1
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO. 50-2008-CA-028051 XXXX MB AB
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
/
VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN
TAKEN ON BEHALF OF THE PLAINTIFF
DATE: February 17, 2010
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1 February 17, 2010 1 THEREUPON,
2 INDEX 2 JEFFREY EPSTEIN
3 WITNESS DIRECTCROSS REDIRECT RECROSS
4 JEFFREY EPSTEIN 3 being by Toni Becker first duly sworn to tell
5 BY MR. EDWARDS 4 4 the whole truth, as hereinafter certified.
6 testified as follows:
EXHIBITS
7 FOR IDENTIFICA PAGE 6 DIRECT EXAMINATION
8 I Jane Doe numb usJeffrey 7 BY MR. EDWARDS:
Epstein complain 35
9 8 Q Can you give us your name.
2 Document, Nonprosecution Agreement 135 9 A Jeffrey Epstein.
10 10 Q Mr. Epstein, you made a comment when you
11
CER1iFILO QUESTIONS 11 came in the room that you were appreciative of me
12 12 being respectful to your housekeeper yesterday
Page Line 13 and I intend for that to be the same with you
13
61 22 14 today.
14 123 20 15 1 want to start by asking you, at this
146 l4 16 point we've gone through a lot of discovery in
15 148
153 5 17 this ease. There aren't may disputed facts as
16 159 13 18 to what actually happened at your house.
162 3
17 19 Generally I think you would agree that you
18 20 derived a way for young females to come to your
19 21 house and engage In varying degrees of sexual
20
21 22 activity, some of the girls as young as 12, some
22 23 of them as old as seventeen or so, most in
23 24 between, but as of yet you haven't provided an
24
25 25 explanation.
3
1 The videotaped deposition of JEFFREY 1 1 want to provide you an opportunity to
2 EPSTEIN in the above-entitled and numbered cause, 2 tell the jury at this time why you did ft.
3 was taken before me, TERRI BECKER, a Registered
4 Professional Reporter and Notary Public for the 3 MR. PIKE: I'm going to object
5 State of Florida at Liege, at 444 West Railroad 4 Confusing, compound and irrelevant, as
6 Avenue, in the City of West Palm Beach, Palm worded.
7 Beach County, in the State ofFlorida, beginning
8 at the hour of 5 eiclock a.m, pursuant to 6 A You know, I would 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 file 8 attorneys have told me that I can't and 1 must
11 herein, on behalf of the PLAINTIFF in the
12 above-entitled action pending in the above-named 9 invoke my Fifth, Sixth and Fourteenth Amendment
13 court 10 rights or I risk losing their counsel.
14 The appearances at said time and place 11 Accordingly, I therefore assert those rights.
15 were as follows:
16 12 Sorry.
FARMER, JAFFE, WEISSING,
EDWARDS, F1STOS & LEHRMAN, P.L. 13 MR. PIKE: In addition to that I'll move
17 Attorneys for Plaintiff 14 to strike counsel's statement as a
425 North Andrews Avenue, Suite 2 15 narrative, as well.
18 Fort 33301
Tel: 16 MR. EDWARDS: I understand. I wanted to
19 BY: BRAD . WARDS 17 provide him an opportunity, if today was
STEVEN R. JAFFE, ESQ. 18 going to be the day.
20
BURMAN, CRITTON, LUTTIER & COLEMAN 19 MR. PIKE: Same thing, move to strike.
21 Attorneys for Defendant 20 Q Mr. Epstein, how long have you been
303 Banyan Boulevard, Suite 400 21 sexually attractive to underage minor females?
22 Wes orida 33401
Tel: 22 MR. PIKE: Objection, harassing,
23 BY: MICHAEL PIKE, ESQ. 23 argumentative.
24 ALSO PRESENT: 24 A Are you kidding?
JOE ROVNER, Videographer
25 (U.S Legal Support) 25 Q No, l mean, I don't feel Eke I'm
2 (Pages 2 to
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1 divulging any secrets here, right? 1 argumentative, compound, harassing and
2 MR. PIKE: Move to strike. 2 irrelevant.
3 Q That's the question that's pending. 3 Q 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 I have to follow my attorneys' advice. They have 6 Amendment, Fourteenth Amendment right as advised
7 told me I must invoke my Fifth, 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 Q 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
11 those rights and under the constitution 11 psychologist or other medical professional?
12 guaranteed by the Fifth and Sixth, and Fourteenth 12 A I intend to respond to all of your
13 amendment. 13 questions at some relevant time; however, today
14 Q Would you consider yourself addicted to 14 at the present time, my attorneys have counseled
15 sex with minor females? 15 me that I cannot provide answers to any questions
16 MR. PIKE: Same objections. 16 relevant to this lawsuit and I must accept their
17 A You know, Mr. Edwards, again, I want to 17 advice or risk losing my Sixth Amendment rights
18 be very respectful. As the current U.S. Attorney 18 to effective representation.
19 has described your law firm as a criminal 19 Accordingly, I assert my Fifth,
20 enterprise and part of one of the largest frauds 20 Federal — Fifth and Sixth and Fourteenth
21 in Florida's history, it has been reported that 21 Amendment rights, to the United States
22 your firm has fabricated multiple cases against 22 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
25 unfortunately at this time, although I would Ida 25 matters, Mr. Epstein's medical history is
7 9
1 to answer that question, on advice of counsel I 1 not relevant at this time nor has he placed
2 will have to refrain and assert my Fifth, Sixth 2 same at issue in this case.
3 and Fourteenth Amendment right. 3 MR. EDWARDS: Understood.
4 Q Can you then provide an explanation for 4 Q 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- 6 A Again?
7 When she was a minor? 7 Q 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
11 respect, it was not my idea for him to give 11 at this time; however, my attorneys have
12 this speech about a former ARA law firm I 12 counseled me that I cannot provide answers to the
13 was asking to elaborate on that. 13 questions relevant to this lawsuit today. I must
14 MR. PIKE: Counsel, I'm working with 14 accept their advice or risk losing my Sixth
15 your follow-up question. 15 Amendment right to effective representation.
16 MR. EDWARDS: I understand. 16 Accordingly then, I assert my Fifth, Sixth and
17 MR. PIKE: I'm objecting, object to the 17 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 Q Isn't it true that you have engaged in
20 based upon your question. 20 some sexual interaction with hundreds of underage
21 MR. EDWARDS: Will he elaborate on the 21 minor females In die last ten years of your
22 relevance of that soliloquy to his touching 22 life? Is that true?
23 -when she was 13, 14 and 15 years old in 23 MR. PIKE: Objection, relevance.
24 a sexual manna? 24 A Mr. Edwards, the current U.S. Attorney
25 MR. PIKE: I'm going to object again, 25 has described your law firm as a criminal
3 (Pages 6 to 9)
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1 enterprise and pan of the largest fraud in 1 50 years old?
2 Florida's history. It has been reported that 2 MR. PIKE: I'm going to object once
3 your firm fabricated multiple cases, many, many 3 again. We are getting way too argumentative
4 multiple cases against me in order to fleece 4 with the questioning. The questioning is
5 unsuspecting investors out ofmillions and 5 compound It is speculative and it is also
6 millions of dollars. Unfortunately, at this time 6 harassing. Whether or not this deposition
7 in response to your question, my attorneys have 7 video, thereofis played in front of a jury
8 advised me that I must assert my Sixth Amendment, 8 is a question of fact, and it will be
9 Fifth Amendment, Fourteenth Amendment right. 9 determined by a judge pursuant to a motion
10 Though, I believe, you know, that I would really 10 in limine, various portions thereof may or
11 like to answer your questions today, but at this 11 may not be played, so hiving placed those
12 moment i must assert those rights or risk having 12 objections on the record I'm going to
13 my attorneys resign. 13 insttuct Mr. Epstein not to answer that
14 Q You're Invoking your Fifth Amendment 14 question.
15 rights to each of these questions because you 15 MR. EDWARDS: Mr. Pftce, I don't know if
16 know your answers will incriminate you and you 16 you watehegainia hours of harassing
17 feel it will result in you being prosecuted for 17 questions tri=that she sometimes
18 your crimes; Isn't that right? 18 invoked her Fifth Amendment rights, I
19 MR. PIKE: Objection, argumentative, 19 understand the adverse advice that would be
20 harassing. Calls fora legal conclusion. 20 given and she was made to answer these
21 Q You can answer. 21 questions and these exact same questions
22 A No, in fact, the Supreme Court recently 22 were asked ofher, in fact, I'm using the
23 said the Fifth Amendment right is there to 23 phraseology from Mr. Luttier. I'm not
24 protect the innocent, so, that's the way I would 24 trying to harass him.
25 like to answer that. 25 Q I'm simply asking him to explain to the
11 13
1 Q Are you actually telling 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, explain 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 be respectful to the to the court
7 harassing. 7 reporter rather than having a diatribe back
8 A I would like to respond to that 8 and forth between you and myself, I'll move
9 question, as you know, however, at the present 9 to strike your last statement as
10 time my attorneys have counseled me that I cannot 10 irrelevant. Let's move on.
11 provide answers to any questions relevant to this 11 Q Is it true, Mr. Epstein, you were born
12 lawsuit and i must accept their advice or risk 12 January 20,1953?
13 losing my Sixth Amendment right to effective 13 A Yes.
14 representation. Accordingly, I assert my Fifth, 14 Q Where?
15 Sixth and Fourteenth Amendment right under the 15 A New York.
16 United States Constitution. 16 Q Where in New York?
17 Q Mr. Epstein, you understand that this is 17 A Brooklyn.
19 aeo that will be playe ie Jury in 18 Q Did you go to high school there?
19 trial against you 1m wants answers. 19 A Yes, sir.
20 The jury is going to want answers, so I know that 20 Q Where?
21 you're telling us that you're going to respond at 21 A Lafayette High School.
22 some time In the future; but the time is now. 22 Q After high school did you attend
23 Would you like this opportunity to explain why 23 college?
24 you engaged In sexual activity with.. 24 A Yes.
25 beginning when she was 13 years old and you were 25 Q Where was that?
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1 A New York. 1 I'll restate the answer. I would like to
2 Q 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 Q Sorry, i didn't hear. 4 has advised me I must take the Fifth, Sixth and
5 A Cooper Union. 5 Fourteenth Amendment right under the U.S.
6 Q Did you get a degree from Cooper Union? 6 Constitution.
7 A No, sir. 7 Q After college where were you employed?
8 Q How many years were you in college? 8 A You Imow, I would like to respond to all
9 A I believe, two. 9 your questions today, however, on advice of
10 Q What did you study? 10 counsel, I intend to take the Fifth, Sixth and
11 A Physics. 11 Fourteenth Amendment rights provided by the
12 Q Why did you leave college early? 12 United States Constitution or risk losing my
13 A I intend to respond to all relevant 13 counsel's representation.
14 questions regarding this lawsuit, however, at the 14 Q Isn't it true that you were a teacher at
15 present time my attorneys have counseled me that 15 the Dalton School in New York after college?
16 I cannot provide answers to questions that may be 16 A Again, I would like to respond to all
17 relevant to this lawsuit, so accordingly I assert 17 your questions; however, my attorneys have
18 my constitutional rights as guaranteed by the 18 counseled me that i cannot provide answers to any
19 Fifth, Sixth and Fourteenth Amendment. 19 questions today regarding to this lawsuit so I
20 Q Are you invoking your Fifth Amendment 20 must accept their advice or risk losing my Sixth
21 rights as to why you left college, Is it safe 21 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: I'm going to move to strike, 24 Amendment of the constitution.
25 speculative, argumentative, harassing. 25 Q Mr. Eistein, didrit have sex with any
15 17
Calls for a legal conclusion, and 1know 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 4 Q 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 I'm going to instruct him not to answer that 7 A Mr. Edwards, your firm has been
8 question, based upon his Fifth, Sixth and 8 described by the U.S. Attorney as one of the
9 Fourteenth Amendment rights to the United 9 largest — as a criminal enterprise, perpetrating
10 States Constitution. 10 one of the largest frauds in Florida's history.
13. MR. EDWARDS: With all due respect you 11 It has been reported that your firm fabricated
12 cannot invoke his Fifth Amendment rights, 12 multiple cases against me and others in order to
13 your attorneys instructed me in that fact -- 13 fleece unsuspecting investors out of millions and
14 MR. PIKE: lie can. 14 millions of dollars.
15 MR. EDWARDS: 11M. 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
17 Mr. Epstein. 17 must assert my Fifth Amendment, Sixth Amendment
18 Q Can we assume you're Invoking your Fifth 18 and Fourteenth Amendment rights, though I believe
19 Amendment rights as to why you left college 19 you know I would like -- really like to answer
20 early, that that answer you feel would 20 your questions but at this time I must assert
21 incriminate you? 21 those rights or have my attorneys resign.
22 MR. PIKE: Once again, move to strike 22 MR. EDWARDS: Mr. Pike, I think you know
23 for the same reasons. 23 he has a couple of options here. He can
24 You can answer. 24 answer questions or he can invoke his Fifth
25 A I've already answered the question. 25 Amendment rights. This nonresponsive
5 (Pages 14 to 17)
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1 verbiage regarding the RBA law firm 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 the deposition and I would ask you to 3 Fourteenth Amendment constitutional rights
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
7 finish, but obviously this is going to be 7 adverse inference presumptions.
8 the subject matter of some motion in the 8 MR. EDWARDS: I don't want the adverse
9 °Duns 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 10 I don't want the adverse inferences.
11 this process along by eliminating that 11 MR. PIKE: Having said that, please
12 portion ofhis answer. I understand what he 12 allow the witness to answer to answer the
13 is saying. 'get it, but that's not 13 question.
14 something responsive to any of the questions 14 A Can you please repeat the question?
15 and I think you know it is inappropriate. 15 Q Isn't it true while working at Bear
16 MR. PIKE: I think the deponent is 16 Stearns you were already engaging in sex with
17 answering the questions. If you believe the 17 underage minor females?
18 responses are inappropriate and feel you can 18 A As your firm has been described by the
19 take it up with the Court with the motion 19 U.S. Attorney, as a criminal enterprise, using
20 you are speaking of, as you've done then you 20 some of the cases fabricated against me,
21 can, as you've done several times before. 21 personally, I would like to answer that question
22 Q After leaving the Dalton School. is it 22 today; however, upon advice of counsel I must
23 true that you began working as a money manager at 23 assert my Fifth, Sixth and Fourteenth Amendment
24 Bear Stearns? 24 rights under the U.S. Constitution or, in fact,
25 A I intend to respond to all your 25 risk losing their representation.
19 21
1 questions regarding this lawsuit at some relevant 1 Q At some point in time while 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 fellow named Leslie Wexler, correct?
4 to any questions relevant to this lawsuit. Since 4 A Again, I would like to answer all
5 the U.S. Attorney has described your law firm as 5 questions relevant to this lawsuit, but today I
6 a criminal enterprise, Mr. Edward; and a pan of 6 must assert my Fifth Amendment, Sixth Amendment
7 the largest fraud in Florida's history, I am 7 and Fourteenth Amendment right to the U.S.
8 going to assert my Sixth Amendment, Fifth 8 Constitution.
9 Amendment and Fourteenth Amendment rights to the 9 Q In fact, I read in another deposition of
10 U.S. Constitution. 10 yours that you do not consider yourself to be
11 Q Isn't It true that while you were 11 homosexual, correct?
12 working at Bear Stearns you were already engaging 12 A (No response.)
13 in sex with underage minors? 13 Q You've answered that question before,
14 A Again, I believe you know the answers to 14 correct?
15 those questions, but -- 15 A Correct.
16 Q Yes. 16 Q Do you consider yourself to be
17 A May I finish? 17 bisexual?
18 Q I do. 18 A No.
19 MR. PIKE: Move to strike. Let the 19 Q In any event, you did develop a sexual
20 witness -- 20 relationship with Leslie Wexler at some point In
21 Q Sure - 21 time; Is that true?
22 MR. PIKE: Let the witness answer your 22 A No.
23 question. 23 Q Did you have a business relationship
24 MR. EDWARDS: I would love for him to 24 with Mr. Wexler?
25 finish the questions. 25 A I intend to respond to all relevant
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1 questions. I would like to answer most of your 1 Therefore l'Ilassert my Constitutional
2 questions, Mr. Edwards, today, however, 2 rights under the Fifth, Sixth and Fourteenth
3 especially since your firm has been described by 3 Amendment.
4 the United States Attorney in South Florida as a 4 THE WITNESS: Excuse me, could we take a
5 criminal enterprise purported to -- purported to 5 break?
6 have put — pulled off the largest fraud in 6 MR. EDWARDS: Already?
7 Florida's history, I would like to answer it, 7 THE WITNESS: Restroom.
8 however, my attorneys here today counseled me 1 8 THE VIDEOGRAPHER: Going off the video
9 must assert my Fifth, Sixth and Fourteenth 9 record 11:38 a.m.
10 Amendment right under the U.S. Constitution, 10 THE WITNESS: Thank you.
11 therefore Pm going to do that. 11 (Pause in the proceedings.)
12 Q Are you saying because Rothstein, 12 THE VIDEOGRAPHER: We're back on the
13 Rosenfeld, Adler was determined to be a criminal 13 video record at 11:48 a.m.
14 enterprise or somebody was running a criminal 14 Q How did you meet Chislalne Maxwell?
15 enterprise out of that law firm, that is the 15 A I intend to respond to all relevant
16 reason why you are not going to answer these 16 questions to this lawsuit; however, at the
17 questions today? You linked that together in 17 present time my attorneys have counseled me that
18 that answer. I just want to make sure I'm 18 I cannot provide answers to any questions
19 understanding that right? 19 relevant to this lawsuit, and must accept this
20 A I'm going to take the Fifth I intend 20 advice or risk losing effective -- my right to
21 to respond to all relevant questions today. I 21 effective representation. Accordingly,
22 would like to respond; unfortunately my attorneys 22 therefore, I assert my Fifth, Sixth and
23 have counseled me I can't, l must assert my 23 Fourteenth Amendment rights to the U.S.
