AddressThe Mar-a-Lago Club, 1100 South Ocean Boulevard, Palm Beach, Florida 334801
EntityThe Mar-a-Lago Club, L.C.2
OperatorFlorida Properties Management, described in evidence as “the management company for the Mar-a-Lago Club”3
Described in the filings as”Trump’s Maralago”4
In the civil recordJane Doe No. 102 v. Epstein alleges that Ghislaine Maxwell approached a teenage employee of the club’s spa there5; Virginia Giuffre’s own case, Giuffre v. Maxwell, gives the same location for her recruitment6
The reported banThe New York Post reported on 15 October 2007 that the club had confirmed Epstein was barred; Epstein denied it7
Trial subpoenasSouthern District of New York subpoenas of 5 October and 17 November 2021, both returnable 29 November 2021 in United States v. Ghislaine Maxwell18
Trial exhibitGovernment Exhibit 823, a Mar-a-Lago personnel action notice; the sealed original went to the jury and a redacted public version, 823-R, was admitted for the public on 8 December 2021910

Mar-a-Lago is a private club at 1100 South Ocean Boulevard in Palm Beach, Florida, operating as The Mar-a-Lago Club, L.C. and run by a management company, Florida Properties Management.123 Court filings in the Epstein litigation describe it as Donald Trump’s club.411 It enters the Epstein record in three ways. A civil pleading placed an approach to a teenage employee of the club’s spa there.5 The sworn account of Virginia Giuffre separately places her own employment in the club’s spa, and Maxwell’s approach to her, there as well.612 A New York Post item of 15 October 2007 reported that the club had confirmed Epstein was barred from it, which Epstein denied.7 And in 2021 federal prosecutors subpoenaed the club twice for employment records and called its human resources director as a witness at Maxwell’s trial.183 The documents described below concern the conduct of Epstein and Maxwell; none of them records a finding against the club, its management or its staff.

The club

The trial subpoena issued by the United States Attorney for the Southern District of New York on 5 October 2021 is addressed to “The Mar-a-Lago Club, 1100 South Ocean Boulevard, Palm Beach, Florida 33480.”1 A 2015 letter from the club gives the name on its letterhead as “The Mar-a-Lago Club, L.C.” at the same address.2

The club’s human resources director, testifying at Maxwell’s trial on 8 December 2021, said she worked for Florida Properties Management, “the management company for the Mar-a-Lago Club,” that she was “in charge of all the employment processes,” and that she had worked at Mar-a-Lago “almost 15 years.”310 She described the personnel file as “normally … a paper file, in an individual folder,” and said new-hire paperwork consisted of an application, a policies and procedures handbook and a personnel action notice completed by the manager at the time of hire.313 On cross-examination she agreed that she had started in about 2007, that the document introduced through her concerned the year 2000, and that she had no personal knowledge of how it had been completed.14

The approach at the club

Content warning: this section concerns the sexual exploitation of a minor.

The Jane Doe No. 102 complaint

Jane Doe No. 102 v. Epstein was one of the civil actions against Epstein consolidated before Judge Kenneth A. Marra in the Southern District of Florida, docketed there as 09-80656-CIV.15 Jane Doe No. 102’s counsel of record were Katherine Warthen Ezell and Robert C. Josefsberg of Podhurst Orseck.16 On 8 October 2009 George Rush of the New York Daily News emailed Maxwell a list of allegations from that complaint and asked her to respond. Quoting the complaint, he put to her that she had met the plaintiff when she was 15 and working as a changing-room assistant at “The Mar-a-Lago Club in 1998,” and had told her she could learn massage therapy and earn a “great deal of money” at Epstein’s.175 Maxwell forwarded the reporter’s messages to Epstein the following day.17

The attorney Brad Edwards, summarising the same complaint in a declaration of September 2010, wrote that “Jane Doe No. 102’s complaint alleged that Jane Doe 102 was initially approached at Trump’s Maralago by Ghislaine Maxwell and recruited to be Maxwell and Epstein’s underage sex slave.”411 That is a lawyer’s summary of a pleading, not a finding.

