DOJ-OGR-00000451.jpg
549 KB
Extraction Summary
4
People
2
Organizations
3
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / court filing (defense letter to judge)
File Size:
549 KB
Summary
This document is page 7 of a defense letter to Judge Berman dated July 16, 2019. It addresses two specific points: 1) Refuting Mr. Boies' speculation that payments in late 2018 were to cooperating witnesses, clarifying instead that they were to employees/friends who invoked the Fifth Amendment; and 2) Dismissing the government's concern over an Austrian passport, noting it expired 32 years ago and was never used. The document emphasizes Epstein's religious background in the context of acquiring said passport.
People (4)
| Name | Role | Context |
|---|---|---|
| Richard M. Berman | Judge |
Recipient of the letter; presiding over the case.
|
| Jeffrey Epstein | Defendant |
Subject of the proceedings; described as an 'affluent member of the Jewish faith'.
|
| David Boies | Third-party counsel |
Referred to as 'Mr. Boies'; speculated about payments made to witnesses.
|
| Unnamed Recipients | Payment Recipients |
Described as 'long-time [Epstein] friends and employees' who invoked the Fifth Amendment.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
Raised issues regarding an Austrian passport.
|
|
| DOJ |
Indicated in footer stamp (DOJ-OGR).
|
Timeline (3 events)
2018-11-28
2018-12-03
Unknown (Prior to 2019)
Civil depositions where recipients invoked the Fifth Amendment.
New York and Florida
Payment Recipients
Mr. Boies
Relationships (2)
Described as 'long-time [Epstein] friends and employees'
Mr. Boies
→
Adversarial/Legal
→
Payment Recipients
Recipients refused to cooperate with Mr. Boies and invoked the Fifth Amendment
Key Quotes (4)
"recipients were “long-time [Epstein] friends and employees” – not putative victims"Source
DOJ-OGR-00000451.jpg
Quote #1
"each invoked the Fifth Amendment and refused to testify when civilly deposed"Source
DOJ-OGR-00000451.jpg
Quote #2
"as for the Austrian passport the government trumpets, it expired 32 years ago"Source
DOJ-OGR-00000451.jpg
Quote #3
"Epstein – an affluent member of the Jewish faith"Source
DOJ-OGR-00000451.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,141 characters)
Case 1:19-cr-00490-RMB Document 24 Filed 07/16/19 Page 7 of 9
Hon. Richard M. Berman
July 16, 2019
Page 7
July 16, 2019
Page 7
Seventh, to the extent third-party counsel (Mr. Boies) speculated
that the November 28 and December 3, 2018 payments⁸ were 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.
that the November 28 and December 3, 2018 payments⁸ were 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
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
__________________
⁸ 7/12/19 Ltr. 11.
⁹ 7/15/19 Tr. 70-71.
¹⁰ Ibid. 69.
⁸ 7/12/19 Ltr. 11.
⁹ 7/15/19 Tr. 70-71.
¹⁰ Ibid. 69.
DOJ-OGR-00000451
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