Page 1 Page 3
UNITED STATES DISTRICT COURT 1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
SOUTHERN DISTRICT OF FLORIDA 2 IN AND FOR PALM BEACH COUNTY. FLORIDA
CASE NO. 502008CA028051XXXXMB AB
CASE NO. 08-CIV-80119-MARRA/JOHNSON 3
4 .
JANE DOE NO. 2.
5 Plaintiff.
Plaintiff.
6 -vs- VOLUME I OF III
-vs- VOLUME I OF III
JEFFREY EPSTEIN. 7 JEFFREY EPSTEIN.
Defendant 8 Defendant.
I I
9
Related eases: 10
08-80232. 08-08380. 08-80381. 08-80994 11
08-80993. 08-8081 1. 08-80893. 0940469 12 VIDE TAPED DEPOSITION OF
09.80591. 09-80656. 09-80802. 09-81092 13
r 14
VIIMMI 15 Wednesday. March 24.2010
SMON OF
10:37 - 6:51 p.m.
16
Wednesday. March 24. 2010 17
10:37 - 6:51 p.m. 18 250 Australian Avenue South
Suite 1500
250 Australian Avenue South 19 West Palm Beach. Florida 33401
Suite 1500 20
West Palm Beach. Florida 33401 21
22 Reported By:
Cynthia Hopkins. RPR. FPR
Reported By:
Cynthia Hopkins. RPR. FPR 23 Notary Public. State of Florida
Notary Public. State of Florida Prose Court Reporting Services
Prose Court Reporting Services 24 Job No.: 1484
Job No.: 1484 25
Page 2 Page 4
1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 1 DI THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
IN AND FOR PALM BEACH COUNTY. FLORIDA CIRCUIT IN AND FOR PALM BEACH COUNTY. FLORIDA
2 CASE NO. 502008CA028058XXXXMB AD 2 CASE No302008CA037319XXXXMB AB
3 3
M.
4
5 Plaintiff. Plaintiff.
6 -vs- VOLUME I OF III 5
7 VOLUME I OF III
JEFFREY EPSTEIN. J
8 AN
EFISISI,
Defendant. 8
9 / Defendants.
10 9
11 10
VI SITION OF
11 VItSITION OF
12
12
13
13
14 Wednesday. March 24. 2010
14 Wednesday. March 24. 2010
10:37 - 6:51 p.m.
10:37 - 6:51 p.m.
15
15
16
16
17 250 Australian Avenue South
17 250 Australian Avenue South
Suite 1500
Suite 1500
18 West Palm Beach. Florida 33401 16 West Palm Beach. Florida 33401
19 19
20 20
21 21
22 Repotted By: 22 Repotted By:
Cynthia Hopkins. RPR. FPR Cynthia Hopkins. RPR. FPR
23 Notary Public. State of Florida 23 Notary Public. State of Florida
Prose Court Reporting Services Prose Court Reporting Services
24 Job No.: 1484 24 Job No.: 1484
25 25
1 (Pages 1 to 4)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 1 of 47
EFTA_00065318
EFTA01246464
Page 5 Page 7
APPEARANCES: 1
2 On behalf of the Plaintiffs. : 2 INDEX
SPENCER T. KUVIN. ESQUIRE 3
LEOPOLD KUVIN 4
2925 PGA Boulevard 5 EXAMINATION DIRECT CROSS REDIRECT'
Suite 201)
6
5 Palm Beach Garden. Florida 33410
Phone:
6 7
7 On behalf of the Plandiffs...... and BY MR. KUVIN 9
Jane Doe: a
8 9
9 MATTHEW WEISSING. ESQUIRE 10 EXHIBITS
FARMERJAFTE MUSSING. EDWARDS 11 _ _ _
10 FISTOS & LBIRNIAN.P.L 12
425 North Andimvx Avenue 13 EXHIBIT DESCRIPTION PAGE
11 Suite 2 14
Fort Lauderdale Florida 33301
PLAINTIFFS EX. 1 PHOTO 16
12 Phone:
13 On behalf of Jane Does I throu5h K: 15 PLAINTIFFS EL 2 MOE INC.. 24
14 ADAM D. HOROWITZ- ESQUIRE PASSENGER MANIFEST'
MERNIEI-STEIN it HOROWITZ. P.A. 16 PLAINTIFFS EX. 3 HYPERION AIR. INC..
15 18205 Biscayne Boulevard PASSENGER MANIFEST
Suite 22114 17 PLAINTIFFS EX. 6 PHOTO 63
16 Miami. a t i PLAINTIFFS EL 7 PHOTO 65
Phone: 18 PLAINTIFFS EX. 8 PHOTO 68
17 E-mail: PLAINTIFFS EX. 9 PHOTO 71
16 On behalf of the PI:midis. 101. 102 and 103: 19 PLAINTIFFS EL 10 PHOTO 100
19 KATHERINE W. EZELI- ESQUIRE PLAINTIFFS EL 11 PHOTO 101
AMY JOSEFSBERG EDERI. ESQUIRE 20 PLAINTIFFS EL 12 PHOTO 103
20 PODHURST ORSECK
PLAINTIFFS EX. 4 PHONE MESSAGE PADS
25 wear Flatlet Street
21 Suite WO
21 PLAINTIFFS EL 5 CELLPHONE RECORDS
Miami.iiiiiiiiii PLAINTIFFS EL 13 PHOTO 144
22 Phone: 22
23 1Via telephoner 23
24 24
25 25
Page 6 Page 8
1 Appearances continued... 1 PROCEEDINGS
2 On behalf of the Plaintiff. Jane Doe ll:
2
3 ISIDRO MANUEL GARCIA. ESQUIRE — — —
GARCIA. ELKINS & BOEHRINGER 3 THE VIDEOGRAPHER: We are now on video
4 224 Datum Avenue. Suite 900 4 record. This is Media No. 1 in the videotaped
West Palm Beach Fl ida 33401
5 Phone: 5 deposition of in the matter of
6 6 Jane Doe versus Jeffrey Epstein, et al. Today
7 On behalf of the Defendant:
7 is Wednesday. March 24th. 2010. It is
8 JACK ALAN GOLDBERGER. ESQUIRE
ATTERBURY. GOLDBERGER & WEISS. P.A. 8 10:36 a.m. We are here at Prose Court
9 250 Australian Avenue South 9 Reporting. 250 South Australian Avenue. West
Suite 1400
10 West ida 33401-5012 10 Palm Beach. Florida.
Phony 11 My name is Joe Kozak. I'm the
11
12 videographer. The reporter is Cindy
12
13 On f h Win • 13 Hopkins from Prose Court Reporting Agency.
14 19 Would counsel please introduce
15 yourselves, and then the court reporter
16 will swear in the witness.
17 MR. KUVIN: Good morning. Spencer Kuvin
17 18 on behalf of one of the Plaintiffs.
18
19 MR. HOROWITZ: Adam Horowitz on behalf of
19
20 ALSO PRESENT: 20 Jane Does 2 through 8. And just for the record
21 Jessica Cadwell. Paralegal 21 purposes. the deposition is also being taken in
Burman. Critton. Lanier & Coleman. P.A.
22 the federal cases, I believe, case being
22 Joseph Kozak. Videographer
Prose Court Reporting Services 23 Jane Doe 2 versus Jeffrey Epstein.
23 24 MR. WEISSING: Matt Weissing on behalf of
24
25 25 three of the Plaintiffs.
2 (Pages 5 to 8
PROSE COURT REPORTING AGENCY, INC.
CONFIDENTIAL 3501.125-025
Page 2 of 47
EFTA_00065319
EFTA01246465
Page 9 Page 11
1 MR. GARCIA: Sid Garcia for Jane Doe. 1 privilege.
2 Roman Numeral II. 2 MR. KUVIN: I'll agree with that
3 MR. GOLDBERGER: Jack Goldberger on behalf 3 procedure.
4 of Jeffrey Epstein. 4 MR. Anyone object to that
5 MS. CADWELL: Jessica Cadwell. paralegal. 5 procedure?
6 on behalf of Jeffre stein. 6 MR. GOLDBERGER: Actually I think if, in
7 MR. on behalf 7 fact, this deposition is used in a trial, 1
a of the witness. 8 think you would want the lengthier answer as
9 MR. KUVIN: Kathy. your turn. 9 being the answer that is played to the jury.
10 MS. EZELL: Okay. Kathy Ezell and Amy 10 So either you guys can agree that it gets cut
11 Ederi on behalf of Plaintiff, Jane Doe 103. 11 in or she's going to have to -- I can't tell
12 Thereupon. 12 you what to do, but I would suggest that she
13 l l 13 give the lengthier answer each time.
14 Having been first duly sworn or affirmed, was 14 But there's got to be a way that you
15 examined and testified as follows: 15 guys can reach an agreement though, that
16 DIRECT EXAMINATION 16 from a technology perspective, that the
17 BY MR. KUVIN: 17 lengthy answer that she just gave would be
18 Q. Good morning. 18 used during any trial testimony. Can that
19 A. Morning. 19 be done?
20 Q. Couldyougive us your full name, please. 20 MR. KUVIN: I don't know procedurally
21 A. . 21 whether it can be done.
22 Q. il aiave a middle name? 22 MR. GOLDBERGER: I think --
23 A. 23 MR. KUVIN: I don't know that, well --
24 Q. Would ou s II that for us? 24 MR. GOLDBERGER: And again, it's not my,
25 A. 25 ifs not my deal. I'm just telling you how
Page 10 Page 12
1 Q. What's our current address? 1 we've done it in the past.
2 MR. I'm going to instruct the 2 MR. KUVIN: I hear you. and I have a
3 witness not to answer that question on the 3 number of issues primary, primarily of which
4 basis of her Fifth and 14th Amendment 4 that you're not here to represent anyone
S privileges against self-incrimination. 5 currently.
6 MR. KUVIN: Okay. We had spoken before 6 MR. GOLDBERGER: Yeah. I am. I'm
7 with respect to there are likely going to be 7 actually. I'm actually here representing
8 answers similar to that throughout this 8 Jeffrey Epstein. so...
9 deposition. I have agreed to a procedure that 9 MR. KUVIN: Okay. With respect to all the
10 we can do a shortened answer. However you want 10 civil cases. though. you're not here to
11 to handle that. I leave it up to you. But I do 11 represent anyone, so --
12 agree that whatever the shortened answer is, 12 MR. GOLDBERGER: Yes. I am.
13 that it will satisfy the length. lengthy answer 13 MR. KUVIN: With the exception --
14 that she would like to give. 14 MR. GOLDBERGER: I represent -- I am --1
15 So, do we want to do that with this 15 don't mean to interrupt you. but I am counsel
16 question, or how do you want to handle 16 of record in the civil cases.
17 that procedurall ? 17 MR. KUVIN: Oka . Okay.
18 MR. Well. I think I have given 18 MR. If we have a stipulation,
19 the instruction. I think she, will give her 19 what's the problem? Are you --
20 the same instruction in the future to the 20 MR. KUVIN: There is none.
21 extent that it's relevant, and I think that if 21 MR. -- worried about a waiver?
22 we can all just agree that if she simply says 22 MR. GOLDBERGER: No. I'm not worried abou
23 or I simply say "The Fifth Amendment," that 23 that at all. I'm worried about what is played
24 will qualify as giving a sufficient answer to 24 to a jury if this gets tried.
25 -- a, a matter of law. and will invoke that 25 MR. KUVIN: Okay. And I appreciate you
3 (Pages 9 to 12)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 3 of 47
EFTA_00065320
EFTA01246466
Page 13 Page 15
1 coachingM. but I think he can handle 1 I choose to invoke my Fifth Amendment right.
2 himself pretty adequately now -- 2 BY MR. KUVIN:
3 MR. GOLDBERGER: I have -- 3 Q. Would ou agree with me that you're
4 MR. KUVIN: So I leave it up to -- 4 approximatel
5 MR. GOLDBERGER: I have all the confidence 5 MR. : Same instruction.
6 in . 6 THE WITNESS: On the advice of my lawyer,
7 MR. KUVIN: Mr. with respect to 7 I must invoke my Fifth Amendment right.
8 how you want to handle it. I think we have an 8 BY MR. KUVIN:
9 agreement. 9 Would you agree with me that your eyes are
10 MR. : I'm satisfied that we have 10
11 a stipulation, and I assume if there is ever a 11 MR. Same instruction.
12 trial, that would be played or produced to the 12 THE WITNESS: On the advice of my lawyer,
13 jury that simply by using shorthand, what she's 13 I choose to invoke my Fifth Amendment right.
14 really saying is the lengthier answer now. I'm 14 BY MR. KUVIN:
15 satisfied with that. 15 Q. Would you agree with me that you were born
16 MR. KUVIN: And I agree with that. 16 in
17 BY MR. KUVIN: 17 MR. : Same instruction.
18 Q. Okay. Ma'am, what is your current 18 THE WITNESS: On the advice of my lawyer,
19 address? 19 I choose to invoke my Fifth Amendment right.
20 MR. : Again, I will instruct the 20 BY MR. KUVIN:
21 witness not to answer the question. 21 Q. What are the names of your parents?
22 THE WITNESS: On the instruction of my 22 MR. : Same instruction.
23 lawyer. I choose to invoke my Fifth Amendment 23 THE WITNESS: On the advice of my lawyer,
24 right. 24 I must invoke my Fifth Amendment right.
25 25
Page 14 Page 16
1 BY MR. KUVIN: 1 BY MR. KUVIN:
2 Q. What is our current phone number? 2 Q. Areyou married or single?
3 MR. : Same instruction. 3 MR. : Same instruction.
4 THE WITNESS: On the advice of my lawyer, 4 THE WITNESS: On the advice of my lawyer,
5 I choose to invoke my Fifth Amendment right. 5 I must to invoke my Fifth Amendment right.
6 BY MR. KUVIN: 6 (Plaintiffs Exhibit No. I was marked for
7 Q. What is our cell hone number? 7 identification.)
8 MR. : Same instruction -- 8 MR. KUVIN: I'm going to show you what
9 THE WITNESS: On the advice of my lawyer, 9 we'll mark as Plaintiffs Exhibit I.
10 I choose to invoke m Fifth Amendment right. 10 And I'll ask the videographer to zoom
11 MR. : You have to let me speak 11 in here fora second.
12 before you answer in case there's an objection 12 BY MR. KUVIN:
13 or any of the other lawyers have an objection. 13 Q. Okay. Ma'am, I am going to show you a
14 BY MR. KUVIN: 14 photograph we've marked as Plaintiffs Exhibit 1 and
15 Q. I am going to show you a photograph. Oh, 15 ask you if you recognize this registered sex
16 what is your date of birth? 16 offender.
17 MR. : Same instruction. 17 MR. : First, object to the form
18 THE WITNESS: On the advice of my lawyer, 18 of the question. It assumes facts not before
19 I choose to invoke my Fifth Amendment right. 19 the witness, and I'll give the witness the same
20 MR. KUVIN: Let's make is easier. 20 instruction as to that question.
21 BY MR. KUVIN: 21 THE WITNESS: At the advice of my lawyer,
22 Q. would ou agree with me that 22 I must invoke my Fifth Amendment right.
23 your date of birth i 23 BY MR. KUVIN:
24 MR. : Same instruction. 24 Q. Would you agree with me that this
25 THE WITNESS: On the advice of my lawyer, 25 registered sex offender's name is Jeffrey Epstein?
4 (Pages 13 to 1 6)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 4 of 47
EFTA_00065321
EFTA01246467
Page 17 Page 19
1 MR. Same instruction, same 1 question. It's ambiguous and compound. and I
2 objection. 2 will instruct the witness not to answer based
3 THE WITNESS: At the advice of my lawyer, 3 on her Fifth Amendment privilege.
4 I must invoke my Fifth Amendment right. 4 THE WITNESS: On the advice of my lawyer,
S BY MR. KUVIN: 5 I must invoke my Fifth Amendment right.
6 Q. Would you agree with me that Jeffrey 6 BY MR. KUVIN:
/ Epstein is a sexual offender? 7 Q. And wh did ou do that?
8 MR. Object to the form of the 8 MR. : Object to the form. It's
9 question and instruct the witness not to answer 9 ambiguous, in fact that what?
10 on her Fifth Amendment privilege. 10 BY MR. KUVIN:
11 THE WITNESS: On the advice of my lawyer I 11 Q. Why did you bring minor girls to
12 must invoke my Fifth Amendment right. 12 Jeffrey Epstein for him to have sex with?
13 BY MR. KUVIN: 13 MR. : Same objection as to forty
14 Q. Would you agree with me that 14 and instruct the witness not to answer.
15 Jeffrey Epstein sexual) abused you? 15 THE WITNESS: On the advice of my lawyer,
16 MR. Objection to the form, 16 I must invoke my Fifth Amendment right.
17 both as to the form of the question as to 17 BY MR. KUVIN:
18 harassing and instruct the witness not to 18 Q. What do ou currently do for a job?
19 answer, based on the Fifth Amendment privilege. 19 MR. : Instruct the witness not
20 THE WITNESS: On the advice of my lawyer. 20 to answer the question.
21 I must invoke my Fifth Amendment right. 21 THE WITNESS: On the advice of my lawyer,
22 BY MR. KUVIN: 22 I must invoke my Fifth Amendment right.
23 Q. Would you agree with me that you were a 23 BY MR. KUVIN:
24 minor when Jeffrey Epstein first had sexual 24 I.
25 relations with you?
Page 18 Page 20
1 MR. Object to the form. It 1 MR. Instruct the witness not
2 assumes facts not before the witness. It is a 2 to answer the question.
3 compound question and I would instruct the 3 THE WITNESS: On the advice of my lawyer,
4 witness not to answer based on her Fifth 4 I must invoke my Fifth Amendment right.
S Amendment privilege. 5 BY MR. KUVIN:
6 THE WITNESS: On the advice of my lawyer. 6 ii
7 I must invoke my Fifth Amendment right. I
8 BY MR. KUVIN: 8 MR. Same instruction.
9 Q. Would you agree with me that you have had 9 THE WITNESS: On the advice of my lawyer,
10 sex with Jeffrey E tein? 10 I must invoke my Fifth Amendment right.
11 MR. Same instruction. 11 BY MR. KUVIN:
12 THE WITNESS: On the advice of my lawyer. 12 I.
13 I must invoke my Fifth Amendment right.
14 BY MR. KUVIN: 9
15 Q. Would you agree with me that you first had 15 MR. Instruct the witness not
16 sex with Jeffrey Epstein when you were under the age 16 to answer the question.
17 of 18? 17 THE WITNESS: On the instruction of my
18 MR. Same instruction. 18 lawyer, I must invoke my Fifth Amendment right.
19 THE WITNESS: On the advice of my lawyer. 19 BY MR. KUVIN:
20 I must invoke my Fifth Amendment right. 20 •
21 BY MR. KUVIN:
22 Q. Would you agree with me. ma'am, that you
23 brought numerous underage girls to Jeffrey Epstein 23 MR. Object to the form. It's
24 so that he could have sex with them? 24 compound and assumes facts not present before
25 MR. Object to the form of the 25 the witness, and I instruct the witness not to
S (Pages 17 to 20)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 5 of 47
EFTA_00065322
EFTA01246468
Page 21 Page 23
1 answer the question based on her Fifth 1 witness, and I will instruct the witness not to
2 Amendment privilege. 2 answer based on her Fifth Amendment privilege.
3 THE WITNESS: On the instruction of my 3 THE WITNESS: On the instruction of my
4 lawyer, I must invoke my Fifth Amendment right. 4 lawyer, I must invoke my Fifth Amendment right.
5 BY MR. KUVIN: 5 BY MR. KUVIN:
6 Q. Who introduced you to Jeffrey Epstein the 6 Q. Would you agree with me that
7 first time that ou met him? 7 Jeffrey Epstein owns numerous planes, private
8 MR. Same instruction. 8 planes?
9 THE WITNESS: On the instruction of my 9 MR. Instruct the witness not
10 lawyer, I must invoke my Fifth Amendment right. 10 to answer.
11 BY MR. KUVIN: 11 THE WITNESS: On the instruction of my
12 Q. Did Ghislaine Maxwell introduce you to 12 lawyer, I must invoke my Fifth Amendment right.
13 Jeffrey Epstein for the first time? 13 BY MR. KUVIN:
14 MR. Same instruction. 14 Q. And you've been on every one of those
15 THE WITNESS: On the instruction of my 15 private planes: isn't that true?
16 lawyer, I must invoke my Fifth Amendment right. 16 MR. : Object to the form. It
17 BY MR. KUVIN: 17 assumes facts not before the witness, and I
18 Q. When was the first time you were in 18 will instruct the witness not to answer based
19 Jeffrey Epstein's home located on El Brillo Way on 19 on her Fifth Amendment privilege.
20 Palm Beach Island? 20 THE WITNESS: On the instruction of my
21 MR. Object to the form of the 21 lawyer, I must invoke my Fifth Amendment right.
22 question as compound and assuming facts not 22 BY MR. KUVIN:
23 before the witness. And I instruct the witness 23 Q. Ma'am, isn't it true that you've seen the
24 not to answer based on her Fifth Amendment 24 passenger manifest for Jeffrey Epstein's plane?
25 privilege. 25 MR. Object to the form. It
Page 22 Page 24
1 THE WITNESS: On the instruction of my 1 assumes facts that are not established as known
2 lawyer, I must invoke my Fifth Amendment right. 2 to this witness, and I instruct the witness not
3 BY MR. KUVIN: 3 to answer the question based on her Fifth
4 Q. Would you agree with me that 4 Amendment privilege.
5 Jeffrey Epstein owns a home at 358 El Brillo Way, 5 THE WITNESS: On the instruction of my
6 Palm Beach Island. Florida? 6 lawyer, I must invoke my Fifth Amendment right.
7 MR. : Instruct the witness not 7 MR. KUVIN: Let me show you what we'll
8 to answer based on her Fifth Amendment 8 mark as Exhibit 2.
9 privilege. 9
10 THE WITNESS: On instruction of my 10 (Plaintiff's Exhibit No. 2 was marked for
11 counsel, I must invoke my Fifth Amendment 11 identification.)
12 right. 12 MR. KUVIN: Thank you.
13 BY MR. KUVIN: 13 MR. : Do you want to zoom in on
14 Q. Would you agree with me that you've been 14 it like you did the last time?
15 in that home numerous times? 15 MR. KUVIN: No. that's fine.
16 MR. Instruct the witness not 16 MR. : Take your time.
17 to answer the question based on her Fifth 17 MR. KUVIN: And flip through.
18 Amendment privilege. 18 BY MR. KUVIN:
19 THE WITNESS: On instruction of my lawyer, 19 Q. All right. Ma'am. would you agree with me
20 I must invoke my Fifth Amendment right. 20 that this is a passenger manifest for one of
21 BY MR. KUVIN: 21 Jeffrey Epstein's ai lanes?
22 Q. Would you agree with me that you have gone 22 MR. : Instruct the witness not
23 on Jeffrey E stein's lane numerous times? 23 to answer the question based on her Fifth
24 MR. . Object to the form. It 24 Amendment privilege.
25 assumes fact. that are not present for the 25 THE WITNESS: On the instruction of my
6 (Pages 21 to 24)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 6 of 47
EFTA_00065323
EFTA01246469
Page 25 Page 27
1 lawyer I must exercise my Fifth Amendment 1 Amendment privilege.
