UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendants. / Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-8-591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF TAKEN ON BEHALF OF THE PLAINTIFF DATE: April 13, 2010 U.S. Legal Support (561) 835-0220 EFTA00181769 2 1 2 3 4 6 7 April 13,2010 INDEX WITNESS DIRECT CROSS REDIRECT RECROSS BY MR. EDWARDS 5 98 BY MR. HOROWITZ 65 BY MR. LANGINO 77 BY MS. EZELL 8I 10 EXHIBITS 11 PLAINTIFF'S FOR IDENTIFICATION 12 I Message dated August 21,2005. 13 14 15 16 17 18 19 20 21 22 23 24 25 PAGE 45 APPEARANCES (CONTINUED) 2 LEOPOLD-KUVIN Attorneys for Plaintiffs 3 II. B. and CI'. 2925 PGA Boulevard, Suite 200 4 Palm Beach Garden, Florida 33410 Tel: (561)515-1400 BY: ADAM J. LANGINO, ESQ. 5 6 7 PODHURST, ORSECK Attorneys for Jane Does I and 3 City National Bank Building, Suite 88 9 25 West Saida Street Miami, Florida 33130 10 Tel: (954)463-4346 BY: KATHERINE W. EZELL, ESQ. 11 12 BURMAN. CIUTTON, LUTITER & COLEMAN, LIP Attorneys for Defendant Jeffrey Epstein 13 303 Banyon Boukvard. Suite 400 West Palm Beach. Florida 33401 14 Tel: (561)842-2820 BY: DAVID YAREMA, ESQ. 15 ROBERT turret'', ESQ. 16 AlTERBURY, GOLDBERGER & WEISS 17 Co-Counsel for Defendarus One Clearbke Court 18 Suite 1400 West Palm Beach. Florida 33401 19 Tel: (561)659.8300 BY: JACK A. GOLDBERGER. ESQ. 20 21 22 23 24 25 ALSO PRESENT: JESSICA CADWELL JOE ROVNER. Videographer (U.S. Legal) 3 1 The videotaped deposition of — 2 in the above-entitled and numbered 3 cause, was taken before me, TERRI BECKER, a 4 Registered Professional Reporter and Notary 5 Public for the State of Florida at Large, at 444 6 West Railroad Avenue, in the City of West Palm 7 Beach, Palm Beach County, in the State of 8 Florida, beginning at the hour of 10:00 o'clock 9 a.m., pursuant to the Notice in said cause for 10 the taking of said deposition which is annexed to 11 the court file herein, on behalf of the PLAINTIFF 12 in the above-entitled action pending in the 13 above-named court. 14 The appearances at said time and place 15 were as follows: 16 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL 17 Attorneys for Plaintiffs Jane Does, L.N. and E.W. 18 425 North Andrews Avenue Suite 2 19 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 20 BY: BRADLEY J. EDWAltDS, ESQ. 21 MERMELSTEIN & HOROWITZ, P.A. 22 Attorneys for Plaintiffs Jane Does, numbers 2 through 8 23 18205 Biscayne Boulevard Suite 2218 24 Miami, Florida 33160 Tel: (305) 931-2200 25 BY: ADAM D. HOROWITZ, ESQ. 16 17 18 19 20 21 22 23 24 25 5 1 THEREUPON, 2 3 being by Terri Becker lint duly sworn to tell 4 the whole truth, as hereinafter certified, 5 testified as follows: 6 DIRECT EXAMINATION 7 BY MR. EDWARDS: 8 Q Can you tell us your name. 9 0 Q What Is your date of birth? 1 A February 21, 1985. 2 Q What is your Social Security number? 3 A Under advice of my counsel, I invoke my 4 privileges under the Fifth and Sixth Amendments 5 to the United States Constitution and respectfully decline to answer the question. Q Where were you born? A I'm sorry, though I would like to answer your question, I must invoke my Fifth and Sixth Amendment privileges and refuse to answer your questions. Q What is your current address? MR. GOLDBERGER: There is going to be a continued, obviously, you anticipate I'm sure, continued invocation of Fifth 2 (Pages 2 to 5) U.S. Legal Support (561) 835-0220 EFTA00181770 1 2 3 4 5 6 7 B 6 Amendment privileges. If it is okay with all counsel, to shorten things, I'll simply have the witness say "Fifth." if that satisfies everyone's interest. MR. EDWARDS: That is fine with me. MR. GOLDBERGER: Okay, with that Cathy? MS. EZELL: Yes. MR. HOROWITZ: Yes. 1 2 3 5 6 7 8 8 A The Fifth. Q Do you know a lady by the name of Maritsa Vazques? A The Fifth. Q Is this somebody who helped to falsify a visa for you? MR. YAREMA: Object to the form. A The Fifth. 9 Q reask the question, what's your 9 Q Do you know Evelyn Velasaques? 10 current address? 10 A The Fifth. 11 A Fifth. 11 Q Were you ever a working model in the 12 Q Are you currently living at 358 El 12 United States? 13 Brillo Way with a man named Jeffrey Epstein? 13 A The Fifth. 14 A The Fifth. 14 Q Can you tell us your parents' names? 15 Q Are you also familiar with all address in 15 A The Fifth. 16 New York, 301 East 66th Street? 16 Q Flow is it that you have supported 17 A The Fifth. 17 yourself financially, since you have been in this 18 Q When Mr. Epstein was incarcerated in 18 country? 19 jail, you went to visit him on numerous 19 MR. YAREMA: Object to the fonn. 20 occasions; is that correct? 20 A The Fifth. 21 MR. YAREMA: Objection. 21 Q Have you supported yourself financially? 22 A Thc Fifth. 22 A The Fifth. 23 Q When you went to visit him you indicated 23 Q What is the last grade you completed in 24 to jail personnel your address was 301 East 66th 24 school? 25 Street, apartment 8-D in New York City, New York; 25 A The Fifth, I take the Fifth Amendment. 7 9 1 Is that correct? 1 Q Are you in school now? 2 MR. YAREMA: Objection. 2 A The Fifth. 3 A Fifth. 3 Q Have you ever attended any school in the 4 Q Isn't it true when Mr. Epstein was In 4 United States? 5 jail, you visited him on more than 50 occasions? 5 A The Fifth. 6 MR. YARE•MA: Form objection. 6 Q Ilave you ever been employed since 7 Q True? 7 residing in the United States? 8 A The Fifth. 8 A The Fifth. 9 Q Flow long have you been in the United 9 Q Is Jeffrey Epstein your sole means of 10 States, Ms. 10 financial support today? 11 A The Fifth. 11 MR. YAREMA: Object to the form. 12 Q Who brought you to the United States? 12 A Thc Fifth. 13 MR. YAREMA: Form objection. 13 Q Since coming to this country, hasn't 14 A The Fifth. 14 Jeffrey Epstein always been your sole means of 15 Q What is your current status In this 15 financial support? 16 country? 16 MR. YAREMA: Object to the form. 17 A The Fifth. 17 A The Fifth. 18 MR. YAREMA: Form objection. 18 Q Flow much does Jeffrey Epstein pay you 19 MR. GOLDBERGER: Let me take a half a 19 today? 20 second. 20 MR. YAREMA: Object to the form. 21 (Witness and her counsel confer.) 21 A The Fifth. 22 Q Are you a U.S. citizen? 22 Q What does every Epstein pay you for? 23 A The Fifth. 23 MR. YAREMA: Object to the form. 24 Q What type of visa are you here on? 24 A The Fifth. 25 MR. YAREMA: Form objection. 25 Q Does he pay you specifically to be his 3 (Pages 6 to 9) U.S. Legal Support (561) 835-0220 EFTA00181771 10 12 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 sex slave? 2 MR. YAREMA: Object to the form. 3 A The 4 Q Are you aware that the reports about you 5 indicate that you were brought to the United States by Jeffrey Epstein when you were roughly 13 or 14 years old to be his Yugoslavian lesbian sex slave? MR. YAREMA: Object to the form. A The Fifth. Q Is that true? MR. YAREMA: Object to the form. A The Fifth. Q Have you performed any services for Jeffrey Epstein aside from being his sex slave? MR. YAREMA: Object to the fonn. A The Fifth. Q What Is your sexual orientation? MR. YAREMA: Object to the form. MR. GOLDBERGER: I'm going to instruct the witness not to answer that question. It serves no purpose other than to harass or intimidate her, so in addition to Fifth Amendment privileges, I'm objecting on privacy grounds. 1 Epstein's sex slaves? 2 MR. YAREMA: Object to the Iona 3 A Fifth. 4 Q What does it mean to be Jeffrey 5 Epstein's sex slave? 6 MR. YAREMA: Object to the form. 7 A Fifth. 8 Q Are you aware that Jeffrey Epstein reads 9 books on how to be a proper master to his sex 10 slave? 11 MR. YAREMA: Object to the fonn. 12 A Fifth. 13 Q What has Jeffrey Epstein done to train 14 you to be his sex slave? 15 MR. YAREMA: Object to the fonn. 16 A Fifth. 17 Q What do your parents think about you 18 being Jeffrey Epstein's sex slave? 19 MR. YAREMA: Object to the fonn. 20 A Fifth. 21 Q When did you first learn that Jeffrey 22 Epstein had a sexual obsession for underage minor 23 females? 24 MR. YAREMA: Object to the form. 25 A Fifth. 11 1 A I take the Fifth. 2 Q I represent a lady named, a young female 3 named E.W.; you know who that is, right? 4 Ma. YAREMA: Object to the form. S A The Fifth. 6 Q Jeffrey Epstein made you have sex with 7 E.W., didn't he? 8 MR: YAREMA: Object to die form. A The Fifth. Q You did, in fact, engage in sexual activity with E.W. when she was only 16 years old; isn't that true? MR. YAREMA: Object to the fonn. A The Fifth. Q Back to my original question: And I'll ask you this way: Do you consider yourself heterosexual, bi-sexual, or can you answer that question? MR. YAREMA: Object to the form. MR. GOLDBERGER: Seine objection. Do not answer the question. A Fifth. Q How did you meet Jeffrey Epstein? A Fifth. Q When did you become one of Jeffrey 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 13 Q How many times has Jeffrey Epstein made you have sex with underage minor females? MR. YAREMA: Object to the fonn. A Fifth. Q Do you enjoy sex with underage minor females? MR. YAREMA: Object to the form. A Fifth. Q What is the youngest child that Jeffrey Epstein has forced you to have sex with? MR. YAREMA: Object to the form. A Fifth. Q Does Jeffrey Epstein today still make you have sex with underage minor females? MR. YAREMA: Object to the form. A Fifth. Q How ninny underage minor females has Jeffrey Epstein made you have sex with, since you were over the age of 18? MR. YAREMA: Object to the form. A The Fifth. Q Prior to turning 18, Is it true that Jeffrey Epstein made you have sex with many other children in kid-type orgies? MR. YAREMA: Object to the form 4 (Pages 10 to 13) U.S. Legal Support (561) 835-0220 EFTA00181772 14 16 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 A Fifth. 2 Q Has Jeffrey Epstein also made you 3 perform sexually on his friends? 4 MR. YAREMA: Object to the form. 5 A Fifth. 6 Q Do you know David Copperfield? 7 MR. YAREMA: Object to the form. 8 A Fifth. Q Have you ever been made to perform sexually on David Copperfield? MR. YAREMA: Object to the form. A Fifth. Q Do you know Prince Andrew? A Fifth. Q Have you ever been made to perform sexually on Prince Andrew? MR. YAREMA: Object to the form. A Fifth. Q When was the first time that you knew Jeffrey Epstein molested underage girls? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein molest you when you were underage? MR. YAREMA: Object to the form. