10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Epstein taken April 14, 201.0 Deposition of Jeffrey Epstein taken February 17, 2010 Deposition of Alfredo Rodriguez taken July 29, 2009 (242?44, 223928, 230431, 278280) Deposition of Nadia Maroinkova taken April 13, 2010 (11) Deposition of Jeffrey Epstein dated March 8, 2010 Deposition of Jeffrey Epstein dated October 8, 2009 Deposition of Jeffrey Epstein dated May 1, 2009 Deposition of Jeffrey Epstein dated May 7, 2009 Deposition of Sarah Kellen dated March 24, 2010 . Deposition of Adriana Muoinska Ross dated March 15, 2010 Deposition of Janusz Bansiak taken February 16, 2010 (14, 154?160, 172-175) Deposition of Louella Rabuyo taken October 20, 2009 (9) Deposition of Larry Eugene Morrison taken October 6, 2009 (102-103) Deposition of Alfredo Rodriguez taken August 7, 2009 (302-306, 348) 20. Deposition of Mark Epstein taken September 21, 2009 (48?50) 21. Deposition of Larry Visoski taken October 15, 2009 22. Deposition of Bradley J. Edwards taken March 23, 2010 (1 10?116) DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, er Case No. 50 2009 CA ATTACHMENT 22 Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUET IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 AG Complex Litigation, Fla.R.Civ.Pro. 1201 JEFFREY EPSTEIN, Plaintiff, VOLUME I OF II SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M. individually, Defendants. VIDEOTAPED DEPOSITION OF BRADLEY J. EDWARDS, ESQUERE Tuesday, March 23, 20010 i 10:00 5:07 p.m. i 2139 Palm Beach Lakes, Boulevard West Palm Beach, Florida 33401 35:56.? 9:251- 'l Reported By: Hopkins, RPR, PPR Notary Public, State of Florida Prose Court Reporting 5 Job No.: 1333 - . Rm. (561) 832~7500 PROSE COURT REPORTING AGENCY, INC. . M. 3531332" ?6$Ei?i3?c?3? . . . . ?34 (561) 832*?506 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 83 ?7506 ?Mm-e- rmine; 7 a i . . Page 110 that you were aware of; that is, hard copies? A. I don't know. Q. Okay. Could have been more, could have been less; you just don't know? A. Correct. Q. If i understood your testimony, Mr. Rothstein, Mr. Rosehfeldt, any other attorney or investigator could have accessed those files depending or where they were within the firm, true? A. I am not sure exactly who could have accessed it. You asked me if the attorneys could and the attorneys had swipe cards for various locked areas. Each attorney I believe had access to any area where those files were located. I believe so. Q. Okay. Well, during the time you were there did an individual by the name of Ken Jehhe work there? A. Yes. Q. Okay. Did an individual by the name of Mike Fisteh work for the firm Me A. Yes. Q. for Were they employees of the firm or were they independent contractors? A. I don't know. Q. Okay. During the time they were there, - me .- 5:523 maximum rump: .-.. - A A . ?1.323513 ?in?I-S-?ii??ki "ii'fik? "Ki ?RC-a?r' (561) 832? Page 111 did they also have swipe cards so that they could access different areas in the firm? A. I believe so. Q. With regard to when you joined REA, did you ever have any further meetings with Mr. Rothstein; that is, from the day you started at RRA, did you ever meet Mr. Rothstein again? A. By meet him again Q. Did you ever have a meeting with him again regarding your position in the firm? A. No. Q. Okay. Did you ever meet with him and a number of other individuals with regards to firm business? A. No. Q. Firm cases? A. I don't believe so. i Q. Was Mr. Rothstein ever present in any meeting where any of your cases were discussed? Let me strike that. Was Mr. Rothstein ever present wherein at any meeting where any of the cases against Jeffrey Epstein were discussed? Don't tell i me content; just was he ever present. A. How would 1 know that? I don't know. He ?autism? ;m1*w~n~svi could, he could be in a meeting right now where the case mm 500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 :Erfaik?h??i" 3 naturalists ""263" :si?wzwx WW ?4215in 1.35m; 832*7500 Page 112 could be discussed for all I know. Q. I?m sorry. Obviously, where you, where you were present. Where you ever present at a meeting where Mr. Rothstein was also present where the Epstein cases were discussed? A. No. Q. Did he ever call you to communicate with you, call you either by phone, video conference, in any fashion to discuss any act aspect of the cases that you had against Jeffrey Epstein? - You can answer that. MR. SCAROLA: THE WITNESS: He has communicated about various, about legal issues related to the case as well as commented about the case to me on very few occasions but I would say less than three times. BY MR. CRITTON: Q. During the time that you, from April of '09 through late October of '09, correct? A. In that time period, where, is that when these Q. Correct. A. things happened? Q. Well, that's the time you were there; that?s what I am asking. - . we: mm mm- PROSE COURT REPORTING AGENCY, INC. (561) 832w75 6 (561) 832*7500 Page 113 i A. When I was there. Q. And do you, can you remember the date, any specific date that you spoke with him? A. No. Q. Do you remember any specific month that you would have had one of the well, what did you say something less than five conversations? I don't want to misquote you. A. I said less than three conversations. Q. All right. So, something less then three conversations you had with Mr. Rothstein regarding Epstein cases, either legal issue or a comment, some comment about the case to you, correct? A. Yes. Q. All right. The first time that he ever spoke to you, did he call you or did you call him? A. Z, I never called Scott Rothstein about anything. Oh, take that back. About anything related to Jeffrey Epstein. Q. The first conversation that you can recall where either a legal issue or a comment was made about Jeffrey Epstein by Mr. Rothstein to you, he obviously initiated the call? A. It wasn't a call. Q. What was itPROSE COURT REPORTING AGENCY, INC. (561) 832*7506 33333:: 3.3.0 (561) A. sitting at a table in BOVA when he walked over to my table and commented about Jeffrey Epstein. Q. time? A. Q. other lawyers? A. no idea. Q. answer that question without disclosing any mental impressions with regard to the lawsuit or any attorney?client privileged communications, 832?7500 PROSE COURT REPORTENG AGENCY, ENC. Page 114 A comment in passing. And I believe I was Exit? "tedmun?zm??m Okay. Who were you there with at the I don't remember. Were you with some friends? Were you with All right. I am jogging my memory. I, I have 3431 [5.1112 7.3-5.1 What did he say? MR. SCAROLA: To the extent that you can you can answer. To the extent that it might invade either the or attorney?client privilege, you should not respond. THE WITNESS: Can I talk to you? MR. SCAROLA: Sure. (A brief recess was held.) MR. SCAROLA: Are we on? THE VIDEOGRAPHER: Yeah. MR. SCAROLA: The record should reflect' 1.3m . . . .. Len,? 1:15.43 (561) 832*7506 3: . "316? .. a? Page 115 1 that we have had an opportunity to consult and 2 I have advised Mr. Edwards that there is no 3 privilege protection for the particular 4 communications involved. 3 5 BY MR. CRITTON: 6 Q. What did he say? i 7 A. He commented to me, I want you to get that 8 pedophile. 9 And your response was what? 10 A. I didn't respond. 11 Q. all right. Second conversation that you 12 can remember, where were you? rm: 33:12.55: new: 13 A. I had just come out of the conference room on 14 the main floor after taking a deposition in another 15 case. And he walked by and said, did you get that F'ing ??itiffci?i?: Wmm? 16 pedophile yet. 17 Q. And your response? 18 A. Again. 19 Q. No reaponse. 20 A. Didn't respond. 21 Q. On the first occasion when he came over 22 and if I understand correctly, all he said was the 23 comment that you referenced and then he left. You 24 didn?t respond and then he just made the comment and 25 then left(561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 116 i A. Right. He was walking by in his normal, loud, ostentatious kind of way, greeting everybody in the restaurant. Came over to my table and he feels, at least my impression was obliged to say something to everyone. And that's the comment he said to me. And if you?ve ever seen him, he is basically always just skipping around and he hoped on over somewhere else. So, yes, it was in, literally in passing. Q. Okay. How, how, how did he even know you had cases involving Mr. Epstein? A. I don't know. Q. Because I think you testified earlier that you had never discussed an Epstein case with Mr. Rothstein onemon?one, correct? 2 A. Absolutely, true. i Q. You never discussed an Epstein case or either of your three clients with Mr. Rothstein even with a group of people around, correct? A. Correct. Q. All right. Do you remember a third occasion that he spoke to you regarding Epstein related occasion, cases? A. Anything else that he ever spoke with me about related to Epstein related issues is attorney?client and 2.4m. can? farm?. (561) 832?7500 7' .. .. 2?5 ?v m. PROBE COURT REPORTENG AGENCY, ENC. (56 832M7506 DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, a: a1. Case No. 50 2009 CA 040800MMBAG ATTACHMENT 21 - Larry Visoski October 15, 2009 25 3 IN THE CIRCUIT COURT OF THE FIFTEENTH JUSICIAL CERCUIT BEACH COUNTY, FLOR: DA CASE NO. so 2 3 - Lat. 4 _vs_ ?ai?tiff: 5 DIRECT CROSS REDIRECT RECROSS 6 JEFFREY EPSTEIN, Defendant, '7 . BY MR. EDWARDS: 0 BEPOSITIGN OF LARRE VISOSKI 8 BY MR. CRHTON: 214 Thursday, October 15, 2009 By MR. 229 10:13 3:3? p.221. 9 BY MR. CRITFON: 221 515 N. Flegler Drive 10 Soite 92m) 11 west Palm Search, Florida 33401 12 13 i 8 Reported By: 14 . .. .. Wendy Beath Anderson, RPR, CREE, PPR Rotary Public, State of Florida 15 i i ?12542 3'6 NUMBER DESCREPTEON PAGE 17 EX. 1 FLEGHT LOG 800K PREVIOUS oeeot 18 19 EX. 2 MESSAGE PAD 119 EX. 3 MESSAGE PAD 319 20 EX. 4 COMPLAINT . 139 EX. 5 ENMATE LOG 16APPEARANCES: 1 PROCEEDWGS 2 On behalfof the Ptainti?: 2 3 BRADLEY J. EDWARDS, ESQUIRE ROTHSTEIN, ROSENFELDT, ADLER 3 Deposition taken before Wendy Beath Anderson, 3331:2333 0'33 Bowman} 4 Certified Reattime Reporter and Notary Pubtic in and for 5 For; Lauderdala, Florida 33394 5 the State of Florida at Large, in the above cause. 6 6 .. 7 On behalf of the Defendant: . . 8 7 We're gt)an to put something on 9 BURSIIAN. 68? gilt?fig: 8 the record about welt, we?it do it this way 303 anyan ou ever uite . West Palm Beach} Florida 3343, 9 MR. REINHART. Do it at the end, after we get 1 1 0 him whatever you want. its your show. 13. On hehatf of the Witness: . . 12 BRUCE REENHARTI ESQURE 13. Ckay. There were i dont 250 South Australian Avenue 12 even thzok Mr. aware of this. There was 13 Suite 1400 13 West Pa'm Beach, Roma 33401 a subpoena doces tecqu or 1?th wttness, as weft as 14 14 the prewous witness, which was another pliot, Dave 31?: ESQUIRE 15 Rogers, and that doses teoum was to bring the 1220 NW 157th Attenue 16 ?ight logs rotated from 1998 through 2005. What 17 Pembroke Pines, Florida 33028 17 was produced at the previous deposition were flight 3.8 ADAM D. HOROWITZ, ESQUIRE . MERMELSTEEN HOROWWL PA 18 logs from 2002 through 2005, artd now Mr. Remhart 19 18205 Biscayne Boozevard, Suite 2218 9 has agreed to produce the remainder of the fight 2 0 Mtam'u Honda 33150 20 tags requested, those going from 1998 through 2002. H. WILers, ssouzes (VIA 2 1 MR. REINHART: Correct. They?re pitot togs. 21 WCHARD H- PA, 22 not ?ight tags. There are other records we 2290 10th Avenue North, Surte 404 . . 22 Lake Worth! Florida 33461 23 indtcated are corporate records, and those you :3 24 have to deaf with Mr. Critton. 4 25 MR. However, with the proviso, too, Larry Visoski October 15, 2009 5 7 1 that we?re going to work out that these records are 1 the question and you need to wait untii i ?nish asking 2 to be used within the con?nes of this litigation 2 the question. 3 and not to be spread to the press or anyone eise, 3 A. So you?re not ailowed to interrupt me? 4 because they do contain con?dentiai information as 4 Q. And you?re not altowed to interrupt me. 5 to who may have been on the piano and other records 5 A. Like iiust did? 6 of Mr. Rogers, which but for the subpoena woutd 6 Q. Right. ?3 have been only avaiiable to the FAA or some other 7 MR. CRITTON: Cara just snickered when you 8 law enforcement agencies. 8 said you?ve been accused because she recognizes 9 MR. EDWARDS: Okay. is that sit you want to 9 it?s true. 10 put on? 10 MR. EDWARDS: i don't know what the meaning of 3. 1 MR. Yes. 1 1 her snickenng was. 12 MR. EOWARDS: i?m not saying i necessarily 12 BY MR. EDWARDS: 13 agree or disagree with you. That?s something that 13 Q. But for what it?s worth, if you don't 14 we'il deat with some other day. 1 4 understand the question or We asked a bad question, i 15 MR. CRETTON: Bruce, you'd better produce 15 don't want you to guess. Give me the best answer to the 6 these records, but there has to be some sort of 6 best of your knowledge and it you need me to rephrase 1 7 understanding before 17 it. i wilt. 1 8 MR. REENHART: Correct. 18 A. Okay. 19 MR. EDWARDS: i won't do anything unit! you 18 Q. Okay. Teii me your current address. 2 0 ?le whatever you ?w until we work whatever it is 2 0 A. 113? Pine Point Road, Riviera Beach, Florida 21 out in court. i?ii say that on the record, that 21 33404. 22 t?rn not doing anything with the records outside of 22 Q. How tong have you tived there? 23 my office until some judge deais with it. 23 A. Approximater nine years. 2 4 MR. And for the record. i?ii adopt 24 Q. Okay. Who do year five there with? 25 what Mr. Critton said on this one limited occasion. 25 A. My wife and one chitd at this time. 6 8 3. MR. EDWARDS: right. 1 Q. right. How many chiidren do you have? 2 Thereupon, 2 A. Two. 3 (LARRY 3 Q. How did are they? 4 having been first duty sworn or af?rmed, was examined 4 A Fifteen and eighteen. 5 and testi?ed as foitows: 5 Q. And is the 18?year?old, is not iiving with 6 THE WITNESS: Yes, i do. 6 you? 7 DERECT 7 A. She?s off in schooi. 8 BY MR. EDWARDS: 8 Q. Okay. What schooi is that? 9 Q. Can you teit us your name for the record. 9 A Syracuse. 10 A. Lawrence Visoski, Jr. 3.0 Q. Who's your empioyer right now? 11 Q. And Mr. Visoski, have you ever had your 11 A NES, LLC. 12 deposition taken before? 12 How long has NES, LLC been your employer? 3.3 A. No. 13 A. I'm guessing. i?d say back 1991. i have to Q. Okay. Here's the process: for going to ask 14 do the math, but 17, 18 years. 15 you questions. You?re going to give us answers. Try to 15 Q. Has that been your oniy employer since 1991'? 16 give us answers that we alt understand and that the 1 6 A. Yes. 17 court reporter can take down, such as yes, no, or some Q. And has that been your onty source of income 18 other verbs! answer that we can understand. it?s easy it 8 since 1991? 19 when we get in a casual conversation to nod or shake 19 A. Yes. 20 your head, and the court reporter is not writing 20 Q. And what is NES, 2 1 pictures or anything else. 2 1 A. i don't reaiiy know. i mean, it?s the company 22 A. i understand. 22 that my check comes from. 23 Q. The other thing is, and i?ve been accused of 23 Q. What do you do for MES, LLC that results in 24 this in other depositions i don't know if it?s true 2 4 them paying youneed to wait untit you ?nish answering 25 A. i am chief pitot for the aircraft and Larry Visoski October 15, 2009 9 3. 1 heticopters. 1 Q. What ?oor or suite number is MESyou have a specific boss or somebody 2 A. i beiieve wait, i dont know that NES, LLC 3 you answer to at NES, 3 has an of?ce there. i knowthat?s where Lesile has the 4 A. Severai peopie would eat! to scheduie ?ights 4 phone number where i calt. So i don't know for a fact 5 from the office, being it either Mr. Epstein or, you 5 it MES, LLC has an of?ce there. 6 know, i would just get a phone caii and they would 6 Q. And what suite number, then, would Leslie 7 schedule a trip. ?3 Stuff sit in to answer that telephone number at 8 Q. Okay. Aside from Mr. Epstein, who etse would 8 750?9895? 9 there be that would call to schedute flights? 9 A. i think it's 10F. 10 A. Lesiie. 10 Q. And when you stay at 301 East 66th Street, 1 1 Q. Leslie who? 13. what suite nurnher or what apartment number do you stay 12 A. Lestie Gruff. 12 in? 13 Q. When?s the last time you taiked to Lesiie 13 A. 120. 1 4 Gruft? 14 Q. And how about DaveRogers, where does he stay? 15 A. Probabiy two weeks ago, three weeks ago. 15 A. I'm guessing. because it?s been sometime 16 Q. And where is she Currentiy? 16 since we?ve been there, 108. but don?t quote me on it. A. i beiieve in New York, is where 1 spoke to her 17 Q. Who are the other peopie in that building that 18 on the phone last. 18 you know to stay there on a regular fairty regutar 19 Q. What's the telephone number you caii to reach 19 basis? 20 Lesiie Stuff? 20 A. We seen peopte in the etevator that. you 21 A. (212)7509895. 21 know. have been on the airpiane. Case in point. maybe 22 And what address is Lesiie Gruff at? 22 Sarah Keilen. but I don?t know for a fact that she fives 2 3 A. Do you mean where the office is located? 23 there, or anybody else for that matter. 2 4 Correct. 24 Q. Okay. When you say you?ve seen Sarah Ketien 25 A 301 East 66th Street. 25 on the elevator 1 0 12 1 Q. And it?s my understanding from other 1 A. i only assume she lives there. i don?t know 2 depositions that there are atso apartments in that 301 2 for a fact. l?rn trying to be honest and tactuat for 3 East 66th Street building? 3 you. So i contdn?t honestly say ifi knew she tived 4 A. Yes. 4 there or not. 5 Q. And Mr. Epstein either owns or leases or rents 5 Q. Where do you think Sarah Ketten lives? 6 certain of those apartments. is that your 6 A. i would think she lives there. 7 understanding? 7 Q. You don?t have a better tocation? 8 MR. Form; specutation. 8 A. i don't have another location. 9 THE i?m oniy speoutating. i 9 Q. Anybody else? 10 don?t to my understanding, 5 don't know. to A. Not to my knowtedge. i mean, to oniy be 1 1 BY MR. EDWARDS: 1 guessing that people tive in that buitding that -- you 12 Q. Do you know other peopte that live in that 1 2 know, 1 don?t have any facts to prove that they actualiy 13 buiiding? 1.3 live there. i mean, i don't think you want me to guess. 14 A. Watt, it would he myseif, Dave Rogers well, 14 Q. Welt, NES, LLC. wouid you say that the owner 15 when you say expiain. 15 or controiler of that company is Jeffrey Epstein? 16 Q. When you're saying yourself and Dave Rogers 16 MR. CRITTON: Form- 17 A. See, we don't live there. mean, we have 17 THE WITNESS: i don?t know that for a fact. 18 we wouid stay there when we would have a trip. 18 BY MR. EDWARDS: 19 0. Okay. When you woutd ?y up to New York and 19 Q. Jeffrey Epstein is somebody you've indicated 2 0 land in New York, the place where you wouto stay, is 2 0 that you've worked for for t? or 18 years, right? 2 1 that 301 East 66th Street? 2 1 A. Yes. 22 A. Yes, that?s correct. 22 Q. And over the t? or 18 years you?ve become 23 Q. That?s also a iocation you've indicated in 23 personaliy ciosa with him as wail, correct? 24 this deposition that is the of?ce for MES, 24 MR. CRITTON: Form. 25 A. Yes. 25 THE i don't understand how you mean Larry Visoski October 15, 2009 1 3 3. 5 1 "ciose." Define that. 1 you know, teievisions and such. 2 BY MR. EDWARDS: 2 Q. is that another hobby oriob or something of 3 Q. Weii, more so than just a pilot that takes him 3 yours? 4 from Point A to Point 4 A. Both. 5 A. That is myiob. 5 Q. Does he pay you for that? 6 Q. Right. But you know him on a personai ievei 6 A. Not any more than my salary. and that you've had personal conversations that don?t Q. What's your current salary? 8 necessariiy deal with ?ying from Point A to Point 8; 8 A. At this time, 180,000. 9 isn't that right? 9 Q. And what are you paid $180,000 to do? 3.0 MR. Form. 3.0 A. To manage his aircraft. 3.3. THE WITNESS: More speci?c, meaning we talk Q. What does that entaii? 3.2 about cars. mean, does that make you a personai 3.2 A. Scheduiing maintenance. Anything that has to 33 friends? 3.3 do with any ?ight, whether it be weather, flight 14 BY MR. EDWARDS: to planning, time and distance to and from a location, any 1 5 Q. Have you ever gone to his house to eat? 15 logistics invoived in running an operation that has 1 6 A. No. 1 6 aircraft. 1? Q. Have you been to his New York home? Q. in addition to the 180,000, does he give you 18 A. Yes. 18 bonuses as wait? 19 Q. How many occasions have you been to his New 19 A. ?i?here have been Christmas bonuses. 2 0 York home? 20 Q. Over the years, you mean. there have been 2 1 MR. Object to form. 2 1 Christmas bonuses? 22 THE We normaiiy pick up luggage in 22 A. Yes. 2 3 the lobby, so it would probabiy be quite often. 23 Q. is 180,000 the most he?s ever paid you? 2 4 Any time we depart out of New York, we stop by the 24 A. No. 25 house and pick up luggage and head to the aircraft. 25 Q. right. Were you making - when was the 1 4 1 6 1 BY MR. EDWARDS: 1 last time that you were making an amount different than 2 Q. Other than picking up iuggage, have you been 2 180,000? 3 to his home to visit or socialize with him? 3 A. Last year. 4 A. Not to sociaiize. no. 4 Q. Thatwouid be 2008? 5 Q. Have you been to his Palm Beach home? 5 A. That wouid be correct. Yeah, we all took a 6 A. To? 6 salary out, i don?t know the exact date. It might have ?i Q. To Mr. Epstein?s Pairn Beach house? 7 been 2008, last year. it was iast Christmas we alt took 8 A. Right. 8 a 10 percent saiary out. 9 Q. Have you been there? 9 Q. Do you know why? 10 A. Yes. 10 A. Economic reasons. 11 Q. Have you been inside? 11 Q. And who toid you that you were going to have 12 A. Yes. 3.2 to take the salary out? 13 Q. And how many occasions have you been inside 13 A. Darren indyke. 14 that homeexptanation? 3.5 A. The same, as far as picking up luggage, and 15 A. He exoiained it was due to economic reasons 3.6 that wouidbe on a reguiar basis, you know, for a 16 throughout the country. 17 departure. We wouldn?t always go to the house to pick 17 Q. Okay. So in 2008, how much was - were you 3.8 up iuggage, but it made it easier for ioading the 18 being paid by MES, 19 aircraft, getting it done prior to departure. 19 A. 200.000. 20 Q. is that the oniy reason that you have ever 20 Q. And is 200,000 the most that you?ve ever made 21 gone to the Palm Beach home over the last 18 years, is 21 from NES, 22 to pick up luggage? 22 A. Yes, sirthat $200,000What other reasons have you gone there? 24 bonus that year as wattseveral horns theater equipments, 25 MR. REENHART: Which year are you taiking Larry Visoski October 15, 2009 17 9 1 about? 1 my paycheck. So I don't even know what?s written on the 2 MR. EDWARDS: 2008. 2 top of it. 3 THE WETNESSI That year, i think we skipped 3 Q. That would be something that oniy your wife 4 Christmas bonuses that year. The last bonus might 4 wouid see. l?m assuming? 5 have been 200?. 5 A. You?re right, since she probaon wouldn't know 6 BY MR. EDWARDS: 6 the answer either, because she?s looking at the right 7 Q. if you ever got a bonus from Mr. Epstein column and not the top coiumn. 8 and i'm only deriving this from you using the term 8 Q. Right. When is the ?rst time that you had 9 "Christmas bonus.? 9 heard the name MES, LLC, that company? 3.0 A. Hotiday bonus. 1 0 A. Five, six years, and even questioned what it 1 1 Q. am i correct to assume m? sorry. Am i 1 stood for. And i think to this day i couldn't answer 1 2 correct to assume that if you got a bonus, there was 12 that nonestiy, what it stands for. 1 3 oniy one and it was at the end of the year, around the 13 Q. Okay. But it?s your understanding that the 3.4 hoiidays? 1 4 NES, LLC is paying you for the work that you do as a 1 5 A. Yes. 1 5 piiot or maintain the pianes for Jeffrey Epstein? 1 6 Q. Okay. And how much was the 2007 hotiday 16 A. To my understanding, yes. 1? bonus? 17 Q. And back in 1991, do you know have to ask my wife, to be honest. i 18 different company that was paying you or if it was 1 9 haven't seen my paycheck in 27 years, so i believe it 19 Jeffrey Epstein directly paying you? 20 was 0,000. 20 A. i don't remember. i mean, i don't. 2 1 Q. And in 2007 you aiso made $200,000? 21 Q. Okay. Throughout your career with as a 2 2 A. Yes. 22 pilot for Jeffrey Epstein, since 1991, has there ever 23 Q. Okay. 23 been a time when you believe you were paid directiy from 2 4 A, With a question mark. I'm trying to be as 24 Jeffrey Epstein personaliy versus some company? 25 accurate as i can, but yes. 25 A. Not to my knowiedgeSomething pretty ciose to that? 3. Q. Okay. So whether it was NES, LLC or some 2 A. Yes, sir. 2 other company, it was of a sudden a company name, to 3 Q. Okay. So with the bonus it was 210,000, 3 the best of your knowledge? 4 roughly? 4 A. Exactiy, yes. 5 A. Right. 5 Q. And back in 1991, do you remember 6 Q. Okay. And how tong were you making that 6 approximateiy how much you were being paid that year? "i saiary? A. Fifty-five or 60,000. is maybe what i started. 8 A. Probabiy he was very reiigious about giving 8 Q. Okay. 9 annual increases, so i wouid probably say 2006, you 9 A. You?re going back a tong ways. 10 know, it was we would get increment increases of 10 Q. Yes. 13. five or $10,000 each year. So i wouid say 2006. So it 1 A. i?m trying. 12 graduated, you know, progressive. 12 Q. Your reiationship goes back that far. That's 13 Q. Okay. Do you remember the progression if we 13 why i chose that year. 14 start at 1991? Do you remember roughiy what the 14 A. Right. 15 progression was up through 200772008, when you were 15 Q. Okay. Did you get bonuses even back that far? 16 making $200,000? 16 A. Yes, sir. 17 A. No, twoutdn?t know the progression. 1? Q. And do you remember what your bonuses were 3.8 Q. Okay. Do you remember what you were making 18 appmximately? 19 from - and was NES, LLC the company paying you back in 19 A. 5,000. i mean, that was kind of the -- the 20 1991? 20 starting point. 21 A. I don?t know. I don?t remember. Let me say 21 Q. Okay. in addition to monitary bonuses, were 2 2 it that way. i don?t remember. 22 there ever gifts or any other type of compensation that 23 Q. Okay. When how tong do you remember NES, 23 NES, LLC or Jeffrey Epstein provided you? 24 LLC being the payer of your check? 24 A. Yes. 25 A. Personaily, two years, because We never seen 25 Q. And is that over the span of the 18 years? Larry Visoski October 15, 2009 2 2 3 1 A. Yes. 1 Q. But more so than that, if there's going to be 2 Q. Okay. Tait me what some of those items are. 2 a casual conversation about a pool or a poet heater or 3 A. i remember one speci?caiiy was a poet heater. 3 whatever, it?s going to be with you most likeiy if he?s at Q. Excuse me? a going to be taiking to piiots, right? 5 A. Apooi heater. 5 MR. CREWON: Form. 6 Q. When was that? 6 THE WETNESS: Right. 7 A. 1995-ish. 7 BY MR. EDWARDS: 8 Q. Okay. Why did you get that? 8 Q. Okay. And you feet ttke over the years your 9 A. i had boiit a poet and i didn't have a heater 9 relationship with Jeffrey Epstein has been pretty good? 10 and it kind of iaughed at me saying, "How can you have a 10 A. Yes. 11 poo! without a heater?? So he says, "You ought to get a 11 Q. And you have been cioser to him over the years 12 heater.? 12 as you?ve grown to know him? 13 Q. Where were you when you had that conversation? 13 MR. CRETTON: Form. 14 A. in the airplane. 14 THE WITNESS: The same throughout the same 15 Q. How did he know that you had built a poet? 15 year. We never got any closer than 1991 than are 16 A. Just in generai conversation. 16 with him now. i'rn very professions! at what I do 17 Q. You were having a conversation with Jeffrey and know the iine behrveen being professional and 18 Epstein? 18 thinking you?re somebody?s buddy. 19 A. Yes. 19 BY MR. EDWARDS: 20 Q. And this is something that was happening on 2 0 Q. Okay. So that's not something that you think 23. the airpiane, this conversation? 21. you are? You don?t think you?re his buddy? 22 A. During the ?ight. Yeah. it would have been 22 A. No, sir. 23 iike on cruise or something. 23 Q. Do you consider yourseif his friend? 24 Q. Okay. When you say "during the ?ight.? does 24 A i beiieve so. 25 that -- 25 Do you think he considers you his friend? 22 2 4 1 A. Again, you're going back a long ways. 1 A. i think so. 2 Q. i understand. We?re talking about 1995 right 2 Q. right. What makes you think that? 3 now. 3 MR. Specoiation. 4 A. Yes. 4 THE WITNESS: He's always been kind and 5 Q. You?re having a conversation with Jeffrey respectfui. 6 Epstein. Who is ?ying the airplane? 6 BY MR. EDWARDS: "i A. The auto pilot and there?s two crew. 7 Q. Ever invited you to dinner? 8 Q. Okay- So are you back in the back portion or 8 A. No, sir. 9 is be up in the cockpit? 9 Q. Have you ever associated or socialized with 3.0 A. Up in the cockpit. 10 him during the day at any of his homes? 11. 0. Okay. Jeffrey Epstein sometimes comes up 11 A. Onty during a business reason. 12 there? 12 (21. Okay. What are the other are the pieces 13 A. Just, yeah, in between the two piiot seats. 13 that you believe that Mr. Epstein owns? i know we?ve 14 Q. All right. is that something that was 14 tatked about this Manhattan the Manhattan house. 15 typical, to have conversations tike that? 3. 5 We read the articies about it, the Pairn Beach mansion. 1 6 A. Mm?hrnm. 16 But what other places are you with that 17 Q. Yes? 17 Mr. Epstein owns? 3.8 A. Yes. No nodding. 18 MR. Form; predicate, speculation. 19 Q. And would those conversations be directed 19 THE WITNESS: To answer it inonestiy, i don't 2 0 mainly with you or with the other piiots as weit? 2 0 know speci?caiiy that he owns any of the 21 A. Mainly with me. 21 residences, to be honest. i would only assume that 2 2 Q. i mean, you've kind of been described as the 22 he owns. So if you want me to answer nonestiy, i 2 3 main guy or the main piiot. Wouldn?t you consider that 2 3 don?t know that he owns any of the other. 2 a pretty much your roie, right? 2 4 BY MR. EDWARDS: 25 A. Well, that?s chief piiot. 25 Q. Okay. Welt, what wouid be the basis for your Larry Visoski October 15, 2009 2 5 2 "7 1 assumption that he owns the horns in Patm Beach? 1 Q. Are those private airports? 2 A. He goes there, but i don't assume you don?t 2 A. Public. 3 have to own a house to go to it. 3 Q. Public, okay. Are there any private ianding 4 Q. And not oniy does he go there, you?re aware 4 pieces where you would lend any airpianes in New Mexico? 5 that he spends the night there; he resides there 5 A. There are. 6 sometimes, correct? 6 Q. That you have landed "i A. Yes. 7 A. ?that! have. 8 Q. When he's in Patm Beach, that's where he 8 Q. m- his airpiane? 9 A. He sieeps. 9 A. Yes. 10 Q. steeps? Right. When he's in New York, do 10 Q. Where? 11 you know where he sleeps? 11 A. We have a 4500~foot strip on the ranch. 12 A. No. 3.2 Q. When you say yoorself and somebody"? 13 Q. But you've been to a particutar house in New 3.3 A. The company. 14 York that?s a very large house that we've all read about 3.4 Q. What company? 15 that you picked up Euggage at, right? 15 A. Welt, shouio say -- I see where you're going 16 A. Yes, sir. 16 with that. The ranch owns whoever owns the ranch. 17 MR. CRITYON: Form. 17 The ranch has a runway on it. 18 BY MR. EDWARDS: 18 Q. Okay. And you?ve Eanoed an airplane on that 19 Q. And that home, do you know that - i know that 19 runway? 20 you?re saying that you haven't done a public record 20 A. That ranch. yes. 2 1 search to make sure that Jeffrey Epstein owns it. 21 Q. How many times do you think you've landed 22 A. Yeah. 22 there? 23 Q. But you assume that he does? 23 A. Ten. 24 A. Assuming. 24 Q. Ali right. And have you been inside his 2 5 Q. That's where he sleeps when he's in New York? 25 ranch? 2 6 2 8 1 MR. Form. It A. Yes. 2 THE i assume. 2 MR. Form to the iastquestion. 3 BY MR. EDWARDS: 3 MR. REINHART: Can you clarify, the physicat 4 Q. That's where his luggage is when you pick it 4 ranch or the residences or the structures on the 5 up? 5 ranch? 6 A. Doesn?t mean he owns it. 6 MR. EDWARDS: i don't have a good visuai 7? Q. Right. But that?s where it is? ?i appreciation for it. 8 A. Yes, sir. 8 BY MR. EDWARDS: 9 Q. Do you know of anybody else who owns that home 9 Q. Why don?t you describe it in your words what to in New York? 10 this ranch that we are tatking about kooks likeheard it referred to as the Zorro Ranch. Have you 12 Q. Okay. Have you been to his ranch in New 12 heard that? 13 Mexico? 13 A. I've heard that. 14 A. Yes. 14 Q. That?s the ranch we're ah familiar with, 15 MR. CRETTON: Form- 3.5 we're taiking about where the runway is and everything 1 6 SY MR. EDWARDS: 3. 6 etse? 17? Q. How many times have you been to his ranch in A. Yes. 18 New Mexico? 18 Q. Describe it in your own words, the Landscaping 3.9 MR. Form; predicate. 19 of this ranch. What do we have on it? 20 THE A guesstimate, fifty times, only 20 A. There is a house up on the hill, a Earge 21 due to the fact that we would ?y there. 2 1 house. 22 BY MR. EDWARDS: 22 Q. How big? 23 Q. And where wouid you tend? 23 A. Big. We read 40,000 square feet in the 24 A. Depending upon the aircraft, either 24 paper. 25 Albuquerque or Santa Fe. 2 5 Q. Have you been to it? Larry Visoski October 15, 2009 2 9 3 1 A. Yes. 1 A. Yes, sir. 2 Q. Does that seem like it?s feasible, 2 Q. And he sleeps there? 3 approximately 40,000 3 A. Yes. 4 A. I think so, yes. 4 Q. Okay. Q. What else do we have on it? 5 A. i assume he does. 6 A. There is a compound that has kind of motei 6 Q. You assume he sleeps? 7 room type they call it bunkhouse. 7 A. i do. i think. 8 Q. Where's the bunkhcuse located? 8 Q. Okay. 9 A. At the entrance to the ranch. 9 MR. This is really -- 10 Q. Okay. And what is that primarily used for? 10 BY MR. EDWARDS: 3.1 A. For the people that work on the ranch, they 11 Q. Otherthan the pool heater in 1995, have you 12 reside there. it's aiso a place where anybody that 12 ever received any other gifts on top of the compensation 13 traveled on the airplane would stay. it?s kind of like, 13 from Mr. Epstein? I 3.4 you know, a hotel room. 1'4 A. i did get land on the ranch to build a housethat from the first house that 1.5 Q. What do you mean you got land on the ranch? 6 you described, the 40,000 square foot house? 16 A, He deeded me land to build a home. 1? A. it's probably 4 miles. 3.7 Q. When was that? 1.8 Q. Okay. So the Zorro Ranch is a rather iarge 3.8 A. Ten years ago at least. 19 area of property? 19 Q. Do you know if he?s ever deeded anyone eise in 20 A. Yes. 20 this land on the ranch to build a home? 21 Q. And how many times know we just taiked 21 A. Not to my knowledge. 22 about how many times you've been in the housethat? 23 many limes have you been on that ranch in New Mexico, 23 A. We wouid vacation out there and my wife fell 24 the Zorro Ranch? 24 in love with New Mexico and we were looking for 25 A. Thirty to titty times over the years. That?s 25 property. 30 32 3. a guesstimate. 1 Q. And did you talk to him about that? 2 Q. ls that over when was the ?rst time that 2 A. Yes. He knew i he was aware was looking 3 you went to that ranch? 3 for a home and he says, ?Well, i have so much land, I 4 A. A guess, don?t know when it was, actually, 4 could give you a spot to build a home on." So i built a 5 our first trip, but 1995f94. 5 house. 6 Q. Okay. And do you believe Jeffrey Epstein 6 Q. So how long has a home actuaiiy been on that 7 andlor a corporation owned or controlled by him to be 7' property? 8 the sole ownerof that ranch? 8 A. Nine years. 9 A. don't know any of those detaiis. 9 Q. And that?s a home that you own? 10 Q. Have you ever talked to Jeffrey Epstein about 10 A. Yes, sir. 11 who owns that ranch? 11 Q. And that's a home that was -- when i say "you 12 A. No. 12 own it," is there a mortgage on it or did he give it to 13 Q. Do you know of anybody else who may own that 13 you free and clear? 14 ranch? 14 A. No, no, i paid for the house. i made payments 15 A. Not to my knowiedgeOther than Jeffrey Epstein, do you know of 3.6 Q. All right. So what did he actually give you? 17 anybody eise who regularly stays there when they?re in 17 A. 40uacres of land. 18 New Mexico? 18 Q. That you did not have to pay for? 19 A. Not to my knowledge. 19 A. You know, id have to go back and look. I 2 0 Q. Does Jeffrey Epstein stay there when you're in 20 think it was had to pay something for it. i don't 2 1 New Mexico? 2 remember. 22 A. lie has. 22 Q. How often have you visited that piece -- that tire place? 23 home that you own? 24 A. i don't know if there's a key. 24 A. My wife would spend summers out there with the 2 5 One way or another, he gets in, right? 25 kids. Larry Visoski October 15, 2009 33 35 1 Q. Okay. But that?s on the Zorro Ranch? 1 A. t800 square feet. 2 A. Yes. 2 Q. Were you ever at that house at the same time 3 Q. So in addition to the 50 or so times you?ve 3 when he's at his house that?s on that Zorro Ranch? 4 been to the Zorro Ranch, you've been to your property 4 A. Yes. 5 that's on the Zorro Ranch? 5 Q. Ali right. We started back in 1991 with you 6 A. Yes, which over the years, it?s once~a~year 6 making around $55,000 a year and that has progressed 7 visits. So i mean, it is included in the 50 times that 7 overtime to a point where in 2007 you were making 8 i?ve been there. 8 $200,000 a year. i don?t want to go through every 9 Q. Okay. And did you have a conversation with 9 single year; that wouid take a really long time. But 10 him that led to him giving you or gifting you 40-acres 3.0 the progression, was that on a yearly basis normaiiy or 1 1 of iand? 3.3. after two years or three years? 12 A. We talked about it because he knew i was 12 A. Yearly basis. 1 3 looking for a home out there. 13 Q. Okay. And wouid that normaily be in it; Q. Okay. in gifting you that tend, did you 14 increments of? 3.5 consider yourself at that point in time to be more than 15 A. $5,000. 16 just his piiot, as more of a 1friend? 16 Q. Okay. You?ve taiked about a coupie other 17 A. No. You?re using the word "gifting." i paid gifts that have been given to you from Jeffrey Epstein 18 for the land. i dont recaii what it was. But you use 18 over the years; one is a pool heater in 1995 and now 19 the word ?friend.? i don?t know that a sure, he was 19 some 40 acres of iand on his New Mexico ranch. Any 20 a friend. i 20 other gifts you can think about? 21 Q. Well. did he give Dave Rogers any iand out on 21 A. NO other Qi?s. 22 the New Mexico ranch? 22 Q. Okay. i don?t want to spiit hairs with you. 23 A. No. 23 You obviousiy thought about that answer before giving 24 Q. Okay. When you say you paid for it, i thought 24 it. What other items are you thinking about that he?s 25 that i asked that question, "Did you pay for the 25 given to you or cut you a discount on or otherwise that 34 3 6 1 40~acres?? i thought your answer was. "i don?t know, 1 you feel was compensation for you working for him? 2 i'd have to go back and took." 2 A. I drive a company car. i 3 Are you saying now that you did pay for that 3 Q. Okay. What kind of car? 4 land? 4 A. A Hummer. 5 A. i don?t remember. if there was company car." That's owned by N58, 6 money, it was just for, you know, the iegal purpose of a 6 7 transfer of ownership of the land. ?3 A. No, I think the registration has Zorro 8 Q. Okay. it it was a substantiai amount of 8 Deveiopment on it. 9 money. that's something that you wouid have remembered? 9 Q. What is Zorro Deveiopment? 10 A. on. exactiy. No. it was nota substantiat 3.0 A. beiieve that?s the ranch. or at least it has 11 amount. 11 the name of the ranch. i don?t know what the entity is. 12 Q. Okay. Do you remember approximateiy how much 12 Q. And it?s your understanding that that?s a 13 money you had to give Jeffrey Epstein for that tend? 13 company vehicle? 14 A. i would only be guessing. it might have been 14 A. Yes. 15 five dollars. To my knowiedge, I don?t remember. 15 Q. And where is that vehicie primarily garaged? 16 Q. Okay. So when l?rn saying he gave you the 3.6 A. At my home. 17 130d, 06 may have 802118?? given you the 17 Q. in West Paim Beach or in the Zorro Ranch? 18 A. Sure. 3.8 A. No, here in West Paim Beach. 19 Q. Okay. And to the best of your knowledge, he's 19 Q. All right. And is there oniy one company 2 0 never given anyone eise rand out there? 2 0 vehicle that you?re issuedknowledge. 21 A. Yes, sir. 22 MR. Form. 22 Q. And is that something that was - that you did 23 BY MR. EDWARDS: 23 not have to pay for? 24 Q. Ali right. How big is this house that you 24 A. No, it?s just something ldrive. i mean, it's 25 buiit on the ranch? 25 not titted to me or anything iike that. it?s just a car Larry Visoski October 15, 2009 37 3 9 1 that i drive. 1 Q. And which airpiane was that? 2 Q. Ali right. You?ve worked for him for 18 2 A. the Hawker. 3 years. i don?t even know how tong the iiummer woutd 3 Q. Does he stiil have the Hawker? 4 test, out presumabiy, that's not the car you've had over 4 A. No. 5 the entire 18 years. Have you aiways had a company car? 5 Q. How tong did he have that plane? 6 A. No, I haven?t. no. 6 A. Five years, guesstimate; four or ?ve years. 7 Q. When did you get the Hummer? Q. So sometime in the mid '905? 8 A. Probabiy three years ago. 8 A. Yes. 9 Q. {Do any other members of Mr. Epstein's piioting 9 Q. Did you keep any type of logs or documentation 10 team have company cars? 10 as to who wouid have been dying on that airplane transported any individuais? 1 2 Q. Qniy you? 12 A. The same tags as you possess now are the 13 A. Yes. 13 ?ight iogs. 1 4 Q. And do you know how that decision was made to 14 Q. Okay. 15 get you a company vehicte? 15 A. That?s the standard for the industrythat?s something that you kept, or that 3.7 Q. What do you use that vehicle for? 1? Dave Rogers kept? 18 A. To and from the airport. 18 A. Dave Rogers. 19 Q. Ali right. Do you use it for persona! reasons 3.9 Q. Okay. If there are any documents out there 20 aiso? 2 0 with names of passengers on any of the ?ights involving 2 1 A. i guess, yes. 2 1 pianes owned or controiied by Jeffrey Epstein andlor his 22 Q. 1 mean, that?s your primary vehicle? 22 companies. those would be documents in the possession of 23 A. Yes, or i drive my wife's car. 23 Dave Rogers and not yourseif? 2 4 Q. Which is? 2 a A. Oh, the corporation actuaiiy, they beiong to. 25 A. Type of car? 25 Q. OkayYes. 1 MR. REINHART: That was a compound question. 2 A. A Mercedes. 2 You might want to spiit it in haif. 3 Q. And is that something that was aiso a gift 3 MR. EDWARDS: Okay. 4 from Mr. Epstein? 4 BY MR. EDWARDS: 5 A. No. sir. 5 Q. What documents do you beiieve exist that 6 Q. What type of Mercedes is that? 6 indicate names of individuais that have been passengers 7 A. A i. 430, ten years old- 7 on Mr. Epstein's airpianes? 8 Q. Ali right. Are there any other items 8 MR. Are we going back ail the way 9 company car. the iand in New Mexico. the poet heater 9 from '91 to the present? 10 any other items that Mr. Epstein has given you over time 10 MR. EDWARDS: Sure. 11 as compensation or reward or anything else? 11 THE WETNESS: You?re talking about the Hawker? 12 A. No, sir. 12 BY MR. EDWARDS: 13 Q. And your oniy income is from Mr. Epstein or 13 Q. Any airplanes. What documents wouid there be? 14 his companies? 3.4 A. ?there would he the same: Fiight tops and 15 A. Correct. 1 5 passenger manifests would exist. 16 Q. Okay. And it's been that way since 199?? 16 Q. And are either of those required? 1? A. Yes. 17 A. The fiight tog is required for the aircraft to 18 Q. How did you meet Mr. Epstein or become 18 track times and landings. 1 9 invotved with him in 1991? 1 9 Q. And in the ?ight log, is it required that you 20 A. We heard at the airport that Mr. Epstein was 20 designate the names of the passengers? 21 purchasing an airplane when Dave Rogers and mysetf Were 21 A. No. 22 living in Coiumbus. and we had the opportunity to 22 Q. That's just something that Dave Rogers did on 23 interview with him, and we did and got the job. 23 his own? 24 Q. And this is before he owned the airpiane? 2 4 A. Everybody does that. it?s more for internai 2 5 A. Yes. 2 5 Revenue. Larry Visoski October 15, 2009 4 1 4 3 1 Q. Okay. it something happens. they know who is A. Jeffrey wouid aiways critique Dave's fiying 2 on the plane? 2 and i tried to help Dave and expiain to 3 A. Exactiy, weight and balance. 3 him what Jeffrey likes and doesn?t like. And Jeffrey?s 4 Q. Have you ever kept any ?ight tags that have 4 atso conveyed these Eikes and dislikes. And Dave 5 names of people on the airptane? 5 maintained continuing with certain piioting techniques 6 A. When you say "kept." i have tilted out ?ight 6 that were just not comfortabie to passengers. And this ?i fogs or the passenger manifest, yes. 7 went on through the years, and Jeffrey iust got tired of 8 Q. By "kept" i meant maintained to where they're 8 it one day. 9 in your possession either on paper or computer? 9 Q. What speci?caiiy were Jeffrey Epstein?s iikes 10 A. We keep -- 10 and disiikes with respect to the ?ight of the plane? 11 MR. Can you differentiate a ?ight 11 MR. CRETTON: Let me put in a form here. But 12 iog from the piiot?s log that we showed you 3.2 i don?t know what this has to do with anything in 13 earlier? 13 this case. 14 MR. EDWARDS: Okay. 14 MR. EDWARDS: I understand that. Bob. 15 BY MR. EDWARDS: 3.5 MR. i want to use this for some 16 Q. i?rn talking about -- i don't know that it's 16 other depositions where we we've gone beyond the: 17 caiied a flight tog, a pilot?s tog or any kind of tog. 1? scope. 18 A. They are different. yes. 18 THE WITNESS: The case in point, the last 19 Q. Yeah. i'rn asking about, have you kept or do 19 straw was there was a technique called quiet ?ying 20 you have any documentation that woutd indicate the names 20 where you would retard the throttles well short of 2 1 of passengers that have flown on any of Jeffrey 21 the runway and pretty much giide the alrpiane in. 22 Epstein?s pianos? 22 Wait, if you don?t do that ccrrectiy, you have to 23 A. No. 23 spool the engines up just prior to touching down 24 Q. Either in the form of paper or on a computer? 24 that because you?re Easing air speed and it's an 25 A. No. 25 uncomfortabie sound and testing for the passengers 4 2 4 4 1 Q. Makes that easy. 1 thinking that you?re not going to make the runway. 2 A. Okay. 2 And it was a continuous practice of Dave doing that 3 Q. in 1991, were you the chief piiot? 3 to be neighbor friendiy as opposed to being 4 A. No. 4 passengencomfort friendly. 5 Q. Somebody else was the chief piiot? 5 BY MR. EDWARDS: 6 A. Yes. 6 Q. Okay. "i Q. Who's that? 7 A. Hence, the transfer of power. 8 A. Dave Rogers. 8 Q. Has he ever discussed with you where he wants 9 Q. Ail right. At what point in time did you 9 you to be. whether that is ?stay in the cockpit when i 10 become chief piiot and switched with Dave Rogers? 10 have peopie on the airpiane," or don?t intermingie with 11 A. Six years age; ?ve, six years ago. 11 the passengers or anything else? 12 Q. Why? 12 A. He?s never stated that to us. 13 A. Professionaiism, technique. 13 MR. Could you clarify which "he" 14 Q. What do you mean by that? 14 you?re taiking about? 15 A. The way Dave woutd operate an aircraft, 15 MR. EDWARDS: i'm taiking about Jeffrey 16 Jeffrey knew the difference when i was ?ying and when 16 Epstein. 17 Dave was fiying. 17? MR. Okay. 18 Q. How do you know he knew the difference? 18 BY MR. EDWARDS: 19 A. Just 19 Q. You understood that? 28 Q. He toid you? 20 A. Yes. 2 3. A. Yes. He knew the difference that if he never 21 Q. it's my understanding that in the wait, 22 came up front, he knew who was flying. who landed. 22 tel! me other than the Hawker, what other airplanes have 2 3 Q- And what was the conversation that he had with 23 you fiown for Jeffrey Epstein? 2 a you that resuited in you becoming chief pilot. switching 24 A. A Guifstream. 25 positions with Dave Rogers? 25 Q. Does he stili have that piane? Lanny Visoski October 15, 2009 4 5 4 7 1 A. Yes, sir. 1 and who was on the flightsplane is that? 2 A. One flight i beiieve we went to Sebring and - 3 A. Large corporate jet. 3 another tiight we went to Nassau, Bahamas. 4 Q. How tong has Nassau. Bahamas with? 5 A. Fourteen years; 13, 14 years. 5 A. to have to took at the ?ight tog, but i 6 Q. And other than the what other 6 think it was Sarah, Story and Nadia, i beiieve. i think 7 airplanes does he have? that was the three passengers, to the best of my 8 A. When you say obviousty, these are 8 knowledge. 9 company~owned 9 Q. And it's my understanding that 10 Q. Jeffrey Epstein or his companies. 10 St. James is an isiand that Jeffrey Epstein owns or 11 A. A Boeing 72?. ll controis? 12 Q. Wait, I know that?s avery large airpiane. i 12 MR. CRITTON: Form. 13 think that?s been described by other peopie. so i?m not 13 THE WITNESS: i don't know that he owns it. 14 going to have you do that. But there?s partitions in 14 BY MR. EDWARDS: 15 that airplane in the back rooms of that airplane. 15 (2. Has he ever been to an istand caiied Littie 1 6 right? 1 6 St. James? A. Yes. 17 A. Yes. 18 Q. Several different partitions to where if the 3.8 Q. And have you been there with Jeffrey Epstein? 1 9 pitot comes out of the cockpit, you don't necessariiy 1 9 A. this been there when he was there. 20 see the passengers? 20 Q. Have you flown on an airpiane with him to that 21 A. Yes. 2 1 destination? 22 Q. That?s true? 22 A. No. 23 A. Yes. 23 Ct. Ail right. When you say you've been there 24 0 Okay. 24 when he was there, how did that some about? 25 MR. REENHART: Keep your voice flew into St. Thomas and then hear you. 1 Littie St. James in a helicopterthe heiicopter as wait? 3 MR. REENHART: And so Mr. Wiitits can hear 3 A. Yes. 4 you. 4 Q. How many helicopters are owned or controlled 5 BY MR. EDWARDS: 5 by Jeffrey Epstein andlor corporations associated with 6 Q. Other than the Gnifstream and the Boeing and 6 him? . 7 the Hawker, what other airpianes has Jeffrey Epstein 7 MR. CRITTON: Form. 8 owned over the years? 8 THE WITNESS: At this time, one. 9 A. That is it. 9 BY MR. EDWARDS: 18 Q. And currentiy stilt owns -- or the companies 10 Q. And has that been ?own in the last 13. associated with him own the Guifstream and the Boeing? two years? 12 A. Yes. 12 A. Just for routine maintenance. 1 3 Q. And in the past two years, have you tiown 13 Q. And when you and m- let?s say when Sarah 1 4 those two airplanes? 14 Keiien and Story Coweiis and Nadia flew to Nassau. do 15 A. Just'tor routine ?ights to keep them ioose 15 you know the purpose of that trip? 16 or, you know you know what i mean. 16 A. No. 17 Q. Have those two airplanes been ?own by anyone 17 Q. How long did you stay? 1.8 etse in the last two years? 18 A. Five hours. 19 A. No. 29 Q. Did you pick anybody up there? 20 Q. Have those two airpianes been ?own in the 20 A. No. Meaning passengers? 23. last two years for any reason other than routine 2 1 Q. Yes. 22 maintenanoetype ?ightsWe?ve had one -- two ?ights i think in the 23 Q. What happened? You landed the airptane and 24 past two years. 2 4 then what? 25 Q. And what were the purposes of those fiights 25 A. The passengers left. Dave and i went and had Larry Visoski October 15, 2009 a 9 5 1 lunch. The passengers showed up and we came back. 1 to his isiand?" We never landed on his isiand. We 2 Q. Have you ever stayed at the home that is on 2 landed in St. Thomas. 3 Little St. Jameswas just trying to be exact. 5 Q. Have you known Jeffrey Epstein to stay at that 5 Q. Thank you. 6 home? 6 A. it?s a smait island. 7 A. i don't know that for a fact. "i Q. Okay. So how is it that when Mr. Epstein 8 Q. Okay. Do you beiieve that he is the owner or 8 wants to go to Littie St. James, what is the path that 9 controller or has some interest in the home or the 9 you take to get actually to the isiand of 10 isiand of Littie St. James? 3.0 St. James? 1 1 MR. CRITTQN: Form- 13. A. i don?t understand the question. 12 THE WITNESS: i have no knowiedge of that 12 Q. Wait, you just told me you fly the airpiane to 3.3 being a fact. 13 St. Thomas? 14 BY MR. EDWARDS: 14 A. Right. 15 Q. And you have no belief that that is a fact? 15 Q. And then what? 16 A. Exactly. 16 A. Then sometimes i wouid go get the heiicopter it? Q. When you say you?ve been there when he was or he could also take a boat to the island. But 18 there, how many times has that occurred? 18 normaity the heiicopter?s tocated on St. Thomas. i?d 19 A. Estimating, a hundred times. 19 ?re up the heticopter, come pick him up, drop him at 20 Q. Okay. 2 0 the island and i come back to St. Thomas. 2 3. A. Trying to give an honest answer. 2 1 Q. And when he stays on St. James, you drop him 22 Q. Okay. And in the approximate -- l'm not going 22 off on St. James. i suppose you?re going to teii me you 23 to hold you to a hundred times, but in the approximately 23 don?t know it he stays there or not? 24 hundred times - 2 4 A. Exactly. 25 A. Sure. 2 5 Q. But do you stay 5 52 1 Q. for what period of time are we tatiting 1 A- I don't. 1 mean 2 about? 2 Q. Weil, he either stays there or someone else 3 A. During what period of time? 3 picks him up in a helicopter or he swims away? 4 Q. Right. 4 A. Correct. 5 A. Let's see, when did all this happen? What. 5 5 Q. Okay. You stay on St. Thomas? 6 2007? So eight years prior to whenever he stopped 6 A. Yes. ?i fiying. 3" Q. Okay. is there a piace that you've stayed on 8 Q. ?981'99? 8 St. James, ever? 9 A. Yeah, i guess, yes. 9 A. No, We never. 10 Q. i mean, that sounds like a right 1 0 Q. So in the hundred or more times that you?ve 1 1 A. Sounds about right, yeah. Don?t hoid me to it 1 1 been to the isiand, is it my understanding that each of 12 again. 12 those times you?ve been there to drop off Jeffrey 13 Q. right. 13 Epstein andior any passengers and you've immediateiy 14 A. You?re going hack a tong way. 14 left and gone to St. Thomas? 15 Q. So from approximateiy the ?98f99 time frame 15 A. Yes, sir. 16 when Jeffrey Epstein would fiy to Little St. James, 1 6 Q. You never been inside that home that?s located 17 would you he the pilot? 17 on St. James? 18 A. Yes. 18 A. Yes, i've been inside the home. 19 Q. Okay. And you say that you've been there - i 19 Q. How many times have you been inside the home? 20 thought that you just told me that you?ve been there the 20 A. i mean, ten, ?fteen times. 21 same time he was there, but then i thought the 21 Q. And for what occasion? 22 subsequent question was weti, were you on the ?ight 22 A. We set up the theater system that?s in the 23 with him, and i thought your answer was no. Maybe i 23 living room. 24 misunderstood that. 241 Q. Okay. 25 A. No, you said the question "Have you ever tiown 25 A. So it woutd be there to work to hook up a TV Larry Visoski October 15, 2009 5 3 5 5 or a stereo. 3. Q. It seems to be - i mean, you seem like 2 Q. And do you know Les Wexler?? 2 somebody who has common sense. It seems tike somebody 3 A. No, I don?t. 3 that knows Jeffrey Epstein? at Q. Have you ever met him before? 4 MR. Form. 5 A. i have met him. 5 BY MR. EDWARDS: 6 Q. Do you know of any relationship between Les 6 Q. Correct, Sarah Keiien? "i Wexter and Jeffrey Epstein? 7' A. Yes. . 8 A. i don?t know what to what extent they have 8 Q. right. And do you betieve that there is a 9 a retationship, no. 9 business relationship there or a personal reiationst?rip 10 Q. Do you know if they know one another? 10 there, from your observations? 3.1. A. I don?t know that for a fact. They taik to 11 A. oniy be specuiating. When they get on the 12 one another, so i wouid assume. But I don?t know to -- 12 airplane, my focus is forward and {tying safelyyou know they talk to one another? 13 don't you know, to oniy be guessing at either one of 14 A. We seen them speak to one another at the 14 those two. 15 foot of the airpiane. 3.5 Q. Okay. Have you ever sociaiized with Sarah 16 Q. All right. Have you ever down the 3.6 Keiten? 17 airplane any of the airplanes with Les Wexler as a 17 A. No. 18 passenger? 18 Q. Other than speaking with her on the airpiane, 19 A. No. 19 have you spoken with her elsewhere? 20 Q. Have you ever frown the airpianes with Sarah 20 A. Over the phone, in passing. 1 mean. walking 21 Keiien as a passenger? 2 3. down the street in New York. 1 mean. yes. 22 A. Yes. 22 Q. Why wouid you caii Sarah Keiien or why wouid 23 Q. And do you know Sarah Keiien? 23 she cail you? 2 4 A. Yes. A. She would caii me to scheduie the aircraft for 25 Q. And for how iong have you knovsm Sarah Keiien? 25 a departurei?m guessing, six years. i mean, don?t hair! 1 Q. And have you ever catied her? 2 me to it. I?m not the greatest on length or times, but 2 A. Yes. 3 six. seven years, I think. 3 Q. When?s the last time you taiked to Sarah 4 . Q. How did you meet her? 4 Keiien? 5 A. i guess was introduced. Site was on a ?ight 5 A. A week ago. 6 or ours. 6 Q. What was the occasion? 7 Q. You were introduced to her by whom? ?i A. We were discussing carpet for one of the 8 A. She may have introduced herseif. i mean, 8 aircraft. 9 you're going back a ways. i don't know the official 9 Q. And where was she when you were taiking with 10 introduction, how it went. 10 her? 11 Q. And to your knowiedge, what don?t know. it was over the phone. 12 associated or at?iiated in some way with Jeffrey 3.2 Q. Did she caii you or you caii her? 13 Epstein? 2 3 A. No, i sailed her on her ceii. 14 MR. CRETTON: Form. 14 Q. Okay. And that?s a New York number? 3.5 THE WITNESS: iwouid assume so. I don?t know 15 A. i don't know. it's on speed diet. 1 6 to what ievei or what actuaiiy heriob description 1 6 Q. Do you have your phone with you? 17 is. 1? A. Yes. 18 BY MR. EDWARDS: 18 Q. Could you teii me what that number is? 19 Q. Ali right- Wait, how many ?ights have you 1 9 A. Sure. 20 ?own where she and Jeffrey Epstein have been passengers 20 Q. Thanks, 21 together on one of the airpianes that we've been 2 1 A. Sure. (91?)855?3363. 22 discussing? 22 Q. Which airpiane were you discussing carpeting 23 A. i?d only be guessing again. 23 for? 24 Q. We're talking hundreds of ?ights, though? 24 A. Was actuain - actuaiiySure, sure. a lot of ?ights. 25 heiicopter. Now that i?m thinking about it, the Larry Visoski October 15, 2009 How tong have you known Nadia Maroinkoya? 2 Q. in the last two years, did you teil me the 2 A. i don?t know, five years. A guess again, 3 has fiown? 3 four, ?ve years. 4 A. Yes. 4 Q. Do you know what her relationship is, if any, 5 Q. And where to? 5 with Jeffrey Epstein? 6 A. i have fiown the to Fort Lauderdaie 6 A. i do not know. "i on several occasions for maintenance. We ?own it to 7 Q. Do you know if she knows Jeffrey Epstein? 8 Miami. And i try to fly the helicopter at least every 8 A. iwouid assume so. They taik. iwouid 9 two weeks just either by myseii imagine she knows him. 10 it's important that it keeps moving. 10 Q. And how many times has she been on the 1 1 O. Other than maintenance-type flights, have you ll airpiane or the heiicopter on ?ights at the same time 12 ?own the in the last ooupie of years? 12 as a passenger with Jeffrey Epstein? 13 A. Yes. 13 A. Many. i'd have to took at the tagsthe helicopter? 14 Q. Hundreds of times? 15 A ifiew to Miami with Mr. Epstein. 15 MR. Form. 1 6 Q. When was that? 16 THE WETNESS: Sore. A it was a couple weeks ago or a month ago, i 17 BY MR. EDWARDS: 1 8 think 18 Q. if you were going to, as somebody who has been 19 O. For what? 19 Jeffrey Epstein?s piiot for 18 years, teii me today who 2 0 A. Sorry? 20 the ?ve otosest peopie are to Jeffrey Epstein, would 2 1 Q. For what occasion? 2 Nadia be one of them? 22 A. i think he had a meeting with his attorneys in 22 MR. CRITTON: Form. 2 3 Miami. 23 THE in only be guessing and 24 Q. Today is October the 15th. is this during the 24 specuiating. i have no idea. 25 month of October that you had this flight in the 25 5 8 60 helicopter with Mr. Epstein? 1 BY MR. EDWARDS: 2 A. i?d have to look at the hook to be exact for 2 Q. Okay. Welt, as his oiiot and the person who 3 you. 3 trayeis with Jeffrey Epstein on the majority of his 4 Q. Okay. But it?s either the and of September or 4 flights, who are the peopie who trayei most frequently 5 the beginning of October? 5 with Jeffrey Epstein? 6 A. Yeah. 6 A. l?d have to took at the iogs. 7 Q. How do you know that he was meeting with his 7 MR. REENHART: Can we get a time period? 8 attorneys? 8 BY MR. EDWARDS: 9 A. i believe that he had mentioned that he was 9 Q. in the last ten years, which peopie travei l0 meeting his attorneys. 3.0 most frequentiy with him? 1 1 Q. Did he teii you why? 11 A. l'd have to look at the ?ight logs to give 12 A. No. 12 you an accurate answer. 13 Q. Why did he teii you he was meeting with his 13 Q. You can't give me one singie name of somebody 4 attorneys? Did you ask him? 14 who you wouid say is a frequent fiyer? 15 A. No. 15 A. Sarah. 1 6 Q. Okay. That?s just something that he said to 16 Q. Sarah Kellen? you in conversation? 17 A. Yes. 18 A. Yes, air. 18 Q. Anybody eise? 19 Q. Was there anyone else on the airoiane besides: 19 A. Nadia. 20 you and Mr. Epstein? 20 Q. Nadia Marcinkova? 2 A. Yes. 21 A. Year]. 22 Q. Who was that? 22 Q. Okay. Anybody else? 23 A. Nadia. 23 A. Just mainiy those two. 2 4 O. Nadia who? 24 Q. How about Ghisiaine Maxwell? 25 A. Nadia Marcinkova. 25 A. Not for sometime. Larry Visoski October 15, 2009 63. 63 1 Q. What's your understanding between the 1 Miami? 2 relationship of Ghisiaine Maxweii and Jeffrey Epstein? 2 A. Twenty-titre minutes. 3 A. i don?t realty know. 3 Q. And did they talk to one another during that 4 Q. All right. So when you say youire guessing 4 flight? 5 that Nadia Marcinkova and Sarah Kelien know or are 5 A. No. 6 associated with Jeffrey Epstein, that guess is being 6 Q. They were both compieteiy siient during that 7 made on the with the observation that they have been 7 ?ight? 8 frequent flyers with Jeffrey Epstein on more than 8 A. Yes. 9 hundreds of ?ights on his private plane? 9 Q. Okay. is that typicai when they are on 3.0 A. Yes, that?s what i?m basing it on. 10 ?ights together, especialiy with the heiicopter, where 11 Q. And do you know where hiadia Maroinkova is it you?re in pretty ciose quarters, that they wouid abstain 12 staying these days? 12 from speaking to one another? 13 A. No- 13 MR. Form. 14 Q. Do you know what car she's driving these days? to THE Yeah, it wouid be typicai. It's 15 A. No, i don't. 15 very noisy and communicating in a helicopter is, 16 Q. Okay. Do you know if she?s iiving with 16 you know, not that comfortahie. 17 Jeffrey Epstein these days? 1? BY MR. EDWARDS: 18 A. i don?t know that. 18 Q. Over the last five or six years that you have 3.9 Q. Do you know how Nadia Marcinkova met Jeffrey 19 known or been with Nadia Marcinkova, have you 20 Epstein? 20 heard her and Jeffrey Epstein conversing with one 2 1 A. i don?t. 21 another? 22 Q. Were you on an internationai {tight bringing 22 A. i?ve heard them conversingher into the country from some other country at any 23 what they had said, 1 couici say it I wouldn?t even 24 time? 24 know what they had said to each other. We seen them 25 A. i don?t know. 25 taiking to each other. 62 64 1 MR. REENHART: Can we ciarify? You mean with 1 Q. But you don?t remember a singie speci?c 2 Mr. Epstein or 2 conversation between Jeffrey Epstein and Nadia 3 MR. EDWARDS: No. 3 Maroinkova? 4 BY MR. EDWARDS: 4 A. An honest answer, no. 5 Q. Did you ever bring Nadia Marcinkova from some 5 Q. Okay. Anci the same for Sarah Keilen; have you 6 foreign country into the United States? 6 seen or have you seen Jeffrey Epstein speak with 7 A. I?d have to took at the tog books, honestiy. 7 Sarah Kelien? 8 Q. That?s not something you remember? 8 A. I?ve seen him speak with her, yes. 9 A. No. i mean, she i think shes been on 9 Q. Can you teii me a singie speci?c conversation 10 Europe trips with us, and i think she's returned from 10 that you have overheard between Jeffrey Epstein and 11 Europe with us, but could not say that honestly. 11 Sarah Keiien? 12 Q. On this recent helicopter flight with Nadia 12 A. One thing that comes to mind wouid he make 13 Marcinkova and Jeffrey Epstein, did you taik with them 13 sure we have Oreo cookies on the airplane. it wouid be 14 during that fiight? 14 something completeiy nonchaiant. 3.5 A. No. 15 Q. Okay. And do you know or have reason to know 16 Q. Where did the fiight go from? And obviousiy, 16 of any ernpioyment relationship between Sarah Kelien and 17 it tended in Miami, but where did you ieave from? Jeffrey Epstein? 18 A. West Paint Beach. 18 A. i have no knowledge of any of that. 19 Q. And dict Nadia and Jeffrey Epstein arrive 19 Q. Do you know it Sarah Kelien works for Jeffrey 2 0 together? 2 0 Epstein? 23. A. You know, i don?t remembertrio not know. 22 helicopter and i think they both started walking up- So 22 Q. Do you know if Sarah Keiien schedules messages 23 cion?t know it they came separately or not. i was 23 for Jeffrey Epstein? 24 already at the helicopter. 24 A. i have no idea. 25 Q. How long is that flight from Paim Beach to 25 Q. Has Jeffrey Epstein ever indicated to you that Larry Visoski October 15, 2009 65 67 he is fascinated or infatuated or appreciates or ioves 3. women? 2 or iikes massages? 2 MR. CRETTON: Form- 3 A. i have no knowledge of that. 3 THE WITNESS: No. 4 Q. Ail right. How about Ghisiaine Maxweii, has 4 BY MR. EDWARDS: 5 she ever talked to you about massage therapy or have you 5 Q. You think that this is just a story that a 6 ever overheard her talking about that? 6 bunch of underage women have made upYou certainly read the papers over the last 8 MR. Objection. Now it?s 9 couple of years. correct? 9 argumentative. Who gives a darn what he thinks one 10 A. Not on my top ten iist. i mean, i've read a 10 way or another? If he has personai knowiedge 11 couple artistes, but I'm not one to iocos on that so 11 MR. EDWARDS: You're objecting to the form? 12 much as some peopte would. 12 MR. CRETTON: it?s argumentative. 13 Q. Okay. When the investigation about Jeffrey 13 MR. EDWARDS: You?re objecting to the form? 3.4 Epstein came about. the criminal investigation you?re 1 4 MR. CRETTON: Yes. 3.5 aware that?s what l'rn taiking about. right? 15 MR. EDWARDS: Okay. 16 A. That was East year? 16 BY MR. EDWARDS: 17 Q. Weii, it was a couple years ago. 17 Q. is that something that you believe that a 18 A. Right. okay. 18 bunch of women -- some of which know each other, some 19 Q. Did you speak with Jeffrey Epstein about that 19 don't, some of which have been on the airpiane and some 20 investigation? 20 which haven?t made this up, that Jeffrey Epstein 2 1 A. No. 21 engaged in some sexual conduct with them? 22 Q. Were you told not to speak with him about that 22 MR. Form. 23 investigation? 23 THE What i heiieve doesn?t matter in 2 4 A. i think we knew oursetves that we weren?t -- 2 4 this case, does it? 25 it wouldn?t be proper to even bring right. When you read in the newspapers 1 BY MR. EDWARDS: 2 the allegations that Mr. Epstein was involved with 2 Q. i need an answer. Do you believe it? Do you 3 numerous underage giris for sexuat reasons, were you 3 beiieve these girls made this up? 4 surprised? =1 MR. CRiTiOhi: Form. 5 A. i didn?t beiieve it. 5 MR. REINHART: i?m going to instruct him not 6 Q. Do you believe it today? 6 to answer. Move on. "i A. i don?t beiieve it. 7 MR. EDWARDS: is there a privilege that we're 8 Q. You don?t believe that Jeffrey Epstein was 8 asserting? 9 involved with underage girls in a sexual way? 9 MR. No, it?s irrelevant. it?s 10 MR. CRITTQN: Form. 10 harassment and not likeiy to iead to discoverabie 1 1 THE WETNESS: You?re asking for my opinion, 11 evidence. 3.2 and i don?t think my opinion is relevant in that 12 MR. EDWARDS: i?m going to put on the record 13 matter. 13 right now that it is we are aiiowed discovery 14 BY MR. EDWARDS: 14 into a count. We are also aiiowed discovery 15 Q. i think it?s reievant. Can you just teii me 3.5 into the intent of Mr. Epstein in developing a 1 6 whether today you beiieve that Jeffrey Epstein has 16 criminal enterprise designed to sexually expioit 17 engaged in sex with underage girls? 1? and sexuaiiy abuse underage girls. We beiieve that 3.8 MR. CRITTON: Form; specuiation, irrelevant, 18 in doing so, he associated intentionally with 19 always. 19 peopie of simiiar beliefs that sex with underage 20 THE WITNESS: it?s irreievant. 20 girls is okay, and that there have been many 2 1 BY MR. EDWARDS: 23. discussions with this witness, as wait as many 22 Q. i need an answer. 22 other witnesses with - to insure his protection 23 A. i don?t believe he had sex with underage 2 3 from law enforcement that they not answer these 24 women. 2 it speci?c questions. And thus, the opinions and 25 Q. Or engaged in any sexuai acts with underage 2 5 beiiefs of all of these witnesses that we are Larry Visoski October 15, 2009 6 9 7 3. aiieging associated with this oriminai enterprise 1 A. It's an opinion. and i believe that he has 2 are certainly reasonably caioulated to lead to the 2 not. 3 discovery of admissibie evidence. And if you?re 3 Q. Okay. isn?t it true that at some point in 4 still instructing the witness. based on that 4 time you learned that Jeffrey Epstein has strike 5 proffer, not to answer any of these questions, i?m 5 that. 6 going to continue to ask the questions and you can 6 MR. When you uitimateiy get to a 7 instruct him not to answer and we can go to the 7 good place to break. wit! you let us know? 8 Court. 8 MR. EDWARDS: Let's break now. 9 MR. My response is to his opinion 9 (A break was had at 11:28 am.) 10 whether peopie making aiiegations in this case are 10 BY MR. EDWARDS: i. 1 colluding or making up a story is irreievant to 11 Q. Ail right. Eighteen years of being a piiot 12 what you inst said. So i am going to instruct him 12 for Jeffrey Epstein and in terms of being abie to name 13 not to answer any question that goes to his opinion 13 somebody that you wouid say you've observed with Jeffrey 1 4 of someone else?s motivation or the truth of facts 14 Epstein and would classify that person as Jeffrey 15 to which he has no knowledge. 15 Epstein?s friend, can you name anybody? 1 6 So yes, i?m instructing him not to answer. 16 A. Nadia, Sarah; iust people that we see 17 MR. CRETTON: Let me add in my part, is that i 17 routineiy on the airplane. 18 think you?re certainty not oniy capabie to ask 18 Q. That?s peopie you see routinely in the last 1 9 questions with regard to what his personal 19 ?ve to ten years, right? 20 knowledge is, and if he knows something or he has 20 A. Yes. 2 1 reasonabie basis for it; certainly you are omitted 21 Q. Prior to that time. anybody that you?ve 22 to that information. i think you?ve asked those 22 noticed as Jeffrey Epstein's friend may be Gbisiaine 23 questions and he?s given you straightforward 23 Maxweil? 24 answers as to what he knew or what he didn't know 2% A. What time frame? 25 under those circumstances. And as to what his 25 Q. is that a person that at some point in time ?7 7 2 1 thoughts are on something which he has no factual 1 you wouid classify as Jeffrey Epstein?s friend? 2 basis or even an assumption to know one way or 2 A. i would classify it. i don't know if it?s 3 another is irrelevant. That?s uitimateiy for a 3 true. 4 fact-?nder in this case. 4 Q. But that's oniy because they were on the 5 While it's interesting, it?s argumentative and 5 airpiane together? 6 i don?t think he's i meanYes. 7' question-by?quesiion basis. if he has knowledge, 7 Q. Do you know what Jeffrey Epstein does for a 8 that?s great, but to argue your case with this 8 living in your 18 years of observing and tatking with 9 witness or any other witness doesn?t serve a 9 Jeffrey Epstein? 10 purpose and I think is, you know i think itgood use of our time. i?ii put it that way. 11 0. No idea? 12 But you know, you can go ahead and ask. 3.2 A. No. 13 MR. EDWARDS: I can ask the question and it 13 (21. Ever asked him? 14 the witness is being instructed not to answer, 14 A. No, actuaiiy. i. 5 we?li Eat a judge decide whether he needs to answer 1 0. Ever been curious? 16 the question and whether it?s discoverable or not. 16 A. Sure. 17 MR. REENHART: Absoluteiy. Make your record. 17 Q. Ever done anything to satisfy that curiosity? 3.8 BY MR. EDWARDS: 18 A. if you mean Google it, not realty, actuaily. 19 Q. Do you have any reason to beiieve that Jeffrey 19 i mean. 1 reaiiy have not. 20 Epstein engaged in sexuai activity with underage women? 20 Okay. So in 18 years of traveiing and being 2 1 A. i have no reason to beiieve. 21 the piiot and driving and taking this person, Jeffrey 22 Q. Okay. So as you sit here today, based on your 22 Epstein. from one property in New York to New Mexico and 23 18 years of knowiedge, experience and observation of 23 Florida and around the world. you have no idea what he 24 Jeffrey Epstein, is it your beiief that he has not had 24 does in terms of how he makes money? 25 sex or engaged in sexuai activity with underage women? 2 5 A. No. sir. Larry Visoski October 15, 2009 was produced this ?ight log ieli me if 1 Q. But it?s evident that the piano is being used, 2 i?m using the wrong term. What is this called. this 2 at least for this time period. January of 2002 through 3 hook that I?ve been provided by Dave Rogers? 3 2005, on a fairly regular basis. 1 mean, we're looking a A. I've never seen that book. 4 at January 6th, 11th, 13th, 13th, 14th, right? 5 0. Fit iet you see it. idon't know that it was 5 A. Uh~huh. 6 always in a book, so maybe that?s why you haven?t seen 6 Q. I mean, is that something that YOU 885' 1? it. Tell me what we?re iooking at. 7 accurately re?ects the amount of use of Jeffrey 8 A. Well, judging with the name at the bottom, i 8 Epstein's pianos? 9 hetieve this is Dave?s {tight log, iog book. 9 A. Yes. 10 Q. i didn?t know if it was caiied a flight tog. 10 Q. So he travels quite frequently? 11 A. Piiot tog book, how?s that? That?s the 13. A. Yes. 12 appropriate name. 12 Q. And he travels with many different peopie, 13 Q. it was marked as Composite Exhibit 1 in 13 right? 14 Roger?s deposition, as indicated by the exhibit sticker. 14 MR. CRETFON: Form. 15 We?ll mark it the same in your deposition as weii. 15 THE WITNESS: Yes. 16 MR. Why don?t you refer to it as 16 MR. CRETTON: Can i ask one question? i was 17 his? 3.7 wondering what happened, who has possession of now 18 MR. EDWARDS: Fine. 3.8 what?s the originai Exhibit No. i of Mr. Rogers' 19 BY MR. EDWARDS: 19 deposition? Did you retain it? 20 Q. it?s the piiot tog book of Dave Rogers? 20 MR. The actuai book iisett? 21 A. Yes. 21 MR. EDWARDS: The court reporter took it, 22 Q. And the years provided in this book are 2002 22 right? 23 through 2005; i can represent that to you. I?m going to 23 MR. CRETTON: The one marked as an exhibit, 24 ask you about certain people" that David Rogers wrote 2 4 did you keep that? 25 down as being on the airpiane and i want to ask you if 25 MR. This you know who they are. This person right here is Cindy 1 MR. REWARDS: This is it? 2 Lopez. it seems like she flew on numerous flights. Do 2 MR. Who took it from the deposition 3 you know who that is? 3 the other day? 4 A. No. i heard the name, but i don?t know who 4 MR. EDWARDS: i have this one right now. 5 that is. 5 MR. That?s the only copy? 6 Q. right. is that somebody that you remember 6 MR. EDWARDS: Okay. 7 seeing on any of the ?ights that you were on? 7 MR. So you took the originat? 8 A. What year are we taiking about here? i don?t 8 MR- EDWARDS: Apparentiy. it has the original 9 remember. 9 sticker. to Q. Well, this is January 2002. You?d probably 10 MR. When i say ?the original,? the know how to read this book a little bit better than me, 11 originai copy. Wouid you have someone recreate 12 so 1 don?t know. 12 what you've got and send it to us so we have it? 13 A. He keeps his a iot more current, so i know the 13 MR. EDWARDS: Sure. in tact, why den": i wait 14 name. if she watked in here right now, i wouici probably 14 untii i get the whoie thing and Hi copy all the 15 took right through her, to be honest. 15 pages and send it to you instead of piecemeai. 16 Q. Do you know what af?liation or relationship 16 MR. HOROWETZ: You mean before the transcript 17 she had with Jeffrey Epstein? comes? 18 A. No. 18 MR. EDWARDS: We can copy it. 19 Q. Okay. There are various each row i?m told 3.9 MR. [f you give it to me, i'ii copy 20 by David Rogers is a different ?ight and it indicates 20 it and send it back to you. 21 where it takes off from and where it feeds, et cetera. 21 MR. i have a copy. It iust doesn?t 22 There?s a lot of other information, especiaiiy over on 22 have the exhibit sticker on. 23 this side of the page that i?rn not with, nor do 23 MR. EDWARDS: That?s what was told to me the 24 i need to be. 24 other day, that?s why I took it. 25 A. Right. 25 MR. CRITTON: iwant something i just don't Larry Visoski October 15, 2009 "i 7 7 9 1 want to if you give me a copy, l?il put a 1 that is. does it? 2 sticker on it. 2 A. No. 3 MR. REINHART: Or gust copy the page that has 3 Q. Okay. Do you know what the purpose of nor 4 the exhibit sticker on it. 4 being on the airpiane flight along with Jeffrey Epstein, 5 MR. Sorry. Maxweii and Sarah Kellen would he? 6 BY MR. EDWARDS: 6 A. No. 7 Q. Like on this ?ight, we have l?m 7 Q. Okay. Do you Know how it comes about that 8 assuming that's Jeffrey Epstein, correct? 8 Cindy Lopez gets on that ?ight? l-low does she even know 9 A. Yes, i?ii assume. 9 there's a fiigiit available? 10 Q. Ghisiaine Maxwell, right? 10 A. i don?t know. 11 A. Yes. 11 Q. All right. Well, let?s go down to somebody 3.2 Q. Sarah Kellen? 12 that we may all know a little bit better. February 9th, 13 A. i would assume. 13 2002, there?s a flight that has Bill Ciinton, four 3.4 Q. i mean -- okay. And then this name, do you 14 Secret Service agents and then instead of listing names 15 recognize that person, Alexia? 15 or initiais or anything else, it?s just listed as two 1 6 A. Never heard it. 16 males, one female, Jeffrey Epstein, Ghislaine Maxweil, 17 Q. And then Cindy Lopez? 1? Sarah Kellen and i forget who Dave Rogers told me 18 A, Yes, - 3.8 is- Do you remember who that is? 3.9 Q. You?ve heard that nameheard the name. 20 Q. Okay. Either way, how is it that someone like 2 1 Q. Not sure who that is, though? 21 Bill Ciinton gets on a Jeffrey Epstein ?ight? 22 A. No. 22 MR. Form. 2 3 Q. There?s only one, two, three, four, ?ve, six 23 THE WETNESS: i don't know. 2 4 people on that flight? 24 BY MR. EDWARDS: 2 5 A. Uh~huh. 25 Q. Do you know before the flight takes off that 7 8 8 0 1 Q. That?s pretty typicai of the amount of 1 Bill Clinton?s going to be a passenger on the flight? 2 passengers that you wouid have on a ?ight? 2 A. Yes. 3 A. it varied, sure. 3 Q. And how do you know? How do you get that 4 Q. Okay. But it varied hehween - if we look a 4 information? 5 few lines down, Jeffrey Epstein and Ghisiaine Maxwell 5 A. The day before l'd get a phene call from, say, 6 were the only two passengers. Certainly there were 6 Sarah saying we're leaving tomorrow going to wherever, "3 flights like that as well, right? i and sometimes she?ll say who?s going, sometimes she 8 A. Mm?hmm. 8 won?t. On a case where President Clinton wouio varied from having one or two people 9 board, we would put a littie extra catering on board or 1 0 to six or seven people, right? 10 do that little extra TLC to the aircraft. 1 1 A. Yes. 11 Q. If it's ieaving this says it?s leaving from 12 Q. What's the most people that you remember 12 Min and where is it ianding? 13 traveling on any of Jeffrey Epstein's airpianas? 13 A. HPN i believe is White Plains. 14 A. Twenty?five. 14 Q. Okay. Do you remember that ?ight? 15 Q. Okay. That would be a rarity, wouldn't you 15 A. I remember being on it- 16 say? 1.6 Q. Weii, i mean, if you iook through here, 17 A. Oh, yeah. 1? obviousiy you had Bill Clinton on the airplane ten or 18 Q. Because We looked through this log. i 18 twenty times, right? 1 9 haven?t seen any piece where there were 25, but there 19 A. Yeah. He?s my main focus. remember him 20 are lines that have maybe eight or nine people listed. 20 being on the aircraft, sure. 2 1 A. Right. 21 Q. Do you remember him being on the airplane with 22 Q. Let?s see. There's a flight from 22 younger girls? 23 January 15th - sorry, January 17th, January and 23 MR. CRITTON: Form. 24 January 22nd of 2002 that all had Cindy Lopez. That 24 THE No. 25 doesn?t serve to refresh your recollection as to who 25 Larry Visoski October 15, 2009 8 1 8 3 1 BY MR. EDWARDS: 1 this time with Doug Band, three Secret Service agents, 2 Q. Okay. Do you know what his reiationship was 2 Jeffrey Epstein, Ghisiaine Maxwell and Sarah Kelien. Do 3 with Jeffrey Epstein? 3 you remember that ?ight? 4 A. No. 4 A. Where did we go? 5 Q. Do you know if they were friends? 5 Q. Starts in JFK. 6 A. Assuming. 6 A. Right. 7 Q. But you?re assuming why? Just because he?s on 7 Q. Where is that? 8 his plane? 8 MR. CRETTON: Do you have a date? 9 A. Yeah. 9 MR- EDWARDS: March tch, 2002. 10 Q. Okay. So you assume that the peopie that are 3.0 THE WETNESS: EGGW beiieve is Luton, 11 tisted on here are friends of Jeffrey Epstein?s and 11 Engiand. 12 that?s why they are riding on his plane? 12 BY MR. EDWARQS: 13 A. l'm speculating. 13 Q. Okay. Do you remember ?ying to England? 14 Q. I'm just not familiar with the because We 1 at A. i do remember ?ying to England. ljust don't 15 never been on a private fiight - with the manner in 15 remember that trip. What airpiarte were we in? We were 16 which you go about getting on one ofthese fiights. I 16 in the Boeing. 17 mean, you have to, i guess, know that Jeffrey Epstein 17 Q. Do you remember the purpose of the trip? 18 has a piano, that it's going from a destination that you and want to go to, and that it's avaiiahie and 1 9 Q. Do you know who Doug Band is? 20 those kind of things. Can you teii me, eniighten me 20 A. i heard he?s Clinton?s, how wouid you say, 21 A. Well, it?s not puoticiy offered, no. it wouid 23. assistant. 1 mean, I?ve seen that in the newspaper, 22 he no different than you jumping in your car and knowing 22 seen it on CNN. 23 you're going to the mati. i mean, it?s not puhiic 23 Q. Okay. Did you ever hear that Doug Band and 24 information, you know, where pianes are coming to and 24 Ghistaine Maxweii were together, even for a day or a 25 from, and you don?t put your name out there to get 25 night? 8 2 8 4 1 onboard a ?ight. 1 A. No. 2 Q. Does Jeffrey Epstein charge these peopie as 2 Q. Did you ever hear that Doug Band and Ghisiaine 3 passengers? 3 Maxweii were the people attributed to introducing Bill 4 A. I don't know. 4 Ciinton and Jeffrey Epstein? 5 Q. Okay. Are these peopie such as Bil! Clinton, 5 MR. CRITTON: Form. 6 does that mean that Bili Clinton called Sarah Kelten or 6 THE i don?t know. 7 somebody af?iiated with Jeffrey Epstein to get on the 7 BY MR. EDWARDS: 8 plane or that Jeffrey Epstein caiied Bit! Ciinton and 8 Q. All right. There?s another ?ight here an 9 asked do you want a ride? 9 January - i can?t read this upside down. Maybe it says 1 0 MR. Form; predicate. 10 May 1 1 THE have no idea. 13. A. Looks tike. 12 BY MR. EDWARDS: 12 Q. 22nd, 2002. Again, with President Bill 13 Q. No idea? 13 Clinton, Janice, Jessica. Can you teit me who Janice 14 A. No idea whatsoever. to and Jessica are? 15 Q. Joe Pagano, do you know who that is? 15 A. idon't remember. 1 6 A. Yes. 16 Q. Would you know them if you saw them? 17 Q. What's his relationship with Jeffrey Epstein, 17 A. Probabiy not because the names don?t even ring 18 or what was it back in February sorry, March 1?th of 18 a bell. 19 2002, when he and Sarah Keilen and Jeffrey Epstein and 19 Q. rig ht. And then there are pienty of 20 Todd and one female were on this ttight? 2 0 ?ights, many of {tights where Jeffrey Epstein, 21 A. i don?t know to what extent or what his 21 Ghisiaine Maxweii and Sarah Kelien are the primary 22 relationship is. He just was a passenger on the 22 passengers, or at least are some of the passengers on 23 airplane. 23 the flights, correct? 24 Q. Okay. And the next day sorry, two days 24 A. mehmm, yes. 25 tater on the 19th of March, Biil Clinton flies again, 25 Q. And as you sit here, you being the Larry Visoski October 15, 2009 8 5 8 7 piiot of these ?ights, you're not sure what their 1 we?re referring to the same ?ight on June Zist of 2002, 2 relationship is or whether any of them were sociaiiy 2 that includes Jean Luc Brunei. Virginia Roberts, Jeffrey 3 connected in any test way? 3 Epstein, Ghislaine Maxweii, Sarah Keiien, those are the 4 MR. Form. 4 passengers of this ?ight, does that serve to tog your 5 THE No. When you?re flying the 5 memory 83 to Who ngnia Roberts i8? 6 airplane, there's a iot more going on than 6 A. No. i mean, you see how frequentiy we I 7 passengers' relations. 7 mean, it's the passengers in the back are so far 8 BY MR. EDWARDS: 8 removed from an operation of commanding an airpiane iike 9 Q. Ali right. You remember this person, Virginia 9 that. it?s nothing that in your head. 1 0 Roberts, are you with her at ail? 10 Q. And you as the piiot, is there any way that 1 i. A. i remember the name, that?s it. 11 you wouid know what?s going on in the back of the 12 Q. What do you think her relationship is to 12 airpiane? 13 Jeffrey Epstein? 13 A. No. My concerns are at! on the cockpit. 14 A. No idea. 14 MR. CRITTON: Brad. the last one that you 15 MR. What date are you on, Brad? :6 mentioned. was that the same date, June 213i, '02? 16 MR. EDWARDS: Oh, sorry. tam at June 2ist, 16 MR. EDWARDS: Yes. 17 2002, BY MR. EDWARDS: 18 BY MR. EDWARDS: 18 Q. There's another name here that i was going to 19 Q. That's not somebody that you specificaliy 19 ask you do you know. June 23rd, 2002, Juiiana Baroosa, 20 remember? 20 are you with that name? 2 1 A. Min-mmthat somebody that you think was a 22 Q. Also on the same ?ight with Jean Luc Brunei. 23 reguiar fiyer for any period of time in Jeffrey 23 That doesn?t heip to iog your memory either, right? 24 Epstein?s iifereguiar. 25 Q. That?s somebody that you remember Okay. Jean Loo Brunei. is that a name that 1 frequent passenger? 2 you know? 2 A. Who are you referring to? 3 A. Yes. 3 Q. Juiiana Barbosa? 4 Q. How do you know that name? 4 A. No. 5 A. Only because it?s a unique name and his attire 5. Q. Dr. Jarecki, is that somebody that you 6 is very unique. 30 you remember certain things. So i 6 remember ?ying? "i know he who that is. 7 A. i know the name. He may have been on the 8 Q. you know what he does? 8 airpiane once or twice. l?m guessing onlyyou remember meeting him? 10 Q. Do you know his association with Jeffrey 3.0 A. Yes. i have met him. 11 Epstein, if any? 11 Q. Do you; remember his purpose for being on the 12 A. No, i don?t know what the relationship is. 12 airpiane? 3.3 Q. Have you ever heard of him owning or running 13 A. No, sir. 14 or managing a modeiing company? 14 Q. Amanda Venaro, do you remember her purpose for 15 A. i have seen that in the paper a few years 15 being on the airplane? 16 backOkay. Other than seeing it in the paper, have 17 MR. Can we get a date? 18 you ever taiked to Jean Luc Brunei or Jeffrey Epstein 18 MR. EDWARDS: was asking him if he 19 about owning or running or managing a modeling company? 3.9 remembered Amanda Venaro. i wasn?t referring to a 20 A. No. 20 speci?c ?ight. 2 3. Q. Do you know if Jeffrey Epsteirs?s affiliated 21 BY MR. EDWARDS: 2 2 with the modeiing company that?s owned, run or managed 22 Q. You don?t remember her being on the ?ight? 23 by Jean Luc: Brunei? 23 A. i don?t remember the name. 24 A. No, i have no idea. 24 Q. Me showing you the ?ight isn't going to jog 25 Q. And seeing that this is a ?ight now, that 25 the memory? Larry Visoski October 15, 2009 8 9 9 A. No. The name that woutd iaunch it ?rst -- 1 see her name, that doesn?t change your opinion as to 2 MR. Coutd ask you a question? You 2 whether or not you remember her or what 3 have the original exhibit marked at the deposition. 3 A. i remember the name, you know, that's alt. 4 it iooks like it's been hightighted. 4 Q. Do you remember about what age she was when 5 MR. EDWARDS: I hightighted it. 5 she was ?ying on the airpiane? 6 MR. CRETTON: Oh, okay. So you've highlighted 6 A. No. "i the original exhibit that's marked for the 7 Q. This could be somebody who is 50 years old or 8 deposition? ijust want the record to re?ect 8 ten years old, forall you know? 9 that. 9 MR. Form. 10 MR. EDWARDS: Yeah. 10 THE WETNESS: Yes. 11 MR. Okay. Thank you. 11 BY MR. EDWARDS: 3.2 MR. EDWARDS: At the time 1 hightighted it i 12 Q. Okay. 13 didn't reaiize was hotding on to the origins! 13 A. I mean, twouid only be guessing at an age. 14 exhibit. I didn?t reaiize that until you just 3.4 Q. Yeah, but i mean, you don?t remember her at 15 pointed that out. 3.5 all. So you don?t 16 MR. I've noticed that. 16 A. i remember the name, exactly. MR. EDWARDS: So now when 1 give it to you. 17 Q. Other than the name? 3.8 i'm giving you my work product as well. i don't :8 A. Right, yes. sir. 19 see how this works against you, but anyway. 19 Q. But you can?t even some ciose to putting a 20 BY MR EDWARDs: 20 face with that name? 21 Q. Melissa Staii, is that a name that you 23. A. i mean, no. i mean, it you said drew her 22 remember? 22 picture with i couldn't come ciose to even getting Okay. And then Jean Luc Brunei is somebody 24 Q. Okay. You remember this ?ight where 25 who i noticed fiew relatively frequentiy, so is that why 25 President Clinton, Kevin Spacey and Chris Tucker, 9O 92 1 you - that name jogs your memory a tithe better than 1 Jeffrey Epstein, Ghislaine Maxweii? 2 some of these other peopie? 2 A. Yes. 3 A. He dresses uniquely. 3 Q. From JFK to what is this, 4 Q. in what way? 4 A. LPAZ, that is 5 A. Just ioud ctothes. so something that you would 5 Q. South Africa or something? 6 remember, that's ail. 6 A. No, it?s the Azores islands, Santa Maria. Q. Do you know his rote in Jeffrey?s tits? 7 Q. Do you know the purpose of that trip? 8 A- No. 8 A. That was a fuel stop. 9 Q. Ever heard that he is aftitiated with Jeffrey 9 Q. Okay. And do you know why Chris Tucker and 10 Epstein because they both have a sexuai attraction to 10 Kevin Spacey were on that airplane? 3.1 underage girts? 11 A. No. 12 MR. Form. 12 Q. Did you taiit to them? 13 THE You?re making an assumption on 13 A. They came up in the cockpit and said hetio. 14 that. 14 So they conversed, nothing more. 15 BY MR. EDWARDS: 15 Q. Another name that is on here a few times, l?m 16 Q. Have you ever heard that? 16 speci?caliy referring right now to the dates of 1?1 MR. REINHART: He?s asked you if you ever 17 September 23rd and 24th of 2002, is Ron Burkie. Do you 18 heard that. 18 know who that is, Ron Burkle? 19 BY MR. EDWARDS: 19 A. i know what that is, yes. i didn't realize he 20 Q. it your answer is no, it's no. 20 was on our airplane. 2 1 A. i?m sorry, I thought you said they did. No, i 21 Q. Right now that is the ?rst time that you 22 have not. 22 remember Ron Burkle being on your airplane? 23 Q. Okay. i keep hightighting this name, Virginia 23 A. Yeah. 2 4 Roberts, just because it iooks like somebody that?s 24 Q. You don't know the purpose for him being on 25 regulariy flying on the airplane. But the more that you 25 that airptane? Larry Visoeki October 15, 2009- 93 95 1 A. No. Granted, I'm seeing this for the ?rst 1 BY MR. EDWARDS: 2 time, so I?m trying to 2 Q. Okay. You don?t remember which fiights it 3 Q. Let me ask you that. Because this was given 3 wouid have been where there woutd have been girts under 4 to me at a deposition of Dave Rogers, who i understand 4 the age of 18? was the chief pilot for Mr. Epstein, and now you?re the 5 MR. Form. 6 cheap pilot. but you aiways kind of worked in tandem, 6 THE Wait, 1 wouid have to look at ?7 correct? 7 the ?ight legs. 8 A. Sure; we complemented each other. 8 BY MR. EDWARDS: 9 Q. And you both worked for the same company that 9 Q. It?s not iltegai to have somebody under the 10 ilies Jeffrey Epstein's airpianes, right?ight anyway, right? 11 A. Yes. 11 A. No, not at ailthe presumption, which may have 12 (2. Were you ever aware that you, as piiot, were 13 been i may have been misled here, or 1 may have, you 13 transporting gins under the age of 18 who were supposed 14 know, misunderstood the purpose behind this book or hon 14 to be models? 3.5 it was created. i thought that you had probabiy seen 15 MR. CRETTON: Form. 16 this before at some point in time? 16 THE WITNESS: i had no knowledgeMR. EDWARDS: 18 Q. Did you know that Dave Rogers was keeping this 18 Q. Okay. You never knew who the people on the 19 book? 1 9 airpiane were, what their purpose was, their rote with 20 A. No. i know he keeps a piiot log book. 20 Jeffrey Epstein or Jean Luc Brunei? 21 Q. Okay. But you didn't know he was keeping the 21 A. No. 22 names of the people who were on the airplane? 22 Q. right. Do you know Juiiette Bryant? 23 A. No. it?s not required, so I mean, 23 A. No. i don?t remember that name. 24 Q. So today is the first time that you are 24 Q. Andrea Metrovich? 25 teaming that the names of the people that are on the 25 A. I remember the name. 94 9 6 1 airplane was kept by Dave Rogers? 1 Q. She ?ew frequently at least for a period of 2 A. Yes, in his tog book. 2 time. Do you remember that? 3 Q. Okay. And it?s my understanding when you fly 3 A. Yes. a back into the country through Customs, you have to a Q. [s that somebody that you thought was 5 report the peopie that are on the airplane, right? 5 with the modeling industry or related to the modeiing 6 A. Yes. 6 industry? 7 Q. And who wouid create that document or caii A. No. 8 that information into Customs? 8 Q. Okay. And these peopie, did Jeffrey Epstein 9 A. Whoever the captain was for the day. 9 ever teii you how he was associated with any of them? 10 Q. At times wouid that be youYes. 3. 1 Q. Did you ever wonder how he was associated with 12 Q. Okay. And at times when you wouid come into 3.2 any otthem? I 13 the country with passengers -- weii, not at times. 13 A. No, never interested. 14 Didn't you aiso have to report their date of birth? 1 at Q. And on severai of these - on most of these. 15 A. Sure. 15 the names or initials of the people that are on the 1 6 Q. At times weren?t there aiso peopte that you 16 flight are iisted. Do you know on the occasions where would bring in from other countries into the United 1? it iists genericaiiy two females or three temaies or six 1 8 States that were under the age of 18? 18 femaies. do you know why that was done? 19 A. Yes. 3.9 A. Just because we didn?t know our the 2 0 Q. And at some times those were flights that 20 person's name. We tried to do the best we coutd to keep 21 included Jean Luc Brunei and girts that were under the: 21 the records. 22 age of 18, right? 22 Q. When you say ?we tried to do the best that we 23 MR. CRITTON: Form. 23 could" 2 4 THE i don't remember those flights. 24 A. Dave and l. 25 25 Q. Okay. But the ?rst time that you teamed Larry Visoski October 15, 2009 97 9 9 1 that he kept anybody's names was today, right? 1 at the airport office that i had turned into 2 A. Wait, i didn?t know he kept them in his log 2 connect that has the passenger names on them. 3 book. We would hit out the passenger manifest as 3 BY MR. EDWARDS: ti we're n- having passengers? names in your pilot tog 4 Q. Okay. 5 book, he?s probabiy the oniy person in the world that 5 A. it?s patted a passenger manifest. 6 does that. 6 Q. Okay. 7 Q. Okay. 7 MR. Right. 8 A. So when you were mentioning putting the names 8 BY MR. EDWARDS: 9 down, when you said tomato or mate, you know, [was 9 Q. The passenger manifest, just so i understand 10 referring to the passenger manifest. 1 0 exactty what that is, teil me. Tel! me in your own 11 Q. For each of these same ?ights, then, that 11 words. .12 we're referring to out of this log book that was marked 12 A. it's departure time, the city, the landing 13 as Composite Exhibit 1 in Dave Rogers' deposition, am I 13 time exactiy and the passengers that wouid have been on 3.4 understanding you correctly, then, there would aiso be a 14 that ?ight. 15 passenger manifest for each of these ?ights? 15 Q. And at times on that passenger manifest wouid 16 A. Yes. 16 you list aiso genericaliy tomato or mate? Q. Now, where would i?nd the passenger 17 A. Yes. That was the document was referring to 18 manifest? Who keeps that documentation? 3.8 stating that if we didn't know a personCorporate our corporate of?cefind out a name. We just put in to 20 Q. Which is whom? 20 account for how many peopie were on the aircraft at that 23. A. Up in New York, Darren indyke. 21 time. 22 Q. At what corporatiOn is that, though? 22 Q. Who is currentiy in the custody or controi 23 A. NES, LLC, I guess. 23 sorry. Who currently maintains or has possession of the 24 MR. Do you know for sure? 24 passenger manifest from t898 through the present, 25 THE i don?t know for sure. I mean, 25 through today for those airplanes that you flew related 98 1 1 when you say we would just send them up to New 1 to Jeffrey Epstein? 2 York. 2 A. I currentiy have, which connect has now, 2005, 3 BY MR. EDWARDS: 3 i beiieve, untii the present time. And the records 4 Q. Did you ever keep a copy of them?? 4 previous to that i betieve were turned into counset with 5 A. No. 5 the previous investigation with Jack Goidberger's 6 Q. Why did you keep a passenger manifest? 6 office, i believe. i beiieve they maintain those 7 A. Just for tracking of to have the times on 7 records. 8 there for 8 Q. When you say ?turned into counsel,? there are 9 MR. REINHART: Can I confer with him on one 9 a tot of counsel invoived here. 10 thing before you ask a question? 3.0 A. Jack Goidherger's oftice, i beiieve. 11 MR. EDWARDS: Yeah, yeah. it Q. When you say "the previous investigation," 12 (Off the record discussion.) 12 you're talking about the criminat investigation? 13 MR. Mr. Edwards, tet him amend his 13 A. Exactly, yes, sir. 3.4 prior answer. i think he misunderstood the 14 Q. And you?re aware in that criminal 15 question. 3.5 investigation, obviously, that Jeffrey Epstein pied 16 MR. EDWARDS: i don't know what question we?re 16 guilty to certain charges, correct? amounting the answer to. 17 A. From what i read, yes. 18 MR. Let me ciarify this way: As 3.8 Q. Weii, you did visit him in jail, right? 19 the passenger manifests, they are corporate 1 9 A. Yes. We didn?t taik about that. 20 documents of either JEGE or Hyperion Air, whatever 20 Q. Okay. You know in order to go to jaii, 2 1 company owns the piane. Mr. Visoskt has physical 2 1 though, you have to be convicted of some crime, right? 22 custody of them. He retains them but they?re not 22 MR. Form; argumentative. 23 his documents. They?re the corporate documents. 23 THE Yes. 24 So they?re not in New York. 2 4 BY MR. EDWARDS: 25 THE WETNESS: Those are the ones that i have 25 Q. it wasn?t like he was visiting the jaii and Larry Visoski October 15, 2009 you were visiting and you happened to bump into each 1 Q. And for the passenger manifest prior to 2005, 2 other. You actuaiiy went to see him while those passenger manifests go back in time? 3 inmate in jaii? 3 A. They shouid go back, i guess, to 1991 or 4 A. Right, yes. 4 whenever we started existence. 5 Q. Okay. So when we?re taiking about the 5 Q. And did you turn them over from 1991 at! the 6 criminai investigation, we?re taiking about the criminai 6 way through to 2005? 7 investigation revolving around the aiiegations of ?i A. i don?t know. i didn't turn them in. Dave 8 Jeffrey Epstein engaging in sex acts with minors? 8 Rogers did. 9 MR. Form. 9 Q. Are you in possession of a copy of any of 10 BY MR. EDWARDS: 10 those materials? 1 1 Q. That?s the criminai investigation you're 13. A. No. 3.2 talking about, right? 12 Q. i thought that. you know, ten minutes ago when 3.3 MR. Form. 13 we were taiking about this you said you had them back at 14 THE WITNESS: i don't know the foil de?nition 14 an office or 15 of really what happened there. i know that it was 15 A. That was the of?ce, the airplane of?ce, 16 something to do with soiicitation of prostitution. 16 which t?ue given to Bruce, which is the current log. He That?s all i read. 1? is in possession of them now. i had possession of them. 18 BY MR. EDWARDS: l8 Q. Okay. What he's in possession of wjust so 19 Q. Okay. Were you aware that the aiiegations 19 know what documents are where, he?s in possession of the 2 0 revolved around underage giris or giris under the age of 20 passenger manifests from 2005 through the present? 21 ?i8? 2 3. A. Correct. 22 MR. CRITTON: Form. 22 Q. If I want to obtain the passenger manifests 23 THE WITNESS: i was aware it revolved around 23 from 1998 through 2005, that?s something that i would 24 it, yes. 24 request from whom? 25 25 THE WETNESS: Hetp me out. ThatMR. EDWARDS: 1 MR. REENHART: it you know. 2 Q. Who ?rst made you aware of that? 2 THE i don't know who possesses them 3 A. The newspaper. 3 right now. They were turned into Jack Goidberger?s 4 Q. Were you ever questioned by the police? 4 office a year and a haii or two years ago. 5 A. i don?t know who questioned me, actuaiiy. 5 BY MR. EDWARDS: 6 did have a questioning session, but i don't even 6 Q. You started out by indicating that you sent 7 remember who questioned me. 7 these passenger manifests, or a copy thereof, to Darren 8 Q. Where did that take place? 8 indyke or someone at MES, is that correct? 9 A. I don?t remember. 9 A- Correct. 10 Q. At your house? 10 Q. if i requested them from MES. LLC, that?s 11 A. No. in: thinking it was Jack Goldberger?s 11 somebody at some point in time was in possession of 12 of?ce, or it may have been downtown at the Palm Beach 12 the passenger manifests? 13 County Courthouse or something in that area there. 13 A. Sure. 14 Q. Okay. So it either happened at an attorney?s 14 Q. And NES, address is the one you gave me 15 of?ce that represented 1 at 301 East 66th Street? 16 A. Exactly, yeah, i think so. 16 A. i believe so. I don?t know what address 17 Q. Jeffrey Epstein or the other side? 17 they?re using for that. I know that -- 18 A. Yeah. 18 Q. But Darren indyke's the attorney that i wouid 3.9 Q. And during that questioning, is that when you 19 caii -- 20 turned over the passenger manifest from prior to 2005? 20 A. Yes, sir. 2 1 A. Yes. 21 Q. -- and he could prohahiy steer me in the right 22 Q. And you turned those manifests directiy over 22 direction? 23 to Jack Goidoerger? 23 A. Yes. 24 A. Yes. Actuaiiy, i Dave Rogers did 24 MR. Form. 25 that. I wasn't in possession of those records. 25 Larry Visoski October 15, 2009 5 107 1 BY MR. EDWARDS: 1 hetio. 2 Q. Do you know Arny Taylor? 2 Q. That?s somebody who was on the airpiane 3 A. Yes. 3 muitipie times? 4 Q. How do you know her? 4 A. More than once. i mean, i have no account for 5 A. She was on the airplane. 5 how many times. 6 Q. How oid is she? .6 Q. Weii, We asked you about a bunch of names, 7 A. i have no idea. 7 most of which you don't realty remember, but that's one 8 Q. Age range? 8 name you do remember. 9 A. Twentyeight. 9 A. Yeah, i remember the name, yeah. 10 Q. New? 10 Q. Okay. And that?s somebody who you actuatiy 11 A. Yeah, 28, or maybe if not oider now. She was 11 you would remember the face too? 12 probabiy 28 brobabiy, guess. She was somebody in her 12 A. i might remember Amy?s face. 13 iate 20s. 13 Q. right. Do you remember why she would have 14 Q. So we're taiking about 2003? That?s what Pro 14 ever been on your airpiane? 15 trying to understand. 15 A. No idea. 16 A. i?m guessing. 16 Q. President Andres Postrana, at the time i guess 17 Q. We?re talking 2009 now. We?re saying 28. By 17 that was the president of Coiombia back in February 18 that do you mean in 2003 she was 23 or 24 years oid? 18 sorry, March 20th of 2003. Do you know who that is? $9 A. You?re having me guess on her age. 19 A. I don't remember him being on the airpiane, 28 Q. Yeah. 20 but i know who that is. 2 1 A. i mean, i can?t be accurate. 21 Q. Okay. He's on the airpiane with Jeffrey 22 Q. Somebody between 18 and 25? 22 Epstein, Ghisiaine Maxweii, Sarah Keiien and Jean Luo 23 MR. CRITTON: Form. 23 Brunei? 24 BY MR. EDWARDS: 24 A. Where did we go? 25 Q. At the time you were seeing her back in 25 Q. i'ii [at you took at it. I?m taiking about you want me to guess 1 this tine, ieft out of Paim Beach? 2 Q. No, i don?t want you to guess. 2 A. Paim Beach to Nassau. i'm sorry, i don?t 3 A. i don't know then. 3 remember that one. 4 Q. Wait, if i say between ten and ?fty? 4 Q. When we're saying we?re going down to Nassau, 5 A. That's a range. 5 is that a piece that you frequently went to with the 6 Q. it I say between ten and fifty, you?re not 6 airptane? ?i guessing there anymore. You know she?s in there, right? 7 A. No, not at aii. 8 A. She?s in the middie there, yeah. 8 Q. And is that a route that you wouid take for 9 Q. Okay. How can we narrow that down? We?re 9 the uitimate destination to be Littie St. James? 10 talking about somebody in her 203her 203. 11 Q. If the ultimate destination was Little 12 Q. At ieast that?s what you beiieved? 12 St. James - show me a ?ight where the ultimate 13 A. Yes. 13 destination was Littie St. James. 14 Q. right. is that somebody that you know to 14 A. Yeah, right here. that?s St. Thomas. 15 be associated or friendly with Ghisiaine Maxweii? 15 Q. Okay. So on that ?ight that you just pointed 16 A. i don?t know. 15 to, March 22th, 2003, we have Jeffrey Epstein, Sarah Q. Do you know what her relationship was to 1? Ketten, Cindy Lopez again, Brent Tyndali do you know 18 Jeffrey Epstein or Ghisiaine Maxweii? 18 who Brent Tyndaii is? 19 A. No. 19 A. Yes. 20 Q. Do you know where she is now? 20 Q. And who is that? 21 A. No idea. 23. A. i believe he was the chef. 22 Q. When's the fast time you talked to her? 22 Q. And Magaie Bianchen (phonetic), is that 23 A. i don?t know. What date do you have on there? 23 somebody you know to be a modei these days? 24 Q. February 2003. 24 A. have no idea. 25 A. So, probany that tong ago. i may have said 25 Q. Do you remember that ?ight? Larry Visoski October 15, 2009 him around Jeffrey Epstein? 2 Q. Do you remember Naomi-.Campbeil. picking her up 2 A. No. 3 from St. Thomas along with Jean Leo Brunei? 3 Q. Ail right. a A. tremernber her being on board. idon?t a A. No. 5 remember the ?ight. 5 . Q. Atina Webber, do you know that name? 6 Q. Do you know 3er Pashcow? 6 A. No. 7 Yes. Q. She was on severai ?ights. You don?t 8 Q. How do you know him? 8 remember seeing her? 9 A. He was on the airplanethat somebody you knew at one point in 10 Q. Ali right. And how about Atari Derehowitz, i?rn 11 time to be a friend of Jeffrey Epstein's? 11 sure you know who that is? 3.2 A. He was on the airplane. [don?t know wnattne 12 A. Sure. He?s famous. 13 relationship was. 13 Q. What was your understanding of Aian is Q. Do you know what the reiationship is today? 14 Dersnowitz?s reiationshio with Jeffrey Epstein? 15 A. No idea. 15 A. Never taiked about it- 16 Q. How about Todd Mister, do you know what that 16 Q. Forrest Sawyer, do you know why he was on your 1? relationship is or was today? 17 airplaneNever heard the name. acieaily. 19 Q. Do you remember him? 19 Q. Realtyatt? 21 Q. Larry Summers? 22 A. i mean, i know the name. ldon?t know. 22 A. iknow the name. idon't remember tiying him. 23 Q. Paula Epstein, do you know who that is? 23 Q. Have you ever tatked to Joe Fontaneia? 24 A. Yes. 24 A. Yes. 25 Q. Who is that? 25 Q. How do you know himThat?s Jeffrey's mom. 1 A. He usually drops Jeffrey off at the airport. 2 Q. She?s passed away? 2 Q. in fact, you?ve called him directly before, 3 A. Yes. 3 right? 4 Q. At ieastthat?s your understanding, right? 4 A. Yes. 5 A. That?s what! heard, yes. 5 Q. You stili have his number? 6 Q. Okay. Tila Davies, do you know her? 6 A. i haven't yes, i think i still got it in my ?l A. Tiia Davies, i know the name. 7? memory. 8 Q. Somebody who fiew on the airplane with some 8 Q. Okay. What is it? 9 reguiarity? 9 A. it?s been a few years. (91 ?)945-7500. it?s 1 0 A. Yes. 10 kind of an easy one. 11 Q. And do you know her to be friends of Gnislaine 11 MR. CRIWON: 917 is the ?rst 12 Maxweii or Nadia Maroinkova or Jeffrey Epstein? 12 THE WITNESS: Yes. 13 MR. Form. 13 MR. CRITTON: Who was this for? 3.4 THE WITNESS: i have no idea who she was 14 MR. Joe, Joe Fontanela. 1 5 friends with. 1 5 MR. EDWARDS: Fonianela. 16 BY MR. EDWARDS: 16 BY MR. EDWARDS: 17 Q. All right. Do you know what role she ever 3.7 Q. Do you know his address, where he resides? 18 played, if she played one, in Jeffrey Epstein?s life? 18 A. No, i don'you know if he what his rote is in 20 Q. right. Gienn Dubin, are you with 20 Jeffrey Epstein?s life? 2 1 him? 21 A. Not reaiiy. He just he drove the car. 2 2 A. Yes. 22 Q. He drove what car? 23 Q. How do you know Gienn DubinNew Yorkthe airplane. 24 Q. Okay. Do you know if he?s a housekeeper up at 2 5 Outside of the airplane, have you ever seen 25 that house up in New York? Larry Visoski October 15, 2009 3 1 5 A. i don?t know what his rote is. 3. Q. Do you know did you tell me, do you know 2 Q. Have you ever worked for a company called Air 2 what Lesiie Gruii does for Jeffrey Epstein? 3 Ghistaine? Do you know that company? 3 A. i don't know her exact title. 4 A. Yes. 4 Q. You taiked to at! of these individuals at some 5 Q. Do you know what that company does? 5 point in time, either on the phone or in person, right? 6 A. No. 6 A. Yes. 7 Q. Have you ever been an empioyee of that 'i Q. And you don?t know whether they play a roie in 8 company? 8 Jeffrey Epstein's life, or if they do, what they do? 9 A. No. 9 A. Exactiy. 10 Q. Do you know who runs that company? 10 Q. And how do you decide who you?re going to caii 3. it A. No. 11 for what reason? 3.2 Q. is Jeffrey Epstein associated with that 12 A. For example? Can you be more speci?c? 3.3 company? 13 Q. if you?re going to make a teiephone caii and 14 A. i don't know. 14 you?re going to taik to let?s say Lestie Grutf, why 1 5 Q. How have you heard of that company? 3.5 woutd you choose to catt her? 16 A. it's the company name that our registration 16 A. [don?t know. You?re having me make the phone for the heiicopters is under, Air Ghislaine. salt. 1 don?t know why would caii her. 3.8 Q. is that somebody who?s ever paid you, a 3.8 Q. Have you ever caiied her? 1 9 company who?s ever paid you? 19 A. I think, yes, No caiied her, sure. 20 A. No. 20 Q. Why? What wouid he the reason that you wouid 2 1 Q. Do you know igor Zinoviev? 21 caii her? Somebody told you to cat! her? Here, catt 22 A. Yes. 22 this number? 2 3 Q. How do you know him? 23 A. i may have called her maybe that him on the airptane. 2 4 had a departure time for any specific trip. I mean, 25 Q. What is your understanding of his af?iiation 25 that woutd 1. 4 1 6 1 with Jeffrey Epstein? 1 Q. Okay. So you?re calling her related to 2 A. 1 don?t know. He doesn't tafk much. 2 Jeffrey Epstein? 3 Q. Okay. And Sandy Berger, do you know who that 3 A. Sure. 4 is? 4 Q. Okay. So you know that she piays some role in 5 A. don't know. 5 some aspect of Jeffrey Epstetn?s life, whatever that is? 6 Q. Do you know any reason why you woutd have 6 A. Right. 7 frown him on the airptane? 7 Q. Okay. So when t'm asking these questions 8 A. don't even know the name. 8 about these peopte. and 1 feet tike I?m getting answers 9 Q. Adrianna Muchinska? 9 that l'm not really not sure that these people have any 10 A. i know the name Adrianna. 10 role in their tife, that?s not that?s not comptetely 3.1 Q. Somebody who ?ow on the piane pretty 11 accurate, right? 12 regulariy? 12 MR. CRITTQN: Form; argumentative. 3.3 A. lwouid have to look at the logs. I think 13 BY MR. EDWARDS: 14 we've had that name on severai it?s a common first 3.4 Q. I mean, you do know that these people are 15 name. I?m not famitiar reaiiy on who that is. is somehow invoived with him, whether sociatly or 16 Q. What about Betta, do you know who Bella is? 3.6 business-wise or otherwise, and during the course of is that a name you ever heard? 3.7 your years, you've made teiephone caiis on his behatf or 3.8 A. Yes. 18 to coordinate things with them right? 19 Q. Works up in the New York of?ce or something? 19 A. Right. 20 A. Yes. 20 MR. CRETTON: Object to the form. You said 21 Q. Have you ever spoken with Bella personaity? 21 "these peopte.? 22 A. Yes. 22 BY MR. EDWARDS: 23 Q. Do you know what she does for Jeffrey Epstein, 23 Q. I?m taiking about Sarah Kellen. That?s 24 if anyt ing? somebody you catted before, right? 25 A. don't know exactly what her role is. 25 A. Sure. Larry Visoski October 15, 2009 What wouid be a reason you caiied Sarah 1 BY MR. EDWARDS: 2 Kellen? 2 Q. Do you remember making that phone cali after 3 MR. Object to form. Probably the 3 reading the message? 4 same reasons he said two hours ago, for scheduiing 4 A. Let me look at the date here. Okay. March. 5 purposes. But you?ve covered that. Go ahead and 5 MR. REENHART: The question is, do you 6 answer it again. 6 remember making the cali? 7' THE For scheduiing purposes, wouid 7? THE Okay, let me. ?Person tor the 8 be my oniy reason to caii her. 8 car wilt be here in 15 minutes to drop off foam and 9 BY MR. EDWARDS: 9 papers." [don't know. 10 Q. That?s funny that you used the exact same 10 BY MR. EDWARDS: 3. 1. words that Mr. Critton wants you to use. 11 Q. That doesn?t mean anything to you? 12 MR. CRITTON: It?s what he said two hours ago. 12 A. That doesn't - i mean. you?re taiking four 13 BY MR. EDWARDS: 13 years ago. i can't answer that accurately. i 14 Q. What wouid he the reason why you wouid cat: 14 MR. So the answer is you don't 15 Ms. Maxweii, Ghisiaine Maxwell? 15 16 A. Same reason. 16 THE WITNESS: Yeah, i don?t recali. 17 Q. That's not somebody you caii these days, 17 BY MR. EDWARDS: 18 though, right? 18 Q. it you don?t remember, that?s ?ne. 19 A. i haven't seen her in some time. 19 (Piainti?'s Exhibit Nos. 2 AND 3 were marked 20 Q. What made you stop Ghisiaine Maxweii 20 for identi?cation.) 2 where you thought at one point in time you thought she 21 BY MR. EDWARDS: 2 2 was a person to call related to yourjob? 22 Q. So l'ii show you Exhibit 3, the same type of 23 A. dust was no reason to. 23 document, and I can make the representation that this 2 4 Q. Is that somebody who you think is stili 2 4 was message pads provided by the state attorney's of?ce 25 af?liated or associated with Jeffrey Epstein or his?? 25 reiatiye to the criminai investigation revoiving around 1 1 8 2 1 whatever he does? 1 Jeffrey Epstein. So that's how i have these documents. 2 A. only can speculating. i don?t know. 2 i?m not trying to puii out old documents. 3 Q. right. Do you know the number 3 MR. CRETTON: What?s the date? 4 (917)868-6145? at MR. EDWARDS: March 19th. 5 MR. Couid you say it siowiy. 917? 5 MR. REENHART: The question is, do you 6 MR. EDWARDS: 868-6145. Thank you. And just 6 remember the ssh? ?i in case you didn't get it. i?m going to mark these 7 THE WETNESS: "Torn from Midnight Express is 8 as an exhibit so that we can read them tater. 8 at? heip me out "convention center with new 9 BY MR. EDWARDS: 9 boat. They are two points two parts of this." 10 Q. Do you know that number? 10 BY MR. EDWARDS: 13. A. Yes. 11 Q. "Show"? 12 Q. What is that number? 12 A. "Show up the water? 13 A. That?s my cot! phone. 13 MR. REINHART: ?On the water.? 14 Q. Okay. Is that your ceil phone? 14 THE WITNESS: "On the water and at the 15 A. Yes. sir. 15 center.? 16 Q. Ali right. i?m going to show you two 16 BY MR. EDWARDS: 1? documents here or pieces of paper. We'il mark them as Q. Do you remember making that caii? 18 Exhibit 2 and Exhibit 3. The first one is dated 18 A. No. i mean, "Torn from Midnight Express is at 19 March 51h, 2005. Do you remember making this teiephone 19 convention center with new boat. They are two parts 20 caii? And just for the record. this looks titre a 20 of? -- i mean 21 message that?s being taken reiative to a phone cali that 21 Q. But as Jeffrey Epstein?s pilot, why wouid you 22 you made. 22 be teaving such a message about Tom from Midnight 23 MR. REZNHART: So the question is does he 23 Express relative to boats and a boat show? 24 remember making the phone caii? 2a A. netp out with heat purchases or, you know, 25 25 anything to do with, you know, that moves. So i mean, Larry Visoski October 15, 2009 consuited with you on each of those 2 Q. Okay. When you say "you heip out with heat 2 purchases? 3 purchases," what do you mean? 3 A. Not every one of them, no. 4 A. Give my opinion, whether or not whether to buy 4 Q. Does he own any boats new that you're aware 5 a certain boat. it?s just a hobby. i have knowledge on 5 of? 6 boats. Not onlyjust airpianes but, you know. 6 A. i don?t know if he owns them or not. 7 Q. You give your opinion to whom? 7 Q. Okay. Do you know of any boats that he 8 A. To Jeffrey. 8 controls or maintains? 9 Q. Okay. And Jeffrey Epstein obviousiy, at toast 9 A. Himself or? 10 in your mind, you beiieve he wants your opinion? 10 Q. i-iow about this l?ii ask you this way. i A. Yes. 11 don't want to spiit hairs with you here: i know we?ve 12 Q. Okay. So boats is another thing that the two 12 been talking about corporations and things tike that. 3 of you have discussedYes. 14 Q. Do you know of any boats that he is the person 15 Q. right. And so this a conversation or at 15 with the most controi over? 1 6 least some evidence that a conversation existed between 1 6 A. Yes. 3.7 yourself and Jeffrey Epstein relative to a boat or a 17 Q. Okay. Where wouid those boats be located and 18 boat show? 18 what kind of boat are we talking about? 19 A. Correct. 1.9 A. St. ?thomas is the location. it wouid he a 2 0 Q. Do you remember having that conversation? 20 34~foot in?atable boat. 1 know that one specificatiy. 2 1 A. We've had many conversations about boats and 21 Q. Okay. Do you know when he made that purchase? 22 different boat shows. If you're referring to this one 22 A. Eight years ago, seven years ago'05, i don?t recaii this one. 2 3 white ago. - 24 Q. Okay. So aside from being a piiot which 24 Q. is that something you had had input in? 25 throughout this entire deposition i believe your 25 A. Not on that one speci?caliytestimony has been, you know, you're gust the piiot for 1 Q. Is there any other boat that you know of 2 him it iooks like there?s some other rote that you?re 2 Jeffrey Epstein being the primary user of or the primary 3 playing here in his iife. for not suggesting that you 3 controlier of? a are or you are not. i?m just saying from the appearance 4 A. i mean, there's boats in St. Thomas. i mean, 5 of this, it iooks that way. is there anything eise that 5 it's not part of my job. you know, what goes on with the 6 you want to teli me or that you want to clarify in terms . 6 boats or who controlied them. it?s more of an opinion of the roie that you ptay in Jeffrey Epstein?s life 2 of what horsepower shouid be on the back of the boat, 8 outside of being just his piiot? 8 huii designs. it?s out of my area. 9 MR. REINHART: Let me object to form. He aiso 9 Q. But your sole responsibility or your sets 10 told you he installs the audio and video equipment 10 obtigation that you have ever had with Jeffrey Epstein 11 before. 11 relative to boats is just giving some opinions about the 12 MR. EDWARDS: Correct. 12 boat? 13 THE WITNESS: i have an interest in boats. 13 A. Mmuhmm. 14 You know, with the isiand, i don?t think i bought 14 Q. is that yes? 15 any boats, you know, for the company, but he 15 A. Yes, yes. 16 appreciates my opinion on heat purchases. 16 Q. Okay. Ali right. Has he ever given you his 3. 7 BY MR. EDWARDS: 7 opinions about boats? 18 Q. Okay. 18 A. Sure. We?ve discussed it back and forth. 1 9 A. Having the knowiedge of aviation and things 1 9 Q. Other than boat conversations, have you ever 2 that move quite fast. So i have oonsuited with him on 20 talked other conversations, such as 2 boat items. 2 1 A. Cars. 22 Q. How many boat purchases are you aware of 22 Q. Okay. How about such as have you ever 23 Jeffrey Epstein making in the time period that you've 23 known Jeffrey Epstein to have a girifriend, somebody you 2 4 known him? 2 4. consider a girifriend? 25 A. Two or three. 25 A. No. Larry Visoski October 15, 2009 years and sit the travels you had i. Q. Did he ever fiy anywhere else with you either 2 with him, do you know anything about Jeffrey Epstein's 2 by heiicopter or airpiane in the last two years? 3 sex life? 3 A. We fiew one time to the Sikorsky plant. 4. A. No. 4 Q. What?s the Sikorsky piant?? 5 Q. Do you know who he has sex with? 5 A. That?s where they build the Sikorsky 6 A. No. 6 heiicopters. it?s in Palm Beach County. 7' Q. Do you know if he has sex with anybody? 7 - Q. And when was that? 8 A. i don't know. 8 A. Probably a month ago, i?m guessing. 9 Q. Do you know if he's ever had sex on the 9 Q. For what purpose? 10 airplane while you've been piloting it? 10 A. They gave us a tour at a facility. 11 A. i have no idea. 11 Q. Who?s they? 1 2 Q. That's something that you just woutdn't know 12 A. Sikorsky. 1 3 because you're up in the cockpit? 13 Q. And who requested the tour of the 14 A. That is correct. 3.4 A. They offered it to our ?ight department. 15 THE Could i take a two-minute 3. 5 Q. And who went? 1 6 bathroom break iust to toss my coffee? i 6 A. Jeffrey, mysetf, Nadia and igor. 17 MR. EDWARDS: Sure. Q. And if i wanted documentation of either of 18 (A break was had at 12:35 pm.) 18 those trips, the trip to Miami or the trip to the 19 BY MR. EDWARDS: 19 Sikorsky giant, who wouid have that documentation? 20 Q. right. We're back on the record. Over 20 A. i wouid. 21 the years you've indicated that the any gifts or 2 1 Q. So i could request it trorn your attorney to 22 other items or things given to you by Jeffrey Epstein 22 get it from you? 23 exclusiveiy are the pooi heater, the 40~acres of iand 23 MR. Let me just check(Off the record discussioncompany 25 MR. Okay. He has custody company car? 1 but they?re corporate documents. So you?d have to 2 A. Yes. 2 request it from Mr. Critton, who i understand 3 Q. That?s it? 3 represents all the corporations. 4 Modding.) 4 THE WITNESS: Yes. 5 Q. Okay. 5 BY MR. EDWARDS: 6 A. Yes, l?m sorry, yes. 6 Q. What?s the corporation that the document was 7 Q. Arid the ?ight to Miami that was reoentiy 7 prepared for? 8 taken, other than Jeffrey Epstein and Nadia Marcinkova, 8 A. Meaning who what, iike Air Ghisiaine, the 9 was there anybody eise on that flight? 9 owner of the helicopter? Yes, Air Ghisiaine. 10 A. No. 10 Q. Air Ghisiaine? 11 Q. How long did you also tiy them back from 11 A. That?s the helicopter. 12 Miami to Paim Beach? 12 Q. And the name Ghisiaine is obviousiy not that 13 A. No. He drove back. 13 typicai of a narne. is that reference or related to 14 Q. When you say "he drove back," who drove back? 14 Ghisiaine Maxwell? 15 A. Well, i assume he drove backwouid assume. i have no knowiedge. 16 him back. 16 Q. Nobody?s ever told you that? 1? Q. When?s the next time you saw him again? A. Nobody?s brought it up. 18 A. twouid only be guessing. A week later, i 18 Q. Okay. And how long were you at the Sikorsky 19 mean. 19 facility? 20 Q. Okay. And was that in Pain: Beach County when 20 A. Three hours, four hours. 21 you saw him the next time? 2 1 Q. And what time of day was this? 22 A. Yes, sir. 22 A. Nine in the morning. Nine, i think, and we 23 Q. Do you know of him leaving Palm Beach County 23 returned at one, something like that. 24 in the last two years on any other occasion? 24 Q. And was the purpose to buy or purchase 25 A. No. 25 anything? Larry Visoski October 15, 2009 12 9 13 1 1 A. They have a new heiio0pter being deveioped 1 Q. Back in his of?ce? 2 there, so they?re trying to look for investors in it. 2 A. Yes, sir. 3 So they were just kind of pushing their product. 3 Q. What was that conversation? 4 Q. Do you know what Jeffrey Epstein does for a 4 A. Give me a time frame. i mean, i?ve been there 5 living for business today, these days? 5 several times. 6 A. No. 5 Q. Okay- How many times do you think you've been 7 Q. Do you know or have you ever been to the ?i to the Fiorida Science Foundation? 8 Florida Science Foundation? 8 A. Twenty, thirty. 1 9 A. Yes, sir. 9 Q. Weii, the Florida Science Foundation?s oniy 1 0 Q. And do you know what the Fiorida Science 10 been around since late 2630?; is that right? 11 Foundation does? 11 MR. Fonn. 12 A. Not exactly. 12 BY MR. EDWARDS: 13 Q. Well, generally? 13 Q. Something around that? 14 A. No, idon?t. i mean, realty, i don?t. 14 A. idon?t know exactly. 15 Q. Okay. is it your understanding that Jeffrey l5 Q. right. So in the last 20 years in the 1 6 Epstein is somehow affiliated with the Florida Science 16 last couple 0? years you?ve been there 20 0f 30 times. 1? Foundation? 17 approximateiy? 18 A. it's my understanding that, yes. 18 A. Yes, sir. 19 Q. i mean, did you just by happenstance siumbie 19 Q. And during those times when you?ve been there. 2 0 into the Fiorida Science Foundation, or was it rotated 20 without having to go through each conversation, did you 2 3. to your reiationship with Jeffrey Epstein? 21 ever taik to him about the fact that he was on probation 2 2 A. We heard that?s where his of?ce was. i 22 or that he was 23 mean, i have no other there? 24 Q. any part of the criminai investigation? 25 A. Taik about airplanes- 25 A. No, not at allTaik to who? 1 Q. What was the purpose of the conversation? 2 A. Jeffrey. 2 A. We were sometimes talking about We. you know, 3 Q. Jeffrey just happened to be at the Fiorida 3 the iatest piasrna that?s out there, LCD, you know, 4 Science Foundation? 4 setting up a stereo systems, you know, in the Palm Beach 5 A. Yes. 5 house. That's usuaiiy the main thrust of our 6 Q. How did you know that he was going to be at 6 conversations these days. the Florida Science Foundation? 7 Q. How wouid you know to go to the Florida 8 A. He sailed me and toid me. 8 Science Foundation on each of those occasions? Wouid he 9 Q. And he said come to the Florida Science 9 just calf you? 1 0 Faundation to {aik to me about what? 10 A. Yeah, he would cail me and say come Maintenance on the airpianes, upcoming. It's 11 got a broom?: 0n 3 new Semi-Eng- 12 an ongoing. 12 Q. With each time you were at the Florida Science 13 Q. And did he have an office there? 13 Foundation, how tong wouid you stay typicaily? 14 A. Yes. 14 A. Ten, fifteen minutes. Not much more than 15 Q. So this is when you walked in, this is the 15 that. 1 6 piace that?s right next to Jack Gold berger?s office? 16 Q. You wouid go there for ten or ?fteen minutes. 1 MR. Form. 1? have a conversation about a TV and ieave? 18 THE Yes. 18 A. Yes, sir. 19 BY MR. EDWARDS: 19 Q. Why couidn?t you have that conversation over 20 Q- And you walk in and there?s a reception desk 20 the phone? Whatwas it about? 21 right there? 21 MR. CRETTON: Form. 2 2 A, Yes, 22 THE if it was pertaining that where you taiked or did you talk 23 3'6 have a broohure, a picture (lithe TV -- one 2 4 somewhere behind that reception desk? 2 4 Da?iwiaf TV We i?oked at if was the Size Of a -- 2 5 A. Behind the reception area. 25 like ?ve foot diagonai, so i had a photo of myseif Larry Visoski October 15, 2009 1 33 1 35 1 standing next to it or the satesperson. So i mean, 1 A. We've landed in Paris. 2 there's a reason to visuatiy show him something 2 Q. You're aware that he has some control over 3 reference to that. 3 another piece of property over there? 4 BY MR. EDWARDS: 4 A. i know we?ve picked up luggage at a residence. 5 Q. Did you ever communicate with Jeffrey i don?t know to what extent his ownership is, it any. 6 Epstein you can send him an e-mail, right? You couid 6 Q. All right. 7 have done that? 7 A. Right. 8 A. Yes. 8 Q. And are you aware that he has some empioyees 9 Q. To send him the picture or something titre 9 that iisten to what he says that work in that house? 10 that, that was an option? 10 MR. Form. 1 1 A. Right. 11 THE WETNESS: in Paris, yes, there is one 12 Q. And what's Jeffrey Epstein?s e?maii address 12 person there. 13 that you use? 13 BY MR. EDWARDS: 14 A. I have to do it on my computer, you know, 14 Q. What?s his name? 15 with - i have to type in the prompts for it because is A. Voltzan. Because i aiways thought there was 16 it?s a long e?mail address. 16 nobody there. 1? Q. Okay. How tong have you e?mait corresponded 17 Q. Vuttzan Cauidron (phonetic)? 18 with Jeffrey Epstein? 18 A. don?t know exactiy. lwoutd have to look it 3.9 A. Probabty two years. A year to two years. i 19 up. 20 mean, it?s fairiy something we iust started doing. I 20 Q. Have you talked to him before? 21 mean, we?d never done that in the past. 21 A. No. 22 Q. Watt, in the past he was in jait or have some 22 Q. When you?ve been in Paris 23 restrictions? 23 A. You?re not going to ask why? 24 A. The restrictions, yes. 24 Q. Welt, i'm assuming he doesn?t speak Engiish. 25 Q. So you you'd see him on the airpiane 25 A. There you go, okay. 134 1 3 6 frequentiy? i Q. So i thought there was no need for that? 2 A. Exactiy. 2 A. Okay. just wanted to see. 3 Q. So when you didn?t see him on the airpiane 3 Q. Where do you stay when Jeffrey Epstein is in 4 frequently, than some of your correspondence was by 4 Paris? 5 e-maii, other times by telephone? 5 A. A hotel. 6 A. Mm?hmm. 6 Q. Okay. And in New Mexico, when you tend there, "i Q. And other times in person? 7 you stay on the ranch somewhere, but at your place? 8 A. Yes. 8 A. 1 stay at my piece. 9 Q. And what was your e-maii what was the 9 Q. And in New York, you have an apartment that he 18 substance of the eurnaii correspondence that you would 10 sets you up at, right, the 301? 11 have with Jeffrey Epstein? 11 A. Yes, have a place could stay. 12 A. it wouid have to be retated. i mean, you have 12 Q. And in St. Thomas? 13 to give me a topic. i mean, whether Hotei. 3.4 Q. Never about the onminai investigation? 14 Q. And in Paris you stay at a home? 15 A. Oh, no, no, never. 15 A. (Modding) 1 6 Q. Do you know what his intention is or his plans 16 Q. Are there any other properties such as what we 17 are for when he is off probation? were tatidng about today t?m not saying Jeffrey 18 A. No idea. 18 Epstein is the sets owner or direct owner, but any other 3.9 Q. Or off community controt? 19 properties that you're familiar with that Jeffrey 20 A. have no idea. 20 Epstein is -- has direct access to and at least it gives 2 1 Q. Has he ever indicated to you he wants you to 21 the appearance to you that he is the owner or controller 22 tiy him to some other iocation outside the United States 22 of that property? 2 3 to iive permanentiy? 23 MR. FormTHE WITNESS: Name the list that you?ve 2 5 Q. Have you ever flown to his place in Paris? 25 stated. Larry Visoski October 15, 2009 MR. EDWARDS: 1 BY MR. EDWARDS: 2 Q. The Manhattan house. 2 Q. And ask you about some of the aliegations in 3 A. Yes. 3 here and see if you know anything about them. it a Q. Mansion or whatever we want to caii it, the 4 indicates he owns a ?ight of aircraft that inciudes a 5 Zorro Ranch, the island of St. James, the Paint Beach 5 a helicopter, and a Boeing 727. True? 6 house. 6 MR. CRITTON: What's the question? 7 A. Mm-hmm. 7 THE WITNESS: Piease repeat. 8 Q. And the Paris piece. 8 BY MR. EDWARDS: 9 A. That?s alt i?m aware of. 9 Q. Are you aware of him owning a iV 10 Q. And have you ever at any of those ?ve pieces 10 aircraft, a heiicopter and a Boeing ?3?27? i think we 11 hung around him and stayed around him for -- during the 11 taiked about it, right? 12 daytime for the course of an entire day? 12 A. Right. 13 A. No. 13 0. Okay. And it indicates a ?eet of motor 14 Q. Ali right. So do you know what he does during 14 vehicies? 15 his days while he's there? 15 MR. Wait a minute. He said right, 16 A. No. 16 is that we taiked about it, as distinct from him 1? Q. Are you aware of a list of underage giris that 17 knowing one way or another. 18 is kept to come over and service him each of those days? 18 What?s the question? 19 MR. CRITTON: Form. 19 BY MR. EDWARDS: 20 THE WITNESS: Absoiuteiy not. 20 Q. Do you know that he owns those things? 21 BY MR. EDWARDS: 2 A. i do not know that he owns them. 22 Q. i?m the ?rst person to ever even imply that 22 Q- Do you believe that he owns those things? 23 to you, right? 23 MR. Form. 24 A. A iist, yes, you are. 24 THE WITNESS: i wouid be guessing, 25 Q. Okay. Have you ever been made aware that 25 1 38 3.4 0 1 Sarah Keiien keeps a iist of underage girls to service 1 BY MR. EDWARDS: 2 Jeffrey Epstein for sexuai purposes? 2 Q. What does the company NES, LLC, do to your 3 A. i am not aware of them. 3 knowiedge? 4 MR. CRETTON: Form to the last question. 4 A. i have no idea. 5 BY MR. EDWARDS: . 5 Q. How does that company generate pro?t, it you 5 Q. Have you ever been made aware that Ghisiaine 6 know? 7 Maxwell keeps a list of girts in the nearby areas of ?i A. i'have no idea. . 8 each of at Jeffrey Epstein's residences to service 8 Q. That's the company that pays your paycheck, 9 him sexuaiiy? 9 but you have absoiuteiy no ciue what they do to generate 10 A. No. 10 money? 1 1 MR. Form. 11 A. No, sir. 12 MR. EDWARDS: 12 Q. if anything? 13 Q. Okay. Have you ever read some of the 13 A. Correct. 14 compiaints that have been fried against him in the 1 4 Q, Have you ever heard that that company 15 various courts, whether state court or federai court, 15 generates money through sex trafficking of young girls? 16 against Jeffrey Epstein? 16 MR. CRITTON: Form. 1? A. No, i have not. 17 THE WETNESS: Absoiutely not. 18 Q. right. So this Jane Doe 102 versus 18 BY MR. EDWARDS: 19 Jeffrey Epstein, you?re not familiar with who that 19 Q. Never, okay. Have you ever heard that Jeffrey 20 person is? 20 Epstein has a sexuai preference for underage giris? 2 1 A. No idea. 2 1 Other than what you've read in the newspaper, have you 22 Q. Okay. i'm going to mark Jane Doe, one of the 22 heard that from any other individuais before? 23 22, versus Epstein as Exhibit No. 4 to this deposition. 23 A. No. 2 4 (Piaintitf?s Exhibit No. 4 was marked for 24 Q. Ever heard that he has had sex or sexuai 2 5 identi?cation.) 25 relationships with many minor girls, some as young as 12 Larry Visoski October 15, 2009 4 1 4 3 1 years did? 1 about that? 2 MR. Form. 2 MR. REINHART: Hoid on. The question is have 3 THE No. 3 you ever been toid that fact that he just read to 4 BY MR. EDWARDS: 4 you? 5 Q. Never? 5 BY MR. EDWARDS: 6 A. Never. 6 Q. Right. 3? Q. Have you ever seen any photographs in any of 7 A. have never been toid that fact. 8 his homes depicting young~looking girls engaging in sex 8 Q. Has anybody ever questioned you about your 9 acts? 9 possible invoivernent with helping to 10 A. No. 10 Mr. Epstein have sex with underage giris? 11 Q. Or reading directiy from the compiaint, 1 A. No. 12 ?engaged in lewd acts?? 12 Q. When you were questioned by either the poiice 3.3 A. No, absoiuteiy not. 13 or the whoever the investigative resource that was 14 Q. Have you iooked around the waiis of his 14 being used at the time? 3.5 various homes when you're in there picking up iuggage? 15 A. Right. 16 A. i mean, not any more than i walked in here and 16 Q. Do you remember who that person was that was 17 not iooking at the waits over there, i couidn?t teii you 17 questioning you? 18 what those are; so nothing speci?c. 18 A. No, i don?t remember. 19 Q. Sometimes we're talking about a 50,090 square 3.9 Q. know you don't know the iocation where it 2 0 foot house? 2 0 was, but do you remember who they were af?liated with? 2 A. ExactiyManhattan? 22 Q. Was it oniy one time? 23 A. It's pretty big. 23 A. Yes. 2 at Q. Okay. Have you ever looked at any of his 24 Q. Did you 8230 have to testify before a grand 2 5 computers for any reason? 2 5 jury proceedingdid not. 2 Q. i know that you hetped set up some of the - 2 Q. Have you ever known ivir- Epstein to get a 3 A. Computers are not my expertise. 3 massage white on an airpiane? 4 Q. right. Have you ever been toid that 4 PHONE This is everybody in Boone, 5 Mr. Epstein committed sex acts against underage giris on 5 Charies and the witness is here and the court 6 a iiteral daiiy basis, that's what he does? 6 reporter and the videographer. "i A. i?ve never been toid that. 7 MR. EDWARDS: Fantastic, but i think that you 8 Q. Have you ever read the complaints against him 8 may have the wrong room. 9 that indicate that?s what he does on a deity basis? 9 PHONE ATTORNEY: 'i was told to ask for 858. 10 MR. CRITTON: Form. 10 MR. EDWARDS: Let?s go off the record. 3. 3. THE WITNESS: No. 11 (Off the record discussion.) 12 BY MR. EDWARDS: 12 BY MR. EDWARDS: 1 3 Q. So in your mind, you never beiieved that you 13 Q. All right. in the complaint, l?m going to 14 were transporting around somebody whose sole goai in 14 teli you what it aiieges and l'rn going to ask if this 15 iite is to get have sex with iittie girls? 15 helps to refresh your recoiiection about any of Jeffrey 16 MR. Form. 3.6 Epstein?s activities. The defendant, Jeffrey Epstein, 7 THE WITNESS: i never beiieved that, no. 1 7 transported the plaintiff to another state in order to 3.8 BY MR. EDWARDS: 18 engage in sex acts with her. And this occurred when she 1 9 Q. Okay. Have you ever been toid that-he 19 was mereiy 15 years old. 20 conspired with others, inciuding assistants andfor his 20 Do you remember transporting somebody that 23. drivers andlor piiots and his friend Ghisiaine Maxwelt, 23. iooked titre they were 15 years old on your airpiane? 22 to further these sex acts and to avoid poiice detection? 22 A. No, sir. 23 MR. Form. 23 Q. You never remember taking a 15?year?otd, or 24 BY MR. EQWARDS: 24 somebody that iooks around that appmximate age, on your 25 Q. Have you ever anybody ever questioned you 25 airpiane?? Larry Visoski October 15, 2009 more specific? 1 Q. To Santa Fe? 2 Q. Welt, i know that you?ve indicated earlier in 2 A. Yes. 3 the deposition that you remember some girls under the 3 Q. To Los Angeles? 4 age of 13 on the airpiane. And so let me ask, before i 4 A. Yes. 5 get back into this, whether ail those individuals you 5 Q. To San Francisco? 6 were taiking about were accompanied by a parent or some 6 A. Yes. 7 - of those people were on the airpiane for some other 7 Q. To St. Louis? 8 purpose, modeiing, or you don?t know why they were 8 A. Yes. 9 there? i?m going to let you on who these 9 Q. All right. Continuing to international 10 peopie are that you hetieve may have been under the age 10 destinations, including Europe, have you ever flown it 1 1 of 18 and why you think they were on the airplane? 1 1 to Europe? 12 MR. Form. 3.2 A. Yes. 13 THE WITNESS: We?ve had younger peopte on the 13 Q. The Caribbean? 14 airplane that have been, you know, with their 14 A. Yes. 15 famiiy members, iike you said. i don't remember 15 Q. And Africa? 16 transporting anybody that was of questionabie age. 16 A. Yes. 1? l?m not i?d oniy be guessing at somebody?s age 17 Q. On those ?ights to those various places, is 1 8 if i didn?t iD them at the foot of the airplane. 3.8 it your to the best of your knowledge, you were 19 So i can?t guess to their age. 19 unaware of Jeffrey Epstein engaging in sex with underage 20 BY MR. EDWARDS: 20 girls on his airplane? 21 Q. Ati right. "Mr. Epstein used his privatejet 21 MR. CRETTON: Form. 22 to transport the minor piaintift to Manhattan where he 2 2 ?ii-1E WITNESS: i have no knowledge of any of 23 provided her spending money and accommodations with him 23 that. 24 at his mansion." 24 or MR. EDWARDS: 25 Do you have any idea who that might be 25 Q. "tie provided accommodations with him in order 1 4 6 4 8 3. referring to? to have her to him at alt times whenever he 2 MR. CRETTON: Form. 2 wanted, including white transporting the minor piaintift 3 THE WITNESS: No, sir. 3 on his private jet.? 4 BY MR. EDWARDS: 4 That?s something that you had no knowiedge of? 5 Q. And you don?t remember being a pilot of an 5 A. (Witness shakes head.) 6 airplane where he was transporting a 15~year?old to 6 Q. You have to a yes or no. 7 Manhattan from Miami or Paim Beach? 7 A. for sorryguessing at somehody's age and 8 Q. ?Each time they would travei to one of these 9 can?t guess. 9 destinations, the same pattern of sexuai abuse wouid 10 Q. "Defendant transported plaintiff in his 10 occur, often with a vast array of aspiring modeis, 11 private jet to locations that inciuded Paint Beach, New 11 actresses, ceieorities, andior other femaies, including 3.2 York City, Santa Fe, Los Angeies, San Francisco, 12 minors from ail over the worid." 13 St. Louis." 13 Again, that's something you have no personat 14 Do you remember ever piioting his airpiane to 14 knowiedge of? 15 those destinations that i iust mentioned? 15 A. No. 1 6 MR. REINHART: Can we break them down? 1 6 Q. Has anybody ever indicated that it you did Objection; compound. I have persona! knowiedge of some of these things, then 18 MR. EDWARDS: Okay. 3.8 you could also have been impiicated in some form of a 19 BY MR. EDWARDS: 19 crime? Has any law enforcement or anybody ever 20 Q. Have you ever down his airplane to Palm 20 indicated that to you? 2 3. BeachYes, sir. 22 Q. Okay. is that something you?ve ever worried 2 3 Q. Okay. Have you ever flown it to New York 2 3 about? 24 CityYes. 2 5 Q. right. "Upon information and oetief, Larry Visoski October 15, 2009 4 9 1 defendant transported minor girls from Turkey.? Did you 1 ever flown to or from in a Jeffrey Epstein airplane? 2 ever leave in one of his airplanes out of Turkey? 2 A. We have flown to Prague. 3 A. I'd have to look at the records. 1 don?t 3 Q. Okay. Have you picked people up in Prague and 4 recall Turkey. 4 flown out of Prague? 5 Q. Do you ever remember taking any minor girls 5 A. I don't remember. 6 out of Turkey? 6 Q. l?m not saying no, you didn't, but 7 A. No, 1 don?t remember. ?3 A. Best of my knowledge. 8 Q. What records would you have to look at to see 8 Q. you don't remember? 9 if you took people out or left out of Turkey? 9 A. Exactly. Best of my knowledge. 2 don't 10 A. to have to look at the ?ight legs, but i to remember. 1 1 personally don?t remember ?ying into Turkey. 11 Q. Do you remember the reason for going to Turkey 12 Q. And would the flight logs coming into the 22 or to Prague? 13 United States from ~turkey indicate the names of the 13 A. No. 14 people on the plane? 14 Q. This also says Asia. Have you ever flown to 15 A. They might. 15 or from Asia with Jeffrey Epstein? 16 Q. Okay. Where would i get those particular 3.6 A. Yes. 1? flight logs that would have that information? 3.7 Q. Or on 3 Jeffrey Epstein airplane? 18 A. Depended upon what year you're talking. 3.8 A. Yes. 1 9 Q. We're talking in this particular complaint 3.9 Q. Do you know the purpose of those flights to 20 between 1998 and 2002. 20 and from Asiaclon't possess those passenger 23. A. No. - 22 manifests. 22 Q. Did it ever occur to you that maybe it was to 23 Q. Do you know who wouid possess those? 23 pick up minor girls for him to have sex with on the back 2 at A. That would he i guess 24 of the airplane? 25 MR. Do you know who has them today? 25 MR. Formnot know who has them 1 THE Never occurred to me. 2 today. 2 BY MR. EDWARDS: 3 BY MR. EDWARDS: 3 Q. Did you ever hear that he maintained some of 4 Q. Who did you give them to? 4 these underage girls as sex slaves 5 A. Actually, I didn?t give them to anybody. {Dave 5 A. Never heard of such a thing. 6 Rogers was in possession of those logs. So i don?t know 6 Q. from the age of 12 through the age ot-?lo? "l where they are right now. 7 MR. Form. 8 Q. You?re still thinking that the best evidence 8 THE WITNESS: No knowledge of that. 9 of that, any that may have left out of Turkey, 9 BY MR. EDWARDS: 10 would be in the flight logs that's marked as Composite 10 0. Ever picked up girls that looked young, many 11 Exhibit 1, or are we talking about the manifests that 11 of whom who spoke no English? '00 you ever remember 12 we?ve been referring to? 12 that? 13 A. I don't know how accurate that log book is or 13 A. Zero. do not. 14 even how accurate the passenger manifest is. 3.4 Q. All right. The complaint goes on to say, 15 Q. Okay. So there may be no actual documentation 15 "Plaintiff was required to be sexually exploited by 16 indicating a flight leaving out of Turkey when. in fact, 1 6 defendant?s adult male peers, including royalty." So 17 a flight may have left out of Turkey? 17 l?m going to talk, do you have any familiarity with 3.8 A. Correct. 18 Prince Andrew? 19 Q. Okay. The Czech Republic is the next place 19 A. i know who he is. 20 listed. Is that a place you've flown to or from in a 20 Q. Was he ever on the airplane? 23. Jeffrey Epstein airplane? 21 A. He may have been on the airplane. 22 A, More speci?c. could you name the city? 22 Q. Do you remember him on the airplane with young 23 Q. i can't name the city, at least the complaint 23 girls? 24 doesn?t name the city. But he been to the Czech 24 A. No. i do not. 25 Republic before. Anywhere within that country. have you 25 Q. Do you remember Jeffrey Epstein flying in to Larry Visoski October 15, 2009 1 5 3 5 1 meet with Prince Andrew? 1 BY MR. EDWARDS: 2 A. i don't remember. I know that happened, but i 2 Q. Okay. Do you remember who else was on that 3 couldn't be accurate. 3 flight that left after to pm? 4 Q. Has Prince Andrew ever been on the airplane at 4 A. No, i do not. 5 the same time as a young girt, to the best of your 5 Q. Do you remember why it iett after 10 pm? 6 memory anci knowledge? 6 A. No, i do not. 7 A. To the best of my knowtedge, no. 7 Q. Do you remember Jeffrey Epstein instructing 8 Q. This aiso says politicians, talking about 8 you to wait untii after 10 pm. to teave? 9 locai or US. politicians. Do you remember certain 9 A. No. 10 politicians being on the airpiane? 1 0 Q. Would you have listened to him if he had told 11 A. No mean yeshad instructed you to do that? 12 Q. What politicians would that be? 12 A. i don?t understand the question. 13 A. President Ciinton. 13 Q. Wait, it he toid you wait until after 10 14 Q. Okay. Who else? 14 i realize there?s going to be a fine, but wait until 15 A. Former president of Israei help me outwith 15 after 10 pm. to leave, intentionally ieaving 16 the name, Barak? 1 6 after 10 pm, do you remember that instruction ever 17 Q. Ehud Baralt? 17 A. No, I don?t remember that instruction. 18 A. Yes, those are the two that remember. 18 Q. Okay. 19 Q. How many times was Ehud Sarah on? the airpiane 19 A. i mean, itjust happened to be departing 20 that you piloted for Mr. Epstein? 20 after to and there is a penalty for ieaving after it} for 21 A. Maybe once. 21 noise. So there was no intention 22 Q. And where did that tiight pick up and where 22 Q. Ail right. This aiso talks about this 23 did it go to, to the best of your memory? 23 particular person 15 years old being sexuaiiy expioited 24 A. Best of my memory, it was Pairn Beach to 24 by businessmen andior other professional or personal 25 Teterboro. 25 acquaintances. Are you aware of other personal Where is Taterboro? 1 professional acquaintances of Jeffrey Epstein also 2 A. in New Jersey. 2 sexuaiiy abusing or exploiting iittle kids or underage 3 Q. And what was the purpose of that ?ight, do 3 girls on yourairplane? 4 you know? 4 MR. Form. 5 A. i don't know. 5 THE WITNESS: No. 6 Q. Was Jeffrey Epstein on the ?ight? 6 BY MR. EDWARDS: 7 A. i'd have to look at the ?ight logs to ?i Q. if you had been aware that Mr. Epstein was - 8 guarantee. 8 and by this this is more in the form of a 9 Q. Anything about that flight stick out in your 9 hypothetical, and that for not going to suggest to you to mind? 10 it?s a fact that he was. But if you had been aware that 11 A. None. 11 every singie day Jeffrey Epstein's goal was to locate 12 Q. Such as a ?ne needing to be paid because it 12 underage girls for the purposes of sex, and either have 13 left after 10:00 13 sex with them on the airplane or at some other 14 A. For that was the ?ight, yes. 14 designation that you were destination that you were 15 Q. You remember that? 15 traveling him to, would you have continued to piiot 16 A. it?s coming back to me. 16 those planes? 17 Q. And do you remember young girls being on that 17 MR. CRITTON: Form. 18 ?ight? 18 THE WITNESS: You said it was hypothetical? 19 A. No. 19 BY MR. EDWARDS: 20 Q. right. 20 Q. Right, it is a hypotheticai. 2 1 A. i remember the ?ne. 2 1 A. Why would i want to answer that? Because 22 Do you remember who paid the ?ne? 22 you're being hypotheticai. i mean, it would obviously 2 3 MR. Hold on. Let me object to form 23 be wrong. 24 of the question. "Do you remember? it suggests 24 Q. Sure. Well, a hypotheticai question is a 2 5 that there were. So form, predicate. 25 iegai question that i?m allowed to ask. Larry Visoski October 15, 2009 3.57 1 5 9 i. A. Okay. 1 THE WETNESS: Never heard of such a thing. 2 Q. And i?m just asking yoo if you did have 2 BY MR. EDWARDS: 3 knowiedge that Jeffrey Epstein was having sex with 3 Q. Do you know of any friends that he has in 4 tittle girls either on the plane or at a piace that you 4 France that wouid send him birthday -- a birthday 5 were taking him to or from on a deity basis, that?s what 5 present? 6 he did, wouid you have continued to be his piiotobject. Object to the "i Q. Do you know of him receiving any birthday 8 form. its argumentative. it has no more value 8 gifts or birthday peopie from anyone? 9 than assuming he was chopping up bodies or anybody 9 A. Never. 1 0 was chopping up bodies in the plane you?re ?ying. 10 Q. This particuiar person that ?ied this 1 1 What difference does it make? Form. 1 complaint, Jane Doe 102, indicates ?Defendant and 12 MR. EDWARDS: What difference does it make in 12 Ghisiaine Maxweii acknowiedged and celebrated 13 a case about him having sex with tittie giris? i?m 13 piaintiff?s 16th birthday." 14 not going to argue with you about it. You?ve 14 Do you remember them ceiebrating somebody who 15 stated your obiection. 15 you ?ow on the airptane?s toth birthday? 1.6 MR. CRETTON: Exactty. it?s an argumentative 16 A. i don?t recaii. 17 question. 17 Q. Any of this iog your memory as to who Virginia 18 MR. EDWARDS: I?m not going to argue with you 18 Roberts is? 1 9 about it. 3.9 A. No. 2 0 MR. You're arguing with him about 20 0.. "From the age of 15, piaintift? this Jane 21 now. 2 3. Doe 102 ?was sexuain expioited and abused by 22 MR. EDWARDS: No, I?m asking him the 22 defendant on a daily basis and often muitipie times each 23 hypotheticai. 23 day.? 24 BY MR. EDWARDS: 2 4 So going back, was there ever a day where you 25 Q. Can you answer that? Would you have continued 25 were with Jeffrey Epstein where you could observe him piiot for somebody who?s traveling to and from 1 and Virginia Roberts during an entire day? 2 destinations with the goat of having sex with underage 2 MR. CRETTON: Form. 3 giris? 3 ?ii-IE WITNESS: i don?t remember Virginia 4 MR. Form. 4 Roberts, so i couldn?t answer the question. 5 THE it coutd be any person. it 5 BY MR. EDWARDS: 6 doesn?t have to be Jeffrey Epstein, then, right? 6 Q. "in September 2002, Defendant Epstein 7 BY MR. EDWARDS: purchased a commerciai round-trip airline ticket and 8 Q. True. 8 provided a passport. US. currency and accommodations 9 A. No, i wouidn?t pilot an airptane if there was 9 for piaintiff to ?y to Thailand." 10 wrongdoing going on. 10 Do you remember him doing that for anybody 11 Q. That you knew about? 11 around that time period? 12 A. That i knew you about, sure. 12 A. No, sir. 13 Q. Me reading this compiaint to you, is this the 13 MR. CRITTON: What was the date? 14 first time you've heard these allegations 14 MR. EDWARDS: September 2002. 15 A. Yes. 15 MR. CRITTON: Okay, thanks. 16 Q. against Mr. Epstein? 16 MR. EDWARDS: have here and this is 17 A. Yes. 17 actualiy my oniy copy, so i don?t mind marking it 18 Q. it goes on to say, "On one of Epstein?s 18 as a composite exhibit, but we'li either have to 19 birthdays, a friend of Epstein sent him three 19 copy this white thing or we'ii have an agreement of 20 12-year-old giris from France who spoke no Engiish for 20 counsei. It?s the visitor inmate log from when 2 the purpose of for defendant to sexually expioit and 2 1 Mr. Epstein was in jaii in Paim Beach. 22 abuse. After doing so, they were sent back to France 22 MR. CRITTON: Wail, before we get started. it 23 the next day." 23 is now 1:15. We started at 10:00. 24 Are you famitiar with that occasion? 24 MR. EDWARDS: We didn?t realty start at 10:00. 25 MR. CRITTON: Form. 25 MR. CRETTON: Shortly thereafter. i was here Larry Visoski October 15, 2009 flpretty much after it). But we?ve been here since 1 just tatked about general happenings that go on in 2 10:00. I want to take a lunch break. 2 there- 3 MR. EDWARDS: Let's do it. 3 Q. What did he say? rt MR. CRETFON: For an hour? 4 A. it?s terrible; it's cold; he can?t sleep. 5 ile. EDWARDS: Sure. 5 They wake him up every two hours. You know, just items 6 (A break was had at 1:15 pm.) 6 like that, uncomfortable things. We talked about the ?3 BY MR. EDWARDS: 7 airpianes a great deal. You know, we got major 8 Q. All right. looked through the inmate log of 8 maintenance on the big airptane, so we discussed that a 9 the visitors who visited Jeffrey Epstein and your name 9 little bit. And then it was reailyjust how 10 appears one. two, three, four, ?ve. six, seven, eight 10 uncomfortable he was there. 11 times. 11 Q. How iong did you visit with him on that ?rst 12 A. Okay. 12 visit, Juiy 3rd? 13 Q. Seern to be accurate in terms of how many times 13 A. i think we stayed the full hour. 14 you went to visit him? Q. Ali right. is that what the time aliotment 15 A. i thought six, but yes, 15 was? 16 Q. I?ll let you review the records and tell me if 16 A. i believe it is, yeah. I don't think you 17? you dispute any of that record. And I?ll go ahead and could ieave early, or I?m not aware that you couid leave 18 mark that as Composite Exhibit 5. 18 early, untii tater on we found out you couid stay for 19 (Plaintiff?s Exhibit No. 5 was marked for 1 9 ?ve minutes or longer. But i don?t think any of us 20 identi?cation.) 20 knew that was once you got in there. you stayed there 21 MR. REINHART: its two pages. 21 for the hour. 22 MR. EDWARDS: Two pages. 22 Q. Okay. So you taiked to him for an hour and 23 MR. REINHART: Okay. 23 for the most part it was just about the conditions and 24 BY MR. EDWARDS: 24 his disappointment with the conditions? 25 Q. Seem accurate? 25 A. Sure, yeah. absoluteiyYes. 1 Q. And did Igor talk to him as well? 2 Q. Okay. Jeffrey Epstein's piea, beiieve, was 2 A. Brie?y. 1 mean, not that much. You're going 3 June 30th, 2008. i think that?s when he was taken in 3 back a Iittie ways again to remember exactly what was 4 custody from there. Your first visit is July 3rd, 2008. 4 discussed. You know, he asked how his family was doing. 5 And the other name on that visit is tgor Zinoviev. Did 5 i guess igor?s got a son, 3 think he asked how his son 6 you go with Igor to visit Jeffrey Epstein? 6 was doing. You know, just generai questions tike that. "i A. Yes. Q. Did you ride to the jail that day with igorwith lgor? 8 A. beiieve we did. i believe I met lgor 9 A. ltjust happened he wanted to see us both at 9 probabiy at Jeffrey's house and picked him up, or if 10 the same time. There was no apparent reason. 10 not, we may have met at the airport and drove together. 1 1 Q. t-tow did you know that Jeffrey wanted to see 11 But we did drive together on that occasion. 12 you? 12 Q. In what vehicle did you drive? 13 A. i don't recail who called and toid me that he 13' A. The tlurnrner. 4 wanted to see me. i couidn't give you an accurate name, 14 Q. That's the vehicle you described earlier as 1 5 whether it was, you know, his attorney, Darren. And is the company vehicle? 16 actually, i wouid put a lot weight to think it was 3.6 A. Yes, sir. 1? Darren, his attorney. 17 Q. is that a vehicle paid for by Jeffrey Epstein? 18 Q. That woutd have made a phone call to you that 18 A. Meaning? 3.9 said 19 Q. Weil, is that a vehicle paid for by you? 20 A. Yeah. to go. 20 A. What do you mean "paid for"? 2 3. Q. And what did you taik about with Jeffrey 2 1 Q. Did you purchase the vehicie with your money? 22 Epstein four days after he pied guiity to offenses that 22 A. i didn?t purchase that one, no. 23 landed him in jail? 23 Q. Do you know if it was purchased by Jeffrey 24 A. I think the ?rst visit was how disappointed 24 Epstein or a corporation of Jeffrey Epstein's? 2 5 or how scared he was, you know. being inside there. We 25 A. Probably a corporation. Larry Visoski October 15, 2009 65 1 67 1 MR. Form; move to strike. Sounds 3. that was hoiding Jeffrey Epstein. they?re 2 like a guess. 2 accurate, your name is the ?rst one listed on the top 3 BY MR. EDWARDS: 3 of the sheet? 4 Q. To the best of your knowtedge, that's how most 4 A. Right. There may have been eariier dates. i 5 of the items that you?ve discussed that being the 5 have no idea. 6 Boeing and the Guifstream -- they were usuaiiy held in 6 Q. Weii, you know, the ?rst date that he could 7 corporate names, to your knowledge? 7 have been in there it iooks Elke was Ti1i08 and then, 8 A. To my knowledge, exactly, yes. 8 you know, so i guess somebody couid have seen him or 9 Q. And so when you?re saying the when you're 9 W2, but those records were never provided to us. You 10 taiking about the Hummer vehicie and you're stating that 10 see we were provided a whoie big stack. 11 its iikaiy a coroorate entity, is that iust something 11 A. i understand. 3.2 that you're guessing about, or do you have knowiedge? 3.2 Q. The next date i'm going to taik to you about 13 A. No, i?m iust guessing. 3.3 is 711268. 14 Q. Okay. 14 A. Lin-huh. 15 A. i have no proof 3.5 Q. it looks, again, like it?s yourseit and Igor 16 Q. of ownership of who it?s registered to or 16 Zinoviev? 17 anything iike that? 17 A. Mm-hrnm. 1 8 A. Exactiy. 18 Q. And that?s something we talked about in this 19 Q. is it registered to you? 19 deposition. l?rn going to ask you again, i don?t know 20 A. No, no. 20 that you elaborated last time, what is your 21 Q. So its registered to somebody other than you? 2: understanding of his rsiationsinip with Jeffrey Epstein? 22 A. Exactiy. 22 Is that a friend of his? 23 Q. Okay. 23 A. i don?t know his gob description. i mean, 24 A. iiust drive it, i guess. 24 he?s somebody that?s around a lot, but i don?t know his 25 Q. Okay. so on Juiy 5th, 2003I you go back to 25 exact job description. l-iis English is, to sayjail again, and again, igor Zinoviev is 100 percent, so conversation with somebody that doesn?t 2 iisted as a visitor. Did you go with him together on 2 fatty understand you, you know, you get lost in 3 that occasion? 3 transiation a little bit. So i don?t 4 A. i didn?t even reaiize it was two days after 4 Q. So on these three visits to the iail, the 5 the ?rst visit. 5 ?rst three that we?re taiking about that we've taiked 6 Q. Wait. i mean, you see where this is going? 6 about so far, each or those times you traveied to and 7 A. Yeah, ido. it gets further apart, yeah. 7 from the jaii with igor? 8 Q. Do you remember what the discussion was on 8 A. Mm~hmm 9 9 Q. Yes? 10 A. No, because it?s probabiy similar to the first 10 A. Yes. yes. 1 1 one. i mean, we taiked - actuaiiy, one of the visits 1 1 Q. And each of those time, is it fair to say you 12 we taiited about ?shing and iust trying to - you know, 12 had some form of communication either were taiking about things that wouid just occupy his 13 jaii or 14 mind with conversation that he probably 14 A. Sure. 15 wasn't getting there. So for that hour of the day, i 15 Q. -- to the gait? 1 6 tried to give my best of conversation to 16 A. Yeah. 1? him, 17 Q. Since you're going to see an inmate in the 18 Q. Okay. On his visitor log you were the first 18 iaii, is it a safe assumption a portion of that 3. 9 one to go visit him. Did you know that? 19 conversation was about the person that you?re going to 20 A. i did not know that. i wasn't aware of that. 20 see and possibiy the crime that was committed? 2 1 MR. CRETTON: Let me just obiect to form to 2 3. A. Yes, that wouid be a good assumption. 22 the iast question. 22 Q. Okay. And what was the form -- what was the 2 3 BY MR. EDWARDS: 23 substance of that conversation that you can remember 2 a Q. Wait, at toast if these records are accurate, 2 4 related to Jeffrey Epstein and the iocation you were 25 which are the records that were provided to us by the 25 going to visit him? Larry Visoski October 15, 2009 think igor and i discussed on trying to be 1 Q. And in the course of that conversation, again. 2 upbeat and not look at the position that he?s in sitting 2 the and the unusual 1?1? cat! it case 3 across the tabie from us, to be upbeat and upiift his 3 against him, that didn't come up between you and 4 spirits. 4 Mr. Epstein? 5 Q. Did you and tgor discuss whether or not you 5 A. I never taiked about it with him. 6 were going to taik to him about his piea of guiity or 6 Q. And at that point in time. what were you aware 7 the fact that he?s not registered as a sex offender? 7 of in terms of the number of girls that he was aileged 8 A. No. 8 to have bad sexual some sort or sexuai relationship 9 Q. Or whether you were going to stay away from 9 with him at his Pairn Beach house? 3. 0 those topics? 1 0 A. What was the question? How many gins? 3.3. MR. Form. 11 Q. Yeah, how many giris were you -- 12 THE ESS: We never we don?t discuss A. Aware of? 13 that amongst ourselves andfor with Jeffrey in any 13 Q. -- aware of? 14 way, form. 3.4 A. None. wasn?t aware of any. to be honest. 3. 5 BY MR. EDWARDS: 15 Q. The next visit is on Wt 7198 and it's lgor 1 6 Q. Okay. But that?s not i realize you didn?t 16 Zinoviev and somebody named Jean Reno and then yourseif discuss that. You?ve told me that. Do you know who Jean Reno is? 1 8 A. Right, but we didn?t discuss that even prior 18 A. No. 19 to going in, as you asked. 19 Q. Do you think that that visit, that you visited 20 Q. Okay. So your discussion was mainiy hey, 28 him at the same time that Jean Rene visited? 2 1 iet?s be upbeat? 2 3. MR- What?s the date? 22 A. Yes. 22 MR. EDWARDS: it?s 7f17l08. 23 Q. And that was to, in essence, maintain his 23 THE No, i don?t know a Jean Rene. 2 4 spirits or raise his spirits? 24 unless somebody came after. i mean, i don't -- 25 A. Exactly. 25 don?t know a Jean Rene. 17' 3.7 2 1 Q. Okay. And you were doing that as a friend of 1 BY iv?iR. EDWARDS: 2 his, notjust his piiot, right? 2 Q. Okay. And then before you visited him again. 3 A. i felt honored that he asked me to come and 3 the visitors are iisted as Nadia Marcinkova or Sarah 4 give support iike that, because prior to him going away, 4 Keilen?? 5 it was known to us that there was going to be no 5 A. mehrnm. 6 visitors, because i had offered to him that i wonid be 6 Ct. Mainiy those two individnais. And they iist 7 happy to come and visit him it he deemed it necessary, 1? as addresses, 30? East 66th Street as their residence? 8 and he says no, i'm not going to have anybody. 8 A. Lin-huh. 9 Q. So 9 (22. Given your previous testimony, does that 18 A. i guess it was so bad there, that he may have to surprise you that they fist those that address as it changed his mind and wanted to have some visitors. 11 their residence? 12 Q. When did you have this conversation with him 12 MR. Form. where he indicated he was not going to have visitors 13 THE WETNESS: t've seen them there, so i mean, 14 while he was in iaii? 14 in: not surprised. 15 A. i don?t exactiy remember. it may have been on 15 BY MR. EDWARDS: 16 the trip heading to Palm Beach, the test ?ight. 16 Q. Okay. Did you know that they were visiting it?? O. From his isiand, from St. Thomas i guess it 1? him in jail? 18 would be from? 18 A. No, i didn?t know who was scheduled to see him 19 A. i forgot where it started from. it might have 19 or whatever. 28 been New York or the isiand, one of the two. i don't 20 Q. Did Jeffrey talk to you at any point in time 21 remember the last fiigitt. 23. about Nadia Marcinkova or Sarah Keiien? 22 Q. And i mean. did at toast the fact come up that 22 A. No, not at alt. 2 3 hey, this a person who you?re w- is going to be in jet! 23 MR. REINHART: Can we get a time frame for 24 for sometime? 24 that? Ever? 25 A. Mm-hmm, yes. 25 MR. EDWARDS: Oh, no, wait, I was taiking Larry Visoeki October 15, 2009 it 7 3 1 7 5 i?m sorry. 1 at the house. 2 BY MR. EDWARDS: 2 Q. Those are cars that Jeffrey Epstein owns, to 3 Q. i was taiking right now about in the 3 your knowledge? 4 conversations that you had with him that we?ve discussed 4 A. I don't know who owns them. 5 with you and him in the jaii Did he discuss 5 Q. What cars are there that i know with this 6 with you Nadia Marcinkova or Sarah Keilen? 6 case we?re dealing with a lot of corporations and it?s 7 A. No, no. 7 not iike asking me. Hey, what car do yoo own? But what 8 Q. Did he taik to you about whether or not you 8 cars are you aware that are -- that you believe are used 9 shouid taik to anybody about his criminai investigation 9 primarily by Jeffrey Epstein? 10 or possibie litigation? 3.0 A. Used primarily by Jeffrey Epstein, a Mercedes 1 1 A. No. not at alt. 11 8500 sedan. i don?t remember the year on that one. 12 Q. The next time you see him is on August 9th, 12 Q. Okay. 13 2008, at the iaii. in that occasion it mentions as his 13 A. There's a Caditiao Escalade. 14 visitors that day Nadia Marcinkova, Sarah Keiien and 14 Q. Okay. 15 Larry Visoski. Did you go to the fat! with Sarah and 15 A. Those are his two main cars that he wouid be 1 6 Nadia that time? 1 6 driven there? Which one are you 17 Q. What are the other cars that you reguiariy see 1 8 referring to? 18 parked at his Pairn Beach mansion, if there are any? 19 Q. The next one, i tried to highlight them just 3.9 A. it wouid he a whole array. Half the time the 20 so that 20 parking lot is fall because of construction workers, 2 A. Right, that one. 2 2 yards keepers. 22 MR. REINHART: 8ft). 22 Q. Okay. Fair enough. What vehicie does Sarah 23 BY MR. EDWARDS: 23 Kelten drive or Nadia Marcinkova drive when they?re dowr 2 ?3 Q. 8i9i08? 2 4 here, if you know? 25 A. One of those two we ati drove together. i 25 A. i mean, anybody has a choice to pick out don?t remember which one it was. it was either the 9 or 1 or whatever there. I've seen Nadia driving a Mercedes 2 the 16, and then the other one i met everybody there. 2 convertible. 3 So i can't be accurate on which time we ail drove 3 Q. Is that different than the Mercedes $500 4 together. 4 sedan? 5 Q. How did you'coordinate driving together? 5 A. Yes. i think it?s different. 6 A. i don?t exactiy remember now. i mean. i think 6 Q. When you say they have basicain a choice of 7 Sarah and I may have conversed on the phone and said do cars to drive 8 you want to meet at deftrey?s house and we sit drive 8 A. Weii. there?s cars in the lot there. 9 together? Does it make sense to get together and drive 9 Q. Obviousiy, they canone car. - 3. 0 construction workers? cars? 11 Q. is that jaii visit the result of Jeffrey ll A. No. 12 Epstein requesting your presence there. or is that the 3.2 MR. REENHART: Let him ?nish his question. 13 resutt of you wanting to go see him as a friend in jaii? 13 BY MR. EDWARDS: 1 4 A. A combination of both. i?m sure if I said, 1 4 Q. So that?s kind of what I?m getting at. What 15 Hey, i?d like to come to jait and visit you, that he 15 other cars do you think that Jeffrey Epstein has 1 6 woutd either say yea or nay. 1 6 whether it's titted, i don't know 3.7 Q. Okay. And you said at least on one of those 17 A. Right. 18 occasions you rode to and from the gait with Sarah and 18 Q. but he is the person in control of that 1 9 Nadia? 1 9 vehicie? 20 A. Yes. 20 A. Right. 23. Q. And during any of - obviousiy, when you're in 21 Q. What other vehicies do you think he?s 22 the car together wet}, who?s driving the car? 22 controiltng in Paim Beach? 23 A. was driving, I betieve. 23 A. In Patrn Beach? 24 Q. And that's the Hummer again? 2 4 Q. We?ve named the Mercedes S500 sedan, 25 A. Actuaiiy, i think we take one of the suburbans 25 Escaiade? Larry Visoski October 15, 2009 Right. 1 he various peopie, schedulers, piiots, 2 Q. And We identi?ed a Mercedes convertible? 2 handlers and other associates and cowconspirators 3 A. Right. 3 that have a similar mentality; that is, people that a; Q. in addition to that, are there any others that 4 do not agree with laws rotated to sex abuse and 5 you?re aware of? 5 abuse of children. And that?s why this line of 6 A. That he's in oontroi of? 6 questioning regarding whether or not this witness 7 0. Yes. has a motive or a bias or was involved in 8 A. No. 8 conversations related to his motive or bias, to 9 Q. And does the conversation come up between 9 continue to work for Jeffrey Epstein or believed 10 Nadia and Sarah and yourseif about the reason why 10 the same peiiefs of Jeffrey Epstein, is at least 1 1 Jeffrey Epstein is in jail? ll reasonably calcuiated to the lead the discovery of 12 MR. REINHART: Can we get a time frame? 12 admissibie evidence. and that is the argument at 13 MR. EDWARDS: At any time. 13 least along those tines being made to the judge 14 BY MR. EDWARDS: 14 regarding these questions. 15 Q. At any time have you ever had that exact 15 MR. CRITTON: Can we talk foriust one minute? 1 6 conversation ever come up? 16 Because maybe can i talk with well, i know i 17 A. No, we didn?t talk about that among ourselves 17 can talk with Bruce. Let?s just take a break. 18 really. 18 (A break was had at 2:45 pm.) 1 9 Q. And have you ever been told that Nadia 19 MR. EDWARDS: We're back on the record. Do 20 Marcinkova provides the rote of a sex stave to Jeffrey 2 you have the same position? 2 Epstein? That?s just her role in life? 2 1 MR. REINHART: Let me say this: He previously 22 MR. CRETTON: Form. 22 said he would have never aiiowed anything on the 23 MR. That?s just have you been told 2 3 piano to be done it you want to ask it 2 4 that. 2 4 he agrees with the iaw appiied by the 25 THE WITNESS: No. 2 5 legislature do you agree the law passed MR. EDWARDS: 1 state of Florida should be compiled with? 2 Q. Have you been ted to believe that by anybody? 2 THE i don't know what the iaw is. 3 A. No. 3 BY MR. EDWARDS: 4 MR. Form. 4 Q. Okay. The laws in piece to protect children 5 BY MR. EDWARDS: 5 under the age of 18 from being sexualiy touched, 6 Q. Do you have any w? based on your observations, 6 fondled, molested by people over the age of 24, do you 7 do you have any other opinion as to what rote she ptays 7 agree with those taws? 8 in Jeffrey Epstein?s iite, if any? 8 A. Yes. 9 A. i don't have an opinion on what the rote is. 9 Q. And you agree that persons who commit a 10 Q. Do you agree with the criminal statutes that 10 violation of those laws shoutd be prosecuted? 1 1 are in place to protect young children from sexuai 1 1 A. Persons that do that. 3.2 predators? Do you agree with those statutes? 12 MR. CRETTON: Forrn. 3.3 lViR. Form. 13 BY MR. EDWARDS: 14 MR. l'm going to direct him not to 14 Q. Yes, persons that do that. 15 answer the question. it?s irreievant and it?s not 15 A. Persons that do that, absoiutely. 16 iikeiy to iead to discoverable evidence what his 16 Q. And if you were to receive continued - what 13? opinion is on a law that's been passed by the 17 you would perceive as continued information that Jeffrey 18 legislature of Florida. 18 Epstein was one of those persons, wouid you continue to 19 MR. EDWARDS: Just so the record is clear, 1 19 be empioyed by or atongside of Jeffrey Epstein? 20 don't know that we did this iast time, out it's 20 MR. CRETTON: Form; speculation. 21 been alleged in the complaint it has been 2 1 ?ii-IE WETNESS: You?re assuming that there?s 22 atieged in several complaints that Jeffrey Epstein 22 guilt. 23 particulariy prays on vulnerable disadvantaged 23 BY MR. EDWARDS: 24 females, underage femaies, and that in order to 24 Ct. No. i?m saying, hypothetically, if you were 25 gain access to the muititude of underage females. 25 convinced that Jeffrey Epstein was guiity of those acts Larry Visoski October 15, 2009 1 8 3. 8 3 1 which he pied guiity to 1 against him and the allegations contained within many cl 2 MR. Form. 2 these civil complaints on behaif of girts who were under 3 MR. REINHART: Can we for purposes of your 3 the age of 18? ls there any reason why you haven't 4 hypothetical, what facts do you want him to assume 4 discussed that? 5 are true? You said the facts to which he pied 5 MR. if that?s based on 6 guilty, but the witness aiready said he doesn?t 6 conversations you had with your iawyer, then don?t 7 know what he pied guiity to. He knows the charge 7 disclose what you and your tawyer taiked about. 8 he doesn't know the facts. 8 BY MR. EDWARDS: 9 BY MR. EDWARDS: 9 Q. Correct. 10 Q. Soiicitation of prostitution of a minor. 10 A. have not spoken to Jeffrey about any of 1 1 somebody under the age of 18. 3.1 this, and it was my understanding that is to 12 MR. EDWARDS: That?s the charge, right, 12 have conversation about this. 80 We never presented 13 solicitation of prostitution of a minor? 13 any questions to him reference this case or any others. 1 4 MR. CRETTON: No. i think you?ve got it 14 Q. it was your understanding that it was illegal 1 5 wrong. l'il object to the form. 15 to talk to Jeffrey Epstein about the aiiegations made 16 MR. EDWARDS: Okay. 16 against Jeffrey Epstein? 17 BY MR. EDWARDS: 1? A. Yes, or anything to do with the case. That?s 18 Q. Then we'il handie the question this way: if 18 why we never discussed any portions of it. 19 you were to believe based on information and evidence 19 Q. Okay. So 20 that Mr. Epstein engaged in sex or some form of sex acts 20 A. i may be wrong in that assumption, but i 2 1 with peopie of the age range of 12, 13, 14, 15 years 2 1 don't - 22 old, wouid you continue your employment with 22 Q. So the reason why you haven?t discussed this 2 3 Mr. Epstein? 23 with Jeffrey Epstein is you believed it was illegal? 24 MR. Form; specuiation. 24 A. Correct, yes. 25 THE wouid certainty be specuiating 25 Q. Who led you to believe that it was iliegaihave to discuss it with my wife long and 1 MR. REINHART: Again, it it was a discussion 2 hard. i don?t think i could give you a correct and 2 you had with any iawyer, then you can just give a 3 honest answer at this time. 3 name, don't give a discussion of the conversation 4. BY MR. EDWARDS: 4 you had. 5 Q. Okay. Given the ailegations that have been 5 THE WETNESS: it was my own assumption. 1 6 made in this case, is this something that you have 6 mean, just basic criminal knowiedge of knowing '3 discussed with anyone other than your attorney? 7 you?re not supposed to ~:,you know, it-somebody?s 8 A. No, not really. Only from the fact that 8 in triai or in a deposition or whatever, i don't 9 they're allegations and there?s a lot more work, 9 i didn't think it was appropriate to discuss the 10 I?m sure, to be discovered. 10 matter with themthere, for the -- 11 BY MR. EDWARDS: 12 if this deposition is not typed and we request 12 Q. Okay. So the next two visits and i think the 13 it i?d like at least this portion where 13 test two visits we'ii taik about are on 14 Mr. Edwards' last question back about ?ve pages 14 Actuaiiy, it iooks like you visited him twice in one 15 worth, so just it you oouid mark it from this 15 day; is that right? 16 page back about ?ve pages. 1 6 A. i don?t think that's possihie. i mean, that 17 if nobody requests the deposition, id just 1? wiil show how accurate the court record is. There?s no 18 iike those ?ve pages. 18 way. 19 MR. EDWARDS: i'm going to request the 19 Q. You wouidn?t have visited him twice in one 20 deposition, 20 day? 21 MR. Okay. We?ii mark this then, so 21 A. No. i think there?s only one visitation per 22 you couid tell me where it is, approximateiy. 22 day. 23 BY MR. EDWARDS: 23 Q. Okay. And it looks like the same visitors 24 Q. is there a reason why you have not discussed 24 each tirne, except that it says for period three and then 25 25 the next one's for period tour. So there are two with Jeffrey Epstein the allegations that have been made; Larry Visoski October 15, 2009 different periods. Was there ever a time when they 1 telephone, how frequentty woutd you talk to him? 2 atlowed you to stay for more than an hour? 2 A. How irequentiy during a given weekknowiedge. 3 Q. Yeah. a Q. Okay. So again, it?s Sarah Keiien and Nadia 4 A. More speci?c? 5 Maroinkova. same questions: Did you ever ask them their 5 Q. Sure. 6 invotvement with Jeffrey Epstein? 6 A. Depends upon what?s going on that week. 7 A. Absolutety not. "i Q. I mean, is it somebody you wouid taik to him 8 Q. And again, what was the discussion with 8 every day? 9 Jeffrey Epstein atong with Sarah Ketien and Nadia 9 A. No. 10 Marcinkova? 3.0 Q. right. Wait, at that point in time, he's 1 3. A. On the test visits, it was mainiy airptane 11 going from the jait to the Fionda Science Foundation 12 stuff and tater on in the visitations, we were advised 12 and back, and it you?re not going to see him in person, 13 that you couto ieave eariy, so i wouio only stay for 13 and you're not corresponding by e?mait, then woutd you 14 maybe 30 minutes and then, you know, Jeffrey woutd l4 correspond by tetephone, that either being you cat! him 15 continue his conversations with them and then i would 15 or he caited you? 1 6 just wait outside. 3.6 A. Yes. 17 0. Okay. it"? Q. And, you know, in any given week, what was the 18 A. So I would do my business with him taiking 18 typical week tike? i mean 19 about airptanes or whatever i had coming up and then 19 A. How many times? 20 exit. 20 Q. Yes. 2 1 Q. And then why did you stop visiting him in jet! 21 A. Maybe once in a week, sometimes twice in a 22 after that September 6th, 2888, visit? 22 day. i mean, it wouid vary. There was no routine. 23 A. was never Salted back to Visit. 23 Q. And what would the conversation be? 24 Q. Okay. Wait. shortiy after that then he was on 24 A. Mostiy we discussed audio and video, TVs, home 25 work reiease? 25 theaters. it's a niche of his and we're constantty l8 6 18 8 1. A. Watt, that?s true. 1 looking at new items that are out there, you know, 2 Q. Right? 2 what's the biggest LCD fiat screen out there. 3 A. Yeah. 3 Q. Okay. And since he's been out ofiaii and on 4 Q. So the next times you wouid have gone to see 4 community control or house arrest or whatever it is, 5 him wouid have been at the Fiorida Science Foundation, 5 where he?s located at his home now, have you visited him 6 where we talked about earlier? 6 at his home? 7 A. We seen him there, yes. 7 A. have been to the home. i haven?t visited, 8 Q. Okay. And in fact, i think you said you saw 8 butt have had work to do there. 9 him 20 or 30 times 9 Q. And have you caiied him on the teiephone 10 A. Sure. 10 there? 13. Q. over the last two years, last year and a 13. A. Once i think I?ve salted the house. Normaiiy 12 hatf or so? 12 he caiis me because it?s usuatly he needs me to do 13 A. Yes. 13 something. 14 Q. And how tong woutd you stay each time at the 14 Q. And what have those conversations been about 15 Fiorida Science Foundation and taik to him? 15 since he's been out of iaii? 16 A. Like my originai answer, ten, ?fteen minutes. 16 A. Let?s put a stereo in the gym, tet?s out a TV 1? Q. Okay. And how trequentiy wouid you tatk to 17 in the iiving room, iet?s put a bigger stereo in the 3.8 Jeffrey Epstein white he was at the Fiorida Science 3.8 gym, iet?s pot a bigger, bigger stereo in the gym, iet's 19 Foundation? 19 go redo what we?ve done. It?s always audio. He's a 20 MR. REINHART: i?m sorry, you're taiking in 20 very audio person. 23. person or at! conversations? Because he testified 2 1 Q. Do you know of any other modi?cations that 22 he had phone conversations and personai visits. 22 he's made to the house at 358 Briilo since the time 23 BY MR. EDWARDS: 23 that he went into jaii? 24 Q. i was actuaity talking about phone 24 MR. Form; predicate. 25 conversations. So when you wouid call him on the 25 THE Meaning? Be more speci?c. Larry Visoski October 15, 2009 MR. EDWARDS: 1 A. No, idon't. It's not my airplane. 2 Q. Structurai modi?cations, architectural 2 Q. We stiil don't know whose airpiane it is yet. 3 modi?cations? 3 The time when you took Mr. Epstein to Miami in the East 4 A. Starting what date? 4 month, do you know which attorney he was going to see? 5 Q. June 30th, 2008. 5 A. No, i do not. 6 MR. REINHART: i think the question on the 6 Q. And do you know whether it was related to table was have you observed any structural changes civil cases or criminal cases or anything else? 8 to the house at El Brilio since Mr. Epstein went to 8 A. No idea. 9 jaii? 9 Q. Do you know where the location was in Miami 1 0 THE Structural changes? 1 that he was going to? 1 3. BY MR. EDWARDSnot. 12 Q. Structural, architecturai, anything like that, 12 Q. Other than yourseif visiting Mr. Epstein at 1 3 changes to the house, to the interior of the house since 13 the Florida Science Foundation, are you aware of any 14 he went to jaii? 14 other visitors. people that visited him? 15 A. No. I mean, it you could be more specific. 5 15 A. No, i?rn not. Just whoever was there during my 1 6 mean, you're taiking furniture or? 16 visit. . 1? Q. I?ve never been in the house, so I can?t be 1? Q. Okay. Are you aware of a corporation named 18 much more speci?c. Have you noticed any changes from 18 the Zorro Trust? 19 before he went to jail to after he went to iaii, the 19 A. I?ve heard the name. 20 inside of the house, that you couid be speci?c about? 20 Q. And is that something that you?ve heard 21 A. No, i can't be specific. 21 reiative to your involvement with Jeffrey Epstein? 22 MR. Can ltaik to Mr. Visoski fora 22 A. Yes. I mean, i don't even remember where i 23 second? 23 heard Zorro Trust. have no definition of it, but 24 MR. EDWARDS: Sure. 24 know the name is out there. 25 (Off the record discussion.) 25 Q. Okay. ls that a company that you believe is 1 90 1 92 1 MR. REINHART: i think Mr. Visoski can expand 1 af?liated or related to Jeffrey Epstein in some way? 2 on his previous answer. Why don?t you expand. 2 A. have no de?nition. i don?t know who back to that one? 3 Q. Do you know how you heard about it? 4 BY MR- EDWARDS: 4 A. i don?t remember. That?s going back in the 5 Q. Sure. The question dealt with the structural 5 early days of when Zorro existed. 6 architectural changes you?re aware of. 6 Q. Who was at the Fiorida Science Foundation when 7 A. There has been a kitchen extension, but when 7 you wouid meet with Jeffrey Epstein on these meetings? 8 you asked the question, i was unaware of when that 8 A. Sarah wouid be there. 9 actually took piace. So to be accurately answering your 9 Q. Anybody eise? to question, i know there?s been a kitchen extension. i 10 A. Story would be there on occasion. That?s 11 don't exactly know when that transpired, it pretty much it. 12 Q. How do you know about the extension? How do 12 Q. And would they be in the same room with 13 you know this happened? 13 yourself and Jeffrey Epstein when you had conversations 14 A. i knew what the kitchen tooked like before and 14 with him? 15 after the extension and i don't i thought it was 15 A. No, not reaily. Not particutarly. 16 during the hurricane season when they actuaiiy did that 6 Q. They wouid just be at the location? 17 extension. 1? A. Sure, yes. 3.8 Q. Who made you aware of it? 18 Q. Anybody eise that worked there or was 1 9 A. Nobody. i just walked in the kitchen and 19 with the Fiorida Science Foundation that you 2 0 noticed a bigger room than what it was. 20 know of? 21 0. All right. Do you know who Martin Nowack is? 21 A. Not to my knowledge. 1 mean, i do my business and get out. 2 3 Q. Do you ever remember him being on your 23 Q. Can anybody other than Jeffrey Epstein have an 2 4 airplane, or that name of somebody being on your 24 of?ce at the Florida Science Foundation? 2 5 airplane? 25 A. Not that i know of. Larry Visoski October 15, 2009 Ail right. And were you deeded the property 1 Q. Wail, we've just described this wide array of 2 that we spoke about eariier on the New Mexico ranch? is 2 cars that Jeffrey had for peopie to use 3 that deeded to you? 3 A. Welt, you said for him to use. 4 A. Yes. 4 MR. Hoid it. 5 Q. And has it been since back in, i think you 5 BY MR. EDWARDS: 6 said 1998 or 1999 or whenever it was? 6 Q. Is there a reason why? 7 A. Yes. 7 MR. Wait. You guys are both taiking 8 0. Okay. And do you know and did you buitd a 8 over one another. You need to iet him wait and 9 house on it then? 9 tinish his question because if I want to assert an 1 0 A. Yes, i did. 10 objection, neither one of you gives me a chance. 1 3. Q. Okay. And that's a property that i think you 11 which may be the pian. Form. 12 said you have a mortgage on it. that's a property that 12 MR. EDWARDS: Yeah, we have a conspiracy 13 you pay you mortgaged that property? 13 against you. 14 A. Yes. sir. 1 4 MR. CRITTON: I knew it. l?li take that as an 15 Q. right. And as welt, the home you own 15 admission. 1 6 here, you have a mortgage on that property as weii? 16 BY MR. EDWARDS: 17 A. That is correct. 17 Q. is there any reason did Jeffrey say that he 18 Q. Ali right. Are you with a vehicie, a 18 wanted that vehicie to use or to be parked at his house? 1 9 Chevy Suburban 1590, year 1999you have a coior? 20 Q. Then how did it come about that you started 2 1 0. No. i can toil you the piate. i oouid teii 21 parking that venicie at his home? 22 you the VEN. Chevy Suburban Chevy Suburban 1500, 22 A. i think the origination of that came when i 23 registered to Larry Visoski? 23 started using the Hummer, that the Suburban was parked 24 A. That wouid be mine. That's a white one, then. 24 in my driveway and I wanted to get it out of my driveway 25 0. Okay. When did you get it? 25 as an eyesore. So hence. i decided to let peopie l?m guessing. it was probaoiy two years old 1 house drive it as a grocery shopping car or something, 2 when i got it. Maybe ?99. Maybe '01, ?02. 2 or just as extra transportation. 3 Q. Something you drive? 3 Q. Okay. But when you go to park the car at 4 A. Occasionaiiy- it?s kind of a beat up car now, 4 somebody eise's house, you have to let them know. Hey. 5 so it's kind of a knock around. 5 i?m giving you the keys? 6 Q. Best of your knowiedge, it stays parked at 6 A. Mm?hmm. 7 your house? '7 Q. Who did you give the keys to? 8 A. Recently it?s been in Jeffrey's driveway, 8 A. i don?t know if I gave the keys to anybody. i 9 9 may have just ieft them on the counter there and toid 10 Q. Why? 10 Yanush this is an extra car if you guys needed it to run 1 1 A. Just for an extra car to use. 11 around because it was an eyesore at my driveway. 12 G. For Jeffrey to use? 12 Q. Are you tamitiar with a Meroedes~8enz SUV 13 A. No. i mean, for anybody that would come to 13 1999? 14 the house to heip out. igor i think has driven the car 14 A. Say that again. 15 before. 15 Q. Mercedes SUV, 1999 registered in your name? 16 Q. How did it come about that you began to park 16 A. Yes. the Chevy Suburban, the 1999 car that we?re taiking 1 7 Q. And what car is that? 18 about. at Jeffrey?s house? 1 8 A. That?s my car -- my wife's car. 1 9 A. When there was more activity here in West Paint 1 9 Q. Does that stay at your house? 2 0 Beach. We were never usuain coming here that often, 2 0 A. Yes. 21 and now with this going on, with Jeffrey being in 21 Q. And that?s the car that?s parked at your house 22 town ionger, we needed more cars and transportation. So 22 now? 23 my car was just sitting in the driveway at home white I 23 A. Yes. 24 was driving the Hummer. So i decided to let them use 24 Q. Are you familiar with a Land Rover, Range 2 5 the Hummer at the house. 2 5 Rover Sport 2808? Larry Visoski October 15, 2009 1 97 9 9 1 A. Yes. 1 2005 registered in your name? 2 Q. Registered in your name? 2 A. Yes. 3 A. Yes. 3 Q. And whose car is that? 4 Q. And whose car is that? 4 A. That car also is a Palm Beach house car to be 5 A. That?s another extra car for the household to 5 used at the house. 6 use at Jeffrey?s house. 6 Q. What does that mean, ?a Palm Beach house car"? ?i Q. And when was that car purchased? ?l A. it?s a car that we park in Jeffrey?s driveway 8 A. Last year. 8 for people to use. Anybody that comes to the house can 9 Q. And who purchased that car? 9 select a car to go anywhere. i mean, run errands, go 10 A. it was purchased in my name. 10 shopping, do whatever they need to do. And that was 11 Q. By whom? Who purchased the car in your name? 1 1 purchased the same way. it was in my name. 12 A. Wellname. but the funds 12 Q. And the funds came from Jeffrey Epstein? 13 carnefrom they were wired to my account from New 13 A. They were wired to my account. i don't know 1 4 York. 1 4 exactly what account they came from. 15 Q. From whom, though? A mysterious source just 15 Q. Again, that?s a conversation that has to take 1 6 sent funds? We know that didn't happen, so l?m iust 6 place before ?w that you have to agree to out a car in trying to elaborate here. 1 "i your name? 18 A. Jeffrey had paid for the car. 18 A. Yes, yes. 19 Q. Okay. And why did Jeffrey pay for that a conversation beMeen yourself 20 put it in your name? 28 and Jeffrey Epstein that takes place? 2 1 A. i don?t know. 21 A. Yes. 22 Q. i mean, you had to agree for this to happen. 22 Q. And what is the substance of that conversation 23 So what was the conversation between you and Jeffrey 23 that results in a Mercedes~Benz 2005 being placed in 2 4 that resulted in Jeffrey paying for a Land Rover, a 2008 24 your name? 25 Land Rover and putting it in your name? 25 A. He just said we need a fun car for the house 1 9 8 2 1 A. idon't recall exactly how the conversation 1 in Palm Beach. 2 came about. He just says we want to buy an ?08 Land your name? 3 Rover and put it in my name. So we did. i didn't ask 3 A. i don't know. 4 any further questions. 4 Q. You didn't ask any questions about that? 5 Q. Did this conversation happen when didn?t. 6 jail or after he was out? 6 Q. Okay. Are you aware of a Jaguar X~Type 2005 'l A. Meaning out on house arrest? 7 registered in your name? 8 Q. Right. 8 A. forgot about that one. yes. 9 A. When you say "out" i think otthe Science 9 Q. Whose car is that? 10 Foundation. On work release, so you have to be more 10 A. That?s a Palm Beach car. 11 speci?c. 11 Q. What do you mean "a Palm Beach car"? 12 Q. You tell me what happened, when the 12 A. it?s the Palm Beach house car, another run 13 conversation happened relative to where Jeffrey was at 13 around for people to use. 14 the time. 14 Q. And again, that?s a conversation that has to 15 A. I'd only be guessing again. i would say this 15 take place that results in a car being placed 16 probably happened a year ago, maybe less than a year 1 6 registered in your name? ago. to have to look. i don?t remember exactly the A. Yes. 18 Q. So it was either at a time when he?s at the 18 Q. Okay. Now we're talking about several cars 19 Florida Science Foundation or possibly on houss arrest? 1 9 herewas de?nitely before house 20 A. Yes. 21 arrest. it was probably during the time of the Florida 2 1 Q. "that are all being placed in your name? 22 Science Foundation, to be accurate. 22 A. Yes. 23 Q. Okay. Are you aware 2 3 Q. You never at any time ask any questions to 24 A. About eight or nine months ago. 2 4 Jeffrey Epstein why are you placing these cars in my 25 Q. Okay. Are you aware of a Mercedestenz CLK 25 name? Larry Visoski October 15, 2009 did not. 1 Q. Who drives that car, Ford 2 Q. So your suspicions were never -- your 2 A. That was shipped to St. Thomas. 3 curiosity was never piqued at ail as to why these cars 3 Q. For who to use and for what purpose? 4 are being placed in your name? 4 A. Well, that car shouid have been put under LSJ, 5 A. My curiosity was piqued. 5 LLC. 6 Q. You never asked him the question, you just 6 Q. What?s LSJ, 7 agreed to do it? 7 - A. Little St. James. 8 A. That?s correct. 8 Q. And that?s a corporation? 9 Q. That goes for the Jaguar X-?i?ype? 9 A. Yes. 10 A. Yes. 10 Q. Your understanding is that?s a corporation 1 1 Q. Are you with a Big Dog 11 af?liated with Jeffrey Epstein? 12 Chopper Motorcyoie, 2003? 12 A. i know it's a corporation. I don't know its 13 A. That is mine. 13 to Jeffrey. 1.4 Q. Yours? 1% Q. At this point in time, the way that this car 15 A. Yes. 15 comes about is through a conversation with yoursetf and 1. 6 Q. Registered in your name for a good purpose, 16 Jeffrey Epstein? 1? right? 1? A. Yes. yes. 18 A. Yes, it is. 18 Q. Soto make some representation that this - 1 9 Q. At your house? 19 that this corporation LSJ, 1.1.0, you're not sure if that 20 A. Yes. 20 has any af?liation with Jeffrey Epsteindon?t have any facts to tie the two 22 A. Absoluteiy. 22 together. 23 Q. Ail right. Ford 2008, registered in 23 Q. Common sense woutd dictate? 24 your name, are you famitiar with that? 24 A. Yes. 25 A. it?s not registered in my name. 25 Q. OkayOkay. So if that?s registered in your name. 1 MR. CRITFON: Form. 2 that woutd be a shock to you? That would he a surprise 2 BY MR. EDWARDS: 3 to you? 3 Q. Again, that?s not a car that you use, the Ford 4 A. Yes. it woutd be. 4 5 Q. There should he no documentation from you 5 A. No, it?s not even here. 6 where you wouid he the registered owner of the Ford 6 Q. And when you say on St. Thomas, is it on 7 actuai St. Thomas, or is it on Little St. James? 8 A. What year? 8 A. No, it?s on St. Thomas. it's a work vehicle. 9 Q. 2008. 9 Q. For whom? 10 A. i remember buying that car. i just that 10 A. For the workers, for the island. 11 shouldn?t be in my name. 11 MR. REENHART: Be careful to answer his 12 Q. What do you mean you remember buying that car? 12 question. I think his question isat! the car purchases for 13 St. Thomas or Littie St. James isiand? Where 14 Mr. Epstein. i'm a car fanatic, so for years this been 14 physicatty is the car, if you know. 15 the car-shopper. i'm the car fanatic. 15 THE i don?t know for a fact. 16 Q. Okay- But these cars aren?t classic vehicles- 16 BY MR. EDWARQS: These are vehicles that are not being refurbished or Q. it?s your understanding it's on St. Thomas? 18 anything, they?re being driven around town? 18 A. Yes. 19 A. No, but they?re fun. The new Range Rover is a 19 Q. And when you say "the workers," what?s going 20 nice car. 20 on on St. Thomas to where there?s workers that need an 2 1 Q. This Ford F250, that?s a car aiso that's Paint 2 2 F-25t}? 22 Beach as you woutd say a Pairn Beach car? 22 A. Just moving sand. I don?t know the exact 23 A. No. 23 detaii for it. 2 4 Q. That?s a car that stays at your house? 24 Q. What were you toid about the need for this car St. Thomas? Larry Visoski October 15, 2009 2 05 2 1 A. They need a work truck. 1 Ci. Okay. And by "Jeffrey's boat," it was 2 (It. To do what? 2 purchased with Jeffrey?s money? 3 A. I don't know what the detaii or the - you 3 A. That is correct. 4 know. what the job detail was for the truck. Theyjust 4 Q. Do you know how much that cost? 5 needed a work truck. 5 A. I think it was 80,000. 6 Q. So Jeffrey Epstein teiis you they need a work 6 Q. Do you know how much the Ford F-250 cost? 7 truck on St. Thomas and that's the only description that i A. Twenty??ve, i?m guessing. batipark. 8 you're given? 8 Q. Do you know how much the Jaguar X?Type cost? 9 A. Yes, to go purchase and get the best deai 9 A. 11,000. 10 can on a pickup truck. and that's what you know how much the Mercedes-Benz CLK 13. some reason it got put in my name. 11 cost? 12 (Off the record discussion.) 12 A. 35,000. 13 BY MR. EDWARDS: 13 Q. Do you know how much the Land Rover cost? 14 Q. Whose money was used to purchase the truck. 14 A. 68,000. 15 You say you purchased the truck. I want the record to 15 Q. Do you know how much the Mercedes-Benz SUV 1 6 he ciear whether you?re purchasing it with your money? 1 6 cost, that's yours, right? The Chevy Suburban is yours A. No, this was wire-transferredwait? 18 don't remember how that -- i think it was a wire 18 A. Yes, i remember how much those cost too. 19 transfer or a check was FedExed from the New York of?ce 19 Q. is there another boat, 35-foot Donzi 20 to pay for that. ?that shoutd not be in my name, is what 20 powerboat. 1999? 21 i?m getting at. 2?1! certainty change that, but i 2 1 A. That?s the one i thought you were taiking 22 thought you wer 22 about originally. 23 Q. i understand that. 23 Q. That's the same boat? 24 A. No, I'm being yeah, i didn't. 24 A. That?s the same boat. 25 MR. REINHART: There's no question. 25 Q. is there any other boat that?s registered MR. EDWARDS: 1 your name? 2 Q. 34?foot JVC Powerboat, 2000, owner LSJ, LLC, 2 A. No. 3 registered to Larry Visositi. Do you know that? 3 Q. Did you know that in -- tet rne ask you this: 4 A. Yes. . 4 Do you have a 2003 Ferrari 5 Q. You knew that that boat was registered in your 5 A. No. 6 name? 6 0. Any reason why the car is registered in your 7 A. its registered to LSJ. it's Jeffrey's boat 7 name and the asking price is $159000 being acid in New 8 that we keep here in West Paim Beach. 8 York? 9 Q. And do you keep it at your home? 9 A. That car is not registered in my nameits registered 11 Q. Do you know that the registration is to your name. 12 homeyOur name? 13 A. it?s used in my home address. yes. 13 A. Because i was trying to so]! it. 14 Q. Why was that done? 14 Q. Why were you trying to salt it? 15 A. We were eventually going to ship it out to 15 A. it was Jeffrey?s car and we didn?t want it 3. 6 St. Thomas for it to five, but since Jeffrey?s here, 16 anymore. 17 we're keeping it in Fiorida, and when we ship the boat 1? Q. Why wouid he put his pilot in charge of 18 over. we will change titie to the Little St. James 18 setting his Ferrari? 1 9 address. 19 A. Because i bought it. 20 Q. What do you mean "since Jeffrey's here we're 20 Q. How much did you buy it for? 21 keeping it in Florida"? What does Jeffrey being here 21 A. 179,000. Now, when i say "i bought it," it 22 have to do with keeping a boat that?s registered in your 22 was his money. I was the one that negotiated it, to he 23 name and to your address 23 clearNew York. 2 4 A. Weii, i have access to use the boat, you know, 24 Q. Are you aware of the Zorro Trust winning an 2 5 here in Ftorida, but it?s Jeffrey?s boat. 25 85 mitiion?dotlar Power Bait iottery in 2008? Larry Visoski October 15, 2009 MR. Mr. Edwards, he needs to expanc 2 MR. CRETTON: Say that again. 2 upon one eariier answer he gave when you asked him 3 MR. EDWARDS: The Zorro Trust winning an 3 if he knew anybody else who worked at the Florida 4 85 claiming the ticket for 4 Science Foundation. 5 85 Power Bali ticket in 2008. 5 BY MR. EDWARDS: 6 THE WETNESS: No. 6 Q. Okay. '3 BY MR. EDWARDS: 7 A. My wife worked there. When you used the words 8 Q. Have you ever iisted your employer as 8 "worked there" -- or not referring to her as a past 9 Ghisiaine Air in making political contributions? 9 tense. but she werked there when it ?rst opened 1 0 A. i may have. 10 answering the phones. 13. Q. Did you know that you had made politicai 11 Q. What?s your wife?s name? 12 contributions 12 A. 3.3 A. Yes, i have. 13 Q. How does she spell that? 1 4 Q. iis?ting your needed a company name for that event, and i 15 Q. Same iast name as you? 1 6 had put Air Ghisiaine. 16 A. Yes. 17 Q. And NES, LLC wouldn?t do? 17 Q. How tong did she work there? 18 A. i didn't think of it at the time. 18 A. A month, maybe. 19 Q. Did somebody teii you to use Air Gnisiaine 19 Q. And she was answering the phones for the 20 rather than the company that has been paying you? 20 Fiorida Science Foundation? 2 A. No. 21 A. Yes. 22 Q. You iust chose to use an empioyer that isn?t 22 Q. Do you have a good relationship with your 23 actually your employer, nor have they ever been? 23 wife? 24 A. 1 represent Air Ghisiaine, JEGE and Hyperion 24 A. i think so. 25 as chief piiot, so 1 consider those reaiiy the companies 25 Q. You stiil don't know what the Fiorida Science 2 2 1 2 1 that i work for and never realiy associated myself with 1 Foundation does? 2 NES, LLC as my reaiistic empioyer. So when i go to a 2 A. No, because she doesn?t. 3 convention, an aviation convention, and somebody says 3 Q. She doesnt know what it does either? a who do you work for, i use the name JEGE because that?s: 4 A. We never taiked about it. 5 the name of the Boeing company. 5 Q. You never talked to your wife about what she 6 Q. But when sit here and ask you who you work 6 did? 7 for, you give me a different answer. "i A. No. 8 A. You?re asking for the absolute correct answer, 8 MR. CRETTON: He knew she was answering 9 which is where my paycheck comes from, which is NES, 9 phones. 10 LLC. i probably have used that twice in t? or 18 years 10 BY MR. EDWARDS: 13. as my empioyer. 1 3. Q. Do you know of any other empioyees, friends, 12 Q. Do you know Dana Burns? 12 agents, relatives of Jeffrey Epstein who he places his 13 A. I know the name. yes. 1 3 property in their names, registers them in his names or 1 4 Q. How do you know her? 1 4 anybody eise? 15 A. i've seen her on the airpiane a couple times. 15 A. Not to my knowledge. don't know. 1 6 Q. Somebody that you know to he invoived 16 Q. To your knowiedge, you?re the oniy person? 17 romanticain or sexuain with Jeffrey Epstein at any 17 A. I'm the oniy one i'm aware of. 18 time? 18 Q. And with respect to minor girls being on the 3.9 A. I don?t know that. 3.9 airpiane, that being under the age of 18, how many times 20 Q. Are there any other cars, vehicles, items, 2 0 wouid you say that you have ?own giris into the 21 other things that are registered in your name that are 2 1 country, into the United States where you have given a 22 actuaiiy Jeffrey Epsteln's? 22 date of birth to Customs of somebody on the airpiane 23 A. No. You've actuaiiy covered them and 23 that is under the age of 18? 24 actualiy shed light on some that i did not reaiize, iike 24 A. i?d have to look at ?ight records to verify 25 that Ford. 25 or give you a correct answer. i don?t know any to my Larry Visoski October 15, 2009 2 13 2 3.5 1 knowledge at this point. 1 leave? 2 Q. What flight records would you have to look at? 2 A. Us as the crew. 3 A. The passenger manifests. 3 Q. Okay. So if a massage table had ever been 4 Q. Passenger manifests would have the date of 4 used, it would have been you and the crew who would have 5 birth on it? 5 been responsible for either taking towels or doing 6 A. No. It would have a name, but I don't have 6 something with the massage table? 7 Q. But at some point in time you remember people, 7 A. Absolutely. 8 minor date of births. coming into the country and that 8 Q. And if understood your testimony, you never 9 being tinned over to Customs? 9 saw a circumstance where it appeared to you that the 10 MR. Form. 10 massage table had been used in any manner; is that 11 THE WITNESS: don't remember anybody 11 correct? 12 transporting on the airplane from the country back 12 A. That is correct. it stayed in the same 13 into the U.S. that was a minor, to my knowledge. 13 location since the day it was put on there. 14 BY MR. EDWARDS: 14 Q. You were asked a bunch a number of 15 Q. Okay. Within the country. minors flying -- 15 questions about Mr. Epstein, l'il use this 16 A. i don't know. 16 Mr. Epstein is the person who directed you generain 1? Q. - on a plane? 17 unless one of -- someone else who worked on his behalf 18 A. i don?t know dates of birth. 18 called you and asked you to, say, set up a time to leave 19 Q. And any people that you knew to be minors on 19 or pick up luggage, et cetera. My question to you is 20 the airplane, were they always accompanied by parents or 20 this: Have you flown in the past for other private 21 were there minors on the airplane that you?re aware of 21 individuals like Mr. Epstein, as distinct from a 22 that were not accompanied by parents? 22 commercial? 23 A. i didn't know either way. i mean, people 23 A. Yes, i have. 24 would get on the airplane and get off the airplane. i 24 Q. And approximately have you flown for tour, 2 5 could tell you there were times people would get on that 2 5 ?ve, six other private individuals over the yearsdidn't even know were on the airplane. Our focus is 1 A. Three. I had a short career as far as 2 up front. 2 transferring of owners. 3 Q. Was there a massage table on the airplane? 3 Ci. ln terms of transferring to the other owners, 4 A. Which aircraft? 4 separate and apart from Mr. Epstein, again, every 5 G. On any of them? 5 individual is different, but was your relationship 6 A. The Boeing used to have a table on there, but 6 really any different with any of those other 7 it stayed in the same spot and appeared to be never 7 individuals? That is, you were in essence you were 8 used. 8 hired to perform a specific task: Fly an airplane to 9 0. Okay. So to the best of your knowledge, you 9 get from Point A to Point 8 and get the people there 10 have no knowledge of that massage table on the airplane to safety? 1 1 ever being used? 1 1 A. My first job, corporate-wise, was for an owner 12 A. Correct. 3.2 in Miami and was hired as a pilot, but yet, i would go 13 MR. EDWARDS: I don't have anything else. 13 to his house and maintain a boat that was in the back of 14 CROSS (LARRY 14 his house above and beyond my call of duty because interest in boats. it?s just something like to do. 16 Q. Mr. Visoski, i have just a few questions. You 16 But i always treated Mr. Epstein like any of the other were just asked about a massage table on the any of prior clients that 1 had as owners. i knew that was 3.8 Mr. Epstein's airpianes and you said there was a massage 18 not afraid to work for a living, and they understood 1 9 table on the Boeing? 1 9 that. 2 0 A. Yes. 2 0 Q. And it sounds like at least the first owner 2 1 Q. Okay. Was there always a massage table on the 21 that you worked for asked you to do similar things that 22 Boeing oriust for a period of time? 22 you've done for Mr. Epstein, such as take care of a boat 23 A. Just for a period of time. 23 or purchase a boat or maintain the boat? 24 Q. All right. And who?s responsible for cleaning 24 A. Sure, absolutely. 25 up the airplane after Mr. Epstein andlor the guests 25 Q. So your relationship with Mr. Epstein with Larry Viseski October 15, 2009 regard to if you bought boats or you bought cars on his 1 Ltd? 2 behatf, that?s very similar to your prior experience 2 A. No, i have not. 3 with working with another private individuai? 3 Q. Did Mr. Edwards, in approximateiy four hours, 4 A. That is correct. 4 tittie over four hours of questioning, ever ask you one 5 Q. In terms of the records, the manner in which 5 question about LM. that you can recaii? 6 you ?ew the piano or i don?t want to say flew the 6 A. Not that i recait. 7 piano. but in which you operated and maintained the 7 Q. Have you ever heard the name Did you 8 piano for Mr. Epstein are substantially the same you've 8 ever know someone named 9 done with other private individuais? 9 A. Never heard that name. 10 - A. Right. exactty the same. We wouldn't treat 10 Q. In approximateiy four~and?a~half hours of 13. Mr. Epstein any different than any prior previous 12 questioning by Mr. Edwards. did he ever ask you about 12 jobs that 1 had. it?s the same routine we carry over 12 13 and that?s why we?re good at what we do. We take care 13 A. No, he did not. 14 of the airpianes to the best of our 14 Q. in approximately the are you with 15 Q. is your focus as the pitot, as the captain of 15 an individuai by the name of Jane 16 both of the airplanes when you took over that 16 A. I never heard that name. 1? responsibitity a number of years ago, is it your 17 Q. in approximateiy four?and-a-hatf hours of 18 ohiigation to get the passengers there safety onhoard 18 questioning by Mr. Edwards, did he ever ask you 19 and safely to the destination and then return? 3.9 questions about Jane 20 A. Yes, that was aiways iota number one. 20 A. No, he did not. 21 Q. And most of us have had to say a much more 21 MR. That's i have. 22 substantiat experience in flying commercial planes and I 22 MR. EDWARDS: i only have two questions based 23 rareiy see in fact, I can't remember the last time 23 on what your testimonyjust was to Mr. Critton. 24 particuiarly after 2001 I saw the pilots coming back 24 25 into the cabin shaking hands and heiping distribute the snacks or liquids. Maybe i?m not on the same ?ights 1 (LARRY 2 that some of the other lawyers here are, but i assume 2 BY MR. EDWARDS: 3 you tiy commerciat from time to time? ?3 Q. You said you had three other peopie that 4 A. Sure. a you?ve ?own for? 5 Q. Do you ever see the piiots interacting with 5 A. Three other previous jobs. l?rn trying to be 6 the peopie who are in the back of the airplane? 6 as accurate. 7 A. No, not at ali. They stay at their station up 7 Q. Those are private individuals? 8 front. 8 A. That is correct. 9 Q. You got as the captain of the pianos, when 9 Q. And who are those people? 10 you're ?ying, you have substantiai responsibitities not 10 A. Hero Gtimpsure in Coiumbus, Ohio, and Edward 11 oniy to the peopte on the plane, but as well to the air 13. Seltzer in Miami. And then the other was Torn Boyd, and 12 space which you?re ?ying? 12 that was more of a Learjet charter, but he was the owner 3.3 A. Yes. I 13 of ?ve Learjets. Those are my oniy three gobs in my 14 Q. Okay. By the way, we?ve been here about -- 14 life. 15 for about an hour and ten we started about ten. it?s 15 Q. Aiso weaithy indiViduals? 16 now 3:30. Did you ever hear the name Has 16 A. Big time. 17 Mr. Edwards ever asked you one question about 17 Q. And did you know what they did for a iiving? i8 MR. EDWARDS: is the question have you ever 18 A. Those 1 did, yes. 19 heard of her or did 1 ask any questions about her, 19 Q. And did you ever go visit any of those peopie 20 or did you ask both questions and give the same 20 in iaii?? 21 answer? 21 MR. CRETTON: Form. 22 MR. CRITTON: i?ll break them down. 22 THE WETNESS: i know my ?rst individuai had 2 3 MR. EDWARDS: It doesn?t matter to me. 23 troubie with the law after I had ieft. i don?t 24 BY MR. CRITTON: 2d remember what it was pertaining to; but no, I never 25 Q. Did you ever meet an individuai by the name of 25 visited any of them in tail, no, sir. Larry Visoski October 15, 2009 MR. EDWARDS: 1 CERTIFICATE OF OATH 2 Q. Even the one who had troubie with the law, you 2 THE STATE OF FLORIDA 3 didn't go visit him in jaii? COUNTY OF PALM BEACH 4 A. No, i did notthem put vehicles or other 6 {ha undersigned authority. certify that 6 beats or 3353 your name? 7 LARRY personain appeared before the and was duty 7 A. No. 8 sworn on the 15th day of October, 2009. 8 Q. Okay. Any of those peopie ever deed any 9 9 property or acres or anything like that to you? 10 Dated this 22nd day of October. 2009those peopie ever hire your wife 1 2 for employmentAnd your attorney, is that your attorney paid 15 15 for by you, or is this somebody that?s hired by Jeffrey Wendy Breath Anderson, RPR, ORR, PPR 1 6 Epstein? 16 Notary Public State of Florida A. it is somebody that is hired by Jeffrey My Commission Expires: 9190/2013 18 Epstein 17 My Commission No; DD 936647 19 MR. EDWARDS: Okay. #1 ?542 2 0 MR. CRETTON: One follow-up to your question. 20 2 1 RECROSS (LARRY VESOSKE) 2 1 22 BY MR. CRITTON: 22 23 Q. With regard to the private individuals that 23 24 you worked for prior to Mr. Epstein, what was the 24 25 longest period of time that you worked for thoseThe iorigest period of time was ?ve years and 1 i i A . 2 THE STATE OF FLORIDA 2 the shortest being two years. 3 COUNTY PAW BEACH 3 MR. Thank youEDWARDS: We? order' Reporter sea: Kiwi; Pugiigi?ilhd fir thee Stgtae Egg 5 MR. We?i] read. 6 Rages at?arge. gadgereby?hai 1 gas I . au ooze 0 an repo sa: eyes on 6 We 1; take a cop)" from page! 7 stehotype: and thatthe foregoing pages are a tree sad 7 mini with index. correct transcription of my shorthand notes of said 8 W.t 8 deposition. ?955 excuse 9 I further certify that said deposition was 9 (Deposition was concluded at 3:37 gm.) taken at the time and place hereinabove set forth and 1 0 10 that the taking of said deposition was commenced and compieted as hereinabove set out. 1 3.1 12 2 further certify that I am not ahorney or 3.2 counsel of any of the parties, oer am I a reiazive or 1 3 emptoyae of any attorney or counsel of party connected 1 4 13 with the action. nor am I ?nancieliy interesied in the 5 action. 14 1 6 The foregoing codi?cation of this transcript 15 does not appiy to any reprodoction of ihe same by any 3- 7 means unless under the direct conhot ahdior direction 1 8 1 6 of the oedh?ying reporter. 1 9 17 Dated ihis 22nd day of October, 2009Wendy Beath Anderson, RPR. ORRJob #127542 23 2 4 2 25 25 Larry October 15, 2009 2 2 5 227 1 DATE: October 22. 2009 RATA 2 TO: LARRY Job #127642 . . do Robert 3? Grim?! JR 2 RE. LM. VS. EPSTEIN CR. WMB 2 IN RE: LM. vs. {Epstein fl 10.15.09 JOB 127542 Please take notice that Thumday? ma 1 5h 5 [30 WRZTE ON TRANSCRIPT - ENTER CHANGES HERE 5 of October. 2009, you gave your deposition to the 6 PAGE LZNE CHANGE REASON above-referred matter. At that time? you did not waive ?3 signature. it is now necessary that you sign your 7 deposition. 8 As previousiy agreed to, the transcript wilt be furnished to you through your counsel. Please read 3 9 the following instructions carefully: At the end of the transcript you will find an 10 errata sheet. As you read your deposition, any changes 9 or corrections that you wish to make shouid be noted on 10 13. the errata sheet. citing page and tine number of said change. DO NOT write or: the transcript itsett. Once *1 12 you have read the transcript and noted any changes, he 12 sure to sign and date the errata sheet and return these 13 13 pages to me. If you do not react and sigh the deposition 14 14 within a reasonable time (Le, 38 days unless otherwise 15 directed) the origioai, which has aiready been forwarded 16 15 to the ordering attorrtey. may be fried with the Clerk of the Court. if you wish to waive your signature. sign 17 16 your name in the blank at the bottom of this ietter and 18 Please forward {no original signed errata sheet to this {mum ?1 to office so that copies may be distributed to oil parties. Very truly yours, 1 9 18 Under penaily of perjury, i declare that have read my 19 28 deposition and that it is true and correct subject to Wendy Beam Andersom RPRI ORR any changes in form or substance entered here. 20 ESQUIRE DEPOSITION SERVICES, INC. 21 535 North Flagler Drive, 21 West Palm Beach. Fiorida 33401 22 DATE 22 I do hereby waive my signature. 23 23 2:2 SIGNATURE OF DEPONENE 2 4 VISOSKI THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 hereby certify that i have read the 6 foregoing deposition by me given, and that the 7 statements contained herein are true and correct to the 8 best of my knowiedge and beiief, with the exception of 9 any corrections or notations made on the errata sheet, 1 0 if one was executed. 1 1 12 Dated this day of . 13 2009LARRY 2 0 Job #127542 0?1 DEFENDANT BRADLEY EDWARDS STATEMENT OF UNDISP UTED FACTS Epstein v. Edwards, 6! al. Case No. 50 2009 CA ATTACHMENT 20 35 Certi?ed Copy UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, Plaintiff, vs. Case No. 08-80893? OHN SON JEFFREY EPSTEIN, Defendant. DEPOSITION OF MARK EPSTEIN September 21, 2009 11:30 a.m. One Penn Plaza, New York, New York Lisi . ?Mm-?53. .- . man?; I Tait Free: 800.211.3376 Facsimile: 954.331.4418 Suite 1300 515 East Las Dias Bouievard I Fort Lauderdaie, FL 33301 an Aiexander Galio Company Mark Epstein September 21, 2 05*? 48 M. Epstein Maxwell and knowing your brother, would that surprise you to hear that? MR. COHEN: Objection. A. I don?t know Ghislaine Maxwell. mean I know her, but you can tell me anything, it's not going to surprise me. Q. When you would see your brother and Ghislaine Maxwell, where would you be; at his house, at a function, out to dinner? A. Probably at his house more than anything. Q. Which house would that be? A. More likely Florida. Q. Do you know how he met her? A. No. Q. Do you know where she is now? A. NO. Q. When is the last time you saw Ghislaine Maxwell? A. Probably around when my mother died, that?s five and a half years ago. Q. Have you ever met Leslie Wexner? A. No. Q. Have you ever met Donald Trump? ESQUIRE an Alexander Gallo Company Toll Free: 800.211.3376 Facsimiie: 954.331.4418 Suite 1300 515 East Las OEas Boulevard Fort Lauderdale, FL 33301 Mark Epstein September 21, 2009 49 M. Epstein Yes. that through your brother? Yes. . Where was that? 10 . We flew up on my brother?s plane from Florida together. Donald was on the plane. Q. When? A. Somewhere between 5 and 10 years ago. Q. Okay. So we are talking about A. It's either late ?90?s early 2000. Probably more like late ?90'e. Q. Was that the only time you've met Donald Trump? A. Yes. Q. Which plane was this of your brother's? A. 1 don?t remember. Q. Was this one of the big planes, the 727? A. No. It wasn?t that one, no. gi;p Q. Okay. How many people were on this Chairplane? It was my brother, myself, Donald, i?he pilot the compilot. I don?t remember I Tet} Free: 800.211.3376 Facsimile: 954.331.4418 I Suite 1300 I I . I 515 East Las Olas Bouievard I Fort Lauderdaie, FL 33301 .at'mexanderSammie?! Mark Epstein 50 M. Epstein don?t remember if anybody else was on the plane. Q. What was the purpose of Donald Trump riding on your brother's airplane? A. You'll have to ask Donald. I think he wanted a ride back to New York. Q. What was your understanding of the relationship of Donald Trump and your brother? A. They were friends. Q. Do you know how they met? A. No. Q. When you say "friends," how? frequently did they associate? A. I have no idea. Q. What was your understanding did you A. I had no understanding. They were friends. That was my understanding. Q. When they were in the airplane together, they talked as if they were friends? A. Yeah, I talked to him like he was my I am a friendly friend. I never met the guy. guy. Q. Were there girls on the plane? September 21, 206? Tot! Free: 800.211.3376: Facsimite: 954.331.44i8 Suee 1300' 515 East Las Olas Boulevard Fort Lauderdale, Ft. 3330.1." ESQUIRE an Marauder Gaiio Company DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISP UTED FACTS Epstein v. Edwards, et a2. Case No. 50 2009 CA ATTACHMENT 19 Page 299 25 Wv?q??g - . .- ?Pa-mum-o wt I Page 301 1 A. i don't remember, Ma'am. He came from 1 video, even phones. 2 New Albany, Ohio. 2 Q. Would he also repair the televisions if . 3 Q. From New - 3 they needed work? i 4 A. New Albany, Ohio. 4 A. No. Q. New Albany, Ohio. Did he have his own 5 Q. No. Did you have any kind of intercom 6 business? 6 system in the house? 7 A. No, he worked for Mr. Epstein. He will 7 A. Yes, ma'arn. i 8 maintain all the computers. 8 Q. And what kind of system was that? i 9 Q. Was he there everyday? 9 A. It was standard office equipment, Lucid 10 A. No, ma?am. 10 Technologies maybe, but it was an intercom like we 11 Q. Do you know whether at that time Mr. 11 using right now. i 12 Epstein had an of?ce in Palm Beach? 12 MS. EZELL: Just let the record reflect 13 A. Not outside the house, no. 13 that the witness pointed to the telephone on 14 Q. Do you have any knowledge of whether or 14 the table that has a speaker phone. i 15 not the video equipment was - and I don't know 15 THE WITNESS: Yes, ma?am. 16 the technical term, forgive meMS. EZELL: 17 kind of equipment that would record for a certain 17 Q. And did you use that in your work? 18 amount of time and then record over that film? 18 A. Yes, ma?am. 19 A. Idon?t know. 19 Q. And what did you use it for? i 20 MR. Form. 20 A. Mr. Epstein used to page me when he 21 BY MS. EZELL: 21 needed me. I 22 Q. You don?t know? 22 Q. Did you have one of those phones in the 23 A. No, ma?am. 23 kitchen? 24 MR. CRITTON: Just for clari?cation,1 24 A. Yes, ma?am. i 25 may have misunderstood, but -I thought he 25 Q. And was there one out in the staff house Page 300 Page 302 1 said he didn?t even know the video equipment 1 as well? i- 2 existed until he read the FBI report. 2 A. Yes, ma'am. 3 MS. EZELL: He said he didn't know that 3 Q. Do you know where others were in the is 4 it was upstairs and downstairs, I believe. 4 house? 5 MR. CRITTON: I thought he said he didn?t 5 A. Probably have like 15 phones. We used to i 6 know that it even existed. 6 have three in the staff house, one in the cabana, 7 MS. EZELL: I may be wrong. 7 two in the master bedroom, one in each room, 8 BY MS. EZELL: 8 kitchen, dining room, Mrs. Maxwell's of?ce, the 9 Q. Did you know it existed before you read 9 garage. 10 the FBI report? 10 Q. Where was Mrs. Maxwell?s office? 11 A. No, ma'am. 11 A. Under the stairs next to the kitchen. 12 Q. I?m sorry, then I was wrong. 12 Q. Can you give me some idea of what size 13 How did you know then that the young 13 space that was? 14 technician from Ohio maintained the computers and 14 A. It was probably - we change the floor. 15 the video equipment? 15 Twelve by ?ve, something like that. 16 A. Because we used to request there were 16 Q. And was the computer equipment in that 17 always problems with the computers so he came to 17 space? 18 the house and he was the programmer. It was very 18 A. Yes, ma'arn. 19 sophisticated. 19 Q. Do you know whether Ms. Maxwell kept the 20 MR. CRITTON: Form to the last question, 20 names and telephone numbers of the girls who came 21 move to strike the answer as nonresponsive. 21 to do messages? I 22 BY MS. EZELL: 22 A. Yes, ma'am. *3 23 Q. How did you know then that he maintained 23 MR. CRITTON: Form. 24 the video equipment as well? 24 BY MS. EZELL: A. Because he was in charge of computers, 25 Q. Do you know that because you saw the .. .. .4. . 9 (Pges 299 to 302) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, Fl. 33141 Page 303 1 names and phone numbers? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma?am. 4 BY MS. EZELL: Q. Do you know if she kept pictures of the 6 giris on the computer? 7 A. Yes, she did. 8 Q. And you know that as well because you 9 happen to see them? 10 A. Yes, ma?am. 11 MR. CRITTON: Form to the last two 12 questions. 13 BY MS. EZELL: 14 Q. Were they similar to the pictures that 15 Ms. Kellen had on her computer? 16 MR. Form. 17 THE WITNESS: Yes, ma?am. 18 BY MS. EZELL: 19 Q. Did the pictures that they kept there 20 look like pictures that were posed? 21 A. They were more casual. 22 Q. Did they look as though the person being 23 photographed knew that they were being 24 photographed? 25 MR. CRITTON: Form. Page 305 1 computer? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. And did she generally have phone numbers for those girls? A. Yes, ma?arn. Q. And were they generally pictures of the girls? MR. CRITTON: Form. THE WITNESS: No, ma'am. BY MS. EZELL: Q. Anddid Ms. Maxwell have a list of the giris who came to give massages? MR. CRITTON: Form. THE WITNESS: Yes, ma?am. BY MS. EZELL: Q. Did she have telephone numbers generally? A. Yes, ma?am. MR. CRITTON: Form. BY MS. EZELL: Q. Were there pictures on her computer of the girls who came to give massages? MR. CRITTON: Form. BY MS. EZELL: Page 394 1 THE WITNESS: No, ma'am. 2 BY MS. EZELL: 3 Q. And what can you tell me about that, what 4 lead you to draw that conclusion? 5 A. They were probably taken in parties in 6 big reception or banquet. 2 MR. CRITTON: Let me offer as a 8 suggestion, not that you have to accept or 9 that you would, you're using the term young 10 girls generically, he has probath seen 11 many, many young girls, there was no 12 you?ve used it interchangeabiy with just 13 young girls versus young girls who may have 14 come to -- purported to give a massage and, 15 therefore, that may be a different answer, 16 so that's part of my form objection. 17 MS. EZELL: Okay, thank you. 18 BY MS. EZELL: 19 Q. When I asked you about Ms. Kellen whether 20 she had a list of the girls and telephone numbers, 21 I think I asked about those girls that came to 22 give messages, but let me go back and just ask it that way. Did you notice that Ms. Kellen had a list of the giris that came to give messages Page 306 I Q. Ms. Maxwell I'm talking about. A. Yes, ma?am. Q. And were those pictures the more casual ones that you described when I asked whether or not the subject looked as though she knew she was being photographed? MR. CRITTON: Form. THE WITNESS: i'm sorry, can you repeat? BY MS. EZELL: Q. Yeah. The pictures of the young girls - who came to the house to give messages that were . on Ms. Maxwell's computer, did they appear to have - been taken when the girls knew they were being photographed? MR. Form. THE WITNESS: I don?t think they knew they were being photographed. BY MS. EZELL: Q. I believe you said they were more casual pictures. A. Yes, ma?am. Q. Did you notice any node photographs in those pictures? A. Yes, ma?am. MR. CRITTON: Form for the last question. - - 10 (Pages 303 305) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, Fl. 33141 ?rmwN? a Page 347 F.E., and I think you told us that you had seen her, you recognized her photograph. A. Yes, i did. Q. On how many occasions did you ever see her at the Epstein home? A. More than three times. More than three? A. Yes, sir. Q. That's as accurate as you can be? A. Yes. Page 349 Q. I?m sorry? I A. Yes, I did, I told the police. Q. And at the time that you spoke with the police and gave them a statement, isn?t it true, A Mr. Rodriguez, that you were no longer employed by Mr. Epstein? A. Yes. Q. And you understood that you were required to tell the police of?cers the truth at that time? ummv WwwAv-?v- Q. More than three? 11 A. Yes. i A. More than three. 12 Q. And if! understood your testimony I Whether it was four or five you don't 13 believe from July 29th through today, you at no 21 know, but more than three? 14 time asked any of these girls how old they were. i A. More than three, sir. 15 True? I Q. in terms of F.E.'s age, did you ever ask 15 A. No. her what her age was? 17 Q. And as to whether the girls were under 18 i A. No, sir. 18 or 18 or over 18, you really didn?t know one way Q. Did she appear to you to be someone at 19 or the other at the time. Would that be a fair least from seeing her and recalling her that she 20 statement? 21 appeared at least to you to be while a young woman 21 A. Yes. 5 22 appeared to be someone who was 18 or older? 22 MR. WILLITS: Object to the form of the if 23 A. No, sir. 23 question. 24 Q. Okay. Well, did you ever say anything to 24 BY MR. CRITTON: 25 the police or did you ever -- were you ever 25 Q. On Exhibit 6 there is a person who's Page 348 Page 350 1 concerned about that such that you told someone? I covered, the lady that Ms. Ezeil asked you about I .i 2 A. No, sir. 2 believe was on the right~hand side of the 3 Q. Haven't you told the police, sir let 3 photograph. There is a young lady on the 4 me strike that, let me ask it this way. 4 left-hand side with a black hat on. I 5 In your taped statement that you gave to 5 Do you recognize her at all? 6 the police did you not tell them that all of the 6 A. No, I don't recognize her. 7 girls appeared to you to be 18 or above? 7 Q. Okay. Thank you. With regard to the i 8 A. Sir, as far as when all these actions 8 photograph four that you saw that you think 9 that were taking place I was under an environment 9 possibly might be A.H., I think you told us that 10 that I thought I was going to be -- in other 10 you recall seeing that woman in the sauna at Mr. 11 words, I was afraid of any reprisal Mr. Epstein 11 Epstein's house on one occasion and she was naked. 12 and Mrs. Maxwell if I say something that is any 12 A. Yes. 13 idea of me because I have this confidentiality 13 Q. Was that near the end of your employment 14 agreement. What I saw that they were very young, 14 or the middle or the front and? 15 but I cannot say that they were 18 and oldJanuary 2005, sir, and I was 16 Q. Right. Let me just take you back to my 16 terminated in March, so that was two months prior. 17 question again and see if you can answer my 17 Q. And did you ever tell anyone that you had 18 question. 18 seen her naked in the sauna? 19 MR. CRITTON: Could you please read it 19 A. I told Louella. 20 back? 20 Q. Okay. And what did Louella say? . 21 (ihereupon, a portion of the record was 21 A. She was surprised. 22 read by the reporter.) 22 Q. Okay. Did you wake the young lady up in 23 THE WITNESS: I think I told the police 23 the sauna? - 24 thatMR. CRITTON: 25 Q. And do you know how old the young lady pow-??9? 21 (Fag to 350) Kress Court Reporting, Inc. 305?866-7688 7115 Rue Notre Dame, Miami Beach, Fl. 33141 DEFENDANT BRADLEY EDWARDS A TEMENT OF UNDISP UTED FACTS Epstein v. Edwards, 83? (12. Case No. 50 2009 CA 040800MMBAG ATTACHMENT 18 Original Transcript IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA L.M., Plaintiff, vs. Case No. 502008CA028051 AD JEFFREY EPSTEIN, Defendant. DEPOSITION OF LARRY EUGENE MORRISON TAKEN ON BEHALF OF THE PLAINTIFF VOLUME I Pages 1 to 200 October 6, 2009 10:55 am. 515 N. Flagler Drive West Palm Beach, FL 33401-4321 Jennifer DiLorenzo, court reporter Free: 800.211.3376 Facsimite: 954.331.4418 Suite 1300 515 East Las Olas Bouievard Fort Lauderdaie, FE. 33301 ESUIR: an Nuaner Galio Company Larry Eugene Morrison Volume I October 6' 102 Q. Would any of those girls look extremely youn 1 to you? I 2 MR. PIKE: Form. 3 A. Not Not that I thought. 4 Q. Not back in 2001, we're talking about? 5 A. Right, right. 6 Q. No. 7 What would Ghislaine Maxwell say to you, if: 3 anything? 9 MR. PIKE: Form. 310 A. She?d w~ Mostly small talk, just ?w She all kind of did the business management part of it as far as, you know, arranging cell phone I was having cell phone problems with the company cell phone, she would handle things like that, but she would have minor inputs on the interior work. Q. What was your understanding back in 2001 sti of the relationship between Ghislaine Maxwell and Jeffr Epstein? 19 MR. PIKE: Form. 20 A. I really didn't understand it. I thought 21 it was personal a personal and business. 22 Q. When you say "personal," did you think it we 23 sexual? 24 A. I thought maybe they were dating and, you 25 ESQIRE T011 Free: 800.2113? - Facsnnae:954.33144 Sakai? 515 East Las Dias Boater Fort Lauderdale, FE. 333 an Aiexander Gaiio Company Larry Eugene Morrison Volume I October 6, 2009 103 neg know, business relationship too. Q. Did you know who Ghislaine Maxwell was? A. Not right away, no; no. Q. Not right away? A. Right. Q. At some point in time you were curious enough to make an attempt to find out. if A. No, I ~w MR. PIKE: Form. A. w" heard about her and there was a book up in New York in the apartment that we stayed in that was You know, you?re sitting there with nothing to do, I read that. Do you remember the name of the book? It was just "Maxwell." . Have anything to do with her father? Porto Yeah, it was about him, that's what it was about. I mostly just flipped through looking at pictures, boats, and airplanes and stuff. Q. Back in 2001, the first time you had a real conversation with Ghislaine Maxwell MR. PIKE: Form. A. Yes. Q. mm what did that conversation consist of, if ,you remember? Toi! Free: 800.211.3376 Facsimiie: 954.331.4418 Suite 1300 515 East Las Dias Boulevard Fort Lauderdate, FL 33301 DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case No. 50 2009 CA ATTACHMENT 17 w? awn; Certi?ed Copy IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION L.M., Plaintiff, vs. CASE No. SOZOOSCA02805 AB JEFFREY EPSTEIN, Defendant. DEPOSITION OF LOUELLA RABUYO VOLUME I October, 20, 2009 10:10 am. 515 N. Flagler Drive Suite 200-? West Palm Beach, Florida 33401 Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Floridq Toii Free: 866.709.8777 Facsimiie: 561.394.2621 Suite 600 4440 PGA Bouievard ES I I I Paim Beach Gardens, FL 33410 an Mexander Gailo Com pany )ber 20, 2 Louella Rabuyo - Volume I October 20, 2009 9 no, you 1 head or shake your head, and she can't take that down. 2 A All right. 3 It?s also very easy to say uhwhuh or huh?uh, 4 but it kind of looks the same on paper, so you can?t do 5 that either. I'm going to wait until you finish your mes, 6 answer, and you have to wait until I finish my question, 7 because if we talk Over one another, then the court her I 8 reporter can?t get it down. 9 A Okay. Yes, sir. said .0 All right. So if you don't understand the a she .1 question, tell me you don?t understand and I?ll try to ask a better question. ,3 A Yes. ion, Okay. So you were hired in November of 2004 I .5y to be the housekeeper for Mr. Epstein? that :6 A Yes. i7_ And when you were hired, who exactly hired to work?8 you, who let me strike that. an taken?"1 sporter,i?? your ?5 ?ee: 866.7098}; . - I. . me: 561394.26? 