EFTA01246832

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendants. / Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-8-591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF TAKEN ON BEHALF OF THE PLAINTIFF DATE: April 13, 2010 U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 1 of 38 EFTA_00067613 EFTA01246832 2 4 April 13,2010 APPEARANCES (CONTINUED) 2 LEOPOLD-KUVIN 2 INDEX wilwiIfs 3 WITNESS DIRECT CROSS REDIRECT RECROSS 3 4 4 5 BY MR. EDWARDS 5 98 6 BY MR. HOROWITZ 65 S BY: ADAM J. LANGINO, ESQ. 6 7 BY MR. LANGINO 77 7 8 BY MS. EZELL 81 PODIRMST, ORSECK 8 AllOmtp (calm Does I sad 3 Hu& Building. Suite )38 10 EXHIBITS 11 PLAINTIFF'S 10 FOR IDENTIFICATION PAGE BY: KATHERINE W. EZELL, ESQ. 11 12 12 BURMAN. CROTON. LUTTIER & COLEMAN, III' I Message dated August 21, 2005. 45 pstein 13 13 14 14 BY: DAVID YAREMA, ESQ. 15 15 ROBERT CRITION. ESQ. 16 16 ATTERBURY, GOLDBERGER & WEISS 17 17 I for Defendants 18 19 18 20 t9 21 BY: JACK A. GOLDBERGER. ESQ. 20 22 21 ALSO PRESENT: 23 22 JESSICA CADWEU. JOE ROVNER. Yid:n(40W 24 23 (US. Legal) 25 24 25 3 m i. to deposition of 1 THEREUPON. i in the above-entitled and numbered 2 3 cause, was taken before me, TERRI BECKER, a 4 Registered Professional Reporter and Notary 3 being by Terri Becker first duly sworn to tell 5 Public for the State of Florida at Large, at 444 4 the whole truth, as hereinafter certified, 6 West Railroad Avenue, in the City of West Palm 5 testified as follows: 7 Beach. Palm Beach County, in the State of 8 Florida, beginning at the hour of 10:00 o'clock 6 DIRECT EXAMINATION 9 a.m., pursuant to the Notice in said cause far 7 BY MR. EDWARDS: 10 the taking of said deposition which is annexed to 8 Q Can you tell us your name. 11 the court file herein, on behalf of the PLAINTIFF 12 in the above-entitled action pending in the 9 A 13 above-named coon. 0 Q What Is your dale of birth? 14 The appearances at said lime and place 1 A 15 were as follows: 16 12 Q What Is your Social Security number? FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL 13 A Under advice of my counsel, 1 invoke my 17 legs Plaintiffs Jane Does, 14 privileges under the Fifth and Sixth Amendments 15 to the United States Constitution and 18 16 respectfully decline to answer the question. 17 Q Where were you born? 18 A I'm sorry, though I would like to answer 20 BY: BRADLEY J. EDWARDS, ESQ. 21 19 your question, l must invoke my Fifth and Sixth MERMELSTEIN & HOROWITZ P.A. 20 Amendment privileges and refuse to answer your 22 Attorneys for Plaintiffs Jane Does, 21 questions. 23 22 Q What is your current address? 23 MR. GOLDBERGER: There is going to be a 24 continued, obviously, you anticipate I'm 25 BY: ADAM D. HOROWITZ. ESQ. 25 sure, continued invocation of Fifth 2 (Pages 2 to 5) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 2 of 38 EFTA 00067614 EFTA01246833 6 1 Amendment privileges. If it is okay with 1 A The Fifth. 2 all counsel, to shorten things, I'll simply 2 Q Do you know a lady by the name of 3 have the witness say -Filth,. if that 3 Maritsa Vazques? 4 satisfies everyone's interest. 4 A The Fifth. 5 MR. EDWARDS: That is fine with me. 5 Q Is this somebody who helped to falsify a MR. GOLDBERGER: Okay, with that Cathy? 6 visa for you? 7 MS. EZELL: Yes. 7 MR. YAREMA: Object to the form. 8 MR. HOROWITZ: Yes. A The Fifth. 9 Q I'll reask the question, what's your 9 Q Do you know Evelyn Velasaques? 10 current address? 10 A The Fifth. 11 A Fifth. 11 Q Were you ever a working model hat ilw 12 Q Are you currently living at 358 El 12 United States? 13 SHIM Way with a man named Jeffrey Epstein? 13 A The Fifth. 14 A The Fifth. 14 Q Can you tell us youi parents' names? 15 Q Are you also familiar with an address in 15 A The Fifth. 16 New York, 301 East 66th Street? 16 Q How is it that you have supported 17 A The Fifth. 17 yourself financially, since you have been in this 18 Q When Mr. Epstein was incarcerated In 18 country? 19 Jail, you went to visit him on numerous 19 MR. YAREMA: Object to the form. 20 occasions; is that correct? 20 A The Fifth. 21 MR. YAREMA: Objection. 21 Q Have you supported yourself financially? 22 A The Fifth. 22 A The Fifth. 23 Q When you went to visit him you indicated 23 Q What Is the last grade you completed in 24 to jail personnel your address was 301 East 66th 24 school? 25 Street, apartment 8-D in New York City, New York; 25 A The Fifth, I take the Fifth Amendment. 7 9 1 Is that correct? 1 Q Are you in school now? 2 MR. YAREMA: Objection. 2 A The Fifth. 3 A Fifth. 3 Q Have you ever attended any school in the 4 Q Isn't it true when Mr. Epstein was in 4 United States? S jail, you visited him on more than 50 occasions? 5 A The Fifth. 6 MR. YAREMA: Form objection. 6 Q Have you ever been employed since 7 Q True? 7 residing in the United States? 8 A The Fifth. 8 A The Fifth. 9 Q How long have you been in the United 9 Q Is Jeffrey Epstein your sole means of 10 States, 10 financial support today? 11 A The Fifth. 11 MR. YAREMA: Object to the form. 12 Q Who brought you to the United States? 12 A The Fifth. 13 MR. YAREMA: Form objection. 13 Q Since coming to this country, hasn't 14 A The Fifth. 14 Jeffrey Epstein always been your sole means of 15 Q What is your current status in this 15 financial support? 16 country? 16 MR. YAREMA: Object to the form. 17 A The Fifth. 17 A The Fifth. 18 MR. YAREMA: Form objection. 18 Q How much does Jeffrey Epstein pay you 19 MR. GOLDBERGER: Let me take a half a 19 today? 20 second. 20 MR. YAREMA: Object to the form. 21 (Witness and her counsel confer.) 21 A The Fifth. 22 Q Are you a U.S. citizen? 22 Q What does every Epstein pay you for? 23 A The Filth. 23 MR. YAREMA: Object to the form. 24 Q What type of visa are you here on? 24 A The Fifth. 25 MR. YAREMA: Form objection. 25 Q Does he pay you specifically to be his 3 (Pages 6 to 9) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 3 of 38 EFTA_00067615 EFTA01246834 10 12 1 sex slave? 1 Epstein's sex slaves? 2 MR. YAREMA: Object to the form. 2 MR. YAREMA: Object to the Ism 3 A The Fifth. 3 A Fifth. 4 Q Are you aware that the reports about you 4 Q What does it mean to be JelTrey 5 Indicate that you were brought to the United 5 Epstein's sex slave? 6 States by Jeffrey Epstein when you were roughly 6 MR. YAREMA: Object to the font. 7 13 or 14 years old to be his lesbian 7 A Fifth. 8 sex slave? 8 Q Are you aware that Jeffrey Epstein reads 9 MR. YAREMA: Object to the form. 9 books on how to be a proper master to his sex 10 A Thc Fifth. 10 slave? 11 Q Is that true? 11 MR. YAREMA: Object to the Iona. 12 MR, YAREMA: Object to the lomt 12 A Fifth. 13 A The Fifth. 13 Q What has Jeffrey Epstein done to train 14 Q Have you performed any services for 14 you to be his sex slave? 15 Jeffrey Epstein aside front being his sex slave? 15 MR. YAREMA: Object to the form. 16 MR. YAREMA: Object to the form. 16 A Fifth. 17 A The Fifth. 17 Q What do your parents think about you 18 Q What is your sexual orientation? 18 being Jeffrey Epstein's sex slave? 19 MR. YAREMA: Object to the Iona. 19 MR. YAREMA: Object to the form. 20 MR. GOLDBERGER: I'm going to instruct 20 A Fifth. 21 the witness not to answer that question. It 21 Q When did you first learn that Jeffrey 22 serves no purpose other than to harass or 22 Epstein had a sexual obsession for underage minor 23 intimidate her, so in addition to Fifth 23 females? 24 Amendment privileges, I'm objecting on 24 MR. YAREMA: Object to the form. 25 privacy grounds. 25 A Fifth. 11 13 1 A I take the Fifth. 1 Q How many times has Jeffrey Epstein made Q I represent a lady named, a young female 2 you have sex with underage minor females? 3 named S; you know who that is, right? 3 MR. YAREMA: Object to the Porn. 4 MIL YAREMA: Object to the form. 4 A Filth. 5 A The Fifth. 5 Q Do you enjoy sex with underage minor 6 Q Jeffrey Epstein made you have sex with 6 females? 7 didn't he? 7 MR. YAREMA: Object to the fort. 8 MR: YAREMA: Object to the form. 8 A Fifth. 9 A The Fifth. 9 Q What is the youngest child that Jeffrey 10 Q You did, In fact, engage in sexual 10 Epstein has forced you to have sex with? 11 activity with M. when she was only 16 years 11 MR. YAREMA: Object to the fonts. 12 old; isn't that true? 12 A Fifth. 13 MR. YAREMA: Object to the form. 13 Q Does Jeffrey Epstein today still make 14 A The Fifth. 14 you have sex with underage minor females? 15 Q Back to my original question: And I'll 15 MR. YAREMA: Object to the form. 16 ask you this way: Do you consider yourself 16 A Fifth. 17 heterosexual, bl-sexual, or can you answer that 17 Q How many underage minor females has 18 question? 18 Jeffrey Epstein made you have sex with, since you 19 MR. YAREMA: Object to the form. 19 were over the age of 18? 20 MR. GOLDBERGER: Same objection. Do not 20 MR. YAREMA: Object to the fonn. 21 answer the question. 21 A Thc Fifth. 22 A Fifth. 22 Q Prior to turning 18, is it true that 23 Q How did you meet Jeffrey Epstein? 23 Jeffrey Epstein made you have sex with many other 24 A Fifth. 24 children in kid-type orgies? 25 Q When did you become one of Jeffrey 25 MR. YAREMA: Object to the fonn. 4 (Pages 10 to 1 3) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 4 of 38 EFTA_00067616 EFTA01246835 14 16 1 A Filth. 1 A Fifth. 2 Q Has Jeffrey Epstein also made you 2 Q Have you read the nonprosecution 3 perform sexually on his friends? 3 agreement between the government and Jeffrey 4 MR. YAREMA: Object to the form. 4 Epstein? 5 A Fifth. 5 A Fifth. 6 Q Do you know David Copperfield? 6 Q Are you aware that inside that document 7 MR. YAREMA: Object to the form. 7 you are labeled as a co-conspirator of his crimes 8 A Fifth. 8 against children? 9 Q Have you ever been made to perform 9 MR. YAREMA: Object to the form. 10 sexually on David Copperfieki? 10 A Fifth. 11 MR. YAIIEMA: Object to the form. 11 Q Isn't it true that your role was to lure 12 A Fifth. 12 or procure underage minor females to Jeffrey 13 Q Do you know Prince Andrew? 13 Epstein for him to molest, correct? 14 A Fifth. 14 MR. YAREMA: Object to the fonn. 15 Q Have you ever been made to perform 15 A Fifth. 16 sexually on Prince Andrew? 16 Q You also scheduled appointments for 17 MR. YAREMA: Object to the form. 17 Jeffrey Epstein, so there would be designated 18 A Fifth. 18 times for Jeffrey Epstein to molest underage 19 Q When was the first time that you knew 19 minor females, correct? 20 Jeffrey Epstein molested underage girls? 20 MR. YAREMA: Object to the fonn. 21 MR. YAREMA: Object to the form. 21 A The Fifth. 22 A Fifth. 22 Q As well, you participated in various sex 23 Q Did Jeffrey Epstein molest you when you 23 acts with underage minor females, thus molesting 24 were underage? 24 them yourself; is that correct? 