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Fifth. Q Have you read the nonprosecution agreement between the government and Jeffrey Epstein? A Fifth. Q Are you aware that inside that document you are labeled as a co-conspirator of his crimes against children? MR. YAREMA: Object to the form. A Fifth. Q Isn't it true that your role was to lure or procure underage minor females to Jeffrey Epstein for him to molest, correct? MR. YAREMA: Object to the form. A Fifth. Q You also scheduled appointments for Jeffrey Epstein, so there would be designated times for Jeffrey Epstein to molest underage minor females, correct? MR. YAREMA: Object to the fonn. A The Fifth. Q As well, you participated in various sex acts with underage minor females, thus molesting them yourself; is that correct? MR. YAREMA: Object to the fonn. 1 2 3 4 5 6 7 B 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 15 A Fifth. Q I'm assuming you understand why you're here today, correct? MR. YAREMA: Object to the form. A The Fifth. Q For allegations related to Jeffrey Epstein interacting sexually with numerous underage minor females; that's something you know, right? MR. YAREMA: Object to the fonn. A The Fifth. Q That's something In addition to the civil lawsuits, there were criminal cases involving the same conduct, correct? MR. YAREMA: Object to the form. A Fifth. Q You were n part of that criminal investigation, in fact, you were a co-conspirator of Jeffrey Epstein's; is that right? MR. YAREMA: Object to the form. A Fifth. Q What crimes did you conspire to commit with Jeffrey Epstein against underage minor females? MR. YAREMA: Object to the form. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 17 A Fifth. Q Do you understand that Jeffrey Epstein's interaction with underage minor females is illegal? Do you understand that? MR. YAREMA: Object to the fonn. A The Fifth. Q Do you understand that the Lewd and Lascivious Molestation Statute in Florida indicates a person who intentionally touches in a lewd or lascivious manner, the breasts, genital area or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or entices a person under 16 years of age, to so touch the perpetrator, commits lewd or lascivious molestation? Are you aware of that statute? A Fifth. Q That is a statute that you know Jeffrey Epstein to have violated; is that true? MR. YAREMA: Object to the form. A The Fifth. Q That's a statute that you yourself have violated; is that true? MR. YAREMA: Object to the form. A The Fifth. Q You've observed Jeffrey Epstein violate 5 (Pages 14 to 17) U.S. Legal Support (561) 835-0220 EFTA00181773 18 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that statute on many underage minor females, true? MR. YAREMA: Object to the tbnn. A The Fifth. Q Have you ever discussed with Jeffrey Epstein that the fact that he is a child molester? MR. YAREMA: Object to the form. A Fifth. Q Have you asked Jeffrey Epstein why he has made you interact with underage minor females in a sexual manner? MR. YAREMA: Object to the form. A Fifth. Q During the litigation of these civil eases, has Jeffrey Epstein indicated to you an intent to continue to molest children? MR. YAREMA: Object to the form. A Fifth. Q Is it your intent to continue to commit sex crimes against minors? MR. YAREMA: Object to the font A Fifth. Q in addition to your being named as a co-conspirator of Jeffrey Epstein regarding his 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 co-conspirator in the non-prosecution agreement related to Jeffrey Epstein's crimes against minors? MR. YAREMA: Object to the form. A Fifth. Q Do you know IIIMP A Fifth. Q These are all people who also participated in Jeffrey Epstein's scheme to lure underage females to him for sex; is that true? MIL YAREMA: Object to the form. A Fifth. Q You and these other co-conspirators played various roles to make sure Jeffrey Epstein was able to engage in sexual contact or conduct, with underage minor females on an everyday basis; is that true? MR. YAREMA: Object to the form. A Fifth. Q Since the time you first met Jeffrey Epstein, has his appetite for underage minor females always been the same? MR. YAREMA: Object to the form. A Fifth. 19 1 crimes against minors, there Is also a person 2 ram. listed as a co-conspirator. 3 Do you know IMM? 4 A Fifth. 5 Q This is somebody who lives with you and 6 Jeffrey Epstein; is that true? 7 MR. YAREMA: Object to the form. 8 A Fifth. 9 Q And is somebody who you 10 know to be Story Cowles's girlfriend; is that 11 true? 12 MR. YAREMA: Object to the fonts. 13 A Fifth. 14 Q She's spoken with Story Cowles about 15 this case on numerous occasions; is that true? 16 MR. YAREMA: Object to the form. 17 A Fifth. 18 conversations with Story 19 Cowles and your observations of them, you believe 20 would implicate you in a crime and that's why 21 you're able to take the Fifth as to that 22 question? 23 MR. YAREMA: Object to the form. 24 A Fifth. 25 Q Who is Lesley Croft, also listed as a 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q By that I mean, have you observed Jeffrey Epstein to interact sexually with underage minor females literally on a daily basis? MR. YAREMA: Object to the form. A Fifth. Q Wasn't it one of your specific job duties to make sure that he had different underage minor females to molest on a daily basis? MR. YAREMA: Object to the form. A Fifth. Q In addition to the improper sexual contact between Jeffrey Epstein and underage minor females at the West Paint Beach house, you have observed similar improper and illegal contact by Jeffrey Epstein in his New York mansion, as well, correct? MR. YAREMA: Object to the form. A Fifth. Q In fact, he operates a very similar scheme up there, in that he schedules these appointments with underage minor females, under the guise that it is going to be a massage; is that correct? 6 (Pages 18 to 21) U.S. Legal Support (561) 835-0220 EFTA00181774 22 24 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 MR. YAREMA: Object to the form? 2 A Fifth. 3 Q When he is in New York, he has contact 4 with underage minor remain for the purposes of 5 sexually molesting them as well; is that 6 correct? 7 MR. YAREMA: Object to the form. 8 A Fifth. Q When he is in his ranch In New Mexico, similarly, Jeffrey Epstein is engaging in sex with underage minor females front that local area as well, and that's something you've observed? MR. YAREMA: Object to the form. A Filth. Q On his island, particularly, lie has flown underage minor females to the island for underage kid-type orgies; is that true? MR. YAREMA: Object to the fonn. A Fifth. Q You're shaking your head Indicating, at least to me, indicating that you may not agree with what I'm saying, and I would love to give you the chance to explain it to us. MR. GOLDBERGER: I appreciate that, but don't — 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 when Jeffrey Epstein commits these crimes against children? MR. YAREMA: Object to the font A Fifth. Q Is there any way for you to escape being his sex slave? MR. YAREMA: Object to the font A Fifth. Q Have you ever wanted to cooperate with the authorities, so that you could escape being his sex slave? MR. YAREMA: Object to the fonn. A Fifth. Q Do you represent to others that you arc his girlfriend or his sex slave, or some other designation? MR. YAREMA: Object to the toms. A Fifth. Q Isn't it true that you recently represented to the Probation Officer that you were his live-in girlfriend? MR. YAREMA: Object to the form. A Fifth. Q When Probation calls the house, are you told to tell Probation that he is in the swimming 23 1 MR. EDWARDS: Read too much into it? 2 MR. GOLDBERGER: Exactly. Don't go 3 there. Just ask the questions and we will 4 move right along. MR. EDWARDS: I agree, Jack, I just know 6 if this is played for a jury, I don't went 7 the jury to interpret her shaking her head 8 as a "No," and then her pleading the Fifth. 9 MR. GOLDBERGER: I appreciate that. 10 Don't take anything as to any head movements 11 or any body movements at all. Just ask the 12 questions and we will let the video speak 13 for itself. 14 Q How many of these — you know what an 15 orgy is, don't you? 16 A Fifth. 17 Q And how many of these orgies, as I'm 18 calling them, where there are numerous underage 19 minors having sex with each other and with 20 Jeffrey Epstein, have you observed on Jeffrey 21 Epstein's island? 22 MR. YAREMA: Object to the form. 23 A Fifth. 24 Q Is part of your role as Jeffrey 25 Epstein's sex slave, to not tell the authorities 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 25 pool or doing some other activity that would not allow him to come to the telephone? MR. YAREMA: Object to the foam A Fifth. Q Isn't it true you're under strict orders to tell Probation that? MR. YAREMA: Object to the form. A Fifth. Q Isn't ft true you've heard Jeffrey Epstein tell you on numerous occasions, regarding the age of the girls that he wants to his house, for the purposes of sexually molesting, the phrase he uses is "the younger the better," true? MR. YAREMA: Object to the fonn. A Fifth. Q I asked you earlier about E.W. out of turn as a result of an objection related to your sexual orientation, but I'll talk specifically about E.W. right now. You know who that is, right? MR. YAREMA: Object to the form. A Fifth. Q That is somebody you observed Jeffrey Epstein to call for the purposes of getting her 7 (Pages 22 to 25) U.S. Legal Support (561) 835-0220 EFTA00181775 1 2 3 26 to his house to sexually molest; is that right? MR. YAREMA: Object to the form. A Fifth. Q The first time she went to Jeffrey 1 2 3 4 28 minor females? MR. YAREMA: Object to the form. A Fifth. Q You have received oral sex from underage 5 Epstein's house was in 2002 when she was only 14 minor females? 6 years old; is that true? 6 MR. YAREMA: Object to the form. 7 MR. YAREMA: Object to the form. 7 A Filth. 8 A Fifth. 8 Q All of these sexual acts with minor 9 Q In fact In 2002 you were only 18 years 9 females involving you happened in the presence of 10 old or so yourself; is that right? 10 Jeffrey Epstein? 11 A Fifth. 11 MR. YAREMA: Object to the form. 12 Q And E.W. is somebody you observed at 12 A Fifth. 13 Jeffrey Epstein's house on more than 100 13 Q During your interaction with underage 14 occasions between 2002 and 2005, a time period 14 minor females in a sexual manner, isn't it true 15 between 14 and 17 years of age for her; is that 15 that Jeffrey Epstein would participate in the 16 right? 16 sexual acts and the act would be over upon 17 MR. YAREMA: Object to the form. 17 Jeffrey Epstein ejaculating, correct? 18 A Fifth. 18 MR. YAREMA: Object to the form. 19 Q And each time E.W. was summoned to 19 A Fifth. 20 Jeffrey Epstein's house, it was for the purposes 20 Q Did Jeffrey Epstein tell you, that when 21 of Jeffrey Epstein sexually molesting her, 21 E.W. was an underage minor female, he forced her 22 correct? 22 to give him oral sex? 23 MR. YAREMA: Object to the fonn. 23 MR. YAREMA: Object to the form. 24 A Filth. 24 A Fifth. 25 Q If it was not Jeffrey Epstein personally 25 Q Do you remember E.W. coming over, a 27 29 1 calling E.W., you observed to call 1 young girl, with braces on, and going up into 2 E.W. for the purposes of her coming over and 2 Jeffrey Epstein's bedroom on numerous occasions 3 pleasing Jeffrey Epstein sexually, correct? 3 to be sexually molested? 4 MR. YAREMA: Object to the form. 4 MR. YAREMA: Object to the form. 5 A Fifth. S A Fifth. 6 Q And do you remember the instance where 6 Q Do you know when it was that Jeffrey 7 Jeffrey Epstein instructed you to lay down naked 7 Epstein developed his plan or scheme to gain 8 and engage in a threesome with E.W. and Jeffrey 8 access to hundreds of underage minor females for 9 Epstein? 