24 Fifth, Sixth and Fourteenth Amendment rights 24 Constitution.
25 under the U.S. Constitution. 25 Q You would agree, would you not, that
23 25
Q Because other law firms have asked very 1 Ghislaine Maxwell shares your sexual obsession
2 similar questions and you haven't responded to 2 for underage minor females?
3 any of theirs either. I just want to understand 3 MR. PIKE: Argumentative, speculation,
4 what the relationship between Rothstein, 4 harassing.
5 Rosenfeld, Adler is to you invoking your Fifth 5 A You know, Mr. Edwards, the current U.S.
6 Amendment rights today, if you can articulate 6 Attorney has described your law firm as a
7 that for me. 7 crininal enterprise, and as taking part in one of
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
10 A ROCIISICill, Rosenfeld, Adler has been 10 multiple cases of a sexual nature against
11 described by the U.S. Attorney as a criminal 11 people — other people and me, in order to fleece
12 enterprise and as part of the largest fraud in 12 unsuspecting investors out of millions of
13 Florida's history. It has been reported that 13 dollars, so unfortunately at this time in
14 your faro fabricated multiple cases using me, and 14 response to your questions, my attorneys have
15 against me in order to fleece unsuspecting 15 advised mei must assert my Sixth Amendment,
16 investors out of millions of dollars. 16 Fifth Amendment and Fourteenth Amendment rights,
17 Q Another long time friend of yours is 17 though 1 believe, as you know, I would really
18 Gliblaine Maxwell, right? 18 like to answer these questions, but at this
19 A I intend to respond to all relevant 19 moment, although at this time I have to assert
20 questions. I would like to answer most of these 20 those rights or risk losing effective counsel.
21 questions today, but I can't because my attorneys 21 Q Do you know
22 have counseled me that I cannot provide answers 22 A I intend to respond to all relevant
23 to any questions relevant to this lawsuit. I 23 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
25 Amendment right to effective representation. 25 cannot provide answers to any questions relevant
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1 to this lawsuit. Your finn 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 sexual 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, I'm 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
right. 8 Fifth, Sixth and Fourteenth Amendment right under
9 Q Did you and Ghis sexually 9 the U.S. Constitution.
10 assault at 'a house? 10 Q Do you own a home in New Mexico?
11 A i intend to respond to all relevant 11 A i intend to respond to all relevant
12 questions regarding this lawsuit; however, at the 12 questions regarding this lawsuit and as I've had
13 present time my attorneys have counseled me I 13 to do with most of your questions here today, I'm
14 cannot provide answers to any questions relevant 14 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
16 risk losing my Sixth Amendment rights to 16 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 Fifth, 18 Q Is it true that you have had underage
19 Sixth and Fourteenth amendments to the U.S. 19 females, at each of those homes, for orgies with
20 Constitution. 20 you and Ghislaine Maxwell?
21 Q Stating Ghlslalne 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. PIKE: Form, argumentative, 24 really would. However, as your firm has been
25 harassing? 25 described by the U.S. Attorney as a criminal
27 29
1 A Mr. Edwards, your firm has fabricated 1 enterprise, which its principal 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 firm and its co-ccnspiritors through the
4 in order to be pan of what the U.S. Attorney has 4 operation of enterprise and through various
described as the largest fraud, the largest fraud 5 activities including mail fraud, wire fraud and
6 in Florida's history. I would like to answer all 6 money laundering, and fabricating multiple sex
7 your questions; however, my attorneys have 7 cases against me and others, though I would 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 courisel has advised me I must take the Fifth,
10 under the U.S. Constitution. 10 Sixth and Fourteenth Amendment right provided by
11 Q Do you own a home in Manhattan? 11 the U.S. Constitution.
12 A i intend to respond to all relevant 12 Q Do you know somebody named
13 questions to this lawsuit; however, at the 13 (phonetic)?
14 present time my attorneys have counseled me that 14 MR. PIKE: Can you spell that, for the
15 I cannot provide answers to any questions 15 record?
16 relevant to this lawsuit, and I must accept their 16 MR. EDWARDS: No.
17 advice or risk losing my Sixth Amendment right to 17 MR. PIKE: Or for the court reporter?
18 effective representation. 18 A No.
19 Accordingly, therefore, I have to assert 19 Q You don't know the name?
20 my Fifth, Sixth and Fourteenth Amendment right 20 A No. Could you spell it?
21 under the U.S. Constitution. 21 Q (Witness shrugs.)
22 Q Do you own an island in the V.S. Virgin 22 A Okay.
23 Islands? 23 Q Did your sexual obsession with underage
24 A !intend to respond to all relevant 24 minor females grow at some point in time to allow
25 questions regarding this lawsuit; however, at the 25 you access to these underage minors every single
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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 confusing as well; as worded. Do you want 4 Q Sure, let's test that answer.
5 to break it down, Mr. Edwards? 5 A Okay.
6 Q Isn't It true that for the past ten 6 Let's talk about Jane DoMJane Doe
7 years you have found a way to engage in sexual 7 who was represented bMI
8 conduct with underage minors on an every day a firm, had nothing to do with
9 bask? 9 Rothstein, Rosenfeld, Adler. Do you know
to MR. PIKE: Speculation. Argumentative. 10 A Who?
it A As your firm has been described as a 11
12 criminal enterprise by the United States Attorney 12 A Can you spelt it?
13 and is part of the scheme to defraud people in 13 Q Common spelling,
14 South Florida of millions of dollars, you have 10
15 fabricated sexual cases and sexual claims against 15 A Can you spell it forme, please?
16 people like me and others. Unfortunately at this 16
17 time although I would like to answer your 17 A What's the last name, how is it
18 questions, Mr. Edwards, my counsel has advised me 18 spelled?
19 I cannot They have advised me I must assert my 19 Q-Ibelieve.
20 Fifth, Sixth and Fourteenth Amendment rights 20 A I intend to respond to all relevant
21 under the U.S. Constitution. 21 questions regarding this lawsuit; however, at the
22 Q isn't it true that you ►ave promised 22 present time my attorneys have counseled me that
23 underage minors money or other benefits to engage 23 I cannot provide answers to any questions that
24 in sexual conduct with you over the past ten 24 may be relevant to this lawsuit and I must accept
25 years? 25 this advice or risk losing my Sixth Amendment
31 33
1 A Again, as I've answered many of your 1 right to effective representation. Accordingly,
2 questions today, and unfortunately will 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 firm 4 the Constitution.
5 bringing this lawsuit, I believe, if I'm wrong 5 Q Just for the record, I can only spell it
6 please, correct me -- 6 the way it was spelled in your flight logs from
7 Q You're wrong. 7 your airplane. I don't know exactly how she
8 A This is the firm that didn't notice this 8 spells her name, only how your pilot would spell
9 deposition? 9 her name.
10 Q Did not? 10 MR. PIKE: Form, speculating.
11 A Did not? 11 Q If I misspell it —
12 Q No. 12 MR. PIKE: Form, speculation,
13 A I apologize. Though your former firm 13 argumentative, harassing.
14 has been described, and the person you represent, 14 MR. EDWARDS: That's harassing?
15 L.M., in this case was represented by the firm 15 MR. PIKE: It assumes facts currently
16 that was described by the U.S. Attorney as 16 not in evidence in this particular
17 perpetrating one of the largest frauds in South 17 deposition; therefore, I move to strike.
18 Florida's history, fabricating multiple sexual 18 MR. EDWARDS: I was responding to his
19 cases against me and others in order to fleece 19 question asking me how to spell her name. I
20 unsuspecting investors out of millions and 20 don't know how other than his own pilot.
21. millions of dollars, so though unfortunately, I 21 MR. PIKE: Mr. Edwards, he asked you to
22 would like to answer each one of your questions 22 spell the name, you then spelled the name,
23 today, my counsel has advised me I must assert my 23 then went on with another narrative and
24 Sixth Amendment, Fourteenth Amendment and Fifth 24 there wasn't a question posed, on the floor.
25 Amendment right, though I believe you know, I 25 Q You would agree you Interacted with-
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1 every day in a sexual way, when she was 15 years 1 for a second?
2 old, right? 2 May I ask you a question?
3 A Again, I'm softy? 3 MR. PIKE: Sure. Can we take a break
4 Q Sure. You would agree that you 4 fora second?
5 Interacted with. 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 VIDEOGRAPHER: Off the video record
10 assert my Sixth Amendment, Fourteenth Amendment 10 12:01 p.m.
11 and Fifth Amendment rights provided by the U.S. 11 (Pause in the proceedings.)
12 Constitution and the fact that the current U.S. 12 THE VIDEOGRAPHER: We are back on the
13 Attorney has described your law finn as a 13 video record at 12:02 p.m.
14 criminal enterprise, is one of the largest frauds 14 Q Is it true, Mr. Epstein, that you and
15 in Florida's history for fabricating sexual -- 15 Ghislaine Maxwell forced■ to have sex with
16 cases of a sexual nature against me and others. 16 you on a daily basis?
17 Unfortunately, although I would like to answer 17 MR. PIKE: Form, argumentative,
18 those questions, if I do I risk losing my 18 harassing.
19 attorneys' counsel. Therefore, I must assert my 19 A Unfortunately at this time, though I
20 right. 20 would really like to answer those questions, and
21 MR. EDWARDS: Madam court reporter, Ill 21 like I have dent for most of your questions here
22 as an exhibit, the Jane Doe number 22 today, Mr. Edwards, your firm was described as a
23 crsus Jeffrey Epstein complaint, at 23 criminal enterprise, a serious criminal
24 some point in time. It will be Exhibit 1, 24 enterprise by the current U.S. Attorney. Part of
25 as Pm going to go through some of the facts 25 that criminal enterprise was fabricating cases of
35 37
1 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 plaja. 2 fleece unsuspecting investors out of millions of
3 (Jane Doe numberMversus 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 1 for identification, as of 5 questions, I must assert my Sixth Amendment,
6 this date.) 6 Fifth Amendment and Fourteenth Amendment rights
7 MR. PIKE: Counsel, do you have an extra 7 under the U.S. Constitution or risk having my
copy of that for me? 8 attorneys resign.
9 MR. EDWARDS: No. 9 Q Isn't it true thaMwas yours and
10 MR. PIKE: May I look at it real quick? 10 Ghlslaine Maxwell's sex slave front the time she
11 MR. EDWARDS: No. It has my notes on 11 was 15 through the time she escaped when she was
12 it. 12 19?
13 MR. PIKE: I understood, I saw the 13 MR. PIKE: Again objection,
14 highlights. 14 argumentative, harassing.
15 MR. EDWARDS: The notes are highlighted 15 A Mr. Edwards, your fimi has been
16 so when we copy it, it will not show up. 16 described as — excuse me, as a criminal
17 MR. PIKE: Just for the record, that's a 17 enterprise by the current U.S. Attorney and part
18 current, operative pleading, correct? 18 of the largest fraud in Florida's history. Part
19 MR. EDWARDS. Correct. 19 of that fraud was fabricating multiple cases
20 THE WITNESS: What does that mean? 20 against people like me and others, of a sexual
21 MR. PIKE: There may have been some 21 nature, in order to fleece unsuspecting investors
22 amendments to a complaint and I want to make 22 out of millions and millions of dollars, so
23 sure that's the operative complaint at issue 23 though I would like to answer that question, my
24 that he is speaking of today. 24 attorneys have told me today I must assert my
25 THE WITNESS: Can I go off the record 25 Sixth Amendment, Fourteenth Amendment and Fifth
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1 Amendment right. 1 the complaint filed byalagainst you, isn't it
2 Q Isn't it true that you and Chisialne 2 true, sir, that a friend of yours sent you three,
3 Maxwell celebrated her 16th birthday with her and 3 12-year old females for you to sexually abuse on
4 had sex with her on that day? 4 one of your birthdays?
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, I would like to answer that 7 THE WITNESS: Excuse me.
question. My attorneys have told me today, I A Vetere 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 10 Q Yes, I'll read It.
11 to the U.S. Constitution, especially my concern 11 "On one of the defendant Epstein's
12 is, that your firm has filed fraudulent lawsuits, 12 birthdays, a friend of defendant sent him
13 fabricated lawsuits, and the U.S. Attorney, the 13 2-year old girls fro ho spoke no
14 current U.S. Attorney has described your firm as 14 t for defendant to sexually exploit and
15 a criminal enterprise that — whose main purpose 15 abuse? After doing so they were sent back to
16 was to generate money for the finn and its 16 next day."
17 co-conspirators through the operation of various 17 sn't that true?
18 criminal activities, including mail fraud, wire 18 MR. PIKE: Once again, move to strike,
19 fraud and money laundering. 19 irrelevant, argumentative, harassing, and
20 m i tAre you saying that the complaint of 20 for the record, the exhibit that's being
21 gainst you, the allegation in that 21 read from is a complaint that's unrelated to
22 complaint, are fake? 22 the instant matter and not filed or
23 MR. PIKE: Form. Misinterprets the 23 incorporated by the current plaintil
24 witness's testimony. 24 in this matter.
25 Q Or saying k Is true? 25 A I would like to answer that question, I
39 41
1 MR. PIKE: Same objection. 1 really would; however, today my attorneys have
2 Q It is either true or false? 2 told me I have to assert my Fifth Amendment,
3 A I'll repeat myself, unfortunately, but 3 Sixth Amendment and Fourteenth Amendment rights
4 the current U.S. A has described your law 4 of the US. Constitution, especially because your
5 firm that filed that fil m—wm 5 firm involved in this lawsuit has fabricated,
6 involved in the filing o laim, 6 widely reported, multiple cases of sexual
7 motions — I'm softy, 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 U.S. Attorney
9 firm'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? 10 history, fleecing people out of millions of
11 Q Answer the question. 11 dollars, so though 1 would like to answer that
12 A All right. 12 question, today I have to assert those rights or
13 The U.S. Attorney has described that 13 risk losing my attorneys' counsel.
14 firm as a criminal enterprise perpetrating one of 14 Q Isn't it true that you Contd.as a
15 the largest frauds in Florida's history against 15 15-year old girl to have sex with numerous
16 unsuspecting investors, fleecing them out of 16 friends of yours?
17 millions of dollars by creating, crafting and 17 A Are you kidding?
18 fabricating fellacious (sic) sexual claims 18 Q Reading front a lawsuit.
19 against people like me and others, so 19 A Sorry. Mr. Edwards. Though I would like
20 unfortunately, though I would like to answer your 20 to answer that question as well, as I've answered
21 questions, Mr. Edwards, my counsel has advised me 21 most of your other questions here today, I would
22 that at least today I must assert my Sixth 22 like to respond; however, my attorneys here today
23 Amendment, Fifth Amendment and Fourteenth 23 have advised me I have to assert my Fifth
24 Amendment rights under the U.S. Constitution. 24 Amendment, Sixth Amendment and Fourteenth
25 Q Isn't It true, sir, and I'm reading from 25 Amendment rights under the U.S. Constitution,
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1 especially as your firm has been accused by the 1 spell his name? Are you acting like you don't
2 U.S. Attorney as being a criminal enterprise, and 2 know him?
3 part of the largest fraud in Florida's history. 3 MR. PIKE: Form, move to strike,
4 Basically -- sorry, if I didn't read correctly, 4 argumentative and irrelevant as worded.
5 um.... the operation of the enterprise through 5 Mr. Edwards, you know that there are
6 various criminal activities including mail (mud, 6 various standing orders, if not in this
7 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 Fifth Amendment. Federal Courts have
10 Q By the way — 10 ordered that certain questions that you are
11 A Yes, sir? 11 asking shall not be answered or Mr. Epstein
12 Q - didn'tM r trip 12 would risk losing his Fifth Amendment
13 ticket paid for by you toad she 13 right -
14 ultimately did not get back on the plane but le MR. EDWARDS: I understand that. He is
15 instead escaped t. 15 asking to spell people's names.
16 A I would like to answer that question, 16 MR. PIKE: -- under the United States
17 but today I would have to assert my Sixth 17 Constitution. A lot of these questions here
18 Amendment fights, my Fifth Amendment tights and 18 today that you're asking have already been
19 my Fourteenth Amendment rights under the U.S. 19 ruled on by various Courts, that the Fifth
20 Constitution, especially since your firm has been 20 Amendment protects any response thereto, so
21 described as perpetrating one of the largest 21 I would like -- Fm giving you some leeway
22 frauds in Florida's history, fleecing investors 22 here with regard to the argumentative
23 out of millions of dollars, being described by 23 questions. We've already -- and I'm not
24 the U.S. Attorney of South Florida, as a criminal 24 obviously testifying for the witness, but
25 enterprise engaged in various criminal activities 25 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
7 laundering. 2 deposition for being argumentative, and I
3 Q Do you know a man named Jean Luc 3 think you understand what the Court said
4 Brunel? 4 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 Q He was at your house last week, does 6 that, I would like to caution you
7 that remind you? 7 professionally, if you continue with the
8 MR. PIKE: Form, move to strike, 8 argumentative questions, I am going to have
9 speculation, argumentative, harassing. 9 to terminate this deposition —
10 Is there a question on the table, Mr. 10 MR. EDWARDS: I completely understand.
11 Edwards? 11 MR. PIKE: Okay. We are here today
12 MR. EDWARDS: Yes. 12
13 Q Do you know him? 13 MR.. EDWARDS: Mr. Brunel —
14 A Can you spell his name for me, please? 14 MR. PIKE: I want the Court to know we
15 Q I don't need to spell his name. Do you 15 are here today to allow you to ask your
16 know who I'm talking about, Mr. Brunel? 16 questions, but the harassing and
17 A Sorry, Mr. what? 17 argumentative tone is not going to be
18 Q 18 tolerated.
19 A I would like to answer that question as 19 MR. EDWARDS: We have a video. We can
20 well, but my attorneys have counseled me today I 20 show the Court the tone. It is obviously
21 have to assert my Sixth Amendment rights, Fifth 21 not harassing.
