EFTA01246559

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME III OF III JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994 08-80993, 08-80811, 08-80893, 09-80469 09-80591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF Wednesday, March 24, 2010 10:37 - 6:51 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d1499-0cd8-4599-a2a0-6d38827b68t6 3501.125-027 CONFIDENTIAL Page 1 of 21 EFTA 00065413 EFTA01246559 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028058XXXXMB AD • I Plaintiff, - vs- VOLUME III OF III JEFFREY EPSTEIN, Defendant. VIDEOTAPED DEPOSITION OF Wednesday, March 24, 2010 10:37 - 6:51 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge I 905d1499-0cd8-4599-a2a0-6d38827b68t6 3501.125-027 CONFIDENTIAL Page 2 of 21 EFTA 00065414 EFTA01246560 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXXMB AB ~•, Plaintiff, -vs- VOLUME III OF III JEFFREY EPSTEIN, Defendant. VIDEOTAPED DEPOSITION OF Wednesday, March 24, 2010 10:37 - 6:51 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge I 905d1499-0cd8-4599•a2a8-6d38827b68c6 3501.125-027 CONFIDENTIAL Page 3 of 21 EFTA_00065415 EFTA01246561 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No.502008CA037319XXXXMB AB Plaintiff, - vs- VOLUME III OF III JEFFREY EPSTEIN AND Defendants. VIDEOTAPED DEPOSITION OF Wednesday, March 24, 2010 10:37 - 6:51 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1484 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge I 905d1499-0cd8-0599•a2a8-6d38827b68c6 3501.125-027 CONFIDENTIAL Page 4 of 21 EFTA 00065416 EFTA01246562 Page 381 Page 383 APPEARANCES: 1 - - - 2 On behalf of the Plaintiff.: SPENCER T. KUVIN. ESQUIRE INDEX LEOPOLD KUWIN 2 - - - 2925 PGA Boulevard 3 WITNESS: DIRECT CROSS REDIRECT RECRO suite No S Palm Beach Gardens. Florida 33410 4 Phone: 561.515.1400 6 5 By Mr. Garcia 383 On behalf of the Plaintiffs...... and 6 By Ms. Ezell 386 lane Doe: 7 8 9 MATMEW WE1SSING. ESQUIRE 8 - - - FARMER. JAFFE MUSSING. EDWARDS 9 EXHIBITS 10 F1STOS & LEIIRMAN. P.L 425 North Andrews Avenue 10 - - - 11 Suite 2 11 EXHIBIT PAGE Fort Lauderdale Florida 33301 12 Phone: 12 Exhibit 16 389 13 On behalf gallant Does I through a: 13 14 ADAM D. HOROWITZ. ESQUIRE MERMELSTEIN & HOROWITZ. P.A. 14 15 18205 Biscayne Boulevard 15 Suite 2218 16 t i 16 Miami. Phone: 17 MI 18 18 On behalf ol the Plunk'' ' . 101. 102 and 103: 19 KATHERINE W. I,MELL. ESQUIRE 19 AMY JOSEFSBERG EDERI. ESQUIRE 20 20 POIMURST OILSECK 25 Wem Flatlet Sheet 21 21 SWIG MO 22 Miami.ii iiii 22 Phone: 23 21 Wu telephone! 24 24 25 25 Page 382 Page 384 I Appearances continued._ 1 PRODEEDINGS 2 On behalf of the Plaintiff. Jane Doe II: 2 - - - 3 ISIDRO MANUEL GARCIA. ESQUIRE GARCIA. ELKINS & BOERRINGER 3 THE VIDEOGRAPHER: We are now on the record 4 224 Daum Avenue. Suite 900 4 It is 5:42 .m. and I'm on media number three. West Palm Beach Fl ida 33401 5 Phone: 5 MR. If I could just put something 6 6 quickly on the record before we start. 7 On behalf of the Defendant: 7 I know Mr. Garcia said he had a couple of 8 JACK ALAN GOLDBERGER. ESQUIRE ATTERBURY. GOLDBERGER & WEISS. P.A. 8 additional questions. which I have no objection to 9 250 Australian Avenue South 9 him asking. but it is 5:42 and we've been going Suite 1400 lo West Pa Floridaida 33401-5012 0 almost seven hours with Ms. Kellen. Phone: 11 And I know Ms. Ezell has questions and she has 11 12 got her one client she has to ask questions about. 12 13 On behalf of t • W. • • 13 I understand that, but I hope we can focus on going 14 14 forward to areas that have not already been covered 15 so we can actually get out of here tonight. because ■ 16 at some point we really do have to go. and I would 17 like to get this over with today. 17 18 So with that. Mr. Garcia. if you have some 18 19 additional questions. I have no objection to you 19 20 ALSO PRESENT: 20 asking that. 21 Jessica Cadwell. Paralegal 21 MR. GARCIA: Thank ou. Burman. Critton. Lanier & Coleman. P.A. 22 CROSS - continued 22 23 Joseph Kozak. Videographer 23 BY MR. GARCIA: Prose Court Reporting Services 24 Q. Have you ever had a different hair color? 24 25 25 MR. . Asking it at any time in her 5 (Pages 381 to 384) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d1499-04:418-4599-4240-6d38827b88c6 3501.125-027 CONFIDENTIAL Page 5 of 21 EFTA_00065417 EFTA01246563 Page 385 Page 387 1 life she's ever dyed her hair a different hair 1 Q. And you are sure that you only had it up for 2 color? 2 about ten minutes? 3 MR. GARCIA: Yes, or if she's dyed her hair 3 MR. Did you mean literally ten 4 now or if that's her natural color. Let's start 4 minutes or just for a brief period of time? 5 with that. 5 THE WITNESS: A very brief period of time. 6 BY MR. GARCIA: 6 MR. You can answer Mr. Garcia's 7 Q. Is that our natural color? 7 question. 8 MR. : Answer that. 8 BY MR. GARCIA: 9 THE WITNESS: Yes. 9 Q. Can you be more specific? Are we talking 10 BY MR. GARCIA: 10 about ten minutes for a day or ten minutes in a week or 11 Q. What is your natural color, so the transcript 11 a month? 12 will reflect it? 12 A. Maybe a day. Maybe two days. 13 MR. We have a video, so I think 13 Q. Okay. 14 it's pretty clear. 19 MR. GARCIA: Oka . that's all I have. Thanks. 15 THE WITNESS: Brown. 15 CROSS ( 16 BY MR. GARCIA: 16 BY MS. EZELL: 17 Q. Have you ever dyed your hair or colored your 17 Q. Ms. Kellen. my name is Katherine Ezell. I'm 18 hair blonde or any type of shade of light, lighter 18 here with Amy Josefsberg Merl. We represent Jane Doc 19 shade? 19 103. We also represent three clients who have not yet 20 MR. : You mean at any time in her 20 filed. Some of the questions may be repetitive. but I 21 life has she done that? 21 believe we have the right to ask them with regard to our 22 MR. GARCIA: Yes, sir. 22 clients. So with that said. we'll move along as fast as 23 THE WITNESS: Yes. 23 we can. 24 BY MR. GARCIA: 24 Why did you take down your Facebook page? 25 Q. For what period of time? 25 A. I think it's a stupid site. I don't Page 386 Page 388 1 A. I don't recall. 1 understand it. I don't understand the point of it. 2 Q. And how long have you gone back to your 2 Q. Do you have e-mail? 3 natural color brown? 3 A. Yes. 4 A. It's been a long time. I don't recall exactly 4 Q. And what is our e-mail address? 5 the dates. 5 MR. • Instruct the witness not to 6 Q. Do know somebody named Craig Greczyn. G-r-e-c. 6 answer based on Fifth Amendment privilege. 7 as in cat. z as in Zorro, y-n? 7 THE WITNESS: At the advice of counsel. I must a A. No. 8 invoke my Fifth Amendment right. 9 Q. He's a student at SUNY University, S-U-N-Y. in 9 BY MS. EZELL: 10 Courtland. 10 Q. Have ou. have ou done e-mail under the 11 A. No idea. 11 address 12 Q. Do you know Kofi Sansculotte. K-o-f-i. 12 A. Can you repeat that? I'm sorry. 13 S-a-n-s-c-u-1-o-t-t-e? 13 . Have ou used e-mail with the address 14 A. No. 14 15 Q. And Michael Daley? 15 A. No. 16 A. No. 16 Q. Have ou used e-mail with the address 17 Q. I tried to see if I could Google your Facebook 17 . 18 page. and you thought you took it down after about ten 18 MR. • Hold on a second. I'm going tc 19 minutes. I did come up with three or four Sarah 19 instruct the witness not to answer any questions 20 Kellens. I'm not sure if it's the same one that you 20 about any e-mail addresses that she may or may not 21 are, but are you sure that you've taken it down? 21 have had in the past based on her Fifth Amendment 22 A. Yes. 22 privilege. 23 Q. And do you have any idea when you took it 23 THE WITNESS: At the advice of my counsel. I 24 down? 24 must invoke my Fifth Amendment right. 25 A. Maybe a year ago. 25 6 (Pages 385 to 388) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d1499-Occ18-4599-a2a0-8d38827b88c8 3501.125-027 CONFIDENTIAL Page 6 of 21 EFTA_00065418 EFTA01246564 Page 389 Page 391 1 BY MS. F7Fit i . 