25 MR. YAREMA: Object to the form. 25 MR. YAREMA: Object to the font 15 17 1 A Fifth. 1 A Fifth. 2 Q I'm assuming you understand why you're 2 Q Do you understand that Jeffrey Epstein's 3 here today, correct? 3 interaction with underage minor females is 4 MR. YAREMA: Object to the fonn. 4 Illegal? Do you understand that? S A The Fifth. 5 MR. YAREMA: Object to the form. 6 Q For allegations related to Jeffrey 6 A The Fifth. 7 Epstein interacting sexually with numerous 7 Q Do you understand that the Lewd and 8 underage minor females; that's something you 8 Lascivious Molestation Statute In Florida 9 know, right? 9 indicates a person who Intentionally touches in a 10 MR. YAREMA: Object to the form. 10 lewd or lascivious manner, the breasts, genital 11 A The Fifth. 11 area or buttocks, or the clothing covering them, 12 Q That's something In addition to the 12 of a person less than 16 years of age, or forces 13 civil lawsuits, there were criminal cases 13 or entices a person under 16 years of age, to so 14 involving the same conduct, correct? 14 touch the perpetrator, commits lewd or lascivious 15 MR. YAREMA: Object to the feta 15 molestation? Are you aware of that statute? 16 A Fifth. 16 A Fifth. 17 Q You were a part of that CaMillai 17 Q That is a statute that you know Jeffrey 18 Investigation, in fact, you were a co-conspirator 18 Epstein to have violated; Is that true? 19 of Jeffrey Epstein's; is that right? 19 MR. YAREMA: Object to the form. 20 MR. YAREMA: Object to the form. 20 A The Fifth. 21 A Fifth. 21 Q That's a statute that you yourself have 22 Q What crimes did you conspire to commit 22 violated; is that true? 23 with Jeffrey Epstein against underage minor 23 MR. YAREMA: Object to the form. 24 females? 24 A The Fifth. 25 MR. YAREMA: Object to the tom. 25 Q You've observed Jeffrey Epstein violate 5 (Pages 14 to 17) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 5 of 38 EFTA_00067617 EFTA01246836 18 20 that statute on many underage minor females, 1 co-conspirator in the non-prosecution agreement 2 true? 2 related to Jeffrey Epstein's crimes against 3 MR. YAREMA: Object to the font 3 minors? 4 A The Filth. 4 MR. YAREMA: Object to the form. 5 Q (lave you ever discussed with Jeffrey 5 A Fifth. 6 Epstein that the fact that he is a child 6 Q Do you know or molester? 7 8 MR. YAREMA: Object to the form. a A Fifth. 9 A Filth. Q These are all people who also t0 Q Have you asked Jeffrey Epstein why he 10 participated in Jeffrey Epstein's scheme to lure has made you interact with underage minor females 11 underage females to him for sex; is that true? 12 in a sexual manner? 12 MR. YAREMA: Object to the form. 13 MR. YAREMA: Object to the fon% 13 A Fifth. 14 A Filth. 14 Q You and these other co-conspirators 15 Q During the litigation of these civil 15 played various roles to make sure Jeffrey Epstein 16 cases, has Jeffrey Epstein indicated to you an 16 was able to engage In sexual contact or conduct, 17 intent to continue to molest children? 17 with underage minor females on an everyday basis; 19 MR. YAREMA: Object to the loon. 18 is that true? 19 A Fifth. 19 MR. YAREMA: Object to the form. 20 Q Is it your intent to continue to commit 20 A Fifth. 21 sex crimes against minors? 21 Q Since the time you first met Jeffrey 22 MR. YAREMA: Object to the form. 22 Epstein, has his appetite for underage minor 23 A Fifth. 23 females always been the same? 24 Q In addition to your being named as a 24 MR. YAREMA: Object to the form. 25 co-conspirator of Jeffrey Epstein regarding his 25 A Fifth. 19 21 crimes against minors, there is also a person 1 Q By that I mean, have you observed named listed as a co-conspirator. 2 Jeffrey Epstein to interact sexually with 3 Do you know 3 underage minor females literally on a doily 4 A Fifth. 4 basis? 5 Q This Is somebody who lives with you and MR. YAREMA: Object to the form 6 Jeffrey Epstein; Is that true? 6 A Fifth. 7 MR. YAREMA: Object to the four. 7 Q Wasn't it one of your specific job 8 A Filth. duties to make sure that he had different 9 Q And is somebody who you 9 underage minor females to molest on a daily 10 know to be girlfriend; is that 10 basis? 11 true? 11 MR. YAREMA: Object to the form. 12 MR. YAREMA: Object to the form. 12 A Fifth. 13 A Fifth. 13 Q In addition to the improper sexual 14 Q She's spoken with about 14 contact between Jeffrey Epstein and underage 15 this case on numerous occasions; is that true? 15 minor females at the West Palm Beach house, you 16 MR. YAREMA: Object to the form. 16 have observed similar improper and illegal 17 A Fifth. 17 contact by Jeffrey Epstein in his New York 18 conversations with= mansion, as well, correct? 19 and your observations of them, you believe 19 MR. YAREMA: Object to the form. 20 would implicate you in a crime and that's why 20 A Fifth. 21 you're able to take the Fifth as to that 21 Q In fact, he operates a very similar 22 question? 22 scheme up there, in that he schedules these 23 MR. YAREMA: Object to the fonn. 23 appointments with underage minor females, under 24 A Fifth. 24 the guise that it is going to be a massage; is 25 Q Who is Lesley Groff, also listed as a 25 that correct? 6 (Pages 18 to 21) U.S. Legal Support (561) 835 - 0220 CONFIDENTIAL 3501.144-028 Page 6 of 38 EFTA_00067618 EFTA01246837 22 24 1 MR. YAREMA: Object to the loon? 1 when Jeffrey Epstein commits these crimes against 2 A Fifth. 2 children? 3 Q When he is in New York, he has contact 3 MR. YAREMA: Object to the font 4 with underage minor females for the purposes of 4 A Fifth. 5 sexually molesting than as well; is that S Q Is there any way for you to escape being 6 correct? 6 his sex slave? 7 MR. YAREMA: Object to the fonn. 7 MR. YAREMA: Object to the form. 8 A Fifth. 8 A Fifth. 9 Q When he is in his ranch in New Mexico, 9 Q Have you ever wanted to cooperate with 10 similarly, Jeffrey Epstein is engaging in sex 10 the authorities, so that you could escape being 11 with underage minor females from that local area 11 his sex slave? 12 as well, and that's something you've observed? 12 MR. YAREMA: Object to the fonn 13 MR. YAREMA: Object to the fonn. 13 A Fifth. 14 A Fifth. 14 Q Do you represent to others that you are 15 Q On his island, particularly, he has 15 his girlfriend or his sex slave, or sonic other 16 flown underage minor females to the island for 16 designation? 17 underage kid-type orgies; is that true? 17 MR. YAREMA: Object to the form. 18 MR. YAREMA: Object to the form. 18 A Fifth. 19 A Fifth. 19 Q Isn't it true that you recently 20 Q You're shaking your head indicating, at 20 represented to the Probation Officer that you 21 least to me, indicating that you may not agree 21 were his live-In girlfriend? 22 with what I'm saying, and I would love to give 22 MR. YAREMA: Object to the form. 23 you the chance to explain it to us. 23 A Fifth. 24 MR. GOLDBERGER: I appreciate that, but 24 Q When Probation calls the house, are you 25 don't — 25 told to tell Probation that he is in the swimming 23 25 1 MR. EDWARDS: Read too much into it? 1 pool or doing some other activity that would not 2 MR. GOLDBERGER: Exactly. Don't go 2 allow him to come to the telephone? 3 there. Just ask the questions and we will 3 MR. YAREMA: Object to the fonn. 4 move right along. 4 A Fifth. 5 MR. EDWARDS: I agree, Jack, I just know S Q Isn't It true you're under strict orders 6 if this is played for a jury, I don't want to tell Probation that? 7 the jury to interpret her shaking ha head 7 MR. YAREMA: Object to the fonn. 8 as a "No." and then her pleading the Fifth. 8 A Filth. 9 MR. GOLDBERGER: I appreciate that. 9 Q Isn't it true you've heard Jeffrey 10 Don't take anything as to any head movements 10 Epstein tell you on numerous occasions, regarding 11 or any body movements at all. Just ask the 11 the age of the girls that he wants to his house, 12 questions and we will let the video speak 12 for the purposes of sexually molesting, the 13 for itself. 13 phrase he uses is "the younger the better," 14 Q How many of these — you know what an 14 true? 15 orgy Is, don't you? 15 MR. YAREMA: Object to the form. 16 A Fifth. 16 A Fifth. 17 Q And how many of these orgies, as I'm 17 Q I asked you earlier about M. out of 18 calling them, where there are numerous underage 18 turn as a result of an objection related to your 19 minors having sex with each other and with 19 sexual orientation, but I'll talk specifically 20 Jeffrey Epstein, have you observed on Jeffrey 20 about.. right now. You know who that Is, 21 Epstein's island? 21 right? 22 MR. YAREMA: Object to the form. 22 MR. YAREMA: Object to the form. 23 A Fifth. 23 A Fifth. 24 Q Is part of your role as Jeffrey 24 Q That is somebody you observed Jeffrey 25 Epstein's sex stave, to not tell the authorities 25 Epstein to call for the purposes of getting her 7 Pages 22 to 25) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 7 of 38 EFTA_00067619 EFTA01246838 26 28 to his house to sexually molest; Is that right? 1 minor females? 2 MIL YAREMA: Object to the font 2 MR. YAREMA: Object to the form. 3 A Fifth. 3 A Fifth. 4 Q The first time she went to Jeffrey 4 Q You have received oral sex front underage 5 Epstein's house was in 2002 when she was only 14 5 minor females? 6 years old; Is that true? 6 MR. YAREM A: Object to the fonn. 7 MR. YAREMA: Object to the font,. 7 A Fifth. A Fifth. 8 Q All of these sexual acts with minor 9 Q In fact in 2002 you were only 18 years 9 females involving you happened in the presence of 10 old or so yourself; is that right? 10 Jeffrey Epstein? 11 A Fifth. 11 MR. YAREM A: Object to the bona. 12 Q And M. is somebody you observed at 12 A Fifth. 13 Jeffrey Epstein's house on more than 100 13 Q During your interaction with underage 14 occasions between 2002 and 2005, a time period 14 minor females in a sexual manner, isn't it true 15 between 14 and 17 years of age for her; is that 15 that Jeffrey Epstein would participate in the 16 right? 16 sexual acts and the act would be over upon 17 MR. YAREMA: Object to the font,. 17 Jeffrey Epstein ejaculating, correct? 18 A Fifth. 18 MR. YAREMA: Object to the font,. 19 Q And each time M. was summoned to 19 A Filth. 20 Jeffrey Epstein's house, it was for the purposes 20 Q Did Jeffrey Epstein tell you, that when 21 of Jeffrey Epstein sexually molesting her, 21 M. was an underage minor female, he forced her 22 correct? 22 to give hint oral sex? 23 MR. YAREMA: Object to the form. 23 MR. YAREMA: Object to the font 24 A Fifth. 24 A Fifth. 25 Q If it was not Jeffrey Epstein personally 25 Q Do you remember coming over, • 27 29 1 calling ., you observed to call 1 young girl, with braces on, and going up Into 2 S for the purposes of her coming over and 2 Jeffrey Epstein's bedroom on numerous occasions 3 pleasing Jeffrey Epstein sexually, correct? 