22 Amendment rights and Fourteenth Amraultrent rights 22 MR. PIKE: That's fine.
23 under the U.S. Constitution or risk losing my 23 Q Mr. Brunel is a long-term friend of
24 right to effective representation. 24 yours, right?
25 Q What's the purpose for you asking me to 25 A I intend to respond to all relevant
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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
4 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 Q When you were bein criminally
7 Q You know him as somebody who has been 7 investigated and= was i 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?
11 A You will have to repeat the question, 11 MR. PiKE: Form.
12 fm sorry. 12 A Again?
13 Q You know Mr. Brunel as somebody who has 13 Q Putting a time frame on It, the time
14 been caught engaging in sex with minors in the 14 frame where you were being criminally
15 past; is that correct? 15 investigated —
16 MR. PiKE: Form. 16 A What time frame is that?
17 A I intend to respond to all relevant 17 Q In her complaint it is not specific,
18 questions regarding this lawsuit; however, at the 18 but, let's just make it whenever. At some . int
19 present time my attorneys have counseled me that 19 in time did you place a telephone call to in
20 I cannot provide answers to any questions 20 Meriting her not to come forward with
21 relevant to this lawsuit, and I must accept their 21 any information about you engaging In sex with
22 advice or risk losing my Sixth Amendment tight to 22 her while she was a minor?
23 effective representation as your firm has been 23 MR. PiKE: Form.
24 described by the US. Attorney as a criminal 24 A I intend to respond to all relevant
25 enterprise and part of one of the largest frauds 25 questions regarding this lawsuit; however, at the
47 49
1 in Florida's history specifically said you have 1 present time my attorneys have counseled me that
2 been fabricating -- the law firm has been 2 I 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 fleece 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 Q 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: &WM.
10 Q You were Involved in a modeling business 10 A Again, as your firm has been described
11 with him called M.C. Squared; is that correct? 11 by the current U.S. Attorney as a criminal
12 A Again? 12 enterprise involved in mail fraud, wire fraud,
13 Q You were involved in a modeling agency 13 money laundering, and specifically crafting,
14 with — 14 fabricating multiple cases of sexual — of a
15 A What do you mean 15 sexual nature against people like me, and others,
16 Q — with Mr. Brunel called M.C. Squared? 16 in order to fleece many, many unsuspecting
17 A "Involved" means what, what do you 17 investors out ofmillions of dollars; I would
18 mean? 18 like to answer your questions here today, Mr.
19 Q You tell the jury your involvement with 19 Edwards, but unfortunately, my attorneys have
20 the modeling agency. You can clarify for me, 20 counseled me that I must assert my Fifth, Sixth
21 Fillet you do that. 21 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 Q Who are your current employees?
24 questions regarding this lawsuit. However, at 24 MR. PIKE: Form.
25 the present time my attorneys have counseled me 25 A Say that again.
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1 Q 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 A I intend to respond to all relevant 3 MR. EDWARDS: This is on the video.
4 questions regarding this lawsuit; however, at the 4 MR. PiKE: Nonetheless you know the
5 present time my attorneys have counseled me that rules. Nonetheless. If we have a question
6 I cannot provide answers to any questions that 6 on the table, would 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
10 assert my Sixth Amendment, Sixth Amendment and 10 the court reporter, I would agree, but the
11 Fourteenth Amendment rights as provided by the 11 jury is going to see a video and everybody
12 U.S. Constitution. 12 knows commonly, if somebody shakes their
13 Q Isn't it true you pay your employees to 13 head, they are saying "no," and if that was
14 bring you underage minor females for sex? 14 the answer, I wanted to give him a chance to
15 MR. PIKE: Form, argumentative, 15 elaborate on it, that's it.
16 speculation, harassing. 16 Q Isn't It true that when underage females
17 A Mr. Edwards, your firm has been 17 would come to your house, you would engage in
18 described the current U.S. Attorney as a criminal 18 sexual activity with them and then pay them?
19 enterprise, a criminal enterprise, part of the 19 MR. PIKE: Same objections.
20 largest fraud in South Florida's history; but 20 A Unfortunately I would like to answer
21 part of that fraud was fabricating, urn, 21 that question today, but my attorneys have
22 fictitious cases against me -- excuse me, against 22 counseled me that i must assert my Sixth
23 people like me, of a sexual nature, in order to 23 Amendment right, my Fifth Amendment right and my
24 fleece unsuspecting investors out of millions of 24 Fourteenth Amendment right under the U.S.
25 dollars. 25 Constitution.
51 53
1 Unfortunately at this time, though, I 1 The fact that your finn 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 Florida's -- South
4 assert my Sixth Amendment, Fourteenth Amendment 4 Florida's history, pan 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 fleece
7 Q Isn't It true when underage females were 7 unsuspecting investors out ofmillions of
8 brought to you, you would engage in sex with them 8 dollars. I would like to answer that question,
9 and pay them? 9 Mr. Edwards; however, today, i must assert my
10 MR. PIKE: Form, argumentative, 10 Fifth, Sixth and Fourteenth Amendment right.
11 harassing. 11 Q In addition to paying these underage
12 A (Witness shakes head.) 12 females for sexual activity, you also paid them
13 Q 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 Q Are you shaking your head to say "no, I 15 MR. PIKE: Form.
16 don't know how to interpret that answer?" 16 Q Is that correct?
17 A I didn't realize i was shaking my head. 17 A I intend to respond to all relevant
18 MR. EDWARDS: I thought he was actually 18 questions regarding this lawsuit; however, at the
19 answering a question. 19 present time my attorneys have counseled me that
20 MR. PiKE: Well just strike The miles 20 i may not, and I must assert -- they have advised
21 are well-known to every lawyer who practices 21 me must assert my Sixth Amendment right, my
22 in the State of Florida, that it is clear 22 Fifth Amendment right and my Fourteenth Amendmen
23 that a nod of the head or shake of the head 23 rights under the U.S. Constitution.
24 is not understood by the record, so 24 Q You would pay underage females 200 to
25 therefore Mr. Epstein was clearly not 25 $300 for engaging in sexual activity with you or
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i for procuring another underage female to engage 1 Attorney, and as part of the largest fraud in
2 in sexual 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 malicious cases of sexual harassment
4 Assumes facts not in evidence and calls for 4 and other cases of sexual nature against people
5 a legal conclusion as well, argumentative. 5 like me and others, although I would like to
6 A I intend to respond to all relevant 6 answer that question today, my attorneys have
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 U.S. Constitution. Although I believe you
10 may be relevant to this lawsuit, and I must 10 know I would really like to answer your
11 accept their advice or risk losing my Sixth 11 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.
13 Accordingly, therefore, I must assert my 13 Q Isn't it true with this method you were
14 constitutional rights as guaranteed by the Fifth, 14 able to interact sexually with underage girls
15 Sixth and Fourteenth Amendment to the U.S. 15 every single day?
16 Constitution. 16 MR. PIKE: Form, asked and answered.
17 Q Would you agree that your scheme was 17 Same objections.
18 devised to coerce these underage minors to bring 18 Q Co ahead.
19 you as many other underage minors, as were 19 A Oh, I7n sorry. Can you repeat it?
20 available for you to engage in sexual activity 20 Q Sure. With this method of -
21 with? 21 A "This method" being what, sorry?
22 MR. PIKE: Fonn. 22 Q 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 Q Yes. Would you agree that your scheme 24 true that that method resulted in you engaging in
25 was devised to coerce underage girls into 25 sexual activity with underage minors on an every
55 57
1 bringing as many other underage girls to you, as 1 day basis?
2 were available for sexual purposes? 2 MR. PIKE: Same objections.
3 MR. PIKE: Form. 3 A Your firm has been described by the
4 A Did you say "for sexual purposes"? 4 current U.S. Attorney as a criminal enterprise
5 Q Yes, for sexual purposes. 5 engaged in one of the largest frauds in South
6 A I'm not surprised. Since your firm was 6 Florida's history, and as part of that fraud,
7 described as pin pybsting one of the largest 7 creating, fabricating, malicious cases of sexual
8 frauds in Florida's history by crafting, 8 nature against people like me and others, so
9 fabricated sexual harassment cases against people 9 unfortunately, though I would like to answer that
10 like me and others in order to fleece 10 question today, I must assert my Sixth Amendment,
11 unsuspecting investors out of millions of 11 Fourteenth Amendment and Fifth Amendment rights
12 dollars, I would like to answer that question. 12 to my counsel's advisement to do, although I
13 However, today my attorneys have advised me i 13 believe you know I would really like to answer
14 must assert my Sixth Amendment, Fifth Amendment 14 those questions today, I must assert those rights
15 and Fourteenth Amendment right under the U.S. 15 or risk losing my attorneys representation.
16 Constitution, and if i don't do so, I risk 16 Q To keep track of all these underage
17 losing — uh... losing effective representation. 17 minors, you stored their names and telephone
18 Q Utilizing this method of using underage 18 numbers In your home computer; isn't that
19 minors to bring you other underage minors, you 19 correct?
20 were able to engage in sex with hundreds of 20 MR. PiKE: Form, argumentative,
21 underage minor females. Is that true? 21 speculation.
22 MR. PIKE: Form, argumentative, 22 A Again? Sorry.
23 harassing and calls for speculation. 23 Q 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
25 described as a criminal enterprise by the U.S. 25 question, of course, I'll keep reading it as many
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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 U.S.
5 repeat the question. S Constitution. So although I would like 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 7 my attorneys resign.
8 question. 8 Q Do you know
9 MR. EDWARDS: I don't mind going through 9 A I intend to respond to all relevant
10 that, Mike, because I do want answers, but 10 questions regarding this lawsuit; however, at the
11 if I'm going to repeat the question multiple 11 present time my attorneys have counseled me that
12 times and get the same answer, we are 12 I cannot provide answers to any questions
13 wasting time. I want to stop us wasting 13 relevant to this lawsuit and must accept their
14 time repeating questions if I'm getting the 14 advice or risk losing my Sixth Amendment right to
15 same nonresponsive answer. 15 effective representation.
16 MR. PIKE: I understand your intention 16 Q Isn't it true you employed
17 here. 17 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 Q Isn't it true you employed
21 various questions that you've asked in other 21 for the purposes of contacting underage minor
22 indications, so you coming here today is of 22 females and scheduling them appointments to be at
23 no surprise that Mr. Epstein is required to 23 your house?
24 invoke his Fifth, Sixth and Fourteenth 24 A The current U.S. Attorney has described
25 Amendment rights under the United States 25 your law firm, Mr. Edwards, as a criminal
59 61
1 Constitution -- 1 enterprise engaged in one of the largest 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 multiple cases of a
4 thinking you were going to pull a rabbit out 4 sexual nature against me and others, in order to
of a habit, and Mr. Epstein was going to 5 fleece unsuspecting investors out ofmillions and
6 waive his Fifth, Sixth and Fourteenth 6 millions of dollars, so, though unfortunately I
7 Amendment rights to the U.S. Constitution, 7 would like to answer every one of your questions
8 at least not today. That will not be 8 today my attorneys have counseled me that today I
9 occurring. 9 must assert my Sixth Amendment, Fifth Amendment
10 Q Isn't it true that to keep track of the 10 and Fourteenth Amendment rights under the U.S.
11 names and phone numbers of these underage minor 11 Constitution. Though I believe you know I would
12 females, to Interact with sexually, you stored 12 like to answer those questions, although today I
13 those names and phone numbers in your home 13 must assert those rights or risk having my
14 computer? 14 attorneys resign.
15 A Thank you. I've heard the question 15 Tell the Jury how you know
16 now. It didn't surprise again, I've now heard 16
17 the question and the fact that your firm has been 17 MR. PIKE: Form move to strike.
18 described as a criminal enterprise by the current 18 MR. EDWARDS: Move to strike my
19 U.S. Attorney in South Florida, and part of one 19 question?
20 of the largest frauds in Florida's history. it is 20 MR. PIKE: (Nods.)
21 reported that your firm fabricated malicious 21 MR. EDWARDS: What basis?
22 cases of a sexual nature against people and 22 s' MR. PIKE: Do I have to state a
23 against me, in order to fleece unsuspecting 23 basis? Usually I'm just required to state
24 investors out ofmillions of dollars. 24 'form."
25 Unfortunately, though I would like to 25 MR. EDWARDS: You have done more than
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1 that today. 1 your firm, Mr. Edwards, as a criminal enterprise
2 MR. PIKE: If I went on a diatribe of 2 involved in mail fraud, wire fraud, money
3 explaining, you know, what's centbsing, 3 laundering and, in fact, fabricating multiple
4 compound and relevant, then you would blame 4 cases of a sexual nature against me, others, in
5 for testifying for the witness. So I just 5 order to fleece unsuspecting investors in South
6 move to strike the question. 6 Florida out ofmillions and millions of dollars.
MR. EDWARDS: Make sure you mark that 7 Unfortunately, though I would like to
8 somewhere on this transcript, somehow. 8 answer each one of your questions here today, my
Tell the jury how you know 9 anomeys have advised me I must assert my Sixth
10 10 Amendment, Fourteenth Amendment and Fifth
11 MR. PIKE: Move to strike. 11 Amendment right under the U.S. Constitution,
12 A I intend to respond to all relevant 12 although I believe you know I would like to
13 questions regarding this lawsuit. However, at 13 answer your questions, but at this moment I must
14 the present time my attorneys have counseled me 14 assert those rights or risk having my attorneys
15 that I cannot provide answers to any questions 15 resign.
16 relevant to this lawsuit and must accept their 16 Q Isn't it true that with each of these
17 advice or risk losing my Sixth Amendment right to 17 underage minor females that were brought to your
18 effective representation. Accordingly, I assert 18 house, your method of sexually exploiting them
19 my Fifth Atinanhinint, Sixth Amuslusart and 19 was nearly Identical; is that correct?
20 Fourteenth Amendment right under the U.S. 20 MR. PIKE: Objection, argumentative,
21 Constitution. 21 conflising, overbroad and vague.
22 Q Isn't It true that you brought her to 22 A I don't even understand the question.
23 this country when she was underage and made ha 23 Q Okay. When a 14 or 15-year old would be
24 your sex slave, and you've bragged about this? 24 led Into your bedroom, you would appear from the
25 MR. PIKE: Form, argumentative, 25 shower first, usually naked; Is that correct?
63 65
compound, harassing and calls for 1 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 all relevant
5 present time my attorneys have counseled me that 5 questions regarding this lawsuit; however, today
6 I cannot provide answers to any questions 6 my attorneys have advised me that 1cannot
7 relative to this lawsuit and I must accept this 7 provide answers to any questions relevant to this
8 advice or risk losing my Sixth Amendment right to 8 lawsuit and must accept their advice or risk
9 effective representation. However, I would like, 9 losing my Sixth Amendment right to effective
10 so I'm clear, the question was, did I bring her 10 representation. Accordingly, therefore, I must
11 here? Specifically — 11 assert my Constitutional rights — the Fifth
12 Q Your answer is fine. 12 Amendment, Sixth Amendment and Fourteenth
13 A Okay. 13 Amendments to the U.S. Constitution.
14 Q Is it true that you demanded numerous 14 MR. PIKE: Can we go off the record for
15 underage minor females to have sex with 15 a second?
16 Inside your home while you watched, 16 MR. EDWARDS: If it is necessary.
17 masturbating? 17 MR. PIKE: Yes, let's go off the
18 MR. PIKE: Same objections. 18 record.
19 A You have to repeat the question. 19 THE VIDEOGRAPHER: Going off the video
20 Q Isn't it true that you have ordered 20 record at 12:35 p.m.
21 several underage minor females to have sex with 21 (Pause in the proceedings.)
22 in your home while you watched, 22 THE VIDEOGRAPHER: Back on the video
23 masturbating? 23 record 12:44 p.m.
24 MR. PIKE: Same objections. 24 MR. EDWARDS: Can you tell me what my
25 A The current U.S. Attorney has described 25 last question is?
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1 THE COURT REPORTER: Certainly. 1 her vagina; is that correct?
2 (The record was read.) 2 MR. PIKE: Form.
3 Q 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 we I cannot, must
6 MR. PIKE: Same objections. Form. 6 assert my rights under the U.S. 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 U.S. Constitution,
9 present time my attorneys have counseled me I 9 especially since your finn has been described as
10 cannot provide answers to any questions relevant 10 a criminal enterprise by the current U.S.
11 to this lawsuit and must accept their advice or 11 Attorney perpetrating one of the largest frauds
12 risk losing my Sixth Amendment right to effective 12 in South Florida's history, fleecing investors
13 representation. 13 out of millions of dollars by fabricating
14 Q You would then order them to, or order 14 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.
16 correct? 16 Q With many of these underage minors you
17 MR. PIKE: Form. 17 would use vibrators on them; Is that correct?
18 A I intend to respond to all relevant 18 MR. PIKE: Form.
19 questions regarding this lawsuit and I would like 19 A I would like to respond to that question
20 to answer each and every one of your questions 20 as l would like to respond to all your other
21 today, Mr. Edwards; however, my attorneys have 21 questions today. However, my attorneys have
22 told me that I cannot do that today unless and I 22 counseled me that I must assert my Sixth
23 must assert my Sixth Amendment, Fifth Amendment 23 Amendment rights, my Fifth Amendment rights and
24 and Fourteenth Amendment rights under the U.S. 24 my Fourteenth Amendment nghts under the U.S.
25 Constitution or risk losing my counsel. 25 Constitution.
67 69
1 Therefore, I'm going to assert those rights as 1 Q 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 Q You would then roll over and continue 4 MR. PIKE: Form.
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 1would
A I intend to respond to all relevant 7 like to answer each and every one of your
8 questions regarding this lawsuit. It is -- it is a questions; however, my attorneys have counseled
9 my understanding that the current U.S. Attorney 9 me that today I must assert my Sixth Amendment,
10 has described your law finn as a criminal 10 Fifth Amendment and Fourteenth Amendment rights
11 enterprise, yours and Mr. Jaffe's firm, as a 11 under the U.S. Constitution, especially since
12 criminal enterprise and part of the largest fraud 12 your fine has been described by the current U.S.