1 THE VIDEOGRAPHER: Okay. 2 Q. With regard to the Facebook page again, why 2 MS. EZELL: This is the second page. 3 did you start it up if you thought it was a stupid site 3 THE VIDEOGRAPHER: Okay. 4 and didn't know how to use it? 4 MS. EZELL: And here's the third page. 5 A. I was just curious. 5 THE VIDEOGRAPHER: Okay. 6 Q. Did anyone help you do that? 6 MS. EZELL: And just for identification 7 A. No. 7 purposes. those are Bates stamped SAO 496 a Q. Did anyone tell you to take it down? 8 through -- I'm sorry. 495 through 497. If you 9 A. No. 9 would pass that down, please. to the witness. 10 Q. You were asked about any licenses. Have you 10 BY MS. EZELL: 11 never held a real estate license? 11 Q. Doyou recognize this. Sorry? 12 A. Never. 12 MR. : Are you asking about all three 13 Q. Do you hold any licenses in any states other 13 pages simultaneously or one page at a time? 14 than Florida? 14 MS. EZELL: All three simultaneous. 15 MR. : When you say licenses, you mean 15 MR. : Okay. 16 professional as opposed to a driver's license or 16 BY MS. EZELL: 17 some other sort of a license? 17 Q. This appears to be. the first page appears to 18 MS. EZELL: Yes. 18 indicate that this was obtained from the driver's 19 THE WITNESS: I don't have a license anywhere 19 license authority in 20 for anything. 20 MR. : The first page we have looks 21 BY MS. EZELL: 21 like it's a printed page. 22 Q. Do you have a driver's license? 22 MS. EZELL: Ri ht. 23 A. Yes. 23 MR. : From -- oh, I see. Okay. never 24 Q. And in what state? 24 mind. 25 MR. : I instruct her not to answer 25 Page 390 Page 392 1 based on her Fifth Amendment privilege. 1 BY MS. EZELL: 2 THE WITNESS: At the advice of counsel. I must 2 Q. It's from the supervisor driver license clerk 3 invoke m Fifth Amendment privilege. 3 in the city and county of Do you see that? 4 MR. You can roll your eyes all you 4 A. Yes. 5 want. Mr. Horowitz. It's my client's right. 5 Q. Do you recognize that application. pages two 6 She'll invoke it if she needs to. 6 and three? 7 MR. HOROWITZ: I was shaking my head, not 7 MR. : Page two is a printout of what 8 rolling my eyes. The Fifth Amendment assertion as 8 appears to be a driver's license. Page three 9 to whether a person has a driver's license is 9 appears to be a fingerprint. 10 ridiculous. It is ridiculous. 10 Is that what you are asking her, if she 11 MR. You can have that opinion. am 11 recognizes this? 12 if you want to bring that up to the judge, I'll be 12 MS. EZELL: Yes, uh huh. 13 happy to explain to the judge why it's a valid 13 MR. : I instruct her not to answer 14 invocation. I disagree with you. 14 those questions. 15 MS. EZELL: It is certainly a record that the 15 THE WITNESS: At the instruction of my lawyer, 16 government has and can be accessed. 16 I must invoke my Fifth Amendment right. 17 MR. That's true. 17 BY MS. EZELL: 18 (The document was marked Exhibit 16 for 18 Q. Even thou h this is a public record? 19 identification.) 19 MR. : Well, if it's a public record 20 BY MS. EZELL: 20 or not, she doesn't have to admit or authenticate 21 Q. I'm going to show you in a moment what I have 21 it for you. You can prove it some other way. She 22 premarked as Exhibit 16. 22 has a Constitutional right not to admit or 23 MS. EZELL: Actually, it's Composite 16. It's 23 authenticate the document for you. and that's what 24 three pages. I'll show it before I give it to the 24 she is invoking. 25 witness. 25 7 (Pages 389 to 392) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d1499-0c68-4599-a2a0-8d38827b68c8 3501.125-027 CONFIDENTIAL Page 7 of 21 EFTA_00065419 EFTA01246565 Page 393 Page 395 1 BY MS. F7Ft i • 1 BY MS. EZELL: 2 Q. Didyou ever hold a driver's license? 2 Q. Did you at one time hold 3 MR. Same instruction. It's been 3 in -- I won't pronounce it right, but ? 4 asked and answered. 4 THE REPORTER: Could ou spell -- 5 THE WITNESS: At the instruction of my lawyer, 5 MS. EZELL: It's I believe. 6 I must invoke my Fifth Amendment right. 6 MR. : I instruct the witness not to 7 BY MS. F7Ft t • 7 answer based on her Fifth Amendment privilege. 8 Q. Do you currently hold a driver's 8 THE WITNESS: At the instruction of my lawyer, 9 license? 9 I must invoke my Fifth Amendment right. 10 MR. It's been asked and answered. 10 BY MS. EZELL: 11 same instruction. 11 Q. Were ou born on ? 12 THE WITNESS: At the instruction of my lawyer, 12 MR. : Same instruction. 13 I must invoke my Fifth Amendment right. 13 THE WITNESS: At the instruction of my lawyer, 14 BY MS. EZELL: 14 I must invoke my Fifth Amendment right. 15 Q. Is that not your picture on the second page of 15 BY MS. EZELL: 16 that exhibit? 16 Q. Doyou see a sr nature there for 17 MR. Same instruction. 17 MR. : Just asking if she sees a 18 THE WITNESS: At the instruction of my lawyer, 18 signature on the paper -- 19 I must invoke my Fifth Amendment right. 19 MS. EZELL: That says 20 BY MS. EZELL: 20 THE WITNESS: I see it. 21 Q. Do ou see the ran 21 BY MS. EZELL: 22 MR. She's just asking if you see 22 Q. Is that our si attue? 23 that on the document. 23 MR. : Instruct the witness not to 24 THE WITNESS: Yes. 24 answer based on her Fifth Amendment privilege. 25 25 THE WITNESS: At the instruction of my lawyer, Page 394 Page 396 1 BY MS. F7Ft i • 1 I must invoke my Fifth Amendment right. 2 Q. And haven't you testified today that that is 2 BY MS. EZELL: 3 your name? 3 Q. Do you drive an automobile in Palm Beach 4 MR. The testimony will speak for 4 County? 5 itself. Next question. 5 MR. Let me understand the question. 6 BY MS. EZELL: 6 Are you asking if she ever drives a vehicle in the 7 Q. You ma answer. 7 county or if she drives a vehicle registered in the a MR. Next question. 8 county? 9 MS. EZELL You are instructing her not to 9 MS. EZELL: If she drives a vehicle in Palm 10 answer that uestion? 10 Beach Count . 11 MR. I am. 11 MR. You can answer that. In other 12 BY MS. EZELL: 12 words, did you drive a car here today? 13 Q. What was your address at the time that that. 13 THE WITNESS: Yes. 14 that you a lied for a license then? 14 BY MS. EZELL: 15 MR. Object to the form, assumes 15 Q. You were asked earlier if you have ever been 16 facts that she has not acknowledged. that she ever 16 to Palm Beach as opposed to West Palm Beach where we ar 17 applied for this license, and I'll instruct her not 17 today. and I believe you answered yes. 18 to answer. 18 A. Uh huh. 19 BY MS. EZELL: 19 Q. Where have you been in Palm Beach? 20 Q. Is thepost office box -- 20 MR. I instruct her not to answer 21 MR. Hold on. let her answer or not 21 based on her Fifth Amendment privilege. 22 answer. 22 THE WITNESS: At the instruction of my lawyer. 23 THE WITNESS: At the instruction of my lawyer. 23 I must invoke my Fifth Amendment right. 24 I must invoke my Fifth Amendment right. 24 BY MS. F7In T - 25 25 Q. When was the last time you were on Palm Beach 8 (Pages 393 to 3 9 6) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d1499-0468-4599-a2a0-6d38827b68c6 3501.125-027 CONFIDENTIAL Page 8 of 21 EFTA_00065420 EFTA01246566 Page 397 Page 399 1 island, if it's an island? 1 BY MS. F7F1I • 2 MR. Objection, it's been asked 2 Q. Do ou know Glenn Dubin? 3 before, and I'll instruct her nor to answer for the 3 MR. : It's also asked and answered, 4 same reason. 4 but Inlet her answer it again. 5 THE WITNESS: At the instruction of my lawyer. 5 THE WITNESS: At the instruction of my lawyer, 6 I must invoke my Fifth Amendment right. 6 I must invoke my Fifth Amendment right. 7 BY MS. EZELL: 7 BY MS. F7FI 1 • 8 Q. Haveyou ever heard of Jeffrey Epstein? 8 Q. 9 MR. Objection, instruct the witness 9 MR. Same instruction, objection to 10 not to answer based on her Fifth Amendment 10 the form, assumes facts that she has not 11 privilege. 11 acknowledged. so there is no foundation for the 12 THE WITNESS: At the instruction of my lawyer, 12 question. 13 I must invoke m Fifth Amendment right. 13 THE WITNESS: At the instruction of my lawyer. 