9 the purposes of his sexual gratification? 10 MR. YAREMA: Object to the form. 10 MR. YAREMA: Object to the form. 11 A Fifth. 11 A Fifth. 12 Q Do you remember that that during that 12 Q Were you a part of the planning of that 13 threesome, Jeffrey Epstein demanded E.W. to 13 scheme of Jeffrey Epstein's to gain Recess to 14 straddle you and otherwise engage sexually with 14 underage minor females? 15 you while Jeffrey Epstein was using vibrators 15 MR. YAREMA: Object to the fonn. 16 and/or dildos on you? 16 A Fifth. 17 MR. YAREMA: Object to the font 17 Q Do you know Ghislaine Maxwell? 18 A Fifth. 18 A Fifth. 19 Q in addition to your sexual interactions 19 Q Is that somebody who helped Jeffrey 20 with E.W., isn't it true that you have used 20 Epstein to devise the scheme to allow him access 21 strap-on dildos and vibrators on other underage 21 to various and n variety of underage minor 22 minors at Jeffrey Epstein's direction? 22 females? 23 MR. YAREMA: Object to the form. 23 MR. YAREMA: Object to the form. 24 A Fifth. 24 A Fifth. 25 Q You have given oral sex to underage 25 Q Is somebody that was also 8 (Pages 26 to 29) U.S. Legal Support (561) 835-0220 EFTA00181776 30 32 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 involved in the planning of this scheme to gain access to underage minor females? MR. YAREM A: Object to the form. A Fifth. Q When is the first time that you observed Jeffrey Epstein's method of enticing or Inducing underage minor females into sexual acts with him inside his bedroom? MR. YAREMA: Object to the form. A Fifth. Q Isn't it true that after an underage minor female was brought to Jeffrey F.pstein's house, typically or Adriana or yourself would lead that underage minor female to Jeffrey Epstein's bedroom and leave them alone in the room; is that true? MR. YAREMA: Object to the fonn. A Fifth. Q Then Jeffrey Epstein would appear either naked or wearing a towel; is that true? MR. YAREMA: Object to the fonn. A Fifth. Q This is his habit or method of operation, every single time, and that's something that he has told you about his sexual 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 sex toys on you, correct? A Fifth. Q And he has instructed you to use sex toys and vibrators on other underage minor females, correct? MR. YAREMA: Object to the form. A Fifth. Q You have observed Jeffrey Epstein digitally penetrate the vagina of underage minor females, including E.W., correct? MR. YAREMA: Object to the fonn. A Fifth. Q As part of his plan to avoid detection by law enforcement, you have observed Jeffrey Epstein to pay these underage minor females to he quiet, correct? MR. YAREMA: Object to the fonn. A Fifth. Q And this is something that he has told you he does, for the purposes of grooming these underage minor females, and avoiding law enforcement detection, correct? MR. YAREMA: Object to the form. A . Fifth. Q Jeffrey Epstein has talked to you about 31 1 interaction with underage minors; is that true? 2 MR. YAREMA: Object to the fonn. 3 A Fifth. 4 Q And he would direct or demand or 5 instruct the underage minor female to remove her 6 clothing; is that true? 7 MR. YAREMA: Object to the form. A Fifth. Q Then he would perform one or more lewd or lascivious or sexual acts on the underage minor female. Is that true? MR. YAREMA: Object to the form. A Fifth. Q And you have observed Jeffrey Epstein engage in sexual interaction with underage minor females on hundreds and hundreds of occasions, correct? MR. YAREMA: Object to the fonn. A Fifth. Q And you have observed Jeffrey Epstein using vibrators and sexual toys on underage minors, true? MR. YAREMA: Object to the form. A Fifth. Q In fact, he has also used vibrators and 33 1 the psychology of brainwashing or grooming 2 underage minor females to perform for him 3 sexually, hasn't he? 4 MR. YAREMA: Object to the form. 5 A Fifth. 6 Q And Sarah Kellen has also spoken with 7 you about the methodology behind gaining access 8 to and grooming underage minor females for sex? 9 MR. YAREMA: Object to form. 10 A Fifth. 11 Q Isn't it true that Chislaine Maxwell and 12 yourself and had access to a master 13 list of underage minor females names and phone 14 numbers so that they could be called? 15 MR. GOLDBERGER: Time out. Are you 16 talking to mc, counsel? 17 MR. HOROWITZ: Nodding my head, back at 18 you. You were nodding at me. 19 MR. GOLDBERGER: I wasn't nodding at 20 you. I'm not talking to you, I'm not 21 communicating with you.. I don't know what 22 you think we are doing here. You said "It 23 is true," and I have no idea what you are 24 talking about. Don't interrupt the 25 deposition, okay? 9 (Pages 30 to 33) U.S. Legal Support (561) 835-0220 EFTA00181777 34 MR. HOROWITZ: I think you interrupted. 1 36 A Fifth. 2 MR. GOLDBERGER: I didn't do a thing -- 2 Q In addition to that system, isn't it 3 MR. EDWARDS: I don't know what's 3 true that Jeffrey Epstein traffics underage minor 4 happened here. It has deteriorated here for 4 females through a modeling agency? 5 no reason whatsoever and has nothing to do 5 MR. YAREMA: Object to the form. 6 with me or the witness. 6 A Fifth. 7 MR. GOLDBERGER: You're 100 percent 7 Q Is a modeling agency that he is involved 8 correct. 8 in with Jean Luc Brunel; you know who that is MR. EDWARDS: Can we go back to it. 9 right? 10 MR. GOLDBERGER: Absolutely. 10 MR. YAREMA: Object to the loan. 11 MIL EDWARDS: Perfect. 11 A Fifth. 12 The silent fight disrupted me. I lost 12 Q Arc you familiar with MC-2 or MC-Squared 13 where I am now. 13 Modeling Agency? 14 MR. GOLDBERGER: Sony. 14 A Fifth. 15 MR. EDWARDS: Can you read it back. 15 Q You know Jean Luc Brunel, right? 16 THE COURT REPORTER: Certainly. 16 MR. YAREMA: Object to the form. 17 (The record was read.) 17 A Fifth. 18 MR. EDWARDS: I'll rephrase the 18 Q Is Jean Luc Brunel somebody that you 19 question. 19 have been made to perform on sexually? 20 Q Isn't it true that yourself, Chislalne 20 MR. YAREMA: Object to the form. 21 Maxwell and had access to a master 21 A Fifth. 22 of list of underage minor females names and phone 22 Q Jean Luc Brunel is somebody that you 23 numbers so they could be called for the purpose 23 know to also be a child molester, true? 24 of coming to Jeffrey Epstein's house to be 24 MR. YAREMA: Object to the form. 25 sexually molested? 25 A Fifth. 35 37 1 MR. YAREMA: Object to the form. 1 Q This is somebody who for years the 2 A Fifth. 2 public has known of Jean Luc Brunel as a child 3 Q How many underage minor females are on 3 molester, true? 4 that master list? 4 MR. YAREMA: Object to the fonn. 5 MR. YAREMA: Object to the form. 5 A Fifth. 6 A Fifth. 6 Q In fact, that is the only thing Jeffrey 7 Q Are there photographs of these underage 7 Epstein and Jean Luc Brunel have in common, is 8 minor females on that master list? 8 their obsession for underage minor females, MR. YAREMA: Object to the form. 9 correct? 10 A Fifth. 10 MR. YAREMA: Object to the four. 11 Q Is that master list saved on a computer 11 A Fifth. 12 system, as has been testified to in the past? 1.2 Q And the modeling agency is but one other 13 MR. YAREMA: Object to the fonn. 13 mechanism used by Jeffrey Epstein to gain access 14 A Fifth. 14 to underage minor females for sex, true? 15 Q Has Jeffrey Epstein talked to you about 15 MR. YAREMA: Object to the fonn. 16 the success of his scheme to procure underage 16 A Fifth. 17 minor females? 17 Q I read you the statute earlier on Lewd 18 MR. YAREMA: Object to the form. 18 and Lascivious Molestation, Chapter 800.04, and 19 A Fifth. 19 that's something that you have witnessed Jeffrey 20 Q By that, I mean, the method where he 20 Epstein violate on hundreds of occasions, 21 molests an underage minor female, then offers 21 correct? 2 them additional money if they will bring hint 22 MR. YAREMA: Object to the form. 3 other underage minor females to molest; are you 23 A Fifth. 4 familiar with that system? 24 Q And something that you have witnessed 5 MR. YAREMA: Object to the form. 25 Jeffrey Epstein specifically violate, against 10 (Pages 34 to 37) U.S. Legal Support (561) 835-0220 EFTA00181778 1 2 3 4 5 6 7 38 E.W., true? MR. YAREMA: Object to the form. A Fifth. Q Also a statute you have witnessed Jeffrey Epstein violate against then minor, LM.? MR. YAREMA: Object to the font 1 2 3 4 5 6 7 40 Epstein's house, and he is using all resources to try to intimidate and harass her; Is that true? MR. YAREMA: Object to the form. A Fifth. Q in fact, has he talked to you about his tactic of intimidating and harassing any victims that come forward against him, regarding the 8 A Fifth. a sexual abuse that they endured by him? 9 Q In fact L.M. was somebody that Jeffrey 9 MR. YAREMA: Object to the font 10 Epstein liked or likes; isn't that true? 10 A Fifth. 11 MR. YAREMA: Object to the fonn. 11 Q Would you agree that Jeffrey Epstein 12 A Fifth. 12 contributed to the delinquency of these various 13 Q L.M. was somebody Jeffrey Epstein met 13 minors that he sexually abused? 14 when she was only 13 years old and began sexually 14 MR. YAREMA: Object to the font 15 molesting her the first day that he met her, 15 A Fifth. 16 true? 16 Q in addition to abusing them, he also 17 MR. YAREMA: Object to the form. 1.7 encouraged them to return to him to receive more 18 A Fifth. 18 sexual abuse and encouraged them into a life of 19 Q L.M. was one of his main girls, as he 19 prostitution, true? 20 would call them; is that true? 20 MR. YAREMA: Object to the fonn. 21 MR. YAREMA: Object to the lone. 21 A Fifth. 22 A Fifth. 22 Q Flow many underage minor females have you 23 Q L.M. procured for him or brought for him 23 observed Jeffrey Epstein engage in sex acts with 24 to his house, over 50 girls between the ages of 24 on any of his airplanes? 25 12 and 15 years old; is that true? 25 MR. YAREMA: Object to the form. 39 41 1 MR. YAREMA: Object to the form. 1 A Fifth. 2 A Fifth. 2 Q Have you engaged in sexual acts with any 3 Q Each of these girls, aged 12 to 15, you 3 underage minor females on Jeffrey Epstein's 4 observed come into the house, go into Jeffrey 4 airplanes? 5 Epstein's bedroom and leave the house after being 5 MR. YAREMA: Object to the form. 6 sexually molested, true? 6 A Fifth. 7 MR. YAREMA: Object to the form. 7 Q How many tines has Jeffrey Epstein 8 A Fifth. 8 talked to you about the reasons why he sexually 9 Q And in addition to L.M. being sexually 9 abuses minors? 10 molested herself, she was enticed or coerced into 10 MR. YAREMA: Object to the form. 11 bringing her friends over, to also be sexually 11 A Fifth. 12 molested, true? 12 Q Didn't he tell you that it is his intent 13 MR. YAREMA: Object to the form. 13 to harm these minors in hopes of gaining 14 A Fifth. 14 psychological advantage over them? 15 Q Has Jeffrey Epstein talked to you about 15 MR. YAREMA: Object to the form. 16 an FBI statement that was given by L.M.? 16 A Fifth. 17 A Fifth. 