that the foregoing constitutes a true and correct transcript. I further certify that I am not related to, employed by, nor of counsel for any of the parties or attorneys herein, nor otherwise interested in the result of the within action. In witness whereof, I have affixed my Signature this 23rd day of November, 2016. My commission expires September 3, 2018. Pamela J. Hansen, CRR, RPR, RMR 216 = oth SEreet, Suave 600 Denver, COLOrado. cUZO0Z VIRGINIA GIUFFRE VOLUME II 11/14/2016 563

Case 18-2868, Document 286, 08/09/2019, 2628248, Page40 of 55 . Epstein did invite two young brunettes to a dinner which he gave on his Caribbean island for Mr. Clinton shortly after he left office. | I'd have been about 17 at the time. I flew to the Caribbean with Jeffrey and then Ghislaine J Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her. I remember she was very excited because she got her license around the first year we met. | Lused to get frightened flying with her but Bill had the secret service with him and I remember J him talking about what a good job she did. I don't remember seeing Bill again on the trip but I assume Ghislaine flew him back. Virginia disclosed that Mr. Clinton's vice-president Al Gore and his wife, Tipper, were also guests of Epstein on his island. Virginia said that yet another American liberal icon, Senator George Mitchell, frequently visited Epstein's New York residence. Mr. Mitchell, aged 77, was very close to Jeffrey, Virginia recalled. I also met Naomi Campbell at a birthday party of hers on a yacht in the South of France. She is a friend of Ghislaine's but she was a real bitch to me. | Donald Trump was also a good friend of Jeffrey's. He didn't partake in any sex with any of us ~ but he flirted with me. He'd laugh and tell Jeffrey, 'you've got the life.’ isin : AGREN BLANDO REPORTING ee

Case 18-2868, Document 286, 08/09/2019, 2628248, Page41 of 55 Ghislaine took nude picture of me lying naked in a hammock, posed with my legs open, a bit provocatively that I gave to Jeffrey for his birthday. y The hammock photo was "all over the houses" and Bill Clinton and Andrew "had to have seen" ~~ it, | | JS I spent four years as millionaire's personal masseuse. | I was living on the streets, beaten up and slept with at least two older men in return for food. While on the streets, I slept with men for money. | | was a paedophile’s dream. L Three years later she was reunited with her family. J After about two years: he started to ask me to ‘entertain’ his friends. She recalls he said “I’ve got a good friend and I need you to fly to the island to entertain him, massage him and make him feel how you make me feel.” The way it usually worked was I'd been sent to meet a man on the private island Jeffrey owned in the Caribbean, or at his ranch in New Mexico, which was really isolated. I met famous friends of his such as Al Gore and Heidi Klum and Naomi Campbell. She was, she says, delighted when Epstein invited her to accompany him on a six-week trip in 2001. | FBI told me that Epstein had hidden cameras watching me the entire time even when I was in the bathroom. I was so embarrassed. The FBI told me everything he did was illegal because I was under age.

. Case 18-2868, Document 286, 08/09/2019, 2628248, Page42 of 55 J Virginia got a part-time job as a changing room assistant. I told Ghislaine I wanted to become a masseuse and she said she worked for a very wealthy gentleman who was looking for a traveling masseuse. I’d get training and be paid well. - Another lady led me into Jeffrey's bedroom. The lady walked me straight through into the ', massage room. Afterwards, she was given two $100 bills and told to return the next day. That was the beginning J of the four years she spent with Epstein. / Radar Online has obtained exclusive "Diary entries" of "Teen Sex Slave". I led Prince Andrew into the upstairs bathroom next to the room I was staying in. I was doing my best trying to put on a good show for him by slowly undressing and started to pour a bath. He was caressing every part of my naked body and filling my head with endless compliments about my blossoming figure. He paid careful attention to my toes and was licking them. | I also saw Prince Andrew at the Ranch in New Mexico.

Case 18-2868, Document 286, 08/09/2019, 2628248, Page43 of 55 EXHIBIT QQ

From: — Viginia Gufrecase 15-2068, DocuITent 286, 08/09/2019, 2628248, Page44 of 55 Sent: Fri 5/20/2011 2:20:09 AM Importance: Normal Subject: How ya doing?? Received: Fri 5/20/2011 2:20:09 AM Hi Buddy, I hope you are stopping to smell the daffodils once in a while and having a good day!! I am so excited today because I ca: go sign with an agent as my contract is finished with "Mail On Sunday"... YEAH!! Sandra and I have been working really hard to get me ready for my trip to the U.S in a few weeks and I was wondering if I could use your advice again. She has got an INT'L agent who 1s interested in speaking with me and I don't want to say "Yes" to the first bite because I'm not su what to look for in an agent. What could you recommend that I do? I will send Jarred and Irene (your recommended agen a copy of the synopsis and sample chapters but how do I choose the right one for "The Story"? Do you know anyone else that might be interested in this as well? If so, 1 am keen on speaking with anyone who might be. I am sooooo000 excited about this and will keep you updated with the progressing events. When I am in New York we have to meet up for some city shopping and take the kids to Central Park to see the Zoo, given there will be no masturbating kangaroo's for you to make friends with, but who know's? I am looking forward to showing Robbie around and he's got some family out there < well we have to catch up with. Such busy times, but I'm loving it!! Anyways I hope your taking care and catch me up on | your fun times!! Take care, Jenna CONFIDENTIAL GIUFFREO003959

Case 18-2868, Document 286, 08/09/2019, 2628248, Page45 of 55 EKAHIBIT RR

Case 194gren Blande, Covet Reporting S Video, FAGeA6 of 55 TN). cee, UNAS: Ode Dore eCr COURT DOUTHERN: DISTRICT OF NEW YORK Cayvyidl ACtuon No. 15=-cv—-07433—RWS CONE LOENIIAL “ViEDEOLAPED DEPOSITION -OF VIRGINIA GLUE ERE May 5% 2016 VIRGINIA L. GIUFFRE, Plaintiff, er GHISLAINE MAXWELL, Defendant. AP PoARANGC Eo * PAMBER, JAFFE, WEISSING, BEDWARDS, FISTOS & LEHRMAN, P.L. By Brad Edwards, Esq. 425 N. Andrews Avenue Suite 2 FOrL. baucgercete, Fin sosvl Phone: 954.524.2820 brad@pathtojustice.com Appearing on behalf of the Plaintiff BOLES, SCHILLER & FPLEXNER LLP BY SiLGrid S. MeCawley, Esc. (For Porcion) 401 East Las Olas Boulevard Suite 1200 Foru lauderdale, Fh. S53301l—2211. Phone: 954.356.0011 smccawley@bsfllip.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE 5/3/2016

Case 194gren Blande, Coust Reporting 8 Video, FAGe47 of 55 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, ESq. 10 ia LZ 3 14 Rs) 16 Ia IE s i Zz) Zi 22 23 24 Lo Jeffrey S. Pagliuca, Esq. 150 Hast 10th Avenue Denver, CO 80203 Phone: 50320514 /304 Imenninger@éhmflaw.com jJpagliuca@hmflaw.com Appearing on behalf of the Defendant Also Present: Brenda Rodriguez, Paralegal Nicholas F. Borgia, CLVS Videographer VIRGINIA GIUFFRE 5/3/2016

10 aa LZ is: 14 Rs) 16 Ia IE s i Zz) Zi 22 23 24 Lo Case 194gren Blande, Coust Repgrting 8 Video, FAGe48 of 55 Pursuant to Notice and the Federal Rules of Civil Procedure, the VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE, called by Defendant, was taken on Tuesday; May 3, 2016, commencing at 9:00 asm., at 150 Fast 10th Avenue, Denver, Colorado, before Kelly A. Mackereth, Certified Shorthand Reporter, Registered Professional Reporter, Certified Realtime Reporter and Notary Public within Colorado. K kK KK KOK OK ye hh. gy SE BR XAMINATION PAGE MS. MENNINGER 8 PRODUCTION REQUEST (s).; (None. ) VIRGINIA GIUFFRE 5/3/2016

10 aa LZ is: 14 Rs) 16 1] LG Ly Z0 Zl ZF 22 24 Lo Case 194gren Blande, Coust Repgrting S Video, FAGeA9 of 55 DBoGRLe T LON INDEX OF EXHIBITS INITIAL REFERENCE Complaint and Demand for Jury 7 Trial re Jane Doe No. 102 v. Jeffrey Epstein Jane Doe #3 and Jane Doe #4's 7 i. Motion Pursuant to Rule 21 for JOAnNder Arr ACT Aon Declaravion Of Virginie Ll. Zo GlUurrre ve Cane Doe 21. and Jane DOS #2 “76. DnTeea Stares OT America Declaration of Jane Doe 3 re SL Jane Doe #1 and Jane Doe #2 vs. United States of America Declaration of Virginia Giuffre So re Bradley J. Edwards and Paul G. Cassell vs. Alan M. Dershowitz FBI documentation, date of entry 36 iforae Document tatlbed Tebecon, 39 Participants Jack Scarola, Brad Fdwards, Virginia Roberts. Re Edwards adv. Epstein, 4/7/11, (23 pages of transcription) The Billionaire's Playboy Club, 4l By Virginia Roberts Plaintiff's Response and 44 Objections to Defendant's First Set of Discovery Requests to Plaintiff re Giuffre v. Maxwell VIRGINIA GIUFFRE 5/3/2016

10 aa LZ is: 14 Rs) 16 17] LG Ly Z0 Zak ZF LZ 24 Lo Case 194gren Blande, Coust Repgrting 8 Video, FAGe50 of 55 O PA nO C) ye) HH Eg 4 HH O Z INITIAL Rea eC Plaintiff's Supplemental 46 Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff Undated Declaration of Virginia 46 Giuffre re Plaintiff's Supplemental Response and Objections to Defendant's First Set of Discovery Requests served on March 22, 2016 Plaintiff's Second Amended 4] Supplemental Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff Mrs. Virginia Giuffre resume 67/ Compilation of e-mails re Open 68 Position — Virginia Giuffre Virginia Lee Roberts passport 180 app LaCallon Composite of e-mail strings Zo Compilation of e-mails between Zo0 Glurire ena Silva end olherse Compilation of e-mails between ZOD Virginia Giuffre and Sandra White Compilation of e-mails between Z69 Marianne Strong and Virginia Giuffre Compilation of e-mails between ZAG Virginia Roberts and Jason Richards VIRGINIA GIUFFRE 5/3/2016

10 aa LZ is: 14 Rs) 16 Ia IE s i Zz) Zi 22 23 24 Lo Case 1849ren Plande Covet Reporting & Video, FAGe51 of 55 DESCRIP IT LON INITIAL REEF ERENCE Compilation of e-mails between 284 Sharon Churcher and Virginia Giuffre Compilation of e-mails among Zo1 Sharon Churcher, Michael Thomas, Virginia Giuffre and others Compilation of May 2011 e-mails 288 among Sharon Churcher, Virginia Giuffre, Paulo Silva and others Compilation of June 2011 e-mails 289 between Virginia Giuffre and Sharon Churcher PR Hub Statement on Behalf of 300 Ghislaine Maxwell article Lj27 15 e-mail, trom Ross Gow «6G 309 To Whom It May Concern VIRGINIA GIUFFRE 5/3/2016