14 MR. It's also been asked and 14 I must invoke my Fifth Amendment right. 15 answered. 15 BY MS. F7Ft I • 16 BY MS. EZELL: 16 Q. 17 Q. Do you read the newspapers? 18 A. Na really. 18 MR. 19 Q. Have you read any newspapers in the last four 19 MS. EZELL: 20 years in Palm Beach County? 20 MR. Objection to form. Once again, 21 A. I'm sure I have. 21 assumes facts that she has not acknowledged. that 22 Q. Have you read the Palm Beach Post? 22 there is no foundation. Instruct her not to answer 23 A. No, I don't. 23 the question. 24 Q. What newspapers do you read? 24 THE WITNESS: At the instruction of my lawyer. 25 A. New York Times. New York Post. That's about 25 I must invoke my Fifth Amendment right. Page 398 Page 400 1 it., on occasion. 1 BY MS. EZELL: 2 Q. And have you ever — do you watch the news on 2 Q. Are you an onl child? 3 TV. local news? MR. It's been asked and answered o 4 A. No. 4 responded to, and I'll instruct her once again to 5 Q. When you did your Facebook page. whose 5 respond. 6 computer did you use? 6 THE WITNESS: At the instruction of my lawyer. 7 A. My own. 7 I must invoke my Fifth Amendment right. 8 Q. What kind of computer do you own? 8 BY MS. EZELL: 9 A. An Apple computer. 9 Q. I believe you stated that you had changed your 10 Q. Is it a laptop? 10 hair color at some point in your life. 11 A. Yes. 11 Have you changed it in the last five years? 12 Q. How long have you had that computer? 12 A. I don't recall exact years and dates. 13 A. I don't recall. 13 Q. I'm sorry? 14 Q. Doyou know Eva Andersson? 14 A. I don't recall exact years and dates that I 15 MR. Objection, it's been asked and 15 have. 16 answered. 16 Q. Have you been a blonde at some point in the 17 MS. EZELL: I think it was asked whether or 17 last, in the last eight years? 18 not she had been on a plane with her. 18 A. Most likely. 19 MR. I believe she was asked if she 19 Q. At more than one time? In other words, have 20 knew who Eva Andersson was, but she can go ahead 20 you gone back and forth between being a brunette and a 21 and respond to the question. I instruct her not to 21 blonde or were you a blonde for a certain period of 22 answer. 22 time? 23 THE WITNESS: At the instruction of my lawyer. 23 A. I think I went back and forth at one point. 24 I must invoke my Fifth Amendment right. 24 Q. Have you ever either had an office or worked 25 25 at an office in thi. building. which is One Clearlake 9 (Pages 397 to 4 00) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 90561499-0.48-4599-a2a0-6d38827b68c6 3501.125-027 CONFIDENTIAL Page 9 of 21 EFTA_00065421 EFTA01246567 Page 401 Page 403 1 Centre? 1 BY MS. EZELL: 2 MR. Instruct the witness not to 2 Q. Do you consider yourself a citizen of the 3 answer based on her Fifth Amendment privilege. 3 United States? 4 THE WITNESS: At the advice of counsel. I must 4 MR. : You can answer that. 5 invoke my Fifth Amendment right. 5 THE WITNESS: Yes. 6 BY MS. EZELL: 6 BY MS. EZELL: 7 Q. Have you ever gone to that office on a daily 7 Q. And of what state do you consider yourself to 8 basis with Jeffrey E rein? 8 be a citizen? 9 MR. Objection to form. There is no 9 MR. That was just asked and 10 foundation, because she hasn't acknowledged going 10 answered. 11 to an office in this building. 11 MS. EZELL: I asked about residency. 12 Also objection as to the implied knowledge of 12 MR. : I apologize. 13 Mr. Epstein. Instruct her not to answer. 13 THE WITNESS: What's the difference? 14 THE WITNESS: At the instruction of my lawyer. 14 MR. : Instruct the witness not to 15 I must invoke my Fifth Amendment right. 15 answer the question based on Fifth Amendment. 16 BY MS. EZELL: 16 THE WITNESS: At the instruction of my lawyer, 17 Q. Have you ever had anything to do with a 17 I must invoke my Fifth Amendment right. 18 company called the Florida Science Foundation? 18 BY MS. EZELL: 19 MR. Instruct the witness not to 19 Q. Have you changed your residency in the last 20 answer based on Fifth Amendment. 20 three years? 21 THE WITNESS: At the instruction of my lawyer, 21 MR. Residency for which? I just 22 I must invoke my Fifth Amendment right. 22 want to be clear. Ms. Ezell. You mean legal 23 BY MS. EZELL: 23 residency or where she actually lives residency? 24 Q. Your middle name is :. is that correct? 24 MS. EZELL: Well, let's do both. 25 A. Correct. 25 Page 402 Page 404 1 Q. 1 BY MS. EZELL: 2 MR. It's been asked and answered 2 Q. Have you changed your legal residency in the 3 twice. You can answer it a ain. 3 last five years? 4 THE WITNESS: 4 A. I don't think so. 5 BY MS. F7Ft I • 5 Q. Have you changed the place you live in the 6 Q. Thank you. 6 last five years? 7 Where do you. of what state are you a 7 MR. Instruct her not to answer that 8 resident? 8 question based on Fifth Amendment. 9 MR. Instruct the witness not to 9 THE WITNESS: At the advice of counsel, I must 10 answer based on Fifth Amendment. 10 invoke my Fifth Amendment right. 11 THE WITNESS: At the instruction of my lawyer, 11 BY MS. EZELL: 12 I must invoke my Fifth Amendment right. 12 Q. Have you changed your citizenship. your state 13 BY MS. EZELL: 13 citizenship in the last five years? 14 Q. Where do ou vote? 14 MR. : Again, for purposes of voting 15 MR. Same instruction. 15 and other things or just -- 16 THE WITNESS: At the instruction of my lawyer, 16 MS. EZELL: Yes, whatever things citizenship 17 I must invoke my Fifth Amendment right. 17 entitles one to do. 18 BY MS. EZELL: 18 MR. If you understand the question 19 Q. Are ou registered to vote? 19 you can answer it. 20 MR. It's been asked and answered. 20 THE WITNESS: I don't recall really ever 21 I'll instruct her not to answer again, or to answer 21 changing -- I didn't know that you could change 22 it, to respond to it. I should say. 22 your citizenship of a state. 23 THE WITNESS: At the instruction of my lawyer. 23 BY MS. EZELL: 24 I must invoke my Fifth Amendment right. 24 Q. Well, if you move from one state to another. 25 25 you might change your voter's registration. time you 10 (Pages 401 to 4 0 4) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d1499-04:68-4599-a2a0-6d38827b68c6 3501.125-027 CONFIDENTIAL Page 10 of 21 EFTA_00065422 EFTA01246568 Page 405 Page 407 1 done that? 1 THE WITNESS: At the advice of my lawyer, I 2 MR. You can answer. 2 must invoke my Fifth Amendment right. 3 THE WITNESS: No. 3 BY MS. EZELL: 4 BY MS. EZELL: 4 Q. 5 Q. Are you a resident of or citizen of the US 6 Virgin Islands currentl ? 7 MR. Do you understand? You can a answer it. 8 Q. Have you ever been involved in modeling for M 9 THE WITNESS: No. 9 Squared? 10 BY MS. EZELL: 10 MR. • Instruct the witness -- 11 Q. Do ou taxes in any state? 11 objection to the form, assumes knowledge of an 12 MR. Answer that yes or no. 12 entity by the name of MC Squared which the witness 13 THE WITNESS: Yes. 13 has not acknowledged or have any knowledge of. so 14 BY MS. F7Ft I • 19 there is no foundation for the question. 15 Q. In what states do you pay taxes? 15 Ed instruct her not to answer based on her 16 MR. Instruct her not to answer that 16 Fifth Amendment privilege. 17 question based on Fifth Amendment. 17 THE WITNESS: At the instruction of my lawyer, 18 THE WITNESS: At the instruction of my lawyer, 18 I must invoke my Fifth Amendment right. 19 I must invoke my Fifth Amendment right. 19 BY MS. EZELL: 20 BY MS. EZELL: 20 21 Q. Doyou ownproperty in any state? 22 MR. It's a yes or no question. You 23 can answer that. 24 THE WITNESS: No. 25 Page 406 Page 408 1 BY MS. EZELL: 2 Q. Is that a no? I 3 A. No. I 4 Q. Have you owned property in any state in the 4 BY MS. EZELL: 5 last five years? 5 Q. And what happened to those, where are those 6 A. No. 6 pictures? 7 Q. Are you taking any prescribed medication at 7 A. I have them. 8 this time? 8 Q. And who is your boyfriend? 9 MR. You can answer the question. 9 MR. : Hold on a second. 