EFTA01087055

Page 172 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No. Plaintiff, -vs - JEFFREY EPSTEIN, Defendant. CONTINUED DEPOSITION OF JEFFREY EPSTEIN VOLUME III Thursday, October 8, 2009 1:46 - 3:48 p.m. 250 South Australian Avenue Suite 1400 West Palm Beach/ Florida 33401 Reported By: Jeana Ricciuti, RPR, FPR, CLR Notary Public, State of Florida Prose Court Reporting Agency, Inc. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Joann Moduli WMMMAIO-496c-aVW099977073134 EFTA01087055 1' ..:4c 17j Page 175 APPE3tRANCFS 2 On behaifotthe Mania 1 PROCEEDINGS SPENCER T. KUYIN, ESQUIRE 2 3 ADANILANOINO, ESQUIRE LEOPORD KUV1N, PA 3 THE VIDEOGRAPHER: We're back on the record at 4 2193 POA Manna Sufis 200 4 1:46. Palm Florida 33410 5 CONTINUED DIRECT EXAMINATION 6 6 BY MR. KUVIN: Salta tad ■ and Iwo Doe In Coo No. 1 7 Q. Do you personally know John Mack, former CEO CARA I. 110131FS, FSQUIRR 8 ROTHSTEIN, ROSEMEIDT CADLPIC 8 al Morgan Stanley? 401 Paµ Las Olaf Boenzad 9 Suite 1440 9 A. I'll have to answer that the same way I've 10 fat 33301 10 answered most of your questions here today, Mr. Kuvin, Phone air P near /one Doe la Case WIN and 11 is, I intend to respond to all relevant questions NyhIch wr 2 THERINII W. MERL, ESQUIRE 12 regarding this lawsuit; however, at the present time, my PODHURSTORSECR. PA •3 21 Weµ HaslerSerett 13 attorneys have counseled me I cannot provide answers to 14 any questions relevant to this lawsuit. I must accept Hone: S On behalfof the Defendant. 15 this advice or risk losing my Gth Amendment right to TACK CrOLDBEROUR, IA FOAL' :6 STORY ROM FS, PARAI FOAL 16 effective representation. Accordingly, I assert my Al'1E RBI IRV. 601.1aUEK(it 441; MS, P 250 Sac* Augrolien Avenue 17 federal constitutional rights as guaranteed by the 5th, Sway 1120 18 6th and 14th Amendment to the United States Wne Palialinkla 33401 /Sone: 19 Ccestitution. MICHAEL!. Ha ESQUIRE 20 MR. KUVIN: Okay. Same deposition as shown 70 BURMAN, aurrotc.T.U1TXRA COLEMAN, P 303 Beam houleverd 21 before, different clip. I'm going to play it for 21 Sake 400 Wert P 3 a 33101 22 counsel first. 22 hone. 23 MR. PIKE: 'thank you. 23 ALSO P 21 DAN DOM( RY, VIDLOORAP2IER 24 MR. KUVIN: Mr. V ideowapher, just let me know VISUAL EVIDISNCE,IXC. 25 25 when you're ready. Page 174 Page 176 1 --- THE VIDEOGRAPHER: Whenever you are. EXHIBITS 2 -•• 2 MR. KUVIN: Okay. 3 WITNESS: CONEDDIRECT 3 (Video played.) 4 JEFFREY EPSTEIN 4 VIDEO WITNESS: "What did I do to Jeffrey and BY MR. KUVIN 175 6 5 what did Jeffrey do to me? I went up there 6 multiple times; I can't count. And I would be on a 8 7 massage table, massaging his legs, he would turn EXHIBITS 9 8 over, his penis would be hanging out. He would put 10 NUMBER DESCRIPTION PAGI 9 a vagina -- or a vibrator to my vagina, lie would 11 PLAINTIFFS EX. 9 PHOTOGRAPH OF GHISLA1NE 182 MAXWELL 10 touch my vagina with his fingers. He would touch 12 PLAINTIFFS FM 10 PHOTOGRAPH OF 191 . 11 my breasts. He would try to kiss my mouth. He 13 PLAINTWFS 1 PHOTOORAPHOF 196 12 would bring my hands toward his penis." PIAINTWFS EX. 12 PHOTOGRAPH 13 (Video stopped.) 19 PLAINTIFFS EX 13 PHOTOGRAPH OF 199 14 MR. KUVIN: Okay. PIAINT1FFS RAPH OF 15 MIL PIKE: I'm just going to object to the use PtAtbnifFs E .Is PH RAPE! OF111.11 201 16 of the video as to relevance, predicate and 16 PLAINTIFFS EX 16 PHOTOGRAPH OF • ANDREW 17 foundation. 17 PLAINTIFFS EX. 17 LETTERTOB. KRISCHER FROM 203 18 BY MR- KUVIN: M. REITER 19 Q. All right. Let me get it back to the same 18 PLAINTIFFSEX. IS RECEIPT OF PURCHASES MADE 206 FROM JAIL 20 location, 19 PLAINTIFFS EX. 19 FAA REGISTRY 218 21 Sir, first of all, once again, just sol can 20 21 22 lay the foundation for this, do you recognize this girl? 22 23 A. I'm going to have to respond to that question 23 24 the same way I've responded to most of your other 24 25 25 questions hero today, which is, I intend to respond to 2 (Pages 173 to 176) PROSE COURT REPORTING AGENCY, INC. • Electronically signed by Jeana Ricciuti - - Electronically signed by Jeana Ricclutl bleclerlf0410498e4244•099977073134 EFTA01087056 Page 177 Page 179 1. all relevant cannot provide answers to any questions 1 the United States Constitution. 2 relevant to this lawsuit; however, at the present time, 2 BY MR. KUVIN: 3 my attorneys have counseled me I cannot provide answers 3 Q. Did you do what that young lad described just 4 to any questions relevant to the lawsuit. I must accept 4 now to hundreds of women, including M. ? this advice or risk losing my 6th Amendment right to 5 MR. PIKE: Form, argumentative, harassing, 6 effective representation. Accordingly, I assert my 6 lacks appropriate predicate, foundation, lacks 7 federal constitutional rights as guaranteed by the 5th, identity. 8 6th and 14th Amendment to the United States 8 THE WITNESS: Excuse me. Pm going to respond 9 Constitution. 9 to that the same way I've responded to most of your 10 Q. Did this girl brings to your home for a 10 other questions here today, which is, I intend to 11 naked massage? 11 respond to all relevant questions regarding this 12 A. Pm going to have to respond to that the same 12 lawsuit; however, at the present time, my attorneys 13 way I've responded to most of your other questions here 13 have counseled me that I cannot provide answers to 14 today, which Is, I Intend to respond to all relevant 14 any questions relevant to the lawsuit. I must 15 questions regarding this lawsuit; however, at the 15 accept their advice or risk losing my 6th Amendment 16 present time, my attorneys have counseled me I cannot 16 right to effective representation. Accordingly, I 17 provide answers to any questions that may be relevant to 17 must assert my federal constitutional rights as 18 the lawsuit. I must accept this advice or risk losing 18 guaranteed by the 5th, 6th and 14th Amendment to 19 my 6th Amendment right to effective representation. 19 the United States Constitution. 20 Accordingly, I assert my federal constitutional rights 20 BY MR. KUVIN: 21 as guaranteed by the 5th, 6th end 14th Amendment to the 21 Q. While. was standing naked in your home, 22 United States Constitution. 22 specifically in your bathroom, did you tell her that you 23 Q. I'd like to play this clip for you and then 23 could get her an interview as a model because of your 24 Pm going to ask you a question. 24 connections? 25 MR. PIKE: The same clip you just played? 25 A. I'm going respond to that the same way I've Page 178 Page 180 1 MR. KUVIN: Exactly. 1 responded to most of your questions today, Spencer. I 2 MR. PIKE: Same objection. 2 intend to respond to all relevant questions regarding 3 (Video played.) 3 this lawsuit; however, at the present time, my attorneys 4 VIDEO WITNESS: "What did I do to Jeffrey and 4 have counseled me I cannot provide answers to any 5 what did Jeffrey do to me? I went out there 5 questions that may be relevant to the lawsuit. I must 6 multiple times; I can't count. And I would be on a 6 accept this advice or risk losing my Gth Amendment right 7 massage table, massaging his legs. Ho would turn 7 to effective representation. Accordingly, I must assert 8 over, his penis would be hanging out. He would put 8 my federal constitutional right as guaranteed by the 9 a vagina -- or vibrator to my vagina. He would 9 5th, 6th and 14th Amendment to the United States 10 touch my vagina with his fingers. He would touch 10 Constitution. 11 my breasts. He would try to kiss my mouth. He 11 MR. PIKE: Same objection to that line of 12 would bring my hands toward his penis." 12 questioning. 13 (Video stopped.) 13 BY MR. KUVIN: 14 BY MR. KUVIN: 14 Q. As. was standing naked in your bathroom 15 Q. Did you do that with that girl? 15 before you when she was 15, did you ask her to turn 16 MR. PIKE: Fenn. 16 around so you could see her ass better? 17 THE WITNESS: I intend to respond to all 17 MR. PIKE: Form, argumentative, harassing. 18 relevant questions regarding this lawsuit; however, 18 lacks appropriate predicate, foundation. 19 at the present time, my attorneys have counseled me 19 THE WITNESS: ri1respond to that as I 20 I cannot provide answers to any questions that may 20 responded to your last question, which is, I intend 21 be relevant to this lawsuit. I must accept this 21 to respond to all relevant questions regarding this 22 advice or risk losing my 6th Amendment right to 22 lawsuit; however, at the present time, my attorneys 23 effective representation. Accordingly, I must 23 have counseled me I cannot provide answers to any 24 assert my federal constitutional rights as 24 questions that may be relevant to this lawsuit. I 25 guaranteed by the 5th, 6th and 14th Amendment to 25 must accept their advice or risk losing my 6th 3 (Pages 177 to 180) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana RIccluti bl8d9df0-4fcb-496c-a244-099977073134 EFTA01087057 Page 181 Page 183 1 Amendment right to effective representation; 1 Q. And her father is Robert Maxwell? 2 therefore, I must assert my federal constitutional 2 A. Was Robert Maxwell. 3 rights as guaranteed by the 5th, 6th and 14th 3 Q. Pm sorry, he's passed, correct? 4 Amendment to the United States Constitution. 4 A. Correct. 5 BY MR. KUVIN: 5 Q. She is a close friend of yours, is she not? 6 Q. WhenM. was 15 years old and standing naked 6 A. Fm going to respond to that question the same 7 in front of you in your bathroom, did you tell her that 7 way I've responded to most of your other questions here 8 you could help her become a model? 8 today, Mr. Kuvin, which is, I intend to respond to all 9 MR. PIKE: Same objections, including 9 relevant questions regarding to this lawsuit; however, 10 foundation. 10 at the present time, my attorneys have counseled me I 11 THE WITNESS: Is it different than the last 11 cannot provide answers to any questions that may be 12 question? 12 relevant to this lawsuit. I must expect — accept their 13 MR. KUVIN: Uh-huh. 13 advice or risk losing my 6th Amendment right to 14 MR. GOLDBEftGER: Just go ahead. 14 effective representation. Accordingly, I must assert my 15 THE WITNESS: Okay. I intend to respond to 15 federal constitutional rights as guaranteed by the 5th, 16 all relevant questions pertaining to this lawsuit; 16 6th and 14th Amendment to the United States 17 however, at the present time, my attorneys have 17 Constitution. 18 counseled me I cannot provide answers to any 18 Q. Ghisluine Maxwell has accompanied you to 19 questions that may be relevant to this lawsuit, so 19 numerous social events in the last few years; isn't that 20 I've answered most questions here today the same 20 true? 21 way. I must expect that - accept their advice or 21 MR. PIKE: Form. 22 risk losing my 6th Amendment right to effective 22 THE WITNESS: I'm going to respond to that 23 representation. Accordingly, I assert my federal 23 question the same way I've responded to most of 24 constitutional rights as guaranteed by the 5th, Gth 24 your questions here today, which is, I intend to 25 and 14th Amendment to the United Slates 25 respond to all relevant questions regarding your Page 1.87 Page 184 1 Constitution. 