EFTA01103326

Page 1 Page 3 IN THE CIRCUIT COURT OF THE FIFTEENTH 1 INDEX JUDICIAL CIRCUIT, IN AND FOR 2 Direct Examination by Mr. Edwards 4 PALM BEACH COUNTY, FLORIDA 3 4 EXHIBIT INDEX ) Plaintiffs Exhibit Hunter I marked for ID. 24 ) Plaintiff; 6 (Exhibit held by Attorney Edwards.) ) 7 vs. 149. +++++++++ ) 8 EPSTEIN and 9 ) 10 Deposition of JEFFREY EPSTEIN, a witness ) 11 of lawful age, taken by the Plaintiff, for the Defendants. ) 12 purpose of discovery and for use as evidence in the 13 above entitled cause, wherein: E.W. is the 14 Plaintiff, and JEFFREY EPSTEIN and- West Palm Bach, Florida 15 the Defendants, in the Circuit Court in and for Palm April 30th, 2009 16 Beach County, Florida, pursuant to notice heretofore I008 o'clock A.M. 17 filed, before LINDA P. AUKAMP, a Registered 18 Professional Reporter and Notary Public in and for 19 the State of Florida at Large, at 250 Australian VIDEOTAPED DEPOSITION 20 Avenue South, Suite 1400, West Patin Beach, Palm OF 21 Beach County, Florida, on the 30th day of April, JEFFREY EPSTEIN 22 23 2009, commencing at 10:08 o'clock A.M. I 24 25 Page 2 Page 1 APPEARANCES: 1 THEREUPON, 2 For The Plaintiff: 2 THE VIDEOGRAPHEEt: This is the 30th day 3 ROTHSTEIN, ROSENFELDT, ADLER 3 April, 2009. The time is 10:08 a.m. This is 401 East Las Olas Boulevard, Suite 1650 4 Fon Lauderdale, Florida, 33301.4252 4 videotaped ition of Jeffrey Epstein in the By BRADLEY JAMES EDWARD, ESQUIRE and 5 matter of... versus Epstein. This deposition 5 WILLIAM J. BERGER, ESQUIRE and 6 is being held at 250 Australian Avenue South, RUSSELL ADLER, ESQUIRE 6 7 West Palm Beach, Florida. My name is Jeff 7 For The Defendant Abbott, lam the videographer representing BURMAN, CRITTON, LUTHER & COLEMAN 9 Visual Evidence, Incorporated. S I5 North Plaster Drive, Suite 400 10 Would the attorneys please announce their 9 West Palm Beach, Florida 33401.4349 By JOHN MICHAEL BURMAN, ESQUIRE 11 appearances for the record. 10 12 MIt EDWARDS: Brad Edwards on behalf of 11 Also for the Defendant 3.3 the plaint' "deposition was set in 12 ATTER.BURY, GOLDBERGER & WEISS, P.A. the case of 3.4 250 Australian Ave. South, Suite 1400 13 West Palm Beach, Florida 33401 15 THE VIDEOGRAPHER: Oh. By JACK A. GOLDBERGER, ESQUIRE 16 MR. EDWARDS: That is a separate client of 14 17 mine, but that's not the case 15 Also Present: 16 Jeff Abbott, Videographer, Visual Evidence 18 THE VIDEOGRAPHER: Okay, that's what I 17 19 had. Sorry. 18 20 MR. BERGER: And Pm William J. Berger, 19 21 for the plaintiff, also. 20 21 22 MR. GOLDBERGER: Jack Goldberger on behal 22 23 of Jeffrey Epstein. 23 24 MR. BURMAN: Michael Burman on behalf of 24 25 25 le in. Mat'•-•••mil.N 1 (Pages 1 to 4) PALM BEACH REPORTING SERVICE, INC. EFTA01103326 Page 5 Page 7 1 THEREUPON, 1 length - 2 JEFFREY EPSTEiN, 2 MR. BURMAN: Obviously we can't tell what 3 Being a witness in the notice heretofore 3 you're going to play to a jury without the 4 filed, being of lawful age, and being first duly 4 entire spiel, what questions you night play to 5 sworn in the above cause, testified on his oath as 5 a jury if you decide to do that when this case 6 follows: 6 is tried, so we're going to go with the entire 7 THE WITNESS: Yes, I do. 7 spiel to every question you ask. If -- that's 8 DIRECT EXAMINATION 8 Mr. Goldberger's representation, or 9 Q. (By Mr. Edwards) Can you tell us your 9 recommendation. 10 fidl name for the record? 10 MR. EDWARDS: Okay. 11 A. Jeffrey Edward Epstein. 11 MR. GOLDBERGER: We will go question by 12 Q. And what's your date of birth? 12 question, and we may or may not invoke Fifth 13 A. January 20th, 1953. 13 Amendment privileges and there may be times 14 Q. And your social security number? 14 where I'm going to have to think about it, 15 A. 15 discuss it with Mr. Burman whether we're going 16 Q. And your current address in West Palm 16 to invoke on any particular question, but on 17 Beach? 17 those questions that we do invoke Fifth 18 A. I intend to respond to all relevant 18 Amendment privileges, I think we have no choice 19 questions regarding this lawsuit. However, at the 19 but, as you say, do the entire spiel. 20 present time my attorneys have counseled me that I 20 Q. (By Mr. Edwards) Can you tell me the 21 cannot provide answers to any questions relevant to 21 addresses of other homes that you own outside of 22 this lawsuit, and I must accept the advice or risk 22 West Palm Beach? 23 losing my Sixth Ansadment right to effective 23 A. I intend to respond to all relevant 24 representation. 24 questions regarding this lawsuit. However, in the 25 Accordingly, I assert my Fifth, Federal 25 present my attorneys have counseled me that I cannot Page 6 Page 8 3. Constitutional rights as guaranteed by the Fifth, 1 provide answers to any questions relevant to this 2 Sixth, and Fourteenth Amendments to the United 2 lawsuit, and i must accept the advice or risk losing 3 States Constitution. 3 my Sixth Amendment right to effective 4 Q. So you're unwilling to give us your 4 representation. 5 address of your house in Palm Beach Comity? Q. Have you seen any — 6 A. I intend to respond to all relevant 6 MR. GOLDBERGER: And, excuse me, and your 7 questions regarding this lawsuit. However, at the 7 Fifth Anwhipeat privileges. 8 present time my attorneys have counseled me that I 8 THE WITNESS: Yes. 9 cannot provide answers to any questions relevant to 9 Accordingly, i, excuse me, I assert my 10 this lawsuit or risk losing my Sixth Amendment right 10 Federal Constitutional rights as guaranteed by 11 to effective representation. 11 the Fifth, Sixth and Fourteen Amendments of the 12 MR. EDWARDS: Mr. Goldberger, can we enter 12 United States Constitution. 13 into an agreement so that we all know that he's 13 Q. (By Mr. Edwards) Have you seen any 14 reading off of that piece of paper, we know 14 psychologists a psychiatrists in your life? 15 what the whole spiel is, but maybe he can just 15 MR. GOLDBERGER: Go ahead. 16 say fifth or same answer or something like 16 THE WITNESS: I intend to respond to all 17 that, so we can continue to move on, rather 17 relevant questions regarding this lawsuit. 18 than read that paper the entire time? We'll be 18 However, at the present time my attorneys have 19 here for days. 19 counseled me that I cannot provide answers to 20 MR. GOLDBERGER: I think out of an 20 any questions relevant to this lawsuit, and i 21 abundance of caution ifs probably appropriate 21 must accept this advice or risk losing my Sixth 22 that whatever we feel is the proper response 22 Amendment right to effective representation. 23 is, so that our invocation of our Fifth 23 Accordingly. I assert my constitutional 24 Amendment privileges is properly protected, 24 rights as guaranteed by the Fifth, Sixth and 25 so I think we're noin to have to Ove the full 25 Fourteenth Amendment of that constitution. 2 (Pages 5 to 8 PALM BEACH REPORTING SERVICE, INC. EFTA01103327 Page 9 Page 11 1 Q. (By Mr. Edwards) Tell me the names of all 1 A. Sorry, could you repeat the question? 2 the businesses in which you are affiliated in any 2 Q. Sure. 3 way? 3 I have a videotaped copy of the plea 4 A. I intend to respond to all relevant 4 colloquy — 5 questions regarding this lawsuit. However, at the 5 A. No, the question before that. That's 6 present time my attorneys have counseled me that I 6 okay. 7 cannot provide answers to any questions relevant to 7 Q. The question is, where do you intend to 8 this lawsuit, and I must accept this advice or risk 8 reside once you are released from jail? 9 losing my Sixth Amendment right to effective 9 A. I intend to respond to all relevant 10 representation. 10 questions regarding this lawsuit. However, at the 11 I also assert my Federal Constitutional 11 present time my attorneys have counseled me that I 12 Rights as guaranteed by the Fifth, Sixth, and 12 cannot provide answers to any questions relevant to 13 Fourteenth Amendments to the United States 13 this lawsuit, and I must accept their advice or risk 14 Constitution. 14 losing my Sixth Amendment right to effective 15 Q. My understanding is you're currently 15 representation. 16 serving a 12-month jail sentence, is that correct? 16 Accordingly, I assert my Federal 17 MR. GOLDBERGER: You can answer, but -- 17 Constitutional right as guaranteed by the Fifth, 18 THE WITNESS: Na 18 Sixth, and Fourteenth Amendment of the United States 19 Q. (By Mr. Edwards) You were currently, you 19 Constitution. 20 were initially sentenced to 18 months in jail, is 20 Q. As you know, that question was asked to 21 that correct? 21 you when you pled guilty last June in 2008, and you 22 MR. GOLDBERGER: Go ahead. 22 responded to the judge that you planned to reside in 23 THE WITNESS: Yes. 23 West Palm Beach, Florida. Is that no longer your 24 Q. (By Mr. Edwards) And at the present 24 intent? 25 moment are you still under the supervision of that 25 A. I intend to respond to all relevant Page 10 Page 12 1 jail sentence? 1 questions regarding this lawsuit However, at the 2 A. Yes. 2 present time my attorneys have counseled me that I 3 Q. Do you !mow what your release date will 3 cannot provide answers to any questions relevant to 4 be? 4 this lawsuit, and I must accept this advice or risk S A. No. 5 losing my Sixth Amendment right to effective 6 Q. You have not been told the date of your 6 representation. 7 release? 7 Accordingly, I assert my Federal 8 A. Not yet. 8 Constitutional right as guaranteed by the Fifth, 9 Q. Where do you plan to reside when you're 9 Sixth, and Fourteenth Amendment of the constitution. 10 released from jail? 10 Q. This deposition is not being taken in the 11 A. I intend to respond to all relevant 11 county jail, but rather in your attorney, Jack 12 questions regarding this lawsuit. However, at the 12 Goldberger's office, so can you please inform the 13 present time my attorneys have advised me that I 13 jury as to your current schedule as it is exists 14 must accept the advice, advised me not to answer 14 today? 15 those questions. I must accept their advice or risk 15 MR GOLDBERGER: Let me hold off on that. 16 losing my Sixth Amendment right to effective 16 Okay. 17 representation. 17 THE WITNESS: I don't understand the 18 Accordingly, I assert my Federal 18 schedule, the question. 19 Constitutional right as guaranteed by the Fifth, 19 MR. GOLDBERGER: Yeah, if you can just, if 20 Sixth, and Fourteenth Amendment of the constitution. 2o you can rephrase the question, I think we can 21 Q. Mr. Epstein, I have a videotaped copy of 21 answer it for you. 22 the plea colloquy where you pled guilty and told 22 Q. (By Mr. Edwards) Okay. Currently you 23 that judge you would be residing in West Palm Beach, 23 described that you're under the supervision of the 24 Florida. Are you saying now that the statement you 24 jail sentence at this point in time, you're within 25 made to that inlEn312longer true? 25 the 18 months of your,jail sentence. But this isn't 3 (Pages 9 to 12) PALM BEACH REPORTING SERVICE, INC. EFTA01103328 Page 13 Page 15 1 a jail setting, so obviously you're outside of the 1 constitution. 2 jail setting. 2 Q. (By Mr. Edwards) Are you saying that 3 I am asking you just to tell the jury your 3 providing me an answer as to where you currently 4 current schedule; you wake up, are you released from 4 work, would somehow incriminate you? 5 jail at some time, do you have to report back to 5 MR. GOLDBERGER: Let's not be 6 jail on a daily basis? 6 argumentative. He responded to the question on 7 A. Yes, I report back to jail at 8:00 p.m. 7 advice of counsel, and if you think that was an 8 Q. Every single day? 8 improper invocation, then you have a remedy, 9 A. Yes. 9 but don't argue with the witness, which is what 10 Q. And is it seven days a week that you're 10 we did. Okay. 11 out on work release? 11 Q. (By Mr. Edwards) Do you have any plans to 12 A. No, sir. 12 leave the country once you're released from jail? 13 Q. How many days a week are you out on work 13 A. I intend to respond to all relevant 14 release? 14 questions regarding this lawsuit. However, at the 15 A. Six. 15 present time my attorneys have counseled me that I 16 Q. And of those six days, how many hours per 16 cannot provide answers to any questions relevant to 17 day are you out on work release? 17 this lawsuit, and must accept the advice or risk 18 A. Twelve. 18 losing my Sixth Amendment right to effective 19 Q. And what are the hours that you're out on 19 representation. 20 work release versus the hours that you are confined 20 Accordingly, I assert my Federal 21 to the jail? 21 Constitutional right as guaranteed by the Fifth, 22 A. Repeat the question, please. 22 Sixth, and Fourteenth Amendment of the constitution. 23 Q. What are the hours that you are out on 23 Q. Do you currently own any jets or 24 work release outside the jail versus the hours that 24 airplanes? 25 you are inside the jail, meaning if you report back 25 A. I intend to respond to all relevant Page 14 Page 16 1 to the jail at 8:00 and stay there until 8:00 in the 1 questions regarding this lawsuit. However, at the 2 morning, tell me that 2 present time my attorneys have counseled me that I 3 A. I just did. 3 cannot provide answers to any questions relevant to 4 Q. And is that the schedule? 4 this lawsuit, and must accept the advice or risk 5 A. !just did. Yes, that's the schedule. 5 losing my Sixth Amendment right to effective 6 Q. Okay. So from 8:00 p.m. until 8:00 an. 6 representation. 7 you're in the jail? 7 Accordingly, I assert my constitutional 8 A. Yes. 8 right as guaranteed by the Fifth, Sixth, and 9 Q. And then from 8.00 a.m. to 8:00 p.m. 9 Fourteenth Amendment ofirnstitution 10 you're out on work release? 10 MR. BURMAN: Is a state or federal 11 A. Is that a question? 11 case? 12 Q. Yes. 12 MR. EDWARDS: State. 13 A. Yes. 13 MR BURMAN: Okay. I am going to, in 14 Q. And where do you, where do you work? 14 addition to my client's assertion of his 15 MR. GOLDBERGER Objection. 15 rights, also object on the grounds that 16 THE WITNESS: I intend to respond to all 16 punitive damages hasn't been allowed in this 17 relevant questions to this lawsuit. However, 17 case yet. That's clearly a financial-type 18 at the present time my attorneys have counseled 18 question and, therefore, we object on those 19 me that I cannot provide answers to any 19 grounds, as well. 20 questions relevant to this lawsuit, and I must 20 MR. EDWARDS: Thank you. 21 accept this advice or risk losing my Sixth 21 Q. (By Mr. Edwards) Who are the pilots that 22 Amendment right to effective representation. 22 are employed by you or work for you or fly your 23 Therefore, I assert my Federal 23 airplanes? 24 Constitutional right as guaranteed by the 24 A. I intend to respond to all relevant 25 Fifth, Sixths and Fourteenth Amendment of the 25 questions regarding this lawsuit. However at the 4 (Pages 13 to 16) PALM BEACH REPORTING SERVICE, INC. EFTA01103329 Page 17 Page 19 1 present time my attorneys have counseled me that I 1 questions regarding this lawsuit However, at the 2 cannot provide answers to any questions relevant to 2 present time my attorneys have advised me that I 3 this lawsuit, and must accept their advice or risk 3 cannot provide answers to any questions currently. 4 losing my Sixth Amendment right to effective 4 Therefore, I must accept this advice or risk losing 5 representation. 5 my Sixth Amendment right to effective 6 Accordingly, I assert my Federal 6 representation. 7 Constitutional rights guaranteed by the Fifth, 7 Accordingly, ! assert my Federal 8 Sixth, and Fourteenth Amendment to the United States 8 Constitutional right as guaranteed by the Fifth, 9 Constitution. 9 Sixth, and Fourteenth Amendment to the constitution. 10 Q. What person or persons make your travel 10 Q. Are you currently working with the Florida 11 arrangements when you travel? 11 Science Foundation? 12 A. I intend to respond to all relevant 12 MR. GOLDBERGER: Umm, okay. 13 questions regarding this lawsuit However, at the 13 THE WITNESS: Yes. 14 present time my attorneys have advised me that I 14 Q. (By Mr. Edwards) And that is a, a 15 cannot provide answers to any questions relevant to 15 business that operates just next door to your 16 this lawsuit, and must accept this advice or risk 16 attorney, Jack Goldberger's office, is that correct? 17 losing my Sixth Amendment right to effective 17 A. No. 18 representation. 18 Q. The Florida Science Foundation does not 19 Accordingly, I would have to assert my 19 have an office on this floor right next door to your 20 Federal Constitutional right as guaranteed by the 20 attorney, Jack Goldberger's office? 21 Fifth, Sixth, and Fourteenth Amendment of the 23. A. Is that a question? 22 constitution. 22 Q. Yes. 23 Q. Once you are released from jail, are you 23 A. You have to rephrase the question, please? 24 under an obligation to report to probation? 24 Q. Does the Florida Science Foundation have 25 A. Yes. 25 an office right next door to your attorney, Jack Page 18 Page 20 1 Q. Do you intend to do so? 1 Goldbergees office? 2 A. Yes. 2 A. No. 3 Q. And once you are released, do you, 3 Q. What is your role with the Florida Science 4 according to your sentence, are you scheduled to 4 Foundation? 5 serve one year community control or house arrest? A. I intend to respond to all relevant 6 MR. GOLDBERGER: That's a compound 6 questions regarding this lawsuit. However, at the 7 question. Please rephrase it. 7 present time my attorneys have advised me that I 8 THE WITNESS: Yes. 8 cannot answer questions relevant to this lawsuit and 9 Q. (By Mr. Edwards) When you're released 9 must accept their advice, or risk losing my Sixth 10 from jail, do you intend to serve one year community 10 Amendment right to effective representstion. 11 control as a part of your sentence? 11 Therefore, I must assert my Federal 12 A. Yes. 12 Constitutional right under the Fifth, Sixth, and 13 Q. And under that provision, will you be able 13 Fourteenth Amendment to the constitution. 14 to continue working or will you be strictly confined 14 Q. What does the Florida Science Foundation 15 to your house? 15 do? 16 MR. GOLDBERGER: That calls for a legal 16 A. I intend to respond to all relevant 17 interpretation on the part of my client that 17 questions to this, regarding this lawsuit. However, 18 he's just not, he's just not competent to 18 at the present time my attorneys have counseled me 19 answer. So, if you know, fine, but I can't 19 that I cannot provide answers to any questions 20 imagine you would know. 20 relevant to this lawsuit i must accept their 23. THE WITNESS: I don't know. 21 advice or risk losing my Sixth Amendment right to 22 Q. (By Mr. Edwards) Who are the people that 22 effective representation. 23 will be living or working in your house once you are 23 Accordingly, lessen my Federal 24 released from jail? 24 Constitutional rights guaranteed by the Fifth, 25 A. I intend to respond to all relevant 25 Sixth, and Fourteenth Amendment to that 5 (Pages 17 to 20) PALM BEACH REPORTING SERVICE, INC. EFTA01103330 Page 21 Page 23 1 constitution. 1 to this lawsuit, and I must accept that advice or 2 Q. Have you procured minors for the purposes 2 risk losing their representation. 3 of prostitution? 3 Accordingly, I assert my Federal 4 A. I intend to respond to all relevant 4 Constitutional right as guaranteed by the Fifth, 5 questions to this, regarding this lawsuit However, 5 Sixth, and Fourteenth Amendment. 6 at the present time my attorneys have counseled me 6 Did you intentionally touch my client, 7 that I cannot provide answers to any questions 7 8 relevant to this lawsuit, and must accept their 8 A. I don't understand the question, sorry. 9 advice or risk losing my Sixth Amendment right to 9 Q. For the purpose of this lawsuit, we have 10 effective representation. 10 used the pseudonym to describe my client. Do you 13. Accordingly, I assert my Federal 11 know who Pm talking about when I refer toMil 12 Constitutional right as guaranteed by the Fifth, 12 A. I intend to respond to all relevant 13 Sixth and Fourteenth Amendment of the United States 13 questions to those, this lawsuit. However, at the 14 Constitution. 14 present time my attorneys have advised me that I 15 Q. Isn't it true that you did plead guilty to 15 cannot accept, answer any questions relevant to this 16 two felonies related to prostitution with minors? 