10 THE WITNESS: 10 Instruct the witness not to answer based on 11 BY MS. EZELL: 11 her Fifth Amendment privilege. 12 Q. I'm so 12 BY MS. EZELL: 13 A. 13 Q. Is that your current boyfriend who took the 14 Q. Anything else? 14 pictures? 15 A. No. 15 MR. • You can answer that. 16 Q. You didn't take anything before this 16 THE WITNESS: No. 17 deposition today? 17 BY MS. EZELL: 18 A. No. 18 Q- 19 •. 20 MR. • At this point this is getting 21 into her privacy rights beyond the scope of 22 Q. And for what company or organization did you 22 anything I think that's relevant to this case. I'm 23 model at 18? 23 going to ask you to move on. MR. Instruct her not to answer the 24 MS. EZELL: Are you instructing her not to question based on her Fifth Amendment privilege. 25 answer? 11 (Pages 405 to 4 08) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d1499-Occla-4599-a2a0-6d38827baace 3501.125-027 CONFIDENTIAL Page 11 of 21 EFTA_00065423 EFTA01246569 Page 409 Page 411 1 MR. I am. I am. 1 THE WITNESS: I don't — I don't get it. It's 2 BY MS. EZELL: 2 vague. I don't understand the question. 3 Q. Do you have all copies of those pictures or 3 BY MS. EZELL: 4 have they been distributed? 4 Q. Are you not aware of an organization that 5 A. I hope I have all copies. 5 limits its membership to billionaires? 6 Q. Would you please -- I have a little difficulty 6 A. No. I'm not. 7 hearing you. 7 A. So 9 9 MR. : Instruct the witness not to 10 answer based on her Fifth Amendment privilege, and 11 that's also been asked and answered several times. 12 THE WITNESS: At the instruction of my lawyer, 13 I must invoke my Fifth Amendment right. 14 BY MS. EZELL: 15 Q. By whom are ou currently employed? 16 MR. : Objection. also been asked ant 17 answered several times. Instruct her not to 18 answer. 19 THE WITNESS: At the instruction of my lawyer, 20 I must invoke my Fifth Amendment right. 21 BY MS. EZELL: 22 Q. Are you employed by an individual or by a 23 corporation? 24 Q. Who introduced you to Jeffrey Epstein? 24 MR. : Same instruction. 25 MR. Instruct the witness not to 25 THE WITNESS: At the instruction of my lawyer, Page 410 Page 412 1 answer based on her Fifth Amendment privilege. 1 I must invoke my Fifth Amendment right. 2 THE WITNESS: At the instruction of my lawyer. 2 BY MS. EZELL: 3 I must invoke my Fifth Amendment right. 3 Q. Do ou receive a W2? 4 BY MS. EZELL: 4 MR. : Same instruction. 5 Q. Have you ever been to a social event in New 5 THE WITNESS: At the instruction of my lawyer, 6 York that is restricted to billionaires? 6 I must invoke my Fifth Amendment right. 7 A. Sorry. can you repeat that? 7 BY MS. EZELL: 8 Q. Yes. Have you ever been to a social event 8 Q. Do ou receive a 1099? 9 that's held annually in New York restricted to 9 MR. : Same instruction. 10 billionaires? 10 THE WITNESS: At the instruction of my lawyer, 11 A. I've never heard of such an event, no. 11 I must invoke my Fifth Amendment right. 12 Q. Have you ever been to such an organization in 12 BY MS. EZELL: 13 California? 13 Q. Does anyone claim you as a dependent on their 14 A. No. I, I have never heard of such an event 14 tax returns? 15 like that, so I don't know. 15 MR. Anyone other than herself? 16 Q. Have you never seen your picture taken and 16 MS. EZELL: Yes. 17 displayed in rint media at such an event? 17 THE WITNESS: No. 18 MR. Objection to the form. It's 18 BY MS. EZELL: 19 not established she has any idea what event or what 19 Q. Have you ever signed a confidentiality 20 kind of event this would be. 20 agreement? 21 BY MS. EZELL: 21 MR. : With anyone? 22 Q. An annual event involving millionaires 22 MS. EZELL: Yes. 23 billionaires, excuse me. 23 MR. HOROWITZ: Instruct the witness not to 24 MR. Objection to the form. There 24 answer based on her Fifth Amendment privilege. 25 is a lack of foundation for the question. 25 TIIL WITNESS: At the instruction of my lawyer, 12 (Pages 409 to 4 12) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d1499-0ca-4599-a2a0-6d38827b68c6 3501.125-027 CONFIDENTIAL Page 12 of 21 EFTA_00065424 EFTA01246570 Page 413 Page 415 1 I must invoke my Fifth Amendment right. 1 implicitly. Instruct the witness not to answer. 2 BY MS. EZELL: 2 THE WITNESS: At the instruction of my lawyer, 3 3 I must invoke my Fifth Amendment right. I 4 BY MS. EZELL: A. Have I what? I'm so 5 Q. Do you know Juan Alessi? 6 6 THE WITNESS: At the instruction of my lawyer, 7 I must invoke my Fifth Amendment right. 8 A. I don't recall ever saying those words. 8 BY MS. EZELL: 9 Q. Is it true that you will do anything Jeffrey 9 Q. Doyou know Alfredo Rodriguez? 10 Epstein asks? 10 MR. : It's been asked and answered. 11 MR. : Objection to the form. compounc 11 Go ahead and answer it again. 12 question. Assumes knowledge of Jeffrey Epstein. so 12 THE WITNESS: At the instruction of my lawyer, 13 I instruct the witness not to answer. 13 I must invoke my Fifth Amendment right. 14 THE WITNESS: At the instruction of my lawyer. 14 BY MS. EZELL: 15 I must invoke my Fifth Amendment privilege. 15 Q. I think you also might have been asked if you 16 BY MS. EZELL: 16 know Januscz Banasiak. 17 Q. In 2005 and '6. did you have a designated 17 THE WITNESS: At the instruction of my lawyer, 18 computer in Mr. E rein's home on El Brillo Way? 18 I must invoke my Fifth Amendment right. 19 MR. : Objection to form. it's 19 BY MS. EZELL: 20 compound and assumes knowledge of Mr. Epstein and 20 Q. Are ou a hoto rapher? 21 of a location on El Brillo Way. so I instruct the 21 MR. : Objection to the form, its 22 witness not to answer. 22 ambiguous. Amateur photographer? Professional 23 THE WITNESS: At the instruction of my lawyer. 23 photographer? Can you clarify? 24 I must invoke my Fifth Amendment right. 24 BY MS. EZELL: 25 25 Q. Do you enjoy photography? Page 414 Page 416 1 BY MS. EZELL: 1 A. Yes. 2 Q. Did you have on a computer at El Brillo Way a 2 Q. What kind of camera do you have? 3 list of contact information and pictures of numerous 3 MR. Instruct the witness not to 4 women? 4 answer the question. 5 MR. Objection to the form, it's 5 THE WITNESS: At the instruction of my lawyer. 6 compound and it is lack of foundation based on the 6 I must invoke my Fifth Amendment right. 7 prior question and answer. 7 BY MS. EZELL: 8 Instruct the witness not to answer. 8 Q. Do you know Maria Akssi? 9 THE WITNESS: At the instruction of my lawyer, 9 THE WITNESS: At the instruction of my lawyer. 10 I must invoke my Fifth Amendment right. 10 I must invoke my Fifth Amendment right. 11 BY MS. EZELL: 11 BY MS. F7PT 1 - 12 Q. Did you and Ghislaine Maxwell share that 12 Q. Have you ever known Jeffrey Epstein to give 13 information on both of our computers? 13 caniems to young women who come to his home to give hin 14 MR. Objection to form, assumes 14 massages? 15 knowledge of a person by the name of Ghislaine; 15 MR. Objection to the form. standing 16 Maxwell. 16 objection. lack of foundation as to Mr. Epstein and 17 Also lack of foundation based on the prior two 17 to his home. Instruct the witness not to answer. 18 answers. Instruct the witness not to answer. 18 THE WITNESS: At the instruction of my lawyer. 19 THE WITNESS: At the instruction of my lawyer, 19 I must invoke my Fifth Amendment right. 20 I must invoke my Fifth Amendment privilege. 20 BY MS. F7Pr T - 21 BY MS. EZELL: 21 Q. Have you been encouraged in your pursuit of 22 22 photograph • b Mr. E tein? ■ 23 MR. : Same objection previously 24 MR. Objection to form, lack of 24 stated. 25 foundation, assumes knowledge of Sir. Epstein 25 THE WITNESS: At the in‘truction of my lawyer. 13 (Pages 413 to 416) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (IM M) 905d1499-0.48-4599-a2.a0-6d381327b118c6 3501.125-027 CONFIDENTIAL Page 13 of 21 EFTA_00065425 EFTA01246571 Page 417 Page 419 1 I must invoke my Fifth Amendment right. 1 THE WITNESS: At the instruction of my lawyer. 