3 to be sexually molested? 4 MR. YAREMA: Object to the form. 4 MR. YAREMA: Object to the tons 5 A Fifth. 5 A Fifth. 6 Q And do you remember the instance where 6 Q Do you know when it was that Jeffrey 7 Jeffrey Epstein instructed you to lay down naked 7 Epstein developed his plan or scheme to gain and engage in a threesome with M. and Jeffrey access to hundreds of underage minor females for 9 Epstein? 9 the purposes of his sexual gratification? 10 MR. YAREMA: Object to the fonn. 10 MR. YAREMA: Object to the font 11 A Fifth. 11 A Fifth. 12 Q Do you remember that that during that 12 Q Were you a part of the planning of that 13 threesome, Jeffrey Epstein demanded M. to 3 scheme of Jeffrey Epstein's to gain access to 14 straddle you and otherwise engage sexually with 4 underage minor females? 15 you while Jeffrey Epstein was using vibrators 5 MR. YAREMA: Object to the form 16 and/or dildos on you? 6 A Fifth. 17 MR. YAREMA: Object to the fonts 7 Q Do you know Ohislaine Maxwell? 18 A Fifth. A Fifth. 19 Q In addition to your sexual interactions 9 Q Is that somebody who helped Jeffrey 20 with M., isn't it true that you have used 0 Epstein to devise the scheme to allow hint access 21 strap-on dildos and vibrators on other underage 1 to various and a variety of underage minor 22 minors at Jeffrey Epstein's direction? 2 females? 23 MR. YAREMA: Object to the form. 3 MR. YAREMA: Object to the 24 A Fifth. 4 A Fifth. 25 Q You have given oral sex to underage 5 Q Is somebody that was also B (Pages 26 to 29) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 8 of 38 EFTA_00067620 EFTA01246839 30 32 1 Involved In the planning of this scheme to gain 1 sex toys on you, correct? 2 access to underage minor females? 2 A Fifth. 3 MR. YAREMA: Object to the fonn. 3 Q And he has instructed you to use sex A Filth. 4 toys and vibrators on other underage minor 5 Q When Is the first time that you observed 5 females, correct? 6 Jeffrey Epstein's method of enticing or inducing 6 MR. YAREMA: Object to the form. 7 underage minor females into sexual acts with him 7 A Fifth. 8 inside his bedroom? 8 Q You have observed Jeffrey Epstein 9 MR. YAREMA: Object to the form. 9 digitally penetrate the vagina of underage minor 10 A Fifth. 10 females, Including •., correct? 11 Q Isn't it trite that after an underage 11 MR. YAREMA: Object to the fonn. 12 minor female was brought to Jeffrey Epstein's 12 A Fifth. 13 house, typically or or 13 Q As pan of his plait to avoid detection 14 yourself would lead that underage minor female to 14 by law enforcement, you have observed Jeffrey 15 Jeffrey Epstein's bedroom and leave them atone do 15 Epstein to pay these underage minor females to be 16 the room; is that true? 16 quiet, correct? 17 MR. YAREMA: Object to the fonn. 17 MR. YAREMA: Object to the form. 18 A Fifth. 16 A Fifth. 19 Q Then Jeffrey Epstein would appear either 19 Q And this is something that he has told 20 naked or wearing a towel; is that true? 20 you he does, for the purposes of grooming these 21 MR. YAREMA: Object to the form. 21 underage minor females, and avoiding law 22 A Fifth. 22 enforcement detection, correct? 23 Q This Is his habit or method of 23 MR. YAREMA: Object to the form. 24 operation, every single time, and that's 24 A Fifth. 25 something that he has told you about his sexual 25 Q Jeffrey Epstein has talked to you about 31 33 1 interaction with underage minors; is that true? 1 the psychology of brainwashing or grooming 2 MR. YAREMA: Object to the form. 2 underage minor females to perform for him 3 A Fifth. 3 sexually, hasn't he? 4 Q And he would direct or demand or 4 MR. YAREMA: Object to the fonn. 5 Instruct the underage minor female to remove her 5 A Fifth. 6 clothing; is that true? 6 Q And has also spoken with 7 MR. YAREMA: Object to the form. 7 you about the methodology behind gaining access 8 A Fifth. 8 to and grooming underage minor females for sex? 9 Q Then he would perform one or more lewd 9 MR. YAREMA: Object to form. 10 or lascivious or sexual acts on the underage 10 A Fifth. 11 minor female. Is that true? 11 Q Isn't it true that Ghislaine Maxwell and 12 MR. YAREMA: Object to the form. 12 yourself and had access to a master 13 A Fifth. 13 Ilst of underage minor remain names and phone 14 Q And you have observed Jeffrey Epstein 14 numbers so that they could be called? 15 engage in sexual interaction with underage minor 15 MR. GOLDBERGER: Time out. Are you 16 females on hundreds and hundreds of occasions, 16 talking to me, counsel? 17 correct? 17 MR. HOROWITZ: Nodding my head, back at 18 MR. YAREMA: Object to the font 18 you. You were nodding at me. 19 A Fifth. 19 MR. GOLDBERGER: I wasn't nodding at 20 Q And you have observed Jeffrey Epstein 20 you. I'm not talking to you, I'm not 21 using vibrators and sexual toys on underage 21 communicating with you.. I don't know what 22 minors, true? 22 you think we arc doing here. You said "It 23 MR. YAREMA: Object to the fonn. 23 is true," and I have no idea what you are 24 A Fifth. 24 talking about. Don't inlet-nn the 25 Q In fact, he has also used vibrators and 25 deposition, okay? 9 (Pages 30 to 33) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 9 of 38 EFTA_00067621 EFTA01246840 34 36 1 MIL HOROWITZ: I think you interrupted. 1 A Fifth. 2 MR. GOI.DBERGER: I didn't do a thing -- 2 Q In addition to that system, isn't it 3 MR. EDWARDS: I don't know what's 3 true that Jeffrey Epstein traMcs underage minor 4 happened here. It has deteriorated here for 4 females through a modeling agency? 5 no reason whatsoever and has nothing to do 5 MR. YAREMA: Object to the form. 6 with mc or the witness. 6 A Fifth. 7 MR. GOLDBERGER: You're 100 percent 7 Q Is a modeling agency that he is Involved 8 correct 0 in with Jean Luc Brunel; you know who that is 9 MR. EDWARDS: Can we go back to it. 9 right? 10 MR. GOLDBERGER: Absolutely. 10 MR. YAREMA: Object to the form. 11 MR. EDWARDS: Perfect. 11 A Fifth. 12 The silent fight disrupted mc. I lost 12 Q Are you familiar with MC-2 or MC-Squared 13 where I am now. 13 Modeling Agency? 14 MR GOLDBERGER: Sony. 14 A Fifth. 15 MR EDWARDS: Can you read it back. 15 Q You know Jean Luc Brunel, right? 16 THE COURT REPORTER: Certainly. 16 MR. YAREMA: Object to the fonn. 17 (The record was read.) 17 A Fifth. 18 MR. EDWARDS: I'll rephrase the 18 Q Is Jean Luc Brunel somebody that you 19 question. 19 have been made to perform on sexually? 20 Q Isn't it true that yourself, Ghislaine 20 MR. YAREMA: Object to the form. 21 Maxwell and had access to a master 21 A Fifth. 22 of list of underage minor females names and phone 22 Q Jean Luc Brunel is somebody that you 23 numbers so they could be called for the purpose 23 know to also be a child molester, true? 24 of coming to Jeffrey Epstein's house to be 24 MR. YAREMA: Object to the fonn. 25 sexually molested? 25 A Filth. 35 37 1 MR. YAREMA: Object to the form. 1 Q Thls is somebody who for years the 2 A Fifth. 2 public has known of Jean Luc Brunel as a child 3 Q How many underage minor females are on 3 molester, true? 4 that master list? 4 MR. YAREMA: Object to the form S MR. YAREMA: Object to the form. 5 A Fifth. 6 A Fifth. 6 Q In fact, that is the only thing Jeffrey 7 Q Are there photographs of these underage 7 Epstein and Jean Luc Brunel have in common, is 8 minor females on that master list? 8 their obsession for underage minor females, 9 MR. YAREMA: Object to the form. 9 correct? 10 A Fifth. 10 MR. YAREMA: Object to the form. 11 Q Is that master list saved on a computer 11 A Fifth. 12 system, as has been testified to in the past? 12 Q And the modeling agency Is but one other 13 MR. YAREMA: Object to the form. 13 mechanism used by Jeffrey Epstein to gain access 14 A Fifth. 14 to underage minor females for sex, true? 15 Q Has Jeffrey Epstein talked to you about 15 MR. YAREMA: Object to the form. 16 the success of his scheme to procure underage 16 A Fifth. 17 minor females? 17 Q I read you the statute earlier on Lewd 18 MR. YAREMA: Object to the form. 18 and Lascivious Molestation, Chapter 800.04, and 19 A Fifth. 19 that's something that you have witnessed Jeffrey 20 Q By that, I mean, the method where he 20 Epstein violate on hundreds of occasions, 21 molests an underage minor female, then offers 21 correct? 22 them additional money if they will bring him 22 MR. YAREMA: Object to the form. 23 other underage minor females to molest; are you 23 A Fifth. 24 familiar with that system? 24 Q And something that you have witnessed 25 MR. YAREMA: Object to the forum 25 Jeffrey Epstein specifically violate, against 10 (Pages 34 to 37) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 10 of 38 EFTA_00067622 EFTA01246841 38 40 1 M., true? 1 Epstein's house, and he is using all resources to 2 MR. YAREMA: Object to the font. 2 try to intimidate and harass her; is that true? 3 A Filth. 3 MR. YAREMA: Object to the form. 4 Q Also a statute you have witnessed A Fifth. 5 Jeffrey Epstein violate against then minor, 5 Q In fact, has he talked to you about his 6 6 tactic of Intimidating and harassing any victims 7 MR. YAREMA: Object to the font 7 that conic forward against hint, regarding the 8 A Fifth. 8 sexual abuse that they endured by hint? Q In fact M. was somebody that Jeffrey 9 MR. YAREMA: Object to the fem. 10 Epstein liked or likes; Isn't that true? 10 A Fifth. 11 MR. YAREMA: Object to the fonn. 11 Q Would you agree that Jeffrey Epstein 12 A Fifth. 12 contributed to the delinquency of these various 13 Q In was somebody Jeffrey Epstein met 13 minors that he sexually abused? 14 when she was only 13 years old and began sexually 14 MR. YAREMA: Object to the form. 15 molesting her the first day that he met her, 15 A 16 true? 16 Q In addition to abusing them, he also 17 MR. YAREMA: Object to the fonn. 17 encouraged them to return to hint to receive more 18 A Filth. 18 sexual abuse and encouraged them into a life of 19 Q was one of his main girls, as he 19 prostitution, true? 20 would call them; Is that true? 20 MR. YAREMA: Object to the form. 21 MR. YAREMA: Object to the form. 21 A Fifth. 22 A Fifth. 22 Q How many underage minor females have you 23 Q procured for hint or brought for him 23 observed Jeffrey Epstein engage in sex acts with 24 to his house, over 50 girls between the ages of 24 on any of his airplanes? 25 12 and 15 years old; is that true? 25 MR. YAREMA: Object to the form. 39 41 1 MR. YAREMA: Object to the fonn. 1 A Fifth. 2 A Fifth. 2 Q Have you engaged in sexual acts with any 3 Q Each of these girls, aged 12 to 15, you 3 underage minor females on Jeffrey Epstein's observed come into the house, go into Jeffrey 4 airplanes? 5 Epstein's bedroom and leave the house after being MR. YAREMA: Object to the form. 6 sexually molested, true? 6 A Fifth. 