This legal document, dated July 16, 2019, is a filing addressed to Hon. Richard M. Berman. It argues two points on behalf of Epstein: first, that certain individuals were not cooperating witnesses but rather long-time friends and employees who invoked the Fifth Amendment in prior civil proceedings, and second, that an expired Austrian passport acquired by Epstein in the 1980s was for personal protection during travel and there is no evidence it was ever used.
| Name | Role | Context |
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| Richard M. Berman | Honorable (likely a Judge) |
The document is addressed to Hon. Richard M. Berman.
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| Epstein |
Mentioned in relation to his friends and employees, and his acquisition of an Austrian passport.
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| Mr. Boies |
Mentioned as someone with whom Epstein's friends and employees did not cooperate.
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| Location | Context |
|---|---|
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Location of prior federal civil proceedings.
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Location of prior state civil proceedings.
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Mentioned in connection to travel during the 1980s when hijackings were prevalent.
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"witnesses who were cooperating with us"Source
"long-time [Epstein] friends and employees"Source
Complete text extracted from the document (1,190 characters)
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