13 in Florida's history, fabricating malicious cases 13 Attorney as perpetrating one of the largest
14 of a sexual nature against me and others, in 14 frauds in Florida -- in Florida's history, by
15 order to fleece investors out ofmillions of 15 fabricating malicious cases of a sexual nature
16 dollars, through bogus schemes including 16 against me and others.
17 conspiracy to — excuse me to commit mail 17 Q ID 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 20 A Again?
21 me I cannot, and must assert my Fifth, Sixth and 21 Q In June of 2008, you pled guilty to two
22 Fourteenth Amendment rights under the U.S. 22 felonies; is that correct?
23 Constitution. 23 MR. PIKE: Same objection.
24 Q You would then rub the underage minor 24 A Yes.
25 female's vagina and/or insert your fingers into 25 Q And what were those felonies that you
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1 pled guilty to? 1 Q 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 procuring a minor for underage sex. 5 Q My understanding from reading the court
6 Q You have taken the Fifth as to questions 6 files that one of these females vs asE Do you
7 related to many of these underage minors, but the 7 know who that is?
8 underage minors that were the vi ' • ' the 8 A I intend to respond to all relevant
9 cases where you pled guilty, wer is that 9 questions in this lawsuit. However, at the
10 one of them? 10 present time my attorneys have counseled me that
11 MR. PIKE: Form, mischaracterizes the 11 I cannot provide answers to any of these
12 witness's testimony. Calls for a legal 12 questions today. So accordingly, I must assert
13 conclusion? 13 my constitutional rights under the Fifth, Sixth
14 A Again. 14 and Fourteenth Amendments of the U.S.
15 Q What was the name of the any of the 15 Constitution.
16 underage minors that were the subject of the 16 Q You're aware• is somebody that
17 criminal charges to which you pled guilty? 17 alleges she was at your house on more than 100
18 A I don't know. 3.8 occasions; is that true?
19 Q So, tell me about those charges. What 19 MR. PIKE: Form.
20 were the allegations of those charges? 20 A Can you repeat the question, sir?
21 MR. PIKE: Form. 21 Q Are you aware that Is a female that
22 A Solicitation of prostitution, not 22 alleges that when she was underage, she was at
23 underage prostitution... Prostitution. 23 your house on more than 100 occasions?
24 Q Were the victims or the prostitutes, as 24 MR. PIKE: Form, predicate.
25 you would say, were they minors? 25 A I intend to respond to all relevant
71 73
1 MR. PIKE: Form. 1 questions to this lawsuit, 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 Q Okay, so tell me what those cases were 4 Sixth Amendment right and my Fourteenth Amendment
about. What happened? 5 right under the U.S. Constitution or risk losing
6 MR. PIKE: Form again. 6 than as my attorneys, so therefore I must assert
7 A I... (Witness shrugs.) I can't tell you 7 those rights.
8 any more than that. 8 Q You understand that her complaint was
9 Q You don't know what you pled guilty to? 9 that Epstein tumult on to her stomach on the
10 A I just told you -- 10 massage bed and inserted his penis in to her
11 MR. PIKE: Object to the form, asked and 11. vagina, Stated Epstein began to pump his penis
12 answered, 12 in her vagina and, she became upset over this.
13 Q Do you know what you pled guilty to, the 13 She said her head was being held against the bed
14 facts? 14 forcibly as he continued to pump inside of her
15 A Solicitation of prostitution. 15 while she screamed "no."
16 Q I understand that that's the charge. 16 Are you aware of those allegations?
17 What were the underlying facts? What did you do, 17 MR. PIKE: Form, predicate.
18 did you pull up In a car, talk to the person, did 18 A I'm sorry, did you say there is a
19 they come over to your house, how did you get 19 complaint?
20 them, those kinds of things. Tell the jury what 20 Q In the incident report that led to a
21 were the underlying facts about the charges you 21 charging document, that led to a charge that you
22 pled guilty to? 22 bane pled guilty to. Are you aware of that
23 MR. PIKE: Object to the form. Move to 23 Information coming fromM )
24 strike. 24 MR. PIKE: I'm sorry, Mr. Edwards; what
25 A I don't 'mow. 25 are you reading from?
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1 MR. EDWARDS: The 87-page Palm Beach 1 argumentative, compound, harassing.
2 Police Department incident report where 2 A This was who?
3 there are numerous underage females 3 Q The question is, are you aware.?
4 describing their interaction with Mr. 4 A MINI
5 Epstein at his house. I'mreading The current U.S. Attorney, since he has
6 specifically from page 41 related t 6 described your firm as a criminal enterprise and
7 who was one of the victims he pi 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 of a sexual nature against people like me
10 that you're seeking production of, in this 10 and others, and fleecing investors out of
11 same exact case? 11 millions of dollars by using means described in
12 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
14 State Attorney's file. 14 today, though I would like to answer each one of
15 MR. PIKE: Okay. Sony. What's the 15 your questions, my attorneys have counseled me
16 question? 16 that I must not, !must assert my Sixth
17 Q Are you aware of that allegation? What 17 Amendment, Fifth Amendment and Fourteenth
18 I just read to you. 18 Amendment rights under the U.S. Constitution, and
19 A I would like to answer that question, 19 I believe you know I would like to answer those
20 but, however, today my attorneys have advised me 20 questions. I must assert those rights or risk
21 I must assert my Fifth Amendment, Sixth Amendment 21 losing my attorneys tailor!.
22 and Fourteenth Amendment rights under the U.S. 22 Q Do you knov
23 Constitution. 23 A Spell it, please.
24 Q Assuming your attorneys have advised you 24 Q I don't know how to spell her name, bat
25 but because of Res indicate, double Jeopardy, you 25 do you know'? I don't know that she would
75 77
1 cannot be charged for any crimes that you have 1 have ever spelled her name for you.
2 already pled guilty to relating ME, so I 2 MR. PIKE: Form, move to strike.
3 would like you to explain to the jury, in your 3 Q Her name is
4 words, or your version of the story, what was 4 A I intend to respond to all relevant
5 your interaction withM at your house when she 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 attorney/client 8 would like to, and I must, in fact, take their
9 communications. 9 advice or risk losing their representation, so
10 A I intend to respond to all relevant 10 therefore, I must assert those rights under the
11 questions regarding this lawsuit. 1 would like 11 U.S. Constitution.
12 to answer each of your questions today, however, 12 Q Do you know the names of any of the
13 my attorneys have counseled me that I may not. 13 females that you allegedly solicited for
14 They've advised me that I must assert my Fifth 14 prostitution and pled guilty to?
15 Amendment, Sixth Amendment and Fourteenth 15 MR. PIKE: Relevance.
16 Amendment rights under the U.S. Constitution. 16 A Sitting here today, no, I do not.
17 Therefore, if I don't, I tisk losing their 17 Q You asked me to spell=s name.
18 counsel. Therefore, I mist assert those rights 18 That's somebody that your attorneys took her
19 here today, Mr. Edwards. 19 deposition about a year and a half ago. Does
20 Q Are you aware that= Advised police 20 that help to refresh your recollection as to who
21 that she was ripped and torn in her vagina area 21 =is?
22 and had dlMolly walking to the car after this 22 A I would like to answer that question but
23 episode where you forcibly inserted your penis 23 today, according to my attorneys, I must assert
24 into her vagina? 24 my Fifth Amendment, Sixth Amendment and
25 MR. PIKE: Objection, relevance, 25 Fourteenth Amendment rights under the U.S.
20 (Pages 74 to 77)
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1 Constitution. I must accept their advice or risk 1 and Fourteenth Amendment rights to the U.S.
2 losing my Sixth Amendment right to effective 2 Constitution or risk losing effective
3 representation, Mr. Edwards, so though I would 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 Q Just so you are clear, since your
6 attorney made it an objection that it was
7
8
mil There is another victim, her name Is
that was listed as one of the females at
your house and you pled guilty to the
7
8
unclear, then you invoked your Fifth Amendment
rights —
solicitation of. 9 A Sorry.
10 1would like to ask you if you remember 10 Q I'm talking about the cases where you
11 her? 11 already pled guilty and you can't be charged
12 MR. PIKE: Form, confusing, compound. 12 again. What were the facts and circumstances
13 A =? 13 that led up to you pleading guilty to these
14 Q I don't know her first time, initial 14 felonies?
15 last name Is IM 15 A I've answered the question.
16 MR. PIKE: Same objection. 16 MR. PIKE: Same objection, asked and
17 A I intend to respond to all relevant 17 answered.
18 questions regarding this lawsuit. However, at 18 THE VIDEOGRAPHER: Counsel.
19 the present time my attorneys have counseled me 19 (Indicating five minutes left on tape.)
20 that I cannot provide answers to any questions 20 MR. EDWARDS: Okay.
21 relevant to this lawsuit, and I must accept their 21 Q Just so the Jury understands, these
22 advice or risk losing my right to effective 22 three females that were the subject of the guilty
23 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
79 81
1 Q With each case that results In a 1 your house; isn't that correct?
2 charge - 2 MR. PIKE: Objection, argumentative,
3 THE WITNESS: Excuse me, is there some 3 compound, harassing, assumes facts not in
4 water? 4 evidence. I move to strike.
THE VIDEOGRAPHER: Off the record? 5 A You have to t the uestion.
6 MR. EDWARDS: Stopping again? 6 Q Okay are all people
7 THE WITNESS: Can I get some water? Mr. 7 that were, at the time you engaged In sexual
a Jaffe, 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?
it THE WITNESS: Sony. 11 MR. PIKE: Same objections incorporated
12 Q With each conviction, charge, or with 12 as well 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
la facts and circumstances that lead up to that plea 14 understand the question.
15 of guilty. 15 Q Isn't it true that you used underage
16 MR. PIKE: Form. 16 minor females to bring other underage minor
17 Q What are the facts and circumstances 17 females to your house for sex?
18 that led to you pleading guilty to the two 18 MR PIKE: Asked and answered.
19 felonies that you've described? 19 A (Witness shrugs.)
20 MR. PIKE: Form, overbroad, compound, 20 MR. PIKE: Way earlier on.
21 coniltsing, calls for a legal conclusion. 21 MR. EDWARDS: He doesn't understand the
22 A I would like to respond to that 22 question -
23 question. I would like to respond to that 23 MR. PIKE: You can answer the question.
24 question, but today my attorneys have advised me 24 Q I'm going through the progression.
25 I must assert my Fifth Amendment, Sixth Amendment 25 MR. PIKE: You can answer, but it is
23. (Pages 78 to 81)
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1 asked and answered. 1 1:05 p.m.
2 A As your firm, Mr. Edwards and Mr. 2 (Pause in the proceedings.)
3 Jaffe's has been described by the U.S. Attorney 3 THE VIDEOGRAPHER: Back on the video
4 as perpetrating one of the largest frauds in 4 record 1:15 p.m.
5 South Florida's history by crafting malicious 5 Q 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 U.S. Attorney's words, investment 8 sexually, were prostitutes prior to meeting you?
9 schemes. Unfortunately, though I would like to 9 A I'm saying I pled guilty to the
10 answer every one of your questions if I'm able, 10 solicitation of prostitution.
11 my attorneys have advised me I must assert my 11 Q Right, and you would certainly agree
12 Sixth Amendment, Fourteenth Amendment and Fifth 12 that that would require yourself and one other
13 Amendment rights under the U.S. Constitution. 13 Individual for that act of prostitution,
14 Therefore, at the moment I cannot answer that 14 correct?
15 question. 15 MR. PIKE: Form. Also calls for a legal
16 Q The acts related to your guilty plea 16 conclusion.
17 occurred at your Palm Beach house; is that 17 A I pled guilty to solicitation of
18 correct? 18 prostitution.
19 MR. PIKE: Form. 19 Q Are you saying that those females that
20 A Again, sorry. 20 were the victims, at least listed as victims by
21 Q If you were soliciting prostitutes, It 21 the State, were prostitutes prior to meeting
22 wasn't out on the street, it wasn't at a hotel. 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 I pled guilty to solicitation of
25 correct? 25 prostitution.
83 85
1 MR. PIKE: Objection, relevance, 1 Q 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 Q — 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.
7 must assert my Sixth Amendment, Fifth Amendment 7 A I pled guilty to solicitation of
8 and Fourteenth Amendment rights under the U.S. 8 prostitution, not underage prostitution, simply,
9 Constitution. Otherwise I risk losing their 9 prostitution.
10 representation. So, accordingly I must assert 10 Q Are you saying now that the subjects of
11 those rights, Mr. Edwards, and Mr. Jaffe. 11 that, which were called victims, were not
12 Q 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 Q These were crimes that occurred here In 15 as well as mischaracterizes the witness's
16 Palm Beach County? 16 testimony.
17 MR. PIKE: Form. 17 A I pled guilty to solicitation of
18 Q Is that correct? 18 prostitution, not underage prostitution,
19 A ... I pled guilty in Palm Beach County. 19 solicitation of prostitution.
20 Q Isn't it true that you kept a calendar 20 Q I was under the impression you pled
21 or schedule — 21 guilty to a second degree felony, that being
22 THE VIDEOGRAPHER: I have to change the 22 procuring a minor for the purposes of
23 tape. 23 prostitution.
24 MR. EDWARDS: Change it. 24 A That's correct.
25 THE VIDEOGRAPHER: Off the video record 25 Q So a minor Is somebody under the age of
22 (Pages 82 to 85)
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1 18, and I'm asking for the guilty plea related to 1 advised me I cannot and they've advised me I must
2 that count; are you at all remorseful for your 2 assert my Sixth Amendment right, my Fifth
3 interactions with that minor? 3 Amendment right and my Fourteenth Amendment right
4 MR. PIKE: Same objections. 4 under the U.S. Constitution, therefore, that's
5 A What minor? 5 what I'm going to do.
6 Q The charge is procuring a minor. You 6 Q 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, speculation.
9 Q You were never told during the State 9 A You said where is...
10 Attorney's prosecution of you, who this person 10 MR. PIKE: "Again."
11 was? 11 Q Where is the calendar or schedule that
12 A No. 12 kept for you for your appointments
13 Q Why did you plead guilty to a felony 13 for sex with underage females?
14 charge that resulted In you going to jail, 14 MR. PIKE: Same objection.
15 without even knowing who the victim was? 15 Q If there is not one, you can tell me
16 MR. PIKE: Form. That question calls 16 there Is not one.
17 for attorneyklient information, and 17 A I would like to answer each one of your
18 therefore, I'm going to instruct him not to 18 questions today. However, I have been advised by
19 answer that. 19 counsel that I must assert my Fifth Amendment,
20 Q If it has anything to do with any 20 Sixth Amendment and Fourteenth Amendment rights
21 conversations with your attorney, I don't want to 21 under the U.S. Constitution or risk losing their
22 know. I'm Just going off of the plea colloquy 22 representation. Therefore, I'm going to have to
23 between you and the Judge, where you understood 23 assert those constitutional rights, though I
24 the charges and have been advised and apprised of 24 would like to answer that question.
25 the charges and you still willingly, willfully 25 Q Are you still in possession of the
87 89
1 plod guilty to the charges. I'm taking now 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 I still...?
4 MR. PIKE: What was the question? I 4 Q Are you still In possession of the
5 don't know the question on the table now. 5 computers that were removed from your house just
6 Q Who was the minor? 6 prior to the execution of the search warrant?
7 A I don't know. 7 A I intend to respond to all relevant
8 Q You were never told the tune or Initials 8 questions regarding this lawsuit. However, at
9 of that minor victim by the State Attorney's 9 the present time my attorneys have counseled me I
10 Office or the prosecutor? 10 cannot respond to any questions that may be
11 A Not that I recall. 11 relevant to this lawsuit, no matter how much I
12 Q 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 representation. Therefore, I must assert my
15 something that you do In New York, and New 15 rights under the Fifth, Sixth and Fourteenth
16 Mexico, Florida, everywhere, not just West Palm 16 Amendments of the U.S. Constitution.
17 Beach; isn't that right? 17 Q Who is it that removed those computers
18 MR. PIKE: Again, form, compound, again 18 from your house prior to the execution of the
19 IISSUMCS facts not in evidence. 19 search warrant?
20 Argumentative and harassing, and moreover, 20 MR. PIKE: Objection, predicate.
21 we have already been down this road before 21 A I intend to respond to all relevant
22 in separate related questions that have 22 questions regarding this lawsuit. However, at
23 already been asked and answered. 23 the present time my attorneys have counseled me
24 A I would like to respond to each one of 24 that I cannot provide answers to any questions
25 your questions; however, today my attorneys have 25 that may be relevant to this lawsuit, no matter
23 (Pages 86 to 89)
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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 today... and hopefully will get to
3 Accordingly, therefore, I would have to assert 3 do so at sane point, my lawyers have advised me I
4 those rights, Mr. Edwards. 4 must today assert my constitutional rights under
5 Q It is my understanding, through 5 the Sixth Amendment, Fifth Amendment and
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 repri...naltation.
9 you engaged in sexual activity; is that correct? 9 Q And as part of that organization you
10 A You're - 10 developed code terms such as "Work" or "Manage"
11 MR. PIKE: Objection. 11 as opposed to engage in sex with minors; is that
12 A -- you're asking for my understanding? 12 true?
13 Q No— 13 MR. PIKE: Form, argumentative,
la A Are you asking me to tell you what your 14 speculation, harassing, assumes facts not in
15 understanding is? 15 evidence.
16 Q Did the computers that were removed from 16 A Can you... you...?
17 your home Just prior to the execution of the 17 Q You developed code terms such as you -
18 search warrant contain the complete list of 18 A "You" me?
19 underage minor females with whom you engaged in 19 Q Yes, you, would ask these girls if they
20 sexual activity? 20 would like to give you a massage or work for you,
21 MR. PIKE: Form. 21 rather than asking them to do what was going to
22 A Though I would like to answer that 22 be done, which is engage in sexual activity with
23 question, like all your other questions here 23 you; isn't that true?