17 Q Are you aware that Jeffrey Epstein pled 18 Q lie has also told you that that FBI 18 guilty to two felonies related to his Interaction 19 statement that was favorable for him is 19 with minors? 20 completely false; isn't that true? 20 MR. YAREMA: Object to the form. 21 MR. YAREMA: Object to the form. 21 A Fifth. 22 A Fifth. 22 Q And as a result he was incarcerated, and 23 Q Has he spoken to you about the fact that 23 as we spoke about earlier, you visited hint in 24 she is now telling the complete story and 24 jail on more than 50 occasions, correct? 25 accurate account as to what happened at Jeffrey 25 MR. YAREMA: Object to the form. 11 (Pages 38 to 41) U.S. Legal Support (561) 835-0220 EFTA00181779 42 44 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6' 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Fifth. Q Aren't your observations with Jeffrey Epstein's interactions with E.W., wouldn't you agree he coerced her into a life of prostitution? MR. YAREMA: Object to the form. A Fifth. Q And based on your observations of Jeffrey Epstein's interactions with L.M., wouldn't you agree that Jeffrey Epstein coerced her into a life of prostitution? MR. YAREMA: Object to the form. A Fifth. Q And with respect to Jane Doe and E.W. and L.M., wouldn't you agree that Jeffrey Epstein forced these girls to be a prostitute for him? MR. YAREMA: Object to the form. A Fifth. Q Would you agree that Jeffrey Epstein's actions against E.W., L.M. and Jane Doe, were intentional, deliberate and reckless? MR. YAREMA: Object to the form. A Fifth. Q Would you agree that that intentional, deliberate and reckless conduct by Jeffrey Epstein against L.M., E.W. and Jane Doe was 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Do you profit from sex trafficking or children? MR. YAREMA: Object to the form. A Fifth. Q Do you know Sergio Cordero? A Fifth. Q A Q criminal enterprise that Is designed to molest underage minor females, to be organized? MR. YAREMA: Object to the form. A Fifth. Q Is your role in that criminal arrangement to molest underage minor females, to help organize? MR. YAREMA: Object to the fonn. A Fifth. Q As part of that organization, isn't it true that you, as well as various staff members, took meticulous messages regarding appointments and scheduling underage minor females to come over to be sexually molested? MR. YAREMA: Object to the form. A Fifth. Do you know Mike Sanka? Fifth. Would you consider Jeffrey Epstein's 43 likely to cause severe emotional distress? MR. YAREMA: Object to the form. A Fifth. Q And isn't it a fact that Jeffrey Epstein has specifically told you that it Is his intent to cause severe emotional distress, as it weakened his victims? MR. YAREMA: Object to the form. A Fifth. Q Ilas Jeffrey Epstein talked to you about your role in what he calls a criminal enterprise? MR. YAREMA: Object to the form. A Fifth. Q Has lie talked to you about his organization being a criminal enterprise, that you need to help protect? MR. YAREMA: Object to the form. A Fifth. Q What does Jeffrey Epstein do for a living? A Fifth. Q Does he profit from international sex trafficking of children? MR. YAREMA: Object to the form. A Fifth. 45 1 Q These were message pads that had a 2 carbon copy that were positioned or stationed in 3 several places around Jeffrey Epstein's home near 4 the telephone; you're familiar with those, 5 right? 6 MR. YAREMA: Object to the form. 7 A Fifth. 8 Q Since I'm assuming that you are going to 9 take the Fifth on each and every question related 10 to any messages, I will show you only one, which 11 will be marked, this one page, as Plaintiff's 12 Exhibit 1. The date on the message that I will 13 be showing you is 8/21, August 21, 2005. 14 (Message dated August 21,2005 was 15 marked as Plaintiff's Exhibit number I for 16 identification, as of this date.) 17 MR. EDWARDS: Do you want to see it 18 first? 19 MR. GOLDBERGER: (Counsel examines 20 document and hands it to the witness.) 21 Q Would you look at the exhibit, please, 22 if you can see it? I don't know if you can see 23 it over your coffee. 24 A I can see it. 25 Q Okay. Do you recognize it? 12 (Pages 42 to 45) U.S. Legal Support (561) 835-0220 EFTA00181780 1 2 3 4 5 6 7 8 46 A Filth. Q That particular message indicates it is from You're the only In the house; is that correct? MR. YAREMA: Object to the form. A Fifth. Q This is a call from you indicating that '1= cannot work today be 1 2 3 4 5 6 7 8 48 Ghisiaine Maxwell's sexual interaction with Jane Doe-102 when she was a minor? MR. YAREMA: Object to the fonn. Q This is one of many underage minor females that was trafficked basically around the globe to be sexually exploited and abused; is that correct? MR. YAREMA: Object to the fonn. here at 4:00 p.m.;" Is that right? 9 A Fifth. 10 MR. YAREMA: Object to the form? 10 Q Was that typical of Jeffrey Epstein and 11 A Fifth. 11 Ghisiaine Maxwell to sexually abuse minors on 12 Q Who Is =? 12 Jeffrey Epstein's airplane? 13 A Fifth. 13 MR. YAREMA: Object to the form. 14 MR. YAREMA: Object to the form. 14 A Fifth. 15 Q That's an underage minor female that was 15 Q And also typical of Ghislaine Maxwell 16 scheduled to be molested at Jeffrey Epstein's 16 and Jeffrey Epstein to prostitute or pimp out 17 house? 17 underage minors to friends? 18 MR. YAREMA: Object to the Iona. 18 MR. YAREMA: Object to the form. 19 A Fifth. 19 A Fifth. 20 Q You scheduled that act of molestation; 20 Q By "friends," lent talking specifically 21 is that right? 21 about people of royalty, politicians, 22 MR. YAREMA: Object to the form. 22 academicians, businessmen and other professional 23 A Fifth. 23 or personal acquaintances? 24 Q And Britney will be at the house at 4:00 24 MR. YAREMA: Object to the fonn. 25 pan. Britney is another underage minor female; 25 A Fifth. 47 49 1 is that correct? 1 Q Were you with Jeffrey Epstein on his 2 MR. YAREMA: Object to the form. 2 birthday when one of his friends sent to him 3 A Fifth. 3 12 — sorry, three 12-year olds for the purposes 4 Q That's somebody else that you were 4 of Jeffrey Epstein sexually abusing them? 5 scheduling to come to his house at 4:00 p.m. for 5 MR. YAREMA: Object to the form. 6 Jeffrey Epstein to engage in sexual acts with 6 A Fifth. 7 her, while she was an underage minor, true? 7 Q How many occasions have you observed 8 MR. YAREMA: Object to the form. 8 Jeffrey Epstein to receive as gifts front friends, 9 A Fifth. underage minor females for the purposes of hint 10 Q Do you know Les Wexner? 10 sexually abusing them? 11 A Fifth. 11 MR. YAREMA: Object to the form. 12 Q That's somebody that you know owns and 12 A Fifth. 13 operates the Victoria's Secret, the Limited? 13 Q These three 12-year olds were from 14 MR. YAREMA: Object to the form. 14 France. Were they sent to hint on his birthday by 15 A Is that a question? 15 Jean Luc Brunel or by somebody else? 16 Q Is that somebody that you know to own 16 MR. YAREMA: Object to form. 17 Victoria's Secret or operate Victoria's Secret? 17 A Fifth. 18 A Fifth. 18 Q Have you ever been made to engage in sex 19 Q Do you know if Jeffrey Epstein still 19 with 12-year olds? 20 talks with Leslie Wexner? 20 MR. YAREMA: Object to the form. 21 MR. YAREMA: Object to the form. 21 A Fifth. 22 A Fifth. 22 Q Is it true that Jeffrey Epstein makes 23 Q Do you know Jane Doe-102? 23 you dress up as a 12-year old? 24 A Fifth. 24 MR. YAREMA: Object to the form. 25 Q Are you aware of Jeffrey Epstein and 25 A Fifth. 13 (Pages 46 to 4 9) U.S. Legal Support (561) 835-0220 EFTA00181781 50 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q As part of being Jeffrey Epstein's sex slave, isn't it true that he asks you or requests of you to dress younger than 12 at times? MR. YAREMA: Object to the form. A Fifth. Q Have you seen naked photographs of the underage minor females with whom Jeffrey Epstein has engaged in sex acts? MR. YAREMA: Object to the form. A Fifth. Q Are there hidden cameras in any of Jeffrey Epstein's homes, that you know to have taken surreptitious videos or photographs of underage minors? MR. YAREMA: Object to the form. A Fifth. Q Does Jeffrey Epstein still watch pornography to this day? MR. YAREMA: Object to the form. A Fifth. Q Does Jeffrey Epstein watch homemade pornographic videos of underage minors engaging in sex orgies on his island? MR. YAREMA: Object to the form. A Fifth. 21 22 23 24 25 13 14 15 16 17 18 19 7 8 9 10 11 1 A Fifth. 2 Q Do you know Bill Riley? 3 A Fifth. 4 Q Have you seen the flight logs front 5 Jeffrey Epstein's private airplane flights? 6 MR. YAREMA: Object to the form. A Fifth. Q Are you aware that you're listed as a passenger on many flights, along with Jeffrey Epstein on his private airplane? MR. YAREMA: Object to the form. 2 A Fifth. Q Certainly comes as no surprise to you, since you were on his airplane on numerous occasions, correct? MR. YAREMA: Object to the form. A Fifth. Q On September 22,2003, you were listed as being on a flight with Ma Jeffrey 0 Epstein, S.H. and B.T. My question is who is S.H. and who is B.T.? MR. YAREMA: Object to the font. A Fifth. Q Do you know A Fifth. 51 1 Q Prior to the search warrant being 2 executed, you are aware that at least three 3 computers were taken at Jeffrey Epstein's direction, from Jeffrey Epstein's house, to avoid 5 detection by law enforcement, correct? 6 MR. YAREMA: Object to the form. 7 A Correct. 8 Q Adriana and some other person took those computers to avoid Jeffrey Epstein — to avoid the authorities obtaining the evidence contained on those computers, correct? MR. YAREMA: Object to the form. A Fifth. Q Who are the persons along with Adriana took the computers front Jeffrey Epstein's house prior to the execution of the search warrant? YAREMA: Object to the form. A Fifth. Q Where are those computers today? MR. YAREMA: Object to the form. A Fifth. Q Were they taken by his investigator, BM Riley? MR. YAREMA: Object to the form. 1 2 3 4 5 6 7 8 9 1.0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 53 Q That's somebody that you're familiar with, because you have been to Jeffrey Epstein's house on many occasions with correct? MR. YAREMA: Object to the form. A Fifth. Q In fact, do you remember there being a burglary of Jeffrey Epstein's house where he actually called the police to investigate the burglary? MR. YAREMA: Object to the fonn. A Fifth. Q And during the police investigation inside Jeffrey Epstein's house, you were speaking with both in person, at Jeffrey Epstein's house, correct? MR. YAREMA: Object to the fonn. A Correct. Q Is this another person that Jeffrey Epstein, when she was a minor, violated sexually? MR. YAREMA: Object to the form. A Fifth. Q Do you still speak withl ? MR. YAREMA: Object to the form. 14 (Pages 50 to 53) U.S. Legal Support (561) 835-0220 EFTA00181782 1 2 3 4 5 6 54 A Fifth. Q Do you know Bill Clinton? A Fifth. Q You have been on Jeffrey Epstein's airplane with Bill Clinton? MR. YAREMA: Object to the fonn. 1 2 3 4 5 6 56 Jeffrey Epstein specifically flew to Palm Beach for the purposes of engaging in sex acts with Jane Doe? MR. YAREMA: Object to the form. A Fifth. Q Generally, isn't it true Jeffrey Epstein 7 A Fifth. 