16 lawsuit, and must accept their advice, or risk 17 MR. GOLDBERGER: Wait a minute, let me 17 losing my Sixth Amendment right to effective 18 just hold off a second. 18 rgrc istation. 19 (Thereupon, a discussion was had off 19 Q. Did you — 20 the record.) 20 A. Accordingly -- excuse me -- I assert my 21 MR. GOLDBERGER: You can answer the 21 Federal Constitutional right as guaranteed by the 22 question. 22 Fifth, Sixth, and Fourteenth Amendment to the United 23 THE WITNESS: Could you repeat the 23 States Constitution. 24 question? 24 MR. BURMAN: We further object on the 25 Q. (By Mr. Edwards) Isn't it true that you 25 ground tha name has not been disclosed Page 22 Page 24 1 pled guilty to two felony counts related to 1 and you've objected to that. 2 procurement of a minor for prostitution and/or 2 MR. EDWARDS: Thanks. 3 solicitation of a minor for prostitution? 3 (By Mr. Edwards) Did you touch my client 4 A. No. 4 NM, against her will? 5 Q. What counts did you plead guilty to? 5 A. We don't know who is. You haven't 6 A. Procuring a minor for prostitution and 6 told me who is. 7 soliciting prostitution. 7 Q. Okay. 8 Q. Have you had sex with minor girls? B MR. EDWARDS: Do you have an exhibit 9 A I intend to respond to all relevant slicker? 10 questions regarding this lawsuit. However, at the 10 (Thereupon, Plaintiffs Exhibit 11 present time my attorneys have advised me that I 11 Number 1 was marked for Identification by 12 cannot provide answers to any questions relevant to 12 Attorney Edwards.) 13 this lawsuit at the present time, and I must accept 13 Q. (By Mr. Edwards) Pm going to show you an 14 that advice or risk losing my Sixth Amencirnent right 14 exhibit that I have marked for identification 15 to effective representation. 15 purposes as Plaintiffs Exhibit 1. 16 Accordingly, I assert my Federal 16 Do you recognize the girl on the left in 17 Constitutional right under the Fifth, Sixth, and the 17 the photograph? 18 Fourteenth Amendment to the Constitution. 18 A. I intend to respond to all relevant 19 Q. Have you engaged in sex acts with girls 19 questions regarding — 20 who at the time you engaged in those sex acts were 20 THE WITNESS: Excuse me one second. 21 minors? 21 (Thereupon, a discussion was had off 22 A. I intend to respond to all relevant 22 the record.) 23 questions to this lawsuit. At the present time my 23 THE WITNESS: I intend to respond to all 24 attorneys have counseled me that I cannot respond, 24 relevant questions regarding this lawsuit. 25 I'm som. provide answers to any uestions relevant 25 Howeveriz2a theJre,sent time atto have 6 (Pages 21 to 24) PALM BEACH REPORTING SERVICE, INC. EFTA01103331 Page 25 Page 27 1 counseled me that I cannot provide answers to 1 A. I intend to respond to all relevant 2 any questions relevant to this lawsuit. I must 2 questions regarding this lawsuit. However, at the 3 accept their advice or risk losing my Sixth 3 present time my attorneys have counseled me that 1 4 Amendment right to effective representation. 4 cannot provide answers to any questions relevant to 5 Accordingly, I assert my Federal 5 this lawsuit, and 1 must accept this advice or risk 6 Constitutional right as given by the Fifth, 6 losing my Sixth Amendment right to effective 7 Sixth -- as provided by the Fifth, Sixth, and 7 representation. 8 Fourteenth Amendment to the constitution. 8 Accordingly, I assert my Federal 9 Q. (By Mr. Edwards Do you know somebody by 9 Constitutional right as guaranteed by the Fifth, 10 the name o 10 Sixth, and Fourteenth Amendment to the United States 11 A. I intend to respond to all relevant 11 Constitution. 12 questions regarding this lawsuit. However, at the 12 Q. Did you engage in sex or sex acts with a 13 present time my attorneys have counseled me that I 13 female named (phonetic)? 14 cannot provide answers to any questions relevant to 14 A. I intend to respon to all relevant 15 this lawsuit, and must accept their advice or risk 15 questions regarding this lawsuit. However, at the 16 losing my Sixth Amendment right to effective 16 present time my attorneys have counseled me that I 17 representation. 17 cannot provide answers to any questions relevant to 18 Accordingly, I assert my Federal 18 this lawsuit, and I must accept this advice or risk 19 Constitutional right as guaranteed by the Fifth, 19 losing my Sixth Amendment right to effective 20 Sixth and Fourteenth Amendment to the constitution. 20 representation. 21 Q. For the purposes of this deposition, when 21 Accordingly, I assert my Federal 22 I refer toM, I'm speaking of 22 Constitutional right under the Fifth, Sixth, and 23 Back to mthiitial questi . 23 Fourteenth Amendment of the constitution. 24 touch my client,.., against her will? 24 Q. Between 2001 and 2005 did you en 25 A. I intend to respond to all relevant 25 sex or sex acts with a minor female named Page 26 Page 28 1 questions regarding this lawsuit. However, at the 1 (phonetic)? 2 present time my attorneys have advised me that I 2 A. I intend to respond to all relevant 3 cannot provide answers to any questions relevant to 3 questions regarding this lawsuit. However, at the 4 this lawsuit, and must accept their advice or risk 4 present time my attorneys have counseled me that I 5 losing my Sixth Amendment right to effective 5 cannot provide answers to any questions relevant to 6 representation. 6 this lawsuit, and I must accept this advice or risk 7 Accordingly, I assert my Fifth, Sixth, and 7 losing my Sixth Amendment right to effective 8 Fourteenth — Fifth, Sixth and Fourteenth Amendment 8 representation. 9 of the constitution. 9 Accordingly, I assert my Federal 10 Q. Did engage in sex or sex acts with my 10 Constitutional rights as guaranteed by the Fifth, 11 clien against her will? 11 Sixth, and Fourteenth Amendment to the United States 12 A. I intend to respond to all relevant 12 Constitution. 13 questions regarding this lawsuit. However, at the 13 Q. Between 2001 and 2005 did vou engage in 14 present time my attorneys have advised me that I 14 sex or sex acts with a minor named Mphonetic)? 15 cannot provide any questions relevant to this 15 A. I intend to respond to all relevant 16 lawsuit, and must accept their advice or risk losing 16 questions regarding this lawsuit. However, at the 17 my Sixth Amendment right to effective 17 present time my attorneys have counseled me that I 18 representation. 18 cannot provide answers to any questions relevant to 19 Accordingly, I assert my Federal 19 this lawsuit, and I must accept this advice or risk 20 Constitutional right as guaranteed by the Fifth, 20 losing my Sixth Amendment right to effective 21 Sixth, and Fourteenth Amendment to that 21 representation. 22 constitution. 22 Accordingly, I assert my Federal 23 Q. Isn't it true that when you touthec. 23 Constitutional right as guaranteed by the Fifth, 24 against her will, you knew her to be a minor at the 24 Sixth, and Fourteenth Amendment to the United States 25 time? 25 Constitution. 7 (Pages 25 to 28) PALM BEACH REPORTING SERVICE, INC. EFTA01103332 Page 29 Page 31 1 Q. Between 2001 and 2005 did you will 1 Q. Between 2001 and 2005 did you eruriS 2 sex or sex acts with a minor female named 2 sex or sex acts with a minor female named 3 int (phonetic)? 3 (phonetic)? 4 A. I intend to respond to all relevant 4 A. I intend to respond to all relevant 5 questions regarding this lawsuit. However, at the 5 questions regarding this lawsuit. However, at this 6 present time my attorneys have counseled me that I 6 time my attorneys have counseled me that I cannot 7 cannot provide answers to any questions relevant to 7 provide answers to any questions relevant to this a this lawsuit, and must accept their advice or risk 8 lawsuit, and I must accept this advice or risk 9 losing my Sixth Amendment right to effective 9 losing my Sixth Amendment right to effective 10 representation. 10 representation. 11 Accordingly, i assert my Federal 11 Accordingly, I assert my Federal 12 Constitutional right as guaranteed by the Fifth, 12 Constitutional right as guaranteed by the Fifth, 13 Sixth, and Fourteenth Amendment to the United States 13 Sixth, and Fourteenth Amendment of the United States 14 Constitution. 14 Constitution. 15 MR. BURMAN: Mr. Edwards, can I inquire of 15 Q. Between 2001 and 2005 did you ensi 16 you one thing? Do you have a RICO count in 16 sex or sex acts with a minor female named 17 UN's case? 17 (phonetic)? 18 MR. EDWARDS: Yes. 18 A. I intend to respond to all relevant 19 MR. BURMAN: Okay. These other girls, are 19 questions regarding this lawsuit. However, at the 20 any of than your clients, as well? 20 present time my attorneys have counseled me that I 23. MR. EDWARDS: Some may be. 21 cannot provide answers to any questions relevant to 22 MR. BURMAN: Okay. Thank you. 2 2 this lawsuit, and must accept this advice or risk 23 MR. EDWARDS: Some are not. 23 losing my Sixth Amendment right to effective 24 MR. BURMAN: Okay. 24 representation. 25 Q. (By Mr. Edwards) Between 2001 and 2005 25 Accordingly, I assert my Federal Page 30 Page 32 1 did you engage in sex or sex acts with a minor 1 Constitutional rights as guaranteed by the Fifth, 2 female named IMIMEliphonetic)? 2 Sixth, and Fourteenth Amendment to the United States 3 A. I intend to respond to all relevant 3 Constitution. 4 questions regarding this lawsuit. However, at the 4 Q. Between 2001 and 2005 did you engage in 5 present time my attorneys have counseled me that I 5 sex or sex acts with a minor female named - 6 cannot provide answers to any questions relevant to 6 (phonetic)? 7 this lawsuit, and must accept this advice or risk 7 A. I intend to respond to all relevant B losing my Sixth Amendment right to effective a questions regarding this lawsuit. However, at the 9 representation. 9 present time my attorneys have counseled me that I 10 Accordingly, I assert my Federal 10 cannot provide answers to any questions relevant to 11 Constitutional rights as guaranteed by the Fifth, 11 this lawsuit I must accept this advice or risk 12 Sixth, and Fourteenth Amendment to the constitution. 12 losing my Sixth Amendment right to effective 13 Q. Between 2001 and 2005 did you engage in 13 representation. 14 sex or sex acts with a minor female named 14 Accordingly, I assert my Federal 15 (phonetic)? 15 Constitutional right under the Fifth, Sixth, and 16 A. I intend to respond to all relevant 16 Fourteenth Amendment to the constitution. 17 questions regarding this lawsuit. However, at the 17 Q. Between 2001 and 2005 did you e in 18 present time my attorneys have counseled me that I 18 sex or sex acts with a minor female named 19 cannot provide answers to any questions relevant to 19 (phonetic)? 20 this lawsuit, and I must accept this advice or risk 20 A. I intend to respond to all relevant 21 losing my Sixth Amendment right to effective 21 questions regarding this lawsuit However, at the 22 representation. 22 present time my attorneys have counseled me that I 23 Accordingly, I assert my Federal 23 cannot provide answers to any questions relevant to 24 Constitutional right as guaranteed by the Fifth, 24 this lawsuit, and must accept this advice or risk 25 Sixth ?. and Fourteenth Amendment to the constitution. 25 Iosing my Sixth Amendment right to effective 8 (Pages 29 to 32) PALM BEACH REPORTING SERVICE, INC. EFTA01103333 Page 33 Page 35 1 representation. 1 Fifth, Sixth, and Fourteenth Amendment to the 2 Accordingly, I assert my Federal 2 United States Constitution. 3 Constitutional right as guaranteed by the Fifth, 3 Q. (By Mr. Edwards) Between the year 2001 4 Sixth, and Fourteenth Amendment to the United States 4 and 2005 did you en ge in sex or sex acts with a 5 Constitution. 5 minor female named honetic)? 6 THE WITNESS: Can we take a break for, a 6 MR. BURMAN: O ect to form, vague and 7 bathroom break, is that okay? 7 indefinite. Last name, please. 8 THE VIDEOGRAPHER: We're off the record at 8 MR. EDWARDS: You can answer. 9 10:39. 9 THE WITNESS: I intend to respond to all 10 (Thereupon, a discussion was had off 10 relevant questions regarding this lawsuit. 11 the record.) 11 However, at the present time my attorneys have 12 THE VIDEOGRAPHER: We're back on the 12 counseled me that I cannot provide answers to 13 record at 10:44. 13 any questions relevant to this lawsuit. I must 14 Q. (By Mr. Edwards) Between 2001 and 2005 14 accept this advice or risk losing my Sixth 15 did you engaliisex or sex acts with a minor 15 Amendment right to effective representation. 16 female name' (phonetic)? 16 Accordingly, I assert my Federal 17 A. I intend to respond to all relevant 17 Constitutional rights as guaranteed by the 18 questions regarding this lawsuit. However, at the 18 Fifth, Sixth and Fourteenth Amendment to the 19 present time my attorneys have counseled me that I 19 United States Constitution. 20 cannot provide answers to questions relevant to this 20 Q. (By Mr. Edwards) Between 2001 and 2005 21 lawsuit, and I must accept their advice or risk 21 did you engage in sex or sex acts with a minor 22 losing my Sixth Amendment right to effective 22 female named (phonetic)? 23 representation. 23 MR. BURMAN: Object to form, vague and 24 Accordingly, I assert my Federal 24 indefinite. Last name, please. 25 Constitutional right as guaranteed by the Fifth, 25 MR. EDWARDS: You may answer. Page 34 Page 36 1 Sixth and the Fourteenth Amendment to the United 1 THE WITNESS: I intend to respond to all 2 States Constitution. 2 relevant questions regarding this lawsuit. 3 THE WITNESS: Can I see you a second, 3 However, at the present time my attorneys have 4 Mike? 4 counseled me that I cannot provide answers to 5 MIL BURMAN: Sure. 5 any questions relevant to this lawsuit, and 6 THE VIDEOORAPHER: We're off the record at 6 must accept this advice or risk losing my Sixth 7 10:45. 7 Amendment right to effective representation. 8 (Thereupon, a brief break was taken.) 8 Accordingly, I assert my Federal 9 THE VIDEOGRAPHER: Back on the record at 9 Constitutional right as guaranteed by the 10 10:46. 10 Fifth, Sixth and Fourteenth Amendment to the 11 Q. (By Mr. Edwards) Between the year 2001 11 United States constitution. 12 and 2005 did you eriy in sex or sex acts with a 12 Q. (By Mr. Edwards) Between 2001 and 2005 13 minor female named 13 did you engage in sex or sex acts with a minor 14 MR. BURMAN: Object to form, form vague 14 female named phonetic)? 15 and indefinite. Last name, please. 15 MR. BURMAN: Object to the form, vague and 16 MR. EDWARDS: You can answer the question. 16 indefinite. Last name, please. 17 THE WITNESS: I intend to respond to all 17 MR. EDWARDS: You can answer if - 18 relevant questions regarding this lawsuit 18 THE WITNESS: 1 intend to respond to all 19 However, at the present time my attorneys have 19 relevant questions regarding this lawsuit. 20 counseled me that I cannot provide answers to 20 However, at the present time my attorneys have 21 any questions relevant to this lawsuit, and 21 counseled me that I cannot provide answers to 22 must accept this advice or risk losing my Sixth 22 any questions relevant to this lawsuit. I must 23 Amendment right to effective representation. 23 accept this advice or risk losing my Sixth 24 Accordingly, I assert my Federal 24 Amendment right to effective representation. 25 Constitutional right as guaranteed b the 25 Accordinfy, I assert my Federal 9 (Pa -es 33 to 36) PALM BEACH REPORTING SERVICE, INC. EFTA01103334 Page 37 Page 39 1 Constitutional right as guaranteed by the 1 Accordingly, I assert my Federal 2 Fifth, Sixth and Fourteenth Amendment to the 2 Constitutional right as guaranteed by the 3 United States Constitution. 3 Fifth, Sixth, and Fourteenth Amendment to the 4 Q. (By Mr. Edwards) Between 2001 and 2005 4 United States Constitution. did you engage in sex or sex acts with a minor S Q. (By Mr. Edwards) Between 2001 and 2005 6 female named (phonetic)? 6 did you engage in sex or sex acts with a minor 7 MR. BURMAN: Object to form, vague and 7 female that you referred to as 8 indefinite. Last name, please. 8 (phonetic)? 9 MR. EDWARDS: You can answer, if you know. 9 MR. BURMAN: Object to form, vague and 10 THE WITNESS: 1 intend to respond to all 10 indefinite. Last name, please. 11 relevant questions regarding this lawsuit. 11 MR. EDWARDS: You can answer. 12 However, at the present time my attorneys have 12 MR. BURMAN: Or flavor. 13 counseled me that I cannot provide answers to 13 THE WITNESS: I intend to respond to all 14 any questions relevant to this lawsuit. I must 14 relevant questions regarding this lawsuit. 15 accept this advice or risk losing my Sixth 15 However, at the present time my attorneys have 16 Amendment right to effective representation. 16 counseled me that I cannot provide answers to 17 Accordingly, I assert my Federal 17 any questions relevant to this lawsuit, and 18 Constitutional right as guaranteed by the 18 must accept this advice or risk losing my Sixth 19 Fifth, Sixth, and Fourteenth Amendment to the 19 Amendment right to effective representation. 20 United States Constitution. 20 Accordingly, I assert my Federal 21 Q. (By Mr. Edwards) Between 2001 and 2005 21 Constitutional right as guaranteed by the 22 did you engaga in sex or sex acts with a minor 22 Fifth, Sixth, and Fourteenth Amendment to the 23 female named (phonetic)? 23 constitution. 24 MR. BURMAN: Object to form, vague and 24 Q. (By Mr. Edwards) Between 2001 and 2005 25 indefinite. Last name, please. 25 did you engage in sex or sex acts with a minor Page 38 Page 40 1 MR. EDWARDS: You can answer. 1 female named phonetic)? 2 THE WITNESS: I intend to respond to all 2 MR. 13 : Object to form, vague and 3 relevant questions regarding this lawsuit. 3 indefinite. Last name, please. 4 However at the present time my attorneys have 4 MR. EDWARDS: You can answer. 5 counseled me that I cannot provide answers to 5 THE WITNESS: I intend to respond to all 6 any questions relevant to this lawsuit, and 6 relevant questions regarding this lawsuit 7 must accept this advice or risk losing my Sixth 7 However, at the present time my attorneys have 8 Amendment right to effective representation. 8 counseled me that I cannot provide answers to 9 Accordingly, I assert my Federal 9 any questions relevant to this lawsuit, and 10 Constitutional right as guaranteed by the 10 must accept this advice or risk losing my Sixth 11 Fifth, Sixth, and Fourteenth Amendment to the 11 Amendment right to effective representation. 12 United States Constitution. 12 Q. (By Mr. Edwards) Between -- 13 Q. (By Mr. Edwards) Between 2001 and 2005 13 THE WITNESS: Sorry? 14 did you engage in sex or sex acts with a minor 14 MR. EDWARDS: I didn't realize you weren't 15 female named (phonetic)? 15 finished. 16 MR. BURMAN: Object to form, vague and 16 THE WITNESS: Accordingly, I assert my 17 indefinite. Last name, please. 17 Federal Constitutional right as guaranteed by 18 MR. EDWARDS : You can answer. 18 the Fifth, Sixth and Fourteenth Amendment to 19 THE WITNESS: i intend to respond to all 19 the United States Constitution. 20 relevant questions regarding this lawsuit 20 Q. (By Mr. Edwards) Between 2001 and 2005 21 However, at the present time my attorneys have 21 did you in sex or sex acts witha 12-year-old 22 counseled me that I cannot provide answers to 22 girl named onetic)? 23 any questions relevant to this lawsuit, and 23 MR B : Object to form, vague and 24 must accept this advice or risk losing my Sixth 24 indefinite. Last name, please. 25 Amendment right to effective representation. 25 MR. EDWARDS: You can answer. 10 (Pages 37 to 4 0) PALM BEACH REPORTING SERVICE, INC. EFTA01103335 Page 41 Page 43 1 THE WITNESS: I intend to respond to all 1 MR. EDWARDS: You can answer. 2 relevant questions regarding this lawsuit. 2 THE WITNESS: I intend to respond to all 3 However, at the present time my attorneys have 3 relevant questions regarding this lawsuit. 4 counseled me that I cannot provide answers to 4 However, at the present time my attorneys have 5 any questions relevant to this lawsuit, and 5 counseled me that I cannot provide answers to 6 must accept this advice or risk losing my Sixth 6 any questions relevant to this lawsuit, and 7 Amendment right to effective representation. 7 must accept this advice or risk losing my Sixth 8 Accordingly, I assert my Federal 8 Amendment right to effective representation. 