1 lawsuit; however, at the present time, my attorneys 2 BY MR. KUVIN: 2 have counseled me I cannot provide answers to any 3 Q. Who is GhIslaine Maxwell? 3 questions that may be relevant to that lawsuit. I 4 A. I intend to respond to all relevant questions 4 must accept their advice or risk losing my 6th 5 regarding this lawsuit; however, at the present time, my 5 Amendment right to effective representation. attorneys have counseled me that I cannot provide 6 Accordingly, I must assert my federal 7 answers to any questions relevant to this lawsuit. As I 7 constitutional right as guaranteed by the 5th, 6th 8 have done to most of your other questions here today, I 8 and 14th Amendment of the United States 9 must accept their advice or risk losing my 6th Amendment 9 Constitution. 10 right to effective representation. Accordingly, I 10 BY MR. KUVIN: 11 assert my federal constitutional rights as guaranteed by 11 Q. One ofyour houseboys that has been deposed in 12 the 5th, 6th and 14th Amendment to the United States 12 this case testified that you were a rather nice 13 Constitution. 13 gentleman that used to talk to the staff, and that when 14 MR. KUVIN: Let me show the camera what we'll 14 Ms. Maxwell came into the picture, that you stopped 15 mark as Exhibit 9 to this deposition. 15 talking to the staff and the staffhad to communicate 16 THE VIDEOGRAPI-IER: Okay. 16 through Ms. Maxwell. Do you agree or disagree with 17 (Plaintiffs Exhibit No.9 was marked for 17 that? 18 identification.) 18 MR. PIKE: Form, foundation, predicate, 19 BY MR. KUVIN: 19 argumentative, assumes facts not in evidence. 20 Q. Let me show you what we've marked as Exhibit 9 20 THE WITNESS: I'm going to answer that the 21 to your deposition. Do you recognize Ghislaine Maxwell 21 same way I've answered most ofyour questions here 22 in this photograph? 22 today, which is, I intend to respond to all 23 A. Yes. 23 relevant questions regarding this lawsuit; however, 24 Q. And who is she standing with? 24 at the present time, my attorneys have counseled me 25 A. Her father. 25 that I cannot provide answers to any questions that 4 (Pages 181 to 184} PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Rican' (601-280.428.9381) Electronically signed by Jeana Flicciutl (601.280-428.9381) bf8d9O0-4(cb-496c-a244-09997 7073134 EFTA01087058 Pogo Page 187 1 may be relevant to your lawsuit. I must accept 1 to respond to all relevant questions regarding this 2 their advice or risk losing my 6th Amendment right lawsuit; however, at the present time, my attorneys 3 to effective representation. Accordingly, I assert 3 have counseled me I cannot provide answers to any 4 my federal constitutional rights as guaranteed by 4 questions relevant to that lawsuit. I must accept the 5th, 6th and 14th Amendment of the United 5 their advice or risk losing my Gth Amendment right 6 States Constitution. 6 to effective representation. Therefore, I assert 7 BY MR. KUVIN: 1 my federal constitutional rights as guaranteed by 8 Q. Ho also testified that he felt you were a 0 the 5th, 6th and 14th Amendments to the United 9 rather nomad guy until Ms. Maxwell came into the Stales Constitution. 10 picture, and that she led you into this life of 10 BY MR. KUVIN: 11 perversion, sexual perversion. Do you agree with that? 11 Q. Do you know where Donald Trump's Maralago 12 MR. PIKE: Same objections. 12 estate is? 13 THE WITNESS: I'm going to respond to that the 13 A. Yes. 14 same way I've responded to most of your questions 14 Q. Have you been there? 15 hem today, Mr. Kuvin, which is, I intend to 15 A. Yes. 16 respond to all relevant questions regarding this 16 Q. Who with? 17 lawsuit; however, at the present time, my attorneys 17 A. Pm going to have to answer that question the 18 have counseled me 1cannot provide answers to any 18 same way I've answered most of your other questions here 19 questions relevant to this lawsuit. I must accept 19 today. I intend to respond to all relevant questions 20 their advice or risk losing my 6th Amendment -- 20 regarding this lawsuit; however, at the present time, my 21 excuse me -- I must accept their advice or risk 21 attorneys have counseled molcannot provide answers to 22 losing my 6th Amendment right to effective 22 any questions that may be relevant to the same lawsuit. 23 representation. Accordingly, I must assert my 23 I must accept their advice or risk losing my 6th 24 federal constitutional rights as guaranteed by the 24 Amendment right to effective representation. 25 5th, 6th and 14th Amendment to the United States 25 Accordingly, I must assert my federal constitutional Page 186 Page 188 1 Constitution. 1 rights as guaranteed by the 5th, 6th and 14th Amendment 2 BY MR. KUVIN: 2 to the United States Constitution. 3 Q. Did Ms. Maxwell procure underaged girls for 3 Q. Have you seen the high school transcripts you to have sexual relationships with? 4 grades ofgirls that you have had sexual relationships 5 A. I'm going to answer that question the same way 5 with dating back to 2005? 6 I've answered most of your other questions today, 6 MR. PIKE: Form, relevance, improper 7 Mr. Kuvin, which is, I intend to respond to all relevant 7 hypothetical, lacks facts -- assumes facts not in 8 questions regarding this lawsuit; however, at the 8 evidence, lacks appropriate predicate, foundation. 9 present time, my attorneys have counseled me I cannot 9 THE WITNESS: I'm going to answer that 10 provide answers to any questions relevant to that 10 question the same as I've answered most of your 11 lawsuit. Excuse me. I must accept their advice or risk 11 other questions here today, Mr. Kuvin, which is, I 12 losing my 6th Amendment right to effective 12 intend to respond to all relevant questions 13 representation. Accordingly, I must assert my federal 13 regarding this lawsuit; however, at the present 14 constitutional rights as guaranteed -- guaranteed by the 14 time, my attorneys have counseled me that I cannot 15 5th, 6th and 14th Amendments to the United States 15 provide answers to any questions that may be 16 Constitution. 16 relevant to this lawsuit. I must accept their 17 Q. Ms. Maxwell procured a particular underaged 17 advice or risk losing my 6th Amendment right to 18 girl who worked at Donald Trump's Maralago, for you to 18 effective representation. Accordingly, I assert my 19 have a sexual relationship with; isn't that true? 19 federal constitutional rights as guaranteed by the 20 MR. PIKE: Form, argumentative, lacks 20 5th, 6th and 14th Amendment to the United States 21 appropriate predicate, foundation, assumes facts 21 Constitution. 22 not in evidence. 22 BY MR. KUVIN: 23 THE WITNESS: I'm going to respond to that the 23 Q. Do you deny that the high school transcripts 24 same way I've responded to most of your other 24 which were found in your trash on Palm Beach that showed 25 questions hero today, Mr. Kuvin, which is, I intend 25 the ages ofsome of the girls you were engaged with 5 (Pages 185 to 188) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana Ricciuti bted9dfOA(cb-496c-a244-099977073134 EFTA01087059 Page 189 Page 191 sexual ads with at your home dune from your house? 1 MR. GOLDBERGER: Break time? 2 MR. PUCE: Same objection in addition to 2 MR. KUVIN: No, not again. Please not. 3 argumentative and harassing. 3 lust let us know when you're good to go. 4 THE WITNESS: I intend to respond to all 4 THE VIDEOGRAPHER: Were back on the record at relevant questions regarding this lawsuit; however, 5 2:04. This will be the beginning of tape No. 3. 6 as I've done with most of your other questions 6 BY MR. KUVIN: today, at the present time my attorneys have 7 Q. Do you have security cameras throughout your 8 counseled me that I cannot provide answers to any 8 home on Palm Beach Island? 9 of those questions relevant to this lawsuit. I 9 A. I'm going to answer that question the same way 10 must accept their advice or risk losing my 6th 10 I've answered most of your questions here today, 11 Amendment right to effective representation. 11 Mt Kuvin. I intend to respond to all relevant 12 Accordingly, I must used my federal 12 questions regarding this lawsuit; however, at the 13 constitutional rights as guaranteed by the 5th, 6th 13 present time, my attorneys have counseled me I cannot 14 and 14th Amendments to the United States 14 provide answers to any questions relevant to the 15 Constitution. 15 lawsuit I must accept their advice or risk losing my 16 BY MR. KUVIN: 16 6th Amendment right to effective representation. 17 Q. Did you have numerous photos of nude young 17 Accordingly, I assert my federal constitutional rights 18 women, girls under the ago of 18, back in your home 18 as guaranteed by the 5th, 6th and 14th Amendment to the 19 in -- on Palm Beach Island in 2005 and 2006? 19 United States Constitution. 20 A. I'm going to have to respond to that question 20 (Plaintiffs Exhibit No. 10 was marked for 21 tho same way I've responded to most of your questions 21 identification.) 22 here today, which is, I intend to respond to all 22 MR. KU VIN: ru show the camera a photograph 23 relevant questions regarding this lawsuit; however, at 23 here. Okay? 24 the present time, my attorneys have counseled 'no I 24 THE VIDEOGRAPHER: LIR it up. Yeah, there 25 cannot provide answers to any questions relevant to the 25 you go. Okay. Page 190 Page 192 - 1 same lawsuit. I must accept their advice or risk losing 1 MR. KUVIN: Okay? 2 my 6th Amendment right to effective representation. 2 BY MR. KUVIN: Accordingly, I must assert my federal constitutional 3 Q. Let me show you what we marked as Plaintiffs rights as guaranteed by the 5th, 6th and 14th Amendment. 4 Exhibit 10. Do you recognize this young lady? Q. Did you have photographs of girls under the 5 A. Yes. 6 ago of ten who were nude, either partially or fully 6 Q. Who is sho? 7 nude, in your home on Palm Beach in 2005 and 2006? 7 A. Her name is (phonetic). 8 MR. PIKE: Fenn. 8 Q. And who is she? 9 THE WITNESS: I'm going to respond to that 9 A. I just -- her name is 10 question the same way I've responded to most of' 10 Q. How do you recognize her? 11 your other questions, which is, I intend to respond 11 A. I don't understand the question. 12 to all relevant questions regarding this lawsuit; 12 Q. Well, is she a friend of yours? Did she work 13 however, at the present time, my attorneys have 13 for you? Flow do you recognize her? 14 counseled me I cannot provide answers to any 14 A. How do I recognize her? 15 questions relevant to this lawsuit. I must accept 15 Well, I'd like to respond to that question 16 this advice or risk losing my 6th Amendment right 16 but, however, my attorneys have told me that I can't 17 to effective representation. Accordingly, I assert 17 respond to any questions today that may -- excuse me. I 18 my federal constitutional rights as guaranteed by 18 intend to respond to all relevant questions regarding 19 the 5th, 6th and 14th Amendments of the United 19 this lawsuit; however, at the present time, my attorneys 20 States Constitution. 