10 aa LZ is: 14 Rs) 16 1] LG Ly Z0 Zl ZF 22 24 Zo Case 194gren Blande, Covet Repgrting 8 Video, FAGe52 of 55 Some names have been changed in order to protect other people. @ (BY MS. MENNINGER) Protect their privacy? A Protect their privacy, yeah, I would say, Just not getting them involved in, if this were to ever go public. QO Well, again, without rereading the whole manuscript —-A Reading it, yeah. I'm trying to see if I can -- see something in here. O Let me narrow my question and maybe that will help. A Yes. Q Is there anything -- well, first of all, dia You. author that. ent are Manuscript: A Yes, IF did. QO Did anyone else author part of that manuscript? A Do you mean did anyone else write this with me? O RAO nt. A No. QO That's all your writing? A This 1S my writing. O Okay. To the best of your recollection, VIRGINIA GIUFFRE 5/3/2016 42

10 aa LZ is: 14 Rs) 16 17] LG Ly Z0 Zak ZF LZ 24 Zo Case 194gren Blande, Covet Repgrting S Video, FAGe53 of 55 as you sit here right now, is there anything in that manuscript about Ghislaine Maxwell that 1s untrue? A I don't believe so. Like I said, there is a lot of stuff that I actually have left out of here. O Um-hum. A So Lhere. i 16 a Lot more anrormacion 1 could put in there. But as far as Ghislaine Maxwell goes, I would like to say that there is 99.9 percent of it would be to the correct knowledge. O All right. Is there anything that you -and I understand you're doing this from memory. Is there anything that you recall, as you're sitting here today, about Ghislaine Maxwell that is contained in that manuscript, that is not true? A You know, I haven't read this ina very long time. I don't believe that there's anything in here about Ghislaine Maxwell that 1s not true. MR. EDWARDS: I'd just ask, Counsel, if you have anything specific to show her about Ghislaine Maxwell -MS. MENNINGER: I'll ask questions. MR. EDWARDS: -—-- I'll have her look at it. MS. MENNINGER: I'll ask questions. MR. EDWARDS: I know, but I want the record clear that if she hasn't read it ina long VIRGINIA GIUFFRE 5/3/2016 43

10 ia LZ 3 14 Rs) 16 1] LG Ly Z0 Zl ZF 22 24 Lo Case 1849ren Blande Covet Reporting § Video, FAGE54 of 55 IT, VIRGINIA GIUFFRE, do hereby certify that I have read the foregoing transcript and that the same and accompanying amendment sheets, if any, constitute a true and complete record of my testimony. Signature of Deponent ( ) No Amendments ( ) Amendments Attached Acknowledged before me this day Or - Boos Notary Public: Address: My commission expires Seal: KAM VIRGINIA GIUFFRE 5/3/2016 344

10 aa LZ is: 14 Rs) 16 17] LG Ly Z0 Zl ZF 22 24 Lo Case 1849ren Blande Covet Reporting § Video, FAGE55 of 55 STATE OF COLORADO) ) SG. REPORIOR: © CHRILEICATE COUNTY OF DENVER ) I, Kelly A. Mackereth, do hereby certify that I am a Registered Professional Reporter and Notary Public within the State of Colorado; that previous to the commencement of the examination, the deponent was duly sworn to testify to the truth. I further certify that this deposition was taken in shorthand by me at the time and place herein set forth, that it was thereafter reduced to typewritten form, and that the foregoing constitutes a true and correct transcript. I further certify that I am not related to, employed by, nor of counsel for any of the parties or attorneys herein, nor otherwise interested in the result of the within action. In witness whereof, I have affixed my Signature this llith day of May, 2016. My commission expires April 21, 2019. Kelly A. Mackereth, CRR, RPR, CSR Zio = LOC Street, Suice 600 Denver, COolorago GUZU0Z VIRGINIA GIUFFRE 5/3/2016 345

Case 18-2868, Document 287, 08/09/2019, 2628251, Pagel of 76 UNTTED-SErATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK a a a a ce a ce ee a4 VIRGINIA GIUFERE, GluLi Tre, | LS €Civs- 7435 -againstSEALED OPINION GHISLAINE MAXWELL, Maxwell. sis sh st “ms ace nee tem ema st ac a a a, el ay cpl ds eee x A PPEHRARANCE 8: Counsel for Giuffre BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 By: Sigrid S. McCawley, Esq. | Meredith Lb. Schultz,: Esq. Counsel for Maxwell HADDON, MORGAN AND FOREMAN, P.C. 150 East Tenth Avenue Denver, CO 80203. By; Laura A. Menninger, Esq. Jetrtrey S« Pagliuca,. Bec.

Case 18-2868, Document 287, 08/09/2019, 2628251, Page2 of 76 Sweet, D.J. The defendant Ghislaine Maxwell (“Maxwell” or the “Maxwell”) has moved pursuant to Rule 56, Fed. R. Civ. P., for summary judgment dismissing the complaint of plaintiff Virginia L. Giuffre (“Giuffre” or the “Giuffre”) alleging defamation. Upon the facts and conclusions set forth below, the motion is denied. I. Prior Proceedings Since the filing of the complaint on September 21, 205, SECLIng 2orth Ciarecets Sia of defamation by Maxwell, this action has been vigorously litigated, as demonstrated by the 704 seckee eaere: as of March 8, 2017. At ese. Se the truth or falsity of a January 2015 statement issued by Maxwell. Discovery has proceeded, a joint pretrial order has been filed, and the action is set for trial on May <5, Z0Ls« The instant motion was heard and marked fully submitted on February 16, 2017.

Case 18-2868, Document 287, 08/09/2019, 2628251, Page3 of 76 Il. The Facts The facts have been set forth in Maxwell’s Memorandum of Law in Support of Maxwell’s Motion for Summary Judgment, Southern District of New York, Local Rule 56.1; Giuffre’s Statement of Contested Facts and Giuffre’s Undisputed Facts; and Maxwell’s Reply to Giuffre’s Statement of Contested Facts and Giuffre’s iacaeouecd Facts pursuant to Local Civil Rule 56.1. They are not in dispute except as noted below. 1. +°In early 2011, Giuffre, in two British tabloid interviews, made numerous false and defamatory allegations against Maxwell. In the articles, Giuffre made no direct allegations that Maxwell was involved in any improper conduct with Jeffrey Epstein (“Epstein”), who had pleaded guilty in 2007 tO procuring 4. Miner Tor prostitucion, None rneéless, Giuttire suggested that Maxwell worked with Epstein and may have known about the crime for which he was convicted. Giuffre has denied that the allegations she made against Maxwell were false and defamatory. She noted that she did give an interview to journalist, Sharon Churcher (“Churcher”), im which She cdescribed Maxwell’ s role as. Someone

Case 18-2868, Document 287, 08/09/2019, 2628251, Page4 of 76 who recruited or facilitated the recruitment of young females for Epstein, that she was interviewed by the FBI in 2011, and that she discussed Maxwell’s involvement in the sexual abuse. Ze In the articles, Giuffre alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” Giuffre did not contest this statement but noted it is irrelevant. a In response to the allegations, Maxwell’s British | attorney, working with Ross Gow (“Gow”), Maxwell’s public relations representative, issued a statement on March 9, 2011, denying “the various allegations about [Maxwell] that have appeared recently in the media. These allegations are all entirely false.” Giuffre has denied that Maxwell’s British attorney, Philip Barden (“Barden”), “issued a statement,” noting that ae appears to have the contact “Gow” and a reference to Devonshire Soll Clore.

Case 18-2868, Document 287, 08/09/2019, 2628251, Page5 of 76 4, The March 9, 2011 statement read in full: Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 20k London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. | Tt is unacceptable that letters sent by Maxwell’s legal representatives to certain newspapers DOlIntiIng out the truch and asking for The allegations to be withdrawn have simply been ignored. In the circumstances, Maxwell is now proceeding to take legal action against those newspapers. “T understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop,” said Ghislaine Maxwell. | “A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said. Media contact: Ross Gow Acuity Reputation) Tels =-44=2035=-005-7/90 Mob? +4457773=7559=251 Email: ross@acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: Peae=Z03-000=1790,

Case 18-2868, Document 287, 08/09/2019, 2628251, Page6 of 76 Mob: +44-7778-755-251, Email: ross at acuityreputation.com Giuffre has noted it is unclear if the original included the italics that are inserted above. Dt In 2008, two alleged victims of Epstein brought an. action under the Crime Victims’ Rights Act. (the “CVRA | Action”) against the United States Government purporting to challenge Epstein’s plea agreement. They alleged the Government violated their CVRA rights by entering into the agreement. 6. Giuffre moved to join the CVRA Action on December 30, 2014, claiming she, too, had her CVRA rights violated by the Government. On January 1, 2015, Giuffre filed a “corrected” joinder motion. See Jane Doe 1 and Jane Doe 2 v. United States, Nos. 9208 -Cy=00730—-KaN, DOGkee. Now. 280 (S.D. Flax Jaen. 2, 201) (“CVRA Joinder Mot.”). Giuffre’s joinder motion in this unrelated action included gratuitous and “lurid” accusations. Giuffre has denied the final sentence fragment. Vs The issue presented in the joinder motion was narrow: whether Giuffre should be permitted to join the CVRA

Case 18-2868, Document 287, 08/09/2019, 2628251, Page? of 76 | Action as a party under Federal Rule of Civil Procedure zl, specifically, whether she was a “known victim[] of Mr. Epstein and the Government owed them CVRA duties.” Jane Doe 1 and Jane Doe 2 v. United States, No. 9:08-cv-80736-KAM, Docket No. 324 (S.D. Flas Ape, 7, 2015) (CVRA Mot. Op.7). eb os. Yeu, “the bulk of the [motion] consists -of copious factual details that [Ms. Giuffre] and [her co-movant] ‘would prove . . . if allowed to VOL” ~. £06. Giuri re gratuitously included provocative sn Te ne. details” of her alleged sexual activities as an alleged victim of sexual trafficking. Giuffre has denied that the issues presented in her joinder motion were narrow and has noted that the issues presented by the joinder motion and related pleadings were multiple and complex, requiring numerous details about Giuffre’s sexual abuse and the listing of the perpetrators of her abuse. In a pleading explaining why the motion was filed, see Jane Doe 1 and Jane Doe 2 v. United States, No. 9:08-cv-80736-KAM, Docket No. 291 at 18-26 & n.17 (S.D. Pie. Waa 2s 20S) Greene s lawyers specifically listed nine separate reasons why Jane Doe 3's allegations that Alan Dershowitz (“Dershowitz”) had sexually abused her were relevant to the case and appropriately included in the relevant filings. Additionally; Giucire states that Judge

Case 18-2868, Document 287, 08/09/2019, 2628251, Pages of 76 Marra’s ruling concluded that certain allegations were not necessary “at this juncture in the proceedings,” adding hac “Jane Doe 3 is free to reassert these factual details through proper evidentiary proof, should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a matter presented for the Court’s consideration.” CVEA. Mou. Op. at 5-6. Giuffre notes that the CVRA litigation continues and no trial has been held as of the filing of this motion so that the extent to which these Pest details will be used at trial has not yet been determined. See Docket Sheet, Jane Doe 1 and Jane Doe 2 v. United States, No. 9:08-cv-80736-KAM. 8. At the time hey filed the motion, Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA Action. While they deliberately filed the motion without disclosing Giuffre’s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. Giuffre has noted her denial as set forth to Statement 7 above.