2 right. 2 THE WITNESS: On the instruction of my
3 BY MR. KUVIN: 3 lawyer, I must invoke my Fifth Amendment right.
4 Q. And would you agree with me that you 4 BY MR. KUVIN:
5 appear as a passenger on these flight manifests on 5 Q. Would you also agree with me that the two
6 numerous occasions? 6 unknown females listed on the passenger manifest
7 MR. Object to the form. It 7 marked as Exhibit 2 were underage girls, under the
8 assumes facts not established as known to this 8 age of IS?
9 witness, and I instruct the witness not to 9 MR. : Object to the form. It
10 answer the question. 10 calls for speculation. Also it's not been
11 THE WITNESS: On the instruction of my 11 established this witness has any knowledge of
12 lawyer, I must exercise my Fifth Amendment 12 this document and instruct her not to answer
13 right. 13 based on her Fifth Amendment privilege.
14 BY MR. KUVIN: 14 THE WITNESS: On the instruction of my
15 Q. Would you agree with me that your name 15 lawyer, I must invoke my Fifth Amendment right.
16 does, in fact, appear on the passenger manifest for 16 BY MR. KUVIN:
17 these planes for this lane? 17 Q. Would you agree with me that the girls
18 MR. Same objection and same 18 that are listed as females one, and the second
19 instruction. 19 female for this flight of January II, 2005, from
20 THE WITNESS: On the advice of my lawyer, 20 West Palm Beach to the U.S. Virgin Islands, that
21 I must invoke my Fifth Amendment right. 21 those two females were under the age of 17?
22 BY MR. KUVIN: 22 MR. : Same objection. It has
23 Q. Who are the two females that appear on the 23 not been established the witness has any
24 passenger manifest for January II, 2005. on the 24 knowledge of this document. It calls for her
25 first page of Exhibit 2? 25 to speculate, and I instruct her not to answer
Page 26 Page 28
1 MR. I'll object to the form, 1 based on her Fifth Amendment privilege.
2 and it has not been established this witness 2 THE WITNESS: On the instruction of my
3 knows anything about this document, and I will 3 lawyer, I must invoke my Fifth Amendment right.
4 instruct her not to answer based on the Fifth 4 BY MR. KUV1N:
S Amendment privilege. 5 Q. Would you agree with me that the two
6 THE WITNESS: On the instruction of my 6 females shown on the flight with you of January II,
7 lawyer I must invoke my Fifth Amendment right. 7 2005 were under the a e of 16?
8 BY MR. KUVIN: 8 MR. Same objection as to form
9 Q. Do you agree with me that you took a 9 It has not been established this witness knows
10 flight on Jeffrey Epstein's plane from West Palm 10 anything about whether there were these
11 Beach to the U.S. Virgin Islands. St. Thomas on 11 witnesses, these females and who they are, so
12 January II, 2005? 12 it's asking her to speculate. and I instruct
13 MR. Instruct the witness not 13 her not to answer based on her Fifth Amendment
14 to answer the question based on her Fifth 14 privilege.
15 Amendment privilege. 15 THE WITNESS: On the instruction of my
16 THE WITNESS: On the instruction of my 16 lawyer, I must invoke my Fifth Amendment
17 lawyer I must invoke my Fifth Amendment right. 17 privilege.
18 BY MR. KUVIN: 18 BY MR. KUV1N:
19 Q. Would you agree with me that on that 19 Q. Ma'am, you were on that flight of
20 flight were you. Jeffrey Epstein, 20 January 11. 2005. wereyou not?
21 and two unknown females? 21 MR. I instruct the witness not
22 MR. Object to the form. Again 22 to answer based on her Fifth Amendment
23 assumes facts that have not been established 23 privilege.
24 this witness has any knowledge of and instruct 24 THE WITNESS: On the instruction of my
25 the witness not to answer based on her Fifth 25 lawyer I must invoke my Firth Amendment right.
7 (Pages 25 to 28)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 7 of 47
EFTA_00065324
EFTA01246470
Page 29 Page 31
1 BY MR. KUVIN: 1 MR. Same instruction.
2 Q. You also agree with me that the two girls 2 THE WITNESS: On the instruction of my
3 that are listed as on that flight with you of 3 lawyer, I must invoke my Fifth Amendment right.
4 January 11, 2005, were under the age of 15 years 4 BY MR. KUVIN:
5 old? 5 Q. Who is
6 MR. Object to the form. It 6 MR. : Same instruction.
7 calls for speculation, lack of personal 7 THE WITNESS: On the advice of my lawyer,
8 knowledge, and instruct the witness not to 8 I must invoke my Fifth Amendment right.
9 answer based on her Fifth Amendment privilege. 9 BY MR. KUVIN:
10 THE WITNESS: On the instruction of my 10 Q. Who is Mark Zeff.
11 lawyer, I must invoke my Fifth Amendment right. 11 MR. Same instruction.
12 BY MR. KUVIN: 12 THE WITNESS: On the advice of my lawyer,
13 Q. Would you agree with me that the two 13 I must invoke my Fifth Amendment right.
14 females listed as being on that flight with you of 14 BY MR. KUVIN:
15 January I 1 of 2005 were under the age of 14 years 15 Q. Who is David Mullen?
16 old? 16 MR. : Same instruction.
17 MR. Object to the form. It 17 THE WITNESS: On the advice of my lawyer,
18 calls for speculation. The witness has no 18 I must invoke my Fifth Amendment right.
19 personal knowledge and instruct the witness not 19 BY MR. KUVIN:
20 to answer based on her Fifth Amendment 20 Q. Who is Todd Meister?
21 privilege. 21 MR. : Same instruction.
22 THE WITNESS: On the instruction of my 22 THE WITNESS: On the advice of my lawyer,
23 lawyer, I must invoke my Fifth Amendment right. 23 I must invoke my Fifth Amendment right.
24 BY MR. KUVIN: 24 BY MR. KUVIN:
25 Q. Would you agree with me that the two 25 Q. Who is Jean-Luc Brunel?
Page 30 Page 32
1 females listed as being on the flight with you of 1 MR. Same instruction.
2 January II, 2005, from West Palm Beach to the U.S. 2 THE WITNESS: On the advice of my lawyer,
3 Virgin Islands, with Jeffrey Epstein as well, were 3 I must invoke my Fifth Amendment right.
4 under the age of 13 years old and you were aware of 4 BY MR. KUVIN:
S that? 5 Q. Ma'am, would you agree with me that all of
6 MR. Object to the form both as 6 the names I just recently mentioned where you
7 compound. it also assumes facts that it has not 7 invoked your Fifth Amendment, were involved in a
8 been established this witness has any knowledge 8 conspiracy to abuse underaged girls, girls under the
9 of. calls for her to speculate, and I instruct 9 age of 18 for sexual ain and pleasure?
10 her not to answer based on her Fifth Amendment 10 MR. : Object to the form of the
11 privilege. 11 question. It calls for a legal conclusion. It
12 THE WITNESS: On the instruction of my 12 is compound. It calls for her to speculate.
13 lawyer I must invoke my Fifth Amendment right. 13 There is no basis for her to be able to give a
14 BY MR. KUVIN: 14 legal opinion as to what a conspiracy is, and I
15 Q. Who is ? 15 instruct her not to answer based on her Fifth
16 MR. I'm sony. Can you repeat 16 Amendment privilege.
17 the name? 17 THE WITNESS: On the advice of my lawyer.
18 MR. KUVIN: 18 I must invoke my Fifth Amendment right.
19 MR. I'll instruct the witness 19 BY MR. KUVIN:
20 not to answer based on her Fifth Amendment 20 Q. Would you agree with me that all of the
21 privilege. 21 names I just mentioned were individuals that were
22 THE WITNESS: On instruction of my lawyer, 22 working together for their own sexual gain and
23 I must invoke my Fifth Amendment right. 23 pleasure?
24 BY MR. KUVIN: 24 MR. : Object to the form of the
25 Q. Who's Ohislaine Maxwell? 25 question as ambiguous and compound. I instruct
8 (Pages 29 to 32)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 8 of 47
EFTA_00065325
EFTA01246471
Page 33 Page 35
1 her not to answer based on her Fifth Amendment 1 BY MR. KUVIN:
2 privilege. 2 Q. Would you agree with me that Jeffrey
3 THE WITNESS: On the advice of my lawyer I 3 Epstein worked closely with Jean-Luc Brunel in order
4 must invoke my Fifth Amendment privilege. 4 to obtain girls from out of state and bring them to
5 BY MR. KUVIN: 5 Florida for their own sexual pleasure?
6 Q. What is MC S •oared? 6 MR. Object to the form as
7 MR. I instruct the witness not 7 ambiguous. whose own sexual pleasure. and
8 to answer based on her Fifth Amendment 8 instruct the witness not to answer the question
9 privilege. 9 based on her Fifth Amendment privilege.
10 THE WITNESS: On the advice of my lawyer I 10 MR. KUVIN: Perfectly good objection. She
11 must invoke my Fifth Amendment right. 11 doesn't have to answer the question. Let me
12 BY MR. KUVIN: 12 clarify.
13 Q. Would you agree with me that MC Squared is 13 BY MR. KUVIN:
14 a modeling agency that was funded by 14 Q. Would you agree with me, ma'am. that both
15 Jeffrey Epstein? 15 Jean-Luc Brunel and Jeffrey Epstein worked together
16 MR. I instruct the witness not 16 to obtain underage girls from out of state and bring
17 to answer based on her Fifth Amendment 1"/ them to Florida for both of their own sexual
18 privilege. 18 pleasure?
19 THE WITNESS: The advice of my lawyer I 19 MR. I'm going to object as
20 must invoke my Fifth Amendment right. 20 compound and instruct -- I object to the form
21 BY MR. KUVIN: 21 as compound. and instruct the witness not to
22 Q. Would you agree with me that MC Squared 22 answer based on her Fifth Amendment privilege.
23 was wholly funded b Jeffrey Epstein? 23 THE WITNESS: On the instruction of my
24 MR. • Object to the form of the 24 lawyer I must invoke my Fifth Amendment right.
25 question as to what "wholly funded" means, and 25
Page 34 Page 36
1 I would instruct the witness not to answer the 1 BY MR. KUVIN:
2 question based on her Fifth Amendment 2 A. Would you agree with me that
3 privilege. 3 Ghislaine Maxwell. Jean-Luc Brunel- and Jeffrey Epsteit
4 THE WITNESS: On the advice of my lawyer I 4 worked together to obtain underage girls from out of
5 must invoke my Fifth Amendment right. 5 state and bring them into the State of Florida for their
6 BY MR. KUVIN: 6 own sexual .lea ure?
7 Q. Would you agree with me that 7 MR. : Object to the form of the
8 Jeffrey Epstein is the sole individual whose money 8 question as compound and ambiguous. and
9 was used to start the corn • any. MC Squared? 9 instruct the witness not to answer based on her
10 MR. Instruct the witness not 10 Fifth Amendment privilege.
11 to answer the question based on her Fifth 11 THE WITNESS: On the instruction of my
12 Amendment privilege. 12 lawyer. I must invoke my Fifth Amendment right.
13 THE WITNESS: On the advice of my lawyer I 13 (Katherine Ezell and Amy Ederi
14 must invoke my Fifth Amendment right. 14 entered the deposition.)
15 BY MR. KUVIN: 15 MR. GOLDBERGER: That's why we're --
16 Q. Would you agree with me that 16 MR. KUVIN: That's why we lost them.
17 Jean-Luc Brunel worked with Jeffrey Epstein to 17 MR. : Do you want to take a
18 obtain underage girls for both of their sexual 18 one-minute break so we can --
19 pleasure? 19 MR. KUVIN: Yeah, let's take a quick
20 MR. Object to the form of the 20 one-minute break.
21 question as ambiguous and instruct the witness 21 THE VIDEOGRAPHER: We're now off video
22 not to answer based on her Fifth Amendment 22 record. The time is 10:56 a.m.
23 privilege. 23 (A brief recess was held.)
24 THE WITNESS: On the advice of my lawyer I 24 (Plaintiffs Exhibit No. 3 was marked for
25 must invoke my Fifth Amendment right. 25 identification.)
9 (Pages 33 to 36)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 9 of 47
EFTA_00065326
EFTA01246472
Page 37 Page 39
1 THE VIDEOGRAPHER: We're now on video 1 personal knowledge and instruct her not to
2 record at 11:01 a.m. 2 answer based on her Fifth Amendment privilege.
3 MR. KUVIN: Just for the video record and 3 It's also compound.
4 for the written record Katherine Ezell and Amy 4 THE WITNESS: On the instruction of my
5 Eden have now appeared and are present in 5 lawyer I must invoke my Fifth Amendment
6 person. 6 privilege.
7 MR. GOLDBERGER: Just one more matter for 7 BY MR. KUVIN:
8 the record. Jack Goldberger. on behalf of 8 Q. The witness says that you may not have
9 Jeffrey Epstein. Rather than impose a form 9 knowledge or we don't know whether you have
10 objection to every question. I think we have 10 knowledge regarding this passenger manifest, so let
11 reached an agreement that on behalf of 11 me ask you, do you have any knowledge about this
12 Mr. Epstein. I am adopting the form objections 12 passenger manifest?
13 that Mr. is making on behalf of his 13 MR. Object to the form of the
14 client nunc pro tunc to the beginning of this 14 question as ambiguous as to this and what a
15 deposition. 15 manifest is, and also her knowledge, and I will
16 MR. KUVIN: No objection. 16 instruct her not to answer based on her Fifth
17 MR. GOLDBERGER: Okay. 17 Amendment privilege.
18 BY MR. KUVIN: 18 THE WITNESS: On the instruction of my
19 Q. All right. All right. would 19 lawyer, I must invoke my Fifth Amendment
20 you agree with me that there was an agreement 20 privilege.
21 between Jeffrey Epstein, Ghislaine Maxwell. 21 BY MR. KUVIN:
22 Jean-Luc Brunel. yourself and to 22 Q. Based on the objection, do you know what a
23 bring in girls from out of state that were underage? 23 manifest is?
24 MR. : Object to the form of the 24 MR. Object to the form of the
25 question as leading, as compound, and instruct 25 question as ambiguous and instruct her not to
Page 38 Page 40
1 the witness not to answer based on her Fifth 1 answer based on her Fifth Amendment privilege.
2 Amendment privilege. 2 THE WITNESS: On the instruction of my
3 THE WITNESS: On the instruction of my 3 lawyer I must invoke my Fifth Amendment right.
4 lawyer I must invoke my Fifth Amendment right. 4 BY MR. KUVIN:
5 BY MR. KUVIN: 5 Q. Have ou heard the word "manifest" before?
6 Q. Would you agree with me that there was an 6 MR. I'll instruct the witness
7 agreement between Jeffrey Epstein, 7 not to answer based on her Fifth Amendment
8 Ghislaine Maxwell, Jean-Luc Brunel, yourself and 8 privilege.
9 to bring in girls that were 9 THE WITNESS: On the instruction of my
10 underage from out of state for sexual contact? 10 lawyer I must invoke my Fifth Amendment right.
11 MR. : Object to the form of the 11 BY MR. KUVIN:
12 question as leading and compound, and I 12 Q. Would you agree with me, ma'am. that you
13 instruct the witness not to answer based on her 13 have seen this passenger manifest, listed as
14 Fifth Amendment privilege. 14 Exhibit 3, in the 'est?
15 THE WITNESS: On the instruction of my 15 MR. I'll instruct the witness
16 lawyer I must invoke my Fifth Amendment 16 not to answer based on her Fifth Amendment
17 privilege. 17 privilege.
18 BY MR. KUVIN: 18 THE WITNESS: On the instruction of my
19 Q. All right. Let me show you what we've 19 lawyer I must invoke my Fifth Amendment right.
20 premarked as Plaintiffs Exhibit 3. Do you 20 BY MR. KUVIN:
21 recognize this as the passenger manifest for one of 21 Q. Who is
22 Jeffrey Epstein's lanes? 22 MR. I'll instruct the witness
23 MR. : I object to the form of 23 not to answer based on her Fifth Amendment
24 the question. It assumes facts that this 24 privilege.
25 witness. evidence that this witness has no 25 THE WITNESS: On the instruction of my
10 (Pages 37 to 40)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 10 of 47
EFTA_00065327
EFTA01246473
Page 41 Page 43
1 lawyer I must invoke my Fifth Amendment 1 listed in the risen er list to the left?
2 privilege. 2 MR. : Object to the form. the
3 MR. KUVIN: S ellin for the court 3 question is leading and instruct the witness
4 reporter i 4 not to answer based on the Fifth Amendment
5 BY MR. KUVIN: 5 privilege.
6 Q. Who is Eva Andersson, with two S's? 6 THE WITNESS: On the instruction of my
7 MR. • I'll instruct the witness 7 lawyer, I must invoke my Fifth Amendment right.
8 not to answer based on her Fifth Amendment 8 BY MR. KUVIN:
9 privilege. 9 Q. Would you agree with me that you were on a
10 THE WITNESS: On the instruction of my 10 plane with Jeffrey E stein on April 27. 2005?
11 lawyer, I must invoke my Fifth Amendment right. 11 MR. : Same instruction.
12 BY MR. KUVIN: 12 THE WITNESS: On the instruction of my
13 Q. Who is (phonetic)? 13 lawyer, I must invoke my Fifth Amendment right.
14 MR. Same instruction. 14 BY MR. KUVIN:
15 THE WITNESS: On the instruction of my 15 Q. Would you agree with me that on that plane
16 lawyer, I must invoke my Fifth Amendment right. 16 of April 27, 2005. from Teterboro. New Jersey. to
17 BY MR. KUVIN: 17 West Palm Beach. was a female who was under the age
18 Q. Who is (phonetic)? 18 of 16?
19 MR. Same instruction. 19 MR. : Object to the form. It
20 THE WITNESS: On the instruction of my 20 assumes facts not established. Any personal
21 lawyer I must invoke my Fifth Amendment right. 21 knowledge by this witness, and instruct her not
22 BY MR. KUVIN: 22 to answer based on her Fifth Amendment
23 Q. Who is Chris Valdez (phonetic)? 23 privilege. It also calls for speculation.
24 MR. Same instruction. 24 THE WITNESS: On the instruction of my
25 THE WITNESS: On the instruction of my 25 lawyer, I must invoke my Fifth Amendment
Page 42 Page 44
1 lawyer I must invoke my Fifth Amendment right. 1 privilege.
2 BY MR. KUVIN: 2 BY MR. KUVIN:
3 Q. Who is James Stanley? 3 Q. Would you agree with me that on the flight
4 MR. Same instruction. 4 of April 27, 2005. from Teterboro. New Jersey to
5 THE WITNESS: On the instruction of my 5 West Palm Beach was a female on the plane with you
6 lawyer. I must invoke my Fifth Amendment right. 6 that was under the of 15?
7 BY MR. KUVIN: 7 MR. : Object to the form of the
8 Q. Who is S hia Stanley? 8 question. It requires speculation. It assumes
9 MR. Same instruction. 9 facts not established before this witness.
10 THE WITNESS: On the instruction of my 10 I'll instruct her not to answer based on her
11 lawyer I must invoke my Fifth Amendment right. 11 Fifth Amendment privilege. It's also
12 BY MR. KUVIN: 12 ambiguous.
13 Q. Who is Alexis Stanley? 13 THE WITNESS: On the instruction of my
14 MR. Same instruction. 14 lawyer,I must invoke my Fifth Amendment
15 THE WITNESS: On the instruction of my 15 privilege.
16 lawyer. I must invoke my Fifth Amendment right. 16 BY MR. KUVIN:
17 BY MR. KUVIN: 17 Q. Will you turn to May 6. 2005, please. And
18 Q. Ma'am, if you would, in Exhibit 3, would 18 this is, for the record, in Exhibit 3. On May 6th.
19 you turn to the date of April 27.2005. for me? 19 2005, ma'am. will you agree with me that you took a
20 It's about halfway through the packet. April 27, 20 flight from Teterboro. New Terse West Palm
21 '05. Are you there? 21 Beach. with Jeffre E. tein
22 A. Uh-huh. 22 David Mullen. Larry
23 Q. Okay. On this particular date, will you 23 Morrison and another female?
24 agree with me that you flew from Teterboro. 24 MR. : Object to the form of the
25 New Jersey to %Vest Palm Beach on a plane with people 25 question as compound. calling for speculation.
11 (Pages 41 to 44)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 11 of 47
EFTA_00065328
EFTA01246474
Page 45 Page 47
I instruct the witness not to answer based on 1 BY MR. KUVIN:
2 her Fifth Amendment privilege. 2 Q. Do you also agree with me on that flight
3 THE WITNESS: On the instruction of my 3 of June 20th, 2005. was an unidentified female,
4 lawyer, I must invoke my Fifth Amendment 4 according to thepassenger manifest?
5 privilege. 5 MR. Object to the form --
6 BY MR. KUVIN: 6 excuse me -- as leading, and instruct the
7 Q. Would you agree with me, ma'am, that on 7 witness not to answer based on her Fifth
8 the flight of May 6th, 2005. that's shown in 8 Amendment privilege.
9 Exhibit 3, that the female identified in the 9 THE WITNESS: On the instruction of my
10 passenger manifest was under the age of 16? 10 lawyer, I must choose to invoke my Fifth
11 MR. : Object to the form. It 11 Amendment privilege.
12 assumes facts not established that this witness 12 BY MR. KUVIN:
13 has any personal knowledge. It calls for her 13 Q. Would you agree with me that that female
14 to speculate, and I'll instruct her not to 14 listed on the flight of June 20. 2005, was under the
15 answer based on her Fifth Amendment privilege. 15 age of 16 years old?
16 THE WITNESS: On the instruction of my 16 MR. Objection to the form as
17 lawyer, I must invoke my Fifth Amendment 17 leading and also requiring speculation. I'll
18 privilege. 18 instruct the witness not to answer based on her
19 BY MR. KUVIN: 19 Fifth Amendment privilege.
20 Q. Would you agree with me that the female 20 THE WITNESS: On the instruction of my
21 identified in the passenger manifest of May 6th, 21 lawyer, I must choose to invoke my Fifth
22 2005, was under the a e of 15? 22 Amendment privilege.
23 MR. : Same objection as the 23 BY MR. KUVIN:
24 previous question, same instruction. 24 Q. Would you agree with me that the
25 THE WITNESS: On the instruction of my 25 unidentified female on the passenger manifest of
Page 46 Page 48
1 lawyer I must invoke my Fifth Amendment 1 June 20, 2005. was under the age of 14?