20 have counseled mo that I cannot provide answers to any 21 THE VIDEOGRAPHER: Mr. Kuvin, fin sorry I have 21 questions relevant to this lawsuit. I must accept their 22 to change. 22 advice or risk losing my 6th Amendment right to 23 MR. KUVIN: Go ahead 23 effective representation. Accordingly, I assert my 24 THE VIDEOGRAPHER: well go off the record at 24 federal constitutional rights as guaranteed by the 5th, 25 2:03. This will be the end of tape No.2. 25 Gth and 14th Amendment to the United States 6 (Pages 189 to 192) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans Rletiutl Electronically signed by Jeana Riccardi bf8d9tlf041cb-496c-a244-09997 7073134 EFTA01087060 Page 191 Page 195 1 Constitution. 1 THE WITNESS: Pm going to respond to that 2 Q. Did you have sex with IM? 2 question the same way I've responded to most of 3 A. I'm going to answer that question like I've 3 your questions here today, Mr. Kuvin, which is, I 4 answered most of your questions here today, which is, 1 4 intend to respond to all relevant questions 5 intend to respond to all relevant questions regarding 5 regarding this lawsuit -- excuse me, however, at 6 this lawsuit; however, at the present time, my attorneys 6 the present time, my attorneys have counseled me I 7 have counseled me I cannot provide answers to any 7 cannot provide answers to any questions relevant to 8 questions relevant to this lawsuit. I must accept their 8 the lawsuit, or might be relevant to the lawsuit. 9 advice or risk losing my 6th Amendment right to 9 I must accept their advice or risk losing my 6th 10 effective representation. Accordingly, I assert my 10 Amendment right to effective representation. 11 federal constitutional rights as guaranteed by the 5th, 11 Accordingly, I assert my federal constitutional 12 6th and 14th Amendment to the United States 12 rights as guaranteed by the 5th, 6th and 14th 13 Constitution. 13 Amendment of the United States Constitution. 14 Q. When did you first meet Prince Andrew? 14 BY MR. KUVIN: 15 And let mo make it a compound question so I 15 Q. Did you fly with Prince Andrew on your plane, 16 don't have to repeat it over and over. When did you 16 or planes, with any underaged girls, girls under the age 17 first meet Prince Andrew, under what conditions did you 17 of18? 18 meet him, and who was present at that list meeting? 18 A. I'm going to answer that question the same way 19 A. I'm going to answer that question as I've done 19 I've answered all the other questions here today, 20 most of your questions here today, Mr. Kuvin, which is, 20 virtually, which is, I intend to respond to all relevant 21 I intend to respond to all relevant questions regarding 21 questions regarding this lawsuit; however, at the 22 this lawsuit; however, at the present time, my attorneys 22 present time, my attorneys have counseled me I cannot 23 have counseled met cannot provide answers to any 23 provide answers to any questions relevant to the 24 questions relevant to that lawsuit. I must accept their 24 lawsuit. I must accept their advice or risk losing my 25 advice or risk losing my 6th Amendment right to 25 6th Amendment right to effective representation. Page 194 Page 196 1 effective representation. Accordingly, I must assert my 1 Accordingly, I must assert my federal constitutional 2 federal constitutional rights as guaranteed by the 5th, 2 rights as guaranteed by the 5th, 6th and 14th Amendments 3 6th and 14th Amendment to the United States 3 to the United States Constitution. 4 Constitution. 4 Q. Do you 'mow 5 Mk PIKE: In addition, relevance. 5 MR. KUVIN: For the court reporter, it's 6 BY MR. KUVIN: 6 7 Q. Do you pay Ms. Maxwell a salary? 7 THE WITNESS: I intend to respond to all 8 MR. PIKE: Form. 8 relevant questions regarding this lawsuit; however, 9 BY MR. KUVIN: 9 at the present thne, my attorneys have counseled me 10 Q. Ohislaine Maxwell, so we're clear. Do you pay 10 I cannot provide answers to any questions relevant 11 her a salary? 11 to the lawsuit. I must accept this advice or risk 12 A. I'd like -- excuse me. I'm going to answer 12 losing my 61h Amendment right to effective 13 that question the same way I've answered most of your 13 representation. Accordingly, I assert my federal 14 questions here today, which is, I intend to answer all 14 constitutional rights as guaranteed by the 5th, 6th 15 questions relevant to this lawsuit; however, at the 15 and 14th Amendments to the United States 16 present time, my attorneys have counseled me I cannot 16 Constitution. 17 provide answers to any questions relevant to this 17 MR. KUVIN: Let me show the camera what we'll 18 lawsuit. I must accept their advice or risk losing my 18 mark as Exhibit II. 19 6th Amendment right to effective representation. 19 (Plaintiffs Exhibit No. 11 was marked for 20 Accordingly, I assert my federal constitutional rights 20 identification.) 21 as guaranteed by the 5th, 6th and 14th Amendment to the 21 THE VIDEOORAPHER: Okay. 22 United States Constitution. 22 MR. KUVIN: Okay? 23 Q. Did you provide any underaged girls for sex to 23 BY MR. KUVIN: 24 Prince Andrew? 24 Q. In Exhibit 11, sir, you're standing with a 25 MR. PIKE: FO1111 25 woman. Who Is that woman in that photograph? 7 (Pages 193 to 196) (.1) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Juana Ricciuti Electronically signed by Arena RIcciull 618d9dt04tcb-496c-a240-098977073134 EFTA01087061 Page 19 / Page 199 1 A. (phonetic). A. I intend to respond to all relevant questions 2 Q. Where were you? 2 regarding this lawsuit; however, as I've done to most of 3 A. I intend to respond to all relevant questions 3 the questions at the present time, my attorneys have 4 regarding this lawsuit; however, at the present time, my 4 counseled me that I cannot provide answers to any of' attorneys have counseled me Icannot provide answers to 5 those questions that may be relevant to the lawsuit. I 6 any questions that may be relevant to this lawsuit. I 6 must accept this advice or risk losing my Gth Amendment must accept this advice or risk losing my 6th Amendment 7 right to effective representation. Accordingly, 8 right to effective representation. Accordingly, I must 8 asset my federal constitutional rights as guaranteed by 9 assert my federal constitutional rights as guaranteed by 9 the 5th, 6th and 14th Amendments of the United States 10 the 5th, 6th and 14th Amendments to the United States 10 Constitution. 11 Constitution. 11 BY MR. KUVIN: 12 MR. KUVIN: And just so the court reporter 12 Q. Fin going to show you what we'll mark as 13 knows, Ghislaine is spelled G-H-I-S-L-A-I-N-E. 13 Exhibit 13. Let me show it to the camera, first. 14 BY MR. KUVIN: 14 (Plaintiffs Exhibit No. 13 was marked for 15 Q. Who is ,excirse 15 identification.) 16 me? 16 BY MR. KUVIN: 17 A. I'm going to answer that question the same way 17 Q. Sir, is It true that Exhibit 13 shows your 18 I've answered most of your questions here today, which 18 personal assistant, 19 is, I intend to respond to all relevant questions 19 A. I intend to respond to all relevant questions 20 regarding this lawsuit; however, at the present time, my 20 regarding this lawsuit; however, at the present time, my 21 attorneys have counseled me I cannot provide answers to 21 attorneys have counseled me that I cannot provide 22 any questions relevant to the lawsuit. I must accept 22 answers to any questions that may be relevant to this 23 their advice or risk losing my 6th Amendment right to 23 lawsuit. I must accept their advice or risk losing my 24 effective representation. Excuse me. Accordingly, I 24 6th Amendment right to effective representation. 25 must assert my federal constitutional rights as 25 Accordingly, I assert my federal constitutional rights Page 198 Page 200 1 guarantee -- guaranteed by the 5th, 6th and 14th 1 as guaranteed by the 5th, 6th and 14th Amendment to the 2 Amendment tote United States Constitution. 2 United States Constitution. 3 (Plaintiffs Exhibit No. 12 was marked for 3 Q. Let me show you what we'll mark as Exhibit 14. ,1 identification.) 4 (Plaintiffs Exhibit No. 14 was marked for 5 MR. KUVIN: Let me show to the camera what 5 identification.) 6 we've marked as Exhibit 12. 6 BY MR. KUVIN: 7 BY MR. KUVIN: 7 Q. Sir, does Exhibit 14 show --,a 8 Q. Let me show you what I've marked as Exhibit 8 girl that you have had a sexual relationship with since 9 12. Do you recognize any of the girls in that 9 before she was 18 years old? 10 photograph? 10 MR. PIKE: Fenn, argumentative, harassing, 11 A. I'm going to answer that question the same way 11 assumes facts not in evidence, lacks appropriate 12 I've answered most of your other questions here today, 12 . predicate and foundation. 13 Mr. Kuvin, which is, I intend to respond to all relevant 13 THE WITNESS: I intend to respond to all 14 questions regarding this lawsuit; however, at the 14 relevant questions regarding this lawsuit; however, 15 present time, my attorneys have counseled me that 1 15 at the present time, my attorneys have counseled me 16 cannot provide answers to any questions that may be 16 I cannot provide answers to any questions relevant 17 relevant to the lawsuit. I must accept their advice or 17 to this lawsuit. I must accept their advice or 18 risk losing my 6th Amendment right to effective 18 risk losing my 6th Amendment right to effective 19 representation. Accordingly, I assert my federal 19 representation. Accordingly, I assert my federal 20 constitutional rights as guaranteed by the 5th, 6th and 20 • constitutional rights as guaranteed by the 5th, 6th 21 14th Amendment to the United States Constitution. 21 and 14th Amendment to the United States 22 Q. Sir, isn't it true that in what we've marked 22 Constitution. 23 as Plaintiff's Exhibit 12 the blond standing on the 23 BY MIL KUVIN: 24 left is and the blonde, dirty blonde 24 Q. I'm going to show the camera what we'll mark 25 standing on the right is 25 as Exhibit 15. 8 (Pages 197 to 200) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RIcchal Electronically signed by Jeana RIcclutl bred9W0-4fcb-496c-a244-099977073134 EFTA01087062 Page 201 Page 203 (Plaintiffs Exhibit No. IS was marked for 1 cannot provide answers to any questions relevant to this 2 identification.) 2 lawsuit. I must accept their advice or risk losing my 3 BY MR. KUVIN: 3 6th Amendment right to effective representation. 