2 BY MS. EZELL: 2 I must invoke my Fifth Amendment right. 3 Q. Have you ever taken pictures of any of the 3 BY MS. EZELL: 4 young women who have visited the Epstein mansion to 4 Q. Have you. have you ever photographed any of 5 provide massa es? 5 the young women who visited or visit the Epstein home tc 6 MR. Objection to form, compound. 6 provide massy es to Mr. Epstein? 7 lack of foundation. Instruct the witness not to 7 MR. Objection to form. its been 8 answer. 8 asked and answered. 9 THE WITNESS: At the instruction of my lawyer, 9 Also lack of foundation and standing 10 I must invoke my Fifth Amendment right. 10 objection. Same instruction. 11 BY MS. EZELL: 11 THE WITNESS: At the instruction of my lawyer. 12 Q. Are you aware of any hidden cameras on the 12 I must invoke my Fifth Amendment right. 13 premises? 13 BY MS. EZELL: 14 MR. Which premises? 14 Q. Have you ever photographed any minor girls who 15 MS. EZELL At the El Brillo Way address of 15 are either partial) nude or nude? 16 Mr. Epstein. 16 MR. That's also been asked and 17 MR. Objection to form, lack of 17 answered. I instruct her once again not to answer 18 foundation, compound. Instruct the witness not to 18 the question. 19 answer. 19 THE WITNESS: At the instruction of my lawyer. 20 THE WITNESS: At the instruction of my lawyer, 20 I must invoke my Fifth Amendment right. 21 I must invoke my Fifth Amendment right. 21 BY MS. EZELL: 22 BY MS. EZELL: 22 Q. Have you ever been aware of something called 23 Q. Did you ever meet a young woman named M.? 23 the Edge Grou ? 24 A. At the instruction of my lawyer, I must invoke 24 MR. Consult. 25 my Fifth Amendment right. 25 THE WITNESS: At the advice of my lawyer, I Page 418 Page 420 1 Q. Were you sometimes designated or requested by 1 must invoke the Fifth Amendment right. 2 Mr. Epstein to buy gifts for the young women who would 2 BY MS. EZELL: 3 come to the home to e him massages? 3 Q. Is that the name of a group that's, whose 4 MR. iv: Objection to form, lack of 4 membershi is made u of billionaires? 5 foundation. Instruct the witness not no answer. 5 MR. : Objection to form. lack of 6 THE WITNESS: At the instruction of my lawyer. 6 foundation. Instruct the witness not to answer. 7 I must invoke my Fifth Amendment right. 7 THE WITNESS: At the instruction of my lawyer, 8 BY MS. F7Ft I • 8 I must invoke my Fifth Amendment right. 9 Q. Were you aware that Mr. Epstein gave .. a 9 BY MS. EZELL: 10 digital camera and encouraged her in her pursuit of 10 Q. Did you attend a function of the Edge Group in 11 photograph ? 11 February of 1902 -- I'm sorry. 2002? 12 MR. : Same objection stated to the 12 MR. : Object to form, there is a lack 13 previous question and same instruction. 13 of foundation. Instruct the witness not to answer. 14 THE WITNESS: At the instruction of my lawyer. 14 THE WITNESS: At the instruction of my lawyer, 15 I must invoke my Fifth Amendment right. 15 I must invoke my Fifth Amendment right. 16 BY MS. F7F1 f • 16 BY MS. EZELL: 17 Q. Have you ever met a young woman named ? 17 Q. Have you attended several functions since 2002 18 A. At the instruction of my lawyer. I must invoke 18 of the Edge Grou • ? 19 my Fifth Amendment right. 19 MR. : Objection to the form, because 20 Q. Were you ever aware that Mr. Epstein gave 20 there is no foundation for her having any knowledge 21 a regular camera and encouraged her in her pursuit of 21 of an entity called the Edge Group. so I'll 22 photograph ? 22 instruct her not to answer. 23 MR. : Objection to form, assumes 23 THE WITNESS: At the instruction of my lawyer, 24 certain facts, lack of foundation, compound. 24 I must invoke my Fifth Amendment right. 25 Instruct the witness not to answer. 25 14 (Pages 417 to 420) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 90561499-0468-4599-82.80-66388271368c6 3501.125-027 CONFIDENTIAL Page 14 of 21 EFTA_00065426 EFTA01246572 Page 421 Page 423 1 BY MS. F7IFI I • 1 is a lack of foundation of her having any 2 Q. Are you a member of the Edge Group or do you 2 interaction with anyone at any home owned by 3 go as the guest of Mr. E stein? 3 Mr. Epstein, whoever he may be. Instruct her not 4 MR. Again, there is no foundation 4 to answer. 5 for the question because there is no. there is no 5 THE WITNESS: At the instruction of my lawyer, 6 connection of her to this organization, and I'd 6 I must invoke my Fifth Amendment right. 7 instruct her not to answer. Form objection. 7 BY MS. EZELL: 8 THE WITNESS: At the instruction of my lawyer, 8 Q. Were you the one who routinely would get out 9 I must invoke my Fifth Amendment right. 9 the lotion, towels, and massage equipment once you 10 BY MS. F7IFI I • 10 arrived at the massy e room with the girl? 11 Q. Do you know Ghislaine Maxwell's e-mail 11 MR. Same objection to the form. 12 address? 12 same objection stated to the previous question. 13 MR. Instruct the witness not to 13 It's been asked and answered as well. 14 answer, objection to form, lack of foundation as to 14 THE WITNESS: At the instruction of my lawyer, 15 her knowledge of anyone named Ghislaine Maxwell. 15 I must invoke my Fifth Amendment right. 16 THE WITNESS: At the instruction of my lawyer. 16 BY MS. EZELL: 17 I must invoke my Fifth Amendment right. 17 Q. Does Mr. Epstein particularly like any 18 19 20 a•Do BY MS. F7IFI I • ? you know a=I or 18 19 20 particular massy e oils? MR. • Objection to the form. standar objection. no foundation as to her knowledge of 21 A. At the instruction of my lawyer, I must invoke 21 anything relating to Jeffrey Epstein. Instruct her 22 my Fifth Amendment right. 22 not to answer. 23 Q. Did you participate in a sort of routine 23 THE WITNESS: At the instruction of my lawyer. 24 involving young women who would come to the house. 24 I must invoke my Fifth Amendment right. 25 Mr. Epstein's house on El Brillo Way to provide 25 Page 422 Page 424 1 massages? 1 BY MS. EZELL: 2 MR. That's been asked and answered 2 Q. Was it your general practice to leave the girl 3 several times. object to the form, lack of 3 alone either just before or when Mr. Epstein would com 4 foundation as to any knowledge relating to Epstein 4 into the room? s or El Brillo Way. Instruct her not to answer. 5 MR. : Objection to the form, again 6 THE WITNESS: At the instruction of my lawyer. 6 assuming multiple facts and the same question. none 7 I must invoke my Fifth Amendment right. 7 of which have any foundation. Instruct her not to a BY MS. EZELL: 8 answer. 9 Q. Was it routine practice for you to come and 9 THE WITNESS: At the instruction of my lawyer 10 meet the girl after she arrived at El Brillo Way to 10 I must invoke my Fifth Amendment right. 11 provide a massage for the sexual gratification of 11 BY MS. EZELL: 12 Mr. Epstein? 12 Q. Who paid the girls who came to El Brillo Way 13 MR. : Objection to form, it's 13 to provide massages and other sexual favors for 14 compound. There is a lack of foundation. Instruct 14 Mr. Epstein? 15 the witness not to answer. It's been asked and 15 MR. : Same objection as to form as 16 answered several times. 16 previously stated to the last three or four 17 THE WITNESS: At the instruction of my lawyer. 17 questions. Same instruction to the witness. 18 I must invoke my Fifth Amendment right. 18 THE WITNESS: At the instruction of my lawyer 19 BY MS. EZELL: 19 I must invoke my Fifth Amendment right. 20 Q. Was it your practice to then lead the young 20 BY MS. EZELL: 21 woman who had come to give Mr. Epstein a massage up a 21 Q. Who was responsible for keeping the supply of 22 stairway that is behind a door in the kitchen of the 22 cash in the house from which the girls were paid? 23 home on El Brillo Wa ? 23 MR. : Same objection as to form and 24 MR. : Objection to the form, it's 24 lack of foundation. Instruct the witness not to 25 compound. assuming many facts. It's not, and there 25 answer. 