1' SIRE Suite 5f. $40 PGA Bouievl Sardens, FL 334, quiresoiutions? When you were hired to be the housekeeper for mr. Epstein, who did you interview with? A Ms. Maxeell. Is that Ghislaine Maxwell or just Laine Maxwell? A Ghislaine Maxwell. And where did the interview take place? an Alexander Gaiiu Company Ton Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Bouievard Pafm Beach Gardens, FL 33410 DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISP UT ED FACTS Epstein 12. Edwards, 61? a1. Case No. 50 2009 CA 040800X300QMBAG ATTACHMENT 16 CASE AB Plaintiff, JEFFREY EPSTEIN AND SARAH KELLEN, Defendants. DEPOSITZON OF JANUSZ Tuesday, February 16, 2010 10:09 2:30 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1317 (561) 832?7500 PROSE Eiectronica?y signed by napkins {601-951-976-2934) Eiectronicaiiy signed by napkins (691.051676-2934) Electronicaiiy signed by cynihia hopkins (601 -651-976-2934) a- - ., -- URT REPO 3533?_- 4. x: -. - IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 1N AND FOR PALM BEACH COUNTY, FLORIDA - -. .-: RTING AGENCY, INC. Page 1 I. . .. . 224;. J. new. . . 2?34: . ammu- . a?nu?m v, - m' 3 Men-?- (561) 8327506 2675391 82:11 Page 14 1 Q. Okay. So, I assume then that your wife 2 that you are separated from I guess at the time, she 3 didn't come down to Palm BeachAnd this is somebody who still lives 6 somewhere other than Florida? 7 A. Correct. i 8 Q. So, you came down in February 2005 and 9 began working. What did you, what did you first 10 start doing for Jeffrey Epstein? 11 A. First I doing? 1 don't remember nothing i 12 special. 13 Q. Okay. Well, were you working em I will 14 rephrase it. Were you working only for Jeffrey 15 Epstein or were you working also for Ghislaine 16 Maxwell, the other person who interviewed you, or 17 anybody else in the house? i 18 A. I guess only for him.beoause she was visiting 19 a few times house, but 1 am employed by him. 20 Q. Okay. What was your understanding at that 21 time as to the relationship between Ghislaihe 22 Maxwell and Jeffrey Epstein? 23 A. They were like partners in business. 24 Q. Okay. What business was that, if you i 25 know? i Electronically signed by hopkins Electronically signed by hapkins {601-051e78-2934) Electronically signed by hopkins (6014151 ?9?6~2934) Page 154 1 A. No. 2 MR. GOLDBERGER: Form. 3 BY MR. EDWARDS: 4 Q. And have you known, just based on your 5 observations, Nadia to have girlfriends? And by 6 girlfriends I mean girlfriends that she would be 6 7 intimate with in addition to being the girlfriend of 8 Jeffrey Epsteinyou know somebody by the name of Jean i ll Luc Brunei? 12 A. Yes. 13 Q. How do you know him? 14 A. He was in the house like, I guess, a few 15 times. 16 When? 17 A. When? i 18 When was the last time you saw him there? 19 A A week ago. 20 Q. Today is, what, February 16th, and this is 21 a Tuesday. So, when we are saying a week ago, are 22 you saying it was last Tuesday, Wednesday, Thursday, 23 Friday, do you remember? 3 24 A. I don't remember the date but he stay maybe 25 three days, I think, in the house. i 82?97506 Eiectronica?y signed by hopkins {801 651-976-2934) Eiectronicaiiy signed by cynihia napkins (601 ~051-9?6-2934) Electronica?y signed by hopkins {601 4351-9256-2934) 9age 155 1 Q. Sor if he arrived on Tuesday. he stayed 2 through Thursday or Friday and w" i 3 A. Yes. 4 Q. Do you know what the occasion was for him 5 to come in town? 6 A. No. 7 Q. Where did he stay in the house last week? 8 A. One of the bedrooms upstairs. 9 Q. And was Mr. Epstein also staying in the 10 house? 11 A. Yes. 12 Q. All right. Did Mr. Brunei bring any 13 company with himwas him alone? 16 a. Yesthe house? 18 A I think he has been picked up by Igor at this 19 point. 20 Q. And where did he I assume he flew in 21 from somewhere? 22 A. Yes. 23 Q. Picked up from the airport, safe 24 assumption? He didn't just drive to the airport. 25 (A discussion was held off the record.) aseoam We, ?61) 332-7553 Electronically signed by [napkins (601-0518764934) Electronicaiiy signed by hopkins (691-051-976-2934) Electronica?y signed by napkins (601 ?(351-976-2934) Page 156 i 1 BY MR. EDWARDS 2 Q. So, do you know where it was that 3 Mr. Brunei flew in fromyou know where Mr. Brunel generally 6 lives? I mean is it New York, is it 7 A. I know that he spends some time in Florida, in 8 Miami, but exactly where he is, I don?t know. i 9 Q. But obviously he wouldn?t fly here to Palm 10 Beach from Miami, right, so he had to be coming from ll somewhere else you would assume? 12 A. Yes, I assume. 13 Q. Were you told similar to the way that 14 you have been describing throughout the deposition, 15 you?re told who is coming in town. Were you told he 16 was going to be at the house? 17 A. Yeah. Usually he requires to be picked up, so 18 I know that he is coming. 19 Q. Okay. We?ll go through some other 20 instances where you had occasion to pick him up_or 21 break plans, but talking specifically about last i 22 week: When were you first told that Mr. Brunel was 23 going to be coming into town? i 24 A. I think Igor told me that he has to go and 25 pick him up. A??gbyr Electronically signed by napkins {801 -051-976~2934) Eiectronicaliy signed by hopkins {601-0516762934} Electronically signed by hopk?ns {691-951-976-2934) Page 157 day off, I guess, because usually I 3 am the one who pick up people. So, I guess it was my 2 4 days off and lgor was working, so he went to pick him i 5 6 Q. Okay. It wouldn't be Story Cowles picking the best of your recollection Igor lO picked up Jean Luc Brunel sometime last week from 11 the airport and took him to the house? 12 A. Right. 13 Q. Do you know what car he took to pick him 14 up? 15 A. I think Cadillac Esoalade. 16 Q. The black Escalade? 17 A. Yes. 18 Q. And what did Mr. Brunei and Mr. Epstein do 19 for the three day stay when Mr. Brunei was staying 20 at Mr. Epstein?s house last week? 21 MR. GOLDBERGER: Form. i 22 THE WITNESS: I don't know. 23 BY MR. EDWARDS: 24 Q. Did you interact, communicate with 25 Mr. Brunei? .ks?i) Eiectronicaliy signed by napkins {601 ?51-976-2934) Eiectronica?y signed by cynihia napkins (801-051?976?2934) Eiectmnica?y signed by cynihia napkins {6814351676-2934) 2d75a91d-3eaa-42b3-aezz?b5d3c? 8261 Page 158 A. Yes. 2 Q. And what did he say as to why he was here? 3 MR. GOLDBERGER: Form. 4 THE WITNESS: Good morning. How are you? 5 Exchange handshakekitchen and he was cooking something and that's 7 it. 8 BY MR. EDWARDS: 9 Q. When you say he was cooking something, he a l0 was personally cooking? ll A. Yes. 12 Q. All right. So, this is a house that he is 13 familiar enough with and he is a regular enough . 14 guest that he makes himself at home? 15 A. Yes. 16 Q. Okay. And last week do you remember 17 anything in the threemday period that Mr. Brunei was 18 staying at the house that Mr. Brunei did from the i 19 time he woke up to the time that he went to sleep? 20 MR. GOLDBERGER: Form. 21 BY MR. EDWARDS: 22 Q. I mean did go to the movies? Did he go to 23 the beach? Did they just hang out around the house 24 and walk? 25 A. Yeah. I think he walked outside to the beach. 5 (561) 832*7500 COURT REPORTING AGENCY, INC. (561) 832-37506 Electronicai?y signed by hopkins {661-051-976-2934) Eiectronica?y signed by cynihia napkins (601?051676-2934) Electronicaiiy signed by hopkins (601 4351-3376-2934) Page 159 1 He was swimming in the pool, talking on the phone just i 2 what I remember. 3 Q. Okay. During the threemday stay last i 4 week, how often were I mean, i assuming that he 5 came in town to see Mr. Epstein; is that true? 6 A. Yes. 7 Q. And so the majority of his time during 8 that three days was spent hanging around with 9 Mr. Epstein? 10 A. Yes. 11 Q. All right. Did you see them talking with i 12 one another? 13 A. Yes. 5 14 Q. Where were they talking with one another? 15 A. In the cabana, outside sitting next to the i 16 pool. 17 Q. Ali right. And when you said that 18 Mr. Brunei walked to the beach, did Mr. Epstein walk 19 to the beach with himMr. Brunei walked alone? i 22 A. Yes. 23 Q. Who else was in the house last week while 5 24 Mr. Brunei was in the house? 25 A. Nadia, Sarah, and Story, I think. 2 . .. a (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-37506 Electronically signed by hopkins ~05? ~9?6-2934} Electronicaily signed by hopkins 4351 676?2934) Electronicain signed by napkins (601-0513764934) Page 160 i 1 Q. Sarah Kellen? 2 A. Yes. 3 Q. And Story Cowles? 4 A. Yes. 5 Q. Okay. Who else. Igor? 6 A. Igor. I guess that's it. i 7 Q. Did you overhear any of the substance of i 8 the conversations that Mr. Brunei was having with i 9 Mr. Epstein? 10 A. No. 11 Q. A11 right. What is your understanding as i 12 to the relationship between Mr. Brunei and 13 ex. Epstein? 14 A. I guess they are friends. 15 Q. Okay. In addition to being friends 16 well, let me ask this question first: Do you know i 17 when they became friends? 18 A. No. 19 Q. You don't know how long they have known 20 each otherYou don't know who introduced them? 23 A. No. 24 Q. They could have met since they were five 25 years old or they could have met five years ago for (1) - CQUET I Electronica?y signed by hopkins {601 Electronicaizy signed by napkins {801 451-976-2934) Electronicaiiy signed by cynihia hopkins {601 4151 -9?6-2934) 82619 Page 172 to Miami. 2 Q. Okay. 3 A. But how long he stay in Miami, how long he 4 stays outside of Miami, I have no idea. 5 Q. And when was that occasion where you know i 6 that Jean Luc Brnnel was in Miami or spending time 7 in Miami? 8 A. I think at one point I drove him to Miami. 3 9 Q. And when was that? 10 A. I think the time he was here in this month of 2 il January. I think I drove him back to Miami from, from 12 the Palm Beach, Palm Beach house. 13 Q. Okay. So, that time in January he flies 14 into the Palm Beach airport from some undisclosed or 15 unknown location, you take him to the Palm Beach 2 16 house, right? 17 A. Right. 18 How long does he stay on that occasion? a 19 A. Maybe three days. 20 And during that threewday period were any i 21 other did any females accompany him to the Palm 22 Beach house? 23 .A. No. I don't remember. I don?t recall. 24 Q. Well, maybe this will jog your memory: i 25 When you drove him to Miami, did you drive him (was co 832-7555" Electronically signed by hopkins Electronically signed by napkins (601~051~976-2934) Electronically signed by hopkins (601 4.151 4376?2934) 821319 Page 173 1 alone ?w 2 A. Yes. 3 Q. m? or did you drive him with somebody 4 else? 5 A. Alone. 6 Q. Okay. And where did you take him to in 7 Miami? 5 8 A. i don?t know. He left he told me his car, 9 one of his friends somewhere in Miami Beach, so I 10 dropped him over there and he pick up his car over 11 there. 12 And who is his friend, do you know? 2 13 A I don't knowMiamiWhat kind of oar was that? 17 A Mercedes. a 18 Q. All right. And do you remember where it i 19 was in Miami that his car was parked? 20 A. Some mm I don?t remember the others, but 21 somewhere in Miami Beach. 22 Q. All right. At a condo, at an apartment, 23 on the side of the road, a houseprivate house. 25 Q. A private house on Miami Beach. Do you (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Eiectronically signed by napkins (601$51-976-2934} E?ectronically signed by cynihia hopkins (601-051?976-2934} Eiectronicaily signed by napkins (601-051-9?6-2934) Page 174 1 know the name of the person that lived at that 2 house? 3 A. No. 4 Q. All right. In talking about this person 5 Jean Luc Brunel, would "w you said he came here last 6 week. He came here in January. Stayed three or 7 four days each time, two consecutive months. Since 8 Mr. Epstein has been out on house arrest is Jean Lao i 9 Brunel one of the people that visits on a 10 basis? ll A. NO. 12 Q. Okay. 13 A. There was no regular visit. It?s just 14 occasionally I would say. 15 Q. Okay. So, prior to the January visit, 16 when is the previous time that Jean Luo Brunel was 17 at Mr. Epstein's house? i 18 A. I don't remember. I don't rememberthe people who frequently i 20 calls Mr. Epstein? 21 A. Yes. 22 Q. And Mr. Epstein frequently calls him? 23 A. I don't know. 24 Q. Okay. Well, I guess you would only know 25 the calls that come in and you take messages, right? ii (561) 750 'ag am, me. (5832?42505 Electronica?y signed by hopkins {601 $51-976-2934) Electronicaiiy signed by hopkins (891-051-976-2934) Electronically signed by hopkins (601-051-976-2934) Page 175 i 3. A. Right. 2 Q. How times would you estimate ww I know you 3 told us two times in 2010. Let me ask it this way: 4 In 2010 were there only those two occasions where 5 Mr. Brunei was staying at Mr. Epstein's house in 6 Palm Beach? 7 A. Yes, as far as I remember. 8 Q. Okay. How many occasions, in addition to 9 those two, would you estimate that Mr. Brunel has 2 10 stayed at the Palm Beach house since Mr. Epstein has 11 been out on house arrest and also staying at that 12 house? 13 A. It?s hard to tell. I would say maybe three 14 times. 15 Q. Three times in addition to the two times 16 this year, five times total? 2 17 A. No, three times total. 18 Q. Okay. So, one time this month, one time 19 last month, and then for the period of time from i 20 I don't remember when he was on house arrest, maybe 21 July. So from duly to December you think that there 22 was only one other occasion when Mr. Brunei was at 23 the house? i 24 A. You know, it's hard to remember but I think 25 so. He was maybe totally three times for the last few ms; COURT gamma; (551,750'6' Eiectronicaily signed by {napkins (601?051-976?2934) Eiectronically signed by hopkins (601-051 676-2934) Eiectronicaliy signed by hopkins 82d1 DEFENDANT BRADLEYJ EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, 2: al. Case No. 50 2009 CA 040800MMBAG ATTACHMENT 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendants. DEPOSITION OP ADRIANA ROSS Volume 1 of 1 Pages 1 through 138 Videotaped Monday, March 15, 2010 10:13 a.m. 12:42 p.m. U.S. Legal Support 515 East Las Olas Boulevard, 3rd Floor Fort Lauderdale, Florida 33301 Stenographically Reported By: Janet L. McKinney, RPR, FPR, CLR Registered Professional Reporter Florida Professional Reporter Certified LiveNote Reporter U.S. Legal Support (954) 463*2933 3. Videotaped deposition taken before JANET L. ON BEHALF OF I FARMER, tarps, EDWARES, 2 Registered Professronal Reporter, Florida i?iTgi?kfd??xiime 3 Professional Reporter, Certi?ed LiveNote Reporter and smaz a - - - Fm Laaderdale, Roma 333018268 Notary Pubiro In and for the State of Florida at Large 9545242829 5 intheabovecause ESQ 6 (WhereupOn, Witness?s Exhibit 1 was marked for on BEHALF or me DEFENDANT JEFFREY 393mm: 7 Idenn?camn?) BURMAN, 8 VIDEOGRAPHER: We are now on the video record. COLEMAN, LLP . 3f}; Banyan Bouievard 9 Today IS Monday, the clay of March, 2010. The gigm Beach, Haida 3340i 1 0 time is 9:13 am. (sic). We are here at 515 East 561:342-2320 1 1 Las Olas Boulevard, 3rd Floor, Fort Lauderdale, Mpske@bclciaw.com BY: MICHAEL J. PIKE, ESQ. 2 Florida, for the purposo of taking the Videotape on BEHALF oz: omen 2N RELATED CASES: 1 3 dePOSi??m 0f Adriana R035 lake? in case Number MERMELSTEIN 35 HOROWITZ, 4 lane Doe v. Jeffrey Epstein, et a1. 18205 Biscayne Boelevard Suite @218 1 3.. 5 The court reporter is Janet McKinney; the $333233? 33160 1 6 videographer is Sean McGuire, both of U.S. Legai Ssm@sexahuseattomey.com BY 17 suppun' 8 Will counsel and present please introduce ON BEHALF OF THE . 1 9 yourself and the court reporter W111 swear the ROBBINS, TUNKEY, ROSS, AMSEL, - RABEN WAXMAN, RA. 2 0 Wlmess' ifsgistmihwest Third Avenue 2 1 MR. EDWARDS: Brad Edwards. I represent the GUI Miami, Florida 33129 2 2 piaintiff, Eane Doe also "Jane Doe"; EW, LM, 395.858.9558 2 3 Criminalawyer@aol.com BY: ALAN 5- R035, 539- 24 MR. Stuart Merinelstein. I Also Present: Sean McGuire, Vldeographer U.S. Legal Support 2 5 represent Jane Doe Numbers 2 through 8. 3 5 1 MR. 131KB: Michael Pike on behalf of Jeffrey 2 Epmehi ADRIANA ROSS Page 3 MR. ROSS: And good morning, my name is Aian . . 4 Ross. 1 represent the witness, Adriana Ross. D?rect Exam}?at}?? 33? Edwards 7 5 THE REPORTER: Would you raise your right Cross-Exammation By Mr. Memeistein lli 6 hand i Redirect Examination By Mr. Edwards 127 7 385 Ramos-Examination By Mr. Marnieistein l33 DO you soiemly swear or af?m the testimony 8 you're about to give will be the truth, and nothing Certi?cate of Oath I 37 9 but the truth, so heip you God? Certi?cate of Reporter 138 0 THE WITNESS: I do. 3. 3. MR. ROSS: Before the deposition begins and in I I 12 an effort to streamiine the process of getting . 3 through this deposition on behalf of the witness we Desmpm?? Page 3. 4 have had marked as Wimess Exhibit Number 1 an 1 Jane Doe I 02 V. jeffwy Epstein 33 3.5 August 31, 2007 letter rom the {halted States 0 p} ai 3. 6 Attorney?s Office addressed to Miss Ross through ZAWZG Teiephone messages 62 1 7 her then counsel, Bruce Lyons, which is called a 3 Handwritten notes 72 8 target letter identifying her as a target of a 2H Telephone message 87 1 9 fedora} Grand Jury investigation in the Southern 4 Gawker.eom photo with story 127 2 0 District of Florida and outlining a number of 2 offenses that were the subject matter of WHNE 2 2 investigation. SS 2 3 As a result of that, it is anticipated that No. Descriptlon i?age 2 4 some of the questions that may be asked clurmg the 2 5 course of this deposition she may invoke her Fifth 1 Target letter 4 2 (Pages 2 to 5) U.S. Legal Support (954) 463?2933 6 8 1 Amendment privilege against self~incrimination 1 Q. And who are you married to? 2 And in order to streamline this we've agreed prior 2 A. Duncan Ross. 3 to beginning this that she will simply answer "i 3 Q. All right. And sometime after 2803 if I 4 refuse to answer. The parties will understand and 4 understand you correctly you kept the name Mucinska 5 the record will re?ect that she is invoking her 5 until you were able to formally change it to Ross? 6 Fifth Amendment privilege against 6 A. Correct. 7" self?incrimination. 7 Q. Okay. Were you married in this country? 8 If there is some other privilege, 8 A. Correct. 9 attorney-cheat privilege or some other objection 9 Q. When did you come to the United States? 1 0 that i may have to a question, I'll speci?cally 1 0 A. Fall of 2002. I do not recall exact month. 1 1 state it. But her answer refuse to answer" will 1 1 Q. And why? 12 be on Fifth Amendment grounds if that?s acceptable 1 2 A. I was invited by modeling agency on a business 1 3 to everyone. 1 3 visa. 1 4 MR. EDWARDS: It?s acceptable. 14 Q. What modeling agency? 1 5 MR. MBRMELSTEIN: It's acceptable. 15 A. Elite Models. 1 6 MR. PIKE: Acceptable. 3? 6 Q. And who was the connection at Elite Models 1 7 MR. ROSS: Okay. Madam court reporter has 1 7 that invited you? 3. 8 already marked the exhibit, and Fit leave that 8 A. Actually it was my husbandwith her. 1 9 Europe and at the time he he knew that agency and I 2 0 MR. EDWARDS: Okay. 2 0 was modeling in Europe and he showed my pictures and 2 1 2 1 they invited me. 22 22 Q. How long have you been modeling? 2 3 2 3 A. Since about i was i6 years old. 2 4 2 4 Q. Since 16, so mid-98's? Late 90?s? 2 5 2 5 A. Probably around ?98, '99, I believe. 7 9 THEREUPON: 1 Q. Okay. And what agencies did you model for in 2 ADRIANA ROSS 2 Europe? I 3 3 4 and testified as follows: 4 that eventually change the name to and 8 Models. 1 5 DIRECT EXAMINATION 5 was also represented by Ricardo Guy in Milan. Then on 6 BY MR. EDWARDS: 6 my second trip to Milan an agency called Women. 7 Q. Can you tell us your full - full name. 7 i was then represented in Japan by agent: -- 8 A. Adriana Ross. 8 oh, that's you just mean Europe or 9 Q. At some point in time you were known as 9 Q. Well, you can continue. 1 0 Adriana Mucinska; is that correct? 1 A. Yeah. I was represented in Japan by agency 1 1 A. Correct. 1 1 Zucca. i was in South Korea, I do not recall the name 12 Q. And when did that change? 1 2 of the agency. I was represented in Taiwan by Fashion 1 3 A. Well, I got married and initially i stayed 1 3 Management. 1 4 with my name and then because immigration kind of 1 4 Q. Okay. And these were all agencies that you 1 5 made a mistake of not changing my name when I ?rst 1 5 worked for or worked with prior to coming to the United2 1 6 came to this country. And at some point when I was 1 5 States? 1 "i removing my conditional residency i made sure that this 1 7 A. Not all of them. Some citizen: I worked 8 mistake is contacted. I do not recall exact time when 1 8 already been United States and traveling. 3. 9 that happened. 1 9 Q. Okay. But sometime around 2002 you were 2 Q. When were you married? 20 invited by Elite Models to come to the United States to 2 3. A. July 12th, 2003. 2 1 model? 22 Q. Okay. What's your date of birth? 22 A. Correct. 2 3 A. 7 of October 1983. 23 Q. And at the time well, where are you from? 2 4 Q. 10/7233? 24 A. I'm Poiish. 2 5 A. Yes. 25 Q. Okay. So at the time you were a Polish 3 (Pages 6 to 9) U.S. Legal Support (954) 463-2933 10 12 1 citizen? 3. A. Since fall 2008. 2 A. Yes. 2 Q. And when do you expect to graduate? 3 Q. So in order to come to the United States you 3 A. Fall 2010- 4 needed to get a work visa? 4 Q. Are you a full?time student or pa rt~time? 5 A. I was invited actuallyjust to kind ?ail?time student at this time. 6 feeling if I will be suitable. So I came on a business 6 Q. When you first arrived in Miami, Florida in ?l tourist visa which is, believe, 81132. 7 fall of 2092 did you decide during that two weeks that 8 Q. Okay. And where did you first go when you 8 you were going to stay permanently? 9 came to the United States, what stateFlorida. to Q. Okay. Did you go back to I?oland? 11 Q. And what city in Florida? 1 A. Yes, I have. lhave I went back for 12 A. Miami. 12 Christmas. 13 Q. And what did you do {or your two weeks when 1 3 Q. Okay. Poor question. Going back to 2002 I'm 14 you first arrived in Miami, Florida? 14 trying to just understand how it was that -- you came 1 A. I do not recall. 3. 5 over here on a two?week business visa, but eventually 6 Q. Okay. But did you do any modeling? 3. 6 you ended up staying for a longer period of time, 3. "l A. Well, like i would see sorne photographers, the 1 7 correct? 18 agency would send me like on all calls to see 3. 8 A. Right. 1 9 photographers to kind of introduce me as a model. 1 9 Q. Okay. And how did that come about, just tell 2 Q. And why did you make the decision to go with 20 me? 2 1 Elite Models in the United States when you already were 21 A. Well, i got romantically involved with my 2 2 modeling in 2 2 current husband and so when you know, we just 2 3 A. Urn-hum. 2 3 started dating, we got engaged, and that's how, you 2 4 Q. -- Europe? 2 4 know, our relation evolved evolved, and eventually, 2 5 A. Well, you know, just to expand it was 2 5 you know, I got married and and stayed. ll 13 3. something that I did. And i decided to take a year off 3. Q. Okay. And since coming to the United States 2 after i graduated lion} high school and you know, 2 have you always lived in Miami, Florida? 3 just to expand the modeling the modeling 3 A. No. . Al possibilities, Opportunities. 4 Q. All right. Where else have you lived in the 5 Q. Where did you graduate from high school? 5 United States? 6 A. In Warsaw, Poland. 6 A. New York. 7 Q. What year? 7 Q. Where in New York? 8 A. 2002, I believe. 8 A. Manhattan. 9 Q. And do you have any college? Have you gone to 9 Q. What was the address in Manhattan where you 1 0 college after that? 3. lived? 1 3. A. I have an associate degree from Miami Dade 3.3. MR. ROSS: i'm going to advise you to invoke l. 2 College Miami Dade College, and I?m pursuing a 12 privilege. l. 3 bachelor degree right now. 13 A. I refuse to answer. 14 Q. When did you get your associate?s degree from 3.4 Q. Okay. Have you -- are you familiar with an 15 Miami Bade? 15 address at 381 East 66th Street in New York? 1 6 A. 2008. Summer of 2008. 3. 6 A. I refuse to answer. 17 Q. And you're pursuing a bachelor?s degree right 17 MR. PIKE: May we take a break for a second? 1 8 now? 1 8 May I speak with you? 19 A. Yes. 19 MR. ROSS: Sure. 20 Q. From where? 20 VIDEOGRAPHER: Off the record, 10:22 am. 2 1 A. Florida International University. 2 1 (Recess taken at 10:22 am.) 2 2 Q. in what? 2 2 (Deposition resumed at l0:23 am.) 2 3 A. Accounting. 2 3 VIDBOGRAPHER: On the record, 10:23 am. 2 4 Q. How long have you been in the accounting 24 MR. ROSS: Brad, let mejust interrupt for a 2 5 program? 2 5 moment. 4 {Pages 10 to 13) U.S. Legal Support (954) 463*2933 14 16 1 MR. EDWARDS: No probieru. A. I?m sorry, I don?t understand your question. 2 MR. ROSS: Just to be sure, when the witness 2 Q. ?ow long did you iive attire 1040 South Shore 3 answers "i refuse to answer? to be clear the foil 3 Drive address that you moved intoin the fail in 2802? 4 statement that she's not saying for the sake of LI A. Well, since since I came i iived there, I 5 saving time is that she's invoking her Fifth 5 aiways stayed there whether being in Miami traveiing 6 Amendment right against seif-incrimination. Just 6 back and forth, and I live currently at this address. 7 to be clear. 7 Q. Okay. What was the first time that you moved 8 MR. EDWARDS: That?s what i?ve understood all 8 from that address to iive eisewhere? 9 along. 9 A. Ido not recaii. 3.0 MR. MERMELSTEIN: That?s what i understood. 3.0 Q. Okay. i know that you toid me you lived in 21 MR. ROSS: Okay, free. Go ahead. 1 3. New York City and we? re not going to discuss - I?m 1 2 MR. EDWARDS: This is just for the sake of 2 assuming you' re not going to answer a lot of questions 13 brevity 13 about New York City, but at what time period did you 1 4 MR. ROSS: Exactly. 4 move there? Was it right after you got here two weeks, 1 5 MR. EDWARDS: and iet?s move it on. 1 5 a year tater? I'm just trying to get a year as to when 3. 6 BY MR. EDWARDS: 3.6 you moved to New York? Q. Ail right. So I?m going to ask the question 1? MR. ROSS: i?m going to instruct you not to 8 again, I don't remember whether you'd responded yet, 1 8 answer. 1 9 but are you familiar with the address in Manhattan 19 A. i refuse to answer. 20 361 East 66th Street in New York? 20 Q. Okay. Do you know a guy by the name of Jean 2 1 A. i refuse to answer. - 2 Luc Brunei? 2 2 Q. Okay. How 'ioug did you iive in weil, what 2 2 A. I refuse to answer. 23 the ?rst-.addgess that you tired in in Miami? 23 Q. Where are your parents? 24 A. 1040 :Si'ioie Drive,'IMiarni Beach, Florida 2 4 A. They?re in Warsaw, Poland. 25 1040 South Shore Drive, Miami Beach, Florida. 2 5 Q. And since you?ve been in the United States 15 17 1 Q. South Shore. Okay. 1 have they come to the United States? 2 A. Um?hum. 2 A. Yes, they have visited me. 3 - Q. Have you ever had your deposition taker: 3 Q. Rave they ever met Jeffrey Epstein? 4 before? 4 A. I refuse to answerHave they ever met Jean Lac Brunei? 6 Q. Okay. You?re doing very wet] so far. There's 6 A. I refuse to answer. a couple rates I didn?t expiain but maioiy because 7 Q. Where are you currentiy employed? 8 you're doing very weil. I just have to wait for you to 8 A. I pursue I go to schooi fun-time, I do not 9 ?nish your answer; you have to wait for me to finish 9 work. 10 my question. We have one court reporterAre you also stilt in the modeling business 3.3. take down one of us. Give us an answer that we ali 1 though? 1 2 understand. Nodding of the head or shaking the head 3. 2 A. No, i'm not. 13 are easy to do and I get what you're saying, but she 13 Q. And when was the last time you did any 14 doesn't. Air?ha or tin-ah are things that are commonly 1 4 modeling? 3. 5 said. They look the same on paper. 3. 5 A. it would be late spring, early summer of 2006 3. 6 If I ask a bad question which couid happen, as 1 6 I went on a trip to Taiwan. 17 already happened and probany will again, just tell me 17 Q. And why did you stop modeiing at that time? 1 8 don?t understand the question," ask it again - 1 8 A. I wanted 1 aiways kind of know that it's 1 9 A. Okay. 1 9 something that i'm going to be doing and {just decided 2 0 Q. - all right? 2 to go and pursue a college degree. 2 3. And I'm assuming that?s the address, 1048 2 1 Q. Okay. Is it something that you ever pian to 22 South Shore Drive, where you began iiving in fall of 2 2 go back to, modeiing? 2 3 2002Correct. 2 4 Q. Are you invoived at all with the modeling 2 5 Q. How long did you iive at that address? 2 5 industry? 5 (Pages 14 to 17) U.S. Legal Support (954) 463*2933 come about that you 2 Q. I mean, helping to recruit models, heiping 2 began working with Jeffrey Epstein? 3 others to recruit modeis, anything tike that? 3 MR. PIKE: Farm. 4 A. No. 4 A. refuse to answer. 5 Q. Do you ever do you currently tail: to 5 Q. What did Jeffrey Epstein pay you in salary? 6 Mr. Brunei? 6 MR. PIKE: Form. 7 A. i refuse to answer. A. i refuse to answer. 8 Q. When is the last time that you talked to 8 Q. What was the time period that you worked for 9 Jeffrey Epstein? 9 him? 1 A. I refuse to answer. 1 0 A. I refuse to answer. 13 Q. Do you know a woman by the name of Ghislaine 3.3. Q. Why did you stop working for him? 12 Maxwell? 3.2 MR. HKE: Form. 33 A. i refuse to answer. 3.3 A. Irefuse to answer. 14 Q. Do you know someone by the name of Sarah 14 Q. What initialiy were you hired to do? 1 5 Kelien? 5 A. I refuse to answer. 1 6 A. I refuse to answer. 1 6 MR. PIKE: Form. 17 Q. Do you know a person named Nadia Marcinkova? Q. Has Jeffrey Epstein ever paid you to stay 18 A. I refuse to answer. 1 8 quiet or keep quiet about what went on in his house? 19 Q. Did Jeffrey Epstein have anything to do with 3.9 MR. PIKE: Form. 2 0 you moving to New York City? 2 0 A. I refuse to answer. 2 3 A. ire?zse to answer. 2 3. Q. Have you talked to Sarah Kelien or Nadia 22 Q. Did you ever live in a place in New York City 22 Marcinkova about the things that went on in Jeffrey 1/2 3 owned or eontrolied by Jeffrey Epstein? 2 3 Epstein's house? 2 a A. I refuse to answer. I 2 4 MR. PIKE: Form. 2 5 Q. Are you famitiar with the modeling agency MC 2 5 A. {refuse to answer. 19 21 3. Squared? 1 Q. Did you sign a con?dentiality agreement with 2 A. i refuse to answer. 2 Jeffrey Epstein? 3 Q. Do you know of underage females being 3 A. I refuse to answer. 4 transported into this country to work for the modeling 61 MR. Form. 5 agency MC Squared? 5 Q. Did that con?dentiality agreement outline 6 A. I re?ise to answer. 6 what you should say to authorities should he be caught 7 Q. Do you know of those underage females being 7 with underage females? 8 given work visas and staying at the 301 East 66th 8 MR. Form. 9 Street address? - 9 A. I re?zse to answer. 10 A. I refuse to answer. 1 0 Q. Is there another book or manual or written 1 1 Q. Can you say whether you have observed 1 3. memorialization of what you, as an employee of Jeffrey 12 Mr. Brunei or Mr. Epstein engaging in sex with underage 12 Epstein, should do if confronted by law enforcement? 13 females? 13 MR. PIKE: Form. 3. 4 A. I refuse to answer. 3. 4 A. I refuse to answer. 15 Q. Do you know where Mr. Brunei lives? 3. 5 Q. Are you invoking your Fifth Amendment right 16 A. i refuse to answer. 1 6 because you beiieve you eouid be prosecuted? 3.7 Q. Is it true that Mr. ?ru nei stays in the 301 17 MR. ROSS: Invoke. 3. 8 East 66th address frequentiy with underage femaies? 8 A. i refuse to answer. 3. 9 A. I refuse to answer. 3. 9 Q. Are you also invoking because you're seared to 20 Q. At what point were you hired to work for 2 0 testify against Jeffrey Epstein? 2 1 Mr. Epstein? 2 3. MR. PIKE: Form. 2 2 MR. MEGS: Form. 2 2 A. I refuse to answer. 2 3 MR. EDWARDS: You can answer the 2 3 Q. When did you ?rst team that Jeffrey Epstein 2 4 question. Mr. i?ike is making a legai objection. 24 had a sexual obsession for underage femaies? 2 5 A. i refuse to answer. 2 5 A. i refuse to answer. 6 (Pages 18 to 23} U.S. Legal Support (954) 463*2933 2 2 2 4 1 MR. PIKE: Form. 3. different than they are here, but are you familiar with 2 Q. Isn't it true that you have seen Jeffrey 2 the Florida Statutes that protect children against 3 Epstein sexually interacting with females as young as 3 sexual offenders or sexual predators? 4 12 years old? 4 MR. ROSS: Invoke. 5 A. [refuse to answer. 5 A. {refuse to answer. 6 MR. PEKE: Form. 6 Q. Let me just read you the lewd or lascivious 7 Q. is it true that you have observed Jeffrey 7 molestation statute and then i'm going to ask you some 8 Epstein?s sexual obsession to include the age range 12 8 questions about it. 9 to 17? 9 It says: person who intentionally touches 10 MR. PIKE: Form. 10 in a lewd or laseivious manner the breasts, genitals, 1 1 A. refuse to answer. 1 genital area or buttocks or the clothing covering them 12 Q. Have you ever had sex with Jeffrey Epstein? 12 of a person less than 16 years of age or forces or 3. 3 A. refuse to answer. 1 3 entices a person under 16 years of age to so touch the 1 4 MR. Form. 14 perpetrator, commits lewd or lascivioas molestation, a 15 Q. ?ave you ever been paid for sex with Jeffrey 15 second degree felony." 1 6 Epstein? 1 6 After hearing that statute isn't that MR. PIKE: Form. 17 something - isn't that a crime that you know 3.8 A. I refuse to answer. 18 Mr. Epstein to have committed on an everyday basis 3. 9 Q. Do you know if Nadia Marcinkova had sex with 1 9 while you were working for him? 2 0 Jeffrey Epstein when she was underage? 2 0 MR. PIKE: Form. 2 3. MR. iiorm. 2 1 A. i refuse to answer. 22 A. Irefuse to answer. 22 Q. And that?s a statute that he violated with 23 Q. What have yon been told about Jeffrey 23 more than 100 underage females; is that true? 2 4 Epstein?s sexual obsession with underage minor 2 4 MR. PIKE: Form. 2 5 children? 2 5 A. i refuse to answer. 2 3 2 5 1 MR. PIKE: Form. 1 Q. When did you become aware that Mr. Epstein was: 2 A. i refuse to answer. 2 a child molester? 3 Q. Isn't it true that Jeffrey Epstein interacted 3 MR. PIKE: Fonn. 4 sexually with underage minors on an everyday basis? 4 A. i refuse to answer. I 5 MR. PZKB: Form. 5 Q. Have you ever seen him with a female under the 6 A. I refuse to answerAnd most of the time Mr. Epstein would 7 MR. PIKE: Form. 8 interact with underage minors at least two times a day; 8 A. I refuse to answer. 9 is that true? 9 Q. Have you ever known Jeffrey Epstein to have 3.0 MR. PIKE: Form. 10 sex with an adult? 1 A. refuse to answer. 11 MR. PIKE: Form. 12 Q. Can you explain to the jury how Mr. Epstein 12 A. itefuse to answer. 13 would access new underage minor females for sex every 3.3 Q. Does he is he sexually attracted to adults? 1 4 day? 1 4 MR. PIKE: Form. 1 5 MR. PIKE: Form. 3. 5 A. I refuse to answer. 3. 6 A. i refuse to answer. 3. 6 Q. When was the first time you learned of 1 7 Q. How many assistants did Jeffrey Epstein hire 3.7 Mr. Epstein getting a massage from an underage minor 1 8 to bring him underage minor females for sex? 1 8 female? 1 9 A. i refuse to answer. 1 9 MR. PIKE: Form. 20 MR. Form. 2 0 A. i refuse to answer. 2 3. Q. Were you one of those assistants that helped 2 1 Q. i realize some of these questions may sound 2 2 to bring him underage minor females? 2 2 repetitive but during this case we've learned of key 2 3 MR. PIKE: Form. 2 3 terms that different people on Mr. Epstein's let?s say 2 4 A. Ire?zse to answer. 2 4 payroll or inner circle recognize or talk about. So 25 Q. I know that the laws in Poland are probably 25 when I talk about "massages", do you know what that 7 {Pages 22 to 25) U.S. Legal Support (954) 463-2933 2 6 2 8 1 term means? 1 Q. Is there a book or manual or is it written 2 MR. PIKE: Form. 2 anywhere that the -- that sex with underage minors is 3 A. I refuse to answer. 3 to be referred to as a "massage"? 4 Q. isn't "massage" the word that was told by 4 A. refuse to answer. 5 Jeffrey Epstein to all of his employees to refer to 5 MR. PIKE: Form. 6 whatever acts he engages in with underage females in 6 Q. Were there ever team meetings, for lack of a 7 his bedroom? 7 better word, where Jeffrey Epstein and possibly 8 MR. PIKE: Form. 8 Ghislaine Maxwell, Sarah Kellen, yoursolf, would talk 9 A. I refuse to answer. 9 about this organization of obtaining underage girls for 1 0 Q. At this point - were you -- were you ever in 3. 0 Jeffrey Epstein for sex? 11 the bedroom with him when he was engaging in sexual 1 1 MR. Form. 12 acts with underage females and calling them "massages"? 2 A. I refuse to answer. 13 MR. PIKE: Form. 1 3 Q. What methods does Jeffrey Epstein use to gain 1 4 A. I refuse to answer. 1 4 access to underage minor females for sex? 3.5 Q. Did you ever participate in any of the sexual 15 MR. PIKE: Form. 1 6 acts that Jeffrey Epstein was having with underage 1 6 A. refuse to answer. 1 7 females? 1 7 Q. What is your understanding of Jeffrey 3. 8 MR. PIKE: Form. 1 8 Epstein's involvement with the modeling industry? 1 9 A. I refuse to answer. 2 9 MR. PIKE: Form. 28 Q. Now, just so that the record is clear there is 20 A. I refuse to answer. 2 1 not a single piece of evidence that ever indicates that 2 1 Q. gave you ever modeled for MC Squared? 2 2 you were involved with underage females, I'm not even 2 2 MR. PIKE: Form. 2 3 implying that and I realize that you invoking it may 2 3 A. i refuse to answer. 2 4 may give the wrong light and that?s not -- that's not 2 4 Q. Has Jeffrey Epstein ever promised you anything 2 5 my intention, so but were you ever aware of Nadia 2 5 related to a modeling career? 2 7 2 9 1 Mareinkova participating in sex with underageferuales? 1 MR. PIKE: Form. 2 A. I refuse to answer. 2 A. I refuse to answer. 3 Q. Have you read the poliee?eports related to 3 Q. Have you ever talked to Jean Luc Bro nel about 4 the criminal investigation into Mr. Epstein? 4 modeling? 5 A. Irefuse to answer. 5 A. lrefose to answer. 6 Q. And you?re aware of this 87-page police report 6 Q. Have you ever talked to Jean Luc Brunei about 7 that details numerous females that indicate that they 7 his desire to have sex with underage females? 8 were involved sexually with Mr. Epstein when they were 8 A. I refuso to answer. 9 minors? 9 Q. Isn't it true that Jean Loo Brunet has been in 3.0 A. I refuse to answer. 18 trouble for years for having sex with underage minors 1 MR. PIKE: Form. 1 1 in Europe? 1 2 Q. Did anyone instruct you to use the code word 12 A. I refuse to answer. 13 "massage"? 13 Q. Are you familiar with The McIntyre Reports? 3. 4 A. I refuse to answer. 3. 4 A. i refuse to answer. 15 Q. And when referring to these underage minor 3.5 Q. Okay. Are you familiar with reports done on 1 6 females that would come over to Mr. Epstein?s house did 1 6 modeling agencies back in the 80?s and 90?s related to 17 anybody also tell you to use the term "work"? 17 agency owners having sex with underage minors? 1 8 A. I refuse to answer. 3. 8 MR. ROSS: Answer the question. 1 9 MR. PIKE: Form. 3. 9 A. No, I'm not. 2 0 Q. Meaning when somebody would call to schedule 20 Q. Okay. Did you ever hear of Jean Luc Brunel?s 2 1 one of these underage females for a massage isn?t it 2 3. reputation for having sex with underage girls? 2 2 true that they would say "it's time to come to work" 2 2 MR. ROSS: Invoke. 23 and schedule a specific appointment? 23 A. refuse to answer. 2 4 MR. PIKE: Form. 24 Q. Do you know how Jean Lac Brunei knows Jeffrey 2 5 A. I refuse to answer. 2 5 Epstein? 8 {Pages 26 to 29) U.S. Legal Support (954) 463*2933 30 32 A. I refuse to answer. 1 investigation into Jeffrey Epstein? 2 MR. PIKE: Penn. 2 A. Irefuse to answer. 3 Q. isn?t their connection the obsession for 3 MR. PIKE: Form. 4 underage minor females? 4 MR. ROSS: In addition, attorney?client 5 MR. PIKE: Form. 5 privilege. 6 A. i refuse to answer. 6 Q. And I certainly would ?u do not want to know 7 Q. Based on your observations of Jeffrey Epstein "3 anything you talked to your attorney about, I 8 would you categorize his obsession for underage minor 8 apologize. - 9 females as an addiction? 9 A. (Neda) 10 MR. PIKE: Form. 10 Q. Why was it that you were named as a 3. 3. A. I refuse to answer. 1 1 co~conspirator of Jeffrey Epstein?s in the 1 2 Q. Isn't it true that Ghislaine Maxwell delivers 2 non-prosecution agreement? 3.3 underage minor females to Jeffrey Epstein? 13 MR. Form. 3.4 MR. FIKE: Form. 1 4 A. i refuse to answer. 15 A. I refuse to answer. 15 Q. Do you feel like a victim of Jeffrey 1 6 Q. Have you ever had a sexual relationship with 6 Epstein's? 1 7 Ghislaine Maxwell? 1 7 MR. PIKE: 01m. 3. 8 A. lre?lse to answer. 3. 8 A. I refuse to answer. 1 9 Q. Do you know what Ghislaine Maxwell does in 3.9 Q. Do you feel like Jeffrey Epstein brainwashed 2 0 general for Jeffrey Epstein? 2 0 you to some extent? 23. MR. PIKE: Form. 21 MR. PEKE: Form. 2 2 A. i refuse to answer. 2 2 A. I refuse to answer. 2 3 Q. Have you seen photographs of underage minor 23 Q. Do you feel any remorse for any role that you 2 4 females in Jeffrey Epstein?s patrol control or 2 4 may have played in having underage minor females at 2 5 possession? 2 5 Jeffrey Epstein's house for him to molest them? 3 1 3 3 1 MR. PIKE: Form. 1 MR. PIKE: Form. 2 A. refuse to answer. 2 A. I refuse to answer. 3 Q. Were there surveillance cameras, hidden 3 Q. Have you known Ghislaiue Maxwell and Jeffrey 4 surveillance cameras inside Jeffrey Epstein's home? 4 Epstein to keep sex slaves? 5 MR. Form. 5 A. I refuse to answer. 6 A. I re?ise to answer. 6 Q. Do you know somebody named Virginia Roberts? 7 Q. Did those surveillance cameras capture "1 A. refuse to answer. 8 underage minor females naked? 8 Q. Have you met Virginia Roberts? 9 MR. PIKE: Form. 9 A. I refuse to answer. 1 A. i refuse to answer. 1 0 MR. EDWARDS: All right. Let me go ahead and 3. Q. And didn't Jeffrey Epstein and Ghislaine 3.1 mark as -- as Plaintiffs Exhibit 1 a lawsuit that 3. 2 Maxwell watch those surreptitiously obtained videos of 3. 2 was filed by Bob osefsberg on behalf of Jane Bee 1 3 underage minor females? 3. 3 102 v. Jeffrey Epstein just for the purposes of 1 4 MR. Form. 3. 4 asking the witness some questions. 1 5 A. I refuse to answer. 3. 5 MR. ROSS: l've seen it. 1 6 Q. And those videos and photographs of underage 1 6 (Whereupon, Plaintiffs Exhibit 1 was marked 17 minor females were saved on Jeffrey Epsteio's computers 17 for identi?cation.) 38 in his house, right? 18 Q. ?ave you ever read the lawsuit Jane Doe 182 v. 1 9 MR. PIKE: Form. 19 Jeffrey Epstein? 20 A. i refuse to answer. 2 0 A. I refuse to answer. 2 1 Q. Have you seen those photographs and videos on 2 1 Q. in the lawsuit it indicates the plaintiff was 22 Jeffrey Epstein?s computers? 22 15 years old when Ghislaine Maxwell and Jeffrey Epstein 2 3 MR. PIKE: Form. 23 had a threesome with this underage minor female. Are 2 4 A. refuse to answer. 24 you aware of that? 2 5 Q. Who have you talked to related to the criminal 25 MR. PEKE: Form. 9 (Pages 30 to 33) U.S. Legal Support (954) 463?2933 3 4 3 6 A. {refuse to answer. 1 Q. Jane Doe 182 ultimately escaped from him and 2 Q. And Jeffrey Epstein anchor Ghislaine Maxweli 2 ieft to Australia, is that your understanding? 3 obtained and purchased passports for 15-year~old Jane 3 A. i refuse to answer. 4 Doe 102 to transport her to Paint Beach, New York City, 4 MR. PIKE: Form. 5 Santa Fe, Los Angeles, San Francisco, St. Louis, as 5 Q. Have you ever spoken with Jane Doe 182? 6 weil as Europe, the Caribbean, and Africa; are you 6 A. i refuse to answer. 7 aware of that? 7 Q. On one of Epstein's birthdays a friend of 8 A. i refuse to answer. 8 Jeffrey Epstein sent to hint 12 three 12uyear-oid 9 MR. PIKE: Form. 9 giris from France who spoke no English for Epstein to 10 Q. It?s also alleged that Jeffrey Epstein in 10 sexaaiiy exploit and abuse and after doing so he sent 11 addition to molesting Jane Doe 102 along with Ghisiaine 3.3. them back to France the next day. Are you familiar 12 Maxweli forced her to have sex with other modeis, 12 with that? I 13 actresses, and celebrities? 13 MR. PIKE: Form. 1 A. I refuse to answer. 3. 4 A. I refuse to answer. 15 MR. PIKE: Forrn. 3.5 Q. isn?t that something that is fairly common for 3. 6 Q. It also indicates that Jeffrey Epstein 3.6 Mr. Epstein? 17 transported other minor giris from Turkey, the Czech 17 A. i refuse to answer. 18 Repubiie, Asia, and other countries. Are you aware of 18 MR. Form. 19 that? 19 Q. Who are the friends that send to Jeffrey 2 0 MR. PIKE: Form. 2 0 Epstein underage minor females for his birthday so that 2 3. A. i refuse to answer. 2 it he can abuse? 2 2 Q. Is Jeffrey Epstein involved in the 2 2 A. I refuse to answer. 2 3 international child sex trade? 2 3 MR. Form. 2 4 MR. Form. 24 Q. Is one of those friends Jean Luc Brunei? 2 5 A. lrefuse to answer. 2 5 A. I refuse to answerJean Luc Brunei his partner in that 1 Q. Have you ever met Prince Andrew? 2 international chiid sex trade? 2 A. I re?zse to answer. 3 MR. PIKE: Form. 3 Q. fins Prince Andrew been involved with underage 4 A. i refuse to answer. 4 minor females to your knowledge? 5 Q. Are you aware that after -- that Jeffrey A. i re?lse to answer. 6 Epstein forced Jane Doe 102 to have sex with other 6 Q. Have you ever met Alan Dershowitz? 7 aduit male peers including royalty, politicians, A. I refuse to answer. 8 academicians, businessmen andlor other professional and 8 Q. When Atari Dershowitz stays at Jeffrey 9 personal acquaintances of Jeffrey Epstein's? 9 Epstein?s house isu?t it true that he has been at the 10 MR. 91KB: Form. 10 house when underage minor females have been in the 1 1 A. i refuse to answer. 1 1 bedroom with Jeffrey Epstein? 1 2 Q. Is that something that he did with giris other 1 2 A. i refuse to answer. 13 than Jane Dec 162? 1 3 Q. Has - are you familiar with the media 1 4 MR. Form. 3. 4 publication or oniine resource RadarOniine? 1 5 A. irefuse to answer. 1 5 A. I refuse to answer. 3. 6 Q. Aren't you familiar with Jeffrey Epstein?s 1 6 Q. is that something that you assisted practice of pimping out underage minor females to other 17 Mr. Epstein with when he purchased RadarQniine? 8 people that have the same sexual obsession with 1 8 A. i refuse to answer. 1 9 underage minors? 1 9 Q. And do you know his business partner in that 20 MR. PIKE: Form. 20 endeavor? 2 A. I refuse to answer. 2 A. i refuse to answer. 2 2 Q. And doesn?t he bene?t ?nanciain from that. 22 Q. Isn't it also true that he used RadarOniine as 2 3 sex trade? 2 3 another way to gain access to underage minor femaies 2 4 MR. PIKE: Penn. 2 4 for sex? 25 A. i refuso to answer. 25 MR. PIKE: Form. 10 (Pages 34 to 37) U.S. Legal Support (954) 463*2933 38 40 1 A. refuse to answer. 3. Is Sarah Kellen somebody who travels with 2 Q. Have you been to all of Jeffrey Epstein's 2 Jeffrey Epstein? 3 properties? 3 MR. PIKE: Form. 4 MR. FIKE: Form. 4 A. refuse to answer. 5 A. refuse to answer. 5 Q. And when Jeffrey Epstein is coming to town 6 Q. Certainly you?ve been to the property at 358 6 doesn't he call Sarah Kellen, his number one assistant? 7 El Britlo Way, correct? 7 MR. PIKE: Form. 8 MR. PIKE: Form. 8 A. I refuse to answer. 9 A. I refuse to answer. 9 Q. And at some point in time, it looks like in 0 Q. Have you been to his property in Manhattan? 10 early 2805 or late 2084, you were also an assistant of 1 A. re?rse to answer. 1 1 Jeffrey Epstein's, correct? 12 MR. PIKE: Form. 3.2 MR. l?lKE: Form. 13 Q. And have you been to his island in -- it was 13 A. Ire?lse to answer. 1 4 Little St. James, i believe lie calls it Little 14 Q. And how was it that you transitioned from 15 St. Jeff's now? 15 being involved in modeling to being an employee of 6 MR. l?lKE: Form. 3. 6 Jeffrey Epstein? 1 7 A. I refuse to answer. MR. Form. 1 8 Q. And have you witnessed underage child sex 18 A. I refuso to answer. 3. 9 orgies on that island? 19 Q. Other than arranging for underage minor 2 0 MR. Form. 20 females to come to Jeffrey Epstein's house did you do 2 1 A. I refuse to answer. 2 1 anything else for Jeffrey Epstein? 2 2 Q. Do you know a female named Jeletzia? 22 MR. FIKE: Form. 2 3 A. re?ise to answer. 2 3 A. I refuse to answer. 2 4 Q. Do you know where Jeletzla lives these days? 24 Q. Did you ever fly on Jeffrey Epstein?s 2 5 A. I refuse to answer. 2 5 airplane? 39 41 1 Q. What is your understanding of Sarah Kellen's A. I re?tse to answer. 2 role in Jeffrey Epstein's life? 2 Q. Did you witness Jeffrey Epstein abuse 3 A. Irefuse to answer. 3 sexually abusing underage minor females on his 4 MR. PIKE: Form. 4 airplane? 5 Q. Isn't it true that she gets paid just to bring 5 MR. PIKE: Form. 6 him underage minor females for sex? 6 A. I refuse to answer. 7 MR. MKE: Form. 7 Q. Did you know that it was illegal for Jeffrey A. refuse to answer. 8 Epstein to interact sexually with underage minor 9 Q. And additionally, she schedules the 9 females? 10 appointments for underage minor females for him to 10 MR. l?lKE: Form. 1 1 molest? 1 1 A. refuse to answer. 12 A. refuse to answer. 12 Q. Did you ever object to Jeffrey Epstein 13 MR. PKE: Form. 13 interacting sexually with underage minor females? 14 Q. You know Dana Burns? 14 MR. FIKB: Form. 1 5 A. refuse to answer. 1 5 A. re?ne to answer. i 6 Q. Does she still work for Ghislaine Maxwell? 1 6 Q. Would Jeffrey Epstein get angry refuse to answer. 3.7 did not have an appointment set for him with underage minor child victim of 8 underage minor female? 1 9 Jeffrey Epstein's? 1 9 MR. PIKE: Form. 20 A. refuse to answer. 20 A. I refuse to answer. 21 Q. Through discovery we've talked to numerous 21 Q. Has Jeffrey Epstein contacted you in the last 22 witnessos about, you know, Jeffrey Epstein and people 22 year? 2 3 that work for him. I don?t know if you'll be able to 2 3 A. refuse to answer. 2 4 answer any of these questions but l'll ask them anyway 2 4 MR. PIKE: Form. 25 one at a time. 2 5 Q. ?as Sarah Kellen contacted you within the last 11 (Pages 38 to 41) U.S. Legal Support (954) 463~2933 42 44 3. year? 3. A. 1 refuse to answer. 2 A. I re?jse to answer. 2 MR. ROSS: Form. 3 Q. Has anybody that is associated with Jeffrey 3 Q. Are you aware of Jeffrey Epstein's for lack of 4 Epstein?s party contacted you in the last yea r? 4 a better word "ritual" with these underage minor 5 MR. Form. 5 females in his bedroom? 6 A. Ire-fuse to answer. 6 MR. PIKE: Form. 7 Q. By that i mean to include Ghislaine Maxweh, 7 A. I refuse to answer. 8 Lesley Groff, any of these people, have they contacted 8 Q. Wouldn't it generally begin with Jeffrey 9 you within the last year? 9 Epstein placing a call to Sarah Kellen or yourself and 10 MR. PIKE: Form. 10 toiling you that he's going to he in town at the Palm l. 1 A. i refuse to answer. 3. 1 Beach mansion? 12 Q. Are you familiar with the names of some of the 12 MR. Fem. 3 underage minor females? 3.3 A. refuse to answer. 1 4 A. I refuse to answer. 1 4 Q. And then isn't there a list of underage minor 3.5 Q. Are you familiar with 15 females stored in the computer system? 16 A. I refuse to answer. 1 6 MR. PIKE: Form. 3. 7 Q. Do you remember what LM looked like? 1 7 A. refuse to answer. 3. 8 A. I refuse to answer. 1 8 Q. And that computer system is interconnected 3. 9 Q. Are you familiar with 1 9 from his New York home. his New Mexico home, his 2 A. I refuse to answer. 2 0 island, his home in France, and West Palm Beach; is 2 i Q. Do you remember what EW looked like? 2 1 that correct? 22 A. I refuse to answer. 22 MR. PIKE: Feral. 23 Q. Are you familiar with Jane Doc? 2 3 A. i refuse to answer. 24 A. refuse to answer. 2 4 Q. And have you seen that list of underage minor 25 Q. "these are 311 females that were underage minor 2 5 females stored in the computer system? 43 45 3. females that Jeffrey Epstein interacted with sexually 1 MR. Form. 2 during a time when you were working for him; isn't that 2 A. I refuse to answer. 3 true? 3 Q. And isn't it true there are over a thousand 4 A. lrcfuse to answer. 4 girls at any given time between the age range of 12 and 5 MR. PIKE: Form. 5 17 all of which have been molested by Jeffrey Epstein? 6 Q. And LM was somebody that went over to Jeffrey 6 MR. PIKE: Form. 7 Epstein's house and was molested at a young age by him 7 A. I refuse to answer. 8 more than 108 times; is that true? 8 Q. And when Mr. Epstein would eat! and tell you 9 MR. PIKE: Form. 9 the time that he was going to he in town it would then 10 A. I rc?ise to answer. 10 be your job to get an underage minor female was also somebody who went over to 3. 1 house and set a specific appointment for that person; 12 Jeffrey Epstein's house when she was between 14 and 3.2 is that correct? 13 16 years old more than a hundred times; isu't that 13 MR. PIKE: Form. 1 4 true? 1 4 A. refuse to answer. 1 5 MR. PIKE: Form. 3.5 Q. And he would tell you the exact time of day 1 6 A. I refuse to answer. 3. 6 that he wanted his two or three appointments to molest Q. And Jane Doe was somebody that went to Jeffrey 3. 7 underage minor females? 18 Epstein?s house more than 15 times to be molested by 1 8 MR. PIKE: Form. 1 9 Jeffrey Epstein when she was 14 and 15 years old; is 1 9 A. Ire?xse to answer. 2 0 that true? 2 0 Q. And you would go into the computer system and 2 1 MR. PIKE: Form. 21 call the person that he told you he wanted to see for 2 2 A. {refuse to answer. 22 that day; is that correct? 2 3 Q. is it also true that LM brought to Jeffrey 2 3 MR. Form. 2 4 Epstein's house between 58 and 75 other underage minor 24 A. i refuse to answer. 2 5 females for Jeffrey Epstein to molest? 25 Q. And that may be Brittany or Tatum or Courtney 12 (Pages 42 to 45} U.S. Legal Support (954) 463*2933 4 6 4 8 1 or somebody local that you would call on the telephone 1 in time Jeffrey Epstein showed you exactly what he does 2 and tell them to come work at a speci?c time? 2 with each of these girls in the bedroom, correct? 3 MR. REE: Form. 3 MR. PIKE: Form. 4 A. I refuse to answer. 4 A. I refuse to answer. 5 Q. And didn't Mr. Epstein tell you that the way 5 Q. So after about he would order the underage 6 you need to tell these girls is that they are working 6 minor female to begin massaging him, correct? 7? so that they do not feel that they have the option to 7 MR. MKS: Form. 8 decline? 8 A. [refuse to answer. 9 MR. PIKE: Form. 9 Q. And then he would rollover and begin to 10 A. refuse to answer. 10 masturbate with his right hand, correct? 11 Q. I mean, the of it all was explained 3.1 A. i refuse to answer. 12 in detail by Jeffrey Epstein; isn't that correct? 12 Q. And then he would begin also grabbing the 13 MR. Form. 33 breasts, buttocks, and vagina area of these underage 1 4 A. I refuse to answer. 1 ?1 minor females, correct? 15 Q. And once the girls were inside the bedroom 15 A. I refuse to answer. 1 6 Jeffrey Epstein said that he can take care of the rest, 16 MR. PIKE: Penn. 1 3? correct? 1 7? Q. And his ritual was so specific that with each 18 MR. FIKE: Form. 18 of them he would demand that they pinch his nipples 1 9 A. I refuse to answer. 1 9 very hard, right? 2 Q. And the underage minor female would show up at 20 MR. PIKE: Form. 2 1 the house and be greeted at the door by either 2 3. A. refuse to answer. 22 yourself, the house manager, or Sarah Kellen, correct? 22 Q. That's a fetish that you know that Jeffrey 23 MR. PIKE: Form. 23 Epstein has, right, he likes his nipples pinched very 2 4 A. i re?ise to answer. 2 4. hard? 2 5 Q. Many of these underage minor females including 2 5 MR. Formthree clients, LM, EW, and Jane Doe you met 1 A. refuse to answer. 2 personally, right? 2 Q. And as he's masturbating with one hand and has 3 A. lrethse to answer. 3 his other hand groping or inserting his ?ngers into 4 MR. PIKE: Form. 4 the underage miner's vagina he?s also telling them to 5 Q. And then you would lead them upstairs to his 5 pinch his nipples, correct? 6 bedroom and leave him alone in the bedroom, leave my 6 MR. PIKE: Form. 7 client alone in the bedroom? 7 A. I refuse to answer. 8 MR. PIKE: Form. 8 Q. And this continues and sometimes this 9 A. refuse to answer. 9 escalates to him using vibrators, correct? 10 Q. And let?s take LM, and she went there many 10 MR. PZKE: Form. 1 3. times between the ages of 13 and 16. If she was taken 3. 1 A. I refuse to answer. 12 up to his bedroom she would be left alone in the 12 Q. And have you seen vibrators in the Palm Beach 1 3 bedroom until Jeffrey Epstein arrived, correct? 1 3 mansion house? 14 MR. PIKE: 270ml. 14 MR. PIKE: Form. 1 5 A- i refuse to answer. 1 5 A. i refuse to answer. 1 6 Q. And Jeffrey Epstein would appear usually naked 1 6 Q. And other times he orders Nadia Marcinkova to 1 7 and order for her to take her clothes off? 1 participate in these encounters with underage minor 1 8 A. I refuse to answer. 3. 8 females; is that correct? 1 9 MR. PIKE: Form. 1 9 A. I refuse to answer. 2 Q. And then Mr. Epstein would lay face down on 2 0 Q. Are you familiar with Nadia Marcinkova 21 the massage table would usually be the next step, 2 3. strapping on dildos to have sex with these underage 2 2 correct? 2 2 minor females? 23 MR. PIKE: Form. 23 MR. Form. 2 4 A. i refuse to answer. 2 4 A. lrefuse to answer. 2 5 Q. And you know this ritual because at some point 25 Q. And when Miss Marcinkova would have sex witl1 13 (Pages 46 to 49) U.S. Legal Support (954) 463*2933 50 52 3. the underage minor females Jeffrey Epstein would watch 1 A. I refuse to answer. 2 and continue to ejac - continne to masturbate, 2 Q. Do you know what Jeffrey Epstein does for a 3 correct? 3 living? 4 MR. PIKE: Form. 4 A. i refuse to answer. 5 A. re?lse to answer. 5 Q. Does he do anything aside from interacting 6 Q. Has he ever asked yon to participate in these 6 sexually with underage minor females? 7 threesomes with underage minor females? 7 MR. Form. 8 A. [refuse to answer. 8 A. [refuse to answer. 9 MR. i?iKE: Form. 9 Q. Do you know how it is that he made his money 10 Q. Have you ever participated in sex with 18 where he is purported to be a billionaire? 3. underage minor females at the direction of Jeffrey 1 A. refuse to answer. 12 Epstein? 12 MR. Form. 13 MR. PIKE: Form. 33 Q. Do you know David Copper?eld? 1 4 A. I refuse to answer. 3 4 A. I refuse to answer. 15 Q. The this whole experience that i am 15 Q. Is David Copper?eld somebody that would come 3. 6 explaining right now is identical every single time 1 6 into town and interact sexually with underage minor 1 7 with these underage minor females; isn't that your 1 7? females? 3. 8 understanding? 1 8 A. refuse to answer. 3. 9 MR. PIKE: Form. 1 9 Q. Do you know Martin Nowak? 2 {3 A. I refuse to answer. 2 A. i refuse to answer. Q. And this whole experience is what he has 2 1 Q. Is that also somebody that would interact 2 2 taught you and the other employees to call a "massage", 2 2 sexually with underage minor females? 2 3 correct? 2 3 A. I refuse to answer. 24 MR. PIKE: Form. 2 4 Q. Do you know Leslie Werner? 2 5 A, refuse to answer. 2 5 A. I refuse to answeralways ends with him ejaculating? 1 Q. is that somebody you've met before? 2 A. i refuse to answer. 2 A. i refuse to answer. 3 MR. PIKE: Form. 3 Q. Kas Mr. Epstein himself interacted sexually 4 Q. And then he offers 280 to $300 cash to the 4 with Leslie Wexner? 5 underage minor female, correct? 5 MR. PIKE: Form. 6 MR. PIKE: Form. 6 A. I refuse to answer. 7 A. refuse to answer. 7 Q. When Mr. Epstein was being investigated 8 Q. And then he also gives them another another 8 criminally how did you first learn about that? 9 option to make money which is each time you come to my 9 A. i refuse to answer. 3.0 house and we engage in this sexual interaction I will 10 Q. At some point in time he was tipped off that 1 give you $289, but each i?ernale you bring me like you. 3. 3. his home - tltat a search warrant was going to be 12 between the age range of 12 and 16, i will pay you $200 12 executed on his home, correct? 3. 3 per person. 3. 3 MR. PIKE: Form. 1 4 MR. PIKE: Form. 3. 4 A. i refuse to answer. 15 Q. is that something you're familiar with? 35 Q. And just a month before the execution of that 16 A. i refuse to answer. 1 6 search warrant -- less than a month before the 17 Q. And LM at that offer was one of the girls who execution of that search warrant he ordered you to do 3.8 brought him 75 pins underage minor females, correct? 18 something with certain evidence, didn?t he? 3.9 MR. PIKE: Form. 19 MEL PIKE: Form. 2 A. I refuse to answer. 2 A. refuse to answer. 2 3. Q. And so he's basically created a pyramid of 2 1 Q. In fact, there were at least three very key 2 2 underage minor females where the computer system has a 2 2 computers that contained a lot of the information that 2 3 thousand of these females ready to come over to work 2 3 I've been asking you about. You?re familiar with those 2 4 for him? 24 computers that were in his house, correct? 25 MR. Form. 25 MR. PIKE: Form. 14 (Pages 50 to 53} U.S. Legal Support (954) 463~2933 54 56 A. I refuse to anewer. 1 search warrant was imminent? 2 Q. And he ordered you to come over and take those 2 A. i refuse to answer. 3 computers out of his house, correct? 3 Q. Did you ever question when you were directed 4 A. i refuse to answer. ?1 to take these computers from his home? 5 MR. PIKE: Form. 5 A. i refuse to answer. 6 Q. And you couid basically take the local 6 Q. How much additionai money or bonus were you 7 database that exposed this crimiuai enterprise that 7 paid to take the computers that we?re talking about out 8 I've been talking about dealing with sex with underage 8 of Jeffrey Epstein's house? 9 minor vehicies -- underage minor females and you could 9 MR. PIKE: Form. 1 0 take the evidence from his home, correct? 1 0 A- Ire?ise to answer. 3. 1 MR. PIKE: Form. 13. Q. Wouid those computers reveai criminal activity 3.2 A. I refuse to answer. 12 of oniy Jeffrey Epstein or of others? 13 Q. And you?ve seen the material that?s on those 13 MR. PIKE: Form. 1 4 computers, correct? 1 4 A. {refuse to answer. 15 MR. PIKE: Form. 15 Q. Did you talk with Sarah Kellen about the 16 A. refuse to answer. 1 6 crimiuai investigation into Jeffrey Epstein and others? 1 7 Q. And if! were to look at those computers it 1 "i A. i refuse to answer. 18 would dispiay cxactiy what i?ve been describing to you 18 Q. Well, at some point in time what?s been marked 19 today, right? 3. 9 as Defense Exhibit 1, you received a Grand Jury 20 MR. PIKE: Form. 2 investigation target letter, correct? 2 1 A. i refuse to answer. 2 1 A. Ire?ise to answer. 22 Q. And you went to his house with a male, 22 Q. Welt, we have it right here. i'm 23 correct? 2 3 with it. I know you got the {otter and i know that, 2 4 A. I refuse to answer. 2 4 you know, the substance of it you?re not going to teli 2 5 MR. PIKE: Form. 2 5 me about. But this fetter is dated August 2097, 55 57 1 Q. There was one other guy with you that heiped 1 the search warrant was executed on his home back in 2 that assisted you to take these computers from his 2 October of 2085. So during those two years leading up 3 home; is that right? 3 to this target letter who did you talk to? 4 MR. PIKE: Form. 4 A. I refuse to answer. 5 A. I refuse to answerWhere did you take those? 6 MR. ROSS: And priviiege. Attorney?client "i A. irefese to answer. priviiege. 8 Q. Did you take those was it Biil Reitly that 8 Q. Okay. In addition to your attorney did you 9 went to the home? 9 talk to anybody eise about the criminal investigation? 10 A. I refuse to answer. 1 0 A. I refuse to answer. 11 Q. Do you know who Bill Reiin is? 1 Q. And Bruce Lyons was your initial computer 12 A. I refuse to answer. 1 2 computer was your initial attorney in this case, 13 Q. He?s one of the investigators hired by Roy 13 correct? 1 4 Black to represent Jeffrey Epstein? 1 4 MR. ROSS: You can answer yes or no. 1 5 A. i refuse to answer. 1 5 A. Yes. 3.6 Q. Did you take those computers ever to your 3.6 Q. Okay. And that was an attorney that was hired i7 house? 1 7 for you by Jeffrey Epstein? 1 8 A. I refuse to answer. 1 8 MR. ROSS: invoice. 19 Q. And i guess the house that I would be talking 19 A. I refuse to answer. 2 0 about is the 1040 South Shore Drive, have those 20 Q. Someone that was paid for by Jeffrey Epstein 2 1 computers ever been to that house? 2 1 to represent you? 22 MR. PIKE: 901111. 22 MR. PEKE: Form. 2 3 A. i refuse to answer. 2 3 A. i refuse to answer. 24 Q. Were you nervous about the fact that you were 24 Q. So once he hired you a criminai attorney then 2 5 taking these computers out of the home at a time when a 2 5 it seemed like you did something wrong? 15 {Pages 54 to U.S. Legal Support (954) 463~2933 58 6O 1 MR. PIKE: Form. 1 credibility? 2 A. I refuse to answer. 2 A. i refuse to answer. 3 Q. You hadn't actualiy gone into any relationship 3 Q. Did he tell you that he could scare them to go 4 with Jeffrey Epstein with the intent to commit crimes, 4 away? 5 did you? 5 A. i refuse to answer. 6 A. i refuse to answer. 6 MR. PIKE: Form and form to the last question. 7 Q. You didn?t know that he was a child molester 7 MR. EDWARDS: Ali right. Let's see, what did 8 when you first met him, did you? 8 I say, i said this was 9 MR. PIKE: Form. 9 MR. ROSS: E. 1 0 A. I refuse to answer. 1 0 MR. EDWARDS: -- Piaintiff's i and we?re going 1 1 Q. Were you impressed by his money and his 3. 3. to write on the back of it and then okay. 1 2 lifestyle? 1 2 Q. Jeffrey Epstein kept message pads near alt of 3.3 A. i refuse to answer. 13 his phones in his home, right? 1 4 Q. Did you think that he could get you further in 14 MR. PIKE: Form. 15 life if you would just listen to what he said? 15 A. Ire?zse to answer. 1 6 MR. Form. 1 6 Q. And those are message pads that have a carbon A. I refuse to answer. copy back side to them, you?re familiar with them? 18 Q. At this point in time you have no contact with 18 MR. Form. 1 9 him as a child molester, do yon? 3.9 A. I re?zse to answer. 20 MR. PIKE: Form. 20 Q. And this is for anybody who takes a message 2 1 A. I refuse to answer. 2 3. they write it down that somebody called, the reason for 2 2 Q. Did Jeffrey Epstein assist in getting you a 22 calling, the time that they called? 2 3 visa? 2 3 MR. PIKE: Form. 2 4 A. I refuse to answer. 2 4 A. i refuse to answer. 25 MR. PIKE: Form. 25 Q. And many a times anytime that Jeffrey Epstein 59 61 1 Q. Has he done any favors for your family? 1 was in town there were at least two scheduled 2 A. I refuse to answer. 2 "massages" for lack of a better word, with Jeffrey 3 MR. PIKE: Form. 3 Epstein and these underage minor females, correct? 4 Q. is he paying for your college? 4 A. refuse to answer. 5 A. refuse to answer. 5 MR. FIKE: Form. 6 MR. PIKE: Form. 6 Q. And do you have the and there was a 7 Q. Right now is he paying for your college? 7 particular schedniing book that contained these 8 MR. ROSS: Invoke. 8 appointments with between Jeffrey Epstein and 9 A. I refuse to answer. 9 underage minor females, correct? 3.0 MR. PIKE: Form. 10 MR. PIKE: Form. 3.1 Q. Did Jeffrey Epstein ever talk to you about the 1 A. i refuse to answer. 12 chances of him going to prison? 12 Q. And it was your primary responsibility to 13 A. i refuse to answer. 1 3 assist Sarah Kellen in setting these appointments up. 1 4 MR. PIKE: Farm. 1 4 right? 15 Q. Did Jeffrey Epstein ever talk to you about 15 A. I refuse to answer. 1 6 what he intended his defenses to be to the criminal 16 MR. 91KB: Form. 17 actions he committed against these underage minors? 17 Q. It took at least two or three fail?time 1 8 A. I refuse to answer. 18 empioyees to keep up with Jeffrey Epstein's addiction 1 9 MR. PIKE: Penn. 3.9 to underage minors, correct? 2 0 Q. Did he tell you that he would spend as much 20 A. I refuse to answer. 2 1 money as possible to intimidate and harass these 21 MR. Form. 22 underage minor victims? 22 Q. Lesley Groff did pretty much the same thing up 2 3 A. i refuse to answer. 2 3 in New York, right? 24 MR. Form. 2 4 MR. PIKE: Form. 25 Q. Did he tell you that he would destroy their 25 A. i refuse to answer. 16 (Pages 58 to 61} U.S. Legal Support (954) 463~2933 62 64 1 Q. And you're familiar that there is this group 1 that he wouid promise these girls something in order to 2 of giris in New York that were summoned to his home for 2 get them to aiiow him to sexualiy abuse them? 3 generaiiy the exact same thing as the Falm Beach giris? 3 MR. PIKE: Form. 4 A. I refuse to answer. 4 A. i refuse to answer. 5 Q. right. 5 Q. Because he certainly did not want them to tell 6 MR. i?iKBz Form. 6 the police, correct? 7 Q. the going to Show you an exhibit here, we?ll 7 A. i refuse to answer. 8 mark it as you know what, it's a bunch of message 8 Q. And did you have many meetings about what to 9 pads, I'm going to mark it as 2A, -D, whatever. 9 do if any of these girls toid the 3.0 So we'll say 2A. 1 A. I refuse to answer. 11 {Whereopom Piaimifi?s Exhibit 2A through 1 1 MR. PIKE: Fem]. 1 2 were marked for identi?cation.) 1 2 Q. Was it aiways known that Jeffrey Epstein would 13 Q. Do you recognize it? 13 hire everyone attorneys and tell everyone just not to 4 A. I refuse to answer. 1 4 taik? 1 5 Q. Okay. 15 MR. PIKE: Form. 1 6 MR. PIKE: May I see that? 16 A. refuse to answer. 17 MR. EDWARDS: Sure. Q. And at the same time then he could employ a 18 Q. Do you recognize the handwriting on it? 1 8 bunch of investigators, dig up a launch of dirt on these 1 9 A. i refuse to answer. 19 girls, and intimidate them and scare them to go away, 20 Q. It indicates "Adriana hasn't confirmed Julie 20 correct? 2 for 11 yet, so she is keeping Brittany on hold in case 2 1 MR. Form. 2 2 aiic doesn?t call back." 2 2 A. I refuse to answer. 2 3 What does that message mean? 2 3 Q. And Jeffrey Epstein doesn't iike he didn't 2 4 A. I refuse to answer. 24 like any of these underage minor females, right? 25 MR. PIKE: Form. 25 MR. PIKE: Form. 63 65 3. Q. Julie?s an underage minor femaie that Jeffrey A. I refuse to answer. 2 Epstein was going to molest at ilz??, correct? 2 Q. In fact, it was the opposite, he liked to hurt 3 MR. PIKE: Form. 3 them; isn't that true? 4 A. Irefuse to answet. 4 MR. PIKE: Form. 5 Q. And if Juiie wasn't availahie then you had 5 A. i refuse to answer. 6 another underage minor female named Brittany that couitl 6 Q. And after they came forward if they toid the ?3 step in her place and fui?ii that role for Jeffrey 7 truth he was dead set on hurting them even more, 8 Epstein, correct? 8 correct? 9 MR. PIKE: Form. 9 MR. PIKE: Form. 1 A. I refuse to answer. 10 A. I refuse to answer. 11 Q. All right. 28 is another message pad and I?m 11 Q. And that's also a feeling that Ghisiaine 12 going to - we?tt stop skipping the process of moving 12 Maxwell shared as well, correct? 13 this on and I?m assuming you're not going to be able to 13 A. I refuse to answer. 1 4 answer as to whether or not you you recognize that 4 Q. And that?s something that she also toid you, 1 5 either, right? 1 5 "Don't worry. If we get caught we have it covered and 1 6 A. i refuse to answer. 1 6 we'll just attack these Iittie giris." 1 7 Q. Okay. This is a message from 914105, so 1 7? MR. PIKE: Form. 1 8 September 4th, 2885, 7:25 pm. saying "Adriana 8 A. i refuse to answer. 1 9 cancelled ulie. She would iike to speak to you I 1 9 Q. right. There?s another message from 20 believe about coliege," and a teiepltooe number. And 20 9110105. "Adriana says Lauren con?rmed for 4 2 1 then a question from you, "Should 1 schedule anyone 2 1 Can you teii us what that message means? 22 else?" What did that message mean? 22 MR. Form. 2 3 MR. PIKE: Form. 2 3 A. I re?ise to answer. 2 4 A. {refuse to answer. 2 4 Q. it?s another underage minor female that 2 5 Q. That another typical pioy of Mr. Epstein?s, 2 5 Jeffrey Epsteih?s going to molest at 4 correct? 17 (Pages 62 to 65) U.S. Legal Support (954) 463~2933 66 68 1 A. lre?xse to answer. 1 for 4:30 2 Q. And when I say "molest", you know, he may say 2 Do you remember leaving that message? 3 "massage", I mean, that's -- that?s something 3 A. irefuse to answer. 4 interehangeahie, right? 4 Q. And this is - 5 MR. PIKE: Form. 5 MR. PIKE: Form. 6 A. {re?lse to answer. 6 Q. It's his typicai sehedaie where he scheduies 7 Q. it's the routine that I described in detail 7 one underage minor female to moiest in the morning and 8 that is identical with every single giri every single 8 one in the afternoon, correct? 9 time, correct? 9 MR. PIKE: Form. 1 0 A. i refuse to answer. 1 0 A. I refuse to answer. 11 Q. And it?s basicain as far as he can get with 1 1 Q. I mean, considering this is - have you ever 1 2 this underage minor female without her crying or 1 2 worked anywhere etse where there is somebody sexu aily 13 screaming or running out of the house? 13 moiesting underage minor females on a daily basis iike 14 MR. PIKE: Penn. 3.4 this? 15 A. I re?ise to answer. 15 MR. PIKE: Form. 1 6 Q. Did you ever see any of the giris cry or 1 6 A. i refuse to answer. 17 scream or ran out of the house? 1? Q. At some point in time did you tell your 1 8 MR. PIKE: Form. 18 parents that this was happening? 1 9 A. i refuse to answer. 1 9 MR. PIKE: Form. 2 0 Q. Did you have a personal reiationship with any 20 A. I refuse to answer. 2 1 of these underage minor females? 2 1 Q. Did you ever talk to anybody else in the house 2 2 A. I refuse to answer. 2 2 and say "Hey, look, this is not right"? 23 Q. There's another message here from 9! 18(85, 23 A. i re?ise to answer. 2 4 same day Eater in the day, 10 pm. saying "Julie wilt 2 4 Q. Do you fee! sorry for these girlsyou want me to cancei Brittany?" 2 5 A. i refuse to answer. 67 69 1 Do you know what that message meansnot remember Ail? 2 MR. PIKE: horn}. 2 A. I refuse to answer. 3 A. ire?ise to answer. 3 Q. Okay. And do you know what happened up in the 4 Q. What is this? 4 bedroom between AH as a minor and Jeffrey Epstein? 5 There's another message from 91mm saying 5 MR. Form. 6 got a car for," and then the name is biotted out. The 6 A irefase to answer. 7 State Attorney's Office blotted the names of minors out 7' Q. Well, this is what she tciis police: "She 8 sometimes in their file. So do you -- do you know 8 arrived at the house, went upstairs to the bedroom. 9 can you tilt in that blank? 9 She advised she immediately removed her eiothing and 1 0 A. i refuse to answer. 10 Nadia Marcinhova and Epstein were already naked in the 3. 1 Q. Do you know if this was the car that he rented 1 1 bedroom. AH explained that Nadia Marcinkova and she 12 for Jane Doc 4? 12 had a sexual encounter that inciuded kissing, touching, 1 3 A. I refuse to answer. 1 3 and oral sex. AH remembered that she ciimaxed and was 1 4 Q. All right. Or the ear that he rented for 14 removing herseif from the massage table. Epstein then 15 A. i refuse to answer. 15 turned AH onto her stomach on the massage tahic and 1 6 MR. PIKE: Form. 1 6 inserted his penis into her vagina. AH stated Epstein 17 Q. You?re familiar with both of those people, 17 began to pump his penis in her vagina. AH became upset 18 right? 18 over this. She said her head was being hefd forcihiy 1 9 A. I refuse to answer. 19 against the bed as he continued to pump inside her. 2 0 Q. In fact, AH was somebody that was over at 2 0 She screamed and Epstein stopped. He would 2 1 Jeffrey Epstein's house many times, correct? 2 normaiiy pay her $280, but for this he apologized and 2 2 A. I re?ise to answer. 2 2 paid her a thousand doiiars for that visit." 2 3 MR. PIKE: Form. 2 3 Are you familiar with that encounter? 2 4 Q. 9.312005. Message from Adriana saying "i ieft 2 4 A. I refuse to answer. 25 message for Ashiey to con?rm for 11 aun. and Vanessa 25 MR. PEKE: Form. 18 (Pages 66 to 69) U.S. Legal Support (954) 463?2933 7O 72 1 Q. Do you remember a time when AH as a A. I refuse to answer. 2 16-year-oid I believe at this time ieft her house - 2 Q. And at that point in time -- weii, are you 3 ieft the house visibly upset? 3 aware of him molesting underage minors while he was a 4 MR. PIKE: Form. 4 teacher there? 5 A. [refuse to answer. 5 A. Irefuse to answer. 6 Q. She advised that she was ripped and torn in 6 Q. There's another note that's not a message pad 7 her vagina area and had difficulty waihing to the ear; 7 which {guess I wilt since it has your name on it I 8 do you remember that? 8 will mark it as what are we on -- 3 -- wait, 9 MR. PEKE: Form. 9 MR. ROSS: 3. 1 0 A. i refuse to answer. 3.0 MR. EDWARDS: i messed up. 11 Q. These message pads were message pads that were 1 1 MR. ROSS: 3. 3.2 taken from trash pulls outside of Jeffrey Epstein?s 3.2 (Whereupon, Plaintiffs Exhibit 3 was marked 1 3 home and for the most weii, there's so many messages 1 3 for identi?cation.) 14 here, but most of them are by somebody other than 14 Q. Look at that white I fix what I've messed up 15 yourself. So my question is who are the other people 15 over here. 1 6 that wouid take messages for Jeffrey Epstein for 1 6 MR. ROSS: 1?rn going to show this to the underage minor females to come to the house? witness. 18 MR. PIKE: Form. 18 MR. EDWARDS: Yes. Yes. 19 A. i refuse to answer. 3.9 Q. Do you recognize that document? 20 Q. And the messages include CL, "Can I come work 20 A. i refuse to answer. 21 today?" 2 1 Q. There are 3 tot of different things on here 22 What does "work" mean? 22 that don't necessarily relate to you. At least I can?t 2 3 A. I refuse to answer. 2 3 tell that they do. But it does indicate "Adriana's 2 4 MR. PIKE: Form. 2 4 parents are going to the embassy on the 23rd." 25 Q. That means come to your house and get paid for 25 Do you remember when that happened? 71 73 1 Jeffrey Epstein sexually molesting this person white 1 A. i refuse to answer. 2 she was underage; is that correct? 2 Q. Why did your parents go to the embassy? 3 A. I refuse to answer. 3 A. Ire?zse to answer. 4 MR. FIKE: Form. 4 Q. More importantiy why was Mr. Epstein concerned 5 Q. And it was aiso pretty frequent that the giris 5 that your parents were going to the Emhassy? 6 would come in tandem, isn't that true, two at a time? 6 MR. PIKE: Form. 7 MR. 131KB: Form. 7 A. {refuse to answer. 8 A. i refuse to answer. 8 Q. Was -- at that point in time was Mr. Epstein 9 Q. And one being the girl that wonid bring the 9 assisting your parents with anything? 10 new girl there. wouid wait downstairs white the new 10 A. I refuse to answer. i 1 girl was upstairs getting moiested but then getting 1 1 Q. Are your parents citizens of the United 1 2 paid? 1 2 States? 13 MR. PIKE: Form. 13 MR. ROSS: Form. 14 A. i refuse to answer. 14 A. lret?nse to answer. 15 Q. How did Jeffrey Epstein explain himseif to you 15 Q. Are youdid this? 3. 6 A. No. 17 MR. PIKE: Form. 17 Q. Has Mr. Epstein ever offered to get you a visa 1 8 A. I refuse to answer. 1 8 for the United States? 1 9 Q. Do you know when it is that he first became 3.9 A. refuse to answer. 2 0 sexually obsessed with underage minor females? 2 0 MR. PIKE: Form. 2 1 MR. PIKE: Asked and answered. 2 1 Q. Do you know Raer Roshan? 2 2 A. I refuse to answer. 2 2 A. i refuse to answer. 2 3 MR. PIKE: Form. 2 3 Q. That was Jeffrey Epstein's partner in 2 4 Q. Did you know that he was a school teacher at 24 RadarOnline, correct? 25 the Dalton Schooi? 25 A. I refuse to answer. 19 (Pages 70 to 73) U.S. Legal Support (954) 463-2933 74 1 Q. And if i showed you every single message pad 3. A. I refuse to answer. 2 here would you be able to answer any of the questions 2 Q. And isn?t it typical for Jeffrey Epstein to 3 about any of the messages that were left at Jeffrey 3 have a sex siave that flies with him an the airplane? 4 Epstein?s house? 4 A. I refuse to answer. 5 A. I refuse to answer. 5 MR. PIKE: Form. 6 MR. EDWARDS: Okay. That saves the quali?cations is that the 7 time. 7 section slave be underage, correct? 8 MR. ROSS: It did. 8 MR. PIKE: Form. 9 Q. Have you ever met Biil Clinton? 9 A. I refuse to answer. 10 A. Itemse to answer. 10 Q. And if the Sex slave is 15 years old isn't it 3.3. Q. Is Bill Clinton was Biil Ciinton a friend 1 1 your understanding and based on your observations that 3.2 of Jeffrey Epstein's? 12 he wiil even make them dress as if theyrefuse to answer. 1 3 MR. PIKE: Form. 1 4 Q. Is Bill Clinton somebody who Jeffrey Epstein 14 A. I refuse to answer. 1 5 has ever procured underage minor females for? 1 5 MR. PIKE: Form. 1 6 A. refuse to answer. 3. 6 Q. Do you know President Andres Pastrana? 17 MR. PIKE: Form. 3.7 A. lrefnse to answer. 1 8 Q. And just -- and just for, you know, the sake 18 Q. Do you know him as somebody who has had sex 3.9 of what the evidence shows, there's no evidence that I 19 with underage minor females brought to him by Jeffrey 2 0 have that indicates that that happened, but if you were 20 Epstein? 23. going to answer that question I?m willing to ask it. 2 3. MR. PIKE: Form. 2 2 Have you met him at Jeffrey Epstein's house in 2 2 A. I refuse to answer. 23 Palm Beach County? 23 Q. Have you ever heard of Ehnd Burak? 2 4 MR. PM: Form. 2 4 A. I refuse to answer. 25 A. {refuse to answer. 25 MR. 91KB: Form. 75 77 1 Q. You have ?own on Jeffrey Epstein's airplanes 1 Q. Is that another person that Epstein -- Jeffrey 2 numerous times, correct? 2 Epstein procures underage minor females for? 3 A. I re?ne to answer. 3 MR. PIKE: Fonn. 4 Q. As weli has Bill Clinton and you?re aware of 4 A. [refuse to answer. 5 that, right? 5 Q. You've met Naomi Campbell I'm assuming? 6 MR. PIKE: Form. 6 A. i refuse to answer. 7 A. refuse to answer. 7 Q. Anytime separate and apart from any dealings 8 Q. Have you ever seen the flight logs from 8 with Jeffrey Epstein have you met her in the modeling 9 Jeffrey Epstein ?s airpianes? 9 industry? That's a modei, right? 1.0 MR. PIKE: Form. 10 MR. PIKE: Form. 1 1 A. refuse to answer. 13. MR. ROSS: You can answer the question. 12 Q. And on many times it is Bill Clinton, Secret 12 A. No, I have not. 3.3 Service agents, Jeffrey Epstein, Ghislaine Maxwell, 1 3 Q. Okay. Do you know Todd Meister? 14 Sarah Kellen, and others. Have you do you know 1 4 A. I refuse to answer. 3. 5 about these flights? 3. 5 Q. Joel Pashcow? 6 A. i refuse to answer. 3.6 A. {refuse to answer. 17 MR. PIKE: Form. 1'7 Q. You've been to their houses? 1 8 Q. And have you ever witnessed sex on any of 18 A. I refuse to answer. 1 9 Jeffrey Epstein's ?ights? 1 9 Q. Do you know Aline Weber? 2 A. I refuse to answer. 2 A. I refuse to answer. 2 1 MR. PIKE: Form. 2 3. Q. Have you ever stayed at the 381 East 66th 22 Q. Do you know Emmy Taylor? 22 Street places with Aline Weber? 2 3 A. refuse to answer. 2 3 MR. Form. 24 Q. is that somebody that is Ghislaine Maxwell's 2 4 A. I refuse to answer. 2 5 sex slave? 25 Q. And typically aren't there at least 16 20 (Pages 74 to 77) U.S. Legal Support (954) 463-2933 78 80 1 underage minor femaies staying at these various 3. MR. PIKE: Form. 2 condominiums located at 391 East 66th Street? 2 Q. And you fiew to his isiand, right? 3 A. irefoseto answer. 3 A. {refuse to answer. ?3 Q. And those femates get work visas to say that 4 MR. PIKE: Form. 5 they're models, but aetnaliy they are prostituted out 5 Q. You flew to New Mexico? 6 by Jeffrey Epstein and John Loo Brunei, correct? 6 A. I refuse to answer. 7 A. i refuse to answer. 7 MR. PIKE: Form. 8 MR. PIKE: Form. 8 Q. You flew to New Jersey? 9 Q. And various businessmen and around 9 MR. PIKE: Form. 1 0 New York and Washington, D.C. go to those apartments 1 A. i refuse to answer. 1 2 frequentty to have sex with underage minors; is that 1 1 Q. Several of the flights are just yourself, 12 true? 3.2 Jeffrey Epstein, and Sarah Kellen. What did you do on: 1 3 A. I refuse to answer. 1 3 those ?ights? 3.4 Q. Do you remember a flight on December 3rd, 2004 3. 4 MR. FIKE: Form. 3.5 that you took with Jeffrey Epstein, Nadia Mareihkova, 15 A. I refuse to answer. i 6 Sarah Kelien, and somebody with initials SH -- 6 Q. Who's Adam Perrylang? A. I refuse to answer. 17 A. I refuse to answer. 18 Q. frorn JFK to 1 8 Q. Is that somebody that you were made to have 1 9 MR. PIKE: Penn. 1 9 sex with? 2 Q. Do you remember that? 20 A. I refuse to answer. 2 3. A. irefase to answer. 2 3. Q. Did Jeffrey Epstein ever make you have sex 22 Q. Who is 22 with any females? 2 3 A. i re?zse to answer. 2 3 MR. PIKE: Fonn. 2 4 Q. Is that an underage minor? 2 4 A. i refuse to answer. 2 5 A. i refuse to answer. 25 Q. Did he ever make you have sex with any you remember a fiight that you took 1 friends? 2 December 27th with Nadia Mareinkova and ?effrey 2 MR. PIKE: Fem. 3 Epstein? 3 A. i refuse to answer. 4 A. ire?ise to answer. 4 Q. Who is Sandy Berger? 5 Q. What airport is this, 5 A. I refuse to answer. 6 A. I refuse to answer. 6 Q. That?s somebody else that was with 7 Q. Do you know Doug Band? 7 Clinton at one point in time, correct? 8 A. I refuse to answer. 8 A. I refuse to answer. 9 Q. Isn?t that liutou?s assistant? 9 Q. A close friend of Jeffrey Epstein's? 10 A. I refuse to answer. 1 0 MR. PIKE: Form. 3. 1 Q. You?ve been on the airpiaue with him before? 13. A. I refuse to answer. 12 A. i refuse to answer. 3.2 Q. He called the house within three weeks of the 13 Q. Have you been on the airplane with 13 search warrant being executed. Did he tip off Jeffrey J. 4 Clinton before? 1 4 Epstein? 3.5 A. I refuse to answer. 315 MR. Form. 1 6 Q. Who is Tatiana? 6 A. I refuse to answer. 17 A. I refuse to answer. 17 Q. Is he somebody that's involved with underage 18 Q. That's somebody you've ?own with on Jeffrey 8 minors? 1 9 Epsteiu's plane on numerous occasions, correct? 1 9 A. i refuse to answer. 20 MR. PIKE: Form. 2 0 Q. Do you know Igor Zinoviev? 2 1 A. i refuse to answer. 2 1 A. i refuse to answer. 22 Q. In fact, do ring the year 2005 you ?ew on 22 Q. Andrea Metrovieh? 23 Jeffrey Epstein's piano wouid you say more than 50 2 3 A. I mothers to answer. 2 4 times? 2.4 Q. Have you ?own on the airplane with Alan 2 5 A. I refuse to answer. 2 5 Dershowitz before? 21 (Pages 78 to 81) U.S. Legal Support (954) 463*2933 82 84 1 MR. PIKE: Form. 1 give you a ticket, correct? 2 A. 1 refuse to answer. 2 MR. PIKE: Fem. 3 Q. And Jean Luc Brunei is somebody who you have 3 A. i refuse to answer. 4 been on the airpiane with several times, correct? 4 Q. Was it ever your job to call the police 5 A. I refuse to answer. 5 department and ask if any poiice reports were on ?le 6 MR. PIKE: Form. 6 or anybody compiained about the activities at Jeffrey 7 Q. Anti when Jean Lac Brunei is on this airpiane 7 Epstein's house? 8 there are underage minor minor femaies on the 8 MR. PIKE: Form. 9 airpiane with you, correct? 9 A. i refuse to answer. 10 MR. PIKE: Form. 1 Q. Have you ever gone physicain to the police 1 1 A. I refizse to answer. 1 1 department? 12 Q. is there a back room to this airplane? Is 12 A. i refuse to answer. 13 there any sort of separation or is it all one big room? 13 Q. Was there a ?ight where you flew aione with 14 MR. PIKE: Form. 14 Jean Lac Brnnel? 1 5 A. {refuse to answer. 1 5 A. i refuse to answer. 1 6 Q. So if Jeffrey Epstein and Jean Lue Brunei are 16 Q. Have you ever ?own on the plane with Prince 17" engaged in sex acts with underage minors did you - Andrew? 1 8 A. I re?zse 1 8 MR. PIKE: Form. 19 Q. Sorry did you observe any of those acts? 1 9 A. I refuse to answer. 2 0 A. I refuse to answer. 2 Q. Do you know Zinta Brankis? 2 1 MR. PIKE: Form. 2 1 A. i re?zse to answer. 22 Q. And on numerous of the ?ights the ?ight iogs 22 Q. That's another mode! that Jeffrey Epstein 2 3 indicate someone?s name then oftentimes initials, but 2 3 knows, correct? 2 4 sometimes it would just say "three femalesrefuse to answer. 2 5 know why? 2 5 MR. FIRE: Form. 83 85 1 A. {refuse to answer. 1 Q. Somebody that he had engaged in sex with when 2 MR. PIKE: Form. 2 she was underage? 3 Q. Who?s Ciairc Hazel? 3 A. I re?zse to answer. 4 A. I refuse to answer. 4 Q. She actaaiiy got a modeiing contract out of 5 Q. Do you know Jo?Jo and 5 it? 6 A. irefuse to answer. 6 MR. PEKE: Form. 7 Q. Thcy' re the house managers up at the mansion 7 A. {refuse to answer. 8 up in Manhattan, correct? 8 Q. Why does Jean Lac Brunei and Jeffrey Epstein 9 MR. PIKE: Form. 9 ?y together so often? 1 0 A. I refuse to answer. 1 0 MR. PEKE: Form. 1 1 Q. Ami they assist Mr. Epstein in engaging in 1 1 A. i refuse to answer. 1 2 underage sex with minors in New York, correct? 1 2 Q. And why does Ghisiaine Maxweii aiso ?y so 3. 3 MR. PIKE: arm. 1 3 often with Jeffrey Epstein and Jean Luc Brunei? 3. 4 A. I refuse to answer. 1 4 A. I refuse to answer. 15 Q. They aiso maintain a pretty close reiationship 15 MR. PEKB: Form. 1 6 with the police? 1 6 Q. Isn't it true that three of them are A. {re?lse to answer. 1 7 obsessed and addicted to sex with underage minors? 18 Q. And that's a big component aiso, right, that 3.8 MR. i?lKE: Form. 1 9 Jeffrey Epstein has is friendly with the law 3. 9 A. Irefuse to answer. 2 0 enforcement, correct? 2 0 MR. PIKE: Brad, how much ionger do you have? 2 1 MR. i?iKE: Form. 2 1 MR. EDWARDS: How long? You want to take a 22 A. i refuse to answer. 2 2 break? 2 3 Q. Like law enforcement wouid do favors for not 2 3 MR. PIKE: Yeah. 2 4 only Jeffrey Epstein but his various assistants. If 2 4 MR. EDWARDS: Sure. It?s going 3 int faster 2 yoo were speeding around the neighborhood they wouidn't 2 5 than I thought it woaid. 22 {Pages 82 to 85) U.S. Legal Support (954) 463?2933 86 88 1 VIDEOGRAPHER: Off the record, ll:33 am. 1 MR. PEKE: Form. 2 (Recess taken at 11:33 am.) 2 A. refuse to answer. 3 (Deposition resumed at 11:43 am.) 3 Q. Can you tell as any of the other folks that 4 VIDBOGRAPHER: On the record, 11:43 am. ?3 Jeffrey Epstein would supply underage minor girls to? 5 BY MR. EDWARDS: 5 MR. PIKE: Form. 6 Q. All right. There?s one more message that! 6 A. refuse to answer. 7 wanted to ask you about. As I mentioned, I'm not going 7 Q. Do you know a man by the name of Glenn Dubin? 8 to go tit rough all of the messages that I have, but 8 A. I refuse to answer. 9 there's one from 9J4l2005, 9:08 am. from Adriana. "is 9 Q. Do you know his wife? 3.0 it okay for Tatum to stop by and drop something?" 10 A. i refuse to answer. 3. 1 A. refuse to answer. 3.1 Q. His wife at some point in time was associated 12 MR. PIKE: Form. 12 with Jeffrey Epstein; is that correct? 1 3 Q. So what were your hours working for Jeffrey 3. 3 A. I refuse to answer. 14 Epstein? 14 Q. And her name?s Eva Donia; is that right? 1 5 A. I refuse to answer. 3. 5 A. irefnse to answer. 16 Q. I mean, some of these messages are 9:00 in the 16 Q. Either way, isn't it true that Jeffrey Epstein 17 morning and others are as late as 8:30 or 9 at night. then started supplying underage females to Glenn Dubin? 3.8 So what were your hours? 18 MR. PZKE: Form. 1 9 A. I refuse to answer. 1 9 A. i refuse to answer. 2 0 Q. Another message from 9M also, some day, 2 0 Q. Do you know Johanna Sjoberg? 2 1 "Ashley," I think, "con?rmed an 11 a.rn., Vanessa is at 21 A. I refuse to answer. 22 4:30 pm." 22 Q. Is that Somebody who also worked for Jeffrey 2 3 MR. MERMELSTEIN: I think that?s one you did. 2 3 Epstein? 2 4 MR. EDWARDS: Oh, yeah? Okay. 2 4 A. I refuse to answer. 2 5 Q. All right. Do you remember that message? 2 5 MR. PIKE: Form. 87 89 A. I refuse to answer. 1 Q. Did Jeffrey Epstein ever get a legitimate 2 MR. EDWARDS: Do you care how I attach it 2 massage from somebody that's a masseuse? 3 since it's 3 MR. PIKE: Form. 4 MR. ROSS: No. 4 A. I refuse to answer. 5 MR. EDWARDS: I?ll attach it as whatever it 5 Q. The underage females that we've talked about 6 is. 6 pa rtieularly, LM, EW, and Jane Doe, those girls were 7 MR. ROSS: 4. 7 not prostitutes, were they? 8 MR. EDWARDS: 2 -- well, I?ll just go 2H since 8 A. {refuse to answer. 9 it's a message. You don?t have a problem with 9 Q. These were just girls who were in 8th, 91:11, 3.0 that? 28? 10 18th grade in high school, right? 1 1 MR. ROSS: Whatever. 1 1 A. refuse to answer. 12 (Whereupon, Plaintiffs Exhibit 2H was marked 3.2 Q. These were girls that you knew had never 13 for identi?cation.) 13 committed prostitution in the past, right? 1 4 Q. Do you still consider Jeffrey Epstein a 1 4 A. I refuse to answer. 15 friend? 15 Q. And that goes for all of these girls on the 1 6 A. refuse to answer. 1 6 phone list of underage minors to call, these were not MR. PIKE: Form. 17 prostitutes, correct? 18 Q. Did you ever think of Jeffrey Epstein as a 18 A. re?ise to answer. 19 friend? 19 Q. You never called a prostitution or escort 20 MR. Form. 20 service for Jeffrey Epstein. did you? 2 1 A. I refuse to answer. 2 1 MR. PIKE: Form. 2 2 Q. Other than the people that I've mentioned 22 A. I re?ase to answer. 23 of you know, l?resident Pastrana and Ehnd Burak and 23 Q. And as well you never called a legitimate 2 4 l?rince Andrew did you meet any other people of royalty 24 massage parlor for Jeffrey Epstein, correct? 2 5 being friends with Jeffrey Epstein? 2 5 A. I refuse to answer. 23 (Pages 86 to 89} U.S. Legal Support (954) 463*2933 9O 92 3. MR. PIKE: Form. 3. Q. Did Ghisiaine Maxwell ever threaten you? 2 Q. He devised this scheme of having underage 2 A. Refuse to answer. 3 minor girls bring him other underage minor girls so 3 Q. How was it decided who would cal: which giri? 4 that he could gain access to his target age group, 12 4 A. i refuse to answer. 5 to 16 years old, correct? 5 Q. And by that, just so it's clear, like i said, 6 A. I refuse to answer. 6 there's going to be many, many, many message pads, i 7 Q. Have you heard Jeffrey Epstein say ?The 7 have not counted them, but 2 tot created by either 8 younger the better?" 8 yourself or someone named Janusz Banaziak or Louella 9 A. I refuse to answer. 9 Rabuyo, Alfredo Rodriguez, Nadia Marcinkova, Sarah 1 0 Q. And did Jeffrey Epstein tell you that it made 19 Kellen, various people that we know to have been 1 3. him happy the younger the girl was? 11 employed at Jeffrey Epstein?s home. And it seems that 1 2 A. lre?lse to answer. 12 on one particuiar day Sarah may eat} several girls, you 1 3 MR. 131KB: Form. 13 may call several girts, Nadia may call several girls. 1 4 Q. The less developed the girl is the more 14 Who is directing which - which ofyou, which of the 15 excited Jeffrey Epstein gets; is that true? 15 assistants is going to call the underage minor to give 1 6 MR. PIKE: Form. 1 6 them an appointment? 1? A. I refuse to answer. 17 A. I refuse to answer. 1 8 Q. Do you ever plan to talk to Jeffrey Epstein in 18 MR. PIKE: Form. 1 9 the future? 19 Q. And what would happen on the occasions where 2 0 A. I refuse to answer. 20 Jeffrey Epstein says he's going to be in town and then 2 3. MR. PIKE: Form. 2 it he's ultimateiy not in town but a giri shows up anyway? 22 Q. Would you ever work for him again? 22 MR. PIKE: Penn. 2 3 A. i refuse to answer. 2 3 A. i refuse to answer. 2 4 Q. Why didn?t you stop working for him sooner? 2 4 Q. Weren?t you just told just to pay her to keep 25 A. refuse to answer. 25 her happy? 91 93 1 MR. 13KB: Form. 1 A. lrefuse to answer. 2 Q. Did you -- welt, you knew that it was itlegal 2 Q. And isn't part of the whoie scheme that these 3 what he was doing at the time you were doing it, 3 girls were typically told ?Don't tell anybody what goes: 4 correct? 4 on inside this house," right? 5 A. Ire?zse to answer. 5 MR. PIKE: Form. 6 Q. Did you know that you were part of a large 6 A. I refuse to answer. 7 child molestation ring? Q. And did Jeffrey Epstein tell yon that because 8 MR. Form. 8 these girls are young and they're poor and they?re 9 A. refuse to answer. 9 underprivileged type girls they?re liker not going to 1 0 Q. Did you ever tell anyone while you were 3.0 say anything anyway? Isn?t that what he told you? 1 3. working for him that you wanted to stop? 1 1 MR. PIKE: Form. 3.2 A. I refuse to answer. 3.2 A. I refuse to answer. 13 MR. PEKE: Form. 13 Q. Did Ghisiaine Maxwell talk to you about that 14 Q. Did you continue working there becauSe you 14 as well? 1 were just scared to stop? 1 5 A. I refuse to answer. 3. 6 A. refuse to answer. 1 6 MR. Form. 1.7 MR. PIKE: Form. 3.7 Q. Have you seen Jeffrey Epstein angry? 3. 8 Q. Were you in fear of what Ghislaine Maxwell or 1 8 A. I refuse to answer. 3. 9 Jeffrey Epstein might do to you if you quit performing 9 Q. isn't it true that he's very nice and engaging 20 your services for his child molestation ring? 20 as long as he gets his way and gets you to cooperate, 2 3. A. I refuse to answer. 2 1 right? 2 2 MR. PIECE: Fonn. 2 2 A. I refuse to answer. 23 Q. Did Jeffrey Epstein ever threaten you? 23 Q. But if he doesn't get his way he gets very, 24 A. i refuse to answer. 2 4 very angry and mad and sea ry; isn't that true? 2 5 MR. PIKE: 01m. 2 5 A. I refuse to answer. 24 (Pages 90 to 93) U.S. Legal Support (954) 463*2933r 94 96 1 Q. Anal you've seen both sides of him, right? 1 A. I refuse to answer. 2 A. i refuse to answer. 2 MR. PIKE: Form. 3 Q. In fact, you know of girls who were 13 years 3 Q. Was it you or Sarah Kellen that took all of 4 old and cooperated with everything he said because they 4 the gifts over to her home? 5 felt they had no choice up in that bedroom, right? 5 MR. PIKE: Form. 6 A. irefuseto answer. 6 A. Irefuse to answer. 7 MR. PIKE: Form. 7 Q. i beiieve it was Sarah Keilen in a did 8 Q. And you also know girls who resisted and were 8 Jeffrey Epstein own a Mercedes? 9 yelled at and toid to grab their money and get out of 9 MR. PIKE: Form. 1 0 there, right? 1 0 A. I refuse to answer. 13. A. I refuse to answer. 11 Q. And do you remember when Sarah Keiien toaded 12 Q. Wouldn?t you agree that that house upstairs 12 up the Mercedes with all the baby gifts and took it to 1 3 can be somewhat confusing in how it's -- how it's [aid 1 3 my client's trailer? 1 4 out? 1 4 A. I refuse to answer. 15 A. I refuse to answer. 15 Q. And that was so that while LM that was to 1 6 Q. in fact, there?s a stairwcil that starts from 1 6 thank her white she was pregnant she continued to bring the kitchen, there's a door and it aimest blends in in 3.7 him 13-, 14-, and 15-year-old girls to moiest, correct? 18 the kitchen with the other closets, correct? 18 MR. PIKE: Feral. 1 9 A. I refuse to answer. 1 9 A. i refuse to answer. 20 MR. 91KB: Form. 20 Q. Because LM would no longer qualify as somebody 2 1 Q. But you open that door and there's a stairway 2 he?d be sexualiy interacting with as she was pregnant, 2 2 that twists it seems to the left and there?s another 2 2 correct? 23 door at the top of that stairway, right? 23 MR. PEKE: Form. 2 4 A. I re?zse to answer. 2 4 I A. i refuse to answer. 25 Q. And then when you exit that stairway you take 25 Q. Because the only real disqualifications for 95 97 1 a right and you head towards a littic hallway that 1 interacting sexualiy with Mr. Epstein are if you have 2 eventually ieads into Mr. Epstein's bedroom, right? 2 tattoos, right? 3 A. I refuse to answer. 3 A. I refuse to answer. 4 Q. And if it?s your first time in that bedroom as 4 Q. if you're African-American or black? 5 a 14-yea r-oitl girl and you don't like what's happened 5 A. refuse to answer. 5 up there would you agree that it?s a tough way to find 6 Q. You've never known him to interact with an 7 your a place to find your way out of? 7 African-American or black girl, have you? 8 MR. PIKE: Form. 8 A. i refuse to answer. 9 A. {refuse to answer. 9 Q. If you've been pregnant? 1 Q. Did Jeffrey -- didn't Jeffrey Epstein tell you 1 0 A. Ire?ise to answer. 1 1 that he would act as a father?type figure to these 3.1 Q. Or if you are pregnant, correct? 1 2 giris? 1 2 A. I refuse to answer. 1 3 A. I refuse to answer. 1 3 Q. But certainly he was not above having a 1 ll MR. PIKE: Form. 1 4 pregnant 16-year-old girl bringing him underage minor 15 Q. And he would propose that what they are doing 15 females, correct? 1 6 for him or with him chpite the law is okay? 1 6 A. {refuse to answer. 1 7 A. i refuse to answer. Q. In fact -- 18 MR. PIKE: Form. 18 MR. P3433: Form. 1 9 Q. And they could continue to make a lot of money 1 9 Q. it was his belief that he was doing her a 2 0 if they would come over and be his sex victims, right? 20 favor in that he was giving her money for providing a 2 1 MR. PIKE: Form. 2 1 service, correct? 22 A. i refuse to answer. 22 MR. PIKE: Penn. 2 3 Q. And you were aware when my client, LM, was 2 3 A. Ire?zse to answer. 24 pregnant at 16 years old that Jeffrey Epstein bought 2 4 Q. Is it Jeffrey Epstein?s belief that he did 2 5 everything on her baby registry, right? 2 5 these girls a favor? 25 (Pages 94 to 97) U.S. Legal Support (954) 463*2933 98 100 1 A. {refuse to answer. 1 A. {refuse to answer. 2 Q. i mean. doesn?t he think that these girls are 2 Q. Do you know how it is that Sarah Keilen met 3 that he ever -- that they ever -- that he ever 3 Jeffrey Epstein? 4 ailowed them out of their traiier and into his mansion, 4 A. i refuse to answer. 5 correct? 5 Q. Do you know Story Cowies? 6 A. [refuse to answer. 6 A. irefuse to answer. 7 MR. Form. 7 Q. You know who Sergio Cordero is? 8 Q. We've defined the molestation statute or at 8 A. I re?ise to answer. 9 least I read it to you earlier and now we've talked 9 Q. Weli, that's somebodywho also assists 10 about this scheme of Jeffrey Epstein gaining access to 10 Mr. Epstein in bringing him underage minor femaies for E1 this number of underage minor females. At the time 11 sex, correct? 12 when you were working for him did you recognize him as 12 A. ire?zse to answer. 1 3 a serial ehiid molester? 1 3 MR. PIKE: Form. 1 4 MR. PIKE: Form. 1 4 Q. And Khalid Monroe, you know who that. is? 1 5 A. i refuse to answer. 1 5 A. I refuse to answer. 1 6 Q. Do you know of anybody that ever worked for 1 6 Q. Also somebody that through MC Squared or some him that quit working for him because of what he was 1 7 affiliation with that modeling agency would help for 18 doing? 18 Jeffrey Epstein to gain access to underage minor 1 9 A. i refuse to answer. 1 9 females for sex, correct? 20 MR. PIKE: Form. 20 MR. PIKE: Form. 2 1 Q. Do you know Michael Friedman? 2 3. A. 1 re?ne to answer. 22 A. refuse to answer. 22 Q. And do you know of trips that Mr. Cordero, 23 Q. is that somebody you ever met there? 2 3 Mr. Brunei, and Mr. Epstein took to Brazil speci?cally 2 4 A. I refuse to answer. 2 4 for the purposes of Mr. Epstein engaging in sex with 2 5 Q. What countries does Jeffrey Epstein typically 2 5 12wyear-old girls? 99 101 1 bring underage minor females from? 1 MR. PIKE: Form. 2 A. I refuse to answer. 2 A. i re?ise to answer. 3 Q. Do you know why he chooses the countries that 3 Q. Are you - you are aware that Jeffrey Epstein I 4 he chooses to import underage minor females from? 4 pied guilty to two felonies reinted to his sexuai 5 A. refuse to answer. 5 interactions, correct? 6 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. Was Nadia - do you know how old Nadia '7 Q. Okay. 8 Marcinkova was when she came to this country? 8 VIDEOGRAPHER: Excuse me, counsel. 9 A. i refuse to answer. 9 MR. ROSS: I object on privilege grounds 10 Q. Have you had conversations with Nadia 1 attorney-cheat priviiege grounds. 11 Ma reinltova about Jeffrey Epstein bringing her to this 1 1 MR. EDWARDS: Okay, ?ne. {was trying to get 1 2 country? 3. 2 into an area we may get answers. 1 3 A. i refuse to answer. 1 3 VIDEOGRAPHER: Could I just get you to put 1 4 Q. She?s been described by some as his 1 4 your phone on the table? I?m starting to get 15 Yugoslavian lesbian sex slave. is that something that 1 interference. 3. 6 is an accurate description based on the observations 1 6 MR. ROSS: The phone? 17 you have? 17 VIDEOGRAPHER: Yes, sir. 18 A. i refuse to answer. 1 8 MR. EDWARDS: You got a secret phone? 1 9 MR. RIKE: Form. 1 9 It's anytime it receives any 2 0 Q. Did you ever engage in any lesbian sex with 20 kind of information. 21 Nadia Mareinkova? 2 1 MR. ROSS: Oh, okay, yeah, it?s 2 2 A. I refuse to answer. 2 2 VIDEOGRAPHER: It's not that it?s ringing. 23 Q. Has Sarah Keiien ever had sex with Jeffrey 2 3 MR. ROSS: Right. it?s not doing it now. 2 4 Epstein? 2 4 VIDEOGRAPHER: i apoiogize for the 2 5 MR. Form. 2 8 interruption. 26 (Pages 98 to 101) U.S. Legal Support (954) 463*2933 102 104 1 Q. All right. I ask you that question because 1 Q. Wouldn?t you iihe to separate yourself being 2 there was also something. caiied a non-prosecuti0n 2 the person that you are from this person who brought 3 agreement. Are you familiar with that document? 3 you into this mess? =1 A. I refuse to answer. 4 MR. PIKE: Form. 5 MR. ROSS: Attomeywclient priviiege. 5 A. [refuse to answer. 6 Q. And that is also a document that inciudetl your 6 Q. is Jeffrey Epstein paying for your attorney 7 name as a co~conspirator; are you familiar with that? 7 now? 8 A. I refuse to answer. 8 MR. PIKE: Form. 9 MR. ROSS: Attorney-client priviiege. 9 A. [refuse to answer. 1 0 Q. And that is because of your involvement with 1 0 MR. ROSS: Well, actuaily you can answer. 1 1 calling on the telephone underage minors to bring them 1 1 A. No, my parents help me. 12 to Jeffrey Epstein?s house, correct? 12 Q. Are you aware of Jeffrey Epstein?s cloSest 1 3 A. I refuse to answer. 1 3 friends now? 1 4 Q. Or for your involvement in scheduiing 3. 4 A. refuse to answer. 15 appointments in Jeffrey Epstein?s appointment hook for 15 MR. PIKE: Form. 1 6 underage minor ?underage minor females to be involved 3. 6 Q. Who are the people that you believe are 1 7 with Jeffrey Epstein sexually, correct? 1 7 Jeffrey Epstein's enemies? 18 MR. PIKE: Form. 3.8 MR. PIKE: Form. 1 9 A. i refuse to answer. 1 9 A. i refuse to answer. 20 Q. It is certainty not because you sought out 20 Q. Dicl you ever find out that Jeffrey Epstein and 23. this ehiid molestation ring in hopes of rising to the 2 1 Ghisiaine Maxweli had been targeting and prcying upon 22 top, correct? 22 underage femaies for sex for more than a decade? 23 MR. PIKE: Form. 23 MR. PIKE: Form. 2 4 A. i re?tse to answer. 2 4 A. i refuse to answer. 25 Q. Didn't you do everything that you did that 2 5 Q. Who is Jeffrey Epstein's girifriend nowanybody couid ever say is illegal at the direction of 1 you know? 2 Jeffrey Epstein? 2 A. I refuse to answer. 3 A. Irefuse to answer. 3 MR. PIKE: Form. 4 Q. And if it wasn't at the direction of Jeffrey 4 Q. Since being on house arrest has Jeffrey Epstein it was at the direction of Ghisiaine Maxwell or 5 Epstein continued to engage in sex with underage minor 6 Sarah Kclien. correct? 6 femaies? 7 MR. PEKE: Form. 7 MR. PIKE: Form. 8 A. i refuse to answer. 8 A. I refuse to answer. 9 Q. I mean, those things were not things that you 9 Q. Knowing that his habit was more than was at 10 would have done but for being under the supervision of 10 toast two underage minor females for sex every singie 1 Jeffrey Epstein; isn't that right? 13. day do you believe that he stopped? 12 MR. 81KB: Form. 12 MR. PIKE: Porn}. 1 3 A. I refuse to answer. 13 A. I refuse to answer. 1 4 Q. And you continued to do these things either 14 Q. isn?t it your belief that he will continue to 3. 5 out of fear or because you were just impressed with 1 5 do that once of these cases are over? 1 6 Jeffrey Epstein's lifestyle? 1 6 A. I refuse to answer. 1? A. Irefnse to answer. 17 MR. PIKE: Form. 18 Q. Aren't you angry for him involving you in this 18 Q. Isn't it true that Jeffrey Epstein believes 19 criminal activity? 1 9 that he is entitled to have sex with whomever he wants 20 A. I refuse to answer. 20 including 13-, 14-year-old giris? 23. MR. Form- 21 MR. Form. 22 Q. Do you ever intend in the future to talk about 22 A. i refuse to answer. 2 3 what he did and what he involved you in? 2 3 Q. Do you know whether he continues do you 2 4 MR. PIKE: Form. 2 4 know whether he intends to continue to moicst underage 25 A. I reque to answer. 2 5 minors within the United States? 27 (9ages 102 to 105) U.S. Legal Support (954) 463~2933 106 3.08 3. MR. Form. 1 Epstein out of the trouble that he would have been in 2 A. I refuse to answer. 2 related to his sexual interactions with minor females? 3 Q. Do you know Mike Sanka? 3 A. Irefuse to answer. 4 A. I refuse to answer. 4 MR. Fonn. 5 Q. That's sornebody else that assisted Jeffrey Q. Ditl Jeffrey Epstein tell you that you need to 6 Epstein in gaining access to underage minor females 6 cooperate if you want the protection that me and my 7 that were foreigners, correct? '7 connections can give you for this activity? 8 A. I refuse to answer. 8 MR. 81KB: Form. 9 MR. PIKE: Form. 9 A. Irefuse to answer. 10 Q. He?s also involved in the modeling agency, 10 Q. You admit that you called LM on the telephone 1 1 too, correct? 1 1 for her to come to Jeffrey Epstein?s house to be 3. 2 MR. PIKE: Form. 1 2 molested by Jeffrey Epstein when she was an underage 3. 3 A. I refuse to answer. 1 3 female? 2 4 Q. That's a friend of or former friend of Jean 14 A. refuse to answer. 3. 5 Lot: Brunel's? 3. 5 MR. PIKE: Form. Asked and answered twice. 1 6 A. I refuse to answer. 1 6 Q. Do you agree that you called EW on the 3.7 Q. tlow many times has Jean Lue Brunei shown up at 17 telephone for the purposes of her coming to Jeffrey 1 8 Jeffrey Epstein's house with underage minor females? 1 8 Epstein's house for him to sexually molest her? 1 9 MR. PIKE: Form. 1 9 MR. PIKE: Same objection. 2 0 A. refuse to answer. 2 0 A. I refuse to answer. 21 Q. And when that would happen isn?t it true that 2 3. Q. And do you agree that you called Jane Doe and 2 2 they would have orgies with these underage minor 2 2 told her to come to your house to work, meaning for 2 3 females? 2 3 Jeffrey Epstein to sexually molest her? 2 4 MR. PIKE: Form. 2 4 MR. PIKE: Asked and answered. 2 5 A. I refuse to answer. 2 5 A. refuse to answerWhat was done or let me ask it a different 1 Q. The ?rst trial that is set in these cases is 2 way. Strike that. 2 in July of this year. Do you intend to he in the local 3 Where is the scheduling book for the massage 3 area? 4 appointments for Jeffrey Epstein? 4 MR. ROSS: You can answer. 5 MR. PIKE: Form. 5 A. Yes. 6 A. i refuse to answer. 6 Q. Okay. And what address will you be at? 7 Q. Is that something else that was removed from MR. ROSS: You can answer. 8 the home prior to the search warrant being executed? 8 A. 1040 South Shore Drive. 9 A. Irefuse to answer. 9 Q. That's Miami? 10 MR. PIKE: Form. 3. A. Miami Beach, Florida. 3. 3. Q. Do you know how it is that well, did 1 3. Q. And the 2311? is? 1 2 Jeffrey Epstein ever tell you that because of the 1 2 A. 33141. 13 people he knew he would not he going to prison for the 3.3 Q. And I presume that if I needed to ?nd you or 14 crimes that he committed? 3. 4 locate you or anything else I could go through your 3.5 A. I refuse to answer. 15 attorney? 3.6 MR. PIKE: Form. 3.6 A. Yes. 17 Q. And is it your understanding that Ken Starr Q. Okay. Who do you live at that address with? 1 8 had played a major role in devising the non~proseeution 1 8 MR. ROSS: You can answer. 1 9 agreement or having the government agree not to 1 9 A. With my husband and my mom-in-law and his 2 0 prosecute Jeffrey Epstein for his crimes against 2 sister as well. 2 1 minors? 2 3. Q. And your husband's name is Duncan? 2 2 A. I refuse to answer. 2 2 A. Duncan Ross. 23 MR. 211415: Form. 2 3 Q. And your name? 2 4 Q. Is it also your understanding that Bill 2 4 A. Monica Ross. 25 Clinton played somewhat of a role in helping Jeffrey 25 Q. And who else lives at the house with you, I?m 28 (Pages 106 to 109} U.S. Legal Support (954) 463~2933 110 3.12 3. sorry? 1 in Europe, correct? 2 A. His sister. 2 A. Conect. 3 Q. And her name is? 3 Q. And did he have a different employment or 4 A. Steila Erin Ross. 4 profession then? 5 Q. And have you toid Monica or Stella your 5 A. Yes. 6 involvement. with Jeffrey Epstein? 6 Q. What was he doing then? ?i A. i refuse to answer. 7 A. Well, at that time he was serving in the 8 Q. Have you told your parents? 8 entertainment business. He was Dling and yeah. 9 A. I refuse to answer. 9 When met him he came to Europe for a DJ event. DJing 10 Q. Are your parents in the country now? 3.0 event. 1 1 MR. ROSS: You can answer. 11 Q. And where was that in Europewent to Spain and then i was in Monaco at 13 Q. Do they have plans to come back? 13 the time and he knew the people that I was there with 3.4 MR. ROSS: You can answer. 14 and we were nitroduced. That?s where we met. 3.5 A. They may visit, I?m not surehave connections to modeling permanent basis they're in ?oland? 3. 6 United States? A. Yes. 17 A. Yes. 3.8 Q. Okay. What's the address where they are have those connections? 3. 9 Poland? 1 9 A. l'in you know, I'm not sure. I don't know 2 A. Kuznicy Kollatajowskia 33, Warsaw, Poland. 2 0 at this time, but he knew agencies here and lie was 2 1 Q. She's great. I?m sure she got that. 2: doing, I believe, some photographic work as well 22' A. Would you like me to spell it out? 2 2 himself. 2 3 second wordprofessional 2 4 Warsaw, Poland 02495. 24 photograph photographer? 2 5 MR. EDWARDS: One way to never find a witness 2 5 A. Yes. You may say so, yes. 111 113 CE. is just move to Poland. There's no way. 1 Q. And a scientist as well? 2 MR. ROSS: Couldn't get anyone to type the 2 A. Yes. 3 subpoenawork for particular modeling 4 MR. EDWARDS: Right, exactly. Ali right. 4 agencies in the United States? 5 don?t have any other questions for you. Thank you. 5 A. I mean, do you i don?t understand your 6 THE Thank you. 6 question. Do you mean like 7 CROSSAEXAMENATION 7 Q. Welt, did he perform work or services for 8 BY MR. 8 particniar modeling agencies in the United States? 9 Q. Okay. Mrs. Ross, I have some qaestions for 9 A. Well, I believe he would hire models from 10 you. Your husband, Duncan Ross, what does he do for a 3.0 modeling agencies, yes. 1 1 living? 1 1 Q. He would hire models? 12 A. He?s a student. 12 A. Yes, for you know, thatAnd what is he a PM). in? 1 3 works. You hire a model from a modeling agency for a 3.4 A. He works on bone marrow transplant immunology. 1 4 particular job, a client that you may havemedical doctor? 15 Q. So as a photographer he would hire models for 1 6 A. He?s scientist. He's working on his 1 6 a particular modeling agency? 17 degree. MR. PIKE: Form. 18 Q. And which school is be working on his Pint). 3.8 A. Yesyou know which modeling agencies he 2 0 A. University of Miami. 2 0 typically worked with? 2 1 Q. And how long has he been doing that? 2 3. A. Well, i presume Elite Models because, you 2 2 A. I cannot recall when he started but we were 2 2 know, he had connection and he invited me. i than 2 3 already married. Maybe one or two years into my 2 3 just various Miami Beach -- you know, Miami, South 2 4 marriage. i do not recall the exact time. 2 4 Beach modeling agencies. 2 5 Q. And I believe you testified that you met him 2 5 Q. Did he work for MC Squared? 29 (Pages 110 to 113) U.S. Legal Support (954) 463*2933 114 3.16 i A. I refuse to answer. 1 MR. PIKE: Form. 2 Q. In 2094 and 2905 you were employed by Jeffrey 2 A. I refuse to answer. 3 Epstein, correct? 3 Q. And as young underage girls who were 4 MR. PIKE: Roma. 4 impressed, intimidated, and in awe of his weaith they 5 A. irei?usc to answer. 5 would be uniikeiy to - to complain to authorities that 6 Q. And as an employee of Jeffrey Epstein you were 6 he was engaging in sexual activity with them? 7 under his instruction and supervision, correct? 7 A. refuse to answer. 8 MR. PIKE: Form. 8 MR. PIKE: Form. 9 A. i refuse to answer. 9 Q. Okay. Did Jeffrey Epstein instruct you to 1 0 MR. Let's go off the record for a 0 call girls on the teiephone to schedute appointments 3.1 second. 13. for them to come to his Palm Beach house for massages; 12 MR. WMISTEW: Sure. 1 2 which were, in fact, to be sexuai activity? 13 VIDEOGRAPHER: Off the record at 12: 12 pm. 1 3 MR. PIKE: Form. 1 4 (Discussion off the record.) 1 4 A. I refuse to answer. 1 5 MR. I?li be brief on the general 1 5 Q. Prior to May 2905 did you call dune Doc 4 to 6 questions. 1 6 schednie appointments for her to come to the Epstein 7 On the record, 12: 14 pm. 1 7 house to engage in to give Jeffrey Epstein a massage 8 BY MR. MERMELSTEIN: 8 which would, in fact, be sexual activity with Jeffrey J. 9 Q. And as an employee of Jeffrey Epstein were you 1 9 Epstein? 20 also subject to the to the instructions and 20 MR. PEKE: Form. 2 1 supervision of Ghislaine Maxweil? 2 3. A. i refuse to answer. 2 2 MR. PIKE: Form. 2 2 Q. Okay. Prior to May 2085 while you were at the 23 A. I refuse to answer. 23 Epstein house in i?ahn Beach did you receive caiis from 2 4 Q. And as an employee of Jeffrey Epstein did you 2 4 Jane Doe 4 regarding the scheduling of an appointment 2 5 work under the supervision and instruction of his 2 for her to come to the Epstein house to give Jeffrey 1 3. 5 1 7 1 primary assistant Sarah Kellen? Epstein a massage? 2 MR. PIKE: Form. 2 MR. PIKE: Form. 3 A. I refuse to answer. 3 A. I refuse to answer. 4 Q. Okay. Did Jeffrey Epstein teii you that 4 Q. When Jane Doc 7 - let me strike that. 5 that he recruited from western Palm Beach County 5 Do you know Jane Doe 7? 6 underage giris to come to his Palm Beach mansion for 6 A. I refuse to answer. . 7 sexual activity? 7 Q. When Jane Doe 7 was a minor female did you 8 MR. Form. 8 call Jane Bee 7 to schedule appointments for her to 9 A. refuse to answer. 9 come to the Epstein house in Paim Beach to give Epstein 10 Q. And did Jeffrey Epstein have a computer 10 a massage? 11 database at his Palm Beach mansion where he iisted 3. 3. MR. PIKE: Form. 12 underage high school girls in Pain: Beach County and 12 A. i refuse to answer. 13 their contact information so that he could have these 13 Q. When Jane Doc 7 was a minor female did you 3.4 underage minors come to his house for sexaat activity? 14 receive caiis from Jane Bee 7 while you were at the 3.5 MR. PIKE: Form. 15 Epstein house for her to come to the house by 1 6 A. I re?ise to answer. 1 6 appointment and give Jeffrey Epstein a massage? Q. And did Jeffrey Epstein teii you that the MR. PIKE: Form. 18 reason he brought in underage minors from western Paint: 18 A. I re?tse to answer. 3.9 Beach County is because he anticipated they would he 19 Q. The computer database that Jeffrey Epstein 20 impressed, in awe, and intimidated by his weaith? 2 0 maintained girfs from western Paint Beach County who 2 1 MR. PIKE: Form. 21 would come to the house in Paint Beach to give Epstein an 2 2 A. i refuse to answer. 2 2 massage, did that computer database include the name 23 Q. And as young girls who were impressed and in 2 3 and contact information for Jane Doc 2? 24 awe and intimidated of his weatth they woaid do what he 24 MR. PIKE: Form. 2 5 asked them to do? 2 5 A. i re?lse to answer. 30 (Pages 114 to 117) U.S. Legal Support (954) 463?2933 118 3.20 1 Q. Do you know who Jane Doe 2 is? 1 Q. i'rn sorry so he would contact Jane Doc 7 2 A. I refuse to answer. 2 and have her come to his house to give him a massage? 3 Q. Do you know who Jane Doc 5 is? 3 A. irefase to answer. 4 A. i refuse to answer. 4 Q. Are you aware that the computer database that 5 Q. Did the computer database that Epstein . 5 Jeffrey Epstein maintained in his home contained the 6 maintained on his computers in his home have the name 6 name Jane Doc 8 so that he could contact Jane Doc 8 and 7 and contact information for Jane Doc 5 so that Epstein 7 have him come to the house in i?alm Beach for purposes 8 couid contact her for - for massages in his i?alm Beach 8 of giving him a massage? 9 home? 9 MR. PIKE: Form. 1 0 MR. 21KB: Form. 1 A. I refuse to answer. 1 1 A. I re?ise to answer. 3. 1 Q. You removed three computers from the Palm 12 Q. Do you know the name Jane Doc 6? 12 Beach house with another gentleman prior to the search 13 A. I refuse to answer. i. 3 warrant being issued by the Palm Beach police; isn't 1 4 Q. Bid the computer database that Epstein 3. 4 that correct? 1 5 maintained in his home of underage girls who he wouid 15 A. refuse to answer. 1 6 have come over for massages and sexual activity did 1 6 MR. PIKE: Form. Asked and answered. 17 that computer database include the name and contact 17 Q. And Jeffrey Epstein instructed you to remove 1 8 information for Jane Doc 6? 8 these computers; is that correct? 1 9 A. i refuse to answer. 19 MR. PIKE: Form, asked and answered. 20 Q. Do you know the name Jane Doc 3? 20 A. I refuse to answer. 2 1 A. I re?tse to answer. 21 Q. And Jeffrey Epstein told you that the reason 2 2 Q. Did the computer database that Jeffrey Epstein 2 2 he was instructing you to remove the computers was to 23 maintained in his home include the name and contact 23 hide his sexual activities with underage minors from 2 4 information of Jane Doc 3 so that he couid contact Jane 2 4 the authorities? 25 Doc 3 to come to his Palm Beach home and give him a 25 MR. i?iKE: Formmassage which wouid become sexual activity? 1 A. i refuse to answer. 2 A. i refuse to answer. 2 Q. As an employee of Jeffrey Epstein did you know 3 Q. Did the computer database that Jeffrey Epstein 3 Jannsz Banaziak? 4 maintained in his home include the name Jane Bee 4? 4 A. I refuse to answer. 5 MR. i?iKE: Form. 5 MR. PIKE: Form. 6 A. I refuse to answer. 6 Q. Was Janusz Bauaziak aiso air-?employee of 7 Q. Do you know Jane Doc 4? 7 Jeffrey Epstein? 8 A. i refuse to answer. 8 I MR. PIKE: Form. 9 Q. Did the - did Jeffrey Epstein tell you that 9 A. i refuse to answer. 1 0 he maintained the contact information for Jane Doc 4 in 3. Q. When Janusz Banaziak testified that you and 3. 1 his computer database in his home so that he couid 1 1 another gentieman removed the three compnters from 3.2 contact her to come to his Paim Beach mansion for i 2 effrey Epstein's home he was telling the truth, 1 3 massages? 3 correct? 1 4 MR. PIKE: Form. 1 4 A. refuse to answer. 15 A. i refuse to answer. 15 MR. PIKE: Form. 3. 6 Q. Did you know for a fact that the computer 1 6 Q. Did you observe Jeffrey Epstein persuading, 1 database inciuded the name Jane Doc 4 so that Jeffrey 1 7 inducing, or enticing underage girls to engage in 3.8 Epstein could contact her and she would come to the 18 sexual activities with him? 3.9 i?alm Beach mansion to give Jeffrey Epstein a massage? 1 9 A. I refuse to answer. 2 0 MR. PIKE: Formstrike that. 2 1 A. I refuse to answer. 21 Did you observe Jeffrey Epstein persuading, 2 2 Q. Did you know that the computer database that 22 inducing, or enticing giris who came to his house for 2 3 Jeffrey Epstein maintained his home contained the name 23 the purpose of giving him a massage to engage in sexual 24 and contact information of Jane Doc 7 24 activity with him? 25 A. i refuse sorry. 25 MR. PIKE: Form. 31 (Pages 118 to 121) U.S. Legal Support (954) 463~2933 122 124 A. I refuse to answer. 1 A. I refuse to answer. 2 Q. Did Jeffrey Epstein teil you that he induced, 2 Q. Did Jeffrey Epstein admit to you on numerous 3 persuaded, or enticed underage giris to engage in 3 occasions when Jane Doc 4 was an underage minor that he 4 some! activities with him when they came to his Patm 4 rubbed Jane Doe 4's vagina? 5 Beach mansion to give him a massage? 5 A. {refuse to answer. 6 MR. PIKE: Form. 6 MR. PIKE-2: Form. 7 A. i refuse to answer. 7 Q. Did Jeffrey Epstein admit to you that on 8 Q. Wouid you instruct when you spoke to 8 occasions prior to Jane Doc 4 turning the age of 18 9 underage girls to appointments for massage in 9 that he performed oral sex on Jane Doc 4? 0 Epstein's home would you instruct these giris to lie 1 ?3 MR. Form. 11 about their ages and say they were 18 years old when 1 A. {refuse to answer. 1 2 you knew that they were younger than 18? 12 Q. Did Jeffrey Epstein admit to you that on 1 3 A. I refuse to answer. 13 numerous occasions prior to Jane Doc 4 reaching the age 14 Q. Did Jeffrey Epstein instruct you as to what to 14 of 13 he wouid ptace a vibrator on Jane Doe 4?s 1 5 say to the girls who you contacted by telephone to make 1 5 genitals? 6 appointments to scheduie massages in Epstein?s home? 1 6 MR. PIKE: Form. 3. 7 A. I refuse to answer. 1 A. I refuse to answer. 1 8 MR. PIKE: Form. 18 Q. Did Jeffrey Epstein admit to you that prior to 9 Q. And would Jeffrey Epstein toil you to have the 1 9 Jane Doc 4 becoming 18 years of age he wouid masturbate 2 0 girls who you contacted by the teiepnone to make 2 0 in her presence? 2 3. appointments to come to the mansion to give Jeffrey 2 3. A. {refuse to answer. 22 Epstein massages, that they should -- that these girls 22 MR. i?iKE: Form to the test question. 2 3 should tie about their ages to Jeffrey Epstein? 23 MR. MERMELSTEIN: Ham? 2 4 MR. PIKE: Form. 24 MR. i?iKE: Form to the iast question. 2 5 A. I refuse to answer. 25 Q. Did Jeffrey Epstein admit to you that prior Prior to May 2905 are you aware that Jeffrey 3. Jane Doc 7 reaching the age of 18 years old he wouid 2 Epstein had numerous appointments with Jane Doc 4 for 2 touch her breasts? 3 her to come to the mansion to come to give him a 3 MR. PIKE: Form. 4 massage? 4 A. {refuse to answer. 5 A. I refuse to answer. 5 Q. Did Jeffrey Epstein admit to you that prior to 6 MR. PIKE: Form. 6 Jane Doc 7 reaching the age of 18 he would gropc her - 7 Q. Frior to May 2905 are you aware that Jane Doc 7 grope Jane Doe 7's buttocks? 8 4 wouid come to the mansion to give Jeffrey Epstein a 8 MR. PIKE: Form. 9 massage on a frequent and regular basis? 9 A. i refuse to answer. 3.0 A. i refuse to answer. 10 Q. And did Jeffrey Epstein admit to you that 1 MR. PIKE: Form. 1 1 prior to Jane Doc 7 reaching the age of 18 he wouid rub 12 Q. Are you aware that prior to May 2905 Jeffrey 12 Jane Doe 7?s vagina? 1 3 Epstein engaged with engaged in sexual activities 1 3 A. I refuse to answer. 14 with Jane Doc 4 at the Palm Beach mansion 56 to a 14 MR. PIKE: Form. 15 hundred times? 3.5 Q. Do you know who ?aley Robson is? 1 6 A. i refuse to answer. 1 6 A. ire?sse to answer. 1 7 MR. PIKE: Form. 17 Q. Did Jeffrey Epstein instruct you to cail Hatcy 18 Q. Did Jeffrey Epstein admit to you that on 18 Robson on numerous occasions to recruit underage girls 1 9 numerous occasions he - wnen Jane Doc 4 was an 1 9 to come to the Palm Beach Mansion to give Jeffrey 2O underage minor he touched her breasts? 20 Epstein a massage? 21 MR. Form. MR. PIKE: Form. 2 2 A. I refuse to answer. 2 2 A. i refuse to answer. 23 Q. Did Jeffrey Epstein admit to you that on 2 3 Q. Did Jeffrey Epstein instruct you on numerous 24 numerous occasions when Jane Doc 4 was an underage 24 occasions to contact Haicy Robson for the purpose of 25 minor he touched and groped tier buttocks? 25 scheduling underage giris for appointments to come to 32 (Pages 122 to 125) U.S. Legal Support (954) 463*2933 126 128 1 the Pain: Beach mansion and give Jeffrey Epstein a 1 Q. Excuse me? 2 massage? 2 A. CPA ?rm. 3 A. I refuse to answer. 3 Q. Okay. What was the name of that CPA firm? 4 MR. Form. 4 A. William Owens, CPA, PA. 5 Q. Did Jeffrey Epstein advise you that Haiey 5 Q. William Owens. And is that in Miami? 6 Robson was his contact in western Paim Beach County 6 A. Correct. 7 high schools for the purpose of recruiting underage 7 Q, Where did you work prior to that? 8 giris to come to the Paim Beach mansion where he wouid 8 A. I worked for maybe less than a month at a 9 then engage in sexual activity with them? 9 clothing store. 10 A. I re?ise to answer. 1 0 Q. What clothing store? 1 1 MR. PIKE: Form. 1 3. A. one Monaco. 12 Q. Did Sarah Kellen instruct you on how to 12 Q. Where's that? 13 contact underage girls for the purpose of bringing them 1 3 A. South Beach. 14 to the Falm Beach mansion for massages and what to say 1 4 Q. Where in South Beach? 15 to these young girls? 15 A. It?s on Coilins Avenue and I beiiove maybe 6th 1 6 MR. PIKE: Form. 1 6 and 8:11, Pm not sure. 1? A. I refuse to answer. Q. Okay. Why'd you leave there? 18 Q. Did Sarah Kellen train you in how to contact 1 8 A. The clothing store? 19 girls and recruit them to come to the Palm Beach 1 9 Q. Correct. 2 mansion and - and provide Jeffrey Epstein with 2 0 A. Because I got the accounting job. 2 massages? 2 1 Q. And that's hat you want to be you said? 2 2 A. I refuse to answer. 2 2 A. Yes, uni-hum. 23 MR. PIKE: Form. 2 3 Q. Okay. And I suppose that you left the 24 Q. Was one of your primary duties scheduling 2 4 accounting ?rm because you went to sehooi to finish 25 regular appointments, at least two per day, for Jeffrey 2 5 . your degree? - 127 129 Epstein to have underage girls come to the mansion to 3. A. Weil, I was working part?time and going to 2 give him a massage? 2 school parotime and itjust became too chaiienging. 3 MR. PIKE: Asked and answered, form. 3 The accounting program is very demanding, so I wanted 4 A. I refuse to answer. 4 to dedicate myself to study. 5 MR. MERMELSTEIN: Okay. That's ah I have- 5 Q. How long were you at this accounting firm 6 MR PIKE: I have no questions. 6 Williams Owens William Owens? 7 MR. EDWARDS: i only have a couple- 7 A. Maybe two and a half years about maybe. 8 1?1! go ahead and mark this as Number 4. 8 Something like that. 9 (Where-upon, Plaintiffs Exhibit 4 was marked 9 Q. Ail right. So we're in when was it that 3. 0 for identi?cation.) 3. 0 you left there? 1 REDERECT BMMINATION 3. 3. A. May of 2009. 12 BY MR. EDWARDS: 3.2 Q. Okay. May '09, so that brings us back to Rate 3.3 Q. This photograph appears to he Jeffrey Epstein, 3.3 2806 or something when you started there? 3.4 yourself, and Maer Roshan in this photograph taken from 3.4 A. Yes. That would be about right, yes. 15 an internet newspaper. Can you tell me where that 15 Q. And then it was sometime earlier than that in 16 picture was taken? 1 6 2006 when you were at the clothing store? 1? A. I refuse to answer. 1 7 A. Yes. 18 MR. May I see that, counsel? 18 Q. And you were there for about a month? 19 Q. Was this related this event, was it reIated 1 9 A. About, yes. 2 0 to MC Squared? 20 Q. Give or take 21 5 A. lrefuse to answer. 21 A. Yes. 22 Q. Ali right. What is I know that you toid as 22 Q. a week or so? 23 that you?re not empioyed now becaase you're in schooz. 23 Where -- where did you work prior to the 24 What was your last empioyment? 24 eiothing store Ciub Monaco? 25 A. I was working at the Ioeal CPA firm. 25 A. I was modeling. 33 (Pages 126 to 129) 0.8. Legal Support (954) 463*2933 230 132 1 Q. And where were you modeling? 3. A. Urn-horn. 2 A. In Miami. New York. 2 Q. There?s a period of time from 2002 through 3 Q. For what agency? 3 2086 where -- you know, 2006 you start with if) Models 4 A. In Miami was with Elite Models. lwas with 4 and again with Elite. 2 know when you came over here 5 Michele Fomnner in 2092 you were with Elite also, right? 6 Q. Who's that? 6 A. I'm sorry, you're confusing me with the "i A. Michele Pomniier Agency. 7 tirneframe. 8 Q. Okay. How do you spell the last name? 8 Q. i'm confusing myself, how about that. Let?s 9 A. And then 9 start over. 1 0 Q. Okay. That was in Miami? 3. 0 2802 you come over to the United States", 1 1 A. Yes. 1 1 you' re working at Elite? 1 2 Q. And then what agency did you work through in 12 A. Yes, i'vc been invited by Elite. 13 New York? 13 Q. Okay. And then if i understand you correctly 1 4 A. ID Models. 1 4 over time you continue to work with or through Elite? 3.5 Q. Excuse roe? 15 A. Well, i?ve been, you know, changing agencies 1 6 A. II) Models. 3. 6 throughout the period. 17 Q. ll)? 17 Q. Okay. What are some of the other modeling 1 8 A. Yes. 1 8 agencies you have worked for or with? 1 9 Q. Just in the letter I 1 9 A. refuse to answer. 2 A. Yes. 20 Q. Okay. The only other names of modeling 2 1 Q. -- letter 2 agencies that you can answer are H) Models and Elite; 2 2 And who was the person that got you hooked up 2 2 is that correct? 2 3 at ID Models? 2 3 THE WITNESS: Should 2 4 A. My husband had that contact. 2 4 MR. ROSS: Welt, she's already answered also 25 (2. Okay. How long did you work with if) Models? 25 Michele E?oninrier. 131 133 1 A. I'm trying to think. i do not recall exact 1 MR. EDWARDS: But I thought that was somebody 2 timef?rarne. 2 through Elite, like they?r 3 Q. All right. Well, if the clothing store was 3 MR. ROSS: No, no, no, Michele Pommier is a 4 sometime late 2806 are we talking about earlier in the 4 MR. EDWARDS: Different, okay. 5 year 2806 when you were working with Elite in Miami and 5 Q. All right. Is there anybody else that you?re 6 ll) Models in New York? 6 able to w- to tell me where you worked? 7 MR. ROSS: I?m going to ask you to invoke. 7 MR. ROSS: Invoke as to any further 8 THE WITNESS: l'm sorry? 8 information. 9 MR. ROSS: You should invoke with regard to 9 THE WETNESS: I?m sorry? 3. 0 this time?ame you*re talking about now. 1 0 MR. ROSS: invoke your privilege. 3. 1 MR. EDWARDS: Okay. 1 A. {refuse to answer any questions. 12 A. i refuse to answer. 1. 2 MR. EDWARDS: All right. That?s all I got. 13 Q. Okay. Can you tell me about any job that you 13 MR. WMISTEIN: Can I just follow up a 14 had modeling or otherwise prior to working at Models 1 4 couple? 1 5 or with Elite? 1. 5 6 A. Recall ?just name any 1 6 BY MR. Q. Any what was your - what employment did 17 Q. in what has been marked as Exhibit 2C is a 8 you have just prior to working with Elite Models and ll) 1 8 phone message from you to Adri - from you to Jeffrey 19 Models? 3.9 Epstein dated September 10th, 2095 at 1:15 pm. 2 A. I was working as a model in Europe. 1 2 0 And the message that you left was Lauren 2 1 graduated from high school in 2002 and 1 dedicated that 2 3. con?rmed 4 is that correct? 22 year to modeling and so I was modeling. {did not have 2 2 A. I refuse to answer. 23 employment. 23 Q. Is the Lauren referred to in this message 24 Q. All right. So just so I understand you were 24 Lauren Murphy? 2 5 modeling in Europe, you came over here in 2002. 2 5 MR. PIKE: Form. 34 (Pages 130 to 133) U.S. Legal Support (954) 463*2933 134 136 1 A. I re?lse to answer. 3. and no word index. 2 Q. And did you scheduie Lauren 2 MR. 1'11 take a copy with a 3 MR. PIKE: Form. 3 mini. 4 Q. Lauren Murphy to come to the Paim Beach 4 (The deposition was conciuded at 12:42 pm.) 5 mansion as an underage female to give Jeffrey Epstein 5 (Reading and Signing of the deposition was 6 massages? 6 waived by the witness and ail parties.) MR. PIKE: Form. 7 8 A. i re?zse to answer. 8 9 Q. Aiso what has been marked as Exhibit is a 9 10 phone message from you to Jeffrey Epstein dated 1 11 September 11th, 2885 at 9:15 am. And the message was 1 12 that you got 3 eat for a particular person. Do you 12 1 3 recall that? 1 3 1 4 MR. Form. 3. 4 3.5 A. I refuse to answer. 1 5 16 Q. Is the car that you obtained on 1 6 17? September 11th, 2805 for Jane Bee 4? 1 8 MR. PEKE: Formrefuse to answer. 3. 9 20 Q. And Jane Doe 4 is a girl who had been coming 20 2 1 to the Palm Beach mansion to give Jeffrey Epstein a 2 3. 22 massage and engage in sexual activities with him for a 2 2 23 substantial period of time; is that correctrefuse to answer. 2 4 2 5 Q. And aiso what has been marked as Exhibit actualiy -- 1 CERTIFICATE OF OATH 2 MR. EDWARDS: is that 2 STATE OF FLORIDA 3 MR. MERMELSTEIN: Are they similar? COUNTY OF BROWARD 4 MR EDWARDS: yeah? I guess they masked em 5 i, Janet L. MoKirmey, Registered Professional 5 names on one Of?iem and they didn?t 0? the 0318? 6 Reporter, Florida Professional Reporter, Certi?ed 6 MR. MERMELSTEIN: Right OkaY? 7 LiveNote Reporter, Notary Pubiic, State of Fion'da, "i Q. And what has been marked as Exhibit ZG is a 8 certify that ADRIANA ROSS personaiiy appeared before me 8 message from you to Jeffrey Epstein dated 9 011 Math 15: 2010 and was duty 9 September 3rd, 2005 at 8:50 p.111. And the message you 1 0 Signed this 2m day Of March? 2010? 10 left is, quote, ieft message for Ashicy to con?rm 1 for 11:60 am. and Vanessa for 4:30 pm." 13 12 Did you, in fact, ieave that message? 9514.44? 13 MR. PIKE: Form. 14 Janet McKinney 4 A. I refuse go Registered Professionai Reporter 1 5 Q. And this message that you ieft con?rmed an 1 5 Fiorgda pro?fessmnal Reporter 1 6 appointment for Jane Doe 4 for 4:30 9.111., correct? 1 6 17 A- ?333?? ?0 answer- Commission No; DD552183 3.8 MR. right "?11358 all i 17 Expires: June 2? 2010 9 have. 1 8 2.0 MR. ROSS: Waive. 3-9 23. MR. MERMELSTEIN: Arr right. 20 22 VIDEOGRAPHER: Offthe reeord,12:42 p.111. 2 3 THE REPORTER: Are you ordering? 2 3 24 MR. EDWARDS: Yes. 24 2 5 MR. PIKE: I want a copy, a mini, no 2 5 35 (Pages 134 to 137) U.S. Legal Support (954) 463~2933 oo-?Jmmenwmw 20 23. 22 23 24. 25 3.38 CERTIFICATE OF REPORTER STATE OF FLORIDA COUNTY OF BROWARD I, Jarret McKinney, Registered Professional Reporter, Fion'da Professionai Reporter, Certi?ed LiveNote Reporter, certify that I was authorized to and did stenographicaiiy report the deposition of ADRIANA ROSS, pages I through 138; that a review of the transcript was not requested; and that the transcript is a true record of my stenographic notes. I further certify that I not a relative, empioyee, attorney, or counsei of any ofthe parties, nor am I a reiative or employee of any of the parties? attorneys or counsel connected with the action, nor am I ?nanciatly interested in the action. Dated this 2 I st day of March, 2010. ferret L. McKinney, ?bR, Registered I?rofessionai Reporter Fiorida Professionai Reporter Certi?ed LiveNote Reporter U.S. Legal Support (954) 463?2933 36 {Page 138) 139 A able 8:5 39:23 63:13 74:2 133:6 abuse 36:10,21 41:2 64:2 abusing 41:3 academicians 35:8 acceptable 6:12,14,15 6:16 access 23:13 28:14 37:23 90:4 98:10 100:18 106:6 accounting 11:23,24 128:20,24 129:3,5 accurate 99:16 35:9 act 95:11 action 138:15,16 actions 59:17 activities 84:6 120:23 121:18 122:4 123:13 134:22 activity 56:11 103:19 108:7 115:7 115:14 116:6,12,18 118:16 119:1 121:24 126:9 actresses 34:13 acts 26:6,12,16 82:17,19 adam 80:16 addicted 85:17 addiction 30:9 61:18 addition 32:4 34:11 57:8 additional 56:6 additionally 39:9 address 13:9,15 14:19,23 15:21,25' 16:3,6,8 19:9,18 109:6,17 110:18 addressed 5:16 admit 108:10 123:18,23 124:2,7,12 124:18,25 125:5,10 adri 133:18 adriana 1:13 3:2 4:13 5:4 7:2,8,10 62:20 63:18 65:20 67:24 86:9 137:8 138:8 adrianas 72:23 adult 25:10 35:7 adults 25:13 advise 13:11 126:5 advised 69:9 70:6 affiliated 81:6 affiliation 100:1? affirm 5:7 affirmed 7:3 africa 34:6 97:4,7 afternoon 68:8 age 22:8 24:12 24:13 25:6 43:7 45:4 51:12 90:4 124:8,13,19 125:1,6,11 agencies 9:1,14 29:16 112:20 113:4,8,10 113:19,24 132:15,18 132:21 agency 8:12,14,19 9:6,7,10,12 10:18 18:25 19:5 29:17 100:17 106:10 113:13,16 130:3,7,12 agents 75:13 ages 47:11 122:11 122:23 agree 94:12 95:6 107:19 108:16,21 agreed 6:2 agreement 21:1,5 32:12 102:3 107:19 ah 67:14,20 69:1,4,11 69:13,15,16 69:17 70:1 ahead 14:11 33:10 127:8 ahha 15:14 airplane 40:25 41:4 76:3 79:11 79:13 81:24 82:4,7,9,12 airplanes 75:1,9 airport 79:5 a1 1:8 4:14 alan 2:24 5:3 37:6,8 81:24 alfredo 92:9 aline 77:19,22 alleged 34:10 allow 64:2 allowed 98:4 amendment 6:1,6,12 14:6 21:15 amsel 2:20 andrea 81:22 andres 76:16 andrew 37:1,3 87:24 andrews 2:4 angeles 34:5 angry 41:16?93:17 93:24 103:18 answer 6:3,4,11,11 13:13,16 14:3,21 15:9,11 16:12,18,19 16:22 17:4 17:6 18:7 18:10,13,16 18:18,21,24 19:2,6,10 19:14,16,19 19:23,25 20:4,7,10 20:13,15,20 20:25 21:3 21:9,14,18 21:22,25 22:5,11,13 84:17 U. 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(954) Legal Support 463*2933 144 30:24 controlled 18:23 99:10 cooperate 93:20 108:6 cooperated 94:4 copperfield 52:13,l5 COPY 60:17 135:25 136:2 cordero 100:7,22 correct 7:10,11 8:6 8:8 9:22 12:17 15:24 38:7 40:11 44:21 45:12 45:22 46:12 46:17,22 47:13,22 48:2,6,10 48:14 49:5 49:9,18 50:3,23 51:5,18 53:12,24 54:3,10,14 54:23 56:20 57:13 61:3 61:9,19 63:2,8 64:6 64:20 65:8 65:12,25 66:9 67:21 68:8 71:2 73:24 75:2 76:7 78:6 79:19 81:7 82:4,9 83:8 83:12,20 84:1,23 88:12 89:17 89:24 90:5 91:4 94:18 96:17,22 97:11,15,21 98:5 100:11 100:19 101:5 102:12,17 102:22 103:6 106:7 106:11 112:1,2 114:3,7 120:14,18 121:13 128:6,19 132:22 133:21 134:23 135:16 corrected 7:18 correctly 8:4 132:13 couldnt 111:2 counsel 4:18 5:17 101:8 127:18 138:13,15 counted 92:7 countries 34:18 98:25 99:3 country 7:16 8:7 19:4 99:8 99:12 110:10 county 74:23 115:5 115:12,19 117:20 126:6 137:3 138:3 couple 15:7 127:7 133:14 course 5:25 court 1:1 4:15,19 6:17 15:10 courtney 45:25 covered 65:15 covering 24:11 cowles 100:5 ope 127:25 128:2 128:3,4 created 51:21 92:7 credibility 60:1 crime 24:17 crimes 58:4 107:14 107:20 criminal 27:4 31:25 54:7 56:11 56:16 57:9 57:24 59:16 103:19 2:23 criminally 53:8 critton 2:9 3:4 111:7 ?rY 66:16 crying 66:12 current 12:22 currently 16:6 17:7 18:5 czech 34:17 dade 11:11,12,15 daily 68:13 dalton 71:25 dana 39:14 database 54:7 115:11 117:19,22 118:5,14,l7 118:22 119:3,11,17 119:22 120:4 date 7:22 dated 56:25 133:19 134:10 135:8 138:17 dating 12:23 david 52:13,15 day 4:9 23:8,14 36:11 45:15 45:22 66:24 66:24 86:20 92:12 105:11 126:25 137:10 138:17 days 38:24 dd552183 137:16 dead 65:7 dealing 54:8 dealings 77:7 decade 104:22 december 78:14 79:2 decide 12:7 decided 11:1 17:19 92:3 'decision 10:20 decline 46:8 dedicate 129:4 dedicated 131:21 defendant 2:8 defendants 1:9 defense 56:19 defenses 59:16 defined 98:8 degree 11:11,13,14 11:17 17:20 24:15 111:17 128:25 delivers 30:12 demand 0.8. 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Legal Support (954) 463*2933 146 employee enterprise 50:1.12 108:23 70:12 73:23 21:11 40:15 54:7 52:2 53:3.7 110:6 114:3 74:4.12.22 114:6.19.24 55:14 56:12 114:6.19.24 75:1.9.19 121:2.6 112:8 56:16 57:17 115:4.10.17 79:19.23 138:13.14 enticed 57:20 58:4 116:9.16.l7 81:9 84:7 employees 122:3 58:22 59:11 116:19.23 92:11 95:2 26:5 50:22 entices 59:15 60212 116225 97:24 61:18 24:13 60:25 61:3 117:1.9.9 102:12.15 employment enticing 61:8 63:2.8 117:15.16 103:16 112:3 127:24 121:17r22 64:12.23 117:19.2l 104:12.17 131:17.23 entitled 69:4.10.14 118:5.7.14 104:25 encounter 105:19 69:16.20 118:22 106:18 69:12?23 Epstein 70:16 71:1 119:3.9.18 108:11.18 encounters 1.8 2,8 3.14 71:15 73:4 119:19.23 121:12 49:17 7338.17 12025.17,21 122:10.16 endeavor 12,3 1?_9 74:14 75:13 121:2.7.16 erin . 76 2.20 121:21 110:4 37.20 18.19.23 78:6.15 122:22.23 49:9 12.16 20.2.5.17 79:3 80:12 12322.8.13 escaped ends 21.2.12.20 . 80:21 81:14 123:18.23 36-1 51:1 21.23 22.3 . 82:16 83:11 124:2.7.12 escort enemles 22.12.16.20 83:19.24 124:18.25 89.19 104:17 23.3.7.12 . 84:22 85:8 125:5.10.17 as enforcement 23.17 24.18 85:13 86:14 125:20.23 2.6 12 18 24 21'12 83?20 25?119r17 I I 87:14.18.25 126:1.5.20 83:23 26.5.16 6 engage - . . . . 28_ 88.23 89.1 133.19 51:10 99:20 -10:13:24 . europe 29,25 30,7 89.20.24 134.5.10.21 8.19 20 9,2 105:5 - - 90:7.10.15 135:8 . 116:17 30-13.20 . 9.8 10.24 121:91:23 92:20 20:23 22:8 . 122:3 126:9 32.19 33.4 112.1.9.11 33.13 19 22 93:7:17 22:24 25:23 131.20 25 134:22 - . . - engaged 96:8 97:1 30:24 31:4 12:23 82:17 34322 3526 . 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Legal Support (954) 463*2933 147 74:19 evolved 12:24,24 ew 4:22,22 42:19,21 43:11 47:1 89:6 108: exact 7:18 8:10 45:15 62:3 111:24 131:1 exactly 14:14 48:1 54:18 111:4 examination 3:3,4 7:5 127:11 examined 7:3 excited 90:15 excuse 101:8 128:1 130:15 executed 53:12 57:1 81:13 107:8 execution 53:15,17 exhibit 4:6 5:14 6:18 33:11 33:16 56:19 62:7,11 72:12 87:12 127:9 133:17 134:9,25 135:7 exit 94:25 expand 10:25 11:3 expect 12:2 experience 50:15,21 expires 137:17 explain 15:7 23:12 71:15 explained 46:11 69:11 explaining 50:16 exploit 36:10 exposed 54:7 extent 32:20 face 47:20 fact 53:21 55:24 65:2 67:20 79:22 94:3 94:16 97:17 116:12,18 119:16 135:12 faizly 36:15 fall 8:10 12:1,3 12:7 15:22 16:3 familiar 13:14 14:19 18:25 24:1 29:13,15 35:16 36:11 37:13 42:12 42:15,19,23 49:20 51:15 53:23 56:22 60:17 62:1 67:17 69:23 102:3,7 family 59:1 far 15:6 66:11 faxmer 2:3 fashion 9:12 faster 85:24 fathertype 95:11 favor 97:20,25 favors 59:1 83:23 fe 34:5 fear 91:18 103:15 federal 5:19 feel 32:15,19,23 46:7 68:24 feeling 10:6 65:11 felonies 101:4 felony 24:15 felt 94:5 female 25:5,18 33:23 38:22 41:18 45:10 46:20 48:6 51:5,11 63:1,6 65:24 66: 68:7 108: 117:7,13 134:5 12 13 females -19:3,7,13,18 21:7,24 22:3 23:13 23:18,22 24:23 26:6 26:12,17,22 27:1,7,16 27:21 28:14 29:7 30:4,9 30:13,24 31:8,13,17 32:24 35:17 36:20 37:4 37:10,23 39:6,10 40:20 41:3 41:9,13 42:13,25 43:1,25 45:17 46:25 48:14 49:18 49:22 50:1 50:7,11,l7 51:18,22,23 52:6,17,22 54:9 61:3,9 64:24 66:21 68:13 70:17 71:20 74:15 76:19 77:2 78:1,4 80:22 82:8 82:24 88:17 89:5 97:15 98:11 99:1 99:4 100:10 100:19 102:16 104:22 105:6,10 106:6,18,23 108:2 fetish 48:22 fifth 5:25 6:6,12 14:5 21:15 figure 95:11 file 67:8 84:5 filed 33:12 fill 67:9 financially 35:22 138:16 find 95:6,7 104:20 109:13 110:25 fine 14:11 101:11 fingers 49:3 finish 15:9,9 128:24 firm .1 127:25 128:2 128:3,24 129:5 first 7:3,15 10:14 14:23 16:7 21:23 25:16 53:8 58:8 71:19 95:4 109:1 fistos 2:3 fix 72:14 flew 79:22 80:2,5 80:8 84:13 flies 76:3 flight 10:8 12:6 0.8. 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Legal Support (954) 463*2933 149 87:19 106:14,14 friendly 83:19 friends 36:19,24 81:1 87:25 104:13 fulfill 63:7 full 7:7,7 14:3 fuiltime 12:4,5 17:8 61:17 further 58:14 133:7 138:12 future 90:19 103:22 gain 28:13 37:23 90:4 100:18 gaining 98:10 106:6 gawker 3:19 general 30:20 114:15 generally 44:8 62:3 genital 24:11 genitals 24:10 124:15 gentleman 120:12 121:11 getting 5:12 25:17 58:22 71:11 71:11 ghislaine 18:11 28:8 30:12,17,19 31:11 33:3 33:22 34:2 34:11 39:16 42:7 65:11 75:13,24 85:12 91:18 92:1 93:13 103:5 104:21 114:21 gifts 9624,12 girl 66:8 71:9,10 71:11 90:11 90:14 92:3 92:21 95:5 97:7,14 134:20 girlfriend 104:25 girls 28:9 29:21 34:17 35:12 36:9 45:4 46:6,15 48:2 51:17 62:2,3 64:1 64:9,19 65:16 66:16 68:24 71:5 88:4 89:6,9 89:12,15 90:3,3 92:12,13,13 93:3,8,9 94:3,8 95:12 96:17 97:25 98:2 100:25 105:20 115:6,12,23 116:3,10 117:20 118:15 121:17,22 122:3,9,10 122:15,20 122:22 125:18,25 126:8,13,15 126:19 127:1 give 5:8 15:11 going 12:8,14:17 11,12,17 19 24:7 :10 45:9 :11 56:24 12 60:10 7,9 63:2 6:12 101:9 101:10 group 62:1 90:4 guess 55:19 72:7 135:4 guilty 101:4 26:24 51:11 84:1 92:15 108:7 116:17,25 117:9,16,21 118:25 119:19 120:2 122:5 122:21 123:3,8 125:19 126:1 127:2 129:20 134:5,21 given 19:8 45:4 gives 51:8 giving 97:20 120:8 121:23 glenn 88:7,17 go 10:8,20 12:10 14:11 17:8,20,22 33:10 45:20 60:3 64:19 73:2 78:10 86:8 87:8 109:14 114:10 127:8 god 5:9 goes 89:15 93:3 63:12,13 65:25 72:16 72:24 73:5 74:21 85:24 86:7 92:6 92:15,20 93:9 107:13 129:1 131:7 good 5:3 government 107:19 grab 94:9 grabbing 48:12 grade 89:10 graduate 11:5 12:2 graduated 11:2 131:21 grand 5:19 56:19 great 110:21 greeted 46:21 groff 42:8 61:22 grope 125:6,7 groped 123:25 groping 49:3 grounds guy 9:3,5 16:20 55:1 habit 105:9 hadnt 58:3 haley 125:15,17,24 126:5 half 129:7 hallway 95:1 hand 5:6 48:10 49:2,3 handwriting 62:18 handwritten 3:17 happen 15:16 92:19 106:21 happened 7:19 15:17 69:3 72:25 74:20 95:5 happening 68:18 haapy 90:11 92:25 harass 59:21 hard 8.8. Legal Support (954) 463*2933 . l1 .g4v 1' 150 48:19,24 hasnt 62:20 hazel 83:3 head 15:12,12 69:18 95:1 hear 29:20 heard 76:23 90:7 hearing 24:16 hed 96:21 held 69:18 help 5:9 100:17 104:11 helped 23:21 55:1. helping 18:2,2 107:25 hes 44:10 49:2,4 51:21 55:13 92:20,21 93:19 106:10 111:12,16 111:16 hey 68:22 hidden 31:3 hide 120:23 high 11:2,5 89:10 115:12 126:7 131:21 hire 23:17 64:13 113:9,11,13 113:15 hired 19:20 20:14 55:13 57:16 57:24 hold 62:21 home 31:4 44:19 44:19,20 53:11,12 54:10 55:3 55:9,25 56:4 57:1 60:13 62:2 70:13 92:11 96:4 107:8 118:6,9,15 118:23,25 119:4,11,23 120:5 121:12 122:10,16 hooked 130:22 hopes 102:21 horowitz 2:15 hours 86:13,18 house 20:18,23 27:16 31:18 32:25 37:9 37:10 40:20 43:7,12,18 43:24 45:11 46:21,22 49:13 51:10 53:24 54:3 54:22 55:17 55:19,21 56:8 66:13 66:17 67:21 68:21 69:8 70:2,3,17 70:25 74:4 74:22 81:12 83:7 84:7 93:4 94:12 102:12 105:4 106:18 108:11,18 108:22 109:25 115:14 116:11,17 116:23,25 117:9,15,15 117:21 120:2,7,12 121:22 houses 77:17 hum 124:23 hundred 43:13 123:15 hurt 65:2 hurting 65:7 husband 8:18 12:22 109:19 111:10 130:24 husbands 109:21 I id 130:14,16,17 130:23,25 131:6,14,18 132:3,21 identical 50:16 66:8 4:7 33:17 62:12 72:13 87:13 127:10 identifying 5:18 igor 81:20 ill 6:10,18 15:18 39:24 87:5,8 114:15 127:8 136:2 illegal 41:7 91:2 103:1 in 9:24 11:12 12:5,13 13:11 14:17 15:21 16:1 16:11,15,17 17:12,19 24:7 26:22 29:19 56:22 62:7,9 63:11,13 72:16 74:21 77:5 86:7 101:14 109:25 110:15,21 112:19,19 120:1 128:16 131:1,7,8 132:6,8 133:9 immediately 69:9 immigration 7:14 imminent 56:1 immunology 111:14 implying 26:23 import 99:4 importantly 73:4 impressed 58:11 103:15 115:20,23 116:4 include 22:8 42:7 70:20 117:22 118:17,23 119:4 included 69:12 102:6 119:17 including 35:7 46:25 105:20 index 136:1 indicate 27:7 72:23 82:23 indicates 26:21 33:21 34:16 62:20 74:20 induced 122:2 inducing 121:17,22 industry 17:25 28:18 77:9 information 53:22 101:20 115:13 117:23 118:7,18,24 119:10,24 133:8 initial 57:11,12 U. (954) Lega1 Support 463~2933 151 initially 7:13 20:14 initials 78:16 82:23 inner 25:24 inserted 69:16 inserting 49:3 inside 31:4 46:15 69:19 93:4 instruct 16:17 27:12 116:9 122:8 122:10,14 125:17,23 126:12 instructed 120:17 instructing 120:22 instruction 114:7,25 instructions 114:20 intend 103:22 109:2 intended 59:16 intends 105:24 intent 58:4 intention 26:25 24:9 interact 23:8 41:8 52:16.21 97:6 interacted 23:3 43:1 53:3 interacting 22:3 41:13 52:5 96:21 97:1 interaction 51:10 interactions 101:5 108:2 66:4 44:18 interested 138:16 interference 101:15 11:21 34:23 35:2 internet 127:15 interrupt 13:24 interruption 101:25. intimidate 59:21 64:19 intimidated 115:20,24 116:4 introduce 4:18 10:19 introduced 112:14 investigated 53:7 5:19,22 27:4 32:1 56:16 56:20 57:9 55:13 64:18 invited 8:12,17,21 9:20 10:5 113:22 132:12 invoke 5:25 13:11 21:17 24:4 29:22 57:18 59:8 131:7 131:9 133:7 133:10 invoking 6:5 14:5 21:15,19 26:23 involved 12:21 17:24 26:22 27:8 34:22 37:3 40:15 81:17 102:16 103:23 106:10 involvement 28:18 102:10 102:14 110:6 involving 103:18 island 38:13,19 44:20 80:2 isnt 22:2 23:3 24:16,17 26:4 27:21 29:9 30:3 30:12 36:15 37:9,22 39:5 43:2 43:13 44:14 45:3 46:12 50:17 65:3 71:6 76:2 76:10 79:9 85:16 88:16 93:2,10,19 93:24 103:11 105:14,18 106:21 120:13 issued 120:13 ive 14:8 33:15 53:23 54:8 54:18 72:14 87:22 132:12,15 jaffe 2:3 james 38:14 jane 1:5 3:14 4:14,22,22 4:25 33:12 33:18 34:3 34:11 35:6 35:13 36:1 36:5 42:23 43:17 47:1 67:12 89:6 108:21 116:15,24 117:4,5,7,8 117:13,14 117:23 118:1,3,7 118:12,18 118:20,24 118:24 119:4,7,10 119:17,24 120:1,6,6 123:2,7,14 123:19,24 124:3,4,8,9 124:13,14 124:19 125:1,6,7 125:11,12 134:17,20 135:16 janet 1:22 4:1,15 137:5,14 138:5,19 janusz 92:8 121:3,6 121:10 japan 9:7,10 jean 16:20 17:5 29:3,6,9,20 29:24 35:1 36:24 82:3 82:7,16 84:14 85:8 85:13 106:14,17 jeffrey 1:8 2:8 3:14 4:14 5:1 17:3 18:9 18:19,23 20:2,5,17 20:22 21:2 21:11,20,23 22:2,7,12 22:15,20,23 23:3,17 25:9 26:5 26:16 28:7 28:10,13,17 '28:24 29:24 30:7,13,20 30:24 31:4 31:11,17,22 32:1,11,15 32:19,25 33:3,13,19 33:22 34:2 34:10,16,22 35:5,9,16 36:8,19 37:8,11 38:2 39:2 39:19,22 40:2,5,11 0.8. Legal Support (954) 463*2933 152 40:16,20,21 85:10,24 38:22,24 46:22 56:15 62:8,13,18 40:24 41:2 96:8 97:24 jersey 61:13 75:14 52:24 55:11 41:7,12,16 88:10,25 80:8 78:16 80:12 56:23,23,24 41:21 42:3 88:11,23 82:10 86:3 58:7 62:8 43:1,6,12 100:3,18 78:18 86:7,11 66:2 67:1,8 43:17,18,23 101:3 'ob 88:23 100:2 67:11 68:3 43:25 44:3 102:12,15 15:10 84:4 183:6 115:1 71:19,24 44:8 45:5 102:17 113:14 126:12,18 73:21 74:18 46:12,16 103:2,4,11 128:20 kellens 75:14,22 47:13,16 103:16 131:13 39:1 ?6:16,18 48:1,22 jcel ken 50:1,11 104: 5 77:15 107:1? 52:2 55:14 105:4,18 jchanna kept 82:25 83:5 56:8,12,16 106:5,18 88:20 8:4 60:12 84:20 87:23 57:17,20 107:4,12,20 john key 88:7,8,20 5824,22 107:25 78:6 25:22 53:21 91:6 92:10 108:5,11,12 johnson khalid 94:3,8 108:17;23 1:2 1:00:14 982161723. 61:2,8,18 110:6 114:2 jojo kind 88:3,7 63:1,7 114:6,18,24 83.5 7:14 l0:5!19 100:2,5,7 64:12,23 115:4,10,17 .O?efsber 17:18 100:14,22 65:25 67:21 116:8,17,18 ?3.12 9 101:20 105:1,23,24 68:4 70:12 116:25 juiie kissi?g 106:3 70:16 71:1 117:16,18 r2.20 22 69il2 107:11 71:15 73:23 118:22 065.5419 kitchen 112:18,18 74:3,12,14 118:3,8,17 66:2; 94.17 18 113:12,18 74:22 75:1 118:18,23 kn?w 113:22,23 75:8,13,18 120:5,17,21 3ulle$ . . 117:6 118:1 76:2,18 121:2,7,12 ?3=1 8'1? 17:1? 118:3,12,28 77:1,8 78:6 121:16,21 JulY 89'?2 91:2 118:7,16,22 78:15 78:2 122:2,14,18 7:21 109=2 20 121:2 78:18,23 122:21,23 June 126:15 80:12,21 123:1,8,12 137:17 kaz'lz 127:22 81:8,13 123:18,23 jury 132:3,4,15 82:16 83:18 124:2,7,12 5:19 23:12 10:25 11?2 knowing 83:24 84:6 124:18,25 56:19 12f22'24'25 105:8 84:22 85:8 125:5,10,17 16:10:20 knowledge 85:13 86:13 125:18,23 18:13:14?17 37:4 87:14,18,25 126:1,5,20 keep 19?3'7?15 known 88:4,12,16 126:25 20:18 33:4 22:19 23?25 7:9 25:9 88:22 88:1 127:13 61:18 82:24 24?17 25?25 33.3 64:12 88:20,24 133:18 keeping 29324 3??19 87:6 134:5,10,21 62:21 knows 32:2: 3::ii .135'8 ke%1en 38:24 38:14 29?24 88:23 . . jeffs 3.8 . .. kollatajo_ . . 82:20 83:7 38:15 28:8 40:1,6 41;7 a7:25 110:20,24 83.17 85.10 34168214 41.25 44.8 48:22 52:2 korea U.S. Legal Support (954) 46382933 153 9:11 kuzincy 110:23 kuznicy 110:20 lack 28:6 44:3 61:2 laid 94:13 large 4:4 91:6 las 1:18 4:11 lasoivious 24:6,10,14 late 8:24 17:15 40:10 86:17 129:12 131:4 lauderdale 1:19 2:5 4:11 lauren 65:20 133:20 133:23,24 134:2,4 law 21:12 83:19 83:23 95:16 laws 23:25 lawsuit 33:11,18,21 lay 47:20 lead 47:5 leading 57:2 leads 95:2 leaxn 21:23 53:8 learned 25:16,22 leave 6:18 47:6,6 128:17 135:12 leaving 68:2 left 36:2 47:12 67:24 70:2 70:3 74:3 94:22 128:23 129:10 133:20 135:10,10 135:15 legal 1:18 2:25 4:16 19:24 legitimate 89:1,23 lehxman 2:3 lesbian 99:15,20 lesley 42:8 61:22 leslie 52:24 53:4 letter 3:25 5:15,18 56:20,23,25 57:3 130:19 130:21 lewd 24:6,10,14 lie- 122:10,23 life 39:2 58:15 lifestyle 58:12 103:16 light 26:24 liked 65:2 likes 48:23 list 44:14,24 89:16 listed 115:11 listen 58:15 little 38:14,14 65:16 95:1 live 14:22 15:25 16:2,6,8 18:22 109:17 lived 13:2,4,10 14:23 16:4 16:10 livenote 1:25 4:3 137:7,15 138:7,21 lives 19:15 38:24 109:25 living 15:22 52:3 2 111:11 11p 2:9 1m 4:22,23 42:15,17 4326,23 47:1,10 51:17 89:6 95:23 96:15 96:20 108:10 loaded 96:11 local 46:1 54:6 109:2 127:25 locate 109:14 located? 78:2 logs 75:8 82:22 long 8:22 11:24 14:22 15:25 16:2 85:21 93:20 111:21 129:5 130:25 longer 12:16 85:20 96:20 look 15:15 54:17 68:22 72:14 looked 42:17,21 looks 40:9 los 34:5 lot 16:12 53:22 72:21 74:6 85:24 92:7 95:19 louella 92:8 louis 34:5 luo 16:21 17:5 29:3,6,9,20 29:24 35:1 36:24 78:6 82:3,7,16 84:14 85:8 85:13 106:15,17 lucky 98:3 luttier 2:9 83:5 lyons 5:17 57:11 mad 93:24 madam 6:17 maer 127:14 maintain 83:15 maintained 117:20 118:6 118:15,23 119:4,10,23 120:5 major 107:18 making 19:24 male 35:7 54:22 man 88:7 management 9:13 manager 46:22 managers 83:7 manhattan 13:8,9 14:19 38:10 83:8 manner 24:10 mansion 0.8. Legal Support (954) 463*2933 154 44:11 49:13 massage 75:13 85:12 mentioned 47:1 53:1 83:7 98:4 25:17 26:4 91:18 92:1 86:7 87:22 58:8 74:9 115:6,11 27:13,21 93:13 103:5 mercedes 74:22 77:5 119:12,19 28:3 47:21 104:21 96:8:12 77:8 98:23 122=5r21 50:22 66:3 114:21 mermelstain 10032 123:3,8,14 69;14,15 maxwells 2:15:18 3:4 111:25 125:19 89:2,24 75:24 3:5 4:24:24 112:9,14 126:1,8,14 107:3 me 5:15 14:10 methods 126:20 116:17 18:25 19:5 86:23 111:8 28:13 127:1 134:5 117:1,10,16 28:21 114:12,15 metrovich 134:21 117:22 100:16 114:18 81:22 manual 119:1,19 113:25 124:23 meaico 21:10 28:1 120:2,8 127:20 127:5 44:19 80:5 march 121:23 mcguire 133:13,16 miami 1:17 4:9 122:5,9 2:25 4:16 135:3,6,18 2:16,22 137:9,10 123:4,9 meintyra 135:21 10:12,14 138:17 125:20 29:13 136:2 11:11,12,15 marcinkova 126:2 127:2 mokinney mess 12:6 13:2 18:17 20:22 134:22 1:22 4:2,15 104:3 14:23,24,25 22:19 27:1 massages 137:5,14 massage 16:5 109:9 49=16:20:25 25=25 26:12 138:5,18 3:18 68 12 109:10 69:10:13. 61:2 116:1]. mean 60:16t20 111:20 78:15 79:2 118:8,16 9:8 18:2 52:8:23 113;23,23 92:9 99:8 l19=13 42:7 46:11 63:11,17,22 128:5 130:2 99=11r21 122=15:32 62:23 63:22 65:19,21 130:4,10 mark 126=14r21 66:3 68:11 66:23 67:1 131:5 33:11 62:8,9 13436 70:22 86:16 67:5,24,25 michael 72:8 127:8 massaging 98:2 103:9 68:2 70:11 2:12 5:1 marked 48:6 113:5,6 70:11 72:6 98:21 4:6 5:14 masseuse meaning 74:1 86:6 michele 6:18 33:16 89:2 27:20 108:22 86:20,25 130:5,7 56:18 62:12 masturbate means 37:9 92:6 132:25 72:12 87:12 48:10 50:2 26:1 65:21 133:3 127:9 124:19 67:1 70:25 133:23 midSOS 133:17 masturbating media 134:10,11 8:24 134:9,25 49:2 37:13 mike 135:7 material medical 135:12,15 106:3 marriage 54:13 111:15 NBSsages milan 111:2: matter meet 3:16 70:13 9:5,6 married 5:21 87:24 70:16:20 mini 7:13,28 8:1 maxwell meetings 74:3 86:8 135:25 136:3 8:7 12325 18:12 28:8 28:6 64:8 86:16 minor 111:23 30:12,17,19 meister messed 22:2: 23:13 marrow 31:12 33:3 77:13 72:10:14 23:18,22 111:14 33:22 34:2 met 25:17 27:15 martin 34:12 39:16 21:12 8318 i713r5 28:14 30:4 52:19 42:7 65:12 33:8 37:1:6 30:8,13,23 0.8. Legal Support (954) 463~2933 155 31: 32: 34: 36: 37: 39: 40: 41: 42: 43: 44: 45: 46: 48: 49: 50: 50: 51: 52: 8,13,17 24 33:23 17 35:17 20 37:4 10,23 6,10,18 19 41:3 8,13,18 13,25 24 44:4 14,24 10,17 20,25 6,14 17,22 1,7,11 17 51:5 18,22 6,16,22 54:9,9 59:22 61:3 61:9 63:1,6 64:24 65:24 66:12,21 68:7,13 69:4 70:17 71:20 74:15 76:19 77:2 78:1,24 82:8,8 88:4 90:3,3 92:15 97:14 98:11 99:1 99:4 100:10 100:18 102:16,16 105:5,10 106:6,18,22 108:2 117:7 117:13 123:20,25 124:3 minors 23:4,8 27:9 28:2 29:10 29:17 35:19 49:4 59:17 61:19 67:7 72:3 78:11 81:18 82:17 83:12 85:17 89:16 102:11 105:25 107:21 115:14,l8 120:23 mistake 7:15,18 model 9:1,21 10:19 77:9 84:22 113:13 131:20 modeled 28:21 modeling 8:12,14,20 8:22 10:16 10:22 11:3 11:3 17:10 17:14,17,22 17:24 18:25 19:4 28:18 28:25 29:4 29:16 40:15 77:8 85:4 100:17 106:10 112:15 113:3,8,10 113:13,16 113:19,24 129:25 130:1 131:14,22 131:22,25 132:17,20 models 8:15,16 9:4 9:20 10:21 18:2,3 34:12 78:5 113:9,11,15 113: 130: 21 4,14,16 130:23,25 131:6,14,18 131:19 132:3,21 molest 32:25 39:11 43:25 45:16 63:2 65:25 66:2 68:7 96:17 105:24 108:18,23 molestation 24:7,14 91:7 91:20 98:8 102:21 molested 43:7,18 45:5 71:11 108:12 molester 25:2 58:7,19 98:13 molesting 34:11 68:13 71:1 72:3 moment 13:25 mominlaw 109:19 monaoo 112:12 128:11 129:24 monday 1:17 4:9 money 51:9 52:9 56:6 58:11 59:21 94:9 95:19 97:20 monioa 109:24 monroe 110:5 100:14 month 8:10 53:15 53:16 128:8 129:18 morning 5:3 68:7 86:17 motherinlaws 109:23 move 14:15 16:14 111:1 moved 16:3,7,16 moving 18:20 63:12 mpike 2:12 muoinska 7:10 8:4 muzphy 133:24 134:4 nadia 18:17 20:21 22:19 26:25 49:16,20 69:10,11 78:15 79:2 92:9,13 99:7,7,10 99:21 naked 31:8 47:16 69:10 name 5:3 7:7,14 7:15 8:4 9:4,11 16:20 18:11 18:14 67:6 72:7 82:23 88:7 102:7 109:21,23 110: 117: 118 118: 119: 120: 130: 131: 3 22 :6,12,17 20,23 4,17,23 6 128:3 8 16 named 18:1 33: 63: 7 32:10 6 38:22 6 92:8 names 42:1 88: 132 135 2 67:7 14 :20 :5 naomi 77:5 near 60:1 2 necessarily 72:2 need 46:6 2 108:5 needed 10:4 109:13 neighborhood 83:2 5 nervous 55:2 4 never 89:1 97: new 13:6 14: 16: 18 23: 44: 61: 71: 78: 80: 130 131 2,19,23 6 110:25 ,7,15 20 16: 13,16 11 :20,22 13 34:4 19,19 23 62:2 10,10 10 80:5 8 83:12 :2,13 :6 0.8. Legal Support (954} 463?2933 156 newspaper 41:12 101:9 101221 94:21 3:2,12,23 127:15 objection okay pages nice 6:9 19:24 6:17,20 7:22 11:4 1:14 138:9 93:19 108:19 8:7 9:1,14 opposite paid night observations 9:19:25 65:2 20:17 22:15 86:17 30:7 76:11 10:8,16 option 39:5 56:7 nipples 99:16 12:10:13,19 46:7 51:9 57:20 69:22 48:18:23 observe 13:1,14 oral 70:25 71:12 49:5 82:19 121:16 14:11:22 69:13 124:9 palm nodding 121:21 15:1:5119 order 2:11 34:4 15:12 observed 15:7:10120 6:2 10:3 44:10,20 nods 19:11 22:7 17:21 29:15 47:17 48:5 49:12 62:3 32:9 obsessed 29320 5738 64:1 74:23 115:5 71:20 85:17 57:16 60:11 ordered 11535711712 32:12 102:2 obsession 62:15 63=17 53:17 54:2 115:18 107:18 21:24 22:8 59=3 74=6 ordering 116:11,23 normall 22:24 30:3 77:13 86:30 135:23 117:9,20121 69 21 30:8 35:18 86=24 95=16 oxders 118:8,25 'th obtained 101:7,ll:21 49:16 119:12,19 31:12 34:3 109?6117 organization 120=7r11113 134 16 110=18 28.9 122:4 n?tary ht I . 111:9 115:4 123:14 4:4 137:7,16 0 aiming l6_9 22 orgles . 9 28-9 1 38-19 106:22 125:1 n? 8 oc?asio?s 127:5 128:3 ou?line 126:1,6,8 72:6 79.19 92_19 128:17,23 21.5 126:14,19 ?Otes 129:12 . . 134:4,21 3:17 138:11 123-19124 130:8!1Or25 paper nowak 1243318.!13 13 5:20 . 125.18 24 - . 15.15 52:19 132:13,17 outSlde parents number ootober 132:20 70:12 16.23 68:18 . . 7:23 57:2 5 4.13 5.14,20 133:4 135:6 Owen 72:24 73:2 40:6 63:28 offenders Gigs 128:4,5 73:5?9r11 98:11 127:8 24:3 1:38 4:11 129:6,6 l04zll numbers Offenses old owned 110:8:10 4:25 5-21 8:23 22:4 18:23 parlor numerous Offar 33:22 43:13 owners 89:24 27:7 39:21 51117 43:19 76:10 29:17 gart 75:2 79:19 Offered 90:5 94:4 91:6 93:2 82:22 123:2 73:17 95:24 99:7 Participate 123?19'24 ?ffers 122=11 Pad 26:15 49:17 124:2,13 51:4 125:: 63:11 72:6 50:6 affice once Participatad 5:16 67=7 46:15 57:24 pads 50:10 0 oftentxmes 195:15 60:12:16 Participa_._ oath 82:23 online 62:9 70:11 27:1 3:7 137:]. oh 37:14 70:13. 92:6 Particular 8.8. Legal Support (954) 463*2933 157 113:3,8,11 112:13 60:13 31:19,23 61:10,16,21 113:16 perform photo 32:3,13,1? 61:24 62:6 134:12 113:7 3:19 32:21 33:1 62:16,25 particularly performed photograph 33:25 34:9 63:3,9,23 89:6 124:9 112:24 34:15:20:24 64:3:11:15 parties performing 127:13,l4 35:3:10:14 64:21:25 6:4 136:6 91:19 photographer 35:20:24 65:4:9xl7 138:13,14 period 112:24 36:4:13:18 65:22 66:5 partner 12:15 16:13 113:15 36:23 37:25 66:14,18 35:1 37:19 20:8 132:2 38:4:8:12 67:2:16:23 73:23 132:16 10:17r19 38:16,20 68:5,9,15 parttime 134:23 photographic 68:19 69:5 12:4 129:1,2 permanent 112:21 40:3f7'12 69:25 70:4 party 110:16 photographs 40117,:22 42:4 Permanently 77:15 perpetrator physically 42:5?10 7336?20 passports 24:14 84:10 3::?7g??l7 34:3 perrylang picture 4? 44:12,16,22 75:21 76:5 pastrana 80:16 127:16 . 45:1,6,13 76:8,13,15 76.16 87:23 person pictures . 45:18,23 76:21,25 18:17 24:9 8:20 . 46.3,9,13 77:3,1o,23 2:6 24:12,13 piece . 46.18,23 78.8,19 patrol 45:11,21 26:21 . . . 47.4,8,l4 79.20 80.1 30:24 51:13 71:1 pxke . 77.1 104.2 47.19,23 80.4,7,9,14 Pa? 2:12 5=1r1 48:3,7,l6 80:23 81:2 20:5 51:12 104:2 6:16 13:17 . . 130.22 48.20,25 81 10,15 69.223. 92:24 49:6r10f14 PaYlng 1 20=3r6r12 49:23 50:4 82:14,21 59:4,? 104:6 9393012. 20=16r19124 50:9,13,19 83:2,9,13 payroll 35-9 ~20 21=?r8r13 50:24 51:3 83:21 84:2 25:24 personally 21:21 22:1 51:6fl4fl9 phi 47:2 137:8 22=6r30r14 51:25 52:7 85:6,10,15 78:18 PersuadEd 22:17:21 52:12 53:5 85:18,20,23 Peers 122=3 I 23=1r5r19 53:13,19,25 86:12 87:17 35:7 persuadlng 23=15r20123 54:5,11,15 87:20 88:1 penis 321:16121 24=20r24 54:20,25 88:5,18,25 69:16,17 ph 25=3r7r11 55:4,22 89:3,21 people 111:12:13:16 25:14:19 56:9,13 90:1,13,16 25:23 35:18 1l1=18 25:2r8r13 57:22 58:1 90:21 91:1 39:22 42:8 phone 26318 27:11 58:9,16,20 91:8,13,17 67:17 78:15 89:16 101:14 27?19r24 58:25 59:3 91:22,25 87:22,24 101:16:18 28=5r11r15 59:6,10,14 92:18,22 92:10 133:18 28?19122 59:19,24 93:5,11,16 101:16 134:10 29:1 3O=2r5 60:6,14,18 94:7,20 107:13 phones 30:10:14121 60:23 61:5 95:8,14,18 31:1,5,9,14 U.S. Legal Support (954) 463*2933 158 95: 96: 96: 97: 98: 99: 100: 101: 102: 103: 103: 104: 104: 105: 105: 106: 106: 107: 107: 108: 108: 113: 114: 114: 115 115: 116: 116: 117 117: 118: 119 120: 120 121 121: 122: 123: 123: 124: 124 125: 125: 126: 126: 127: 133: 21 96:2 5,9,18 23 22 98:7 14,20 6,19,25 97:18 13,20 1 18,23 7,12,21 24 4,8,15 18,23 3,7,12 17,21 1,9,12 19,24 5,10,16 23 4,8,15 19,24 17 4,8,10 22 :2,8,15 :2,11,17 24 10 :5,l4,20 9,16,19 :25 :5,8,15 25 6,18,24 6,11,17 21 6,10,16 :22,24 3,8,14 21 4,11,16 23 3,6,18 25 134:3,7,14 134:18 135:13,25 pimping 35:17 pinch 48:18 49:5 pinched 48:23 place 18:22 63:7 95:7 124:14 places 77:22 placing 44:9 plaintiff 1:6 2:2 4:22 33:21 plaintiffs 2:14 33:11 33:16 60:10 62:11 72:12 87:12 127:9 plan 17:21 90:18 plane 79:19,23 84:16 plans 110:13 played 32:24 107:18 107:25 please 4:18 5:6 pied 101:4 3:11 63:25 plus 51:18 point 7:9,16 19:20 26:10 40:9 47:25 53:10 56:18 58:18 68:17 72:2 73:8 81:7 88:11 poland 9:3 11:6 12:10 16:24 23:25 110:16,19 110:20,24 111:1 police 27:3,6 64:6 64:9 69:7 83:16 84:4 84:5,10 120:13 polish 9:24,25 politicians 35:7 78:9 pommier 130:5,7,9 132:25 133:3 poor 12:13 93:8 possession 30:25 11:4 possible 59:21 possibly 28:7 practice 35:17 predators 24:3 pregnant 95:24 96:16 96:21 97:9 97:11,14 presence 124:20 present 2:25 4:18 president 76:16 87:23 presume 109:13 113:21 pretty 61:22 71:5 83:15 preying 104:21 primary 61:12 115:1 126:24 prince 37:1,3 84:16 87:24 prior 6:2 9:15 103:8 116:15,22 120:12 123:1,7,12 124:8,13,18 124:25 125:5,11 128:7 129:23 131:14,18 prison 59 12 167:13? privilege 6:1,6,8,9 13:12 32:5 57:6,7 101:9,10 102:5,9 133:10 probably 8:25 15: 23:25 problem 14:1 87:9 process 17 5:12 63:12 procured 74:15 procures 77:2 profession 112:4 professional 1:23,24 4:2 4:3 35:8 112:23 137:5,6,14 137:15 138:5,6,20 138:20 program 11:25 129:3 promise 64:1 promised 28:24 properties 38:3 property 3826,10 propose 95:15 prosecute 107:20 prosecuted 21:16 prostituted 78:5 prostitutes 89:7,17 prostitution 89:13,19 protect 24:2 protection 108:6 provide 126:20 providing 97:20 0.8. Legal Support (954) 463*2933 159 46:11 public 4:4 137:7,16 publication 37:14 pulls 70:12 Pump 69:17,19 purchased 34:3 37:17 purported 52:10 purpose 4:12 121:23 125:24 126:7,13 purposes 33:13 100:24 108:17 120:7 pursue 17:8,20 pursuing 11:12,17 put 101:13 pyramid 51:21 76:6 qualify 96:20 question 6:10 12:13 14:17 15:10 15:16,18 16:1 19:24 29:18 56:3 60:6 63:21 70:15 74:21 77:11 102:1 113:6 124:22,24 questions 5:24 16:12 24:8 25:21 33:14 39:24 74:2 111:5 111:9 114:16 127:6 133:11 quiet 20:18,18 quit 91:19 98:17 quote 135:10 raben 2:21 rabuyo 92:9 radaronline 37:14,17,22 73:24 reer 73:21 raise 5:5 range 22:8 45:4 51:12 reaching 124:13 125:1 125:6,11 read 24:6 27:3 33:18 98:9 reading 136:5 ready 51:23 real 96:25 realize 25:21 26:23 reason 60:21 115:18 120:21 recall 7:18 8:10 9:11 10:15 16:9 111:22 111:24 131:1,16 134:13 receive 116:23 117:14 received 56:19 receives 101:19 recess 13:21 86:2 recognize 25:24 62:13 62:18 63:14 72:19 98:12 record 4:8 6:5 13:20,23 26:20 86:1 86:4 114:10 l14:13,14 114:1? 135:22 138:11 3:5 133:15 recruit 18:2,3 125:18 126:19 recruited 115:5 recruiting 126:7 redirect 3:4 127:11 refer 26:5 referred 28:3 133:23 referring 27:15 reflect 6:5 refuse 6:4,11 13:16 14:21 16:19 16:22 17:4 17:6 18:7 18:10,13,16 18:18,21,24 19:2,6,10 19:14,16,19 19:25 20:4 20:7,10,13 20:15,20,25 21:3,9,14 21:18,22,25 22:5,11,13 22:18,22 23:2,6,1l 23:16,19,24 24:5,21,25 25:4,8,12 25:15,20 26:3,9,14 26:19 27:2 27:5,10,14 27:18,25 28:4,12,16 28:20,23 29:2,5,8,12 29:14,23 30:1,6,11 30:15,18,22 31:2,6,10 31:15,20,24 32:2,14,18 32:22 33:2 33:5,7,9,20 34:1,8,14 34:21,25 35:4,11,15 35:21,25 36:3,6,14 13:13 1453: :4,12,16 :21,24 54 54 55: :12,15,18 55: 56: 56: :4,10,19 57: 55 57 17,22,25 2,5,7,12 15,18,21 :1,5,9,11 38: .138: :8,12,15 39: 40: 40: 41: 41: 42: 17,21,23 25 39:3 17,20 4,8,13 18,23 1,6,11 15,20,23 2,6,11 :14,16,18 :20,22,24 43: 43: 44: 44: 45: 45: 46: 46: 47: 47: 48: 48: 49: 49: 50: 50: :2,7,16 51: 52: 4,10,16 22 44:1 7,13,17 23 45:2 7,14,19 24 46:4 10,14,19 24 47:3 9,15,18 24 48:4 8,11,15 21 49:1 7,11,15 19,24 5,8,14 20,25 20 52:1 :14,18,20 52: :2,6,9,14 23,25 20 54:1 5,7,10 23 56:2 5,10,14 17,21 23 58:2 0.8. Legal Support (954) 463*2933 160 5758:2 6,10,13 17,21,24 2,5,9,13 18,23 :2,5,15 60: 61: 19,24 4,11,15 :20,25 62: 62: :10,16,24 :4,7,10 64: 65: 65: :1,6,10 66: 67: 67: 68: 68: 4,14,19 24 63:4 16,22 13,18,23 15,19,22 3,10,13 15,19,22 3,10,16 20,23,25 :2,6,24 70: 70: 71: 71: 72: 73: :14,19,22 73: 74: 74: 75: 75: :1,4,9,l4 76: 77: 5,10,19 23 71:3 8,14,18 22 72:1 5,20 1,3,7,10 25 74:5 10,13,16 25 75:3 7,11,16 20,23 17,22,24 4,6,14 :16,18,20 77: 78: :21,23,25 79: 79: 24 78:3 7,13,17 4,6,8,10 12,15,17 :21,25 80: 80: 3,6,10 15,17,99: 100: 100: 100: 101: 102 102: 24 81:3 5,8,11 16,19,21 :23 82:2 5,11,15 18,20 1,4,6,10 114,17,22 3,9,12 :15,19,21 24 85:3 7,11,14 :19 86:11 15,19 1,16,21 2,6,8,10 13,15,19 21,24 :4,8,11 14,18,22 :25 90:6 20,23,25 :5,9,12 16,21,24 2,4,1? :23 93:1 6,12,15 18,22,25 :2,6,11 15,19,24 3,9,13 :17,22 1,6,10 14,19,24 3,5,8,10 12,16,23 1,6,15 19,22,24 :2,5,9,13 18,22 1,4,6,8 12,16 21 2,6 :4,8,13 19,24 103: 103: 103: 104: 104: 105: 105: 106: 106: 106: 107: 107: 108: 108: 110: 114: 114: 115: 115: 116: 116: 117: 117: 118: 118: 118: 119: 119: 119: 120: 120: 121: 121: 122: 122: 123: 123: 124: 124: 125: 125: 126: 126: 127: 131: 132: 133: 3,8,13 17,20 25 5,9,14 19,24 2,8,13 16,22 2,4,8 13,16 20,25 6,9,15 22 3,9,14 20,25 7,9 1,5,9 23 3,9,16 22 2,7,14 21 3,6,12 18,25 2,4,11 13,19 21 2,6,8 15,21 25 3,10,15 20 1,4,9 14,19 1,7,13 17,25 5,10,16 22 1,5,11 12,21 4,9,13 16,22 3,10,17 22 4,17,21 12 19 11,22 134:1,8,15 134:19,24 135:14,17 regard 131:9 regarding 116:24 registered 1:23 4:2 137:5,14 138:5,20 registry 95:25 regular 123:9 126:25 reilly 55:8,11 relate 72:22 related 2:14 27:3 28:25 29:16 31:25 101:4 108:2 127:19,19 relation 12:24 relationship 30:16 58:3 66:20 83:15 relative 138:12,14 remember 14:18 42:17 42:21 68:2 69:1 70:1,8 72:25 78:14 78:20 79:1 86:25 96:11 remembered 69:13 remorse 32:23 remove 120:17,22 removed 69:9 107:7 120:11 121:11 removing 7:17 69:14 rented 67:11,14 repetitive 25:22 report 27:6 138:8 reported 1:21 reporter 1:23,24,25 3:8 4:2,3,3 4:15,l9 5:5 6:17 15:10 135:23 137:6,6,7 137:14,15 137:15 138:1,6,6,7 l38:20,20 138:21 reports 27:3 29:13 29:15 84:5 represent 4:21,25 5:4 55:14 57:21 represented 9:5,7,10,12 republic 34:18 reputation 29:21 requested 138:10 residency 7:17 resisted 94:8 .resouroe 37:14 resbonded 0.8. Legal Support (954) 463?2933 161 14:18 61:12 rest 46:16 result 5:23 resumed 13:22 86:3 reveal 56:11 review 138:9 ricardo 9:3,5 right 5:5 8:3 11:13,17 12:18 13:4 14:6,17 15:20 16:14 21:15 31:18 33:10 47:2 48:10,19,23 50:16 54:19 55:3 56:22 59:7 60:7 60:13 61:14 61:23 62:5 63:11,15 64:24 65:19 66:4 67:14 67:18 68:22 75:5 77:9 80:2.83:18 86:6,25 88:14 89:10 89:13 93:4 93:21 94:1 94:5,10,23 95:1,2,20 95:25 97:2 101:23 102:1 103:11 111:4,4 127:22 129:9,14 131:3,24 132:5 133:5 133:12 135:6,18,2l ring 91:7,20 102:21 ringing 101:22 ripped 70:6 rising 102:21 ritual 44:4 47: 48:17 robbins 2:20 roberts 33:6,8 tobson 125:15,18,24 126:6 rodriguez 92:9 role 32:23 39:2 63:7 107:18 107:25 roll 48:9 romantieally 12:21 room 82:12,13 roshan 73:21 127:14 toss 1:13 2:20,24 3:2 4:13 5:3,4,4,11 5:16 6:17 7:2,8 8:2,5 13:11,19,24 14:2,11,14 25 16:17 21:17 24:4 29:18 29:22 32:4 33:15 44:2 57:6,14,18 59:8 60:9 72:9,11,16 73:13 74:8 77:11 87:4 87:7,11 101:9,16,21 101:23 102:5,9 104:10 109:4,7,18 109:22,24 110:4,11,14 111:2,9,10 131:7,9 132:24 133:3,7,10 135:20 137:8 138:9 routine 66:7 roy 55:13 royalty 35:7 87:24 1:22 138:19 rub 125:11 rubbed 124:4 rules 15:7 run 66:17 running 66:13 8 sake 14:4,12 74:18 salary 20:5 san 34:5 sandy 81:4 sanka 106:3 santa 34:5 sarah 18:14 20:21 28:8 39:1 40:1,6 41:25 44:9 46:22 56:15 61:13 75:14 78:16 80:12 92:9,12 96:3,7,11 99:23 100:2 103:6 115:1 126:12,18 saved 31:17 saves 74:6 saving 14:5 saying 14:4 15:13 63:18 66:24 67:5,24 says 24:9 65:20 92:20 scare 60:3 64:19 scared 21:19 91:15 scary 93:24 schedule 27:20,23 63:21 68:6 116:10,16 117:8 122:9 122:16 134:2 scheduled 61:1 schedules 39:9 68:6 scheduling 61:7 102:14 107:3 116:24 125:25 126:24 scheme 90:2 93:2 98:10 school 11:2,5 17:8 71:24,25 89:10 111:18 115:12 127:23 128:24 129:2 131:21 schools 126:7 scientist 111:16 113:1 scream 66:17 screamed 69:20 screaming 66:13 sean 2:25 4:16 search 53:11,16,17 56:1 57:1 81:13 107:8 120:12 second 9:6 13:17 24:15 110:23 U. S. (954) Legal Support 463~2933 162 114:11 secret 75:12 101:18 section 76:7 see 10:17,18 45:21 60:7 62:16 66:16 127:18 seen 22:2 25:5 30:23 31:21 33:15 44:24 49:12 54:13 75:8 93:17 94:1 6:1,7 14:6 send 10:18 36:19 sent 36:8,10 sepaxate 77:7 104:1 separation 82:13 september 63:18 133:19 134:11,17 135:9 sergio 100:7 serial 98:13 service 75:13 89:20 97:21 services 91:20 113:7 serving 112:7 set 41:17 45:11 65:7 109:1 setting 61:13 sex 19:12 22:12 22:15,19 23:13,18 25:10 27:1 28:2,10,14 29:7,10,17 29:21 33:4 34:12,23 35:2,6,23 37:24 38:18 39:6 49:21 49:25 50:10 54:8 69:13 75:18,25 76:3,10,18 78:11 80:19 80:21,25 82:17 83:12 85:1,17 95:20 99:15 99:20,23 100:11,19 100:24 104:22 105:5,10,19 124:9 2:17 sexual 21:24 22:8 22:24 24:3 24:3 26:11 26:15 30:16 35:18 51:10 69:12 101:4 108:2 115:7 115:14 116:6,12,18 118:16 119:1 120:23 121:18,23 122:4 123:13 126:9 134:22 sexually 22:3 23:4 25:13 27:8 36:10 41:3 41:8,13 43:1 52:6 52:16,22 53:3 64:2 68:12 71:1 71:20 96:21 97:1 102:17 108:18,23 sh 78:16,22 shaking 15:12 shared 65:12 shes 14:4,5 99:14 110:21 132:24 shore 14:24,25 15:1,22 16:2 55:20 109:8 show 46:20 62:7? 72:16 showed 8:20 48:1 74:1 shown 106:17 shows 74:19 92:21 sic 4:10 side 60:17 sides 94:1 sign 21:1 signed 137:10 signing 136:5 similar 135:3 simply 6:3 single 26:21 50:16 66:8,8 74:1 105:10 sir 101:17 sister 109:20 110:2 sjobexg 88:20 skipping 63:12 slave 75:25 76:3,7 76:10 99:15 slaves 33:4 solemnly 5:7 somebody 27:20 33:6 40:1 43:6 43:11,17 46:1 52:15 52:21 53:1 60:21 67:20 68:12 70:14 74:14 75:24 76:18 78:16 79:18 80:18 81:6,17 82:3 85:1 88:22 89:2 96:20 98:23 100:9,16 106:5 133:1 someones 82:23 somewhat 94:13 107:25 30011631: 90:24 soxry 16:1 68:24 82:19 110:1 119:25 120:1 131:8 132:6 133:9 sort 82:13 sought 102:20 sound 25:21 south 9:11 14:24 14:25 15:1 15:22 16:2 55:20 109:8 113:23 128:13,l4 southern 1:1 5:19 southwest 2:21 Spain 112:12 speak 13:18 63:19 specific 27:23 45:11 46:2 48:17 specifically 6:10 100:23 speeding 83:25 spell 110:22 130:8 spend 59:20 spoke 36:9 122:8 spoken 36:5 0.8. 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Legal Support (954) 463?2933 168 68:1 86:17 86:22 135:11,16 300 51:4 301 13:15 14:20 19:8,17 77:21 78:2 303 2:10 305 2:17,23 31 5:15 3lst 56:25 33 3:14 86:1,2 110:20 33129 2:22 33141 109:12 33160 2:16 33301 1:19 333013268 2:5 33401 2:11 358 38:6 3rd 1:18 4:11 78:14 135:9 4 4 3:19,25 63:17 65:20 65:25 67:12 68:1 86:9 86:20,22 87:7 116:15 116:24 119:4,7,10 119:17 123:19,24 124:3,8,9 124:13,19 127:8:9 133:21 134:17,20 135:11,16 135:16 400 2:10 42 1:17 135:22 136:4 425 2:4 43 86:3,4 4s 124:4,14 4th 2:22 63:18 5 5 118:3,7 50 43:24 79:23 123:14 135:9 515 1:18 4:10 524 2:5 561 2:11 6 6 118:12,18 62 3:16 66th 13:15 14:20 19:8,18 77:21 78:2 6th 128:15 7 7 3:3 7:23,24 63:18 117:4 117:5,7,8 117:13,14 119:24 128:1 125:1 125:6,11 72 3:17 75 43:24 51:18 73 125:7,12 8 8 4:25 86:17 120:6,6 135:9 803 29:16 83 I 7:24 842 2:11 858 2:23 87 3:18 87page 27:6 8th 89:9 128:16 9 9 4:10 63:17 65:20 66:23 67:5,24 86:9,9,16 86:17,28 134:11 903 8:24 29:16 931 2:17 954 2:5 9550 2:23 98 8:25 99 8:25 9th 89:9 8.8. Legal Support (954) 463*2933 DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et al. Case Na: 50 2009 CA 040800WMBAG ATTACHMENT 14 Page 1 Page 3 UNITED STATES DISTRICT COURT 1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT SOUTHERN DISTRICT OF FLORIDA 2 IN AND FOR FALM BEACH COUNTY, FLORIDA CASE NO 08 CW 80119 CASE NOJANE DOE NO. 2, 5 plaintiff Plaintiff 6 wo VOLUMEEOFHI ?vs- VOLUME I OF JEFFREY EPSTEEN, 7 Defendant. 8 Defendant. I 9 Related cases: . 1 08~80232, 08-08380, 08450381, 08?80994 1 1 08?80993, 08-80811, 09-80469 12 1353905310}: 05' 09430591, 09?80656, 09?80802, 09?81092 I 13 SARAH KELLEN 14 VIDEOTAPED OF 1 5 24? 29 SARAH KELLEN 6 pm? Wednesday, March 24, 2010 17 . 10:37 - 551 pm, 1 8 250 Australian Avenue South 250 Australian Avenue South 3. 9 West Palm Beach, Fiorida 33401 Suite 1500 2 0 West Paim Beach, Fiorida 33401 2 1 2 2 Reported By: Hopkins, RPR, PPR gaggiin Rm Fm 2 3 Notary Public, State of Flo?da Notazy Pubiio, State of Florida 2 4 Prose Cfm? Reporting services Prose Court Reporting Services ?nab 1484 mbNo:om4 25 Page 2 Page 4 1 IN THE COURT OF THE 15TH IUDICZAL CIRCUIT 1 EN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL ZN AND FOR PALM BEACH COUNTY, FLORIDA ZN AND FOR PALM BEACH COUNTY, FLORIDA 2 CASE NO. AD 2 CASE Piain?tiff, Plaintiff, 6 ?vs? VOLUME 1 OF IE1 5 7 6 ~ve JEFFREY 7 JEFFREY 8 AND SARAH KELLEN, Defendant. 8 9 r; Defendants. 13 i; f; @5531? SET ION 0F 1 1 VIDEOTAPED 09 3 3.2 SARAH KELLEN 13 14 wiggdagjgfai? 24? 2010 14 Wednesday, March 24, 2010 9' :2 1 7 250 South 250 Australian Avenue South . Suite 1500 :3 West 81111 3383011: Ronda 33491 18 West PaIm Beach, Florida 33401 Reported By: 22 Reported By: Hookins, Fm? Hopkins, RPR, FPR 2 3 Notary Pubhc, State of Fiorgda 2 3 Notary Public, State of Fiorida Prose Court Reportmg Semees Prose Court Reporting Services 2 4 Job No; 1484 24 .Eob No; 1484- 2 5 2 5 (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. mammammi smegma wtmasm?uxx ?115:2 mama:me ?tm?m N255 ?JEi?E??s??m R?immlmiia?w?i? Pi mama? 33 5; {4&1 xoxememtww? 334m? - Jaym?mzx-w a?emwmw? -1 . Womaamemwm??mmk mwh??rcd?. ?lm 5 1 (Pages 1 to 4) (561) 832-7506 Page 5 Page 7; 1 APPEARANCES: 1 2 . On behaif of the Plaintiffs, 13.3.: 2 3 SPENCER T. KUVIN, ESQUIRE 3 LEOPOLD KUVIN 4 4 gg?? Boulevard 5 EXAMINATION DIRECT CROSS REDZRECT 6 5 Paim Beach Gardens, Flonda 33430 Phone: 561.515.2400 ,3 SARAH KELLEN 6 7 0o behaif of the E?Iaintiffs, LM, ow. and BY MR- KUVIN 9 Jane Bee: 8 8 9 9 MATTHEW BSQUIRE 10 I 1T 3 FARMER, JAFFE, WEISSING, EDWARDS 1 1 1o 12 1 1 gz?tNgr?t Andrews Avenue 1 3 EXHIBIT DESCRIPTION PAGE u: 1 4 Fort Leuderdale, Fiorida 33301 1 12 Phone: 954.524.2820 15 1 PHOTO 16 3.3 On behaif of Jane Does 1 through 8: 2 24 14 ADAM nonomrz, ESQUIRE MANIFEST MEMLSTEIN HOROWFTZ, Mg 16 PLAINTIFF 8 ex. 3 HYPERION AER, INC, 15 38205 Biscayne Boulevard PASSENGER MANIFEST Suite 222 8 7 EX. 6 PHOTO 63 16 Miami, Florida 33150 EX. 7 PHOTO 65 Phone: 305.931.2200 18 Ex. 8 PHOTO 68 17 E-maii: Ahorowitz@sexabuseattomey.corn EX. 9 PHOTO 7E 3.8 On hehaif of the Plaintiffs, 10?, 102 and 103: 19 PLAINTIFFS Ex 19 100 19 PHOTO 101 2 ORSECEK 5?3?ng 20 EX. 12 PHOTO 103 25 West ?agler Shea PLAINTIFFS EX. 4 PHONE MESSAGE PADS 21 Suite 380 2 1 EX. 5 RECORDS Miami, amid, 33; 3g EX. 13 PHOTO 144 22 Phonoz30535ezsoo 22 23 (Via telephone) 23 24 24 25 25 Page 6_ Page 8: 1 Appearances I i 5 2 On behalf of the Plaintiff, Jane Doe E1: 2 3 ISIDRO MANUEL GARCLA, ESQUIRE GARCIA, ELKINS BOEHRINGER 3 THE VIDEOGRAPHER: We are now on video a; 224 Datum Avenue, Suite 900 - - West Palm Beach: Fiorida 33401 4 record-.2135 rs Medza NO. the vrdeotaped 5 phone: 561.832.8033 5 deposmon of Sarah Kelien the matter of Obh??thdt 6 hmmewwM??wEmwmamo??JACK ALAN GOLDBERGEK ESQUIRE 7 13 Wednesday, March 24th, 2010. It IS ATTERBURY, GOLDBERGER PA. 8 10:36 am. We are here at Prose Court 9 3333*? Avenue south 9 Reporting, 250 South Australian Avenue, West 10 West PaEm Beach, Florida 33401?5012 1 0 Palm Beach Fim?ida- 11 Phone: 561.659.8300 1 1 My name is Kozak. I?m the 12 12 videographer. The reporter is Cindy 13 On behaif ofthe Witness: 13 Hopkins from Prose Court Reporting Agency. 1 4 BRUCE E. ESQUIRE 1 4 LAW OFFICE OF BRUCE E. would counsel please muoauce 1 5 One Clearlake Camer 1 5 yourseives, and then the court reporter 250 South Austraiian Avenue, Suite 1400 1 6 win swear in the Witness, :6 West Paim Beach, Florida 33401 . - Phone: 5612026360 1 7 MR. KUVYN. Good moromg. Spencer Kuvm 3. 7 1 8 on behaif MR. 1101101112112: Adam Horowitz on ooharf of f- 29 ALSO PRESENT: 2 0 Liane Does 2 through 8. And just for the record 2 1 Jessica Cadweli, Parai?egai 2 1 purposes, the deposition is also being taken in Barman, Critton, Luther ColemanJoseph Kozak, Videographer em 68865, leve, case 6mg Prose Court Reporting Services 2 3 Earle Bee 2 versus Jeffrey Epstein. g: 2 4 MR. WEISSING: Matt Weissing on behalf of 2 5 three of the Piaintiffs. . '35. ,4 3: memoweezee? 2 (Pages 5 to 8) {561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-4506 .3 Page 9 Page 11 1 MR. GARCIA: Sid Garcia for Jane Doe, privilege. 2 Roman Numerai ii. 2 MR. I?ll agree with that 3 MR. GOLDBERGER: Jack Goldberger on behalf 3 procedure. 4 of Jeffrey Epstein. 4 MR. RHEINMRT: Anyone object to that 5 MS. Jessica Cadwell, paralegal, procedure? 6 on behalf of Jeffrey Epstein. 6 MR. GOLDBERGER: Actuaily I think if, in 7 MR. Bruce Rheinhart on behalf 7 fact, this deposition is used in a trial, i 8 of the witness, Sarah Keilen. 8 think you wouid want the lengthier answer as 9 MR. KUVIN: Kathy, your turn. 9 being the answer that is played to the jury. 1 0 MS. EZELL: Okay. Kathy Ezell and Amy 1 0 So either you guys can agree that it gets cut 1 Ederi on behalf of Plaintiff, Jane Doe 103. in or she's going to have to -- i can?t tell l2 Thereupon, 12 you what to do, but I would suggest that she 3 (SARAH KELLEN) 3 give the lengthier answer each time. 1 4 Having been first duly sworn or affirmed, was 1 4 But there?s got to be a way that you 1 5 examined and testi?ed as follows: 1 5 guys can reach an agreement though, that 1 6 DIRECT 1 6 from a technoiogy perSpeetive, that the 1 7 BY MR. KUVIN: 7 answer that shejust gave would be 1 8 Q. Good morning. 3. 8 used during any trial testimony. Can that 1 9 A. Morning. 1 9 he done? .2 0 Q. Could you give us your full name, please. 2 0 MR. KUVIN: I don't know procedurally A. Sarah Kellen. 2 1 whether it can be done. i 2 2 Q. Do you have a middle name? 2 2 MR. I think -- 2 3 A. Lynneile. 2 3 MR. I don't know that, well '2 a Q. Would you Speli that for us? 2 4 MR. GOLDBERGER: And again, itit?s not my deal. I?m just telling you how i Page 10 Page 12 :1 Q. What?s your current address? 1 we?ve done it in the past. 2 MR. RHEINHART: I?m going to instruct the 2 MR. i hear you, and i have a '3 witness not to answer that question on the 3 number of issues primary, primarily 0f WhiCh 113 basis of her Fifth and 14th Amendment 4 that you?re not here to represent anyone i- ,5 privileges against self-inerimination. 5 currently. ?26 MR. KUVIN: Okay. We had spoken before 6 MR. GOLDBERGERI Yeah: I 3111- I'm .7 with respect to there are liker going to be 7 actually, i?m actually here representing '28 answers similar to that throughout this 8 Jeffrey Epstein, ,9 deposition. I have agreed to a procedure that 9 MR. KUVIN: Okay. With reSpect shortened answer. However you want 3. 0 civil cases, though, you're not here to to handle that, I leave it up to you. But i do 1 1 represent anyone, so 33:2 agree that whatever the shortened answer is, 1 2 MR. GOLDBERGER: Yes, I am- . that it will satisfy the length, answer 1 3 MR. With the exception -- ,3 {hat she would like to give. 1 4 MR. GOLDBERGER: I represent -- want to do that with this 1 5 don?t mean to interrupt you, but I am counsel question, or :how do you want to handle 1 6 of record in the civil cases. that procedurally? 1 7 MR. KUVIN: Okay. Okay. MR. RHEINHART: Well, i think I have given 1 8 MR. RHEINHART: if we have a stipulation, the instruction. '1 think she, wilt give her 1 9 what?s the problem? Are you -- .. the same instruction in the ?iture to the 2 0 MR. KUVIN: There is none. .. a .that'itfs relevant, and I think that if 2 1 MR. MWRY: - worried about a waiver? ?g wecan-alljustagree that ifshe simply says 2 2 MR. GOLDBERGBR: No, I?m not worried about or {simply say "ifhe Fifth Amendment,? that 2 3 that at ali. i?m worried about what is played ,1 will qualify aslg'i-yiing a .-.snfficient answer to 2 4 to a jury if this gets tried. [tin-i I. wwasmattrolaw, and wiil invoke that 2 5 Skiy. prgfeciate you i_ 3 {Pages 9 to 12) E832e755'059 PROBE COURT RE PORT ING AGENCY INC . (5rteammate;Winemaamm?ewmwm. mammal, Mame Mew WW emammwr'? r: imm?mmtewwa gamma . gamma ?mam JIZ ivMiIW .- Page 13 Page 15 1 coaching Bruce, but i think he can handle 1 I choose to invoke my Fifth Amendment right. 2 himself pretty adequately now -- 2 BY MR. KUVIN: 3 MR. GOLDBERGER: I have -- 3 Q. Would you agree with me that you're 4 5 MR. GOLDBERGER: i have ali the con?dence I 5 MR. Same instruction. 6 in Bruce. 6 THE WITNESS: On the advice of my lawyer, - 7 MR. KUVIN: Mr. Rheinhart, with respect to i must invoke my Fifth Amendment right. 8 how you want to handie it, I think we have an 8 BY MR. 9 agreement. 9 Q. Would you agree with me that your eyes are 1 0 MR. I?m satis?ed that we have 1 0 hazel? 1 1 a stipulation, and I assume if there is ever a 1 1 MR. Same instruction. 1 2 triai, that would be played or produced to the 12 THE WITNESS: On the advice of my lawyer, 13 jury that simply by using shorthand, what she?s 13 I choose to invoke my Fifth Amendment right. 1 4 reaiiy saying is the lengthier answer now. Pro 3. 4 BY MR. KUVIN: 1 5 satisfied with that. 15 Q. Would you agree with me that you were born 1 6 MR. KUVIN: And I agree with that. 1 6 in HawaiiMR. Same instruction. IL 8 Q. Okay. Ma'arn, what is your current 1 8 THE WITNESS: On the advice of my lawyer, 9 address? 1 9 i choose to invoke my Fifth Amendment right. 2 0 MR. RHBINHART: Again, I wili instruct the . 2 0 BY MR. 2 1 witness not to answer the question. 2 1 Q. What are the names of your parents? 2 2 THE WITNESS: On the instruction of my 2 2 MR. Same instruction. 2 3 lawyer, i choose to invoke my Fifth Amendment 2 3 THE WITNESS: On the advice of my lawyer, 2 4 right. 2 4 i must invoke my Fifth Amendment right. 25 25 Page is Page 16 3. BY MR. KUVIN: 1 BY MR. KUVIN: 2 Q. What is your current phone number? 2 Q. Are you married or single? 3 MR. RHEINHART: Same instruction.? 3 MR. RHEZNHART: Same instruction. 4 THE WITNESS: On the advice of my iawyer, 4 THE WITNESS: On the advice of my lawyer, it 5 i choose to invoke my Fifth Amendment right. I 5 I must to invoke my Fifth Amendment right"(Plaintiff?s Exhibit No. was marked for '7 What?is your cellphone number? 7 - identification.) 8 MR. RHEINHART: Same instruction -- 8 MR. I'm going to show you what 9 THE WITNESS: On the advice of my lawyer, 9 we?ll mark as Plaintiffs Exhibit E. 1 i choose to invoke my Fifth Amendment right. 1 0 And i?ll ask the videographer to zoom 1 1 MR. RHEINHART: You have to let me Speak 3. in here for a second. 1 2 before you answer in case there?s an objection 2 BY MR. KUWN: 13 or any of the other iawyers have an objection. 1 3 Q. Okay. Ma?am, i am going to show you a 14 BY MR. KUVIN: 1 4 photograph we?ve marked as Plaintiff?s Exhibit 1 and 3.5 Q. i am going to show you a photographyou recognize this registered sex 1 6 what is your date of birth? 1 6 offender. 17 MR. RHEINHART: Same instruction. 1 7 MR. RHEINHART: First, object to the form 1 8 THE WITNESS: On the advice of my lawyer, 18 of the question. It assumes facts not before 1 9 i choose to invoke my Fifth Amendment right. 9 the witness, and i'll give the witness the same 2 0 MR. KUVZN: Let?s make is easier. 2 instruction as to that questionthe advice of my lawyer, 2 2 Q. Ms. Kellen, would you agree with me that 2 2 i must invoke rny Fifth Amendment right. 23 your date of birth is May 25th, 1979? 23 BY MR. KUVIN: 2 4 MR. RHEINRART: Same instruction. 2 4 Q. Wonid you agree with me that this 2 5 THE WITNESS: On the advice of my lawyer, 25 registered sex offender's name is Jeffrey Epstein? (561) 832-7500 PROSE COURT REPORTING AGENCY, ?'?ii?iat?mi new? M-"ermr .m mm, {m mam (rm?-?gwgRoentgen; attenuators/ts awnings-orator nuswaitress;?zeimzmw?enm teases: new: madman-5 m; aanaarmarwmamnearer:er (sitit?ht?o?s?? W?icszi?w?i?zii?t?ii?i?rti? 4 (Pages 13 to 16) INC. (561) 832?7506 11m it .. [579? Page 17 (561) the form of the 832-4500 1 MR. RHBINHART: Same instruction, same 1 question. It's ambiguous and compound, and I 2 objection. 2 will instruct the witness not to answer based 3 THE WITNESS: At the advice of my lawyer, 3 on her Fifth Amendment privilege. 4 i must invoke my Fifth Amendment right. 4 THE On the advice of my lawyer, 5 BY MR. 5 i must invoke my Fifth Amendment right. 6 Q. Would you agree with me that Jeffrey 6 BY MR. KUVIN: 7 Epstein is a sexual offenderthat? 8 MR. Object to the form of the 8 MR. Object to the form. It's 9 question and instruct the witness not to answer 9 ambiguous, in fact that what? 1 on her Fifth Amendment privilege. 0 BY MR. 1 1 THE WITNESS: On the advice of my iawyer i 1 1 Q. Why did you bring minor girls to 1 2 must invoke my Fifth Amendment right. 12 Jeffrey Epstein for him to have sex with? 13 BY MR. 13 MR. Same objection as to form 1 4 Q. Would you agree with me that 1 4 and instruct the witness not to answer. i 1 5 ieffrey Epstein sexually abused you? 1 5 HE On the advice of my lawyer, 3. 6 MR. RHBINHART: Objection to the form, 21. 6 i must invoke my Fifth Amendment right. 17 both as to the form of the question as to '7 BY MR. 8 harassing and instruct the witness not to 8 Q. What do you currently do for a job? 1 9 answer, based on the Fifth Amendment privilege. 3. 9 MR. RHEINHART: instruct the witness not 2 8 THE WITNESS: On the advice of my lawyer, 2 0 to answer the question. 2 1 i must invoke my Fifth Amendment right. 2 3. THE WITNESS: On the advice of my lawyer, 2 2 BY MR. KUVTN: 2 .2 I must invoke my Fifth Amendment right. 2 3 Q. Would you agree with me that you were a 2 3 BY MR. KUVIN: 2 4 minor when Jeffrey Epstein first had sexual 2 4 Q. Would you agree with me that you currently 2 5 relations with you? 2 5 work for 3effrey Epstein? Page 3.8 Page 20 1 MR. RHEINHART: Object to the form. it 1 MR. RHEINHART: instruct the witness not 2 assumes facts not before the witness. it is a 2 to answer the question. 3 compound question and I would instruct the 3 THE WITNESS: On the advice of my lawyer, ?1 witness not to answer based on her Fifth 4 I must invoke my Fifth Amendment right. 5 Amendment privilege. 3 BY MR. KEVIN: 6 THE WITNESS: On the advice of my lawyer, 6 Q. How long have you worked for 7 i must invoke my Fifth Amendment right. 7 Jeffrey Epstein? 8 BY MR. KUVIN: 8 MR. Same instruction. 9 Q. Would you agree with me that you have had 9 THE WITNESS: On the advice of my lawyer, 0 sex with Jeffrey Epstein? I must invoke my Fifth Amendment right. 1 1 MR. Same instruction. 1 1 BY MR. KEVIN: 1 2 THE WITNESS: On the advice of my lawyer, 12 Q. Would you agree with me that you?ve worked 1 3 i must invoke my Fi?h Amendment right. 3.3 for Jeff, Eeffrey Epstein for over 20 years as his 4 BY MR. KBVIN: 3. 4 personal assistant? 5 Q. Would you agree with me that you first had 1 5 MR. RHEINHART: Instruct the witness not 1 6 sex with .ief??ey Epstein when you were under the age 1 6 to answer the question. 3.7 of 18? 1 7 THE WITNESS: On the instruction of my 1 8 MR. RHEEJHART: Same instruction. 1 8 lawyer, i must invoke my Fifth Amendment right. 1 9 THE WITNESS: On the advice of my lawyer, 9 BY MR. KUVIN: 2 i must invoke my Fifth Amendment right. 2 0 Q. Would you agree with me that when you 2 1 BY MR. KUVIN: 2 1 ?rst were hired by Jeffrey Epstein as his personal 2 2 Q. Would you agree with me, ma'am, that you 2 2 assistant, you were under the age of 18? 2 3 brought numerous underage girls to Jeffrey Epstein 2 3 MR. RHEINHART: Object to the form. It?s 2 ?it so that he could have sex with them? 2 4 compound and assumes facts not present before 2 5 PROBE COURT REPORTING AGENCY, the witness, and I instruct the witness not to 7-. 32mm tires me; ?it airtight-y}? sysah?regttgay? greatest ?that? t! We tax We as: av; rr?rw?t?daemm't eta: 3-: game 5 (Pages 17 to 20) (561) 832*?506 INC. Page 2 Page 23 1 answer the question based on her Fifth 3. witness, and i will instruct the witness not to 2 Amendment privilege. 2 answer based on her Fifth Amendment privilege. 3 THE WITNESS: On the instruction of my 3 THE WITNESS: On the instruction of my 4 lawyer, i must invoke my Fi?h Amendment right. 4 lawyer, I must invoke my Fifth Amendment right. 5 BY MR. KUVIN: 5 BY MR. 6 Q. Who introduced you to Jeffrey Epstein the 6 Q. Would you agree with me that 7 first time that you met him? 7 Jeffrey Epstein owns numerous planes, private 8 MR. RHEINHART: Same instruction. 8 planes? 9 THE WITNESS: 0n the instruction of my 9 MR. RHEZNHART: instruct the witness not i lawyer, i must invoke my Fifth Amendment right. it 0 to answer. 1 BY MR. KUVIN: 1 THE WITNESS: On the instruction of my 3. 2 Q. Did Ghislaine Maxwell introduce you to it 2 lawyer, i must invoke my Fifth Amendment right. 13 Seffrey Epstein for the first time? 13 av MR. KUVIN: 1 4 MR. Same instruction. 1 4 Q. And you?ve been on every one of those 1 5 THE WITNESS: On the instruction of my 5 private pianos; isn't that true? ll 6 lawyer, i must invoke my Fifth Amendment right. 3. 6 MR. RHBINHART: Object to the form. it 3.7 BY MR. KUVIN: 3.7 assumes facts not before the witness, and i 1 8 Q. When was the first time you were in 8 will instruct the witness not to answer based 9 Jeffrey Epstein?s home located on El Brillo Way on 1 9 on her Fifth Amendment privilege. 2 0 Palm Beach Island? 2 0 THE WITNESS: On the instruction of my 2 1 MR. RHEINHART: Object to the form of the 2 lawyer, i must invoice my Fifth Amendment right. 2 2 question as compound and assuming facts not 22 BY MR. KUVIN: 2 3 before the witness. And i instruct the witness 2 3 Q. Ma'arn, isn't it true that you?ve seen the 2 4. not to answer based on her Fifth Amendment 2 4 passenger manifest for ieffrey Epstein?s plane? 2 5 privilege. 25 MR. answer; Object to the form. Page 22 Page 2 4 1 THE WITNESS: On the instruction of my 1 assumes facts that are not established as known 2 lawyer, I must invoke my Fifth Amendment right. 2 to this witness, and I instruct the witness not 3 BY MR. KUVIN: 3 to answer the question based on her Fifth 4 Q. Would you agree with me that 4 Amendment privilege. 5 Jeffrey Epstein owns a home at 358 BI Brillo Way, 5 THE, WITNESS: On the instruction of my 6 Palm Beach Island, Florida? 6 lawyer, i must invoke my Fifth Amendment right. 7 MR. RHEINBART: instruct the witness not 7 MR. KUVIN: Let me show you what we'll 8 to answer based on her Fifth Amendment 8 mark as Exhibit 2. 9 privilege. 9 3. 0 THE WITNESS: On instruction of my 1 0 (Plaintiffs Exhibit No. 2 was marked for 1 i counsel, 1 must invoke my Fifth Amendment 1 1 identi?cation.) 3. 2 right. 12 MR. KUVIN: Thank you. 3 BY MR. KUVTN: 1 3 MR. Do you want to zoom in on 1 4 Q. Would you agree with me that you've been 1 4 it like you did the last time? 1 5 in that home numerous times? 1 5 MR. KUVIN: No, that?s ?ne. 6 MR. RHERJHART: instruct the witness not 1 6 MR. RHEINHART: Take your time. 17 to answer the question based on her Fifth 1 7 MR. KUVIN: And flip through. 1 8 Amendment privilege. 1 8 BY MR. KUVIN: i 9 THE WITNESS: On instruction of my iawyer, 9 Q. All right. Ma?am, would you agree with me 2 {3 i must invoke my Fifth Amendment right. 2 0 that this is a passenger manifest for one of 2 1 BY MR. KUVIN: 21 Jeffrey Epstein's airplanes? 2 2 Q. Would you agree with me that you have gone 2 2 MR. Instruct the witness not 2 3 on Jeffrey Bpstein?s plane numerous times? 2 3 to answer the question based on her Fifth 2 4 MR. Object to the form. It 2 4 Amendment privilege. 2 5 assumes facts that are not present for the 2 5 THE WITNESS: On the instruction of my 6 (Pages 21 to 24) (561) 832~7500 PROBE COURT REPORTING AGENCY, INC. (561) 832?7506 Page 25 Page 27 lawyer I must exercise my Fifth Amendment 1 Amendment privilege. 2 right. 2 THE WITNESS: On the instruction of my 3 BY MR. KUVIN: 3 lawyer, I must invoke my Fifth Amendment right. 4 Q. And would you agree with me that you 4 BY MR. KUVIN: 5 appear as a passenger on these ?ight manifests on 5 Q. Would you also agree with me that the two 6 numerous occasions? 6 unknown females listed on the passenger manifest 7 MR. RHEENHART: Object to the form. It 7 marked as Exhibit 2 were underage girls, under the 8 assumes facts not established as known to this 8 age of 18? 9 witness, and instruct the witness not to 9 MR. Object to the form. It 3. 0 answer the question. 1 0 calls for speculation. Also it?s not been 3. 1 THE WITNESS: On the instruction of my 1 1 established this witness has any knowledge of 12 lawyer, I must exercise my Fifth Amendment 12 this document and instruct her not to answer 23 right. 1 3 based on her Fifth Amendment privilege. 4 BY MR. KUVIN: 1 4 THE WITNESS: On the instruction of my 1 5 Q. Would you agree with me that your name 1 5 lawyer, i must invoke my Fifth Amendment right. 1 6 does, in fact, appear on the passenger manifest for 6 BY MR. KUVIN: '7 these planes, for this plane? 1 7 Q. Would you agree with me that the girls 1 8 MR. RHEINHART: Same objection and same 1 8 that are listed as females one, and the second 1 9 instruction. 3. 9 female for this flight of January 11, 2005, from 2 0 THE WITNESS: On the advice of my lawyer, 2 0 West Palm Beach to the US. Virgin islands, that 2 I must invoke my Filth Amendment right. 2 1 those two females were under the age of 17? 22 BY MR. KUVIN: 22 MR. RHEINHART: Same objection. it has 2 3 Q. Who are the two females that appear on the 2 3 not been established the witness has any 2 4 passenger manifest for January 1 l, 2005, on the 2 4 knowledge of this document. It calls for her 2 5 ?rst page of Exhibit 2? 2 5 to speculate, and I instruct her not to answer Page 26 Page 28 1 MR. l'll object to the form, 1. based on her Fifth Amendment privilege. 2 and it has not been established this witness 2 THE On the instruction of my 3 knows anything about this document, and I wili 3 lawyer, I must invoke my Fifth Amendment right. 4 instruct her not to answer based on the Fifth 4 BY MR. KUVIN: 5 Amendment privilege. 5 Q. Would you agree with me that the two 6 THE WITNESS: On the instruction of my 6 females shown on the flight with you of January 1 l, 7 lawyer i must invoke my Fifth Amendment right. 7 2005 were under the age of 16? 8 BY MR. KUVIN: 8 MR. RHEINHART: Same objection as to form. 9 Q. Do you agree with me that you took a 9 It has not been established this witness knows 1 0 ?ight on Jeffrey Epstein?s plane from West Palm 1 anything about whether there were these 1 1 Beach to the US. Virgin Islands, St. Thomas on 1 witnesses, these females and who they are, so 1. 2 January ll, 2005? 1 2 it's asking her to speculate, and I instruct 13 MR. RHEENHART: Instruct the witness not 13 her not to answer based on her Fifth Amendment 3. 4 to answer the question based on her Fifth 1 4 privilege. 1 5 Amendment privilege. 1 5 THE WITNESS: On the instruction of my 1 6 THE WITNESS: On the instruction of my 1 6 lawyer, i must invoke my Fifth Amendment 1 7 lawyer i mustinvolce my Fifth Amendment right. 1 7 privilege. 18 BY MR. KUVINWould you agree with me that on that 1 9 Q. Ma?am, you were on that ?ight of 2 0 flight were you, Jeffrey Epstein, Nadia Marcinkova 2 ianuary ll, 2005, were you not? 2 and two unknown females? 2 3. MR. RHEINHART: I instruct the witness not 2 2 MR. RHEINHART: Object to the form. Again 22 to answer based on her ifth Amendment 2 3 assumes facts that have not been established 2 3 privilege. 2 4 this witness has any knowledge of and instruct 2 4 THE WITNESS: On the instruction of my 2 5 2 5 lawyer i must invoke my Fifth Amendment right. ceijz?irifg?ksz 3x332} A: ittvf?gs'ei'arnw?s?m (561) the witness not to answer ba 832~7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?37506 ?mith . \n cameraman; Mn ma thin??th ?ll; >r a i: out. tear mm: 7 (Pages 25 to 28) Page 29 Page 31 MR. RHEINHART: Same instructionYou also agree with me that the two girls 2 THE WITNESS: On the instruction of my 3 that are listed as on that flight with you of 3 lawyer, 1 must invoke my Fifth Amendment right. 4 January ll, 2005, were under the age of l5 years 4 BY MR. KUVIN: 5 old? 5 Q. Who is Dana Burns? . I 6 MR. RHEINHART: Object to the form. it MR. RHEINHART: Same instruction. 7 calls for speculation, lack of personal 7 THE WITNESS: On the advice of my lawyer, 8 knowledge, and instruct the witness not to 8 I must invoke my Fifth Amendment right. 9 answer based on her Fifth Amendment privilege. 9 BY MR. KUVIN: 1 0 THE WITNESS: On the instruction of my 1 Q. Who is Mark Zeff. 1 lawyer, I must invoke my Fifth Amendment right. . 1 MR. RHEINI-IART: Same instruction. 12 BY MR. KUVIN: 12 THE WITNESS: On the advice of my lawyer, 1 3 Q. Would you agree with me that the two 13 i must invoke my Fifth Amendment right. 1 ?l females listed as being on that flight with you of 4 BY MR. KUVIN: 15 January ll of2005 were under the age of l4 years 15 Q. Who is David Mullen? 16 16 1 7 MR. Object to the form. It 1 7 WITNESS: On the advice of my lawyer, 1 8 calls for speculation. The witness has no 1 8 i must invoke my Fifth Amendment right. 1 9 personal knowledge and instruct the witness not 1 9 BY MR. KUVIN: 2 to answer based on her Fifth Amendment 2 0 Q. Who is Todd Meister? 2 1 privilege. 2 1 MR. Ri-lBiNi-iAR?i?: Same instruction. 2 2 THE On the instruction of my 2 2 THE WITNESS: On the advice of my lawyer, 2 3 lawyer, 1 must invoke my Fifth Amendment right. 2 3 I must invoke my Fifth Amendment rightMR. KUVIN: 2 5 Q. Would you agree with me that the two 2 5 Q. Who is Jean-Lac Brunei? Page 30 Page 32 1 females listed as being on the flight with you of 1 MR. RHEINHART: Same instruction. 2 January ll, 2805, from West Palm Beach to the RS. 2 THE On the advice of my lawyer, 3 Virgin Islands, with Jeffrey Epstein as well, were 3 i must invoke my Fifth Amendment right. 4 under the age of l3 years old and you were aware of 4 BY MR. 5 that? 5 Q. Ma?arn, would you agree with me that all of 6 MR. RHBINHART: Object to the form both as 3 6 the names {just recently mentioned where you 7 compound, it also assumes facts that it has not "7 invoked your Fifth Amendment, were involved in a 8 been established this witness has any knowledge 8 conspiracy to abuse underaged girls, girls under the 9 of, calls for her to speculate, and I instruct 9 age of 18 for sexual gain and pleasure? 1 0 her not to answer based on her Fifth Amendment 3. 0 MR. RHEINHART: Object to the form of the 1 privilege. 1 1 question. it calls for a legal conclusion. it 1 2 THE WITNESS: On the instruction of my 12 is compound. It calls for her to speculate. 1 3 lawyer I must invoke my Fifth Amendment right. 1 3 There is no basis for her to be able to give a 1 4. BY MR. KUVIN: 11 legal opinion as to what a conspiracy isAdriana Musinska? 1 5 instruct her not to answer based on her Fifth 1 6 MR. I'm sorry. Can you repeat 1 6 Amendment privilege. 1 7 the name? 17 THE WETNESS: On the advice of my lawyer, 8 MR. Musinska, 1 8 I must invoke my Fifth Amendment right. 1 9 MR. RHEINHART: I?ll instruct the witness answer based on her Fifth Amendment 2 Q. Would you agree with me that all of the 2 1 privilege. 2 1 names [just mentioned were individuals that were 2 2 THE WITNESS: On instruction of my lawyer, 2 2 working together for their own sexual gain and 2 3 i must invoke my Fifth Amendment right. 2 3 pleasure? 2 4 BY MR. KEVIN: 2 4 MR. RHBINHART: Object to the form of the 2 5 Q. Who's Ghislaine Maxwell? 1 2 5 question as ambiguous and compound. 1 instruct 8 (Pages 29 to 32) (561) 832?4500 PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 .. ?gourmet. .miu- ?ammtnimnmimmw? ?miin mm- m?wmneaamarwx rm. - Iarssaamx Page 33 Page 35 1 her not to answer based on her i?h Amendment 1 BY MR. 2 privilege. 2 Q. Would you agree with me that Jeffrey 3 THE On the advice of my lawyer 3 Epstein worked closely with .iean-Luc Brunei in order 4 must invoke my Fifth Amendment privilege. 4 to obtain girls from out of state and bring them to ii 5 BY MR. 5 Florida for their own sexual pleasure? 6 Q. What is MC Squared? 6 MR. RHEENHART: Object to the form as 7 MR. instruct the witness not 7 ambiguous, whose own sexual pleasure, and 8 to answer based on her Fifth Amendment 8 instruct the witness not to answer the question 9 privilege. 9 based on her Fifth Amendment privilege. 1 0 THE WITNESS: On the advice of my lawyer i 1 0 MR. KUVZN: i?erfectly good objection. She 1 must invoke my Fifth Amendment right. 1 1 doesn?t have to answer the questionclarify. ii. 3 Q. Would you agree with me that MC Squared is 1 3 BY MR. KEVIN: 4 a modeling agency that was funded by 4 Q. Would you agree with me, ma?arn, that both i. 5 ieffrey Epstein? 1 5 Jean-Luc Brunei and Jeffrey Epstein worked together fl 6 MR. RHEINHART: I instruct the witness not 3. 6 to obtain underage girls from out of state and bring 17 to answer based on her Fifth Amendment 3.7 them to Florida for both of their own sexual 1 8 privilege. 8 pleasure? i. 9 THE The advice of my lawyer i 1 9 MR. RHEINHART: i'm going to object as 2 0 must invoke my Fifth Amendment right. 2 0 compound and instruct i object to the form 2 1 BY MR. KUVIN: 2 .l as compound, and instruct the witness not to 22 Q. Would you agree with me that MC Squared 2 2 answer based on her Fifth Amendment privilege. 2 3 was wholly funded by Jeffrey Epstein? 2 3 THE WITNESS: On the instruction of my 2 4 MR. Object to the form of the 2 4 lawyer I must invoke my Fifth Amendment right. 2 5 question as to what ?wholly funded" means, and 2 5 Page 34 Fage 36 1 i would instruct the witness not to answer the 1 BY MR. KUVEN: 2 question based on her Fifth Amendment 2 A. Would you agree with me that 3 privilege. 3 Ghislaine Maxwell, .i'eanv-Luc Brunel, and Jeffrey Epstein 4 THE WITNESS: On the advice of my lawyer I I 4 worked together to obtain underage girls from out of 5 must invoke my Fifth Amendment right. 5 state and bring them into the State of Florida for their 6 BY MR. KUVIN: 6 own sexual pleasure? 7 Q. Would you agree with me that 7 MR. RHEINHART: Object to the form of the 8 .ieffrey Epstein is the sole individual whose money 8 question as compound and ambiguous, and 9 was used to start the company, MC Squared? 9 instruct the witness not to answer based on her 0 MR. instruct the witness not 3. 0 Fifth Amendment privilege. 1 to answer the question based on her Fifth 1 1 THE WITNESS: On the instruction of my 3. 2 Amendment privilege. 1 2 lawyer, i must invoke my Fifth Amendment right. 1 3 THE WITNESS: On the advice of my lawyer i 1 3 (Katherine Ezell and Amy Ederi 1 4 must invoke my Fifth Amendment right. 1 4 entered the deposition.) 5 BY MR. 3. 5 MR. GOLDBERGER: That?s why we?re 1 6 Q. Would you agree with me that 6 MR. KUVIN: That?s why we lost them. 7 lean?Lac Brunel worked with ieffrey Epstein to 3. 7 MR. WWHART: Do you want to take a 18 obtain underage girls for both of their sexual 1 8 one-minute break so we can -- 9 pleasure? 1 9 MR. KUVIN: Yeah, let?s take a quick 2 0 MR. RHEENHART: Object to the form of the 2 0 one?rninute break. 2 1 question as ambiguous and instruct the witness I 2 1 "fl-IE We're now off video 2 2 not to answer based on her Fifth Amendment 2 2 record. The time is 10:5 6 am. 2 3 privilege. 2 3 (A brief recess was held.) 2 4 THE On the advice of my lawyer i 24 (Plaintiffs Exhibit No. 3 was marked for 2 5 must invoke my Fifth Amendment right. 2 5 identi?cation.) 9 (Pages 33 to 36) (561) 833-7500 PROBE COURT REFORTING AGENCY, INC. (561) 832*7506 Page 37' Page 39 personal knowledge and inStruct her not to 1 THE VIDEOGRAPHER: We?re now on video i 2 record at l:0l am. 2 answer based on her Fifth Amendment privilege. 3 MR. Just for the video record and 3 it?s also compound. 4 for the written record Katherine Ezell and Amy 4 THE On the instruction of my 5 Ederi have now appeared and are present in 5 lawyer I must invoke my Fifth Amendment 6 person. 6 privilege. 7 MR. GOLDBERGER: Just one more matter for 7 BY MR. 8 the record. Jack Goldberger, on behalf of 8 Q. The witness says that you may not have 9 Jeffrey Epstein. Rather than impose a form 9 knowledge or we don't know whether you have 3. objection to every question, i think we have 1 0 knowledge regarding this passenger manifest, so let i; 1 reached an agreement that on behalf of 1 me ask you, do you have any knowledge about this 1 2 Mr. Epstein, I am adopting the form objections 2 passenger manifest? 3. 3 that Mr. Rheinhart is making on behalf of his 1 3 MR. RHEINHART: Object to the form of the it 4 client nunc pro tune to the beginning of this 1 4. question as ambiguous as to this and what a 1 5 deposition. 1 5 manifest is, and also her knowledge, and i will 1 6 MR. KUVEN: No objection. 6 instruct her not to answer based on her i 7 MR. GOLDBERGER: Okay. 1 7 Amendment privilege. 18 BY MR. 3.8 THE WITNESS: On the instruction of my 1 9 Q. All right. All right. Ms. Kellen, would 1 9 lawyer, I must invoke my Fifth Amendment 2 0 you agree with me that there was an agreement 2 privilege. 2 1 between Jeffrey Epstein, Ghislaine Maxwell, 2 3. BY MR. KUVIN: 2 2 Jean-Luc Brunel, yourself and Nadia Marcinkova to 2 2 Q. Based on the objection, do you know what a 2 3 bring in girls from out of state that were underage? 2 3 manifest is? 2 4 MR. RHEINHART: Object to the form of the 2 4 MR. RHEINHART: Object to the form of the 2 5 question as leading, as compound, and instruct 2 5 question as ambiguous and instruct her not to Rage 38 Page 403 1 the witness not to answer based on her Fifth 1 answer based on her Fifth Amendment privilege. 2 Amendment privilege. 2 THE On the instruction of my 3 THE WITNESS: On the instruction of my 3 lawyer I must invoke my Fifth Amendment right. 4 lawyer i must invoke my Fifth Amendment right. 4 BY MR. 5 BY MR. KUVIN: 5 Q. Have you heard the word "manifest" before? 6 Q. Would you agree with me that there was an 6 MR. i'll instruct the witness 3: 7 agreement between Jeffrey Epstein, '7 not to answer based on her Fifth Amendment 8 Ghislaine Maxwell, lean-Lite Brunei, yourself and 8 privilege. 9 Nadia Marcinkova to bring in girls that were 9 THE On the instruction of my 1 underage from out of state for sexual contact? 3. 0 lawyer I must invoke my Fifth Amendment right. 1 1 MR. RasmHAR'r: Object to the form of the ii BY MR. Kovm: 12 question as leading and compound, and I 1 2 Q. Would you agree with me, ma?am, that you 1 3 instruct the witness not to answer based on her 1 3 have seen this passenger manifest, listed as 5 1 4 Fifth Amendment privilege. 1 4 Exhibit 3, in the past? i? 1 5 THE On the instruction of my 15 MR. l?ll instruct the witness 3. 6 lawyer I must invoke my Fifth Amendment 1 6 not to answer based on her Fifth Amendment 3. 7 privilege. 1 7 privilege. ?i 18 BY MR. 18 THE WITNESS: On the instruction of my It 9 Q. All right. Let me show you what we?ve 1 9 lawyer I must invoke my Fifth Amendment right. 2 premarked as Plaintiff?s Exhibit 3. Do you 2 0 BY MR. KUVIN: 2 1 recognize this as the passenger manifest for one of 2 1 Q. Who is Zinta Bronkis? 2 2 ~leffrey Epstein?s planes? 2 2 MR. REEINHART: I?ll instruct the witness 2 3 MR. 1 object to the form of 2 3 not to answer based on her Fifth Amendment 2 4 the question. It assumes facts that this 2 4 privilege. 2 witness, evidence that this witness has no 2 5 THE On the 'nstruction of my 10 (Pages 37 to 40) (561) 832?4500 PROSE COURT REPORTING AGENCY, INC. (563.) 832*7506 Page 41 Page 43 .ii?xlt'l. am amt 'wmae: .. - .r 3. lawyer i must invoke my Fifth Amendment 1 listed in the passenger list to the left? 2 privilege. 2 MR. RHEINHART: Object to the form, the 3 MR. KUVIN: Spelling for the court 3 question is leading and instruct the witness 4 reporter is Z?i?n?t-a, B~r~o~u~k~i~s 4 not to answer based on the Fifth Amendment 5 BY MR. 5 privilege. 6 Q. Who is Eva Andersson, with two 8?3? 6 THE. WITNESS: On the instruction of my 7 MR. RHEINHART: i'll instruct the witness 7 lawyer, i must invoke my Fifth Amendment right. 8 not to answer based on her Fifth Amendment 8 BY MR. KUVIN: 9 privilege. 9 Q. Would you agree with me that you were on a l. 0 THE WITNESS: On the instruction of my 10 plane with leftiey Epstein on April 2?7, 2005? 3. lawyer, I must invoke my Fifth Amendment right. 1 1 MR. Same instruction. 12 BY MR. KUVIN: 1 2 THE On the instruction of my 13 Q. Who is Sevina Dubin (phonetic)? 1 3 lawyer, I must invoke rny Fifth Amendment right. 1 4 MR. RHEINHART: Same instruction. 1 4 BY MR. KUVIN: 5 THE WITNESS: On the instruction of my 15 Q. Would you agree with me that on that plane 1 6 lawyer, I must invoke my ii?th Amendment right. 1 6 of April 27, 2005, from Teterboro, New Jersey, to 7 BY MR. KUVIN: '7 West Palm Beach, was a female who was under the age 1 8 Q. Who is Mya Dubin (phonetic)? 1 8 of 16? 9 MR. Same instruction. 1 9 MR. RHEINHART: Object to the form. it 2 0 THE WITNESS: On the instruction of my 2 0 assumes facts not established. Any personal 2 lawyer i must invoke my Fifth Amendment right. 2 1 knowledge by this Witness, and instruct her not 2 2 BY MR. 22 to answer based on her Fifth Amendment 2 3 Q. Who is Chris Vialdez (phonetic)? w2'3 privilege. it also calls for speculation. 2 4 MR. RHEINHART: Same instruction. 2 4 THE WITNESS: On the instruction of my 2 5 THE WITNESS: On the instruction of my 2 5 lawyer, i must invoke my Fifth Amendment Page 42 Page 44 3. lawyer I must invoke my Fifth Amendment right. 1 privilege. 2 BY MR. KUVINJames Stanley? 3 Q. Would you agree with me that on the flight 4 MR. RHEINHART: Same instruction. 4 of April 27, 2005, from Teterboro, New Jersey to 5 THE WITNESS: On the instruction of my 5 West Palm Beach was a female on the plane with you 6 lawyer, I must invoke my Fifth Amendment right. 6 that was under the age of l5? 7 BY MR. KUVIN: 7 MR. RHEENHART: Object to the form of the 8 Q. Who is Sophia Stanley? 8 question. it requires speculation. it assumes 9 MR. RHEINHART: Same instruction. 9 facts not established before this witness. 1 0 THE S: On the instruction of my 1 0 l?li instruct her not to answer based on her 1 ll lawyer I must invoke my Fifth Amendment right. 1 Fifth Amendment privilege. It?s also 1 2 BY MR. KUVIN: 12 ambiguous. 3 Q. Who is Alexis Stanley? 1 3 THE WITNESS: On the instruction of my 3. 4 MR. RHEINHART: Same instruction. 1 4 lawyer,l must invoke my Fifth Amendment 3. 5 THE WITNESS: On the instruction of my . 5 privilege. 1 6 lawyer, i must invoke my Filth Amendment right. 1 6 BY MR. KUVINWill you turn to May 6, 2005, please. And 1 8 Q. Ma?am, if you would, in Exhibit 3, would 1 8 this is, for the record, in Exhibit 3. On May 6th, 1 9 you turn to the date of April 27, 2005, for me? 1 9 2005, ma?arn, will you agree with me that you took. a 2 0 it's about hal?Nay through the packet. April 27, 2 0 flight from ?i?eterboro, New Jersey to West Palm 2 1 '05. Are you there? 2 1 Beach, with Jeffrey Epstein, Nadia Marcinkova, 2 2 A. Uh-huh. 2 2 Andriana, Andrea Musinska, David Mulien, Larry 2 3 Q. Okay. On this particular date, will you 2 3 Morrison and another female? 2 4 agree with me that you flew from Teterboro, 2 4 MR. RHEINHART: Object to the form of the 2 5 New Jersey to West Palm Beach on a plane with people 2 5 question as compound, calling for Speculation. I 11 (Pages 41 to 44) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 flattens}: ikih-LL'YM decimal Elm Ki - kiwi? ram: "at h? :wi??mxmu? Page 45. Page 47 1 i instruct the witness not to answer based on 1 BY MR. KUVIN: 2 her Fifth Amendment privilege. 2 Q. Do you also agree with me on that flight 3 THE WITNESS: On the instruction of my 3 of June 20th, 2005, was an unidenti?ed female, 4 lawyer, i must invoke my Fifth Amendment 4 according to the passenger manifest? 5 privilege. 5 MR. Object to the form 6 BY MR. KUVIN: 6 excuse me as leading, and instruct the 7 Q. Would you agree with me, ma?am, that on 7 witness not to answer based on her Fifth 8 the flight of May 6th, 2005, that?s shown in 8 Amendment privilege. 9 Exhibit 3, that the female identi?ed in the 9 THE WITNESS: On the instruction of my 1 0 passenger manifest was under the age of 16? 1 0 lawyer, i must choose to invoke my Fifth 1 1 MR. RHEINHART: Object to the form. it 1 1 Amendment privilege. 1 2 assumes facts not established that this witness 1 2 BY MR. KUVIN: 1 3 has any personal knowledge. it calls for her 1 3 Q. Would you agree with me that that female 1 4 to speculate, and I?ll instruct her not to 1 4 listed on the ?ight ofJone 20, 2005, was under the 1 5 answer based on her Fifth Amendment privilege. l. 5 age of 16 years old? . 1 6 THE WITNESS: On the instruction of my 3. 6 MR. RHEINHART: Objection to the form as i 1 '7 lawyer, i must invoke my Fifth Amendment 1 leading and also requiring speculation. I?ll 1 8 privilege. 3. 8 instruct the witness not to answer based Fifth Amendment privilege. 2 0 Q. Would you agree with me that the female 2 0 THE On the instruction of my 2 1 identi?ed in the passenger manifest of May 6th, 2 1 lawyer, i must choose to invoke my Fifth 2 2 2005, was under the age of 15? 2 2 Amendment privilege. 2 3 MR. Same objection as the 2 3 BY MR. KUVIN: 2 4 previous question, same instruction. 2 4 Q. Would you agree with me that the 2 5 THE WITNESS: On the instruction of my 2 5 unidenti?ed female on the passenger manifest of Page 4 6 Page 4 8 1 lawyer I must invoke my Fifth Amendment 1 June 20, 2005, was under the age of 14? 2 privilege. 2 MR. Objection, calls for 3 BY MR. KUVIN: 3 speculation, instruct the witness not to answer 4 Q. Would you agree with me that the female 4 based on her Fifth Amendment privilege. ii 5 listed in the passenger manifest of May 6th, 2005, 5 Till? WZTNESS: On the instruction of my 6 was under the age, was under the age of 14? 6 lawyer, I must invoke my Fifth Amendment ?7 MR. RHEINHART: Same instruction as to the 7 privilege. 8 previous two questions and the same objection 8 BY MR. KUVIN: 9 as to those two questions. 9 Q. Turn to the date of June 30, if you would, 1 0 THE WITNESS: On the instruction of my 1 0 2005. Would you agree with me that you took a 1 lawyer i must invoke my Fifth Amendment 1 1 flight from Teterboro, New Jersey, to West Palm 12 privilege. 12 Beach on lune 30, 2005, with Jeffrey Epstein? 13 BY MR. KUVIN: . 13 MR. RHEINHART: Object to the form as 1 4 Q. if you would turn to the date of June 20 14 leading and compound, instruct the witness not 3.5 of 2005 for me, please. On the date of June 20, to answer based on her Fifth Amendment 3. 6 2005, would you agree with me that you took a flight 6 privilege. 1 7 with Jeffrey Epstein from West Palm Beach to 3. 7 THE WITNESS: On the instruction of my 8 Teterboro, New Jersey? 1 8 laWyer I must, I must invoke my Fifth Amendment 1 9 MR. RHEINI-IART: Object to the form as 9 right. 2 0 leading. l?ll instruct the witness not to 2 0 BY MR. KUVIN: 2 1 answer based on her Fifth Amendment privilege. 2 1 Q. Would you agree with me that Dana Burns 2 2 THE On the instruction of my 2 2 was on that ?ight? 2 3 lawyer, i must invoice my Fifth Amendment 2 3 MR. RHEINHART: Same instruction. 2 4 privilege. 2 4 THE On the instruction of my 2 5 2 5 lawyer I must invoke my Fifth Amendment 12 (Pages 45 to 48} (563.) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-57506 Page 49 Page 51 1 privilege. 3. THE WITNESS: On the instruction of my 2 BY MR. 2 lawyer i must invoke my Fifth Amendment 3 Q. Would you agree with me that there was 3 privilege. 4 also another female on that flight with you? 4 BY MR. 5 MR. RHEENHART: Same instruction. 5 Q. Would you agree with me that on both of 6 THE WITNESS: On the instruction of my 6 those flights were girls that were under the age of 7 lawyer, i must invoke my Fifth Amendment '7 l6? 8 privilege. 8 MR. RHEINHART: Same form objection as to 9 BY MR. KUVIN: 9 compound, also ambiguous and requiring 0 Q. Would you agree with me that you had 1 0 speculation and instruct the witness not to 1 1 personal knowledge that that young female on that 1 1 answer based on her Fifth Amendment privilege. 1 2 ?ight with you of June 30, 2005, was under the age 1 2 THE The instruction of my lawyer 3 of 16? 3 i must invoke my Fifth Amendment privilege. 1 4 MR. RHEINHART: Object to the form as i 4 BY MR. KUVEN: 5 compound and calling for speculation, and it 5 Q. Would you agree with me, ma?am, that you ll. 6 instruct the witness not to answer based on her 1 6 have flown on Jeffrey Epstein?s plane from 1 7 Fifth Amendment privilege. 7 Teterboro, New Jersey, to West Palm Beach, on 1 8 THE On the instruction of my 1 8 numerous occasions where there were girls on the 9 lawyer, i must invoke my Fifth Amendment 9 plane under the age of 16? 2 0 privilege. 2 0 MR. RHEINHART: Object to the form as 2 1 BY MR. KUVIN: 2 1 compound and ambiguous as to what numerous 2 2 Q. Would you agree with me that you had 2 2 means. instruct the witness not to answer 2 3 personal knowledge that that young female on the 2 3 based on her Fifth Amendment privilege. 2 4 flight of June 30, 2005, was under the age of 15? 2 4 THE Wi?ihlESS: On the instruction of my 2 5 MR. RHBINHART: Same instruction, calls 2 5 lawyer I must invoke my Fi?h Amendment Page 50 Page 52 for speculation. 1. privilege. 2 THE WITNESS: On the instruction of my 2 BY MR. KUVIN: 3 lawyer, I must invoke my Fifth Amendment 3 Q. Would you agree with me that you have 4 privilege. 4 flown on Je?i?ey Epstein?s plane from Teterboro, New 5 BY MR. KUVIN: 5 Jersey, to West i?alm Beach on at least 100 occasions 6 Q, Would you agree with me that you had 6 where there were girls on the plane with you under 7 personal knowledge that that young female ?ight of June 30, 2005, with you was under the age 8 MR. Object to the form as 9 of 14? 9 compound, requiring speculation and ambiguous, 0 MR, RHEINHART: Objection to form as to 1 0 and instruct her not to answer based on her 1 1 compound and requiring speculation. ill 1. 3. Fifth Amendment privilege. 12 instruct the witness not to answer based on her 1 2 THE WITNESS: On the instruction of my 1 3 ifth Amendment privilege. 1 3 lawyer I must invoke my Fifth Amendment 1 4 THE WITNESS: On the instruction of my 1 4 privilege. 1 5 lawyer must invoke my Fifth Amendment 1 5 BY MR. KUVIN: 1 6 privilege. 1 6 Q. Would you agree with me, ma?am, that you 3. 7 BY MR. 1 7 have ?own on Jef?'ey Epstein?s plane at least 100 1 8 Q. Ma?am, just so we can be quicker about it 8 times from Teterboro, New iersey to West Palm Beach, 3. 9 this, there are flights of July 5th, July l5. It 1 9 Florida, where there were girls under the age of 15 2 0 looks like those are the last two. Would you agree 2 0 on the plane with you? 2 with me that on July 5th and July 15, you took - 2 1 MR. RHEINHART: Same objections as the 2 2 ?ights on Jeffrey Epstein?s plane? I 2 2 previous question, same instruction. 2 3 MR. Object to the form as 2 3 THE WITNESS: On the instruction of my 2 4 compound and instruct the witness not to answer 2 4 lawyer, I must invoke my Fifth Amendment 2 5 based on Fifth Amendment privilege. 2 5 privilege. 13 (Pages 49 to 52) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 ?um-.2 skilltI-i? emanyaememmem maintainers iSem" - "whitiluix?i?ww?TI hs?rxn?mu-I ?lmi?ilm" ?ii?fm' Miumw: mmaasemm a herewsma'ewwsmer:roavww Page 53: Page 55 1 BY MR. KUVIN: 1 occasions where Jeffrey Epstein was flying with 2 Q. Would you agree with me that you have 2 young girls under the age of l6 from Teterboro, New 3 flown on ieffrey Epstein?s plane from Teterboro, New 3 Jersey, to Florida, West l?alrn Beach, Florida, with 4 Jersey to West Palm Beach on at least 100 occasions 4 girls under the age of 16, was doing so, so that he 5 where there were girls on the plane with you that 5 could have sexual contact with them? 6 were under the age of 14? 6 MR. RHEINHART: Object to the form. It's 7 MR. Objection to the form. '7 compound and requires her to assume facts that 8 It's compound and ambiguous, calls for 8 have not been established, and it?s ambiguous, 9 speculation and instruct her not to answer 9 and instruct her not to answer based on the 1 0 based on her Fifth Amendment privilege. 1 0 Fifth Amendment privilege. 1 1 WITNESS: On the instruction of my 1 1 THE WITNESS: On the instruction of my 12 lawyer, I must invoke my Fifth Amendment 12 lawyer, i must assert my Filth Amendment right. 13 privilege. 13 BY MR. KUVIN: 1 4 BY MR. KUVIN: 1 4 Q. Do you agree with rne that on the flights 1 5 Q. Would you agree with me that you have been 15 from West Palm Beach to l?aris, where you were 1 6 on the plane, one of Jeffrey Epstein?s strike 1 6 present on the plane with Jeffrey Epstein, that 1 7 that. 17 there were girls under the age of 16 that 1 8 Would you agree with me that you have 1 8 leffrey Epstein was having sexual contact with on 1 9 been on .leffrey Epstein's plane with him to Paris 1 9 that plane? 2 0 where there have been girls on the plane with you 2 0 MR. RHEINHART: Same objections as 2 1 under the age of l6? 2 1 previously stated. It?s compound, ambiguous, 2 2 MR. RHEINHART: Objection to the form as 22 and assumes facts that she has no knowledge, or 2 3 compound, assuming facts not established the 2 3 it has not been established that she has any 2 4 witness has any knowledge, and instruct the 2 4 knowledge of, and instruct her not to answer 2 5 witness not to answer based on her Fifth 2 5 based on the Fifth Amendment, and its leading. Page 54 Page 56 1 Amendment privilege. It's also leading. 1 THE WITNESS: On the instruction of my 2 THE WITNESS: On the instruction of my .2 lawyer i must invoice my Fifth Amendment right. 3 lawyer, I must invoke my Fifth Amendment 3 BY MR. KUVIN: 4 privilege. 4 Q. Ma?am, you?ve been on the plane, you?ve 5 BY MR. KUVIN: 5 been on a plane with Jeffrey Epstein in the past, 6 Q. Would you agree with me that you have been 6 have you not? 7 on the plane with leffrey Epstein on flights to 7 MR. RHEINHART: Objection to the form as 8 Paris where there have been girls on the plane with 8 leading, and instruct her not to answer based 9 you under the age of 15? 9 on the Fifth Amendment privilege. 1 0 MR. Same objection and same 1 0 THE WITNESS: On the instruction of my 1 1 instruction as the previous question. 1 1 lawyer, I must invoke my Fifth Amendment 1 2 THE On the instruction of my 1 2 privilege. 1 3 lawyer, i must invoke my Fifth Amendment 1 3 BY MR. KUVIN: 4 privilege. . 1 4 Q. Have you been on a plane with 1 5 BY MR. KUVIN: 1 5 Jeffrey Epstein ever in your entire life? 1 6 Q. Would you agree with me that you have been 1 6 MR. RHEINHART: instruct the witness not 1 7 on those same flights we have been discussing where 17 to answer based on her Fifth Amendment right. i. 8 there have been girls under the age of 14? 1 8 THE WITNESS: On the instruction of my 1 9 MR. Same instruction and same 1 9 lawyer i must invoke my Fifth Amendment 2 objection as the previous two questions. 2 privilege. 2 1 THE WITNESS: On the instruction of my 2 1 BY MR. KUVIN: 2 2 lawyer, I must invoke my Fifth Amendment 2 2 Q. Have you ever been on a plane with 2 3 privilege. 2 3 Jeffrey Epstein where there was a girl on the plane 2 4 BY MR. KUVIN: 2 4 with you under the age of 14? 2 5 2 5 remune? amp; (561) 832*7500 Q. Would you agree with me that on the PROSE COURT REPORTING AGENCY, ENC. MR. RHEINHART: Same instruction. 14 (Pages 53 to 56) (561) 832~7506 m3 slim-him "were saw-Wrasse WSW-163: (vex at. Thin a Kath-mlhiil' ti. Page 57 Page 5 9 1 THE On the instruction of my 1 MR. Same objection as stated 2 lawyer, I must invoke my Fifth Amendment 2 to the previous question; it's ambiguous and 3 privilege. 3 instruct her not to answer based on the Fifth 4 BY MR. novel: 4 Amendment. 5 Q. Ma'am, isn?t it true that you?ve seen 5 THE WITNESS: On the instruction of my 6 ieffrey Epstein have sex with girls under the age of 6 lawyer, I must invoke my Fifth Amendment right. 7 14 on his plane? 7 MR. KUVIN: Just to clarify, is the 8 MR. RHEINHART: Objection to the form. It 8 ambiguity the word ?sex?? 9 assumes facts that it's not been established 9 MR. MEWHART: Sex and also assumes that 1 that she would have any knowiedge of, and Th 1 0 she's ever met Jeffrey Epstein in her life. 1 1 instruct her not to answer based on her Fifth 3. 1 MR. KEVIN: Any other words in there I 1 2 Amendment right. 3.2 need to clarify? 1 3 THE WITNESS: On the instruction of my 3.3 MR. REBINHART: No. 4 lawyer, i must invoke my Fifth Amendment 1 4 BY MR. KUVIN: 1. 5 privilege. 1 5 Q. Okay. Ma?am, do you what?s your 1 6 BY MR. KUVIN: 1 6 definition of the word "sex"? 1 ?7 Q. WOuld you agree with me that you?ve seen 1 7 MR. RHEINHART: Object to the form of the 1 8 Jeffrey Epstein have sex with girls on his plane in 1 8 question and instruct the witness not to answer 1 9 your presence during flights to Paris? 1 9 based on her Fifth Amendment privilege. 2 0 MR. RHEINHART: Same objection previously . 2 {3 THE WITNESS: On the instruction of my 2 1 stated, and it assumes facts that have not been 2 3. lawyer, I must invoke my Fifth Amendment right. 2 2 established and instruct her not to answer 2 2 BY MR. 2 3 based on her Fifth Amendment right. 2 3 Q. Would you agree with me that the word 2 4 THE WITNESS: On the instruction of my 2 4 "sex" means both vaginal intercourse as well as oral 2 5 lawyer, I must invoke my Fifth Amendment 2 5 sex? Would you agree with that de?nition? Page 58 Page 60 1 priviiege. 1 MR. RHEINHART: You can answer that. 2 BY MR. KUVIN: 2 THE WITNESS: No. 3 Q. Ma?am, isn?t it true that you?ve seen 3 BY MR. KUVIN 4 Jeffrey Epstein and Jean?hue Brunei have sex with 4 Q. Okay. Would you agree with me that sex, - 5 girls under the age of 14 on Mr. Epstein?s piano on 5 for the purpose of our questions here today, will be 6 flights to Paris? 6 limited strictly to vaginal intercourse? 7 MR. RHEINHART: Objection to the form. 7 A. Sorry. Can you repeat that? 8 it's compound, as to several answers all at the 8 Q. Yes. For the purpose of my questions here 9 same time and certain facts, and instruct her 9 today, will you agree that the word "sex" wiil be 1 0 not to answer based on her Fifth Amendment. 1 0 limited to vaginal intercourse between a man's penis 1 1 THE WITNESS: On the instruction of my 1 1 and a woman's vagina? 1 2 lawyer, i must invoke my Fifth Amendment 1 2 MR. if you're instructing her 1 3 privilege. 1 3 that in the future she should assume that 4 BY MR. . 1 4 that's what you mean by your question, that?s 1 5 Q. Ma'arn, isn?t it true that you have had sex 1 5 fine. 1 6 with Jeffrey Epstein on his plane? 1 6 MR. KU VIN Okay. 1 7 MR. RHEINHART: instruct the witness not 1 7 MR. RHEINHART: If that?s what you mean, 1 8 to answer based on the Fifth Amendment 1 8 then that's understood. 1 1 9 privilege, also object to the form of the 1 9 MR. KUVIN: That?s what i mean. 2 0 question as compound and ambiguous. 2 0 MR. RHEINHART: Okay. 2 1 THE WITNESS: On the instruction of my 2 1 MR. KWIN: All right. Let's go with that 2 2 lawyer, I must invoke my Fifth Amendment right. 2 2 de?nition. And for the purposes of my 2 3 BY MR. KUVIN: 2 3 questions, "oral sex? will mean contact between 2 4 Q. isn?t it true that you?ve had sex with 2 4 an individuai's mouth and a man's sexual organ, 2 5 Jeffrey Epstein on his plane on flights to Paris? 2 5 penis. Fair enough? 15 (Pages 57 to 60) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?4506 Page 61 Page 63% 1 MR. RHEINHART: Understood. 1 Mr. Epstein?s residence, as to her knowledge of 2 MR. KUVZN: Okay. 2 Mr. Epstein and other facts as to which she?s 3 BY MR. 3 invoking her Fifth Amendment privilege. 4 Q. Working with those de?nitions if we 4 THE, WITNESS: On the instruction of my 5 could, would you agree with me that you had sex with 5 lawyer, i must to invoke rny Fifth Amendment 6 Jeffrey Epstein on his plane? 6 privilege. 7 MR. Objection to the form. 7 MR. KUVIN: Let me show you what we'll 8 It's compound and instruct her not to answer 8 mark as Exhibit 6. And this one for going to 9 based on the Fi?h Amendment privilege, because 9 show it to the camera real briefly, if i could. 1 to do so would implicitly admit that she's ever 1 0 Okay. 1 1 met leffrey Epstein in her life, and so as to 1 MR. RHEINHART: Let me see it. 'ihank you. 12 that she?s invoking the Fi?h Amendment 3.2 (Plamtiffs Exhibit No. 6 was marked for 3 privilege. 1 3 identi?cation.) 1 4 THE WITNESS: On the instruction of my 1 4 BY MR. KUVIN: 1 5 lawyer, I must invoke my Fifth Amendment 1 5 Q. Ma?arn, do you recognize any of the girls 16 privilege. 16 shown in Exhibit 6? 1 '7 BY MR. KUVIN: 17 MR. i?ll instruct the witness 1 8 Q. Would you agree with me that you have had 1 8 not to answer based on her Fifth Amendment 1 9 oral sex with leffrey Epstein on his plane? 1 9 privilege. 2 0 MR. Same objection stated to 2 0 THE WITNESS: On the instruction of my 2 1 the previous question. it?s compound and it 2 1 lawyer, i must invoke my Fifth Amendment right. 22 assumes facts that?s not been established as to 2 2 BY MR. KUVIN: 2 3 which she is invoking her Fifth Amendment 2 3 Q. Would you agree with me that that is you 2 4 privilege. . 2 4 on the right in this photograph, the far right? 2 5 THE On the instruction of my 2 5 MR. RHEINHART: l'll instruct the witness Page 62 Page 64% lawyer, i must invoke my Fifth Amendment 1 not to answer. 2 privilege. 2 ?fl-EB WITNESS: On the instruction of my 3 BY MR. KUVIN: 3 lawyer, i must invoke my Fifth Amendment 4 Q. Would you agree with me that you have had 4 privilege. 5 sex with Jeffrey Epstein in his home I 5 BY MR. KUVIN: 6 MR. RHEINHART: Object to th -- . 6 Q. Would you agree with me that that is ?7 MR. -- here in West Palm, in West 7 Nadia Marcinkova on the left in that photograph that 8 Palm Beach? 8 we marked as Exhibit 6? a} 9 MR. RHEINHART: l?ll instruct the witness 9 MR. Same instruction. 