Giuffre’s account

Answering requests for admission in her defamation suit against Maxwell, Giuffre said that when she had earlier told her story she “firmly believed she was 15 years old when she was recruited away from her job at Mar-a-Lago by Ghislaine Maxwell,” that she “later obtained some records from Mar-a-Lago which indicated that she was employed there during the year 2000,” and that she was therefore 16 for part of that year and 17 for the rest. Her answer concluded that although she now knew she had not been 15, “she now has conclusive proof that she was an underage minor when Ghislaine Maxwell approached her, recruited her, introduced her to Jeffrey Epstein, and sexually trafficked her as an underage minor.” The answers are quoted in Maxwell’s motion to compel, which was placed on the public docket on 5 January 2024.6

Deposed on 3 May 2016, Giuffre said the first job she held “was in the year 2000, and that was at Mar-a-Lago,” during a summer break from studying for a GED; that she was interviewed for and worked as a “locker room attendant” in the spa area; and that the hiring process involved “a series of drug tests, polygraph tests. I mean, it was a very extensive regime to get a job there.”1218 Asked what records had caused her to date the employment to 2000, she answered, “The Mar-a-Lago employment documents,” and said her name was on them.19 She agreed that she had previously told the media she met Maxwell in 1998 or 1999 and had been 15, and said, “It was a mistake that I made”; she placed her discovery of the error in about the middle of 2015.20

Maxwell’s answers

Maxwell was deposed in the same case on 22 April 2016. Asked whether she was a member at Mar-a-Lago she answered “No”; asked whether she had visited, “Yes”; and asked whether she had visited in the year 2000, “I’m pretty sure I did.”21 Asked whether she had introduced Giuffre to Epstein, she answered, “I don’t recall how she actually met Mr. Epstein.”21

Interviewed by Deputy Attorney General Todd Blanche on 24 July 2025, Maxwell was asked whether she recalled ever recruiting a masseuse from the Mar-a-Lago spa to give a private massage to Epstein. She answered: “I’ve never recruited a masseuse from Mar-a-Lago for that, as far as I remember. I can’t ever recollect doing that.”22 Asked in the same session whether she knew whether masseuses from the club’s spa had ended up giving Epstein private massages, she said she did not recall it but that it was possible.23 She said she had visited the club, mostly alone, and believed Epstein had gone there and would “maybe go himself to the spa.”24 Asked whether she had ever heard Epstein or anyone say that Trump had done anything inappropriate with masseuses, she answered, “Absolutely never, in any context,”23 and said she had never seen Trump receive a massage or behave inappropriately.2425 Maxwell gave that account after her conviction, in a recorded proffer interview at which her own counsel were present.26

The reported ban

The 2007 report and Epstein’s denial

A New York Post Page Six item of 15 October 2007, headed “SEX CASE ‘VICTIMS’ LINING UP,” reports: “Meanwhile, the Mar-a-Lago Club in Palm Beach last night confirmed a Web site report that Epstein has been banned there.” A source quoted anonymously said Epstein “would use the spa to try to procure girls” and had approached a woman working there, after which he was not allowed back. The same paragraph carries Epstein’s answer: he “denies he is banned from Mar-a-Lago and says, in fact, he was recently invited to an event there.”7

The 2009 inquiry

Two years later, Edwards tried to obtain documentary confirmation. On 28 July 2009 he wrote to Michele Dargan, a staff writer at the Palm Beach Daily News:27 “I was wondering if you were able to get a members list at the Maralago, and even more importantly if you were able to get a list of banned members from the Maralago? Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club, and we already know of certain minors that he took from the club to his house.”28

Dargan replied on 29 July that the paper had “no way of getting the members or the banned members lists,” and reported the result of asking Trump directly: “However, I spoke to Donald Trump today … he said Epstein is not a member and would not confirm or deny that he ever was a member. He would not comment at all (which is very rare for him) on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-Lago.”28

Edwards answered the next day: “We have our answer then. All the pieces are public record”, and listed a complaint “filed by Josephsberg regarding Epstein being at the club with Ghislaine Maxwell and taking a 15 year old home with him, a newspaper article that indicated he was banned for similar conduct (don’t remember who published it but I read it a few months back), and a no comment from Trump. He’s banned.” He added that he expected to “get the official word” from depositions being scheduled.28 The correspondence does not identify the complaint or the article any further.