24 today, unfortunately my attorneys have counseled 24 MR. PIKE: Same objections.
25 me that I'm going to have to assert my Sixth 25 A Are you asking if I developed code
91 93
1 Amendment, Fifth Amendment and Fourteenth 1 words? Is that the question?
2 Amendment rights under the U.S. Constitution. I 2 Q Right. Code words.
3 point -- excuse me. I would point out that your 3 A I would like to respond to that
4 film was described by the current U.S. Attorney 4 question, but unfortunately today my attorneys
S 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 Fifth 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 ofdollam 9 representation. Accordingly I assert my
10 I believe the senior partner of that 10 Constitutional rights as guaranteed by those
11 firm currently sits in jail. Unfortunately 11. amendments.
12 though I would like to answer all of your 12 Q What did it mean within your
13 questions, today my attorneys have counseled me I 13 organization when someone, some underage minor
14 must assert my rights under the Sixth Amendment, 14 female was coming over to work for you?
15 Fourteenth Amendment and Fifth Amendment of the 15 MR. PIKE: Form
16 U.S. Constitution. 16 A What did if mean?
17 Q Isn't it true, you and nd 17 Q Right, what did it mean? What did it
18 Ghislaine Maxwell and operated 18 mean to you was going to happen when an underage
19 as an organized criminal enterprise designed to 19 minor female would either call to work or IM
20 sexually exploit minor? 20 would tell you this person was coming to
21 MR. PIKE: Objection, argumentative, 21 work for you at a specific time?
22 speculation, calls fora legal conclusion 22 MR. PIKE: Objection, vague,
23 and continues to assume facts not in 23 speculative, assumes facts not in evidence.
24 evidence. 24 A I would like to answer that question, as
25 A Thought would like to answer that 25 most of your other questions today. However,
24 (Pages 90 to 93)
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1 today my attorneys have counseled me that I must 1 as a trash pull, 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 don't, I risk losing them as my attorneys so, 4 Q No. In your home, do you typically have
5 therefore, I must wort those rights. 5 your housekeeper, housemanager, or somebody else,
6 Q You're laughing as If my questions are 6 when they take a message for you, write on a
7 ludicrous right now but you're aware that there 7 specific pad that informs you as to who is
8 were trash pulls from your home where there were 8 calling, the time they are calling 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 coining over to your house, weren't you? 12 answered.
13 MR. PIKE: Same objections, form, as 13 Q You know what I'm talking about?
14 well. Move to strike, and also assumes 14 A I know what a message pad is.
15 facts not in evidence. Lack predicates. 15 Q Do you use them commonly in your home or
16 Q You're aware of the trash pull and the 16 did you back prior to your arrest?
17 message pads, correct? 17 A I would like to answer that question,
18 MR. PIKE: Same objections. 18 but today my attorneys have advised me I have to
19 Do you have any documents with you here 19 assert my Fifth Amendment, Sixth Amendment and
20 today that you speak of? 20 Fourteenth Amendment rights under the U.S.
21 MR. EDWAFtDS: No, but at this point in 21 Constitution, so therefore, I'm going to do that
22 time in the trial, they will already about 22 or I risk losing their representation.
23 in evidence. 23 Q Is my question to you confusing? Do you
24 A Pin aware ofa trash pull? What's a 24 know what I'm talking about?
25 "trash pull"? I'm sorry. 25 MR. PIKE: Form
95 97
1 Q Are you aware of I'll ask it of you 1 A Not specifically, no.
2 this way: When would take a phone 2 Q Okay.
3 message for you, what did she write it down 3 The information -
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 tome, 6 Q I don't have it to show you today, but
7 sorry. 7 If the Information and evidence that I have
8 Q If another employee of yours were to 8 learned through this process is accurate and
9 answer the telephone, 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
11 message for you and write It down so that you 11 about this document, so --
12 could read it later, what would that message be 12 A Okay.
13 written on? 13 Q — if we are going to get to a point you
14 A Most likely paper. 14 tell me "This document doesn't exist" or "I don't
15 Q Okay, Is that paper typically In the 15 know what you're talking about," okay, that's
16 form of a message pad that has a carbon copy 16 fine, but that's something we can hash out.
17 sheet to the back? 17 Here is my question: When a
18 A No. 18 housekeeper/housemanager would take a message for
19 Q You're unfamiliar with the documents 19 you from any taller, is there a specific message
20 that I'm talking about, that being a message pad 20 pad that has a carbon copy located near your
21 that Informs you as to who called, the lime they 21 telephone, for them to write down the name of the
22 called and the purpose for calling? 22 caller, the purpose for the call and the time
23 MR. PIKE: For purposes of the question 23 called?
24 you're specifically talking about a message 24 MR. PIKE: Fenn.
25 pad, nothing related to what you're defining 25 Q Is that something you're familiar with?
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1 A I would like to respond to that 1 Q Between the years 2002 and 2005, 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 U.S. 4 Q If there is more than one, tell us
5 Constitution. that.
6 Q You're Invoking your Fifth Amendment 6 A The question is unclear. I'm sorry.
7 right is not that you understand the question. 7 Q Okay, let me start with between 2002 and
8 You understand my question and are electing to 8 2005, did you employ a hossemanager?
9 invoke your Fifth Amendment rights; is that 9 MR. PIKE: Form.
10 correct? 10 A Where?
11 A Yes. 11 Q At your Palm Beach home.
12 Q When or a housekeeper or 12 A I intend to respond to all relevant
13 housemanager, whoever happened to be employed at 13 questions here today, Mr. Edwards. Hopefully we
14 the time, would take messages, what form would 14 will get some. But my attorneys have advised me
15 you normally or typically receive them In? 15 that today I must invoke my Sixth Amendment,
16 A (Witness shrugs.) 16 Fifth Amendment and Fourteenth Amendment rights
17 MIt PIKE: Same objections. 17 under the U.S. Constitution; or risk losing them
18 A I don't understand the question. 18 as counsel. So today I have to assert those
19 Q When a caller would call the home, 19 privileges.
20 housemanager or housekeeper or 20 Q Do you knoa
21 don't know what you would call her, assistant, 21 A I intend to respond to all relevant
22 would answer the phone, and take a message for 22 questions regarding this lawsuit. However, at
23 you so that you would know who called, what would 23 the present time no matter how much I would like
24 they typically 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 told me that I have
99 101
1 MR. PIKE: Objection. Object to the 1 to invoke my Sixth Amendment, Fifth Amendment and
2 fens, lacks predicate. You have not 2 Fourteenth Amendment or, in fact, risk losing
3 established anything here today relative to 3 their representation. Therefore, I'm going to
4 a housekeeper or housemanager or the like. 4 have to assert my rights under those.
5 Urn... And Pm trying to understand the 5 Is a female that was born
6 question. But — 6
7 MR. EDWARDS: Really? 7 A Is that a question?
8 MR. PIKE: — it lacks predicate. Q 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 Q Normally they would write It down on a 11 MR. EDWARDS: That assumes that he did
12 piece of paper and give It to you? 12 meet her; is that what you're saying?
13 A I didn't say that. 13 MR. PIKE: Your question assumes --
14 Q Have you ever been given a message that 14 MR. EDWARDS: He met her?
15 is ripped out of a message pad that has a carbon 15 MR. PIKE: -- exactly what he just said
16 copy to it? 16 which hasn't been established on the record
17 A Oh, I see. Okay. I intend I would 17 yet pursuant to the appropriate Florida
18 like to answer that question, but today my 18 Rules of Civil Procedure and the Evidence
19 attorneys have advised me I must respond by 19 Code. Lacks predicate.
20 invoking my Sixth Amendment right, my Fifth 20 A That being said, I would like to answer
21 Amendment right and my Fourteenth Amendment 21 that question, 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 23 me I must assert my Sixth Amendment right, my
24 I must assert those tights or I risk losing my 24 Fourteenth Amendment right, and my Fifth
25 representation here today. 25 Amendment right under the U.S. Constitution.
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1 THE WITNESS: Can you throw me one of 1 A And now the question?
2 the suckey candies, please 2 Q You know who she is, correct?
3 Thank you. 3 MR. PIKE: Form.
4 MR. EDWARDS: (Handing candy.) 4 A I would like to answer that question
5 THE WITNESS: Appreciate it. 5 here, Mr. Edwards, but unfortunately today my
6 Q Isn't It true ou me for the Ant 6 attorneys have counseled me I must invoke my
7 time I just before her 7 Fifth Amendment. Sixth Amendment and Fourteenth
8 fourteenth birthday? 8 Amendment rights under the U.S. Constitution, and
9 MR. PIKE: Same objections. 9 if I don't, I risk losing their representation,
10 A You know, your firm has been accused by 10 therefore I must assert those rights.
11 the U.S. Attorney of perpetrating one of the 11 en I asked you aboutiM or
12 largest frauds in South Florida history by 12 you sat there for a while thinking hard
13 crafting sexually charged lawsuits against people 13 about whether or not you knew them. Doyou
14 like me and others in order to fleece 14 remember either= o
15 unsuspecting investors here in South Florida out 15 MR. PIKE: I move to strike counsel's
16 ofmillions of dollars. The firm of you and Mr. 16 statement because the statement as worded
17 Jaffe. The U.S. Attorney described it as bogus 17 assumes facts certainly not in evidence. It
18 schemes connived by your firm. 18 is argumentative, speculates as to what is
19 I would like to answer every one of your 19 "thinking hard," and, counsel, i don't
20 questions here today, however, my attorneys have 20 understand the question on the table,
21 counseled me that 1may not, and have advised me 21 combined with your narrative. If you could
22 that I have to invoke my Sixth Amendment, Fifth 22 repeat the question?
23 Amendment and Fourteenth Amendment rights under 23 MR. EDWARDS: Sure.
24 the U.S. Constitution. Therefore, that's what I 24 Q I'm asking If during this questioning
25 will do, otherwise I risk losing their 25 process, has It refreshed your recollection as to
103 105
1 representation. 1 who is or do you really have no Idea who
2 Q Isn't it true= 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 4 Q Do you rememberM
A Are you going to ask one question?
6 MR. PIKE: Form. 6 Which question would you like answered first?
7 THE WITNESS: Tissue, please. 7 Q Do you remernberM
8 MR. EDWARDS: (Handing tissue.) A I would like to answer that question. 1
9 A I would like to answer that question 9 would like to answer that question today, however
10 like all the other questions you've asked me here 10 my attorneys today have advised me that I must
11 today, but today my attorneys have counseled me 11 assert my Fourteenth Amendment, Fifth Amendment
12 that I have to invoke my Sixth Amendment right, 12 and Sixth Amendment rights under the U.S.
13 my Fifth Amendment right and Fourteenth Amendment 13 Constitution, no matter how much I would like to
14 rights under the U.S. Constitution; therefore 14 answer these questions. So unfortunately, I'm
15 that's what I will do. 15 going to assert those rights.
16 Q Do you know wbo 16 Q When you first met= isn't it true
17 right, she had a lawsuit against you previously? 17 that she was just about to begin her ninth grade
18 MR. PIKE: Form. 18 year In high school?
19 A Again the last mune? 19 MR. PIKE: Same objections. Form.
20 20 A I believe her testimony in front of the
21 A Could you spell it for mc? 21 FBI, in a sworn deposition says something else,
22 Q Well, the pseudonym that she used in her 22 but I don't recall exactly what. I don't have
23 lawsuit against on alleging similar facts to 23 any recollection.
24 those alleged i versus Jeffrey Epstein was 24 Q Of=
25 versus Jeffrey Epstein. 25 MR. PIKE: Form.
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1 A You asked the question when I met her, I 1 Q When you first came into the room today,
2 think, if I met her. 2 didn't you look at me and say "I likeM" Isn't
3 Q 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 recollection if I ever met 5 A I don't believe I said that
6 her. I just told you, I did read her FBI 6 Q What Is It that you believe you did say
7 statement, w I know what she has said and it is 7 referencing= when you sat down in that seat
8 not what you've just represented to me. 8 prior to the cameras rolling?
9 Q Your only knowledge of any interaction 9 MR. PIKE: Form. Counsel, I was here
10 you may have had will Is derived from an FBI 10 during that whole time and I don't recall
11 statement that she gave; Is that true? 11 any such statement.
12 A I believe what you just represented she 12 MR. EDWARDS: You weren't in the room.
13 said was not what she had sworn to. 13 A 1don't remember. I don't know.
14 Q I'm not asking what she said. I'm 14 Sorry.
15 asking do you independently remember If she was 15 Q So is it your testimony right now that
16 entering into her ninth grade year of high school 16 you did not say to me "I
17 when you met her? Independent of anything you've 17 A That's
18 read. 18 MR. PIKE: Objection.
19 MR. PIKE: All right, let me just move 19 A -- that's correct.
20 to strike the... Diatribe between Mr. 20 Q Do you IllteM?
21 Edwards and Mr. Epstein. I'm confused as to 21 MR. PIKE: Form, predicate, and
22 what question is on the table now. 22 relevance.
23 MR. EDWARDS: Okay. 23 A I would like to answer all your
24 Q Independent of anything you've ever 24 questions here as I've... tried to do my best,
25 mad- 25 however, my attorneys have advised me that I must
107 109
1 A Okay. 1 assert my Sixth Amendment, Fourteenth Amendment
2 Q — do you remember meeting`, just 2 and Fifth Amendment rights under the U.S.
3 before sbe entered into her ninth grade year in 3 Constitution.
4 high school? 4 Q When you first met., Isn't it true
5 A I would like to answer that question, S that you knew she was an economically
6 however my attorneys today have advised me that 6 disadvantaged girl that needed money?
7 though her own statements are contradictory to 7 MR. PIKE: Objection, speculation,
8 what you just said, her sworn statements to the 8 assumes facts not in evidence, and it is
9 FBI contradict what you just said. I have to 9 argumentative as worded.
10 invoke my Sixth Amendment, Fifth Amendment and 10 A I would like to answer all your
11 Fourteenth Amendment rights to the U.S. 11 questions here today, Mr. Edwards, and Mr.
12 Constitution. 12 Jaffe. However, on advice ofcounsel I have to
13 Q Just a few minutes ago when you asked 13 assert my Sixth Amendment, Fifth Amendment and
14 when you met her, you said, "I don't know if I've 14 Fourteenth Amendment rights under the U.S.
15 ever met her," so Is that your testimony, that IS Constitution, or risk losing my right to
16 you don't know if you ever met 16 effective representation. So accordingly I must
17 A My testimony is very clear. I must 17 assert those rights as guaranteed by the Sixth,
18 assert the rights my attorneys have asked me to 18 Fifth and Fourteenth amendments.
19 assert today, though her testimony under oath to 19 Q When she was a 14-year old girl, she was
20 the FBI is not what you represented it to be, to 20 taken into your bedroom and you ordered her to
21 me, and the ladies and gentlemen of the jury who 21 take her clothes off; Is that correct?
22 are watching this, hopefully. 22 MR. PIKE: Objection, vague, confusing.
23 MR. PIKE: Form. 23 As to "her' I'm not quite sure who you...
24 Q We will get into that. 24 Q Virlien=was a I4-year old girl, she
25 A Okay. 25 was taken up to your bedroom and you ordered her
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to take her clothes off; isn't that true? 1 THE VIDEOGRAPHER: Going off the video
2 MR. PIKE: Objection, speculation, and 2 record 1:49 p.m
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 represented to me is a total contradiction to the 6 record 2:04 p.m.
7 FBI sworn statement that I read of= I must 7 Q Mr. Epstein, when was a 14-year old
8 unfortunately respond by asserting the rights 8 girl, Isn't it true that while you were naked o0
9 demanded by my attorneys today, which is my Sixth 9 the massage table, you ordered-to take off
10 Amendment, Fifth Amendment and Fourteenth 10 her clothes and provide you a massage?
11 Amendment right against sorry, given by the 11 A I believe I've answered that question,
12 U.S. Constitution, though her testimony is 12 didn't i?
13 exactly — does not purport in any way to what 13 Q i don't remember where we left off,
14 you've just said. 14 that's why.
15 Q And whenMwas 14 years old, you 15 MR. PiKE; Form, argumentative,
16 ordered she begin to give you a manage while she 16 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. 18 answaed. But we did take a break, so you
19 A Sorry, you have to repeat the question 19 can respond.
20 for me. 20 (Counsel addressing Mr. Epstein.)
21 Q When-was a 14-year old girl — 21 A The current U.S. Attorney has described
22 A Right. Yes? 22 your law firm as a criminal enterprise involved
23 Q you laughed and said, "right" about 23 in fabricating sexually charged cases against
24 what? 24 people like me in order to fleece Mc iresing
25 A I didn't hear the first part of your 25 investors out of millions of dollars. He used
111 113
1 question. Now I understood it. 1 words like "bogus schemes."
2 Q When-Was a 14-year old girl, wasn't 2 Unfortunately at this time in response
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? 4 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 U.S. Constitution, though I would like
8 A I understand that your lino has been 8 to answer those questions.
9 accused by the U.S. Attorney of South Florida, 9 Q WhileMwas 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 Florida's history, by crafting malicious, 11 your nipples during that massage; Isn't that
12 sexually charged ons against people like 12 true?
13 me. I understand testimony is not what 13 MR. PIKE: Same objections,
14 you've just described, though she swore to the 14 argumentative, speculation, harassing,
15 FBI... under oath. Though I would like to answer 15 assumes facts not in evidence and lacks
16 your questions here today, my attorneys have 16 predicate.
17 advised me I may not. I must assert my Sixth, 17 A i asked her to pinch her nipples?
18 Fifth and Fourteenth Amendment rights under the 18 Q Pinch your nipples?
19 U.S. Constitution or risk losing their 19 A I believe her own sworn testimony
20 representation. 20 contradicts that statement. However, I would
21 THE WITNESS: Restroom break. 21 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. 23 Edwards, I must take my constitutional privileges
24 MR. EDWARDS: Stopping again? 24 of the Sixth Amendment, Fifth Amendment and
25 THE WITNESS: Yeah. 25 Fourteenth Amendment, keeping in mind that your
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1 firm, of you, Mr. Edwards, and Mr. Jaffes firm 1 MR. PIKE: Same objections incorporated?