1 0 not to answer based on her Fifth Amendment 1 0 THE On the instruction of my 1 1 privilege and same objection previously stated 1 1 lawyer, I must invoke my Fifth Arnendment 1 2 to the last two questions. 1 2 privilege. 1 3 THE WITNESS: On the instruction of my 1 3 BY MR. KUVIN: 14 1 5 privilege. 1 5 MR. Same instruction. 6 BY MR. KUVIN: - 1 6 THE WITNESS: On the instruction of my 1 '7 Q. Would you agree with me that you have had 1. '7 lawyer, i must invoke my Fifth Amendment 1 8 oral sex with Jeffrey Epstein in his home in West 1 8 privilege. 1 9 Palm Beach? 1 9 BY MR. KUVIN: 2 0 MR. GARCIA: is it West, or Palm Beach? 2 Q. How old is Nadia Marcinkova in this 2 1 MR. KUVIN: Palm Beach Island, 1 think 2 1 photograph, if you know? 2 2 it?s, because yeah, for clarity, his home on 2 2 MR. RHEENHART: I'm going to object to the 3, 2 3 Palm Beach. 2 3 form in that it assumes facts as to her 2 4 MR. RHEINHART: Object to the form. it 2 4 knowledge of anything about Ms. Marcinkova, and 2 assumes facts as to her knowledge of 2 5 as to which she is invoking her Fifth Amendment (561) 832-7500 PROBE COURT REPORTING AGENCY, INC. (561) (Pages 61 to 64) 832*7506 Page 65 huge 67 ii: Selim-dam? new; meannm gm?, ?range/135..? gunmen: - g?dq?mfx??wg 1 privilege. 1 THE On the instruction of my 2 THE WITNESS: On the instruction of my 2 lawyer, I must invoke my Fifth Amendment 3 lawyer, I must invoke my Fifth Amendment 3 privilege. 4 privilege. ti BY MR. KUVEN: 5 MR. This is Exhibit 7. Let me 5 Q. Would you agree with me that Haley Robson 6 show you what we'll mark as Exhibit 6 has been to Mr. Epstein's home on hundreds of 7 (Flaintiff's Exhibit No. 7 was marked for 7 occasions? 8 identi?cation.) 8 MR. RHEINHART: Object to the form as 9 BY MR. KUVIN: 9 compound and also assumes knowledge as this 1 Q. Do you recognize the girl that's shown in 1 0 witness has and instruct her to invoice her 1 1 Exhibit 7? 1 1 Fifth Amendment privilege relating to 1 2 MR. i need to consult with her 12 Ms. Robson. l. 3 one second. 13 THE WITNESS: On the instruction of my 1 4 MR. Sure. 1 4 lawyer, I must invoke my Fifth Amendment 1 5 THE Are we off the record? 1 5 privilege. 1 6 MR. KUVINMR. RHEINHART: instruct the witness to 1 7 Q. Would you agree with me that you directed 1 8 invoke her Fifth Amendment priviiege as to 1 8 Haley Robson on hundreds of occasions to bring girls 1 9 Exhibit 7. 1 9 under the age of 16 to Mr. Epstein?s house? 2 0 MR. KUVIN: She?s ciipped up. Okay. 2 0 MR. RHEINHART: Object to the form of the 2 1 MR. RHBINHART: Now you have to answer. 2 1 question as compound and ambiguous and assuming 2 2 THE WITNESS: On the advice of my lawyer, 2 2 facts as to which there is no factual basis 2 3 i must invoke my Fifth Amendment privilege. 2 3 that this witness has any knowledge and 2 4 BY MR. KUVIN: 2 4 instruct the witness not to answer based on her 2 Q. Would you agree with me that the giri 2 5 Fifth Amendment privilege. Page 66 Page 68 1 shown in Exhibit 7 is l-Iaiey Robson? 1 THE WITNESS: On the instruction of my 2 MR. RHEINHART: Instruct the witness not 2 lawyer, I must choose to invoke my Fifth 3 to answer based on the Filth Amendment 3 Amendment right. 4 privilege. 4 BY MR. KUVIN: 5 THE WITNESS: On the instruction of my 5 Q. Would you agree with methat on hundreds 6 lawyer, i must invoke my Fifth Amendment 6 of occasions you directed Haley Robson to bring 7 privilege. ?7 underage girls under the age of 16 to Mr. Epstein's 8 BY MR. KUVIN: 8 home for sex with Mr. Epstein? 9 Q. Do you agree with me that Haley Robson was 9 MR. Object to the form. It?s 1 0 under the age of 16 when she was ?rst asked to go 1 0 compound and it assumes facts as to this 1 to Mr. Epstein?s home? 1 1 that this witness has no personal knowledge, 1 2 MR. RHEINHART: Objection to the form. It 12 and it's been established by this record, and 3 assumes any knowledge by this witness as to the 13 instruct her to invoke her Fifth Amendment 1 4 person you identified as Haley Robson. it?s 1 4 privilege. 1 5 compound and i would instruct her not to answer 1 5 THE On the instruction of my 1 6 based on her Fifth Amendment privilege. i. 6 lawyer, I must invoke my Fifth Amendment 1 7 THE WITNESS: 0n the instruction of my 3. 7 privilege. 1 8 lawyer, i must invoke my Fifth Amendment 3. 8 MR. KUVIN: We'll mark this as Exhibit 8. 1 9 privilege. 1 9 (Plaintiffs Exhibit No. 8 was marked for 2 0 BY MR. KUVIN: - 2 0 identi?cation.) 2 1 Q. Would you agree with me that you know 2 1 BY MR. KUVIN: 2 2 personally Haley Robson? 2 2 Q. Ma?am, do you recognize the person that?s 23 MR. RBEINHART: Instruct the witness not 2 3 shown in Exhibit 8? 2 4 to answer based on the Fifth Amendment 2 4 MR. RHEINHART: Let me consult one second. 2 5 privilege. 2 5 MR. KUVIN: Sure. 17 (Pages 65 to 68) (561) PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 Page 69 Page 71 3. MR. RHEINHART: i instruct the witness not 3 3. MR. GARCIA: He didn't make a Fifth 2 to answer the question based on her Fifth 2 Amendment objection. So can we just rephrase 3 Amendment privilege. 3 the question? 4 THE WITNESS: Based on the instruction of 4 MR. RHEINI-IART: I would instruct the 5 my lawyer, i must invoke my Fifth Amendment 5 witness not to answer based on the Fifth 6 right. 6 Amendment privilege to clarify. 7 BY MR. KEVIN: '7 MR. KUVIN: Okay. Let?s mark this as 8 Q. Would you agree with me that the person 8 Exhibit 9. 9 shown on Exhibit 8 is you? 9 MR. RHEENHART: And for the record, the 1 0 MR. Same instruction. 1 0 basis is that it assumes her knowledge of 1 1 THE WITNESS: 0n the instruction of my 1 3. anything relating to Jeffrey Epstein, the 1 2 lawyer, I must invoke my Fifth Amendment 12 question assumed that. 1 3 privilege. 1 3 (Plaintiffs Exhibit No. 9 was marked for 1 4 BY MR. KUVIN: 1 a identi?cation.) 1 5 Q. Would you agree with me that this is a 3.5 BY MR. KUVIN: 1 6 modeling shot of you that was taken through one of 1 6 Q. Ma?arn, do you recognize the girl shown in 1 7 Mr. Epstein?s modeling agencies? 17 Exhibit 9? 1 8 MR. Object to the form of the 1 8 MR. RHBINHART: I?ll instruct the witness 1 9 question as compound and assuming facts as to 1 9 not to answer based on her Fifth Amendment 2 which there has been no basis that this witness 2 privilege. 2 1 has any personal knowledge, and she's going 2 1 THE WITNESS: On the instruction of my 2 2 invoke her Fifth Amendment privilege. 2 2 lawyer, i must invoke my Fifth Amendment right. 2 3 THE WITNESS: On the instruction lawyer, i must invoke my Fifth Amendment 2 4 Q. Would you agree with me that the girl 2 5 privilege. 2 5 shown in Exhibit 9 is Nadia Marcinkova? Page 70 Page 72 1 BY MR. 1 MR. Same instruction. 2 Q. Would you-agree with me that you were 2 THE WITNESS: On the instruction of my 3 under the age of 18 in this photograph we?ve marked 3 lawyer, I must invoke my Fifth Amendment 4 as Exhibit 8? 4 privilege. 5 MR. RHEINHART: Same objection as to the 5 MR. KUVIN: I forgot to do one more thing. 6 previous question and same instruction. 6 If you could give that back to me for just one "7 THE WITNESS: On the instruction of my 7 second just for the record so we can see what 8 lawyer, i must invoke my Fifth Amendment right. 8 we?re talking about here. 9 BY MR. KUVIN: 9 Okay. I will give you back Exhibit 1 Q. Would you agree with me that you were 1 9. 1 under the age of 17 in this photograph that we've 3. 1 MR. Thank you. 1 2 marked as Exhibit 8? 12 BY MR. KUVIN: 1 3 MR. RHEINHART: Same objection as the 3 Q. Would you agree with me that this 1 4 previous two question and the same instruction. 1 4 photograph of Nadia Marcmkova was taken when she 1 5 THE WITNESS: On the instruction of my 15 was under the age of 18? 1 6 lawyer, I must invoke my Filth Amendment right. 1 6 MR. RHEINHART: Objection to the form. it 1 7 BY MR. KUVIN: 17 assumes this witness has any knowledge that the 1 8 Q. Would you agree with me that Jeffrey 1 8 person in the photograph is, in fact, Nadia 1 9 Epstein kept this photograph of you in his home, if 1 9 Mareinkova. Therefore, it's ambiguous and 2 0 you know. - 2 0 compound, and I?ll instruct her not to answer 2 1 MR. Object to the form of the 2 3. based on her Fifth Amendment privilege. 2 2 question as compound and ambiguous, and I would 2 2 THE WITNESS: 0n the instruction of my 2 3 instruct the witness not to answer. 2 3 lawyer, I must invoke my Fi?h Amendment right. 2 4 THE WITNESS: On the instruction of my 2 4 BY MR. KUVIN: 2 lawyer, i must invoke my Fifth Amendment right. 2 5 Q. Would you agree with me that the girl 18 (Pages 69 to 72) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 3 ii \5 -. - (?wig ?wow?now: . .022 .5, MW - . an: on? Khalil?. ink-39k 'm'w'z?amxm' . .. ism Jamar; . "51' imitaw'?. New. .., e: is new? mammweimisaxmumrm B?'m ?it it: 1 madam ?at. ?hammer med? - - kt?? Page 73 Page 75 1 shown in that photograph strike that. implicitly assumes that she does, I would 2 Would you agree with me that this . 2 instruct her not to answer it based on her 3 photograph was kept by Jeffrey Epstein in his home? 3 Fifth Amendment privilege. 4 MR. RHEINHART: Objection to the form as 4 THE WITNESS: Upon the instruction of my 5 to being compound in that it assumes that she 5 lawyer, i must invoke my Fifth Amendment 6 has any knowledge of Jeffrey Epstein or his 6 privilege. '7 home, and I would instruct her not to answer 7 BY MR. KUVIN: 8 based on her Fifth Amendment. 8 Q. Ma'am, are you aware of the effect, the 9 THE WITNESS: On the instruction of my 9 emotional effect on the underage girls that have 1 lawyer, I must invoke my Fifth Amendment right. 1 0 been abused by Eeffrey Epstein? Are you aware of 1 1 BY MR. KUVIN: 1 1 the emotional effect that it's had on the underage 12 Q. Would you agree with me that 12 girls that have been abused by Jeffrey Epstein? 1 3 Nadia Marcinkova was under the age of l6 when this 1 3 MR. RHBINHART: Obj ection to the form as 1 4 photograph was taken in Exhibit 9? 4 to, again, the question assumes this witness 15 MR. Objection to the form as 5 has any knowledge, first, of Jeffrey Epstein, 6 compound and also assuming this witness has any 6 second that leffrey Epstein has sexually abused '7 knowledge that the person in the photograph is, 7 anyone ever, and third, that anyone has been 1 8 in fact, Nadia Marcinkova. ?i?herefore, i would 1 8 damaged by anything that Jeffrey Epstein has 1 9 instruct her to invoke her Fifth Amendment 1 9 done, and fourth, that she would somehow have 2 privilege. 2 0 any knowledge of these people?s emotional 2 1 THE 888: On the instruction of my 2 situations. For all those reasons, the 2 2 lawyer, i must invoke my Fifth Amendment right. 2 2 question is ambiguous and compound, and I would 2 3 BY MR. KUVIN: 2 3 instruct her not to answer based on her Fifth 2 4 Q. Ma'am, is Jeffrey Epstein paying for your. 2 4 Amendment. 2 5 attorney today? 2 5 THE Upon the instruction of my Page 74 Page 76 1 MR. I?ll instruct the witness 1 lawyer, i must invoke my Fifth Amendment right. 2 not to answer based on her Fifth Amendment 2 BY MR. 3 privilege. 3 Q. Ma'ani, do you have any regret for what 4 THE WITNESS: On the instruction of my 4 you've done? 5 lawyer, I must invoke my Fifth Amendment right. I 5 MR. RHEINHART: Objection to the form. 6 BY MR. KUVIN: 6 That question is not designed to lead to 7 Q. Ma?am, is Jeffrey Epstein paying for you 7 discoverable evidence. It?s meant solely for 8 to keep quiet with respect to the things he has done 8 the purpose of harassment, and I would instruct 9 to underage girls? 9 her not to answer. i. 0 MR. RHEINHART: Objection to the form that it's ambiguous and compound, also assumes 3. Q. Ma'arn, do you have any regrets for what 1 2 this witness has any knowledge at all of 12 Jeffrey Epstein has done through you in obtaining 1 3 Jeffrey Epstein, and therefore I am instructing 1 3 underage girls for sexual abuse? 1 4 her to invoke her Fifth Amendment privilege. 1 4 MR. Same objection as the 1 5 THE WITNESS: On the instruction of my 1 5 previous question as well as that question is 1 6 lawyer, I must invoke my Fifth Amendment 1 6 now free to assume this witness has any 1 7 privilege. 7 knowledge at all of Jeffrey Epstein or 1 8 BY MR. KUVIN: 1 8 ieffrey Epstein having abused any underage 9 Q. Ma?am, how much is Jeffrey Epstein paying 1 9 women or girls or anything else that 2 0 you to keep quiet with respect to things he?s done 2 .ieffrey Epstein may ever have done. 2 to underage girls? 2 1 And therefore, since it assumes that 2 2 MR. Object to the form as 2 2 fact, i would instruct her not to answer 2 3 multiple compound questions, and it?s again 2 3 based on her Fifth Amendment. 2 4 assuming this witness has any knowledge at all 2 4 BY MR. KUVIN 2 5 of Jeffrey Epstein. Since the question 2 5 Q. Are you scared of Jeffrey Epstein? 19 (Pages 73 to 76) (561) 832-4500 PROSE COURT RERORTING AGENCY, INC. (561) 832*7506 Page 77 Page 79; 1 MR. KUVIN: I?m sorry, you had to respond. 1 lawyer, and i must invoke my Fifth Amendment 2 i cut you off. 2 privilege. 3 THE WITNESS: Upon the instruction of my 3 BY MR. 1i lawyer, I must invoke my Fifth Amendment right. 4 Q. Do you know who Les Wexner is? 5 BY MR. KUVIN: 5 MR. RHEINHART: l'll instruct the witness 6 Q. Are you scared of Jeffrey Epstein? 6 not to answer based on her Fifth Amendment 7 MR. RHEINHART: Objection to the form in 7 privilege. 8 that it assumes this witness has ever met 8 THE On the instruction of my 9 Jeffrey Epstein in her life. Because it 9 lawyer, I must invoke my Fifth Amendment 1 0 assumes that, I would instruct her not to 1 0 privilege. 1 answer based on the Fifth Amendment. 3. IL BY MR. KUVIN: 3.2 THE WITNESS: On the instruction of my 1 2 Q. Do you know whether or not Mr. Epstein has l3 lawyer, I must invoke'my Fifth Amendment right. 1 3 had a homosexual relationship with Les Wexner in the 14 av MR. Kovm: 3.4 past? 5 Q. Are you aware of .leffrey Bpstein?s sexual 15 MR. RHEINHART: Objection to the form in it 6 obsession for children? i 6 that it again assumes that this witness knows 7 MR. RHEINHART: Same instructions as the 17 anything at all about Jeffrey Epstein or has 1 8 previous question, also objection to the 3, 8 ever met Jeffrey Epstein in her life, and 9 question. It?s not designed to lead to any 3. 9 therefore, I would instruct her not to answer 2 discoverable evidence at all. it's simply 2 0 based on her Fifth Amendment privilege, and the 2 1 meant for harassment. 2 1 question is compound and ambiguous. 2 2 THE WITNESS: 0n the instruction of my 2 2 THE WITNESS: On the instruction of my 2 3 lawyer, I must invoke my Fifth Amendment 2 3 lawyer, I must invoke my Fifth Amendment 2 4 priviiege. 2 4 privilege. 25 25 Page 78 Page 80% 1 BY MR. aovm: 1 BY MR. KUVIN: 2 Q. At what point did you realize that 2 Q. you know the magician by the name 3 Jeffrey Epstein was sexually attracted to girls 3 David Copperfield? 4 under the age of 18? 4 MR. RHEINHART: l?ll instruct the witness 5 MR. RHEINHART: Once again, the question 5 not to answer based on her Fifth Amendment 6 assumes this witness knows anything at all 6 right. 7 about Jeffrey Epstein, underage women, sexuai '7 THE WITNESS: On the instruction of my 8 abuse of underage women, and she?s not going to 8 lawyer, i must invoke my Fifth Amendment 9 answer any questions that assume that as a 9 privilege. 1 0 predicate. They are objectionable as ambiguous 0 BY MR. Ki}sz 3. l. and compound, and I instruct her not to answer. 1 Q. You are aware, are you not, that 12 THE WITNESS: On the instruction of my 1 2 David Copper?eld has visited Eeffrey Epstein?s home 13 lawyer, I must invoke my Fifth Amendment 3. 3 in Palm Beach? 4 privilege. 1 4 MR. Objection to the form as 15 BY MR. KUVIN: 1 5 it once again assumes she has some knowledge of 3. 6 Q. Are you aware whether or not 1 6 Jeffrey Epstein, or whether he has a home in 3. 7 ieffrey Epstein has had any homosexual relationships 1 7 Palm Beach. Because those facts are implicit i 8 in the past? 1 8 in the question, the question is ambiguous and 2i 9 MR. RHEINHART: Same objection as the 9 compound. would instruct her not to answer 2 0 previous question. The question as stated 2 0 based on her Fifth Amendment. 2 1 assumes this witness has some knowledge of 2 1 THE WETNESS: On the instruction of my 2 2 .leffrey Epstein. And since it assumes that 2 2 lawyer, i must invoke my Fifth Amendment 2 3 fact, it is ambiguous and it?s compound, and I . 2 3 privilege. 2 4 instruct her not to answer. 2 4 BY MR. THE WITNESS: On the instruction of my 2 5 Q. You are aware, are you not, that 20 (Rages 77 to 80) (561) 832*7500 QROSE COURT REPORTING AGENCY, INC. (561) 8394506 Page 81 Page 835 1 David Copper?eld and Jeffrey Epstein used to share 1 privilege. 2 for sexual for sex, girls under the age of 16? 2 THE WITNESS: On the instruction of my 3 MR. RHEINHART: Same objection as 3 lawyer, must invoke my Fifth Amendment 4 previously stated to the last i don't know how 4 privilege. 5 many questions. This question again assumes 5 BY MR. KUVIN: g: 6 this witness knows Jeffrey Epstein, has any 6 Q. How many people did Jeffrey Epstein use to 7 knowledge of leffrey Bpstein?s life. And 7_ help him bring minor females to his house in Palm 8 because it assumes that fact, there is an 8 Beach for sex? 9 underlying predicate it is ambiguous and 9 MR. RHEINHART: Same objection as the 1 0 compound. I would instruct her not to answer. 1 0 previous question and I instruct her not to 1 1 THE WITNESS: On the instruction of my 1 1 answer. 12 lawyer, must invoke my Fifth Amendment 12 THE On the instruction of my 1 3 privilege. 1 3 lawyer, i must invoke my Fifth Amendment 1 4 BY MR. KUVFN: 1 4 privilege. 1 5 Q. From the time you met Mr. Epstein, isn't 1 5 BY MR. KUVYN: 1 6 it true that he would arrange for underage girls, 1 6 Q. Do you agree that Jeffrey Epstein is a 3.7 girls under the age of 18, to have sex with every 1 '7 child molester? 1 8 single day? 1 8 MR. RHEENHART: That question is solely 1 9 MR. RHEINHART: Let me try this again. 1 9 intended to harass the witness and it's 2 Objection to the form. Any question you?re 2 ambiguous as to what a child molester means, 2 1 going to ask her that assumes she knows 2 3. and you're asking for a legal conclusion and 2 2 Jeffrey Epstein, she's ever met Eeffrey 22 instruct her not to answer. 2 3 Epstein, she's ever seen Jeffrey Epstein, knows 2 3 BY MR. 2 4 where he lives, knows what he doesyour own opinion. 2 5 assumes that as part of the question, I will 2 5 MR. RHEINHART: I will again instruct her Page 82 Page 84 deem the question to be ambiguous and compound, 1 not to answer based on her Fifth Amendment 2 because you're asking her to admit as a 2 privilege as well as the question having no 3 predicate that she knows Mr. Epstein. As to 3 legitimate basis and will not lead to 4 any question like that, i am going to instruct discoverable evidence. 5 her to take the Fifth Amendment on that basis. 5 THE WITNESS: On the instruction of my 6 So i would again instruct her to take the Fifth 6 lawyer, must invoke my Fi?h Amendment "7 Amendment as to that question. 7 privilege. 8 THE WITNESS: On the instruction of my 8 BY MR. KUVIN: 9 lawyer, I must invoke my Fifth Amendment 9 Q. Would you agree that Jeffrey Epstein is 1 0 privilege. 1 obsessed with underage females? 1 1. MR. KUVIN: If you want to short circuit 1 1 MR. RHEINHART: Objection to the form. 12 that, anytime i mention Jeffrey Epstein you can 12 It?s ambiguous as to what you mean by 1 3 have a standing objection on that issue. I 3 1 3 "obsessed." l?ll instruct the witness not to 1 4 have no problem. 14 answer based on her Fifth Amendment privilege, 1 5 MR. RHEINHART: Great. 1 5 because the question assumes knowledge of 1 6 BY MR. KUVIN: 6 Jeffrey Epstein. 1'7 Q. Can you explain, if you would, to ajury 17 THE WITNESS: On the instruction of my 1 8 how Mr. Epstein would access underage minor females 1 8 lawyer, i must invoke my Fifth Amendment 1 9 for sex every day? 1 9 privilege. 2 0 MR. RHEINKART: The question is compound that it asks about Mr. Epstein every day, 2 1 Q. How would you de?ne the word "obsessed"? 22 underage females, and involves multiple 2 2 MR. RHEINHART: You can answer that. 23 questions in the same question, and also based 2 3 THE WITNESS: i don?t know. You like it a 2 4 on the standing objection, I would instruct her 2 4 lot. i don?t know. (563.) PROSE COURT REFORTING AGENCY, 832""7506 INC. (561) Page 85 . Page 87 1 BY MR. 1 lawyer, I must invoke my Fifth Amendment 2 Q. Okay. Using your de?nition of obsessed, 2 privilege. 3 would you agree with me that Jeffrey Epstein was 3 BY MR. KUVIN: a; obsessed with underage females? 4 Q. Did you keep ajournal with the names of 5 MR. Same objection; same 5 girls in it in the year 2005?? 6 instruction. 6 MR. RHEINHART: Objection to the form as 7 THE WITNESS: On the instruction of my 7 ambiguous. What do you mean by "journal"? 8 lawyer, I must invoke my Fifth Amendment 8 MR. i will de?ne it. 9 privilege. 9 MR. i?lease. 1 0 BY MR. KOVINWhen was the ?rst time that you learned 1 1 Q. Did you keep a pad of paper, either a 1 2 Mr. Epstein was getting a massage from a girl under 12 ringed notebook or some other format with the names 1 3 the age of 16?? 13 of girls and their phone numbers in it in 2005? 3 1 4 MR. RHEINHART: One second. 3. 4 MR. RHEINHART: I'll instruct the witness 1 5 MR. KUVIN: Sure. 3.5 not to answer based on her Fifth Amendment 1 6 MR. RHEINHART: I want to make the 1 6 privilege. Also the question remains '7 standing objection for the reasons previously 1 7 ambiguous. 1 8 stated, the question is otherwise also compound 3. 8 THE WITNESS: On the instruction of my 1 9 in that it assumes multiple facts and asks her it 9 lawyer, I must invoke my Fifth Amendment 2 to answer multiple questions at the same time. 2 privilege. 2 1 PM instruct her not to answer based Fifth Amendment. 2 2 Q. Would you agree with me that you kept a 2 3 THE WITNESS: On the instruction of my 2 3 pad of paper or ajournal, however you want to 2 4 lawyer, I must invoke my Fifth Amendment 2 4 describe it, that contain the names of hundreds of 2 5 privilege. 2 5 underage girls and their phone numbers? Page 8 6 Rage 88 1 BY MR. 1 MR. Object to the form ofthe 2 Q. Do you know who owns the home at 358 2 question. It?s compound and asking her to 3 El Briilo Way? 3 answer inuitiple questions at the same time. 4 MR. RHEINHART: Same instructions as to 4 It?s also leading, and i would instruct her not 5 the standing objection. 5 to answer based on her Fifth Amendment. 6 THE WITNESS: On the instruction of my 6 THE WITNESS: On the instruction of my '7 lawyer, I must invoke my Fifth Amendment 7 lawyer, I must invoke rny Fifth Amendment right. a privilege. 8 BY MR. Kayne 9 BY MR. KUVIN: 9 Q. Would you agree with me that you kept a 1 Q. Have you been on Palm Beach Island before? 1 pad of paper, notebook, or journal with the names of 1 3. MR. RHEINHART: i am sorry. Can you 1 hundreds of girls under the age of 16 so that you 12 restate the question? 3.2 could contact them and have them come to i 3. 3 MR. KUVIN: Sure. 1 3 Jeffrey Epstein?s home for sex with him? 1 4 BY MR. KUVIN: 1 4 MR. RHEINHART: Objection to the form as 1 5 Q. Have you been on the Island of Palm Beach 1 5 compound and ambiguous, and i?ll instruct her 1 6 before? 1 6 not to answer based on Fifth Amendment. 1 7 MR. RHEINHART: You can answer that yes or 17 THE On the instruction lawyer, I must invoke my Fifth Amendment 1 9 TRIS WITNESS: Yes. 1 9 privilege. 2 0 BY MR. KUVIN: 2 0 BY MR. KUVIN: 2 1 Q. How many times? 2 1 Q. Do you know Alfredo Rodriguez? 2 2 MR. RHEINHART: instruct her not to 2 2 MR. RHEINHART: I'll instruct the witness 2 3 answer that question based on her Fifth 2 3 not to answer based on her Fifth Amendment 2 4 Amendment privilege. . 2 4 privilege. 3?9 am (561) THE WETNESS: Ont 832-31500 THE WITNESS: On the instruction 0 fmy 3?3? 5 at? are? 3 PROBE COURT REPORTING AGENCY, 22 (Pages 85 to 88) INC. (561) 832*7506 Page 8 9 Page 91 lawyer, i must invoke my Fifth Amendment 1 prosecution by either the State or the federal 2 privilege. 2 government? 3 BY MR. KEVIN: 3 MR. She's not answering that 4 Q. Are you aware that Alfredo Rodriguez has ti question. She?s not required to answer the 5 pled guilty to federal charges for hiding ajournal 5 question. She?s invoked her Fifth Amendment 6 containing the names of women? 6 privilege. She will continue to do so as to 7 MR. RHEINHART: Objection to the form as 7 that question. You can move on. 8 compound and instruct her not to answer. 8 BY MR. KUVIN: 9 THE WITNESS: On the instruction of my 9 Q. Ma?am, are you invoking your Fifth 1 0 lawyer, I must choose to invoke my Fifth 1 0 Amendment because your lawyer is advising you to i 1 Amendment privilege. l. invoke your Fifth Amendment, or because you 2 BY MR. KEVIN: 1 2 personally have a fear that you might be prosecuted 3 Q. Do you have a personal fear of criminal 3 by either the state or the federal government? 4 prosecution as you sit here today? 1 4 MR. We have now been down this 15 MR. RHEINHART: i instruct the witness 5 street four times. She?s not going to answer 3. 6 object to the form. That?s the whole basis why 1 5 the question. You can move along or we can 1 7 one would invoke the Fifth Amendment so clearly 1 7 leave. 1 8 she's does. I am not going to have her answer 18 MR. KUVIN: i am just clarifying the 1 9 the question. It?s solely meant to harass. 3. 9 question, and I appreciate itshe not going to answer 2 0 object. {just want to make sure that have a 2 1 that question? 2 Cl. clear record of every possible machination of 2 2 MR. She's not going to answer 2 2 the question so that I don?t get hit later with 2 3 that question. 2 3 you didn't ask the speci?c question you need 2 4 MR. i think what I need to 2 4 to ask. So, I'm not doing it certainly to 2 5 establish is that she personally has a fear, 2 5 harass. {just want to make sure that the Page 90 Rage 92 1 not her lawyer. So I would like to establish 1 record is very clear of my question. 2 whether the Witness has a personal fear. 2 MR. RHEINHART: I understand. You can 3 MR. Well, ?rst of all, under 3 move on. 4 the Fifth Amendment you don't have to be in 4 BY MR. KUVIN: 5 fear. You just have to believe that the 5 Q. Ma?arn, have you had any direct 6 government believes you can be prosecuted for 6 communications with the State Attorney's office in 7 something. She's been invoking the Fifth 7 the last two years? 8 Amendment on her own. it is implicit in her 8 MR. RHEINHART: When you say "direct 9 invocation in what she fears. She's not going 9 communications," can you clarify? 3. to answer that question. 0 MR. Yes. 1 MR. KUVIN: Well, I tend to disagree. She 1 3. BY MR. KUVIN: 3.2 hasn?t been invoking it on her own. She's been 1 2 Q. You, personally, have you spoken with 1 3 invoking it after you have instructed her to 3 anyone in the State Attorney?s of?ce in the last 1 4 invoke it. So i want to know her personal 1 4 two years? 15 MR. RHEINHART: You can take that up with 3. 5 MR. KUVIN: I can?t imagine there would be 6 the judge then. She?s not answering the 6 a Fifth Amendment for that. '7 question. She's invoking her Fifth Amendment 1 '7 MR. RHBINHART: Let me consult. if i l. 8 on her own accord based on the advice of her 3. 8 might. Okay? 9 lawyer. And you can take it up somewhere else, 3. 9 MR. KUVIN: Sure. it, 2 0 but she?s not answering that question. 2 0 .MR. RHEINHART: It would all depend on 2 1 MR. KUVIN: Well, then let me clarify the 2 1 what was said to her if she could consult with 2 2 record. 2 2 them now. For example, if they consulted and 2 3 BY MR. KUVIN 2 3 they teld her they were about to prosecute, 2 4 Q. Ma?ain, are you invoicing your Fifth 2 4 then there could be a Fifth Amendment claim, 2 5 Amendment because you personally have a concern of 2 5 couldn?t there? 23 (Pages 89 to 92) (561) 832*7500 COURT REPORTING AGENCY, INC. (561) 832-57506 Page 93 Page the statements 1 Q. Have you spoken with anybody at the US. 2 they told her. i mean, that?s certainly not 2 Attorney's Of?ce in the last ?ve years? 3 Fifth Amendment. That?s something that was 3 A. No. 4 told to her. 4 Q. Have you spoken with anyone at the FBI in 5 MR. We'll take that up 5 the last five years? 6 elsewhere if you need to. You can answer. 6 A. No. ?7 MR. KEVIN: Okay. 7 Q. Have you spoken with anyone at the 8 THE WITNESS: No, have not. 8 Palm Beach Police Department in the last five years? 9 BY MR. KEVIN: 9 MR. When you say, ?the Palm 1 Q. All right. Ma'ain, have you had any 1 0 Beach Felice," for any purpose or as related to 1 personal communications with anyone working for the 1 1 this case? Again, for example, if there was 1 2 federal government in the last two years? 1 2 like a parking ticket -- 1 3 MR. RHEINHART: When you say "the federal 1 3 MR. Sure. 1 4 government" do you mean the postal service, the 1 4 MR. RHEINHART: or some other thing, I 1 5 entire federal government, or do you want to 15 want to clarify that. 1 6 clarify that? 3. 6 BY MR. KiiVlN: 1 7 MR. KUVIN: Well, I certainly could leave Q. Let?s, let?s start with broadopen-ended. If she's talked to a post 1 8 work to specific. Can you recall having any 1 9 of?ce employee, that would be interesting, but 1 9 conversations for any reason with the Palm Beach 2 0 certainly not to this case. 2 0 Police Department in the last five years? 2 1 BY MR. KUVINLet's talk about the US. Attorney?s 2 2 Q. Okay. Do you have knowledge whether or 2 3 Of?ce or anyone working on behalf of the US 2 3 not the Palm Beach Police Department ever requested 2 4 Attorney?s Of?ce. 2 4 for you to come in for an interview at any tinie in 2 5 A. l-lave I personally ever spoken to anyone? 2 5 the last ?ve years? l?an 94 Page 96 1 Q. Yes, ina?am, personally have you ever had 1 MR. If you know the answer to 2 any conversations with anyone at the Attorney's 2 that question because that?s something your 3 Of?ce or one of their -- one -- a person 3 attorney told you, you don?t have to answer 4 representing to be from that of?ce in the last two 4 that question. Otherwise, go ahead and answer. 5 yearsMR. KUVIN: 7 Q. Okay. Do you know, as you sit here today, '7 Q. Okay. When did you. ?rst retain an 8 whether or not you ever were requested to give a 8 attorney? What date did you ?rst retain a I 9 statement by the State Attorney's office for the 9 mean, let me clarify. What date did you first 1 0 Palm Beach Police Department? 1 0 retain a criminal attorney? 1 1 MR. May 1 consult? 1 1 MR. l'll instruct her not to 1 2 MR. KUVIN: Yes. 12 answer based on the Fifth Amendment privilege. 1 3 MR. RHEINHART: You may answer. And for 1 3 THE WITNESS: On the instruction of my 1 4 the record, 1 was just determining whether the 1 4 lawyer, I must invoke my Fifth Amendment 5 answer to that question would be protected by 1 5 privilege. 1 6 the attorney?client privilege. 6 BY MR. KWLN: 1 7 MR. KUVIN: Understood. 1 7 Q. Did you first retain a criminal attorney 1 8 THE WITNESS: No, i don?t. i don?t know. 1 8 in the year 2005? 3. 9 BY MR. new: 1. 9 MR. Same instruction. 2 0 Q. Let me clarify the last two questions i 2 0 THE WITNESS: On the instruction of my 2 1 asked about the State Attorney?s Office and the US. 2 1 lawyer, i must invoke my Fifth Amendment 2 2 Attorney?s Office. Have you spoken with anybody 2 2 privilege. 2 3 personally at the State Attorney's Of?ce in the 2 3 BY MR. KUVIN: 2 4 last five years? 2 4 Q. Did you retain a criminal attorney 2004? 24 gas 93.to 96) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 ?an??u??im?i??mm-WM? new: 333% lid??- itk'i - .- I earner-?amend anagram marred new meantime-mama. "marmemamree mime martian Page 97 Page 99 3. MR. RHEINHART: Same instruction. 3. assumes facts that have not been established 2 THE WITNESS: On the instruction of my 2 and it's compound. 3 lawyer, I must invoke my Fifth Amendment 3 THE On the instruction of my 4 privilege. 4 lawyer, I must invoke my Fifth Amendment 5 BY MR. KUVIN: 5 privilege. 6 Q. Have you ever worked as a professional 6 MR. And to clarify the '7 model? '7 objection is that it assumes that she's ever 8 MR. RHEINHART: May consult? 8 met or knows anything about Jean-Luc Brunei. 9 MR. KUVIN: Sure. 9 BY MR. KUVIN: 0 MR. REEINHART: You can answer the Q. Were you ever promised anything regarding 1 1 question. - 1 your modeling career by Jeffrey Epstein? 12 THE WITNESS: Yes. 12 MR. RHEINHART: Same objection, instruct 1. 3 BY MR. KUVIN: 3 the witness not to answer. 1 4 Q. When? 1 4 THE WITNESS: On the instruction of my 1 5 A. I don't remember. i don?t remember the dates. 1 5 lawyer, I must invoke my Fifth Amendment 1 6 it was at least maybe ten years ago. 1 6 privilege. 17 Q. And you?re how old now? - 17 BY MR. KUVEN: 1 8 MR. RHEINHART: I?ll instruct the witness 1 8 Q. You would agree with me that there is a 1 9 not to answer the question. Nice try. 9 ?nancial arrangement between Jean-Lac Brunei and 2 0 Instruct you not to answer based on 2 0 Jeffrey Epstein, do you not? 2 1. your Fifth Amendment privilege. 2 1 MR. Objection. it assumes she 2 2 On the instruction of my 2 2 has any knowledge of either Mr. Epstein or 2 3 lawyer, I?m going to invoke my Fifth Amendment 2 3 Mr. Brunei, and as to that she is going to 2 4 privilege. 2 4 invoke her Fifth Amendment privilege. The 2 5 MR. KUVIN: I'm just trying to find out. 2 5 question is compound and therefore ambiguous. Page 98 Page 100 1 MR. RBEINHART: Like I said, good try. 1 THE WITNESS: On the instruction of my 2 Move on. 2 lawyer, I must invoice my Fifth Amendment 3 BY MR. 3 privilege. 4 Q. With respect to your work as a 4 BY MR. KUWN: 5 professional model, what company did you work for? 5 Q. Would you agree with me that 6 MR. RHEINI-IART: Instruct the witness not 6 Ghislaine Maxwell provides underage girls to 7 to answer based on the Fifth Amendment 7 Mr. Epstein for sex? 8 privilege. 8 MR. Objection to the form. it 9 THE WITNESS: On the instruction of my 9 assumes she knows anything at all about 10 lawyer, I invoke my Fifth Amendment privilege. 1 Ghislaine Maxwell and asks her to assume that 3. BY MR. KUVIN: 1 she does, and therefore it is compound and 2 Q. What is your understanding of 2 ambiguous, and I would instruct her not to 3 Mr. Bpstein's involvement with the modeling 1 3 answer. 3. a industry? 1 4 THE WITNESS: Upon the instruction of my Ii 5 MR. RHEINHART: Standing objection, and - 15 lawyer, I must invoke my Fifth Amendment 1 6 instruct the witness not to answer based on 6 privilege. 3.7 Fifth Amendment, on that basis. 17 MR. KUVIN: That's a good point. Take a 3. 8 THE WITNESS: Upon the instruction of my 1 8 look at what we?ll mark as Exhibit 10. 1 9 lawyer, I must invoke my Fifth Amendment 1 9 (Plaintiffs Exhibit No. It} was marked for 2 privilege. 2 identi?cation.) 2 3. BY MR. KUVIN: 2 1 MR. KUVIN: All me to show it to the 2 2 Q. Were you ever promised anything regarding 2 2 camera first. 2 3 your modeling career by Sean-Lue Brunel? 2 3 MR. RHEENHART: Okay. 2 4 MR. RHEINHART: instruct the witness not 2 4 MR. KUVIN: Okay. 2 5 to answer based on Fifth Amendment, also 2 5 THE, WITNESS: Okay. 25 (Pages 97 to 100) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (563.) 832*7506 Page 101 Page 103 1 BY MR. KUVIN: 1 You?re asking the witness three 2 Q. Take a look at what we marked as Exhibit 2 questions at the same time, and I would 3 10. Do you recognize the two people in that 3 instruct her not to answer based on the 4 photograph? 4 Fifth Amendment. 5 MR. I?ll instruct the witness 5 THE WITNESS: On the instruction of my 6 not to answer based on her Fifth Amendment 6 lawyer, i must invoke my Fifth Amendment 7 privilege. 7 privilege. 8 THE, WITNESS: On the instruction of my 8 MR. KUVIN: Just so we?re clear, had she 9 lawyer, I must invoke my Fifth Amendment 9 answered the first two questions, then 1 privilege. 2L 0 obviously I wouldn?t have to ask the third one 1 1 BY MR. KUVIN: 1 1 that has all of them in it but 1 2 Q. Would you agree with me that?s 1 2 MR. RHEINHART: If you had accepted her 1 3 Ghislaine Maxwell on the right and Jeffrey Epstein 1 3 answer, you would have known that she wasn?t 1 4 on the left? 1 4 going to answer these, and we could have saved 1 5 MR. Objection to the form. It 15 a few minutes. 1 6 assumes that she knows who Ghislaine Maxwell 1 6 MR. And as you well know, I must 1 "7 and Jeffrey Epstein are, and therefore its 1 7 ask the question in order to gain the inference 1 8 compound and ambiguous, and i would instruct 8 at trial. 1 9 her not to answer. 1 9 MR. RHEWHART: i understand. 2 0 THE WITNESS: On the instruction of my 2 0 MR. KUVIN: All right. 2 1 lawyer, I must invoke my Fifth Amendment 2 1 (Plaintiff?s Exhibit No. 12 was marked for 2 2 privilege. 2 2 identification.) 2 3 MR. Okay. I will mark this as 2 3 BY MR. KUVIN: 2 4 Exhibit 1 1. 2 4 Q. Do you recognize the gentleman that is 25 25 shown~~ Page 102' Page 104 1 (Plaintiff?s Exhibit No. ll was marked for 1 MR. RHEINHART: We?ll have a job here. 2 identi?cation.) 2 MR. That is true. 3 BY MR. Kt]sz 3 BY MR. KUVIN: 4 Q. Let me show you what we marked as 4 Q. that is shown in Exhibit 12? 5 Exhibit 1 1. Hang on one second. 5 MR. KUVIN: Let tne hold this for the 6 MR. RHEINHART: Sure. 6 camera first. 7 BY MR. KUVIN: 7 MR. RHEZNHART: i?m sorry. Is there a 8 Q. Do you recognize the young lady shown in 8 question pending? 9 Exhibit 11?? 9 MR. KUVIN: Yes. 1 0 MR. i?li instruct the witness 0 BY MR. KUVIN: 1 1 not to answer based on her Fifth Amendment 1 1 Q. Do you recognize the gentleman shown in 1 2 privilege. 2 Exhibit 12? 1 3 THE WITNESS: On the instruction of my 1 3 MR. RHEINHART: I instruct her not to 1 4 lawyer, i must invoke my itth Amendment 1 4 answer based on the Fifth Amendment. 1 5 privilege. 1 5 THE WITNESS: On the instruction lawyer, i rnust invoke my Fifth Amendment 17 Q. Do you agree with me that the young girl 1 7 privilege. 1 8 shown in Exhibit ll was recruited by Ghislaine 3. 8 BY MR. KUVIN: 1 9 Maxwell to, for sexual activity with 1 9 Q. Would you agree with me that that is 2 ieffrey Epstein? 2 0 Prince Andrew shown in Exhibit 12? 2 1 MR. Objection to the form. It 2 1 MR. RHEINHART: Same instruction. 2 2 assumes she knows who the person is in Exhibit 2 2 THE WITNESS: On the instruction of my 2 3 it, and assumes she knows who Ghislaine Maxwell 2 3 lawyer, i must invoke my Fifth Amendment 2 4 is, and assumes she knows who .ieffrey Epstein 2 4 privilege. 25 25 26 (Pages 101 to 104) (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (561) 832*7506 .t i 3 am ssh-casement; ?mum??krri. ?met 9min El'i??ilifl bim?r' 2? Page 105 Page 107% i 3. BY MR. Kovrn: 1 break now. i 2 Q. Would you agree with me that you have been 2 MR. KUVIN: Okay. 3 present where Jeffrey Epstein and Prince Andrew have 3 THE VIDEOGRAPHER: We're now off video 4 had sexual relations with underage girls? 4 record. The time is ll:57 am. 6 MR. Objection to the form, 5 (A luncheon recess was held.) 6 it?s compound in that it assumes she knows who 6 (Plaintiff's Exhibit No?s 4 was marked for 7 the person is in Picture 12, she knows who 7 identification.) 8 Prince Andrew is, and she knows who Jeffrey 8 (Plaintiffs Exhibit No. 5 was marked for 9 Epstein is. it?s compound and ambiguous, and 9 identi?cation.) 3% i. l?ll instruct her not to answer based on her 1 0 THE VIDEOGRAPHER: We're now on video 1 1 Fifth Amendment. 11 record. The time is 1:02 p.111. 12 THE WETNESS: On the instruction of my 12 MR. KUVIN: All right, counsel. l?m going 13 lawyer, must invoke my Fifth Amendment 1 3 to ask a couple more general questions, and 4 privilege. 1 4 then when we get into the speci?individual girls, I just want to make sure, 1. 6 Q. Would you agree with me that Prince Andrew 1 6 once again, on the record, as we've done in l. 7 and Jeffrey Epstein used to share underaged girls 1 7 every deposition in this case, that we?ll use 1 8 for sexual relations? 1 8 the Plaintiff?s full name with the l. 9 MR. RHEINHART: Same objection previously 3. 9 understanding that the final transcript will 2 0 stated, requires her to also speculate who 2 0 only contain their initials, and there will be 2 1 Prince Andrew is. I instruct her not to answer 2 a key at the conclusion that?s only provided to 2 2 based on the Fifth Amendment. 2 2 the parties in this case and their counsel to 2 3 THE WITNESS: On the instruction of my 2 3 be kept con?dential going forward. But 2 4 lawyer, I must invoke my ifth Amendment 2 4 obviously, for the purposes of this deposition, 25 privilege. 25 we will be using full names. Page 106 Page 108 1 MR. RHEINHART: Also requires speculation 1 MR. RHEINHART: Agreed. 2 as to who Jeffrey Epstein is as well. 2 MR. Okay. Is there any 3 BY MR. KUVIN: 3 disagreement with that around the table? 4 Q. Do you know who Prince Andrew is? 4 MR. HOROWITZ: Agreed. 5 MR. It?ll instruct her not to 5 MR. Agreed. 6 answer based on the Fi?h Amendment. 6 MS. EZELL: Agreed. 7 THE WITNESS: On the instruction of my 7 MR. lack, do you agree to the -- 8 lawyer, I must invoke my Fifth Amendment 8 MR. GOLDBERGER: I thought I'm not a part 9 pdv?ege. 9 ofit 1 0 MR. KUVEN: it's almost 12:00. Do you 1 0 MR. KUVIN: Well, you?ve been playing a 1 1 want to take a quick lunch? 1 1 part, so i want to make sure you agree. 12 MR. RHEINHART: Sure. How much longer do 2 12 MR. Yeah, I agree. i agree. 13 you think you will be, Mr. Kuvin, before we go 13 MR. Hold on. Let mejust 1 on to other counsel? 1 4. explain to her what we?re talking about. 1 5 MR. KUVIN: Probably not that much longer. 15 MR. KUVIN: Please do. i; 1 6 MR. RHEINHART: Okay. 1 6 MR. RHEINHART: But when the transcript is 1 7 MR. have to get through a couple 1 7 typed up, it won't have her name it will just 18 of more generic stuff, and then get into the - 18 have initials. But we?ll get a code that 1 9 specifics of my cases and then -- II. 9 explains the name. So that way you would be 2 0 MR. Okay. So, we, butjust so 2 0 asked if you recognize the name not a set of 2 1 we have a sense of planning whether this is the 2 1 initials that you may not understand or a lane 2 2 right time for a lunch break. You're not going 2 2 Doc number that you do not know. 2 3 to ?nish in the next 15 or 20 minutes? 2 3 MR. KEVIN: That's way too confusing. 2 4 MR. KUVIN: No, not even close. 2 4 Okay? 2 5 MR. Okay. Let?s take a lunch 2 5 MR. RilEiNl-iAR?l?: Correct. 27 (Pages 105 to 108) (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (561) 832*7506 Page 109 Page 111 1 BY MR. 1 objection to the form. 2 Q. Let?s take a look at what I?ve marked 2 THE WETNESS: At the instruction of my 3 premarked as Exhibit 4. it's a stack of documents, 3 lawyer, I must invoke my Fifth Amendment 4 just so you understand what this is and your 4 privilege. 5 attorney can object or agree or disagree as he secs 5 BY MR. KUVIN: 6 but this is a stack of documents that was part 6 Q. Yes. Do you know Alex Hall? 7 of the trash pull from Jeffrey Epstein?s home as 7 MR. RHEINHART: Instruct the witness not 8 part of the criminal investigation. Just so you're 8 to answer the question based on her Fifth 9 aware of what these are. 9 Amendment privilege. 1 0 MR. That was retrieved, that 1 WITNESS: On the instruction of my 1 1 was retrieved by the Palm Beach Police 1 1 lawyer, i must exercise my Filth Amendment 12 Department from the trash 12 privilege. 1 3 MR. KEVIN: That?s correct. 13 BY MR. KUVIN: 1 4 MR. RHEINHART: at the home of what is 1 4 Q. Will you agree with me that on the ?rst 1 5 known to be Mr. Epstein's home? 15 page of Exhibit 4, you were to arrange for roses to 1 6 MR. KUVIN: Correct. 1 6 be delivered to Jane Doc No. 103 at her high school 17 MR. RHEINHART: Okay. 17 performance? 1 8 MR. KUVIN: All right. And that?s not a 18 MR. RHEINHART: Objection to the form. 1 9 question. Ijust wanted to kind of give you a 1 9 it?s compound in that it assumes this is the 2 context for what l?m going to be asking you 2 0 witness?s handwriting and assumes the witness 2 1 about. 2 1 knows a person by the name of Jane Doc No. 103 2 2 MR. RHEINHART: Thank you. 2 2 and the witness otherwise knows .ieffrey Epstein 2 3 BY MR. 2 3 whose name is at the bottom of the paper, and 2 4 Q. All right. in taking a look at Exhibit 4, 2 4 therefore, its compound and ambiguous, and 2 5 i'd like you to take a look at the front page, the 2 5 instruct her not to answer. Page 110 Page 112 1 first page of those documents. 1 THE On the instruction of my 2 ls that your handwriting, ma?am? 2 lawyer, I must exercise my Fifth Amendment 3 MR. RHEINHART: Instruct the witness not 3 right. 4 to answer based on the Fifth Amendment 4 MR. KUVIN: i forgot to mention this at 5 privilege. 5 the beginning, but objection to form usually 6 THE At the instruction of my 6 covers all that stuff like vague and compound, 7 lawyer, I must exercise my Fifth Amendment '7 and ?m 8 right. 8 MR. Okay. 9 BY MR. 9 MR. KUVIN: l'li leave it up to you, 1 Q. And, in fact, that is your handwriting on .1 0 but objection to form as far as the civil arena 1 1 this notepad, is it not? 1 context will cover all of those. 12 MR. RHEINHART: Same instruction. it?s 1 2 MR. Just ?gured I?d make the 1 3 the same question. 1 3 record clear in case we ever have an issue, or 1 4 THE WITNESS: On the instruction of my 1 Al in case you want to correct it based on what I 1 5 lawyer, i must invoke my Fifth Amendment right. 1 5 believe to be the improper form, I will give 1 6 BY MR. KUVIN: 1 6 you a chance to correct it. 17 Q. In this note do you agree that you 1 7 BY MR. KUVIN: 1 8 arranged for an extension of one month on the rental 1 8 Q. No problem. All right. On Page young lady under the age of i6? 1 9 Exhibit 4, if you?d take a look at that. Is that 2 0 MR. RHEINHART: Objection to the form. it 2 0 your handwriting? 2 1 is compound. It assumes that this is her .2 1 MR. RHEINHART: Instruct the witness not . 2 2 handwriting. it doesn?t identify who the young 2 2 to answer based on the Fifth Amendment 2 3 lady might be, and it?s otherwise ambiguous, so 2 3 privilege. 2 4 i instruct her not to answer on the Fifth 2 4 THE WITNESS: On the instruction of my 2 5 Amendment privilege in addition to the legal 2 5 lawyer, 1 choose to exercise my Fifth Amendment 28 (Pages 109 to 112) (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (561) 832*7506 ii it i arenas-.m- matters-"reaw-rawa; '3 :ai'ni'm ?ilk anemraxaamxammamx;.1" as $5 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, Page 113 Page 115 3. right. 1 MR. RHEINHART: Okay. i would be happy 2 BY MR. KUVIN: 2 to. 3 Q. Do you know who Larry is, as referred to 3 MR. KUVIN: i just want to clarify, 4 in Page 2 of Exhibit 4? 4 because I don?t think -- 5 MR. RHEINHART: i?m sorry. Can you -- 5 MR. Okaydon?t think this is a 7 Q. Do you know who 7 problem, but I just want to clear it up. 8 MR. RHEINHART: restate the question? 8 MR. RHEINHART: Thank you, Mr. Kuvin. 9 BY MR. 9 Fit let her answer that question. 10 Q. Do you know who Larry is as referred to in 10 MR. KUVIN: Not a problem. 1 1 Page 2 of Exhibit 4? i 1 3. MR. RHEINHART: So the question pending 2 MR. REEINHART: So, just so I?m clear, 12 is, is that your handwriting? 1 3 what the question is, the document on its face 13 MR. KUVIN: Correct. 1 4 has the name Larry in it. You?re just asking 1 4 BY MR. KUVIN: 1 5 this witness whether she knows who this person 3.. 5 Q. is this your handwriting? Just yes or no. 1 6 Larry isMR. KEVIN: Correct. 1 '7 Q. Okay. Thank you. All right. Let?s look 3. 8 MR. instruct the witness not 18 at Page 4 of Exhibit 4. All right. This one?s a 1 9 to answer based on her Fifth Amendment 1 9 little different. is this your handwriting? 2 0 privilege. 2 0 MR. RHEINHART: Let me consult with her 2 1 THE WITNESS: On the instruction of my 2 1 again. 2 2 lawyer, i must invoke my Fifth Amendment right. 22 Okay. That's fine. You can answer 2 3 BY MR. KUVEN: 2 3 the question consistent with the 2 4 Q. Do you know why Larry was recommending 2 4 conversation we just had. 25 that Mr. Epstein leave? I 2 5 THE WITNESS: No. Page 114: Page 116 1 MR. Objection to the form and 3. BY MR. KUVIN: 2 instruct the witness not to answer based upon 2 Q. you know who Danielle is as referred to 3 her Fifth Amendment privilege. 3 in this note of Page 4 of Exhibit 4? 4 THE WITNESS: On the instruction of my 4 MR. instruct the witness not 5 lawyer, I must invoke my Fifth Amendment right. 5 to answer based on her Fifth Amendment 6 BY MR. KUVIN: 6 privilege. '7 Q. Would you agree with me that Larry was 7 THE WITNESS: On the instruction of my 8 calling to wam Mr. Epstein to leave town because he 8 lawyer, I must exercise my Fifth Amendment 9 was going to be arrested? 9 right. 1 0 MR. Objection to the fonn. 1 0 BY MR. KUVIN: 1 1 The question assumes facts that are not before 1 1 Q. All right. Let's look at Page 5, 12 her, and it requires her to speculate, and also 12 Exhibit 4. 1 3 implies that she knows anything at all about 13 Before we go to Rage 5, rather, going 1 4 Jeffrey Epstein, so i will instruct her not to 1 4 back to Page 4 for a minute. Will you agree with me 1 5 answer. 1 5 that Danielle as referred to in Page 4 of Exhibit 4 1 6 THE) WITNESS: On the instruction of my 1 6 is a girl that is under the age of 16? 17 lawyer, i wish to exercise my Fifth Amendment 1 7 MR. RHEINHART: Object to the form. You 1 8 right. 1 8 previously asked if she knew who Danielle was, 1 9 BY MR. KUVIN: 1 9 and she invoked her Fifth Amendment privilege. 2 Q. Take a look at Page 3 of Exhibit 4, 2 0 Since the new question presumes that she does 2 1 please. is that your handwriting? 2 1 know who Danielle is she is going to invoke her 2 2 MR. RHEINHART: i?il instruct her not to 2 2 Fi?h Amendment privilege upon my instruction. 2 3 answer based on the Filth Amendment privilege. 2 3 MR. KUVIN: All right. Let?s look at 2 4 MR. Before we do that, would you 2 4 Page 5. consult with her? 2 5 MR. Let her answer. antenna is Alternating?! tbs? stills}: tier: men an st 5.5mm 1.135; We tavern} as t; is? 3.132 Kareem erg sexism-:5 cinema-ems: fel??ia examiner; ire?25:: were 29 (Pages 113 to 116) INC. (561) 832?37506 .{i?ltti?iuln?i Ii?m??fax Wm manta-m?; ii Wigwam was: mm? .em?mawwxammwamaremimwa i Page 1.17 Page 119 1 MR. KUVIN: i?m sorry, go ahead. it that Page 5 of Exhibit 4 appears to be a receipt for 2 THE WITNESS: On the instruction of my 2 books ordered through Amazon.com? 3 iawyer, i must invoke my Fifth Amendment 3 MR. You can answer that yes or 4 privilegelooks like a receipt from 6 Q. All right. Take a look. at Page 5, if you 6 Amazon. 7 wouid. Have you ever ordered anything, anything 7 BY MR. KUVIN: 8 yourself from Amazon.com? 8 Q. Okay. And did you piace this order for 9 MR. You're asking for herseif 9 Jeffrey Epstein? or anyone eise if she has ever piaced an order 1 0 MR. RHEINHART: Instruct the witness not 5 1 with Amazon.com for any reason? 1 1 to answer the question in that the question 12 MR. KUVIN i am asking whether she 1 2 presumes that she knows who Jeffrey Epstein is, 3 personaliy has ever placed an order with a 13 and therefore, I instruct her not to answer. 1 4 company called Amazon.com. 1 4 THE WITNESS: On advice of counsel, 1 must 15 MR. RHEINHART: Yes or no. You can answer 15 invoke my Fifth Amendment privilege. 16 that. 16 BY MR. KUVIN: 1 7 THE WITNESS: Yes. Q. Have you ever read the book identi?ed in 18 BY MR. KUVIN: 18 Page 5 of Exhibit 4 called Slave Craft: Road Maps 1 9 Q. Okay. So you would agree with me that you 1 9 for Erotic Servitude Principals, Skills and Tools? 2 0 know what Amazoncom is? 2 0 MR. Instruct the witness not I 2 A. Yes. 2 3. to answer based on her Fifth Amendment 2 2 Q. Okay. Now, have you ever pieced an order 2 2 privilege. 2 3 through Amazon.com for things to be delivered at 2 3 THE WITNESS: On the instruction of my 2 4 358 El Briilo Way? 2 4 lawyer, i must choose to invoke my Fifth 2 5 MR. RHEINHART: Instruct the witness to 2 5 Amendment right. Page 118 Page 120 1 invoke her Fifth Amendment privilege as to that 3. BY MR. KUVIN: 2 question. 2 Q. {)id you ever see that book I just 3 THE On the instruction of my 3 described at the home of Jeffrey Epstein on 4 lawyer, i must invoke my Fifth Amendment 4 358 Way? 5 privilege. 5 MR. Objection to the form in 6 BY MR. KUVIN: 6 that it presumes she knows Jeffrey Epstein and '7 Q. Wili you agree with me '7 has ever been to 358 El Brillo Way. So, i 8 MR. RHEINHART: i'm sorry, Mr. Kuvin, for, 8 instruct her not to answer based on the Fifth 9 for the record, the page, pages of this exhibit 9 Amendment. 1 are not numbered, but the page we?re looking at 1 0 THE WITNESS: On the of my 1 purports to be a receipt for an order from 1 1 lawyer, I must choose to invoke my Fifth 1 2 Amazon.com; is that correct? 12 Amendment right. 13 MR. KUVIN: Correct. ijust want her to 3 BY MR. KUVIN: 1 4 establish foundation before i got into 1 4 Q. Have you ever seen the book, Training With 1 5 speci?cs, 1 5 Miss Abernathy: A Workbook for Erotic Slaves and 1 6 MR. RHEINHART: No, but you referred to it 1 6 Their Owners, at the home of Jeffrey Epstein on 1 7 as Page 5, but they are not numbered, so Ijust 17 358 El Way? 1 8 wanted to make sure that we?re iooking at the 1 8 MR. RHEINHART: Same objection and same 9 same page on the exhibit. 1 9 instruction as the previous question. 2 0 MR. KUVIN: That is true. i?m just trying 2 0 THE WITNESS: On the instruction of my 2 1 to establish foundation for the questions i'm 2 lawyer, I must choose to invoke my Fifth 2 2 about to ask her. 2 2 Amendment right. 2 3 MR. RHEINHART: Understood. 2 3 BY MR. KUWN: 2 4 BY MR. KEVIN: 2 4 Q. Have you ever read that book that ijnst 2 5 Q. All right. Ma?am, would you agree with me 2 5 described which is shown in Fage 5 of Exhibit 4? 30 (Pages 117 to 120) (561) 832*7500 PROSE REPORTING AGENCY, INC. (561) 832*7506 Page 121- Page 3.23 1 MR. Same instruction. 1 BY MR. KUVIN: 2 THE WITNESS: On the instruction of my 2 Q. This note, Page 9 of Exhibit 4, appears to 3 3 4 Amendment right. 4 there's a blanked out name, for ll then Brittany 5 BY MR. KUVIN: 5 couid work at 6. Do you know anyone with the name 6 Q. Let?s look at the sixth page of Exhibit 4, 6 Brittany? 7 please. Is that your handwriting? 7 MR. If she knows anyone in the 8 A. No. 8 world by that name? 5 9 Q. All right. Let?s look at Page 7. is that 9 MR. Yeah. We could start with 0 your handwriting? that. A. No. It IL MR. RHBINHART: i?m saying, in the 1 2 Q. Okay. Look at the next page which wouid 12 context, are you asking in the context of this 1 3 be Page 3. Is that your handwriting? 3 note which you just read, or are you asking, I 4 A. No. 4 generically, does she know anyone in the world i 5 Q. Let?s see how much quicker this goes. 1 5 by the name of Brittany? 1 6 Let's look at Page 9. is that your handwriting? 1 6 MR. KUVEN: Why don't we first Look at Page 9 again, if you would. 18 BY MR. 1 9 MR. RHEINHART: When you say Page 9, It 9 Q. is this note referring to you when it 20 that's the page that purports to say 10:00. 2 0 says, "Sarah"? 2 1 MR. KUVIN: Dr. Bard. 2 1. MR. RHEINHART: instruct the witness not 2 2 MR. -- Dr. Bard at the top? 2 2 to answer based on her Fifth Amendment 2 3 MR. KUVIN: Correct. 23 privilege. 2 4 MR. RHEINHART: Okay. 2 4 THE WITNESS: On the advice of counsel, 2 5 2 5 must invoke my Fifth Amendment right. Page 122 Page 124% 1 BY MR. KUVEN: 1 BY MR. KUVZN: 2 Q. Do you know who Dr. Bard is? 2 Q. in the context of this note, do you know 3 MR. RHEINHART: Instruct the witness not 3 who Brittany is? 4 to answer based on the Fifth Amendment, because 4 MR. RHEINHART: Sarne instruction. 5 this sheet of paper has Jeffrey Epstein's name 5 Till?) WITNESS: on the advice of counsel, I 6 on the bottom, so the question implies that she 6 must invoke my Fifth Amendment right. 7 knows some connection between Dr. Bard and 7 BY MR. KUVEN: 8 Mr. Epstein. 8 Q. All-right. Let's look at Page 10. 9 MR. KUVZN: Hang on a minute. Based on 9 MR. RHEINHART: Mr. Kuvin, let me go back. the objection, let me reword the question. 1 0 MR. KUVIN: Sure. 1 1 BY MR. KUVIN: 1 1 MR. RHEINHART: As to Page 1 of this 1 2 Q. Independent from this note and independent 12 exhibit, i think you had asked the witness 1 3 from anyone who may or may not be known as i. 3 whether this was her handwriting. i 4 ieffrey Epstein, do you know anyone by the name of 3. 4 MR. Do you want to have her go 1 5 Dr. Bard? 3 15 back and answer? 1 6 A. l?m Sorry. Ask the question again. 1 6 MR. RHEINHART: Yes, I would. Having 7 Q. Yes. I don?t want you to assume anything consuited with her further, I will have her go i. 8 from, the purpose of my question has anything to do 1 8 back to this question. 1 9 with someone who may be known as Jeffrey Epstein. 9 MR. KUVIN: Let's do that. I'll, I'll go 2 0 All I?m asking you is, generally, do 2 0 back and ask the question so that we can be 2 1 you know a person by the name of Dr. Bard? 2 1 clear. 2 2 MR. Let me consult. 2 2 BY MR. KUVIN: 2 3 MR. KUVIN: Yes, yeah. 23 Q. On the Exhibit 4, the first page of 2 4 THE WITNESS: At the advice of counsel, I 2 4 Exhibit 4, ma?am, is that your handwriting? Yes or 2 5 must invoke my Fifth Amendment right. 2 5 no. 31 (Pages 121 to 124) (563.) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Page 125_ Page 127 1 A. No. 1 it in giving my advice, so thank you for 2 Q. Okay. All right. Let's skip Page 10, 2 clarifying. 3 because i think that?s just a duplicate, and go to 3 MR. Absolutely. 4 Page 11, if you would. 4 BY MR. KUVIN: 5 MR. RHEINHART: Page ll is -- 5 Q. All right. In Page 11 of Exhibit 4, 6 MR. KUVIN: It looks like DTG Operations, 6 there's a reference in the top right-hand corner, a 7 d/b/a Dollar Rent a Car. I 7 message to a Mr. Goldsmith. Do you see that? 8 MR. RHEINHART: Got it. it's a printed 8 A. Uh-huh. 9 sheet, not a handwritten sheet. 9 Q. Yes? 1 0 MR. Correct. 1 0 MR. RHEINHART: You have MR. RHEINHART: Okay. Thank you. 1 1 on the record. 12 BY MR. KUVEN: 3.2 THE WITNESS: Yes, I see it. 3 Q. All right. Do you know a gentleman by the 1 3 BY MR. KUVIN: 1 4 name of Janusz Banasiak, spelled Jeannie-z, i 4 Q. Okay. All right. Do you know who 1 5 3.5 Mr. Goldsmith is? 3. 6 MR. RHEINHART: instruct the witness not 1 6 MR. RHEENHART: instruct the witness 1 7 to answer based on her Fifth Amendment 1 7 not to answer based on her privilege against 18 privilege. 18 self-incrirnination. 1 9 THE WITNESS: On the instruction of, my 1 9 THE WITNESS: At the advice of counsel, 1 2 0 lawyer, i must invoke my Fifth Amendment 2 0 must invoke my Fifth Amendment privilege. 21 privilege. 21 av MR. KUVIN: 22 BY MR. KUVIN: 22 Q. Is this your handwriting on exhibit on 2 3 Q. Ma?am, isn?t it true that you rented cars ?2 3 the messages shown in Exhibit 4, Page ll? 2 4 through Dollar Rent a Car for underage girls, girls 2 4 MR. RHEINHART: Same instruction. 2 5 under the age of 18? 2 5 THE WITNESS: At the advice of counsel, 1 Page 126 Page 128 1 MR. RHEINHART: instruct the witness not 3. must invoke my Fifth Amendment privilege. 2 to answer based on the Fifth Amendment 2 MR. Hold on a second, Sarah. 3 privilege. 3 MR. KUVIN: Yeah, check. 4 THE WITNESS: On the instruction of my 4 MR. RHEINHART: Okay. Can you repeat the 5 lawyer, i must invoke the Fifth Amendment 5 question again? Maybe I rnisheard it, 6 privilege. 6 Mr. Kuvin. 7 BY MR. KUVIN: 7 MR. KUVIN: Yeah, not a problem. Let me 8 Q. Did you rent any cars from Dollar Rent a 8 lay a little foundation for it. 9 Car in West Palm Beach in the last five years? 9 MR. RHEINHART: That?s okay. if you can 1 0 MR. RHEINHART: Same instruction. 1 0 just ask the question again. I think I just 1 1 THE WITNESS: On the instruction of my 1 misheard what you were asking. 1 2 lawyer, I must invoke my Fifth Amendment 12 BY MR. KUVINI 1 3 privilege. - 13 Q. Is this your handwriting shown on the 1 4 BY MR. KUVIN: . 14 messages which is Page ii of Exhibit 4? 5 Q. Let's take a look at Page ll. 15 A. No. 6 MR. RHEINHART: if we can just let me 3. 6 Q. Okay. is this handwriting that of 7 go back, Mr. Kuvin, to clarify the prior two 1'7 Ms. Sioberg? 1 8 questions. When you say, "did you rent,? did 1 8 MR. iohanna -- i?m sorry, Sjoberg, 1 9 you mean did she personally pay for the rental, 1 9 Sjoberg?? How do you pronounce it, Sjoberg? 2 0 or was she, in any way, involved in arranging - 2 0 MS. CADWELL: Sjoberg? 2 1 the rental? 2 1 MR. KUVIN: i know somebody would know. 2 2 MR. sovnv: The second part, in any way 2 2 MR. meannessinvolved in arranging for the rental of a 2 3 pronunciation, I?m sorry? 2 4 vehicle. 2 4 MR. KUVIN: Yes. 2 5 MR. RHEINHART: That's how i interpreted 2 5 32 (Pages 125 to 128) (561) PROBE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 129 Page 131 1 BY MR. KUVIN: 1 appear to be directed weil, let me, let me back 2 Q. Is this the handwriting of 2 up. 3 Johanna Sjoberg, if you know? 3 Page i i of Exhibit 4 appears to be a 4 MR. RHEINHART: Hold on. Let me object to 4 message dated October 2nd, 2005, from Sarah. Do you 5 the form in that it presumes she knows what 5 see that top iett?hand corner? 6 Ms. Sjoberg?s handwriting is like or that she's 6 A. Yes. "7 ever known Ms. Sjoberg. So before you ask the ?7 Q. Okay. At 10:40 am. My question is: Did it 8 question, try to clarify that. 8 you cail and leave a message at 10:40 am. on 9 MR. KUVIN: Weil, that's what I'm trying 9 October 2, 2005, stating: sick and she 1 to find out. 1 0 can?t come today? 1 1 BY MR. KUVIN: 1 1 MR. RHEENHART: instruct the witness not ti 1 2 Q. Do you recognize this as the handwriting 12 to answer the question based on her Fifth 1 3 of Johanna SiobergAmendment privilege. 1 11 MR. RHEINHART: My, my objection to the 4 WITNESS: On the instruction of my 15 form is that you, you haven?t asked her whether 15 iawyer I must exercise my Fifth Amendment i. 6 she actuaiiy knows who Johanna Sjoberg is, or 1 6 priviiege. 17 whether she would recognize her handwriting Upside down at the bottom of i?age would love to ask that 1 9 another phone message dated 1011 of 2005. Appears 2 0 question if she?d answer it. 2 0 to be written to someone named Sarah. Do you see 2 1 MR. snowman Well, if she'll answer, 2 1 that? 2 2 that's a different question. But i think you 2 2 A. Yes. 2 3 need to ask it ?rst otherwise this question is 2 3 Q. Okay. Do you 2 4 ambiguous. 2 4 MR. RHEINHART: Is it written, I'm sorry, 2 5 MR. KUVIN: All right. 2 5 is it written to someone named Sarah or it Page 130 Page 132 1 BY MR, 1 appears to be a phone call from a person named 2 Q. Not, not to beat a dead horse on the 2 Sarah? 3 point, do you know Johanna Sjoberg? 3 MR. KUVIN: From a person named Sarah. 4 MR. i instruct the witness not 4 Thank you. 5 to answeradvice of counsel, I must 6 Q. Did you call someone, anyone on October 1 7 invoke my Fifth Amendment privilege. 7 of 2005 at 9:50 a.n1., to confirm two people, one at 8 BY MR. nevus: 11:00 and one at 4:00 p.rn.? 9 Q. Have you seen iohanna Sjoberg?s 9 MR. RHEINHART: Instruct the witness not 1 0 handwriting in the past? IL 0 to answer based on her Fifth Amendment 3. 3. MR. RHEINHART: Objection to the form as 1 1 privilege against self?incrimination since this 1 2 previously stated. I'ii instruct the witness 12 document was seized from Mr. Epstein's home. 1 3 not to answer. 1 3 THE WITNESS: At the instruction of my IL 4 "ii-IE WITNESS: On advice of counsel, I must 1 4 lawyer, I must invoke my Fifth Amendment 1 5 invoke my Fifth Amendment priviiege. 1 5 privilege. 1 6 BY MR. KUVIN: . 1 6 BY MR. KUVIN: 1 '7 Q. Do you recognize Page 11 in Exhibit 4 as 1 7 Q. Are you the Sarah that?s referred to in i. 8 the handwriting of Johanna 83' oberg? 1 8 these phone messages that we?ve been looking at? 1 9 MR. RHEINHART: Objection to the form for 1 9 MR. RHEINHART: Instruct the witness not 2 the reasons previousiy stated many, many times, 2 0 to answer. 2 1 and i will instruct her not to answer. 2 3. THE WITNESS: On the instruction of my 2 2 THE WITNESS: At the advice of counsel, 1 2 2 lawyer, I must invoke my Fifth Amendment 2 3 must invoke my Fifth Amendment privilege. 2 3 privilege. 2 4 BY MR. KUVIN: 2 4 BY MR. KUVIN: 2 5 Q. Did you ever see these messages the 2 5 Q. Let?s ski Page 12 and go to Page 13 of 33 (Pages 129 to 132) 83247500 PROBE COURT AGENCY, INC. (561) 83247506 (561) 832?7500 PROBE COURT REPORTING AGENCY, '34 INC. (561) 832?7506 (Pages 133 to 136) a (?lmmaker min mr?r?. ?3 new. siixv??lk?orlx :h ram uranium ww' "Su?i i':i Page 133 Page 135 i. this same exhibit, if you would. Okay. 1 Fifth Amendment right. 2 is that your handwriting on Page 13 2 BY MR. 3 which happens to be a note stating "Johanna S. is 3 Q. Are you aware that Jeffrey Epstein would 4 coming"? 4 refer to ?work? as performing naked massages for 5 MR. RHEINHART: Okay. Hold on. Can you I 5 him? 6 just show me what page you're looking at? 6 MR. Object to the form of the 7 Okay. We skipped a page. 7 question. It?s compound and I instruct the 8 THE WITNESS: No. 8 witness not to answer. 9 BY MR. KUVIN: 9 THE On advice of counsel, I Wish 3. 0 Q. Okay. Do you recognize whose it is? 0 to invoke my Fifth Amendment right. 1 1 MR. RHEINHART: Let me talk to you again. 1 1 BY MR. KUVIN: 12 BY MR. KUVEN: 12 Q. Let's take a look at the next page, i?age 13 Q. if it?s a yes, you might want to talk to l3 16. All right. if we look at not the message, the 4 him; if it?s a no, it might be quick. 3. 4 phone message, but the note next to that it says: 15 A. No, no. Sorry. 3.5 Haley on Saturday with Sage at 10:30. 1 6 Q. Let's look at Page 14, same exhibit. The i. 6 Do you know who Haley is as referred 7 note on the right-hand side states, "The girl from 3.7 to in this note? 18 St. Bart's got sick so she won't be able to come. 3. 8 A. On the advice of counsel, I must invoke my 1 9 Sarah got message from her.? First of all, just 3. 9 Fifth Amendment right. 2 0 generally, do you see the note I?m referring to? 2 Q. Do you know who Sage is as referred to in 2 A. Yes. 2 1 this note? 2 2 Q. Okay. Do you know what that is talking 2 2 A. On the advice of counsel, 1 must invoke my 2 3 about? . 2 3 Fifth Arnendment rightMR. GARCIA: I haven't heard the counsel 2 5 Q. is that your handwriting? 2 5 give any advice. Page 134' Page 136 1 A. No. 1 MR. anemnnar; You don't know what we?ve 2 Q. Did Mr. Epstein obtain girls under the age 2 talked about outside of the room 3 of 16 from St. Bart's? 3 MR. GARCIA: lust changing the procedure 4 MR. RHEINHART: Instruct the witness not 4 is all? 5 to answer. Object to the form of the question 5 MR. RBEINHART: i'm changing the procedure 6 in that it presumes that she knows who 6 for Mr. Kuvin. 7 Mr. Epstein is. 7 MR. i?rn all happy for speed. 8 THE WITNESS: On advice of counsel, I must 8 BY MR. KUVBQ: 9 invoke my Fifth Amendment privilege. 9 Q. All right. Let?s look at Page 17 of 1 0 BY MR. KUVIN - 0 Exhibit 4. it appears to be a phone message at the 1 3. Q. All right. Let?s take a look at the next 1 1 bottom dated 9/ 1/05 to Jeffrey from Jean-Lac. Lot 12 page. Appears to be a note, phone message of 1 12 me ask this: Do you recognize the phone number I 3 can't read the date, 2005 to Eeffrey from 1 3 that?s listed there of (646)286-7000? 1 4 Melissa Hanes. Just generally, do you see what For 1 4 MR. RHEINHART: Instruct the witness not 1 5 talking about so we're on the same page here? 1 5 to answer based on her Fifth Amendment 1 6 A. Yes. - 3. 6 privilege and self-incrimination. 7 Q. Okay. Do you know who Melissa Hanes is? 7 THE: WITNESS: On advice of counsel, 1 must 1 8 A. On the advice of counsel, I wish to invoke my 8 invoke my Fifth Amendment right. 3. 9 Fifth Amendment right. 1 9 MR. KUVIN: Let me show this one to the 2 Q. All right. The note appears to say: She 2 0 camera if I could. if you could focus on the 2 1 called again, if she could work any time Monday 2 1 bottom message for me. 2 2 through Friday. 2 2 THE VIDEOGRAPHER: i can't really read 2 3 Do you know what that message 2 3 that. 2 4 pertains to? 2 MR. Do I need to tilt it? 2 5 A. On advice of counsel, 1 wish to invoke my 2 THE I think you need to Page 137 Page 139 1 bring the whole paper up closer. 1 Do you first of all, do you see 2 MR. KUVIN: Towards you? 2 that in front of you? Are we talking about the same 3 THE VIDEOGRAPHER: Yes, towards the tens. 3 thing here? 4 MR. KUVIN: Just pass that up so we can 4 A. Yes. 5 get a good shot of the bottom message. 5 Q. Okay. Do'you know who "Haley" is 6 6 7 please. Let it focus. That's good. Go out. 7 MR. Instruct the witness not 8 Okay. 8 to answer based on her Fifth Amendment 9 MR. All right. Thank you very 9 privilege. 0 much. 1 0 THE WITNESS: 0n the instruction of my 1 1 BY MR. KUVEN: 1 lawyer, i must invoke my Fifth Amendment 12 Q. The message appears to read: 9/ 1/2005 to 12 privilege. 1 3 Jeffrey, 8:08, Jean-Lac, teiephoneMR. KUVIN: 1 4 teacher for you to teach you how to speak Russian. 1 4 Q. Does your handwriting appear anywhere on 1 5 She is two times eight years old, not blonde. 5 Page i9 her 1 6 Lessons are lfree and you can have first today if you 1 6 A. On the 1?7 cail. Do you know what that message is referring 7 Q. on either notethe advice of my lawyer, I must invoke my 3. 9 MR. RHEENHART: Instruct the witness not 1 9 Fifth Amendment privilege. 2 to answer the question. Object to the form of 2 Q. Is that your handwriting on the ieft in 2 1 the question because in that it presumes she 2 1 the note that i just read that says: Haiey, 2 2 has knowiedge of eitherjeffrey or Jeanine that phone number. 2 3 MR. Same instruction. 2 4 THE WITNESS: On the advice of counsei, i 2 4 ?fl-IE WITNESS: On the instruction of my 2 5 wish to invoke my Fifth Amendment right. 2 5 lawyer, i must invoke my Fifth Amendment Page 138 Page 140 1 BY MR. KUVIN: privilege. 2 Q. Would you agree with me that this message 2 BY MR. KUVIN: 3 is a message from Jean?Lac, that he?s providing a 3 Q. Ail right. Let?s take a look at the next 4 l6-year?old giri to Jeffrey Epstein? . 4 page which is Page 20. Is that your handwriting on 5 MR. Object to the form in that 5 this paper? 6 it calls for speculation and also assumes facts 6 MR. RHEINHART: Let me tail; to her. '7 as to Mr. JeanvLuc and Mr. Epstein; therefore, '7 THE WITNESS: On the advice of my iawyer, 8 i instruct her to invoice her Fifth Amendment 8 i wish to invoke my Fifth Amendment privilege. 9 priviiege. 9 BY MR. KUVZN: 1 0 THE WITNESS: On the instruction from my 1 Q. is this a list of giris that were being 1 1 lawyer, I must invoke rny Fifth Amendment - 1 provided to Jeffrey Epstein for sex? 1 2 priviiege. 2 MR. RHEINHART: Objection to the form, the 1 3 BY MR. KUVIN: 13 standing objection previously stated. 1 will 1 4 Q. Skip the next page if you would, and the 4 instruct the witness not to answer that 1 5 following page will be i?age 19 of Exhibit 4. It 15 question. 1 6 should be two messages. 1 6 WITNESS: On the instruction of my 1 7 MR. RREINHART: Show me what you?re 1 '7 lawyer, i must invoke my Fifth Amendment 18 bo?ngah 18 gn??mm. 1 9 MR. KUVIN: And the top left one says, 1 9 BY MR. BLOWN: 2 0 "Friday." 2 0 Q. Did Jeffrey Epstein not like girls that 2 1 MR. Thank you. 2 1 had tattoos? 2 2 BY MR. KUVIN: 2 2 MR. Objection to the form 2 3 Q. The message on the left-hand side that 2 3 based on the standing objection and the same 2 4 appears to be, have a date of 4/8/05 and a number 7 2 4 instruction. 2 5 written on it. it says: Haley, 11:00 am. 2 5 THE WITNESS: On the instruction of my 35 (Pages 137 to 140) (561) 832M7500 QROSE COURT REPORTING AGENCY, INC. (561) 83257586 some. arise-:4 name. . 4n- mit-F. itiirc?az?l erase:- - Easementseaem' a? c?mirm . Page 141 Page 143 a 1 lawyer, I must invoke my Fifth Amendment 1 MR. Same instruction. 2 privilege. 2 THE WITNESS: On the advice of my lawyer, 3 3 4 Q. Did Jeffrey Epstein not like girls that 4 right. g; 5 had blonde hair? 5 BY MR. KUVIN: 6 MR. RHEINHART: Standing objection and the 6 Q. Do you know who EW. is? 7 same instruction. 7 MR. Same instruction. 8 "fl-IE WITNESS: On the instruction of my 8 THE WITNESS: On the advice of my lawyer, 9 lawyer, I must invoke my Fifth Amendment 9 I wish to invoke my Fifth Amendment privilege. 1 privilege. 1 0 BY MR. KUVIN: 3.1 BY MR. KUVIN: 11 Q. you know who L.M. is? it 2 Q. Take a look at the next page, if you 3.2 MR. RHEINHART: Let me consult for a 13 would. This one. 13 second. 14 MR. RHEINHART: Thank you. 14 MR. sown: Yep. 15 BY MR. KUVIN: 5 (A discussion was held off the record.) 6 Q. Is that your handwriting? 6 MR. Mr. Kuvin, I?m just asking 7 A. On instruction of my lawyer, i must invoke my 1 7 you to clarify. Are you asking if she's ever 8 Fifth Amendment privilege. 8 heard the name of these people or whether she?s 3. 9 Q. Is this an additional -- on Page 21, is 9 actually ever met someone she knows to have 2 0 this an additional list of girls that were being 2 0 that name? 3 2 1 provided to Jeffrey Epstein for sex? 2 1 MR. KUVIN: Second part, whether she knows 2 2 MR. RHEINIIART: I?m sorry. Did we change 2 2 someone personally by that name. {don't want if 2 3 to a different page or the same page? 2 3 to know what somebody may have told her. 24 MR. KUVIN: The same page. - 24 MR. naemnaar: Sure. 2 5 i 2 5 MR. KUVIN: Certainly not attorneys or Page 142_ Page 144% .55 1 BY MR. KUVIN: 3. anything like that. I want to know whether she 2 Q. Is this an additional list of girls that 2 has any personal knowledge of someone by the 3 were v- 3 name of L.M. 4 MR. RHEINHART: Thank you. 4 MR. RHEINHART: Okay. Based on our 5 BY MR. 5 conversation, she can answer or not answer the it 6 Q. being provided to Eeffrey Epstein for 6 question. 7 sex? 7 THE WITNESS: On the advice of my lawyer, 8 MR. Objection to the form. 8 I choose to invoke my Fifth Amendment right. 9 The same objection and the same instruction. 9 MR. KUVIN: Okay. It?s like a 1 0 'i?i-IB WITNESS: On the instruction of my 1 cough/sneeze. 3. lawyer, i must invoke my Fifth Amendment 1 1 MR. GARCIA: I tried to sti?e it, bu 3.2 privilege. 12 MR. GOLDBERGER: You got it all over me. 13 BY MR. KUVIN: 13 rust kidding. 3. a Q. Page 22. Note on the right appears to 4 MR. GARCIA: You don?t want to get this. 3.5 say: Johanna has a friend, Andrea, that would like 1 5 I?ve bad if for a couple of days. 1 6 to work tonight. Do you know who iohanna is refer, 6 MR. Ki} VIN: What number are we on? l3. 1 7 referring to in that note? 3. 7 That's why I always leave some with numbers 1 8 MR. RHEINHART: Instruct the witness not 1 8 still on there to show the picture to the it 9 to answer based on the privilege against 1 9 camera. 2 settlincrimination. 2 0 Exhibit 13 will be pursuant to 2 1 THE WITNESS: On the advice of my lawyer, 2 confidentiality and the identities of the 2 2 i wish to assert my Fifth Amendment right. 2 2 girls involved in this case. 2 3 BY MR. KUVIN: 2 3 MR. As I presume the prior 2 41 Q. Do you know who Andrea is referring to in 2 4 questions were as well. 2 5 that note? 2 MR. KUVIN: Yes. Absolutely. This is (561) 832*7500 PROSE COURT REPORTING AGENCY, 36 (Pages 141 to 144) INC. (561) 832*7506 Page 145_ Page 147 "3a 1 MW "?WW?mnxm'r smasmmem? ?macaw . ?animate mam remained . knit mama: saliniu?m?arzh?m skirmish-n. crawl". ?mime-Mm? p. 3. different because it?s an exhibit. 1 in Exhibit 13 came to Mr. Epstein's home when she 2 MR. Agreed. 2 was only 15 years old? 3 MR. KUVIN: Okay. 3 MR. Objection to the form 4 (Rlaintiffs Exhibit No. 13 was marked for 4 based on the standing objection, also 5 identi?cation.) 5 speculation as to any age and instruct the 6 MR. We?re moving off of 6 witness not to answer. 7 Exhibit 12? 7 THE WITNESS: On the advice of my lawyer, 8 MR. KUVIN: Yes. 8 i must choose to exercise rny Fifth Amendment 9 MR. RHEINHART: i was looking at the next 9 right. 1 0 exhibit. 1 0 BY MR. KEVIN: 1 MR. We?re done with the trash. 1 1 Q. Do you agree with me that when you 12 MR. RHEINHART: Okay. 12 arranged to have this girl come to Mr. Epstein?s 1 3 BY MR. KEVIN: 13 home, that you were aware that she was 15 years old? i. 4 Q. Just take a look at Exhibit l3. Do you 1 4 MR. RHEINHART: Objection to the form. It 15 recognize the girl in that photograph? 15 is compound. it assumes facts that are not 1 6 A. On the advice of my lawyer, i must choose to 1 6 admitted by this witness, and it's ambiguous in 17 exercise my Fifth Amendment privilege. 17 that regard, and therefore I instruct her not 1 8 Q. Do you agree with me that that girl shown 1 8 to answer. 1 9 in that photograph is 1 9 THE WITNESS: On the advice of my lawyer, 2 0 MR. Objection to the form for 2 Imast choose to exercise my Fifth Amendment 2 1 the reasons previously stated, causes her to 2 1 right. 2 2 speculate, and I instruct her not to answer 2 2 BY MR. KUVIN: 2 3 based on her Fifth Amendment privilege. 2 3 Q. Do you agree that when this girl was 2 4 THE WITNESS: On the advice of my lawyer, 2 4 brought to Mr. Epstein's home, that she performed a 2 5 1 must choose to exercise my itth Amendment 2 5 massage on Mr. Epstein while he was naked? Page 146 Page 148 1 privilege. 3. MR. Objection to the form, 2 BY MR. KUVIN: 2 standing objection. The question assumes that 3 Q. Do you agree with me that you arranged to 3 this witness has any knowledge of 4 have the girl shown in Exhibit 13 be brought to 4 Eeffrey Epstein or whether this person ever 5 Mr. Epstein?s home for sex with Mr. Epstein? 5 came to Mr. Epstein?s home. it is therefore 6 MR. Objection to the form as 6 ambiguous, and I instruct her not to answer. 7 compound, and also the standing objection, and 7 THE WITNESS: On the instruction of my 8 instruct the witness not to answer. 8 lawyer, i must choose to exercise my Fifth 9 THE WITNESS: On the advice of my lawyer, 9 Amendment right. 1 i must choose to exercise my Fifth Amendment 1 0 BY MR. KUVIN: 1 3. privilege. 1 1 Q. Do you agree with me that this girl shown 12 BY MR. KEVIN: 12 in Exhibit 13 was 15 years old at the time she was 13 Q. Would you agree with me that the girl 13 asked by Jeffrey Epstein to remove her clothes? 14 shown in Exhibit 13 did, in fact, come to 4 MR. RHEINHART: Objection to the form. it 1 5 Mr. Epstein's home in 2005? . 5 requires speculation and assumes facts relating 1 6 MR. RHEINHART: Same objection previously 1 6 to Mr. Epstein and events that may have 17 stated. It's compound as to the date, place, 17 occurred which this witness has no knowledge 1 8 person, and also presumes knowledge of 1 8 and has not admitted any knowledge. And I 1 9 Mr. Epstein, so i would instruct her not to 1 9 instruct her not to answer. 2 0 answer. 2 0 THE WITNESS: On advice of counsel I must 2 1 THE WITNESS: On the advice of my lawyer, 2 1 choose to exercise my Fifth Amendment right. 2 2 i must choose to exercise my Fifth Amendment 2 2 BY MR. KUVIN: 2 3 privilege. 2 3 Q. Do you agree that you described for the 2 4 BY MR. 2 4 girl'as shown in Exhibit 13 by the way, her name 2 5 Q. Do you agree with me that the girl shown 2 5 is 8.13. -- that you described to 13.13. how to set up 37 (Pages 145 to 148) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Page 149 Page 151 1 the massage table in Jeffrey Epstein's bathroom? 1 counsel, I must choose to invoke my Fifth 2 MR. RHBINHART: Objection to the form for 2 Amendment right. 3 the reasons previously stated, and instruct the 3 BY MR. KUVIN: 4 witness not to answer. 4 Q. Do you agree with me that during the 5 THE WITNESS: On the advice of counsel, 5 massage that 8.8. was forced to give to Mr. Epstein, 6 must choose to exercise my Fifth Amendment 6 that he touched her between her legs? 7 right. 7 MR. RHEINHART: Objection to the form. It 8 BY MR. KUVIN: 8 is ambiguous including the term "forced." it 9 Q. Do you agree that you showed BB. where 9 assumes facts that this witness has not i 0 the massage oils are kept in Jeffrey Epstein?s admitted or that this witness has not i. 1 bathroom in his home? 1 it acknowledged any personal knowledge and 1 2 MR. RHEIN HART: Objection to the form in 2 instruct her not to answer. 3.3 that it assumes knowledge of Jeffrey Epstein, 1 3 THE On the instruction of my 1 4 knowledge that this person was ever at 4 lawyer, I must therefore invoke my Fifth 1 5 Jeffrey Epstein's home none of which is 5 Amendment right. 1 6 admitted or acknowledged by this witnessinstruct the witness not to answer. 1 7 Q. Do you agree with me that Mr. Epstein l. 8 THE On advice of counsel I must 18 touched 13.8. between her legs? 3. 9 choose to invoke my Fifth Amendment right. 9 MR. RHEINHART: Objection to the form and 2 0 BY MR. KUVIN: 2 0 the question presumes knowledge of 2 1 Q. Do you agree that you showed 3.3., as 2 3. Jeffrey Epstein. instruct the witness not to 2 2 shown in Exhibit l3, where Mr. Epstein kept the; 22 answer. 2 3 vibrator-sin his bathroom at his house? i 2 3 THE WITNESS: On the instruction of my 2 4 MR. Same objection as stated 2 4 lawyer, i must choose to invoke my Fifth 2 5 to the previous question as to the form of the 2 5 Amendment right. Page 150 Page 152 3. question, and instruct the witness not to 1 BY MR. KUVIN: 2 answer. 2 Q. Do you agree with me that BB. told 3 WITNESS: On advice of counsel, must 3 Mr. Epstein to stop touching him there touching 4 choose to exercise my Fifth Amendment right. 4 her there? 5 BY MR. KUVIN: 5 MR. Same objection previously 6 Q. Do you agree with me that in 2005 you 6 stated to the last question and instruct the 7 knowingly provided BB, 3. 15?year?old girl, to 7 witness not to answer. 8 Mr. Epstein so that he could sexuain abuse her? 8 THE WITNESS: On the instruction of my 9 MR. Objection to the form as 9 lawyer, i must invoke my Fifth Amendment right. 1 to it calling for a legal conclusion as to 0 BY MR. KWIN: 1 1 assuming multiple facts, since therefore 3. 1 Q. Do you agree with me that you have 12 compound and instruct the witness not to 12 personal knowledge that after telling Mr. Epstein to 1 3 answer. 1 3 stop touching her between her legs, Mr. Epstein 4 THE WITNESS: On advice of counsel, I must 1 4 apologized and then touched her again between her 1 5 choose to invoke my Fifth Amendment right. 1 5 legs? 1 6 BY MR. ELEVEN: 6 MR. Objection to the form and It '7 Q. Do you agree with me that BB. was given 7 the standing objection previously stated as l. 8 to Mr. Epstein to perform a naked massage of him 8 well as the question is compound and instruct, 9 while he touched 1 9 and ambiguous, and I instruct the witness not 2 0 MR. Objection to the form. 2 to answer. 2 1 Standing objection and other facts that are 2 1 THE WITNESS: On the instruction of my 2 2 assumed in the question to which this witness 2 2 lawyer, i must choose to exercise my Fifth 2 3 does not admit, and therefore the witness is 2 3 Amendment right. 2 4 instructed not to answer the question. 2 4 BY MR. KUVIN: THE WITNESS: On the instruction of my 2 5 ?01 832~7500 PROSE COURT REPORTING AGENCY, mam $3 at: rm: tar. Q. Do you agree with me that Mr. Epstein -s WM . . renames. marinate a?mih'iiams rumimlmr?x a ii 4-. titans s. $23? 36:3?! rm ma??af??ixi?yxgzis?i?a'?tzim a: rrw?st?ssnamsan?; m'tz?mm'xm magma: 38 (Pages 149 to 152) INC. (561) 832*7506 PROBE COURT REPORTING AGENCY, INC. g. 4? anew-mew. a? . .zmmeusmm . u. sweet:er z?c?im enemas: Tril??hx?ii??im'ei?e?h?u' Manama arm Page 153 Page 155 1 speci?cally targeted young underage girls that were 1 Mr. Epstein naked massages? 2 economically disadvantaged for his own sexual 2 MR. RHEINHART: Object to the form. It's 3 pleasure? 3 multiple layers of compound questioning, 4 MR. RHEINHART: Objection to the form. 4 includes terms like "enterprise" that are 5 Several of the terms are ambiguous and it 5 ambiguous and may call for a legal conclusion 6 assumes knowledge of Mr. Epstein and his 6 that this witness is not competent to give. I 7 habits, and therefore, i instruct the witness 7 instruct the witness not to answer. 8 not to answer the question. 8 THE WITNESS: On the instruction of my 9 THE WITNESS: On the instruction of my 9 lawyer, I must choose to exercise my Fifth 1 0 lawyer, I must choose to exercise my Fifth 1 0 Amendment right. 1 1 Amendment right. 1 1 BY MR. KUVIN: 2 BY MR. KUVIN: 1 2 Q. Do you agree with me that there is a 1 3 Q. Do you agree with me that Mr. Epstein 1 3 staircase leading out oer. Epstein?s kitchen in 1 4 would pay these girls 2 to $300 for this sexual 14 his home on Palm Beach? 1 5 massage? 3. 5 MR. Objection to the form, 1 6 MR. RHEINHART: Objection to the form. 1 6 presumes knowledge of Mr. Epstein or his home 3. 7 Standing objection and assumes knowledge of 1 '7 on Palm Beach. instruct the witness not to 1 8 Mr. Epstein and his practices, so therefore, I 1 8 answer. 1 9 instruct the witness not to answer. 1 9 THE WITNESS: On the instruction of my 2 0 THE WITNESS: On the instruction of my 2 0 lawyer, i must choose to invoke my Fifth 2 lawyer, i must choose to invoke my Fifth 2 1 Amendment right. 2 2 Amendment rightyou agree with me that when BB. was 2 4 Q. Do you agree with me that you handed BB. 2 4 brought to Mr. Epstein?s bathroom, that he walked . 2 5 $200? 2 5 out of the shower wearing a towel? Page 154 Page 156 1 MR. RHEINHART: Objection to the form, 1 MR. Objection to the form in 2 instruct the witness not to answer. 2 that it presumes knowledge of 3.3., that Ms. 3 THE WITNESS: 0n the instruction of my 3 BB. was ever at Mr. Epstein?s home, that this 4 lawyer, I must choose to invoke my Fifth 4 witness knows anything about Mr. Epstein or his 5 Amendment right. 5 home; therefore, the question is compound and 6 BY MR. KUVIN: 6 ambiguous, and i instruct her not to answer. 7 Q. And just so we're clear, do you agree with 7 THE On the instruction of my 8 me that you handed BB. in 2005, $200 after she was 8 lawyer, i must choose to assert my Filth 9 in the bathroom with Mr. Epstein at his home? 9 Amendment right. 10 MR. Objection to the form. 10 BY MR. KUVIN: 1 The question presumes knowledge of a person by 1 3. Q. Do you know 12 the name of 13.3., therefore i instruct the 12 A. On the instruction of my lawyer, I must choose 13 witness not to answer the question. 13 to assert my Filth Amendment privilege. 1 4 THE On the instruction of my - 4 Q. Did you have C.L. excuse me, strike 1 5 lawyer, i must choose to invoke my Fifth 2 1 5 that. {)id you tell CL. to come over to 1 6 Amendment right. 1 6 Mr. Epstein?s home to give Mr. Epstein a massage? 17 BY MR. KUVIN: 17 MR. RHBINHART: Objection to the form. 1 8 Q. Do you agree with me that Mr. Epstein had 1 8 It's compound. Stand objection, standing 1 9 a plan let me rephrase that. 1 9 objection, sorry. instruct the witness not to 2 0 Do you agree with me that Mr. Epstein 2 0 answer. 2 3. had an enterprise, a sexual enterprise, established 2 3. On the instruction of my 2 2 by which young girls would be brought to his home, I 2 2 lawyer, i must choose to invoke my Fifth 2 3 introduced to you, where you would then set up a 2 3 Amendment right. 2 4 massage table, Show them where the oils were, and 2 4 BY MR. KUVIN: 2 5 have these young girls under the age of 18, give 2 5 Q. Did you introduce CL. to Jeffrey Epstein? 39 (Pages 153 to 156) (563.) 832*7500 (561) 832*7506 Page 157 Page 159 1 MR. Objection to the form, 1 BY MR. KUVIN: 2 standing objection. instruct the witness not 2 Q. Would you agree with see that you visited 3 to answer. 3 a man by the name of 3effrey Epstein while he was in 4 THE On the instruction from my 4 jail in Palm Beach County? 5 lawyer, I must choose to invoke my Fifth 5 MR. RHEINHART: Objection to the form, 6 Amendment right. 6 standing objection. Assumes other facts that '7 BY MR. KUVIN: 7 this witness has not acknowledged, and instruct i 8 Q. Do you agree with me that Mr. Epstein 8 her not to answer. 9 threatened CL. with physical vioience? 9 THE WITNESS: Upon instruction from the 1 0 MR. Objection to the form, the lawyer, I must choose to invoke my Fifth 3. standing objection, as well as ambiguous as to 1 3. Amendment right. i 1 2 the term "threaten." Instruct the witness not answer. 1 3 Q. Do you agree that you arranged to have 1 4 THE Upon instruction from my 1 4 CL. come to Jeffrey Epstein?s home. for a nude 5 lawyer, i must choose to invoke my Fifth 15 massage? 1 6 Amendment right. 1 6 MR. Objection to the form, 7 BY MR. KUVIN: 1 '7 standing objection previously stated. 1 8 Q. Do you agree with me that Jeffrey Epstein 8 THE WITNESS: On the instruction of my 9 told C.L. that if she talks to anyone about what had 1 9 lawyer, I must choose to invoke my Fifth 2 0 occurred at his home, bad things would happen to 2 0 Amendment right. 2 i her? 2 1 BY MR. KUVIN: 2 2 MR. Objection to the form, 2 2 Q. Do you agree that (1.1.. has been to 2 3 it?s compound, and a standing objection. Also 2 3 358 El Brillo Way on at least two occasions? 2 4 assumes numerous other facts that this witness 2 4 MR. RHEINHART: Objection to the form. it 2 5 has not acknowledge nor admitted, and therefore 2 5 assumes knowiedge of C.L. and of 358 El Brillo Page 158 Page 160 1 instruct her not to answer. 1 Way, to which the witness has not acknowledged, 2 THE WITNESS: On the instruction from my 2 and instruct the witness not to answer. 3 lawyer, I must choose to invoke my Fifth 3 THE On the instruction of my 4 Amendment privilege. 4 lawyer, I must choose to invoke my Fifth 5 BY MR. 5 Amendment right. Q. Would you agree with me that in 2005 that 6 BY MR. KUVIN: 7 Jeffrey Epstein was between the ages you agree that Mr. Epstein has an 8 years old? 8 odd-shaped penis? 9 MR. RHEINHART: Objection to the form. 9 MR. RHEENHART: Objection to the form of 1 0 Standing objection as to any knowledge of the question. it assumes knowledge of 1 1 Jeffrey Epstein. instruct the witness not to 1 1 Mr. Epstein. It assumes knowledge of 1 2 answer. 1.2 Mr. Epstein's body parts, and instruct the 1 3 "run WITNESS: rile instruction of my 1 3 Witness not to answer. 1 4 lawyer, i must choose to assert my Fifth 1 4 THE WITNESS: On advice on the Ti 5 Amendment right. 1 5 instruction of my lawyer, I must choose to 1 6 BY MR. KUVIN: 1 6 invoke my itth Amendment right. 1 ?7 Q. Would you agree with me that i '7 BY MR. KUVIN: 1 8 - Jeffrey Epstein has tremendous wealth? 1 8 Q. Have you seen 3effrey Epstein's penis? 1 9 MR. Objection to the form as i 9 MR. Objection to the form, and 2 0 stated in the previous question, and instruct 2 0 we're getting awfully close to a line here, Mr. 2 1 the witness not to answer. 2 1 Kuvin. 2 2 THE WITNESS: On the instruction from the 2 2 MR. KUVIN: I think the identity of 2 3 lawyer, I must choose to invoke my i?h 2 3 something that young 14 and 15-year-old girls 2 4 Amendment right. 2 4 have seen is directly relevant to the issues in 2 5 2 5 this case. If they can describe it, then 40 (Pages 157 to 160) (561) 832*?500 PROBE COURT REPORTING AGENCY, INC. (561) 832*7506 (561) 832?7500 PROSE COURT REPORTING AGENCY, ENC. (561) 832?7506 it a . :?Las?ul- 'mneiizaxanmmfo new as; -M?wssnaavorlsv on: ?Field;- at: .. . Mu?ngmm max: 93962 161 Page 163 1 obviously it?s important because they are the 1 MR. KUVIN: The Epstein matter. 2 only ones that are answering questions in this 2 MR. instruct the witness not 3 case. 3 to answer. Objection to the form as compound 4. MR. RHEINHART: Well, people have rights. 4. and assumes the existence of Mr. Epstein which, 5 People will assert their rights, and I am just 5 again, we are not acknowledging, and therefore 6 telling you, we're getting close to a line 6 am instructing her not to answer. 7 here. 7 THE WITNESS: On the instruction of my 8 MR. KUVIN: I think i?m being 8 lawyer, i choose to assert my Fifth Amendment 9 respectful 9 right. 1 0 MR. RHEINHART: You haven?t crossed it yet 1 0 BY MR. KEVIN: 1 1 because i?m still here, but i'm just warning 1 1 Q. Are you aware that Mr. Epstein negotiated 1 2 you. 1 2 for your immunity from prosecution in the 1 3 Instruct the witness not to answer 13 non?prosecution agreement that was entered into with 1 4 any question that presumes existence or 1 4 the United States Attorney?s Office for the Southern 1 5 any knowledge of Jeffrey Epstein or any of 1 5 District of Florida? 1 6 his body parts. 1 6 MR. RHEINHART: Again, objection to the 17 MR. KUVIN: Okay. 1 7 form for the reasons previously stated as to 1 8 THE WITNESS: On the instruction of my 1 8 the standing objection and instruct her not to 1 9 lawyer, I must choose to assert my Fifth 1 9 answer. 2 0 Amendment right. 3 2 0 THE WITNESS: On the instruction lawyer, i must choose to invoke my Fifth 2 2 Q. Do you know whether or not Mr. Epstein has 2 2 Amendment right. 2 3 any identifying characteristics MR. KUVEN: 2 4 private genitalia? 2 4 Q. Do you agree with me that BB. was 2 5 MR. RHEINHART: Objection to the form for 2 5 emotionally tramnatized as a result of the incidents Page 162 Page 164 1 the reason previously stated, because it 1 that occurred Jeffrey Epstein's home in 2005? 2 presumes that she has any knowledge of who 2 MR. RHEINHART: Objection to the form. It 3 Jeffrey Epstein is or what his body parts look 3 assumes any knowledge of BB. or any incidents 4 like, and i would instruct her not to answer. 4 that would have occurred at a home purporting 5 THE On the instruction of my 5 to belong to a person by the name of Saffrey 6 lawyer, i must choose to assert my Fifth 6 Epstein, and instruct her not to answer. 7 Amendment right. 7 THE WITNESS: Upon instruction from my 8 BY MR. KUVIN: 8 lawyer, i must choose to invoke my Fifth 9 Q. Have you heard anyone other than your 9 Arnendment right. 1 lawyers that have deseribed what any of 1 0 BY MR. KUVIN: 1 1 Mr. Epstein's body parts look like? 1 1 Q. Do you agree with me that was 1 2 MR. RHEINHART: Objection to the form. It 12 emotionally traumatized as a result of the incidents 1 3 is irrelevant what she?s heard from other 1 3 that occurred at Jeffrey Epstein?s home? 1 4 people, and again, it presumes facts that she's 1 4 MR. RHEINHART: Same objection as to the 1 5 not acknowledged. It is compound, and it is 1 5 previous question, and instruct the witness not 1 6 harassing at this point. 1 6 to answer. 17 THE WITNESS: On instruction of my lawyer, 1 7 THE WITNESS: 0n the instruction of my 1 8 I must choose to invoke my Fifth Amendment 1 8 lawyer, I must choose to invoke my Fifth 1 9 right. 1 9 Amendment privilege. 2 0 BY MR. KUVIN: 2 0 BY MR. KWIN: 2 1 Q. Were you consulted with respect to the 2 1 Q. Do you know tane {)oe No. 102? 2 2 non?prosecution agreement that was entered into with 2 2 MR. RHEINHART: Instruct the witness not 2 3 the United States Attorney's Of?ce for the Southern 2 3 to answer based on Fifth Amendment privilege. 2 4 District of Florida as it relates to this case? 2 4 THE WITNESS: On instruction of my lawyer, 2 5 MR. RHEZNHART: Which case? 5 2 5 gust choose to invoke my Fifth Amendment 41 (Pages 161 to 164) $32-$4wa 3? i ii a i 3 ?130- ?We? ?ummlmemnimir?s up; - uw 1' Page 165 Page 167 1 right. 1 in New York? 2 BY MR. 2 MR. instruct the witness not 3 Q. Have you known Jeffrey Epstein to keep 3 to answer based on the Fifth Amendment 4 underage, under the age of 18, sex slaves? 4 privilege. 5 MR. Objection to the form both 5 THE WETNESS: On the instruction of my 6 as to ambiguity as to what you mean by "sex 6 lawyer, i choose to invoke my Fifth Amendment "7 slaves," and "keep," also the standing 7 right. 8 objection as to any knowledge of Mr. Epstein 8 BY MR. 9 and instruct the witness not to answer. 9 Q. Are you aware that various underage girls 1 0 THE WITNESS: On the instruction of my 1 0 brought in from out of the country live at 301 East 1 1 lawyer, I must choose to invoke my Fifth 3. 1 66th Street? 12 Amendment right. 1 2 MR. RHEINHART: Objection to the form. 1 3 BY MR. KUVIN: 1 3 it's compound, and instruct the witness not to 1 4 Q. Where do most of the models come from that 1 4 answer. 1 5 are part of MC Squared Modeling Agency? 1 5 THE WITNESS: On the instruction from my 1 6 MR. RHEINHART: Objection to the form. It 1 6 lawyer, i must choose to invoke my Fifth 1 7 assumes knowledge of an entity by the name of 1 '7 Amendment right. 1 8 MC Squared Modeling which the witness has not 1 8 BY MR. 1 9 acknowledged and therefore I instruct her not 1 9 Q. You?ve stayed at that address before, have 2 to answer, and the question is compound. 2 0 you not? 2 1 THE WITNESS: On the instruction of my 2 3. MR. RHEINHART: instruct the witness not 2 2 lawyer, I must choose to invoke my Fifth 2 2 to answer. 2 3 Amendment privilege. 2 3 THE WITNESS: On the instruction lawyer, i must choose to invoke my Fifth 25 Q. Who gets visas for the modeis at MC 2 5 Amendment right. Page 166 Page 168 1 Squared, if you know? 1 BY MR. 2 MR. RHEINHART: Same, same objection as to 2 Q. You?ve stayed there hundreds of times, 3 the previous question, same instruction. 3 have you, hundreds of times have you not? 4 THE WITNESS: On the instruction of my 4 MR. RHEINHART: instruct the witness not 5 lawyer, i must choose to invoke my Fifth 5 to answer. 6 Amendment right. 6 THE WITNESS: On instruction from my 7 BY MR. KUVIN: 7 lawyer, I must choose to invoke my Fifth 8 Q. Do you work with Jeffrey Epstein to get 8 Amendment right. 9 visas for out-of?the?country models or models that 9 BY MR. KUVIN: 1 are -- strike that. 1 0 Q. Are you aware that Mr. Epstein obtains 1 1 Do you work with Jeffrey Epstein to 1 1 visas for girls from out of the country to work as 1 2 get visas for girls that are underage and bring them 12 models and then prostitutes them out? 1 3 into the United States so that they can work as 1 3 MR. Objection to the form of 4 models for MC Squared? I 1 4 the question in that it is ambiguous and it 1 5 MR. RHBINHART: Objection to the form and 5 assumes numerous facts that have not 1 6 assumes knowledge as to Mr. Epstein and as to I 6 acknowledged that this witness has any 1 7 MC Squared and other matters that are not 7 knowledge of, and the term "prostitutes them 1 8 admitted or acknowledged by this witness. The 1 8 out? is ambiguous, so I would instruct her not 1 9 question is compound. i would instruct her not 1 9 to answer the question. 2 0 to answer. 3 2 0 THE WITNESS: On the instruction of my 2 1 THE. WITNESS: On the instruction from my 5 2 1 lawyer, I must choose to invoke my Fifth IR 2 3 Amendment right. i 2 3 BY MR. never: 2 4 BY MR. KUVTN: 24 Q. You know what Radar Online is, do you not? 2 6 Q. Do you know who owns 301 East 66th Street 2 5 MR. RHEINHART: Instruct the witness not 42 (Pages 165 to 168) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Page 169 Page 171 1 to answer the question based on her Fifth 1 THE WITNESS: On the instruction from my 2 2 3 THE WITNESS: On the instruction of my 3 right. 4 lawyer, i must choose to invoke my Fifth 4 BY MR. KOVIN: 5 Amendment right. 5 Q. Wouid you agree with me that ieffrey 6 BY MR. 6 Epstein has a iist of underage giris that live 7 Q. in fact, you were around when 7 within a ciose proximity to ail of his different 8 Jeffrey Epstein bought Radar Online, were you not? 8 homes in every different state? 9 MR. Objection to the form, 9 MR. Objection to the form in 1 0 standing objection as to any knowledge of 1 0 that it assumes Mr. Epstein has homes in every 1 .ieffrey Epstein or of Radar Online, and 1 singie state and that she knows who Mr. Epstein 1 2 instruct the witness not to answer. 12 is, and therefore i instruct her not to answer. 1 3 THE On the instruction from my 1 3 THE WITNESS: On advice of my iawyer, I 1 4 lawyer, i must choose to invoke my Fifth 3. 4 must choose to invoke my Fifth Amendment right. 1 5 Amendment right. 1 5 BY MR. KUVIN: 1 6 BY MR. KUVTN: 1 6 Q. You?re aware Mr. Epstein has a home in New 1 7 Q. Are you aware that Jeffrey Epstein 1 "7 York, right? 1 8 accessed or obtained underage girls through his 1 8 MR. RHEINHART: Instruct the witness not 1 9 Radar connection? 1 9 to answer, and standing objection of knowledge 2 0 MR. RHETNHART: Same objection as 2 of Mr. Epstein. 2 1 previously stated to the last question and same 2 1 THE WITNESS: On the instruction of my 2 2 instruction. 2 2 lawyer, i must invoke my Fifth Amendment right. 2 3 THE On the instruction from my 23 BY MR. 1(8sz 2 iawyer, i must choose to invoke my Fifth 2 41 Q. Are you aware that he has a home in New 2 5 Amendment privilege. 2 5 Mexico? Page 170 Page 172 1 BY MR. KUVIN: 1 MR. RHEINHART: By he, you mean 2 Q. How many different properties does 2 Mr. Epstein? 3 Eefirey Epstein own? 3 MR. KUVIN: Yeah. 4 MR. RHEINHART: Objection to the form, 4 MR. RHEINHART: Got to make sure the 5 standing objection. Instruct the witness not 5 question is clear. 6 to answer. 6 MR. Yes. 7 THE WITNESS: On the instruction of my 7 MR. RHBINHART: Standing objection to the 8 iawyer, I must choose to invoke my Fifth 8 form and instruct the witness not to answer. 9 Amendment right. 9 THE WITNESS: On the instruction from my 10 BY MR. KUVIN: 1. 0 lawyer, i must choose to invoke my Fifth 1 1 Q. You've been to of Jeffrey Epstein?s 1 1 Amendment privilege. 1 2 home, have you not? 12 BY MR. 1 3 MR. RHEINHART: Same objection as 13 Q. Are you aware he has a home in the US. 1 1i previousiy stated to the East question. Same 1 4 Virgin Isiands? 1 5 instruction. 1 5 MR. RHEINHART: Same instruction, same 1 6 THE WETNESS: On the instruction from my 6 objection. 1 7 lawyer, I must invoke my Fifth Amendment right. 7 THE WITNESS: On the instruction of my 1 8 BY MR. KUVIN: 1 8 iawyer, I must choose to invoke my Fifth It 9 Q. You agree with me that Jeffrey Epstein 9 Amendment right. 2 keeps a iist?of giris in the nearby areas around 2 0 BY MR. KUVIN: 2 1 of his homes and properties? I 2 3. Q. And isn?t it true that you kept a iist of 22 MR. RHEINHART: Objection to the form, for 22 underage giris that couid service, in other words, 2 3 the standing objection as weii as ambiguous as 2 3 give Mr. Epstein naked massages in every piace that 2 4 to ?nearby,? and "ail of his propertiesthose homes {just described? 2 5 instruct; the witness not to answer. - MR. RHEINHART: Same objection as 43 (Pages 169 to 172) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 tm= Mme?- ?mime-?W detonate Mm "tram Page 173 Page 175 1 previously stated, the standing objection and i. to Mr. Epstein's house on Palm Beach, you were aware 2 instruct her not to answer. 2 that they were brought so that Mr. Epstein could 3 THE WITNESS: On the instruction of my 3 molest them, correct? 4 lawyer, i must choose to invoke my Fifth 4 MR. Objection to the form as 5 Amendment right. 5 to knowledge of Mr. Epstein, as to knowiedge of 6 BY MR. . 6 any home on Palm Beach, and ambiguous as to the 7 Q. Now, you're also aware, are you not, that 7 term "molest," and instruct the witness not to 8 Jeffrey Epstein would pay other girls to bring 8 answer. 9 additional underage girls to him for naked massages, 9 THE WITNESS: On the instruction from my 1 are you not? 3.0 lawyer, I must choose to invoice my Fifth 1 MR. RHBINHART: Standing objection and 1 1 Amendment right. 12 instruct the witness not to answer. 1 2 BY MR. KUVIN: 3 THE WITNESS: On the instruction from my 1 3 Q. You?re aware that Mr. Epstein raped 4 lawyer, I must choose to invoke my Fifth 1 4 several underage minors in his bedroom? 1 5 Amendment privilege. i 5 MR. RHEINHART: Objection to the form as 1 6 BY MR. KUVIN: . 1 6 to knowledge of Mr. Epstein, and also ambiguous 7 Q. And, in fact, you frequently would pay 1 7 as to the term "rape." 8 other girls to bring additional girls under the age 1 8 THE WITNESS: On the instruction Mr. Epstein for naked massages? I 9 lawyer, i must choose to invoke my Fifth 2 0 MR. RHEINHART: Objection to the form, - 2 0 Amendment rights. 2 standing objection as to Mr. Epstein, also as 2 1 BY MR. KUVIN: 2 2 to any knowledge of any naked massages by 2 2 Q. Do you know what the term "rape" means? 2 3 anybody to anybody. instruct the witness not 2 3 MR. Not as you used it. if 2 4 to answer. 2 4 you want to teli us what you mean by when you 2 5 THE On the instruction of my 2 5 used it, we'll be happy to answer -- Page 174 Page 176 1 lawyer, I choose to invoke my Fifth Amendment 1 MR. i want to know if 2 right. 2 MR. RHEINHART: or evaluate your 3 BY MR. KUVIN: 3 question. 4 Q. And there was a complete list of girls, 4 MR. i want to know if she has her 5 underage girls, that was stored on Mr. Epstein?s 5 own de?nition of what the phrase or word 6 computer system; isn't that true? 6 ?rape? means, so that we can use her de?nition 7 MR. RHEINHART: Objection to the form. 7 of that word. I want to make sure it's 8 it's ambiguous as to what a complete list is, 8 completely unambiguous. 9 and also a standing objection to any knowledge 9 MR. Your asking the question. ii. 0 of Mr. Epstein, and instruct the witness not to 10 if you want to define the term, she?il respond 1 1 answer. 1 1 to your question. i 2 THE WITNESS: On the instruction from my 1 2 BY MR. KUVIN: Ii. 3 lawyer, I must choose to invoke my Filth 3 Q. Do you what the term or word ?rape? means? 1 4 Amendment privilege. 1 4. A. Yes. 5 BY MR. KUVIN: 5 Q. Okay. What is your understanding of that 6 Q. in fact, you?ve seen the list of underage 3. 6 word? 1 7 girls that exists on Mr. Bpstein?s computer, have 17 MR. Now, we?re not answering 1 8 you not? 1 8 that question. It's your term. It?s your 1 9 MR. RHEINHART: Objection to the form, I 9 question. if you want to de?ne it, you can go 2 standing objection. 2 ahead and define it. 2 3. THE WITNESS: On the instruction from my 2 3. MR. KUVIN: Well, I beg -- 2 2 lawyer, I must choose to invoke my Fi?h 22 MR. RHBINHART: if you want to give her 2 3 Amendment right. 2 3 speci?cs as to what she you can define it. 2 4 BY MR. KUVIN: 2 4 MR. KUVIN: i beg to differ with you, and 2 Q. When underage minor females were brought 2 5 i don't know that that?s a proper objection. 44 (Pages 173 to 176) (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (561) 832*7506 arms,? sur?ng. - Page 177 Page 179 a 1 I?m asking her her understanding of the word. 1 or vaginal penetration or union with the sexual 2 MR. RHEINHART: And I am instructing her 2 organ of another, or oral, anal or vaginal 3 not to answer it because that question is not 3 penetration of another with any other object, 4 likely to lead to discoverable evidence. it?s 4 or with any object. Excuse me. All right? i 5 simply meant to harass her. And you can define 5 MR. RHEINHART: Okay. 6 the term in your question. 6 BY MR. KUVIN: '7 MR. Well, with all due respect, 7 Q. Do you understand that de?nition as 8 it's certainly not to harass if there have been 8 have explained it to you, or would you like me to 9 girls that were alleging that they were raped. 9 read it again? 1 0 MR. RHEENHART: Well, you de?ne what you 3. A. Read it again, please. 3. 1 mean by when you say that they allege that they 3. 1 Q. Absolutely. Florida law de?nes "rape" as 1 2 have been raped, and she will be happy to 1 2 oral, anal or vaginal penetration by, or union with 1 3 evaluate your question. 3.3 the sexual organ of another; or oral, anal or 1 4 MR. KUVIN: And that's what I'm trying to 1 4 vaginal penetration by another with any object. And 1 5 understand. 1 5 obviously that is without the other?s consent. 1 6 MR. She's not going to 1 6 A. You did not say that. 1 7 speculate on what you mean when you frame a 1 7 MR. RHEINHART: Okay. 1 8 word in your questionMR. KUVIN: That's exactly what l'rn trying 1 9 Q. Adding without the other's consent, it 2 to do. I?m trying to make sure that we are 2 0 obviously, to that de?nition. 2 1 using the same de?nition, so i would like to 2 1 Now, let?s use that definition for 2 2 use her definition of the word. 22 "rape," because that?s as it's de?ned by Florida 2 3 MR. RHEINHART: Right. She?s not going to 2 3 law. Using that de?nition, are you aware, as you 2 4 answer it, so you can either move on we can 2 4 sit here today, that Jeffrey Epstein has raped 2 5 stop. 2 5 underage girls? Page 178 Page 180 1 MR. KUVIN: Okay. So you?re instructing 1 MR. RHEINHART: Standing objection to the 2 her not to answer the question? 2 form ofthe question, and I would instruct the 3 MR. RHEINHART: I am instructing her not 3 witness not to answer. 4 to answer the question for the third time. 4 THE On the instruction of my 5 MR. KUVIN: Okay. i just want to be 5 lawyer, I must choose to invoke rny Fifth 6 clear. 6 Amendment right. 7 MR. GARCIA: What?s the legal objection? 7 BY MR. sown: 8 MR. RHEINHART: I?ve already stated what 8 Q. Are you aware as you sit here today that 9 my legal objection is. It?s meant solely for 9 Jeffrey Epstein raped 8.13.? 1 harassment. it's not likely to lead to 1 0 MR. RHEINHART: Objection to the forrn. 1 1 discoverable evidence. 1 The question assumes that he did, or that she 1 2 BY MR. KUVEN: 1 2 has any knowledge of whether he didOkay. For the purpose of my question, i 1 3 instruct the witness not to answer. 1 4 would like to, because your attorney won?t allow you 1 4 THE WITNESS: On the instruction of my 1 5 to de?ne the word "rape," i would like you to use 1 5 lawyer, i must choose to invoke rny Fifth 6 the word and understand the word "rape" to mean 1 6 Amendment privilege. ?7 sexual contact with an individual, including 17 BY MR. KUVIN: .. 8 sexual -- well, let me clarify here. Hang on. You 3. 8 Q. Are you aware as you sit here today, that 1 9 know what, if we?re going to do it, let's do it 1 9 Jeffrey Epstein well, let me rephrase that. 2 0 right since we can?t use your de?nition. 2 0 You are aware, are you not, as you 2 1 MR. RHBINHART: You can use whatever 2 sit here today, that Jeffrey Epstein raped 2 2 definition you like, but you need to tell me 2 2 MR. RHEINHART: Objection to the form as 2 3 what it is. 2 3 leading, and also again assumes -- your 2 4 MR. KUVIN: Let's use the definition of 2 4. question assumes that she knows things that 2 5 (561) we: saw "rape" as defined by Florida law as oral, anal is?; $.14 avatewwrsamaai tiers? 832?7500 . Kama ?suntan-name- 5w PROSE COURT REPORTING AGENCY, she?s not acknowledged that she kno WS 01' are? at. W.mtri? nan as: will (Pages 177 to 180) INC. (561) 832*7506 Page 181 Page 183 it ii - i-W h??il??k?ii: 1 doesn?t know, and I instruct her not to answer. 3. MR. Same objection as 2 THE WITNESS: On the instruction of my 2 previousiy stated as to ambiguity and compound, 3 3 4 Amendment right. 4 rue WITNESS: On the instruction of my 5 BY MR. KUVIN: 5 lawyer, I must choose to invoke my Fifth 6 Q. Do you agree that Jeffrey Epstein has 6 Amendment right. 7 raped hundreds of girls under the age of 18? 7 BY MR. 8 MR. RHEINHART: Objection to the form, 8 Q. Have you ever had sexual contact in any 9 standing objection as to any knowledge of 9 manner with any underage giris that were brought to 1 0 Jeffrey Epstein. Instruct the witness not to Mr. Epstein?s home? 1 1 answer. 1 1 MR. Objection to the form. 1 2 THE WITNESS: On the instruction of my 12 Standing objection, compound, instruct the 1 3 lawyer, I must choose to invoke my Fifth 1 3 witness not to answer. 1 4 Amendment privilege. 1 4 THE On the instruction of my 1 5 BY MR. KUVIN: 3. 5 iawyer, I must choose to invoke my Fifth 1 6 Q. You?re aware, are you not, that it 6 Amendment right. 1 7 ieffrey Epstein has raped hundreds of girls under 17 BY MR. KUVINDid you keep an appointment book for 1 9 MR. RHEINHART: Objection to the form as 1 9 Mr. Epstein? i 2 0 leading. Instruct the witness not to answer 2 0 MR. RHEINHART: Objection to the form, . 2 3. for the reasons previously stated to the last 2 standing objection. Instruct the witness not 2 2 the question. 2 2 to answer. 2 3 THE WITNESS: On the instruction of my 2 3 THE WITNESS: On the instruction of my 24 lawyer, i must choose to assert my Fifth - 2 4 iawyer, I must choose to invoke my Fifth -- Ame'ndrne?t'rig'iiaaAmendment right. Page 182: Page 184 1 BY MR. 1 BY MR. KUVIN: 2 Q. You're aware, as you sit here today, are 2 Q. Did you preserve a document that shows the 3 you not, that Jeffrey Epstein has raped hundreds of 3 appointments kept for Mr. Epstein in the years 2004? 4 giris under the age of 16? 4 MR. Objection to the form, the 5 MR. RHEENHART: Objection to the form. 5 standing objection, compound question and 6 Standing objection. It assumes numerous facts 6 instruct the witness not to answer. 7 mixed in a compound question, and therefore I 7 THE WITNESS: On the instruction of my 8 instruct the witness not to answer. 8 lawyer, i must choose to invoke my Fifth 9 THE WITNESS: On the instruction of my 9 Amendment right. 1 lawyer, i must choose to assert my Fifth 1 0 BY MR. KUVEN: 1 Amendment right. 1 1 Q. Same question with respect to any 2 BY MR. KUVIN: 3.2 appointments kept for Mr. Epstein in 2005. 1 3 Q. Isn?t it true that Mr. Epstein had at 1 3 MR. RHEINHART: Same objection previousiy 1 4 ieast one or two scheduled appointments for sex with 1 4 stated to the previous question. 1 5 underage girls every day whiie he was here in Pahn 1 5 THE WITNESS: On the instruction of my 1 6 Beach County in the year 2005? 1 6 iawyer, i must choose to invoke my Fifth 17 MR. RHEINHART: Objection to the form. 17 Amendment right. 1 8 It's compound, standing objection as well, and 1 8 BY MR. KUVIN: 9 instruct the witness not to answer. 1 9 Q. Same with respect to any appointments kept 2 0 THE WITNESS: On the instruction of my 2 for Mr. Epstein in 2006. 2 1 iawyer, I must choose to invoke my Fifth 2 1 MR. RHEINHART: Same objection as 2 2 Amendment right. 2 2 previoust stated to the iast two questions. 2 3 BY MR. KUVIN: 2 3 THE WITNESS: On the instruction ofrny 2 4 Q. Did you actuain locate underage giris in 2 4 iawyer, I must choose to invoke my Fifth 2 5 Palm Beach for Jeffrey Epstein to rape? 2 5 Amendment privilege. 46 (Pages 1 1 to 8 (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-4506 Page 185 Page 187 1 BY MR. 2 MR. Yeah, whenever you get to 2 Q. Have you provided any appointment books to 2 a convenient point in your questioning, i think 3 anyone with respect to appointments for Mr. Epstein? 3 we can use a break. if you're in the middle of 4 MR. HART: Same standing objection as 4 something, i don?t want to stop you. 5 to knowledge of Mr. Epstein. The question is 5 MR. KUVIN: No, this is fine. We can take 6 compound and instruct the witness not to 6 a quick break. Five minutes? 7 answer. 7 MR. RHEINHART: Yes, thank you. 8 THE On the instruction of my 8 THE We're now offtlie 9 lawyer, must choose to invoke my Fifth 9 record. it is 2:08 pm. 1 0 Amendment right. 1 (A brief recess was held.) 1 1 BY MR. KUVIN: 12 Q. Would Bp Mr. Epstein pay the underage 12 1 3 girls more money if they took off both their tops 1 3 1 4 and their bottoms? 1 4 1 5 MR. RHEINHART: Objection to the form, 1 1 6 standing objection. Instruct the witness not 1 6 17 to answerthe instruction of my 3. 8 1 9 lawyer, I must choose to invoke my ifth 1 9 2 0 Amendment right. 2 2 1 BY MR. KUVIN: 2 l. 2 2 Q. Would Mr. Epstein pay the underage girls 2 2 2 3 more if they would actually touch his penis? 2 3 2 4 MR. Same instruction, same 2 4 2 5 objection. 2 5 Page 186 1 THE WITNESS: On the instruction of my 2 lawyer, i must choose to assert my Fifth 3 Amendment right. 4 BY MR. Kt}sz 5 Q. Would Mr. Epstein pay the underage girls 6 more if he would allow them to have sex with thorn? 7 MR. RHEINHART: Can you restate that 8 again? 9 MR. KUVIN: YesWould Mr. Epstein pay the underage girls 12 more money if they would allow him to have sex with 13 them? 1 4 MR. RHEINHART: Objection to the form, 5 standing objection. Instruct the witness not 1 6 to answer. 1 7 THE WITNESS: On the instruction of my 1 8 lawyer, i must invoke my Fifth Amendment right. 3. 9 MR. KUVIN: Hang on one second. You can 2 0 stop at any time i'll sign it. 2 1 MR. Mr. Kuvin, I don't know if 2 2 you're getting to a convenient breaking point 2 3 but 2 4 MR. KUVIN: Do you want to take a quick 2 one? 47 (Pages 185 to 187) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Page 187 Page 189 UNITED STATES DISTRICT COURT 3. EN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT SOUTHERN DISTRICT OF FLORIDA IN AND FOR PALM BEACH COUNTY, FLORIDA 2 CASE NO. 502003CA02805 AB CASE NO. 3 5 4 3 JANE DQE 2? Piaimia, 5 VOLUME OF ?vs? VOLUME 11 OF JEFFREY EPSTEIN, 6 Defendant. IEFFREY EPSTEIN, I Defendant. Related cases: 8 I 08~30232, 08-08380, 0880381, 08?80994 9 0880993, 08?8081 1, 0880893, 09-80469 DEPOSITION 0F SARAH KBLLEN 8 09 80591, 09 80656, 09 80802, 09 81092 Wednesday, March 24? 201 12 10:37 - 6:51 pm. 13 DEPOSITION OF 14 SARAH KELLER 5 250 Australian Avenue South West Palm Beach, Fiorida 33401 Wednesday, Mal-ch 24, 2010 16 10:3? 6:51pm. 17 250 Australian Avenue South 3-8 suite 1500 9 Eepg?dam? RPR PPR . 3?31 I in 3 3 West Palm Beach, Fiorlda 33401 2 0 Notary pub?c, State of Fiorida g; Reported By: 2 1 Prose Court Reporting Hopkins, RPR, FPR 2 2 Notary Public, State of Fiorida 2 3 Prose Court Reporting 2 4 Job N0.: 1434 25 Page 188 Page 190 1 IN THE. CIRCUIT COURT OF 15TH JUDICIAL CIRCUIT 1 IN THE CIRCUIT COURT OF "ff-IE FIFTEENTH JUDICIAL IN AND OR PALM BEACH COUNTY, FLORIDA CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 CASE NO. AD 2 CASE AB 3 3 13W, 8.13. 4 4 Plaintiff: Piaintiff 5 5 3 6 VOLUME 0F ?1 6 ~vs~ VOLUME 8 OF IEFFREY EPSTEIN 7, JEFFREY AND SARAH KBLLEN, 8 8 Defendant. I Defendants. 9 9 0 1 DEPOSITION OF SARAH KELLEN 1 VIDEOTAPED DEPOSITION OF 1 2 Wednesday, March 24, 20 20 1 2 SARAH KELLBN . . 3 ?0.37 6.51 p.211. 1 3 4 Wednesday, March 24, 2010 14 250 Australian Avenue 30th 10337 515? P-m- West Paim Beach, Fiorida 3340250 Australian Avenue South 3. "3 Suite I 500 1 8 Reported By: 1 8 West Palm Beach, Florida 3340} Cymhia Hopidns, RPR, FPR 3. 9 3.9 Notary Pubiic, State of Flarida 2 Prose Conn Reporting 2 3. 2 0 2 2 Reported By: 2 1 Hopkins, RPR, FPR 2 2 2 3 Notary Pubiic, State of Florida 2 3 i?rose Court Reporting Services 24 24 job No; 1484 i. 2 2 5 gamma 83359.6 mm {3 ?84 M3481 $32 N??ia'gm mamammza: 3* mi 5:33.568 gagsmsiazme $8332? 1 (Pag?s 187 to 190) (561) 832-7506 .3 e. inking; ?ka?a?i'am?m?m?f 1 Mm - v. dram: {Kw-Km W64 3:1 ?it"m m??mii?ai?m 113.1%! set-:- 33' Page 191 Page 193 1 APPEARANCES: 1 2 . On behalfofthe Plaintiffs, 8.8.: 3 SPENCER T. KUVIN, ESQUIRE 2925 PGA Boulevard 4 suite 200 5 Palm Beach Gardens, Florida 33420 5 DIRECT CROSS RBDIRECT Phone: 562.515.1400 6 BY KUVIN E94 6 On behalf ofthe Ptaimiffs, L.M., aw. and 7 BY MR- HOROWITZ 21? 8 Jane Bee: BY MR. WEISSING 271 9 MATTHEW WEISSING, ESQUIRE 8 BY GARCIA 3?25 FARMER, were, WEISSING, EDWARDS 9 10 FISTOS LEHRMAN8mm; :1 venue I Fort Laederdazo, Florida 33302 1 2 12 Phone: 954.524.2820 1 3 13 On behaif of Jane Does 1 throug? 8: 14 ADAM D. Honowm, ESQUIRE, 4 EXHIBIT DESCRIPTION PAGE MERMELSTEIN HOROWITZ, PA. 1 5 3.5 18205 Biscayne Boulevard . Suite 2213 1 6 EX. 14 REQUEST FOR WARRANT 197 15 $333113 EX. 15 ANSWER AND 342 one: . . 17 E?mail: Ahorowitz@sexabasea2tomey.com 3" 7 AFFIRMATIVE DEFENSES 1 8 On eehezfofthe Plaintiffs, 101, 202 and 103: 1 8 1 9 KATHERINE W. EZELL, 1 9 AMY JOSEFSBERG EDERI, 20 20 25 West Flagler Street 2 2 1 Suite 800 2 2 Miami, Florida 33130 22 Phone: 305.358.2382 23 23 {Via telephone) 2 4 2 4 Page 192 Page 194 1 Appearances 1 I 2 On behalf of the Plaintiff, iane Doe II: 2 ,3 ,9 ,3 3 ISIDRO MANUEL GARCIA, ESQUIRE GARCIA, ELKINS BOEHRINGER 3 THE VIDEOGRAPHER: We?re now back on the 4 224 Datum Avenue, Suite 900 - . 4 West Palm Beach, Haida 3340i 4 record. It IS 2.19 pm. Starting Media Unit 5 Phone: 561.832.8033 5 NO- 2- f: If 6 DIRECT EXAMINATEON 6 8 6 61?. an I 8 LACK ALAN GOLDBERGER, ESQUIRE 7 BY MR- ATTERBURY, GOLDBERGER WEISS, PA. 8 Q. right. Did Eef??ey Epstein taik to 9 3:33?? Avenue Smith 9 you about whether or not he was going to be going to is West Palm Beach, Fion?da 33401?5012 1 0 jail 3361? he was arrested? 1 1 Phone: 561.659.8300 1 3. MR. Objection to the form, 12 12 standing objection. Instruct the witness not 3.3 On behalf of the Witness: 1 3 to answer. 1 4 BRUCE E. REMHART, ESQUIRE . - LAW OFFECE OF BRUCE B. RBINHART 1 4 THE WE On the Instruction of my 1 5 One Charla? Center 1 5 lawyer, I must Invoke my Fifth Amendment right. 250 South Australian Avenue, Suite 1400 6 BY MR. KUVIN: 3? 6 glisgeiiaggfzegf?gg?nda 33401 1 '7 Q. How did you ?rst ieam of the criminal 1? 1 8 investigation with respect to Mr. Epstein? :3 1 9 MR. Objection to the form, 20 ALSO PRESENT: 2 0 standing objection. Instruct the witness not 2 1 Jessica Cadwell, Paralegal 2 3. to answer. Bunnan, Critton, Luttier Coteman, PA. . . 22 joseph Komk: Videographer 2 2 THE WITNESS. On the of my Prose Court Reporting Services 2 3 lawyer, i must exercise my Fifth Amendment right. mam-2.2m 2 (Pages 191 to 194) (563.) PROBE COURT REPORTING AGENCY, INC. (561) 832*7506 i2 i?ei? 3" -. riihikwii "235 annexation-man. a. - WM r" m?M?MMe-uemrtrerwer Am'mwv . max/MN ?a a?ewix' e?-iuihz Page 195 Page 197 1 BY MR. KUVIN: It not know about. 2 Q. Do you know who tipped off ieffrey Epstein 2 But if you can answer, go ahead. 3 about an ongoing investigation against him back in 3 THE WITNESS: No. 4 2005?? 4 BY MR. KUVIN: 5 MR. Same objection as 5 Q. Let me show what we?il mark as Exhibit 14, 6 previously stated to the last two questions and 6 which purports to be a request for a warrant for 7 same instruction. ?7 your arrest. 8 THE WITNESS: On the instruction of my 8 MR. Okay. 9 lawyer, i must invoke my Fifth Amendment right. 9 (Plaintiffs Exhibit No. 14 was marked for 0 BY MR. KUVIN: 1 identi?cation.) 1 1 Q. Were you aware that there was a warrant 1 3. BY MR. 2 issued for your arrest in connection with . 12 Q. Just yes or no; have you seen that request 1 3 Jeffrey Epstein? 13 for a warrant before? 1 4 MR. RHEINHART: Objection to the form, 14 A. No. 1 ?53 standing objection, same instruction. 1 5 Q. Ail right. If you wouid turn to the 1 6 THE On the instruction of my 1 6 probable cause affidavit. if you would go ahead and 1 7 lawyer, I must invoke my Fifth Amendment right. '7 turn to the keep turning, and again. There Have you seen the warrant that was issued 9 All right. There's a document attached to 2 0 for your arrest in connection with Jeffrey Epstein? 2 8 this exhibit entitled, Probable Cause Af?davit. 2 1 MR. RHEINI-IART: Same objection and same 2 3. Have you had a chance to read through this 22?page 2 2 instruction as the last question. - 2 2 document in the past? 2 3 THE WITNESS: On the instruction of my 2 3 MR. RHEINHART: I?m sorry. Are you asking 2 4 lawyer, I must invoke my Fifth Amendment right. 2 4 her if she?s ever seen it before or if she?s 2 5 3 2 5 ever read it before? Page 196 Rage 198 1 BY MR. KUVIN: 3. MR. KUVIN: Good point. 2 Q. Have you seen the probable cause af?davit 2 BY MR. KUVZN: 3 with respect to the arrest warrant issued for your 3 Q. Let?s ask first: Have ever seen it 4 arrest on May 1, 2006? 4 before? 5 MR. Hang on one second. i 5 A. I don't believe so. 6 object to the form. Can you, can you 6 Q. Okay. if you would turn to keep it in 7 repeat the question just for the record? 7 front of you if we turn to ?age 22, and we look 8 MR. KEVIN: Yes. 8 at the last paragraph. 9 BY MR. KEVIN 9 Do you agree that Epstein in the years, 1 8 Q. Have you been made aware, or have you ?n 1 0 2005, 2804 and 2005, did commit lewd and iascivious i let me ciarify. Have you seen the probabie cause 1 it molestation on a i4-year~old girl? 3.2 affidavit that was attached to your warrant for 12 MR. Just if I can ciarify, are 3.3 arrest on May 1, 2006? I 3 you asking whether that's what the document 1 4 MR. RHEINHART: Object to the form. i 14 says? 3. 5 don?t believe there ever was a warrant issued, 3. 5 MR. No, I'm asking whether she?s 6 but go ahead and answer the question, if you 1 6 aware of it. 1 7 can. 17 MR. RHEINHART: I'm going to object to the 8 THE WITNESS: No. 3. 8 form. It calls for a legal conclusion that 1 9 BY MR. KUVIN: 1 9 she's not competent to make. That's ambiguous 2 8 Q. Have you seen the request for a warrant 2 in that regard, and also the standing objection 2 3. with the attached probahie cause af?davit that was 2 and I will instruct her not to answer. 22 issued on May Est, 2006? 2 2 THE On the advice of my lawyer, 2 3 MR. Object to the form. 2 3 I must to invoke my Fifth Amendment right. 2 4 Assumes her knowledge of something that she may 2 4 BY MR. KUVIN: 2 not know, the existence of something she may 2 5 Q. Do you agree that in the years 2004 and 3 (Pages 195 to 198) (561) 832?7500 RROSE COURT REPORTING AGENCY, INC. (561) 832*7506 an? Page 199 Page 203. Il. 2005 Mr. Epstein molested hundreds of 14, 15, and 3. Ieffrey Epstein took nude photos of girls under the 2 16?year-old girls? 2 age of 18? 3 MR. Same objection to the 3 MR. RHEINHART: Objection to the form, 4 form, standing objection and also calls for a 4 standing objection, instruct the witness not to 5 legal conclusion and is ambiguous. Instruct 5 answer. 6 the witness not to answer. 6 THE WITNESS: On the instruction of my 7 THE WITNESS: On the instruction of my 7 lawyer, i must invoke my Fifth Amendment right. 8 lawyer, I must invoke my Fifth Amendment right. 8 BY MR. KUVIN: 9 BY MR. KUVIN: 9 Q. Have you taken any photographs of girls Q. Do you agree that the facts contained 3. 0 under the age of 18, nude photographs of girls under 1 3. within this probable cause af?davit are true and 1 ii. the age of 18 yourself? 2 accurate? 12 MR. RHEINHART: Object to the form as 3 MR. Objection to the form. 13 ambiguous. Can we get a time period or any 4 You?ve never established that she's read it, so 1 4 sort of l. 5 how can she say whether it?s true and accurate. 1 5 MR. KUVIN: Sure. 3. 6 instruct the witness not to answer the 6 MR. RHEINHART: limitation of that? 3. 7 question. Do you want to clarify your 1 '7 MR. KUVEN: Absolutely. 18 question? 18 BY MR. KUVIN: 3. 9 MR. KUVIN: No. 1 9 Q. in the years of 2004 to 2006, did you ever 2 0 BY MR. KEVIN: 2 0 taken any nude photographs of underage girls being 2 3. Q. Were you present at 358 El Brilio Way when 2 1 girls under the age of 18? 2 2 the search warrant was issued for that home? 2 2 MR. RHEINHART: Object to the form as 2 3 MR. Objection to the form as 2 3 ambiguous. instruct the witness not to answer. 2 4 to any knowledge of 358 El Brilio Way. Also 2 4 THE On the advice of my lawyer, 2 5 ambiguous. Are you asking about when the 2 5 I must exercise my Fifth Amendment right. Page 200' Page 202 1 warrant was issued or when the warrant was 3. MR. KUVIN: And just so we're clear, when 2 executed? 2 you say ?instruct the witness not to answer,? 3 MR. KUVIN: i don?t know. You criminal 3 you mean for the Fifth Amendment grounds as 4 guys know the language. 4 opposed to i 5 BY MR. KUVIN: 5 MR. Well, technically that 6 Q. When the cops came into the house and 6 would be manufacturing child pornography, so if 7 searched the home at 358 El Brillo Way, were you 7 the truthful answer that question would be yes, 8 there? 8 she would be admitting to a crime. 9 MR. Objection to the form as 9 MR. KUVIN: No, I understand that. 1 to compound, and assuming knowledge as to 0 MR. RHEINHART: So yes, i?m instructing 1 it 358 El Brillo Way or any search by the police. 1 1 her not to answer the question. 2 instruct the witness not to answer. 3.2 MR. KUVIN: Because there have been some 1 3 THE MWESS: On the instruction of my 3.3 questions that we?ve instructed her, you?ve 1 4 lawyer, i must exercise my Fifth Amendment 3. 4 instructed her not to answer at all, and then 3. 5 privilege. 5 others i just wanted for clarify. g; 1 6 BY MR. KUVIN: 6 MR. RHEINHART: Thank you. I was getting 17 Q. Are you aware of any covert cameras that 1 '7 sleppy. i apologize. 8 exist in the home at 358 El Brillo Way? 1 8 MR. KUVIN: That?s okay. 1 9 MR. Objection to the form. 1 9 BY MR. KUVIN: 2 0 Standing objection as it relates to El Briilo 2 Q. All right. Do you agree that you have -- 2 1 Way, and instruct the witness not to answer. 2 1 well, let me ask you this: Have you taken any video 2 2 THE WITNESS: On the instruction of my 2 2 of girls under the age of i 8, nude girls under the 2 3 lawyer, I must invoke my Fifth Amendment rightthe years 2004 through 2006MR. Once again 2 5 Q. Are you aware or whether or not 2 5 MR. KUVIN: Go ahead. 4 (Pages 199 to 202) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*?506 Page 203 Page 205 ft? 1 MR. Wait. Hold on a second. 1 Standing objection as to knowiedge of 2 Let me go back to the prior question about 2 Mr. Epstein. instruct the witness not to 3 still photographs. 3 answer based on the Fifth Amendment. 4 MR. KUVIN: Yes. 4 THE WITNESS: On the instruction of my 5 MR. RHEINHART: Okay. And I think the 5 iawyer I must exercise my Fifth Amendment 6 question was had-taken between ?04 6 right. 7 and '06 any still ph'btographs of nude women 7 BY MR. 8 under the age of 18. 8 Q. Do you know whether or not an attempt to 9 MR. KUVIN: Yes. 9 give a $90,000 donation was an attempt to stop the 1 0 MR. RHEENHART: is that correct? 1 want 1 0 Palm Beach Police from investigating Mr. Epstein? 1 1 to go back to that question. 1 1 MR. Objection to the form. 12 MR. KUVIN: Okay. You can go back to that 12 Standing objection as previously stated, and 1 3 question. 13 the same instructions as the previous question. 14 THE WITNESS: No. 1 4 THE WITNESS: At the instruction of my 1 5 BY MR. KUVIN: 1 5 lawyer, I must invoke my Fifth Amendment right. i 6 Q. Have you taken any nude videotape of girls 1 6 MR. Hold on a second. Almost 1 7 under the age of 18 for the years 2004 through 2006? 1 7 doneMR. KUWN: 1 9 Q. Asking those same questions, have you 1 9 Q. Is your mother also named Sarah Kellen? 2 0 taken any nude photographs of girls under the age from 2004 through 2006? 2 3. Q. Did you ever Iive at 2644 Peter Street, 22 A. No. - 22 Honolulu, Hawaii? 2 3 Q. Have you taken any nude video of giris 23 MR. instruct the witness not 2 a under the age of 18 from 2004 to 2006? 2 4 to answer based on the Fifth Amendment 25 A. No. 25 privilege against self-incrimination. 5 Page 204 Page 206 1 Q. Do you know what the COUQ Foundation is? 1 THE WITNESS: On the instruction of my 2 A. Can you repeat that? 2 lawyer, I must invoke my Fifth Amendment right. i 3 Q. Do you know what the COUQ Foundation is? 3 BY MR. KUVIN: 4 MR. RHEINHART: Mr. Kuvin, can I ciarify? 4 Q. Did you ever live at 301 East 66th Street, 5 Are you asking if she's ever heard of such an 5 Apartment Iii-N in New York, New York? 2: 6 entity or whether she actualiy knows what that 6 MR. RHEINHART: Same instruction as 7 entity is? '7 previous question. 8 MR. KUVIN: Let?s start with if she?s ever 8 THE WITNESS: On the instruction of my 9 heard over it, and then I will follow up with 9 lawyer, I must invoke my Fifth Amendment right. 0 the following question of whether she knows 1 0 BY MR. KUVIN: 1 1 what it is. 1 1 Q. Have you ever gone by the name of Sarah 12 MR. sauna-mar; Okay. 12 Bonk, B-o-n-k? 13 BY MR. KUVIN: 3 MR. Same instruction as the 1 4 Q. Have you ever heard of this, about the IL 4 previous two questions. 1 5 COUQ Foundation before? 1 5 THE WITNESS: On the instruction of my i 6 MR. RHEINHART: I instruct her not to 6 lawyer i must invoke my Fifth Amendment right. 1 7 answer based on her Fifth Amendment priviiege. 7 BY MR. KUVIN: 8 THE WITNESS: On the advice of my lawyer, 8 Q. Did you change your name from Sarah Bonk 1 9 I must assert my Fifth Amendment right. 1 9 to Sarah Kellen? 2 0 BY MR. KUVEN: 2 0 MR. RHBINHART: Objection to the form and 2 1 Q. Were you aware that Mr. Epstein, through 2 3. it assumes a prior question that there was no 2 2 the COUQ Foundation, attempted to make a $90,000 22 answer to, and I would instruct the witness not 2 3 donation to the Palm Beach Police Department in 2 3 to answer. 2 4 2006? 2 4 THE WITNESS: Upon the instruction of my 2 5 MR. Objection to the form. lawyer, I must invoke my Fifth Amendment right. (561) 832~7500 PROBE COURT REPORTING RGENCY, 5 INC. (Pages 203 to 206) (561) 832-7506 huge 20? (561) PROSE COURT REPORTING AGENCY, 1 BY MR. KUVIN: 1 compound, instruct the witness not to answer. 2 Q. Have you ever used the alias of 2 THE WITNESS: On the instruction of my 3 Sarah Bonk? 3 lawyer, I must invoke my Fifth Amendment right. 4 MR. anemHAnr: Objection to the l?rn 4 BY MR. KUVIN: 5 sorry. instruct the witness not to answer 5 Q. Have you ever used illegal drugs with 6 based on Fifth Amendment privileges. 6 Nadia Marcinkova? '7 THE WITNESS: Upon the instruction of my 7 MR. RHEINHART: Same obiection and 8 lawyer, i must invoke my Fifth Amendment right. 8 instruction as to the previous question. 9 BY MR. KUVIN: 9 ?i?i?IE WITNESS: On the instruction of my Q. Do your parents live in North Carolina? 3. 0 lawyer, i must invoke my Fifth Amendment right. 1. 1 MR. RHEINHART: instruct the witness not fl 1 BY MR. KUVIN: i. 2 to answer the question based on her Fifth 12 Q. Did you ever use the phone number of 3 Amendment privilege. 1 3 655-0995? 1 4 THE WZTNESS: On instruction of my lawyer i 4 MR. RHEINHART: instruct the witness not 1 5 i must invoke my Fifth Amendment right. 15 to answer based on her Fifth Amendment 1 6 BY MR. 3. 6 privilege. 1 7 Q. Do you have any brothers and sisters? it?? 'i?l-IE WITNESS: On the instruction of my 1 8 MR. RHEINHART: Same instruction as the 1 8 lawyer, I must invoke my Fifth Amendment right. 9 previous question. 1 9 BY MR. KUVIN: 3 2 0 THE On the instruction of my 2 0 Q. Rave you ever. used the phone number 2 lawyer, I must invoke my Fifth Amendment right. 2 1 881-8116, 881?8l16." 22 BY MR. 22 MR. Thank you. 2 3 Q. Have your parents met Jeffrey Epstein? 2 3 'l?l-lE I don?t recognize that 2 4 MR. RHEINHART: Objection to the form. 2 4 number. 2 5 Standing objection and also instruct the 2 5 Page 208 Page 210; witness not to answer based on her Fifth 1 BY MR. KUVIN: 2 Amendment privilege. 2 Q. Okay. When the police entered Jeffrey 3 ?i?i-lE WETNESS: On the instruction of my 3 Bpstein?s home, they took something that?s called a 4 lawyer, I must invoke my Fifth Amendment right. 4 bottle of Peach Flavored Joy Jelly. Just a 5 BY MR. KUVIN: 5 foundation of what I?m about to ask you. 6 Q. Do your parents know what you've done with 6 Have you ever seen anything called Peach ?7 7 8 MR. RHEINHART: Objection to the form as 8 l-iave you ever seen that before anywhere? 9 stated to the previous question, and same 9 MR. Just so i am clear about 1 instruction. 1 8 your question 1 1 THE WITNESS: 0n the instruction of my 3. MR. KUVIN: Not necessarily in a home, 12 lawyer, i must invoke my Fifth Amendment right. 1 2 just anywhere in her entire life has she ever 1 3 BY MR. KUVIN 3 seen a bottle of something called Peach 1 4 Q. Have you ever used illegal drugs with 1 ?fl Flavored Joy Jelly. 1 5 Jeffrey Epstein? 1 5 THE WITNESS: No, i have not. 6 MR. Objection to the form. 1 6 BY MR. KUVIN: 7 Standing objection, instruct the witness not to 1 7 Q. Okay. Also taken from the home were, was It 8 answer. 1 8 an adult sex toy called a Twin Torpedo which, 1 9 THE WITNESS: On the instruction of my 1 9 according to Detective Recarey during his deposition 2 0 lawyer, I must invoke my Fifth Amendment right. 2 was a donbie~headed dildo. Not with respect to 2 1 BY MR. KUVIN: 2 1 Mr. Epstein, but in your life, have you ever seen 2 2 Q. Have you ever used illegal drugs with 22 something called at Twin Torpedo or double-headed 2 3 Ghislaine Maxwell? 2 3 dildo? 2 4 MR. RHEINHART: Objection to the form, 2 4 A. No, I have not. 2 5 assumes knowledge of Ghislaine Maxwell. It?s 2 5 Q. Also confiscated from the home was soap in 6 (Pages 207 to 21 ENC. (561) 832?97506 Page 211. Page 213 2i Ki rams. xrewaalanzaauzac-?a ii s. 1 the shape of a penis and vagina. Once again, not i HE On the instruction of my 2 necessarily with respect to Mr. Epstein's home, in 2 lawyer, I must invoke my Fifth Amendment right. 3 your entire life have you ever seen soap in the 3 BY MR. 4 shape of a penis and vagina? 4 Q. Do you agree that these cerporations that 5 A. Not that I recall. 5 ijust mentioned were utilized by Jeffrey Epstein in 6 Q. Do you ever recall being in Ohio? 6 an attempt to have sexual relationships with 7 MR. Ever in her life? 7 underage girls? 8 MR. KUVIN: The state, ever in her life. 8 MR. RHEINHART: Objection to the form as 9 MR. KUVIN: 9 to compound, and also assumes knowledge of 1 Q. Let?s start there, recall being in the 1 0 Mr. Epstein, asks for more than one answer to 1 1 State of Ohio for any reason? i 3. the question. i would instruct her not to 1 2 A. Maybe for a layover, but not that 12 answer based on her Fifth Amendment privilege 1 3 specifically remember. 1 3 because the question assumes knowledge of 4 Q. Okay. Do you know an lvan Robles? 1 4 Mr. EpsteinTREE WITNESS: Upon instruction of my 1 6 Q. Have you seen a gentleman by the name of 6 lawyer i must invoke my Fifth Amendment right. 1 7 Alan Dershowitz at the home of Jeffrey Epstein 7 MR. KUVIN: I think I am done. Hang on 18 be?ue? l8 onesecond. 1 9 MR. RHEINHART: Objection to the form. 1 9 All right. I appreciate it. That's all 2 0 Standing objection, presumes knowledge of 2 8 the questions i have at this time. Reserve the 2 1 Jeffrey Epstein or his home. Instruct the 2 3. right to ask any follow-up questions if other 2 2 witness not to answer. 2 2 attorneys raise new and different issues by 2 3 THE On the instruction of my 2 3 their questioning. 2 4 lawyer, I must exercise rny Fifth Amendment 2 4 MR. Understood. 2 5 right. 2 5 MR. KUVIN: Pass the witness at this time. Rage 212- Page 214 1 BY MR. KUVIN: 1 Who wants to go? Mr. Horowitz, do you have a 2 Q. Have you ever heard of the El Zorro Ranch 2 microphone? 3 Corporation? 3 MR. HOROWITZ: I do. 4 MR. RHEINHART: Instruct the witness not 4 CROSS (SARAH KELLEN) 5 to answer based on her Fifth Amendment 5 BY MR. 6 privilege. 6 Q. Ms. Kellen, did you use the telephone 7 THE) WITNESS: On the instruction of my 7 number, the (9l7)855?3363 at any time between 2001 8 lawyer i must exercise my Fifth Amendment 8 and 2006? 9 right. 9 A. On the advice of my lawyer, I must exercise Fifth Amendment right. 3. 1 Q. Have you ever heard of the New York - 1 Q. {)id you use the telephone number 12 Strategy Group? 12 (917)855-3363 between 2001 and 2006 at Jeffrey 13 MR. Same instruction. 13 Epstein?s expense? 1 4 THE WITNESS: On the instruction of my . 1 4 MR. Objection to the fonn in 5 lawyer, i must invoke my Fifth Amendment right. 3 1 5 that it assumes knowledge of ieffrey Epstein. 1 6 BY MR. KUVIN: 1 6 Standing objection as previously stated with 1 7 Q. Have you ever heard of the Ghislaine 3. '7 Mr. Kuvin. Instruct the witness not to answer, 1 8 Corporation? 1 8 based on her Fifth Amendment right. 1 9 MR. RHEINHART: Same instruction. . 1 9 THE WITNESS: On the instruction of my 2 0 THE WITNESS: On the instruction of my 2 0 lawyer, I must exercise my Fifth Amendment 2 1 lawyer, i must invoke my Fifth Amendment right. 2 1 right. 2 2 BY MR. KUVINHave you ever heard of the Financial 2 3 Q. Did you use the telephone number 2 4 Strategy Group? 2 4 (917)855-33 63 at Jeffrey Epstein's direction? 2 5 MR. RHEINHART: Same instruction. 25 MR. RHEINHART: Same objection as the 7 (Pages 211 to 214) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Page 215 Page 217 a a it i rams/mm .w some m?w?m?r? t??wx'm W?m ?(traumatizeer ?1 I a . mg 1 previous question and the same instruction. 1 lawyer, i must choose to exercise my Fifth 2 THE WITNESS: On the instruction of my 2 Amendment right. 3 lawyer,?i must exercise my Fi?h'Amendment '3 BY MR. HOROWITZ: 4 right. 4 Q. Did Jeffrey Epstein ever admit to you that 5 BY MR. HOROWITZ: 5 between the years 2001 and 2006 he had sexual 6 Q. Was (917)855~3363 a telephone number from 6 contact with underage girls who came to, quote, work ?7 which you placed telephone calls on behalf of ?7 for him? 8 Jeffrey Epstein? 8 MR. Objection to the form, 9 MR. RHEINEIART: Same objection as the 9 standing objection previously stated. Also 1 0 previous question and the same instruction. 1 0 ambiguous as to the term "work for him.? 1 1 THE WITNESS: On the instruction of my 1 instruct the witness not to answer based on her 12 lawyer, i must invoke my Fifth Amendment right. 1 2 Fifth Amendment privilege. 1 3 BY MR. HOROWITZ: 1 3 THE WITNESS: On the instruction of my 1 4 Q. Between 2001 and 2006, was it your job to 4 lawyer, I must choose to exercise my Fifth 5 set up massage tables for Jeffrey Epstein? 1 5 Amendment right. 1 6 MR. RHEINHART: Same objection as the 1 6 BY MR. HOROWZTZ: 7 previous question, same instruction. 1 ?7 Q. Between the years 2001 and 2006, did 1 8 THE WITNESS: On the instruction of my 1 8 Jeffrey Epstein ever tell you that he masturbated in 9 lawyer, i must invoke my Fifth Amendment right. 1 9 the presence of underage girls who came to, quotework for him? 2 1 Q. Between 200i and 2006, was it yonrjob to 2 1 MR. RHBINHART: Objection to the form. 2 2 arrange massage oils before Jeffrey Epstein?s 22 Standing objection previously stated and 2 3 massages? 2 3 instruct the witness not to answer. 2 4 MR. RHEINHART: Objection to the form. 2 4 THE On the instruction of my 2 5 it?s compound and assumes facts not admitted to 2 5 lawyer, I must exercise my Fifth Amendment Page 216 Page 218 1 be to the knowledge of this witness, and i 1 right. 2 instruct her not to answer based on her Fifth 2 BY MR. HOROWITZ: 3 Amendment privilege. 3 Q. Do you know a girl named or did you 4 THE WITNESS: On the instruction of my 4 know a girl named Jane Doe No. 2, (spells name), 5 lawyer, i must invoke my Fifth Amendment right. 5 when she was still under the age of 18? 6 BY MR. HOROWZTZ: 6 A. On the instruction of my lawyer, I must choose 7 Q. At any time between 2001 and 2006, was it '7 to invoke my Fifth Amendment right. 8 yourjob to place telephone calls to girls under the 8 Q. Do you acknowledge that Jane Doe No. 2 9 age of 18 when Jeffrey Epstein was in Palm Beach to 9 came to Jeffrey Epstein's Palm Beach estate in late 1 0 see if the girls wanted to, quote/unquote, work? 1 0 2004? 1 1. MR. RHEINHART: Objection to the form as 1 1 MR. RHEINHART: Objection to the form. 1 2 compound and instruct the witness not to answer 1 2 Standing objection previously stated as to 13 based on her Fifth Amendment privilege. 13 compound and ambiguous, and I instruct the 4 THE WITNESS: On the instruction of my 1 4 witness not to answer based on her Fifth 15 lawyer, I must invoke my Fifth Amendment right. 1 5 Amendment privilege, based on the prior, based 1 6 BY MR. HOROWETZ: 1 6 on the prior answer to the prior question. 17 Q. Between the years 2001 and 2006, did you i 17 THE WITNESS: Sony. 1 8 and Jeffrey Epstein have an understanding between i 18 MR. HOROWITZ: There was a question 1 9 the two of you that the term "wor referred to him 9 pending. 2 0 having sexual contact with girls under the age of . 2 0 MR. RHEINHART: There was a question 2 1 18? 2 1 pending. i have instructed you not to answer. 2 2 MR. RHEINHART: Objection to the form, 2 2 THE WITNESS: Oh, then upon the 2 3 standing object, standing objection, and 2 3 instruction of my lawyer, i must invoke my 2 4 instruct the witness not to answer. 2 4 Fifth Amendment right. 25 a 8 (Pages 215 to 218) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 as; mg 3: Page 219 Rage 221 1 BY MR. HOROWITZ: 1 THE On the instruction of my 2 Q. Between the years 2001 and 2006, did 2 iawyer, I must invoke my Fifth Amendment right. 3 Jeffrey, did Jeffrey Epstein instruct you to 3 BY MR. HOROWITZ: 4 communicate by teiephone to arrange for girls under 4 Q. Did you teii Jeffrey Epstein that you had 5 the age of 18 to come to his house for his sexual 5 to con?rm by telephone that Jane Doe No. 2 would be 6 grati?cation? 6 coming to his home at a speci?c time to give him a 7 MR. Objection to the form. 7 massage? 8 Standing objection previously stated, and also 8 MR. Objection to the form, 9 it?s ambiguous. Instruct the witness not to 9 standing objection as previousiy stated, and 1 0 answer based on her Fi?h Amendment privilege. 1 0 the same instruction to the witness. 1 1 THE WITNESS: On the instruction of my 1 1 THE WITNESS: On the instruction of my 3. .2 lawyer, I must exercise my Fifth Amendment 3. 2 lawyer, i must invoke my Fifth Amendment right. 3.3 privilege. 3.3 BY MR. nonowrrzBid Jeffrey Epstein teii you that it was 1 5 Q. in late 2004, did you receive a telephone 1 53 his intent during the course of Jane Doe No. 25 1 6 caii wherein you were told that a girl named Jane 1 6 visit to his home to have sexuai contact with her? 1 7 Doe No. 3 was bringing Jane Doc No. 2 to Jeffrey 1 '7 MR. RHEINHART: Objection to the form as 1 8 Epstein?s home? 1 8 previousiy stated to the last question and same 1 9 MR. Objection to form. 1 9 instruction to the witness. 2 0 Standing objection, compound, and instruct the 2 0 Ti?iE WITNESS: On the instruction of my 2 1 witness not to answer based upon her Fifth 2 3. iawyer, I must invoke my Fifth Amendment right. 2 2 Amendment privilegeTHE WITNESS: On the instruction of my 2 3 Q. At any point did Jane Doc No. 2 tot! you 2 4 anyer, i must exercise my Fifth Amendment . 2 4 that she was i8 years otd or older? 2 5 right. 2 5 MR. Objection to the form, Page 220 Page 222 1 BY MR. HOROWITZ: 1 assumes knowledge of a person by the name of 2 Q. Did ieffrey Epstein observe you receive a 2 Jane Doe No. 2. it?s a compound question and 3 teiephone cail wherein you were toid that .iane Doe 3 instruct the witness not to answer. 4 No. 3 was bringing Jane Doc No. 2 to his home? 4 THE WITNESS: On the instruction of my 5 MR. RHEINHART: Standing objection to the 5 lawyer, I must invoke my Fi?h Amendment right. 6 form as stated to the previous question, same 6 BY MR. 7 instruction. ?7 Q. In your own mind, is it, is it accurate to 8 THE WITNESS: On the instruction of my . 8 say that you never believed that iane Doc No. 2 was 9 iawyer, I must invoice my Fifth Amendment right. 9 i8 or cider, correctMR. Objection to the ferm, 1 1 Q. Did Jeffrey Epstein instruct you to 1 1 same basis as the prior question, and the same 12 communicate by telephone to arrange for Eane Doc 1 2 instruction. 3 No. 2 to come to his home for his sexual 1 3 THE WITNESS: On the instruction of my 4 gratification? 1 4 iawyer, I must invoke my Fifth Amendment right. 5 MR. Standing objection as 15 BY MR. HOROWITZ: 6 previously stated, same instruction to the 1 6 Q. Did Jane Doe No. 2 teil you that she 7 witness. 1 7 attended Royai Pahn Beach High School? 1 8 THE WITNESS: On the instruction of my 1 8 MR. RHEINHART: Same objection as the 9 lawyer, I must invoke my Fifth Amendment right. 1 9 previous question, same instruction. 2 0 BY MR. HOROWITZ: 2 0 THE WITNESS: On the instruction of my 2 1 Q. Did Jeffrey Epstein inform you that Jane 2 iawyer, i must invoke my Fifth Amendment right. 2 2 Doc No. 2 wouid be giving him a massage that was 2 2 BY MR. 2 3 sexual in nature? 2 3 Q. Are you aware did, did Jeffrey Epstein - 2 4 MR. Standing objection to the 2 4i tell you that he sexuaiiy abused iane Doc No. 2 when 2 5 form and the same instruction to the witness. 2 5 she was a chiid?? 9 (hages 219 to 222) (561) 83247500 PROBE COURT REPORTING AGENCY, INC. (561) 832-4506 Page 223 Page 225 i :ti zswm< Rail? li's?i MmmwaeaaWaawm-mmuaix 1 MR. RHEINI-IART: Objection to the form. 1 answer that. You can move on. 2 Standing objection relating to Jeffrey Epstein 2 MR. HOROWIT Z: You?re, you're directing 3 or any knowledge of Jeffrey Epstein. Also as 3 her not to answer that? 4 to iane Doe No. 2, same instruction to the MR. RHEINHART: I'm directing her not to 5 witness. 5 answer that question because there are, there 6 THE On the instruction of my 6 are legal bases for the objections that 7 lawyer, I must invoke my Fifth Amendment right. 7' underlie the Fifth Amendment invocation, and at 8 BY MR. HOROWITZ: 8 some point presumably ajudge will rule on 9 Q. Did Ieffrey Epstein instruct you to take 9 those before the jury ever hears this. 1 0 Jane Doc No. 2?s name and telephone number for the 0 BY MR. HOROWETZ: 3. purpose of calling her to come to his house for more 1 1 Q. Ms. Kellen, did you know a girl named lane 1 2 sexual activity? 12 Dee No. 3 when she was still a child? 1 3 MR. RHEINHART: Objection to the form. 1 3 MR. RHEINHART: Objection to the form as 1 4 Standing objection, same objection to the 4 to what you mean by when you say a child and 5 previous question, same instruction. 1 5 also assumes knowledge of a person, so I 1 6 ?fl-1E On the instruction of my 1 6 instruct the witness not to answer. 1 7 lawyer, i must invoke my Fifth Amendment right. 1 '7 THE On the instruction of my 1 8 BY MR. HOROWITZ: 1 8 lawyer, I must invoke my Fifth Amendment right. 1 9 Q. Did Jeffrey Epstein instruct you to put 1 9 BY MR. HOROWITZ: 2 {3 Jane Doc No. 2's name and telephone number into a 2 8 Q. Did, did Jeffrey Epstein instruct you to 2 1 master journal or log in which you and he archived 2 1 communicate by telephone with Haley Robson for the 2 2 the names and centact information of teenage girls? 2 2 purpose of arranging for underage girls to come to 2 3 MR. RHEINHART: Objection to the form, 2 3 his house so that he, Jeffrey Epstein, could engage 2 4 standing objection, otherwise compound and 2 4 in sexual activity? 2 5 instruct the witness not to answer. 2 5 MR. Objection to the form. Page 224 Page 226 1 THE WITNESS: On the instruction of my 1 Standing objection, compound and ambiguous. 2 lawyer, i must invoke my Fifth Amendment right. 2 Instruct the witness not to answer on Fifth 3 BY MR. 3 Amendment grounds. 4 Q. Did you, in fact, place Jane Doc No. 2?s 4 THE On the instruction of my 5 name and telephone number into a master journal or 5 lawyer, I must invoke my Fifth Amendment right. 6 log in which you and leffrey Epstein archived the 6 BY MR. HOROWITZ: 7 names and contact information for teenage girls? 7 Q. Did Jeffrey Epstein instruct you to 8 MR. Objection to the form, 8 communicate by telephone to arrange for Jane Doc No. 9 same as the previous question, ambiguous and 9 3 to give him a massage? 8 compound, and instruct the witness not to 1 0 MR. Same objection as stated 1 1 answer. 1 1 to the previous question, and standing 1 2 THE WITNESS: On the instruction of my . 12 objection, and instruct the witness not to 1 3 lawyer, I must invoke my Fifth Amendment right. it 3 answer. 1 4 BY MR. HOROWITZ: 1 4 THE WITNESS: On the instruction of my 1 5 Q. You have asserted a Fifth Amendment 1 5 lawyer, i must invoke my Fifth Amendment right. 1 6 objection as to a number of my questions relating to 1 6 BY MR. HOROWYFZ: 17 lane Doe No. 2. Is there any reason in your mind a I 17 Q. Did leffrey Epstein inform you that the 1 8 jury should not infer from your responses today that 1 8 massage lane Doc No. 3 waste give him would be 3. 9 you did, in fact, assist Mr. Epstein in procuring 1 9 sexual in nature? 2 minors for sexual activity? 2 0 MR. Same standing objection 2 1 MR. RHEINHART: Right. Objection to the 2 1 previously stated, and I instruct the witness 2 2 form. We're not going to answer that. That 2 2 not to answer. 2 3 calls for a legal conclusionTHE WITNESS: On the instruction of my 2 4 Speculate on legal objections that have been 2 4 lawyer, I must invoke my Fifth Amendment right. 2 5 made by her counsel, and we?re not going to 2 5 10 (Pages 223 to 226) (561) 832""?500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Page 227 Page 229; 1 BY MR. HOROWITZ: 1 MR. Same objection to the 2 Q. Did Epstein observe you Speaking 2 previous question, same instruction. 3 with Haley Robson by teiephone arranging for Jane 3 THE WITNESS: On the instruction come to his home to give him a massage? 4 lawyer, i must invoke my Fifth Amendment right. 5 MR. Objection to the form. 5 BY MR. HOROWITZ: 6 Standing objection, otherwise compound and 6 Q. Jane Doc No. 3 toid you she attended Royal 7 ambiguous and instruct the witness not to 7 Paim High School, correct? 8 answer. 8 MR. RHEINHART: Instruct the witness not 9 THE WITNESS: On the instruction of my 9 to answer based on her Fifth Amendment 1 lawyer, i must invoke the Fifth Amendment 1 privilege. 1 1 right. 1 1 THE WITNESS: On the instruction of my 1 2 BY MR. HOROWITZ: 1 2 lawyer, I must invoke my Fifth Amendment right. 1 3 Q. Did you tell Jeffrey Epstein that you had 1 3 BY MR. HOROWITZ: 1 4 confirmed by telephone that Liane Doc No. 3 would be 1 4 Q. Did ieffrey Epstein instruct you to take 1 5 coming to his home, his home at a speci?c time to 15 Jane Doe No. 3?s name and telephone number for the 1 6 give him a massage? 6 purpose of calling her to come back to his home for 1 "7 MR. Same objection as stated 1 7 more sexual activity? 1 8 to the previous question. Same instruction to 1 8 MR. Objection to the form, 1 9 the witness. 9 standing objection previously stated. Instruct 2 0 THE On the instruction of my 2 the witness not to answer. 2 1 lawyer, I must invoke my Fifth Amendment right. 2 1 THE On the instruction of my 2 2 BY MR. HOROWETZ: 2 2 lawyer I must invoke my Fifth Amendment right. 23 Q. Did Jeffrey Epstein tell you it was his 2 3 BY MR. HOROWITZ: 2 4 intent during the course of Jane Doe No. 3?s visit 2 4 Q. Did you, in fact, after Jane Doe No. 3's 2 5 to his home to engage her in sexual activity? 2 5 first visit to 3ei'frey Epstein?s home, call her to Page 228 Page 230 1 MR. Same objection stated to 1 arrange for her to come back to his house for more 2 the previous two questions and the same 2 sexual activity? 3 instruction. 3 MR. Standing objection to the 4 THE WITNESS: On the instruction of my 4 form of the question. instruct the witness not 5 lawyer, i must invoke my Fifth Amendment right. 5 to answer. 6 BY MR. HOROWITZ: 6 THE On the instruction of my 7 Q. Did Jeffrey Epstein tell you that during '7 lawyer I must invoke my Fifth Amendment right. 8 the course of Jane Doe No. 3?s visit to his home, 8 BY MR. HOROWITZ: 9 that he did, in fact, persuade her to engage in 9 Q. Did Jeffrey Epstein instruct you to put 1 8 sexuai activity? 1 iane Doe No. 3?s name and telephone number into a 1 1 MR. Objection to the form. . 3. master journal or iog in which you and he archived 1 2 Standing objection previously stated. Instruct 5 12 the names and contact information for underage 1 3 the witness not to answer. 13 girls? 1 4 THE On the instruction of my 1 4 MR. RHEINHART: Objection to the form, 1 5 lawyer, I must invoke my Fifth Amendment right. I 1 5 standing objection. Otherwise compound and ambiguous and instruct the witness not to 1 7 Q. At any point did Jane Doc No. 3 tell you 1 7 answer. 1 8 that she was 18 or older? 1 8 THE WITNESS: On the instruction of my 1 9 MR. RHEINI-IART: Objection to the form and 9 lawyer i must invoice the Fifth Amendment. 2 instruct the witness not to answerTHE WITNESS: On the instruction of my 2 1 Q. Did you, in fact, put Sane Doc No. 3's 2 2 lawyer, I must invoke my Fifth Amendment right. 2 2 name and telephone number into a masterjournal or 2 3 BY MR. HOROWITZ: 2 3 log, in which you and Jeffrey Epstein had archived 2 4 Q. in your mind you didn't believe that Jane 2 4 the names and information of teenage girlsolder, correct? 2 5 MR. Objection to the form, 11 (Pages 227 to 230 {561) 832?7500 PROSE COURT. REPORTING AGENCY, INC. (561) 832*7506 arses mmh??imm?'?? Tk?h?mfi33'all?i?w lasts-meet 4mm maimcmp '24?me new We Rage 231 Page 233 1 standing objection and otherwise compound and 1 answer. 2 instruct the witness not to answer. 2 'i?I-iE WITNESS: On the instruction of my 3 THE WITNESS: On the instruction of my 3 lawyer, i must invoke my Fifth Amendment right. 4 iawyer, i must exercise my Fifth Amendment 4 BY MR. 5 right. 5 Q. Did you, in fact, communicate with 6 BY MR. 6 Haley Robson by teiephone to arrange for Jane Doe 7 Q. Okay. You've asserted a Fifth Amendment 7 No. 4 to come to ieffrey Epstein's home? 8 objection and assertion of the privilege as to my 8 MR. Standing objection as 9 questions about Jane Doe No. 3. Is there any reason 9 previously stated. instruct the witness not to 3. 0 why a jury shouid not infer from your assertion of 3. 0 answer. 1 3. the privilege that you did, in fact, assist 1 1 THE WITNESS: On the instruction of my 3. 2 Jeffrey Epstein in procuring minors for his sexual 3.2 lawyer, i must invoice my Fifth Amendment right. i. 3 pleasure? 3. 3 BY MR. HORO i 4 MR. RHEINPLART: Same objection I stated 3. 4 Q. Did Jeffrey Epstein inform you that the i. 5 the last time as to the other ciient. There 15 massage Jane Doc No. 4 was to give him wouid be i 6 have been legai objections lodged to the 1 6 sexual in nature? 17 questions. if ajudge rules as to the iegality 17 MR. Objection to the form. it 8 of the questions and the pr0priety of the 8 Standing objection previously stated. Instruct i 9 answers, then the jury can draw whatever i 9 the witness not to answer. 2 inference the judge?s instructs them to draw, 2 0 THE On the instruction of my 2 i. but untii then we're not going to specuiate on 2 it iawyer, I must invoke my Fifth Amendment right. 22 what the jury ought to conciude based on 2 2 BY MR. HOROWITZ: 2 3 questions that haven?t been ruled to be proper. 2 3 Q. Did Jeffrey Epstein observe you speaking 2 4 MR. HOROWITZ: So we're clear, you have 2 4 with Haley Robson to arrange for Jane Doc No. 4 to 2 5 instructed her not to answer? 2 5 come to his home for sexuai activity? Page 232 Page 234 1 MR. I?ve instructed her not to 1 MR. RHEINI-IART: Objection to the form. 2 answer, yes. 2 Standing objection as previousiy stated, and 3 BY MR. HOROWITZ: 3 compound and ambiguous and instruct the witness 4 Q. Ms. Keiien, did you know a giri named Jane 4 not to answer. 5 Doe No. 4 when she was a child? 5 THE WITNESS: On the instruction of my 6 A. On the instruction of my lawyer, i must invoke . 6 iawyer, i choose to invoke my Fifth Amendment 7 my Fifth Amendment right. 7 right. 8 Q. Did iane Doc No. 4 come to 8 BY MR. HOROWITZ: 9 Jeffrey Epstein?s Paim Beach home on multiple 9 Q. Prior to May of 2005, did you answer phone 3. 0 occasions between 2003 and 2885? calis at Jeffrey Epstein?s home from Jane Doe No. 4 1 MR. RHEINHART: Objection to the form, 1 1 during which you arranged for Jane Bee No. 4 to come 12 standing objection. Otherwise compound and 12 to Jeffrey Epstein's home? it 3 instruct the witness not to answer based on her 1 3 MR. RHEINHART: Objection to the form. 1 4 Fifth Amendment privilege. 1 4 Standing objection previous iy stated. It?s 1 5 THE WITNESS: On the instruction of my 15 compound, and instruct the witness not to 1 6 lawyer, i must choose to invoke my Fifth 1 6 answer. 3.7 Amendment right. - 1 7 THE WITNESS: At the instruction of my 1 8 BY MR. HOROWITZ: 1 8 iawyer, i must invoke my Fifth Amendment right. 1 9 Q. At any time prior to May of 2005 did 1 9 BY MR. HOROWITZ: 2 0 Jeffrey Epstein instruct you to with 2 Q. Prior to May of2005, did .ieffrey Epstein 2 i-Iaiey Robson by telephone to arrange for Jane Doe 2 observe you speaking with iane Doc Nocome to his home? 2 2 telephone after your making arrangements for Je? -- 2 3 MR. Standing objection to the 2 3 for Jane Doe No. 4 to come to his home? 2 4 form of the question. Otherwise ambiguous and 2 4 MR. RHEINHART: Objection to the form, 25 compound, and instruct the witness not to 2 5 standing objection, and instruct the witness 12 (Pages 231 to 234) (561) 832~7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 'i?k?i?ix?mrtm humans-sex As?i" W?i Page 235: Page 237 1 not to answer. 1 Standing objection and instruct the witness not 2 THE WITNESS: On the instruction of my 2 to answer. 3 lawyer, I must invoke rny Fifth Amendment right. 3 THE WITNESS: On the instruction of my 4 BY MR. HOROWITZ: 4i lawyer, i must invoke my Fifth Amendment right. 5 Q. Prior to May of 2805, did Jeffrey Epstein 5 BY MR. 6 instruct you to get Jane Doe No. 4?s telephone 6 Q. Did Jane Doe No. 4 tell you and 7 number so that you could communicate with her for 7 Jeffrey Epstein that she attended Royal Palm Beach 8 the purpose of scheduling future massages? 8 High School? 9 MR. RHEINHART: Objection to the form, 9 MR. Objection to the form, 1 0 standing objection, otherwise compound and 1 0 standing objection, instruct the witness not to 1 1 instruct the witness not to answer. 1 1 answer. 12 THE WITNESS: On the instruction of my 1 2 THE WITNESS: On the instruction of my 1 3 lawyer, I must invoice my Fifth Amendment 1 3 lawyer, i must invoke my Fifth Amendment right. 1 4 privilegeMR. HOROWITZ: 15 Q. Did Jane Doc No. 4 regularly discuss her 1 6 Q. Did you on multiple occasions tell Jeffrey 1 6 life at Royal Palm Beach High School with you in the 17 Epstein that you had con?rmed by telephone that 1 7 presence of Jeffrey Epstein? 18 Jane Doc No. 4 would be coming to his home for a m- 3. 8 MR. RHEINHART: Objection to form, 1 9 at a speci?c time to give him a massage? 1 9 standing objection as well as ambiguous as to 2 0 MR. Objection to the form. 2 0 what ?regularly? means. Instruct the witness 2 1 It?s compound and standing objection as well, 2 1 not to answer. 2 2 and instruct the witness not to answer. 2 2 THE WITNESS: On the instruction of my 2 3 THE WITNESS: On the instruction of my 23 lawyer, i must invoke my Fifth Amendment right. 2 4 lawyer, I must invoke my Fifth Amendment 2 4 BY MR. HOROWITZ: 2 5 privilege. 2 5 Q. Did Jane Doe No. 4 come to Jeffrey Page 236 Page 238 1 BY MR. 1 Epstein's Palm Beach home on dozens of occasions 2 Q. Did leffrey Epstein tell you it was his 2 between 2003 and May of 2885, to give him massages 3 intent during the course of Jane Doe No. 4?s visits 3 during which he engaged her in sexual activity? 4 to his home to induce her to engage in sexual 4 MR. Objection to the form, 5 activity? 5 standing objection. it?s also otherwise 6 MR. Objection to the form, 6 compound and instruct the witness not to '7 standing objection and instruct the witness not 7 answer. 8 to answer. 8 THE On the instruction of my 9 THE WITNESS: On the instruction of my 9 lawyer, I must invoke my Fifth Amendment right. 1 lawyer, I must invoke my Fifth Amendment right. 1 0 BY MR. HOROWETZ: 1 1 BY MR. HOROWITZ: 1 1 Q. Prior to May of 2005, did Jeffrey Epstein 12 Q. Did ieffrey Epstein tell you that, in 1 2 instruct you to communicate with Jane Doc No. 4, via 1 3 fact, during lane Doe No. 4 -- 4?s visits to his 13 telephone, to arrange for Jane Doe No. 4 to come to 1 4 home, he was able to induce her to engage in sexual 1 4 his Palm Beach home so he could engage .lane Doe 1 5 activity? 1 5 No. 4 in sexual activity? 1 6 MR. RHEINHART: Objection to the form, . 6 MR. RHEINHART: Objection to the form as 7 same objection as the previous questions. 1 7 stated in the previous question. Same 1 8 instruct the witness not to answer. - 8 instruction to the witness. 9 THE WITNESS: On the instruction of my 1 9 THE WITNESS: On the instruction of my 2 lawyer, i must invoke my Fifth Amendment right. 2 lawyer, I must invoke my Fifth Amendment right. 2 1 BY MR. BOROWITZDid both you and Eeffrey Epstein know that 2 2 Q. Did Jeffrey Epstein instruct you to tell 2 3 Jane Doc No. 4 was younger than 18 when she came to 2 3 Jane Doe No. 4 to lie to police investigators during 2 4 Jeffrey Epstein?s home in 2003 and 2004? 2 the course of their 2005 investigation? 2 5 MR. Objection to the form as .1 1'01 (561) EAR. RHBMART: Objection to the form. 832-7500 PROSE COURT REPORTING AGENCY, tom}; x?gte?gg?s?tc; seal. 93:: amateurs-issuers 2259.95 $93.93*: Hie: get: yer; gium'wm'mum 5';st messiaranawzz?s? $373 not raw 13 INC . (Pages 235 to 238) (561) 832?47506 "tim?rmhmamag?m ?Bevin. av a ?a our ?Mgrolih??muu - was: 3533a m?imm?w Page 239 Page 241- 3. stated to the last severai questions and 1 MR. RHEINHART: Objection to the form. 2 instruct the witness not to answer. 2 it?s a compound question and standing objection 3 THE WITNESS: On the instruction of my 3 as well. Instruct the witness not to answer. 4 iawyer, i must invoke my Fifth Amendment right. 4 THE On the instruction of my 5 BY MR. HOROWITZ: 5 lawyer, I must invoke my Fifth Amendment right. 6 Q. Did you, in fact, teli iane Doe No. 4 to 6 BY MR. HOROWITZ: 7 lie to police invest, investigators during the 7 Q. Did you inform ieffrey Epstein that you 8 course of their 2005 investigation of Jeffrey 8 had been provided Jane Doc No. 5's telephone number? 9 Epstein? 9 MR. RHEINHART: Same objection as the 1 0 MR. Object to the form because 3. 0 previous question, same instruction. 1 1 it presumes knowledge of Jane Doc No. 4. 3. 1 THE WITNESS: Upon instruction of my 1 2 instruct the witness not to answer. 12 iawyer, i must invoke my Fifth Amendment right. 13 THE WITNESS: Upon the instruction lawyer, i must invoke my Fifth Amendment right. 1 4 Q. Did Jeffrey Epstein instruct you to cail 15 BY MR. RHEINHART: 15 Jane Doc No. 5 to come to his home and give him a 6 Q. Okay. You?ve asserted a Fifth Amendment 1 6 message in either 2001 or 2002? 1 7 objection and privilege as to my questions about 3. 7 MR. Objection to the form, 1 8 Jane Doe No. 4, yourseif, and ieffrey Epstein. is i. 8 same objection as the previous questions and 1 9 there any reason in your mind why ajury should not 1 9 same instruction to the witness. 2 0 infer from your assertion of the priviiege that you 2 0 THE On the instruction of my 2 3. did, in fact, assist Mr. Epstein in committing 2 1 lawyer, I must invoke my Fifth Amendment right. 22 sexual abuse upon Jane Doe No. 4? 22 BY MR. HOROWITZ: 2 3 MR. i am going to instruct the 2 3 Q. Did Jeffrey Epstein inform you that the 2 4 witness not to answer the question for the 2 4 massage Jane Doe No. 5 was to give him would be 2 5 reasons 1 stated at the last client that we 2 5 sexual in nature? Page 240: Page 242 1 discussed. The questions are iegaily not 1 MR. RHEINHART: Same objection previously 2 proper in our view, and therefore the questions 2 stated, standing objection and instruct the 3 and answers should not be held against her 3 witness not to answer. 4 untii ajudgc ruies on the propriety of the 4 THE WITNESS: Upon the instruction of my 5 questions. And we can address that another 5 lawyer, i must invoke my Fifth Amendment right. 6 day. i?m instructing her not to answer. 6 BY MR. HOROWITZ: 7 BY MR. '7 Q. Did ieffrey Epstein observe you Speaking 8 Q. Okay. Ms. Keiien, do you know a girl 8 with Jane Doe bio. 5 on the teiephone to arrange for 9 named iane Doc No. 5 when she .was stili a chiid 9 Jane Dee No. 5 to come to his home for a massage? 1 0 under the age of 18? 1 0 MR. Same objection as previous 1 A. At the instruction my lawyer, i must invoke my 3. 1. questions and same, to the form of the 12 Fifth Amendment right. 3. 2 question, and same instruction. 1 3 Q. Did a child under the age of 18 named iane 1. 3 THE WITNESS: Upon the instruction come to ieffi?ey Epstein's Palm Beach home 1 4 lawyer, i must invoke my Fifth Amendment right. 1 5 in approximater 2001 or 2002? 1 5 BY MR. HOROWITZ: 1 6 MR. Objection to the form. 1 6 Q. Did you teil Jeffrey Epstein that you had 17 Instruct the witness not to answer. 17 confirmed by telephone that Jane Doc No. 5 wouid be 18 THE 0n the instruction of my 18 at his home at a specific time to give him a 1 9 lawyer, I must invoke my Fi?h Amendment right. 1 9 massage? 2 0 BY MR. HOROWIT Z: - 2 0 MR. Objection to the form and 2 1 Q. in 2001 or 2002 did you inform 2 1 instruct the witness not to answer. 2 2 ief?'ey Epstein that you received a telephone cail . 2 2 THE WITNESS: On the instruction of my 2 3 in which you were referred to an underage giri named 2 3 lawyer, i must invoke my Fifth Amendment right. 2 4 Jane Doc No. 5 who wouid be willing to come to his 2 4 BY MR. HOROWITZ: 2 6 (561) 832*7500 home to give him a massage for money? U1 "-an i . .. rm? yew-M Q. Did ieffrey Epstein teli you that PROSE COURT REPORTING AGENCY, stair: minaase?argeieteri rheumatism-{w sea rim-tarsus 14 (Pages 239 to 242) INC. (561) 83247506 Page 243 Page 245 1. his intent, during the course of Jane Doc No. 5's 1 Amendment objection or privilege as to my questions 2 visit to his home, to persnade her to engage in 2 about iane Doc No. 5. Is there any reason in your 3 sexual activity? 3 mind why ajury should not infer that the reason 4 MR. RHEINHART: Objection to the form, 4 you?re asserting the Fifth Amendment is because you 5 standing objection. instruct the witness not 5 and ieffrey Epstein committed a crime in inducing 6 to answer based on Fifth Amendment. 6 and enticing iane Doc No. 5 to come to his home for ?7 THE WITNESS: On the instruction of my ?7 sexual activity? 8 lawyer, i must invoke my Fifth Amendment right. 8 MR. RHEINHART: Once again, I instruct the 9 BY MR. HOROWITZ: 9 witness not to answer. Legal basis is the 1 0 Q. Did Jeffrey Epstein tell you that during 1 0 question is not reasonably caicuiated to lead 1 the course of Jane Doc No. 5?s visit to his home in 1 to admissible evidence. It's not otherwise 12 either 2001 or 2002 that he succeeded in persuading 1 2 proper discovery. And for the reasons I stated 1 3 her to engage in sexuai activity with him? 13 as to the prior witnesses, until the legality 1 4 MR. RHBINHART: Objection to the form, 1 4 and prepriety of the questions is ruled upon by 1 5 standing objection. Otherwise compound and 15 the court, there should be no inference drawn. 1 6 instruct the witness not to answer based Fifth Amendment. 1 7 Q. Ms. Keilen 1 8 THE WITNESS: On the instruction by my 1 8 MR. One second. Go ahead. 1 9 lawyer, i must invoke my Fi?h Amendment right. 1 9 i'm sorry. - 2 0 BY MR. HOROWITZ: 2 0 MR. HOROWITZ: You?re conferring about a 2 1 Q. Did Jeffrey Epstein instruct you to take 2 1 privilege I trust? 2 2 Jane Doc No. 5?s name and teiephone number down so 2 2 MR. Yes, priviiege issue. 2 3 that you and he could call Jane Doc No. 5 to come his home for more sexual activity? 2 4 Q. Ms. Kellen, do, did you know a girl named 2 5 MR. RHEINHART: Objection to the form. 2 5 lane Doc No. 6 when she was still a child under the Page 244' Page 246 1 instruct the witness not to answer. 1 age of 18? 2 THE WITNESS: On the instruction of my 2 A. At the advice of counsel, i must invoke my 3 lawyer, must invoke my Fifth Amendment right. 3 Fifth Amendment right. 4 BY MR. HOROWITZ: 4 Q. Ms. Kellen, did 3ane Doc No. 6 come to 5 Q. After iane Doc No. 5?s first visit, did 5 Jeffrey Epstein?s Palm Beach home in approximately 6 Jeffrey Epstein instruct you to call her on the 6 August of 2004 when she was still a child? 7 telephone to arrange for her to come back for more 7 MR. RHEENHART: Objection to the form, 8 sexual activity? 8 standing objection, and instruct the witness 9 MR. Objection to the form as 9 not to answer. 1 0 previously stated, and form, standing objection 1 0 THE WITNESS: On the instruction of 1 1 and instruct the witness not to answer. 1 1 counsel, I must invoke my Fifth Amendment 12 THE WITNESS: On the instruction of my 1 2 right. 1 3 lawyer, i must invoke my Fifth Amendment rightMR. HOROWITZ: 4 Q. Ms. Kellen, were you aware that Jane Doc 1 5 Q. Did you, in fact, call Jane Doe Nowas just 13 years old when she came to Jeffrey 1 6 the telephone to arrange for her to come back to 6 Epstein's home in August of 2004? 1 7 ieffrey Epstein?s home for more sexuai activity? 1 ?7 MR. RHEINHART: Objection to the form. It 1 8 MR. Same objection previously 8 assumes multiple facts. It's therefore 1 9 stated, and standing objection, and instruct 9 compound. Instruct the witness not to answer. 2 the witness not to answer and objection to 2 0 THE On the advice of counsel, 1 2 1 form. - 2 1 must invoke my Fifth Amendment right. 2 2 THE WITNESS: On the instruction of my 2 2 BY MR. HOROWITZ: 2 3 lawyer, i must invoke my Fifth Amendment right. 2 3 Q. in 2004 did you receive a phone call from giri named EW. wherein she stated she was 2 5 Q. Ms. Kellen, you have asserted a Fifth 3 2 5 bringing Jane Doc No. 6 to Jeffrey Epstein's home 15 (Pages 243 to 246) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 semi. rm in} names-m Immin?liimxh maximums m?mrnimaam - Page 247 Page 249; ms 35 .hmtim $5an an he. .umWWeMm-rr mudguam? Mm? Mr Ii'" imhaui?xmt?mu ==~mmsm=egzmw mam mer'vemm 3. for a massage? 1 THE WITNESS: On the instruction of my 2 MR. RHEINHART: Objection to the form. 2 lawyer, i must invoke my Fifth Amendment right. 3 Instruct the witness not to answer. 3 BY MR. HOROWITZ: 4 THE WITNESS: On the advice of counsel, I 4 Q. Did Jeffrey Epstein observe you speaking 5 must invoke my Fifth Amendment right. 5 with 3W. by telephone to arrange for Jane Doc No. 6 6 BY MR. HOROWITZ: 6 to come to his home for a massage? 7 Q. Did Jeffrey Epstein instruct you to 7 MR. Objection to the form, 8 communicate by telephone with 8W. for the purpose 8 standing objection and otherwise compound 9 of under arranging for underage minor girls to 9 instruct the witness not to answer. 3. 0 come to his home for a massage? 0 THE WITNESS: On the instruction of my 1 1 MR. Objection to the form. 1 iawyer, I must invoke my Fifth Amendment right. 12 It?s a compound question. Instruct the witness 2 BY MR. 13 not to answer. 3.3 Q. Did Jeffrey Epstein con?rm with you that 1 4 THE WITNESS: On the advice of counsel, 1 1 4 you had spoken with 3W. by telephone to confirm a 5 must invoice my Fifth Amendment right. 1 5 specific time that Jane Doe No. 6 would be at his 3. 6 BY MR. HOROWITZ: Ii. 6 home? 3.7 Q. Did you, in fact, communicate by telephone 1 7 MR. Objection to the form, 1 8 with EW. for the purpose of arranging for underage 8 standing objection. Instruct the witness not 3. 9 minor girls to come to Jeffrey Epsteinis home to 1 9 to answer. 2 0 give him a massage? 2 0 THE On the instruction of my 2 1 MR. RHEINHART: Same objection stated to 2 iawyer, I choose to invoke my Fifth Amendment 22 the previous question. Same instruction to the 2 2 right. 2 3 witnessTHE WITNESS: On the instruction of my 2 4 Q. Did Jeffrey Epstein tell you that it was 2 5 iawyer, I must invoke my Fifth Amendment right. 2 5 his intention during the course of Jane Doe No. 6's Page 238 Page 250 3. BY MR. i Visit to his home to persuade her to engage in 2 Q. in 2804 did ieffrey Epstein instruct you 2 sexu'ai?activity with him? 3 to communicate with EW. by telephone to arrange for 3 MR. RHEINHART: Objection to the form, 4 Jane Doe No. 6 to give him, to give him a massage 4 standing objection. instruct the witness not 5 for his own sexuai grati?cation? 5 to answer. 6 MR. RHEINHART: Objection to the form for 6 THE At the instruction of my 7 the same reasons stated to the previous 7 lawyer, I must choose to invoke my Fifth 8 questions and instruct the witness not to 8 Amendment right. 9 answer. 9 BY MR. HOROWITZ: 0 THE WITNESS: On the instruction of my 1 0 Q. Did ieffrey Epstein teii you that during 1 1 lawyer i must invoke my Fifth Amendment right. 1 the course of Jane Doe No. 63 visit to his home he 1 2 BY MR. HOROWITZ: 12 succeeded in persuading her to engage in sexuai 3. 3 Q. Did you, in fact, communicate with SW. by 3.3 activity with him? 1 4% telephone to arrange for Jane Doe No. 6 to come to 1 4 MR. Same objection as stated 1 5 Jeffrey Epstein?s home for his sexual gratification? 5 to the previous question to form. Instruct the 1 6 MR. RHEENHART: Objection to the form. 1 6 witness not to answer. 3.7 instruct the witness not to answer. 1 '7 THE WITNESS: On the instruction of my 1 8 THE On the instruction of my 8 lawyer, i must invoke my Fifth Amendment right. 1 9 iawyer, I must invoice my Fifth Amendment right. 1 9 BY MR. HOROWITZ: 2 0 BY MR. HOROWZTZ: 2 Q. Did Jeffrey Epstein instruct you to take 2 1 Q. Did 3effrey Epstein inform you that the 2 1 Jane Doe No. 6?s name and teiephone number to call 2 2 massage Jane Doe No. 6 was to give him would be 2 2 her to come to his home for more sexual activity 2 3 sexuai in nature? 2 3 with him? 2 4 MR. Objection to the form. 2 4 MR. RHEINHART: Objection to the form. 2 5 Instruct the witness not to answer. 2 5 Instruct the witness not to answer. 16 (Pages 247 to 250) (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (561) 832?7506 Page 251 Page 253 :12 been . 2m mitii'i?tms?" i??-iih 'i'a'tf. Tm 168?.- . kim- va-i . Muir?? 3. THE WITNESS: 0n the instruction of my 1 MR. Instruct the witness not 2 lawyer, I must invoke my Fifth Amendment right. 2 to answer the question for the legal reasons I 3 BY MR. HOROWITZ: 3 previously stated. Also the Fifth Amendment is 4. Q. Did you, in fact, take Jane Doc No. 6?s 4 designed to protect both the innocent and the 5 name and telephone number down so that you couid 5 guilty, and i would just assert the same things 6 call her to come to ieffrey Epstein?s home for more 6 1 previously said, that until a judge rules on 7 sexual activity? 7 the propriety of the questions, there should be 8 MR. RHEINHART: Objection to form. 8 no negative inference drawn from the answer. 9 instruct the witness not to answer. 9 BY MR. HOROWITZ: ?ii-[E WITNESS: At the instruction of my 1. Q. Ms. Kellen, are, are you asserting your 1 1 lawyer, I must invoke my Fifth Amendment right. 1 1 Fifth Amendment priviiege today because you're an 1 2 BY MR. HOROWITZ: 2 innocent person, or to conceal your criminal 3. 3 Q. Did Jeffrey Epstein instruct you to put 1 3 activity? 1 4 Jane Doc No. 6's name and teiephone number into a i 4 MR. RHEINHART: I am going to instruct her i 5 master journal or iog in which he archived the names 15 not to answer that question. That's not a 1 6 and contact information of teenage girls with whom 3. 6 proper question. She could invoke the Fifth 17 he had sexuai activity? 1 7 Amendment for any reason. She doesn't have to 8 MR. RHEINHART: Objection to the form. 1 8 explain why. if ajudge wants to ask her that, 1 9 instruct the witness not to answer. 1 9 she'll tell the judge. 2 0 THE. WITNESS: On the instruction of my 2 8 If you?re going to move to, if you?re 2 3. lawyer, i must invoke my Fifth Amendment right. . 2 i going to move to another person, could we maybe 2 2 BY MR. HOROWZTZ: 22 take a five-minute break? 2 3 Q. Did you, in fact, put Jane Doc No. 6?s 2 3 MR. HOROWITZ: Sure. 2 4 name and telephone number into a masterjournai or 2 4 MR. RHEINHART: before the next person, 2 5 log in which you and Jeffrey Epstein archived the 2 5 if you?re done Page 252 Page 254 1 names and contact information of teenage girls who 3. MR. We?ve got tots more girls. 2 wouid had sexuai activity with Jeffrey Epstein? 2 MR. RHEINHART: Okay. That's fine. But 3 MR. RHEINHART: Objection to the form. 3 now a good breaking point? 4 Standing objection. it?s compound. instruct 4 MR. HOROWITZ: Sure. 5 the witness not to answer. 5 MR. RHEINHART: Thanks. 6 THE WITNESS: At the instruction of my 6 THE We?re now off video 7 lawyer, i must invoke my Fifth Amendment right. 7 record. The time is 3: 14 pm. 8 BY MR. HOROWITZ: 8 (A brief recess was held.) 9 Q. Did Jeffrey Epstein instruct you to call 9 THE VIDEOGRAPI-ZER: We're now on the video 1 0 EW. on the teiephone to arrange for iane Doc No. 6 1 0 record. The time is 3:24 pm. 1 1 to come back and give him another massage for his 3. 1 MR. i?ve been told I can start 1 2 sexual pleasure? 2 my questions without Sack Goldberger in the 13 MR. RHEINHART: Objection to the form, I 1 3 room. 3.. 4 instruct the witness not to answer. 1 4 MR. REIEENHART: Absoiuteiy. 1 5 THE WITNESS: At the instruction of my 15 BY MR. HOROWITZ: i 6 lawyer, I must invoke my Fifth Amendment right. 1 6 Q. Ms. Kellen, did you know a, did you know a BY MR. HOROWITZ: 1 '7 giri named iane Doc No. 7 when she was still 1 8 Q. Ms. Kellen, you have asserted a Fifth 18 a chiid under the age of 18? 19 19 2 0 questions about Jane Doc No. 6 and Jeffrey Epstein. 2 0 my Fifth Amendment privilege. 2 3. Is there any reason in your mind why ajury shouid 2 1 Q. Ms. Keiien, did a girl named Liane Doe 2 2 not infer from your assertion of the privilege that, 2 2 No. 7 come to Eeffrey Epstein's Palm Beach home on 2 3 in fact, you and Jeffrey Epstein engaged in criminal 2 3 muitipie occasions between 2003 and May of 2005? 2 4 conduct in inducing her to come to his home for his 2 4 MR. RHEINHART: - Objection to the form. 2 5 sexual pleasure? 2 5 instruct, instruct the witness not to answer. 17 (Pages 251 to 254) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 ?bih?iietxh?iili?wu?; madame 8N: .AM ?cw-v a Hat??m i Page 255 Page 257 1 THE On the instruction of my 1 BY MR. 2 lawyer, I must invoke my Fifth Amendment 2 Q. Sure. At any time prior to May of 2005, 3 privilege. 3 did Jeffrey Epstein confirm with you that you had 4 BY MR. HOROWITZ: 4 spoken to Jane Doe No. 7 by teiephone and that Faith 5 Q. Prior to May of 2005, did you receive a 5 would be coming to his home at a particular time to 6 phone call from a girl named Haley Robson wherein 6 give him a massage? ?7 she told you she was bringing Jane Doe No. 7 to ?7 MR. RHEINHART: Object to form. 8 ieffrey Bpstein's home to give him a massage? 8 THE WITNESS: On the instruction of my 9 MR. Objection to the form. 9 lawyer, i must invoke my Fifth Amendment 1 0 THE WITNESS: At the instruction of my 1 0 privilege. 1 It. lawyer, I must invoke my Fifth Amendment 1 1 BY MR. HOROWITZ: 1 2 priviiege. 1. 2 Q. And did you, in fact, speak to Liane Doe 1 3 MR. We?re trying to speed 3. 3 No. 7 by telephone and confirm that Jane Doe No. 7 - 1 4 things along here. 1. 4. would be coming to Jeffrey Epstein?s home at a 1 5 MR. Fine. 1 6 particular time to give him a massage? 1 6 BY MR. HOROWITZ: 6 MR. RHEINHART: Object to the form. 1 '7 Q. At any time prior to 2005, did 1 7 THE WITNESS: On the instruction of my 1 8 Jeffrey Epstein instruct you to communicate with 8 iawyer, I must invoke Iny Fifth Amendment 1 9 Haley Robson by telephone to arrange for Jane Doe 1 9 privilege. 2 0 No. 7 to give him a massage? 20 BY MR. 2 1 MR. RHEINHART: Objection to the form. 2 1 Q. Did Jeffrey Epstein tell you it was his 2 2 THE WITNESS: At the instruction of my 2 2 intention during the course of Jane Doc No. 7?s 2 3 lawyer, i must invoke my Fifth Amendment . 2 3 visits to his home to persuade or entice her to 2 4 privilege. 2 4 engage in sexual activity? 2 5 2 5 MR. RHEINEART: Obiect to form. Page 256 Rage 258 1 BY MR. HOROWITZ: 1 THE WITNESS: At the instruction of my 2 Q. Did Jeffrey Epstein inform you that the 2 lawyer i must invoke my Fifth Amendment 3 massage .iane Doe No. 7 was to give him would be 3 privilege. 4 sexuai in nature? 4 BY MR. HOROWITZ: 5 MR. RHEINHART: Objection to the form. 5 Q. Did Jeffrey Epstein ever tell you that 6 THE WITNESS: At the instruction of my 6 during the course of Jane Doe No. 7's visits to his 7 lawyer, i must invoke my Fifth Amendment 7 home that he succeeded in persuading her or enticing 8 privilege. 8 her to engage in sexuai activity? 9 BY MR. 9 MR. RHEINHART: Object to form. 3. Q. Did .ieffrey Epstein observe you speaking 1 0 THE WETNESS: At the instruction of my 1 1 with i-iaiey Robson by telephone to arrange for iane 1 1 lawyer I must invoke my Fifth Amendment 3. 2 Dee No. 7 to come to his home to give him a. massage 12 privilege. 3 that was sexual in nature? 13 BY MR. HOROWETZ: 1 4 MR. Objection to the form. 1 4 Q. Ms. Kellen, did you ask Jane Doe Nothe instruction of my 1 5 old she was when she came to Jeffrey Epstein's home? 1 6 lawyer, I must invoke my Fifth Amendment 1 6 MR. RHEENHART: Objection to form. 1 7 privilege. 1 7 THE WITNESS: At the instruction iawyer, I must invoke my Fifth Amendment 1 9 Q. At any time prior to May of 2005, did 1 9 privilege. 2 0 Jeffrey Epstein con?rm with you that she (sic) had 2 0 BY MR. HOROWZTZ: 2 1 spoken to Jane Doe No. 7 by telephone and that Jane 2 1 Q. And Jane Doc No. 7 never told you that she 2 2 Dee No. 7 would be coming to his home to give him a 2 2 was i8 or older; is that correct? 2 3 massage? 2 3 MR. Objection to form. 2 4 MR. i'm sorrythe instruction of my 2 5 restate your question, Mr. Horowitz? 2 5 iawyer, I must invoke my Fifth Amendment 18 (Pages 255 to 258) 832-37500 PROBE COURT AGENCY, INC. (561) 832*7506 Page 259 Page 263. privilege. 1 MR. RHEINHART: Object to form. 2 BY MR. HOROWETZ: 2 THE WITNESS: At the instruction of my 3 Q. And when Jane Doe No. 7 came to leffrey 3 lawyer must invoke my-Fifth Amendment 4 Epstein?s home, she appearedto you to look younger 4 privilege. 5 than 18, correct? 5 BY MR. HOROWITZ: 6 MR. RHElNlTER?iT-iiObject to form. 6 Q. Did Jeffrey Epstein instruct you to call 7 THE WITNESS: At the instruction of my 7 Jane Doe No. 7 to tell her to lie to police of?cers 8 lawyer I must invoke my Fifth Amendment 8 investigating his criminal activity? 9 privilege. 9 MR. RHEINHART: Object to form. 1 0 BY MR. HOROWITZ: 0 THE WITNESS: On the instruction of my 1 1 Q. Did Earle Doc No. 7 tell you that she was a 3. lawyer, i must invoke my Fifth Amendment 1 2 student at Royal Palm Beach High School? 1 2 privilege. 3 MR. Object to form. 1 3 BY MR. HOROWITZ: 14 THE WITNESS: At the instruction of my 1 4 Q. Did you, in fact, call lane Doc No. 7 to 5 lawyer, i must invoke my Fifth Amendment 1 5 tell her to lie to police of?cers investigating 6 privilege. 1 6 Jeffrey Epstein?s criminal activity? 1 7 BY MR. HOROWITZ: 1 7 MR. Object to form. 1 8 Q. Did Jeffrey Epstein instruct you to take 1 8 THE WITNESS: At the instruction of my 1 9 Jane Doe No. 7?s name and telephone number down so 1 9 lawyer, I must invoke my Fifth Amendment 2 8 you can call Jane Doe No. 7 to come to his home for 2 privilege. 2 1 more sexual activity? 2 1 BY MR. HOROWITZ: 22 MR. RHEINHART: Object to form. 2 2 Q. Okay. You?ve asserted a Fifth Amendment 2 3 THE WITNESS: On the instruction of my 2 3 objection or privilege as to all of my questions 2 4 lawyer, I must invoke my Fifth Amendment 2 4 concerning Jane Doc No. 7 and her visits to Jeffrey 2 5 privilege. 2 Epstein. is there any reason that you can think of 5 Page 260 Page 262 1 BY MR. HOROWITZ: 1 that ajury should not infer that you are asserting 2 Q. Did you, in fact, take Jane Doc No. 7's 2 the Fifth Amendment privilege to conceal the 3 name and telephone number down so you could call 3 criminal activity of yourself and .ieffrey Epstein? 4 Jane Doe No. 7 to come to ieffrey Epstein?s home for 4 MR. RHEINHART: As previously done, I will 5 other sexual activity? I 5 instruct the witness not to answer that 6 MR. RHEINHART: Object to form. 6 question. I believe it calls for a legal 7 THE WITNESS: On the instruction of my 7 conclusion. it?s also not designed to lead to 8 lawyer, I must invoke my Fifth Amendment 8 discoverable evidence, and whether or not any 9 privilege. 9 inference should be drawn will be an issue for 3. 0 BY MR. HOROWITZ: it 0 the jury after the judge rules on the 3. 3. Q. Did Jeffrey Epstein instruct you to put 2 objections to the questions. 3.2 Jane Doc No. 7?s name and telephone number into a 12 MR. HOROWITZ: So, did you say you were 3. 3 master journal or log in which you and he archived 13 MR. RHEINHART: I?rn instructing her not to 1 4 the names of, and telephone numbers of teenage girls 1 4 answer. 3. 5 with whom he wanted to engage in sexual activity? 5 MR. HOROWITZ: Thank you. it 6 MR. RHEINHART: Object to form. 6 BY MR. HOROWITZ: 7 THE. At the instruction of my 17 Q. Ms. Kellen, did you know a girl named lane 1 8 lawyer, i must invoke my Fifth Amendment 1 8 Doc No. 8 when she was still a child under the age 1 9 privilegeMR. HOROWZTZ: 2 A. Upon the instruction of my lawyer, I must 2 3. Q. Did you, in fact, pat Jane Doc No. 7's 2 1 invoke my Fifth Amendment right. 22 name and telephone number into a master journal or 2 2 Q. Ms. Kellen, isn?t it true that a girl 2 3 log in which you archived the names of teenage girls 2 3 named Jane Doc No. 8 came to Jeffrey Epstein's Palm 2 4 with whom .ieffrey Epstein did engage in sexual 2 4 Beach home in approximately 2001 or 2002 when she 2 5 2 5 5333:2133: (561) activity? '2 ?reminiscent832-7500 PROSE COURT REPORTING AGENCY, INC. was still a child under the age of 18? (Pages 259 to 262) (561) 832*7506 may . . :5 Hi smut/razors?. WW .1 Page 263 Page 265 1 MR. Object to form. 1 BY MR. HOROWITZ: 2 THE WITNESS: On the instruction of my 2 Q. Did you tell Jeffrey Epstein that you had 3 lawyer, i must invoke my ifth Amendment right. 3 con?rmed by telephone that Sane Doe No. 8 would, in 4 BY MR. HOROWITZ: 4 fact, be coming to his home at a particular time to 5 Q. Ms. Kellen, did you receive a phone call 5 give him a massage? 6 from a girl named Carolyn Andriano that she was 6 MR. Object to form. 7 bringing Jane Doe No. 8 to Jeffrey Einstein's home 7 THE WITNESS: On the instruction of my 8 for the purpose of giving him a massage? 8 lawyer, I must invoke my Fifth Amendment right. 9 MR. RHEINHART: Object to form. 9 BY MR. HOROWITZ: 1 0 THE On the instruction of my 1 0 Q. Did Jeffrey Epstein tell you that it was 1 1 lawyer, I must invoke my Fifth Amendment right. 1 1 his intention that, during the course of Jane Doe 1 2 BY MR. HOROWITZ: 12 No. 83 visit to his home, that he would persuade or 13 Q. Did Jeffrey Epstein instruct you to 3 induce her to engage in sexual activity with him? 1 4 communicate by telephone with Carolyn Andriano to 1 4 MR. RHEINHART: Object to form. 1 5 arrange for Carolyn to bring underage girls to his 1 5 THE WITNESS: Upon the instruction of my 1 6 home for sexual activity? 1 6 lawyer, i must invoke my Fifth Amendment right. 17 MR. Object to formTHE WITNESS: On the instruction of my 1 8 Q. Did Jeffrey Epstein tell you that, in 1 9 lawyer, i must invoke my Fifth Amendment right. 1 9 fact, during the course of .iane Doe No. 8's visit to 2 0 BY MR. HOROWETZ: 2 0 his home, he succeeded in persuading or inducing her 2 1 Q. Did Jeffrey Epstein pay Carolyn Andriano 2 1 to engage in sexual activity? 2 2 to bring underage girls to his home for sexual 2 2 MR. Object to the form. 2 3 activity? 2 3 THE WITNESS: Upon instruction of my 2 4 MR. RHEIN Object to form. 2 4 lawyer, i must invoke my Fifth Amendment 2 5 WITNESS: On the instruction of my 2 5 privilege. Page 264 Page 266 1 lawyer, I must invoke my Fifth Amendment right. 1 BY MR. HOROWETZ: 2 BY MR. HOROWZTZ: 2 Q. .iane Doe No. 8 never told you that she was 3 Q. Did Jeffrey Epstein instruct you to 3 18 years old or older; is that correct? 4 communicate with Carolyn Andriano by telephone to 4 MR. RHEINHART: Object to form. 5 arrange for Jane Doe No. 8 to give him a massage 5 THE WETNESS: Upon the instruction of my 6 that was to be sexual in nature? 6 lawyer, I must invoke my Fifth Amendment right. 7 MR. RHEINHART: Object to form. 7 BY MR. HOROWITZ: 8 THE WITNESS: On the instruction of my 8 Q. And when you saw Eane Doe No. 8, she 9 lawyer, i must invoke my Fifth Amendment right. 9 appeared to you to be less than 18; is that correct? 1 0 BY MR. HOROWITZ: 1 0 MR. RHEINHART: Object to the form. 1 1 Q. Did Je?iey Epstein inform you that the 1 1 THE WITNESS: On the instruction of my 1 2 massage that Jane Doe No. 8 was to give him would be 1 2 lawyer, i must invoke my Fifth Amendment right. 1 3 sexual in nature? 1 3 BY MR. HOROWITZ: 3. 4 MR. RHEINHART: Object to form. 1 4 Q. Did Jeffrey Epstein instruct you to call 15 THE WITNESS: On the instruction of my 1 5 Carolyn Andriano on the telephone to arrange for 1 6 lawyer, i must invoke my Fifth Amendment right. 1 6 lane Doe No. 8 to come back and give him another 1 7 BY MR. HOROWITZ: 1 7 massage that was to be sexual in nature? 1 8 Q. Did leftiey Epstein observe you speaking 1 8 MR. RHEINHART: Objection to the form. 1 9 with Carolyn Andriano by telephone making 1 9 THE On the instruction of my 2 0 arrangements for lane Doe No. 8 to come to his home 2 0 lawyer, i must invoke my Fifth Amendment right. 2 1 to give him a massageMR. RBEINHART: Object to form. 2 2 Q. Ms. Kellen, you have asserted a Fifth 2 3 THE WITNESS: On the instruction of my 2 3 Amendment objection or privilege lawyer, i must invoice my Fifth Amendment right. 2 4 questions about Jane Doc No. 8. is there any reason 2 5 2 5 in your mind why ajury should not infer that, in 20 (Pages 263 to 266) (561) 832~7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Mb.- ?waxwu. rcmx-mm? - ?av-mas; emanate-?Zara ?chitin:- 5'vfx?rk Ml?ivii- amwmarmrmamwam - '3 WM - - Mam mi.qu Page 267 Page 269 1 fact, you and Jeffrey Epstein engaged in criminal 1 MR. Same instruction. 2 activity as it relates to Jane Doe No. 8? 2 THE WITNESS: Upon the instruction of my 3 MR. RHEINHART: instruct the witness not 3 lawyer, i must invoke my Fifth Amendment right. 4 to answer the question. 4 BY MR. 5 MR. HOROWITZ: you have the premarked 5 Q. And did you place at least some of the 6 Exhibit 5, by any chance? 6 calls re?ected on that phone bill with an 7 MR. I gave it back to 7 toward arranging for minor children under the age of 8 Mr. Kuvin. 8 18 to come to Jeffrey Bpstein?s home for his sexual 9 MR. I?ll hand it back to you. 9 pleasure? 0 Sorry. 1 0 MR. Object to the form as 1 3. BY MR. HOROWITZ: i. 1 compound and a standing objection, and also 12 Q. Let me ask Ms. Kellen to take a look at 3.2 instruct the witness not to answer based on 1 3 what?s been premarked as Exhibit 5. i. 3 Fifth Amendment. 14 MR. RHEINHART: {Do you want us to look at 3.4 THE WITNESS: Upon the instruction of my 3.5 the whole thing? i 5 lawyer, i must invoke my Fifth Amendment right. 3. 6 MR. Well, if we?re going to l. 6 BY MR. HOROWZTZ: 17 take more than a yeah, we can go off record 1 7 Q. And with reSpect to the phone calls 1 8 if she's going to look at the whole thing. 1 8 re?ected on the bill which you received, did you 3. 9 MR. RHEENHART: if you want to ask her 1 9 answer some of those phone calls with an toward 2 0 about every page, we?ll look at every page. 2 0 arranging for procuring underage girls to come to 2 1 But if you want to just ask some general 2 3. Jeffrey Epstein?s home for his sexual pleasure? 2 2 questions, perhaps then we can just -- - 22 MR. RHEINHART: Object to the, object to 2 3 MR. HOROWITZ: Well, if you know that 2 3 the form. instruct the witness not to answer, 2 4 you're going to assert the Fifth Amendment 2 4 based on Fifth Amendment privilege. 2 5 MR. RHEINHART: I doubt we're answering 2 5 THE WITNESS: Upon the instruction of my Page 268 Page 270 3. any questions about it, but go on ahead. And 1 lawyer, I must invoke my Fifth Amendment right. 2 if we need to take a break, we?ll take a break. 2 BY MR. 3 BY MR. HOROWITZ: 3 Q. Do, does the phone, does the premarked 4 Q. Okay. Have you had enough of a look at 4 Exhibit 5 re?ect phone calls wherein you arranged 5 those records to determine whether those are the 5 for Jeffrey Epstein to meet children under the age 6 telephone records for the cellphone that you used 6 of 18 for his sexual pleasure? ?7 during the time periods set forth on those phone ?7 MR. Objection to the form. 8 bills? 8 it's a compound question, instruct the witness 9 MR. Instruct the witness not 9 not to answer based on the Fifth Amendment. 1 to answer the question based on the Fifth 1 0 THE WITNESS: Upon the instruction of my 1 1 Amendment. 3. lawyer, I must invoke my Fifth Amendment right. 12 THE WITNESS: Upon the instruction of my 3.2 BY MR. HOROWITZ: 3 lawyer, I must invoke my Fifth Amendment right. 3.3 Q. Would it be accurate to describe .leffrey 1 4 BY MR. 3. 4 Epstein?s home between the years 2001 and 2006 as a 5 Q. Are the phone calls that the telephone 1 5 house of horrors? 6 bills reflect as having been made phone calls that 3. 6 MR. Object to the form of the '7 were placed by you? 17 question. instruct the witness not to answer. 18 MR. RHEINHART: Same instructionlawyer, i must invoke my Fifth Amendment right. 2 0 was committed at effrey Epstein's home every day 2 it BY MR. HOROWITZ: 2 1 that he was in Palm Beach County between the years 2 2 Q. Okay. Are the phone calls that the phone 2 2 2001 and 2006? 2 3 bill re?ects as having been received on that 2 3 MR. Object to the form. it 2 4 telephone line phone calls that you, in fact, 2 4 assumes she knows anything about Eeffrey 2 5 received? 2 Epstein or his home or when he is in Palm Beach 21 (Pages 267 to 270) (561) 832~7500 (561) 832*7506 PROSE COURT REPORTING AGENCY, INC. .tt th 65%; newewmwn mwwacwm i unaman "3:366:th he}! Lelime ?Emanumww -.. saw ?name. mil amusements-me mes-a . agent a: Page 271 Page 273 1 County, so instruct her not to answer the 1 compound and assumes facts not within the 2 question. 2 knowledge of this witness. instruct the 3 THE WITNESS: Upon the instruction of my 3 witness not to answer based on the Fifth 4 lawyer, I choose to assert my Fifth Amendment 4 Amendment. 5 right. 5 THE WITNESS: Upon the instruction of my 6 MR. No other questions. 6 lawyer, i must invoice my Fifth Amendment right. 7 MR. RHEINHART: Thank you. Who is next '7 BY MR. WEISSING: 8 up? 8 Q. Beginning in August of 2002, are you aware 9 MR. KUVIN: Next? Do you want to go next? 9 that 8W. was coerced by Jeffrey Epstein into sexual 1 0 MS. BZELL: Do you have a triai date? You 1 0 conduct? 1 1 may want to go because you have a triai date. 1 3. MR. RHEINHART: Objection to form, 3.2 MR. Ido. 12 ieading. Weii, it?s compound. instruct the 3 MR. Yeah, you do. Whenever you?re 13 witness not to answer based on the Fifth 4 ready. Go ahead. After you. 1 4 Amendment. ri?he question is aiso ambiguous as 15 MR. RHEINHART: Whenever you're ready. is 5 to coercion. 1 6 our videographer ready. 1 6 THE WITNESS: Upon the instruction of my 1 7 THE Oh, yeah. We?re all 1. 7 lawyer, i must assert my Fifth Amendment right. 18 good. 1 8 MR. WEISSING: Are you aware that between i it 9 MR. RHBINHART: We're good? 1 9 August 2002 and September of 2005, RW. had 2 0 THE VIDEOGRAPHBR: We never went off the 2 0 sexual conduct with Jeffrey Epstein? 2 1 record. 2 1 MR. Object to the form, 2 2 CROSS (SARAH KELLEN) 2 2 standing objection. Instruct the witness not answer. 2 4 Q. Ms. Kellen, Matt Weissing herethe instruction of my 2 5 know 2 5 lawyer, I must invoke my Fifth Amendment right. Page 272. Page 274 1 MR. RHEINHART: Instruct the witness not 3. BY MR. WEISSING: 2 to answer the question based on Fifth 2 Q. Okay. Are you aware that between August 3 Amendment. 3 2002 and September of 2005, Jef??ey Epstein engaged 4 THE WITNESS: On the instruction of my 4 in fondiing and inappropriate sexual 5 iawyer, I must invoke my Fifth Amendment right. 5 touching of 6 BY MR. 6 MR. Objection to the form, 7 Q. Have you ever met 7 standing objection and ambiguous as to 8 MR. RHEZNHART: Object to the form. I 8 tenninoiogy. instruct the witness not to 9 believe that?s been asked and answered several 9 answer. 1 0 times. Weii, not answered several times. But 10 THE WITNESS: Upon the instruction of my 1 3. Fit instruct her once again not to answer the iawyer, i must invoke my Fifth Amendment right. 1 2 question. 3.2 BY MR. WEISSING: 3 BY MR. WEISSING: 13 Q. Are you aware that during that same 3. 1i Q. Are you aware that E.W. was 14 years of 4 period, that ieffrey Epstein engaged in orai sex or i. 5 age when she first came to Jeffrey Epstein?s mansion 5 other sexuai misconduct with 1 6 in 2002? 1 6 MR. RHEINHART: Same objection as the 7 MR. RHEINHART: Object to the form. 17 previous question and same instruction to the 1 8 instruct the witness not to answer. i 8 witness. 1 9 ?i?i-IE WITNESS: On the instruction of my 3. 9 THE On the instruction of my 2 lawyer, i must invoke my Fifth Amendment right. 2 lawyer, I must invoke my Fifth Amendment right. 2 1 BY MR. WEISSINGAre you aware that at ail times that 22 Q. Are you aware that in that same time 2 3 from 2002 to 2005, when E.W. came to his mansion, 2 3 period that jeffrey Epstein masturbated minor child? . 2 4 presence of 2 5 MR. RHEINHART: Object to the form. its 2 5 MR. RHEINHART: Objection to the form, 22 (Pages 271 to 274) (561) 832-4500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 5: Xanail's?fx Iii/ii?: kh- r: ??i?h?i??hi?'mmwm ti?ivk?iu-Sii: ?t?ar use ran; i3?. Page 215 Page 1 standing objection and instruct the witness not 1 answer as well as compound. 2 to answer. 2 THE At the instruction of my 3 THE WITNESS: Upon the instruction of my 3 iawyer, i must invoke my Fifth Amendment right. 4 iawyer, i must invoke my Fifth Amendment rightall times that BW. was engaged with 6 Q. Are you aware that for all of her 6 the behaviors with Jeffrey Epstein, did he know that 7 behaviors with ieffrey Epstein that E.W. was paid by 7 she was a minor child? 8 him? 8 MR. Objection to the form, 9 MR. Objection to the form, 9 calls for Speculations as to Mr. Epstein's 1 0 leading, as weli as the standing objection, and mindset, also assumes she knows Mr. Epstein, so 1 instruct the witness not to answer. 1 1 i would object as compound and instruct her not 1 2 THE Upon the instruction of my 1 2 to answer. 1 3 lawyer, I must invoke my Fifth Amendment right. 1 3 THE At the instruction iawyer, I must invoke my Fifth Amendment righther work for 15 BY MR. 1 6 Jeffrey Epstein? 1 6 Q. At all times during her interaction with 1 7 MR. Objection to the form. 17 ieffrey Epstein, did Jeffrey Epstein tell you that 1 8 Instruct the witness not to answer. 1 8 he knew that BW. was a minor child? 1 9 THE WITNESS: On the instruction of my 1 9 MR. RHBINHART: Objection to form. 2 0 lawyer, I must invoke my Fifth Amendment right. 2 0 THE WITNESS: At the instruction of my 2 1 BY MR. WEISSING: 2 1 lawyer, i must invoke my Fifth Amendment right. 2 2 Q. Are you aware that Jeffrey Epstein, during 2 2 BY MR. WEISSING: 2 3 the period of August 2nd -- 2002 and September of 2 3 Q. {)id Jeffrey Epstein tell you that he 2 4 2085 committed numerous criminal and sexuai offenses 2 4 engaged in numerous sexual activities with EW. 2 5 against a minor child? 2 5 between the periods of August 2nd and September Page 276 3 Page 278 1 MR. Objection to the form. 1 August 2002 and September 2005? 2 Calls for a legal conclusion. it?s compound 2 MR. RHEINHART: Objection to the form. 3 and ambiguous and instruct the witness not to 3 THE At the instruction of my 4 answer. 4 lawyer, I must invoke my Fifth Amendment right. 5 THE WITNESS: Upon the instruction of my 5 BY MR. WEISSING: 6 iawyer, I must invoke my Fifth Amendment right. 6 Q. Did Jeffrey Epstein tell you that he had 7 BY MR. WEISSENG: '7 sexually exploited E.W. and contributed to her 8 Q. Are you aware that due to the in?uence of 8 deiinquency? 9 Jeffrey Epstein?s interaction with E.W., that it led 9 MR. RHEENHART: Objection to form. it's 1 0 her to a delinquent lifestyle? 1 ambiguous, calls for legai conclusions, and 1 MR. RHBINHART: Objection to the form, 1 1 it?s compound. Instruct the witness not to 1 2 ieading. Requires speculation, is ambiguous 12 answer based on Fifth Amendment priviiege. 3 and compound, and instruct the witness not to 13 HE WETNESS: On the instruction of my 1 4 answer. 1 4 lawyer, I must assert my Fifth Amendment right. 15 'fl-iE WITNESS: On the instruction of my 15 BY MR. WEISSING: 6 lawyer, i must invoke my Fifth Amendment right. 1 6 Q. Did Seffrey Epstein ever tell you that he 17 BY MR 5 17 intentionally was harming 8 Q. At all times when BW. was engaged with 8 MR. RHEINHART: Objection to the form. it 9 Jeffrey Epstein, he knew that she was a minor child. 1 9 assumes knowledge ofieffrey Epstein. Instruct 2 0 MR. is that a question answer. 2 1 statement? 2 1 THE WITNESS: On the instruction of my 2 2 BY MR. WEISS 2 2 lawyer, I must exert my Fifth Amendment right. 2 3 Q. Correct? 2 3 BY MR. WEISSING: 2 4 MR. Objection to the form, 2 4 Q. Did you know that leffrey Epsteinis 2 5 leading. I?ll instruct the witness not to 2 5 behavior was causing inj pain and suffering, and 23 (Pages 275 to 278) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Page 279 Page 281% emotional trauma to 1 ambiguous as to "school children.? Instruct 2 MR. Objection to the form, 2 the witness not to answer. 3 calls for speculation and is otherwise a 3 THE WITNESS: At the instruction of my 4 standing objection. 4 lawyer, I must invoke my Fifth Amendment right. it 5 THE WITNESS: At the instruction of my 5 BY MR. WEISSING: 6 lawyer, I must invoke my Fifth Amendment right. 6 Q. With regard to the young girls who you 7 BY MR. ?7 contacted to set up sexual encounters with 8 Q. Were you aware that Jeffrey Epstein was 8 Jeffrey Epstein, were they between the ages, school 9 using his wealth and the proximity of his mansion to - 9 girls between the ages of 13 and 17 years of age? 1 0 lead young underage girls into having sexual 1 0 MR. RHEINHART: Objection to the form. 1 1 behaviors with him? 1 3. it?s compound and instruct the witness not to 12 MR. RHEINHART: Objection to form, 12 answer. 3 standing objection and ambiguous. 3 THE. WITNESS: Upon the instruction of my 1 4 THE WITNESS: At the instruction of my 4 lawyer, i must invoke my Fifth Amendment right. 1 5 lawyer i must invoke my Fifth Amendment right. 5 BY MR. WEISSINGNow, do you believe that ieffrey Epstein 17 Q. Were you charged with scheduling girls to 7 presents a clear danger to female children in this 1 8 meet with Jeffrey Epstein? 1 8 community? 1 9 MR. Objection to form, 1 9 MR. RHEINHART: Objection to form, 2 standing objection. 2 8 standing objection. 2 1 THE WITNESS: At the instruction of my 2 1 THE WITNESS: On the instruction of my 2 2 lawyer, I must invoke my Fifth Amendment right. 2 2 lawyer, I must invoke my Fifth Amendment right. 23 BY MR. WEISSING: . 2 3 BY MR. WEISSING: 2 4 Q. in scheduling girls to meet with . 2 4 Q. Did Eeffrey Epstein tell you that he was 2 5 Jeffrey Epstein, did you ever call any escort 2 5 intentionally engaging in sexual misconduct with Page 280 Page 282 1 services? 3. KW. in an effort to hurt her? 2 MR. RHEINHART: Objection to form, 2 MR. RHEINHART: Objection to the form, 3 standing objection. 3 standing objection and also ambiguous. 4 THE WITNESS: At the instruction of my 4 THE WITNESS: On the instruction of my 5 lawyer i must invoke my Fifth Amendment right. 5 lawyer, I must invoke my Filth Amendment right. 6 BY MR. WEIssmo: 6 BY MR. WEISSING: 7 Q. in scheduling sexual encounters for 7 Q. Did Jeffrey Epstein tell you that he knew 8 Jeffrey Epstein, did you ever contact any, any known 8 that his sexual behavior with EW. was, in fact, 9 prostitutes? 9 injuring her? 1 0 MR. REEINHART: Objection to form. 1 0 MR. Objection to form. 1 1 THE WITNESS: At the instruction of my 1 "fl-1E WITNESS: At the instruction 1 must 1 2 lawyer, I must invoke my Fifth Amendment right. 12 invoice my Fifth Amendment rightMR. WEESSING: 1 4 Q. With regard to the girls who were 1 4 Q. Were you aware that Jeffrey Epstein 3.5 scheduled, these were basically school children, i 15 touched 33W. with ?u in her, in the intimate areas 16 conect? 16 ofherbody? 1 7 MR. RHEINHART: Objection to form, 1 7 MR. RHEINHART: Objection to the form, 1 8 leading, and also a standing objection. 8 both compound, standing objection and 9 THE WITNESS: At the instruction of my 1 9 ambiguous. 2 lawyer, i must invoke my Filth Amendment right. i 2 0 THE WITNESS: On the instruction of my 2 1 BY MR. WEISSING: 2 1 lawyer, I must invoke my Fifth Amendment right. 2 2 Q. Were the girls who you contacted on behalf 2 2 BY MR. WEISSEJG: 2 3 of Jeffrey Epstein, school children in this 2 3 Q. Are you aware that Jeffrey Epstein 2 4 community? I 2 4 penetrated vagina? 2 MR. Ob'ecti to form and 2 5 MR. RHEINHART: Objection to the form, purses. itamt'imtitski?zius?zei? ?833- 24 (Pages 279 to 282) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-4506 Page 283 Page 285 we .9 21. standing objection. 1 MR. Objection to the form in ii 2 THE WITNESS: At the instruction of my 2 that assumes knowledge of ieffrey Epstein or 3 lawyer, I must invoice my Fifth Amendment right. 3 where his mansion is or what goes mansion, so instruct her not to answer it. 5 5 6 BW. in the intimate portions of her body on dozens 6 lawyer, I must invoke my Fifth Amendment right. 7 of occasions between August 2002 and September of 7 BY MR. 8 2005? 8 Q. Between August 2002 and September of 2005, 9 MR. Objection to the form, 9 did Jeffrey Epstein coerce or engage EM. in sexual 1 0 standing objection. 0 activity at his mansion? 1 1 THE WITNESS: At the instruction of my 1 1 MR. RHBINHART: Objection to form and 12 lawyer, I must invoke my Fi?h Amendment right. 12 ambiguous as to "coercion." 13 BY MR. waissmo: 3. 3 rue WITNESS: On the instruction of my 4 Q. Did Jeffrey Epstein teil you that he had 3. 4 lawyer, I must invoke my Fifth Amendment right. 3. 5 touched EW. in the intimate portions of her body 1 5 BY MR. 1 6 and penetrated her body with a design to injure her 1 6 Q. Between August 2002 and September 2005, 17 between August 2002 and September of 2005? 17 did Jeffrey Epstein engage in sexual misconduct with 1 8 MR. RHEINHART: Objection to the form as 18 . 9 compound and instruct the witness not to 9 MR. RHEINHART: Objection to the form and 2 0 answer. 2 0 ambiguous as to "sexual misconduct. 2 1 WITNESS: On the instruction of my 2 1 THE WITNESS: At the instruction of my 2 2 lawyer, i must invoke my Fifth Amendment right. 2 2 lawyer, i must invoke my Fifth Amendment right. 23 BY MR. 23 BY MR. WEISSING: 2 4 Q. Do you know who L.M. is? 2 4 Q. Between August 2002 and September of 2005, 2 5 MR. RHEINHART: Instruct the witness not 2 5 did ieffrey Epstein engage in conduct with LM. for Page 288 Page 286% to answer based on the Fifth Amendment. 1 his sexual grati?cation? 2 THE WITNESS: On the instruction of my 2 MR. RHEINHART: Objection to form. 3 iawyer, i must invoke my Fifth Amendment right. 3 TEE WZTNESS: At the instruction of my 4 BY MR. WEISSIN G: 4 iawyer I must invoke my Fifth Amendment right. 6 Q. Were you aware when BM. first came to 5 BY MR. WEISSING: 6 Jeffrey Epstein?s mansion in 2002 that she was a, 6 Q. Were you aware that between August 2002 7 she was a 14?year-old child? 7 and September of 2005, Jeffrey Epstein engaged in 8 MR. RHEINHART: Objection to the form, 8 sexual, engaged in behavior with L.M. for his sexual 9 standing objection. 9 grati?cation? 1 0 THE WITNESS: At the instruction of my 10 MR. RHEINHART: Objection to the form, the 3. iawyer, i must invoke my Fifth Amendment right. 1 1 standing objection previously stated and 12 BY MR. WEISSING: 12 ambiguous. 3 Q. How many minor female chiidren have been I 3 THE WITNESS: At the instruction of my 4 brought to Jeffrey Epstein?s mansion for the . 4 lawyer, I must invoke my Fifth Amendment right. 5 purposes of his sexuai grati?cation? 5 BY MR. WEISSING: 6 MR. Objection to the form, 1 6 Q. Between August -- during that same period 1 7 ambiguous as to time period and standing 1 7 of time, did Jeffrey Epstein engage in orai sex or 8 objection. 8 other misconduct with 9 THE WITNESS: On the instruction of my 1 9 MR. RHEINHART: Standing objection to 2 0 lawyer, i must invoke my Fifth Amendment right. 2 0 form. 2 1 BY MR. walssmo: 2 1 ran WITNESS: At the instruction of my 2 2 Q. Between the years of 200i and 2005, were 2 2 lawyer, i must invoke my Fifth Amendment right. 2 3 more less or less than 1,000 underage female chiidren brought to Jeffrey Epstein's mansion for 2 4 Q. During that same period of time, did his - after their 25 (Pages 283 to 286) (563.) PROBE COURT REPORTING AGENCY, INC. (563.) 832*7506 Page 287 Page 289 Jim of the minor child?s sexual organs? 1 THE WITNESS: At the instruction of my $2 2 MR. Can you, can you clarify 2 lawyer, i must invoke my Fifth Amendment right. 3 what you said, "the minor child"? 3 BY MR. i 4 MR. Yes. We?re talking about 4 Q. During that same period did ieffrey 5 LM. Epstein tell you that he knew that L.M. was a minor 6 MR. {just want to make sure 6 child? 7 you?re limiting the question to LEVI. '7 MR. RHEINHART: Objection to the form, the 8 MR. All right. 8 standing objection. 9 MR. On that basis, we?re 9 THE WITNESS: At the instruction of my 1 objecting to the form, and standing objection. 0 lawyer, i must invoke my Fifth Amendment right. 1 it assumes multiple facts this witness does not 1 1 BY MR. 1 2 acknowledge she does have information about, Li 2 Q. Did Jeffrey Epstein tell you that he knew 3 and therefore the question is compound and 13 that he was injuring LM. through numerous sexual 3. 4 ambiguous, and i instruct her not to answer. 1 ?ii encounters with her between August 2002 and 1 5 THE WITNESS: On the instruction of my 1 5 September of 2005? 1 lawyer I must invoke my Fifth Amendment right. 1 6 MR. RHEINHART: Objection to the form, and 17 BY MR. WEZSSING: 17 standing objection. Also compound question and 1 8 Q. You knew that during that period of time, i 8 ambiguous, and instruct the witness not to 9 that Jeffrey Epstein was engaged in fondling and 1 9 answer the question. 2 penetrating the sexual organs of 2 0 THE WITNESS: At the instruction of my 2 1 MR. RHEINHART: Objection to form, 2 lawyer, i must invoke my Fifth Amendment right. 22 leading, and also a standing objection. 22 BY MR. WEISSING: 2 3 THE WITNESS: At the instruction of my 2 3 Q. Did you know that Jeffrey Epstein was 2 4 lawyer I must invoke my Fifth Amendment right. 2 4 injuring LM. through sexual contact with her during 2 5 2 5 that period of time? Page 288 Page 290% 3.. BY MR. WEISSING: 1 MR. RHEINHART: Objection to the form. It 2 Q. Did you know during that period of time 2 assumes knowledge of Jeffrey Epstein and BM. 3 that Jeffrey Epstein was engaging in sexual 3 and instruct the witness not to answer. 4 penetration of 4 THE WITNESS: At the instruction of my 5 MR. Ri?IEil?xiHAR'i?: Objection to the form, 5 lawyer, i must invoice my Fifth Amendment right. 6 standing objection previously stated. 6 BY MR. WEISSING: 7 THE WITNESS: At the instruction of my 7 Q. Did you know that the criminal conduct by 8 lawyer, i must invoke my Fifth Amendment right. 8 Jeffrey Epstein against LM. was causing damage During that period of time did you know 3. 0 MR. RHEINHART: Objection to the form. it 1 that EM. was a minor child? it 1 calls for a legal conclusion that the witness 12 MR. RHEINHART: Objection to form, it 2 is not competent to give. Also calls for 13 standing objection and assumes multiple facts l3 speculation as to harm, if any, to a person she 4 and therefore can't be answered without, 1 4 hasn?t even acknowledged that she knows, so 1 5 because the question is too ambiguous. 5 it?s an improper question. i instruct her not 6 instruct the witness not to answer. 1 6 to answer based on the Fifth Amendment. 7 THE WITNESS: At the instruction of my 1 7 THE At the instruction of my 1 8 lawyer i must invoke my Fifth Amendment right. 8 lawyer I must invoke my Fifth Amendment right. 9 BY MR. WEISSING: 9 BY MR. WEISSING: 2 8 Q. From August 2002 to September 2005, did 2 Q. Are you aware that in the State of Florida 2 1 Jeffrey Epstein know that LM. was a minor child? 2 3. it is a crime to engage in sex, sexual activity with 2 2 MR. ausmaanr: Objection to the form, - 2 2 a minor child? 2 3 calls for speculation and also a standing 2 3 A. Can you repeat the question, please? 2 4 objection as assuming knowledge of Jeffrey 2 4 Q. Yes. Are you aware that in the State of 2 Epstein. Instruct the witness not to answer. 2 5 Florida it is against, it is a crime to engage in 26 (Pages 287 to 290) (561) 83247500 PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 mm ,wm? "'vs "2+5 .. .: my -sae??waeaum? - a. Manama =2 ii Page 291 Page 293 1 sexual activity with a minor child? 1 MR. RHEINHART: Objection to the form to 2 MR. Can I?d just ask you to 2 the extent it assumes knowiedge of 3 clarify, when you say "sexual activity,? are 3 Jeffrey Epstein or L.M. 4 you using a iegai term of art, or do you have a 4 THE WITNESS: At the instruction of my 5 speci?c de?nition? 5 iawyer, i must invoke my Fifth Amendment right. 6 MR. WEISSING: Sexual activity. 6 BY MR. WEISSING: 7 MR. RREINHART: Okay. You mean by an 7 Q. At times that Jeffrey Epstein was 8 adult with a minor child? 8 involved with L.M., she was a minor child, or was 9 MR. Yes. 9 she a minor child? - 1 0 MR. RHEINHART: Okay. Hoid on one second. 1 0 MR. Objection to the form, 1 1 i?m going to object. it catls for a legal - 1 1 standing objection. It assumes facts that 1 2 conclusion. i?m going to instruct her not to 1 2 there has been no admission this witness knows 1 3 answer the question. 13 anything about. Instruct her not to answer. 1 4 MR. No 4. "ii-{E WITNESS: At the instruction of my 1 5 MR. i?m instructing her not to 1 5 lawyer, I must invoke my Fifth Amendment right. 1 6 answer the question. it calls for a iegai 1 6 BY MR. 1 7 conclusion. it's not a factuai question that 17 Q. Did Jeffrey Epstein intentionaiiy 1 8 is designed to tend to discoverable evidence. 1 8 penetrate LM. during his, while she was mansion? 2 0 Q. Did you know that LM. was suffering 2 0 MR. Same objection to the 2 1 injury and emotional and trauma as a 2 1 form. 2 2 resuit of the behavior engaged in with her by 22 THE WITNESS: At the instruction of my 2 3 }effrey Epstein? 2 3 lawyer, i must invoke my Fifth Amendment right. 24 MR. RHEINHART: Objection to the form. 2 4 BY MR. WEISSING: 2 5 Assumes knowledge of the existence of a person 2 5 Q. Did Eeffrey Epstein engage in masturbation Page 292' Page 294 l. by the name of L.M. which has not been 1 in front of LM. while she was a minor child at his 2 acknowledged. I instruct her not to answer. 2 mansion? 3 THE WITNESS: On the advice of counsel, I 3 MR. Objection to the form. 4 must invoke my Fifth Amendment right. 4 THE At the instruction of my 5 BY MR. WEISSING: 5 iawyer, I must invoke my Fifth Amendment right. 6 Q. Were you at the mansion the ?rst time 6 BY MR. WEISSING: 7 that LM. came to see Jeffrey Epstein? 7 Q. Did you know that Eeffrey Epstein was 8 MR. RHEINHART: Objection to the form. 8 engaging in sex, his sexual grati?cation in the 9 Standing objection as to knowiedge of 9 presence of 3. 0 Jeffrey Epstein or any mansion. 1 0 MR. RHEINHART: Objection to the form. 3. 1 THE WITNESS: On the advice of counsei, i 13. On the instruction of my 3.2 must invoke my Fifth Amendment right. 12 iawyer, I must invoke my Fifth Amendment right. 13 BY MR. 13 BY MR. WEISSING: 1 4 Q. Did Jeffrey Epstein teii you that he 1 4 Q. Did you know that Epstein touched LM. in 1 5 intended to injure L.M. by engaging her in sexual 15 the intimate portions of her body on numerous, 6 activity? 1 6 dozens of occasions between August of 2002 and 7 MR. Object to the form. 1 '7 September of 2005? 1 8 Assumes knowledge of Jeffrey Epstein and LM, 1 8 MR. RHEINHART: Object to the form. 1 9 Standing objection. 9 THE WITNESS: At the instruction of my 2 0 THE WITNESS: On the advice of my iawyer, 2 lawyer, I must invoke my Fifth Amendment right. 2 3. i must invoke my Fifth Amendment right. 2 1 BY MR. WEIS SING: 2 2 BY MR. WEISSING: 2 2 Q. Have you met Jane Doe? 2 3 Q. Did Jeffrey Epstein tell you that he 2 3 A. At the instruction of my lawyer, i must invoke 2 4 intended to cause severe emotional distress to L.M. 2 4 my Fifth Amendment right. 2 by engaging her in sexual activity? 2 5 Q. As part of your job, would you set up the 27 (Pages 291 to 294) (561} 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Page 295 Page 29'? massage table where minor children were escorted in 1 massage table and order them to take their clothes 2 Jeffrey Epstein?s mansion? 2 off? 3 MR. Objection to the form. 3 MR. Objection to form. It It's a compound question that assumes things 4 THE. WITNESS: At the instruction of my 5 about herjob and other things that are not 5 lawyer, I must invoke my Fifth Amendment right. 6 established and instruct her not to answer. 6 BY MR. WEIS SING: ?7 THE At the instruction of my 7 Q. After they disrobed, are you aware that he 8 lawyer, I must invoke my Fifth Amendment right. 8 would allow them to massage him? 9 BY MR. warssmo: 9 MR. Are we talking about a 1 0 Q. Between 2001 and 2005 were you an employee 1 0 speci?c person on a specific date, or are you of Jeffrey Epstein? asking a general practice and policy? 1 2 MR. Instruct the witness not 1 2 MR. WEISSING: General. 3. 3 to answer based on Fifth Amendment privilege. 3 MR. Object to the question as 1 43 THE WITNESS: At the instruction of my 1 ti ambiguorxs, open ended, and instruct the witness l. 5 lawyer, I must invoke my Fifth Amendment right. 1 5 not to answer. 1 6 BY MR. 6 THE WITNESS: On the instruction of my '7 Q. As part of your employment, were you 1 7 lawyer, I must invoke my Fifth Amendment right. 8 responsible for setting up a massage table in the 8 BY MR. WEIS SING: 9 mansion? 1 9 Q. Are you aware that ieffrey Epstein 2 0 MR. Objection to the form. 2 routinely would turn on, turn onto his back and ask 2 it THE WITNESS: On the instruction of my 2 the girls to pinch his nipples? 2 2 lawyer, I must invoke my Fifth Amendment right. 2 2 MR. RHEENHART: Objection to the formIt?s a compound question. 2 a Q. As part of your employment for, with 2 THE WITNESS: At the instruction of my 2 5 Jeffrey Epstein, were you responsible for escorting 2 5 lawyer, i must invoke my Fifth Amendment right. Fargo 296 Page 298 1 underage girls to the massage table area in the 1 BY MR. 2 mansion? I 2 Q. After exposing his naked body to these 3 MR. Objection to form. 3 girls, are you aware that he would then masturbate 4 Till}. WIWBSS: At the instruction of my 4 in their presence? 5 lawyer, I must invoke rny Fifth Amendment right. 5 MR. Object to the form. You 6 BY MR, 6 keep asking questions about what it 7 Q. After escorting underage girls to the 7 Jeffrey Epstein did. She's not acknowledged 8 massage area in the mansion, did you leave them 8 she even hnovvns a Jeffrey Epstein. You can ask 9 alone? 9 her if Jeffrey Epstein went to the moon; she?s 0 MR. RHEINHART: Objection to form. 1 0 not going to answer the question, but you can 1 THE WITNESS: At the instruction of my 1 keeping asking. 12 lawyer, i must invoke my Fifth Amendment right. 3.2 THE WITNESS: On the instruction lawyer, I must invoke my Fifth Amendment right. 4 Q. After the underage girls were left alone, 3. 4 BY MR. WEISSING: 5 are you aware that Jeffrey Epstein appeared either 15 Q. The amount of, the amount of money given 6 naked or, or wrapped in a towel? 1 6 to these young girls was dependent upon the extent '7 MR. RHEINHART: Objection to form. Calls 3.7 of behavior engaged in by 3effrey Epstein; is that 8 for speculation and compound question. Assumes i 8 correct? Egg 1 9 facts that she?s not acknowledged any personal 1 9 MR. RHBINHART: Objection to form, leading 2 0 knowledge of. 2 and otherwise objection to the form for the 2 1 THE WITNESS: On the instruction of my 2 1 reasons previously stated. 2 2 lawyer, I must invoke my Fifth Amendment right. 2 2 THE WITNESS: On the instruction of my 2 3 BY MR. WEIS SING: 2 3 lawyer, i must invoke my Fifth Amendment right. 2 4 Q. Are you aware that after appearing naked 2 4 BY MR. WEISSING: 2 5 in front of underage girls, he would lay down on th 2 5 Q. Were the girls paid more if they used 28 (Pages 295 to 298) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Rage 299 Page 301 3 ?mi never: mam-teem :Ls magma W: teaser-35M: 1' t? 1 vibrators or sexual toys? lawyer, I must invoke my Fifth Amendment right. 2 MR. RHEINHART: Objection to the form. 2 BY MR. 3 THE WITNESS: On the instruction of my 3 Q. Were you aware that during that period of Al lawyer, I must invoke my Fifth Amendment right. 4 time that Jane Doe was a minor child? 5 BY MR. WEISSING: 5 MR. RHEINHART: Objection to the form. 6 Q. Regarding Jane Doe, when she was first 6 THE At the instruction of my 7 brought to Epstein?s mansion in 2003, she was in 7 lawyer, I must invoke my Fifth Amendment right. 8 middle school, or was she in middle school? 8 BY MR. 9 MR. Objection to form. 9 Q. Were you aware that during that period of 0 THE WITNESS: On the instruction of my 1 0 time that Jeffrey Epstein engaged in fondling and 1 lawyer, must invoke my Fifth Amendment right. 1 3. sexual touching of Jane Doe? 12 BY MR. 12 MR. Form. 1 3 Q. Are you aware that in 2003 when Jane Doe 3 THE At the instruction of my 14 1A 5 school? 1 5 BY MR. WEESSING: 6 MR. Objection to the form. 1 6 Q. During that period of time, were you aware 7 Once again to answer the question, she would 1 7 that Jeffrey Epstein engaged in masturbation in the 8 have to implicitly admit that she knows Jeffrey J. 8 presence of Eane Doe? 9 Epstein or knows anything about Jeffrey Epstein 9 MR. Objection to form. 2 0 which she is not going to do, so to go onto the 2 0 THE WITNESS: The instruction of my 2 3. second half of the question, it?s a compound 2 lawyer, i must invoke my Fifth Amendment right. 2 2 question as to whatever happened with 2 2 BY MR. 2 3 Mr. Epstein. But you keep asking her. She's 2 3 Q. During that period of time, are you aware 2 4 not going to ansWer them. So, they?re compound 2 that Jeffrey Epstein engaged in sexual penetration 2 5 and ambiguous. 2 55 of Jane Doe? Page 300 Page 302 1 THE WITNESS: On the instruction of my 1 MR. RHEINHART: Objection to form. 2 lawyer, I must invoke rny Fifth Amendment right. 2 THE WITNESS: On the instruction of my 3 BY MR. WEISSING: 3 lawyer, i must invoke my Fifth Amendment right. 4. Q. Are you aware that between February 2003 4 BY MR. 5 and June of 2005 that Jane Doe engaged in sexuai 5 Q. During that period of time, are you aware 6 conduct with Jeffrey Epstein at his mansion? 6 that Jeffrey Epstein perpetuated that kind of 7 MR. RHEINHART: Objection to the form. '7 behavior upon Jane Doe on dozens of occasions? 8 THE WITNESS: At the instruction of my 8 MR. Objection to the form. 9 lawyer, i must invoke my Fifth Amendment right. 9 it's ambiguous and. otherwise standing 3. 0 BY MR. WEISSING: it 0 objection. 1 3. Q. in 2003 she was only are you aware that 1 1 THE WITNESS: On the instruction of my 1 2 she was only 14 years of age when she first came to 12 lawyer, i must invoke my Fifth Amendment right. 1 3 the mansion? 3. 3 BY MR. WEISSING: 1 4 MR. RHEINHART: Objection to form. 1 4 Q. Are you aware that when he was engaging in 5 THE WITNESS: At the instruction of my 15 the sexual conduct with Jane Doe, that he was doing 1 6 lawyer, I must invoke my Fifth Amendment right. 1 6 so with the speci?c intent to cause her emotional 7 BY MR. WEISSING: and injury and damage? 1 8 Q. Between February of 2003 and lune 2005, 8 MR. Objection to the form. 1 9 was Jeffrey Epstein aware that she was 14, 15, i6 1 9 Calls for a legal conclusion and is ambiguous 2 0 years of age? 2 0 and is compound. 2 1 MR. Objection to form. Calls 2 1 THE WETNESS: The instruction of my lawyer 2 2 for her to speculate on the state of mind of a 2 2 I must invoke my Fifth Amendment right. 2 3 person she's not admitting she has any 2 3 BY MR. WEISSING: 2 4 knowledge of. 2 4 Q. Did Jeffrey Epstein tell you that when he 2 5 THE WITNESS: At the instruction of 2 5 would engage in the sexual conduct with Jane Doe, 29 (Pages 299 to 302) (561) 832~7500 PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 Page 303- Page 305 1 that he was intentionally and deliberately 3. going to instruct the witness not to answer it 2 attempting to cause her and emotional 2 at all. 3 pain and suffering? 3 BY MR. WEISSING: 4 MR. Objection to form for the 4 Q. Okay. Did you engage in an agreement with 5 reasons previously stated. 5 Jeffrey Epstein that you would seek out underage 6 ?i?llE WITNESS: At the instruction of my 6 female children for his sexual gratification? 7 lawyer, i must invoke my Fifth Amendment right. . 7 MR. Objection to the form. 8 BY MR. WEISSING: 8 It?s a compound question. Instruct the witness 9 Q. Did you see evidence that Jeffrey 9 not to answer. 1 Epstein's sexual misconduct with her led to 2 0 THE On the instruction of my 1 1 emotional distress on her behalf? 1 1 lawyer, I must invoke my Fifth Amendment right. 12 MR. Objection to the form. 12 BY MR. 13 THE WITNESS: At the instruction of my 13 Q. Are you aware that Jane Doe was injured as 1 4 lawyer, i must invoke my Fifth Amendment right. 1 4 a result of sex traf?cking committed against her? 15 BY MR. 15 MR. RHEINHART: Objection to form. Uses l. 6 Q. Are you aware that all of Jeffrey 6 legal terminology like "sex trafficking," and 1 7 Epstein?s behavior with the minor children were 1 '7 presumes as part of the question that she knows 1 8 violations of numerous criminal laws? 1 8 a person by the name oflane Doe, which she is 1 9 MR. RHEINHART: Objection to the form. It 1 9 does not acknowledge. Therefore she's not 2 0 calls for a legal conclusion. i will instruct 2 0 going to answer the question in that form. 2 3. her not to answer the question at all. 2 1 instruct her not to answer, based on Fifth 2 2 BY MR. WEISSING: . 2 2 Amendment because the answer would implicitly 2 3 Q. Did you know that Jeffrey Epstein?s . 2 3 acknowledge that she knows these people or that 2 4 behavior with these minor children was criminal in 2 4 she knows Mr. Epstein. 2 5 nature? 2 5 THE WTINESS: On the instruction of my Page 304 Page 306% 1 MR. Objection to the form. it - 1 lawyer, I must invoke my Fifth Amendment right. 2 assumes she has knowledge of whatever conduct 2 BY MR. 3 Jeffrey Epstein, whoever that may be, may have 3 Q. Are you aware that Jane, Jane Doe suffered i 4 engaged in. So it requires her to Speculate as 4 emotional and trauma and injury as a 5 to a legal conclusion that she?s not going to 5 result of the behavior engaged with her by 6 give. 6 Jeffrey Epstein? 7 BY MR. 7 MR. Sarne objection as stated 8 Q. Through the course of your employment with 8 to the previous question and instruct the ti 9 Jeffrey Epstein, were you paid bonuses or any kind 9 witness not to answer, because to attempt to 1 of additional monies for bringing minor children for 1 0 answer that question would implicitly admit 1 1 his sexual gratification to him? 1 1 that she knows Jeffrey Epstein or knows 12 MR. RHEINHART: Objection to form. 12 anything about Jane Doe. 1 3 Assumes facts such as that she ever worked for 13 THE On the instruction of my 1 4 Jeffrey Epstein or has any immediate knowledge, - 1 4 lawyer, I must invoke my Fifth Amendment right. 1 5 is otherwise compound and ambiguous, and 1 5 BY MR. WEISSING: 6 instruct her not to answer. 1 6 Q. With regard to these girls who were being 1 7 THE WITNESS: At the instruction of my 3 1 '7 procured for Jeffrey Epstein, did you arrange for 1 8 lawyer, I must exert my Fifth Amendment right. 1 8 their travel to the mansion? 9 BY MR. WEISSING: 9 MR. Objection to the form, 2 8 Q. Did you conspire with Jeffrey Epstein to 2 0 ambiguous to the term ?procurement,? and for 2 1 gain access to minor children for his sexual 2 3. the reasons previously stated, and the standing 2 2 gratification? 2 2 objection, and instruct the witness not to 2 3 MR. it?s a question that calls 2 3 answer the question. 5 2 4 for a legal conclusion. It doesnthe instruction of my 2 5 lead to any discoverable evidence, and I am 2 5 lawyer, I must invoke my Fifth Amendment right. 30 (Pages 303 to 306) (561) 832?4500 PROSE COURT AGENCY, INC. (561) 832*7506 me?? i ?tit .J. ma hm hm creme.- wic?t?a'miri; it 1:55!? ?ber-:31: 3-mmw? ?Emm-rqu. iilihrr?ah'. 1' .- uranium bsiiwii?i?ries m3? traumatisaacwtumimarat- Page 307. Page 309 your work for lefii'ey Epstein, did you 2 Q. Are you aware that Jeffrey Epstein engaged 3 coordinate efforts with others in bringing minor 3 in sexual misconduct with lane Doe at least 20 times 4 female children to his mansion for his sexual 4 between February 2003 and June 2005 while she was a 5 grati?cation? . 5 minor child? 6 MR. RHEINHART: Objection to the form. 6 MR. RHEIN HART: Objection to the form. 7 Same objection previously made to the standing 7 THE WITNESS: 0n the instruction of my 8 objection. 8 lawyer, i must invoke my Fifth Amendment right. 9 THE, At the instruction of my 9 BY MR. 1 lawyer, I must invoke my Fifth Amendment right. 1 0 Q. In the scheduling of girls for 1 1 BY MR. 1 Jeffrey Epstein, did he have a particular interest 1 2 Q. Were you aware that many of the girls 12 in girls under the age of 14? 1 3 brought to Epstein?s were minor Epstein mansion 13 MR. Objection to the form. It 1 4 were minors, under at age of 14 years of age? 1 4 assumes she did scheduling for lef??ey Epstein. 1 5 MR. Object to the form. 15 in order to answer the question, she has to 6 instruct the witness not to answer. 1 6 implicitly admit that which she?s not 17 THE WITNESS: At the instruction of my 1 7 admitting, and therefore she?s not answering 8 lawyer, I must invoke the Fifth Amendment 1 8 the question. 1 9 right. 19 THE WITNESS: At the instruction lawyer, i must invoice my Fifth Amendment right. 2 i. Q. Did you coordinate with some of the girls 2 it BY MR. WEISSING: 2 2 to bring other underage female children to Epstein 2 2 Q. In procuring girls for Eeffrey Epstein, 2 3 for his sexual grati?cation? 2 3 was he primarily interested in young, skinny and 2 4 MR. Objection. Can we narrow 2 4 attractive girls? 