7 MR. YAREMA: Object to the fonn. 7 Q How many times has Jeffrey Epstein 8 A Fifth. 8 talked to you about the reasons why he sexually Q And in addition to M. being sexually abuses minors? 10 molested herself, she was enticed or coerced into 10 MR. YAREMA: Object to the form. 11 bringing her friends over, to also be sexually 11 A Fifth. 12 molested, true? 12 Q Didn't he tell you that it is his intent 13 MR. YAREMA: Object to the Ions 13 to harm these minors in hopes of gaining 14 A Fifth. 14 psychological advantage over them? 15 Q Has Jeffrey Epstein talked to you about 15 MR. YAREMA: Object to the form. 16 an FBI statement that was given by •? 16 A Fifth. 17 A Fifth. 17 Q Are you aware that Jeffrey Epstein pled 18 Q He has also told you that that FBI 18 guilty to two felonies related to his interaction 19 statement that was favorable for him is 19 with minors? 20 completely false; isn't that true? 20 MR. YAREMA: Object to the form. 21 MR. YAREMA: Object to the lona. 21 A Fifth. 22 A Fifth. 22 Q And as a result he was incarcerated, and 23 Q Has he spoken to you about the fact that 23 as we spoke about earlier, you visited hint in 24 she is now telling the complete story and 24 jail on more than 50 occasions, correct? 25 accurate account as to what happened at Jeffrey 25 MR. YAREMA: Object to the loan. 11 (Pages 38 to 41) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 11 of 38 EFTA_00067623 EFTA01246842 42 44 A Fifth. 1 Q Do you profit from sex trafficking of Q Aren't your observations with Jeffrey 2 children? Epstein's interactions with wouldn't you 3 MR. YAREMA: Object to the form. 4 agree he coerced her into a life of prostitution? 4 A Fifth. 5 MR. YAREMA: Object to the loan. 5 Q Do you know Sergio Cordaro? 6 A Fifth. 6 A Fifth. 7 Q And based on your observations of 7 Q Do you know Mike Sank*? a Jeffrey Epstein's interactions with M., 8 A Fifth. 9 wouldn't you agree that Jeffrey Epstein coerced 9 Q Would you consider Jeffrey Epstein's 10 her Into a life of prostitution? 10 criminal enterprise that is designed to molest 11. MR. YAREMA: Object to the form. 11 underage minor females, to be organized? 12 A Fifth. 12 MR. YAREMA: Object to the form. 13 Q And with respect to Jane Doe and M. 13 A Fifth. 14 and M., wouldn't you agree that Jeffrey Epstein 14 Q is your role in that criminal 15 forced these girls to be a prostitute for him? 15 arrangement to molest underage minor females, to 16 MR. YAREMA: Object to the form. 16 help organize? 17 A Fifth. 17 MR. YAREMA: Object to the form. 18 Q Would you agree that Jeffrey Epstein's 18 A Fifth. 19 actions against M., S and Jane Doe, were 19 Q As part of that organization, Isn't it 20 intentional, deliberate and reckless? 20 true that you, as well as various staff members, 21 MR. YAREMA: Object to the form. 21 took nietleulous messages regarding appointments 22 A Fifth. 22 and scheduling underage minor females to come 23 Q Would you agree that that intentional, 23 over to be sexually molested? 24 deliberate and reckless conduct by Jeffrey 24 MR. YAREMA: Object to the form. 25 Epstein against •., `and Jane Doe was 25 A Fifth. 43 45 1 likely to cause severe emotional distress? 1 () These were message pads that had a 2 MR. YAREMA: Object to the form. 2 carbon copy that were positioned or stationed in 3 A Fifth. 3 several places around Jeffrey Epstein's home near 4 Q And isn't it a fact that Jeffrey Epstein 4 the telephone; you're familiar with those, 5 has specifically told you that it is his intent 5 right? 6 to cause severe emotional distress, as it 6 MR. YAREMA: Object to the form. 7 weakened his victims? 7 A Fifth. 8 MR. YAREMA: Object to the form. a Q Since I'm assuming that you are going to 9 A Fifth. 9 lake the Fifth on each and every question related 10 Q Has Jeffrey Epstein talked to you about 10 to any messages, I will show you only one, which 11 your role in what he calls a criminal enterprise? 11 will be marked, this one page, as Plaintiff's 12 MR. YAREMA: Object to the form. 12 Exhibit 1. The date on the message that I will 13 A Fifth. 13 be showing you is 8/21, August 21,2005. 14 Q Has he talked to you about his 14 (Message dated August 21, 2005 was 15 organization being a crIntinal enterprise, that 15 marked as Plaintiff's Exhibit number 1 for 16 you need to help protect? 16 identification, as of this date.) 17 MR. YAREMA: Object to the form. 17 MR. EDWARDS: Do you want to see it 18 A Fifth. 18 first? 19 Q What does Jeffrey Epstein do for a 19 MR. GOLDBERGER: (Counsel examines 20 living? 20 document and hands it to the witness.) 21 A Fifth. 21 Q Would you look at the exhibit, please, 22 Q Does he profit from international sex 22 if you can see it? I don't know if you tan see 23 traMckIng of children? 23 it over your coffee. 24 MR. YAREMA: Object to the form. 24 A I can see it. 25 A Fifth. 25 Q Okay. Do you recognize it? 12 (Pages 42 to 45) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 12 of 38 EFTA_00067624 EFTA01246843 46 48 A Fifth. 1 Chisiaine Maxwell's sexual interaction with Jane Q That particular message indicates It Is 2 Doe-I02 when she was a minor? 3 from In You're the only'' in the 3 MR. YAREMA: Object to the Ponca. 4 house; is that correct? 4 Q This is one of many underage minor 5 MR. YAREMA: Object to the form. 5 females that was trafficked basically around the 6 A Fifth. 6 globe to be sexually exploited and abused; is 7 Q This is a call front you indicating that 7 that correct? 8 cannot work today and will be 8 MR. YAREMA: Object to the fonn. 9 here at 4:00 p.m.;" is that right? A Fifth. 10 MR. YAREMA: Object to the font? 10 Q Was that typical of Jeffrey Epstein and 11 A Fifth. 11 Chislaine Maxwell to sexually abuse minors on 12 Q Who Is' 12 Jeffrey Epstein's airplane? 13 A Fifth. 13 MR. YAREMA: Object to the font 14 MIL YAREMA: Object to the fonn. 14 A Fifth. 15 Q That's an underage minor female that was 5 Q And also typical of Chislaine Maxwell 16 scheduled to be molested at Jeffrey Epstein's 6 and Jeffrey Epstein to prostitute or pimp out 17 house? 7 underage minors to friends? 18 MR. YAREMA: Object to the form. 8 MR. YAREMA: Object to the form. 19 A Fifth. A Fifth. 20 Q You scheduled that act of molestation; 0 Q By "friends," I am talking specifically 21 is that right? 1 about people of royalty, politicians, 22 MR. YAREMA: Object to the fonn. 2 academicians, businessmen and other professional 23 A Fifth. 3 or personal acquaintances? 24 Q And will be at the house at 4:00 4 MR. YAREMA: Object to the fonn. 25 p.m. is another underage minor female; 5 A Fifth. 47 49 1 Is that correct? 1 Q Were you with Jeffrey Epstein on his 2 MR. YAREMA: Object to the form. 2 birthday when one of his friends sent to him 3 A Fifth. 3 12 — sorry, three 12-year olds for the purposes 4 Q That's somebody else that you were 4 of Jeffrey Epstein sexually abusing them? 5 scheduling to come to his house at 4:00 p.m. for 5 MR. YAREMA: Object to the form. 6 Jeffrey Epstein to engage In sexual acts with 6 A Fifth. 7 her, while she was an underage minor, true? 7 Q How ninny occasions have you observed 8 MR. YAREMA: Object to the form. 8 Jeffrey Epstein to receive as gifts from friends, 9 A Fifth. 9 underage minor females for the purposes of him 10 Q Do you know Les Wexner? 10 sexually abusing them? 11 A Fifth. 11 MR. YAREMA: Object to the form. 12 Q That's somebody that you know owns and 12 A Fifth. 13 operates the Victoria's Secret, the Limited? 13 Q These three 12-year olds were from 14 MR. YAREMA: Object to the fonn. 14 France. Were they sent to him on his birthday by 15 A Is that a question? 15 Jean Luc Brunel or by somebody else? 16 Q Is that somebody that you know to own 16 MR. YAREMA: Object to form. 17 Victoria's Secret or operate Victoria's Secret? 17 A Fifth. 18 A Fifth. 18 Q Have you ever been made to engage in sex 19 Q Do you know If Jeffrey Epstein still 19 with 12-year olds? 20 talks with Leslie Wexner? 20 MR. YAREMA: Object to the form. 21 MR. YAREMA: Object to the form. 21 A Fifth. 22 A Fifth. 22 Q Is It true that Jeffrey Epstein makes 23 Q Do you know Jane Doe-102? 23 you dress up as a 12-year old? 24 A Fifth. 24 MR. YAltEMA: Object to the font. 25 Q Are you aware of Jeffrey Epstein and 25 A Fifth. 13 (Pages 46 to 49) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 13 of 38 EFTA_00067625 EFTA01246844 50 52 1 Q As part of being Jeffrey Epstein's sex 1 A Fifth. 2 slave, isn't it true that he asks you or requests 2 Q Do you know Bill Riley? 3 of you to dress younger than 12 at times? 3 A Fifth. 4 MR. YAREMA: Object to the form. 4 Q Have you seen the flight logs front 5 A Fifth. 5 Jeffrey Epstein's private airplane flights? 6 Q Have you seen naked photographs of the 6 MR. YAREMA: Object to the form. 7 underage minor females with whom Jeffrey Epstein 7 A Fifth. 8 has engaged in sex acts? 8 Q Are you aware that you're listed as a MR. YAREMA: Object to the form. 9 passenger on many flights, along with Jeffrey 10 A Fifth. 10 Epstein on his private airplane? 11 Q Are there hidden cameras in any of 11 MR. YAREMA: Object to the form 12 Jeffrey Epstein's homes, that you know to have 12 A Fifth. 13 taken surreptitious videos or photographs of 13 Q Certainly conies as no surprise to you, 14 underage minors? 14 since you were on his airplane on numerous 15 MR. YAREMA: Object to the Conn. 15 occasions, correct? 16 A Fifth. 16 MR. YAREMA: Object to the four. 17 Q Does Jeffrey Epstein still watch 17 A Fifth. 18 pornography to this day? 18 Q On September 22,2003, you were listed 19 MR. YAREMA: Object to the form. 19 as being on a flight with ,,lelTrey 20 A Etta,. 20 Epstein, and ■. My question 21 Q Does Jeffrey Epstein watch homemade 21 is who is ■. and who Is..? 22 pornographic videos of underage minors engaging 22 MR. YAREMA: Object to the funn. 23 in sex orgies on his island? 23 A Fifth. 24 MR. YAREMA: Object to the form. 24 () Do you know 25 A Fifth. 25 A Fifth. 51 53 1 () Prior to the search warrant being 1 Q That's somebody that you're familiar 2 executed, you are aware that at least three 2 with, because you have been to Jeffrey Epstein's 3 computers were taken at Jeffrey Epstein's 3 house on many occasions with 4 direction, from Jeffrey Epstein's house, to avoid 4 correct? 5 detection by law enforcement, correct? 5 MR. YAREMA: Object to the form 6 MR. YAREMA: Object to the form. 6 A Fifth. 7 A Correct. 7 Q In fact, do you remember there being a and some other person 8 burglary of Jeffrey Epstein's house where he 9 took those computers to avoid Jeffrey Epstein — 9 actually called the police to investigate the 10 to avoid the authorities obtaining the evidence 10 burglary? 11 contained on those computers, correct? 