2 has been accusal by the U.S. Attorney of 2 A Again, the question?
3 perpetrating one of the largest frauds in 3 Q 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 fleece from 5 to the point of ejaculating while you were
6 local people millions of dollars. 6 inserting your lingers into= vagina?
7 Q And during this massage la, you 7 MR. PIKE: Objection, argumentative,
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
10 MFt. PIKE: Same objections? 10 predicate.
11 A Unfortunately, though I would like to 11 A Though I would like to answer that
12 answer each one of your questions here today, my 12 question with specificity 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 14 have advised me I cannot. They advised me I must
15 Amendment and Fourteenth Amendment rights under 15 assert my Fifth Amendment, Sixth Amendment and
16 the U.S. Constitution, otherwise 1risk losing 16 Fourteenth Amendment rights under the U.S.
17 their effective representation, and the fact that 17 Constitution or potentially lose effective
18 your firm has been accused of fabricating these 18 representation, so therefore, I will assert those
19 malicious lawsuits to fleece investors out of 19 rights.
20 millions of dollars, as described by the U.S. 20 Q Isn't it true that the ritual that I'm
21 Attorney here in South Florida as a criminal 21 describing occurred with approximately 100
22 enterprise involved in mail fraud, money 22 times when she was between the ages of 13 and 16?
23 laundering... Unfortunately! would like to 23 MR. PIKE: Same objections, with the
24 answer each question, but I can't today. 24 additional objection of vague and
25 Q Isn't it true that while you were 25 confusing.
115 117
1 masturbating you inserted your fingers into her 1 A Since your firm has been involved --
2 14-year old 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 L.M.'s
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 7 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 I must assert
10 of your questions today, Mr. Edwards, my counsel 10 my Fifth, Sixth and Fourteenth Amendment rights
11 has told me 1 cannot answer any questions that 11 under the U.S. Constitution or potentially risk
12 maybe relevant to this lawsuit. The fact that 12 losing effective representation.
13 your firm has been accused of major fraud, the 13 Q In addition to the sexual abuse directed
14 largest fraud in South Florida history, by the 14 against= that I've just described, Isn't It
15 U.S. Attorney calling your firm a criminal 15 true that you also paid her money to bring you
16 enterprise involved in money laundering — I 16 more than 50 other underage minor females for you
17 believe it is racketeering, but 1could be 17 to similarly abuse?
18 wrong... Monetary transactions via fraud, mail 18 MR. PIKE: Same objections.
19 fraud, conspiracy — sorry —I would like to 19 A Though I believe in her own swum
20 answer your questions but today on advice of 20 testimony to the U.S. government that she
21 counsel, l am going to have to assertinirights. 21 contradicts those assertions, and I'm sure maybe
22 Q Isn't it true also that while Wan 22 you'll have some explanation at trial, but the
23 14-year old rental., you masturbated to the point 23 ladies and gentlemen of the jury should know
24 of laculating while Inserting your fingers into 24 about your firm being accused by the U.S.
25 vagina? 25 Attorney of perpetrating one of the largest
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1 frauds in U.S. history by crafting malicious 1 described as one of the largest frauds in South
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 I'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 Q Each time that you digitally penetrated
6 Jaffe, my counsel says I may not and have asked 6 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 Q You keep bringing up this fraud of the 9 speculative, harassing. It assumes facts
10 former law firm known as Rothstein, Rosenfeld, 10 not in evidence, and with regard to this
11 Adler in response to my questions, so I would 11 line of questioning, the Court has already
12 like you to tell the jury at this time which 12 ruled that the demeanor in which you're
13 allegation are you now saying is fraudulent or 13 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: I'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
18 his answers. 18 are outrageous and I understand that, but
19 MR. PIKE: Same objections. 19 they have to be asked.
20 Q Do you understand the question? 20 MR. PIKE: Maybe the demeanor and tone
21 A No. 21 of your question is laced in a manner that
22 Q You made reference to — in response to 22 it is proper for the video, but the content
23 my questions about what you did sexually to 23 of the question is the same exact harassing
24 24 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 Q -- 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
4 which allegations that is making against you 4 his answer will be, but what I'm saying is:
5 are you disputing at this time or calling a fraud 5 could you rephrase the question?
6 or calling untrue? 6 Q Answer that question. I'll work on
7 MR. PIKE: Confusing, compound and — if 7 rephrasing it for you at some point.
the court reporter would read back Mr. 8 A Sorry, I forgot what the question is by
9 Epstein's response, I think you will see the 9 now.
10 way you just phrased the question 10 Q Isn't It true that each time that you
11 mischaracterizes his testimony. Because -- 11 interacted withIMI sexually, meaning digitally
12 well, I'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 WITNESS: Sorry?
16 MR. PIKE: Mischaracterizes the 16 MR. PIKE: Form. Go ahead.
17 witness's testimony. 17 A I would like to answer each one of your
18 A own statements contradict every 18 questions here today. However, my attorneys have
19 one of your allegations that you've made to me 19 counseled me that today I have to assert my Fifth
20 today, as a hypothetical. In her own words. And 20 Amendment, Sixth Amendment and Fourteenth
21 you -- and the potential reasons this concerns me 21 Amendment rights under the U.S. Constitution and
22 is the fact that the law firm that represented 22 I'm cognizant of the fact that your firm has
23 and two others have been accused by the U.S. 23 crafted these malicious lawsuits, it has been
24 Attorney of fraudulently producing cases against 24 reported that the lawsuits are of a sexual
25 me and others, to fleece investors in what he's 25 nature, in order to fleece investors, so though I
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1 would 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. Pm simply
3 counsel's advice. 3 going to instruct the witness not to answer
4 Q Isn't It true that for each underage 4 that question because... I don't understand
5 minor that= brought to you for the purposes 5 it. I don't know what to say about that
6 of you engaging in sexual activity, you paid her 6 question.
7 5200? 7 A (Gesturing.)
8 MR. PIKE: Objection, speculation. 8 Q All of the things that I've told 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 lacks predicate. 10 she was underage, you paying her for sexual
11 A Though I would like to answer that 11 conduct, those are all things that really
12 question, as most of your other questions here 12 happened, there is nothing about that, that
13 today, Mr. Edwards, I intend to respond, 13 anybody has fabricated or made up, is there?
14 hopefully at some point to all of your questions, 14 MR. PIKE: Objection, argumentative,
15 but today my attorneys have advised me I must 15 speculative, it assumes facts not in
16 invoke my Sixth Amendment, Fifth Amendment and 16 evidence, it certainly mischaracterizes the
17 Fourteenth Amendment right under the U.S. 17 witness's testimony all day, since I have
18 Constitution. 18 been here, and I have been here the whole
19 Q Over the course of relatively a roughly 19 time. It assumes facts not in evidence. It
20 three years, isn't it true that you touched or 20 is also overbroad and substantially compound
21 fondle in a sexual manner on more than 50 21 because you're attempting to incopmate all
22 occasions? 22 of your questions today into one question.
23 MR. PIKE: Objection, argumentative. 23 MR. EDWARDS: I think you know, Mr.
24 Calls for speculation. It is overbroad, 24 Pike, your objection should be limited to
25 confusing and vague, and it assumes facts 25 the fonn. If you object to the form it is
123 125
1 not in evidence. 1 fine.
2 A Could you repeat the question forme? 2 MR. PIKE: I'm sorry, that's -
3 I'm sorry, Mr. Edwards. 3 MR. EDWARDS: You —
4 Yes. The three-year period betwee 4 MR. PIKE: You've asked me several times
when you were engaging In sexual conduct 5 today to tell you why. I thought I was
6 wit isn't it true that that conduct took 6 helping. Fm sorry. I certainly will keep
7 place on more than 50 occasions? 7 objecting to
MR. PIKE: Same objection 8 MR. EDWARDS: Appreciate it.
9 A I believe if you read your own client's 9 MR. PIKE: — the form.
10 FBI statements, what her statement it changed 10 MR. EDWARDS: Thank you.
11 dramatically after she decided to file a 11 Q And your answer is?
12 different lawsuit, at the request of you and your 12 A Repeat the question.
13 firm, with one of your firms — there have been 13 Q Every single allegation that. has
14 many firms it seems, was accused ofmajor fraud. 14 nude and I have now questioned vou about in terns
15 Since the testimony has changed dramatically, I 15 of your sexual Involvement within they are
16 would like to answer those questions, but today 16 all 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 18 correct?
19 and my Fourteenth Amendment right. 19 MR. PIKE: Objection, argumentative,
20 Q ** Your answers are not going to 20 speculative, compound. It is vague,
21 incriminate you if the answer is "no," it is only 21 overbroad —
22 if the answer is "yes" that it wi0 incriminate 22 MR. EDWARDS: You're objecting to form?
23 you, so aren't you telling the jury every single 23 MR. PIKE: Yes, assumes facts not in
24 thing I've asked you is not part of a fraud, just 24 evidence and lacks predicate. That is
25 happens to be true, isn't it? 25 Conn.
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1 A And I would like to answer that question 1 MR. EDWARDS: It is not a responsive
2 specifically 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: Well move to strike it.
5 Fourteenth Amendment rights under the U.S. 5 Let's have an answer to the question.
6 Constitution, keeping well aware of your firm's 6 MR. PIKE: The witness is trying. If
7 responsibility in the largest fraud in Florida's 7 there is a legal basis for your moving to
history by crafting sexually charged lawsuits 8 strike, it would be taken up with the Court
9 against people like me and others. 9 and you can move to strile.
10 I believe in addition, since ha 10 You can continue.
11 allegations, as you've phrased them, have changed 11 MR. EDWARDS: Strike it, it is
12 dramatically since her sworn statement, until in 12 nonresponsive?
13 fact, after she joined this firm charged with 13 A Your allegations thatiarkeep throwing
3.4 this major fraud and most of her statements have 14 at me, relate to the fact that= testimony,
15 changed, I believe, so... 15 after giving a sworn statement to the FBI,
16 Q You re r when-became pregnant 16 changed dramatically after she decided to file a
17 when she wa ears old, don't you? 17 lawsuit for money, joining your firm that's been
18 MR. PIKE: Form, relevance, move to 18 accused by the U.S. Attorney ofono 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
21 questions here today, Mr. Edwards; each and every 21 advice of counsel today I must assert my Fifth
22 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:iris under the U.S. Constitution.
24 Fourteenth Amendment and Fifth Amendment rights 24 Q Whe was a pregnant.year-old,
25 under the U.S. Constitution. 25 she brought you at least ten underage minor
127 129
1 Q Isn't It true that when was 14 1 females during 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
4 A Separate from the fact that in ha own 4 not in evidence and lacks predicate.
5 testimony, her own sworn testimony under oath 5 A I —I —I unfortunately would like to
6 before she decided to file a lawsuit 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
10 that I must assert my Sixth Amendment, Fifth 10 Amendment rights the U.S. titution.
11 Amendment and Fourteenth Amendment rights under 11 Q After had her son a ears old,
12 the U.S. Constitution. 12 and you were being criminally hives 'gated for
13 Q Isn't it true when she became pregnant 13 some of the conduct that we've discussed here
14 at ageMou no longer interacted with her 14 today; isn't it true that you personally hired
15 sexually but still demanded that she bring you 15 and retained and paid for an attorney to
16 other underage minor females for you to sexually 16 representM
17 exploit? 17 MR. PIKE: Objection, speculation --
18 MR. PIKE: Objection, speculation. 18 MR. EDWARDS: Object to the form, Mr.
19 Compound. Harassing, and assumes facts not 19 Pike.
20 in evidence. 20 MR. PIKE: I will not. I am allowed to
21 A I believe her testimony changed 21 assert the basis for my objections, I am not
22 dramatically from her sworn statements to the 22 limited to just saying "form? I'm able to
23 FBI 23 assert the basis as to why, so I don't waive
24 Q That's not a responsive — 24 that basis.
25 MR. PIKE: Excuse me 25 MR. EDWARDS: It is just more of this
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1 obstructionist -- 1 THE WITNESS: Ready? Thank you.
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 will be finished within four seconds. So THE VIDEOGRAPHER: Back on the video
6 am going to object to form, it's 6 record 2:50 p.m.
7 argumentative, speculative and it assumes 7 Q Isn't it true, Mr. Epstein, that you
facts not in evidence and it lacks B gave= money to coerce her into interacting
9 predicate. That's it. 9 with you sexually?
10 A I'm sorry. (Witness shrugs.) Again? 10 A Mr. Edwards, I would like to answer each
11 Q The response to the question. 11 and every one of your questions here today, but
12 A I don't know the question. 12 unfortunately, like I've done with mostly all of
13 Q You don't remember the question? Did 13 your other questions, I'm going to have to assert
14 you Mr= an attorney at some point In time? 14 my rights, Sixth Amendment, Fourteenth Amendment
15 Do you remember that? 15 and Fifth Amendment on advice of counsel.
16 MR. PIKE: Same objection. 16 Although I would like to answer, if I don't
17 A Not to the 17 follow my counsel's advice, I risk losing
18 Q Do you kno 18 representation.
19 A ... Do I know James Eisenberg? I don't 19 Q White committing these sexual acts
20 believe I've ever met James Eisenberg. 20 against= when she was Just a minor, you knew
21 Q Is It your testimony today then that ou 21 it would psychologically damage her, Isn't that
22 never paid for an attorney to represen 22 true?
23 A (Witness shakes head.)... On advice of 23 MR. PIKE: Form, lacks predicate,
24 my counsel, I would like to answer that question, 24 speculation.
25 but on advice of counsel I'm going to have to 25 A I intend to respond at some point to —
131 133
1 assert my Sixth Amendment, Fourteenth Amendment 1 I would like 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 counsel
3 Sixth Amendment rights of the U.S. Constitution. 3 they've required me to assert my Fifth Amendment,
4 Q And that attorney that was paid for by 4 Sixth Amendment and Fourteenth Amendment rights
5 yoµ Informed= that if she were to teU the 5 under the U.S. Constitution, though I would like
6 FBI 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 Q In fact, you deliberately and
8 that, correct? 8 intentionally caused severe emotionally distress
9 MR. PIKE: Same objections. 9 to underage minor females, including.' Isn't
10 A I recognize, I believe she made one of 10 that true?
11 the statements at her deposition after she 11 MR. PIKE: Objection, argumentative,
12 decided to sue me for a bunch of money and your 12 speculation, it is compound. And it assumes
13 film has represented a number of... cases of a 13 facts not in evidence.
14 sexually charged nature that turned out to be 14 MR. EDWARDS: Okay.
15 fraudulent in order to fleece local investors. 15 A I would like to answer that question, as
16 The U.S. Attorney described your firm and these 16 I would like to answer all siflaur other
17 cases as a bogus scheme, and I'm aware of that, 17 questions today regarding= However, my
18 and would like to answer your question in more 18 attorneys today have advised me that I must
19 detail today, Mr. Edwards; however my attorneys 19 assert my Sixth Amendment right to effective
20 advised me that at least today, I must assert my 20 representation and my Fifth Amendment right and
21 rights under the Sixth Amendment Fourteenth 21 my Fourteenth Amendment right. Though I would
22 Amendment and Fifth Amendment. 22 like to answer that with specificity, I must
23 MR. PIKE: It is the food. 23 follow my attorney's advice.
24 MR. JAFFE: I didn't want him in the 24 Q Will you admit for the jury that you
25 room in mid answer. 25 were investigated federally for your Illegal
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activities with underage minors? 1 Graff or . Can you explain to
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. PIKE: Object to the form of the
5 here today, especially since your firm has been 5 question?
6 accused by the federal, I guess, the federal 6 A I would like to answer that question,
7 government,... 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, Fifth Amendment and
9 being a criminal enterprise using sexually 9 Fourteenth Amendment rights under the U.S.
10 fabricated, sexual cases... fabricated cases, to 10 Constitution.
11 fleece investors out of millions of dollars, but 11 Q Isn't It fair to say that you, as well
12 I would like to answer your questions; however my 12 as the co-conspirators, operated as an organized
13 attorneys have demanded that I assert my rights 13 criminal enterprise designed to sexually exploit
14 under the Sixth Amendment, Fifth Amendment and 14 underage minors?
15 Fourteenth Amendment. 15 MR. PIKE: Object to argumentative,
16 Q In fact, as a result of that 16 speculation. It is vague and it assumes
17 investigation, you, as well as the United States 17 facts not in evidence.
18 Attorney's Office entered Into what has now been 18 A Are you suggesting it was a criminal
19 known and referred to as the nonprosecution 19 enterprise? Is that the words?
29 agreement; isn't that correct? 20 Q Yes.
21 MR. PIKE; Same objection. The document 21 A Though I would like to answer that
22 speaks for itself? 22 question today, I think the only criminal
23 A You have to repeat the question. 23 enterprise that I have been reading about today
24 Q Asa result of the criminal 24 was your firm, that's been accused of being a
25 investigation into your activities with minor 25 criminal enterprise involved in defrauding
135 137
1 females, you reached a resolution with the United 1 people, 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 U.S. Attorney (indicating), but
4 that correct? 4 though I would like to answer your questions with
S MR PIKE: I'm going to object. Vague, 5 specificity today, on advice of counsel, though I
confining, misrepresents the agreement and 6 would like to answer it, they demanded I assert
7 the document is the best evidence. Will you 7 my Sixth Amendment, Fourteenth Amendment and
8 mark it? 8 Fifth Amendment right or I risk losing their
MR. EDWARDS: I can mark it. We will 9 representation.
10 copy it at the end and manic it as Exhibit 2. 10 Q Did you care about any of the underage
11 (Document, Nonprosecution Agreement, was 11 minor females at the time when you were engaging
12 deemed narked as Exhibit number 2 for 12 In sexual conduct with them?