2 5 down "other girls" and who we are talking 2 5 MR. RHEINHART: Objection to the form and Page 308 Page 310 1 about? We already have questioning from 1 implicitly assumes that she procured girls for 2 Mr. Horowitz about his clients and Mr. Kuvin 2 Jeffrey Epstein, which she has not admitted to 3 about his clients. Can we narrow that down a 3 or is not admitting to, so therefore she can?t 4 little bit? 4 fairly answer the question as it?s been asked, 5 MR. WEISS ING: I?m asking about whether or 5 so therefore, I will instruct her not to answer 6 not she had someone she coordinated with to 6 it. '7 bring other girls. Okay? 7 THE On the instruction of my 8 MR. RHEINHART: And same form objection. 8 lawyer, I must invoke my Fifth Amendment right. 9 THE WITNESS: On the instruction of my 9 BY MR. WEISSING: 0 lawyer, I must invoke my Fifth Amendment 1 Q. With regard to the amount paid to the 3. 1 privilege. 1 girls for what they did with Jeffrey Epstein, would 12 BY MR. WEISSING: 1 2 the standard payment be several hundred dollars? 1 3 Q. When you scheduled these girls to come to 1 3 MR. Objection to the form, 1 4 the mansion, you knew that they were coming for 4 standard objection. 5 leffrey Epstein?s sexual grati?cation, did you not? 1 5 THE WITNESS: At the instruction of my 1 6 MR. RHEINHART: Objection to the form. 6 lawyer, I must invoke my Fifth Amendment right. i 7 It's a compound question that assumes she did 1 7 BY MR. WEISSING: I 1 8 scheduling, assumes she brought them have a standard escalation of the 1 9 mansion, assumes she knows what the mansion is, 9 amount that he would pay depending upon the nature 2 0 and she knows who Jeffrey Epstein is. 2 0 of the sexual acts that he performed with them? 2 1 So it's a compound question that she can't 2 1 MR. RHEINHART: Objection, objection. The 2 2 fairly answer without -- in the form that it?s 2 2 question has been asked and answered in 2 3 asked and instruct her not to answer. 2 3 different forms several times, and again 2 4 THE WITNESS: At the instruction of my 2 4 standing objection as to the form of the 2 lawyer, i must invoke my Fifth Amendment right. 2 5 question. 31 (Pages 307 to 310) (561) PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Page 311 Page 313 1 THE WITNESS: At the instruction of my it happen? 2 lawyer, i must invoke my Fifth Amendment right. 2 MR. RHEINHART: Objection to the form for 3 BY MR. WEISSING: 3 the same reasons previously stated. 4 Q. The engaging in sexual practices with Al THE WITNESS: At the instruction of my 5 underage girls, was this something that went on for 5 lawyer, I must invoke my Amendment right. 6 a substantial period of time? 6 BY MR. WEISSING: 7 MR. RHEINHART: Objection to the form. 7 Q. Are you aware that Epstein received sexual 8 It?s ambiguous. It assumes facts that she?s 8 grati?cation from sexually abusing minor children? 9 not conceding, and she can?t fairly answer the 9 MR. RHEINHART: Object to the form. It 1 0 question based on the assumptions that are made 1 0 calls for a legal conclusion and it's 1 1 in it. i will therefore instruct her not to 1 1 ambiguous, and the standing objection as to any 12 answer the question. 3.2 knowledge of Jeffrey Epstein or any abuse of 1 3 THE WITNESS: At the instruction of my 1 3 minor children. 3. 4 lawyer i must exercise my Fifth Amendment 1 4 THE WITNESS: At the instruction of my 1 5 right. 1 5 lawyer, i must invoke my Fifth Amendment rightMR. WEISSING: 1 7 Q. With regard to the payments made to the 17 Q. Did Jeffrey Epstein ever tell you that he 1 8 girls, would he make bigger payments to these minor 1 8 received sexual gratification from sexually abusing 1 9 girls depending upon the degree of force he used 1 9 minor children? 2 0 towards them? 2 0 MR. Objection to the form for 2 1 MR. Objection to the form. it 2 3. the same reasons previously stated. 2 2 assumes numerous facts that have not been i 22 THE At the instruction of my 2 3 established nor that this Witness is admitting. 2 3 lawyer, I must invoke my Fifth Amendment right. 2 4 So, i instruct her not to answer. 2 4 MR. RHEINHART: Folks, it?s 4:20. We?ve 2 5 TEE At the instruction of my 2 5 been at this for a long, long time. This is Page 312 Page 3142 lawyer, i must invoke my Fifth Amendment right. 1 now getting pointless, and we're term inating 2 BY MR. 2 the deposition at 5:00. So I suggest you pick 3 Q. Along that line, would he make greater 3 up the pace. 4 payments, larger payments to the girls if they if 4 You can ask a million questions about what 5 he was more concerned about them reporting the 5 Jeffrey Epstein knew, what Jeffrey Epstein did. 6 crimes committed against him? 6 She doesn't know. She?s not going to say, so 7 MR. RHEINHART: Objection to the form. It 7 we've got 40 minute and we're out of here. 8 calls for speculation. It calls for a legal 8 MR. GARCIA: i haven't asked any 9 conclusion. it assumes facts that have not 9 questions. 1 0 been admitted. Standing objection to the form. 1 0 MR. EDWARDS: There others of us that have 1 1 THE At the instruction of my 1 1 questions. 1 2 lawyer, I must invoke my Fifth Amendment 12 MR. RHBINHART: You can take that up with 13 privilege. 13 the judge. We're done at 5:00. 1 4 BY MR. 4 MS. EZELL: For the record, there are some 1 5 Q. Would you pay the girls more money because 1 5 filed cases who attorneys have not been able to 6 of the amount of force used by Jeffrey Epstein l. 6 ask questions, and we certainly assert our 1 7 against them and feared that they would report the l. 7 right to call Ms. Kellen again. 1 8 crimes committed against them? 3 1 8 MR. RHEINHART: You can, you can certainly 9 MR. Objection to the form. 3. 9 take that up, but i am not, you know, how many, 2 0 THE WITNESS: On the instruction of my 2 0 how many times do we have to ask the same 2 1 lawyer, I must invoke my Fifth Amendment right. 2 1 question over and over and over again that it?s 2 2 BY MR. WEZSSING: 2 2 clear is a compound question that asks her to 2 3 Q. Are you aware that after having unlawful 2 3 assume facts that she?s not admitted she knows 2 4 sex with these minor children, that Epstein would 2 4 anything about and it?s a hypothetical question 2 5 tell them not to tell anyone or bad things would 2 5 not designed to get us anywhere. (561) 832-4500 PROSE COURT REPORTENG AGENCY, 32 INC. (561) 832-37506 3' :5an runawm sameness m1:m ii lat/mi: zest; - the; win shamanism." at 9: (Pages 311 to 314) mac. wattle. Id??im?diclwa leatherette/1mm madm- an?. anaemia/Mr:me - aw newsman :55. W?t?m?n?xj?d minim-.th ?c?t?r 'lhi?nl' a I m. Page 315 Page 317 1 So can we focus on the speci?c questions 3. THE On the instruction of my 2 that she can answer or from which you can draw 2 lawyer, i must invoke my Fifth Amendment 3 an adverse inference if asked properly, and 3 privilege. 4 let?s move it along. 4 BY MR. WEISSING: 5 MS. EZELL: Each young woman's case is an 5 Q. Do you know Alan Dershowitz? 6 individual case, and we have the right to ask, 6 MR. The question was asked and 7 ask whatever questions that we need to with '7 answered about three-and-a-half hours ago. 8 regard to each one. 8 TEE On the instruction of my 9 MR. RHEINHART: 9 lawyer, i must invoice my Fifth Amendment 1 0 MR. GOLDBERGER: Let?s just go forward 1 privilege. 1 1 until 5:00 and see where we?MR. WEISSING: 1 2 Q. Do you know David Copper?eld? 1 3 Q. Did you know that Jeffrey Epstein received 13 MR. RHEINHART: That question was asked 1 4 sexual grati?cation from directing others to 1 4 about three-and-a?half?hours ago. 1 sexually ahuse minor children? 3. 5 T118 On the instruction of my 1 6 MR. RHEINHART: Objection to the form. 1 6 lawyer, i must invoke my Fifth Amendment 1 '7 THE WITNESS: On the instruction of my 1 7 privilege. 1 8 lawyer, I must invoke the ifrh Amendment it 8 BY MR. 1 9 right. 1 9 Q. in addition to his place at, in Palm 2 0 BY MR. WEISSING: 2 0 Beach, are you aware that Jeffrey Epstein has an 2 1 Q. Did you know that Jeffrey Epstein received 2 1 apartment located at 301 East 66th Street, Apartment 2 2 sexual grati?cation from directing Marcinkova to 2 2 146 through in New York? 2 3 sexually abuse minor children? 2 3 MR. RHEINHART: That question was asked 2 4 MR. RHEINHART: Objection to the form. It 2 4 about four hours ago. It?s been asked and 2 5 assumes knowledge of a person named Marcinkova. 2 5 answered. Page 316 Page 318 1 it is otherwise compound and objectionable. 1 THE WITNESS: At the instruction of my 2 THE WITNESS: On the instruction of my 2 lawyer, I invoke my Fifth Amendment privilege. 3 lawyer, i must invoke my Fi?h Amendment right. 3 BY MR. WEESSING: - I, 4 MR. WEISSING: Let?s go off the record for 4 Q. While in New York, have you procured 5 a moment. 5 underage minor children to engage in sexual acts 6 11-113 VEDEOGRAPHER: Are we all good with 6 with Jeffrey Epstein at that location? 7 going off the record? 7 MR. RHEINHART: Object to the form. 8 MR. Yeah, that?s fine. 8 THE WITNESS: On the instruction of my 9 MR. Yes. 9 lawyer, i must invoke my Fifth Amendment 1 0 THE VIDEOGRAEHER: We?re now off the 1 privilege. 1 1 record at 4:22 pm 1 1 BY MR. WEISSING: 1 2 (A brief recess was held.) 12 Q. With regard to the minor children procured 3 THE VIDEOGRAPHERthat location, were they school children 1 4 record. It is 4:24 pm. 1 4 in the New York areaMR. The previous question, 1 6 Q. Do you know Nadia Marcinkova? . 1 6 objection to the form. The same as all the 3. 7 MR. KUVIN: Marcinkova. 17 previous questions, it assumes a fact that?s 1 8 THE WITNESS: On the instruction of my i 1 8 not been established. it can?t fairly be 1 9 lawyer, I must invoke my Fifth Amendment 1 9 answered. 2 0 privilege. . 2 0 THE WITNESS: On the instruction lawyer, 1 must invoke my Fifth Amendment 2 2 Q. Do you know have you procured minor 2 2 privilege. 2 3 children to have sexual relations with 2 3 BY MR. 2 4 Nadia Marcinkova at Jeffrey Epstein?s mansion? 2 4 Q. Did Jeffrey Epstein have sexual encounters 25 MR. RHEINHART: Ohiection to the form. 2 5 with underage people while at that apartment? -33 (Pages 315 to 318) (561) 832?7580 (561) 832-7506 PROSE COURT REPORTING AGENCY, INC. a. swarm - ft?m mmfl??i?mmb . imam? 13.x?: .M. it" ?s?mww? 123? an? .. smears. exude. Mama-a . Page 319 Page 321 1 MR. Objection to the form. 1 privilege. 2 THE WITNESS: On the instruction of my 2 BY MR. WEISSING: 3 lawyer, I must invoke my Fifth Amendment 3 Q. Have you been to Jeffrey Epstein's 4 privilege. 4 property at 6100 Red Hook Quarters, Suite 3?8, in 5 BY MR. WEISSING: 5 St. Thomas, the Virgin Islands? 6 Q. With regard to underage children that he 6 A. On the instruction of my lawyer, i must invoke 7 had sexual encounters with in New York, were those 7 my Fifth Amendment privilege. 8 school children in that area? 8 Q. Over what period of time have you been to 9 MR. RHEINHART: Objection to the form. No 9 that location? 3. factual basis for the question. 1 8 MR. RHEINHART: Objection to the form. 3. 1 THE WITNESS: On the instruction of my 11 THE WITNESS: On the instruction of my 1 2 lawyer, I must invoke my Fifth Amendment 12 lawyer, I must invoke my ilth Amendment 1 3 privilege. IL 3 privilege. 1 4 BY MR. WEISSING: 4 BY MR. WEISSING: 3. 5 Q. Are you aware of another location that he 1 5 Q. Are you aware of .leffrey Epstein engaging 6 has at 457 Madison Avenue, lower floor, New York? 1 6 in sexual encounters with underage persons at that 7? MR. RHEINHART: Objection to the form. 1 7 location? 1 8 THE At the instruction my lawyer 8 MR. RHEINHART: Objection to the form. 1 9 i must invoke my Fifth Amendment privilege. l. 9 THE WITNESS: On the instruction lawyer, i must invoke my Fifth Amendment 2 1 Q. Are you aware of Jeffrey Epstein having 2 privilege. 2 2 sexual encounters with underage children at that 2 2 BY MR. WEISSING: 2 3 location? 2 3 Q. With regard to the underage children he 2 4 MR. RHEINHART: No factual basis for the 2 4 engaged in sexual activity with at that location, 2 5 question. Objection to form. 2 5 where were those children procured from? Page 320 Page 322 3. THE WITNESS: On the instruction of my 1 MR. RHEINHART: Objection to the form. it 2 lawyer, I must invoke my Fifth Amendment 2 assumes facts that there has not been any basis 3 privilege. 3 to assume this witness has any knowledge of. 4 BY MR. WEISSWG: 4 THE WITNESS: On the instruction of my 5 Q. Was it part of your employment to obtain 5 lawyer, i must invoke my Fifth Amendment 6 underage children for sexual encounters with him at 6 privilege. 7 that location? 7 BY MR. WEISSING: 8 MR. RHEINHART: Objection to the form. 8 Q. Were you, were you engaged by Jeffrey 9 THE WITNESS: At the instruction of my 9 Epstein to procure school children from the Virgin 1 lawyer, I must invoke my Fifth Amendment 1 0 Islands area for sexual behavior at that location? 1 privilege. 1 3. MR. REEINHART: Objection to the form. 12 BY MR. WEISSING: 12 Standing objection, it assumes knowledge of 1 3 Q. With regard to the underage children he 1 3 Jeffrey Epstein. 4 had sex with at that location, were those school 1 4 THE WITNESS: At the instruction of my 1 5 children from that area? 1 5 lawyer i must invoke my Fifth Amendment 1 6 MR. RHEINHART: Can i ask what the good 1 6 privilege. 1 7 faith basis is to ask the question if he 17 BY MR. WEISSING: 1 8 actually had sex with someone at that location? 3. 8 Q. Who is Story Cowles? l. 9 Because i, i know no factual predicate that i i 9 MR. Objection to the form. 2 0 have heard today for asking the questions, so i 2 0 THE WITNESS: At the instruction of my 2 1 will instruct the witness not to answer it 2 lawyer, I must invoke my Fifth Amendment 2 2 because it presumes that she knows ieffrey 2 2 privilege. 2 3 Epstein. 2 3 BY MR. WEISSING: 2 4 THE WITNESS: On the instruction of my 2 4 Q. Did Mr. Cowies in your presence ever have 2 5 lawyer, I must invoke my Fl 11 Amendment - 2 5 sexual encounters with underage persons at any of 34 (Pages 319 to 322) (563.) 832*7500 PROSE COURT REPORTING AGENCY, INC. (56l) 832-37506 Page 323 Rage 325 1 Mr. Epstein?s properties? 1 MR. WEISSING: I have no other questions. 2 MR. Objection to the form. It 2 MR. RHEENHART: Okay. Ms. Ezeli, 3 assumes knowledge of Mr. Epstein. 3 Mr. Garcia, do you want to go next? 4 TEE WITNESS: At the instruction of my 4 MR. GARCIA: Is it okay if I go? 5 lawyer, I must invoke my Fifth Amendment 5 MS. EZELL: We were just discussing that. 6 privilege. 6 l?rn going to go quite a while, and I believe 7 BY MR. WEISSING: 7 you think you can finish in 30 or 40 minutes, 8 Q. Were you, did you participate in procuring 8 9 underage children for having sex with Mr. Cowles at 9 MR. GARCEA: About 45. About 45 minutes. 0 Mr. Epstein?s properties? 1 0 MS. EZELL: It makes sense for Mr. Garcia 1 MR. RHEINHART: Objection to the form. It 1 to go first. 12 assumes knowledge of Mr. Epstein. 1 2 MR. RHEINHART: Your decision. Do you 1 3 THE WITNESS: At the instruction of my 13 need a break or are you okay? 1 4 lawyer, I must invoke my Fifth Amendment 1 4 THE WITNESS: I?m okay. 1 5 privilege. 1 5 MR. RHEINHART: I?ll siide over. 1 6 BY MR. 16 THE. Are we on a break? 1 7 Q. Have you ever heard of Sarah Kensington? 1 7 MR. No, no breaks. 1 8 MR. RHEINHART: Objection to the form. 1 8 CROSS (SARAH KELLEN) 1 9 THE WITNESS: On the instruction of my 1 9 BY MR. GARCIA: 2 lawyer, i must invoke my Fifth Amendment 2 Q. Ms. Kellen, I think you?ve already 2 1 privilege. 2 1 answered this question about your cell number. Are 2 2 MR. WEISSING: Okay. Let's you objected 22 you able to tell me if you have a new cell number 3 2 3 to the form. 2 3 other than the one that was given to you which i 2 4 MR. RHEINHART: I'm sorry. i didn't mean 2 4 believe was (917)8556363? 2 5 to object to form. That one I apologize. Just 2 5 MR. Instruct the witness not Page 324 Page 326; 1 instruct the witness not to answer the 1 to answer the question based on her Fifth 2 question. 2 Amendment privilege. 3 BY MR. WEISSING: 3 THE WITNESS: At the instruction of my 4 Q. Have you ever gone by the name 4 lawyer, I must invoke my Fifth Amendment right. 5 Sarah Kensington? 5 BY MR. GARCEA: 6 A. At the instruction of my lawyer, i must invoke 5 6 Q. All right. Can you tell me who pays for 7 my Fifth Amendment privilege. I ?7 that cell number? 8 Q. Have you ever been paid by .ieffrey Epstein 8 MR. RHEINHART: Same instruction. 9 to obtain underage children to have sex with 9 THE, WITNESS: On the instruction of my 1 Jean-Lire Brunei? 1 lawyer, I must invoke my Fifth Amendment 1 1 MR. RHEINHART: Objection to the form. it .1 1 privilege. 12 assumes knowledge of Jeffrey Epstein. 12 BY MR. GARCIA: 3 THE WITNESS: At the instruction of my 1 3 Q. Can you tell me how long you?ve had that a; 1 4 lawyer, I must invoke my Fifth Amendment 1 4 cell number? i 1 5 privilege. 1 5 MR. Just -- 1 6 BY MR. WEISSINO: 6 THE WITNESS: On the instruction -- 1 '7 Q. Other than the properties that we've 17 MR. RHEINHART: .iust so I'm clear, when 8 discussed, are you aware of any other properties 8 you say "that" cell numbe 1 9 that Jeffrey Epstein owns? 1 9 MR. GARCIA: The (917)855-3363. 2 A. At the instruction of my lawyer, i must invoke 2 0 MR. RHEINHART: Thank you. Instruct the 2 1 my Fifth Amendment privilege. 2 1 witness not to answer based on Fi?h Amendment. 22 Q. Are you aware of the ?nancial assets of 2 2 THE At the instruction of my 23 Seffrey Epstein? 2 3 lawyer, I must invoke my Fitth Amendment right. 2 4 A. On the instruction of my lawyer, I must invoke 2 4 BY MR. GARCIA: (561) my Fifth Amendment privilege. 832*7500 PROBE COURT REPORTING AGENCY, at 77777 Q. ll right. Would you have any objection 35 (Pages 323 to 326) INC. (561) 832~7506 Page 327 Page 329 to me dialing that number to see what the response 1 MR. RHEINHART: There?s all sorts of facts 2 is? 2 that you may be able to prove from other places 3 MR. Would she object to it? 3 that she?s doesn't have to admit to. 4 MR. GARCIA: Yeah. 4 MR. GARCIA: I am not asking her for other 5 MR. RHEINHART: You can do whatever you 5 facts. i?rn asking her if she files income tax 6 want to do. 6 returns. 7 MR. GARCIA: Okay. 7 MR. Correct. You asked her - 8 MR. Just do it. 8 that. She?s answered your question. 9 MR. GARCIA: Okay. LetMR. GARCIA: Even though the Government 3. 0 it on Speaker. And i am dialing (917)855-3363. 18 has her income tax returns, if she files them, i. 1. (Telephone call being made: Please leave - 1 you are you're still asserting a privilege 12 a message. At the tone please record your 1 2 on information the Government already has? 3.3 message.) 13 MR. Yes. 3. 4 BY MR. GARCIA: 1 fl BY MR. GARCIA: 3.5 Q. Were you able to hear the voice that said, 1 5 Q. Does Mr. Epstein pay you in cash or by 3. 6 "l?iease leave a message"? 1 6 check? ?a 17 A. Well, i heard what it said. 17 MR. RHEINHART: Objection to the form of l. 8 Q. All right. Do you recognize that voice? 1 8 the question. Assumes Mr. Epstein. 9 A. My lawyer has instructed me to assert my Fifth 1 9 THE WITNESS: On the instruction of my 2 0 Amendment right. 2 lawyer, i must assert my Fifth Amendment right. 2 1 Q. As to whether or not you recognize voice? 2 2 Q. What is your place of birth? 2 3 MR. Yes. 2 3 MR. Instruct the witness not 2 4 THE Yes, he has. 2 4 to answer the question. 2 5 THE VIDEOGRAPHER: And what?s the 2 5 THE 0n the instruction of my Page 328 Page 330 ii 1 good~faith basis for asserting that privilege? 1 lawyer, I must invoke my Fifth Amendment right. 2 MR. i don?t have to tell you 2 MR. How can that possibly 3 what the good?faith basis is. She?s asserting 3 incriminate her? i 4 a privilege as to whether she recognizes a 4 MR. I will answer that 5 voice or not. If you can identify the voice, 5 question when ajudge asks it to me. 6 it could potentially lead back to other places 6 MR. GARCEA: Do you have any case law that 7 that could incriminate her in theory. So, she 7 supports that question as subject to a Fifth 8 has a good faith basis to invoke it. 8 Amendment objection? 9 BY MR. GARCIA: 9 MR. RHEENHART: I'll answer the question 0 Q. Do you have a job currently? 1 0 when ajudge asks it of me. 1 1 MR. RHEINHART: instruct the witness not 3. 1 BY MR. GARCIA: fl. 2 to answer. 12 Q. Did you graduate from high school? 3.3 THE MTNESS: On the instruction of my 1 3 MR. RHEENHART: Same obiection, sarne 1 4 lawyer, I choose to assert my Fifth Amendment 1 4 instruction. 15 right. 15 THE Witness: On the advice of my lawyer, 1 6 BY MR. GARCIA: - 6 I must invoke my Fifth Amendment right. 1 7 Q. Do you file income tax returns? 1 7 BY MR. GARCIA: 1 8 MR. RHBINHART: Same instruction. - 8 Q. What states have you lived in other than 1 9 THE WITNESS: On the instruction of my 9 Florida and New York? 2 0 lawyer, I choose to assert rny Fifth Amendment 2 0 MR. RHEINHART: Same instruction. 2 1 right. 2 1 THE WITNESS: On the instruction of my 2 2 MR. GARCIA: The Government, presumably, 2 2 lawyer, I must invoke rny Fifth Amendment right. 2 3 has her income tax returns, so what is the 2 3 BY MR. GARCIA: 2 4 basis for asserting a privilege against 2 4 Q. Did you attend college? 2 self-incrimination? 2 5 MR. RHEINHART: Same instruction. 36 (Pages 327 to 33 (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (561) 832-57506 Page 331 Page 333 1 THE WITNESS: On the instruction of my 1 MR. KUVIN: So it's really kind of 2 lawyer, i must invoke my Fifth Amendment right. 2 comical, so I apologize for my laughing, but 3 BY MR. GARCIA: 3 it's just bordering 4 Q. Have you ever been to New Mexico? 4. MR. RHEINHART: Your -- 5 MR. Same instruction. 5 MR. KUVIN: -- on absurd. 6 THE WITNESS: On the instruction of my 6 MR. Look, I think most of the 7 lawyer, i must invoke my Fifth Amendment right. 7 questions that the rest of you~all asked today 8 BY MR. 8 were absurd, and we?ve answered your questions 9 Q. Do you have a passport? 9 respectfully. We didn't laugh. We didn't make 1 0 MR. RHEINHART: Same instruction. 1 0 fun of you. It is unprofessional and 1 1 THE WITNESS: On the instruction of my 1 1 disrespectful of you to laugh at the witness 1 2 lawyer, I must invoke my Fifth Amendment right. 1 2 when she's asserting a Constitutional right. 1 3 MR. GARCIA: The Government has access to 1 3 And don?t walk away from me when I?m 1 4 her passport, and you're saying that?s, you can 1 4 talking to you. 1 5 object to whether or not she has a paSSport? 1 5 MR. l'm not walking away, I?m 1 6 MR. RHEINHART: There?s lots of things 1 6 listening. I?m not walking away at all. I?m 1 '7 that there may be evidence of from other . '7 just throwing away my trash. I apologize if it 1 8 sources that she doesn't have to admit to. She 8 seemed like I was walking away. 1 9 has a Constitutional right not to admit to. 9 MR. Uh?huh, which you were. 2 0 BY MR. GARCIA: 2 0 Mr. Garcia, if you want to ask your questions, 2 i. Q. Have you ever traveled to Mexico? 2 1 you may ask them. She will answer thorn. If 2 2 MR. Same instruction. 2 2 you don?t like the questions, you can certify 2 3 THE WITNESS: On the instruction of my 23 them to the judge and I will be happy to 2 4 lawyer, i must invoke my Fifth Amendment right. 2 4 discuss with the judge whether or not there is 2 5 2 5 a good-faith basis. Page 332 Page 334 1 BY MR. GARCIA: 1 MR. GARCIA: Certify all those questions. 2 Q. Do you have a driver?s license? 2 BY MR. 3 MR. RHEINHART: Same instruction. 3 Q. Let me ask you, do you, do you deny that 4 THE WITNESS: On the instruction of my 4 you solicited a minor by the name of Jane Doe No. ii 5 lawyer, I must invoke my Fifth Amendment right. 5 for the purposes of providing sexual services to 6 BY MR. GARCIA: 6 Jeffrey Epstein? 7 Q. Do you have a driver?s license in New 7 MR. RHBINHART: Instruct the witness not 8 York? 8 to answer. 9 MR. RHEINHART: Same instruction. 9 THE WITNESS: At the instruction of my 1 0 THE WITNESS: On the instruction of my 1 0 lawyer, I must assert my Fifth Amendment right. 1 1 lawyer, I must invoke my Fifth Amendment rightMR. GARCIA: 1 2 Q. Do you deny that you solicited Jane Doc 13 Q. Are you registered to vote? 1 3 No. 2 on multiple occasions by your cellphone in 1 4 MR. RHBINHART: Same instruction. 1 4 order for her to provide sexual services for pay to 1 5 "fl-IE WITNESS: On the instruction of my 1 5 Mr. Epstein? 6 lawyer, i must invoke my Fifth Amendment right. 1 6 MR. RHEINHART: Same instruction, same 1 7 MR. Mr. Kevin, if you?d like 1 7 objection to the form previously stated. 1 8 to keep laughing, feel free. 1 8 THE WITNESS: At the instruction of my 1 9 MR. I think it's absolutely absurd 1 9 lawyer, i must invoke rny Fifth Amendment right. 2 0 that she?s objecting to some of these questions taking the Fifth to some of these questions. 2 1 Q. Do you know why Jeffrey Epstein is only 2 2 i mean, I want interested in minor girls? 2 3 is blue. 1 think she?s going to take the Filth 2 3 MR. RHEINHART: Objection to the form, 2 4 as to that question, as well. 2 4 standing objection. it assume she has some 2 5 MR. RHEINHART: Look, I, -- 2 5 knowledge of Jeffrey Epstein that's implicit in 37 (Pages 331 to 334) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-57506 a: :47 E?mi?tmw??mr m? was ii?m?ir'; statue quwn. .. my mam?? ?mam .wq-W? v: .3 mm? "ii-?M cl mam". elude". w. .mm-?h?s?i Page 335 Page 337 l. the question. 1 compelled by her parents to do anything. 2 THE WITNESS: On the instruction of my 2 Move on. I will debate the legal issues 3 lawyer, I must invoke my Fifth Amendment right. 3 with the judge, not with you. 4 BY MR. GARCIA: 4 BY MR. GARCIA: 5 Q. Do your parents approve of your 5 Q. Do you have any siblings? 6 association with Mr. Epstein? 6 MR. RHEINHART: Instruct the witness not 7 MR. Objection to the form. 7 to answer. That was also asked and answered 8 What's -- instruct the witness not to answer. 8 many hours ago. 9 THE On the instruction of my 9 THE WITNESS: On the instruction of my 1 lawyer 1 0 lawyer, i must invoke my Fifth Amendment right. 1 1 MR. GARCIA: To the form or is this some 1 1 BY MR. GARCIA: 2 constitutional issue that you're raising? . IL 2 Q. Have you ever discussed your relationship 1 3 MR. Object to the form of your 1 3 with Mr. Epstein with your siblings, assuming you 1 4 question as assuming facts that have not been 1 4 have any? 3. 5 established, and also it?s irrelevant to lead 1 5 MR. RHBINHART: instruct the witness not I. 6 to any admissible evidence. But to the extent 1 6 to answer the question. Objection to the form. 1 '7 that you're asking any questions that could I 7 THE WITNESS: At the instruction of my 1 8 relate to her parents, she is invoking the 8 lawyer, I must invoke my Fifth Amendment right. 1 9 Fifth Amendment as to that question. 1 9 BY MR. GARCIA: 2 0 THE At the instruction of my 2 0 Q. Do you have a ?ance, boyfriend, or 2 1 lawyer, I must invoke my Fifth Amendment right. 2 3.. signi?cant other? 2 2 BY MR. GARCIA: 2 2 MR. Objection to the form. 2 3 Q. How did you meet Mr. Epstein? 2 3 Instruct the witness not to answer as to the 2 4 MR. RHEIN HART: instruct the witness not 2 4 Fifth Amendment. 2 5 to answer. 2 5 I I THE WITNESS: On the instruction of my Page 336 Page 338 1 THE WITNESS: At the instruction of my 1 lawyer, i must invoke my Fifth Amendment right. 2 lawyer, i must invoke my Fifth Amendment right. 2 BY MR. GARCIA: 3 BY MR. GARCIA: 3 Q. Have you discussed your relationship with 4 Q. Did your parents know Mr. Epstein? 4 Mr. Epstein with your boyfriend, ?ance, or 5 MR. That question I think was 5 signi?cant other? 6 asked and answered several hours ago, and Fit 6 MR. Objection to the form, the 7 instruct the witness not to answer as to Fifth 7 standing objection, assumes knowledge of 8 Amendment privilege. 8 Mr. Epstein, and I will instruct her not to 9 THE WITNESS: On the instruction of my 9 answer. 1 lawyer, i must invoke my Fifth Amendment right. 1 0 THE WITNESS: On the instruction of my 3. 1 BY MR. GARCIA: lawyer, I must invoke my Fifth Amendment right. 1 2 Q. Have you ever discussed your relationship 1 2 BY MR. GARCIA: 1 3 with Mr. Epstein with your parents? 13 Q. Now, you were asked before if you visited 1 4 MR. Objection to the term. 1 4 Mr. Epstein at the County jail; is that correct, 3.5 Instruct the witness not to answer. 1 5 here in Palm Beach County? Do you recall those I 6 THE WITNESS: On the instruction of my 1 6 questions? 1 '7 lawyer, I must invoke my Fifth Amendment right. 1? A. I do recall being asked that. 3. 8 MR. GARCIA: Wouldn?t that be a waiver if 1 8 Q. All right. And did you have to ?ll out 1 9 she?s discussed it with her parents? 9 any type of leg when you visited the Palm Beach 2 0 MR. RHEINHART: Waiver of what? 2 0 County jail and provide identi?cation to the 2 1 MR. GARCIA: A waiver of any imagined or 2 1 Government as to what your name was, and provide 2 2 real Fifth Amendment right against 2 2 your name to the Government and who you were 2 3 seif~incrirnination 2 3 visiting? 2 4 MR. RHEINHART: It's only waived if it was 2 4 MR. RIIEINHART: Objection to the form 2 5 2 5 because it assumes she went to the Palm Beach a Jake? (561} compelled, and you did it anyway. She wasn?t 832~7500 1w 'smqs?? 934w 3.2 2; 3352532 mm ?sh/thither}? i .Erk?yi'r?xg- New. .vvs- ?r iv? Ma?? emu; PROSE COURT REQORTING AGENCY, 38 INC. (Pages 335 to 338) (561) 832?7506 Page 339 Page 341 1 County jail. When that question was asked 1 lawyer, i invoke my Fifth Amendment right. 2 before, she invoked her Fifth Amendment 2 BY MR. GARCIA: 3 privilege, so she's not answering the question 3 Q. Why did you go see Jeffrey Epstein at the 4 this time either. 4 County jail? 5 THE At the instruction of my 5 MR. RHEENHART: Objection to the form. It 6 lawyer, I must invoke my Fifth Amendment right. 6 assumes facts that have not been acknowledged 7 BY MR. GARCIA: 7 or admitted. instruct the witness not to 8 Q. Have you spoken to Jeffrey Epstein about 8 answer. 9 this deposition that you?re giving today? 9 THE At the instruction of my 1 0 MR. instruct the witness not 1 0 lawyer, I invoke my Fifth Amendment right. 1 to answer the question. 1 3. BY MR. GARCIA: 2 THE WITNESS: At the instruction of my 1 2 Q. Were your conversations monitored by l. 3 iawyer, i invoke my Fifth Amendment right. 1 3 anyone? 1 4 BY MR. GARCIA: 43 MR. RHBINHART: Objection to the form. It 1 5 Q. When is the last time you spoke with 1 5 assumes facts that have not been admitted or 1 6 Mr. Epstein? i. 6 acknowiedged and instruct the witness not to 17 MR. RHEINHART: instruct the witness not 3.7 answer. 1 8 to answer the question. 1 8 THE At the instruction of my 1 9 THE WITNESS: 0n the instruction of my 1 9 iawyer, I invoke my Fifth Amendment right. 2 0 lawyer, invoke my Fifth Amendment right. 2 0 BY MR. GARCIA: 2 1 BY MR. GARCIA: 2 1 Q. Let me Show you what's been filed on your 2 2 Q. Was anybody else in the room when you 2 2 behalf as an answer with af?rmative defenses. I 2 3 spoke to Mr. Epstein besides the two of you? 2 3 have some extra copies here. We'll mark her copy as 2 4 MR. RHEZNHART: Instruct the witness not . 2 4 Exhibit .2 5 to answer the question. Object to the form 2 5 THE COURT REPORTER: i5. Yes, 15. Page 340 Page 342 1 because it assumes any knowledge of 1 MR. GARCIA: What is it, 2 Mr. Epstein. 2 THE COURT REPORTER: 15, yes. 3 ?ii-IE WITNESS: At the instruction of my 3 (Plaintiff?s Exhibit No. 15 was marked for 4 lawyer, i invoke my ifth Amendment right. 4 identi?cation.) 5 BY MR. GARCIA: 5 BY MR. GARCIA: 6 Q. Where are you currently staying? 6 Q. Couid you please take a look at that 7 MR. RHEINHART: Instruct the witness not '7 document. 8 to answer. 8 A. Do you want me to read the whoie thing? 9 BY MR. GARCIA: 9 Q. No, just take a look Are you currently engaged 1 0 you if you've ever seen it before. 1 1 MR. RHBINHART: Hoid on. Hold on. Let 3. 1 MR. RHEINHART: You can answer. 1 2 her let her respond. 12 THE WITNESS: No, no. 1 3 THE WITNESS: At the instruction of my 13 BY MR. GARCIA: 4 lawyer, I invoke my Fifth Amendment right. i 4 Q. Were you aware that you were 3 Defendant 5 BY MR. GARCIA: 15 in a civil action filed by iane Doe il, in the 6 Q. Are you currently engaged in any criminal 3. 6 United States District Court, Southern District of 1 7 activity at the, wherever it is that you?re staying? 17 Florida? 1 8 MR. Object to the form in that 8 MR. You can answer that other 3. 9 it requires a legal conclusion. Second of all, i 9 than if it involves discussions, private 2 i believe it?s meant more for harassment than 2 0 discussions you had with your iawyers. 2 3. to lead to any discoverable evidence. Third of 2 1 THE WITNESS: i only would have if my 2 2 aii, she?s instructed not to answer the 2 2 lawyer told me. I don?t know for sure. 2 3 question based on her Fifth Amendment 2 3 BY MR. GARCIA: 2 4 privilege. 2 4 Q. Okay. Take a look at Page 5. Do you see 2 WITNESS: On the instruction of my 2 5 the section that begins with "Affirmative defenses?? 39 (Rages 339 to 342) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 . meshes? of: 52 *wma'i. ih?ii??iitlii-i-?Si?m??i unmade: nasm-rmmwamn:mmn met.- ides ??ai?ism Wane. MW i?l?lw?i? ?Ki. - grandam Page 343' Page 345 ??m?mihdah?h?m tuieHWm-mssaetememimaanm r. maxim-manna catamarans Eliswa Maths 0 Loan humidi?er. . :??lSiiXi -. - batsmen.? namramxam seam Imam wmaemmnaa-v 't i. A. Uh-huh. Yes. 1 BY MR. GARCEA: 2 Q. Do you have any evidence to support the 2 Q. Did you have any conversations with 3 first affirmative defense, and i'll tell you for the 3 Jane Doe No. ii at any time in which she told you 4 record that Jane Doe i1, is Jane Doc No. Ii, was a 4 that she was a, she consented and was a willing 5 willing participant in the acts alleged, and 5 participant in the acts that are alleged in the 6 therefore her claims are barred or her damages are 6 complaint with Jeffrey Epstein? 7 required to he reduced accordingly? 7 MR. RHEENHART: Object to the form because 8 MR. RHEINHART: I?m sorry. Can you repeat 8 it assumes knowledge of Jane Doe No. ll. And 9 the question that you're asking? 9 the witness is going to her invoke her Fifth 1 0 MR. GARCIA: Can you read it back? 1 0 Amendment privilege as to any evidence or any 1 (The requested portion of the record was 1 1 knowledge of Jane Doe No. II. 1 2 read by the reporter.) 1.2 THE WITNESS: At the instruction of my 3. 3 BY MR. GARCIA: 1 3 lawyer, i must invoke my Fifth Amendment right. 1 4 Q. Do you have any evidence to support that 4 BY MR. GARCIA: 5 affirmative defense? 15 Q. The second af?rmative defense on the same 1 6 A. i don't understand the question. 1 6 page it says, "As to i?laintiff?s claim, Plaintiff 1 '7 Q. Okay. ?l?his affirmative defense alleges on 17 actually consented to and participated in conduct 1 8 your behalf by Mr. Rheinhart claims that Jane Doe 8 similar and are identical to the acts alleged with 1 9 No. ii consented to and was a willing participant in 1 9 other persons which were the sole or contributing 2 the acts alleged, and therefore her claims were 2 0 cause of Plaintiff?s alleged damages." 2 1 barred or her damages were required to be reduced. 2 1 Do you have any facts to support the 2 2 Do you have any factual basis for 2 2 second affirmative defense? 2 3 asserting that defense, and if so, what facts do you 2 3 MR. And once again to the 2 4 have to support it? 2 4 extent that, the, the question object to the 2 5 MR. RHEINHART: Do you understand the 2 5 form to the extent the question requires her to Page 344 Page 346 1 question? 1 acknowledge any knowledge of lane Doc No. II or 2 Uh?uh. 2 Jane Doc No. ii's activities she would invoke 3 THE COURT REPORTER: is that a yes? 3 her Fifth Amendment privilege. I would 4 THE WETNESS: Yes, sorry. 4 instruct her to do so. 5 MR. RHEINHART: You can answer if you can 5 THE WITNESS: On the instruction of my 6 answer. 6 lawyer, must invoke my Fifth Amendment right. 7 THE I'm sorry. Do I have any 7 BY MR. GARCIA: 8 facts. 8 Q. So i don't waste any time with the court 9 BY MR. 9 on these issues, can you tell me at least a yes or 1 Q. Right. What, what evidence do you have to 3. 0 no as to whether or not you have any facts to 1 support the claim that Jane Doc No. Ii consented to 1 1 support, without telling me what the facts are, 2 and was a willing participant with leffrey Epstein 12 whether or not you have any facts to support the 3 in the acts described in the complaint? 1 3 defenses? 14 MR. RHEINHART: I am just consulting on 1 4 MR. RHEINHART: Whether she personally 1 5 what might be a privilege issue. 1 5 does? 1 6 (A discussion was held off the record.) 1 6 MR. Yes, exactly, personally. 1 7 MR. RHEINHART: A portion 'of the truth of 17 MR. or has her defense team 3. 8 that would require attorney?client privilege I 8 acting on her behalf? 1 9 information, so I am going to instruct her not 1 9 MR. GARCIA: No, just personally. 2 0 to answer that portion of it, and ask that going to instruct 2 1 MR. GARCIA: Okay. 2 it her not to answer based on her Fifth Amendment. 2 2 MR. RHEINHART: Hold it. Okaythe rest, i?ll instruct her not to answer the 2 3 Q. Do you have any information to support 2 4 question based on her Fifth Amendment 2 4 the, any facts to support the third affirmative 2 5 privilege. 2 5 defense that the Plaintiff impliedly consented to 40 (Pages 343 to 346) (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 347 Page 349 'ii 1 the acts alleged by not objecting, and therefore her 1 page? 2 claims are barred or her damages are required to be 2 A. What page, sir? 3 reduced accordingly? 3 Q. Page 6. It says, ?As to Plaintiff's 4 MR. RHEINKART: Once again I would assert 4 claim, Defendant reasonably, reasonably believed or 5 an attorney-client privilege as to this, 5 was told that the Plaintiff had attained the age of 6 this question that you have asked requires a 6 l8 years old at the time of the alleged acts." 7 legal conclusion which would require her to 7 Who told you that the Plaintiff was ?8 at 8 MR. I?m not asking for the legal 8 the time of the acts involved in this case? 9 conclusion. I'm asking what facts she has to 9 MR. Again, I would instruct 1 0 support an affirmative defense which requires 1 the witness not to answer the question based on 1 you to put on evidence of what that defense is. 1 both the attorney~client privilege and her 12 MR. RHEINI-IART: Right. But you're asking 2 Fifth Amendment privilege against 1 3 her what evidence she has of legal conclusions, 1 3 self-incrimination. 1 4 which is concepts such as consent, claims being 1 4 TEE WITNESS: At my lawyer?s instruction, 1 5 barred, damages required to be reduced 1 5 I must assert my Fifth Amendment right. 1 6 accordingly, those are legal concepts you?re 1 6 BY MR. GARCIA: 3.7 asking her to make, a lay person to give a Q. At the time that lane Doc No. ll was 1 8 statement as to what the factual evidence is 1 8 involved in some sort of a relationship, if you can 1 9 there to support a legal conclusion. ?fhe only 1 9 call it that, with Mr. Epstein, did you have 2 0 way she would know if they support the legal 2 counsel? Did you have a lawyer representing you? 2 conclusion is based on conversations she's had 2 1 MR. RHEINHART: Object to the form. 2 2 with counsel. 2 2 She the question assumes that there is any 2 3 W. GARCIA: So, are you instructing her 2 3 knowledge of any relationship between lane Doe 2 4 not to answer on that basis person named Mr. Epstein. She's 2 5 MR. Yes, that's right, yeah. 2 5 not going to answer the question based on the Page 348 Page 358 1 MR. GARCIA: the Fifth Amendment 1 Fifth Amendment. 2 privilege? 2 THE WITNESS: At the instruction of my 3 MR. On, on that basis only. 3 lawyer, I assert my Fifth Amendment right. 4 As to that question I am instructing her not to 4 BY MR. GARCIA: 5 answer on the basis of the attorney-client 5 Q. Did'lane Doc No. ll ever tell you that she 6 privilege. 6 was l8 at the time of the alleged acts? '7 BY MR. 7 MR. RHEINHART: Object to the form. 8 Q. Outside of your discussions with ecunsel, 8 Instruct the witness not to answer based on the 9 do you have any facts to support the third 9 ifth Amendment. 1 0 affirmative defense based upon your discussions with 1 0 THE On the instruction of my 1 1 lane Doe No. ll or discussions with any other person 3. lawyer, I assert rny Fifth Amendment right. 1 2 or review independently of your counsel of any 12 BY MR. GARCIA: 1 3 document that would support this third affmnative 1 3 Q. I think the Fifth Af?nnative Defense is 4 defense? 1 4 pretty much similar, but it says, "As to Plaintiffs 1 5 MR. Object to the form to the 1 5 claim, Plaintiff's claims are barred as she said she 6 extent that it requires any acknowledgment of 6 was 18 years or older at the time, end quote. I 1 '7 any knowledge of Jane Doe No. II, 1 would 1 7 assume that you?re referring to yourself; she told 1 8 instruct her not to answer the question based 1 8 you that She was 18 years old at the time? 1 9 on the Fifth Amendment. 1 9 MR. RHEINHART: Instruct the witness not 2 0 THE WITNESS: Upon rny lawyer's 2 to answer based on her Fifth Amendment 2 1 instruction, 1 choose to exert my Fifth 2 privilege. 3% 2 2 Amendment rightMR. GARCLA: 2 3 Q. Do you have any evidence to support that 2 4 Q. The fourth af?rmative defense on Page 6 2 4 assertion; that is did you make any journal 2 5 of Exhibit 15, could you turn to that on the next 2 5 entries ?7 by the way, do you keep any type of 41 (Pages 347 to 350) (561) 832*7500 PROSE COURT REPORTING AGENCY, ENC. (561) 832-57506 Page 351 Page 353 3. journal or diary? 1 BY MR. GARCIA: 2 MR. RHEINHART: Instruct the witness not 2 Q. l'tn going to give you some dates here. if 3 to answer based on the Fifth Amendment. 3 you want to, i don?t know if he wants to write them 4 BY MR. GARCIA: 4 down or take them one at a time: June 16th, 2003; 5 Q. Have you ever kept 5 July 2nd, 2003; April 9th, 2004; lune 7th, 2004; 6 MR. Hold on, please. Let her, 6 July 30th, 2004; August 30th, 2004; October 9th, 7 let her answer. '7 2004; October 12th, 2004; October 30th, 2004; and 8 THE WITNESS: On the instruction of my 8 November 9th, 2004. Do you recall soliciting Jane 9 lawyer, I assert my Fifth Amendment right. 9 Doe No. Ii to come to Jeffrey Epstein's home on any 1 0 BY MR. GARCIA: 1 of those dates? 1 1 Q. Have you ever kept a journal or diary in 1 1 MR. RHEINEMRT: Objection to the form. 1 2 the past? 2 Standing objection as previously stated as to 1 3 MR. RHEINHART: Same instruction. 1 3 any knowledge of Jeffrey Epstein or lane Doc 1 4 THE WITNESS: At the instruction of my 1 4 No. Ii, and instruct the witness not to answer. 15 lawyer, I assert my Fifth Amendment right. 1 5 THE On the instruction -- 1 6 BY MR. GARCIA: 6 MR. GARCIA: Okay. So your instruction is 1 7 Q. As to the sixth affinnative defense, what 1 '7 not based on Fifth Amendment? 1 8 evidence do you have that Plaintiffs alleged instructing 1 9 damages were caused in whole or in part by events 1 9 her not to answer based on Fifth Amendment. 2 0 and/ or circumstances completely unrelated to the 2 0 THE On the instruction that, i would assert 2 2 right. 2 3 an attorney?client privilege. 2 3 BY MR. GARCEA: 2 4 BY MR. GARCIA: 2 4 Q. Do you contest, in any way, that Jane Doc 2 5 Q. Well, do you have a witness that you can 2 5 No. was solicited by you on each of these dates Page 352- Page 354 3. identify that will testify about this? 1 for the purposes of providing Jeffrey Epstein with 2 MR. RHEINHART: Instruct the witness not 2 sexual massages and/or services. 3 to answer that based on the Fifth Amendment 3 MR. Objection to form. its a 4 privilege. She doesn?t have to help you. 4 compound question. It assumes facts that she's 5 THE WITNESS: On the instruction of my 5 not acknowledged or admitted. It is therefore 6 lawyer, I exert my Fifth Amendment right. 6 compound and ambiguous. I would instruct her 7 MR. GARCIA: All right. So your position '7 not to answer based on her Fifth Amendment 8 is that you don't have to answer any questions 8 privilege. 9 about affirmative defensesMR. GARCEA: 1 maintain them? 1 0 Q. Where did you live in 2003? 1 1 MR. RHBINHART: That?s not what i said. 1 1. MR. Instruct the witness not 1 2 You asked to identify a particular witness. If 12 to answer based on the Fifth Amendment. 1 3 identifying a witness could potentially lead to 1 3 THE WITNESS: At the instruction of my 1 4 putting herself in jeopardy for criminal 1 4 lawyer, I must exercise my Fifth Amendment 2 ES prosecution, she doesn?t have to answer. 3. 35 right. 1 6 MR. GARCIA: This would be a witness that 3. 6 BY MR. GARCIA: 1 7 would support her defense, not, not cause her 17 Q. What cellphone number did you have in 1 8 criminal prosecution. 1 8 2003? 1 9 MR. RHEINHART: I, i understand your 1 9 MR. RHEINHART: Same instruction. 2 0 point, and my point is if identifying such a 2 0 THE WITNESS: At the instruction of my 2 1 witness could also lead her potentially to 2 1 lawyer I must exert my Fifth Amendment right. 2 2 criminal prosecution by the Government, she 2 2 BY MR. GARCIA: 2 3 doesn't have to answer that question and she's 2 3 Q. Where did yon live in 2004? 2 4 not going to. Witnesses can have many factual 2 4 MR. RHEINHART: Same instruction. 2 purposes. 2 THE WITNESS: At the instruction of my 2 42 (Pages 351 to 354) (561) 832*7500 PROSE COURT REPORTING AGENCY, ENC. (563.) 832*7506 .5: WMKWEMW - use; a teat-mars:- ?awless augment S?mim?MW- i 2'26}: L: mega-smart: its care: Page 355 Page 357 1 lawyer I must exercise my Fifth Amendment 1 BY MR. GARCIA: 2 right. 2 Q. There was some doctor that was -- you were 3 BY MR. GARCIA: 3 asked about earlier today. Do you recail his name? 4 Q. What cellphone number did you have in 4 MR. RHEINHART: The name that was asked of 5 2004? 5 her? if you remember -- 6 MR. RHEINHART: Same instruction. 6 MR. KUVIN: it?s Dr. 7 THE WITNESS: At the instruction of my 7 MR. oomsnnoaa: Feelgood? 8 lawyer [just exercise my Fifth Amendment 8 MR. KUVIN: No, that?s your doctor, Jack. 9 right. 9 Dr. hang on. ['11 get it for you. 0 BY MR. GARCIA: 1 0 MS. EZBLL: Bard, it was Bard. 3. 1 Q. Where did you ?rst recruit Jane Doe 1 1 MR. Bard, B-a?r?d, i believe. 1 2 No. II for soliciting her to provide sexual services 1 2 MR. GARCIA: Dr. Bard. I think that's 13 to Jeffrey Epstein? 3. 3 right. 1 4 MR. Objection to the form. 3. 4 BY MR. GARCIA: 3. 5 Standing objection previously stated. instruct 1 5 Q. Do you know a Dr. Bard? it: 3. 6 the witness not to answer based on her Fifth 3. 6 THE WETNESS: At the instruction of my 17 Amendment. 1 7 lawyer, I choose to exercise my Fifth Amendment 1 8 THE WITNESS: At the instruction of my 1 8 right. 3. 9 lawyer I must exercise my Fifth Amendment 3. 9 BY MR. GARCIA: 2 0 right. 2 8 Q. Did Dr. Bard ever provide any type of 2 1 BY MR. GARCIA: 2 1 dental services to youclubs where young women hung 2 2 MR. Objection to the form. It 2 3 out and approach them in order to solicit them for 2 3 assumes facts that have not been established 2 4 Mr. Epstein? 2 4 that she's ever seen by Dr. Bard. So, once 2 5 MR. Objection to the form. It 2 5 again, we assert a Fifth Amendment privilege. Page 356 Page 358 1 assumes knowledge of Mr. Epstein, therefore i WITNESS: At the instruction of my 2 instruct the witness not to answer based on the 2 lawyer, I must exercise my Fifth Amendment 3 Fifth Amendment privilege. 3 right. 4 THE WITNESS: At the instruction of my 4 BY MR. GARCIA: 5 lawyer, I must exercise my Fifth Amendment 5 Q. Have you ever had any dental work done in 6 right. 6 the past ten years? And I don?t mean cavities. I?m 7 BY MR. GARCIA: 7 taiking about cosmetic-type dental work. 8 Q. Did you ever pay Stone Doe No. II for 8 A. Yes, sir. i 9 sexual services and/or sexual massages provided to 9 Q. Ah right. What state was it in? 1. 0 Mr. Epstein? 8 MR. RHEINI-IART: One second. 3. 1 MR. RI-IEINHART: Objection to the form for 3. 1 MR. GOLDBERGER: Excuse me. 1 2 the reasons previously stated in the standing 12 MR. You can answer. You can 13 objection. instruct the witness not to answer, 1 3 answer as to what state it occurred. 4 based on the Fifth Amendment. 1 4 THE WITNESS: In New York. 5 THE WITNESS: On the instruction of my 1 5 BY MR. GARCIA: 6 lawyer, I choose to exercise my Fifth Amendment 1 6 Q. Was the dental work paid for by anyone 1 7 right. 1 "7 other than yourseif?? 1 8 BY MR. GARCIA: 8 MR. Instruct the witness not 9 Q. Did you pay in US. currency? 1 9 to answer based on the Fifth Amendment 3 2 8 MR. RHEINHART: Same objection, same 2 privilege. 2 It instruction. 2 1 THE WITNESS: At the instruction of my 22 THE WITNESS: On the instruction of my 2 2 lawyer, I must assert my Fifth Amendment right. - .2 3 lawyer, i choose to exercise my Fifth Amendment 2 3 BY MR. GARCIA: 2 4 right. 2 4 Q. What was the name of the doctor that 2 5 2 5 provided the cosmetic dental services? 43 (Pages 355 to 358) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Page 359 Page 361 the whims in; 1 MR. You can answer. Sony, 1 any type of surgical procedure performed on his 2 wait a minute. 2 penis? 3 Instruct the witness not to answer the 3 MR. Objection to the form to 4 question based on the Fifth Amendment. 4 the extent it assumes any knowiedge of 5 BY MR. GARCIA: 8 Mr. Epstein and instruct the witness not to 6 Q. Did Jeffrey Epstein - 6 answer. 7 MR. RHEINIIART: Hoid on. You have to let 7 WITNESS: On the instruction of my 8 her assert her privilege. 8 lawyer, I must invoke my Fifth Amendment right. 9 THE WITNESS: At the instruction of my 9 BY MR. GARCIA: 1 0 Iawyer, i must assert my Fifth Amendment right. 1 Q. Has he ever toid you that he?s ever had a 1 1 BY MR. GARCIA: 3. It penile irnpiant added to his penis? 3. 2 Q. Did Jeffrey Epstein suggest that you get 22 MR. RHEINHART: Sarne instruction, same 3. 3 the dentai work done? 13 objection. i. 4 MR. RHEINI-IART: Instruct the witness not I. 4 THE WITNESS: On the instruction of my 3. 5 to answer. Objection to the form, instruct the 3.5 iawyer, I must invoke my Fifth Amendment right. 1 6 witness not to answer. 1 6 BY MR. GARCIA: 7 THE On the instruction of my 17 Q. Has Mr. Epstein have you ever observed 1 8 iawyer, i must assert my Fifth Amendment right. 1 8 Mr. Epstein or has he ever told you that he takes 1 9 BY MR. GARCIA: 9 Viagra or Ciaiis? 2 8 Q. Do you know Kevin Spacey? 2 0 MR. RHEINHART: Objection to the form. 2 1 MR. Are you asking if she?s 2 3. Standing objection. It assumes knowledge of 2 2 ever met Kevin Spacey? 22 Mr. Epstein, and therefore I wouid instruct the 2 3 MR. GARCIA: Yes, I?m sorry. 2 3 witness not to answer. 2 4 MR. KUVIN: There you go. I 2 4 THE WITNESS: On the instruction of my 2 5 MR. Instruct the witness not 2 5 lawyer, I must invoke my Fifth Amendment right. Page 360. Page 362 to answer the question. 1 BY MR. GARCIA: 2 THE WITNESS: At the instruction of my 2 Q. Did you ever meet Lewis or Dorothy 3 iawyer, I must invoke my Fifth Amendment right. 3 Culiman, C~u~iui~rn~a~n? 4 BY MR. GARCIA: 4 MR. GARCIA: I think the look means that 5 Q. Did you ever met Chris Tucker? 5 she's going to object. 6 MR. RHEINHART: Sarne instruction. 6 MR. Are you asking I just 7 THE WITNESS: At the instruction of my '7 want to ciarify the question. Are you asking 8 lawyer I must invoke my Fifth Amendment 8 if she has ever met a person she knows to have 9 privilege. 9 that name or if she's ever -- 0 BY MR. GARCIA: 8 MR. GARCIA: Yes. 1 1 Q. Did you ever meet Bill Clinton? . 1 MR. RHEINILART: You can answer the 12 MR. RIIEINHART: Same instruction. 12 question. 13 THE WITNESS: On the instruction of my 1 3 THE WITNESS: No. it 4 Iawyer, i must invoke my Fifth Amendment right. I 4 MR. GARCIA: There were two people, Lewis, It 5 BY MR. GARCIA: 3.5 L?e?w?i-s, and Dorothy Culiman. 6 Q. Did you ever ?y with these three Ii. 6 MR. So it's Spiit it in two 1 7 gentlemen and Jeffrey Epstein to Africa on Ieffrey 1 7 questions. Do Lewis ?rst and Dorothy second. 1 8 Epstein?s 727 airplane? 8 Have you met Lewis? 1 9 MR. Objection to the form. 1 9 THE WITNESS: No. 2 0 It?s a compound question. Instruct the witness 2 0 MR. RHEINIIART: Dorothy? 2 1 not to answer based on the Fifth Amendment. 2 1 THE WITNESS: No. 2 2 THE WITNESS: At the instruction of my 2 2 BY MR. GARCIA: 2 3 iawyer, I must invoke my Fifth Amendment right. 2 3 Q. Have you had any other type of cosmetic 2 4 BY MR. GARCIA: 2 4 surgery other than the dental surgery that you 2 Q. Has Mr. Epstein ever told you that he had 2 5 talked about? 44 (Pages 359 to 362) (561) 832?7500 PROBE COURT REPORTING AGENCY, INC. (561) 832-37506 1mm it?d-?35" "mm? heist}: .Ei. NM saunas; Page 363 Page 365 1 MR. RHEINHART: What m? we?re getting, 1 Fifth Amendment on who this dentist was? 2 we're getting into personal privacy issues 2 MR. RHEINHART: Yes, she did. 3 herelittle foundation 3 BY MR. GARCIA: 4 for why that?s relevant? 4 Q. Do you have a Facebook page? 5 MR. GARCIA: {don't think i have to 5 A. No. 6 reveal that to you, but i would proffer this, 6 Q. Have you ever had one? 7 that if Mr. Epstein paid for it, it might lead 7 A. I may have started one, but I, for like ten 8 to perhaps bias on the part of the witness. 8 minutes. 3 9 MR. RHEENHART: Welt, why don?t you ask it 9 Q. You started one for ten minutes. Did you 1 that way? She's ever had any surgery that was 1 0 turn it off after ten minutes? 3. paid for by Mr. Epstein or otherwise funded by 3. 3. A. Yes. 3. 2 Mr. Epstein. 3. 2 Q. What year was this? 3i 3 MR. On behalf of the other -- on 3. 3 A. don?t remember. 1 4 behalf of the other Plaintiffs as well, i would 1 4 Q. What prompted you to turn it of? after ten 15 say that for identi?cation purposes it becomes 2 5 minutes? 3. 6 imperative if some of the other girls have 1 6 A. i think; it's a stupid site. l7 alleged, as they have in their complaints that 3. 7 Q. How about a is it called MyFace or 8 they saw Ms. Kellen when they arrived at the 1 8 MySpace? Sorry. MySpace. i. 9 home if she?s changed her physical appearance, 1 9 MR. It's not YourFace, sorry, Sid. 2 at the date that we go to trial, i believe that 2 0 MR. GARCIA: Trust me, you don't want to 2 3. any cosmetic surgery she has might be relevant 2 1 get that on there. 2 2 to the case. 22 BY MR. GARCIA: 2 3 MR. I understand. I 2 3 Q. How about a MySpace page, have you ever 2 4 understand. Hold on one secondthose? 2 5 go ahead and ask. 2 5 A. No. Page 364 Page 366 1 BY MR. GARCIA: 1 Q. No. what, what name did you use on the 2 Q. Okay. Have you ever had any other type of 2 Facehook page? 3 cosmetic surgery that was ?nanced by Mr. Epstein? 3 A. I don't remember. 4 MR. RHEINHART: Objection to the form in 4 Q. Did Jeffrey Epstein suggest that wouldn?t 5 that it assumes Mr. Epstein, any knowledge of 5 be such a good idea? 6 Mr. Epstein. But if you want to ask her go 6 MR. RHEENHART: Objection to the form. ?7 ahead and ask her the general question, has she 7 Standing objection. Instruct the witness not 8 ever had it done by anybody, paid by anybody. 8 to answer based on Fifth Amendment. 9 MR. GARCIA: All right. 9 THE At the advice of my lawyer, 1 0 BY MR. GARCIA: i must invoke my Fifth Amendment right. 1 Q. Have you ever had any other cosmetic 1 BY MR. GARCIA: 3. 2 surgery? 1 2 Q. Where were you when you set up a Facebook l. 3 A. No. 13 page for about ten minutes? i 4 Q. What type of dental procedure did you have 1 4 MR. Objection to the form. 1 5 done? 1 5 Sorry. instruct the witness not to answer, 1 6 A, Invisalign, 6 based on the Fifth Amendment. 1 7 Q, And what is that? 7 THE WITNESS: At the instruction of my 8 A. Straightens your teeth. 1 8 lawyer, I must invoke my Fifth Amendment right. 1 9 Q. is it something that you wear? 1 9 BY MR. GARCIA: 2 A. Sometimes. Not all the time. 2 Q. Do you know who Max Brochman, 2 1 Q. You?re still wearing it today? 2 B?r~o~c~k~m~a?MR. instruct the witness not 2 3 Q. And what year was the dental process done? 2 3 to answer based on the Fifth Amendment. '3 2 a A. Staged two years ago, 2 4 THE WITNESS: At the instruction of my 2 5 MR. GARCIA: I'm sorry. Did you take the 2 5 lawyer, I must invoke my Fifth Amendment right. 45 (Pages 363 to 366) (561) 832-7500 PROBE COURT REPORTING AGENCY, INC. (561) 832*7506 a amraawmm - gamma-rams" remu- Ww?wzmoemeewmwm ataammiaum? w. WW . View. 'i?i?li?fa?ad? .i Page 367 Page 369 1 BY MR. GARCIA: 3. lawyer, I must invoke rny Fifth Amendment right. 2 Q. Do you know who Cindy Lopez is? 2 BY MR. GARCIA: 3 MR. RHEINHART: Same instruction. 3 Q. Were you home schooled by your parents or 4 THE WITNESS: At the instruction of my 4 one of your parents, or someone else? 5 lawyer, I must invoke my Filth Amendment right. 5 A. Myself. 6 BY MR. GARCIA: 6 Q. Do you know what the name of the program 7 Q. Do you hold any professional licenses 7 was that authorized you to home school yourself? 8 issued by any, any state? 8 MR. instruct the witness not 9 MR. RHEINHART: Hold on a second. You can 9 to answer based on the Fifth Amendm?t. 1 0 answer. 0 THE On the advice of my counsel, 3. 1 THE WITNESS: No. 1 i must invoke my Fifth Amendment right. 12 BY MR. GARCIA: 12 BY MR. GARCIA: 3 Q. Have you ever held a professional license? 3 Q. i-Iave you ever been a licensed masseuseyou have any degrees? 1. 5 Q. Have you ever taken any courses to become 1 6 A. No. Well -- 6 a licensed masseuse? 17 Q. Well I?m sorry, go aheadCollege degrees 3 1 8 Q. Have you applied for any licenses and been 1 9 Q. Any type of degree, high school, college. - 9 turned down for same? 2 A. have a high school degreeAnd what year did you receive that degree? 2 1 Q. Do you have any facts to deny that 2 2 A. l?rn really bad with years. I can?t say for 2 2 Mr. Epstein digitally penetrated .iane Doc No. ii on 2 3 sure. 2 3 each of the about ten occasions that I listed before 2 4 Q. Okay. And what high school did you 2 for you? 2 5 receive it from? 2 5 MR. Objection to the form of Page 368. Page 3702 1 MR. RHEINHART: Instruct the witness not 1 the question in that it assumes knowledge of 2 to answer based on Fifth Amendment. 2 Mr. Epstein and Ms. Doe No. iI. It's a 3 THE On the instruction of my 3 compound question. It?s ambiguous. And I 4 lawyer, I must invoke my Fifth Amendment right. 4 instruct the witness not to answer based on the 5 BY MR. GARCIA: 5 Fifth Amendment. 6 Q. Were you associated with Mr. Epstein at 6 THE WITNESS: On the instruction of my '7 the time that you attended high school? 7 lawyer, i must exercise rny Fifth Amendment 8 MR. Objection to the form. 8 right. 9 Standing objection. instruct the witness not 9 BY MR. GARCIA: 3. 0 to answer. 1 Q. Did you know that Mr. Epstein would 1 1 THE WITNESS: At the instruction of my 1 1 digitally penetrate Jane Doe No. II prior to 3.2 lawyer, I must invoice my Fifth Amendment right. 12 soliciting her for massages of Mr. Epstein? 3 BY MR. GARCIA: 13 MR. RHEINHART: Same objection as stated 4 Q. Was it a public or private high school? 3. 4 to the previous question, the standing 1 5 MR. RI-IBINI-IART: You can answer that. 15 objection to form and instruct the witness not 1 6 THE) WITNESS: It was home school. 3. 6 to answerBut you still got a degree from some 1 8 MR. Hold on. 1 9 entity; is that correct? 1 9 THE WITNESS: On the instruction of my 2 0 A. Yes. 2 lawyer, I must invoke my Fifth Amendment right. 2 1 Q. What was the entity that issued you a 2 1 BY MR. GARCIA: 2 2 degree? 2 2 Q. Did you discuss what type of activities 2 3 MR. Instruct the witness not 2 3 Mr. Epstein would engage in with Jane Doc No. Ii 2 4 to answer based on the Fifth Amendment. 2 4 prior to soliciting her for massages and sexual play 2 5 THE On the instruction of rn 2 5 with Mr. Epstein? 46 (Pages 367 to 370) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (563.) 832*7506 Page 371 Page 373 2M5 12?? am?mrrm'm Wm catamarans-an. 1 MR. RHEWHART: Object to the form of the 1 lawyer, I invoke my Fifth Amendment right. 2 question as ambiguous and standing objection as 2 BY MR. GARCIA: 3 well. instruct the witness not to answerautomobile? 4 WITNESS: On the instruction of my 4 MR. RHEINHART: Same instruction. 5 lawyer, i must invoke my Fifth Amendment right. - 5 THE WITNESS: On the instruction of my 6 BY MR. GARCIA: 6 lawyer, i invoke my Fifth Amendment right. 7 Q. Did Mr. Epstein ever tell you that he had 7 BY MR. GARCIA: 8 sought out or treatment 8 Q. Who paid for your automobile? 9 for any reason? 9 MR. RHEINHART: Same instruction. 1 0 MR. RHEINHART: instruct the witness not 1 0 THE WITNESS: On the instruction of my 1. 3. to answer based on the standing objection. 1 1 lawyer, I invoke my Fifth Amendment. 12 Objection to form. 12 BY MR. GARCIA: 1 3 THE On the instruction of my 1 3 Q. Has Jeffrey Epstein ever purchased an 1 4 lawyer, I must invoke my Fifth Amendment right. 1 4 automobile for you? 15 BY MR. GARCIA: 5 MR. RHEINHART: Objection to the form 1 6 Q. Have you ever received any paychecks from 1 6 based upon the standing objection and instruct 3. 7 any enterprise associated or controlled by Jeffrey 7 the witness not to answer. 1 8 Epstein? 1 8 THE WITNESS: On the instruction of my 9 MR. Objection to the form, the - 9 lawyer, invoke my Fifth Amendment right. 2 0 standing objection. Instruct the witness not - 2 0 BY MR. GARCIA: 2 to answer. 2 1 Q. What limousine service THE WITNESS: At the instruction of my 2 2 York when you move ?'om place to place? 2 3' lawyer, i must invoke my Fifth Amendment right. 2 3 MR. RHEINHART: Same instruction. 2 4 BY MR. GARCZA: 2 4 THE WITNESS: On the instruction home or some sort of a condo lawyer, I invoke my Fifth Amendment right. Page 372 Page 374 1 or anything like that? 1 BY MR. GARCEA: 2 MR. instruct the witness not 2 Q. Who pays for your limousine service? 3 to answer based on the Fifth Amendment 3 MR. Same instruction. 4 privilege. 4 WITNESS: On the instruction of my 5 THE On the instruction of my 5 lawyer, invoke my Fifth Amendment right. 6 lawyer, I must invoke my Fifth Amendment right. 6 BY MR. 7 BY MR. GARCIA: 7 Q. How do you spend your typical day in New 8 Q. Do you pay rent to any landlord? 8 York? 9 MR. RHEINHART: Same instruction. - 9 MR. RHEINHART: instruct the witness not 1 0 THE WETNESS: On the instruction of my 1 to answer based on the Fifth Amendment. Also 1 3. lawyer, I must invoke my Fifth Amendment right. 1 objection to the form as to what's a typical 12 BY MR. GARCIA: 1 2 day. 3 Q. The place where you live, who owns it? 1 3 BY MR. 4 MR. RHEINHART: Same instruction. 1 4 Q. Monday through Friday, typicai work hours, 1 5 THE WITNESS: At the instruction of my 15 say 9:00 to 5:00, what do you typicaiiy do Monday 1 6 lawyer, I must invoke my Fifth Amendment right. 1 6 through Friday, 9:00 to 5:00 p.rn.? 1 '7 BY MR. 17 MR. RHEINHART: instruct the witness not 1 8 Q. Do you exit a building in New York where 1 8 to answer based on the Fifth Amendment. 1 9 you exit from a different building's parking garage; 1 9 THE WITNESS: At the instruction of my 2 0 in other words, do you exit strike that. 2 0 lawyer, i must invoke my Fifth Amendment rightdifferent parking garage to 2 1 BY MR. GARCIA: 2 2 exit the, from the building where you live? 2 2 Q. What is Financial Trust Company? 2 3 MR. RHEINHART: Instruct the witness not 2 3 MR. Instruct the witness not 2 4 to answer based on the Fifth Amendment. 2 4 to answer based on the Fifth Amendment. 2 5 THE WITNESS: On the instruction of my 2 5 THE WITNESS: At the instruction of my 47 (Pages 371 to 374) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Page 3 7 5 ii 1 lawyer, I must invoke my Fifth Amendment right. 2 MR. GARCIA: Fm just asking what it is. 3 MR. RHEINHART: Understood. 4 BY MR. GARCIA: 5 Q. Well, Eet me not waste any time. Do you 6 know what it is, yes or no? 7 MR. instruct the Witness not 8 to answer based on the Fifth Amendment. 9 THE WITNESS: At the instruction of my 1 a lawyer, I invoke my Fifth Amendment right. 1 3. BY MR. GARCIA: 12 Q. Has feffrey Epstein ever told you that he 3 is a government witness, otherwise known as a 4 snitch, or con?dentiai informant? 15 MR. RHEINHART: Objection to the form in 6 that it assumes knowiedge of Mr. Epstein. 1 7 Instruct the witness not to answer. 1 8 THE WITNESS: On the instruction of my 9 iawyer, I invoke my Fifth Amendment right. 2 0 BY MR. GARCIA: 2 1 Q. Has he ever toid you that he is invoived 2 2 in a case invoiving, providing information 2 3 concerning money iaundering? 2 4 MR. RHEINHART: Same objection and same 2 5 instruction. Page 376 1 THE WIMESS: At the instruction of my 2 iawyer, I must invoke my Fi?h Amendment right. 3 MR. GARCIA: That?s i have. Thank 4 you. 5 MR. RHEENHART: Great. ShouEd we take a 6 break? i know you need to change the tape as 7 W811. 8 me Yes. We?re now going 9 off the record. It is 5:18 pm. 1 (A brief recess was held(Pages 375 to 376} (561) 832-7500 PROBE COURT REPORTING AGENCY, INC. (561) 832-57506 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. - ?92.1mm: JANE DOE NO. 2, Plaintiff, ?rem-2 VOLUME OF IJEFFREY EPSTEIN, rw'va-m Defendant. Related oases: 08*80232, 08*08380, 08~80381, 08+80994 08*80993, 08w8081l, 08*80893, 09*80469 09*80591, 09*80656, 09*80802, 09*81092 4.. . VIDEOTQPED DEPOSITION OF SARAH KELLEN war/m? Wednesday, March 24, 2010 10:37 6:51 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 awn? om ?vw'?vlw?o- :?vwm ?ght? - A?rl-?i?i??k?i i?k?xi 31% 2.63: ?exemeze i-Z-Iud?eTi-w??i?li 12-522223 =23: {$32 322% ?35 $22 at: (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronicatly signed by Rachei Bridge (201-2726174627) IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. AD 'a'mim ?W?c?wmgu W034: Plaintiff, VOLUME OF JEFFREY EPSTEIN, Defendant. .. .M-vw MM. VIDEOTAPED DEPOSITION OF SARAH KELLEN ?mvu?m: NM. wm.?.mm Mm. my. Wednesday, March 24, 2010 10:37 6:51 p.m. (?my Iva-w .M m. .u 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 m: ?My-v Reported By: Rachel W. Bridge, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 Mawk-?aizmem - - - - A9 . 3 .. {5:15.355 8 mats-.5 55%? 9'23 {.31 Us? 31% 33'} 337153?? m: 25.34 33$ 5 Rim-3 .13 ?313?- L?af?e 1.53 ?9 (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronicaiiy signed by Rachel Bridge (201-2726174627) IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. AB Plaintiff, VOLUME OF JEFFREY EPSTEIN, Defendant. mm mu VIDEOTAPED DEPOSITION OF SARAH KELLEN Wednesday, March 24, 2010 10:37 6:51 p.m. 250 Australiao Avenue South Suite 1500 West Palm Beach, Florida 33401 rm Reported By: Rachel W. Bridge, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 WW I. mam ":awwmma?wm - 4m? w?gimmekmied-eicmaimmww (561) 832~7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronicaiiy signed by Rachel Bridge (201-272-6174627) IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE AB Plaintiff, -VS- VOLUME OF - JEFFREY EPSTEIN AND SARAH KELLEN, Defendants. VIDEOTAPED DEPOSITION OF SARAH KELLEN Wednesday, March 24, 2010 10:37 6:51 p.m. Mimi; 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 "merm" A (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 Electronicany signed by Rachei Bridge (201-272-61?-4627) Page 381 Page 383 behalf ofthe Ptaiaaff, 13.13.: 3 SPENCER T. KUVIN, ESQUIRB - EN LEOPOLoxuvni 2 i gi ?1 3 WITNESS: DIRECT CROSS REDERECT aecaoss 5 Palm Beach Gardens, Florida 33430 4 Sarah Kelien 7 On behalf of the Piaintiffs, L.M., EW. and 6 By MS. Ezeil 386 Jane Doc: 7 a i 9 ESQUIRE 8 FARMER, JAFFB, WEISSING, EDWARDS Fen?acammwman 9 EXHIBITS a 425 North Andrews Avenue 1 0 11 11 I a For: Landerdale, Florida 33301 PAGE 12 Phone: 954.524.2320 12 15 339 1 3 On behalf of3aao Does 1 through 3; 3, 3 1:1 ADAM e. nonowrrz, ESQUIRE 1 4 WRMELSTEW a Hoaowzrz, RA. 5 18205 Biscayne Boulevard 3. 5 a 1 6 Miami, Fiorida 33160 0 Poona 30593L2200 1? a E-mail: Ahorowitz@sexabtzseattomey.com 1 8 18 On behalfofthe Plaintiffs, tot, 202 and 103: 19 W. EZELL, ESQUZRE 3.9 AMY JOSEFSBERG seam, ESQUIRE 2 0 2 0 ORSECK 25 West Fiagler Street 2 21 22 a Miami,Fiorida 33230 2 2 Phone: 305.358.2800 - 2 3 23 (Via teiephonePage 382 Page 384 1 Appearances 3. I 2 On behaif of the Plaintiff, Jane Doe II: 2 3 MANUEL GARCLA, ESQUIRE ELKINS BOEHRINGER 3 THE We are now on the record. ?3 224 Datum Avenue: Suite 900 4 It is 3'42 In and I?m on media number three West Palm Beach, Florida 33401 p' ii 5 phone: 5613328033 5 jUSi put something if 6 quickly on the record before we start. neaote sextant: - a it 8 SACK ALAN ESQUIRE 7 iicnow Mr. (iatcra sald he had a couple of ATTERBURY, GOLDBERGER WEISS, RA. 8 questlons, WhiCh I have no objection to 9 Avenue south 9 him asking, but it is 5:42 and we've been going 10 West Palm Beach, Florida 334016012 10 31mm Sewn how's With MS- Phone: 561.659.8300 1 2 And i know Ms. Ezeii has questions and she has 3i: 1 2 got her one client she has to ask: questions about. 1 3 0n behalf Ofthe Witness; 1 3 i understand that, buti hope we can focus on going 14 BRUCE 5- REINHART: ESQUIRB 1 4 forward to areas that have not airead been covered LAW OFFICE OF BRUCE E. REINHART 15 one Cleariake center 1 5 so we can actually get out of here tonight, because 250 South Austraiian Avenue, Suite 1460 1 6 at some point we really do have to go, and i wouid 16 West Palm Beach, Fiorida 33401 17 1.1, .tht Phone: 561.202.6360 1 0 g? 13 over 0 2f)" 17 1 8 So that, Mr. Garcia, if you have some :3 1 9 additional questions, i have no objection to you 2 ALSO 2 0 aSking that 2 1 jessica Cadaell, Paralegal 2 1 MR. GARCIA: Thank you. 2 2 Bum?, ?we? C01?man= PA- 2 2 CROSS continued (SARAH KELLEN) 2 3 Joseph Kozak, Videographer 2 3 BY MR- 24 9f058 001111 Services 2 4 Q. Have you ever had a different hair coior? 2 5 2 5 MR. REINHART: Asking if at any time in her a?cmamzezrmq smog-ate; gig?iczs-xua?tu?t tag-wage; extras-mam as: $3232.: as?: mamamnaneezcawesome 5 (Pages 381 to 384) (561) 832m7soo PROBE COURT REPORTING AGENCY, INC. (561) 832~7506 Eiectronicany signed by Rachel Bridge (201-272-617-4627?) Page 385 Page 387 Luau-$3 it c, .45. V. twaimusmuauw z-W?M?maramm rug: mam-a .- or ?mam .. .. . 1 iife she?s ever dyed her hair a different hair 1 Q. And you are sure that you only had it up for 2 color? 2 about ten minutesthat?s her natural coior. Let's start 4 minutes orjust for a brief period of time? 5 with that. 5 THE A very brief period of time. 6 BY MR. GARCIA: 6 MR. You can answer Mr. Garcia's '7 Q. Is that your natural color? 7 question. 8 MR. Answer that. 8 BY MR. 9 THE WITNESS: Yes. 9 Q. Can you be more speci?c? Are we talking 1 0 BY MR 1 0 about ten minutes for a day or ten minutes in a week or 1 1 Q. What is your natural color, so the transcript a month? 3.2 re?ect it? 12 A. Maybe a day. Maybe two days. 1 3 MR. REINHART: We have a Video, so i think 1 3 Q. Okay. 1 4 it's pretty clear, 1 4 MR. GARCIA: Okay, that?s I have. Thanks. 1 5 THE WITNESS: Brown. 1 5 CROSS (SARAH KELLEN) 6 BY MR. GARCIA: 1 6 BY MS. EZELL: 7 Q. Have you ever dyed your hair or colored your 1 7 Q. Ms. Kellen, my name is Katherine Ezell. I?m 3. 8 hair blonde or any type of shade of light, lighter 1 8 here with Amy osefsberg Ederi. We represent iane Doe IE. 9 shade? 1 9 l03. We aiso represent three ciients who have not yet 2 0 MR. REINHART: You mean at any time in her 2 0 ?led. Some of the questions may be repetitive, but i 2 .1 life has she done that? 2 believe we have the right to ask them with regard to our 2 2 MR. Yes, sir. . 22 ciients. So with that said, we'll move along as fast as 23 THE WITNESS: Yes. 23 we can. 2 4 BY MR. GARCEA: 2 4 Why did you take down your acebook page? 2 5 Q. or what period of time? 2 5 A. I think it's a stupid site. I don't Page 386 Page 388 A. I don?t recaii. I understand it. I don't understand the point of it. 2 Q. And how long have you gone back to your 2 Q. Do you have e?mail? 3 natural color brown? 3 A. Yes. 4 A. It's been a long time. i don?t recall exactiy 4 Q. And what is your e-mail address? 5 the dates. 5 MR. REINHART: Instruct the witness not to 6 Q. Do know somebody named Craig Greczyn, G~r?e?c, 6 answer based on Fifth Amendment privilege. 7 as in cat, 2 as in Zorro, y?n? 7 THE At the advice of counsel, I must 8 A. No. 8 invoke my Fifth Amendment right. 9 Q. He's a student at SUNY University, in 9 BY MS. EZELL: 1 Courtland. Q. Have you, have you done e-maii under the 1 1 A. No idea. 1 1 address JKeElens@Earthiink.net? 1 2 Q. Do you know Ko? Sanscuiotte, K?o~f~i, 1 2 A. Can you repeat that? I?m sorry. 1 3 S?a?nvs~c?u~i~o~t~t~e? 1 3 Q. Rave you used e-mail with the address 1 4 A. No. 1 4 3Keiiens@Earthlink.net? 1 5 Q. And Michael DaieyHave you used e-maii with the address 1 7" Q. I tried to see if I couid Google your Facebook 1 7 Kellens@Earthiink.net? 1 8 page, and you thought you took it down after about ten 1 8 MR. REINHARY: Hold on a second. I?m going to 1 9 minutes. I did come up with three or four Sarah 1 9 instruct the witness not to answer any questions 20 Kellens. l?m not sure if it's the same one that you . 2 0 about any e~maii addresses that she may or may not 2 1 are, but are you sure that you've taken it down? 2 1 have had in the past based on her Fifth Amendment 2 2 A. Yes. 3 2 2 priviiege. 2 3 Q. And do you have any idea when you took it i 2 3 THE WITNESS: At the advice of my counsel, I 2 4 down? 2 4 must invoke my Fifth Amendment right. 2 5 A. Maybe a year ago. . 25 6 (Pages 385 to 388) (561) 832-4500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronicaiiy signed by Rachel Bridge (201-2?2-61?-4627) Page 389 Page 391 1 BY MS. EZELL: 1 THE VIDEOGRAPHER: Okay. 2 Q. With regard to the Facebook page again, why 2 MS. EZELL: This is the second page. 3 did you start it up if you thought it was a Stupid site 3 THE VIDEOGRAPHER: Okay. 4 and didn?t know how to use it? 4 MS. EZELL: And here's the third page. 5 A. i was just curious. 5 THE VIDEOGRAPHER: Okay. 6 Q. Did anyone heip you do that? 6 MS. EZELL: And just for identi?cation 7 A. No. 7 purposes, these are Bates stamped SAO 496 8 Q. Did anyone tell you to take it down? 8 through -- i?rn sorry, 495 through 497would pass that down, please, to the witness. 1 0 Q. You were asked about any iicenses. Have you 1 0 BY MS. EZELL: 1 1 never held a real estate license? 1 1 Q. Do you recognize this. Sorry? 1 2 A. Never. 12 MR. REINHART: Are you asking about all three 1 3 Q. Do you hold any licenses in any states other 13 pages simultaneously or one page at a time? 1 4 than Florida? 1 4 MS. EZELL: All three simultaneous. 1 5 MR. When you say iicenses, you mean 1 5 MR. REINHART: Okay. 1 6 professionai as opposed to a driver?s iicense or 1 6 BY MS. EZELL: 17 some other sort of a license? 17 Q. This appears to he, the first page appears to 18 MS. EZELL: Yes. 1 8 indicate that this was obtained from the driver?s 1 9 THE WITNESS: I don't have a iicense anywhere 1 9 iicense authority in Hawaii. 20 for anything. 2 0 MR. REINHART: The ?rst page we have looks 2 1 BY MS. BZELL: 2 1 like it?s a printed page. 2 2 Q. Do you have a driver?s license? 2 2 MS. EZELL: Right. 2 3 A. Yes. 2 3 MR. REINHART: From -- oh, I see. Okay, never 2 4 Q. And in what state? 2 4 mind. 2 5 MR. i instruct her not to answer 2 5 Page 390 .Page 392 1 based on her Fifth Amendment privilege. 1 BY MS. EZELL: 2 THE WITNESS: At the advice of counsel, I must 2 Q. It?s from the supervising driver license clerk 3 invoke my Fifth Amendment priviiege. 3 in the city and county of Honolulu. Do you see that? 4 MR. REINHART: You can roll your eyes all you 4 A. Yes. 5 want, Mr. Horowitz. it's my ciient?s right. 5 Q. Do you recognize that application, pages two 6 She'll invoice it if she needs to. 6 and three? 7 MR. HOROWITZ: I was shaking my head, not 7 MR. REINHART: Page two is a printout of what 8 roiling my eyes. The Fifth Amendment assertion as 8 appears to be a driver's license. Page three 9 to whether a person has a driver's license is 9 appears to he a ?ngerprint. 1 ridicuious. It is ridiculous. 1 0 Is that what you are asking her, if she 1 1 MR. REINHART: You can have that opinion, and 1 1 recognizes this? 1 2 if you want to bring that up to the judge, 111 be 12 MS. EZELL: Yes, uh huh. 1 3 happy to explain to the judge why it?s a vaiid 1 3 MR. REMART: I instruct her not to answer 1 4 invocation. 1 disagree with you. 1 4 those questions. 1 5 MS. EZELL: it is certainly a record that the 1 5 "Pi-{i3 WZTNESS: At the instruction of my lawyer, 1 6 government has and can be accessed. 1 6 I must invoke my Fifth Amendment right. 1 7 MR. REINHART: That?s true. 17 BY MS. EZELL: 1 8 (The document was marked Exhibit 16 for 1 8 Q. Even though this is a pubiic record? 1 9 identi?cation.) 1 9 MR. REINHART: Wei}, if it?s a public record 2 0 BY MS. EZELL: 2 0 or not, she doesn't have to admit or authenticate 2 1 Q. i?rn going to Show you in a moment what I have 2 1 it for you. You can prove it some other way. She 2 2 premarked as Exhibit l6. 22 has a Constitutional right not to admit or 2 3 MS. EZELL: Actuaiiy, it's Composite 16. it's 2 3 authenticate the document for you, and that?s what 2 4 three pages. I'll show it before I give invoking. 2 5 witness. 2 5 7 (Pages 389 to 392) (561) 832~7500 PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 Eiectronicaiiy signed by Rachel Bridge kiE-ha?xu. Jiimh??irm? "-22 3.34" ?am it" maid-in?nite; 'vu'w :33 ii Page 393 Page 395 1 BY MS. 1 BY MS. EZELL: 2 Q. Did you ever hold a Hawaii driver's license? 2 Q. Did you at one time hoid a post of?ce Box 333 3 MR. REINHART: Same instruction. it?s been 3 in I won't pronounce it right, but Haliewa, Hawaii? 4 asked and answered. 4 THE REPORTER: Could you spell -- 5 THE WITNESS: At the instruction of my anyer, 5 MS. EZELL: it?s i believe. 6 i must invoke my Fifth Amendment right. 6 MR. I instruct the witness not to 7 BY MS. BZELL: 7 answer based on her Fifth Amendment priviiege. 8 Q. Do you currently hold a Hawaii driver's 8 THE At the instruction of my iawyer, 9 license? 9 I must invoke my Fifth Amendment right. 1 0 MR. It?s been asked and answered, 0 BY MS. EZELL: 1 1 same instruction. 1 3. Q. Were you born on May 25, 1979? 12 THE At the instruction of my lawyer, 2 MR. REINHART: Same instruction. 13 i must invoke my Fifth Amendment right. 13 THE. At the instruction of my iawyer, 4 BY MS. BZELL: 1 4 I must invoke my Fifth Amendment right. 1 5 Q. is that not your picture on the second page of 15 BY MS. EZELL: 1 6 that exhibitsignature there for Sarah Kellen? 17 MR. REINHART: Same instruction. 1 7 MR. REINHART: Just asking if she sees a 8 THE WITNESS: At the instruction of my iawyer, 1 8 signature on the paper ?m 9 I must invoice my Fifth Amendment right. 1 9 MS. EZELL: That says Sarah Kelien. 2 0 BY MS. EZELL: 2 0 THE WITNESSyou see the name Kellen, Sarah Lynneiie? 2 3. BY MS. EZELL: 2 2 MR. REINHART: She's just asking that your signature? 2 3 that on the document. 2 3 MR. Instruct the witness not to 2 4 THE WITNESS: Yes. 2 4 answer based on her Fifth Amendment priviiege. 2 2 5 Tree Witness: At the instruction of my lawyer, Page 394 Rage 396 1 BY MS. EZELL: 1 I must invoice my Fifth Amendment right. 2 Q. And haven't you testified today that that is 2 BY MS. EZELL: 3 your name? 3 Q. Do you drive an automobiie in Palm Beach 4 MR. REINHART: The testimony will speak for 4 COunty? 5 itself. Next question. 5 MR. REINHART: Let me understand the question. 6 BY MS. EZELL: 6 Are you asking if she ever drives a vehicle in the 7 - Q. You may answer. 7 county or if she drives a vehicle registered in the I 8 MR. Remnant: Next question. 8 county? 9 MS. EZELL: You are instructing her not to 9 MS. EZELL: If she drives a vehicle in i?alm fl 0 answer that question? 1 0 Beach County. 3. 1 MR. REINHART: 1am. 1 1 MR. REINHART: You can answer that. In other 1 2 BY MS. EZELL: 12 words, did you drive a car here today? 1 3 Q. What was your address at the time that that, 1 3 THE WITNESS: Yes. ii. 4 that you applied for a iicense then? 1 4 BY MS. EZELL: i. 5 MR. REINHART: Object to the form, assumes 15 Q. You were asked eariier if you have ever been 1 6 facts that she has not acknowledged, that she ever 1 6 to Palm Beach as opposed to West Paint Beach where we are I 7 appiied for this iicense, and I'll instruct her not 1 7 today, and i believe you answered yes. 3. 8 to answer. 1 8 A. Uh huh. ii. 9 BY MS. EZELL: 9 Q. Where have you been in Palm Beach? 2 Q. Is the post office box -- 2 0 MR. REINHART: i instruct her not to answer 2 1 MR. REMART: Hoid on, let her answer or not . 2 3. based on her Fifth Amendment priviiege. 2 2 answer. 2 2 THE WITNESS: At the instruction of my iawyer, it 2 3 THE WITNESS: At the instruction of my lawyer, 2 3 i must invoke my Fifth Amendment right. 2 4 I must invoke my Fifth Amendment right. 2 4 BY MS. EZBLL: 2 5 2 Q. When was the iast time you were on Palm Beach 8 (Pages 393 to 396) (561) 832~7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronicatty signed by Rachei Bridge Page 39?? Page 399 1 island, if it?s an island? 1 BY MS. EZELL: 2 MR. REINHART: Objection, it?s been asked 2 Q. Do you know Glenn Dubin? 3 before, and PH instruct her not to answer for the 3 MR. REINHART: It's also asked and answered, 4 same reason. 4 but I'll let her answer it again. 5 THE At the instruction of my lawyer, 5 THE WITNESS: At the instruction of my lawyer, 6 i must invoke my Fifth Amendment right. 6 i must invoke rny Fi?h Amendment right. 7 BY MS. EZELL: 7 BY MS. BZELL: 8 Q. Have you ever heard of iefl?rey Epstein? 8 Q. Do you know that they have two daughters? 9 MR. REINHART: Objection, instruct the witness 9 MR. REINHART: Same instruction, objection to 1 0 not to answer based on her Fifth Amendment 1 0 the form, assumes facts that she has not 1 privilege. 1 1 acknowledged, so there is no foundation for the 12 THE At the instruction of my lawyer, 12 question. 1 3 I must invoke my Fifth Amendment right. 3. 3 THE WITNESS: At the instruction of my lawyer, 4 MR. REZNHART: It?s also been asked and 3. 4 i must invoke my Fifth Amendment right. 15 answered. 1 5 BY MS. EZELL: 3. 6 BY MS. EZBLL: 1 6 Q. Have you ever seen pictures of the little 1 Q. Do you read the newspapers? 1 7 girls? i. 8 A. Not really. 1 8 MR. Which little girls? 3. 9 Q. Have you read any newspapers in the last four 1 9 MS. EZBLL: The Duhins' children. 2 0 years in Palm Beach County? 2 0 MR. REINHART: Objection to form. Once again, 2 1 A. I'm sure I have. 2 1 assumes facts that she has not acknowledged, that 2 2 Q. Have you read the Palm Beach Post? 2 2 there is no foundation. Instruct her not to answer 23 A. No, [don?t. 23 the question. 2 4 Q. What newspapers do you read? 2 4 THE At the instruction of my lawyer, 2 5 A. New York Times, New York Post. That's about 2 5 i must invoke my Fifth Amendment right. Page 398 Bags 400 1 it, on occasion. 1 BY MS. 2 Q. And have you ever do you watch the news on 2 Q. Are you an only child? 3 TV, local news? 3 MR. It?s been asked and answered or 4 A. No. 4 reSponded to, and i?li instruct her once again to 5 Q. When you did your Facebook page, whose 5 respond. 6 computer did you use? 6 THE WITNESS: At the instruction of my lawyer, '7 A. My own. 7 i must invoke my Fifth Amendment right. 8 Q. What kind of computer do you own? 8 BY MS. EZELL: 9 A. An Apple computer. 9 Q. i believe you stated that you had changed your Q. Is it a laptop? 1 0 hair color at some point in your life. 1 1 A. Yes. 3. 3. Have you changed it in the last ?ve years? if 3. 2 Q. How long have you had that computer? 1 2 A. i don?t recall exact years and dates. 3. 3 A. ldon?t recall. 1 3 Q. sorry? i 1 4 Q. Do you know Eva Andersson? i. 4 A. i don?t recall exact years and dates thatl 5 MR. REINHART: Objection, it?s been asked and 5 have. ii. 6 answered. 1 6 Q. Have you been a blonde at some point in the lg 1 7 MS. EZELL: I think it was asked whether or 1 7 last, in the last eight years? 1 8 not she had been on a plane with her. 1 8 A. Most likely. 3. 9 MR. REINHART: i believe she was asked if she 9 Q. At more than one time? In other words, have 2 0 knew who Eva Andersson was, but she can go ahead 2 0 you gone hack and forth between being a brunette and a 2 1 and respond to the question. I instruct her not to 2 ll blonde or were you a blonde for a certain period of 22 answer. 22 time? if 2 3 THE WITNESS: At the instruction of my lawyer, 2 3 A. I think I went back and forth at one point. 2 4 i must invoke my Fifth Amendment right. 2 4 Q. Have you ever either had an office or worked of?ce in this building, which is One Clearlake 9 (Pages 397 to 400) (561) 832?4500 QROSE COURT REPORTING AGENCY, INC. (561) 832?3506 Electronically signed by Rachel Bridge (201-2726174627) Rage 403. Page 403 1 Centre? 1 BY MS. EZELL: 2 MR. instruct the witness not to 2 Q. Do you consider yourself a citizen of the 3 answer based on her Fi?h Amendment privilege. 3 United States? 4 THE WITNESS: At the advice of counsel, 1 must I 4 MR. REINHART: You can answer that. invoke my Fifth Amendment right. 5 THE Yes. 6 BY MS. EZELL: 6 BY MS. EZELL: 7 Q. Have you ever gone to that of?ce on a daily 7 Q. And of what state do you consider yourself to a basis with Jeffrey Epstein? 8 be a citizen? 9 MR. REWRT: Objection to form. There is no 9 MR. That was just asked and foundation, because she hasn't acknowledged going 1 answered. 11 to an office in this building. 3.1 MS. EZELL: i asked about residency. 2 Aiso objection as to the implied knowledge of 3.2 MR. REINHART: i apologize. 1 3 Mr. Epstein. Instruct her not to answer. 1 3 THE WITNESS: What's the difference? 4 THE WITNESS: At the instruction of my lawyer, 14 MR. REWHART: instruct the witness not to 5 I must invoke rny Fifth Amendment right. 15 answer the question based on Fifth Amendment. 1 6 BY MS. EZELL: 6 rue At the instruction oftny anyer, 17 Q. Have you ever had anything to do with a 17 i must invoke my Fifth Amendment right. 1 8 company called the Florida Science Foundation? 1 8 BY MS. EZELL: 9 MR. Instruct the witness not to 1 9 Q. Have you changed your residency in the last 2 0 answer based on Fifth Amendment. 2 0 three years? 2 3. THE WITNESS: At the instruction of my lawyer, 2 1 MR. REINHART: Residency for which? Ijust 2 2 i must invoke my Fifth Amendment right. 2 2 want to be clear, Ms. Bzell. You mean legal ii 2 3 BY MS. EZELL: 2 3 residency or where she actually lives residency? 2 4 Q. Your middle name is Lynneile; is that correct? 2 4 MS. EZELL: Well, let?s do both. 2 5 A. Correct. 2 5 Page 402 Page 404 1 Q. L?y-n-e-l-l-e? 1 BY MS. EZBLL: 2 MR. REINHART: it's been asked and answered 2 Q. Have you changed your legal residency in the 3 twice. You can answer it again. 3 last five years? 4 THE WITNESS: L?y-n-n-e?l-l-e. 4 A. idon't think so. 5 BY MS. EZELL: 5 Q. Have you changed the place you live in the 6 Q. Thank you. 6 last five years? 7 Where do you, of what state are you a 7 MR. REINHART: Instruct her not to answer that 8 resident? 8 question based on Fifth Amendment. 9 MR. REINHART: instruct the witness not to 9 THE WITNESS: At the advice of counsel, 1 must 3. 0 answer based on Fifth Amendment. 1 0 invoke my Fifth Amendment right. 1 1 THE WITNESS: At the instruction of my lawyer, 1 1 BY MS. EZELL: "3 1 2 i must invoke my Fifth Amendment right. 1 2 Q. ?at/e you changed your citizenship, your state 3 BY MS. 3 citizenship in the last ?ve years? 4 Q. Where do you vote? 1 4 MR. REINHART: Again, for purposes of voting it; 15 MR. REINHART: Same instruction. 1 5 and other things or just -- 6 THE WITNESS: At the instruction of my lawyer, 1 6 MS. EZELL: Yes, whatever things citizenship 17 i must invoke my Fifth Amendment right. 1 7 entitles one to do. 1 8 BY MS. EZELL: 8 MR. REMART: if you understand the question, 9 Q. Are you registered to vote? 3. 9 you can answer it. 2 0 MR. REINHART: It?s been asked and answered. 2 0 THE I don?t recall really ever 2 3. PH instruct her not to answer again, or to answer 2 1 changing -- {didn't know that you could change 22 it, to reSpond to it, i should say. 2 2 your citizenship of a state. 2 3 THE. At the instruction of my lawyermust invoke my Fifth Amendment right. 2 4 Q. Well, if you move from one state to another, :3 2 5 2 5 you might change your voter's registration. Have you 10 (Pages 401 to 404) (561} 832*7500 pnose COURT REPORTING AGENCY, INC. (561) 832~7506 Electronically signed by Rachel Bridge (201?272-6174627) Page 405 Page 407 g; i done that? 1 THE WITNESS: At the advice of my lawyer, i 2 MR. REINHART: You can answer. 2 must invoke my Fifth Amendment right. 3 ran WITNESS: No. 3 BY MS. azsLL: 4 BY MS. EZBLL: 4 Q. What kind of modeling did you resident of or citizen of the US 5 A. Very iittle. i did a job for Champion 6 Virgin {stands currentiy? . 6 Sportswear, a coupie of hair shows. That's about it 7 Mn. REINHART: Do you understand? You can 7 ready. 8 answer it. 8 Q. Have you ever been involved in modeiing for MC 9 rue WITNESS: No. 9 Squared? 1 0 BY MS. EZELL: 0 MR. RBINHART: instruct the witness -- i 1 1 Q. Do you pay taxes in any state? 1 objection to the form, assumes knowiedge of an 1 2 MR. Answer that yes or no. 1 2 entity by the name of MC Squared which the witness 1 3 THE WITNESS: Yes. 1 3 has not acknowiedged or have any knowledge of, so 1 4 BY MS. EZELL: 1 4 there is no foundation for the question. 1 5 Q. in what states do you pay taxes? 1 5 I'd instruct her not to answer based on her 3. 6 MR. REINRART: Instruct her not to answer that 1 6 Fifth Amendment priviiege. 3.7 question based on Fifth Amendment. 1 7 THE WITNESS: At the instruction of my anyer, 1 8 THE WITNESS: At the instruction of my lawyer, 3. 8 I must invoke rny Fifth Amendment right. 3. 9 i must invoke my Fifth Amendment right. it 9 BY MS. EZELL: 2 0 BY MS. EZELL: 2 Q. Have you ever been photographed nude or 2 1 Q. Do you own property in any state? 2 1 partiaiiy nude? 2 2 MR. REINHART: it?s a yes or no question. You 2 2 MR. REINHART: When you say partiaily nude, 2 3 can answer that. 23 can you clarify? 2 '4 THE WITNESS: No. 24 MS. EZELL: With either, without without a bottom or with something draped across Page 406 Page 408 1 BY MS. BZELL: 1 part of a body, but not ail parts of her body. 2 Q. is that a no? 2 THE My boyfriend took pictures of me 3 A. No. 3 one time. 4 Q. Have you owned property in any state in the 4 BY MS. BZELL: 5 last five years? 5 Q. And what happened to those, where are those 6 A. No. 6 pictures? 7 Q. Are you taking any prescribed medication at 7 A. I have them. 8 this time? 8 Q. And who is your boyfriend? 9 MR. You can answer the question. 9 MR. REINHART: Hold on a second. 1 0 THE WITNESS: Yasmin. 1 instruct the witness not to answer based on 1 1 BY MS. BZELL: 1 1 her Fifth Amendment privilege. 1 2 Q. rm sorry? 1 2 or MS. ozone: 1 3 A. Yasmin. It's a birth control pili. 13 Q. Is that your current boyfriend who took the 1 4 Q. Anything else? it 4 pictures? 1 5 A. No. .15 MR. You can answer that. 1 6 Q. You didn?t take anything before this 1 6 THE WITNESS: No. 1 7 deposition today? 1 7 or MS. EZELLthose pictures were you nude or partialiy 1 9 Q. At what age did you first modei 3. 9 nude? 2 professionaily? 2 0 MR. At this point this is getting 2 1 A. I beiieve I was 18, 2 1 into her privacy rights beyond the scope of 2 2 Q. And for what company or organization did you 2 2 anything I think that?s relevant to this case. I'm 2 3 model at 18? 2 3 going to ask you to move on. 2 4 MR. instruct her not to answer the 2 4 MS. BZELL: Are you instructing her not to 2 5 question based on her Fifth Amendment privilege. 2 5 answer? =55? 11 (Pages 405 to 408) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 Electronicaliy signed by Rachel Bridge (201?2726174627) 905m ,2 tr i Page 409 Page 411 1 MR. REINHART: i am. i am. 1 THE WITNESS: ldon?t I don't get it. It?s 2 BY MS. EZELL: 2 vague. I don?t understand the question. 3 Q. Do you have all copies of those pictures or 3 BY MS. BZELL: 4 have they been distributed? 4 Q. Are you not aware of an organization that 5 A. I hope I have all copies. 5 limits its membership to billionaires? 6 Q. Would you please i have a little dif?culty 6 A. NO, I'm ?Ot- 7 hearing you. 7 Q. At some point did you become an employee of 8 A. Sorry. 8 Jeffrey Epstein? 5 9 Q. Would you please tell me again all the 9 MR. REINHART: instruct the witness not to 3. 0 companies that you have modeled for? 1 0 answer based on her Fi?l?l Amendment privilege, and 1 A. i don't remember their names. It was so long 1 1 that?s also been asked and answered several times. 1 2 ago. I 1 2 THE WITNESS: At the instruction of my lawyersporting 1 3 I must invoke my Fifth Amendment right. 1 4 A. Oh, i got ajob for Champion Sportswear. 1 4 BY MS. EZBLL: 1 5 Q. And what did you model for Champion? 1 5 Q. By whom are you currently employed? 1 6 A. Athletic wear. 1 6 MR. REINELART: Objection, also been asked and 1 7 Q. And then you said some hair Shows? 1 7 answered several times. instruct her not to 1 8 A. Right. Just where they cut and color your 1 8 anSWer. 1 9 hair in different styles and you do a little rtmway 1 9 THE WITNESS: At the inS?uCtiC'? Of my lawyer: 2 0 show. 2 I must invoke my Filth Amendment right. 2 1 Q. Have you ever done a runway show for, for 2 1 BY MS. EZELL: 2 2 clothes, clothing? 22 Q. Are you employed by an individual corporation? 2 4 Q. Who introduced you to Jeffrey Epstein? 2 4 MR- REINHARTI Same instruction. 2 5 MR. instruct the witness not lawyer, page 410 Page 412 answer based on her Fifth Amendment privilege. 1 I must invoke my Fifth Amendment right. 2 THE WITNESS: At the instruction of my lawyer, 2 BY MS. EZELL: 3 must invoke my Fifth Amendment right. 3 Q. Do you receive a 4 BY MS. EZELL: 4 MR. Same instruction. 5 Q. Have you ever been to a social event in New 5 THE WETNESS: At the instruction of my lawyer, 6 York that is restricted to billionaires? 6 i must invoke my Fifth Amendment right. 7 A. Sorry, can you repeat that? 7 BY MS. EZELL: 8 Q. Yes. Have you ever been to a social event 8 Q. Do you receive a 1099? 9 that's held annually in New York restricted to 9 MR. REINHART: Same instruction. 1 billionaires? 1 0 THE WITNESS: At the instruction of my lawyer, 1 1 A. I?ve never heard of such an event, no. 1 1 i must invoke my Fifth Amendment right. 12 Q. Have you ever been to such an organization in 12 BY MS. EZELL: 1 3 California? 1 3 Q. Does anyone claim you as a dependent on their l. 4 A. No. I, have never heard of such an event 1 4 tax returns? 1 5 like that, so i don't know. 1 5 MR. REINEART: Anyone other than herself? 1 6 Q. Have you never seen your picture taken and 1 6 MS. EZELL: Yes. 1 7 diSplayed in print media at such an event? 1 7 No. 1 8 MR. Objection to the form. its 1 8 BY MS. EZELL: 1 9 not established she has any idea what event or what 1 9 Q. Have you ever signed a con?dentiality 2 kind of event this would be. 2 0 agreement? 2 1 BY MS. EZELL: 2 1 MR. With anyone? 2 2 Q. An annual event involving millionaires 2 2 MS. EZELL: Yes. 2 3 billionaires, excuse me. 2 3 MR. HOROWITZ: Instruct the witness not to 2 4 MR. REMART: Objection to the form. There 2 4 answer based on her Fifth Amendment privilege. 2 5 is a lack of foundation for the question. 2 5 THE WITNESS: At the instruction of my lawyer, if premium is w: m: swam More 'cr are row; Kati!? mezan use 12 (Pages 409 to 412) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge Page 413- Page 415 1 I must invoke my Fifth Amendment right. I 1 impiicitiy. instruct the witness not to answer. 2 BY MS. EZELL: 2 THE At the instruction of my iawyer, 3 Q. Have you stated that you consider yourseif a 3 i must invoke my Fifth Amendment right. 4 loyal employee? 4 BY MS. EZELL: A. Have i what? Fm sorry. 5 Q. Do you know Juan Aiessi? 6 Q. Have you ever stated that you consider 6 THE WITNESS: At the instruction of my lawyer, 7 yourself a employee? 7 i must invoke my ifth Amendment right. 8 A. I don't recall ever saying those words. 8 BY MS. EZELL: 9 Q. is it true that you wilt do anything Jeffrey 9 Q. Do you know Aifredo Rodriguez? 1 Epstein asks? 1 0 MR. It?s been asked and answered. 1 1 MR. RBINHART: Objection to the form, compound 1 1 Go ahead and answer it again. 12 question. Assumes knowledge of Jeffrey Epstein, so 12 THE At the instruction of my lawyer, 1 3 I instruct the witness not to answer. 1 3 i must invoke my Fifth Amendment right. 1 4 THE WITNESS: At the instruction of my iawyer, 3. 4 BY MS. EZELL: 1 5 I must invoke my Fifth Amendment priviiege. 1 5 Q. I think you aiso might have been asked if you 1 6 BY MS. EZELL: 3. 6 know ianuscz Banasiak. 1 7 Q. In 2005 and did you have a designated 3. 7 THE At the instruction of my lawyer, 1 8 computer in Mr. Bpstein?s home on Si Briilo Way? 1 8 i must invoke my Fifth Amendment right. 1 9 MR. REINHART: Objection to form, its 3. 9 BY MS. EZELL: 2 0 compOund and assumes knowiedge of Mr. Epstein and 2 Q. Are you a photographer? 2 1 of a iocation on Bi Brilio Way, so I instruct the 2 1 MR. REINHART: Objection to the form, its 2 2 witness not to answer. 2 2 ambiguous. Amateur photographer? Professional 2 3 THE WITNESS: At the instruction of my lawyer, 2 3 photographer? Can you ciarify? 2 4 i must invoice my Fifth Amendment right. 2 4 BY MS. EZELLyou enjoy photography? Page 414 Page 416 1 BY MS. EZELL: A. Yes. 2 2 3 list of contact information and pictures of numerous 3 MR. REINHART: the whims net to 4 young women? 4 answer the question. 5 MR. Objection to the form, it?s 5 THE WITNESS: At the instruction of my lawyer, 6 compound and it is lack of foundation based on the 6 i must invoke my Fifth Amendment right. 7 prior question and answer. 7 BY MS. EZELL: 8 instruct the witness not to answer. 8 Q. Do you know Maria Alessi? 9 THE At the instruction of my iawyer, 9 THE WITNESS: At the instruction of my lawyer, 1 I must invoke my Fifth Amendment right. 1 0 I must invoke my Fifth Amendment right. 1 1 BY MS. EZELL: 1 BY MS. EZBLL: It 2 Q. Did you and Ghislaine Maxweii share that 12 Q. Have you ever known Jeffrey Epstein to give 1 3 information on both of your computers? 13 cameras to young women who come to his home to give him 1 4 MR. REINHART: Objection to form, assumes 1 4 massages? 5 knowledge of a person by the name of Ghisiaine; 1 5 MR. REINHART: Objection to the form, standing 1 6 Maxweii. 1 6 objection, lack of foundation as to Mr. Epstein and 1 7 Also tack of foundation based on the prior two 1 7 to his home. instruct the witness not to answer. 18 answers. instruct the witness not to answer. 1 8 THE WETNESS: At the instruction of my lawyer, 1 9 THE WITNESS: At the instruction of my lawyer, 1 9 1 must invoice my Fifth Amendment right. 2 0 i must invoke my Fifth Amendment privilege. 2 0 BY MS. EZELL: 2 1 BY MS. EZELL: 2 1 Q. Have you been encouraged in your pursuit of 2 2 Q. Would you consider your roie in the Epstein 22 photography by Mr. Epstein? 2 3 household to be that of assistant to Mr. Epstein? 2 3 MR. REINHART: Same objection previousiy 2 4 MR. RBWHART: Objection to form, lack of 2 4 stated. 2 5 foundation, assumes knowledge of Mr. Epstein 25 THE WITNESS: At the instruction of my lawyer, (561) 832?7500 Electronicaiiy signed by Racine! Bridge (201-2724517462?) PROBE COURT REPORTING AGENCY, mmersmma 52235 r39 g. a g. V62 5:939 mm Assamese?; . ham. . war in: 13 (Pages 413 to 416) INC. (561) 832*7506 mm 2 .t m? was?nmm'vi'. mmuuimiemm Page 417- Page 419 I I must invoke my Fifth Amendment right. 3. THE WITNESS: At the instruction of my lawyer, 2 BY MS. EZELL: 2 i must invoke my Fifth Amendment right. 3 Q. Have you ever taken pictures of any of the 3 BY MS. EZELL: 4 young women who have visited the Epstein mansion to 4 Q. Have you, have you ever photographed any of 5 provide massages? 5 the young women who visited or visit the Epstein home to 6 MR. Objection to form, compound, 6 provide massages to Mr. Epstein? 7 lack of foundation. Instruct the witness not to 7 MR. Objection to form, it?s been 8 answer. 8 asked and answered. 9 THE WITNESS: At the instruction of my lawyer, 9 Also lack of foundation and standing 1 i must invoke my Fifth Amendment right. 10 objection. Same instruction. 1 3. BY MS. EZELL: 3. THE WITNESS: At the instruction of my lawyer, 1 2 Q. Are you aware of any hidden cameras on the 12 I must invoice my Fifth Amendment right. 1 3 premises? 1 3 BY MS. EZELL: 4 MR. REINHART: Which premises? 1 4 Q. Have you ever photographed any minor girls who 1 5 MS. EZELL: At the E1 Way address of 5 are either partialiy nude or nude? 1 6 Mr. Epstein. 6 MR. That?s aiso been asked and 7 MR. REINHART: Objection to form, iack of 1 7 answered. I instruct her once again not to answer 1 8 foundation, compound. instruct the witness not to 1 8 the question. 1 9 answer. 1 9 THE WITNESS: At the instruction of my lawyer, 2 0 THE WITNESS: At the instruction of my iawyer, 2 0 I must invoice my Fifth Amendment right. 2 I must invoke my Fifth Amendment right. 2 1 BY MS. EZELL: 2 2 BY MS. EZELL: 22 Q. Have you ever been aware of something caiied 2 3 Q. Did you ever meet a young woman named 2 3 the Edge Group? 2 4 A. At the instruction of my iawyer, I must invoke 2 4 MR. Consult. 2 5 my Fifth Amendment right. 2 5 THE WITNESS: At the advice of my iawyer, I Page 418 Page 420 3. Q. Were you sometimes designated or requested by 1 must invoke the Fifth Amendment right. 2 Mr. Epstein to buy gifts for the young women who wouid 2 BY MS. EZELL: 3 come to the home to give him massages? 3 Q. Is that the name of a group that?s, whose 4 MR. REINI-IART: Objection to form, tack of 4 membership is made up of 6 foundation. Instruct the witness not no answer. 5 MR. Objection to form, iack of 6 THE WITNESS: At the instruction of my iawyer, 6 foundation. Instruct the witness not to answer. 7 I must invoke my Fifth Amendment right. 7 THE WITNESS: At the instruction of my lawyer, 8 BY MS. EZELL: 8 I must invoke my Fifth Amendment right. 9 Q. Were you aware that Mr. Epstein gave AD. a 9 BY MS. EZELL: It 0 digitai camera and encouraged her in her pursuit of 3. 0 Q. Did you attend a function of the Edge Group in I 1 photography? 1 1 February of 1902 w~ i?m sorry, 2002? 1 2 MR. REINHART: Same objection stated to the 2 2 MR. REINI-IART: Object to form, there is a lack Ii 3 previous question and same instruction. 3. 3 of foundation. instruct the witness not to answer. 1 4 THE WITNESS: At the instruction of my iawyer, 1 4 THE WITNESS: At the instruction of my lawyer, 1 5 I must invoke my Fifth Amendment right. 1 5 i must invoke my Fifth Amendment right. 1 6 BY MS. EZELL: 1 6 BY MS. EZELL: 1 7 Q. Have you ever met a young woman named Mil? I 17 Q. Have you attended several functions since 2002 1 8 A. At the instruction of my lawyer, I must invoke 8 of the Edge Group? 1 9 my Fifth Amendment right. 1 9 MR. REINI-IART: Objection to the form, because 2 0 Q. Were you ever aware that Mr. Epstein gave MD. I 2 0 there is no foundation for her having any knowledge 2 1 a reguiar camera and encouraged her in her pursuit of 2 1 of an entity caiied the Edge Group, so 1?11 2 2 photography? 2 2 instruct her not to answer. .2 3 MR. REINHART: Objection to form, assumes 2 3 THE WITNESS: At the instruction ofmy iawyer, 2 a certain facts, iack of foundation, compound. 2 4i i must invoke my Fifth Amendment right. 2 5 Instruct the witness not to answer. 2 5 14 (Pages 417 to 420) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*?7506 Etectronicaiiy signed by Rachet aridge (201-2726174632?) Page 421 Page 423 1 BY MS. EZELL: 3. is a iack of foundation of her having any 2 Q. Are you a member of the Edge Group or do you 2 interaction with anyone at any home owned by 3 go as the guest of Mr. Epstein? 3 Mr. Epstein, whoever he may be. Instruct her not 4 MR. REINHART: Again, there is no foundation 4 to answer. 5 for the question because there is no, there is no 5 THE WITNESS: At the instruction of my iawyer, 6 connection of her to this organization, and Pd 6 I must invoke my Fifth Amendment right. 7 instruct her not to answer. Form objection. 7 BY MS. EZELL: 8 THE At the instruction of my iawyer, 8 Q. Were you the one who routineiy wouid get out 9 I must invoke my Fifth Amendment right. 9 the iotion, towels, and massage equipment once you 0 BY MS. EZELL: 1 arrived at the massage room with the girl? it 1 1 Q. Do you know Ghisiaine Maxweii?s e-maii 1 3. MR. REINHART: Same objection to the form, 12 address? 1 2 same objection stated to the previous question. 1 3 MR. REINHART: instruct the witness not to 1 3 It's been asked and answered as weii. 1 4 answer, objection to form, lack of foundation as to 1 4 THE WITNESS: At the instruction of my iawyer, 1 5 her knowiedge of anyone named Ghisiaine Maxweii. 3. 5 I must invoke my Fifth Amendment right. :t 6 THE At the instruction of my iawyer, 1 6 BY MS. EZELL: 17 I must invoke my Fifth Amendment right. 1 7 Q. Does Mr. Epstein particuiariy like any 1 8 BY MS. EZELL: 1 8 particuiar massage oils? 9 Q. Do you know a Nicole Hesse or Hesse, 1 9 MR. REMART: Objection to the form, standard 2 H-e-s?s-e? 2 objection, no foundation as to her knowiedge of 2 3. A. At the instruction of my iawyer, I must invoke 2 1 anything reiating to Jeffrey Epstein. instruct her 2 2 my Fifth Amendment right. 2 2 not to answer. 2 3 Q. Did you participate in a sort of routine 2 3 THE WITNESS: At the instruction of my iawyer, 2 4 invoiving young women who wouid come to the house, 2 4 I must invoke my Fifth Amendment right. 2 5 Mr. Epstein's house on Bi Way to provide 2 5 Page 422 Page 424 1 massages? . 1 BY MS. EZELL: 2 MR. RBINHART: That?s been asked and answered 2 Q. Was it your general practice to ieave the giri 3 several times, object to the form, Each of I 3 aione eitherjust before or when Mr. Epstein wouid come 4 foundation as to any knowiedge relating to Epstein 4 into the room? 5 or El Briilo Way. instruct her not to answer. 5 MR. REMART: Objection to the form, again 6 THE WITNESS: At the instruction of my anyer, 6 assuming multiple facts and the same question, none 7 I must invoke my Fifth Amendment right. 7 of which have any foundation. Instruct her not to 8 BY MS. EZELL: 8 answer. 9 Q. Was it routine practice for you to come and 9 THE At the instruction of my lawyer, 1 0 meet the giri after she arrived at Ei Brilio Way to 1 i must invoke my Fifth Amendment right. 1 1 provide a massage for the sexuai grati?cation of 1 1 BY MS. EZELL: 1 2 Mr. Epstein? 1 2 Q. Who paid the giris who came to Hi Way 1 3 MR. REINHART: Objection to form, it's 1 3 to provide massages and other sexual favors for 1 4 compound. There is a lack of foundation. instruct 4 Mr. Epstein? 1 5 the witness not to answer. It's been asked and 1 5 MR. REINHART: Same objection as to form as 1 6 answered several times. 1 6 previously stated to the East three or four 1 7 THE WITNESS: At the instruction of my lawyer, 1 7 questions. Same instruction to the witness. 1 8 i must invoke my Fifth Amendment right. 1 8 THE WITNESS: At the instruction of my lawyer, 1 9 BY MS. EZELL: 9 I must invoke my Fifth Amendment right. 2 0 Q. Was it your practice to then iead the young - 2 0 BY MS. EZELL: 2 1 woman who had come to give Mr. Epstein a massage up a 2 1 Q. Who was responsible for keeping the supply of 2 2 stairway that is behind a door in the kitchen of the 22 cash in the house from which the giris were paid? 2 3 home on El Way? 2 3 MR. Same objection as to form and 2 4 MR. REINHART: Objection to the form, its 2 4 tack of foundation. Instruct the witness not to 2 5 compound, assuming many facts. It?s not, and there 2 5 answer. 15 (Pages 421 to 424) (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronicaiiy signed by Rachel Bridge 995m Page 425 Page 42?? "m in?rm}. 1 THE WITNESS: At the instruction of my lawyer, 1 MR. Objection to the form, lack of 5 2 I must invoke my Fifth Amendment right. 2 foundation. instruct the witness not to answer. 3 BY MS. 3 THE Witness: At the instruction of my lawyer, 1i Q. Was it your practice or habit to get the 4 i must invoke my Fifth Amendment right. 5 telephone numbers and contact information of each girl 5 BY MS. EZELL: 6 before she left Bl Brillo Way? 6 Q. Did you ever text with Jane No. 103 about her 7 Same objection as to form as 7 coming to Mr. Epstein?s house? 8 stated to the last series of questions. Same 8 MR. REINHART: Same instruction, same 9 instruction. 9 objection. 1 0 THE At the instruction of my lawyer, 1 0 THE WITNESS: At the instruction of my lawyer, 1 1 i must invoice my Fifth Amendment right. 1 1 i must invoke my Fifth Amendment right. 1 2 BY MS. EZELL: 1 2 BY MS. EZELL: 1 3 Q. Going back to that stairway that led from the 1 3 Q. Were you aware that Jeffrey Epstein was 1 Ii kitchen up to the massage room, was there a time when 1 helping Jane No. 103 with her college application? 1 5 there were photos of nude girls ail the Way up that 1 5 MR. REINHART: Objection to the form, lack of 1 6 stairway? 1 6 foundation as to any knowledge as to Jeffrey 17 MR. REINHART: Same objection as to form and 3. '7 Epstein, so therefore it?s compound and ambiguous. 1 8 lack of foundation as to any basis to question this 1 8 instruct you not to answer. It 9 witness on anything having to do with a home owned 3. 9 THE WITNESS: At the instruction of my lawyer, 2 by Mr. Epstein or any staircase or any pictures on 2 I must invoke my Fifth Amendment right. 2 a staircase. So instruct her not to answer. 2 1 BY MS. BZELL: 2 2 THE WITNESS: At the instruction of my lawyer, 2 .2 Q. Did you ever hear Mr. Epstein tell Jane No. 2 3 i must invoke my Fifth Amendment right. 2 3 103 that he would help her even with the ?nancing of 2 4 BY MS. EZELL: 2 4 her college, of her education? 2 Q. Do you recall a time when all those 2 5 MR. REINHART: Same objection stated to the Page 426 Page 428 1 photographs were removed? 1 previous question. Objection to form and lack of 2 MR. REINHART: Objection to the form, iacic of 2 foundation. Instruct the witness not to answer. 3 foundation, same objection as the previous series 3 THE WITNESS: At the instruction of my lawyer, 4 of questions. Same instruction. 4 I must invoke my Fifth Amendment right. 5 THE: WITNESS: At the instruction of my lawyer, 5 BY MS. BZELL: 6 i must invoke my Fifth Amendment right. 6 Q. Do you recall -- and i believe it?s in "3 BY MS. EZELL: 7 Exhibit 4, ifwe could puli Exhibit 4, please. if I 8 Q. Did you ever text giris about coming to 8 could just look at it for a moment, please. 9 provide massages for Jeffrey Epstein? 9 MR. REINHART: Certainly. 1 0 MR. REINHART: Objection as to form, tack of 2 0 MS. EZELL: Thanks. on, good, it?s on the 1 1 foundation as to any knowledge of Jeffrey Epstein. 1 1 front. 12 Instruct her not to answer. 12 BY MS. nanL: 1 3 THE WITNESS: At the instruction of my lawyer, 13 Q. The ?rst page of Exhibit must invoke my Fifth Amendment right. 1 4. look at that. Do you recognize that handwriting? 1 5 BY MS. EZBLL: 5 MR. That was asked and answered 1 6 Q. Do you know how to text? 1 6 about six hours ago. She said no. 1 7 A. Yes. You can answer it again. 1 8 Q. And how long have you been textingTwelve years. 1 9 BY MS. EZELL: 2 0 Q. Tweive years? That's great. You are way 2 Q. Were you aware that Mr. Epstein ordered roses 2 ahead of me. i still don't know how. 2 1 to be deiivered to Jane No. 103 at the stage of her high 2 2 Do you know a young woman named Jane No. 103? 2 2 school after a play? 2 3 A. At the advice of my counsel, 1 must invoke my 2 3 MR. Objection to the form, tack of 2 4 Fifth Amendment right. 2 4 foundation, standing objection. 2 5 Q. Did you ever drive Jane No. 103 anywhere? 2 5 THE At the instruction of my lawyer, 16 (Pages 425 to 428) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Etectronicaiiy signed by Rachel Bridge (201-2726174627) Page 429 Page 431 1 i must exercise my Fifth Amendment right. 1 MR. REENHART: Same instruction, same i 2 BY MS. EZELL: 2 objection. 3 Q. Do you recall teliing no, sorry. 3 THE WITNESS: At the instruction of my iawyer, 4 Did you and Jane No. 103 become friendly? 4 i must invoke my Fifth Amendment right. 5 MR. REINHART: Object to the form, tact: of 5 BY MS. BZELL: i; 6 foundation as to any relationship with Jane No. 103 6 Q. Did, did you give yourself .iane No 103 any '7 or knowledge of a person named Jane No. 103. 7 gifts? 8 Instruct the witness not to answer. 8 MR. REINHART: I'm sorry, can you rephrase? 9 THE WITNESS: At the instruction of my lawyer, 9 BY MS. EZBLL: 1 i must invoke my Fifth Amendment right. 1 Q. Did you yourself give Jane No 103 any gifts? 1 3. BY MS. EZELL: 1 1 MR. Objection to the form. 2 Q. Do you remember that Jane No. 103 came to 1 2 Instruct the witness not to answer the question. 1 3 Mr. Epstein's home on or about Juiy 23rd, 2004? 1 3 THE WETNESS: At the instruction of my lawyer, 1 4 MR. REINHART: Object to the form, leading, as 1 4 I must invoke my Fifth Amendment right. 1 5 weii as previously stated objection to the East 1 5 BY MS. EZELL: 1 6 question. 1 6 Q. Did you ever buy gifts for Jeffrey Epstein to 1 7 BY MS. EZELL: 1 7 give to fame No 103? 1 8 Q. And do you remember 1 8 MR. REINHART: Objection to form. 1 9 MR. REINHART: Hoid on. 1 9 THE WITNESS: At the instruction of my lawyer, 2 0 MS. EZELL: Sorry. 2 0 I must invoke my Fifth Amendment right. 2 1 THE WITNESS: At the instruction of my iawyer, 2 1 BY MS. EZELL: 2 2 I wish to invoke my Fifth Amendment right. 2 2 Q. Did you ever receive massages at the Bi Brillo 2 3 BY MS. EZELL: 2 3 Way house? - 2 4 Q. Do you remember that Jane No. 103 continued to 2 4 MR. REINHART: Obj ection to form, lack of 2 5 come to Mr. Epstein?s house and indeed came over 100 2 5 foundation. Same instruction. Page 430 Page 432 1 times over about a year and a half? 1 THE WITNESS: At the instruction of my lawyer, 2 MR. REMART: Object to the form for reasons 2 I must invoke my Fifth Amendment right. 3 previously stated in the last several questions. 3 BY MS. EZELL: 4 Instruct her not to answer. 4 Q. Did you receive massages given by .iohanna 5 Tire At the instruction of my lawyer, 5 siooet-g? 6 i must invoke my Fifth Amendment right. 6 W. REWHART: Objection to the form, lack of 7 BY MS. EZELL: 7 foundation as to any knowledge of a person named 8 Q. Do you remember calling to tell .iane No. 103 8 Johanna Sjoberg. Lack of knowledge as to any, lack 9 that Mr. Epstein would be coming in town and would like 9 of foundation as to any connection to Bi Briilo 1 to see her? 10 Way. Instruct the witness not to answer. 1 1 MR. REMART: Objection to form, instruct the 1 1 THE WITNESS: At the instruction of my iawyer, 1 2 witness not to answer. 1 2 i must invoice my Fifth Amendment right. 1 3 THE Witness: At the instruction of my iawyer, 13 BY MS. EZELL: 1 4 I must invoke my Fifth Amendment rightEdge Science dinner on :i 5 BY MS. BZELL: 15 February 27, 2003, in Monterey, California? 1 6 Q. Did you overhear Mr. Epstein himseif call Jane 1 6 MR. REINHART: it's been asked and answered, 1 7 No. 103 at her home? objection to form. 1 8 MR. REINHART: Objection to the form, lack of 1 8 MS. EZELL: No, i didn?t ask about Monterey, 1 9 foundation as to any knowledge of Jeffrey Epstein. 1 9 California. 2 0 instruct her not to answer. 2 0 MR. REINHART: You asked about any Edge Group 2 1 THE At the instruction of my anyer, . 2 1 meetings in California, and she said she has no 2 2 I must invoke my Fifth Amendment right. 22 idea what the Edge Group is. 2 3 BY MS. EZELL: 23 MR. GARCIA: I thought she took the Fifth on 2 a Q. Did you and Jane No. 103 ever go shopping 2 a that. 25 together? 25 MR. RESINHART: said she didn't 17 (Pages 429 to 432) (561) 832w7500 PROSE COURT REPORTING AGENCY, INC. (561) 832"?7506 Eiectronicaily signed by Rachei Bridge (281472617462?) Page 433 Page 435 3. know what the Edge Group was, but whatever, you can 1 BY MS. EZELL: 2 answer the question. 2 Q. Do you want to respond? i didn?t give you 3 THE WITNESS: At the instruction of my lawyer, 3 time. 4 i must choose to invoke my Fitth Amendment right. 4 MR. REINEART: I've instructed her not to 5 BY MS. EZBLL: 5 answer the question. Let?s move on. If 6 Q. Do you know Max Brockrnan? 6 BY MS. EZELL: 7 MR. REINHART: l?m sorry, can you repeat? 7 Q. Do you recall a dinner at El Briilo Way 8 BY MS. EZELL: 8 attended by David Copper?eld where Eerie Noyou know a Max Brockman? 9 guest? it 0 MR. RBINHART: i beiieve that was asked and 0 MR. REMART: Objection to the form, lack of 1 3. answered already, but 1 foundation, and a standing objection as to her 1 2 TEE WITNESS: At the instruction of my lawyer, 1 2 knowiedge of anything invoiving El Brillo Way or 1 3 I must invoke my Filth Amendment right. 1 3 Jeffrey Epstein. instruct her not to answer. 3. 4 or MS. 32am: 1 4 THE WITNESS: At the instruction of my lawyer, 1 5 Q. Have you ever been photographed with Max 1 5 I must invoke rny Fifth Amendment right. 1 6 Brockrnan at an Edge Science dinner? 1 6 BY MS. EZELL: 1 7 A. At the instruction of my iawyer, I must invoke 1 7 Q. What is the reiationship between Jeffrey 1 a my rise Amendment right. i Epstein and David Cepperfieid? 9 MR. REINHART: You should let me i need to 1 9 MR. Objection to form, iack of 2 0 object to the form of the question first, but go 2 foundation as to her knowledge of either one of 2 ahead. 1 know we ail want to get out of here. Go 2 1 those people. Instruct her not to answer. 2 2 ahead. 22 THE At the instruction of my lawyer, 2 3 THE WITNESS: Say it again. 2 3 i must invoice my Fifth Amendment right. 2 4 MR. RBINHART: No, you are okay. Go ahead, 2 4 BY MS. EZELL: 2 5 Ms. Ezcll. Thank you. 25 Q. To your knowledge, do they recruit girls for Page 434 Page 436 1 BY MS. Beam: 1 one another? 2 Q. Do you know Whether Jeffrey Epstein attended 2 MR. Object to the form, compound, 3 the Edge Science dinner in Monterey, California? 3 and again, lack of foundation. Instruct her not to 4 MR. REINHART: Objection to the form, lack of 4 answer. 5 foundation. Instruct the witness not to answer. 5 THE At the instruction of my lawyer, 6 THE At the instruction of my lawyer, 6 i must invoke my Fifth Amendment right. 7 i must invoke my Fifth Amendment right. 7 BY MS. EZELL: 8 BY MS. BZELL: 8 Q. To your knowledge, are they involved in any 9 Q. You testified a moment ago that you were 9 sexual traf?cking of young women? photographed node by your boyfriend or a former 1 0 MR. Object to the form for the 1 1 boyfriend and that you hoped there are no photographs 1 reasons previously stated. Also calis for a legal 12 disseminated eisewhere, 12 conclusion as to what sexual traf?cking is. 1 3 At what age were those photographs taken? - 3 instruct her not to answer. 1 4 MR. REENHART: i'm going to instruct her not 1 4 THE WITNESS: At the instruction of my iawyer, i. 5 to answer that. It has nothing to do with 5 I must invoke my Fifth Amendment right. 3. 6 anything. It?s not reasonabiy calculated to lead 1 6 BY MS. EZBLL: 17 to discoverable evidence. We can move on. 17 Q. I believe you asked about Allen Dershowitz 1 8 BY MS. BZELL: 1 8 earlier. 1 9 Q. Were you in any way damaged by that i. 9 MR. Twice. i 2 0 experience? 2 0 BY MS. EZELL: 2 1 MR. REINHART: Same instruction. Let's move 2 1 Q. And were instructed not to answer. 22 on. 22 MR. Remnant: Twice. 2 3 BY MS. EZBLL: 2 3 BY MS. EZELL: 2 4 Q. Do you have any regrets? 2 4 Q. Ali right. i?m going to ask again on behalf 2 5 MR. REENHART: Same instruction. Move on. of Are gin aggf?gf 18 (Pages 433 to 436) (561) 832-7500 PROBE. COURT REPORTING AGENCY, INC. (563.) 832~7506 Electronicaiiy signed by Rachel Bridge (2014726174627) Eiectronicaliy signed by Rachel Bridge (201-272-617-462?) ?age 437 Page 439 1 Alien Dershowitz and Jeffrey Epstein? 1 BY MS. EZELL: 2 MR. REWHART: And for the third time, PIE 2 Q. Do you know that when David Copper?eld is in 3 object to the form and instruct her not to answer 3 town, he gives Jeffrey Epstein tickets and Jeffrey gives 4 the question, 4 some to young women to attend those shows? 5 THE For the third time, i take the 5 MR. REINHART: Object to the form, multiple, 6 advice of my lawyer and invoke rny Fi?h Amendment 6 compound question, and a compiete iacit of 7 right. 7 foundation. instruct the witness not to answer. 8 BY MS. BZELL: 8 THE WITNESS: At the instruction of my lawyer, 9 Q. When Aiien Dershowitz cemes to Palm Beach, he 9 I must invoke my Fifth Amendment right. 3. 0 stays at the BE Briilo mansion, doesn't he? 30 BY MS. EZBLL: 3. 1 MR. RBINHART: Objection to the form. There 3. 3. Q. And do you know that those giris are invited 3.2 is no foundation for her having any knowiedge of 3.2 back stage after the show? 3 3 anything having to do with a person by the name of 1 3 MR. RBINHART: Same objection, complete tack 14 Allen Dershowitz. i instruct her not to answer. 3. 4 of foundation, and standing objection previously 3. 5 THE WITNESS: At the instruction of my lawyer, 5 stated. 1 6 I must invoke my Fifth Amendment right. 1 6 THE WITNESS: At the instruction of my lawyer, 7 BY MS. EZELL: 3. 7 i must invoke my Fifth Amendment right. 3. 8 Q. When Allen Dershowitz, or has Alien Dershowitz 8 BY MS. EZELL: 3 9 ever been there when young ladies came to give massages? 9 Q. Do you remember on or about, in or about March 2 0 MR. REINHART: Same objection stated to the 20 of 2005 having conversations with one of the young women 2 3. previous question. Same instruction. 2 1 who came to the house to give massages about her 2 2 THE WITNESS: At the instruction of my lawyer, 2 2 conversations with Jane No. 103? 2 3 I must invoke my Fifth Amendment right. 23 MR. REINHART: Objection to the form, standing 2 4 BY MS. EZELL: 2 4 objection, lack of foundation. instruct the 2 5 Q. Has Allen Dershowitz ever been the beneficiary 2 5 witness not to answer, because the question implies Page 438 Page 440 of those massages? 1 that she has any knowledge at all of Bi Way. 2 MR. Same objection and same 2 BY MS. BZELL: 3 instruction. 3 Q. Same question sorry. 4 THE WITNESS: At the instruction of my lawyer, 4 A. At the instruction of my iawyer, I must choose 5 I must invoke my Fifth Amendment right. 5 to invoke my Fifth Amendment priviiege. 6 BY MS. EZELL: 6 Q. Same question as to March of 2806. 7 Q. Do you know John Casablanca? 7 MR. REINHART: Same objection and same 8 A. Never heard that name before. 8 instruction. 9 Q. Have you ever heard of a worid-famous 9 THE WITNESS: At the instruction of my iawyer, it 0 whose stage name is David Copper?eld? I must choose to invoke my Fifth Amendment 1 1 MR. REINHART: That's aiso been asked at least 1 privilege. 2 three times. i?il instruct her again not to answer 12 BY MS. EZELL: 13 the question. 1 3 Q. Do you have any recoliection of a conversation 1 4 THE WETNESS: At the instruction of my lawyer, 3. 4 in which one of the young women told Jane No. 103 that 5 I must invoke my Fifth Amendment right. 3. 5 those girls who, those giris who would help Saffrey in 6 BY MS. EZELL: 3. 6 regard to the investigation wouid be compensated and 1 7 Q. Have you ever gone to one of David 3. 7 those who would not or who would hurt him in the 1 8 Copperfield?s shows? 1 8 investigation wouid be dealt with? 3. 9 MR. REINI-LART: Objection to form, lack of 1 9 MR. REINHART: Objection to the form, iack of 2 foundation as to knowiedge of any person by the 2 foundation, compound question. instruct the 2 1 name of David Copper?eld. Instruct her not to 2 1 witness not to answer, because the question implies 2 2 answer. 2 2 some knowledge of anything relating to a person by 2 3 THE WITNESS: At the instruction of my iawyer, 2 3 the name of Ieffrey Epstein. 2 4 i must invoke my Fifth Amendment right. 2 4 THE WITNESS: At the instruction of my iawyer, 2 5 2 5 I must invoice my Fifth Amendment right. 19 (Pages 437 to 440) 832?7500 PROSE COURT REPORTING AGENCY, INC. - (561) 832~7506 timudrtx-K". . i i i "Hora" "airman-c aw" ?ailiviixiw??i?ih?da?- Page 441: Page 443 i BY MS. EZELL: 1 BY MS. EZELL: 2 Q. Do you know .lohn Brockman? 2 Q. Did you escort those underage girls to the 3 A. At the instruction of my lawyer, i must invoke 3 massage room where the defendant would enter and urge 4. my Fifth Amendment right. 4 the girls to remove their clothes? 5 Q. Do you know of someone named Brocinnan being 5 MR. REINHART: Objection to the form, asks a 6 the editor and publisher of a publication of the Edge 6 compound question, several questions within one. 7 Foundation? 7 Also assumes knowledge of a person by the name 8 MR. REINHART: Object to the form. There is 8 of Jeffrey Epstein and a massage room, so there is 9 no foundation that she has any knowledge of any 9 no foundation. Instruct the witness not to answer. 1. entity by the name of the Edge Foundation, and 3. 0 THE WITNESS: At the instruction of my lawyer, 1 would instruct her not to answer the question based 1 1 i must invoke my Fifth Amendment right. 1 2 on her Fifth Amendment privilege. . 1 2 BY MS. EZELL: 1 3 THE WITNESS: At the instruction of my lawyer, 1 3 Q. Did you ever tell the girls to remove their 1 4 i must invoke my Fifth Amendment right. 1 4 clothes? 1 5 BY MS. EZELL: 5 MR. REENHART: Same objection and the same 1 6 Q. Did you participate in a scheme by Jeffrey J. 6 instruction. 1 7 Epstein to recruit underage girls to come to his 1 7 THE WITNESS: At the instruction of my lawyer, 3. 8 residence to provide massages? 1 8 i must invoke my Fifth Amendment right. 3. 9 MR. Objection to the form, calls 1 9 BY MS. EZELL: 2 for a legal conclusion. Also has no foundation as 2 Q. And did you sometimes deliver cash from the 2 1 to any knowledge of a person by the name of Jeffrey 2 3. defendant to the underage girls after they performed the 2 2 Epstein, and because it calls for a legal 22 massage? 2 3 conclusion, I'll simpiy instruct her not to answer 2 3 MR. REINHART: That's been asked at least 2 4 the question at all. Move on. 2 4 three or four other times. 2 5 2 5 MS. EZELL: I?m asking on behalf of my client. Page 442 Page 444 1 BY MS. EZELL: 1 MR. REENHART: I understand, but we've been 2 Q. Did you assist, support, and facilitate 2 here for over an hour, and we can'tjust keep going 3 Jeffrey Epstein?s child exploitation enterprise? 3 over. If they have been asked in the deposition, g; 4 MR. REINHART: Once again, objection the 4 your clients can have the benefit of the answer, 5 question, calls for a legal conclusion as to what 5 but we?ve been here now for almost eight hours and 6 is an enterprise, which is a term of art in the 6 you still -- '7 criminal law about which this witness has no 7 THE WITNESS: At the instruction of my lawyer, 8 knowledge, and it?s a legal conclusion not likely 8 i must invoice my Fifth Amendment right. 9 to lead to discoverable evidence. So i would 9 BY MS. EZELL: 1 instruct her not to answer the question at all. 1 Q. Did you ever take part in delivering cash ??orn 1 1 BY MS. EZELL: 1 1 the defendant to the procurers of the underage girls who it 1 2 Q. Did you arrange times for underage girls to 12 came for the massage appointments? 3 come to Jeffrey Epstein's residence? 13 MR. REINHART: Objection to the form. The 4 MR. REINHART: Objection to form, standing 1. 4 term procure is a legal term of art, and i?ll 1 5 objection previously stated. 1 5 instruct the witness not to respond to the question i 6 THE. WITNESS: At the instruction of my lawyer, 1 6 at all. 3. ?7 i must invoke my Fi?h Amendment privilege. 17 BY MS. EZELL: 3. 8 BY MS. EZELL: 3. 8 Q. Did you, did you by using the telephone assist 3. 9 . Q. Did you arrange, tranSport, or yourself 1 9 Jeffrey Epstein in enabling himself to commit sexual 2 tranSport underage girls to or from Jeffrey Bpstein?s . 2 0 battery on, and acts of lewdness in the presence of . 2 residence? 2 1 young women? 2 2 MR. Same objection, same 2 2 MR. REINHART: Same as the previous 2 3 instruction as the last question. 2 3 instruction. instruct the witness not to answer 2 4 THE WITNESS: At the instruction of my lawyer, 2 4 the question at all, because it results in a legal 2 5 i must invoke my Fifth Amendment privilege. 2 5 question, not a factual question, so it's not 20 (Pages 441 to 444 (561) 832*7500 COURT REPORTING AGENCY, INC. (561) 832~7506 Electronically signed by Rachel Bridge (201-272-617462?) Page 445 Page 447 1 reasonably designed to lead to discoverable 1 deposition or you may waive reading and aiiow the 2 evidence. 2 court reporter to simpiy type it up and distribute 3 BY MS. EZELL: 3 it to the iawyets who order it. 4 Q. Did you facilitate these acts as wait as 4 Do you choose to read or waive? 5 assisting Mr. Epstein in avoiding poiice detection? 5 THE WITNESS: Waive. 6 MR. REINHART: Same instruction. 6 MS. EZBLL: Thank you. ?7 BY MS. EZELL: '7 MR. REINHART: Thank you. 8 Q. Do you know when and by whom the computers 8 THE Okay, this conciudes 9 were removed from the El Briilo mansion? 9 today?s videotape deposition of Sarah Keiien. The 0 MR. REINHART: Objection to the form, lack of 0 time is 18:51. 1 it foundation, and it also assumes knowiedge of a 3. (Witness excused.) 12 place known as the Bi mansion. So instruct 12 (Deposition was concluded.) 3 the witness not to answer the question based on the 3 4 i Amendment. 1 4 5 THE WITNESS: At the instruction of my iawyer, 5 6 i must invoke rny Fifth Amendment right. 1 6 7 BY MS. EZELL: 7 8 Q. Was Jane No. 103 invited to just come and hang mansion? 1 9 2 0 MR. REWHART: Objection to the form, same as .2 2 1 the previous question. It assumes knowledge of a 2 2 2 piece known as the E1 mansion and a person 2 2 2 3 by the name of iane No. 103. It is compound and 2 3 2 4 tacking in foundation. 2 4 2 5 TEES WITNESS: at the instruction of my iawyer, 2 5 Page 446 Page 448 i rnust invoke my Fifth Amendment right. 1 1 A 3 Q. Have you caiied any giris under the age of 18 4 4 in Paint Beach or West Palm Beach in the iast six years? 5 Rad?? Bridge? Registered meessionai Reporter, Fionda Professronal Reporter and Notary 5 MR- REINHARTI For any Purim?? 6 Pubiic in and for the State of Florida at iarge, do 5 MS. Yes. hereby certify that I was authorized to and did report 7 THE WITNESS: Can you repeat the question? 3:216: 8 BY MS. EZELL: 8 shorthand notes of said deposition. 9 Q- wanedanygirtsundertheageom 9 in Pain} 333011 or we? Palm Bead} in the 135: Six Yea?? 18 that the taking of saidpdeposition was commenced and 1 1 MR. REINHARY: You can answer that yes or no, Compieted as hereinabove 38* outfurther certify that i am not attorney or 3. 3 THE WITNESS: i don't think so. l2 counsel of any of the parties, nor an: i a relative or 1 4 MS. EZELL: i don?t have any other questions. e?i?ptoyee any ?We? 0? .Of party ?in?amed . 3 With the action, nor am i financzaiiy interested In the 1 5 Thank you. action 1 a ma an set? 14 . . I 1 meme: Yes. it 8 THE YIDEOGRAPHER: This conciudes today's means uniess under the direct controi andfor direction 9 videotap? deposition of Sarah Kellen. is 0mm Apm, - 2 0 MR. REINHART: Hold on, i?m sony, one last 18 .4 2 1 thing. Since you?re theoiast defense person piaintiff?s lawyer standing, I guess you need to 21 If 2 3 advise her she has the right to read or waive on 2 2 2 4 the record. :2 2 5 MS. EZELL: You do have the right to read this 2 5 21 (Pages 445 to 448) (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (561) 832-3506 Etectronicaity signed by Rachel Bridge (201-272-617-4627) a summedmara?: areas-Mamet m1}. Miami/eschews: $359 Km: a?h? {ti DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISP TED FACTS Epstein v. Edwards, er a1. Case No. 50 2009 CA OAOSOOWMBAG ATTACHMENT 13 DEPO.EPSTEIN 0001 1 IN THE CIRCUIT COURT OF 15th 3UDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE 2008 5 JANE DOE, II 7 P1aintiff, 8 vs. 9 3EFFREY EPSTEIN, and SARAH KELLEN 10 Defendant. 11 12 13 OF THE WITNESS JEFFREY EPSTEIN 14 TAKEN BY THE P1aint5ff 0N May 7, 2009 0002 APPEARANCES: 2 3 ON BEHALF OF THE PLAINTIFF 4 GARCIA LAW FIRM 224 Datura Street, St. 900 5 West Pa1m Beach, FL 33401 6 BY: ISIDRO M. GARCIA 7 TARA A. FINNIGAN, P.A. 224 Datura Street, Suite 990 3 West Pa1m Beach, FL 33401 10 ON BEHALF OF THE DEFENDANT ll ATTERBURY GOLDBERGER WEISS, P.A. 250 Austra1ian Ave, South 12 west Pa1m Beach, FL 33401 13 BY: JACK A. GOLDBERGER, ESQ. 15 BURMAN, CRITTON, et 16 515 North F1ag1er Dr., St. 400 West Pa1m Beach, FL 33401 18 BY: 3. MICHAEL BURMAN I 3 WITNESS EXAMINATION PAGE ?age 1 DEPO.EPSTEIN 3EFFREY EPSTEIN Direct by Mr. Garcia 4 QUESTIONS MARKED FOR CERTIFICATION . (Identified with an asterisk on the fo1iowing pages.) PAGE NO. LINE NODeposition of JEFFREY EPSTEIN, a witness herein, taken on beha1f of the Piaintiff herein, For the purpose of discovery and For use as evidence in the above~entit1ed cause, before JULIE ANDOLPHO, Court Reporter and Notary Pub1ic in and for the State of Fiorida at Large, at 250 Austra1ian Avenue, West Pa1m Beach, state of F1orida, on May 7, 2009, commencing at or about 10:00 whereupon: BEFFREY EPSTEIN, a witness herein being of Tawfu1 age, and being First du1y sworn in above cause, testified on his oath as foiiows: ?age 2 questions regarding this present time my attorneys have counseied me I cannot DEPO.EPSTEIN DIRECT EXAMINATION BY MR. GARCIA: Piease state your foii name. Jeffrey Edward Epstein. where do you 1ive, Sir? United States Virgin Isiands. what is your home address? I intend to res ond to reievant awsuit, however, at the IMO P40 >40 provided any questions reievant to this 1awsuit. I must accept this advise or risk iosing my 6th amendment right to effective re resentation. Accordingiy, I assert my federa constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Does that mean you are not going to answer my question about your home address? MR. GOLDBERGER: He iust answered it, Sid. MR. GARCIA: To a1 questions w~ I mean MR. GOLDBERGER: record a second. MR. GARCIA: we can go off, I 1et's go off the Let's put i; 03 the record w? guess. Go_a ea . (whereupon there is a discussion off the record.) I BY MR. GARCIA: Do you have a home that you own in Paim Beach, the Town of Paim Beach? A As I have said in my previous questions and I repeat it. I intend to respond to reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk iosing my 6th amendment ri ht to effective representation. According y, I assert my federai constitutionai rights as guaranteed by 5th, 6th and 14th amendment of the United States Constitution. MR. GOLDBERGER: one second? MR. GARCIA: Let me ask on the record. Can we have a stipuiation that his answer wouid be the same to each question I pose? MR. GOLDBERGER: It's okay that the question he asked, but rather than you read Can we go off the record that. THE read it. MR. GOLDBERGER: A11 right. we?11 read it to you. Do you know Dainya Nida? A As I've said in response to questions asked of me so far, I intend to respond to reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this iawsuit. I must accept this advise or risk iosing my 6th amendment right to effective Page 3 DEPO. EPSTEIN representation. _Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States - Constitution. . who is sarah keiien? . A As I've said in response to a11 oestions previousiy asked of me, I intend to respon to a11 reievant questions regarding this 1awsoit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk iosing my 6th amendment ri ht to effective representation. According y, I assert my federai constitutionai rights as guaranteed by 5th, 6th and 14th amendment of the United States Constitution. Did you ever strike that. Did Dain a Nida ever come to your house in the Town of Pa Beach for any reason? A As I've said previousiy to questions asked of me, I intend to respond to reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk iosing my 6th amendment right to effective re resentation. Accordingiy, I assert my federa constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. when Dainya Nida came to your house, did she ever "w did you ever ask her to engage in sexuai acts with you? A Can you repeat the question? Yes. Did you ever, when Dainya Nida came to your house, did you ever ask her to engage in any sexuai acts with you? A As I've said in response to your other questions I intend to res end to a1] reievant questions regarding this awsuit, however, at the present time my attorneys have coonseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutiona} rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Mr. Epstein, I note for the record you're reading from a script, are you reading from a script? A As I've said in response to a1] questions asked of me, I intend to respond to a11 reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. MR. GARCIA: A11 right. Wei}, for the Page 4 DEPO. EPSTEIN record, since he is reading from the script I?m entitied to have a copy of what he's readin from and make it a deposition exhibit so like to make that document, at some point, exhibit 1. I see handwriting on it a150, I don?t know if you ciaim that to be an attorney ciient communication, I just want a copy of script he's reading from. MR. GOLDBERGER: The whoie document is attorney ciient priviiege and we're not giving it to you. If you want to fiie a motion, we' 3 have a hearing on it. MR. GARCIA: I wiH . DIRECT av MR. GARCIA: (cout?p) what is your present age? A 56. what is your date of birth? A January 20, 1953. Did you know the age of Dainya Nida when she came to your house in the Town of Paim Beach? A Can you repeat the question? Did you know the age of Dainya Nida when she came to your house in the Town of Palm Beach? A As I've said in response to your other questions, I intend to respond to a11 reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this iawsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Did on ever pay naiyna Nida any money for any services at she rendered to you? A As I've said in response to your other questions, I intend to respond to a11 reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this iawsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. In the answer in affirmative defenses that were fiied on your behaif in the case of Jane Doe, II vs. Jeffrey Epstein and Sarah Keiien, case number pending before Judge Hafeie you ciaim as your second affirmative defense the foiiowing, quote, "As to a1] counts aiieged, piaintif consented to and participated in conduct similar and/or identicai to the acts a11eged with other persons which was the soie and contributing cause of piaintiff's aiieged damages." what evidence if any do you have plaintiff consented to or participated in conduct simiiar and/or identicai to the acts aiieged with other persons and who are the other persons? A Can you repeat that question? MR. GARCIA: Before you read it back, 1et Page 5 DEPO. me put this on the record, that question can in no way invoke a 5th or 6th amendment priviie because it's not asking about his contact it asking about what evidence he has that she engaged in acts with other persons of a simiiar nature. MR. GOLDBERGER: It cou1d iead to incriminating evidence and, therefore, the question, once it?s read back, I anticipate the question not being answered. MR. GARCIA: why wouid it lead MR. GOLDBERGER: I'm not going to engage in that, I?m you I have a good faith basis invoking the 5th amendment. MR. GARCIA: Uniess he aiieged that he participated with the third persons. Anyway, read it back to him. (whereupon_the iast question is read back.) A As I've said in response to your other questions, I intend to respond to a11 reievant questions regarding this 1awsuit, however, at the present time my attorneys have counse1ed me I cannot rovide answers to any questions re1evant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. where were you born? A Excuse me, I didn?t Finish. I'm sorry. A According1y, I assert my Federa1 constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. - where were you born? In New York. what art? Brook yn. what neighborhood in Brookiyn? I don't understand the question. canarsie, Ba Shore? where was I born? Yeah. where did you grow up in Brookiyn, did you grow up in Brookiyn? A Yes. what part of Brook} did you grow up in iet me ask you this, what igh SC 003 did you attend? A Lafayette. And where did you 3ive through ww in high schooi, was there a particuiar neighborhood name? A As I?ve said in response to questions asked of me so far, I intend to respond to reievant questions regarding this 1awsuit, however 1et me withdraw that question. Did you attend coiiege? A Yes. I where did you attend c011ege? A As I've said in response to your other questions, I intend to respond to a1] reievant questions regarding this 1awsuit, however, at the Page 6 DEPO . present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. MR. GOLDBERGER: GO Off the record a second. (Discussion off the record.) DIRECT BY MR. GARCIA: Let me ask this, did you graduate from coiiege? A NO. right. Can you teii me what years you attended coiie e, if you did attend? A As I ve said in response to your other questions, I intend to respond to reievant questions regarding this iawsuit, however, at the present time my attorneys have counseied me I cannot rov1de answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. A17 right. Accordingiy mm I?m sorry. Shouid I go back to the beginning? You paused, I thought you were done. I assert my federa constitutiona] rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Did you graduate from Lafayette High Schooi? A Yes. A23 what year did you graduate? A . Were you in the service at any point? A 0. As to the third affirmative defense raised in the answer to affirmative defenses to this Barticuiar case you aiiege, or your iawyer on your ehaif aiieges, quote, "As to counts, defendant reasonabiy beiieved the piaintiff had attained the age of 18 years oid at the time of the aiieged acts." End quote. what made you reasonabiy beiieve that the piaintiff had aiieged 18 years of age at the time of the aiieged acts? A As I've said in response to your other questions, I intend to respond to reievant questions regarding this iawsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. what states, besides the State of Fiorida, do you presentiy own a home in, if any? A As I've said in response to your other Page 7 HM HM cum DEPO.EPSTEIN questions, I intend to respond to a1] reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions re1evant to this 1awsuit. I must accept this advise or risk 1osing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Are you currentiy residing in the Paim Beach County Jaii? A Yes. Are you schedu1ed to be re1eased at some future date from the Paim Beach County Baii? A Yes. Do you know when that date is? A No. Are you on some sort of fur1ough or home reiease program, I don?t know what it's ca11ed exact1y, where you get to 1eave the Paim Beach County 3ai3 every morning and return at ni ht? MR. GOLDBERGER: You have to rep rase the question. If you're asking if he's on house arrest the answer is no. I don't know what it's caiied MR. GOLDBERGER: ask him if he's on work reiease. Are you on work reiease? A Yes. what time do you ieave the Palm Beach Jaii each morning? 8 a.m. what time are you required to be back? County A 8 p.m. where do you work during these hours? As I've said in response to your other questions, I intend to respond to a1? reievant questions regarding this iawsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk 1osing my 6th amendment right to effective representation. Accordingiy, I assert my federal constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. can we take a restroom break? Sure. (whereUpon a break is taken.) DIRECT BY MR. GARCIA: Can you te]? me what days you are participating in this work reiease program, whether Monday through Friday or is it every day of the week? A Monday through Saturday. Do you have an office somewhere for your business that is separate from your home? A As I've said in response to your other questions, I intend to respond to re1evant .0 questions_regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot Page 8 sud HH WM DEPO.EPSTEIN rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Have you ever been charged with a crimina1 offense? MR. GOLDBERGER: You can answer that. A Yes. And where were you charged with a criminai offense? A Paim Beach. And was it a charge brought by the state or the federai prosecutor? A State. Do you know what the charged crime was? A Yes. what was it? A Soiiciting prostitutes. Did you take a piea in that case? A Yes. And what did you piead guiity to or did you piead guilty? . A I aiready answered that question. You did piead guiity? A Yes. Did you piead guiity to that specific crime? A Yes. And what sentence was there a sentence that was agreed upon or was it imposed by the court without agreement? A It was agreed. And what was the sentence? A Tweive months in the county jaii. Any other conditions? A No. And was work reiease part of the agreement? A NO You appiied for work reiease after you started serving time in the county jaii? A Yes, Sir. And was that agreed to by the state prosecutors office? A I don?t know. Any other conditions besides 12 months in the county jaii? MR. GOLDBERGER: As the question is phrased that was a sentence to the solicitation. I?m sorry? A That was the sentence to the soiicitation of prostitution. And was it a singie count or muitipie counts? A Singie. who was the ai3eged victim? A As I've said in response to your other questions, I intend to respond to a1? reievant Page 9 DE P0. EPSTEIN questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Were you, if you know, were you indicted by a grand jury or was the charge direct fiied by state attorney? A Indicted by a grand jury. Did the grand jury, if you know, consider any other charges? A I don't know. Did you testify before the grand jury? MR. GOLDBERGER: Go ahead and answer that. A No. were you asked to testify 1et me ask this, were you offered the opportunity to testify? A I don't know. ?d 7Q when is the first time that you met Daiyna Ni a. A As I?ve said in response to your other questions, I intend to respond to reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this iawsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Have you ever been charged in any other court of the United States or abroad for any crime? MR. GOLDBERGER: You have to rephrase the question. Other than soiicitation for prostitution? MR. GARCIA: Other than this one case that he taiked about in Paim Beach County. MR. GOLDBERGER: what one case are you taiking about? MR. GARCIA: where he said the grand jury indicted him for soiicitation of prostitution. A Couid you repeat the question? Have you ever been charged of a crime in any other court in the United States or abroad besides the charge that you discussed soiicitation of prostitution? A I don?t understand the question. what?s a crime, is that a traffic ticket? NO. A Is it since I?m 18? Yeah, since you're 18. MR. GOLDBERGER: condense the question. I want to make sure he answers the question accurateiy so ask the question one more time and then we'ii get an answer. Ever been char ed with a misdemeanor or a feiony ievei criminai of ense in any court in the United States or abroad besides the one you?ve Page 10 DEPO.EPSTEIN aiready discussed? A Not that I remember. MR. GOLDBERGER: He?s going to ciarify answer. Another charge in Paim Beach. what was the other charge? A Procuring minors for prostitution. And what agency or what prosecutors office charged you with that crime? A State attorney. Did you piead guiity to that as we11? A Yes. So did you piead gui1ty to two separate that A offenses? A Yes. Is that with a singie minor or muitipie minors in terms of what you piead ui1ty to? A I intend evant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Are you a registered sex offender? A Yes. was that part of the piea agreement that you made with the State Attorneys Office? MR. GOLDBERGER: If you know. A Yes. I had asked you before if there were any other conditions of your piea, you didn't mention that, is that is there anything eise that you haven't mentioned that's part of your piea agreement? MR. GOLDBERGER: You asked him what the conditions were of the soiicitation of the Rrostitution charge that he pied guiity to and answered that question. MR. GARCIA: I see. He hadn't reveaied he pied guiity to a different charge which is procuring the minor for prostitution. MR. GOLDBERGER: You didn't ask him that. DIRECT BY MR. GARCIA: Are there any other conditions for either crime that you apparentiy pied guiity to in Paim Beach County, any other conditions besides the 12 months or atever period of time you mentioned in the county jaii and being a registered sex offender? ?1 A An additiona} six months in the county 3ai . An additionai six months? A Yes. The totai sentence is 18 months, yes? A That's 12 pius 6. Okay. And what eise? A One year of community controi. community centre? in Paim Beach County or Page 11 DEPO.EPSTEIN somewhere eise? A Community controi. Are you aiiowed to ieave the county during that one year? A I don't know. Have you made any agreement with the United States Attorneys Office concerning a deferred prosecution or pretriai intervention?type of program? MR. GOLDBERGER: You know, I'm kind of Mike is feeiing the same way I am I'm kind of giving you eeway to ask some questions here that may be arguabiy reievant but we're getting into areas that are not reievant and it appears to me that you're just asking the questions to embarrass Mr. Epstein so I'm going to give you a 1ittie more 1eeway but at some point I'm oin?_to cut it off if you go too far. 1'11 et 1m answer that. MR. GARCIA: I'm 'ust asking about any agreements he made if made an agreement. Have you made any agreements with the U.S. Attorneys Office to avoid eing prosecuted for any federai offenses? MR. GOLDBERGER: phrased, Sid MR. GARCIA: iet's go back to the previous question, there was no objection to it. Read that back. (whereupon the Foiiowing question is read back:) Have you made any agreement with the United States Attorneys Office concerning a deferred prosecution or pretriai of program?" The way that question was A Yes. And do you know what the agreement is? A Yes. what does the agreement caii for? A The agreement states what it states. weii, can you summarize it for me? A No. MR. BURMAN: Object to the form. Do you have an understanding of the agreement? MR. BURMAN: Object to the form. what is your understanding of the agreement? MR. BURMAN: Object to the form of the question. You can answer it. MR. GOLDBERGER: can you give me a hint as to why you think that's arguab reievant? MR. GARCIA: we may move to seek to enforce the agreement. We may add a count for just a third party beneficiary of that agreement for breach of contract ciaim. are endiess here. MR. GOLDBERGER: That's fine, if you want to do that you can do that but Mr. Epstein's understanding of what the agreement is 1egai1y you can do what you can Page 12 The DEPO.EPSTEZN MR. GARCIA: he's a party of the agreement, his understanding of what the agreement is is cruciai to whether or not there is a agreement and what the agreement and terms are. DZRECT BY MR. GARCIA: Uniess they instruct you not to answer, you have to answer question and that question does not vioiate anybody's priviiege against seifwincrimination. MR. GOLDBERGER: Go ahead and answer. A Repeat the question. Sure. what is your understanding of the agreement made with the U.S. Attorneys Office? A That if I abide by the terms and conditions of the agreement I not be prosecuted. A31 right. Did you Sign that agreement? A Yes. Did you have a opgortunity to reFTegt on the terms of the agreement efore you signed it? A Yes. Did you have advice of counsei before you Signed it? A Yes. . A11 right. Was the agreement ever modified? A Yes. why was it modified, if you know? A (Modding). You don know? You're shaking your head, but I don't know what that means. MR. GOLDBERGER: I think that wouid ca11 For Mr. Epstein to kind of revea} attorney ciient priviiege so 1'71 advise him not to answer the question. MR. GARCIA: A11 right. who is Gera1d Lefcourt, MR. GOLDBERGER: It wouid invoive attorney ciient priviiege. He?s not answering that question. MR. GARCIA: 3 just want to know who he 35. MR. GOLDBERGER: He?s a 1awyer. Did he represent you in these negotiations? THE WITNESS: that agreement? MR. GOLDBERGER: I don't know. MR. GARCIA: IS he not going to answer who Geraid Lefcourt is? MR. GOLDBERGER: Correct. who is Sanchez? MR. GOLDBERGER: He's not going to answer How does he have a copy of any questions that wou1d invo1ve reveaiing attorney c1ient priviiege. THE WITNESS: can I have a second with you? MR. GARCIA: Just to save some time, I Page 13 DEPO.EPSTEIN signed the nondisciosure a reement that's why I have this, if that's what is oestion is. MR. GOLDBERGER: what non isciosure agreement? MR. GARCIA: Apparentig there is something the u.s. Attorney requires efore turning over this document, you have to sign some sort of agreement not to disciose, if that's his concern. MR. GOLDBERGER: It is of concern so 1et me ciarify this. You signed some sort of nondisciosure agreement with the U.S. Attorney? MR. GARCIA: Yes. MR. GOLDBERGER: what v.5. Attorne MR. GARCIA: whoever is handiing this MR. GOLDBERGER: who wouid that be? MR. GARCIA: I beiieve it's she's the one who signed the agreement. There is some sort of protective order, if I understand, that was entered by Judge Mara requiring any party who is given this agreement to sign the agreement not to disciose it to anyone, Marie Veafona (phonetic). MR. GOLDBERGER: So you contacted Ms. Veafona and she had you sign a nondisciosure agreement? MR. GARCIA: That?s why I don't want to make it an exhibit to this deposition because I don't want the court reporter to see it. I want to Show it to the witness so he can identify it for me MR. GOLDBERGER: 1et me see what you're going to show him? (Handing) MR. GARCIA: Its got the addendum, too. MR. GOLDBERGER: So what's your uestion? MR. GARCIA: My question is di he sign the originai agreement, did he sign the addendum to it and what dates did he sign those. I beiieve they're dated. MR. GOLDBERGER: I don't know how you can ask questions about a document that is not to be reduced and make it part of a deposition wit out vioiating the non MR. GARCIA: mm weii, I assume it can be produced to him and to his iawyers. MR. GOLDBERGER: By acknowiedging the existence of a a reement it vioiates the terms of the secrecy the document, correct? MR. GARCIA: I don?t think SO. MR. GOLDBERGER: I think it does. MR. GARCIA: I think it restricts disciosures to third parties. - MR. GOLDBERGER: I'm going to instruct him not to answer any questions about the agreement. If you want to see the judge on is, we can. If you?re right, you re right; it you?re not, you?re not. Out of an abundance of caution I'm not going to have him answer any questions about it right now. Page 14 DEPO.EPSTEIN BY MR. GARCIA: Can you give me an exempiar of how you sign your name? (No-response). MR. GARCIA: Come on, incriminate him. MR. GOLDBERGER: that doesn't YES "m MR. GARCIA: for a crime, his Signature? A I intend to res 0nd to a11 reievant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this iawsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States constitution. Do you have a preference for women under the age of 18? A As I've said in response to uestions previousiy asked of me, I intend to respon to reievant questions regarding this iawsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk iosing my 6th amendment ri ht to effective representation. According y, I assert my federai constitutionai rights as guaranteed by 5th, 6th and 14th amendment of the United States Constitution. Have you ever been married? A No. Have you ever been engaged? MR. BURMAN: Go ahead and answer it. A No. Do you have any empioyees? A Excuse me? Do ou have any empioyees? A Emp oyees? Yes. A I intend to res ond to reievant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Do you have a company that is incorporated anywhere? MR. GOLDBERGER: question. Do you own are you invoived in any business, any type of enterprise where your business is incorporated in any state? A As I've said in response to previousiy asked of me, I intend to respon That's kind of a vague uestions to a11 reievant questions regarding this iawsuit, however, Page 15 DEPO. EPSTEIN at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk losing my 6th amendment ri ht to effective representation. According y, I assert my federai constitutionai rights as guaranteed by 5th, 6th and 14th amendment of the United States Constitution. when you are on work reiease Monday through Saturday pursuant to your agreement with either the Sheriff's Office and/or the Prosecutor's Office here iocaiiy, do you actuaiiy do any work? MR. GOLDBERGER: we're not going to answer that question. Bring that to the judge. MR. GARCIA: why? MR. GOLDBERGER: It's just to embarrass him. what?s the ossibie purpose of that reievant to your awsuit. it just reaiiy serves no purpose, Mr. Garcia. h? 7 MR. GARCIA: why wouid working embarrass 1m. MR. GOLDQERGER: I don't know the . reievance of it. I'm reaiiy going be f1ex1b1e and aiiow you to ask any questions even marginaiiy reievant MR. GARCIA: I just want to know how he's Spending him time out of 'aii MR. GOLDBERGER: why is at of issue to you? I MR. It may iead to the discovery of adm7551b3e ev1dence. . A Then that's an easy answer. As I've said in response to questions reviousiy asked of me, I intend to res and to a11 re evant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk iosing my 6th amendment right to effective re resentation. Accordingiy, I assert my federa constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. where does sarah Keiien presentiy iive? A As I've said in response to some of your other questions, I intend to respond to a1} reievant questions regarding this 3awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this iawsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Has sarah Keiien visited you during your stay at the Paim Beach County Jai]? A Yes. How many times? A I don't know. Do you know when she visited you 1ast? A NO. what did you discuss with her? Page 16 DEPO.EPSTEIN A As I've said in response to a1} uestions previousiy asked of me, I intend to respon to a11 reievant questions regarding this iawsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk iosing my 6th amendment ri ht to effective representation. According y, I assert my federai constitutiona] rights as guaranteed by 5th, 6th and 14th amendment of the United States Constitution. Have you A one second can you grab my IPhone? Have you discussed with Ms. Keiien providing, at your expense, 1egai representation for any c1aims made against her? MR. Go ahead. As I've said in response to a1] uestions prev1ousiy asked of me, I intend to respon to a11 reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk iosing my 6th amendment ri ht to effective representation. According y, I assert my federai constitutionai rights as guaranteed by 5th, 6th and 14th amendment of the United States Constitution. Did you hire David Spicer at one time to represent you in this case? MR. GOLDBERGER: You can answer that. A Yes. Is he . A what was the question again, sorry? (whereupon there is a ringing sound.) THE WITNESS: I have to take this outside. (whereupon a break is taken.) DIRECT BY MR. GARCIA: David Spicer, I think I was asking you about him, is he representing you now? A No, he's not. DO you know why he represented you at 1east for a brief time in this case? A I considered hiring him and decided not to. oid you hire him for any other case beSides this case? . A This case meaning what? .d The case that we re here on today Dainya N1 a. MR. GOLDBERGER: I think during the discussions there wouid have been an attorney ciient reiationship. MR. GARCIAthis way. Did he fiie an appearance in any other case other than this case invo1ving Dainya Nida? A I don't know. I But he's no ionger representing you? A Correct. Were_you ever interviewed by the Town of raim Beach Poiice Department concerning any aiieged Page 17 a DEPO.EPSTEIN criminai wronnging on your part? A (No response). MR. GARCIA: I ?ust want to know if he was interviewed, not contents of the interview at this point. A P1ease rephrase the question, you ta1k about oniy in certain w~ traffic tickets a ain? No. No. Forget the traffic tic ets, just these cases invoiving the aiieged sexuai misconduct on your part. A NO. were you ever interviewed by the Federai Bureau of Investigation in any of these caseshome at 358 E1 Way in Paim Beach, orida? MR. BURMAN: In addition to what he's going to read, I'm going to object on the grounds that this depOSition is being taken in a state case and that there's been no approvai of a ciaim for gunitive damages and that gues?ion wouid directed towards financiai wort . MR. GARCIA: I'm trying to find out if that is aiieged to be the scene of the events, I'm trying to estab1ish whether or not it was or it wasn't. A Was it the scene of the events in question? No. I think my question w? I was expiaining to your 1awyer why I?m asking the question. The question is iet me as this way. Have you ever resided at a home at 358 ?1 Way. THE COURT REPORTER: I need to go off the record due to computer difficuities. MR. GARCIA: Sure. (whereupon a break is taken.) MR. GARCIA: Back on the record. DIRECT BY MR. GARCIA: Did you keep any sex toys at that home? A As I've said in response to some of our other questions, I intend to respond to a1} re evant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingly, I assert my federal constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Did you ever penetrate Dainya Nida's vagina using your fingers? A I intend to res ond to reievant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk Tosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai Page 18 DEPO.EPSTEIN rights as guaranteed by the 5th, 6th_and_l4th amendment of the United States Constitution. 9 when do you intend to answer these questions? . A I intend to res end to reievant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Did you ever teii Dainya Nida that she a mode}? I intend to res end to reievant regarding this awsuit, however, at the shouid be A questions present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Did you ever offer Dainya Nida heip in becoming a modei? MR. GARCIA: For the record, the witness has been shaking his head and in response to?the 1ast few questions. MR. GOLDBERGER: I disagree with that assertion that that is what is happening, but you can say what you want for the record. MR. BURMAN: I didn't see it. A I intend to res 0nd to reievant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Did you ever teii Dainya Nida ou couid not wait untii she was 18 so you couid her to Paris? A As I've said in response to some of the questions previousiy asked of me, I intend to respond to reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. 2 must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federal constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Did you aiways pay the same amount for sexuai services for Dainya Nida? MR. GOLDBERGER: Form. . A I intend to respond to reievant questions regarding this iawsuit, however, at the Page 19 DEPO.EPSTEIN present time my attorneys have counseied me I cannot rovide answers to any questions re1evant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutional rights as guaranteed by the 5th, 6th and 14th amendment of the United States constitution. Did you ever offer Dainya Nida additionai monies if she ad sexuai intercourse with you? A I intend to respond to a1] reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk 1osing my 6th amendment right to effective representation. According1y, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Let me expiain and put on the record this is about MR. GARCIA: Let me einain and put on the record that this is about second conference during the deposition. In a civii case if a witness confers during a deposition with his counsei I'm entitled to find out what that discussion was about. *I'm going to go ahead and ask what did you just discuss with your counsei? MR. BURMAN: I disagree with that, it's attorney c1ient priviiege and I instruct him not to answer that. MR. GARCIA: Okay. Certify that question and print it up right away. Did you ever give oainya Nida any gifts besides cash? MR. GOLDBERGER: You can answer. A As I've said in res onse to some of your other guestions previousiy as ed of me, I intend to respon to a11 reievant questions regarding this 3awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Do you know a Detective Siivestri? A NO. Do you know an officer with the Town of Paim Beach either throng a traffic citation they may have written for you or maybe you caiied them out for some issue at your home? A Not that I reca11. - Has the Town of Pa1m Beach Poiice ever been to your home on way? Object to the form. A I intend to res end to reievant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this Page 20 DEPO.EPSTEIN iawsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. take a break? Absoiuteiy. I want to put on the record that any discussion had with counsei during a break in the deposition A he's not coming with me. Okay, MR. GOLDBERGER: I'm going to check my messages, you want to send a monitor with me? MR. GARCIA: NO. (whereupon a break is taken.) DIRECT BY MR. GARCIA: Do you have any escort From the Paim Beach County Sheriff's Office when you go on your work reiease program? A I don?t understand the question. Does anybody from the Sheriff's Office may we transport you when you?re on work reiease? A NO. No. so you travei on your ownwherever you go when you're reieased for work? -As I've said in response to many of your questions asked of me, I intend to respond to reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk iosing my 6th amendment ri ht to effective representation. According y, I assert my federai constitutionai rights as guaranteed by 5th, 6th and 14th amendment of the United States Constitution. Are you housed at the Pain Beach County Stockade or at the main jaii on Gun Ciub Road? A Housed, Stockade. *Are you with the generai popuiation? MR. GOLDBERGER: I Just not geing to answer any more questions about where he's iiving at the Paim Beach County Stockade, it?s got zero reievance. I respect your rights to you want a judge to teii them I'd be happy to but it's irreievant to ask the questions, if Us he's got to answer honestiy, Mr. Garcia, anything you're doing. MR. GARCIA: A right, certify the question. MR. GOLDBERGER: okay: MR. GARCIA: Your ba51s is reievance? MR. GOLDBERGER: No, it's the purpose of this is to embarrass Mr. Epstein and to him. DIRECT BY MR. GARCIA: *Do you have a written agreement concerning your work reiease program in terms of where you can go, what time you get to 1eave, what Page 21 16 17 18 20 DEPO.EPSTEIN time you get to come back? MR. BURMAN: Teii him not to answer. Object to the form. Don?t answer it. MR. GARCIA: Certify that question. MR. BURMAN: we'11 assert his priviiege to privacy. is Robert Josephsberg? A He?s an attorney. . what was his roie in terms of, if any d1d he have any roie in terms of the agreement between the U.S. Attorney's Office and yourseif? MR. GOLDBERGER: Object to the form. A what's his MR. GOLDBERGER: object to the form and invoke attorney ciient priViiege on beha1f of Mr. Epstein. MR. GARCIA: I'm not asking him to disciose what he discussed with you or any other attorneys. MR. GOLDBERGER: can answer that. MR. GARCIA: That's the oniy way he That's a speaking objection MR. GOLDBERGER: mm I don?t want to you?re right. MR. GARCIA: I want to know if he has an understanding on his own without your interpretation of the understanding as to what Mr. Josephsberg's roie was or is in terms of your agreement with the v.5. Attorney's office. A I unciear. Okay. Are you abie to testify in terms of how many times Ms. Nida came to your house in the Town of Paim Beach? MR. GOLDBERGER: object to the form. A As I have responded to some of your previous questions, I intend to respond to a11 reievant questions regarding this 1awsuit. however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk 1osing my 6th amendment ri ht to effective representation. According y, I assert my federal constitutionai rights as guaranteed by 5th, 6th and 14th amendment of the United States Constitution. At any point did any iaw enforcement authorities seize your home and/or business computers? A I intend to res ond to a11 reievant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. According1y, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. I note for the record you have some sort of teiephone device and you've been receiving phone Page 22 MN [Acamumnqcunouxnnd ewe DEPO.EPSTEIN caiis and A I have not received any phone caiis. 0r messages. . A No, I haven?t received anything. You haven?t received anyt ing during the deposition? A No, Sin. Are you aiiowed to have mw is it a teiephone? A Yes. A11 right. Are you aiiowed to have this teiephone durin your work reiease hours? A I've een using it as a ciock, Sir. Okay. I want to know if you if you're ?iiowgd to have a teiephone during work reiease ours. A Yes. Is this a teiephone, is it a smart phone? A I'm sorry, I don't know what that means. Is it a Biackberry? A I?m not very fami iar with these things. Sorry. what's the brand of it? MR. GOLDBERGER: Don?t answer this. TEE WITNESS: Okay. *Do you have access to the internet on that phone? MR. GOLDBERGER: Don't answer. MR. GARCIA: On what grounds? MR. GOLDBERGER: on grounds that it?s none of your business. MR. GARCIA: You can?t do that in a civii case, you can't say it's none of your business, it's not a 1egaT jection. MR. BURMAN: He's correct. I'm tailing him not to answer on the grounds it?s a privacy priviiege. MR. GARCIA: certify the question. DIRECT BY MR. GARCIA: Are you aiiowed to have this device, whatever it may be, in jaii? A NO. MR. BURMAN: Same objection. Don't answer, it?s privac priViiege. MR. GARCIA: ay. Are you abie to receive emaii transmissions on the phone? MR. BURMAN: Same objection. Don't answer it, priviiege, privacy. Have you received any emaii communications from sarah Keiien in the past iet me ask this, when were ou first incarcerated at the Paim Beach County 3ai when was A June 30. June 30 of what year? A This year, sorry, 08. Have you received any emaii transmissions from Sarah Keiien since June 30 of 2008? MR. BURMAN: Same objection. Don't answer on the basis of priviiege of privacy he has under the Fiorida Constitution. Page 23 DEPO.EPSTEIN A I intend to res end to reievant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. who is your service provider for that phone? MR. BURMAN: Same objection, privacy, priviiege. Don't answer it. MR. GOLDBERGER: A150 form. A13 right. You can answer. MR. BURMAN: couid 2 just inquire for the record, is there some aiiegation that Mr. Epstein has tried to make contact with your ciient? MR. GARCIA: NO. MR. BURMAN: Okay. Thank you. BY MR. GARCIA: You can answer the question. A I don't know. *You don't know who your service provider 35. MR. GOLDBERGER: You just invoked privacy MR. GARCIA: he didn?t instruct him not to answer. MR. BURMAN: I'm him now. Thanks for reminding me. MR. GARCIA: Certify the question. *what's the phone number associated with this particuiar phone? MR. BURMAN: same objection, privacy priviiege. Don?t answer. MR. GARCIA: certify the question. *How iong have you ad this particuiar phone? MR. BURMAN: Same objection, priviiege of privacy. Don't answer. *How iong have you had this particuiar phone number? MR. BURMAN: Same objection, privacy, priviiege. Don't answer. MR. GARCIA: Certify a1} those questions as weii. Did you ever tei] Dainya Nida that you wanted the encounter with her to be like a, quote, "a porn video," end quote? MR. GOLDBERGER: Object to the form. A As I have previousiy responded to many of your other questions, I intend to respond to reievant questions regarding this iawsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this iawsuit. I must accept this advise or risk iosing my 6th amendment ri ht to effective representation. According y, I assert mK federai constitutionai rights as guaranteed by 5th, 6th Page 24 DEPO.EPSTEIN and 14th amendment of the United States Constitution. You can answer. A As I've said in response to some of your other questions asked of me, I intend to respond to reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk Tosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Have you been invoived in any other persona1 1itigation where you are a party to a awsuit aSide from these cases, and I?m inciuding Dain a Nida and the other cases that have made simi ar aiiegations, have you ever been a party to any other type of 1awsuit personaiiy? A Yes. A31 right. Any in Paim Beach County? A Maybe. There's something in the paper about a contractor suing you for buiiding a dock or something, are ou with that case? A Somew at, not very much. Anything besides that, any other cases in Paim Beach County besides the unpaid dock case? A Not that I recaii. How about in New York? A You have to teghrase the_question. Have you ever een sued ihdiViduaiiy as a person as opposed to your corgorate entity, if you ave one which we don?t know ecause you aven't answered that question, in your personai capacity individuaiiy in the State of New York? Ever? Yes. I beiieve so. You beiieve so. I have no idea. You know what the nature of the ciaim was, was it a breach of MR. GOLDBERGER: object to the form. MR. BURMAN: Object to the form. MR. GOLDBERGER: Let me just m? we?ve gone aimost two hours now, I'd iike to stop at 12 for 1unch if we can. THE WITNESS: Can we stop at one for How many times? 1unch? MR. GARCIA: I think we?ii be done before that, before 1:00 for sure. MR. GOLDBERGER: Okay. DIRECT BY MR. GARCIA: what was your answer? A You have to repeat the question. (whereupon the foiiowin question is read back:) ?0 You know at the nature of the ciaim was, was it a breach of ww Page 25 DEPO.EPSTEIN MR. GOLDBERGER: object to the form. In other words, what kind of 1awsuit was it in New York, or iawsuits, piurai, that was fiied against you in New York? A I don?t understand the question. You cannot answer the question? A I don?t understand the question. I asked you if you had ever been sued in the State of New York, I think your answer was yes, and now I'm asking for what kind of a 1awsuit was it that was fiied against you? A Again, I don?t understand the question. If I was sued over the past 20 years in ten different cases I?m not sure of what case you're referring to. I'm not referring to any particuiar case. I'm asking you to teii me what kind of suit was brought against you. In other words, at some p01nt in time you were served with a iawsuit, presumably you 0 ened it up and had taken a iook at it and possi 1y given depositions in the suit just 1ike you are giving your deposition today, so I'm asking you do you know what kind of 1awsuit was fiied against you, or 1awsuits, were fiied against you in the State of New York? A No, I don't. You don't know? A NO. Have you ever given a deposition before today? A Yes. In what type of case? MR. GOLDBERGER: AS best as you can recaii. A A securities case, I beiieve. Okay. And were you sued or were you suing someone? Both. who brought the suit originaiiy you I don know. where was the deposition taken? My best recoiiection is New York. And what year was this iawsuit? I don't remember. Ten years ago. More than ten ears, Tess than ten years? Ten years, may more than ten years. And was that the oniy deposition you've ever given? A That I recaii. I Have you ever given a deposition in any of these cases invoiving a1 egations such as were made by Dainya Nida? MR. BURMAN: Ob%ect to the form. Id what are the a1 egations made by Dainya N1 a. 03>03> Weii, I'm taiking about the cases where you took a deferred plea agreement with the U.S. Attorney's office, six or seven young women that you aiiegediy performed sexuai acts with. A That's not the case. what's that? Page 26 DEPO.EPSTEIN MR. GOLDBERGER: I have no idea what the question is but out of an abundance of caution, piease u~ I?m just asking if you've given a deposition in any of these cases? MR. GOLDBERGER: what cases? MR. GARCIA: You want me to read the names of the aiieged victims? MR. GOLDBERGER: Sure. Sure. Wei}, I can?t find my 1ist, I do have a 1ist somewhere but I'm taiking about these cases where it is aiieged that you soTicited or had others soiicit for you young women under the age of 18 to come to your house on Way and for them and you to perform certain sexuai acts, and I reaiize that you have every right to contest whether any of that occurred, but my question is have you given a deposition invoiving those issues in any of those cases that have been brought against you? MR. GOLDBERGER: The form of the question is I want him to answer the question but the form makes 1t very difficuit. MR. GARCIA: why? MR. GOLDBERGER: Because you're suggesting MR. GARCIA: w" I am not suggesting anything. I?m asking him has he given a deposition in any of the cases invoiving simiiar aiiegations. MR. GOLDBERGER: I need specific case and then we wii MR. GARCIA: on to ask a be happy to "w I'm not going to abie to give you a_specitic case. He can answer the question. MR. GOLDBERGER: Under the circumstances, I need you to invoke your privileges. A I intend to res ond to a11 reievant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. A11 right. Have you given a deposition in the past two years? Yes. In what case? MR. GOLDBERGER: E.W. Yes. what are the aiiegations in that case against you? I don't know. You were never served with a compiaint? You can answer that. 03>03> 03> Ifm sure I was. 01d you read the compiaint? N0. Page 27 DEPO . EPSTEIN who is the attorney that took your deposition? MR. GOLDBERGER: THE WITNESS: Do you know? No. where did the deposition take piace? A Here. At this office? A Yes. Did you ever ask Dainya Nida to bring other young women to your home on way? A As I've said in response to some of our other questions, I intend to respond to re evant questions regarding this iawsuit, however, at the present time my attorneys have counseied me 2 cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Q. In the past three years, have you destroyed any computer fiies of computers that you used or controiied? A As I've said in response to questions many of the questions asked of me, I intend to respond to reievant questions regarding this iawsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this iawsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. who is Adriana Ross? A As I've said in response to many of your questions asked of me, I intend to respond to reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this iawsuit. I must accept this advise or risk iosing my 6th amendment ri ht to effective representation. According y, I assert my federai constitutionai rights as guaranteed by 5th, 6th and 14th amendment of the United States Constitution. who is Lesiie Grotf (phonetic)? A As I?ve said in response to the questions asked of me, I intend to respond to relevant questions regarding this iawsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States constitution. who is Nadia Marcinkova? MR. GOLDBERGER: Here's the probiem, Mr. Garcia, to the extent that you are reviewing this agreement that was not to be Page 28 DEM). EPSTEIN made pubiic, one of the main reasons why it was not to be made pub1ic is so that the names are not reveaied and you are vioiating the spirit of the nonadisciosure agreement by asking questions that come off the document that you have for very 1imited purposes. You can ask, go ahead, but I caution you that you very, very wei] may be vioiating the nondisciosure provision of the agreement and I note when you showed me the agreement you had received eariier from the U.S. Attorney there's an emaii attachment to that that very, very carefuiiy cautions you that it's a priv11eged document and for your use oniy and not to be pub1ished anywhere. MR. GARCIA: Okay. BY MR. GARCIA: Answer my question, Sir. A I intend to res end to a11 reievant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk 1osing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Have you ever asked Sarah Keiien, Adriana Ross, tesiie Groff or Nadia Marcinkova to find and soiicit on your behaif young women to provide prostitution services for you? MR. BURMAN: object to the form. You can answer. A As I've said in response to some of your other questions, I intend to respond to reievant questions regarding this iawsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the united States Constitution. I may have asked you this aiready, I apoiogize if I?m being a iittie bit repetitive, has Sarah Keiien, Adriana Ross, Lesiie Groff or Nadia Marcinkova ever been empioyed by you or any other business entity you own or contro A I intend to res ond to a1? reievant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutiona1 rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. *For the record, this is the second conference you've had with counsei which I can?t hear so I'm going to ask you again the 1ast two conferences during this period of questioning teii Page 29 NH DEPO.EPSTEIN me what you discussed with counsei. MR. BURMAN: object, attorney ciient priviiege aiso work product privi ego and instruct him not to answer. MR. GARCIA: Certify those questions. MR. GOLDBERGER: And I have no obiigation to teii you based on those priviieges being invoked. MR. GARCIA: You?re wrong. I can teii you there's case iaw right on point and I'd be happy to Show it to you. an. GOLDBERGER: We can deai with that at another time but if you reaiiy must know the concern is that you continue to vioiate the nondisciosure provisions of the nonwprosecution agreement in direct contravention of what the agreement was as to what use you can make of It. MR. GARCIA: He's not-a third party, he's an actuai party to the agreement and my eiient is a third party benefic1ary to the agreement and I have not provided the a reement to any third party in accordance wit my agreement with U.S. Attorney's Office. Let me have a coupie of minutes, I'm aimost wrapped up. I just have to find something, it wi i be a coupie of minutes. (w ereupon a break is taken.) DIRECT BY MR. GARCIA: Did you ever soiicit or have someone soiicit on your behaif a young woman named Britt to perform sexuai services for you at your home on Way in Paim Beach? MR. GOLDBERGER: Object to form. A As I've said in response to some of your other questions, I intend to respond to relevant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Did you ever soiicit or have someone soiicit on your behaif a young woman whose first name is Aiexis for the purposes of performing prostitution services for you in your home on way in Paim Beach? MR. BURMAN: Object to the form. A As I've said in response to some of your other questions, I intend to respond to a1} reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Page 30 DEPO.EPSTEIN A13 right. Did ou ever soiicit or have someone soiicit on your be aif a young woman by the name of Rhianin (phonetic) to perform prostitution services for you in your home on Way in Paim Beach? MR. BURMAN: Object to the form. A As I've said in response to other questions of a simiiar nature, I intend to respond to reievant questions regarding this 1awsuit, however, at the present time my attorneys have counse1ed me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federa1 constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. MR. GARCIA: 2?11 just note for the record Mr. Epstein just assed a note that he wrote whiie answering question to his defense counsei which a ain I consider to be communications uring the deposition, I wouid ask you to teii me at you wrote in that note. MR. GOLDBERGER: we be abie to have iunch at 1:00. MR. GARCIA: Okay. DIRECT BY MR. GARCIA: I was up to Rhianin, 1et me move on to sherry. Did you ever 501icit or have someone soiicit on your behaif a young woman by the name of Sherry, spe ied with an S, to provide prostitution services for you at your home on way in Paim seach? . MR. BURMAN: Object to the form. MR. GOLDBERGER: Object to the form and for ciarification purposes do you have a iast name? MR. GARCIA: NO. A I intend to respond to a1} reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this iawsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. I'm going to assume, and you teii me if I?m wrong, your answers wouid be the same for Nicoie, Haiiey and Joanna if I asked you the same question? MR. BURMAN: I wouid object to the form, if you specified each person, because you?re not giving us iast names, ob'ect to form and I thin you can probabiy stipu ate his answer wouid the same. MR. GOLDBERGER: That's correct. IS that okay with you? MR. GARCIA: Yes. DIRECT BY MR. GARCIA: Do you know someone named Haiiey Robson? Page 31 DEPO. EPSTEZN A As I've said in response to some of your other questions, Mr. Garcia, I intend to respond to reievant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Do you know someone by the name of ?w I'ii read the same names again, not with the uestion aboot_whether or not you soiicited them or prostitution at I want to know if you now these peogie and if you're 901ng to assert the same P1Eht may we can have the same stipuiation. no you now any young women by the name of Britt, Aiexis, Rhianin, Sherry, Nico e, Haiiey or Joanna? MR. BURMAN: My objection is the same. If you are referring to a different person other than Haiiey Robson, I reaiiy can?t object on form because you did give a 1ast name. Is the Haiiey you're referring to in this uestion a different individua] or the same in ividuai? MR. GARCIA: I assume the same individuai, it's the same articie which I produced to your firm which is avaiiabie on a pubiic site. MR. BURMAN: To the extent you have asked this question with regard to ~w and not speci ied a 3ast name, I wouid object to form and we wouid Mr. Epstein wouid answer the question in the same fashion invoking his constitutiona] priviie es and if we can have that stipuiation it wi 1 save us some time. MR. GARCIA: That's fine. Agreed? MR. GOLDBERGER: Yes, that's fine. BY MR. GARCIA: Do you have any agreement with the U.S. Attorney's office to preserve your computer records? A Yes . A31 right. Have you abided by that agreement? MR. GOLDBERGER: I'm going to invoke attorney ciient priviiege on that question. can you tei me who has controi or who has the actuai equipment? MR. GOLDBERGER: Attorney ciient. who is Aiexander Lian, LwlwAwN? A I don?t know. who is Paim Beach Marine? MR. BURMAN: Is that a person? MR. GARCIA: No, it's a company. You know who they are? No. I beiieve it?s the iawsuit is that the name of the company? I don?t reaiiy know. Is that case pending? I don?t reaiiy know. who is Dougias Shottie, Page 32 DEPO. EPSTEIN A As I?ve said in response to some of our other questions, I intend to respond to re evant questions regarding this 1awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk 1osing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. *Do you have any ciose personai friends? MR. BURMAN: Object to the form and aiso assert his priviiege as far as privacy, instruct him not to answer. MR. GARCIA: Certify the question. Have you discussed any of your ed sexuai encounters with Dainya Nida with any ose persona] friends? MR. GOLDBERGER: Object to the form, the same priviiege as Mr. Burman invoked as far as pr}V?cy and then I'd ask you to invoke the F1 . A As I've said in response to some of our other questions, I intend to respond to re evant questions regarding this iawsuit, however, at the present time my attorneys have counseied me I cannot provide answers to any questions reievant to this 1awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. A11 right. Just to refresh our recoiiection, he is, according to a pu iished articie, not invoived in these cases, he aiiegediy is the person who represented you when you signed a contract for having a dock put into your home. MR. GOLDBERGER: who are you taiking about? MR. GARCIA: Dou ias Shottie. Does that refres your recoiiection as to who he might be? A I intend to res end to reievant questions regarding this awsuit, however, at the present time my attorneys have counseied me I cannot rovide answers to any questions reievant to this awsuit. I must accept this advise or risk iosing my 6th amendment right to effective representation. Accordingiy, I assert my federai constitutionai rights as guaranteed by the 5th, 6th and 14th amendment of the United States Constitution. Okay. That's a1] I have. A Great. Thank you. MR. GOLDBERGER: Thanks for coming over. (whereupon the deposition is conciuded at 12:20 Page 33 DEPO.EPSTEXN THE STATE OF FLORIDA COUNTY OF PALM BEACH x, the undersigned authority, certify that the aforementioned Witness personaiiy appeared before me and was duiy sworn. WITNESS my hand and officiai seai this 12th day of May, 2009. JULIE ANDOLPHO, COURT REPORTER Notary Pubiic State of Fiorida My Commission Expires:12/14/09 My Commission 00499509 I I A THE STATE OF FLORIDA, COUNTY OF PALM BEACH I, Juiie Andoipho, Professiona1 Reporter, do hereby certify that I was authorized to and did report said deposition in stenotype; and the forgoing pages numbered 1 to inciusive, are a true and correct transcription of my shorthand notes of said deposition. I further certify that I am not an attorney or counsei of any of the parties, nor am I a reiative or empioyee of any attorney or counsei of party connected wit the action, nor am I financiaiiy interested in the action. The foregoing certification of this transcript does not appiy to any reproduction of the same by any means uniess under the direct controi and/or direction of the certifying re orter. IN WITNESS WHEREOF, I have ereunto set my hand this 12th day of May, 2009. JULEE ANDOLPHO, COURT REPORTER Notary Pubiic in and for the STATE OF FLORIDA My Commission Expires:12/l4/09, 00499509 - Page 34 DEPO. EPSTEIN Page 35 DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISPU TED FACTS Epstein v. Edwards, 3: a1. Case No. 50 2009 CA 040800MMBAG ATTACHMENT 12 VS. JEFFREY EPSTEIN and SARAH KELLEN, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff, No. Defandants. West Palm Beach, Florida April 30th, 2009 10:08 o'clock A.M. VIDEOTAPED BEPOSITION OF JEFFREY EPSTEIN Palm Beach Reporting Service, Inc. (561)471-2995 APPEARANCES: For The Plaintiff: ROTHSTEIN, ROSENFELDT, ADLER 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida, 33301~4252 By BRADLEY JAMES EDWARD, ESQUIRE and WILLIRM J. BERGER, ESQUIRE and RUSSELL ADLER, ESQUIRE For The Defendant: BURMAN, CRITTON, LUTTIER COLEMAN 515 North Flagler Drive, Suite 400 West Palm Beach, Florida 33401w4349 By JOHN MICHAEL BURMAN, ESQUIRE Also for the Defendant: ATTERBURY, GOLDBERGER WEISS, P.A. 250 Australian Ava. South, Suite 1400 West Palm Beach, Florida 33401 By JACK A. GOLDBERGER, ESQUIRE Also Present: Jeff Abbott, Vidoographor, Visual Evidence Palm Beach Reporting Service, Inc. (561)47l~2995 Direct Examination by Mr. Edwards 4 I I I Plaintiff's Exhibit NUmber marked for I.D. 24 (Exhibit held by Attorney Edwards.) Deposition of JEFFREY EPSTEIN, a of lawful age, taken by the Plaintiff, for the purpose of discovery and for use ae evidence in the above entitled cause, wherein: E.W. is the Plaintiff, and JEFFREY EPSTEIN and SARAH KELLEN are the Defendants, in the Circuit Court in and for Palm Beach County, Florida, pursuant to notice heretofore fiied, before LINDA P. AUKAMP, a Registered Professional Reporter and Notary Public in and for the State of Florida at Large, at 250 Australian Avenue South, Suite 1400, West Palm Beach, Palm Beach County, Florida, on the 30th day of April, 2009, commencing at 10:08 o'clock A.M. Palm Beach Reporting Service, Inc. (561)471~2995 muTHEREUPON, THE VIDEOGRAPHER: This ie the 30th day of April, 2009. The time is 10:08 a.m. Thie is videotaped deposition of Jeffrey Epstein in the matter of L.M. versus Epstein. This deposition is being held at 250 Australian Avenue South, West Palm Beach, Florida. My name is Jeff Abbott, I am the videographer representing Vieual Evidence, Incorporated. Would the attorneys please announce their appearances for the record. MR. EDWARDS: Brad Edwards on behalf of the plaintiff. -And this deposition was set in the case of E.W., not L.M. THE VIDEOGRAPHER: Oh. MR. EDWARDS: That is a separate client of mine, but that?s not the caee. THE VIDEOGRAPKER: Okay, that's what I had. Sorry. MR. BERGER: And I'm William J. Berger, for the plaintiff, aleo. MR. GOLDBERGER: Jack Goldberger on behalf of Jeffrey Epstein. MR. BURMAN: Michael Burman on behalf of Jeffrey Epstein. Palm Beach Reporting Service, Inc. (561)471w2995 THEREUPON, 2 JEFFREY EPSTEIN: 3 Being a in the notice heretofore 4 filed, being of lawful age, and being first duly sworn in the above cause, testified on his oath as 6 follows: 7 THE WITNESS: Yes, I do. 8 DIRECT EXAMINATION 9 Q. (By Mr. Edwards) Can you tell us your 10 full name for the record? 11 A. Jeffrey Edward Epstein. 12 Q. And what?e your date of birth? 13 A. January 20th, 1953. 14 Q. And your social security number? 15 A. 090?44~3348. 16 Q. And your current address in West Palm 1? Beach? 18 I A. I intend to respond to all relevant 19 questions regarding this lawsuit. However, at the 20 present time my attorneys have counseled me that I 21 cannot provide answers to any queetions relevant to 22 this lawsuit, and I must accept the advice or riek 23 losing my Sixth Amendment right to effective w? wee 24 representation. 25 Accordingly, I assert my Fifth, Federal Palm Beach Reporting Service, Inc. (561)47l~2995 3Constitutional righte as guaranteed by the Fifth, Sixth, and Fourteenth Amendments to the United States Conetitution. Q. So you're unwilling to give us your address of your house in Palm Beach County? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answere to any queetione relevant to this lawsuit or risk losing my Sixth Amendment right to effective representation. MR. EDWARDS: Mr. Goldberger, can we enter into an agreement so that we all know that he?s reading off of that piece of paper, we know what the whole spiel is, but maybe he can just fifth or game anewer or something like that, so we can continue to move on, rather than read that paper the entire time? We'll be here for days. MR. GOLDBERGER: I think out of an abundance of caution it?s probably appropriate that whatever we feel is the proper response is, so that our invocation of our Fifth Amendment privileges is properly protected, SO I think we?re going to have to give the full Palm Beach Reporting Service, Inc. (561)471~2995 "length mm MR. BURMAN: Obviously we can't tell what you?re going to play to a jury without the entire spiel, what questions you might play to a jury if you decide to do that when this case is tried, so we're going to go with the entire spiel to every question you ask. If v? that?s Mr. Goldberger?e representation, or recommendation. MR. EDWARDS: Okay. MR. aomne?nean: We will go question by question, and we may or may not invoke Fifth Amendment privileges and there may be times where I'm going to have to think about it, discuss it with Mr. Burman whether we're going to invoke on any particular question, but on those questions that we do invoke Fifth Amendment privileges, I think we have no choice but, as you say, do the entire spiel. Q. (By Mr. Edwards) Can you tell me the addresses of other homes that you own outside of West Palm Beach? A. I intend to respond to all relevant However, in the questions regarding this lawsuit. present my attorneys have counseled me that I cannot Palm Beach Reporting Service, Ina. (561)471~2995 dprovide anewers to any questions relevant to this lawsuit, and I must accept the advice or riek losing my Sixth Amendment right to effective Q. Have you any wv MR. GOLDBERGER: And, excuse me, and your Fifth Amendment privileges. THE WITNESS: Yes. Accordingly, I, excuse me, I assert my Federal Conetitutional rights as guaranteed by the Fifth, Sixth and Fourteen Amendments of the United Statee'Conetitotion. Q. (By Hr. Edwards) Have you seen any or in your life? MR. GOLDBERGER: Go ahead. THE WITNESS: I intend to respond to all relevant queations regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answere to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I aasert my constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment of that constitution. Palm Beach Reporting Service, Inc. (561)471~2995 (By Mr. Edwards) Tell me the names of all the businesses in which you are affiliated in any way? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneye have counseled me that I cannot provide answers to any questions relevant to thie lawauit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. I also assert my Federal Constitutional Rights ae guaranteed by the Fifth, Sixth, and Fourteenth Amendmente to the united States Constitution. Q. My understanding is you're currently serving a 12~month jail sentence, ie that correct? MR. GOLDBERGER: You can answer, but ?m THE WITNESS: No. Q. (By Mr. Edwards) You were currently, you were initially sentenced to 18 months in jail, is that correct? MR. GOLDBERGER: GO ahead. THE WITNESS: Yes. Q. (By MI. Edwards) And at the present moment are you still under the supervision of that Palm Beach Reporting Service, Inc. (561)471?2995 jail sentence? A. Yes. Q. Do you know what your releaee date will be? A. No. Q. You have not been told the date of your release? A. Not yet. Q. Where do you plan to reside when you?re released from jail? A. I intend to reepond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have advised me that I must accept the advice, advised me not to answer those questions. I must accept their advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Conetitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the constitution. Q. Mr. Epstein, I have a videotaped copy of the plea colloquy where you pled guilty and told that judge you would be residing in West Palm Beach, Florida. Are you saying now that the statement you made to that judge is no longer true? Palm Beach Reporting Service, Inc. (561)471?2995 Sorry, could you repeat the question? Q. Sure. I have a videotaped copy of the plea oolloqu a? A. No, the question before that.l That?e okay. Q. The question is, where do you intend to reside once you are released from jail? A. I intend to respond to all relevant questions regarding this laweuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the United States Constitution. Q. As you know, that question was asked to you when you pled guilty last June in 2008, and you responded to the judge that you planned to reside in West Palm Beach, Florida. Is that no longer your intent? A. I intend to respond to all relevant Palm Beach Reporting Service, Inc. (561)471?2995 questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this laweuit, and I muet accept this advice or riek losing my Sixth Amendment right to effective representation. Accordingly, I aseert my Federal Conetitutional right ae guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the constitution. Q. This deposition is not being taken in the county jail, but rather in your attorney, Jack Goldberger?s office, 50 can you please inform the jury a8 to your current Schedule as it ie exiets today? MR. GOLDBERGER: Let me hold off on that. Okay. THE WITNESS: I don?t understand the schedule, the question. MR. GOLDBERGER: Yeah, if you can just, if you can rephrase the question, I think we can anewer it for you. Q. (By Hr. Edwards) Okay. Currently you described that you?re under the supervision of the jail sentence at this point in time, you're within the 18 months of your jail sentence. .But thie isn?t Palm Beach Reporting Service, Inc. (561)47lw2995 wejail setting, so obviouely you're outside of the jail eetting. I em asking you just to tell the jury your current schedule; you wake up, are you released from jail at some time, do you have to report back to jail on a daily basis? A. Yes, I report back to jail at 8:00 p.m. Q. Every single day? A. Yes. Q. And ie it eeven daye a week that you're out on work release? A. No, Sir. Q. How many days a week are you out on work release? A. Six. Q. And of thoee six daye, how many hours per day are you out on work release? A. Twelve. Q. And what are the hours that you?re out on work release versus the?hours that you are confined to the jail? A. Repeat the question, pleaee. Q. What are the hours that you are out on work release outside the jail versue the hours that you are inside the jail, meaning if you report back Palm Beach Reporting Service, Inc. (561)471?2995 . . . .. the jail at 8:00 and stay there until 8:00 in the morning, tell me that. A. I juat did. Q. And is that the schedule? A. I just did. Yes, that?s the schedule. Q. Okay. So from 8:00 p.m. until 8:00 a.m. you're in the jail? A. Yes. Q. And then from 8:00 a.m. to 8:00 p.m. you're out on work release? A. Is that a question? Yea. A. Yea. Q. And where do you, where do you work? MR . GOLDEERGER Object ion. THE I intend to respond to all relevant queetione to this lawsuit. However, at the present time my attorneye have couneeled me that I cannot provide anewers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Therefore, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the Palm Beach Reporting Service, Inc. (561)471v2995 i? - .925constitution. Q. (By Hr. Edwards) Are you saying that providing me an answer as to where you currently work, would somehow incriminate you? MR. GOLDBERGER: Let's not be argumentative. He responded to the question on advice of counsel, and if you think that was an improper invocation, then you have a remedy, but don't argue with the witness, which is what we did. Okay. 9. (By Mr. Edwards) Do you have any plans to leave the country once you?re released from jail? A. I intend to reepond to all relevant questione regarding thie lawsuit. However, at the time my attorneys have counseled me that I cannot provide answers to any questione relevant to this lawsuit, and must aoceyt the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the constitution. Q. Do you currently own any jets or airplanes? A. I intend to respond to all relevant Palm Beach Reporting Service, Inc. (561)47l~2995 questions regarding thie laweuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any queetione relevant to this lawsuit, and muet accept the advice or riek losing my Sixth Amendment right to effective representation. Accordingly, I my constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the constitution. MR. BURMAN: Is A.W. a state or federal case? MR. EDWARDS: State. MR. BURMAN: Okay. I am going to, in addition to my client?s assertion of his rights, also object on the grounds that punitive damages haen't been allowed in this case yet. That's clearly a question and, therefore, we object on those grounds, as well. MR. EDWARDS: Thank you. Q. (By Mr. Edwards) Who are the pilote that are employed by you or work for you or fly your airplanes? A. I intend to respond to all relevant queetions regarding this lawsuit. However, at the Palm Beach Reporting Service, Inc. (561)47l~2995 present time my attorneys have counseled me that I cannot provide anewere to any questions relevant to this lawsuit, and muet accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. What person or persons make your travel arrangements when you travel? A. I intend to reepond to all relevant questions regarding this lawsuit. However, at the time my attorneys have advised me that I cannot provide snewers to any questions relevant to this laweuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I would have to assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the constitution. Q. Once you are released from jail, are you under an obligation to report to probation? A. Yes. Palm Beach Reporting Service, Inc. (561)471~2995 f?you intend to do so? A. Yes. Q. And once you are released, do you, according to your sentence, are you scheduled to serve one year community control or house arrest? MR. GOLDBERGER: That's a compound queetion. Please rephrase it. THE WITNESS: Yes. Q. (By Mr. Edwarde) When you're released from jail, do you intend to serve one year community control as a part of your sentence? A. Yes. Q. And under that provision, will you be able to continue working or will you be etrictly confined to your house? MR. GOLDBERGER: That calls for a legal interpretation on the part of my client that he's just not, he's just not competent to answer. So, if you know, fine, but I can?t imagine you would know. THE WITNESS: I don't know. Q. (By Mr. Edwards) Who are the people that will be living or working in your house once you are released from jail? A. I intend to respond to all relevant Palm Beach Reporting Service, Inc. (561)471~2995 ?questions regarding this lawsuit. However, at the present time my attorneye have advised me that I cannot provide answers to any questions currently. Therefore, I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly,.I assert my Federal Conetitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. Are you currently working with the Florida Science Foundation? MR. GOLDBERGER: umm, okay. THE WITRESS: Yes. Q. (By Mt. Edwards) And that is a, a business that operates just next door to your attorney, Jack Goldberger?s office, is that correct? A. No. Q. The Florida Science Foundation does not have an office on this floor right next door to your attorney, Jack Goldberger'e office? A. Is that a question? Q. Yes. A. You have to rephrase the question, please? Q. Does the Florida Science Foundation have an office right next door to your attorney, Jack Palm Beach Reporting Service, Inc. (561)471w2995 Goldberger's office? A. No. Q. What is your role with the Florida Science Foundation? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have advised me that I cannot answer-questions relevant to this lawsuit end must accept their advice, or risk losing my Sixth Amendment right to effective representation. Therefore, I must assert my Federal Constitutional right under the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. What does the Florida Science Foundation do? A. I intend to respond to all relevant questions to this, regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional righte guaranteed by the Fifth, Sixth, and Fourteenth Amendment to that Palm Beach Reporting Service, Inc. (561)471?2995 constitution. Q. Have you procured minors for the purposes of prostitution? A. I intend to respond to all relevant questions to this, regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept their advice or risk loeing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment of the United States Constitution. Q. Isn't it true that you did plead guilty to two felonies related to prostitution with minors? MR. GOLDBERGER: Wait a minute, let me just hold off a second. (Thereupon, a discussion wag had off the record.) MR. GOLDBERGER: You can answer the question. THE WITNESS: Could you repeat the question? Q. (By Mt. Edwards) Ien?t it true that you Palm Beach Reporting Service, Inc. (561)471w2995 21pled guilty to two felony counte related to procurement of a minor for prostitution end/or solicitation of a minor for prostitution? A. No. Q. What counts did you plead guilty to? A. Procuring a minor for prostitution and soliciting prostitution. Q. Have you had sex with minor girls? A. I intend to respond to all relevant queetione regarding this lawsuit. However, at the time my attorneys have advised me that I cannot provide answers to any questions relevant to this lawsuit at the present time, and I must accept that advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right under the Fifth, Sixth, and the Fourteenth Amendment to the Constitution. Q. Have you engaged in sex acts with girls who at the time you engaged in those sex acts were minors? A. I intend to respond to all relevant questions to this laweuit. At the present time my attorneys have counseled me that I cannot respond, I'm sorry, provide.answere to any questions relevant Palm Beach Reporting Service, Inc. (561)471~2995 fathis lawsuit, and I must accept that advice or risk losing their representation. Accordingly, I my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment. Q. Did you intentionally touch my client, A. I don't understand the question, sorry. Q. For the purpose of this lawsuit, we have used the pseudonym to describe my client. Do you know who I'm talking about when I refer to A. I intend to reepond to all relevant questiona to those, this lawsuit. However, at the present time my attorneys have advised me that I cannot accept, answer any questions relevant to this lawsuit, and must accept their advice, or risk losing my Sixth Amendment right to effective representation. Q. Did you w~ e. Accordingly excuse me ?w I aseert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Conetitution. KR. BURMAN: We further object on the ground that name has not been disclosed Palm Beach Reporting Service, Inc. (56l)471~2995 . . . . ewe and you've objected to that. MR. EDWARDS: Thanks. Q. (By Hr. Edwards) Did you touch my client, E.W., against her will? A. We don't know who E.W. is. You haven't told me who E.W. is. Q. Okay. MR. EDWARDS: Do you have an exhibit sticker? (Thereupon, Plaintiff's Exhibit Number 1 was marked for Identification by Attorney Edwards.) Q. (By Mr. Edwards) I?m going to Show you an exhibit that I have marked for identification purpoees as Plaintiff?s Exhibit 1. Do you recognize the girl on the left in the photograph? A. I intend to respond to all relevant questions regardin THE WITNESS: Excuse me one second. (Thereupon, a was had off the record.) THE WITNESS: I intend to respond to all relevant questione regarding this lawsuit. However, at the present time my attorneye have Palm Beach Reporting Service, Inc. ?akoouneeled me that I cannot provide anawers to any queations relevant to this lawsuit. I must accept their advice or risk loeing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as given by the Fifth, Sixth as provided by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwarda) Do you know somebody by the name of Courtney Wild? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right ae guaranteed by the Fifth, Sixth and Fourteenth Amendment to the constitution. Q. For the purposee of this deposition, when I refer to E.W., I'm speaking of Courtney Wild. Back to my initial question. Did you touch my client, against her will? A. I intend to respond to all relevant Palm Beach Reporting Service, Inc. (561)471?2995 questions regarding thie lawsuit. However, at the present time my attorneys have advised me that I cannot provide anewere to any questions relevant to this lawsuit, and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Fifth, Sixth, and Fourteenth Fifth, Sixth and Fourteenth Amendment of the constitution. Q. Did you engage in.sex or sex acts with my client, E.W., against her will? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have advised me that I cannot provide any questions relevant to this leweuit, and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I my Federal Conetitutionel right ee.guarenteed by the Fifth, Sixth, and Fourteenth Amendment to that constitution. Q. Ien?t it true that when you touched E.W. against her will, you knew her to be a minor at the time? Palm Beach Reporting Service, Inc. (561)471m2995 . . ssintend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Did you engage in sex or sex acts with a female named Hailey Robson, (phonetic)? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this iawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right under the Fifth, Sixth, and Fourteenth Amendment of the constitution. Q. Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Brittney, Palm Beach Reporting Service, Inc. (561)471~2995 (phonetic)? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questione relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Between 2001 and 2005 did you engage in sex or sex acts with a minor named Sage {phonetic}? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Palm Beach Reporting Service, Inc. (56l)471~2995 Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Carolyn Casey (phonetic)? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united Statee Constitution, MR. BURMAN: Mr. Edwards, can I inquire of you one thing? Do you have a RICO count in case? MR. EDWARDS: Yes. MR. BURMAN: Okay. These other girls, are any of them your clients, as well? KR. EDWARDS: Some may be. MR. BURMAN: Okay. Thank you. MR. EDWARDS: Some are not. MR. BURMAN: Okay. Q. (By Mr. Edwards) Between 2001 and 2005 Palm Beach Reporting Service, Inc. (561)471?2995 did you engage in sex or sex acts with a minor female named Carolyn Adriamo (phonetic)? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneya have couneeled me that I cannot provide anewers to any questione relevant to this lawsuit, and must accept this advice or risk loeing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Amy (phonetic)? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Palm Beach Reporting Service, Inc. (561)471?2995 Between 2001 and 2005 did you engage in Sex or sex acts with a minor female named Melissa (phonetic)? A. I intend to respond to all relevant questions regarding this lawsuit. However, at this time my attorneye have counseled me that I cannot provide anewers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Conetitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the United States Conetitution. Q. Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Dara (phonetic)? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneye have couneeled me that I cannot provide anewers to any questions relevant to this lawsuit, and muet accept this advice or risk loeing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (551)471w2995 Constitutional rights as guaranteed by the Fifth. Sixth. and Fourteenth Amendment to the United States Constitution. Q. Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Janine (phonetic)? A. I intend to respond to all relevant questions regarding thie lawsuit. Rowever, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I aseert my Federal Conetitutional right under the Fifth, Sixth, and FOurteenth Amendment to the constitution. Q. Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Amanda (phonetic)? A. I intend to respond to all relevant questions regarding this leweuit. However. at the time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and muet accept this advice or risk losing my Sixth Amendment right to effective Palm Beach Reporting Service. Inc. (561)471?2995 yawAccordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. THE WITNESS: Can we take a break for, a bathroom break, ie that okay? THE VIDEOGRAPHER: We?re off the record at 10:39. (Thereupon, a diecussion was had off the record.) THE VIDEOGRAPHER: We're back on the record at 10:44. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Holly (phonetic)? A. I intend to respond to all relevant queetione regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide anewers to queetions relevant to thie lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Palm Beach Reporting Service, Inc. (561)471~2995 . Sixth and the Fourteenth Amendment to the United States Constitution. THE WITNESS: Can I see you a second, Mike? MR. BURMAN: Sure, THE VIDEOGRAPHER: We?re off the record at 10:45. (Thereupon, a brief break was taken.) THE VIDEOGRAPHER: Back on the record at 10:46. Q. (By Mr. Edwards) Between the year 2001 and 2005 did you engage in sex or sex acts with a minor female named Eva (phonetic)? MR. BURMAN: Object to form, form vague and indefinite. Last name, please. MR. EDWARDS: You can answer the question. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneye have counseled me that I cannot provide answers to any questions relevant to this laweuit, and must accept thie advice or riek loeing my Sixth Amendment right to effective Accordingly, I assert my Federal Constitutional right as guaranteed by the Palm Beach Reporting Service, Inc. (561)471-2995 $96.Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between the year 2001 and 2005 did you engage in sex or sex acts with a minor female named Riannen (phonetic)? MR. Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can anewer. THE WITNESS: I intend to respond to all relevant questions regarding thie lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept thia advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the united States Conetitution. Q. (By Hr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Nicole (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: may answer. Palm Beach Reporting Service, Inc. (561)471~2995 frintend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have couneeled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the united States constitution. Q. (By Hr. Edwards) Between 2001 and 2005 did you engage in sex or sex acte with a minor female named Tatum (phonetic)? MR. BURMAN: Object to the form, vague and indefinite. Last name, please. MR. EBWARDS: You can answer if w? THE WITNESS: I intend to respond to all relevant queetions regarding thie lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or riek losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471~2995 Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Conetitution. Q. (By Mr. Edwarde) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Shawna (phonetio)? MR. Object to form, vague and indefinite. Last name, please. MR. EDWARDS: Yen can anewer, if you know. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneye have counseled me that I cannot provide answers to any queetione relevant to this lawsuit. I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mt. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Vivian (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, pleaee. Palm Beach Reporting Service, Inc. (561)471?2995 ?3.2.7465 ?23MR. EDWARDS: You can answer. THE WITNESS: I intend to reepond to all relevant queetione regarding this lawsuit. However at the time my attorneys have counseled me that I cannot provide answers to any queetione relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Conetitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Danielle (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and muet accept this advice or risk loeing my Sixth Amendment right to effective representation. Palm Beach Reporting Service, Inc. (561)471n2995 Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United Statee Conetitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in Sex or sex aote with a minor female that you referred to as Courtney Ice Cream, (phonetic)? MR. HERMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can anewer. MR. BURMAN: Or flavor. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have oouneeled me that I cannot provide answere to any questions relevant to this lawsuit, and muet accept this advice or riek losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwarda) Between 2001 and 2005 did you engage in Sex or sex acts with a minor Palm Beach Reporting Service, Inc. (561)471~2995 fax 3efemale named Tamika (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, pleaee. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Q. (By Mt. Edwards) Between w~ THE WITNESS: Sorry? MR. EDWARDS: I didn?t realize you weren?t finished. THE WITNESS: Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. (By Mt. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a 12?year~old girl named Virginia (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Laet name, please. MR. EDWERDS: You can answer. Palm Beach Reporting Service, Inc. (561)471~2995 . THE WITNESS: I intend to respond to all relevant questions regarding thie lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Alisha (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. HR. EDWARDS: Yen can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept their advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)47lm2995 .Constitutional right as guaranteed by the Fifth, Sixth and the Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Cara (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept their advice or riek losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By nr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Mary (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. Palm Beach Reporting Service, Inc. (561)47l~2995 MR. You can answer. THE WITNESS: I intend to tespond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have couneeled me that I cannot provide anewers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Conetitutional right a3 guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Conetitution. Q. (By MI. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Shelby (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Lest name, please. MR. EDWARDS: You may answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective Palm Beach Reporting Service, Inc. (561)471~2995 Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the United States Constitution. Q. (By MI. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Ashley (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questidns regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. MR. GOLDBERGER: One moment. (Thereupon, a discussion was had off the record.) {Thereupon, Attorney Adler entered Palm Beach Reporting Service, Inc. (561)471?2995 the deposition room.) MR. EDWARDS: We're back on. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or eex acte with a minor female named Sherry (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, MR. EDWARDS: You can anewer. THE WITNESS: I intend to respond to all relevant queetione regarding this lawsuit. However, at the present time my attorneye have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept thie advice or risk losing my Sixth Amendment right to effective representation. _Acoordingly, I aesert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwarde) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Colleen (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Leet name, please. MR. EDWARDS: You may answer. Palm Beach Reporting Service, Inc. (561)471?2995 THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, i assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and the Fourteenth Amendment to the united States Conetitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Julie (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You may answer. THE WETNESS: I intend to respond to all relevant questiona regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471?2995 . Ids? [?Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united Statee Constitution. Q. (By Mt. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Vanessa (phonetic)? MR. HERMAN: Object to the form, vague and indefinite. Laet name, please. MR. EDWARDS: You can answer. THE intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneye have counseled me that I cannot provide anewere to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mt. Edwards) Between 2001 and 2005 did you engage in sex or sex.acts with a minor female named April (phonetic)? ME. BURMAN: Object to form, vague and indefinite. Last name, please. Palm Beach Reporting Service, Inc. (561)471?2995 MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any queetions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mt. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Alexandra (phonetic)? I MR. BURMAN: Object to form, vague and indefinite. And last name, please? MR. GOLDBERGER: Is that Alexander or Alexandra? MR. EDWARDS: dra. THE WITNESS: i intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answere to any questions relevant to this lawsuit, and Palm Beach Reporting Service, Inc. (561)471~2995 ?gaitmust accept this advice or risk loeing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth. and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Michelle (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can enewer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the time my attorneye have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept thie advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional righte ae guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mt. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor- Palm Beach Reporting Service, Inc. (561)471-2995 female named Yolanda (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or riek losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United Stetee Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did.you engage in eex or sex acts with a minor female named Angelique (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, pleaee. MR. EDWARDS: You can answer. TEE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneye have couneeled me that I cannot provide answers to Palm Beach Reporting Service, Inc. (561)471?2995 {PI?"any questions relevant to thie lawsuit, and must accept this advice or riek losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Conetitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwarde) Between 2001 and 2005 did you engage in Sex or eex acts with a minor female named Faith (phonetic)? MR. BURMAN: Object to form, vague and indefinite. .Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide anewere to any queetions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Conetitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwarde) Between 2001 and 2005 Palm Beach Reporting Service, Inc. (561)471~2995 did you engage in sex or sex acts with a minor female named Molly (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. You can answer. was WITNESS: intend to respond to all relevant questions regarding this lawsuit. However, at the time my attorneys have oouneeled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the United States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you engage in sex or sex acts with a minor female named Felicia (phonetic)? MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have Palm Beach Reporting Service, Inc. (561)471~2995 . counseled me that I cannot provide answers to any questions relevant to thie lawsuit, and I must accept thie advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Conetitution. Q. (By Mr. Edwarde) Between 2001 and 2005 did you engage in eex or.sex acts with a minor female named Leigh, MR. BURMAN: Object to form, vague and indefinite. Last name, please. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant queetione regarding this laweuit. However, at the time my attorneye have counseled me that I cannot provide answere to any queetione relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective Accordingly, I my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Palm Beach Reporting Service, Inc. (551)471-2995 (By Hr. Edwards) Isn't it true that at the time you engaged in sex or sex acts with each of the people we have just discuaeed, you knew they were minors? MR. BHRMAN: Object to form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Constitutional right under the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwarde) With each of these girls, isn't it true that you used someone else to recruit them to your house? MR. BURMAN: Object to form, vague and indefinite. THE WITNESS: I intend to respond to all relevant questions regarding thie lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to Palm Beach Reporting Service, Inc. (561)47l~2995 _?n?%gnestione relevant to this lawsuit, and must aocept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the - United Statee Constitution. Q. (By Mr. Edwarde) For the purposes of these next questions, when I refer to "the minor girls" I?m referring to Hailey Robson, Brittney, Sage, Carolyn Casey, Carolyn Adriamo, Amy, Melissa, Dara, Janine, Amanda, Holly, Eva, Riannen, Nicole, Tatum, Shawna, Tamika, Vivian, Danielle, Jennifer, Virginia, Alisha, Alexandra, Sarah, Courtney Ice Cream, Lauren, Melissa, Dana, April, Cara, Mary, Shelby, Ashley, Sherry, Colleen, Julie, Vanessa, Michelle, Yolanda, Angelique, Faith, Molly, Felicia, Leigh or Leigh, and Courtney, my client, which is the plaintiff in this lawsuit. My question is ?m MR. GOLDBERGER: You've identified that Courtney as Courtney Wild, correct? MR. EDWARDS: Correct. Q. (By Mr. Edwards) With each of these girls, isn?t it true that you paid somebody else to Palm Beach Reporting Service, Inc. (561)471?2995 bring them to your house? MR. BURMAN: object to the form, vague and indefinite. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the time my attorneys have counseled me that I cannot provide answers to any questions relevant to this laweuit, and must accept this advice or risk loeing my Sixth Amendment right to effective representation. Accordingly, I my Fedexal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mt. Edwards) For each of these minor girls, isn't it true that you paid each of them for sex or sex ecte? MR. BURMAN: Object to form, vague and indefinite. Further explaining that to the extent that no laet names have been identified for most of the girls. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have Palm Beach Reporting Service, Inc. (561)47lw2995 counseled me that I cannot provide answers to any questions relevant to this lawsuit, and =muet accept thie advice or risk loeing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united Statea Constitution. Q. (By Mr. Edwards) Isn?t it true that in order to recruit each of these minor girls to your house, you had someone tell them, rich guy in Palm Beach will pay you cash to go to his house and give him a massage"? MR. BURMAN: Object to form, vague and indefinite, to the extent last names of the girle have not been identified. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneya have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I aseert my Federal Constitutional right as guaranteed by the Palm Beach Reporting SerVioe, Inc. (561)471~2995 Fifth, Sixth, and Fourteenth Amendment of the united States Constitution. Q. (By Mr. Edwards) Each of these minor girls, when arriving at your house, was greeted at the door by one of your at your mansion, isn?t that correct? MR. BURMAN: Objeot to form, vague and indefinite. No description of last namee of the alleged minor girls. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the time my attorneys have advised me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united Statee Constitution. Q. (By Mr. Edwarde) Each of these minor girle was eeoorted up to your bedroom by one of your employees, isn?t that correct? MR. BURMHN: Object to the form, vague and ?indefinite. Palm Beach Reporting Service, Inc. (561)471~2995 Fog THE WITNESS: I intend to respond to all relevant questions regarding thie lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this laweuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional righte e3 guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. May I juet ask, step outside for a second, I went to just ask a question. MR. BURMAN: Sure. THE VIDEOGRAPHER: Going off the record at 11:11. (Thereupon, a brief break was taken.) THE VIDEOGRAPHER: Okay, we?re back on the record at 11:16. Q. (By Mr. Edwarde) Previously I named, or I gave you the namee of 49 minor girls. Isn't it true that you engaged in sex or sex acts with each of them? MR. BURMAN: Object to the form, vague and indefinite. Last namee weren?t provided for Palm Beach Reporting Service, Inc. moat of them. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide anewere to any questions relevant to this lawsuit, and muet accept that advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Constitutional fight as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Hr. Edwards) with reepeot to each of the minor girls that was taken into your bedroom by one of your employees, isn't it true that you entered the room wearing only a towel? MR. HERMAN: Object to form, vague and indefinite, last namee of the alleged minor girls weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneye have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and meet accept thie advice or risk losing my Sixth Palm Beach Reporting Service, Inc. (561)471w2995 .J K. .