15 (Pages 421 to 424) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d1499-0a18-4599-a2a0-6d38827868c6 3501.125-027 CONFIDENTIAL Page 15 of 21 EFTA_00065427 EFTA01246573 Page 425 Page 427 1 THE WITNESS: At the instruction of my lawyer 1 MR. Objection to the form, lack of 2 I must invoke my Fifth Amendment right. 2 foundation. Instruct the witness not to answer. 3 BY MS. EZELL: 3 THE WITNESS: At the instruction of my lawyer, 4 Q. Was it your practice or habit to get the 4 I must invoke my Fifth Amendment right. 5 telephone numbers and contact information of each girl 5 BY MS. EZELL: 6 before she left El Brillo Way? 6 Q. Did you ever text with Jane No. 103 about her 7 MR. Same objection as to form as 7 coming to Mr. E rein's house? 8 stated to the last series of questions. Same 8 MR. : Same instruction. same 9 instruction. 9 objection. 10 THE WITNESS: At the instruction of my lawyer 10 THE WITNESS: At the instruction of my lawyer, 11 I must invoke my Fifth Amendment right. 11 I must invoke my Fifth Amendment right. 12 BY MS. EZELL: 12 BY MS. EZELL: 13 Q. Going back to that stairway that led from the 13 Q. Were you aware that Jeffrey Epstein was 14 kitchen up to the massage room, was there a time when 14 helping Jane No. 103 with her college application? 15 there were photos of nude girls all the way up that 15 MR. : Objection to the form, lack of 16 stairway? 16 foundation as to any knowledge as to Jeffrey 17 MR. Same objection as to form an 17 Epstein. so therefore it's compound and ambiguous. 18 lack of foundation as to any basis to question this 18 Instruct you not to answer. 19 witness on anything having to do with a home own 19 THE WITNESS: At the instruction of my lawyer, 20 by Mr. Epstein or any staircase or any pictures on 20 I must invoke my Fifth Amendment right. 21 a staircase. So instruct her not to answer. 21 BY MS. EZELL: 22 THE WITNESS: At the instruction of my lawyer 22 Q. Did you ever hear Mr. Epstein tell Jane No. 23 I must invoke my Fifth Amendment right. 23 103 that he would help her even with the financing of 24 BY MS. F7Ft i • 24 her college, of her education? 25 Q. Do you recall a time when all those 25 MR. Same objection stated to the Page 426 Page 428 1 photographs were removed? 1 previous question. Objection to form and lack of 2 MR. : Objection to the form. lack of 2 foundation. Instruct the witness not to answer. 3 foundation. same objection as the previous series 3 THE WITNESS: At the instruction of my lawyer, 4 of questions. Same instruction. 4 I must invoke my Fifth Amendment right. 5 THE WITNESS: At the instruction of my lawyer. 5 BY MS. EZELL: 6 I must invoke my Fifth Amendment right. 6 Q. Do you recall -- and I believe it's in 7 BY MS. FM I - 7 Exhibit 4, if we could pull Exhibit 4, please. If I a Q. Did you ever text girls about coming to 8 could just look at it for a moment, please. 9 provide massy es for Jeffrey Epstein? 9 MR. : Certainly. 10 MR. : Objection as to form, lack of 10 MS. EZELL: Thanks. Oh. good, it's on the 11 foundation as to any knowledge of Jeffrey Epstein. 11 front. 12 Instruct her not to answer. 12 BY MS. EZELL: 13 THE WITNESS: At the instruction of my lawyer. 13 Q. The first page of Exhibit 4, I'd ask you to 14 I must invoke my Fifth Amendment right. 14 look at that. Doyou recognize that handwriting? 15 BY MS. EZELL: 15 MR. : That was asked and answered 16 Q. Do you know how to text? 16 about six hours ago. She said no. 17 A. Yes. 17 You can answer it again. 18 Q. And how long have you been texting? 18 THE WITNESS: No. 19 A. Twelve years. 19 BY MS. EZELL: 20 Q. Twelve years? That's great. You are way 20 Q. Were you aware that Mr. Epstein ordered roses 21 ahead of me. I still don't know how. 21 to be delivered to Jane No. 103 at the stage of her high 22 Do you know a young woman named Jane No. 103? 22 school after a la ? 23 A. At the advice of my counsel. I must invoke my 23 MR. : Objection to the form, lack of 24 Fifth Amendment right. 24 foundation, standing objection. 25 Q. Did you ever drive Jane No. 103 anywhere? 25 TIM WITNESS: At the instruction of my lawyer, 16 (Pages 425 to 428) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d1499-0cd8-4599-a2a043438827b68c8 3501.125-027 CONFIDENTIAL Page 16 of 21 EFTA_00065428 EFTA01246574 Page 429 Page 431 1 I must exercise my Fifth Amendment right. 1 MR. : Same instruction. same 2 BY MS. EZELL: 2 objection. 3 Q. Do you recall telling — no, sorry. 3 THE WITNESS: At the instruction of my lawyer, 4 Did you and Jane No. 103 become friendly? 4 I must invoke my Fifth Amendment right. 5 MR. Object to the form, lack of 5 BY MS. EZELL: 6 foundation as to any relationship with Jane No. 103 6 Q. Did, did you give yourself Jane No 103 any 7 or knowledge of a person named Jane No. 103. 7 gifts? a Instruct the witness not to answer. 8 MR. : I'm sorry. can you rephrase? 9 THE WITNESS: At the instruction of my lawyer, 9 BY MS. EZELL: 10 I must invoke my Fifth Amendment right. 10 Q. Didyou ourself give Jane No 103 any gifts? 11 BY MS. F7Fil I • 11 MR. : Objection to the form. 12 Q. Do you remember that Jane No. 103 came to 12 Instruct the witness not to answer the question. 13 Mr. Epstein's home on or about July 23rd. 2004? 13 THE WITNESS: At the instruction of my lawyer, 14 MR. Object to the form, leading. as 14 I must invoke my Fifth Amendment right. 15 well as previously stated objection to the last 15 BY MS. EZELL: 16 question. 16 Q. Did you ever buy gifts for Jeffrey Epstein to 17 BY MS. EZELL: 17 give to Jane No 103? 18 Q. And do ou remember -- 18 MR. : Objection to form. 19 MR. Hold on. 19 THE WITNESS: At the instruction of my lawyer, 20 MS. EZELL Sorry. 20 I must invoke my Fifth Amendment right. 21 THE WITNESS: At the instruction of my lawyer. 21 BY MS. EZELL: 22 I wish to invoke my Fifth Amendment right. 22 Q. Did you ever receive massages at the El Brillo 23 BY MS. F7Ft I • 23 Way house? 24 Q. Do you remember that Jane No. 103 continued tc 24 MR. : Objection to form, lack of 25 come to Mr. Epstein's house and indeed came over 100 25 foundation. Same instruction. Page 430 Page 432 1 times over about a •ear and a half? 1 THE WITNESS: At the instruction of my lawyer, 2 MR. : Object to the form for reasons 2 I must invoke my Fifth Amendment right. 3 previously stated in the last several questions. 3 BY MS. EZELL: 4 Instruct her not to answer. 4 Q. Did you receive massages given by 5 THE WITNESS: At the instruction of my lawyer, 5 ? 6 I must invoke my Fifth Amendment right. 6 MR. Objection to the form. lack of 7 BY MS. F7FI I • 7 foundation as to any knowledge of a person named 8 Q. Do you remember calling to tell Jane No. 103 8 Lack of knowkdge as to any. lack 9 that Mr. Epstein would be coming in town and would like 9 of foundation as to any connection to EA Brillo 10 to see her? 10 Way. Instruct the witness not to answer. 11 MR. • Objection to form, instruct the 11 THE WITNESS: At the instruction of my lawyer. 12 witness not to answer. 12 I must invoke my Fifth Amendment right. 13 THE WITNESS: At the instruction of my lawyer. 13 BY MS. EZELL: 14 I must invoke my Fifth Amendment right. 14 Q. 15 BY MS. F7FII 1: 16 Q. Did you overhear Mr. Epstein himself call Jane 16 MR. It's been asked and answered. 17 No. 103 at her home? 17 objection to form. 18 MR. : Objection to the form, lack of 18 MS. P7PI T • No. I didn't ask about Monterey. 19 foundation as to any knowledge of Jeffrey Epstein. 19 California 20 Instruct her not to answer. 20 MR. You asked about any Edge Group 21 THE WITNESS: At the instruction of my lawyer, 21 meetings in California. and she said she has no 22 I must invoke my Fifth Amendment right. 22 idea what the Edge Group is. 23 BY MS. F7Ft 1 • 23 MR. GARCIA: I thought she took the Fifth on 24 Q. Did you and Jane No. 103 ever go shopping 24 that. 25 together? 