7 would fly front place to place for the purpose of 8 Q Isn't take true you have been on Jeffrey Epstein's airplane with Doug Band, Bill Clinton's 8 engaging in sexual activity with minors at his destination? 10 righthand man? 10 MR. YAREMA: Object to the form. 1/. MR. YAREMA: Object to the fonn. 11 A Fifth. 12 A Filth. 12 Q Isn't it true that he employed numerous 13 Q Have you witnessed improper sexual 13 people for the sole purpose of scheduling 14 activity between Jeffrey Epstein and minors, 14 appointments with underage minor females at each 15 while he was in the presence of Bill Clinton? 15 destination he landed? 16 MR. YAREMA: Object to the fowl. 16 MR. YAREMA: Object to the form. 17 A Fifth. 17 A Fifth. 18 Q How many times have you ridden on the 18 Q What is Jeffrey Epstein's relationship 19 airplane with Jean Luc Brunel? 19 with Sandy Berger? 20 MR. YAREMA: Object to the form. 20 MR. YAREMA: Object to the fonn. 21 A Fifth. 21 A Fifth. 22 Q Each time that Jean Luc Brunel visits 22 Q Do you know what Jeffrey Epstein's 23 Jeffrey Epstein's house, does he bring underage 23 relationship is with Alan Dershowitz? 24 minors to Jeffrey Epstein's house to engage in 24 MR. YAREMA: Object to the fonn. 25 sex with? 25 A Fifth. 55 57 1 MR. YAREMA: Object to the form. 1 Q That's somebody who you know to have 2 A Fifth. 2 stayed at Jeffrey Epstein's house on many 3 Q Do you know Glenn Dubin? 3 occasions, correct? 4 A Fifth. 4 MR. YAREMA: Object to the form. 5 Q Do you know Aline Weber? 5 A Fifth. 6 A Fifth. 6 Q And also somebody who you know to have 7 Q Is that somebody that was a sexual abuse 7 been at the house when E.W. was in Jeffrey victim at one point In time of Jeffrey Epstein 8 Epstein's bedroom getting sexually abused, 9 and Jean Luc Brunei? 9 correct? 10 MR. YAREMA: Object to the form. 10 MR. YAREMA: Object to the form. 11 A Fifth. 11 A Fifth. 12 Q Between 2002 and 2005 when E.W. was 12 Q Alan Dershowitz is also somebody that 13 abused by Jeffrey Epstein sexually, isn't it true 13 you also know to have been at the house when L.M. 14 that Jeffrey Epstein took flights to Palm Beach 14 was being sexually abused in Jeffrey Epstein's 15 for the purposes of sexually abusing E.W.? 15 bedroom, correct? 16 MR. YAREMA: Object to the fonn. 16 MR. YAREMA: Object to the form. 17 A Fifth. 17 A Fifth. 18 Q And between those same years of 2002 and 18 Q Generally, Alan Dershowitz is familiar 19 2005, Isn't It true that Jeffrey Epstein took 19 with Jeffrey Epstein's habit of engaging in 20 airplane flights to Palm Beach front places 20 sexual acts with minors on a daily basis, 21 outside of the State, to engage in sexual acts 21 correct? 22 with L.M.? 22 MR. YAREMA: Object to the form. 23 MR. YAREMA: Object to the form. 23 A Fifth. 24 A Fifth. 24 Q When Alan Dershowitz was in town, 25 Q From 2003 through 2005, isn't it true 25 Jeffrey Epstein did not break his schedule for 15 (Pages 54 to 57) U.S. Legal Support (561) 835-0220 EFTA00181783 58 9 10 I1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Alan Dershowit, meaning he continued to sexually abuse minors despite Alan Dershowitz being a guest in the house? MR. YAREMA: Object to the form. A Fifth. Q Alan Dershowitz never engaged in any sexual activity with these underage minors; isn't that true? MR. YAREMA: Object to the form. A Fifth. Q Have you been made to have sex with Ghislaine Maxwell? MR. YAREMA: Object to the form. A Fifth. Q Do you know Emmy Taylor? A Fifth. Q Similar to you being Jeffrey Epstein's sex slave, is Emmy Taylor, or was Emmy Taylor Ghislaine Maxwell's sex slave? MR. YAREMA: Object to the fonn. A Fifth. Q Ghislaine Maxwell is somebody who you know to be bi-sexual, true? MR. YAREMA: Object to the form. A Fifth. 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q What was the purpose of that flight? MR. YAREMA: Object to the form. A Fifth. Q Did you sign a confidentiality agreement with Jeffrey Epstein? MR. YAREMA: Object to the form. A Fifth. Q When is the last time that you observed Jeffrey Epstein have sex with a minor? MR. YAREMA: Object to the form. A Fifth. Q Since being on probation, has Jeffrey Epstein been able to, or has he flown to his Island? MR. YAREMA: Object to the form. A Fifth. Q To your knowledge, has Jeffrey Epstein flown to New York while on probation or community control? MR. YAREMA: Object to the form. A Fifth. Q Isn't it true that he has flown both to New York and to his island, and you have accompanied hint on those trips, since he was on community control? 59 1 Q You know that Ghislaine Maxwell engaged 2 in sexual acts with underage minor females, true? 3 MR. YAREMA: Object to the fonn. 4 A Fifth. 5 Q This is yet another friend of Jeffrey 6 Epstein's that is into the act of molesting underage minor females, right? 8 MR. YAREMA: Object to the fonn. A Fifth. Q Nov, you are the next participant In that activity, meaning you have been groomed to enjoy and appreciate the acts of sex with underage minors, true? MR. YAREMA: Object to the form. A Fifth. Q Has Jeffrey Epstein instructed you to lie to his Probation Officer in any way? MR. YAREMA: Object to the form. A Fifth. Q Mr. Visoskl testified that you took a helicopter flight within the last year with Jeffrey Epstein to Miami. Do you remember that flight? MR. YAREMA: Object to the form. A Fifth. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 61 MR. YAREMA: Object to the form. A Fifth. Q Isn't It also true that Jeffrey Epstein has Indicated to you that he will always engage in sex acts with underage minor females? MR. YAREMA: Object to the form. A Fifth. Q In fact, that's something that he has told you, that he believes he Is entitled to do; isn't that right? MR. YAREMA: Object to the form. A Fifth. Q Isn't It true that Jeffrey Epstein believes and has told you that if he doesn't physically force the underage minor female into any act, then he is entitled to engage in sex with any underage minor female despite the age? MR. YAREMA: Object to the lone. A Fifth. Q What is the youngest female you have witnessed or observed Jeffrey Epstein to engage in sex with? MR. YAREMA: Object to the form. A Fifth. Q Do you have a bank account at Chase Bank 16 (Pages 58 to 61) U.S. Legal Support (561) 835-0220 EFTA00181784 62 64 1 in New York? 2 A Fifth. 3 Q And the money In that bank account under 4 your name is money that was given to you by 5 Jeffrey Epstein, correct? 6 MR. YAREMA: Object to the form. 7 A Fifth. 8 Q For the passed ten or so years, you have 9 lived with Jeffrey Epstein under his control, 10 right? 11 MR. YAREMA: Object to the font 12 A Fifth. 13 Q You get to lead the life of a 14 millionaire, and to lead that life, you were only 15 required to be Jeffrey Epstein's sex slave and to 16 bring Jeffrey Epstein other slaves? 17 MR. YAREMA: Object to the font 18 A Fifth. 19 Q Is this 301 East 66th Street apartment 20 still an apartment that you frequent today? 21 MR_ YAREMA: Object to the form. 22 A Fifth. 23 Q And you're familiar with the nine or ten 24 apartments that Jeffrey Epstein owns or controls 25 up there at 301 East 66th Street, aren't you? 1 2 3 4 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q That's somebody who these days refers to himself as Jeffrey Epstein's personal assistant, right? MR. YAREMA: Object to the form. A Fifth. Q That's somebody who you know to work for or at the Florida Science Foundation, which is owned by Jeffrey Epstein, correct? MR. YAREMA: Object to the fonn. A Fifth. Q It Is also somebody that you know to have stayed at Jeffrey Epstein's house with correct? MR. YAREMA: Object to the form. A Fifth. Q This is somebody that has been involved — Story Cowles is somebody who's been involved sexually with for at least a year, right? MR. YAREMA: Object to the form. A Fifth. Q In fact, you know that they took a trip around the world together and during that trip they discussed Jeffrey Epstein and his interaction with underage minor females, 63 1 MR. YAREMA: Object to the font 2 A Fifth. 3 Q At any given time, there are between 8 4 and 16 underage minors living in or staying at 5 those apartments? 6 MR. YAREMA: Object to the form. 7 A Fifth. 8 Q On the various passenger lists on 9 Jeffrey Epstein's airplane, where it will list, 10 for instance, Jeffrey Epstein, 11 12 13 14 15 16 17 18 19 20 21 22 23 24 5 going from Florida to St. Thomas, then generically, female, female; would you know who those female, females are? MR_ YAREMA: Object to the fonn. A Fifth. Q Are those females listed generically rather than specifically because they are underage minor females engaging in sex with you or Jeffrey Epstein? MR. YAREMA: Object to the fonn. A Fifth. Q Is Story Cowles someone that you see on a regular basis at Jeffrey Epstein's house? MR. YAREMA: Object to the font A Fifth. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 65 correct? MR. YAREMA: Object to the font A Fifth. MR. EDWARDS: Done. I don't have anything else. MR. GOLDBERGER: Okay. MR. HOROWITZ: I do, why don't we take a short break. MR. GOLDBERGER: We are stopping at I I:50. MR. HOROWITZ: What? MR. GOLDBERGER: 11:50. MR. HOROWITZ: I kind of remember that e-mail. THE VIDEOGRAPHER: Off the video record. (Pause in the proceedings.) THE VIDEOGRAPHER: We are back on the video reconl at 11:18 a.m.) (At this time Robert Critton joined the proceedings.) CROSS EXAMINATION BY MR. HOROWITZ: Q Ms. between 2001 and 2006, did Jeffrey Epstein instruct you to place telephone calls to arrange for girls under the 17 (Pages 62 to 65) U.S. Legal Support (561) 835-0220 EFTA00181785 1 2 3 4 S 66 age of 18 to come to his home for his sexual gratification? MR. YAREMA: Object to the form. A Fifth. Q Between 2001 and 2006 did you, In fact, 1 2 3 4 5 68 A Fifth. Q Did Jeffrey Epstein admit to you that he sexually abused Y.L. in his Palm Beach home in 2004? MR. YAREMA: Object to the form. 6 place telephone calls to arrange for girls under A Fifth. 7 the age of 18 to come to Jeffrey Epstein's home 7 Q Did you ever instruct a girl named 8 for his sexual gratification? a to bring other underage girls to Jeffrey 9 MR. YAREMA: Object to the form. 9 Epstein's home for Jeffrey Epstein's sexual 10 A Fifth. 10 pleasure? 11 Q Are you personally aware that a girl 11 MR. YAREMA: Object to the form. 12 named M.L. came to Jeffrey Epstein's Palm Beach 12 A Filth. 13 home in late 2004? 13 Q In 2004 did you communicate by telephone 14 YAREMA: Object to the form. 14 with nor the purpose of bringing 15 A Fifth. 15 V.1.. to Jeffrey Epstein's home for sexual 16 Q Did Jeffrey Epstein admit to you he 16 activity MR. YAREMA: Object to the fora. 17 sexually abused M.L.? 17 A Fifth. 18 MR. YAREMA: Object to the form. 18 Q Did Jeffrey Epstein instruct you to 19 A Fifth. 19 communicate with for the purpose of 20 Q Isn't It true in late 2004 you made 20 making arrangements for Y.L. to come to his home? 21 arrangements by telephone to bring M.L. to 21 MR. YAREMA: Object to the form. 22 Jeffrey Epstein's home? 22 A Fifth. 