UNITED STATES DISTRICT COURT

0001 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 Case No. 08-CV-80893-CIV-MARRA/JOHNSON 3 4 5 JANE DOE, 6 Plaintiff, 7 vs. 8 JEFFREY EPSTEIN, et al., 9 Defendants. 10 11 12 13 DEPOSITION OF Volume 14 Pages 1 through 138 Videotaped 15 16 17 Monday, March 15, 2010 10:13 a.m. - 12:42 p.m. 18 U.S. Legal Support 515 East Las Olas Boulevard, 3rd Floor 19 Fort. Lauderdale, Florida 33301 20 21 Stenographically Reported By: 22 Janet L. McKinney, RPR, FPR, CLR 23 Registered Professional Reporter 24 Florida Professional Reporter 25 Certified LiveNote Reporter 0002 1 APPEARANCES: 2 ON BEHALF OF THE PLAINTIFF: 3 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN 4 425 North Andrews Avenue Suite 2 5 Fort Lauderdale, Florida 33301-3268 6 BY: BRADLEY EDWARDS, ESQ. 7 8 ON BEHALF OF THE DEFENDANT JEFFREY EPSTEIN: 9 BURMAN, CRITTON, LUTTIER COLEMAN, LLP 10 303 Banyan Boulevard Suite 40C 11 West Palm Beach, Florida 33401 12 3524-006 Page I of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009248 EFTA00159250 BY: MICHAEL J. PIKE, ESQ. 13 14 ON BEHALF OF OTHER PLAINTIFFS IN RELATED CASES: 15 KERMELSTEIN & HOROWITZ, P.A. 18205 Biscayne Boulevard 16 Suite 2218 Miami, Florida 3316C 17 18 BY: STUART S. MERMELSTEIN, ESQ. 19 ON BEHALF OF THE WITNESS: 20 ROBBINS, TUNKEY, ROSS, AMSEL, 21 RABEN & WAXMAN, P.A. 2250 Southwest Third Avenue 22 4th Floor Miami, Florida 33129 23 24 BY: ALAN S. ROSS, ESQ. 25 Also Present: Sean McGuire, Videographer U.S. Legal Support 0003 1 2 3 INDEX Page Direct Examination By Mr. Edwards 7 4 Cross-Examination By Mr. Mermelstein 111 Redirect Examination By Mr. Edwards 127 Recross-Examination By Mr. Mermelstein 133 6 7 Certificate of Oath 137 8 Certificate of Reporter 138 9 10 EXHIBITS 11 PLF'S 12 No. Description Page 13 14 1 Jane Doe 102 v. Jeffrey Epstein 33 15 complaint 16 2A-2G Telephone messages 62 17 3 Handwritten notes 72 18 2H Telephone message 87 19 4 Gawker.com photo with story 127 20 21 22 WITNESS'S 23 No. Description Page 24 25 1 Target letter 4 0004 1 Videotaped deposition taken before JANET L. 3524-006 Page 2 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009249 EFTA00159251 2 McKINNEY, Registered Professional Reporter, Florida 3 Professional Reporter, Certified LiveNote Reporter and 4 Notary Public in and for the Slate of Florida at Large 5 in the above cause. 6 (Whereupon, Witness's Exhibit 1 was marked for 7 identification.) 8 VIDE0GRAPHER: We are now on the video record. 9 Today is Monday, the 15th day of March, 2010. The 1C time is 9:13 a.m.. (sic). We are here al 515 East. 11 Las Olas Boulevard, 3rd Floor, Fort Lauderdale, 12 Florida, for the purpose of taking the videotape 13 14 deposition of taken in Case Number 08-CIV-80893, ane oe v. effrey Epstein, el. al. 15 The court reporter is Janet. McKinney; the 16 videographer is Sean McGuire, both of V.S. Legal 17 Support. 18 Will counsel and all present please introduce 19 yourself and the court reporter will swear the 20 witness. 21 N.R. EDWARDS: Brad Edwards. I represent the 22 plaintiff, Jane Doe also "Jane Doe"; EW, "EW"; LM, 23 'LM.". 24 MR. MERMELSTEIN: Stuart Mermelstein. I 25 represent Jane Doe Numbers 2 through 8. 0005 1 MR. PIKE: Michael Pike on behalf of Jeffrey 2 Epstein. 3 MR. ROSS: And good morning, my 4 Ross. I represent the witness, 5 THE REPORTER: Would you raise your rig 6 hand, please. 7 Do you solemnly swear or affirm the testimony 8 you're about to give will be the truth, and nothing 9 but the truth, so help you God? 10 THE WITNESS: I do. 11 MR. ROSS: Before the deposition begins and in 12 an effort to streamline the process of getting 13 through this deposition on behalf of the witness we 14 have had marked as Witness Exhibit Number 1 an 15 August 31, 2007 letter from the United States 16 Attorney's Office through 17 her then counsel, which is called a 18 target. letter ide. as a target of a 19 federal Grand Jury investigation in the Southern 20 District of Florida and outlining a number of 21 offenses that. were the subject =alter of 22 investigation. 23 As a result of that, it is anticipated that. 24 some of the questions that may be asked during the 25 course of this deposition she may invoke her Fifth 0006 1 Amendment privilege against self-incrimination. 2 And in order to streamline this we've agreed prior 3 to beginning this that she will simply answer "I name is Alan 3524-006 Page 3 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009250 EFTA00159252 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0008 1 2 3 4 5 4 refuse to answer.' The parties will understand and 5 the record will reflect that, she is invoking her 6 Fifth Amendment privilege against 7 self-incrimination. 8 If there is some other privilege, 9 attorney-client privilege or sore other objection 1C Chat I may have to a question, I'll specifically 11 state it. But her answer °I refuse to answer• will 12 be on Fifth Amendment grounds if that's acceptable 13 CO everyone. 14 MR. EDWARDS: It's acceptable. 15 KR. MERMELSTEIN: It's acceptable. 16 KR. PIKE: Acceptable. 17 MR. ROSS: Okay. Madam court reporter has 18 already marked the exhibit, and I'll leave that 19 with her. 20 MR. EDWARDS: Okay. 21 22 23 24 25 0007 1 THEREUPON: 2 3 having been first duly sworn or affirmed, was examined 4 and testified as follows: 5 DIRECT EXAMINATION 6 BY K.R. EDWARDS: 7 Q. Can you tell us your full 8 A. Q. At some point in time you is that correct? A. Correct. Q. And when did that change? ou married? Q. When were A. Q. uk4v. whni 'mvout le of birth? A. [ Q. A. Yes. full name. were known as Q. And who are you married to? 3524-006 Page 4 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009251 EFTA00159253 6 A. Correct. 7 8 9 10 11 w 12 13 14 15 A. 16 Q. w o was t e connection at 17 that invited you? 18 19 20 21 22 23 24 25 0009 1 2 5 6 3 4 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0010 1 2 3 4 6 7 Q. Well, you can continue. A. Yes. Q. So in order to come to the United States you needed to get a work visa? A. I was invited actually just to kind feeling if I will be suitable. So I came on tourist visa which is, I believe, 61/82. of get a a business 3524-006 Page 5 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009252 EFTA00159254 9 IC 11 12 13 14 15 16 17 18 19 2C 21 22 23 24 25 0011 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 2C 21 22 23 24 25 0012 2 8 Q. Okay. And where did you first go when you came to the United States, what state? A. Florida. Q. And what city in Florida? A. Miami. Q. And what did you do for your two weeks when you first arrived in Miami, Florida? A. I do not recall. Q. Okay. But did you do any modeling? A. Well, like I would see some photographers, the agency would send me like on all calls to see photographers to kind of introduce me as a model. why did you make the decision Lo go with in the United Stales when you already were modeling in -- A. Um-hum. Q. -- Europe? A. Well, you know, just to expand it was something that I did. And I decided to take a year off after I graduated from. high school and -- you know, just to expand the modeling -- the modeling possibilities, opportunities. Q. Where di uate from high school? A. In Q. What ear? A. Q. And do you have any college? Have you gone to college after that? did you get your associate's degree from. A. Q. chelor's degree right now? A. Yes. Q. From where? A. Q. in wnaL. A. Q. a you been in the program? A. Since fall Q. And when do you expect to graduate? 3 A. Fall 4 Q. Are you a full-Lime student or part-Lime? 5 A. I'm a full-time student at this time. 6 you first arrived in Miami, Florida in 7 did you decide during that two weeks that_ 8 you were going to stay permanently? 9 A. No. 3524-006 Page 6 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009253 EFTA00159255 IC Q. Okay. Did you go back to 11 A. Yes, I have. I have -- I went back for 12 Christmas. 13 Q. Okay. Poor question. Going back LcI'm 14 trying to just understand how it was that -- you came 15 over here on a two-week business visa, but eventually 16 you ended up staying for a longer period of Lime, 17 correct? 18 A. Right- 19 Q. Okay. And how did that. come about, just tell 20 me? 21 A. Well, I got. romantically involved with my 22 current husband and so when -- you know, we just 23 started dating, we got engaged, and that's how, you 24 know, our relation evolved -- evolved, and eventually, 25 you know, I got married and -- and stayed. 0013 1 Q. Okay. And since coming to the United States 2 have you always lived in Miami, Florida? 3 A. No. 4 Q. All right. Where else have you lived in the 5 United States? 6 A. New York. 7 Q. Where in New York? 8 A. Manhattan. 9 Q. What, was the address in Manhattan where you 10 lived? 11 MR. ROSS: I'm going to advise you Lo invoke 12 privilege. 13 A. I refuse to answer. 14 Q. Okay. Have you -- are you familiar with an 15 address at 301 East 66th Street in New York? 16 A. I refuse to answer. 17 MR. PIKE: May we take a break for a second? 18 May I speak with you? 19 MR. ROSS: Sure. 20 VIDEOGRAPHER: Off the record, 10:22 a.m. 21 (Recess Laken at 10:22 a.m.) 22 (Deposition resumed at 10:23 a.m.) 23 VIDEOGRAPHER: On the record, 10:23 a.m.. 24 MR. ROSS: Brad, let me just interrupt for a 25 moment. 0014 1 MR. EDWARDS: No problem. 2 MR. ROSS: Just to be sure, when the witness 3 answers "I refuse to answer" to be clear the Cull 4 statement that she's not saying for the sake of 5 saving Lime is that. she's invoking her Fifth 6 Amendment right against self-incrimination. Just. 7 to be clear. 8 MR. EDWARDS: That's what I've understood all 9 along. IC MR. MERMELSTEIN: That's what I understood. 11 MR. ROSS: Okay, fine. Go ahead. 3524-006 Page7of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009254 EFTA00159256 12 MR. EDWARDS: This is just for the sake of 13 brevity -- 14 MR. ROSS: Exactly. 15 MR. EDWARDS: -- and let's move it on. 16 BY MR. EDWARDS: 17 Q. All right. So I'm going to ask the question 18 again, I don't remember whether you'd responded yet, 19 but are you familiar with the address in Manhattan 20 301 East. 66th Street in New York? 21 A. I refuse to answer. 22 Q. Okay. How long did you live in -- well, what 23 was the first address that you lived in in Miami? 24 A. 25 0015 1 Q. South Shore. Okay. 2 A. Um-hum. 3 Q. Have you ever had your deposition Laken 4 before? 5 A. No. 6 Q. Okay. You're doing very well so far. There's 7 a couple rules I didn't explain but mainly because 8 you're doing very well. I just. have to wait for you to 9 finish your answer; you have to wait for me to finish 10 my question. We have one court reporter. She can only 11 Lake down one of us. Give us an answer that we all 12 understand. Nodding of the head or shaking the head 13 are easy to do and I gel what you're saying, but she 14 doesn't. Ah-ha or un-ah are things that are commonly 15 said. They look the same on paper. 16 If I ask a bad question which could happen, as 17 already happened and probably will again, just tell me 18 'I don't understand the question," I'll ask it again -- 19 A. Okay. 20 Q. -- all right? 21 And I'm assuming that's the address, 22 where you began living in !Pk 23 24 A. Correct. 25 Q. How long did you live al that address? 0016 1 A. I'm sorry, I don't understand our uestion. 2 Q. How long did you live al the 3 address that you moved into in the fall in 2002? 4 A. Well, since -- since I came I lived there, I 5 always stayed there whether being in Miami traveling 6 back and forth, and I live currently at this address. 7 Q. Okay. What was the first lime that you moved 8 from that address to live elsewhere? 