9 Constitutional right as guaranteed by the 9 Accordingly, I assert my Federal 10 Fifth, Sixth, and Fourteenth Amendment to the 10 Constitutional right as guaranteed by the 11 constitution. 11 Fifth, Sixth, and Fourteenth Amendment to the 12 Q. (By Mr. Edwards) Between 2001 and 2005 12 United States Constitution. 13 did you engage in sex or sex acts with a minor 13 Q. (By Mr. Edwards) Between 2001 and 2005 14 female named (phonetic)? 14 did you engage in sex or sex acts with a minor 15 MR. BURMAN: Object to form, vague and 15 female namedM (phonetic)? 16 indefinite. Last name, please. 16 MR. BURMAN: Object to form, vague and 17 MR. EDWARDS: You can answer. 17 indefinite. Last name, please. 18 THE WITNESS: I intend to respond to all 18 MR. EDWARDS: You may answer. 19 relevant questions regarding this lawsuit. 19 THE WITNESS: I intend to respond to all 20 However, at the present time my attorneys have 20 relevant questions regarding this lawsuit. 21 counseled me that I cannot provide answers to 21 However, at the present time my attorneys have 22 any questions relevant to this lawsuit. I must 22 counseled me that I cannot provide answers to 23 accept their advice or risk losing my Sixth 23 any questions relevant to this lawsuit, and 24 Amendment right to effective representation. 24 must accept this advice or risk losing my Sixth 25 Accordingly, I assert my Federal 25 Amendment right to effective representation. Page 42 Page 44 1 Constitutional right as guaranteed by the 1 Accordingly, I assert my Federal 2 Fifth, Sixth and the Fourteenth Amendment to 2 Constitutional right as guaranteed by the 3 the constitution. 3 Fifth, Sixth, and Fourteenth Amendment of the 4 Q. (By Mr. Edwards) Between 2001 and 2005 4 United States Constitution. 5 did you engage in sex or sex acts with a minor 5 Q. (By Mr. Edwards) Between 2001 and 2005 6 female named =phonetic)? 6 did you engagejash or sex acts with a minor 7 MR. BURMAN: Object to form, vague and 7 female named .MA (phonetic)? 8 indefinite. Last name, please. 8 MR. BURMAN: Object to form, vague and 9 THE WITNESS: I intend to respond to all 9 indefinite. Last name, please. 10 relevant questions regarding this lawsuit. 10 MR. EDWARDS: You can answer. 11 However, at the present time my attorneys have 11 THE WITNESS: I intend to iespund to all 12 counseled me that I cannot provide answers to 12 relevant questions regarding this lawsuit. 13 any questions relevant to this lawsuit, and 13 However, at the present time my attorneys have 14 must accept their advice or risk losing my 14 counseled me that I cannot provide answers to 15 Sixth Amendment right to effective 15 any questions relevant to this lawsuit, and I 16 representation. 16 must accept this advice or risk losing my Sixth 17 Accordingly, I assert my Federal 17 Amendment right to effective representation. 18 Constitutional right as guaranteed by the 18 Accordingly, I assert my Federal 19 Fifth, Sixth, and Fourteenth Amendment to the 19 Constitutional right as guaranteed by the 20 United States Constitution. 20 Fifth, Sixth, and Fourteenth Amendment to the 21 Q. (By Mr. Edwards) Between 2001 and 2005 21 United States Constitution. 22 did you e in sex or sex acts with a minor 22 MR. GOLDBERGER: One moment 23 female (phonetic)? 23 (Thereupon, a discussion was had off 24 MR. BURMAN: Object to form, vague and 24 the record.) 25 indefinite. Lastname,please. 25 ,.., 11LaoheresAttorney Adler entered 11 (Pages 41 to 44) PALM BEACH REPORTING SERVICE, INC. EFTA01103336 Page 45 Page 47 1 the deposition room) 1 Constitutional rights as guaranteed by the 2 MR. EDWARDS: We're back on. 2 Fifth, Sixth, and Fourteenth Amendment to the 3 Q. (By Mr. Edwards) Between 2001 and 2005 3 United States Constitution. 4 did you enpgsm sex or sex acts with a minor 4 Q. (By Mr. Edwards) Between 2001 and 2005 5 female named (phonetic)? 5 did you engage in sex or sex acts with a minor 6 MR. BURMAN: Object to form, vague and 6 female named (phonetic)? 7 indefinite. Last name, please. 7 MR. BURMAN: Object to the form, vague and 8 MR. EDWARDS: You can answer. 8 indefinite. Last name, please. 9 THE WITNESS: I intend to respond to all 9 MR. EDWARDS: You can answer. 10 relevant questions regarding this lawsuit. 10 THE WITNESS: I intend to respond to all 11 However, at the present time my attorneys have 11. relevant questions regarding this lawsuit. 12 counseled me that I cannot provide answers to 12 However, at the present time my attorneys have 13 any questions relevant to this lawsuit, and 13 counseled me that I cannot provide answers to 14 must accept this advice or risk losing my Sixth 14 any questions relevant to this lawsuit, and 15 Amendment right to effective representation. 15 must accept this advice or risk losing my Sixth 16 Accordingly, I assert my Federal 16 Amendment right to effective representation. 17 Constitutional right as guaranteed by the 17 Accordingly, I assert my Federal 18 Fifth, Sixth, and Fourteenth Amendment to the 18 Constitutional right as guaranteed by the 19 constitution. 19 Fifth, Sixth, and Fourteenth Amendment to the 20 Q. (By Mr. Edwards) Between 2001 and 2005 20 United States Constitution. 21 did you engage in sex or sex acts with a minor 21 Q. (By Mr. Edwards) Between 2001 and 2005 22 female named phonetic)? 22 did you engage in sex or sex acts with a minor 23 MR. BURMAN: Object to form, vague and 23 female named 111.111(phonetic)? 24 indefinite. Last name, please. 24 MR. BURMAN: Object to form, vague and 25 MR. EDWARDS: You may answer. 25 indefinite. Last name, please. Page 46 Page 48 1 THE WITNESS: I intend to respond to all 1 MR. EDWARDS: You can answer. 2 relevant questions regarding this lawsuit. 2 THE WITNESS: I intend to respond to all 3 However, at the present time my attorneys have 3 relevant questions regarding this lawsuit. 4 counseled me that I cannot provide answers to 4 However, at the present time my attorneys have 5 any questions relevant to this lawsuit, and 5 counseled me that I cannot provide answers to 6 must accept this advice or risk losing my Sixth 6 any questions relevant to this lawsuit, and 7 Amendment right to effective representation. 7 must accept this advice or risk losing my Sixth 8 Accordingl y, I assert my Federal 8 Amendment right to effective representation. 9 Constitutional rights as guaranteed by the 9 Accordingly, I assert my Federal 10 Fifth, Sixth, and the Fourteenth Amendmen t to 10 Constitutional right as guaranteed by the 11 the United States Constitution. 11 Fifth, Sixth, and Fourteenth Amendment to the 12 Q. (By Mr. Edwards) Between 2001 and 2005 12 United States Constitution. 13 did you engage in sex or sex acts with a minor 13 Q. (By Mr. Edwards) Between 2001 and 2005 14 female named phonetic)? 14 did you engage in sex or sex acts with a minor 15 MR BURMAN: Object to form, vague and 15 female named phonetic)? 16 indefinite. Last name, please. 16 MR. BURMAN Object to form, vague and 17 MR. EDWARDS: You may answer. 17 indefinite. And last name, please? 18 THE WITNESS: I intend to respond to all 18 MR. GOLDBERGER: Is that or 19 relevant questions regarding this lawsuit. 19 IIIIIIP 20 However, at the present time my attorneys have 20 MR. EDWARDS: — dra. 21 counseled me that I cannot provide answers to 21 THE WITNESS: I intend to respond to all 22 any questions relevant to this lawsuit, and I 22 relevant questions regarding this lawsuit. 23 must accept this advice or risk losing my Sixth 23 However, at the present time my attorneys have 24 Amendment right to effective representati on. 24 counseled me that I cannot provide answers to 25 Accordingly. I assert my Federal 25 any questions relevant to this lawsuit, and 12 (Pages 45 to 48) PALM BEACH REPORTING SERVICE, INC. EFTA01103337 Page 49 Page 51 1 must accept this advice or risk losing my Sixth 1 any questions relevant to this lawsuit, and 2 Amendment right to effective representation. 2 must accept this advice or risk losing my Sixth 3 Accordingly, I assert my Federal 3 Amendment right to effective representation. 4 Constitutional right as guaranteed by the 4 Accordingly, I assert my Federal 5 Fifth, Sixth, and Fourteenth Amendment to the 5 Constitutional right as guaranteed by the 6 United States Constitution. 6 Fifth, Sixth, and Fourteenth Amendment to the 7 Q. (By Mr. Edwards) Between 2001 and 2005 7 United States Constitution. 8 did you engage in sex or sex acts with a minor 8 Q. (By Mr. Edwards) Between 2001 and 2005 9 female named (phonetic)? 9 did you engage in sex or sex acts with a minor 10 MR. BURMAN: Object to form, vague and 10 female named =phonetic)? 11 indefinite. Last name, please. 11 MR. BURMAN: Object to form, vague and 12 MR. EDWARDS: You can answer. 12 indefinite. Last name, please. 13 THE WITNESS: I intend to respond to all 13 MR. EDWARDS: You can answer. 14 relevant questions regarding this lawsuit. 14 THE WITNESS: I intend to respond to all 15 However, at the present time my attorneys have 15 relevant questions regarding this lawsuit 16 counseled me that I cannot provide answers to 16 However, at the present time my attorneys have 17 any questions relevant to this lawsuit, and I 17 counseled me that I cannot provide answers to 18 must accept this advice or risk losing my Sixth 18 any questions relevant to this lawsuit, and I 19 Amendment right to effective representation. 19 must accept this advice or risk losing my Sixth 20 Accordingly, I assert my Federal 20 Amendment right to effective representation. 21 Constitutional rights as guaranteed by the 21. Accordingly, I assert my Federal 22 Fifth, Sixth, and Fourteenth Amendment to the 22 Constitutional right as guaranteed by the 23 United States Constitution. 23 Fifth, Sixth, and Fourteenth Amendment to the 24 Q. (By Mr. Edwards) Between 2001 and 2005 24 United States Constitution. 25 did you engage in sex or sex acts with a minor 25 Q. (By Mr. Edwards) Between 2001 and 2005 Page 50 Page 52 1 female namedd hbonetic)? 1 did you engage in sex or sex acts with a minor 2 MR. B : jest to form, vague and 2 female named (phonetic)? 3 indefinite. Last name, please. 3 MR. BURMAN: Object to form, vague and 4 MR. EDWARDS: You can answer. 4 indefinite. Last name, please. 5 THE WITNESS: I intend to respond to all 5 MR. EDWARDS: You can answer. 6 relevant questions regarding this lawsuit. 6 THE WITNESS: I intend to respond to all 7 However, at the present time my attorneys have 7 relevant questions regarding this lawsuit. 8 counseled me that I cannot provide answers to 8 However, at the present time my attorneys have 9 any questions relevant to this lawsuit, and I 9 counseled me that I cannot provide answers to 10 must accept this advice or risk losing my Sixth 10 any questions relevant to this lawsuit, and I 11 Amendment right to effective representation. 11 must accept this advice or risk losing my Sixth 12 Accordingly , I assert my Federal 12 Amendment right to effective representation. 13 Constitutional right as guaranteed by the 13 Accordingly, I assert my Federal 14 Fifth, Sixth, and Fourteenth Amendmen t to the 14 Constitutional right as guaranteed by the 15 United States Constitution. 15 Fifth, Sixth, and Fourteenth Amendment of the 16 Q. (By Mr. Edwards) Between 2001 and 2005 16 United States Constitution. 17 did you engage in sex or sex acts with a minor 17 Q. (By Mr. Edwards) Between 2001 and 2005 18 female named bonetic)? 18 did you engage in sex or sex acts with a minor 19 MR. BURMAN: bject to form, vague and 19 female named (phonetic)? 20 indefinite. Last name, please. 20 MR. BURMAN: Object to form, vague and 21 MR. EDWARDS: You can answer. 21 indefinite. Last name, please. 22 THE WITNESS: I intend to respond to all 22 MR. EDWARDS: You can answer. 23 relevant questions regarding this lawsuit. 23 THE WITNESS: I intend to respond to all 24 However, at the present time my attorneys have 24 relevant questions regarding this lawsuit. 25 counseled me that I cannot provide answers to 25 However at the present time myttome s have - 13 (Pages 49 to 52) PALM BEACH REPORTING SERVICE, INC. EFTA01103338 Page 53 Page 55 1 counseled me that I cannot provide answers to 1 any questions relevant to this lawsuit, and 2 any questions relevant to this lawsuit, and I 2 must accept this advice or risk losing my Sixth 3 must accept this advice or risk losing my Sixth 3 Amendment right to effective representation. 4 Amendment right to effective representation. 4 Accordingly, I assert my Federal Accordingly, I assert my Federal 5 Constitutional right as guaranteed by the 6 Constitutional right as guaranteed by the 6 Fifth, Sixth, and Fourteenth Amendment to the 7 Fifth, Sixth, and Fourteenth Amendment to the 7 United States Constitution. 8 United States Constitution 8 Q. (By Mr. Edwards) For the purposes of 9 Q. (By Mr. Edwards) Between 2001 and 2005 9 these next questions, when I refer to "the minor 10 did you engage in sex or sex acts with a minor 10 Its" I'm refeninc to 11 female named El==. 11 12 MR. BURMAN: Object to form, vague and 12 13 indefinite. Last name, please. 13 14 MR. EDWARDS: You can answer. 14 15 THE WITNESS: I intend to respond to all 15 16 relevant questions regarding this lawsuit. 16 17 However, at the present time my attorneys have 17 18 counseled me that I cannot provide answers to 18 S, my client, which is 19 any questions relevant to this lawsuit, and I 19 the plaintiff in this lawsuit. 20 must accept this advice or risk losing my Sixth 20 My question is -- 21 Amendment right to effective representation. 21 MR. GOLDBERGER: You've identified that 22 Accordingly, I assert my Federal 22 correct? 1 23 Constitutional right as guaranteed by the 23 MR. EDWARDS: Correct. 24 Fifth, Sixth, and Fourteenth Amendment to the 24 Q. (By Mr. Edwards) With each of these 25 constitution. 25 girls, isn't it true that you paid somebody else to Page 54 Page 56 1. Q. (By Mr. Edwards) Isn't it true that at 1 bring them to your house? 2 the time you engaged in sex or sex acts with each of 2 MR. BURMAN: Object to the form, vague and 3 the people we have just discussed, you knew they 3 indefinite. 4 were minors? 4 THE WITNESS: I intend to respond to all 5 MR. BURMAN: Object to form. 5 relevant questions regarding this lawsuit 6 THE WITNESS: I intend to respond to all 6 However, at the present time my attorneys have 7 relevant questions regarding this lawsuit. 7 counseled me that I cannot provide answers to 8 However, at the present time my attorneys have any questions relevant to this lawsuit, and 9 counseled me that I cannot provide answers to 9 must accept this advice or risk losing my Sixth 10 any questions relevant to this lawsuit, and 10 Amendment right to effective representation. 11 must accept this advice or risk losing my Sixth 11 Accordingly, ! assert my Federal 12 Amendment right to effective representation. 12 Constitutional right as guaranteed by the 13 Accordingly, I assert my Federal 13 Fifth, Sixth, and Fourteenth Amendment to the 14 Constitutional right under the Fifth, Sixth, 14 United States Constitution. 15 and Fourteenth Amendment to the United States 15 Q. (By Mr. Edwards) For each of these minor 16 Constitution. 16 girls, isn't it true that you paid each of them for 17 Q. (By Mr. Edwards) With each of these 17 sex or sex acts? 18 girls, isn't it hue that you used someone else to 18 MR. BURMAN: Object to form, vague and 19 recruit them to your house? 19 indefinite. Further explaining that to the 20 MR. BURMAN: Object to form, vague and 20 extent that no ►ast names have been identified 23. indefinite. 21 for most of the girls. 22 THE WITNESS: I intend to respond to all 22 MR. EDWARDS: You can answer. 23 relevant questions regarding this lawsuit. 23 THE WITNESS: I intend to respond to all 24 However, at the present time my attorneys have 24 relevant questions regarding this lawsuit. 25 counseled me that I cannot rovide answers to 25 However at the .resent time attom have 14 Pa es 53 to 56) PALM BEACH REPORTING SERVICE, INC. EFTA01103339 Page 57 Page 59 1 counseled me that I cannot provide answers to 1 THE WITNESS: I intend to respond to all 2 any questions relevant to this lawsuit, and 2 relevant questions regarding this lawsuit. 3 must accept this advice or risk losing my Sixth 3 However, at the present tint my attorneys have 4 Amendment right to effective representation. 4 counseled me that I cannot provide answers to 5 Accordingly, I assert my Federal 5 any questions relevant to this lawsuit, and I 6 Constitutional tight as guaranteed by the 6 must accept this advice or risk losing my Sixth 7 Fifth, Sixth, and Fourteenth Amendment to the 7 Amendment right to effective representation. 8 United States Constitution. 8 Accordingly, I assert my Federal 9 Q. (By Mr. Edwards) Isn't it true that in 9 Constitutional rights as guaranteed by the 10 order to recruit each of these minor girls to your 10 Fifth, Sixth, and Fourteenth Amendment to the 11 house, you had someone tell them, "A rich guy in 11 United States Constitution. 12 Palm Beach will pay you cash to go to his house and 12 May I just ask, step outside for a second, 13 give him a massage"? 13 I want to just ask a question. 14 MR. BURMAN: Object to form, vague and 14 MR. BURMAN: Sure. 15 indefinite, to the extent last names of the 15 THE VIDEOGRAPHER: Going off the record at 16 girls have not been identified. 16 11:11. 17 THE WITNESS: I intend to respond to all 17 (Thereupon, a brief break was taken.) 18 relevant questions regarding this lawsuit 18 THE VIDEOGRAME12: Okay, we're back on the 19 However, at the present time my attorneys have 19 record at 11:16. 20 counseled me that I cannot provide answers to 20 Q. (By Mr. Edwards) Previously I named, or I 21 any questions relevant to this lawsuit. I must 21 gave you the names of 49 minor girls. Isn't it true 22 accept this advice or risk losing my Sixth 22 that you engaged in sex or sex acts with each of 23 Amendment right to effective representation. 23 them? 24 Accordingly, I assert my Federal 24 MR. BURMAN: Object to the form, vague and 25 Constitutional right as guaranteed by the 25 indefinite. Last names weren't provided for Page 58 Page 60 1 Fifth, Sixth, and Fourteenth Amendment of the 1 most of them. 2 United States Constitution. 2 THE WITNESS: I intend to respond to all 3 Q. (By Mr. Edwards) Each of these minor 3 relevant questions regarding this lawsuit 4 girls, when arriving at your house, was greeted at 4 However, at the present time my attorneys have 5 the door by one of your employees at your mansion, 5 counseled me that I cannot provide answers to 6 isn't that correct? 6 any questions relevant to this lawsuit, and 7 MR. BURMAN: Object to form, vague and 7 must accept that advice or risk losing my Sixth 8 indefinite. No description of last names of 8 Amendment right to effective representation. 9 the alleged minor girls. 9 Accordingly, I assert my Federal 10 THE WITNESS: I intend to respond to all 10 Constitutional right as guaranteed by the 11 relevant questions regarding this lawsuit 11 Fifth, Sixth, and Fourteenth Amendment to the 12 However, at the present time my attorneys have 12 constitution. 13 advised me that I cannot provide answers to any 13 Q. (By Mr. Edwards) With respect to each of 14 questions relevant to this lawsuit, and I must 14 the minor girls that was taken into your bedroom by 15 accept this advice or risk losing my Sixth 15 one of your employees, isn't it true that you 16 Amendment right to effective representation. 16 entered the room wearing only a towel? 17 Accordingly, I assert my Federal 17 MR. BURMAN: Object to form, vague and 18 Constitutional right as guaranteed by the 18 indefinite, last names of the alleged minor 19 Fifth, Sixth, and Fourteenth Amendment to the 19 girls weren't provided. 20 United States Constitution. 20 THE WITNESS: I intend to letwnd to all 21 Q. (By Mr. Edwards) Each of these minor 21 relevant questions regarding this lawsuit 22 girls was escorted up to your bedroom by one of your 22 However, at the present time my attorneys have 23 employees, isn't that correct? 23 counseled me that 1 cannot provide answers to 24 MR. BURMAN: Object to the form, vague and 24 any questions relevant to this lawsuit, and 25 indefinite. 25 must accept this advice or risk losing my Sixth 15 (Pages 57 to 60) PALM BEACH REPORTING SERVICE, INC. EFTA01103340 Page 61 Page 63 1 Amendment right to effective representation. 