- 10 "-61. Amendment right to effective representation. Accordingly, my federal, I have to assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, end Fourteenth Amendment to the united States Constitution. Q. (By Hr. Edwards) With respect to each of these minor girls, isn?t it true that you ordered each of them to get naked to give you a massage? MR. BURMAN: Object to form, vague and indefinite with regard to the alleged minor girls, the names weren't provided. Laet names weren't provided. MR. EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneye have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept thie advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwarde) With respect to each of Palm Beach Reporting Service, Inc. (561)471w2995 named minor girls, isn't it true that you masturbated in front of each of them? MR. BURMAN: Object to the form, vague and indefinite with regard to the alleged minor girls, their last names weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the time my attorneys have counseled me that I cannot provide answers to any questions relevant to this leweuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I aesert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By me. Edwards) Isn?t it true that you asked each of the minor girls to do Similar things to you, such as rub your nipples? MR. BURMAN: Object to the form, vague and indefinite with regard to the alleged minor girls, the last names weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. Palm Beach Reporting Service, Inc. (561)471?2995 However, at the present time my attorneys have counseled me that I cannot provide answers to any queetione relevant to this lawsuit, and I must accept this advice or risk loeing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the Uhited States Conetitution. Q. (By Hr. Edwards) with reepect to all of the named 49 minor girls, isn?t it true that you tried to touch each of them in a Sexual way? MR. BURMAN: Object to form, vague and indefinite with regard to the alleged minor girls, last names weren?t provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit. I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by.the Fifth, Sixth, and Fourteenth Amendment to the Palm Beach Reporting Service, Inc. (561)471?2995 weunited States Constitution.- Q. (By Mr. Edwards) mWith respect to each of the 49 minor girls, isn't it true that you touched their bare breasts? MR. BURMAN: Object to form, vague and indefinite with regard to the alleged minor girls, last names weren?t provided. THE WITNESS: I intend to reepond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to thie lawsuit. And I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United Statee Constitution. Q. (By Mr. Edwards) With respect to each of these 49 minor girle, isn't it true that you inserted your fingers into their vaginas? MR. Object to form of the question, vague and indefinite with regard to the alleged minor girls, last names weren't provided. Palm Beach Reporting Service, Inc. (561)471n2995 {mm-exi- ,srTHE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) With respect to the 49 named minor girls, isn?t it true that you attempted to use vibrators on each of them? MR. BURMAN: Object to the form of the question, vague and indefinite with regard to the alleged minor girls, last names weren't provided. MR, EDWARDS: You can answer. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Palm Beach Reporting Service, Inc. (561)471~2995 Amendment right to effective representation. Accordingly, I my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Between 2003. and 2005 did you have a woman named Nadia Marcinkova living at your Palm Beach houee with you? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Conetitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Conetitution. Q. Is it true that you considered Nadia Maroinkova your Yugoelavian lesbian sex slave? A. I intend to respond to all relevant questions regarding this laweuit. However, at the present time my attoxneys have counseled me that I cannot provide answers to any questions relevant to Palm Beach Reporting Service, Inc. (561)471?2995 f?this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q.- Can you tell me why it is that you just smiled when I asked you the last question about Nadia Marcinkova? MR. GOLDBERGER: Don't answer that. Q. (By Mr. Edwards) Did you think the question was ?unny? MR. HERMAN: Object to form. MR. GOLDBERGER: You can answer. THE WITRESS: No. Q. (By Mr. Edwards) Do you know Nadia Marcinkova? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Palm Beach Reporting Service, Inc. (561)471w2995 Accordingly, I assert my Federal Constitutional righte as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Isn?t it true that you brought Nadia into the room to have threesome sex with you and many of these minor female girls? MR. BURMAN: Object to the form of the question, vague and indefinite with regard to the word "may" and with regard to the fact that last namee haven't been described, or disoloeed. I THE I intend to respond to all relevant questione regarding this lawsuit. However, at the present time my attorneys have couneeled me that I cannot provide answers to any questions relevant to this laweuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I aseert Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Conetitution. Q. (By Mr. Edwards) Isn?t it true that you ejaculated in front of each of these minor girls? Palm Beach Reporting Service, Inc. (561)471~2995 MR. BURMAR: Object to form, vague and indefinite. Lest names were not provided of the alleged minor girls. THE WITNESS: I intend to respond to all relevant queetions regarding this lawsuit. However, at the time my attorneys have counseled me that I cannot provide answers to any questions relevant to this laweuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mt. Edwards) with reepect to each of these 49 minor girls, isn?t it true that you paid each of them for sex? MR. BURMAN: Object to the form, vague and indefinite. Last names of the many of the minor girls were not provided, alleged minor girle. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my ettorneye have counseled me that I cannot provide answers to Palm Beach Reporting Service, Inc. . .any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Conetitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mt. Edwarde) Isn't it true that you offered each of the 49 minor girls money if she would bring you more minor girls for you to engage in sex or sex acts with? MR. BURMAN: Object to the form, vague and indefinite. beet names of many of the alleged minor girls weren?t provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answere to any questions relevant to this lawsuit, and must accept their advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the Palm Beach Reporting Service, Inc. (561)471~2995 united Statee Constitution. Q. (By Mr. Edwards) With reepeot to each of the 49 named minor girls, isn't it true that the sex or sex acts occurred in your bedroom? MR. BURMAN: Object to form of the question, vague and indefinite with regard to the alleged minor girls, the last names weren?t provided. THE WITNESS: I intend to respond to all relevant questions regarding this laweuit. However, at the time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Conetitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Hr. Edwards) with respect to each of these minor girls, isn?t it true that certain other employees of yours played a role in furthering your sexual contact with these minors? MR. BURMAN: Object to the form of the question, vague and indefinite with regard to Palm Beach Reporting Service, Inc. (561)471w2995 '72 the alleged minors, last names weren?t provided. THE WITNESS: Could you_repeat the question? Sorry. Q. (By Mr. Edwards) Sure. With respect to the 49 minor girls whose names I provided, isn't it true that certain of yours played a role in furthering sexual contact between you and these minore? MR. BURMAN: Same objection, THE WITNESS: I intend to respond to all relevant questions regarding thie leweuit. However, at the time my attorneys have counseled me that I cannot provide answers to any questions releeant to this laweuit, and I. must accept this advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwarde) Some of your employees were delegated the reopensibility of cleaning your sex toys after you engaged in Sex with minor girls, isn?t that true? Palm Beach Reporting Service, Inc. (561)471~2995 MR. BURMAN: Are you referring to the 49 alleged minors that you just identified, or is this a generic question? the 49, that MR. EDWARDS: Yes, THE WITNESS: Can you repeat the question please? MR. w~ are known to us. MR. BURNER: Okay. Object to the form, vague and indefinite with regard to the alleged minore, last namee weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwarde) Isn't it true that you hired employees to work for you for the sole purpose of echeduling minor girls to come to your house for Palm Beach Reporting Service, Inc. (561)471w2995 MR. BURMAN: Once again, are you referring to the 49 you identified, or just generic? MR. EDWARDS: General queetion. MR. BURMAN: General question? MR. EDWARDS: Right. THE WITNESS: I intend to respond to all relevant queetions regarding this lawsuit. However, at the present time my attorneye have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I my Federal Conetitutional righte as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Isn't it true that you hired employees that were delegated responsibilities in order to assist you in avoiding detection of your actions by law enforcement? THE WITNESS: What's the question? MR. BURMAN: Object to the form, vague and indefinite. THE WITNESS: Could you repeat it again? MR. EDWARDS: Sure, I?ll clean it up. Palm Beach Reporting Service, Inc. (561)471?2995 it(By Hr. Edwarde) Isn't it true that you had working for you with a purpose of helping you to avoid detection of your criminal activities by law enforcement? MR. BURMAN: Objeot to form, vague an indefinite. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk loeing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did you have operable surveillance equipment inside your house from 2001 through 2006 in your Palm Beach house? MR. BURHAN: Objection, vague and indefinite. THE WITNESS: I intend to reepond to all relevant questions regarding this lawsuit. However, at this present time my attorney has Palm Beach Reporting Service, Inc. (561)47l~2995 counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal I Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Eewards) Did you destroy or tamper with evidence, including computer images, computer equipment, surveillance equipment, photos, notes, diaries, or photocopy records as a result of the criminal investigation of you between 2001 and 2006? MR. GOLDBERGER: Let me object on the form. Are you asking, are you suggesting that there is a criminal investigation that went on between 2001 and 2006? Is that the question? MR. EDWARDS: Well, at Some time, at some point in time there was, since he pled guilty. MR. GOLDBERGER: But what?e the purpose of the 2001 to 2006? Maybe you can rephraee the question. MR. EDWARDS Okay. Q. (By Mr. Edwards) How about this. Have Palm Beach Reporting Service, Inc. (561)471~2995 kwyou ever at any time destroyed or tampered with any evidence of your involvement with minor girle? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the time my attorneys have counseled me that I cannot anewer questions with reepect to this lawsuit, and must accept their advice or risk loeing my Sixth Amendment right to effective I representation. Accordingly, I assert my Federal Constitutional Rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendmente to the United Stetee Constitution. Q. Have you ever destroyed computer images or computer equipment because of a fear it would be need against you in a prosecution for your sexual involvement with minor girls? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneye have counseled me that I cannot provide answers to any queetions relevant to this lawsuit, and I must accept this advice or risk loeing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471~2995 .5 We'78 Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the Uhited States Constitution. Q. Did you ever, at any time, destroy photographs, notee, or diaries in an effoxt to avoid detection by law enforcement? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide anewers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. - Q. Did other people hired by you destroy or tamper with evidence in an effort to avoid detection of criminal activities or prosecution? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk Palm Beach Reporting Service, Inc. (561)471~2995 losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Was your houee at some point in time in Palm Beach burglarized by a former housekeeper named Juan (phonetic)? A. Yes. Q. In relation to that burglary, did you provide the Palm Beach Police Department with surveillance video from the inside'of your house? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneye have counseled me that I cannot provide anewere to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. At the time your house was burglarized, Palm Beach Reporting Service, Inc. (561)471~2995 how many operable surveillance cameras were inside your houee? A. I intend to reepond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have couneeled me that I cannot provide answers to any questions relevant to this laweuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional righte as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United Statee Constitution. Q. How long have you been on work release? MR. GOLDBERGER: Hang on. Yeah, he can that's fine. THE WITNESS: A little over six months. Q. (By Mr. Edwards) You know the date that you started work release? A. No. Q. If the court records indicate that your guilty plea occurred on June 30th, 2008, is that something you'd quarrel with? I A. No. Q. How long did you, do you believe you were Palm Beach Reporting Service, Inc. (561)471*2995 the county jail after that June 30th, 2008 plea before you were granted work release? MR. GOLDBERGER: If you know. THE WITNESS: Couple of months. Q. (By Mr. Edwards) Do you know if any of your victims were informed of your petition for work releaee? A. I do not know. Q. When was the Florida Science Foundation created? A. I intend to respond to all relevant questions regarding thie lawsuit. However, at the present time my ettorneye have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights ae guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. Isn?t it true that you created the Florida Science Foundation months before pleaing guilty knowing that you would eventually be on work release in an office right next to your attorney?s office? Palm Beach Reporting Service, Inc. (561)471w2995 June MR. BURMAN: Object to the form. THE WITNESS: I intend to re3pond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Since being sentenced in of 2008, have you had contact with any minors? MR. GOLDBERGER: You can answer that. THE WITNESS: I intend to respond to all relevant questions regarding thin lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and mnet accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the Palm Beach Reporting Service, Inc. (561)471~2995 Leeconstitution. Q. (By Mr. Edwards) Do you currently have access to a computer that you uee? A. I intend to respond to all relevant questione regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this laweuit. I must accept this advice ox-riek losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional righte as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. What is e?mail that you have been using since being eentenced in 2008? MR. GOLDBERGER: Object to the form, assumes facts not in evidence. THE WITRESS: I intend to respond to all relevant queetione regarding this laweuit. However, at the time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective Acdordingly, I assert my Federal Palm Beach Reporting Service, Inc. (551)471*2995 "Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Do you intend to communiCate with any minors once you are released to house arrest? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provided answers to any questions relevant to, this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Is it true that you have been diagnosed by a with a sexual disorder related to your sexual appetite for minor girls? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk Palm Beach Reporting Service, (561)471m2995 losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights ae guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. Isn?t it true that you intend to continue engaging in sex acts with minor girls once you are released? MR. BBRMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this laweuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Have you engaged in sex or sex acts with minor girls outside of the United States? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the Palm Beach Reporting Service, Inc. present time my attorneys have counseled me that I cannot provide-answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. Is it true that you have your own island? MR. BURMAN: Object, also on the, on the grounds that the punitive damages haven't been allowed yet. Not relevant. MR. EDWARDS: Answer. THE I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights under the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Palm Beach Reporting Service, Inc. (561)471~2995 (By Mr. Edwards) Have you engaged in sex or sex acts with minors on the island of Little St. Jeff's? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneye have counseled me that I cannot provide anewere to any questions relative to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional righte as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the Uaited States Constitution. Q. Ian't it true that you have engaged in sexual acts or sex with girls as young as 12 years old? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal ?alm Beach Reporting Service, Inc. (561)471~2995 Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. What is the youngest girl that you have engaged in eex or sex acts with in the last ten years? A. I intend to respond to all relevant queetiona regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my sixth Amendment right to effective representation. Accordingly, I assert under the Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the united States Constitution. Q. Have you diaoussed with any of your friends the fact that you engage in sex or sex acts with minors? A. i intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk Palm Beach Reporting Service, Inc. (561)47l~2995 losing my Sixth Amendment right to effective Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United Statee Constitution. Q. Did you know that the girls that were providing you massages were under the age of 18 at the time they were doing A. I intend to respond to all relevant queetions regarding this lawsuit. However, at the time my attorneya have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk loeing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Isn't it true that the age group that you enjoy to engage in sex with ie between 12 and 16 years old? MR. BURMAN: Object to form. .THE WITNESS: I intend to respond to all Palm Beach Reporting Service, Inc. (561)47l~2995 laws relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Do you agree with the Q. (By Mr. Edwards) that prohibit you from having sex or engaging in sex acts with minors? lawe acts MR. BURMAN: Object to form. THE WITNESS: Can you repeat the question? Q. (By MI. Edwards) Do you agree with the that prohibit you from engaging in sex or sex with minor girls? MR. BURMAN: Object to the form. THE WITKESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Palm Beach Reporting Service, Inc. (561)471~2995 Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united Statee Constitution. Q. (By Mr. Edwards) Isn't it true that you devised a scheme or plan to engage in sex or sex acts with multiple minor gires? A. I intend to respond to all relevant questions regarding this lawsuit. ?owever, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to thie lawsuit, and I must accept this advice or risk loeing my Sixth Amendment right to effective Accordingly, I must assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. THE WITNESS: Can I take a pee break? THE VIDEOGRAPHER: We?re off the record at 11:50. This will be the end of tape one. (Thereupon, a brief break was taken.) THE VIDEOGRAPHER: This is the beginning of tape number two, and we?re back on the Palm Beach Reporting Service, Inc. (561)47lez995 1" A .3 5? 2:31record at 11:59. Q. (By Mr. Edwards) Between 2001 and 2005 did you digitally penetrate the vaginas of more than 50 minor girla? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any queetions relevant to thie lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the constitution. Q. Between 2001 and 2005 did you masturbate in front of more than 50 minor girls? A. I intend to respond to all relevant Iquestions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questione relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Palm Beach Reporting Service, Inc. (561)471~2995 wasSixth and Fourteenth Amendment to the constitution. Q. Between 2001 and 2005 did you ejaculate in front of more than 50 minor girls? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and ?ourteenth Amendment to the United States Constitution. Q. Does the body form of a 12 to 16 year old girl sexually appeal to you? Mk. BURMAN: Object to the form. THE I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answere to any queetione relevant to this lawsuit, and I must accept this advice or riek losing my Sixth Amendment right to effective representation. Accordingly, I aseert my Federal Palm Beach Reporting Service, Inc. (561)471~2995 Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Did you use your wealth, power, and connections to impress or influence minor girls into having sex with you? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept their advice or risk losing my Sixth Amendment right to effective Accordingly, I aesert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Did you intentionally target economically deprived children for the purposes of having sex or engaging in sex acts with? A. Do you went to rephrase the question? Q. Did you intentionally target economically deprived children for the purposes of sex? A. I intend to respond to all relevant questions regarding this lawsuit. HoweVer, at the Palm.Beach Reporting Service, Inc. present time my attorneys have counseled me that I cannot provide answera to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. During the criminal investigation there were statements to the media that you believed the girls to be 18. Which girls were you re?erring to? A. I intend to THE WITNESS: Excuse me one second. (Thereupon, a discussion was had off the record.) MR. GOLDBERGER: Umm, let me object to the form as to vague. I don't know what statements you're talking about. Are you talking about statements that Mr. Epstein made? MR. EDWARDS: Through attorneys. MR. GOLDBERGER: Well, is that the question? Why don't you rephrase the question, why don't you rephrase the question so we understand what it is. Palm Beach Reporting Service, Inc. (561)471~2995 (By Mr. Rewarde) Various attorneys of yours made to the media that you were of, under the belief that the girle that you were engaging in sex acta with were 18 years of age. Which girls were you, was that referring to? HR. GOLDBERGER: Can you identify a specific statement made by a specific attorney? MR. EDWARDS: We'll get there later on in theldepoeition. Q. (By Mr. Edwards) Have you ever, at any time, made that statement, that you believed the girls that you were engaging in sex aote with were 18 years of age or older? MR. GOLDBERGER: To the media, are you talking about? Q. (By Mr. Edwards) Yourself or through anyone else to anyone else. MR. GOLDBERGER: Object to the w" that's ~w MR. Object to the form. MR. GOLDBERGER: I have no idea what the question is. Just ask the queetion, I?ll be happy to try and have the client anewer it for you. Q. (By Mr. Edwards) Okay. I'm not talking Palm Beach Reporting Service, Inc. (561)471~2995 about statements to your attorneys, that?e privileged. Have you ever made the atatement to anyone else, other than your attorneys, that you believed the girls that were giving you massages at your house were over the age of 18? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United Statee ConstitutionQ Q. Between 2001 and 2005 did you pay any females for sex? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective Palm Beach Reporting Service, Inc. (561)471?2995 flu?E?:- .representation. Accordingly, I assert Federal Constitutional rights under the Fifth, Sixth, and Fourteenth Amendment to the united States Conetitution. Q. Between 2001 and 2005 did you tell minor female girle at your house that you prefer to engage in sexual activities with minors? A. I intend to reepond to all relevant questione regarding this lawsuit. However, at the present time my attorneye have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United Statee Constitution. Q. Is it true that many of the 49 minor girls previously named told you that they were under the age of 15 at the time you were engaging in sex aote with them? MR. BURMAN: Object to form of the question, vague and indefinite to the extent Palm Beach Reporting Service, Inc. (561)47l~2995 ?fth-Hthat the alleged minor girls? last names weren?t provided. THE WXTNESS: I intend to reepond to all relevant questione regarding this lawsuit. However, to the present time, at the present time my attorneys have counseled me that i cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. E?warde) How did the minor girls previously named in this deposition arrive to your mansion between 2001 and 2005? MR. BURMAN: Objection, vague and indefinite. MR. GOLDBERGER: And it's, it?s vague and indefinite, but to aseist in answering the queetion, can you tell us what mansion you?re talking about? MR. EDWARDS: Palm Beach mansion. THE WITNESS: Can you repeat the question? Palm Beach Reporting Service, Inc. (561)471?2995 .(By Mr. Edwards) How did they arrive at your house? A. ?They? arrive? Q. How did any of the minor girls whose names I named previously in this deposition arrive to your house? MR. Object to the form of the question, vague and indefinite to the extent that the alleged minor girls? laet names weren't provided. THE WITNESS: I intend to resPond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, that I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Hr. Edwards) Many of the minor girls named previously in this deposition did not drive a car to your house or have a driver's license, isn't that true? Palm Beach Reporting Service, Inc. (561)471-2995 101 ER. BURMAN: Object to form of the queetion, vague and indefinite to the extent that the alleged minor girls' last names weren't provided. THE WITNESS: You have to repeat the question, again. Sorry. Q. (By Mr. Edwarde) Isn't it true that many of the minor girle previously named in thie deposition did not drive a car or have driver's licenses? MR. BURMAN: Same objection. THE WITNESS: I intend to respond to all relevant questions regarding thie lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) is it true that you disouesed with many of these girls the fact that they were in middle school or high school at the Palm Beach Reporting Service, Inc. (561)471w2995 Es 10 11 12 1.3 1.102 time they were engaging in sex acts with you at your house? MR. BURMAN: Are you referring to the previous 49? MR. EDWARDS: Yes. MR. Okay. Object to form of the question, vague and indefinite to the extent that the names, the last names of many of the alleged minor girls weren't provided. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Hr. Edwards) Did any of the girls that engaged in sex acts with you at your house between 2001 and 2005 tell you that they were in middle school or high school? A. Sorry, repeat the question. Palm Beach Reporting Service, Inc. (561)471u2995 103 MR. BURMAN: Are you talking about the 49? MR. EDWARDS: No. MR. BURMAN: No. Q. (By Mr. Edwarde) Did any minor girls that engaged in eex or eex acte with you between the years of 2001 and 2005 at your house tell you that they were in middle echool or high school at the time? MR. BURMKN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this laweuit. However, at the present time my attorneys have counseled me that I cannot provide anewere to any questiong relevant to this lawsuit, and I must accept thie advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. MR. EDWARDS: Okay. What time do you want to break for lunch? MR. GOLDBERGER: 1:00. THE WITNESS: 1:15? MR. GOLDBERGER: Yeah, 1:15. Is that Palm Beach Reporting Service, Inc. (561)471u2995 104 okay? MR. EDWARDS: Yeah, that's fine with me. What time do we have now? THE WITRESS: It will be another hour. (Thereupon, a discuseion was had off the record.) Q. (By Mr. Edwards) Did you ever discuss with any minor girle at your house that you would pay them to bring you other minor girls for the purposes of sex? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this laweuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth. Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did you tell any of the minor girls that were at your house for sex that you preferred pure, young girls for sex? Palm Beach Reporting Service, Inc. (561)471?2995 105 MR. BURNER: Object to the form. TEE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Did you tell any of the minor girls at your house between 2001 and 2005 that you do not like girls that have tattoos? MR. BBRMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Palm Beach Reporting Service, Inc. (561)471*2995 Ewan106 Fifth, Sixth, and Fourteenth Amendment of the constitution. Q. (By Mr. Edwards) Did you tell any of the minor girls that were at your house not to bring you any girls that were pregnant or had babies? MR. BURMAN: Object to the form. THE WITRESS: I intend to reSpond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot pxovide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the constitution? Q. (By Mr. Edwards) Did you specifically instruct any of the minor girls not to bring you any black girls? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to Palm Beach Reporting Service, Inc. (561)471w2995 to107 any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Constitutional rights a3 guaranteed by the Fifth, Sixth and Fourteenth Amendment o? the constitution. Q. (By Mr. Edwards) Isn?t it true that you did not like to have sex or engage in sex acts with black girls? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any queetions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment. Q. (By Mr. Edwards) Isn?t it true that black girls were brought to your house and you turned them away at the door because you do not like black girle? Palm Beach Reporting Service, Inc. MR. BURMAN: Object to the form. THE WITNESS: II intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any queetions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the constitution. Q. (By Mr. Edwards) Isn?t it true that you also turned away girls because they were 18 years or older and too old for you? MR. BURMAN: Object to the form. I intend to respond to all relevant queetione regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. I assert Federal Accordingly, Constitutional rights as guaranteed by the Palm Beach Reporting Service, Inc. (561)471~2995 109 Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Isn?t it true that you also turned away minor girls with tattoos because you did not feel that they were pure? MR. BURMAK: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By ax. Edwards) Is it true that your specific instructions were, to these minor girls, to bring you white girls between the ages of 12 and 17 that were not pregnant, did not have babies, and did not have tattoos? HR. HERMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. Palm Beach Reporting Service, Inc. (561)471?2995 I 10 ll 12 13 14110 However, at the present time my attotneye have counseled me that I cannot provide answers to any questions relevant to thie lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the conetitution. Q. (By ax. Edwards) Is it true that you offered each minor girl approximately $200 in cash for sex? MR. BURMAN: Are you Object to the form. back on the 49, or is thie generic? MR. EDWARDS: No, generic. THE arrange: Would you repeat the question? Q. (By Mr. Edwards) Between 2001 and 2005 ieu't it true that you offered each minor girl that came to your house for sex $200 for that sex? MR. BURHAN: Object to the form. THE WITNESS: I intend to reapond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have oouneeled me that I cannot provide answers to Palm Beach Reporting Service, inc. (561)471w2995 111 any questions relevant to this lawsuit, and I must accept this advice or riek losing my Sixth Amendment right to effective repreaentation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwards) Why did you laugh about that last question? MR. BURMAN: Object to the form. THE WITNESS: I have a atomachache at the moment. I wasn't laughing. Q. (By Mr. Edwards) Ien?t it true that you targeted young, economically deprived kids with little or no parental guidance? MR. BURMAN: Object to the form. THE WITNESS: You have to repeat the question. Q. (By Mr. Edwards) Isn?t it true that you were targeting young, economically deprived minor girls with little or no parental guidance? MR. BURMAN: Object to the form. Q. (By Mr. Edwarda) For Sex. A. 1 intend to xespond to all relevant questions regarding this laweuit. However, at the Palm Beach Reporting Service, Inc. 112 time my attorneya have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. Have you ever told anybody that the girls were over at your houee because you just like massages? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or riek losing my Sixth Amendment right to effective representation.? Accordingly, I my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Conetitution. Q. (By Mt. Edwards) Isn't it true that none Palm Beach Reporting Service, Inc. (561)471w2995 these minor girls that you engaged in sex acts with at your house had any massage experience? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 did you ever have a professional masseuse give you a massage at your house in Palm Beach? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept thie advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471*2995 114 Constitutional rights ae guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the United States Constitution. Q. in fact, when these minor girls would tell you they had no massage experience, didn?t you respond by telling them that that is actually better for you? MR. BURMAN: Object to the form. THE WITNESS: I intend to reepond to all relevant questions regarding thie lawsuit. However, at the present time my attorneys have couneeled me that I cannot provide enewere to any questions relevant to this lawsuit, and I must accept the advice or risk loeing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right ae guaranteed by the Fifth, Sixth and Fourteenth Amendment to the constitution. Q. (By Mr. E&werds) Did you tell these minor girle to get naked and touch you so that you could get off? MR. BURMAN: Object to the form. THE WITNESS: What? Whet?e w~ repeat the question. Palm Beach Reporting Service, Inc. (561)471v2995 (By Mr. Edwards) Did you tell these minor girls between 2001 and 2005 at your Palm Beach mansion to get naked and touch you so that you could get off? A. Get off? MR. GOLDBERGER: Are you asking him if that's a statement that was made? EDWARDS: Yes, to these girls. MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr; Edwards) Will you agree that you exchanged money for sexual gratification with at least 50 girls at your Palm.Beach mansion between 2001 and 2005? MR. BURKAN: Object to the form. Palm Beach Reporting Service, Inc. (561)471~2995 116 THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me not to provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwards) Between 2001 and 2005 you never ordered professional escort to come to your house for sex, did you? A. Rephrase the question, please. Q. Between 2001 and 2005 you never ordered from an escort service in Palm Beach County for a professional escort to come to your house for sex, did you? A. You never ordered? THE WITNESS: Do I answer the question? HR. GOLDBERGER: You don't understand. Rephrase it. Q. (By Mr. Edwards) Did you ever call an escort service-to have an escort sent to your house Palm Beach Reporting Service, Inc. (561)471?2995 Palm Beach for sex? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. You did not call a professional escort because that would likely result in a girl over the age of 18 coming to your house for sex, right? at. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept_this advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Constitutional rights as guaranteed by the Palm Beach Reporting Service, Inc. 118 Fifth, Sixth, and Fourteenth Amendment of the constitution. Q. (By Mr. Edwards) Do you enjoy coercing minors into eex acts with you? MR. BURMAN: Object to the form. THE WITNESS: I intend to reepond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I meet accept this advice or risk loaing my Sixth Amendment right to effective representation. Accordingly, I asaert my Federal Conatitutional right aa guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United Statea Constitution. Q. (By Mr. Edwards) Do you know Sarah Kellen? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot pro?ide anawers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Palm Beach Reporting Service, Inc. (561)471~2995 119 Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth. Sixth, and Fourteenth Amendment to the constitution. Q. Did you instruct her to assist you in gaining access to minor girls for sex? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Did you instruct any other employees of yours to assist you in gaining access to minors for sex? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective Palm Beach Reporting Service, Inc. (561)471w2995 . 3H1120 representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. What people were living with you in your Palm Beach mansion between 2001 and 2005? I MR. GOLDBERGER: Object to the form. THE WITKESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide enswere to any questions relevant to this laweuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I aseert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did you meet with people employed by you to discuss a plan to gain access to minor girls for the purposes of sex? A. I intend to respond to all_relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I Palm Beach Reporting Service, Inc. (561)471~2995 3121 cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. Which employees did you discuss your plan to gain access to minor girls for the purposes of sex? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth; and Fourteenth Amendment to the United States Constitution. Q. Is it true that you have many people working in your house in Palm Beach County, or did, between the years 2001 and 2005? Palm Beach Reporting Service, Inc. (561)471?2995 intend to respond to all relevant questions regarding this laweuit. However, at the present time my attorneys have counseled me that I cannot provide answexs to any questions relevant to this lawsuit, and I must accept this advice or riek loeing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right aa guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. How many employees work in the various houses that you own right now? A. That?s that question is owned right now? I don't understand the question. Q. Well, it's my underetanding that you own numerous properties. I just want to know how many people are actually paid by you or employed by you that work and/or live in those homes? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the time my attorneys have couneeled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective Palm Beach Reporting Service, Inc. (561)47l~2995 123 representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment of the united States Constitution. Q. Did you ever peroonally procure a, or sorry, strike that. Did you ever personally go out and recruit a minor girl to bring back to your house for sex? THE WITNESS: Object to form, no? MR, BURMAN: Object to form. THE WITNESS: I intend to respond to all relevant questions regardin MR. EDWARDS: I?m sorry, is there something you don?t understand about the question? If you don't, I'll rephrase it. MR. GOLDBERGER: We objected to the form, now you can answer. MR. EDWARDS: I thought he objected to the form, that's why I was MR. GOLDBERGER: He aeked 1*m not ~u Brad, he asked hie lawyer a queetion, that's all. We objected to the form, that's fine. 1m. EDWARDS: Okay. MR. GOLDBERGER: Go ahead and answer. Palm Beach Reporting Service, Inc. (561)471~2995 egg-1.124 THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution. Q. (By Mr. Edwards) Who is the first minor that you brought to your house for sex? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Palm Beach Reporting Service, Inc. (561)47l~2995 ?fmk 125 plan Q. (By Mr. Edwards) Have you had sex with 100 minor girls in the last ten years? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwards) When did you devise your to gain access to minor girls for sex? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing ?y Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471~2995 126 Constitutional righta ae guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwarde) With whom did you meet to discuss your plan to gain accees to minor girls for sex? MR. BGRMAN: Object to the form. THE WITNESS: I intend to respond to all. relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide anawere to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwards) Do you agree that you have a criminal enterprise that is comprieed of, at the very least, yourself, Sarah Kellen, and Nadia Marcinkova who have the common goal of bringing minors to you for the purposes of sex? MR. BUREAN: Object to the form. THE WITNESS: I intend to respond to all Palm Beach Reporting Service, Inc. (561)471~2995 127 relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwards) Was the target age range for your criminal enterprise always minors between the ages of 12 and 16? MR. BURMAR: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendments to the united States Constitution. Palm Beach Reporting Service, Inc. (561)471?2995 (By Mr. Edwards) What are the namee of all of the members of your criminal enterprise that has the common goal of procuring miners for the purposes of sex? MR. BURMAE: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment to effective Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwarde) In addition to paying each of these minor girle approximately $200 for sex, did you also provide traneportation for them to and from your house? MR. BURMAN: Are we generic, or are we going with the 49? MR. Generic. MR. BURMAN: Generic? Okay. Object to the form. Palm Beach Reporting Service, Inc. (561)471u2995 . 3129 THE WITNESS: You have to repeat the question, I'm sorry. Q. (By Mr. Edwards) In addition to paying minor girls approximately $200 to engage in sex or sex acts with them, did you also provide transportation for minor girls to and from your house? BURMAN: Same objection. THE WITNESS: I intend to reSpond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide any answers relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did you, one of your employees, or someone within your enterprise have an account with Yellow Cab for the purposes of transporting minors to and from your house? MR. BURMAR: Object to form. MR. GOLDBERGER: Do you understand the Palm Beach Reporting Service, Inc. (561)471w2995 130 question when he saye "enterprise"? Do you have any idea what he means? THE WITNESS: No. MR. GOLDBERGER: Can you define enterprise, so we can determine whether we need to answer the question. MR. EDWARDS: .I?m talking about pereons involved with a common goal. We have defined this earlier. MR. GOLDBERGER: I?m sorry, I was out of the room did you define it? MR. EDWARDS: You were out of the room. MR. GOLDBERGER: Okay. MR. EDWARDS: And persons, we defined it as, at the very leaet, Mr. Epstein, Sarah Kellen and Nadia Marcinkova having the common goal of bringing minors to and from the Palm Beach house for the purposes of sex. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have oouaseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Palm Beach Reporting Service, Inc. (561)471~2995 131 Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Sorry, can we take a break again? Bathroom break. MR. Let's just break for lunch then. MR. GOLDBERGER: I can?t, because I've got wm there's a reason why, I've got a commitment at 1:15, so w~ THE VIDEOGRAPHER: Off the record at 12:40. (Thereupon, a_discussion was had off the record.) (Thereupon, a brief break was taken.) THE VIDEOGRAPHER: Back on the record at 12:54. Q. (By Mt. Edwarde) Between 2001 and 2005 did you or any of your employees or assistants have an account with Yellow Cab? A. I intend to respond to all releVant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide anewers to any questions relevant to Palm Beach Reporting Service, Inc. (561)471~2995 ?132 this lawsuit, and I muet accept their advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. Are you currently actually a billionaire? MR. BURMAN: Objection. That goes to punitive damages, and I object. THE WXTNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. 2412.. am: And I should add for the record that I would instruct him not to answer that question, even if he wasn't invoking the Fifth. Palm Beach Reporting Service, Inc. (561)471-2995 133 were what Q. (By Mr. Edwards) Between 2001 and 2005 you a billionaire? MR. BURMAN: Objection, instruct you not to answer that question based on the fact that that?s directed toward punitive damages, and that has not been allowed to file, be filed, or proceeded with in the state court action. You ehould read that, as well. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have oouneeled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the united States Constitution. Between 2001 and 2005 Q. (By Mr. Edwards) types of cars did you have that you owned, parked in your driveway at your Palm Beach mansion? MR. Object, once again on the" grounds that punitive damages have not been. Palm Beach Reporting Service, Inc. (561)471w2995 134 approved yet in this case. I instruct him not to answer that question. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwards) Is your house in Palm Beach located on the water? THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights under the Fifth, Sixth, and Fourteenth Amendment to the constitution. Falm Beach Reporting Service, Inc. (561)471?2995 (By Mr. Edwards) What: is the square footage of your house in Palm Beach? MR. BURMAN: Object, on the grounds that that question, in part, delves into his financial situation, which has not been approved to be explored in this case yet, becauee punitive damages have not been approved or allowed to be proceeded with here, and I instruct him not to answer the question. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that i cannot provide answere to any questions relevant to thia lawsuit, and must accept his advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did you tell the minor girls that were at your house that you were extremely wealthy between 2001 and 2005? MR. GOLDBERGER: Object to the form. THE WITNESS: I intend to respond to all Palm.Beach Reporting Service, Inc. (561)471~2995 955136 relevant questions regarding this lawsuit. However, at the time my attorneye have counseled me that I cannot provide answere to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Did you talk to the minor girls that were at your house between 2001 and 2005 about all of the houses and care that you owned? MR. 313mm Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept thie advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the Palm Beach Reporting Service, Inc. .137 United States Constitution. Q. (By Mr. Edwards) Did you use your wealth and the minors lack thereof to influence that minor to have sex with you? MR. Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and meet accept advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) After you ejaculated in front of minor girls, did you tell each one of them that every time she came to your house for sex, you would pay her $200 caeh? MR. Object to the form. THE WITNESS: I intend to reepond to all relevant questions regarding this lawsuit. However, at the present time my attorneye have counseled me that I cannot provide answers to Palm Beach Reporting Service, Inc. (561)471~2995 138 any questiona relevant to thie lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwarde) Was it your plan to groom each minor girl to be your personal sex slave? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questiona regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questione relevant to this lawsuit, and I must accept this right or risk losing my Sixth Amendment right to effective representation? Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwards) Did you upon each minor girl that what she was doing with you sexually wee morally right? MR. BURMAN: Object to the form. Palm Beach Reporting Service, Inc. (561)471v2995 139 THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution. Q. (By Mr. Edwards) Was it part of your plan to display your wealth and power in an effort to gain sexual access to minor girls? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Feurteenth Amendment to the Palm Beach Reporting Service, Inc. (561)471w2995 {Hm-5? ?Kan-140 united States Constitution. Q. (By Mr. Edwards) Did you intentionally target very poor minor girls because you knew that demographic would be the most impressed by your wealth and likely listen to you? MR. BURMAN: Object to the form. TEE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and must accept this advice or risk loeing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional right as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) None of the minor girls that you engaged in sex or sex acts with had ever engaged in prostitution prior to meeting you, isn?t that correct? HR. BURMAN: Object to the form, THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have Palm Beach Reporting Service, Inc. (561)471w2995 E31593 141 counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Isn?t it true that you corrupted and injured minor girls for your own sexual gratification? MR. Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mr. Edwards) Isn't it true that you typically engaged in sex or sex acts with minor Palm Beach Reporting Service, Inc. (561)471~2995 24.- 25 142 girls three or four times each day at your Palm Beach mansion? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwards) Isn't it true that you in, that you coerced minor girls into prostitution? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. How?ver, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Palm Beach Reporting Service, Inc. (561)471?2995 143 Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment in the United States Constitution. Q. (By Mr. Edwards) Isn't it true that you and your employees, including Sarah Kellen, called these minor girls to encourage them to bring more minor girls to you for sex. By called I mean on the telephone? MR. Object to the form. THE WITNESS: Can you repeat the question? Q. (By My. Edwards) Isn?t it true that you and your assistants or employees, including Sarah Kellen, called minor girls on the teiephone to encourage them or command that they bring you other minor girls for sex? MR. BURMAN: Object to the form. THE WITRESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Palm Beach Reporting Service, Inc. (561)471~2995 [rt-144 Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwards) What are all the telephone numbers assigned to you or your Palm Beach mansion between 2001 and 2005? A. Again? Q. What were all of the telephone numbers assigned to you or your Falm Beech mansion 2001 and 2005? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Who scheduled your massage appointments between 2001 and 2005? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I Palm Beach Reporting Service, Inc. (561)471~2995 3me3145 cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. THE WITNESS: Excuse me? Accordingly I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By Mt. Edwards) Is it true that you were ejaculating in front of three or four minor girls per day between 2002 and 2005 at your Palm Beach mansion? MR. Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept the advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Palm Beach Reporting Service, Inc. (561)471?2995 (By Mr. Edwards) Have you ever treated with any doctors or physicians and discussed sexual issues with them? THE WITNESS: I intend to respond to all relevant questione regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answere to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. (By MI. Edwards) Did you and your assistants or employees use the word work, WwowR~K, to describe you engaging in sex acts with minors at Your house? A. I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have oounaeled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment right to effective representation. Palm Beach Reporting Service, Inc. (561)47l~2995 Elma-HR147 Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the United States Constitution. Q. Did you rely on Sarah Kellen and your other assistants to properly schedule these minor girls in a way so that they would not come in contact with one another? MR. BURMAN: Object to form. THE WITNESS: I intend to respond to all relevant questions regarding thie lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept their advice or risk losing my Sixth Amendment Right to effective representation. So, accordingly, I assert my Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendments to the United States Constitution. MR. EDWARDS: Ready to break? MR. He wants to eat. We're off the record at THE VIDEOGRAPHER: 1:12. Palm Beach Reporting Service, Inc. (561)471?2995 148 (Thereupon, a lunch break was taken from 1:12 to 2:32 p.m THE VIDEOGRAPHER: We're back on record at MR. EDWARDS: Ready? HR. GOLDBERGER: Sure. Q. (By Hr. Edwards) Mr. Epstein, did you ever care about any of the feelings of the minor girls that you were engaging in sex with? MR. BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit at this time, so I must accept their advice or I lose potential I risk losing my Sixth Amendment right to effective representation. And accordingly, I have to assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the Uaited States Constitution. Q. (By Mr. Edwards) Did it ever occur to you that any of these girls were somebody's daughter MR. BURMAN: Object to the form. Palm Beach Reporting Service, Inc. (561)47l~2995 airy-"(By Mr. Edwards) when you were engaging in sex with them? MR. BURMAN: Object to the form of the question. THE VIDEOGRAPHER: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to these questions, as I have to accept their advice or risk losing my Sixth Amendment right to effective representation, Brad. THE WITNESS: Is it okey_if I call you Brad? HR. EDWARDS: You can continue. THE WITNESS: And, accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth and Fourteenth Amendment to the united States Constitution. Q. (By Mr. Edwards) When you were digitally penetrating minor girls, did you care about the fact that you were emotionally or hurting them? MR. BURMAN: Object to the form of the question. THE WITNESS: I intend to respond to all Palm Beach Reporting Service, Inc. (561)471-2995 ISO relevant questions regarding this lawsuit. However, at the present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit, and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendments to the Uhited States Constitution. Q. (By Mr. Edwards) We have heard over and over again that you intend to respond to this. When do you intend to respond to these questions? BURMAN: Object to the form. THE WITNESS: I intend to respond to all relevant questions regarding this lawsuit. However, at the present time on advice of counsel I cannot provide answers to those questions at this time. I must accept advice of my counsel or risk losing my Sixth Amendment right to effective representation. Accordingly, I?ll have to assert my Federal Constitutional rights as guaranteed by the Fifth, Sixth, and Fourteenth Amendment to the united States Constitution. Palm Beach Reporting Service, Inc. (561)471?2995 (By Mr. Edwards) Ien't it true that at the time that you were sexually battering these minor girls, you didn't care what happened to them and only cared about your only personal eexuel gratification? MR. BURMAN: We need Object to the form. to talk outside. THE WITNESS: Me, too? THE VIDEOGRAPHER: We're off the record at (Thereupon, a brief break was taken.) THE VIDEOGRAPHER: We?re back on the. record at 2:36. MR. BURMAN: For the purposes of the record, I will tell you that this line of questioning, in my View, is way beyond the bounds of permissible questions, and nothing but pure argument, and if you continue in this vein, I will stop the deposition and we will seek instruction from Judge Hafele about what's permissible and what's not. I Q. (By Hr. Edwards) Isn?t it true that at the time you were inserting your fingers into the vagina of these little kids, all you cared about was Palm Beach Reporting Service, Inc. (561)471?2995 (3 M5951 152 your own sexual gratification? MR. HERMAN: The deposition is over. THE VIDEOGRAPHER: Conclude at 2:37, and of tape 2 of 2. MR. BERGER: We?re going to order instant copy, and we want the tape, also, Mr. Videographer. MR. BURMAN: We want this as soon as they get theire, we want ours. (Thereupon, the deposition was adjourned at 2:38 Palm Beach Reporting Service, Inc. (561)471-2995 1153 CERTIFICATE OF OATH STATE OF FLORIDA SS COUNTY OF PALM BEACH I, the undersigned authority, cartify that and was duly $worn. WITNESS my hand and offiaial seal this LINDA P. AUKAMP, RPR Commission NO.: DD 499271 NOtary Public State of Florida My Commission Expire$: 12?26?09 Palm Beach Reporting Service, Inc. (561)471-2995 g2154 DEPOSITION CERTIFICATE STATE OF FLORIDA SS COUNTY OF BEACH I, LINDA P. AUKAMP, a Registered Professional Reporter, certify that I was authorized to and-did stenographically report the deposition of that a review of the transcript was requested; and that the transcript ie a true and complete record of my etenographic notes. I FURTHER CERTIFY that on the 2009, I notified 5 that the deposition was ready for reading and signing by the witness. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the partiee? attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 2009. Palm Beach Reporting Service, Inc. (561)471?2995 155 LIRDA P. RPR Palm Beach Reporting Service, Inc. (561)471w2995 153 CERTIFICATE OF OATH STATE OF FLORIDA SS COUNTY OF PALM BEACH I, the undersigned authority, certify that JEFFREY EPSTEIN personally appeared before me and was duly sworn. WITNESS my hand and official seal this let 2009. MQW LINDA.P. AUKAMP, RPR day of May, Commission NO.: DD 499271 Notary Public State of Florida My Commiesien Expires: 12?26~09 LE Hr rwewaM?Semmem%w Commission Expires 03526. 2 3: Commission 00 499271 Bonded By Nation 0 Assn. "bi - 'wgi-qu ?alm Beach Reporting Service, Inc. (561)471~2995 154 DEPOSITION CERTIFICATE STATE OF FLORIDA SS COUNTY OF PALM BEACH I, LINDA P. AUKAMP, a Registered Professional Reporter, certify that I was authorized to and did stenographioally report the deposition of JEFFREY that a review of the transcript was requested; and that the transcript is a true and complete record of my stenographio notes. I FURTHER CERTIFY that on the let day of May, 2009, I notified JOHN MICHAEL BURMAN, ESQUIRE that the deposition of JEFFREY EPSTEIN was ready for reading and signing by the witness. I further certify that i am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties? attorney or counsel connected with the action, nor am I financially interested in the action. Dated thie let day of May, 2009. LINDA P. AUKAMP, RPR Palm Beach Reporting Service, Inc. rm155 TO: JEFFREY EPSTEIN c/o JOHN MICHAEL BURMAN, ESQUIRE 515 North Flagler Drive, Suite 400 West ?alm Beach, Florida 33401 RE: E.W. VS. JEFFREY EPSTEIN and SARAH KELLEN At the conclusion of your deposition given in the above?styled cause you indicated you wished to read and Sign the tranecript. This letter is to advise you that your deposition ie ready, and we ask that you call our office at (561) 471w2995 at your earliest convenience for an appointment to come in. If you are a party in this action and your attorney has ordered a copy of thie transcript, you may wish to read his copy and forward to ue a photoetatic copy of your signed correction sheet. It ie neceesary that you do this as soon as possible, since the transcript cannot be held beyond two weeks from the date of this letter. If you have any reason which you would like for me to place on your depoeition as to your failure to Sign the Same, please advise. Thank you for your prompt attention. Very truly yours, PALM BEACH REPORTING SERVICE, INC. 1665 Palm Beach Lakes Blvd., Suite 1001 West Palm Beach, Florida 33401 BY: LINDA P. AUKAMP, RPR Date: May let, 2009 Palm Beach Reporting Service, Inc. (561)471~2995 DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, 9: 051. Case No. 50 .2009 CA ATTACHMENT 11 Page 16 Page 18 it IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT 1 - - IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No. AB 3 WITNESS: DIRECT CROSS REDIRECT RECROSS 4 JEFFREY EPSTEIN 5 BY MR. 21 6 a PiaintiffJEFFREY EPSTEEN, 1 0 NUMBER DESCRIPTION PAGE D?m?mm 11 PLABWUFFSEX.1 FDLESEXUAL 24 OFFENDEIUPREDATOR FLYER 1 2 EX. 2 STATEMENT 25 . PLAINTIFFS EX. 3 OF HOME 33 CON {wagg?g?fmw EPSTEIN 1 3 ex. 4 BOTTLE OF JOY JELLY 38 EX. 5 PHOTOGRAPH OF GIRL 129 Th Oct 8 2009 3.4 EX. 6 PHOTOGRAPH OF GIRL 129 0 er EX. 7 PHOTOGRAPH OF GIRL 131 100GIRL 132 . . p. . 1 6 250 South Australian Avenue Suite 1400 9 3 West Palm Beachfiorida 33401 2 0 it Reported By: Joana Ricciuti, RPR, sea, CLR Notary Public, State of Florida 23 Frose Court Reporting Agency, Inc. it? Page 17 . Page 3.9 1 APPEARANCES: . 2 On behalfofthe Plaloiilt: 1 I SPENCER T. KUVIN, esouzse $3?1?3?gv? REUIRE 3 Deposition taken before Jeane Riccmti, Registered mulmr?i 4 Professional Reporter and Notary Public in and for the 5 :Ei'ifg?g?ihg?ggir ?orid" 334?) 5 State of Florida at Large, in the above cause?L.M.anoa.soil)? 8" ?e 7 THE VIDEOGRAPHER: We're on the video record. 8 ADLER 8 This is the 8th day of October, 2009, and the time 9 3:32:35 0'35 Bou'm?d 9 it approximately 10:07 am. Fozt Laucierdaie, Florida 33301 10 This is the continuation of the videotaped 10 Phone: 954.522.3456 . . 3s 11 On behaifofi?lointiffianc Doe in Case No. 30591 and 1 1 deposrtion of Jeffrey Epstein in the matter of BB. 12 EZELL, ESQUIRE 12 versus Epstein. This deposition is being heid at 13 1 3 250 South Australian Avenue, No. I400 in West Paim Miami, Florida 33230 14 Beach, Fiorida. 14 Phone: 305.353.2300 . 15 On behalfoflhe Defendant: 15 My name 1s Dan Doskey. Fm the Vldeograpber g2; JACK asouzas . . . 1 6 STORY ROWLES, PARALEGAL 1 6 representing Visuai vadence, Incorporated. 1? 1 7 Wouid the attorneys present please announce Suite i400 8 their appearances for the record? 18 West Palm Beach, Florida 3340] I Phone: 502.659.8309 19 MR. KUVIN: Spencer Kuvm and Adam Langmo behalf ofthe Plaintiff, as. 20 Eg?gj??gig?v LUTHER COLEMAN, 2 1 MS. HOLMES: Cara Holmes for LM. 21 Suite 400 I 22 MR. PIKE: Michael Pike on behalf of West Palm Beach, Fiorlda 33402 a 22 Phone: 561.842.2820 2 3 Jeffrey Epstein. 2 ?i I 23 message, vmo?wm 2 4 MR. GOLDBERGBR: And Jack Goldberger on behaif 25 VISUAL EVIDENCE, INC. 2 5 of Epstein ammosea-maxest?rmamawmemw? i. 1 (Pages 16 to 19) (561) 832~7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeane Ricciuti {601~280-428-9381) Electronicaity signed by Jeana Ricciuti (601??280428-9381) a4?! Page 20 Page 22 1 Kathy, do you want to identify yourself? 1 A. Correct. 2 Kathy, are you there? 2 Q. Mr. Epstein, on January 30th of 2008, isn't it 3 MS. EZELL: Yes. 3 true that you pied guiity to procuring a person under 4 MR. PIKE: She puts it on mute every once for prostitution? 5 while. 5 A. No. 6 MR. GOLDBERGER: Hey, Kathy, are you there? 6 Q. You did not plead guilty? 7 MS. EZELL: Yes. 7 A. You asked me -- do you want to repeat it? 8 MR. GOLDBERGER: .iust -- we'rejust 8 Q. Did you piead guilty to procuring a person 9 identifying everyone who's on this thing. Can you 9 under the age of 18 for prostitution? 1 0 just identify yourself? 1 A. On what date? 1 1 MS. EZELL: Yes. It?s Kathy Ezell. I?m 1 3. Q. Regardless of the date, did you plead guilty 3. 2 sorry, Kathy Ezeli is here. 1 2 to procuring a person under the age prostitution? i 4 "thereupon, 4 MR. GOLDBERGER: Do you need to take a break? 3.5 (JEFFREY EPSTEIN) 15 MR. KUVIN: I?m sorry, what are we doing? 3. 6 having been first duly sworn or af?rmed, was examined 1 6 MR. GOLDBERGER: l?rn taking a break to talk to l? and testified as follows: 17 my Client 8 THE WITNESS: Yes, ma'am. 8 MR. KUVIN: For what reason? 9 MR. PIKE: Pull that back, please. 1 9 MR. GOLDBERGER: Whether we have to invoice a 2 0 MR. KUVIN: Back? 2 privilege or not. 2 1 MR. PIKE: Yeah, not on the video. I want to 2 1 MR. KUVIN: Okay. 2 2 make sure it's not on the video. 2 2 THE VIDEOGRAPHER: Going off the record at 2 3 MR. KUVIN: We're good? Thank you. 2 3 10:10. 2 4 THE VIDEOGRAPHER: It's not. 2 4 (A brief recess was taken.) 2 5 DIRECT EXAMINATION 2 5 THE VIDEOGRAPHER: We're back on the record at Page 2 1 Page 23 2 BY MR. sum: 3. 10:12. Q. Could you give us your name, sir, please. 2 BY MR. KUVIN: 3 A. Jeffrey Epstein. 3 Q. Okay. Mr. Epstein, did you plead guilty to 4 MR. GOLDBERGER: Kathy, you?ve got to put it 4 procuring a person under the age of 18 for prostitution? 5 on mute. Kath Kathy? 5 A. I pled guilty procuring a minor, I believe, 6 MS. EZELL: Give me one second. 6 for prostitution. 7 MR. GOLDBERGER: Just put it on mute, please. 7 Q. When did you plead guilty to that charge? 8 MR. KUVIN: You can probably turn the volume 8 A. On June the 30:11. 9 down; it won't effect her mic, I would imagine. 9 Q. And did you procure a minor for prostitution 3. 0 MR. GOLDBERGER: Good idea. Okay. 0 in compiiance with that charge? 1 1 BY MR. KUVIN: 1 1 A. I fully intend to respond to all relevant 12 Q. Mr. Epstein, is your date of birth, 1 2 questions regarding this lawsuit; however, at the 13 .ianuary 20, l953? 1 3 present time, my attorneys have counseled me i cannot 14 A. Yes. 1 4 provide answers to any questions relevant to this 1. 5 Q. Race is White? 1 5 lawsuit. i must accept this advice or risk losing my 1 6 A. Yes. 1 6 6th Amendment right to effective representation. 1? Q. You are male? 1 7 Accordingly, I assert my federal constitutional rights 18 A. Yes. 1 8 as guaranteed by the 5th, 6th and l4th Amendment to the 9 Q. Hair is gray? 1 9 us Constitution. 2 A. Yes. 2 0 Q. Okay. rs like to mark as Exhibit 1 the 2 3. Q. Eyes are blue? I 2 1 Florida Department of Law Enforcement Sexual 2 2 A. Yes. 2 2 Offender/Predator Flyer. 2 3 Q. Height is 6-foot tall? 2 3 MR. KUVIN: For the record, let me show that 2 4 A. Correct. 2 to Mr. -- well, let me show that to the camera, .2 Q. Weight is 180 pounds? 2 5 first. 2 (Pages 20 to 23) (561) 832*??500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Joana Ricciuti (80148042843381) Electronicaliy signed by Jea na Ricciuti (801-280-428-9381) a4?l 9 Page 24 Page 2 6 1 Okay. Let me know when you have it. 3. but it's not -- - 2 (Plaintiff?s Exhibit No. 1 was marked for 2 MR. KUVIN: If you choose to 3 identi?cation.) 3 MR. It's not it?s not being 4 THE VIDEOGRAPHER: Okay. 4 admitted into evidence. 5 MR. KUVIN: Okay? 5 MR. Sir, please don't interrupt me. 6 BY MR. KUVIN: 6 Are you 7 Q. All right. Let me show you this sexual 7 MR. GOLDBERGER: l'll interrupt you 8 offender/predator flyer. is that you, sir? 8 MR. KUVIN: Are you representing Mr. Epstein 9 A. It's a photograph of me, yes. 9 in this deposition or is Mr. Pike? Because I want 1 0 Q. Okay. Is that the predator flyer for you? 10 to be clear which one of you is going to be doing 1 1 A. No, it is not. 1 1 the talking during the deposition. 3. 2 Q. Who's it for? 1 2 MR. GOLDBERGER: We both are representing 1 3 A. It?s a sexual offender flyer. 1 3 Mr. Epstein. 14 Q. I?m sorry, I was reading the title where it 1 4 MR. PIKE: Let's go off the record for a 1 5 says ?Predator Flyer.? Do you see that? 1 5 second. 1 6 A. It actually said "Sexual Offender/Predator" 6 MR. KUVIN: No, we're not going off the 1 '7 because it's used for both categories. And if you?ll 7' record. We're staying on the record and only one 1 8 notice, the designation says sexual offender, which is _l 8 attorney may speak at a time. 1 9 extremely different than sexual predator. 1 9 So right now, I?d like you all to choose. I 2 0 Q. What?s your understanding of the difference 2 0 don't mind, either one of you can inject -- 2 1 between the two? 2 1 MR. PIKE: Hold on a second. 2 2 A. l'rn not i know i?rn a sex l?ve been 22 MR. KUVIN: and represent Mr. Epstein. 2 3 registered as a sexual offender. 2 3 MR. GOLDBERGER: Let let let him ?nishsexual offender? 2 4 Let him finish. 2 5 MR. GOLDBERGER: Jeff. 2 5 MR. KUVIN: Let me ?nish, please. Page 25 Page 27 1 THE WITNESS: 1 fully intend to respond to all 1 Either one of you can represent Mr. Epstein, 2 relevant questions regarding this lawsuit; however, 2 but I don't want objections flying from both 3 at the present time, my attorneys have counseled me 3 chairs, both Mr. Epstein?s criminal lawyer and his 4 I cannot provide answers to any questions relevant 4 civil lawyer. . 5 to this lawsuit. 1 must accept this advice or risk 5 So l?d ask you to please choose which one is 6 losing my 6th Amendment right to effective :6 going to object, just like Judge Hafele has 7 representation. Accordingly, I have to assert my '7 required at hearings that only one attorney can 8 federal constitutional rights as guaranteed by the 8 represent Mr. Epstein in an argument at a hearing. 9 5th, 6th and 14th Amendment to the US Constitution. 9 MR. GOLDBERGER: Actually, we have two 1 0 MR. KUVIN: Let's go ahead and I?d like to 1 0 different roles in this matter. I represent 1 1 mark what you?re reading from here today as Exhibit 1 1 Mr. Epstein on all criminal matters, so I'm going 1 2 2 to the deposition. 1 2 to Speak when I think it's relevant to any criminal 1 3 (Plaintiff?s Exhibit No. 2 was marked for 1 3 matters. And Mr. Pike represents Mr. Epstein on 1 4 identification.) 14 any civil matters, and he will speak when it's 1 5 BY MR. KUVIN: 1 5 relevant to any civil matters. 1 6 Q. Who prepared that document for you, sir? i. 6 BY MR. KUVIN: 3.7 MR. GOLDBERGER: Dorft answer that question, 17 Q. Okay. Sir, can i please have the paper back, 18 Jeffrey. lt?s attorney-client privileged and this 1 8 which has already been marked as Exhibit 2? 1 9 is my work product, and we?re not marking it, 1 9 MR. KUVIN: Mr. Goldberger, if you choose that 2 0 MR. KUVIN: I don?t think you have the right 2 0 this document is not to be produced in this case, I 2 3. to tell me what I can and can?t -- 2 1 have no objection to you sealing that document 2 2 MR. You can mark it all you 2 2 until such time as lodge Hafele decides the issue 2 3 want 2 3 as to whether or not I'm allowed to mark something 2 4 MR. KUVIN: It's been marked. 2 4 that the witness is reading in a deposition. Is 2 5 MR. GOLDBERGER: You can mark it all you want, 2 5 that fair to you? 3 (Pages 24 to 27) (561) 832?7500 PROSE COURT REPORTING AGENCY, ENC. (563.) 832*7506 Electronically signed by Joana Ricciuti (601-2804288381) Electronically signed by Jeana Rieciutl {601-280-428-9381) 3 - Sits: 5'53} an: 2 matwmnae Ki Page 30 sexual offender or a sexual predator, which one? "f . J. . .525. .. I: .. hummus. \?e?tf??i?te . . . 5.. Page 28 1 MR. GOLDBERGER: You can mark anything you 1 A. I fuily intend to respond to all relevant 2 want to mark. Go ahead and mark it, and then we?ll 2 questions regarding this lawsuit; however, at the 3 go from there. 3 present time, my attorneys have counseled me I cannot 4 MR. Okay, sounds good. Thank you very 4 provide answers to any questions reievant to this 5 much. 5 lawsuit. must accept this advice or risk losing my 6 BY MR. KUVIN: 6 6th Amendment right to effective representation; 7 Q. Okay, sir. What I've marked as Exhibit 2, did 7 Accordingly, I assert my federai constitutional rights 8 you prepare that document? 8 as guaranteed by the 5th, 6th and 14th Amendment to the 9 MR. GOLDBERGER: Attorney~ciient 9 US Constitution. 1 0 THE WITNESS: Attorney?client privilege. 1 0 Q. Sir, do you like having things inserted in 1 1 BY MR. KUVIN: 1 1 your anus for sexual grati?cation? 12 Q. Sir, you are reading from a document, are you 12 MR. PIKE: Objection, argumentative, 1 3 not, when i ask you certain questions? 1 3 harassing. 1 4 MR. GOLDBERGER: Attorney~ciient 1 it THE WITNESS: 1 fully intend to respond to all 1 5 BY MR. KUVIN: 1 5 relevant questions regarding this lawsuit; however, 1 6 Q. The document that you're reading from is 1 6 at the present time, my attorneys have counseled me 1 7 Exhibit 2 that's in front of you right now. 1 7 I cannot provide answers to any questions relevant 8 MR. GOLDBERGER: Attorney~ciient 1 8 to this lawsuit. I must accept this advice or risk 1 9 BY MR. KUVIN: 1 9 losing my 6th Amendment right to effective 2 Q. Why do you feel a need to read from a document 2 0 representation. 2 1 with respect to the issues of whether or not you have a 2 1 BY MR. KUVIN: 22 5th Amendment right? 22 Q. Do you live at 35 -- 2 3 MR. GOLDBERGBR: Attorney?client. 23 MR. GOLDBERGER: Hold on. 2 4 BY MR. KUVIN: 24 THE WITNESS: Excuse me, let me finish. Is 2 5 Q. Sir, with respect to the last questions i was 2 5 that fair. Page 29 Fage 31 1 asking you about, the difference between a sexual 1 BY MR. KUVIN: 2 offender and a sexual predator, when Mr. Goldberg piped 2 Q. Absolutely. ti certainly want you to finish. 3 up and said your 3 A. Accordingly, I assert my federal 4 MR. GOLDBERGER: Goidberger. Goldberger. 4 constitutional rights as guaranteed by the 5th, 6th and 5 BY MR. KUVIN: 5 14th Amendment to the US Constitution. 6 Q. I'm sorry, Mr. Goldberger said your name in 6 Q. Sir, do you live at 358 El Briilo Way, Paim 7? order to clue you in to object on 5th Amendment 7 Beach, Florida? 8 grounds 8 A. I fuliy intend to respond to ail relevant 9 MR. GOLDBERGER: Form. 9 questions regarding this lawsuit; however, at the 1 0 BY MR. KUVIN: 1 0 present time, my attorneys have counseled me i cannot 1 1 Q. -- did you feel a need to respond at that 1 1 provide answers to any questions relevant to this 1 2 point? 1 2 lawsuit. I must accept this advice or risk losing my 1 3 MR. HKE: Object to the form. 1 3 6th Amendment right to effective representation. 1 4 MR. GOLDBERGER: The invocation of 5th 1 4 Accordingly, i assert my federal constitutional right as 1 5 Amendment privileges is going to be decided by me, 1 5 guaranteed by the 5th, 6th and 14th Amendment to the US 1 6 as Mr. Epstein's criminal counsei. {will make 1 6 Constitution. 1 that decision. 17 Q. i noticed that Mr. Goldberger shook his head 1 8 MR. KUVIN: Okay. I wouid just like to note 1 8 when I asked you where you lived. Do you have a probiem 1 9 for the record that that's improper. That?s not 1 9 letting us know where you live? 2 0 what the case iaw says, and we?ll take that up u- 2 0 i?m trying to understand why that issue is 2 1 MR. GOLDBERGER: Fair enough. 2 protected by the 5th Amendment, given the fact that 2 2 MR. KUVIN: issue with Judge Hafeie? 2 2 you?re required to live at that address pursuant to the 2 3 BY MR. KUVIN: 2 3 sexual offender flyer and pursuant to the Court?s order Q. All right, sir. Do you consider yourself a 2 4 convicting you based on your guilty plea. MR PIKE: Form, argumentative. 4 (Pages 28 to 31 "x *5 Aft "31? MR im Waste; is use}: #nmxatemenasura antiserum ensure: (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-37506 Electronicaiiy signed by Joana Ricciuti (6014804288381) Electronically signed by Joana Ricciuti (601-280-428-9381) a4?l 9 Page 32 Page 34 1 THE Do you want to repeat the 1 purple item retrieved from your trash at 358 El Briilo a 2 question? 2 Way that appeared to be a device known as a jelly anal 3 BY MR. KUVIN: 3 wand. Have you ever heard of something like that? 4 Q. Sure. Did the Court require you to stay at 4 MR. Form, argumentative, harassing. 5 358 El Brillc Way on Palm Beach 5 Same objections, attorney~client work product. 6 (Interruption in the proceedings.) 6 THE WITNESS: I fully intend to respond to all 7 BY MR. KEVIN: 7 relevant questions regarding this lawsuit; however, 8 Q. Sir, did the Court require you to stay at 358 8 at the present time, my attorneys have counseled me 9 El Brillo Way, i?alm Beach, Florida subsequent to you 9 I cannot provide answers to any questions relevant 1 0 being released from prison? 1 0 to this lawsuit. 1 must accept this advice or risk 1 1 MR. Form. 11 losing my 6th Amendment right to effective 1 2 THE WITNESS: I fully intend to respond to all 1 2 representation. Accordingly, I assert my federal 1 3 relevant questions regarding this lawsuit; however, 1 3 constitutional rights as guaranteed by the 5th, 6th 1 4 at the present time, my attorneys have counseled me 1 4 and 14th Amendment to the US Constitution. 15 i cannot provide any answers to questions relevant 1 5 BY MR. KUVIN: 16 to this lawsuit. 1 must accept this advice or risk 1 6 Q. Outside of your home at 358 El Brillo Way was 17 losing my 6th Amendment right to effective 1 7 also recovered a 3~inch purple-sized ?nger -- I'm 1 8 representation. Accordingly, assert my federal 1 8 sorry, a 3?inch purple linger-sized object which had a 1 9 constitutional rights as guaranteed by the 5th, 1 9 broken end, which is apparently a sexual toy similar -- 2 0 6th and l4th Amendment to the US Constitution. 2 0 similar to a cyclone vibrator possibly used for rectal 2 1 BY MR. 2 1 grati?cation. 22 Q. Let?s go ahead and mark as Exhibit 3 a nice 2 2 Do you know what a cyclone vibrator is? 2 3 photo of your home. 2 3 A. No. 24 (i?laintift's Exhibit No. 3 was marked for 2 4 MR. PIKE: Form, harassing. 25 identi?cation.) 2 5 THE, WITNESS: No, but i do know that that Page 33 Page 35 1 BY MR. KUVIN: 1 MR. PIKE: Same objections. 2 Q. Okay. Let?s get this for the camera, if I 2 THE WITNESS: -- broken purple object turned 3 could. Okay. 3 out to be, later on, described as a salad fork from 4 All right. I'm going to Show you what l?ve 4 the kitchen, strictly something that had been 5 marked as Exhibit 3. is that a photograph of your home, 5 broken in the dishwasher and then reported it in a 6 sir, at 358 E1 Brillo Way? 6 report obviously inaccurately. 7 A. I fully intend to respond to all relevant ?7 BY MR. KUVIN: 8 questions regarding this lawsuit; however, at the 8 Q. Okay. So the broken 9 present time, my attorneys have counseled rue i cannot 9 A. Salad fork, nothing more than a broken salad 0 provide answors to any questions relevant to this 1 0 fork, correct. 11 lawsuit. 1 must accept this advice or risk losing my 3. 1 Q. So the 3~inch purple linger-sized object was a 1 2 6th Amendment right to effective representation. 12 salad fork? 1 3 Accordingly, assert my federal constitutional rights 1 3 A. Was a broken handle of a salad fork. Yes, the 1 4 as guaranteed by the 5th, 6th and lath Amendment to the 1 4 question has been asked and answered, i believe. 1 5 US Constitution. 15 Q. Okay. When did you see that? 1 6 Q. had asked you before whether or not you 1 6 MR. PIKE: Form. '7 liked things inserted in your anus for sexual 3.7 THE WITNESS: See what? 18 gratification, and l?d like to go back to that for a 1 8 BY MR. 19 moment, if I could. 1 9 Q. Well, you called -- 2 0 Have you read the police report, incident 2 A. See that. What's the that? 2 1 report, on your arrest? 2 1 Q. You called it a salad fork. 2 2 MR. Form, argumentative, harassing. 2 2 When did you see the salad. fork after the 2 3 MR. GOLDBERGER: Attorney~client work product. 2 3 police had taken it into custody? 24 BY MR. KUVIN: 2 4 MR. PIKE: Form. 25 Q. Sir, according to the report, there was a 2 5 THE WITNESS: I did not see the salad fork, .. .. 5 (Pages 32 to 35) (561) 832~7500 PROSE COURT REPORTING AGENCY, INC. (563.) 832*7506 Electronically signed by Joana Ricciuti (601-2804283381) Electronically signed by Joana Ricciuti (601-280-428-938?) Page 3 6 Page 38 . 1 nor did i represent that I did see the salad fork. 1 (Plaintiffs Exhibit No. 4 was marked for 2 BY MR. KUVZN: 2 identi?cation.) 3 Q. Okay. So you have no idea what it was that 3 MR. Okay- All right Ifwe could. 4 the police took out of the trash? 4 just get a shot of that for me. 5 A. The poiice 5 Okay, thank you. 6 MR. PIKE: Form. 6 BY MR. KUVIN: 7 THE WITNESS: filed a later report saying 7 Q. According to the incident report, in a room of 8 it was a salad fork, I believe. 8 your home in 9 BY MR. KUVXN: 9 MR. PIKE: What page are you on, Counsel? 10 Q. You never saw that piece, did you? 1 0 MR. KUVZN: Page 44. 3.1 A. No. 1 MR. PIKE: What paragraph? 3.2 Q. You have no idea what it was that they took 1.2 MR. KUVIN: Line 4. 1 3 out of there? 1 3 BY MR. 14 MR. PIKE: Formdresser armoire was located a bottle 15 "mm 1 just said the police said it; 1 5 of peach-flavored .ioy Jelly, parenthetically a sexual 1 6 was a salad fork, a mere salad fork misrepresented 6 lubricant. 17 in that police report, as many things have been, it 1 7 i have here something cailed Joy Jelly. I 1 8 seems, 1 8 even have peach. Do you know what that isMR. PIKE: Form objection, harassing. 2 Q. Did they misrepresent the jelly anal wand? 2 0 MR. GOLDBERGER: Can youjust clarify the 2 1 A. i?ve 2 1 question as to where you got that? Did that come 2 2 MR. PIKE: Form. 22 from your home or from somewhere else, Mr. Kuvin? 2 3 THE WITNESS: -- never heard of that before. 2 3 MR. KUVIN: I don?t think that's relevant. 2 4 BY MR. KUVIN: 2 4 MR. GOLDBERGER: Just curious as to what 2 5 Q. Have you used Vibrators that you?ve placed in 25 you're you?ve made a big point to identify this, Page 37 Page 39 1 your anus? 1 this exhibit, and show it to the camera. So if my 2 MR. PIKE: Form, objection, harassing. 2 client is going to answer the question, I'd like to 3 THE WITNESS: No. 3 know whether it came from your home or from 4 BY MR. KUVIN: 4 whether you bought it or where it came from just so 5 Q. You never placed anything like a vibrator in 5 he can just so he can accurately answer the 6 your anus? 6 question should he choose to want to answer it. 7 MR. PIKE: Same objections. "7 MR. KUVIN: Well, he can make the choice 8 THE WITNESS: No. 8 whether he wants to answer it or not. 9 BY MR. KUVIN: 9 MR. GOLDBERGER: All right. Q. There was in a dresser of an armoire of your 1 0 BY MR. KUVIN: 1 home 3. 1 Q. Do you know what that is? 12 MR. KUVIN: This is page 44, Counsel. i.?d 1 2 MR. PIKE: Form objection, improper 1 3 like to reference it. 1 3 hypothetical. 14 THE WITNESS: is that marked as an exhibit? 4 THE WITNESS: I don't understand the question. 3. a don?t know what he's reading. 1 5 BY MR. KUVIN: 1 6 MR. PIKE: It's not marked as an exhibit. 6 Q. Do you know what Exhibit 4 is? WITNESS: The police report? 17 A. You've just described it. i have no knowledge 18 BY MR. sown: 3.8 but what you've just described. 9 Q. No, it's not. it?s my work product, much like 1 9 Q. You don't know what that's used for? 2 0 how Mr. Goldberger felt that your 5th Amendment was your 2 0 MR. Form objection, harassing. 2 1 work product. 2 1 THE WITNESS: I've heard what you said it?s 2 2 MR. KUVIN: So let's mark this as exhibit 2 2 used for. I've never seen it before. 2 3 what are MR. KUVIN: 24 COURT REPORTER: 4. 2 4 Q. Do you know what that, right there, Exhibit 4, 2 5 2 5 this peach??avored 6 (Pages 36-to 39) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?97506 Electronically signed by Joana Ricciuti (601 ~280-428-9381) Electronically signed by Jeane Ricciuti (601-280-428-9381) 341 9 Page 4 Page 4 2 3. A. You've asked me that question already. 1 MR. Form, lack of predicate. 2 Q. Joy Jelly, do you know what it?s used for? 2 BY MR. KUVIN: 3 MR. i?lKE: Asked and answered. 3 Q. Have you used it? 4 BY MR. 4 MR. i?lKE: Same objection, lack of predicate, 5 Q. Not this bottle, but Joy leliy, do you know 5 no foundation, harassing. 6 what it's used for? 6 THE WITNESS: 1 fully intend to respond to all 7 MR. i?iKE: Same objection, harassing, asked 7 relevant questions regarding this lawsuit; however, 8 and answered. 8 at this time, I cannot provide any questions [sic] 9 BY MR. KUVZN: 9 relevant to the lawsuit. 1 must accept counsels? 1 Q. You can answer. 1 0 advice or risk losing my 6th Amendment right to 1 1 A. I?ve already told you. 3. 1 effective representation. Accordingly, I assert my 1 2 Q. You still haven?t answered the question. it 2 federal constitutional rights as guaranteed by the 13 MR. PIKE: Counsel, he answered the question. 1 3 5th, 6th and 14th Amendment to the US Constitution. i. 4 It?s been asked and answered twice. 1 4 BY MR. KUVIN: 5 MR. GOLDBERGER: Let's get a read~back on 1 5 Q. Would you agree with the description that you 1 6 this. 1 6 are a pervert? 1 7 MR. KUVIN: Sure. I'd like to hear the 1 7 MR. PIKE: Same objection, harassing, 1 8 answer. 1 8 argumentative. g; 1 9 MR. GOLDBERGER: From the start of the line of 1 9 BY MR. KUVIN: 20 questioning. 2 Q. You can answer. It?s either a simple yes or 2 1 From the first time asked? 2 2 A. I fully intend to respond to all relevant 2 3 MR. GOLDBERGER: Yes, please. 2 3 questions regarding this lawsuit; however, at the 2 4 (A portion of the record was read by the 2 4 present time, my attorneys have counseled me that . 2 5 reporter.) 2 5 cannot provide answers to any questions relevant to this Rage 41 Page 43 1 MR. GOLDBERGER: That?s all I need to hear, 1 lawsuit. i must accept this advice or risk losing my 2 thanks. 2 6th Amendment right to effective representation. 3 BY MR. KUVIN: 3 Accordingly, I must assert my federal constitutional 4 Q. Do you know what Joy Jelly is used for? 4 rights as guaranteed by the 5th, 6th and 14th Amendment 5 A. I've heard what you've just described. I have 5 of the US Constitution. 6 no independent knowledge. 6 Q. Have any mental health counselors diagnosed 7 Q. You've never used Joy Jelly? 7 you as a sexual deviant? 8 A. I fully intend to respond to all relevant 8 MR. PIKE: Again, form 9 questions regarding this lawsuit; however, at the 9 THE WITNESS: I don?t believe so. 10 present time, my attorneys have counseled me I cannot 1 0 MR. PIKE: work product. 1 1 provide an answer to any questions relevant to this 1 1 BY MR. 12 lawsuit. i must accept this advice or risk losing my 12 Q. Do you believe you're a sexual deviant? 1 3 6th Amendment right to effective representation. 1 3 MR. PIKE: Form. 1 4 Accordingly, I assert my federal constitutional rights 1 4 THE WITNESS: No, I do not. 1 5 as guaranteed by the 5th, 6th and l4th Amendment to the 15 BY MR. KUVIN: 6 US Constitution. 1 6 Q. Do you have sex with minors? 1 7 Q. You agree with me that Joy jelly is a sexual 17 MR. PZKE: Same objection, form, 5th 1 8 lubricant that's used on sexual devices like vibrators 1 8 Amendment. 1 9 and anal jelly wands? 1 9 THE WITNESS: 1 fully intend to respond to all 20 MR. Same objections. 2 0 relevant questions regarding this lawsuit; however, 2 1 THE WITNESS: I have no'knowledge of that. 2 1 at the present time, my attorneys have counseled me 2 2 BY MR. ELEVEN: 2 2 I cannot provide answers to any questions relevant 2 3 Q. Do you agree that Joy Eelly is a sexual 2 3 to this lawsuit. I must accept this advice or risk 2 4 lubricant? 2 a losing my 6th Amendment right to effective 2 5 A. I have no knowledge of that. 25 representation. Accordingly, assert my federal 7 (Pages 40 to 43) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronically signed by Joana Ricciuti (601-280-428~9381) - Electronically signed by Jeane Ricciuti (601~280-428-9381) Page 4 4 Page 4 6 3 constitutional rights as guaranteed by the 5th, 6th 1 MR. Same objection, attorney?client, 2 and 14th Amendment to the US Constitution. 2 work product. 3 BY MR. KUVIN: 3 MR. KUVIN: Are you telling him not to answer? 4 Q. Would you agree that you have a. 4 MR. PIKE: It?s attorney-client, work product. 5 disorder with respect to your sexual preferences? 5 I'm instructing him not to answer. 6 MR. PIKE: Same objection. 6 BY MR. KUVIN: 7 THE WITNESS: I fully intend to respond to all 7 Q. Okay. So despite the fact that you're reading 8 relevant questions regarding this lawsuit; however 8 this canned statement over and over to my questions, you 9 at the present time, my attorneys have counseled me 9 don't want to answer any questions about the written 1 I cannot provide answers to any questions relevant 1 0 statement; isn?t that true? 1 to this lawsuit. I must accept this advice or risk 1 1 MR. PIKE: Same objection, attorney-client, i 2 losing my 6th Amendment right to effective 1 2 work product. I'm instructing the witness not to 1 3 representation. Accordingly, assert my federal 3 answer. i4 constitutional rights as guaranteed by the 5th, 1 4 BY MR. KUVIN: 15 6th and 14th Amendment to the US Constitution. 15 Q. You don?t ever fully intend to respond anything, do you? 1 7 Q. Have you had sex with transsexuals? 1 7 MR. PIKE: Same objection. 1 8 MR. PIKE: Same objection. 1 8 BY MR. KUVIN: 1 9 THE WITNESS: No. 1 9 Q. Or would you like to? 2 0 BY MR. KUVIN: 20 MR. PIKE: Same objection. Now we're getting 2 1 Q. Do you know a Ms. Cordero? 2 borderline harassing and argumentative. 2 2 A. I fully intend to respond to all relevant 22 I think you should move on to certainly you 2 3 questions regarding this lawsuit; however, at the 23 didn?t come here to be argumentative and harassing 2 4 present time, my attorneys have counseled rne cannot 24 all day, Mr. Kevin, so i would hope that you would 2 5 provide answers to any questions relevant to this 2 5 move on to another topic. Page 4 5 Page 47 it lawsuit. I must accept this advice or risk losing my 1 THE WITNESS: Jack? 2 6th Amendment right to effective representation. 2 MR. KUVIN: i'm just looking. 3 Accordingly, assert my federal constitutional rights 3 MR. GOLDBERGER: He can look at it all he 4 as guaranteed by the 5th, 6th and 14th Amendments to the 4 wants. 5 US Constitution. 5 lust ask for permission next time, if you want 6 Q. Do you know a Ms. Maximilia Cordero? 6 to, because it is something that I gave to my 7 MR. PIKE: Same objection. 7 client. So when you want to look -- I've let you 8 THE WITNESS: I fully intend to respond to all 8 mark it. If you want to look at it, just ask my 9 relevant questions regarding this lawsuit; however, 9 permission to do so, okay? 10 at the present time, my attorneys have counseled me 1 0 MR. KUVIN: Sure. 1 i cannot provide answers to any questions relevant 1 MR. GOLDBERGER: is that all right with you? 1 2 to this lawsuit. 1 must accept this advice or risk 12 MR. KUVIN: Perfectly line. 3 losing my 6th Amendment right to effective 13 MR. GOLDBERGER: Thanks. 4 representation. Accordingly, i assert my federal 14 BY MR. 15 constitutional rights as guaranteed by the 5th, 15 Q. Your typed paper there says that you cannot 1 6 6th and Mill Amendment to the US Constitution. 1 6 provide answers. Why not? BY MR. 17 MR. PIKE: Attorney?client, work product. I?m 1 8 Q. When do you intend to fully respond? 3. 8 instructing him not to answer. it?s my work 9 MR. PIKE: Same objection. in addition, work 1 9 product. 2 0 product, attorney-client. 2 0 MR. Are you stipulating that you 2 1 BY MR. KUVIN: 2 drafted the document we've marked as Exhibit 2? 2 2 Q. I?m sorry, I misquoted you. You said I -- 22 MR. No such stipulation. 23 you?ve repeated now numerous times, fully intend to 2 3 MR. PIKE: No such stipulation. 2 4 respond, so let me rephrase my question. 2 fl MR. KUVIN: Well, if it?s work product -- 2 5 When do you fully intend to respond? 2 5 MR. PIKE: It's attorney-client, work product. 8 (Pages 44 to 47) (561) 832?7500 PROBE COURT REPORTING AGENCY, INC. (561) 832~7506 Electronically signed by Jenna Ricciuti (601-2804284338?) Electronically signed by Jeane Ricciuti (601-2804289381) Page 4 8 Page 50 1. MR. KUVIN: Ijust wanted to clarify. 1 Q. Okay. Go ahead. Don't wait for me. 2 BY MR. nevus: 2 A. 5th, 6th and 14th Amendment to the us 3 Q. Did you have a sexual relationship with 3 Constitution. 4 Maximilia Cordero when she still had a penis? 4 Q. Okay. You agree, would you not, that 5 MR. PIKE: Same objection. 5th Amendment. 5 Sarah Kellen is currently dating Story Kowles, the 6 THE WITNESS: fully intend to respond to all 6 gentleman who is sitting here in the room working for 7 relevant questions regarding this lawsuit; however, 7 Mr. Goldberger at your deposition? 8 at the present time, my attorneys have counseled me 8 A. l. fully intend to respond to all relevant I 9 I cannot provide answers to any questions relevant 9 questions regarding this lawsuit; however, at the 1 0 to this lawsuit. I must I must accept this 1 0 present time, my attorneys have counseled me I cannot 3. 1 advice or risk losing my 6th Amendment right to 1 1 provide answers to any questions relevant to this 2 effective representation. Accordingly, I assert my 1 2 lawsuit. I must accept their advice or risk losing my 1 3 federal constitutional rights as guaranteed by the 1 3 6th Amendment right to effective representation. 1 4 5th, 6th and 14th Amendment to the US Constitution. 1 ?4i Accordingly, I assert my federal constitutional rights 1 5 BY MR. KUVIN: 15 as guaranteed by the 5th, 6th and 14th Amendment to the l. 6 Q. Do you know Sarah Kellen? 1 6 US Constitution. 1 7 A. I fully intend to respond to all relevant 3.7 Q. Do you know how long Sarah Kellen has been a 1 8 questions regarding this lawsuit; however, at the 1 8 dating Mr. Story Kowles? 9 present time, my attorneys have counseled me I cannot 1 9 A. I fully intend to respond to all relevant 2 0 provide answers to any questions relevant to this 2 0 questions regarding this lawsuit; however, at the 2 1 lawsuit. I must accept this advice or risk losing my 2 1 present time, my attorneys have counseled me I cannot 2 2 6th Amendment right to effective representation. 2 2 provide answers to any? questions relevant to this 2 3 Accordingly, I assert my federal constitutional rights 2 3 lawsuit. i must accept this advice or risk losing my 2 4 as guaranteed by the 5th, 6th and 14th Amendment to the 2 4 6th Amendment right to effective representation. 2 5 US Constitution. 2 5 Accordingly, i assert my federal constitutional right as Page 49 Page 51 it Q. You agree, do you not, that Sarah Kellen is, 1 guaranteed by the 5th, 6th and 14th Amendment to the US 2 or as least was, your personal assistant for many years? 2 Constitution. 3 MR. PIKE: Same objection. 3 Q. Did you introduce Ms. Kellen to Story Kowles? 4 THE WITNESS: I fully intend to respond to all 4 A. I fully intend to respond to all relevant 5 relevant questions regarding this lawsuit; however, 5 questions regarding this lawsuit; however, at the 6 at the present time, my attorneys have counseled me 6 present time, my attorneys have counseled me I cannot 7 I cannot provide answers to any questions relevant 7 provide answers to any questions relevant to this 8 to this lawsuit. I must accept this advice or risk 8 lawsuit. i must accept this advice or risk losing my 9 losing -- 9 6th Amendment right to effective representation. 1 0 MR. GOLDBERGER: Why don?t you why don?t 1 0 Accordingly, I assert my federal constitutional rights 1 1 you wait until he?s listening, so 13. as guaranteed by the 5th, 6th and 14th Amendment to the 1 2 MR. KUVIN: Oh, I don?t need to listen. I?ve 2 Constitution. 3 heard it many times. 1 3 Q. Are you aware that one of the State 1 4 MR. GOLDBERGER: No, we're going to Wait. 1 prosecutors, Dahlia Weiss, who was working on your 1 5 We're going to wait. 1 5 criminal case, was also married to a lawyer working for it. 6 MR. KUVIN: Oh, no, you don?t have to wait. 1 6 Mr. Goldberger here? 1 7 MR. GOLDBERGER: Oh, no, We will. 17 MR. GOLDBERGER: Attorney?client, work 18 BY MR. 18 product. 1 9 Q. Okay. I?m sorry, are you done? 1 9 Don?t answer. 2 A. No. 2 0 MR. I'm sorry, work product? 2 1 Q. Oh, please finish. 2 Somehody's marriage? 22 A. I must accept this advice or risk losing my 22 MR. GOLDBERGER: Uh?huh. Don't answer it. 2 3 6th Amendment right to effective representation. 2 3 MR. KUVIN: I?d like an explanation as to how 2 4 Accordingly, assert my federal constitutional rights 2 someone's marriage is work product on the record so 2 5 as guaranteed clear to determine whether I need to bring - 9 (Pages 48 to 51) (563.) 832-57500 PROBE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Joana Ricciuti (601-2804286381) Electronically signed by Joana Ricciuti (601-280-428-938'2) a4?! Page 52 Page 5 4 1 that question up in front of Judge Hafele. 3. reasonably calculated to lead to admissible 2 MR. PIKE: The rules do not require for 2 evidence in this case. 3 speaking objections, and we're going to limit 3 THE WITNESS: No. 4 ourself to form and the appropriate objections 4 BY MR. KUVIN: 5 thereafter, which have been asserted. So there 5 Q. It's a shame. i 6 does not need to be anything in the record. Should 6 MR. GOLDBERGBR: What was that? 7 you wish to file a motion, you can do so. 7 THE WITNESS: Shame, he said. 8 MR. Well, before I ?le such motion, I 8 BY MR. 9 think the rules also dictate that I can request an 9 Q. Why not? 1 0 explanation, which l'm doing. 1 0 MR. PIKE: Objection, relevance. I?m going to i 1 3. MR. BIKE: We?ve already objected. instruct him not to answer the question. it?s l. 2 MR. KUVIN: Okay. 1 2 argumentative. 3 BY MR. KUVIN: 3. 3 BY MR. KUVIN: i. 4 Q. you know Dahlia Weiss? 3. 4 Q. is there anyone else that you know that is 1 5 A. I fully intend to respond to all relevant 3. 5 dating staff at Mr. Goldberger's ofti so other than 6 questions regarding this lawsuit; however, at the 3. 6 Ms. Kellen and Ms. Wife Ms. Weiss? Li. 7 present time, my attorneys have counseled me I cannot 1 7 MR. PIKE: Objection, form. i 1 8 provide answers to any questions relevant to this 1 8 MR. GOLDBERGER: Whoa, whoa, whoa. First of 19 lawsuit. i must accept this advice or risk losing my 19 all, let?s get the question right. Ms. Kellen and 2 0 6th Amendment right to effective representation. 2 0 Ms. Weiss are dating each other; is that the 2 3. MR. GOLDBERGER: Actually, till let you answer 2 1 question? 22 the question as asked, as to do you know Dahlia 22 MR. KUVIN: No, l'll clarify. 23 Weiss. 23 MR. GOLDBERGER: Thank you. 2 4 Tea WITNESS: No, I do not. 2 4 BY MR. KUVINthere anyone else that you know that's it Page 53 Page 5 5 1 BY MR. KUVIN: 1 dating staff at Mr. Goldberger's office other than 2 Q. With respect to Mr. Goldberger, your criminal 2 Ms. Kellen, or married to staff working for 3 attorney, did you buy him a brand new 3 Mr. Goldberger other than Ms. Weiss? 4 MR. GOLDBERGER: Don't. 4 MR. GOLDBERGER: There are peeple 5 THE WITNESS: i fully intend to respond to all 5 MR. PIKE: Objection, form, multiple, 6 relevant questions regarding this lawsuit; however, 6 compound, vague, irrelevant, not reasonably 7 at the present time, my attorneys have counseled me 7 calculated to lead to admissible evidence. 8 I cannot provide answers to any questions relevant 8 MR. GOLDBERGER: Do you understand the 9 to this lawsuit. must accept this advice or risk 9 question? The question as asked: Do you know 0 losing my 6th Amendment right to effective 1 0 anyone who dates anyone at my office? representation. 1 1 THE WITNESS: This is why this is why we?re l. 2 MR. GOLOBERGER: It?s also attorney-client and 1 2 here? 13 work product as to my fees. 1 3 MR. GOLDBERGER: I mean, do you know the 1 4 THE WITNESS: Accordingly, I assert my federal 1 4 question is: Do you know if anyone in my office 1 5 constitutional rights as guaranteed by the 5th, 6th 1 5 dates anybody? 1 6 and l4th Amendment to the US Constitution. 1 6 THE WITNESS: No, I do not. 17 MR. GOLDBERGER: l'rn sorry, it's also 17 MR. GOLDBERGER: Okay. 1 8 attorney~client work product as to my fees. 1 8 BY MR. KUVIN: 19 BY MR. KUVIN: 9 Q. That's a good point. I?m glad you made it. 2 Q. Have you bought any new cars for your civil 2 0 No, you know why we?re here? We?re here to 2 1 attorneys, like Mr. Critton? 2 1 ask you whether or not you had any sexual contact with 2 2 MR. PIKE: Objection, relevance. 2 2 BB. Did youWho? 2 4 Q. Robert Critton. 2 4 Q. With a young girl that was 14 years old. 2 5 MR. BIKE: Argumentative, harassing, not 2 5 A. What was her name? 10 (Pages 52 to 55) (561) 832-4500 PROBE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeane Ricciuti {801~280~428~9381) Electronically signed by Jeane Ricciuti {601;280?4288381} a4?! Page 56 Page 58 L. 1 Q. BB. 3. MR. KUVIN: {just wanted to make sure. 2 A. Can you refresh my recoliection who she do 2 MR. GOLDBERGER: Spencer, i?m not going to get 3 you have anything to show me, something that might 3 into an argument with you. i want you pursuant to the 4 MR. KUVIN: I don?t want to argue. You asked 5 con?dentiaiity that we've previously discussed in this 5 me it? I was ciear 6 case. 6 MR. GOLDBERGER: Let me iet rne finish 7 A. So teii me who it is that you're representing? 7 what - 8 Q. i will do that. 8 MR. KUVIN: -- and 131131; wanted to be ciear. 9 Have you had sex with numerous girls underage? 9 MR. GOLDBERGER: Are you -- are you going to 3.0 A. You?ve asked me if this which question 10 let me ?nish what I'm saying? 1 1 MR. GOLDBERGER: Wait, the question was 1 3. MR. KUVIN: Ijust wanted to know if I was 12 MR. KUVIN: i?il strike the question and 12 clear. You're trying to teli me to keep my mouth 1 3 rephrase. 3 shut. 3.4 MR. GOLDBERGER: Which question are you 1 4 MR. GOLDBERGER: Ali right. 1 5 striking? 1 5 MR. KUVIN: So i wanted to make sure that the 1 6 MR. KUVIN: i wili strike all of them and 1 6 record was patentiy ciear what you're asking me to 1 7 rephrase. 7 do. 1 8 BY MR. KUVIN: 1 8 MR. GOLDBERGER: Are you done? 1 9 Q. Did you have sex with underaged -- 3. 9 MR. KUVIN: I'm done. 20 MR. GOLDBERGER: Sorry, wait a minute. Wait a 20 MR. GOLDBERGER: Okay. So the response to 2 1 minute. Let mejust ciarify. The question that 2 1 your question is, I want you to aliow my ciient 22 you're striking is, did you have sex with a woman 22 iet me finish aiiow my ciient to finish his 2 3 by the name of 13.13.? 2 3 answers. if you want to interrupt while he's 2 4 MR. KUVIN: Right. 2 4 asking while he's answering a question, i?m not 2 5 MR. GOLDBERGER: That's question one? 2 5 going to aiiow you to do that. if you want to Page 57 Page 5 9 1 And the second question you're striking is? 1 respond to a question that he answers by being 2 MR. KUVIN: i'm moving on. 2 argumentative, you can do so, and the appropriate 3 BY MR. KUVIN: 3 objection be entered. 4 Q. Do you have sex with underaged giris? 4 My oniy point of my response to you was that I 5 A. I fuiiy intend to respond to reievant 5 do not want you interfering while he is answering a 6 questions regarding this lawsuit -- 6 question, that?s it, okay? {just want you to act 7 MR. GOLDBERGER: Let do me a favor. After 7 ethicaiiy, honorably and fair. 8 you ask the question, he's going to answer it. 8 MR. KUVIN: i would ask you to do the same 9 Keep your mouth shut and let him answer the 9 MR. GOLDBERGER: i?m trying. 10 question, and don't editoriaiize while the question 10 MR. KUVIN: and to stop your speaking 1 is being answered. ifyou want to editorialize 1 1 objections. 12 afterwards in the form of another question, go 12 MR. GOLDBERGER: I'm trying. 1 3 ahead, but while he?s answering the question, do 1 3 MR. KUVIN: Objection to form usually works, i. 4 not say anything. Are we -- are we clear on that? 4 according to our local rules. 15 MR. i'm sorry, ijust want to he 1 5 MR. GOLDBERGER: Okay. 6 clear, did youjust tell me to keep my mouth shut? 1 6 MR. KUVIN: Okay? Thank you. 17' MR. GOLDBERGER: White my client is answering l7 Maybe when you get into the civil arena, you'd 1 8 a question. 1 8 understand. 1 9 MR. KUVIN: So you're telling me I need to 1 9 MR. PIKE: Let?s move on. 2 0 keep my mouth shut? 2 0 MR. KUVIN: But Ijust Want to make sure that 2 3. MR. GOLDBERGER: No, no. i'm telling 2 1 you're on the same page. 2.2 you to 22 MR. oomesnoea: Spencer -- 23 MR. is that i?m sorry, i thought 2 3 MR. PIKE: Let's move on. 2 4 that's what i heard. 2 4 MR. I appreciate it. 25 MR. GOLDBERGER: Spencer, i'm not 2 5 MR. GOLDBERGER: Let's move on. 11 (Pages 56 to 59) (561) 832-7500' PROSE COURT REPORTING AGENCY, INC. (563.) 832?7506 Etectronicaiiy signed by Joana Riccioti (601-2804288381) Eiectronicaiiy signed by Joana Ricciuti (601-2804283381) a4? Page 60 Page 62 1 BY MR. KUVIN: I. cannot provide answers to any questions relevant 2 Q. Do you have sex with underaged girls, that's 2 to this lawsuit. I must accept this advice or risk 3 the reason we?re here, is it not, Mr. Epstein, to answer 3 losing my 6th Amendment right to effective 4 that question? 4 representation. Accordingly, assert my federal 5 MR. PIKE: Form. 5 constitutional rights as guaranteed by the 5th, 6th 6 av MR. 6 and 14th Amendment to the US Constitution. 7 Q. Do you want to answer that question for us 7 BY MR. KUVIN: 8 today? 8 Q. Isn't true that you've sexually molested girls 9 MR. Multiple, compound. 9 under the age of 3.0 THE WITNESS: What's the question? 1 0 MR. PIKE: Same objection. 1 it BY MR. KUVIN: 1 1 THE. WITNESS: fully intend to respond to all 1 2 Q. Do you have sex with underaged girls? It 2 relevant questions regarding this lawsuit; however, 1 3 A. I fully intend to respond to all relevant 1 3 at the present time, my attorneys have counseled me 4 queS?OnS regarding this laWSUil; however, at the 1 4 I. cannot provide answers to any questions relevant 1 5 present time, my attorneys have counseled me I cannot 1 5 to this lawsuit. 1 must accept this advice or risk 1 6 provide answers to any questions relevant to this 1 6 losing my 6th Amendment right to effective l7 lawsuit. 1 must accept this advice or risk losing my 1 7 representation. Accordingly, I assert my federal 1 8 6th Amendment right to effective representation. 1 8 constitutional rights as guaranteed by the 5th, 6th 1 9 Accordingly, i assert my federal constitutional rights 1 9 and 14th Amendment to the US Constitution. it 20 as guaranteed by the 5th, 6th and l4th Amendments to the 2 0 BY MR. KUVIN: 2 1 US Constitution. 2 1 Q. isn't it true that you've asked numerous, 2 2 Q. isn?t it true that you like to have sex with 2 2 possibly hundreds, of underaged girls to have sex with 2 3 little girls? 2 3 you? 24 MR. PIKE: Same objection. 2 4 MR. Same objection, argumentative, 2 5 2 5 harassing. Page 63. Page 63 1 BY MR. KUVIN: 1 THE WITNESS: I fully intend to respond to all 2 Q. Girls under the age of 8? 2 relevant questions regarding this lawsuit; however, 3 MR. PIKE: Argumentative, harassing. 3 at the present time, my attorneys have counseled rne 4 THE WITNESS: One question or two? 4 I cannot provide answers to any questions relevant 5 BY MR. KUVIN: 5 to this lawsuit. I must accept this advice or risk 6 Q. Isn?t it true that you like to have sex ?with 6 iosin my 6th Amendment right to effective '7 little girls who are under the age of 18? 7 representation. Accordingly, I assert my federal 8 MR. Argumentative, harassing. 8 constitutional rights as guaranteed by the 5th, 6th 9 THE WITNESS: I fully intend to respond to all 9 and 14th Amendment to the US Constitution. 1 0 relevant questions regarding this lawsuit; however, 1 0 BY MR. KEVIN: 1 at the present time, my attorneys have counseled me 1 1 Q. isn?t it true that you've told Sarah Kellen to 12 I cannot provide answers to any questions relevant 3.2 avoid service of a witness subpoena in this case because 1 3 to this lawsuit. I must accept this advice or risk 1 3 she has information that would incriminate you? 14 losing my 6th Amendment right to effective 1 4 A. I fully intend to respond to all relevant i 5 representation. Accordingly, I assert my federal 3. 5 questions regarding this lawsuit; however, at the 6 constitutional rights as guaranteed by the 5th, 6th 3. 6 present time, my attorneys have counseled me I cannot 1 7 and 14th Amendment to the US Constitution. it 7 provide answers to any questions relevant to this 18 BY MR. KUVIN: 1 8 lawsuit. 1 must accept this advice or risk losing my Li. 9 Q. isn't it true that you've asked little girls 1 9 6th Amendment right to effective representation. 2 8 under the age of 18 to see their vaginas? 2 0 MR. PIKE: In addition, the question is 2 3. MR. PIKE: Same objection, argumentative, 2 1 argumentative; same objection as before. 2 2 harassing. 2 2 BY MR. KUVIN: 23 THE WITNESS: I fully intend to respond to all 2 3 Q. isn't it true that you conspired with Sarah 2 4 relevant questions regarding this lawsuit; however, 2 4 Kellen to obtain girls under the age of 18 to come to 2 5 at the present time, my attorneys have counseled me 2 5 your home, get naked and givo you messages while you 12 (Pages 60 to 63) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (563.) 832*7506 Electronically signed by Jenna Riceiuti (60%2804286381) Electronically signed by Jenna Ricciuti (60?2~280428~9381) a4? Page 64 Page 66 1 masturbated? 1 to this lawsuit. I must accept this advice or risk 2 MR. PIKE: Same objections, argumentative, 2 losing my 6th Amendment right to effective 3 harassing. 3 representation. Accordingly, I must assert my 4 THE WITNESS: I fully intend to respond to all 4 federal constitutional rights as guaranteed by the 5 relevant questions regarding this lawsuit; however, 5 5th, 6th and 14th Amendment to the US Constitution. 6 at the present time, my attorneys have counseled me 6 BY MR. KUVIN: 7 i cannot provide answers to any questions relevant 7 Q. isn't it true, sir, that you've had underaged 8 to this lawsuit. 1 must accept this advice or risk 8 girls under the age of l6 come to your home, get naked 9 losing my 6th Amendment right to effective 9 and give you massages while you masturbated? 1 representation. Accordingly, if assert my federal 1 0 MR. PIKE: For purposes of the record, I'm 1 1 constitutional rights as guaranteed by the 5th, 6th 1 1 just going to say same objection relating hack to 1 2 and 14th Amendment to the US Constitution. 1 2 the same objections. 13 BY MR. 1 3 THE WITNESS: I fully intend to respond to all 1 4 Q. Are you treating with a mental health 1 4 relevant questions regarding this lawsuit; however, 1 6 counselor currently? 1 5 at the present time, my attorneys have counseled cannot provide answers to any questions relevant 7 MR. PIKE: Work product. 1 7 to this lawsuit. i must accept this advice or risk 1 8 BY MR. KUVIN: 1 8 losing my 6th Amendment right to effective 9 Q. Did you go to the mental health counselor as 1 9 representation. Accordingly, assert my federal 2 0 required by your plea of guilty? 2 constitutional rights as guaranteed by the 5th, 6th 2 1 A. I fully intend to respond to all relevant 21 and 14th Amendment to the US Constitution. 2 2 questions regarding this lawsuit; however, at the 22 BY MR. KUVIN: 2 3 present time, my attorneys have counseled me I cannot 2 3 Q. isn't it true that you?ve had underaged girls 2 4 provide answers to any questions relevant to this 2 ti under the age of 15 come to your home, get naked and 2 5 lawsuit. I must accept this advice or risk losing my 2 5 give you massages while you masturbated? Page 65 Page 67 3. 6th Amendment right to effective representation. 1 MR. PIKE: Same objections. 2 Accordingly, I assert my federal constitutional rights 2 THE WITNESS: 1 WHY inle?d to respond to all 3 as guaranteed by the 5th, 6th and i4th Amendment to the 3 relevant Questions regarding this however, 4 US Constitution. 4 at the present time, my attorneys have counseled me 5 May we take a break? 5 I cannot provide answers to any questions relevant 6 MR. GOLDBERGER: Sure. 6 to this lawsuit. l. must accept this advice or risk 7 MR. PIKE: In addition to that, it's a 7 [using my 6th Amendment right to effective 8 privileged information. 8 representation. Accordingly, i assert rny federal 9 THE We're off the record at 9 constitutional rights as guaranteed by the 5th, 6th 1 10:50. 1 0 and 14th Amendment to the US Constitution. 1 1 (A brief recess was taken.) it 1 May 1 see talk to my counsel for a second 12 THE Back on the record at 12 outside? 1 3 1 1:00. 1 3 MR. KUVIN: Sure. 1 4 MR. KUVIN: Thank you. 1 4 MR. PIKE: Are we oft? it 5 BY MR. novel: 1 5 MR. KUVIN: Not yet. 6 Q. Isn?t it try, sir, that you?ve had under 3. 6 MR. PIKE: We're off the record. 1 7 girl underaged girls, under the age of 17, come to MR. KUVIN: We?re off that record. We?re not 1 8 your home, get naked and give you massages while you 1 8 off that record until everybody leaves. 1 9 masturbated? 1 9 MR. PIKE: Stop the video. The video off 2 0 MR. PIKE: Objection, form, argumentative, 2 0 the 2 l. harassing. 2 1 MR. KUVIN: i can't go off. the record if. it 2 2 THE WITNESS: I fully intend to respond with the lawsuit. 2 3 relevant questions regarding this lawsuit; however, 2 3 MR. PIKE: We don't have anyone here. .3 2 4 at the present time, my attorneys have counseled me 2 4 THE VIDEOGRAPHER: You know that you both have 2 5 I cannot provide answers to any questions relevant 25 to agree for us to go off the record. 13 (Pages 64 to 67) (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronically signed by Joana Ricciuti Electronically signed by Jeane Ricciuti {601 ~280~428~9381) Page 68 Page 70 1 MR. PIKE: We don't have anyone here. 1 MR. No. 2 MR. KUVIN: understand that, but i am not 2 MR. GOLDBERGBR: I'm sorry, you ready? 3 going off the record unless it's not pertaining to 3 MR. PIKE: Okay. a the lawsuit. if it?s not pertaining to the lawsuit 4 MR. KUVIN: Are we ready now? 5 that we're here about today, I'll go off the 5 MR. GOLDBERGER: Yep. 6 record, but if it pertains to the lawsuit, I cannot 6 MR. Rolling? 7 go off the record. 7 THE VIDEOGRAFHER: We're roiling at 11:05. 8 MR. PIKE: i don?t i don't understand. You 8 BY MR. 9 don": have a witness in a chair and you?re roiling 9 Q. Okay. Isn?t it true, sir, that you?ve had l. tape. 1 underaged girls under the age of 14 come to your home, 1 1 MR. KUVIN: Exactly. My tape is going to 1 get naked and give you massages while you masturbated? 1 2 constantly roll with respect to the litigation. 1 2 MR. Argumentative, harassing, 1 3 MR. PIKE: And the point? 13 irrelevant. Same objections as before. 1 4 MR. The point is I don?t want to miss 3. 4 THE WITNESS: fuliy intend to respond to all 3. 5 anything, and i want to make sure there's no 1 5 relevant questions regarding this lawsuit; however, 1 6 misrepresentations about what goes on with respect 1 6 at the present time, my attorneys have counseled me 1 7 to the litigation. 1 7 I cannot provide answers to any questions relevant 1 8 MR. PIKE: Then l'rn instructing you to keep 1 8 to this lawsuit. I must accept this advice or risk 9 rolling tape, and for you to keep typing to 9 losing my 6th Amendment right to effective 2 everything that they say out loud in this room. 2 representation. Accordingly, I assert my federal 2 3. MR. KUVIN: Not when everybody leaves. 2 1 constitutional rights as guaranteed by the 5th, 6th 22 We're good now. He wants to go off and I Want 22 and 14th Amendment to the US Constitution. 2 3 to go off now. 2 3 BY MR. KUVIN: 2 4 THE VIDEOGRAPHER: We'll go off the record at 2 4 Q. Isn't it true, sir, that you've had underaged 25 11:03. 25 girls under the age of 13 come to your home, get naked . it Page 69 Page 7 1 1 Does he, though? 3. and give you massages while you masturbated? 2 MR. KUVIN: i don't know. It?s a good 2 MR. Same objections. in addition, 3 question. 3 asked and answered. 4 MS. EZELLMR. KUVIN: No, I changed from 14 to 13. 5 MR. nevus: Oh, no. 5 MR. luKE: Same objections. 6 Hey, how are you? I keep forgetting you*re 6 BY MR. KUVIN: 7 there, Katherine. '7 Q. You can answer. 8 MS. EZELL: I'm there. Actually was on the 8 A. I fully intend to respond to all relevant 9 phone, so ljust missed whatjust happened. Are 9 questions regarding this lawsuit; however, at the i 0 you terminating or are you breaking or what? 1 0 present time, my attorneys have counseled me I cannot 1 1 MR. KUVIN: No, he wanted to step out of the 3. 1 provide answers to any questions relevant to this 1 2 room. It 2 lawsuit. I must accept this advice or risk losing my 13 MS. EZELL: Oh, okay. 1 3 6th Amendment right to effective representation. 1 4 MR. GOLDBERGER: Okay, thank you. 1 4 MR. GOLDBERGER: Thank you, Michael. 15 i had to discuss an issue with my client. I 15 THE WITNESS: Accordingly, i. assert my federal 1 6 appreciate the time. 1 6 constitutional rights as guaranteed by the 5th, 6th 17 MR. KUVIN: Anytime, Jack. 17 and 14th Amendment to the US Constitution. I 8 MR. GOLDBERGER: You know you don?t like me 1 8 Thank you. 1 9 anymore. 3. 9 av MR. KUVIN: 2 0 MR. KUVIN: The secret is I never liked you. 2 Q. Isn't it true, sir, that you?ve had underage - 2 1 THE WITNESS: That?s no secret. 2 1 girls under the age of 12 come to your home, get naked 2 2 MR. KUVIN: There you go. 2 2 and give you massages while you masturbated? 2 3 MR. PIKE: Move up the record for me so I can 2 3 MR. PIKE: Same obj actions. 24 see. 24 BY MR. KUVIN: 2 5 MR. Are we ready? 2 5 Q. I'm sorry, was there something funny about 14 (Pages 68 to 71) (561) 832*7500 PROBE COURT AGENCY, INC. (563.) 832~7506 Electronically signed by Jeane Ricciuti (601~280~428~9381) Electronically signed by Jeane Ricciuti {601~280~428~9381) Page 2 Page 4 3. that question? 1 losing my 6th Amendment right to effective 2 A. Are we 2 representation. Accordingly, I assert my federal 3 MR. PIKE: Same objectidn, argumentative. 3 constitutional rights as guaranteed by the 5th, 6th 4 MR. GOLDBERGER: Don?t even respond to that. 4 and l4th Amendment to the US Constitution. 5 "rue WITNESS: 1 fully intend to respond to an 5 BY MR. KUVIN: 6 relevant questions regarding this lawsuit; however, 6 Q. Your name is ieffrey Epstein, correct? 7 at the present time, my attorneys have counseled me 7 A. Correct. 8 i cannot provide answers to any questions relevant 8 Q. I just wanted to see if I could get an answer. 9 to this lawsuit. 1 must accept this advice or risk 9 MR. PIKE: l'm going to move to strike 1 losing my 6th Amendment right to effective 3. counsel's last statement; it's not a question. 1 1 representation. Accordingly, assert my federal 1 1 BY KUVIN: - 1 2 constitutional rights as guaranteed by the 5th, 6th 1 2 Q. Do you agree you maintain a home in New 1 3 and l4th Amendment to the US Constitution. 1 3 Mexico? ft 4 BY MR. KUVIN: 1 4 A. I fully intend to respond to all relevant 1 5 Q. Isn't it true that you've engaged in sexual 1 5 questions regarding this lawsuit; however, at the 3. 6 activities with girls under the age of 17, including 1 6 present time, my attorneys have counseled me I cannot 3. '7 touching their vaginas? 1 7 provide answers to any questions relevant to this 3. 8 MR. PIKE: Same objections. l. 8 lawsuit. 1 must accept this advice or risk losing my 1 9 THE WZTNESS: I fully intend to respond to all 1 9 6th Amendment right to effective representation. 2 0 relevant questions regarding this lawsuit; however, 2 0 Accordingly, I assert my federal constitutional rights 2 1 at the present time, my attorneys have counseled me 2 1 as guaranteed by the 5th, 6th and 14th Amendment to the 2 2 I cannot provide anSWers to any questions relevant 2 2 US Constitution. 23 to this laWSuit. i must accept this advice or risk 2 3 Q. isn't it true that you've engaged in sexual 24 losing my 6th Amendment right to effective 2 4 activities with girls under the age of 16, including 2 5 representation. Accordingly, I assert my federal 2 5 touching their vaginas?? Page 7 3 Page 7 5 1 constitutional rights as guaranteed by the 5th, 6th 1 MR. PIKE: Objection, harassing, 2 and 14th?Amendment to the US Constitution. 2 argumentative. 3 BY MR. KUVIN: 3 THE WITNESS: Didn?t you ask the same question 4 Q. isn?t it true that you've engaged in sexual 4 before? it 5 activities with girls under the age of 17, including 5 BY MR. KUVIN: 6 using vibrators on their vaginasbefore; now i went to 16. 7 MR. PIKE: Same objections. 7 MR. PIKE: Same objection. 8 THE WITNESS: I fully intend to respond to all 8 THE I fully intend to respond to all 9 relevant questions regarding this lawsuit; however, 9 relevant questions regarding this lawsuit; however, 1 at the present time, my attorneys have counseled me i. at the present time, my attorneys have counseled me 1 1 I cannot provide answers to any questions relevant 1 1 I cannot provide answers to any questions relevant 1 2 to this lawsuit. i must accept this advice or risk 1 2 to this lawsuit. I must accept this advice or rislc 13 losing my 6th Amendment right to effective 3. 3 losing my 6th Amendment right to effective 14 representation. Accordingly, I assert my federal 4 representation. Accordingly, assert my federal 15 constitutional rights as guaranteed by the 5th, 6th 1 5 constitutional rights as guaranteed by the 5th, 6th 1 6 and 14th Amendment to the US Constitution. 1 6 and 14th Amendment to the US Constitution. 17 BY MR. KUVIN: 17 av MR. KUVIN: 1 8 Q. Do you agree that you maintain a home in New 1 8 Q. Isn?t it true that you've engaged in sexual 1 9 York? 1 9 activities with girls under the age of to, including 2 0 MR. PIKE: Objection, form. 2 0 using vibrators on their vaginas? 2 1 THE WITNESS: I fully intend to respond to all 2 1 MR. PIKE: Same objection, asked and answered. 2 2 relevant questions regarding this lawsuit; however, 2 2 MR. KUVIN: Nope. The question before, and we 2 3 at the present time, my attorneys have counseled me 2 3 can read it back, was whether he touched their 2 4 I cannot provide answers to any questions relevant 2 4 vaginas, and this question is very speci?c asking 2 5 to this lawsuit. I must accept this advice or risk 2 5 whether he used vibrators on their vaginas. 15 (Pages 72 to 75) (561) 832?7500 PROBE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeane Ricciuti (60148042843381) Electronically signed by Jeane Ricciuti {601-2804288381} Page 76 Page 78 1 MR. PIKE: Same objection, asked and answered. 1 process, we will once again terminate this 2 BY MR. KUVIN: 2 deposition. I am giving you a fair opportunity to 3 Q. You can answer. 3 continue to use the discovery process in the manner 4 A. I fully intend to reSpond to all relevant 4 in which it is utilized; however, your 5 questions regarding this lawsuit; however, at the 5 grandstanding, laughing in the background, and 6 present time, my attorneys have counseled me I cannot 6 snide comments and remarks are not appropriate 7 provide answers to any questions relevant to this '7 during the discovery process; therefore, this is my 8 lawsuit. I must accept this advice or risk losing my 8 one warning to you, Mr. Kuvin. 9 6th Amendment right to effective representation. 9 MR. I disagree. 1 0 Accordingly, I. must assert my federal constitutional 1 0 MR. PIKE: I'm not asking you for an i 1 1 rights as guaranteed by the 5th, 6th and 14th Amendment 1 1 agreement. Please proceed. 1 2 to the US Constitution. 1 2 MR. KUVIN: I'm just making sure that the 1 3 Q. Have you requested girls under the age of 16 13 record is clear. 1 4 to spread their legs in front of you so that you could 1 4 And, by the way, you should fix the door, 15 see their vaginas? 15 Jack, because there's no spring on it, so when 1 6 MR. Same objection. 1 6 somebody touches it, it goes very fast. So I 3.7 THE WITNESS: I fully intend to respond to all 17 apologize if it did slam, and that's the only thing 1 8 relevant questions regarding this lawsuit; however, 3. 8 i do agree with. 1 9 at the present time, my attorneys have counseled me 3. 9 MR. GOLDBERGER: Okay. i appreciate the 2 0 i cannot provide answers to any questions relevant 2 apology. 2 1 to this lawsuit. I must accept this advice or risk 2 1 As long as we're going to yak here, Spencer, i 2 2 losing my 6th Amendment right to effective 2 2 you made a comment that i should learn the rules of 2 3 representation. Accordingly, I assert my federal 2 3 civil procedure and learn how to conduct 2 4 constitutional rights as guaranteed by the 5th, 6th 2 depositions and so forth. l've been practicing 26 and 14th Amendment to the US Constitution. 2 5 primarily criminal defense for 33 years, and do you Page 77 Page 79 1 BY MR. KUVIN: 1 know what, we don?t play these gamesyou agree that you maintain a home in the 2 issues, we ask questions, we don't laugh at 3 US Virgin Islands? 3 witnesses when they give answers in depositions. 4 A. As I've answered most of your questions today, 4 We're not sarcastic. We simply ask the questions 5 I'll answer this basically the same way, which is, I 5 and act professionally, and that?s all i'm asking 6 fully intend to respond to all relevant questions 6 you to do in this deposition, but apparently you?re 7 regarding this lawsuit; however, at the present time, my 7 incapable of doing that. 8 attorneys have counseled me I cannot provide answers to 8 So you're creating this environment here, 9 any questions relevant to this lawsuit. i must accept 9 you're creating this atmosphere. I'm trying to be 1 0 this advice or risk losing my 6th Amendment right to 1 polite to you, but it's becoming more and more 1 1 effective representation. Accordingly, I assert my 1 dif?cult. So I?m asking you to just kind of act 1 2 federal constitutional rights as guaranteed by the 5th, 1 2 professionally and we?ll get along, and we'll get 1 3 6th and 14th Amendment to the US Constitution. 1 3 through this, that's all. 1 4 Q. Do you want to give answers? 1 4 MR. I?ve been acting professionally. 1 5 MR. PIKE: Move to strike, argumentative, 15 Frankly, i wasn?t the one that told the other 6 harassing. 1 6 attorney to shut up. I mean, those were your Mr. Kuvin, I have no reticence with regard to 17 words, not mine. ijust wanted to make sure that I 1 8 getting in front of Judge Hafele once again, and 1 8 understood what you were saying to me. 1 9 let me delineate for you what your comments and 3. 9 MR. GOLDBERGER: it was a reaction to your 2 0 some of your conduct here today is and has been: 2 0' MR. KUVIN: Sir -- 2 1 Laughing, argumentative comments after your 2 1 MR. GOLDBERGER: It was a reaction to your 22 questioning, interrupting the witness, snide 22 MR. -- I would appreciate it if you 2 3 comments, as well as slamming doors in an of?ce 2 3 would let me finish. 2 4 that is not yours. 2 4 MR. GOLDBERGER: It was a reaction to your 2 5 Now, if you continue to disrupt the discovery 2 5 inappropriate comments and conduct. 16 (Pages 76 to 79 (561) 832-57500 PROBE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronically signed by Jeane Ricciuti (601-280-428-9381) Electronically signed by Jeane Ricciuti (601-280-428-9381) Page 80 Page 82 1 MR. KUVIN: See, the problem is you keep 1 we've both been warned. 2 interrupting me. 2 MR. PIKE: Mr. Kevin, you bring up a fabulous 3 MR. GOLDBERGER: You?re the one that's 3 point, a fabulous point, and I'm surprised 4 interrupting me, Spencer. 4 MR. KUVIN: It's amazing. I'm surprised that 5 MR. KUVIN: You want me to be courteous and 5 I brought it up. 6 let you speak, and then you continue to interrupt 6 MR. PIKE: The next time you choose to laugh 7 me when i want to respond to the nonsensical 7 at the witness, we'll call Judge Hafeie and see 8 arguments that you?re making, because i. have been 8 today what he has to say about that, okay? 9 perfectly courteous here. I?ve been asking 9 MR. KUVIN: Perfectly fine. 3 perfectly courteous questions, relevant questions 3. 0 MR. PIKE: It's a great idea. 3 3 to the case, pertinent questions to the issues in 1 MR. KUVIN: It sounds good to me. 32 this case. 3.2 MR. PIKE: So let's proceed. with some relevant i 3. 3 So if you have a problem with the questions, i 3 questions. ft 4 then make a legal objection. You and I both know 1 4 And I would try to give you a hint: Keep in 1 5 that a speaking, objection is an improper 5 mind the allegations in your complaint. 3. 6 one; that objection to form is the oniy objection 6 MR. KUVIN: Sounds good to me. 3.7 you should be making. And the only comment i made 17 MR. PIKE: Let's move forward. 3 8 about you practicing in civil was just merely the 8 BY MR. KUVIN: 3 9 fact that I didn?t know whether you understood that 9 Q. Isn?t it true, sir, that you?ve engaged in 2 objection to form covers everything. 2 0 sexual activities with girls under the age of 15, 2 1 MR. GOLDBERGER: 1 have an -- 21 including touching their vaginas? 22 MR. It certainty wasn't meant insult at all, and the sorry if you took it that 2 3 MR. PIKE: Argumentative, harassing, same 2 4 way. 2 ti objections. Sorry. 2 5 MR. GOLDBERGER: i appreciate it. i accept 2 5 THE WITNESS: fully intend to respond to all Page 8 1 Page 8 3 3. your apology. 1 relevant questions regarding this lawsuit; however, 2 I have I have a suggestion, because 2 at the present time, my attorneys have counseied me 3 apparently, for whatever reason, everyone's 3 I cannot provide answers to any questions relevant 4 grandstanding, wejust can't seem wait a minute, 4 to this lawsuit. 1 must accept this advice or risk 5 let mejust ?nish. Let me finish. 5 losing my 6th Amendment right to effective 6 MR. i?m not grandstanding. I want to 6 representation. Accordingly, I assert my federal 7 get through my questions. 7 constitutional rights as guaranteed by the 5th, 6th 8 MR. GOLDBERGER: We can't seem to get along. 8 and 14th Amendment to the US Constitution. 9 MR. KUVIN: i just want to get through the 9 BY MR. KUVIN: 0 questions. 3. Q. Isn't it true that you?ve engaged in sexual 1 1 MR. GOLDBERGER: Do you want to have the 3. 1 activities with girls under the age of 15, including 2 mediator sit in for this deposition? Is that what 12 using vibrators on their vaginas? 1 3 you want to do? 1 3 MR. PIKE: Same objection. 1 4 MR. KUVIN: No, i don?t think we need it. I'm 1 4 THE WITNESS: As I've answered your 1 8 working through my questions. 1 5 questions -- most of your questions today, i'll 3. 6 MR. GOLDBERGER: Okay, then. Go ahead. 1 6 answer it the same way now, which is, I foily 3 7 MR. PIKE: Let's proceed then. 1 7 intend to respond to all relevant questions 3. 8 MR. KUVIN: Okay, great. 1 8 regarding this lawsuit; however, at the present 3 9 MR. GOLDBERGER: You've been warned. 1 9 time, my attorneys have counseled me i cannot 2 KUVIN: I don?t know what the warning is 2 0 provide answers to any questions relevant to this i 2 3. supposed to mean. Nobody is ajudge in this room. 2 2 lawsuit. 1. must accept this advice or risk losing 2 2 I don?t think i need a warning. 2 2 my 6th Amendment right to effective representation. 2 3 MR. GOLDBERGER: That?s why i?m suggesting 2 3 Accordingly, I assert my federal constitutional 2 4 that 2 4 rights as guaranteed by the 5th, 6th and 14th 2 5 KUVIN: You?ve been warned as well, so now 2 5 Amendment to the US Constitution. 17 (Pages 80 to 83) (563.) 832*7500 PROSE COURT REPORTENG AGENCY, INC. (561) 8334506 Etectronicatly signed by Jeane Ricciuti (601-2804283381) Electronically signed by Joe na Ricciuti (601-280-428-9381) Page 84 Page 86 1 BY MR. KUVIN: 1 BY MR. KUVIN: 2 Q. Isn't it true that you?ve engaged in sexual 2 Q. What is the youngest girl that you've had sex 3 activities with girls under the age of i4 including 3 with? 4 touching their vaginas?? 4 MR. PIKE: Form. 5 MR. PIKE: Same objections. 5 TliE WITNESS: I'm going to answer that 6 THE WITNESS: As i?ve answered most of your . 6 question the same way I?ve answered most of your '7 other questions today, I fully intend to respond to I 7 other questions here today, which is, I fully 8 all relevant questions regarding this lawsuit; 8 intend to respond to all relevant questions 9 however, at the present time, my attorneys have 9 regarding this lawsuit; however, at the present 1. 0 counseled me I cannot provide answers to any 3. 0 time, my attorneys have counseled me i cannot 1 1 questions relevant to this lawsuit. 1 must accept 1 3. provide answers to any questions that may be l2 this advice or risk losing my 6th Amendment right 12 relevant to this lawsuit. I must accept this 13 to effective representation. Accordingly, I assert 13 advice or risk losing my 6th Amendment right to 4 my federal constitutional rights as guaranteed by 1 4 effective representation. Accordingly, i assert my 1 5 the 5th, 6th and 14th Amendment to the US 1 5 federal constitutional rights as guaranteed by the 1 a Constitution. 1 6 5th, 6th and 14th Amendment to the us Constitution. ?7 BY MR. KUVIN: 3. 7 BY MR. KUVIN: i 8 Q. Isn?t it true that you've engaged in sexual 1 8 Q. What is the youngest age of a girl that has 19 activities with girls under the age of l4, including 1 9 given you a naked massage? 2 8 using vibrators on their vaginas? 2 0 MR. PIKE: Form, argumentative, harassing and 2 1 MR. PIKE: Same objections. 2 1 as worded, irrelevant. 22 THE WITNESS: I?ll respond to this question in 2 2. THE WITNESS: i?m going to answer that 2 3 the same way I've responded to some of your other 2 3 question the same way I've answered most of your 2 4 questions, which is, I fully intend to respond to 2 4 other questions here today, which is, fully 2 5 all relevant questions regarding this lawsuit; 2 5 intend to respond to all relevant questions Page 85 Page 87 1 however, at the present time, my attorneys have 1 regarding this lawsuit; however, at the present 2 counseled me I cannot provide ansters to any 2 time, my attorneys have counseled me i cannot 3 questions relevant to this lawsuit. i must accept 3 provide answers to any questions that may be 4 this advice or risk losing my 6th Amendment right 4 relevant to this lawsuit. I must accept this to effective representation. Accordingly, I assert 5 advice or risk losing my 6th Amendment right to 6 my federal constitutional rights as guaranteed by 6 effective representation. Accordingly, I. assert my 7 the 5th, 6th and 14th Amendment to the US 7 federal constitutional rights as guaranteed by the 8 Constitution. 8 5th, 6th and 14th Amendment to the US Constitution. 9 BY MR. KUVIN: 9 BY MR. KUVIN: i. Q. Isn't it true that you've engaged in sexual 1 0 Q. What is the youngest age of a girl you have 1 1 activities with girls under the age of 14, which i. i. masturbated in front of? 12 includes using vibrators on their vaginas? 12 MR. PIKE: Same objections as before. 1 3 MR. PIKE: Same objections. 3 THE WITNESS: I'm going to answer that 1 4 THE WITNESS: I'll answer that question the 1 4 question in the same way I've answered most of your 1 5 same way i?ve answered most of your other questions 3. 5 other questions here today, Mr. Kuvin, which is, I 1 6 here today, Mr. Kuvin, which is, I fully intend to 1 6 intend to respond to all relevant questions 1 7 respond to all relevant questions regarding this 1 7 regarding this lawsuit; however, at the present 1 8 lawsuit; however, at the present time, my attorneys i. 8 time, my attorneys have counseled me i cannot i. 9 have counseled me I cannot provide answers to any 1 9 provide answers to any questions that may be 2 0 questions that may be relevant to this lawsuit. I 2 0 relevant to this lawsuit. 1 must accept this 2 1 must accept their advice or risk losing my 6th 2 1 advice or risk losing my 6th Amendment right to 2 2 Amend -- Amendment right to effective 2 2 effective representation. Accordingly, I assert my 2 3 representation. Accordingly, I assert my federal 2 3 federal constitutional rights as guaranteed by the 2 4 constitutional rights as guaranteed by the 5th, 6th 2 4 5th, 6th and Amendments to the US 2 5 and 14th Amendment to the US Constitution. 2 5 Constitution. 18 (Pages 84 to 87) (561) 832-7500 PROBE COURT REPORTING AGENCY, INC. (561) 832w7506 Electronically signed by Joana Ricciuti (601~280-428~9381) . Electronically signed by Jeane Ricciuti (601-280-428~9381) Page 8 8 Page 98 1 BY MR. KUVIN: 1 for girls under the age of 17? 2 Q. What is the youngest age of a girl that you 2 MR. PIKE: Same objections. 3 have ejaculated in front of? 3 THE WITNESS: I'm going to answer that I 4 MR. Same objections as before to this 4 question the same way I've answered most of your 5 same line of questioning incorporated. 5 other questions here today, Mr. Kuvin, which is, I 6 THE WITNESS: What was the question before 6 fully intend to respond to all relevant questions 7 that, sir? 7 regarding this lawsuit; however, at the present 8 BY MR. KUVIN: 8 time, my attorneys have counseled me I cannot I 9 Q. What is the youngest age the one before or 9 provide answers to any questions relevant to this 18 this one? I'm sorry. 10 lawsuit. i must accept their advice or risk losing 1 A. The one before, i thought it was the same 1 1 my 6th Amendment right to effective representation. 12 question. 3.2 BY MR. KUVIN: 3 Q. No, the one before was masturbated, and this 1 3 Q. Do you agree that you 1 4 one was ejaculated. i'll rephrase it. 14 A. Accordingly 1 5 What is the youngest age of a girl you have 1 5 Q. Oh, i apologize. 1 6 ejaculated in front of? 1 6 A. Accordingly, I assort my federal 17 MR. PIKE: Same objection, argumentative, 17 constitutional rights as guaranteed by the 5th, 6th and 1 8 harassing. 1 8 l4th Amendment to the US Constitution. 1 9 THE WITNESS: i?rn going to respond to that 9 Q. I?m sorry, are you done? 2 0 question the same way I?ve responded to most of 2 0 A. Yes. 2 1 your other questions here today, which is, I fully 2 1 Q. Okay. I apologize for interrupting you. 2 2 intend to respond to all relevant questions .2 2 Do you agree that you have a sexual preference 23 regarding this lawsuit; however, at the present 2 3 for girls under the age of 16? 2 4 time, my attorneys have counseled me i cannot 2 4 MR. PIKE: Same objections, form. 2 5 provide answers to any questions that may be 2 5 THE WITNESS: l'm going to answor that Page 89 Page 91 i 1 relevant to this lawsuit. 1 must accept their 1 question the same way I?ve answered most of your 2 advice or risk losing my 6th Amendment right to 2 other questions here today. I fully intend to 3 effective representation. Accordingly, i assert my 3 respond to all relevant questions regarding this 4 federal constitutional rights as guaranteed by the 4 lawsuit; however, at the present time, my attorneys 5 5th, 6th and 14th Amendment to the US Constitution. 5 have counseled me I cannot provide answers to any 6 BY MR. KUVIN: 6 questions that may be relevant to this lawsuit. 1 7 Q. Do you agree that you have a sexual preference '7 must accept their advice or risk losing my 6th 8 for underaged girls; in other words, girls under the age 8 Amendment right to effective representation. 9 of 18? 9 Accordingly, assert my federal constitutional 1 0 MR. PIKE: Same objections, in addition to 10 rights as guaranteed by the 5th, 6th and 14th 1 1 form. 1 1 Amendment of the US Constitution. 3.2 THE WITNESS: the going to answer that 12 BY MR. KUVIN: 1 3 question the same way l?ve answered most of your 1 3 Q. Do you agree that you have a sexual preference 1 4 other questions here today, Mr. Kuvin, which is, i 14 for girls under the age of l5? 1 5 fully intend to respond to all relevant questions 15 MR. PIKE: Same objections. 1 6 regarding this lawsuit; however, at the present 1 6 THE WITNESS: l'rn going to answer that 1 7 time, my attorneys have counseled me i cannot 1 7 question the same way I?ve answered most of your 1 8 provide answers to any questions that may be 1 8 other questions here today, Mr. Kuvin, which is, if 1 9 relevant to this lawsuit. 3 must accept their 1 9 fully intend to respond to all relevant questions 2 0 advice or risk losing my 6th Amendment right to 2 0 regarding this lawsuit; however, at the present 2 1 effective representation. Accordingly, I assert my 2 1 time, my attorneys have counseled me I cannot 2 2 federal constitutional rights as guaranteed by the 2 2 provide answers to any questions relevant to this 23 5th, 6th and 14th Amendment to the US Constitution. 2 3 lawsuit. i must accept their advice or risk losing 2 4 BY MR. KUVIN: 2 4 my 6th Amendment right to effective representation. 2 5 Q. Do you agree that you have a sexual preference 2 5 Accordingly, I assert my federal constitutional 19 (Pages 88 to 91) (561) 832*7500 PROSE COURT REPORTING AGENCY, ENC. (561) 832-4506 Electronically signed by Jenna Ricciuti Electronically signed by Joana Ricciutl (801-280-428-9381) - Page 92 Page 94 1 rights as guaranteed by the 5th, 6th and 14th 1 Constitution. 2 Amendment to the US Constitution. 2 BY MR. 3 BY MR. KUVIN: 3 Q. Do you agree that you've been treating with a 4 Q. Do you agree that you have a sexual preference 4 for your sexual perversions?? 5 for girls under the age of 14? 5 MR. PIKE: Objection, vague, harassing, also 6 MR. i?lKE: Same objections. 6 privilege; in addition, 7 "fl-IE i'm going to answer that 7 could call for their information resulting from 8 question the same way I've answered most of your 8 non~testifying consulting expert information. 9 other questions here today, Mr. Kuvin, which is, I 9 I?m going to instruct the witness not to 1 0 fully intend to respond to all relevant questions 1 0 answer. 1 1 regarding this lawsuit; however, at the present 1 1 BY MR. KUVIN: 12 time, my attorneys have counseled me I cannot 2 Q. Do you agree that you've been treating with a 1 3 provide answers to any questions relevant to this 1 3 for your sexual perversions? 1 4 lawsuit. 1 must accept their advice or risk losing 1 4 MR. PIKE: Same objection. 1 5 my 6th Amendment right to effective representation. 1 5 BY MR. 6 Accordingly, l. assert my federal constitutional 3. 6 Q. Do you agree that according to your State 17 rights as guaranteed by the 5th, 6th and 14th 1 7 Court sentence, you are mandated to obtain mental health 1 8 Amendment to the US Constitution. it 8 counseling or therapy? 19 BY MR. KUVIN: it 9 MR. PIKE: Same objection. 2 Q, Do you agree that you have a sexual preference 2 0 BY MR. KUVIN: 2 1 for girls under the age that therapy with? 2 2 MR. PIKE: Same objection. 2 2 MR. Let's take a break for one second. 2 3 THE WITNESS: I'm going to answer that 2 3 We don't have to leave. 2 4 question the same way I've answered most of your 2 4 I'm going to maintain the same objections and 2 5 other questions today, which is, fully intend to 2 5 instructions. Page 93 Page 95 1 respond to all relevant questions regarding this 3. BY MR. KUVIN: 2 lawsuit; however, at the present time, my attorneys 2 Q. How often are you going to that mental health 3 have counseled me 1 cannot provide answers to any 3 counselor? 4 Questions that may be relevant to this lawsuit. 1 4 MR. PIKE: Same objection and instruction. 5 must accept this advice or risk losing my 6th 5 BY MR. KUVIN: 6 Amendment right to effective representation. 6 Q. What do you discuss with the therapist? 7 Accordingly, assert my federal constitutional 7 MR- PIKE: De?nimly Same ObieCiion and 8 rights as guaranteed by the 5th, 6th and 14th 8 instruction. 9 Amendment to the US Constitution. 9 BY MR. KUVIN: 0 BY MR. KUVIN: 0 Q. Have you violated your probation by not going 1 1 Q. Do you agree that you have a sexual preference 1 to a mental health counselor or therapist? 12 for girls under the age of 12? 12 MR. PIKE: Same objection and instruction. 13 MR. Objection, harassing. in addition, 13 BY MR. KUVIN: 24 vague and indefinite, form. 14 Q. Do you agree that while in Palm Beach you've 15 THE WITNESS: I?m going to anSWer that 1. 5 prayed on girls who are generally troubled, under the 1 6 question the same way l?ve answered your other 1 6 age of 17 and economically disadvantaged because you can 17 questions here today, which is, I intend to respond control them better? 1 8 to all relevant questions regarding this lawsuit; 1 8 MR. PIKE: Objection, harassing, 1 9 however, at the present time, my attorneys have 1 9 argumentative, vague and indefinite. 2 counseled me I cannot provide answers to any 2 0 THE WITNESS: I'm going to answer that 2 1 questions relevant to this lawsuit. 1 must accept 2 1 question the same way l?ve answered most of your 2 2 this advice or risk losing my 6th Amendment right 22 other questions here today, which is, 1 fully 2 3 to effective representation. Accordingly, assert 2 3 intend '50 1939083 to 51? ?imam [1116580113 2 4 my federal constitutional rights as guaranteed by 2 4 regarding this lawsuit; however, at the present 2 5 the 5th, 6th and 14th Amendment to the US 2 5 time, my attorneys have counseled me I cannot 20 (Pages 92 to 95) (561) 832~7500 PROSE COURT REPORTING AGENCY, INC. (563.) 832*7506 Electronically signed by Jeane Ricctuti (601-280-428-9381) Electronically signed by Jeane Ricciuti (601-280-428-9381) a4t .35. Tm am sear; 33am BREW uwaeaswsawemw're sea.- was. . a; 33:93:19: 3843'. ?ilm?kti?d?iI-il?ff?iimzm?l am ??lam?i?ww the? *2 {55:23.3} 4 ?2 Manama; ?25.24 - management-tartar .ce: Page 96 Page 98 1 provide answers to any questions relevant to this 1 Union from 1969 to 1971, correct? 2 lawsuit. I must accept this advice or risk losing 2 A. Correct. 3 my 6th Amendment right to effective representation. 3 Q. Okay. You were raised in Coney Island? 4 Accordingly, i assert my federal constitutional 4 A. Correct. 5 rights as guaranteed by the 5th, 6th and 14th 5 Q. You attended Lafayette High School in 6 Amendment to the US Constitution. 6 Brooklyn, New York? 7 BY MR. KUVIN: 7 A. Is that a question? 8 Q. Do you agree that let me ask you this: Do 8 Q. Yes. Did you attend w- I'm sorry, did you 9 you see patterns in things? 9 attend Lafayette High School in Brooklyn, New York? 1 0 MR. PIKE: Form, compound, confusing, vague. 1 A. Yes. 1 1 THE WITNESS: i don't 1 Q. And you took classes at oh, I asked that, 3 1 2 BY MR. KUVIN: 12 I?m sorry. 1 3 Q. Do you understand the question? 1 3 You went to Courant Institute of Mathematical 1 4 A. No, I don't. 1 4 Sciences where you ieit without a degree, correct? 1 5 Q. Do you see patterns in numbers? 15 A. Correct. 1 6 MR. PIKE: Same objection, lack of predicate, 1 6 Q. From '73 to '75, you taught calculus and 1 7 foundation. 3.7 physics at The Dalton School? 1 8 What are you talking about? 1 8 A. I?m not sure those years are correct. 1 9 THE WITNESS: I don't understand the question. 1 9 Q. What years were you at Dalton? 2 0 BY MR. KUVIN: 2 0 A. I believe it was '74 to ?76. 2 1 Q. Do you recognize patterns in large numbers? 2 1 Q. Okay. 22 MR. PIKE: Same 22 A. I?m not certain. 2 3 MR. GOLDBERGER: You just asked the question 2 3 Q. Okay. Now, Dalton School is a high schooi, 2 4 the same way. just ask it a different way and 2 4 correct? 2 5 he?ll try and answer it for you. 2 5 A. Correct. Page 97 Page 99 1 MR. KUVIN: i did. I tried to clarify it. 1 Q. What were the ages of the children you were 2 MR. GOLDBERGER: You made it you said large 2 teaching at that high school? 3 numbers versus numbers. 3 A. Mostly 01d mostly l7 and 18. 4 THE idon?t understand the question. 4 Q. Okay. So you were teaching seniors? 5 BY MR. KUVIN: 5 A. Yes. 6 Q. Do you see patterns in any sequences of 6 Q. What were you teaching? 7 numbers? 7 A. You just asked that question, mathematics and 8 MR. PIKE: Same objection. 8 physics. 9 THE WITNESS: Do I see patterns? idon?t 9 Q. You're right, I apologize. 1 understand the question. 1 0 Were you teaching any girls that were under the time? 12 Q. Well, you developed a software to help make 12 A. i don't know. 1 3 money in the stock market, correct? 1 3 Q. Did you have any sexual contact with any of 1 4 MR. PIKE: Objection as to relevance. 1 4 the girls that you were teaching at Dalton? 1 5 THE WITNESS: No, that?s no, absolutely Ci. 5 A. Again? 1 6 not. 1 6 Q. Did you have any sexual contact with the girls 1 7 BY MR. KUVIN: 1 7 that you were teaching at Dalton? 1 8 Q. it wasn't a software, a computer software, 1 8 A. While i was a teacher? 19 that you helped to develop many years ago after leaving 19 Q. Well, let's start with that question, yes. 2 0 your teachingjob? 2 A. No. 2 1 MR. PIKE: Same objection. 2 1 Q. How about after? 2 2 THE WITNESS: i don?t know what you're talking 2 2 A. Not that I remember. 2 3 about. 2 3 Q. Did you date any girls that were previously 2 4 BY MR. KUVIN: 2 ?1 your student at Dalton? 2 5 Q. Let?s go back. You took classes at Cooper 2 5 A. I?m going to answer that question like every 21 (Pages 96 to 99) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Joana Ricciuti Electronically signed by Joana Ricciuti (Bot-28042841381) ?.3312 razor-eat 1-5 id what mimikt?i?i - haidtdi'? V). new maestarmaoarm - unmanned-raters} ?35 a?m 31?: 3: erreaeana Kid'th ht - mimit??sxi??kh?t ?st-Psi- Page 100 Page 102 1 other question I've answered today, which is, intend 1 I?ve tried, can you believe that? 2 to respond to all relevant questions regarding this 2 THE VIDEOGRAPHER: i do believe that. I do. 3 lawsuit; however, at the present time, my attorneys have 3 MR. KUVIN: Right. Oh, yeah, yeah, yeah. i 4 counseled me {cannot provide answers to any questions 4 remember you mentioned that before, right, yeah. 5 that may be relevant to this lawsuit. 1 must accept 5 THE WITNESS: Are we off the record? 6 this advice or risk losing my 6th Amendment right to 6 MR. KUVIN: Unfortunately, Mr. Pike wanted us 7 effective representation. Accordingly, I. assert my 7 on pennanently, so we?re on permanently. 8 federal constitutional rights as guaranteed by the 5th, 8 MR. PIKE: Actually, no. The I wanted to 9 6th and 14th Amendment to the US Constitution. 9 go off the record in order to, you know, conserve Q. You do not have a college degree, correct? 3. on Jeana's time, as well as the videographer, but 1 A. Correct. 1 1 Mr. Kuvin, you stated you wanted to be on the 2 Q. Regardless of that, you became a trader at i 2 record because you wanted to ensure that everything 1 3 Bear Steams at some point, correct? 1 3 was on the record that had to deal with this case. 1 4 MR. PIKE: Form. 1 4 So now we?re seeing people coming MR. KUVIN: 1 5 doors after they use the restroom, which I really different way if you?re 1 6 see as a complete waste of resources. 1 '7 confused. You look con?ised. 1 7 Nonetheless -- 1 8 A. Yes. 3. 8 MR. GOLDBERGER: Let?s all be friends here and '3 1 9 Q. You became a trader at Bear Stearns without a 9 let's just do this depo. 2 0 college degree; is that correct? 2 0 MR. KUVIN: Ijust wanted to stay record while u- 22 Q. You had -- .22 MR. GOLDBERGER: That?s ?ne. 2 3 A. I was never a trader. 23 MR. KUVIN: the attorneys were still in the 2 4 Q. I'm sorry. Whatjob did you hold at 24 room, that's all. 2 5 Bear Steams? 2 5 MR. GOLDBERGER: That?s fine. Page 101 Page 103 1 MR. I?d like to take a break and speak 3. MR. KUVIN: When the attorneys leave the room, 2 to my client. 2 I don't mind going off the record. That?s no 3 MR. Okay. 3 problem with me. 4 THE Your mic is still on, 4 MR. GOLDBERGER: Let's just get along and get 5 Mr. Pike. 5 this stuff done and move on. 6 MR. PIKE: Thank you. I appreciate that 6 MR. KUVIN: l'rn more than happy to do that. 7? reminder. 7 MR. GOLDBERGER: Are we cool with that? 8 MR. GOLDBERGER: Okay. 8 MR. KUVIN: Sure. 9 MR. PIKE: Go ahead. 9 MR. GOLDBERGER: Sure. 3. 0 MR. KUVIN: Yes. As far as I'm concerned, you 3. 0 THE VIDEOGRAPHER: Spencer, you have about five minutes. 1 2 THE VIDEOGRAPHER: Okay. We'll go off the 1 2 MR. KUVIN: Why don't you change tape so we 1 3 record at 1 1:3 3. 1 3 don?t have to stop. 1 4 MR. KUVIN: As far as she is concerned, she's 4 MR. GOLDBERGER: What time do you want to 5 got to keep going, 1 5 stop, because l*ve just got some stuff that I need 1 6 THE VIDEOGRAPHER: Well, l'rn going to start it 6 to do at some point today. Do you want to take a 1 "i the recording again because i i'm in an awkward 7? break or do you not -- 8 position. l?mjust going to keep it going. It 8 THE VIDEOGRARHER: Let me go off the record. 1 9 MR. That?s not a problem. 1 9 We'll go off the record at i :36. This will be the 2 0 THE VIDEOGRAPHER: Okay. 2 0 end of videotape No. 1. 2 3. MR. KUVIN: Can I make shadow animals in front 2 1 COURT REPORTER: Are we going off the paper 2 2 of you? 2 2 record, too? 2 3 THE VIDEOGRARHER: If you'd like. 2 3 MR. KUVIN: Sure. 2 4 MR. KUVIN: Jeana is the best court reporter i 2 4 MR. PIKE: Yeah. 2 5 have ever had in all of the hundreds of cases that 2 5 (A brief recess was taken.) 22 (Pages 100 to 103) (561) 832-7500 PROSE COURT REPORTERG AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciutl (601-280-428-9381) Electronically signed by Jeane Ricciuti (661 ~280-428-9381) 9age 104 Page 106 1 THE VIDEOGRAPHER: We?re back on the record at 1 as guaranteed by the 5th, 6th and 14th Amendment to the 2 i :39. This will be the beginning of tape No. 2. 2 US Constitution1982, you founded your own ?nancial 4 Q. Whatjob whatjob did you have at 4 management firm called I. Epstein Company; isn't that 5 Bear Stearns? 5 true? 6 A. fully intend to respond to all relevant 6 A. As i?ve answered most of your other questions i 7 questions regarding this lawsuit; however, at the 7 today, Mr. Kevin, I intend to fully respond to all i, 8 present time, my attorneys have counseled me I cannot 8 relevant questions regarding this lawsuit; however, at 9 provide answers to any questions that may be relevant to 9 the present time, my attorneys have counseled me I 1 0 this lawsuit. i must accept this advice or risk losing 1 0 cannot provide answers to any questions relevant to this 1 1 my 6th Amendment right to effective representation. 1 1 lawsuit. I must accept their advice or risk losing my 1 2 Accordingly, I assert my federal constitutional rights 1 2 6th Amendment right to effective representation. 1 3 as guaranteed by the 5th, 6th and 14th Amendment to the 1 3 Accordingly, I assert my federal constitutional rights 1 4 US Constitution. 1 4 as guaranteed by the 5th, 6th and 14th Amendment to the 1 5 MR. KUVIN: Obviously, I?m going to have to 1 5 us Constitution. 1 6 take this tip with Judge l-lafele, but I?m trying to 1 6 Q. The company that you founded called I. Epstein 1 7 understand, counsel, and, you know, l'm not going 1 7 Company later changed its name to Financial Trust Co, 1 8 to ask the witness obviously but how his job at 8 and its headquarters are in the private islands of the 1 9 Bear Steams is a potential 5th Amendment issue in 1 9 US Virgin Islands; isn't that true? 20 this case. 2 A. I fully intend to respond to all relevant 2 1 MR. PIKE: it?s asked and answered. 2 1 questions regarding this lawsuit; however, at the 2 2 MR. KUVIN: So there is no explanation? 2 2 present time, my attorneys have counseled me I cannot 2 3 MR. PIKE: You said you wanted to take it up 2 3 provide answers to any questions relevant to this 2 4 with the judge; you can take it up with the judge. 2 4 lawsuit. I must accept their advice or risk losing my 2 5 Number one, the relevancy of it is it's not 2 5 6th Amendment right to effective representation. Page 105 Page 107 1 applicable to your lawsuit, that I mean, that's 1 Accordingly, I assert my federal constitutional rights 2 the large part. 2 as guaranteed by the 5th, 6th and 14th Amendments to the 3 MR. KUVIN: Relevance we can argue about. 3 United States Constitution. 4 MR. Anyway, but again, I don't need to 4 Q. Do you socialize with Leonard Sustain 5 make your case for you. You can make your case to 5 (phonetic)? 6 iudge 'i-Iafele. The privilege has been asserted. 6 A. I?m going to answer that question the way I've 7 BY MR. KUVIN: 7 answered most of your other questions here today, 8 Q. Sir, isn?t it true that you do not have a 8 Mr. Kuvin, which is, i intend to respond to all relevant 9 college degree? 9 questions regarding this lawsuit; however, at the 1 A. Yes, that?s true. 1 0 present time, my attorneys have counseled me i cannot 1 1 Q. All right. Now, you have no post-secondary 1 1 provide answers to any questions relevant to this 1 2 degrees? 1 2 lawsuit. I must accept their advice or risk losing my 1 3 A. No, sir. 3 6th Amendment right to effective representationBear Stearns 1 4 Accordingly, I assert my federal constitutional rights 1 5 without a college degree or any post-secondary degrees? 1 5 as guaranteed by the 5th, 6th and l4th Amendment to the 1 6 A. You don't need a college degree to get ajob 1 6 US Constitution. 1.7 with Bear Stearns. 17 Q. Have you socialized with Richard Axle 8 Q. Who gave you thejob? 1 8 (phonetic)? 1 9 A. I fully intend to respond to all relevant 1 9 A. l'rn going to answer that question the same way 2 0 questions regarding this laWSuit; however, at the 2 0 I?ve answered most of your other questions here today, 2 1 present time, my attorneys have counseled me I cannot 2 1 which is, 1 fully intend to respond to all relevant 2 2 provide answers to any questions relevant to this 2 2 questions regarding this lawsuit; however, at the 2 3 lawsuit. I must accept their advice or risk losing my 2 3 present time, my attorneys have counseled me I cannot 2 4 6th Amendment right to effective representation. 2 4 provide answers to any questions relevant to this 2 5 Accordingly, I assert my federal constitutional rights 2 5 lawsuit. I must accept their advice or risk losing my 23 (Pages 104 to 107) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?37506 Electronically signed by Joana Ricciuti (6014804288381) Electronically signed by Jeane Ricciuti {601~280~428~9381) Page 108 Page 110 1 6th Amendment right to effective representation. 1 I fully intend to respond to all relevant questions 2 Accordingly, assert my federal constitutional rights 2 regarding this lawsuit; however, at the present time, my 3 as guaranteed by the 5th, 6th and 14th Amendment to the 3 attorneys have counseled me I cannot provide answers to 4 US Constitution. 4 any questions relevant to this lawsuit. 1 must accept 5 MR. 81KB: And in addition, the question lacks 5 this advice or risk losing my 6th Amendment right to 6 predicate and it?s vague and ambiguous. It's 6 effective representation. Accordingly, i assert my 7 overly broad. 7 federal constitutional rights as guaranteed by the 5th, 8 BY MR. KUVIN: 8 6th and 14th Amendment to the US Constitution. 9 Q. Do you know Gerald Edelman? 9 Q. Do you know a politician, George Mitchell? 1 0 A. l?m going to answer that question the same way 1 0 A. Fat going to answer that question the same way 1 1 i've answered most of your other questions here today, 3. 1 i?ve answered most of your other questions here today, 1 2 Mr. Kuvin, which is, i fully intend to respond to all 1 2 which is, I fully intend to respond to all relevant 1 3 relevant questions regarding this lawsuit; however, at 1 3 questions regarding this lawsuit; however, at the 3. 4 the present time, my attorneys have counseled me that i 1 4 present time, my attorneys have counseled me i cannot 1 5 cannot provide answers to any questions that may be 1 5 provide answers to any questions relevant to this 1 6 relevant to this lawsuit. i must accept this advice or 1 6 lawsuit. I. must accept their advice or risk losing my 1 7 risk losing my 6th Amendment right to effective 3. 7 6th Amendment right another yawn? 1 8 representation. Accordingly, I assert my federal 1 8 Q. I?m sorry, I can't help yawning. it seems to 1 9 constitutional rights as guaranteed by the 5thfunction of the day. 2 0 14th Amendment to the US Constitution. 2 0 MR. Move to strike. 2 1 Q. Do you know Murray Gelman? 2 1 BY MR. KUVIN: 22 A. l'rn going to answer that question the same way 22 Q. I apologize. I tried to keep my mouth shut 2 3 I've answered most of your other questions here today, 2 3 for that one, so but I can?t help it. I apologize. 2 4 which is, i fully intend to respond to all relevant 2 4 MR. Move to strike. 2 5 questions regarding this lawsuit; however, at the 2 5 THE WITNESS: Accordingly, i assert my federal Page 10 9 I . Page 1 1 1 1 present time, my attorneys have counseled me I cannot 1 cghtitutional rights as guaranteed by the 5th, 6th 2 provide answers to any questions that may be relevant to 2 and '1 4th Amendment to the US Constitution. 3 this lawsuit. 1 must accept this advice or risk losing 3 BY MR. KUVIN: 4 my 6th Amendment right to effective representation. 4 Q. Do you know President Bill Clinton? 5 Accordingly, I assert my federal constitutional rights 5 A. i?m going to reSpond to that question the same 6 as guaranteed by the 5th, 6th and 14th Amendment to the 6 way I've responded to most of your other questions here 7 US Constitution. 7 today, which is, i intend to respond to all relevant 8 Q. Do you know Ben Goertzel, spelled 8 questions regarding this lawsuit; however, at the 9 9 present time, my attorneys have counseled me that I 1 A. i?m going to answer that question the same way 1 0 cannot provide any answers to questions that may he 1 1 l've answered most of your other questions here today, 1 1 relevant to this lawsuit. I must accept this advice or 1 2 which is, I fully intend to respond to all relevant 3. 2 risk losing my 6th Amendment right to effective 1 3 questions regarding this lawsuit; however, at the 3 representation. Accordingly, I assert rny federal 1 4 present time, my attorneys have counseled me I. cannot 1 4 constitutional rights as guaranteed by the 5th, 6th and 1 6 provide answers to any questions relevant -- was that 1 5 14th Amendment to the US Constitution. 1 6 just a yawn? 1 6 Q. Do you know Actor Kevin Spacey? 17 Q. i?m sorry, yes, that wasjust a yawn. 17 A. I'm going to answer that question the same way 1 8 A. I must accept this advice or risk losing my 1 8 I?ve answered most of your other questions here today 1 9 6th Amendment right to effective representation. 3. 9 MR. PIKE: Excuse me for a minute, 2 0 Accordingly, I assert my federal constitutional rights 2 0 Mr. Epstein. 2 l. as guaranteed by the 5th, 6th and 14th Amendment to the 2 3. Obviously, your line of questioning is 2 2 US Constitution. 2 2 personal not does does Mr. Epstein -- does 2 3 Q. Do you know Marvin Minsky, 2 3 Mr. Epstein know who President Clinton is by virtue 24 A. i?m going to answer that question the same way 2 4 of him being the President of the United States. 2 5 I?ve answered most of your other questions here today. 2 5 You mean, does he personally know him, correct? 24 (Pages 108 to 111) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans Ricciuti (601 ?2801428-9381) Electronically signed by Jeana Riccluti (561) 832-57506 a sitar/Mid wantsmaesmamratet Page 112 Page 114 1 MR. KUVIN: Absolutely. Thank you for the 1 rue WHNESS: l?rn going to 2 clari?cation, and I?ll clarify. Next time [can 2 MR- Hang 011- 3 rephrase, do you know them personally. I don?t 3 THE WITNESS: EXCESS me. 4 want to have go back to every question. Do we have 4 MR. i?m sorry, what's the form 5 the understanding that my questions before -- 5 obiection? 6 MR, Yes, 6 MR. PIKE: it's a form objection and relevance '7 MR. KUVIN: dealt with whether or not 7 followed therea?er. 8 Mr. Epstein knew these gentleman, i was asking, 8 MR. i just wanted to correct the form 9 personally? 9 if there was something wrong with the form. Is 1 0 MR. PIKE: Yes. I want the record to be 1 0 there anything particular with the form i need to 1 3. clear. I don't want you to later say that how 1 1 correct? 12 could Mr. Epstein not know who i?resident Clinton is 12 MR. PIKE: Form, relevance: 3. 3 by virtue of him being the President of the United 1 3 BY MR. KUVIN: 14 States at some point in time, and vice versa with 14 Q. Do you own a Boeing 727'? 15 Kevin Spacey and whoevar else you -- so, yes, we 15 A. For going to answer that 1 6 have that agreement on a personal basis. 1 6 (Interruption in the proceedings.) 1'7 Okaya perfectly ?ne, 17 WOMAN: Carl, IS here for, 18 BY MR. KUVIN: 18 Mr. Kuvin. 19 Q. Do you know Actor Kevin Spacey personally? 1 9 MR. Who? 2 0 A. I'm going to answer that question the same way 2 0 UNIDENTIFIED WOMAN: He said he was expecting 2 1 I've answered most of your other questions here today, 2 1 him. 2 2 which is, i intend to respond to all relevant questions 22 MR. KUVIN: Please let him know we're going to 2 3 regarding this lawsuit; however, at the present time, I 2 3 be taking a break at 12100: and if he wail 2 4 cannot provide questions to any questions relevant to 2 4 Thank you. 2 5 this lawsuit. 1 must accept this advice or risk losing 25 BY MR. KUVIN: Page 113 Page 115 1 my 6th Amendment right to effective representation. 1 Q. I apologize for the interruption. 2 Accordingly, assert my federal constitutional rights 2 A. No problem. 3 as guaranteed by the 5th, 6th and 14th Amendment to the 3 i?rn going to answer that question the same way 4 US Constitution. 4 I?ve answered most of your other questions here today, 5 Another yawn? That's pretty good. Try to 5 which is, 1 fully intend to respond to all relevant 6 Q. That was just a breath, actually, a deep 6 questions regarding this lawsuit; however, at the 7 breath, that?s all. Thank you for paying attention. 7 present time, my attorneys have counseled me I cannot 8 Do you know Actor Chris Tucker personally? 8 provide answers to any questions relevant to this 9 A. For going to answer that question the same way 9 lawsuit. 1 must accept their advice or risk losing my 1 0 I've answered most of your other questions here today, 1 0 6th Amendment right to effective representation. 1 1 which is, i intend to respond to all relevant questions 1 1 Accordingly, I assert my federal constitutional rights 12 regarding this lawsuit; however, at the present time, my 1 2 as guaranteed by the 5th, 6th and 14th Amendment to the 1 3 attorneys have counseled me i cannot provide answers to 1 3 US Constitution. 1 4 any questions that may be relevant to this lawsuit. 1 4 Q. Have you ever referred to your Boeing 727 1 5 must accept their advice or risk losing my 6th Amendment 1 5 plane as "Air Fuck One"? 16 right to effective representation. Accordingly, 1 6 MR. PIKE: Form, argumentative, harassing. 17 assert my federal constitutional rights as guaranteed by l. 7" THE WITNESS: l?ll have to answer that the 1 8 the 5th, 6th and l4th Amendment to the US Constitution. 3. 8 same way i?ve answered most of your other questions Boeing 727? 9 here today, which is, I intend to respond to all 2 0 MR. PIKE: I?m sorry, Spencer, i didn't hear 2 0 relevant questions regarding this lawsuit; however, 2 1 you. Can you repeat the question? 2 at the present time, my attorneys have counseled me 2 2 MR. KUVIN: Sure. 2 2 I cannot provide answers to any questions that may 2 3 BY MR. KUVIN: 2 3 be relevant to this lawsuit. must accept their 24 Q. Do you own a Boeing 727? 2 4 advice or risk losing my 6th Amendment right to 2 5 MR. PIKE: Form objection, relevance. 2 5 effective representation. Accordingly, i assert my '25 (Pages 112 to 115) (563.) 832-7500 PROBE COURT REPORTING AGENCY, INC. (561) 832-57506 Electronically signed by Jenna Ricciuti (60148042843381) . Electronically signed by Joana Ricciuti (661?280428~9381} Page 116 Page 118 1 federal constitutional rights as guaranteed by the 1 which is, I fully intend to respond to all relevant 2 5th, 6th and 14th Amendment to the US Constitution. 2 questions regarding this lawsuit; however, at the 3 BY MR. KUVIN: 3 present time, my attorneys have counseled me i cannot 4 Q. Have you ever taken any underaged girls, girls 4 provide answers to any questions that may be relevant to 5 under the age of 18, on your Boeing 727? 5 this lawsuit. I must accept their advice or risl: losing 6 A. l'm going to answer that question the same way 6 my 6th Amendment right to effective representation. 7 I've answered most of your other questions here today, 7 Accordingly, I assert my federal constitutional rights 8 Mr. Kuvin, which is, l. intend to fully respond to all 8 as guaranteed by the 5th, 6th and 14th Amendment to the 9 relevant questions regarding this lawsuit; however, at 9 US Constitution. 1 0 this time, I cannot provide any answers to questions 1 Q. Isn't it true that you funded Mr. Nowak's 1 1 relevant to this lawsuit as my attorneys have counseled 1 1 research at the Institute For Advanced Study in 1 2 me. 1 must accept their advice or risk losing my 6th 1 2 Princeton? 1 3 Amendment right to effective representation. 1 3 A. I'm going to answer that question the same way 1 4 Accordingly, I assert my federal constitutional rights 1 4 l?ve answered most of your other questions here today, 1. 5 as guaranteed by the 5th, 6th and i4th Amendment to the 1 5 Mr. Kuvin, which is, I fully intend to respond to all 1 6 US Constitution. 1 6 relevant questions regarding this lawsuit; howeverconfidential informant for the 7 the present time, my attorneys have counseled me I f. 1 8 prosecution of Bear Stearns? 1 8 cannot provide answers to any questions relevant to this 1 9 MR. Form, relevance. 1 9 lawsuit. I must accept their advice or risk losing my g- 2 0 THE l?m going to answer that 2 0 6th Amendment right to effective representation. - 2 1 question the same way I've answered most of your 2 1 Accordingly, i assert my federal constitutional rights 22 questions here today, which is, I fully intend to 22 as guaranteed by the 5th, 6th and 14th Amendment of the 2 3 respond to all relevant questions regarding this 2 3 US Constitution. 2 4 lawsuit; however, at the present time, my attorneys 2 4 MR. PIKE: Can we go off the record for a 2 5 have counseled me i cannot provide answers to any 2 5 second? Page 117 Page 119 1 questions that may be relevant to the lawsuit. I 1 MR. Sure. 2 must accept their advice or risk losing my 6th 2 THE Off the record at 3 Amendment right to effective representation. 3 1:55 am. 4 Accordingly, I assert my federal constitutional 4 MR. GOLDBERGER: Here?s my issue. Actually, 5 rights as guaranteed by the 5th, 6th and 14th 5 we probably should be on the record on this one. 6 Amendment to the US Constitution. 6 MR. KUVZN: Are we going on? 7 BY MR. KUVIN: 7 MR. GOLDBERGER: Yeah, let?s go on. 8 Q. Did you trade infon?nation with the Federal 8 MR. KUVIN: Sure. 9 authorities in order to get a lighter sentence with 9 THE VIDEOGRAFHER: Back on the record at 1 0 respect to the charges brought against you in Palm Beach 1 1 1:55. 1 1 County by the US Attorney's Office? 1 1 MR. GOLDBERGER: We were just off the record 1 2 A. I'm going to answer that question the same way 1 2 and talked about taking a break, and I hate to 3 I?ve answered most of your other questions here today, 1 3 inject personal problems into a scheduling, but I 1 4 which is, 1 fully intend to respond to all relevant 1 4 am suffering from some actually some nerve 1 5 questions regarding this lawsuit; however, at the 1 5 neurological problem. I'm on a fairly heavy 16 present time, my attorneys have counseled me i cannot l. 6 steroid right now and it?s causing me some issues. 1 7 provide answers to any questions relevant to this 17 I didn't want to try and reset this deposition 1 8 lawsuit. 1 must accept their advice or risk losing my 1 8 because I know, Mr. Kuvin, you wanted to take the 1 9 6th Amendment right to effective representation. 1 9 deposition, but given the medications i'm on, l?d 2 0 Accordingly, I assert my federal constitutional rights 2 0 just assume keep going unless that's a huge problem 2 1 as guaranteed by the 5th, 6th and 14th Amendment to the 2 1 for you. 22 US Constitution. 2 2 MR. KUVIN: Not a problem for me at all. Do 2 3 Q. Do you know, personally, Martin Nowak? 2 3 you want to go straight through lunch? 24 A. I'm going to answer that question the same way 2 Al MR. GOLDBERGBR: i think so. I mean, if 2 5 I?ve answered most of your other'questions here today, 2 5 you've ever taken steroids before, they can -- they 26 (Pages 116 to 119) (561) 832~7508 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Joana Ricciuti (601-2884283381) Electronically signed by Joana Ricciuti (601 480-428-9381) a4?l Electronically signed by Jeane Ricciuti (601~280-428-9381) Electronically signed by Joana Ricciuti (601*280-428-9381) a41 Page 120 Page 122 1 can mess with you pretty good, so l'd prefer to 1 attorneys have counseled me i cannot provide answers to 2 keep going. 2 any questions relevant to this lawsuit. I must accept I 3 MR. KUVIN: Fine with me. 3 this advice or risk losing my 6th Amendment right to 4 MR. PIKE: May we go off the record? 4 effective representation. Accordingly, I assert my 5 MR. Sure. 5 federal constitutional rights as guaranteed by the 5th, 6 THE We?ll go off the record at 6 6th and 14th Amendment to the US Constitution. 7 1 2:56. 7 Q. And isn't it true also that you have retained 8 (A brief recess was taken.) 8 Alan Dershowitz to defend you in the criminal charges 9 THE We?re back on the record at 9 that were brought against you in Palm Beach? 1 12:12. 1 0 MR. GOLDBERGER: Attorney~client. 1 1 BY MR. KUVIN: 1 1 MR. PIKE: Attorney-client, work product. 1 2 Q. Sir, isn?t it true that you pledged 1 2 BY MR. 1 3 $30 million to Harvard University in 2003? 1 3 Q. Isn?t it also true that Alan Dershowitz works 1 4 A. l?m going to answer that question the same way 1 4 on staff at Harvard University as a professor? I mean, 1 5 I?ve answered most of your other questions here today, 1 5 if you know. 1 6 which is, I intend to respond to all relevant questions 1 6 A. I'm going to answer that question like i?ve 1 7 regarding this lawsuit; however, at the present time, my 1 7 answered most of your other questions here today, which 1 8 attorneys haVe counseled me I cannot provide answers to 1 8 is, I fully intend to reSpond to all relevant questions 1 9 any questions relevant to this lawsuit. 1 must accept 1 9 regarding this lawsuit; however, at the present time, my 2 0 their advice or risk losing my 6th Amendment right to 2 0 attorneys have counseled me I cannot provide answers to i; 2 1 effective representation. Accordingly, assert my 2 1 any questions that may be relevant to this lawsuit. I . 2 2 federal constitutional rights as guaranteed by the 5th, 2 2 must accept this advice or risk losing my 6th Amendment 3. 2 3 6th and 14th Amendment to the US Constitution. 2 3 right to effective representation. Accordingly, i 2 4 Q. isn?t it true that that $30 million pledge to 2 4 assert my federal constitutional rights as guaranteed by 2 5 Harvard was shortly before you were arrested with 2 5 the 5th, 6th and 14th Amendment to the US Constitution. Page 121 Page 123 1 respect to the charges brOught against you in Palm Beach 1 Q. Isn?t it true that you own a 50,000 square 2 for having sex with underaged girls and soliciting 2 foot home in Manhattan that was formerly owned by Lex 3 underaged girls for prostitution? 3 Wexner? 4 (Interruption in the proceedings.) 4 A. I?m going to answer that question as i've 5 W. GOLDBERGER: Thank you. 5 answered most of your other questions here today, 6 Hey Kathy, it's Jack Goldberger. You're back 6 Mr. Kuvin, which is, I fully intend to respond to all 7 on. 7 relevant questions regarding this lawsuit; however, at 8 MS. EZELL: Okay, good. Thanks, lack. 8 the present time, my attorneys have counseled me I 9 MR. GOLDBERGER: Okay. 9 cannot provide answers to any questions that may be 1 0 MS. EZELL: i?ni putting the mute on. 1 0 relevant to this lawsuit. 1 must accept this advice or 1 1 MR. GOLDBERGER: Okay. 1 1 risk losing my 6th Amendment right to effective 1 2 THE WITNESS: Can you read me the question? 1 2 representation. Accordingly, I assert rny federal 1 3 MR. KUVIN: Sure. Could you read it back, 1 3 constitutional rights as guaranteed by the 5th, 6th and 14 please? 1 4 14th Amendment to the US Constitution. 1 (A portion of the record was read by the 1 5 Q. Isn?t it true that one of your only clients is 1 6 reporter.) 1 6 a ?nancial advisor with Lox Wexner? 17 THE WITNESS: No. 17 A. i?m going to respond to that question the same 1 8 BY MR. 1 8 way l?ve responded to most of your other questions here 1 9 Q. isn?t it true that you pledged $30 million to 1 9 today, which is, I fully intend to respond to all 2 iiarvard University in 2003, which is shortly before 2 0 relevant questions regarding this lawsuit; however, at 2 1 charges were brought against you in Palm Beach? 2 the present time, my attorneys have counseled me I 2 2 A. I'll answer that question the same way I've 2 2 cannot provide answers to any questions relevant to this 2 3 answered most of your other questions here today, which 2 3 lawsuit. I must accept their advice or risk losing my 2 4 is, I fully intend to respond to all relevant questions 2 4 6th Amendment right to effective representation. 2 5 regarding this lawsuit; however, at the present time, my 2 5 Accordingly, I assert my federal constitutional rights :?ir?vmikil?i? in: 27 (Pages 120 to (561) 832e7500 PROBE COURT REPORTING AGENCY, ENC. (56-1) 832*?506 Page 12d Page 126 1 as guaranteed by the 5th, 6th and 14th Amendment to the 1 Q. Did Mr. Wexner replace you with Dennis Hersch? 2 US Constitution. 2 A. l?rn going to answer that question like We 3 Q. lsnit it true that Lox Wexner has since ?red 3 answered most of your other questions here today, which 4 you after charges were brought against you in Palm Beach 4 is, fully intend to respond to all relevant questions 5 County for soliciting underaged girls for sex? 5 regarding this lawsuit; however, at the present time, my 6 A. l?in going to reSpond to that question the same 6 attorneys have counseled me i cannot provide answers to '7 way l've responded to most of your other questions here 7 any questions relevant to this lawsuit. must accept 8 today, which is, intend to respond to all relevant 8 their advice or risk losing my 6th Amendment right to 9 questions regarding this lawsuit; however, at the 9 effective representation. Accordingly, i assert my 1 0 present time, my attorneys have counseled me i cannot 1 0 federal constitutional rights as guaranteed by the 5th, 1 1 provide answers to any questions relevant to this 1 1 6th and 14th Amendment to the US Constitution. 1 2 lawsuit. 1 must accept their advice or risk losing my 1 2 Q. Would you agree that Mr. Wexner was your only 1 3 6th Amendment right to effective representation. 1 3 client when you were a ?nancial adviser? 4 Accordingly, I assert my federal constitutional rights 1 4 A. l'm going to answer that question like We 1 5 as guaranteed by the 5th, 6th and 14th Amendment to the 1 5 answered most of your other questions here today, 1 6 United States Constitution. 1 6 Spencer -- Mr. Kuvin 1 7 Q. Are you a homosexual? 7 Q. Thank youwhich is, I fully intend to respond to all 1 9 Q. Have you had homosexual relationships with 1 9 relevant questions regarding this lawsuit; however, at 2 0 Mr. Wexner?? 2 0 the present time, my attorneys have counseled me I 2 1 A. I'm going to answer that question the way l?ve 2 1 cannot provide answers to any questions relative to this 2 2 answered all your other questions here today, basically, 2 2 lawsuit. I must accept their advice or risk losing my 2 3 which is, intend to respond to all relevant questions 2 3 6th Amendment right to effective representation. 2 4 regarding this lawsuit; however, at the present time, my 2 4 Accordingly, i assert my federal constitutional rights 2 5 attorneys have counseled me i cannot provide answers to 2 5 as guaranteed by the 5th, 6th and 14th Amendment to the Page 125 Page 127 1 any questions relevant to this lawsuit. I must accept 1 US Constitution. 2 this advice or risk losing my 6th Amendment right to 2 MR. KUVIN: All right. With the understanding 3 effective representation. Accordingly, i assert my 3 that -- see, now he's yawning. You don't pick on 4 federal constitutional rights as guaranteed by the 5th, 4 him when he yawns. 5 6th and 14a Amendment to the US Constitution. 5 With the m- 6 Q. Have you ever touched Mr. Wexner's penis? 6 MR. PIKE: Move to strike. 7' MR. PIKE: Objection, harassing, irrelevant, '7 MR. KUVIN: With the understanding that I . 8 argumentative. 8 understand you all object and you?ve moved to 9 MR. GOLDBERGER: Object. 9 disclose the identity of 13.13., who's been 10 THE WITNESS: No. 1 0 identi?ed in this case, obviously the same 1 1 BY MR. KUVIN: 1 1 proceedings would go with respect to this 1 2 Q. Have you ever had anal sex with Mr. Wexner? 1 2 deposition that have gone with every other 1 3 A. No. 13 deposition regarding the identity of the unknown 1 4 Q. Have you ever threatened Mr. Wexner that you 14 8.8. So i?m going to ask questions, obviously, 1 5 would disclose private information about him if he 1 5 utilizing full names and using the same procedure 16 testi?ed against you in the civil proceedings which 1 6 we've used in all other depositions in this case. 17 have been brought against you here in Palm Beach County? 1 7 MR. PIKE: i don't think that there?s been an 18 MR. GOLDBERGER: Can you l?m sorry, can you 18 agreement in that regard. i think that there?s 1 9 repeat the question? 1 9 been a motion to seal that had been subsequently 20 MR. KUVIN: Sure. Go ahead and repeat it 2 8 ?led by, i believe it was, Brad Edwards' of?ce 2 1 back, please. 2 1 after a particular depo occurred. So if you want i 2 2 (A portion of the record was read by the 2 2 to address it by by that, then that would be 2 3 reporter.) 2 3 ?ne. i 2 4 THE WITNESS: No. 2 If there was an order entered that that 25 BY MR. KUVIN: 2 5 deposition shall not be disclosed to the media 28 (Pages 124 to 127) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronically signed by Jeane Ricciutl (601 a280~428~9381) Electronically signed by Jeane Ricciuti (601 ~280~428~9381) Page 128 Page 130 3 ii 1 earlier this morning, in that regard, l?m not quite which is, fully intend to respond to all relevant 2 sure what what you?re asking, Mr. Kuvin. 2 questions regarding this lawsuit; however, at the i 3 . MR, Kuva; well, [just want to make sure 3 present time, my attorneys have counseled me i cannot 4 that when Jeana types up the transcript, that it's ti provide answers to any questions that may be relevant to 5 done the same exact way that they've all been done, 5 this lawsuit. I must accept this advice or risk losing 6 which is, that the girls would be utilized by 6 my 6th Amendment right to effective representation. 7 initial that will have the same -- 7 Accordingly, I assert my federal constitutional rights 8 MR. PIKE: Pseudonym. 8 as guaranteed by the 5th, 6th and 14th Amendment to the 9 MR. KUVIN: pseudonym -- that will have the 9 US Constitution. 0 same attachment to the deposition as we always 1 0 Q. I?m going to Show you what I've marked as if 3. have, which is confidential. 1 1 Exhibit 7, and I've blacked out the name -- or the face 12 MR. PIKE: That's ?ne. 12 of a girl that is shown in this photograph before i mark 1 3 MR. KUVIN: If you chose to obviously I 3 it to the deposition. I'm going to draw an arrow with a 14 challenge the con?dentiality and want to disclose 1 4 star to the girl that I'd like you to identify. 1 5 my client's name for some reason, then we'll 1 5 MR. PIKE: First, I'm going to object to the 1 6 address that with the Court at some later time. 1 6 use of this exhibit. it's it's not an original 17 MR. PIKE: That's fine. 1 7 any longer, and it was not provided to me prior to 1 8 MR. KUVIN: Okay. Good enough. All right. 1 8 your marking out the face of the other individual 3. 9 MR. PIKE: Pending the Court's ruling on that. 1 9 in this photograph; therefore, I don?t -- I object 2 0 MR. Obviously pending the Court's 20 to it and would like to know the basis for which 2 1 ruling, 2 1 you?ve marked out this individual's face. 22 All right. You got your camera? Good to go? 22 MR. KUVIN: To protect her privacy. 2 3 BY MR. KUVIN: 2 3 MR. PIKE: Third party privacy right? 2 4 Q. I'm going to show you what we'll mark as 2 4 MR. KUVIN: She has a right to privacy. I 2 5 Exhibit 5. 2 5 certainly don't want to breach any potential right Page 129 page 133. 1 (Plaintiffs Exhibit No. 5 was marked for to privacy she may have because I haven't asked her 2 identi?cation.) 2 whether or not it's okay to show her photograph, 3 MR. KUVIN: Okay? 3 which is why i blacked her out. 4 BY MR. KUVIN: 4 MR. PIKE: Okay. But having said that, 5 Q. Do you recognize this young girl? 5 that that theory and objection is duly noted. 6 A. for going to answer that question the same way 6 I'll go ahead and allow the witness to be 7 I've answered most of your other questions, which is, I '7 questioned on Exhibit 7. 8 intend to respond to all relevant questions regarding 8 (Plaintiff's Exhibit No. 7 was marked for 9 this lawsuit; however, at the present time, my attorneys 9 identi?cation.) 1 0 have questioned excuse me, my attorneys have 1 0 BY MR. KUVIN: 1 1 counseled me I cannot provide answers to any questions 1 1 Q. I'd like you to take a look 12 relevant to this lawsuit. I must accept this advice or 12 MR. KUVIN: I'm sorry, let me show this to the 3 risk losing my 6th Amendment right to effective 1 3 camera, ?rst. 1 4 representation. Accordingly, I assert my federal 1 4 THE VIDEOGRAPHER: Okay. 15 constitutional rights as guaranteed by the 5th, 6th and 15 BY MR. KUVIN: 3. 6 14th Amendment to the United States Constitution. 1 6 Q. Okay. Do you recognize the girl on the left 17 Q. I'll Show you what we're marking as Exhibit 6. 17 in Photograph Exhibit 1 8 Okay? 1 8 A. I'm going to respond to that question the same i. 9 (Plaintiff?s Exhibit No. 6 was marked for 1 9 way I've responded to most of your other questions here - 2 identi?cation.) 2 0 today, Mr. Kuvin, which is, I intend to respond to all 2 1 BY MR. KUVIN: 2 1 relevant questions regarding this lawsuit; however, at 22 Q. Do you recognize this young girl that l?ve 22 the present time, my attorneys have counseled me I 3 marked as Exhibit 6? 2 3 cannot provide answers to any questions relevant to this 2 Al A. i?m going to respond to that the same way I've 2 4 lawsuit. 1 must accept this advice or risk losing my 2 5 responded to most of your other questions here today, 2 5 6th Amendment right to effective representation. 29 (Pages 128 to 131) (561) 832N7500 PROSE COURT REPORTING AGENCY, INC. (563.) 832?7506 Electronically Sig had by Jeane Ricciuti (601-2804283381) Electronically signed by Jenna Ricciuti (601-280-428-9381) a4?l (561) ?Java . ?at. .. 5 832-3500 Electronically signed by Joana Ricciuti (601-2864288381) Electronically signed by Joana Ricciuti (601-2804288381) PROSE COURT REPORTING AGENCY, Page 132 Page 134 1 Q. Excuse me. 3. this massage, you were masturbating? 2 A. Accordingiy, I assert my federal 2 A. "She" being 13.3.? I?m sorry. She what was 3 constitutional rights as guaranteed by the 5th, 6th and 3 the question? 4 14th Amendment to the US Constitution. 4 Q. Yes, all these questions refer to the same 5 (Photograph shown to the camera.) 5 child, 13.13. You can make that assumption for all my 6 (Plaintiff?s Exhibit No. 8 was marked for 6 questions. 7 identi?cation.) '7 A. Okay. 8 BY MR. KUVIN: 8 MR. PIKE: Objection to form, argumentative, 9 Q. Okay. Do you recognize the girl shown in 9 move to strike. 1 0 Exhibit It 0 BY MR. KUVIN: 1 1 A. I'm going to answer that question the same way 1 1 Q. Do you agree that while she was giving you 1 2 I?ve answered most of the other questions here today, 1 2 this massage, you were masturbating? 1 3 which is, 1 fully intend to respond to all relevant 3 MR. PEKE: Form, argumentative, harassing. 4 questions regarding this lawsuit; however, at the 1 4 THE WITNESS: l'm going to respond to that 1 5 present time, my attorneys have counseled me I cannot 1 5 question the same way i?ve responded to most of 1 6 provide answers to any questions relevant to this 1 6 your other questions here today, which is, I intend 1 "l lawsuit. I must accept this advice or risk losing my 1 ?7 to respond to all relevant questions regarding this 1 8 6th Amendment right to effective representation. 1 8 lawsuit; however, at the present time, my attorneys 1 9 Accordingly, I assert my federal constitutional rights 1 9 have counseled me I cannot provide answers to any 2 0 as guaranteed by the 5th, 6th and 14th Amendment of the 2 0 questions relevant to this lawsuit. I must accept 2 1 United States Constitution. 2 1 their advice or risk losing my 6th Amendment right .2 2 Can we take a break for a second? 2 2 to effective representation. Accordingly, i assert 2 3 Q. Sure. 2 3 any federal constitutional rights as guaranteed by 24 MR. PIKE: Sure. 24 the 5th, 6th and 14th Amendment to the US 2 5 THE VIDEOGRAPHER: Going off the record at 2 5 Constitution. Page 133 Page 135 1 12:27. 1 BY MR. KUVIN: 2 (A brief recess was taken.) 2 Q. Do you agree that while she was giving you 3 THE VIDEOGRAPHER: Back on the record at 3 this naked massage, she told you she was 16? 4 12:29. 4 MR. PIKE: Form, argumentative, harassing, 5 BY MR. KUVIN: 5 assumes facts not in evidence. 6 Q. Sir, do you agree that in 2005, you had BB. 6 THE WITNESS: I?m going to have to respond to '3 come to your house, get naked and give you a massage '7 that question the same way I've responded to most 8 while you had nothing on but a washcloth over your 8 of your other questions here today, which is, i 9 genitals? 9 intend to reSpond to all relevant questions 1 0 MR. PIKE: Objection form, argumentative. 1 0 regarding this lawsuit; however, at the present 1 1 THE WITNESS: Is that is that who you. 1 1 time, my attorneys have counseled me I cannot 12 said? Can you spell that for me? 12 provide answers to any questions that may he 1 3 BY MR. KUVIN: 1 3 relevant to this lawsuit. 1 must accept their 1 4 Q. It's in the record. 1 4 advice or risk losing my 6th Amendment right to 1 5 A. I'm going to answer that question the same way 1 5 effective representation. Accordingly, I assert my 1 6 I?ve answered most of your other questions here today, 1 6 federal constitutional rights as guaranteed by the 1 7 which is, I intend to respond to all relevant questions 5th, 6th and 14th Amendment to the US Constitution. 18 regarding this lawsuit; however, at the present time, my 1 8 BY MR. KUVZN: 1 9 attorneys have counseled me i cannot provide answers to 1 9 Q. Do you agree that while she was giving you 2 0 any questions relevant to this lawsuit. I must accept 20 this naked massage, she told you that she was 15? 2 1 this advice or risk losing my 6th Amendment right to 2 1 MR. PIKE: Same objections as before. 2 2 effective representation. Accordingly, I assert my 2 2 THE WITNESS: I'm going to answer that 2 3 federal constitutional rights as guaranteed by the 5th, 2 3 question the same way I've answered most of your 2 4 6th and 14th Amendment to the US Constitution. 2 4 other questions here today, which is, I intend to 2 5 Q. Do you agree that while she was giving you 2 5 respond to all relevant questions regarding this 30 INC. (Pages 132 to 135) (561) 832?7506 a4?t ??359: KM ?eld/tri?e?? stare: ?ts? newsman mamasszacwm'e?? 5 restatement-R ?exam . . 'l?i?i arrangement rem 3.53 ii'?'iniz ieww Matti .ii-W?i?a?s?zs W3?W$i?i??d? tats-u: newest an; hw??mai?a? raw 5:5 Su?-52 tat-3553i alarawszrarmamrtme erratum ?llies; Page 136 Page 138 3. lawsuit; however, at the present time, my attorneys 1 you a naked massage while you were naked, that you also 2 have counseled me i cannot provide answers to any 2 touched her vagina? 3 quastions that may be relevant to this lawsuit. I 3 MR. Same objections as before. 4 must accept this advice or risk losing my 6th 4 THE WITNESS: l?m going to respond to that 5 Amendment right to effective representation. 5 question the same way I've responded to most of. 6 Accordingly, assert my federal constitutional 6 your other questions here today, Mr. Kuvin, which 7 rights as guaranteed by the 5th, 6th and i4th 7 is, I fully intend to respond to all relevant 8 Amendment to the US Constitution. 8 questions regarding this lawsuit; however, at the 9 MR. PIKE: Mr. Kuvin, i?ve been incorporating 9 present time, my attorneys have counseled me i 1 0 and asserting the same objections, by saying same 1 0 cannot provide answers to any questions that may be 1 3. objection as before, are you okay with that? 1 relevant to this lawsuit. 1 must accept this 1 2 MR. KUVIN: Perfectly fine. 1 2 advice or risk losing my 6th Amendment right to 13 MR. PIKE: Okay. 1 3 effective representation. Accordingly, I must 1 4 BY MR. KUVIN: 1 4 assert my federal constitutional rights as 1 5 Q. Do you agree that while 13.33. was in your home, 1 5 guaranteed by the 5th, 6th and mm Amendment to 1 6 you asked her to get completely naked? 1 6 the United States Constitution. 17 MR. Same objection. 17 BY MR. KUVIN: 18 THE i?m going to respond to that 1 8 Q. Do you agree that during this naked massage 1 9 question the way I've responded to most of your 1 9 with B.B., that you asked her whether she wanted you to 2 0 other questions here today, which is, I. intend to . 2 0 stop touching her vagina, and she said yes. 2 It reSpond to all relevant questions regarding this 2 1 MR. PIKE: Same objections. 2 2 lawsuit; however, at the present time, my attorneys 2 2 THE WITNESS: i?m going to respond to that 2 3 have counseled me i cannot provide answers to any 2 3 question the same way I've responded to most of 2 4 questions relevant to this lawsuit. i must accept 2 4 your other questions here today, Mr. Kevin, which 2 5 their advice or risk losing my 6th Amendment right 25 is, I intend to respond to all relevant questions Page 137 Page 139 1 to effective representation. Accordingly, I assert 1 regarding this lawsuit; however, at the present 2 my federal constitutional rights as guaranteed by 2 time my attorneys have counseled me i cannot 3 the 5th, 6th and 14th Amendment to the United 3 provide answers to any questions relevant to this 4 States Constitution. 4 lawsuit. I must accept their advice or risk losing 5 BY MR. KUVIN: 5 my 6th Amendment right to effective representation. 6 Q. Do you agree that alter B.B. got naked in your 6 Accordingly, I assert my federal constitutional 7 home, that you asked her to massage you while you were 7 rights as guaranteed by the 5th, 6th and 14th 8 naked? 8 Amendment of the United States Constitution. 9 MR. PIKE: Form, lacks predicate, 9 BY MR. KUVIN: 1 argumentative, harassing, assumes facts not in 10 Q. Do you agree that regardless of 13.8. telling 1 evidence. 1 1 you to stop touching her vagina, you nonetheless 12 THE WITNESS: I'm going to respond to that 1.2 disregarded her and touched her there again? 1 3 question the same way I've responded to most of 13 MR. PIKE: Same objections as before. 1 4 your other questions here today, Mr. Kuvin, which 14 WITNESS: I'm going to respond that 5 is, I intend to respond to all relevant questions i 5 question the same way I've responded to most of 1 6 regarding this lawsuit; however, at the present 1 6 your other questions here today, which is, I intend 17 time, my attorneys have counseled me that i cannot 1 7 to respond to all relevant questions regarding this 1 8 provide answers to any questions that may he 1 8 lawsuit; however, at the present time. My 1 9 relevant to this lawsuit. 1 must accept their 1 9 attorneys have counseled me that I cannot provide 2 0 advice or risk losing my 6th Amendment right to 2 0 answers to any questions relevant to this lawsuit. 2 1 effective representation. Accordingly, I assert my 2 1 I must accept their advice or risk losing my 6th 2 2 federal constitutional rights as guaranteed by the 2 2 Amendment right to effective representation. 2 3 5th, 6th and 14th Amendment to the US Constitution. 2 3 Accordingly, i must assert my federal 2 4 BY MR. KUVZN: 2 4 constitutional rights as guaranteed by the 5th, 6th 25 Q. Do you agree that while 8.13. was 1.5 and giving 2 5 and 14th Amendment to the United States 31 (Pages 136 to 139) (561) 832?4500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronically signed by Joana Ricciuti (601-280428-9381) Electronically signed by Joana Ricciuti (601-2804288381) Page 140 Page 142 1 Constitution. 1 Sarah Kellen, you had another underaged girl, Haley 2 BY MR. KUVIN: 2 Robson, working to obtain other underaged girls to come 3 Q. You penetrated B.B.'s vagina with your ?nger 3 to your house with sexual encounters for sexual 4 and a vibrator, did you not? 4 encounters with you? 5 MR. PIKE: Same objections. 5 MR. PIKE: Same objections. 6 THE WITNESS: l?rn going to respond to that 6 THE WITNESS: Could you repeat the question? 7 question the same way i?ve responded to most of 7 BY MR. 8 your other questions here today, which is, I fully 8 Q. Sure. Isn?t it true that in addition to Sarah 9 intend to respond to all relevant questions 9 Kellen, you had another girl who, at the time was 1 0 regarding this lawsuit; however, at the present 1 0 underage, Haley Robson, working to obtain underaged 1 1 time, my attorneys have counseled me i cannot 1 1 girls to come to your house for sexual encounters with 1 2 provide answers to any questions relevant to this 1 2 you? 1 3 lawsuit. I must accept their advice or risk losing 1 3 PIKE: Same objections. 1 4 my 6th Amendment right to effective representation. 1 4 THE WITNESS: l?ni going to have to respond to 1 5 Accordingly, I must assert my federal 1 5 that question the same way I've responded to your 1 6 constitutional rights as guaranteed by the 5th, 6th 6 other questions here today, Mr. Kuvin, which is, I 1 '7 and 14th Amendment to the United States 1 7 intend to respond to all relevant questions 1 8 Constitution. 1 8 regarding this lawsuit; however, at the present 1 9 BY MR. KUVIN: 1 9 time, my attorneys have counseled me that i cannot 2 0 Q. And it is also true that you've paid hundreds 2 0 provide answers to any questions that may be 2 1 of girls under the age of 17 for similar encounters 2 3. relevant to this lawsuit. 1. must accept this 2 2 where you've asked them to get naked, you've laid on a 2 2 advice or risk losing my 6th Amendment right to 2 3 table naked, masturbated and then touched them in their 2 3 effective representation. Accordingly, I must 2 4 vagina at your Palm Beach home; isn't that true? 2 4 assert my federal constitutional rights as 2 5 MR. PIKE: Form, argumentative, harassingp-g; 28- guaranteed by the 5th, 6th and 14th Amendment to Page 141 Page 143 1 multiple, compound, it?s confusing, vague, it lacks 1 the United States Constitution. 2 proper predicate and foundation. 2 BY MR. KUVIN: 3 MR. KUVIN: Let me back up. 3 Q. And when these young girls were recruited to 4 BY MR. KUVIN: 4 come to your home, you told Kellen and Robson to tell 5 Q. Becauso of the compound, I'm going to have to 5 them that it would be a platonic massage with no sexual 6 break it down a little. 6 contact; isn?t that true? 7 isn't it true, sir, that you've paid hundreds 7 MR. Same objections. 8 of girls under the age of 17 to come to your home and 8 THE WITNESS: l'm going to respond to that 9 give you naked massages? 9 question the way I've responded to most of your 1 0 MR. PIKE: Same objection, plural. 1 0 other questions here today, Mr. Kuvin, which is, 1 1 THE WITNESS: l?m going to have to respond to 1 1 intend to respond to all relevant questions 1 2 that question the same way I've responded to most 1 2 regarding this lawsuit; however, at the present 13 of your other questions here today, Mr. Kuvin, i 3 time, my attorneys have counseled me I cannot 14 which is, I intend to respond to all relevant 1 4 provide answers to any questions that may be 1 5 questions regarding this lawsuit; however, at the 1 5 relevant to this lawsuit. 1 must accept their 1 6 present time, my attorneys haVe counseled me I 6 advice or risk losing my 6th Amendment right to 1 7 cannot provide answers to any questions relevant to 1 7 effective representation. Accordingly, I assert my 1 8 this lawsuit. I must accept their advice or risk 1 8 federal constitutional rights as guaranteed by the 1 9 losing my 6th Amendment right to effective 1 9 5th, 6th and l4th Amendment to the United States 2 0 representation. Accordingly, I assert my federal 2 0 Constitution. 2 1 constitutional rights as guaranteed by the 5th, 6th 2 1 BY MR. KUVIN: 2 2 and 14th Amendment to the United States 2 2 Q. It was only after the girls arrived at your 2 3 Constitution. 2 3 home that they learned that they would have to get naked 2 4 BY MR. KUVIN: 2 4 and you would be fondling them sexually; isn't that 2 5 Q. Isn't it true, sir, that in addition to 2 5 true? sumacear-mammauszm . 1m. mam-sit 32 (Pages 140 to 143) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronically signed by Jenna Ricciuti {601~280~428~9381) Electronically signed by Jeane Riccmti (601~280~428~9381) 34'! 9 Page 144 Page 146 i? 1 MR. PIKE: Form, argumentative, lacks 1 statement. 2 predicate, improper foundation, argumentative and 2 MR. KUVIN: He was asking me a questicin, 3 harassing. 3 that?s the only reason why I responded. I a 4 run WITNESS: I'm going to respond to that 4 apologize. 5 question the same way I responded to most of your 5 MR. PIKE: Once again, move to strike. 6 other questions here today, which is, I intend to 6 THE WITNESS: I intend to respond to all 7 respond to all relevant questions regarding this 7 relevant questions regarding this lawsuit; however, 8 lawsuit; however, at the present time, my attorneys 8 at the present time, my" attorneys have counseled me 9 have counseled me i cannot provide any answers to 9 I cannot provide answers to any questions relevant 0 question that may be relevant to this lawsuit. 1 1 to this lawsuit. 1 must accept this advice or risk 1 1 must accept their advice or risk losing my 6th 1 1 losing my 6th Amendment right to effective 1 2 Amendment right to effective representation. 1 2 representation. Accordingly, assert my federal 1 3 Accordingly, I must assert my federal 1 3 constitutional rights as guaranteed by the 5th, 6th 1 4 constitutional rights as guaranteed by the 5th, 6th 1 4 and 14th Amendment to the United States 1 5 and 14th Amendment to the United States 1 5 Constitution. 1 6 Constitution. 1 6 BY MR. KUVIN: 17 BY MR. KUVIN: 1 7 Q. Do you have a massage table in your Palm Beach 1 8 isn?t it true that you had numerous girls 1 8 home? 1 9 under the age of 17 brought to your home by taxi? 1 9 A. I'm going to answer that question, Mr. Kuvin, 2 0 MR. PIKE: Form, argumentative, overbroad, 2 the same way I've answered most of your other questions 2 1 lacks appropriate foundation. 2 1 here today, which is, I intend to respond to all 22 BY MR, KUVIN: 22 relevant questions regarding this lawsuit; howeverclarify. From the years 2004 2 3 the present time, my attorneys have counseled me that I 2 4 through 2006, 2 4 cannot provide answers to any questions relevant to this 2 5 MR, PIKE: Same objections, minus overbmad_ 2 5 lawsuit. I must accept their advice or risk losing my Page 145 Page 14'? 1 THE WITNESS: I'm going to have to answer that 1 6th Amendment right to effective representation. 2 question the same way I've answered most of your 2 Accordingly, i must assert my federal constitutional 3 other questions here today, which is, I intend to 3 rights as guaranteed by the 5th, 6th and 14th Amendment 4 respond to all relevant questions regarding this 4 to the United States Constitution. 5 lawsuit; however, at the present time, my attorneys 5 Q. Did you have a massage table at your home in 6 have counseled me I cannot provide answers to any 6 2005? 7 questions that may be relevant to this lawsuit. I '7 MR. PIKE: Lacks appropriate foundation. 8 must accept their advice or risk losing my 6th 8 KUVIN: I'm sorry, what?s the objection to 9 Amendment right to effective representation. 9 that one? 1 0 Accordingly, I assert rny federal constitutional 0 MR. PIKE: Lacks appropriate foundation. 3. 1 rights as guaranteed by the 5th, 6th and 14th 1 1 MR. KUVIN: Foundation? 12 Amendment to the United States Constitution. 1 2 MR. Yes, it doesMR. Kuer: 14 Q. Isn't it true that you paid a taxi to haVe 1 4 Q. Did you have a home in 2005? i 5 girls, underaged girls like 8.3., brought to your home 1 5 I?m sorry, Pm just trying to lay the 6 from the years 2004 to 2006? 1 6 foundation, and I apologize for laughing, ijust don?t 17 A. I?m going to reSpond to that question the way 1 7 understand the objection. i'm trying to understand the 1 8 l've responded to most of your other questions here 1 8 foundation question of did you have a massage table at 1 9 today, which is, I intend to respond to all relevant 1 9 your home in 2005. I want to fix my question, if if 2 0 questions regarding this lawsuit; however, at the 2 I can. 2 1 present time, my attorneys have counseled me that I 2 1 MR. PIKE: if you can. 2 2 cannot I'm sorry, should'l start again? Do you 22 MR. KUVIN: All right. 2 3 want 2 3 BY MR. KUVIN: 2 4 Q. No, please, don't start again. 2 4 Q. Did you have a home in 2005? 2 5 MR. PIKE: Move to strike counsel's last 2 5 A. I'm going to reapond to that question the same 33 (Pages 144 to 147) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronically signed by Jenna Ricciuti (601-280428-9381) Electronically signed by Jeane Ricciutl (601-2804289381) a4?! 9 Page 148 Page 150 1 way I've responded to most of your other questions here 1 BY MR. 2 today, which is, fully intend to respond to all 2 Q. Do you know what the word "massage" is? Do 3 reievant questions regarding this lawsuit; however, at 3 you know what that word means? 4 the present time, my attorneys have counseled me that I 4 A. I'm going to respond to that question the same 5 cannot provide answers to any of your questions that may 5 way i?ve responded to most of your other questions here 6 be relevant to this iawsuit. i must accept their advice 6 today, which is, i intend to respond to all relevant 7 or risk losing my 6th Amendment right to effective 7 questions regarding this lawsuit; however, at the 8 representation. Accordingly, I assert my federai 8 present time, my attorneys have counseled me I cannot 9 constitutional rights as guaranteed by the 5th, 6th and 9 provide any answers to questions that may be relevant to 1 0 14th Amendment to the United States Constitution. 1 0 this lawsuit. I must accept their advice or risk losing 1 Q. Do you know what a massage table is? 1 1 my 6th Amendment right to effective representation. 2 A. I'm going to have to answer that question the 1 2 Accordingly, i assert my federal constitutional rights 3; 1 3 same way I've anSWered most of your other questions here 1 3 as guaranteed by the 5th, 6th and 14th Amendment to the 1 4 today, Mr. Kuvin, which is, I intend to respond to all 1 4 United States Constitution. 1 5 relevant questions regarding this lawsuit; however, at 5 Q. Do you understand what I mean when i ask you 1 6 the present time, my attorneys have counseled me I 1 6 about the year 2005? 1 7 cannot provide answers to any questions that may be 1 7 MR. PIKE: Form, vague and confusing. 1 8 relevant to this lawsuit. I must accept this advice or 1 8 BY MR. KUVZN: 1 9 risk losing my 6th Amendment right to effective 1 9 Q. You can answer. 2 representation. Accordingiy, assert n?ry federal 2 -- A. I don't understand the question. 2 constitutional rights as guaranteed by the 5thyou understand what I mean by the year 22 14th Amendment to the United States Constitution. 22 2005? 2 3 Q. Do you know what a table is? 2 3 MR. GOLDBERGER: You just asked the same 2 4 MR. PIKE: Objection, harassing 2 4 question. He said he didn't understand it. Just 2 5 MR. KUVIN: i?m just trying 2 rephrase the question. Page 149 Page 151 1 MR. PIKE: -- argumentative. 1 BY MR. KUVIN: 2 MR. KUVIN: I apologize. i.?m just trying to 2 Q. Do you understand dates? 3 lay the foundation. I want to make sure that 3 A. Like going on a date? 4 there's no problem with the foundation for the 4 Q. No. Like years, dates. 2001, 2000, do you 5 question of, did you have a massage table in your 5 know what that means? 6 home in 2085. So I've asked him whether he had a 6 A. Yes. 7 home, i'rn asking him whether he knows what a 7 MR. KUVIN: Okay. So Ijust want to make 8 massage table is m- 8 sure. We've objected to the word "massage," 5th 9 W. GOLDBERGER: I have no problem with him 9 Amendment, he knows what a table is, he knows what 1 0 answering what a table is. .iust ask him the 10 dates and years are and he's objected to his house. 1 1 question. 1 1 MR. GOLDBERGBR: The question, Spencer, okay? 12 BY MR. 12 Don't do that, piease. 1 3 Q. Do you know what a table is? 1 3 MR. KUVIN: l?m trying to make sure that i 1 4 A. Yes. 1 4 have it all right here. 1 5 Q. Okay. Did you have a massage table in your 15 MR. GOLDBERGER: All right, but don't 1 6 home back in 2005? 1 6 verbalize your thoughts. Just ask a question. 17 MR. PIKE: Same objection. 17 MR. KUVIN: Okay. 8 THE WITNESS: I?ve already answered 18 MR. PIKE: i'rn also going to move to strike 1 9 MR. Wait. Wait. Same objection 1 9 counsel's last statement from the record. 20 MR. PIKE: Asked and answered. 20 BY MR. KUVIN: 2 1 MR. KUVIN: w? means what? 2 It Q. Did you have a massage table at your home in 2 2 MR. PIKE: It's asked and answered. 2 2 2005? 2 3 MR. KUVIN: Is that the only objection? 2 3 MR. PIKE: Same objection, lacks foundation, 2 4 MR. PIKE: And it still lacks the appropriate 2 4 improper predicate. 2 5 foundation. 2 5 THE WITNESS: I'm going to respond to that 34 (Pages 148 to 151) (561) 832-4500 PRQSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronically signed by Jeane Ricciuti (601-2804289381) Etectronicatly signed by Jenna Rieciuti (601-280-428-9381) a4?t Page 152 Page 154 1 question the same way I've responded to most of 1 MR. PIKE: There was not a compound. 2 your other questions here today, which is, i intend 2 MR. Okay. 3 to respond to all relevant questions regarding this 3 MR. PIKE: The objection was foundation and 4 lawsuit; however, at the present time, my attorneys 4 predicate. 5 have counseled me i cannot provide answers to any 5 BY MR. KUVIN: 6 questions that may be relevant to the lawsuit. I 6 Q. Okay. You can answer. 7 must accept their advice or risk losing my 6th 7 A. l?m going to answer that question the way I?ve 8 Amendment right to effective representation. 8 answered most of your other questions here today. i 9 Excuse me? 9 intend to respond to all relevant questions regarding 1 0 BY MR. 1 0 this lawsuit; however, at the present time, my attorneys 1 1 Q. l'm sorry, I just had a nasal problem. 1 1 have counseled me I cannot provide answers to any 2 A. Let me start from the beginning again. 12 questions that may be relevant to the lawsuit. 1 must fl 3 Q. Whatever you'd like to do. I 1 3 accept their advice or risk losing my 6th Amendment 1 4 A. i intend to respond to all relevant questions 1 4 right to effective representation. Accordingly, I 1 5 regarding this lawsuit. I should start again. 1 5 assert my federal constitutional rights as guaranteed by 1 6 Q. Okay. Whatever you're comfortable doing. I 6 the 5th, 6th and 14th Amendment to the United States 1 7 have all day. 1 7 Constitution. 1 8 A. I intend to respond to all relevant questions 1 8 Q. I'm going to show you a clip of a deposition 1 9 regarding this lawsuit; however, at the present time, my 1 9 that was taken in this case and, first of all, ask 2 attorneys have counseled me I cannot provide answers to 2 0 you -- this is the deposition of L.M. that had been 2 1 any questions relevant to this lawsuit. i must accept 2 1 previously taken in this case. 2 2 their advice or risk losing my 6th Amendment right to 2 2 MR. PIKE: Wait a minute. 2 3 effective representation. Accordingly, I must assert my 2 3 MR. KUVIN: You're welcome to watch. 2 4 federal constitutional rights as guaranteed by the 5th, 2 4 MR. PIKE: i might I want it played to the 2 5 6th and 14th Amendment to the United States 2 5 video first. Page 153 Page 155% 1 Constitution. 1 MR. KUVIN: Okay, I can do that. 2 Q. Did you have a massage table in your upstairs 2 MR. 3311(5): Okay. So let's play it to the 3 bathroom in 2005? 3 video first and then we'll determine what's next. 4 MR. PIKE: Foundation, lacks appropriate 4 MR. KUVIN: Well, I'm going to ask him a 5 predicate. 5 couple of questions first before I hit play. 6 THE WITNESS: i'm going to respond to that 6 MR. PIKE: i need to see it first. 7 question the same way I've responded to most of 7 MR. Come around and look. i want him 8 your other questions here today, Mr. Kuvin, which 8 to see it at the same time. 9 is, I intend to respond to all relevant questions 9 MR. PIKE: That?s ?ne. i want it played to 1 0 regarding this lawsuit; however, at the present 1 0 the camera ?rst. 1 3: time, my attorneys have counseled me I cannot 11 MR. Oh, no. Fm not going to do your 12 provide answers to any questions that may be 12 order. i?m going tojust ask him ?rst 13 relevant to the lawsuit. i must accept their 1 3 PIKE: You need to you're asking the 1 4 advice or risk losing my 6th Amendment right to 4 Witness about an exhibit technically that is going 1 5 effective representation. Accordingly, assert my 1 5 to be utilized in this deposition that you have not 1 6 federal constitutional rights as guaranteed by the 1 6 provided me first. So just like you would 1 7 5th, 6th and 14th Amendment to the United States 1 7 professionally provide me a document first, I'm 1 8 Constitution. 1 8 asking that you provide me the video first, play it 1 9 BY MR. KUVZN: 1 9 to the camera, or you and I can step outside and 2 8 Q. Did you keep various massage oils, lotions, 2 0 you can play it to me and then you can ask the 2 1 sexual devices and sexual toys in your upstairs bathroom 2 1 witness. The witness will remain in here. You and 2 2 in 2005?? 22 I can go into a different room. Then he's not 2 3 MR. PIKE: Same objection. 2 3 going to answer any questions with regard to the jg 2 4 MR. KUVIN: Wait a minute, is there a compound 2 4 video, then I ask that it not you're not giving 2 5 in there? Because if so, I?ll separate them out. 2 5 me a document that you're questioning the witness 35 (Pages 152 to 155) (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (561) 832-97506 Electronically signed by Jeane Ricciutl (661~280~428~9381) Electronically signed by Jeane Ricciuti (601-280428?9381) Page 3.56 Page 158 on. It doesn't work that way. 1 lawsuit. 1 must accept this advice or risk losing my 2 MR. KUVIN: Let me speak. You were provided 2 6th Amendment right to effective representation. 3 the deposition of L.M. Someone from your office 3 Accordingly, I assert my federal constitutional rights 4 was present and actualiy asking the questions. 4 as guaranteed by the 5th, 6th and 14th Amendment of the 5 This is not an exhibit that you do not have or did 5 United States Constitution. 6 not have previous. You?ve had this ever since the 6 Q. Did you watch her deposition as she was giving 7 deposition was taken. So I'm not surprising you 7 it? 8 with any new document or testimony or anything of 8 MR. GOLDBERGER: Attorney-client. 9 the like. This is the exact same testimony of a 9 BY MR. KUVIN: 1 0 witness who had been previously taken in this case 1 0 Q. Were you present and watching L.M.'s testimony 1 1 and Z?rn not going to play it, [just want to see a 1 by closed-circuit camera as she gave her testimony in 3 12 couple of questions first. I. will agree with your 12 this case? 1 3 procedure to piay it to the camera first, and then i. 3 MR. PIKE: Attorney~client, work product. 14 I will ask him questions after We played it to 1 4 MR. GOLDBERGER: Attorney-client, work 3. the camera about what I just piayed. 1 5 product. i. 6 MR. PIKE: As long as -- 1 6 MR. PIKE: i'm going to instruct the witness 1 7 MR. .KUVIN: But I want some identi?cation 1 7 not to answer both of those questions. 1 8 issues ?rst, and that's all. 1 8 MR. KUVIN: I'm going to play one of the 1 9 MR. PIKE: Let me ciear something up. i was 1 9 clips. Teli me if you can get a ciear shot of 2 0 not at the deposition of LM. Bob Critton and Mark 2 0 this. 2 3. Luttier -- 2 1 THE VIDEOGRAPHER: is this going to be played 2 2 MR. KUVIN: Correct. 2 2 with audio? 23 MR. PIKE: were at that deposition. 23 MR. YesMR. KUVIN: Both attorneys at your office. 24 can pick it up. ?2 5 MR. PIKE: I have not seen this video. 25 MR. PIKE: And for purposes of the record, I Page 157 Page 159 1 MR. KUVEN: Both attorneys at your office. 1 want it to this camera to zero out from the 2 MR. PIKE: It doesn't matter. It doesn't 2 current deponent onto that. i do not want my 3 matter. 3 ciient in the background of this videotape. Is 4 So as long as you agree to play the video 4 that understood? 5 first to the camera -- 5 THE VIDEOGRAPHER: We asked to get a shot of 6 MR. KEVIN: Sure. 6 the computer screen and that's what I have. 7 MR. PIKE: then you can proceed with your 7 MR. PIKE: Let me see what your shot is. 8 questioning. 8 THE VIDEOGRAPHER: You're welcome to do so. 9 MR. Sure. 9 MR. KUVIN: You got a ciean shot? 1 8 MR. PIKE: And then you can play it to the 10 THE VIDEOGRAPHER: If he sticks his face in 1 1 witness, but I want to see it ?rst. 1 1 front of the computer, I can't do anything about l. 2 MR. KUVIN: That's ?ne. That?s ?ne. 12 it, but i've been asked to give a shot computer. That?s what I have. 1 4 Q. All right. i have a photograph here or a 14 MR. PIKE): Let?s go. 1 5 video clip showing a young lady who's been identi?ed in 1 5 MR. Okay, are we good? Ciean shot? i. 6 this case as LM. Her deposition was given in this 1 6 (Video being played.) 3.7 case. 17 vroeo WITNESS: "And his littie fetish with 1 8 And just to some foundation, first, do you 18 me, pinching his nipples. He's probably getting 1 9 recognize this girl? 1 9 hard right now." 2 A. I'm going to respond to that question the way 2 0 (Video stopped.) 2 1 I?ve responded to most of your other questions here 2 1. BY MR. 2 2 today, which is, intend to respond to all reievant 2 2 Q. Okay. That?s ail. Ail right? Okay. 2 3 questions regarding this iawsuit; howevermake sure that I have that. I?m going 2 4 present time, my attorneys have counseled me I cannot 2 4 to play a clip for you that Igust played for your 2 5 provide answers 'to any questions relevant to this 2 5 attorneys, and then i'd like to ask you a question about .. 36 (Pages 156 to 159) (561) 832*7500- PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeane Ricciuti (601-2804284338?) Electronically signed by Joana Riccinti (601-2804288381) a4?i Page 160 Page 162 1 it. 1 United States Constitution. 2 (Video being played.) 2 Q. Have you had underaged girls, which include 3 VIDEO "And his little fetish with 3 3.3., in 2004, 2005 and 2006, massage your chest while 4 me, pinching his nipples. He's probably getting 4 they were naked? 5 hard right now." 5 A. I intend to respond to all relevant questions i 6 (Video stopped.) 6 to this lawsuit; however, at the present time, my 7 BY MR. KUVIN: 7 attorneys have counseled me I cannot provide answers to 8 Q. Do you have a fetish where you like young 8 any questions that may be relevant to this lawsuit. As 9 women to pinch your nipples? 9 l've done with most of your questions here today, I must 1 0 A. I'm going to respond to that the same way i?ve 1 0 accept their advice or risk losing my 6th Amendment responded to most of your other questions here today, 1 1 right to effective representation. Accordingly, i 1 2 which is, I intend to respond to all relevant questions 1 2 assert my federal constitutional rights as guaranteed by 13 regarding this lawsuit; however, at the present time, my 1 3 the 5th, 6th and 14th Amendment to the United States 3. 4 attorneys have counseled me I cannot provide answers to 1 4 Constitution. 1 5 any questions relevant to this lawsuit. I must accept 1 5 Q. Does Mr. Wexner know of your sexual preference 1 6 their advice or risk losing my 6th Amendment right to l. 6 for underaged girls, girls under the age of i7? 17 effective representation. Accordingly, I assert my 17 MR. PIKE: Form, argumentative, harassing, 1 8 federal constitutional rights as guaranteed by the 5th, 1 8 assumes facts not in evidence. 1 9 6th and 14th Amendment to the United States 1 9 THE WITNESS: I?m going to have to answer that 2 0 Constitution. 2 the same way I've answered most of your questions 2 1 MR. PIKE: And I assume, Mr. Kuvin, you will 2 1 here today, which is, I intend to respond to all g; 2 2 provide me with the number on the roll that 2 2 relevant questions regarding this lawsuit; however, 2 3 you?re that you pretty much marked as an exhibit 2 3 at the present time, my attorneys have counseled me 2 4 here, where it starts numerically and where it ends 2 4 I cannot provide answers to any questions that may 25 numerically so I can pull it and we can have an 25 be relevant to the lawsuit. I must accept their Page 161 Page 163 1 exhibit made for purposes of this deposition. 1 advice or risk losing my 6th Amendment right to 2 MR. KUVEN: Oh, I don't intend to attach it as 2 effective representation. Accordingly, assert my 3 an exhibit to this deposition. 3 federal constitutional rights as guaranteed by the 4 MR. PIKE: Well, what were the where did it 4 5th, 6th and 14th Amendment to the United States 5 start and where did it begin on the roll? 5 Constitution. 6 MR. KUVIN: I don?t know. It's a clip that 6 BY MR. KUVZN: I 7 pulled from the master videoDid you pay 13.13. $200 to come to your home in 8 though. I can certainly identify it in the 8 2005? 9 transcript. 9 MR. Form. 1 0 MR. So you?ll provide that to me? 1 0 MR. KUVIN: i?m sorry, what?s the form 1 1 MR. KUVIN: Yeah, I?ll ?nd a place in the 1 1 problem? 12 transcript for you, that's not a problem. 12 MR. PIKE: i don?t need to provide you with a 1 3 BY MR. KUVIN: 13 speaking objection. The rules are the rules. 1 4 Q. Do you like to have underaged girls message 1 4 You've clearly stated to me today that you don't 1 5 your legs, underaged being under the age of 18? 1 5 want speaking objections, and i've abided by that; 1 6 A. I'm going to respond to that question the same 1 6 therefore, the objection is form. 1 7 way l've responded to most of your other questions here 1 7 MR. I'm just asking for a 8 today, which is, I intend to reSpond to all relevant 18 clari?cation so I can correct the question if i 1 9 questions regarding this lawsuit; however, at the 1. 9 need to. 2 0 present time, my attorneys have counseled me i cannot 2 0 MR. PIKE: Ask your question again, Mr. Kuvin. 2 1 provide answers to any questions relevant to this 2 1 MR. Can you read it back for me? 2 2 lawsuit. I must accept their advice or risk losing my 2 2 Thank you. 2 3 6th Amendment right to effective representation. 2 3 (A portion of the record was read by the 2 a Accordingly, I assert my federal constitutional rights 2 4 reporter.) 2 5 as guaranteed by the 5th, 6th and 14th Amendment to the 2 5 THE WITNESS: I'm going to respond to that 37 (Pages 160 to 163) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 Electronically signed by Joana Ricciutt (601-2804283381) Electronically signed by Jenna Ricciutl Page 164 Page 3.66 1 question in the same way We responded to most of 1 and 14th Amendment to the United States 2 your other questions here today, which is, I intend 2 Constitution. 3 to respond to ail relevant questions regarding this 3 THE VIDEOGRAPHER: Spencer, can we take a 4 lawsuit; however, at the present time, my attorneys 4 quick break? 5 have counseled me I cannot provide answers to any 5 MR. KUVIN: Change tape? 6 questions that may be reievant to this lawsuit. I 6 THE No, a problem with your i 7 must accept their advice or risk losing my 6th 7 mic. ljust want to go off for a second and see if 8 Amendment right to effective representationAccordingly, i must assert my federal 9 MR. KUVIN: Sure. I constitutional rights as guaranteed by the 5th, 6th 1 0 THE We're off the record at 1. and 14th Amendment to the United States 3. 3. 1:03 p.111. 1 2 Constitution. 1 2 (A brief recess was taken.) 13 MR. was: Same objection. 13 1 4 BY MR. KUVIN: 1 4 15 Q. You knew 13.13. was 15 years old when she came 1 5 1 6 to your home, didn't you? I 1 6 1 7 MR. PIKE: Form. 1 7 8 THE WZTNESS: I'm going to respond to that 1 8 1 9 question the same way I've responded to most of 1 9 2 0 your other questions here today, which is, I intend 2 0 2 to respond to all relevant questions regarding this 2 1 2 2 lawsuit; hOWever, at the present time, my attorneys 2 2 3 have counseled me i cannot provide answers to any 2 3 2 4 questions relevant to this lawsuit. I must accept 2 4 2 5 their advice or risk losing my 6th Amendment right 2 5 Page 165 Rage 167 1 to effective representation. Accordingly, I assert 1 CERTIFICATE OF OATH 2 my federal constitutional rights as guaranteed by 2 THE STATE OF FLORIDA 3 the 5th, 6th and 14th Amendment to the United 3 COUNTY OF FALM BEACH 4 States Constitution. 2 5 BY KUYIN: 6 I, the undersigned authority, certify that 6 What 15 the wexner Children 5 TmSta the "i JEFFREY EPSTEIN personally appeared before me and was 7 Second? 8 duly sworn on the 8th day of October, 2009. 8 MR. PIKE: Can you restate your question 9 9 again? 3. 0 Dated this 8th day of October, 2009. 3. 0 BY MR. KUVIN: ll 1 1 Q. Yes. What is the Wexner?s Children?s I'm 12 2 sorry, Wexner, singular, Chiidren's Trust second? 2mg? 14 MR. GOLDBERGER: Okay. 15 15 THE WITNESS: I'm going to have to respond to jeana Riccimi? RPR, 6L 3. 6 that question the same way I've responded to most 3. 6 Notary Public - State of Florida 3. 7 of your other questions here today, Mr. Kuvin, My Commission Expires: 2/ 1 7/2013 1 8 which is, I intend to respond to relevant 17 My CommiSSiOH NO-I DD 354778 9 questions regarding this iawsuit; howeverpresent time, my attorneys have counseled me I 2 1 cannot provide answers to any questions relevant to 2 2 2 this lawsuit. I must accept this advice or risk 22 2 3 iosing my 6th Amendment right to effective 2 3 2 4 representation. Accordingly, I assert my federal 2 4 2 5 constitutional rights as guaranteed by the 5th, 6th 25 38 (Pages 164 to 167) (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (563.) 832?4506 Electronically signed by Joana Ricciuti (601-280428-9381) Electronically signed by Jeana Ricciuti (601-280428-9381) a41 Page 168 Page 170 1 a I 1 CERTIFICATE 1 CERTIF1CATE 2 - THE) STATE OF FLORIDA 2 3 COUNTY or BEACH 4 3 THE STATE OF LORZDA 5 1' Joana Ricciuti Registered Professional 7 I Reporter and Notary Public in and for the State of 4 COUNTY OF 9A11M BEACH 6 Florida at large, do hereby certify that I was 5 i hereby certify that have read the ti authorized to and did report said deposrtion 1n 6 foregomg deposmon by me given, and that the 7 stenotypc; and that the foregoing pages are a true and . a correct transcription of my shorthand notes of said 7 statements contained herein are true and correct to the - - . a deposmon. I 8 best of my knowledge and belief, With the exception of 9 I further certify that said deposrtron Was 9 . . i taken at the time and place hereinabovc set forth and any correcnons 0r ?Nations made on the errata 3 sets 10 that the taking of said deposition was commenced and 1 0 if one was executed, coinpieted as hereinabovc set Out. 1 3. 1 I further certify that I am not attorney or 1 2 Dated this day of 1 2 counsel of any of the parties, nor am I a relative or 1 3 2009. employee of any attorney or counsei of party connected 3 with the action, nor am I ?nancially interested in the 1 4 action. 1 5 3. 4 The foregoing certi?cation of this transcript 1 6 5 does not apply to any reproduction of the same by any 1 7 means unless under the direct control andfor direction 1 8 1 6 of the certifying reporter. 1 7 Dated this 8th day or October, 2009. 1 9 EFFREY EPSTEIN ?nal ,;gmw 21 2 1 "Qumran/x? ?jasmine 2 2 areas Riccinti, aha, seaPage 169 Page 171% 1 one: October 22, 2009 1 a A A a 2 TO: ?ight 2 IN RE: 13.13. v. EPSTEIN CR: JEANA RICCZUTI 3 BURMAN. canton, LUTTIER a COLEMAN, PA. 2 Epsmm 303 Banyan Boulevard i . 4 Suite 400 5 DO NOT WRITE ON - ENTER CHANGES HERE 5 West Palm Beach, Florida 33401 6 PAGE it LINE CHANGE REASON rN RE: as. v. 7 6 Please take notice that on Thursday, the 8th ?i of October, 2009, you gave your deposition in the 8 g} abovercferred matter. At that time, you did not waive i? signature. it is now necessary that you sign your 9 deposition. a 9 As previously agreed to. the lranscript wil! be furnished to you through your counsel. Please read 10 10 the following instructions carefuiiy: At the end oftho transcript you will find an 1 1.1 errata sheet, As you read your deposition, any changes or corrections that you wish to make should he noted on 1 2 .1 2 the errata sheet. citing page and line number of said 3% change. DO NOT write on the transcript itself. Once 13 you have read the transcript. and noted any changes, he 1 3 sure to sign and date the errata sheet and return these 4 pages not read and sign the deposition 5 within a reasonable time 30 days unless otherwise directed) the original, which has already been forwarded 1 5 16 :2 orderiitrlg attorniey, may be fried \yith the Clerk of 1 6 ourt. you was i to waive year signature. your name in the blank at the bottom of this letter and 1 7 please onward {he o?ggna; Signed errata sheet to [his 18 "mm ?t to of?ce so that copies may be distributed to all parties. Very truly yours. 1 8 . 19 Under penalty of peijory, 2 declare that i have read my a 1 9 deposition and {her it is true and correct subject. to 7?0 1 any changes in form or substance entered here. . ieana Riccrutl, RPR, FPR. CLR 2 0 21 Prose Court Reporting Agency. INC. 2 1 TE 250 S. Australian Avenue, Ste 1500 A i 22 West Palm Beach. Florida 334a: 2 2 23 Ido hereby waive my signature. 23 SIGNAI URE OF DEPONENT: 24 24 25 JEFFREY EPSTEIN 25 exams/aa??i?gwa" Lawnmower-aces? - t. 39 (Pages 168 to 171) (561) 832?7500 PROBE COURT AGENCY, INC. (561) 832?7506 Electronically signed by Jeane Rieciuti(601-2804284381) Electronicaiiy signed by Joana Ricciuti 280428-9381) a41 Page 172 Page 174 IN THE CIRCUIT THE 15th JUDICIAL CIRCUIT - - - IN AND FOR PALM BEACH COUNTY, FLORIDA 2 I I 3 WITNESS: DIRECT CASE No. AB 4 IBFFREY 5 BY MR. KUVIN 175 6 an, 7 PlaintiffNUMBER DESCRIPTION PAGE 1 1 EX. 9 PHOTOGRAPH OF GEES LAINE 182 Defendant. MAXWELL 12 BX. 10 PHOTOGRAPH OF JOANNA 191 1 3 EX. 1 1 PHOTOGRAPH OF EULA MAXWELL 196 EX. 22 PHOTOGRAPH 198 CONTINUED OF IEFFREY EPSTEEN 1 4 ex. 23 PHOTOGRAPH OF SARAH KBLLEN 199 3? VOLUME HI ex. PHOTOGRAPH OP NADIA 200 3; 1 5 MARCINKOVA Er Thursday, October 8, 2009 EX. 15 PHOTOGRAPH 0? HALEY ROBSON 201 1 6 EX. 16 PHOTOGRAPH OF 201 - 3148 pm. ANDREW 17 EX. 17 LETTER TO B. KRISCHER FROM 203 250 South Australian Avenue M- REITER Suite 1400 18 EX. 18 RECEIPT OF MERCHASES MADE 206 . FROM JAIL :3 West Palm Beach? 1"?63 33401 1 9 ex. 19 FAA REGISTRY 213 2 Reported By: 2 1 Joana Ricciuti, RPR, F1312, CLR 22 Notazy Public, State of Florida 2 3 Prose Court Reporting Agency, inc. 2 4 2 5 Page 173 Page 175 1 APPEARANCES: 2 0n behaifofl'he Piainti??: 0 I SPENCER xuvm. asouues 2 - - - 3 ADAM LANSING, as UIRE . LEOPOLD KUVIN, RE. 3 THE VIDEOGRAPHER: We?re back on the record at 4 2295 PGA Beuievard 4 I ?46 I 5* Suite 200 - I 5 Patm Beach Gardens, Florida 33416 5 CONTINUED DIRECT EXAMINATION Phcne: 551.935.4302 3039::El a 7 Q. Do you personally know John Mack, former CEO CARA L. was . Amen 8 at Morgan Stantey? 9 32515321535 0'35 301mm? 9 A. have to answer that the same way I've Fort Lauderdale, Florida 33301 i answered most of your questions here today, Mr. Kuvin, 10 Phone: 954.522.3456 . . . . 11 On belraifet?Piainti??Jane Doe en Case No. 30591 and 1 is, 1 mtend to respond to all relevant questrons 12 WELL, ESQUIRE 1 2 regarding this lawsuit; however, at the present time, my PODHURST ORSECK, PA. . 13 25 WW Flag,? 5mm 1 3 attorneys have counseled me I cannot provrde answers to Miami. Florida 33130 1 4 any questions relevant to this iawsuit. I must accept ii 14 Phone: 305.353.2890 . 