13 identification, as of this date.) 13 MR. PIKE: Objection, argumentative.
14 A Yes. 14 Harassing, already been ruled upon by the
IS Q In that agreement, there are listed 15 Court relative to this exact question.
16 co-conspirators of Jeffr stein, those being 16 MR. EDWARDS: I feel comfortable with
17 Leslie Graff 17 the question. It goes to punitive damages.
18 (phonetic) and . Can you explain 18 The issue related to the Court was a
19 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 subject matter. I'm just
21 the federal government? 21 asking for Mr. Epstein to tell the jury how
22 A Co-conspirators? 22 he felt about these girls, whether he cared
23 Q Yes, it says "criminal charges against 23 about them, when he was engaging in illegal
24 any co-conspirators of Epstein including but not 24 sexual conduct with them.
25 limited to Leslie 25 MR. PIKE: Counsel, I'm going to
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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 Fifth Amendments of the
4 be; however you're attempting to lace this 4 U.S. Constitution, or else I risk losing their
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 cane 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 10 more than happy to let him respond.
11 withdraw the question, that's fine. 13. MR. EDWARDS: i don't remember the
12 MR. EDWARDS: I don't want to withdraw 12 question we will take it up with the Court
13 the question. 13 and we'll get a ruling on it.
14 MR. PIKE: Then I instruct him not to 14 MR. PIKE: It was whether or not he
15 answer. 15 cared about these i believe you quoted it
16 MR. EDWARDS: Mark that somehow, that 16 as underage minors, but I would like the
17 page, so we can fmd it in the record, 3.7 court reporter to read back the question
3.8 relative to the hearing that will be had on 18 just to conserve judicial resources and not
19 that question and others similar. 19 go back. So if she can reread the question
20 Q At the time when you were engaging in 20 that would be good.
21 sexual conduct with underage females, you knew 21 MR EDWARDS: If you can find the
22 that exposing them to this, was not beneficial or 22 question.
23 good for these girls; isn't that true? 23 THE COURT REPORTER: Certainly.
24 MR. PiKE: Objection, argumentative, 24 MR. EDWARDS: I think I know it
25 speculation, =tunes facts not in evidence. 25 Q 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, like most of your other questions here 3 sexual activities?
4 today, on advice of counsel I must assert my 4 MR. PIKE: Same objections, as before.
5 Fourteenth Amendment, Fifth Amendment and Sixth 5 A Though I would like to answer that
6 Amendment rights. Though I would like to answer, 6 question as well as most of your other questions,
7 if I do so, I visit losing my effective 7 if not all of your other questions here today, on
8 representation of counsel. 8 advice of counsel I will have to assert my
9 Q Isn't It true, Mr. Epstein. that the 9 Fourteenth Amendment right my Sixth Amendment
10 only thing that you cared about was accessing as 10 right and my Fifth An not right, because no
11 many underage females as possible. for the 11 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
13 MR. PiKE: Argumentative, speculation, 13 representation.
14 harassing. 14 Q At the time you were engaging in sexual
15 A What's the question? 15 activity with these underage minors, including
16 MR. PIKE: And assumes facts not in 16 you knew that this conduct was illegal,
17 evidence. 17 didn't you?
18 Q Isn't It true that the only thing that Is ME. PIKE: Same objections. Form.
19 you cared about when you were interacting with 19 A I would like to answer that question, as
20 these underage females in a sexual manner, was 20 well as most of your other questions here today,
21 ejaculating or your own personal gratification? 21 however, today my counsel has instructed me to
22 MR. PIKE: Sam, same exact objections. 22 assert my Fourteenth Amendment, Sixth Amendment
23 A Though I would like to answer that 23 and Fifth Amendment right, and ifI do not, and
24 question, and to the ladies and gentlemen of the 24 if, in fact, I answer that question if I can
25 jury, I would very much like to answer that 25 answer that question, I potentially risk losing
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1 my effective counsel's representation. 1 testimony — to the FBI. You watched her
2 Q In fact, you told many of these underage 2 deposition when it was being taken. Which —
3 minor females not to tell anybody what happened 3 A You're nuking 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: Sorry.
6 MIt PIKE: Fenn 6 A My fault
7 A I would like to answer that question, as 7 MR. PIKE: Then Ill object and you'll
8 well as the other questions; however, my counsel 8 respond.
9 has advised me that today I must assert my 9 Q Which are you saying is the truthful
10 Fourteenth Amendment, Sixth Amendment and Fifth 10 testimony, her statement to the FBI or the
11 Amendment rights under the U.S. Constitution. 11 videotaped deposition that you watched?
12 Q The underage minor females that have 12 MR. PUCE: Object to the Conn
13 come forward with information about your sexual 13 A What I've said, and I think repeat
14 interactions with them have been investigated, 14 myself is until she joined your firm and started
15 harassed, humiliated in an effort for you to 15 to seek money, her testimony was different.
16 intimidate them to go away. Is that true? 16 That's my understanding.
17 MIt PIKE: Objection. Argumentative, 17 Q Are you denying any sexual Involvement
18 speculative, compound. It is overbroad, and 18 with= at this time?
19 assumes facts not in evidence. 19 MR. PIKE: Form
20 A Can you repeat the question? 20 A I would Wee to answer that question. I
21 Q Sure. Any underage minor female that 21 would like to answer it as with most of your
22 you engaged in sexual activity with, that has now 22 questions here today, however, my attorneys have
23 pursued a lawsuit against you, isn't it true that 23 advised me that I must take that — assert my
24 you've spent a lot of money and a lot of 24 rights under the Sixth Amendment, Fourteenth
25 resources Investigating them in an effort to 25 Arnmdment and Fifth Amendment, no natter how much
143 145
1 intimidate them and hopefully make them go away? 1 I would like to answer that question, or
2 MR. PIKE: Same objections. 2 potentially risk losing my counsel.
3 A I believe your client's testimony 3 Q Isn't your game plan with all of these
4 changed dramatically when she joined up with you 4 civil lawsuits that have been tiled against you,
5 and your law firm, 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 dropping the lawsuits against you?
to the FBI, and decided to seek money. However, a MR. PIKE: Objection. Relevance. Move
9 anything above that or beyond that, I'm going to to strike. It is argumentative and
10 have to, in fact, assert my Fifth Amendment, 10 harassing.
11 Sixth Amendment and Fourteenth Amendment rights 11 A I would like to answer that question. I
12 as directed by my competent counsel. 12 think you know the answer to that question.
13 Unfortunately, they have told me if I daft, I 13 Q Yes.
14 risk losing their representation. 14 A (Witness nods.) However, today my
15 Q All right, I'll give you a chance here 15 attorneys have advised me I must assert my Sixth
16 since you keep bringing up her statement to the 16 Amendment rights, my Fourteenth Amendment rights
17 FBI as opposed to her sworn testimony for 13 17 and my Fifth Amendment rights.
18 hours under oath in this case. Are you saying 18 Q You don't have any remorse for the
19 that the sworn testimony to the FBI was, in fact, 19 sexual abuse that you committed againstM, do
20 the truth? 20 you?
21 A What I'm saying is, it seems ha 21 MR. PIKE: Objection. It is
22 testimony has changed dramatically after she 22 argumentative. It is harassing. It is, I
23 joined your finn, that's all. 23 believe, confined under the Judge's order
24 Q Okay. Irrespective of her testimony, 24 and it assumes facts not in evidence?
25 you've read her testimony and you read her 25 A 'prat being said, would like to answer
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1 that question today, but my attorneys have 1 Q ** But as it relates to, obviously-
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 13 tan old to
4 my Sixth Amendment righ 4
5 Q In fact, you recently didn't
6 you? 6
7 A Yes, and you and your firm that's been
8 accused of the largest fraud in Florida's 8
9 history. described by the U.S. Attorney as a 9
10 criminal enterprise involved in money laundering, 10
11 conspiracy to commit one crime excuse me, mail 11
12 fraud, mmit wire fraud. 12 O
13 Yes, 13 answer that question, for the same reasons
14 Q ** Tell the jury — 14 stated.
15 A Yes. 15 MR. EDWARDS: Let's mark that.
16 16 Q Is it your feeling that because you are
17 17 wealthy and these children are poor, that you are
18 18 entitled to sexually abuse them?
19 MR. PIKE: I'm going to instruct the 19 MR. PIKE: Argumentative.
20 witness not to answer that question in this 20 Q In speaking about these children, and
21 medium, as it is wholly irrelevant 21 indnding
22 currently, as were it, to this particular 22 MR. PIKE: Argumentative, speculation,
23 lawsuit. 23 compound, it's vague, and it assumes facts
24 MR. EDWARDS: lust so you can rethink 24 not in evidence.
25 that position, the lack of remorse goes to 25 A In keeping with your firm's propensity
147 149
1 punitive damages, that is an aspect of the 1 for filing fellacious (sic), manufactured,
2 case that 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 U.S. Attorney of the largest
4 tein is noticed for 4 fraud in South Florida's history, by
5 S manufacturing sexual cases, I would like to
6 6 answer each and every one of your questions,
7 is not proper for this 7 including why I sued you, but today I'm not going
8 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 position. 10 Amendment and Fifth Amendment right.
11 MR PIKE: — in that regard, I'm going 11 Q This answer that you keep reciting,
12 to instruct him not to answer any questions 12 about the Rothstein, Rosenfeld, Adler firm —
13 relative to that lawsuit because of that 13 A You do know who they are, right?
14 objection, as well as, it is m 14 Q — you are aware, obviously, that all of
15 15 the lawsuits that were filed against you,
16 16 including, were tiled at least a year
17 17 before, or approximately a year before Rothstein,
18 18 Rosenfeld, Adler had any of these cases; you're
19 19 aware of that, right?
20 20 MR. PIKE: Form.
21 21 A I do not know when Rothstein Adler got
22 22 involved in these cases. I do know that the
23 MR EDWARDS: I understand your position 23 moment that they did surface, and, in fact, I
24 completely, Mr. Pike. 24 understand you shared information with all the
25 MR PIKE: Thank you. 25 other attorneys that you so — that the jury
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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 filed 4 Q she was in your bedroom. You
5 cases against me; yes, I'm aware of that. instructed her to get naked. You inserted your
6 Q I don't understand that answer. Steven, 6 fingers 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 claims that have amounted
10 his answer was. As in all depositions, if 10 to various counts, coercion, prostitution,
11 you don't understand the answer, clarify the 11 intentional infliction 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. 14 arc "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. 16 how to provide this case to the jury, what are
17 MR. PIKE: The witness has answered the 17 your defenses to t►ese allegations?
18 question. Do you have another question to 18 MR. PIKE: I'm going to object to this
19 clarify his answer? 19 line of questioning. It is compound; as
20 MR EDWARDS: Yes. 20 worded it could call for disclosure of
21 Q Please clarify your answer. 21 attorney/client information as well as work
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 filed, answer in
24 narrative. 24 affirmative defenses, and the affirmative
25 MR. EDWARDS: Me saying "clarify your 25 defenses are set forth there and the
151 153
answer" is narrative? 1 document there speaks for itself.
2 MR. PIKE: What do you mean by "clarify 2 MR. EDWARDS: Okay.
3 your answer? 3 Q Respond.
4 MR. EDWARDS: I didn't hear what he 4 A The document speaks for itself.
5 said. Say it again so I can hear it. 5 Q ** So you agree with the affirmative
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
10 MR. EDWARDS: Okay. 10 testified. The winless testified that the
11 MR. PIKE: It was an answer, a 11 document speaks for itself, and again, I'm
12 question — 12 going to object to attomey/clicnt, work
13 MR. EDWARDS: I understand -- I mean I 13 product and instruct the witness not to
14 don't understand the answer, but now I know 14 answer.
15 the answer. 15 Q I'm not asking what your legal defense
16 MR. PIKE: Okay. 16 Is. I'm asking: What is your response to the
17 Q At this point in time, please tell the 17 claims?
18 Jury what is your defense of the claims being 18 MR. PIKE: Same objection.
19 asserted against you in this lawsuit by-7 19 Q What Is your personal response?
20 MR. PIKE: I'm going to object. Calls 20 A I would like to respond to that
21 for a legal conclusion. 21 question. I would like to respond today to that
22 A What are the claims? So since you're 22 question; however, today my attorneys have told
23 representing can you tell me what the 23 me that I cannot respond. They've asked me to
24 claims are? 24 assert my Fourteenth Amendment, Sixth Amendment
25 Q Yes, we've gone through it. She went to 25 and Fifth Amendment rights of the US.
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1 Constitution, though I would really like to 1 A (Laughter.)... Did I tell... 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, 1must — as I have done with
4 Q I know you've invoked your Fifth 4 mostly each one of your questions, I have to
3 Amendment rights related to many of these 5 assert my Fifth Amendment, Sixth Amendment and
6 question 6 Fourteenth Amendment rights under the U.S.
7 contacte 7 Constitution.
a and spoke to him about case as well as 8 Q You were 51 when was 14, and you
several of the other girls, who have claims 9 were interacting with her sexually. Is it your
10 against you? 10 testimony that despite the disparity in age you
11 11 do not consider= to be a victim?
12 12 MR. PIKE: Argumentative, speculation,
13 A Can you repeat the question? 13 assumes facts not in evidence. Compound,
14 Q Dlda 14 lacks predicate.
15 year, coma 15 A Not only does it contradict your own
16
17 II and discuss these cases that have been filed
against you and the allegations made by these
16
17
client's statements to the FBI under sworn
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,
21 but unfortunately today my attorneys have advised 21 Fifth Amendment and Fourteenth Amendment rights.
22 me I cannot. They've advised me I must assert my 22 Q In the last ten years, what is the
23 Sixteenth — excuse me, my Fourteenth Amendment, 23 youngest underage minor female that you have
24 Sixth Amendment and Fifth Might, so 24 interacted with sexually?
25 therefore, I will do so. 25 MR. PIKE: Argumentative, speculation,
155 157
1 i li aWhy Is it that you will talk tiM 1 assumes facts not in evidence.
2 bout this but you will not talk to the Jury 2 A The answer to that question is — I
3 a out this? 3 would like to give you an answer to that today,
4 MR. PIKE: Form. Argumentative, 4 but my attorneys have advised me I must assert my
S 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.
7 assumes facts not in evidence and now lacks 7 Q Do you know Michael Friedman?
8 predicate. A Doesn't ring a bell.
9 A 9 Q Former housekeeper/employee of yours,
10 10 worked at the Palm Beach house?
11 Did you not talk to him? If you 11 A ... Could. Don't know.
12 didn't talk to him, tell me that. That's fine. 12 Q So you would be unable to answer what
13 MR. PIKE: Some objections. 13 Michael Friedman did for you?
14 A I would like to tell you answers to each 14 A Yes.
15 one of your questions, however today my attorneys 15 Q Are you aware that our investigator
16 have demanded that I respond by asserting my 16 spoke with Michael Friedman, former housekeeper
17 Fourteenth Amendment, Sixth Amendment, Fifth 17 for you, or housemanager for you, out in
18 Amendment privilege, though I would like to 18 California?
19 respond, but they said if I do so, I risk losing 19 A No.
20 their representation. 20 Q Any reason why when asked about the
21 Q Didn't you te 21 activity that occurred in your house, he would
22 underage minors were not victims at all and that 22 tear up and say, "I was hoping to forget
23 regardless of their age, you did not personally 23 everything I saw"?
24 consider them victims? 24 MR. PIKE: Objection, argumentative.
25 MR. PIKE: Same objection. 25 Speculative, Assumes facts not in
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1 evidence. 1 Q During this civil discovery and
2 A Again, the question? 2 litigation —
3 Q Is there any reason that when asked 3 A Um-hum?
A I don't know who he is. 4 Q -• have you paid for, and/or retained an
5 MR. PIKE: Also, hearsay. 5 attorney for any other witnesses?
6 THE VIDEOGRAPHER: Counsel? 6 A Any other witnesses?
7 MR. EDWARDS: Go ahead. 7 Q Yes, like I'll give you an example that
THE VIDEOGRAPHER: Going off the video 8 you may, just to refresh your recollection or
9 record 3:23 p.m. 9 tell you what I'm talking about
10 (Pause in the proceedings.) 10 you know who that is, right?
11 THE VIDEOGRAPHER: Back on the video 11 A Yes.
12 record 3:30 p.m. 12 Q She is someone to works for you now,
13 Q 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 Q 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
19 that person is, or still no real memory of him at 19 and Fifth.
20 all? 20 Q That somebody who has informed us that
21 A No real memory. 21 you paid for and obtained an attorney by the name
22 Q To the best of your knowledge, he never 22 of Bruce Reinhart to represent her during this
23 worked for you? 23 process. Is that —
24 MR. PIKE: Form. 24 MR. PIKE: Form.
25 A Not that I can recall, but there are 25 A I have to assert my Fifth Amendment,
159 161
1 lots of people who work for me, so... 1 Sixth Amendment and Fourteenth Amendment, right.
2 Q Can you tell the jury who the various 2 Q 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,
5 already. 5 Janusz Banaziak
6 Q In that you invoked your Fifth 6 Ghislaine Maxwell your brother, Mark Epstein,
7 Amendment, correct? 7 Larry Visoski, Larry
8 A That's correct, Sixth Amendment and 8 Morrson, David Rogers, Igor linovkw. Have I
9 Fourteenth Amendment. 9 missed anybody else that during this litigation
10 Q Eigthteen and twenty-first? 10 you've paid for or retained attorneys?
11 A (Witness shrugs.) 11 MR PIKE: Form, same objection.
12 MR, PIKE: Move to strike. 12 A I'm not clear. Are you suggesting I've
13 Q ** Have you, during this litigation and 13 paid for attorneys for all these people?
14 by "this litigation." I don't only mea 14 Q Yes.