2 privilege. 2 MR. Objection, calls for
3 BY MR. KUVIN: 3 speculation, instruct the witness not to answer
4 Q. Would you agree with me that the female 4 based on her Fifth Amendment privilege.
5 listed in the passenger manifest of May 6th, 2005, 5 THE WITNESS: On the instruction of my
6 was under the a e. was under the age of 14? 6 lawyer, I must invoke my Fifth Amendment
7 MR. Same instruction as to the 7 privilege.
8 previous two questions and the same objection 8 BY MR. KUVIN:
9 as to those two questions. 9 Q. Turn to the date of June 30, if you would,
10 THE WITNESS: On the instruction of my 10 2005. Would you agree with me that you took a
11 lawyer I must invoke my Fifth Amendment 11 flight from Teterboro. New Jersey, to West Palm
12 privilege. 12 Beach on June 30. 2005. with Jeffrey Epstein?
13 BY MR. KUVIN: 13 MR. Object to the form as
14 Q. If you would turn to the date of June 20 14 leading and compound, instruct the witness not
15 of 2005 for me, please. On the date of June 20, 15 to answer based on her Fifth Amendment
16 2005, would you agree with me that you took a flight 16 privilege.
17 with Jeffrey Epstein from West Palm Beach to 17 THE WITNESS: On the instruction of my
18 Teterboro, New Jerse ? 18 lawyer I must, I must invoke my Fifth Amendment
19 MR. Object to the form as 19 right
20 leading. I'll instruct the witness not to 20 BY MR. KUVIN:
21 answer based on her Fifth Amendment privilege. 21 Q. Would you agree with me that
22 THE WITNESS: On the instruction of my 22 was on that fli t?
23 lawyer, I must invoke my Fifth Amendment 23 MR. Same instruction.
24 privilege. 24 THE WITNESS: On the instruction of my
25 25 lawyer I must invoke my Firth Amendment
12 (Pages 45 to 48)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 12 of 47
EFTA_00065329
EFTA01246475
Page 49 Page 51
1 privilege. 1 THE WITNESS: On the instruction of my
2 BY MR. KUVIN: 2 lawyer I must invoke my Fifth Amendment
3 Q. Would you agree with me that there was 3 privilege.
4 also another female on that flight with you? 4 BY MR. KUVIN:
5 MR. Same instruction. 5 Q. Would you agree with me that on both of
6 THE WITNESS: On the instruction of my 6 those flights were girls that were under the age of
7 lawyer, I must invoke my Fifth Amendment 7 16?
8 privilege. 8 MR. : Same form objection as tc
9 BY MR. KUVIN: 9 compound, also ambiguous and requiring
10 Q. Would you agree with me that you had 10 speculation and instruct the witness not to
11 personal knowledge that that female on that 11 answer based on her Fifth Amendment privilege.
12 flight with you of June 30, 2005, was under the age 12 THE WITNESS: The instruction of my lawyer
13 of 16? 13 I must invoke my Fifth Amendment privilege.
14 MR. Object to the form as 14 BY MR. KUVIN:
15 compound and calling for speculation, and 15 Q. Would you agree with me, ma'am. that you
16 instruct the witness not to answer based on her 16 have flown on Jeffrey Epstein's plane from
17 Fifth Amendment privilege. 17 Teterboro. New Jersey. to West Palm Beach. on
18 THE WITNESS: On the instruction of my 18 numerous occasions where there were girls on the
19 lawyer, I must invoke my Fifth Amendment 19 plane under the a e of 16?
20 privilege. 20 MR. : Object to the form as
21 BY MR. KUVIN: 21 compound and ambiguous as to what numerous
22 Q. Would you agree with me that you had 22 means. Instruct the witness not to answer
23 personal knowledge that that young female on the 23 based on her Fifth Amendment privilege.
24 flight of June 30, 2005. was under the age of 15? 24 THE WITNESS: On the instruction of my
25 MR. Same instruction, calls 25 lawyer I must invoke my Fifth Amendment
Page 50 Page 52
1 for speculation. 1 privilege.
2 THE WITNESS: On the instruction of my 2 BY MR. KUVIN:
3 lawyer, I must invoke my Fifth Amendment 3 Q. Would you agree with me that you have
4 privilege. 4 flown on Jeffrey Epstein's plane from Teterboro. New
5 BY MR. KUVIN: 5 Jersey. to West Palm Beach on at least 100 occasions
6 Q. Would you agree with me that you had 6 where there were girls on the plane with you under
7 personal knowledge that that young female on the 7 the age of 16?
8 flight of June 30. 2005. with you was under the age 8 MR. Object to the form as
9 of 14? 9 compound, requiring speculation and ambiguous,
10 MR. : Objection to form as to 10 and instruct her not to answer based on her
11 compound and requiring speculation. I'll 11 Fifth Amendment privilege.
12 instruct the witness not to answer based on her 12 THE WITNESS: On the instruction of my
13 Fifth Amendment privilege. 13 lawyer I must invoke my Fifth Amendment
14 THE WITNESS: On the instruction of my 14 privilege.
15 lawyer I must invoke my Fifth Amendment 15 BY MR. KUVIN:
16 privilege. 16 Q. Would you agree with me. ma'am. that you
17 BY MR. KUVIN: 17 have flown on Jeffrey Epstein's plane at least 100
18 Q. Ma'am, just so we can be quicker about 18 times from Teterboro, New Jersey to West Palm Beach
19 this, there are flights of July 5th, July IS. It 19 Florida. where there were girls under the age of IS
20 looks like those are the last two. Would you agree 20 on the plane with ou?
21 with me that on July 5th and July 15, you took 21 MR. Same objections as the
22 flights on Jeffrey E rein's plane? 22 previous question, same instruction.
23 MR. : Object to the form as 23 THE WITNESS: On the instruction of my
24 compound and instruct the witness not to answer 24 lawyer, I must invoke my Fifth Amendment
25 based on Filth Amendment privilege. 25 privilege.
13 (Pages 49 to 52)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 13 of 47
EFTA_00065330
EFTA01246476
Page 53 Page 55
1 BY MR. KUVIN: 1 occasions where Jeffrey Epstein was flying with
2 Q. Would you agree with me that you have 2 girls under the age of 16 from Teterboro. New
3 flown on Jeffrey Epstein's plane from Teterboro. New 3 Jersey. to Florida, West Palm Beach, Florida, with
4 Jersey to West Palm Beach on at least 100 occasions 4 girls under the age of 16, was doing so, so that he
5 where there were girls on the plane with you that 5 could have sexual contact with them?
6 were under the a e of 14? 6 MR. : Object to the form. It's
7 MR. : Objection to the form. 7 compound and requires her to assume facts that
8 It's compound and ambiguous. calls for 8 have not been established, and it's ambiguous,
9 speculation and instruct her not to answer 9 and instruct her not to answer based on the
10 based on her Fifth Amendment privilege. 10 Fifth Amendment privilege.
11 THE WITNESS: On the instruction of my 11 THE WITNESS: On the instruction of my
12 lawyer, I must invoke my Fifth Amendment 12 lawyer, I must assert my Fifth Amendment right.
13 privilege. 13 BY MR. KUVIN:
14 BY MR. KUVIN: 14 Q. Do you agree with me that on the flights
15 Q. Would you agree with me that you have been 15 from West Palm Beach to Paris, where you were
16 on the plane, one of Jeffrey Epstein's -- strike 16 present on the plane with Jeffrey Epstein, that
17 that. 17 there were girls under the age of 16 that
18 Would you agree with me that you have 18 Jeffrey Epstein was having sexual contact with on
19 been on Jeffrey Epstein's plane with him to Paris 19 that plane?
20 where there have been girls on the plane with you 20 MR. : Same objections as
21 under the a e of 16? 21 previously stated. It's compound, ambiguous.
22 MR. Objection to the form as 22 and assumes facts that she has no knowledge, or
23 compound. assuming facts not established the 23 it has not been established that she has any
24 witness has any knowledge, and instruct the 24 knowledge of, and instruct her not to answer
25 witness not to answer based on her Fifth 25 based on the Fifth Amendment, and it's leading.
Page 54 Page 56
1 Amendment privilege. It's also leading. 1 THE WITNESS: On the instruction of my
2 THE WITNESS: On the instruction of my 2 lawyer I must invoke my Fifth Amendment right.
3 lawyer. I must invoke my Fifth Amendment 3 BY MR. KUVIN:
4 privilege. 4 Q. Ma'am, you've been on the plane, you've
5 BY MR. KUVIN: 5 been on a plane with Jeffrey Epstein in the past,
6 Q. Would you agree with me that you have been 6 have you not?
7 on the plane with Jeffrey Epstein on flights to 7 MR. Objection to the form as
8 Paris where there have been girls on the plane with 8 leading, and instruct her not to answer based
9 you under the a e of 15? 9 on the Fifth Amendment privilege.
10 MR. : Same objection and same 10 THE WITNESS: On the instruction of my
11 instruction as the previous question. 11 lawyer, I must invoke my Fifth Amendment
12 THE WITNESS: On the instruction of my 12 privilege.
13 lawyer, I must invoke my Fifth Amendment 13 BY MR. KUVIN:
14 privilege. 14 Q. Have you been on a plane with
15 BY MR. KUVIN: 15 Jeffrey Epstein ever in our entire life?
16 Q. Would you agree with me that you have been 16 MR. Instruct the witness not
17 on those same flights we have been discussing where 17 to answer based on her Fifth Amendment right.
18 there have been:iris under the age of 14? 18 THE WITNESS: On the instruction of my
19 MR. : Same instruction and same 19 lawyer I must invoke my Fifth Amendment
20 objection as the previous two questions. 20 privilege.
21 THE WITNESS: On the instruction of my 21 BY MR. KUVIN:
22 lawyer, I must invoke my Fifth Amendment 22 Q. Have you ever been on a plane with
23 privilege. 23 Jeffrey Epstein where there was a girl on the plane
24 BY MR. KUVIN: 24 with you under the a e of 14?
25 Q. Would you agree with me that on the 25 MR. Same instruction.
14 (Pages 53 to 5 6)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 14 of 47
EFTA_00065331
EFTA01246477
Page 57 Page 59
1 THE WITNESS: On the instruction of my 1 MR. Same objection as stated
2 lawyer, I must invoke my Fifth Amendment 2 to the previous question; it's ambiguous and
3 privilege. 3 instruct her not to answer based on the Fifth
4 BY MR. KUVIN: 4 Amendment.
5 Q. Ma'am, isn't it true that you've seen 5 THE WITNESS: On the instruction of my
6 Jeffrey Epstein have sex with girls under the age of 6 lawyer, I must invoke my Fifth Amendment right.
7 14 on his plane? 7 MR. KUVIN: Just to clarify, is the
8 MR. : Objection to the form. It 8 ambigui the word "sex"?
9 assumes facts that it's not been established 9 MR. : Sex and also assumes that
10 that she would have any knowledge of. and I'll 10 she's ever met Jeffrey Epstein in her life.
11 instruct her not to answer based on her Fifth 11 MR. KUVIN: Any other words in there I
12 Amendment right. 12 need to clan ?
13 THE WITNESS: On the instruction of my 13 MR. : No.
14 lawyer, I must invoke my Fifth Amendment 14 BY MR. KUVIN:
15 privilege. 15 Q. Okay. Ma'am, do you -- what's your
16 BY MR. KUVIN: 16 definition of the word "sex"?
17 Q. Would you agree with me that you've seen 17 MR. : Object to the form of the
18 Jeffrey Epstein have sex with girls on his plane in 18 question and instruct the witness not to answer
19 your presence Burin fli hts to Paris? 19 based on her Fifth Amendment privilege.
20 MR. : Same objection previously 20 THE WITNESS: On the instruction of my
21 stated, and it assumes facts that have not been 21 lawyer, I must invoke my Fifth Amendment right.
22 established and instruct her not to answer 22 BY MR. KUVIN:
23 based on her Fifth Amendment right. 23 Q. Would you agree with me that the word
24 THE WITNESS: On the instruction of my 24 "sex" means both vaginal intercourse as well as oral
25 lawyer, I must invoke my Fifth Amendment 25 sex? Would you agree with that definition?
Page 58 Page 60
1 privilege. 1 MR. You can answer that.
2 BY MR. KUVIN: 2 THE WITNESS: No.
3 Q. Ma'am, isn't it true that you've seen 3 BY MR. KUVIN:
4 Jeffrey Epstein and Jean-Luc Brunel have sex with 4 Q. Okay. Would you agree with me that sex,
5 girls under the age of 14 on Mr. Epstein's plane on 5 for the purpose of our questions here today, will be
6 flights to Paris? 6 limited strictly to vaginal intercourse?
7 MR. Objection to the form. 7 A. Sorry. Can you repeat that?
8 It's compound. as to several answers all at the 8 Q. Yes. For the purpose of my questions here
9 same time and certain facts, and instruct her 9 today, will you agree that the word "sex" will be
10 not to answer based on her Fifth Amendment. 10 limited to vaginal intercourse between a man's penis
11 THE WITNESS: On the instruction of my 11 and a woman's va ma?
12 lawyer, I must invoke my Fifth Amendment 12 MR. If you're instructing her
13 privilege. 13 that in the future she should assume that
14 BY MR. KUVIN: 14 that's what you mean by your question, that's
15 Q. Ma'am, isn't it true that you have had sex 15 fine.
16 with Jeffrey E stein on his plane? 16 MR. KUVIN: Oka .
17 MR. : Instruct the witness not 17 MR. If that's what you mean,
18 to answer based on the Fifth Amendment 18 then that's understood.
19 privilege, also object to the form of the 19 MR. KUVIN: That's what I mean.
20 question as compound and ambiguous. 20 MR. Okay.
21 THE WITNESS: On the instruction of my 21 MR. KUVIN: All right. Let's go with that
22 lawyer, I must invoke my Fifth Amendment right. 22 definition. And for the purposes of my
23 BY MR. KUVIN: 23 questions, "oral sex" will mean contact between
24 Q. Isn't it true that you've had sex with 24 an individual's mouth and a man's sexual organ,
25 Jeffrey Epstein on hi, plane on flights to Paris? 25 penis. Fair enough?
15 (Pages 57 to 60)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 15 of 47
EFTA_00065332
EFTA01246478
Page 61 Page 63
1 MR. : Understood. 1 Mr. Epstein's residence, as to her knowledge of
2 MR. KUVIN: Okay. 2 Mr. Epstein and other facts as to which she's
3 BY MR. KUVIN: 3 invoking her Fifth Amendment privilege.
4 Q. Working with those definitions if we 4 THE WITNESS: On the instruction of my
5 could, would you agree with me that you had sex with 5 lawyer, I must to invoke my Fifth Amendment
6 Jeffrey Epstein on his 'lane? 6 privilege.
7 MR. : Objection to the form. 7 MR. KUVIN: Let me show you what we'll
8 It's compound and instruct her not to answer 8 mark as Exhibit 6. And this one I'm going to
9 based on the Fifth Amendment privilege, because 9 show it to the camera real briefly, if I could.
10 to do so would implicitly admit that she's ever 10 Okay.
11 met Jeffrey Epstein in her life, and so as to 11 MR. : Let me see it. Thank you
12 that she's invoking the Fifth Amendment 12 (Plaintiffs Exhibit No. 6 was marked for
13 privilege. 13 identification.)
14 THE WITNESS: On the instruction of my 14 BY MR. KUVIN:
15 lawyer, I must invoke my Fifth Amendment 15 Q. Ma'am, do you recognize any of the girls
16 privilege. 16 shown in Exhibit 6?
17 BY MR. KUVIN: 17 MR. : I'll instruct the witness
18 Q. Would you agree with me that you have had 18 not to answer based on her Fifth Amendment
19 oral sex with Jeffrey Epstein on his plane? 19 privilege.
20 MR. : Same objection stated to 20 THE WITNESS: On the instruction of my
21 the previous question. It's compound and it 21 lawyer, I must invoke my Fifth Amendment right.
22 assumes facts that's not been established as to 22 BY MR. KUVIN:
23 which she is invoking her Fifth Amendment 23 Q. Would you agree with me that that is you
24 privilege. 24 on the right in this hoto raph, the far right?
25 THE WITNESS: On the instruction of my 25 MR. : I'll instruct the witness
Page 62 Page 64
lawyer, I must invoke my Fifth Amendment 1 not to answer.
2 privilege. 2 THE WITNESS: On the instruction of my
3 BY MR. KUVIN: 3 lawyer, I must invoke my Fifth Amendment
4 Q. Would you agree with me that you have had 4 privilege.
5 sex with Jeffre tein in his home -- 5 BY MR. KUVIN:
6 MR. : Object to the -- 6 • Would ou agree with me that that is
7 MR. KUVIN: -- here in West Palm, in West 7 on the left in that photograph that
8 Palm Beach? 8 we marked as Exhibit 6?
9 MR. : I'll instruct the witness 9 MR. Same instruction.
10 not to answer based on her Fifth Amendment 10 THE WITNESS: On the instruction of my
11 privilege and same objection previously stated 11 lawyer, I must invoke my Fifth Amendment
12 to the last two questions. 12 privilege.
13 THE WITNESS: On the instruction of my 13 BY MR. KUVIN:
14 lawyer, I must invoke my Fifth Amendment 14 Q. How old areyou in this photograph?
15 privilege. 15 MR. Same instruction.
16 BY MR. KUVIN: 16 THE WITNESS: On the instruction of my
17 Q. Would you agree with me that you have had 17 lawyer, I must invoke my Fifth Amendment
18 oral sex with Jeffrey Epstein in his home in West 18 privilege.
19 Palm Beach? 19 BY MR. KUVIN:
20 MR. GARCIA: Is it West, or Palm Beach? 20 Q. How old is in this
21 MR. KUVIN: Palm Beach Island. I think 21 photograph, if ou know?
22 it's, because -- yeah, for clarity, his home on 22 MR. I'm going to object to the
23 Palm Beach. 23 form in that it assumes facts as to her
24 MR. : Object to the form. It 24 knowledge of anything about Ms. and
25 assumes facts as to her knowledge of 25 as to which she is in‘okino, her Fifth Amendment
16 (Pages 61 to 64)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 16 of 47
EFTA_00065333
EFTA01246479
Page 65 Page 67
1 privilege. 1 THE WITNESS: On the instruction of my
2 THE WITNESS: On the instruction of my 2 lawyer, I must invoke my Fifth Amendment
3 lawyer. I must invoke my Fifth Amendment 3 privilege.
4 privilege. 4 BY MR. KUVIN:
5 MR. KUVIN: This is Exhibit 7. Let me 5 Q. Would you agree with me that
6 show you what well mark as Exhibit 7. 6 has been to Mr. Epstein's home on hundreds of
7 (Plaintiff's Exhibit No. 7 was marked for 7 occasions?
8 identification.) 8 MR. Object to the form as
9 BY MR. KUVIN: 9 compound and also assumes knowledge as this
10 Q. Do you recognize the girl that's shown in 10 witness has and instruct her to invoke her
11 Exhibit 7? 11 Fifth Amendment privilege relating to
12 MR. I need to consult with her 12 Ms.
13 one second. 13 THE WITNESS: On the instruction of my
14 MR. KUVIN: Sure. 14 lawyer, I must invoke my Fifth Amendment
15 THE VIDEOGRAPHER: Are we off the record? 15 privilege.
16
17
18
MR. KUVIN: No. no.
MR. Instruct the witness to
invoke her Fifth Amendment privilege as to
16
17
18
.
BY MR. KUVIN:
Would you agree with me that you directed
on hundreds of occasions to bring girls
19 Exhibit 7. 19 under the a e of 16 to Mr. Epstein's house?
20 MR. KUVIN: She's clipped up. Okay. 20 MR. Object to the form of the
21 MR. Now you have to answer. 21 question as compound and ambiguous and assuming
22 THE WITNESS: On the advice of my lawyer, 22 facts as to which there is no factual basis
23 I must invoke my Fifth Amendment privilege. 23 that this witness has any knowledge and
24 BY MR. KUVIN: 24 instruct the witness not to answer based on her
25 Q. Would you agree with me that the girl 25 Fifth Amendment privilege.
Page 66 Page 68
1 shown in Exhibit 7 is 1 THE WITNESS: On the instruction of my
2 MR. Instruct the witness not 2 lawyer, I must choose to invoke my Fifth
3 to answer based on the Fifth Amendment 3 Amendment right.
4 privilege. 4 BY MR. KUVIN:
5 THE WITNESS: On the instruction of my 5 Q. Would you agree with me that on hundreds
6 lawyer, I must invoke my Fifth Amendment 6 of occasions you directed to bring
7 privilege. 7 underage girls under the age of 16 to Mr. Epstein's
8 BY MR. KUVIN: 8 home for sex with Mr. E tein?
9 Q. Do you agree with me that was 9 MR. : Object to the form. It's
10 under the age of 16 when she was first asked to go 10 compound and it assumes facts as to this --
11 to Mr. Epstein's home? 11 that this witness has no personal knowledge.
12 MR. Objection to the form. It 12 and it's been established by this record, and
13 assumes any knowledgelas witness as to the 13 instruct her to invoke her Fifth Amendment
14 person you identified as It's 14 privilege.
15 compound and I would instruct her not to answer 15 THE WITNESS: On the instruction of my
16 based on her Fifth Amendment privilege. 16 lawyer, I must invoke my Fifth Amendment
17 THE WITNESS: On the instruction of my 17 privilege.
18 lawyer, I must invoke my Fifth Amendment 18 MR. KUVIN: We'll mark this as Exhibit 8.
19 privilege. 19 (Plaintiff's Exhibit No. 8 was marked for
20 BY MR. KUVIN: 20 identification.)
21 Q. Would ou agree with me that you know 21 BY MR. KUVIN:
22 personally 22 Q. Ma'am. do you recognize the person that's
23 MR. Instruct the witness not 23 shown in Exhibit 8?
24 to answer based on the Fifth Amendment 24 MR. : Let me consult one second.
25 privilege. 25 MR. KUVIN: Sure.
17 (Pages 65 to 68)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 17 of 47
EFTA_00065334
EFTA01246480
Page 69 Page 71
1 MR. : I instruct the witness not 1 MR. GARCIA: He didn't make a Fifth
2 to answer the question based on her Fifth 2 Amendment objection. So can we just rephrase
3 Amendment privilege. 3 the question?
4 THE WITNESS: Based on the instruction of 4 MR. : I would instruct the
5 my lawyer, I must invoke my Fifth Amendment 5 witness not to answer based on the Fifth
6 right. 6 Amendment privilege to clarify.
7 BY MR. KUVIN: 7 MR. KUVIN: Okay. Let's mark this as
8 Q. Would you agree with me that the person 8 Exhibit 9.
9 shown on Exhibit 8 is ou? 9 MR. : And for the record. the
10 MR. : Same instruction. 10 basis is that it assumes her knowledge of
11 THE WITNESS: On the instruction of my 11 anything relating to Jeffrey Epstein, the
12 lawyer, I must invoke my Fifth Amendment 12 question assumed that.
13 privilege. 13 (Plaintiffs Exhibit No. 9 was marked for
14 BY MR. KUVIN: 14 identification.)
15 Q. Would you agree with me that this is a 15 BY MR. KUVIN:
16 modeling shot of you that was taken through one of 16 Q. Ma'am, do you recognize the girl shown in
17 Mr. Epstein's modelin a encies? 17 Exhibit 9?
18 MR. : Object to the form of the 18 MR. : I'll instruct the witness
19 question as compound and assuming facts as to 19 not to answer based on her Fifth Amendment
20 which there has been no basis that this witness 20 privilege.