15 On behalfofthe Defendant: 1 5 advrce or rISk 103mg my 62h Amendment ?ght effective representation. Accordingiy, i assert my GOLDBERGER warss, PA. - - e; 1, 250 South Australian Avenue 1 7 federal rights as guaranteed by the 5th, Suite 1400 8 6th and 14th Amendment to the United States 18 West Palm Beach, Fienda 3340] Phone: 561.659.8300 1 9 ConstitutionPIKE, ESQumg 2 0 MR. Okay. Same depOSItron as Shown 20 BURMAN, semen, LUTHER COLEMAN, PA. . . . . 303 Banyan Bouicvard 2 1 before, different clip. I gomg to play 1t for 21 Suite 490 2 2 counsei ?rst. West 'i?alm Beach, Florrda 33401 2, 22 Phonc1561.842.2820 2 3 MR. PIKE: Thank. you. 23 ALSO PRESENTDAN DOSKEY, ymaoomnaa MR. KUVIN: Mr. Videographer, Just Tet me know 25 VISUAL EVIDENCE, INC. 2 5 when yew?, ready. are?qu 1 (Pages 172 to 17 (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Eiectronicaliy signed by Jeane Ricciuti (601-2804283381) Electron icaily signed by Jeane Ricciuti (601-280-428-9381) 34 Page 176 Page 178 1 "rue VIDEOGRAPHER: Whenever you are. 1 MR. Kuer: Exactly. 2 MR. Okay. 2 MR. PIKE: Same objection. 3 (Video played.) 3 (Video played.) 4 VIDEO "What did i do to Jeffrey and 4 VIDEO WITNESS: "What did I do to Jeffrey and 5 what did Jeffrey do to me? i went up there 5 what did Jeffrey do to me? went out there 6 multiple times; i can?t count. And I would be on a 6 multiple times; I can?t count. And i would be on a massage table, massaging his legs, he would turn 7 massage table, massaging his legs. He would turn 8 over, his penis would be hanging out. He would put 8 over, his penis would be hanging out. He would put 9 a vagina -- or a vibrator to my vagina. He would 9 a vagina -- or vibrator to my vagina. He would 1 touch my vagina with his ?ngers. He would touch 1 touch my vagina with his ?ngers. He would touch 1 1 my breasts. He would try to kiss my mouth. He 1 1 my breasts. He would try to kiss my mouth. He 12 would bring my hands toward his penis." 1 2 would bring my hands toward his penis.? 3 (Video stopped.) 1 3 (Video stopped.) 4 MR. KUVIN: Okay. 1 4 BY MR. KUVIN: 1 5 MR. PIKE: I?mjust going to object that with that girl? 1 6 of the video as to relevance, predicate and 1 6 MR. Form. 1 7 foundation. 1 7 THE WITNESS: intend to respond to all 1 8 BY MR. KUVIN: 1 8 relevant questions regarding this lawsuit; however, 1 9 Q. All right. Let me get it back to the same 19 at the present time, my attorneys have counseled me 2 0 location. 2 0 I cannot provide answers to any questions that may 2 1 Sir, first of all, once again, just so i can 2 1 be relevant to this lawsuit. 1 must accept this 2 2 lay the foundation for this, do you recognize this girl? 2 2 advice or risk losing my 6th Amendment right to 2 3 A. I?m going to have to respond to that question 2 3 effective representation. Accordingly, I must 2 a the same way I've responded to most of your other 2 4 assert my federal constitutional rights as 2 5 questions here today, which is, i intend to respond to 2 5 guaranteed by the 5th, 6th and 14th Amendment to Page 177 Page 179 1 all relevant cannot provide answers to any questions 1 the United States Constitution. 2 relevant to this lawsuit; however, at the present time, 2 BY MR. 3 my attorneys have counseled me I cannot provide answers 3 Q. Did you do what that young lady described just 4 to any questions relevant to the lawsuit. i must accept 4 now to hundreds of women, including 5 this advice or risk losing my 6th Amendment right to 5 MR. Form, argumentativo, harassing, 6 effective representation. Accordingly, I assert my 6 lacks appropriate predicate, foundation, lacks 7 federal constitutional rights as guaranteed by the 5th, 7 identity. 8 6th and 14th Amendment to the United States 8 THE WITNESS: Excuse me. l'm going to respond 9 Constitution. 9 to that the same way l've responded to most of your 10 Q. Did this girl bring 8.8. to your home for a 1 0 other questions here today, which is, intend to 1 1 naked massage? 1 1 respond to all relevant questions regarding this 12 A. l?m going to have to respond to that the same 1 2 lawsuit; however, at the present time, my attorneys 1 3 way l?ve responded to most of your other questions here 1 3 have counseled me that i cannot provide answers to 1 4 today, which is, i intend to respond to all relevant 1 4 any questions relevant to the lawsuit. i must 1 5 questions regarding this lawsuit; however, at the 1 5 accept their advice or risk losing my 6th Amendment 1 6 present time, my attorneys have counseled me i cannot 1 6 right to effective representation. Accordingly, I 1 7 provide answers to any questions that may be relevant to 1. 7 must assert my federal constitutional rights as 1 8 the lawsuit. 1 must accept this advice or risk losing 1 8 guaranteed by the 5th, 6th and 14th Amendment to 1 9 my 6th Amendment right to effective representation. Cl 9 the United States Constitution. 2 0 Accordingly, I assert my federal constitutional rights 2 0 BY MR. KUVIN: 2 1 as guaranteed by the 5th, 6th and 14th Amendment to the 21 Q. While BB. was standing naked in your home, 2 2 United States Constitution. 2 2 speci?cally in your bathroom, did you tell her that you 2 3 Q. id like to play this clip for you and then 2 3 could get her an interview as a model because of your 2 4 I'm going to ask you a question. 2 4 connections? 2 5 MR. PIKE: The same clip you just played? 2 5 A. l'm going respond to that the same way We 2 (Pages 176 to 179) (561) 832~7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronically signed by Jeane Riociuti Electronically signed by Jeana Riociuti {601-280-428-9381) 34 Page 180 Page 3.82 1 responded to most of your questions today, Spencer. 1 1 Constitution. 2 intend to respond to all relevant questions regarding 2 BY MR. KUVIN: 3 this lawsuit; however, at the present time, my attorneys 3 Q. Who is Ghislaine Maxwell? 4 have counseled me i cannot provide answers to any 4 A. i intend to respond to all relevant questions 5 questions that may be relevant to the lawsuit. I must 5 regarding this lawsuit; however, at the present time, my 6 accept this advice or risk losing my 6th Amendment right 6 attorneys have counseled me that I cannot provide 7 to effective representation. Accordingly, I must assert 7 answers to any questions relevant to this lawsuit. As i 8 my federal constitutional right as guaranteed by the 8 have done to most of your other questions here today, i 9 5th, 6th and l4th Amendment to the United States 9 must accept their advice or risk losing my 6th Amendment 1 0 Constitution. 1 0 right to effective representation. Accordingly, i. 1 MR. Same objection to that line of 1 assert my federal constitutional rights as guaranteed by 2 questioning. 1 2 the 5th, 6th and 14th Amendment to the United States 1 3 BY MR. KUVIN: 3 Constitution. 1 4 Q. As 13.13. was standing naked in your bathroom 1 4 MR. KUVIN: Let me show the camera what we'll 1 5 before you when she was 15, did you ask her to turn 1 5 mark as Exhibit 9 to this deposition. 1 6 around so you could see her ass better? 1 6 THE Okay. 17 MR. PIKE: Form, argumentative, harassing, l7 (Plaintiffs Exhibit No. 9 was marked for 1 8 lacks appropriate predicate, foundation. 1 8 identi?cation.) 1 9 THE WITNESS: l"il respond to that as I 1 9 BY MR. KUVIN: 2 responded to your last question, which is, intend 2 Q. Let me show you what we?ve marked as Exhibit 9 2 1 to respond to all relevant questions regarding this 2 1 to your deposition. Do you recognize Ghislaine Maxwell 2 2 lawsuit; however, at the present time, my attorneys 2 2 in this photograph? 23 have counseled me I cannot provide answers to any 23 A. Yes. 24 questions that may be relevant to this lawsuitshe standing with? 2 5 must accept their advice or risk losing my 6th 2 5 A. Her father. Page 181 Page 183 1 Amendment right to effective representation; 3. Q. And her father is Robert Maxwell? 2 therefore, I must assert my federal constitutional 2 A. Was Robert Maxwell. 3 rights as guaranteed by the 5th, 6th and 14th 3 Q. i?m sorry, he?s passed, correct? 4 Amendment to the United States Constitution. 4 A. Correct. 5 BY MR. KUVIN: 5 Q. She is a close friend of yours, is she not? 6 Q. When 13.8. was 15 years old and standing naked 6 A. I?m going to respond to that question the same '7 in front of you in your bathroom, did you tell her that 7 way I've responded to most of your other questions here 8 you could help her become a model? 8 today, Mr. Kuvin, which is, i intend to respond to all 9 MR. PIKE: Same objections, including 9 relevant questions regarding to this lawsuit; however, 3. foundation. 1 0 at the present time, my attorneys have counseled me I 1 1 THE WITNESS: Is it different than the last 1 1 cannot provide answers to any questions that may he 1 2 question? 1 2 relevant to this lawsuit. 1 must expect accept their 13 MR. KUVIN: Uh~huh. l. 3 advice or risk losing my 6th Amendment right to 14 MR. GOLDBERGBR: Just go ahead. 14 effective representation. Accordingly, I must assert my 1 5 THE WITNESS: Okay. I intend to respond to 3. 5 federal constitutional rights as guaranteed by the 5th, 1 6 all relevant questions pertaining to this lawsuit; 3. 6 6th and 14th Amendment to the United States 3.7 however, at the present time, my attorneys have 1 7 Constitution. 1 8 counseled me I cannot provide answers to any 1 8 Q. Ghislaine Maxwell has accompanied you to 9 questions that may be relevant to this lawsuit, so 19 numerous social events in the last few years; isn't that 2 0 I've answered most questions here today the same 2 0 true? 2 1 way. I must expect that -- accept their advice or 2 1 MR. PIKE: Form. 22 risk losing my 6th Amendment right to effective 22 THE I'm going to respond to that 2 3 repreSentation. Accordingly, I assert my federal 2 3 question the same way I?ve responded to most of 2 4 constitutional rights as guaranteed by the 5th, 6th 2 4 your questions here today, which is, i intend to 2 5 and l4th Amendment to the United States 2 5 respond to all relevant questions regarding your 3 (Pages 180 to 183) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeane Ricciuti (661-289-428-9381) Electronically signed by Jenna Ricciuti (601-280-428-9381) 34 3. Page 184 Page 186 1 lawsuit; however, at the present time, my attorneys 1 Constitution. 2 have counseled me i cannot provide answers to any 2 BY MR. KUVIN: 3 questions that may be relevant to that lawsuit. I 3 Q. Did Ms. Maxwell procure underaged girls for 4 must accept their advice or risk losing my 6th 4 you to have sexual relationships with? 5 Amendment right to effective representation. 5 A. I'm going to answer that question the same way 6 Accordingly, I must assert my?federal 6 I?ve answered most of your other questions today, 7 constitutional right as guaranteed by the 5th, 6th 7 Mr. Kuvin, which is, I intend to respond to all relevant 8 and 14th Amendment of the United States 8 questions regarding this lawsuit; however, at the 9 Constitution. 9 present time, my attorneys have counseled me I cannot 1 0 BY MR. 1 0 provide answers to any questions relevant to that 1 1 Q. One of your househoys that has been deposed in 1 1 lawsuit. Excuse me. I must accept their advice or risk 1 2 this case testified that you were a rather nice 1 2 losing my 6th Amendment right to effective 1 3 gentleman that used to talk to the staff, and that when 1 3 representation. Accordingly, I must assert my federal l. 4 Ms. Maxwell came into the picture, that you stopped 1 4 constitutional rights as guaranteed -- guaranteed by the 3.5 talking to the staff and the staff had to communicate 15 5th, 6th and 14th Amendments to the United States i. 6 through Ms. Maxwell. Do you agree or disagree with 6 Constitution. 1 7 that? 1 7 Q. Ms. Maxwell procured a particular underaged 3. 8 MR. PIKE: Form, foundation, predicate, 8 girl who worked at Donald Trump's Maralago, for you to 1 9 argumentative, assumes facts not in evidence. 1 9 have a sexual relationship with; isn't that true? 2 0 THE WITNESS: I?m going to answer that the 2 0 MR. PIKE: Form, argumentative, lacks i 2 1 same way live answered most of your questions here 2 appropriate predicate, foundation, assumes facts 22 today, which is, I intend to respond to all 22 not in evidence. 2 3 relevant questions regarding this lawsuit; however, 2 3 THE WITNESS: I'm going to reSpond to that the 2 4 at the present time, my attorneys have counseled me 2 4 same way I've responded to most of your other 2 5 that I cannot provide answers to any questions that 2 5 questions here today, Mr. Kuvin, which is, i intend page 185 Page 18? 1 may be relevant to your lawsuit. I must accept it to respond to all relevant questions regarding this 2 their advice or risk losing my 6th Amendment right 2 lawsuit; however, at the present time, my attorneys 3 to effective representation. Accordingly, I assert 3 have counseled me i cannot provide answers to any 4 my federal constitutional rights as guaranteed by 4 questions relevant to that lawsuit. 1 must accept i 5 the 5th, 6th and 14th Amendment of the United 5 their advice or risk losing my 6th Amendment right 6 States Constitution. 6 to effective representation. Therefore, 1 assert 7 BY MR. KUVIN: 7 my federal constitutional rights as guaranteed by 8 Q. He also testified that he felt you were a 8 the 5th, 6th and 14th Amendments to the United 9 rather normal guy until Ms. Maxwell came into the 9 States Constitution. 1 0 picture, and that she led you into this life of 10 BY MR. 1 perversion, sexual perversion. Do you agree with that? 11 Q. Do you know where Donald Trump's Maralago 12 MR. PIKE: Same objections. 2 estate is? 1 3 l?m going to respond to that the 13 A. Yes. 14 same way I've responded to most of your questions 14 Q. Have you been there? 15 here today, Mr. Kuvin, which is, intend to 15 A. Yes. 1 6 respond to all relevant questions regarding this 1 6 Q. Who with? 1 7 lawsuit; however, at the present time, my attorneys 1 '7 A. i?m going to have to answer that question the 1 8 have counseled me I cannot provide answers to any 1 8 same way l've answered most of your other questions here i 1 9 questions relevant to this lawsuit. I must accept 1 9 today. i intend to reSpond to all relevant questions 2 0 their advice or risk losing my 6th Amendment -- 2 0 regarding this lawsuit; however, at the present time, my 2 1 excuse me i must accept their advice or risk 2 1 attorneys have counseled me I cannot provide answers to 2 .2 losing my 6th Amendment right to effective 2 2 any questions that may be relevant to the same lawsuit. 2 3 representation. Accordingly, I must assert my 2 3 i must accept their advice or risk losing my 6th 2 4 federal constitutional rights as guaranteed by the 2 4 Amendment right to effective representation. 2 5 5th, 6th and 14th Amendment to the United States 2 5 Accordingly, i must assert my federal constitutional 4 (Pages 184 to 187) (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (561) 832?52506 Electronically signed by Joana Riccluti (601-280-428~9381) Electronically signed by Jeane Riccluti (601 480-428-9381) 34 Page 188 Page 190 1 rights as guaranteed by the 5th, 6th and l4th Amendment 1 same lawsuit. 1 must accept their advice or risk losing 2 to the United States Constitution. 2 my 62h Amendment right to effective representation. a 3 Q. Have you seen the high school transcripts 3 Accordingly, I must assert my federal constitutional 4 grades of. girls that you have had sexual relationships 4 rights as guaranteed by the 5th, 6th and 14th Amendment. 5 with dating back to 2005? 5 Q. Did you have photographs of girls under the 6 MR. EKE: Form, relevance, improper 6 age often who were nude, either partially or fully hypothetical, lacks facts assumes facts not in 7 nude, in your home on Palm Beach in 2005 and 2006? 8 evidence, lacks appropriate predicate, foundation. 8 MR. PIKE: Form. 9 THE WITNESS: for going to answer that 9 THE WITNESS: l'rn going to respond to that 1 0 question the same as i've answered most of your 1 0 question the same way l've responded to most of 1 other questions here today, Mr. Kuvin, which is, 1 3. your other questions, which is, intend to reSpond 3. 2 intend to respond to all relevant questions i. 2 to all relevant questions regarding this lawsuit; Ii. 3 regarding this lawsuit; however, at the present 1 3 however, at the present time, my attorneys have 1 4 time, my attorneys have counseled me that i cannot 4 counseled me cannot provide answers to any 1 5 provide answers to any questions that may he 1 5 questions relevant to this lawsuit. I must accept 1 6 relevant to this lawsuit. 1 must accept their 1 6 this advice or risk losing my 62h Amendment right 1 7 advice or risk losing my 6th Amendment right to 1 7 to effective representation. Accordingly, i assert 1 8 effective representation. Accordingly, assert my 1 8 my federal constitutional rights as guaranteed by 3. 9 federal constitutional rights as guaranteed by the 1 9 the 5th, 6th and 14th Amendments of the United 2 0 5th, 6th and 14th Amendment to the United States 2 0 States Constitution. 2 1 Constitution. 2 1 rue VIDEOGRAPHER: Mr. Kuvin, i'm sorry 1 have it 2 2 BY MR. KUVIN: 2 2 to change. 2 3 Q. Do you deny that the high school transcripts 2 3 MR. KUVIN: Go ahead. 2 4 which were found in your trash on Palm Beach that showed 2 4 THE VIDEOGRAPHER: We'll go off the record at 2 5 the ages of some of the girls you were engaged with 2 5 2:03. This will be the end of tape No. 2. Page 189 Page 191 3. sexual acts with at your home came from your house? 1 MR. GOLDBERGER: Break time? 2 MR. PIKE: Same objection in addition to 2 MR. KUVFNI N0, not again- Please mi- 3 argumentative and harassing, 3 Just let us know when you're good to go. 4 THE 1 intend to respond to all 63 THE VIDEOGRAPHER: We?re back on the record at 5 relevant questions regarding this lawsuit; however, 5 2g04- This Will be the beginning Ofiape NO- 3- 6 as l've done with most'of your other questions 6 BY MR. KUVIN: 7 today, at the present time my attorneys have 7 Q. Do you have security cameras throughout your 8 counseled me that i cannot provide answers to any 8 home on Palm 3680i} 9 of those questions relevant to this lawsuit. I 9 A- l'm 80ng 1'0 answer that question the same Way 3. 0 must accept their advice or risk losing my 6th 1 0 We answered most of your questions here today, 1 1 Amendment right to effective representation. 1 1 Mr. Kuvin. intend to respond to all relevant 2 Accordingly, I must assert my federal 3. 2 questions regarding this lawsuit; however, at the 1 3 constitutional rights as guaranteed by the 5th, 6th 1 3 present time, my attorneys have counseled me i cannot 4 and 14th Amendments to the United States 1 4 provide answers to any questions relevant to the fl 5 Constitution. 1 5 lawsuit. I must accept their advice or risk losing my 1 6 BY MR. KUVIN: 1 6 6th Amendment right to effective representation. 1 7 Q. Did you have numerous photos of nude young 3. 7 Accordingly, assert my federal constitutional rights 1 8 women, girls under the age of 18, back in your home .i 8 as guaranteed by the 5th, 6th and 14th Amendment Palm Beach Island in 2005 and 2006? 9 United States Constitution. 2 0 A. I?m going to have to respond to that question 2 0 (Plaintiffs EXhibit NO- ?0 was marked for 2 1 the same way i?ve responded to most of your questions 2 3. identification.) 2 2 here today, which is, l. intend to respond to all 2 2 MR. KUVIN: I?ll Show the camera a photograph 2 3 relevant questions regarding this lawsuit; however, at 2 3 here. Okay? 2 4 the present time, my attorneys have counseled me I 2 4 THE VIDEOGRAPHER: Lift it up. Yeah. there 2 5 cannot provide answers to any questions relevant to the 2 5 you go. Okay. oer-o3. 5 (Pages 188 to 191) (561) 832?7500 PROBE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jenna Ricciuti (601-2804289381) Electronically signed by Joana Ricciuti (601 480428-9381) Page 192 Page 194 1 MR. KUVIN: Okay? 1 effective representation. Accordingly, I must assert my 2 BY MR. 2 federal constitutional rights as guaranteed by the 5th, 3 Q. Let me show you what we marked as Plaintiffs 3 6th and 14th Amendment to the United States 4 Exhibit 10. Do you recognize this young lady? 4 Constitution. 5 A. Yes. 5 MR. PIKE: in addition, relevance. 6 Q. Who is she? 6 BY MR. 7 A. Her name is Joanna Shogert (phonetic). 7 Q. Do you pay Ms. Maxwell a salary? 8 Q. And who is she? 8 MR. PIKE: Form. 9 A. [just -- her name is Joanna Shogert. 9 BY MR. KUVIN: 10 Q. How do you recognize her? 1 Q. G'hislaine Maxwell, so we?re cleardon't understand the question. 1 1 her a salary? 12 Q. Well, is she a friend of yours? Did she work 1 2 A. I?d like -- exouse me. I'm going to answer 1 3 for yo How do you recognize her? 1 3 that question the same way I've anSWered most of your 14 A. How do I recognize her? 1 4 questions here today, which is, I intend to answer all 1 5 Well, I?d like to respond to that question 1 5 questions relevant to this lawsuit; however, at the 1 6 but, however, my attorneys have told me that i can?t 1 6 present time, my attorneys have counseled me I. cannot 1 7 respond to any questions today that may excuse me. i 1 7 provide answers to any questions relevant to this 1 8 intend to respond to all relevant questions regarding 1 8 lawsuit. 1 must accept their advice or risk losing my 1 9 this lawsuit; however, at the present time, my attorneys 1 9 6th Amendment right to effective representation. 2 0 have counseled me that I cannot provide answers to any 2 0 Accordingly, I assert my federal constitutional rights 2 1 questions relevant to this lawsuit. 1 must accept their 2 1 as guaranteed by the 5th, 6th and l4th Amendment to the 2 2 advice or risk losing my 6th Amendment right to 2 2 United States Constitution. 2 3 effective representation. Accordingly, I assert my 2 3 Q. Did you provide any underaged girls for sex to 2 4 federal constitutional rights as guaranteed by the 5th, 2 4 Prince Andrew? 2 5 6th and 14th Amendment to the United States 25 MR. PIKE: Form. Page 193 Page 195 1 Constitution. 1 THE WITNESS: i'm going to respond to that 2 Q. Did you have sex with Joanna Shogert? 2 question the same way I?ve responded to most of 3 A. I'm going to answer that question like I?ve 3 your questions here today, Mr. Kuvin, which is, I 4 answered most of your questions here today, which is, I 4 intend to respond to all relevant questions 5 intend to respond to all relevant questions regarding 5 regarding this lawsuit excuse me, however, at 6 this lawsuit; however, at the present time, my attorneys 6 the present time, my attorneys have counseled me I 7 have counseled me i cannot provide answers to any '7 cannot provide answers to any questions relevant to 8 questions relevant to this lawsuit. I must accept their 8 the lawsuit, or might be relevant to the lawsuit. 9 advice or risk losing my 6th Amendment right to 9 I must accept their advice or risk losing my 6th 1 0 effective representation. Accordingly, I assert my 1 0 Amendment right to effective representation. 1 1 federal constitutional rights as guaranteed by the 5th, 1. 1 Accordingly, I assert rny federal constitutional 2 6th and l4th Amendment to the United States 1 2 rights as guaranteed by the 5th, 6th and 14th 1 3 Constitution. 1 3 Amendment of the United States Constitution. 1 4 Q. When did you ?rst meet Prince Andrew? 1 4 BY MR. KUVIN: 15 And let me make it a compound question so I. 15 Q. Did you fly with Prince Andrew on your plane, 1 6 don?t have to repeat it over and over. When did you 1 6 or planes, with any underaged girls, girls under the age 1 "i first meet Prince Andrew, under what conditions did you 1 ?i of 18? 1 8 meet him, and who was present at that first meeting? 1 8 A. I'm going to answer that question the same way 1 9 A. I'm going to answer that question as I?ve done 1 9 l?ve answered all the other questions here today, 2 0 most of your questions here today, Mr. Kuvin, which is, 2 virtually, which is, I intend to respond to all relevant 2 1 i intend to respond to all relevant questions regarding 2 1 questions regarding this lawsuit; however, at the 2 2 this lawsuit; however, at the present time, my attorneys 2 2 present time, my attorneys have counseled me 1 cannot 2 3 have counseled me I cannot provide answers to any 2 3 provide anSWers to any questions relevant to the 2 4 questions relevant to that lawsuit. I must accept their 2 4 lawsuit. 1. must accept their advice or risk losing my 2 5 advice or risk losing my 6th Amendment right to 2 5 6th Amendment right to effective representation. . main .- 6 (Pages 192 to 195) (561) 832*7500 PROBE COURT REPORTING AGENCY, INC. (563.) 83247506 Electronically signed by Jeane Ricciuti (601-2804283381) Electronically signed by Jeane Ricciuti {601-280428-9381) 34 Page 196 Page 198 1 Accordingly, I must assert my federal constitutional 1 guarantee m- guaranteed by the 5th, 6th and 14th 2 rights as guaranteed by the 5th, 6th and 14th Amendments 2 Amendment to the United States Constitution. 3 to the United States Constitution. 3 (Plaintiff?s Exhibit No. 12 was marked for 4 Q. Do you know Christine Drangshoit? 4 identi?cation.) 5 MR. KUVIN: For the court reporter, it's 5 MR. KUVIN: Let me show to the camera what 6 we?ve marked as Exhibit 12. '7 THE WITNESS: I intend to respond to all 7 BY MR. KUVIN: 8 relevant questions regarding this lawsuit; however, 8 Q. Let me show you what l've marked as Exhibit 9 at the present time, my attorneys have counseled me 9 12. Do you recognize any of the girls in that 1 I cannot provide answers to any questions relevant 1 0 photograph? 1 1 to the lawsuit. 1 must accept this advice or risk 1 1 A. I'm going to answer that question the same way 1 2 losing my 6th Amendment right to effective 1 2 i?ve answered most of your other questions here today, 1 3 representation. Accordingly, assert my federal 1 3 Mr. Kuvin, which is, i intend to respond to all relevant 4 constitutional rights as guaranteed by the 5th, 6th 1 4 questions regarding this lawsuit; however, at the 1 5 and 14th Amendments to the United States 1 5 present time, my attorneys have counseled me that I 1 6 Constitution. 1 6 cannot provide answers to any questions that may he 1 7 MR. Let me show the camera what we?ll 1 '7 relevant to the lawsuit. I must accept their advice or 1 8 mark as Exhibit 1 1. 3. 8 risk losing my 6th Amendment right to effective 1 9 (Plaintiffs Exhibit No. ll was marked for i 9 representation. Accordingly, I assert my federal 2 0 identification.) 2 constitutional rights as guaranteed by the 5th, 6th and 2 1 THE VIDEOGRAPHER: Okay. 2 1 14th Amendment to the United States Constitution. 2 2 MR. xuvrn: Okay? .2 2 Q. Sir, isn't it true that in what we've marked 2 3 BY MR. KUVIN: 2 3 as Plaintiff's Exhibit 12, the blond standing on the 2 4 Q. in Exhibit ll, sir, you're standing with a 2 4 left is Nadia Marcinkova, and the blends, dirty blonde 2 5 woman. Who is that woman in that photograph? 25 standing on the right is Sarah Kellen? Page 197 Page 199 1 A. Eula Maxwell (phonetic). A. I intend to respond to all relevant questions 2 Q. Where were you? 2 regarding this lawsuit; however, as I've done to most of 3 A. i' intend to respond to all relevant questions 3 the questions at the present time, my attorneys have 4 regarding this lawsuit; however, at the present time, my 4 counseled me that I cannot provide answers to any of 5 attorneys have counseled me I cannot provide answers to 5 those questions that may be relevant to the lawsuit. I 6 any questions that may be relevant to this lawsuit. 1 6 must accept this advice or risk losing my 6th Amendment '7 must accept this advice or risk losing my 6th Amendment 7 right to effective representation. Accordingly, 8 right to effective representation. Accordingly, I must 8 assert my federal constitutional rights as guaranteed by 9 assert my federal constitutional rights as guaranteed by 9 the 5th, 6th and 14th Amendments of the United States 1 the 5th, 6th and 14th Amendments to the United States 1 0 Constitution. 11 Constitution. 3. 1. BY MR. KUVIN: 12 MR. And just so the court reporter 12 Q. I?m going to Show you what we?ll mark as 1 3 knows, Ghislaine is spelled 1 3 Exhibit 13. Let me Show it to the camera, first. 4 BY MR. l. 4 (Plaintiff?s Exhibit No. l3 was marked for 5 Q. Who is Nadia Marinkova Marcinkova, excuse 1 5 identi?cationMR. xuer: 1 7 A. I?m going to answer that question the same way 17 Q. Sir, is it true that Exhibit 13 shows your 1 8 I've answered most of your questions here today, which 1 8 personal assistant, Sarah Kellen? 1 9 is, I intend to respond to all relevant questions 1 9 A. intend to reSpond to all relevant questions 2 0 regarding this lawsuit; however, at the present time, my 2 0 regarding this lawsuit; however, at the present time, my 2 attorneys have counseled me I cannot provide answers to 2 1 attorneys have counseled me that I cannot provide 2 2 any questions relevant to the lawsuit. I must accept 2 2 answers to any questions that may be relevant to this 2 3 their advice or risk losing my 6th Amendment right to 2 3 lawsuit. I must accept their advice or risk losing my 2 4 effective representation. Excuse me. Accordingly, I 2 4 6th Amendment right to effective representation. 2 5 must assert my federal constitutional rights as 2 5 Accordingly, i assert my federal constitutional rights 7 (Pages 196 to 199) (561) 832-7500 PROBE COURT REPORTING AGENCY, INC. (561) 832-57506 Electronically signed by Jeane Ricciuti (601?2804286381) Electronically signed by Joana Ricciuti (601*280428~9381) Page 200 Page 202 1 as guaranteed by the 5th, 6th and 14th Amendment to the marked as Exhibit 16. 2 - United States Constitution. 2 er MR. KUVIN: 3 Q. Let me show you what we?ii mark as Exhibit 14. 3 Q. Do you recognize the gentleman in that 4 (Piaintifi?s Exhibit No. 14 was marked for 4 photograph, sir? 5 identi?cation.) 5 MR. PIKE: Hoid on for a second. 6 BY MR. KUVIN: 6 MR. GOLDBERGER: Do you want to discuss it 7 Q. Sir, does Exhibit 14 show Nadia Marcinkova, a 7 with me? 8 girl that you have had a sexual reiationship with since 8 MR. PIKE: Let?s take a break for one minute. 9 before she was I8 years old? 9 MR. KEVIN: All right. i 1 0 MR. PIKE: Form, argumentative, harassing, 0 THE VIDEOGRAPHER: Off the record at 2: 16. 1 1 assumes facts not in evidence, lacks appropriate 1 (A brief recess was taken.) 1 2 predicate and foundation. 1 2 THE VIDEOGRAPHER: We?re back on the record at 13 THE WITNESS: i intend to respond to ali 13 2:45. 1 4 reievant questions regarding this lawsuit; however, 1 4 BY MR. KUVIN: 1 5 at the present time, my attorneys have counseied me 1 5 Q. Okay. Do you recognize the person that's 1 6 i cannot provide answers to any questions relevant 1 6 shown in Exhibit 16? 1 7 to this iawsuit. i must accept their advice or 1 7 A. Yes. 1 8 risk iosing my 6th Amendment right to effective 1 8 Q. Who is that? 1 9 representation. Accordingiy, i assert my federal 1 9 A. Prince Andrew. 2 constitutionai rights as guaranteed by the 5thyou know Prince Andrew? 2 1 and 14th Amendment to the United States 2 1 A. i'm going to have to respond to that question 2 2 Constitution. 22 the same way We responded to most of your questions 2 3 BY MR. KUVIN: 2 3 here today, Mr. Kevin, which is, I intend to respond to 2 4 Q. I'm going to show the camera what we?ii mark 2 4 all reievant questions regarding this lawsuit; however, 2 5 as Exhibit 15. 2 5 at the present time, my attorneys have counseled me I Page 201 Page 203 1 (Plaintiffs Exhibit No. 15 was marked for 1 cannot provide answers to any questions relevant to this 2 identi?cation.) 2 lawsuit. 1 must accept their advice or risk losing my 3 BY MR. KUVIN: 3 6th Amendment right to effective representation. 4 Q. Sir, does Exhibit 15 show Haley Robson, an 4 Accordingly, I assert my federai constitutionai rights 5 underaged giri that you were back in 2005 and 5 as guaranteed by the 5th, 6th and 14th Amendment to the 6 2006 to procure other underaged girls for sex and sexual 6 United States Constitution. 7 contact at your home? 7 Q. I?m going to show you a document that we'ii 8 MR. PIKE: Same objections to Exhibit IS as 8 mark as Exhibit 17. 9 were made to Exhibit i4. 9 MR. PIKE: Thank you. i. 0 THE WITNESS: I?m going to answer that the 10 (Piaintifi's Exhibit No. i7 was marked for 1 1 same way I've answered most of your questions here 1 3. identification.) 1 2 today, Mr. Kuvin, which is, i intend to reapond to 12 BY MR. 1 3 ail reievant questions regarding this iawsuit; 13 Q. I'm going to give you a minute to take a look i. 4 however, at the present time, my attorneys have i. 4 at that document and just teii me when you're ready to 1 5 counseled me that I cannot provide answers to any 1 5 answer any questions about it. 1 6 questions that may be relevant to the lawsuit. 1. 6 A. Okay. 17 must accept their advice or risk losing my 6th 17 Q. Okay. First of aii, have you seen this ietter 8 Amendment right to effective representation. 3. 8 before? 1 9 Accordingly, I am going to assert my federai 19 MR. GOLDBERGER: Attorney~client priviiege, 2 constitutionai rights as guaranteed by the 5th, 6th 2 0 work product. 2 1 and 14th Amendments to the United States 2 1 BY MR. KUVIN: 2 2 Constitution. 2 2 Q. Have you seen this letter before outside of 2 3 (Plaintiff?s Exhibit No. 1.6 was marked for 2 3 the reiationship with your attorneys? 2 4 identi?cation.) 2 4 MR. GOLDBERGER: You can answer that question. 2 5 MR. KUVIN: Let me show the camera what We?ve 2 a run WITNESS: No. 8 (Pages 200 to 203) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronicaiiy signed by Jeane Ricciuti Electronicaiiy signed by Jeane Ricciuti 480-423-9381) Page 204 Page 206 1 BY MR. KUVIN: 1 BY MR. KUVIN: 2 Q. Do you know Chief of Poiice Michael Reiter? 2 Q. How long were you there? 3 Do you know who he is? 3 A. 13 months, approximately. a A. I know who he is. 4 Q. All right. And ofthose 13 months, how many 5 Q. Do you know State Attorney Barry Krischer? 5 months were you there where you had to stay there 24 i 6 A. I know who he is. 6 hours a day? 7 Q. Did you ever speak with Chief of i?olice 7 A. i don't recall speci?cally. 8 Michael Reiter in the past? 8 Q. More than a month? 9 A. I don?t remember. 9 A. Yes. 1 Q. Did you ever talk to anyone, either at the 1 0 Q. More than two months? 1 1 State Attorney?s of?ce, yourself, or Michael Reiter 1 1 A. Yes. 1 2 about the prosecution of your claim without the presence 1 2 Q. More than three months? :l 1 3 of your attorneys? 1 3 A. YesMore than four? 3 1 5 Q. Did you ever talk to any of the police that 1 5 A. i think so, I don't remember. 1 6 worked for the Town of Paim Beach without the presence 1 6 Q. Do you recall when you were provided work 1 7 of your attorneys? 3. 7 release, when you were able to ieave during the daylight 1 8 A. Explain -- 1 8 hours? 1 9 MR. PIKE: Wait one second. 19 A. Not with speci?city. 2 0 THE WITNESS: I?m sorry. 2 0 Q. While you were there at the jail in Pain: 2 3. MR. PIKE: Can you state the question again? 2 1 Beach i?m going to show you what we?il mark as 22 MR. Sure. 22 Exhibit 18. 2 3 BY MR. KUVIN: 2 3 (Plaintiffs Exhibit No. 1.8 was marked for 2.4 Q. Did you ever speak to any of the police 2 4 identification.) 2 5 of?cers that worked for the Town of Palm Beach without 2 5 Page 205 Page 207 3. the presence of your attorneys? 1 BY MR. 2 MR. GOLDBERGER: Is the question, have you 2 Q. Did you purchase items from the jail? 3 ever spoken to a Town of Paim Beach police of?cer? 3 MR. GOLDBERGER: Hang on a second. 4 Is that the can we rephrase it like that? 4 MR. PIKE: Hold on one second. 5 MR. KUVIN: Sure. 5 THE WITNESS: It looks that way, yes, sir. 6 MR. Okay. 6 BY MR. KUVIN: 7 THE WITNESS: i've been stopped by the poiice '7 Q. Okay. 8 for traf?c violations, if that's what you mean. 8 MR. And the document speaks for itself, 9 BY MR. KUVIN: 9 the composite document speaks for itseif. 3. Q. Any other times that you had conversations 1 0 BY MR. KUVIN: 3. 1 with any of the Town of Rain: Beach 1 1 Q. i?d like you to take a look at Exhibit 18. it 12 A. No. 12 shows purchases weil, does it show purchases by you? 13 Q. -- police officers? 1 3 MR. Asked and answered. 14 A. Not that 1 recaii speci?cally. 1 4 THE Yes. 15 Q. Okay. Now, you were housed at the?iaii after 1 5 BY MR. KUVIN: 1 6 your plea of guilty that we had spoke about at the 6 Q. Okay. And it appears those purchases took 17 beginning of your deposition; is that correct? 17 place from 7/ 8/08 through 9/30/08 is the last one that i 1 8 MR. PIKE: Form. 1 8 have; is that correct? 1 9 THE WITNESS: Say it again. 1 9 MR. The document speaks for itself. 2 0 BY MR. KUVIN: 2 0 BY MR. KUVIN: 2 1 Q. Yes. You were housed at the locai jail here 2 1 Q. You can answer. 2 2 in Palm Beach County after your plea of guilty that we 2 2 A. The document Speaks for itself. 2 3 spoke about at the beginning of your deposition? 2 3 Q. Is that correct, the iast date is 9/30/08? 2 4 MR. PIKE: Form. 2 4 A. The last date here is 9/30, yes. 2 5 THE WITNESS: Yes. 2 5 MR. PIKE: With regard to what you provided to 9 (Pages 204 to 207) (563.) 832?7500 PROSE COURT REPORTING AGENCY, INC. 832*7506 Electronically signed by Jeane Ricoiuti (601-280-428~9381) Etectrontcaity signed by Jeane Ricctuti (601-280-428~9381) Page 208 Page 210" i 1 the witness. 1 MR. PIKE: Asked and answered. 2 MR. KUVIN: Sure, absolutely. 2 THE WITNESS: So should I answer? 3 THE WITNESS: Okay. 3 MR. PIKE: You can answer again. 4 BY MR. KUVIN: 4 THE WITNESS: Ask the question again. 5 Q. And just so we're clear, this composite 5 BY MR. KUVIN: 6 exhibit that we've marked as Exhibit l8 contains 6 Q. So can we assume that all of the items that 7 purchases from 7/8/08, 7/ 15, 7/22, 7/29, 8/5, 8/i2, 7 are shown in these receipts were either used by you or 8 8/21, 8/26, 9/2, 9/9, 9/23 and so the record 8 thrown away? 9 is clear; there is no question. 9 A. I don't even know if I received some of those 1 A. Okay. 1 0 items, so I would assume I used most of them. 1 1 Q. Okay? 1 1 Q. Okay. 12 A. Uh~huh. 1 2 A. Okay? 1 3 Q. All right. These items that you purchased, 1 3 Q. Sure. Take a look, Ijust want to make sure, 14 did you utilize all of these items yourself? 1 4 did you receive all these items? IL 5 MR. PIKE: Form, relevance. 1 5 A. I don't know. 1 6 THE WITNESS: I don?t understand the question. 1 6 MR. PIKE: Asked and answered. 1 7 BY MR. KUVIN: 1 7 BY MR. KUVIN: 18 Q. Well, you purchased a number of items that are 3.8 Q. How did you purchase them? 1 9 shown in this receipt. 1 9 A. I filled out a form. 2 A. Yes. 2 0 Q. And how were they provided to you? 2 3. Q. The question is: Did you use them yourself? 2 1 MR. PIKE: Form. 2 2 MR. PIKE: Same objection. 22 THE Sometimes they would come in a 2 3 THE WITNESS: I don't know if i used all of 2 3 bag. 2 4 them, 2 4 BY MR. KUVIN: 2 5 2 5 Q. Okay. And did you determine whether or not Page 209 Page 211 1 BY MR. KUVIN: 1 the form you filled out, the information or the product 2 Q. Well, what did you do with the items that you 2 that you put on that form actually was provided? 3 purchased? 3 A. No, never. 4 MR. PIKE: Form, overbroad. 4 Q. If we look at the items that are contained 5 BY MR. KUVIN: 5 within these receipts, I'd like you to go, if you would, 6 Q. You can answer. 6 to the second invoice here dated 7/15/08. The third 7 A. I used some, I threw away some. 7 item down is a Luhriderrn lotion. 8 Q. Did you give any away? 8 A. Yes. 9 A. Not that i remember. 9 Q. Do you see that? 10 MR. Same objection. 1 A. Yes. 1 3. BY MR. KUVIN: 1 1 Q. Did you purchase that? 12 Q. Did you provide any items that you purchased 12 A. It appears so. 13 to other inmates while you were there in jail? 1 3 Q. Did you receive it? 14 MR. PIKE: Form. 14 A. ldon't remember. 1 5 THE WITNESS: Not to the best of my 1 5 Q. Did you use the Lubriderm lotion that you 1 6 recollection. 1 6 receiv or that you may have received in jail? 17 BY MR. KUVIN: 17 MR. PIKE: Form. 1 8 Q. Okay. With respect to all of the items that 8 BY MR. KEVIN: 9 are listed in these receipts, is it a safe assumption 1 9 Q. Let me strike that and roast; it. 2 that you either used them yourself or threw them away? 2. A. Okay. 2 1 MR. PIKE: Asked and answered. If you don?t 2 1 Q. Did you use the Lubriderrn lotion which you had 2 2 know if you know. 2 2 purchased from thejail while you were there? 2 3 THE WITNESS: I. don?t know. 2 3 A. I might have. 2 4 BY MR. KUVIN: 2 4 Q. What for? 2 5 Q. I?m sorry? i didn't hear you. 25 A. To moisturize my hands and face. 10 (Pages 208 to 211) (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 Electronically signed by Joana Ricciuti (601-280-428-9381) Electronically signed by Joana Ricciuti (601-289428-9381) 34 Page 212 Page 214 1 Q. Okay. Did you use Lubriderm lotion while you I 1 Q. How do you know you definitely did not use it? 2 were injail to masturbate at all? 2 A. Because it was not -- anything that said hand 3 A. No. 3 lotion I. did not use, i threw in the garbage 4 MR. BIKE: Form objection, harassing. 4 Q. Why is that? 5 THE WIKNESS: Absoiuteiy not. 5 A. Because it wasn't something that i had 6 BY MR. KUVIN: 6 ordered. 7 Q. It appears, if you would turn to 7/29/08, 7 MR. PIKE: Can I -- can Ijust have an 8 which is approximately two weeks iater, and the second 8 agreement that the objections to this line of 9 thing down is another bottle of Lubriderm lotion. Do 9 questioning is irrelevant, so I don't have to 1 0 you see that? 0 MR. KUVIN: Sure. 11 A. Yes. 11 MR. PIKE: interrupt. 12 Q. What did you use that for? 12 MR. KUVIN: Sure. 1 3 MR. PIKE: Asked and answered. 13 MR. PIKE: Agreed? 1 4 MR. KUVIN: It's a second bottle. 14 MR. Agreed. 15 MR. It?s the same question, Spencer. 15 BY MR. KUVINsomething rcievant? 1 6 Q. Let's turn again to 9/30/08, the last invoice 1? THE WITNESS: No probiem. 17 in there. 18 MR. BIKE: He can answer. 1 8 A. Yes. 1 9 THE WITNESS: My hands and my face. 1 9 Q. Do you see there is an entry for two more 2 0 BY MR. KUVIN: 2 0 bottles of hand lotion. Do you see that? 2 1 Q. Okay. 2 1 A. Correct. 22 A. I believe the ?rst bottle went missing. 22 Q. What did you do with those? 2 3 Q. If we turn to approximately one month later on 2 3 A. To the best of my knowledge, I threw them 2 4 8/21/08, do you have that one? 2 4 right away. 2 5 A. Yes. 2 5 Q. You didn?t use them for anything? Page 213 Page 215 1 Q. All right. On that occasion, you bought two 1 A. No. 2 bottles of hand lotion again. 2 Q. is it your testimony here today that you did 3 A, Yes. 3 not use any of the bottles of hand iotion or Lubriderm 4 Q. What did you use those for? 4 iotion that we had previousiyjust gone through to 5 A. Nothing. 5 masturbate while you were in jail? 6 Q. What did you do with them? 6 A. That's correct. 7 A. They were bought by accident. 7 Q. Did Ghisiaine Maxwell visit you in jail? 8 Q. How did you buy them by accident? 8 A. No. 9 A. Because you ?ll out a check form and 9 Q. Did Nadia Marcinkova visit you while you were 10 sometimes the forms don?t make any sense, they just 1 0 injaii? 1 1 deliver in other things, 1 1 A. I intend to respond to all relevant questions 12 Q. Sir, did you get those two bottles? 12 regarding this iawsuit; however, at the present time, my 13 A, Yes, Yes_ 1 3 attorneys have counseled me i cannot provide answers to 4 Q. And you never used them? 1 4 any questions relevant to this iawsuit. {must accept 1 5 A, No, I threw them away, 1 5 this advice or risk losing my 6th Amendment right to 1 6 Q. Okay. if we turn to 9/9/08, do you see that 1 6 effective representation. Accordingly, assert my 1 7 entry? 1 7 federai constitutional rights as guaranteed by the 5th, 1 8 A, Yes_ 1 8 6th and 14th Amendment to the United States 1 9 Q. All right. And another invoice here, on that 1 9 Constitution. 2 0 date a bottle of hand lotion, do you see that? 2 0 Q. Did you have sex with Nadia Marcinkova while 2 1 A, Yes, i do, 2 1 you were housed at the Palm Beachjail facilityMR. PIKE: Form. 2 3 A, 1 don?t know, 2 3 THE WITNESS: I intend to respond to ail 2 4 Q. Do you know if you used it? 2 4 relevant questions regarding this lawsuit; however, 2 5 A. De?nitely not. 2 5 at the present time, my attorneys have counseled rue . 11 (Pages 212 to 215) (561} 832-37500 COURT AGENCY, INC. (561) 832?7506 Eiectronicaily signed by Joana Riceiuti Eiectronicaliy signed by Joana Riceiuti (601 480-428-9381) Page 216 Page 218 1 I cannot provide answers to any questions relevant 1 5th, 6th and 14th Amendment to the United States 2 to this lawsuit. As I've answered most of your 2 Constitution. Excuse me. 3 question today, Mr. Kuvin, I must accept this 3 MR. KUVIN: This is 19. 4 advice or risk losing my 6th Amendment right to 4 (Plaintiff's Exhibit No. 19 was marked for 5 effective representation. Accordingly, I assert my 5 identi?cation.) 6 federal constitutional rights as guaranteed by the 6 BY MR. KUVIN: 7 5th, 6th and l4th Amendments to the United States 7 Q. I have an FAA registry for a Boeing 727, 8 Constitution. 8 manufacture year 1969, with i?m just looking for the 9 BY MR. 9 tail number here. I'm sorry, I'm just trying to ?nd 1 Q. Did you pay girls so that they would not 1 the tail number. 1 testify against you in the civil proceedings that have 1 1 A. Not a problem. 1 2 been ?led in both Federal and State Court? 1 2 Q. Let?s do this, it's a Mode Code 53106661. 1 3 MR. PIKE: Form. 1 3 I'll show this to your counsel first. 4 THE WITNESS: Okay. Like most of your other 1 4 Here it is, I'm sorry, Tail No. 5 questions here today, Mr. Kuvin, I'm going to 5 There?s no question pendingjust yet. 1 6 respond by saying I intend to respond to all 3. 6 MR. PIKE: Thank you. relevant questions regarding this lawsuit; however, 1 7 Okay. 8 at the present time, my attorneys have counseled me 1 8 BY MR. KUVIN: 9 I cannot provide answers to any questions relevant 9 Q. Let me show you what we marked as Exhibit ?19. 2 to this lawsuit. I must accept this advice or risk 2 0 I?ll give you a minute to take a look at that. 2 losing my 6th Amendment right to effective 2 1 A. Okay. 2 2 representation. Accordingly, I must assert my 22 Q. What is 3A -- EGE, inc? 2 3 federal constitutional rights as guaranteed by the 2 3 A. intend to reSpond to all relevant questions 2 4 5th, 6th and 14th Amendments to the United States 2 4 regarding this lawsuit; however, at the present time, my 2 5 Constitution. 2 5 attorneys have counseled me I cannot provide answers to Page 217 Page 219 1 BY MR. KUVIN: 1 any questions relevant to this lawsuit. i must accept 2 Q. Did you have sex with Nadia Marcinkova when 2 this advice or risk losing my 6th Amendment right to 3 she was under the age of 14? 3 effective representation. Accordingly, as I've done 4 MR. Form. 4 with most of your questions, I must assert my federal 5 THE WITNESS: I. intend to respond to all 5 constitutional rights as guaranteed by the 5th, 6th and 6 relevant questions regarding this lawsuit; however, 6 14th Amendment to the United States Constitution. '7 at the present time, my attorneys have counseled me 7 Q. Mr. Epstein, are you aware that after 8 I cannot provide answers to any questions relevant 8 September 11, 2001 that the Federal Government started 9 to this lawsuit. 1 must accept this advice or risk 9 tracking all flights of all public and private aircraft? 3.0 losing my 6th Amendment right to effective 1 0 MR. Form, relevance. 3t 1 representation. Accordingly, i must assert my 1 1 BY MR. KUVIN: 2 federal constitutional rights as guaranteed by the l. 2 Q. Are you aware of that? 13 5th, 6th and l4th Amendment to the ConstitutionOkay. Are you aware that the FAA keeps track 15 Q. Did you tell people that Nadia Marcinltova was 1 5 of all flights that are made both within the continental 6 your sex slave? 6 US and from the continental US abroad? MR. PIKE: Same objection. 1 7 MR. PIKE: Same objection. 1 8 rue I intend to respond to all 1 8 THE Witness: No. 1 9 relevant questions regarding this lawsuit; howover, 9 BY MR. 2 at the present time, my attorneys have counseled me 20 Q. Do you know whether cannot provide answers to any questions relevant .2 1 this way: Have you evor seen the ?ight tracking 2 2 to this lawsuit. I must accept this advice or risk 2 2 information for any planes that you may own? 2 3 losing my 6th Amendment right to effective 2 3 A. i don?t believe so. 2 4 representation. Accordingly, i must assert my 2 4 Q. Is JEGE, inc. a company that is owned by you? 2 5 federal constitutional rights as guaranteed by the 2 5 A. I'll have to answer that question the way I?ve 12 (Pages 216 to 219) (561) 832*7500 COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Joana Ricciuti (601?2804283381) Electronically signed by Joana Ricciuti (601-2804289381) 34 Page 220 Page 222 answered most of your other questions here today, which 1 federal constitutional rights 33 guaranteed by the 2 is, intend to respond to all relevant questions 2 5th, 6th and 14th Amendment to the United States 3 regarding this lawsuit; however, at the present time, my 3 Constitution. 4 attorneys have counseled me I cannot provide answers to 4 BY MR. 5 any questions relevant to this lawsuit. I must accept 5 Q. isn't it true that you went to Thailand in 6 this advice or risk losing my 6th Amendment right to 6 2001 so that you could engage in sexual relations with 7 effective representation. Accordingly, i assert my 7 girls under the age of l6 with Prince Andrew without any 8 federal constitutional rights as guaranteed by the 5th, 8 fear of any legal recourse? 9 6th and 14th Amendment to the United States 9 MR. PIKE: Same objection. in addition. 1 0 Constitution 1 improper hypothetical, lack of predicate, 1 1 Q. The plane that is identified in the FAA foundation, argumentative, harassing. 1 2 registry in the document marked Exhibit 19, just so 1 2 THE WITNESS: intend l0 respond to All 1 3 we're clear, because I don't think I asked it exactly, 1 3 relevant questions regarding this lawsuit; however, 1 4 but is this your plane? 1 a at the present time, my attorneys have counseled me 1 5 A. I'm going to answer that question the same way 1 5 i cannot provide answers to any questions relevant 1 6 i?ve answered most of your questions today, Mr. Kuvin, 1 6 to this lawsuit. i must accept this advice or risk 1 7 which is, I intend to respond to all relevant questions 1 7 losing my 6th Amendment right to effective 1 8 regarding this lawsuit; however, at the present time, my 1 8 representation. Accordingly, I must assert my 1 9 attorneys have counseled me i cannot provide answers to 9 federal constitutional rights as guaranteed by the 2 0 any questions relevant to this lawsuit. 1 must accept 2 0 5th, 6th and 14th Amendment to the United States 2 3. this advice or risk losing my 6th Amendment right to 2 1 Constitution. 22 effective representation. Accordingly, I assert my 22 BY MR. KUVIN: 2 3 federal constitutional rights as guaranteed by the 5th, 2 3 Q. Have you seen the photographs of you and 2 4 6th and 14th Amendment to the United States 2 4 Prince Andrew while you were in Thailand with half naked 2 5 Constitution_ 25 women, some of which were under the age of 16?? Page 221 Page 223 1 Q. Isn't is true, sir, that you flew to Thailand 1 MR. PIKE: Same objections. 2 in 2001? 2 THE WITNESS: I intend 3 MR. PIKE: Form. 3 MR. PIKE: Relevance as well, excuse me. I'm 4 THE WITNESS: I intend to respond to all 4 sorry. 5 relevant questions regarding this lawsuit; however, 5 THE WITNESS: I intend to respond to all 6 at the present time, my attorneys have counseled me 6 relevant questions regarding this lawsuit; however, 7 I cannot provide answers to any questions relevant 7 at the present time, my attorneys have counseled me 8 to this lawsuit. I must accept this advice or risk 8 i cannot provide answers to any questions relevant 9 losing my 6th Amendment right to effective 9 to this lawsuit. i must accept this advice or risk 10 representation. Accordingly, assert rny federal 1 losing my 6th Amendment right to effective 1 2i constitutional rights as guaranteed by the 5th, 6th 1 1 representation. Accordingly, i assert my federal 1 2 and 14th Amendment to the United States 1 2 constitutional rights as guaranteed by the 5th, 6th 1 3 Constitution. 1 3 and 14th Amendments to the United States 1 4 BY MR. KUVIN: 1 4 Constitution. 16 Q. is a true that you went to Thailand in 2001 1 5 av MR. KUVIN: i. 6 with Prince Andrew? 1 6 Q. Did you bring any young women on the plane 17 MR. PIKE: Form. 17 with you when you went to Thailand in 2001? 1 8 THE WITNESS: I. intend to respond to all 1 8 MR. PIKE: Same objection. 1 9 relevant questions regarding this lawsuit; however, 1 9 THE WITNESS: I intend to respond to all 2 at the present time, my attorneys have counseled me 2 0 relevant questions regarding this lawsuit; however, 2 1 i cannot provide answers to any questions relevant 2 1 at the present time, my attorneys have counseled me 2 2 to this lawsuit, and as I?ve done for most of all 2 2 I cannot provide answers to any questions relevant 2 3 your questions today, Mr. Kuvin, I must accept this 2 3 to this lawsuit. 1 must accept this advice or risk 2 4 advice or risk losing my 6th Amendment right to 2 4 losing my 6th Amendment right to effective 2 5 effective representation. Accordingly, assert my 2 5 representation. Accordingly, I assort my federal 13 (Pages 220 to 223) (563.) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeane Ricciuti {601-280-428v9381) Electronically signed by Jeane Ricciuti (604-280-428-9381) Page 224 Page 226 3. constitutional rights as guaranteed by the 5th, 6th 1 Q. Yeah. Capital M, capital C, number 2; sound 2 and 14th Amendments to the United States 2 familiar at all? 3 ConstitutionOkay. Are you part owner in a teen modeling Q. Have you bragged to people before that you 5 agency? 6 bought brought Nadia Marcinkova to the United States 6 A. No. 7 to be your Yugoslavian sex slave? 7 Q. Do you own any Interest in any modeling 8 A. i intend to respond to all relevant questions 8 agencies currently? 9 regarding this lawsuit; however, at the present time, my 9 A. intend to respond to all relevant questions 0 attorneys have counseled me I cannot provide answers to 3 0 regarding this lawsuit; however, at the present time, my 1 any questions relevant to this lawsuit. i must accept 3 1 attorneys have counseled me I cannot provide answers to 1 2 their advice or risk losing my 6th Amendment right to 1 2 any questions relevant to this lawsuit. 1 must accept 1 3 effective representation. Accordingly, i must assert my 1 3 this advice or risk losing my 6th Amendment right to 3 4 federal constitutional rights as guaranteed by the 5th, 1 4 effective representation. Accordingly, assert my 3. 5 6th and 14th Amendments to the United States 1 5 federal constitutional rights as guaranteed by the 5th, 1 6 Constitution. 1 6 6th and 14th Amendments to the United States 1 7 Q. Have you had 3. 7 Constitution. 3. 8 MR. GOLDBERGER: You raised the same objection 3 8 Q. Do you know what a sexual device called a Twin 3. 9 to that question, right? 3 9 Torpedo is? 2 0 MR. PIKE: Yeah, i did. 2 0 MR. PIKE: Same objections, irrelevant as 2 3. BY MR. KUVIN: 2 3. worded. 2 2 Q. Have you had sex with numerous girls under the 2 2 THE WITNESS: Would you like to ask me a bunch 2 3 age of 18 in the presence of Nadia Marcinlcova? 2 3 of questions or are we going to do you want to 2 4 MR. PIKE: Same objections. 2 4 individual answers to these? Do you want a 2 5 THE WITNESS: I'm going to answer that the 2 5 compound question? Page 225 Page 22? 1 same way i've answered most of your questions here 1 BY MR. KUVIN: 2 today, Mr. Kevin, which is, I intend to respond that way, it doesn't matter to me. 3 all relevant questions regarding this lawsuit; 3 THE WETNESS: It's up to you. 4 however, at the present time, my attorneys have 4 MR. KUVIN: it?s up to you guys. 5 counseled me I cannot provide answers to any 5 MR. PIKE: As i?ve said, Mr. Kuvin, if you 6 questions relevant to the lawsuit. i must accept 6 want to limit the time that we Spend here today and 7 their advice or risk losing my 6th Amendment right 7 ask a compound question if you're going to list 8 to effective representation. Accordingly, I assert 8 various items or list individuals by name and ask 9 my federal constitutional rights as guaranteed by 9 questions, I won't have a compound objection to 1 the 5th, 6th and 14th Amendments to the United 3.0 that type of inquiry if it?s in light of attempting 1 1 States Constitution. 1 1 to save time. 12 BY MR. KUVIN: 12 MR. KUVIN: Sure. 13 Q. What is 1 3 BY MR. 14 MR. PIKE: Same objection. 14 Q. All righty. 3. 5 THE I don?t understand the question. 1 5 MR. PIKE: But that?s limited to the compound 1 6 BY MR. KUVIN: 1 6 objection. 3.7 Q. MC and then a number 2, what is that? 1 7 MR. KUVIN: Oh, no, that's ?ne. 1 8 MR. PIKE: Lack of predicate, foundation. 3. 8 BY MR. KUVIN: 1 9 THE WITNESS: What is that? 1 9 Q. All right. Did you purchase something called 2 0 MR. PIKE: Irrelevant. 2 0 a Twin Torpedo, a soap made in the shape of a penis, and 2 3. BY MR. KUVIN: 2 1 a soap in the shape of a vagina? 2 2 Q. Do you know what it is? 2 2 A. I'm going to anSWer that question like I'answered most of your questions here today, which is, i 2 4 Q. You've neVer heard of that before? 2 4 intend to respond to all relevant questions regarding 2 5 A. 2 5 this lawsuit; however, at the present time, my attorneys 14 (Pages 224 to 227) (561) 832-4500 COURT REPORTING AGENCY, INC. (561) 832~7506 Electronically signed by Joana Ricciuti {601-280-428-9381) Electronically signed by Joana Ricciuti (601-280-428-9381) 34 Page 228 Page 230 1 have counseled me that i cannot provide answers to any 1 A. i intend to respond to all relevant questions 2 questions relevant to this lawsuit. 1 must accept this 2 regarding this lawsuit; however, at the present time, my 3 advice or risk losing my 6th Amendment right to 3 attorneys have counseled me I cannot provide answers to 4 effective representation. Accordingly, I assert my 4 any questions relevant to the lawsuit. I must accept 5 federal constitutional rights as guaranteed by the 5th, 5 this advice or risk losing my 6th Amendment right to 6 6th and 14th Amendment to the United States 6 effective representation. Accordingly, i must assert my 7 Constitution. 7 federal constitutional rights as guaranteed by the 5th, 8 MR. PIKE: Additionally, just for the Court?s 8 6th and 14th Amendments to the Constitution. 9 record, you're questioning the witness on Exhibit 9 I Q. Do you have an egg~shaped penis? 1 No. what? 10 A. I intend to respond to all relevant questions 1 1 MR. it's not an exhibit. it's the 1 1 regarding this lawsuit; however, at the present time, my 1 2 Town of Palm Beach Incident Report with respect to 1 2 attorneys have counseled me I cannot provide answers to 1 3 Jeffrey Epstein, of which i gave you a copy before. 1 3 any questions that may be relevant to this lawsuit. i 1 4 And that was referencingjust so the record is 1 4 must accept this advice or risk losing my 6th Amendment 3. 5 clear, page 46. 1 5 right to effective representation. Accordingly, i must 1 6 MR. PIKE: Then I would add additional 1 6 assert my federal constitutional rights as guaranteed by privileges and objections in addition to what 1 7 the 5th, 6th and 14th Amendment to the United States 1 8 Mr. Epstein has already raised underneath Florida 1 8 Constitution. 1 9 Rule of Criminal Procedure 3.220 and work product. 1 9 Q. Do you have any identifying marks on your 2 0 Not necessarily the document in front of you, but 2 penis? 2 1 the questions and the answer you?re attempting to 2 1 A. I intend to respond to all relevant questions 2 2 elicit. 2 2 regarding this lawsuit; however, at the present time, my 2 3 BY MR. KUVIN: 2 3 attorneys have counseled me I cannot provide answers to 2 4 Q. Whose mobile wireless number is (561)317-2143? 24 any questions relevant to the lawsuit. I must accept 2 5 A. intend to respond to all relevant questions 25 their advice or risk losing my 6th Amendment right to 9age 229 Page 231 1 regarding this lawsuit; however, at the present time, my 1 effective representation. Accordingly, I hereby assert 2 attorneys have counseled me I cannot provide answers to 2 my federal constitutional rights as guaranteed by the 3 any questions relevant to this lawsuit. I must accept 3 5th, 6th and l4th Amendments to the United States 4 this advice or risk losing my 6th Amendment right to 4 Constitution. 5 effective representation. Accordingly, I hereby assert 5 MR. PIKE: In addition, same objection and 6 my federal constitutional rights as guaranteed by the 6 privilege which regard to the Florida Rule of 7 5th, 6th and 14th Amendments to the United States 7 Procedure 3.220 and work product. Not necessarily 8 Constitution. 8 the document you?re talking or speaking from, but 9 Q. I?m going to read you, for speed?s sake, three 9 the testimony. 0 separate phone numbers, and it's the same question for 1 0 MR. KUVIN: wasjust reading this. I wasn't 1 1 each. Do you recognize the following phone numbers? 1 1 asking questions from this at the moment. 1 2 They all have Area Code 561. The first one is 832-4117, 12 BY MR. 1 3 the second is 3l7~2l43, and the third is 383-7542. 1 3 Q. Does your penis have any deformities? 1 4 A. I intend to respond to all relevant questions 1 4 MR. PIKE: Form. 1 5 regarding this lawsuit; however, at the present time, my 1 5 THE WITNESS: I intend to respond to all 1 6 attorneys have counseled me I cannot provide answers to 1 6 relevant questions regarding this lawsuit; however, 17 any questions relevant to this lawsuit. i must accept 17 at the present time, my attorneys have counseled me 1 8 this advice or risk losing my 6th Amendment right to 18 I cannot provide answers the any questions relevant 1 9 effective representation. Accordingly, I must assert my 19 to the lawsuit. i must accept this advice or risk 2 0 federal constitutional rights as guaranteed by the 5th, 2 losing my 6th Amendment right to effective 2 1 6th and 14th Amendments to the United States 2 1 representation. Accordingly, I assert my federal 2 2 Constitution. 2 2 constitutional rights as guaranteed by the 5th, 6th 2 3 Q. Did Sarah Kellen have the phone number 2 3 and 14th Amendment to the Constitution, as I've 24 655-0995 or 88l.~8l 1.6 or 655 i?m sorry, same number 2 done with most of your questions here today. 15 (Pages 228 to 231) anew? tenure :s-l?xW wax-anus?? El?n-M?! x?fm are E?LWmt-?w??tia assesses r?a?d?l?i?i?i i?W? ?73: ?f?i?i?e??lmWM?? a {:93le 32-9 EX amnesia 5.1 385% ?t ill-31 all-3.2 is: Writ? {Elsi . .. .. (561) 832~7500 PROBE. COURT REPORTENG AGENCY, INC. (563.) 832-7506 Electronically signed by Joana Ricciuti (601-280-428-9381) Electronically signed by Joana Ricciuti (601-280-428-9381) (561) 832-7500 Electronically signed by Joana Ricciuti (6014804239381) Electronically signed by Jeane Ricciutl (601-280-428-9381) PROSE COURT REPORTING AGENCY, Page 232 Page 234 1 BY MR. 1 Marcinkova, Sarah Kellen or Ghisiaine Maxwell from the 2 Q. Did you ever utilize Dollar~Rent~a~Car to rent 2 years 2005 to 2006? 3 cars while you were here in Palm Beach at any time? 3 MR. PIKE: Relevance. 4 A. I intend to respond to all relevant questions, 4 THE WITNESS: intend to reSpond to all 5 Mr. Kuvin, regarding this lawsuit; however, at the 5 relevant questions regarding this lawsuit. As We 6 present time, my attorneys have counseled me i cannot 6 answered most of your questions the same way today, 7 provide answers to any questions that may prove relevant 7 Mr. Kevin, at the present time, my attorneys have 8 to this lawsuit. i must accept this advice or risk 8 counseled me i cannot provide answers to any of 9 losing my 6th Amendment right to effective 9 year questions that may be relevant to this 1 0 representation. Accordingly, I must assert my federal 0 lawsuit. must accept this advice or risk losing 1 1 constitutional rights as guaranteed by the 5th, 6th and 1 my 6th Amendment right to effective representation. 3. 2 14th Amendment to the United States Constitution. 12 Therefore, accordingly, 1 assert my federal 3 Q. What was your personal cell phone carrier back 1 3 constitutional rights as guaranteed by the 5th, 6th 1 4 in 2004? 1 4 and 14th Amendment to the United States 1 5 A. I intend to respond to all relevant questions it 5 Constitution. 1 6 regarding this lawsuit. 1 6 May we take a break, please? 1 7 Q. Let me make this quicker. i?m sorry for MR. KUVIN: Sure. I 8 interrupting you, I apologize. Let?s say, what was your 1 8 MR. PIKE: Yes. 1 9 cell phone carrier back from 2004 through 2006. 9 MR. GOLDBERGER: Yes. 20 MR. FIKE: And I'm not objecting to compound; 20 THE VIDEOGRAPHER: Going off the record at 2 1 however, there are various allegations in your 2 1 3:21. 2 2 complaint regarding a time frame. So therefore, 2 2 (A brief recess was taken.) 2 3 with regard to the allegations in your complaint, 2 3 THE We're back on the record at 2 4 relative to your question, I?m not objecting to the 2 4 3:30. 2 5 compound, I?m saying it?s overbroad. 2 5 Page 233 Page 235 1 MR. KUVIN: 2004 to 2006? 1 BY MR. 2 MR. PIKE: Overbrcad and irrelevant based upon 2 Q. Here, let me move this out of the way. 3 the allegations that you've alleged. 3 A. You can take your .ioy Jelly home now. 4 MR. KUVIN: All right. Well, let me clarify 4 Q. It's actually an exhibit to your deposition. 5 the question then. 5 A. Sorry. 6 BY MR. KUVIN: 6 Q. Have you read the police department's, the 7 Q. What was your cell phone carrier from 2004 to 7 Palm Beach Police Department's, probable cause 8 2005? 8 affidavit? Have you ever read it? 9 MR. PIKE: Same objections. 9 MR. PIKE: Attorney~ciient, work privilegeWellagain. What was 1 i Q. Have you ever read the police department, Palm 1 2 your cell phone carrier from 2005 to 2006?? i. 2 Beach Police Department's incident report regarding you? 13 MR. PIKE: Relevance. 13 MR. PIKE: Same objection. 14 THE WITNESS: I intend to respond to all 1 4 MR. GOLDBERGER: Same objection. l. 5 relevant questions regarding this lawsuit; however, 1 5 MR. PIKE: And instruction, l'm sorry. i. 6 at the present time, my attorneys have counseled me 1 6 BY MR. KUVIN: 1 7 I cannot provide answers to any questions relevant 1 7 Q. Are you circumcised? 1 8 to this lawsuit. 1 must accept their advice or 1 8 MR. Objection, relevance. 1 9 risk losing my 6th Amendment right to effective 1 9 THE WITNESS: i intend to respond to all 2 representation; therefore, I must assert my federal 2 0 relevant questions regarding this lawsuit; however, 2 1 constitutional rights as guaranteed by the 5th, 6th 2 i at the present time, my attorneys have counseled me 2 2 and 14th Amendments to the United States 2 2 I cannot provide answers to any questions relevant 2 3 Constitution. 2 3 to this lawsuit. 1 must accept this advice or risk 2 4 BY MR. KUVIN: 2 4 losing my 6th Amendment right to effective 2 representation. Accordingly, assert my federal Vx 3.3mm ?are Mm?e?? (Pages 232 to 235 INC. (561) 832*7506 ?ltrate?. mammarameeaanaam Sciatiin 5&3? awd??ki-?i?k??si?iti email: ilk? rammuztatmaa tats mm Page 236 Bags: 238 1 constitutional rights as guaranteed by the 5th, 6th 1 correct? 2 and 14th Amendments to the United States 2 A. You asked that before. 3 Constitution. 3 Yes, correct. ti BY MR. KUVIN: 4 Q. Okay, I?m sorry. Q. Was a search warrant performed and executed your home on Palm Beach island? 6 clarify. 7 MR. GOLDBERGER: Attorney-client, work 7 A. Do you want to do compound again? 8 privilege. 8 Q. Yeah. Did you or do you currently own a 2005 9 l'li instruct you not to answer. 9 black Cadillac Escalade ESV, bearing Florida iicense tag 0 BY MR. KUVIN: - 1 1 Q. Do you know Zara Bailey, spelled 1 A. I intend to respond to all reievant questions 1 2 Daniel Estes, spelled or Douglas 1 2 regarding this lawsuit; however, at the present time, my 1 3 Sehoettie, 3 attorneys have counseled me I cannot provide answers to 4 A. intend to respond to all relevant questions 1 4 any questions that may be reievant to the lawsuit. I 1 5 regarding this lawsuit; however, at the present time, my 1 5 must accept their advice or risk losing my 6th Amendment 1 6 attorneys have counseled me i cannot provide answers to 1 6 right to effective representation. Accordingly, I 1 7 any questions relevant to this lawsuit. And as i?ve 1 7 assert my federal constitutional rights as guaranteed by 1 8 answered most of your questions today, Mr. Kevin, I must 1 8 the 5th, 6th and 14th Amendment to the United States 1 9 accept this advice and risk losing w? or risk losing my 1 9 Constitution. 2 0 6th Amendment right to effective representation. 2 0 Q. Have you hired attorneys for either 2 1 Accordingly, assert my federal constitutional rights 2 3. Sarah Kellen, Ghislaine Maxweil, Nadia Marcinkova or any 2 2 as guaranteed by the 5th, 6th and 14th Amendments to the 2 2 other -- 2 3 United States Constitution. 2 3 MR. GOLDBERGER: Attorney-client, work 2 4 Q. Did you have a chef working for you at your 2 43 product. 25 Palm Beach home back in 2005? 2 5 Are you done? i'm sorry. Page 237 Page 239 1 A. i intend to reSpond to all relevant questions 1 BY MR. KUVIN: 2 regarding this lawsuit; however, at the present time, my 2 Q. -- or any other women in this case? 3 attorneys have counseled me i cannot provide answers to 3 MR. GOLDBERGER: Okay. Now attorney-client, 4 any questions relevant to this lawsuit at this time. i 4 work product. 5 must accept their advice or risk losing my 6th Amendment 5 1 direct you not to answer. 6 right to effective representation. Accordingly, I must 6 BY MR. KUVIN: 7 assert my federal constitutional rights as guaranteed by 7 Q. Do you know the name of the girl that was with 8 the 5th, 6th and 14th Amendment to the United States 8 3.13. when she was brought to your home? 9 Constitution. 9 MR. PIKE: Form, lack-of predicate, 1 0 MR. PIKE: Additionally, predicate and 1 0 foundation. 1 1 foundation. 1 1 THE WITNESS: Like I've done to many of your 12 BY MR. 12 other questions and responded to many of your other you currentiy own a 2004 1 3 questions today, Mr. Kuvin, that question I must 4 hiack Chevy Suburban, hearing Florida tag 4 answer that, i intend to answer all relevant 15 A. i intend to respond to ail relevant questions 1 5 questions regarding this lawsuit; however, at the 6 regarding this lawsuit; however, at the present time, my 1 6 present time, my attorneys have counseled me i 1 7 attorneys have counseled me i cannot provide answers to 1 cannot provide answers to any questions that may he 18 any questions that may be relevant to the lawsuit. I 1 8 reievant. i must accept this advice or risk losing 1 9 must accept their advice or risk losing my 6th Amendment 1 9 my 6th Amendment right to effective representation; 2 0 right to effective representation; therefore, i assert 2 0 therefore, I assert my federal constitutional 2 1 my federal constitutional rights as guaranteed by the 2 1 rights as guaranteed by the 5th, 6th and 14th 2 2 5th, 6th and 14th Amendment to the United States 2 2 Amendment to the Constitution. 2 3 Constitution. 2 3 BY MR. KUVIN: 2 4 Q. I think I asked this before, and I apologize 24 Q. Did you, in fact, give BB. $200 for did, but your date of. birth is January 20, 1953, 2 5 her to get naked and give on a massage while you were 17 (Pa as 236 to 239) (561) 832?7500 COURT REPORTING AGENCY, INC. (561) 832~7586 Electronically signed by Joana Ricciuti (601~280~428~938'i) Eiectronicatiy signed by Jeane Ricctuti (601~280428?9381) Page 240 Page 242 amd?w i timestamer amateurs twat, {$555653 mes. fliers sane Sit?t? atrium {it sierra. Xx mamanmtemtu i?t?il? naked and, in addition, touch her in her vagina without 1 Q. Have you told young ladies girls under the 2 her permission in 2005? 2 age of 18, when they came to your house and got naked to 3 MR. PIKE: Predicate, foundation -- 3 give you a massage, quote, the more you do, the more you 4 THE WITNESS: i believe that's been asked and 4 get paid? 5 answered. 5 MR. PIKE: Objection, fonn, predicate, 6 MR. PIKE: Harassing. And i. believe as 6 foundation, improper hypothetical and assumes facts 7 worded, that question has been asked and answered 7 not in evidence, relevance. 8 in sub parts. I believe you've asked those 8 THE WITNESS: Like most of your questions, 9 questions initially at the beginning of this 9 Mr. Kuvin, today, i intend to respond to all 1 0 deposition. The same objections would, therefore, 1 0 relevant questions regarding this lawsuit; however, 1 1 apply and be incorporated. It i. at the present time, my attorneys have counseled me 1 2 MR. KUVIN: I disagree, 3. 2 I cannot provide answers to any questions relevant 3. 3 THE WITNESS: Like most of your other it 3 to this lawsuit. I must accept this advice or risk 1 4 questions here today, I intend to respond to all 1 4 losing my 6th Amendment right to effective 1 5 relevant questions regarding this lawsuit; however, 1 5 representation. Accordingly, assert my federal 1 6 at the present time, my attorneys have counseled me 1 6 constitutional rights as guaranteed by the 5th, 6th 1 7 i cannot provide answers to any questions that may 1 7 and 14th Amendment to the United States 31 8 be relevant. I must accept this advice or risk 18 Constitution. 3. 9 losing my 6th Amendment privilege. Accordingly, i 19 BY MR. KUVIN: 2 assert my federal constitutional rights as 2 0 Q. Do you have any tattoos? 2 1 guaranteed by the 5th, 6th and 14th Amendment to 2 1 A. i intend to respond to all relevant questions 2 2 the US Constitution. 2 2 regarding this lawsuit; however, at the present timeattorneys have counseled me I cannot provide answers to 2 4 Q. Do you agree, sir, that your conduct, with 2 4 any questions relevant to this lawsuit. must accept 2 5 respect to 13.8., caused her severe emotional distress? 25 this advice or risk losing my 6th Amendment right to Page 241 Page 243 1 MR. PIKE: Same objection. in addition, it's 1 effective representation. Accordingly, I must assert my 2 argumentative, harassing and calls for a 2 federal constitutional rights as guaranteed by the 5th, 3 conclusion. 3 6th and 14th Amendments to the United States 4 THE WITNESS: I'm going to have to answer that 4 Constitution. 5 the same way I?ve answered most of your questions 5 Q. Do you have a steam room in your home on Palm 6 today, Mr. Kuvin, which is, I intend to respond to 6 Beach Island? 7 all relevant questions regarding this lawsuit; 7 MR. PIKE: Same objections. 8 however, at the present time, my attorneys have 8 THE WITNESS: I'm going to answer that 9 counseled me I cannot provide answers to any 9 question the same way I've answered most of your 10 questions relevant to the lawsuit. I must accept 1 8 questions here today, which is, I intend to respond 1 1 this advice or risk losing my 6th Amendment right 1 1 to all relevant questions regarding this lawsuit; 1 2 to effective representation. Accordingly, i must 1 2 however, at the present time, my attorneys haVe i. 3 assert my federal constitutional rights as 1 3 counseled me that 1 cannot provide answers to any 1 4 guaranteed by the 5th, 6th and 14th Amendment. 1 4 questions relevant to the lawsuit. 1 must accept 1 5 BY MR. 1 5 this advice or risk losing my 6th Amendment right 1 6 Q. Do you have gray chest hair? 1 6 to effective representation. Accordingly, I must 1 7 A. I intend to respond to all relevant questions 1 7 assert my constitutional rights as guaranteed by 1 8 regarding this lawsuit; however, at the present time, my 18 the 5th 5th, 6th and 14th Amendments to the 9 attorneys have counseled me i cannot provide answers to 3. 9 United States Constitution. 2 0 any of those questions that may be relevant. I must 2 0 BY MR. KUVIN: 2 accept this advice or risk losing my 6th Amendment right 2 1 Q. Did you provide payments to underaged girls by 2.2 to effective representation. Accordingly, I assert my 2 2 utilizing cash and wire transfers through Western Union 2 3 federal constitutional rights as guaranteed by the 5th, 2 3 in 2004 or 2005? 24 24 2 5 Constitution. 2 5 previous last three questions incorporated here. 18 (Pages 240 to 243) (561) 832w7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeane Ricciuti (601-2304288381) Electronically signed by Joana Ricciuti (601-2804289381) (561) 83247506 34 thin (561) 832?7500 Electronically signed by Joana Ricciuti (601?280428~938?l) Electronically signed by Jeane Ricciuti (6Dl~280428~9381) Page 244 Page 246 1 THE WITNESS: I intend to respond to all 3. at the present time, my attorneys have counseled me 2 relevant questions regarding this lawsuit; however, 2 that i cannot provide answers to any questions 3 at the present time, my attorneys have counseled me 3 relevant to the lawsuit. I must accept their 4 I cannot provide answers to any questions relevant 4 advice or risk losing my 6th Amendment right to 5 to the lawsuit. I must accept this advice or risk 5 effective representation. Accordingly, assert my 6 losing my 6th Amendment right to effective 6 federal constitutional rights as guaranteed by the 7 representation. Accordingly, assert my federal 7 5th, 6th and 14th Amendment to the United States 8 constitutional rights as guaranteed by the 5th, 6th 8 Constitution. 9 and 14th Amendment to the United States 9 BY MR. KUVIN: 1 0 Constitution. 10 Q. Hold on a second. i may be done. 1 1 BY MR. KUVIN: 1 Do you know a Dr. Kaku, 1 2 Q. Did you excusc me. Did you take any 1 2 A. I intend to respond to all relevant questions 1 3 videotapes of girls that were under the age of 18 in 3 regarding this lawsuit; however, at the present time, my 14 your home on Palm Beach island? 1 4 attorneys have counseled me i cannot provide answers to 15 MR. PIKE: Same objections incorporated. i 5 any questions that may be relevant. i must accept this 1 6 THE WITNESS: As I have with most of your 1 6 advice or risk losing my 6th right to effective 1 7 questions today, i?m going to have to anSWer that, 1 7 representation. Accordingly, I assert my federal 1 8 I intend to respond to all relevant questions 1 8 constitutional rights as guaranteed by the 5th, 6th and 9 regarding this lawsuit; however, at the present 3. 9 14th Amendment to the United States Constitution. 2 0 time, my attorneys have counseled me I cannot 2 0 MR. Can you hold on one second? 2 1 provide answers to any questions that may be 2 1 MR. KUVIN: I'm almost done. 2 2 relevant to this lawsuit. i must accept this 22 MR. PIKE: No, no. We?re not going anywhere. 2 3 advice or risk losing my 6th Amendment right to 23 MR. KUVIN: Okay. 2 4 effective representation. Accordingly, if assert my 2 4 MR. PIKE: Okay. 2 5 federal constitutional rights as guaranteed by the 2 5 Page 245 Page 247 1 5th, 6th and 14th Amendment to the United States 1 MR. KUVIN: Okay. All right, I appreciate 2 Constitution. 2 your patience. That?s all the questions that 3 BY MR. KUVIN: 3 have right now. I know that Mr. Goldberger needs 4 Q. Have you ever provided a dozen roses to a 4 to deal with an issue right now with Ms. Ezell 5 young girl under the age of 18 who came to your house to 5 regarding any further questions. 6 give you a massage? 6 MR. GOLDBERGER: I think we clari?ed that. 7 MR. PIKE: Form, vague, ambiguous, assumes 7 Ms. Ezell, are you there? 8 facts not in evidence. 8 MS. EZELL: I'm here. 9 THE WITNESS: I intend to respond to all 9 MR. GOLDBERGBR: Yeah. You had a discussion 1 0 relevant questions regarding this lawsuit; however, 1 with Bob Critton already concerning the question 1 at the present time, my attorneys have counseled me 3. 1 you raised with me earlier, right? 12 that I cannot provide answers to any questions that 12 MS. EZELL: Yes, I did, and i don?t have any 1 3 may be relevant. I must accept their advice or 1 3 questions. it 4 risk losing my 6th Amendment right to effective 1 4 MR. PIKE: Ms. Ezell, this is Michael Pike. 3. 5 representation. Accordingly, I must assert my 1 5 don't know what your conversation was with Bob, but 1 6 federal constitutional rights as guaranteed by the 1 6 did you cross notice this deposition? 1 7 5th, 6th and 14th Amendment. 17 MS. EZIELL: No, i did not. 1 8 BY MR. KUVIN: 3.8 MR. PIKE: So what is your purpose of being 1 9 Q. Did you ever instruct anyone to deliver a 1 9 here? 2 bucket of roses after a high school drama performance to 2 0 My position is that these are closed 2 1 an underaged girl? 2 1 proceedings and your client, your client did not 2 2 MR. Same objection. In addition, lacks 2 2 cross notice this deposition and/or your clients. 2 3 predicate and foundation. It?s overbroad as well. 2 3 So what is your purpose of sitting in on this 2 4 THE WITNESS: I fully intend to respond to all 2 4 deposition? 2 5 relevant questions regarding this lawsuit; however, 2 5 MS. EZELL: Well, I received a notice of it, amateur: PROSE COURT REPORTING AGENCY, INC. - ?d li? . 19 (Pages 244 to 247) (561) 832~7506 34 E?age 248 Page 250 1 and I just thought i wouid listen to it white I was 1 CERTIFICATE OF OATH 2 doing some other work. And I don't know why it 2 THE STATE OF FLORIDA 3 would be a closed proceeding. 3 COUNTY OF PALM BEACH 4 MR. PIKE: Discovery proceedings are closed if i I 1: it 21 pi: trial discovery, ma am, it not a court 6 I, the undersigned authority, Cm; fy that procee mg' . 7 JEFFREY EPSTEIN personaiiy appeared before me and was Nonetheicss, do you have any questions for the 8 dub, sworn on the 8th day of October, 2009' 8 witness? 9 9 Ms. EZELL: No. i don?t. 1 0 Dated this 82h day of October, 2009. 10 MR. PIKE: And Ms. Holmes, who are you here 0n 1 1 1 1 behalf of? Which ciients? 1 2 12 MS. HOLMES: LM. and raw. if; 3 MR. PIKE: Are you aiso here on hehaif of Jane {in ii, i 4 Doe in the case 80893? 1 5 2.93? I a, 15 MS. HOLMES: i believe SO, yes. Jeana Ricciuti? 1 6 MR. PIKE: Do you have any questions for the 1 5 Notary {Jub?c . State of pgorida 1? witness? My Commission Expires: 2/ 17.12013 1 8 MS. HOLMES: No, I do not. 17 My Commission Nd: DD 854778 9 MR. GOLDBERGBR: Katherine, we're going to 1 8 2 0 end. Do you want me to disconnect you now? 1 9 2 3. MS. EZELL: Yes, thanks. 22 MR. GOLDBERGER: Okay. 22 2 3 THE VIDEOGRAPHER: Conclude the deposition and 2 3 2 4 go off the record at 3:00 2 4 2 5 MR. PIKE: Wait one second. 2 5 Page 249 Page 251 1 MR- 2 MR. GOLDBERGER: He?sjust going to read. COUNTY OF PALM BEACH 3 MR. PIKE: You didn?t give the witness a 4 I. 5 i, Jeane Ricciuti, Registered Professionai 4 Chance to read or wave and he mad' Reporter and Notary Pubiic in and for the State of 5 THE VIDEOGRAPHER: Conciude the deposrtiorl and 6 Fiorida at large, do hereby certify that I was 6 go o??the record at 3 :48. This wiil be the end of authorized to and did retort said deposition in 7 stenotype; and that the foregoing pages are a true and i3 7 tape NO- 3- correct transcription of my shorthand notes of said 8 8 deposition. . 9 I further certify that said deposition was 9 (Witness excused?) taken at the time and piece hereinabove set forth and 0 (Deposition was concluded.) 0 that the taking of said deposition was commenced and 1 1 compieted as hereinabove set out. 1 1 1 2 I further certify that i am not attorney or 1 3 2 coansei of any of the parties, nor am I a relative or emptoyce of any attorney or connsei of party connected 3?4 13 with the action, nor am I financially interested in the 1 5 action. 14 3? 6 The foregoing Certi?cation of this transcript i 1 does not appiy to any reproduction of the same by any 8 means unless under the direct controi anda?or direction 1 6 of the certifying reporter. 1 9 1 7 Dated this 8th day of October, 2009jaw? Ay?'?ewg? deans Rieciuti, spa, FPR(Pages 248 to 251) (561) 832-?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832""7506 Etectronicalty signed by Joana Ricciuti (801?280428~9381) Eiectronicatiy signed by Joana Ricciuti {601 ~280-428n9381) 34 Page 252 DO NOT WRITE ON - CHANGES HERE Page 254 REASON 1 October 22, 2009 1 A A 2 . T01 353335? 2 at as: as. v. EPSTEIN ca: 315nm RICCIUTI BURMAN, CRITTON. LUTHER COLEMAN, RA. 2 EPSTEW 303 Banyan Boulevard A . etc or 4 Suite 400 5 West Palm Beach, Florida 33402 6 PAGE it LINE it CHANGE 5 EN BB. v. '7 6 Please take notice that on Thursday. the 8th 7 of October, 2009, yen gave your deposition in the 8 above-referred matter. At that time. you did not waive 8 signature. It is now necessary that you Sign your 9 deposition. 9 As previously agreed to. the transcript will 10 be fumishe? to you through your counsel. Please read 1 0 the following instructions care?ztty: At the end ofthe transcript you will find an 11 1 1 errata sheet. As you read your deposition. any changes or corrections that you wish to make should be noted on 12 1 2 the errata street, citing page and tine number ol?said change. I30 NOT wn'te on the transcript itself. Once I 3 1 3 you have read the transcript and noted any changes, be sure to sign and date the errata sheet and return these 14 pages not read and sign the deposition 15 within a reasonabie time 30 days unless otherwise 15 directed} the origins}, which has already been forwarded 1 6 to the ordering attorney, may be filed with the Cierk of 1 6 the Court, Ifyou wish to waive your signature. Sign I . . . . 17 your name in the biank at the bottom of this letter and 17 Please roman: or?gmal errata Sim? to lhis return it to us. of?ce so that coptcs may be distributed to all parties. 18 1 8 Vet? ?1339 You?. Under paucity of perjury, I ?cclaro that i have read my 19 19 deposition and that it is true and correct subject to 20 any changes in form or entered here. teana Ricciuti. RPR, FPR, CLR 2 0 2 1 From Court Reporting Agency. INC. 2 1 DATE: 250 S. Australian Avenue. Ste 1500 22 22 West Palm Beach. Florida 33401 2 3 DEPONENT: 23 i do hereby waive my signature. 2 4 2 4 25 JEFFREY EPSTEIN 25 Page 253 2 .. .. .. 3 THESTATEOFFLORHMR 4 COUNTY OF PALM BEACH 5 i hereby certify that I have read the 6 foregoing deposition by me given, and that the 7 statements contained herein are true and correct to the 8 best of my knowledge and belief, with the exception of 9 any corrections or notations made on the errata sheet, 1 0 if one was executed. 11 i 2 Dated this day of 13 200932?7 500 PROSE COURT REPORTING AGENCY INC . Eiectronicaily signed by Joana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) macros ouster/tattooka *5 it??e??i 3% E'ieb?a sectariach 3W morammc?wzwmeomcm wettest-5:3: 9: 9352? ?5823964: ammotmeau masseuse-amen 9M?c325? astumwmmemtu 5.133,? (hi3: 3 ?ied} "i grammat- teem: restart/trauma 635.: an mm; at ii?zt?e? ?3?3i3?v?2?i?3?avi?%? tun :Si-Ii Kati-1 2x826 Page 177 Page 179. 1 Okay. We?ve been discussing Jane Doc 5 for 1 BY MR. HOROWITZ: 2 some time now. Okay. I'm going to ask you a. few more 2 During the course of Jane Doe S?s visit to your 3 questions about her. During the course of Jane Doe 5?s 3 home in 200i or 2002, did you place a vibrator on her 4 visit to your home in 2001 and 2002, did you rub Jane 4 vagina? 5 Doc 5?s vagina over her underwear? 5 MR. PIKE: Form. 6 MR. PIKE: Form, and assumes facts not in 6 THE WITNESS: I?d like to answer that 7 evidence. 7 THE VIDEOGRAPHER: Hold on. There?s major 8 THE WITNESS: I?d like to answer that 8 static. Time off the record 2:40. 9 question. I'd like to answer every question you?ve 9 (Thereupon, a short break was taken.) 10 asiced me here today. But on advice of counsel, 10 THE Time on the record 2:41 1 1 they?ve instructed me, I must assert my Sixth 1 1 MR. Back on the record. 1 don't 12 Amendment, Fourteenth Amendment and Fifth Amendmen 1 2 know that answer to this 13 Rights. 1 3 question, so I'm going to repeat it. And if you 14 BY MR. HOROWITZ: 1 4 have to repeat your answer, I apologize. 1 5 During the course of Jane Doe 5?s visit to your 1 5 MR. PIKE: Thank you. 1 6 home in 2001 and 2002, did you rub her vagina under her 1 6 BY MR. HOROWITZ: underwear? During the course of Jane Doe 5?s visit to your 18 MR. PIKE: Form. - 18 home in 2001 or 2002, did you place a vibrator on her 1 9 THE WITNESS: Elm afraid it?s the same answer 1 9 vagina? 20 as most of the other answers I?ve given here 2 0 MR. l?lKE: Form. 2 1 today. Though I would like to answer these 2 1 THE WITNESS: I'd like to answer the questions 2 2 questions with speci?city, especially that 22 about Jane Doe 5. However, my attorneys have told 23 question, my counsel has advised me that i may not, 2 3 me that i may not answer any questions regarding 24 and must assert my rights under the Sixth 2 4 anything that may be relevant to any of the 2 5 Amendment, Fourteenth and Fifth Amendment. 2 5 lawsuits brought by you, your ?rm, your partner Page 178 Page 180 1 And if! chose to answer, which I prefer to do, 1 that was suspended or disbarred alter he brought 2 they?ve advised me i may waive those rights, or 2 these lawsuits. So, though I'd like to answer the 3 risk losing their representation. 3 question, Mr. Horowitz, my attorneys have advised 4 BY MR. HOROWITZ: 4 me, at least today, that I must assert my rights 5 During the course of Jane Doe 5's visit to your 5 under the Sixth, Fourteenth and Fifteen -- Fifth 6 home in 2001 and 2002, did did you insert your 6 Amendment, and I respectfully have to decline. 7 fingers into her vagina? BY MR. HORQWITZ: 8 MR. PIKE: Form. 8 During the course of Jane Doe 5's visit to your 9 THE I'd very much like to answer that 9 home in 2001 or 2002, did you masturbate in her 10 question as well, Mr. Horowitz, but my attorneys 10 presence? 11 have advised me today that I cannot, and i must 11 MR. PIKE: Form. 12 assert my rights under the Sixth, Filth and 12 THE WITNESS: I?d very much like to answer 13 Fourteenth Amendments. 1 3 every question, every single question regarding 14 Though it would -- I'd prefer to answer the 1 4 Jane Doc 5 and her claims. However, my attorneys 1 5 question, they told me that if I choose to do so, I It 5 have advised me, at least today, that I may not do 16 risk waiving those rights. I would prefer to have 1 6 so, and must assert my rights under the Sixth 17 that conversation with your partner that was 17 Amendment, Fourteenth and Fifth Amendment. 18 suspended or disbarred from the Florida Bar after 1 8 And, though I would prefer to answer, they have 19 filing the lawsuit on lane Doe 5?s behalf. I?d 1 9 advised me that if i choose to do so, 1 risk 2 0 prefer to talk to Mr. Edwards? partner, if he was 2 0 waiving those rights and risk losing their 2 able to be here, except he's injail for 2 1 representation. 22 fabricating cases of a sexual nature against people 2 2 BY MR. HOROWITZ: 23 like me. So, believe me, [?01 Elite to answer those 23 During the course of Jane Doe 5?s visit to your 24 questions, but today my attorneys have told me I 24 home in 2001 or 2002, did you ejaculate in her presence. 25 rnaynot 25 .. .wagmemmrn .r . - a are. art-semamnm-am a: ?amusement-me ans-s. . sear-tantrums: a Midi-1K!) a not-Maw was sewers-madam? raft-m: med amrusrauesrnamrm 5&1 ?xrtI-rt-?t ww? rm?dct? iri?aeii?c'a'i- Kilt-5:33:33 WES-W sateen net-raw?; 3&3 his? kt {?tment-?MM MR. PIKE: Form. lien? 45 (Pages 177 to 180) UNIVERSAL COURT REPORTING (954) 712*2600 (877) Page 181 Page 183 1 THE WITNESS: Did I ejaculate in Miss Jane Doe 1 of Miss Jane Doe 5's complaints or claims. My 2 5?s presence? I'd like to answer that question and 2 attorneys have told me that, at least today, that i 3 that all her claims w? however, today, my attorneys 3 may not do so today, and must assert my rights 4 have counseled me that I may not. 4 under the Sixth Amendment, Filth Amendment and 5 . They?ve instructed me that I have to assert my 5 Fourteenth, and have to respond the same way i've 6 Sixth Amendment, Fourteenth Amendment and Fifth 6 responded to most of your -- my -- your other 7 Amendment Rights. Though l'd like to answer that 7 questions posed here today. 8 question, I am going to have to respond as We 8 BY MR. HOROWITZ: 9 answered most of your other questions here today, 9 Did you pay Jane Doc 5 $200 after you had 1 0 which is by asserting those rights. 1 0 sexual contact with her in your home? 1 1 BY MR. HOROWITZ: 1 MR. PIKE: Form. 12 Did you have sexual contact with Jane Doe 5 in 12 THE WITNESS: i?d like to respond to every one 13 your Palm Beach home in either 2001 or 2002? 13 of Jane Doe 5?s claims, but my attorneys have 1 4 MR. PIKE: Form. 1 4 advised me that at least today I must assert my 15 THE WITNESS: "Sexual contact"? 3. 5 rights under the Fifth, Sixth and Fourteenth 1 6 MR. Yes. 1 6 Amendment. Though I?d like to answer that THE WITNESS: Can you tell me what you mean by 17 question, i am going to have to respond similarly 1 8 that? 8 that l've answered most of your other questions 38 l9 20 Contact, sexual of a sexual nature. Do you 20 And I though I would l've been advised by 2 1 understand do you understand what that means? 2 1 my attorneys, if I choose to answer, i risk waiving 22 A We asked you -- 22 my rights and/or risk losing their representation. 2 3 Have you had sexual contact? 23 BY MR. HOROWITZ: 24 A l?ve asked you to clarify what you mean, 24 You never asked Jane Doe for permission to 25 please. 2 5 touch either her breasts or genitals, correct? Page 182 Page 184 1 Well, I?m going to use a broad de?nition, 3. MR. Form. 2 okay? 2 THE WITNESS: I would like to respond to every 3 A Yes. 3 single one of your client's claims. My attorneys 4 That would involve touching someone's sexual 4 have advised me at least today, I cannot answer any 5 organs, someone else touching your sexual organs, having 5 questions that may be relevant to those claims. 6 sexual contact together, such as intercourse or oral sex 6 And, though your partner who ?led this lawsuit on 7 or anal sex. Did you have any of those activities of a 7 Miss Jane Doe 5?s behalf was disbarred suSpended 8 sexual nature with Jane Doe 8 by the Florida Bar -- suspended by the Florida Bar 9 MR. PIKE: Form. 9 after ?ling this claim, or Mr. Edwards?, who ?led 10 THE I?d like to respond to every one 10 similar claims, partner who sits in jail, l?d like 1 of lane Doe S's claims. However, today, my counsel 3.1 to answer every single question. However, today, 12 has advised me that i may not. So I am going to 12 my attorneys told me that if I do so, choose to do 13 have -- under their instructions have to assert my 1 3 so, I risk waiving my rights and risk losing their 1 4 Sixth Amendment, Fourteenth Amendment and Fifth a representation. 15 Amendment Rights. Though l?d like to answer that 1 5 BY MR. HOROWITZ: 16 question, I've been told that if i choose to do so, 1 6 Mr. Epstein, Jane Doc 5 told you when she was 17 I risks losing their representation and waiving 17 in your home that she did not want you to touch her 1 8 those rights. 1 8 body, isn?t that true? 1 9 BY MR. HOROWITZ: 19 MR. PIKE: Form. 20 During the course of lane Doe 5's visit to your 20 THE I would very much like to answe 2 1 home in 2001 or 2002, did you also touch another 2 1 every question regarding Jane Doe 5's claims, but 2 2 underage girl in a sexual manner in the presence of Jane 2 2 today my attorneys have informed me that answer, and must assert my rights under the Sixth, 24 MR. PIKE: Form. 2 4 Fifth and Fourteenth Amendment. So, though I woul 25 THE I'd like to respond to every one 2 like to answer those questions, I ys eaasussuxmamma .355.? ?5 . madmwm- - We? an user-tn t-asttaaranxa mmti??i?imi iris-3 {Kiwi}? ?mitt??e?eiiw(Pages 181 to 184) UN IVERSAL COURT RE PORT I NS (954) 712-2600 (877) (3376) Page 185 Page 187 1 have informed me that if I choose to do so, which STATE OF FLOREDA 3 representation and wan/mg my 5 COUNTY OF BROWARD 4 BY MR, HOROWITZ: 6 Reporter, igotlary :ublic . . in an or tote 0 on" a at Large. 0 tare 5 Mr- Epstein, you made sexual contaCt With Jane 7 certify that the aforementioned witness was me first a I . 6 Doe 5 after she indicated to you that she did not want ?0 1" the ?"83 that} was I . 8 anthonzed to and did report said deposnion 1n 7 to be touched by you, 11 that right? stcnotype; andthat the foregoing pages are a true and 8 MRI PIKE: Form. 9 i(Eritrean{anon of my shorthand notes of said 9 THE WITNESS: i?d like to answer each and every ,corn att sai eposition was 1 0 one of your questions regarding Miss Jane Doe 5?8 taken at the time and place hereinabove set. forth and 1 1 eiaims. However, my attorneys have advised me that 12 commenced a? 12 today at least, may not answer those claims, and 13 - I further certify that I am not an attorney or 3 must assert under the 1 4 counsel of any ofthe parties, nor am I a relative or 1 4 Amendment, Sixth Amendment and Fifth Amendment 15 smears: 053311 attorney or counsrii of any ogre . . . . conne '3 action. nor am 15 And, though as you might imagine, i would like actionanswer those claims with -- questions with The foregomg certi?cation of this transcript my counsel has toid me that if I 1? does not apply to any reproduction ofthe same by any - - - means untess under the direct control andfor direction 1 8 choose to do so, .1 wave might losmg 18 0me mifymg more: 1 9 their representation and waive -- warvmg some of 19 IN WITNESS WHEREOF. i have heretsnto set my hand my this 22nd day ofMarch, 2010MR. HOROWITZpersuade Jane Doe 5 that it was 22 Vicki L. Lima, Court Reporter - - Notary Public State of Florida 2 3 okay for you'to touch her breasts and genitals while she 33 Commission No: DD 882603 2 4 was still a child? Expiration Date: May 26, 2013 . . . . . 2 4 Job #9207813 25 (Videotaped deposmon continued in Voiume II.) 25 Page 186 Page 188 1 1 UNIVERSAL LEGAL REFORTING 333 EAST LAS OLAS BOULEVARD. 508 2 2 FORT LAUDERDALE, FLORIDA 3330] 3 STATE or FLORIDA 3 4 COUNTY OF BROWARD March 22, 2010 Job {razors?A VolumeI 5 Jeffrey Edward Epstein, witness 6 5 Michael 1. ?lm, Esquire 303 Banyan Bouliovnrd. Suite 400 8 West Palm Beat: Florida 3340] 7 8 Jeffrey Edward Epstein personaiiy appeared before me anc CASE No: {Joey-sot 9 was duty sworn 3 . Dear Mr. Epstein: 1 Pionsc take notice that on Manon 8, 2008, on 3. 1 my hand and of?cral seal this 223d day 10 gave your deposition in the above-referred merrier. At 3.2 of March, 2010. toaststorso;resist?- 3 As previousiy agreed to, the transcript wilt be 1 2 furnished to you through your counsel. Please read the 4 following instructions: 1 5 1 3 At ?age :89, you will ?nd an errata shoot. As you read your deposnion. any changes or corrections 1 6 1 a ligat you wish to make should be noted on the errata . . . I not, citing page and line number ofsaid change. DD tclo L. Lima, Court Reporter 15 3on write on in: tranilcript itisclf. Ori?ce you have read 1o an note any angos, sure to Sign 1 7i NOtary_ State Of F101 Ida 3.6 and data the errata sheet and return these pages to us No: DD 882608 17 at the address listed above. You need not return the . entire [ransom t. 1 8 Expiration Date: May 26, 2013 if you dopnot road and sign the depositioa 1 8 within thirty (30} days, the original, which has already A been forwarded to the ordering attorney, may be filed 3. 9 19 with the Clerk of the Court. Ifyoo wish to waive your 2 0 Sign your name in the blank at the bottom of 20 is oztcran return itto us. 2 1 2 1 Very Indy yours. Universal legal Reporting. 2 2 2 2 23 Vicki L. Lima 2 2 Court Reporter - Notary think: 2 4 ?i do hereby waive my signature. 2 5 25 -: 47 (Pages 185 to 188) UNIVERSAL COURT REPORTING (954) 712?2600 (877) (3376) imit- games atoms is ?ts-22%? we erwmeanmmay more ?atworm 8185.3.- Page RE: Jane Doe No. 2 vs. Jamey Edward Epstein 3 DEPOSZTION OF: Jeffrey Edward Epstein, Voiume I 4 TAKEN: March 8, 20 I0 5 DO NOT WRITE 0N TRANSCRIPT - ENTER CHANGES HERE 6 PAGE 3} LINE CHANGE REASON Please forward the originai signed errata sheet to this 2 1 of?ce so {hat copies may be distributed to al! parties. 22 Under permit}: of per}ury, I declare that I have read my depositisn and that it is true and correct subject to 2 3 any changes in form or substance entere? here. 2 11 DATE: SIGNATURE OF DEPONENT 2 5 Job #920764; . . g; g. msazsm?mezmemm3m3m mm 4- mwmm?m. .vz. - .vseumassm v?m-r: 48 (Page 189) UNIVERSAL COURT REPORTING (954) 712*2600 (877) (3376) Page 190 Page 192 UNZTED STATES DISTRICT COURT 1 SOUTHERN OF FLORIDA 2 VOLUME case no: 3 (Pages 190 335) innenoesmxa 4 Plaintiffs EXAMINATION INDEX vs. 3EFFREY 2 Defendant. JEFFREY EDWARD EPSTEFN Related (33565? CONTINUED DIRECT 193 08~80232, 08?80380,08w80381,08?80994, 8 08-80993, 08-3081 ADS-808910980469, 09-80591 ,ooseoesepseosoz?a?s1092VIDEO TAPED DEPOSITION OF JEFFREY EDWARD EPSTEIN i VOLUME 11 13 EXHIBIT INDEX (Pages zoo - 335) 14 MAR EXHIBIT Monday, March 3, 2020 15 i VEHICLE AND VESSEL INFORMATION 330 302 Clematis Street Suite 3000 1 6 West Paim Beach, Florida 3340: 17 t0:05 am. -6:l7 p.121. 18 19 2O Reported By: 2 1 Vicki L. Lima, Court Reporter 2 2 Notary Public, State of Florida 2 3 Universal Legal Reporting Phone 24 Job 25 Page 191 Page 193 APPEARANCES. 1 (Beginning of Volume II.) 3 2 MR. PIKE: Form. ?3 2 me" 3= 3 THE WITNESS: as like to answer every question 5 JESSICA o. ARBOUR, ESQUIRE 4 that you posed here today, Mr. Horowitz, regarding MERMELSTEIN HOROWITZ28205 Biscayne Boulevard any 0 your len $3 an espema 135 ans 06 6 5?s claims. However, my attorneys have advised me Miami, Honda 33 260 0e helialfofthe Plaintiffs, Jane Doe, LM. and raw; 7 that at least today, i must assert my rights under arose eownnos, ESQUIRE - - 9 MISSING. 8 the'Sixth, Fourteenth and Fifth Amendment, or risk eowanos, FISTOS LEHRMAN, PL. 9 iosrng those rights or the -- and/or their io Andrews Avenue 1 representation. 11 Fort Lauderciaie, Reside 33301 1 1 BY MR. 12 On behalfof the Piamtiff, Jane Doe 103: KATHERINE W, EZELL, ESQUIRE 12 Did you tell Jane Doe 5 to relax and quote, 13 3 just let it let it happen, end quote, when she 14 25 West rzegier Street 1 4i resisted your sexual advances? Suite 800 I is Miaini,Florida 33130 15 MR. PIKE- Form 15 011 behaifofl'he Defendania?d Witness 1 6 THE It wouid give me great pleasure FIKE, esouma bi . BURMAN, CRZWON, Lumen to a e10 answer one oe 5 aims. owever, 18 $233333? 1 8 my attorneys have advised me today, at least today, West perm Beach, Florida 33401 1 9 that i must assert my rights under the Sixth 19 JACK ESQUZRE 20 excuse me -- Fourteenth and Fifth Amendment. And, 20 ATTERBURY, GOLDBERGER PA. 2 1 though very much like to answer those One Cleariake Centre 2 2 . 21 250 Aastralian Avenue South questions, that question, and other questions Suite 1408 i a 22 West Palm Beach, Florida 33402 You 22203? Ff: ?3313)?, I a?fg?mg ?0513?? to 23 asse ose mg 5 an respec or: me. 2s ALSO PRESENT: . 25.. area (Pages 190 to 193) UNIVERSAL COURT REPORTING (954) 712?2600 (877) 291-DEPO (3376) mm .. Page 194 Page 196 1 Did you instruct SK. to take Jane Doe 5's 3. However, my attorneys have counseled me that I may 2 telephone number so you can call Jane Doc 5 to come to 2 not. And if 1 choose to do so, contrary to their 3 your home for more sexual activity? 3 advice, I risk losing their representation and 4 MR. PIKE: Form. 4 waiving those rights. 5 THE WITNESS: I'd like to answer each one of 5 BY MR. HOROWITZ: 6 your questions, these claims made by Jane Doe 5. 6 - Okay. With respect to Jane Doe 5 and the 7 However, today at least, my attorneys have advised 7 questions that you have asserted your Fifth Amendment 8 me that I may not answer any questions that may be 8 privilege, have you been asserting your Fifth Amendmen 9 relevant to any of the lawsuits brought by you, 9 privilege to protect your innocence, or to conceal your 10 your partner who?s been suspended after he filed 1 0 guilt? 1 Miss lane Doe 5's claim. lie was suspended for 11 MR. PIKE: Form. 12 improper behavior by the Florida Bar. i may not 3.2 THE That's a question obviously 13 answer the questions of Mr. Edwards regarding his 13 designed to try to embarrass me. it what I'd 14 or his partner, Mr. Scott Rothstein, who was 14 like to answer that question. However, my counsel 1 5 accused of the largest fraud by fabricating cases 1 5 has advised me that since your ?rm, your partner 1 6 of a sexual nature of against people, me and 1 6 who was suspended for improper behavior since he 17 others, in order to steal millions of dollars from 17 tiled this claim, Mr. Edwards' partner who sits in 18 18 1 9 answer those questions, my attorneys have advised 9 claim the Fifth Amendment, and should claim the 20 me that if I do so, I risk losing their 20 Fifth Amendment who are innocent. respectfully 2 1 representation and waiving my rights. 2 decline to answer, based on my counsel?s advice, 22 BY MR. 2 2 because they?ve told me if I choose to answer, 1 2 3 Alter Jane Doc 5 visited your home, did you 2 3 may waive those rights, but l?d like to answer. 24 instruct SK. to call Jane Doe 5 on the telephone to 24 BY MR. 25 arrange for her to come back for more sexual activity? 25 Sir, is there any reason you can think of as to Page 195 Fage 19? 1 MR. PIKE: Form. 1 why the jury should not infer from your testimony today 2 THE WETNESS: I?d like to answer each one of 2 that you did, in fact, sexually abuse Jane Doe 5 when 3 Miss Liane Doe 5?s claims. i?d like to answer each 3 she was a child? 4 one with specificity. However, my attorneys have 4 MR. PIKE: Form. 5 advised me today, that I must assert my rights 5 THE WITNESS: I believe thejury will be able 6 under the Fourteenth, Sixth and ifth Amendment. 6 to see what your firm, Mr. Edwards' firm, and what 7 And if I choose to answer, which is my preference, 7 the neWSpapers have referred to as part of the 8 I risk losing their representation and waiving 8 largest fraud in South Florida's history by 9 those speci?c rights. 9 crafting cases of a sexual nature against people 10 BY MR. 10 like me and others, simply to get money. His 1 1 Isn't it true, sir, that you sexually abused 1 partner sits injail. Your partner has been 12 lane Doe 5 when she was a child? 12 suspended. l'd rather thejury will make its 13 MR. PIKE: Form. 13 own decision. 14 THE WITNESS: I'd very much like to answer that 14 BY MR. HOROWITZ: 1 5 question, as I'd like to answer some of the others, 15 Great. The next individual l?d like to talk to 1 6 that question in particular, it?s been clear that 16 you about is Jane Doe 6, and if you either write that 17 your ?rm, your partner who's been suspended after 17 down, or get that name in your head so that you remembe 18 filing such a claim of sexual abuse, Mr. Edwards? 18 it when I ask you some questions about her, i would 1 9 partner who?s in jail for probably the rest of his 1 9 appreciate it, okay -- 20 life, probably the rest of his life for filing just 20 THE WITNESS: Mr. Pike -- 21 those types of claims, sexual abuse claimssexual claims of claims of a sexual nature 22 -- Jane Doc 6, okay? 2 3 against people, me and others, to steal money, just 2 3 MR. PIKE: Proceed. 24 it's about money from people in South Florida, 2 4 BY MR. HOROWITZ: so i?d like to answ th All right. You dgn?t deny that Jane Doc 6 came crouch . . 2 (Pages 194 to 197) UN IVERSAL COURT RE PORT ENG (954) 712?2600 (877) 2 (3376) Page 198 Page 200 1 to your home in Palm Beach County in August 2004, do 1 today have told me I may not, and must assert my 2 you? 2 rights, or waive -- potentially waive them, or risk 3 MR. PIKE: Form. 3 losing their representation 4 THE WITNESS: I would very much like to answer 4 BY MR. HOROWITZ: 5 every claim made by your client, Jane Doc 6. 5 Okay. 6 However, today, my attorneys have advised that 6 A -- so, unfortunately, I must respectfully 7 may not. i must assert my rights under the Sixth, 7 decline to answer that question. 8 Fourteenth and Filth Amendment. 8 Did you instruct SK. to communicate by 9 BY MR. HOROWITZ: 9 telephone with E.W. For the purpose of arranging for 1 Now, Jane Doc 6 was only 13 years old when she 1 underage girls to come to your home to give you a 1 1 came to your home; is that right? 1 1 massage? 12 MR. PIKE: Form. 12 MR. Form. 13 WITNESS: Again, it would -- I would prefer 13 THE WITNESS: I'd like to answer each one of 1 4 to answer every single one of your client's Jane 14 your claims here today with specificity. EW. 1 5 Doe 6's claims regarding this case, your claim 1 5 represented by Mr. Edwards sitting next to you, 1 6 against me. However, my attorneys have advised me 1 6 represented by the man who?s currently sitting in I may not do so today. i must assert my rights 17 jail for the perpetrating of the largest fraud in It 8 under the Fourteenth, Filth, and Sixth Amendment. 1 8 Florida?s history, for creating ?ctitious, 1 9 Though I would like to answer each one of your 1 9 malicious cases of a sexual nature against wealthy 2 0 questions, Mr. Horowitz, today, I must respectfully 2 0 people in order to steal money, steal money. The 2 1 decline to do so. 21 US. Attorney called attorneys a criminal 22 BY MR. HOROWITZ: 22 enterprise. So, though I'd like to answer that 2 3 Mr. Epstein, you paid for a taxi to bring 2 3 question, as all your other questions here today, 24 13~year~old Jane Doc 6 to your home in 2004; isn?t that 2 Al my attorneys have instructed right? 2 5 BY MR. HOROWITZ: Page 199 Page 201 1 MRdm??me. 1 2 THE WITNESS: I'm sure, Mr. Horowitz, you?re 2 girls to your home so you could engage in sexual 3 aware that I'd like to answer these questions with 3 activity with these girls; isn?t that right? 4 specificity. I?m sure you're aware that I would 4 MR. PIKE: Form. 5 like to answer each one of these sexually charged 5 THE WITNESS: Again, E.W. represented by 6 questions, questions similar to the ones you've 6 Mr. Edwards' ?rm, and former her former 7 asked before. I have to respond in a similar way, 7 attorney, Mr. Scott Rothstein, sits in a county 8 which unfortunately, my counsel has advised me i 8 jail probably for the rest well, at least a 9 must take their advice, which is to claim the 9 federaijail for the rest of his life for 1 0 Sixth, Fifth and Fourteenth Amendment Rights, 1 fabricating cases of a sexual nature against 1 1 because by not doing so, i may waive those rights, 1 1 wealthy people in South Florida in order to steal 12 or risk losing their representation. 12 money from unsuspecting investors. It would give 13 BY MR. HOROWITZ: 13 me pleasure to be answer to be able to answer 14 in 2004 did you receive a phone call from a 14 your questions today with specificity. However, my 15 girl named EW. in which she told she was bringing Jane 15 attorneys have counseled me that at least today, I 16 Doc 6 to your home for a massage? 16 may not do so excuse me without waiving my MR. PIKE: Form. 17 rights and risking their representation risk 18 THE WITNESS: believe E.W. is 1 8 losing their representation. 19 represented by the man sitting next to you, 19 BY MR. HOROWITZ: 20 Mr. Edwards, though Mr. Edwards' partner, the one 20 Mr. Epstein, in 2004 did you instruct SK. to 2 1 who's in jail for bringing cases of a sexual 2 1 make contact with E.W. by telephone so that arrangement 22 nature, sexually charged nature against people like 22 could be made for Jane Doc 6 to come to your home for 2 3 me and others, so, though I'd like to answer all 2 3 your sexual grati?cation? 2 4 your questions regarding E.W., and like Miss lane 2 4 MR. PIKE: Form. 25 Doc 6 and her and their claims, my attorneys 2 5 cream. st mm . 1- . anew straws-m THE WITNESS: Okay. I would like to swer the 3 (Pages 198 to 201) UNIVERSAL COURT REPORTING (954) 712*2600 (877) 291-DEPO (3376) .E?Ad?aii trustees?; {$1.83 $2.95 ?ea 523.4 starts; armies meme-ease ilil'?ir?v?i?m??mz teams Knitted sf?dm?rh?i xii} waswsi?umuamamnwara ?at K235131352: alert-emu Waite Eli disagreements: narrates. 9452?: F4514merznn-rm. .62?:th Page 202 Page 204 1 claims of Jane Doe 6. I would very much like to 1 Dee 6's claim, which i would like to answer, but today, 2 answer the claims of your Mr. Edwards' 3W. It 2 under advice of counsel, they have instructed me that 3 would be nicer if Mr. or I would appreciate it 3 may not, and I should claim my Sixth Amendment, 4 unfortunately but Mr. Edwards's partner who 4 Fourteenth Amendment and Fifth Amendment Right. 5 represented E.W. along with him is injail for 5 BY MR. HOROWITZ: 6 misrepresenting or the U.S. Attorney has called 6 Did you confirm with SK. that she did, in 7 his ?rm a criminal enterprise, the one 7' fact, speak with B.W. by telephone to confirm a specific 8 representing previously representing E.W. You 8 time that Jane Doe 6 would be at your house? 9 represent Jane Doe 6. l?d like to answer her 9 MR. PIKE: Form. 10 claims, but today my attorneys have counseled me 10 THE WITNESS: I'd like to answer each and every 1 1 that I must respectfully decline and assert my 1 1 one of your questions, Mr. Horowitz, regarding the 12 rights under the Fourteenth, Sixth and Fifth 12 claims of these of Jane Doe 6 and E.W. However, 1 3 Amendment. 1 3 today, on advice of counsel, I am going to have to 1 4 BY MR. HOROWITZ: 14 simply claim the Fifth, Sixth and Fourteenth 15 Did you inform that the massage that Jane 1 5 Amendment Rightgive you would be sexual in nature? 16 MR. HOROWITZ: 1 7 MR. PIKE: Form. 1 "i Was it your intent during the course of Jane 18 THE WITNESS: Unfortunately, I am going to have 18 Doe 6?s visit to your home that you would persuade, 1 9 to respond to that question the way I've responded 19 induce or entice her to engage in sexual activity? 20 to most of your questions and claims here today 20 A l'd like to answer every question you?ve asked 2 1 regarding Jane Doc 6 and some of your other clients 21 me here today, every single question, especially with 2 2 that you tiled suits for, post ?ling the suit your 22 respect to Jane Doe 6's claims. However, my attorneys 2 3 partner was suspended by the Florida Bar, post 2 3 have instructed me that i must assert my rights under 24 ?ling the suit Mr. Edwards' partner ?nds himself 2d the Sixth, Fourteenth and Fifth Amendment. Though tires 2 5 in jail. 25 claims of a Sexual nature are not that surprising since Page 203 Page 205 1 So, though l?d very much like to answer those 1 Mr. Edwards and who he represents E.W., who's partne 2 questions, my attorneys have counseled me today 2 sits in jail for perpetrating what the US. Attorney 3 that I cannot answer, at least today, any questions 3 called the largest fraud in South Florida's history, 4 relevant to these lawsuits. And if i decide or 4 stealing millions of dollars from unsuspecting local 5 choose to answer the questions, I risk losing their 5 investors. i?d very much like to answer each and every 6 representation and waiving those rights. Excuse 6 one of your questions, but my attorney has told me that 7 me, Adam, ?ve? 7 if I choose to do so, I risk waiving my rights and risk 8 THE WITNESS: Yeah, if you need it. 8 losing their representation. 9 THE Time off the record 3:02. 9 MR. PIKE: I 10 (Thereupon, a short break was taken.) 1 0 THE WITNESS: Sorry. 11 BY MR. HOROWITZ: 11 MR. PIKE: object to form to that questionMR. HOROWITZ: 13 THE VIDEOGRAPHER: Time on the record 3: 12. 13 During the course of Jane Doe 6's visit to your 14 BY MR. HOROWITZ: 14 home, did you succeed in persuading, inducing or 15 Mr. Epstein, we're still talking about Jane Doe 3.5 enticing her to engage in sexual activity with you? 16 6, okay? 16 MR. Form. 17 A Yes. 17 THE WITNESS: I would very much like to answer 18 Mr. Epstein, did you observe SK. speaking with 18 every single question and claim of Jane Doc 6. 1 9 EW. by telephone and making arrangements for Jane Doe 1 9 However, today, my attorneys have advised me that 2 0 to come to your home to give you a message? 2 0 may not. I must assert my rights under the Sixth, 2 1 A l?d like to answer that question. I'd like to 2 3t Fourteenth and Fifth Amendment. Now, i prefer to 22 answer all your questions here today. I believe Miss 2 2 answer. They've told me that if choose represented by Mr. Edwards, who's partner is in 2 3 risk losing their representation and waiving those 2 4 jail for his wrongdoing, for creating cases of sexually 2 4 rights. charged natures. You're asking me a question of Jane riwmzwae. .. BY MR. HOROWITZ: 4 (Pages 202 to 20 UN I VERSAL COURT RE PORT ENG (954) 712*2600 (877) (3376) -- Page 206 Page 208 - 1 All right. Did SK. tell you that she spoke to 1 av MR. HOROWITZ: 2 anyone on the phone who arranged for Jane Doc 6 to come 2 Sir, when lane Doc 6 came to your home in 2004 3 to your house? 3 when she was 13 years old, you didn't, in your own mind, 4 MR. PIKE: Form. 4 believe her to be 18 years old or older, did you? 5 THE WITNESS: Again? I'm sorry, Mr. Horowitz. 5 MR. PIKE: Form. 6 BY MR. HOROWITZ: 6 THE WITNESS: Repeat the question, please? "i Did SK. tell you she spoke to anyone on the 7 BY MR. HOROWITZ: 8 phone -- on the phone to make arrangements for Jane Doc 8 Sure. When you looked at Jane Bee come to your home? 9 and she was in your home, you didn't believe her to be 10 MR. PIKE: Same objection. 10 18 years old or older, did you? 1 1 THE l'd very much like to answer 11 "fl-1E WITNESS: l?d like to answer each one of 1 2 every question regarding these claims here today. 3.2 your 1 3 However, my attorneys have advised me that at least It 3 MR. PIKE: Same objection. 14 today, I must assert my rights under the 14 THE excuse me. I'd like to answer 15 Fourteenth, Sixth and Fifth Amendment. And though 15 each one of your claims today. However, my 1 6 i prefer to answer the question, if I choose to do 1 6 attorneys have counseled me that I may not. They 1? so, I risk losing those rights and their have instructed me to assert my rights under the 1 8 representation. 1 8 Fourteenth, Sixth and Fifth Amendment. 1 9 BY MR. HOROWITZ: 1 9 Though I?d like to answer each one of those 20 Okay. You asked Jane Doe questions, l?d like to answer that question 2 1 when she came to your home; is that right? 2 1 directly to your partner, Jeffrey Herman, that in 22 MR. PIKE: Form. 22 fact brought this claim, but he has been suspended 23 THE WITNESS: Again, like the other questions 23 by the Florida Bar, or the claims directly to 2 4 you've asked me regarding your claims of Jane Doe 2 4 Mr. Edwards' partner who sits in jail for 2 5 6, l'd like to answer each one. However, today, my 2 5 fabricating cases of a sexual nature against Page 20? Page 209 1 attorneys have advised me that i may not. I must 1 wealthy people in South Florida. 2 assert my rights under the Sixth, Fourteenth and 2 I'd very much like to answer, but according to 3 Fifth Amendment. Though I prefer to answer that 3 my counsel I may not answer those, or i may waive 4 question, i prefer to answer that question directly 4 my rights or risk losing their representation. 5 to the your partner that brought this claim, but 5 BY MR. HOROWITZ: 6 i guess he's been suspended or disbarred by the 6 During the course of Jane Doe 6?s visit to your 7 Florida Bar, or I'd like to answer it to 7 home in 2004, were you nude in her presence? 8 Mr. Edwards' partner who sits in a jail for 8 MR. PIKE: Form. 9 crafting, fabricating malicious claims simply to 9 THE WITNESS: I'd very much would like to 0 get money. I'd very -- as you probably recognize, 0 answer each and every question regarding Jane Doe i. 1 I?d like to answer those questions today, but i 1 6's claims. However, my attorneys have told me i. 2 under the instructions of counsel, I must 1 2 today that I may not. i must assert my rights 3.3 respectfully decline. 1 3 under the Fourteenth, Sixth and Fifth Amendment. 1 4 BY MR. HOROWITZ: 1 4 Though I prefer to answer, I'm told that if i 5 Sir, there was never a point in time when Jane 1 5 choose to do so, 1 risk losing their representation 16 Doe 6 told you that she was ill years old or older; isn?t I 6 and waiving thosc rights. 1? that right? 1 7 BY MR. HOROWITZ: 18 MR. PIKE: Form. 18 During the course of Jane Doe 6's visit to your 19 THE WITNESS: Like all your other questions 1 9 home in 2004, did you instruct Jane Doc 6 to remove he 2 0 regarding Jane Doe 6 and her claims, l?d very much 2 clothing? 2 1 like to answer each and every one. However, today, 2 1 MR. PIKE: Form. 2 2 my counsel has advised me that I may not, and must 22 THE WITNESS: I'd like to answer each and every f; 2 3 assert my rights under the Fourteenth, Fifth and 2 3 one of your questions here today and the claims of 2 4 Sixth Amendment. And if I choose to answer, risk 2 4 Jane Doc 6. However, my attorneys have advised me, 25 meant-3.3; . . . losin their counsel and waivin those rihts. 25 .zife-glemymwu at least today, that my rights under ?lms?; 5 (Pages 206 to UNIVERSAL COURT REPORTING (954) 7122600 (877) (3376) I 209 Page 210 Page 212 the Fourteenth, Sixth and Fifteenth and Fifth 1 MR. PZKE: Form. 2 Amendments of the US. Constitution. Though I 2 THE WITNESS: i'd very much like to answer each 3 prefer to answer, they?ve instructed me that if I 3 and every one of Jane Doe 6's claims. However, my 4 choose to do so, I risk waiving those rights and 4 attorneys today have instructed me that I may not 5 losing their representation. 5 answer today, and that I must assert my rights 6 BY MR. HOROWITZ: 6 under the Sixth, Fourteenth and Fifth Amendment. During the course of Jane Doc 63 visit to your 7 Though i'd like to answer the question, they've 8 home in 2004, did you instruct Jane Doc 6 to pinch your 8 instructed me that if I do, I risk losing their 9 nipples and rub your chest? 9 representation and waiving those rights. 3. 0 MR. PIKE: Form. 1 0 BY MR. HOROWITZ: 1 THE WITNESS: As I've answered most of your 1 1 in 2004 did you rub Jane Doe 6's vagina? 1 2 other questions here today, Mr. Horowitz, it would 12 MR. PIKE: Form. 1 3 give me great pleasure to be able to answer these 1 3 THE WITNESS: That question, like most of your 14 claims of lane Doc 6. However, my attorneys have 14 other questions here today, I would prefer to 3.5 instructed me that I may not, and that I must 15 answer. I?d like to answer. I'd like to answer 1 6 assert my rights under the Fourteenth, Sixth and 1 6 directly to your partner who is no longer here Fifth Amendment because they told me that if I do 17 because he's been suspended after he filed this 18 so, I risk losing their representation and waiving 18 claim, suspended by the Florida Bar for filing 19 those rights. 19 not for filing, but after he filed the claim. I 20 BY MR. HOROWITZ: 2 0 prefer to answer directly to Mr. Edwards? partner 21 During the course of Jane Doe 6's visit to your 2 1 who sits injail for the rest of his life, for the 22 home in 2004, did you ask Jane Doc 6 about her sexual 22 rest of his life, for filing and misleading 23 experience and preferences? 2 3 ?ling malicious claims, make fabricating claims 24 MR. PIKE: Form. 24 against people like me and others in South Florida, 25 THE WITNESS: it would give me great pleasure 25 stealing money -- millions of dollars from Page 211 Page 213 1 to answer each one of your questions and Jane Doc 1 investors. So I would like to answer each one of 2 6'3 claims. However, my attorneys have instructed 2 your questions with speci?city. However, my 3 me today that I may not, and that i must assert my 3 attorneys have advised me today that I may not. 4 rights under the Sixth -- excuse me ?Fifth and 4 BY MR. 5 Fourteenth Amendment. Though I would prefer to 6 In 2004 in 2004 did you masturbate by 6 choose to answer those questions, my attorneys have 6 stroking your penis in front of Jane Doe 6? 7 7 8 representation and waiving those rights. 8 THE WITNESS: I'd like to answer each one of 9 BY MR. HOROWITZ: 9 your questions regarding lane Doe 6's claims. 1 0 In 2004 did you touch Jane Doe 6's breasts? 10 However, my attorneys have advised me that today I ll H. 12 THE WITNESS: Like many of your other questions 12 suspended after he filed this claim, Mr. Edwards? 13 here today, there he -- I'd very much prefer to 3.3 partner sits injail, my attorneys have advised me 1 4 answer that question, as your other questions with 1 4 still that I must assert my rights under the 15 specificity. However, my counsel has advised me 1 5 Fourteenth, Sixth and Fifth Amendment. And if I 16 that I. may not. I must assert my rights under the 16 choose to answer, which is my preference, that I 17 Fourteenth, Sixth and ii?th amendment. So though 1 17 risk losing their representation and/or waiving 1 8 choose would choose to answer that, my attorneys 1 8 those rights. 1 9 told me that if I do, i risk losing their 1 9 BY MR. HOROWITZ: 2 0 representation and potentially waiving those 2 0 In 2004 did you ejaculate after stroking the 2 1 rights. 2 shaft of your penis in front of Jane Doc 6? 22 BY MR. HOROWITZ: 22 MR. PIKE: Form. 23 Did you touch Jane Doe 6's breasts even after 23 THE WITNESS: I?d like to anSWer each one of 2 4 she made attempts to walk away from you during her visit 24 Jane Doe 6?s claims, and all the questions each 25 in 2004? 2 and every uestion ou?ve asked me here toda . I'd ?mmi?m? .e - i 6 (Pages 210 to 213) i UNIVERSAL COURT REPORTING (954) 712*2600 (877) (3376) 2x?3?9?? . Page 214 Page 216 1 like to answer it directly to your partner. 1 as well as every other question you've asked me 2 However, he?s been suspended by the Florida Bar 2 here today, but I'm going to have to reSpond in a 3 3 4 directly to Mr. Edwards' partner who sits in jail 4 though I'd like to answer the question, my counsel 5 for fabricating cases of a sexual nature against 5 here has advised me that i may not, and must assert 6 wealthy people in South Florida, in jail 6 the rights under the Sixth, Fourteenth and ifth '7 potentially for the rest of his life. So though 7 Amendment; otherwise, risk losing their 8 I?d like to answer those questions, my attorneys 8 representation and/or waiving those rights. 9 have counseled that i may not. i must assert those 9 BY MR. HOROWITZ: 1 0 rights or risk losing their representation and/or 1 Did you ever ask Jane Doe 6 for permission to 1 waiving those rights. 1 1 touch her breasts? 1 2 BY MR. HOROWITZ: 1 2 MR. PIKE: Form. 13 in 2004 did you walk across the room naked and 13 THE WITNESS: These claims of Jane Doc 6 woul 4 enter a shower in front of Jane Doe 6? 4 give me great pleasure to answer, especially with 15 MR. PIKE: Form. 15 speci?city with Jane Doe 6, your client. it?s 1. 6 THE Again, as I've answered most of 6 unfortunate that your partner couldn't be here to your questions here today, it would give me great 1 hear some of these responses since he's been 1 8 pleasure, in fact, to answer the claims of Jane Doe 3. 8 disbarred no, not disbarred you?ve corrected 1 9 6. However, my attorneys have advised me that 1 9 me -- he?s only been suspended by the Florida Bar 2 0 may not, and must assert my rights under the Sixth, 2 0 for impmper behavior after he ?led this case. 2 1 Fourteenth and Fifth Amendment. Though I prefer to 2 1 Mr. Edwards's partner sits in jail. Though I?d 22 answer those questions, my attorneys have told me 2 2 like to answer -- as you might imagine, I'd like to 23 that if I choose to do so, I risk losing their 23 answer these questions. My counsel has advised me 24 representation. And I would prefer to tell your 2 4 that if i do so, I risk losing his representation. 25 partner directly who filed this claim, who's 25 BY MR. HOROWITZ: Page 215 Page 217 1 subsequently suspended by the Florida Bar. I would 1 Isn?t it true, sir, that Jane Doe 6 indicated 2 prefer to tell Mr. Edwards' partners, but he's in 2 to you that she did not want you to touch her body? 3 jail with now i guess most of his other many 3 MR. PIKE: Form. 4 of his other partners are on their way for ?ling 4 THE WITNESS: It would give me great pleasure 5 malicious claims. So though i'd like to answer 5 to answer each question and claim of lane Bee 6 and 6 that question, Mr. Horowitz, here today, I must 6 your client. However excuse me however, my 7 respectfully decline to do so. 7 counselors advised. me today that i may not, and 8 BY MR. HOROWITZ: 8 must assert my rights under Sixth, Fourteenth and 9 Did you have sexual contact with Jane Doe 6 at 9 Fifth Amendment. 10 your Palm Beach home in 2004? 3.0 BY MR. I-IOROWITZ: 1 1 MR. PIKE: Form. 1 1 isn?t it true, sir, that you touched Jane Doe 12 THE WITNESS: I would like to answer each and 12 6?5 breasts after she indicated to you that you did not 1 3 every claim of Jane Doe 6 and all your other 1 3 -- that she not want you. to touch her? 14 clients. it would be -- give me pleasure to be 1 4 MR. PIKE: Form. 1 5 able to answer those questions directly to your 1 5 MR. HOROWITZ: I am going to clean up that 1 6 partner, but he's been suspended after he ?led 1 6 question. I probably didn?t ask it right. these claims. must assert those rights, even BY MR. HOROWETZ: 1 8 though I would prefer to answer the question, or 1 8 Isn't it true, sir, that you touched Jane Doe 1 9 risk losing the representation of my counsel and 1 9 63 breast after she indicated she did not want you to 2 0 inadvertently waiving those rights. 2 touch her? 2 1 BY MR. HOROWITZ: 2 1 MR. PIKE: Form. 22 Did you pay $200 to Jane Doe 6 alter having had 22 THE WITNESS: I'd like to answer that question, 2 3 sexual activity with her? 2 3 like every other question you?ve asked me here 2 4 MR. PIKE: Form. 2 4 today, mostly every question. It's unfortunate I 25 can't make that answer directly to your partner who 23:33:; a'p?yx'maarrae?sstr" . Amie-Snow.th . 7 (Pages 214 to 217) UNIVERSAL COURT REPORTING (954) 712?2600 (877) (3376) Page 218 Page 220 1 '1 2 partner who sits in jail. But though I?d like to 2 Mr. Edwards' who sits there while his partner stays 3 answer those questions, my counsel has advised me i 3 in jail -- yes, he finds it, i guess, very funny. 4 must assert my rights under the Sixth, Fourteenth 4 I don't ?nd it that funny. 5 and Fifth amendment. So though I?d like to answer; 5 Well, I'd like to answer each one of the 6 it would be my preference to answer. He's told me 6 questions about Miss E.W. and Miss lane Doc 6. ?i that if i do so, I risk losing his representation 7 However, my attorneys have told me today that I ma 8 and/or waiving those rights. 8 not, and that I must assert my rights under the 9 BY MR. HOROWITZ: 9 Sixth, Fourteenth and Filth Amendment. So, though 10 Mr. Epstein, did you try to persuade 13?year? 10 I'd like to answer all the questions regarding ways 1 1 old Jane Doc 6 that it was okay for you to touch her 11 that these girls are trying to get money, be it 1 2 breast and masturbate by stroking your penis in front of 2 from me, or from Mr. Rothstein?s other victims, I 1 3 her? 1 3 must assert those rights, or, in fact, according to 1 4 MR. PIKE: Form. 14 my counsel, lose risk losing his representation 15 THE WITNESS: Mr. Horowitz, it would give me 15 and waiving those rights. 16 great pleasure to answer every one of Jane Doc 65 1 6 MR. PIKE: All right. Now, that -- now, that 1 '7 claims, every one. However, my counsel has advised 17 Mr. Epstein is done answering that particular today, and that i must assert 18 question and responding, do we do we need a 3. 9 those rights. I would much prefer to answer it to 9 break, because i?m i?m not comfortable with the 20 your partner who ?led this claim, Mr. Jef??ey 20 way in which the laughing is going forward and 2 Herman, but he?s been suspended by the Florida Bar 2 1 things of that sort? 22 after he ?led this claim for improper behavior, or 22 MR. EDWARDS: Okay. Well, I I found that 2 3 Mr. Edwards' partner who sits in jail after he 2 3 answer pretty funny, and I want to make sure that 24 tiled their claims. So though I'd prefer I 241 understand the answer so that I know if I have to 2 5 would like to answer, my counsel has advised me 2 5 take any legal action whatsoever. What Page 219 Page 221 1 that if I choose to do so, 1 risk losing his 1 understand the answer to be was that Mr. Epstein is 2 representation andior waiving those rights. 2 making the accusation now that B.W. is my 3 BY MR. HOROWITZ: 3 prostitute. That's 4 Okay. Sir, you don?t deny that you sexually 4 THE WETNESS: Oh, no, that?s not correct. 5 abused lane Doc 6 when she was a child, do you? 5 MR. EDWARDS: w? that's what i heard, right? 6 MR. PIKE: Form. 6 That's what everybody in the room heard. 7 THE WITNESS: The question about sexually 7 MS. EZELL: That's -- that?s that's what i 8 abusing, which was in fact one of the cases that 8 heard. 9 Mr. Rothstein?s i mean, Scott Rothstein?s 9 MR. Okay. First of all 1 0 Mr. Edwards sits ther Mr. Rothstein sits in 0 MR. HOROWITZ: That?s what i heard. 1 1 jail for his accusing people of sexual harassment, 1 1 MR. EDWARDS: That is not true. 12 sexual abuse, and in order to steal money from 12 MR. PIKE: i?ll tell you what, we're going 1 3 local Florida investors. l?d like to answer every 1 3 to take a break we?re going to take a break 1 4 question about Jane Doe 6?s claim of sexual abuse. 1 4 now. That is not the way that I interpreted the 1 5 However, my counsel today has informed me that i 15 response. The response was that she made a 1 6 may not answer today. And though as you might 1 6 she's an admitted prostitute, and that she was a guess, i?d like to answer those questions, heis 17 client of yours. if we?re going to be playing 18 informed me if choose to do so, I risk losing his 1 8 games with semantics, then we will do that at 1 9 representation and/or waiving those rights. 1 9 another date by motion practice, but we're not 20 BY MR. 20 going to -- this is not the form in which to do 2 1 Sir, did you pay SW. for bringing Sane {Joe 6 2 1 this, laughing, playing games with words. 2 2 to your home in 2004? 2 2 Everybody in this room knew exactly what the 2 3 MR. PIKE: Form. 2 3 response was. And remember something, this is -- 2 4 THE WIWESS: I -- if EW. so i?m clear, I 2 4 MR. EDWARDS: Right, it is -- 25 25 vavava mm 4m ea believe ELW. has filed a claim as an die MR. PIKE: Remembesomethin,this i a 8 (Pages 218 to 221) UNIVERSAL COURT REPORTING (954) 712?2600 (877) (3376) seamless smith! "hail-Esthitil? ?6325! 3:5 Wm; mwmerot it? terse i-i i?tito?ez?d. tamuiasasam nation-mere: it w?d?s?f? XS ind-3 1% 3:2 it ?is int M?s: mm 55-bit 5.61%- R-ti?c-Sii rautmaasma {attest 33.187: tat-Ra? m2 hi . awwewma-?W mam-vow Mz 09-941?th Page 222 Page 224 and you represent someone, and as a result, no 1 if I misspoke, I apologize. Your client is an .2 matter which way you interpret some response, there 2 admitted prostitute, and that's what I meant to 3 are various privileges that attach to litigation. 3 say. 4 If you want to threaten legal action here in 4 MR. HOROWITZ: Okay. Move to strike. Okay. I 5 this form, then you can go ahead and do so on 5 -- 6 record. So is that what you were doing? 6 MR. PIKE: Wait, wait. Hold on one second. 7 MR. EDWARDS: Well 7 MR. HOROWITZ: I know you want to take a 8 MR. PIKE: Were you threatening -- were you 8 break, but -- 9 threatening i want to be clear 9 MR. PIKE: No, I I i don?t want to take a 10 MR. EDWARDS: If 1 0 you just moved to strike something that we just 1 1 MR. PIKE: in this deposition right now, 11 spent seven minutes going back and forth with 3. 2 wer 1 2 pursuant to Mr. Edwards' request. Do you want to 1 3 MR. EDWARDS: Oh, I'll be very clear. 1 3 withdraw that? 14 MR. PIKE: were with threatening Mr. Epstein 1 4 MR. HOROWITZ: No. But if you want to no. 15 with legal action? 15 MR. PIKE: Okay. All right. Next question. 3. 6 MR. EDWARDS: If the accusation is that B.W. is 1 6 BY MR. HOROWZTZ: l7 a prostitute of mine, then I want to know that that 17 Mr. Epstein, we?ve been -- we?ve been talking 18 is the the allegation, and that is clearly his 18 about Jane Doe 6 a bit, and you've mentioned names like 19 position, so that if legal action is to be taken, 1 9 Jeffrey Herman and Scott Rothstein. Are you suggesting 20 it can be, but I was giving him a chance to clarify 2 0 that in any way her allegations of sexual abuse were 2 3. that or correct that, if that was not the correct 2 1 fabricated or embellished by virtue of her attorney or 2 2 interpretation, but that's what everybody in the 22 -- or somehow through Mr. Rothstein's dealings? 23 room heard. That?s what?s going to be very clear 23 MR. Form. 24 on the record. Ms. Ezell is nodding her head. 2 4 THE WITNESS: It's been validly reported that 2 5 Everybody heard 2 5 Mr. Rothstein crafted, fabricated malicious Page 223 Page 225 1 MR. PIKE: Listen 1 lawsuits of a sexual nature in order to steal 2 MR. EDWARDS: that statement or sentence. 2 millions of dollars from local Florida investors. 3 MR. PIKE: -- this 3 With respect to any question with that may be it MR. HOROWITZ: Can we can we move on? 4 relevant to this lawsuit. However, my attorneys 5 MR. PIKE: No, we can't. Once again 5 have advised me today that I must respond by taking 6 MR. HOROWITZ: It?s not your deposition. 6 the Sixth, Fourteenth and Fifth Amendment. 7 THE REPORTER: Wait a second. 7 Though I choose to -- I would prefer to answer 8 MR. PZKE: Once again, this is not 8 the questions, Mr. Horowitz, that you?ve asked me 9 MR. EDWARDS: Let?s read it back. 9 regarding your claims your client's claims, my 10 MR. PIKE: No, we're not going to reread it. 10 attorneys have told me that if I choose to do so, I 1 1 We're not going to go back and reread it. I 1 risk losing their representation and waiving those 1 2 Mr. Epstein not only answered. the question, but 1 2 rights. 1 3 then he also corrected you and said that was not 1 3 BY MR. HOROWITZ: 4 the appropriate response. 14 All right. Are I want to be clear about 1 5 HOROWITZ: Okay. 3.5 this one. Are you it 6 MR. PIKE: Now, if you would 1 6 A Okay. 17 MR. HOROWITZ: That?s line. suggesting that Miss Jane Doc 6 in any way 1 8 MR. PIKE: Now, if you would, you can rephrase fl 8 fabricated or embellished her claim alter retaining an 1 9 your response briefly to 1 9 attorney? 2 i?l-IE WETNESS: Mr. Edwards represents an 2 0 MR. PIKE: Form, asked and answered. 2 admitted prostitute, B.W. These claims are made by 2.3. THE WITNESS: The partner of your partner 2 2 admitted prostitutes. They ?led claims under a 2 2 has been suspended from the practice of -- Florida 2 3 section of the Florida?s law of admitted 2 3 Bar practice after he ?led Jane Doe 6?s claim. 2 a prostitutes. So the claims here that it was his 2 4 Mr. Edwards? partner, Scott Rothstein, sits in client as osed to his rostitutejail rebany for the rest of his life for 2 .. .mxrmamm . awe-3c 9 (Pages 222 to 225) UNIVERSAL COURT REPORTING (954) 712?2600 (877) 2 (3376) were; ?563?! streamers steamers triers-er. {Statute} reg: an} resumes {m 23.5 more it ?tt?ah?l? is ill} 5X83 mm?ti?i?? mag-35:59? restarts-easing: Cit rm?ntmw-wwkwa AE'dem?Jz?tm my ?5.1mm. . ham x. Page 226 Page. 228 1 fabricating malicious claims of a sexual nature 1 privilege as anything but the rights of an 2 against wealthy people in South Florida. 2 American, to assert rights under the Constitution, 3 I?d like to answer your questions with more 3 I ?nd disturbing. I ?nd it disturbing that your 4 specificity. However, my attorneys have counseled 4 partner who?s been suspended, the claims of your 5 me that I may not today; I must assert my rights 5 clients, Mr. Edwards? clien whose paltner and 6 5 7 I though I choose -- prefer to answer those 7 ?rm that?s been called by the US. Attorney as the 8 questions, Mr. Horowitz, my attorney said that ifI 8 largest criminal enterprise, or the largest fraud 9 choose to do so, I risk losing their representation 9 in South Florida?s history. I I ?nd it and waiving those rights. 1 0 disturbing that you?d question the reasons I would 1 BY MR. HOROWITZ: assert my Constitutional rights. 1 2 Given that you have asserted your Fifth 1 2 BY MR. 13 Amendment privilege, is there any reason ajury should 13 Okay. And you're but you're you're 14 not infer from your testimony that you did in fact 1 4 refusing to tell us why you're asserting the Fifth 5 sexually abuse Jane Doe 6 when she was just a 13?year? 1 5 Amendment; is that right? 6 old girl? 3. 6 A I've answered your question. 1 7 MR. PIKE: Form. 1 7 MR. PIKE: It's attorney-client work product. 18 THE. WITNESS: The Fifth Amendment, of my 1 8 MR. HOROWITZ: How much time left on the tape 9 understanding, is to be used as well to protect 9 THE VIDEOGRAPHER: Nine minutes on this tape 2 1 from malicious false claims, including those made 2 1 change tapes? 2 2 by Mr. Edwards' partner, Scott Rothstein, who sits 2 2 MR. PIKE: Yes. 2 3 in jail at the moment probably for the rest of his 2 3 MR. HOROWITZ: Let's change tapes 2 4 life for crafting these malicious false claims. 2 4 THE VIDEOGRAPIIER: Time off the record 3:41. 25 The Attorney called his firm one of the largest 25 MR. HOROWITZ: Great. Page 227 Page 229 criminal enterprises in South Florida?s history. I (Thereupon, a short break was taken.) 2 will be -- my -- I would prefer to answer your 2 THE VIDEOGRAPHER: Time on the record 3:47. 3 questions with speci?city, but my counsel today 3 This is ape 5. 4 has told me that 1 may not, and I must -- excuse me 4 BY MR. nonowrrz: 5 assert my rights under the Sixth, Fourteenth and 5 Mr. Epstein, my next series of questions 6 Fifth Amendment. Though I prefer to answer those 6 involves a one of our clients by the name of Jane Doe 7 questions, he?s advised me that if I choose to do 7. You may know her as Jane Doc 7 as wellrisk losing those rights and losing his 8 can either write that name down or keep it in your mind 9 representation. 9 so we?re on the same page as to who -- who we're talking 1 0 BY MR. HOROWITZ: 1 0 about, I would appreciate it, okay? 1 1 In this case are you asserting the Fifth A (Witness complying). 1 2 Amendment in order to protect your innocence or to 1 2 Isn't it true that a girl named Sane Doe 7 came 3 conceal your guilt? 1 3 to your home on multiple occasions between 2003 and Ma 4 MR. PIKE: I am going to instruct him not to 14 of 2005? 5 answer that question. It?s attorney~client work 1 5 MR. PIKE: Form. 3.6 product. is run WITNESS: I'd like to answer your those BY MR. HOROWITZ: 3.7 questions -- excuse me -- Mr. Horowitz, but today 1 8 Isn't it true, sir, that you?re the 8 my attorney has counseled me that I must assert my 1 9 Fiith Amendment privilege here to conceal your own 1 9 Sixth Amendment, Fourteenth Amendment and Fifth 2 wrongdoing? 2 0 Amendment Right. 2 1 MR. PIKE: Same objection. 2 1 BY MR. HOROWITZ: 22 THE WITNESS: May I answer? 22 Prior to May of2005 did you receive a phone 2 3 MR. PIKE: This one, yeah. 2 3 call from a girl named HR. advising you that she was 2 4 THE WITNESS: I think -- I Mr. Horowitz, to 2 4 bringing Jane Doc 7 to your home to give you a massage? assume simply that I?m asserting my Fifth Amendmein MR. PIKE: Form. (Pages 226 to 229) UNIVERSAL COURT REPORTING (954) 712*2600 (877) (3376) Page 230 Page 2 32 1 THE WITNESS: l?d like to answer every one of 1 . BY MR. HOROWITZ: 2 the claims of your clients today. However, my 2 At any time prior to May 2005 did you confirm 3 attorneys have counseled me that today at least, 3 with SK. that she had Spoken to Jane Doc 7 by telephone 4 that I must simply assert my Fifth, Sixth and 4 and that Jane Doc 7 would be coming to your home to giv 1i 5 Fourteenth Amendment Right. 5 you a massage? 6 BY MR. HOROWITZ: 6 MR. PIKE: Form. 7 At any time prior to 2005 did you instruct SK. 7 THE WITNESS: i?d very much like to answer 8 strike that. 8 every one of Jane Doe 7?s claims with specificity, 9 At any time prior to 2005 did you instruct SK. 9 but unfortunately, like many of your other 1 to communicate with HR. by telephone to arrange for 10 questions today, Mr. Horowitz, my attorneys have 1 1 Jane Doe 7 to come to your home for a massage in which 1 counseled me that I may not answer any questions 12 you would pay her money? 12 that may be relevant to a lawsuit, or any of your 1 3 MR. PIKE: Form. 3. 3 lawsuits. 1 4 THE WITNESS: I would very much like to answer 1 4 Unfortunately, your partner after he ?led this 1 5 each and every question you?ve asked me here today, 15 lawsuit was suspended by the Florida Bar, so he's 1 6 but like many of your other questions, I am going 1 6 not here. Mr. Edwards's partner, who sits in jail, It"? to have to assert my Fourteenth excuse me -- 17 is not here. So these claims of a sexual nature 1 8 Fourteenth, Fifth and Sixth Amendment Rights as 1 8 would give me great pleasure to be able to answer 1 9 advised by my counsel. Though I choose and prefer 9 with Speci?city, but i'm told that if I choose to 20 to answer that question, my attorney said that if I 20 do so today, my risk losing the representation 2 1 do so, I risk losing their counsel and waiving 21 of my counsel and waiving my rights. 22 those rights. 22 BY MR. HOROWITZ: .2 3 BY MR. HOROWITZ: 2 3 Was it your intent during the course of Jane 2 4 Did you inform SK. that the massage lane Doe 7 24 Doe 7's visit to your home, that you would either 2 5 was to give you would be sexual in nature? 2 5 persuade, induce or entice her to engage in sexual Page 231 Page 233 1 MR. PIKE: Form. 1 activity with you? .2 THE WITNESS: i?m sure the claims of sexual 2 MR. PIKE: Form. 3 the claims the sexual claims made by your 3 THE WITNESS: I'd very much like to answer 4 client, lane Doc 7, that would give me great 4 every one of Jane Doe 7's claims with respect to 5 pleasure to answer with speci?city. However, 5 any sexual nature of any of her claims. However, 6 today, I may I cannot do so on advice of my 6 my attorneys have counseled me that today at least, 7 counsel who's instructed me to assert my Fifth, 7 I may not, and must assert_my rights under the 8 Sixth and Fourteenth Amendment Right. He told me 8 Fifth, Fourteenth and Sixth Amendment. And thoug 9 that if I choose to answer those questions, which 9 I?d prefer to answer those questions, they've told 1 is my preference, that I would risk losing his 1 0 me that if i choose to do so, i risk losing those 1 1 representation and waiving those rights. 1 1 rights and their representation. 1. 2 BY MR. HOROWITZ: 2 BY MR. HOROWITZ: 13 Did you observe S.K. speaking with HR. by 3 During the course of Jane Doe 7?s visits to 1 4 telephone while making arrangements for Jane Doe 7 to 14 your home, did you succeed in persuading, inducing or 1 5 come to your home for a massage? 15 enticing her to engage in sexual activity with you? 1 6 MR. Form. 16 MR. PIKE: Form. 17 THE WITNESS: [would very much like to answer 17 THE WITNESS: Mr. Horowitz, i?d like to answer? 1 8 each and every one of your questions today i 8 each and every one of your questions posed here~ 19 especially with respect to Jane Doe 7 and her it 9 today, but like most of the other questions, I am 20 claims. However, today, on advise of my counsel, 20 going to have to answer the same way because my 2 they?ve asked me to assert my Fourteenth, Sixth and 2 attorneys have counseled me that I must assert my 22 Fifth Amendment Rights. So, though i?d prefer to 22 Fifth, Sixth and Fourteenth Amendment Rights. 2 3 answer those questions, l'm told that ifI choose 2 3 Though I prefer to answer those questionsrisk losing their representation and 2 4 be much prefer the fact to answer it to your 2 5 3 waivin rights. . .musasmasmrer-mwvw artner- who filed this claim e, he's 11 (Pages 230 to 233) COURT REPORTING (954) 712?2600 (877) (3376) :4 . mm arenas-My?, . . Page 234 Page 236*: 1 1. 2 bar. 2 Jane Doc 7 told you she was in school at Royal 3 I would also like to speak directly to 3 Palm Beach High School; isn?t that true? 4 Mr. Edwards? partner, but he's in jail for 4 MR. PIKE: Form. 5 falsifying claims of a sexual nature against 5 THE WITNESS: As most of your other questions 6 wealthy people, stealing investors' monies and from 6 here today, Mr. Horowitz, I'd like to answer all of 4? 7 people in South Florida, and Mr. Edwards? firm 3? those questions, each question, especially with 8 being accused by the US. Attorney of being a 8 respect to Jane Doe 7. However, my attorneys have 9 criminal enterprise, and perpetrating one of the 9 counseled me that at least today, I must assert my 1 0 largest frauds in South Florida histories hyjust 10 rights under the Sixth, Fifth and Fourteenth 1 1 these types of cases. i. 1 Amendment. Because though I prefer to answer the 12 BY MR. HOROWITZ: 3.2 questions, they have told me that if I choose to do 13 Mr. Epstein, you asked Jane Doe risk losing their representation and/or 1 4 was in 2003; isn't that right? 1 4 waiving those rights. 1 5 MR. PIKE: FormTHE WITNESS: i would like to answer each and 1 6 Prior to May of 2005 were you ever nude in 1 7 every one of your questions, Mr. Horowitz. front of Jane Doc 7? 1 8 However, today, my attorneys have counseled me that 1 8 MR. Form. 19 may not answer any questions that may be relevant 19 THE WITNESS: I?d like to answer each one of 20 to any of your lawsuits, so i must assert my Fifth, 20 Jane Doe 7?s claims, each one speci?cally. . 2 1 Sixth and Fourteenth Amendment Rights. And though 2 1 However, today, my attorneys have counseled me the 2 2 I would prefer to answer those questions, each 2 2 i may not, and that i must assort my Fourteenth -- 2 3 question, my attorneys have told me that if I 2 3 my Fourteenth, Sixth and Fifth Amendment Rights as 2 4 choose to do so, 1 risk losing their representation 2 4 provided by the Constitution. They?ve told me that E: 2 5 and waiving those rights. 2 5 I choose to anSWer that question, which is my Page 235 Page 23?; 1 BY MR. HOROWITZ: 1 preference, I risk losing their representation 2 Mr. Epstein, lane Doc 7 never told you she was 2 and/or waiving those rights. 3 18 years old or older; isn't that true? :3 BY MR. HOROWITZ: 4 MR. PIKE: Form. a Prior to May of 2005 did you instruct Jane Doc 5 "fl-IE WITNESS: It would give me great pleasure 5 7 to remove her clothing during your massage? 6 to be able to answer every one of Jane Doe 7's 6 MR. PIKE: Form. 7 claims here today. HOWever, my attorneys have "i THE WITNESS: it would give me great pleasure 8 advised me that I must assert my Fourteenth, Sixth 8 to answer every one of Jane Doe 7's claims, each 9 and Fifth Amendment Rights, because if i choose to 9 one, with specificity. However, today, my 1 0 answer those questions, I risk losing their 1 0 attorneys have counseled me that I may not, and 1 representation and/or waiving those rights. 1 1 they?ve instructed me that i must assert my Fifth .3 1 2 BY MR. HOROWITZ: 1 2 Amendment, Fourteenth Amendment and Sixth Amendmen 1 3 When Jane Doe 7 came to your home between 2003 13 Rights under the US. Constitution. Though I?d 4 and May of 2005, she appeared like to answer the question, they told me that if i 15 younger than 18 years old; isn't that right? 15 do so, i risk losing their representation and 1 6 MR. PIKE: Form. 16 waiving those rights. 17 THE WITNESS: id like to answer each and every your questions here today, Mr. Horowitz. 18 Prior to. May of 2005 did you instruct Jane Doc 1 9 However, my attorneys have counseled me that I may 1 9 7 to pinch your nipples and rub your chest? 20 not; i must assert my Fifth Amendment, Fourteenth 20 MR. Form. 2 3. Amendment and Sixth Amendment Rights. And though 2 1 THE WITNESS: i?d like to answer each one of 2 2 l'd rather -- and I prefer to answer each one of 2 2 Jane Doe 7's claims with speci?city. However, 2 3 Jane Doe 7's claims, my attorneys told me that ifI 2 3 today my attorneys have counseled me that I may 2 4 choose to do so here today, I risk losing their 2 4 not, and that I must assert my rights under the 25 representation and waiving those rights. 25 Fourteenth, Sixth and Fifth Amendment. Though i'd 12 (Pages 234 to 237) UN IVERSAL COURT RE PORT I NG (954) 712*2600 (877) 291WDEPO (3376) Widens?. mli?suzv?rmrexx: Jim-Jun" Avt-vwcxaumwavumi?mu Page 238 Page 240 1 prefer to answer the question, my attorneys have 1 Prior to May 2005 did you touch .iane Doe 7?s 2 counseied me that if] choose to do so, I risk 2 breasts, even after she made repeated attempts to stop 3 losing their representation and waiving those 3 you? 4 rights. 4 MR. PIKE: I apologize, form. 5 BY MR. HOROWITZ: 5 THE WITNESS: It would give me great pleasure 6 Did you prior to May 2005 ask Jane Doe 7 6 to answer each and every one of .iane Doe 7's 7 questions about her sexual experience and preferences? 7 claims, each and every one. However, today, my 8 MR. PIKE: Form. 8 counsel has advised that I may not. I must assert 9 THE WITNESS: Mr. Horowitz, as you probably 9 my rights under the Fourteenth, Sixth and Fifth 10 probably know, I?d like I?d like to answer each 1 0 Amendment. And though I prefer to answer, my 1 1 one of your questions today, especially Jane Doe 3. counsel has told me that if I choose to do so, I 1 2 7's claims. However, my counsel has advised me 1 2 risk losing his representation and/or waiving those 1 3 that I must assert my rights under the Fourteenth, 1 3 rights. 14 Fifth and Sixth Amendment. And though I would l4 BY MR. HOROWITZ: 1 5 prefer to answer that question, he has counseled me 1 5 Mr. Epstein, prior to May 2005 did you rub Jane 1 6 that if I choose to do so, I risk iosing his 1 6 Doe 7's vagina? 1 7 representation and waiving those rights. 1 MR. PIKE: Form. 18 BY MR. HOROWITZ: 8 THE WITNESS: It would give me great pleasure 19 Mr. Epstein, prior to May of 2005 did you touch 1 9 to answer the questions and claims of Jane Doe 2 0 Iane Doe 7?s breasts? 2 0 your questions. It would give me great pleasure to 2 1 MR. PIKE: Form. 2 1 answer the questions of your partner, Zeffrey 22 THE WITNESS: Mr. Horowitz, I'd iike to answer 2 2 Herman, who filed. Jane Doe 7?s lawsuit before he 23 each one of your questions posed here today, but I 2 3 was suspended by the Florida Bar. It wouid give me 2 4 am going to have to respond as I've done to most of 2 4 great pleasure to, in fact, answer the questions 2 5 your questions here today, the same exact way, 2 5 posed by Mr. Edwards? partner, Scott Rothstein, who Page 239 Page 241 3. which is unfortunately rny counsel has told me that 1 sits in jail. 2 i may not answer any questions that may be relevant 2 His other partner is on the way to jail for 3 to any one of the lawsuits filed by you or your 3 fabricating cases of a sexual nature against 4 partner that or your partner who was suspended 4 wealthy people. However, my attorneys have 5 from the by the Florida Bar, or Mr. Edwards?s 5 counseled me here today, I have to assert my 6 Edwards' ciients -- excuse me -- Mr. Edwards' 6 Fourteenth, Sixth and Fifth Amendment Rights. An "3 partner, Scott Rothstein, who sits in jail. They 7 though I'd very much like to answer those 8 said, "I'm sorry, you can?t you have to assert 8 questions, he's informed me that ifI choose to do 9 your rights under the Fourteenth, Sixth and Fifth 9 so, I risk losing his representation and/or waiving 10 Amendment." And though I would choose to answer 1 0 those rights. 1 1 the question, I?ve been advised 1 risk losing their 1 1 BY MR. HOROWITZ: 1 2 representation and/or waiving those rights. 1 2 Prior to May of 2005 did you rub Jane Doe 7's 1 3 BY MR. HOROWITZ: 1 3 buttocks? 14 Prior to May 2005 did you attempt to remove the 1 4 MR. PIKE: Form. 15 bra off -- remove a bra off of Jane Doe 1 5 THE WITNESS: Again? 1 6 MR. PIKE: Form. 1 6 BY MR. HOROWITZ: THE WITNESS: i would very much iike to reSpond 17 Prior to May of 2005 did you rub Jane Doe 7?3 18 to the claims made by Jane Doe 7 with speci?city. 18 buttocks? 1 9 However, today, my counsel has advised me that I ll. 9 MR. PIKE: Form. 20 must assert my rights under the Fourteenth, Sixth 20 THE WITNESS: it would give me great pleasure 2 1 and Fifth Amendment. And though I?d prefer to 2 to be able to answer each one of Jane Doe 7's 22 answer those questions, I if I do so, I?m told 22 claims here today with Speci?city. However, my 2 3 that I risk losing their representation and/or 2 3 counsel has advised me that I must assert my 2 4 waiving those rights. 2 4 Fourteenth, Sixth and Fifth Amendment Right, so 2 5 BY MR. IIORQWITZ: 2 5 oin to "netfui fuse to answer. 13 (Pages 238 to 241) UNIVERSAL COURT REPORTING (954) 712-43600 (877) (3376) ?23518 maximise? 5w.st new swsaasu-usmt fist Maia?riot {is} 2?33: reiterated r356? Sci ii?mi {.22 Sign std: WERE a news?: easement: Page 242 Page 244 mat?- ems-Herr .. Mr. Epstein, lam going pic up with the 1 BY MR. HOROWITZ: 1 questions about lane Doe 7, okay? 2 Prior to May 2005 did you masturbate by 2 A Thank you. 3 stroking your penis in front of Jane Doe 3 Prior to May 2005 did you walk across the room 4 MR. Form. 4 naked and enter a shower in front of Jane Doe 5 'l?i-iE WITNESS: i'd like to answer each one of 5 MR. PIKE: Form. 6 your sexually charged questions, Mr. Horowitz. I 6 THE WITNESS: I would greatly like to I 7 would -- I would it would give me pleasure to be 7 would actually like to answer each one of your 8 able to respond directly to your other partner -- 8 questions today, Mr. Horowitz, especially all the 9 at least in this question -- who's now been 9 claims made by Liane Doc However, at least 3. 0 unfortunately suspended from practicing law in the 1 0 today, my counsel has advised me that I must assert 1 State of Florida after he filed. this claim, or the 11 my rights under the Fifth, Sixth and Fourteenth 12 partner of Mr. Edwards who sits in jail for ?ling 12 Amendment. Though i prefer to answer the question, 1 3 claims of a sexual nature against wealthy people in 13 he's informed me that if I choose to do so, i risk 1 4 Florida in order to fleece unsuspecting South 14 losing his representation and/or waiving those 15 Floridians, his ?rm accused of ?ling and 15 rights. 1 6 fabricating sexual cases, called Attorney a criminal enterprise. So, though I?d 1? Mr. Epstein, did you have sex -- sexual contact 1 8 like to answer each one of your questions, my 18 with Jane Doe 7 at your i?alrn Beach home on multiple 1 9 attorneys have said. if I do so, I risk losing their 19 occasions between 2003 and 2005? 2 0 representation and/or waiving those rights. 2 0 MR. Form. 2 1 BY MR. HOROWITZ: 23. THE WITNESS: Mr. Horowitz, these claims of a 2 2 Prior to May of 2005 did you ejaculate after 2 2 sexual nature I'd very much like to answer, 2 3 masturbating, stroking your penis in front of Jane Doe 23 especially with respect to iane {)oe 7. I'd like to 2 4 2 4 answer those questions, if your partner was here 2 5 MR. PIKE: Form. 25 who filed the claim, but he's been suspended by the Page 243 Page 245 it THE Again, your questions of a 1 Florida Bar for improper behavior. I?d like to 2 2 3 embarrass rne -- I would greatly like to answer 3 he sits in jail for crafting cases -- and if I 4 those questions. i'd like to answer it to your 4 misspoke before, it's crafting cases where he told 5 partner who has been disbarred -- sorry, not 5 people that he had settled cases against me and 6 disbarred you?ve told me he's been suspended and 6 others. Not ?led cases, but crafted total "i not disbarred I keep getting it confused -- 7 fictitious cases of a sexual nature in order to 8 after he filed this lane Doe 7?s claims, or similar 8 convince and fleece people of thousands and 9 claims ?led by Mr. Edwards and his partner, Scott 9 millions of dollars in South Florida. So thosc I?d 1 Rothstein, but his partner, Scott Rothstein, sits 1 0 like thOugh l'd like to answer these questions 1 1 in jail. So, though i?d like to answer each one of 11 of a sexually charged nature, my counsel has 12 these claims, my counsel has told me that at least 12 advised me that today at least, i must assert my 1 3 today, at least today, I must assert my rights 1 3 rights under the Sixth, Fifth and Fourteenth 1 4 under the Fourteenth, Sixth and Filth Amendment. 14 Amendment. And though I'd prefer to answer those 1 5 And if I choose to answer, I risk losing his 3. 5 questions, he has told me that if I choose to do so 1 6 representation and/or waiving those rights. I?m 1 6 if I choose to so, i risk losing his 1 7 going to need five minutes. 1 7" representation and/or waiving those rights. 1 8 BY MR. HOROWITZ: 8 BY MR. HOROWITZ: 19 Prior do you need ?ve minutes new? 1 9 Did you pay $200 to Jane Doe 7 a?er each 28 THE WITNESS: Sure. 2 0 occasion in which you had sexual contact with her 2 1 THE VIDEOGRAPHER: lime off the record 4:05 2 3. MR. PIKE: Form. 2 2 (Thereupon, a short break was takenTHE VIDEOGRAPHER: Time on the record 4:14. 23 -- between 2003 and 2000 and May 2005? 2 4 BY MR. HOROWITZ: 24 MR. Form. 25 25 THE WIESS: l'd like to answer that uestion, ?an. .ert was; raw-kg 14 (Pages 242 to 245) UNIVERSAL COURT REPORTING (954) 712?2600 (877) 2 91WDEPO (3376) 5 Page 246 Page 248 1 as I?d like to answer each and every question 1 she indicated she did not want you to touch her? 3 2 regarding Jane Doc 7 and her claims. However, my 2 MR. PIKE: Form. 3 counsel has advised me that at least today, I may 3 THE WITNESS: Mr. Horowitz, i?d like to answerig 4 not answer any questions relevant to this lawsuit 4 each one of Jane Doe 7?s claims. However, today, 5 or any other lawsuits, so that I must assert my 5 my counsel has advised me that I must assert my 6 rights under the Sixth, ifth and Fourteenth 6 rights under the Fourteenth, Sixth and Fifth 7 Amendment. Though I'd prefer to answer, he?s told 7 Amendment. Though I'd prefer to answer these 8 me that if I choose to do so, I risk losing his 8 questions directly to your partner that was 9 representation and potentially waiving those 9 suspended or disbarred or Ikeep getting it to rights. 10 confused since he ?led these claims of Jane Doe 1 1 BY MR. HOROWETZ: 1 1 7, or Mr. Edwards' partner who sits in jail for 12 Did you ask Jane Doe 7 for permission to touch 12 fabricating malicious claims of a sexual nature -- 13 either her breasts or vagina or both? 13 I'm i?m I'm sorry, if you ?nd this very 1 4 A Again, Mr. Horowitz, as I've answered most of 4 funny. I don't. However, my attorneys have 1 5 your questions here today, i?d very much like to answer 1 5 counseled me, i -- I must not answer that question gt 1 6 the claims of Jane Doe 7 and your firm and your partner, 16 today, and if I choose to do so, I risk losing his 17 Jeffrey Herman, who was suspended by the Florida Bar representation and/or waiving those rights. 18 after he filed these claims on behalf of Jane Doc 7. 18 BY MR. HOROWITZ: 19 However, my counsel at least today has advised me that i 9 When Jane Doe 7 was under the age of 18, did 2 0 must assert my rights under the Fourteenth, Fifth and 2 0 you try to persuade her that it was okay for you to 2 1 Sixth amendment. And though i prefer to answer thosa 2 1 touch her breasts and vagina and to masturbate in front 2 2 questions, he's told me that if I choose her? 2 3 risk losing his representation and/or waiving those 2 3 MR. PIKE: Form. 24 rights. 24 THE WITNESS: Are you serious? Is can i 2 5 MR. Form to that question as well. 2 5 hear that question again? Page 247 Page 249 1 av MR. HOROWITZ: 1 av MR. Honowrrz: 2 When Jane Doe 7 was still a minor, she 2 Do you deny that when she was still a child 3 indicated to you that she did not want you to touch her 3 Can 1 I need to hear the question again, 4 body; isn't that true? 4 sorry. 5 MR. PIKE: Form. 5 Oh, I thought you said your hearing was okay. 6 THE WITNESS: It would give me ?e I would like 6 MR. PIKE: Let's just go forward. with the 7 to answer those questions and claims of lane Doe 7 question 8 7. However, today, my attorneys have counseled me 8 BY MR. HOROWZTZ: 9 that I must assert my rights under the Sixth, Fifth 9 When Zane Doc 7 was still 10 and Fourteenth Amendment. Though I would prefer tc 10 MR. PIKE: -- and stop harassing the witness. 11 give the answers directly to the your partner 1 1 BY MR. HOROWITZ: 12 who filed this claim on behalf of Jane Doc but 12 When 1 3 the Florida Bar has suspended his license for 13 MR. HOROWITZ: Harassing? 14 14 1 5 prefer to give it to Mr. Edwards' partner, but he 1 5 MR. HOROWITZ: Is that what he doing, or is 1 6 sits in jail, and his other partner harassing pinching -- 3 17 tojail from -- for basically fabricating malicious MR. PIKE: Let?s move to strike. 18 claims of a sexual nature against people in South 18 MR. HOROWITZ: the the 19 Florida. So, though i'd like to anSWer that 3. 9 MR. PIKE: All right. Let?s just go. 2 0 question, I?d prefer to answer that question, I'm 2 0 MR. HOROWZTZ: All right. I just want to know 2 1 told that if I do so, 1 risk losing my counsel's 21 what's -- which is harassing. 2 2 representation and/ or waiving those rights. 2 2 BY MR. HOROWITZ: 2 3 BY MR. HOROWITZ: 2 3 Okay. When Jane Doe 7 was still a child, did 2 4 Isn't it true, sir, you touched Jane Doe 7?s you try to persuade her that it was okay for you to ad 25 .529. casts and genitals when shewas still a child after a - -. 3' touch her va ina, breasts, and to masturbate? (Pages 246 to 249) UN IVERSAL COURT RE PORT I NG (954) 712?2600 (877) 291-DEIPO (3376) ?ix-arm 52.25am rm are Page 2 50 Page 252 1 MR. PIKE: Form. 1 BY MR. HOROWITZ: 2 THE WITNESS: I would very much like to answer 2 Did you instruct SK. to call Jane Doc '7 -- 3 the claims of Jane Doe 7 and your ?rm, but your 3 strike that. 4 unfortunately your partner has is not here 4 Did you instruct SK. to tell Jane Doe 7 to 5 because he?s been suspended by the Florida Bar for 5 mislead the police with regard to their investigation 6 improper behavior. I?d prefer to answer that 6 into your criminal activity? 7 question of a sexually charged nature to 7 MR. PIKE: Form. 8 Mr. Edwards? partner, who unfortunately couldn't be 8 THE WITNESS: I?d like to answer every one of 9 here because he's in jail for potentially the rest 9 your questions that you've posed here today 10 of his life for fabricating cases of a sexual 10 regarding Jane Doe 7 and her claims. However, my 1 1 nature against people in South Florida, stealing 1 1 attorneys haVe advised me at least today, I may not 1 2 investors' monies, ?eecing people out of millions 22 do so, and I must assert my privileges under the 1 3 of dollars, creating sexually charged cases in 3.3 Sixth, Filth and Fourteenth Amendment. Though I'd 1 4 order to sort of fleece people. However, my 1 4 prefer to answer those questions, I?m told that if 15 attorneys have told me that today must assert my 15 I choose to do so, 1 risk losing his representation 1 6 rights under the Sixth, Filth and fourteenth 1 6 and potentially waiving those rights. 1 7 Amendment. And if I choose to answer those 1 7 BY MR. HOROWITZ: 1 8 questions, which is my preference, I risk losing 1 8 Mr. Epstein, is the telephone number 1 9 his counsel and waiving those rights. 1 9 917?855?3363 a telephone number that SK. used at you 2 0 BY MR. HOROWITZ: 20 expense in 2005?? 2 1 Did you pay H.R. to bring Jane Doe ?7 to your 2 1 MR. PIKE: Form. 2 2 home for sexual activity? 2 2 THE WITNESS: I don?t recall. 2 3 MR. Form. 2 3 BY MR. HOROWITZ: 2 4 THE WITNESS: I would very much like to answer 2 4 What telephone numbers did you use, or did you 2 5 all questions regarding HR. and Jane Doe 7's 25 pay to be used between 200i and 2006?? Page 251 Page 253 1 claims regarding HR. However, today, my counsel 1 A I 2 has advised me that I must assert my rights under 2 MR. PIKE: Form. 3 the Fifth, Fourteenth and Sixth Amendment. 3 THE i don?t recall. 4 BY MR. 4 BY MR. HOROWITZ: 5 Did you instruct SK. to write down Jane Doe 5 Okay. Can you think of any telephone number 6 7?s name and telephone number so that you could call 6 that you either used from your home, or paid someone 7 Jane Doe 7 to come to your home for more sexual 7 else to use between 2001 and 2006? 8 activity? 8 A I'd like to answer that question, but on advice 9 MR. PIKE: Form. 9 of counsel i am going to have to claim. my privilege 10 THE WITNESS: Again, these charges of a sexual 1 0 under the Sixth, Fourteenth and Fifth Amendment. 1 1 nature that you and your firm have lodged against 1 1 Sir, you don?t deny that you sexually abused 12 me, it would give me great pleasure to speci?cally 12 Jane Doe 7 when she was still a child, do you? 1 3 answer those questions with respect to Jane Doe 7'3 13 MR. PIKE: Form. 14 claims. I would like to answer it directly to your 14 THE WITNESS: l?rn sure these questions of a 1 5 partner, Mr. Herman, who ?led the claim, but he?s 15 sexually charged nature, Mr. l-lorowitz, are going to 1 ?6 been suspended or disbarred by the Florida Bar. 1 6 be obvious to thejury. I'd like to answer each 1 7 i?d like to respond to these sexually charged 1 7 one of the claims that you?ve made of sexual abuse. 1 8 questions to Mr. Edwards' partner, Scott Rothstein, 1 8 l'd like to answer it to your partner, Mr. Jeffrey 1 9 but he's in jail for fabricating malicious cases of 1 9 Herman, but he can't be here because he's been 2 a sexual nature against wealthy peeple in South 2 0 suspended or disbarred by the Florida Bar for 2 3. Florida. So, though i would like to answer these 2 1 improper behavior after he ?led these claims of 2 2 questions, I have been informed by my attorneys 2 2 sexual abuse. I?d like to make -- respond to the 2 3 that i must assert my privileges. And if I. choose 2 3 sexual abuse claims made by Mr. Edwards' partner, 24 to answer, which is my preference, risk losing 2 4 Scott Rothstein, but he?s in jail for the rest of 25 25 his life, an his other artner__ on the we to m- .M'..wrm agar, .. his re resentation and/or waiving my rights. UNIVERSAL COURT (954) 712*2600 (877) 16 REPORT ING 291-DEPO (3376) rastzeuzmuxama ?2??ng Sf?R?l lit at areismsmureau ?5295??le a Hilda-E radar aura . Kramer-2: 3 34 teaser swiEKk?-ll {2x12 starter-2 xi?lM-S?- Jail-Emir id id i? 33.5.? 3 .. . . .s (Pages 250 to 253) Page 254 Page 256 1 jail for iictitiously fabricating malicious claims 1 losing his representation and waiving those rights. 2 of a sexual nature. So, though I?d like to answer 2 BY MR. 3 those questions, my attorneys have counseled me 3 Mr. Epstein, is there any reason why the jury 4 that i may not today. And he?s told me that if i 4 should not infer from your testimony today that, in 5 do so, I risk losing his representation and/or 5 fact, you did sexually abuse Jane Doc 6 waiving those rights. 6 MR. PIKE: Form. 7 BY MR. HOROWITZ: 7 THE WITNESS: Again, these questions of a 8 Isn't it true, sir, that you are asserting the 8 sexually charged nature regarding my right to take 9 Fifth Amendment privilege with regard to my questions 9 the Fifth Amendment under the advise of counsel, 10 about lane Doc 7 because you did, in fact, sexually 10 ?nd disturbing. Not not so much disturbing 1 1 abuse Jane Doc 7 when she was a child? 11 than your partner who's been disbarred or suspended 12 MR. PIKE: Form. 12 by the Florida Bar since he ?led the claim here by 13 THE WITNESS: The polar trick of asking someone 13 these girls, or Mr. Edwards? partner who sits in 14 why they're asserting their Fifth Amendment Right, 14 jail potentially for the rest of his life, with his 3.5 i'm I?m i'm surprised, Mr. Horowitz. The 15 other partners on the way tojaii for ?ctitious, 1 6 Supreme Court has made it very clear that the Fifth 16 malicious claims of a sexual nature. l?d like to 17 Amendment is a right of every American who answer your questions with great specificity, 18 innocent American to use to protect themselves from 18 Mr. Horowitz, but my counsel has advised me that at 19 people making malicious false claims, similar to 19 least today, i may not. And if i do so, which is 20 the one that the US. Attorneys have put 20 my preference, 1 risk losing their representation 2 1 Mr. Edwards' partner in jail for, for the rest 2 1 and/or waiving those rights. 2 2 potentially the rest of his life for making 2 2 BY MR. HOROWITZ: 23 malicious claims against innocent people, making 23 Mr. Epstein, you're not suggesting that lane 24 fictitious claims. Your partner has been suspended 24 Dee 7 fabricated or embellished her allegations of abus 25 since ?ling this claim of a sexual nature. So, 25 in light of anything done by ieffrey Herman or Scott Page 255 Page 257 1 though i?d like to answer that question, my 1 Rothstein, are you? 2 attorneys have advised me i may not. 2 MR. Form. 3 BY MR. HOROWITZ: 3 THE WITNESS: think the jury is going to 4 - Are you asserting the Fifth Amendment because 4 decide that ieffrey Herman who's been disbarred or you?re an innocent man, or because you?re a guilty man? 5 suspended by the Florida Bar for improper behavior 6 MR. PIKE: Form. 6 alter ?ling this claim, or Mr. Edwards? partner 7 THE WITNESS: l'd like to answer that question 7 who sits in jail potentially for the rest of his 8 as well. The Fifth Amendment is the right of an 8 life, Mr. Horowitz, for the rest of his life, for 9 American to protect themselves from charges 9 fabricating cases speci?cally of a sexual nature 18 false charges. it?s a right that the Supreme Court 10 i think the jury will decide whether these are 1 1 says protects the innocent, Mr. Horowitz, the 1 i. fabricated or embellished. I'd like to answer with 12 innocent. it?s a Supreme Court case. it's the 3.2 great speci?city today; however, my attorneys have 1 3 you?re the lawyer. 1 3 advised that at least today, I must respond by 14 i would like to thejury to know that your 1 4 taking asserting my Fifth Amendment, Fourteenth 15 partner has been suspended for improper behavior 1 5 and Sixth Amendment privilege. And though i woul 16 since he ?led these sexual abuse claims. 1 6 very much like to respond to that question, he?s 17 Mr. Edwards' partner sits in jail for potentially 17 told me that if I do so, 1 risk losing his 1 8 the rest of his life for fabricating malicious 1 8 representation and/or waiving those rights. 1 9 claims of a sexual nature against wealthy people in 1 9 BY MR. HOROWITZ: 2 0 South Florida. I would like to answer your 2 Well, what is it that you?d like the jury to 21 questions more Specifically, but my attorneys will 2 1 infer exactly from the fact that Jane Doc 7 had Jeffrey 22 not allow me to. They told me i must assert my 2 2 Herman as an attorney? 2 3 rights under the Sixth, Fifth and Fourteenth 2 3 MR. PIKE: Form. 24 Amendment. Though i would very much like to answer 24 THE WITNESS: Jeffrey Herman went was 25 ts? new. that question, 1? told tat if i do so, I risk 2 at (we-idles . suspended after he ?led laim on haifof Jane UN IVERSAL COURT RE PORT ING (954) 712*2600 1(877) (3376) ?wvwfalttz'i?n . (Pages 254 to 257) 3% ?rmwm ??ii?ir?z ermine tie'ibii?at it '?t'li m?tx??l? sesamentsemnrranna Wei; sci-5&3 te'ii'?i surest {Ni->353. rszcues ttz's?si?ii their: at {it ii Page 258 Page 260 3. Doc 7 and your other girls. Scott Rothstein went 1 and Sixth Amendment. Though i?d very much like 2 to jail for filing ?ctitious, malicious claims of 2 answer those questions, I?m told that if i choose 3 a sexual nature in order to simply get money, steal 3 to do so, I risk losing his representation andfor 4 money, fleece people for money. i'd like to answer 4- waiving those rights. 5 every one of your questions today, Mr. Horowitz. 5 BY MR. HOROWITZ: 6 However, my attorneys have counseled me that today 6 Was was C.M.A. your prostitute? 7 at least I may not, and must assert my rights. And '7 MR. PIKE: Form. 8 if i choose to answer the question, which is my 8 THE. WITNESS: Again, i'm sure these these 9 preference, I potentially might lose his 9 questions you find very clever, Mr. Horowitz. So 1 0 representation and/or waiVe those rights. 1 0 it's it's questions of a sexually charged nature 1 1 BY MR. HOROWITZ: 1 1 brought by Mr. Edwards' finn, his partner sitting 12 Okay. Mr. Epstein, so we're on the same page, 12 in jail for bringing cases of a sexually charged 13 my next series of questions will involve lane Doe Numbers 13 nature against wealthy people in South Florida, 1 4 8, okay? Have you got that name locked into your head? 1 4 sitting in jail for the rest of his life. Your 15 A {'11 do my best. 15 partner being suspended by the Florida Bar for 6 Okay. isn't it true, sir, that a girl named l. 6 improper behavior after filing of cases on behalf 1? Jane Doc 8 came to your Palm Beach estate in your Jane Doe 8. So though I?d like to answer each 3. 8 approximately 2001 or 2002? 8 one of your questions here today, my counsel has 3.9 MR. PIKE: Form. 1 9 advised me that i may not. And excuse me w? 20 A I would very much like to answer the claims of 20 BY MR. HOROWITZ: 21 a Jane Doc 8. However, my attorneys have counseled me 2 1 Go ahead. 22 that I must assert my rights under the Fifth, Fourteenth 22 A -- and though i would much prefer to do so, 23 and Sixth Amendment. i'd like to answer these claims of 2 3 he?s told me that if I do so, 1 risk losing his 24 a Jane Doe 8, but they told me if I were to do so, i 2 4 representation and or waiving those rights. l?ve got to 2 5 would risk losing their representation and/or waiving 2 5 take five minutes, sorry. Page 259 Page 261 1 those rights. 3. THE VIDEOGRAPHER: Time off the record 4:35. 2 BY MR. HOROWITZ: 2 (Thereupon, a short break was taken.) 3 Did you receive a phone call a girl named 3 BY MR. HOROWITZ: 4 C.M.A., wherein she told you she was bringing Jane Doc 8 4 Mr. Epstein, we?re still 5 to your home for the purpose of giving you a massage? 5 THE VIDEOGRAPHER: Time on the record 4:42. 6 A i would very much like to answer any question 6 MR. Sorry. 7? regarding C.M.A., i believe, an admitted prostitute. '7 BY MR. HOROWITZ: 8 Her claims of bringing a lane Doe 8 -- a girl named Jane 8 Mr. Epstein, we're still going to talk about 9 Doe 8; is that right to my house. However, my 9 lane Doc 8 a little bit more, okay? Did you instruct 1 attorneys have counseled with respect to all questions 10 (EMA. to bring underage girls to your home to engage in 1 3. today, all questions, i must assert my rights under the 1 1 sexual activity with you? 12 Fifth, Sixth and Fourteenth Amendment. Though l?d like 12 MR. PIKE: Form. 13 to answer these questions with specificity, my counsel 13 THE WITNESS: I?d like to answer each question 1 4 has told me that if choose to do so, I risk losing his 1 4 being posed here today about now C.M.A., i believe, 15 representation excuse me or my and/or my -- 3.5 an admitted prostitute and drug addict, and her i. 6 waiving my rights. 1 6 claims of bringing 8. Jane Doc 8 I. believe you 17 Did you instruct SK. to place a telephone call 17 said her name was -- to my house. However, at the 8 C.M.A. to arrange for C.M.A. to bring underage girls to 18 in the at the insistence of my attorney, his 1 9 your home for sexual activity? 1 9 response -- he's required me to assert my Fifth 20 20 2 1 THE WITNESS: I would like to answer each and 2 1 Right. Though to like to answer each and every 2 2 every one of your questions regarding a C.M.A., who 22 question about your Jane Doc 8, I unfortunately 2 3 i believe is an admitted prostitute, and a Jane Doc 2 3 could not do so today. 24 8, but my attorneys have advised me at least today, 24 BY MR. HOROWITZ: I must assert my rights under the Filth, Fourteenth 2 5 25 Mme-v. . Mr. Epstein, you?re not suggesting that 18 (Pages 258 to 261) UNIVERSAL COURT REPORTING (954) 712?2600 (877) 291MDEPO (3376) ?1 .1 ?mutt: .. KI Page 262 Page 264 1 status as either a prostitute or drug user 1 brought this claim on behalf of Jane Doe 8, 2 diminishes the credibility of Jane Doe 8's sexual abuse 2 believe. But since that claim was broughtI'll let the -- 4 whose Mr. Edwards' partner, who's sitting next 5 MR. PIKE: Form. 5 to you, but he?s in jail for the rest of his life 6 THE WITNESS: jury decide that. 6 for bringing fictitious claims of a sexual nature 7 7 8 Okay. Well, I want to know wha -- wha -- 8 as much money as he could. He was accused and 9 what you're trying to convey to the jury? 9 Mr. Edwards? firm was accused by the US. Attorne 10 MR. PIKE: Form. 1 of being -- and perpetrating the largest hand in 1 1 THE I'd like to answer that question, 1 3. South Florida?s history being a criminal 1 2 Mr. Horowitz, like I?d like to answer every one of 12 enterprise. And I?m so I?m sorry I can?t answer 1 3 your questions, but I. think it's going to be 1 3 these questions with speci?city today, 14 obvious about what C.M.A. and Jane Doe 8 are 14 Mr. Horowitz. But on advice of counsel, he?s told 15 15 1 6 answer with more speci?city, my attorneys have 1 6 representation and/or waiving my rights. 1 7 advise me i may not today, and I must assert my 1 7 BY MR. HOROWITZ: 1 8 rights under the Fifth, Sixth and Fourteenth i. 8 Mr. Epstein, is it your sworn testimony that 1 9 Amendment. Though l'd like I?d like to answer 1 9 Jane Doe 8 retained Jeffrey Herman, and that he was 2 the question, my attorneys have counseled me today 2 suspended after he was retained? 2 1 that if I choose to do so, I risk losing their 2 1 MR. PIKE: Form. 22 representation and/or waiving those rights. 22 THE WITNESS: I?m sorry, it?s again? 2 3 BY MR. HOROWITZ: 2 3 BY MR. HOROWITZ: 24 Did you instruct SK. to communicate with 24 My question is well, I?ll break it up in two 2 5 C.M.A. by telephone in order to arrange for Sane Doc 8 2 5 questions. is it your sworn testimony that lane Doe 8 Page 263 Page 265 1 to give you a massage? 1 hired Jeffrey Herman to be her attorney? 2 MR. PIKE: Form. 2 A I only know tha w? my only knowledge is that 3 THE WITNESS: I would like to answer every 3 Jane Doe 8 is represented by the firm where Jeffrey 4 question about your Jane Doc 8 claim. I'd like to 4 Herman was used to be a partner. 5 answer every question about your C.M.A. connection, 5 Okay. And you?re not suggesting to anyone that 6 whoevar, to Jane Bee 8. However, my attorneys have 6 Jeffrey Herman was suspended after Jane Doe 8 decided 7 advised me that i may not answer those questions 7 file a lawsuit, are you? 8 today. I must assert my rights under the 8 MR. PIKE: Form. 9 Fourteenth Amendment, Sixth Amendment and Fifth 9 THE WITNESS: I do not know when Jane Doe 8 3.0 Amendment. Though i think the l'd like to 10 decided to ?le a lawsuit. if you?d like to tell 11 answer those questions, my attorney has told me 1 1 me, l'd be able to answer that question. 12 that if i choose to do so, I risk losing his 12 BY MR. HOROWITZ: 13 representation and/or waiving those rights. 1 3 Okay. 14 BY MR. HOROWITZ: 14 A Would you like to tell me? 15 Mr. Epstein, did you inform SK. that the 15 Did SK. tell you that she con?rmed by 16 massage that Jane Doe 8 was to give you would be sexual 1 6 telephone that Jane Doe 8 would be coming to your home in nature? at a specific time to give you a massage? 18 MR. PIKE: Form. 18 MR. PIKE: Form. 1 9 THE WITNESS: I'd like to answer every one of 19 THE WITNESS: I'd like to respond to every 20 your questions regarding the claims of your Jane 20 question regarding Jane Doc 8 and her claims; 2 1 Doe 8. However, my attorneys have counseled that I 2 1 however, my attorney has counseled me today that I 2 2 may not answer any questions that may be relevant 22 may not answer those questions today, Mr. Horowitz. 23 to any of your lawsuits. I would prefer to have 23 I must assert my rights under the Fifth, Fourteenth 2 4 given it to your partner, Jeffrey Herman, testi?ed 2 4 and Sixth Amendment. I would like to I'd like 2 5 in front of your partner, Jeffrey Herman, wh 25 \U?wm'am?fmv??- 19 (Pages 262 to 265) to, in fact, know wheher Mr. Herman?s ?rm -- UN I VERSAL COURT RE PORT I NG (954) 712*2600 (877) (3376) it 35534! immune a Page 266 Page 268 1 Mr. Herman who?s been disbarred, or your firm or 1 years old or older, did she? '2 your partner, Mr. HermanMR. PIKE: Form. 3 suspended sorry, not disbarred -- you keep 3 THE WITNESS: I'd like to answer each and eve 4 correcting me. I'm not really sure of the 4 question about your Jane Doe 8 claim. However, 5 difference or Mr. Edwards' partner who?s in jail - 5 today, my attorneys have counseled me that I may 6 for crafting all these ?ctitious lawsuits, and 6 not, and i must assert my rights under the Sixth, 7 fleecing people out of thousands of millions of I- 7 Fourteenth and Fifth Amendment. Though I'd like to 8 dollars. I'd like to do that, however, my 8 answer every question about Jane Doe 8 -- your Jane 2* 9 attorneys have counseled me that I may not do that 9 Doe 8 claim, my attorneys have counseled said to 10 today. And if I choose to answar those questions, 10 me that if I choose to answer those questions, I 1 1 which I prefer to do, I risk losing their 1 1 risk losing their representation andXor waiving 2 representation and/or waiving those rights. 1 2 those rights. 1 3 BY MR. HOROWITZyour intent during the course of Jane 14 When when you met Jane Doe 8, she appeared 2* 1 5 Doc 8?s visit to your home, that you would persuadeyounger than 18 years old; isn?t that l6 16 ?ght? 17 you? MR. Form. 18 MR. 131KB: Form. I didn?t know if you were 18 THE WITNESS: Again, I'd like to answer every 1 9 ?nished. 1 9 question i could possibly answer regarding your 20 MR. HOROWITZ: l'rn finished. 20 lane {Joe 8 claim, and every and the claims 2 1 THE WITNESS: i?d like to answer every question 2 1 regarding your other people that you?ve brought up 22 with respect to your Jane Doe 8 claim, every one. 22 today, but i must respond the same way I?ve 23 However, today, my counsel has advised me that i 23 responded to most of your other questions here 24 may not, and must assert my Sixth, Fifth and 2 4 today, Mr. Horowitz, which is on advice of my 2 5 Fourteenth Amendment Right. And though I'd prefer 2 5 counsel, 1 could not answer today, though I?d like Page 267 Page 269 1 to answer the questions, he's told me that if I 1 to. They've instructed me that I must assert my 2 choose to do so, I risk losing his representation 2 rights under the Fourteenth, Sixth and Fifth 3 and/or waiving those rights. 3 Amendment. And if 1 choose to answer the 4 BY MR. HOROWITZ: 4 questions, which is my preference, they tell me 5 During the course of Jane Doe 8's visit to your 5 that i would risk losing their representation 6 home, did you succeed in persuading her, inducing her, 6 and/or waiving my rights. 7 or enticing her to engage in sexual activity with you? '7 BY MR. HOROWITZ: 8 MR. PIKE: Form. 8 Were you nude in front of Jane Doc 8 when she 9 THE WITNESS: i would like to answor every 9 was still a child under the age of i8? 10 question about your Jane Doc 8 Jane Doc 8 or 10 MR. i?iKE: Form. 1 1 Jane Doc 8 claim. However, my attorneys have 1 1 THE WITNESS: Mr. Horowitz, I'm going to hav 12 12 13 that may be relevant to any one of your lawsuits 13 of your questions here today. It would give me 1 4 brought by you or your partner, Jeffrey Herman, but 1 4 pleasure to answer the claims of Jane Doc 8. 1 5 he's been suspended by the Florida Bar since he 15 However, my counsel has advised me that I may not 16 ?led money many of your claims of a similar 1 6 answer any questions relevant that may be 1 7 nature, or Mr. Edwards's partner who sits in jail 17 relevant to any of. the lawsuits that you've 1 8 for the rest of his life for crafting malicious 1 8 brought, or your partner that was subsequently l9 fabricated sexual natured-type claims -- sexually l9 suspended from the practice of law in Florida has 2 0 charged claims against wealthy people in Florida in 20 brought. And though I?d like to answer those 2 1 order to ?eece investors out of millions of 21 questions Speci?cally, my counsel has told me that 22 dollars. So though I'd like to answer those 22 if i do so, I risk losing his representation and/or 2 3 questions, Mr. Horowitz, today I cannot. 2 3 waiving those rights. 2 4 BY MR. HOROWITZ: 2 4 BY MR. HOROWITZ: UNIVERSAL COURT REPORTING (954) 712-2600 (877) (3376) Page 270 Page 272 1 clothing when she was still a child? 1 BY MR. HOROWITZ: 2 MR. PIKE: Form. 2 During the course of her visit to your home, 3 THE WITNESS: I?d like to answer each one of 3 did you touch Jane Doe 8?s breasts? 4 the questions you?ve posed about your Jane Doe 8 4 MR. Form. . 5 claim; however, my attorneys have counscled me that 5 WITNESS: Unfortunately my attorneys hav 6 I may not today excuse me I must assert my 6 counseled me that today, though I'd like to answer 7 rights under the Fourteenth, Filth and Sixth 7 every one of your questions speci?cally, i?d have 8 Amendment. Although I?d prefer to answer the 8 to answer this question like I've answered most of 9 question, my attorneys have counseled me that I may 9 the other questions with respect to Jane Doe 8 and 10 not. 1 0 the Jane Doe 8 claims, which is I?d have to assert 1 1 BY MR. HOROWITZ: 11 my rights under the Sixth, Fourteenth and Fifth 12 When .iane Doe 8 was still a child, did you 12 Amendment. Because if I don't do so, and I choose 1 3 instruct her to pinch your nipples and rub your chest? 1 3 to answer, which is my preference, my counsel has 14 MR. PIKE: Form. 1 4 advised me I am in risk of losing their 1 5 THE WITNESS: It would give me pleasure to be 15 representation and waiving those rights. 1 6 able to anSWer the questions regarding your Jane 1 6 BY MR. Doc 8 claims. However, my attorneys have counseled 17 During the course of her visit to your home, 18 me that today I may not answer any question that 18 did you rub Jane Doe 8?s vagina? 19 may be relevant to any of the lawsuits brought by 19 MR. PIKE: Form. a, 20 your ?rm, your ?rm, including your partner, 2 0 THE WITNESS: Again? 2 1 Jeffrey Herman, who was subsequently suspended or 21 BY MR. 22 disbarred by the Florida legal by the Florida 22 During the course of lane Doc 8's visit to your 2 3 Bar after bringing some of these claims, or 2 3 home, did you rub her vagina? 2 4 Mr. Edwards? partner that sits in jail for the rest 2 4 MR. PIKE: Form. 25 of his life for crafting and trying to convince, 2 5 THE WITNESS: I'd like to answer every one of ii? Page 271 Page 273 1 other people that these claims were real, I 1 your Jane Doe 8 claims, especially your Jane Doc 8 2 believe, claims claims like this were real, and 2 claims with respect to the details of what these 3 fleeced investors out of millions of dollars. His 3 questions. However, my attorneys have counseled 4 ?rm, Mr. Edwards? ?rm, of being accused by the 4 that today, I cannot answer those questions, at US. Attorney of being a criminal enterprise, 5 least today, and i must assert my rights under the 6 perpetrating one of the largest frauds in South 6 Fourteenth, Filth and Sixth Amendment. And though 7 Florida's history against south Floridians. So I'd prefer to answer those questions, especially 8 though I'd like to answer each one of your 8 the questions of a sexually charged nature, similar 9 questions with great specificity, my counsel has 9 to the ones where Mr. Edwards, who's sitting next 10 told me today at least, i may notyou, whose partner is in jail for for 1 1 I risk losing their representation and/or waiving 1 1 crafting malicious claims of a sexual nature, or 12 those rights. 12 your partner who you smile about while you think 13 BY MR. HOROWITZ: 1 3 he's been disbarred or suspended. it's okay. I?d 14 During the course of her visit, did you ask is like to anSWer those questions, but today, I 15 Jane Doe 8 questions about her sexual experience and 15 cannot, because though I choose preferences? 1 6 if I choose to do so, my counsel said I risk losing 1 7 MR. PIKE: Form. 1 7 his representation and/or waiving those rights. 1 8 THE WITNESS: 1 would very much like to answer 1 8 BY MR. HOROWITZ: 19 every question regarding the claims of your Jane 19 When Jane Doe 8 was at your homeyour Jane Doe 8 claim. However, today, my 2 0 masturbate in her presence? 2 attorneys have counseled me that I may not, and 2 1 MR. PIKE: Form. 22 - must assert my rights under my Fourteenth, Sixth 22 THE WITNESS: I'd like to answer that lane Doe 2 3 and Fifth Amendment. Though i?d like to answer 23 8 question as much as it?s Jane Doe 8, right 24 each claim, today I am going to respectfully 24 lane Doe 8 question, as well as every other Jane 2 5 decline. 2 5 Doe 8 claim that you?ve put on the table here 21 (Pages 270 to 273) UNIVERSAL COURT REPORTING (954) 712*2600, (877) (3376) Page 274 Page -. entrainment? Sara-3 {at {it?ll-t it {We ?$8355sz astral 1 today, Mr. Horowitz. However, on the, advice of my 1 would prefer to answer those questions, today I may 2 counsel, I am going to have to assert my rights 2 not because i?ve been told that if i do so, I risk 3 under the Fourteenth Amendment, Sixth Amendment an: 3 losing his representation and/or waiving my rights. 4 Fifth Amendment. Though because i'd like to 4 BY MR. HOROWITZ: 5 answer that question, I'm told by my counsel that 5 Mr. Epstein, when Jane Doe 8 was at your home 6 if i choose to do so, I risk losing his 6 and was still a child, did you tell her that you wanted 7 representation and/or waiving those rights. "3 her to give you oral sex, otherwise known as a blow 8 BY MR. BOROWITZ: 8 job? 9 When Jane Doc 8 was still a child under the age 9 MR. PIKE: Form. 10 of 18, isn't it true, sir, you masturbated to the point 1 0 THE WITNESS: Mr. Horowitz, I'd like to answer 1 of ejaculation in front of her? 1 1 -- answer every question and claim made by your 12 MR. PIKE: Form. 12 Jane Doe 8. However, my attorneys have counseled 1 3 THE WITNESS: l?rn sure these questions of a 13 me that at least today, I have to assert my rights is sexually charged nature, that hopefully thejury 4 under the Fourteenth Amendment, the Sixth Amendmen 15 will be able to see through thorn, Mr. Horowitz. 15 and the Fifth Amendment. I'm told that though l'd 16 I'd like to answer all those questions. However, 16 like to answer those questions, if I choose to do 17 my counsel today has told me that I must respond by so, I risk losing his representation and/or waiving 3.8 asserting my rights under the Sixth, Fifth and 8 my rights. 1 9 Fourteenth Amendment. 1 9 I prefer to answer questions like this of a 20 Sexually charged cases, similar to the ones 2 0 sexually charged nature to your partner, Jeffrey 21 where Mr. Roth -- excuse me which Scott 21 Herman, but he's been suspended by the Florida Bar 22 Rothstein had ?ctitiously fabricated, who's he 22 for improper behavior alter filing many of your 23 is Mr. Edwards' partner, who?s in jail. 23 claims. 24 Mr. Edwards? partners are on the way to jail for 2 4 id prefer to answer those questions to 25 simply fabricating trying to steal money from 25 Mr. Edwards partner, Scott Rothstein, but he?s in Page 275 Page 277 investors in South Florida. 1 jail for the rest of his life it appears the 2 Your partner after he ?led this or sometime 2 rest of his life. Many of Mr. Edwards' partners 3 during these claims has been suspended jail for the rest of their life 4 Florida Bar. So, though l'd like to answer these 4i for crafting cases of a sexually charged nature, 5 questions with great speci?city, my attorneys have 5 fictitious cases, in order to steal millions of 6 told me ifI do so, I risk losing their 6 dollars form local investors. So though id like representation and/or waiving those rights. 1? to answer that question, l'm told that if I do so, 8 BY MR. HOROWITZ: 8 I risk losing the representation of my counsel and 9 When Jane Doe 8 was still a child and she was 9 waiving those rights. 1 in your home, did you tell her that you wanted her to 10 BY MR. HOROWITZ: 1 1 touch your penis? 1 1 Mr. Epstein, did you engage in sexual activity 1.2 MR. PIKE: Form. 12 with Jane Doe 8 during the course of a massage at your 13 THE WITNESS: Again, I would like to answer 13 Palm Beach home in 2001 or 2002? 14 every question about your Jane Doc 8 claims with 3.4 MR. PIKE: Form. 15 great specificity, and Pitt sure the ladies and 3.5 THE WITNESS: When? 1 6 gentlemen of the jury will understand that these 16 MR. HOROWITZ: Let me start over. sexually charged cases, similar to the ones where 1? THE REPORTER: 2001, 2002 you said. 1 8 Mr. Edwards' partner has gone to jail for 8 MR. l?ll I'll I?ll ask the 1 9 fabricating cases, trying to steal money from 1 9 question again, so that the record is a little bit 2 0 people in South Florida, your partner after filing 2 0 clearer. 2 1 some of these cases has been suspended, will see 21 BY MR. HOROWITZ: 22 through it. And though I?d like to be able to 22 Did you engage in sexual activity with Jane Doc 2 3 answer with great speci?city, my counsel has told 2 3 8 during the course of a massage at your Palm Beach horn 24 me I may not and must assert my rights under the 24 in 2001 and 2002? 25 Sixth: Fi are. 3931.933?. 1. . w. 'aegm Amy-ow?: Smaesiauamas muses rears mainstream measurements; ?in 5-3355. ?52333 this it- irh? in am lawman Lfeiir??-i?tam I MR. PIKE: Form. (P gee 274 to 277) UN I VERSAL COURT RE PORT ENG (954) 712*2600 (877) (3376) 9ago 278 Page 280; 2.4m? - . 3 - 1 THE WITNESS: l?d like answer that question. 1 MR. FIKE: Form. 2 I?d like to answer all the questions with respect 2 THE WITNESS: in 2001, 2002 I?d like to 3 to your Jane Doc 8 claims. However, my counsel has 3 answer every one of your questions regarding your 4 advised me today that I must, at least today, 4 Jane Doc 8 claims. However, my attorneys have 5 assert my rights under the Fifth, Sixth and 5 counseled me today that i must assert my Sixth 6 Fourteenth Amendment. So though I?d like to answer 6 Amendment, Fifth Amendment and Fourteenth Amendme 7 7 8 losing his representation and/ or waiving those 8 your questions regarding Jane Doc 8, today 1'12} 9 rights. 9 going to have to refuse to do so. 10 BY MR. HOROWITZ: 10 BY MR. HOROWITZYou touched Jane Doc 83 breasts, you touched 1 2 THE VIDEOGRAPHER: Three minutes 12 her genitals, and you did that after she indicated to 1 3 MR. HOROWITZ: i'm sorry? 13 you that she did not want to be touched by you; isn't 141 THE VIDEOGRAPHER: l'm sorry, three minutes 01? 14 that right? 15 tape remaining. 15 MR. PIKE: Form. 16 MR. HOROWITZ: Okay. 16 THE WITNESS: l'd prefer excuse me -- if I 17 BY MR. HOROWITZ: 17 if i understood, in fact, when your partner, 18 Did you ask Jane Doc 8 for permission to touch 18 Jeffrey Herman, tiled most of his cases against me, 1 9 her in a sexual manner when she was still a child? 1 9 because I know he was disbarred or suspended after 20 MR. PIKE: Form. 20 he ?led these cases of a sexual nature. I'm not 2 1 THE WITNESS: I?d like to answer every one of 2 1 sure of the time frame, or when Mr. EdWards? 2 2 your questions, but unfortunately I am going to 2 2 partner got involved who?s now in jail for filing 2 3 have to answer the same way l?ve answered most of 2 3 for fabricating -- sorry for fabricating 2 4 those here today, which is my counsel has advised 2 4 malicious cases of a sexual nature against many 2 5 me that i must assert my rights under the 25 people in South Florida, called by the US. Page 279 Page 281 1 Fourteenth Amendment, the Sixth Amendment and Fifth 1 Attorney -- his ?rm called by the US. Attorney, a 2 Amendment. However, I'd like to answer those 2' criminal enterprise. His partner is in jail for 3 questions, but he?s told me that if i do so, Irish 3 the rest of his life. Many of his partners are on 4 losing his representation. 4 the way to jail for the rest of their lives 55 id like answering those questions to your 5 potentially. So though i?d like to answer every 6 partner, Jeffrey Herman, but he's not here because 6 question with respect to your Jane Doc 8 sexual he's been suspended for improper behavior after he 7 claim your Jane Doc 8 claims of a sexual nature, 8 filed these cases, after he had a press conference 8 I've been advised by my counsel at least today that 9 in Palm Beach, in the streets of Palm Beach, called choose to do so, which 10 the media. 1 is my preference, I risk losing their 1 1 I'd like to express the same answer to 1 1 representation or waiving those rights. 12 Mr. Edwards partner, but he's injail for the rest 12 BY MR. HOROWITZ: 3 of his life for creating fictitious cases. So, 1 3 Mr. Epstein, is it your testimony that Jane Doe 14 Mr. Horowitz, though I'd like to answer the 14 8 has in any way fabricated or embellished her 15 question today, i must deny i must refrain from 1 5 allegations that you sexually abused her during her 1 6 doing so at the advice of counsel. 1 6 childhood? 1? MR. HOROWITZ: Let?s change tapes. 17 MR. PIKE: Form. 18 THE VEDEOGRAPHER: Time off the record 5:01. 18 THE WITNESS: I believe thejury will make the 1 9 (Thereupon, a short break was taken.) 1 9 decision, Mr. Horowitz. I believe that they will 20 THE VIDEOGRAPHER: Time on the record 5:09. 20 understand that many of these claims put together 2 1 This is Tape 6. 2 1 by your partner who was suspended for improper 22 BY MR. HOROWITZ: 22 practice in the State of Florida, who could no 23 Mr. Epstein, in 2001 and 2002, Jane Doc 8 2 3 longer practice law at least temporarily I 2 4 indicated to you that she did not want you to touch her understand that Mr. Edwards? partner who's in jail L'szan'ztizous-M body; isn?t that right? .ritsamli?xa'm?: mam-1:it.er . suntan-mmcazrw?ucsa 3m arr not for otentiall the rest of his life for (Pages 278 to .?n?nrmers?ew Masts-Masada,? Wm.) 23 UN IVERSAL COURT RE PORT ENG (954) 712*2600 (877) (3376) immat??e?? 1W5: ail?lmi? {ii-i 9.3342 Page 282 Page 284 1 fabricating cases of a sexual nature. Many of 1 Mr. Epstein, you don?t deny that you sexually 2 Mr. Edwards? partners on their way to jail for the 2 abused 3 rest of. their life for fabricating cases of a 3 A Huh? a sexual nature. l'd like to answer each one of your 4 Mr. Epstein, you don't deny that you sexually 5 questions regarding Jane Doe 8 and your other 5 abused Jane Doe 8, do you? 6 women, however, on advice of counsel today, I 6 MR. PIKE: Form. 7 cannot. And i am told that if I choose to do so, 7 THE WITNESS: Mr. Horowitz, these sexually 8 and not assert my rights under the Sixth, Fifth and 8 this sexual abuse types of questions, which i?d be 9 Fourteenth Amendment, I risk waiving those rights 9 more than happy to answer, had it not been for my 1 and losing his representation. 1 attorneys instructing me that i must assert my 1 1 BY MR. HOROWITZ: 3. 1 Fourteenth Amendment, Sixth Amendment and Fifth 12 Mr. Epstein, did you pay C.M.A. to bring lane 12 Amendment Rights, 1 I wish I could answer the 1 3 Doc 8 to your home? 1 3 question because Mr. Edwards? partner, Scott 1 4 MR. PIKE: Form. 1 it Rothstein, who?s in jail for fabricating cases of a 1 5 THE WITNESS: i believe again, I would like 1 5 sexual nature against wealthy individuals in South 1 6 to answer all questions regarding C.M.A., I 1 6 Florida -- it?s no secret. Most of the people 7? believe, an admitted prostitute, drug addict and 7 many of the people here, I'm sure, know that his 1 8 her -- and anything to do with your lane Doc 8 8 partners are many of them are in jail, many are 1 9 claims. However, today, my counsel has advised jail. Though -- though -- so though 2 that I must, at least today, assert my rights under 2 i would like to answer the questions regarding 2 1 the Fifth, Sixth and Fourteenth Amendment. And 2 1 questions of a sexual nature, my attorneys at least 2 2 though I would prefer to answer each one of your 22 for today, at least for today, have said i may 23 questions, Mr. Horowitz, he?s told me that if I 23 not. And if i choose to do so, which they know is 2 4 choose to do so, I risk losing his representation 2 4 my preference, they have told me I risk losing 2 5 andlor waiving my rights. 2 5 their represent and/ or waiving my rights. Page 283 Page 285 1 BY MR. HOROWITZ: 1 BY MR. 2 Mr. Epstein, did you instruct SK. to call 2 isn't it true, sir, that you are asserting your 3 C.M.A. on the telephone to arrange for Jane Doe 8 to 3 Filth Amendment privilege today with regard to questions 4 come back and give you another massage? 4 about Jane Doc 8 because you did in fact sexually abuse 5 MR. PIKE: Form. 5 Jane Doe 8 during her childhood? 6 THE WITNESS: To give me excuse me? 6 MR. Form. 7 BY MR. HOROWITZ: 7 THE WITNESS: I'm asserting my Fifth Amendment 8 One more time. Did you instruct SK. to call 8 Sixth Amendment and Fourteenth Amendment Right as 9 C.M.A. on the telephone to make arrangements for Jane 9 advised by my counsel, as a right of every American 1 0 Doc 8 to come back to your home for more sexual 1 to protect themselves from malicious, false claims, 1 1 activity? 3. 1 similar to the ones that your colleague here, 1 2 MR. PIKE: Form. 3.2 Mr. Edwards? partner is in jail for, fabricating by it 3 THE WITNESS: I'd like to answer every question 1 3 sexual cases of a sexual nature, called by the 1 4 that you posed today regarding your Jane Doe 8 14 US. Attorney the largest fraud in South Florida's 1 5 claims, of her relationship with C.M.A. However, 15 history, his firm of 70 partners considered a it 6 my attorneys have counseled me that at least today 16 criminal enterprise for basically fabricating case 1 7 I must assert my Fourteenth Amendment, Sixth -- cases of a sexual nature sexually charged 18 Amendment and Fifth Amendment Rights. Though I'd l8 nature. So though I would like nothing more than 1 9 prefer to answer each one of the questions, my 1 9 to answer the questions that you?ve posed here 2 attorneys told me that if I choosc to do so, Irish 2 0 today regarding your cases, Mr. Horowitz, l've been 2 1 losing his representation and/or waiving those 2 1 told that if I choose to answer those questions, I 22 rights. 22 risk losing my counsel's representation and waiving 2 3 I believe the air conditioning has just gone 2 3 those rights. 2 4 off. 2 4 BY MR. HOROWITZ: 25 25 5: "has; MR. HQWITZ: ?m1! 5' . 'rcL-euwumm-mmz as as}; 5Mw anathema. use-saver. Mr. Epstein, i -- in your mind, why shouldn?t 24 UNIVERSAL COURT REPORTING (954) 712*2600 (877) (337 6) - .a ?sea 2:3 yea-.39 we: (Pages 282 to 285) ??883! reassuraqu ?thl?sldl a Page 286 Page 288 1 the jury infer from your testimony today that you did, i an answer. He never gave an answer. 2 in fact, sexually abuse Jane Doc 8 when she was a child 2 MR. HOROWITZ: Okay. Are you withdrawing th? 3 given that you've been asserting a Fifth Amendment 3 objection? 4 mama? 4 5 MR. Form. 5 your question. 6 THE WITNESS: -- I believe the jury'will see 6 HOROWITZ: So are you withdrawing the 7 through your meager attempt that simply suggesting "i objection? 8 8 9 that?s used to protect innocent people from 9 objection prior to. You?re asking the question 10 malicious sexually charged cases similar to the 3.0 again. I'm allowing him to answer. 11 ones where Mr. Edwards' partner is injail for the 11 HOROWITZ: l?ll ask the question ~~just to 12 rest of his life, with many of his other partners 12 be have a clear record, i am going spend the rest of their life in jail 1 3 question again. 1 4 for the cases of a -- for fabricating a malicious 1 4 MR. Yes. 15 case and stealing money from local Floridians. So 15 BY MR. HOROWITZ: 16 l'd like to answer each and every one of the 1 6 Mr. Epstein, identify all of your health care 17 questions posed by you here today, Mr. Horowitz. 1 "l providers for the past ten years, including, without 1 8 However, my attorneys have instructed me that l. 8 limitation, mental health 19 must assert my Fifth Amendment, Sixth Amendment anc 9 counselors, physicians, hospitals and treatment 20 Fourteenth Amendment Right. So though l'd prefer 2 0 facilities? 21 to answer the question, my counsel has told me that 2 3. MR. PIKE: With reSpect to the order risk losing his representation and 22 believe the order said and 23 potentially waiving those rights. 23 I don't think it went on -- i think 24 BY MR. HOROWITZ: 24 it actually limited, and if you recall, the 25 Mr. Epstein, your counsel indicated to me that 25 additional hospitals and providers. So having Page 287 Page 289 1 you wanted to possibly change an answer that you had 3. stated that, Mr. Epstein can identify for you the 2 given me earlier concerning your health care providers 2 and/or that he has been 3 that you've had in the past ten years. My question for 3 seen by within the last ten years, but he will not 4 you is 4 elaborate on his answer if it would invade 5 MR. PIKE: Well 5 attorney?client work product. 6 MR. HOROWITZ: Let me finish the question, then 6 HOROWITZ: Okay. So you answer as to a 7 you could -- 7 portion of the question, you?re instructing him not 8 MR. PIKE: Go ahead. 8 to answer; is that right? 9 BY MR. HOROWZTZ: 9 MR. PIKE: Consistent with the order. 1 0 identify for us your health care providers 18 MR. HOROWITZ: That's your version of. the 11 for -- in the past ten years, including without 11 order. 12 limitation, mental health 12 MR. PIKE: Do you have the order. 13 counselors, physicians, medical doctors, hospitals and 13 MR. You do. it was mailed to you. i. 4 treatment facilities? 14 MR. PIKE: Do you have the order here today? 15 MR. PIKE: Wait a second, let me be clear. 1 15 MR. HOROWITZ: No. 16 did not tell you that Mr. Epstein wanted to change 16 MR. PIKE: Okay. his answer. Basically objected and instructed 17 MR. HOROWITZ: i know what it says, though. 18 him not to answer a particular question because you 18 Can can we can wejust get a question -- an 1 9 did not have the order or the interrogatory or the 1 9 answer to the question? 2 0 request for production that you were referencing. 2 0 MR. PIKE: Sure. 2 1 At a break you had showed me those particular 2 1 MR. HOROWITZ: Did you understand the question. 2 2 documents two of them. Not the order itself. 2 2 THE WITNESS: Dr. Steve Alexander and 2 3 And as a result, I agreed to allow you to ask 2 3 Dr. Steven Strumwasser. 24 Mr. Epstein the question so we didn't have to come 24 BY MR. HOROWITZ: 25 25 a. My: :?i-nt-ns-sm back as a courtesy. So I did I 'tllto kay. And Dr. Sten lexander, what is his 62. mergerm Canasta-3;: ?tar.? 25 (Pages 286 to 289) UN I VERSAL COURT RE PORT I NG (954) 712?2600 (877) (3376) ?m?s splint?1.333523% sea? assessment-ass awmeemermraur tarrmrea i=9 immatures .31? - .I he Page 290 Page 2 92 1 area of practice? 1 Do you go to his of?And where does he practice? 3 or does he come to you? 4 A In Palm Beach. 4 A I?ve 5 And between what period of. time -- during what 5 MR. PIKE: l'rn going to instruct him not to 6 period of time did you receive a either treatment or 6 answer that question. 7 a consultation from him? 7 BY MR. 8 MR. PIKE: i?m going to instruct him not to 8 Does Doctor do you see Dr. Alexander at his 9 answer because that's attorney-client work product. 9 of?ce 1 0 MR. HOROWITZ: Okay. It?s attorney?client as 10 MR. RIKE: i?m going to instruct him 1 1 to 1 1 BY MR. HOROWITZ: 12 MR. PIKE: And work product. 1 2 -- or does he come see you? 13 MR. HOROWITZ: Okay. All right. 13 MR. I'm going to instruct him not to 1 4 MR. You didn't ask him who hired those 1 4 answer that question, also overbroad. it 5 individuals. 1 5 BY MR. HOROWITZ: 1 6 MR. HOROWITZ: Okay. {don't need to know 1 6 Okay. Between 2001. and 2006, using those two?: 1 7 that. 1 7 years as sort of a bookmark, did your sexual interests 18 MR. Sure, if you're raising your 18 include looking at girls under the age of 18 while they 1 9 eyebrows as if you're concerned with regard to the 1 9 were undressed? a 20 objection. That show 20 MR. PIKE: Form. ,3 2 1 MR. HOROWITZ: I'm not going to deal with it 2 1 MR. i?d like to answer each and 2 2 today with you 2 2 every one of your questions here today, .2 2 3 THE REPORTER: One at a time. 2 3 Mr. Horowitz. i?m going to answer that question 24 MR. PIKE: that shows some sort of 2 4 like I?ve answered mostly all your other questions, i: 2 5 bewilderment as to why I'm raising the objection. 2 5 which is on advice of counsel, they've asked me to sage 291 Page 293%: 3. So what I?m doing is, just allowing you the 1 assert my Fourteenth Amendment Right, my Sixth 2 opportunity to ask the appropriate question so you 2 Amendment Right, my Fifth Amendment Right. So 3 understand the objection, that?s ail. 3 though I'd like to answer each and every one of 4 BY MR. HOROWITZ: 4 your questions, for going to have to assert those 5 Okay. Were you under the care of Steven 5 rights today. 6 Alexander before any investigation into criminal 6 BY MR. HOROWITZ: 7 activity began? 7 Between 2001 and 2006 did your sexual interests 8 MR. i?m going to instruct him not to 8 include looking at the breasts and vaginal area of girls 9 answer that question. 9 between the ages of 12 and i7? 10 BY MR. HOROWITZ: 10 MR. PIKE: Form. 1 1 Were you under the other doctor -- am I saying 11 THE WITNESS: I'm going to answer that question 12 this right, Strumwasscr? 12 like l've answered any -- most of your other 13 A Yes, sir. 13 questions here today, which is on advice of 3. 4 What is his area of specialty? 14 counsel, l?m going to have to assert my rights 5 A 15 under the Fourteenth Amendment, the Sixth Amendmen 1 6 Does he have a 6 and Fifth Amendment. 1 "r A 1 don?t know. 1 7 BY MR. nonownz: 1 8 Were you under his care or treatment before any 3.8 Between 200i and 2006 did your sexual interests 1 9 investigation into a criminal activity occurred? 1 9 include digitally penetrating the vaginas of girls 20 MR. PIKE: Again, I?m going to instruct him not 20 between the ages of 12 and 17? 2 1 answer, work product. 2 1 MR. Form. 22 BY MR. 22 THE WITNESS: i find these questions -- I?d 2 3 Okay. And where is Dr. Strumwasser's of?ce 2 3 like to answer every one of those questions. 2 4 located? However, my counsel has told me i may not today. i wish I co ash? .hww-gr/ uid answer those questions with reSpect ma: examine?! e: 26 (Pages 290 to 293) UNIVERSAL COURT REPORTING (954) 712*2600 (877) (3376) Page 294 Page 296 1 or directly to your partner that ?led most of 1 MR. PIKE: Form. 2 these lawsuits, however, he?s been suspended from 2 WITNESS: I?d like to answer every one of 3 the Florida Bar. 3 your questions here today regarding all your claims 4 I'd like to answer these questions to 4 of these girls, however, my attorneys have 5 Mr. Edwards' partner, but he's in jail for 5 counseled me today that i must assert my Fourteenth 6 fabricating cases of a sexually charged nature 6 Amendment, Sixth Amendment and Fifth Amendmen 7 against wealthy people and stealing millions of 7 Right. So though I would like to answer the 8 dollars from local South Floridians. So though i 8 question, I'm told that if I do so, i risk losing 9 wouid prefer to answer these question, I've been 9 his representation and/or waiving those rights. 10 told by my counsel that if I choose to do so, i 10 BY MR. HOROWITZ: 1 1 risk losing his representation and waiving my 1 1 Mr. Epstein, between 2001 and 2006 did your 12 rights. 12 interest include paying girls under the age of 18 for 1 3 BY MR. HOROWITZ: 1 3 massages of a sexuai nature? 14 Between 2001 and 2006 did your sexual interests 14 MR. PIKE: Form. 15 include masturbating on a massage table in the presence 15 THE WITNESS: I would really like to answer 1 6 of girls under the age of 8? 1 6 every one of your questions here today, 17 MR. PIKE: FormMr. Horowitz. Unfortunately i am going to have to 1 8 let me interject here for a second. I 1 noticed 1 8 answer that question like I've answered many of 19 that the tenor of the questions has changed since 19 your other questions, on advice of my counsel who?s 2 0 we've been in deposition for over seven hours, and 2 0 suggested that I must assert my rights under the 2 1 I noticed that you have a list of questions toward 2 3. Fourteenth, Fifth Amendment and Sixth Amendment. 22 the hack of your outline there (indicating) that 2 2 "though i would greatly prefer to answer these 2 3 seems to he not really detailed or relevant to your 2 3 questions, my attorneys told me that if i choose to 24 clientsrisk losing his representation and waiving 2 5 MR. HOROWITZ: i don?t know what outline you're 2 5 my rights. Page 295 Page 29'? 1 looking at. Are you looking at my outline? 1 BY MR. HOROWITZ: 2 MR. PIKE: I?m not ?nished 2 Between 2001 and 2006 did you have a room in 3 MR. HOROWITZ: Continue. 3 your home in Palm Beach County where you received 4 MR. PIKE: Ijust want to make a clean 4 messages? 5 record, okay? Mr. Edwards is very -- is very well 5 MR. PIKE: .-Form. 6 aware, and I'm very well aware, that no matter what 6 THE WITNESS: I am going to have to answer the 7 your understanding as of as of this case and question the same way I've answered most of your 8 what you're trying to prove and what burden you're 8 other questions here today, Mr. Horowitz, which is 9 trying to meet, cannot use this deposition as a 9 on advice of my counsel I'm told that I must assert 1 0 means to harass Mr. Epstein or any other client. 1 0 my rights under the Sixth Amendment, Fourteenth 1 1 His sexual interests in general, as you?re 11 Amendment and Fifth Amendment. And though I'd 12 asking them, is argumentative and it's harassing, 12 prefer to answer those questions, rny attorneys told 13 and I'm only going little bit 13 me that if I choose to do so, i risk losing their 1 4 longer, okay? 1 4 representation or waiving my rights. 15 MR. HOROWITZ: Okay. it 5 BY MR. HOROWITZ: 6 MR. PIKE: So if you would, try to rephrase 16 Between 2001 and 2006, at your home in Palm your question Beach, did you have sexual contact with over 30 girls 18 MR. HOROWITZ: Okay. 18 under the age of 18 in your massage room? 1 9 MR. because we've been here a long 1 9 MR. Form. 20 time, and and and 1 know what you?re 20 THE WITNESS: I would like to answer each one 2 1 to do here. 2 1 of your claims today, Mr. Horowitz. However, my 2 2 BY MR. HOROWITZ: 2 2 attorneys have counseled me that I may not answer 2 3 Between 2001 and 2006, Mr. Epstein, would it 2 3 any questions that may be relevant to any of your 2 4 arouse you to have underage girls talk about their sex 2 4 iawsuits brought by you, your partner who's been 2 5 2 5 W: lif while the ?re undressed? .2: suspended the practice of law in South 27 UN I VERSAL COURT RE PORT ENG (954) 712?2600 (877) (3376) Ewen?: (antagonizing he 152.1 m?im??l a: #Wkehi attenuates: 3-2333 sane ?(?55055 masts. an narrates t??w?h?d vii-Mi}; ?313: We) . (Pages 294 to 297) Page 298 Page 300 1 Florida, Mr. Edwards? partner, Scott Rothstein, who 1 fictitious cases part of the perpetration of the 2 sits spending the rest of his life in jail for 2 largest fraud in South Florida?s history, calling 3 fabricating cases. l'd like to answer every one of 3 Mr. Edwards' ?rm a criminal enterprise. 4 your questions, but today, my attorney told me I 4 Your partner is not here today because he's 5 cannot, at least today. And if I choose to do so, 5 been suspended after he ?led these cases. So 6 1 risk losing his representation and/or waive my 6 though I'd like to answer each and every one of 7 rights. 7 your questions, my counsel has advised me that 8 BY MR. HOROWITZ: 8 may not today. And though I?d prefer to do so, he 9 isn?t it true, sir, that between 2000 -- isn't 9 said if I choose to do so, i would risk losing his 10 it true, air, that between 200i and 2006, you had a very 10 representation and/or waiving my rights. 1 1 speci?c method for sexually abusing girls between the 1 1 BY MR. HOROWITZ: 1 2 ages of l2 and 13 in your Palm Beach County home? 1 2 Mr. Epstein, between 2001 and 2006 you paid 1 3 A You continue to use -- 13 people to recruit and solicit girls to come to your home 1 4 MR. Form. 1 a who were between the ages of 13 and 17, whereupon yo 1 5 THE WITNESS: huh. Again, these questions, 1 5 would engage in sexual activity with them; isn't that 1 6 i believe the jury is going to see through, 1 6 right? 1 7 Mr. Horowitz. These are questions similar to the 17 MR. PIKE: Form. 1 8 ones that people have suggested Mr. Edwards? 1 8 MR. HOROWITZ: Again, I'm sure, Mr. Horowitz, 1 9 partner, Scott Rothstein, who's spending the rest 1 9 the jury will be able to see through your questions 2 of his life in jail for fabricating cases of a 2 0 of a sexually charged nature. I?d like to answer 2 1 sexually charged nature, has tried to convince 2 1 each one of your questions. However, my attorneys 2 2 investors in South Florida, that he stole millions 2 2 have counSeled me that today at least, may not. 23 of dollars based on sexually charged cases similar 2 3 i must assert my rights under the Fourteenth, Sixth 24 to these claims that you?ve made. I?d like to 24 and Fifth Amendment. The questions of a sexually 2 5 answer each one of your questions today. However, 2 5 charged nature don?t surprise me. They?re similar Page 299 Page 301 1 my attorneys have counseled me that I may not 1 in nature to the sexually charged cases that 2 answer any questions that may be relevant to any of 2 Mr. Edwards partner currently sits in jail for 3 your lawsuits. 3 for the rest of his life. 4 BY MR. HOROWITZ: 4 A "RU-man law ?rm ?led bankruptcy, called by 5 Between 2000 5 the US. Attorney a criminal enterprise, 6 A Excuse me. 6 perpetrating one of the largest frauds in South 7 Go ahead. 7 Florida history by crafting cases of a sexually 8 A And though I'd prefer to answer the question, 8 charged nature in order to fleece local Floridians 9 my attorneys have counseled me that thousands and thousands of dollars. So though 10 excuse me bless you I risk losing their 10 I'd like to answer each one of your questions, 1 1 representation and/or waiving my rights. 1 1 today at the advice of counsel, i cannot. And 12 BY MR. HOROWITZ: 12 though i?d like to answer it, my counsel has told 13 Between 2001 and 2006 you targeted a speci?c 1 3 me that if i choose to do so, i risk losing his 14 age of girls between 13 and l7 for sexual abuse in your 1 4 representation and/or waiving my rights. 15 borne; isn't that right? 1 5 BY MR. HOROWITZ: 1 6 MR. Form. 16 Mr. Epstein, between 2001, 2006 you paid THE WITNESS: These type of questions, sexually someone to schedule appointments by telephone for girl 18 charged questions, I believe the jury will be able 18 between the ages of 13 and 17 to come to your home for 1 9 to see through, Mr. Horowitz. They're similar to 1 9 sexual activity with you; isn't that right? 2 0 the claims and charges and that Mr. Roth 2 0 MR. PIKE: Form. 2 1 Mr. Edwards' partner, Scott Rothstein, sits 2 1 THE WITNESS: These claims of a sexually 22 currently in jail for the rest of his life, 22 charged nature i would very much like to answer 2 3 fabricating cases of a sexual nature simply in 2 3 today with great speci?city. But as most of your 2 4 order to steal millions of dollars from local 2 4 questions have been answered today, i, on the 25 lied some of these . - "W?rwtr as" advice of counsel, have had to nvoke my Sixth 28 (Pages 298 to 301) UN IVERSAL COURT RE PORT ENG (954) (877) (3376) he?d??w?i kl?s??i?t m?iw??l??d Hail autumn 93's: thrills amen iihlsaiei? $312 Lil-213'? new, mam arse/ma 23:39 sea with? $?3?ll3?t?2 mid? teestmnuswum tidtwm smear}: 1? 33% ii Page 302 Page 304 Sixth and Fifth Amendment to any question that may ?mm i . . 1 Amendment, Fourteenth Amendment and Fifth Amendmen 3. be relevant to any of the lawsuits brought by you, 2 Rights. Though I'd prefer to speak to your partner 2 your partner of your ?rm who?s been found after he 3 who's not here because he's been suspended from the 3 filed these claims to have committed improper acts 4 practice of law in South Florida after heis ?led 4 and has been suspended from the practice of law in 5 these cases, held a big press conference. 5 South Florida, or the cases brought by Mr. Edwards' 6 Mr. Edwards' partner who's in jail for the rest 6 whose those firm has been described by the US. 3" 7 of his life it appears for fabricating ?ctitious 7 Attorney as a criminal enterprise of a of 70 8 cases of a sexually charged nature. So though Pd 8 attorneys, where his senior partner is spending the 9 like to answer every one of your questions with 9 rest of his life in jail for fabricating cases of a 10 great speci?city, I?ve been told by my counsel if 1 0 sexually charged nature against people in South 1 i choose to do so, i risic losing his representatiOn 1 1 Florida, wealthy people, in order to fleece 12 and waiving those rights. Five minutes? 12 unsuspecting investors out of their life savings. 13 MR. HOROWITZ: If that?s what you need. 13 So though I?d like to answer that question, 14 THE WIT NESS: is that okay? is that okay? 3.4 Mr. Horowitz, very much so like to answer that 15 MR. EDWARDS: Break. 15 question, l've been informed that if i chose to do 1 6 THE WITNESS: Five minutes? 1 6 so, I risk losing the representation of my counsel 17 MR. EDWARDS: Break as long as you want. 17 and waiving my rights. 18 THE VIDEOGRAPHER: Okay. Time off the record 1 8 BY MR. HOROWITZ: 19 5:33. 19 Okay. And with regard to the underage girls 2 0 (Thereupon, a short break was taken.) 2 0 who you had sexual contact with at your home between 21 THE VIDEOGRAPHER: Back on the record 5:41. 2 2001 and 2006, you had a common scheme of paying the 2 2 BY MR. HOROWITZ: 2 2 between 2 to $300 each, each time they came; is that 2 3 Mr. Epstein, with regard to the girls who were 2 3 right? 24 at your Palm Beach County home between 2001 and 2006 2 4 MR. PIKE: Form. 25 with whom you had sexual activity, nearly all of these 2 5 THE WITNESS: I would very much like to answor Page 303 Page 305% 1 girls were high school students in F?alm Beach County; 1 all the questions about the claims the so-called 2 isn?t that right? 2 claims of all your girls, of all your young women, 3 MR. PIKE: Form. 3 represented by your ?rm, represented initially by 4 THE I?d like to answer all of. your 4 your partner who was suspended by the Florida Bar 5 questions here today, Mr. tierowitz, about all the 5 for improper behavior. He?s not here because of 6 claims made by the girls you represent. However, 6 that excuse roe the claims of Mr. Edwards' 7 on advice of my counsel at least today, they've 7 clients, some admitted prostitutes. His partner is 8 instructed me to assert my Fourteenth Amendment 8 in jail for the rest of his life for fabricating 9 Right, my Sixth Amendment Right and my Fifth 9 cases of a sexually charged nature against people 10 Amendment Right. So though I would prefer to 10 in South Florida in it in order to fleece some 1 answer the questions, if i choose to do so, Pie 1 of the people out of their life savings. Yes, i?d Z2 informed that I risk losing my counsel's 12 very much like to answer each and every one of your 13 representation and/or waiving my rights. 13 questions, however, today, on advice of counsel, 1 1 4 BY MR. HOROWITZ: 1 4 cannot. 1 5 And with regard to the girls under the age of 15 BY MR. HOROWITZ: 1 6 l8 who came to your home in 2001 through 2006, your 1 6 With regard to the underage girls who came to purpose in having them come to your home was for sexua 17 your home between 2001 and 2006 1 8 activity, but they were told they were coming to your 18 A Would you let me finish? Would you mind if I 1 9 home to give a massage; isn't that right? 1 9 finish. I'm sorry. I choose 1 would I haven?t 2 0 MR. PIKE: Form. 2 0 finished. 21 THE WITNESS: id like to answer each and every 21 You have not ?nished. Would you like to 22 one of your questions about the claims of your 2 2 finish? 23 girls. However, today, my counsel has informed me 23 A Yes, if I could. 2 4 that I mustlassert my rights under the Fourteenth, 2 4 Go ahead. 25 i ikc to res ond hose ?sum ems: :12 ?new ?9 UN I VERSAL COURT RE PORT ING (954) 7122600 (877) (3376) manna Him-w (Pages 302 to 305) "Mt Page 306 Page 308 1 questions, my counsel has told me that if i do so, i 1 MR. PIKE: Form. 2 risk losing his representation and potentially waiving 2 THE WITNESS: I'd like to answer that question, 3 my rights. Sorry. Go ahead. 3 like I?d like to answer most of your other 4 With regard to the girls who came to your home 4 questions here today with respect to the claims of 5 between 2001 through 2006 who were under the age of 18 5 all these girls. However, my attorneys have told 6 you knew that each of them was not a trained masseuse, 6 me I may not answer those questions today and must 7 correct? 7 assert my rights under the Fourteenth, Fifth and 8 MR. PIKE: Form. 8 Sixth Amendment. - 9 THE WITNESS: i would like to answer each one 9 So though your partner can't be here the 1 0 of the claims brought by your various girls. 1 0 partner that filed most of your cases because 1 1 However, today, my counsel has told me that i must 1 he?s been suspended ?om practicing law by the 1 2 not answer any questions that may be relevant to 1 2 Florida Bar, or Mr. Edwards' partner who sits to 1 3 any of the lawsuits brought by your ?rm, or Mr. 1 3 your right can't be here because he's in jail for 1 4 Edwards' firm whose partner sits in jail accused by 1 4 fleecing people but of their entire life savings by 1 5 the US. Attorney of South Florida of his firm 1 5 crafting cases of a sexually charged nature. As 1 6 being a criminal enterprise, his partner being in 1 6 you might imagine, I would like to answer each and 1 "l jail for the rest of his life accused by the United 1 7 every one of your questions, but at least today, I 1 8 States Government of fabricating cases of. a 8 cannot, because if i choose to do so, l?rn told by 1 9 sexually charge nature in order to fleece local 1 9 my counsel that I risk losing their representation 2 0 investors out of their life savings. So though Fri 2 0 and waiving my rights. 2 1 like to answer those questions, Mr. Horowitz 2 1 BY MR. HOROWITZ: 2 2 very much so, in fact, my attorneys have told me 2 2 With regard to all of the underage girls who 2 3 that if I choose to do so, I risk losing their 2 3 came to your home between 2001 and 2006, isn't it true 2 4 representation and waiving my rights. 2 4 that you touched all of them on either their breasts, 25 MR. HOROWITZ: 25 vagina, buttocks, or some combination of those three Page 307 Page 309 1 Okay. With regard to all of the underage girls 1 parts? 2 who came to your home between 2001 and 2006, you knew 2 MR. PIKE: Form. 3 each them was under the age of 18; is that right? 3 THE WITNESS: i'd like to answer every one of 4 MR. PIKE: Form. 4 those questions with great specificity, however, 5 THE WITNESS: i am going to have to respond to 5 today, my attorneys have advised me that any 6 that question the way We responded to most of 6 question that may be relevant to any of the 7 your questions here today. l'd like to respond to 7 lawsuits ?led by your ?rm, your firm whose 8 every one of your questions with reSpect to all 8 partner has been suspended by the Florida Bar for 9 these claims made by your clients, claims filed by 9 improper behavior, cases filed by Mr. Edwards? ?rm 10 your partner who's not here because he's been 1 0 whose partner sits in jail for the rest of his 1 3. suspended from practicing law in the State of 1 1 life, accused and pled guilty, I believe, to 12 Florida -- in fact, practicing law anywhere, or 12 fleecing investors out of some of their life 13 Mr. Edwards1 partner who?s injaii for the rest of 1 3 savings and like crafting cases of a sexually 14 his life for ?eecing local investors out of their 1d charged nature. I?d like to answer every one of 15 life savings by crafting cases of a sexually 1 5 your questions with great specificity. However, 1 6 charged nature. l'd like to answer every one of 1 6 i?rn told by my counsel if I choose to do so, i risk 17 your questions, but my counsel has advised me i may losing his representation and waiving my rights. 1 8 not today. And if choose to do so, which is my 1 8 BY MR. HOROWITZ: 19 preference, 1 risk losing his representation and/or 1 9 Between 2001 and 2006 did you keep sexual toys 2 0 waiving my right. 2 0 for your own use in your Palm Beach County home? 2 1 BY MR. HOROWITZ: 2 1 MR. PIKE: Form. 22 And with regard to all of the underage girls 2 2 THE WITNESS: l'd like to answer that 23 who came to your home between 2001 and 2006, you askec 2 3 question. I'd like to answer the questions of all 24 each of them to undress in your presence while giving 2 4 your claims regarding your girls that you?re 25 you a massage; isn?t that right? 2 repreeing. Unfounat your partne be 30 (Pages 306 to 309) UN I VERSAL COURT RE PORT I NS (954) 712*2600 (877) 291-DEPO (3376) ?2 Pmu?c??l? meagre ?ak? mm?lm?iwi? ?g?i WW3 tres?mtma?mm mate-autia?ameuszmsearumt treasure #322 seasmsatamranaxrae intestinesmmvameram?emwmnu .. "uwwivamgaugmcmuuraides?, M, ?Momma -- Page 310 Page 312 x; El 1 here because he's been suspended from practicing 1 assert the Fifth 2 law. So though I?d like to answer your questions, 2 MR. PIKE: Well, you wan you want to be 3 I?ve been advised by my counsel that i cannot 3 here asking the same question let inc -- let me 4 today. I must assert my rights under the 4 get this straight. Despite the fact that the Court 5 Fourteenth, Sixth and Fifth Amendment. And though 5 has because I'm working on time, all right? So 5% 6 I'd like to answer each one of these questions with 6 deepite the fact that the Court has already made a 7 great specificity, i'm told that if I choose to do ruling on a number of issues covered by the Fifth 8 so, I risk losing his representation and waiving my 8 Amendment, you still want to ask those questions 9 rights. 