EFTA00016311.pdf

Type: pdf
Source set: data-set-8
Extracted text

From: Jack Scarola  
To: ' 9
Cc: "I 
V  
> 
Subject: Re: 12/04/09 
. vs Epstein Deposition Transcript 
Date: Mon, 14 Sep 2020 18:35:38 +0000 
' 
(USANYS)" 
I am unaware of any protective order relating to the 
case. 
On Sep 14, 2020, at 12:10 PM, 
Jack, 
 l> wrote: 
Are you able to tell us whether there was a protective order entered in the civil suit, or any other type of agreement that 
would govern disclosing materials from the civil case with us? When you shared the deposition, we assumed there were 
no such restrictions, but I wanted to check. 
Thanks, 
From: Jack Scarola 
Sent: Thursday, September 10, 2020 3:46 PM 
To: 
1 < 
Cc: 
< 
Subject: Re: 12/04/09 
. vs Epstein Deposition Transcript 
Please let me know if you are able to locate the transcript. 
On Sep 10, 2020, at 11:30 AM, 
Jack, 
(USANYS) < 
wrote: 
Thanks for your email. We will likely reach out to your adversary in the deposition to ask for a copy, but I wanted to check 
to see whether you had already done so. 
Thanks, 
From: Jack Scarola 
Sent: Wednesday, September 9, 2020 9:53 AM 
To: 
I<
).; 
(USANYS)<
> 
Subject: Fwd: 12/04/09 
vs Epstein Deposition Transcript 
> 
The email exchange below confirms our inability to locate the first volume of 
deposition. However, attached are 
fairly detailed notes of Paralegal/Investigator Mike Danchuk, who attended the deposition and recorded these notes 
EFTA00016311


contemporaneously. 
appears to have held nothing back, and the notes certainly paint a picture of the kind of 
troubled young women who were particularly susceptible to Epstein's pattern of recruitment, grooming and 
victimization. 
Sent from my iPad 
Begin forwarded message: 
From: "Chris R. Rodgers" 
Date: September 8, 2020 at 3:30:51 PM EDT 
To: Jack Scarola 
Cc: Mary McCann .‘c
a, "Wendy P. Calvet" c 
>, 
"[email protected]" <cmaysepste ineta lz6385257@ projects.fileyi ne.com> 
Subject: FW: 12/04/09 
. vs Epstein Deposition Transcript 
Jack, below is the "Unable …
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