Case 18-2868, Document 287, 08/09/2019, 2628251, Page9 of 76 oe As the -districl court noted in ruling on. Une joinder motion, Giuffre “name[d] several individuals, and she offers details about the type of sex acts performed and where they COOK place.” CVRA Mot. Op. et So. Tne coure. tuled Thar “these lurid details are unnecessary,” explaining that “[t]he factual details regarding whom and where the Jane Does engaged in sexual activities are immaterial and impertinent... , especially considering that these details involve nonparties who are not related to the respondent Government.” Id. Accordingly, “[t]hese unnecessary details shall be stricken.” Id. The court then struck all Giuffre’s factual allegations relating to her alleged sexual activities and her allegations of misconduct by non-parties. Id. at 6. The court said the sectiing of the “lurid e6taellse” was @ sanction for Giurire’ s improper inclusion OL. Them it; tHe Mocvon.. 1d. at. 7. Giuffre has noted her denial as set forth in Statement 7 above. 10, ‘THE Gistrice court an the CVRA Action. Lound nov only that the “lurid details” were unnecessary but also that the joinder motion itself was “entirely unnecessary.” Id. at 7. Giuffre and her lawyers knew the motion with all its “lurid

Case 18-2868, Document 287, 08/09/2019, 2628251, Page10 of 76 details” was unnecessary because the motion itself recognized that she would be able to participate as a fact witness to achieve the same result she sought as a party. The court denied Giutire.s VOINder Mocuon.. Td. ec: 10% Giuffre has noted her denial as set forth in Statement 7 above. 11. One of the non-parties Giuffre “named” repeatedly in the joinder motion was Maxwell. According to the “lurid details” of Giuffre included in the motion, Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein: e Maxwell “approached” Giuffre in 1999 when Giuffre was “fifteen years old” to recruit her into the scheme. e Maxwell was “one of the main women” Epstein used to “procure under-aged girls for sexual activities.” e Maxwell was a “primary co-conspirator” with Epstein in his scheme. e She “persuaded” Giuffre to go to Epstein’s Mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.” 10)

Case 18-2868, Document 287, 08/09/2019, 2628251, Page11 of 76 e At the mansion, when Giuffre began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.” e Epstein “with the assistance of” Maxwell “converted [Giutire| into. .«. «. a ‘sex sleve.*” Id. Giuffre was a “sex slave” from “about 1999 tnrough 2002.” e Maxwell also was a “co-conspirator in Epstein’s sexual abuse.” e Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the . immunity protected her from prosecution “for the crimes she committed in Florida.” e Maxwell “participat[ed] in the sexual abuse of [Giuffre] and others.” e Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [Giuffre].” Id. She shared the photos with Epstein. e As part of her “role in Epstein’s sexual abuse ring,” Maxwell “connect[ed]” Epstein with “powerful individuals” so that Epstein could traffic Giuffre to these persons. e Giuffre was “forced to have sexual relations” with Prince Andrew in “[Maxwell’s] apartment” in London. Maxwell “facilitated” Giuffre’s sex with Prince Andrew “by acting as a ‘madame’ for Epstein.” e Maxwell “assist[ed] in internationally trafficking” Giuffre and “numerous other young girls for sexual purposes.” e Giuffre was “forced” to watch Epstein, Maxwell and others “engage in illegal sexual acts with dozens of underage girls.” See CVRA Joinder Mot. 4.4.

Case 18-2868, Document 287, 08/09/2019, 2628251, Page12 of 76 Giuffre has denied the reference to “lurid details” and has noted her denial as set forth in Statements 6 and 7 above and that the testimony from numerous witnesses has corroborated the statements Giuffre made in her joinder motion: e Johanna Sjoberg (“Sjoberg”) May ig, 2016 Dep... Tha at 6=9, 13, 93-30; 142-145. e Anthony Figueroa (“Figueroa”) June 24, 2016 Déby. Tr. Vol. 2b at 96-97 and. 103. e Rinaldo Rizzo (“Rizzo”) June 10, 2016 Dep. ies 2a. oO OU: e Lynn Miller’s May 24, 2016 Dep. Tr. at 1105. e Joseph Recarey’s June 21, 2016 Dep. Tr. at Zo 04 e David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36. e Excerpted Rodgers Dep. Ex. 1 at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, Io/0, ana LOO D e NadiaMarcinkova (“Marcinkova”) Dep. Tr. at 10:18-21; 12:11-15; etc. le

Case 18-2868, Document 287, 08/09/2019, 2628251, Page13 of 76 e Sarah Kellen (“Kellen”) Dep. Tr. at 15:1318; 20:12-16; etc. e Epstein Dep. Tr. at 116:10-15; 117:18118:10; etc. e Juan Alessi (“Alessi”) Dep. Tr. At 28, 5254. e U.S. Attorney Victim Notification Letter GIUFFRE002216-002218. e July 2001 New York Presbyterian Hospital Records GIUFFRE003258-003290. e Judith Lightfoot psychological records GIUFFRE005431-005438. e Message Pad evidencing Maxwell arranging to have underage girls and young women come to Epstein’s home GIUFFRE001386-001571. e “Black Book” in which Maxwell and other household staff maintained a roster of underage girls including pF minors at the time the Palm Beach Police’s Investigation of Jeffrey Epstein GIUFFRE001573-00669. Le

Case 18-2868, Document 287, 08/09/2019, 2628251, Page14 of 76 e Sex Slave books Epstein ordered from Amazon.com at GIUFFREO06581. e The folder Maxwell sent to Thailand with Giuffre bearing Maxwell’s phone number GIUPFREOOZL91 005192. e The Palm Beach Police Report showing that Epstein used women and girls to collect underage girls for his abuse GIUFFREOO5S614OOS 700% e Epstein’s Flight Logs showing that Maxwell flew with Giuffre 23 times GIUFFREO07055O07 6. 12, da the So6inder motion, -Glutive silso slieged She was “forced” to have sex with Dershowitz, “model scout” Jean Luc Brunel, and “many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a eat icnown Prime Minister, and other world leaders.” CVRA Joinder Mot. at 5-6. Giuffre has noted her denial as set forth in Statements 7 and 11 above. 14

Case 18-2868, Document 287, 08/09/2019, 2628251, Page15 of 76 13. ‘Giurtire Said. after serving: tor four years.as.a “sex slave,” she “managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years.” Id. at oe Giuffre has admitted making this statement and has noted since discovered evidence that indicates she was mistaken on the exact timeframe of her abuse and was with Maxwell and Epstein from the years 2000-2002. 14. Giuffre suggested the Government was part of Epstein’s “conspiracy” when it “secretly” negotiated a nonprosecution agreement (“NPA”) with Epstein precluding federal prosecution of Epstein and his “co-conspirators.” Id. at 6. The Government’s secrecy, Giuffre alleged, was motivated by its fear that Giuffre would raise “powerful objections” to the agreement that would have “shed tremendous public light” on Epstein and Other powerful individuals. 2a. al 6-7. Giuffre has denied that she suggested that the Government was part of Epstein’s conspiracy to commit sex offenses and has noted that the CVRA Action deals with whether the Government failed in their responsibilities to the victims ko

Case 18-2868, Document 287, 08/09/2019, 2628251, Page16 of 76 to inform the victims that the Government was working out an NPA, that the Government did fail to so inform the victims, and that it intentionally did not inform the victims because the expected serious objection from many of the victims might prevent the Government from finalizing the NPA with Epstein. 15. The other “Jane Doe” who joined Giuffre’s motion who alleged she was sexually abused on “many occasions” by Epstein was unable to corroborate any of Giuffre’s allegations. Giuffre has denied the statement and noted that the other Jane Doe could corroborate many of Giuffre’s allegations based on a similar pattern of abuse by Epstein that she suffered, that she did not know Giuffre, and further has noted pT who was deposed in this case, and who was a minor, corroborates the same pattern of abuse. 16. In her multiple and lengthy consensual interviews with Churcher three years earlier, Giuffre told Churcher of virtually none of the details she described in the joinder motion. 16

Case 18-2868, Document 287, 08/09/2019, 2628251, Page1/7 of 76 Giuffre has denied the statement and noted that absence of any citation or evidence on this point and that the statement here is knowingly false based on the articles and Giuffre’s deposition. 17. As Giuffre and her lawyers expected, before Judge Marra in the CVRA Action could strike the “lurid details” of Giuffre’s allegations in the joinder motion, members of the media obtained copies of the motion. Giuffre has denied the statement ae See Toren a1 Statement 7 above. 18. At the direction of Barden, on January 2, 2015, Gow sent to numerous representatives of British media organizations an email containing “a quotable statement on behalf of Maxwell” (the “Press Release”). The email was sent to more than six and probably fewer than 30 media representatives. It was not sent to non-media representatives. Giuffre has denied that “[a]t Mr. Barden’s direction, on January [2], 2015, Gow sent To numerous representatives of British media organizations an email containing ‘a quotable dt

Case 18-2868, Document 287, 08/09/2019, 2628251, Page18 of 76 statement on behalf of Maxwell’” and has noted that Gow produced an email exchange he had with Maxwell in which Maxwell directs Gow to send the Press Release as follows: Te: Ro Jon 2045 20:14:59 +0000 Ce: Philip Sarden<philip. barden@ devonshires.co.uk> Subject: FW: URGENT - this Is the statement sso nota new individual. de by Victoria Roberts against Ghisiaine Maxweil are untrue. The allegations me The original allegations are not new and have been fully responded to and shown to Each time the story is re told it changes with new salacious details about bic figures and world leaders and now it is alleged by. vat A involved itt having relations wit h her, wh le h he denies ie Ms Roberts claims ar 2s news, ag they are de Giluttre has. further noted that chronologically, this email comes at the end of various other email exchanges betueen Maxwell and Gow that discuss issuing a press release and that the subject line of this email that Maxwell wrote to Gow states “URGENT —- this is the statement,” thereby instructing Gow to release this statement to the press. Additionally, Giutfre notes that shortly after Maxwell sent this email to Gow directing him to release the Press Release, Gow distributed it to multiple media outlets, and that no email has been produced in which 18

Case 18-2868, Document 287, 08/09/2019, 2628251, Page19 of 76 Barden directed Gow to issue this press release. At his deposition, Gow authenticated this email and confirmed that Maxwell authorized the statement. Giuffre has noted that the email and Gow’s cescneay establish that Maxwell, not Barden, directed and “command[ed]” ‘Gow to publish the defamatory statement and the first sentence of the statement is false and the second sentence - “This email was sent to more than 6 and probably less than 30 media representatives” - omits the fact that not only did Gow admit to emailing the statement to the press, but he also read it to over 30 media representatives over the phone. Giuffre has denied the statement. 19. Among the media representatives who received the ueee Release were Martin Robinson of the Daily Mail, P. Peachey | of The Independent, Nick Sommerlad of The Mirror, David Brown of The Times, Nick Always and Jo-Anne Pugh of the BBC, and David Mercer of the Press Association. These representatives were selected based on their request after the joinder motion was filed—for a response from Maxwell to Giuffre’s allegations in Ehe MOELOn: lee

Case 18-2868, Document 287, 08/09/2019, 2628251, Page20 of 76 Giuffre has denied the second sentence and has noted there is no record evidence that Gow (or anyone else) “selected” 7FOUrNaLISts: “Lor a response,” or thar sie was any selection process and that Gow testified that anyone who inquired received a reference to the Press Release. 20. The email to the media members read: To Whom It May Concern, , Please find attached a quotable statement on behalf of Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Fach time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms. Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms. Roberts claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory. 20

Case 18-2868, Document 287, 08/09/2019, 2628251, Page21 of 76 Ghislaine Maxwell’s original response to the lies and defamatory claims remains the samé. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. Giuffre has noted that the body text of the email that was sent to news media was cropped and the headings and metadata were omitted and has further noted the image of the email set forth below. a