21 has any personal knowledge, and she's going 21 THE WITNESS: On the instruction of my
22 invoke her Fifth Amendment privilege. 22 lawyer, I must invoke my Fifth Amendment right.
23 THE WITNESS: On the instruction of my 23 BY MR. KUVIN:
24 lawyer, I must invoke my Fifth Amendment 24 Q. Would you agree with me that the girl
25 privilege. 25 shown in Exhibit 9 is ?
Page 70 Page 72
1 BY MR. KUVIN: 1 MR. Same instruction.
2 Q. Would you agree with me that you were 2 THE WITNESS: On the instruction of my
3 under the age of 18 in this photograph we've marked 3 lawyer, I must invoke my Fifth Amendment
4 as Exhibit 8? 4 privilege.
5 MR. : Same objection as to the 5 MR. KUVIN: I forgot to do one more thing.
6 previous question and same instruction. 6 If you could give that back to me for just one
7 THE WITNESS: On the instruction of my 7 second just for the record so we can see what
8 lawyer, I must invoke my Fifth Amendment right. 8 we're talking about here.
9 BY MR. KUVIN: 9 Okay. I will give you back Exhibit
10 Q. Would you agree with me that you were 10 9.
11 under the age of 17 in this photograph that we've 11 MR. Thank you.
12 marked as Exhibit 8? 12 BY MR. KUVIN:
13 MR. : Same objection as the 13 Q. Wouldyou agree with me that this
14 previous two question and the same instruction. 14 photograph of was taken when she
15 THE WITNESS: On the instruction of my 15 was under the a e of 18?
16 lawyer, I must invoke my Fifth Amendment right. 16 MR. Objection to the form. It
17 BY MR. KUVIN: 17 assumes this witness has any knowleifihat the
18 Q. Would you agree with me that Jeffrey 18 n in the photograph is, in fact.
19 Epstein kept this photograph of you in his home, if 19 Therefore,it's ambiguous and
20 you know. 20 compound. and I'll instruct her not to answer
21 MR. : Object to the form of the 21 based on her Fifth Amendment privilege.
22 question as compound and ambiguous, and I would 22 THE WITNESS: On the instruction of my
23 instruct the witness not to answer. 23 lawyer, I must invoke my Fifth Amendment right.
24 THE WITNESS: On the instruction of my 24 BY MR. KUVIN:
25 lawyer, I must invoke my Fifth Amendment right. 25 Q. Would you agree with me that the gill
18 (Pages 69 to 72)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 18 of 47
EFTA_00065335
EFTA01246481
Page 73 Page 75
1 shown in that photograph -- strike that. 1 implicitly assumes that she does. I would
2 Would you agree with me that this 2 instruct her not to answer it based on her
3 photograph was ke t b Jeffrey Epstein in his home? 3 Fifth Amendment privilege.
4 MR. Objection to the form as 4 THE WITNESS: Upon the instruction of my
5 to being compound in that it assumes that she 5 lawyer, I must invoke my Fifth Amendment
6 has any knowledge of Jeffrey Epstein or his 6 privilege.
7 home, and I would instruct her not to answer 7 BY MR. KUVIN:
8 based on her Fifth Amendment. 8 Q. Ma'am. are you aware of the effect, the
9 THE WITNESS: On the instruction of my 9 emotional effect on the underage girls that have
10 lawyer, I must invoke my Fifth Amendment right. 10 been abused by Jeffrey Epstein? Are you aware of
11 BY MR. KUVIN: 11 the emotional effect that it's had on the underage
12 • Would you agree with me that 12 girls that have been abused by Jeffrey Epstein?
13 was under the age of 16 when this 13 MR. Objection to the form as
14 photograph was taken in Exhibit 9? 14 to. again, the question assumes this wimess
15 MR. : Objection to the form as 15 has any knowledge, first, of Jeffrey Epstein,
16 compound and also assuming this witness has any 16 second that Jeffrey Epstein has sexually abused
17 knowledge that the rson in the photograph is, 17 anyone ever, and third, that anyone has been
18 in fact, Therefore. I would 18 damaged by anything that Jeffrey Epstein has
19 instruct her to invoke her Fifth Amendment 19 done, and fourth, that she would somehow have
20 privilege. 20 any knowledge of these people's emotional
21 THE WITNESS: On the instruction of my 21 situations. For all those reasons, the
22 lawyer, I must invoke my Fifth Amendment right. 22 question is ambiguous and compound. and I would
23 BY MR. KUVIN: 23 instruct her not to answer based on her Fifth
24 Q. Ma'am, is Jeffrey Epstein paying for your 24 Amendment.
25 attorney today? 25 THE WITNESS: Upon the instruction of my
Page 74 Page 76
1 MR. I'll instruct the witness 1 lawyer, I must invoke my Fifth Amendment right.
2 not to answer based on her Fifth Amendment 2 BY MR. KUVIN:
3 privilege. 3 Q. Ma'am, do you have any regret for what
4 THE WITNESS: On the instruction of my 4 you've done?
5 lawyer, I must invoke my Fifth Amendment right. 5 MR. : Objection to the form.
6 BY MR. KUVIN: 6 That question is not designed to lead to
7 Q. Ma'am, is Jeffrey Epstein paying for you 7 discoverable evidence. It's meant solely for
8 to keep quiet with respect to the things he has done 8 the purpose of harassment, and I would instruct
9 to underage iris? 9 her not to answer.
10 MR. Objection to the form in 10 BY MR. KUVIN:
11 that it's ambiguous and compound, also assumes 11 Q. Ma'am, do you have any regrets for what
12 this witness has any knowledge at all of 12 Jeffrey Epstein has done through you in obtaining
13 Jeffrey Epstein, and therefore I am instructing 13 underage girls for sexual abuse?
14 her to invoke her Fifth Amendment privilege. 14 MR. : Same objection as the
15 THE WITNESS: On the instruction of my 15 previous question as well as that question is
16 lawyer, I must invoke my Fifth Amendment 16 now free to assume this witness has any
17 privilege. 17 knowledge at all of Jeffrey Epstein or
18 BY MR. KUVIN: 18 Jeffrey Epstein having abused any underage
19 Q. Ma'am, how much is Jeffrey Epstein paying 19 women or girls or anything else that
20 you to keep quiet with respect to things he's done 20 Jeffrey Epstein may ever have done.
21 to underage irls? 21 And therefore, since it assumes that
22 MR. Object to the form as 22 fact, I would instruct her not to answer
23 multiple compound questions, and it's again 23 based on her Fifth Amendment.
24 assuming this witness has any knowledge at all 24 BY MR. KUVIN:
25 of Jeffrey Epstein. Since the question 25 Q. Are you scared of Jeffrey Epstein?
19 (Pages 73 to 7 6)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 19 of 47
EFTA_00065336
EFTA01246482
Page 77 Page 79
1 MR. KUV1N: I'm sorry, you had to respond. 1 lawyer, and I must invoke my Fifth Amendment
2 I cut you off. 2 privilege.
3 THE WITNESS: Upon the instruction of my 3 BY MR. KUVIN:
4 lawyer, I must invoke my Fifth Amendment right. 4 Q. Do ou know who Les Wexner is?
5 BY MR. KUVIN: 5 MR. I'll instruct the witness
6 Q. Are ou scared of Jeffrey Epstein? 6 not to answer based on her Fifth Amendment
7 MR. Objection to the form in 7 privilege.
8 that it assumes this witness has ever met 8 THE WITNESS: On the instruction of my
9 Jeffrey Epstein in her life. Because it 9 lawyer, I must invoke my Fifth Amendment
10 assumes that, I would instruct her not to 10 privilege.
11 answer based on the Fifth Amendment. 11 BY MR. KUV1N:
12 THE WITNESS: On the instruction of my 12 Q. Do you know whether or not Mr. Epstein has
13 lawyer, I must invoke my Fifth Amendment right. 13 had a homosexual relationship with Les Wexner in the
14 BY MR. KUV1N: 14 past?
15 Q. Are you aware of Jeffrey Epstein's sexual 15 MR. Objection to the form in
16 obsession for children? 16 that it again assumes that this witness knows
17 MR. Same instructions as the 17 anything at all about Jeffrey Epstein or has
18 previous question. also objection to the 18 ever met Jeffrey Epstein in her life, and
19 question. It's not designed to lead to any 19 therefore. I would instruct her not to answer
20 discoverable evidence at all. It's simply 20 based on her Fifth Amendment privilege, and the
21 meant for harassment. 21 question is compound and ambiguous.
22 THE WITNESS: On the instruction of my 22 THE WITNESS: On the instruction of my
23 lawyer, I must invoke my Fifth Amendment 23 lawyer, I must invoke my Fifth Amendment
24 privilege. 24 privilege.
25 25
Page 78 Page 80
1 BY MR. KUVIN: 1 BY MR. KUVIN:
2 Q. At what point did you realize that 2 Q. Do you know the magician by the name
3 Jeffrey Epstein was sexually attracted to girls 3 David Cop. erfield?
4 under the a e of 18? 4 MR. : I'll instruct the witness
5 MR. Once again, the question 5 not to answer based on her Fifth Amendment
6 assumes this witness knows anything at all 6 right.
7 about Jeffrey Epstein, underage women, sexual 7 THE WITNESS: On the instruction of my
8 abuse of underage women, and she's not going to 8 lawyer, I must invoke my Fifth Amendment
9 answer any questions that assume that as a 9 privilege.
10 predicate. They are objectionable as ambiguous 10 BY MR. KUVIN:
11 and compound, and I instruct her not to answer. 11 Q. You are aware, are you not, that
12 THE WITNESS: On the instruction of my 12 David Copperfield has visited Jeffrey Epstein's home
13 lawyer, I must invoke my Fifth Amendment 13 in Palm Beach?
14 privilege. 14 MR. : Objection to the form as
15 BY MR. KUV1N: 15 it once again assumes she has some knowledge of
16 Q. Are you aware whether or not 16 Jeffrey Epstein, or whether he has a home in
17 Jeffrey Epstein has had any homosexual relationships 17 Palm Beach. Because those facts are implicit
18 in the past? 18 in the question, the question is ambiguous and
19 MR. Same objection as the 19 compound. I would instruct her not to answer
20 previous question. The question as stated 20 based on her Fifth Amendment.
21 assumes this witness has some knowledge of 21 THE WITNESS: On the instruction of my
22 Jeffrey Epstein. And since it assumes that 22 lawyer, I must invoke my Fifth Amendment
23 fact, it is ambiguous and it's compound. and I 23 privilege.
24 instruct her not to answer. 24 BY MR. KUVIN:
25 THE WITNESS: On the instruction of my 25 •. You are aware. are you not. that
20 (Pages 77 to 80)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 20 of 47
EFTA_00065337
EFTA01246483
Page 81 Page 83
1 David Copperfield and Jeffrey Epstein used to share 1 privilege.
2 for sexual -- for sex, iris under the age of 16? 2 THE WITNESS: On the instruction of my
3 MR. : Same objection as 3 lawyer, I must invoke my Fifth Amendment
4 previously stated to the last I don't know how 4 privilege.
5 many questions. This question again assumes 5 BY MR. KUVIN:
6 this witness knows Jeffrey Epstein, has any 6 Q. How many people did Jeffrey Epstein use to
7 knowledge of Jeffrey Epstein's life. And 7 help him bring minor females to his house in Palm
8 because it assumes that fact, there is an 8 Beach for sex?
9 underlying predicate it is ambiguous and 9 MR. Same objection as the
10 compound. I would instruct her not to answer. 10 previous question and I instruct her not to
11 THE WITNESS: On the instruction of my 11 answer.
12 lawyer, I must invoke my Fifth Amendment 12 THE WITNESS: On the instruction of my
13 privilege. 13 lawyer, I must invoke my Fifth Amendment
14 BY MR. KUVIN: 14 privilege.
15 Q. From the time you met Mr. Epstein, isn't 15 BY MR. KUVIN:
16 it true that he would arrange for underage girls. 16 Q. Do you agree that Jeffrey Epstein is a
17 girls under the age of 18. to have sex with every 17 child molester?
18 single day? 18 MR. That question is solely
19 MR. : Let me try this again. 19 intended to harass the witness and it's
20 Objection to the form. Any question you're 20 ambiguous as to what a child molester means,
21 going to ask her that assumes she knows 21 and you're asking for a legal conclusion and
22 Jeffrey Epstein, she's ever met Jeffrey 22 instruct her not to answer.
23 Epstein, she's ever seen Jeffrey Epstein, knows 23 BY MR. KUVIN:
24 where he lives, knows what he does, if it 24 Q. In your own o • inion.
25 assumes that as part of the question, I will 25 MR. I will again instruct her
Page 82 Page 84
1 deem the question to be ambiguous and compound. 1 not to answer based on her Fifth Amendment
2 because you're asking her to admit as a 2 privilege as well as the question having no
3 predicate that she knows Mr. Epstein. As to 3 legitimate basis and will not lead to
4 any question like that. I am going to instruct 4 discoverable evidence.
5 her to take the Fifth Amendment on that basis. 5 THE WITNESS: On the instruction of my
6 So I would again instruct her to take the Fifth 6 lawyer, I must invoke my Fifth Amendment
7 Amendment as to that question. 7 privilege.
8 THE WITNESS: On the instruction of my 8 BY MR. KUVIN:
9 lawyer. I must invoke my Fifth Amendment 9 Q. Would you agree that Jeffrey Epstein is
10 privilege. 10 obsessed with undera e females?
11 MR. KUVIN: If you want to short circuit 11 MR. Objection to the form.
12 that, anytime I mention Jeffrey Epstein you can 12 It's ambiguous as to what you mean by
13 have a standing objection on that issue. I 13 "obsessed." I'll instruct the witness not to
14 have no roblem. 14 answer based on her Fifth Amendment privilege,
15 MR. Great. 15 because the question assumes knowledge of
16 BY MR. KUVIN: 16 Jeffrey Epstein.
17 Q. Can you explain. if you would, to a jury 17 THE WITNESS: On the instruction of my
18 how Mr. Epstein would access underage minor females 18 lawyer, I must invoke my Fifth Amendment
19 for sex eve da ? 19 privilege.
20 MR. The question is compound 20 BY MR. KUVIN:
21 in that it asks about Mr. Epstein every day. 21 Q. How would ou define the word "obsessed"?
22 underage females, and involves multiple 22 MR. You can answer that.
23 questions in the same question. and also based 23 THE WITNESS: I don't know. You like it a
24 on the standing objection. I would instruct her 24 lot. I don't know.
25 not to answer based on her Fifth Amendment 25
-...
21 (Pages 81 to 8 4)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 21 of 47
EFTA_00065338
EFTA01246484
Page 85 Page 87
BY MR. KUVIN: 1 lawyer, I must invoke my Fifth Amendment
2 Q. Okay. Using your definition of obsessed, 2 privilege.
3 would you agree with me that Jeffrey Epstein was 3 BY MR. KUVIN:
4 obsessed with undera e females? 4 Q. Did you keep a journal with the names of
5 MR. Same objection; same 5 girls in it in the ear 2005?
6 instruction. 6 MR. : Objection to the form as
7 THE WITNESS: On the instruction of my 7 ambiguous. What do you mean by "journal"?
8 lawyer, I must invoke my Fifth Amendment 8 MR. KUVIN: I will define it.
9 privilege. 9 MR. : Please.
10 BY MR. KUVIN: 10 BY MR. KUVIN:
11 Q. When was the first time that you learned 11 Q. Did you keep a pad of paper. either a
12 Mr. Epstein was getting a massage from a girl under 12 ringed notebook or some other format with the names
13 the age of 16? 13 of girls and their one numbers in it in 2005?
14 MR. One second. 14 MR. : I'll instruct the witness
15 MR. KUVIN: Sure. 15 not to answer based on her Fifth Amendment
16 MR. I want to make the 16 privilege. Also the question remains
17 standing objection for the reasons previously 17 ambiguous.
18 stated, the question is otherwise also compound 18 THE WITNESS: On the instruction of my
19 in that it assumes multiple facts and asks her 19 lawyer, I must invoke my Fifth Amendment
20 to answer multiple questions at the same time. 20 privilege.
21 I'll instruct her not to answer based on her 21 BY MR. KUV1N:
22 Fifth Amendment. 22 Q. Would you agree with me that you kept a
23 THE WITNESS: On the instruction of my 23 pad of paper or a journal. however you want to
24 lawyer, I must invoke my Fifth Amendment 24 describe it, that contain the names of hundreds of
25 privilege. 25 underage girls and their phone numbers? i
Page 86 Page 88
1 BY MR. KUVIN: 1 MR. Object to the form of the
2 Q. Do you know who owns the home at 358 2 question. It's compound and asking her to
3 El Brillo Wa '≥ 3 answer multiple questions at the same time.
4 MR. Same instructions as to 4 It's also leading, and I would instruct her not
5 the standing objection. 5 to answer based on her Fifth Amendment.
6 THE WITNESS: On the instruction of my 6 THE WITNESS: On the instruction of my
7 lawyer, I must invoke my Fifth Amendment 7 lawyer, I must invoke my Fifth Amendment right.
8 privilege. 8 BY MR. KUVIN:
9 BY MR. KUVIN: 9 Q. Would you agree with me that you kept a
10 Q. Have .ou been on Palm Beach Island before? 10 pad of paper, notebook, or journal with the names of
11 MR. I am sorry. Can you 11 hundreds of girls under the age of 16 so that you
12 restate the question? 12 could contact them and have them come to
13 MR. KUVIN: Sure. 13 Jeffrey Epstein's home for sex with him?
14 BY MR. KUVIN: 14 MR. : Objection to the form as
15 Q. Have you been on the Island of Palm Beach 15 compound and ambiguous, and I'll instruct her
16 before? 16 not to answer based on Fifth Amendment.
17 MR. You can answer that yes or 17 THE WITNESS: On the instruction of my
18 no. 18 lawyer, I must invoke my Fifth Amendment
19 THE WITNESS: Yes. 19 privilege.
20 BY MR. KUVIN: 20 BY MR. KUVIN:
21 Q. How man times? 21 Q. Do ou know Alfredo Rodriguez?
22 MR. I'll instruct her not to 22 MR. : I'll instruct the witness
23 answer that question based on her Fifth 23 not to answer based on her Fifth Amendment
24 Amendment privilege. 24 privilege.
25 THE WITNESS: On the instruction of my 25 THE WITNESS: On the instruction of my
22 (Pages 85 to 88)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 22 of 47
EFTA_00065339
EFTA01246485
Page 89 Page 91
1 lawyer, I must invoke my Fifth Amendment 1 prosecution by either the State or the federal
2 privilege. 2 government?
3 BY MR. KUVIN: 3 MR. : She's not answering that
4 Q. Are you aware that Alfredo Rodriguez has 4 question. She's not required to answer the
5 pled guilty to federal charges for hiding a journal 5 question. She's invoked her Fifth Amendment
6 containing the names of women? 6 privilege. She will continue to do so as to
7 MR. Objection to the form as 7 that question. You can move on.
8 compound and instruct her not to answer. 8 BY MR. KUVIN:
9 THE WITNESS: On the instruction of my 9 Q. Ma'am. are you invoking your Fifth
10 lawyer, I must choose to invoke my Fifth 10 Amendment because your lawyer is advising you to
11 Amendment privilege. 11 invoke your Fifth Amendment, or because you
12 BY MR. KUVIN: 12 personally have a fear that you might be prosecuted
13 Q. Do you have a personal fear of criminal 13 by either the state or the federal government?
14 prosecution as ou sit here today? 14 MR. : We have now been down thin
15 MR. I instruct the witness -- 15 street four times. She's not going to answer
16 object to the form. That's the whole basis why 16 the question. You can move along or we can
17 one would invoke the Fifth Amendment so clearly 17 leave.
18 she's does. I am not going to have her answer 18 MR. KUVIN: I am just clarifying the
19 the question. It's solely meant to harass. 19 question. and I appreciate it. And you can
20 MR. KUVIN: So is she not going to answer 20 object. I just want to make sure that I have a
21 that question? 21 clear record of every possible machination of
22 MR. She's not going to answer 22 the question so that I don't get hit later with
23 that question. 23 you didn't ask the specific question you need
24 MR. KUVIN: I think what I need to 24 to ask. So. I'm not doing it certainly to
25 establish is that she personally has a fear, 25 harass. I just want to make sure that the
Page 90 Page 92
1 not her lawyer. So I would like to establish 1 record is ve clear of my question.
2 whether the witness has a personal fear. 2 MR. I understand. You can
3 MR. Well, first of all, under 3 move on.
4 the Fifth Amendment you don't have to be in 4 BY MR. KUVIN:
5 fear. You just have to believe that the 5 Q. Ma'am, have you had any direct
6 government believes you can be prosecuted for 6 communications with the State Attorney's office in
7 something. She's been invoking the Fifth 7 the last two ears?
8 Amendment on her own. It is implicit in her 8 MR. When you say "direct
9 invocation in what she fears. She's not going 9 communications," can you clarify?
10 to answer that question. 10 MR. KUVIN: Yes.
11 MR. KUVIN: Well, I tend to disagree. She 11 BY MR. KUVIN:
12 hasn't been invoking it on her own. She's been 12 Q. You, personally, have you spoken with
13 invoking it after you have instructed her to 13 anyone in the State Attorney's office in the last
14 invoke it. So I want to know her personal -- 14 two years?
15 MR. : You can take that up with 15 MR. KUVIN: I can't imagine there would be
16 the judge then. She's not answering the 16 a Fifth Amendment for that.
17 question. She's invoking her Fifth Amendment 17 MR. Let me consult. If I
18 on her own accord based on the advice of her 18 might. Okay?
19 lawyer. And you can take it up somewhere else, 19 MR. KUVIN: Sure.
20 but she's not answering that question. 20 MR. It would all depend on
21 MR. KUVIN: Well, then let me clarify the 21 what was said to her if she could consult with
22 record. 22 them now. For example, if they consulted and
23 BY MR. KUVIN: 23 they told her they were about to prosecute,
24 Q. Ma'am. are you invoking your Fifth 24 then there could be a Fifth Amendment claim,
25 Amendment because you personally have a concern of 25 couldn't there?
23 (Pages 89 to 92)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 23 of 47
EFTA_00065340
EFTA01246486
Page 93 Page 95
1 MR. KUVIN: No, not as to the statements 1 Q. Have you spoken with anybody at the U.S.
2 they told her. I mean. that's certainly not 2 Attorney's Office in the last five years?
3 Fifth Amendment. That's something that was 3 A. No.
4 told to her. 4 Q. Have you spoken with anyone at the FBI in
5 MR. : We'll take that up 5 the last five years?
6 elsewhere if you need to. You can answer. 6 A. No.