23 MIL YAREMA: Object to the form. 23 Q Did Jeffrey Epstein tell you it was his 24 A Fifth. 24 intent during the course of Y.L.'s visit to his 25 Q Did Jeffrey Epstein instruct you to 25 home to persuade, induce or entice her to engage 67 69 1 communicate by telephone to arrange for M.L. to 1 in sexual activity with him? 2 come to his home for his sexual gratification? 2 MR. YAREMA: Object to the form. 3 ML YAREMA: Object to the form. 3 A Fifth. 4 A Fifth. 4 Q Did Jeffrey Epstein admit to you that he 5 Q Did Jeffrey Epstein inform you that M.L. 5 had succeeded in, in fact, persuading, inducing 6 would be giving him a massage that was sexual in 6 or enticing Y.L. to engage in sexual activity 7 nature? 7 with hint? 8 MR. YAREMA: Object to the form. 8 MR. YAREMA: Object to the form. A Fifth. 9 A Fifth. 10 Q Did Jeffrey Epstein tell you it was his 10 Q Are you personally aware that a teenage 11 intent during the course of M.L.'s visit to his 11 girl named came to Jeffrey Epstein's Palm 12 home to persuade, induce or entice her to engage 12 Beach home on multiple occasions between 2003 and 13 in sexual activity? 13 2005? 14 MR. YAREMA: Object to the fount 14 MR. YAREMA: Object to the form. 15 A Fifth. 15 A Fifth. 16 Q Did Jeffrey Epstein tell you that, in 16 Q Did Jeffrey Epstein admit to you that he 17 fact, he succeeded in persuading, inducing or 17 sexually abused 18 enticing M.L. to engage in sexual activity with 18 MR. YAREMA: Object to the form. 19 him? 19 A Fifth. 20 MR.. YAREMA: Object to the form. 20 Q At any time prior to May of 2005, did 21 A Fifth. 21 Jeffrey Epstein instruct you to place telephone 22 Q Are you personally aware that a girl 22 calls to for the purpose of arranging for 23 named Y.L. came to Jeffrey Epstein's Palm Beach 23 her to come to his home and engage in sexual 24 home on multiple occasions in 2004? 24 activity? 25 MR. YAREMA: Object to the form. 25 MR. YAREMA: Object to the form. 18 (Pages 66 to 69) U.S. Legal Support (561) 835-0220 EFTA00181786 70 72 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 A Fifth. 2 Q Did you, in fact, communicate by 3 telephone with for the purpose of arranging 4 for her to come to his home for sexual activity? 5 MR. YAREMA: Object to the form. 6 A Fifth. 7 Q At any time prior to May of 2005, did 8 you place a telephone call to wherein you arranged for M. to come to Jeffrey Epstein's home for sexual activity? MR. YAREMA: Object to the fonn. A Fifth. Q Prior to May of 2005, did you ever observe speaking with by telephone to arrange for N. to come to Jeffrey Epstein's home? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein tell you that it was his intention to sexually abuse M. during the course of her visits to his home? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein tell you that he succeeded in engaging in sexual activity 1 2 3 4 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in either 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Did you, in fact, call A.G. to come to Jeffrey Epstein's home and give him a massage in a sexual nature in 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Dld you either observe or overhear- - speaking with A.C. on the telephone to arrange for A.C. to conic to Jeffrey Epstein's home for a massage of a sexual nature? MR. YAREMA: Object to the Iona. A Fifth. Q Did Jeffrey Epstein tell you it was his intent during the course of A.G.'s visit to his home to persuade, induce or entice her to engage in sexual activity? MR. YAREMA: Object to the form. A Fifth. Q Didn't Jeffrey Epstein admit to you that he succeeded in persuading, inducing or enticing A.G. to engage in sexual activity with him at his home while she was still a minor? MR. YAREMA: Object to the form. 71 while she was still a minor, at his home? MR. YAREMA: Object to the loon. A Fifth. Q Are you personally aware that n teenage girl named an A.C., came to Jeffrey Epstein's Palm Beach home in approximately 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein admit to you that he sexually abused A.C.. at his home while she was still a child? MR. YAREMA: Object to die fonn. A Fifth. Q In 2001 or 2002, did inform you that she received a telephone call in which she was referred to A.C., who would be willing to tome to Jeffrey Epstein's home for sexual activity? MR. YAREMA: Object to the form. A Fifth. (Whereupon, at this point in the proceedings, Robert Griffon left the deposition room.) Q Did Jeffrey Epstein instruct you to call A.C. to come to his home and give him a massage 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 73 A Fifth. Q Are you personally aware that a girl named M. came to Jeffrey Epstein's home in approximately August 2004? MR. YAREMA: Object to the font A Fifth. Q Did Jeffrey Epstein admit to you that he had sexually abused when she was only 13 years old? MR. YAREMA: Object to the form. A Fifth. Q In 2004 did you participate In a telephone call wherein you arranged for M. to come to Jeffrey Epsteln's home for the purpose of giving him a massage that was to be sexual in nature? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein instruct you to communicate by telephone and make arrangements for M. to come to his home for sexual activity while she was still a child? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein tell you it was his 19 (Pages 70 to 73) U.S. Legal Support (561) 835-0220 EFTA00181787 74 intention during the course of M.'s Ash to 1 76 MR. YAREMA: Object to the (ben. 2 his home to persuade, induce or entice her to 2 A Fifth. 3 engage in sexual activity with him? 3 Q Did you participate in a telephone call 4 MR. YAREMA: Object to the form. 4 wherein you arranged for J.M. to come to Jeffrey 5 A Fifth. 5 Epstein's home for a massage? 6 Q Did Jeffrey Epstein tell you that, in 6 MR. YAREMA: Object to the form. 7 fact, he SUCCCC(iCli in persuading, inducing and 7 A Fifth. a enticing M. to engage In sexual activity with 8 Q Did Jeffrey Epstein instruct you to 9 him while she was still a child at his home? 9 participate In a telephone call wherein you were 10 MR. YAREMA: Object to the form. 10 to arrange for J.M. to come to his home for 11 A Fifth. 11 sexual activity? 12 Q Are you personally aware that a girl 12 MR. YAREMA: Object to the form. 13 named F.P. came to Jeffrey Epstein's boost In Palm 13 A Fifth. 14 Beach on multiple occasions between 2003 and May 14 Q Did Jeffrey Epstein admit to you it was 15 of 2005? 15 his intention during the course ofJ.M.'s visit 16 MR. YAREMA: Object to the form. 16 to his home, to engage her in sexual activity 17 A Fifth. 17 while she was still a child? 16 Q Did Jeffrey Epstein admit to you that he 18 MR. YAREMA: Object to the form. 19 sexually abused F.P. at his home between 2003 and 19 A Fifth. 20 May of 2005? 20 Q Did Jeffrey Epstein admit to you he had, 21 MR. YAREMA: Object to the form. 21 in fact, persuaded, enticed and engaged J.M. in 22 A Fifth. 22 sexual activity at his home while she was still a 23 Q Prior to May of 2005, did you receive a 23 child? 24 phone call from a girl named wherein 24 MR. YAREMA: Object to the form. 25 she told you she ,vas bringing F.P. to Jeffrey 25 A Fifth. 75 77 Epstein's home to give him a massage? 1 MR. HOROWITZ: No other questions at 2 MR. YAREMA: Object to the Form. 2 this point. 3 A Fifth. 3 MR. LANGINO: I have less than ten 4 Q At any time prior to 2005, did Jeffrey 4 minutes of questioning. 5 Epstein instruct you to communicate with I= 5 MR. GOLDBERGER: Fine, that will bring 6 by telephone to make arrangements for F.P. 6 us right to the break. 7 to conic to his home? 7 CROSS EXAMINATION 8 MR. YAREMA: Object to the form. BY MR. LANGINO: A Fifth. 9 Q I'm Adam Langino and I represent B.R. 10 Q Prior to F.P.'s visits to Jeffrey 10 and C.L. 11 Epstein's home, did Jeffrey Epstein tell you it 11 Do you know an individual named B.B.? 12 was his intention to induce, entice and engage 12 A Fifth. 13 F.P., to engage in sexual activity with him? 13 Q Do you know an individual named C.L.? 14 MR. YAREMA: Object to the form. 14 A Fifth. 15 A Fifth. 15 Q Have you seen B.B. at the defendant's 16 Q After F.P.'s visits to Jeffrey Epstein's 16 Palm Beach property? 17 home, did Jeffrey Epstein tell you that he 17 MR. YAREMA: Object to the form. 18 succeeded in enticing, engaging and persuading 18 A Fifth. 19 F.P. to engage in sexual activity with him while 19 Q Have you seen C.L. at the defendant's 20 she was still a child? 20 Palm Beach property? 21 MR. YAREMA: Object to the form. 21 MR. YAREMA: Object to the form. 22 A Fifth. 22 A Fifth. 23 Q Arc you personally aware that n teenage 23 Q Have you ever engaged in a sexual act 24 girl named J.M. came to Jeffrey Epstein's Paint 4 with B.B.... B.B.? 25 Beach home in approximately 2001 or 2002? 5 MR. YAREMA: Object to the form. 20 (Pages 74 to 77) U.S. Legal Support (561) 835-0220 EFTA00181788 1 2 3 4 5 6 78 A Fifth. Q Have you ever engaged in a sexual act with C.L.... C.L.? MR. YAREMA: Object to the form. A Fifth. Q Did you ever observe the defendant, 1 2 3 4 5 6 80 with the defendant was consensual? MR. YAREMA: Object to the form. A Fifth. Q Do you know if C.L.'s sexual activity with the defendant was consensual? MR. YAREMA: Object to the form. 7 Jeffrey Epstein, with 8.6.? 7 A Fifth. 8 MR. YAREMA: Object to the form. 8 Q When you participated in sexual acts 9 A Fifth. 9 with each minor, how did you feel? 10 Q Did you ever observe the defendant, 10 MR. YAREMA: Object to the form. 11 Jeffrey Epstein, with C.L.? 11 A Fifth. 12 MR. YAREMA: Object to the form? 12 Q In your heart, did you know it was 13 A Fifth. 13 wrong? 14 Q Have you ever physically touched B.B.? 14 MR. YAREMA: Object to the form, and in 15 MR. YAREMA: Object to the form. 15 addition this is irrelevant and has already 16 A Fifth. 16 been addressed by Judge Hafele as an 17 Q Have you ever physically touched C.L.? 17 inappropriate question. That's my 18 MR. YAREMA: Object to the form. 18 objection. 19 A Fifth. 19 A Fifth. 20 Q Has the defendant ever made a statement 20 Q During this time period did you feel 21 to you about B.B.? 21 confused? 22 MR. YAREMA: Object to the form. 22 MR. YAREMA: Object to the form. 23 A Fifth. 23 MR. GOLDBERGER: Same — 24 Q Has the defendant ever made a statement 24 MR. YAREMA: Same objection. 25 to you about C.L.? 25 A Fifth. 79 81 1 MR. YAREMA: Object to the form. 1 Q Are you currently in love with the 2 A Fifth. 2 defendant? 3 Q Has ever made a statement 3 MR. YAREMA: Object to the fonn, same 4 to you about B.B.? 4 objection. That question has no relevance 5 MR. YAREMA: Object to the form. 5 to this... it is inappropriate per Judge 6 A Fifth. 6 Hafeic's order. 7 Q Has ever made a statement 7 MR. GOLDBERGER: Also involves privacy 8 to you about C.L.? 8 rights of my client. I instruct her not to 9 MR. YAREMA: Object to the form. 9 answer the question. 10 A Fifth. 10 A Fifth. 11 Q Have you ever communicated with B.B.? 11 Q Have you ever been in love with .Jeffrey 12 MR. YAREMA: Object to the form. 12 Epstein? 