11 MR. YAREMA: Object to the form. 12 MR. YAREMA: Object to the form. 12 A Fifth. 13 A Fifth. 13 Q And during the police investigation 14 Q Who are the persons along with 14 inside Jeffrey Epstein's house, you were speaking 15 took the computers front Jeffrey 15 with MEI both in person, at Jeffrey 16 Epstein's house prior to the execution of the 16 Epstein's house, correct? 17 search warrant? 17 MR. YAREMA: Object to tile form. 18 MR. YAREMA: Object to the form. 18 A Correct. 19 A Fifth. 19 Q Is this another person that Jeffrey 20 Q Where are those computers today? 20 Epstein, when she was a minor, violated 21 MR. YAREMA: Object to the form. 21 sexually? 22 A Fifth. 22 MR. YAREMA: Object to the form. 23 Q Were they taken by his investigator, 23 A Fifth. 24 Bill Riley? 24 Q Do you still speak with 25 MR. YAREMA: Object to the form. 25 MR. YAREMA: Object to the form. 14 (Pages 50 to 53) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 14 of 38 EFTA_00067626 EFTA01246845 54 56 A Fifth. 1 Jeffrey Epstein specifically flew to Palm Beach 2 Q Do you know Bill Clinton? 2 for the purposes of engaging in sex acts with 3 A Fifth. 3 Jane Doe? 4 Q You have been on Jeffrey Epstein's 4 MR. YAREMA: Object to the toms. airplane with Bill Clinton? 5 A Fifth. 6 MR. YAREMA: Object to the fonn. 6 Q Generally, Isn't it true Jeffrey Epstein 7 A Fifth. 7 would fly front place to place for the purpose of 8 Q Isn't take true you have been on Jeffrey 8 engaging in sexual activity with minors at his 9 Epstein's airplane with Doug Band, Bill Clinton's 9 destination? 10 righthand man? 10 MR. YAREMA: Object to the form. 11 MR. YAREMA: Object to the fonn. 11 A Fifth. 12 A Fifth. 12 Q Isn't It true that he employed numerous 13 Q slave you witnessed Improper sexual 13 people for the sole purpose of scheduling 14 activity between Jeffrey Epstein and minors, 14 appointments with underage minor females at each 15 while he was in the presence of Bill Clinton? 15 destination he landed? 16 MR. YAREMA: Object to the form. 16 MR. YAREMA: Object to the form. 17 A Fifth. 17 A Fifth. 18 Q How many times have you ridden on the 18 Q What is Jeffrey Epstein's relationship 19 airplane with Jean Luc Brunel? 19 with Sandy Berger? 20 MR. YAREMA: Object to the font 20 MR. YAREMA: Object to the fonn. 21 A Fifth. 21 A Fifth. 22 Q Each time that Jean Luc Brunel visits 22 Q Do you know what Jeffrey Epstein's 23 Jeffrey Epstein's house, does he bring underage 23 relationship is with Alan Dershowitz? 24 minors to Jeffrey Epstein's house to engage in 24 MR. YAREMA: Object to the form. 25 sex with? 25 A Fifth. 55 57 1 MR. YAREMA: Object to the form. Q That's somebody who you know to have 2 A Fifth. 2 stayed at Jeffrey Epstein's house on many 3 Q Do you know Glenn Dubin? 3 occasions, correct? 4 A Fifth. 4 MR. YAREMA: Object to the form. 5 Q Do you know li n? A Fifth. 6 A Fifth. 6 Q And also somebody who you know to have 7 Q Is that somebody that was a sexual abuse 7 been at the house when M. was In Jeffrey 8 victim at one point in time of Jeffrey Epstein 8 Epstein's bedroom getting sexually abused, 9 and Jean Luc Brunel? 9 correct? 10 MR. YAREMA: Object to the Conn. 10 MR. YAREMA: Object to the fonn. 11 A Fifth. 11 A Fifth. 12 Q Between 2002 and 2005 when M. was 12 Q Alan Dershowitz is also somebody that 13 abused by Jeffrey Epstein sexually, isn't it true 13 you also know to have been at the house when M. 14 that Jeffrey Epstein took flights to Palm Beach 14 was being sexually abused in Jeffrey Epstein's 15 for the purposes of sexually abusing M.? 15 bedroom, correct? 16 MR. YAREMA: Object to the form. 16 MR. YAREMA: Object to the fonn A Fifth. 17 A Fifth. Q And between those same years of 2002 and 18 Q Generally, Alan Dershowitz is familiar 2005, Isn't it true that Jeffrey Epstein took 19 with Jeffrey Epstein's habit of engaging in airplane flights to Palm Beach front places 20 sexual acts with minors on a daily basis, outside of the State, to engage in sexual acts 21 correct? with M.? 22 MR. YAREMA: Object to the form. MR. YAREMA: Object to the form. 23 A Fifth. A Fifth. 24 Q When Alan Dershowltz was In town, 5 Q From 2003 through 2005, Isn't it true 25 Jeffrey Epstein did not break his schedule for 15 (Pages 54 to 57) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 15 of 38 EFTA_00067627 EFTA01246846 58 60 Alan Dershowitz, meaning he continued to sexually 1 Q Whnt was the purpose of that flight? 2 abuse minors despite Alan Dershowitz being a 2 MR. YAREMA: Object to the form. 3 guest In the house? 3 A Fifth. 4 MR. YAREMA: Object to the fonn. 4 Q Did you sign a confidentiality agreement 5 A Fifth. 5 with Jeffrey Epstein? 6 Q Alan Dershowitz never engaged in any 6 MR. YAREMA: Object to the tome sexual activity with these underage minors; isn't 7 A Fifth. 8 that true? 8 Q When is the last time that you observed 9 MR. YAREMA: Object to the fonn. 9 Jeffrey Epstein have sex with a minor? 10 A Fifth. 10 MR. YAREMA: Object to the form. 1 Q have you been made to have sex with 11 A Fifth. 12 Chislaine Maxwell? 12 Q Since being on probation, has Jeffrey 13 MR. YAREMA: Object to the lona. 13 Epstein been able to, or has he flown to his 14 A Fifth. 14 island? 15 Q Do you know 15 MR. YAREMA: Object to the Conn 16 A Fifth. 16 A Fifth. 17 Q Similar to you being Jeffrey Epstein's 17 Q To your knowledge, has Jeffrey Epstein 18 sex slave, is MEM, or was 113 flown to New York while on probation or community 19 Chislaine Maxwell's sex slave? 19 control? 20 MR. YAREMA: Object to the font 20 MR. YAREMA: Object to the fonn. 21 A Fifth. 21 A Filth. 22 Q Chislaine Maxwell is somebody who you 22 Q Isn't it true that he has flown both to 23 know to be IA-sexual, true? 23 New York and to his island, and you have 24 MR. YAREMA: Object to the form. 24 accompanied him on those trips, since he was on 25 A Fifth. 25 community control? 59 61 Q You know that Chislaine Maxwell engaged 1 MR. YAREMA: Object to the form. 2 in sexual acts with underage minor females, true? 2 A Fifth. 3 MR. YAREMA: Object to the form. 3 Q Isn't it also true that Jeffrey Epstein 4 A Fifth. 4 has indicated to you that he will always engage 5 Q This is yet another friend of Jeffrey 5 in sex acts with underage minor females? 6 Epstein's that is into the act of molesting 6 MR. YAREMA: Object to the form. 7 underage minor females, right? 7 A Fifth. 8 MR. YAREMA: Object to the form. 8 Q In fact, that's something that he has 9 A Fifth. 9 told you, that he believes he is entitled to do; 10 Q Now, you are the next participant in 10 isn't that right? 11 that activity, meaning you have been groomed to 11 MR. YAREMA: Object to the fonn. 12 enjoy and appreciate the acts of sex with 12 A Filth. 13 underage minors, true? 13 Q Isn't It true that Jeffrey Epstein 14 MR. YAREMA: Object to the form. 14 believes and has told you that if he doesn't 15 A Fifth. 15 physically force the underage minor female into 16 Q Has Jeffrey Epstein instructed you to 16 any act, then he is entitled to engage in sex 17 Ile to his Probation Officer in any way? 17 with any underage minor female despite the age? 18 MR. YAREMA: Object to the form. 18 MR. YAREMA: Object to the form. A Fifth. 19 A Fifth. Q Mr. Visoski testified that you took a 20 Q What is the youngest female you have helicopter flight within the last year with 21 witnessed or observed Jeffrey Epstein to engage Jeffrey Epstein to Miami. Do you remember that 22 in sex with? flight? 23 MR. YAREMA: Object to the fonn. MR. YAREMA: Object to the form. 24 A Fifth. 5 A Fifth. 25 Q Do you have a bunk account at Chase Bank 16 (Pages 58 to 61) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 16 of 38 EFTA_00067628 EFTA01246847 62 64 1 In New York? 1 Q That's somebody who these days refers to 2 A Fifth. 2 himself as Jeffrey Epstein's personal assistant, 3 Q And the money in that bank account under 3 right? 4 your name is money that was given to you by 4 MR. YAREMA: Object to the fonn. 5 Jeffrey Epstein, correct? 5 A Fifth. 6 MR. YAREMA: Object to the fon. 6 Q That's somebody who you know to work for 7 A Fifth. 7 or at the Florida Science Foundation, which is 8 Q For the passed ten or so years, you have 8 owned by Jeffrey Epstein, correct? 9 lived with Jeffrey Epstein under his control, 9 MR. YAREMA: Object to the form. 10 right? 10 A Fifth. 11 MR. YAREMA: Object to the form. 11 Q It is also somebody that you know to 12 A Fifth. 12 have stayed at Jeffrey Epstein's house with= 13 Q You get to lead the life of a 13 correct? 14 millionaire, and to lead that life, you were only 14 MR. YAREMA: Object to the fonn. 15 required to be Jeffrey Epstein's sex slave and to 15 A Fifth. 16 bring Jeffrey Epstein other slaves? 16 Q This is somebody that has been 17 MR. YAREMA: Object to the form. 17 Involved — is somebody who's been 18 A Fifth. 18 Involved sexually with for at least 19 Q Is this 301 East 66th Street apartment 19 a year, right? 20 still an apartment that you frequent today? 20 MR. YAREMA: Object to the tome. 21 MR. YAREMA: Object to the form. 21 A Fifth. 22 A Fifth. 22 Q In fact, you know that they took a trip 23 Q And you're familiar with the nine or ten 23 around the world together and during that trip 24 apartments that Jeffrey Epstein owns or controls 24 they discussed Jeffrey Epstein and his 25 up there at 301 East 66th Street, aren't you? 25 interaction with underage minor females, 63 65 1 MR. YAREMA: Object to the form. 1 correct? 2 A Fifth. 2 MR. YAREMA: Object to the form. 3 Q At any given time, there are between S 3 A Fifth. 4 and 16 underage minors living in or staying at 4 MR. EDWARDS: Done. I don't have S those apartments? 5 anything else. 6 MR. YAREMA: Object to the fonn. 6 MR. GOLDBERGER: Okay. 7 A Fifth. 7 MR. HOROWITZ: I do, why don't we take a 8 Q On the various passenger lists on 8 short break. 9 Jeffrey Epstein's airplane, where it will list, MR. GOLDBERGER: We are stopping at 10 for instance, Jeffrey Epstein, 10 11:50. 11 going from Florida to St. 11 MR. HOROWITZ: What? 12 Thomas, then generically, female, female; would 12 MR. GOLDBERGER: 11:50. 13 you know who those female, females are? 13 MR. HOROWITZ: I kind of remember that 14 MR. YAREMA: Object to the form. 14 e-mail. 15 A Fifth. 15 THE VIDEOGRAPHER: Off the video record. 16 Q Are those females listed generically 16 (Pause in the proceedings.) 17 rather than specifically because they are 17 THE V1DEOCRAPHER: We are back on the 18 underage minor females engaging in sex with you 18 video record at 11:18 a.m.) 19 or Jeffrey Epstein? 19 (At this time Robert Critton joined the 20 MR. YAREMA: Object to the fonn. 20 proceedings.) 21 A Fifth. 21 CROSS EXAMINATION 22 Q Is someone that you see on 22 BY MR. HOROWITZ: 23 ■ regular basis at Jeffrey Epstein's house? 