7 MR. KUVIN: Okay. 7 Q. Have you spoken with anyone at the
8 THE WITNESS: No, I have not. 8 Palm Beach Police De .artment in the last five years?
9 BY MR. KUVIN: 9 MR. : When you say, "the Palm
10 Q. All right. Ma'am. have you had any 10 Beach Police," for any purpose or as related to
11 personal communications with anyone working for the 11 this case? Again, for example. if there was
12 federal government in the last two years? 12 like a parking ticket --
13 MR. : When you say "the federal 13 MR. KUVIN: Sure.
14 government" do you mean the postal service, the 14 MR. : -- or some other thing. I
15 entire federal government, or do you want to 15 want to clarify that.
16 clarify that? 16 BY MR. KUVIN:
17 MR. KUVIN: Well. I certainly could leave 17 Q. Let's, let's start with broad, and we can
18 it open-ended. If she's talked to a post 18 work to specific. Can you recall having any
19 office employee, that would be interesting, but 19 conversations for any reason with the Palm Beach
20 certainly not to this case. 20 Police Department in the last five years?
21 BY MR. KUVIN: 21 A. No.
22 Q. Let's talk about the U.S. Attorney's 22 Q. Okay. Do you have knowledge whether or
23 Office or anyone working on behalf of the U.S. 23 not the Palm Beach Police Department ever requested
24 Attorney's Office. 24 for you to come in for an interview at any time in
25 A. Have I personally ever spoken to anyone? 25 the last five years?
Page 94 Page 96
1 Q. Yes, ma'am, personally have you ever had 1 MR. : If you know the answer tc
2 any conversations with anyone at the U.S. Attorney's 2 that question because that's something your
3 Office or one of their -- one -- a person 3 attorney told you, you don't have to answer
4 representing to be from that office in the last two 4 that question. Otherwise, go ahead and answer.
5 years. 5 THE WITNESS: No.
6 A. No. 6 BY MR. KUVIN:
7 Q. Okay. Do you know, as you sit here today, 7 Q. Okay. When did you first retain an
8 whether or not you ever were requested to give a 8 attorney? What date did you first retain a -- I
9 statement by the State Attorney's office for the 9 mean, let me clarify. What date did you first
10 Palm Beach Police De 'ailment? 10 retain a criminal attorne ?
11 MR. : May I consult? 11 MR. : I'll instruct her not to
12 MR. KUVIN: Yes. 12 answer based on the Fifth Amendment privilege.
13 MR. : You may answer. And for 13 THE WITNESS: On the instruction of my
14 the record. I was just determining whether the 14 lawyer, I must invoke my Fifth Amendment
15 answer to that question would be protected by 15 privilege.
16 the attorney-client privilege. 16 BY MR. KUVIN:
17 MR. KUVIN: Understood. 17 Q. Did you first retain a criminal attorney
18 THE WITNESS: No, I don't. I don't know. 18 in the year 2005?
19 BY MR. KUVIN: 19 MR. : Same instruction.
20 Q. Let me clarify the last two questions I 20 THE WITNESS: On the instruction of my
21 asked about the State Attorney's Office and the U.S. 21 lawyer, I must invoke my Fifth Amendment
22 Attorney's Office. Have you spoken with anybody 22 privilege.
23 personally at the State Attorney's Office in the 23 BY MR. KUVIN:
24 last five years? 24 Q. Did you retain a criminal attorney in
25 A. No. 25 2004?
24 (Pages 93 to 9 6)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 24 of 47
EFTA_00065341
EFTA01246487
Page 97 Page 99
1 MR. Same instruction. 1 assumes facts that have not been established
2 THE WITNESS: On the instruction of my 2 and it's compound.
3 lawyer, I must invoke my Fifth Amendment 3 THE WITNESS: On the instruction of my
4 privilege. 4 lawyer, I must invoke my Fifth Amendment
5 BY MR. KUVIN: 5 privilege.
6 Q. Have you ever worked as a professional 6 MR. : And to clarify the
7 model? 7 objection is that it assumes that she's ever
8 MR. May I consult? 8 met or knows anything about Jean-Luc Brunel.
9 MR. KUVIN: Sure. 9 BY MR. KUVIN:
10 MR. You can answer the 10 Q. Were you ever promised anything regarding
11 question. 11 your modelin career b Jeffrey Epstein?
12 THE WITNESS: Yes. 12 MR. : Same objection, instruct
13 BY MR. KUVIN: 13 the witness not to answer.
14 Q. When? 14 THE WITNESS: On the instruction of my
15 A. I don't remember. I don't remember the dates. 15 lawyer, I must invoke my Fifth Amendment
16 It was at least maybe ten years ago. 16 privilege.
17 Q. And ou're how old now? 13 BY MR. KUVIN:
18 MR. I'll instruct the witness 19 Q. You would agree with me that there is a
19 not to answer the question. Nice try. 19 financial arrangement between Jean-Luc Brunel and
20 Instruct you not to answer based on 20 Jeffrey Epstein. doyou not?
21 your Fifth Amendment privilege. 21 MR. : Objection. It assumes she
22 THE WITNESS: On the instruction of my 22 has any knowledge of either Mr. Epstein or
23 lawyer, I'm going to invoke my Fifth Amendment 23 Mr. Brunel. and as to that she is going to
24 privilege. 24 invoke her Fifth Amendment privilege. The
25 MR. KUVIN: I'm just trying to find out. 25 question is compound and therefore ambiguous.
Page 98 Page 100
1 MR. Like I said, good try. 1 THE WITNESS: On the instruction of my
2 Move on. 2 lawyer, I must invoke my Fifth Amendment
3 BY MR. KUVIN: 3 privilege.
4 Q. With respect to your work as a 4 BY MR. KUVIN:
5 professional model. what company did you work for? 5 Q. Would you agree with me that
6 MR. Instruct the witness not 6 Ghislaine Maxwell provides underage girls to
7 to answer based on the Fifth Amendment 7 Mr. Epstein for sex?
8 privilege. 8 MR. Objection to the font. It
9 THE WITNESS: On the instruction of my 9 assumes she knows anything at all about
10 lawyer, I invoke my Fifth Amendment privilege. 10 Ghislaine Maxwell and asks her to assume that
11 BY MR. KUVIN: 11 she does, and therefore it is compound and
12 Q. What is your understanding of 12 ambiguous, and I would instruct her not to
13 Mr. Epstein's involvement with the modeling 13 answer.
14 industry? 14 THE WITNESS: Upon the instruction of my
15 MR. Standing objection, and 15 lawyer, I must invoke my Fifth Amendment
16 instruct the witness not to answer based on 16 privilege.
17 Fifth Amendment, on that basis. 17 MR. KUVIN: That's a good point. Take a
18 THE WITNESS: Upon the instruction of my 18 look at what we'll mark as Exhibit 10.
19 lawyer, I must invoke my Fifth Amendment 19 (Plaintiff's Exhibit No. 10 was marked for
20 privilege. 20 identification.)
21 BY MR. KUVIN: 21 MR. KUVIN: All me to show it to the
22 Q. Were you ever promised anything regarding 22 camera first.
23 your modelin career b Jean-Luc Brunel? 23 MR. Okay.
24 MR. . Instruct the witness not 24 MR. KUVIN: Okay.
25 to answer based on Fifth Amendment. also 25 THE WITNESS: Okay.
25 (Pages 97 to 100)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 25 of 47
EFTA_00065342
EFTA01246488
Page 101 Page 103
1 BY MR. KUVIN: 1 You're asking the witness three
2 Q. Take a look at what we marked as Exhibit 2 questions at the same time, and I would
3 10. Do you recognize the two people in that 3 instruct her not to answer based on the
4 photograph? 4 Fifth Amendment.
5 MR. : I'll instruct the witness 5 THE WITNESS: On the instruction of my
6 not to answer based on her Fifth Amendment 6 lawyer, I must invoke my Fifth Amendment
7 privilege. 7 privilege.
8 THE WITNESS: On the instruction of my 8 MR. KUVIN: Just so we're clear, had she
9 lawyer, I must invoice my Fifth Amendment 9 answered the first two questions, then
10 privilege. 10 obviously I wouldn't have to ask the third one
11 BY MR. KUVIN: 11 that has all of them in it but --
12 Q. Would you agree with me that's 12 MR. : If you had accepted her
13 Ghislaine Maxwell on the right and Jeffrey Epstein 13 answer, you would have known that she wasn't
14 on the left? 14 going to answer these, and we could have saved
15 MR. : Objection to the form. It 15 a few minutes.
16 assumes that she knows who Ghislaine Maxwell 16 MR. KUVIN: And as you well know, I must
17 and Jeffrey Epstein are, and therefore it's 17 ask the question in order to gain the inference
18 compound and ambiguous, and I would instruct 18 at trial.
19 her not to answer. 19 MR. : I understand.
20 THE WITNESS: On the instruction of my 20 MR. KUVIN: All right.
21 lawyer, I must invoke my Fifth Amendment 21 (Plaintiff's Exhibit No. 12 was marked for
22 privilege. 22 identification.)
23 MR_ KUVIN: Okay. I will mark this as 23 BY MR. KUVIN:
24 Exhibit II. 24 Q. Do you recognize the gentleman that is
25 25 shown --
Page 102 Page 104
1 (Plaintiff's Exhibit No. II was marked for 1 MR. We'll have a job here.
2 identification.) 2 MR. KUVIN: That is true.
3 BY MR. KUVIN: 3 BY MR. KUVIN:
4 Q. Let me show you what we marked as 4 Q. -- that is shown in Exhibit 12?
5 Exhibit II. Han on one second. 5 MR. KUVIN: Let me hold this for the
6 MR. Sure. 6 camera first.
7 BY MR. KUVIN: 7 MR. I'm sorry. Is there a
8 Q. Do you recognize the young lady shown in 8 question pending?
9 Exhibit II? 9 MR. KUVIN: Yes.
10 MR. I'll instruct the witness 10 BY MR. KUVIN:
11 not to answer based on her Fifth Amendment 11 Q. Do you recognize the gentleman shown in
12 privilege. 12 Exhibit 12?
13 THE WITNESS: On the instruction of my 13 MR. I instruct her not to
14 lawyer. I must invoke my Fifth Amendment 14 answer based on the Fifth Amendment.
15 privilege. 15 THE WITNESS: On the instruction of my
16 BY MR. KUVIN: 16 lawyer, I must invoke my Fifth Amendment
17 Q. Do you agree with me that the young girl 17 privilege.
18 shown in Exhibit II was recruited by Ghislaine 18 BY MR. KUVIN:
19 Maxwell to, for sexual activity with 19 Q. Would you agree with me that that is
20 Jeffrey Epstein? 20 Prince Andrew shown in Exhibit 12?
21 MR. Objection to the form. It 21 MR. Same instruction.
22 assumes she knows who the person is in Exhibit 22 THE WITNESS: On the instruction of my
23 II. and assumes she knows who Ghislaine Maxwell 23 lawyer, I must invoke my Fifth Amendment
24 is. and assumes she knows who Jeffrey Epstein 24 privilege.
25 is. and is therefore compound. 25
26 (Pages 101 to 104)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 26 of 47
EFTA_00065343
EFTA01246489
Page 105 Page 107
1 BY MR. KUVIN: 1 break now.
2 Q. Would you agree with me that you have been 2 MR. KUVIN: Okay.
3 present where Jeffrey Epstein and Prince Andrew have 3 THE VIDEOGRAPHER: We're now off video
4 had sexual relations with underage girls? 4 record. The time is 11:57 a.m.
5 MR. Objection to the form, 5 (A luncheon recess was held.)
6 it's compound in that it assumes she knows who 6 (Plaintiffs Exhibit No's 4 was marked for
7 the person is in Picture 12. she knows who 7 identification.)
8 Prince Andrew is, and she knows who Jeffrey 8 (Plaintiffs Exhibit No. 5 was marked for
9 Epstein is. It's compound and ambiguous, and 9 identification.)
10 I'll instruct her not to answer based on her 10 THE VIDEOGRAPHER: We're now on video
11 Fifth Amendment. 11 record. The time is 1:02 p.m.
12 THE WITNESS: On the instruction of my 12 MR. KUVIN: All right, counsel. I'm going
13 lawyer, I must invoke my Fifth Amendment 13 to ask a couple more general questions, and
14 privilege. 14 then when we get into the specifics of the
15 BY MR. KUVIN: 15 individual girls. I just want to make sure,
16 Q. Would you agree with me that Prince Andrew 16 once again, on the record, as we've done in
17 and Jeffrey Epstein used to share underaged girls 17 every deposition in this case, that we'll use
18 for sexual relations? 18 the Plaintiffs full name with the
19 MR. Same objection previously 19 understanding that the final transcript will
20 stated, requires her to also speculate who 20 only contain their initials, and there will be
21 Prince Andrew is. I instruct her not to answer 21 a key at the conclusion that's only provided to
22 based on the Fifth Amendment. 22 the parties in this case and their counsel to
23 THE WITNESS: On the instruction of my 23 be kept confidential going forward. But
24 lawyer, I must invoke my Fifth Amendment 24 obviously, for the purposes of this deposition,
25 privilege. 25 we will be using full names.
Page 106 Page 108
1 MR. Also requires speculation 1 MR. Agreed.
2 as to who Jeffrey Epstein is as well. 2 MR. KUVIN: Okay. Is there any
3 BY MR. KUVIN: 3 disagreement with that around the table?
4 Q. Do ou know who Prince Andrew is? 4 MR. HOROWITZ: Agreed.
5 MR. • I'll instruct her not to 5 MR. WEISSING: Agreed.
6 answer based on the Fifth Amendment. 6 MS. EZELL: Agreed.
7 THE WITNESS: On the instruction of my 7 MR. KUVIN: Jack, do you agree to the --
8 lawyer. I must invoke my Fifth Amendment 8 MR. GOLDBERGER: I thought I'm not a pan
9 privilege. 9 of it.
10 MR. KUVIN: It's almost 12:00. Do you 10 MR. KUVIN: Well, you've been playing a
11 want to take a uick lunch? 11 pan, so I want to make sure you agree.
12 MR. Sure. How much longer do 12 MR. GOLDBERGER: Yeah. I agree. I agree.
13 you think you will be. Mr. Kuvin, before we go 13 MR. : Hold on. Let me just
14 on to other counsel? 14 explain to her what we're talking about.
15 MR. KUVIN: Probably not that much longer. 15 MR. KUVIN: Please do.
16 MR. Okay. 16 MR. : But when the transcript is
17 MR. KUVIN: I have to get through a couple 17 typed up, it won't have her name it will just
18 of more generic stuff, and then get into the 18 have initials. But we'll get a code that
19 specifics of m cases and then -- 19 explains the name. So that way you would be
20 MR. Okay. So. we. but just so 20 asked if you recognize the name not a set of
21 we have a sense of planning whether this is the 21 initials that you may not understand or a Jane
22 right time for a lunch break. You're not going 22 Doe number that you do not know.
23 to finish in the next 15 or 20 minutes? 23 MR. KUVIN: That's way too confusing.
24 MR. KUVIN: No. not even close. 24 Okay?
25 MR. Okay. Let's take a lunch 25 MR. Correct.
27 (Pages 105 to 108)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 27 of 47
EFTA_00065344
EFTA01246490
Page 109 Page 111
BY MR. KUVIN: 1 objection to the form.
2 Q. Let's take a look at what Tve marked -- 2 THE WITNESS: At the instruction of my
3 premarked as Exhibit 4. It's a stack of documents, 3 lawyer, I must invoke my Fifth Amendment
4 just so you understand what this is and your 4 privilege.
5 attorney can object or agree or disagree as he sees 5 BY MR. KUVIN:
6 fit, but this is a stack of documents that was part 6 Q. Yes. Do
7 of the trash pull from Jeffrey Epstein's home as 7 MR. Instruct the witness not
8 part of the criminal investigation. Just so you're 8 to answer the question based on her Fifth
9 aware of what these are. 9 Amendment privilege.
10 MR. That was retrieved, that 10 THE WITNESS: On the instruction of my
11 was retrieved by the Palm Beach Police 11 lawyer, I must exercise my Fifth Amendment
12 Department from the trash -- 12 privilege.
13 MR. KUVIN: That's correct. 13 BY MR. KUVIN:
14 MR. : -- at the home of what is 14 Q. Will you agree with me that on the first
15 known to be Mr. Epstein's home? 15 page of Exhibit 4, you were to arrange for roses to
16 MR. KUVIN: Correct. 16 be delivered to Jane Doe No. 103 at her high school
17 MR. : Okay. 17 performance?
18 MR. KUVIN: All right. And that's not a 18 MR. Objection to the form.
19 question. I just wanted to kind of give you a 19 It's compound in that it assumes this is the
20 context for what I'm going to be asking you 20 witness's handwriting and assumes the witness
21 about. 21 knows a person by the name of Jane Doe No. 103
22 MR. Thank you. 22 and the witness otherwise knows Jeffrey Epstein
23 BY MR. KUVIN: 23 whose name is at the bottom of the paper, and
24 Q. All right. In taking a look at Exhibit 4, 24 therefore, it's compound and ambiguous, and
25 I'd like you to take a look at the front page, the 25 instruct her not to answer.
Page 110 Page 112
1 first page of those documents. 1 THE WITNESS: On the instruction of my
2 Is that our handwriting, ma'am? 2 lawyer, I must exercise my Fifth Amendment
3 MR. : Instruct the witness not 3 right.
4 to answer based on the Fifth Amendment 4 MR. KUVIN: I forgot to mention this at
5 privilege. 5 the beginning, but objection to form usually
6 THE WITNESS: At the instruction of my 6 covers all that stuff like vague and compound,
7 lawyer, I must exercise my Fifth Amendment 7 and --
8 right. 8 MR. : Okay.
9 BY MR. KUVIN: 9 MR. KUVIN: --I'll leave it up to you,
10 Q. And, in fact, that is your handwriting on 10 but objection to form as far as the civil arena
11 this notepad is it not? 11 context will cover all of those.
12 MR. Same instruction. It's 12 MR. : Just figured I'd make the
13 the same question. 13 record clear in case we ever have an issue, or
14 THE WITNESS: On the instruction of my 14 in case you want to correct it based on what I
15 lawyer, I must invoke my Fifth Amendment right. 15 believe to be the improper form. I will give
16 BY MR. KUVIN: 16 you a chance to correct it.
17 Q. In this note do you agree that you 17 BY MR. KUVIN:
18 arranged for an extension of one month on the rental 18 Q. No problem. All right. On Page 2 of
19 car for a lad under the age of 16? 19 Exhibit 4, if you'd take a look at that. Is that
20 MR. Objection to the form. It 20 your handwritin ?
21 is compound. It assumes that this is her 21 MR. : Instruct the witness not
22 handwriting. It doesn't identify who the 22 to answer based on the Fifth Amendment
23 lady might be, and it's otherwise ambiguous, so 23 privilege.
24 I instruct her not to answer on the Fifth 24 THE WITNESS: On the instruction of my
25 Amendment privilege in addition to the legal 25 lawyer. I choose to exercise my Fifth Amendment
28 (Pages 109 to 112)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 28 of 47
EFTA_00065345
EFTA01246491
Page 113 Page 115
1 right. 1 MR. Okay. I would be happy
2 BY MR. KUVIN: 2 to.
3 Q. Do you know who Larry is, as referred to 3 MR. KUVIN: I just want to clarify,
4 in Page 2 of Exhibit 4? 4 because I don't think --
5 MR. I'm sorry. Can you -- 5 MR. Okay.
6 BY MR. KUVIN: 6 MR. KUVIN: I don't think this is a
7 Q. Do ou know who -- 7 problem but I 'ust want to clear it up.
8 MR. -- restate the question? 8 MR. Thank you, Mr. Kuvin.
9 BY MR. KUVIN: 9 I'll let her answer that question.
10 Q. Do you know who Larry is as referred to in 10 MR. KUVIN: Not a problem.
11 Page 2 of Exhibit 4? 11 MR. So the question pending
12 MR. So, just so I'm clear. 12 is, is that your handwriting?
13 what the question is, the document on its face 13 MR. KUVIN: Correct.
14 has the name Larry in it. You're just asking 14 BY MR. KUVIN:
15 this witness whether she knows who this person 15 Q. Is this your handwriting? Just yes or no.
16 Larry is? 16 A. No.
17 MR. KUVIN: Correct. 17 Q. Okay. Thank you. All right. Let's look
18 MR. • Instruct the witness not 18 at Page 4 of Exhibit 4. All right. This one's a
19 to answer based on her Fifth Amendment 19 little different. Is this our handwriting?
20 privilege. 20 MR. Let me consult with her
21 THE WITNESS: On the instruction of my 21 again.
22 lawyer, I must invoke my Fifth Amendment right. 22 Okay. That's fine. You can answer
23 BY MR. KUVIN: 23 the question consistent with the
24 Q. Do you know why Larry was recommending 24 conversation we just had.
25 that Mr. Epstein leave? 25 THE WITNESS: No.
Page 114 Page 116
1 MR. Objection to the form and 1 BY MR. KUVIN:
2 instruct the witness not to answer based upon 2 Q. Do you know who is as referred to
3 her Fifth Amendment privilege. 3 in this note of Pa _e 4 of Exhibit 4?
4 THE WITNESS: On the instruction of my 4 MR. : Instruct the witness not
5 lawyer, I must invoke my Fifth Amendment right. 5 to answer based on her Fifth Amendment
6 BY MR. KUVIN: 6 privilege.
7 Q. Would you agree with me that Larry was 7 THE WITNESS: On the instruction of my
8 calling to warn Mr. Epstein to leave town because he 8 lawyer, I must exercise my Fifth Amendment
9 was going to be arrested? 9 right.
10 MR. Objection to the form. 10 BY MR. KUVIN:
11 The question assumes facts that are not before 11 Q. All right. Let's look at Page 5,
12 her, and it requires her to speculate, and also 12 Exhibit 4.
13 implies that she knows anything at all about 13 Before we go to Page 5, rather, going
14 Jeffrey Epstein, so I will instruct her not to 14 backSt aris 4 for a minute. Will you agree with me
15 answer. 15 that as referred to in Page 4 of Exhibit 4
16 THE WITNESS: On the instruction of my 16 is a girl that is under the age of 16?
17 lawyer, I wish to exercise my Fifth Amendment 17 MR. : Object to the form. You
18 right. 18 previously asked if she knew who was,
19 BY MR. KUVIN: 19 and she invoked her Fifth Amendment privilege.
20 Q. Take a look at Page 3 of Exhibit 4, 20 Since the new presumes that she does
21 please. Is that our handwriting? 21 know who is she is going to invoke her
22 MR. I'll instruct her not to 22 Fifth Amendment privilege upon my instruction.
23 answer based on the Fifth Amendment privilege. 23 MR. KUVIN: All right. Let's look at
24 MR. KUVIN: Before we do that, would you 24 Page 5.
25 consult with her? 25 MR. Let her answer.
29 (Pages 113 to 1 1 6)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 29 of 47
EFTA_00065346
EFTA01246492
Page 117 Page 119
1 MR. KUVIN: I'm sorry. go ahead. 1 that Page 5 of Exhibit 4 appears to be a receipt for
2 THE WITNESS: On the instruction of my 2 books ordered throw h Amazon.com?
3 lawyer. I must invoke my Fifth Amendment 3 MR. : You can answer that yes or
4 privilege. 4 no.