9 again while you're here at deposition just to have 10 BY MR. HOROWITZ: 1 0 Mr. Epstein invoke the Fifth Amendment, correct? 11 Between 2001 and 2006, isn't it true that you 11 MR. HOROWITZ: Well, you don?t know what 12 used sexual toys on underage girls in Palm Beach 12 questions i intend to ask. I have some very 1 3 County? 1 3 specific questions about his net worth that have 1 4 MR. PIKE: Form. 1 4 not been addressed by any Court. 1 5 THE WITNESS: i would like to answer every one your questions regarding these ciairns by your 1 6 Okay. Is your net worth over one biliion girls, but on advice of counsel today, i?ve been 17 dollars, sir? ?g 18 told that I must assert my rights under the Fifth, 1 8 THE WITNESS: 0n advise of counsel, I am going 1 9 Sixth and Fourteenth Amendment. i'd prefer to, in 19 to have to invoke the Fifth Amendment, Sixth 2 fact, assert those rights to your partner who has 2 0 Amendment and Fourteenth Amendment. 2 1 been suspended by the Florida Bar since filing 2 1 BY MR. HOROWITZ: 2 2 these sexualiy charged cases, or Mr. Edwards? 2 .2 Do you either own or have a bene?cial interest 2 3 partner who sits next to you, for his partner who?s 2 3 in the property located at 358 Brilio (phonetic) Way in 24 now sitting spending the rest of his life in. 2 4 Palm Beach, Florida? 25 jail accused of stealing the life savings of many 2 5 A I'm going to have to invoke my Fi?h Amendment Page 311 Page 313% 1 Floridians by crafting sexual iy cases of a 3. Sixth Amendment and Fourteenth Amendment Right. 2 2 3 answer each and every one of your questions, 3 in the property located at 9 East 71 st Street in New 4 Mr. Horowim, today, I'm told if i choose to do so, 4 York, New York? 5 I risk losing the representation of my counsel and 5 A On advice of my counsel, I am going to have to 6 waiving my rights. 6 invoke my Fifth Amendment, Sixth Amendment and 7 BY MR. HOROWITZ: Fourteenth Amendment Right. 8 What is your net worth at the present time? 8 Do you either own or have a beneficial interest 9 MR. PIKE: Form. I'm going to instruct him not 9 in the Property located a? 49 Zorro (Phonetic) Rand! 10 to answer that question. There's no the Court 10 Road in Stanley, New 1 1 has already ruled on that. Pursuant to the Court's 11 A On advice of my counsel, Mr. Horowitz, though 1 2 order, your order, and Mr, Edwards' order_ 12 i'd like to answer these questions, my counsel has 1 3 MR. HOROWITZ: Are you instructing him not to 13 advised me that i must invoke my Fifth Amendment, Sixth 14 answer? 1 4 Amendment and Fourteenth Amendment Right. 1 5 MR. EDWARDS: My order? 1 5 Do you either own or have a bene?cial interest 1 5 MR. p?qg; Yeah, 16 in a property located at 301 East 66th Street in New MR. HOROWITZ: Are you instructing him not to 17 York, New York? 1 8 answer? 1 8 A Again, Mr. Horowitz, I'll have to answer that 1 9 MR. PIKE: It's already it's already been 1 9 question, as I?ve answered mostly all your other 2 ruled on by the Court that Mr. Epstein does not 2 0 questions here today, though in like to answer each one 2 1 have to answer any net worth information. That 2 1 with speci?city, my counsel has advised me that i must 22 orderjust came out, What's the purpose in -- 22 invoke my excuse me my Sixth Amendment Right, my 2 3 MR. HOROWITZ: I believe what the Court said is 2 3 Fifth Amendment Right and Fourteenth Amendment Right, 2 4 that it sustained his Fi?h Amendment privilegethough I'd prefer to answer these 25 he's got to assert the Fifi . He can he can 25 questions, i'm told that if I choose to do so, ris 31 (Pages 310 313) UNIVERSAL COURT RE PORT ING (954) 712~2600 (877) (3376) Page 314 Page 316 losing the representation of my counsel and waiving 1 MR. PIKE: Form to all these net worth 2 those rights. 2 questions. Are we in agreement there? 3 MR. PIKE: Before before you start another 3 MR. HOROWITZ: No, I -- I think you waived it 4 question there, [just want to be clear for the 4 when you didn?t answer assert those before. 5 record that you said on the record that these 5 MR. PIKE: That's ?ne. 6 questions that you had prepared were going to be 6 WITNESS: I'd like to answer each one of I speci?cally detailed, and that they were not 7 those questions, but today, under advice of 8 addressed by the Court, but, in fact, you've gone 8 counsel, i'm going to have to assert my Fourteenth 9 9 1 0 have been directly addressed by the Court. 3. 0 Right, Mr. Horowitz. 11 Now, I?m here. I'm here. I'm here. i've 1 1 BY MR. HOROWITZ: 3. 2 unbuttoned my tie. I?ve my button - i've 2 Do you either own or have a beneficial interest it 3 pulled my tie out. I?m here for the nights for 13 in in islands known as Little St. James in the US. 4 you, but are you really going to waste our time 14 Virgin Islands? 1 5 with questions that the Court has already ruled 1 5 MR. PIKE: Form, and for the record I can't 16 on? 1 6 waive Fifth. Go ahead. 17 MR. HOROWITZ: All right. I'm not here for the 17 THE WITNESS: Excuse me, but i'd like to answe 1 8 entire night with you, okay? I've got places to 1 8 that question, but on advice of counsel, I'm going it 9 be. i?ve got a plane to catch. I'm going to try 1 9 to assert my Fifth Amendment, Sixth Amendment and 2 to get through as much as I can, but there's a 2 0 Fourteenth Amendment Right. 2 1 point in time where I?ve got to go, okay? 21 BY MR. HOROWITZ: 2 2 MR. PIKE: Okay. I understand. 22 So you either own or have a beneficial interest 2 3 MR. HOROWITZ: l'm not going to get into a 23 in the property located -- in a property located in the 2 4 banter with you right now. We're going to continue 2 4 Westminster neighborhood in London, England? 2 5 with these questions. We?re going to get done with 2 5 MR. PIKE: Form. Page 315 Page 317 1 as much as we can. 1 THE WITNESS: On advice of counsel, l'rn going 2 MR. PIKE: That's fine. Ijust want to bring 2 to invoke my Fifth Amendment, Sixth Amendment and 3 it up with the Court that you?ve gone on and you've 3 Fourteenth Amendment Right. 4 asked a ton of questions here today that have 4 BY MR. HOROWITZ: 5 already been covered by the Court's order that 5 Do you either own or have a beneficial interest 6 that of which you and i have spent a lot of time on 6 in the property located at a strike that. "i with regard to motion practice. 7 Do you either own or have a beneficial interest 8 BY MR. HOROWITZ: 8 in any property located on Avenue Folk (phonetic) in 9 Okay. Do you either own or have a bene?cial 9 Paris, France? 18 interest in the property located at 457 Madison Avenue, 10 MR. PIKE: Form. 11 Fourth Floor? 11 THE WITNESS: I'm going to answer that 12 A Though I'd like to answer each and every one of 12 question, as i've answered all your other questions 13 your questions with respect to these issues, on advice It 3 with respect to these issues, which is i am going 14 of counsel, i'm going to have to invoke my Fourteenth 14 to have to invoke my Fifth Amendment, Sixth 15 Amendment, Sixth Amendment and Fifth Amendment Right 113 Amendment and Fourteenth Amendment Right. 16 Do you either own or have a bene?cial interest 16 BY MR. in the property located at 14 Wall Street? 17 Sir, i am going to hand you a document we?ll 18 A As i said before, i'm going to -- as I've 18 mark it as Exhibit 1 it's it?s it's from the 1 9 answered most of these other questions, I'm going to 1 9 Florida Department of Law Enforcement Sexual Offender' 20 have to invoke rny Sixth Amendment, Fifth Amendment and 20 and Predator's Flyer hearing your nameFourteenth Amendment Right, though I'd prefer to answer 2 1 says, "Vehicle and Vessel information." You can take a 2 2 these questions. 22 look at it for a moment with your you and counsel. 2 3 Do you either own or have a beneficial interest 2 3 My question is simply going to be: Is this an accurate 24 in the property located at 8000 Walton Parkway in New 2 a list of the vehicles and vessels that you own as of 2 5 Albany, Ohio? 2 5 today's date? .v ?a?ksra'??r'lav': arm. 32 (Pages 314 to 317) UNIVERSAL couar REPORTING (954) (8'77) (3376) -. sat-ea: am? 343%}; ?lSa?c?ii 5% K4 him-Nit marinate mil?4&3? steamernuwz WEMK arranging w; rimmrarxremmau decreases. (Wish:- a Page 318 Page 320 3,3 menu;me Jase;st accounts of other people? MR. PIKE: Form. 33 (Fag 318 to 321) UNIVERSAL COURT REPORTING (954} (877) (3376) 1 A I am going to respond to that question, 1 MR. PIKE: Form. 2 Mr. Horowitz, as We responded to every other question 2 THE WITNESS: I would like to answer that 3 today virtually, which is i am going to have to invoke 3 question, but i am going-to have to answer the same 4 my Fifth Amendment, Sixth Amendment and Pourteenth 4 way I've answered most of your other questions 5 Amendment Right. 5 today, which is my counsel has informed me that any 6 MR. HOROWITZ: Okay. 6 questions relevant to these lawsuits, i must invoke 7 MR. PIKE: Form. 7 my Sixth Amendment, Fifth Amendment and Fourteent 8 BY MR. 8 Amendment Right. 9 With respect to the vehicles and vessels listed 9 BY MR. HOROWITZ: 10 on Document Exhibit 1, are there any vehicles on 10 Since the first lawsuit was ?led against you it 1 that list that you do not own or have a bene?cial 3. alieging childhood sexual abuse, isn't it true that your 12 interest in at the present time? 3.2 efforts to conceal your assets have included placing 13 MR. PIKE: Form. 1 3 money in the accounts of corporations in which you have 14 THE WITNESS: I?m going to assert my Fifth 14 a bene?cial interest? 15 Amendment, Sixth Amendment and Fourteenth Amendment 15 MR. PIKE: Form. 16 Rights. 16 THE WITNESS: Mr. Horowitz, l'm going to answe I BY MR. HOROWITZ: "i that question, as i've answered most of your other 1 8 And with respect to the vehicles and vessels on 1 8 questions here today. My counsel has informed me It 9 Exhibit 1, are there any other vehicles or vessels not 1 9 that I cannot answer any questions that may be j_ 2 0 on that list which you -- which you own? 2 0 relevant to your lawsuits, so therefore, I must i. 2 1 MR. PIKE: Form. 2 invoke my Fourteenth Amendment Rights, my sixth 22 THE WITNESS: Pin going to answer that 22 Amendment Rights and my Fifth Amendment Rights. 2 3 question, as l've answered most of your other 2 3 BY MR. HOROWITZ: - 24 questions here today, which is I am going to have 24 Since the filing of the ?rst lawsuit against 2 5 to invoke my Fifth Amendment, Sixth Amendment and 2 5 you in which it was alleged that you committed sexual Page 319 Page 321 Fourteenth Amendment Right. 1 abuse 2 BY MR. HOROWITZ: 2 THE REPORTER: Committed I?m sorry? 3 And in the past two years isn't it true, sir, 3 MR. l'm sorry, I?ll slow down a 4 that you have transferred vehicles and -- vehicles, 4 little bit. 5 vessels or aircraits out of your own name to other 5 BY MR. HOROWITZ: 6 parties in an effort to defraud potential creditors? 6 Since the ?ling of the ?rst lawsuit against 7 MR. PIKE: Form. 7 you in which it was alleged that you committed childhood 8 THE WITNESS: Unfortunateiy I'd like to answer 8 sexual abuse, have you expended money those questions, but on the advice of 9 lawyers of witnesses in in the lawsuit? 10 counsel here today, i cannot answer any questions 10 MR. PIKE: Form. 1 1 that may be relevant to any of the lawsuits. 3.1 THE WITNESS: Mr. Horowitz, going to answe 12 BY MR. HOROWITZ: 12 that question the way I?ve answered most of your 13 Ali right. Since the first civil lawsuit was 3.3 other questions here today, which is though i?d 14 ?led against you alleging childhood sexual abuse, have 14 like to answer those questions, I've been advised 15 you been taking steps to hide and conceal your assets? 15 by my counsel that i may not. And if i choose to 6 MR. PIKE: Form. 16 do so, and not invoke my Fourteenth, Sixth and 17 THE WITNESS: I would like to answer that 3.7 Fifth Amendment Rights which i am hereby doing, 18 question with speci?city, however, my counsel has 18 that if 1 answer those questions I lose 9 advised me that i must invoke my Fourteenth 1 9 potentially lose his representation and/or waive my 2 0 Amendment, Sixth Amendment and Fifth Amendmem 2 0 rights. 2 1 Right. 2 1 BY MR. HOROWITZ: 22 BY MR. HOROWITZ: 22 Did you have surveillance cameras in either the i 2 3 Isn't it true, sir, that your efforts to 2 3 interior or exterior of your home on at Brilio Way 2 4 conceal your assets have included piecing money in 2 4 between 2001 and 2006? Page 322 Page 324 WITNESS: Mr. Horowitz, l'm going to answer 1 questions of a sexual nature, I would refer to, in 2 that question the same way We answered most of 2 fact, direct it to your partner who?s been 3 your other questions here today. i'd like to 3 su3pended after he ?led some of these cases from 4 answer each one of your questions regarding your 4 practicing law -- he got suspended from filing 5 claims with great speci?city, however, my counsel 5 practicing law in Florida. 6 has advised me that i may not today, and thereby 6 Mr. Edwards? partner who's in jail for crafting 7" have to invoke my Fourteenth Amendment Rights, my cases of a sexual nature, defrauding investors, 8 Sixth Amendment Rights and Fifth Amendment Rights 8 local people, out of their life savings by 9 as provided by the US. Constitution. So though 9 fabricating malicious sexually charged cases. So it 0 I'd like to answer those questions, I've been 1 0 though I would like to answer each and every one of 11 informed that if I do so, i risk losing his 1 3. your questions, today I cannot do so. And I?m told 3.2 representation and/or waive my rights. 12 that if i choose to do so, i risk losing the 3.3 BY MR. HOROWITZ: l3 representation of my counsel. 1 4 Sir, have you had sexual contact with girls 1 4 BY MR. HOROWITZ: 15 under the age of 18 in New York State in the past ten 1 5 Was it your practice between 2001 and 2006 to It 6 years? 1 6 use your power to in?uence minor girls into having MR. PIKE: Form. sexual contact with you? 3.8 THE WITNESS: l'm sorry? 18 MR. 91KB: Form. 1 9 BY MR. HOROWITZ: l. 9 THE WITNESS: I would like to answer each and 2 0 Have you, Jeffrey Epstein, had sexual contact 2 0 every one of your questions. HOWever, my counsel 2 with girls under the age of 18 in New York State within 23. has told. me I may not. And though i would prefer 2 2 the past ten years? 2 2 to answer, he's told me that if I choose to, I w- 23 MR. PIKE: Form. 23 if. potentially will lose his representation or 2 4 THE WITNESS: Mr. Horowitz, i?d like to answer 2 4 waive my rights, therefore, I must invoke the 2 5 every one of your questions here today about the 2 5 rights as protected under the Constitution of Page 323 Page 325 1 claims made by all your girls. However, on advice 1 the Fourteenth Amendment, Sixth Amendment and Fifth 2 of my counsel, I've been toid that I must invoice my 2 Amendment. 3 Fourteenth Amendment, Sixth Amendment and Fifth 3 BY MR. HOROWITZ: 4 Amendment Rights. Though i would like to answer 4 Isrrt it true, sir, that the real reason that 5 those questions, We been told if I choose to do 5 you brought underage girls to your home in Palm Beach 6 so, I risk losing my counsel's representation 6 County between 2001 to 2006, was that you could get 7 and/or waive those rights. 7 sexual satisfaction? 8 BY MR. HOROWITZ: 8 MR. PIKE: Form. 9 Have you had sexual contact with girls under 9 THE WITNESS: Mr. Horowitz, I would like the State of New Mexico in the past ten 3.0 answer each and every one of your questions that 1 1 years? 1 1 you've raised here today. Unfortunately my counsel 12 MR. Form. 3.2 has advised me that i cannot, and they have 1 3 THE WITNESS: Mr. Horowitz, l'm going to answer 13 instructed me to assert my rights as the as 14 that question the same way I?ve answered virtually 3.4 under the Fourteenth Amendment, Sixth Amendment an . 5 all of your questions here today. On advice of my 1.5 Fifth Amendment of the US. constitution. I would 16 l6 questions he's informed me that i must invoke my 3.7 prefer to answer those questions, but my attorney l8 Sixth Amendment, Fifth Amendment and Fourteenth 18 has told me I may not. But if I choose to do so, i 1 9 Amendment Right under the US. Constitution. 1 9 will risk losing his representation and/or waiving 2 0 BY MR. HOROWITZ: 2 0 those rights. Five minutes? 2 1 Sir, between 2001 and 2006 was it your practice 21 MR. HOROWITZ: Sure. 22 to use your wealth to in?uence minor girls to have 22 THE VIDEOGRAPHER: Time off the record 6:05 2 3 sexual contact with you? 23 (Thereupon, a short break was taken.) 24 MR. PIKE: Form. 24 MR. HOROWITZ: All right. Let mejus -- 25 25 was: new rm; r?mx'p/ mm THE WITNESS: Mr. Horowitz, these types of man. 33.55318 5.8 ?35: {4-32 3:3 rttesaawssau tsatarsz-sta {ta an an: :32 9.9353 - ??wt?i ans $925615. Ses'?iid?i?'dw! ms: h?c? m3 $518} i?hii?ik?x?h a it?d-i $53 ti?ii?id??i??t I- VIDEOGRAPHER: Time on the record 6:11. 34 (Pages 322 to 325) UNIVERSAL COURT REPORTING (954) 712*2600 (877) (3376) Page 326 Page 328 1 MR. HOROWITZ: All right. Let me just get this 1 to put that on the record, so that it?s clear why 2 on the record. It's now 6:11 pm. We've been 2 we're not ?nishing, at least from my vantage 3 working all day, as best we can, plowing through so 3 point. a; 4 far the claims of my seven clients, and though I 4 MS. EZELL: And I'd to add that I had cross- 5 have done my very best on my part to get through as 5 noticed on behalf of our client in the one ?led a 6 much material as I can, I simply cannot finish 6 case we have. We also represent three other ?i "7 today, number one, because we?ve already been 7 clients, and we do not yet have filed cases. We 8 working an eight-hour day, and two, maybe more 8 certainly want a chance to ask our questions as i 9 importantly, I have a plane to catch in about a 9 well. I do think we wasted a great deal of time 10 little bit over an hour. So with that said, I 10 today in very self-serving answers that did nothing 1 1 cannot complete today. You know, you can ?le what 1 1 to advance the discovery in this matter. 3.2 you need to, and I'll ?le what I need to, but 12 MR. PIKE: Is everybody done? 13 MR. EDWARDS: Wen 13 MR. Yes. 14 MR. HOROWITZ: Do you want to say anything? 14 MR. EDWARDS: I'll justjoin in on the comment 15 MR. EDWARDS: Yeah. For the purposes of the 15 by defense counsel. 1 6 record, l?d. just like to make the record in that 1 6 MR. PIKE: Okay. i?m just going to move to 1 the deposition was set in nine cases today, I 1 7 strike for purposes of the trial. I understand 18 believe. i was unable to ask any questions today, 1 8 that everybody is trying to make a record for any 3 1 9 and I think the record is going to be clear as to 1 9 future motion, but I move to strike everybody's 2 0 the reason why that happened, both the video and 2 0 comments for purpose purposes of the trial in 2 the transcript, in a case like this where the 2 1 this matter. 2 2 options are answer questions, or take the Fifth, 2 2 We're here right now, Mr. Edwards, for you to 2 3 and the election for the most part was take the 23 begin and ?nish your deposition. We're here right 24 ifth, it should be a short abbreviated 24 now for you, Mrs. Ezeii, to begin and ?nish your 2 5 deposition. instead the types of answers that we 2 5 deposition of Mr. Epstein. And Mr. Horowitz, this Page 32'? Page 329 1 received were obstructionist in nature. I think 1 case has been -- this deposition has been set for 2 that that's that's going to be something that 2 some time, and, you know, whether or not you have a 3 the Court is going to rule upon, but that?s going 3 ilight plan, or whether or not it was prearranged, 4 to be our position. And that after every nearly 4 I do not know. But we are here right now to ?nish 5 every question, there was some injection into the 5 your deposition for your clients. So I see that I 6 record by Mr. Epstein about Jeffrey Herman and some 6 everybody is standing, with the exception of 7 discipline that he had with the Florida Bar, as '7 Ms. Ezeil. I?m sitting, and For ready to ?nish 8 well as Scott Rothstein and his being in jail, as 8 this deposition and let you guys commence. 3 9 well as something to do with other partners going 9 MS. EZELL: We?ve been going for eight hours 1 0 tojail, despite the fact that I haven?t asked a 10 and ?fteen minutes. The facility we?re in is all i: 11 single question, nor have any questions been asked 11 closed down. The lights are off everywhere. We 32 about my clients. 12 can?t get in and out of doors. i. think to suggest 1 3 in addition to the mockery that was made of 1 3 we proceed for what would be another eight hours at 14 this deposition by Mr. Epstein and of the overall 14 this point isjust not workable. 1 5 discovery process today because of the way he chose 15 MR. EDWARDS: And i probably have five hours 0 1 6 to answer questions and that his counsel did not 16 questions, and that's assuming that the answers instruct him to do otherwise, and instead seemed to 7 that we receive were less elongated than the ones 1 8 encourage those types of responses, we're unable to 8 we received already. So given the circumstances 19 ?nish today. it's going to take another day. 19 and the nature of the responses and how long it 2 0 And one other thing that i think is going to be 2 0 takes to respond, we would not ?nish until next 2 1 clear, but I want to put on the record, is that we 2 1 Thursday at this pace so Ijust don't think it 22 probably took fifteen no exaggeration -- breaks, 22 would be fruitful to continue. 2 3 each one of them initiated by Mr. Epstein, which 2 3 MR. PIKE: I understand your statement. 26 24 . 35 (Pages 326 to 329 UNIVERSAL COURT REPORTING (954) 712?2600 (877) (3376) Page 330 Page 332 to have it after hours. Our particular area is 1 2 is area is not closed down, so if you'd iike to 2 3 go forth with the deposition, we are here, as I've 3 STATE OF FLORIDA 4 said 4 COUNTXC 0F BROWARD 5 MR. HOROWITZ: Let me say this. You know, my 2 6 neariy of my ciients have had two days of 7 I, the undersigned authority, certify that 7 deposmonss despite the they re parties 8 Jeffrey Edward Epstein personain appeared before me am. 8 to only one case. Mr. Epstein IS a party to a 9 was duly sworn. 9 dozen casesjust for on the iawyers who are here 10 10 today. So given the practice of parties? appearing 1 WITNESS my hand and officiai seal this 22nd day 1 1 for two days of depositions in the past, it makes 12 0f Mamhs 2010- 12 sense particularly in the case of Mr. Epstein who's 1 3 a party in muitipie cases to do at ieast two days 1 5 1 4 of depositions for the same reasons. There?s just material to cover. . Vicki L. Lima, Court Reporter 1 6 MR. PIKE: I think everybody has said their Notary pub?c State OfFiorida 17 piece. Commission No: DD 882608 18 MR. EDWARDS: Yep. 18 Expiration Date: May 26, 2013 1 9 MR. PIKE: Are we going off the record? 10b #920763 20 MR. HOROWITZ: Yes, we can go off the record. 2.1 THE VIDEOGRAPHER: Time off the record 6:17. 21 22 (Videotaped deposition was conciuded.) 22 2 3 (Thereupon, Exhibit No. i was marked for 2 3 2 4 identi?cation.) 2 4 2 5 THE REPORTER: Do you want to order this, 2 5 Page 331 Page 333 1 Mr. CERTIFICATE 2 MR. HOROWITZ: Yes. 3 STATE 3F Home; 3 We'll take a copy' 5 COU?iiegiFL?l?gla??igrt Iieporter, Notary Pubiic 4 MR- PIKE: We'llekemw- . 5 Copy, please. duly sworn to testify to the whole trad); that Iywas aaihorized to and did report said deposition in 6 (Proceedings were stenotype; and that the foregoing pages are a true and 7 8 coneet?traoscription of my shorthand notes of said 8 9 deposmon. 9 3.0 i ?arther cenify {hat the said deposition was taken a: the time and place hereinabove set forth and 0 3.1 that the iakiag of said deposition was commenced and 1 12 completed as heremabove set out. 1 2 2 further eeriin that I am not an attorney or 1 3 1 3 cormsei of any of the parties, nor am I a reiative or foe faittn 'The foregoing certi?cation of this rranseript 6 does not appiy to any of the same by any 3. 7 means unless under the direct control andfor direction 1 8 17 of the certifying reporter. 1 8 IN WITNESS WHEREOF, I have herein-no set my hand 1 9 this 22nd day of March, 2020Vicki L. Lima, Court Reporter 2 2 Notary i?ublie - State orrlorida 2 3 2 2 Commission No: DD 882608 Expiration DateJob #920763 24 2 5 25 36 (Page 330 to 33 UN IVERSAL COURT RE PORT ENG (954) 712-26OO (877) 291-DEPO (3376) 332.53% museutmem 5% amazesmme E?i?i? (re-24x; -2 '63? $33913 cere?cs 5. Page 334 33/2 ?st it {$565 @mii??mt it?' i?t 7' sis gossametez'm 3. UNIVERSAL LEGAL REPORTING 888 EAST LAS OLAS BOULEVARD, SUITE 508 2 FORT LAUDERDALE, FLORIDA 33305 (95a) 722-2609 3 March 22, 2010 Job #9207643 Volume 2! 4 ief?frey Edward Epstein, witness 5 Michael J. Pike. Esquire 303 Banyan Boulevard. Suite 400 6 West Palm Beach, Florida 3340] ?3 RE: forte Doe No. 2 vs. Jeffrey Epstein CASE NO: OS-CV-SOI 8 Dear Mr. Epstein: 9 Please take notice that on March 8, 2008, you 1 0 gave your deposition in the abovoreferred matter. At that time, you did not waive your signature. It is now 1 1 necessary that you sign your deposition. As agreed to, the transcript will be 1 2 furnished to you through your counsel. Pioesc read the following instructions: 13 At {?age 335. you wiil find an errata sheet. As you read your deposition, any changes or corrections 1 4 that you wish to make should he noted on the errata sheet, oiling page and line number of said change. DO 1 5 NOT write on the transcript itself. Once you have read the transcript and noted any changes. he sure to sign 16 and date the errata sheet and return lliese pages to us at the address listed above. You need not return the 1 ?t entire transcript. If you do not read and sign the deposition 18 within thirty (30) days. the original, which has already been forwarded to the ordering attorney. may be fitted 19 with the Clerk ofthe Court. if you wish to waive your signature. sign your name in the blank at the bottom of zo this terror and return it to us. 2 1 Very truly yours. Universal Legal Reporting, 2 2 2 3 Vicki L. Lima Court Reporter - Notary Public 2 4 i do hereby waive my signature. 2 5 Page 335 1 A A 2 IN RE: Jane Doc No. 2 vs. Jeffrey Edward Epstein 3 DEPOSITION OF: Icf??ey Edward Epstein, Volume II 4 TAKEN: March 8, 2019 5 DO NOT WRITE. ON TRANSCRIPT - ENTER CHANGES HERE 6 PAGE it LINE ti CHANGE REASON .Phase forward the original signed errata sheet to this 2 1 of?ce so that copies may be distributed to all parties. 22 Under penaity of perjury, i deciare that have read my deposition and that it is true and correct subject to 2 3 any changes in form or substance entered here. 2 4 DATE: SIGNATURE OF DEPONENT 2 :3 Job #9207643 wider: mom'th 3's. UNIVERSAL COURT REPORTING (877) (954) 712*2600 291WDEPO Afx??m?e - . 37 ?vi?h?i? #5434333 (Pages 334 to 335) (3376) DEFENDANT BRADLEY J. EDWARDS STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, eta]. Case No. 50 2009 CA ATTACHMENT 9 I UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. JANE DOE, @041 x? Plaintiff, VS. JEFFREY EPSTEIN, et 31., Defendants. Related Cases: 08~80119, 08?80232, 08?80380, 08?80381, 08w80811, 08w80893, 09*80469, 09m8?59l, 09?80656, 09?80802, 09?81092 {wk VIDEOTAPED DEPOSITION OF NADIA MARCINKOVA TAKEN ON BEHALF OF THE PLAINTIFF DATE: April 13, 2010 U.S. Legal Support (561) 835-0220 take the Fifth. I represent a lady named, a young female named you know who that_is, right? MR. YAREMA: Object to the form. A The Fifth. Jeffrey Epstein made you have sex with E.W., didn't he? MR. YAREMA: Object to the form. A The Fifth. You did, in fact, engage in sexual activity with E.W. when she was only 16 years old; isn't that true? MR. YAREMA: Object to the form. A The Fifth. Back to my original question; And I'll ask you this way: Do you consider yourself heterosexual, binsexual, or can you answer that question? MR. YAREMA: Object to the form. MR. GOLDBERGER: Same objection. Do not answer the question. A Fifth. How did you meet Jeffrey Epstein? A Fifth. When did you become one of Jeffrey U.S. Legal Support (561) 835*0220 DEFENDANT BRADLEY J. EDWARDS ?8 STA TEMENT OF UNDISP UT ED FACTS Epstein v. Edwards, et al. Case No. 50 2009 CA ATTACHMENT 8 10 ll 12 13 .H14 .Page 270 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO: OS-va80119 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. CONDENSED JRNE DOE NO. 3, CASE NO: Plaintiff, VS. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, CASE NO: Plaintiff, VS. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 5, CASE NO: Plaintiff, VS JEFFREY EPSTEIN, Defendant. Kress Court Reporting, Inc. 305866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 Page 271 Page 273 1 JANE DOE N0. 6, CASE NO: cow-88994 1 IN THE GRCUIT COURT OF THE 15TH 2 Plaintiff, JUDICIAL CIRCUIT PALM BEACH COUNTY, FLORIDA 4 JEFFREY 5mm? 3 CASE no. sozooecmozra 19mm; AB 5 Defendant. 4 6 8.3., Jame DOE N0. 7, CASE NO: 03431-80993 5 7 Plaintiff, PlaintiffJEFFREY 6mm! 8 JEFFREY EPSTEIN. 10 Defendant. Gamma?; 11 9 mm] 22 C. M.A., CASE NO: os~cv?soau 1o 13 Plaintiff, Ii 14 VS- 12 1031 Ives Dairy Road 15 JEFFREY EPSTEIN, Suite 228 ?5 13 North Miami, Fto?da 17 August 7, 2069 awe DOE, CASE no: com-30393 i; 1:15 pm to 5:VIDEOTAPED V5. 13 DEPOSITION 20 JEFFREY 5mm 19 ?f 21 20 ALFREDO RODRIGUEZ Defendant. 21 22 22 taken on behaif of the Piaintiffs pursuant 23 23 to a Rte-Notice of Taking Continued Videotaped 24 24 Deposztion (Duces Tatum) 25 25 .. .. Page 2'22 Page 274 1 JANE DOE N0. 11, CASE NO: 1 APPEARANCES: 2 Piaintiff, 2 3 vs. 3 4 JEFFREY 59mm: 4 28205 Biscayne 5 Defendant. Suite 2218 5 Miami, Fiorida 33160 6 Attorney for Jane Doe 2, 3, 4, 5, JANE DOE NO. 101 CASE NO: os~cv~30591 51'3"" 7' 7 a ROSENFELDT muse Piainti?', BY: BRAD J. EDWARDS, ESQ, and 8 9 CARA HOLMES, ESQ. V5. Las Dias City Centre 9 10 Suite 1650 401 East Les Dias Bouievard JEFFREY Emmi 11 Fort Lauderdaie, Florida 33301 10 Attorney for Jane {Doe and EW. DefendantRSECK 12 JANE N0. 102, CASE NO. 08 CV 80656 BY: KATHERINE w. Elm" ESQ. 13 ?am 1 15 25 West FIagierStreet 14 Vs. Suite 800 15 JEFFREY EPSTEIN, 16 Miami, Florida 33130 15 Defendant Attorney for Jane One 101 and 102-. 17 17 18 $013011}me 18 19 BY: ADAM J. mnomo, ESQ. 19 2925 PGA Boulevard 20 20 Suite 200 21 Palm Beach Gardens, F?crida 33420 21 Attorney for 8.8. 22 23 24 Kress Court Reporting, Inc. 305666-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 ?a r. acqu 4..- u-ww a .. Migmn?W m van-w aim-RH? nan-nun -- v, v-A-w a; an.? .. Page 275 Page 1 APPEARANCES: 1 Deposition taken before MICHELLE PAYNE, Court RICHARD mum ESQ. 2 Reporter and Notary Public in and for the State of 2290 1am AVenue'Nore: 3 Florida at Large, in the above cause. 4 Suite 404 4 .. .. .. 5 mm; Elm? 33?? 5 THE VIDEOGRAPHER: This is a continuation Appeared via telephone. 6 of the deposition of Alfredo Rodriguez. 1 7 Today is Friday, August the 7th, the year i, elm-{OM wry-15R 8 2009, starting time approximately 1:15 pm. i a gotagi?sa?a?mm ESQ 9 hWill the court reporter piease swear in i I 10 witness? 9 3:811:35? Flagler Drive 1 1 Thereupon? 10 West Palm Beach, Fiorida 33401 12 ALFREDO 11 Jeffrey Elm? 13 having been ?rst duly sworn or af?rmed, was 12 14 examined and testi?ed as foiiows: :3 ALSO PRESENT: 15 MR. Before we get started just 16 with regard to Ms. Ezell represents Jane Doe 15 VIDEOGMPHER 17 101 and 102, the alleged time of her 16 18 incidents as of least have been plead in the 17 19 compiaint for 101 is '99 I'm sorry, '98 18 20 through 2002, with Jane Doe 102 the Spring :3 21 of Sprinngummer of 2003. Mr. Rodriguez . 21 22 never even began employment until '04 and 22 23 '05. Ithink her questioning I think g: 24 can't say she doesn't have standing based on 25 25 the court order, but I would say it?s Page 276 Page 278 . 1 CONFINUED INDEX OF WMINATTON 1 completely irrelevant and immaterial and has 2 wrmess 0mm, CROSS REDIREC, 2 no probative value with regard to this 3 3 particuiar witness based upon the two 4 RODRIGUEZ 4 clients at least that are in suit at this 5 point in time. 5 (BY mu) 441? 467 6 MS. EZELL: As Mr. Critton well knows I 6 (By Mr. wane) 334 453, 469 7 represent a number of other clients whose . 8 cases have not been filed and I believe we 7 Chum) 338 464 9 do have standing to ask questions, and I do 8 (By Mr. Edwards) 419, 454, ?as 10 intend to do that today. 11 EXAMINATION 9 Wm?) ?52 12 or MS. EZELL: it; 13 Q. Mr. Rodriguez, rye: states:c last time that . 14 are were guests att ouse, requent guests, if, mw?f?gmlm 15 friends from Harvard, 14 3 Drawing 315 16 Do you remember that testimony? 15 4 Photograph 327 17 Yes! [natal-m is 2523:3332 18 Q. And was there a iawyer from Harvard named 1a 7 Photograph 331 19 Alan Dershowitz? i' 19 8 Photograph 443"531 A. Yes, ma'am' 5_ ?g 355were rammed by M5. 21 IQ. And are you familiar with the fact that Ezeil.) 22 he a famous author and famous lawyer? 22 23 A. Yes, ma'am. $3 24 Q. How often during the six months or so 25 25 that you were there was Mr. Dershowltz there? I Iw'y u- .a pf "Mung-aw.? . .w .. nun 3 (Pages 275 to 278) Kress Court Reporting, Inc. 305866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 Page 279 Page 281 1 A. Two or three times. 1 Q. Can you tell me where those were? i 2 Q. And did you have any knowledge the kitchenwas visiting there? 3 formal -- the main entrance. And there was one 4 A. No, ma'am. 4 more added later on, but there is two when I was 5 Q. You don't know whether or not he was a 5 working there. 6 lawyer acting as a lawyer or whether he was 6 Q. Could you just give me a rough sketch of 7 there as a friend? 7 the house of where the main entrance was and where 8 A. i believe as a friend. 8 the kitchen was? 9 Q. Were there also young ladies in the house 9 A. i?m not an architect but it's something 10 at the time he was there? 10 like this. This is the kitchen, this is the main 11 MR. CRITTON: Form. 11 entrance. 12 THE WITNESS: Yes, ma'am. 12 Q. Will you mark the kitchen with a K, 13 BY MS. EZELL: 13 please, and the main entrance with 14 Q. And would those have included, for 14 A. This is the pool. 15 instance, Sarah Kellen and Nadia Mercenacova? 15 Q. The pool? 16 A. Yes, ma'arn. 16 A. Yes, ma?am. 17 Q. Were there other young ladies there when 17 Q. And in the upper left? 18 Mr. Dershowitz was there? 18 A. In the terrace, yeah, there was a balcony 19 MR. CRITTON: Form. 19 here. 20 THE WITNESS: Yes, ma?am. 20 Q. And where were the staircases? 21 BY MS. EZELL: 21 A. This is one, the kitchenyou have any idea who these young 22 foyer, and the pool. 23 women were? 23 Q. Okay. And would you just put an where 24 A. No, ma'am. 24 the foyer staircase began? And KS where the 25 Q. Were any of those the young women that 25 kitchen staircase began. Page 280 - Page 282 1 you have said came to give messages? 1 And you said that later another staircase 2 A. Yes, ma'am. 2 was added? 3 Q. And do you have any idea whether or not 3 A. Yeah, we rehabilitated this, you know, 4 Mr. Dershowitz was also receiving messages? 4 but you asked me how many stairs there were, to A. I don't know, Ma?arn. . 5 answer your question there were three. 6 - Q. I want to ask you to take this piece of 6 Q. Three. So where was the third one? 7 paper, please, and a pencil 7 A. The pool, this leads to the pool. 8 MR. WILLITS: Can anybody hear me? 8 Through the outside master bedroom you could go 9 MS. EZELL: Yes. Can you hear me? 9 downstairs to the pool. 10 MR. WILLITS: I've heard nothing for 10 Q. Okay. A stairway then from the outside, 11 about a minute or so. 11 from outside the master bedroom? 12 MR. CRITTON: Can you hear me now? 12 A. Yes, ma?am. 13 MR. WILLITS: Yes. 13 Q. Down to the pool? 14 MS. EZELL: I'm asking questions, I?m 14 A. Yes, ma'am. 15 sorry. 15 Q. One of your duties was to answer the 16 MR. CRITTON: Why don?t we go off the 16 door. 15 that correct? 17 record for a second. 17 A. Yes, ma?am. 18 (Thereupon, a discussion was held off the 18 Q. Which door would you answer? 19 record.) 19 A. Mainly the kitchen. 20 THE VIDEOGRAPHER: We're back on the 20 Q. And why was that, why would people mainly 21 record. 21 come to the kitchen? 3 22 BY MS. EZELL: 22 A. I'll say it was for practicable reasons 23 Q. Mr. Rodriguez, you indicated that there 23 because not to go to the main it was shorter 24 were several staircases in the house? 24 because the entrance was here, so this was the 25 A. Yes, ma'am. driveway and we used to take into the back door of 4 (Pages 279 to 28 Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NM NH {Ii-hm Rage 242 engaging in sex acts with these young girls? MR. CRITTON: Form. THE WITNESS: No, I don't know. BY MR. EDWARDS: Q. No one ever toid you that? A. No. Q. Weil, since you?ve been keeping up with what's been written in the newspapers, at some point in time you've read that Nadia Marcenacova joined in some of these sex acts with some of these girls. Right? MR. CRITTON: Form. THE WITNESS: I beiieve so. BY MR. EDWARDS: Q. I'm not the first person telling you that? A. No, no, no, I read it in the newspaper. MR. CRITTON: He read your press release. MR. EDWARDS: Long before I ever had anything to do with this case. BY MR. EDWARDS: Q. Were you surprised when you read that? MR. CRITFON: Form. THE WITNESS: No. BY MR. EDWARDS: Page 244 page 72, Rodriguez stated the amount of girls that came to the house was approximately 15. That's the estimate that you gave back A. All the girls that I saw coming in and out. Q. Well, when I read this, you can teil me what it actualiy means, when i read this i . interpreted that as because they were talking about masseuses I interpreted that as the number of girls of the Palm Beach area that came over and you iabeied masseuses. Is that correct? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. Okay. Could you name I mean, I know that we've named T. and C., could you name any of the other -- A. C. comes all the time, you know, I remember her. Q. Okay. No other names pop out though? A. ?i?o be honest with you, no. Q. A. Yeah, because I remember because the car. Q. Ali right. It goes on to say, when asked to ide tify these giris, so somebody else asked EQW {322% ??ikta?wx 3.9% ease in? tithii?-fa some mam ?mi?i?i 25 Page 243 Q. Were you surprised when the story started coming out that these girls that were coming over to the house were under the age of 18 and Mr. Epstein was engaging in sex acts with them? MR. CRITTON: Form. THE WITNESS: No. BY MR. EDWARDS: Q. When was the first time that you knew for sure 100 percent that well, let me say it this way. When was the first time that you read that information? A. Underage? Q. Yes. A. When this scandai broke out when the Palm Beach Police Department Q. Contacted you? A. Yeah. MR. CRITTON: Why don?t you let him finish his answer instead of suggesting or giving him the answer. THE WITNESS: The West Paim Beach Poiice Department got involved. BY MR. EDWARDS: Q. Skipping to the second paragraph of Lom?dmm.bWNH mer Page 245 you the same question I just did, Rodriguez stated he could not at the moment but knew he wrote their names down on a journal he kept during his employ with Mr. Epstein. Is that true? A. Yes. MR. CRITTON: Form. BY MR. EDWARDS: Q. Did you ever find that journal? A. Probably has some pages at home. Q. Because later on it seems like you met up with the police officer and produced a green ioider that contained documents, but that?s not the same thing as the journal. Right? A. No, this is my writings. Q. Okay. So if we want to obtain that journal from you what?s the best way to go about getting it? A. I probahiy have to look in my house. Q. Okay. Well, it looks like we?re going to come back for a second part of this, so by next time maybe you could find it. Right? A. Okay. Q. All right. Mr. Mermeistein asked you if anybody had contacted you about this case that was either an that was an investigator with Mr. ?st??imet'?t?vmik are: ?ed-keti'kEi-S'XAR $.02 ml?izuai?t mm?? 9M Saki 935:3 at: sortie gamma.- mi M??l?m?m 5&3} 7,3353% we mmzmiwmema {29$ 5i?z??ffek9?$? 0 E) 239%? - 62 (Pages-Ee- i i i i Kress Court Reporting, Inc. 305?866-7688 713.5 Rue Notre Dame, Miami Beach, Fi. 33141 Page 222 Epstein's investigators that you felt there was more going on in the bedroom than just massages? MR. CRITTON: Form. THE WITNESS: Because they were more interested in how much I know, they didn?t ask me anything else, and I told them exactly what I knew and what I was doing. BY MR. EDWARDS: Q. Okay. You were asked by Mr. Mermelsteia when he was asking you about the meeting with Mr. Epstein's investigators he said, did they make any threat Oi? did they threaten you, and you paused and said I don't believe so. A. Yeah, I think they didn't teli me anything that I will feel they told me that they want to know what I know and EH need an attorney. Q. Okay. Did you find that strange at all that they offered you an attorney? A. I went to have dinner at my house and I told this to my wife and she told me, Alfredo, you don?t need an attorney, so I called him the next day and that was it. Q. You cailed the investigators? A. Yes. I declined, I don't need an \DmeW-?WNl?l Page 224 massage with a handle with two rubber things that you can do massage yourself, this was always on the floor, maybe one or two. BY MR. EDWARDS: Q. Okay. When you say this is always on the floor, do you mean 24 hours a day it's on the floor? A. No, no, no, after each massage. Because I assume the masseuses or anybody they were doing, they were taken out of the closet wherever they belong and they would leave there. So Louella and myself, we always find this on the floor. Q. And this is a massager that belongs to or is owned by Mr. Epstein? A. Yes. Q. This isn't something that these girls would bring over to the house? A. No, no, it?s in the house, it's part of the inventory. Q. And that statement is a few statements after you felt that there was a lot more going on than just massages, is there something about that object being left on the ground and the type of object that it was that also lead you to believe that there is something more going on here than imitwmh?i- {await-$0 . Page 223 attorney. Q. If we want to know the exact names of the investigators that you met at Don Shula's and at your house, how wouid we get that information, do you have it somewhere? A. Probably I have it in the house. Q. So if we do have to come back here and finish this up, the next time wouid you be able to bring that? A. I think so. Q. Okay. Do you know where in your house that you have it, I mean, have you kept it in a certain piace? A. I have to look. Q. All right. After the sentence that we left off it says, he, speaking of Mi?. Rodriguez, would clean Mr. Epstein?s bedroom after the alleged massages and would discover massagers slash vibrators and sex toys scattered on the ?oon Can you tell us what types of sex toys that you found scattered on the ?oor after the massages with these young girls? MR. CRITTON: Form. THE WITNESS: Like I explain, there was a 25 MW-Y?Mf??uszso .. Lama .1 Ac". Page 225 just massages? MR. Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. What about it, just teil us? MR. CRITTON: Form. THE WITNESS: I thought they were having a good time, I never thought it was something done against anyhody's will, but of course, you know that it?s more than massage. BY MR. EDWARDS: Q. Right, I?m just asking you to explain how you know that. MR. CRITTON: Let me just move to strike his last answer as speculation. Form as to your statement. THE WITNESS: You're 50 years old and it's -- you?re an aid you know, it's just instinct. MR. CRITTON: Move to strike. BY MR. EDWARDS: Q. It was obvious to you? A. Yes. MR. CRITION: Form. ?sh?s: we u?itsx?? tkwefi?imi??i?k i'ki'ii?a?ci?vis? ?tti?hi??d tits-i ii: is its 57 (regain to i: Kress Court Reporting, Inc. 305866-7688 7115 Rue Notre Dame, Miami Beach, Fl. 33141 Page 226 Page 228 i 1 BY MR. EDWARDS: 1 underwear she brought it to the laundry and we 2 Q. He also said he wouid wipe down the 2 used to label it. 3 vibrators and sex toys and put them away in the 3 Q. Just so that the record is clear as to 4 armoire. 4 what we?re taiking about with this and that, I 5 MR. ON: Form. 5 want you to tell us what Louella wouid teli you 6 THE WITNESS: These things have a tip, 6 specificaily, I found this and then would she show 7 they have the cream, they have ali kinds of 7 you what it was? 8 cream for giving massage. 8 A. No, she didn't show me, she said I 9 BY MR. EDWARDS: 9 cleaned this and I put it away, it was a vibrator. 10 Q. How many of these massagers or vibrators 10 Q. Did she describe the vibrator for you so 11 would you wipe down? 11 that you knew which one she was talking about? 12 MR. CRITTON: Forrn. 12 A. The vibrator that a female wouid use for 13 THE WITNESS: This big one alt the time. 13 personai use. 14 BY MR. EDWARDS: 14 Q. Not the same long one that you've been 15 Q. Right. Other than the big one all the 15 describing? 16 time did you wipe down at any time any of the 16 A. No. 17 other sex toys or vibrators? 17 Q. One that is a penis shaped vibrator. 18 A. No. 18 MR. CRITTON: Forrn. 19 MR. CRITFON: Form. 19 THE WITNESS: Yes. 20 BY MR. EDWARDS: 20 BY MR. EDWARDS: 21 Q. So if there were any other sex toys or 21 Q. That's what she was talking about? 22 vibrators orI beiieve you used the term dildo 22 A. Yes. 23 earlier that were ever used, those are items that 23 Q. And did she teli you on how many 24 you did not ?nd on the floor and were put away in 24 occasions after these -- 25 the armoire? 25 A. Several times. Page 227 Page 229 1 MR. CRITTON: Forrn. 1 Q. And can you explain to us why it is that 2 THE WITNESS: Louelia told me I did this, 2 and maybe it's justI don?t understand the 3 I did that. 3 process of cieaning the room who went in first and 4 BY MR. EDWARDS: 4 second and whatever, but my question tell us what did Loueila tell you? 5 that she wouid aiways be the one to encounter the 6 A. She ?nd toys on the floors, she have to 6 penis shaped vibrators and you would encounter 7 clean them. 7 this other ionger vibrator? 8 Q. Did she tell you when she found the toys 8 MR. CRITTON: Form. 9 on the ?oor? 9 THE WITNESS: Because After his massages, you know. 10 clean the room. When she was busy she will it Q. With the young girls that we're taiking 11 ask me, Alfredo, can you heip me carry, I 12 about? 12 have a lot of towels, because there were 13 A. Yes. 13 mountains because being an older woman I 14 Q. Okay. And when did Louella teli you 14 heip her carry to the and put the towels 15 that? 15 downstairs, take it to the laundry. But she 16 A. Almost every other time when she found 16 told me I found these things, I clean it, 2 17 it, you know, Aifredo I found this thing again 17 put it in that armoire, they?re over there. 18 because she despised to clean thisshe will give me we used to 19 the gioves or whatever. 19 communicate all those little detaiis, but it 20 Q. Okay. So it sounds iike you had the room ?rst. 21 actual conversation about this where she's 21 BY MR. EDWARDS: 22 describing she doesn't want to clean it. 22 Q. And what did she say about liking or 23 A. Because I told her to tell me up to date 23 disliking the fact that she had to ciean these i 24 on things that are not normal, so she toid me, you 24 vibrators? 25 25 know, I found this, I found that, or some f. .n A. She didn?t like to clean those. 58 Kress Court Reporting, Inc. 305?866?7688 7115 Rue Notre Dame, Miami Beach, FL 33141 Page 230 Page 232 1 Q. Did she teii you why? 1 a lack of respect. So, you know, she was 2 A. Because, you know, she knew what they 2 shocked. So obviously she needed a job but 3 were for and probabiy she despised to clean 3 she expressed her 4 objects. 4 MR. I'm sorry, I did not hear 5 Q. Did she ever make any comments about how 5 that, couid the witness repeat that? 6 young the girls were that were in the room with 6 THE WITNESS: I was just talking about 7 Mr. Epstein just before she had to go in and clean 7 Louelia, deeply religious staff member that 8 these vibrators? 8 worked with me and she toici me one occasion 9 MR. CRITTON: Form. 9 that she was crying because the picture of 10 THE WITNESS: No. 10 the Pope was next to a naked girl. 11 BY MR. EDWARDS: 11 MR. WILLITS: Okaythe giris that were coming 12 BY MR. EDWARDS: 13 over and going behind closed doors with Mr. 13 Q. Okay. Besides Louella did you ever have 14 Epstein a subject that ever came up between you 14 a conversation with anybody else that works in the 15 and 15 house about the young age of the girls and Mr. 16 A. Sometimes. 16 Epstein being in the bedroom and the fact that 17 Q. And what wouid the conversation consist 17 there are sex toys on the floor afterwards being 18 of? 18 wrong? 19 A. She will be surprised and say some of the 19 MR. Form. 20 girls are too young, and I said we just wonder, 20 THE WITNESS: Nobody else inside the 21 you know, but we comment each other. 21 house was aliowed except just the two of us, 22 Q. Did it ever as a father did it ever 22 so I never commented on this with anybody. 23 occur to you that maybe I should say something or 23 BY MR. EDWARDS: 24 I shouldn't be here or I shouldn't be apart of 24 Q. Ail right. The next sentence starts a 25 this considering how young they are and how old he 25 new paragraph, Epstein ordered Rodriguez to go to Page 231 Page 233 1 is? 1 the Doiiar Rent a Car and rent a car for the same 2 MR. CRITTON: Form. 2 giri he brought the roses to. 3 THE WITNESS: Yes. 3 I guess we're talking about A. 4 BY MR. EDWARDS: 4 So that she couid drive herself to 5 Q. Is that something that on more than one 5 Epstein's house without incident. Rodriguez said 6 occasion you thought to yourseif this is just 6 the girl always needed rides to and from the 7 wrong? 7 house. 8 MR. CRITTON: Form. 8 Are those statements you agree with? 9 THE WITNESS: Yes. 9 MR. CRITTON: Form. 10 BY MR. EDWARDS: 10 THE WITNESS: I took her a few times to 11 Q. And did you ever have a conversation with 3.1 her house. 12 Louella about the fact that that's not right? 12 BY MR. EDWARDS: 13 A. We had. 13 Q. You took A. to and from her house? 14 Q. And Louella stayed there and she's 14 A. In Royai Palm Beach. 15 employed there? 15 Q. Okay. Did she say anything believe she was. 16 you about what was going on in the bedroom with 17 Q. And did she ever mention to you that she 17 Mr. Epstein? 18 thought that the situation was wrong and that she 18 A. I always try to keep the conversation to 19 was contempiating -- 19 a minimum when I was with them because deepiy reiigious -- 20 job, you know, I didn't want to talk so the 21 MR. CRITTON: Form to the last question. 21 conversation was minimal. 22 THE WITNESS: Catholic giri 22 Q. And these are giris that you?re talking 23 -- lady, and one day she came crying because 23 to that are roughiy the same age as a daughter 24 she found a picture of the Pope next to 24 that you have? 25 naked girl, both pictures, and she said it?s 25 A. Yeah. 59 (Pages 230 to 233 Kress Court Reporting, Inc. 3058664688 7115 Rue Notre Dame, Miami Beach, FL 33141 wearasme warms fat-??iibw wemesimesremwaeam antennae wetness:er earnest; mamae?m i?ii?iehtihian lath tit/35:76? Haunt-W322 awazsasmn 39:34 mm a??ima?i?f?? hi rkh?ii memes} renames: ?nit-ieaseswnumaszzuzs a. .) a: DEFENDANT BRADLEY J. EDWARDS ?5 STA TEMENT 0F UNDISP TED FACTS Epstein 12. Edwards, 9! a2. Case No. 50 .2009 CA 040800WMBAG ATTACHMENT 7 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50w2008mCA"028051 MB AB L.M., Plaintiff, VS. JEFFREY EPSTEIN, Defendant. VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN TAKEN ON BEHALF OF THE PLAINTIFF DATE: February 17, 2010 U.S. Legal Support (561) 835~0220 2 4 1 February 17, 2010 1 THEREUPON, 2 . ?03? 2 JEFFREY EPSTEIN 3 WITNESS DIRECT CROSS REDERECT RECROS 4 IEFFREY EPSTEIN 3 being by Tom Becker ?rst duly sworn to tei! 56> BY MR. EDWARDS 4 4 the whole truth, as hereinafter certi?ed, EXHIBITS 5 testi?ed as foliows: 7 FOR IDENTIFICATION PAGE 6 DIRECT EXAMINATION 8 1 one Doe number 102 versus Jeffrey 7 BY MR Epstein compiaint. 3S 8 . 9 Can you give us your name. 2 Document, Nonprosecution Agreement. 135 9 A Jeffrey Epstein. :2 18 Mr. Epstein, you made a comment when you CERTIFIED QUESTIONS 11 came in the room that you were appreciative of mo 12 12 being respectful to your housekeeper yesterday 13 Page Line 13 and I intend for that to be the same with you 6} 1 4 todaywant to start by asking you, at this 15 :14 1 6 point we've gone through a lot of discovery in 153 5 17 this case. There aren't many disputed facts as 16 159 13 18 to what actually happened at your house. 162 3 19 Generally I think you would agree that you 18 20 derived a way for young females to come to your 1 9 2 1 house and engage in varying degrees of sexuai them as old as seventeen or so, most in g: 24 between, but as of yet you haven?t provided an 25 25 exphna?on. 3 5 3. The videotaped deposition of JEFFREY 1 I want to provide you an opportunity to 2 EPSTEIN in the above-entitled and numbered cause - - . . 3 2 0 3 was taken before me, TERRI BECKER, a Registered ten the Jury at this, tune, Why yo? It 4 Professionai Reporter and Notary Public for the 3 PIKE: I $01113 to Obie?- 5 State of Florida at Large, at 444 West Railroad 4 Confusing, compound and irreievant, as 6 Avenue, in the City of West Palm Beach, Palm 5 worded 7 Beach County, in the State of Fioricla, beginning 8 at the hour of 11:15 o'clock pursuant to 6 A You know I ?(Bald like to answer that 9 the Notice in said cause for the taking of said 7 question, frankly. However, at this time, my 10 deposition which is annexed to the court tile 8 moms 5 have told that} .t a I 11 herein, on behalf or the PLAINTIFF above-emitted action pending in the above-named 6 my I an Fourteth Amen mam 13 com, 3.0 rights or I risk losing their counsel. 14 The appearances at 83?} ?me and Place 1 1 Accordingly, I therefore assert those rights. 15 were as foliows: 2 16 FARMER, more, WEISSING, 0W EDWARDS, FISTOS LEHRMAN, PL. 13 MR. PIKE: In addition to that i'll move 17 Attorneys for Plaintiff . 1 4 to strike counsel's statement as a 425 North Andrews Avenue, Suite 2 1 t. 18 Fort Lauderdaie, Florida 33301 ?aria we? as We - Tel; (954) 524-2320 16 MR. EDWARDS: I understand. wanted to 19 BY: BRADLEY 1- EDWARDS 1? provide him an opportunity, if today was l8 . 20 gomg to be the day. BURMAN, CRITTON, LUTTIER COLEMAN 1 9 MR. PIKE: Same thing. move to strike. 2 1 Attorneys for Dafendant . 2 Mr. Epstein, how long have you been 21 xa? . 19 22 West Palm Beach, Florida 33401 Se a me we 9?ng minor ema es? Tet: (561) 842-2820 22 MR. PIKE: Objection, harassmg, 2?3 BY: MICHAEL PIKE, ESQ 23 argumentative. 24 . . 9 JOE ROVNER, Videographer 2 4 A Are 3?0? k?ddmg' . 2 (Pages 2 to 5) U.S. Legal Support (561) 835-0220 6 8 1 divulging any secrets here, right? 3. argumentative, compound, harassing and 2 MR. PIKE: Move to strike. 2 irrelevant. 3 That?s the question that?s pending. 3 You can answer. 4 A I would like to answer that question as 4 A I would like to answer, however, I?m 5 well, as all your other questions today, however, 5 going to have to assert my Fifth Amendment, Sixth 6 have to follow my attorneys? advice. They have 6 Amendment, Fourteenth Amendment right as advisec told me I must invoke my Filth, Sixth and 7 by my counsel, otherwise i risk losing their 8 Fourteenth Amendment right to not answer those 8 advice. 9 questions today, or any questions relevant to 9 Mr. Epstein, have you ever been 10 this lawsuit, so accordingly, I?m going to assert 10 diagnosed with a sex addiction to minors by a 1 1 those rights and under the constitution 11 or other medical professional? 1 2 guaranteed by the Fifth and Sixth, and Fourteenth 12 A I intend to respond to all of your 1 3 amendment. 1 3 questions at some relevant time; however, today 14 Would you consider yourself addicted to 14 at the present time, my attorneys have counseled 5 sex with minor females? 1 5 me that i cannot provide answers to any questions 1 6 MR, PIKE: Same objections, 6 relevant to this lawsuit and i must accept their 17 A You know, Mr. Edwards, again, I want to 1? advice or risk losing my Sixth Amendment rights 1 8 be very respectful. As the current U.S. Attorney 18 to effective representation. 19 has described your law firm as a criminal 1 9 Accordingly, I assert my Fifth, 2 enterprise and part of one of the largest frauds 2 0 Federal Fifth and Sixth and Fourteenth 2 1 in Florida?s history, it has been reported that 2 3. Amendment rights, to the United States 2 2 your firm has fabricated multiple cases against 2 2 Constitution. 23 me in order to fleece unsuspecting investors out 23 MR. PIKE: In addition to that. Mr. 24 of millions and millions of dollars, so 24 Edwards, as the Court has ruled on several 2 5 unfortunately at this time, although I would like 2 5 matters, Mr. Epstein?s medical history is 7 9 It to answer that question, on advice of counsel 1 1 not relevant at this time nor has he placed 2 will haVe to refrain and assert my lfth, Sixth 2 same at issue in this case. 3 and Fourteenth Amendment right. 3 MR. EDWARDS: Understood. 4 Can you then provide an explanation for 4 Mr. Epstein, were you sexually abused as 5 what relevance that soliloquy of yours has to, 5 a minor? 6 whether or not you engaged in sex acts with L.M. 6 A Again? 7 When she was a minor? 7 Were you sexually abused, as a minor? 8 MR. PIKE: Objection, no, he cannot. 8 A You know, again, I would like to respond 9 Argumentative. Compound, harassing. 9 to all -- if any questions seem to be relevant. 10 MR. EDWARDS: Mr. Pike, with all due 10 i would like to respond to any relevant question 3.1 respect, it was not my idea for him to give 11 at this time; however, my attorneys have 12 this speech about a former RRA law ?rm i 12 counseled me that i cannot provide answers to the 13 was asking to elaborate on that. 3 questions relevant to this lawsuit today. I must 1 4 MR. PIKE: Counsel, l'rn working with 1 4 accept their advice or risk losing my Sixth 15 ymrmumvupmm?mn 15 3.6 MR. EDWARDS: i understand. 16 Accordingly then, assert my Fifth, Sixth and 17 MR. PIKE: l?m objecting, object to the 1 7 Fourteenth Amendment right to the United States 18 form and stating the reasons on the record 18 Constitution. 19 why the form is required to be objected to, 19 Isn't it true that you have engaged in 20 based upon your question. 20 some sexual interaction with hundreds of underag 21 MR. EDWARDS: Will he elaborate on the 2 1 minor females in the last ten years of your 22 relevance of that soliloquy to his touching 22 life? Is that true? 23 L.M. when she was 13, 14 and 15 years old in 23 MR. PIKE: Objection, relevance. 2 4 a sexual manner? 24 A Mr. Edwards, the current US. Attorney 2 5 MR. PIKE: I?m going to object again, 2 5 has described your law ?rm as a criminal 3 (Pages 6 to 9) U.S. Legal Support (561) 835-0220 1 0 1 2 1 enterprise and part of the largest fraud in 50 years old? 2 Florida?s history. It has been reported that 2 MR. PIKE: I?m going to object once 3 your ?rm fabricated multipie cases, many, many 3 again. We are getting way too argumentative 4 multiple cases against me in order to fieece 4 with the questioning. The questioning is 5 5 6 millions of. dollars. Unfortunateiy, at this time 6 harassing. Whether or not this deposition "3 in response to your question, my attorneys have 7 video, thereof is piayed in front of a jury 8 8 9 Fifth Amendment, Fourteenth Amendment right. 9 determined by ajudge pursuant to a motion 10 Though, I believe, you know, that wouid realty 10 in limine, various portions thereof may or 1 1 like to answer your questions today, but at this 1. 1 may not he played, so having piaced those 12 moment I must assert those rights or risk having 1 2 objections on the record I'm going to 1 3 my attorneys resign. 1 3 instruct Mr. Epstein not to answer that 4 You?re invoking your Fifth Amendment 1 4 question. 15 rights to each of these questions because you 15 MR. EDWARDS: Mr. Pike, 1 don't know if 1 6 know your answers will incriminate you and you 1 6 you watched the 13 hours of harassing 17 feel it wilt result in you being prosecuted for 1? questions to L.M., that she sometimes 1 8 your crimes; isn't that right? 1 8 invoked her Fifth Amendment rights, I 19 MR. PIKE: Objection, argumentative, 9 understand the adverse advice that wouid be 20 harassing. Calls fora Iegai conciusion. 2 0 given and she was made to answer these 23. You can answer. 2 1 questions and these exact same questions 22 A No, in fact, the Supreme Court 22 were asked of her, in fact, I'm using the 23 said the Fifth Amendment right is there to 2 3 phraseology from Mr. Luttier. i?m not 24 protect the innocent, so, that's the way 1 would 2 4 to harass him. 25 like to answer that. 25 I'm simply asking him to expiain to the 1 1 3 1 Are you actually tailing the jury that 1 jury. If you're saying it didn't happen, if 2 you didn't commit the crimes that have been 2 you're saying it did happen, expiain to the jury 3 alleged against you by the various females that 3 why you did it. That's all I want to hear. I'm 4 were under age when you engaged in sex with 4 being respectful about this. 5 them? Are you telling the jury that right now? 5 MR. PIKE: In an effort to keep a clean 6 MR. PIKE: ObjectiOn, argumentative, 6 record he respectfui to the to the court 7 harassing. reporter rather than having a diatribe back 8 A I would iike to respond to that 8 and forth between you and myseif, I'li move 9 question, as you know, however, at the present 9 to strike your last statement as 10 1 1 provide answers to any questions reievant to this 1 Is it true, Mr. Epstein, you were born 12 12 January20,l953? 13 losing my Sixth Amendment right to effective 13 A Yes. 1 4 representation. Aecordingiy, i assert my Fifth, 14 Where? 1 5 Sixth and Fourteenth Amendment right under the 1 5 A New York. 1 6 United States Constitution. 1 6 Where in New York? Mr. Epstein, you understand that this is 17 A Brooklyn. 18 the video that will be played to the jury in 18 Did you go to high school there? 1 9 L.M.'s trial against you and L.M. wants answers. 19 A Yes, sir. 20 The jury is going to want answers, so I know that 2 0 Where? 2 1 you're telling us that you're going to respond at 2 3. A Lafayette High School. 22 some time in the future; but the time is new. 22 After high schooi did you attend 2 3 Would you like this opportunity to explain why 2 3 college? 24 you engaged in sexual activity with LM. 24 A Yes. 25 beginning when she was 13 years old and you wer 25 Where was that? 4 (Pages 10 to 13) U.S. Legal Support (561) 835*0220 1 4 1 6 1 A New York. 1 i'll restate the answer. i would like to 2 What college did you attend? 2 reSpond, intend to respond, and would like to 3 A Cooper Union. 3 respond to all questions today. However, counsel 4 Sorry, I didn't hear. 4 has advised me i must take the Filth, Sixth and 5 A Cooper Union. 5 Fourteenth Amendment right under the US. 6 Did you get a degree from Cooper Union? 6 Constitution. 7 A No, sir. 7 After college where were you employed? 8 8 9 A I believe, two. 9 your questions today, however, on advice of 10 - What did you study? 10 counsel, I intend to take the Fifth, Sixth and 1 1 A Physics, 1 Fourteenth Amendment rights provided by the 1 2 Why did you leave college early? 1 2 United States Constitution or risk losing my A :w 14 questions regarding this lawsuit, however, at the 3.4 Isn't it true that you were a teacher at 15 present time my attorneys have counseled me that 1 5 the Dalton School in New York after college? 3.6 i cannot provide answers to questions that may he 16 A Again, 1 would like to respond to all 17 relevant to this lawsuit, so accordingly i assert your questions; however, my attorneys have 28 my constitutional rights as guaranteed by the 3. 8 counseled me that i cannot provide answers to any 1 9 Fifth, Sixth and Fourteenth Amendment. 1 9 questions today regarding to this lawsuit so i 2 0 Are you invoking your Fifth Amendment 2 0 must accept their advice or risk losing my Sixth 2 1 rights as to why you left college, is it safe 2 1 Amendment right to effective representation. 22 then to presume that that answer you believe 22 Accordingly, I assert my Constitutional rights as 23 would incriminate you in some way? 23 guaranteed by the Fifth, Sixth and Fourteenth 24 MR. PIKE: l'm going to move to strike, 24 Amendment of the constitution. 25 speculative, argumentative, harassing. 25 Mr. Epstein, did you have sex with any 15 17 1 Calls for a legal conclusion, and i know 1 underage students while teaching at the Dalton 2 exactly what you?re trying to do here, Mr. 2 School? 3 Edwards, is lace the record with questions 3 A Could you repeat that? 4 that would ultimately give you an adverse ti Yes. Did you have sex with any underage 5 inference at any potential trial of this 5 students while teaching at the Dalton School in 6 matter, so having put that on the record, 6 New York? 7 7 A Mn?megmm?mm%bwn 8 question, based upon his Fifth, Sixth and 8 described by the US. Attorney as one of the 9 Fourteenth Amendment rights to the United 9 largest as a criminal enterprise, perpetrating 10 States Constitution. 1.0 one of the largest frauds in Florida?s history. 1 1 MR. EDWARDS: With all due respect you 1 1 it has been reported that your ?rm fabricated 12 cannot invoke his ifth Amendment rights, 12 multiple cases against me and others in order to 3 your attorneys instructed me in that fact -- 1 3 fleece unsuspecting investors out of millioas and 1 4 MR. PIKE: Pie can. i. 4 millions of dollars. 15 MR. EDWARDS: That LM. Had to do it 15 Unfortunately at this time in response 16 herself, so, i would like to hear it from 16 to your question, my attorneys have advised me i Mr. Epstein. 1? must assert my Fifth Amendment, Sixth Amendment 18 Can we assume you're invoking your Fifth 18 and Fourteenth Amendment rights, though i believe 3.9 Amendment rights as to why you left college 19 you know i would like really like to answer 2 0 early, that that answer you feel would 2 0 your questions but at this time I must assert 2 incriminate you? 2 1 those rights or have my attorneys resign. 2 2 MR. PIKE: Once again, move to strike 2 2 MR. EDWARDS: Mr. Pike, i think you know 2 3 for the same reasons. 23 he has a couple of options here. He can 24 You can answer. 24 answer questions or he can invoice his Filth 2 5 A We already answered the question. 25 Amendment rights. This nonresponsive 5 (Pages 14 to 17} 0.3. Legal Support (561) 835?0220 18 20 1 verbiage regarding the RRA law ?rm is not 1 MR. PIKE: Mr. Edwards, as you know 2 one of the options, it's inappropriate in 2 there are serious Fifth, Sixth and 3 3 4 instruct your client not to obstruct this 4 at issue here, and the witness is attempting 5 process any further. i am not going to 5 to answer your questions to the best of his 6 terminate the deposition. i want it to 6 ability, despite how laced they are with "r ?nish, but Obviousiy this is going to be "i adverse inference presumptions. 8 the subject matter of some motion in the 8 MR. EDWARDS: I. don?t want the adverse 9 courts and you know the judges will not 9 inferences. I want the answers, that?s it. 10 appreciate this. i would like to just move 1 I don't want the adverse inferences. 1 1 this process aiong by eliminating that 1 1 MR. PIKE: Having said that, please 12 portion of his answer. I understand what he 1 2 aliow the witness to answer to answer the 1 3 is saying. I get it, but that?s not 1 3 question. 1 4 something responsive to any of the questions 1 4 A Can you please repeat the question? 1 5 and I think you know it is inappropriate. 1 5 Isn't it true white working at Bear 16 MR. PIKE: I think the deponent is 1 6 Stearns you were already engaging in sex with answering the questions. If you believe the 1 7 underage minor females? 18 responses are inappropriate and feet you can 1 8 A As your ?rm has been described by the 1 9 take it up with the Court with the motion 1 9 US. Attorney, as a criminal enterprise, using 2 0 you are speaking of, as you?ve done then you 2 0 some of the cases fabricated against me, 2 1 can, as you've done severai times before. 2 1 personally, I would iike to answer that question 22 After leaving the Dalton School, is it 22 today; however, upon advice of counsel 1 must 23 true that you began working as a money manager a: 2 3 assert my Fifth, Sixth and Fourteenth Amendment 24 Bear Stearns? 2 4 rights under the US. Constitution or, in fact, 2 5 A i intend to respond to your 2 5 risk losing their representation. 1 9 2 1 1 questions regarding this lawsuit at some relevant 1 At seme point in time white at Bear 2 time, however, at the present time my attorneys 2 Stearns you met and managed the money for a 3 have counseled me that I cannot provide answers 3 feilow named Lesiie Weider, correct? 4 4 5 the us. Attorney has described your law ?rm as 5 questions relevant to this lawsuit, but today I 6 a criminal enterprise, Mr. Edwards, and a part of 6 must assert my Fifth Amendment, Sixth Amendment the largest fraud in Florida?s history, 1. am "i and Fourteenth Amendment right to the 1.1.3. 8 going to assort my Sixth Amendment, Fifth 8 Constitution. 9 Amendment and Fourteenth Amendment rights to the 9 In fact, I read in another deposition of 1 0 US. Constitution. 10 yours that you do not consider yourself to be 1 1 Isn't it true that while you were 1 homosexual, correct? 12 working at Bear Stearns you were already engaging 12 A (No response.) 13 in sex with underage minors? 13 You?ve answered that question before, 1 4 A Again, i believe you know the answers to 1 4 correct? 1 5 those questions, but 1 5 A Correct. 1 6 Yes. 16 Do you consider you rseif finish? 1 7 bisexualMR. PIKE: Move to strike. Let the 19 In any event, you did develop a sexual 2 witness -- 2 0 relationship with Leslie Wexier at some point time; is that true? 22 MR. PIKE: Let the witness anSWer your 22 A No. 23 question. 23 Did you have a business relationship 24 MR. EDWARDS: I would iove for him to 24 with Mr. Wexler? 2 5 finish the questions. 2 5 A I intend to respond to all relevant 6 (9ages 18 to 21} U.S. Legal Support (561) 835*0220 22 24 1 questions. I would like to answer most of your 1 Therefore i?ii assert my Constitutionai 2 questions, Mr. Edwards, today, however, 2 rights under the Fifth, Sixth and Fourteenth 3 especialiy since your firm has been described by 3 Amendment. 4 the United States Attorney in South Florida as a 4 THE. WITNESS: Excuse me, couid we take a 5 criminai enterprise purported to -- purported to 5 break? 6 have put puiied off the largest fraud in 6 MR. EDWARDS: Already? 7 Fiorida?s history, I would like to answer it, 7 THE WITNESS: Restroom. 8 however, my attorneys here today counseied me i 8 THE. VIDEOGRAPHBR: Going off the video 9 must assert my Fifth, Sixth and Fourteenth 9 record 11:38 am. . 10 Amendment right under the US. Constitution, 10 THE. WITNESS: Thank you. 1 1 therefore I?m going to do that. 1 1 (Pause in the proceedings.) 12 Are you saying because Rothstein, 12 THE VIDEOGRAPHER: We?re back on the 3 Rosenfeld, Adier was determined to be a criminal 3 video record at 1 1:48 am. 14 enterprise or somebody was running a criminal 14 How did you meet Ghislaine MaXWeii? 15 enterprise out of that iaw firm, that is the 5 A I intend to respond to all relevant 1 6 reason why you are not going to answer these 1 6 Questions to this lawsuit; however, at the questions today? You iinked that together in 1 7" present time my attorneys have counseied me that 1 8 that answer. I just want to make sure I?m 1 8 i cannot provide answers to any questions 1 9 understanding that right? 1 9 reievant to this lawsuit, and must accept this 2 0 A I?m going to take the Fifth I intend 2 0 advice or risk iosing effective my right to 2 1 to respond to ail reievant questions today. I 2 3. effective representation. Accordingly, 22 would like to respond; unfortunately my attorneys 22 therefore, I assert my Fifth, Sixth and 2 3 have counseled me I can't, i must assert my 2 3 Fourteenth Amendment rights to the U.S. 2 4 Fifth, Sixth and Fourteenth Amendment rights 2 a Constitution. 25 under the US. Constitution. 25 You would agree, would you not, that 2 3 2 5 1 Because other law ?rms have asked very 1 Ghislaine Maxwell shares your sexual obsession 2 simiiar questions and you haven't responded to 2 for underage minor females? 3 any of theirs either. {just want to understand 3 MR. PIKE: Argumentative, speculation, 4 what the relationship between Rothstein, 4 harassing. 5 Rosenfeid, Adler is to you invoking your Fifth 5 A You knew, Mr. Edwards, the current US. 6 Amendment rights today, if you can articulate 6 Attorney has described your law ?rm as a 7 mm?wme 7 8 MR. PIKE: Form, compound, 8 the largest frauds in Florida's history. It has 9 argumentative. 9 been widely reported that your firm fabricated 1 0 A Rothstein, Rosenfeid, Adler has been 1 muitiple cases of a sexual nature against 1 1 described by the US, Attorney as a criminal 11 people other people and me, in order to fleece 12 enterprise and as part of the largest fraud in 1 2 unSUSpecting investors out of of 13 Florida?s history. It has been reported that 13 doliars, so unfortunately at this time in 14 your firm fabricated multiple cases using me, and 14 reSponse to your questions, my attorneys have 15 against me in order to fleece unsuspecting 1 5 advised me I must assert my Sixth Amendment, 16 16 17 Another long time friend of yours is though I beiieve, as you know, I would really 1 8 Ghisiaine Maxwell, right? 1 8 like to answer these questions, but at this 1 9 A I intend to respond to all relevant 9 moment, although at this time i have to assert 2 0 questions, I would like to answer most of these 2 0 those rights or risk iosing effective counsel. 2 1 questions today, but i can't because my attorneys 2 1 Do you know Annie Farmerany questions relevant to this iawsuit, I 2 3 questions regarding this lawsuit; however, at the 24 must accept their advice or risk losing my Sixth 24 present time my counsel has advised me that I 2 5 Amendment right to effective representation. 2 5 cannot provide answers to any questions reievant 3 7 (Pages 22 to 25) U.S. Legal Support (561) 835-0220 26 28 1 to this lawsuit. Your ?rm has been described as 1 present time my attorneys have counseled me that 2 a criminal enterprise, and is part of the largest 2 I cannot provide answers to any questions 3 fraud in Florida?s history fabricating sexuai 3 relevant to this lawsuit, no matter how much I 4 cases against me and others. Therefore, 4 would like to. 5 unfortunately, although I would like to answer 5 Therefore, I must accept their advice or 6 all of your questions today, l'rn going to have to 6 risk losing my Sixth Amendment right to effective 7 assert my Fifth, Sixth and Fourteenth Amendment 7 representation; therefore, I have to assert my 8 right. 8 Fifth, Sixth and Fourteenth Amendment right under 9 Did you and Ghislaine Maxwell sexuain 9 the U.S. Constitution. to assault Annie Farmer at Leslie Wexler?s house? 10 Do you own a home in New Mexico? it 1 A i intend to respond to ail reievant 1 A i intend to respond to all reievant 3.2 questions regarding this lawsuit; howeVer, at the 1 2 questions regarding this lawsuit and as We had 13 present time my attorneys have counseled me i 1 3 to do with most of your questions here today, Pin 1 4 cannot provide answers to any questions relevant 3.4 going to have to take my attorneys' advice and 15 to this lawsuit and must accept this right or 15 assert my Fifth, Sixth and Fourteenth Amendment 1 6 risk losing my Sixth Amendment rights to 6 right under the U.S. Constitution or risk losing 17 effective presentation. Accordingly, I assert my 17 effective representation. 18 Constitutional rights as guaranteed by the Filth, 18 Is it true that you have had underage 9 Sixth and Fourteenth amendments to the U.S. 9 females, at each of those homes, for orgies with 20 Constitution. 20 you and Maxwell? 21 Stating Ghislaine Maxwell and you had 21 MR. PIKE: Form, argumentative, 22 devised several schemes to lure underage girls to 22 speculation and harassing. 23 you for sex; isn't that correct? 23 A i would like to answer that question. i 24 MR. l?lKE: Form, argumentative, 24 reaily would. However, as your firm has been 25 harassing? 25 described by the U.S. Attorney as a criminal 2 7 2 9 1 A Mr. Edwards, your firm has fabricated enterprise, which its principai purpose was 2 multiple cases of sexual harassment claims and 2 racketeering conspiracy to generate money for the 3 other types of sexual cases against me and others 3 ?rm and its co-conSpiritors through the 4 in order to be part of what the U.S. Attorney has 4 operation of enterprise and through various 5 described as the largest fraud, the iargest fraud 5 activities including mail fraud, wire fraud and 6 in Florida's history. 1 would like to answer all 6 money laundering, and fabricating muitiple sex 7 your questions; however, my attorneys have 7" cases against me and others, though i wouid like 8 counseled me that at least today, I must assert 8 to answer your question today, Mr. Edwards, my 9 my Fifth, Sixth and Fourteenth Amendment rights 9 ecunsel has advised me i must take the Fifth, 0 under the U.S. Constitution. 10 Sixth and Fourteenth Amendment right provided home in Manhattan? 11 the U.S. Constitution. 12 A intend to respond to all reievant 12 Do you know somebody named Galitsea 3 questions to this lawsuit; however, at the 1 3 (phonetic)? 14 present time my attorneys have counseled me that 14 MR. PIKE: Can you spell that, for the 3.5 i cannot provide answers to any questions 15 record? 1 6 relevant to this lawsuit, and i must accept their 1 6 MR. EDWARDS: No. advice or risk losing my Sixth Amendment right to 17 MR. PIKE: Or for the court reporter? 1 8 effective representationAccordingly, therefore, i have to assert 1 9 You don't know the name? 2 my Fifth, Sixth and Fourteenth Amendment right 2 A No. Couid you spelt it? 2 1 under the U.S. Constitution. 2 1 (Witness shrugs.) 22 Do you own an island in the U.S. Virgin 22 A Okay. 23 islands? 23 Did your sexual obsession with underage 2 4 A i intend to respond to all relevant 2 4 minor females grow at some point in time to 25 questions regarding this lawsuit; however, at the 25 you access to these underage minors every single 8 (Pages 26 to 29) U.S. Legal Support (561) 835-0220 30 32 1 day for sex? 1 would like to answer those questions, though at 2 MR. PIKE: Overbroad. Speculation, 2 this moment I must assert those rights or risk 3 argumentative, compound, harassing and 3 losing my attorneys. 4 4 5 to break it down, Mr. Edwards? 5 A Okay. 6 Isn't it true that for the past ten 6 Let?s taik about Jane Doe 102, Jane Doe years you have found a way to engage in sexual 7? 102, V.R., who was represented by Bob 8 conduct with underage minors on an every day 8 Josephberg's ?rm, had nothing to do with 9 basis? 9 Rothstein, Rosenfeld, Adler. Do you know 10 MR. PIKE: Specuiation. Argumentative. 10 A Who? 1 A As your firm has been described part of the scheme to defraud people in 3 Common spellin- iike the 1 4 South Florida of miliions of dollars, you have 1 4 State - 15 15 1 6 peopie like me and others. Unfortunately at this 6 I 17 time aithough i would like to answer your 1? A What?s the last name, how is it 18 questions, Mr. Edwards, my counsei has advised me 1 8 spelled? 9 I cannot. They have advised me I must assert my 1 9 beiieve. 20 Fifth, Sixth and Fourteenth Amendment rights 2 0 A I intend to respond to relevant 2 1 under the US. Constitution. 2 1 questions regarding this iawsuit; however, at the 22 Isn't it true that you have promised 22 present time my attorneys have counseied me that 23 underage minors money or other bene?ts to engage 23 I cannot provide answers to any questions that 2 4 in sexual conduct with you over the past ten 2 4 may be reievant to this lawsuit and I must accept 26 years? .2 5 this advice or risk losing my Sixth Amendment 31 33 1 A Again, as We answered many of your 1 right to effective representation. Accordingly, 2 questions today, and unfortunately wili probably 2 i assert my Constitutional rights as guaranteed 3 end up not answering most of your questions 3 by the Fifth, Sixth and Fourteenth Amendment to 4 today, as your firm has been described, the ?rm 4 the Constitution. 5 bringing this lawsuit, i believe, if Fm wrong 5 Just for the record, I can oniy spell it 6 please, correct me -- 6 the way it was spelled in your ?ight iogs from 7 You're wrong. 7 your airplane. I don't know exactly how site 8 A This is the ?rm that didn't notice this 8 spoils her name, only how your pilot would spelt 9 deposition? 9 her name. 10 Did not? 10 MR. PIKE: Perm, speculating. 1 1 A Did not? 1 1 if I misspeil it 12 No. 12 MR. Form, Speculation, 13 A i apoiogize. Though your former ?rm 13 argumentative, harassing. 14 has been described, and the person you represent, 14 MR. EDWARDS: That's harassing? 15 15 16 that was described by the US. Attorney as 16 not in evidence in this particular 1 7 perpetratng one of the largest hands in South 1 "l deposition; therefore, I move to strike. 1 8 Fiorida?s history, fabricating multiple sexual 8 MR. EDWARDS: I was responding to his 1 9 cases against me and others in order to fleece 1 9 question asking me how to spoil her name. I 2 0 unsuspecting investors out of miilions and 2 0 don?t know how other than his own pilot. 2 1 millions of dollars, so though unfortunately, I 2 1 MR. PIKE: Mr. Edwards, he asked you to 2 2 would iike to aHSWer each one of your questions 2 2 spell the name, you then spelled the name, 2 3 today, my counsel has advised me I must assert my 2 3 then went on with another narrative and 2 4 Sixth Amendment, Fourteenth Amendment and Fifth 2 4 there wasn't a question posed, on the floor. 2 5 Amendment right, though I believe you know, I 2 5 You wouid agree you interacted with V.R 9 (Pages 30 to 33) U.S. Legal Suppoxt (561) 835?0220 3 4 3 6 1 every day in a sexual way, when she was 15 years 1 for a second? 2 old, right? 2 May asic you a question? 3 A Again, I'm sorry? 3 MR. PIKE: Sure. Can we take a break 4 Sure. You would agree that you 4 for a second? 5 interacted with V.R. sexually on an every day 5 MR. EDWARDS: Again? 6 basis when she was 15 years old? 6 THE WITNESS: Just a question. 7 A You know, again, Mr. Edwards, i would 7 MR. PIKE: He wants to speak with me for 8 like to answer all your questions here today. My 8 a second. 9 attorneys have asked me -- advised me that I must 9 THE Off the video record 3.0 assert my Sixth Amendment, Fourteenth Amendment 10 12:01 pm. 1 1 and Fifth Amendment rights provided by the US. 1 (Pause in the proceedings.) 12 Constitution and the fact that the current us. 12 THE VIDEOGRAPHER: We are back on the 13 Attorney has described your law ?rm as a 3 video record at 12:02 pm. 14 criminal enterprise, is one of the largest frauds 14 is it true, Mr. Epstein, that you and 3.5 in Florida?s history for fabricating sexual 15 Ghislaine Maxwell forced V.R. to have sex with 1 6 cases of a sexual nature against me and others. 1 6 you on a daily basis? Unfortunately, although I would like to answer 1? MR. PIKE: Form, argumentative, 8 those questions, if I do risk losing my 1 8 harassing. 1 9 attorneys counsel. Therefore, must assert my 1 9 A Unfortunately at this time, though 2 0 right. 2 0 would really like to answer those questions, and 2 1 MR. EDWARDS: Madam court reporter, FM 2 ll. like have done for most of your questions here 22 attach as an exhibit, the Jane Doe number 22 today, Mr. Edwards, your firm was described as a 2 3 NR versus Jeffrey Epstein complaint, at 2 3 criminal enterprise, a serious criminal 2 4 some point in time. It will he Exhibit 1, 2 4 enterprise by the current US. Attorney. Part of 2 5 as l?m going to go through some of the facts 2 5 that criminal enterprise was fabricating cases of 3 5 37 as alleged in the complaint and as will be 1 a sexual nature against me and others in order to 2 testified to by the plaintiff. 2 fleece unsuspecting investors out of millions of 3 (Jane Doe number 102 versus Jeffrey 3 dollars. Though, unfortunately at this time no 4 Epstein complaint was deemed marked as 4 matter how i would like to respond to your 5 Exhibit number I for identi?cation, as of 5 questions, I must assert my Sixth Amendment, 6 this date.) 6 Filth Amendment and Fourteenth Amendment rights 7 MR. PIKE: Counsel, do you have an extra 7 under the U.S. Constitution or risk having my 8 copy of that for me? 8 attorneys resign. 9 MR. EDWARDS: No. 9 Isn't it true that V.R. was yours and 1 0 MR. PIKE: May look at it real quick? 10 Chisiaine Maxwell?s sex slave from the time she 1 MR. EDWARDS: No. it has my notes on 1 1 was is through the time she escaped when she was 12 it 12 19? 13 MR. PIKE: I understood, 1 saw the 13 MR. PIKE: Again objection, 1 4 highlights. 1 4 argumentative, harassing. 18 A 1 6 so when we copy it, it will not show up. 1 6 described as -- excuse me, as a criminal MR. PIKE: lust for the record, that's a 17 enterprise by the current US. Attorney and part 1 8 current, operative pleading, correct? 1 8 of the largest fraud in Florida's history. l?art 9 MR. EDWARDS: Correct. 1 9 of that fraud was fabricating multiple cases 2 0 THE What does that mean? 2 0 against people like me and others, of a sexual 2 ll. MR. PIKE: There may have been some 2 3. nature, in order to fleece unsuspecting investors 2 2 amendments to a complaint and I want to make 2 2 out of millions and millions of dollars, so 2 3 sure that?s the operative complaint at issue 2 3 though i wouid like to answer that question, my 2 4 that he is speaking of today. 2 4 attorneys have told me today I must assert my 2 5 THE WITNESS: Can i go off the record 2 5 Sixth Amendment, Fourteenth Amendment and Fifti 10 (Pages 34 to 37) U.S. Legal Support (561) 38 40 1 Amendment right. 1 the complaint filed by V.R. against you, isn't it 2 Isn't it true that you and Ghislaine 2 true, sir, that a friend of you rs sent you three, 3 Maxwell celebrated her 16th birthday with her and 3 12-year old females for you to sexually abuse on 4 hadsexv??iheronthatday? 4 5 MR. PIKE: Form. Compound, confusing, 5 MR. PIKE: Form, argumentative, 6 argumentative, harassing. 6 harassing, and irrelevant to this lawsuit. 7 A Mr. Edwards, 1 would like to answer that 7' THE WITNESS: Excuse me. 8 question. My attorneys have told me today, I 8 A You?re saying it is part of the 9 have to at least today assert my Fifth Amendment, 9 lawsuit? 10 Sixth Amendment and Fourteenth Amendment rights 1 0 Yes, I'll read it. 1 1 to the US. Constitution, especially my concern 1 1 "On one of the defendant Epsteln?s 12 is, that your firm has filed fraudulent lawsuits, 1 2 birthdays, a friend of defendant Epstein sent him 13 fabricated lawsuits, and the US. Attorney, the 13 three, 12-year old girls from France who spoke nt 1 4 current US. Attorney has described your firm as 4 English for defendant to sexually exploit and 5 a criminal enterprise the whose main purpose 15 abuse? After doing so they were sent back to 6 was to generate money for the tirm and its 1 6 France the next day." 17 co-conspirators through the operation of various isn't that true? 18 criminal activities, including mail fraud, wire 2.8 MR. PIKE: Once again, move to strike, 1 9 fraud and money laundering. 9 irrelevant, argumentative, harassing, and 20 Are you saying that the complaint of 20 for the record, the exhibit that's being 2 1 L.M. against you, the allegation in that 2 1 read from is a complaint that's unrelated to 22 complaint, are false? 22 the instant matter and not filed or 2 3 MR. PIKE: Form. Misinterprets the 23 incorporated by the current plaintiff, L.M., 2 4 witness's testimony. 2 4 in this matter. 25 Or saying it is true? 25 A i would like to answer that question, I 39 41 1 MR. PIKE: Same objection. 3. really would; however, today my attorneys have 2 It is either true or false? 2 told me i have to assert my Fifth Amendment, 3' A l'll repeat myself, unfortunately, but 3 Sixth Amendment and Fourteenth Amendment right: 4 the current US. Attorney has described your law 4 of the US Constitution, especially because your 5 firm that tiled that filed L.M.'s claim was 5 firm involved in this lawsuit has fabricated, 6 involved in the ?ling of L.M.'s claim, 6 widely reported, multiple cases of sexual 7' motions I?m sorry, do you want to tell me what 7 harassment cases against individuals like me and 8 it was then? Would you like to tell me the 8 others, perpetrating what the US. Attorney 9 ?rm's involvement in this lawsuit, since we will 9 called One of the largest frauds in Florida's 10 be here the rest of the day? 1 0 history, ?eecing people out of millions of 1 Answer the question. 1 1 dollars, so though i would like to answer that 12 A All right. 12 question, today i have to assert those rights Or 13 The US. Attorney has described that 13 risk losing my attorneys? counsel. 1 4 firm as a criminal enterprise perpetrating one of 4 Isn't it true that you forced V.R. as a 15 the largest frauds in Florida's history against 15 {5-year old girl to have sex with numerous 1 6 unsuSpecting investors, ?eecing them out of 1 6 friends of yours? millions of dollars by creating, crafting and 17 A Are you kidding? 18 fabricating fellacious (sic) sexual claims 18 Reading from a lawsuit. 19 against people like me and others, so 19 A Sorry, Mr. Edwards. Though i would like 2 0 unfortunately, though I would like to answer your 20 to answer that question as Well, as I've answered 2 1 questions, Mr. Edwards, my counsel has advised me 2 1 most of your other questions here today, I would 2 2 that at least today I must assert my Sixth 22 like to respond; however, my attorneys here today 2 3 Amendment, ifth Amendment and Fourteenth 2 3 have advised me I have to assert my Fifth 2 4 Amendment rights under the US. Constitution. 2 4 Amendment, Sixth Amendment and Fourteenth 25 Isn?t it true, sir, and I'm reading from 25 Amendment rights under the US. Constitution, 11 (Pages 38 to 41) U.S. Legal Support (561) 835?0220 42 44 1 especially as your ?rm has been accused by the 1 spell his name? Are you acting like you don?t 2 US. Attorney as being a criminal enterprise, and 2 know him? 3 3 it Basically -- sorry, if i didn?t read correctly, 4 argumentative and irrelevant as worded. 5 the Operation of the enterprise through 5 Mr. Edwards, you know that there are 6 various criminal activities including mail fraud, 6 various standing orders, if not in this "i wire fraud and money laundering, fabricating 7 case, in various other cases, that 8 sexual harassment cases against people like me 8 specifically describe the protections of the 9 and others. 9 Fi?h Amendment. Federal Courts have 10 By the way -- 1 ordered that certain questions that you are 11 A Yes, sir? asking shall not be answered or Mr. Epstein 12 didn't V.R. receive a round trip 12 would risk losing his Fifth Amendment 13 ticket paid for by you to Thailand, and she 1 3 right 14 ultimately did not get back on the plane but 1 4 MR. EDWARDS: I. understand that. He is 15 instead escaped to Australia? 1 asking to spell people?s names. 1 6 A I would like to answer that question, 1 6 MR. FIKE: -- under the United States 17 but today i would have to assert my Sixth Constitution. A lot of these questions here 18 Amendment rights, my Fifth Amendment rights and 1 8 today that you're asking have already been 19 my Fourteenth Amendment rights under the US. 1. 9 ruled on by various Courts, that the Filth 2 0 Constitution, especially since your ?rm has been 2 0 Amendment protects any response thereto, so 2 1 described as perpetuating one of the largest 2 1 {would like l?m giving you some leeway 2 2 frauds in Florida's history, ?eecing investors 2 2 here with regard to the argumentative 23 out of millions of dollars, being described by 2 3 questions. We've already and i'm not 2 4 the US. Attorney ofSouth Florida, as a criminal 2 4 obviously testifying for the witness, but 2 5 enterprise engaged in various criminal activities 2 5 we've already handled a lot of these issues 43 45 1 including mail fraud, wire fraud and money. 1 in court and we have already adjourned one 2 laundering. 2 deposition for being argumentative, and 3 Do you know a man named Jean Lac 3 think you understand what the Court said 4 Brunel? a there, so having said that, and i understand 5 A Can you spell it? 5 that you have ajob to do, but having said 6 He was at your house last week, does 6 that, I would like to caution you 7 that remind you? professionally, if you continue with the 8 MR. PIKE: Form, move to strike, 8 argumentative questions, 1 am going to have 9 speculation, argumentative, harassing. 9 to terminate this deposition 1 0 Is there a question on the table, Mr. 10 MR. EDWARDS: I completely understand. 1 1 Edwards? 1 1 MR. PIKE: Okay. We are here today 12 MR. EDWARDS: Yes. 12 to 13 Do you know him? 13 MR. EDWARDS: Mr. Brunei 1 4 A Can you spell his name for me, please? 1 4 MR. PIKE: i want the Court to know we 15 i don?t need to spell his name. Do you 15 are here today to allow you to ask your 1 6 know who I'm talking about, Mr. Brunel? 16 questions, but the harassing and 1? 17 fl 8 B-r~u~n~e~l. 1 8 tolerated. 1 9 A i would like to answer that question as 1 9 MR. EDWARDS: We have a video. We can 2 0 well, but my attorneys have counseled me today i 2 0 Show the Court the tone. it is obviously 2 have to assert my Sixth Amendment rights, Fifth 2 1 not harassing. 2 2 Amendment rights and Fourteenth Amendment rights 2 2 MR. PIKE: That's ?ne. 23 under the (1.8. Constitution or risk losing my 23 Mr. Brunei is a long-term friend of 2 4 right to effective representation. 2 4 yours, right? 2 5 What?s the purpose for you asking me to 2 5 A I intend to respond to all relevant 12 (Pages 42 to 45) U.S. Legal Support (561) 835-0220 4 6 4 8 1 questions of this lawsuit; however, today my 1 that i cannot provide answers to any questions 2 attorneys have counseled me I cannot provide 2 relevant to this lawsuit and I must accept their 3 answers to any questions that may be relevant to 3 advice or risk losing my Fifth, Sixth and A this lawsuit and i must accept their advice or 4 Fourteenth Amendment rights under the U.S. 5 risk losing my Sixth Amendment right to effective 5 Constitution. 6 representation. 6 When you were being criminally 7 You know him as somebody who has been 7 investigated and V.R. was in Australia, is it 8 caught engaging in sex with underage minors in 8 true that you made a personal telephone call to 9 the past; is that correct? 9 her telling her not to come forward with any of 10 MR. PIKE: Form. 10 the information she knew? 1 A You will have to repeat the question, 1 1 MR. PIKE: Form. 12 Pm sorry. 12 A Again? 13 You know Mr. Brunei as somebody who has 13 Putting a time frame on it, the time 1 4 been caught engaging in sex with minors in the 1 4 frame where you were being criminally 1 5 past; is that correct? 1 5 investigated 16 MR. PIKE: Form. 16 A What time frame is that? A I intend to respond to all relevant 17 in her complaint it is not specific, 18 questions regarding this lawsuit; however, at the 3.8 but, let's just make it whenever. At some point 19 present time my attorneys have counseled me that 19 in time did you place a telephone call to V.R. in 20 i. cannot provide answers to any questions 20 Australia warning her not to come forward with 2 1 relevant to this lawsuit, and I must accept their 2 1 any information about you engaging in sex with 22 advice or risk losing my Sixth Amendment right to 22 her while she was a minor? 2 3 effective representation as your ?rm has been 2 3 MR. Form. 24 described by the U.S. Attorney as a criminal 24 A I intend to respond to all relevant 2 5 enterprise and part of one of the largest frauds 25 questions regarding this lawsuit; howeverFiorida?s history speci?cally said you have 1 present time my attorneys have counseled me that 2 been fabricating the law firm has been 2 cannot provide answers to any questions 3 fabricating multiple cases of a sexual nature in 3 relevant to this lawsuit and i must accept their 4 order to ?eece unsuspecting investors out of 4 advice or risk losing my Sixth Amendment right to 5 millions of dollars, including mail fraud, wire 5 effective representation. 6 fraud and money laundering, so unfortunately, 6 With respect to underage females, isn't 7? though i would like to answer all your questions 7 it true that you have made the statement, in 8 here today, i must assert my Sixth Amendment, 8 quotes, "the younger the better"? 9 Fourteenth Amendment and Fifth Amendment right. 9 MR. PIKE: Form. 10 You were involved in a modeling business 10 A Again, as your firm has been described 1 3. with him called M.C. Squared; is that correct? it by the current U.S. Attorney as a criminal 12 A Again? 12 enterprise involved in mail fraud, wire fraud, 13 You were involved in a modeling agency 13 money laundering, and speci?cally crafting, 14 with 14 fabricating multiple cases of sexual of a 1 5 A What do you mean 1 5 sexual nature against people like me, and others, 1 6 with Mr. Brunei called M.C. Squared? 16 in order to ?eece many, many unsuspecting 1 "f A "Involved" means what, what do you 1 7 investors out of millions of dollars; I would 1 8 mean? 1 8 like to answer your questions here today, Mr. 1 9 You tell the jury your involvement with 9 Edwards, but unfortunately, my attorneys have 20 the modeling agency. You can clarify for me, 20 counseled me that 1 must assert my Filth, Sixth 2 3. I'll let you do that. 2 3. and Fourteenth Amendment right or they will 22 MR. PIKE: Object to the form. 22 resign. 23 A I intend to respond to all relevant 23 Who are your current empioyees? 24 questions regarding this lawsuit. However, at .24 MR. PIKE: Form. 2 5 the present time my attorneys have counseled me 2 5 A Say that again. 13 (Pages 46 to 49) U.S. Legal Support (561) 835-0220 50 52 1 Who are your current employees, people 1 responding to one of your questions and you 2 who work for you, that you pay? 2 know that, Mr. Edwards. 3 3 maenwmunwmnemumnaa 4 questions regarding this lawsuit; however, at the 4 MR. PIKE: Nonetheless you know the 5 present time my attorneys have counseled me that 5 rules. Nonetheless. if we have a question 6 i cannot provide answers to any questions that 6 on the tabie, wetzid you pleaSe repeat it so 7 may be relevant to this lawsuit, or risk losing 7 i can recall it and Mr. Epstein can endeavor 8 my Sixth Amendment right to effective 8 to answer it. 9 representation. Accordingly, therefore, I must 9 MR. EDWARDS: Sure, and if it was only 1 0 assert my Sixth Amendment, Sixth Amendment and 1 0 the court reporter, wouid agree, but the 1 1 Fourteenth Amendment rights as provided by the 1 1 jury is going to see a video and everybody 1 2 US. Constitution. 1 2 knows commonly, if somebody shakes their 13 Isn't it true you pay your employees to 3.3 head, they are saying and if that was 1 4 bring you underage minor females for sex? 1 4 the answer, i wanted to give him a chance to 15 MR. PIKE: Form, argumentative, 15 eiaborate on it, that's it. 1 6 specuiation, harassing. 1 6 Isn't it true that when underage females 1? A Mr. Edwards, your ?rm has been 17 would come to your house, you would engage in 18 described the current Attorney as a criminal 18 sexual activity with them and then pay them? 1 9 enterprise, a criminal enterprise, part of the 9 MR. PIKE: Same objections. 20 20 A 2 3. part of that fraud was fabricating, urn, 2 1 that question today, but my attorneys have 2 2 fictitious cases against me excuse me, against 2 2 counseled me that I must assert my Sixth 2 3 people like me, of a sexual nature, in order to 2 3 Amendment right, my Fifth Amendment right and my 2 4 fleece unsuSpecting investors out of millions of 2 4 Fourteenth Amendment right under the .S. 25 do?wsUnfortunately at this time, though, I 1 The fact that your ?rm has been 2 would like to answer every one of your 2 described as a criminal enterprise and part of 3 questions. My attorney has advised me I must 3 one of the largest frauds in Fiorida?s -- South 4 assert my Sixth Amendment, Fourteenth Amendment 4 Florida?s history, part of that fraud has been 5 and Fifth Amendment rights or risk losing them as 5 described as fabricating cases of sexual nature 6 my attorneys. 6 against me and others in order to ?eece 7? Isn't it true when underage females were 7 unsuspecting investors out of of 8 brought to you, you would engage in sex with them 8 dollars. 1 would like to answer that question, 9 and pay them? 9 Mr. Edwards; however, today, i must assert my 1 0 MR. PIKE: Form, argumentative, 1 0 Fifth, Sixth and Fourteenth Amendment right. 11 harassing. 11 In addition to paying these underage 12 A (Witness shakes head.) 12 females for sexual activity, you also paid them 13 Are you shaking your head to say "no" 13 to bring their underage friends to you, to also 14 A Excuse me. 14 engage in sexual activity with them? 15 Are you shaking your head to say "no, i 15 MR. PIKE: Form. 1 6 don't know how to interpret that answer?" 1 6 Is that correct? 17 17 A 18 MR. EDWARDS: i thought he was actually 18 questions regarding this iawsuit; however, at the 19 answering a question. 1 9 present time my attorneys have counseled me that 20 MR. PIKE: We?ll just strike. The rules 20 i may not, and i must assert they have advised 2 are wed?known to every lawyer who practices 2 1 me I must assert my Sixth Amendment right, my 22 22 2 3 that a nod of the head or shake of the head 2 3 rights under the US. Constitution. 24 is not understood by the record, so 24 You would pay underage females 280 to 25 therefore Mr. Epstein was clearly not 25 $308 for engaging in sexual activity with you or 14 (Pages 50 to 53) 0.3. Legal Support (561) 835~0220 54 56 1 for procuring another underage female to engage 1 Attorney, and as part of the largest fraud in 2 in sexuai activity with you; is that correct? 2 South Florida?s history, and as part of the fraud 3 MR. PIKE: Form, move to strike. 3 fabricating maiicious cases of sexuai harassment 4 Assumes facts not in evidence and calls for 4 and other cases of sexual nature against people 5 a legal conciusion as well, argumentative. 5 me and others, aithough i would iike to 6 6 7 questions regarding this lawsuit; however, at the 7' advised me I must assert my Sixth Amendment, '8 present time my attorneys have counseled me that 8 Fourteenth Amendment and Fifth Amendment rights 9 i cannot provide answers to any questions that 9 of the US. Constitution. Although i believe you 1 0 may be relevant to this lawsuit, and I must 1 0 know I would really iike to answer your 1 1 accept their advice or risk losing my Sixth 1 1 questions, but at this moment if I don't assert 12 Amendment right to effective representation. 12 those rights, I risk having my attorneys resign. 1 3 Accordingiy, therefore, I must assert my 1 3 isn't it true with this method you were 1 4 constitutional rights as guaranteed by the Fifth, 4 able to interact sexually with underage girls 153 Sixth and Fourteenth Amendment to the U.S. 15 every singie day? 16 (hmMan 16 Wouid you agree that your scheme was Same objections. 18 devised to coerce theSe underage minors to bring 28 Go ahead. 19 you as many other underage minors, as were 19 A Oh, i'm sorry. Can you repeat it? 20 available for you to engage in sexual activity 20 Sure. With this method of 2 with? 2 A "This method" being what, sorry? 22 MR. PIKE: Form. 22 Your method of using underage minors to 23 A Can you repeat the question? 23 bring you other underage minors for sex; isn't it 24 Yes. Would you agree that your scheme 24 true that that method resuited in you engaging in 25 was devised to coerce underage giris into 25 sexuai activity with underage minors on an eVery 55 5? bringing as many other underage girls to you, as 1 day basis? 2 were available for some! purposes? 2 MR. PIKE: Same objections. 3 MR. PIKE: Form. 3 A Your ?rm has been described by the 4 A 4 5 Yes, for sexuai purposes. 5 engaged in one of the largest frauds in South 6 A i?m not surprised. Since your ?rm was 6 Florida?s history, and as part of that fraud, 7 described as perpetrating one of the iargest 7 creating, fabricating, maiicious cases of sexuai 8 frauds in Florida?s history by crafting, 8 nature against peopie like me and others, so 9 fabricated sexual harassment cases against peopie 9 unfortunateiy, though 1' would like to answer that 10 like me and others in order to fleece 10 question today, i must assert my Sixth Amendment, 1 unsuspecting investors out of miilions of 1 1 Fourteenth Amendment and Fifth Amendment rights 12 dollars, 1 would like to answer that question. 3.2 to my counsel's advisement to do, although i .13 However, today my attomeys have advised me I 3.3 believe you know i would reaiiy like to answer 14 must assort my Sixth Amendment, Fifth Amendment 14 those questions today, i must assert those rights 15 and Fourteenth Amendment right under the US. 3.5 or risk losing my attorney?s representation. 16 Constitutiou, and if i den?t do so, I risk 16 To keep track of all these underage l7 losing losing effective representation. minors, you stored their names and telephone 18 Utilizing this method of using underage 18 numbers in your home computer; isn't that 3.9 minors to bring you other underage minors, you 19 correct? 20 were abie to engage in sex with hundreds of 20 MR. PIKE: Form, argumentative, 2 underage minor femaies. Is that true? 2 1 speculation. 22 MR. PIKE: Form, argumentative, 22 A Again? Sorry. 2 3 harassing and caiis for speculation. 2 3 Are you going to answer the question or 24 A Since, Mr. Edwards, your firm has been 24 just read? If you are going to answer the 2 5 described as a criminal enterprise by the US. 2 5 question, of course, I'll keep reading it as many 15 (Pages 54 to 57) U.S. Legal Support (561) 835?0220 58 60 1 times. 1 answer each one of your questions today, Mr. 2 A Excuse me? 2 Edwards, my attorneys have advised me that i must 3 MR. PIKE: The witness is attempting to 3 assert my Sixth Amendment, Fifth Amendment and 4 answer your question. He asked you to? 4 Fourteenth Amendment rights under the US. 5 repeat the question. 5 Constitution. 80 although I would iilte to 6 MR. EDWARDS: He is? 6 answer, I must assert those rights or risk having 7 MR. PIKE: He asked you to repeat the I 7 my attorneys resign. 8 question. 8 Do you know Sarah Kellen? 9 9 A 1. 0 that, Mike, because i do want answers, but 1 0 questions regarding this lawsuit; however, at the 1 1 if i'm going to repeat the question muitiple 1 1 present time my attorneys have counseied me that 3.2 times and get the same answer, we are 12 I cannot provide answers to any questions 1 3 wasting time. I want to stop us wasting 1 3 reievant to this iawsuit and must accept their 1 4 time repeating questions if I?m getting the 14 advice or risk iosing my Sixth Amendment right to 1 5 same nonresponsive answer. 15 effective representation. 16 MR. PIKE: i understand your intention 16 isn't it true you employed Sarah Kellen here. to contact underage minor females and make them: 18 MR. EDWARDS: Yeah. 18 appointments to be at your house? 19 MR. PIKE: however, these questions 19 A Sorry, again? 20 are similar in nature, if not identical to 20 Isn't it true you em pioyed Sarah Keiien 2 3. various questions that you?ve asked in other 2 1 for the purposes of contacting underage minor 22 indications, so you coming here today is of 22 females and scheduling them appointments to be a 2 3 no surprise that Mr. Epstein is required to 2 3 your house? 24 invoke his Fifth, Sixth and Fourteenth 24 A The current US. Attorney has described 2 5 Amendment rights under the United States 25 your law ?rm, Mr. Edwards, as a criminai 59 61 1 Constitution enterprise engaged in one of the iargest frauds 2 MR. EDWARDS: i understand that. 2 in South Florida's history. it has been reported 3 MR. PIKE: if you came here today 3 that your firm fabricated muitiple cases of a 4 thinking you were going to puil a rabbit out 4 sexuai nature against me and others, in order to 5 of a habit, and Mr. Epstein was going to 5 ?eece unsuspecting investors out of and 6 waive his Fifth, Sixth and Fourteenth 6 of doilars, so, though unfortunater I 7 Amendment rights to the US. Constitution, 7 would iike to answer every one of your questions 8 at least not today. That wiil not be 8 today my attorneys have counseled me that today i 9 occurring. 9 must assert rny Sixth Amendment, Fifth Amendment 10 Isn't it true that to keep track of the 10 and Fourteenth Amendment rights under the US. 11 names and phone numbers of these underage mine 11 Constitution. Though i believe you know I would 12 females, to interact with sex uaiiy, you stored 12 like to answer those questions, although today I 3. 3 those names and phone numbers in your home 1 3 must assert those rights or risk having my 1 4 com puter? 1 4 attorneys resign. 15 A Thank you. i?ve heard the question 15 Tell the jury how you knew Nadia 16 now. it didn't surprise again, i've now heard 16 Marcinkova. 17 the question and the fact that your firm has been MR. PIKE: Form move to strike. 1 8 described as a criminal enterprise by the current 1 8 MR. EDWARDS: Move to strike my 1 9 US. Attorney in South Florida, and part of one 1 9 question? 2 0 of the largest frauds in Florida?s history, it is 2 0 MR. PIKE: (Node) 2 1 reported that your firm fabricated malicious 2 3. MR. EDWARDS: What basis? 2 2 (mos of a scxuai nature against people and 22 MR. PIKE: Do I have to state a 2 3 against me, in order to ?eece unsuspecting 2 3 basis? Usually I'm just required to state 2 4 investors out of millions of dollars. 2 4 "form." 2 5 Unfortunately, though i wouid like to 25 MR. EDWARDS: You have done more than 16 (Pages 58 to 61) 0.8. Legal Support (561) 835~0220 62 64 1 that today. 1 your firm, Mr. Edwards, as a criminal enterprise 2 2 3 explaining, you know, what's confusing, 3 laundering and, in fact, fabricating muitipie 4 compound and reievant, then you wouid blame 4 cases of a sexual nature against me, others, in 5 5 6 move to strike the question. 6 Florida out of millions and of doiiars. 7 MR. EDWARDS: Make sure you mark that 7 Unfortunately, though i would iike to 8 somewhere on this transcript, somehow. 8 answer each one of your questions here today, my 9 Tell the jury how you know Nadia 9 attomeys have advised me I must assert my Sixth 1 0 Marcinkova? 1 0 Amendment, Fourteenth Amendment and Fifth 1 1 MR. PIKE: Move to strike. 11 Amendment right under the US. Constitution, 12 A i intend to respond to all reicvant 12 although i heiieve you know I would hire to 3 questions regarding this iawsuit. However, at 1 3 answer your questions, but at this moment i must 1 4 the present time my attorneys have counseled me 1 4 assert those rights or risk having my attorneys 1 5 that I cannot provide answers to any questions 1 5 resign. 1 6 relevant to this lawsuit and must accept their 1 6 Isn't it true that with each of these 1 7? advice or risk iosing my Sixth Amendment right to underage minor females that were brought to you 18 effective representation. Accordingly, i assert 18 house, your method of sexually exploiting them 19 my Fifth Amendment, Sixth Amendment and 19 was neariy identical; is that correct? 2 Fourteenth Amendment right under the US. 2 0 MR. PIKE: Objection, argumentative, 2 1 Constitution. 2 1 confusing, overhroad and vague. 2 2 isn't it true that you brought her to 2 2 A i don't even understand the question. 2 3 this country when she was underage and made her 23 Okay. When a 14 or 15-year old would be 24 your sex stave, and you've bragged about this? 24 led into your bedroom, you would appear from th 25 MR. 91KB: Form, argumentative, 25 shower first, usuaiiy naked; is that correct? 63 65 1 cornpound, harassing and cails for 3. MR. PIKE: Objection, argumentative, 2 speculation. 2 assumes facts not in evidence, and 3 A i intend to respond to all relevant 3 harassing. 4 questions regarding this lawsuit; however, at the 4 A I intend to respond to ail relevant 5 present time my attorneys have counseled me that 5 questions regarding this iawsuit; however, today 6 I cannot provide answers to any questions 6 my attorneys have advised me that i cannot 7 reiative to this iawsuit and i must accept this '7 provide answers to any questions reievant to this 8 advice or risk iosing my Sixth Amendment right to 8 lawsuit and must accept their advice or risk 9 effective representation. However, I would like, 9 iosing my Sixth Amendment right to effective 18 so Fm ciear, the question was, did 1 bring her 1 0 representation. Accordingly, therefore, I must 11 here? Speci?cally 1 1 assert my Constitutionai rights the Fifth 12 Your answer is fine. 12 Amendment, Sixth Amendment and Fourteenth 1 3 A Okay. 3 Amendments to the US. Constitution. 14 Is it true that you demanded numerous 14 MR. Can We go off the record for 15 underage minor females to have sex with Nadia 15 a second? 1 6 Marcinkova inside your home while you watched, 1 6 MR. EDWARDS: If it is necessary. 1? masturbating? 1? MR. PIKE: Yes, let?s go off the 18 MR. PIKE: Same objections. 18 record. 19 A You have to repeat the question. 1 9 THE VIDEOGRAPHER: Going off the video 2 0 Isn't it true that you have ordered 2 0 record at 12:35 pm. 1 severe! underage minor females to have sex with 2 1 (Pause in the proceedings.) 22 Nadia Marcinkova in year home while you watched, 22 "ii-IE VIDEOGRAPHER: Back on the video 23 masturbating? 23 record 12:44 pan. 2 4 MR. PIKE: Same objections. 2 4 MR. EDWARDS: Can you teii me what my 2 5 A The current U.S. Attorney has described 2 5 last question is? 17 (eages 62 to 65) 0.8. Legal Support (561) 835?0220 66 68 1 THE COURT REPORTER: Certainly. 3. her vagina; is that correct? 2 (The record was read.) 2 MR. PIKE: Form. 3 After appearing from the shower naked, 3 A I intend to respond to all relevant 4 you would order the underage minor female to 4 questions regarding this lawsuit. Unfortunately, 5 disrobe; isn't that true? 5 today my attorneys have advised me I cannot, must 6 MR. PIKE: Same objections. Form. 6 assert my rights under the US. Constitution, 7 A I intend to respond to all relevant 7 under the Fifth Amendment and Sixth amendment and 8 questions regarding this lawsuit; however, at the 8 Fourteenth amendments of the US. Constitution, 9 present time my attorneys have counseled me I 9 eSpecially since your firm has been described as 10 cannot provide answers to any questions relevant 1 0 a criminal enterprise by the current US. 1 1 to this lawsuit and must accept their advice or 1 1 Attorney perpetuating one of the largest frauds 12 risk losing my Sixth Amendment right to effective 12 in South Florida's history, ?eecing investors 13 representation. 1 3 out of millions of dollars by fabricating 14 You would then order them to, or order 1 4 malicious cases, malicious cases of a sexual 15 her to begin providing you a massage; is that 15 nature against people like me and others. 1 6 correct? 1 6 With many of these underage minors you 17 MR. PIKE: Form. would use vibrators on them; is that correct? 18 A I intend to respond to all relevant .18 MR. PIKE: Form. 19 39 2 to answer each and every one of your questions 2 as I would like to respond to all your other 2 2 today, Mr. Edwards; however, my attorneys have 2 1 questions today. However, my attorneys have 2 2 told me that I cannot do that today unless and I 2 2 counseled me that i must assert my Sixth 2 3 must assert my Sixth Amendment, ifth Amendment 2 3 Amendment rights, my Fifth Amendment rights and 2 4 and Fourteenth Amendment rights under the US. 24 my Fourteenth Amendment rights under the US. 25 25 6? 69 1 Therefore, I?m going to assert those rights as 1 And with many of these underage minors, 2 guaranteed by the Fifth Amendment, Sixth 2 you would give and/or receive oral sex from them 3 Amendment and Fourteenth Amendment. 3 is that correct? 4 You would then rollover and continue 4 MR. PIKE: Form. 1. 5 with masturbating; is that correct? 5 A I intend to respond to all relevant 6 MR. PIKE: Form. 6 questions regarding this lawsuit, and I would 7 A i intend to respond to all relevant i like to answer each and every one of your 8 questions regarding this lawsuit. It is it is 8 questions; however, my attorneys have counseled 9 my understanding that the current US. Attorney 9 me that today I must assert my Sixth Amendment, 10 19 ll enterprise, yours and Mr. Jaffe?s ?rm, as a 3.1 under the U.S. Constitution, especially since 1 2 criminal enterprise and part of the largest fraud 12 your firm has been described by the current US. 13 in Florida?s history, fabricating malicious cases 13 Attorney as perpetrating one of the largest 1 4 of a sexual nature against me and others, in 4 frauds in Florida in Florida's history, by 15 order to fleece investors out of millions of 5 fabricating malicious cases of a sexual nature 1 6 dollars, through bogus schemes including 1 6 against me and others. 17 conspiracy to excuse me to commit mail 17 In June of 2008 you pled guilty to a 18 fraud, wire fraud and money laundering, so though 18 couple of felonies, right? 19 I would like to answer each and every one of your 19 MR. PIKE: Form, vague and confusing. 20 questions here today, my attorneys have counseled 2 0 A Again? 21 me I cannot, and must assert my Fifth, Sixth and 2 1 In true of 2008, you pied guilty to two 22 Fourteenth Amendment rights under the U.S. 2 2 is that correct? 2 3 Constitution. 2 3 MR. PIKE: Same objection. 24 You would then rub the underage minor 24 A Yes. 2 5 female?s vagina and/or insert your ?ngers into 2 5 And what were theSe felonies that you 18 (Pages 66 to 69) U.S. Legal Support (561) 835?0220 TO 72 3. pied guilty to? 1 You don't know what you pled guilty to? 2 A Solicitation of prostitutes, not 2 A i pled guilty to solicitation of 3 underage prostitutes but simply prostitutes. 3 prostitution, not underage prostitution, but 4 Solicitation of prostitutes and one count of 4 prostitution. 5 6 You have taken the Fifth as to questions 6 files that one of these i?emaies was Add. Do you 7 rotated to many of these underage minors, but the 7 know who that is? 8 underage minors that were the victims in the 8 A I intend to respond to all relevant 9 cases where you pied guilty, were is that 9 questions in this lawsuit. However, at the, 10 one of them? 1 0 present time my attorneys have counseied me that 3. 1 MR. PIKE: Form, mischaracterizes the 1 I cannot provide answers to any of these 1 2 witness's testimony. Calls for a legal 1 2 questions today. So accordingiy, I must assert 13 conclusion? 1 3 my constitutional rights under the Fifth, Sixth 1.4 A Again. 3. 4 and Fourteenth Amendments of the US. 1 5 What was the name Constitution. 1 6 underage minors that were the subject of the 1 6 You're aware A.H. is somebody that l? criminal charges to which you pled guilty? 17? alleges she was at your house on more than 100 8 A I don?t know. 1 8 occasions; is that true? 1 9 So, tell me about those charges. What 19 MR. PIKE: Form. 2 0 were the allegations of those charges? 2 A Can you repeat the question, sir? 2 1 MR. PIKE: Form. 2 1 Are you aware that AJri. is a female that 2 2 A Soiicitation of prostitution, not 2 2 alleges that when she was underage, she was at 2 3 underage Prostitution. 2 3 your house on more than 100 occasions? 24 Were the victims or the prostitutes, as 24 MR. PIKE: Form, predicate. 2 5 you wouid say, were they minors? 2 5 A i intend to respond to all relevant 71 73 1 MR. PIKE: Form. 1 questions to this ansuit, Mr. Edwards. However, 2 A i pled guilty to solicitation of 2 today my attorneys have counseled me that I must 3 prostitution. 3 respond by invoking my Fifth Amendment right, my 4 Okay, so tel! me what those cases were 4 Sixth Amendment right and my Fourteenth Amendmer 5 about VVhathappened? 5 6 MR. PIKE: Form again. 6 them as my attorneys, so therefore I must assert 7 A (Witness shrugs.) i can't tcil you 7 those rights. 8 any more than that. 8 You understand that her complaint was 9 You don't know what you pied guilty to? 9 that Epstein turned H. on to her stomach on the 10 A ljust told you 10 massage bed and inserted his penis in to her 11 MR. PEKE: Object to the form, asked and 11 vagina, H. Stated Epstein began to pump his penis 2 answered. 1 2 in her vagina and, she became upset over this. 13 Do you know what you pied guilty to, the 13 She said her head was being held against the bed 1 4 facts? 14 forcibly as he continued to pump inside of her 1 5 A Solicitation of prostitution. 15 while she screamed 1 6 i understand that that?s the charge. 16 Are you aware of those aliegations? 17 What were the underlying facts? What did you dr. MR. PIKE: Form, predicate. 18 did you puil up in a car, talk to the person, did 18 A for sorry, did you say there is a 19 they come over to your house, how did you get 19 compiaint?? 20 them, these kinds of things. Tell the jury what 20 In the incident report that led to a 2 were the underlying facts about the charges you 2 3. charging document, that led to a charge that you 22 pled guilty to? 22 have pled guilty to. Are you aware of that 2 3 MR. PIKE: Object to the form. Move to 23 information coming from 24 strike. 24 MR. PIKE: i?m sorry, Mr. Edwards; what 25 A 25 meymlma?ng?om? 19 {Pages 70 to 73} 0.8. Legal Support (561) 835?0220 7 4 7 6 1 MR. EDWARDS: The 87-page Palm Beach 3. argumentative, compound, harassing. 2 2 3 3 4 describing their interaction with Mr. 4 A All. Epstein at his house. For reading 5 The current US. Attorney, since he has 6 speci?cally from page 41 related to All, 6 described your firm as a criminal enterprise and "i who was one of the victims he pled guilty 7 part of one of the largest frauds in Florida?s 8 to. 8 history by fabricating, fabricating, malicious 9 MR. PIKE: is that the same document 9 cases ot." a sexual nature against people like me 1 0 that you?re seeking production of, in this 1 and others, and ?eecing investors out of 1 1 same exact case? 1 1 millions of dollars by using means described in 1 2 MR. EDWARDS: i don?t know what you're 12 the complaint against your firm, including mail 13 talking about. This is something from the 13 fraud, wire fraud, money laundering; I'm afraid 1 4 State Attorney's file. 1 4 today, though i would like to answer each one of 15 MR. PIKE: Okay. Sorry. What?s the 15 your questions, my attorneys have counseled me 16 manna? 16 17 Are you aware of that allegation? What Amendment, Fifth Amendment and Fourteenth 18 Ijust read to you. 18 Amendment rights under the U.S. Constitution, and 1 9 A I would like to answer that question, 3. 9 i believe you know I would like to answer those 2 0 but, however, today my attorneys have advised me 2 0 questions. I must assert those rights or risk 21 i must assert my Fifth Amendment, Sixth Amendment 2 losing my attorney's representation. 2 2 and Fourteenth Amendment rights under the U.S. 2 2 Do you know 23 Constitution. 23 A Spell it, please. 2 4 Assuming your attorneys have advised you 2 4 I don't know how to spell her name, but 25 but because of Res Judicata, double jeopardy, you 2 5 do you know a i don't know that she woulr "i 5 7 7 1 cannot be charged for any crimes that you have 1 have ever spelled her name for you. 2 already pled guilty to relating to A.H., so I 2 MR. PEKE: Form, move to strike. 3 would like you to explain to the jury, in your 3 Her name is 4 4 5 your interaction with All. at your house when sh 5 questions regarding this lawsuit. However, at 6 was a minor? 6 the present time my attorneys have counseled me 7 MR. PIKE: Object to the form as 7 that I may not provide answers today, though I 8 worded. Could disclose attorneylclient 8 would like to, and i must, in fact, take their 9 communications. 9 advice or risk losing their representation, so 11 ll IlS.Cmm?uMon 1 2 to anSWer each of your questions today, however, 1 2 Do you know the names of any of the 3 my attorneys have counseled me that i may not. 1 3 females that you allegedly solicited for 14 They've advised me that I must assert my Fifth 4 prostitution and pled guilty to? 5 Amendment, Sixth Amendment and Fourteenth 3. 5 MR. PIKE: Relevance. 1 6 Amendment rights under the US. Constitution. 16 A Sitting here today, no, I do not. 17 Therefore, if i don?t, risk losing their 17 You asked me to spell name. 18 counsel. Therefore, 1 must assert those rights 1 8 That's somebody that your attorneys took her i 9 here today, Mr. Edwards. 1 9 deposition about a year and a half ago. Does 20 Are you aware that All. Advised police 2 0 that help to refresh your recollection as to who 2 1 that she was ripped and torn in her vagina area 2 1 S.G. is? 2 2 and had dif?culty walking to the ear after this 2 2 A I would like to answer that question but 2 3 episode where you forcibly inserted your penis 2 3 today, according to my attorneys, I must assert 2 4 into her vagina? 2 4 my Filth Amendment, Sixth Amendment and 2 5 MR. PIKE: Objection, relevance, 2 5 Fourteenth Amendment rights under the U.S. 20 (Pages T4 to T7) U.S. Legal Support (561) 835*0220 78 80 1 Constitution. 1 must accept their advice or risk 1 and Fourteenth Amendment rights to the US. 2 losing my Sixth Amendment right to effective 2 Constitution or risk iosing effective 3 representation, Mr. Edwards, so though i Wouid 3 representation. Accordingly, i must assert my 4 like to answer the question, today i must assert 4 rights as guaranteed by the Constitution. 5 those rights. 5 Just so you are clear, since your 6 There is another victim, her name is 6 attorney made it an objection that it was 7 that was listed as one of the females at 7 nuclear, then you invoked your Fifth Amendmen: 8 you house and you pled guilty to the 8 rights 9 solicitation of. 9 A Sorry. 10 I would like to ask you if you remember 10 i'm talking about the cases where you 1 1 her? 1 1 already pled guilty and you can't be charged 12 MR. Form, con?tsing, compound. 12 again. What were the facts and circumstances 1 3 A All? 1 3 that led up to you pleading guilty to these 14 I. don't know her first time, initial 14 felonies? 1 5 last name is 3.5 A I?ve answered the question. 1 6 MR. Same objection. 1 6 MR. PIKE: Same objection, asked and 7 A I intend to respond to all relevant 17 answered. 1 8 questions regarding this lawsuit. However, at 18 THE VIDEOGRAPHER: Counsel. 19 the present time my attorneys have counseled me 19 (Indicating ?ve minutes left on tape.) 2 0 that I cannot provide answers to any questions 2 0 MR. EDWARDS: Okay. 21 2 2 advice or risk losing my right to effective 2 2 three females that were the subject of the guilty 2 3 representation. Therefore, though i would like 23 pleas in State Court, were procured by your 24 to answer the questions, i must assert those 24 method of having underage minor females locate 25 rights. 25 other underage minor females and bring them to ?i 9 8 1 1 With each case that results in a 3. your house; isn't that correct? 2 charge 2 MR. Objection, argumentative, 3 THE WITNESS: Excuse me, is there some 3 compound, harassing, assumes facts not MR. EDWARDS: Stopping again? 6 Okay, A.H., All, S.G. are all people 7 THE WITNESS: Can I get some water? Mr. that were, at the time you engaged in sexual 8 laffe, can you pass some water? 8 activity with them, were underage and were 9 THE VIDEOGRAPHER: There is no water 9 brought by other underage minor females; is that 10 here. 10 true? 11 THE WITNESS: Sorry. 1 1 MR. PIKE: Same objections incorporated 12 With each conviction, charge, or with 12 as wait as motion to strike. 13 each charge that leads to a conviction, there are 13 A i don't understand i?m sorry, i don't it facts and circumstances that tead up to that plea 14 understand the question. 1 5 of guilty. 1 5 Isn?t it true that you used underage 16 MR. PIKE: Form. 16 minor females to bring other underage minor 1 7 What are the facts and circumstances females to your house for sex? 18 that led to you pleading guilty to the two 3.8 MR. PIKE: Asked and answered. 1 9 felonies that you've described? 1 9 A (Witness shrugs.) 2 0 MR. PIKE: Form, overbroad, compound, 20 MR. PIKE: Way earlier on. 2 confusing, calls for a legal conclusion. 2 1 MR. EDWARDS: tie doesn't understand the 2 2 A I would iike to respond to that 22 question -- 2 3 question. i would like to respond to that 2 3 MR. PIKE: You can answer the question. 2 4 question, but today my attorneys have advised me 2 4 I?m going through the progression. 25 21 (Pages 78 to 81) U.S. Legal Support (561) 835-0220 82 84 I asked and answered. 1 1:05 pm. 2 2 3 laffe?s has been described by the US. Attorney 3 THE VIDBOGRAPHER: Back on the video 4 as perpetrating one of the largest frauds in 4 record 1:15 p.111. 5 South Florida?s history by crafting malicious 5 Mr. Epstein, as it relates to the 6 cases of a sexual nature against people like me 6 charges you pled guilty to, are you saying today 7 and others, in order to fleece, using bogus 7 that those females that you interacted with 8 schemes, in the US. Attorney's words, investment 8 sexually, were prostitutes prior to meeting you? 9 schemes. Unfortunately, though I would like to 9 A I'm guilty to the 0 answer every one of your questions if I'm able, 1 0 solicitation of prostitution. 1 my attorneys have advised me I must assert my 1 1 Right, and you would certainly agree 1 2 Sixth Amendment, Fourteenth Amendment and Fifth 12 that that would require yourself and one other 13 Amendment rights under the US. Constitution. 13 individual for that act of prostitution, 1 4 Therefore, at the moment I cannot answer that 4 correct? 15 question. 15 MR. PIKE: Form. Also calls for a legal 16 The acts related to your guilty plea 16 conclusion. occurred at your Palm Beach house; is that A pled guilty to solicitation of 8 correct? 1 8 prostitution. 9 MR. PIKE: Form. 19 Are you saying that those females that 20 A Again, sorry. 20 were the victims, at least listed as victims by 2 1 If you were soliciting prostitutes, it 23. the State, were prostitutes prior to meeting 22 22 you? 23 These were girls that you solicited to be 23 MR. PIKE: Form. Vague. Irrelevant? 24 prostitutes at your house in Palm Beach, 24 A pled guilty to solicitation of 2 5 correct? 2 5 prostitution. 83 85 1 MR. PIKE: Objection, relevance, 1 Do you have any remorse for your 2 argumentative. Calls for speculation as 2 actions -- 3 worded and assumes facts not in evidence. 3 MR. PIKE: Form. 4 A Though I would like to answer that 4 against these victims that led to 5 question, my attorneys today have advised me I 5 your plea of guilty? 6 cannot answer you today, and they?ve advised me i 6 MR. PIKE: Form, argumentative. must assert my Sixth Amendment, Fifth Amendment 7 A i pled guilty to solicitation of 8 and Fourteenth Amendment rights under the 11.3. 8 prostitution, not underage prostitution, simply, 9 Constitution. Otherwise I risk losing their 9 prostitution. 10 representation. So, accordingly I must assert 10 Are you saying now that the subjects of 11 those rights, Mr. Edwards, and Mr. .laffe. 3.1 that, which were called victims, were not 12 In what county did you plead guilty to 12 underage when you engaged in sex with them? 13 these felony offenses? 13 MR. PIKE: Form, argumentative, 14 A Palm Beach County. 14 speculation, assumes facts not in evidence, 15 These were crimes that occurred here in 15 as well as mischarac?terizes the witness's 6 Palm Beach County? 16 testimony. 17 MR. PIKE: Form. A I pled guilty to solicitation of 18 olmmuwnue 18 19 A I pled guilty in Palm Beach County. 19 solicitation of prostitution. 2 0 Isn't it true that you kept a calendar 2 I was under the impression you pied 21 or schedule 2 1 guilty to a second degree felony, that being 22 THE VIDEOGRAPHER: I have to change the 22 procuring a minor for the purposes of 2 3 tape. 2 3 prostitution. 24 MR. EDWARDS: Change it. 24 A That?s correct. 25 THE VIDEOGRAPHER: Off the video record 25 So a minor is somebody under the age of 22 (Pages 82 to 85} U.S. Legal Support (561) 835-0220 86 88 1 18, and I'm asking for the guiity pica reiated to 1 advised me i cannot and they've advised me i must 2 that count; are you at all remorsefui for your 2 assert my Sixth Amendment right, my itth 3 interactions with that minor? 3 Amendment right and my Fourteenth Amendment right 4 MR. PIKE: Same objections. 4 under the US. Constitution, therefore, that's 5 A What minor? . 5 what i?m going to do. 6 The charge is procuring a minor. You 6 Where is the calendar or schedule of 7' tell me. Who was that minor? 7 your underage sex appointments? 8 A i don?t know. 8 MR. PIKE: Form, specuiation. 9 You were never told during the State 9 A You said where 10 Attorney's prosecution of you, who this person 10 MR. PIKE: "Again." 1 1 was? 1 2 Where is the caiendar or schedule that 12 A No. 12 Sarah Keiien kept for you for your appointments 13 Why did you plead guilty to a feiony 13 for sex with underage females? 14 charge that resulted in you going to jail, 14 MR. PIKE: Same objection. 5 without even knowing who the victim was? 1 5 if there is not one, you can teii me 1 6 MR. i?lKE: Form. That question calls 1 6 there is not one. 1 7 for attorney/{cheat information, and 17 A i would to answer each one of yoUI 1 8 therefore, I'm going to instruct him not to 1 8 questions today. However, I have been advised by 9 answer that. 19 counsel that I must assert my Fifth Amendment, 2 0 If it has anything to do with any 2 0 Sixth Amendment and Fourteenth Amendment rights 2 conversations with your attorney, 1 don't want to 2 1 under the US. Constitution or risk losing their 2 2 know. i'm just going off of the plea colloquy 2 2 representation. Therefore, I?m going to have to 2 3 between you and the Judge, where you understood 2 3 assert-those constitutional rights, though I 24 the charges and hayelbeen advised and apprised of 24 would iike to answer that question. 25 the charges and you wiliingiy, willfully 25 Are you still in possession of the 87 89 1 pied guilty to the charges. i'm taking new that 1 computers that were taken from your house prior 2 you're saying, you don?t even know what those 2 to the execution of the search warrant? 3 charges were about? 3 A Again. Am 4 MR. PIKE: What was the question? i 4 Are you still in possession of the 5 don?t know the question on the tabie now. 5 computers that were removed from your house just 6 Who was the minor? 6 prior to the execution of the search Warrant? Ai??hwn 8 You were never toid the name or initiais 8 questions regarding this lawsuit. However, at 9 of that minor victim by the State Attorney's 9 the present time my attorneys have counseied me i 1 0 Office or the prosecutor? 1 0 cannot respond to any questions that may be M. 12 Just so the jury understands, this 12 might want to. i must accept this advice or risk 13 method of paying underage minor females to bring 13 losing my Sixth Amendment right to 14 you other underage minor females for sex, is 14 representatioa. Therefore, 1 must assert my 1 5 something that you do in New York, and New 1 5 rights under the Fifth, Sixth and Fourteenth 1 6 Mexico, Florida, everywhere, not just West Palm 1 5 Amendments of the US. Constitution. 17 Beach; isn't that right? Who is it that removed these computers 18 MR. PIKE: Again, form, compound, again 18 from your house prior to the execution of the 19 assumes facts not in evidence. 19 search warrant? 2 Argumentative and harassing, and moreover, 2 0 MR. PIKE: Objection, predicate. 2 3. we have already been down this road before 2 A i intend to respond to ail relevant 2 2 in separate related questions that have 2 2 questions regarding this lawsuit. However, at 2 3 already been asked and answered. 2 3 the present time my attorneys have counseied me 2 4 A I wouid iike to respond to each one of 2 4 that i cannot provide answers to any questions 2 5 your questions; however, today my attorneys have 25 that may be relevant to this lawsuit, no matter 23 (Pages 86 to 89) U.S. Legal Support (561) 835*0220 9O 92 1 how much i would like to, and I must accept their 1 question, Mr. Edwards, like most of your other 2 advice or risk losing their representation. 2 questions here and hopefully will get to 3 Accordingly, therefore, would have to assert 3 do so at some point, my lawyers have advised me I 4 thoso rights, Mr. Edwards. 4 must today assert rny constitutional rights under 5 5 6 information and belief, it is my understanding 6 Fourteenth Amendment of the U.S. Constitution and 7 that this computer system contained the complete 7 i must accept their advice or risk losing 8 list of names of underage minor females with whom 8 effective representation. 9 you engaged in sexual activity; is that correct? 9 And as part of that organization you 10 A You'r m- 10 developed code terms such as "Work" or "Massage' 1 1 MR. PIKE: Objection. 3.1 as opposed to engage in sex with minors; is that 2 A -- you're asking for my understanding? 12 true? 1 3 No -- 13 MR. PIKE: Form, argumentative, 1 4 A Are you asking me to tell you what your 3.4 speculation, harassing, assumes facts not in 1 5 understanding is? 1 5 evidence. 1 6 Did the computers that were removed from 16 A Can your home just prior to the execution of the You developed code terms such as you 18 search warrant contain the complete list of 18 A "You" me? 1 9 underage minor females with whom you engaged ir 19 Yes, you, would ask these girls if they 20 sexual activity? 20 would like to give you a massage or work for you, 2 1 MR. PIKE: Form. 2 1 rather than asking them to do what was going to 22 A Though would like to answer that 22 be done, which is engage in sexual activity with 2 3 question, like all your other questions here 2 3 you; isn't that true? 2 4 today, unfortunately my attorneys have counseled 2 4 MR. PIKE: Same objections. 25 me that l'rn going to have to assert my Sixth 2 5 A Are you asking if I developed code 91 93 3. 1. 2 Amendment rights under the U.S. Constitution. 1 2 Right. Code words. 3 3 4 ?rm was described by the current U.S. Attorney question, but unfortunately today my attorneys 5 as a criminal enterprise involved in money 5 told me I have to respond by taking -- invoking 6 laundering, creating and fabricating malicious 6 my Sixth Amendment, Fourteenth Amendment and 7 cases of a Sexual nature against people like me 7 Filth Amendment rights of the U.S. Constitution, 8 and others, in order to fleece local investors 8 or risk losing my amendment right to effective 9 out of millions of dollars. 9 representation. Accordingly I assert my 10 i believe the senior partner of that 10 Constitutional rights as guaranteed by those 1 1 ?rm currently sits in jail. Unfortunately 1 amendments. 12 though i would like to answer all of your 12 What did it mean within your 13 questions, today my attorneys have counseled me I 13 organization when someone, some underage minor 1 4 must assert my rights under the Sixth Amendment, 14 female was coming over to work for you? 16 15 1 6 U.S. Constitution. 3. 6 A What did it mean? 17 Isn't it true, you and Sarah Kellen and 1? Right, what did it mean? What did it 18 Ghislaine Maxwell and Nadia Marcinkova operated 18 mean to you was going to happen when an underagl l. 9 as an organized criminal enterprise designed to 19 minor female would either call to work or Sarah 20 sexually exploit minor? 20 Kellen would tell you this person was coming to 2 1 MR. PIKE: Objection, argumentative, 2 1. work for you at a speci?c time? 22 speculation, calls for a legal conclusion 2 2 MR. PIKE: Objection, vague, 2 3 and continues to assume facts not in 2 3 speculative, assumes facts not in evidence. 2 4 evidence. 24 A I would like to answer that question, as 2 5 A Though i would like to answer that 25 most of your other questions today. However, 24 (Pages 90 to 93) U.S. Legal Support (561) 835-0220 3 94 96 1 today my attorneys have counseled me that i must 1 as a trash puli, just what someone takes as 2 invoke my Sixth Amendment, Fourteenth Amendment 2 a message at Mr. Epstein?s home and 3 and Fifth Amendment right, or risk and if I 3 A Do i know what a message pad is? 4 dorft, i risk losing them as my attorneys so, 4 No. In your home, do you typicaily have 5 therefore, I must assert those rights. 5 your housekeeper, housemanager, or somebody else 6 You're laughing as if my questions are 6 when they take a message for you, write on a indicrous right now but you?re aware that there 7? Speci?c pad that informs you as to who is 8 were trash pulls from your home where there were 8 calling, the time they are cutting and the 9 message pads, messages taken by various employees 9 purpose for their calling, and there is a carbon 10 of yours, where these terms, "Massage," "Work" 10 copy sheet evidencing that message? 11 were used in conjunction with underage minor 11 MR. PIKE: Objection, asked and 12 females coming over to your house, weren't you? 12 answered. 13 MR. PIKE: Same objections, form, as 3.3 You know what I'm talking about? 14 well. Move to strike, and aiso assumes 14 A I know what a message pad is. 15 facts not in evidence. Lack predicates. 15 Do you use them com moniy in your home or 1 6 You're aware of the trash pull and the 1 6 did you back prior to your arrest? 1 7 message pads, correct? 17 A I would like to answer that question, 18 MR. PIKE: Same objections. 1 8 but today my attorneys have advised me I have to 19 Do you have any documents with you here 1 9 assort my Fifth Amendment, Sixth Amendment and 2 0 today that you speak oi? 2 Fourteenth Amendment rights under the U.S. 2 1 MR. EDWARDS: No, but at this point in 2 1 Constitution, so therefore, i'm going to do that 2 2 time in the trial, they aiready about 2 2 or I risk iosing their representation. 2 3 in evidence. 23 is my question to you confusing? Do you 2 4 A i'm aware of a trash pail? What?s a 2 4 know what I'm talking about? 2 5 "trash puii"? l'm sorry. 2 5 MR. PIKE: Form. 95 97 1 Are you aware Not SPCCi?caiFy, n0. 2 this way: When Sarah Kellen would take a phone 2 Okay. 3 message for you, what did she write it down 3 The information w? 4 with? 4 A Is there something you have to Show me, 5 MR. PIKE: Form. 5 so i know what you're talking about? 6 A The question makes no sense to me, 6 I don't have it to show you today, but 7 sorry. 7 if the information and evidence that I have 8 If another employee of yours were to 8 learned through this process is accurate and 9 answer the teiephone, be it your housekeeper, 9 correct, it would seem a foregone conclusion that 10 housemanager, would answer the phone, take a 10 you and I would be on the same page, at least 1 1 message for you and write it down so that you 1 1 about this document, so 12 couid read it later, what wouid that message he 12 A Okay. 3 written on? 13 if we are going to get to a point you 3.4 A Most likeiy paper. 14 tell me "This document doesn't exist" or don't 1 5 Okay, is that paper typicain in the 1 5 know what you're talking about," okay, that's 16 form ofa message pad that has a carbon copy 16 fine, but that's something we can hash out. sheet to the back? 17 Here is my question: When a 18 A No, 18 housekeeperfhousemanager would take a message to 19 You're unfamiliar with the documents 19 you from any caller, is there a specific message 20 that I'm talking about, that being a message pad 20 pad that has a carbon copy iocated near your 2 1 that informs you as to who called, the time they 2 1 telephone, for them to write down the name of the 22 called and the purpose for calling? 22 caiier, the purpose for the can and the time 2 3 MR. PIKE: For purposes of the question 2 3 called? 2 4 you?re speci?cally talking about a message 2 4 MR. PIKE: Form. 2 5 pad, nothing related to what you're de?ning 2 5 Is that something you're familiar with? 25 (Pages 94 to 97) U.S. Legal Support (561) 835?0220 98 100 A I would like to respond to that 1 Between the years 2802 and 2885, who was 2 question. Today my attorneys have counseled me i 2 your house manager? 3 must assert my Sixth Amendment, Fifth Amendment 3 A (No response.) 4 and Fourteenth Amendment right under the US. 4 If there is more than one, tell us 5 Constitution. 5 that. 6 You're invoking your Fifth Amendment 6 A The question is unciear. i'm sorry. 7 right is not that you understand the question. "i Okay, let me start with between 2002 and 8 You understand my question and are electing to 8 2005, did you employ a housemanager? 9 invoke your Fifth Amendment rights; is that 9 MR. Form. 10 correct? 10 A Where? 11 A Yes. 11 At your Palm Beach home. 12 When Sarah Kellen or a housekeeper or l2 A I intend to respond to ali relevant l3 hoasemanager, whoever happened to be employed a: 13 questions here today, Mr. Edwards. Hopefully we 14 the time, wouid take messages, what form wouid 14 will get some. But my attorneys have advised me 15 you normally or typicaily receive them in? 15 that today i must invoke my Sixth Amendment, 1 6 A (Witness shrugs.) 6 Fifth Amendment and Fourteenth Amendment rights 17 MR. PIKE: Same objections. under the US. Constitution; or risk losing them 18 A I don?t understand the question. 1 8 as counsel. So today I have to assert those 19 When a caller would call the home, 19 priviieges. 20 housemanager or housekeeper or Sarah Kellen, I 2 0 Do you know 21 don't know what you wooid call her, assistant, 2 1 A i intend to respond to relevant 22 would answer the phone, and take a message for 22 questions regarding this lawsuit. However, at 2 3 you so that you would know who called, what would 2 3 the present time no matter how much I wouid like 24 they typicain write down the message on so that 24 to answer that question, I cannot, because my 25 you would have it? 25 counsel the attorneys have toid me that have 99 I 101 J. 2 form, lacks predicate, You have not 2 Fourteenth Amendment 02?, in fact, risk losing 3 3 4 a housekeeper or housemanager or the iike. 4 have to assert my rights under those. 5 And i'm trying to understand the LM. is a female that was born in July 6 question. But -- 6 of 2988. I . 7 MR. EDWARDS: Really? 7 A Is that a questioo?? 8 MR. PIKE: it lacks predicate. 8 Not yet. When is the first time that 9 MR. EDWARDS: This will play well. 9 you met her? 10 A Piece of paper. 10 MR. PIKE: Objection, Speculation. 11 Normally they would write it down on a 1 1 MR. EDWARDS: That assumes that he did 1 2 piece of paper and give it to you? 1 2 meet her; is that what you?re saying? 1 3 A i didn't say that. 3 MR. PIKE: Your question assumes 14 Have you ever been given a message that 14 MR. EDWARDS: He mother? 15 is ripped out of a message pad that has a carbon 1 5 MR. PIKE: exactly what hejust said 1 6 copy to it? 1 6 which hasn't been estabiished on the record 1 7? A Oh, i see. Okay. I intend i would 1 7 yet pursuant to the appropriate Florida 3.8 like to answer that question, but today my 18 Rules of Civil Procedure and the Evidence 3. 9 attorneys have advised me I must respond by 1 9 Code. Lacks predicate. 20 20 2 1 Amendment right and my Fourteenth Amendment 2 1 that but today my attorneys have 22 rights under the U.S. Constitution. Though I 22 counseled me that I cannot, and they*ve advised 23 would like to answer these questions, accordingly 2 3 me i must assert my Sixth Amendment right, my 24 I must assert those rights or I risk losing my 2 4 Fourteenth Amendment right, and my Fifth 25 representation here today, 2 5 Amendment right under the Constitution. 26 (Pages 98 to 101) 0.3. Legal Support (561) 835?0220 102 104 1 THE WITNESS: Can you throw me one of 3. A And now the question? 2 the suckey candies, please 2 You know who she is, correct? 3 Thank you. 3 MR. PIKE: Form. 4 MR. ED WARDS: (Handing candy.) 4 A i would iike to answer that question 5 THE WITNESS: Appreciate it. 5 here, Mr. Edwards, but unfortunately today my 6 Isn?t it true you met L.M. for the ?rst 6 attorneys have counseied rne I must invoke my "3 time in July or August of 2002 just before her Fifth Amendment, Sixth Amendment and Fourteenth 8 fourteenth birthday? 8 Amendment rights under the U.S. Constitution, and 9 MR. PIKE: Same obj ections. 9 if I don't, 1' risk losing their representation, 1 A You know, your ?rm has been accused by 1 0 therefore I must assert those rights. 1 1 the U.S. Attorney of perpetrating one of the 11 When I asked you about LM. or Carolyn 12 iargest frauds in South Florida history by 12 Andriano, you sat there for a white thinking hard! 1 3 crafting sexuaily charged lawsuits against people 1 3 about whether or not you knew them. Do you 1 4 like me and others in order to fleece 1 4 remember either L.M. or Carolyn Andriano? 15 unsuspecting investors here in South Florida out 15 MR. PIKE: i move to strike counsel?s 6 of miliions of doiiarsstatement because the statement as worded 7 Jaffe. The U.S. Attorney described it as bogus 1 '3 assumes facts certainly not in evidence. It 1 8 schemes contrived by your ?rm. 18 is argumentative, speculates as to what is 9 I would like to answer every one ofyour 1 9 "thinking hard," and, counsel, I don't 2 0 questions here today however, my attorneys have 2 0 understand the queStion on the tabie, 2 1 counseied me that I may not, and have advised me 21 combined with your narrative. If you couid 22 22 23 Amendment and Fourteenth Amendment rights under 23 MR. EDWARDS: Sure. 2 4 the U.S. Constitution. Therefore, that's what I 2 4 I'm asking if during this questioning 25 will do, otherwise i risk losing their 25 process, has it refreshed your recoilection as to 103 105 1 representation. 1 who L.M. is or do you reatiy have no idea who 2 Isn't it true LM. as a 13 or 14-year 2 that is? 3 old girl was taken to your house by another 3 MR. PIKE: Form. Asked and answered. 4 underage minor female, that being Caroiyn 4 Do you remember 5 Andriano? 5 A Are you going to ask one question? 6 6 7 THE WITNESS: Tissue, please. 7 Do you remember 8 8 9 A i would like to answer that question 9 would iike to answer that question today; however 10 like all the other questions you've asked me here 1 0 my attorneys today have advised me that must 1 1 today, but today my attorneys have counseied me 1 1 assert my Fourteenth Amendment, Fifth Amendment 12 that I have to invoke my Sixth Amendment right, 1 2 and Sixth Amendment rights under the U.S. 13 l4 rights under the U.S.- Constitution; therefore I 14 answer these questions. So unfortunately, I'm 1 5 that's what will do. 1 5 going to assert those rights. 16 Do you know who Carolyn Andriano is, 1 6 When you first met L.M., isn't it true right, she had a lawsuit against you previously? 1 that she was just about to begin her ninth grade 18 MR. PIKE: Form. 18 year in high schooi? 19 A Again the last name? 19 MR. PIKE: Same objections. Form. 2 Carolyn Andriano. 2 A I believe her testimony in front of the 2 1 A Could you speli it for me? 2 1 FBI, in a sworn deposition says something else, 22 Well, the pseudonym that she used in her 22 but I don?t recall exactly what. i den't have 2 3 lawsuit against you alleging similar facts to 2 3 any recollection. 2 4 those alleged in L.M. versus Jeffrey Epstein was 2 4 01? L.M. 25 C.M.A. versus Jeffrey Epstein. 25 MR. PIKE: Form. 27 (Pages 102 to 105) U.S. Legal Support (561) 835*0220 106 108 1 A You asked the question when I met her, i 1 When you ?rst came into the room today, 2 think, if I met her. 2 didn't you look at me and say "i like Isn't- 3 You have no recollection as to when you 3 that the statement that you made to me? 4 met her? 4 MR. PIKE: Form. Move to strike. 5 A I don't have recoilection ifl ever met 5 A i don?t believe I said that. 6 her. Ijust told you, did read her FBI 6 What is it that you believe you did say 7 statement, so i know what she has said and it is "f referencing LM. when you sat down in that seat 8 not what you?ve just represented to me. 8 prior to the cameras roliing? 9 Your only knowledge of any interaction 9 MR. PIKE: Form. 'Counsel, 1 was here 10 you may have had with L.M. is derived from an FBI 10 during that whole time and I don?t recall 1 1 statement that she gave; is that true? 1 3. any such statement. 12 A iheiieve what youjust represented she 12 MR. EDWARDS: You weren't in the room. 1 3 said was not what she had sworn to. 1 3 A i don?t remember. I don't know. 1 4 I'm not asking what she said. I'm 14 Sorry. It 5 asking do you independently remember your testimony right now that 16 entering into her ninth grade year of high school like 7 when you met her? Independent of anything you've A That's 1 8 read. 1 8 MR. PIKE: Objection. 19 MR. 91KB: All right, let mejust move 19 A that?s correct. 2 0 to strike Diatrihe between Mr. 2 0 Do you like 2 1 Edwards and Mr. Epstein. I'm confused as to 2 1 MR. PIKE: Form, predicate, and 2 2 what questiori is on the table now. 2 2 relevance. 2 3 MR. EDWARDS: Okay. 2 3 A I would like to answer all your 2 4 Independent of anything you've ever 2 4 questions here as tried to do my best, 2 5 read 2 5 however, my attorneys have advised me that i must 107 109 2 do you remember meeting L.M., just 2 and Fifth Amendment rights under the U.S. 3 before she entered into her ninth grade year in 3 Constitution. 4 high school? 4 When you ?rst met L.M., isn't it true 5 A i. would like to anSwer that question, 5 that you knew she was an economically 6 however my attorneys today have advised me that 6 disadvantaged girl that needed money? though her own statements are contradictory to 7 MR. PIKE: Objectimr, speculation, 8 what you just said, her sworn statements to the 8 assumes facts not in evidence, and it is 9 contradict what youjust said. I have to 9 argumentative as worded. 3.0 invoke my Sixth Amendment, Fifth Amendment and 10 A i would like to answer ali your 3. 1 Fourteenth Amendment rights to the U.S. 1 questions here today, Mr. Edwards, and Mr. 1 2 Constitution. 12 latte. However, on advice of counsel 1 have to 13 est a few minutes ago when you asked 1 3 assert my Sixth Amendment, Fifth Amendment and 3.4 when you met her, you said, don't know if {'ve 14 Fourteenth Amendment rights under the U.S. 5 ever met her," so is that your? testimony, that: 1 5 Constitution, or risk iosing my right to 16 you don't know if you ever met 16 effective representation. So accordingly I must 3.7 A My testimony is very clear. I must 17 assert those rights as guaranteed by the Sixth, 18 assert the rights my attorneys havo asked me to 18 Fifth and Fourteenth amendments. 9 assert today, though her testimony under oath to 1 9 When she was a l4?year old girlnot what you represented it to he, to 20 taken into your bedroom and you ordered her to 2 1 me, and the ladies and gentiemen of the jury who 2 1 take her clothes off; is that correct? 22 are watching this, hopefully. 2 2 MR. PIKE: Objection, vague, confusing. 2 3 MR. PIKE: Form. 2 3 As to "her," I?m not quite sure who 2 4 We will get into that. 2 4 When L.M. was a 14-year old girl, she 25 A Okay. 25 was taken up to your bedroom and you ordered he 28 (Pages 106 to 109) U.S. Legal Support (561) 835?0220 1 0 1 2 1 to take her ciothes off; isn't that true? 1 THE VIDEOGRAPHBR: Going off the video 2 MR. PIKE: Objection, speculation, and 2 record 1:49 pm. 3 assumes facts not in evidence. Lacks 3 THE WITNESS: Thank you. 4 predicate. 4 (Pause in the proceedings.) 5 A Though once again what you?ve just 5 THE VIDEOGRAPHER: Back on the video 6 6 rammz?dpm. ?3 FBI sworn statement that i read of L.M., i must '1 Mr. Epstein, when L.M. was a 14-year old 8 unfortunately respond by asserting the rights 8 girl, isn't it true that while you were naked on 9 demanded by my attorneys today, which is my Sixth 9 the massage table, you ordered LM. to take off 10 Amendment, Fifth Amendment and Fourteenth 10 her clothes and provide you a massage? 1 IE. Amendment right against sorry, given by the 1 1 A i believe I've answered that question, 12 12 (?dntl? 3 exactly does not purport in any way to what 1 3 I don't remember where we left off, 1 4 you?ve just said. 1 4 that's why. 15 15 16 ordered she begin to give you a massage while she 1 6 speculation. it is compound and assumes 17 was naked and you were naked; isn't that true? 17 facts not in evidence and has been asked and 18 MR. PIKE: Same objections. 1 8 answered. But we did take a break, so you 1 9 A Sony, you have to repeat the question 1 9 can respond. 2 for me. 2 (Counsel addressing Mr. Epstein.) 2 3. When L.M. was a 14-year old girl 2 A The current US. Attorney has described A mthm? 22 23 you laughed and said, "right" about 23 in fabricating sexually charged cases against 2 4 what? 2 4 people like me in order to fleece unsuspecting 25 A I didn?t hear the ?rst part of your 25 investors out of millions of dollars. He used 1 1 1 1 3 1 question. Now i understood it. 1 words like "bogus schemes." 2 2 3 it true that you received a massage from her 3 to your questions, though I would like to answer 4 while she was naked and you were naked? each and every one, I?m going to have to, on 5 MR. PIKE: Objection, speculation, 5 advice of counsel, assert my Sixth Amendment, 6 assumes facts not in evidence, lacks 6 Fifth Amendment and Fourteenth Amendment rights 7 predicate. 7 under the US. Constitution, though i would like 8 A i. understand that your ?rm has been 8 to answer those questions. 9 accused by the US. Attorney of South Florida, 9 While L.M. was a naked 14-year old girl 10 perpetrating one of the largest frauds in 10 providing you a massage, you ordered her to pinch 11 Floridds history, by" crafting malicious, 11 your nipples during that massage; isn't that 12 sexually charged allegations against people like 12 true? 13 me. i understand L.M.'s testimony is not what 13 MR. PIKE: Same objections, 14 you?ve just described, though she swore to the 1 4 argumentative, speculation, harassing, 15 under oath. Though i would like to answer 15 assumes facts not in evidence and lacks 16 your questions here today, my attorneys have 1 6 predicate. 17 advised me i may not. I must assert my Sixth, 1 7 A I asked her to pinch her nipples? 18 Fifth and Fourteenth Amendment rights under the 18 Pinch your nipples? 19 19 2 representation. 2 0 contradicts that statement. However, I would 2 1 THE WITNESS: Restroom break. 2 1 like to answer all your questions here today, but 22 MR. EDWARDS: Excuse me? 22 my attorneys advised me, at least today, Mr. 23 THE WITNESS: Restroom break. 2 3 Edwards, 1 must take my constitutional privileges 24 MR. EDWARDS: Stopping again? 2 4 of the Sixth Amendment, Fifth Amendment and 2 5 THE: WITNESS: Yeah. 2 5 Fourteenth Amendment, keeping in mind that your 29 (Pages 110 to 113) 0.8. Legal Support (561) 835-0220 114 116 1 ?rm, of you, Mr. Edwards, and Mr. .iaffe's firm 1 MR. PIKE: Same objections incOrporated? 2 has been accused by the US. Attorney of 2 A Again, the question? 3 perpetrating one of the largest frauds in 3 Isn't it true that during this sexual 4 Florida's history by crafting sexually charged 4 massage, while you were that you masturbated 5 lawsuits against people like me, to ?eece from 5 to the point of ejaculating while you were 6 local people millions of dollars. 6 inserting your ?ngers into vagina? 7 ?And during this massage by L.M., you 7 MR. Objection, argumentative, 8 began to masturbate in front of her; isn't that 8 speculation. it is compound. it is vague. 9 true? 9 it assumes facts not in evidence and lacks 0 MR. PIKE: Same objections? 1 predicate. 1 1 A Unfortunately, though i would like to 1 A Though would like to answer that 12 answer each one of your questions here today, my 12 question with Speci?city and detail today, no 13 attorneys have counseled me today at least, i 13 matter how much I would like to, my attorneys 14 have to assert my Fifth Amendment, Sixth 3.4 have advised me i cannot. They advised me I must 1 5 Amendment and Fourteenth Amendment rights under 1 5 assert my Fifth Amendment, Sixth Amendment and 1 6 the U.S. Constitution, otherwise I risk losing 16 Fourteenth Amendment rights under the US. 1 7 their effective representation, and the fact that Constitution or potentially lose effective 1 8 your ?rm has been accuscd of fabricating these 1 8 representation, so therefore, I will assert those 19 19 ?mus 2 millions of dollars, as described by the US. 2 0 isn't it true that the ritual that I'm 21 Attorney here in South Florida as a criminal 21 describing occurred with Lil/L, approximately 106 22 enterprise involved in mail fraud, money 22 times when she was between the ages of 13 and 16 2 3 Unfortunately I would like to 2 3 MR. PIKE: Same objections, with the 2 4 answer each question, but l. can?t today. 2 4 additiOnal objection of vague and 2 5 Isn't it true that while you were 2 5 confusing. 115 117 masturbating you inserted your ?ngers into her 1 A Since your firm has been involved 2 14-year aid vagina? 2 according to the U.S. Attorney in crafting these 3 MR. PIKE: Objection, argumentative. 3 fraudulent. lawsuits in order to fleece local 4 Speculation. It is harassing. It assumes 4 investors, and the fact that i believe in 5 facts not in evidence. The question 5 sworn statements, that?s what you?ve just alleged 6 continues to lack predicate, and i also 6 at least is totally contradicted by your client's 7 believe the question has been asked and own sworn statements, though i would like to 8 answered sometime ago. 8 answer these questions today, my attorneys have 9 A Though I would like to answer each one 9 advised me i may not and advised me must assert of your questions today, Mr. Edwards, my counsel 10 my Fifth, Sixth and Fourteenth Amendment rights 3. 1 has told me cannot answer any questions that 1 1 under the US. Constitution or potentially risk 3.2 may be relevant to this lawsuit. The fact that 2 losing effective representation. 13 your ?rm has been accused of major fraud, the 13 In addition to the sexual abuse directed 1 4 largest fraud in South Florida history, by the 1 4 against LM. that l've just described, isn't it 15 US. Attorney calling your firm a criminal 15 true that you also paid her money to bring you 1 6 enterprise involved in money laundering 6 more than 50 other underage minor females for you 17 believe it is racketeering, but i could be 1 7 to similarly abuse? 1 8 Monetary transactions via fraud, mail 1 8 MR. PIKE: Same objections. 1 9 fraud, conspiracy -- sorry i would like to 1 9 A Though i believe in her own sworn 2 0 answer your questions but today on advice of 20 testimony to the US. government that she 2 1 counsel, 1 am going to have to assert my rights. 2 1 contradicts those assertions, and I'm sure maybe 2 2 Isn't it true also that while L.M. was a 2 2 you'll have some explanation at trial, but the 2 3 24-year old female, you masturbated to the point 2 3 iailies and geniiemen 0f ihe lury know 2 4 of ejaculating while inserting your ?ngers into 2 4 about your firm being accused by the US. 2 5 L.M.'s vagina? 2 Attorney of perpetrating one of the largest 30 (Pages 114 to 11?) U.S. Legal Support (561) 835-0220 118 120 1 1 2 lawsuits of a sexual nature in order to fleece 2 Florida's histOry. So, it concerns me. it is a 3 investors out of millions of dollars, local 3 factor in the way l'm thinking about answering. 4 investors; and though i would like to answer your 4 Sorry. 5 questions in detail today, Mr. Edwards, and Mr. 5 Each time that you digitaliy penetrated 6 laffe, my counsel says may not and have asked 6 Lil/K. or otherwise fondled her sexually, you paid 7 me to assert those rights, which I must 7 her $200; is that correct? 8 unfortunately. 8 MR. PIKE: Objection, argumentative, 9 You keep bringing up this fraud of the 9 speculative, harassing. it assumes facts 10 former iaw ?rm known as Rothstein, Rosenfeld. 10 not in evidence, and with regard to this 1 Adler in response to my questions, so 1 would 1 1 line of questioning, the Court has already 12 like you to tell the jury at this time which 1 2 ruled that the demeanor in which you?re 13 allegation are you now saying is fraudulent or 1 3 presenting this question is improper, and 14 untrue, that's been made by 14. harassing, so if. you would 15 MR. PIKE: Form, confusing, compound, 15 MR. EDWARDS: l?m very comfortable with 16 and irrelevant. 16 the demeanor right now, Mr. Pike. These are 17 MR. EDWARDS: Only made irrelevant by 17 just the facts of the lawsuit. The facts 1 8 his answers. 1 8 are outrageous and I understand that, but 19 MR. PIKE: Same objections. 19 they have to be asked. 20 Do you understand the question? 20 MR. PIKE: Maybe the demeanor and tone 21 A No 21 22 You made reference to m- in response to 22 it is proper for the video, but the content 2 3 my questions about what you did sexually to 2 3 of the question is the same exact harassing 2 4 L.M. -- 2 4 question that was deemed by the Judge to be 25 A Yes, sir? 25 argumentative. i'm not saying that he's not 119 121 1 you have responded with these fraud 1 going to answer your question. 2 allegations against the firm of Rothstein, 2 MR. EDWARDS: Okay. 3 Rosenfeld, Adler. I want you to tell the jury 3 MR. PIKE: Or that you don?t know what a which allegations that L.M. is making against you 4 his answer will be, but what l'rn saying is: 5 are you disputing at this time or cutting a fraud 5 could you rephrase the question? 6 or calling untrue? 6 Answer that question. I'll work on 7 MR. PIKE: Confusing, compound and if rephrasing it for you at some point. 8 8 9 Epstein's response, think you will see the 9 now. 1 8 way you just phrased the question 10 Isn't it true that each time that you 11 mischaracterizes his testimony. Because -- 11 interacted with L.M. sexually, meaning digitally 3.2 well, l?ll keep it there unless you want me 12 penetrated her or fondled her in some other way. 13 to go further. You want me to go further? 13 that you paid her $200 each time? 14 MR. EDWARDS: No, i want him to go 14 MR. PIKE: Form. 15 further. 15 THE WETNESS: Sorry? 16 16 witness's testimony. A i would like to answer each one of your 1 8 A own statements contradict every 18 questions here today. However, my attorneys have 1 9 one of your allegations that you?ve made to me 1 9 counseled me that today i have to assert my Fi?h 2 0 today, as a hypothetical. in her own words. And 2 0 Amendment, Sixth Amendment and Fourteenth 2 1 you and the potential reasons this concerns me 21 Amendment rights under the 11.8. Constitution and 22 is the fact that the law ?rm that represented 2 2 I?m cognizant of. the fact that your firm has 2 3 LM. and two others have been accused by the US. 23 crafted these malicious lawsuits, it has been 2 4 Attorney of fraudulently producing cases against 2 4 reported that the lawsuits are of a sexual 25 31 (Pages 118 to 121) 0.8. Legal Support (561) 835*0220 122 124 wouid like to answer those questions, Mr. 1 MR. PIKE: Objection, argumentative, 2 Edwards, and Mr. Jaffe, today I must keep my 2 irrelevant and move to strike. i'm simply 3 counsei's advice. 3 a going to instruct the witness not to answer 4 Isn't it true that for each underage 41 that question I don?t understand 5 minor that L.M. brought to you for the purposes 5 it. I don't know what to say about that 6 ofyou engaging in sexual activity, you paid her 6 question. 7 $209? 7 A (Gesturing.) 8 MR. PIKE: Objection, specuiation. 8 All of the things that I?ve toid you or 9 Compound question, and it assumes facts not 9 that i've asked you about, you touching her while 10 in evidence. Therefore tacks predicate. 10 she was underage, you paying her for sexual 1 A Though I would iike to answer that 1 1 conduct, those are all things that reaiiy 12 question, as most of your other questions here 12 happened, there is nothing about that, that 1 3 today, Mr. Edwards, I intend to respond, 1 3 anybody has fabricated or made up, is there? 1 4 hopefuliy at some point to of your questions, 1 4 MR. PIKE: Objection, argumentative, 1 5 but today my attorneys have advised me I must 15 speculative, it assumes facts not in 1 6 invoke my Sixth Amendment, Fifth Amendment and 6 evidence, it certainiy mischaracterizes the 3.7 Fourteenth Amendment right under the US. witness's testimony all day, since i have 18 Constitution. 18 been here, and I have been here the whole 1 9 Over the course of relatively a roughiy 3. 9 time. It assumes facts not in evidence. it 20 three years, isn't it true that you touched or 20 is aiso overbroad and substantiaiiy compound 2 fondled LIVE. in a sexuai manner on more than 50 2 1 because you're attempting to incorporate all 2 2 occasions? 22 of your questions today into one question. 23 MR. PIKE: Objection, argumentative. 23 MR. EDWARDS: I think you know, Mr. 24 Cails for Specuiation. It is overbroad, 24 Pike, your objection shouid be limited to 25 confusing and vague, and it assumes facts 25 the form. If you object to the form, it is 123 125 nothzewidence. 1 ?ne. 2 A Couid you repeat the question for me? 2 MR. PIKE: I'm sorry, that's 3 I'm sorry, Mr. Edwards. 3 MR. EDWARDS: You -- 4 Yes. The three~year period between 2002 4 MR. PIKE: You've asked me several times 5 and 2005 when you were engaging in sexuai conduct 5 today to teIl you why. i thought i was 6 with L.M., isn't it true that that conduct took 6 helping. I?m sorry. I certainly keep 7 place on more than 50 occasions? 7 objecting to -- 8 MR. PIKE: Same objections. 8 MR. EDWARDS: Appreciate it. 9 A i believe if you read your own ciient?s 9 MR. PIKE: the form. 1 0 FBI statements, what her statement it changed 10 MR. EDWARDS: Thank you. 1 1 dramaticaliy after she decided to ?le a 1 1 And your answer is? 1 2 different lawsuit, at the request of you and your 3.2 A Repeat the question. 1 3 ?rm, with one of your ?rms -- there have been 1 3 Every single aliegation that LM. has 14 many ?rms it seems, was accused of major fraud. 14 made and i have now questioned you about in terms 15 Since the testimony has changed dramaticaily, i 1 5 of your sexual involvement with L.M., they are 1 6 would like to answer those questions, but today 1 6 true; isn't that correct? There is nothing 17 my attorneys have advised me i must assert my 17 fabricated about any of these allegations, 18 Sixth Amendment right, my Fifth Amendment right 1 8 correct? 1 9 and my Fourteenth Amendment right. 19 MR. PXKE: Objection, argumentative, 2 0 Your answers are not going to 20 specuiative, compound. it is vague, 2 1 incriminate you if the answer is it is only 2 3. overbroad -- 22 if the answer is "yes" that it will incriminate 22 MR. EDWARDS: You're objecting to form? 2 3 you, so aren't you the jury every single 2 3 MR. PIKE: Yes, assumes facts not in 24 thing I?ve asked you is not part of a fraud, just 2 4 evidence and lacks predicate. That is 25 happensnibetruaisn??t? 25 tons. 32 (Pages 122 to 125) U.S. Legal Support (561) 835?0220 126 128 1 1 2 speci?cally today, however, on advice of counsel 2 answer so I won't allow 3 they?ve suggested I take the Sixth amendment 3 MR. PIKE: That 4 assert my Sixth Amendment, Fifth Amendment and 4 MR. EDWARDS: We'll move to strike it. 5 Fourteenth Amendment rights under the U.S. 5 Let's have an answer to the question. 6 Constitution, keeping weil aware of your ?rm?s 6 MR. The witness is trying. If '7 responsibility in the largest fraud in Florida's 7 there is a legal basis for your moving to 8 history by crafting sexuain charged lawsuits 8 strike, it would be taken up with the Court 9 against peoole like me and others. 9 and you can move to strike. 1 0 I believe in addition, since her 1 0 You can continue. 1 1 allegations, as you've phrased them, have changed 1 1 MR. EDWARDS: Strike it, it is 1 2 dramatically since her sworn statement, untii in 1 2 nonresponsive? 1.3 fact, after shejoined this firm charged with 1 3 A Your allegations that you keep throwing 14 this major fraud and most of her statements have 1 4 at me, relate to the fact that LM. testimony, 15 changed, I believe, 1 5 after giving a sworn statement to the 1 6 You rem ember when LAW. became pregnant 1 6 changed dramatically after she decided to file a 1 7 when she was 16 years old, don't you? 3.7 lawsuit for money, joining your firm that's been 18 MR. PIKE: Form, relevance, move to 18 accused by the U.S. Attorney of one of the 19 strike? 19 largest frauds in Florida?s history. I would 20 A I would like to answer each one of your 20 like to answer those questions; however, on 2 1 questions here today, Mr. Edwards; each and every 2 1 advice of counsel today i must assert my Filth 2 2 one of your questions. However, today my counsel 22 Amendment, Sixth Amendment and Fourteenth 23 has told me i must assert my Sixth Amendment, 23 Amendment rights under the U.S. Constitution. 24 Fourteenth Amendment and Fifth Amendment rights 24 When LM. was a pregnant 16 year~oid, 25 under the U.S. Constitution. 25 she brought you at ieast ten underage minor Isn't it true that when LM. was 14 femaies (in ring her pregnancy; isn't that true? 2 years old, 15 years old and 16 years old, you 2 MR. PIKE: Objection, argumentative, 3 touched her genitals? 3 speculation. It is vague and assumes facts at A Separate from the fact that in her own 4 not in evidence and lacks predicate.- 5 testimony, her own sworn testimony under oath A -- I unfortunately would like to 6 before she decided to ?le a iawsuit for money, 6 answer that question as well as every other 7 there was never any discussion about anything 7 question you?ve asked me here today, but my 8 like that. I would like to answer that question, 8 attorneys have advised my i must assert my Fifth 9 but my attorneys have advised me, at least today, 9 Amendment, Sixth Amendment and Fourteenth that I must assert my Sixth Amendment, Fifth 1 0 Amendment rights under the U.S. Constitution. 1 1 Amendment and Fourteenth Amendment rights under 1 1 After L.M. had her son at 16 years old, 12 the U.S. Constitution. 12 and you were being criminally investigated for 13 Isn't it true when she became pregnant 13 some of the conduct that we've discussed here longer interacted with her 1 4 today; isn't it true that you personally hired 1 5 sexualiy but still demanded that she bring you 15 and retained and paid for an attorney to 1 6 other underage minor females for you to sexually 3. 6 represent exploit? 17 MR. PIKE: Objection, speculation -- 18 MR. PIKE: Objection, speculation. 18 MR. EDWARDS: Object to the form, Mr. 1 9 Compound. Harassing, and assumes facts not 1 9 l?ike. 2 in evidence. 2 0 MR. PIKE: i will not. i am allowed to 2 1 A lbeiieve her testimony changed 2 1 assert the basis for my objections, I am not 2 2 dramatically from her sworn statements to the 2 2 limited to just saying "form." I'm able to 2 3 FBI 2 3 assert the basis as to why, so i don?t waive 24 (2 Tha?snotazuspon?ve?~ 24 thatbams. 2 5 MR. PIKE: Excuse me -- 2 5 MR. EDWARDS: it is just more of this 33 (Pages 126 to 129} U.S. Legal Support (561) 835-0220 130 132 1 obmnm?ongtu 1 2 MR. PIKE: It?s not obstructionist, it 2 THE VIDEOGRAPHER: Going off the video 3 is objecting to form. What is 3 record 2:29 p.m. 4 obstructionist is what we are doing now. i 4 (Pause in the proceedings.) 5 wili he ?nished within four seconds. So I 5 THE VIDEOGRAPHER: Back on the video 6 am going to object to form, it?s 6 record 2:50 pm. argumentative, speculative and it assumes 7 Isn't it true, Mr. Epstein, that you 8 facts not in evidence and it lacks 8 gave L.M. money to coerce her into interacting 9 predicate. That's it. 9 with you sexually? 0 A I'm sorry. (Witness shrugs.) Again? 10 A Mr. Edwards, I would iike to answer each 1 1 The response to the question, 1 1 and every one of your questions here today, but 12 A I don?t know the question, 12 unfortunateiy, iike I've done with mostiy of 1 3 You don't remember the question? Did 1 3 your other questions, I'm going to have to assert 14 you hire an attorney at some point in time? 14 my rights, Sixth Amendment, Fourteenth Amendmen 1 5 Do you remember that? 15 and Fifth Amendment on advice of counsei. 16 16 AMwmmemMermamwm??dm? A Not to the best of my recollection. foilow my counsel's advice, I risk iosing 8 Do you know James Eisenberg? 1 8 repreScntation. 19 A Do I know James i don't 19 While committing these sexual acts 20 believe I?ve ever met James Eisenberg. 20 against LM. when she was just a minor, you knew 2 1 Is it your testimony today then that you 2 1 it wouid damage her; isn't that 22 never paid for an attorney to represent 22 true? 2 3 A (Witness shakes On advice of 23 MR. PIKE: Form, iacks predicate, 2 4 my counsel, i would like to answer that question, 2 4 speculatiOn. 2 5 but on advice of counsel I'm going to have to 2 5 A i intend to respond at some point to 131 133 1 assert my Sixth Amendment, Fourteenth Amendment 3. I would titre to respond to each and every one of 2 and Fifth Amendment rights against excuse me, 2 your questions, but today on advice of my counsei 3 Sixth Amendment rights of the U.S. Constitution. 3 they've required me to assert my Fifth Amendment, 41 And that attorney that was paid for by 4 Sixth Amendment and Fourteenth Amendment rights 5 you, informed L.M. that if she were to tell the 5 under the U.S. Constitution, though i vvouid like 6 exactly what happened at your house, that her 6 to answer each of these questions. 7" son could be taken from her. You're aware of 7 in fact, you deliberatciy and 8 that, correct? 8 intentionally caused severe emotionally distress 9 MR. PIKE: Same objections. 9 to underage minor females, including isn't 1 A I recognize, I believe she made one of 10 that true? 11 the statements at her deposition after she 1 1 MR. PIKE: Objectiori, argumentative, 12 decided to sue me for a bunch of money and your 12 speculation, it is compound. And it assumes 1 3 firm has represented a number cases of a 1 3 facts not in evidence. 14 scxualiy charged nature that turned out to be 1 4 MR. EDWARDS: Okay. 1 5 frauduient in order to fieece locai investors. 15 A i would iike to answer that question, as 1 6 The US. Attorney described your firm and these 1 6 i would like to answer of your other 17 cases as a bogus scheme, and Pm aware of that, 17 questions today regarding L.M. However, my 18 and would like to answer your question in more 18 attorneys today have advised me thati must 19 detail today, Mr. Edwards; however my attorneys 1 9 assert my Sixth Amendment right to effective 2 advised me that at ieast today, I must assert my 20 representation and my Fifth Amendment right and 2 1 rights under the Sixth Amendment, Fourteenth 2 1 my Fourteenth Amendment right. Though I would 2 2 Amendment and Fifth Amendment. 22 iike to answer that with speci?city, I must 23 MR. PIKE: It is the food. 23 follow my attorney's advice. 2 4 MR. JAFFE: i didn't want him in the 2 4 Will you admit for the jury that you 2 5 room in mid answer. 25 were investigated federally for your illegai 34 (Pages 130 to 133) U.S. Legal Suppoxt (561) 835-0220 134 136 1 activities with underage minors? Graft or Nadia Marcinkova." Can you explain tr 2 MR. PIKE: Same objections. 2 the jury what each of those four individuals did 3 A i would like to answer that question, as 3 for you or conspired with you to do? 4 well as all the other questions you?ve asked me 4 MR. Object to the form of the 5 6 accused by the federal, i guess, the federal 6 A I would like to answer that question, 7 being considered a criminal -- you 7 however, today my attorneys advise me that I must 8 firm has been considered and investigated as 8 assert my Sixth Amendment, Filth Amendment and 9 being a criminal enterprise using sexually 9 Fourteenth Amendment rights under the US. 3. 0 fabricated, sexual fabricated cases, to 3. 0 Constitution. 1 1 fleece investors out of millions of dollars, but 1 1 Isn't it fair to say that you, as well 1 2 i would like to answer your questions; however my 3.2 as the edeonspirators, operated as an organized 3 attorneys have demanded that assert my rights 1.3 criminal enterprise designed to sexually exploit it under the Sixth Amendment, Fifth Amendment and 3.4 underage minors? 5 Fourteenth Amendment. 3.5 MR. PIKE: Object to argumentative, 6 in fact, as a result of that 1 6 speculation. it is vague and it assumes 3.7 investigation, you, as well as the United States facts not in evidence. 3.8 Attorney's Of?ce entered into what has now been 18 A Are you suggesting it was a criminal 3. 9 known and referred to as the nonprosecution 1 9 enterprise? Is that the words? 2 0 agreement; isn't that correct? 2 0 Yes. 2 1 MR. PIKE: Same objection. The document 2 1 A Though would like to answer that 22 speaks for itself? 2 2 question today, 1 think the only criminal 23 A You have to repeat the question. 2 3 enterprise that have been reading about today 2 4 As a result of the criminal 2 4 was your ?rm, that's been accused of being a 25 investigation into your activities with minor 2 5 criminal enterprise involved in defrauding 135 137 1 females, you reached a resolution with the United 1 peeple, using mail fraud, wire fraud, money 2 States Attorney's Office, in what has now been 2 laundering, the operation of the enterprise 3 described as the nonprosecution agreement; is 3 this is by the Attorney (indicating), but 4 that correct? 4 though i would like to answer your questions with 5 MR. PIKE: l?m?going to object. Vague, 5 speci?city today, on advice of counsel, though I 6 confusing, misrepresents the agreement and 6 would like to answer it, they'demanded assert 7 7 8 mark it? 8 Fifth Amendment right or I risk losing their 9 MR. EDWARDS: I can mark it. We will 9 representation. 10 copy it at the end and mark it as Exhibit 2. 10 Did you care about any of the underage 11 (Document, Nonprosecution Agreement, was 11 minor females at the time when you were engaging, l2 deemed marked as Exhibit number 2 for 12 in sexual conduct with them? 1 3 identi?cation, as of this date.) 1 3 MR. PIKE: Objection, argumentative. 14 14 15 In that agreement, there are listed 1 5 Court relative to this exact question. 1 6 co~conspirators of Jeffrey Epstein, those being 1 6 MR. EDWARDS: I feel comfortable with 17? Sarah Kellen, Adriana Ross, Leslie Grafl' 7 the question. it goes to punitive damages. 18 (phonetic) and Nadia Marcinkova. Can you explain 18 The issue related to the Court was a 9 to the jury what those individuals did for you 19 repetitive question on that topic or around 20 related to the crimes that Were investigated by 20 that general so bject matter. l.?rnjust 2 1 the federal government? 2 1 asking for Mr. Epstein to tell the jury how 22 22 2 3 Yes, it says "criminal charges against 2 3 about them, when he was engaging in illegal 2 4 any err-conspirators of Epstein including but not 2 4 sexual conduct with them. 25 limited to Sarah Kellen, Adriana Ross, Leslie 25 MR. PIKE: Counsel, I?m going to 35 (Pages 134 to 137) U.S. Legal Support (561) 835?0220 138 140 1 instruct him not to answer the question. 1 question; however, today my attorneys have 2 You can certify it to the Court, if you 2 advised me I must take assert my rights under 3 like. You know what the answer is going to 3 the Fourteenth, Sixth and Filth Amendments of the 4 a 5 video. You know the Court has already 5 representation. 6 ordered that these types of questions are 6 MR. PIKE: And Mr. Edwards,just so we 7 not permitted because they are argumentative 7 don?t have to come back on the question that 8 and harassing. In fact, other questions 8 I instructed him not to answer, if you would 9 bordered but this question is on exact point 9 go ahead and repeat that question, I will be 10 with the Court's order. If you want to 1 0 more than happy to let him respond. 1 1 withdraw the question, that's fine. 1 1 MR. EDWARDS: I don't remember the 12 MR. EDWARDS: I don?t want to withdraw 32 question we will take it up with the Court 1 3 the question. 13 and we'll get a ruling on it. 1 4 MR. PIKE: Then i instruct him not to 1 4 MR. PIKE: It was whether or not he 1 5 answer. 1 5 cared about these I believe you quoted it 16 MR. EDWARDS: Mark that somehow, that 16 as underage minors, but i would like the page, so we can find it in the record, 1 7 court reporter to read back the question 1 8 relative to the hearing that will be had on 1 8 just to conserve judiciai resources and not 1 9 that question and others similar. 1 9 go back. So if she can reread the question 20 At the time when you were engaging in 20 that would be good. 2 1 sexual conduct with underage females, you knew 2 3. MR. EDWARDS: If you can find the 2 2 that exposing them to this, was not bene?cial or 2 2 question. 2 3 good for these girls; isn't that true? 2 3 THE COURT REPORTER: Certainty. 24 MR. PIKE: Objection, argumentative, 24 MR. EDWARDS: I think i know it. 25 speculation, assumes facts not in evidence. 25 Did you care about any of these underage 139 141 1 Lacks predicate. 1 minor females that you were engaging in sex with 2 A Though I would like to answer that 2 at the time when you Were engaging in these 3 question, iike most of your other questions here 3 sexual activities? 4 today, on advice of counsel 1 must assert my 4 MR. Same objections, as before. 5 5 A 6 Amendment rights. Though I would like to answer, 6 question as well as most of your other questionsrisk losing my effective 7 if not all of your other questions here today, on 8 representation of counsel. 8 advice of counsel 1 will have to assert my 9 Isn't it true, Mr. Epstein, that the 9 Fourteenth Amendment right, my Sixth Amendment 10 oniy thing that you cared about was accessing as 10 right and my Fifth Amendment right, because no 11 many underage females as possible, for the 1 1 matter how much I actually want to answer that 12 purposes of sex? 1 2 question, if I do so I. risk losing my counsel's 1 3 MR. PIKE: Argumentative, speculation, 1 3 representation. 14 harassing. 1d At the time you wore engaging in sexual 15 A What?s the question? 1 5 activity with these underage minors, including 1 6 MR. PIKE: And assumes facts not in 1 6 L.M., you knew that this conduct was 17 evidence. 1 didn't you? 18 Isn't it true that the only thing that 18 MR. PIKE: Same objections. Form. 1 9 you cared about when you were interacting with 1 9 A I wouid like to answer that question, as 2 0 these underage females in a sexual manner, was 2 0 well as most of your other questions here today; 2 1 ejaculating or your own personal grati?cation? 2 1 however, today my counsel has instructed me to 2 2 MR. PIKE: Form, same exact objections. 22 assert my Fourteenth Amendment, Sixth Amendmen 23 A Though I would like to answer that 2 3 and Fifth Amendment right, and if i do not, and 2 4 question, and to the ladies and gentlemen of the 2 4 if, in fact, I answer that question if i can 25 jury, I would very much like to answer that 2 5 answer that question, I potentially risk losing 36 (Pages 138 to 141) U.S. Legal Support (561) 835-0220 142 144 1 my effective counsel?s representation. 3. testimony -- to the FBI. You watched her 2 in fact, you told many of these underage 2 deposition when it was being taken. Which 3 minor females not to teii anybody what happened 3 A You?re making assumptions, I?m sorry. 4 with you in the house, or else they would be in 4 MR. PIKE: Let him finish the question. 5 trouble; isn't that true? 5 THE WITNESS: Sony. 6 MR. Form. 6 A My fault. 7 A Iwouid iike to answer that question, as 7 MR. PIKE: Then Fit object and you'll 8 weli as the other questions; however, my counsei 8 respond. 9 has advised me that today i must assert my 9 Which are you saying is the truthful 0 Fourteenth Amendment, Sixth Amendment and Fifth 3.0 testimony, her statement to the FBI or the 1 Amendment rights under the U.S. Constitution. 11 videotaped deposition that you watched? 12 The underage minor femaies that have 12 MR. PIKE: Object to the form. 13 come forward with information about your sexua 13 A What I've said, and I think l?ii repeat 1 4 interactions with them have been investigated, 3. 4 mysetf is until she joined your firm and started 1 5 harassed, in an effort for you to 1 5 to seek money, her testimony was different. 1 6 intimidate them to go away. Is that true? 1 6 That?s my understanding. 17 MR. PIKE: Objection. Argumentative, 17' Are you denying any sexual invoivement 18 13 manamumomw l9 assumes facts not in evidence. 19 MR. PIKE: Form. 20 A 20 A hdeMwMamwwmaqm?mni 2 1 Sure. Any underage minor female that 2 wouid like to answer it as with most of your 2 2 you engaged in sexua! activity with, that has now 22 questions here today; however, my attorneys have 2 3 pursued a lawsuit against you, isn't it true that 2 3 advised me that I must take that assert my 2 4 you've spent a lot of money and a lot of 2 4 rights under the Sixth Amendment, Fourteenth 25 resources investigating them in an effort to 2 5 Amendment and Fifth Amendment, no matter how muc 143 145 1 intimidate them and hepefuiiy make them go away?.? 1 i would to answer that question, or 2 MR. i?iKE: Same objections. 2 potentialiy risk iosing my counsel. 3 A Ibeiicve your client?s testimony 3 Isn't your game plan with of these 4 changed dramaticain when she joined up with you 4 civil iawsuits that have been ?ied against you, I 5 and your iaw ?rm, accused of fraud, when she 5 to spend as much money as you can to investigate, 6 decided to change her testimony, at least from 6 and harass these young women into hopefully 7 what the statements said, both to the police and "f dropping the lawsuits against you? 8 to the FBI, and decided to seek money. However, 8 MR. PIKE: Objection. Relevance. Move 9 anything above that or beyond that, I'm going to 9 to strike. It is argumentative and 1 0 have to, in fact, assert my Fifth Amendment, 1 harassingdirected by my competent counsel. 1 2 think you know the answer to that question. 1 3 Unfortunateiy, they have told me if i don't, I 3 Yes. 1 a risk losing their representation. 1 4 A (Witness nods.) However, today my 1 5 right, I'll give you a chance here 15 attorneys have advised me I must assert my Sixth 6 since you keep bringing up her statement to the 6 Amendment rights, my Fourteenth Amendment rights 1? FBI as opposed to her sworn testimony for 23 17 and my Fifth Amendment rights. 18 hours under oath in this case. Are you saying 18 You don?t have any remorse for the 19 that the sworn testimony to the was, in fact, 1 9 sexual abuse that you committed against L.M., do 20 thetn?h? 20 you? 2 3. A What i?m saying is, it seems her 2 1 MR. PIKE: Objection. it is 22 testimony has changed dramatically after she 22 argumentative. It is harassing. it is, I 2 3 joined your ?rm, that's all. 2 3 believe, con?ned under the Judge's order 2 41 Okay. Irrespective of her testimony, 2 4 and it assumes facts not in evidence? 25 you've read her testimony and you read her 25 A That being said, I would iike to answer 37 (Pages 142 to 145) U.S. Legal Support (561) 835~0220 146 148 1 that question today, but my attorneys have 1 ?it But as it relates to, obviously L.M. 2 advised me that i must assert my Fourteenth 2 sued you making the allegations that you sexually 3 Amendment rights, my Fifth Amendment rights and 3 molested her from when she was Z3 years old to 4 my Sixth Amendment rights. 4 when she was 16 years old and now you?ve sued he 5 5 6 you? 6 case, and Ijust want to understand what your 7 A Yes, and you and your firm that's been 7 factual basis is, or what evidence you?re using 8 accused of the largest fraud in Florida's 8 to support your lawsuit against L.M., so that the 9 history, described by the U.S. Attorney as a 9 jury can he valuate whether that is evidence of 10 criminal enterprise involved in money laundering, 10 lack of remorse that would go to punitive damages 11 conspiracy to commit one crime excuse me, mail 11 claims that L.M. has against you. 12 fraud, commit conspiracy to commit wire fraud. 12 MR. PIKE: would instruct him not to 1 3 Yes, i sued you, your firm and L.M. 1 3 answer that question, for the same reasons 1 4 Tell the jury 1% stated. 15 15 16 -- the basis for the evidence that you 16 Is it your feeling that because you are have to sapport the allegations in the complaint wealthy and these children are poor, that you are 8 against L.M. 18 entitled to sexually abuse them? 19 MR. PIKE: l?m going to instruct the 19 MR. PIKE: Argumentative. 20 witness not to answer that question in this 20 In speaking about these children, and 21 21 inaudMgIaNL 2 2 currently, as were it, to this particular 2 2 MR. PIKE: Argumentative, Speculation, 23 lawsuit. 23 compound, it?s vague, and it assumes facts 24 MR. EDWARDS: Just so you can rethink 24 not in evidence. 2 5 that position, the lack of remorse goes to 2 5 A In keeping with your ?rm's propensity 4 1 4 9 1 punitive damages, that is an aspect of the 3. for ?ling fellacious (sic), manufactured, 2 case that LM. has against Mr. Epstein. 2 sexually charged cases, based on nothing but thin 3 MR. PIKE: This lawsuit, the current one 3 air, accused by the US. Attorney of the largest 4 Mr. Epstein is noticed for, and the lawsuit 4 fraud in South Florida's history, by 5 in which Mr. Epstein has filed against the 5 manufacturing sexual cases, I would like to 6 former Rothstein, Rosenfeld, Adler, LM. and 6 answer each and every one of your questions, 7 Mr. Brad Edwards, is not proper for this "3 including why i sued you, but today For not going 8 medium -- 8 to be able to. have to simply listen to my 9 MR. EDWARDS: i understand your 9 counsel and assert my Sixth Amendment, Fourteenth 10 pom?on 10 11 MR. PIKE: -- in that regard, I'm going 11 This answer that you keep reciting, 12 to instruct him not to answer any questions 12 about the Rothstein, Rosenfeld, Adler firm 1 3 relative to that lawsuit because of that 3 A You do know who they are, right? 1 4 objection, as well as, it is my 14 you are aware, obviously, that all of 1 5 understanding that Mr. Scarola has set Mr. 1 5 the lawsuits that were filed against you, 16 Bpstein?s deposition, i believe, either 16 including L.M.'s, were filed at least a year early next week or mid~March, on the case of before, or approximately a year before Rothstein, 18 Epstein versus RRA, Rothstein, Rosenfeld and 18 Rosenfeld, Adler had any of these cases; you're 19 Adler, Mr. Edwards, as well as L.M. 19 aware of that, right? 2 0 Therefore when that time approaches, that 2 0 MR. PIKE: Form. 2 1 would be the appropriate time for those type 2 A I do not know when Rothstein Adler got 2 2 of questions, related to that lawsuit. 22 involved in these cases. do know that the 23 MR. EDWA I understand your position 2 3 moment that they did surface, and, in fact, I 2 4 completely, Mr. Pike. 2 4 understand you shared information with all the 2 5 MR. PIKE: Thank you. 2 5 other attorneys that you so that the jury 38 (Pages 146 to 149) U.S. Legal Support (561) 835?0220 5 0 1 5 2 1 should understand that the information 1 your house when she was 13, 14, 15, 16 years 2 gathered according to the U.S. Attorney, by 2 old 3 illegal means, has been shared with all the other 3 A is that a claim? 4 attorneys that you keep representing have fried 4 - she was in your bedroom. You 5 cases against me; yes, I'm aware of that. 5 instructed her to get naked. You inserted your 6 I don't understand that answer. Steven, 6 ?ngers into her vagina. You used a vibrator on 7 do you '7 her. You coerced her into recruiting other 8 MR. PIKE: Do you have a question? 8 underage minor females, roughly 50 or so more. 9 MR. EDWARDS: i want to understand what 9 These are all ciaims that have amounted to his answer was, As in all depositions, if 10 to various counts, coercion, prostitution, 1 1 you don't understand the answer, ciarify the 11 intentional in?iction of emotional distress, 12 answer. 12 battery, committing various crimes against her. 13 MR. PIKE: No, you have to ask a 13 What are your defenses to that? Normal defenses 14 question. 3.4 are "i didn?t do it," "i did it, but it didn't 15 MR. EDWARDS: i did. And he's 15 hurt her," we are trying to understand so we know 16 responding to it. i. 6 how to provide this case to the jury, what are MR. PIKE: The witness has answered the 1 7* your defenses to these allegations? 18 question. Do you have another question to 18 MR. I'm going to object to this 19 ciarify his answer? 19 line of questioning. it is compound; as 2 0 MR. EDWARDS: Yes. 2 worded it could call for disclosure of 21 21 22 MR. PIKE: I will instruct him not to 22 product. i believe in this particular case 23 answer. it's vague and confusing, it?s 23 there is a document tiled, answer in 2 4 narrative. 24 affirmative defenses, and the af?rmative 2 5 MR. EDWARDS: Me saying "clarify your 2 5 defenses are set forth there and the 1 5 1 5 3 1 answer" is narrative? 1 document there speaks for itseif. 2 MR. PIKE: What do you mean by ?clarify 2 MR- EDWARDS: 3 your mama? 3 Respond. 4 MR. EDWAREJS: i didn't hear what he 4 A The document speaks for itseif. 5 said. Say it again so I can hear it. 5 So you agree with the af?rmative 6 MR. PIKE: Would you please read back 6 defenses that were filed in your case? if you 7 what Mr. Epstein just testified to, madam 7' were to testify, we could expect that to be your 8 court reporter. 8 testimony? 9 (The record was read.) 9 MR. PIKE: That?s not what the witness 1 0 MR. EDWARDS: Okay. testified. The witness testi?ed that the 1 MR. it was an answer, a 1 1 document speaks for itself, and again, I'm 12 question -- 2 going to obj act to attorney/ client, work 1 3 MR. EDWARDS: i understand -- i mean I 3 product and instruct the witness not to 1 4 don't understand the answor, but now I know 1 4 answer. 1 the answer. 3. 5 i'm not asking what your legal defense 1 6 MR. PIKE: Okay. 16 is. I'm asking: What is your response to the 17 At this point in time, piease tell the claims? 1 8 iury what is your defense of the ciaims being 18 MR. Same objection. 1 9 asserted against you in this lawsuit by 19 What is your personal response? 2 0 MR. PIKE: i'm going to object. Calis 20 A I would iike to rcSpond to that 2 3. for a legal conciusion. 2 1 question. i wouid like to respond today to that 22 A What are the claims? So since you're 2 2 question; however, today my attorneys have told 2 3 representing L.M., can you tell me what the 2 3 me that I cannot respond. They've asked me to 2 4 ciairns are? 2 4 assort my Fourteenth Amendment, Sixth Amendmen 2 5 Yes, we've gone through it. She went to 25 and Fifth Amendment rights of the U.S. I: 39 (Pages 150 to 153) U.S. Legal Support (561) 835*0220 154 156 1 Constitution, though I would really like to A Did I I would 2 respond. They are telling me if I did so, I will 2 like to answer that question, but today on advice 3 lose risking their representation. 3 of my counsel, I must -- as I have done with 4 I know you've invoked your Fifth 4 mostly each one of your questions, I have to 5 Amendment rights related to many of these 5 assert my Fifth Amendment, Sixth Amendment and 6 questions, but isn't it true you recently 6 Fourteenth Amendment rights under the as. contacted George Rush at The New York Daily News 7 Constitution. 8 and spoke to him about L.M.'s case as well as 8 You were 51 when L.M. was 24, and you 9 several of the other girls, who have claims 9 were interacting with her sexually. Is it your 10 against you? 1 0 testimony that despite the dispai'ity in age you 11 A Who? 1 1 do not consider LM. to be a victim? 12 George Rush, New York Daily News. 12 MR. Argumentative, speculation, 1 3 A Can you repeat the question? 1 3 assumes facts not in evidence. Compound, 14 Didn't you recently, within the last 14 lacks predicate. 1 5 year, contact George Rush of The New York Daily 1 5 A Not only does it contradict your own 1 6 News and discuss these cases that have been ?led 1 6 client?s statements to the FBI under sworn 17 against you and the allegations made by these 1 "l testimony, I would like to answer that questiOn. 18 various females? 18 Hopefully one day I can answer that question, but 19 MR. PIKE: Form. 19 today my attorneys have said I cannot. They 20 A I would like to answer that question, 20 advised me I must assert my Sixth Amendment, 2 1 but unfortunately today my attorneys have advised 2 1 Fifth Amendment and Fourteenth Amendment rights. 22 me I cannot. They've advised me I must assert my 22 In the last ten years, what is the 2 3 Sixteenth excuse me, my Fourteenth Amendment, 2 3 youngest underage minor female that you have 2 4 Sixth Amendment and Fifth Amendment right, so 2 4 interacted with sexually? 25 therefore, i will do so. 2 5 MR. PIKE: Argumentativc, speculationthat you will talk to George 1 a33umes facts not in evidence. 2 Rush about this but you will not talk to the jury 2 A The answer to that questiori is -- I 3 about this? 3 would like to give you an answer to that today, 4 4 5 speculation. Misstates the witness?s 5 Fourteenth Amendment rights, my Sixth Amendment 6 testimony. It assumes facts the question 6 rights and Fifth Amendment rights. assumes facts not in evidence and now lacks 7 Do you know Michael Friedman? 8 predicate. 8 A Doeso?t ring a boil. 9 A So who is George Rush again? 9 Former housekeeper/employee of yours, 10 George Rush, reporter with The New York 10 worked at the Palm Beach house? 1 1 Daily News. Did you not talk to him? If you 1 1 A Could. Don't know. 12 didn't talk to him, tell me that. That's fine. 12 So you would be unable to answer what 13 MR. PIKE: Same objections. 13 Michael Friedman did for youyour questions, however today my attorneys 1 5 Are you aware that our investigator 1 6 have demanded that I respond by asserting my 16 spoke with Michael Friedman, former housekeeper 17 Fourteenth Amendment, Sixth Amendment, Fifth 1'7 for you, or housemanager for you, out in 18 Amendment privilege, though I would like to 18 California? 1 9 respond, but they said if i do so, I rile losing 19 A No. 20 their representation. 20 Any reason why when asked about the 2 1 Didn't you tell George Rush these 2 1 activity that occurred in your house, he would 22 underage minors were not victims at all and that 22 tear up and say, was hoping to forget 2 3 regardless of their age, you did not personally 23 everything I saw"? 2 4 consider them victims? 2 4 MR. Objection, argumentative. 2 5 MR. PI KE: Same objection. 25 Speculative. Assumes facts not in 40 (Pages 154 to 157) U.S. Legal Support (561) 835?0220 158 160 1 evidence. 1 During this civil discovery and 2 2 3 3 A mmMm? 4 A i don?t know who he is. 4 have you paid for, and/or retained an 5 MR. PIKE: Also, hearsay. 5 attorney for any other witnesses? 6 6 A 7? MR. EDWARDS: Go ahead. 7 Yes, iike i?ll give you an example that 8 THE VIDEOGRAPHER: Going off the video 8 you may, just to refresh your recoliection or 9 record 3:23 pm. 9 tell you what I?m talking about, Lowella Rabuyo; 1 (Pause in the proceedings.) 1 0 you know who that is, right? 11 THE VIDEOGRAPHER: Back on the video 11 A Yes. 1 2 record 3:30 pm. 1 2 She is someone to Works for you now, 13 This person that I asked you about, 13 she's a housekeeper. We took her deposition 14 Michael Friedman, is that somebody who has 14 already. At least that's what her testimony 15 contacted you within the last six months? 15 was. 16 A No. 16 MR. PIKE: Form. 17 In taking a break and thinking about 17 A I would like to answer that question but 18 some of these questions, have you remembered who 18 I have to assert my Sixth Amendment, Fourteenth 1 9 that person is, or still no real memory of him at 1 9 and Fifth. 20 all? 20 That somebody who has informed us that 21 A No real memory. 21 you paid for and obtained an attorney by the noon . 22 To the best of your knowledge, he never 22 of Bruce Reinhart to represent her during this 2 3 worked for you? 2 3 process. Is that -- 24 MR. PIKE: Form. 24 MR. PIKE: Form. 2 5 A Not that i can recall, but there are 2 5 A i have to assert my Fifth Amendmentiots of peopie who work for me, 1 Sixth Amendment and Fourteenth Amendment, right. 2 Can you tell thejury who the various 2 Other people that have indicated that 3 people are that work for you now? 3 you retained and paid for an attorney to 4 A i believe I answered that question 4 represent them are Michael Friedman, Louella 5 already. 5 Rabuyo, Janus: Banaziak, Nadia Marcinkova, 6 In that you invoked your Fifth 6 Ghislaiae Maxweii, your brother, Mark Epstein, 7? Amendment, correct? 7 Naley Robson, Sarah Kellen, Larry Visoski, Larr 8 A That?s correct, Sixth Amendment and 8 Morrson, David Rogers, igor Zinoview. Have I 9 Fourteenth Amendment. 9 missed anybody else that during this litigation 10 Eigthteen and twenty-first? 1O you?ve paid for or retained attorneys? 11 A (Witness shrugs.) 1 I MR. PIKE: Form, same objectiou. 12 MR. PIKE: Move to strike. 1 2 A i'm not clear. Are you suggesting l've 13 Have you, during this iltigation, and 13 paid for attorneys for all these people? 14 by "this litigation," I don't only mean 14 Yes. 1 5 case, but the various other lawsuits that have 1 5 A (Laughton) i would iike to answer those 1 6 been filed against you by other females alleging 6 questions today, but on the advice of counsel I 17 sexual misconduct by you against them. Who have have to invoke my Sixth Amendment, Fifth 18 you retained attorneys for, what witnesses have 18 Amendment and Fourteenth Amendment right. 19 you retained attorneys for? 19 If you have not, tell me which of those 2 0 MR. PIKE: Object to the ferm. 2 0 on that iist that you have not paid for or 21 MR. EDWARDS: Okay. 2 it retained attorneys for? 22 MR. PIKE: l?ii instruct him not to 22 MR. PIKE: Same objection. 2 3 answer because I don't understand the 23 A Same answer. 24 question. Okay? 24 You're invoking your Fifth Amendment, 2 5 MR. EDWARDS: All right. 2 5 right? 41 {Pages 158 to 161) U.S. Legal Support (561) 835?0220 162 164 A And Sixth Amendment and Fourteenth 1 If me narrowing down will help you to 2 and Fifth Amendment. 2 respond, I will. Is there any need for that? 3 3 4 personally, that is paying for the attorneys? 4 MR. EDWARDS: Okay. 5 fees related to your representation? 5 THE WITNESS: Sony. 6 MR. PIKE: I?m going to object to the 6 is it your intent to interact sexually 7 form. I?m going to instruct him not to '7 with minors in the future? 8 answer that question based on relevance; and 8 MR. PIKE: Same objection. 9 it is vague also. 9 A i would iike to answer that question, 1 0 Who is writing the check to your 10 but today my counsel has advised me I must invoke 1 attorneys for your representation in this 1 the rights of the Sixth Amendment, the Fourteenth 1 2 iawsuit? 12 Amendment and the Fifth Amendment of the U.S. 1 3 A (No response.) 1 3 Constitution. 14 Who is paying the biil? 14 Are you currently treating with a 15 A I believe I am. 15 related to any sex addiction that 6 And is it you, personally, or is this 16 you have with minors? one of your corporations or companies? 1 7 A I would like to answer that question, as 1 8 MR. PIKE: Form, speculation. 1 8 well, as most ofthe questions you?ve 9 A i'm not sure. 1 9 asked me today; however, on advice of counsel 20 As you sit here today, you?re not really 20 they?ve asked me to invoke my Sixth Amendment, 2 1 sure whether it is coming from one of the other 21 Fourteenth Amendment and Filth Amendment right, 2 2 corporations that we've discovered during 22 therefore, though I would iike to answer that 2 3 discovery or it is coming from you, personally? 23 question, as well as the other ones, I risk 2 4 Is that correct? 2 a iosing the representation if I. do so. 2 5 MR. PIKE: Asked and answered. 25 MR. PEKE: Moreover I?m going to object 163 165 1 A i believe I would iike to answer but 1 to reievance as have in the past since Mr. 2 2 3 Amendment rights. 3 this case; under the legal terms. 4 As it relates to any of the other 4 You would agree, wouldn't you, that you 5 witnesses who have had attorneys retained for 5 targeted these underage giris including LM. 6 them, is it also your response to invoke your 6 because of their young age? 7 Fifth Amendment rights, rather than to provide me 7 MR. PIKE: Argumentative, speculative, 8 with an answer, as to who is paying the bill for 8 harassing. Assumes facts not in evidence. 9 those attorneys? 9 A i would iike to answer that question, as 1 A I wouid like to answer those questions, 10 weii as most of the other questions you've asked 1 1 but today my attorneys have asked me not to 1 me here today. My counsel has advised me that I 12 respond to any questions that may be relevant to 12 must assert my Fourteenth Amendment, Sixth 13 this iawsuit, so i must foliow their advice and 13 Amendment and Fifth Amendment right. Though i 14 invoke the Sixth Amendment, Fifth Amendment and 14 would iike to answer those questions if 1 5 Fourteenth Amendment, rightrisk losing their representation. 16 Have you interacted sexually with any 16 You would aiso agree, wouldn't you, that 17 underage minors in the last year, while on house 17 you targeted these underage females for sex, 1 8 arrest or work release from jail? 18 including L.M., because they were poor? 19 MR. PIKE: Objection. Argumentative and 19 MR. PIKE: Same objections. 2 0 compound and lacks predicate. 20 A i would like to answer that question. I 2 1 A wouid iike to answer that question, 2 1 would realty like to answer that question, as 22 but on advice of counsel, at least today, they?ve 22 well as the other questions you?ve asked me here 2 3 advised me i must invoice my Sixth Amendment, 2 3 today, however, on advice of my ocunsei they've 24 24 2 5 MR. PIKE: it is also overbroad. 25 Amendment and Fourteenth Amendment rights. If I 42 {Pages 162 to 165} U.S. Legal Support (561) 835*0220 166 168 1 answer that question, i risk losing their 1 today; however, my counsel has advised me that I 2 representation. 2 must assert my Fourteenth Amendment rights, my 3 You would agree, wouldn't you, that you 3 Sixth Amendment rights and my Fifth Amendment 4 sexually molested L.M. for three years? 4 rights, and though I would like to answer those 5 MR. PIKE: Same objection. 5 questions, if i do so i risk iosing their 6 A i think you?ve asked me that question 6 representation. '3 before. I assert the same rights as before. 7 THE WITNESS: Can we take a ten-minute 8 That?s the Fifth, Sixth and Fourteenth 8 break for some air? 9 amendments, just so the record is clear? 9 MR. EDWARDS: We have 15 minutes and 1 0 A Yes. 10 we're done. 1 1 You would agree, wouldn't you, that you 1 1 THE WITNESS: Continue then? 12 coerced LM. into prostitution? 12 MR. EDWARDS: Okay. 13 MR. PIKE: Same objections. 13 Would you agree that you intentionally 1 4 A i believe her own testimony reflects, at 1 4 indoctrinated LM. into this very deviant sexual 1 5 least the sworn statement to the FBI, re?ects 1 5 lifestyle? 1 6 that that is not the case; and though i would 1 6 MR. PIKE: Okay, i?rn going to object. 1 ?i like to answer that question in great detail, 1 "i it is argumentative. it is confusing. it 1 8 cannot do so today on advice of counsel, that 8 is speculative, vague, lacks predicate and 1 9 have asked nae to assert rny Sixth Amendment, Fifth 3. 9 assumes facts not in evidence. 2 0 Amendment and Fourteenth Amendment rightsthat, i would like to 2 1 do so, 1 risk losing their representation. 2 1 answer that question, but my counsel has advised 22 You would agree with me that you groomed 22 me i must assert my Fourteenth Amendment, Sixth 23 LM. into becoming a prostitute? 23 Amendment and Fifth Amendment rights under the 24 MR. PIKE: I'm going to object. 24 Constitution. Aithough 1 would like to 2 5 Argumentative, speculative. Certainly lacks 2 5 answer all your questions today, i cannot do so 167 169 predicate and assumes facts not in 1 risking losing their representation. 2 evidence. 2 Would you agree that you were personally 3 A You know I would like to answer that 3 responsible for destroying her life? 4 question, but I can?t today. Under advice of 4 MR. PIKE: Same act objections. 5 counsel 1 havo to assert my Fourteenth Amendment, 5 A Her life? 6 Sixth Amendment and Fifth Amendment rights. If i 6 7 answer the question, 1 risk losing their 7 A would like to answer that question, 8 counsel. 8 and i understand how your ?rm has been accused 9 You would agree, wouldn't you, that you 9 of fabricated sexually charged lawsuits in order 1 0 brainwashed LM. into believing that this 1 to fleece investors locally in South Florida. 1 1 iifestyle of prostitution was right? 11 The US. Attorney has caiied your law ?rm a 12 MR. Same objections. 12 criminal enterprise based on filing feiiacious 13 A i would like to answer that question, as 13 (sic) sexually charged cases. Although I would 1 4 most of your other questions here today, Mr. 1 4 like to answer that question today, Mr. Edwards, 15 Edwards. On advice of counsel today, l'in going 15 and Mr. .laffe, my counsel has told me that i have 1 6 to have to assert my Fifth Amendment, Sixth 1 6 to assert my rights under the Sixth Amendment, f? 18 18 i 9 representation. 1 9 representation. 20 Would you agree that your interaction 20 We have a factual basis for asking every 2 1 with LM. when she was a minor, was degrading to 2 1 question and making every allegation. i want to 22 her? 2 2 provide you with a last opportunity to tell the 2 3 MR. 81KB: Same objections. 2 3 jury which of these allegations, if any, being 2 4 A wouid like to answer that question. i 2 4 made by L.M., are false or fabricated in any 2 5 would like to answer all of your questions here 2 5 way? 43 (Pages 166 to 169) U.S. Legal Support (561) 835-0220 1.70 '172 1 2 Edwards, you know the tenor of that question 2 questions, am going to have to decline based on 3 cannot be answered without waiver ol'Fifth, 3 my counsel?s advice to invoke, at least today, my 4 Sixth and Fourteenth. I appreciate the 4 Fifth Amendment, Sixth Amendment and Fourteentl 5 question and the semantics of it, but it 5 Amendment rights under the U.S. Constitutiou; 6 It is -- can you rephrase it? 6 because if i don?t, I risk losing their 7 MR. EDWARDS: Yes. 7 representation. 8 Many times -- you know the allegations 8 Is it true that you're currently worth 9 now, we've gone through them, allegations 9 more than one billion dollars personally? 10 and assertion of facts as to what happened 10 A would like to answer that question, as 1 between you and Iter when she was 13would like to answer most of your other 1 2 years old and you were 50, 51, 52 years old. 1 2 questions. I know that?s a lot of money -- 13 Several times you responded saying something 13 actually the amount of money that the U.S. 14 about Rothstein, Rosenfeld Adler, something 14 attorneys accused your firm of trying to steal 1 5 about her FBI statement, what have you; I want to 5 from the people of South Florida. It was 1.2 6 give you a chance to tell the gory, which of her 1 6 billion dollars, the U.S. Attorney claimed your 1 7? allegations, if any, that you believe now are 1 "i firm perpetrated the largest fraud in South 1 8 false or fabricated in any way. 1 8 Florida's history by stealing that sum of money 1 9 MR. PIKE: Same objections. 1 9 from local investors, basod on false allegations 2 0 A I would like to respond to that 2 of sexually charged claims, and although I would 2 1 question, the fact that her ?rm, the law firm 2 1 like to answer these questions with speci?city, 22 representing her has been accused by the U.S. 2 2 under advice of counsel today, I'm going to have 2 3 Attorney of being a criminal enterprise, 2 3 to refuse, based on my Sixth Amendment, 24 24 2 5 cases involving sexual allegations, sexual 2 5 and though i would like to answer the question, I 7 1 3 1 allegations in order to simply fleece local 1 have been told if i do so risk losing their 2 investors out of millions of dollars, so i would 2 representation, Mr. Edwards. 3 very much like to answer that question regarding 3 I'm simply asking: What is your 4 the truthfulness of L.M.'s allegations; however 4 personal net worth at this time? 5 5 6 ii and Fourteenth Amendment rights under the U.S. 8 Constitution, though i would very much like to 8 What is your personal net worth at this 9 answer that questions but if I do i risk losing 9 time? So the answer should be a number or shoult 3. 0 their representation. 1 0 be you invoking your Fifth Amendment rights. 1 3. Would you agree you owe L.M. at least 11 Seemed like the opposite. 12 $15,080,000 to compensate her for the damage 12 MR. PIKE: Asked and answered, he did 13 which you have caused? 13 invoke his Fifth, Sixth and Fourteenth. 14 MR. Objectiori. lrnove to 14 MR. EDWARDS: His answer included 1 5 strike. Argumentative. Compound. Lacks 1 53 something about Rothstein, Rosenfeld and 1 6 substantial predicate. 1 6 Adler stealing some certain amount of money, 1 7 not in evidence. which obviously is nonresponsive, I move to 18 18 9 firm has been accused of perpetrating a fraud 1 9 to the question with something that?s 20 involving millions and millions of dollars, on 20 responsive. He can answer the question, 2 1 unsuspecting investors here in South Florida, 2 1 invoke Fifth Amendment rights, and we will 2 2 millions of dollars by fabricating similar 2 2 get out of here. 2 3 allegations, convincing people to give money to 2 3 We will start over again. 2 4 the ?rm that helped bring this lawsuit, Put 2 4 Can you please tell the jury what your 2 5 afraid i would like to answer those questions but 2 5 current personal net worth is currently? 44 (Pages 1?0 to 173) U.S. Legal Support (561) 835~0220 174 176 1 A I would like to do that today, however, 1 "though i would like to answer with speci?city, .2 For sure that one of the reasons, since your ?rm 2 however if I do so, I risk losing their 3 has been accused of stealing millions of dollars 3 representation so I must assert my rights under 4 from local investors based on fabricated, totally 4 Sixth, Fifth and Fourteenth Amendment. 5 fabricated claims, this Isn't it true, Mr. Epstein, that as long 6 Attorney, has called your ?rm a criminal 6 as you have the money to do it, you will continue enterprise charged with stealing hundreds of "i to engage in sex with minors? 8 millions of dollars frankly, from local 8 MR. PIKE: Again, extremely 9 investors, based on false claims of sexually 9 argumentative, speculative. l'm allowing 1 0 charged nature, 1 would like to answer that 1 the question to give leeway, so we don't 1 1 question in detail. However, my attorneys have 3.1 have to come back here again. it is 12 advised me I cannot answer any questions that may 12 harassing. 1 3 be relevant to this lawsuit and by doing so, I 3 A And with that, For sure this ladies to must invoke my Sixth Amendment, Fifth Amendment. 14 and gentlemen ofthejury, be able to see 1 5 Fourteenth Amendment right and by answering the 5 you and your partner, who your firm has been 1 6 question, risk losing their representation. 1 6 accused of massive hand in South Florida trying 1 "i is it true you're worth 1.8 billion 17 to steal hundreds of millions of dollars from 18 dollars? 1 8 local investors, from creating, fabricating 19 MR. l?lKE: Same objection. 19 malicious, sexually charged claims, cailed by the 20 A Same answer. 2 0 U.S. Attorney a criminal enterprise charged with 2 1 Put the answer. 2 1 money laundering, conspiracy to commit other -- 22 MR. PIKE: For the record. 22 federal violations, so though I would like to 2 3 A I?m sure that?s an interesting question 2 3 answer that question, Mr. Edwards, and Mr. .laffe, 2 4 and l. would like to answer that question for 2 4 today, i cannot. I must invoke my Sixth, Fifth 2 5 you. i'm sure you would like to know as your 2 5 and Fourteenth Amendment rights, on advice of 175 177 1 ?rm has been charged with stealing over a 1 counsel or risk losing their representation. 2 billion dollars from local investors and your 2 Am I correct in my understanding that 3 senior partner of both you and Mr. Jaffe sitting 3 you haVe invoked your Fifth Amendment rights 4 there shaking his head, sits in jail accused of 4 because your answers would incriminate you and 5 fleecing local and foreign investors based on 5 lead to your prosecution? 6 false sexual claims from people. And although 6 MR. PIKE: I?m going to 7 would like to answer that question, like I would 7 MR. EDWARDS: Exactly as phrased by Mr. 8 answer most of your other questions, my counsel 8 Luttier to L.M. i did not say anything but 9 has advised me today, ladies and gentlemen of the 9 allow her to answer the question. 10 jury, i cannot answer that question. Maybe I can 10 MR. PIKE: Object to the form. 11 in the future. However, if I do so today, I risk 3. 1 A in iiact, since you are a lawyer I?m sure 12 losing their representation, so i must assert 1 2 you?re aware the Supreme Court has said the Fifth 13 those rights under the Sixth, Fifth and 1 3 Amendment is used more often to protect innocent 1 4 Fourteenth amendments. 14 people. So that's but today on advice of 15 You would agree, would you not, that it 15 ocunscl I've taken that right. 1 6 would take a jury award of at least 45 million 16 MR. EDWARDS: (Gesturing) 17 dollars in punitive damages to punish you for 17 MR. PIKE: have no questions. 1 8 doing what you did to 1 8 We will read. 1 9 W. Same objections. 1 9 MR. EDWARDS: No further questionswould like to answer all your other and Mr. 2 1 3:52 pm. 2 2 Jaffe?s questions today. However, while he sits 22 THE COURT REPORTER: can he read 23 shaking his head in} going to have to respond 23 copy Mr. Pike? 2 4 to -- my counsel has advised me i cannot answer 24 MR. PIKE: Yes. 25 that question today, though i would like to. 25 THE COURT REPORTER: Thank you all. 45 (Pages 174 to 177) U.S. Legal Support (561) 835-0220 178 180 1 MR. PIKE: On the record, I don't want a 1 THE STATE OF FLORIDA) 2 word index, 2 COUNTY OF PALM BEACH) 3 rnacouaranronren:onw. 3 4 (Discussion off the record.) 4 . 5 5 6 pfease- 6 acknowledged before me this . 7 day of 2009, by TERRI "i Let 5 go reguiar but de?nitely before . 8 BECKER, who IS personally known to me. 8 that -- before Tuesdaypercent expedite? 1 1 3. 1 MR. PIKE: That's ?ne. 12 1 2 THE COURT My pleasureNotary Public, State of Florida. 1 6 6 My commission No. 17 Expires March 13., 2011FLORIDA) 1 i, JEFFREY EPSTEIN, do hereby 2 COUNTY OF PALM BEACH) 2 certify that I have read the foregoing transcript 3 1: TERRI BECKER: a RegiSiered 3 of my deposition given on February 17, 2010; that 4 meeSSional {er and PUblic for the 4 together with the correction page attached hereto 5 State of Fiorida at Large, do hereby certify that 5 notng Changes in form or substance, if any, it 6 I reported the videotaped deposition of JEFFREY 6 is true and correct. 7 EPSTEIN, the DEFENDANT, caiied by the PLAINTIF 7 8 in the above-entitied action; that the witness 8 9 was duiy sworn by me; that the foregoing pages, 10 numbered from 1 to 183, inclusive, constitute a JEFFREY EPSTEIN 1 1 true record of the deposition by said witness. 9 12 i further certify that i am not attorney 10 1 3 or counsel of any of the parties, nor a relative 3- 1 4 or employee of any attorney or counsei connected 12 15 13 1 6 the action. 1 4 I do hereby certify that the deposition 17 WITNESS MY HAND and official seat is the 15 EPSTEIN was submitted to the witness 1 8 City of West Paim Beach, County of Pain: Beach, 1 6 for reading and Signing; that after he had stated 1 9 State Of Florida: this 22nd day 0? February 2010' 17 to the undersigned Notary Pubiic that he had read 2 18 and examined her deposition, he signed the same 2 1 TERM BECKER, Registered It 9 in the presence of the undersigned authority on Professional Reporter and 2 the day Of 2010' 22 Notary Pubiic, State of Florida 21 at Large. My Commission expires 22 23 Marehi3,2011(Pages 178 to 181) U.S. Legal Support (561) 835*0220 182 ERRATA SHEET 2 In Re: LM. V. EPSTEIN 3 DO NOT WRITE ON TRANSCRIPT ENTER CHANGES HERE: 4 5 PAGE LINE CHANGE REASON JEFFREY EPSTEIN 1 6 7 8 THE STATE OF FLORIDA) 19 COUNTY OF PALM BEACH) 2 0 I DO HEREBY CERTIFY THAT JEFFREY EPSTEIN appeared before me and stated that he has read 2 1 his deposition; further, that this Errata Sheet was signed in my presence on this day U.S. LEGAL Registered Professional Reporters 2 444 West Railroad Avenue Suite 360 3 West Palm Beach, Fioricia 33402 (561)835-6220 4 February 22, 2910 5 6 BURMAN, CRITTON, LUTTIER COLEMAN 303 Banyon Boulevard 7 Suite 400 West Palm Beach, Florida 33401 8 MICHAEL PZKE, ESQ. 9 In Re: LM. V. EPSTEIN 1 0 Deposition of: 3EFFREY EPSTEIN 1 1 2 Dear Mr. Pike: 1 3 Since counsel have agreed that you may 1 <1 have the witness read and sign your copy of the deposition, for your convenience, enoiosed 1 5 herewith you ?nd an Errata Sheet for the witness' use in entering any changes to {he 1 6 deposition. Thank you for your prompt attention. 1 8 Cordially yours, U.S. LEGAL SUPPORT 1 9 2 0 BECKER, Registered 2 1 Professional Reporter, Notary Public, State of Florida at 22 Large. My commission expires March 13, 2011. 2 3 CC: Bradley Edwards. 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2011179:23 180:16 183:22 222:13 183:4 22nd179:19 23158:9 29132:3 3 32:16 158:9,12 17?:21 30158zl2 30053:25 183:2 3033:21 183:6 333013:18 334013:22 183:3 183:7 352:8 65:20 3824:9 4 42:5 178:13 4003:21 183:7 4174:6 4253:1? 44 65:23 4443:5 183:2 45175:16 4824:13 49112:2 5 52:15 5012zl 117:16 122:21 123:? 132:6 152:8 178:12 118:10 502008ca028051 1:3 51156:8 170:12 521?8:12 177:21 52428203:18 5613:22 183:3 6 612:13 7 8 8174:17 8350220183z3 84228203:22 87page74:1 9 9543:18 U.S. Legal Support (561) 835~0220 DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISP TED FACTS Epstein v. Edwards, er a1. Case Na: 50 2009 CA ATTACHMENT 6 336 JANE DOE, VS. UNITED STATES DESTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. Plaintiff, JEFFREY EPSTEIN, at al., Defendants. Related Cases: 08~80119, O9w8m591, 08~80232, 08~8081l, O9m80656, 08w80380, 09?80802, VOLUME 08~80381, 09~80469, 09~81092 CONTINUED VIDEOTAPED DEPOSITION DATE: April 14, JEFFREY EPSTEIN TAKEN ON BEHALF OF THE PLAINTIFF 2010 0.8. Legal Support (561) 835-0220 337 339 1 April 14, 201i} 1 APPEARANCES (CONTINUED) 2 2 ORS ECK 3 WITNESS DIRECT CROSS REDIRECT RECROS 3 Attorneys for?Jane Docs I and 3 4 JEFFREY City National Bank Building, Suite 88 5 BY MR. HOROWZTZ 340 4 25 West Flagler Street 6 BY EDWARDS 4?3 Miami, Florida 5 Tel: (954) 463-4346 BY MS- EZELL 531 BY: KATHERINE w. EZELL, ESQ. 6 9 7 EXHIBITS BURMAN, LUTTIER COLEMAN, L2. 10 8 Attorneys for Defendant Jeffrey Epstein 303 Banyon Boulevard, 9 Suite 400 1 FOR ZDENTIFICATION PAGE West Palm Beach, Florida 33401 12 2 Multi~page document. 34 l. 1 0 (561) 8424820 3 3 Multi-page doeument. 349 1 MICHAEL ESQ 1 4 4 Multi-page document. 359 1 2 5 5 Matti-page document. 369 3 6 6 Matti-page document. 378 4 ALSO PRESENT: 7 7 Mnlti?page document. 384 JOE ROWER Videogmpher 18 8 Multi~page document. 391 15 (US, Legag) 1 9 9 Order form from Amazon.com, 1 6 listing three booksThe continued videotaped deposition of 1 2 JEFFREY EPSTEIN in the above-entitled and 2 1.3 I 3 numbered cause, was taken before me, TERRI 3 be, 4 . BECKER, a Registered Professionai Reporter and mg em cc er ?St Swom t0 t3 5 Notary 1?ublic for the State of Florida at Large, 4 the whole truth, as hereinafter certified, i gt :aiIiroag Azegue, in tile gtysoit?t?efst 5 testified as follows: am eae, am eac ouny,m 8 Florida, beginning at the hour of 10:22 o'clock 6 CONTINUED DIRECT EXAMINATION 9 am, pursuant to the Notice and Adjournment in 7 BY MR. HOROWITZ: 1 behalf of the PLAINTIFF the above?entitled . . . . 12 action pending in the abovewname? com- 9 continuing your deposmon from Part One which 1 3 The appearances at said time and place 1 0 was ta ken on March 8, 2010? 1 4 were as follows: 1 1 A Yes. 15 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS PL 12 When we were together on March 8th, you 16 Attomeys for Plaintiffs Jane Does, 13 told us at that time that you were on probation LN. and EW. 14 in the State of Florida. Is that stiil the 1 7 425 North Andrews Avenue 15 ca c9 smez 5' 1 a Fort Lauderdale, Florida 33301 1 6 A Yes- T311 (954) 5244320 17 I believe you also told us part of the 19 BY: BRADLEY J. EDWARDS, ESQ, 18 20 term 0 your sentence was that you were not MERMELSTEIN HOROWITZ, PA. 1 9 aiiowed unsupervised contact with anyone under 2 1 Attorneys for Plaintiffs Jane Doesthat still the case? numbers 2 through 18205 Biscayne Boulevard Suite 2213 2 2 At that time, you told us that you're 2 3 Miami, Florida 33130 2 3 restricted from possessing pornographic Tel: (305BY: ADAM D. HOROWITZ, ESQ. material. Is that still the case. 2 5 2 5 A Yes. 2 (Pages 337 to 340) .U.S. Legal Support (561) 835-0220 341 343 1 At that time you told us you were a 1 Fifth Amendment. 2 registered sex offender in the State of Florida. 2 isn?t it try neither you or anyone you 3 is that still the case? 3 know has facts to support your contention that 4 A Yes. 4 ML. consented to and was a willing participant 5 At that time you told us you lived at 5 in the acts alleged? 6 358 El Brillo Way. Is that still the case? 6 MR. PIKE: Form. 7 A On advice of counsel, sir, I'm going to . "i A As you know i. would really like to 8 have to invoice my Sixth, Fifth and Fourteenth 8 answer that question, but at least today, I 9 Amendment rights. 9 cannot. i am going to have to invoke my rights 10 l'm going to hand you a document which 10 on advice of counsel under the Filth, Fourteenth 11 we will mark as Exhibit 2. We had marked Exhibit 1 1 and Sixth Amendment. 12 1 at our first session. 12 Okay, moving down to paragraph two, it 13 (Multhpage document was marked as 3 says, in part, "as to all counts alleged 14 l?laintifi?s Exhibit number 2 for 14 plaintiff ML. actually consented to and 15 identi?cation, as of this date.) 1 5 participated in conduct similar andfor identical 16 (Handing) 3.6 .to the acts alleged with other persons, which 17 I'm going to ask you to please turn to l? were the sole or contributing cause of 18 page 6. Turn to where it says "Af?rmative 18 plaintiff?s alleged damages." 19 Defenses." Do you see where we are? 19 My question for you is, what facts are 2 0 A Yes. 2 0 you aware of to support your contention that ML. 2 1 Paragraph one, under the words 21 consented to and participated in conduct similar 22 "Affirmative Defenses" says "As to all counts, 22 to andfor identical to the acts alleged in this 2 3 plaintiff actually consented to and was a willing 2 3 lawsuit? 2 4 participant in the acts alleged, and therefore 2 4 MR. PIKE: Form. 2 5 her claims are barred or her damages are required 2 5 A Unfortunately i would like to answer 342 344 1 to be reduced accordingly." This I'll tell you 1 each of your questions here today, Mr. Horowitz, 2 was filed in the case of do you understand - 2 but on advice of counsel, at least today, I have 3 that? 3 to assert my rights under the Fourth, Fifth and 4 A Yes. 4 Sixth Amendment. 5 Have you seen this document before? 5 Isn't it true, sir, that you that this 6 A Not to my recollection, no. 6 contention that ML. consented to or participated 7 This statement that plaintiff ML. 7 in conduct similar to the acts alleged in this 8 actually consented to and was a willing 8 lawsuit with other persons? That's a false 9 participant in the acts alleged; is that a true 9 statement; isn't that true? 10 statement? 10 MR. PIKE: Form. 11 M. A 1 2 answer each one of your questions, out You going 12 the answer to most of these questions. would 1 3 to have to, on advice of counsel, invoke my 1 3 like to give them, but however, at least today on 1 4 rights of the Sixth, Fifth and Fourteenth 1 4 advice of my counsel I have to assert my rights 1 5 Amendment. 15 under the Sixth, Fourteenth and Fifth Amendment. 16 What facts do you have to support this 16 isn't it true, sir, you're not aware of contention here that plaintiff ML. actually who has facts anyone to support the statement 18 consented to and was a willing participant in the 18 that ML. consented to and participated in 9 acts alleged? 19 similar or identical acts with other persons? 2 0 MR. PIKE: Form. 20 MR. PIKE: Form. 2 3. A Though I would like to answer each and 2 A Though I would like to answer that 2 2 every one of your questions here today, Mr. 22 question, as i would like to answer all of your 2 3 Horowitz, unfortunately today on the advice of 23 questions, at least today my counsel has advised 2 4 counsel, i will have to refuse to answer and 2 4 me that i must assert my rights under the Sixth, 2 5 invoke my rights under the Sixth, Fourteenth and 2 5 Fifth and Fourteenth Amendments. 