9 A. I do not recall. IC Q. Okay. I know that you told me you lived in 11 New York City and we're not going to discuss -- I'm 12 assuming you're not going to answer a lot of questions 13 about New York City, but at what time period did you 3524-006 Page 8 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009255 EFTA00159257 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 C018 1 2 3 4 5 6 14 move there? Was it right after you got here two weeks, 15 a year later? I'm just trying to get a year as to when 16 you moved Lo New York? 17 MR. ROSS: I'm going Lo instruct you not to 18 answer. 19 A. I refuse to answer. 20 Q. Okay. Do you know a guy by the name of Jean 21 Luc Brunel? 22 A. I refuse to answer. 23 Q. Where are your parents? 24 A. They're in 25 Q. And since you ve been n t e United States C017 1 2 3 4 5 have they come to the United Stales? A. Yes, they have visited me. Q. Have they ever met Jeffrey Epstein? A. I refuse to answer. Q. Have they ever met Jean Luc Brunel? 6 A. I refuse to answer. 7 Q. Where are you currently employed? 8 A. I pursue -- I go to school full-time, I do not work. Q. Are you also still though? A. No, I'm not. Q. And when was the last. Lime you did any modeling? in the modeling business Q. And why did you stop modeling at that. tire? A. I wanted -- I always kind of knew that it's something Lhat I'm going to be doing and I just decided to go and pursue a college degree. Q. Okay. Is it something that you ever plan to go back to, modeling? A. No. Q. Are you involved at all with the modeling industry? A. No. Q. I mean, helping to recruit models, helping others to recruit models, anything like that? A. No. Q. Do you ever -- do you currently talk Co Er. Brunel? 7 A. I refuse to answer. 8 Q. When is the last time that you talked to 9 Jeffrey Epstein? IC A. I refuse to answer. 11 Q. Do you know a woman by the name of Ghislaine 12 Maxwell? 13 A. I refuse to answer. 14 Q. Do you know someone by the name of 15 3524-006 Page 9 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009256 EFTA00159258 16 A. I refuse to answer. 17 Q. Do you know a person named 18 A. I refuse to answer. 19 Q. Did Jeffrey Epstein have anything Lo do with 20 you moving to New York City? 21 A. I refuse to answer. 22 Q. Did you ever live in a place in New York City 23 owned or controlled by Jeffrey Epstein? 24 A. I refuse to answer. 25 Q. Are you familiar with the modeling agency MC 0019 1 Squared? 2 A. I refuse to answer. 3 Q. Do you know of underage females being 4 transported into this country to work for the modeling 5 agency MC Squared? 6 A. I refuse to answer. 7 Q. Do you know of those underage females being 8 given work visas and staying at the 301 East 66th 9 Street address? 10 A. I refuse to answer. 11 Q. Can you say whether you have observed 12 Mr. Brunel or Mr. Epstein engaging in sex with underage 13 females? 14 A. I refuse to answer. 15 Q. Do you know where Mr. Brunel lives? 16 A. I refuse to answer. 17 Q. Is it true that. Mr. Brunel slays in the 301 18 East. 66th address frequently with underage females? 19 A. I refuse to answer. 20 Q. AL what point were you hired to work for 21 Mr. Epstein? 22 Nil. PIKE: Form. 23 MR. EDWARDS: You can still answer the 24 question. Mr. Pike is making a legal objection. 25 A. I refuse to answer. 0020 1 Q. And how did -- how did it come about that you 2 began working with Jeffrey Epstein? 3 MR. PIKE: Form. 4 A. I refuse Lo answer. Q. What did Jeffrey Epstein pay you in salary? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. What was the time period that. you worked for 9 him? 10 A. I refuse to answer. 11 Q. Why did you stop working for him? 12 MR. PIKE: Form. 13 A. I refuse to answer. 14 Q. What initially were you hired to do? 15 A. I refuse to answer. 16 MR. PIKE: Form. 17 Q. Has Jeffrey Epstein ever paid you to stay 3524-006 Page 10 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009257 EFTA00159259 18 19 20 21 22 23 24 25 0C21 1 2 3 4 5 6 7 8 l0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0022 2 3 4 5 6 7 8 9 IC 11 12 13 14 15 16 17 18 19 quiet or keep quiet about what went on in his house? MR. PIKE: Form. A. I refuse 10 answer. Q. Have you talked to about the things Epstein s ouse? MR. PIKE: Form. A. I refuse to answer. that went on in Jeffrey Q. Did you sign a confidentiality agreement with Jeffrey Epstein? A. I refuse to answer. MR. PIKE: Form. Q. Did that confidentiality agreement outline what you should say to authorities should he be caught with underage females? MR. PIKE: Form. A. I refuse to answer. Q. Is there another book or manual or written memorialization of what you, as an employee of Jeffrey Epstein, should do if confronted by law enforcement? MR. PIKE: Form. A. I refuse to answer. Q. Are you invoking your Fifth Amendment right because you believe you could be prosecuted? MR. ROSS: Invoke. A. I refuse to answer. Q. Are you also invoking because you're scared to testify against Jeffrey Epstein? MR. PIKE: Form. A. I refuse to answer. Q. When did you first learn that Jeffrey Epstein had a sexual obsession for underage females? A. I refuse to answer. V.A. PIKE: Form. Q. Isn't it true that you have seen Jeffrey Epstein sexually interacting with females as young as 12 years old? A. I refuse to answer. MR. PIKE: Form. Q. Is it true that you have observed Jeffrey Epstein's sexual obsession to include the age range 12 to 17? MR. PIKE: Form. A. I refuse to answer. Q. Have you ever had sex with Jeffrey Epstein? A. I refuse to answer. MR. PIKE: Form. Q. Have you ever been paid for sex with Jeffrey Epstein? MR. PIKE: Form. A. I refuse to answer. Q. Do you know if had sex with 3524-006 Page II of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009258 EFTA00159260 20 Jeffrey Epstein when she was underage? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. What have you been told about Jeffrey 24 Epstein's sexual obsession with underage minor 25 children? 0023 1 MR. PIKE: Form. 2 A. I refuse to answer. 3 Q. Isn't it true that Jeffrey Epstein interacted 4 sexually with underage minors on an everyday basis? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. And most of the time Mr. Epstein would 8 interact with underage minors at least two times a day; 9 is that true? 10 MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. Can you explain to the jury how Mr. Epstein 13 would access new underage minor females for sex every 14 day? 15 MR. PIKE: Form. 16 A. I refuse to answer. 17 Q. How many assistants did Jeffrey Epstein hire 18 to bring him underage minor females for sex? 19 A. I refuse to answer. 2C M.R. PIKE: Form. 21 Q. Were you one of those assistants that helped 22 to bring him underage minor females? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. I know that_ the laws in are probably 0024 1 different than they are here, but are you familiar with 2 the Florida Statutes that protect children against 3 sexual offenders or sexual predators? 4 MR. ROSS: Invoke. 5 A. I refuse to answer. 6 Q. Let me just read you the lewd or lascivious 7 molestation statute and then I'm going to ask you some 8 questions about iL. 9 IL says: 'A person who intentionally touches IC in a lewd or lascivious manner the breasts, genitals, 11 genital area or buttocks or the clothing covering them 12 of a person less than 16 years of age or forces or 13 entices a person under 16 years of age to so touch the 14 perpetrator, commits lewd or lascivious molestation, a 15 second degree felony.' 16 After hearing that statute isn't that 17 something -- isn't that a crime that you know 18 Mr. Epstein to have committed on an everyday basis 19 while you were working for him? 2C MR. PIKE: Form. 21 A. I refuse to answer. 3524-006 Page 12 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009259 EFTA00159261 22 Q. And that's a statute that he violated with 23 more than 1CC underage females; is that true? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0025 1 Q. When did you become aware that. Mr. Epstein was 2 a child molester? 3 MR. PIKE: Form. 4 A. I refuse to answer. 5 Q. Have you ever seen him with a female under the 6 age of 12? 7 MR. PIKE: Form. 8 A. I refuse to answer. 9 Q. Have you ever known Jeffrey Epstein to have 10 sex with an adult? 11 MR. PIKE: Form. 12 A. I refuse to answer. 13 Q. Does he -- is he sexually attracted to adults? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. When was the first time you learned of 17 Mr. Epstein getting a massage from an underage minor 18 female? 19 MR. PIKE: Form. 20 A. I refuse to answer. 21 Q. I realize some of these questions may sound 22 repetitive but during this case we've learned of key 23 terms that different people on Mr. Epstein's let's say 24 payroll or inner circle recognize or talk about. So 25 when I talk about •massages', do you know what. that 0026 1 term means? 2 MR. PIKE: Form. 3 A. I refuse to answer. 4 Q. Isn't "massage• the word that was told by 5 Jeffrey Epstein to all of his employees to refer to 6 whatever acts he engages in with underage females in 7 his bedroom? 8 MR. PIKE: Form. 9 A. I refuse to answer. 10 Q. AL this point -- were you -- were you ever in 11 the bedroom with him when he was engaging in sexual 12 acts with underage females and calling them "massages"? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. Did you ever participate in any of the sexual 16 acts that Jeffrey Epstein was having with underage 17 females? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. Now, just so that the record is clear there is 21 not a single piece of evidence that ever indicates that 22 you were involved with underage females, I'm not even 23 implying that and I realize that you invoking it may -- 3524-006 Page 13 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009260 EFTA00159262 24 may give the wrong light and that's not -- that's not 25 my intention, so -- but were you ever aware of 0027 1 participating in sex with underage females? 2 A. I refuse to answer. 3 Q. Have you read the police reports related to 4 the criminal investigation into Mr. Epstein? 5 A. I refuse to answer. 6 Q. And you're aware of this 87-page police report 7 that details numerous females that indicate that they 8 were involved sexually with Mr. Epstein when they were 9 minors? 10 A. I refuse to answer. 11 N.R. PIKE: Form. 12 Q. Did anyone instruct you to use the code word 13 *massage"? 14 A. I refuse Lo answer. 15 Q. And when referring to these underage minor 16 females that would come over to Mr. Epstein's house did 17 anybody also tell you to use the term 'work•? 18 A. I refuse to answer. 19 MR. PIKE: Form. 20 Q. Meaning when somebody would call to schedule 21 one of these underage females for a massage isn't it 22 true that they would say "It's time to come to work" 23 and schedule a specific appointment? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0028 1 Q. Is there a book or manual or is it written 2 anywhere that the -- that sex with underage minors is 3 to be referred to as a "massage"? 4 A. I refuse to answer. 5 MR. PIKE: Form. 6 Q. Were there ever team meetings, for lack of a 7 better word, where Jeffrey Epstein and possibly 8 Ghislaine Maxwell, yourself, would talk 9 about this organization of obtaining underage girls for IC Jeffrey Epstein for sex? 11 MR. PIKE: Form. 12 A. I refuse Lo answer. 13 Q. What methods does Jeffrey Epstein use to gain 14 access to underage minor females for sex? 15 MR. PIKE: Form. 16 A. I refuse to answer. 17 Q. What is your understanding of Jeffrey 18 Epstein's involvement with the modeling industry? 19 MR. PIKE: Form. 20 A. I refuse to answer. 21 Q. Have you ever modeled for MC Squared? 22 MR. PIKE: Form. 23 A. I refuse Lo answer. 24 Q. Has Jeffrey Epstein ever promised you anything 25 related to a modeling career? 