25 MR. I thought she said she didn't 17 (Pages 429 to 432) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d1499-0a18-4599-a2a0-6d38827b68c6 3501.125-027 CONFIDENTIAL Page 17 of 21 EFTA_00065429 EFTA01246575 Page 433 Page 435 1 know what the Edge Group was, but whatever. you car 1 BY MS. F7FI I • 2 answer the question. 2 Q. Do you want to respond? I didn't give you 3 THE WITNESS: At the instruction of my lawyer. 3 time. 4 I must choose to invoke my Fifth Amendment right. 4 MR. : I've instructed her not to 5 BY MS. EZELL: 5 answer the question. Let's move on. 6 Q. Do ou know Max Brockman? 6 BY MS. EZELL: 7 MR. : I'm sorry. can you repeat? 7 Q. Do you recall a dinner at El Brillo Way 8 BY MS. EZELL: 8 attended by David Copperfield where Jane No. 103 was a 9 Q. Do ou know a Max Brockman? 9 guest? 10 MR. : I believe that was asked and 10 MR. : Objection to the form, lack of 11 answered already. but -- 11 foundation, and a standing objection as to her 12 THE WITNESS: At the instruction of my lawyer. 12 knowledge of anything involving El Brillo Way or 13 I must invoke my Fifth Amendment right. 13 Jeffrey Epstein. Instruct her not to answer. 14 BY MS. EZELL: 14 THE WITNESS: At the instruction of my lawyer. 15 Q. Have you ever been photographed with Max 15 I must invoke my Fifth Amendment right. 16 Brockman at an Edge Science dinner? 16 BY MS. F7FI I • 17 A. At the instruction of my lawyer. I must invoke 17 Q. What is the relationship between Jeffrey 18 my Fifth Amendment ri ht. 18 Epstein and David Co rfield? 19 MR. : You should let me -- I need to 19 MR. : Objection to form, lack of 20 object to the form of the question first, but go 20 foundation as to her knowledge of either one of 21 ahead. I know we all want to get out of here. Go 21 those people. Instruct her not to answer. 22 ahead. 22 THE WITNESS: At the instruction of my lawyer. 23 THE WITNESS: Say it again. 23 I must invoke my Fifth Amendment right. 24 MR. : No. you are okay. Go ahead, 24 BY MS. F7FI I • 25 Ms. Ezell. Thank you. 25 Q. To your knowledge, do they recruit girls for Page 434 Page 436 1 BY MS. EZELL: 1 one another? 2 Q. Do you know whether Jeffrey Epstein attended 2 MR. : Object to the form. compound 3 the Edge Science dinner in Monterey, California? 3 and again, lack of foundation. Instruct her not to 4 MR. Objection to the form, lack of 4 answer. 5 foundation. Instruct the witness not to answer. 5 THE WITNESS: At the instruction of my lawyer, 6 THE WITNESS: At the instruction of my lawyer, 6 I must invoke my Fifth Amendment right. 7 I must invoke my Fifth Amendment right. 7 BY MS. EZELL: 8 BY MS. F7Ft I • 8 Q. To your knowledge. are they involved in any 9 0 9 sexual traffickin of oung women? 10 MR. : Object to the form for the 11 reasons previously stated. Also calls for a legal 12 conclusion as to what sexual trafficking is. 13 At what a e were those photographs taken? 13 Instruct her not to answer. 14 MR. I'm going to instruct her not 14 THE WITNESS: At the instruction of my lawyer, 15 to answer that. It has nothing to do with 15 I must invoke my Fifth Amendment right. 16 anything. It's not reasonably calculated to lead 16 BY MS. EZELL: 17 to discoverable evidence. We can move on. 17 Q. I believe you asked about Allen Dershowitz 18 BY MS. EZELL: 18 earlier. 19 Q. Were you in any way damaged by that 19 MR. : Twice. 20 experience? 20 BY MS. EZELL: 21 MR. Same instruction. Let's move 21 Q. And were instructed not to answer. 22 on. 22 MR. : Twice. 23 BY MS. EZELL: 23 BY MS. EZELL: 24 Q. Do ou have an regrets? 24 Q. All right. I'm going to ask again on behalf 25 MR. . Same instruction. Move on. 25 of my client. Are you aware or the friendship betw cell 18 (Pages 433 to 436) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d149941ed11-4599-a2a0-6d38827b68e6 3501.125-027 CONFIDENTIAL Page 18 of 21 EFTA_00O65430 EFTA01246576 Page 437 Page 439 1 Allen Dershowitz and Jeffrey Epstein? 1 BY MS. EZELL: 2 MR. : And for the third time. I'll 2 Q. Do you know that when David Coppetheld is in 3 object to the form and instruct her not to answer 3 town. he gives Jeffrey Epstein tickets and Jeffrey gives 4 the question. 4 some to your women to attend those shows? 5 THE WITNESS: For the third time. I take the 5 MR. Object to the form, multiple. 6 advice of my lawyer and invoke my Fifth Amendment 6 compound question. and a complete lack of 7 right. 7 foundation. Instruct the witness not to answer. 8 BY MS. EZELL: 8 THE WITNESS: At the instruction of my lawyer. 9 Q. When Allen Dershowitz comes to Palm Beach. he 9 I must invoke my Fifth Amendment right. 10 stays at the El Brillo mansion, doesn't he? 10 BY MS. EZELL: 11 MR. : Objection to the form. There 11 Q. And do you know that those girls are invited 12 is no foundation for her having any knowledge of 12 back stage after the show? 13 anything having to do with a person by the name of 13 MR. . Same objection. complete lack 14 Allen Dershowitz. I instruct her not to answer. 14 of foundation, and standing objection previously 15 THE WITNESS: At the instruction of my lawyer. 15 stated. 16 I must invoke my Fifth Amendment right. 16 THE WITNESS: At the instruction of my lawyer. 17 BY MS. EZELL: 17 I must invoke my Fifth Amendment right. 18 Q. When Allen Dershowitz. or has Allen Dershowitz 18 BY MS. EZELL: 19 ever been there when oung ladies came to give massages' 19 Q. Do you remember on or about, in or about March 20 MR. : Same objection stated to the 20 of 2005 having conversations with one of the young women 21 previous question. Same instruction. 21 who came to the house to give massages about her 22 THE WITNESS: At the instruction of my lawyer. 22 conversations with Jane No. 103? 23 I must invoke my Fifth Amendment right. 23 MR. Objection to the form, standing 24 BY MS. F7F/ i - 24 objection. lack of foundation. Instruct the 25 Q. Has Allen Dershowitz ever been the beneficiary 25 witness not to answer, because the question implies Page 438 Page 440 1 of those masse es? 1 that she has any knowledge at all of El Brillo Way. 2 MR. Same objection and same 2 BY MS. EZELL: 3 instruction. 3 Q. Same question -- sorry. 4 THE WITNESS: At the instruction of my lawyer, 4 A. At the instruction of my lawyer. I must choose 5 I must invoke my Fifth Amendment right. 5 to invoke my Fifth Amendment privilege. 6 BY MS. EZELL: 6 Q. Same • uestion as to March of 2006. 7 Q. Do you know John Casablanca? 7 MR. Same objection and same 8 A. Never heard that name before. 8 instruction. 9 Q. Have you ever heard of a world-famous 9 THE WITNESS: At the instruction of my lawyer, 10 illusionist whose stage name is David Copperfield? 10 I must choose to invoke my Fifth Amendment 11 MR. That's also been asked at least 11 privilege. 12 three times. I'll instruct her again not to answer 12 BY MS. EZELL: 13 the question. 13 Q. Do you have an of a conversation 14 THE WITNESS: At the instruction of my lawyer, 19 in which one of the = women told Jane No. 103 that 15 I must invoke my Fifth Amendment right. 15 those girls who, those girls who would help Jeffrey in 16 BY MS. EZELL: 16 regard to the investigation would be compensated and 17 Q. Have you ever gone to one of David 17 those who would not or who would hurt him in the 18 Copperfield's shows? 18 investigation would be dealt with? 19 MR. Objection to form, lack of 19 MR. : Objection to the form, lack of 20 foundation as to knowledge of any person by the 20 foundation, compound question. Instruct the 21 name of David Copperfield. Instruct her not to 21 witness not to answer, because the question implies 22 answer. 22 some knowledge of anything relating to a person by 23 THE WITNESS: At the instruction of my lawyer. 23 the name of Jeffrey Epstein. 24 I must invoke my Fifth Amendment right. 24 THE WITNESS: At the instruction of my lawyer, 25 25 I must invoke my Fifth Amendment right. 19 (Pages 437 to 4 40) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d1499-04:48-4599-a2a0-8d38827b88e8 3501.125-027 CONFIDENTIAL Page 19 of 21 EFTA_00065431 EFTA01246577 Page 441 Page 443 1 By MS. F7Fil I: 1 BY MS. EZELL: 2 Q. Do you know John Brockman? 