How the ban entered the court file

Edwards was by then the defendant in a suit Epstein had brought against him in the Circuit Court for Palm Beach County, and in September 2010 he filed a statement of undisputed facts with a declaration made under penalty of perjury, signed and dated 21 September 2010.29 Both documents list the grounds on which he had noticed a deposition of Trump. Item (c) in the statement reads: “Trump allegedly banned Epstein from his Maralago Club in West Palm Beach because Epstein sexually assaulted an underage girl at the club.”4 The corresponding item in Edwards’s own declaration is more specific about where the claim came from: “I learned through a source that Trump banned Epstein from his Maralago Club in West Palm Beach because Epstein sexually assaulted an underage girl at the club.”11 The same list gives the other grounds: message pads seized from Epstein’s home showing calls from Trump; remarks by Trump about Epstein quoted from a magazine profile; the Jane Doe No. 102 allegation; Mark Epstein’s deposition testimony that Trump had flown on Epstein’s plane; a visit by Trump to Epstein’s Palm Beach home; and Epstein’s computer phone directory, which the filing says “contains 14 phone numbers for Donald Trump, including emergency numbers, car numbers, and numbers to Trump’s security guard and houseman.”411 Edwards states that on this basis he “reasonably believed that Trump might have relevant information to provide in the cases against Jeffrey Epstein and accordingly provided notice of a possible deposition.”4 A deposition notice records that an attorney sought testimony and nothing more. Two further copies of the same statement of undisputed facts are in the release, one of them attached to a notice later filed by Epstein’s counsel; they are copies, not separate accounts.30

Trump’s account in 2025

The Federal Bureau of Investigation’s daily news briefing of 1 August 2025 summarised reporting of the previous day by the Associated Press and Fox News. According to that summary, the family of an accuser in the Epstein case who had died earlier that year said they were shocked by Trump’s statement that Epstein had “stolen” her from his Mar-a-Lago spa, and Trump “said he banned Epstein from the club after learning of the alleged poaching of young women.” The family criticised his language and questioned what he had known at the time.31 This is a government summary of press reports, not a record of the statement itself.

None of the documents cited on this page records an answer, from Trump, from the club or from Epstein, to the allegation in Edwards’s 2010 declaration that a sexual assault took place at the club: Epstein’s 2007 denial answers only whether he was banned, and Trump’s 2009 reply to Dargan was a refusal to comment on the ban and on recruitment.

Employment records

The club’s employment records were sought over more than a decade. For the 1999–2001 period, the club’s own answer was that the records were no longer available.2 The subpoenas and prosecution notes from the 2021 criminal investigation, discussed below, redact the name of the employee whose records were sought; this page does not supply it.

The club’s 2015 letter. On 12 February 2015 the club’s Director of Human Resources wrote to Edwards’s firm, Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, under file number 14-000107. The letter states that “the historical employment records you are requesting, for the time period of ‘1999-2001’ are no longer available.” It goes on to say that a name, blacked out in the released copy, “appears on a spreadsheet dated back to 2000 which lists terminated employees for that time (year 2000),” and that the writer was “unable to confirm whether or not this is the same person due to the fact no other information is listed such as a social security number, address, position, etc. The only information listed is a first and last name.”2

Giuffre v. Maxwell (2015–2017). Giuffre’s discovery answers state that she obtained records from Mar-a-Lago indicating employment during 2000, and she testified that she had reviewed those documents.619

Giuffre v. Dershowitz (2019). At a hearing before Judge Loretta A. Preska on 2 December 2019, counsel for Alan Dershowitz, Howard Cooper,32 told the court that if “we get the records with regard to her employment at Mar-a-Lago that we’ve sought we believe that it will be irrefutable that she cannot avail herself of the state statute and the revived statute of limitations …”33

United States v. Maxwell (2021). Prosecutors approached the club through outside counsel, Patricia Anne Pileggi. On 24 September 2021 Pileggi reported that she had “not been able to locate anyone who recalls” a redacted name “working at Mar a Lago in 2000.”34 On 30 September she reported that Mar-a-Lago had no in-house counsel and that she had been dealing with compliance counsel for the Trump Organization; the next day she wrote that she had “been authorized to accept a subpoena on behalf of the custodian of records for Mar a Lago,” and on 5 October a trial subpoena was sent to her.35 That subpoena, signed and dated 5 October 2021, commands the club to appear on 29 November 2021 and to produce “Any and all employment records relating to” a redacted name.1 A second subpoena of 17 November 2021 adds “PERSONAL APPEARANCE REQUIRED” and demands, besides the employment records, “contact information for the appropriate records custodian, to include former HR Directors of Mar-a-Lago if necessary.”8 The prosecutor who forwarded it noted that the compliance counsel for the Trump Organization, Jill Martin, should be reminded that the subpoena required a witness to appear in person.3635