3524-006 Page 14 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009261 EFTA00159263 0029 1 MR. PIKE: Form. 2 A. I refuse to answer. 3 Q. Have you ever talked to Jean Luc Brunel about 4 modeling? 5 A. I refuse to answer. 6 Q. Rave you ever talked to Jean Luc Brunel about 7 his desire to have sex with underage females? 8 A. I refuse to answer. 9 Q. Isn't it true that Jean Luc Brunel has been in 10 trouble for years for having sex with underage minors 11 in Europe? 12 A. I refuse to answer. 13 Q. Are you familiar with The McIntyre Reports? 14 A. I refuse to answer. 15 Q. Okay. Are you familiar with reports done on 16 modeling agencies back in the 80's and 90's related to 17 agency owners having sex with underage minors? 18 MR. ROSS: Answer the question. 19 A. No, I'm not. 20 Q. Okay. Did you ever hear of Jean Luc Brunel's 21 reputation for having sex with underage girls? 22 MR. ROSS: Invoke. 23 A. I refuse to answer. 24 Q. Do you know how Jean Luc Brunel knows Jeffrey 25 Epstein? 0030 1 A. I refuse to answer. 2 MR. PIKE: Form. 3 Q. Isn't their connection the obsession for 4 underage minor females? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. Based on your observations of Jeffrey Epstein 8 would you categorize his obsession for underage minor 9 females as an addiction? 10 MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. Isn't it true that Ghislaine Maxwell delivers 13 underage minor females to Jeffrey Epstein? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. Have you ever had a sexual relationship with 17 Ghislaine Maxwell? 18 A. I refuse to answer. 19 Q. Do you know what Ghislaine Maxwell does in 20 general for Jeffrey Epstein? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. Have you seen photographs of underage minor 24 females in Jeffrey Epstein's patrol -- control or 25 possession? 0031 1 MR. PIKE: Form. 3524-006 Page 15 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009262 EFTA00159264 2 A. I refuse to answer. 3 Q. Were there surveillance cameras, hidden 4 surveillance cameras inside Jeffrey Epstein's home? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. Did those surveillance cameras capture 8 underage minor females naked? 9 MR. PIKE: Form. 10 A. I refuse to answer. 11 Q. And didn't Jeffrey Epstein and Ghislaine 12 Maxwell watch those surreptitiously obtained videos of 13 underage minor females? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. And those videos and photographs of underage 17 minor females were saved on Jeffrey Epstein's computers 18 in his house, right? 19 MR. PIKE: Form. 20 A. I refuse to answer. 21 Q. Have you seen those photographs and videos on 22 Jeffrey Epstein's computers? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. Who have you talked to related to the criminal 0032 1 investigation into Jeffrey Epstein? 2 A. I refuse to answer. 3 MR. PIKE: Form. 4 MR. ROSS: In addition, attorney-client 5 privilege. 6 Q. And I certainly would do not want to know 7 anything you talked to your attorney about, I 8 apologize. 9 A. (Nods.) 10 Q. Why was it that you were named as a 11 co-conspirator of Jeffrey Epstein's in the 12 non-prosecution agreement? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. Do you feel like a victim of Jeffrey 16 Epstein's? 17 MR. PIKE: Form. 18 A. I refuse to answer. 19 Q. Do you feel like Jeffrey Epstein brainwashed 20 you to some extent? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. Do you feel any remorse for any role that. you 24 may have played in having underage minor females at 25 Jeffrey Epstein's house for him to molest them? 0033 1 MR. PIKE: Form. 2 A. I refuse to answer. 3 Q. Have you known Ghislaine Maxwell and Jeffrey 3524-006 Page 16 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009263 EFTA00159265 4 Epstein to keep sex slaves? 5 A. I refuse to answer. 6 Q. Do you know somebody named 7 A. I refuse to answer. 8 Q. Have you met 9 A. I refuse to answer. 10 MR. EDWARDS: All right. Let me go ahead and 11 mark as -- as Plaintiff's Exhibit. 1 a lawsuit that 12 was filed by Bob Josefsberg on behalf of Jane Doe 13 102 v. Jeffrey Epstein just for the purposes of 14 asking the witness some questions. 15 MR. ROSS: I've seen it. 16 (Whereupon, Plaintiff's Exhibit 1 was marked 17 for identification.) 18 Q. Have you ever read the lawsuit Jane Doe 102 v. 19 Jeffrey Epstein? 20 A. I refuse to answer. 21 Q. In the lawsuit it indicates the plaintiff was 22 15 years old when Ghislaine Maxwell and Jeffrey Epstein 23 had a threesome with this underage minor female. Are 24 you aware of that? 25 MR. PIKE: Form. 0034 1 A. I refuse to answer. 2 Q. And Jeffrey Epstein and/or Ghislaine Maxwell 3 obtained and purchased passports for 15-year-old Jane 4 Doe 102 to transport her to Palm Beach, New York City, 5 Santa Fe, Los Angeles, San Francisco, St. Louis, as 6 well as Europe, the Caribbean, and Africa; are you 7 aware of that? 8 A. I refuse to answer. 9 MR. PIKE: Form. 10 Q. It's also alleged that. Jeffrey Epstein in 11 addition to molesting Jane Doe 102 along with Ghislaine 12 Maxwell forced her to have sex with other models, 13 actresses, and celebrities? 14 A. I refuse to answer. 15 MR. PIKE: Form. 16 Q. It also indicates that Jeffrey Epstein 17 transported other minor girls from Turkey, the Czech 18 Republic, Asia, and other countries. Are you aware of 19 that? 20 MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. Is Jeffrey Epstein involved in the 23 international child sex trade? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0035 1 Q. Is Jean Luc Brunel his partner in that 2 international child sex trade? 3 MR. PIKE: Form. 4 A. I refuse to answer. 5 Q. Are you aware that after -- that Jeffrey 3524-006 Page 17 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009264 EFTA00159266 6 Epstein forced Jane Doe 102 to have sex with ocher 7 adult male peers including royalty, politicians, 8 academicians, businessmen and/or other professional and 9 personal acquaintances of Jeffrey Epstein's? IC MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. Is that something that he did with girls other 13 than Jane Doe 102? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. Aren't you familiar with Jeffrey Epstein's 17 practice of pimping out, underage minor females to other 18 people that have the same sexual obsession with 19 underage minors? 20 MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. And doesn't he benefit financially from that 23 sex trade? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0036 1 Q. Jane Doe 102 ultimately escaped from him and 2 left to Australia, is that your understanding? 3 A. I refuse to answer. 4 MR. PIKE: Form. 5 Q. Have you ever spoken with Jane Doe 102? 6 A. I refuse to answer. 7 Q. On one of Epstein's birthdays a friend of 8 Jeffrey Epstein sent Co him. 12 -- three 12-year-old 9 girls from France who spoke no English for Epstein to 10 sexually exploit and abuse and after doing so he sent 11 them back Lo France the next day. Are you familiar 12 with that? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. Isn't that something that is fairly common for 16 Mr. Epstein? 17 A. I refuse to answer. 18 MR. PIKE: Form. 19 Q. Who are Lhe friends that send to Jeffrey 20 Epstein underage minor females for his birthday so that. 21 he can abuse? 22 A. I refuse to answer. 23 MR. PIKE: Form. 24 Q. Is one of those friends Jean Luc Brunel? 25 A. I refuse to answer. 0037 1 Q. Have you ever Mel Prince Andrew? 2 A. I refuse to answer. 3 Q. Has Prince Andrew been involved with underage 4 minor females to your knowledge? 5 A. I refuse to answer. 6 Q. Have you ever met Alan Dershowitz? 7 A. I refuse to answer. 3524-006 Page 18of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009265 EFTA00159267 8 Q. When Alan Dershowitz stays al Jeffrey 9 Epstein's house isn't it true that he has been at the IC house when underage minor females have been in the 11 bedroom with Jeffrey Epstein? 12 A. I refuse to answer. 13 Q. Has -- are you familiar with the media 14 publication or online resource RadarOnline? 15 A. I refuse to answer. 16 Q. Is that. something that. you assisted 17 Mr. Epstein with when he purchased RadarOnline? 18 A. I refuse to answer. 19 Q. And do you know his business partner in that. 2C endeavor? 21 A. I refuse to answer. 22 Q. Isn't it also true that he used RadarOnline as 23 another way to gain access to underage minor females 24 for sex? 25 MR. PIKE: Form. 0038 1 A. I refuse to answer. 2 Q. Have you been to all of Jeffrey Epslein's 3 properties? 4 MR. PIKE: Form. 5 A. I refuse to answer. 6 Q. Certainly you've been to the properly at 358 7 El Brillo Way, correct? 8 MR. PIKE: Form. 9 A. I refuse to answer. 10 Q. Have you been to his property in Manhattan? 11 A. I refuse to answer. 12 MR. PIKE: Form. 13 Q. And have you been to his island in -- it was 14 Little St. James, I believe he calls it Little 15 St. Jeff's now? 16 MR. PIKE: Form. 17 A. I refuse to answer. 18 Q. And have you witnessed underage child sex 19 orgies on that island? 2C MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. Do you know a female named 23 A. I refuse to answer. 24 Q. Do you know where lives these days? 25 A. I refuse to answer. 0039 1 Q. What is your understanding of 2 role in Jeffrey Epslein's life? 3 A. I refuse to answer. 4 MR. PIKE: Form. 5 Q. Isn't it true that she gets paid just to bring 6 him underage minor females for sex? 7 MR. PIKE: Form. 8 A. I refuse to answer. 9 Q. And additionally, she schedules the 3524-006 Page 19 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009266 EFTA00159268 10 appointments for underage minor females for him to 11 molest? 12 A. I refuse Lo answer. 13 MR. PIKE: Form. 14 Q. You know 15 A. I refuse o answer. 16 Q. Does she still work for Ghislaine Maxwell? 17 A. I refuse to answer. 18 Q. Was she an underage minor child victim of 19 Jeffrey Epstein's? 20 A. I refuse to answer. 21 Q. Through discovery we've talked to numerous 22 witnesses about, you know, Jeffrey Epstein and people 23 that work for him. I don't know if you'll be able to 24 answer any of these questions but. I'll ask them anyway 25 one at a time. 0040 1 Is somebody who travels with 2 Jeffrey Epstein? 3 MR. PIKE: Form. 4 A. I refuse to answer. 5 Q. And when Jeffrey Epstein is coming Lo town 6 doesn't he call his number one assistant? 7 MR. PIKE: Form. 8 A. I refuse to answer. 9 Q. And at some point in Lime, it looks like in 10 early 2005 or lace 2004, you were also an assistant of 11 Jeffrey Epstein's, correct? 12 V. PIKE: Form. 13 A. I refuse to answer. 14 Q. And how was it that you transitioned from 15 being involved in modeling to being an employee of 16 Jeffrey Epstein? 17 MR. PIKE: Form. 18 A. I refuse to answer. 19 Q. Other than arranging for underage minor 20 females to come to Jeffrey Epstein's house did you do 21 anything else for Jeffrey Epstein? 22 MR. PIKE: Form. 23 A. I refuse to answer. 24 Q. Did you ever fly on Jeffrey Epstein's 25 airplane? 0041 1 A. I refuse to answer. 2 Q. Did you witness Jeffrey Epstein abuse -- 3 sexually abusing underage minor females on his 4 airplane? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. Did you know that it was illegal for Jeffrey 8 Epstein to interact sexually with underage minor 9 females? IC MR. PIKE: Form. 11 A. I refuse to answer. 3524-006 Page20of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009267 EFTA00159269 12 Q. Did you ever object to Jeffrey Epstein 13 interacting sexually with underage minor females? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. Would Jeffrey Epstein get angry at you if you 1? did not have an appointment set for him with an 18 underage minor female? 19 MR. PIKE: Form. 20 A. I refuse to answer. 21 Q. Has Jeffrey Epstein contacted you in the last 22 year? 23 A. I refuse to answer. 