This document is a legal response filed on November 28, 2009, by Plaintiff Carolyn M. Andriano (Jane Doe No. 2) in her civil case against Jeffrey Epstein. The filing opposes a motion by third-party witness Igor Zinoview—Epstein's driver, bodyguard, and trainer since November 2005—who sought to avoid being deposed by claiming he had no knowledge of relevant facts. The Plaintiff argues that Zinoview must be deposed because he worked for Epstein during the active Palm Beach Police investigation (2005-2006) and likely possesses knowledge regarding activities at the Epstein residence, especially since Epstein himself invoked the Fifth Amendment.
This document is a response filed by Plaintiff Carolyn M. Andriano on November 28, 2009, opposing a motion by third-party witness Igor Zinoview to prevent his deposition. Zinoview, who worked as Epstein's driver, bodyguard, and trainer starting in November 2005, claims he has no relevant knowledge of legal matters involving Epstein. The Plaintiff argues that because Zinoview worked for Epstein during the active police investigation (2005-2006), he likely possesses relevant information regarding activities at the Epstein residence, and that a complete bar on his deposition is legally unjustified.
This document is an email chain from March 2019 involving an Assistant United States Attorney from the Southern District of New York. The AUSA is investigating Epstein and requests a copy of a search warrant affidavit and order for the Epstein residence that was executed by local authorities prior to FBI involvement. The recipient confirms they have the document and agrees to email it the following morning.
This document is an email chain from March 2019 between an Assistant United States Attorney from the Southern District of New York and an FBI agent (likely Miami division). The AUSA requests a copy of a specific search warrant affidavit and order for the Epstein residence that was originally executed by local authorities before the FBI took over the case. The FBI agent agrees to send it but experiences a delay due to being out of the office.
This document packet contains legal correspondence from May 2007 regarding subpoenas issued to Epstein-affiliated companies JEGE, Inc. and Hyperion Air, Inc. Attorney Jack Goldberger confirms a deadline extension and clarifies that he, Lilly Ann Sanchez, and Gerald Lefcourt are representing the corporations. The packet also includes an inventory of audiotapes (likely wiretaps or controlled calls) with quality notes, and a handwritten breakdown of phone records analyzing calls to and from the 'Epstein Residence' and other redacted parties.
A photograph (Exhibit EFTA00003530) depicting Jeffrey Epstein blowing out candles on a birthday cake. He is seated at a table with Peter Mandelson and another unidentified man. The date is likely January 20th (Epstein's birthday), and a phone on the table suggests it is a Saturday, placing the event likely in 2001 or 2007.
This document is a photograph marked with the evidence tag EFTA00003462. It depicts an unidentified male standing casually in a long, luxurious hallway with wooden floors and arched architecture, believed to be the interior of Jeffrey Epstein's Palm Beach residence. No other text or data is present in the image.
A candid photograph (oriented sideways) depicting Jeffrey Epstein lying prone on a wooden floor adjacent to an area with black and white checkered tiling. A small brown and white dog is sitting on the checkered floor looking towards the camera. The only text present is the Bates stamp 'EFTA00003442' in the corner.
This document is a photograph labeled with the identifier EFTA00003173. It depicts a casual scene inside an opulent residence featuring Ghislaine Maxwell holding a camera and an unidentified male guest eating french fries while wearing a distinctive shiny shirt. The setting includes classical columns and expensive interior decor.
A color photograph showing Jeffrey Epstein playing a grand piano in a luxuriously decorated room with gold and blue curtains. He is dressed casually in a grey sweatshirt and sweatpants with 'MARINES' written down the leg. The image is marked with the Bates stamp EFTA00003165.
An evidence photograph showing an empty white built-in shelving alcove. A bundle of tangled black, white, and blue cables (likely coaxial, ethernet, or AV wiring) sits at the bottom of the lower shelf near an electrical outlet. The surrounding wall features a decorative faux-marble or stone finish. The image is marked with the evidence identifier EFTA00002960 in the bottom right corner.
This is a photograph of a desk setup, likely taken during a law enforcement search of a Jeffrey Epstein property. The image shows an Apple iMac, keyboard, mouse, a white Panasonic landline phone, and distinctive orange leather desk accessories (blotter, folder, organizer). Personal items such as a white baseball cap, glasses, and a piece of coral are also visible. In the background and reflection, individuals in law enforcement attire can be seen processing the scene. The only readable text is the evidence tag identifier EFTA00002895.
This document is an evidentiary photograph (EFTA00002049) showing the interior hallway of a residence. The image features a framed painting depicting three nude women floating on inner tubes in water. Other visible elements include an orange bench, a white door with a sign partially reading 'not ... M !!!!', and a yellow sticky note labeled 'D' on a doorframe, likely serving as a law enforcement evidence marker.