13 A Fifth. 13 MR. GOLDBERGER: Same objection. 14 Q Have you ever communicated with C.L.? 14 MR. YAREMA: Same objections. 15 MR. YAREMA: Object to the form. 15 A Fifth. 16 A Fifth. 16 MR. LANGINO: Thank you. 17 Q Did you know that B.B., B.B. was a minor 17 CROSS EXAMINATION 18 at the time of sexual abuse? 18 BY MS. EZELL: 19 MR. YAREMA: Object to the form. 19 (Discussion off the record.) 20 A Fifth. 20 Q Good morning, Ms. I'm 21. Q Did you know CL... C.L. was a minor at 21 Katherine Ezell and I represent Jane Doe 103, 22 the time of the sexual abuse? 22 whose name is A.H., which shall appear as A.il. in 23 MR. YAREMA: Object to the form. 23 the deposition. 24 A Fifth. 24 Are you aware that in 2004 and 5, there 25 Q Do you know if Ma's sexual activity 25 was a sort of hidden staircase that would take 21 (Pages 78 to 81) U.S. Legal Support (561) 835-0220 EFTA00181789 1 2 3 4 5 6 82 one from the kitchen upstairs to the master bedroom and massage area? MR. YAREMA: Object to the form. A Fifth. Q Do you recall there being nude photographs on the staircase? 1 2 3 4 5 6 84 Q Do you recall that Jeffrey Epstein would join in by performing oral sex on one or the other of you — you or AM.? MR. YAREMA: Object to the form. A Fifth. Q Do you recall that also happening, 7 MR. YAREMA: Object to the form. 7 meaning the oral sex, being performed on the 8 A Fifth. 8 massage table-- 9 Q Did you know AM.? 9 MR. YAREMA: Objection. 10 A Fifth. 10 Q -- to AM.? 11 Q Did A.H. come to the house at 358 El 11 MR. YAREMA: Object to the form. 12 Drillo Way to provide a massage to Jeffrey 12 A Fifth. 13 Epstein? 13 Q Were you present one day when Jeffrey 14 MR. YAREMA: Object to the form. 14 Epstein held A.H. down on the massage table and 15 A Fifth. 15 while holding her inserted his penis into A.H.'s 16 Q Did that massage become sexual in 16 vagina? 17 nature? 17 MR. YAREMA: Object to the form. 18 MR. YAREMA: Object to the form. 18 A Fifth. 19 A Fifth. 19 Q Do you recall he stated that he wanted 20 Q Did All. become a regular visitor at 20 you to observe this? 21 Jeffrey Epstein's house? 21 MR. YAREMA: Object to the fonn. 22 MR. YAREMA: Object to the form. 22 A Fifth. 23 A Fifth. 23 Q Do you recall that A.H. had rules, 24 Q Do you remember that she came maybe 24 lines, that she had stated Jeffrey Epstein was 25 hundreds of times? 25 not to cross, in their encounters? 83 85 MR. YAREMA: Object to the form. 1 MR. YAREMA: Object to the fonn. 2 A Fifth. 2 A Fifth. 3 Q Do you recall that she was under the age 3 Q Do you recall that A.H. had forbidden 4 of 18 at the time she was coming to Jeffrey 4 any kind of vaginal penetration? S Epstein's home? 5 MR. YAREMA: Object to the fonn. 6 MR. YAREMA: Object to the form. 6 A Fifth. 7 A Fifth. 7 Q Do you recall that A.H. refused to touch 8 Q Were you younger than A.H. at the time? 8 Jeffrey Epstein's penis? 9 MR. YAREMA: Object to the form. 9 MR. YAREMA: Object to the Conn. 10 A Fifth. 10 A Fifth. 11 Q Do you remember occasions when you and 11 Q Do you recall that day when Jeffrey 12 Jeffrey Epstein were already in bed when A.H. 12 Epstein held A.II. on her stomach on the massage 13 arrived? 13 table and began pumping his penis into her 14 MR. YAREMA: Object to the form. 14 vagina, that she screamed "No"? 15 A Fifth. 15 MR. YAREMA: Object to the fonn. 16 Q Do you recall Jeffrey Epstein 16 A Fifth. 17 instructing A.H. to remove her clothes and join 17 Q Do you recall that upon her screaming, 18 the two of you in bed? 18 Epstein stopped anti apologized? 19 MR. YAREMA: Object to the form. 19 MR. YAREMA: Object to the form. 20 A Fifth. 20 A Fifth. 21 Q Do you recall that you and Jeffrey 21 Q Do you recall that Jeffrey Epstein paid 22 Epstein bringing sex toys in bed for you and A.H. 22 her $1,000 for that visit? 23 to use on each other? 23 MR. YAREMA: Object to the form. 24 MR. YAREMA: Object to the form. 24 A Fifth. 25 A Fifth. 25 Q Did you engage In sex with A.H. when she 22 (Pages 82 to 85) U.S. Legal Support (561) 835-0220 EFTA00181790 1 2 86 was under 18? MR. YAREMA: Object to the fonn. 1 2 88 end of a play performance during her senior year? MR. YAREMA: Object to the form. 3 A Fifth. 3 A Fifth. 4 Q Did Jeffrey Epstein watch you and A.H. 4 THE VIDEOGRAPHER: Counsel, can we stop 5 having sex while he masturbated? for one minute? 6 MR. YAREMA: Object to the form. 6 MS. EZELL: Sure. 7 A Fifth. 7 THE VIDEOGRAPHER: Off the video reatrd a Q Are you aware that A.H.'s activities 8 11:43 a.m. 9 with Jeffrey Epstein escalated further and 9 (Short pause.) 10 further as time went on? 10 (Whereupon at this point in time, Mr. 11 MR. YAREMA: Object to the form. 11 Langino left the proceedings.) 12 A Fifth. 12 THE VIDEOGRAPHER: Back on the video 13 Q Did you sec Jeffrey Epstein use 13 record I:43 a.m. 14 vibrators and strap-on — use vibrators on A.H.? 14 CROSS EXAMINATION (CONTINUED) 15 MR. YAREMA: Object to the form. 15 BY MS. EZELL: 16 A Fifth. 16 Q Were you present in October 2005 when 17 Q Did you and A.II. engage in sex with 17 the Palm Beach Police Department raided Jeffrey 18 strap-on penises? 18 Epstein's home? 19 MR. YAREMA: Object to the form. 19 MR. YAREMA: Object to the form. 20 A Fifth. 20 A Fifth. 21 Q Did you see Jeffrey Epstein perform oral 21 Q You and others were aware that there 22 sex on A.H. numerous times? 22 would be a raid at that time; were you not? 23 MR. YAREMA: Object to the form. 23 MR. YAREMA: Object to the form. 24 A Fifth. 24 A Fifth. 25 Q Did Jeffrey Epstein pay A.H. an 25 Q Who Informed you that there would be a 87 89 1 additional 5200 to perform oral sex on you? 1 raid on the house? 2 MR. YAREMA: Object to the form. 2 MR. YAREMA: Object to the form. 3 A Fifth. 3 A Fifth. 4 Q Do you recall that each time a new toy 4 Q Did you participate in the removal of 5 or activity was introduced when A.H. was there to 5 nude photographs, sex toys, computer records from 6 give massages, Jeffrey Epstein paid A.H. 6 358 El Brillo Way prior to the raid? 7 additional money? 7 MR. YAREMA: Object to the form. 8 MR. YAREMA: Object to the fonn. 8 A Fifth. 9 A Fifth. 9 Q Do you know who removed those objects at 10 Q Would Jeffrey Epstein masturbate while 10 that time? 11 watching you and A.H. perform sexual acts? 11 MR. YAREMA: Object to the fonn. 12 MR. YAREMA: Object to the fonn. 12 A Fifth. 13 A Fifth. 13 Q Do you remember that at times Jeffrey 14 Q Do you recall that Jeffrey Epstein 14 Epstein paid A.II. to just sleep in his bed in the 15 provided A.H. with gifts of purses and 15 nude? 16 bathingsuits? 16 MR. YAREMA: Object to the form. 17 MR. YAREMA: Object to the forum 17 A Fifth. 18 A Fifth. 18 Q Do you recall at times lie paid her to 19 Q Do you recall that .Jeffrey Epstein 19 just cuddle with him? 20 provided A.N. with a blue 2000 Dodge Neon which 20 MR. YAREMA: Object to the rem]. 21 had been rented for her? 21 A Fifth. 22 MR. YAREMA: Object to the form. 22 Q Did you ever drive A.N. to or from 358 23 A Fifth. 23 El Brillo Way? 24 Q Do you recall that Jeffrey Epstein 24 MR. YAREM A: Object to the font 25 ordered that roses be delivered to A.H. at the 25 A Fifth. 23 (Pages 86 to 89) U.S. Legal Support (561) 835-0220 EFTA00181791 90 92 1 Q Did you ever know to drive 1 he would pay her 1,000 or $1,500 if she would 2 A.II. to or from 358 El Brill° Way? 2 lose ten pounds? 3 MR. YAREMA: Object to the form. 3 MR. YAREMA: Object to the form. 4 A Fifth. 4 A Fifth. Q Do you remember the houseman at that 5 Q Did you know A.H. to be a good student? 6 time as being Alfredo Rodriguez? 6 MR. YAREMA: Object to the form. 7 MR. YAREMA: Object to the font. 7 A Fifth. 8 A Fifth. 8 Q Did It appear that you that A.H. was Q Do you remember Alfredo Rodriguez being 9 smart? 10 instructed to drive A.II. to or from 358 El Brine 10 MR. YAREMA: Object to the fonn. 11 Way? 11 A Fifth. 12 MR. YAREMA: Object to the form. 12 Q Did you observe that A.II. was concerned 13 A Fifth. 13 about her grades? 14 Q Do you recall a time when Alfredo 14 MR YAREMA: Object to the fonn. 15 Rodriguez discovered A.H. asleep upstairs naked? 15 A Fifth. 16 MR. YAREMA: Object to the form. 16 Q Do you recall Jeffrey Epstein expressing 17 A Fifth. 17 interest in college ambitions? 18 Q Were you aware Jeffrey Epstein 18 MR. YAREMA: Object to the form. 19 repeatedly asked AM. to allow him to photograph 19 A Fifth. 20 her in the nude? 20 Q Have you known Jeffrey Epstein to brag 21 MR. YAREMA: Object to the fonn. 21 about donations he's made to colleges like NYU, 22 A Fifth. 22 Columbia, Harvard and Wharton? 23 Q Did you allow Jeffrey Epstein to take 23 MR. YAREMA: Object to the form. 24 photographs, nude photographs of you? 24 A Filth. 25 MR. YAREMA: Object to the fonn. 25 Q Do you know that A.H. wanted very much 91 93 1 A Fifth. 1 to go to school in New York at NYU or at 2 Q Do you recall a time when A.H. gave In 2 Columbia? 3 and did allow Jeffrey Epstein to photograph her 3 MR. YAREMA: Object to the form. 4 while nude? 4 A Fifth. 5 MR. YAREMA: Object to the form. 5 Q Did you know that Jeffrey Epstein 6 A Fifth. 6 promised to help her get info one of those 7 Q Did you ever see any of those 7 schools? 8 photographs taken by Jeffrey Epstein of A.H. in B MR. YAREMA: Object to the form. 9 the nude? 9 A Fifth. 10 MR. YAREMA: Object to the form. 10 Q Do you know whether he did help? 11 A Fifth. 11 MR. YAREMA: Object to the form. 12 Q Do you know whether those photographs 12 A Fifth. 13 were ever developed? 13 Q Do you know whether he offered to pay 14 MR. YAREMA: Object to the form. 14 some of her college expenses? 15 A Fifth. 15 MR. YAREMA: Object to the form. 16 Q Do you know what kind of camera Jeffrey 16 A Fifth. 17 Epstein liked to use when taking photographs of 17 Q Did you ever observe Jeffrey Epstein 18 women posing in the nude? 18 working with A.II. on her college applications? 19 MR. YAREMA: Object to the form. 19 MR. YAREMA: Object to the form. 20 A Fifth. 20 A Fifth. 21 Q Did you ever hear here Jeffrey Epstein 21 Q Did you ever see A.H. Just hanging out 22 tell A.II. that she needed to lose ten pounds? 22 at Jeffrey Epstein's house studying while nude? 23 MR. YAR•M A: Object to the form. 23 MR. YAREMA: Object to the form. 24 A Fifth. 24 A Fifth. 25 Q Did you ever hear here him tell her that 25 Q Did you know that Jeffrey Epstein gave 24 (Pages 90 to 931 U.S. Legal Support (561) 835-0220 EFTA00181792 94 96 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 A.H. airline tickets and theater tickets in New 2 York? 3 MR. YAREMA: Object to the form. 4 A Fifth. 5 Q Did you and A.H. ever go shopping 6 together? 