DOJ-OGR-00030275.tif
41.6 KB
Extraction Summary
10
People
1
Organizations
2
Locations
5
Events
5
Relationships
6
Quotes
Document Information
Type:
Court document
File Size:
41.6 KB
Summary
This document, a court filing from September 17, 2009, details the events surrounding an attempted deposition of Epstein that was ultimately cancelled. Epstein's attorneys initially decided he would not attend, but he later attempted to leave the building and watch via video feed, only to encounter the Plaintiff at the exit, leading to the deposition's cancellation due to the Plaintiff's distress.
People (10)
| Name | Role | Context |
|---|---|---|
| Epstein | Defendant |
Subject of deposition, instructed to leave building, exited in separate elevator, intended to exit through front door...
|
| Mr. Luttier | Counsel/Partner |
Waited for deposition, exited elevator with 'the undersigned', partner of 'the undersigned', present with court repor...
|
| Igor Zinoviev | Epstein's driver |
Exited in separate elevator with Epstein, mentioned in affidavit Exhibit 4 and 5.
|
| Plaintiff | Plaintiff |
Present at the front door, one of two women seen by Epstein, upset by seeing Epstein, resulting in deposition cancell...
|
| Adam Horowitz | Esq. |
Announced that the deposition was not going to take place.
|
| Mr. Hill | Representative |
Present for the deposition on behalf of C.M.A.
|
| Adam Langino | Representative |
Present for the deposition on behalf of B.B.
|
| William Berger | Representative |
Present for the deposition on behalf of three Plaintiffs.
|
| the undersigned | Author/Party to the case |
Waited for deposition, exited elevator with Mr. Luttier, unaware of incident until Adam Horowitz announced it, presen...
|
| Jeffrey Epstein | Affiant |
Affidavit mentioned as Exhibit 4.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| C.M.A. |
Represented by Mr. Hill at the deposition.
|
Timeline (5 events)
Unknown (prior to 2009-09-17)
Attempted deposition of Epstein. Epstein and his driver, Igor Zinoviev, exited in a separate elevator to leave the building. Epstein intended to exit through the front entrance to go home and watch the deposition via video feed.
Deposition location
Unknown (prior to 2009-09-17)
Adam Horowitz, Esq. announced that the deposition was cancelled because Epstein and his client (Plaintiff) saw one another, and the client was upset.
Deposition location
Unknown (prior to 2009-09-17)
Presence of court reporter, videographer, Mr. Hill (for C.M.A.), Adam Langino (for B.B.), and William Berger (for three Plaintiffs) for the deposition.
Deposition location
Locations (2)
| Location | Context |
|---|---|
|
Epstein exited through doors to this area.
|
|
|
Epstein's intended destination to watch deposition via video feed.
|
Relationships (5)
Mr. Luttier is Epstein's counsel/partner
Igor Zinoviev is Epstein's driver
Epstein saw the Plaintiff, causing upset and cancellation of deposition
The undersigned and his partner, Mr. Luttier
affidavit of Jeffrey Epstein and Igor Zinoviev
Key Quotes (6)
"As of 1:00 p.m., no order had been received from the court, so Epstein's attorneys, in good faith, decided that Epstein would not attend the deposition (as per the agreement), if we chose to proceed, which we were doing."Source
DOJ-OGR-00030275.tif
Quote #1
"Counsel instructed Mr. Epstein to leave the building."Source
DOJ-OGR-00030275.tif
Quote #2
"Clearly, Defendant and his counsel simply wish to have meaningful discovery."Source
DOJ-OGR-00030275.tif
Quote #3
"Completely unbeknownst and unexpected by anyone, apparently the Plaintiff and her attorney(s) were at the front door where Mr. Epstein was intending to exit."Source
DOJ-OGR-00030275.tif
Quote #4
"Upon seeing two women, one who might be the Plaintiff, Mr. Epstein immediately made a left turn and exited through a separate set of doors to the garage area."Source
DOJ-OGR-00030275.tif
Quote #5
"The entire incident was completely unknown to the undersigned and Mr. Luttier until Adam Horowitz, Esq. came in and announced that the deposition was not going to take place in that Mr. Epstein and his client saw one another, she was upset and therefore the deposition was cancelled from his perspective."Source
DOJ-OGR-00030275.tif
Quote #6
Full Extracted Text
Complete text extracted from the document (1,927 characters)
Case 9:08-cv-80119-KAM Document 305
Entered on FLSD Docket 09/17/2009
Page 3 of 8
9.