4 Q. Sir, does Exhibit I5 show S an 4 Accordingly, I assert my federal constitutional rights 5 underaged girl that you were utilizing back in 2005 and 5 as guaranteed by the 5th, 6th and 14th Amendment to the 6 2006 to procure other underaged girls for sex and sexual 6 United States Constitution. / contact at your home? 7 Q. I'm going to show you a document that we'll 8 MR. PIKE: Same objections to Exhibit 15 as 8 mark as Exhibit 17. 9 were made to Exhibit 14. 9 MR. PIKE: Thank you. 10 THE WITNESS: I'm going to answer that the 10 (Plaintiffs Exhibit No. 17 was marked for 11 same way I've answered most of your questions here 11 identification.) 12 today, Mr. Kuvin, which is, I intend to respond to 12 BY MR. KUVIN: 13 all relevant questions regarding this lawsuit; 13 Q. I'm going to give you a minute to take a look 14 however, at the present time, my attorneys have 14 at that document and just tell inc when you're ready to 15 counseled me that I cannot provide answers to any 15 answer any questions about it. 16 questions that may be relevant to the lawsuit. 16 A. Okay. 17 must accept their advice or risk losing my 6th 17 Q. Okay. First of all, have you seen this letter 18 Amendment right to effective representation. 18 before? 19 Accordingly, I am going to assert my federal 19 MR. GOLDBERGER: Attorney-client privilege, 20 constitutional rights as guaranteed by the 5th, 6th 20 work product. 21 and 14th Amendments to the United States 21 BY MR. KUVIN: 22 Constitution. 22 Q. Have you seen this letter before outside of 23 (Plaintiffs Exhibit No. 16 was marked for 23 the relationship with your attorneys? 24 identification.) 24 MR. GOLDBERGER: You can answer that question. 25 MR. KUVIN: Let me show the camera what we've 25 THE WITNESS: No. Page 202 Page 204 marked as Exhibit 16. 1 BY MR. KUVIN: 2 BY MR. KUVIN: 2 Q. Do you know Chief of Police Michael Reiter? 3 Q. Do you recognize the ganleman in that 3 Do you know who he is? 4 photograph, 4 A. I know who he is. 5 MR. PIKE: Hold on for a second. Q. Do you know State Attorney Bony Krischer? 6 MR. GOLDBERGER: Do you want to discuss it 6 A. I know who he is. 7 with me? 7 Q. Did you ever speak with ChiefofPolice 8 MR. PIKE: Let's take a break for one minute. 8 Michael Reiter in the past? 9 MR. KUVIN: All right. 9 A. I don't remember. 1.0 THE VIDEOGRAPHER: Off the record at 2:16. 10 Q. Did you ever talk to anyone, either at the 11 (A briefrecess was taken.) 11 State Attorney's office, yourself, or Michael Reiter 12 THE VIDEOGRAPHER: We're back on the record at 12 about the prosecution of yotir claim without the presence 13 2:45. 13 of your attorneys? 14 BY MR. KUVIN: 14 A. No. 15 Q. Okay. Do you recognize the person that's 15 Q. Did you ever talk to any of the police that 16 shown in Exhibit 16? 16 worked for the Town ofPalm Beach without the presence 17 A. Yes. 17 of your attorneys? 18 Q. Who is that? 18 A. Explain - 19 A. Prince Andrew. 19 MR. PIKE: Wait one second. 20 Q. And how do you know Prince Andrew? 20 THE WITNESS: I'm sorry. 21 A. I'm going to have to respond to that question 21 MR. PIKE: Can you state the question again? 22 the same way I've responded to most of your questions 22 MR. KUVIN: Sure. 23 here today, Mr. Kuvin, which is, [intend to respond to 23 BY MR. KUVIN: 24 all relevant questions regarding this lawsuit; however, 24 Q. Did you ever speak to any of the police 25 at the present time, my attorneys have counseled me I 25 officers that worked for the Town of Palm Beach without 9 (Pages 201 to 204) PROSE COURT REPORTING AGENCY, INC. .Electrancaltystgandby RIctiutt Etactronleally signed by Jana Rleelutl blead104fcb-496c-a244.099977073134 EFTA01087063 Page 205 Page 20'r 1 the presence of your attorneys? 1 BY MR. KUVIN: 2 MR. GOLDBERGER: Is the question, have you 2 Q. Did you purchase items from the jail? 3 ever spoken to a Town of Palm Beach police officer? 3 MR. GOLDBERGER: Hang on a second. 4 Is that the — can we rephrase it like that? 4 MR. PIKE: Hold on one second. 5 MR. KUVIN: Sure. 5 THE WITNESS: It looks that way, yes, sir. 6 MR. GOLDBERGER: Okay. 6 BY MR. KUVIN: 7 THE WITNESS: I've been stopped by the police 7 Q. Okay. 8 for traffic violations, if that's what you mean. 8 MR. PIKE: And the document speaks for itself, 9 BY MR. KUVIN: 9 the composite document speaks for itself. 10 Q. Any other times that you had conversations 10 BY MR. KUVIN: 11 with any of the Town of Palm Beach — 11 Q. I'd like you to take a look at Exhibit 18. It 12 A. No. 12 shows purchases well, does it show purchases by you? 13 Q. --police officers? 13 MR. PIKE: Asked and answered. 14 A. Not that I recall specific* 14 THE WITNESS: Yes. 15 Q. Okay. Now, you were housed at the jail after 15 BY MR. KUVIN: 16 your plea of guilty that we had spoke about at the 16 Q. Okay. And it appears those purchases took 17 beghming of your deposition; is that correct? 17 place from 7/8/08 through 9/30/08 is the last one that I 18 MR. PIKE: Form. 18 have; is that correct? 19 THE WITNESS: Say it again. 19 MR. PIKE: The document speaks for itself. 20 BY MR. KUVIN: 20 BY MR. KUVIN: 21 Q. Yes. You were housed at the local jail here 21 Q. You can answer. 22 in Palm Beach County after your plea of guilty that we 22 A. The document speaks for itself. 23 spoke about at the beginning of your deposition? 23 Q. Is that correct, the last date is 9/30/08? 24 MR. PIKE: Form. 24 A. The last date here is 9/30, yes. 25 THE WITNESS: Yes. 25 MR. PIKE: With regard to what you provided to Page 206 Page 208 1 BY MR. KUVIN: 1 the witness. 2 Q. How long were you there? 2 MR. KUVIN: Sure, absolutely. 3 A. 13 months, approximately. 3 THE WITNESS: Okay. 4 Q. All right. And of those 13 months, how many 4 BY MR. KUVIN: 5 months were you there where you had to stay there 24 5 Q. And just so we're clear, this composite 6 hours a day? 6 exhibit that we've marked as Exhibit 18 contains 7 A. I don't recall specifically. 7 purchases from 7/8/08, 7/15,7/22, 7/29, 8/5,8/12, 8 Q. More than a month? 8 8/21, W26,9/2, 9/9, 9/23 and 9/30, just so the record 9 A. Yes. 9 is clear; there is no question. 10 Q. More than two months? 10 A. Okay. 11 A. Yes. 11 Q. Okay? 12 Q. More than three months? 12 A. Uh-huh. 13 A. Yes. 13 Q. All right. These items that you purchased, 14 Q. More than four? 14 did you utilize all of these items yourself? 15 A. I think so,Idon't remember. 15 MR. PIKE: Form, relevance. 16 Q. Do you recall when you were provided work 16 THE WITNESS: I don't understand the question. 17 release, when you were able to leave during the daylight 17 BY MR. KUVIN: 18 hours? 18 Q. Well, you purchased a number of items that are 19 A. Not with specificity. 19 shown in this receipt. 20 Q. While you were there at the jail in Palm 20 A. Yes. 21 Beach -- I'm going to show you what we'll mark as 21 Q. The question is: Did you use them yourself? 22 Exhibit 18. 22 MR. PIKE: Same objection. 23 (Plaintiffs Exhibit No. 18 was marked for 23 THE WITNESS: I don't knots if I used all of 24 identification.) 24 them, so... 25 25 10 (Pages 205 to 208) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana Ricciuti bf8d9d10-4fcb-496c-a244.099977073134 EFTA01087064 Page 209 Page 211 1 BY MR. KUVIN: 1 the form you filled out, the infonnation or the product 2 Q. Well, what did you do with the items that you 2 that you put on that form actually was provided? 3 purchased? 3 A. No, never. 4 MR. PIKE: Form, overbroad. 4 Q. If we look at the items that are contained 5 BY MR. KUVIN: 5 within these receipts, I'd like you to go, if you would, 6 Q. You can answer. 6 to the second invoice here dated 7/15/08. The third 7 A. I used some, I threw away sane. 7 item down is a Lubriderm lotion. 8 Q. Did you give any away? 8 A. Yes. 9 A. Not that I remember. 9 Q. Do you see that? 10 MR. PIKE: Same objection. 10 A. Yes. 11 BY MR. KUVIN: 11 Q. Did you purchase that? 12 Q. Did you provide any items that you purchased 12 A. It appears so. 13 to other inmates while you were there in jail? 13 Q. Did you receive it? 14 MR. PIKE: Form. 14 A. I don't remember. 15 THE WITNESS: Not to the best ofmy 15 Q. Did you use the Lubriderm lotion that you 16 recollection. 16 received or that you may have received in jail? 17 BY MR. KUVIN: 17 MR. PIKE: Form. 18 Q. Okay. With respect to all of the items that 18 BY MR. KUVIN: 19 are listed in these receipts, is it a safe assumption 19 Q. Let me strike that and re-ask it. 20 that you either used them yourself or threw them away? 20 A. Okay. 21 MR. PIKE: Asked and answered. If you don't 21 Q. Did you use the Lubridenn lotion which you had 22 know —if you know. 22 purchased from the jail while you were there? 23 THE WITNESS: I don't know. 23 A. I might have. 24 BY MR. KUVIN: 24 Q. What for? 25 Q. I'm sorry? I didn't hear you. 25 A. To moisturize my hands and face. Page 210 Page 212 MR. PIKE: Asked and answered. 1 Q. Okay. Did you use Lubriderm lotion while you 2 THE WITNESS: So should I answer? 2 were injail to masturbate at all? 3 MR. PIKE: You can answer again. 3 A. No. 4 THB WITNESS: Ask the question again. 4 MR. PIKE: Fonn objection, harassing. 5 BY MR. KUVIN: 5 THE WITNESS: Absolutely not. 6 Q. So can we assume that all of the items that 6 BY MR. KUVIN: 7 are shown in these receipts were either used by you or 7 Q. It appears, if you would turn to 7/29/08, 8 thrown away? 8 which is approximately two weeks later, and the second 9 A. I don't even know if I received some of those 9 thing down is another bottle of Lubriderm lotion. Do 10 items, so I would assume I used most of them. 10 you see that? 11 Q. Okay. 11 A. Yes. 12 A. Okay? 12 Q. What did you use that for? 13 Q. Sure. Take a look, I just want to make surd, 13 MR. PIKE: Asked and answered. 14 did you receive all these items? 14 MR. KUVIN: It's a second bottle. 15 A. I don't know. 15 MR. PIKE: It's the same question, Spencer. 16 MR. PIKE: Asked and answered. 16 Can we got to something relevant? 17 BY MR. KUVIN: 17 THE WITNESS: No problem. 18 Q. How did you purchase them? 18 MR. PIKE: He can answer. 19 A. I filled out a form. 19 THE WITNESS: My hands and my face. 20 Q. And how were they provided to you? 20 BY MR. KUVIN: 21 MR. PIKE: Form. 21 Q. Okay. 22 THE WITNESS: Sometimes they would come in a 22 A. I believe the first bottle went missing. 23 bag. 23 Q. If we turn to approximately one month later on 24 BY MR. KUVIN: 24 821/08, do you have that one? 25 Q. Okay. And did you determine whether or not 25 A. Yes. t, n (Pages 209 to 212) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Mocha' Electronically signed by Jeana Modell hf8d9df0.4fcb-496c•a244.099977073134 EFTA01087065 Page 213 Page 215 1 Q. All right. On that occasion, you bought two 1 A. No. 2 bottles ofhand lotion again. 2 Q. Is it your testimony here today that you did 3 A. Yes. 3 not use any of the bottles ofhand lotion or Lubridenn 4 Q. What did you use those for? 4 lotion that we had previously just gone through to A. Nothing 5 masturbate while you were in jail? 6 Q. What did you do with them? 6 A. That's correct. 