2 Q. Did you escort those underage girls to the 3 A. At the instruction of my lawyer. I must invoke 3 massage room where the defendant would enter and urg 4 my Fifth Amendment right. 4 the girls to remove their clothes? 5 Q. Do you know of someone named Brockman being 5 MR. : Objection to the form, asks a 6 the editor and publisher of a publication of the Edge 6 compound question. several questions within one. 7 Foundation? 7 Also assumes knowledge of a person by the name 8 MR. : Object to the form. There is 8 of Jeffrey Epstein and a massage room, so there is 9 no foundation that she has any knowledge of any 9 no foundation. Instruct the witness not to answer. 10 entity by the name of the Edge Foundation, and I 10 THE WITNESS: At the instruction of my lawyer, 11 would instruct her not to answer the question based 11 I must invoke my Fifth Amendment right. 12 on her Fifth Amendment privilege. 12 BY MS. EZELL: 13 THE WITNESS: At the instruction of my lawyer. 13 Q. Did you ever tell the girls to remove their 14 I must invoke my Fifth Amendment right. 14 clothes? 15 BY MS. F7F11 • 15 MR. : Same objection and the same 16 Q. Did you participate in a scheme by Jeffrey 16 instruction. 17 Epstein to recruit underage girls to come to his 17 THE WITNESS: At the instruction of my lawyer, 18 residence to .rovide massages? 18 I must invoke my Fifth Amendment right. 19 MR. : Objection to the form, calls 19 BY MS. EZELL: 20 for a legal conclusion. Also has no foundation as 20 Q. And did you sometimes deliver cash from the 21 to any knowledge of a person by the name of Jeffrey 21 defendant to the underage girls after they performed the 22 Epstein. and because it calls for a legal 22 massage? 23 conclusion. I'll simply instruct her not to answer 23 MR. : That's been asked at least 24 the question at all. Move on. 24 three or four other times. 25 25 MS. EZELL: I'm asking on behalf of my client. Page 442 Page 444 1 BY MS. F7Ft I • 1 MR. I understand, but we've been 2 Q. Did you assist, support. and facilitate 2 here for over an hour. and we can't just keep going 3 Jeffrey Epstein's child exploitation enterprise? 3 over. If they have been asked in the deposition. 4 MR. Once again, objection the 4 your clients can have the benefit of the answer, 5 question. calls for a legal conclusion as to what 5 but we've been here now for almost eight hours and 6 is an enterprise, which is a term of art in the 6 you still -- 7 criminal law about which this witness has no 7 THE WITNESS: At the instruction of my lawyer, 8 knowledge. and it's a legal conclusion not likely 8 I must invoke my Fifth Amendment right. 9 to lead to discoverable evidence. So I would 9 BY MS. EZELL: 10 instruct her not to answer the question at all. 10 Q. Did you ever take pan in delivering cash from 11 BY MS. EZELL: 11 the defendant to the procurers of the underage girls who 12 Q. Did you arrange times for underage girls to 12 came for the massy e a intments? 13 come to Jerrie tein's residence? 13 MR. : Objection to the form. The 14 MR. Objection to form, standing 14 term procure is a legal term of art, and I'll 15 objection previously stated. 15 instruct the witness not to respond to the question 16 THE WITNESS: At the instruction of my lawyer, 16 at all. 17 I must invoke my Fifth Amendment privilege. 17 BY MS. EZELL: 18 BY MS. EZELL: 18 Q. Did you. did you by using the telephone assist 19 20 21 Q. Did you arrange. transport, or yourself transport underage girls to or from Jeffrey Epstein's residence? 19 20 21 a Jeffrey Epstein in enabling himself to commit sexual on, and acts of lewdness in the presence of women? 22 MR. Same objection. same 22 MR. : Same as the previous 23 instruction as the last question. 23 instruction. Instruct the witness not to answer 24 THE WITNESS: At the instruction of my lawyer. 24 the question at all, because it results in a legal 25 I must invoke my Fifth Amendment privilege. 25 question. not a factual question. so it's not 20 (Pages 441 to 4 4 4) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (IMMMI) 905d1499-0cd8-4599-a2a0-6c1391327b68c6 3501.125-027 CONFIDENTIAL Page 20 of 21 EFTA_00065432 EFTA01246578 Page 445 Page 447 1 reasonably designed to lead to discoverable 1 deposition or you may waive reading and allow the 2 evidence. 2 court reporter to simply type it up and distribute 3 BY MS. F7Ft I • 3 it to the lawyers who order it. 4 Q. Did you facilitate these acts as well as 4 Do you choose to read or waive? 5 assisting Mr. E rein in avoiding police detection? 5 THE WITNESS: Waive. 6 MR. Same instruction. 6 MS. EZELL: Thank you. 7 BY MS. EZELL: 7 MR. Thank you. 8 Q. Do you know when and by whom the computers 8 THE VIDEOGRAPHER: Oka . this concludes 9 were removed from the El Brillo mansion? 9 today's videotape deposition of The 10 MR. Objection to the form, lack of 10 time is l8:51. 11 foundation, and it also assumes knowledge of a 11 (Witness excused.) 12 place known as the El Brillo mansion. So instruct 12 (Deposition was concluded.) 13 the witness not to answer the question based on the 13 14 Fifth Amendment. 14 15 THE WITNESS: At the instruction of my lawyer. 15 16 I must invoke my Fifth Amendment right. 16 17 BY MS. F7Fr I • 17 18 Q. Was Jane No. 103 invited to just come and hang 18 19 out at the El Brillo mansion? 19 20 MR. Objection to the form, same as 20 21 the previous question. It assumes knowledge of a 21 22 place known as the El Brillo mansion and a person 22 23 by the name of Jane No. 103. It is compound and 23 24 lacking in foundation. 24 25 THE WITNESS: at the instruction of my lawyer, 25 Page 446 Page 448 1 I must invoke my Fifth Amendment right. 1 CERTIFICATE 2 THE STATE OF FLORIDA 2 BY MS. EZELL: 3 COUNTY OF PALM BEACH 3 Q. Have you called any girls under the age of 18 4 4 in Palm Beach or West Palm Beach in the last six years? 5 I.Rachel W. Bridge. Registered Professional Reporter. Florida Professional Reporter and Notary 5 MR. For any purpose? 6 Public in and for the State of Florida at large, do 6 MS. EZELL: Yes. hereby certify that I was authorized to and did report 7 said deposition in stenotype: and that the foregoing 7 THE WITNESS: Can you repeat the question? pages am a true and correct transcription of my 8 BY MS. EZELL: 8 shorthand notes of said deposition. 9 Q. Have you called any girls under the age of 18 9 I further certify that said deposition was taken at the time and place hereinabove set forth and 10 in Palm Beach or West Palm Beach in the last six years? 10 that the taking of said deposition was commenced and 11 MR. You can answer that yes or no. completed as hereinabove set out. it 12 if you know. I further certify that I am not attorney or 13 THE WITNESS: I don't think so. 12 counsel of any of the panics. nor ant I a relative or 14 MS. EZELL: I don't have any other questions. employee of any attorney or counsel of party connected 13 with the action. nor am I financially interested in the 15 Thank you. action. 16 THE VIDEOGRAPHER: All set? 14 17 The foregoing certification of this transcript MR. Yes. 15 does nor apply to any reproduction of the same by any 18 THE VIDEOGRAPHER: This concludes today's means unless under the direct control andfor direction 19 videotape deposition of 16 of the certifying reporter. 17 Dated this 9th day of April. 20 MR. Hold on. I'm sorry, one last 18 21 thing. Since you're the last defense person or 19 20 22 plaintiffs lawyer standing. I guess you need to 21 RR. FPR 23 advise her she has the right to read or waive on 22 24 the record. 23 24 25 MS. EZELL: You do have the right to read this 25 21 (Pages 445 to 4 48) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge 905d1499-0,48-4599-a2a0-6d3882713418e6 3501.125-027 CONFIDENTIAL Page 21 of 21 EFTA_00065433 EFTA01246579