24 MR. PIKE: Form. 25 Q. Has contacted you within the last 0042 1 year? 2 A. I refuse to answer. 3 Q. Has anybody that is associated with Jeffrey 4 Epstein's party contacted you in the last year? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. By that I mean to include Ghislaine Maxwell, 8 Lesley Groff, any of these people, have they contacted 9 you within the last year? 1C MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. Are you familiar with the names of some of the 13 underage minor females? 14 A. I refuse to answer. 15 Q. Are you familiar with LM? 16 A. I refuse to answer. 17 Q. Do you remember what LM looked like? 18 A. I refuse to answer. 19 Q. Are you familiar with EW? 20 A. I refuse to answer. 21 Q. Do you remember what EW looked like? 22 A. I refuse to answer. 23 Q. Are you familiar with Jane Doe? 24 A. I refuse to answer. 25 Q. These are all females that were underage minor 0043 1 females that Jeffrey Epstein interacted with sexually 2 during a time when you were working for him; isn't that 3 true? 4 A. I refuse to answer. 5 MR. PIKE: Form. 6 Q. And LM was somebody that went over to Jeffrey 7 Epstein's house and was molested at a young age by him. 8 more than ICC times; is that true? 9 MR. PIKE: Form. IC A. I refuse to answer. 11 Q. And EW was also somebody who went over to 12 Jeffrey Epstein's house when she was between 14 and 13 16 years old more than a hundred times; isn't that 3524-006 Page2lof68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009268 EFTA00159270 14 true? 15 MR. PIKE: Form. 16 A. I refuse to answer. 17 Q. And Jane Doe was somebody that went to Jeffrey 18 Epstein's house more than 15 times to be molested by 19 Jeffrey Epstein when she was 14 and 15 years old; is 20 that. true? 21 MR. PIKE: Form. 22 A. I refuse t0 answer. 23 Q. Is it also true that LM brought to Jeffrey 24 Epstein's house between 50 and 75 other underage minor 25 females for Jeffrey Epstein to molest? 0044 1 A. I refuse to answer. 2 MR. ROSS: Form. 3 Q. Are you aware of Jeffrey Epstein's for lack of 4 a better word "ritual" with these underage minor 5 females in his bedroom.? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. Wouldn't it generally begin with Jeffrey 9 Epstein placing a call to or yourself and 10 telling you that he's going to oe in town at the Palm 11 Beach mansion? 12 MR. PIKE: Form. 13 A. I refuse to answer. 14 Q. And then isn't there a list_ of underage minor 15 females stored in the computer system? 16 MR. PIKE: Form. 17 A. I refuse to answer. 18 Q. And that computer system is interconnected 19 from his New York home, his New Mexico home, his 20 island, his home in France, and West Palm Beach; is 21 that. correct? 22 MR. PIKE: Form. 23 A. I refuse to answer. 24 Q. And have you seen that list of underage minor 25 females stored in the computer system? 0045 1 MR. PIKE: Form. 2 A. I refuse to answer. 3 Q. And isn't it true there are over a thousand 4 girls at any given time between the age range of 12 and 5 17 all of which have been molested by Jeffrey Epstein? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. And when Mr. Epstein would call and tell you 9 the time that he was going to be in town it would then IC be your job to get an underage minor female to his 11 house and set. a specific appointment for that person; 12 is that correct? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. And he would tell you the exact time of day 3524-006 Page 22 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009269 EFTA00159271 16 that he wanted his two or three appointments to molest 17 underage minor females? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. And you would go into the computer system and 21 call the person that he told you he wanted Lo see for 22 that. day; is that correct? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. And that may be 0046 1 or somebody local Lhat you would call on the telephone 2 and tell them to come work at a specific time? 3 MR. PIKE: Form. 4 A. I refuse to answer. 5 Q. And didn't Mr. Epstein tell you that the way 6 you need to tell these girls is that Lhey are working 7 so that they do not feel that they have the option to 8 decline? 9 MR. PIKE: Form. 10 A. I refuse to answer. 11 Q. I mean, the psychology of it all was explained 12 in detail by Jeffrey Epstein; isn't that correct? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. And once the girls were inside the bedroom 16 Jeffrey Epstein said that he can take care of the rest, 17 correct? 18 Y. PIKE: Form. 19 A. I refuse to answer. 20 Q. And the underage minor female would show up at 21 the house and be greeted at the door by either 22 yourself, the house manager, or correct? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. Many of these underage minor females including 0047 1 my three clients, LM, EW, and Jane Doe you met 2 personally, right? 3 A. I refuse to answer. 4 MR. PIKE: Form. Q. And then you would lead them upstairs to his 6 bedroom. and leave him alone in the bedroom, leave my 7 client alone in the bedroom? 8 MR. PIKE: Form. 9 A. I refuse to answer. 10 Q. And let's take LM, and she went there many 11 times between the ages of 13 and 16. If she was Laken 12 up to his bedroom she would be left alone in the 13 bedroom until Jeffrey Epstein arrived, correct? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. And Jeffrey Epstein would appear usually naked 17 and order for her to take her clothes off? 3524-006 Page23of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009270 EFTA00159272 18 A. I refuse to answer. 19 MR. PIKE: Form. 20 Q. And Chen Mr. Epstein would lay face down on 21 the massage table would usually be the next step, 22 correct? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. And you know this ritual because at some point. 0048 1 in Lime Jeffrey Epstein showed you exactly what he does 2 with each of these girls in the bedroom, correct? 3 MR. PIKE: Form. 4 A. I refuse Lo answer. 5 Q. So after about -- he would order the underage 6 minor female to begin massaging him, correct? 7 MR. PIKE: Form. 8 A. I refuse to answer. 9 Q. And then he would roll over and begin to lO masturbate with his right hand, correct? 11 A. I refuse to answer. 12 Q. And then he would begin also grabbing the 13 breasts, buttocks, and vagina area of these underage 14 minor females, correct? 15 A. I refuse to answer. 16 MR. PIKE: Form. 17 Q. And his ritual was so specific that. with each 18 of them he would demand that they pinch his nipples 19 very hard, right? 20 MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. That's a fetish that you know that. Jeffrey 23 Epstein has, right, he likes his nipples pinched very 24 hard? 25 MR. PIKE: Form. 0049 1 A. I refuse to answer. 2 Q. And as he's masturbating with one hand and has 3 his other hand groping or inserting his fingers into 4 the underage minor's vagina he's also telling them to 5 pinch his nipples, correct? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. And this continues -- and sometimes this 9 escalates to him using vibrators, correct? 1C MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. And have you seen vibrators in the Palm Beach 13 mansion house? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. And other times he orders to 17 participate in these encounters with underage minor 18 females; is that correct? 19 A. I refuse to answer. 3524-006 Page24of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009271 EFTA00159273 20 Q. Are you familiar with 21 strapping on dildos to have sex with these underage 22 minor females? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. And when would have sex with 0050 1 the underage minor females Jeffrey Epstein would watch 2 and continue to ejac -- continue to masturbate, 3 correct? 4 MR. PIKE: Form. 5 A. I refuse to answer. 6 Q. Has he ever asked you to participate in these 7 threesomes with underage minor females? 8 A. I refuse to answer. 9 MR. PIKE: Form. 10 Q. Have you ever participated in sex with 11 underage minor females al the direction of Jeffrey 12 Epstein? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. The -- this whole experience that I am. 16 explaining right now is identical every single time 17 with these underage minor females; isn't that your 18 understanding? 19 MR. PIKE: Form. 2C A. I refuse to answer. 21 Q. And this whole experience is what he has 22 taught you and the other employees to call a •massage", 23 correct? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0051 1 Q. And it always ends with him ejaculating? 2 A. I refuse to answer. 3 MR. PIKE: Form. 4 Q. And then he offers 200 to $300 cash to the 5 underage minor female, correct? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. And then he also gives them another another 9 option to make money which is each Lime you come to my 10 house and we engage In this sexual interaction I will 11 give you $200, but each female you bring me like you, 12 between the age range of 12 and 16, I will pay you $200 13 per person. 14 MR. PIKE: Form. 15 Q. Is that_ something you're familiar with? 16 A. I refuse to answer. 17 Q. And LK al that offer was one of the girls who 18 brought him 75 plus underage minor females, correct? 19 MR. PIKE: Form. 2C A. I refuse to answer. 21 Q. And so he's basically created a pyramid of 3524-006 Page 25 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009272 EFTA00159274 22 underage minor females where the computer system has a 23 thousand of these females ready to come over to work 24 for him? 25 MR. PIKE: Form. 0052 1 A. I refuse to answer. 2 Q. Jo you know what Jeffrey Epstein does for a 3 living? 4 A. I refuse to answer. 5 Q. Does he do anything aside from interacting 6 sexually with underage minor females? 7 MR. PIKE: Form. 8 A. I refuse to answer. 9 Q. Do you know how it is that he made his money 10 where he is purported to be a billionaire? 11 A. I refuse to answer. 12 MR. PIKE: Form. 13 Q. Jo you know David Copperfield? 14 A. I refuse to answer. 15 Q. Is David Copperfield somebody that would come 16 into town and interact sexually with underage minor 17 females? 18 A. I refuse to answer. 19 Q. Do you know Martin Nowak? 20 A. I refuse to answer. 21 Q. Is that also somebody that would interact 22 sexually with underage minor females? 23 A. I refuse to answer. 24 Q. Do you know Leslie Wexner? 25 A. I refuse to answer. 0053 1 Q. Is that somebody you've met before? 2 A. I refuse to answer. 3 Q. Has Mr. Epstein himself interacted sexually 4 with Leslie Wexner? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. When Mr. Epstein was being investigated 8 criminally how did you first learn about that? 9 A. I refuse to answer. 10 Q. AL some point in time he was tipped off that 11 his home -- that a search warrant was going to be 12 executed on his home, correct? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. And just a month before the execution of that 16 search warrant -- less than a month before the 17 execution of that search warrant he ordered you to do 18 something with certain evidence, didn't he? 19 MR. PIKE: Form. 20 A. I refuse to answer. 21 Q. In fact, there were aL least three very key 22 computers Lhat contained a lot of the information that 23 I've been asking you about. You're familiar with those 3524-006 Page26of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009273 EFTA00159275 24 computers that were in his house, correct? 25 MR. PIKE: Form. CC54 1 A. I refuse to answer. 2 Q. And he ordered you to come over and take those 3 computers out of his house, correct? 4 A. I refuse to answer. 