7 A. They were bought by accident. 7 Q. Did Ghislainc Maxwell visit you in jail? 8 Q. How did you buy them by accident? 8 A. No. 9 A. Because you fill out a check form and 9 Q. Did visit you while you were 10 sometimes the forms don't make any sense, they just 10 injail? 11 deliver in other things. 11 A. I intend to respond to all relevant questions 12 Q. Sir, did you get those two bottles? 12 regarding this lawsuit; however, at the present time, my 13 A. Yes. Yes. 13 attorneys have counseled me I cannot provide answers to 14 Q. And you never used them? 14 any questions relevant to this lawsuit. I must accept 15 A. No. I threw them away. 15 this advice or risk losing my 6th Amendment right to 16 Q. Okay. If we turn to 9/9/08, do you see that 16 effective representation. Accordingly, I assert my 17 entry? 17 federal constitutional rights as guaranteed by the 5th, 18 A. Yes. 18 6th and 14th Amendment to the United States 19 Q. All right. And another invoice here, on that 19 Constitution. 20 date a bottle of hand lotion, do you see that? 20 Q. Did you have sex with while 21 A. Yes, I do. 21 you were housed at the Palm Bench jail facility? 22 Q. Did you get it? 22 MR. PIKE: Form. 23 A. I don't know. 23 THE WITNESS: I intend to respond to all 24 Q. Do you know if you used it? 24 relevant questions regarding this lawsuit; however, 25 A. Definitely not. 25 at the present time, my attorneys have counseled me Page 214 Page 216 1 Q. How do you know you definitely did not use it? 1 I cannot provide answers to any questions relevant 2 A. Because it was not — anything that said hand 2 to this lawsuit. As I've answered most of your 3 lotion I did not use, I throw in the garbage. 3 question today, Mr. Kuvin, I must accept this 4 Q. Why is that? 4 advice or risk losing my 6th Amendment right to A. Because it wasn't something that I had 5 effective representation. Accordingly, I assert my 6 ordered. 6 federal constitutional rights as guaranteed by the 7 MR. PIKE: Can 1-- can I just have an 5th, 6th and 14th Amendments to the United States 8 agreement that the objections to this line of Constitution. 9 questioning is irrelevant, so I don't have to -- 9 BY MR. KUVIN: 10 MR. KUVIN: Sure. 10 Q. Did you pay girls so that they would not 11 MR. PIKE: — interrupt. 11 testify against you in the civil proceedings that have 12 MR. KUVIN: Sure. 12 been filed in both Federal and State Court? 13 MR. PIKE: Agreed? 13 MR. PIKE: Fenn. 14 MR. KUVIN: Agreed. 14 THE WITNESS: Okay. Like most of your other 15 BY MR. KUVIN: 15 questions here today, Mr. Kuvin, I'm going to 16 Q. Let's turn again to 9/30/08, the last invoice 16 respond by saying I intend to respond to all 17 in there. 17 relevant questions regarding this lawsuit; however, 18 A. Yes. 18 at the present time, my attorneys have counseled me 19 Q. Do you see there is an entry for two snore 19 I cannot provide answers to any questions relevant 20 bottles ofhand lotion. Do you see that? 20 to this lawsuit. I must accept this advice or risk 21 A. Correct. 21 losing my 6th Amendment right to effective 22 Q. What did you do with those? 22 representation. Accordingly, I must assert my 23 A. To the best ofmy knowledge, I threw them 23 federal constitutional rights as guaranteed by the 24 right away. 24 5th, 6th and 14th Amendments to the United States 25 Q. You didn't use them for anything? 25 Constitution. 12 (Pages 213 Lo 216 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana RIcciuti bf8d9df0-4fcb-496c-a244-09997 7073134 EFTA01087066 Page 217 Page 219 1 BY MR. KUVIN: 1 any questions relevant to this lawsuit. I must accept 2 Q. Did you have sex with when 2 this advice or risk losing my Gth Amendment right to 3 she was under the age of 14? 3 effective representation. Accordingly, as I've done 4 MR. PIKE: Form. 4 with most of your questions, I must assert my federal 5 THE WITNESS: I intend to respond to all 5 constitutional rights as guaranteed by the 5th, 6th and 6 relevant questions regarding this lawsuit; however, 6 14th Amendment to the United States Constitution. 7 at the present time, my attorneys have counseled me 7 Q. Mr. Epstein, are you aware that after I cannot provide answers to any questions relevant 8 September 11, 2001 that the Federal Government started 9 to this lawsuit. 1 must accept this advice or risk 9 tracking all flights of all public and private aircraft? 10 losing my 6th Amendment right to effective 10 MR. PIKE: Fenn, relevance. 11 representation. Accordingly, I must assert my 11 BY MR. KUVIN: 12 federal constitutional rights as guaranteed by the 12 Q. Are you aware of that? 13 5th, 6th and 14th Amendment to the Constitution. 13 A. No. 14 BY MR. KUVIN: 14 Q. Okay. Are you aware that the FAA keeps track 15 Q. Did you tell people that was 15 ofall flights that are made both within the continental 16 your sex slave? 16 US and from the continental US abroad? 17 MR. PIKE: Same objection. 17 MR. PIKE: Saint objection. 18 THE WITNESS: I intend to respond to all 18 THE WITNESS: No. 19 relevant questions regarding this lawsuit; however, 19 BY MR. KUVIN: 20 at the present time, my attorneys have counseled me 20 Q. Do you know whether or not — let me ask it 21 I cannot provide answers to any questions relevant 21 this way: Have you ever seen the flight tracking 22 to this lawsuit. I must accept this advice or risk 22 information for any planes that you may own? 23 losing my 6th Amendment right to effective 23 A. 1don't believe so. 24 representation. Accordingly, I must assert my 24 Q. Is JEGE, Inc. a company that is owned by you? 25 federal constitutional rights as guaranteed by the 25 A. l'Ilhave to answer that question the way I've Page 218 Page 220 1 5th, 61h and 14th Amendment to the United States 1 answered most of your other questions here today, which 2 Constitution. Excuse me. 2 is, 1intend to respond to all relevant questions 3 MR. KUVIN: This is 19. 3 regarding this lawsuit; however, at the present time, my 4 (Plaintiffs Exhibit No. 19 was marked for 4 attorneys have counseled me I cannot provide answers to 5 identification.) 5 any questions relevant to this lawsuit. 1must accept 6 BY MR. KUVIN: 6 this advice or risk losing my 6th Amendment right to 7 Q. I have an FAA registry for a Boeing 727, 7 effective representation. Accordingly, I assert my 8 manufacture year 1969, with — I'm just looking for the 8 federal constitutional rights as guaranteed by the 5th, 9 tail number here. I'm sorry, I'm just hying to find 9 Gth and 14th Amendment to the United States 10 the tail number. 10 Constitution. 11 A. Not a problem. 11 Q. The plane that is identified in the FAA 12 Q. Let's do this, it's a Mode S Code 12 registry in the document marked Exhibit 19, just so 13 I'll show this to your counsel first. 13 we're clear, because I don't think I asked it exactly, 14 Here it is,19n sorry, Tail No. N908JE. 14 but is this your plane? 15 There's no question pending just yet. 15 A. I'm going to answer that question the same way 16 MR. PIKE: Thank you. 16 I've answered most of your questions today, Mr. Kuvin, 17 Okay. 17 which is, I intend to respond to all relevant questions 18 BY MR. KUVIN: 18 regarding this lawsuit; however, at the present time, my 19 Q. Let me show you what we marked as Exhibit 19. 19 attorneys have counseled me I cannot provide answers to 20 III give you a minute to take a look at that. 20 any questions relevant to this lawsuit. I must accept 21 A. Okay. 21 this advice or risk losing my 6th Amendment right to 22 Q. What is .1A EGE, Inc.? 22 effective representation. Accordingly, I assert my 23 A. T intend to respond to all relevant questions 23 federal constitutional rights as guaranteed by the 5th, 24 regarding this lawsuit; however, at the present time, my 24 61h and 14th Amendment to the United States 25 attorneys have counseled me I cannot provide answers to 25 Constitution. 13 (Pages 217 to 220) PROSE COURT REPORTING AGENCY, INC. Elictronlcalltilonird-by TanaTBoefuif — Electronically signed by Jenne Riceluti bf8d9d10.4feb-496c•a244-099977073134 EFTA01087067 Page 221 Page 223 1 Q. Isn't is true, sir, that you flew to Thailand 1 MR. PIKE: Same objections. 2 in 2001? 2 THE WITNESS: I intend -- 3 MR. PIKE: Form. 3 MR. PIKE: Relevance as well, excuse me. I'm 4 THE WITNESS: I intend to respond to all 4 sorry. S relevant questions regarding this lawsuit; however, 5 THE WITNESS: I intend to respond to all 6 at the present time, my attorneys have counseled me 6 relevant questions regarding this lawsuit; however, 7 I cannot provide answers to any questions relevant 7 at the present time, my attorneys have counseled me 8 to this lawsuit. 1 must accept this advice or risk 8 I cannot provide answers to any questions relevant 9 losing my 6th Amendment right to effective 9 to this lawsuit. I must accept this advice or risk 10 representation. Accordingly, I assert my federal 10 losing my 6th Amendment right to effective 11 constitutional rights as guaranteed by the 5th, Gth 11 representation. Accordingly, lessen my federal 12 and 14th Amendment to the United States 12 constitutional rights as guaranteed by the 5th, Gth 13 Constitution. 13 and 14th Amendments to the United States 14 BY MR. KUVIN: 14 Constiltdion. 15 Q. Is it true that you went to Thailand in 2001 15 BY MR. KUVIN: 16 with Prince Andrew? 16 Q. Did you bring any young women on the plane 17 MR. PIKE: Porn 17 with you when you went to Thailand in 2001? 18 THE WITNESS: I intend to respond to all 18 h4R. PIKE: Same objection. 19 relevant questions regarding this lawsuit; however, 19 THE WITNESS: I intend to respond to all 20 at the present time, my attorneys have counseled me 20 relevant questions regarding this lawsuit; however, 21 I cannot provide answers to any questions relevant 21 at the present time, my attorneys have counseled me 22 to this lawsuit, and as I've done for most of all 22 I cannot provide answers to any questions relevant 23 your questions today, Mr. Kuvin, I must accept this 23 to this lawsuit. I must accept this advice or risk 24 advice or risk losing my 6th Amendment right to 24 losing my 6th Amendment right to effective 25 effective representation. Accordingly, I assert my 25 representation. Accordingly, I assert my federal Page 222 Page 224 1 federal constitutional rights as guaranteed by the 1 constitutional rights as guaranteed by the 5th, 6th 2 Sth, 6th and 14th Amendment to the United States 2 and 14th Amendments to the United States 3 Constitution. 3 Constitution. 4 BY MR. KUVIN: 4 BY MR. KUVIN: 5 Q. Isn't it true that you went to Thailand in 5 Q. Have you brodtaabefore that you 6 2001 so that you could engage in sexual relations with 6 bought -- brought to the United States 7 girls under the age of 16 with Prince Andrew without any 7 to be your Yugoslavian sex slave? 8 fear of any legal recourse? 