5 BY MR. KUVIN: 5 THE WITNESS: It looks like a receipt from
6 Q. MI right. Take a look at Page 5, if you 6 Amazon.
7 would. Have you ever ordered anything. anything 7 BY MR. KUVIN:
8 yourself from Amazon.com? 8 Q. Okay. And did you place this order for
9 MR. • You're asking for herself 9 Jeffrey Epstein?
10 or anyone else if she has ever placed an order 10 MR. : Instruct the witness not
11 with Amazon.com for any reason? 11 to answer the question in that the question
12 MR. KUVIN: I am asking whether she 12 presumes that she knows who Jeffrey Epstein is.
13 personally has ever placed an order with a 13 and therefore, I instruct her not to answer.
14 compan called Amazon.com. 14 THE WITNESS: On advice of counsel. I must
15 MR. Yes or no. You can answer 15 invoke my Fifth Amendment privilege.
16 that. 16 BY MR. KUVIN:
17 THE WITNESS: Yes. 17 Q. Have you ever read the book identified in
18 BY MR. KUVIN: 18 Page 5 of Exhibit 4 called Slave Craft: Road Maps
19 Q. Okay. So you would agree with me that you 19 for Erotic Servitude - Principals. Skills and Tools?
20 know what Amazon.com is? 20 MR. : Instruct the witness not
21 A. Yes. 21 to answer based on her Fifth Amendment
22 Q. Okay. Now, have you ever placed an order 22 privilege.
23 through Amazon.com for things to be delivered at 23 THE WITNESS: On the instruction of my
24 358 El Brillo Wa ? 24 lawyer, I must choose to invoke my Fifth
25 MR. Instruct the witness to 25 Amendment right.
Page 118 Page 120
1 invoke her Fifth Amendment privilege as to that 1 BY MR. KUVIN:
2 question. 2 Q. Did you ever see that book I just
3 THE WITNESS: On the instruction of my 3 described at the home of Jeffrey Epstein on
4 lawyer, I must invoke my Fifth Amendment 4 358 El Brillo Wa ?
5 privilege. 5 MR. : Objection to the form in
6 BY MR. KUVIN: 6 that it presumes she knows Jeffrey Epstein and
7 Q. Will ou a ree with me -- 7 has ever been to 358 El Brillo Way. So, I
8 MR. • I'm sorry. Mr. Kuvin, for, 8 instruct her not to answer based on the Fifth
9 for the record, the page. pages of this exhibit 9 Amendment.
10 are not numbered, but the page we're looking at 10 THE WITNESS: On the instruction of my
11 purports to be a receipt for an order from 11 lawyer. I must choose to invoke my Fifth
12 Amazon.com; is that correct? 12 Amendment right.
13 MR. KUVIN: Correct. I just want her to 13 BY MR. KUVIN:
14 establish foundation before I got into 14 Q. Have you ever seen the book, Training With
15 specifics. 15 Miss Abernathy: A Workbook for Erotic Slaves and
16 MR. No, but you referred to it 16 Their Owners, at the home of Jeffrey Epstein on
17 as Page 5, but they are not numbered, so I just 17 358 El Brillo Wa ?
18 wanted to make sure that were looking at the 18 MR. : Same objection and same
19 same page on the exhibit. 19 instruction as the previous question.
20 MR. KUVIN: That is true. I'm just trying 20 THE WITNESS: On the instruction of my
21 to establish foundation for the questions I'm 21 lawyer, I must choose to invoke my Fifth
22 about to ask her. 22 Amendment right.
23 MR. Understood. 23 BY MR. KUVIN:
24 BY MR. KUVIN: 24 Q. Have you ever read that book that I just
25 Q. All right. Ma'am. would you agree with me 25 described which is shown in Page S of Exhibit 4?
30 (Pages 117 to 120)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 30 of 47
EFTA_00065347
EFTA01246493
Page 121 Page 123
1 MR. Same instruction. 1 BY MR. KUVIN:
2 THE WITNESS: On the instruction of my 2 Q. This note, Page 9 of Exhibit 4, appears to
3 lawyer, I must choose to invoke my Fifth 3 state that is trying to move -- and then
4 Amendment right. 4 there's a blanked out name, for 11 then
S BY MR. KUVIN: 5 could work at 6. Do you know anyone with the name
6 Q. Let's look at the sixth page of Exhibit 4, 6 M?
7 please. Is that your handwriting? 7 MR. If she knows anyone in the
8 A. No. 8 world by that name?
9 Q. All right. Let's look at Page 7. Is that 9 MR. KUVIN: Yeah. We could start with
10 your handwriting? 10 that.
11 A. No. 11 MR. I'm saying, in the
12 Q. Okay. Look at the next page which would 12 context, are you asking in the context of this
13 be Page 8. Is that your handwriting? 13 note which you just read, or are you asking.
14 A. No. 19 generically, does she know anyone in the world
15 Q. Let's see how much quicker this goes. 15 by the name of ?
16 Let's look at Page 9. Is that your handwriting? 16 MR. KUVIN: Why don't we rust do it in
17 A. No. 17 the context of this note.
18 Q. Look at Pa e 9 a ain, if you would. 18 BY MR. KUVIN:
19 MR. • When you say Page 9, 19 Q. Is this note referring to you when it
20 that's the page that purports to say 10:00. 20 says,' "?
21 MR. KUVIN: Dr. Bard. 21 MR. : Instruct the witness not
22 MR. -- Dr. Bard at the top? 22 to answer based on her Fifth Amendment
23 MR. KUVIN: Correct. 23 privilege.
24 MR. Okay. 24 THE WITNESS: On the advice of counsel. I
25 25 must invoke my Fifth Amendment right.
Page 122 Page 124
1 BY MR. KUVIN: 1 BY MR. KUVIN:
2 Q. Doyou know who Dr. Bard is? 2 In the context of this note, do you know
3 MR. Instruct the witness not 3 who is?
4 to answer based on the Fifth Amendment, because 4 MR. : Same instmction.
5 this sheet of paper has Jeffrey Epstein's name 5 THE WITNESS: On the advice of counsel, I
6 on the bottom, so the question implies that she 6 must invoke my Fifth Amendment right.
7 knows some connection between Dr. Bard and 7 BY MR. KUVIN:
8 Mr. Epstein. 8 Q. All ri t. Let's look at Page 10.
9 MR. KUVIN: Hang on a minute. Based on 9 MR. : Mr. Kuvin, let me go back
10 the objection, let me reword the question. 10 MR. KUVIN: Sure.
11 BY MR. KUVIN: 11 MR. : As to Page 1 of this
12 Q. Independent from this note and independent 12 exhibit. I think you had asked the witness
13 from anyone who may or may not be known as 13 whether this was her handwriting.
14 Jeffrey Epstein, do you know anyone by the name of 14 MR. KUVIN: Do you want to have her go
15 Dr. Bard? 15 back and answer?
16 A. I'm sorry. Ask the question again. 16 MR. : Yes, I would. Having
17 Q. Yes. I don't want you to assume anything 17 consulted with her further, I will have her go
18 from, the purpose of my question has anything to do 18 back to this question.
19 with someone who may be known as Jeffrey Epstein. 19 MR. KUVIN: Let's do that. I'll, I'll go
20 All I'm asking you is, generally, do 20 back and ask the question so that we can be
21 you know a rson b the name of Dr. Bard? 21 clear.
22 MR. Let me consult. 22 BY MR. KUVIN:
23 MR. KUVIN: Yes, yeah. 23 Q. On the Exhibit 4. the first page of
24 THE WITNESS: At the advice of counsel, I 24 Exhibit 4, ma'am. is that your handwriting? Yes or
25 must invoke my Filth Amendment right. 25 no.
31 (Pages 121 to 124)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 31 of 47
EFTA_00065348
EFTA01246494
Page 125 Page 127
1 A. No. 1 it in giving my advice, so thank you for
2 Q. Okay. All right. Let's skip Page 10. 2 clarifying.
3 because I think that's just a duplicate, and go to 3 MR. KUVIN: Absolutely.
4 Page 11, if ou would. 4 BY MR. KUVIN:
5 MR. : Page I 1 is -- 5 Q. All right. In Page II of Exhibit 4,
6 MR. KUVIN: It looks like DTG Operations, 6 there's a reference in the top right-hand comer. a
7 d/b/a Dollar Rent a Car. 7 message to a Mr. Goldsmith. Do you see that?
8 MR. : Got it. It's a printed 8 A. Uh-huh.
9 sheet, not a handwritten sheet. 9 Q. Yes?
10 MR. KUVIN: Correct. 10 MR. : You have to say yes or no
11 MR. : Okay. Thank you. 11 on the record.
12 BY MR. KUVIN: 12 THE WITNESS: Yes. I see it.
13 Q. All right. Do you know a gentleman by the 13 BY MR. KUVIN:
14 name of Janusz Banasiak, spelled J-a-n-u-s-z, 14 Q. Okay. All right. Do you know who
15 B-a-n-a-s-i-a-k? 15 Mr. Goldsmith is?
16 MR. : Instruct the witness not 16 MR. : I instruct the witness
17 to answer based on her Fifth Amendment 17 not to answer based on her privilege against
18 privilege. 18 self-incrimination.
19 THE WITNESS: On the instruction of, my 19 THE WITNESS: At the advice of counsel, I
20 lawyer, I must invoke my Fifth Amendment 20 must invoke my Fifth Amendment privilege.
21 privilege. 21 BY MR. KUVIN:
22 BY MR. KUVIN: 22 Q. Is this your handwriting on exhibit -- on
23 Q. Ma'am, isn't it true that you rented cars 23 the messages shown in Exhibit 4. Page II?
24 through Dollar Rent a Car for underage girls, girls 24 MR. : Same instruction.
25 under the age of 18? 25 THE WITNESS: At the advice of counsel, I
Page 126 Page 128
1 MR. Instruct the witness not 1 must invoke m Fifth Amendment privilege.
2 to answer based on the Fifth Amendment 2 MR. : Hold on a second. In
3 privilege. 3 MR. KUVIN: Yeah, check.
4 THE WITNESS: On the instruction of my 4 MR. : Okay. Can you repeat the
5 lawyer, I must invoke the Fifth Amendment 5 question again? Maybe I misheard it.
6 privilege. 6 Mr. Kuvin.
7 BY MR. KUVIN: 7 MR. KUVIN: Yeah, not a problem. Let me
8 Q. Did you rent any can from Dollar Rent a 8 lay a little foundation for it.
9 Car in West Palm Beach in the last five years? 9 MR. : That's okay. If you can
10 MR. Same instruction. 10 just ask the question again. I think I just
11 THE WITNESS: On the instruction of my 11 misheard what you were asking.
12 lawyer, I must invoke my Fifth Amendment 12 BY MR. KUVIN:
13 privilege. 13 Q. Is this your handwriting shown on the
14 BY MR. KUVIN: 14 messages which is Page II of Exhibit 4?
15 Q. Let's take a look at Page II. 15 A. No.
16 MR. If we can just -- let me 16 . Oka . Is this handwriting that of
17 go back, Mr. Kuvin, to clarify the prior two 17
18 questions. When you say, "did you rent," did 18 MR. KUVIN: -- I'm
19 you mean did she personally pay for the rental, 19 =? How do youwe it.
sorry. .
20 or was she, in any way, involved in arranging 20 MS. CADWELL: .
21 the rental? 21 MR. KUVIN: I knew somebody would know.
22 MR. KUVIN: The second part, in any way 22 MR. : Did we get a
23 involved in arranging for the rental of a 23 pronunciation, I'm sorry?
24 vehicle. 24 MR. KUVIN: Yes.
25 MR. That's how I inter-Feted 25
32 (Pages 125 to 128)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 32 of 47
EFTA_00065349
EFTA01246495
Page 129 Page 131
1 BY MR. KUVIN: 1 appear to be directed -- well, let me. let me back
2 Q. this the handwriting of 2 up.
3 if ou know? 3 Page 11 of Exhibit 4 appears to be a
4 MR. Hold on. Let me object to 4 message dated October 2nd. 2005. fromIn Do you
S the form in that it presumes she knows what 5 see that top left-hand corner?
6 handwriting is like or that she's 6 A. Yes.
/ ever known So before you ask the 7 Q. Okay. At 10:40 a.m. My question is: Did
8 question. try to clarify that. 8 you call and leave a message at 10:40 a.m. on
9 MR. KUVIN: Well, that's what I'm trying 9 October 2, 2005, stating: Mick and she
10 to find out. 10 can't come toda ?
11 BY MR. KUVIN: 11 MR. Instruct the witness not
12 O ourecognize this as the handwriting 12 to answer the question based on her Fifth
13 of . And it can be a yes or no. 13 Amendment privilege.
14 MR. My. my objection to the 14 THE WITNESS: On the instruction of my
15 form is that you, you haven't asked her whether 15 lawyer I must exercise my Fifth Amendment
16 she actually knows who is, or 16 privilege.
17 whether she would recognize her handwriting if 17 BY MR. KUVIN:
18 she saw it. 18 Q. Upside down at the bottom of Page I I is
19 MR. KUVIN: I would love to ask that 19 another phone message dated 10/1 of 2005. Appears
20 question if she'd answer it. 20 to be written to someone named M. Do you see
21 MR. Well, if she'll answer. 21 that?
22 that's a different question. But I think you 22 A. Yes.
23 need to ask it first otherwise this question is 23 Q. ou
ambiguous. 24 MR. : Is it written. I'm sorry.
25 MR. KUVIN: All right. 25 is it written to someone named or it
Page 130 Page 132
1 BY MR. KUVIN: 1 is s to be a phone call from a person named
2 Q. Not, not to beat a dead horse on the 2 .
3 point, do you know Mi 3 MR. KUVIN: From a person named
4 MR. I instruct the witness not 4 Thank you.
5 to answer. 5 BY MR. KUVIN:
6 THE WITNESS: On advice of counsel, I must 6 Q. Did you call someone, anyone on October 1
7 invoke my Fifth Amendment privilege. 7 of 2005 at 9:50 a.m., to confirm two people. one at
8 BY MR. KUVIN: 8 11:00 and one at 4:00 ..m.?
9 Q. Have you seen 9 MR. : Instruct the witness not
10 handwriting in the st? 10 to answer based on her Fifth Amendment
11 MR. • Objection to the form as 11 privilege against self-incrimination since this
12 previously stated. I'll instruct the witness 12 document was seized from Mr. Epstein's home.
13 not to answer. 13 THE WITNESS: At the instruction of my
14 THE WITNESS: On advice of counsel. I must 14 lawyer, I must invoke my Fifth Amendment
15 invoke my Fifth Amendment privilege. 15 privilege.
16 BY MR. KUVIN: 16 BY MR. KUVIN:
17 Q. Do you recd
recognize Pa e 11 in Exhibit 4 as 1/ Q. Are you the that's referred to in
18 the handwriting of . 18 these phone messa es that we've been looking at?
19 MR. Objection to the form for 19 MR. Instruct the witness not
20 the reasons previously stated many, many times, 20 to answer.
21 and I will instruct her not to answer. 21 THE WITNESS: On the instruction of my
22 THE WITNESS: At the advice of counsel, I 22 lawyer, I must invoke my Fifth Amendment
23 must invoke my Fifth Amendment privilege. 23 privilege.
24 BY MR. KUVIN: 24 BY MR. KUVIN:
25 Q. Did you ever see these messages that 25 Q. Let's skip Page 12 and go to Page 13 of
33 (Pages 129 to 132)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 33 of 47
EFTA_00065350
EFTA01246496
Page 133 Page 135
1 this same exhibit, if you would. Okay. 1 Fifth Amendment right.
2 Is that your handwriting on Pa e 13 2 BY MR. KUVIN:
3 which happens to be a note stating s 3 Q. Are you aware that Jeffrey Epstein would
4 coming"? 4 refer to "work" as performing naked massages for
5 MR. Okay. Hold on. Can you 5 him?
6 just show me what page you're looking at? 6 MR. : Object to the form of the
7 Okay. We skipped a page. 7 question. It's compound and I instruct the
8 THE WITNESS: No. 8 witness not to answer.
9 BY MR. KUVIN: 9 THE WITNESS: On advice of counsel. I wish
10 Q. Oka . Doyou recognize whose it is? 10 to invoke my Fifth Amendment right.
11 MR. Let me talk to you again. 11 BY MR. KUVIN:
12 BY MR. KUVIN: 12 Q. Let's take a look at the next page. Page
13 Q. If it's a yes, you might want to talk to 13 16. All right. If we look at not the message, the
14 him; if it's a no, it might be quick. 14 one message, but the note next to that it says:
15 A. No, no. Sony. 15 on Saturday with at 10:30.
16 Q. Let's look at Page 14, same exhibit. The 16 Do you know who is as referred
17 note on the right-hand side states, 'The girl from 17 to in this note?
18 St. Bart's got sick so she won't be able to come. 18 A. On the advice of counsel, I must invoke my
19 got message from her." First of all, just 19 Fifth Amendment right.
20 generally, do you see the note I'm referring to? 20 Q. Do you know who is as referred to in
21 A. Yes. 21 this note?
22 Q. Okay. Do you know what that is talking 22 A. On the advice of counsel. I must invoke my
23 about? 23 Fifth Amendment right.
24 A. No. 24 MR. GARCIA: I haven't heard the counsel
25 Q. Is that your handwriting? 25 give any advice.
Page 134 Page 136
1 A. No. 1 MR. : You don't know what we've
2 Q. Did Mr. Epstein obtain girls under the age 2 talked about outside of the room so...
3 of 16 from St. Ban's? 3 MR. GARCIA: Just changing the procedure
4 MR. Instruct the witness not 4 is all?
5 to answer. Object to the form of the question 5 MR. : I'm changing the procedure
6 in that it presumes that she knows who 6 for Mr. Kuvin.
7 Mr. Epstein is. 7 MR. KUVIN: I'm all happy for speed.
8 THE WITNESS: On advice of counsel, I must 8 BY MR. KUVIN:
9 invoke my Fifth Amendment privilege. 9 Q. All right. Let's look at Page 17 of
10 BY MR. KUVIN: 10 Exhibit 4. It appears to be a phone message at the
11 Q. All right. Let's take a look at the next 11 bottom dated 9/1/05 to Jeffrey from Jean-Luc. Let
12 page. Appears to be a note, phone message of -- I 12 me ask this: Do you rec tze the . hone number
13 can't read the date, 2005 to Jeffrey from 13 that's listed there of
14 Just generally, do you see what I'm 14 MR. : Instruct the witness not
15 talking about so we're on the same page here? 15 to answer based on her Fifth Amendment
16 A. Yes. 16 privilege and self-incrimination.
17 Q. Okay. Do you know who is? 17 THE WITNESS: On advice of counsel. I must
18 A. On the advice of counsel, I wish to invoke my 18 invoke my Fifth Amendment right.
19 Fifth Amendment right. 19 MR. KUVIN: Let me show this one to the
20 Q. All right. The note appears to say: She 20 camera if I could. If you could focus on the
21 called again, if she could work any time Monday 21 bottom message for me.
22 through Friday. 22 THE VIDEOGRAPHER: I can't really read
23 Do you know what that message 23 that.
24 pertains to? 24 MR. KUVIN: Do I need to tilt it?
25 A. On advice of counsel. I wish to invoke my 25 THE VIDEOGRAPHER: I think you need to
34 (Pages 133 to 136)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 34 of 47
EFTA_00065351
EFTA01246497
Page 137 Page 139
1 bring the whole paper up closer. 1 Do you -- first of all, do you see
2 MR. KUVIN: Towards you? 2 that in front of you? Are we talking about the same
3 THE VIDEOGRAPHER: Yes, towards the lens 3 thing here?
4 MR. KUVIN: Just pass that up so we can 4 A. Yes.
5 get a good shot of the bottom message. 5 Q. Okay. Do you know who " " is
6 THE VIDEOGRAPHER: Up a little higher. 6 referring to in this note?
7 please. Let it focus. That's good. Go out. 7 MR. Instruct the witness not
8 Okay. 8 to answer based on her Fifth Amendment
9 MR. KUVIN: All right. Thank you veiy 9 privilege.
10 much. 10 THE WITNESS: On the instruction of my
11 BY MR. KUVIN: 11 lawyer, I must invoke my Fifth Amendment
12 Q. The message appears to read: 9/1/2005 to 12 privilege.
13 Jeffrey, 8:08, Jean-Luc. telephone. He has a 13 BY MR. KUVIN:
14 teacher for you to teach you how to speak Russian. 14 Q. Does your handwriting appear anywhere on
15 She is two times eight years old. not blonde. 15 Page 19 here --
16 Lessons are free and you can have first today if you 16 A. On the —
17 call. Do you know what that message is referring 17 Q. -- on either note?
18 to? 18 A. On the advice of my lawyer. I must invoke my
19 MR. Instruct the witness not 19 Fifth Amendment privilege.
20 to answer the question. Object to the form of 20 Q. Is that your handwriting on the left in
21 the question because in that it presumes she 21 the note that I just read that says:
22 has knowledge of either Jeffrey or Jean-Luc or 22 11:00 am.?
23 that phone number. 23 MR. Same instruction.
24 THE WITNESS: On the advice of counsel, I 24 THE WITNESS: On the instruction of my
25 wish to invoke my Fifth Amendment right. 25 lawyer, I must invoke my Fifth Amendment
Page 138 Page 140
1 BY MR. KUVIN: 1 privilege.
2 Q. Would you agree with me that this message 2 BY MR. KUVIN:
3 is a message from Jean-Luc, that he's providing a 3 Q. All right. Let's take a look at the next
4 I6-year-old irl to Jeffre Epstein? 4 page which is Page 20. Is that your handwriting on
5 MR. : Object to the form in that 5 this paper?
6 it calls for speculation and also assumes facts 6 MR. : Let me talk to her.
7 as to Mr. Jean-Luc and Mr. Epstein; therefore, 7 THE WITNESS: On the advice of my lawyer,
8 I instruct her to invoke her Fifth Amendment 8 I wish to invoke my Fifth Amendment privilege.
9 privilege. 9 BY MR. KUVIN:
10 THE WITNESS: On the instruction from my 10 Q. Is this a list of girls that were being
11 lawyer, I must invoke my Fifth Amendment 11 provided to Jeffre E rein for sex?
12 privilege. 12 MR. : Objection to the form, the
13 BY MR. KUVIN: 13 standing objection previously stated. I will
14 Q. Skip the next page if you would, and the 14 instruct the witness not to answer that
15 following page will be Page 19 of Exhibit 4. It 15 question.
16 should be two mess es. 16 THE WITNESS: On the instruction of my
17 MR. Show me what you're 17 lawyer, I must invoke my Fifth Amendment
18 looking at. 18 privilege.
19 MR. KUVIN: And the top left one says, 19 BY MR. KUVIN:
20 "Friday." 20 Q. Did Jeffrey Epstein not like girls that
21 MR. : Thank you. 21 had tattoos?
22 BY MR. KUVIN: 22 MR. : Objection to the form
23 Q. The message on the left-hand side that 23 based on the standing objection and the same
24 appears to be. have a date of 4/8/05 and a number 7 24 instruction.