23 between 200t and 2006, 24 MR. YAREMA: Object to the fonn. 24 did Jeffrey Epstein instruct you to place 25 A Fifth. 25 telephone calls io arrange for girls under the 17 (Pages 62 to 65) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 17 of 38 EFTA_00067629 EFTA01246848 66 68 age of 18 to come to his home for his sexual 1 A Fifth. 2 gratification? 2 Q Did Jeffrey Epstein admit to you that he 3 MR. YAREMA: Object to the form. 3 sexually abused in his Palm Beach home in 4 A Fifth. 4 2004? 5 Q Between 2001 and 2006 did you, in fact, 5 MR. YAREMA: Object to the form. 6 place telephone calls to arrange for girls under 6 A Fifth. 7 the age of Is to come to Jeffrey Epstein's home Q Did you ever instruct a girl named a a for his sexual gratification? B to bring other underage girls to Jeffrey 9 MR. YAREMA: Object to the form. 9 Epstein's home for Jeffrey Epstein's sexual 10 A Fifth. 10 pleasure? 11 Q Are you personally aware that a girl 11 MR. YAREMA: Object to the form. 12 named M. came to Jeffrey Epstein's Palm Beach 12 A Fifth. 13 home in late 2004? 13 Q In 2004 did you communicate by telephone 14 MR. YAREMA: Object to the form. 14 with for the purpose of bringing 15 A Fifth. 15 ■. to Jeffrey Epstein's home for sexual 16 Q Did Jeffrey Epstein admit to you he 16 activity MR. YAREMA: Object to the fonn. 17 sexually abused M.? 17 A Fifth. 18 MR. YAREMA: Object to the form. 18 Q Did Jeffrey Epstein instruct you to 19 A Fifth. 19 communicate with for the purpose of 20 Q Isn't it true in late 2004 you made 20 making arrangements for M. to come to his home? 21 arrangements by telephone to bring S to 21 MR. YAREMA: Object to the form. 22 Jeffrey Epstein's home? 22 A Fifth. 23 MR. YAREMA: Object to the fonn. 23 Q Did Jeffrey Epstein tell you it was his 24 A Fifth. 24 intent during the course ofM.'s visit to his 25 Q Did Jeffrey Epstein instruct you to 5 home to persuade, induce or entice her to engage 67 69 communicate by telephone to arrange for M. to 1 In sexual activity with him? 2 come to his home for his sexual gratification? 2 MR. YAREMA: Object to the form. 3 MR. YAREMA: Object to the fonn. 3 A Fifth. 4 A Fifth. 4 Q Did Jeffrey Epstein admit to you that he 5 Q Did Jeffrey Epstein inform you that M. S had succeeded in, in fact, persuading, inducing 6 would be giving him a massage that was sexual in 6 or enticing M. to engage in sexual activity 7 nature? with him? MR. YAREMA: Object to the form. 8 MR. YAREMA: Object to the form. 9 A Fifth. 9 A Fifth. 10 Q Did Jeffrey Epstein tell you it was his 10 Q Are you personally aware that a teenage 11 intent during the course ofM.'s visit to his 11 girl named came to Jeffrey Epstein's Palm 12 home to persuade, induce or entice her to engage 12 Beach home on multiple occasions between 2003 and 13 in sexual activity? 13 2005? 14 MR. YAREMA: Object to the fonn. 14 MR. YAREMA: Object to the form. 15 A Fifth. 15 A Fifth. 16 Q Did Jeffrey Epstein tell you that, in 16 Q Did Jeffrey Epstein admit to you that he 17 fact, he succeeded in persuading, Inducing or 17 sexually abused St 18 enticing M. to engage in sexual activity with 18 MR. YAREMA: Object to the form 19 hint? 19 A Fifth. 20 MR. YAREMA: Object to the form. 20 Q At any time prior to May of 2005, did 21 A Fifth 21 Jeffrey Epstein instruct you to place telephone 22 Q Are you personally aware that a girl 22 calls to M. for the purpose of arranging for 23 named came to Jeffrey Epstein's Palm Beach M. 23 her to come to his home and engage in sexual 24 home on multiple occasions in 2004? 24 activity? 25 MR. YAREMA: Object to the form. 25 MR. YAREMA: Object to the form. 18 (Pages 66 to 69) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 18 of 38 EFTA_00067630 EFTA01246849 70 1 A Filth. 1. in either 2001 or 2002? 2 Q Did you, in fact, communicate by 2 MR. YAREMA: Object to the form. 3 telephone with • for the purpose of arranging 3 A Fifth. 4 for her to come to his home for sexual activity? 4 Q Did you, in fact, call M. to come to 5 MR. YAREMA: Object to the tom. S Jeffrey Epstein's home and give him a massage in 6 A Fifth. 6 sexual nature in 2001 or 2002? 7 Q At any lime prior to May of 2005, did 7 MR. YAREMA: Object to the tom. 8 you place a telephone call to I= A Fifth. wherein you arranged fore to come to Jeffrey 9 Q Did you either observe or overhear 10 Epstein's home for sexual activity? 10 speaking with M. on the telephone to 11 MR. YAREMA: Object to the form. 11 arrange for M. to conic to Jeffrey Epstein's 12 A Fifth. 12 home for a massage of a sexual nature? 13 Q Prior to May of 2005, did you ever 13 MR. YAREMA: Object to the form. 14 observe speaking with M. by 14 A Filth. 15 telephone to arrange for M. to come to Jeffrey 15 Q Did Jeffrey Epstein tell you it was his 16 Epstein's home? 16 intent during the course of M.'s visit to his 17 MR. YAREMA: Object to the form. 17 home to persuade, induce or entice her to engage 18 A Fifth. 18 In sexual activity? 19 Q Did Jeffrey Epstein tell you that it was 19 MR. YAREMA: Object to the form. 20 his intention to sexually abuse ■. during the 20 A Fifth. 21 course of her visits to his home? 21 Q Didn't Jeffrey Epstein admit to you that 22 MR. YAREMA: Object to the form. 22 he succeeded in persuading, inducing or enticing 23 A Fifth. 3 M. to engage in sexual activity with him nt his 24 Q Did Jeffrey Epstein tell you that he 24 home while she was still a minor? 25 succeeded in engaging `In sexual activity 25 MR. YAREMA: Object to the form. 71 1.3 1 while she was still a minor, at his home? 1 A Fifth. 2 MR. YAREMA: Object to the form. 2 Q Are you personally aware that a girl 3 A Fifth. 3 named came to Jeffrey Epstein's home in 4 Q Are you personally aware that a teenage 4 approximately August 2004? 5 girl named an came to Jeffrey Epstein's 5 MR. YAREMA: Object to the form. 6 Palm Beach home in approximately 2001 or 2002? 6 A Fifth. 7 MR. YAREMA: Object to the form. 7 Q Did Jeffrey Epstein admit to you that he a A Fifth. had sexually abused M. when she was only 13 9 Q Did Jeffrey Epstein admit to you that he 9 years old? 10 sexually abused M. at his home while she was 10 MR. YAREMA: Object to the fonn. 11 sun a child? 11 A Fifth. 12 MR. YAREMA: Object to the form. 12 Q In 2004 did you participate in a 13 A Fifth. 13 telephone call wherein you arranged for ■. to 14 Q In 2001 or 2002, did inform 14 come to Jeffrey Epstein's home for the purpose of 15 you that she received a telephone call in which 15 giving him a massage that was to be sexual In 16 she was referred to M., who would be willing to 16 nature? 17 come to Jeffrey Epstein's home for sexual 17 MR. YAREMA: Object to the form. 18 activity? 18 A Fifth. 19 MR. YAREMA: Object to the form. 19 Q Did Jeffrey Epstein instruct you to 20 A Fifth. 20 communicate by telephone and make arrangement 21 (Whereupon, at this point in the 21 for M. to conic to his home for sexual activity 22 proceedings, Robert Critton leit the 22 while she was still a child? 23 deposition room.) 23 MR. YAREMA: Object to the foam 24 Q Did Jeffrey Epstein instruct you to call 24 A Fifth. 25 M . to come to his home and give him a massage 25 Q Did Jeffrey Epstein tell you it was his 19 (Pages 70 to 7 3) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 19 of 38 EFTA_00067631 EFTA01246850 74 76 intention during the course of M.'s visit to 1 MR. YAREMA: Object to the form. his home to persuade, Induce or entice her to 2 A Fifth. engage in sexual activity with him? 3 Q Dld you participate in a telephone call 4 MR. YAREMA: Object to the font. 4 wherein you arranged for M. to tome to Jeffrey A Fifth. 5 Epstein's home for a massage? 6 Q Did Jeffrey Epstein tell you that, In 6 MR. YAREMA: Object to the form. 7 fact, he succeeded in persuading, inducing and 7 A Fifth. 8 enticing. to engage in sexual activity with Q Did Jeffrey Epstein instruct you to 9 him while she was still a child at his home? 9 participate in a telephone call wherein you were 10 MR. YAREMA: Object to the form. 10 to arrange for to come to Ids home for 11 A Fifth. 11 sexual activity? 12 Q Are you personally aware that a girl 12 MR. YAREMA: Object to the fonn. 13 named e came to Jeffrey Epstein's home in Palm 13 A Fifth. 14 Beach on multiple occasions between 2003 and May 14 Q Did Jeffrey Epstein admit to you It was 15 of 2005? 15 his intention during the course of visit 16 MR. YAREMA: Object to the fonn. 16 to his home, to engage her in sexual activity 17 A Fifth. 17 while she was still a child? 18 Q Did Jeffrey Epstein admit to you that he 18 MR. YAREMA: Object to the form. 19 sexually abused. at his home between 2003 and 19 A Fifth. 20 May of 2005? 20 Q Did Jeffrey Epstein admit to you he had, 21 MR. YAREMA: Object to the form. 21 In fact, persuaded, enticed and engaged in 22 A Fifth. 22 sexual activity at his home while she was still a 23 Q Prior to May of 2005, did you receive a 23 child? 24 phone call front a girl named wherein 24 MR. YAREMA: Object to the form. 25 she told you she was bringing e to Jeffrey 25 A Fifth. 75 77 1 Epstein's home to give him a massage? 1 MR. HOROWITZ: No other questions at 2 MR. YAREMA: Object to the form. 2 this point. 3 A Fifth. 3 MR. LANGINO: I have less than ten 4 Q At any time prior to 2005, did Jeffrey 4 minutes of questioning. 5 Epstein instruct you to communicate with MI 5 MR. GOLDBERGER: Fine, that will bring 6 by telephone to make arrangements for. 6 us right to the break. 7 to come to his home? 7 CROSS EXAMINATION 8 MR. YAREMA: Object to the Fenn. 8 BY MR. LANGINO: 9 A Fifth. 9 Q I'm Adam Langino and I represent.. 10 Q Prior to M.'s visits to Jeffrey 10 and.. 11 Epstein's home, did Jeffrey Epstein tell you it 11 Do you know an individual named M? 12 was his intention to induce, entice and engage 12 A Fifth. 13 N.,to engage in sexual activity with him? 13 Q Do you know an individual named M.? 14 MR. YAREMA: Object to the fonn. 14 A Fifth. 15 A Fifth. 15 Q Have you seen at the defendant's 16 Q After visits to Jeffrey Epstein's 16 Palm Beach property? 17 home, did Jeffrey Epstein tell you that he 17 MR. YAREMA: Object to the form. 18 succeeded in enticing, engaging and persuading 18 A Fifth. 19 to engage in sexual activity with him while 19 Q (lave you seen.. al the defendant's 20 she was still a child? 20 Palm Beach property? 21 MR. YAREMA: Object to the fonn. 21 MR. YAREMA: Object to the form. 22 A Fifth. 22 A Fifth. 23 Q Are you personally aware that a teenage 23 Q Have you ever engaged in a sexual act 24 girl minted came to Jeffrey Epstein's Palm 24 with 25 Beach home in approximately 2001 or 2002? 25 MR. YAREMA: Object to the fonn. 20 (Pages 74 to 77) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 20 of 38 EFTA_00067632 EFTA01246851 78 80 A Fifth. 