Two internal prosecution notes record the difficulty. A note of 9 September 2021 says the prospective custodian “has worked at Mar a Lago since 2007, so was not around when spreadsheet was created. Just found the spreadsheet on an HR drive, can’t testify that the underlying spreadsheet is a business record.”37 A note of 8 November 2021 says that counsel had not found anyone who remembered, that the custodian did not know who had prepared the record or the source of its information, and that it did not appear to her that the record had been created on a regular basis: it “appears to have been randomly done.”38

What was argued and admitted at trial

On the morning of 8 December 2021 the court heard argument on two proposed exhibits: Government Exhibit 823, a personnel action notice, and Government Exhibit 824, employee benefit application forms.39 The prosecution said the notices “are created in the ordinary course of business by managers at Mar-a-Lago at the time an employee is hired,” that employees eligible for benefits complete the application form and submit it to Mar-a-Lago, “which processes them, sends them out to insurance companies and retains them for Mar-a-Lago’s own business purposes,” and that Exhibit 824 also contained “fax transmittal cover sheets from Mar-a-Lago which indicates that Mar-a-Lago is doing the work of processing and sending out these applications.”4041 Maxwell’s counsel, Ms. Sternheim, objected on relevance and on foundation, arguing that “the fact that somebody fills out a request for insurance does not deem it a business record” and that the government was trying “through a backdoor method” to draw an inference about the complainant from the fact that she had been insured as a club employee’s dependent.4241

The court and the government agreed on what the records did not show. “Nothing in these records appears support that she was employed at Mar-a-Lago,” the court said. The prosecutor replied: “The government agrees, your Honor, these records don’t give rise to that.” Asked what he was trying to show, he answered: “That she was the dependent of a Mar-a-Lago employee.”42 The government’s stated theories of relevance were that the records connected a name on a birth certificate already in evidence to a person associated with the club in 2000, that this bore on the complainant’s age, and that a telephone number in the records matched an entry in another exhibit.4340

The exhibit the government offered through the human resources director, and which the court admitted over objection, was the personnel action notice of the Mar-a-Lago employee whose dependent the government said the complainant was. It was not a record of the complainant’s own employment. The redacted version, Government Exhibit 823-R, was published to the public “in order to protect the personal information of third parties”;9 the jury was directed to the sealed, unredacted Government Exhibit 823 in their own binders.9 The witness read from the exhibit a date of hire of 11 April 2000 for that employee.9 The government then directed the jury to a line labelled “father of child” on an exhibit already in evidence and ended its examination.44

Timeline

DateEventSource
15 October 2007New York Post reports that the club has confirmed Epstein is barred; Epstein denies it7
28–30 July 2009Edwards asks a Palm Beach Daily News reporter for membership and banned-member lists; Trump declines to comment28
8–9 October 2009New York Daily News puts the Jane Doe No. 102 allegations to Maxwell; she forwards them to Epstein175
21 September 2010Edwards’s declaration and statement of undisputed facts set out the grounds for the Trump deposition notice11294
12 February 2015The club’s HR director tells Edwards’s firm that 1999–2001 employment records are no longer available2
22 April 2016Maxwell deposed: not a member, has visited, “pretty sure” she visited in 200021
3 May 2016Giuffre deposed about her 2000 employment as a locker room attendant1219
2 December 2019Dershowitz’s counsel tells the court he is seeking her Mar-a-Lago employment records33
9 September 2021Prosecution note: the prospective custodian joined in 2007 and cannot authenticate the spreadsheet37
24 September 2021Club’s counsel reports she cannot locate anyone who recalls the employment34
5 October 2021Trial subpoena to the club, returnable 29 November1
8 November 2021Prosecution note on the custodian’s inability to authenticate the record38
17 November 2021Second trial subpoena, requiring personal appearance8
8 December 2021Argument on Exhibits 823 and 824; GX-823-R admitted; the club’s HR director testifies4293
24 July 2025Maxwell tells the Deputy Attorney General she never recruited a masseuse from the club’s spa22
31 July 2025Trump reported as saying he banned Epstein from the club over the poaching of young women31

People: Ghislaine Maxwell; Virginia Roberts Giuffre; Brad Edwards; Alan Dershowitz; Mark Epstein.