Date: 2 tanwary 2 cone as = subject: ¢ Ghistoine Mix . el time the story is re told it change « with ne | 3 fle by Ms Roberts t secual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. = Maxwell's original response to the lies and defamatory claims remains the sam VMiaxwe igly denies allegations of an unsavoury nature, which have oe le in the British press ead else where and reserves her right to seek redress at the repetition of such ald defamatory claim: ae Sent from my BlackBerry® wirciess device 21. Barden, who prepared the Press Release, did not intend it as a traditional press release solely to disseminate information to the media, and he intentionally did not pass it through.2@ public Pelations firm, such as Gow’s fii, Aeudey Reputation. Be

Case 18-2868, Document 287, 08/09/2019, 2628251, Page23 of 76 Giuffre has denied the statement and has noted that the Barden Declaration should not be considered. She has further noted that there is no evidence to support any assertion of Barden’s intent and that Maxwell gave the statement to Gow with instructions to publish it. Giuffre also has denied that the statement did not pass “through a public relations firm, such as Gow’s firm, Acuity Reputation” and has noted that record documentary evidence and testimony establish that this statement was disseminated through Gow’s firm, Acuity Reputation. 22. The Press peiesse aeeued two purposes. First, Barden intended that it iPeieaee the harm to Maxwell’s reputation from the press’s republication of Giuffre’s false allegations. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject Giuffre’s allegations to inquiry and scrutiny. For example, he noted in the statement that Giuffre’s Saiegactons changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicized as news.” Giuffre has denied this statement and any statement of Barden’s intent and that there was any “republication” by the Zo

Case 18-2868, Document 287, 08/09/2019, 2628251, Page24 of 76 press as a matter of law as the press did not “republish” the press statement under New York law and that the allegations in the statement are “false,” and cites to the evidence set hOLeEH in Statement 11 above. Giuffre has further disputed that the harm to Maxwell’s reputation could be mitigated by the media’s inquiry into and scrutiny of Giuffre’s allegations, because a deeper inquiry would ane reveal additional evidence corroborating Giuffre’s allegations, and has noted that the record does not establish who drafted the Press Release, and that it was ultimately Maxwell who “noted” anything because it is her statement and that she directed that it be sent to the media and public. Giuffre has also disputed that her allegations have changed over time, “dramatically” or otherwise, that the Press Release “suggest[ed]” that her allegations are “obvious lies,” because the Press Release affirmatively stated that her allegations are “obvious lies” there is no subtlety, suggestion, or statement of opinion here. 24

Case 18-2868, Document 287, 08/09/2019, 2628251, Page25 of 76 23. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish Giuffre’s allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that Giuffre’s allegations were “defamatory.” In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Maxwell considered the publication of Giuffre’s obviously false allegations and the legal indéfensibility of. their own. conduct. Giuffre has denied this statement and the statement that Barden repeatedly noted that Giuffre’s allegations were “defamatory” as he did not “note” anything in the statement, nor does Maxwell cite to any record evidence that he did. Giuffre further denies the sentence, “In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Maxwell considered the publication of Giuffre’s obviously false allegations and the legal indefensibility of their own conduct,” as there is no record Zo

Case 18-2868, Document 287, 08/09/2019, 2628251, Page26 of 76 evidence in support of this claim, and Maxwell has not cited any. 24. Consistent with his purposes as described by Maxwell, Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Maxwell.” The statement was intended to be a single, one-time only, comprehensive response, quoted in full, to Giuffre’s December 30, 2014, allegations that would give the media Maxwell’s response. The purpose of the prefatory statement was to inform the media-recipients of this intent. Giuffre has disputed the statement and any statement relating to Barden’s “purposes,” as explained above, and has noted that Gow repeatedly issued this statement via email and over the phone for months on end and that Maxwell instructed them to publish it by telling them it was “quotable,” and hired a press agent to distribute it to the press with the intent for the press to publish the Press Release. 25. Giuffre has engaged in numerous activities to _ bring: Attention to herself, to rhe: prosecution and punishment of 20

Case 18-2868, Document 287, 08/09/2019, 2628251, Page27 of 76 wealthy individuals such as Epstein, and to her claimed interest eof bringing 1iGhe to The rights cof viclims-oF Sexual: abuse. Giuffre has denied that she engaged in activities to bring attention to herself but has noted that she has taken action to aid in the prosecution of her abusers, and she seeks to bring Light to. the rights of victims. of Sexual abuse: 26. Giuffre created an Organi zation,. Victims Rertuse Si1ilence. Inca, @. Florida Corporation; direcuily: related to: ner alleged experience as a victim of sexual abuse. NW 27. The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse.” Toward this end, Giuffre has “dedicated her professional life to helping victims of sex trafficking.” 28. Giuffre repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. Zo

Case 18-2868, Document 287, 08/09/2019, 2628251, Page28 of 76 Giuffre has denied the statement and noted that she was approached by numerous media outlets and refused to speak to most of them, that media organizations sought her out and she did not seek them out. 29. Giuffre has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s alleged “sex scheme.” Giutireé has stared that this. mischeracter 1766 these activities, that it was against a backdrop of seeking psychological counseling that. sie drafted the manuscript as an “act of empowerment” and “a way of reframing and taking control over the narrative.” Pl.’s Opp’n at 60. Giuffre notes that she ultimately decided not to publish the manuscript. See Giuffre Deps Tr, 24921 Cele? 2502 19=25125. 30. Giuffre was required by Interrogatory No. 6 to identify any face Statemenres attripuced to Maxwell Unhat were “published globally, including within the Southern Davste LO, Ox New York,” as Giuffre alleged in Paragrapm 9-or Coun= One OF er complaint. In response, Giuffre identified the Press Release and 28

Case 18-2868, Document 287, 08/09/2019, 2628251, Page29 of 76 nine instances in which various news media published portions of the Press Release in news articles or broadcast stories. Giuffre has denied this statement. There is no “republication” as a matter of law and Maxwell possesses the knowledge as to where the defamatory statements were published, and Giuffre has noted that she has provided a sampling of Maxwell’s defamatory statements published by the news media and that Maxwell caused her statement to be published in an enormous number of media outlets. Zo

Case 18-2868, Document 287, 08/09/2019, 2628251, Page30 of 76 Jane Doe 3 is Virginia Roberts - so not anew individual. ‘The allegations made by Victoria Roberts. against. Ghislaine Maxwell: are untrue. The original allegations . are not new and -have been. fully responded to.and shown to be untme: : Each time the story is re told it changes with new: . salacious. details about public figures and world leaders and now it is alleged by. Ms: Roberts. that Alan. os -Dershowitz.i isinvolyed im. having sexud relations with. ber, which he denies. Ms. Roberts’ 5 claims. are obvi OuS lies and should be: treated'as such and not publicized a8 REWS, 28 they are defamatory. Ghislaine Maxwell’: original a espana to the lies and 2 cwell strongly oa, ate which have» | esi right to: — nee a ioe a on 4 defamatory claims. 30

Case 18-2868, Document 287, 08/09/2019, 2628251, Page31 of 76 31. In none of the nine instances was there any publication of the entire Press Release. Giuffre has noted extensive evidence of the mass distribution of Maxwell’s defamatory statement to over 66 million viewers as stated by her expert witness James Jansen (“Jansen”). 32. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in Giuffre’s response to Interrogatory No. 6, in connection with the media’s publication of portions of the Press Release Giuffre has disputed this statement and noted it is completely devoid of record evidence and that the record establishes that Maxwell hired Gow because his position allowed him to influence the press to publish her defamatory statement, Dep. Wr. ee to 9eloy Lo 21e-16.27 109:12-22; LOL o=2Z..: dil e= 7, and that Maxwell caused her statement to be published by numerous major news organizations with wide readership all over the globe. a.

Case 18-2868, Document 287, 08/09/2019, 2628251, Page32 of 76 33. Eight years after Epstein’s guilty plea in Florida, Giuffre brought this action, repeating many of the allegations she made in her CVRA joinder motion. Giuffre has noted that the defamation cause of action against Maxwell did not accrue until Maxwell defamed her in January of 2015. 34. The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (ob) That the allegations have been “shown to be untrue.” (c) That Giuffre’s “claims are obvious lies.” 35. Giuffre lived independently from her parents with her fiancé long before meeting Epstein or Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999, Giuffre moved in with the family of a fellow patient. There she a2

Case 18-2868, Document 287, 08/09/2019, 2628251, Page33 of 76 met, and became engaged to, her friend’s brother, James Michael AuSsiurickn <“Agsti rien”) . She and Austrich thereafter rented an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs in that area. Later, they stayed briefly with Giuffre’s parents in the Palm Beach/Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. Although Giuffre agreed to marry Austrich, she never had any intention of doing so. Giuttrée has denied that she voluntarily lived independently from her parents with her fiancé; she states that she was a troubled minor child who was not realistically engaged prior to meeting Maxwell and Epstein, as she was not of legal age to marry. She confirms she had no intention of marrying Austrich. 36. Giuffre re-enrolled in high school from June 2l, 2000 until March 7, 2002. After finishing the 9th grade school year at Forest Hills High School on June 9, 1999, Giuffre reenrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on August 14, 2001. On September 20; 2001, Giuffre then enrolled at Royal Palm Beach High School. A few weeks later, on October 12, 2001, she matriculated at oe:

Case 18-2868, Document 287, 08/09/2019, 2628251, Page34 of 76 Survivors Charter School. Survivor’s Charter School was an alternative school designed to assist students who had been unsuccessful at more traditional schools. Giuffre remained enrolled at Survivor’s Charter School until March 7, 2002. She was present 56 days and absent 13 days during her time there. Giuffre never received her high school diploma or GED. The school day at Survivor’s Charter School lasted from morning until early afternoon. Giuffre has denied the statement and has noted that Giuffre’s school transcripts indicate “NO COURSES TAKEN” for the 1999-2000 and 2000-2001 school years and that her attempt to work and resume school. at Saryiuen's Chearrer School asa 10th grader in the 2001-2002 school year was limited to a DOrt Lon OL the school year, spanning fewer than six months from October 2001 to March 7, 2002. She states that she attempted to get away from Epstein’s abuse and that the records indicate that Giuffre’s attendance was poor, with 69 days present and 32 days absent out of a required 180 day school year. She was not enrolled at the end of the school year. Her presence on flights with Epstein, verified by Epstein’s pilot on flight logs, and an abundance of witness testimony corroborate her story that she was flying domestic and internationally with Epstein at least Oe 34

Case 18-2868, Document 287, 08/09/2019, 2628251, Page35 of 76 times between December 11, 2000 to July 28, 2001 and June 21, 2002 tO. August Zi, 2002. 37. During the year 2000, Giuffre worked numerous JOS. 2m 2000, aie living with her fiancé, Giuffre held five different jobs: at Aviculture Breeding and Research Center, Southeast Employee Management Company, The Club at Mar-a-lLago, Oasis Outsourcing, and Neiman Marcus. Her taxable earnings that year totaled nese iy $9,000. Giuffre cannot now recall either the Southeast Employee Management Company or the Oasis Outsourcing jobs. Giuffre has disputed the statement and has noted that while she held various jobs in 2000, Social Security Administration records do not show the exact dates of employment (month ad day) because they do not need this information to figure Social Security benefits. She states that neither Southeast Employee Management Company nor Oasis Outsourcing were her employers. She states that she worked at Taco Bell, as well as a pet store, but that neither of these are listed on her esetai Security Administration records because they were most likely paid through payroll companies. She subsequently worked at Mar-a-Lago. She also volunteered at Aviculture Breeding and oS