1. However, at the present time my attorneys have 2 Accordingly, my federal, I have to assert 2 counseled me that I cannot provide answers to 3 my Federal Constitutional rights as guaranteed 3 any questions relevant to this lawsuit, and I 4 by the Fifth, Sixth, and Fourteenth Amendment 4 must accept this advice or risk losing my Sixth to the United States Constitution. 5 Amendment right to effective reptw‘ntation. 6 Q. (By Mr. Edwards) With respect to each of 6 Accordingly, I assert my Federal 7 these minor girls, isn't it true that you ordered 7 Constitutional rights as guaranteed by the 8 each of them to get naked to give you a massage? 8 Fifth, Sixth, and Fourteenth Amendment to the 9 MR. BURMAN: Object to form, vague and 9 United States Constitution. 10 indefinite with regard to the alleged minor 10 Q. (By Mr. Edwards) With respect to all of 11 girls, the names weren't provided. Last names 11 the named 49 minor girls, isn't it true that you 12 weren't provided. 12 tried to touch each of them in a sexual way? 13 MR. EDWARDS: You can answer. 13 Wt. BURMAN: Object to font vague and 14 THE WITNESS: I intend to respond to all 14 indefinite with regard to the alleged minor 15 relevant questions regarding this lawsuit. 15 girls, last names weren't provided. 16 However, at the present time my attorneys have 16 THE WITNESS: I intend to respond to all 17 counseled me that I cannot provide answers to 17 relevant questions regarding this lawsuit 18 any questions relevant to this lawsuit, and I 18 However, at the present time my attorneys have 19 must accept this advice or risk losing my Sixth 19 counseled me that I cannot provide answers to 20 Amendment right to effective representation. 20 any questions relevant to this lawsuit. I must 21 Accordingly, I assert my Federal 21 accept this advice or risk losing my Sixth 22 Constitutional right as guaranteed by the 22 Amendment right to effective representation. 23 Fifth, Sixth, and Fourteenth Amendment to the 23 Accordingly, I assert my Federal 24 United States Constitution. 24 Constitutional rights as guaranteed by the 25 Q. (By Mr. Edwards) With rebind to each of 25 Fifth, Sixth, and Fourteenth Amendment to the Page 62 Page 64 1 the 49 named minor girls, isn't it true that you 1 United States Constitution. 2 masturbated in front of each of them? 2 Q. (By Mr. Edwards) With respect to each of 3 MR. BURMAN: Object to the form, vague and 3 the 49 minor girls, isn't it true that you touched 4 indefinite with regard to the alleged minor 4 their bare breasts? 5 girls, their last names weren't provided. 5 MR. BURMAN: Object to form, vague and 6 THE WITNESS: I intend to respond to all 6 indefinite with regard to the alleged minor 7 relevant questions regarding this lawsuit 7 girls, last names weren't provided. 8 However, at the present time my attorneys have 8 THE WITNESS: I intend to respond to all 9 counseled me that i cannot provide answers to relevant questions regarding this lawsuit. 1o any questions relevant to this lawsuit, and I 10 However, at the present time my attorneys have 11 must accept their advice or risk losing my 11 counseled me that I cannot provide answers to 12 Sixth Amaidment right to effective 12 any questions relevant to this lawsuit. And I 13 representation. 13 must accept this advice or risk losing my Sixth 14 Accordingly, lessen my Federal 14 Amendment right to effective representation. 15 Constitutional rights as guaranteed by the 15 Accordingly, I assert my Federal 16 Fifth, Sixth, and Fourteenth Amendment to the 16 Constitutional right as guaranteed by the 17 United States Constitution . 17 Fifth, Sixth, and Fourteenth Amendment to the 18 Q. (By Mr. Edwards) Isn't it true that you 18 United States Constitution. 19 asked each of the minor girls to do similar things 19 Q. (By Mr. Edwards) With respect to each of 20 to you, such as rub your nipples? 20 these minor girls, isn't it true that you 49 21 MR. BURMAN: Object to the form, vague and 21 inserted your fingers into their vaginas? 22 indefinite with regard to the alleged minor 22 MR. BURMAN: Object to form of the 23 girls, the last names weren't provided. 23 question, vague and indefinite with regard to 24 THE WITNESS: I intend to respond to all 24 the alleged minor girls, last names weren't 25 relevant uestions re anii this lawsuit. 25 vided. e...“...-Seawaottamar aaa•••••••eassaa..........vawaserwarirsesearsaw. 16 (Pages 61 to 64) PALM BEACH REPORTING SERVICE, INC. EFTA01103341 Page 65 Page 67 i. THE WITNESS: I intend to respond to all 1 this lawsuit, and I must accept this advice or risk 2 relevant questions regarding this lawsuit. 2 losing my Sixth Amendment right to effective 3 However, at the present time my attorneys have 3 representation. 4 counseled me that I cannot provide answers to 4 Accordingly, I assert my Federal 5 any questions relevant to this lawsuit, and I 5 Constitutional rights as guaranteed by the Fifth, 6 must accept this advice or risk losing my Sixth 6 Sixth, and Fourteenth Amendment to the United States 7 Amendment right to effective representation. 7 Constitution. 8 Accordingly, I assert my Federal 8 Q. Can you tell me why it is that you just 9 Constitutional rights as guaranteed by the 9 I asked you the last question about 10 Fifth, Sixth, and Fourteenth Amendment to the 10 11 United States Constitution. 11 MR. GOLDBERGER: Don't answer that. 12 Q. (By Mr. Edwards) With respect to the 49 12 Q. (By Mr. Edwards) Did you think the 13 named minor girls, isn't it true that you attempted 13 question was ninny? 14 to use vibrators on each of them? 14 MR. BURMAN: Object to form. 15 MR. BURMAN: Object to the form of the 15 MR. GOLDBERGER: You can answer. 16 question, vague and indefinite with regard to 16 THE WITNESS: No. 17 the alleged minor girls, last names weren't 17 B Mr. Edwards) Do you know 18 provided. 18 19 MR. EDWARDS: You can answer. 19 A. I intend to respond to all relevant 20 THE WITNESS: I intend to respond to all 20 questions regarding this lawsuit. However, at the 21 relevant questions regarding this lawsuit. 21 present time my attorneys have counseled me that I 22 However, at the present time my attorneys have 22 cannot provide answers to any questions relevant to 23 counseled me that I cannot provide answers to 23 this lawsuit, and I must accept this advice or risk 24 any questions relevant to this lawsuit, and I 24 losing my Sixth Amendment right to effective 25 must accept this advice or risk losing my Sixth 25 representation. Page 66 Page 68 1 Amendment right to effective representation. 1 Accordingly, I assert my Federal 2 Accordingly, I assert my Federal 2 Constitutional rights as guaranteed by the Fifth, 3 Constitutional rights as guaranteed by the 3 Sixth, and Fourteenth Amendment to the United States 4 Fifth, Sixth, and Fourteenth Amendment to the 4 Constitution. 5 United States Constitution. 5 Q. Isn't it true that you brought Minn) 6 Q. (By Mr. Edwards) Be 001 and 2005 6 the room to have threesome sex with you and many of 7 did you have a woman named living 7 these minor female girls? 8 at your Palm Beach house with you? 8 MR BURMAN: Object to the form of the 9 A. I intend to respond to all relevant 9 question, vague and indefinite with regard to 10 questions regarding this lawsuit. However, at the to the word "may" and with regard to the fact that 11 present time my attorneys have counseled me that I 11 last names haven't been described, or 12 cannot provide answers to any questions relevant to 12 disclosed. 13 this lawsuit, and I must accept this advice or risk 13 THE WITNESS: I intend to respond to all 14 losing my Sixth Amendment right to effective 14 relevant questions regarding this lawsuit. 15 representation. 15 However, at the present time my attorneys have 16 Accordingly, I assert my Federal 16 counseled me that I cannot provide answers to 17 Constitutional right as guaranteed by the Fifth, 17 any questions relevant to this lawsuit, and I 18 Sixth, and Fourteenth Amendment to the United States 18 mist accept this advice or risk losing my Sixth 19 Constitution. 19 Amendment right to effective representation. 20 rue that you consi 20 Accordingly, i assert Federal 21 ex s ve? your Yugoslavian Ide sbituaa 21 Constitutional rights as guaranteed by the 22 A. I intend to respond to all relevant 22 Fifth, Sixth, and Fourteenth Amendment to the 23 questions regarding this lawsuit. However, at the 23 United States Constitution. 24 present time my attorneys have counseled me that I 24 Q. (By Mr. Edwards) Isn't it true that you 25 cannot vide answers to an uestions relevant to 25 'aculated in front of each of these minor a ls? 17 (Pages 65 to 68) PALM BEACH REPORTING SERVICE, INC. EFTA01103342 Page 69 Page 71 1 MR. BURMAN: Object to form, vague and 1 United States Constitution. 2 indefinite. Last names were not provided of 2 Q. (By Mr. Edwards) With respect to each of 3 the alleged minor girls. 3 the 49 named minor girls, isn't it true that the sex 4 THE WITNESS: I intend to respond to all 4 or sex acts occurred in your bedroom? 5 relevant questions regarding this lawsuit. 5 MR. BURMAN: Object to form of the 6 However, at the present time my attorneys have 6 question, vague and indefinite with regard to 7 counseled me that I cannot provide answers to 7 the alleged minor girls, the last names weren't 8 any questions relevant to this lawsuit, and I 8 provided. 9 must accept this advice or risk losing my Sixth 9 THE WITNESS: I intend to respond to all 10 Amendment right to effective representation. 10 relevant questions regarding this lawsuit. 13. Accordingly, I assert my Federal 11 However, at the present time my attorneys have 12 Constitutional rights as guaranteed by the 12 counseled me that I cannot provide answers to 13 Fifth, Sixth, and Fourteenth Amendment to the 13 any questions relevant to this lawsuit, and 14 United States Constitution. 14 must accept this advice or risk losing my Sixth 15 Q. (By Mr. Edwards) With respect to each of 15 Amendment right to effective representation. 16 these 49 minor girls, isn't it true that you paid 16 Accordingly, I assert my Federal 17 each of them for sex? 17 Constitutional right as guaranteed by the 18 MR. BURMAN: Object to the form, vague and 18 Fifth, Sixth, and Fourteenth Amendment to the 19 indefinite. Last names of the many of the 19 United States Constitution. 20 minor girls were not provided, alleged minor 20 Q. (By Mr. Edwards) With respect to each of 21 girls. 21 these minor girls, isn't it true that certain other 22 THE WITNESS: I intend to respond to all 22 employees of yours played a role in authoring your 23 relevant questions regarding this lawsuit. 23 sexual contact with these minors? 24 However, at the present time my attorneys have 24 MR. BURMAN: Object to the form of the 25 counseled me that I cannotprovide answers to 25 question, vague and indefinite with regard to Page 70 Page 72 1 any questions relevant to this lawsuit, and I 1 the alleged minors, last names weren't 2 must accept this advice or risk losing my Sixth 2 provided. 3 Amendment right to effective representation. 3 THE WITNESS: Could you repeat the 4 Accordingly, I assert my Federal 4 question? Sorry. Constitutional rights as guaranteed by the 5 Q. (By Mr. Edwards) Sure. 6 Fifth, Sixth, and Fourteenth Amendment to the 6 With respect to the 49 minor girls whose 7 United States Constitution. 7 names i provided, isn't it true that certain 8 Q. (By Mr. Edwards) Isn't it true that you 8 employees of yours played a role in furthering 9 offered each of the 49 minor girls money if she 9 sexual contact between you and these minors? 10 would bring you more minor girls for you to engage 10 MR. BURMAN: Same objection. 11 in sex or sex acts with? 11 THE WITNESS: I intend to respond to all 12 MR. BURMAN: Object to the fan, vague and 12 relevant questions regarding this lawsuit. 13 indefinite. Last names of many of the alleged 13 However, at the present time my attorneys have 14 minor girls weren't provided. 14 counseled me that I cannot provide answers to 15 THE WITNESS: I intend to respond to all 15 any questions relevant to this lawsuit, and I 3.6 relevant questions regarding this lawsuit. 16 must accept this advice or risk losing my Sixth 17 However, at the present time my attorneys have 17 Amendment right to effective representation. 18 counseled me that I cannot provide answers to 18 Accordingly, I assert my Federal 19 any questions relevant to this lawsuit, and 19 Constitutional rights as guaranteed by the 20 must accept their advice or risk losing my 20 Fifth, Sixth, and Fourteenth Amendment to the 21 Sixth Amendment right to effective 21 United States Constitution. 22 representatiOn. 22 Q. (By Mr. Edwards) Some of your employees 23 Accordingly, I assort my Federal 23 were delegated the responsibility of cleaning your 24 Constitutional rights as guaranteed by the 24 sex toys after you engaged in sex with minor girls, 25 Fifth,Sixth and Fourteenth Amendment to the 25 isn't that true? 18 (Paces 69 to 72) PALM BEACH REPORTING SERVICE, INC. EFTA01103343 Page 73 Page 75 3. MR BURMAN: Are you referring to the 49 1 Q. (By Mr. Edwards) Isn't it true that you 2 alleged minors that you just identified, or is 2 had employees working for you with a purpose of 3 this a generic question? 3 helping you to avoid detection of your criminal 4 MR. EDWARDS: Yes, the 49, that -- 4 activities by law enforcement? 5 THE WITNESS: Can you repeat the question 5 MR. BURMAN: Object to form, vague an 6 please? 6 indefinite. 7 MR. EDWARDS: — are known to us. 7 THE WITNESS: I intend to respond to all 8 MR. BURMAN: Okay. Object to the form, 8 relevant questions regarding this lawsuit. 9 vague and indefinite with regard to the alleged 9 However, at the present time my attorneys have 10 minors, last names weren't provided. 10 counseled me that I cannot provide answers to 13. THE WITNESS: I intend to imp und to all 11 any questions relevant to this lawsuit, and I 12 relevant questions regarding this lawsuit 12 must accept this advice or risk losing my Sixth 13 However, at the present time my attorneys have 13 Amendment right to effective representation. 14 counseled me that I cannot provide answers to 14 Accordingly, I assert my Federal 15 any questions relevant to this lawsuit, and I 15 Constitutional rights as guaranteed by the 16 must accept this advice or risk losing my Sixth 16 Filth, Sixth, and Fourteenth Amendment to the 17 Amendment right to effective representation. 17 united States Constitution. 18 Accordingly, I assert my Federal 18 Q. (By Mr. Edwards) Did you have operable 19 Constitutional right as guaranteed by the 3.9 surveillance equipment inside your house from 2001 20 Fifth, Sixth, and Fourteenth Amendment to the 20 through 2006 in your Palm Beach house? 21 United States Constitution. 21 MR. BURMAN: Objection, vague and 22 Q. (By Mr. Edwards) Isn't it true that you 22 indefinite. 23 hired employees to work for you for the sole purpose 23 THE WITNESS: I intend to respond to all 24 of scheduling minor girls to come to your house for 24 relevant questions regarding this lawsuit. 25 sex? 25 However, at this present time my attorney has Page 74 Page 76 1 MR. BURMAN: Once again, are you referring 1 counseled me that I cannot provide answers to 2 to the 49 you identified, or just generic? 2 any questions relevant to this lawsuit, and I 3 MR. EDWARDS: General question. 3 must accept this advice or risk losing my Sixth 4 MR. BURMAN: General question? 4 Amendment tight to effective representation. 5 MR. EDWARDS: Right. 5 Accordingly, I assert my Federal 6 THE WITNESS: I intend to respond to all 6 Constitutional rights as guaranteed by the 7 relevant questions regarding this lawsuit. 7 Fifth, Sixth, and Fourteenth Amendment to the 8 However, at the present time my attorneys have 8 United States Constitution. 9 counseled me that I cannot provide answers to 9 Q. (By Mr. Edwards) Did you destroy or 10 any questions relevant to this lawsuit, and I 10 tamper with evidence, including computer images, 11 must accept this advice or risk losing my Sixth 11 computer equipment, surveillance equipment, photos, 12 Amendment right to effective representation. 12 notes, diaries, or photocopy records as a result of 13 Accordingly, I assert my Federal 13 the criminal investigation of you between 2001 and 14 Constitutional rights as guaranteed by the 14 2006? 15 Fifth, Sixth, and Fourteenth Amendment to the 15 MR. GOLDBERGER: Let me object on the 16 United States Constitution. 16 form. Are you asking, are you suggesting that 17 Q. (By Mr. Edwards) Isn't it true that you 3.7 there is a criminal investigation that went on 18 hired employees that were delegated responsibilities 18 between 2001 and 2006? Is that the question? 19 in order to assist you in avoiding detection of your 19 MR. EDWARDS: Well, at some time, at some 20 actions by law enforcement? 20 point in time there was, since he pled guilty. 21 THE WITNESS: What's the question? 21 MR GOLDBERGER: But what's the purpose of 22 MR.. BURMAN: Object to the form, vague and 22 the 2001 to 2006? Maybe you can rephrase the 23 indefinite. 23 question. 24 THE WITNESS: Could you repeat it again? 24 MR. EDWARDS: Okay. 25 MR. EDWARDS: Sure, ni clean it, 25 (B Mr. Edwards) How about this. Have 19 Pa es 73 to 76 PALM BEACH REPORTING SERVICE, INC. EFTA01103344 Page 77 Page 79 1 you ever at any time destroyed or tampered with any 1 losing my Sixth Amendment right to effective 2 evidence of your involvement with minor girls? 2 representation. 3 A. I intend to respond to an relevant 3 Accordingly, lessen my Federal 4 questions regarding this lawsuit. However, at the 4 Constitutional rights as guaranteed by the Fifth, 5 present time my attorneys have counseled me that 5 Sixth, and Fourteenth Amendment to the United States 6 cannot answer questions with respect to this 6 Constitution. 7 lawsuit, and must accept their advice or risk losing 7 Q. Was your house at some point in time in 8 my Sixth Amendment right to effective 8 Palm Beach burglarized by a former housekeeper named 9 representation. 9 Juan Allessee (phonetic)? 10 Accordingly, I assert my Federal 10 A. Yes. 11 Constitutional Rights as guaranteed by the Fifth, 11 Q. In relation to that burglary, did you 12 Sixth, and Fourteenth Amendments to the United 12 provide the Palm Beach Police Department with 13 States Constitution. 13 surveillance video from the inside of your house? 14 Q. Have you ever destroyed computer images or 14 A. I intend to respond to all relevant 15 computer equipment because of a fear it would be 15 questions regarding this lawsuit However, at the 16 used against you in a prosecution for your sexual 16 present tint my attorneys have counseled me that I 17 involvement with minor girls? 17 cannot provide answers to any questions relevant to 18 A. I intend to respond to all relevant 18 this lawsuit, and I must accept this advice or risk 19 questions regarding this lawsuit However, at the 19 losing my Sixth Amendment right to effective 20 present time my attorneys have counseled me that 1 20 representation. 21 cannot provide answers to any questions relevant to 21 Accordingly, I assert my Federal 22 this lawsuit, and I must accept this advice or risk 22 Constitutiona l rights as guaranteed by the Fifth, 23 losing my Sixth Amendment right to effective 23 Sixth, and Fourteenth Amendment to the United States 24 representation. 24 Constitution. 25 Accordingly, i assert my Federal 25 Q. At the time your house was burglarized, ' Page 78 Page 80 3. Constitutional rights as guaranteed by the Fifth, 1 how many operable surveillance cameras were inside 2 Sixth, and Fourteenth Amendment to the United States 2 your house? 3 Constitution. 3 A. I intend to respond to all relevant 4 Q. Did you ever, at any time, destroy 4 questions regarding this lawsuit. However, at the 5 photographs, notes, or diaries in an effort to avoid 5 present time my attorneys have counseled me that I 6 detection by law enforcement? 