25 written on it. It says: 11:00 a.m. 25 THE WITNESS: On the instruction of my
35 (Pages 137 to 140)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 35 of 47
EFTA_00065352
EFTA01246498
Page 141 Page 143
1 lawyer, I must invoke my Fifth Amendment 1 MR. Same instruction.
2 privilege. 2 THE WITNESS: On the advice of my lawyer.
3 BY MR. KUVIN: 3 I must choose to invoke my Fifth Amendment
4 Q. Did Jeffrey Epstein not like girls that 4 right.
5 had blonde hair? 5 BY MR. KUVIN:
6 MR. : Standing objection and the 6 Q. Doyou know who is?
7 same instruction. 7 MR. Same instruction.
8 THE WITNESS: On the instruction of my 8 THE WITNESS: On the advice of my lawyer.
9 lawyer, I must invoke my Fifth Amendment 9 I wish to invoke my Fifth Amendment privilege.
10 privilege. 10 BY MR. KUVIN:
11 BY MR. KUVIN: 11 Q. Do ou know who M. is?
12 Q. Take a look at the next page, if you 12 MR. Let me consult for a
13 would. This one. 13 second.
14 MR. : Thank you. 14 MR. KUVIN: Yep.
15 BY MR. KUVIN: 15 (A discussion was held off the record.)
16 Q. Is that your handwriting? 16 MR. Mr. Kuvin, I'm just asking
17 A. On instruction of my lawyer, I must invoke m) 17 you to clarify. Are you asking if she's ever
18 Fifth Amendment privilege. 18 heard the name of these people or whether she's
19 Q. Is this an additional -- on Page 21, is 19 actually ever met someone she knows to have
20 this an additional list of girls that were being 20 that name?
21 provided to Jeffre E stein for sex? 21 MR. KUVIN: Second part, whether she knows
22 MR. : I'm sorry. Did we change 22 someone personally by that name. I don't want
23 to a different page or the same page? 23 to know what somebody may have told her.
24 MR. KUVIN: The same page. 24 MR. Sure.
25 25 MR. KUVIN: Certainly not attorneys or
Page 142 Page 144
1 BY MR. KUVIN: 1 anything like that. I want to know whether she
2 Q. Is this an additional list of girls that 2 has any 'ersonal knowledge of someone by the
3 were -- 3 name of
4 MR. : Thank you. 4 MR. : Okay. Based on our
5 BY MR. KUVIN: 5 conversation, she can answer or not answer the
6 Q. -- being provided to Jeffrey Epstein for 6 question.
7 sex? 7 THE WITNESS: On the advice of my lawyer,
8 MR. : Objection to the form. 8 I choose to invoke my Fifth Amendment right.
9 The same objection and the same instruction. 9 MR. KUVIN: Okay. It's like a
10 THE WITNESS: On the instruction of my 10 cough/sneeze.
11 lawyer, I must invoke my Fifth Amendment 11 MR. GARCIA: I tried to stifle it. but --
12 privilege. 12 MR. GOLDBERGER: You got it all over me.
13 BY MR. KUVIN: 13 Just kidding.
14 Q.Sa 2. Note on fl,ier appears to 14 MR. GARCIA: You don't want to get this.
15 say: has a friend, • that would like 15 I've had if for a couple of days.
16 to work tonight. Do you know who is refer, 16 MR. KUVIN: What number are we on? 13.
17 referring to in that note? 17 That's why I always leave some with numbers
18 MR. : Instruct the witness not 18 still on there to show the picture to the
19 to answer based on the privilege against 19 camera.
20 self-incrimination. 20 Exhibit 13 will be pursuant to
21 THE WITNESS: On the advice of my lawyer, 21 confidentiality and the identities of the
22 I wish to assert my Fifth Amendment right. 22 girls involved in this case.
23 BY MR. KUVIN: 23 MR. As I presume the prior
24 Q. Do you know who is referring to in 24 questions were as well.
25 that note? 25 MR. KUVIN: Yes. Absolutely. This is
36 (Pages 141 to 1 4 4)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 36 of 47
EFTA_00065353
EFTA01246499
Page 145 Page 147
1 different because it's an exhibit. 1 in Exhibit 13 came to Mr. Epstein's home when she
2 MR. : Agreed. 2 was only 115 ears old?
3 MR. KUVIN: Okay. 3 MR. : Objection to the form
4 (Plaintiff's Exhibit No. 13 was marked for 4 based on the standing objection, also
5 identification 5 speculation as to any age and instruct the
6 MR. We're moving off of 6 witness not to answer.
7 Exhibit 12? 7 THE WITNESS: On the advice of my lawyer.
8 MR. KUVIN: Yes. 8 I must choose to exercise my Fifth Amendment
9 MR. I was looking at the next 9 right.
10 exhibit. 10 BY MR. KUVIN:
11 MR. KUVIN: We're done with the trash. 11 Q. Do you agree with me that when you
12 MR. : Okay. 12 arranged to have this girl come to Mr. Epstein's
13 BY MR. KUVIN: 13 home, that ou were aware that she was IS years old?
14 Q. Just take a look at Exhibit 13. Do you 14 MR. : Objection to the form. It
15 recognize the girl in that photograph? 15 is compound. It assumes facts that are not
16 A. On the advice of my lawyer, I must choose to 16 admitted by this witness, and it's ambiguous in
17 exercise my Fifth Amendment privilege. 17 that regard, and therefore I instruct her not
18 Q. Do you agree with me that that girl shown 18 to answer.
19 in that photo his ? 19 THE WITNESS: On the advice of my lawyer,
20 MR. : Objection to the form for 20 I must choose to exercise my Fifth Amendment
21 the reasons previously stated, causes her to 21 right.
22 speculate, and I instruct her not to answer 22 BY MR. KUVIN:
23 based on her Fifth Amendment privilege. 23 Q. Do you agree that when this girl was
24 THE WITNESS: On the advice of my lawyer, 24 brought to Mr. Epstein's home, that she performed a
25 I must choose to exercise my Fifth Amendment 25 massage on Mr. Epstein while he was naked?
Page 146 Page 148
i privilege. 1 MR. Objection to the form,
2 BY MR. KUVIN: 2 standing objection. The question assumes that
3 Q. Do you agree with me that you arranged to 3 this witness has any knowledge of
4 have the girl shown in Exhibit 13 be brought to 4 Jeffrey Epstein or whether this person ever
5 Mr. Epstein's home for sex with Mr. Epstein? 5 came to Mr. Epstein's home. It is therefore
6 MR. : Objection to the form as 6 ambiguous, and I instruct her not to answer.
t compound. and also the standing objection, and 7 THE WITNESS: On the instruction of my
8 instruct the witness not to answer. 8 lawyer, I must choose to exercise my Fifth
9 THE WITNESS: On the advice of my lawyer, 9 Amendment right.
10 I must choose to exercise my Fifth Amendment 10 BY MR. KUVIN:
11 privilege. 11 Q. Do you agree with me that this girl shown
12 BY MR. KUVIN: 12 in Exhibit 13 was 15 years old at the time she was
13 Q. Would you agree with me that the girl 13 asked by Jeffrey E stein to remove her clothes?
14 shown in Exhibit 13 did, in fact, come to 14 MR. Objection to the form. It
15 Mr. Epstein's home in 2005? 15 requires speculation and assumes facts relating
16 MR. : Same objection previously 16 to Mr. Epstein and events that may have
17 stated. It's compound as to the date, place, 17 occurred which this witness has no knowledge
18 person, and also presumes knowledge of 18 and has not admitted any knowledge. And I
19 Mr. Epstein, so I would instruct her not to 19 instruct her not to answer.
20 answer. 20 THE WITNESS: On advice of counsel I must
21 THE WITNESS: On the advice of my lawyer, 21 choose to exercise my Fifth Amendment right.
22 I must choose to exercise my Fifth Amendment 22 BY MR. KUVIN:
23 privilege. 23 Q. Do you agree that you described for the
24 BY MR. KUVIN: 24 girl as shown in Exhibit 13 -- bate way. her name
25 Q. Do you agree with me that the pin shown 25 is.. --that you described to M. how to set up
37 (Pages 145 to 1 48)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 37 of 47
EFTA_00065354
EFTA01246500
Page 149 Page 151
1 the massage table in Jeffrey Epstein's bathroom? 1 counsel, I must choose to invoke my Fifth
2 MR. : Objection to the form for 2 Amendment right.
3 the reasons previously stated, and instruct the 3 BY MR. KUVIN:
4 witness not to answer. 4 Q. Do yotagree with me that during the
5 THE WITNESS: On the advice of counsel, I 5 massage that M. was forced to give to Mr. Epstein.
6 must choose to exercise my Fifth Amendment 6 that he touched her between her legs?
7 right. 7 MR. : Objection to the form. It
8 BY MR. KUVIN: 8 is ambiguous including the term "forced." It
9 Q. Do you agree that you showed M. where 9 assumes facts that this witness has not
10 the massage oils are kept in Jeffrey Epstein's 10 admitted or that this witness has not
11 bathroom in his home? 11 acknowledged any personal knowledge and
12 MR. : Objection to the form in 12 instruct her not to answer.
13 that it assumes knowledge of Jeffrey Epstein, 13 THE WITNESS: On the instruction of my
14 knowledge that this person was ever at 14 lawyer, I must therefore invoke my Fifth
15 Jeffrey Epstein's home none of which is 15 Amendment right.
16 admitted or acknowledged by this witness, and 16 BY MR. KUVIN:
17 instruct the witness not to answer. 17 Q. Do ou agree with me that Mr. Epstein
18 THE WITNESS: On advice of counsel I must 18 touched between her legs?
19 choose to invoke my Fifth Amendment right. 19 MR. : Objection to the form and
20 BY MR. KUVIN: 20 the question presumes knowledge of
21 Q. Do you agree that you showed.., as 21 Jeffrey Epstein. Instruct the witness not to
22 shown in Exhibit 13. where Mr. Epstein kept the 22 answer.
23 vibrators in his bathroom at his house? 23 THE WITNESS: On the instruction of my
24 MR. : Same objection as stated 24 lawyer, I must choose to invoke my Fifth
25 to the previous question as to the form of the 25 Amendment right.
Page 150 Page 152
1 question, and instruct the witness not to 1 BY MR. KUVIN:
2 answer. 2 Q. Do you agree with me that El. told
3 THE WITNESS: On advice of counsel, I must 3 Mr. Epstein to stop touching him there -- touching
4 choose to exercise my Fifth Amendment right. 4 her there?
5 BY MR. KUVIN: 5 MR. Same objection previously
6 Q. Do you agree with me that in 2005 you 6 stated to the last question and instruct the
7 knowingly provided ■., a 15-year-old girl, to 7 witness not to answer.
8 Mr. Epstein so that he could sexually abuse her? 8 THE WITNESS: On the instruction of my
9 MR. Objection to the form as 9 lawyer, I must invoke my Fifth Amendment right.
10 to it calling for a legal conclusion as to 10 BY MR. KUVIN:
11 assuming multiple facts, since therefore 11 Q. Do you agree with me that you have
12 compound and instruct the witness not to 12 personal knowledge that after telling Mr. Epstein to
13 answer. 13 stop touching her between her legs, Mr. Epstein
14 THE WITNESS: On advice of counsel, I must 14 apologized and then touched her again between her
15 choose to invoke my Fifth Amendment right. 15 legs?
16 BY MR. KUVIN: 16 MR. Objection to the form and
17 Q. Do you agree with me that M. was given 17 the standing objection previously stated as
18 to Mr. Epstein to alarm a naked massage of him 18 well as the question is compound and instruct,
19 while he touched ? 19 and ambiguous. and I instruct the witness not
20 MR. Objection to the form. 20 to answer.
21 Standing objection and other facts that are 21 THE WITNESS: On the instruction of my
22 assumed in the question to which this witness 22 lawyer, I must choose to exercise my Fifth
23 does not admit, and therefore the witness is 23 Amendment right.
24 instructed not to answer the question. 24 BY MR. KUVIN:
25 THE WITNESS: On the instruction of my 25 Q. Do you agree with me that Mr. Epstein
38 (Pages 149 to 152)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 38 of 47
EFTA_00065355
EFTA01246501
Page 153 Page 155
1 specifically targeted young underage girls that were 1 Mr. Epstein naked massa es?
2 economically disadvantaged for his own sexual 2 MR. Object to the form. It's
3 pleasure? 3 multiple layers of compound questioning,
4 MR. Objection to the form. 4 includes terms like "enterprise" that are
5 Several of the terms are ambiguous and it 5 ambiguous and may call for a legal conclusion
6 assumes knowledge of Mr. Epstein and his 6 that this witness is not competent to give. I
7 habits, and therefore, I instruct the witness 7 instruct the witness not to answer.
8 not to answer the question. 8 THE WITNESS: On the instruction of my
9 THE WITNESS: On the instruction of my 9 lawyer, I must choose to exercise my Fifth
10 lawyer, I must choose to exercise my Fifth 10 Amendment right.
11 Amendment right. 11 BY MR. KUVIN:
12 BY MR. KUVIN: 12 Q. Do you agree with me that there is a
13 Q. Do you agree with me that Mr. Epstein 13 staircase leading out of Mr. Epstein's kitchen in
14 would pay these girls 2 to $300 for this sexual 14 his home on Palm Beach?
15 massage? 15 MR. Objection to the form,
16 MR. Objection to the form. 16 presumes knowledge of Mr. Epstein or his home
17 Standing objection and assumes knowledge of 17 on Palm Beach. Instruct the witness not to
18 Mr. Epstein and his practices, so therefore, I 18 answer.
19 instruct the witness not to answer. 19 THE WITNESS: On the instruction of my
20 THE WITNESS: On the instruction of my 20 lawyer, I must choose to invoke my Fifth
21 lawyer, I must choose to invoke my Fifth 21 Amendment right.
22 Amendment right. 22 BY MR. KUVIN:
23 BY MR. KUVIN: 23 Q. Do you agree with me that when M. was
24 Q. Do you agree with me that you handed M. 24 brought to Mr. Epstein's bathroom, that he walked
25 $200? 25 out of the shower wearing a towel?
Page 154 Page 156
1 MR. : Objection to the form, 1 MR. Objection to the form in
2 instruct the witness not to answer. 2 that it presumes knowledge of... that Ms.
3 THE WITNESS: On the instruction of my 3 .. was ever at Mr. Epstein's home, that this
4 lawyer, I must choose to invoke my Fifth 4 witness knows anything about Mr. Epstein or his
5 Amendment right. 5 home; therefore, the question is compound and
6 BY MR. KUVIN: 6 ambiguous, and I instruct her not to answer.
7 Q. And just so we're clear, do you agree with 7 THE WITNESS: On the instruction of my
8 me that you handed ill. in 2005, $200 after she was 8 lawyer, I must choose to assert my Fifth
9 in the bathroom with Mr. Epstein at his home? 9 Amendment right.
10 MR. : Objection to the form. 10 BY MR. KUVIN:
11 The question_wsumes knowledge of a person by 11 Q. Do you know M.?
12 the name of M., therefore I instruct the 12 A. On the instruction of my lawyer, I must choose
13 witness not to answer the question. 13 to assert my Fifth Amendment privilege.
14 THE WITNESS: On the instruction of my 14 Q. Did you have . -- excuse me, strike
15 lawyer, I must choose to invoke my Fifth 15 that. Did you tell to come over to
16 Amendment right. 16 Mr. Epstein's home to ive Mr. Epstein a massage?
17 BY MR. KUVIN: 17 MR. Objection to the form.
18 Q. Do you agree with me that Mr. Epstein had 18 It's compound. Stand objection. standing
19 a plan -- let me rephrase that. 19 objection, sorry. Instruct the witness not to
20 Do you agree with me that Mr. Epstein 20 answer.
21 had an enterprise, a sexual enterprise, established 21 THE WITNESS: On the instruction of my
22 by which young girls would be brought to his home, 22 lawyer, I must choose to invoke my Fifth
23 introduced to you, where you would then set up a 23 Amendment right.
24 massage table. show them where the oils were, and 24 BY MR. KUVIN:
25 have these young, girls under the age of 18, give 25 Q. Did you introduce M. to Jeffrey Epstein?
39 (Pages 153 to 156)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 39 of 47
EFTA_00065356
EFTA01246502
Page 157 Page 159
1 MR. Objection to the form, 1 BY MR. KUVIN:
2 standing objection. Instruct the witness not 2 Q. Would you agree with see that you visited
3 to answer. 3 a man by the name of Jeffrey Epstein while he was in
4 THE WITNESS: On the instruction from my 4 jail in Palm Beach Count ?
5 lawyer, I must choose to invoke my Fifth 5 MR. : Objection to the form,
6 Amendment right. 6 standing objection. Assumes other facts that
7 BY MR. KUVIN: 7 this witness has not acknowledged, and instruct
8 Q. Do ou agree with me that Mr. Epstein 8 her not to answer.
9 threatened with h sical violence? 9 THE WITNESS: Upon instruction from the
10 MR. Objection to the form, the 10 lawyer, I must choose to invoke my Fifth
11 standing objection, as well as ambiguous as to 11 Amendment right.
12 the term "threaten." Instruct the witness not 12 BY MR. KUVIN:
13 to answer. 13 Q. Do you agree that you arranged to have
14 THE WITNESS: Upon instruction from my 14 come to Jeffrey Epstein's home for a nude
15 lawyer, I must choose to invoke my Fifth 15 massage?
16 Amendment right. 16 MR. Objection to the form.
17 BY MR. KUVIN: 17 standing objection previously stated.
18 OI Do you agree with me that Jeffrey Epstein 18 THE WITNESS: On the instruction of my
19 told M. that if she talks to anyone about what had 19 lawyer, I must choose to invoke my Fifth
20 occurred at his home, bad things would happen to 20 Amendment right.
21 her? 21 BY MR. KUVIN:
22 MR. Objection to the form, 22 Q. Do you agree that has been to
23 it's compound, and a standing objection. Also 23 358 El Brillo Wa on at least two occasions?
24
24
25
assumes numerous other facts that this witness
has not acknowledge nor admitted, and therefore 25
MR.
assumes knowledge of .: Objection to the form. It
and of 358 El Brillo
Page 158 Page 160
I instruct her not to answer. 1 Way, to which the witness has not acknowledged.
2 THE WITNESS: On the instruction from my 2 and instruct the witness not to answer.
3 lawyer, I must choose to invoke my Fifth 3 THE WITNESS: On the instruction of my
4 Amendment privilege. 4 lawyer. I must choose to invoke my Fifth
5 BY MR. KUVIN: 5 Amendment right.
6 Q. Would you agree with me that in 2005 that 6 BY MR. KUVIN:
7 Jeffrey Epstein was between the ages of 45 and 55 7 Q. Do you agree that Mr. Epstein has an
8 years old? 8 odd-shaped ems?
MR. : Objection to the form. 9 MR. Objection to the form of
10 Standing objection as to any knowledge of 10 the question. It assumes knowledge of
11 Jeffrey Epstein. Instruct the witness not to 11 Mr. Epstein. It assumes knowledge of
12 answer. 12 Mr. Epstein's body parts, and instruct the
13 THE WITNESS: The instruction of my 13 witness not to answer.
14 lawyer, I must choose to assert my Fifth 14 THE WITNESS: On advice -- on the
15 Amendment right. 15 instruction of my lawyer. I must choose to
16 BY MR. KUVIN: 16 invoke my Fifth Amendment right.
17 Q. Would you agree with me that 17 BY MR. KUVIN:
18 Jeffrey Epstein has tremendous wealth? 18 Q. Have ou seen Jeffrey Epstein's penis?
19 MR. : Objection to the form as 19 MR. Objection to the form. and
20 stated in the previous question, and instruct 20 we're getting awfully close to a line here. Mr.
21 the witness not to answer. 21 Kuvin.
22 THE WITNESS: On the instruction from the 22 MR. KUVIN: I think the identity of
23 lawyer, I must choose to invoke my Fifth 23 something that 14 and I5-year-old girls
24 Amendment right. 24 have seen is directly relevant to the issues in
25 25 this case. If the/ can describe it. then
40 (Pages 157 to 160)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 40 of 47
EFTA_00065357
EFTA01246503
Page 161 Page 163
1 obviously it's important because they are the 1 MR. KUVIN: The Epstein matter.
2 only ones that are answering questions in this 2 MR. : I instruct the witness not
3 case. 3 to answer. Objection to the form as compound
4 MR. Well, people have rights. 4 and assumes the existence of Mr. Epstein which,
5 People will assert their rights, and I am just 5 again, we are not acknowledging, and therefore
6 telling you, were getting close to a line 6 am instructing her not to answer.
7 here. 7 THE WITNESS: On the instruction of my
8 MR. KUVIN: I think I'm being 8 lawyer, I choose to assert my Fifth Amendment
9 respectful -- 9 right.
10 MR. You haven't crossed it yet 10 BY MR. KUVIN:
11 because I'm still here, but I'm just warning 11 Q. Are you aware that Mr. Epstein negotiated
12 you. 12 for your immunity from prosecution in the
13 Instruct the witness not to answer 13 non-prosecution agreement that was entered into with
14 any question that presumes existence or 14 the United States Attorney's Office for the Southern
15 any knowledge of Jeffrey Epstein or any of 15 District of Florida?
16 his body pans. 16 MR. : Again, objection to the
17 MR. KUVIN: Okay. 17 form for the reasons previously stated as to
18 THE WITNESS: On the instruction of my 18 the standing objection and instruct her not to
19 lawyer, I must choose to assert my Fifth 19 answer.
20 Amendment right. 20 THE WITNESS: On the instruction of my
21 BY MR. KUVIN: 21 lawyer, I must choose to invoke my Fifth
22 Q. Do you know whether or not Mr. Epstein has 22 Amendment right.
23 any identifying characteristics to any of his 23 BY MR. KUVIN:
24 private genitalia? 24 Q. Do you agree with me that was
25 MR. Objection to the form for 25 emotionally traumatized as a result of the incidents
Page 162 Page 164
1 the reason previously stated, because it 1 that occurred Jeffrey E stein's home in 2005?
2 presumes that she has any knowledge of who 2 MR. : Obj=ion to the form. It
3 Jeffrey Epstein is or what his body parts look 3 assumes any knowledge ofM. or any incidents
4 like, and I would instruct her not to answer. 4 that would have occurred at a home purporting
5 THE WITNESS: On the instruction of my 5 to belong to a person by the name of Jeffrey
6 lawyer, I must choose to assert my Fifth 6 Epstein, and instruct her not to answer.
7 Amendment right. 7 THE WITNESS: Upon instruction from my
8 BY MR. KUVIN: 8 lawyer, I must choose to invoke my Fifth
9 Q. Have you heard anyone other than your 9 Amendment right.
10 lawyers that have described what any of 10 BY MR. KUVIN:
11 Mr. Epstein's bod arts look like? 11 Q. Do you agree with me that ■. was
12 MR. • Objection to the form. It 12 emotionally traumatized as a result of the incidents
13 is irrelevant what she's heard from other 13 that occurred at Jeffrey E stein's home?