Case 18-2868, Document 287, 08/09/2019, 2628251, Page36 of 76 Research Center, where they eventually put her on the payroll but paid her very little. 38. Giuffre’s employment at The Mar-a-Lago spa began in fall 2000. Giuffre’s father, Sky Roberts (“Roberts”), was hired as a maintenance worker at The Mar-a-Lago Club in Palm Beach, Florida, beginning on April 11, 2000. Roberts worked there year-round for approximately 3 years. After working there for a period of time, Roberts became acquainted with the head of the spa area and recommended Giuffre for a job there. Mar-a-Lago closes every Mother’s Day and reopens on Novenber Le. MOOSE employees at Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club is open, i.e., between November 1 and Mother’s Day. Giuffre was hired as a “seasonal” spa attendant to work at the Mar-aLago Club in the fall of 2000 after she had turned 1/7. Giuffre has disputed the statement and noted that the Mar-a-Lago Club produced 177 pages of records in response to Maxwell’s subpoena which did not indicate Giuffre’s actual dates of employment, nor whether she was a full-time or seasonal employee. The only significant record produced was a single, 20

Case 18-2868, Document 287, 08/09/2019, 2628251, Page37 of 76 vague chart entry indicating that Giuffre was terminated in 2000 and that Mar-a-Lago was a summer job. 39. Giuffre represented herself as a masseuse for Epstein. While working at the Mar-a-Lago spa and reading a isnaey book about massage, Giuffre met Maxwell. Giuffre thereafter told her father that she got a job working for Epstein as a masseuse. Giuffre’s father took her to Epstein’s house on one occasion around that time, and Epstein came outside and introduced himself to Roberts. Giuffre commenced employment as a traveling masseuse for Epstein. Giuffre was excited about her job as a masseuse, about traveling with him and about meeting famous people. Giuffre represented that she was employed as a masseuse beginning in January 2001. Giuffre never mentioned Maxwell to Austrich. Giuffre’s father never met Maxwell. Giuffre has denied the statement and has noted that in Florida, a person cannot work as a masseuse unless she is “at least 18 years of age or has received a high school diploma -or high school equivalency diploma,” Fla. Stat. § 480.041. She was a minor child, under the age of 18, “nen She was working at Mara-Lago aS a spa attendant and was approached by Maxwell who told her she could make money as a masseuse, a profession in which a7

Case 18-2868, Document 287, 08/09/2019, 2628251, Page38 of 76 Giuffre had no experience. She states that her ener drove her to Epstein’s house, the address of which was given to her by Maxwell, that she was led into the house and instructed by Maxwell on how to give a massage. She states that Epstein and Maxwell turned the massage into a sexual encounter, and offered her money and a better life to be compliant in the sexual demands of Maxwell and Epstein. She then began travelling with Maxwell and Epstein on private planes and servicing people sexually for money — working not as a legitimate masseuse, but in a position of sexual servitude. Giuffre further noted that Epstein’s house manager, Alessi, described Maxwell’s methodical routine of how she prepared a list of places ahead of time, then drove to each place for the purpose of recruiting girls tomassage Epstein. Alessi stated that on multiple occasions he drove Maxwell to pre-planned aiaees while she recruited girls for massage, and that he witnessed Giuffre at Epstein’s house on the very same day that he witnessed Maxwell recruit Giuffre from Mar-a-Lago. Giuffre further noted Sjoberg’s testimony that she was similarly recruited. 40. In spring 2001, while living with Austrich, Giuffre lied to and cheated on him with Figueroa, her high school boyfriend. Giuffre and Austrich thereafter broke up, and 20

Case 18-2868, Document 287, 08/09/2019, 2628251, Page39 of 76 Figueroa moved into the Bent Oak apartment with Giutfre. when Austrich returned to the Bent Oak apartment to check on his pets and retrieve his belongings, Figueroa punched Austrich in the face. Figueroa and Giuffre fled the scene before police arrived. Figueroa was then a convicted felon and a drug abuser on probation for possession of a controlled substance. Giuffre has objected to the statement as irrelevant and unrelated to the allegations made in Giuffre’s complaint against Maxwell and the alleged information should be excluded by multiple rules of evidence, and has been contested by Giuffre. Ai, “Giuttre freely and voluntarily contacted. the police to come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at age 17, while living im the same apartment, Giuffre and Figueroa hosted a party with a ance Or ‘Guests. During the paxrcy, according to Giuffre, someone entered Giuffre’s room and stole $500 from her shirt pocket. Giuffre contacted the police. She met and spoke with police officers regarding che incident and filed a report. She did not disclose to the officer that she was a “sex slave.” A second time, in June 2002, Giuffre contacted So

Case 18-2868, Document 287, 08/09/2019, 2628251, Page40 of 76 the police to report that her former landlord had left her belongings by the roadside and had lit her mattress on fire. Again, Giuffre met and spoke with the law enforcement officers but did not complain that she was the victim of any sexual trafficking or abuse or that she was then being held as a “sex slave.” Giuffre has objected to the statement as misleading and ceectesane end further noted that she was fearful of Maxwell and Epstein, and, accordingly, she would not have reported her abusers and noted that she knew that Epstein had control over the Palm Beach Police. A>. Brom Auguste 2001 Until Seolember 2002, Epstein and Maxwell were almost entirely absent from Florida on documented travel unaccompanied by Giuffre. Flight logs maintained by Dave Rodgers (“Rodgers”), Epstein’s private pi LoL, evidence the substantial number of trips away from Florida that Epstein and Maxwell took, unaccompanied by Giuffre, between August 2001 and September 2002. Rodgers maintained a log .of all flights on which Epstein and Maxwell traveled with him. Epstein additionally traveled with another pilot who did not keep such logs and he also occasionally traveled via commercial flights. 40

Case 18-2868, Document 287, 08/09/2019, 2628251, Page41 of 76 For substantially all of thirteen months of the twenty-two month period from November 2000 to September 2002, ppeeein. was traveling outside of Florida unaccompanied by Giuffre. During this same period of time, Giuffre was employed at various jobs, enrolled in school, and living with her boyfriend. Giuffre has disputed this statement and noted the flight. logs produced in: this. matter provide substantive evidence of ictus travel while in the control of Maxwell and Epstein, but are incomplete as Giuffre also was flown by Maxwell on commercial flights. The flight logs and pilot testimony clearly prove that Giuffre was flying domestic and internationally with Epstein at least 32 times between December ll, Z2000- te Vuly 2s, 2001 and June 21, 2002 to August 21, 2002. Maxwell has acknowledged the flight logs are incomplete and that there were several pilots and co-pilots that flew Epstein and Maxwell (e.g., Rodgers, Lawrence “Larry” Visoski, Bill Hammond, Pete Rathgeb, Gary Roxburgh, and Bill Murphy) in multiple aircrafts and that only Rodgers produced flight records. Giuffre states that Maxwell has also acknowledged that many of the girls recruited by Maxwell routinely traveled on commercial flights for the purposes of providing massages to Epstein or guests at Epstein’s New York, New Mexico, or U.S. Virgin Island homes. Al

Case 18-2868, Document 287, 08/09/2019, 2628251, Page42 of 76 Giuffre has further noted that her passport application, travel records, and witness testimony demonstrate flight logs are incomplete, that she also flew commercially while she worked for Maxwell and Epstein. Her paeeuoee application, for example, listed travel plans to London, and subsequent flight logs listed Giuffre traveling to London with Maxwell, Epstein, and others. Giuffre has cited the evidence she contends establish her travel with Epstein and Maxwell, including massage training in Thailand. 43. Giuffre and Figueroa shared a ‘93 white Pontiac in 2001 and 2002. Giuffre freely traveled around the Palm Beach area in that vehicle. In August 2002, Giuffre acquired a Dodge Dakota pickup truck from her father. Figueroa used that vehicle in a series of crimes before and after Giuffre left for Thailand. Giuffre has denied the statement and has noted that she purchased a car from the $10,000 payment she received from Epstein after she was forced to have sex with Prince Andrew in London at Maxwell’s home. 42

Case 18-2868, Document 287, 08/09/2019, 2628251, Page43 of 76 Ad. CGiutfre held a: number of jobs in 2Z001.and 2002. During 2001 and 2002, Giuffre was gainfully employed at several jobs. She worked as a waitress at Mannino’s Restaurant, at TGlFriday’s réstaurant (“CCl of Royal Palm Inc.”); ana -at Roadhouse Grill. She also was employed at Courtyard Animal Hospital (“Marc Pinkwasser DVM”). Giuffre has denied the scape: and noted that in 2001 and 2002 she attempted to go back to school to earn her GED, and tried unsuccessfully to hold down waitressing jobs. She earned $212.00 as a waitress working “briefly” at Mannino’s Restaurant and, in 2002, earned $403.64 working at the TGIFriday’s restaurant (“CCI of Royal Palm Beach”) for a “short time period.” She earned about $1,247.90 at Roadhouse Grill until about March 2002, and at the Sore evans Animal Hospital (“Marc Pinkwasser DVM”) she received payroll checks for weeks ending April, 22, 2002 to June 4, 2002, carning a total of $1,561.75. Not long after she lost her job at the Courtyard Animal Hospital, she was traveling with Maxwell to the Bahamas, Santa Fe, New Mexico, and New York. 45. Giuffre traveled to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove her to the 43

Case 18-2868, Document 287, 08/09/2019, 2628251, Page44 of 76 airport. While there, she initially contacted Figueroa frequently, incurring a phone bill of $4,000. She then met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until two days before Figueroa’s deposition in this matter in May 2016. Giuffre admitted traveling to Thailand to receive massage training in September 2002 but noted that she was given an assignment from Maxwell and Epstein that she had to recruit another underage girl from Thailand, and bring that young girl back to Epstein. Giuffre stated that she was expected to return to Epstein and Maxwell upon completion of her massage training and assignment, and that instead she escaped to Australia where she remained in hiding from Maxwell and Epstein for several years. 46. Detective Joseph Recarey (“Recarey”) investigated Epstein and failed to uncover any evidence that Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. Recarey served as the lead detective from the Palm Beach Police Department charged with investigating Epstein. That investigation commenced in 44

Case 18-2868, Document 287, 08/09/2019, 2628251, Page45 of 76 2005. Recarey worked only on the Epstein case for an entire year. He reviewed previous officers’ reports and interviews, conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance footage of the Epstein home, participated in and had knowledge of the search warrant executed on the Epstein home, and ee regarding the case before the Florida state grand jury against Epstein. Recarey’s investigation revealed that not one of the alleged Epstein victims ever mentioned Maxwell’s name and she was never considered a suspect by the Government. None of Epstein’s alleged victims said they had seen Maxwell at Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her, nor told what to wear or how to act by her. Indeed, none of Epstein’s alleged victims ever reported to the Government they had met or spoken to Maxwell. Maxwell was not seen coming or going from the house during the law enforcement surveillance of Epstein’s home. The arrest warrant did not mention Maxwell and her name was never mentioned, before Ww the grand jury. No property belonging to Maxwell, including “sex toys” or “child pornography,” was seized from Epstein’s home during execution of the search warrant. Recarey, when asked to describe “everything that you believe you know about Ghislaine 45

