DOJ-OGR-00000437.jpg

579 KB

Extraction Summary

3
People
0
Organizations
3
Locations
2
Events
2
Relationships
2
Quotes

Document Information

Type: Legal document
File Size: 579 KB
Summary

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.

People (3)

Name Role Context
Richard M. Berman Honorable (likely a Judge)
The document is addressed to Hon. Richard M. Berman.
Epstein
Mentioned in relation to his friends and employees, and his acquisition of an Austrian passport.
Mr. Boies
Mentioned as someone with whom Epstein's friends and employees did not cooperate.

Timeline (2 events)

1980s
Epstein acquired an Austrian passport for personal protection during travel to the Middle East.
Witnesses, described as Epstein's friends and employees, invoked the Fifth Amendment and refused to testify in prior New York federal and Florida state civil proceedings.
New York and Florida
Epstein's friends and employees

Locations (3)

Location Context
Location of prior federal civil proceedings.
Location of prior state civil proceedings.
Mentioned in connection to travel during the 1980s when hijackings were prevalent.

Relationships (2)

Epstein professional and personal unnamed individuals
The document describes certain individuals as 'long-time [Epstein] friends and employees'.
Mr. Boies adversarial (in a legal context) Epstein's friends and employees
The document states that Epstein's friends and employees 'never cooperated with Mr. Boies' and 'invoked the Fifth Amendment and refused to testify when civilly deposed'.

Key Quotes (2)

"witnesses who were cooperating with us"
Source
— unspecified (A claim being refuted in the document.)
DOJ-OGR-00000437.jpg
Quote #1
"long-time [Epstein] friends and employees"
Source
— unspecified (Description of the recipients of payments, refuting the claim they were cooperating witnesses.)
DOJ-OGR-00000437.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (1,190 characters)

Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 7 of 9
Hon. Richard M. Berman
July 16, 2019
Page 7
made to “witnesses who were cooperating with us”9 in civil litigation, he
is wrong. As explained in Court, the recipients were “long-time [Epstein]
friends and employees” 10 – not putative victims – and they never
cooperated with Mr. Boies. To the contrary, each invoked the Fifth
Amendment and refused to testify when civilly deposed, respectively, in
prior New York federal and Florida state civil proceedings. Subject to the
protective orders in these proceedings, we would be pleased to provide
relevant deposition transcripts.
Eighth, as for the Austrian passport the government trumpets, it
expired 32 years ago. And the government offers nothing to suggest – and
certainly no evidence – that Epstein ever used it. In any case, Epstein –
an affluent member of the Jewish faith – acquired the passport in the
1980s, when hijackings were prevalent, in connection to Middle East
travel. The passport was for personal protection in the event of travel to
dangerous areas, only to be presented to potential kidnapers, hijackers
9 7/15/19 Tr. 70-71.
10 Ibid. 69.
DOJ-OGR-00000437

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