6 cannot provide answers to any questions relevant to 7 A. I intend to respond to all relevant 7 this lawsuit, and I must accept this advice or risk 8 questions regarding this lawsuit. However, at the 8 losing my Sixth Amendment right to effective 9 present time my attorneys have counseled me that 9 representation 1 o cannot provide answers to any questions relevant to 10 assert deral 11 this lawsuit, and I must accept this advice or risk 11 Constitutional rights as guaranteed by the Fifth, 12 losing my Sixth Amendment right to effective 12 Sixth, and Fourteenth Amendment to the United States 13 representation. 13 Constitution. 14 Accordingly, I assert my Federal 14 Q. How long have you been on work release? 15 Constitutional rights as guaranteed by the Fifth, 3.5 MR. GOLDBERGER: Hang on. Yeah, he can -- 16 Sixth, and Fourteenth Amendment to the United States 16 that's fine. 17 Constitution. 17 THE WITNESS: A little over six months. 18 Q. Did other people hired by you destroy or 18 Q. (By Mr. Edwards) You know the date that 19 tamper with evidence in an effort to avoid detection 19 you started work release? 20 of criminal activities or prosecution? 20 A. No. 21 A. I intend to respond to all relevant 21 rds indicate that 22 questions regarding this lawsuit. However, at the 25 guiQ 22 lqty. plf H JuTdron3yr0 r co occurrthriIdeon w l:cei oth lea is thatw, dtei,b2e0;yourou F 23 present time my attorneys have counseled me that I 23 something you'd quarrel with? 24 cannot provide answers to any questions relevant to 24 A. No. 25 this lawsuit and I must accept this advice or risk believe were 20 (Pages 77 to 80) PALM BEACH REPORTING SERVICE, INC. EFTA01103345 Page 81 Page 83 1 in the county jail after that June 30th, 2008 plea 1 constitution. 2 before you were granted work release? 2 Q. (By Mr. Edwards) Do you currently have 3 MR. GOLDBERGER: If you know. 3 access to a computer that you use? 4 THE WITNESS: Couple of months. 4 A. I intend to respond to all relevant 5 Q. (By Mr. Edwards) Do you know if any of 5 questions regarding this lawsuit However, at the 6 your victims were informed of your petition for work 6 present time my attorneys have counseled me that I 7 release? 7 cannot provide answers to any questions relevant to 8 A. I do not know. 8 this lawsuit I must accept this advice or risk 9 Q. When NM the Florida Science Foundation 9 losing my Sixth Amendment right to effective 10 created? 10 representation. 11 A. I intend to respond to all relevant 11 Accordingly, I assert my Federal 12 questions regarding this lawsuit. However, at the 12 Constitutional rights as guaranteed by the Fifth, 13 present time my attorneys have counseled me that I 13 Sixth, and Fourteenth Amendment to the constitution. 14 cannot provide answers to any questions relevant to 14 Q. What is e-mail address that you have been 15 this lawsuit, and must accept this advice or risk 15 using since being sentenced in 2008? 16 losing my Sixth Amendment right to effective 16 MR. GOLDBERGER: Object to the form, 17 representation. 17 assumes facts not in evidence. 18 Accordingly, I assert my Federal 18 THE WITNESS: I intend to respond to all 19 Constitutional rights as guaranteed by the Fifth, 19 relevant questions regarding this lawsuit. 20 Sixth, and Fourteenth Amendment to the United States 20 However, at the present time my attorneys have 21 Constitution. 21 counseled me that I cannot provide answers to 22 Q. Isn't it true that you created the Florida 22 any questions relevant to this lawsuit, and I 23 Science Foundation months before pleaing guilty 23 must accept this advice or risk losing my Sixth 24 knowing that you would eventually be on work release 24 Amendment right to effective representation. 25 in an office right next to your attorney's office? 25 Accordingly, I assert my Federal Page 82 Page 84 1 MR. BURMAN: Object to the form. 1 Constitutional rights as guaranteed by the 2 THE WITNESS: I intend to respond to all 2 Fifth, Sixth, and Fourteenth Amendment to the 3 relevant questions regarding this lawsuit. 3 United States Constitution. 4 However, at the present time my attorneys have 4 Q. (By Mr. Edwards) Do you intend to 5 counseled me that I cannot provide answers to 5 communicate with any minors once you are released to 6 any questions relevant to this lawsuit, and 6 house arrest? 7 must accept this advice or risk losing my Sixth 7 A. I intend to respond to all relevant 8 Amendment right to effective representation. 8 questions regarding this lawsuit. However, at the 9 Accordingly, I assert my Federal 9 present time my attorneys have counseled me that I 10 Constitutional rights as guaranteed by the 10 cannot provided answers to any questions relevant to 11 Filth, Sixth, and Fourteenth Amendment to the 11 this lawsuit, and I must accept this advice or risk 12 constitution. 12 losing my Sixth Amendment right to effective 13 Q. (By Mr. Edwards) Since being sentenced in 13 ivin dation. 14 June of 2008, have you had contact with any minors? 14 Accordingly, I assert my Federal 15 MR.. GOLDBERGER: You can answer that. 15 Constitutional rights as guaranteed by the Fifth, 16 THE WITNESS: I intend to respond to all 16 Sixth, and Fourteenth Amendment to the United States 17 relevant questions regarding this lawsuit. 17 Constitution. 18 However, at the present time my attorneys have 18 Q. Is it true that you have been diagnosed by 19 counseled me that I cannot provide answers to 19 a psychologist with a sexual disorder related to 20 any questions relevant to this lawsuit, and 20 your sexual appetite for minor girls? 21 must accept this advice or risk losing my Sixth 23. A. I intend to respond to all relevant 22 Amendment right to effective representation. 22 questions regarding this lawsuit. However, at the 23 Accordingly, I assert my Federal 23 present time my attorneys have counseled me that I 24 Constitutional rights as guaranteed by the 24 cannot provide answers to any questions relevant to 25 Fifth, Sixth and Fourteenth Amendment to the 25 this lawsuit, and I most acceptthis advice or risk %Ow 21 (Pages 81 to 84) PALM BEACH REPORTING SERVICE, INC. EFTA01103346 Page 85 Page 87 1 losing my Sixth Amendment right to effective 1 Q. (By Mr. Edwards) Have you engaged in sex 2 representation. 2 or sex acts with minors on the island of Little 3 Accordingly, I assert my Federal 3 St. Jeffs? 4 Constitutional rights as guaranteed by the Fifth, 4 A. I intend to respond to all relevant 5 Sixth, and Fourteenth Amendment to the constitution. 5 questions regarding this lawsuit. However, at the 6 Q. Isn't it true that you intend to continue 6 present time my attorneys have counseled me that I 7 engaging in sex acts with minor girls once you are 7 cannot provide answers to any questions relative to 8 released? 8 this lawsuit, and must accept this advice or risk 9 MR. BURMAN: Object to the form. 9 losing my Sixth Amendment right to effective 10 THE WITNESS: I intend to respond to all 10 representation. 11 relevant questions regarding this lawsuit. 11 Accordingly, I assert my Federal 12 However, at the present time my attomeys have 12 Constitutional rights as guaranteed by the Fifth, 13 counseled me that I cannot provide answers to 13 Sixth, and Fourteenth Amendment to the United States 14 any questions relevant to this lawsuit, and I 14 Constitution. 15 must accept this advice or risk losing my Sixth 15 Q. Isn't it true that you have engaged in 16 Amendment right to effective representation. 16 sexual acts or sex with girls as young as 12 years 17 Accordingly, I assert my Federal 17 old? 18 Constitutional rights as guaranteed by the 18 A. I intend to respond to all relevant 19 Fifth, Sixth, and Fourteenth Amendment to the 19 questions regarding this lawsuit. However, at the 20 United States Constitution. 20 present time my attorneys have counseled me that I 21 Q. (By Mr. Edwards) Have you engaged in sex 21 cannot provide answers to any questions relevant to 22 or sex acts with minor girls outside of the United 22 this lawsuit, and I must accept this advice or risk 23 States? 23 losing my Sixth Amendment right to effective 24 A. I intend to respond to all relevant 24 representation. 25 questions regarding this lawsuit. However, at the 25 Accordingly, I assert my Federal Page 86 Page 88 1 present time my attorneys have counseled me that I 1 Constitutional tights as guaranteed by the Fifth, 2 cannot provide answers to any questions relevant to 2 Sixth, and Fourteenth Amendment to the United States 3 this lawsuit, and must accept this advice or risk 3 Constitution. 4 losing my Sixth Amendment right to effective 4 Q. What is the youngest girl that you have 5 representation. 5 engaged in sex or sex acts with in the last ten 6 Accordingly, I assert my Federal 6 years? 7 Constitutional rights as guaranteed by the Fifth, 7 A. I intend to respond to all relevant 8 Sixth, and Fourteenth Amendment to the United States 8 questions regarding this lawsuit. However, at the 9 Constitution. 9 present time my attorneys have counseled me that I 10 Q. Is it true that you have your own island? 10 cannot provide answers to any questions relevant to 11 MR. BURMAN: Object, also on the, on the 11 this lawsuit, and must accept this advice or risk 12 grounds that the punitive damages haven't been 12 losing my Sixth Amendment right to effective 13 allowed yet. Not relevant. 13 representation. 14 MR. EDWARDS: Answer. 14 Accordingly, I assert under the Federal 15 THE WITNESS: I intend to respond to all 15 Constitutional rights as guaranteed by the Fifth, 16 relevant questions regarding this lawsuit. 16 Sixth and Fourteenth Amendment to the United States 17 However, at the present time my attorneys have 17 Constitution. 18 counseled me that I cannot provide answers to 18 Q. Have you discussed with any of your 19 any questions relevant to this lawsuit, and I 19 friends the fact that you engage in sex or sex acts 20 must accept this advice or risk losing my Sixth 20 with minors? 21 Amendment right to effective representation. 21 A. I intend to respond to all relevant 22 Accordingly, I assert my Federal 22 questions regarding this lawsuit. However, at the 23 Constitutional rights under the Fifth, Sixth, 23 present time my attorneys have counseled me that I 24 and Fourteenth Amendment to the United States 24 cannot provide answers to any questions relevant to 25 Constitution. 25 this lawsuit and I must this advice or risk AISIoadal• 22 (Pages 85 to 88 PALM BEACH REPORTING SERVICE, INC. EFTA01103347 Page 89 Page 91 1 losing my Sixth Amendment right to effective 1 Amendment right to effective representation. 2 representation. 2 Accordingly, I assert my Federal 3 Accordingly, I assert my Federal 3 Constitutional rights as guaranteed by the 4 Constitutional rights as guaranteed by the Fifth, 4 Filth, Sixth, and Fourteenth Amendment to the 5 Sixth, and Fourteenth Amendment to the United States 5 United States Constitution. 6 Constitution. 6 Q. (By Mr. Edwards) Isn't it true that you 7 Q. Did you know that the girls that were 7 devised a scheme or plan to engage in sex or sex 8 providing you massages were under the age of 18 at 8 acts with multiple minor girls? 9 the time they were doing so? 9 A. I intend to respond to all relevant 10 A. I intend to respond to all relevant 10 questions regarding this lawsuit. However, at the 11 questions regarding this lawsuit. However, at the 11 present time my attorneys have counseled me that I 12 present time my attorneys have counseled me that I 12 cannot provide answers to any questions relevant to 13 cannot provide answers to any questions relevant to 13 this lawsuit, and I must accept this advice or risk 14 this lawsuit, and I must accept their advice or risk 14 losing my Sixth Amendment right to effective 15 losing my Sixth Amendment right to effective 15 representation. 16 representation. 16 Accordingly, I must assert my Federal 17 Accordingly, I assert my Federal 17 Constitutional rights as guaranteed by the Fifth, 18 Constitutional rights as guaranteed by the Fifth, 18 Sixth, and Fourteenth Amendment to the United States 19 Sixth, and Fourteenth Amendment to the United States 19 Constitution. 20 Constitution. 20 THE WITNESS: Can I take a pee break? 21 Q. Isn't it true that the age group that you 21 THE VIDEOGRAPHER: We're off the record at 22 enjoy to engage in sex with is between 12 and 16 22 11:50. This will be the end of tape one. 23 yearsold? 23 (Thereupon, a brief break was taken.) 24 MR. BURMAN: Object to form. 24 THE VIDEOGRAPHER: This is the beginning 25 THE WITNESS: I intend to respond to all 25 of tape number two, and we're back on the Page 90 Page 92 3. relevant questions regarding this lawsuit. 3. record at 11:59. 2 However, at the present time my attorneys have 2 Q. (By Mr. Edwards) Between 2001 and 2005 3 counseled me that I cannot provide answers to 3 did you digitally penetrate the vaginas of more than 4 any questions relevant to this lawsuit, and I 4 50 minor girls? 5 must accept this advice or risk losing my Sixth 5 A. I intend to respond to all relevant 6 Amendment right to effective representation. 6 questions regarding this lawsuit. However, at the 7 Accordingly, I assert my Federal 7 present time my attorneys have counseled me that I 8 Constitutional rights as guaranteed by the 8 cannot provide answers to any questions relevant to 9 Fifth, Sixth, and Fourteenth Amendment to the 9 this lawsuit, and I must accept their advice or risk 10 constitution. 10 losing my Sixth Amendment right to effective 11. Q. (By Mr. Edwards) Do you agree with the 11 representation. 12 laws that prohibit you from having sex or engaging 12 Accordingly, I assert my Federal 13 in sex acts with minors? 13 Constitutional right as guaranteed by the Fifth, 14 MR. BURMAN: Object to form. 14 Sixth and Fourteenth Amendment to the constitution. 15 THE WITNESS: Can you repeat the question? 15 Q. Between 2001 and 2005 did you masturbate 16 Q. (By Mr. Edwards) Do you agree with the 16 in front of more than 50 minor girls? 17 laws that prohibit you from engaging in sex or sex 17 A. I intend to respond to all relevant 18 acts with minor girls? 18 questions regarding this lawsuit. However, at the 19 MR. BURMAN: Object to the form. 19 present time my attorneys have counseled me that I 20 THE WITNESS: I intend to respond to all 20 cannot provide answers to any questions relevant to 21 relevant questions regarding this lawsuit. 21 this lawsuit, and I must accept this advice or risk 22 However, at the present time my attorneys have 22 losing my Sixth Amendment right to effective 23 counseled me that I cannot provide answers to 23 representation. 24 any questions relevant to this lawsuit, and I 24 Accordingly, I assert my Federal 25 must accept this advice or risk losittgmiSixth 25 Constitutional riAtits as guaranteed by the Fifth. 23 (Pages 89 to 92) PALM BEACH REPORTING SERVICE, INC. EFTA01103348 Page 93 Page 95 1 Sixth and Fourteenth Amendment to the constitution. 1 present time my attorneys have counseled ire that I 2 Q. Between 2001 and 2005 did you ejaculate in 2 cannot provide answers to any questions relevant to 3 front of more than 50 minor girls? 3 this lawsuit, and must accept this advice or risk 4 A. I intend to respond to all relevant 4 losing my Sixth Amendment right to effective 5 questions regarding this lawsuit. However, at the 5 representation. 6 present time my attorneys have counseled me that I 6 Accordingly, I assert my Federal 7 cannot provide answers to any questions relevant to 7 Constitutional rights as guaranteed by the Fifth, 8 this lawsuit, and I must accept this advice or risk 8 Sixth, and Fourteenth Amendment to the United States 9 losing my Sixth Amendment right to effective 9 Constitution. 10 representation. 10 Q. During the criminal investigation there 11 Accordingly, I assert my Federal 11 were statements to the media that you believed the 12 Constitutional rights as guaranteed by the Fifth, 12 girls to be 18. Which girls were you referring to? 13 Sixth, and Fourteenth Amendment to the United States 13 A. I intend to 14 Constitution. 14 THE WITNESS: Excuse me one second. 15 Q. Does the body form of a 12 to 16 year old 15 (Thereupon, a discussion was had off 16 girl sexually appeal to you? 16 the record.) 17 MR. BURMAN: Object to the form. 17 MR. GOLDBERGER: Urrnt let me object to the 18 THE WITNESS: I intend to respond to all 18 form as to vague. I don't know what statements 19 relevant questions regarding this lawsuit. 19 you're talking about. Are you talking about 20 However, at the present time my attorneys have 20 statements that Mr. Epstein made? 21 counseled me that I cannot provide answers to 21 MR. EDWARDS: Through attorneys. 22 any questions relevant to this lawsuit, andl 22 MR. GOLDBE1tGER: Well, is that the 23 must accept this advice or risk losing my Sixth 23 question? Why don't you rephrase the question, 24 Amendment right to effective representation. 24 why don't you rephrase the question so we 25 Accordingly, I assert my Federal 25 understand what it is. Page 94 Page 96 1 Constitutional right as guaranteed by the 1 Q. (By Mr. Edwards) Various attorneys of 2 Fifth, Sixth, and Fourteenth Amendment to the 2 yours made representations to the media that you 3 constitution. 3 were of, under the belief that the girls that you 4 Q. (By Mr. Edwards) Did you use your wealth, 4 were engaging in sex acts with were 18 years of age. 5 power, and connections to impress or influence minor 5 Which girls were you, was that referring to? 6 girls into having sex with you? 6 MR. GOLDBERGER: Can you identify a 7 A. I intend to respond to all relevant 7 specific statement made by a specific attorney? 8 questions regarding this lawsuit. However, at the 8 MR.. EDWARDS: We'll get there later on in 9 present time my attorneys have counseled me that I 9 the deposition. 10 cannot provide answers to any questions relevant to 10 Q. (By Mr. Edwards) Have you ever, at any 11 this lawsuit, and I must accept their advice or risk 11 time, made that statement, that you believed the 12 losing my Sixth Amendment right to effective 12 girls that you were engaging in sex acts with were 13 representation. 13 18 years of age or older? 14 Accordingly, I assert my Federal 14 MR. GOLDBERGER: To the media, are you 15 Constitutional rights as guaranteed by the Fifth, 15 talking about? 16 Sixth, and Fourteenth Amendment to the United States 16 Q. (By Mr. Edwards) Yourself or through 17 Constitution. 17 anyone else to anyone else. 18 Q. Did you intentionally target economically 18 MR. GOLDBERGER: Object to the — 19 deprived children for the purposes of having sex or 19 that's — 20 engaging in sex acts with? 20 MR. BURMAN: Object to the form. 21 A. Do you want to rephrase the question? 21 MR. GOLDBERGER: I have no idea what the 22 Q. Did you intentionally target economically 22 question is. Just ask the question, 23 deprived children for the purposes of sex? 23 happy to try and have the client answer it for 24 A. I intend to respond to all relevant 24 you. 25 questions regarding this lawsuit. However, at the 25 9. SBA Mr. Edwards) Okay. rin not talking 24 (Pages 93 to 96) PALM BEACH REPORTING SERVICE, INC. EFTA01103349 Page 97 Page 99 1 about statements to your attorneys, that's 1 that the alleged minor girls' last names 2 privileged. 2 weren't provided. 3 Have you ever made the statement to anyone 3 THE WITNESS: I intend to respond to all 4 else, other than your attorneys, that you believed 4 relevant questions regarding this lawsuit. 5 the girls that were giving you massages at your 5 However, to the present time, at the present 6 house were ova the age of 18? 6 time my attorneys have counseled me thatl 7 A. I intend to respond to all relevant 7 cannot provide answers to any questions 8 questions regarding this lawsuit. However, at the B relevant to this lawsuit, and I must accept 9 present time my attorneys have counseled me that I 9 this advice or risk losing my Sixth Amendment 10 cannot provide answers to any questions relevant to 10 right to effective representation. 11 this lawsuit, and I must accept this advice or risk 11 Accordingly, i assert my Federal 12 losing my Sixth Amendment right to effective 12 Constitutional rights as guaranteed by the 13 representation. 13 Fifth, Sixth, and Fourteenth Amendment to the 14 Accordingly, I assert my Federal 14 United States Constitution. 15 Constitutional rights as guaranteed by the Fifth, 15 Q. (By Mr. Edwards) How did the minor girls 16 Sixth, and Fourteenth Amendment to the United States 16 previously named in this deposition arrive to your 17 Constitution. 17 mansion between 2001 and 2005? 