Places: Palm Beach network.

Topics: Maxwell trial exhibits; Epstein recruitment methods; Alan Dershowitz litigation.

Footnotes

  1. Trial subpoena to The Mar-a-Lago Club, S.D.N.Y., Oct 5, 2021, in United States v. Ghislaine Maxwell, 20 Cr. 330. https://epstein-data.com/EFTA00010243 2 3 4 5 6 7

  2. Letter from the Director of Human Resources, The Mar-a-Lago Club, L.C., to Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., Feb 12, 2015. https://epstein-data.com/EFTA00029389 2 3 4 5 6

  3. Trial transcript, Dec 8, 2021, transcript p.1733. https://epstein-data.com/EFTA02841117 p.28 2 3 4 5 6

  4. Statement of undisputed facts of Bradley J. Edwards, Epstein v. Rothstein and Edwards, Circuit Court of the 15th Judicial Circuit, Palm Beach County, case 50 2009 CA 040800. https://epstein-data.com/EFTA01093549 p.29 2 3 4 5 6 7

  5. George Rush, New York Daily News, to Ghislaine Maxwell, Oct 8, 2009, quoting the Jane Doe No. 102 complaint. https://epstein-data.com/EFTA02438188 pp.2–3 2 3 4

  6. Defendant’s motion to compel responses to her second set of discovery requests, Giuffre v. Maxwell, S.D.N.Y. 15-cv-07433, exhibit filed Jan 5, 2024. https://epstein-data.com/EFTA02793714 p.25 2 3 4

  7. New York Post, Page Six, “SEX CASE ‘VICTIMS’ LINING UP,” Oct 15, 2007. https://epstein-data.com/EFTA01682184 p.171 2 3 4

  8. Trial subpoena to The Mar-a-Lago Club, S.D.N.Y., Nov 17, 2021. https://epstein-data.com/EFTA00078518 2 3 4

  9. Trial transcript, Dec 8, 2021, transcript pp.1735–1736. https://epstein-data.com/EFTA02841117 pp.30–31 2 3 4 5

  10. Trial transcript, United States v. Ghislaine Maxwell, S.D.N.Y. 20 Cr. 330, Dec 8, 2021, cover page. https://epstein-data.com/EFTA02841117 p.1 2

  11. Affidavit of Bradley James Edwards, ¶13. https://epstein-data.com/EFTA01187465 p.8 2 3 4 5

  12. Deposition of Virginia Giuffre, Giuffre v. Maxwell, May 3, 2016, transcript pp.49 and 54. https://epstein-data.com/EFTA02792705 pp.15–16 2 3

  13. Trial transcript, Dec 8, 2021, transcript p.1734. https://epstein-data.com/EFTA02841117 p.29

  14. Trial transcript, Dec 8, 2021, transcript p.1738. https://epstein-data.com/EFTA02841117 p.33

  15. Discovery order of Aug 4, 2009, S.D. Fla., 2009 U.S. Dist. LEXIS 139535, counsel listing. https://epstein-data.com/EFTA01387837 p.1

  16. George Rush, New York Daily News, to Ghislaine Maxwell, Oct 8, 2009, forwarded Oct 9, 2009. https://epstein-data.com/EFTA02438188 pp.1–2 2 3

  17. Deposition of Virginia Giuffre, May 3, 2016, transcript pp.57–58. https://epstein-data.com/EFTA02792705 p.17

  18. Deposition of Virginia Giuffre, May 3, 2016, transcript pp.61–62. https://epstein-data.com/EFTA02792705 p.18 2 3

  19. Deposition of Virginia Giuffre, May 3, 2016, transcript pp.63–64. https://epstein-data.com/EFTA02792705 p.18

  20. Deposition of Ghislaine Maxwell, Giuffre v. Maxwell, Apr 22, 2016, transcript p.17. https://epstein-data.com/EFTA02791404 p.18 2 3