5 MR. PIKE: Form. 6 Q. And you could basically take the local 7 database that exposed this criminal enterprise that. 8 I've been talking about dealing with sex with underage 9 minor vehicles -- underage minor females and you could 10 Lake the evidence from his home, correct? 11 MR. PIKE: Form. 12 A. I refuse to answer. 13 Q. And you've seen Lhe material that's on those 14 computers, correct? 15 MR. PIKE: Form. 16 A. I refuse to answer. 17 Q. And if I were to look at those computers it 18 would display exactly what I've been describing Co you 19 today, right? 2C MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. And you went to his house with a wale, 23 correct? 24 A. I refuse to answer. 25 M.R. PIKE: Form. 0055 1 Q. There was one other guy with you that helped 2 that assisted you to take these computers from his 3 home; is that right? 4 MR. PIKE: Form. 5 A. I refuse to answer. 6 Q. Where did you take those? 7 A. I refuse to answer. 8 Q. Did you take those -- was it Bill Reilly that 9 went to the home? IC A. I refuse to answer. 11 Q. Do you know who Bill Reilly is? 12 A. I refuse to answer. 13 Q. He's one of the investigators hired by Roy 14 Black to represent Jeffrey Epstein? 15 A. I refuse to answer. 16 Q. Did you Lake those computers ever to your 17 house? 18 A. I refuse to answer. 19 Q. And I guess the house that. I would be talking 20 about is the , have those 21 computers ever been to that house? 22 MR. PIKE: Form. 23 A. I refuse Lo answer. 24 Q. Were you nervous about the fact that you were 25 taking these computers out of the home at a Lime when a 3524-006 Page 27 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009274 EFTA00159276 0056 1 search warrant was imminent? 2 A. I refuse to answer. 3 Q. Did you ever question when you were directed 4 to lake these computers from his home? 5 A. I refuse to answer. 6 Q. Bow much additional money or bonus were you 7 paid to take the computers that we're talking about out 8 of Jeffrey Epstein's house? 9 MR. PIKE: Form. 1C A. I refuse to answer. 11 Q. Would those computers reveal criminal activity 12 of only Jeffrey Epstein or of others? 13 N.R. PIKE: Form. 14 A. I refuse to answer. 15 Q. Did you talk with about the 16 criminal investigation into Jeffrey Epstein and others? 17 A. I refuse to answer. 18 Q. Well, at some point in Lime what's been marked 19 as Defense Exhibit 1, you received a Grand Jury 20 investigation target letter, correct? 21 A. I refuse to answer. 22 Q. Well, we have it right. here. I'm familiar 23 with it. I know you got the letter and I know that, 24 you know, the substance of it you're not going to tell 25 me about. But this letter is dated August 31st, 2007, 0057 1 the search warrant was executed on his home back in 2 October of 2005. So during those two years leading up 3 to this target letter who did you talk to? 4 A. I refuse to answer. 5 Q. Did you -- 6 MR. ROSS: And privilege. Attorney-client 7 privilege. 8 Q. Okay. In addition to your attorney did you 9 talk to anybody else about the criminal investigation? 10 A. I refuse to answer. 11 Q. And was your initial computer -- 12 computer -- was your initial attorney in this case, 13 correct? 14 MR. ROSS: You can answer yes or no. 15 A. Yes. 16 Q. Okay. And that_ was an attorney that was hired 17 for you by Jeffrey Epstein? 18 MR. ROSS: Invoke. 19 A. I refuse to answer. 20 Q. Someone that was paid for by Jeffrey Epstein 21 Lo represent you? 22 n. PIKE: Form. 23 A. I refuse to answer. 24 Q. So once he hired you a criminal attorney then 25 it seemed like you did something wrong? 0058 1 KR. PIKE: Form. 3524-006 Page28of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009275 EFTA00159277 2 A. I refuse to answer. 3 Q. You hadn't actually gone into any relationship 4 with Jeffrey Epstein with the intent Lo commit crimes, 5 did you? 6 A. I refuse to answer. 7 Q. You didn't know that he was a child molester 8 when you first met him, did you? 9 MR. PIKE: Form. 10 A. I refuse to answer. 11 Q. Were you impressed by his money and his 12 lifestyle? 13 A. I refuse to answer. 14 Q. Did you think that he could get you further in 15 life if you would just listen to what he said? 16 MR. PIKE: Form. 17 A. I refuse to answer. 18 Q. AL this point in time you have no contact with 19 him as a child molester, do you? 20 M.R. PIKE: Form. 21 A. I refuse to answer. 22 Q. Did Jeffrey Epstein assist in getting you a 23 visa? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0059 1 Q. Has he done any favors for your family? 2 A. I refuse to answer. 3 MR. PIKE: Form. 4 Q. Is he paying for your college? 5 A. I refuse to answer. 6 MR. PIKE: Form. 7 Q. Right now is he paying for your college? 8 MR. ROSS: Invoke. 9 A. I refuse to answer. 10 MR. PIKE: Form. 11 Q. Did Jeffrey Epstein ever talk to you about the 12 chances of him going to prison? 13 A. I refuse to answer. 14 MR. PIKE: Form. 15 Q. Did Jeffrey Epstein ever talk to you about 16 what he intended his defenses Lo be to the criminal 17 actions he committed against these underage minors? 18 A. I refuse to answer. 19 MR. PIKE: Form. 20 Q. Did he tell you that he would spend as much 21 money as possible to intimidate and harass these 22 underage minor victims? 23 A. I refuse to answer. 24 MR. PIKE: Form. 25 Q. Did he tell you that he would destroy their 0060 1 credibility? 2 A. I refuse to answer. 3 Q. Did he tell you that. he could scare them to go 3524-006 Page29of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009276 EFTA00159278 4 away? 5 A. 1 refuse to answer. 6 MR. PIKE: Form and form to the last question. 7 MR. EDWARDS: All right. Let's see, what did 8 I say, I said this was -- 9 MR. ROSS: 1. IC MR. EDWARDS: -- Plaintiff's 1 and we're going 11 to write on the back of it and then -- okay. 12 Q. Jeffrey Epstein kept message pads near all of 13 his phones in his home, right? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 O. And those are message pads that have a carbon 17 copy back side to them, you're familiar with them? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. And this is for anybody who lakes a message 21 they write it down that somebody called, the reason for 22 calling, the time that they called? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. And many a times anytime that Jeffrey Epstein 0061 1 was in town there were at least two scheduled 2 "massages" for lack of a better word, with Jeffrey 3 Epstein and these underage minor females, correct? 4 A. I refuse to answer. 5 MR. PIKE: Form. 6 Q. And do you have the -- and there was a 7 particular scheduling book that contained these 8 appointments with -- between Jeffrey Epstein and 9 underage minor females, correct? 10 MR. PIKE: Form. 11 A. I refuse to answer. 12 O. And it was your primary responsibility Co 13 assist in setting these appointments up, 14 right? 15 A. I refuse to answer. 16 MR. PIKE: Form. 17 Q. IL Look at least two or three full-Lime 18 employees to keep up with Jeffrey EpsLein's addiction 19 to underage minors, correct? 20 A. I refuse to answer. 21 MR. PIKE: Form. 22 Q. Lesley Groff did pretty much the same thing up 23 in New York, right? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0062 1 Q. And you're familiar that there is this group 2 of girls in New York that were summoned to his home for 3 generally the exact same thing as the Palm Beach girls? 4 A. I refuse to answer. 5 Q. All right. 3524-006 Page 30 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009277 EFTA00159279 6 MR. PIKE: Form. 7 Q. I'm going to show you an exhibit here, we'll 8 mark it as -- you know what, it's a bunch of message 9 pads, I'm going to mark it as 2A, -B, -C, -D, whatever. IC So we'll say 2A. 11 (Whereupon, Plaintiff's Exhibit 2A through 2H 12 were marked for identification.) 13 Q. DO you recognize it? 14 A. I refuse to answer. 15 Q. Okay. 16 MR. PIKE: May I see that? 17 MR. EDWARDS: Sure. 18 Q. Do you recognize the handwriting on it? 19 A. I refuse to answer. 20 Q. IL indicates hasn't confirmed 21 for 11 yet, so she is keeping on hold in case 22 doesn't call back." 23 What does that message mean? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0063 1 Q. an underage minor female that Jeffrey 2 Epstein was going to molest at 11:00, correct? 3 MR. PIKE: Form. 4 A. I refuse to answer. 5 Q. And if wasn't available then ou had 6 another underage minor female named that could 7 step in her place and fulfill that role for Jeffrey 8 Epstein, correct? 9 MR. PIKE: Form. 10 A. I refuse to answer. 11 Q. All right. 2B is another message pad and I'm 12 going to -- we'll stop skipping the process of moving 13 this on and I'm assuming you're not going to be able to 14 answer as to whether or not you -- you recognize that 15 either, right? 16 A. I refuse to answer. 17 Q. Okay. This is a message from 9/4/05, so 18 September 4th 2005, 7:25 p.m. saying "- 19 cancelled She would like to speak Lo you I 20 believe about college," and a telephone number. And 21 then a question from. you, "Should I schedule anyone 22 else?' what did that message mean? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. That another typical ploy of Kr. Epstein's, 0064 that. he would promise these girls something in order to 2 get them to allow him to sexually abuse them? 3 MR. PIKE: Form. 4 A. I refuse to answer. 5 Q. Because he certainly did not want them. to tell 6 the police, correct? 7 A. I refuse to answer. 3524-006 Page 31 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009278 EFTA00159280 8 Q. And did you have many meetings about what to 9 do if any of these girls told the police? IC A. I refuse Lo answer. 11 MR. PIKE: Form. 12 Q. Was it always known that Jeffrey Epstein would 13 hire everyone attorneys and tell everyone just not to 14 talk? 15 MR. PIKE: Form. 16 A. I refuse to answer. 17 Q. And at the same time then he could employ a 18 bunch of investigators, dig up a bunch of dirt on these 19 girls, and intimidate them and scare them to go away, 2C correct? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. And Jeffrey Epstein doesn't like -- he didn't 24 like any of these underage minor females, right? 25 MR. PIKE: Form. 0065 1 A. I refuse to answer. 2 Q. In fact, it was the opposite, he liked Co hurt 3 them; isn't that. true? 4 MR. PIKE: Form. 5 A. I refuse to answer. 6 Q. And after they came forward if they told the 7 truth he was dead set on hurting them even more, 8 correct? 9 MR. PIKE: Form. 10 A. I refuse to answer. 11 Q. And that's also a feeling that. Ghislaine 12 Maxwell shared as well, correct? 13 A. I refuse to answer. 14 Q. And that's something that she also told you, 15 •Don't worry. If we get caught we have it covered and 16 we'll just attack these little girls.• 17 MR. PIKE: Form. 18 A. I refuse to answer. 19 Q. All right. There's another message from 2C 9/1C/C5. says confirmed for 4 p.m-" 21 Can you tell us what that. message means? 22 MR. PIKE: Form. 23 A. I refuse to answer. 24 Q. IL's another underage minor female that 25 Jeffrey Epstein's going to molest. at 4 p.m., correct? 0066 1 A. I refuse to answer. 2 Q. And when I say "molest.", you know, he may say 3 "massage", I mean, that's -- that's something 4 interchangeable, right? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. IL's the routine that I described in detail 8 that is identical with every single girl every single 9 time, correct? 3524-006 Page 32 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009279 EFTA00159281 le A. I refuse to answer. 11 Q. And it's basically as far as he can get with 12 this underage minor female without her crying or 13 screaming or running out of the house? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. Did you ever see any of the girls cry or 17 scream or run out of the house? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. Did you have a personal relationship with any 21 of Lhese underage minor females? 