Case 18-2868, Document 287, 08/09/2019, 2628251, Page46 of 76 Maxwells sextial trattichmng conduct,” réeplicd,. “1 don’t.” He confirmed he has no knowledge about Maxwell sexually trafficking anybody. Recarey also has no knowledge of Giutfire’ s conduct. thar is subject of this.lawsuit. Giuffre has denied the statement and noted Chat Recarey wanted to speak to Maxwell, but she did not return his calls and he concluded that Maxwell’s role was to procure girls for Epstein. Giuffre further noted that in the execution of he... search warrant, stationary was found in the home bearing Maxwell’s name, and notes wens written by house staff to Maxwell and message pads uncovered in trash pulls revealing numerous calls left at the house for Maxwell, indicating she was staying in the house during the days when Epstein was engaging in illegal sex acts with minors. Giuffre further noted that a walk through video taken during the execution of the search warrant revealed photos of topless females at the home, anc luding: 2 photograph of Maxwell naked hanging in the home. Alfredo Rodriguez (“Rodriguez”), the house butler from 2004 through 2005, a time period hat included daily sexual abuse of underage females, testified that Maxwell kept a list of the local girls who were giving massages at her desk, and that Maxwell kept nude photos of girls on her computer. Giuffre states that Recarey 46

Case 18-2868, Document 287, 08/09/2019, 2628251, Page47 of 76 testified that when the search warrant was executed, the house had been sanitized and the computers removed from the home. Giuffre states that the co-conspirator who maintained direct contact with the many underage victims was Kellen, whose sole responsibility was to schedule underage girls to Visit Epstein for sex and reported directly to Maxwell. Figueroa testified that Maxwell personally requested that he find and bring girls to Epstein for sex once Giuffre had escaped, and that when he brought the girls Maxwell interacted with them, that Maxwell was “the boss” and that she knew re that was going on. 47. No nude ehovogucen of Giuffre was displayed in Epstein’s home. Epstein’s housekeeper, Alessi, “never saw any photographs of Virginia Roberts [Giuffre] in Epstein’ s house.” Recarey entered Epstein’s home in 2002 to install SeCuriLy cameras to catch a thief and did not observe any “child pornography” within the home, including on Epstein’s desk in his office. Giuffre has denied this statement and noted that Maxwell had pornography on her computer, that there was a 47]

Case 18-2868, Document 287, 08/09/2019, 2628251, Page48 of 76 collage of nude photos in Epstein’s closet, that the collage was taken into evidence by Recarey, who testified to that fact in his. Gepost c10n, tana R1iZZO, a visitor to the home on numerous occasions, was reprimanded by Maxwell for looking at the nude photos, ad eet the search warrant revealed photographs of nudity displayed, including a photograph of Maxwell herself in the nude. Sjorberg testified that Maxwell bought her a eanees for the specific purpose of her taking nude photos of herself and Giuffre has testified that there was a nude photograph of ner at the house. 48. Giuffre drafted a “4 ournal” describing individuals to whom she claims she was sexually trafficked as well as her memories and thoughts about her experiences with EoSstéeéin. In 2Z0io, She ad Hee husband created a bonfire in her backyard in Florida and burned the journal together With Other documents in her possession. Giuffre also kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016. To date, Giuffre cannot locate the “dream TOuUrina ta 49. Giuffre publicly peddled her story beginning in 2011. Giuffre granted journalist Churcher extensive interviews 48

Case 18-2868, Document 287, 08/09/2019, 2628251, Page49 of 76 that resulted in seven widely distributed articles from March . 2011 through January 2015. Churcher regularly communicated with Giuffre and her “attorneys or other agents” from “early 2011” to “the present day.” Giuffre received approximately s160,;,000 tor her stories and pictures that were published pyc news organizations. Giuffre has denied this statement in part and admitted ie au pare; WOring thac. an-2011, Giutire was suit) a Cae from Epstein and Maxwell in Australia and not looking to sell anything or even speak with anyone about what had happened to her. Churcher located Giuffre and impressed the importance oF Giuffre seancins up to enece who had harmed her and speaking with federal authorities. Giuffre did so in 2011, bringing the abuse of Maxwell and Epstein to public light to prevent their continued abuse of others. Giuffre agreed to be interviewed by Churcher and was compensated for sharing her story, which came at the neavy price of being publicly scrutinized. 50. Giuffre drafted a 144-page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, Giuffre drafted a book manuscript which purported to 49

Case 18-2868, Document 287, 08/09/2019, 2628251, Page5O of 76 document Giuffre’s experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. Giuffre communicated with literary agents, ghost writers, and potential independent publishers in an effort to get her book published. She generated marketing materials and circulated those along with book chapters to numerous individuals associated with publishing and the media. Giuffre has denied the statement in part and admitted i on pare, Starving cake she received €@ Victim Notification Letter from the United States Attorney’s office for The southern District of Florida regarding her sexual victimization by | Epstein, that in 2011 she sought psychological counseling £ron..a psychologist for the trauma she endured, and that also that year Churcher sought her out and interviewed her. Giuffre was interviewed by the FBI in 2011. Giuffre has noted that she began to draft a fictionalized account of what happened to her as an act of empowerment and a way of reframing and taking control over the narrative of her past abuse that haunts her and, while she explored trying to publish her story to empower other individuals who were subject to abuse, she ultimately decided now ~O. publish 1c. ou

Case 18-2868, Document 287, 08/09/2019, 2628251, Page51 of 76 Bi. The CVRA [6inder motion tiled by Giurcire generated a media maelstrom and spawned highly DUubLIC.ized litigation between Giuffre’s lawyers — Bradley Edwards (“Edwards”) and Paul Cassell (“Cassell”) — and Dershowitz. After Giuffre publicly accused Dershowitz of sexual MiLSConauct, Dershowitz vigorously defended himself in the media. He called Giuffre a liar and accused her lawyers of unethical conduct. In response, Edwards and Cassell sued Dershowitz, who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organization. Giuffre has denied the statement as set forth in Statement /. 52. Giuffre formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, Giuffre, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to Giuffre, the purpose of the organization 1s to promote Giuffre’s professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual oa

/ es Case 18-2868, Document 287, 08/09/2019, 2628251, Page52 of 76 A6use: Grarire Srbemous to. promote Victims Reruse Silence av every opportunity. For example, Giuffre participated in an interview in New York with ABC to promote the charity and to get her Mission cue to the public. Giuffre has denied that she formed the non-profit Victims Refuse Silence to “speak out on a public controversy,” and noted she sought to help survivors of sexual abuse and sexual trafficking and in order to provide assistance to victims, she attempted to talk about the non-profit’s mission when she had the opportunity to do so. Oe The Applicable Standard Summary judgment is appropriate only where “there is no genuine issue as to any material fact and. . . the moving party is entitled to a judgment as a matter of law.” Fed. R. Civ. P. 56(c). “[T]he substantive law will identify which facts are material.” Anderson v. Liberty Lobby, inc., 4171] US. 242, 248 (1986). A dispute is “genuine” if “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” oF

. Case 18-2868, Document 287, 08/09/2019, 2628251, Page53 of 76 Id. The relevant inguiry on application for summary Judgment 1s “whether the evidence presents a sufficient disagreement to require submission to a jury or whether it 1s so one-sided that one party must prevail as a matter of law.” Id. at DOV 2 court is not charged with weighing the evidence and Aeon its truth, but with determining whether there is a genuine issue for trial. Westinghouse Elec. Corp. v. N.Y. City Transit Auth., 135 f, Supp. 1205, 1212 152 D.Nets 2920) (quoting Anderson, 471 U.S. at 249). “[T]he mere existence of some alleged factual dispute between the parties will not defeat an otherwise properly supported motion for summary judgment; the requirement is that there be no genuine issue of material fact.” Anderson, ATT 0S. ae 247-48. (emphasis in Original). While the moving party bears the initial. burden oF showing that no genuine issue of material fact exists, Atl. Mut. THs. Co. ww: CSX tines. Iob«C., G32 Peed 4228, 233. (2d. Cir. 2002), in cases where the non-moving party bears the burden of persuasion at trial, “the burden on tne moving party may be discharged by ‘showing’—that is, pointing out to the di sterice court-that there is-an absence of evidence to support the nonmoving party’s case.” Celotex Corp. v. Catrett, Ay Ueos, SLL, 325 (1986). “It is ordinarily sufficient for the movant to DOLNt So

Case 18-2868, Document 287, 08/09/2019, 2628251, Page54 of 76 to a lack of evidence .. . on an essential element of the nonmovant’s claim... . [T]he nonmoving party must [then] come forward with admissible evidence sufficient to raise a genuine issue of fact for trial .. . .” Jaramillo v. Weyerhaeuser Co., 5636 h.c0 140, 145 (2d. Cir. 2002) (iancernal Gitacilonus Omi oled); see also Goenaga v. March of Dimes Birth Defects Found., 51 F.3d 14, 18 (2d Cir. 1995) (“Once the moving party has made a properly supported showing sufficient to suggest the absence of any genuine issue as to a material fact, the nonmoving party must come forward with evidence that would be sufficient to support a jury verdict in his favor”). IV. The Motion for Summary Judgment on Republication Grounds is Denied Maxwell has moved for summary judgment dismissing Giuffre’s complaint on the grounds that Maxwell ee Oe jee ose for the republication of her Press Release by the media. Because as a matter of law the issuer of a pisos wolease is responsible for its publication, the motion is denied. In New York, liability for a republication “must be based on real authority to influence the final product.” Davis 54

Case 18-2868, Document 287, 08/09/2019, 2628251, Page55 of 76 V, Cosea=CGavres. 5SC EF. Supp. 1032, 1096 (S.D.N.%. 12904)7 see also Hoffman v. Landers, 146 A.D.2d 744, 747 (N.Y. App. Div. 2d Dep’t 1989) (“One who makes a defamatory sea cneue LS: Oc responsible for Lees Pecommuni carton. withouc: his aubhority or request by another over whom he has nO CONnLCrOL.”). Where a defendant “had no actual part in composing or publishing,” he cannot be held liable “without disregarding the settled eat Ce law that no man is bound for the eeretou: act of another over whom he has not a master’s power of control.” Davis, 580 F. Supp. at 1096 (internal quotation marks and citation omitted). The New York Court of Appeals summarized New York’s republication liability standard in Geraci v. Probst, 938 N, 22d 917 (N.Y. 2010), stating that one who .. . prints and publishes a libel[] is not responsible for its voluntary and unjustifiable repetition, without his authority or request, by others over whom he has no control and who thereby make themselves liable to the person injured, and that such repetition cannot be considered in law a necessary, natural and probable consequence of the original slander or libel. 938 N.E.2d at 921 (internal quotation marks and citation omitted). Thus, “conclusive evidence of lack of actual authority [is] sufficiently dispositive that the [court] ‘hal[s] no option but to dismiss the case ... .’” Davis, 580 F. Supp. at 1096 a

Case 18-2868, Document 287, 08/09/2019, 2628251, Page56 of 76 (quoting Rinaldi v. Viking Penguin, Inc., 420 N.E.2d Siig. woe (Neve i toel) 2 However, New York law assigns liability to individuals for the media’s publication of press releases. New York appellate courts have held that an individual is liable for the media publishing that individual’s defamatory press release. See Levy v. Smith, 132 A.D.3d 961, 962-63 (N.Y. App. Div. 2d Dep’t 2015) (“Generally, [o]ne who makes a defamatory statement is not responsible for its recommunication without his Aue hori, OF request by another over whom he has no control... . Here, however, . . . the appellant intended and authorized the republication of the allegedly defamatory content of the press releases in the news articles.”); see also RESTATEMENT (SECOND) OF Torts § 576 (1977) (“The publication of a libel or slander is a legal cause of any special harm resulting from its repetition by a third person if . . . the repetition was authorized or intended by the original defamer, or... the repetition was reasonably to be expected.”) The facts as set forth above establish that Maxwell approved the Press Release. The Press Release was sent to between six and 30 media representatives by Gow as an employee 56