1 with the defendant was consensual? 2 Q Have you ever engaged in a sexual tel 2 MR. YAREMA: Object to the form. with 3 A Fifth. 4 MR. YAltEMA: Object to the form. 4 Q Do you know if M.'s sexual activity 5 A Fifth. 5 with the defendant was consensual? 6 Q Did you ever observe the defendant, 6 MR. YAREMA: Object to the form. 7 Jeffrey Epstein, with.? 7 A Fifth. MR. YAREMA: Object to the form. 8 Q When you participated hi sexual acts 9 A Fifth. 9 with each minor, how did you feel? 10 Q Did you ever observe the defendant, 0 MR. YAREMA: Object to the form. 11 Jeffrey Epstein, with 1 A Fifth. 12 MR. YAREMA: Object to the form? 2 Q In your heart, did you know it was 13 A Fifth. 3 wrong? 19 Q Have you ever physically touched a? 4 MR. YAREMA: Object to the form, and in 15 MR. YAREMA: Object to the form. 5 addition this is irrelevant and has already 16 A Fifth. 6 been addressed by Judge Hafele as an 17 Q Have you ever physically touched a? 7 inappropriate question. That's my 18 MR. YAREMA: Object to the form. 8 objection. 19 A Fifth. 9 A Fifth. 20 Q Has the defendant ever made a statement 0 Q During this time period did you feel 21 to you about 1 confused? 22 MR. YAREMA: Object to the form. 2 MR. YAREMA: Object to the form. 23 A Fifth. 3 MR. GOLDBERGER: Same — 24 Q Has the defendant ever made a statement 4 MR. YAREMA: Same objection. 25 to you about 5 A Fifth. 79 81 MR. YAREMA: Object to the form. 1 Q Are you currently In love with the 2 A Fifth. 2 defendant? 3 Q Has ever made a statement 3 MR. YAREMA: Object to the fonn, same 4 to you about 4 objection. That question has no relevance 5 MR. YAREMA: Object to the form. 5 to this... it is inappropriate per Judge 6 A Fifth. 6 Hafete's order. 7 Q Has ever made a statement 7 MR. GOLDBERGER: Also involves privacy 8 to you aboutN.? B 9 rights of my client. I 111S1R143 her not to answer the question. MR. YAREMA: Object to the form. 10 A Fifth. 10 A Fifth. 11 Q Have you ever communicated with 11 Q Have you ever been in love with Jeffrey 12 MR. YAREMA: Object to the form. 12 Epstein? 13 A Fifth. 13 MR. GOLDBERGER: Same objection. 4 Q Have you ever communicated with 14 MR. YAREMA: Same objections. 15 MR. YAREMA: Object to the form. 15 A Fifth. 16 A Fifth. 16 MR. LANOINO: Thank you. 17 Q Did you know that U,U was a minor 17 CROSS EXAMINATION 18 at the time of sexual abuse? 18 BY F.ZELL: 19 MR. YAREMA: Object to the form. 19 (Discussion off thc record.) 20 A Fifth. 20 Q Good morning, I'm 21 Q Did you know ....... was a minor at 21 Katherine Ezell and I represent Jane Doe 103, 22 the time of the sexual abuse? 22 whose name Is ., which shall appear as.. in 23 MR. YAREMA: Object to the form. .3 the deposition. 24 A Fifth. 24 Are you aware that in 2004 and 5, there 25 Q Do you know ir sexual activity 75 was a sort of hidden staircase that would take 21 (Pages 78 to 81) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 21 of 38 EFTA_00067633 EFTA01246852 82 134 1 one from the kitchen upstairs to the master 1 Q Do you recall that Jeffrey Epstein would 2 bedroom and massage area? 2 Join in by performing oral sex on one or the 3 MR. YAREMA: Object to the form. 3 other of you — you or ..? 4 A Fifth. 4 MR. YAREMA: Object to the form. 5 Q Do you recall there being nude 5 A Fifth. 6 photographs on the staircase? 6 Q Do you recall that also happening, 7 MR. YAREMA: Object to the form. 7 meaning the oral sex, being performed on the 8 A Fifth. 8 massage table — 9 Q Did you know 9 MR. YAREMA: Objection. 10 A Fifth. 10 Q to 11 Q Did come to the house at 358 El 1 MR. YAREMA: Object to the form. 12 Brill° Way to provide a massage to Jeffrey 12 A Fifth. 13 Epstein? 13 Q Were you present one day when Jeffrey 14 MR. YAREMA: Object to the form. 14 Epstein held.. down on the massage table and 15 A Fifth. 15 while holding her inserted his penis Into M's 16 Q Did that massage become sexual in 16 vagina? 17 nature? 17 MR. YAREMA: Object to the form. 18 MR. YAREMA: Object to the form. 18 A Fifth. 19 A Fifth. 19 Q Do you recall he stated that he wanted 20 Q Did • become a regular visitor at 20 you to observe this? 21 Jeffrey Epstein's house? 21 MR. YAREMA: Object to the form. 22 MR. YAREMA: Object to the form. 22 A Filth. 23 A Fifth. 23 Q Do you recall that.. had rules, 24 Q Do you remember that she came maybe 24 lines, that she had stated Jeffrey Epstein was 25 hundreds of times? 25 not to cross, in their encounters? 83 MR. YAREMA: Object to the fonn. 1 MR. YAREMA: Object to the form. 2 A Fifth. 2 A Fifth. 3 Q Do you recall that she was under the age 3 Q Do you recall that.. had forbidden 4 of 18 at the time she was coming to Jeffrey 4 any kind of vaginal penetration? 5 Epstein's home? 5 MR. YAREMA: Object to the form 6 MR. YAREMA: Object to the fonn. 6 A Fifth. 7 A Fifth. 7 Q Do you recall that.. refused to touch 8 Q Were you younger than.. at the time? 8 Jeffrey Epstein's penis? 9 MR. YAREMA: Object to the form. 9 MR. YAREMA: Object to the fonn. 10 A Fifth. 10 A Fifth. 11 Q Do you remember occasions when you and 11 Q Do you recall that day when Jeffrey 12 Jeffrey Epstein were already in bed when 12 Epstein held.. on her stomach on the massage 13 arrived? 13 table and began pumping his penis into her 14 MR. YAREMA: Object to the fonn. 14 vagina, that she screamed "No"? 15 A Fifth. 15 MR. YAREMA: Object to the fonn. 16 Q Do you recall Jeffrey Epstein 16 A Fifth. 17 instructing. to remove her clothes and Join 17 Q Do you recall that upon her screaming, 18 the two of you in bed? 18 Epstein stopped and apologized? 19 MR. YAREMA: Objoci to the fomi. 19 MR. YAREMA: Object to the fonn. 20 A Fifth. 20 A Fifth. 21 Q Do you recall that you and Jeffrey ,21 Q Do you recall that Jeffrey Epstein paid 22 Epstein bringing sex toys In bed for you and 22 her $1,000 for that visit? 23 to use on each other? 23 MR. YAREMA: Object to the form. 24 MR. YAREMA: Object to the fonn. 24 A Fifth. 25 A Fifth. 25 Q Did you engage In sex with when she 22 (Pages 82 to 85) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 22 of 38 EFTA_00067634 EFTA01246853 86 88 1 was under 18? 1 end of a play performance during her senior year? 2 MR. YAREMA: Object to the form. 2 MR. YAREMA: Object to the Conn. 3 A Fifth. 3 A Fifth. 4 Q Did Jeffrey Epstein watch you and M. 4 THE VIDEOGRAPHER: Counsel, can we stop 5 having sex while he masturbated? 5 for one minute? 6 MR. YAREMA: Object to the form. 6 MS. EZELL: Sure. 7 A Fifth. 7 THE VIDEOGRAPHER: Off the video record 8 Q Are you aware that M's activities 8 11:43 a.m. 9 with Jeffrey Epstein escalated further and (Short pause.) 10 further as time went on? 10 (Whereupon at this point in time, Mr. 11 Mit. YAREMA: Object to the form. 11 Langino left the proceedings.) 12 A Filth. 12 THE VIDEOGRAPHER: Back on the video 13 Q Did you see Jeffrey Epstein use 13 record 1:43 a.m. 14 vibrators and strap-on — use vibrators on M.? 14 CROSS EXAMINATION (CONTINUED) 15 MR. YAREMA: Object to the form. 15 BY MS. EZELL: 16 A Fifth. 16 Q Were you present in October 2005 when 17 Q Dld you and M. engage in sex with 17 the Palm Beach Police Department raided Jeffrey 18 strap-on penises? 18 Epstein's home? 19 MR. YAREMA: Object to the form. 19 MR. YAREMA: Object to the form 20 A Fifth. 20 A Fifth. 21 Q Did you see Jeffrey Epstein perform oral 21 Q You and others were aware that there 22 sex on M. numerous times? 22 would be a raid at that time; were you not? 23 MR. YAREMA: Object to the form. 23 MR. YAREMA: Object to the loon 24 A Fiflh. 24 A Fifth. 25 Q Did Jeffrey Epstein pay M. an 25 Q Who informed you that there would be a 87 89 1 additional 5200 to perform oral sex on you? 1 raid on the house? 2 MR. YAREMA: Object to the form. 2 MR. YAREMA: Object to the fonn. 3 A Fink 3 A Fifth. 4 Q Do you recall that each time a new toy 4 Q Did you participate in the removal of 5 or activity was Introduced when S was there to 5 nude photographs, sex toys, computer records from 6 give massages, Jeffrey Epstein paid 6 358 El Brillo Way prior to the raid? 7 additional money? 7 MR. YAREMA: Object to the roma MR. YAREMA: Objea to the coml. 8 A Fifth. 9 A Fifth. 9 Q Do you know who rentoved those objects at 10 Q Would Jeffr psteln masturbate while 10 that time? 11 watching you and perform sexual acts? 11 MR. YAREMA: Object to the form. 12 MR. YAREMA: Object to the form. 12 A Fifth. 13 A Fifth. 13 Q Do you remember that at times Jeffrey 14 Q Do you recall that Jeffrey Epstein 14 Epstein paid M. to just sleep in his bed in the 15 provided M. with gifts of purses and 15 nude? 16 bathingsults? 16 MR. YAREMA: Object to the form. 17 MR. YAREMA: Object to the form. 17 A Fifth. 18 A Fifth. 18 Q Do you recall at times he paid her to 19 Q Do you recall that Jeffrey Epstein 19 just cuddle with him? 20 provided M. with a blue 2000 Dodge Neon which 20 MR. YAREMA: Object to the form. 21 had been rented for her? 21 A Fifth. 22 MR. YAREMA: Object to the fonn. 22 Q Did you ever driveM. to Or from 358 23 A Fifth. 23 El Milo Way? 24 Q Do you recall that Jeffrey Epstein 24 MR. YAREMA: Object to the form. 25 ordered that roses be delivered ton at the 25 A Filth. 23 (Pages 86 to 8 9) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 23 of 38 EFTA_00067635 EFTA01246854 90 Q Did you ever know to drive 1 he would pay her 1,000 or 51,500 If she would 2 A.H. to or from 358 El Brillo Way? 2 lose ten pounds? 3 MR. YAREMA: Object to the form. 3 MR. YAREMA: Object to the form. 4 A Fifth. 4 A Fifth. 5 Q Do you remember the houseman at that Q Did you know M. to be a good student? 6 time as being Alfredo Rodriguez? 6 MR. YAREMA: Object to the form. MR. YAREMA: Object to the form. 7 A Fifth. 8 A Fifth. Q Did it appear that you that M. was 9 Q Do you remember Alfredo Rodriguez being 9 smart? 10 instructed to drive S to or from 358 El Brillo 10 MR. YAREMA: Object to the fort. 11 Way? 1.1 A Fifth. 12 MR. YAREMA: Object to the form. 12 Q Did you observe that M. was concerned 13 A Fifth. 13 about her grades? 14 Q Do you recall a time when Alfredo 14 MR. YAREMA: Object to the fonn. 15 Rodriguez discovered M. asleep upstairs naked? 15 A Fifth. 16 MR. YAREMA: Object to the form. 16 Q Do you recall Jeffrey Epstein expressing 17 A Fifth. 17 interest in M.'s college ambitions? 10 Q Were you aware Jeffrey Epstein 18 MR. YAREMA: Object to the form. 19 repeatedly asked M. to allow him to photograph 19 A Filth. 20 her in the nude? 20 Q Have you known Jeffrey Epstein to brag 21 MR. YAREMA: Object to the form. 21 about donations he's made to colleges like NYU, 22 A Fifth. 22 Columbia, Harvard and Wharton? 23 Q Did you allow Jeffrey Epstein to take 23 MR. YAREMA: Object to the Porn. 24 photographs, nude photographs of you? 24 A Fifth. 