22 A. I refuse to answer. 23 Q. There's another message here from 9/10/05, 24 same day later in the day, IC p.m. saying will 25 be at 11. Do you want me to cancel • 0067 1 Do you know what that message means? 2 MR. PIKE: Form. 3 A. I refuse to answer. 4 Q. What. is this? 5 There's another message from 9/11/05 saying "I 6 got a car for," and then the name is blotted out. The 7 State Attorney's Office blotted the names of minors out 8 sometimes in their file. So do you -- do you know -- 9 can you fill in that blank? 10 A. I refuse to answer. 11 Q. Do you know if this was the car that he rented 12 for Jane Doe 4? 13 A. I refuse to answer. 14 Q. All right. Or the car that he rented for AK? 15 A. I refuse to answer. 16 MR. PIKE: Form. 17 Q. You're familiar with both of those people, 18 right? 19 A. I refuse to answer. 20 Q. In fact, Ai was somebody that. was over at 21 Jeffrey Epstein's house many times, correct? 22 A. I refuse to answer. 23 MR. PIKE: Form. 24 Q. 9/3/2005. Message from saying "I left. 25 message for to confirm for 11 a.m. and 0068 1 for 4:30 p.m." 2 Do you remember leaving that message? 3 A. I refuse to answer. 4 Q. And this is -- 5 MR. PIKE: Form. 6 Q. It's his typical schedule where he schedules 7 one underage minor female to molest in the morning and 8 one in the afternoon, correct? 9 MR. PIKE: Form. IC A. I refuse to answer. 11 Q. I mean, considering this is -- have you ever 3524-006 Page33of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009280 EFTA00159282 12 worked anywhere else where there is somebody sexually 13 molesting underage minor females on a daily basis like 14 this? 15 MR. PIKE: Form. 16 A. I refuse to answer. 17 Q. At sore point in time did you tell your 18 parents that this was happening? 19 MR. PIKE: Form. 20 A. I refuse to answer. 21 Q. Did you ever talk to anybody else in the house 22 and say "Hey, look, this is not right•? 23 A. I refuse to answer. 24 Q. Do you feel sorry for these girls? 25 A. I refuse to answer. 0069 1 Q. And you say you do or you do not remember AH? 2 A. I refuse to answer. 3 Q. Okay. And do you know what happened up in Lhe 4 bedroom between AH as a minor and Jeffrey Epstein? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. well, this is what she tells police: "She 8 arrived at the house, went upstairs to the bedroom.. 9 She advised she immediately removed her clothing and 10 and Epstein were alread naked in the 11 be room. AH explained that and she 12 had a sexual encounter that included kissing, touching, 13 and oral sex. AH remembered that she climaxed and was 14 removing herself from the massage table. Epstein then 15 turned AH onto her stomach on Lhe massage table and 16 inserted his penis into her vagina. AH stated Epstein 17 began to pump his penis in her vagina. AH became upset 18 over this. She said her head was being held forcibly 19 against the bed as he continued to pump inside her. 20 She screamed 'No,' and Epstein stopped. He would 21 normally pay her $200, but for this he apologized and 22 paid her a thousand dollars for that visit." 23 Are you familiar with that encounter? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0070 1 Q. Do you remember a time when AH as a 2 16-year-old I believe at this time left her house -- 3 left the house visibly upset? 4 MR. PIKE: Form. 5 A. I refuse to answer. 6 7 8 9 MR. PIKE: Form. IC A. I refuse to answer. 11 Q. These message pads were message pads that were 12 taken from trash pulls outside of Jeffrey Epstein's 13 home and for the most_ -- well, there's so many messages 3524-006 Page 34 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009281 EFTA00159283 14 here, but most. of them are by somebody other than 15 yourself. So my question is who are the other people 16 that would take messages for Jeffrey Epstein for 17 underage minor females to come to the house? 18 MR. PIKE: Form. 19 A. I refuse to answer. 2C Q. And the messages include CL, 'Can I come work 21 today?" 22 what. does "work" mean? 23 A. I refuse to answer. 24 M.R. PIKE: Form. 25 Q. That means come to your house and get paid for C071 1 Jeffrey Epstein sexually molesting this person while 2 she was underage; is that correct? 3 A. I refuse to answer. 4 MR. PIKE: Form. 5 Q. And it was also pretty frequent that the girls 6 would come in tandem, isn't that true, two at a time? 7 MR. PIKE: Form. 8 A. I refuse to answer. 9 Q. And one being the girl that would bring the IC new girl there, would wait downstairs while the new 11 girl was upstairs getting molested but then getting 12 paid? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. How did Jeffrey Epstein explain himself to you 16 as to why he did this? 17 MR. PIKE: Form. 18 A. I refuse to answer. 19 Q. Do you know when it is that he first. became 20 sexually obsessed with underage minor females? 21 MR. PIKE: Asked and answered. 22 A. I refuse to answer. 23 MR. PIKE: Form. 24 Q. Did you know that he was a school teacher at 25 the Dalton School? 0072 1 A. I refuse to answer. 2 Q. And at that point in lime -- well, are you 3 aware of him molesting underage minors while he was a 4 teacher there? 5 A. I refuse to answer. 6 Q. There's another note that's not a message pad 7 which I guess I will -- since it has your name on it I 8 will mark it as what are we on -- 3 -- wail, C -- 9 MR. ROSS: 3. IC MR. EDWARDS: I messed up. 11 MR. ROSS: 3. 12 (Whereupon, Plaintiff's Exhibit 3 was marked 13 for identification.) 14 Q. Look at that while I fix what. I've messed up 15 over here. 3524-006 Page 35 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009282 EFTA00159284 16 MR. ROSS: I'm going to show this to the 17 witness. 18 MR. EDWARDS: Yes. Yes. 19 Q. Do you recognize that document? 20 A. I refuse to answer. 21 Q. There are a lot of different things on here 22 that don't necessarily relate to you. At least I can't 23 tell that they do. But it does indicate 24 parents are going to the embassy on the 23rd.• 25 Do you remember when that happened? 0073 1 A. I refuse to answer. 2 Q. Why did your parents go to the embassy? 3 A. I refuse to answer. 4 Q. More importantly why was Mr. Epstein concerned 5 that your parents were going to the Embassy? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. Was -- at that point in time was Mr. Epstein 9 assisting your parents with anything? 10 A. I refuse to answer. 11 Q. Are your parents citizens of the United 12 States? 13 MR. ROSS: Form. 14 A. I refuse to answer. 15 Q. Are you? 16 A. No. 17 Q. Has Mr. Epstein ever offered to get you a visa 18 for the United States? 19 A. I refuse to answer. 20 MR. PIKE: Form. 21 Q. Do you know Raer Roshan? 22 A. I refuse to answer. 23 Q. That was Jeffrey Epstein's partner in 24 RadarOnline, correct? 25 A. I refuse to answer. 0074 1 Q. And if I showed you every single message pad 2 here would you be able Lo answer any of the questions 3 about any of the messages that were left at Jeffrey 4 EpsLein's house? 5 A. I refuse to answer. 6 MR. EDWARDS: Okay. That saves us a lot of 7 Lire. 8 MR. ROSS: It did. 9 Q. Have you ever met Bill Clinton? 10 A. I refuse to answer. 11 Q. Is Bill Clinton -- was Bill Clinton a friend 12 of Jeffrey Epstein's? 13 A. I refuse to answer. 14 Q. Is Bill Clinton somebody who Jeffrey Epstein 15 has ever procured underage minor females for? 16 A. I refuse to answer. 17 MR. PIKE: Form. 3524-006 Page 36 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009283 EFTA00159285 18 Q. And just -- and just for, you know, the sake 19 of what the evidence shows, there's no evidence that I 20 have that indicates that that happened, but. if you were 21 going to answer that. question I'm willing to ask it. 22 Have you met him at Jeffrey Epstein's house in 23 Palm Beach County? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0075 1 Q. You have flown on Jeffrey Epstein's airplanes 2 numerous times, correct? 3 A. I refuse to answer. 4 Q. As well has Bill Clinton and you're aware of 5 that., right? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. Have you ever seen the flight logs from 9 Jeffrey Epstein's airplanes? 10 MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. And on many times it is Bill Clinton, Secret 13 Service agents, Jeffrey Epstein, Ghislaine Maxwell, 14 and others. Have you -- do you know 15 about those flights? 16 A. I refuse to answer. 17 MR. PIKE: Form. 18 Q. And have you ever witnessed sex on any of 19 Jeffrey Epstein's flights? 20 A. I refuse to answer. 21 MR. PIKE: Form. 22 Q. Jo you know 23 A. I refuse to answer. 24 Q. Is that somebody that is Ghislaine Maxwell's 25 sex slave? 0076 1 A. I refuse to answer. 2 Q. And isn't it typical for Jeffrey Epstein to 3 have a sex slave that flies with him on the airplane? 4 A. I refuse to answer. 5 MR. PIKE: Form. 6 Q. And one of the qualifications is that the 7 section slave be underage, correct? 8 MR. PIKE: Form. 9 A. I refuse to answer. 10 Q. And if the sex slave is 15 years old isn't it 11 your understanding and based on your observations that 12 he will even make them dress as if they're 11 or 12? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 MR. PIKE: Form. 16 Q. Jo you know President Andres Pastrana? 17 A. I refuse to answer. 18 Q. Jo you know him as somebody who has had sex 19 with underage minor females brought to him by Jeffrey 3524-006 Page 37 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009284 EFTA00159286 20 Epstein? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. Have you ever heard of Ehud Burak? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0077 1 Q. Is that another person that Epstein -- Jeffrey 2 Epstein procures underage minor females for? 3 MR. PIKE: Form. 4 A. I refuse to answer. 5 Q. You've met Naomi Campbell I'm assuming? 6 A. I refuse to answer. 7 Q. Anytime separate and apart from any dealings 8 with Jeffrey Epstein have you met her in the modeling 9 industry? That's a model, right? 10 MR. PIKE: Form. 11 MR. ROSS: You can answer the question. 12 A. No, I have not. 13 Q. Okay. Do you know Todd Meister? 14 A. I refuse to answer. 15 Q. Joel Pashcow? 16 A. I refuse to answer. 17 Q. You've been to their houses? 18 A. I refuse to answer. 19 Q. Do you know Aline Weber? 2C A. I refuse to answer. 21 Q. Have you ever stayed at the 301 East 66th 22 Street places with Aline Weber? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. And typically aren't there al least 16 0078 1 underage minor females staying at those various 2 condominiums located at 301 East 66th Street? 3 A. I refuse to answer. 4 Q. And those females get work visas to say that 5 they're models, but actually they are prostituted out 6 by Jeffrey Epstein and John Luc Brunel, correct? 7 A. I refuse to answer. 8 MR. PIKE: Form. 9 Q. And various businessmen and politicians around 10 New York and Washington, J.C. go to those apartments 11 frequently to have sex with underage minors; is chat 12 true? 13 A. I refuse to answer. 14 Q. Do you remember a flight. on December 3rd, 2004 15 that ou took with Jeffrey Epstein, 16 and somebody with initials SH -- 17 A. I refuse to answer. 18 Q. -- from JFK to FBI? 19 MR. PIKE: Form. 20 Q. Do you remember that? 21 A. I refuse to answer. 