As of 1:00 p.m., no order had been received from the court, so Epstein's
attorneys, in good faith, decided that Epstein would not attend the deposition (as per the
agreement), if we chose to proceed, which we were doing. The undersigned and Mr. Luttier
specifically waited until just after 1:00 o'clock, the time that the deposition was to start, prior to
leaving with Mr. Epstein. Counsel instructed Mr. Epstein to leave the building. Clearly,
Defendant and his counsel simply wish to have meaningful discovery.
10.
The undersigned and Mr. Luttier exited the elevator heading toward the
deposition room and Mr. Epstein and his driver, Igor Zinoviev exited in separate elevator at the
same time and turned to depart from through the front entrance such that he could go to his home
to watch the deposition and assist counsel, from a video feed.
11. Completely unbeknownst and unexpected by anyone, apparently the Plaintiff and
her attorney(s) were at the front door where Mr. Epstein was intending to exit. Upon seeing two
women, one who might be the Plaintiff, Mr. Epstein immediately made a left turn and exited
through a separate set of doors to the garage area. See affidavit of Jeffrey Epstein and Igor
Zinoviev, Exhibit 4 and 5, respectively.
12.
The entire incident was completely unknown to the undersigned and Mr. Luttier
until Adam Horowitz, Esq. came in and announced that the deposition was not going to take
place in that Mr. Epstein and his client saw one another, she was upset and therefore the
deposition was cancelled from his perspective.
13. The undersigned and his partner, Mr. Luttier, had a court reporter and a
videographer present. Additionally, Mr. Hill on behalf of C.M..A., Adam Langino on behalf of
B.B., William Berger on behalf of three Plaintiffs were present for the deposition.
3
03956-10987
DOJ-OGR-00030275
Entered on FLSD Docket 09/17/2009
Page 3 of 8
9.
As of 1:00 p.m., no order had been received from the court, so Epstein's
attorneys, in good faith, decided that Epstein would not attend the deposition (as per the
agreement), if we chose to proceed, which we were doing. The undersigned and Mr. Luttier
specifically waited until just after 1:00 o'clock, the time that the deposition was to start, prior to
leaving with Mr. Epstein. Counsel instructed Mr. Epstein to leave the building. Clearly,
Defendant and his counsel simply wish to have meaningful discovery.
10.
The undersigned and Mr. Luttier exited the elevator heading toward the
deposition room and Mr. Epstein and his driver, Igor Zinoviev exited in separate elevator at the
same time and turned to depart from through the front entrance such that he could go to his home
to watch the deposition and assist counsel, from a video feed.
11. Completely unbeknownst and unexpected by anyone, apparently the Plaintiff and
her attorney(s) were at the front door where Mr. Epstein was intending to exit. Upon seeing two
women, one who might be the Plaintiff, Mr. Epstein immediately made a left turn and exited
through a separate set of doors to the garage area. See affidavit of Jeffrey Epstein and Igor
Zinoviev, Exhibit 4 and 5, respectively.
12.
The entire incident was completely unknown to the undersigned and Mr. Luttier
until Adam Horowitz, Esq. came in and announced that the deposition was not going to take
place in that Mr. Epstein and his client saw one another, she was upset and therefore the
deposition was cancelled from his perspective.
13. The undersigned and his partner, Mr. Luttier, had a court reporter and a
videographer present. Additionally, Mr. Hill on behalf of C.M..A., Adam Langino on behalf of
B.B., William Berger on behalf of three Plaintiffs were present for the deposition.
3
03956-10987
DOJ-OGR-00030275
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