25 MR. YAREMA: Object to the form. 25 Q Do you know that M. wanted very much 91 93 1 A Fifth. 1 to go to school in New York at NYU or at 2 Q Do you recall a time when M. gave in 2 Columbia? 3 and did allow Jeffrey Epstein to photograph her 3 MR. YAREMA: Object to the form. 4 while nude? 4 A Fifth. 5 MR. YAREMA: Object to the form. 5 Q Did you know that Jeffrey Epstein 6 A Fifth. promised to help her get into one of those 7 Q Did you ever see any of those 7 schools? 8 photographs taken by Jeffrey Epstein of• in 8 MR. YAREMA: Object to the form. 9 the nude? 9 A Fifth. 10 MR. YAREMA: Object to the torn. 10 Q Do you know whether he did help? 11 A Fifth. 11 MR. YAREMA: Object to the form. 12 Q Do you know whether those photographs 12 A Fifth. 13 were ever developed? L3 Q Do you know whether he offered to pay 14 MR. YAREMA: Object to the form 14 some of her college expenses? 15 A Fifth. 15 MR. YAREMA: Object to the form. 16 Q Do you know what kind of camera Jeffrey 16 A Fifth. 17 Epstein liked to use when taking photographs of 17 Q Did you ever observe Jeffrey Epstein 18 women posing in the nude? 18 working with M. on her college applications? 19 MR. YAREMA: Object to the form. 19 MR. YAREMA: Object to the form. 20 A Fifth. 20 A Fifth. 21 Q Did you ever hear here Jeffrey Epstein 21 Q Did you ever see M. Just hanging out 22 tell M. that she needed to lose ten pounds? 22 al Jeffrey Epstein's house studying while nude? 23 MR. YAREMA: Object to the form. 23 MR. YAREMA: Object to the form. 24 A Fifth. 24 A Fifth. 25 Q Did you ever hear here him tell her that 25 Q Did you know that Jeffrey Epstein gave 24 (Pages 90 to 93) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 24 of 38 EFTA_00067636 EFTA01246855 94 96 1 M. airline tickets and theater tickets in New 1 A The Fifth. 2 York? 2 Q Do you know if typically girls who 3 MR. YAREMA: Object to the fonn. 3 Epstein knew, were given tickets to go to the 4 A Fifth. 4 show, then Invited back stage? 5 Q Did you and M. ever go shopping 5 MR. YAREMA: Object to the form. 6 together? 6 A Fifth. 7 MR. YAREMA: Object to the tinm. 7 THE VIDEOGRAPHER: Can you speak up? 8 A Fifth. 8 THE WITNESS: (Adjusts microphone.) 9 Q Did you call M. once and ask her to go 9 Q Did M. ever tell you that David 10 shopping with you for Jeffrey Epstein on his 10 Copperfteld tried to feel her butt during dinner? 11 birthday? 11 MR. YAREMA: Object to the font). 12 MR. YAREMA: Object to the form. 12 A Fifth. 13 A Fifth. 13 Q Did you ever hear Jeffrey Epstein 14 Q Did you and M. purchase adult sex toys 14 telling any of the young women who came to give 15 to use for Jeffrey Epstein's birthday, as a show, 15 him massages, that he was a brain scientist? 16 for him? 16 MR. YAREMA: Object to the Comm. 17 MR. YAREMA: Object to the form. 17 A Fifth. 18 A Fifth. 18 Q Did you know M.? 19 Q Are you aware that Jeffrey Epstein told A Fifth. 20 he would pay her to bring other young girls 0 Q And from now on I will use the initials 21 to give him massages? M. Do you know that M. visited Jeffrey 22 MR. YAREMA: Object to the Porn. 2 Epstein at 358 El Brlllo Way some 15 to 20 times? 23 A Fifth. 3 MR. YAREMA: Object to the form? 24 Q Do you know that Jeffrey Epstein paid 4 A Filth. 25 M. 5200 for each girl that she brought to him, 5 Q Did you ever Interact with M. while 95 97 1 to give him a massage? 1 she was there to give a massage? 2 MR. YAREMA: Object to the form. 2 MR. YAREMA: Object to the form 3 A Fifth. 3 A Fifth. 4 MR. GOLDBERGER: I guess we will have to 4 Q Dld you know that at the time she was 5 take a break now, if that's all right with 5 visiting Mr. Epstein and providing massages, she 6 you. 6 was under the age of 18? 7 MS. EZELL: Okay. 7 MR. YAREMA: Object to the form. 8 THE VIDEOGRAPHER: 11:50 a.m., going off 8 A Fifth. 9 the video record. 9 Q Do you recall being introduced to M. 10 MR. GOLDBERGER: I will be done at 1:15 10 by Mr. Epstein? 11 so we can go until 1:30. 11 MR. YAREMA: Object to the form. 12 (Pause in the proceedings.) 12 A Fifth. 13 THE VIDEOGRAPHER: We are bock on the 13 Q Do you recall that Jeffrey Epstein 19 video record at 1:36 p.m. 14 Instructed you and M. to kiss and fondle each 15 CROSS EXAMINATION (CONTINUED) 15 other around the breasts and buttocks while 16 BY MS. EZELL: 16 massaging him? 17 Q f did you ever have dinner 17 MR. YAREMA: Object to the form. 18 at Jeffrey Epstein's house, with David 10 A Fifth. 19 Copperfield as a guest, when was present? 19 Q Did you ever see Mr. Epstein use a large 20 MR. YAREMA: Object to the form. 20 vibrator/massager on M.? 21 A The Fifth. 21 MR. YAREMA: Object to the form. 22 Q Have you met David Copperfleid? 22 A Fifth. 23 A Fifth. 23 Q Did Jeffrey Epstein ever ask you to 24 Q (lave you ever been given tickets to go 24 purchase a digital camera for hint to give M. ? 25 see one of his shows? 25 MR. YAREMA: Object to the form. 25 (Pages 94 to 97 U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 25 of 38 EFTA_00067637 EFTA01246856 98 100 1 A Filth. 1 THE STATE OF FLORIDA) 2 Q Did you know that Jeffrey Epstein gave 2 COUNTY OF PALM BEACH) 3 I, TERRI BECKER, a Registered 3 a digital camera? 4 Pmfessional Reporter and Notary Public for the 4 MIL YAREMA: Object to the Iona. 5 State of Florida at Large, do hereby certify that 5 A PM. 6 I reported the videotaped deposition of 6 MS. EZELL: I don't have any other 7 the WITNESS, called by the PLAINTIFF 7 questions. Thank you. 8 in the above-entitled action: that the witness 8 MR. GOLDBERGER: You still have your 9 was duly swami by me; that the foregoing pages, 9 microphone on. You must have something on 10 numbered from 1 to 104, inclusive, constitute a 10 your mind, Brad. 11 true record of the deposition by said witness. 11 12 I further certify that I am not attorney REDIRECT EXAMINATION 13 or counsel of any of the patties, nor a relative 12 BY MR. EDWARDS: 14 or employee of any attorney or counsel connected 13 Q through the whole day with the action, nor financially interested in 15 14 you've taken the Fifth on just about every single 16 the action. 15 question. Is there any reason why we should not 17 WITNESS MY IIAND and official seal in the 16 presume that the answer to these questions would 18 City of West Palm Bradt, County of Palm Beach, 17 Incriminate you? 19 State of Florida, this 19th day of April 2010. 18 MR. YAREMA: Object to the form. 20 19 A The Fifth. 21 TERRI ECK ER, Registered 20 Q The reason that you have taken the Fifth Professional Reporter and 21 is because the questions you have been asked Notary Public, State of Florida 22 22 would have been answered in the affirmative and at Lame. My Commission expires 23 you're afraid of prosecution for your 23 March 13,2011. 24 Involvement, true? 24 25 MR. GOLDBERGER: Don't answer that 25 99 101 question. It interferes with the 1 THE STATE OF FLORIDA) 2 attorney/client relationship that I have 2 COUNTY OF PALM BEACH) 3 with and any discussions she 3 and I may have had would come under that 4 5 privilege. 5 The foregoing certificate was 6 acknowledged before me this 6 You can try and dance around that, but 7 day of 2010. 7 I'm simply not going to allow her to answer 8 that question. If you want to bring it up 9 9 with the Judge, you can. 10 10 MR. EDWARDS: Thanks, Jack. 11 11 MR. GOLDBERGER: Okay. 12 12 THE VIDEOGRAPHER: Off the video record 13 13 at 1:41 p.m. 14 14 THE COURT REPORTER: You're ordering Notary Public, State of Florida. 15 this, Brad? 15 My commission No. 16 MR. EDWARDS: Yes. Copies? Expires March 13, 2011. 17 MS. EZELL: Yes. 16 17 18 MR. YAREMA: Yes: 18 19 THE COURT REPORTER: And Adam wanted it; 19 20 is that right? 20 21 MR. EDWARDS: Yes. 21 22 (Time noted: I:45 p.m.) 22 23 23 24 24 25 25 26 (Pages 98 to 101) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 26 of 38 EFTA_00067638 EFTA01246857 102 10 4 do hereby 1 U.S. 1 (GAL SL1PPOR Iterenered Pmfoontal RCPOdarN 2 certify that I have read the foregoing transcript 2 444 W40 luaaed A4cnut Sonic MP 3 of my deposition given on April I), 20)0; that Wert Patin Read. Plaid M401 (561)815.0220 together with the correction page attached hereto 4 5 noting changes in form or substance, if any, it April 19. 2010 5 6 is true and correct. 6 • ". a tISS 7 7 ATTENTION: JACK GOLDBERGER. ESQ. 9 In Re: 110E V. EPSTEIN 10 10 DqatIlion of - 11 11 12 Ds Mr. Otaltraucc 12 11 Sane cannel lone agreeddam ant may love the natant read and an your copy et the 13 14 dcpaaarn. for yoga amremeae. OICIOWCI 14 I do hereby certify that the deposition ilOC•0 )0.1nut Owl an Enna Shed Ice die 15 umutot ant a aval tog tiNy thanga.M Orc 15 of was submitted to the witness dtwoniun 16 16 for reading and signing; that alter she had Tbank you for your inompi tainaion. 17 stated to the undersigned Notary Public that she 17 Conbally yours, 18 had read and examined her deposition, she signed 18 11.6 LEGAL S(.112P(5111. 19 19 the same in the presence of the undersigned . ....._._ . 2010. 20 lERRI IILCKER. Rcaucred 20 authority on the day of Profasional Reporter. Idogny 21 21 Public. Sole or numb a Lair. My c044/04000 cpwcs 22 22 Kw,* I). 2011 2) CC UatlIty Edwards. Eal. 23 Adam Ilona in. Log 24 ...1 Kultnoc Lull, Ea. Onnd Vanua. Ca 25 25 103 1 ERRATA SHEET 2 In Re: DOE V. EPSTEIN 3 DO NOT WRITE ON TRANSCRIPT ENTER CHANGES HERE: 4 5 PAGE LINE CHANGE REASON 6 7 8 9 10 11 12 13 14 15 16 17 18 THE STATE OF FLORIDA) 19 COUNTY OF PALM BEACH) 20 I DO HERESY CERTIFY THAT opwan:d below Inc and stated dial she has read 21 her deposition; further. that this Errata Shed was sigixst in my Rae= on Ibis day 22 of 2010. 23 24 25 27 (Pages 102 to 104) U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 27 of 38 EFTA_00067639 EFTA01246858 Page 1 U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 28 of 38 EFTA_00067640 EFTA01246859 Paae 2 U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 29 of 38 EFTA_00067641 EFTA01246860 U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 30 of 38 EFTA_00067642 EFTA01246861 Page 4 U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 31 of 38 EFTA 00067643 EFTA01246862 Pa9e 5 U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 32 of 38 EFTA 00067644 EFTA01246863 Page 6 U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 33 of 38 EFTA_00067645 EFTA01246864 Page "/ U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 34 of 38 EFTA_00067646 EFTA01246865 Pace 8 U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 35 of 38 EFTA_00067647 EFTA01246866 U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 36 of 38 EFTA_00067648 EFTA01246867 U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 37 of 38 EFTA_00067649 EFTA01246868 U.S. Legal Support (561) 835-0220 3501.144-028 CONFIDENTIAL Page 38 of 38 EFTA_00067650 EFTA01246869