14 people, and again, it presumes facts that she's 14 MR. : Same objection as to the
15 not acknowledged. It is compound, and it is 15 previous question, and instruct the witness not
16 harassing at this point. 16 to answer.
17 THE WITNESS: On instruction of my lawyer. 13 THE WITNESS: On the instruction of my
18 I must choose to invoke my Fifth Amendment 18 lawyer, I must choose to invoke my Fifth
19 right. 19 Amendment privilege.
20 BY MR. KUVIN: 20 BY MR. KUVIN:
21 Q. Were you consulted with respect to the 21 Q. Do ou know Jane Doe No. 102?
22 non-prosecution agreement that was entered into with 22 MR. : Instruct the witness not
23 the United States Attorneys Office for the Southern 23 to answer based on Fifth Amendment privilege.
24 District of Florida as it relates to this case? 24 THE WITNESS: On instruction of my lawyer,)
25 MR. Which case? 25 I must choose to invoke my Fifth Amendment
41 (Pages 161 to 164)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 41 of 47
EFTA_00065358
EFTA01246504
Page 165 Page 167
1 right. 1 in New York?
2 BY MR. KUVIN: 2 MR. Instruct the witness not
3 Q. Have you known Jeffrey Epstein to keep 3 to answer based on the Fifth Amendment
4 underage, under the a e of IS, sex slaves? 4 privilege.
5 MR. : Objection to the form both 5 THE WITNESS: On the instruction of my
6 as to ambiguity as to what you mean by "sex 6 lawyer, I choose to invoke my Fifth Amendment
7 slaves," and "keep," also the standing 7 right.
8 objection as to any knowledge of Mr. Epstein 8 BY MR. KUVIN:
9 and instruct the witness not to answer. 9 Q. Are you aware that various underage girls
10 THE WITNESS: On the instruction of my 10 brought in from out of the country live at 301 East
11 lawyer, I must choose to invoke my Fifth 11 66th Street?
12 Amendment right. 12 MR. Objection to the form.
13 BY MR. KUVIN: 13 It's compound. and instruct the witness not to
14 Q. Where do most of the models come from that 14 answer.
15 are part of MC uared Modeling Agency? 15 THE WITNESS: On the instruction from my
16 MR. : Objection to the form. It 16 lawyer, I must choose to invoke my Fifth
17 assumes knowledge of an entity by the name of 17 Amendment right.
18 MC Squared Modeling which the witness has not 18 BY MR. KUVIN:
19 acknowledged and therefore I instruct her not 19 Q. You've stayed at that address before, have
20 to answer, and the question is compound. 20 you not?
21 THE WITNESS: On the instruction of my 21 MR. Instruct the witness not
22 lawyer, I must choose to invoke my Fifth 22 to answer.
23 Amendment privilege. 23 THE WITNESS: On the instruction of my
24 BY MR. KUVIN: 24 lawyer, I must choose to invoke my Fifth
25 Q. Who gets visas for the models at MC 25 Amendment right.
Page 166 Page 168
1 Squared, if ou know? 1 BY MR. KUVIN:
2 MR. : Same, same objection as to 2 Q. You've stayed there hundreds of times,
3 the previous question, same instruction. 3 have you, hundreds of times have you not?
4 THE WITNESS: On the instruction of my 4 MR. Instruct the witness not
5 lawyer, I must choose to invoke my Fifth 5 to answer.
6 Amendment right. 6 THE WITNESS: On instruction from my
7 BY MR. KUVIN: 7 lawyer, I must choose to invoke my Fifth
8 Q. Do you work with Jeffrey Epstein to get 8 Amendment right.
9 visas for out-of-the-country models or models that 9 BY MR. KUVIN:
10 are -- strike that. 10 Q. Are you aware that Mr. Epstein obtains
11 Do you work with Jeffrey Epstein to 11 visas for girls from out of the country to work as
12 get visas for girls that are underage and bring them 12 models and then ostitutes them out?
13 into the United States so that they can work as 13 MR. Objection to the form of
14 models for MC S, uared? 14 the question in that it is ambiguous and it
15 MR. : Objection to the form and 15 assumes numerous facts that have not
16 assumes knowledge as to Mr. Epstein and as to 16 acknowledged that this witness has any
17 MC Squared and other matters that are not 17 knowledge of, and the term "prostitutes them
18 admitted or acknowledged by this witness. The 18 out" is ambiguous, so I would instruct her not
19 question is compound. I would instruct her not 19 to answer the question.
20 to answer. 20 THE WITNESS: On the instruction of my
21 THE WITNESS: On the instruction from my 21 lawyer, I must choose to invoke my Fifth
22 lawyer. I must choose to invoke my Fifth 22 Amendment right.
23 Amendment right. 23 BY MR. KUVIN:
24 BY MR. KUVIN: 24 Q. You know what Radar Online is. do you not?
25 Q. Do you know who owns 301 East 66th Street 25 MR. Instruct the witness not
42 (Pages 165 to 168)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 42 of 47
EFTA_00065359
EFTA01246505
Page 169 Page 171
1 to answer the question based on her Fifth 1 THE WITNESS: On the instruction from my
2 Amendment privilege. 2 lawyer, I choose to invoke my Fifth Amendment
3 THE WITNESS: On the instruction of my 3 right.
4 lawyer, I must choose to invoke my Fifth 4 BY MR. KUVIN:
5 Amendment right. 5 Q. Would you agree with me that Jeffrey
6 BY MR. KUVIN: 6 Epstein has a list of underage girls that live
7 Q. In fact, you were around when 7 within a close proximity to all of his different
8 Jeffrey Epstein bou ht Radar Online, were you not? 8 homes in eve different state?
9 MR. : Objection to the form, 9 MR. : Objection to the form in
10 standing objection as to any knowledge of 10 that it assumes Mr. Epstein has homes in every
11 Jeffrey Epstein or of Radar Online, and 11 single state and that she knows who Mr. Epstein
12 instruct the witness not to answer. 12 is, and therefore I instruct her not to answer.
13 THE WITNESS: On the instruction from my 13 THE WITNESS: On advice of my lawyer. I
14 lawyer, I must choose to invoke my Fifth 14 must choose to invoke my Fifth Amendment right.
15 Amendment right. 15 BY MR. KUVIN:
16 BY MR. KUVIN: 16 Q. You're aware Mr. Epstein has a home in New
17 Q. Are you aware that Jeffrey Epstein 17 York. right?
18 accessed or obtained underage girls through his 18 MR. : Instruct the witness not
19 Radar connection? 19 to answer, and standing objection of knowledge
20 MR. : Same objection as 20 of Mr. Epstein.
21 previously stated to the last question and same 21 THE WITNESS: On the instruction of my
22 instruction. 22 lawyer, I must invoke my Fifth Amendment right.
23 THE WITNESS: On the instruction from my 23 BY MR. KUVIN:
24 lawyer, I must choose to invoke my Fifth 24 Q. Are you aware that he has a home in New
25 Amendment privilege. 25 Mexico?
Page 170 Page 172
1 BY MR. KUVIN: 1 MR. By he, you mean
2 Q. How many different properties does 2 Mr. Epstein?
3 Jeffrey Epstein own? 3 MR. KUVIN: Yeah.
4 MR. Objection to the form. 4 MR. Got to make sure the
5 standing objection. Instruct the witness not 5 question is clear.
6 to answer. 6 MR. KUVIN: Yes.
7 THE WITNESS: On the instruction of my 7 MR. Standing objection to the
8 lawyer, I must choose to invoke my Fifth 8 form and instruct the witness not to answer.
9 Amendment right. 9 THE WITNESS: On the instruction from my
10 BY MR. KUVIN: 10 lawyer, I must choose to invoke my Fifth
11 Q. You've been to all of Jeffrey Epstein's 11 Amendment privilege.
12 home, have ou not? 12 BY MR. KUVIN:
13 MR. Same objection as 13 Q. Are you aware he has a home in the U.S.
14 previously stated to the last question. Same 14 Virgin Islands?
15 instruction. 15 MR. Same instruction, same
16 THE WITNESS: On the instruction from my 16 objection.
17 lawyer, I must invoke my Fifth Amendment right. 17 THE WITNESS: On the instruction of my
18 BY MR. KUVIN: 18 lawyer, I must choose to invoke my Fifth
19 Q. You agree with me that Jeffrey Epstein 19 Amendment right.
20 keeps a list of girls in the nearby areas around all 20 BY MR. KUVIN:
21 of his homes and ro rties? 21 Q. And isn't it true that you kept a list of
22 MR. Objection to the form, for 22 underage girls that could service, in other words,
23 the standing objection as well as ambiguous as 23 give Mr. Epstein naked massages in every place that
24 to "nearby." and "all of his properties," so I 24 he has one of those homes I just described?
25 instruct the witness not to answer. 25 MR. Same objection as
43 (Pages 169 to 172)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 43 of 47
EFTA_00065360
EFTA01246506
Page 173 Page 175
1 previously stated, the standing objection and 1 to Mr. Epstein's house on Palm Beach. you were aware
2 instruct her not to answer. 2 that they were brought so that Mr. Epstein could
3 THE WITNESS: On the instruction of my 3 molest them, correct?
4 lawyer, I must choose to invoke my Fifth 4 MR. : Objection to the form as
5 Amendment right. 5 to knowledge of Mr. Epstein, as to knowledge of
6 BY MR. KUVIN: 6 any home on Palm Beach. and ambiguous as to the
7 Q. Now, you're also aware, are you not, that 7 term "molest," and instruct the witness not to
8 Jeffrey Epstein would pay other girls to bring 8 answer.
9 additional underage girls to him for naked massages, 9 THE WITNESS: On the instruction from my
10 are you not? 10 lawyer. I must choose to invoke my Fifth
11 MR. : Standing objection and 11 Amendment right.
12 instruct the witness not to answer. 12 BY MR. KUVIN:
13 THE WITNESS: On the instruction from my 13 Q. You're aware that Mr. Epstein raped
14 lawyer, I must choose to invoke my Fifth 14 several undera e minors in his bedroom?
15 Amendment privilege. 15 MR. : Objection to the form as
16 BY MR. KUVIN: 16 to knowledge of Mr. Epstein. and also ambiguous
17 Q. And, in fact, you frequently would pay 17 as to the term "rape."
18 other girls to bring additional girls under the age 18 THE WITNESS: On the instruction of my
19 of 18 to Mr. Epstein for naked massages? 19 lawyer, I must choose to invoke my Fifth
20 MR. : Objection to the form, 20 Amendment rights.
21 standing objection as to Mr. Epstein. also as 21 BY MR. KUVIN:
22 to any knowledge of any naked massages by 22 Q. Do ou know what the term "rape" means?
23 anybody to anybody. Instruct the witness not 23 MR. : Not as you used it. If
24 to answer. 24 you want to tell us what you mean by when you
25 THE WITNESS: On the instruction of my 25 used it, we'll be happy to answer --
Page 174 Page 176
lawyer, I choose to invoke my Fifth Amendment 1 MR. KUVIN: I want to know if --
2 right. 2 MR. : -- or evaluate your
3 BY MR. KUVIN: 3 question.
4 Q. And there was a complete list of girls, 4 MR. KUVIN: I want to know if she has her
5 underage girls, that was stored on Mr. Epstein's 5 own definition of what the phrase or word
6 computer s stem: isn't that true? 6 "rape" means, so that we can use her definition
7 MR. : Objection to the form. 7 of that word. I want to make sure it's
8 It's ambiguous as to what a complete list is, 8 complete) unambi uous.
9 and also a standing objection to any knowledge 9 MR. : Your asking the question.
10 of Mr. Epstein, and instruct the witness not to 10 If you want to define the term, she'll respond
11 answer. 11 to your question.
12 THE WITNESS: On the instruction from my 12 BY MR. KUVIN:
13 lawyer, I must choose to invoke my Fifth 13 Q. Do you what the term or word "rape" means?
14 Amendment privilege. 14 A. Yes.
15 BY MR. KUVIN: 15 Q. Okay. What is your understanding of that
16 Q. In fact, you've seen the list of underage 16 word?
17 girls that exists on Mr. Epstein's computer, have 13 MR. : Now, we're not answering
18 you not? 18 that question. It's your term. It's your
19 MR. Objection to the form, 19 question. If you want to define it. you can go
20 standing objection. 20 ahead and define it.
21 THE WITNESS: On the instruction from my 21 MR. KUVIN: Well, I beg --
22 lawyer, I must choose to invoke my Fifth 22 MR. : If you want to give her
23 Amendment right. 23 specifics as to what she -- you can define it.
24 BY MR. KUVIN: 24 MR. KUVIN: I beg to differ with you. and
25 Q. When underage minor females were brought 25 I don't know that that's a proper objection.
44 (Pages 173 to 1 7 6)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 44 of 47
EFTA_00065361
EFTA01246507
Page 177 Page 179
1 I'm askin: her her understanding of the word. 1 or vaginal penetration or union with the sexual
2 MR. : And I am instructing her 2 organ of another, or oral, anal or vaginal
3 not to answer it because that question is not 3 penetration of another with any other object,
4 likely to lead to discoverable evidence. It's 4 or with an object. Excuse me. All right?
5 simply meant to harass her. And you can define 5 MR. Okay.
6 the term in your question. 6 BY MR. KUVIN:
7 MR. KUVIN: Well, with all due respect, 7 Q. Do you understand that definition as I
8 it's certainly not to harass if there have been 8 have explained it to you. or would you like me to
9 girls that were alle in that they were raped. 9 read it again?
10 MR. : Well, you define what you 10 A. Read it again, please.
11 mean by when you say that they allege that they 11 Q. Absolutely. Florida law defines "rape" as
12 have been raped. and she will be happy to 12 oral, anal or vaginal penetration by, or union with
13 evaluate your question. 13 the sexual organ of another: or oral, anal or
14 MR. KUVIN: And that's what I'm trying to 14 vaginal penetration by another with any object. And
15 understand. 15 obviously that is without the other's consent.
16 MR. : She's not going to 16 A. You did not sot that.
17 speculate on what you mean when you frame a 17 MR. Okay.
18 word in your question. 18 BY MR. KUVIN:
19 MR. KUVIN: That's exactly what I'm trying 19 Q. Adding without the other's consent,
20 to do. I'm trying to make sure that we are 20 obviously, to that definition.
21 using the same definition, so I would like to 21 Now, let's use that definition for
22 use her definition of the word. 22 "rape." because that's as it's defined by Florida
23 MR. : Right. She's not going to 23 law. Using that definition, are you aware, as you
24 answer it, so you can either move on we can 24 sit here today, that Jeffrey Epstein has raped
25 stop. 25 underage girls?
Page 178 Page 180
1 MR. KUVIN: Okay. So you're instructing 1 MR. Standing objection to the
2 her not to answer the . uestion? 2 form of the question, and I would instruct the
3 MR. : I am instructing her not 3 witness not to answer.
4 to answer the question for the third time. 4 THE WITNESS: On the instruction of my
5 MR. KUVIN: Okay. I just want to be 5 lawyer, I must choose to invoke my Fifth
6 clear. 6 Amendment right.
7 MR. GARCIA: What's the legal objection? 7 BY MR. KUVIN:
8 MR. : I've already stated what 8 Q. Are you aware as ou sit here today that
9 my legal objection is. It's meant solely for 9 Jeffrey Epstein ra d ?
10 harassment. It's not likely to lead to 10 MR. Objection to the form.
11 discoverable evidence. 11 The question assumes that he did, or that she
12 BY MR. KUVIN: 12 has any knowledge of whether he did, so I
13 Q. Okay. For the purpose of my question, I 13 instruct the witness not to answer.
14 would like to, because your attorney won't allow you 14 THE WITNESS: On the instruction of my
15 to define the word "rape," I would like you to use 15 lawyer, I must choose to invoke my Fifth
16 the word and understand the word "rape" to mean 16 Amendment privilege.
17 sexual contact with an individual, including 17 BY MR. KUVIN:
18 sexual -- well, let me clarify here. Hang on. You 18 Q. Are you aware as you sit here today, that
19 know what, if we're going to do it, let's do it 19 Jeffrey Epstein -- well, let me rephrase that.
20 right since we can't use our definition. 20 You are aware, are you not, a
21 MR. : You can use whatever 21 sit here toda . that Jeffrey Epstein raped?
22 definition you like, but you need to tell me 22 MR. Objection to the form as
23 what it is. 23 leading, and also again assumes -- your
24 MR. KUVIN: Let's use the definition of 24 question assumes that she knows things that
25 "rape" as defined by Florida law as oral, anal 25 she's not acknowledoed that she knows or
45 (Pages 177 to 180)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 45 of 47
EFTA_00065362
EFTA01246508
Page 181 Page 183
doesn't know, and I instruct her not to answer. 1 MR. Same objection as
2 THE WITNESS: On the instruction of my 2 previously stated as to ambiguity and compound,
3 lawyer, I must choose to invoke my Fifth 3 and instruct the witness not to answer.
4 Amendment right. 4 THE WITNESS: On the instruction of my
5 BY MR. KUVIN: 5 lawyer, I must choose to invoke my Fifth
6 Q. Do you agree that Jeffrey Epstein has 6 Amendment right.
7 raped hundreds of irls under the age of 18? 7 BY MR. KUVIN:
8 MR. : Objection to the form, 8 Q. Have you ever had sexual contact in any
9 standing objection as to any knowledge of 9 manner with any underage girls that were brought to
10 Jeffrey Epstein. Instruct the witness not to 10 Mr. Epstein's home?
11 answer. 11 MR. Objection to the form.
12 THE WITNESS: On the instruction of my 12 Standing objection, compound, instruct the
13 lawyer, I must choose to invoke my Fifth 13 witness not to answer.
14 Amendment privilege. 14 THE WITNESS: On the instruction of my
15 BY MR. KUVIN: 15 lawyer, I must choose to invoke my Fifth
16 Q. You're aware, are you not, that 16 Amendment right.
17 Jeffrey Epstein has raped hundreds of girls under 17 BY MR. KUVIN:
18 the age of 17? 18 Q. Did you keep an appointment book for
19 MR. Objection to the form as 19 Mr. Epstein?
20 leading. Instruct the witness not to answer 20 MR. Objection to the form.
21 for the reasons previously stated to the last 21 standing objection. Instruct the witness not
22 the question. 22 to answer.
23 THE WITNESS: On the instruction of my 23 THE WITNESS: On the instruction of my
24 lawyer, I must choose to assert my Fifth 24 lawyer, I must choose to invoke my Fifth
25 Amendment right. 25 Amendment right.
Page 182 Page 184
1 BY MR. KUVIN: 1 BY MR. KUVIN:
2 Q. You're aware, as you sit here today, are 2 Q. Did you preserve a document that shows the
3 you not, that Jeffrey Epstein has raped hundreds of 3 appointments ke for Mr. Epstein in the years 2004?
4 girls under the a e of 16? 4 MR. Objection to the form, the
5 MR. : Objection to the form. 5 standing objection, compound question and
6 Standing objection. It assumes numerous facts 6 instruct the witness not to answer.
7 mixed in a compound question, and therefore I 7 THE WITNESS: On the instruction of my
8 instruct the witness not to answer. 8 lawyer, I must choose to invoke my Fifth
9 THE WITNESS: On the instruction of my 9 Amendment right.
10 lawyer, I must choose to assert my Fifth 10 BY MR. KUVIN:
11 Amendment right. 11 Q. Same question with respect to any
12 BY MR. KUVIN: 12 appointments ke for Mr. Epstein in 2005.
13 Q. Isn't it true that Mr. Epstein had at 13 MR. Same objection previously
14 least one or two scheduled appointments for sex with 14 stated to the previous question.
15 underage girls every day while he was here in Palm 15 THE WITNESS: On the instruction of my
16 Beach Coun in the ear 2005? 16 lawyer, I must choose to invoke my Fifth
17 MR. Objection to the form. 17 Amendment right.
18 It's compound, standing objection as well, and 18 BY MR. KUVIN:
19 instruct the witness not to answer. 19 Q. Same with respect to any appointments kept
20 THE WITNESS: On the instruction of my 20 for Mr. Epstein in 2006.
21 lawyer, I must choose to invoke my Fifth 21 MR. Same objection as
22 Amendment right. 22 previously stated to the last two questions.
23 BY MR. KUVIN: 23 THE WITNESS: On the instruction of my
24 Q. Did you actually locate underage girls in 24 lawyer. I must choose to invoke my Fifth
25 Palm Beach for Jeffrey Epstein to rape? 25 Amendment privilege.
46 (Pages 181 to 1 8 4)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 46 of 47
EFTA_00065363
EFTA01246509
Page 185 Page 187
1 BY MR. KUVIN: 1 MR. Yeah, whenever you get to
2 Q. Have you provided any appointment books to 2 a convenient point in your questioning. I think
3 anyone with respect to intments for Mr. Epstein? 3 we can use a break. If you're in the middle of
4 MR. Same standing objection as 4 something, I don't want to stop you.
5 to knowledge of Mr. Epstein. The question is 5 MR. KUVIN: No, this is fine. We can take
6 compound and instruct the witness not to 6 a quick break. Five minutes?
7 answer. 7 MR. : Yes, thank you.
8 THE WITNESS: On the instruction of my 8 THE VIDEOGRAPHER: We're now off the
9 lawyer. I must choose to invoke my Fifth 9 record. It is 2:08 p.m.
10 Amendment right. 10 (A brief recess was held.)
11 BY MR. KUVIN: 11
12 Q. Would Ep -- Mr. Epstein pay the underage 12
13 girls more money if they took off both their tops 13
14 and their bottoms? 14
15 MR. Objection to the form. 15
16 standing objection. Instruct the witness not 16
17 to answer. 17
18 THE WITNESS: On the instruction of my 18
19 lawyer, I must choose to invoke my Fifth 19
20 Amendment right. 20
21 BY MR. KUVIN: 21
22 Q. Would Mr. Epstein pay the underage girls 22
23 more if the would actually touch his penis? 23
24 MR. Same instruction, same 24
25 objection. 25
Page 186
1 THE WITNESS: On the instruction of my
2 lawyer, I must choose to assert my Fifth
3 Amendment right.
4 BY MR. KUVIN:
S Q. Would Mr. Epstein pay the underage girls
6 more if he would allow them to have sex with them?
7 MR. Can you restate that
8 again?
9 MR. KUVIN: Yes.
10 BY MR. KUVIN:
11 Q. Would Mr. Epstein pay the underage girls
12 more money if they would allow him to have sex with
13 them?
14 MR. Objection to the form.
15 standing objection. Instruct the witness not
16 to answer.
17 THE WITNESS: On the instruction of my
18 lawyer, I must invoke my Fifth Amendment right.
19 MR. KUVIN: Hang on one second. You can
20 stop at an time I'll si n it.
21 MR. Mr. Kuvin, I don't know i
22 you're getting to a convenient breaking point
23 but --
24 MR. KUVIN: Do you want to take a quick
25 one?
47 (Pages 185 to 1 87)
PROSE COURT REPORTING AGENCY, INC.
3501.125-025
CONFIDENTIAL Page 47 of 47
EFTA_00065364
EFTA01246510