Case 18-2868, Document 287, 08/09/2019, 2628251, Page5/ of 76 of Dciity Reputaticen, the public relations firm hired by Maxwell. The initial sentence of the Press Release —- “Please find attached a quotable seeenent on behalf of Maxwell” communicates Maxwell’s aeomigaeion for the media recipients of the Press Release to publish it. See Nat’ l Puerto Rican Day Parade, Ine. Vv. Casa Pubs.» 1nGs;, 79-2. Ds30 392, 595 (N.Y. App. Div. lst Dep’t 2010) (affirming the refusal to dismiss defamation counts against a defendant who “submitted an open letter that was published in [a] newspaper, and that [the defendant] paid to have the open letter published,” finding that the defendant “authorized [the newspaper] to recommunicate his statements.”). Maxwell has cited Geraci v. Probst in support of her position, but ores is distinguishable from the instant action. In Geraci, the defendant sent a letter to the Board of Fire Commissioners, and, more than three years later, a newspaper published the letter. The court held that the defendant was no liable for that belated ee “made years later without his knowledge or participation.” 938 N.E.2d ae BiG. Here, unlike in Geraci, the Press Release was not published “without [her] authority or request,” but rather with Maxwell’s SULHOLLEY and oO

Case 18-2868, Document 287, 08/09/2019, 2628251, Page58 of 76 by her express request. Gow’s testimony establishes Maxwell’s auEnOuItyY and Conero! Over the Press Release: oF When you sent that email were you acting pursuant Co Ms. Maxwell’s retention of your services? yar Yes, 1 was ke * Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know where the rest of this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine, I’1l go WLoh this.” It 2s my understanding that this is the agreed statement because the subject of the second one is “Urgent, this is the statement” so I take that as an instruction to send it out, as a positive command: “This is the statement.” Maxwell also cites Davis v. Geeta Gaus: involving a libel claim against an author who wrote a book about a military Coup im -Chide. 560 Fe Sipe at 1085. Years after the author published the book, a third-party publishing house republished the book in paperback form and a third-party filmmaker released a movie based on the book. The book author did not actually participate in the republications, though he was aware of the 20

Case 18-2868, Document 287, 08/09/2019, 2628251, Page59 of 76 projects. The court held that the author of the book could nNoU be held liable for the republications, explaining that a “party who is ‘innocent of all complicity’ in the publication of a libel cannot be held accountable.” 580 F. Supp. at 1094 isnvernal .eitacions Omitred).. Ihe Courc furinmer noted that “active participation in implementing the republication resurrects the liability.” Id. Likewise, in Karaduman v. Newsday, Inc., 416 N.E.2d 59/7 (1980), also cited by Maxwell, the court held that reporters of a series of articles on nNereocics trade “cannot be held personally liable for injuries arising from [the] subsequent republication in book form absent a showing that they approved or participated in some other manner in the activities of the third-party republisher.” Id. at 559560. However, the court explicitly noted that this result was reguired because “the record [wa]ls barren of any concrete evidence of the reporters’ involvement in the republication of the newspaper series.” Id. at 540. Here, there. is evidence in the record that Maxwell “actively participated” in influencing the media to publish the Press Release, Davis, 580 F. Supp. at 1094, and “approved” of and sought the publication of the press release, Reads. 416 N.E.2d at 560. Maxwell retained a public relations media oo

Case 18-2868, Document 287, 08/09/2019, 2628251, Page60 of 76 specialist. The Press Release was sent by Maxwell’s enpneee request. Gow’s baae ony about the process leading up to the dissemination of ene Press Release indicates that Maxwell did, indeed, “authorize or intend” for the media recipients to publish the statement. Because there are sufficient facts to demonstrate Maxwell’s authority and control over the publication of the Press Release, Maxwell’s liability for the Press Release’s publication survives the motion for summary judgment. Maxwell has additionally asserted that subjecting her to liability for republication is “particularly unfair” peeaae excerpts of the Press Release, rather than the whole statement, were published. Def.’s Reply at 9. Maxwell cites to Rand v. New York Times Con, 15.0.D.20 217 (ev. Apoyw Div, Tee eo] 1930), in which a newspaper paraphrased the defendant’s opinion, essentially “excis[ing] the opinion from the context in which it was given.” Id. at 424. No similar alteration, sanitization, hyperbolizing, or paraphrasing of Maxwell’s statements has been established here. Nor does the record establish that any statements of Maxwell’s were taken out of context; rather, they were directly aaeted: accurately and unchanged. The publication of Maxwell’s statement that Giuffre’s claims are “obvious lies” 60

Case 18-2868, Document 287, 08/09/2019, 2628251, Page61 of 76 does not distort or misrepresent the message Maxwell intended to convey tO the public with the: Press: Release: Because the purpose-.of the issuance of the Press Release was publication, Maxwell is liable for its content and the motion for summary judgment on the grounds of non-liability for republication is denied. V. The Motion for Summary Judgment to Dismiss the Defamation Claim on the Ground of Substantial Truth is Denied Maxwell has asserted that the Press Release is substantially true and that the defamation claim should therefore be dismissed. See Def.’s Br. at. 39. Whether or nor Giuffre lied about Maxwell’s involvement in the events that Giuffre has alleged took place is the intensely contested factual issue that is the foundation of this sete, Accordingly, summary judgment is not appropriate. See Mitre Sports Intern. Ltd. v. Home Box Office, Inc., 22 F. Supps 32d 240, 255 (S.D.N.Y. 2014) (denying summary judgment because it would require the Court to decide disputed facts to determine whether the statement at issue was substantially true); Da Silva Ve. Time Imc., 90 Fs Stpp. 2e4, 167 (SiDsNate 1979) (denying motion for summary judgment because there was a genuine issue of 61

Case 18-2868, Document 287, 08/09/2019, 2628251, Page62 of 76 material fact as to whether defamatory photo and caption were Erue).< Under New York law, “truth is an absolute, unqualified defense to a civil defamation action” and “‘substantial truth’ suffices to defeat a charge of libel.” Jewell v. NYP Holdings, Inc:, 23 F. Stpps 2d 346, 366 (o.DeNeX. 1998) (internal quotation marks and citations omitted). A statement is substantially true if the statement would not “have a different effect on the mind of the reader from that which the pleaded truth would have produced.” Id. (quoting Fleckenstein v. Friedman, 193 N.E. 537, 538 (N.Y. 1934)). Thus, “it ve, AO necessary to demonstrate complete accuracy to defeat a charge of libel. It is only necessary that the gist or substance of the challenged statements be ae! Printers if, Inc. Vs Professionals Publishing, Inc., 784 F.2d 141, 146 (2d Cir. 1986); see also Korkala v. W.W. Norton & Co., 618 F.Supp. Lo2y 155. (S.DeNeYs 1965) (Shaghe anaccuracies or expression are immaterial provided that the defamatory charge is true i substance.”) (internal quotation marks and citation omitted) ; Sharon v. Time, Inc., 609 F.Supp. 1291, 1294 (S.D.N.Y. 1984) (“Defendant is permitted to prove the substantial truth of Cis statement by establishing any other proposition that has the GZ

Case 18-2868, Document 287, 08/09/2019, 2628251, Page63 of 76 same ‘gist’ or ‘sting’ as the original libel, that 1s, the same effect on the mind of the reader.”). The Honorable Loretta A. Preska has noted that cases addressing whether a statement is substantially true “fall along a broad spectrum.” Jewell, 23 F. Supp. at 367. There are cases a nar a statement is non-actionable because it is completely true. See, e.g., Carter, 233 A.D.2d 473, 474 (N.Y. App. Div. 2d Dep’ & 1996) (claim that defendant committed libel by informing ‘the authorities that plaintiff was endorsing checks made payable to the defendant and depositing them in plaintiff’s account held non-actionable where plaintiff had in fact endorsed checks made payable to the defendant). There are cases where “one struggles to identify any area of ambiguity as to truth.” Jewell, 23 F. Stipp. ab 2607 see, .¢0.,; Miizer y. Journal—-News, 211 A.D.2d 626, 627 (NavY« Apo. Divs 2a septs 1995) (statement that plaintiff was “suspended” substantially true where pieaneees was placed on “administrative leave”). There are cases where the line between the seaecnent and the admitted truth is more tenuous, but the overall “gist” cannot be said to be substantially different. See, e.g., Guccione v. Hustler Magazine, Inc., 600 F.2d. 296, 302-03 (2d Cir. 1986) (holding that statement which implied that. plaintiff was then currently an adulterer was substantially true 63

Case 18-2868, Document 287, 08/09/2019, 2628251, Page64 of 76 where plaintiff had ceased being an adulterer but had “unabashedly committed adultery” for thirteen of seventeen oe Finally, there are “those cases in which a defendant simply asks too much in asserting that a statement 1s substantially true because the difference between the two is plainly substantial.” Jewell, 23 F. Supp. at 368. For example, the court in Da Silva, 908 F. Supp. at 186-87, held that a Photograph Of plaintifit which tda6nti tied .ner as 3 prostitute was not substantially true where the plaintiff had been a prostitute for some Six years but was not at the time of publication. After reviewing this spectrum of cases, the facts upon which Maxwell bases her argument are insufficient to allow this Court to find substantial truth as a matter of law. A material dispute of fact exists as to the “admitted truth” or the “reality” in this case. Maxwell has cited to eacious facts to counter Giuffre’s claims, such as Giuffre’s high school enrollment, short-term jobs, and lack of record on private flight logs during some of the relevant time period, as evidence that Maxwell and Epstein did not abuse Giuffre. The details and significance of the facts offered are highly contested, and therefore cannot establish the “substantial truth” of the Press Reléase. “(Rileasonable Jurors. could Conclude that the statements 64

Case 18-2868, Document 287, 08/09/2019, 2628251, Page65 of 76 are not substantially true.” Boehner v.. Heise, 134 F. SUpes 2c 209, off (ouDelere 2OL0. The motion for summary judgment to dismiss the defamation on the ground of substantial truth is denied as not having been established by undisputed material facts. VI. The Defamation Claim is Not Barred by New York Law Maxwell has moved to dismiss the complaint on the ground that the Press Release is opinion and protected by the pre-litigation privilege under New York law. Because New TOrk law does not support Maxwell’s position, the motion for summary judgment based on the characterization of the Press Release as opinion and as protected by a pre-litigation privilege is denied. Te The Press Release is Not Opinion. As previously held, Maxwell’s statement that GlUrr res claims of sexual assault are lies is not an expression of Opinion: 65