18 Q Between 2001 and 2005 did you pay any 18 MR. BURMAN: Objection, vague and 19 females for sex? 19 indefinite. 20 A. I intend to respond to all relevant 20 MR. GOLDBERGER: And it's, it's vague and 21 questions regarding this lawsuit. However, at the 21 indefinite, but to assist in answering the 22 present time my attorneys have counseled me that I 22 question, can you tell us what mansion you're 23 cannot provide answers to any questions relevant to 23 talking about? 24 this lawsuit, and I must accept this advice or risk 24 MR. EDWARDS: Palm Beach mansion. 25 losing my Sixth Amendment ri t to effective 25 THE WITNESS: Can the estion? Page 98 Page 100 1 representation. 1 Q. (By Mr. Edwards) How did they arrive at 2 Accordingly, I assert Federal 2 your house? 3 Constitutional rights under the Fifth, Sixth, and 3 A. "They" arrive? 4 Fourteenth Amendment to the United States 4 Q. How did any of the minor girls whose names 5 Constitution. 5 I named previously in this deposition arrive to your 6 Q. Between 2001 and 2005 did you tell minor 6 house? 7 female girls at your house that you prefer to engage 7 MR. BURMAN: Object to the form of the 8 in sexual activities with minors? 8 question, vague and indefinite to the extent 9 A. I intend to respond to all relevant 9 that the alleged minor girls' last names 10 questions regarding this lawsuit. However, at the 10 weren't provided. 11 present time my attorneys have counseled me that I 11 THE WITNESS: I intend to respond to all 12 cannot provide answers to any questions relevant to 12 relevant questions regarding this lawsuit 13 this lawsuit, and I must accept this advice or risk 13 However, at the present time my attorneys have 14 losing my Sixth Amendment right to effective 14 counseled me that I cannot provide answers to 15 representation. 15 any questions relevant to this lawsuit, that I 16 Accordingly, 1 assert my Federal 16 must accept this advice or risk losing my Sixth 17 Constitutional rights as guaranteed by the Fifth, 17 Amendment tight to effective representation. 18 Sixth, and Fourteenth Amendment to the United States 18 Accordingly, I assert my Federal 19 Constitution. 19 Constitutional rights as guaranteed by the 20 Q. Is it true that many of the 49 minor girls 20 Fifth, Sixth, and Fourteenth Amendment to the 21 previously named told you that they were under the 21 constitution. 22 age of 15 at the time you were engaging in sex acts 22 Q. (By Mr. Edwards) Many of the minor girls 23 with than? 23 named previously in this deposition did not drive a 24 ha. BURMAN: Object to fonn of the 24 car to your house or have a driver's license, isn't 25 • estion va and indefinite to the extent 25 that true? 25 (Pages 97 to 100) PALM BEACH REPORTING SERVICE, INC. EFTA01103350 Page 101 Page 103 1 MR. BURMAN: Object to form of the 1 MR. BURMAN: Are you talking about the 497 2 question, vague and indefinite to the extent 2 MR. EDWARDS: No. 3 that the alleged minor girls' last names 3 MR. BURMAN: No. 4 weren't provided. 4 Q. (By Mr. Edwards) Did any minor girls that 5 THE WITNESS: You have to repeat the 5 engaged in sex or sex acts with you between the 6 question, again. Sony. 6 years of 2001 and 2005 at your house tell you that 7 Q. (By Mr. Edwards) Isn't it true that many 7 they vim in middle school or high school at the 8 of the minor girls previously named in this 8 time? 9 deposition did not drive a car or have driver's 9 MR. BURMAN: Object to the form. 10 licenses? 10 THE WITNESS: I intend to respond to all 11 MR. BURMAN: Same objection. 11 relevant questions regarding this lawsuit. 12 THE WITNESS: I intend to respond to all 12 However, at the present time my attomeys have 13 relevant questions regarding this lawsuit. 13 counseled me that I cannot provide answers to 14 However, at the present time my attorneys have 14 any questions relevant to this lawsuit, and I 15 counseled me that I cannot provide answers to 15 must accept this advice or risk losing my Sixth 16 any questions relevant to this lawsuit, and I 16 Amendment right to effective representation. 17 must accept this advice or risk losing my Sixth 17 Accordingly, lessen my Federal 18 Amendment right to effective representation. 18 Constitutional rights as guaranteed by the 19 Accordingly, I assert my Federal 19 Fifth, Sixth, and Fourteenth Anmaloient to the 20 Constitutional rights as guaranteed by the 20 constitution. 21 Fifth, Sixth, and Fourteenth Amendment to the 21 MR. EDWARDS: Okay. What time do you want 22 United States Constitution. 22 to break for lunch? 23 Q. (By Mr. Edwards) Is it true that you 23 MR. GOLDBERGER 1:00. 24 discussed with many of these girls the fact that 24 THE WITNESS: 1:15? 25 they were in middle school or high school at the 25 MR GOLDBERGER: Yeah, 1:15. Is that Page 102 Page 104 1 time they were engaging in sex acts with you at your 1 okay? 2 house? 2 MR. EDWARDS: Yeah, that's fine with me. 3 MR BURMAN: Are you referring to the 3 What time do we have now? 4 previous 49? 4 THE WITNESS: It will be another hour. 5 MR. EDWARDS: Yes. 5 (Thereupon, a discussion was had off 6 MR. BURMAN: Okay. Object to form of the 6 the record.) 7 question, vague and indefinite to the extent 7 Q. (By Mr. Edwards) Did you ever discuss 8 that the names, the last names of many of the 8 with any minor girls at your house that you would 9 alleged minor girls weren't provided. 9 pay them to bring you other minor girls for the 10 THE WITNESS: I intend to respond to all 10 purposes of sex? 11 relevant questions regarding this lawsuit. 11 MR BURMAN: Object to the form. 12 However, at the present time my attorneys have 12 THE WITNESS: I intend to respond to all 13 counseled me that 1 cannot provide answers to 13 relevant questions regarding this lawsuit. 14 any questions relevant to this lawsuit, and I 14 However, at the present time my attorneys have 15 must accept this advice or risk losing my Sixth 15 counseled me that I cannot provide answers to 16 Amendment right to effective rt.piesuitation. 16 any questions relevant to this lawsuit, and I 17 Accordingly, I assert my Federal 17 must accept this advice or risk losing my Sixth 18 Constitutional rights as guaranteed by the 18 Amendment right to effective representation. 19 Fifth, Sixth, and Fourteenth Amendment to the 19 Accordingly, I assert my Federal 20 United States Constitution. 20 Constitutional right as guaranteed by the 21 Q. (By Mr. Edwards) Did any of the girls 21 Fifth, Sixth, and Fourteenth Amendment to the 22 that engaged in sex acts with you at your house 22 United States Constitution. 23 between 2001 and 2005 tell you that they were in 23 Q. (By Mr. Edwards) Did you tell any of the 24 middle school or high school? 24 minor girls that were at your house for sex that you 25 A. Soma repeat the question. 25 ftrefen'?!:lp,a. Is for sex? 26 (Pages 101 to 104) PALM BEACH REPORTING SERVICE, INC. EFTA01103351 Page 105 Page 107 1 MR. BURMAN: Object to the form. 1 any questions relevant to this lawsuit, and I 2 THE WITNESS: I intend to respond to all 2 must accept this advice or risk losing my Sixth 3 relevant questions regarding this lawsuit. 3 Amendment right to effective representation. 4 However, at the present time my attorneys have 4 Accordingly, I assert my Federal 5 counseled me that I cannot provide answers to 5 Constitutional rights as guaranteed by the 6 any questions relevant to this lawsuit, and I 6 Fifth, Sixth and Fourteenth Amendment of the 7 must accept this advice or risk losing my Sixth 7 constitution. 8 Amendment right to effective representation. 8 Q. (By Mr. Edwards) Isn't it true that you 9 Accordingly, I assert my Federal 9 did not like to have sex or engage in sex acts with 10 Constitutional rights as guaranteed by the 10 black girls? 11 Fifth, Sixth, and Fourteenth Amendment to the 11 MR. BURMAN: Object to the form. 12 constitution. 12 THE WITNESS: I intend to respond to all 13 Q. (By Mr. Edwards) Did you tell any of the 13 relevant questions regarding this lawsuit. 5 14 minor girls at your house between 2001 and 2005 that 14 However, at the present time my attorneys have 15 you do not like girls that have tattoos? 15 counseled me that I cannot provide answers to 16 MR. BURMAN: Object to the form. 16 any questions relevant to this lawsuit, and I 17 THE WITNESS: I intend to respond to all 17 must accept this advice or risk losing my Sixth 18 relevant questions regarding this lawsuit. 18 Amendment right to effective representation. 19 However, at the present time my attorneys have 19 Accordingly, I assert my Federal 2o counseled me that I cannot provide answers to 20 Constitutional rights as guaranteed by the 21 any questions relevant to this lawsuit, and 21 Fifth, Sixth, and Fourteenth Amendment 22 must accept this advice or risk losing my Sixth 22 Q. (By Mr. Edwards) Isn't it true that black 23 Amendment right to effective representation. 23 girls were brought to your house and you turned them 24 Accordingly, I assert my Federal 24 away at the door because you do not like black 25 Constitutional right as guaranteed by the 25 girls? Page 106 Page 108 1 Fifth, Sixth, and Fourteenth nc.nt of the 1 MR. BURMAN: Object to the form. 2 constitution . 2 THE WITNESS: I intend to respond to all 3 Q. (By Mr. Edwards) Did you tell any of the 3 relevant questions regarding this lawsuit. 4 minor girls that were at your house not to bring you 4 However, at the present time my attorneys have 5 any girls that were pregnant or had babies? 5 counseled me that I cannot provide answers to 6 MR. BURMAN: Object to the form. 6 any questions relevant to this lawsuit, and I 7 THE WITNESS: I intend to respond to all 7 must accept this advice or risk losing my Sixth 8 relevant questions regarding this lawsuit 8 Amendment tight to effective representation. 9 However, at the present time my attorneys have 9 Accordingly, I assert my Federal 10 counseled me that I cannot provide answers to 10 Constitutional rights as guaranteed by the 11 any questions relevant to this lawsuit, and I 11 Fifth, Sixth and Fourteenth Amendment to the 12 must accept this advice or risk losing my Sixth 12 constitution. 13 Amendment right to effective representation. 13 Q. (By Mr. Edwards) Isn't it true that you 14 Accordingly, I assert my Federal 14 also turned away girls because they were 18 years or 15 Constitutional right as guaranteed by the 15 older and too old for you? 16 Fifth, Sixth, and Fourteenth Amendment to the 16 MR. BURMAN: Object to the form. 17 constitution? 17 THE WITNESS: I intend to respond to all 18 Q. (By Mr. Edwards) Did you specifically 18 relevant questions regarding this lawsuit. 19 instruct any of the minor girls not to bring you any 19 However, at the present time my attorneys have 20 black girls? 20 counseled me that i cannot provide answers to 21 MR. BURMAN: Object to the form. 21 any questions relevant to this lawsuit, and I 22 THE WITNESS: I intend to respond to all 22 must accept the advice or risk losing my Sixth 23 relevant questions regarding this lawsuit. 23 Amendment right to effective representation. 24 However, at the present time my attorneys have 24 Accordingly, I assert Federal 25 counseled me that I cannot Erovide answers to 25 Constitutional ridits as guaranteedb the • 27 (Pages 105 to 108) PALM BEACH REPORTING SERVICE, INC. EFTA01103352 Page 109 Page 111 1 Fifth, Sixth and Fourteenth Amendment to the 1 any questions relevant to this lawsuit, and I 2 United States Constitution. 2 must accept this advice or risk losing my Sixth 3 Q. (By Mr. Edwards) Isn't it true that you 3 Amendment right to effective representation. 4 also turned away minor girls with tattoos because 4 Accordingly, I assert my Federal 5 you did not feel that they were pure? 5 Constitutional rights as guaranteed by the 6 MR. BURMAN: Object to the form. 6 Fifth, Sixth, and Fourteenth Amendment to the 7 THE WITNESS: I intend to respond to all 7 United States Constitution. 8 relevant questions regarding this lawsuit. 8 Q. (By Mr. Edwards) Why did you laugh about 9 However, at the present time my attorneys have 9 that last question? 10 counseled me that I cannot provide answers to 10 MR. BURMAN: Object to the form. 11 any questions relevant to this lawsuit, and I 11 THE WITNESS: I have a stomachache at the 12 must accept this advice or risk losing my Sixth 12 moment. I wasn't laughing. 13 Amendment right to effective representation. 13 Q. (By Mr. Edwards) Isn't it true that you 14 Accordingly, I assert my Federal 14 targeted young, economically deprived kids with 15 Constitutional right as guaranteed by the 15 little or no parental guidance? 16 Fifth, Sixth, and Fourteenth Amendment to the 16 MR. BURMAN: Object to the form. 17 United States Constitution. 17 THE WITNESS: You have to repeat the 18 Q. (By Mr. Edwards) Is it true that your 18 question. 19 specific instructions were, to these minor girls, to 19 Q. (By Mr. Edwards) Isn't it true that you 20 bring you white girls between the ages of 12 and 17 20 were targeting young, economically deprived minor 21 that were not pregnant, did not have babies, and did 21 girls with little or no parental guidance? 22 not have tattoos? 22 MR. BURMAN: Object to the form. 23 MR. BURMAN: Object to the form. 23 Q. (By Mr. Edwards) For sex. 24 THE WITNESS: I intend to respond to all 24 A. I intend to respond to all relevant 25 relevant questions regarding this lawsuit. 25 questions regarding this lawsuit. However, at the Page 110 Page 112 However, at the present time my attorneys have 1 present time my attorneys have counseled me that I 2 counseled me that I cannot provide answers to 2 cannot provide answers to any questions relevant to 3 any questions relevant to this lawsuit, and I 3 this lawsuit, and I must accept their advice or risk 4 must accept this advice or risk losing my Sixth 4 losing my Sixth Amendment right to effective 5 Amendment right to effective representation. 5 representation. 6 Accordingly, I assert my Federal 6 Accordingly, I assert my Federal 7 Constitutional right as guaranteed by the 7 Constitutional rights as guaranteed by the Fifth, 8 Fifth, Sixth, and Fourteenth Amendment to the 8 Sixth, and Fourteenth Amendment to the United States 9 constitution. 9 Constitution. 10 Q. (By Mr. Edwards) Is it true that you 10 Q. Have you ever told anybody that the girls 11 offered each minor girl approximately $200 in cash 11 were over at your house because you just like 12 for sex? 12 massages? 13 MR. BURMAN: Object to the form. Are you 13 MR. BURMAN: Object to the form. 14 back on the 49, or is this generic? 14 THE WITNESS: I intend to respond to all 15 MR. EDWARDS: No, generic. 15 relevant questions regarding this lawsuit. 16 THE WITNESS: Would you repeat the 16 However, at the present time my attorneys have 17 question? 17 counseled me that I cannot provide answers to 18 Q. (By Mr. Edwards) Between 2001 and 2005 18 any questions relevant to this lawsuit, and I 19 isn't it true that you offered each minor girl that 19 must accept this advice or risk losing my Sixth 20 came to your house for sex $200 for that sex? 20 Amendment right to effective representation. 23. MR. BURMAN: Object to the form. 21 Accordingly, I assert my Federal 22 THE WITNESS: I intend to respond to all 22 Constitutional right as guaranteed by the 23 relevant questions regarding this lawsuit. 23 Fifth, Sixth, and Fourteenth Amendment to the 24 However, at the present time my attorneys have 24 United States Constitution. 25 counseled me that I cannot urovide answers to 25 . Edwards it true that none 28 (Pages 109 to 112) PALM BEACH REPORTING SERVICE, INC. EFTA01103353 Page 113 Page 115 1 of these minor girls that you engaged in sex acts 1 Q. (By Mr. Edwards) Did you tell these minor 2 with at your house had any massage experience? 2 girls between 2001 and 2005 at your Palm Beach 3 MR. BURMAN: Object to the form. 3 mansion to get naked and touch you so that you could 4 THE WITNESS: I intend to respond to all 4 get off? 5 relevant questions regarding this lawsuit. 5 A. Get off? 6 However, at the present time my attorneys have 6 MR. GOLDBERGER: Are you asking him if 7 counseled me that I cannot provide answers to 7 that's a statement that was made? 8 any questions relevant to this lawsuit, and 8 MR. EDWARDS: Yes, to these girls. 9 must accept this advice or risk losing my Sixth 9 MR. BURMAN: Object to the font 10 Amendment right to effective representation. 10 THE WITNESS: I intend to respond to all 11 Accordingly, I assert my Federal 11 relevant questions regarding this lawsuit. 12 Constitutional rights as guaranteed by the 12 However, at the present time my attorneys have 13 Fifth, Sixth, and Fourteenth Amendment to the 13 counseled me that I cannot provide answers to 14 United States Constitution. 14 any questions relevant to this lawsuit, and I 15 Q. (By Mr. Edwards) Between 2001 and 2005 15 must accept this advice or risk losing my Sixth 16 did you ever have a professional masseuse give you a 16 Amendment right to effective representation. 17 massage at your house in Palm Beach? 17 Accordingly, I assert my Federal 18 A. I intend to respond to all relevant 18 Constitutional right as guaranteed by the 19 questions regarding this lawsuit. However, at the 19 Fifth, Sixth, and Fourteenth Amendment to the 20 present time my attorneys have counseled me that 1 20 United States Constitution. 21 cannot provide answers to any questions relevant to 21 Q. (By Mr. Edwards) Will you agree that you 22 this lawsuit, and I must accept this advice or risk 22 exchanged money for sexual gratification with at 23 losing my Sixth Amendment right to effective 23 least 50 girls at your Palm Beach mansion between 24 representation. 24 2001 and 2005? 25 Accordingly, I assert my Federal 25 MR. BURMAN: Object to the form. Page 114 Page 116 1 Constitutional rights as guaranteed by the Fifth, 1 THE WITNESS: I intend to respond to all 2 Sixth, and Fourteenth Amendment of the United States 2 relevant questions regarding this lawsuit. 3 Constitution. 3 However, at the present time my attorneys have 4 Q. In fact, when these minor girls would tell 4 counseled me not to provide answers to any 5 you they had no massage experience, didn't you 5 questions relevant to this lawsuit, and I must 6 respond by telling them that that is actually better 6 accept this advice or risk losing my Sixth 7 for you? 7 Amendment right to effective representation. 8 MR. BURMAN: Object to the form. 8 Accordingly, I assert my Federal 9 THE WITNESS: I intend to respond to all 9 Constitutional rights as guaranteed by the 10 relevant questions regarding this lawsuit. 10 Fifth, Sixth, and Fourteenth Amendment to the 11 However, at the present time my attorneys have 11 United States Constitution. 12 counseled me that I cannot provide answers to 12 Q. (By Mr. Edwards) Between 2001 and 2005 13 any questions relevant to this lawsuit, and I 13 you never ordered a professional escort to come to 14 must accept the advice or risk losing my Sixth 14 your house for sex, did you? 15 Amendment right to effective representation. 15 A. Rephrase the question, please. 16 Accordingly, I assert my Federal 16 Q. Between 2001 and 2005 you never ordered 17 Constitutional right as guaranteed by the 17 from an escort service in Palm Beach County for a 18 Fifth, Sixth and Fourteenth Amendment to the 18 professional escort to come to your house for sex, 19 constitution. 19 did you? 20 Q. (By Mr. Edwards) Did you tell these minor 20 A. You never ordered? 21 girls to get naked and touch you so that you could 21 THE WITNESS: Do I answer the question? 22 get off? 22 MR. GOLDBERGER: You don't understand. 23 MR. BURMAN: Object to the form. 23 Rephrase it. 24 THE WITNESS: What? What's — repeat the 24 Q. (By Mr. Edwards) Did you ever call an 25 . Lestion. 25 escort service to have an escort sent to your house 29 (Pages 113 to 116) PALM BEACH REPORTING SERVICE, INC. EFTA01103354 Page 117 Page 119 1 in Palm Beach for sex? 1 Accordingly, I assert my Federal 2 A. I intend to respond to all relevant 2 Constitutional rights as guaranteed by the Fifth, 3 questions regarding this lawsuit However, at the 3 Sixth, and Fourteenth Amendment to the constitution. 