8 A. I intend to respond to all relevant questions 9 MR. PIKE: Same objection. In addition, 9 regarding this lawsuit; however, at the present time, my 10 improper hypothetical, lack of predicate, 10 nttorneys have counseled me I cannot provide answers to 11 foundation, argumentative, harassing. 11 any questions relevant to this lawsuit. I must accept 12 THE WITNESS: I intend to respond to all 12 their advice or risk losing my 6th Amendment right to 13 relevant questions regarding this lawsuit; however, 13 effective representation. Accordingly, I must assert my 14 at the present time, my attorneys have counseled me 14 federal constitutional rights as guaranteed by the 5th, 15 I cannot provide answers to any questions relevant 15 6th and 14th Amendments to the United States 16 to this lawsuit. I must accept this advice or risk 16 Constitution. 17 losing my 6th Amendment right to effective 17 Q. Have you had — 18 representation. Actordingly,1 must assert my 18 MR. GOLDBERGER: You raised the same objection 19 federal constitutional rights as guaranteed by the 19 to that question, right? 20 5th, 6th and 14th Amendment to the United States 20 MR. PIKE: Yeah, I did. 21 Constitution. 21 BY MR. KUVIN: 22 BY MR. KUVIN: 22 Q. Have you had sex with numerousgirls under the 23 Q. Have you seen the photographs of you and 23 age of 18 in the presence of= 24 Prince Andrew while you were in Thailand with half naked 24 MR. PIKE: Same objections. 25 women, some of which were under the age of 16? 25 THE WITNESS: I'm going to answer that the 14 (Pages 221 to 224) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans Rledull fascfronleeig signed by Joan. RlccMl bilided10-4fcb-496c-a244-09997 7073134 EFTA01087068 Page 225 Page 227 1 same way I've answered most of your questions here 1 BY MR. KUVIN: 2 today, Mr. Kuvin, which is, I intend to respond to 2 Q. I can do it that way, it doesn't matter to me. 3 all relevant questions regarding this lawsuit; 3 THE WITNESS: It's up to you. 4 however, at the present time, my attorneys have 4 MR. KUVIN: It's up to you guys. 5 counseled me I cannot provide answers to any 5 MR. PIKE: As I've said, Mr. Kuvin, if you 6 questions relevant to the lawsuit. I must accept 6 want to limit the time that we spend here today and 7 their advice or risk losing my 6th Amendment right 7 ask a compound question if you're going to list 8 to effective representation. Accordingly, I assert 8 various items or list Individuals by name and ask 9 my federal constitutional rights as guaranteed by 9 questions, I won't have a compound objection to 10 the 5th, 6th and 14th Amendments to the United 10 that type ofinquiry if it's in light of attempting 11 States Constitution. 11 to save time. 12 BY MR. KUVIN: 12 MR. KUVIN: Sure. 13 Q. What is MC2? 13 BY MR. KUVIN: 14 MR. PIKE: Same objection. 14 Q. All righty. 15 MB WITNESS: I don't understand the question. 15 MR. PIKE: But that's limited to the compound 16 BY MR. KUVIN: 16 objection. 17 Q. MC and then a number 2, what is that? 17 MR. KUVIN: Oh, no, that's fine. 18 MR. PIKE: Lack of predicate, foundation. 18 BY MR. KUVIN: 19 THE WITNESS: What is that? 19 Q. All right. Did you purchase something called 20 MR. PIKE: Irrelevant. 20 a Twin Torpedo, a soap made in the shape of a penis, and 21 BY MR. KUVIN: 21 a soap in the shape of a vagina? 22 Q. Do you know what it is? 22 A. I'm going to answer that question like I've 23 A. No. 23 answered most of your questions here today, which is, I 24 Q. You've never heard of that before? 24 intend to respond to all relevant questions regarding 25 A. MC2? 25 this lawsuit; however, at the present time, my attorneys Page 226 Page 228 Q. Yeah. Capital M, capital C, number 2; sound 1 have counseled me that I cannot provide answers to any 2 familiar at all? 2 questions relevant to this lawsuit. I must accept this A. Na 3 advice or risk losing my 6th Amendment right to Q. Okay. Are you part owner in a teen modeling 4 effective representation. Accordingly, I assert my 5 agency? 5 federal constitutional rights as guaranteed by the 5th, 6 A. Na 6 6th and 14th Amendment to the United States 7 Q. Do you own any interest in any modeling 7 Constitution. 8 agencies currently? 8 MR. PIKE: Additionally, just for the Courts 9 A. I intend to respond to all relevant questions 9 record, youre questioning the witness on Exhibit 10 regarding this lawsuit; however, nt the present time, my 10 No. what? 11 attorneys have counseled me I cannot provide answers to 11 MR. KUVIN: It's not an exhibit. It's the 12 any questions relevant to this lawsuit. I must accept 12 Town of Palm Beach Incident Repoli with respect to 13 this advice or risk losing my Gth Amendment right to 13 Jeffrey Epstein, of which I gave you a copy before. 14 effective representation. Accordingly, I assert my 14 And that was referencing, just so the record is 15 federal constitutional rights as guaranteed by the 5th, 15 clear, page 46. 16 6th and 14th Amendments to the United States 16 MR. PIKE: Then I would add additional 17 Constitution. 17 privileges and objections in addition to what 18 Q. Do you know what a sexual device called a Twin 18 Mr. Epstein has already raised underneath Florida 19 Torpedo is? 19 Rule of Criminal Procedure 3.220 and work product. 20 MR. PIKE: Same objections, irrelevant as 20 Not necessarily the document in front of you, but 21 worded. 21 the questions and the answer you're attempting to 22 THE WITNESS: Would you like to ask me a bunch 22 23 ofquestions or are we going to -- do you want to 23 BY MR. KUVIN: 24 individual answers to these? Do you want a 24 Q. Whose mobile wireless number is 25 compound question? 25 A. I Intend to respond to all relevant questions lizacsrnai,a,mrazwax, 15 (Pages 225 to 228) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Facelift' Electronically signed ----------------- bt8d9dI0-41cb-496c-a244-099977073134 EFTA01087069 Page 229 Page 231 1 regarding this lawsuit; however, at the present time, my 1 effective representation. Accordingly, I hereby assert 2 attorneys have counseled me I cannot provide answers to 2 my federal constitutional rights as guaranteed by the 3 any questions relevant to this lawsuit. I must accept 3 5th, 6th and 14th Amendments to the United States 4 this advice or risk losing my 6th Amendment right to 4 Constitution. 5 effective representation. Accordingly, I hereby assert 5 MR. PIKE: In addition, same objection and 6 my federal constitutional rights as guaranteed by the 6 privilege which regard to the Florida Rule of 7 5th, 6th and 14th Amendments to the United States 7 Procedure 3.220 and work product. Not necessarily 8 Constitution. 8 the document you're talking or speaking from, but 9 Q. Pm going to read you, for speed's sake, three 9 the testimony. 10 separate phone numbers, and it's the same question for 10 MR. KUVIN: I was just reading this. I wasn't 11 each. Do you recognize the following phone numbers? 11 asking questions from this at the moment. 12 They all have Area Code M. The first one is 12 BY MR. KUVIN: 13 the second is and the third is 13 Q. Does your penis have any deformities? 14 A. I intend to respond to all relevant questions 14 MR. PIKE: Form. 15 regarding this lawsuit; however, at the present time, my 15 THE WITNESS: I intend to respond to all 16 attorneys have counseled melcannot provide answers to 16 relevant questions regarding this lawsuit; however, 17 any questions relevant to this lawsuit. 1must accept 17 at the present time, my attorneys have counseled me 18 this advice or risk losing my 6th Amendment right to 18 I cannot provide answers the any questions relevant 19 effective representation. Accordingly, I must assert my 19 to the lawsuit. I must accept this advice or risk 20 federal constitutional rights as guaranteed by the 5th, 20 losing my 6th Amendment right to effective 21 6th and 14th Amendments to the United States 21 representation. Accordingly, I assert my federal 22 Constitution. 22 constitutional rights as guaranteed by the 5th, 6th 23 Did have the phone number 23 and 14th Amendment to the Constitution, as I've 24 or or El -- Pr ins , same number 24 done with most of your questions hero today. 25 again. So two numbers: Either on 25 Page 230 Page 232 1 A. I intend to respond to all relevant questions 1 BY MR. KUVIN: 2 regarding this lawsuit; however, at the present time, my 2 Q. Did you ever utilize Dollar-Rent-a-Car to rent 3 attorneys have counseled me I cannot provide answers to 3 cars while you were hero in Palm Beach at any time? 4 any questions relevant to the lawsuit. I must accept 4 A. I intend to respond to all relevant questions, this advice or risk losing my 6th Amendment right to 5 Mr. Kuvin, regarding this lawsuit; however, at the 6 effective representation. Accordingly, I must assert my 6 present time, my attorneys have counseled me I cannot 7 federal constitutional rights as guaranteed by the 5th, 7 provide answers to any questions that may prove relevant 8 6th and 14th Amendments to the Constitution. 8 to this lawsuit. I must accept this advice or risk 9 Q. Do you have an egg-shaped penis? 9 losing my 6th Amendment right to effective 10 A. I intend to respond to all relevant questions 10 representation. Accordingly, I must assert my federal 11 regarding this lawsuit; however, at the present time, my 11 constitutional rights as guaranteed by the 5th, 6th and 12 attorneys have counseled me I cannot provide answers to 12 14th Amendment to the United States Constitution. 13 any questions that may be relevant to this lawsuit. I 13 Q. What was your personal cell phone carrier back 14 must accept this advice or risk losing my 6th Amendment 14 in 2004? 15 right to effective representation. Accordingly, I must 15 A. I intend to respond to all relevant questions 16 assert my federal constitutional rights as guaranteed by 16 regarding this lawsuit. 17 the Sth, 6th and 14th Amendment to the United States 17 Q. Let me make this quicker. I'm sorry for 18 Constitution. 16 interrupting you, I apologize. Let's say, what was your 19 Q. Do you have any identifying marks on your 19 cell phone carrier back from 2004 through 2006. 20 penis? 20 MR. PIKE: And I'm not objecting to compound; 21 A. I intend to respond to all relevant questions 21 however, there are various allegations in your 22 regarding this lawsuit; however, at the present time, my 22 complaint regarding a time frame. So therefore, 23 attorneys have counseled mot I cannot provide answers to 23 with regard to the allegations in your complaint, 24 any questions relevant to the lawsuit. 1must accept 24 relative to your question, I'm not objecting to the 25 their advice or risk losing my 6th Amendment right to 25 compound, I'm saying it's overbroad. 16 (Pages 229 to 232) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciull Electronically signed by Jeana RIcciull bf8d9df0-4fcb.496e-a244-09997 7073134 EFTA01087070 Page 233 Page 235 1 MR. KUVIN: 2004 to 2006? 