3 (Pages 341 to 344) U.S. Legal Support (561) 8350220 345 34'? 1 Sir, please turn to paragraph three of was not 18 years old at the time of the alleged 2 defendant Epstein's first Amended Answer and 2 acts? 3 Af?rmative Defenses. 3 MR. PIKE: Form. 4 4 5 Yes, paragraph th rec. 5 question, as I would like to answer every 6 A Okay. 6 one of your questions here today, on advice of 7 Do you see it says "As to all counts 7 counsei E'm going to have to assert my rights 8 plaintiff impliedly consented to the acts aiieged 8 under the Sixth, Fi?h and Fourteenth Amendment, 9 by not objecting." 9 sir. 3.0 My question for you is, what facts do 10 Mr. Epstein, what facts are you aware of 3, 1 you have to support your contention that 1 to support your contention that ML. had attained 12 plaintiff ML. imptiediy consented to the acts 12 the age of 18 years old at the time of the 3 alieged by not objecting? 1 3 alleged acts? 1 4 MR. PIKE: Form. And all of these 14 MR. PIKE: Same objection. 15 questions call for a legal conclusion, as 15 A Though I would like to answer that 1 6 welt. 6 question, Mr. Horowitz, I'm going to have to A Though I would like to answer that 17 respond the some way I've reSponded to all of 18 question, as I would like to answer all of your 18 your questions here today; by asserting my rights 1 9 questions here today, on advice of my counsel, 19 on advice of counsel under the Sixth, Fifth and 20 I?m going to have to assert my rights today of 20 Fourteenth Amendment. 21 21 22 Isn?t it true, sir, that you?re not 22 believe that ML. was 18 or older at the time of 2 3 aware of any facts to support your contention 23 the acts alleged? 24 that the plaintiff, M.L., consented to the acts 24 MR. PIKE: FormCan you repeat the question, I'm sorry? 2 my counsel i'm going to have to assert my rights 3 Isn't it true you're not aware of any 3 under the Sixth, Fifth and Fourteenth Amendment. 4 facts to support this contention that ML. 4 Turning to paragraph ?ve of your 5 consented to the acts alleged by not objecting? 5 Amended Answer to M.L.'s lawsuit, it says: "As 6 MR. i?iKE: Form. 6 to all counts, plaintiff?s claims are barred, as A At least today, Mr. Horowitz, i?m going 1? she said she was 18 years or older at the time." 8 to have to assert my rights under the Sixth, 8 Now, Mr. Epstein, that's not a true 9 Fifth and Fourteenth Amendment not to answer that 9 statement, is it? 10 question, though I would titre to. 10 MR. PIKE: Form. 1 1 [Sn't it true, sir, you?re not aware of 1 A I would like to answer every one of your 12 anyone who has facts to support the contention 12 questions with respect to M.L., however, at least 13 that NLL. consented to the acts alleged by not 13 today, Mr. Horowitz, i'm going to have to assert 1 4 objecting? 14 my rights under the Sixth, Fifth and Fourteenth 5 MR. PIKE: Form. 3. 5 Amendment on advice of my counsel. 1 6 A Mr. Horowitz, i would like to answer 16 Mr. Epstein, ML. never told you she was 17 your question but at {east today, under advice of 17 18 years of age or older; isn?t that true? 18 counsei, have to assort my rights under the 18 MR. PIKE: Form. 1 9 Sixth, Fifth and Fourteenth Amendment. 19 A Though I wouid iike to answer every 2 0 Turning to paragraph four, immediately 2 0 question regarding M.L., at ieast today I have to 2 1 following the It says "Defendant 2 1 assert my rights under the Sixth, Fifth and 2 2 reasonabiy believed or was told that plaintiff 22 Fourteenth Amendment, sir, under advice of 2 3 had attained the age of 18 years old at the time 2 3 counsei. 24 of the alleged acts"? Isn?t it true, sir, that's 24 Mr. Epstein, you've had a chance now to 25 not a true statement, is it? You knew that ML. 2 5 review the Af?rmative Defenses one through ?ve 4 (Pages 345 to 348) U.S. Legal Support (561) 835*0220 349 351 ii 3, which were filed on your behalf in this lawsuit. 1 paragraph one it says, "As to all counts, 2 Do you have any facts to support the contentions 2 plaintiff actually consented to and was a willing 3 in any of those Af?rmative Defenses? 3 participant in the acts alleged." Do you see 4 MR. PIKE: Form. 4 that portion of paragraph one? 5 A At least today I?m going to have to 5 A Yes, sir. 6 respond by asserting my rights under the Sixth, 6 The statement here that the plaintiff, 7 Fifth and Fourteenth Amendment, on advice of 7 Jane Doe number 3 consented to and was a willin 8 counsel. 8 participant in the acts alleged; that's not a 9 I wiil take back Exhibit 1 pardon me, 9 true statement, is it? 10 Exhibit 2, and I'm going to hand you what we will 10 MR. PIKE: Form. 1 1 mark as Exhibit 3. 11 A Who is Jane Doe 3? 12 (Multhpage document was marked as 12 You don't know who Jane Doc 3 is? 1 3 I?laintift?s Exhibit number 3 for 13 A I do not. Don?t you? 14 identi?cation, as of this date.) 14 I do, I?ll pull up the list here. There 15 i?m going to hand you and your 15 are a number of cases, as you're aware. 3. 6 attorney 6 Off the record for a second.) 17 MR. HOROWITZ: i have extras. THE VIDEOGRAPHER: Off the video record 18 defendant Epstein's First Amended 18 at 10:35 am. 1 9 Answer and the Affirmative Defenses to I 9 (Pause in the proceedings.) 20 plaintiff's Second Amended Complaint. Do you see 20 THE VIDEOGRAPHER: Back on the video 2 1 that in front of you? 2 1 record l0:40 am. 22 A Yes, sir. 22 Mr. Epstein, Y.L. is Jane Doe 3. You 2 3 Rave you seen that before? 2 3 have in front of you the Amended Answer and 24 A No, sir. 24 Af?rmative Defenses tiled in response to Jane 25 I'm going to ask yen to turn to page 6, 2 5 Doc 3's lawsuit? 350 352 1 the page numbers are at the topYes, sir. 2 the words "Affirmative Defenses"? 2 We marked that as Exhibit 3. Turning to 3 A Yes, sir. 3 af?rmative defense paragraph number one, do yo 4 Paragraph one includes the following 4 see where it says "l?laintit?f actually consented 5 statements 5 to and was a wilting participant in the acts 6 MR. PIKE: Can we -- it appears that 6 alleged" in paragraph one; do you see that? 7 paragraphs one through ?ve are the same. MR. PIKE: Form. The document speaks 8 Would that be correct, as the ones youjost 8 for itself. 9 previously read? 9 Do you see where I'm pointing you to? I 1.0 MR. HORQWITZ: Yes. 10 want to make sure we are on the same page. 1 1 MR. PIKE: Do you want to stipulate that 11 A Yes, do. 1 2 the answers would be the same and the 12 The statement that Jane Doe number 3, 3 invocations 0f the Fifth, Sixth and 13 Y.L., consented to and was a willing participant 1 4 Fourteenth would be the same? as weli as my 3. 4 in the acts alleged; is that a true statement? 15 ?nne?a?mm? 15 6 MR. HOROWITZ: Well, I need to ask the 1 6 A Mr. Horowitz, I would like to answer 1 7 questions as to each client. every question about Y.L. here today, however on 1 8 MR. PIKE: So, you do not want to 18 advice of counsel they've instructed me to assert 1 9 stipulate to that? 1 9 my rights under the Sixth, Filth and Fovrteenth 2 0 MR. HOROWITZ: l'li stipulate that you 2 0 Amendment. 2 have a standing obiection, but I need to ask 2 1 Mr. Epstein, what facts do you know of 2 2 the questions and get them on record. 2 2 to support the statements that Y.L. actually 2 3 MR. PIKE: All right, we will just go 2 3 consented to and was a willing participant in the 2 4 through it. Okay. 24 facts alieged? 2 5 As to Jane Doc 3, do you see in 25 MR. PIKE: Form. 5 (Pages 339 to 352) U.S. Legal Support (561) 835?0220 353 355 1 1 2 MR. PIKE: Form. 2 regarding your client, Y.L., on advise of my 3 A I would like to answer every question 3 counsel, at Ieast today I must assert my rights 4 about Y.L., however, at least today on advice of 4 under the Sixth, Fifth and Fourteenth Amendment. 5 counsel, they?ve instructed me that I must assert 5 Turning to paragraph three of your 6 my rights under the Sixth, Fifth and Fourteenth 6 Af?rmative Defenses, it says "i?Iaintiff Y.L., 3? Amendment. "i impliediy consented to the acts alleged by not 8 Isn't it true, sir, you are not aware of 8 objecting." Do you see that? 9 anyone who has facts to support the statement 9 A Yes. 1 0 that Y.L. consented to and was a willing 3. 0 The ?rst part of that sentence? 1 participant in the acts alleged? 1 A Yes, sir. 12 MR. PIKE: Form. 1 2 That's not a true statementwould Iike to answer every question 1 3 sir? 1 4 about Y.L., however, today under advice of 1 4 MR. PIKE: Form. 1 5 counsel, I cannot. They?ve instructed me to 1 5 A Though I would like to answer every 3. 6 assert my rights under the Sixth, Filth and 6 question about every single question, 17 Fourteenth Amendment. unfortunately today my counsel has advised me 1 8 Turning to paragraph two, it says: 18 that I must assert my rights under the Sixth, 19 "Plaintiff, Y.L., actually consented to and 19 Fifth and Fourteenth Amendment. 2 participated to conduct similar andl?or identica 2 0 Sir, what facts do you have to support 2 1 to acts alleged with other persons, which were 2 3. your contention that Y.L. impiiediy consented to 2 2 the soie or contributing cause of piaintiff's 22 the acts alleged by not objecting? 23 alleged damages." Sir, that's not a true 23 MR. PIKE: Form. 2 4 statement, is it? 2 4 A Though I wouid like to answer every 25 MR. Form. 2 5 question about Y.L. that you pose here todayabout Y.L. today, Mr. Horowitz, however, on 2 counsel advised me that I must assert my rights 3 advice of counsel, they?ve instructed me I must 3 under the Sixth, Fifth and Fourteenth Amendment. 4 assert my rights under the Sixth, Fifth and 4 Isn't it true, sir, you're not aware of 5 Fourteenth Amendment. 5 anyone who has facts to support your statement 6 Mr. Epstein, what facts do you know of 6 that Y.L. in: pliedly consented to the acts alleges 7 to support the statement that Y.L. actually by not objecting? 8 consented to and participated in conduct similar 8 MR. PIKE: Form? 9 andfor identical to the acts alleged with other 9 A Mr. Horowitz, I would like to answer 1 0 persons? 1 0 every question about Y.L., i really would. 1 1 MR. PIKE: Form, and once again this 1 1 However, today my counsel has advised me that I 1 2 line of questioning calls for a legai 12 must assert my Sixth, Fifth and Fourteenth 13 conclusions, as well as work product 1 3 Amendment rights. 14 information. 1 4 Turning to paragraph four of your 15 A Though i wouid iike to answer each and 15 Affirmative Defenses, Mr. Epstein, it says "As t) 1 6 every question about Y.L., today unfortunately my 1 6 all counts, defendant reasonably believed or was counsel has advised me I must assert my rights told that the plaintiff had attained the age of 18 under the Sixth, Fifth and Fourteenth Amendment. 18 18 years old at the time of the alleged acts." 19 19 20 anyone who has facts to support the contention 20 MR. PIKE: Form. 2 1 that Y.L. consented to and participated in 2 A i would like to answer every question 2 2 conduct similar andfor identical to the acts 2 2 about YL. that you've posed here today. 2 3 alleged with other persons? 2 3 However, on advice of my counsel, I must assort 23 MR. PIKE: Form. 2 4 my rights under the Sixth, Fifth and Fourteenth 25 A Though i would like to answer every 2 5 Amendment, at least today. I 6 (Pages 353 to 356) U.S. Legal Support (561) 835*0220 H.- 357 359 1 1 2 you knew that Y.L. was under the age of 18 when 2 I'm going to hand to you the answer and 3 she came to your home; isn't that true, sir? 3 Af?rmative Defenses, Amended Answer and 4 MR. PIKE: Form. 4 Af?rmative Defenses that you filed in the 5 A i would like to answer every question 5 lawsuit ?ied by do you have that in front 6 about Y.L. However, at least today my counsel 6 of you? Jane Doe number 4. has advised me i must assert my rights under the 7 A Yes, sir. 8 Sixth, Fifth and Fourteenth Amendment. 8 i'll ask you to turn to page 6 where 9 Isn't it true, sir, that you had no 9 you'll see the words "Affirmative Defenses" near 10 reason to believe that Y.L. was under 18? 10 the top of the page? 11 11 12 A Can you repeat that question? 12 MR. HOROWITZ: Correct, Exhibit 4. 1 3 Glad you asked. Isn?t it true, sir, you 13 (Muiti-page document was marked as 4 had no reason to believe that was 18 years 1 4 Piaintiff?s Exhibit number 4 for 15 old or older? 1 5 identi?cation, as of this date.) 1 6 MR. PIKE: Form. 1 6 THE WITNESS: Can we take a two?second 1 "i A i would like to answer every question 1 7 break?? 18 about Y.L., and her the question youjust 1 8 MR. HOROWITZ: Sure. I 9 asked, however at ieast today, my counsel has 19 THE VIDEOGRAPHER: Off the video recor 2 0 advised me that i must assert my rights under the 2 0 at 10:48 am. 2 1 Sixth, Fifth and Fourteenth Amendment. 2 1 (Pause in the proceedings) 2 2 Isn't it true, sir, that Y.L. never told 2 2 MR. HOROWITZ: Back on the record. 2 3 you that she was under the age of 18? 2 3 THE VIDEOGRAPHER: Back on the video . .24 A Fonn. 24 1emndi?49anm 25 MR. PIKE: Form. 25 Do you have the Af?rmative Defenses in 358 360 1 MR. HOROWITZ: Strike that. 1 front of you, and the answer you ?led in the 2 Isn't it true, sir, Y.L. never told you 2 VIZ. case, correct? 3 she was 18 years or older? Isn?t that true, 3 A That?s correct. 4 sir? 4 Paragraph one includes the following 5 A i would like to answer every question 5 statement: "As to all counts, piaintiff v.2. 6 you have today regarding and what she told 6 actually consented to and was a willing 7 me. However, today my counsel has advised me] 7' participant in the acts alleged." That's not a 8 must assert my rights under the Sixth, Fifth and 8 true statement, is it, sir? 9 Fourteenth Amendment. 9 MR. PIKE: Form. 3.0 Okay, paragraph five says the 10 A i believe her deposition of V.Z. speaks ll plaintiff?s claims are barred as she said she was 1 to this issue. 1 2 18 years or older at the time. 12 Do you agree with testimony that: 3 Sir, that's not a true statementyour home? 14 it? 14 MR. Form. 15 MR. PIKE: Form. 25 A Unfortunately today, Mr. Horowitz, 1 6 A i would like to teil you exactly what 1 6 though I would like to answer every question 17 Y.L. said, however, my counsel has advised me to about V.Z., i think her deposition speaks quite a 8 say that I must assert my rights under the Sixth, 1 8 walk with some of those issues, but at least, 1 9 Fifth and Fourteenth Amendment. 1 9 with respect to my answering these questions 20 MR. PIKE: i wrote on your exhibit, page 20 today with regard to V.Z. and these issues, my 2 2 counsel has advised me I must assert my rights 22 22 2 3 different one. 2 3 Amendments. 24 MR. Yes, it isjust checkmarks. 24 Are you telling us that V.Z., in your .2 5 (Clean copy was substituted for the page 2 5 opinion, was truthfui in her deposition? 7 (Pages 357 to 360) U.S. Legal Support (561) 835-0220 363. 363 1 R. PIKE: Form, misconstrues the 1 however, with respect to my own issues today, I 2 witness?s testimony. Move to strike. 2 am going to have to assert my rights on the 3 3 4 like to answer that question with respect to Ms. 4 Fourteenth Amendments. 5 deposition, my counsei has advised me at 5 Paragraph two in the Af?rmative 6 least today I must assert rights under the 6 Defenses says, "As to all counts alleged 7 Sixth, Fifth and Fourteenth Amendments. 7 plaintiff, V.Z., actually consented to and 8 Sir, what did you mean when you said 8 participated in simiiar conduct and/or identical 9 testimony speaks to this issue"? 9 to the acts alleged with other persons which won 10 MR. NEE: Asked and answered. 1 0 the sole or contributing cause to piaintiff's 1 A I believe I said "deposition testimony." 1 damages." 12 Yes, what did you mean by that, when you 12 Sir, you know that's not correct; is 13 said "Her deposition testimony speaks to the 13 that correct? 14 issue"? 14 MR. PIKE: Form. 15 MR. PIKE: Asked and answered, form. 15 A beiieve her depositionadvice of counsel, I have to assert 1 6 words speaks to this issue, but as far as today 17 my rights under the Sixth, Fifth and Fourteenth my to that question answer unfortunately will 18 Amendment, sir. 18 have to be that I assert my rights under the 19 What facts do you know of to support the 1 9 Sixth, Fifth and Fourteenth Amendment on advice 2 0 statement that V.Z. actualiy consented to and was 20 of counsel. 2 3. a participant in the acts alieged? 2 1 Sir, isn't it true you're not aware of 2 2 MR. PIKE: Form. 22 any facts to support your contention in this 2 3 A I beiieve her deposition spoke to that 2 3 answer to the amended com piaint that V.Z. 2 a directly, but however, :nyseit?, I?m going to have 2 4 consented to and participated in conduct similar 2 5 to assert my Sixth, Fifth and Fourteenth 2 5 andfor identical to the acts aiieged with other 362 364 1 Amendment rights under advice of counsei, sir. 1 persons? 2 You read her deposition, correct? 2 MR. PIKE: Formheiieve her deposition in her own 4 You have not read her deposition? 4 words Speaks to this exact question, but however, 5 A No. 5 with respect to my answers today, unfortunately 6 But you heiieve her deposition testimony 6 with respect to V.Z., though I wonid iike to 7 correctiy speaks to the issue of the fact that 7 answer every question with respect to V.Z., on 8 she was a willing participant in the acts alleged 8 advice of counsel I have to assert my rights 9 with you? 9 under the Fourteenth, Sixth and Fifth Amendment. 3. 0 A That's not what I said. 10 Sir, my question was: What facts do you 1 1 Why don't you tel! me what you meant 11 know to be true? Clarify for me. Are you saying 12 when you said, "Her deposition testimony speaks 12 that you are adopting what v.z. says as true? 13 to the issue." 13 MR. PIKE: Form, misconstrues the 1 4 A The deposition speaks for itself. Any 1 4 witness's testimony, and that is not exactiy 15 other questions Fin sorry, Mr. Horowitz, but 1 5 what your last question was, so I'm going to It 6 today I have to assert my rights under the Sixth, 1 6 move 1 7 Fifth and Fourteenth Amendments. MR. HOROWITZ: Just to form -- 1 8 isn't it true, sir, that you are not 1 8 MR. PIKE: No, no, I'm not going to iet 19 aware of anyone who has facts that support the 19 the witness answer a question that's going 2 0 statement that V.Z. consented potentialiy waive any Constitutionai 2 1 wilting participant in the acts alleged in her 2 1 privileges here, so it not be just 2 2 iawsuit? 2 2 "form." 2 3 MR. PIKE: Form. 2 3 Now, having said that, if you can repeat 2 a A My understanding of her own testimony in 2 4 the question -- 2 5 her deposition speaks to that matter, but, 25 MR. HOROWITZ: Can you repeat the 8 (Pages 361 to 364) U.S. Legal Support (561) 835-0220 365 36? 1 ques?on? readthatcorrec?y? 2 (Discussion off the record.) 2 MR. PIKE: Form. i?rn going to instruct 3 Are you suggesting answer that questiOn. Did you 4 adopting what V.Z. says is true in her 4 read that correctly? 5 deposition? 5 Do you see where I am? Do you see when 6 MR. PIKE: Form. 6 i am, paragraph four? 7 A Sir, i would like to answer every 7' MR. PIKE: You can answer that question 8 8 9 advice of counsel, 1 have to assert my rights 9 identifying paragraph four in the document 1 0 under the Fourteenth, Sixth and Fifth Amendment 3. 0 in front of you. 1 1 In paragraph three of your Af?rmative 1 1 A I don't think you read it completeiy, 2 Defenses, it says "As to alt counts, plaintiff 1 2 did you? 13 v.22. impiiedty consented to the acts alleged by 13 "As to all counts defendant reasonably 14 not objecting." it believed or was told the plaintiff had attained 15 15 1 6 MR. PIKE: Form. 16 alleged acts." Did I read that correctly now? 1 7 A I believe her own testimony in her 1? MR. PIKE: instruct you not to answer 1 8 deposition speaks to that, however, at least 18 that question. it is not formed right. Bid 19 today, Mr. Horowitz, I have to assert my rights 1 9 you read it correctly connotates an implied 2 0 under the Sixth, Fifth and Fourteenth Amendment 20 potential waiver, did you read it correctly, 2 1 What information do you haVe to support 2 1 is it correct? 22 your assertion that plaintiff v.23. impiiedly 22 Did i accurater read the statement in 23 consented to the acts alleged by not objecting? 23 your Af?rmative Defenses? 2 4 MR. PIKE: Form. 2 4 MR. PIKE: hat is -- you can answer 2 5 A Information separate from her own 26 that question. 366 368 testimony? -- with respect to any other 1 A Yes. 2 question, I'm going to have to assert my rights 2 Okay. Isn't it true, sir, that you 3 under the Sixth, Fifth and Fourteenth Amendment 3 knew, you knew, that V.Z. was not 18 years old 4 upon advice of counsel. 4 before May of 2085; isn't that true? 5 Let's make sure we are on the same page, 5 MR. PIKE: Form. 6 then. 6 A Though I would like to answer every 7 8 Separate from her deposition 8 least today upon advice of counsel, I have to 9 testimony -- 9 assert my rights under the Sixth, Fifth and 10 A Yes? 10 Fourteenth Amendment, sir. 11 -- my question is: Do you haVe any 11 Isn't it true, sir, you had no reason to 12 facts to support your assertion that V.Z. 12 believe up until May 2085 that V.Z. was 18 year 13 impiiedly consented to the acts alleged by not 13 old or older? 1 4 objecting? 1 4 MR. PIKE: Form. 15 MR. PIKE: Form. 15 A Separate and apart from her own 16 A Separate from her own testimony with 18 testimony i believe on the subject, at least with respect to her consenting, at least today, though respect to today, to answer these questions l'm 1 8 I would like to answer that question, I'm going 1 8 going to have to assert my rights under the 9 to have to assert my rights under the Sixth, 3.9 Sixth, Fifth and Fourteenth Amendment on advice 2 0 Fifth and Fourteenth Amendment upon advice of 2 of counsel. 2 1 counsel, sir. 2 1 Isn't it true, sir, that prior to May of 2 2 Okay, paragraph four of the Af?rmative 2 2 2005, V.Z. never told you she was 18 years old 0 2 3 Defenses says, "As to all counts, defendant 2 3 older? 24 reasonably believed or was told that plaintiff 24 MR. PIKE: Form. 25 had attained the age of 18 years old." Did I 25 A Though i would like to answer that 9 (PageS'365 to 368) U.S. Legal Suppoxt (561) 835*0220 369 371 1 question with reSpect to what V.Z. told me, at witness?s testimony? 2 least today I'm going to have to assert my rights 2 A i would like to answer every single 3 under the Fourteenth, Sixth and Fifth Amendment: 3 question regarding claims, every single 4 upon advice of counsel. 4 one, however, today, upon advice of counsel, at 5 As to paragraph five, states the 5 least today, they?ve instructed me to assert my 6 following: "Plaintiff?s claims are barred as she 6 rights under the Sixth, Fifth and Fourteenth 7 said she was 18 years or older at the time." 7 Amendment. 8 Sir, you know that's not true. That 8 Sir, what facts do you know of to 9 never happened before May of 2005; isn?t that 9 support the statement that A.C. consented to and 1 0 correct? 10 was a willing participant in the acts alleged? 11 MR. PIKE: Form. 11 MR. PIKE: Form. 1 3 question with respect to what v.22. said and did, 13 deposition testimony, Fm sorry, but i would like 1 4 i, unfortunately today, have to assert my rights 1 4 to answer every question with respect to her 1 5 under the Sixth, Fifth and Fourteenth Amendment 1 5 behavior -- can you repeat the question, sir? 1 6 upon advice of counsel. 1 6 Sure. What facts do you know of to 17 I'm going to hand you what will he 1 7 support the statement that plaintiff, A.C., 18 marked as Exhibit 5, Defendant Epstein?s First 18 consented to, and was a willing participant in 19 Amended Answer in the Af?rmative Defenses to 3.9 the acts alleged? 20 Plaintiff's Second Amended Complaint in the 20 MR. PIKE: Form. 2 1 lawsuit filed by A.C. 2 1 A Separate and apart from her own 2 2 (Handing) 2 2 testimony on the subject, 1 cannot answer today 2 3 (Multi-page document was marked as 2 3 that question, though i would like to. And upon 2 4 Plaintist Exhibit number 5 for 2 4 advice of counsel, 1 must assert my rights under 25 identi?cation, as of this date.) 25 the Sixth, Fifth and Fourteenth Amendment. 320 372 1 i'm going to ask you again to turn to 1 Isn't it true, sir, you're not aware of 2 page 6 where it says "Af?rmative Defenses." 2 anyone who has facts to support the statement 3 Do you see where it says "Affirmative 3 that A.C. consented to and was a willing 4 Defenses"? 4 participant in the acts alleged? 5 A Uni?hum. 5 MR. PIKE: Form. 6 Paragraph one includes the following 6 A Unfortunately I would like to answer 7 statements: "As to all counts plaintiff actually 7 every Question about A.C.'s alleged participation 8 consented to and was a willing participant in the 8 in any event. However, today, upon advice of 9 acts alleged, and therefore her claims are barred 9 counsel 1 have been instructed that i. must assert 10 or her damages are required to he reduced 10 my rights under the Sixth, Fifth and Fourteenth 1 1 accordingly." 1 1 Amendment. 12 Sir, this statement that AC. consented 12 Sir, paragraph two of the Af?rmative 13 to and was a willing participant in the acts l3 Defenses says: "As to all counts alleged 1 4 alleged; that's not true, is it? 1 4 plaintiff actually consented to and participated 15 MR. PIKE: Form, 15 in conduct similar andlor identical to the acts 16 A I believe her own deposition speaks to 16 alleged with other persons which were the sole or 1 7 that exact question, but at least as far as my 17 contributing cause to plaintiff's alleged 8 answers are concerned today, Mr. Horowitz, 8 damages." 1 9 unfortunately upon advice of my own counsel, i i. 9 New, sir, that's not a true statement 20 have to assert my rights under the Sixth, Fifth 20 that plaintiff consented to and participated in 2 and Fourteenth Amendment. 2 1 similar acts with other persons, is it? 2 2 Do you agree with A.C.'s statements with 2 2 MR. PIKE: Form. 2 3 regard to her activity at your home as stated in 2 3 A I would love to respond to every 2 4 her deposition testimony? 2 4 questiOn with respect to similar acts performed 2 5 MR. PIKE: Form, misconstrues the 2 5 by A.C. with other people. However, at least 10 (2ages 369 to 372) U.S. Legal Suppoxt (561) 835-0220 373 3T5 1 today upon advice of counsci i must assert my 1 information you have about testimony came 2 rights under the Sixth, Fifth and Fourteenth 2 from your lawyers, or did you hear here it from 3 Amendment. 3 some other source? 4 Sir, what facts do you have to support 4 MR. PIKE: Fern}. 5 the assertion that A.C. participated in conduct 5 i'm going to instruct you not to answer 6 simiiar and/or identical to the acts aiieged in 6 that question. 7 her iawsuit against you, with other peopie? 7 Have you heard from any source other 8 MR. PIKE: Form. 8 than your attorneys what A.C. testi?ed about? 9 A Separate and apart from her own 9 MR. PIKE: You can answer that 1 0 deposition, her own testimony, I would iike to 10 question. 1 1 give all the facts with respect to A No. 12 behavior with other people. However, today my 12 Sir, paragraph three of your Af?rmativo 1 3 counsel has advised me that I must assert my 13 Defenses to A.C.'s lawsuit says, "As to all 3.4 rights under the Sixth, Fi?h and Fourteenth 14 counts piaintii?f impliedly consented to the acts 15 Amendment. 15 aileged by not objecting." Do you see that? 1 6 Have you read her deposition testimony" 16 A Yes, sir. MR. PIKE: Form. 17 Sir, you know that's not a true 18 A No. 18 statement, isn't it? 19 Have you listened to her deposition 19 MR. PIKE: Form. 2 0 testimony? 20 A I would iike to answer every question 2 1 A i don't recall. 2 1 with respect to A.C. and what she did or alleged 22 Am I accurate then, whatever you know 22 to have done. However, today I have to assert my 2 3 about her lawsuit is something your attorneys 2 3 rights under the, Sixth, Fifth and Fourteenth 2 4 have shared with you? 2 4 Amendment, upon advice of counsel. 25 MR. PIKE: Form. 25 Sir, what facts do you have to support you have it from another source? 1 your assertion that A.C. consented to the acts 2 MR. PIKE: One second. 2 alleged by not objecting? 3 MR. HOROWITZ: You have to wait for the 3 MR. PIKE: Form. 4 question -- 4 A Unfortunately any facts I might have, my 5 MR. PIKE: No. 5 attorneys have counseied me I must assert my 6 MR. HOROWITZ: That's the way the ruies 6 rights under the Sixth, Fourteenth and Fifth '7 worked. 7 Amendment, so I must assert those rights today, 8 MR. PIKE: You?re asking a question, 8 sir. 9 then you're pausing to elicit a response to 9 Sir, isn't it true you're not aware of 1 waive attomeyr?client privilege, okay? Then 3.0 anyone who has facts to support the statement 11 you?rejumping into another question. if 11 that AC. consented to the acts alleged by not 1 2 you would like me to sit in your chair and 1 2 objecting? 1 3 teach you how to ask the questions, I will 1 3 MR. PIKE: Form. 14 be happy to do so. A Though i wouid iike to answer those 1 5 MR. HOROWITZ: You couldn?t teach me a 1 5 questions with respect to the facts about A.C., 3. 6 single thing. 16 at least today my counsel has advised me I must 1 7" MR. PIKE: However, today we're here for 17 assert my rights under the Sixth, Fifth and 1 8 you. We're here for you to ask your 1 8 Fourteenth Amendment. 1 9 questions. If you wouid iike to break up 1 9 Turning to paragraph four of the 2 0 your questionsAf?rmative Defenses, isn?t it true, sir, that 2 1 that iast question, I'm going to instruct 2 1 you knew that A.C. was 18 years, was under 18 22 you not to answer, because, as you know, it 22 years 02d when she came to your home? 2 3 is attorney/chem information. Ifyou want 2 3 MR. PIKE: Form? 2 4 to try again, we?re here day. 2 4 A Though I would like to answer every 25 Sir, is it accurate to say that at! 2 5 question about Ms. A.C., I cannot, on advice of 11 (Pages 373 to 376) U.S. Legal Support (561) 835?0220 377 379 counsel today, and they?ve asked me to assert my 1 today advised me I must assert my rights under 2 rights under the Sixth, ifth and Fourteenth 2 the Sixth, Fifth and Fourteenth Amendment. 3 Amendment. 3 Isn?t it true, sir, there are no facts 4 isn't it true, sir, that you had no 4 that you're aware of to support the statement 5 reason to believe that A.C. was 18 years or cider 5 that V.A. consented to and was a willing 6 when she Was at your home? 6 participant in the acts alleged? 7 MR. PIKE: Form. 7 MR. PIKE: Form. 8 A Though I would like to answer every 8 A Though, the question of whether she was 9 question about A.C. today, Mr. l-Iorowitz,, my 9 a willing participant in the acts alleged, 10 counsel has advised me I must at least today 10 would really like to answer those questions with 1 assert my rights under the Sixth, iftli and 1 1 respect to VA. However, at least today my 12 Fourteenth Amendment, 12 ecunsel has advised me I must assert my rights 13 kwt?oma?nAllnmeMdmm 33 14 she was 18 years old or older? 1 4 Tu rning to paragraph two of the 15 MR. PIKE: Form. 15 Af?rmative Defenses, what facts do you have to 1 6 A Though I would like to answer that 6 support your assertion that VA. consented to an: 17 question regarding what Ms. A.C. told me, my 17 participated in conduct similar andfor identical 18 counsel has advised me that today must assert 18 to the acts alleged with other persons? 19 my rights under the Sixth, Fifth and Fourteenth 19 MR. PIKE: Form. 20 Amendment, 20 A Though I would like to answer the 2 1 Isn't it true, sir, no one ever told you 21 question about the acts that she's performed with 2 2 that A.C. was 18 years old or older when she was 22 other persons similar to the ones alleged here, 2 3 at you home? 2 3 at least today under adv ice of counsel, 1 have 24 MR. PIKE: Form. 24 been instructed to assert my rights under the 25 ?t 378 380 3. question, with respect to what people told me how 1 Sir, you know that VA. never consented 2 old she was or what she told me how old she was, 2 to or participated in similar or identical acts 3 sorry, but my counsel advised me today I must 3 with other persons; isn't that right? 4 assert my rights under Sixth, Fifth and 4 MR. PIKE: Form. 5 5 6 (loam 6 7 (Mufti-page document was marked as 7 today my counsel has advised me i must assert my 8 Plaintiff's Exhibit number-6 for 8 rights under the Sixth, Fifth and Fourteenth 9 identi?cation, as of this date.) 9 Amendment. 10 Moving on to Exhibit 6, Epstein's First 10 Sir, isn?t it true you're not aware of 1 Amended Answer in Af?rmative Defense is to make 1 1 anyone who has facts to support your assertion 12 his First Amended Complaint in the Jane Doc 12 that V.A. consented to or participated in simila 13 number 6 case, and I'll hand you a copy of that 1 3 or identical acts with other persons? 14 and represent to you that Jane Doc 6 is V.A., 14 MR. PIKE: Form. 1 5 okay? i ask you to turn to page 6 I see 1 5 A I'm sorry, can you read that question 16 you've already done that, of the Af?rmative 3. 6 back? 17 Defenses. 17 Sir, isn't it true you?re not aware of 18 What facts do yoa have to support the 1 8 anyone who has facts to support your assertion 3.9 contention in paragraph one that VA. consented 19 that V.A. consented to and participated willing participant in the acts 2 0 similar or identical acts with other people? 2 1 alleged? 2 1 MR. PIKE: Form. 22 2 3 A Thoagh I would like to answer the 2 3 question regarding does anyone else have 2 a question regarding what VA. consented to and how 24 information with respee to VA. participating 2 5 she was a participant in the events, my counsel 25 with other people in similar acts as your 12 (Pages 377 to 380) U.S. Legal Support (561) 835*0220 381 383 1 question posed, unfortunately, today, sir, Pro 1 to the question of what VA. told me, I would 2 going to have to assert my rights upon advice of 2 iike to respond to every question regarding V.A., 3 counsel under the Sixth, Filth and Fourteenth 3 my counsel has advised me that today at least, i 4 Amm?mmt 4 5 Turning to paragraph three of your 5 Fourteenth Amendment. 6 Af?rmative Defenses, sir, it is not a true 6 isn't it true, sir, that you couid 7 statement that V.A. impliedly consented to the 7 piainiy tell by looking at VA. that she was not 8 acts alleged by not objecting, is it, sir? 8 18 years old? 9 MR. PIKE: Form. 9 MR. PIKE: Form. 10 A The question regarding VA. impiied 10 A Sir, i would like to answer that 1 1 consent that you've just posed, i would iike to 1 1 question, as I would like to answer every other 1 2 answer that question. i would like to answer all 12 question regarding your plaintiff, VA. However 1 3 the questions with respect to VA. that you've 3 today on advice of counsei, they've instructed me 1 4 posed here today. However, upon advice of 1 4 i must assert my rights under the Sixth, Fifth 1 5 counsel 1 have to assert my rights under the 1 5 and Fourteenth Amendment. 16 16 MRJm?thm. 17 Sir, what facts do you have to support 1 7 A isn't it true, sir, no one toid you VA. 18 your contention that V.A., consented to the acts 18 was 18 years old or older. 19 alleged by not objecting? 1 9 MR. PIKE: Form. 20 2O 2 1 A Though I would iike to answer that 2 1 question of what people told me regarding V.A., 2 2 question regarding the facts that I have 2 2 allegedly, my counsel has instructed me I must 2 3 regarding V.A.'s consent, my attorneys have 2 3 respond by asserting my Sixth, Filth and 2 4 advised me that today i have to assert at 2 4 Fourteenth Amendment rights, sir. 2 5 ieast today, i have to assert my rights under the 2 5 Sir, I'm going to hand you what we 382 384 1 Sixth, Fifth and Fourteenth Amendment. 1 mark as Exhibit 7. It is Defendant Epstein's 2 Sure, turning to paragraph fear, it says 2 First Amended Answer and Af?rmative Defenses 3 "As to ali counts" strike that. 3 Plaintiff's First Amended Complaint in Jane Doc 7 4 isn't it true, sir, that you knew when 4 case ?led by 511?. 5 V.A. was at your home that she was not 18 years 5 (Multiwpage document was marked as 6 old? 6 i?laintifl?s Exhibit number 7 for 7 MR. PIKE: Form. 7 identi?cation, as of this date.) 8 A I would like to answer the question 8 i ask you to take a look at that, 9 about V.A., every question about VA. here today 9 please, and turn to page 6, of the Affirmative 1 0 that you've posed. However, upon advice of my 10 Defenses. 1 1 counsei they've advised me that I must assert my 1 1 THE WITNESS: Take a. five-minute break? 1 2 rights under the Sixth, Fifth and Fourteenth 12 MR. HOROWITZ: Sure. 13 Amendment. 13 THE VIDEOGRAPHEER: Off the record at 14 Isn't it true, sir, you had no reason to 14 21:23 am. 15 believe that VA. was 18 years of age or cider? 15 (Pause in the proceedings.) 1 6 MR. FIKE: Form. 16 THE VIDEOGRAPEER: Back on the video 17 A mm?ih?am. 18 heiieve VA. was l8 or over?? I would realiy iike 18 Mr. Epstein, do you have in front of you 1 9 to answer that question, but however, today my 19 the Affirmative Defenses ?led in your behalf in 2 counsel has advised me i must assort my rights 20 .P.'s iaWSuitsir. 22 What facts do you have to support your 2 3 Isn't it true V.A, never told you she 23 contention that RP. consented older? 2 4 willing participant in the acts alleged? 25 13 (Pages 381 to 384) Legal Suppert (561) 835*0220 385 38'? 1 A Separate and apart from her own 1 counsel has advised me i. must assert my rights 2 statements with regard to these issues, i would 2 under the Fifth, Sixth and Fourteenth Amendment. 3 like to answer every question here today with 3 Tu rning to paragraph two of your 4 respect to RP. However upon advice of counsel, 4 Af?rmative Defenses, what facts are you aware 5 at ieast today, I have to assert my rights under 5 to support your contention that consented 6 the Sixth, Fifth and Fourteenth Amendment. 6 to and participated in similar or identical acts 7 And is it your position that, wcii, tell 7 with other persons? 8 us if it is your position that PIP. admitted to 8 MR. PIKE: Form. 9 consenting to and being a wilting participant in 9 A Though I would very much like to respond 1 0 the acts alleged. 18 to simiiar acts that participated in with 1 1 MR. PIKE: Form. 1 respect to your question, sir, at least today my 12 A Can you repeat the question? 3.2 counsei has advised me that i must assert my 13 Is it your position that RP. Admitted 13 rights under the Sixth, Fifth and Fourteenth 1 4 in her deposition testimony to having consented 4 Amendment. 15 to, and having been a wiiling participant in the 15 Isn't it true, sir, you know of no facts 1 6 acts alleged? 6 to support your contention in the Af?rmative l7 A I think her deposition speaks for 17 Defenses that F.P. participated in similar or 1 8 itself, but anything beyond that, at ieast today, 18 identicai acts with other persons? 1 9 Mr. Horowitz, I?m going to have to assert my 19 MR. PIKE: Form. 2 0 rights upon advice of counsei under the Sixth, 20 A As I said previousiy, I wouid like to 2 1 Fifth and Fourteenth Amendment. 2 testify, I would like to answer your questions 2 2 Do you believe that RP. was accurate 22 with respect to RP. However, today my oounsei 2 3 when she, according to you, testified that she 23 has advised me that at least today I wouid have 2 4 consented to and was a willing participant in the 24 to assert my rights under the Sixth, Fifth and 2 5 acts alleged? 25 Fourteenth Amendment. 386 388 1 MR. PIKE: Form. 1 isn't it true, sir, you're not aware of 2 A i wouid like nothing more than to 2 anyone who has facts to support the contention 3 respond to everything RP. has to say. However, 3 that RP. participated or consented to simiiar or 4 at least today, upon advice of my counsel, I'm 4 identical acts with other peopie? 5 5 Mkmw?mn 6 Sixth, Fifth and?Fourteenth Amendment. 6 A The issue of whether RP. participated 7 Mr. Epstein, you know the statement that 7 with other people in similar alleged acts, 1 8 RP. consented to and was a willing participant 8 wouid very much to answer. However, today in 9 in the acts alleged if not a true statement; 9 counsel has advised me i may not, and have 10 10 1 MR. PIKE: Form. 1 3. Fourteenth Amendment rights. 12 A i wouid very much like to respond to 12 Turning to paragraph three, what facts 1 3 whether RP. was a willing participant in any 1 3 do you have to support your contention that 14 alleged act. However, at least today, Mr. 14 consented to the acts alleged by not objecting? 15 Horowitz, my counsel has advised me that i must 15 MR. PIKE: Form. 1 6 assert my rights under the Sixth, Fifth and 1 6 A Though wouid to answer every 17 Fourteenth Amendment. 1 question here today regarding F.P., rny counsei 18 Sir, what facts do you know of to 18 has advised me that at toast today I have to 9 support the statement that F.P. consented to and 1 9 assert my rights under the Sixth, Fifth and 20 was a wilting participant in the acts alleged? 2O Fourteenth Amendment. 2 1 MR. PIKE: Form. 2 i Isn't it true, sir, you know of no facts 22 A Though I wouid like to respond to every 22 to support your contention that RP. consented to 2 3 question regarding the facts regarding RP. and 2 3 the acts alleged by not objecting? 2 4 what she consented to and what she did not 2 4 MR. PIKE: Form. 14 (Pages 385 to 388) U.S. Legal Support (561) 835?0220 389 391 1 question you pose regarding F.P., Mr. Horowitz, advised me that I must assert my rights under the 2 at least today my counsel has advised me I must 2 Sixth, Fifth and Fourteenth Amendment. 3 assert my rights to the Sixth, Fifth and 3 Prior to May 2085, no one told you that 4 Fourteenth Amendment. 4 RP. was under the age of 18; isn't that right? 5 Runne?nymmenMawme? 5 6 anyone who has facts to support the statement 6 A i would very much like to answer every 7 that EXP. consented to the acts alleged by not 3? question with respect to what RP. and what 8 objecting? 8 everyone other people said about RP. 9 MR. WKE: Form, 9 However, at least today my counsel advised me 10 A I would like to answer the question with 10 that I may not. They've advised me that i must 1 1 respect to F.P.'s consent or not consent. 1 assert my rights under the Sixth, Fifth and 12 However, today my counsel has advised me I must 1 2 Fourteenth Amendment. 13 assert my rights under the Sixth, Fifth and 13 (Matti-page document was marked as 4 Fourteenth Amendment, though I would very much 14 Plaintiffs Exhibit number 8 for 15 like to answer that question. 15 identi?cation, as of this date.) 1 6 Tu rning to paragraph four of the 3.6 Sir, I've just handed you defendant 17 Affirmative Defenses, sir, you did not believe in 17 Jeffrey Epstein's Answer and Af?rmative Defense.- 18 your own mind that was 18 years or older 18 to plaintiff's Amended Complaints in the Jane 1 9 before May of 2005; isn't that true? 1 9 Does number 8 lawsuit, ?led by J.M. Do you have 20 MR. PIKE: Form. 20 that in front of you? 21 A Would you repeat the question, Mr. 21 A Yes. 22 Horowitz? 2 2 I'll ask you to turn, please, to page 6, 2 3 You didn't believe prior to May 2005 in 23 which is the Af?rmative Defenses. 24 your mind that was 18 years old or older; 24 With regard to paragraph one, what facts 2 5 isn't that true? 25 do you have to support your contention that J.M. 390 392 1 MR. PIKE: Form. 1 consented to and was a willing participant in the 2 A What I believed in my mind, 2 acts alleged? 3 3 4 question with regard to RP. that you posed here 4 A I would like to answer every question 5 5 6 question with respect to F.P. However, at least 6 advised me that at least today i must assert 7 today i have to assert my rights on advice of 7 my rights under the Sixth, Filth and Fourteenth 8 counsel under the Sixth, Filth and Fourteenth 8 Amendment, though I would very much like to 9 Amendment. 9 answer every question regarding 1M. 1 0 Sir, before May of 2005, you knew that 10 Sir, what facts do you know of to 1 RP. was under the age of 18; isn't that right? 1 1 support the statement that J.M. consented to and 12 MR. i?lKE: Form. 12 was a willing participant in the acts alleged? 13 A Sir, I would like to answer every 13 MR. PIKE: Form. 1 4 question with respect to FR, that you?ve posed 1 4 A Though i would like to answer every 15 here today. However, my counsel has advised me 15 question about any alleged incident with J.M., my 1 6 that at least today i may not, and must assert my 1 6 counsel has advised me that at least today I must 1 7" rights under the Sixth, Filth and Fourteenth 7 assert my rights under the Sixth, Fifth and 8 Amendment. 1 8 Fourteenth Amendment. 1 9 Sir, prior to May 2005 RP. never told 19 Isn't it true, sir, you?re not aware older; isn't that true? 2 0 anyone who has facts to support your aSSertion 2 1 MRCPIKE: Form? 21 that J.M. consented to and was a willing 2 2 A I would very much like to answer those 2 2 participant in the acts alleged? 2 3 questions, every question with respect to RP. 2 3 MR. PIKE: Form. 2 4 that you've posed here today, Mr. Horowitz. 2 4 A iWOuld like to answer every question 25 However, upon advice of my counsel, they've 2 5 regarding J.M., and her claims, and these alleged 15 (Pages 389 to 392) (1.3. Legal Support (561) 8350220 393 395 1 2 counsei has advised me that I must assert my 2 MW. However, my counsei here today has advised 3 rights under the Sixth, Fifth and Fourteenth 3 me that I must assert my rights under the Sixth, 4 Amendment. 4 Fifth and Fourteenth Amendment, at feast today. I 5 Okay, turning to paragraph two, what 5 Turning to paragraph four of the 6 facts are you aware of to support your contention 6 Af?rmative Defenses, it is on the following page 7 that J.M. consented to and participated in 7 if you want to foiiow along; what facts do you 8 simiiar or identical acts with other people? 8 have to support your contention that you beiiever 9 MR. PIKE: Form. 9 J.M. attained the age of 18 at the time of the A With respect to acts with simiiar other 10 alleged acts? 1 1 peopie, I wouid very much like to answer that 11 MR. PIKE: Form. 12 question. However, at toast today my counsel has 12 A Iwouid very much iike to answer every 13 advised me that I must assert my rights under the 13 question with reapect to 1M. and her etaims. 4 Sixth, Fifth and Fourteenth Amendment. 14 However, today, at ieast today, my attorneys have 15 Isn't it true, sir, that this assertion 15 advised me that I must assert my rights under the 1 6 that LEVI. consented to and participated in 16 Sixth, Fifth and Fourteenth Amendment. 1 7 similar or identical acts with other persons; Isn't it true, sir, you knew that J.M. 1 8 that's not a true statement, is it? 18 was tinder the age of 18 at the time of the 19 MR. PIKE: Form. 19 alleged acts? 2O 20 2 1 singie question with respect wouid very much iike to answer every 2 2 alieged claims of aiieged incidents. However, 22 question with respect to J.M.'s claims. However, 2 3 today, my counsel has advised me I must assert my 2 3 my counsel today has advised me I must assert my 2 4 rights under the Sixth, Fifth and Fourteenth 2 4 rights under the Sixth, Fifth and Fourteenth 2 5 Amendment. 2 5 Amendment. 394 396 1 hdt?nhm?nymmenMawmeof 1 2 anyone who has facts to support your assertion 2 believe that J.M. was 18 years old or older at 3 that J.M. consented to and participated in 3 the time of the aiieged acts? 4 similar or identical acts with other people? 4 MR. 911051: Form. 5 MR. PIKE: Form. 5 A I would like to answer every single 6 A I would like to answer every question 6 question regarding claims, sir. However, 'i with respect to J.M., her alieged ciaims and "i at toast today my counsel has advised me i must 8 alleged incidents. However, today my counsel 8 assert my rights under the Sixth, Fifth and 9 has advised me that I must assert my rights under 9 Fourteenth Amendment. 10 the Sixth, Fifth and Fourteenth Amendment, sir. 10 isn?t it true, sir, J.M. never told you 1 1 Turning to paragraph three, what facts 1 3. she was 18 or older? 3.2 do you have to support your aSSertion that J.M. 12 MR. PIKE: Form. 13 consented to the acts alleged by not objecting? 13 A I wooid very much like to answer every 14 MR. PIKE: Form. 14 question regarding ciaims. However, today 1 5 A i would iike to answer every question 1 5 my coansei has advised me that i must assert my 16 with respect to J.M.'s ciaims and alleged l6 rights under the Sixth, Fifth and Fourteenth incidents. However, today my counsei has advised 1 7 Amendment. 1 8 me i must assert my rights under the Sixth, Fifth 18 Isn?t it true, sir, no one ever told you 1 9 and Fourteenth Amendment. 3. 9 that J.M. was 18 or oider? 2 0 Isn't it true, sir, you're not aware of 20 MR. PIKE: Form. 2 1 anyone who has facts to support your assertion 2 1 A I would iike to answer every question 22 that J.M. consented to the facts alleged by not 22 with respect to claims. However, at least 2 3 objecting? 2 3 today my counsei has advised me that I may not, 2 4 MR. PIKE: Form. 2 4 and though I wouid like to, they told me I must 2 5 A i wouid very much like to answer every 25 assert my rights under the Sixth, Fifth and 16 (Pages 393 to 396) U.S. Legal Support (561) 835-0220 397 399 1 Fourteenth Amendment. 3. age of 18 to come to your home for your sexual 2 Sir, did you ever pay for a telephone 2 pleasure? 3 number (407) 665-3144, pay the phone hill? 3 MR. PIKE: Penn. 4 A I would have to assert my rights under 4 A i would like to answer every 0110 5 the Sixth, Fifth and Fourteenth Amendment, sir. 5 questions regarding these phone numbers and 6 Betwaen 2081 and 2006, did you use the 6 allegations. However, today, my counsel has 7 telephone number (407) 655-3144, to get kids to 7 advised me that I may not and must assert my 8 come to your home for your sexual pleasure? 8 rights under the Sixth, Fifth and Fourteenth 9 MR. PIKE: Form. 9 Amendment. 1 0 A Though I would like to answer all these 10 Have you ever paid the telephone bill or 11 questions regarding phone numbers, i?m sorry but 11 had registered in your name the phone number 12 i may not on advice of counsel, so 1' must assert 12 (561) 655?4590? 13 my rights under the Sixth, Fifth and Fourteenth 13 MR. PIKE: Form. 14 Amendment. 14 A Mr. Horowitz, I would like to answer 15 Did you direct one or more people to use 15 each one of your questions regarding phone 1 6 the telephone number 65545144 in order to 1 6 numbers here today, but on advice of counsel 17 get kids, girls, to come to your home for your they've told me I must assert my rights under the 18 sexual pleasure? 18 Sixth, Fifth and Fourteenth Amendment. 19 MR. PIKE: Form. 1 9 is (561) 655-4590 a telephone number you 2 A Though I would like to answer every one 20 used between 2001 and 2006 to get girls under the 2 1 ofyour questions today regarding phone numberscome to your home for your sexual 2 2 on advice of counsel, I may not, because it may 22 pleasure? 2 3 be relevant to other lawsuits or this lawsuit, 2 3 MR. Form. 2 4 and they?ve instructed me that I must assert my 24 A Though I would like to answer every one 2 5 rights under the Sixth, Fifth and Fourteenth 2 of your questions regarding telephone numbers, my 398 400 1 Amendment. 1 counsel has advised me that at least today I may 2 Have you ever either paid or had 2 not, because it may be relevant to this lawsuit 3 registered to you the telephone number (561) 3 or another lawsuit, and they?ve instructed me 4 373.2262? 4 that I must assert my rights under the Sixth, 5 MR. PIKE: Form. 5 Fifth and Fourteenth Amendment. 6 A I would like to answer every question 6 Is (561) 6554950 a telephone number 7? regarding phone numbers, Mr. Horowitz. My 7 that you directed to other people to use in order 8 attorneys have asked me to respond to most of 8 to get kids to come to your home for your sexual 9 your questions here today by asserting my rights 9 pleasure? 10 under the Sixth, Filth and Fourteenth Amendment I 10 MR. PIKE: Form. 1 1 will have to do so with respect to that question. 1 A would like to answer every one ofyour 12 Between the years 2001 and 2006, did you 12 questions regarding phone numbers allegedly used 13 use the telephone number (561) 3734262, in order 13 for these types of purposes. However, my counsel 1 4 to arrange for girls under the age of18 to come .1 4 today has advised me I may not and have 15 to your home for your sexual pleasure? 15 instructed me must assert my rights under the 16 MR. PIKE: Form. 3.6 Sixth, Fifth and Fourteenth Amendment. 1? A I would like to answer every one of your 17 Sir, have you ever paid the phone bill 18 questions regarding phone numbers here today, Mr. 18 or had registered in your name the phone numbe 19 Horowitz. However, on advice of counsel, at 19 (561) 762-2741? 20 least today, they?ve instructed me thatl must 20 MR. PIKE: Form. 2 1 assert my rights under the Sixth, Fifth and 2 A Though would like to answer that 22 Fourteenth Amendment. 22 question as I would like to answer every one of 23 Between 2001 and 2006, did you direct 23 your questions here today, my counsel has advised 24 one or more people to use the telephone number 24 me that at least today, I must assert my rights 25 (561) 373-2262, in order to get girls under the 25 under the Sixth, Fifth and Fourteenth Amendment, 17 (Pages 397 to 400) 0.3. Legal Support (561) 835*0220 401 403 1 sir. 1 phone numbers. However, upon advice of my 2 Is the telephone number (561) 762-2741, 2 counsel, they?ve instructed me that I must assert 3 a telephone number you used between 2001 and 200 3 my rights under the Sixth, Fifth and Fourteenth 4 in order to get girls under the age of 18 to come 4 Amendment. 5 to your home for your sexual pleasure? 5 Sir, have you ever paid the phone hill 6 MR. PIKE: Form. 6 or had the phone number (561) 820-8790 registered 7 A I would like to answer every one of your 7 in your name? 8 questions with respect to these teiephone 8 MR. FIRE: Form. 9 numbers. However, my counsel today has advised 9 A I would very much like to answer every 3. 0 me that I must assert, at least today, my rights 1 0 questiou regarding phone numbers that you've 1 1 under the Fifth, Sixth and Fourteenth Amendment. 1 posed here today, Mr. Horowitz. However, my 1 2 Sir, is (561) 762-2741 a telephone 1 2 counsel has advised me that at least today i must 1 3 number that you directed other people to use in 3 assert my rights under the Sixth, Fifth and 4 order to get girls under the age of 18 to come to 14 Fourteenth Amendment. 1 5 your home for your sexual pleasure? 1 Sir, is the telephone number (561) 16 MR. PIKE: Form. 16 8203790 a telephone number you used between 2001 A i would like to answer every question 1 7 and 2006 to get underage girls to come to your 1 8 regarding these telephone numbers. However, my 1 8 home for your sexual pleasure? 1 9 counsel has advised me that at least today, that 9 MR. PIKE: Form. 20 I may not and they've instructed me I must assert 20 A i would very much like to answer every 2 1 my rights under the Sixth, Fifth and Fourteenth 2 1 one of your questions posed here today with 2 2 Amendment. 2 2 regard to telephone numbers or anything eise. 23 Sir, have you ever registered in your 23 However, my counsel has advised me at least today 2 4 name or paid the phone bill for telephone number 24 that I may not, and must assert my rights under 25 (561) 655-7629? 25 the Sixth, Fifth and Fourteenth Amendment. 402 404 1 MR. PIKE: Form. 1 Sir, is the telephone number (561) 2 A I would like to answer each one of your 2 820?8790 a telephone number you directed others 3 questions today, Mr. Horowitz, regarding these 3 to use in order to get underage girls to come to 4 telephone numbers. My counsel has advised me 4 your home for your sexual pleasare? 5 that at least today I may not, and must assert my 5 MR. PIKE: Form. 6 rights under the Sixth, Fifth and Fourteenth 6 A I would like to answer every one of your 7 Amendment. 7 questions regarding phone numbers, Mr. Horowitz. 8 Is (561) 655?7629 a telephone number you 8 However, today my counsel has advised me that 9 usod between 2001 and 2806 to get girls under th 9 must assert my rights under the Sixth, Fifth and 10 age of 18 to come to your home for your sexual 10 Fourteenth Amendment. 11 pleasure? 1 Sir, have you ever paid the phone bill 12 MR. PIKE: Form. 12 or had the phone number (561) 832?2104 registered 1 3 A Though woutd very much like to answer 13 in your name? 14 every question regarding -- that you?ve posed 14 MR. PIKE: Form. 15 here today regarding phone numbers, on advice of 15 A Sir, lwouid like to answer every one of 6 counsel, I may not. They've instructed me I must 16 your questions regarding phone numbers. However, 17 assert my rights under the Sixth, Fifth and 17 my counsel has advised me that at least today I 18 Fourteenth Amendment, 18 must assert my rights under the Sixth, Fifth and 19 Is (561) 655-3629 a telephone number you 19 Fourteenth Amendment. 20 directed other people to use in order to get 20 Is the telephone number (561) 832-2104 21 2 1 girls under the age of 18 to come to your home 2 telephone number that you used between 290} and 2 2 for your sexual pleasure? 22 2006 in order to get kids to come to your home 23 MR. Form. 23 for your sexual pleasure? 2 4 A I would like to answer every one of your 24 MR. PIKE: Penn. 2 5 questions posed here today regarding various 2 5 A Though I would like to answer every one 18 (Pages 401 to ?04) U.S. Legal Support (561) 835*0220 405 40'? 1 of your questions regarding phone numbers here 1 regarding these various phone numbers you've 2 today, Mr. Horowitz, my counsei has advised me 2 thrown out today, my counsel have advised me that 3 3 4 the Sixth, Fifth and Fourteenth Amendment. 4 Sixth. Fifth and Fourteenth Amendment. 5 Sir, is telephone number (561) 83242204 5 Sir, have you eVer paid the phone bili 6 a telephone number that you directed others to 6 for telephone number (917) 855?3363? 7 use in order to get underage girls to come to 7 MR. PIKE: Form. 8 your home for your sexual pleasure? 8 A Mr. Horowitz, i wouid very much like to 9 MR. PIKE: Form. 9 answer your questions regarding ah the 1 0 A Though I would like to answer every one 1 0 various phone numbers you've thrown out here 1 1 of your questions regarding phone numbers, Mr, 1 3. today. However, on advice of counsei they?ve l2 Horowitz, the various phone numbers you've now 1 2 asked me to assert my Sixth, Fifth and Fourteenth 1 3 put on the tabie, my counsel has advised me at 1 3 Amendment right- 1 4 ieast today I may not. I must assert my rights 1 4 Sir, is the telephone number (917) 5 under the Sixth, ifth and Fourteenth Amendment 1 5 855-2262 a teiephone number that you used between 16 - Sir, have you ever paid the phone bit! 16 2001 and 2006 in order to get underage girls to or had registered in your name the telephone 17 come to your home for your sexuai pleasure? 18 number (222) 527-7580? 18 MR. PIKE: Form. 1 9 MR. PIKE: Form. 1 9 A Mr. Horowitz, with respect to ail these 2 0 A Mr, Horowitz, I wouid iike to answer 20 phone numbers you keep throwing out, i have to 2 1 every one of your questions regarding phone 2 unfortunately answer the question the same way as 2 2 numbers that you?ve posed here today. However, 22 We answered your other questions here 2 3 upon advice of counsei, they?ve instructed me I 23 today, which is I'm going to have to assert my 2 4 must assert my rights under the Sixth, Fifth and 24 rights upon the advice of counsei under the 2 5 Fourteenth Amendment. 25 Sixth, Fifth and Fourteenth Amendment. 406 408 1 is (212) 52%7580, a teiephone number 1 Sir, is (917) 855-3363 a telephone 2 that you used between 2001 and 2806 in order to 2 number that you directed other peopie to use in 3 get girls under the age of 18 to come to your 3 order to get girls to come to your home for your 4 home for your sexual pleasure? 4 sexual pleasure? 5 MR. PIKE: Form. 5 MR. PIKE: Form. 1 6 A Mr. Horowitz, i would very much like to 6 A Aithough I would like to answer every 7 answer every one of your questions regarding 7 one of your questions regarding the various phone 8 various numbers you?ve thrown out here today. I 8 numbers that you've thrown out today, at least 9 have to answer that question Iike I've answered 9 today, upon advice of counsel, 1 have to assert 1 0 all your other questions here today, which is on 10 my rights under the Sixth, Fifth and Fourteenth 1 1 advice of counsei I may not answer these 1 1 Amendment. 12 questions as they may not be relevant to another 12 Have you ever paid the phone bill for 1 3 lawsuit 1 3 telephone number (561) 308-0282? 14 Sir go ahead, sorry. 14 MR. PIKE: Form? 1 5 A though i wouid to, I am going to 15 A With respect to the phone numbers 1 6 have to assert my rights as instructed by 1 6 you?ve thrown out here today and asked questions counsel, under the Sixth, Fifth and Fourteenth 17 with regard to today, my counsel has advised incl 1 8 Amendment, 1 8 must assert my rights under the Sixth, Fifth and 1 9 Sir, is the telephone number (212) 19 Fourteenth Amendment. 20 517-7580 a telephone number that you directed 2 0 Is the telephone number (561) 308~0282 a 21 others to use in order to bring girls to your 2 telephone number you directed other people to use 22 home for your sexual pleasure? 2 2 in order to bring girls under the age 0f18 to 2 3 MR. PIKE: Form. 2 3 your home for your sexual pleasure? 24 A Though I would like to answer each and 24 MR. PIKE: Form. 25 every one of your questions, Mr. Horowitz, 2 5 A I have to answer that question as I've 19 (Pages 405 to 408} U.S. Legal Support (561) 835-0220 409 411 1 answered most of your other questions here today, 1 interest in a business entity known as Zorro 2 Mr. Horowitz, which is upon advice of counsci i 2 Ranch? 3 3 4 and Fourteenth Amendment. 4 of your questions, i would have to manner that 5 Sir, have you ever paid the phone hill 5 one as i?ve answered all your other questions 6 for telephone number (561) 655-4870? 6 here today, which is upon advice of counsel today 3? MR. PIKE: Form. 7 they've asked me instructed me to assert my 8 8 9 here today, Mr. Horowitz. l?rn going to have to 9 Amendment. 10 respond to that telephone number as I have to 10 Sir, have you ever owned or had a 1 1 each and every one of your other phone numbers 1 1 beneficiai interest, been a director or of?cer 12 you've thrown out today, which is upon advice of 12 of New York Strategy Group, 13 14 rights under the Sixth, Fifth and Fourteenth 3.4 of your questions here today, but unfortunately I 5 Amendment although I would iike to answer every 15 my counsei has asked me instructed me to 16 one of your questions. 1 6 assert my rights under the Sixth, Fifth and 1 7 Is the number (562) 655-4870, :1 l7 Fourteenth Amendment. 18 telephone number that you directed other people 18 Have you ever owned or had a beneficial 1 9 to use in order to bring underage girls to your 1 9 interest in or been an officer or director or 2 0 home for your sexual pleasure? 20 founder of the COUQ Foundation? 2 1 MR. PIKE: Form. 2 1 A Though I would like to answer every One 2 2 A Though i would like to answer every 2 2 of your questions, Mr. Horowitz, i have to 2 3 question regarding phone numbers that you?ve 2 3 respond to that questiou as I have responded to 2 4 posed here today, Mr. Horowitz, unfortunately my 2 4 aimost all of your other questions here today, 25 counsei advised me I must assert my rights under 2 5 which is that open advice of counsel, they've 410 412 the Sixth, Fifth and Fourteenth Amendment. 1 instructed me I must assert my rights under the 2 2 3 beneficial interest in a corporation known as 3 Have you ever been an owner,?shareholde1 4 Nine East 71st Street Corporation? 4 or had a beneficial interest in Financial 5 A I would iike to answer every One of your 5 Strategy Group, Inc.? 6 6 7 of counsel, at least today, l'm going to have to 7 well as every other question yoo've posed here 8 assert my rights under the Sixth, Fifth and 8 today. However, my counsel has advised me that 9 Fourteenth Amendment. 9 at ieast today i must assert my rights under the 10 Sir, have you ever owned or had a 10 Sixth, Fifth and Fourteenth Amendment. 11 bene?cial interest in J. Epstein Company? 11 Have you ever owned or had a bene?cial 12 A Sir, at least today with respect to most 12 interest or been a shareholder in Financial 1 3 of your questions, like I've answered almost 13 Trustees, Inc.? 1 a all of your questions here today, upon advice of 4 A Though I would like to answer every one 1 5 counsei, they?ve asked me to assert my rights 15 of your questions here, that you've posed here 1 6 under the Sixth, Fifth and Fourteenth Amendment. 1 6 today, Mr. Horowitz, i have to unfortunateiy 1 7 Have you ever owned or had a bene?cial 1 7 answer that question the same way as I've 1 8 interest or been an of?cer of Zorro Development 18 answered almost ali of your other questions here 1 9 Corporation? 19 today. Upon advice of my counsei they?ve 20 A i would iike to answer every one of your 2 0 instructed me to assert my Sixth, Fifth and 2 1 questions here today, Mr. Horowitz. However, 2 1 Fourteenth Amendment right. 22 upon advice of counsei at least today, they've 22 Sir, have you ever been an owner, 2 3 asked me to assert my rights under the Sixth, 23 shareholder, of?cer or director of the Gislaine 2 4 Fifth and Fourteenth Amendment. 2 4 Corporation? 25 Have you ever owned or had a bene?cial 25 A Can you spell that? 20 (Pages 409 to 412) U.S. Legal Support (561) 835?0220 413 415 1 G~i~s~l~a~i~nue, am i mispronouncing? 1 THE WITNESS: Take a 2 A Yes. I 2 (indicating counsel.) 3 How would you pronounce it? 3 THE VIDEOGRAPHER: Going off the video 4 A 4 rummll?3am. 5 Okay. 5 (Pause in the proceedings.) 6 A Fm sorry, but today at least I have to 6 THE VIDEOGRAPHER: Back on the record 7 assert my rights under the Sixth, Fifth and 7 11:56 am. 8 Fourteenth Amendment upon advice of counsel. 8 (The record was read.) 9 Sir, have you ever been an 9 A Yes. 1 0 owner/sharehoider or director owner of the Florida Science 1 i?lantation Management Corporation? 1 Foundation? 12 A I would like to answer every one of your 3.2 A On advice of counsel, at least today, 1 3 questions here today, Mr. Horowitz, with respect 13 sir, I have been instructed to assert my rights 4 to that one, as well as all the others, i have to 4 under the Sixth, Fifth and Fourteenth Amendment. 15 assert my rights under the Sixth, Fifth and 15 Are you an employee of Florida Science 1 6 Fourteenth Amendment. 1 6 Foundation? Sir, have you ever been an owner, 17 A Yes. 18 shareholder or director of a business entity 18 What do you do in your role as an 19 known as Epstein interests? 3.9 employee of Florida Science Foundation? 2 0 A With respect to that question, as well 2 A Though I would like to answer all of 2 1 as all of your other questions here today, my 2 1 your questions here today, Mr. Horowitz, upon 22 counsel advised me i may only answer the 2 2 advice of counsel, they?ve instructed me I must 23 questions by asserting my rights under the Sixth, 23 assert my rights under the Sixth, Filth and 2 4 Fifth and Fourteenth Amendment. 2 4 Fourteenth Amendment. 25 Sir, have you ever been of?cer, 25 What kind of work is the Florida Science director, shareholder or employee of the Wexne 3. Foundation involved in, if any? 2 Investment Group? 2 MR. PIKE: Form. 3 A I have to respond to that question as 3 A Though I would very much like to answer a 4 5 today, Mr. Horowitz. Upon advice of counsel 5 upon advice of counsel, they've instructed me to 6 6 7 8 Sir, have you ever been a shareholder or 8 Where do you work for the Florida 9 owner of MC Squared Modeling? 9 Science Foundationthe other questions you've posed here today, my 1 1 A At 250 South Australian. That's the 12 counsel has advised me I must assert my rights 1 2 of?ces. 13 under the Sixth, Fifth and Fourteenth Amendment. 13 Is that the City of West i?alm Beach? 14 14 A Yeash. 15 beneficial interest in a business entity known as 15 During what hours do you work at the 1 6 6 Florida Science Foundation? 17 A I?m going to have to respond to that 17 A Upon advice of counsel, sir, they've 18 question as i responded to all of your other 18 instructed me to assert my rights under the 19 questions here today, Mr. Horowitz, which is, on 19 Sixth, Fifth and Fourteenth Amendment. 2 0 advice of counsel they've asked me to assert my 20 How long have you been working at the 2 1 rights under the Sixth, Fifth and Fourteenth 2 1 iorida Science Foundation? 22 Amendment. 22 MR. PIKE: Form. 23 Sir, do you have an ownership or 2 3 A I would like to answer all of your 24 bene?cial interest or even an employee of an 2 4 questions here today, Mr. Horowitz. However, 25 entity known as the Florida Science Foundation" 2 5 upon advice of counsel, at least today, they've 21 (Pages 413 to 416) 0.3. Legal Support (561) 835-0220 417 419 1 instructed me to assert my rights under the 1 MR. PIKE: To the extent you can answer 2 Sixth, Fifth and Fourteenth Amendment. 2 that question without divulging my 3 On what days do you work for the Florida 3 communications with you, you can answer that 4 4 quednnt 5 MR. PIKE: Form. 5 A No. 6 A Though I wouid like to answer each one 6 Did you review any materials, such as "i of your questions here today, my counsel has 7 depositions, police reports, anything else in 8 advised me that at least today I must assert my 8 preparation for your deposition today? 9 rights under the Sixth, Fifth and Fourteenth 9 A No. 18 Amendment. 10 Did you review any notes or any 1 1 Who else, if anyone, works for the 1 handwritten materials in preparation for your 12 Fiorida Science Foundation? 12 deposition today? 13 MR. PIKE: FormThough I wouid iike to w- 1 ?i You have notes on a piece of paper, are 15 MR. PIKE: You know that's standard 3. 5 those notes that you have made or reviewed in 16 Fifth Amendment, anyway. 3. 6 preparation for your continuation of this 1 'i A Though I would like to answer each and 17 deposition here today? 18 every one of your questions today, Mr. Horowitzcounscl has advised me with reapect to that 3. 9 in the past you've told me that some 2 0 question, I must assert my rights under the 2 0 time ago at another deposition, that you did not 2 1 Sixth, Fifth and Fourteenth Amendment. 2 1 like Jane Doe; is that right? 22 Is the Florida Science Foundation a 22 A i don't believe I have no 2 3 for-pro?t or nonprofit corporation? 2 3 recollection of that. 2 4 A Upon advice of counsel, sir, with 2 4 To be more specific, and hopefuiiy to 2 5 respect to that question, I'm going to have to 2 5 jog your memory, do you remember telling me yet 418 420 1 assert my rights under the Sixth, Fifth and 1 iike L.M., but don't like my other two, one of 2 Fourteenth Amendment. 2 those clients being Jane Doe; do you recall that. 3 3 A thdemamwwemwomohmm 4 time, I don't have further questions. There 4 questions, Mr. Edwards, but today at feast, my 5 may be some other questions that arise from 5 counsei advised me I must assert my rights under 6 other peepie's questions. 6 the Sixth, Fiith and Fourteenth Amendment. 7 THE WITNESS: Ail right. 7 Why don't you like Jane Doe? 8 MR. PIKE: Thank you, Mr. Horowitz. 8 MR. PIKE: Form. 9 MR. EDWARDS: Does anybody want to 9 A I wouid like to answer every one of your 10 address what we are going to do for lunch? 1 0 questions, Mr. Edwards. However, today my 11 MR. HOROWITZ: You don?t have to type 3. 1 counsel has advised me that 1 measures assert my 12 this. 12 rights under the Sixth, Fifth and Fourteenth 3 (Disoussion off the record.) 1 3 Amendment. 14 THE VIDEOGRAPHER: Off the video record 14 Did you sexually molest Jane Doe when 15 at 12:00 o'clock noonyears old? 16 (Pause in the proceedings.) 16 MR. PIKE: Form. THE VIDEOGRAPHFR: Back on the video A i would like to answer aft of your 18 record 12:11 pm. 18 1 9 MR. EDWARDS: Ready? 1 9 2 0 MR. PIKE: Yes, thank you. 2 0 2 1 THE WITNESS: Yes. 2 1 2 2 I represent Jane Doe in a case against like ten representative 23 24 plaintiffs here today. Did you do anything to 2d 2 5 prepare for your deposition today? 2 5 22 (Pages 417 to 420) U.S. Legal Suppoxt (561) 835-0220 421 423 1 questions with respect to Jane Doe. However my 1 Have you read the statute or been 2 counsel here today advised me I may not and must 2 instructed upon the Florida statute related to 3 assert my rights under the Sixth, Fifth and 3 lewd and lascivious molestation? 4 Fourteenth Amendment. 4 MR. PIKE: Form, instruct you not to 5 MR. EDWARDS: Move to strike as 5 answer that question, attomey?fclient work 6 nonresponsive. 6 product, as worded. 7 When you say you would lilte to answer Other than your attorney telling you 8 the questions, but your counsel has instructed 8 about the statute, or reading that statute to 9 you that you must invoke your Fifth, Sixth and 9 you, i certainly do not want and am not entitled 10 Fourteenth Amendment rights, are you saying that 10 to communications between you and your attorney 1 1 you disagree with the advice of your counsel? 1 1 but have you otherwise familiarized yourself, 12 MR. PIKE: I instruct you not to answer 12 either by way of reading the statute or being 13 that question. 1 3 told by somebody other than your attorneys, 14 MR. EDWARDS: On what ground? 1 4 regarding the statute lewd and Iascivious 15 MR. PIKE: i don't need to give you 1 5 molestation? 16 grounds. 16 MR. PIKE: Form. MR. EDWARDS: It is not a privilege, 17 A Though I would like to answer every one 18 just something you're instructing him not to 1 8 of you ever questions here today, Mr. Edwards, 1 9 answer? 1 9 most of your questions I have to respond by 2 0 MR. PIKE: Absoluteiy it is a 2 0 asserting on advice of counsei my Sixth, Fifth 2 1 privilege. You heard him, what he said. lie 2 and Fourteenth Amendment right. 2 2 is invoking his Sixth, Fifth and Fourteenth 2 2 Lewd and lascivious molestation is 2 3 Amendment in and as a result of his advice 2 3 defined in Florida as a person who intentionally 2 4 of counsel. Your question elicits 2 4 touches in a lewd or iascivious manner, the 2 5 attorney/client communications as well as 2 5 breasts, genitals, general area, or buttocks, or 422 424 1 work product. 1 the clothing covering them, of a person less thar 2 So, attorney/client work product is the 2 16 years of age, or forces or entices a person 3 basis for your objection? I understand. 3 under 16 years of age to so touch the 4 MR. PIKE: Yeah. 4 perpetrator.? 5 Mr. Epstein, are you going to follow 5 Having read that, isu't that a statute 6 your advice of counsel and invoke your Fifth 6 that you violated on numerous occasions againS? Amendment right against self-incrimination and 7 Jane Doe when she was a minor? 8 not answer that question? 8 MR. PIKE: Form. 9 A I'm going to follow my advice of 9 A I would -- have to assert my rights 1 0 counsel. 10 under the Sixth, Fifth and Fourteenth Amendment 1 1 Mr. Epstein, are you familiar with the 1 1 upon advice of counsel, Mr. Edwards. 12 laws in Florida on lewd and lascivious 12 Su behapter six of that statute involves 1 3 molestation? 1 3 a crime of lewd and lascivious conduct that in 14 MR. PIKE: Form. 14 Florida is de?ned as a person who intentionally 1 5 A On advice of counsel I have to assert my 1 5 touches a person under 16 years of age in a lewc 1 6 rights with the Sixth, Fifth and Fourteenth 16 and laseivious manner, or a person who 17 Amendment. intentionally masturbates in the presence of a 18 Do you understand my question in that 18 victim under 16 years of age." These are also 19 i?m not asking you whether you committed any 1 9 sections of that Florida statute that you 2 0 crimes related to the statute, only whether or 2 0 violated against the then minor, Jane Doe; is 2 1 not you are familiar with the Florida statute on 2 1 that true? 22 lewd and lascivious molestation; do you 22 MR. PIKE: Form. 2 3 understand that question? 2 3 A I would like to answer all of your 24 MR. PIKE: Form. 2 4 questions with respect to tone Doe, Mr. Edwards. 25 A What does "familiar" mean. 25 However, today my counsel has advised me that .l 23 (Pages 421 to 424) 0.3. Legal Support (561) 835*0220 425 4-27 1 am to assert my rights under the Sixth, Fifth and 1 molestation statutes against Jane Doc? 2 Fourteenth Amendment. 2 MR. PIKE: Form. 3 MR. EDWARDS: Move to strike the 3 A Upon advice of counSei, Mr. Edwards, i 4 nonresponsive portion of that answer. 4 have to respond to that question as i responded 5 MR. PIKE: What's noriresponsive?? 5 to most of your other questions here today, by 6 MR. EDWARDS: What you would like to do 6 asserting my rights under the Sixth, Fifth and 7 is not responsive to the question rotated to 3? Fourteenth Amendment. 8 8 9 her,? is either "yes" or "no" or "invoked." 9 partner who heiped file this lawsuit, but he is 10 i don?t reaiiy care and I don?t think it is 10 currently in jail. You might want to strike that 1 1 relevant, what he wouid hire to do. Thatis 1 as nonresponsive, but the indies and gentlemen of 12 the part I would move to strike. 12 the jury will eventuaiiy know that most of these 13 MR. PIKE: if that's the part you're 13 cases have been brought by your firm, your 14 moving to strike, it is duly noted in the 1 4 partner who sits in a jail for fabricating cases 15 record. 1 5 of sexual nature against people like me and 6 MR. EDWARDS: Okay. it 6 others. 17 MR. PIKE: i object to that. For the 7 Okay. Let's talk about that, then. 18 record, based upon your comment, there have 1 8 You're talking about Scott Rothstein? is that 19 been Several depositions in these 1 9 right? You're saying my former partner. Is that 2 0 consoiidated cases and there has been 2 0 who you're referring to that sits in jail? 2 1 implied arguments from the piaintii?f?s side 2 1 A Correct. 2 2 relative to the Fifth Amendment waiver and 2 2 Okay, what about anything that Scott 2 3 why Mr. Epstein is invoicing the Sixth, Fifth 2 3 Rothstein did, affects your answer to my question 2 4 and Fourteenth Amendment Constitutional 2 4 as to whether or not you molested Jane Doe back 2 5 privileges and there are various adverse 2 5 in 2803 and 2004? 426 428 1 inferences that I?m sure the piaintiffs will 1 MR. PIKE: Form? 2 attempt to gain. 2 A I would like to answer that question 3 There have been arguments made reiative 3 with respect to Scott Rothstein, his fabricated 4 to the Fifth Amendment and I think that you 4 cases and the reason he sits injaii. However, 5 have, in particular, Mr. Edwards, have 5 today, at ieast today, my counsel has advised me 6 attempted to balance what Mr. Epstein would 6 i must assert my rights under the Sixth, Fifth 7 like to do, versus what if he did that, 7 and Fourteenth Amendment. 8 whether or not there would be a waiver of 8 You say "at least today," but that?s 9 the Fifth, the Sixth and the Fourteenth. So, 9 something we have gone through with you day aftt 10 i understand your motion to strike and it is 10 day, after day, and you say "at least today," and 11 noted on the record, but I have to make 11 we wait for the next deposition and again there 12 clear for the record that there have been 12 is assertion of a Fifth Amendment right. Is 13 those arguments made and there is a balance 1 3 there ever going to he a day where you do answer 14 as to what someone would like to do versus 1 4 the questiOns? 15 what someone can do, and the resulting i5 MR. PIKE: Form. Move to strike. 1 6 consequences of that being waiver. 1 6 A On advice of counsel, as I've answered 1? Given What your attorney just said, my 17 most of your other questions here today, he them 18 understanding You have been instructed 1 8 argumentative Or not, meant for other purposes or 19 that if you answer these questions, as you would 19 not. my answer is gOii?lg to be that my counsel has 28 iike to, that it would incriminate you? 2 0 advised me that at least today i must assert my 2 1 MR. PIKE: Mischaracterizes my 2 1 rights under the Sixth, Fifth and Fourteenth 22 objection; and i instruct you not to 2 2 Amendment. 23 answer. 2 3 You indicated in your previous answer 2 4 Why is it that you would like-to answer 24 that most of the cases were brought by me or my 25 questions about whether or not you violated 2?5 former partner, Scott Rothstein. My 24 (Pages 425 to 428) U.S. Legal Support (561) 835-0220 429 431 1 understanding is that there were more than 20 1 other questions, which is, that upon advice of 2 cases brought against you alleging you sexually 2 counsel, at least today, they?ve instructed me 3 abused minors, and I have personally only filed 3 that I must assert my rights under the Sixth, 4 three. How many are you aware of in addition to 4 Fifth and Fourteenth Amendment. 5 the three that Scott Rothstein ?led, or brought, 5 Isn't it also true that through the 6 as you say? 6 years he has sent you as, quote, unquote, 7 MR. PIKE: Form, mischaracterizes the 7 "gifts," underage females, as young as 12 years 8 witness?s testimony. 8 old for you to illegally engage in sex with? 9 MR. EDWARDS: Do you want the previous 9 MR. PIKE: Form. to answer read back related to that? 10 A I?m going to respond to that question as 1 1 MR. PIKE: No, I think his answer will 1 I responded to most of your other questions, 12 he the same. 12 which is, upon advice of counsei, at least today, 1 3 A At least today i have to respond to that 13 though I would iike to answer the question, 14 question as I've responded to most of your other 1 4 they've instructed me I must assert my rights 15 questions here today, Mr. Edwards, which is, at 15 under the Sixth, Fifth and Fourteenth Amendment. 16 least today I have to assert my rights under the 16 In fact, you know that we served Mr. 17 Fifth, Sixth and Fourteenth Amendment. 17 Brunei for deposition in this case. Are you 18 in a portion of your answer, you 18 aware of that? 19 indicated that Scott Rothstein fabricated cases. 19 MR. PIKE: Form. 20 Are you alleging that the case of Jane Bee 2 0 A Fun going to have to respond to that 2 1 against Jeffrey Epstein is a fabricated case? 2 1 question as 1 respond to all your other questions 22 MR. PIKE: Form. 22 here today, Mr. Edwards, which is by asserting my 2 3 A I would iike to anSWer each one of your 2 3 rights under the Sixth, Fifth and Fourteenth 2 4 questions here today, Mr. Edwards, especiain 2 4 Amendment. 25 with respect to Jane Doe. However, my counsel 25 He has been a house-guest at your house 430 432 1 has instructed me i must assert my rights under 1 on numerous occasions this year; isn't that 2 the Sixth, Fifth and Fourteenth Amendment. 2 true? 3 Mr. Epstein, do you know a gentleman 3 MR. PIKE: Form. 4 named Jean Luc Bruno! and the last name is 4 A Though I would like to answer every one 5 spelled B-r~u-n-e-l. 5 of your questions here today, Mr. Edwards, 1 have 6 MR. PIKE: Form. 6 to respond to that question on advice of counsel A My counsel has advised me at ieast 7 the same way as I've responded to all of your 8 today, Mr. Edwards, as I?ve responded to roost of 8 other questions, which is, I must assert my 9 your other questions, I have to assert my right 9 rights under the Sixth, Fifth and Fourteenth 0 under the Sixth, Fifth and Fourteenth Amendment 10 Amendment. 1 1 Mr. Brunei is somebody that you know to 1 1 I've asked you simply, if Mr. Brunei has 12 be a child molester; is that right? 12 been a house guest of yours during the year 2810 13 MR. PIKE: Form. 13 and you're choosing to invoke your Fifth 1 4 A I would like to answer every one of your 1 4 Amendment right against self-incrimination and 5 questions here today, Mr. Edwards. However, on 1 basing that on your counsel's advice. 1 6 advice of counsel, they've instructed me i must 1 6 Does your counsel know that you made assert my rights under the Sixth, Fifth and that representation to Probation already this 1 8 Fourteenth Amendment. 1 8 year? 19 Mr. Brunei has been a close friend of 19 MR. PIKE: Form. 20 yours for years and is still a close friend of 20 Do you understand the question? 2 it yours today; is that right? 2 1 A Are you asking me what my counsei 22 MR. PIKE: Form. 22 knows? 23 A Though I would like to answer every one 23 No. 2 4 of your questions posed here today, I have to 2 4 A i think you just asked what my counsci 2 5 answer that one as I've answered most of your 2 5 knows. 25 {Pages 429 to 432) 0.3. Legal Support (561) 835?0220 433 435 1 MR. PIKE: That?s exactly what 3. MR. EDWARDS: Agreed. 2 A You should ask my counsel. 2 MR. PIKE: His response is his verbal 3 3 a your Probation Officer this year, in fact, I'll 4 MR. EDWARDS: i understand that, but 5 ask it this way: Have you indicated to your 5 certainiy if a witness is on the witness 6 i?robation Of?cer that Jean Lac Brunei has been a 6 stand we both know they are allowed to 7 house guest of yours during the year 2010? '7 observe the demeanor of the witness and part 8 MR. PIKE: Form. 8 of that demeanor is the nodding or shaking 9 9 10 answer that question, as I have been instructed 10 is we alt know and understand. I just want 11 to answer most of your other questions here 1 1 to make sure we are on the same page, the 12 today, which is by asserting my rights under the 1 2 jury can ignore those body movements? 1 3 Sixth, Fifth and Fourteenth Amendment. 13 MR. PIKE: As a matter of fact, and as 14 Do you know an attorney named Tama 4 you know, since you tried several cases, 1 5 Kudman? 1 5 there is a patterned jury instruction from 16 MR. PIKE: Form actualiy that?s not 1 6 the judge that says the jury can, in fact, 1 7 "form." 1 withdraw that. 1 7 take it into consideration. 18 A No. 18 MR. HOROWITZ: That's the point. 19 Bid Mr. Brunei tell you that Tania Kudman 19 MR. PIKE: I cannot instruct thejury in 20 was an attorney that was hired to represent him 20 this video deposition to ignore anything 21 humsmm? 21 22 MR. PIKE: I?m sorry, hold on. 22 MR. EDWARDS: That's why i wanted to 23 MR. EDWARDS: Did Mr. Brunei teii him. 2 3 engage -- so I would make sure we are a 24 ?wemwm?mdeMWwaMoWMHm 2 5 A i?m going to have to answer that 2 5 jury should be observing, what they can, 434 436 1 question as I've answered most of your other 1 versus his response. i guess for this time 2 questions here today, Mr. Edwards, which is by 2 we will get into it. 3 asserting my rights under the Sixth, Fifth and 3 In that last question that I asked you, a Fourteenth Amendment. 4 related to you or some entity that you control 5 And did you or some entity that you own 5 paying for the services of Ms. Kudman, is the 6 or control pay for the services of?I?ama Kudman to 6 answer "no" or is the answer that you are 7 represent Jean Lac Brunei, in this matter? 7 invoking your Fifth Amendment right to remain 8 MR. PIKE: Form. 8 . silent? 9 9 10 under the Sixth, Fifth and Fourteenth Amendment 10 A With respect to that question, as with 1 upon advice of counsel. 1 1 respect to all your other questions here today, 12 certainly don't want to get into this 12 Mr. Edwards, upon advice of counsel I have to 13 too often during this deposition but it is 13 assert my rights under the Sixth, Fifth and 14 visibly noticed on the video that prior to the 14 Fourteenth Amendment. 15 invocation of the Fifth Amendment, there is a 15 Isn't it true that you have speci?cally l6 shaking of the head which com monly indicates that 16 instructed Mr. Brunei to avoid his deposition in 17 the answer is and {just want to make sure 17 this case? 18 we are on the same page, that that was not 18 MR. PIKE: Form. 1 9 your indication and that we can ignore those 1 9 A Upon advice of counsel, as with respect 20 types of body movements, as Mr. Pike instructed 20 to most of. your other questions here today, I'm 2 1 me that was the case last time. 2 1 going to answer that the same way by invoking my 22 22 newsmanmsamjnaamrmemh 2 3 ciear. The court reporter does not 2 3 Amendment, sir. 2 a understand nods of the head, shakes of the 2 4 Mr. Epstein, can you describe for the 2 5 head, "um-hum" -- 2 5 jury your various schemes that you have devises 26 (Pages 433 to ?36) U.S. Legal Support (561) 835*0220 437 439 1 to access underage minor females for sex? 1 of my counsei, he's instructed me that i may 2 MR. PIKE: Form. 2 not. i must invoke my rights under the Sixth, 3 A Though I would like to respond to ail 3 Fifth and Fourteenth Amendment. 4 these questions that you've posed here today, Mr. 4 Mr. Epstein, is it true that you have 5 Edwards, I'm going to have to assert my rights 5 sexually molested underage minors in every 6 under advice of counsel under the Sixth, Fifth 6 community where you have homes or houses? "3 and Fourteenth Amendment. 7 MR. PIKE: Form. 8 I think the video will reflect that 8 A Though I would iike to answer each one 9 prior to your invocation at that time there was a 9 of your questions here today, Mr. Edwards, I 10 smile that I would characterize as a smirk, prior 10 would like to answer that questionthat answer, and I would like to understand, 3. 1 your partner, who sits in jail for fabricating 12 was there any intention on your part to convey a 12 cases of a sexuai nature against peopie iike me 1 3 message by that smile, prior to your invocation? l3 and others in South Fiorida, but today, upon 1 4 MR. PIKE: First of ail, this line of 14 advice of my counsel, they've instructed me I 1 5 questioning is not oniy argumentative, out 15 must assert my rights under the Fifth, Sixth and 1 6 it is harassing, okay? 1 6 Fourteenth Amendment. 17 MR. EDWARDS: We can play the video for 17 THE WITNESS: Before you go to the 18 18 badnoon? 1 9 MR. PIKE: You can piay the video, but 1 9 MR. EDWARDS: Move to strike the portion 2 0 if someone raises an eyebrow, blinks, does 20 of the answer that was nonresponsive. 2 1 somethingMR. PIKE: One second. 22 follow up with a harassing question is not 22 MR. EDWARDS: Move to strike the portion 2 3 only improper, but it is a waste of time, of 2 3 of the answer nonresponsive. 2 4 attorney resources as weii as judiciai 2 4 MR. PIKE: Move to strike your motion to 2 5 resources. I'm going to let you proceed, I 2 5 strike. 438 440 1 mean, -- come on. 1 MR. EDWARDS: Based on the fact that ii 2 MR. EDWARDS: With all due respect, I'm 2 was responsive? You feel it was 3 interpreting it as an act 3 responsive? I a 4 5 Fifth Amendment and any adverSe inference 5 MR. EDWARDS: It is fine if you do. 6 6 MRPWE:%m%hm%wmmemea 7 you acknowledged previously that ajury will 7 you're talking about heads and nod shakes. 8 have or could have the ability to view this 8 If you want to be clear for the record, I 9 video, and I'm assuming ajury could make 9 think, and i'm I think 1 think the 10 that same inference, so I want to make sure 10 witness is nodding and shaking his head in a 1 1 the record is just clear. if the manner because your questions are 12 answer is one answer and there is no body 12 argumentative. "Please tell me the scheme 13 13 dmtyoudevmedf 14 body movement, l?m probath going to address 14 "Please tell me who you molested," ail 15 it. 15 of these are argumentative questions 1 6 MR. PIKE: l?rn going to move to strike 1 6 MR. EDWARDS: If it wasn't true, it 17 your last narrative. 17 would be argumentative. 28 MR. EDWARDS: Okay. 18 MR. PIKE: They arejust not formed 1 9 What individuals other than yourself I. 9 right. You are sitting here subjecting the 2 0 helped you to devise your various schemes for 2 witness to questions that that are just 2 1 accessing large numbers of minor females for 2 1 argumentative. They are not structured 2 2 sex? 22 appropriately, and you're taking that and 2 3 MR. PIKE: Form. 2 3 you're implying something eise for the jury 2 4 A Though I wouid like to answer every one 2 4 on the record, and quite frankly, I don?t 25 of your questions today, Mr. Edwards, upon advice 2 5 appreciate that. So, yes, to answer your 27 (Pages 43? to 440) U.S. Legal Support (561) 835*0220 441 443 1 question, it 100 percent is responsive. He 1 that one, however, upon advice of counsei they've 2 is invoking his Sixth, Fifth and 2 instructed me that i must assert my rights under 3 Fourteenth. 3 the Sixth, Fifth and Fourteenth Amendment, and i1 4 THE WITNESS: Bathroom break now? 4 i don't do so, risk losing that representation. 5 MR. EDWARDS: That?s fine. 5 What is special about the question of 6 THE VIDEOGRAPHER: Off the video record 6 you molesting children on a daily basis for the 12:35 pm. "3 better part of two decades, that you would 8 (Pause in the proceedings.) 8 especially like to answer that question? 9 MR. EDWARDS: I will be asking you to 9 MR. PIKE: I'm sorry? 10 read back the last question and answer, so 10 MR. EDWARDS: His answer was that he 1 1 yotfre ready. 1 1 would especially like to answer that 12 THE COURT REPORTER: Certainly. 1 2 previous question and the question posed to 1 3 THE VIDEOGRAPHER: Back on the video 1 3 him 1 4 record 1:16 pm. 1 4 isn't it true for the better part of two 15 MR. EDWARDS: Madam Court Reporter, if 15 decades you have molested children on an ever) 1 6 you couid read back the last question, as 1 6 day basis. And I'm asking now, what is it ahou well as the iast answer which I have been 17 that question that makes you especiaily want to 1 8 told was responsive. 18 respond to that one? 1 9 THE COURT Certainly. 1 9 MR. PIKE: Form. 2 0 (The record was read.) 20 A Though i would like to answer that 2 1 Mr. Epstein, why is it that you would 2 1 question as weii as your other questions here 22 like to teii Scott Rothstein whether you have 22 today, Mr. Edwards, upon advice of counsel, 23 sexually molested underage minors in the various 23 they?ve told me i must assert my rights under the 24 communities where you have homes? 24 Sixth, Fifth and Fourteenth Amendment, or risk 2 5 MR. PIKE: Form. Mischaracterizes the 2 5 losing my representation. 442 444 fl witness's testimony. 1 Is it true that you have intentionally 2 A I would like to answer that question, as 2 prayed on vulnerable children as young as 12 3 well as all of your other questions, Mr. Edwards, 3 years old on an every day basis, for sexual 4 however today my counsei has advised me i must 4 purposes {or the last decade? 5 assert my rights under the Sixth, Fifth and 5 MR. PIKE: Form. I 6 6 7 Can you tell the jury what, if anything, 7 question, as weil as other questions posed by 8 Scott Rothstein has to do with the allegations of 8 you,, and i would prefer to respond to both you 9 you molesting underage children? 9 and your partner, Scott Rothstein, who sits in 10 MR. Form. 10 jail for fabricating questions of a sexual 1 1 A Though I think the jury will find out 1 1 nature, cases of a sexual nature against people 12 what Scott Rothstein has to do with all these 12 iike me and others in South Florida. You were 1 3 cascs, i hepe that?s the case. i have been 1 3 part of a law firm that the U.S. Attorney refers 1 4 instructed by my counsel to respond the largest criminal enterprises in 5 your questions, most of your questions here 1 5 South Florida?s history, so though I would like 1 6 today, but I have to assert my Sixth, Fifth and 1 6 to answer, and you probably mark my question 1 Fourteenth Amendment. 17 as nonresponsive, my counsel has told me today i 1 8 MR. EDWARDS: More to strike the portion 18 must not answer that question and must assert my 1 9 of nonresponsive related to Scott Rothstein. 1 9 Sixth, Fifth and Fourteenth Amendment right. 20 is it true for the better part of two 28 MR. EDWARDS: Move to strike the answer 2 1 decades you have interacted sexually with 2 1 as nonresponsive. All other portions 22 underage minors on a daily basis? 22 portion of the answer, all but the 2 3 MR. PIKE: Penn. 2 3 invocation of the Fifth Amendment. 24 A i would like to answer every one of your 24 Please describe for the jury the plan or 2 5 questions here today, Mr. Edwards, especially 25 scheme that you employed to access the underagi 28 (Pages 441 to 444) U.S. Legal Support (561) 835?0220 minor females of Palm Beach County, including 1 A Though i would like to answer that 2 Jane Doc. 2 question, as well as all the other questions 3 MR. PIKE: Form. 3 you've posed here today, Mr. Edwards, upon advice at A i would like to answer that question as 4 of counsel, they've instructed me i must assert 5 I would like to have answered most of your other 5 my rights under the Sixth, Fifth and Fourteenth 6 questions here today, especially with respect to 6 Amendment. 7 lane Doe, as she is your client, but on advice of 7 With each and every underage minor 8 counsel they?ve instructed me that I must, must 8 female that arrived at your house under the idea 9 assert my Sixth Amendment, Fifth Amendment and 9 they were to give you a massage, they were first 1 0 Fourteenth Amendment right, so therefore that?s 10 led up and left alone in your bedroom with you; 1 1 what I'm going to do. 1 is that correct? 12 Despite your preference you're going to 12 MR. PIKE: Form. 13 listen to your counsel. 13 A Again? Repeat the question. 14 MR. PIKE: Form, l?m going to instruct 1 4 This is a scheme that you've employed 15 you not to answer that question. 1 5 for years and years, and years, and somehow it 6 MR. EDWARDS: As to whether or not he is 1 6 you're having a hard time grasping how a schemt 17 going to listen to counsel? 1 7 that you devised worked? 18 MR. PIKE: He's already invoked on 18 MR. PIKE: No. Move to strike. You 19 advice of counsel. 19 don?t have a question on the table. 2 0 MR. EDWARDS: That last question was 20 Actually your previous question prior to 2 1 taken right out of Bob Critton's play book. 2 3. what you just stated did not involve any 22 MR. PIKE: Take it up with the Court. 22 word, quote, "scheme," end quote. If you 2 3 Bob Critton is not here, i am. 23 want to repeat the question, go ahead. 2 4 Isn?t it true as part of the plan to 2 4 Isn't this how it worked, that an 2 3 access young girls betWeen 12 and 17 years old in 25 underage minor female would come to your hous - i?ahn Beach County, that you Would send a message 1 and you instructed or did you instruct Sarah 2 that you would be willing to pay those females 2 Kellen or one of your other assistants to lead 3 for them providing you a massage at your house? 3 that minor female up to your bedroom to be left 4 MR. Form. 4 alone with you? 5 A You have to repeat the question. 5 MR. PIKE: Form. 6 Sure. The initiation, the manner in 6 A Though I would like to answer that 7 which you gained access to underage girls between 7 question as well as all the other questions 8 the ages of 12 and 17 in Palm Beach, is that you 8 you've posed here today, Mr. Edwards, upon advice 9 would initially have somebody tell them that they 9 of my counsel they've instructed me i must assert 10 could come to your house and give you a massage 10 my rights under the Sixth, Fifth and Fourteenth 1 1 and you would pay them for their time. 1 1 Amendment. 12 MR. PIKE: Form. 12 Once that underage minor female, 3.3 THE WITNESS: It is not a question. 13 normally between the ages of 12 and 17 would 3.4 A You didn?t ask me a question. You made 14 arrive in your bedroom, you would then appear 15 a statement. 15 naked or wearing only a towel each time; is that 16 THE WITNESS: if you want to repeat it 16 correct? 17 back. 17 MR. PIKE: Form. 3.8 (Indicating the court reporter.) 18 A i would like to answer each one of your 3. 9 I'll make it clearer for you. 1 9 questions, Mr. Edwards. However, today my 20 A Thank you. 20 counsel has advised me that I must assert my 2 1 Did you send a message to various 2 1 rights under the Sixth, Fifth and Fourteenth 22 underage minor females, that you would pay for 22 Amendment. 2 3 those underage minor females to provide you a 2 3 After appearing naked or wearing only a 2 4 massage at your house? 2 4 towel, then wouldn't you instruct the underage 2 5 MR. PIKE: Form. 2 5 minor female to get naked herself? 29 (eages 445 to d48) U.S. Legal Support (561) 835*0220 VJ 449 451 1 MR. PIKE: Form. 1 rights under the Filth, Sixth and Fourteenth 2 A Though i would like to answer all of 2 Amendment or, in fact, potentially lose my right 3 your questions here today, I'm going to have to 3 to representation. 4 respond to that question as I?ve responded to 4 What you?re saying with that answer is 5 most of your others here today, which is by my 5 that your counsel will not represent you anymore 6 counsel's instructing me that i must assert my 6 if you choose to waive your Fifth Amendment 7 rights under the Filth, Sixth and Fourteenth 7 rights and begin to answer these questions? 8 8 9 Then, once the underage minor female was 9 advice of counsel, if you know what the 10 naked, you would attempt various lewd or 10 Sixth Amendment is and how it reads, you 1 1 laseivious improper sexual acts against that 1 would understand what the invocation is, in 12 underage minor female, correct? 12 full. So move to strike your 13 MR. PIKE: Form. 13 MR. EDWARDS: Question? 1 4 A Though I would like to respond to all of 1 4 MR. PIKE: -- last question, and it 1 5 your questions, Mr. Edwards, have to respond to 15 mischaracterizes the witness's testimony. 1 6 that as I responded to all of the other questions 1 6 Do you know what the Sixth Amendment is, Mr. here today that you?ve posed, which is that my 17 Edwards? 1 8 counsel, at least today, has instructed me I. must 18 MR. EDWARDS: Yesassert my rights under the Sixth, Fifth and 1 9 deposition and I?m not sure your client 2 0 Fourteenth Amendment. 20 knows about the effective assistance of 2 1 And you would always pay cash money to 2 1 counsel or any amendment 22 the underage minor female after you improperly 22 MR. PIKE: Do you know how due process 2 3 audio!? illegally sexually abused that underage 2 3 clause affects the 6th Amendment? 2 4 minor female, correct? 2 4 Never mind, just go ahead. I'm sorry. 2 5 MR. PIKE: Form. 2 5 MR. EDWARDS: However, the statement we 450 452 1 1 2 every one of your questions here today, Mr. 2 would prefer to do, which seems remarkable 3 Edwards, my counsel has advised me I must assert 3 and incredible, then he would be tired or 4 my rights under" the Sixth, Fifth and Fourteenth 4 you would be tired {from him, and i want to 5 Amendment. 5 understand what 6 Each of these sessions or sexual 6 Why is it that your attorneys will no 7 interactions between you and underage minor 7 longer represent you if you choose to do what you 8 females ended, when you had ejaculated, correct? 8 want to do, which is answer these questions? 9 MR. PIKE: Form. 9 MR. PIKE: Move to strike. 10 A would like to answer that question, as 10 Do you want to ask a question? Because 1 1 i would like to answer all of your other 1 1 Put not quite sure he even testified to 12 questions here today. However, today at least, 12 that. We have been through several 13 13 1 4 my rights under the Sixth, Fifth and Fourteenth 1 4 from the invocation of the Fifth, Sixth and 1 5 Amendment. 1 5 Fourteenth that does not exist. There has 1 6 After paying the underage minor female 1 6 been no mention of ?ring, there's been no 17' for being sexually molested, you would ask the 17 mention of withdrawing, there?s been no 18 underage minor female to leave her telephone 18 mention of anything of the sort. 19 number with one of your assistants; is that 1 9 MR. EDWARDS: Can we go back to the 2 0 correct? 2 0 question and response that ended with "i 2 1 MR. i?lKE: Form. 21 risk losing 22 A I would like to answer that question. I 22 THE COURT REPORTER: Certainly. 2 3 would like to answer most of your other questions 2 3 MR. l?lKB: Once again, do you know that 2 4 here today; however, at least today my counsel 2 4 the Sixth Amendment is? 25 has advised me that I may not, and must assert my 2 5 MR. EDWARDS: Yes. 30 (Pages 449 to 452) 0.8. Legal Support (561) 835-0220 453 455 1 MR. PIKE: Would you like to Googie it? 1 A Though I would like to answer that 2 Because that Sixth Amendment 2 question as well as all the other questions 3 MR. EDWARDS: She will have a hard time 3 you?ve posed here today, Mr. Edwards, I'm afraid 4 going back, if you continue talking. She 4 that upon advice of counsel they've instructed me 5 has to type while you talk. 5 that I must assert my rights under the Sixth, 6 MR. PIKE: The Sixth Amendment, as 6 Fifth and Fourteenth Amendment. 7 incorporated into the due process clause, 7 And a separate offer was made to each 8 which is the Fourteenth Amendment is the 8 underage minor female as well. That is, if she 9 right to effective assistance ofcounsei. 9 brings you other underage minor females so the: 10 MR. EDWARDS: i understand. 3.0 you can sexuaily abuSe, then you would pay a 3. 1 MR. PIKE: Ifyou read it in full, it 1 ?nder's fee for each underage minor female 1 2 will kind of shed light and you can probath 12 brought to you; is that correct? 1 3 glean the invocation and the meaning of it 13 MR. i?lKE: Form. 1 4 from his response. 14 A I would like to answer every one of the 1 5 is there a question? 15 questions you?ve posed here today, Mr. Edwards. 16 MR. EDWARDS: Go back, please. 16 However, today at least, upon advice of counsel, 1 7 (The record was read.) they have instructed me I must assert my rights 1 8 So your counsel told you that you must 18 under the Sixth, Fifth and Fourteenth Amendment. 19 invoke your Fifth Amendment right to remain 19 Haley Robson was a female that brought 2 0 silent, otherwise you will lose your right to 20 you multiple underage minor females; is that 2 1 their representation; is that what you're 2 1 correct? 22 saying? 22 MR. PIKE: Form. 2 3 MR. PIKE: Move to strike. 2 3 A Though I would like to answer every one 2 4 Mischaracterizes the witness's testimony, 2 4 of your questions that you?ve posed here today, 2 5 and misconstrues and 2 5 my counsel has instructed me i must assert my 454 456 1 misinterprets the Fifth, Sixth and 1 rights under the Sixth, Fifth and Fourteenth 2 Fourteenth Amendments. 2 Amendment. 3 I'm going to instruct you not to answer 3 L.M. was an underage minor femaie that 4 that question, because i don't understand 4 you ?rst abused when she was 13 years old; is 5 5 mewu? 6 because -- 6 MR. PIKE: Form. 7 MR. EDWARDS: i wrote down the response 7 A Though I would like to answer every 8 MR. PIKE: -- and because, if I 8 question you have regarding LM. here today, my 9 understand, your question, you phrased it 9 counsel has instructed me that I must assert my 1 0 as, "So ifl understand you, your attorney to rights under the Sixth, Fifth and Fourteenth 1 1 told you," so i'm going to instruct you not 1 1 Amendment. 1 2 to answer that question because it will, 3.2 While L.M. was a minor, she brought you 13 apparently, it would disolose my 3.3 more than 58 underage minor females that you 14 communications with you, so there you go. 1 4 sexually abuse, correct? 15 MR. EDWARDS: in his answer he said, "My 15 MR. PIKE: Form. 1 6 counsel said i can?t respondwould like to answer all the questions telling me already what 17 you have regarding L.M., here today. However, at 18 MR. PIKE: That?s not what he said. He 18 least today my counsel has instructed me I may 1 9 said ?On the advice of counsel." 1 9 not. I must assert my right under my Sixth, 20 MR. EDWARDS: All right. 20 Fifth and Fourteenth Amendment. 2 1 The offer was then made to each underage 2 1 One of the underage minor females 22 minor female that each time she returned to your 22 brought to you by LM. was Jane Doe, when Jan . 2 3 home and you sexually molest her, she will then that correct? 2 be paid cash; is that correct? 2 4 MR. PIKE: Form. 25 MR. PIKE: Form. 2 5 A I would like to answer the questions 31 (Pages 453 to 456) U.S. Legal Support (561) 835-0220 4 57 4 5 9 1 regarding Jane Doe and Mr. Edwards. 1 MR. EDWARDS: No, l?n1 asking if your 2 However, at least today my counsel has instructed 2 client agrees with the assertion that's 3 me i must assert my rights under the Sixth, Fifth 3 stated in the complaintand Fourteenth Amendment. 4 defense that is going to defeat such 5 Looking at the operative complaint in 5 assertion or evidence that is going to 6 Jane Doe versus Jeffrey Epstein case 80893, 6 defeat such assertion. So i'm simply asking 7 referring to the plaintiff Jane Doe, ?rst 7 your 8 indicates this is an action for damages in an 8 Is that a true statement? 9 amount in excess of 50 million dollars. 9 MR. 91KB: Form. 10 Is that a number that you would agree 1 0 A I would like to answer all of. your l. i. would fairly compensate her, as well as punish 1 questions about Jane Doe and your other clients. 12 you for the conduct you committed against Jane 12 However, today my counsel has told me that I may 1 3 Dee? 3. 3 not. I must assert my rights under the Sixth, 1 4 MR. PIKE: Form. 1 4 Fifth and Fourteenth Amendment. 15 A I would like to answer that question. I 15 You did personally call Jane Doe on the 1 6 would like to answer all of your other questions 1 6 telephone on at least one occasion; isn't that that you've posed here today, Mr. Edwards. 1 7 true? 18 However, at least today, on advice of counsel 1 8 MR. PIKE: Form. 1 9 they?ve instructed me that I may not and have 1 9 A I would like to answer your questions 20 instructed me that i must assert my rights under 20 regarding calling Jane Doc, or contacting Jane 21 the Sixth, Fifth and Fourteenth Amendment. 2 1 Doc. However, my counsel has instructed me that 22 One of the allegations Jane Doe makes is 2 2 today, at least, i may not. I must assert my 23 that Jeffrey Epstein demonstrated sexual 23 rights under the Sixth, Fifth and Fourteenth 24 preference and obsession for minor girls. ls it 24 Amendment. 25 true that you have a sexual preference and 25 And at the time when you contacted Jane 458 460 obsession for minor girls? 1 Dee, was the purpose to have her come to your 2 MR. PIKE: Form. 2 house and interact with you Sexually? 3 A i would like to answer the question with 3 MR. PIKE: Form. 4 respect to what Jane Doe said, however, my 4 A Can you repeat the question? 5 counsel today has instructed me that I must 5 Yes, the time that you called Jane Doe, 6 assert my rights under the Sixth, Fifth and 6 was the purpose of your call to have her come to 7 Fourteenth Amendment. 7 your house and interact with you sexually? 8 Another allegation is that defendant 8 MR. PIKE: Form. 9 Epstein's planned scheme and enterprise included 9 A I would like to answer that question as 10 an elaborate system wherein the then minor 10 I would like to answer all of your other 11 plaintiff and other minor girls were contacted by 1 questions with respect to Jane Doe, your client. 12 telephone by Epstein, Sarah Kellen or other 1 2 However, iOda)? at least, my 0091139} 1135 13 unknown employees or assistants working for 1 3 instructed me i must assert my rights under the 14 Epstein, and were then persuaded to come over tr 14 Sixth, Fifth and Fourteenth Amendment. 1 5 Epstein's house for the purposes of engaging in 5 MR. EDWARDS: Move to strike a portion 16 prostitution. 1 6 of the answer that's nonresponsive. 1 7 Is that a true statement? 17 Sarah Kellen was one of your assistants 18 MR. PIKE: First, For going to object to 1 8 back in the years 2003, 2004 and 2005, correct? 19 the form and second, I believe you?re 1 9 A I would like to answer each One of your 20 working from a portion of a complaint 2 0 questions, Mr. Edwards, here today; however, on 21 especially with your reference to scheme and 2 1 advice of counsel, at least today l'm going to 2 2 the RICO allegations that were dismissed 22 have to assert my rights under the Sixth, Fifth 23 with prejudice. So, I just want to he 23 and Fourteenth Amendment. 24 clear, are you doing discovery on a count 24 Sarah Kellen called by telephone Jane 2 5 that no longer exists? 2 5 ?ee when Jane Doe was a minor child, on more thap 32 (Pages 457 to 460) U.S. Legal Support (561) 835?0220 461 463 1 15 occasions; isn?t that true? 1 of your private airplane to Palm Beach for the 2 MR. PIKE: Form. 2 speci?c purpose of luring minor girls to your 3 A Mr. Edwards, would like to answer 3 mansion for the purposes of sexually abusing 4 every one of your questions regarding Jane Doc 4 them? 6 5 6 today, on advice of counsel l'm going to have to 6 A I would like to answer that question, 7 assert my rights under the Sixth, Filth and 7? Mr. Edwards,, but today at least, on advice of - 8 8 9 The purpose of Sarah Kellen contacting 9 Sixth, Fifth and Fourteenth Amendment rights. 10 the minor child Jane Doe back in 2083, 2004 and 10 Isn't it true that you conspired with 11 2005, was always to get her to come to your house 1 1 others to contact minor females including Jane 12 to interact with you sexually; is that correct? 12 Doc, for the purposes of sexually abusing Jane 13 MR. PIKE: Form. 13 Dee? 14 A i would like to answer that question as 14 MR. PIKE: Form. 15 15 1 6 here today regarding your client, Jane Doc. 1 6 Mr. Edwards, as well as every other question 17 However, at least today, my counsel has advised 7 you've posed here today. However, at least today 18 me i must assert my rights under the Sixth, Fifth 1 8 upon advice of counsel they?ve instructed me to 19 and Fourteenth Amendment. 1 9 assert my Sixth, Filth and Fourteenth Amendmem 2 0 Did you or Sarah Kellen or any of your 2 0 right. 2 1 other assistants contact Jane Doe for some other 2 1 Isn't it true that your sexual 2 2 purpose than to have her come to your house for 2 2 interaction with Jane Doe occurred speci?cally .2 3 you to sexually molest her? 2 3 during the time period, February 2003 through 2 4 MR. PIKE: Form. 2 4 June 2005? 2 5 A Though I would like to answer every 2 5 MR. PIKE: Form. 462 464 1 1 2 Jane Doe, Mr. Edwards, my counsel has advised me, 2 Mr. Edwards, as I've responded to all your other 3 at least today, that I may not and must assert my 3 questions, which is that today at least 0n advice 4 rights under the Filth, Sixth and Fourteenth 4 of counsel 1 must assert my rights under the 5 5 6 Each call that was made by you or on 6 During the time Jane Doe was under the 7 your behalf to Jane Doe, was made at a time when 7 age of 16, isn't it true that you digitally 8 Jane Doe was a minor child, true? 8 penetrated her vagina? 9 MR. PIKE: Form. 9 MR. Form. 10 A I would like to answer that question as 1 A i would like to answer that question, as 11 U. 12 .lane Doe, Mr. Edwards. However, today my counsel 12 today my counsel has advised me I must assert my 13 has advised me I may not and must assert my 1 3 rights under the Sixth, Fifth and Fourteenth 14 rights under the Sixth, Fifth and Fourteenth 14 Amendment. 1 5 Amendment. 1 5 Immediately following that question, you 16 In addition to your Palm Beach home, 16 clearly smiled and rolled your eyes. Is there 17? isn't it true that you own a, what has been 17 anything that we should read or the jury should 18 called a mansion in New York, a ranch in New 18 read into that body language? - 19 Mexico, a home in France, as well as an island in 19 MR. PIKE: I?m going to instruct you not 20 the Virgin islands? 2 0 to answer the question. 2 1 MR. PIKE: Form. 2 1 i move to strike it as harassing. 22 A I?m sony, but today at least, on advice 2 2 MR. EDWARDS: Move to strike what as 2 3 of counsel have to assert my rights to the 2 3 harassing? It is something that everybody 24 Sixth, Fifth and Fourteenth Amendment. 24 is going to be able to see and I want to 25 25 33 (Pages 461 to 464) 0.3. Legal Support (561) 835?0220 465 467 1 2 2 3 MR. EDWARDS: How are you instructing 3 MR. EDWARDS: I will. 4 not to answer a question? 4 MR. PIKE: Mark the record. If you 5 MR. Because I am. 5 will. 6 MR. EDWARDS: Based on what? 6 MR. EDWARDS: it is marked. i?mjust 7 MR. PIKE: Becauso it is harassing. wondering whether there is going to he a 8 MR. EDWARDS: i?m not harassing. i want 8 privilege asserted or it is just going to be 9 to know why he did what he did. 9 a blanket, "l'm telling the witness not to 10 10 1 1 mean, it is an argumentative question 1 1 is going to view and should be entitled to 1 2 MR. EDWARDS: tie harassed my clients. 12 know what it means. 13 MR. PIKE: he has been here since 13 MR. PIKE: (Counsel shrugs.) 1 4 10:00 o*clock. He's given several 1 4 MR. EDWARDS: Youjust don't like that 1 5 depositions. This is Volume ill of a 15 your client is giving those body language 1 6 continuation, okay? He?s sitting here 1 6 responses. 17 waiting for your questions but not waiting 1? MR. PIKE: No. Move to strikeharassed. 8 nothing do with that. it has to do with a 19 There is a way to prevent those 19 signi?cant fact, that on a legal basis 20 questions, and that's not do that type of rolling 20 you?re attempting to badger and harass the 2 1 your eyes. 2 1 witness, based upon what you believe are 2 2 MR. PIKE: You're not going to instruct 22 some sort of facial expressions and you?re 2 3 the witness on how to the witness is here 2 3 attempting to get an adverse inference from 2 4 behaving professionally -- 24 an answer. I'm not going to let him answer 25 25 466 468 1 MR. PIKE: Answering your questions, 1 adverse inference relative to some gesture. 2 invoking his Constitutional rights under the 2 MR. EDWARDS: We taice it up, fine. 3 United States Constitution. And Fm sorry 3 MR. l?lKE: Take it up. 4 that that doesn?t make you happy, but I'm 4 Mr. Epstein, isn't it also true that you 5 not here -- 5 used a vibrator or vibrating device on Jane Doe' 6 MR. EDWARDS: it doesn?t make him happy 6 vagina when she was under the age of 16? 7" either, apparently. 7 MR. PIKE: Form. 8 MR. PIKE: i'm not here to dispute 8 A I would like to answer ail of your 9 9 10 being invoked and whether you feel it is 10 of counsel, they've advised me that I may not and 1 1 right or wrong. If you have a question, ask 1 1 must assert my rights under the Sixth, Fifth and 12 the witness a question. 12 Fourteenth Amendment. 13 Why did you roll your eyes when I asked 13 Isn't it also true when Jane Doe was a 14 you if you digitally penetrated Jane Doe when she 14 minor child, that you masturbates! on multiple 15 was 14 and 15 years old? 15 occasions in her presence? 16 MR. PIKE: I?m instructing you not to 16 MR. PIKE: Form. answer that question. 1 7' A i would like to answer all of your 3. 8 MR. EDWARDS: Your reason for the 18 questions regarding Jane Doe. However, today my 19 instruction is based on some privilege? 19 counsel has advised me that I may not, and have 2 0 MR. PIKE: My reason for the instruction 2 instructed me to assert my rights under the 2 1 is that you are attempting to play fast and 2 1 Sixth, Fifth and Fourteenth Amendment. 2 2 loose with the Filth Amendment and adverse 22 in June of 2908, isn't it true, sir, 2 3 inference. 23 that you entered pleas of guilty to various 24 MR. EDWARDS: I?m not. 24 felony -- to two felony charges in Palm Beach 25 MR. PIKE: Yes, you are, and I?m not 25 County? 3 34 (Pages 465 to 468) U.S. Legal Support (561) 835-0220 469 471 1 MR. PIKE: Asked and anSWered within 1 liability"? 2 this deposition. 2 Are you familiar with that section of 3 A Yes. 3 the agreement? 4 And as a result of those guilty pleas 4 MR. PIKE: Form, and the document speaks 5 you were sentenced to 18 months incarceration in 5 for itself. 6 6 7 MR. PIKE: Asked and answered. 2 Are you familiar with that portion of 8 A 8 9 in addition to the sentence related to 9 A i'm not sure what you mean by "familiar 10 those felony charges, isn't it also true that you 10 with," Sir. 11 entered into an agreement known as the 11 Have you read it? 12 "Nonprosecntion Agreement," with the federal 12 A Yes. 13 government? 13 So, if Jane Doe were to bring a claim 14 MR. PIKE: I'm sorry, would you read 14 exclusively under 18 USC 2255, then you already 15 that back, Madam Court Reporter? 3.5 contractually agreed to waive your right to 1 6 (The record was read.) 1 6 contest liability to that claim; is that true? 17 MR. PIKE: Can you reword the question? 17 MR. PIKE: Form, and calls for a legal 18 MR. EDWARDS: Sure. 18 conclusion. 19 Did you enter into an agreement with the 19 A Upon advice of counsel, though i would 2 0 federal government that is entitled 2 0 like to answer all of your questions here today, 2 1 "Nonprosecution Agreement"? 2 1 they've instructed the I must assert my rights 2 2 A Yes. 2 2 under the Sixth, Fifth and Fourteenth Amendment. 23 And that Nonprosecution Agreement at 23 THE WITNESS: Five minutes? 24 paragraph 7 indicates that "The United States 24 MR. EDWARDS: Whatever you need. 2 5 shall provide Epstein's attorneys with a list of 2 5 THE WITNESS: Okay. 470 472 1 individuals Whom it has identified as victims, as 1 THE Going off the video 2 de?ned in i8 USC 2255, after Epstein has signed 2 record 1:51 pm. 3 this agreement, and been sentenced." Have you 3 (Pause in the proceedings.) 4 seen the names of the identified victims that 4 THE Back on the video 5 were supplied by the U.S. Attorney?s office? 5 record 2:5? pm. 6 A i would like to answer that question as 6 The speci?c federal statute that is "i I would like to answer most of your other 7? incorporated in the Nonprosecution Agreement, 12 8 questions here today, Mr. Edwards. However, upor 8 USC 2255, states - rather than do it that way, 9 advice of counsel they've instructed me that 9 let me just ask the question. 10 must assert my rights under the Sixth, Fifth and 1 0 Mr. Epstein, did you knowingly conspire 1 Fourteenth Amendment. 1 with others to use a telephone to persuade, 12 And isn't it true that Jane Doe was on 1 2 induce or entice minor females, including Jane 3. 3 that list of victims that was supplied to you by 3 Doc, to engage in prostitution? 14 the United States? 14 MR. PIKE: Form. 1 5 A i would like to answer that question. 15 A Though i would like to answer that 1 6 However, at least today my attorneys have advised 6 question, as most of your other questions, I have me that I must 8358115 my rights under the Sixth, 17 to respond by telling you that my attorneys have 1 8 Fifth and Fourteenth Amendment. 1 8 told me, at least today, that I must assert my 1 9 in paragraph eight of the Nonprosecution 9 rights under the Sixth, Fifth and Fourteenth 20 Agreement between you, Mr. Epstein, and the 20 Amendment. 2 1 United States Attorney's Office, it indicates, 21 Mr. Epstein, did you knowingly and 22 "If any of the individuals, referred to in 2 2 willfully conspire with others to travel 2 3 paragraph referring to the list of victims, 2 3 interstate for the purpose of engaging in illicit 2 4 "elects to file a lawsuit pursuant to 18 USC 2 4 sexual conduct with minors, including Jane Doe? 25 2255, Epstein waives his right to contest 25 MR. PIKE: Form. i 35 (Pages 469 to 472) 11.8. Legal Support (561) 835*0220 473 475 1 A Though I would like to answer that exclusively under 18 USC 2255, that you waived 2 question, as wet} as most of your other~ questions 2 your right to contest liability? 3 here today, Mr. Edwards, in fact, at! of the 3 MR. PIKE: Form. Aiso, coaid salt for 4 other questions here today, my counsei has 4 the disclosure of attorneyfclient 5 instructed me at Eeast today, i must assert my 5 communications and work product, and is 6 rights under the Fifth, Sixth and Fourteenth 6 protected under the Federal Rule of Evidence 7 Amendment. 7 502408, as welt as 410? 8 Mr. Epstein, did you use a telephone to 8 A Though I woutd like to answer that 9 knowingly persuade, induce or entice minor 9 question, Mr. Edwards, I have to invoke my rights 10 females, including Jane Doc, to engage in 10 under the Sixth, Fifth and Fourteenth Amendment. 1 prostitution? 1 In a recent motion for summary judgment 12 MR. PIKE: Penn. 12 filed on your behalf, 3 statement is made, 13 A Though I would like to answer that 1 3 "Epstein never using a facility or means of 14 question, as wet! as your other questions today, 1 4 interstate commerce, knowineg persuaded, inducer 15 Mr. Edwards, at least today, my counsei has 1 5 or enticed Jane Doe when she was under the age of 6 instructed me that I must assert my rights under 1 6 18 years, to engage in prostitution or sexual the Sixth, Fifth and Fourteenth Amendment. 1 7 activity for which any person can be charged with 3.8 Mr, Epstein, did you travei, interstate 3 a criminai offense or attempted to do so." That 19 commerce for the purpose of engaging in illicit 9 is a false statement, true? 20 sexual conduct with minor females, including Jane 20 MR. PIKE: Penn. 2 1 Doc? 2 1 A Though I wouid like to answer that 22 MR. PIKE: Form. 2 2 question, on advice of counsel I have been 23 A Though I woutd iike to answer that 23 instructed to assert my rights under the Sixth, 24 question, as weii as the other questions you?ve 24 Fifth and Fourteenth Amendment, 25 posed here today, Mr. Edwards, I?m afraid that my 25 The statement was also made on your 4?4 ?76 1 counsei has instructed me that I must assert my 1 behalf, "Epstein never attempted to or conspired 2 rights under the Sixth, Fifth and Fourteenth 2 to knowingly transport Jane Doe in interstate or 3 Amendment. 3 foreign commerce or in any Commonwealth territor 4 Isn?t it true that you agreed with the 4 or possession of the United States, with intent 5 federal government that if Jane Doe brought 5 that Jane Doe engage in prostitution or in any 6 claims exclusively alleging those sections of 18 6 sexual activity for which any person can be 7 USC 2255 that I've read in the preceding, four 7 charged with a criminal offense." 8 paragraphs, that you would admit unto 8 That is also a false statement; isn't 9 her as an identi?ed victim? 9 that right? 1 0 MR. PIKE: Form. 10 MR. PIKE: Form. 1 1 A i don?t beiieve that's what the document 1 1 A You said "Jane Doc.? 12 says. 12 (2 Jane Doe is Jane Doe in this case. 1 3 The document saysMR. PIKE: Form. 1 4 individuals referred to in paragraph 7 elects to 1 4 A ibelieve her deposition speaks to 1 5 file suit pursuant to 18 USC 2255, Epstein waives 1 5 that. With respect to anything else, i have to 1 6 his right to contest liability, and also waives 1 6 assert my rights under the Sixth, Fifth and 1 7 his right to contest damages up to an amount as Fourteenth Amendment. 18 agreed to betWeen the identified individual and 18 You bctieve that Jane Doe's deposition 19 Epstein, so long as the identified individual 19 speaks to whether you attempted or conspired to 2 0 eiects to proceed exclusively under 18 USC 20 knowineg transfer Jane Bee in interstate 2 1 2255." 2 commerce, correct? 22 That's the provision. ask you then 22 MR. PIKE: Form. 2 3 the question: Didn't you agree with the federal 23 You believe her deposition speaks to 2 4 government that if Jane Doe, an identi?ed 24 that? 2 5 victim, proceeds in a case against you, 25 A That?s my belief, yes. 36 (Pages 473 to 476} 0.8. Legal Support (561) 835-0220 And then would you adopt her deposition 1 legal consent? 2 testimony as true and as your support for that 2 MR. PIKE: One Form. 3 assertion? 3 A Without her legal consent? 4 MR. PIKE: Form. 4 Yes. 5 A You're asking her entire deposition 5 A Can you tell me what that means? 6 testimony? 6 In order to answer that question, i need 7 The deposition as it relates to whether 7 to explain to you what legal consent means? 8 or not you knowingly transported her in 8 A Yes, sir. 9 interstate commerce. 9 Let's start with this question 10 A Well, I would like to answer that A Can you explain it to me? 1 1 question, but on advice of counsel, at least 1 1 Do you believe that a 14?year old child 12 today, i. have been instructed to assert my rights 3.2 can legally consent to sexual interaction with a 13 under the Sixth, Fifth and Fourteenth Amendment. 3. 3 man like you that was over the age of 50? 3. 4 A statement that Epstein never attempted 1 4 MR. PIKE: Form. 1 5 to or conspired to travel in interstate commerce 1 5 THE WITNESS: Asking for a 1 6 or travel into the United States or travel in 6 MR. Go ahead and invoke? i 7 foreign commerce for the purpose of engaging in 1 7 A i would like to answer that question, if 1 8 illicit sexual conduct with Jane Doe," is also a 8 i understood it correctly. However, my attorneys 9 faise statement, isn't it? 1 9 have advised me today at least to invoke my 2 0 MR. PIKE: Form? 2 0 Sixth, Fifth and Fourteenth Amendment right. 2 1 A i would like to answer that question as 2 1 MR. PIKE: And 1 think you skipped mm 2 2 well as your other questions, Mr. Edwards. 2 2 a question because you went from the first 23 However, today my counsel has instructed me that 23 question, and the witness was 2 4 i must assert my Filth, Sixth and Fourteenth 2 41 MR. EDWARDS: Asking for a de?nition? .2 5 Amendment right. 2 5 MR. PIKE: Asking for a de?nition, so 478 480 1 The statement that Epstein never 1 he could properly interpret your question 2 attempted to or conspired to travel in foreign 2 and attempt to answer it. 3 commerce and engage in any illicit sexual conduct 3 I'm understanding that, based on your 4 with Jane Doe, is also a false statement; isn't 4 answer, that my question, "Did you intentionally 5 that right? t3 touch Jane Doe without her legal consent?" And 6 MR. PIKE: Form. 6 your response, depends on the de?nition of 7 A i would like to that question as well as 7? "legal consent;" is that true? 8 the other questions posed today, Mr. Edwards. 8 MR. PIKE: I think that the witness -- 9 However, on the advice of counsel they've 9 as people regularly do as deponents, ask for 10 instructed me to assert my Sixth, Filth and 3.0 clari?cation of a question, and Mr. Epstein 1 1 Fourteenth Amendment right. 1 1 asked you to clarify what, "legal consent" 12 in fact, you did contact Jane Doe when 12 was. If you wish to do that, then i guess 1 3 she was a minor child as well as conSpired to use 13 he could potentially understand your 3.4 a telephone to contact Jane Doe when she was a 14 question. However, if you don?t want to do 15 minor chiid, specifically for the purposes of 15 that, then i guess we can just move on. 1 6 engaging in illicit sexual conduct with Jane Doe, l. 6 This will provide the answer: ?ow old 3.7 true? 1? was Jane Doe when you touched her? 18 MR. PIKE: Form. 18 MR. PIKE: Form. Assumes facts not in 9 A Though i would like to answer that l. 9 evidence. 20 question as well as your other questions posed 20 A -- I don't know how to answer 2 3. here today, Mr. Edwards, I have been instructed 2 1 that question. [?11 have to assert my Filth 22 by my counsel that I must assert my rights under 2 2 Amendment, Sixth Amendment and Fourteenth 23 the Sixth, Fifth and Fourteenth Amendment. 2 3 Amendment right. 24 Did you intentionally touch Jane Doe on 2 4 Tell me why you're having trouble 25 her person and against her will or without her 2 5 answering the question and I'll clarify the 37 (Pages 477 to 480} U.S. Legal Support (561) 835*0220 481 483 1 question for you so it will be easier for you to 1 However, at ieast today, my counsel has 2 answer. 2 instructed me I must assert my rights under the 3 MR. PIKE: You've answered the 3 Sixth, Fifth and Fourteenth Amendment. 4 question. 4 Do you see yourseif, Mr. Epstein, as a 5 MR. EDWARDS: His response was he 5 danger to the middle school and high school 6 doesn't know how to answer the question. I 6 children in the {?alm Beach community? 7 want to help him. i want to make sure that 3? MR. PIKE: Form. 8 8 9 answer. 9 question, as weii as the other questions that 10 MR. PIKE: He invoked the Fifth, Sixth 10 you?ve posed here today, Mr. Edwards, my counsel 11 and Fourteenth. 1 1 has instructed me I must respond by asserting my 12 Mr. Epstein, did you touch Jane Doe in 1.2 rights under the Sixth, Fifth and Fourteenth 1 3 intimate areas of her body when she was a minor 1 3 Amendment. 14 child? 14 When you engaged in illegal sexual 15 MR. i?iKE: Form. 15 conduct with Jane Doe, was it your intent to 1 6 A I would like to answer that question, 1 6 cause her Severe emotional distress? all your questions with respect to Jane Doe, Mr. MR. Form. 3.8 Edwards. However, today at least, my counsel has 18 A Though I would like to answer every 1 9 advised me that I must assert my rights under the 1 9 question with respect to Jane Doe, Mr. Edwards,, 20 Sixth, Filth and Fourteenth Amendment. 20 at least today my counsel has advised me that I 21 In fact, didn't you touch Jane Doe in 21 must assort my rights under the Sixth, Fifth and 22 intimate areas of her body, including her vagina, 22 Fourteenth Amendment. 23 her breasts, and her buttocks on dozens of 23 When you engaged in sexual conduct with: 24 occasions between February 2003 and June 2095? 2 4 Jane Doe when she was a minor child, age 14, 15 25 MR. PIKE: Form. 25 16 and 27, would you agree that you showed 482 484 1 A Thoughl would like to answer every 1 reckless disregard with the high probability of 2 question about Jane Doe that you've posed here 2 causing severe emotional distress to Jane Doe? 3 today, Mr. Edwards, upon advice of connect, at 3 MR. PIKE: Form. 4 4 5 my rights under the Sixth, Fifth and Fourteenth 5 questions that you?ve posed here today regarding 6 Amendment. 6 Jane Doe, on advice of counsel, at least today, 7 Do you agree that the inappropriate 7 they've instructed me i must assert my rights 8 sexual conduct, that your inappropriate sexual 8 under the Sixth, Fifth and Fourteenth Amendment 9 conduct towards Jane Doe, was both extreme and 9 Mr. Epstein, did you coerce Jane Doc 10 outrageous? 1 0 into prostitution? 3.1 MR. PIKE: Form. 1 1 A Again? 12 A i would like to answer all of your 12 Did you coerce Jane Doe into 1 3 questions with respect to Jane Doe that you've 1 3 prostitution? lei posed here today, Mr. Edwards. However, upon 1a A Can you tell me what you mean by 1 5 advice of coonsel, they?ve instructed me that 1 5 "coerce," please? 16 16 Q?h?mahmv?dwum Fourteenth Amendment. 17 A We asked you a simple question. Can 18 Do you also agree that your sexual 1 8 you tell me what "coerce" means, please? 19 interaction with Jane Doe when she was a minor 19 The definition of the word "coerce" will 20 child was outrageous and so extreme in degree 20 allow to you answer that question? 21 that it should not he tolerated in a civilized 23. A Pro trying to understand the question. 22 community? 22 MR. PIKE: You?re using -- for the 23 MR. PIKE: Form. 23 record, you're using iegal terms. 2 4 A I would like to respond to all your 2 4 "Consent," "coerce." Those are the terms 2 5 questions with respect to your client, one Doc. 2 5 you?re utilizing in your question. Mr. 38 (Pages 481 to 48a} U.S. Legal Support (561) 835-~0220 485 487 Epstein is simply asking you what those 1 MR. PIKE: Form. 2 2 3 or a response coupled with the invocations. 3 questions with respect to Jane Doe, Mr. Edwards. 4 He doesn't he is not a lawyer, He 4 However, today, my counsel has instructed me that 5 doesn't understand these legal terms, and he 5 I must assert my rights under the Sixth, Fifth 6 is asking you for clarification. if you 6 and Fourteenth Amendment. 7 want to take those legal terms out of your 7 If you answer that question for me, then 8 questions and simpiify them, then go ahead 8 {can to]! you whether that falls under the 9 and do that, but it is fair that he ask What 9 de?nition of coercing her into prostitution. 1 certain words mean. 10 A Is that a question? 1 1 MR. EDWARDS: i absolutely agree and 11 Sure. Can you provide an answer to the 12 want to make sure before I give him the 12 previous question, so I can categorize that as 1 3 de?nition, that this question is being 3. 3 coercion or uoncoorcion? 14 asked because the de?nition wili help him 14 MR. PIKE: No, he cannot, because I 15 to accurately answer the question, assuming 15 don't know what question is on the tabie, 16 that would be the only reason he would ask 1 6 and it is as simple as that. {don?t know 17 me a question. 17 what question is on the table. 18 MR. PIKE: As his lawyer, i think that 18 MR. EDWARDS: Sure. 1 9 the de?nition of the word would assist him 19 Didn't You interact with Jane Doe in 3 2 0 in understanding the question a little bit 20 sexual manner when she was under the age of 18?! 2 1 better, because, as you know, "coerce" and 2 1 MR- PIKE: Object to the form This 22 "consent" have severai meanings, whether or 22 question has been asked no less than twice 2 3 not it be in State court, under the Florida 23 during Your deposition 2 4 State statutes or under federal statutes 2 4 MR. EDWARDS: i?ll agree with that. 25 under 2255. I think that any sort of 25 MR. PIKE: relative to Jane Doe and 486 488 1 response could, you tiptoe into the 1 i'li object to the form. 2 Fifth, Sixth and Fourteenth, and I think Mr. 2 A i wouid like to answer of your 3 Epstein is attempting understand your 3 questions, Mr. Edwards, especially that 4 questions. 4 question. However, today, my counsel has advised 5 MR. EDWARDS: I appreciate that. i feel 5 me that i. must assert my rights under the Sixth, 6 iike we?re getting cioser to an answer than 6 Fifth and Fowteenth Amendment. 7 7 8 litigation, so I?m certainly going to help 8 Dee to engage in prostitution when she was an 9 him out here. 9 underage minor child? 10 Mr. Epstein, do you then at least agree 10 MR. PIKE: Form. 11 that you paid Jane Doe money in exchange for 11 A i would like to answer that question but 3.2 sexual services when she was under the age of 1 2 my counsel has advised me i must respond by 13 18? 13 invoking my Sixth, Fifth and Fourteenth Amendmer 14 MR. i?iKE: Form, mischaracterizes the 14 right. 15 witness's testimony, and move to strike. 15 Can you tell the jury how it is that 16 A Unfortunately I have to answer that 1 6 Jane Doe engaged in an act of prostitution with 1? question as I've answered most of your other 3.7 you? 18 questions here today, Mr. Edwards, which is that 18 MR. Form. 19 my attorneys, at feast today, have advised me 1 9 A On advice of counsel, i'm going to have 20 that i must assert my rights under the Sixth, 2 0 to invoke my Sixth, Fifth and Fourteenth 2 1 Fifth and Fourteenth Amendment. 21 Amendment right. . 22 Mr. Epstein, how did you, meaning what 22 While you were interacting with Jane Doc 23 process did you go through, to get Jane Doc to 2 3 in a sexual manner when she was 14 and 15 years 2 4 exchange your money for her sexual services when 2 4 old, did you consider that molestation? 25 she was under the age of 13? 25 - MR. PIKE: Form. 9-.- 39 (Pages 485 to 488) 0.8. Legal Support (561) 835*0220 489 491 A i would like to answer of your 1 MR. PIKE: 0116 Form. 2 2 3 3 ti counsel has advised me that i must assert my 4 Fourteenth Amendment right. 5 rights under the Sixth, Fifth and Fourteenth 5 During that conversation that you had 6 Amendment. 6 with George Rush from The New York Daily New: 7 While, at the same time you were ?i didn't you express to him that you felt you were 8 molesting Jane Doe, didn't you tell her that you 8 punished criminally for no reason? 9 liked the way her young body iooked? 9 MR. PIKE: Form. 10 MR. PIKE: Form. 10 A Though I wouid like to answer all of i A I would like to respond to ali your 11 your questions, Mr. Edwards, my counsel has 12 questions regarding Jane Doe, is the point, Mr. 12 advised me i must assert my rights under the 1 3 Edwards. However today at least my counsel has 13 Sixth, Fifth and Feurteenth Amendment. 1 4 advised me i must assert my rights under the 1 4 Didn't you also tel! George Rush that a 5 Sixth, Fifth and Fourteenth Amendment. 1 5 more appropriate punishment for your actions will: 16 THE VIDEOGRAPHER: Counsel. 16 these underage minor children would have been a 1? (Indicating five minutes Felt on tape.) 1 '7 188 or $280 fine? 18 MR. EDWARDS: Okay. 18 MR. PIKE: Form. 3.9 Mr. Epstein do you know George Rush? 19 A On advice of counsei I have to assert my 2 0 MR. PIKE: Form I'li withdraw the 2 0 rights under the Sixth, Fifth and Fourteenth 2 3. form. i'm it is not a proper form 2 1 Amendment. 2 2 objection. 2 2 Tell the jury what you feel would be an 2 3 A Pro sorry, on advice of counsel I have 2 3 appropriate penalty for you, for the acts that 2 4 to assert my rights under the Sixth, Filth and 24 you committed against Jane Doc. 2 5 Fourteenth Amendment. 25 MR. i?lKE: Form. 490 492 1 Did you talk to George Rush in the year 1 A Though I wouid like to very much answer 2 2069 about the aliegations of improper sexual 2 that question, on advice of my counsel today, Mr. 3 conduct between you and underage minor children? 3 Edwards, I have to invoke. my Sixth, Fifth and 4 MR. PIKE: Can you repeat the question, 4 Fourteenth Amendment right. I 5 for me, Madam Court Reporter? 5 In your Affi rmative Defenses in the 6 MR. EDWARDS: I can ask it again. 6 complaint of Jane Doe versus Jeffrey Epstein, MR. PIKE: Sure. 7 which is Jane Doe, af?rmative defense number on:- 8 Did you speak with George Rush in 2009 8 indicates that Jane Doe consented to and was a 9 specifically about allegations of your 9 wiiling participant in the acts alleged. to interaction with underage minor children in a 10 What evidence did you have that Jane Doc 1 1 sexual manner? 1 1 consented to or was a willing participant in the 12 A On advice of counsei, i'm going to have 12 acts that were alieged by Jane Doe against you? 13 to assert my rights under the Sixth, Fifth and 13 MR. PIKE: Penn. 1 4 Fourteenth Amendment. 1 4 A Though i would iike to describe the 1 5 Did you know that the conversation 1 evidence that Jane Doe was a willing participant, 1 6 between you and New York Daiiy News reporter 1 6 on advice of counsei today, they've instructed me 1 7 George Rush was recorded? 17 i must assert my rights under the Sixth, Fifth 1 8 MR. PIKE: Form. 18 and Fourteenth Amendment. 19 A On advice of connsei, I'm going to have 1 9 At that point in time you're at least 20 to assert my right under the Sixth, Fifth and 2 admitting that there was an interaction between 2 1 Fourteenth Amendment. 2 1 you and Jane Doe, correct? 22 At the time when you spoke with George 2 2 MR. Form. Move to strike. 23 Rush from The New York Daily News in 2009advice of counsel, i'm going to have 24 tell you that he was recording your statements to 2 4 to assert my rights under the Sixth, Fifth and 25 him? 25 Fourteenth Amendment. 40 {Pages 489 to 492) U.S. Legal Support (561) 835?0220 493 495 1 Two answers ago I believe that you just 1 THE VIDEOGRAPHER: Back on the video 2 told us that you would like to tell the jury 2 record 2:30 pm. 3 about the evidence that exists, that shows that 3 CROSS EXAMINATION (CONTINUED) 4 Jane Doe consented to or was a willing 4 BY MR. EDWARDS: 5 participant in the acts alleged. So, is there 5 Mr. Epstein, are you ready? 6 any evidence that you're aware of in existence in 6 A Yes. this world that shows that Jane Doe consented to 7' The second af?rmative defense indicates 8 the acts she alleged against you? 8 or says that Jane Doe ?actually consented to and 9 MR. PIKE: Form. Also calls for work 9 participated in conduct similar andfor identical 1% product information? 10 to the acts alleged with other persons, which 1 1 A Unfortunately today I have to respond by 11 were the sole or contributing cause of Jane Doe?s 12 asserting my rights of Sixth, Fifth and 12 alleged damages." 1 3 Fourteenth Amendment. 13 What facts or information do you have to 14 THE VIDEOGRAPHER: Counsel? 1 4 support that affirmative defense? 15 MR. EDWARDS: Okay. 15 MR. PIKE: Form, May also call for work 1 6 THE VIDEOGRAPHER: Going of?:c the video 1 6 product information. 17 record 2:34 pan. 17 A Though I would like to answer all your 18 (Pause in the proceedings.) 18 questions, Mr. Edwards, at least today counsel 19 (The deposition of Jeffrey Epstein is 1 9 advised me i must assert my rights under the 2 0 continued in Volume IV.) 20 Sixth, Fifth and Fourteenth Amendment. 2 1 21 And when you say as an affirmative 2 2 22 defense Jane Doe consented to and participated in 2 3 23 conduct similar andfot' identical to the acts as 24 alleged, are you saying that at some other time 2 5 25 Jane Doe was sexually molested by somebody of 494 496 1 UNITED STATES COURT 1 similar or identical age to yourself? 2 SOUTHERN DISTRICT OF FLORIDA 2 MR. PIKE: Form. CASE NO. 3 A I would like to answer all of your 2 4 questions with respect to Jane Doe and her JANE DOE, 5 complaints. However, at least today my counsel 5 Plaintiff 6 has advised me I most assert my rights under the 5 7 Sixth, Fifth and Fourteenth Amendment. 8 The second part of that af?rmative JEFFREY et a1? 9 defense indicates that that similar or identical 8 1 0 conduct that Jane Doe allegedly participated in, 9 Defendam? 1 1 was the sole or contributing cause of Jane Doe'su 3. 2 alleged damages. Ream Cases: 13 Are you acknowledging that that conduct 11 03.301 19? 03302310330330, 03450331, 14 is likely to cause damages to a minor child such 08?80994. 08~80811,08w80893, 09-80469, 1 5 as Jane Dec? :2 0941591. ogio?gs?gisfsoz, 09?32092 16 MR. PIKE: Form. 14 CONTENUED VIDEOTAPED OF 1 7 A I would like to answer all Of your JEFFREY BPSTEIN TAKEN ON BEHALF ques lOl?lS WI espec 0 one an or 16 19 complaint. However, at least today a; 2 0 my counsel has advised me I must assert my rights 19 2 1 under the Sixth, Fifth and Fourteenth Amendment. :2 DARE: April 14,20?) 2 2 Are you taking the position that Jane 22 2 3 Doe's alleged damages Were actually caused by :2 24 separate or other child molester? 25 25 MR. PIKE: One object to the 41 (?ages 493 to 496) U.S. Legal Support (561) 835~0220 497 499 1 form. I think you need to reword the 1 believed or was told that the plaintiff, Jane 2 question. 2 Dee, had attained the age of 18 years old at the 3 MR. EDWARDS: Okay. l?ii ask it again. 3 time of the alieged acts." That is a false 4 4 smwmun?mu?JWnEmwm? 5 facts or information that Jane Doe was molested 5 MR. PIKE: Form. 6 6 7 MR. PIKE: Form. 7 you posed today, Mr. Edwards, about Jane Doe anc 8 A Iwouid iike to anSWer ail your 8 her complaint. However, at least today my 9 questions that you posed here today, Mr. Edwards, 9 attorneys have advised me I must assert my rights 10 every last one of them. However, at least today 10 under the Sixth, Fifth and Fourteenth Amendment. 11 under advice of counsel, 1 have been instructed I 1 1 What gave you the reasonable belief that 12 must assert my rights under the Sixth, Fifth and 12 Jane Doe was 18 years of age or older when you 13 Fourteenth Amendment. 13 touched her in a sexual manner? 14 The next af?rmative defense indicates to MR. PIKE: Form. 15 that Jane Doe impliedly consented to the acts 3. 5 A wouid like to answer of your 1 6 alfeged by not objecting. 1 6 questions with respect to Jane Doe, Mr. Edwards, What do you mean by that af?rmative 17 every one of them. However, today, as you're 18 defense? 18 aware, my counsel has advised me I must assert m) 19 MR. PIKE: Form. 19 rights under the Sixth, Fifth and Fourteenth 2O Ammem 2 1 questions regarding Jane Doe, and her complaint. 2 3. Didn't Jane Doe tell you when you asked 2 2 However, today my attorneys have advised me that 22 her age that she was 15 years old? 2 3 I must assert my rights under the Sixth, Fifth 2 3 MR. PIKE: Form. 24 and Fourteenth Amendment. 2 4 A i would iike to answer that questiorr 2 5 Do you mean 2 5 because I've answered most of your other 498 500 1 MR. PIKE: May aiso call for work 3. questions here today. Unfortunater my counsei 2 product information. Sorry. 2 here today said I must invoke my rights under the 3 3 4 would insert your fingers into her vagina when 4 The second portion of that af?rmative 5 she was 14 or 15 years old, that because she 5 defense is that you reasonably beiieved or you 6 didn't object that she impliedly consented to 6 were told that Jane Doe attained the age of 18. 7 that conduct? 7 Tell the jury, who told you that Jane 8 MR. PIKE: Form. 8 Doc had attained the age of 18 years old when you 9 A What?s the question? 9 engaged in sexual conduct with her? 10 Do you mean by I'll read your 10 MR. PIKE: Form. 1 1 af?rmative defense that you have stated. 1 A Though I would iike very much to answer 1 2 "Plaintiff Jane Doe impliediy consented 12 that question, as most of your other questions 13 to the acts alleged by not objecting," and I?m 13 here today, as you're aware my counsel has 14 asking: By that, do you mean that when you 14 advised me I must assert my rights under the 15 inserted your fingers into her Vagina when she 15 Sixth, Fifth and Feurteenth Amendment. 16 was age 14 or 15, that by her not verbaliy 16 in fact, if you learned that she had 17 objecting, then in your mind she consented? attained the age of 18 years old, you would not 18 MR. Form. 18 have engaged in sexual conduct with her, wouid 1 9 A I would iike to answer at! your 3 9 you? 2 0 questions Mr. Edwards. However, at ieast today, 20 MR. PIKE: Form. 21 at least today, my counsel instructed me I must 21 A I would like to answer all of your 22 assert my rights under the Sixth, Fifth and 22 questions with respect to Jane Doe, Mr. Edwards. 2 3 Fourteenth Amendment. 23 However, at least today, my counsel advised me 24. Your next af?rmative defense states 24 thatI must assert my rights under the Sixth, 2 5 that "Defendant," that being you, "reasonably 2 5 Fifth and Fourteenth Amendment. 42 (Pages 497 to 500) U.S. Legal Support _(561) 835*0220 501 503 .1 1 In fact, there were severai times when 1 Isn't it true during that period of time 2 girls were brought to you by other underage minor 2 when V.R. was your underage sex stave, that she 3 females and these girls were over the age of 18 3 observed you to have sexual intercourse and 4 and you turned them away, as being too old for 4 sexual activity with several females, as young as 5 you; isn't that true? 5 12 years old? 6 6 7 A Again, I would like to answer all your 7 A I would iike to respond to all of these 8 questions here today. I would like to answer 8 questions. And I prefer that your partner, Scott 9 that question. However, my counsel has advised 9 Rothstein, who currentiy sits in jail for 10 me that at least today i may not and must assert 10 fabricating cases of a sexual nature against 11 my rights under the Sixth, Fifth and Fourteenth 1 1 people like me and others, were here to hear some 12 Amendment. 12 of these answers. However, with respect to any 13 in fact, your target age group for 1 3 other question, at least today, my counsel has 1 ?1 sexual activity is between 12 and 17 years old; is advised me that i must assert my rights under the 1 5 is that true? 15 Sixth, Fifth and Fourteenth Amendment. 16 MR. PIKE: Form. 16 Why would you prefer that Scott 1? A Mr. Edwards, i would like to answer that Rothstein hear an answer from you about whethe 18 question, as well as your other questions here 18 or not you had sex with multiple 12 year olds? 1 9 today. However, my counsel has advised me that I 19 MR. PIKE: Form. Move to strike, and 2 0 must not, may not, must assert my rights under 2 mischaracterizes the witness's testimony. 2 1 the Sixth, Fifth and Fourteenth Amendment. 2 1 A At least today, Mr. Edwards, my counsel 2 2 You know a person named V.R., don't 22 has advised me that I must respond to these 2 3 you? 2 3 questions by asserting my rights under the Sixth, 2 4 A Though I would like to answer all of 2 4 Filth and Fourteenth Amendment. 2 5 your questions Mr. Edwards, on advice of counsel 2 5 v.11. is somebody who has filed a lawsuit 502 504 1 today at least, they?ve instructed me that must 1 against you under the pseudonym Jane Doe number 2 respond by asserting my rights under the Sixth, 2 102; isn't that correct? 3 Fifth and Fourteenth Amendment. 3 MR. PIKE: i?m sorry. Can you repeat 4 V.R. is somebody who served as your sex 4 it? 5 slave when she was between the ages of 15 and 18 5 MR. EDWARDS: Sore. 6 years old; isn't that true? 6 V.R. is somebody that filed a lawsuit "3 MR. PIKE: Form. 7? against you under the pseudonym Jane Doe numbel 8 A I would like to respond to all of your 8 192? 9 questions with respect to V.R. However, on 9 A Though I would like to respond to your 10 advice of counsei today at ieast, they've 1 0 oncstions today, Mr. Edwards, with respect to 11 instructed me that I must assert my rights under 1 1 these lawsuits, my counsel has advised me that I 12 the Sixth, Fifth and Fourteenth Amendment. 12 may not, and must assert my rights under the 1 3 Do you know Emmy Taylor? 1 3 Sixth, and Fourteenth Amendment. 14 A Though I would iike to respond to all of 1 it [n that complaint, the allegation is 1 5 your questions here today, Mr. Edwards, under 1 5 made that a friend of Jeffrey Epstein sent him 16 advice of counsel I must assert my rights under 1 6 three 12-year old girls from France, who spoke no 17 the Sixth, Filth and Fourteenth Amendment. 1 7' English, for defendant Epstein to sexually 18 Is that somebody who served as the sex 1 8 exploit and abuse. After doing so, they were 19 stave for Gislaine Maxwell at the same time or 1 9 sent back to France the next day. 20 about the same time that V.R. was your sex slave? 20 That's a true statement, isn't it? 21 MR. PIKE: Form. 21 MR. PIKE: Form. 22 A would like to answer all of your 22 A I would like to respond to all of these 2 3 questions, Mr. Edwards. However today my counse 2 3 However, at least today, my counsel 2 4 has advised me I must assert my rights under the 24 has advised me that I must assert my rights under 25 Sixth, Fifth and Fourteenth Amendment. 25 the Sixth, Filth and Fourteenth Amendment. 43 (uages 501 to 504} U.S. Legal Support (561) 835-0220 505 507 1 In the complaint filed on behalf of Jane 1 Amendment right. 2 Doc number 102 also known as V.R., was filed by 2 MR. EDWARDS: Mark this. 3 an attorney named Bob Josefsberg with Podhurst, 3 (Order form from Amazon.com, listing 4 OrSeck; isn?t that right? 4 three books, was marked as Plaintiffs 5 MR. PIKE: Can you reread that speci?c 5 Exhibit number 9 for identi?cation, as of 6 question for me? . 6 this date.) 7 THE COURT REPORTER: Sure. 7 MR. i?iKE: (Handing to the witness.) 8 (The record was read.) 8 Do you recognize that document that's 9 MR. PIKE: To the extent you know the 9 been marked for identi?cation purposes as 10 answer to that question, you can answer. 10 Exhibit 9? 11 A i think -- i'm going to assert my rights 11 A No. i do not. 12 under the Sixth, ifth and Fourteenth Amendment. 12 Did you indeed order the three books 13 And when I asked you a few questions 13 from Amazon.com that are listed on that order 14 back about your sexual interaction and 14 form that?s been marked as Exhibit 9? 15 intercourse with 12-year old girls and derived 15 A No. 6 that from this complaint, your answer into 1 6 Have you read the three books that are 17 your answer was injected some response related to 17 on that order form, Exhibit number 9? 18 Scott Rothstein, and so my question is, what do 18 A No. 19 you believe, if anything, Scott Rothstein had to 19 Do you know why it is, can you explain 20 do with the complaints or assertions that are 2 0 how that document came to exist? 21 made in the Jane Doe 102 versus Epstein 2 1 A No. 22 complaint? 22 Do you know where that document that 23 MR. PIKE: Form, move to strike. 23 you're holding marked as Exhibit number 9 came 2 4 Mischaraeterizes the witness's testimony. 2 4 from? 25 A I would like to answer that questionHowever, at least today they have instructed me i 1 Would you be surprised if it was taken 2 must respond to that question by asserting my 2 .- from your trash by police or law enforcement? 3 Sixth, Fifth and Fourteenth Amendment right. 3 A Would i be surprised? I don't 4 Mr. Epstein, for at least the passed 4 understand the question. 5 decade you have consistently kept at least one 5 Would it surprise you if the police 6 sex slave at all times. Is that true? 6 pulled that from your trash, outside your house, 7 MR. PIKE: Form. 7 in 2805? 8 8 9 sexualiy charged questions. However, upon advice 9 quite frankly, i don?t know where 10 of counsel, 1 must respond simply by asserting my 3.0 this document came from. There has been no 11 1 2 Amendment right. 12 you're talking about a question relative to, 13 And you have an Amazon.com account, 13 would it surprise you if the police pulied 1 4 right? 1 a I don't think that you?ve laid the 15 MR. PIKE: Form. 15 proper foundation, so i'm going to ob}ect to 1 6 A Upon advice of counsel, l?m going to 1 6 the form. 1 7 have to assert my right to the Sixth Amendment, 1 7 MR. EDWARDS: Okay. At trial I'll enter 18 19 On or about September 4, 2685 you 3.9 him to deny him ever seeing it before i do 20 ordered and received and later receivad three 20 that. It is ?ne, l?ll lay the predicate 21 books from Amazon.com; is that true? 21 MR. PIKE: I-ie's already said that, I 22 MR. i?lKE: Form. Books? 22 believe, he's never -- you asked him ifhe 2 3 Form. 2 3 recognized the document and he said 2 4 A On advice of counsel I have to assert my 2 4 MR. EDWARDS: I appreciate that. 2 5 Sixth Amendment, Fifth Amendment and Fourteenth 25 Would it surprise you if that was 44 (Pages 505 to 508} U.S. Legal Support (561) 835?0220 509 511 1 obtained from a trash pull at your house? 1 A I don't know. 2 A You're asking me a hypothetical 2 is there anybody else that lives in your 3 question. i have no idea. 3 house, besides yourself, that has sex slaves? 4 What is the name and address ofthe 4 MR. PIKE: i?m Mr. Horowitz, I 5 purported purchaser of those books? According to 5 believe, interrupted you, i think he gave 6 Exhibit number 9? 6 you another exhibit, i think it?s Exhibit 9, 7 Ai?mmwn 8 MR. PIKE: Form. 8 aquestion. 9 Looking at that document you cannot tell 9 MR. EDWARDS: it is just placed on the 10 what address those books were shipped to? 1 0 table. i'm waiting for an answer. 11 A it says "biiling address." 21 MR. PIKE: i'm not being smarter. i'm 12 What's the billing address? 12 just saying, are you going to foiiow through 13 A it says what the document says. 1 3 with the question that?s currently on the 14 What is that? 14 table or the one that -- 15 A It says Jeffrey Epstein. 1 5 MR. EDWARDS: i asked a question and 1 6 What's the address? 1 6 many waiting for an answer. 17 A 358 Bi Briilo Way. 17 MR. PIKE: Seriously, I?m not trying to 18 That address at 358 El Briilo Way is 18 be rude or smart. You put an exhibit in 9 your address, correct? 1. 9 front of him and -- 20 MR. PIKE: Form. 20 MR. i wanted to give the 2 1 A On advice of oounsei, i?m going to have 2 1 court reporter the exhibits. She gets the 22 to assert my Fi?h Amendment, Sixth Amendment and 22 exhibits. 2 3 Fourteenth Amendment right. 2 3 MR. PIKE: i've got to know what 2 4 Jeffrey Epstein, that's your name, 2 4 question is on the tabie, that?s all. 25 correct? 2 5 MR. HOROWITZ: i didn't interrupt you, 510 512 1 A Correct. 1 did 2 Can i see the document? 2 MR. EDWARDS: No, it is asked on I 3 3 4 Mr. Epstein, the person whose deposition 4 A Ask the question. 5 was taken yesterday and has been widely reported 5 Anybody else in your house have sex 6 in the newspapers as your sex siave, Nadia 6 slaves? 7 Marcinkova, is she indeed your sex siave? 7? MR. PIKE: Form. 8 8 9 9 10 respond by asserting my Sixth Amendment, Fifth 10 is I have to assert my rights to the Sixth, Fifth 1 Amendment and Fourteenth Amendment right. 3. and Fourteenth Amendment. 12 Does anybody other than yourself have 1 2 Are you familiar with the various 1 3 access to your Amazon.com account? 1 3 messages that are that were taken from your 1 4 MR. PIKE: Form. 1 4 home at 358 El Way? 15 A 15 16 You have never read "Slave Craft, 16 A I?m going to have to assert my rights 17 Readmaps for Erotic Servitude, Principles, Skills 1? under the Sixth, Fifth and Fourteenth Amendment 18 and Tools"? 18 Have you read the messages that were 19 MR. PIKE: Asked and answered. He was 19 taken and placed in the State Attorney's Office 20 aiready asked theso questions I'm sorry, 20 file related to the criminal charges against 21 monemd. 21 you? 22 A I?ve answered the question 2 2 MR. Form. 23 Why was it ordered to your house, the 2 3 A I don't recaii. . 24 shipping address and address both being 24 Why is it that underage minor females 2 5 358 El Way? 25 Were your home in 2004 and 2085 for, in 45 (Pages 509 to 512) U.S. Legal Support (561) 835-0220 513 515 1 quotes, "Work"? 1 question, as I?ve answered most of your other 2 MR. PIKE: Wait a second. Form, Iacks 2 questions here today, Mr. Edwards, which is that 3 predicate, foundation, and for the record, 3 my attorneys advised me to assert my Sixth 4 you're referring to a stack of documents 4 Amendment, Fifth Amendment and Fourteenth 5 that have not been marked 5 Amendment right. 6 MR. EDWARDS: Not referring to anything, 6 Do you know Adriana Mucinska or Adrian: 7 just so that your objection is ciear. "3 Ross? 8 MR. PIKE: You're referring to what I 8 A As I've answered most of your other 9 9 10 message pads. You're eiarifying 1 0 respond that my attorneys have instructed me to 11 making a preiude into your question as to 1 1 assert my rights to the Sixth, Fifth and 1 2 why were underage giris setting your home 12 Fourteenth Amendment. 13 for work? 1 3 That's somebody who is iistcd in the 14 MR. EDWARDS: Right. 14 agreement between yourseif and the United States 15 MR. PIKE: You're not aIiowing the 15 of America as a eo-conspirator of yours. Does 1 6 witness to see the exhibits to which you 16 that heip refresh your recollection as to who Ms. refer, and I think it is an improper 17 Ross is? 18 question and lacks predicate and 18 MR. PIKE: Form. 1 9 foundation. 1 9 A i'm going to have to respond by 2 0 MR. EDWARDS: No matter what I Show the 2 asserting my rights to the Sixth, Fifth and .2 1 witness, any answer he gives is going to 2 1 Fourteenth Amendment. 22 2 3 his Fifth Amendment rights, which is why 2 3 Adriana that would read something like, ieft a 2 4 right now, he is not going to see these. At 2 4 message for Ashley to con?rniwfor 11:60 o'ciock 25 trial he will see all of these things. 25 and Vanessa for 4:30," many messages like that? 514 516 1 MR. PIKE: I?m giad you said that. I 1 MR. PIKE: I'm sorry, but before he 2 think that?s a faise statement. 1 move to 2 answers, I?m just curious, you?re again 3 3 4 document to Mr. Epstein not two minutes ago 4 about an inch thick. Do you want to mark 5 and he answered questions without invoking 5 anything as an exhibit? 6 6 h?LEDWARDS:Nmidedm?mee 1 7 8 8 9 into play. 9 MR. PIKE: Yeah. You're Weicome. Do 10 MR. EDWARDS: It shouid have. 10 you know where these documents came from? 11 MR. PIKE: Thank you. if the Fifth 11 MR. EDWARDS: Yes. 12 Amendment comes into play, he will invoke 1 2 MR. PIKE: Where did you obtain that 1 3 the Fifth. He does not know certain 13 them from? 14 information. Not knowing something, my 14 MR. EDWARDS: It is not my deposition. 15 friend, is not a waiver. Foiiow? So he is 15 You had that chance already. 1 6 trying asked the right no, 17 1? 18 MR. PIKE: trying to actuaiiy work 18 there. Critton took your deposition, not 19 with you on your questions. Maybe if you 1 9 me. That's a case separate and distinct 2 0 show him what you?re taiking about, he can 2 0 from these cases, so my question to you is: 2 1 answer your question. 2 1 You just curious, you have a stack of 22 Why were underage minor females calling 2 2 documents, I think you said earlier they 23 your house to, quote, unquote, "work"? 23 came from the State Attorney's Of?ce tiie?? 2 4 MR. PIKE: Form. 2 4 MR. EDWARDS: It is not my deposition. 2 5 A Unfortunateiy, i have to answer that 25 I'm asking questions. Your ciient is going 46 (Pages 513 to 516) U.S. Legal Support (561) 835~0220 517 519 1 to give answers or not give answers. 1 In a newspaper article dated October 38, 2 MR. Okay. 2 2086 entitled, "The Return Of in quotes, 3 MR. EDWARDS: These will come in with 3 ?Very i?assionate' end quote, "Jeffrey Epstein," 4 the appropriate person at trial, period. 4 there is a quote from somebody that is called in 5 MR. RIKE: Okay. 5 this article Friend," and the quote is: 6 A Question? Sony. 6 "Speaking about Jeffrey Epstein, his life is 7 Sure. 7 about making money and living an erotic life an: 8 Do you remember receiving a message from 8 his escape isn?t alcohol or drugs, it is sex." 9 Adriana Ross or Adriana Mucinska, such as, 9 Is that a true statement? 10 left message for Ashley to con?rm for 11:00 10 MR. PIKE: Form. 1 1 o'clock and Vanessa for 4:30true statement that that?s what 12 A I don?t recall. 12 the article says? 1 3 And when a message such as that is lefttrue statement that your 14 is that indicating Ashley is going to come to 14 life is about making money and living an erotic 15 your house for you to molest her at 11 :00 and 5 life and your escape is not alcohol or drugs, it 1 6 Vanessa will come for you to molest her at 4:30? 1 6 is sex? 1? MR. PIKE: Form. 1 7 MR. PIKE: Form. 18 A I?m going to have to respond by 1 8 A Though I would like to answer that 1 9 asserting my rights under the Sixth, Fifth and 1 9 question, as well as all your other questions 2 Fourteenth Amendment. 20 posed here today, Mr. Edwards, on advice of my 2 1 Why would underage minor females call 2 counsel, he has instructed me I must assert my 22 your home and leave messages like, "i have a girl 22 rights under the Sixth, Filth and Fourteenth 2 3 for him." Do you know? 2 3 Amendment. 24 MR. Form. 24 Another article entitled "The 2 5 A On advice of my counsel, today at least, 2 5 Fanaticist," from New York Magazine dated 518 520 they've advised me I must assert my right under 1 December 10, 2007, a quote or several quotes are 2 2 3 Did you ever employ any underage minor 3 Epstein," this is the author "and Ruhenstcin the 4 females for any legitimate purpose at your home, 4 sort of story New York Magazine wanted to do, an 5 358 El Brillo Way? 5 Epstein seemed to find ironic delight in every 6 MR. PIKE: Form. 6 word. A secretive genius, I said,? a statement 7? A At least today, Mr. Edwards, though I 7 from the author. "She indicates you corrected 8 would like to answer every one of 8 her saying "Not secretive, private," and the next 9 questions, my counsel has advised me I must 9 quote, which I will ask you about, is that you 10 assert my rights under the Sixth, Fifth and 1 0 stated "And if I was a genius, i wouldn't be 1 1 Fourteenth Amendment. 1 1 sitting here, a guy with sex issues;" do you 12 Isn't it true, Mr. Epstein, that each 1 2 remember saying that? 13 underage minor female that contacted -- that 13 MR. PIKE: Form. 14 called your home or was called from your home, 14 to a reporter in New York? 1 5 was called for the purposes of coming to your 1 5 MR. PIKE: Form. Move to strike. 1 6 house to satisfy you sexually? 16 A Though I would like to answer every 17 MR. PIKE: Form. 17 question you?ve posed here today, Mr. Edwards, on 18 THE WITNESS: 1 think I?ve answered that 18 advice of counsel 1 have to assert my Sixth 9 question before. 19 Amendment, Filth Amendment and Fourteenth 20 A i will answer it unfortunately the same 2 0 Amendment right. 2 1 way, which is although I would like to answer 2 1 MR. PIKE: Mr. Edwards, if you would, I 22 - each and every one of the questions you've posed 2 2 know you 2 3 here today, on advice of my counsel they've 2 3 THE WITNESS: Take a break? 24 instructed me I must assert my rights under the 24 MR. PIKE: Actually one second. 25 Sixth, Fifth and Fourteenth Amendment. 25 You provided the title of the second 47 (Pages 517 to 520} U.S. Legal Support (561) 835*0220 521 523 1 article that you just questioned hirn. Could 1 to he ridiculous. You can?t read 2 you please, for the record, provide the 2 MR. EDWARDS: What -- 3 title to the ?rst article. 3 MR. PIKE: You can't read someone else's 4 MR. EDWARDS: did. 4 quote and say "Are you admitting something 5 MR. PIKE: I didn?t hear it. 5 from someone else's quote." He didn't make 6 MR. EDWARDS: i will do it again. 6 the quoteadmission, 7 Return Of. A 'Very Passionate? Jeffrey 7 despite who it is. 8 Epstein.? 8 MR. HOROWITZ: That?s a form objection. 9 MR. Thank you. 9 MR. PIKE: You?re right, form. 3.0 MR. EDWARDS: "Very passionate" is in 10 Your attorney, Jack Goldberger, made 11 quotes, as i said the first time. 11 statement, "Jeffrey Epstein never denied the 12 MR. PIKE: Thank you. 12 girls came to the house." This was related to 3 THE. VIDEOGRAPHER: Going off the video 1 3 the criminal investigation of you. 1 4 record 3:02 pm. 1 4 Do you admit that the girls, 1 5 (Pause in the proceedings.) 1 5 speci?cally Jane Doe, came to your house? 1 6 THE VIDEOGRAPHER: Back on the video 1 6 A Mr. Edwards, I would like to respond to record at 3: i 5 p.m. 17 that question as i responded to most of the other 1 8 In the same article, "The Fanaticist," 18 questions today, but unfortunately my counsel has 1 9 there is a quote by "Michael Wolff." Do you know 1 9 advised me I must assert my rights under the 20 Michael Wolff, the columnist? 20 Sixth, Fifth and Fourteenth Amendment. 2 1 A I have to respond the same way i've 2 1 Mr. Epstein, can you tell the jury who 22 responded to most of your questions here today, 22 Sarah Kellen is? 2 3 which is, I must assert my rights under the 2 3 MR. PIKE: Form. 2 4 Sixth, Fifth and Fourteenth Amendment. 2 4 A Unfortunately, Mr. Edwards, I have to 25 Mr. Wolff says in a quote in this 2 5 respond to that question as responded to most 522 524 1 article, "He has never," speaking abdut Mr. 1 of your other questions today, because on advice 2 Epstein, "been secretive about the girls. At one 2 of counsel they've instructed one to assert my 3 point when his troubles began he was talking to 3 rights under the Sixth, Fifth and Fourteenth 4 me and said, 'What can I say? I like young 4 Amendment. 5 girls.? Is that a comment or statement that you 5 You're aware that she is somebody listed 6 made to Michael Wolff? 6 as a co-conspirator of yours related to your 7? MR. PIKE: Form. 7 criminal activity in the Nonprosecution 8 A Unfortunately have to respond to that 8 Agreement, correct? 9 question as i did to most of your questions 9 MR. PIKE: Form. 10 today, which is I must assert my rights under 10 A With respect to that question as most of 1 1 advice of counsel, under the Sixth, iith and 1 your other questions here today, on advice of 12 Fourteenth Amendment. 12 counsel 1 have been instructed to assert my 13 On several occasions your attorney or 13 rights under the Sixth, Filth and Fourteenth 4 one of your attorneys, Jack Goidherger, has made 14 Amendment. 15 the statement "Jeffrey Epstein has never denied 15 isn't it true that you paid her to have 1 6 that the girls came to the house." Are you 1 6 underage minor females brought to your house, at 17 admitting that the girls that are new plaintiffs, 17 specific times, as you directed? 18 at least came to your house? 18 MR. l?lKE: Form, asked and answered. 1 9 MR. PIKE: Form. 1 9 A As I've answered most of your questions 20 A I would like to answer that question 20 here today, unfortunately my counsel has advised 2 you?ve just quoted an attorney?s statement? 2 1 me that 1 must assert my rights under the Sixth, 22 Right, Jack Gold herger?s statement. 22 Fifth and Fourteenth Amendment. 23 A So what's the question? 2 3 Another co-conspirator of yours, as she 24 MR. PIKE: You can?t -- hold on right 2 4 is labeled in the Nonprosecution Agreement, is 25 there. This is ridiculous. This is getting 25 Lesley Graft. What role did she play or what did 48 (Pages 521 to 524) 0.3. Legal Support (561) 835-0220 525 527 1 she conspire with you to do? 1 underage minor females in the communities 2 MR. PIKE: Form. 2 surrounding each of your homes? 3 A 3 4 question as i did to most of your other questions 4 A Though would like to answer each and 5 here today, which is, on advice of counsel, 5 every one of your questions, Mr. Edwards, my 6 they?ve instructed me to assert my rights under 6 attorneys have advised me at least today, at 7 the Sixth, Fifth and Fourteenth Amendment. 7 ieast today, that i may not. i must assert my 8 Today what roie does Story Cowies play 8 rights as provided by the Sixth, Fifth and 9 in your life? 9 Fourteenth Amendment. 1 0 MR. PEKE: Form. 10 isn't it true that within that computer 11 A i would like to answer all your 11 system were the names and telephone numbers of 12 questions, Mr. Edwards. However, at least today, 12 hundreds of underage minor females that you 1 3 my counsei has advised me that i must assert my 13 sexually moiested? I 1 4 rights under the Sixth, Filth and Fourteenth 14 MR. PIKE: Form. 1 5 Amendment. 15 A I would like to answer every one of your 1 6 is Story Cowies your personal 1 6 questions today, Mr. Edwards. However, upon 1 assistant? advice of counsel 1 must assert my rights as 18 MR. PIKE: Form. 18 protected by the Sixth, Fifth and Fourteenth 9 A Mr. Edwards, 1 wouid iike to answer all 1 9 Amendment. 2 0 your questions here today. However, upon advice 20 Can you explain to the jury what 2 1 of eounsei, they've instructed me that I must 2 2L Gisiaine Maxwell's role was in helping you to 22 assert my Fifth, Sixth and Fourteenth Amendment 22 access underage minors? 2 3 rights to that question. 2 3 MR. PIKE: Form, assumes facts not in 24 And Story Cowles, in addition to being 24 evidence. 2 5 your personal assistant, is Sarah Kellen's 25 A You know i wouid like to answer each and 526 528 boyfriend; is that true? 1 every one of your questions posed here today, Mr. 2 MR. PIKE: Form. 2 Edwards. Unfortunateiy i have to answer that 3 A Though I would iike to answer ali your 3 question on advice of counsel by invoking my 4 questions, Mr. Edwards, on advice of counsel 4 rights under the Sixth, Fifth and Fourteenth 5 they've instructed me that i must assert my 5 Amendment. 6 rights under the Sixth, Fifth and Fourteenth 6 Do you have any remorse for sexualiy Amendment. 1? molesting Jane Doc? 8 Prior to the police executing, the Palm 8 MR. PIKE: Form, argumentative. 9 Beach police executing a search warrant on your 9 A I would like to answer every one of your 10 house in October of 2085, did you direct Adriana 10 questions regarding Jane Doe. However, at least 11 Mncinska to remove at least three computers from 11 today, my counsel has instructed me to assert my 12 your home? 12 rights as protected by the Sixth, Fifth and 13 MR. PIKE): Form. 13 Fourteenth Amendment. 14 A Though I wouid iike to answer at! your 1 4 When is the East time that you visited 15 questions, Mr. Edwards, my attorneys at least 15 your island, Little St. James? 1 6 today have advised me i must assert my rights 1 6 MR. PIKE: Form. 17 under the Sixth, Fifth and Fourteenth Amendment. A Though I would like to answer all your 18 Where are those computers today? 18 questions, Mr. Edwards, my counsel advised me i 19 MR. PEKE: Form. 1 9 must assert my rights as protected by the Sixth, 20 A Though! wouid like to answer ail your 20 Fifth and Fourteenth Amendment. 2 1 questions, my attorneys have advised me I must 2 1 Has any court given you permission to go 22 assert my rights under the Sixth, Fifth and 22 to your island or the Virgin islands while you 23 Fourteenth Amendment. 2 3 have been on house arrest? 24 Isn't it true that these computers 2 4 MR. PIKE: Form. 25 contain the names and telephone numbers of 25 A Mr. Edwards, though i would like to 49 (Pages 525 to 528} U.S. Legal Support (561) 835*0220 529' 531 3. answer all your questions, my counsel has advised 1 MS. EZELL: Okay. i can begin. Are we 2 me that I must assert my rights protected by the 2 ending at 4:00? 3 Sixth, Fifth and Fourteenth Amendment. 3 MR. PIKE: Yes, we are ending at 4:00. 4 Have you interacted sexualiy with 4 CROSS EXAMENATION 5 underage minors since beginning your house arrest 5 BY MS. EZELL: 6 or community control? I 6 MS. EZELL: Let the record reflect that 7 MR. PIKE: Form. 7 I have 3:22 right now. 8 A Though I would like to answer each and 8 Mr. Epstein, good afternoon. 9 every one of your questions posed here today, my 9 A Good afternoon. 10 counsel has advised me that I must assert my 10 You were previously deposed by Mr. 3. 1 rights protected by the Sixth, Fifth and 3. 1 Horowitz on Monday, March 8th of this year. You 12 Fourteenth Amendment. 1 2 were asked with respect to Jane Doe 103, "Do you 1 3 Mr. Epstein, is it your intention to 3 acknowledge that she's been to your home?" There 14 testify in the trial of Jane Doe versus Jeffrey 1 4 was a form objection and your answer was, "Again 3, Epstein? 1 5 wouid like to answer most of your questions. 1 6 MR. PIKE: Object to the form. It may 1 6 HoweVer, today as i've answered most, almost all disclose attomeylclient work product 17 of your questions and will continue to answer on 1 8 information. I instruct him not to answer. 18 advice of counsel, 1 bciieve, this question, I 19 Does Stery Cowles work for you at 19 have to assert my Fifth Amendment, Fourteenth 2 0 Florida Science Foundation? 20 Amendment and Sixth Amendment rights under thu 2 1 MR. PIKE: Form. 2 1 U.S. Constitution." 22 A Though I would like to answer each and 22 If you were asked the same question 2 3 every one of your questions, Mr. Edwards, at 23 today, what would your answer be? That question 2 4 least today my counsei has advised me I must 2 4 was: "Do you acknowledge that Jane Dec 103 has 2 5 assert my rights as protected by the Sixth, Fifth 2 5 been to your homeyour intent in the future to 2 Jane D06 103 is Jane Doe 103. 3 engage in sexual activity with underage minor 3 A would iike to answer the question so 4 children? 4 the answer would be the same. 5 MR. PIKE: Form. 5 MR. PIKE: By ?answering that question,? 6 A I would like to answer each one of those 6 you?re invoking Fifth, Sixth and 7 questions, Mr. Edwards. However, today my 7' Fourteenth? 8 counsel has advised mel must assert my rights 8 THE WITNESS: Yes. 9 protected by the Sixth, Fifth and Fourteenth 9 MR. PEKE: Piease do so. 1 0 Amendment. 10 A I'm invoicing my Sixth Amendment, Fifth 1 When you give that answer, that you 1 1 Amendment and Fourteenth Amendment right. 1 2 would like to respond to each one of my 12 You were then asked "230 you acknowledge 13 questions, wouid it then be your preference to 13 that Jane Doe 103 came to your home for sexual l4 expiain to the jury why it is that you feel 14 contact during her childhood and that you paid 1 5 entitled to sexually molest underage minor 15 her for those services?" 1 6 children? 16 Mr. Pike said "Form, predicate, 17 MR. PIKE: Form, move to strike. 17 foundation, argumentative," and your response was 18 Mischaracterizes the witness?s testimony. 18 would like to answer that question. I think 13 A 20 that question as well, but my counsel has advised 20 and not however, today I'm going 10 have *0 2 1 me that I must assert my rights as protected by 2 assert my Fifth Amendment, Sixth Amendment and 22 the Sixth, Fifth and Fourteenth Amendment. 22 Fourteenth Amendment rights under the U.S. 2 3 MR. EDWARDS: I don't have anything 2 3 Constitution, because I would like to answer that 2 4 further, 2 4 question, my attorneys have advised me that i 2 5 MR. PIKE: Ms. Ezell? 2 5 cannot today, cannot answer any question that may 50 (Pages 529 to 532) U.S. Legal Support (561) 835-0220 533 535 1 be relevant to this iawsnit." 1 could answer those questions." 2 If you were asked that same question 2 can you answer that question today? 3 today, would your answer be the same? 3 MR. PIKE: Form. 4 MR. PIKE: i'm going to object. Form, 4 A Ma'am, unfortunately i?m going to have 5 and I instruct you if your answer is the 5 to invoke my Sixth Amendment, Fifth and 6 same, pieasc tell Ms. Ezeli that. 6 Fourteenth Amendment right to that question. "i A My answer is the same, invoking my right 7 Then you were asked 8 under the Sixth, Fifth and Fourteenth Amendment. 8 THE WITNESS: Can we go off the record 9 9 10 were instructed not to answer the question, but 10 THE VIDEOGRAPHER: Off the Video recori 11 here, ?ve weeks later, today, you also, today, 1 1 3:32 pm. 12 can?t answer those questions, correct? 12 THE WITNESS: Just two minutes. 1 3 MR. PIKE: Asked and answered. 13 MR. EDWARDS: For what? We are 14 A E?m going to, on advice of counsel, Ms. 1 4 going to have a discussion off the record? 1 5 Ezeii, respectfully assert my rights as protected 15 MR. I think my client wants to 3. 6 by the Sixth, Fifth and Fourteenth Amendment. 3. 6 speak with me. 3.7 Later Mr. Horowitz said, "Sir, are yen 17 MR. EDWARDS: Okay. 18 asserting your Sixth, Fifth and Fourteenth 18 MR. PIKE: Are you okay with that Ms. 1 9 Amendment privileges because you're innocent? I 19 Ezeii? 20 that what you're telling us?" 2 0 MS. EZELL: Yes. 2 1 You said "Today on advice of counsel I 2 1 MR. PIKE: Offthe record. 22 cannot answer your questions, any of your 2 2 (Pause in the proceedings.) 2 3 questions that may be relevant to this lawsuit." 2 3 THE VIDEOGRAPHER: 24 MR. PIKE: Form. 24 THE WITNESS: Sorry, go ahead. 2 5 What would your answer be today to that 2 5 THE VIDEOGRAPHER: Back on the video 534 536 1 question? 1 record 3:33 pm. 2 MR. PIKE: Same objection. 2 Later in that same deposition, Mr. 3 A On advice of counsei, with respect to 3 Horowitz asked "Did you have surveillance cameras 4 that question, I'm going to have to assert my 4 in either the interior or exterior of your home 5 rights as protected by the Sixth, Fifth and 5 at [it Briilo Way between 2801 and 2006?" 6 Fourteenth Amendment. 6 You answered, "Mr. Horowitz, I'm going 7? So again, your answer wasn't just that 7 to answer that question the same way as I?ve 8 answer then, ?ve weeks ago, but today, you again 8 answered most of your other questions here 9 cannot answer on advice of counsel, correct? 9 today. I wouid iike to answer each one of your 10 MR. i?lKE: Move to strike. 10 questions regarding your clients with great 3. 1 Mischaracteriaation. Piaintiff has 11 speci?city, however my counsei has advised me 12 invoked sorry, defendant has invoiced 12 that 1 may not today, and therefore have to 13 Fifth, Sixth and Fourteenth. That's his 13 invoke my Fourteenth Amendment rights, my Sixth 1 4 answer. 14 Amendment rights and my Fifth Amendment rights as 15 MS. EZELL: So he invoices them today, as 15 provided by the U.S. Constitution." 3. 6 weil? 1 6 So what about today? Can you answer MR. PIKE: Yes, ma?am. 17 that question for us today? 18 Mr. Horowitz asked "Between 2095 and 18 MR. PIKE: Object to the form. 1 9 2006, did your sexual interests include digitally 19 A Unfortunately, Ms. Ezeti Mrs. Ezell, 2 penetrating the vaginas of girls between the ages 20 1?81 SONY- 21 of 12 and 17?" 21 Ms. is fine. 22 Mr. ?ike objected "Form," and you said, 22 A Okay. MS. 82611. Unfortunately on 2 3 find these questions I would like to 23 advise of ecunsei, I have to assert my rights as 2 4 answer every one of those questions. However, 24 protected by the Sixth, Fifth and Fouxteenth 25 counsel has told me I may not today. I wish I 25 Amendment. 51 (Pages 533 to S36) 0.3. Legal Support (561) 835-0220 MR. PIKE: And Ms. Ezell, let me caution 1 MR. I-IOROWITZ: ijoin in Ms. Ezell's 2 you that We listened to several of your 2 comments. 3 questions. The first one being a repetition 3 MR. EDWARDS: Agreed. 4 of Mr. Horowitz?s question approximately 4 MR. PIKE: Thank you. Three against 5 four weeks ago dealing with your client 103, 5 one. Nonetheless, again, i hold steadfast 6 so i did not have a problem with that 6 the same argument. it is repetitious and 7 background information being repeated. 7 whether or not he is not going to waive 8 However, it seems that the questions that 8 Fifth, Sixth and Fourteenth yesterday and he 9 you?re discussing now and going over are 9 is not going to waive it today, 1 0 just a repetition of Mr. Horowitz?s 10 MS. EZELL: That's ?ne. My objection 11 11 1 2 been established and really has no relation, 1 2 say that "Today i have been instructed not 1 3 in my opinion, to your particular clients. 13 to answer it, because then i come here 1 4 Given the fact we are here today, Mr. 14 hoping ?ve weeks later I may get an answer. 1 5 Horowitz has taken the liberty of concluding 5 and unfortunately that?s not been the case. 1 6 his deposition, obviously with rebuttal 1 6 We have had the same invocation of the available, same with Mr. Edwards, 1 would 17 privileges today, only today,just for 1 8 ask, rather than to have to seek assistance 18 today. 1 9 of the Court, that your questions be 1 9 MR. PIKE: Well, I 2 tailored toward your client. 2 0 MS. EZELL: I'm done with that line of 2 1 MS. EZELL: Mr. Pike, i would beg to 2 1 questioning. 22 differ with you. Questions regarding his 22 MR. PIKE: Okay. 2 3 sexual interests, including digitally 2 3 MS. EZELL: But i think i had the right 24 penetrating vaginas of girls between ages of 24 to ask. 25 12 and 17 certainly pertain to my client. 25 MR. PIKE: Thank youMR. PIKE: Ms. Ezell, you were at that 1 MS. EZELL: Thank you. 2 deposition. You cross~noticed that 2 Mr. Epstein, are you a citizen of the 3 deposition and these cases have been 3 United States? a 4 5 formed, with the exception of one question, 5 And are you a citizen of the United 6 since you commenced your portion of the 6 States Virgin Islands? 7 depo, you have not formed one question 7 A i don't know what that means. 8 8 O?mm?mmonu?monMUMRd 9 You just asked a general questiou that 9 States are you a citizen? 10 had already been asked by Mr. Horowitz who 10 A l'm a citizen of the United States. i. 1 commenced the Volume 1 of this Volume ill or 1 1 And of what State or territory in the 12 IV continuation ofthe deposition. if you 3.2 United States do you claim to he a citizen? 1 3 want to tailor these questions to your 13 A I?m a citizen of the United States. 1 4 client, I have no problem with that, but to l. 4 Where do you vote? 3.5 ask the same exact question Mr. Horowitz 3.5 A vote in the Virgin islands. 1 6 asked who commenced the deposition is a 6 Where do you pay your taxes? 17 waste of time. MR. PIKE: Form. 18 MS. EZELL: That may be your opinion, 18 A On advice of counsel, I?m going to have 1 9 Mr. Pike, but I believe I have, particularly 19 to assert my rights as protected by the Sixth, 20 in the way these questions were answered 2 0 Fifth and Fourteenth Amendment. 2 1 ?ve weeks ago, that today, that day he was 2 1 And I would just note that your tax 22 unable to answer because of advice of 2 2 returns are public documents available to the 23 counsel. certainly have the right to ask 2 3 government, and there is no am no risk of 24 him whether this day, ?ve weeks later, he 2 4 incriminating yourself with such a document. I): 2 5 can answer that question. 2 5 you still maintain the same objection? 52 (Pages 537 to S40) 0.3. Legal Support (561) 835-0220 541 543 1 MR. He does, and that calls for a 1 who came to your home to provide massages and 2 legal conclusion, which currently is, 2 other sexual grati?cation for you, were they 3 think, under it was under appeal and now 3 often transported by Sarah Kellen or other 4 it is back under appeal. 4 assistants that you employed? 5 Before serving yourjail time in Palm 5 MR. PIKE: Form. 6 Beach County, followed by your community control 6 A Though I would like to answer each and time, was your principal place of residence the 7' every one of your questions, Ms. Ezell, I 8 dwelling in Manhattan? 8 respectfully must decline. On advice ofcounsol 9 ATMWW 9 10 Your mansion in Manhattan? 10 protected by the Sixth, Fifth and Fourteenth 11 MR. PIKE: Form. 11 Amendment. 12 A I'm sorry, but at least today, i would 12 Would you acknowledge, Mr. Epstein, that 3 like to answer all your questions, Ms. Ezeli. 13 once the girls were there, beginning with their 14 However, on advice of counsel I will have to 3.4 first experience, their first visit, there was a 1 5 respond by invoking my Sixth, Fifth and 3.5 sort of a ritual that was followed in regard to 6 Fourteenth Amendment. 3. 6 how they were treated, what they were asked to do 1 7 I. won't repeat the same questions 17 and what occurred? 1 8 regarding the plan or scheme. I'll try not to, 18 MR. PIKE: I?m sorry, I didn?t know if 1 9 that have already been covered today. To the 9 that was the question. 2 extent that they didn't just apply to that one 20 MS. EZELL: It is a question. 21 plaintiff, in most instances, I believe that Mr. 23. THE WITNESS: What's the question? 22 Edwards said, "young women" or "young girls like 22 MR. PIKE: What is the question? 2 3 or including Jane Doe," but there were a few 2 3 From the first visit a girl might make 2 4 additional questions in that area I wanted to 24 to your home, was there a ritual or routine that 2 5 ask. 2 5 was followed with regard to what happened during; 542 544 1 Within that arrangement whereby girls 1 that visit? 2 would come or he brought to your home to provide 2 MR. PIKE: Form. 3 massages and other sexual grati?cation for you, 3 A Ms. Ezell, I would like it answer all 4 we re they often brought by taxis that Were paid 4 your questions that you posed here todaysomeone on your hehall? 5 will have to respond unfortunately, as I?ve 6 MR. PIKE: Form. 6 responded to most of the others which is, my 7 7 8 questions today, Ms. Ezeli, I'm going to have to 8 Sixth, Fifth and Fourteenth Amendment. 9 respond to that question as I've responded to 9 For instance, in addition to the other 10 most of your other questions, which is, on advice 10 things that Mr. Edwards and Mr. Horowitz askec 11 of counsel, at least today, they've instructed me 1 1 about, within the same area, would Ms. Kellen or 12 to a3scrt my rights as protected by the Sixth, 12 one of your other assistants usually go up and 3 Fifth and Fourteenth Amendment. 3. 3 lay out the towels and particular massage oils 1 a Also, within that same scheme, were 1 4 that you like? 1 5 these girls sometimes transported to or from your 1 5 MR. PIKE: Form. 1 6 house by the current houseman employed by you at 16 A Ms. Ezeli, unfortunately i have to that time? 1 answer that question as l've answered most of 1 8 MR. PIKE: Form. 18 your other questions here today, respectfully 9 A Though I would like to answer all your 19 decline to answer on advice of counsel who's 2 0 questions, Ms. Ezell, that question as well as 20 asked me to invoke my Sixth Amendment, Fifth 2 1 the others, i must unfortunately at least today, 21 Amendment and Fourteenth Amendment right. 2 2 on advice of counsel, invoke my Sixth Amendment, 22 Was it more or less routine that when a 2 3 Fifth Amendment and Fourteenth Amendment right. 23 girl would come for the first time, that she 24 And again following with that plan as 24 would be accompanied to the massage area by 25 discussed previously, were those same young women 25 another woman or girl? 53 (Pages 541 to 544} 111.3. Legal Support (561) 835-022O S45 54'? 1 MR. PIKE: Form. 1 respectfully decline to answor that question, on 2 2 3 question as I answered most of your other 3 rights as protected by the Sixth, Fifth and 4 questions today, which is on advice of counsel, i 4 Fourteenth Amendment. 5 have to assert my rights as protected by the 5 Did either Ms. Kellen, or you, or the 6 Sixth, Fifth and Fourteenth Amendment. 6 girl who perhaps had been there before instruct 7 Did it occur quite often that Sarah 7 the new girl to begin by massaging the back of 8 Kellen would lead the girl up and introduce you 8 your legs and your back? 9 to her and then quietly leave? 9 MR. PIKE: Form. 1 0 MR. PIKE: Form. 1 0 A would like to respond to all your 11 A Ma'arn, l'in going to respectfully have to 1 1 questions, but unfortunately at least today, my 12 decline to answer that question today on advice 1 2 counsel has advised me I must assert my rights as 3 of counsel. They?ve asked me to assert my rights 13 protected by the Sixth, Fifth and Fourteenth 1 4 as protected by the Sixth, Fifth and Fourteenth 1 4 Amendment. 1 5 Amendment. I would like to answer each and every 1 5 And did you or Ms. Kellen generally ask 1 6 one of your questions. 16 the girls or instruct the girls to remove their Did it also occur sometime that the girl 1 7 clothing? 18 would be accompanied by the girl who brought he 18 MR. Form. 1 9 and the girl who brought her would go up to your 1 9 A Unfortunately, Ms. Ezell have to 20 bedroom and massage area with her, on her initial 2 0 respectfully decline to answer that question 2 1 visit? 2 1 today. On advice of counsel, they?ve asked me to 2 2 MR. PIKE: Form. 2 2 assert my Sixth Amendment, Filth Amendment out 23 23 2 4 I'm asking about whether or not there 2 4 After having til-?le back of your legs 2 5 was a sort of routine that was followed when the 2 5 the feet, the back of your legs and your back 546 548 1 girls would come to your home to provide the 1 massaged, would you then typically turn over, 2 massages and other sexual grati?cation for you. 2 exposing yourself, laying on your back? 3 I?m asking whether or not part of that routine 3 MR. PIKE: Form. 4 was that they would be accompanied by the girl 4 A Ms. Ezell, I?m going to respectfully 5 who brought them? 5 have to decline to answer that question today, 6 MR. PIKE: Form. 6 because my counsel has asked me to assert my 7 A l?rn going to have to, on advice of 7 Sixth Amendment, Filth Amendment and Fourteentl 8 counsel, answer that question by asserting my 8 Amendment right, though i would like to answer 9 rights as protected by the Sixth, Fifth and 9 every one of your questions. 10 Fourteenth Amendment. 10 Would it be your practice at that point, 1 1 If they were accompanied by the girl who 1 1 depending on the skittishness of the girl to 12 brought them, would it be your usual practice to 12 begin trying to fondle her breasts or ruh her 1 3 allow them to start the massage and then excuse 1 3 vagina? 14 the girl who had brought the second girl for her 14 MR. PIKE: Form. 1 5 ?rst visit? 1 5 A Ma'am, i respectfully have to decline to 1 6 MR. PIKE: Form. 1 6 answer that today, though l. would like to answer 17 A Pro going to do my best to respond to 17 each one of these questions. My counsel has 18 these questions, but my counsel has advised me 18 instructed me to assert my Sixth Amendment, Fifth 9 that I must assert my rights as protected by the 9 Amendment and Fourteenth Amendment right. 20 Sixth, i?h and Founeenth Amendment, Ms. Ezell, 20 Assuming the girl was ill at ease, would 2 1 so respectfully must decline. 2 1 it be your practice to then talk with her to try 22 Did you have a routine way that you 22 to elicit from her, her interests, her goals, the 23 liked the massage itself to be conducted? 23 things that were important to her in her life? 24 MR. PIKE: Form, 24 MR. PIKE: Form. 25 A Ms. Ezell, l'm going to have to 2 5 Was that part of your routine? 54 (Pages 545 to 548) U.S. Legal Support (561) 835*0220 549 551 1 MR. PIKE: Sorry. Form. 1 another girl, was it your practice to pay the 2 A Ma'am, though I would Iike to answer 2 procuring girl at least $208 for bringing the new 3 every one of your questions today, unfonunatciy 3 girl? 4 my counsel has advised me I must assert my rights 4 MR. PIKE: Form. 5 as protected by the Sixth, Fifth and Fourteenth 5 A Again? Sorry. Can you repeat the 6 Amendment. 6 question? 7 Would it generally be your practice, if 7? Sure. Maybe i can state it a little 8 the girl was skittish, to perhaps wait until the 8 better. 9 second visit to introduce a vibrator into the 9 Did you tell the girls that you would 10 routine? 10 pay them $200 every time they brought a new 1 1 MR. PIKE: Form. 1 1 girl? 12 A Ms. Ezeli, unfortunater I have to 12 MR. PIKE: Form. 1 3 answer that question the same way as I?ve 3 A Unfortunately, Ms. Ezeli, i?m going to 14 answered every one of your questions today, which 14 have to respond to that question the same way as 1 5 is, I would have to assert my rights protected by 15 I?ve responded to most of your other questions 1 6 the Sixth, Fifth and Fourteenth Amendment on 1 6 today. On advice of counsel, they've instructed 17 advice of counseI. 17 me to assert my Sixth Amendment, Fifth Amendmer 18 Would you try to calm the girl by 18 and Fourteenth Amendment right. 19 telling her to relax, that there was nothing 19 And indeed, did you keep that promise 2 0 wrong with what was going on? 20 and either pay them directly or have Ms. Kellen 2 1 MR. PIKE: Form. 21 pay the procurer $290 for each new girl that she 2 2 A Ma?ain, unfortunately I have to respond 22 brought? 2 3 to that question as I?ve responded to most of 23 MR. PIKE: Form. 2 4 your other questions here today, which is by 24 A Unfortunately, Ms. Ezeil, I have to 2 5 invoking my Sixth Amendment, Fifth Amendment and 25 respond to that question respectfuliy the same as 550 552 1 Fourteenth Amendment right. 1 I responded to most of your other questions here 2 Assuming that the git-i made it through 2 today. My counsel has advised me I must assert 3 the first session, would you generaliy wait until 3 my rights as protected by the Sixth, Fifth and 4 you had reached climax before dismissing her? 4 Fourteenth Amendment. 5 MR. PIKE: Form. 5 THE WITNESS: Can we take atwo-minute 6 THE WITNESS: Earthquake? 6 break? 7 MR. PIKE: Train. For the record a THE VIDEOGRAPHER: Going off the victor 8 train is going by. 8 record 3:54 pm. 9 A Ms. Ezeii, unfortunately I have to 9 (Pause in the proceedings.) to respond to that question as i've responded to 10 THE VIDEOGRAPHER: Back on the video 1 1 most of the other questions here today, which is 1 1 record 3:56 pm. 1 2 I must assert my rights protected by the Sixth, 12 Did you let the girls know that the more 1 3 Fifth and Fourteenth Amendment on advice of my 1 3 they let you do, the more they would be paid? 14 counsel. 14 MR. Form. Again, I'm reaily 15 Wouid you generally pay the new girl 15 trying to work with you, Ms. Ezeii, but that 16 $200 for the massage, either by telling her that 16 is an exact question that Mr. Horowitz 17 the money was on the counter or by telling her asked at the commencement of the 18 that Ms. Kellen would pay her downstairs? 18 deposition. We are back in generalities 19 MR. PIKE: Form. 1 9 again, and it is repetitious. If you could, 20 A Unfortunately, Ms. Ezeil, today i have 2 0 let's try to narrow it to your ciient. 2 1 to respond to that question the same way I've 2 1 MS. EZELL: I?m certainty entitled to 22 responded to all your other questions, which is 2 2 see how my client ?ts into the big picture 23 by invoking my Sixth Amendment, Fifth Amendmert 2 3 or my ciients, and whether this was part of 2 4 and Fourteenth Amendment right. 2 4 a pattern and whether they indeed were 25 And if that girl had been brought by 2 5 treated according to a pattern or scheme or 9+ 55 (Pages 549 to 552) U.S. Legal Support (561) 835-0220 routine. 1 pro-existing obligation beginning at 4:00 2 MR. PIKE: Okay. ijust don?t hear any 2 o'clock. Hoid on a second, guys. So this 3 questions regarding your clients. That?s 3 deposition will be continued consistent with 4 what i?m saying. 4 various court orders. 5 Do you recall that the first time Ali. 5 MS. EZELL: Okay, thank you. 6 came to provide you a massage, you told her to 6 THE VIDEOGRAPHER: Going off the vider 7 take off her clothing, which she refused to do? 7 record 4:00 pm. 8 MR. PIKE: Form. 8 THE. COURT REPORTER: Thank you all. 9 A Ali. -- can we use names so there is no 9 Same orders as yesterday? 10 confusion here? 10 MR. EDWARDS: Yes. 1 1 All. Is She is Jane Doe 103. 11 MR. HOROWITZ: Yes. 1 2 A I?m going to have to respond to that 12 MR. PIKE: Yes. 1 3 question, as responded to at} your other 13 MS. BZELL: Yes, please. 1 4 questions, Ms. Ezell, respectfully, and on advice 1 4 THE COURT REPORTER: Thank you all. 15 of counsel 1 have to assert my rights as 15 (Whereupon, the deposition was adjourned 16 protected by the Sixth, Fifth and Fourteenth 16 at 4:05 o?clock, sine die.) 17 Amendment. 1? 18 And when she did refuse to do that, did 18 19 you begin to try to touch her and paw at her and 19 20 remove some of her clothing? 20 2 1 MR. PIKE: Form. 2 1 22 A Ma?am, I would respectfuliy would 2 2 2 3 like to answer that question, as I would iike to 23 24 answer most of the questions you've posed here 24 2 5 today. Respectfully, l'rn going to have decline on advice of counsei and invoke my Sixth 1 THE STATE OF FLORIDA) 2 Amendment, Fifth Amendment and Fourteenth 2 COUNTY 01? PALM BEACH) 3 Amendment right 3 I, BECKER, a Registered- 4 Over the approximately 17 months that 4 Professwnal?Reporter and Notary Public for the 5 A.H. came to your home, did you or your agents 5 State Of ?endgat Large? do hfareby 06ml? That - 6 1 reported the Videotaped continued deposdion of 6 frequently cali her at her home number or her 7 JEFFREY the DEFENDANT, caged by t, cell number arranging for encounters, arranging! 8 PLAINTIFF in the above-entitled action; that the 8 for her to come ?0 Wu" home ?3 Prov?e the 9 witness was duly sworn by me; that the foregoing 9 massage and sexual favors, sometimes as much a; 10 pages, numbered from 336 to 560, inclusive, 1 0 twice a day? constitute a true record of the deposition by 1 3. MR. PIKE: Form. 12 said Witness. 12 Lars break it up. 13 I further certify that I am not attorney 13 During the 17 months that she came to 14 or counsel of any of the parties, nor a relative 1 4 your home, did it frequentiy happen that you or 1 5 Ghempioyee. Of any attorney or .coumel eqmeaea 6 w1th the action, nor financlaily interested in 15 one of your agents would call ahead of time to 17 the action. 16 tefl her that you would be coming to town? 18 WITNESS MY HAND and official seal in the 17 MR. PIKE: Form. 1 9 City of West Palm Beach, County of Paim Beach, 18 A Ma'am, I'm going to respectfully have to 20 State of Fiorida, this 19% day Oprfii. 2010- 1 9 decline to answer that question on advice of 2 1 fl 20 counsel. They've instructed me to assort my - I I;a 2 1 Sixth Amendment, Fifth Amendment and Fourteenth 22 TERRIPECKEK Register 2 2 Amendment right Professmnai Reporter and 2 3 Notary Pubiic, State of Fionda 23 MR. PIKE: Ms. Ezeii, as you know we've at Large? My Commission expires 2 4 discussed this at the commencement of 2 4 March I 3, 20; It 2 5 today's deposition, that we had a 2 5 56 (Pages 553 to 556) U.S. Legal Support (561) 835-0220 THE STATE OF FLORIDA) 1 ERRATA SHEET 2 2 in Re: JANE DOE V. EPSTEIN 3 3 DO NOT WRITE ON TRANSCRIPT 4 ENTER CHANGES KERR: I 4 5 The fOTegC'mg Celil?caie ??35 5 PAGE LINE CHANGE REASON 6 acknowledged before me this 6 '7 day of 2010Notary Public, State of Florida. JEFFREY EPSTEZN 1 5 My commission No. i: Expires March 13, 2011. 18 16 7 1 9 COUNTY OF PALM BEACH) 8 2 DO HEREBY CERTIFY THAT JEFFREY EPSTEIN 1 9 appeared before me and stated that he has read 2 0 2 1 his deposition; further, that this Errata Sheet ,2 1 was signed in my presence on this day JEFFREY EPSTEIN, do hereby 1 353- . Registered Professronai Reporters 2 certify that I have read the foregoing transcript 2 444 West Railroad Avenue . . . . 300 3 of my deposztton given on April 14, 2010; that 3 ?16392;: Beach, Florida 33401 4 together with the correction page attached hereto (3 5 rioting changes in form or substance, if any, it Aprii 19.2019 5 6 IS true and correct. 5 BURMAN. CRITTON, COLEMAN 303 Banyon Boulevard 1 Suite 400 8 West Paint Beach, Florida 33401 a JEFFREY EPSTEIN ArremzoN: MICHAEL PIKE, ESQ. 9 9 In Re: JANE DOE v. ersrem 1 0 10 Deposition of: 3EFFREY EPSTEIN 1 1 1 12 2 Dear Mr. PikeSince counsel have agreed that you may 1 ?1 1 do hereby certify that the deposmon 14 have the witfnoss read and sign your copy of the . . deposition, or your convenience, enclosed 1 5 of EPSTEIN was submitted to the w1tnes 15 heirewim you. win {and an Errata Shoe; for {he 1 6 for reading and signing; that after he had stated 1 6 mam any Chimes we 1 7 to the undersigned Notary Public that he had read 3113329112501" your prompt attentionGEES, 18 and examined his deposztlon, he s1gned the same us 1,55%; SUPPORT 19 in the presence of the undersigned authority on :3 - TERM BECKER, Registered 2 0 the day Of 2010. 2 1 Professional Reporter, Notary 2 1 Public, State of Florida at 2 2 22 Large. My commission expires March 13, 201 z. 2 3 23 CC: Adam Horowitz, Esq. 2 4 2 4 Braciiey Edwards. Esq. Katherine Ezeii, Esq. 2 5 2 5 5? (Pages 557 to 560) U.S. Legal Support (561) 835-0220 DEFENDANT BRADLEY EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et (A. Case No.: 50 2009 CA 040800MMBAG ATTACHMENT 5 U300 UNITED STATES DISTRICT COURT WQEIE SOUTHERN DISTRICT OF FLORIDA CASE NO.: JANE DOE NO. 2, Plaintiff, ?vs- VOLUME I OF JEFFREY EPSTEIN, Defendant. Related cases: 08~80232, 08*08380, 08*80381, 08*80994, 08*80993, 08~80811, 08~80893, 09?80469, 09*80591, 09*80656, 09~80802, 09~81092 VIDEOMCONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE NO. 4 Tuesday, October 27, 2009 11:11 6:05 p.m. 250 Australian Avenue South SuitewllE West Palm Beach; Florida 33401 Reported By: Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting (561) 832~7500 PROSE COURT REPORTING INC. (561) 832~7506 Page 30 Page 32 1 A. It means he was in my face. We were 1 MR. HOROWITZ: Object to the form. 2 arguing, argument. 2 THE WITNESS: What is a more traumatic 3 Q. You mean he was close 3 time? 4 A. Yes. . 4 BY MR. LUTTIER: 4, Q. his face wasciose in proximity to 5 Q. Yeah. What was more traumatic than that 6 yours? 6 that had happened to you in your life as of that 7 A. Yeah. 7 point in time? 8 Q. And he hit your ?nger? 8 A. Meeting Jeffrey Epstein. 9 A. Uh~huh. 9 Q. Meeting Mr. Epstein. Do you mean 10 Q. Was that -- 10 physicaiiy being introduced to the man? 11 MR. HOROWITZ: Instead of uh~huh just say 11 A. No, being sexually abused by Mr. Epstein. 12 yes. 12 Q. Okay. And what do you mean by sexualiy 13 THE WITNESS: Yes. 13 abused? 14 BY MR. LUTHER: 14 MR. HOROWITZ: Take your time. 15 I assume that while that event was 15 THE WITNESS: Being fingered by him, 16 transpiring it was a signi?cant event to you. 16 having him use a vibrator on me, grabbing my 17 A. Yeah, when it happened. 17 nipples, smelting my butt, jerking off in front 18 Q. Did it scare you? 18 of me, ticking my ciit, severai times. 19 A. Uh-huh. 19 BY MR. LUTTIERcause 20 Q. What severai times, ticking your clit 21 A. Yes. 21 severai times? 22 MR. HOROWITZ: Thank you. 22 A. Fingering me severai times. 23 THE WITNESS: Sorry. 23 Q. So, ticking your clit was not several 24 BY MR. LUTTIER: 24 times? 25 Q. Did it cause you to have fear? 25 MR. HOROWITZ: Object to the form. a Page 31 Page 33 1 A. Yeah. 1 THE WITNESS: No. 2 Q. Fear of him, I would assume. 2 BY MR. LUTTIER: 3 A. Yeah. 3 Q. Now, when did this anything eise? 4 Q. Has up to that point in time, how did 4 A. (Witness shakes head.) 5 it com are to any other event that had happened in 5 Q. Is the answer, no? 6 your iife in terms of the shock to you and the 6 A. Yes, it's no. 7 trauma it caused you? 7 MR. HOROWITZ: Object to the form. I 8 A. It was shocking, but it made me strong, 8 don't think she even understands what the iast 9 and I've moved on from that. 9 question was. 10 Q. At the point in time that this interaction 10 BY MR. LUTTIER: 11 happened that you've described between you and 11 I said anything else. 12 Mr. Vinyard where he bit your finger and your face 13 Q. Now, when was the date that this event 14 A. Uh?huh. 14 occurred where the police were summoned with 15 Q. was that the most traumatic thing that 15 Mr. Vinyard? 16 had ever happened to you in your life as of that 16 A. With when what? 17 point in time? 17 Q. With Preston Vinyard, when you say your face and he bit your ?nger. 19 Q. Had you had other boyfriends do the same 19 A. Yeah. 20 thing to you? 20 Q. When did that happendon?t remember. 22 Q. What was a more traumatic event that had 22 Q. What year? 23 happened to you at that point in time than the event 23 A. Maybe '06, or no, I sorry. I graduated 24 where your ex?boyfriend was in your face and bit 24 ?05 '03 maybe, ?04. 25 your ?nger? 25 (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Q. Had you met Mr. Epstein at the time that (561) 8327506 Page 34 Page 36 1 this event that you?ve described with Mr. Vinyard 1 I met him when I did. 2 occurred where he was in your face and bit your 2 Q. Well, we're going to come back to why you 3 ?nger? 3 would tell people something that is not true, but 1; 4 A. Idon?t remember. Yeah, because I met 4 I?ll get to that later. 5 Mr. Epstein before or around the same time that I 5 MR. HOROWITZ: Move to strike, . 6 met Preston. 6 argumentative. '53. 7 Q. Well -- 7 BY MR. LUTTIER: 8 A. I met him before I hung -- started, before 8 Q. Now, you say you ?rst met Mr. Epstein 9 1 was serious with Preston, so yeah. 9 when you were 15 in the middle of your sophomore 10 Q. Well, do you know when you ?rst met 10 year, and you said somebody, Haley Robson, you 11 Mr. Epstein? 11 mentioned 12 A. Yeah, when I was 15 years old. 12 A. Yes. 13 Q. And how do you know that's when you first 13 Q. she introduced you to him? 14 met him? 14 A. Uh~huh. 15 A. Because it was the middle of my sophomore 15 Q. What do you mean she introduced you to 16 year. I was 15 years old my sophomore year. 16 him? 17 Q. And how do you know it was the middle of 17 A. She brought me to his house. 18 your sophomore year? 18 Q. What do you mean she brought you to his 19 A. Because that?s when i was in class with 19 house? 20 Haley Robson and that's how I knew her and that's 20 A. She drove me to her his house. 21 who brought me there. 21 Q. Had you had some sort of discussion with 22 Q. Do you have any record of when you first 22 Haley Robson about going to Mr. Epstein's before she ,i 23 met Mr. Epstein; that is any written record 23 drove you to his house for the first occasion? 24 anywhere? 24 A. Yeah. 25 A. Any written record? 25 Q. Had you had more than one discussion with Page 35 Page 37 - 1 Q. Yep. 1 Haley Robson about going to Mr. Epstein?s house 2 A. On paper? 2 before she drove you there for the ?rst time? 3 Q. Whether it's examples, but I don?t mean 3 A. More than one conversation about going 4 to limit my question, examples could be you made a 4 there? 5 note somewhere, you noted it on a calendar, you 5 Q. Yep. 6 wrote it down someplace. 6 A. Yeah. 7 A. No. 7 Q. And how many conversations did you have 8 Q. is there any record to the best of your 8 with Haley Robson about going to Mr. Epstein?s house 9 knowledge anywhere in the world that establishes the 9 before you went there for the ?rst time? 10 ?rst date upon which you met Mr. Epstein? 10 A. Probably two, once on the phone and once 11 A. No. 11 on the way there. 12 Q. So, the sole basis for you to have for 12 Q. And how, how long was it or approximately 13 you claiming that you met Mr. Epstein in the middle 13 how long was it before you went there that you had 14 of your sophomore year 14 your conversations with Haley Robson about going to 15 A. I did. 15 Mr. Epstein's house before you went there for the 16 Q. is your recollection; is that right? 16 ?rst time? 17 A. Yes. 17 A. Ask that one more time, please. 18 Q. Have you ever told anyone in the world 18 Q. Do you know what the word prior means? It 19 that you met Mr. Epstein for the ?rst time at some 19 means before -- 20 other time? 20 A. Before it happened. 21 A. No. 21 Q. Okay. Prior to you going to Mr. Epstein's 22 Q. Are you sure? 22 house for the first time, how long was it before 23 A. From whatI can recall, yeah. I don't 23 that that you had this conversation with Haley 24 I mean, I don?t recall, butI don't see why 1 24 Robson? Was it like a month beforehand, two months 25 wouldn't tell the truth, like tell them that's when 25 beforehand, six months beforehand? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. r213." (561) 832-7506 it i Page 134 Page 136 1 Mr. Epstein?s? 1 A. I don?t remember when I saw her there, so 2 A. Probably a few times. 2 I don't know, like, if they were the same. 3 Q. How many? 3 Q. Okay. Well -- 4 A. Before I took I don't remember when I 4 A- What are YOU. like. I *r 5 took Lauren, so I can?t tell you how many times I 5 Q. Did there come a point in time after the 6 had been there before I took her. 6 third massage that the way you performed messages on 7 Q. What?s your best estimate? 7 Mr. Epstein changed? - 8 A. I don't know when I took her, so I don't 8 A- It prowesswew got worse. Yes. but I 9 know how to answer that question. 9 don't recall. 10 Q. Well, do you know if it was more than 10 Q. When you say worse, what do you mean by 11 three times? 11 worse? 12 A. I am sure. 12 A. He would get more, iike, aggressive, like, 13 Q. Was m- how old was Lauren when you took 13 he would be more friendly. Like after, like, going 14 her there? 14 there a couple of times, then he would ask me, oh, 15 A. I don't know how old Lauren was when I 15 will you take your top off, and then the next time 16 took her there. I think she was 18. 15 when I would setup aid 90 to leave. he 9085. take 17 Q. 50, Lauren was out of high school by then? 17 your bra off or, you know, next time you go can you 18 A. She might have been a senior in high 18 take your pants off, or it progressively got worse, 19 school or she could have been out of high school. 19 and then next time it was like, he like used a 20 Q. And she was one year ahead of you? 20 vibrator on me, and then the next time he used a 21 A. Yeah. 21 vibrator and ?ngering me, and then the next time he 22 Q. So, that would have meant that you were 22 would do that and then licking my clit, and then 23 taking her -- 23 before that, grabbing my nipples and at last, I mean 24 A. She could have been her senior year in 24 it progressiver got worse. 25 high school, or she, I could have been a senior year 25 Q. When you say the next time, you mean there Page 135 Page 137 1 in high school. 1 was one visit, and then literally the next visit he 2 Q. So, it could have been in your junior or 2 said, take your top off, and it was 3 senior year of high school? 3 next visit that he said something else, and 4 A. Yeah. 4 literally the next visit be said something else -- 5 Q. And you said you ?rst went in the middle 5 A Yeah. 6 of your sophomore year, right? 6 or were there more than one visit 1? A. Lin-huh. 7 A. It progressively got worse. 8 Q. 80, under your recollection of events 8 Q. Was there more than one time you performed 9 would it be a fair characterization that at the 9 messages between these events? to point in time that you took Lauren to Mr. Epstein?s, 10 MR. HOROWITZ: Object to the form. 11 you had been to Mr. Epstein?s on several occasions? 11 THE WITNESS: Ask that again. What do 3.2 A. Yeah. 12 you you talk 13 Q. At the point as of the point in time 13 BY MR. LUTTIER: 14 that you took Lauren thereLet?s take the fourth visit, what happened 25 messages that you performed for Mr. Epstein been 15 on the fourth visit? 16 conducted in the same manner as what you have 16 A. Get a massage, takes my shirt off, take my 17 described in the ?rst three visits? 17 underwear, Elke I just said. 18 MR. HOROWITZ: Object to the form. 18 Q. Well, I?m asking you about the fourth 19 THE WITNESS: I don't know when I brought 19 visit now. First of all, can you tell me when the 20 her there, so I don?t know you?re asking me 20 fourth visit happened? 21 the same question. 21 A. It happened after the third visit. 22 BY MR. LUTTIER: 22 Q. Okay. Probabiy happened before the ?fth 23 Q. At the point in time that you brought her, 23 visit, too, right? 24 had all the massages that you had performed for 24 A Yeah. I 25 Mr. Epstein been like the ?rst three? 25 MR. HOROWITZ: Argumentative. Can we take a. nun? F'lt?i?mi. NW ts?bxg?isa It ii sj (561) 832-7500 PROBE COURT REPORTING AGENCY, INC. (561) 832?7506 DEFENDANT BRADLEYJ EDWARDS ?8 STATEMENT OF UNDISPUT ED FACTS Epstein v. Edwards, et al. Case No. 50 2009 CA ATTACHMENT 4 Page 1 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. AD E.W. Wumm 'xvmm?ewmw; ?we-adage: Plaintiff, - .. JEFFREY EPSTEIN, Defendant. VIDEOTAPED DEPOSITION OF E.W. VOLUME I Thursday, May 6, 2010 12:31 3:39 p.m. m3: -. .-- 250 South Australian Avenue SuitelBOO West Palm Beach, Florida 33401 . .-.- Reported By: Joana Ricoiuti, RPR, FPR, CLR W'emsmme. - Notary Public, State of Florida I Prose Court Reporting Agency, Inc. 3 if 561) 832w7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 ronically signed by Jea na Ricciuti (601-280428-9381) ronically signed by Jeana Ricciuti (601~280~428-9381} ma measureth . iv ,5 {idly signed by Jeane Ricciuti (601-280-428-9381) wily signed by Joana Ricciuti (awesome-9331) Wi? seem ?a..;mxym< PROBE COURT REPORTING AGENCY: Page 114 Page$200 and her $200 for me to take her there, and that he Q. Did L.M. ever ask Melissa to go? 2 wanted young girls, as she was such; with no tattoos, as '1 A. I don't know. 3 . she was such; to massage, give him a massage, take off Q. Did any other of your friends ask Melissa to 4 your clothes, and then i would leave the room. And go to Mr. Epstein's home? 5 whenever i went when I was taken there and whoever A. i don?t know. 6 was taken there by left the room, he would you know, Q. Was Melissa the same age as you were? 7 want me to either get leave my bottoms on or get A. No. 8 fuily naked, and he wouid want me to stand on the side Q. Older or younger? 9 of him as he touched my breasts. He wanted me to touch A. Younger. 1.0 his nipples, lick his nipples, you know, various things. Q. When you told when you asked Melissa if she 1 1 As he grabbed my butt, as he grabbed my breasts, as he would go, you had already been. to Mr. Bpstein's house, 1 2 touched my vagina, you know, and as he ejaculated, was correct? 1 3 doing those things. A. Correct. 1 4 Q. All right. And you told Melissa this? Q. . Okay. How many times had you been to 5 A. Yeah. . Mr. Epstein's house when you asked Melissa to go? 1 6 Q. And when you said, do you want to come to his A. I would say over ?ve to ten times, somewhere 17 house, do you want to go to his house in between there. 18 A. Would you iike to go to his house to make Q. And were 1 9 $200. A. It varies. I don?t know. 20 Q. And she said? Q. Was Melissa aware that you were going there? 2 1 No, he's a pedophile. A. Yes. 22 Q. And what did you say to that? Q. And did she ever ask you what happened at 2 3 A. Okay, I understand. Mr. Epstein's home? 24 Q. All right. And did you did you think that A. Yes. 25 Mr. Epstein did you think he had problems? Well, let Page 115 Page: 117 Q. Okay. And did you tell her? 1 me ask it this way. A. Yes. 2 A. Yeah. . Q. And what was her what did you tell her 3 Q. Did you know what Mr. Epstein was doing at the happened those five or ten times? 4 time? That is, the ?rst time that you went, did you A. Itold her that I -- 5 perceive and think this is wrong? Q. Before let me -- let me just withdraw that A. or course. - . question. 7 Q. All right. And so every time that you went to Before 8 Mr. Epstein's house item the ?rst time A. You're not done? 9 A. I was aware. Q. Before you asked Melissa to go to 10 Q. you were aware that what from your 3} Mr. Epstein?s home, if i understand it correctly, you 1 1 opinion, that what he was doing was inappropriate and may have been at Mr. Epstein's home five, ten times; is 2 wrong? that correct? 3. 3 A. Correct. A. To the best of my knowiedge. 3t 4 Q. Okay. And did you understand that that is, Q. All right. And you would tell Melissa what 15 you understood that, your mind understood that? You went on at Mr. Epstein's home? 1 6 know it but you still voluntarily returned each time? A. Yes. 17 A. I was homeless. - o. Okay. 18 MR. EDWARDS: Form. A. When I asked her to go, i told her it's you 1 9 THE WITNESS: was homeless when I went to know, pretty plain and obvious that I wouid tell her 2 0 his house, okay? Do you understand? Have you ever why. . 21 been homeless? I?m sorry; i'm sorry. l?ll Q. And did you when you told her what had gone 22 withdraw that question because i know I'm not the It at Mr. Epstein's home and you asked her if she wanted 23 one asking the questions here. I was homeless. I 0 go, what did you tell her? 2 4 was a young child, okay? When I went to his A. ltoid her that, you know, he would pay me 2 5 yes, I knew it was wrong. Yes, I knew he wears, - - . .. 1 2?0: 'ij? - Ik- 30 (Pages lldgidf Page 255 Page 257 home? 1 Q. So she was acting as a pimp for you? I just went through -- I called Yellow Cab and 2 MR. EDWARDS: Form. - had Yellow Cab pick me up and then I had Yellow Cab 3 THE WITNESS: Right. me to her house, pick her up, and then we went to 4 - BY MR. CRITTON: ffrey's, and Jeffrey paid for it. 5 (3. True? ,How many peopie had you taken to Mr. Epstein?s 6 A. True. .. prior to Jane Doc 6? 7 Q. Because she made money off taking you there? mean, the least, like i said earlier, 20 to 8 A. Correct. iris at at least. 9 Q. Okay. Did you consider yourself a prostitute? 1- :How many girls did you take after Sane Doc 6? 1 0 Have on ever considered yourself to he a prostitute? . I?m sorry, repeat that ?rst question. 1 1 A. With Jeffrey Epstein, yes. . My ?rst question was, is: How many'femaies 2 Q. With anyone else? i you taken to Mr. Epstein?s house prior to Jane you considered yourself to be a prostitute Oh, I thought you meant altogether. I I 5 with Mr. Epstein and you knew what you were doing i don?t know how many people I?ve taken 3 6 A. Was wrong. re" Jane Doc 6. 3. 7 Q. was ?dong? Do you know how many females you took after 1 8 A. Yes. Jane'Doe you participated, and I know your view, 1,21 could tell you aitogether it was about 20 to 2 0 but you participated in whatever wrong?? activity was T"'feniales at the least i took to his house. 2 occurring at the same time, true? .I --:Did you consider yourself to be a pimp? 22 A. True, as a iS?year?oldjuveniie, true, . 'No. 2 3 14?year?old, 15-year-old juvenile, true. EDWARDS: Form. 2 4 Q. Let me ask you about Jane Doe. How many of 25 Jane Doe's well, iet me strike that. Page 256 Page 258 II MR. CRITFON: . 1 When you knew Jane Doe, before she went to . Why not? You were -- you were taking females 2 Mr. Epstein's, were you m- were you aware of well, I . Epstein?s house for them giving themselves 3 think you said you were aware that she wouid smoke pot, iing' their body for sexual activity for hire, true? 4 she would drink with you, true? I MR. EDWARDS: Form. 5 A. True. THE WITNESS: Yeah, true, but Ijust never 6 Q. Were you aware of boyfriends that she had coked at myself as a pimp or anything like that. 7 before she went to Mr. Epstein's home; that is, what her .hOIrestiy honestly had a conscience about what 8 reiationship history was? was doing. i wasn?t proud of it by any means. 9 A. No, I really didn?t know much about her other BY-MR. CRITTON: 1 0 than she was Melissa's friend. Well, but you you know what a pimp is, 1 3. Q. And you you said you had met Batu .u't you? 1 2 (phonetic), correct? 3A. Yes. 1 3 A. Correct. And you knew what a pimp was at the time, 1 4 Q. When did you say the last time was that you de?ect? 1 5 Spoke with iane Doe? I'm not I can't answer that honestly. I 6 A. When she had her baby. not have known what a pimp was at that time. 1 7 Q. Do you know what year that was? . Looking back, do you understand that you were 1 8 A. No, I don't. ng as a pimpsuggest it was in '08, would that z; MR. EDWARDS: Form. 2 0 meet with your recollection? THE WITNESS: I sure, you know. 2 A. i was going to say somewhere around there. MR CRITTON -2 2 Q. Did you ever tell Jane Doe that you had ?led And L.M., when she took you, she received 2 3 a iawsuit against Mr. Epstein? . easy for taking you? 2 4 A. Yes, i did. Okay. 2 5 Q. And how did how did the subj ectcorne up 17 (?ages 255 to 258) 832~7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 signed by Joana Ricciuti (601 480-428-9381) 3' by Joana Ricciuti (601-280-428-9381) teal) 832?7500 A. Yes. ailenicarty signed by Joana Ricciutl (601-286-428?9381) mitotiically signed by Joana PROSE COURT REPORTING AGENCY, i>age 203 . Page 205 Q. Did she and did she ever tell you that 1 Q. In what way? Mr. Epstein had ever used any physical force directed to 2 A: There was times where he's put -- inserted his her in any way? 3 ?ngers in my vagina and I didn't want him to. After it A. No. 4 was done and I tried pulling awayfact, Mr. Epstein never used any 5 release his ?ngers from my vagina. So that's being a physical force or coercion to you, did he? 6 little bit physical with somebody. MR. EDWARDS: Form. 7 Q. Let me ask you this: When LM. told you that THE MINESS: Other than masturbating in front. 8 she had been going to Mr. Epstein?s house, what did she of me and, you know, totally taking advantage of my 9 tell you? I mean, other she told you that you could home living situation and my whole situation in 0 make $200 if you go to his house, or if you bring general, my innocence and everything else. i mean, 1 1 another girl you could make $280, correct? if you don't call that taking advantage of me 1 2 A. Yes. LM. really wasn't up hunt with me. physically, I don't know what wha what you 1 3 She didn't tell me that he was going to masturbate in do call taking advantage of somebody physically. 1 4 front of me. She told me it was a massage for $200, and MR. CRITTON: Move to strike as 5 basically that you did have to you could get . non~re5ponsive 1 6 undressed or you didn't have to get undressed and BY MR. CRITTON: massage him for $200. Q. Let me ask you this question: Did Mr. Epstein 1 8 Q. Prior to the time that well, let the strike ever physically threaten you at any time? 3. 9 that. MR. EDWARDS: Form. 2 0 When LM. told you about Mr. Epstein, did she "fl-IE As in, what, like put his hands 2 1 ask you if you wanted Excuse me? BY MR. CRITTON: 2 3 Q. When LM. told you about Mr. Epstein, did she I Q. No, physically threaten you. 2 4 tell you or ask you if you wanted to go? MR. EDWARDS: Penn. 2 5 A. Not right away, no. Page 204 Page 206 THE WITNESS: Like, l?m going to hurt you? 1 Q. She just told you about him? BY MR. CRITTON: . 2 A. Yes. Q. Yes, ma?am. 3 Q. At some point, did she ask you if you wanted A. No, he never said he was going to hurt me. 4 to go? Q. He was never violent with you, was he? 5 A. Yes. MR. EDWARDS: Form. 6 Q. And did you say, sure? THE WITNESS: I guess -- what do you consider 1' A. Yes, after she told me that all i would have violent so I can answer this 8 to do is massage him and I didn?t have to take my BY MR. 9 clothes off, I had the choice to take my clothes if Q. Physically violent with you. it 0 I -- I didn't have to, and you know that yeah, he had MR. EDWARDS: Form. 1 3. a great mansion and he had a chef and we could go there THE WITNESS: Physically violent, as in I'm 1 2 and, you know, get food cooked for us and hang out in a going to hurt you, basically? 1 3 wonderful house and get paid $200 for just giving BY MR. CRITTON: 1 4 somebody a massage, you know, yeah. Q. Yes, ma?am. 3. 5 Q. Had you ever -- had you ever given someone a i A. No, he never said he was going to hurt me. 1 6 massage before? Q. You never felt threatened by Mr. Epstein, did 1 7 A. No. you? it 8 Q. Did -- did you tell her that you had'never A. Yes. By his authority, de?nitely. 1 9 givenanyone a massage, her meaning Q. Did you feel physically did you feel you 20 A. Well, no, I never no, I didn't say L.M., I f- say th eatened by his authority, was that every time you 2 1 never gave anybody a massage, no. . were there? 2 2 Q. So basically, she A. Of course. 2 3 A. I mean, besides -- I mean, actually me and Q. Did he ever try to restrain you in any way? 2 4 LM. would, like, massage each other, but we were 1 girlfr' you know. So no, never laid out a 4 (Pages 203 to 206) INC. (561)- 832*7506 931 7a9f6-1 Page 215? 1 A. Sure. 2 Q. And she told you that you didn't have to get I 3 naked if you didn't want to, true? i 4 A. Truethe home the first time. What 6 happens nextget there, we enter through 8 the door. We go through another door, and now we?re in 9 his kitchen. We go through another door that looked 10 like it would be a closet. We walked mm which is 11 actually a stairwell. We walk up the winding stairwell. 12 We open up the door, and now we?re in, it looks like a 13 hallway. We enter w? we have to am we go to the right, 2 14 we open up another door, which leads into another door. 15 We open up that door, and now we're in his bedroom. 16 We walk around his bed, which would be curving 17 to the left. We open up a door, and now we're in his 18 bathroom. She opens up a closest, shows me where the 19 massage table is. She tells me, okay, help me pretty 20 much set up the massage table. We get the massage 21 table, she shows me where all the lotions are, all Bath 22 Body Works lotions. She asked me to pick out a 23 lotion, whichever ones I want, whatever one I want, set 24 it on the table, make sure that my jewelry was off my 25 hands, and then we had to sit on the couch and wait for (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeans Ricciuti (601 ~280428~9381) Mama? (561) 832*7500 Page 216 him to come in. And he comes in, I introduce myself to him and he takes off his robe and is completely nude underneath his robe. He lays on the mm on the table, he puts like a towel like where his butt would be so he's not completely nude. He has a towel over his butt, and we give him a massage for about 30 to 45 minutes as he's talking on the phone, and it seems what seemed to me like he was handling business. Q. Let me stop you there for a minute. Can you give me a date that you went the first time? A. No. An approximate date? A. August of 2002. And what makes you believe it's August of 2002? A. Because I know it was like kind of right before the ninth grade ninth grade, you know, going into the ninth grade. Q. Were you living with L.M. at the time? A. Yes. Q. Was dad aware she had been going over there? A. No. Q. Did L.M. tell you how far ?w many times she Electronically signed by Jeana Ricciuti (601-280-428~9381) Electronically signed by Jeana Ricciuti (601-280428-9381) arrest}. $153431 We 36.13%: mac :3 i2?: mm 9-5 353331-53 3&33MM-vk5 W'rwwq?ww?w PROBE COURT REPORTING AGENCY, INC. (561) 832?7506 i ii 931 DEFENDANT BRADLEY J. EDWARDS ?8 STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards, et a1. Case No. 50 2009 CA 040800MMBAG ATTACHMENT 3 'Page 1 UNITED STATES DISTRICT COURT I SOUTHERN CASE AB Plaintiff, . . VOLUME I OF 11 JEFFREY EPSTEIN, Defendant. VIDEOWCONFERENCED AND VIDEOTAPED.DEPOSITION OF L.M. Thursday,.September 24, 2009 - - 3 9:40 5:52 p.m. - I .250 Austr?lian_Avonue South Suite 115 West Palm Beach, Florida 33401 Reported By: Hopkins, RPR, FPR Notary Public, State of Florida_ Prose Court Reporting . {5832*7500 PROBE COURT REPORTING (561) Page 73 5 THE WITNESS: What did I do to Jeffrey and what did Jeffrey do to me? I went up there multiple times. I can't count. And I would be on a massage table massaging his legs. He would turn 2 over. His penis would be hanging out. He would put a vagina or a vibrator to my vagina. He would rm?: touch my vagina with his fingers. He would touch I my breasts. He.would try to kiss my mouth. He would bring my hands towards his penis. He would ask the little girls that I was with, hey, can I just see your vagina, can I just see it, even if they would say no. Can I, oh, I know, but let me just see it. Let me just see it. Sick mother fucker. I would like him in this room. .qtaisyxsasgss LUTTIER: Q. Any sexual act that you performed with Jeff? A. Is that not a sexual act when you put a i. . :ibrator to your wife's pussy; is that not a sexual act? . .. Q. Any act that you'performed with Mr. Epstein I . ?hat you haven't described thus far? an?: . .. Let me see. I went there multiple times. :h?re was multiple things that I have done with Jeffrey ldnJeffrey has done with me. ulfQ. ?My question stands. Did you perform any act T. - i- 1.4. rid-5.03 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 -with Mr. Epstein other than what you have described thus far? A. Besides standing there with my legs wide open and his little fetish with me pinching his nipples he Ihis probably getting hard right now with my little ?l2wyearwold girlfriend standing next to me, both naked, eno, I can't think of any other sexual acts I have done I and did you say that you went there lmultiple times? A. Yeah. Q. How many times would you say you went? A. More than, more than 50 times. Q. Did you keep a record of the number of times _you went? A. Unfortunately I didn?t. And were there occasions when you contacted Q. either Mr. Epstein or people on his behalf asking that you be allowed to come over? A. They would call me most of the time, but, yes, ifhere was multiple times I would call them. Q. And for, and who did you call? A. I called the house phone, 655~7273. I don't . There was multiple house_numbers. I would talk 0 Sarah. I would talk to the one mm Page 74 1 imam'awmaa a. w