  21. Interview of Ghislaine Maxwell by Deputy Attorney General Todd Blanche, Jul 24, 2025, transcript p.109. https://epstein-data.com/DOJ-OGR-00022393 (PDF p.109) 2

  22. Interview of Ghislaine Maxwell by Deputy Attorney General Todd Blanche, Jul 24, 2025, transcript p.108. https://epstein-data.com/DOJ-OGR-00022393 (PDF p.108) 2

  23. Interview of Ghislaine Maxwell by Deputy Attorney General Todd Blanche, U.S. Department of Justice, Jul 24, 2025, transcript pp.106–107. https://epstein-data.com/DOJ-OGR-00022393 (PDF pp.106–107) 2

  24. Interview of Ghislaine Maxwell by Deputy Attorney General Todd Blanche, Jul 24, 2025, transcript p.107. https://epstein-data.com/DOJ-OGR-00022393 (PDF p.107)

  25. Interview of Ghislaine Maxwell by Deputy Attorney General Todd Blanche, U.S. Department of Justice, Jul 24, 2025, appearances. https://epstein-data.com/DOJ-OGR-00022393 (PDF p.2)

  26. Michele Dargan and David Rogers, “Palm Beach sex offender Jeffrey Epstein ‘treated differently’,” Palm Beach Daily News, Dec 13, 2008, byline. https://epstein-data.com/EFTA01659997 p.1

  27. Email exchange between Bradley J. Edwards and Michele Dargan of the Palm Beach Daily News, Jul 28–30, 2009. https://epstein-data.com/EFTA01099665 p.21 2 3 4

  28. Affidavit of Bradley James Edwards, declaration under penalty of perjury, signed and dated Sept 21, 2010. https://epstein-data.com/EFTA01187465 p.12 2

  29. Further copies of the same statement of undisputed facts. https://epstein-data.com/EFTA02770202 p.29 ; https://epstein-data.com/EFTA02771734 p.32

  30. FBI Daily News Briefing, Aug 1, 2025, summarising Associated Press (Jul 31, Catalini) and Fox News (Jul 31, Bonavita). https://epstein-data.com/EFTA01655293 pp.3–4 2

  31. Appearances, transcript of proceedings before Judge Loretta A. Preska, Giuffre v. Dershowitz, Dec 2, 2019. https://epstein-data.com/EFTA00092688 p.2

  32. Transcript of proceedings before Judge Loretta A. Preska, Giuffre v. Dershowitz, S.D.N.Y. 19-cv-03377, Dec 2, 2019, transcript p.20. https://epstein-data.com/EFTA00092688 p.21 2

  33. Email of outside counsel for Mar-a-Lago, Sept 24, 2021, in the U.S. Attorney’s subpoena thread. https://epstein-data.com/EFTA00087613 p.3 2

  34. U.S. Attorney’s Office subpoena correspondence with counsel for Mar-a-Lago, Sept 7 – Oct 5, 2021. https://epstein-data.com/EFTA00087613 pp.1–2 2

  35. U.S. Attorney’s Office correspondence with counsel for Mar-a-Lago, Nov 16–17, 2021. https://epstein-data.com/EFTA00078510 p.2

  36. Internal prosecution note, “Call with Pat Pileggi,” Sept 9, 2021. https://epstein-data.com/EFTA00159878 2

  37. Internal prosecution note, “Call with Pat Pileggi re: Mar a Lago,” Nov 8, 2021. https://epstein-data.com/EFTA00159883 2

  38. Trial transcript, Dec 8, 2021, transcript pp.1713–1714. https://epstein-data.com/EFTA02841117 pp.8–9

  39. Trial transcript, Dec 8, 2021, transcript p.1716. https://epstein-data.com/EFTA02841117 p.11 2

  40. Trial transcript, Dec 8, 2021, transcript p.1718. https://epstein-data.com/EFTA02841117 p.13 2

  41. Trial transcript, Dec 8, 2021, transcript p.1717. https://epstein-data.com/EFTA02841117 p.12 2 3

  42. Trial transcript, Dec 8, 2021, transcript p.1715. https://epstein-data.com/EFTA02841117 p.10

  43. Trial transcript, Dec 8, 2021, transcript p.1737. https://epstein-data.com/EFTA02841117 p.32