This is an evidence photograph (marked EFTA00002039) depicting the interior of a bedroom, likely within one of Jeffrey Epstein's properties. The room features white painted wood ceilings, a white four-poster bed frame, a multicolored chevron rug, a white dresser with abstract art above it, a white wicker chair, and a portable dehumidifier or air purifier. A white bathrobe is visible hanging on the door of an adjacent room (likely a bathroom or closet). Yellow evidence markers (sticky notes) are visible on the bed frame and wall. As this is a photograph, there is no textual document content to extract beyond the evidence tag.
A photograph showing a large black chalkboard, likely from Jeffrey Epstein's New York mansion, covered in handwritten notes, diagrams, and lists. The text includes abstract concepts like 'Power', 'Deception', 'Beauty', and 'Matrix', alongside a list of prominent historical mathematicians and physicists including Leibniz, Heisenberg, Turing, and Hilbert. The board also features sketches of a bell curve and geometric grids.
This document is an evidence photograph (Bates stamp EFTA00001953) showing a collection of approximately 12-13 framed pictures laid out on a wooden floor, likely during a police raid or search. The photos depict various scenes, including groups of people, individuals in swimwear, a person in a 'Snow White' costume, and people standing near a private aircraft. The faces of the individuals in the photographs have been redacted with black boxes to protect identities, though one man in a blue/yellow frame resembles Jeffrey Epstein. Stacks of additional frames or albums are visible in a cabinet in the background.
This document is an evidence photograph (marked EFTA00001943) depicting the interior of a closet at an Epstein property. The closet contains shelves with personal items, including Elgydium toothpaste and T/Gel shampoo, as well as a blue massage table or mat. On the floor, several framed personal photographs are laid out; however, the faces of the individuals in these photos have been redacted by law enforcement.
An evidence photograph showing a gloved hand removing a stack of photographs from a wooden cabinet or shelf. The top photograph in the stack depicts a person seated in a wicker chair, but their face and another area are obscured by black redaction boxes. A manila folder in the foreground bears the partial handwritten text 'ECTIVES ET' and 'PINTO -'. The image is stamped with the identifier EFTA00001914.
This is an evidence photograph (marked EFTA00001906) showing a desk setup. The image displays an Apple iMac computer (screen off), a white Apple keyboard, an orange leather notebook/folder, a Logitech audio control unit, a Logitech remote, a scented candle (labeled CERA), three pairs of glasses (one reading, two sunglasses), and a black sculpture. A gloved hand is visible in the top left corner, indicating the photo was taken during a forensic search or raid.
An evidence photograph showing the interior of a room equipped with a yellow dental chair and white medical/dental machinery (appearing to be Castellini brand). The room features hardwood floors, a framed picture of Asian architecture on the left wall, a small decorative mask on the right wall, and an open closet stocked with various medical or cleaning supplies. The image is stamped with the file identifier EFTA00001860.
An evidence photograph (Bates stamped EFTA00001846) depicting a wooden cabinet shelf containing two framed personal photographs, a bronze lizard figurine, and a small rectangular box. The left photo shows a woman with long dark hair (face redacted). The right photo shows a man resembling Jeffrey Epstein seated in a private jet interior wearing a white sweatshirt, next to another individual who has been redacted. Books are visible in the cabinet above.
An evidence photograph (labeled EFTA00001828) depicting the interior of a luxurious room, likely a library or study within one of Jeffrey Epstein's properties. The room is distinguished by floor-to-ceiling wooden bookshelves, a ceiling painted to look like a blue sky with clouds, a classical bronze statue, and a large white desk or table. A blue industrial air mover is situated on the floor near the window.
The document is a photograph of the interior of a residence, featuring a view through a set of open wooden doors. The view reveals a hallway or room with wooden flooring, ornate columns or cabinetry on the right, and a window at the far end. There is a silhouette of an object or person visible against the light of the window. The only text present is the evidence identification number 'EFTA00001825' in the bottom right corner.
An evidence photograph showing the interior of a bathroom with blue walls. The image features a white toilet and a landline telephone placed on a small wooden stool next to it. The document is marked with the evidence identifier EFTA00001793.
This document is a photograph of an interior space, likely within Jeffrey Epstein's Manhattan townhouse. It depicts a hallway or foyer featuring a beige stone floor with dark diamond accents, elaborate white walls with gold trim, and a dark wooden staircase. Furniture includes two fuzzy cream-colored armchairs and a small round table holding a chess set. A white bust sculpture is partially visible on the right. The only text present is the Bates stamp 'EFTA00001495' in the bottom right corner.
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