1 BY MR. KUVIN: 2 MR. PIKE: Overbroad and irrelevant based upon 2 Q. Here, let me move this out of the way. 3 the allegations that you've alleged. 3 A. You can take your Joy Jelly home now. 4 MR. KUVIN: All right. Well, let me clarify 4 Q. Its actually an exhibit to your deposition. 5 the question then. S A. Sorry. 6 BY ME. KUVIN: 6 Q. Have you read the police department's, the 7 Q. What was your cell phone carrier from 2004 to 7 Palm Beach Police Departments, probable cause 8 2005? 8 affidavit? Have youever read it? 9 MR. PIKE: Same objections. 9 MR. PIKE: Attorney-client, work privilege. 10 BY MR. KUV1N: 10 BY MR. KUVIN: 11 Q. Well, lel me try and fix it again. What was 11 Q. Have you over read the police department, Palm 12 your cell phone carrier from 2005 to 2006? 12 Beach Police Departments incident report regarding you? 13 MR. PIKE: Relevance. 13 MR. MICE: Same objection. 14 THE WITNESS: I intend to respond to all 14 MR. GOLDBERGER: Same objection. 15 relevant questions regarding this lawsuit; however, 15 MR. PIKE: And instruction, I'm sorry. 16 at the present time, my attorneys have counseled me 16 BY MR. KUVIN: 17 I cannot provide answers to any questions relevant 17 Q. Are you circumcised? 18 to this lawsuit. I must accept their advice or 18 MR. PIKE.• Objection, relevance. 19 risk losing my 6th Amendment right to effective 19 THE WITNESS: I intend to respond to all 20 representation; therefore, I must assert my federal 20 relevant questions regarding this lawsuit; however, 21 constitutional rights as guaranteed by the 5th, 6th 21 at the present time, my attorneys have counseled me 22 and 14th Amendments to the United States 22 I cannot provide answers to any questions relevant 23 Constitution. 23 to this lawsuit. I must accept this advice or risk 24 BY MR. KUVIN: 24 losing my 6th Amendment right to effective 25 Q. What were the cell phone carriers of 25 representation. Accordingly, I assert my federal Page 234 Page 236 1 or Chislaine Maxwell from the 1 constitutional rights as guaranteed by the 5th, 6th 2 years 2005 to 2006? 2 and 14th Amendments to the United States 3 MR. PIKE: Relevance. 3 Constitution. 4 THE WITNESS: I intend to respond to all 4 BY MR. KUVIN: 5 relevant questions regarding this lawsuit. As I've 5 Q. Was a search warrant performed and executed at 6 answered most of your questions the saute way today, 6 your home on Palm Beach Island? 7 Mr. Kuvin, at the present time, my attorneys have 7 MR. GOLDBERGER: Attorney-client, work 8 counseled me I cannot provide answers to any of 8 privilege. 9 your questions that may be relevant to this 9 Ill instruct you not to answer. 10 lawsuit. I must accept this advice or risk losing 10 BY MR. KUVIN: 11 my 6th Amendment right to effective representation. 11 Do n know spelled 12 Therefore, accordingly, I assert my federal 12 s led • or 13 constitutional rights as guaranteed by the 5th, Gth 13 14 and 14th Amendment to the United States 14 A. I intend to respond to all relevant questions 15 Constitution. 15 regarding this lawsuit; however, at the present time, my 16 May wo take a break, please? 16 attorneys have counseled me I cannot provide answers to 17 MR. KUVIN: Sure. 17 any questions relevant to this lawsuit. And as I've 18 MR.PIKE: Yes. 18 answered most of your questions today, Mr. Kuvin, I must 19 MR. GOLDBERGER: Yes. 19 accept this advice and risk losing -- or risk losing my 20 THE VIDEOGRAPHER: Going off the record at 20 Gth Amendment right to effective representation. 21 3:21. 21 Accordingly, I assert my federal constitutional rights 22 (A brief recess was taken.) 22 as guaranteed by the 5th, 6th and 14th Amendments to the 23 THE VIDEOGRAPHER: Were back on the record at 23 United States Constitution. 24 3:30. 24 Q. Did you have a chef working for you at your 25 25 Palm Beach home back in 2005? 17 (Pages 233 to 236) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans MGM Electronically signed by Jeans Elected bf8d9df04fcb-496c-a244-099977073134 EFTA01087071 Page 237 Page 239 A. I intend to respond to all relevant questions 1 BY MR. KUV1N: 2 regarding this lawsuit; however, at the present time, my 2 Q. -- or any other women in this case? 3 attorneys have counseled me I cannot provide answers to 3 MR. GOLDBERGER: Okay. Now attorney-client, 4 any questions relevant to this lawsuit at this time. I 4 work product. 5 must accept their advice or risk losing my 6th Amendment 5 I direct you not to answer. 6 right to effective representation. Accordingly, I must 6 BY MR. KUVIN: 7 assert my federal constitutional rights as guaranteed by 7 Q. Do you know the name of the girl that was with 0 the 5th, 6th and 14th Amendment to the United Slates 8 when she was brought to your home? 9 Constitution. 9 MR. PIKE: Form, lack of predicate, 10 MR. PIKE: Additionally, predicate and 10 foundation. 11 foundation. 11 THE WITNESS: Like I've done to many of your 12 BY MR. KUVIN: 12 other questions and responded to many of your other 13 Q. Did you own or do you currently own a 2004 13 questions today, Mr. Kuvin, that question -- I must 14 black Chevy Suburban, bearing Florida tag 14 answer that, I intend to answer all relevant 15 A. I intend to respond to all relevant questions 15 questions regarding this lawsuit; however, at the 16 regarding this lawsuit; however, at the present time, my 16 present time, my attorneys have counseled meI 17 attorneys have counseled me I cannot provide answers to 17 cannot provide answers to any questions that may be 18 any questions that may be relevant to the lawsuit. I 18 relevant. I must accept this advice or risk losing 19 must accept their advice or risk losing my 6th Amendment 19 my 6th Amendment right to effective representation; 20 right to effective representation; therefore, I assert 20 therefore, I assert my federal constitutional 21 my federal constitutional rights as guaranteed by the 21 rights as guaranteed by the 5th, 6th and I 4lb 22 5th, 6th and 14th Amendment to the United States 22 Amendment to the Constitution. 23 Constitution. 23 BY MR. KUVIN: 24 Q. I think I asked this before, and I apologize 24 Q. Did you, in fact, give M. 5200 for a -- for 25 if I did, but your date of birth is January 20, 1953, 25 her to get naked and give you a massage while you were 1 Page 238 Page 240 1 correct? 1 naked and, in addition, touch her in her vagina without 2 A. You asked that before. 2 her permission in 2005? 3 Yes, correct. 3 MR. PIKE: Predicate, foundation -- 4 Q. Okay, Pm sorry. 4 THE WITNESS: I believe that's been asked and Do you own a -- or did you own -- let me 5 answered. clarify. 6 MR. PIKE: Harassing. And I believe as A. Do you want to do compound again? I worded, that question has been asked and answered Q. Yeah. Did you or do you currently own a 2005 8 in sub parts. I believe you've asked those 9 black Cadillac Escalade ESV, bearing Florida license tag 9 questions initially at the beginning of this 10 a deposition. The same objections would, therefore, 11 A. I intend to respond to all relevant questions 11 apply and be incorporated. 12 regarding this lawsuit; however, at the present time, my 12 MR. KUVIN: I disagree, but... 13 attorneys have counseled me 1 cannot provide answers to 13 THE WITNESS: Like most of your other 14 any questions that may be relevant to the lawsuit. I 14 questions here today, I intend to respond to all 15 must accept their advice or risk losing my 6th Amendment 15 relevant questions regarding this lawsuit; however, 16 right to effective representation. Accordingly, 16 at the present time, my attorneys have counseled mo 17 assert my federal constitutional rights as guaranteed by 17 I cannot provide answers to any questions that may 18 the 5th, 6th and 14th Amendment to the United States 18 be relevant. I must accept this advice or risk 19 Constitution. 19 losing my 6th Amendment privilege. Accordingly, I 20 . Have you hired attorneys for either 20 assert my federal constitutional rights as 21 Ghislaine Maxwell, Cr any 21 guaranteed by the 5th, 6th and 14th Amendment to 22 other - 22 the US Constitution. 23 MR. GOLDBEROER: Attorney-client, work 23 BY MR. KUVIN: 24 product. 24 Q. Do ou agree, sir, that your conduct, with 25 Arc you done? l'm sorry. 25 respect toM., caused her severe emotional distress? 18 (Pages 237 to 240) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RIcciutI Electronically signed by Jeana Riveted bfededf0-4fcb49600244-099977073134 EFTA01087072 Page 241 Page 243 MR. PIKE: Same objection. In addition, it's 1 effective representation. Accordingly, I must assert my 2 argumentative, harassing and calls for a 2 federal constitutional rights as guaranteed by the 5th, 3 conclusion. 3 6th and 14th Amendments to the United States 4 THE WITNESS: Yin going to have to answer that 4 Constitution. the same way I've answered most of your questions 5 Q. Do you have a steam room in your home on Palm 6 today, Mr. Kuvin, which is, I intend to respond to 6 Beach Island? 7 all relevant questions regarding this lawsuit; 7 MR. PIKE: Same objections. 8 however, at the present time, my attorneys have 8 THE WITNESS: I'm going to answer that 9 counseled me I cannot provide answers to any 9 question the same way I've answered most of your 10 questions relevant to the lawsuit. I must accept 10 questions here today, which is, I intend to respond 11 this advice or risk losing my 6th Amendment right 11 to all relevant questions regarding this lawsuit; 12 to effective representation. Accordingly, I must 12 however, at the present time, my attorneys have 13 assert my federal constitutional rights as 13 counseled me that 1 cannot provide answers to any 14 guaranteed by the 5th, 6th and 14th Amendment. 14 questions relevant to the lawsuit. I must accept 15 BY MR. KUVIN: 15 this advice or risk losing my 6th Amendment right 16 Q. Do you have gray chest hair? 16 to effective representation. Accordingly, I must 17 A. I intend to respond to all relevant questions 17 assert my constitutional rights as guaranteed by 18 regarding this lawsuit; however, at the present time, my 18 the 5th — 5th, 6th and 14th Amendments to the 19 attorneys have counseled me I cannot provide answers to 19 United States Constitution. 20 any of those questions that may be relevant. I must 20 BY MR. KUVIN: 21 accept this advice or risk losing my 6th Amendment right 21 Q. Did you provide payments to underaged girls by 22 to effective representation. Accordingly, I assert my 22 utilizing cash and wire transfers through Western Union 23 federal constitutional rights as guaranteed by the 5th, 23 in 2004 or 20057 24 6th and 14th Amendments to the United States 24 MR. PIKE: Same objections as raised to the 25 Constitution. 