4 present time my attorneys have counseled me that I 4 Q. Did you instruct her to assist you in 5 cannot provide answers to any questions relevant to 5 gaining access to minor girls for sex? 6 this lawsuit, and I must accept this advice or risk 6 A. I intend to respond to all relevant 7 losing my Sixth Amendment right to effective 7 questions regarding this lawsuit However, at the 8 representation. 8 present time my attorneys have counseled me that I 9 Accordingly, I assert my Federal 9 cannot provide answers to any questions relevant to 10 Constitutional right as guaranteed by the Fifth, 10 this lawsuit, and I must accept this advice or risk 11 Sixth and Fourteenth Amendment to the United States 11 losing my Sixth Amendment right to effective 12 Constitution. 12 representation. 13 Q. You did not call a professional escort 13 Accordingly, ! assert my constitutional 14 because that would likely result in a girl over the 14 rights as guaranteed by the Fifth, Sixth, and 15 age of 18 coming to your house for sex, right? 15 Fourteenth Amendment to the United States 16 MR. BURMAN: Object to the form. 16 Constitution. 17 THE WITNESS: I intend to respond to all 17 Q. Did you instruct any other employees of 18 relevant questions regarding this lawsuit. 18 yours to assist you in pining access to minors for 19 However, at the present time my attorneys have 19 sex? 20 counseled me that I cannot provide answers to 20 A. I intend to respond to all relevant 21 any questions relevant to this lawsuit, and I 23. questions regarding this lawsuit. However, at the 22 must accept this advice or risk losing my Sixth 22 present time my attorneys have counseled me that 23 Amendment right to effective representation. 23 cannot provide answers to any questions relevant to 24 Accordingly, I assert my Federal 24 this lawsuit, and I must accept this advice or risk 25 Constitutional rights as guaranteed by the 25 losing my Sixth Amendment right to effective Page 118 Page 120 1. Fifth, Sixth, and Fourteenth Amendment of the 1 representation. 2 constitution. 2 Accordingly, I assert my Federal 3 Q. (By Mr. Edwards) Do you enjoy coercing 3 Constitutional rights as guaranteed by the Fifth, 4 minors into sex acts with you? 4 Sixth, and Fourteenth Amendment to the United States MR BURMAN: Object to the form. 5 Constitution. 6 THE WITNESS: I intend to respond to all 6 Q What people were living with you in your 7 relevant questions regarding this lawsuit 7 Palm Beach mansion between 2001 and 2005? 8 However, at the present time my attorneys have MR. GOLD13ERGER: Object to the form. 9 counseled me that I cannot provide answers to 9 THE WITNESS: I intend to respond to all 10 any questions relevant to this lawsuit, and I 10 relevant questions regarding this lawsuit. 13. must accept this advice or risk losing my Sixth 13. However, at the present time my attorneys have 12 Amendment right to effective repri..x.ntation. 12 counseled me that I cannot provide answers to 13 Accordingly, I assert my Federal 13 any questions relevant to this lawsuit, and I 14 Constitutional right as guaranteed by the 14 must accept this advice or risk losing my Sixth 15 Fifth, Sixth, and Fourteenth Amendment to the 15 Amendment right to effective representation. 16 United States Constitution. 16 Accordingly, I assert my Federal 7 II1By Mr. Edwards) Do you know- 17 Constitutional rights as guaranteed by the 18 Fifth, Sixth, and Fourteenth Amendment to the 19 intend to respond to all relevant 19 United States Constitution. 20 questions regarding this lawsuit However, at the 20 Q. (By Mr. Edwards) Did you meet with people 21 present time my attorneys have counseled me that I 23. employed by you to discuss a plan to gain access to 22 cannot provide answers to any questions relevant to 22 minor girls for the purposes of sex? 23 this lawsuit, and I must accept this advice or risk 23 A. I intend to respond to all relevant 24 losing my Sixth Amendment right to effective 24 questions regarding this lawsuit. However, at the 25 reuresentation. 25 ,resent time my attomevs have counseled me that I 30 (Pages 117 to 120) PALM BEACH REPORTING SERVICE, INC. EFTA01103355 Page 121 Page 123 1 cannot provide answers to any questions relevant to 1. representation. 2 this lawsuit, and I must accept this advice or risk 2 Accordingly, lessen my Federal 3 losing my Sixth Amendment right to effective 3 Constitutional rights as guaranteed by the Fifth, 4 representation. 4 Sixth, and Fourteenth Amendment of the United States 5 Accordingly, I assert my Federal 5 Constitution. 6 Constitutional rights as guaranteed by the Fifth, 6 Q. Did you ever personally procure a, or 7 Sixth, and Fourteenth Amendment to the United States 7 sorry, strike that. 8 Constitution. a Did you ever personally go out and recruit 9 Q. Which employees did you discuss your plan 9 a minor girl to bring back to your house for sex? 10 to gain access to minor girls for the purposes of to THE WITNESS: Object to form, no? 11 sex? 11 MR. BURMAN: Object to form. 12 A. I intend to respond to all relevant 12 THE WITNESS: I intend to respond to all 13 questions regarding this lawsuit However, at the 13 relevant questions regarding — 14 present time my attorneys have counseled me that I 14 MR. EDWARDS: I'm sorry, is there 15 cannot provide answers to any questions relevant to 15 something you don't understand about the 16 this lawsuit, and I must accept this advice or risk 16 question? If you don't, TII rephrase it. 17 losing my Sixth Amendment right to effective 17 MR. GOLDBERGER We objected to the form, 18 representation. 18 now you can answer. 19 Accordingly, I assert my Federal 19 MR. EDWARDS: I thought he objected to the 20 Constitutional rights as guaranteed by the Fifth, 20 form, that's why I was -- 21 Sixth, and Fourteenth Amendment to the United States 21 MR. GOLDBERGER: He asked -- I'm not — 22 Constitution. 22 Brad, he asked his lawyer a question, that's 23 Q. Is it true that you have many people 23 all. We objected to the form, that's fine. 24 working in your house in Palm Beach County, or did, 24 MR. EDWARDS: Okay. 25 between the years 2001 and 2005? 25 MR. GOLDBERCIER: Go ahead and answer. Page 122 Page 124 1 A. I intend to respond to all relevant 1 THE WITNESS: I intend to respond to all 2 questions regarding this lawsuit However, at the 2 relevant questions regarding this lawsuit 3 present time my attorneys have counseled me that 1 3 However, at the present time my attorneys have 4 cannot provide answers to any questions relevant to 4 counseled mo that I cannot provide answers to this lawsuit, and I must accept this advice or risk any questions relevant to this lawsuit, and I 6 losing my Sixth Amendment right to effective 6 must accept the advice or risk losing my Sixth 7 representation. 7 Amendment right to effective representation. a Accordingly, I assert my Federal 8 Accordingly, lessen my Federal 9 Constitutional right as guaranteed by the Fifth, 9 Constitutional right as guaranteed by the 10 Sixth, and Fourteenth Amendment to the United States 10 Fifth, Sixth, and Fourteenth Amendments to the 11 Constitution. 11 United States Constitution. 12 Q. How many employees work in the various 12 Q. (By Mr. Edwards) Who is the first minor 13 houses that you own right now? 13 girl that you brought to your house for sex? 14 A. That's — that question is owned right 14 MR. BURMAN: Object to the form. 15 now? I don't understand the question. 15 THE WITNESS: I intend to respond to all 16 Q. Well, it's my understanding that you own 16 relevant questions regarding this lawsuit. 17 numerous properties. I just want to know how many 17 However, at the present time my attorneys have 1a people are actually paid by you or employed by you 18 counseled me that I cannot provide answers to 19 that work and/or live in those homes? 19 any questions relevant to this lawsuit, and I 20 A. I intend to respond to all relevant 20 must accept the advice or risk losing my Sixth 21 questions regarding this lawsuit. However, at the 21 Amendment to effective representation. 22 present time my attorneys have counseled me that I 22 Accordingly, I assert my Federal 23 cannot provide answers to any questions relevant to 23 Constitutional rights as guaranteed by the 24 this lawsuit, and I must accept this advice or risk 24 Fifth, Sixth, and Fourteenth Amendment to the 25 losin m Sixth Amendment Vitt° effective 25 United States Constitution. 121 to 124 PALM BEACH REPORTING SERVICE, INC. EFTA01103356 Page 125 Page 127 1 Q. (By Mr. Edwards) Have you had sex with 1 relevant questions regarding this lawsuit. 2 over 100 minor girls in the last ten years? 2 However, at the present time my attorneys have 3 MR. BURMAN: Object to the In 3 counseled me that I cannot provide answers to 4 THE WITNESS: I intend to respond to all 4 any questions relevant to this lawsuit, and I 5 relevant questions regarding this lawsuit. 5 must accept this advice or risk losing my Sixth 6 However, at the present time my attorneys have 6 Amendment right to effective representation. 7 counseled me that I cannot provide answers to 7 Accordingly, I assert my Federal 8 any questions relevant to this lawsuit, and I 8 Constitutional rights as guaranteed by the 9 must accept this advice or risk losing my Sixth 9 Fifth, Sixth, and Fourteenth Amendment to the 10 Amendment right to effective representation. 10 United States Constitution. 13. Accordingly, I assert my Federal 11 Q. (By Mr. Edwards) Was the target age range 12 Constitutional rights as guaranteed by the 12 for your criminal enterprise always minors between 13 Fifth, Sixth, and Fourteenth Amendment to the 13 the ages of 12 and 16? 14 United States Constitution. 14 MR. BURMAN: Object to the form. 15 Q. (By Mr. Edwards) When did you devise your 15 THE WITNESS: I intend to respond to all 16 plan to gain access to minor girls for sex? 16 relevant questions regarding this lawsuit. 17 MR. BURMAN: Object to the form. 17 However, at the present time my attorneys have 18 THE WITNESS: I intend to respond to all 18 counseled me that I cannot provide answers to 19 relevant questions regarding this lawsuit. 19 any questions relevant to this lawsuit, and I 20 However, at the present time my attorneys have 20 must accept this advice or risk losing my Sixth 23. counseled me that I cannot provide answers to 21 Amendment right to effective representation. 22 any questions relevant to this lawsuit, and I 22 Accordingly, I assert my Federal 23 must accept this advice or risk losing my Sixth 23 Constitutional rights as guaranteed by the 24 Amendment right to effective representation. 24 Fifth, Sixth, and Fourteenth Amendments to the 25 Accordingly, I assert my Federal 25 United States Constitution. Page 126 Page 128 1 Constitutional rights as guaranteed by the 1 Q. (By Mr. Edwards) What are the names of 2 Fifth, Sixth, and Fourteenth Amendment to the 2 all of the members of your criminal enterprise that 3 United States Constitution. 3 has the common goal of procuring minors for the 4 Q. (By Mr. Edwards) With whom did you meet 4 purposes of sex? 5 to discuss your plan to gain access to minor girls 5 MR BURMAN: Object to the form. 6 for sex? 6 THE WITNESS: I intend to respond to all 7 MR. BURMAN: Object to the form. 7 relevant questions regarding this lawsuit 8 THE WITNESS: I intend to respond to all 8 However, at the present time my attorneys have 9 relevant questions regarding this lawsuit 9 counseled me that I cannot provide answers to 10 However, at the present time my attorneys have 3.0 any questions relevant to this lawsuit, and I 11 counseled me that I cannot provide answers to 11 must accept this advice or risk losing my Sixth 12 any questions relevant to this lawsuit, and I 12 Amendment to effective representation. 13 must accept this advice or risk losing my Sixth 13 Accordingly, I assert my Federal 14 Amendment right to effective representation. 14 Constitutional tights as guaranteed by the 15 Accordingly, I assert my Federal 15 Fifth, Sixth, and Fourteenth Amendment to the 16 Constitutional right as guaranteed by the 16 United States Constitution. 17 Fifth, Sixth, and Fourteenth Amendment to the 17 Q. (By Mr. Edwards) In addition to paying 18 United States Constitution. 18 each of these minor girls approximately $200 for 19 Q. (By Mr. Edwards) Do you agree that you 19 sex, did you also provide transportation for them to 20 have a criminal enterprise that is comprised of at 20 and from your house? 21 the least, yourself, and 21 MR. BURMAN: Are we generic, or are we 22 who have the common goal o nil 22 going with the 49? 23 minors to you for the purposes of sex? 23 MR. EDWARDS: Generic. 24 MR. BURMAN: Object to the form. 24 MR. BURMAN: Generic? Okay. Object to 25 THE WITNESS: I intend to respond to all 25 the form. 32 (Pages 125 to 128) PALM BEACH REPORTING SERVICE, INC. EFTA01103357 Page 129 Page 131 1 THE WITNESS: You have to repeat the 1 Accordingly, I assert my Federal 2 question, Fin sorry. 2 Constitutional right as guaranteed by the 3 Q. (By Mr. Edwards) In addition to paying 3 Fifth, Sixth and Fourteenth Amendment to the 4 minor girls approximately $200 to engage in sex or 4 United States Constitution. 5 sex acts with them, did you also provide 5 Sorry, can we take a break again? 6 transportation for these minor girls to and from 6 Bathroom break. 7 your house? 7 MR. EDWARDS: Let's just break for lunch 8 MIL BURMAN: Same objection. 8 then. 9 THE WITNESS: I intend to respond to all 9 MR. GOLDBERGER: I can't, because I've 10 relevant questions regarding this lawsuit. 10 got — there's a reason why, I've got a 13. However, at the present time my attorneys have 11 commitment at 1:15, so — 12 counseled me that I cannot provide any answers 12 THE VIDEOGRAPHER: Off the record at 13 relevant to this lawsuit, and I must accept the 13 12:40. 14 advice or risk losing my Sixth Amendment right 14 (Thereupon, a discussion was had off 15 to effective representation. 15 the record.) 16 Accordingly, I assert my Federal 16 (Thereupon, a brief break was taken.) 17 Constitutional rights as guaranteed by the 17 THE VIDEOGRAPHER: Back on the record at 18 Fifth, Sixth, and Fourteenth Amendment to the 18 12:54. 19 United States Constitution. 19 Q. (By Mr. Edwards) Between 2001 and 2005 20 Q. (By Mr. Edwards) Did you, one of your 20 did you or any of your employees or assistants have 21 employees, or someone within your enterprise have an 21 an account with Yellow Cab? 22 account with Yellow Cab for the purposes of 22 A. I intend to respond to all relevant 23 transporting minors to and from your house? 23 questions regarding this lawsuit. However, at the 24 MR. BURMAN: Object to form. 24 present time my attorneys have counseled me that I 25 MR. GOLDBERGER: Do you understand the 25 cannot provide answers to any questions relevant to Page 130 Page 132 1 question when he says "enterprise"? Do you 1 this lawsuit, and I must accept their advice or risk 2 have any idea what he means? 2 losing my Sixth Amendment right to effective 3 THE WITNESS: No. 3 representation. 4 MR. GOLDBERGER: Can you define 4 Accordingly, I assert my Federal 5 enterprise, so we can determine whether we need 5 Constitutional right as guaranteed by the Fifth, 6 to answer the question. 6 Sixth, and Fourteenth Amendment to the United States 7 MR. EDWARDS: Pin talking about persons 7 Constitution. 8 involved with a common goal. We have defined 8 Q. Are you currently actually a billionaire? 9 this earlier. 9 MR. BURMAN: Objection. That goes to 10 MR. GOLDBERGER: Pm sorry, I was out of 10 punitive damages, and I object. 11 the room did you define it? 11 THE WITNESS: I intend to respond to all 12 MR. EDWARDS: You were out of the room. 12 relevant questions regarding this lawsuit. 13 MR GOLDBERGER: Okay. 13 However, at the present time my attorneys have 14 MR. EDWARDS: And persons we defined it 14 counseled me that I cannot provide answers to 15 n, 15 any questions relevant to this lawsuit, and I having the common 16 must accept this advice or risk losing my Sixth 17 goo o ringing minors to an from the Palm 17 Amendment right to effective representation. 18 Beach house for the purposes of sex. 18 Accordingly, I assert my Federal 19 THE WITNESS: I intend to respond to all 19 Constitutional right as guaranteed by the 20 relevant questions regarding this lawsuit. 20 Fifth, Sixth, and Fourteenth Amendment to the 21 However, at the present time my attorneys have 21 United States Constitution. 22 counseled me that I cannot provide answers to 22 MR. BURMAN: And I should add for the 23 any questions relevant to this lawsuit, and I 23 record that I would instruct him not to answer 24 must accept this advice or risk losing my Sixth 24 that question, even if he wasn't invoking the 25 Amendment right to effective reresentation. 25 Fifth. 33 (Pages 129 to 132) PALM BEACH REPORTING SERVICE, INC. EFTA01103358 Page 133 Page 135 1 Q. (By Mr. Edwards) Between 2001 and 2005 1 Q. (By Mr. Edwards) What is the square 2 were you a billionaire? 2 footage of your house in Palm Beach? 3 MR. BURMAN: Objection, instruct you not 3 MR. BURMAN: Object, on the grounds that 4 to answer that question based on the fact that 4 that question, in part, delves into his 5 that's directed toward punitive damages, and 5 financial situation, which has not been 6 that has not been allowed to file, be filed, or 6 approved to be explored in this case yet, 7 proceeded with in the state court action. 7 because punitive damages have not been approved 8 You should read that, as well. 8 or allowed to be proceeded with here, and I 9 THE WITNESS: I intend to respond to all 9 instruct him not to answer the question. 10 relevant questions regarding this lawsuit. 10 THE WITNESS: I intend to respond to all 11 However, at the present time my attorneys have 11 relevant questions regarding this lawsuit. 12 counseled me that I cannot provide answers to 12 However, at the present time my attorneys have 13 any questions relevant to this lawsuit, and I 13 counseled me that I cannot provide answers to 14 must accept their advice or risk losing my 14 any questions relevant to this lawsuit, and 15 Sixth Amendment right to effective 15 must accept his advice or risk losing my Sixth 16 representation. 16 Amendment right to effective representation. 17 Accordingly, ! assert my Federal 17 Accordingly, I assert my Federal 18 Constitutional rights as guaranteed by the 18 Constitutional rights as guaranteed by the 19 Fifth, Sixth and Fourteenth Amendment to the 19 Fifth, Sixth and Fourteenth Amendment to the 20 United States Constitution. 20 United States Constitution. 21 Q. (By Mr. Edwards) Between 2001 and 2005 21 Q. (By Mr. Edwards) Did you tell the minor 22 what types of cars did you have that you owned, 22 girls that were at your house that you were 23 parked in your driveway at your Palm Beach mansion? 23 extremely wealthy between 2001 and 2005? 24 MIt BURMAN: Object, once again on the 24 MR. GOLDBERGER: Object to the form. 25 grounds that punitive damages have not been 25 THE WITNESS: I intend to respond to all Page 134 Page 136 1 approved yet in this case I instruct him not 1 relevant questions regarding this lawsuit. 2 to answer that question. 2 However, at the present time my attorneys have 3 THE WITNESS: I intend to respond to all 3 counseled me that I cannot provide answers to 4 relevant questions regarding this lawsuit. 4 any questions relevant to this lawsuit, and I 5 However, at the present time my attorneys have 5 must accept this advice or risk losing my Sixth 6 counseled me that I cannot provide answers to 6 Amendment right to effective representation. 7 any questions relevant to this lawsuit, and I 7 Accordingly, I assert my Federal 8 must accept this advice or risk losing my Sixth 8 Constitutional rights as guaranteed by the 9 Amendment right to effective representation. 9 Fifth, Sixth and Fourteenth Amendment to the 10 Accordingly, I assert my Federal 10 United States Constitution. 11 Constitutional rights as guaranteed by the 11 Q. (13y Mr. Edwards) Did you talk to the 12 Fifth, Sixth, and Fourteenth Amendment to the 12 minor girls that were at your house between 2001 and 13 United States Constitution. 13 2005 about all of the houses and cars that you 14 Q. (By Mr. Edwards) Is your house in Palm 14 owned? 15 Beach located on the water? 15 MR. BURMAN: Object to the form. 16 THE WITNESS: I intend to respond to all 16 THE WITNESS: I intend to respond to all 17 relevant questions regarding this lawsuit. 17 relevant questions regarding this lawsuit. 