15 case, but the various other lawsuits that have 15 A (Laughter,) I would like to answer those
16 been filed against you by other females alleging 16 questions today, but on the advice of counsel I
17 sexual misconduct by you against them. Who have 17 have to invoke my Sixth Amendment, Fifth
18 you retained attorneys for, what witnesses have 18 Amendment and Fourteenth Amendment tight
19 you retained attorneys for? 19 Q If you have not, tell me which of those
20 MR. PIKE: Object to the form. 20 on that list that you have not paid for or
21 MR. EDWARDS: Okay. 21 retained attorneys for?
22 MR- PIKE: ill instruct him not to 22 MR. PIKE: Same objection.
23 answer because I don't understand the 23 A Same answer.
24 question. Okay? 24 Q You're invoking your Fifth Amendment,
25 MR. EDWARDS: All right 25 right?
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1 A And Sixth Amendment and Fourteenth 1 Q If me narrowing down will help you to
2 Amendment... and Fifth Amendment 2 respond, l will. Is there any need for that?
3 Q ** Is it a company or Is It you, 3 A (Witness shakes head.)
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 Q 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 MR. PIKE: Same objection.
9 it is vague also. 9 A I would like to answer that question,
10 Q Who Is writing the check to your 10 but today my counsel has advised me I must invoke
11 attorneys for your representation in this 11 the rights of the Sixth Amendment, the Fourteenth
12 lawsuit? 12 Amendment and the Fifth Amendment of the U.S.
13 A (No response.) 13 Constitution.
14 Q Who Is paying the bill? 14 Q Are you currently treating with a
15 A I believe I am. 15 psychologist related to any sex addiction that
16 Q And is it you, personally, or is this 16 you have with minors?
17 one of your corporations or companies? 17 A I would like to answer that question, as
18 MR. PIKE: Form, speculation. 18 well, as most of the other... questions you've
19 A I'm not sure. 19 asked me today, however, on advice of counsel
20 Q As you sit here today, you're not really 20 theyve asked me to invoke my Sixth Amendment,
21 sure whether it Is coming from one of the other 21 Fourteenth Amendment and Fifth Amendment right,
22 corporations that we've discovered during 22 therefore, though I would like to answer that
23 discovery or it is coming from you, personally? 23 question, as well as the other ones, I risk
24 Is that correct? 24 losing the representation if I do so.
25 MIt PIKE: Asked and answered. 25 MR. PIKE: Moreover I'm going to object
163 165
1 A I believe — I would like to answer but 1 to relevance as I have in the past since Mr.
2 I have to invoke my Sixth, Fourteenth and Fifth 2 Epstein's medical history is not at issue in
3 Amendment rights. 3 this case; under the legal terms.
4 Q As It relates to any of the other 4 Q You would agree, wouldn't you, that you
5 witnesses who have had attorneys retained for 5 targeted these underage girls including_
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 like to answer that question, as
10 A I would like to answer those questions, 10 well as most of the other questions you've asked
11 but today my attorneys have asked me not to 11 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 lawsuit, so I must follow their advice and 13 Amendment and Fifth Amendment right. Though I
14 invoke the Sixth Amendment, Fifth Amendment and 14 would like to answer those questions today... if
15 Fourteenth Amendment, right. 15 I do so, I risk losing their representation.
16 Q Have you interacted sexually with any 16 Q You would also agree, wouldn't you, that
17 underage minors in the last year, while on house 17 you targeted these underage females for sex.
18 arrest or work release from jail? 18 IncludIng=, because they were poor?
19 MR. PIKE: Objection. Argumentative and 19 MR. PIKE: Same objections.
20 compound and lacks predicate. 20 A I would like to answer that question. I
21 A I would like to answer that question, 21 would really like to answer that question, as
22 but on advice of counsel, at least today, theyve 22 well as the other questions you've asked me here
23 advised me I must invoke my Sixth Amendment, 23 today, however, on advice of my counsel theyve
24 Fourteenth and Fifth Amendment right. 24 demanded that I assert my Fifth Amendment, Sixth
25 MIt PIKE: It is also overbroad. 25 Amendment and Fourteenth Amendment rights. If I
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1 answer that question, i risk losing their 1 today; however, my counsel has advised me that 1
2 representation. 2 must assert my Fourteenth Amendment rights, my
3 Q You would agree, wouldn't you, that you 3 Sixth Amendment rights and my Fifth Amendment
4 sexually molested..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 losing their
6 A I think you've asked me that question 6 representation.
7 before. I assert the same rights as before. 7 THE WITNESS: Can we take a ton-minute
8 Q 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 IS minutes and
10 A Yes. 10 we're done.
11 Q You would agree, wouldn't you, that you 11 THE WITNESS: Continue then?
12 coerced into prostitution? 12 MR. EDWARDS: Okay.
13 MR. PiKE: Same objections. 13 Q Would you agree that you intentionally
14 A I believe her own testimony reflects, at 14 IndoetrinateciM foto this very deviant sexual
15 least the sworn statement to the FBI, reflects 15 lifestyle?
16 that that is not the case; and though I would 16 MR. PIKE: Okay, I'm going to object
17 like to answer that question in great detai1,1 17 It is argumentative. It is confusing. It
18 cannot do so today on advice of counsel, that 18 is speculative, vague, lacks predicate and
19 have asked me to assert my Sixth Amendment, Fifth 19 assumes facts not in evidence.
20 Amendment and Fourteenth AnICIRIIIICId rights. If 20 A And on top of that, I would like to
21 do so,1 risk losing their representation. 21 answer that question, but my counsel has advised
22 Q You would agree with me that you groomed 22 me I must assert my Fourteenth Amendment, Sixth
23 into becoming a prostitute? 23 Amendment and Fifth Amendment rights under the
24 MR. PIKE: I'm going to object. 24 U.S. Constitution. Although I would like to
25 Argumentative, speculative. Certainly lacks 25 answer all your questions today, I cannot do so
167 169
1 predicate and assumes facts not in 1 risking losing their representation.
2 evidence. 2 Q 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.
counsel I have to assort my Fourteenth Amendment, 5 A Halite?
6 Sixth Amendment and Fifth Amendment rights. if i 6
7 answer the question,1risk losing their 7 A I would like to answer that question,
a counsel. 8 and I understand how your firm has been accused
9 Q You would agree, wouldn't you, that you 9 of fabricated sexually charged lawsuits in order
10 brainwashedMinto believing that this 10 to fleece investors locally in South Florida.
11 lifestyle of prostitution was right? 11 The U.S. Attorney has called your law firm a
12 MR. PIKE: Same objections. 12 criminal enterprise based on filing fallacious
13 A I would like to answer that question, as 13 (sic) sexually charged cases. Although i would
14 most of your other questions here today, Mr. 14 like to answer that question today, Mr. Edwards,
15 Edwards. On advice of counsel today, I'm going 15 and Mr. Jaffe, my counsel has told me that I have
16 to have to assert my Fifth Amendment, Sixth 16 to assert my tights under the Sixth Amendment,
17 Amendment, Fourteenth Amendment rights. if i 17 Fifth Amendment and Fourteenth Amendment, and if
18 answer that question, I risk losing their 18 I don't do so, I risk losing their
19 representation_ 19 representation.
20 Q Would you agree that your interaction 20 Q We have a factual basis for asking every
21 witbM when she was a minor, was degrading to 21 question and making every allegation. I want to
22 her? 22 provide you with a last opportunity to tell the
23 MR. PiKE: Same objections. 23 jury which of these allegations, if any, being
24 A I would like to answer that question. I 24 made by are false or fabricated in any
25 would like to answer all of your questions here 25 way?
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1 MR. PIKE: Same objections. Mr. 1 no matter how much I would like to answer those
2 Edwards, you know the tenor of that question 2 questions, I am going to have to decline based on
3 cannot be answered without waiver of 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 Fourteenth
5 question and the semantics ofit, but it 5 Amendment rights under the U.S. Constitution;
6 is... It is -- can you rephrase it? 6 because ifl don't, I risk losing their
7 MR. EDWARDS: Yes. 7 representation.
8 Q Many tines» you know the allegations Q Is it true that you're currently worth
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 I would like to answer that question, as
11 between you and her wilguabiars 13, 14 and 15 11 I would like to answer most of your other
12 years old and you wers years old. 12 questions. I know that's a lot of money -
13 Several times you responded saying something 13 actually the amount ofmoney that the U.S.
14 about Rothstein, Rosenfeld & Adler, something 14 attorneys accused your firm of trying to steal
15 about her FBI statement, what have you; I want to 15 from the people of South Florida. It was 1.2
16 give you a chance to tell the jury, whkh of her 16 billion dollars, the U.S. Attorney claimed your
17 allegations, if any, that you believe now are 17 firm perpetrated the largest fraud in South
18 false or fabricated in any way. 18 Florida's history by stealing that sum of money
19 MR. PIKE: Same objections. 19 from local investors, based on false allegations
20 A I would like to respond to that 20 of sexually charged claims, and although I would
21 question, the fact that her firm, the law fum 21 like to answer these questions with specificity,
22 representing her has been accused by the U.S. 22 under advice of counsel today, I'm going to have
23 Attorney of being a criminal enterprise, 23 to refuse, based on my Sixth Amendment,
24 manufacturing, fabricating, out of thin air, 24 Fourteenth Amendment and Fifth Amendment right,
25 cases involving sexual allegations, sexual 25 and though I would like to answer the question,
171 173
1 allegations in order to simply fleece local 1 have been told if I do so 1 risk losing their
2 investors out ofmillions of dollars, so I would 2 representation, Mr. Edwards.
3 very much like to answer that question regarding 3 Q I'm simply asking: What Is your
4 the truthfulness of= allegations; however 4 personal net worth at this time?
5 today my counsel has told me that I must assert 5 MR. PIKE: Form.
6 my Fifth Amendment rights, Sixth Amendment tights 6 A I think I've answered the question,
7 and Fourteenth Amendment rights under the U.S. 7 but...
8 Constitution, thought would very much like to Q 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 should
10 their representation. 10 be you invoking your Fifth Amendment rights.
11 Q Would you agree you owe= at least 11 Seemed like the opposite.
12 515,000,000 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. PIKE: Objection. I move to 14 MR. EDWARDS: His answer included
15 strike. Argumentative. Compound. Lacks 15 something about Rothstein, Rosenfeld and
16 substantial predicate. Assumes... facts... 16 Adler stealing some certain amount of money,
17 not in evidence. 17 which obviously is nonresponsive, I move to
18 A As you might imagine, though your law 18 strike it and ask that he actually responds
19 firm has been accused of perpetrating a fraud 19 to the question with something that's
20 involving millions and millions of dollars, on 20 responsive. He can answer the question,
21 unsuspecting investors here in South Florida, 21 invoke Fifth Amendment tights, and we will
22 millions of dollars by fabricating similar 22 get out of here.
23 allegations, convincing people to give money to 23 Q We will start over again.
24 the firm that helped bring this lawsuit, I'm 24 Can you please tell the jury what your
25 afraid 1 would like to answer those questions but 25 current personal net worth is currently?
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1 A i would like to do that today, however, 1 Though i would like to answer with specificity,
2 Fm sure that one of the reasons, since your firm 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 lights under
4 from local investors based on fabricated, totally 4 Sixth, Fifth and Fourteenth Amendment.
5 fabricated claims, this is not by me but the U.S. 5 Q Isn't it true, Mr. Epstein, that as long
6 Attorney, has called your firma criminal 6 as you have the money to do It, you will continue
7 enterprise charged with stealing hundreds of 7 to engage in sex with 'ninon?
8 millions of dollars frankly, from local 8 MR. PIKE: Again, extremely
9 investors, based on false claims of sexually 9 argumentative, speculative. Fm allowing
10 charged nature, I would like to answer that 10 the question to give leeway, so we don't
11 question in detail. However, my attorneys have 11 have to come back here again. it is
12 advised me i cannot answer any questions that may 12 harassing.
13 be relevant to this lawsuit and by doing so, I 13 A And with that, Pm sure this -- ladies
14 must invoke my Sixth Amendment, Fifth Amendment, 14 and gentlemen of the jury, be able to see
15 Fourteenth Amendment right and by answering the 15 you and your partner, who your firm has been
16 question, i risk losing their representation. 16 accused of massive fraud in South Florida trying
17 Q Is it true you're worth 1.8 billion 17 to steal hundreds of millions of dollars from
18 dollars? 18 local investors, from creating, fabricating
19 MR. PIKE: Same objection. 19 malicious, sexually charged claims, called by the
20 A Same answer. 20 U.S. Attorney a criminal enterprise charged with
21 Q Put the answer. 21 money laundering, conspiracy to commit other --
22 MR. PIKE: For the record. 22 federal violations, so though I would like to
23 A I'm sure that's an interesting question 23 answer that question, Mr. Edwards, and Mr. Jaffe,
24 and I would like to answer that question for 24 today, I cannot. I must invoke my Sixth, Fifth
25 you. I'm sure you would like to know as your 25 and Fourteenth Amendment rights, on advice of
175 177
1 firm has been charged with stealing over a 1 counsel or risk losing their representation.
2 billion dollars from local investors and your 2 Q 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
fleecing local and foreign investors based on 5 lead to your prosecution?
6 false sexual claims from people. And although I 6 MR. PiKE: Pm 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 Luther to 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 11 A In fact, since you are a lawyer I'm sure
12 losing their representation, so I must assert 12 you're aware the Supreme Court has said the Fifth
13 those tights under the Sixth, Fifth and 13 Amendment is used more often to protect innocent
14 Fourteenth amendments. 14 people. So that's — but today on advice of
15 Q You would agree, would you not, that It 15 counsel I've taken that right.
16 would take a Jury award of at least 45 million 16 MR. EDWARDS: (Gesturing.)
17 dollars in punitive de, to punish you for 17 MR. PiKE: I have no questions.
18 doing what you did to 18 We will read.
19 MR. PIKE: Same objections. 19 MR. EDWARDS: No further questions.
20 A I would like to answer that question, as 20 THE VIDEOGRAPHER: Off the video record,
21 I would like to answer all your other and Mr. 21 3:52 p.m.
22 Jaffe's questions today. However, while he sits 22 THE COURT REPORTER: Can he read your
23 shaking his head Fm going to have to respond 23 copy Mr. Pike?
24 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.
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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 THE COURT REPORTER: Okay. 3
4 (Discussion off the record.) 4
5 MR. PIKE: I would like this tomorrow, 5 The foregoing certificate was
6 acknowledged before me this
6 please.
7 2009, by TERRI
day of
Let's go regular but definitely before
8 BECKER, who is personally known to me.
8 that -- before Tuesday, if possible. 9
THE COURT REPORTER: Sure, that will be 10
10 50 percent expedite? 11
11 MR. PIKE: That's fine. 12
12 THE COURT REPORTER: My pleasure. 13
13 (Time noted: 4:00 o'clock p.m.) 14
14 15
15 Notary Public, State ofFlorida.
16 16 My commission No.
17 Expires March 13, 2011.
17
18
18
19 19
20 20
21 21
22 22
23 23
24 24
25 25
179 181
1 THE STATE OF FLORIDA) 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 Registered 3 of my deposition given on February 17, 2010; that
4 Professional Reporter and Notary Public for the 4 together with the correction page attached hereto
5 State ofFlorida at Large, do hereby certify that noting changes in form or substance, if any, it
6 I reported the videotaped deposition of JEFFREY 6 is true and correct.
7 EPSTEIN. the DEPENDANT, called by the PLAINTIFF 7
8 in the above-entitled action; that the witness
8
9 was duly sworn by Inc; that the foregoing pages,
10 numbered from 1 to 183, inclusive, constitute a JEFFREY EPSTEIN
11 true record of the deposition by said witness.
12 I ftuther certify that I am not attorney 10
13 or counsel of any of the parties, nor a relative 11
14 or employee of any attorney or counsel connected 12
15 with the action, nor financially interested in 13
16 the action. 14 I do hereby certify that the deposition
17 WITNESS MY HAND and official seal in the 15 of JEFFREY EPSTEIN was submitted to the wimess
18 City of West Palm Beach, County of Palm Beach, 16 for reading and signing; that after he had stated
19 State of Florida, this 22nd day ofFebruary 2010. 17 to the undersigned Notary Public that he had read
20 18 and examined her deposition, he signed the same
19 in the presence of the undersigned authority on
21 TERRI BECKER, Registered
20 the day of 2010.
Professional Reporter and
22 21
Notary Public, State ofFlorida
at Large My Commission expires 22
23 March 13,2011. 23
24 24
25 25
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1 ERRATA SHEET
2 In Re: L.M. V. EPSTEIN
3 DO NOT WRITE ON TRANSCRIPT
ENTERCHANGES HERE:
4
5 PAGE LINE CHANGE REASON
7
a
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10
11
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13
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15
JEFFREY EPSTEIN
16
17
18
THE STATE OP FLORIDA)
19 COUNTY OF PALM BEACH)
20 I DO HEREBY CERTIFY THAT JEFFREY EPSTEIN
appeared before nr and stated that he has read
21 his deposition; funher, that this Envie Sheet
was signed in my presence on this day
22 of 2010.
23
24
25
183
1 U.S. LEGAL SUPPORT
Registered Professional Reporters
2 441 West Railroad Avenue
Sete 300
3 West Pile e b 33101
4
Febnary 22. 2010
6 BURMAN, CARTON, LUTTIER & COLEMAN
303 Beeson lkok000d
7 Suite 400
West Paint Beads, Thdda 33401
A7 I Ina NN: MICHAEL PIKE, ESQ.
9
b Re. V. EPSTEIN
10
Degiceitices of: JEFFREY EPSTEIN
11
12
Dear Mr Pike
12
&see camel have Spud that you my
14 lave du• Withal ttba and sign yoes copy of the
ckposifice. for your °meadows. ccclosed
Is bacwitli you will fled EMI. Sheet forte
witless' use in Meanmy changes to the
16 depot
17 flunk you for your p.01,44 merited.
16 Cad ally yours,
US LEGAL SUPPORT
19
20
'fn k! BECKER, Registered
22 15/erotic:sal Reporter, Noinry
PAIS; Stme of 'bride al
22 Liege. My convoissioa expires
Mirth 151011.
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CC: Ikadley Edwards, Rai
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