25 previous last three questions incorporated here. Page 242 Page 244 1 Q. Have you told young ladies -- girls under the 1 THE WITNESS: I intend to respond to all 2 age of 18, when they came to your house and got naked to 2 relevant questions regarding this lawsuit; however, 3 give you a massage, quote, the more you do, the more you 3 at the present time, my attorneys have counseled me get paid? 4 I cannot provide answers to any questions relevant MR. PIKE: Objection, form, predicate, 5 to the lawsuit. I must accept this advice or risk foundation, improper hypothetical and assumes facts 6 losing my Gth Amendment right to effective not in evidence, relevance. 7 representation. Accordingly, I assert my federal 8 THE WITNESS: Lilco most of your questions, 8 constitutional rights as guaranteed by the 5th, 6th 9 Mr. Kuvin, today,1 intend to respond to all 9 and 14th Amendment to the United States 10 relevant questions regarding this lawsuit; however, 10 Constitution. 11 at the present time, my attorneys have counseled me 11 BY MR. KUVIN: 12 1 cannot provide answers to any questions relevant 12 Q. Did you -- excuse me. Did you take any 13 to this lawsuit. I must accept this advice or risk 13 videotapes of girls that were under the ago of 18 in 14 losing my 6th Amendment right to effective 14 your home on Palm Beach Island? 15 representation. Accordingly, I assert my federal 15 MR. PIKE: Same objections incorporated. 16 constitutional rights as guaranteed by the 5th, Gth 16 THE WITNESS: As I have with most of your 17 and 14th Amendment to the United States 17 questions today, Pm going to have to answer that, 18 Constitution. 18 I intend to respond to all relevant questions 19 BY MR. Kt./VIN: 19 regarding this lawsuit; however, at the present 20 Q. Do you have any tattoos? 20 time, my attorneys have counseled me I cannot 21 A. I intend to respond to all relevant questions 21 provide answers to any questions that may be 22 regarding this lawsuit; however, at the present time, my 22 relevant to this lawsuit. I must accept this 23 attorneys have counseled mel cannot provide answers to 23 advice or risk losing my 6th Amendment right to 24 any questions relevant to this lawsuit. I must accept 24 effective representation. Accordingly, I assert my 25 this advice or risk losing my 6th Amendment right to 25 federal constitutional rights as guaranteed by the 19 (Pages 241 to 244) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Jeana Meting bffidadlOsifeb-49k-a244-099977073134 EFTA01087073 Page 245 Page 247 1 5th, 6th and 14th Amendment to the United States 1 MR. KUVIN: Okay. All right, 1appreciate 2 Constitution. 2 your patience. That's all the questions that 1 3 BY MR. KUVIN: 3 have right now. I know that Mr. Goldberger needs 4 Q. Have you ever provided a dozen roses to a 4 to deal with an issue right now with Ms. Ezell young girl under the age of 18 who came to your house to 5 regarding any further questions. 6 give you a massage? 6 MR. GOLDBERGER: I think we clarified that. MR. PIKE: Form, vague, ambiguous, assumes 7 Ms. Ezell, are you there? 8 facts not In evidence. 8 MS. EZELL: Fm here. 9 THE WITNESS: I intend to respond to all 9 MR. GOLDBERGER: Yeah. You had a discussion 10 relevant questions regarding this lawsuit; however, 10 with Bob Critton already concerning the question 11 at the present time, my attorneys have counseled me 11 you raised with me earlier, right? 12 that I cannot provide answers to any questions that 12 MS. EZELL: Yes, I did, and I don't have any 13 may be relevant. I must accept their advice or 13 questions. 14 risk losing my 6th Amendment right to effective 14 MR. PIKE: Ms. Ezell, this is Michael Pike. I 15 representation. Accordingly, I must assert my 15 don't know what your conversation was with Bob, but 16 federal constitutional rights as guaranteed by the 16 did you cross notice this deposition? 17 5th, 6th and 14th Amendment. I MS. EZELL: No, I did not. 18 BY MR. KUVIN: 18 MR. PIKE: So what is your purpose of being 19 Q. Did you ever instruct anyone to deliver a 19 here? 20 bucket ofroses after a high school drama perforinanct to 20 My position is that those arc closed 21 an underaged girl? 21 proceedings and your client, your client did not 22 MR. PIKE: Same objection. in addition, lacks 22 cross notice this deposition and/or your clients. 23 predicate and foundation. It's overbroad as well. 23 So what is your purpose ofsitting in on this 24 THE WITNESS: I fully intend to respond to all 24 deposition? 25 relevant questions regarding this lawsuit; however, 25 MS. EZELL: Well, I received a notice of it, Page 246 Page 218 at the present time, my attorneys have counseled me 1 and I just thought I would listen to it while I was 2 that I cannot provide answers to any questions 2 doing some other work. And I don't know why it 3 relevant to the lawsuit. 1must accept their 3 would be a closed proceeding. advice or risk losing my 6th Amendment right to 4 MR. PIKE: Discovery proceedings arc closed if effective representation. Accordingly, I assert my 5 It's a pre-trial discovery, ma'am, it's not a court 6 federal constitutional rights as guaranteed by the 6 proceeding. 5th, 6th and 14th Amendment to the United States 7 Nonetheless, do you have any questions for the Constitution. 8 witness? 9 BY MR. KUVIN: MS. EZELL: No, I don't. 10 Q. Hold on a second. 1ma be done. 10 MR. PIKE: And Ms. Holmes, who am you here on 11 Do you know a Dr. 11 behalfof? Which clients? 12 A. I intend to respond to all relevant questions 12 MS. HOLMES: M. andM. 13 regarding this lawsuit; however, at the present time, my 13 MR. PIKE: Arai also here on behalfof lane 14 attorneys have counseled me I cannot provide answers to 14 Doe in the case 15 any questions that may be relevant. I must accept this 15 MS. HOLMES: 1 believe so, yes. 16 advice or risk losing my 6th right to effective 16 MR. PIKE: Do you have any questions for the 17 representation. Accordingly, I assert my federal 17 witness? 18 constitutional rights as guaranteed by the 5th, 6th and 18 MS. HOLMES: No, I do not. 19 14th Amendment to the United States Constitution. 19 MR. GOLDBERGER: Katherine, we're going to 20 MR. PIKE: Can you hold on one second? 20 end. Do you want me to disconnect you now? 21 MR. KUVIN: I'm almost done. 21 MS.FM t • Yes, thanks. 22 MR. PIKE: No, no. We're not going anywhere. 22 MR. GOLDBERGER: Okay. 23 MR. KUV1N: Okay. 23 THE VIDEOGRAPHER: Conclude the deposition and 24 MR. PIKE: Okay. 24 go off the record at 3:00-- 25 25 MR. PIKE: Wait one second. 20 (Pages 245 to 248 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans Ricoh/0 Bectronicatry signed by Jeans Ricclud bfildedtO4fcb-496c-a244.099977073134 EFTA01087074 Pa go 249 Page 251 MR. KUVIN: Oh, wait. 1 CERTIFICATE 2 2 TH€STATE OF FLORIDA MR. GOLDBERGER: He's just going to read. 3 COUNTY OF PALM REA°I 3 MR. PIKE: You didn't give the witness a 4 4 chance to read or waive and he'll read. S I, Jeana Ricauli, Renbared Professional Reporter aid Notary Public in and for the State of THE VIDEOGRAPHER: Conclude the deposition and 6 Florida at largo, do hereby certify that I was 6 go off the record at 3:48. This will be the end of authorized to and did report said deposition in 7 stenotype; and that the foregoing pages arc a truo and tape No. 3. correct transcription ofmy shorthand noes of said 8 8 deposition. 9 1 further certify that said deposition was 9 (Witness accused.) taken at the lime and place Fiereirrabowt set forth and 10 (Deposition was concluded.) 10 that the taking ofsaid deposition was commenced and 11 completed as hereinabovo set out. 11 12 I further certify that I am not attorney a 13 12 counsel ofuny of the parties, nor ant I a relative or employee of any attorney or counsel ofparty connected 14 3 %nth the action. nor am I financially interested in the 15 action. 14 16 The foregoing certification of this transcript 17 IS does not apply to nny reproduction of thc Mae by any 18 mean unless under the direct exact and/or direction 16 ofdie certifying reporter. 19 17 Dated this 8thday ofOctober, 2009. 20 18 19 21 20 22 21. *ea Riceiuti, PR,FPR, as 23 22 24 73 24 25 25 Page 250 Page 252 1 CERTIFICATE OF OATH 1 DAM Ocnber 21.2003 2 TO. WPM ErS1EDI 2 11113 STATE OF FLORIDA do Mcbael l.IW 3 3 EURA1.431, CIUTI0N,LOTTER it COLEMAN. PA COUNTY OF PALM BEACH 101}ewn 13onfoled 4 Suite 400 West Pact Head\ florid' 31.01 5 6 NAB' M. v. EPSTEIN 1, the undersigned authority, certify that JEFFREY EPSTEIN personally appeared before me and was NSW Isk• nom ths on1 hunday. doe Id) 7 O.-”beg, 21X9,y02gavemedepwidon hale a duly sworn on the 8th day of October, 2009. above reftere4 many Aolai did NI *lie tIgnaine. 14 is now meows tha1”54 signrui &miaow 10 Dated this 8th day of October, 2009. 9 As pinked). awed 00114 tonal/4w° be Ibreishe414 you teoush yew, tassel. Moe mad 11 10 the Itilay.ingimuudeaseirefblly. 12 At the end ofthe iganxiptpx. mill cud en 11 matt 5betL Asp) read yeue depoi6an, *Ay angst% 13 or cernxtions r:as xlshbamoke should be told on 14 12 the emu taecc thimpse Ind Ikx+Atoka Rid Nape. DONUT ca tetranwripl huff Once 1) you hwe te44.34 AM noes/ eny c.angto, le me to signrti daleoe ens.axe =Ireton tbese 15 14 prim me Jeana ificcluti, RPR, FPR, C 15 1404 42 no4 seal and sign Me 4epeauen xiihick a seesecable tine 0.0 30 dip unitsI:dentist 16 Notary Public - State of Florida direord)ihe 43(c.fybee•fonvoied 16 ti the advii5g Wong. mry be Med ‘541h Scathe( My Commission Expir 13 due Cart Wpm wilkatv.ther:eaisraer.‘sIgt 17 My Comntlssion No.: 1? termun In the Will .4 dm Winn *Mit butt te4 t to as 18 19 19 Very lauly)aue. 20 20 21 kin Fticciu6.RM,Flit CLR 22 it Prose Come Rteoting Atiecy, IM: 250S. /v..steslis.5 Aver -T. Ste 1500 23 22 Wc54 Pair Beech, floads 11401 10 lido hereby olive my Rinabore 24 24 25 25 MERRY EPSTEIN 21 (Pages 249 to 252) PROSE COURT REPORTING AGENCY, INC. -- ElictruntcTh --- CtRflittarbrcwva giUU Electronically signed by Jeans Riccluti bflIdedf041eb496e.4244.099977073134 EFTA01087075 Page 253 CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby codify that I have read the 6 foregoing deposition by me given, and that the statements contained herein are true and correct to the 8 best of my knowledge and belief, with the exception of 9 any corrections or notations made on the errata sheet, 10 if one was executed. 11 12 Dated this day of 13 2009. 14 15 16 17 18 19 JEFFREY EPSTEIN 20 21 22 23 24 25 Pao,' 1 RRATA SHEET 2 IN RE v. EPSTEIN CR:MARA RICCIUTI 3 N OP: JEFFREY EPSIE1N < TAKEN: October & 2009 DO NOT WRIIISON TRANSCRIPT -ENTER CHANGES HMI 6 PAGE P LINE I CHANOE REASON 7 tl 10 It 17 13 14 15 16 17 Please roma& the artful *macerate sheet sots (axe so teicoplim my be credbuted lo an peAm Under penalty of perjury. I declare dial I have reed my 19 &Toshio° a/laces id is two and cowect nb§eci to any changes in form or substance entered bere. 20 21 DATE: 22 23 stommuttucw DITONIPIT. 24 25 22 (Pages 253 to 254) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti Electronically signed by Joann Ricclutl bfildedf0-4fcb496c4244499977073134 EFTA01087076