7 MR. YAREMA: Object to the form. 8 A Fifth. Q Did you call A.H. once and ask her to go shopping with you for Jeffrey Epstein on his birthday? MR. YAREMA: Object to the fonn. A Fifth. Q Did you and A.N. purchase adult sex toys to use for Jeffrey Epstein's birthday, as a show, for him? MR. YAREMA: Object to the coml. A Fifth. Q Are you aware that Jeffrey Epstein told A.H. he would pay her to bring other young girls to give him massages? MR. YAREMA: Object to the fonn. A Fifth. Q Do you know that Jeffrey Epstein paid A.H. 5200 for each girl that she brought to him, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A The Fifth. Q Do you know if typically girls who Epstein knew, were given tickets to go to the show, then invited back stage? MR. YAREMA: Object to the font). A Fifth. THE VIDE•OGRAPHER: Can you speak up? THE WITNESS: (Adjusts microphone.) Q Did A.H. ever tell you that David Copperfield tried to feel her butt during dinner? MR. YAREMA: Object to the (ann. A Fifth. Q Did you ever hear Jeffrey Epstein telling any of the young women who came to give him massages, that he was a brain scientist? MR. YAREMA: Object to the form. A Fifth. Q Did you know A.D.? A Fifth. Q And from now on I will use the initials A.D. Do you know that A.D. visited Jeffrey Epstein at 358 El Brillo Way some 15 to 20 times? MR. YAREMA: Object to the form? A Fifth. Q Did you ever interact with A.D. while 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 95 to give hint a massage? MR. YAREMA: Object to the form. A Fifth. MR. GOLDBERGER: I guess we will have to take a break now, if that's all right with you. MS. EZELL: Okay. THE VIDEOGRAPHER: I I:50 a.m., going off the video record. MR. GOLDBERGER: I will be done at I:15 so we can go until 1:30. (Pause in the proceedings.) THE VIDEOGRAPHER: We are back on the video record at 1:36 p.m. CROSS EXAMINATION (CONTINUED) BY MS. EZELL: Q Ms. did you ever have dinner at Jeffrey Epstein's house, with David Copperfield as a guest, when A.H. was present? MR. YAREMA: Object to the form. A The Fifth. Q Have you met David Copperfield? A Fifth. Q Have you ever been given tickets to go see one of his shows? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 97 she was there to give a massage? MR. YAREMA: Object to the form. A Fifth. Q Did you know that at the time she was visiting Mr. Epstein and providing massages, she was under the age of 18? MR. YAREMA: Object to the form. A Firth. Q Do you recall being introduced to A.D. by Mr. Epstein? MR. YAREMA: Object to the fonn. A Fifth. Q Do you recall that Jeffrey Epstein instructed you and A.D. to kiss and fondle each other around the breasts and buttocks while massaging him? MR. YAREMA: Object to the fonn. A Fifth. Q Did you ever see Mr. Epstein use a large vibrator/massager on A.D.? MR. YAREMA: Object to the form. A Fifth. Q Did Jeffrey Epstein ever ask you to purchase a digital camera for him to give A.D.? MR. YAREMA: Object to the fonn. 25 (Pages 94 to 97) U.S. Legal Support (561) 835-0220 EFTA00181793 98 100 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 A Fifth. 2 Q Did you know that Jeffrey Epstein gave 3 A.D. a digital camera? 4 MR. YAREMA: Object to the form. 5 A Fifth. 6 MS. EZELL: I don't have any other 7 questions. Thank you. 8 MR. GOLDBERGER: You still have your microphone on. You must have something on your mind. Brad. REDIRECT EXAMINATION BY MR. EDWARDS: Q Ms.MM. through the whole day you've taken the Fifth on just about every single question. Is there any reason why we should not presume that the answer to these questions would incriminate you? MR. YAREMA: Object to the fonn. A The Fifth. Q The reason that you have taken the Fifth is because the questions you have been asked would have been answered in the affirmative and you're afraid of prosecution for your involvement, true? MR. GOLDBERGER: Don't answer that 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 21 25 THE STATE OF FLORIDA) COUNTY OF PALM BEACH) I. TERRI BECKER, a Registered Professional Reporter and Notary Public for the Suite of Florida at Large, do hereby certify that I tied the videotaped deposition of the WITNESS, called by the PLAINTIFF in the above•entitled action; that the witness was duly sworn by mc; that the foregoing pages. numbered from Ito 104, inclusive, constitute a true record of the deposition by said witness. I further certify that I ant not attorney or counsel or any of the pities, nor a relative or employee of any attorney or counsel connected with the action, nor financially interested in the action. WITNESS MY HAND and official seal in the City of West Palm Beach, County of Palm Beach, State of Florida. this 19th day of April 1010. TERRI BECKER, Registered Professional Reporter and Notary Public, State of Florida at Large. My Commission expires March 13,2011. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 99 question. It interferes with the attomey/client relationship that I have with Ms. and any discussions she and I may have had would come under that privilege. You can try and dance around that, but I'm simply not going to allow her to answer that question. If you want to bring it up with the Judge, you cart. MR. EDWARDS: Thanks, Jack. MR. GOLDBERGER: Okay. THE VIDEOGRAPHER: Off the video record at I:41 p.m. THE COURT REPORTER: You're ordering this, Brad? MR. EDWARDS: Yes. Copies? MS. EZELL: Yes. MR. YAREMA: Yes: THE COURT REPORTER: And Adam wanted it; is that right? MR. EDWARDS: Yes. (Time noted: 1:45 p.m.) 1 2 3 4 S The foregoing certificate was 6 acknowledged before me this 7 day of 2010. 8 THE STATE OF FLORIDA) COUNTY OF PALM BEACH) 9 10 11 12 13 14 15 16 ?'7 18 19 20 21 22 23 24 25 101 Notary Public, State of Florida. My commission No. Expires March 13, 2011. 26 (Pages 98 to 101) U.S. Legal Support (561) 835-0220 EFTA00181794 102 104 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 do hereby certify that I have read the foregoing transcript of my deposition given on April 13,2010; that together with the correction page attached hereto noting changes in form or substance, if any, it is true and correct. MARCINKOVA I do hereby certify that the deposition of was submitted to the witness for reading and signing; that after she had stated to the undersigned Notary Public that she had read and examined her deposition, she signed the same in the presence of the undersigned authority on the day of 2010. 1 2 3 4 U.S. LEGAL SUPPOliT Registered Professaonal !reporters 444 West Railroad Avenue Sok 300 West Palm Beads Elcala 33401 IS611335.0220 Aiwa 19.2010 5 ATTERBURY GOLDBERG. WEISS One fkarlake Crew. Stria 1400 250 Australian Avenue South West Palm Beach. Oxide 33901 8 9 10 ATIENTION: JACK GOLDBERGER. ESQ. In Re: DOE EPSTEIN Depositica at _- 11 12 One Mt Goldberger. 13 Since counsel have agreed that you nay have the witness read and sip your copy of the 19 deposition, far your conthoience, withal herewith you will fib an Ennui Sheet for the 15 winese use is Malin my changes to the deposition. 16 Thank you for slur prompt anemias 17 Conhally Yon. It US LEGAL SUPPORT 19 20 TERRI BECKER. R.:yawed Professiewal Regatta. Wary 21 Public. State offloads at Urge. My coincnission wises 22 March 13.2011. 23 CC: &Sky Edwards. Esq. Adam Horowitz. Esq. 24 Katherine Eull. Esq. David Venom. Esq. 25 1 ERRATA SHEET 2 In Re: DOE I EPSTEIN 3 DO NOT WRITE ON TRANSCRIPT ENTER CHANGES HERE: 1 5 PACE LINE CHANGE REASON 6 7 8 10 11 12 13 14 15 16 17 18 THE STATE OF FLORIDA) 19 COUNTY OF PALM BEACI I) 20 I DO IlEtUit3Y CERTIFY111AT appeared before me and slated that she has read 21 her deposilion: further, 11101 this Erna Shed was signed in my presence on this day 22 of 2010. 23 103 24 25 27 (Pages 102 to 104) U.S. Legal Support (561) 835-0220 EFTA00181795 Page 1 A able19:21 20:16 60:13 above-entitled 3:2,12 100:8 above-naiad 3:13 Absolutely 34:10 abuse40:8,18 48:11 55:7 58:2 70:20 79:18,22 abusod40:13 48:6 55:13 57:8,14 66:17 68:3 69:17 71:10 73:8 74:19 abuses41:9 abusing40:16 49:4,10 55:15 academicians 48:22 access 29:8,13 29:20 30:2 33:7,12 34:21 37:13 accompanied 60:24 account39:25 61:25 62:3 accurate 39:25 acknowledged 101:6 acquaintances 48:23 act28:16 46:20 59:6 61:16 77:23 78:2 action3:12 100:8,15,16 actions42:19 activities86:8 activity11:11 25:1 54:14 56:8 58:7 59:11 67:13 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Certainly 34:16 52:13 certificate 101:5 certified5:4 certify100:5,12 102:2,14 103:20 chance 22:23 CHANGE 103:5 changes102:5 103:3 104:15 Chapter37:18 Chase 61:25 child13:9 18:6 36:23 37:2 71:11 73:22 74:9 75:20 76:17,23 children13:24 16:8 18:17 24:2 43:23 44:2 citizen7:22 City3:6 4:8 6:25 100:18 civi115:13 18:15 Clearlake4:17 104:6 client 81:8 Clinton 54:2,5 54:15 Clinton's54:9 clothes 83:17 clothing17:11 31:6 coerced 39:10 42:4,9 coffee45:23 COLRMA114:12 college 92:17 93:14,18 colleges 92:21 Columbia 92:22 93:2 Dome 25:2 39:4 40:7 44:22 47:5 66:1,7 67:2 68:20 69:23 70:4,9 70:15 71:17 71:25 72:4,11 73:14,21 75:7 76:4,10 82:11 99:4 cows 52:13 coming 9:13 27:2 28:25 34:24 83:4 commission 100:22 101:15 104:21 commit15:22 18:20 commits17:14 24:1 common 37:7 communicate 67:1 68:13,19 70:2 73:20 75:5 communicated 79:11,14 communicating 33:21 community60:18 60:25 complete 39:24 completed 8:23 completely 39:20 computer 35:11 89:5 computers 51:3,9 51:11,15,20 concerned 92:12 conduct15:14 20:16 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Co-Counse14:17 crims19:20 crimes15:22 16:7 18:21 19:1 20:2 24:1 criminal 15:13 15:17 43:11 43:15 44:10 44:14 Critton4:12,15 65:19 71:22 cross2:3 65:21 77:7 81:17 84:25 88:14 95:15 cuddle89:19 current 5:22 6:10 7:15 currently 6:12 81:1 C.F4:3 C.L77:10,13,19 78:3,3,11,17 78:25 79:8,14 79:21,21 80:4 D3:25 5:2 deily21:3,9 57:20 dance 99:6 date1:20 5:10 45:12,16 dated2:12 45:14 David4:14 14:6 14:10 95:18 95:22 96:9 104:24 Davies52:20,24 53:3,15,24 day 38:15 50:18 84:13 85:11 98:13 100:19 101:7 102:20 103:21 days 64:1 Dear104:12 decline 5:16 defendant4:12 78:6,10,20,24 80:1,5 81:2 Defendants1:8 4:17 defendant's 77:15,19 deliberate 42:20 42:24 delinquency 40:12 delivered 87:25 demand 31:4 demanded27:13 Department 88:17 deposition1:13 3:1,10 33:25 71:23 81:23 100:6,11 102:3,14,18 103:21 104:10 104:14,15 Dershowitz 56:23 57:12,18,24 58:1,2,6 designated 16:17 designation 24:16 designs144:10 despite 58:2 61:17 destination 56:9 56:15 detection 32:13 32:22 51:5 deteriorated 34:4 developed29:7 91:13 devise 29:20 different21:8 digital 97:24 98:3 digitally 32:9 dildos27:16,21 dinner95:17 96:10 direct2:3 5:6 31:4 direction 27:22 51:4 discovered 90:15 discussed18:5 64:24 Discussion81:19 discussions 99:3 disrupted 34:12 distress43:1,6 DISTRICT1:1,1 document16:6 45:20 Dodge 87:20 Doe1:4 42:13,19 42:25 56:3 81:21 103:2 104:9 Doe-102 47:23 U.S. Legal Support (561) 835-0220 EFTA00181797 Page 3 48:2 doing25:1 33:22 donations 92:21 Doug 54:9 dress49:23 50:3 drive89:22 90:1 90:10 Dubin 55:3 duly5:3 100:9 duties 21:8 E earlier25:17 37:17 41:23 East6:16,24 62:19,25 Edwards 2:5 3:16 3:20 5:7 6:5 23:1,5 34:3,9 34:11,15,18 45:17 65:4 98:12 99:10 99:16,21 104:23 either30:19 72:1,9 ejaculating 28:17 E1 6:12 82:11 89:6,23 90:2 90:10 96:22 Emmy58:15,18,18 emotional43:1,6 employed 9:6 56:12 employee 100:14 enclosed104:14 encounters 84:25 encouraged 40:17 40:18 endured40:8 enforcement 32:14,22 51:5 engage11:10 20:16 27:8,14 31:15 40:23 47:6 49:18 54:24 55:21 61:4,16,21 67:12,16 68:25 69:6,23 72:17,23 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