Case 18-2868, Document 287, 08/09/2019, 2628251, Page66 of 76 First, statements that Giuffre’s claims ‘against [Maxwell] are untrue,’ have been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning: that Giuffre is not telling the truth about her history of sexual abuse and [Maxwell]’s role, and that some verifiable investigation has occurred and come to a definitive conclusion proving that fact. Second, these statements (as they themselves allege), are capable of being proven true or false, and therefore constitute actionable face. end nol Opimion. Third, 11 their full context, while [Maxwell]’s statements have the effect of generally denying Giuffre’s story, they also clearly constitute fact to the reader. Giurere. Vv. Maxwell, 165... Sabo. 32d. 147, 152 (SeD.Navs 2010). This Court further conciuded that [Giuffre] cannot be making claims shown to be Untrue that are obvious lies without: being a liar. Furthermore, to suggest an individual is not telling the truth about her history of having been sexually assaulted as a minor constitutes more than a general denial, it alleges something deeply disturbing about the character of an individual willing to be DUDIAclLyY Gishonest. about such a reprehensible crime. [Maxwell]’s | statements clearly imply that the denials are based on facts separate and contradictory to those that [Giuffre] has alleged. i. Maxwell argues that the “context” of the entire statement “tested against the understanding of the average reader” should be that of a press release as a whole being read only by Journalists, Det.’ Bre ae. 22 (quoting Aronson Vv. Wrerema, 483. N.8.20 Lise; 1129 (1985))< However, the ultimate 66

Case 18-2868, Document 287, 08/09/2019, 2628251, Page6/ of 76 audience for a press release is the public. The motion to dismiss opinion clearly addressed this issue: Sexual assault of a minor is a clear-cut issue; either transgression occurred or it did not. Either Maxwell was involved or she was not. The issue is not a matter of opinion, and there cannot be differing understandings of the same facts that justify diametrically opposed opinion as to whether Maxwell was involved in Giuffre’s abuse as Giuffre has claimed. Hither Giuffre is telling the truth about her story and Maxwell’s involvement, or Maxwell is telling the truth and she was not involved in the trafficking and ultimate abuse of Giuffre. Giurire; 165 FP. SupDs ac 1oZz. Maxwell has urged that these conclusions at the motion to dismiss stage should be revisited and revised when considering the summary iedenent ameton Since the standard for deciding a Rule 12(b) (6) motion is different from the standard for deciding a Rule 56 motion. In deciding. 4 12 (b) (6) motion, the court must accept as true the factual allegations and draw all inferences in the plaintiff's favor; a plaintiff need only Stave S Claim. that 2s “plausible on. its tace.” Jd. al. 142 (internal quotation marks and citation omitted). In contrast, for a Rule 56 motion, the plaintiff defending the MOELOnN. May noc “rest on [the] allegations” in her complaint. Anderson, 477 U.S. at 249. 67

Case 18-2868, Document 287, 08/09/2019, 2628251, Page68 of 76 In deciding its motion to dismiss opinion, the Court relied on Davis v. Boeheim, 22 N.E.3d 999 (2014), and held thar the three allegedly defamatory statements in the Press Release have a specific and readily understood factual meaning, are capable of being proven true or false, and “clearly constitute fact to the reader.” Giuffre, 165 F. Supp. at 152. The Court determined that “[t]he dispositive inquiry” for purposes of deciding whether an allegedly defamatory statement is fact or nonactionable opinion is whether “a reasonable reader could have concluded that the statements were conveying facts about the pleintiti.” 14. 40 151 Gnternal quotation marks and citation omitted). To answer that inquiry, three factors enumerated in Davis were applied. See id. These three factors are the same as the four factors in Immuno AG v. Moor-Jankowski, 567 N.E.2d 1270 (N.Y. 1991); the difference is that the Davis court collapsed the Immuno AG’s third and fourth factors into one. See Davis, 22 N.E.3d at 1005. “[T]he critical aspect of the inquiry, as articulated in the third factor set forth above, is to view the statements in context.” Jewell, 23 F. Supp. 2d at 377. This contextual analysis “proceeds on two levels, the ‘broader social setting’ of the statements, as well as their ‘immediate Gonvext.’” Ta. (erting tmmuno; SC) Ns«Bs2d ac. 1200). 68

Case 18-2868, Document 287, 08/09/2019, 2628251, Page69 of 76 Maxwell acknowledges that the Court properly applied Davis at the motion. to dismiss stage, but argues that the third factor, especially, benefits from the evidence presented in. ae motion for summary judgment. See Def.’s Br. at 32. In other words, Uanuetl argues ‘tha “the Court did moe have che *full context’” of the Press Release or the “broader social context and surrounding circumstances of the statement.” Id. At the motion to dismiss stage, the text of the Press Release had not yet been produced, nor had there been production of emails or deposition testimony regarding the Press Release. The developed record necessitates the same conclusion as at the motion to dismiss stage. The context and ueouncing circumstances remain the same. The publication was intended by Maxwell to reach the average reader, not simply the reporters, Barden’s intent, a factual issue in contest, notwithstanding. THe ISSue. GL truth or falsity 1s a factual seceeninatied. Nota matter of opinion. See Giuffre, 165 F. Supp. 3d at oe (“[S]tatements that Giuffre’s claims ‘against [Maxwell] are anenue 2 have been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning.”). 69

Case 18-2868, Document 287, 08/09/2019, 2628251, Page/O of 76 oe The Pre-Litigation Privilege is Inapplicable. Maxwell has contended that the pre-litigation privilege as enunciated in Front, Inc. v. Khalil, 2s Nibwse 15; 16 (N.Y. 2015), applies. See Def.’s Br. at 33. “A privileged communication is one which, but for the occasion on which it is uttered, would be defamatory and actionable.” Park Knoll Assocs. v. Schmidt, 451 N.E.2d 182, 184 (N.Y. 1983). “[I]t is well-settled that statements made in the course of litigation are entitled to absolute privilege.” Front, 28 N.E.3d at 18. The privilege that protects statements made in the course of litigation “can extend to preliminary or investigative stages of the process, particularly where compelling public interests are at stake.” Rosenberg v. MetLife, Inc., 866 N.E.3d 439, 443 (N.Y. 2007). In Front, the New York Court of Appeals ruled that the privilege for “statements made by attorneys prior to the commencement of IeEcgat Om as qualified rather than absolute. Id. at 16. Specitiecally, the Court held that an attorney’s statements made before litigation has commenced are privileged if (1) the attorney has “a good faith basis to anticipate litigation” and (2) the statements are “pertinent to that anticipated litigation.” Id. at 20. fat

Case 18-2868, Document 287, 08/09/2019, 2628251, Page/1 of 76 The anticipated. litigation, according to the Press Release, was “redress at the repetition of such old defamatory claims.” See Press Release. According to Barden, Maxwell’s lawyer, he participated in the preparation of the Press Release, the purpose of the Press Release was to dissuade the media from publishing Giuffre’s allegations, and the implication of the Press Release was that any redress sought by Maxwell would be against the media. Giuffre has disputed Barden’s claim that the Press Release was his own statement. Certain of the cases cited by Maxwell in support of the privilege can be distinguished, according to Giuffre, an that they involve communications to or from parties To the ultimate litigation. See, e.g., Kirk v. Heppt, 532 F. Supp. zd 586, 593 (S.D.N.Y¥. 2008) (the communication at issue was made by an attorney’s client to the attorney’s malpractice carrier concerning the client’s justiciable controversy against the attorney over which the clients actually sued); Black v. Green Harbour Homeowners’ Ass’n, Inc., 19 A.D.3d 962, 963 (N.Y. App. Div. 3d Dep’t 2005) (privilege applied to a letter sent by a home owner’s association board of directors to the association’s members informing them of the status of litigation to which the pa

a Case 18-2868, Document 287, 08/09/2019, 2628251, Page/2 of 76 association was a party). Giuffre contends that “there was no statement made by anyone before the commencement of litigation because litigation never commenced.” See Pl.’S Opp’n at 42. Here, the communication at issue was sent to members of the media, and no litigation took place between Maxwell and the media recipients of the Press Release. However, the pre-litigation privilege is not limited to statements between parties in their lawyers. “While the communications at issue in Front were among lawyers and potential parties, the New York Court of Appeals did not syoiieteie require the recipient of the challenged statements to be a lawyer or potential party.” Feist v. Paxfire, nC, NOs. 1a CIV. 5436 (LGS), 2017 WL 177652, at *5 (S.D.N.Y. Jan. 17, 2017); see Front, 28 N.E.3d at 16-17. The Second Circuit “summarily rejected this interpretation when it applied Front to an attorney’s communications to the press.” See Tacopina v. O" Keetie, 645. F.. App’= 7, @ (20: Cir. 206) (“Even erediting |tne plaintiff]’s allegation that [the attorney] shared the affidavit with the Daily News before filing it in court, Tacopina has still not sustained his burden of showing that the statements were not pertinent to a good faith anticipated litigation.”). t2Z

Case 18-2868, Document 287, 08/09/2019, 2628251, Page/73 of 76 Though a statement made to a non-party may be privileged, the pre-litigation privilege does not apply here because the Press Release cannot be considered a “statement[] made by [an] attorney.” Front, 28 N.E.3d at 16. Whether Maxwell’s attorney, Barden, had a hand in drafting the Press Release, and the extent to which he may have been involved, is a disputed issue of fact. The record evidence establishes that, regardless, the Press Release is properly aclripucablLe co Maxwell. Maxwell retained a public relations firm and sent her representative there, Gow, a eyeeded email with the statements: that were to be used in the Press Release. Maxwell instructed Gow to send it, as he testified in his deposition. While Maxwell herself did not disseminate the email to the media recipients, neither did Barden. The statement was sent out by Gow. Additionally, the alleged defamatory statements in the Press Release were attributed to Maxwell, and not to her attorney or his agents. The email stated that the Press Release was a “statement on behalf of” Maxwell and notified the media recipients that “[n]lo further communication will be provided by her [Maxwell] on this matter.” There is no evidence in the email To

a Case 18-2868, Document 287, 08/09/2019, 2628251, Page/4 of 76 that the Press Release was anything near an attorney’s statement; Barden was not even copied on the email. The pre-litigation privilege is intended to protect attorneys from defamations claims “so that those discharging a public function may speak freely to zealously represent their clients without fear of reprisal or financial hazard.” Id. at 18. Where the statement cannot be attributed to an attorney, there 18 NS 7UStit ication, for protecting 12t.by pravatlece. Hea addition, as this Court, concluded. 1m denying Maxwell’s motion to dismiss, “[t]here is no qualified privilege under New York ieety when such statements are Spoken with malice, knowledge of their falsity, or reckless disregard for their truth.” Giuffre, 165 F. Supp. 3d at 155 (internal quotation marks and citation omitted). It is Giuffre’s eeneeneon that Maxwell knew the statements were false because she engaged in and facilitated the sexual abuse of Giuffre. Therefore, according to Giuffre, they were not made in good faith anticipation, Or litigation, and instead were made tor tie inappropriate purpose of “bullyf[ing],” “harass]ment],” and “Sntimi1dlation|." Gee .eront, 23. NeBe3d ae £9 (2010). ARECOLrAING to Giuffre, there is ample record evidence that Maxwell acted 74

Case 18-2868, Document 287, 08/09/2019, 2628251, Page/5 of 76 with malice in issuing the Press Release, thereby making the pre-litigation privilege inapplicable. Because of the existence of triable issues of material fact rather than opinion and because the pre-litigation privilege is inapplicable, the motion for summary judgment is denied. 12

Case 18-2868, Document 287, 08/09/2019, 2628251, Page/6 of 76 VIL. Conclusion For the reasons set forth above, the motion for summary judgment is denied. The parties are. directed to Jointly file -a proposed redacted version of this Opinion consistent with the Protective Order or notify the Court that none are necessary within one week of the date of receipt of this Opinion. It is so ordered. New York, NY March ) z 2017 OBERT W. SWEET U.S.D.J. 76