3524-006 Page38of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009285 EFTA00159287 22 23 24 25 0079 1 2 3 4 5 6 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0080 1 2 3 4 5 6 7 B 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Q. Who is SH? A. I refuse to answer. Q. Is that an underage minor? A. I refuse to answer. Q. Do you remember a December 27th with Epstein? A. Q. A. Q. A. Q. A. flight that you Look and Jeffrey I refuse to answer. What airport is this, TIST? I refuse to answer. Do you know Doug Band? I refuse to answer. Isn't that Bill Clinton's assistant? I refuse to answer. Q. You've been on the airplane with him before? A. I refuse to answer. Q. Have you been on the airplane with Bill Clinton before? A. I refuse to answer. Q. Who is A. I refuse to answer. Q. That's somebody you've flown with on Jeffrey Epstein's plane on numerous occasions, correct? MR. PIKE: Form. A. I refuse to answer. Q. In fact, during the year 2005 you flew on Jeffrey Epstein's plane would you say more than 50 limes? A. I refuse to answer. MR. PIKE: Form. Q. And you flew to his island, right? A. I refuse to answer. MR. PIKE: Form. Q. You flew to New Mexico? A. I refuse to answer. MR. PIKE: Form. Q. You flew to New Jersey? MR. PIKE: Form. A. I refuse Lo answer. Q. Several of the flights are just yourself, Jeffrey Epstein, and What did you do on those flights? MR. PIKE: Form. A. I refuse to answer. Q. Who's Adam Perrylang? A. I refuse Lo answer. Q. Is that somebody that you were made to have sex with? A. I refuse to answer. Q. Did Jeffrey Epstein ever make you have sex with any females? MR. PIKE: Form. 3524-006 Page 39 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009286 EFTA00159288 24 A. I refuse to answer. 25 Q. Did he ever make you have sex with any of his 0081 1 friends? 2 MR. PIKE: Form. 3 A. I refuse to answer. 4 Q. Who is Sandy Berger? 5 A. I refuse to answer. 6 Q. That's somebody else that was affiliated with 7 Bill Clinton at one point in Lime, correct? 8 A. I refuse to answer. 9 Q. A close friend of Jeffrey Epstein's? lO MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. He called the house within three weeks of the 13 search warrant being executed. Did he tip off Jeffrey 14 Epstein? 15 MR. PIKE: Form. 16 A. I refuse to answer. 17 Q. Is he somebody that's involved with underage 18 minors? 19 A. I refuse to answer. 20 Q. Do you know Igor Zinoviev? 21 A. I refuse to answer. 22 Q. Andrea Metrovich? 23 A. I refuse to answer. 24 Q. Have you flown on the airplane with Alan 25 Dershowitz before? 0082 1 MR. PIKE: Form. 2 A. I refuse to answer. 3 Q. And Jean Luc Brunel is somebody who you have 4 been on the airplane with several Limes, correct? 5 A. I refuse to answer. 6 MR. PIKE: Form. 7 Q. And when Jean Luc Brunel is on this airplane 8 there are underage minor -- minor females on the 9 airplane with you, correct? IC MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. Is there a back room to this airplane? Is 13 there any sort of separation or is it all one big room? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. So if Jeffrey Epstein and Jean Luc Brunel are 17 engaged in sex acts with underage minors did you -- 18 A. I refuse -- 19 Q. Sorry -- did you observe any of those acts? 20 A. I refuse to answer. 21 MR. PIKE: Form. 22 Q. And on numerous of the flights the flight logs 23 indicate someone's name then oftentimes initials, but 24 sometimes it would lust say "three females". Do you 25 know why? 3524-006 Page40of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009287 EFTA00159289 0083 1 A. I refuse to answer. 2 MR. PIKE: Form. 3 Q. Who's 4 A. I refuse to answer. 5 Q. Do you know 6 A. I refuse to answer. 7 Q. They're the house managers up at the mansion 8 up in Manhattan, correct? 9 MR. PIKE: Form. 1C A. I refuse to answer. 11 Q. And they assist Mr. Epstein in engaging in 12 underage sex with minors in New York, correct? 13 MR. PIKE: Form. 14 A. I refuse to answer. 15 Q. They also maintain a pretty close relationship 16 with the police? 17 A. I refuse to answer. 18 Q. And that's a big component also, right, Chat 19 Jeffrey Epstein has -- is friendly with the law 20 enforcement, correct? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. Like law enforcement would do favors for not 24 only Jeffrey Epstein but his various assistants. If 25 you were speeding around the neighborhood they wouldn't 0084 give you a ticket, correct? 2 MR. PIKE: Form. 3 A. I refuse to answer. 4 Q. Was it ever your job to call the police 5 department and ask if any police reports were on file 6 or anybody complained about the activities at Jeffrey 7 Epstein's house? 8 MR. PIKE: Form. 9 A. I refuse to answer. 1C Q. Have you ever gone physically to the police 11 department? 12 A. I refuse to answer. 13 Q. Was there a flight where you flew alone with 14 Jean Luc Brunel? 15 A. I refuse to answer. 16 Q. Have you ever flown on the plane with Prince 17 Andrew? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. Do you know 21 A. I refuse to answer. 22 Q. That's another model that Jeffrey Epstein 23 knows, correct? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0085 1 Q. Somebody that he had engaged in sex with when 3524-006 Page4lof68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009288 EFTA00159290 2 she was underage? 3 A. I refuse to answer. 4 Q. She actually got a modeling contract out of 5 it? 6 MR. PIKE: Form. 7 A. I refuse to answer. 8 Q. Why does Jean Luc Brunel and Jeffrey Epstein 9 fly together so often? 10 MR. PIKE: Form. 11 A. I refuse to answer. 12 Q. And why does Ghislaine Maxwell also fly so 13 often with Jeffrey Epstein and Jean Luc Brunel? 14 A. I refuse to answer. 15 MR. PIKE: Form. 16 Q. Isn't it true that all three of them are 17 obsessed and addicted to sex with underage minors? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 MR. PIKE: Brad, how much longer do you have? 21 MR. EDWARDS: How long? You want to take a 22 break? 23 MR. PIKE: Yeah. 24 MR. EDWARDS: Sure. It's going a lot faster 25 than I thought it would. 0086 1 VIDEOGRAPHER: Off the record, 11:33 a.m. 2 (Recess Laken al 11:33 a.m.) 3 (Deposition resumed al 11:43 a.m..) 4 VIDEOGRAPHER: On the record, 11:43 a.m.. 5 BY MR. EDWARDS: 6 Q. All right. There's one more message that I 7 wanted to ask you about. As I mentioned, I'm not going 8 to go through all of the messages that I have, but 9 there's one from 9/4/2005, 9:08 a.m. from "Is 10 it okay for stop by and drop something?" 11 A. I refuse to answer. 12 MR. PIKE: Form. 13 Q. So what were your hours working for Jeffrey 14 Epstein? 15 A. I refuse to answer. 16 Q. I mean, some of these messages are 9:00 in the 17 morning and others are as late as 8:30 or 9 at night. 18 So what. were your hours? 19 A. I refuse to answer. 20 Another message from 9/4 also, same day, 21 " I think, "confirmed an 11 a.m., is at 22 11104.." 23 MR. KERMELSTEIN: I chink that's one you did. 24 MR. EDWARDS: Oh, yeah? Okay. 25 Q. All right.. Do you remember that message? 0087 1 A. I refuse to answer. 2 MR. EDWARDS: Do you care how I attach it 3 since it's -- 3524-006 Page 42 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009289 EFTA00159291 4 MR. ROSS: No. 5 MR. EDWARDS: I'll attach it as whatever it 6 is. 7 MR. ROSS: 4. 8 MR. EDWARDS: 2 -- well, I'll just go 2H since 9 it's a message. You don't have a problem with IC that? 2H? 11 MR. ROSS: whatever. 12 (Whereupon, Plaintiff's Exhibit 2H was marked 13 for identification.) 14 Q. Do you still consider Jeffrey Epstein a 15 friend? 16 A. I refuse to answer. 17 MR. PIKE: Form. 18 Q. Did you ever think of Jeffrey Epstein as a 19 friend? 20 MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. Other than the people that I've mentioned 23 of -- you know, President Pastrana and Ehud Burak and 24 Prince Andrew did you meet any other people of royalty 25 being friends with Jeffrey Epstein? 0088 1 MR. PIKE: Form. 2 A. I refuse to answer. 3 Q. Can you Lell us any of the other folks that 4 Jeffrey Epstein would supply underage minor girls to? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. Do you know a man by the name of Glenn Dubin? 8 A. I refuse Lo answer. 9 Q. Do you know his wife? 10 A. I refuse to answer. 11 Q. His wife at some point in time was associated 12 with Jeffrey Epstein; is that correct? 13 A. I refuse to answer. 14 Q. And her name's Eva Dubin; is that right? 15 A. I refuse to answer. 16 Q. Either way, isn't it true that Jeffrey Epstein 17 then started supplying underage females to Glenn Dubin? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. Do you know 21 A. I refuse to answer. 22 Q. Is that somebody who also worked for Jeffrey 23 Epstein? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0089 1 Q. Did Jeffrey Epstein ever get a legitimate 2 massage from somebody that's a masseuse? 3 MR. PIKE: Form. 4 A. I refuse to answer. 5 Q. the underage females that we've talked about 3524-006 Page43of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009290 EFTA00159292 6 particularly, LM, EW, and Jane Doe, those girls were 7 not prostitutes, were they? 8 A. I refuse to answer. 9 Q. These were just girls who were in 8th, 9th, IC 10th grade in high school, right? 11 A. I refuse to answer. 12 Q. These were girls that you knew had never 13 committed prostitution in the past, right? 14 A. I refuse to answer. 15 Q. And that goes for all of these girls on the 16 phone list of underage minors to call, these were not 17 prostitutes, correct? 18 A. I refuse to answer. 19 Q. You never called a prostitution or escort 20 service for Jeffrey Epstein, did you? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. And as well you never called a legitimate 24 massage parlor for Jeffrey Epstein, correct? 25 A. I refuse to answer. 0090 1 MR. PIKE: Form. 2 Q. He devised this scheme of having underage 3 minor girls bring him other underage minor girls so 4 that he could gain access to his target age group, 12 5 to 16 years old, correct? 6 A. I refuse to answer. 7 Q. Have you heard Jeffrey Epstein say "The 8 younger the better?" 9 A. I refuse to answer. 10 Q. And did Jeffrey Epstein tell you that it made 11 him happy the younger the girl was? 12 A. I refuse to answer. 13 MR. PIKE: Form. 14 Q. The less developed the girl is the more 15 excited Jeffrey Epstein gets; is that true? 16 MR. PIKE: Form. 17 A. I refuse to answer. 18 Q. Do you ever plan to talk to Jeffrey Epstein in 19 the future? 20 A. I refuse to answer. 21 M.R. PIKE: Form. 22 Q. Would you ever work for him again? 23 A. I refuse to answer. 24 Q. why didn't you stop working for him sooner? 25 A. I refuse to answer. 0091 1 MR. PIKE: Form. 2 Q. Did you -- well, you knew that it was illegal 3 what he was doing at the time you were doing it, 4 correct? 5 A. I refuse to answer. 6 Q. Did you know that you were part of a large 7 child molestation ring? 3524-006 Page44of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009291 EFTA00159293 8 MR. PIKE: Form. 9 A. I refuse to answer. IC Q. Did you ever cell anyone while you were 11 working for him. that. you wanted to stop? 12 A. I refuse to answer. 13 MR. PIKE: Form. 14 Q. Did you continue working there because you 15 were just scared to stop? 16 A. I refuse to answer. 17 MR. PIKE: Form. 18 Q. Were you in fear of what. Ghislaine Maxwell or 19 Jeffrey Epstein might do to you if you quit performing 2C your services for his child molestation ring? 21 A. I refuse to answer. 22 MR. PIKE: Form. 23 Q. Did Jeffrey Epstein ever threaten you? 24 A. I refuse to answer. 25 MR. PIKE: Form. 0092 1 Did Ghislaine Maxwell 2 I refuse to answer. 3 How was it decided who would 4 I refuse to answer. 5 Q. And by that, just so it's clear, like I said, 6 there's going to be many, many, many message pads, I 7 have not counted them, but a for rraalad air ha 8 yourself or someone named 9 10 11 employed at Jeffrey Epstein's home. And it seems that 12 13 14 15 16 17 18 19 2C 21 22 23 24 25 0093 1 A. I refuse to answer. 2 Q. And isn't part of the whole scheme that these 3 girls were typically told "Don't tell anybody what. goes 4 on inside this house," right? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. And did Jeffrey Epstein tell you that because 8 these girls are young and they're poor and they're 9 underprivileged type girls they're likely not going to Q. A. Q. A. ever threaten you? call which girl? Various people now to have been on one particular day may call several girls, Who is directing which assistants is going to call the underage minor to give them an appointment? A. I refuse to answer. MR. PIKE: Form. Q. And what would happen on the occasions where Jeffrey Epstein says he's going to be in town and then he's ultimately not in town but a girl shows up anyway? MR. PIKE: Form. A. I refuse to answer. Q. Weren't you just told just to pay her to keep her happy? y call several girls, you may call several girls. h of you, which of the 3524-006 Page 45 of 68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009292 EFTA00159294 le say anything anyway? Isn't that what he told you? 11 MR. PIKE: Form. 12 A. I refuse to answer. 13 Q. Did Ghislaine Maxwell talk to you about that 14 as well? 15 A. I refuse to answer. 16 MR. PIKE: Form. 17 Q. Have you seen Jeffrey Epstein angry? 18 A. I refuse to answer. 19 Q. Isn't it true that he's very nice and engaging 2C as long as he gets his way and gets you to cooperate, 21 right? 22 A. I refuse to answer. 23 Q. But if he doesn't get his way he gets very, 24 very angry and mad and scary; isn't that true? 25 A. I refuse to answer. 0094 1 Q. And you've seen both sides of him, right? 2 A. I refuse to answer. 3 Q. In fact, you know of girls who were 13 years 4 old and cooperated with everything he said because they 5 felt they had no choice up in that bedroom, right? 6 A. I refuse to answer. 7 MR. PIKE: Form. 8 Q. And you also know girls who resisted and were 9 yelled at and told Lo grab their money and get out of 10 there, right? 11 A. I refuse to answer. 12 Q. Wouldn't you agree Chat that house upstairs 13 can be somewhat confusing in how it's -- how it's laid 14 out? 15 A. I refuse to answer. 16 Q. In fact, there's a stairwell that starts from 17 the kitchen, there's a door and it almost blends in in 18 the kitchen with the other closets, correct? 19 A. I refuse to answer. 20 MR. PIKE: Form. 21 Q. But you open that door and there's a stairway 22 that twists it seems to the left and there's another 23 door at the Lop of that stairway, right? 24 A. I refuse Lo answer. 25 Q. And then when you exit that stairway you take 0095 1 a right and you head towards a little hallway that 2 eventually leads into Mr. Epsteln's bedroom, right? 3 A. I refuse to answer. 4 Q. And if it's your first. Lima in that bedroom. as 5 a 14-year-old girl and you don't like what's happened 6 up there would you agree that it's a Lough way to find 7 your -- a place to find your way out of? 8 MR. PIKE: Form. 9 A. I refuse to answer. IC Q. Did Jeffrey -- didn't Jeffrey Epstein tell you 11 that he would act as a father-type figure to these 3524-006 Page46of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009293 EFTA00159295 12 girls? 13 A. I refuse to answer. 14 MR. PIKE: Form. 15 Q. And he would propose that what they are doing 16 for him or with him despite the law is okay? 1? A. I refuse to answer. 18 M.R. PIKE: Form. 19 Q. And they could continue to make a lot of money 20 if they would come over and be his sex victims, right? 21 MR. PIKE: Form. 22 A. I refuse to answer. 23 Q. And you were aware when my client, LK, was 24 pregnant at. 16 years old that Jeffrey Epstein bought 25 everything on her baby registry, right? CC96 1 A. I refuse to answer. 2 MR. PIKE: Form. 3 Q. Was it you or that took all of 4 the gifts over to her home? 5 MR. PIKE: Form. 6 A. I refuse to answer. 7 Q. I believe it was in a -- did 8 Jeffrey Epstein own a Mercedes? 9 MR. PIKE: Form. 10 A. I refuse to answer. 11 Q. And do you remember when loaded 12 up the Mercedes with all the baby gifts and Look it. to 13 my client's trailer? 14 A. I refuse to answer. 15 Q. And that was so that while LM that was to 16 thank her while she was pregnant she continued to bring 17 him 13-, 14-, and 15-year-old girls to molest, correct? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. Because LM would no longer qualify as somebody 21 he'd be sexually interacting with as she was pregnant, 22 correct? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. Because Lhe only real disqualifications for 0097 1 interacting sexually with Mr. Epstein are if you have 2 tattoos, right? 3 A. I refuse to answer. 4 Q. If you're African-American or black? 5 A. I refuse to answer. 6 O. You've never known him to interact with an 7 African-American or black girl, have you? 8 A. I refuse to answer. 9 Q. If you've been pregnant? IC A. I refuse to answer. 11 Q. Or if you are pregnant, correct? 12 A. I refuse to answer. 13 Q. But certainly he was not above having a 3524-006 Page47of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009294 EFTA00159296 14 pregnant 16-year-old girl bringing him underage minor 15 females, correct? 16 A. I refuse to answer. 17 Q. In fact -- 18 MR. PIKE: Form. 19 Q. -- it was his belief that he was doing her a 20 favor in that he was giving her money for providing a 21 service, correct? 22 MR. PIKE: Form. 23 A. I refuse to answer. 24 Q. Is it Jeffrey Epstein's belief that he did 25 these girls a favor? CO9S 1 A. I refuse to answer. 2 Q. I mean, doesn't he think that these girls are 3 lucky that he ever -- that. Lhey ever -- that he ever 4 allowed them out of their trailer and into his mansion, 5 correct? 6 A. I refuse to answer. 7 MR. PIKE: Form. 8 Q. We've defined the molestation statute or at 9 least I read it to you earlier and now we've talked 10 about this scheme of Jeffrey Epstein gaining access to 11 this number of underage minor females. At the time 12 when you were working for him did you recognize him as 13 a serial child molester? 14 MR. PIKE: Form. 15 A. I refuse to answer. 16 Q. Jo you know of anybody that ever worked for 17 him that quit working for him because of what he was 18 doing? 19 A. I refuse to answer. 20 MR. PIKE: Form. 21 Q. Jo you know Michael Friedman? 22 A. I refuse to answer. 23 Q. Is that somebody you ever met there? 24 A. I refuse to answer. 25 Q. What countries does Jeffrey Epstein typically CC99 bring underage minor females from? 2 A. I refuse Lo answer. 3 Q. Jo you know why he chooses the countries that 4 he chooses to import underage minor females from? 5 A. I refuse to answer. 6 MR. PIKE: Form. 7 Q. Was Nadia -- do you know how old 8 was when she came to this country? 9 refuse Lo answer. 10 Q. Have you had conversations with 11 IIIIIIIplabout Jeffrey Epstein bringin!lig lico this 12 country. 13 A. I refuse to answer. 14 Q. She's been described by some as his 15 Yugoslavian lesbian sex slave. Is that something that. 3524-006 Page48of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009295 EFTA00159297 16 is an accurate description based on the observations 17 you have? 18 A. I refuse to answer. 19 MR. PIKE: Form. 20 Q. Did ou ever engage in any lesbian sex with 21 22 A. I refuse to answer. 23 Q. Has ever had sex with Jeffrey 24 Epstein? 25 MR. PIKE: Form. 0100 1 A. I refuse to answer. 2 Q. Do you know how it is that met 3 Jeffrey Epstein? 4 A. I refuse to answer. 5 Q. Do you know Story Cowles? 6 A. I refuse to answer. 7 Q. You know who Sergio Cordero is? 8 A. I refuse to answer. 9 Q. Well, that's somebody who also assists 10 Mr. Epstein in bringing him. underage minor females for 11 sex, correct? 12 A. I refuse to answer. 13 MR. PIKE: Form. 14 Q. And Khalid Monroe, you know who that is? 15 A. I refuse to answer. 16 Q. Also somebody Lhat through MC Squared or some 17 affiliation with that modeling agency would help for 18 Jeffrey Epstein to gain access Co underage minor 19 females for sex, correct? 20 MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. And do you know of trips that Kr. Cordero, 23 Mr. Brunel, and Mr. Epstein took to Brazil specifically 24 for the purposes of Mr. Epstein engaging in sex with 25 12-year-old girls? 0101 1 MR. PIKE: Form. 2 A. I refuse to answer. 3 Q. Are you -- you are aware that Jeffrey Epstein 4 pled guilty to two felonies related to his sexual S interactions, correct? 6 A. I refuse to answer. 7 Q. Okay. 8 VIDEOGRAPHER: Excuse me, counsel. 9 MR. ROSS: I object on privilege grounds -- 10 attorney-client privilege grounds. 11 MR. EDWARDS: Okay, fine. I was trying to get 12 into an area we may get answers. 13 VIDEOGRAPHER: Could I just get you to put 14 your phone on the table? I'm. starting to get 15 interference. 16 MR. ROSS: The phone? 17 VIDEOGRAPHER: Yes, sir. 3524-006 Page49of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009296 EFTA00159298 18 MR. EDWARDS: You got a secret phone? 19 VIDEOGRAPHER: It's anytime it receives any 20 kind of information. 21 MR. ROSS: Oh, okay, yeah, it's -- 22 VIDEOGRAPHER: It's not that it's ringing. 23 MR. ROSS: Right. It's not doing iL now. 24 VIDEOGRAPHER: I apologize for the 25 interruption. 0102 1 Q. All right. I ask you that question because 2 there was also something called a non-prosecution 3 agreement. Are you familiar with that document? 4 A. I refuse to answer. 5 MR. ROSS: Attorney-client privilege. 6 Q. And that is also a document that included your 7 name as a co-conspirator; are you familiar with that? 8 A. I refuse to answer. 9 MR. ROSS: Attorney-client privilege. 10 Q. And that is because of your involvement with 11 calling on the telephone underage minors to bring them 12 to Jeffrey Epstein's house, correct? 13 A. I refuse to answer. 14 Q. Or for your involvement in scheduling 15 appointments in Jeffrey Epstein's appointment book for 16 underage minor -- underage minor females to be involved 17 with Jeffrey Epstein sexually, correct? 18 MR. PIKE: Form. 19 A. I refuse to answer. 20 Q. IL is certainly not because you sought out 21 this child molestation ring in hopes of rising to the 22 Lop, correct? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. Didn't you do everything that you did that 0103 1 anybody could ever say is illegal at the direction of 2 Jeffrey Epstein? 3 A. I refuse to answer. 4 Q. And if it wasn't at the direction of Jeffrey 5 Epstein it was at the direction of Ghislaine Maxwell or 6 Sarah Kellen, correct? 7 MR. PIKE: Form. 8 A. I refuse to answer. 9 Q. I mean, those things were not things that you 1C would have done but for being under the supervision of 11 Jeffrey Epstein; isn't that right.? 12 MR. PIKE: Form. 13 A. I refuse to answer. 14 Q. And you continued to do these things either 15 out of fear or because you were just impressed with 16 Jeffrey Epstein's lifestyle? 17 A. I refuse to answer. 18 Q. Aren't you angry for him involving you in this 19 criminal activity? 3524-006 Page50of68 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009297 EFTA00159299 20 A. I refuse to answer. 21 MR. PIKE: Form. 22 Q. Do you ever intend in the future to talk about 23 what he did and what he involved you in? 24 MR. PIKE: Form. 25 A. I refuse to answer. 0104 1 Q. Wouldn't you like to separate yourself being 2 the person that you are from this person who brought 3 you into this mess? 4 MR. PIKE: Form. 5 A. I refuse to answer. 6 Q. Is Jeffrey Epstein paying for your attorney 7 now? 8 MR. PIKE: Form. 9 A. I refuse to answer. 10 MR. ROSS: Well, actually you can answer. 11 A. No, my parents help me. 12 Q. Are you aware of Jeffrey Epstein's closest 13 friends now? 14 A. I refuse to answer. 15 MR. PIKE: Form. 16 Q. Who are the people that you believe are 17 Jeffrey Epstein's enemies? 18 MR. PIKE: Form. 19 A. I refuse to answer. 2C Q. Did you ever find out. that Jeffrey Epstein and 21 Ghislaine Maxwell had been targeting and preying upon 22 underage females for sex for more than a decade? 23 MR. PIKE: Form. 24 A. I refuse to answer. 25 Q. Who is Jeffrey Epstein's girlfriend now, if 01