18 However, at the present time my attorneys have 18 However, at the present time my attorneys have 19 counseled me that I cannot provide answers to 19 counseled me that I cannot provide answers to 20 any questions relevant to this lawsuit, and I 20 any questions relevant to this lawsuit, and 1 21 must accept this advice or risk losing my Sixth 21 must accept this advice or risk losing my Sixth 22 Amendment right to effective representation. 22 Amendment right to effective representation. 23 Accordingly, I assert my Federal 23 Accordingly, I assert my Federal 24 Constitutional rights under the Fifth, Sixth, 24 Constitutional rights as guaranteed by the 25 and Fourteenth Amendment to the constitution. 25 Fifth Sixth and Fourteenth Amendment to the 34 (Pages 133 to 1 3 6) PALM BEACH REPORTING SERVICE, INC. EFTA01103359 Page 137 Page 139 1 NIAWdStmesOmsituSom 1 THE WITNESS: I intend to respond to all 2 • Q. (By Mr. Edwards) Did you use your wealth 2 relevant questions regarding this lawsuit. 3 and the minors lack thereof to influence that minor 3 However, at the present time my attorneys have 4 to have sex with you? 4 counseled me that I cannot provide answers to 5 MR. BURMAN: Object to the form. 5 any questions relevant to this lawsuit, and I 6 THE WITNESS: I intend to respond to all 6 must accept the advice or risk losing my Sixth 7 relevant questions regarding this lawsuit 7 Amendment right to effective representation. 8 However, at the present time my attorneys have 8 Accordingly, I assert my Federal 9 counseled me that I cannot provide answers to 9 Constitutional rights as guaranteed by the 1 10 any questions relevant to this lawsuit, and 10 Fifth, Sixth, and Fourteenth Amendments to the 11 must accept advice or risk losing my Sixth 11 United States Constitution. 12 Amendment right to effective representation. 12 Q. (By Mr. Edwards) Was it part of your plan 13 Accordingly, I assert my Federal 13 to display your wealth and power in an effort to 14 Constitutional rights as guaranteed by the 14 gain sexual access to minor girls? 15 Fifth, Sixth, and Fourteenth Amendment to the 15 MR. BURMAN: Object to the form. 16 United States Constitution. 16 THE WITNESS: I intend to respond to all 17 Q. (By Mr. Edwards) After you ejaculated in 17 relevant questions regarding this lawsuit. 18 front of minor girls, did you tell each one of them 18 However, at the present time my attorneys have 19 that every time she came to your house for sex, you 19 counseled me that I cannot provide answers to 20 would pay her $200 cash? 20 any questions relevant to this lawsuit, and I 21 MR. BURMAN: Object to the form. 21 must accept the advice or risk losing my Sixth 22 THE WITNESS: I intend to respond to all 22 Amendment right to effective representation. 23 relevant questions regarding this lawsuit. 23 Accordingly, I assert my Federal 24 However, at the present time my attorneys have 24 Constitutional rights as guaranteed by the 25 counseled me that I cannot provide answers to 25 Fifth, Sixth, and Fourteenth Amendment to the Page 138 Page 140 1 any questions relevant to this lawsuit, and I 1 United States Constitution. 2 must accept the advice or risk losing my Sixth 2 Q. (By Mr. Edwards) Did you intentionally 3 Amendment right to effective representation. 3 target very poor minor girls because you knew that 4 Accordingly, I assert my Federal 4 demographic would be the most impressed by your 5 Constitutional rights as guaranteed by the 5 wealth and likely listen to you? 6 Filth, Sixth, and Fourteenth Amendment to the 6 MR. BURMAN: Object to the form. 7 United States Constitution. 7 THE WITNESS: I intend to respond to all 8 Q. (By Mr. Edwards) Was it your plan to 8 relevant questions regarding this lawsuit. 9 groom each minor girl to be your personal sex slave? 9 However, at the present time my attorneys have 10 MR. BURMAN: Object to the form. 10 counseled me that I cannot provide answers to 11 THE WITNESS: I intend to respond to all 13. any questions relevant to this lawsuit, and 12 relevant questions regarding this lawsuit. 12 must accept this advice or risk losing my Sixth 13 However, at the present time my attorneys have 13 Amendment right to effective representation. 14 counseled me that I cannot provide answers to 14 Accordingly, I assert my Federal 15 any questions relevant to this lawsuit, and I 15 Constitutional right as guaranteed by the 16 must accept this right or risk losing my Sixth 16 Fifth, Sixth, and Fourteenth Amendment to the 17 Amendment right to effective representation? 17 United States Constitution. 18 Accordingly, I assert my Federal 18 Q. (By Mr. Edwards) None of the minor girls 19 Constitutional rights as guaranteed by the 19 that you engaged in sex or sex acts with had ever 20 Fifth, Sixth, and Fourteenth Amendment to the 20 engaged in prostitution prior to meeting you, isn't 23. United States Constitution. 21 that comet? 22 Q. (By Mr. Edwards) Did you impress upon 22 MR. BURMAN: Object to the form. 23 each minor girl that what she was doing with you 23 THE WITNESS: I intend to respond to all 24 sexually was morally right? 24 relevant questions regarding this lawsuit. 25 MR. BURMAN: Object to the form. 25 However at the present time m attorn have 35 (Pa es 137 to 140) PALM BEACH REPORTING SERVICE, INC. EFTA01103360 Page 141 Page 143 1 counseled me that I cannot provide answers to 1 Constitutional rights as guaranteed by the 2 any questions relevant to this lawsuit, and I 2 Fifth, Sixth, and Fourteenth Amendment in the 3 must accept the advice or risk losing my Sixth 3 United States Constitution. Amendment right to effective representation. 4 Q. (By Mr. Edwards) Isn't it true that Accordingly, I assert my Federal 5 and your employees, including called 6 Constitutional rights as guaranteed by the 6 these minor girls to encourage them to bring more 7 Fifth, Sixth and Fourteenth Amendment to the 7 minor girls to you for sex. By called I =an on the 8 United States Constitution. 8 telephone? 9 Q. (By Mr. Edwards) Isn't it true that you 9 MR. BURMAN: Object to the form. 10 corrupted and injured minor girls for your own 10 THE WITNESS: Can you repeat the question? 11 sexual gratification? 11 Q. (By Mr. Edwards) Isn't it true that you 12 MR. BURMAN: Object to the form. 12 lam a assistants or employees, including MI 13 THE WITNESS: I intend to respond to all 13 called minor girls on the telephone to 14 relevant questions regarding this lawsuit. 14 encourage them or command that they bring you other 15 However, at the present time my attorneys have 15 minor girls for sex? 16 counseled me that I cannot provide answers to 16 MR. BURMAN: Object to the form. 17 any questions relevant to this lawsuit, and I 17 THE WITNESS: I intend to respond to all 18 must accept this advice or risk losing my Sixth 18 relevant questions regarding this lawsuit. 19 Amendment right to effective ivpiebentation. 19 However, at the present time my attorneys have 20 Accordingly, I assert my Federal 20 counseled me that I cannot provide answers to 21 Constitutional rights as guaranteed by the 21 any questions relevant to this lawsuit, and I 22 Fifth, Sixth, and Fourteenth Amendment to the 22 must accept this advice or risk losing my Sixth 23 United States Constitution. 23 Amendment right to effective representation. 24 Q. (By Mr. Edwards) Isn't it true that you 24 Accordingly, I assert my Federal 25 typically engaged in sex or sex acts with minor 25 Constitutional rights as guaranteed by the Page 142 Page 144 1 girls three or four times each day at your Palm 1 Fifth, Sixth, and Fourteenth Amendment to the 2 Beach mansion? 2 United States Constitution. 3 MR. BURMAN: Object to the form. 3 Q. (By Mr. Edwards) What are all the 4 THE WITNESS: I intend to respond to all 4 telephone numbers assigned to you or your Palm Beach 5 relevant questions regarding this lawsuit. 5 mansion between 2001 and 2005? 6 However, at the present time my attorneys have 6 A. Again? 7 counseled me that I cannot provide answers to 7 Q. What were all of the telephone numbers 8 any questions relevant to this lawsuit, and I 8 assigned to you or your Palm Beach mansion between 9 must accept this advice or risk losing my Sixth 9 2001 and 2005? 10 Amendment right to effective representation. 10 A. I intend to respond to all relevant 11 Accordingly, I assert my Federal 11 questions regarding this lawsuit. However, at the 12 Constitutional rights as guaranteed by the 12 present time my attorneys have counseled me that I 13 Fifth, Sixth, and Fourteenth Amendment to the 13 cannot provide answers to any questions relevant to 14 United States Constitution. 14 this lawsuit, and I must accept this advice or risk 15 Q. (By Mr. Edwards) Isn't it true that you 15 losing my Sixth Amendment right to effective 16 in, that you coerced minor girls into prostitution? 16 representation. 17 MR. BURMAN: Object to the form. 17 Accordingly, i assert Federal 18 THE WITNESS: I intend to respond to all 18 Constitutional rights as guaranteed by the Fifth, 19 relevant questions regarding this lawsuit. 19 Sixth, and Fourteenth Amendment to the United States 20 However, at the present time my attorneys have 20 Constitution. 21 counseled me that I cannot provide answers to 21 Q. Who scheduled your massage appointments 22 any questions relevant to this lawsuit, and I 22 between 2001 and 2005? 23 must accept this advice or risk losing my Sixth 23 A. I intend to respond to all relevant 24 Amendment right to effective representation. 24 questions regarding this lawsuit. However, at the 25 Accordin0v I assert m Federal 25 rifeSent time mcaltylneis have counseled me that I 36 (Pages 141 to 144) PALM BEACH REPORTING SERVICE, INC. EFTA01103361 Page 145 Page 147 1 cannot provide answers to any questions relevant to 1 Accordingly,lassert my Federal 2 this lawsuit, and I must accept this advice or risk 2 Constitutional lights as guaranteed by the Fifth, 3 losing my Sixth AnietaInwat right to effective 3 Sixth, and Fourteenth Amendment to the United States 4 representation. 4 Constitution. 5 THE WITNESS: Excuse me? 5 Q. Did you rely on and your 6 Accordingly I assert my Federal 6 other assistants to y sc u e these minor 7 Constitutional rights as guaranteed by the 7 girls in a way so that they would not come in 8 Fifth, Sixth, and Fourteenth Amendment to the 8 contact with one another? 9 United States Constitution. 9 MR. BURMAN: Object to form. 10 Q. (By Mr. Edwards) Is it true that you were 10 THE WITNESS: I intend to respond to all 11 ejaculating in front of three or four minor girls 11. relevant questions regarding this lawsuit. 12 per day between 2002 and 2005 at your Palm Beach 12 However, at the present time my alio' nays have 13 mansion? 13 counseled me that I cannot provide answers to 14 MR. BURMAN: Object to the form. 14 any questions relevant to this lawsuit, and I 15 THE WITNESS: I intend to respond to all 15 must accept their advice or risk losing my 16 relevant questions regarding this lawsuit 16 Sixth Amendment Right to effective 17 However, at the piesent time my attorneys have 17 representation. 18 counseled me that I cannot provide answers to 18 So, accordingly, l assert my 19 any questions relevant to this lawsuit, and I 19 Constitutional rights as guaranteed by the 20 must accept the advice or risk losing my Sixth 20 Fifth, Sixth and Fourteenth Amendments to the 21 Amendment tight to effective representation. 21 United States Constitution. 22 Accordingly, I assert my Federal 22 MR. EDWARDS: Ready to break? 23 Constitutional rights as guaranteed by the 23 MR. GOLDBERGER: He wants to eat. 24 Fifth, Sixth, and Fourteenth Amendment to the 24 THE VIDEOORAPHER: We're off the record at 25 United States Constitution. 25 1:12. Page 146 Page 148 1 Q. (By Mr. Edwards) Have you ever treated 3. (Thereupon, a lunch break was taken 2 with any doctors or physicians and discussed sexual 2 from 1:12 to 2:32 p.m.) 3 issues with them? 3 THE VTDEOGRAPHER: Were back on record at 4 THE WITNESS: I intend to respond to all 4 2:32. 5 relevant questions regarding this lawsuit 5 MR. EDWARDS: Ready? 6 However, at the present time my attorneys have 6 MR. GOLDI3ERGER: Sure. 7 counseled me that 1cannot provide answers to 7 Q. (By Mr. Edwards) Mr. Epstein, did you 8 any questions relevant to this lawsuit, and I 8 ever care about any of the feelings of the minor 9 must accept this advice or risk losing my Sixth 9 girls that you were engaging in sex with? 10 Amendment right to effective representation. 10 MR. BURMAN: Object to the form. 11 Accordingly, I assert my Federal 11 THE WITNESS: I intend to respond to all 12 Constitutional rights as guaranteed by the 12 relevant questions regarding this lawsuit. 13 Fifth, Sixth, and Fourteenth Amendment to the 13 However, at the present time my attorneys have 14 United States Constitution. 14 counseled me that I cannot provide answers to 15 Q. (By Mr. Edwards) Did you and your 15 any questions relevant to this lawsuit at this 16 assistants or employees use the word work, W-O-R-K, 16 time, so I must accept their advice or I lose 17 to describe you engaging in sex acts with minors at 17 potential -- I risk losing my Sixth Amendment 18 your house? 18 right to effective lepon.entation. 19 A. I intend to respond to all relevant 19 And accordingly, I have to assert my 20 questions regarding this lawsuit. However, at the 20 Federal Constitutional rights as guaranteed by 21 present time my attorneys have counseled me that I 21 the Fifth, Sixth and Fourteenth Amendment to 22 cannot provide answers to any questions relevant to 22 the United States Constitution. 23 this lawsuit, and I must accept their advice or risk 23 Q. (By Mr. Edwards) Did it ever occur to you 24 losing my Sixth Amendment right to effective 24 that any of these girls were somebody's daughter -- 25 representation. 25 MR. BURMAN: Object to the form. 37 (Pages 145 to 148) PALM BEACH REPORTING SERVICE, INC. EFTA01103362 Page 149 Page 151 1 Q. (By Mr. Edwards) — when you were 1 Q. (By Mr. Edwards) Isn't it true that at 2 engaging in sex with them? 2 the time that you were sexually battering these 3 MR. BURMAN: Object to the form of the 3 minor girls, you didn't care what happened to them 4 question. 4 and only cared about your only personal sexual 5 THE VIDEOGRAPHER: I intend to respond to 5 gratification? 6 all relevant questions regarding this lawsuit. 6 MR. BURMAN: Object to the form. We need 7 However, at the present time my attorneys have 7 to talk outside. 8 counseled me that I cannot provide answers to 8 THE WITNESS: Me, too? 9 these questions, as I have to accept their 9 THE VIDEOGRAPHER: We're off the record at 10 advice or risk losing my Sixth Amendment right 10 2:35. 11 to effective representation, Brad. 11 (Thereupon, a brief break was taken.) 12 THE WITNESS: Is it okay if I call you 12 THE VIDEOGRAPHER: We're back on the 13 Brad? 13 record at 2:36. 14 MR EDWARDS: You can continue. 14 MR. BURMAN: For the purposes of the 15 THE WITNESS: And, accordingly, I assert 15 record, I will toll you that this line of 16 my Federal Constitutional rights as guaranteed 16 questioning, in my view, is way beyond the 17 by the Fifth, Sixth and Fourteenth Amendment to 17 bounds of permissible discovery-type questions, 18 the United States Constitution. 18 and nothing but pure argument, and if you 19 Q. (By Mr. Edwards) When you were digitally 19 continue in this vein, I will stop the 20 penetrating these minor girls, did you care about 20 deposition and we will seek instruction from 21 the fact that you were emotionally or 21 Judge Hafele about what's permissible and 22 psychologically hurting them? 22 what's not. 23 MR. BURMAN: Object to the form of the 23 Q. (By Mr. Edwards) Isn't it true that at 24 question. 24 the time you were inserting your fingers into the 25 THE WITNESS: I intend to respond to all 25 vagina of these little kids, all you cared about was Page 150 Page 152 1 relevant questions regarding this lawsuit. 1 your own sexual gratification? 2 However, at the present time my attorneys have 2 MR. BURMAN: The deposition is over. 3 counseled me that I cannot provide answers to 3 THE VIDEOGRAPHER: Conclude at 2:37, end 4 any questions relevant to this lawsuit, and I 4 of tape 2 of 2. 5 must accept this advice or risk losing my Sixth MR. BERGER: We're going to order instant 6 Amendment right to effective representation. 6 copy, and we want the tape, also, 7 Accordingly, I assert my Federal 7 Mr. Videographer. 8 Constitutional rights as guaranteed by the 8 MR. BURMAN: We want this as soon as they 9 Fifth, Sixth, and Fourteenth Amendments to the 9 get theirs, we want ours. 10 United States Constitution. 10 (Thereupon, the deposition was 11 Q. (By Mr. Edwards) We have heard over and 11 adjourned at 2:38 p.m.) 12 over again that you intend to respond to this. When 12 13 do you intend to respond to these questions? 13 14 MR. BURMAN: Object to the form. 14 5 THE WITNESS: I intend to respond to all 15 16 relevant questions regarding this lawsuit. 16 17 However, at the present time on advice of 17 18 counsel I cannot provide answers to those 18 19 questions at this time. I must accept advice 19 20 of my counsel or risk losing my Sixth Amendment 20 21 right to effective representation. 21 22 Accordingly, I'll have to assert my 22 23 Federal Constitutional rights as guaranteed by 23 24 the Fifth, Sixth, and Fourteenth Amendment to 24 25 the United States Constitution. 25 38 (Pages 149 to 1 5 2) PALM BEACH REPORTING SERVICE, INC. EFTA01103363 Page 153 Page 155 1 CERTIFICATE OF OATH 1 TO I MILEY EPSTEIN elo MENA& URMAN. ESQUIRE 2 2 515 N JOHN onb Fluke Drive BrStile 400 Nest Peen Beach, Florida 33401 STATE OF FLORIDA ) 3 3 : SS 4 air. vs. 7117FREY EPSTEIN and COUNTY OF PALM BEACH ) s 4 6 Al tht conclusion of your depositien gives 5 I, the undersigned authority, certify that 7 In the abovutylod cute too Indicated you withod 6 JEFFREY EPS1EIN personally appeared before the and 8 I' astir he analla 7 was duly sworn. TS Meer Is b advise you that you 9 depositioa is ready. end re ask eat you anger 8 WITNESS my hand and official seal this 1st oaks ni (Sal) 4713995 Myour maw 9 day of May, 2009. is conuenithes for at appointment tourer in. 11 If you ere path a °akin tter 10 attar has endued a copy of Ode se trensaipt, rat 11 12 aterideb to read lin copy and Ithward to us 2 photostatic othy Oyu: tired cethectke sheet 12 LINDA P. AUKAMP, RPR 13 13 Commission No.: DD 499271 it is secunty dist toedo Elite icon 14 u mt . since dm inmalth mum be hold 14 Notary Public- State of Florida brood months handy date of this Wier. 15 My Commission Expires: 12-26-09 1S If rya have sat/reason which you would 16 16 like Par nth to pact on thedeposition as to re haws to I* *tuna. ukase advise. 17 17 Tank you for you prompt attetthou. 18 18 19 velytnavyvvn. 19 PALM BEACH READRTNG SERVICE. D40. 20 1665 Pain Bach Lakes Ellud. 21 20 Saito 1001 West Palm Beach. Fkeicla 33401 22 n 23 22 BY: LINDA P. AUKAMP.RPR 23 24 Dale Ntay 1st. 2029 25 245 Page 154 Page 156 1 REPORTER'S DEPOSITION CERTIFICATE 1 CORRECTION SHEET: 2 2 NAME: JEFFREY EPSTEIN 3 STATE OF FLORIDA ) I RE: E.W. vs. JEFFREY EPSTEIN and 4 COUNTY OF PALM BEACH ) 4 5 I, LINDA P. AUKAMP, a Registered The following corrections, additions or 6 Professional Reporter, certify that I was authorized 5 deletions were noted on the transcript of the testimony which I gave in the above-captioned matter 7 to and did stenographically report the depositim of 6 held on April 30th, 2009: 8 JEFFREY EPSTEIN; that a review of the transcript was 7 PAGE(S) LINE(S) SHOULD READ 9 requested; and that the transcript is a true and 8 10 complete record of my stenographic notes. 9 11 I FURTHER CERTIFY that on the 1st day of 10 12 May, 2009,1notified JOHN MICHAEL BURMAN, ESQUIRE 11 13 that the deposition of JEFFREY EPSTEIN was ready fa 12 14 reading and signing by the witness. 13 15 I fitrther certify that I am not a 14 16 relative, employee, attorney, or counsel of any of 15 17 the parties, nor am I a relative or employee of any 16 18 of the parties' attorney or counsel connected with 17 19 the action, nor am I financially interested in the 18 19 2O action. 20 21 Dated this 1st day of May, 2009. 21 22 22 SIGNATURE: 23 23 DATE: 24 LINDA P. AUKAMP, RPR 24 25 25 39 (Pages 153 to 156) PALM BEACH REPORTING SERVICE, INC. EFTA01103364